SAT Report

PMN Number: P-14-0563

SAT Date: 5/28/2014

Print Date: 4/1/2015

Related cases: Yes

Health related cases: 

Ecotox related cases: Analogs: 

On TSCA: 61791-10-4, 68071-95-4

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 1-2 3

 Persistence Bioaccum Toxicity Comments

1 11

Exposure Based Review:

Health:

Ecotox: No

Routes of exposure: Health: Dermal Drinking Water Inhalation 

Ecotox: All releases to water

Fate: ;

P2Rec Comments:

Comment: Forward without comments

Keywords:

 Keywords: LUNG, IRR-MM/L/E/S, DEV, SENS-S, ACUTE; AQUATOX

Summary of Assessment:

 Fate:

Fate Summary: P-14-0563

FATE: MW = 877 with 14% < 500 and 91% < 1000

Liquid with MP < 25 C (E)

S = Disp.

VP < 1.0E-6 torr at 25 C (E)

BP > 400 C (E)
H < 1.00E-8 (E)

POTW removal (%) = 90 via sorption an biodeg; Analog: CAS 863679-20-3: OECD 

NS(Closed Btl): 63%/28d; Analog: CAS 863679-20-3: OECD 303A(cont. activ. sludge test): < 

30.3 mg/L.

Time for complete ultimate aerobic biodeg = wk

Sorption to soils/sediments = v.strong

PBT Potential: P1B1

*CEB FATE: Migration to ground water = negl

 Health:

 Health Summary: Absorption is poor from the skin, moderate from the GI 

tract, and good from the lung (analog). Concern for surfactant effects on the lung; irritation to 

skin (chronic), mucous membranes and lung based on surfactant properties. Concerns for 

developmental toxicity based on quaternary amines and by analogy to C8-C10 alkyl 

(hydroxyethyl)dimethylammonium chloride which caused the death of 3 of 25 dams, reduced 

maternal weight gain and induced delayed ossification at 100 mg/kg with a NOEL of 50 mg/kg 

(8e-14928). There also are concerns for eye irritation and dermal sensitization based on 

submitted analogue test data, and for acute toxicity based on submitted analogue test data. 

 Test Data: Analogue Test Data for Ethoquad 1MCD/25: 

 LD50 ˃300 and ˂ 2000 mg/kg in female rats

Positive for eye irritation in rabbits.

Modified Local Lymph Node Assay (LLNA) Challenge Experiment– EPA reviewer concluded 

that this assay uses a non-guideline modified LLNA that has not been validated. These results 

cannot be used to make a conclusion concerning sensitization.

Local Lymph Node Assay (LLNA) in Mice (Identification of Contact Allergen): EPA reviewer 

concluded that assay results show that Ethoquad IMC/25 is a skin sensitizer. 

 Ecotox:

Test Organism Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 35.4 29 analog

daphnid 48-h LC50 1.2 2.58 PMN

green algal 96-h EC50 0.48 0.39 analog

fish _ chronic value 3.5

daphnid _ chronic 

value

0.12 0.26 analog

algal _ chronic 

value

0.088 0.072 analog

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic _
Value

Ecotox Values Comments: 

Predictions are based on SAR-nearest analog method for cationic surfactants-quaternary 

ammonium ( ); SAR chemical class = surfactant-cationic-quaternary ammonium-C13; 

MW302; liquid with unknown mp (P); S = dispersible (P); pH7; effective concentrations 

based on 100% active ingredients and mean measured concentrations; hardness <150.0 mg/L as 

CaCO3; and TOC <2.0 mg/L;

Ecotoxicity Test Data Results

Case Number: P-14-0563

Chemical Name: Quaternary ammonium compounds, C12-14-alkyl(hydroxyethyl)dimethyl, 

ethoxylated chlorides

CAS RN: 1554325-20-0

Trade Name: Berol R648NG

Initial Data Review 

Invertebrate Ecotoxicity Test:

(1) conducted a 48-hour toxicity test in water fleas (Daphnia magna) with 

P-14-0563 (approx. 60% purity) under static conditions. This study was reported to follow 

OECD guideline No. 202 (2004) and Method C.2 of Council Regulation (EC) No. 440/2008. 

Following a preliminary test, four replicates of five D. magna were exposed to a dilution water 

control (Dutch Standard Water) and the test substance at nominal concentrations of 0.25, 0.56, 

1.2, 2.7 and 6.0 mg/L. Chemical analysis demonstrated that test substance remained stable 

throughout the test. Corresponding mean measured concentrations of 0.22, 0.51, 1.1, 2.5, 5.6 

mg/L were determined via LC-MS/MS analysis (LOD = 0.37 μg/L). A stock solution of 109 

mg/L of the test substance was prepared by adding 0.0109 g of test substance to approximately 

80 mL of test media. The solution was then sonicated for 1 minute. A clear homogeneous stock 

solution was achieved. This solution was then made up to 100 mL with the test media and used 

to generate the nominal test concentrations. The stock was continually stirred during use. All 

vessels were covered by glass plates during the test. Over the course of the study, temperature 

ranged from 19.7-21.05oC, pH ranged from 8.0-8.3 and dissolved oxygen ranged from 9.0-9.1 

mg/L. Dilution water hardness was 212 mg CaCO3/L and TOC was ≤ 2.0 mg/L. A loading rate 

of 100 daphnids/L was calculated. Measured concentrations were 88-93% of nominal at 0 hours 

and 88-96% of nominal at 48 hours. Percent immobility at 0 (control), 0.25, 0.56, 1.2, 2.7 and 

6.0 mg/L was 0, 0, 0, 0, 55 and 100%, respectively. Based on nominal concentrations, the 

48-hour EC50 was 2.58 mg/L.

48-hour EC50 = 2.58 mg/L

(2) conducted a 10-day toxicity test in marine crustaceans (Corophium 

volutator) with P-14-0563 (purity not specified) under unspecified test conditions. This study 

was reported to follow OSPARCOM guidelines (2006) Part A: “A sediment bioassay using an

amphipod Corophium sp.” Three replicates of twenty C. volutator were exposed to the test 
substance at nominal wet weight concentrations of 10, 100, 320, 1000 and 10000 mg/kg. 

Corresponding nominal dry weight concentrations were 13.96, 139.42, 446.23, 1394.68 and 

13945.34 mg/kg, respectively. The wet to dry ratio of sediment used in this study was 1.39 and 

this was used to correct nominal wet sediment concentrations to nominal dry sediment 

concentrations. Additionally, five control replicates of twenty C. volutator were tested 

concurrently. The test substance was characterized as soluble and therefore dissolved in a small 

quantity of sea water (UV sterilized and filtered to 1 ìm) and added directly to the mixing 

container, containing the wet sediment. The mixing vessels were then placed on a platform 

shaker at approximately 150 rpm for 3 hours. After this period, the contents of each container 

were equally distributed between the replicate vessels. Tests were conducted in 1 liter capacity 

glass beakers each containing 2 cm depth (approximately 150 mL) of amended sediment and 850 

mL of overlying seawater (1 ìm filtered ultra violet treated seawater). Test vessels were covered 

with a rectangular sheet of perspex perforated with a small hole above the center of each beaker. 

Aeration was provided and a stream of air bubbles was released at a depth of approximately 6 

cm. Over the course of the study, temperature ranged from 13.8-15.5oC, pH ranged from 

7.88-8.10, dissolved oxygen ranged from 90-99% and salinity ranged from 36-44 ppt. On day 5, 

salinities 5ppt above the day 0 level were recorded in multiple vessels (at the concentration of 

320 mg/kg); however, as no unusual effects in the animals were observed at the time or at Day

10, this was deemed to have had no effect on the test result. Percent mortality at 0 (control), 

13.96, 139.42, 446.23, 1394.68 and 13945.34 mg/kg was 7, 10, 15, 13, 78 and 100%, 

respectively. Based on nominal dry weight concentrations, the 10-day LC50 was 1027.62 

mg/kg. The 10-day NOEC and LOEC values were 446.23 and 1394.68 mg/kg (dry weight), 

respectively.

This study is considered to be unacceptable.

10-day LC50 = 1027.62 mg/kg (dry weight)

10-day NOEC = 446.23 mg/kg (dry weight)

10-day LOEC = 1394.68 mg/kg (dry weight)

The test substance information and study summaries below are for an analogous chemical, not 

the actual PMN substance.

Chemical Name: Quaternary ammonium compounds, coco alkyl (hydroxylethyl) dimethyl, 

ethoxylated, chlorides

CAS RN: 863679-20-3

Trade Name: Berol R648, Ethoquad IMC1214/25, Ethoquad MC 1214/25

Fish Ecotoxicity Test:

(1) conducted a 96-hour toxicity test in zebra fish 

(Danio rerio) with an analog of the PMN substance (82% purity) under static conditions. This 

study was reported to follow OECD guideline No. 203 (1992) and EEC Directive 79/831, Annex 

V, part C.1 (1989). Following a range-finding study, single replicates of seven D. rerio were 

exposed to a dilution water control (Dutch Standard water (DSW) medium) or the test substance 

at nominal concentrations of 6.25, 12.5, 25, 50 and 100 mg/L. Mean measured concentrations at 

0, 6.25, 25 and 100 mg/L were < 0.1, 6.3, 26.3 and 103.5 mg/L respectively, as determined by 

LCMS analysis (LOD = 0.02 mg/L). To prepare the stock solution, a measured amount of 

0.9999 g of test substance was transferred into a 1 L volumetric flask which was filled with test 
medium. The stock solution was then diluted into freshly prepared test medium in order to 

obtain the desired nominal concentrations. Test vessels were covered with glass plates during 

the test. Over the course of the study, temperature ranged from 22.9-23.1oC, pH ranged from 

7.8-8.1 and oxygen saturation ranged from 8.1-8.6 mg/L. The TOC content of the dilution 

medium was ≤ 2.0 mg/L. An average biomass load of 0.32 g/L was reported. The results of the 

chemical analyses showed that the concentration of the test compound during the test remained 

within 80% of the concentration at the beginning of the test. A decrease of < 4% of test 

substance concentration during the 96 hours of testing was observed. Percent mortality at 0 

(control), 6.25, 12.5, 25, 50 and 100 mg/L was 0, 0, 0, 0, 100 and 100%, respectively. Animals 

exposed to test concentrations of 50 and 100 mg/L exhibited sublethal effects including 

surfacing and lying on the bottom of the test vessel. Based on nominal concentrations, the 

96-hour LC50 was 35.36 mg/L.

96-hour LC50 = 35.36 mg/L (82% trimethylalkyl amine ammonium salt)

96-hour LC50 = 29 mg/L (After correction to 100% active ingredient (a.i.))

(2) conducted two 96-hour acute effluent toxicity bioassay tests in 

rainbow trout (Oncorhynchus mykiss) with an analog of the PMN substance (purity not 

specified). The first test used effluent water collected from a fundraiser car wash event at a

commercial automotive service location. The second test used a simulated effluent solution 

containing a consumer car wash detergent. The simulated effluent solution was formulated 

according to the product label directions with dilution that mimicked a car wash effluent. These 

tests are termed “practical” fish toxicity tests because the effluent solutions for both were 

collected or prepared such that each represented the actual runoff water that would be expected 

to enter into storm water drains and, eventually, the streams and rivers of Puget Sound. Both 

tests were conducted according to standard protocols specified in “Methods for Measuring the 

Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine 

Organisms” (EPA-821-R-02-012). In the first test (with car wash effluent), four replicates of ten 

O. mykiss were exposed to a standard 0.5 dilution series consisting of 6.25, 12.5, 25, 50 and 

100% car wash effluent water diluted with potable water. Potable water was also used to run a 

laboratory control test. In the second test (with simulated effluent), four replicates of ten O. 

mykiss were exposed to a concentration series of 0.01, 0.05, 0.1, 0.5, 1 and 10% simulated 

effluent (laboratory-prepared effluent sample) solution diluted with potable water. Potable water 

was also used to run a laboratory control test. There were significant differences in the way the

stock water solutions for the two tests were prepared. For the first test, runoff water was 

collected from the parking lot of an automotive service facility during a fund-raising event. This 

water ran across approximately 30 feet of asphalt before collection and likely included contact 

with petroleum hydrocarbons and the grit and grime typically associated with a heavily traveled 

asphalt lot. Approximately 15 gallons of this water was sampled and delivered “as collected” to 

the laboratory. For the second test, the same detergent concentrate that was used for the car 

wash event was used by the laboratory to prepare a simulated effluent for testing. This simulated 

effluent was mixed according to instructions on the product container and was further diluted to 

simulate addition of rinse water. All water used in the second test was potable. Over the course 

of study 1, temperature ranged from 14.1-16.0oC, pH ranged from 6.7-8.3 and dissolved oxygen 

saturation ranged from 5.2-8.4%. Dilution water hardness was 99 mg/L as CaCO3. Over the 

course of study 2, temperature ranged from 10.6-11.7oC, pH ranged from 7.6-9.3 and dissolved 

oxygen saturation ranged from 8.5-11.6%. Dilution water hardness was 62 mg/L as CaCO3. In 
test 1, percent mortality at 0 (control), 6.25, 12.5, 25, 50 and 100% concentrations was 0, 100, 

100, 100, 100 and 100%, respectively. In test 2, percent mortality at 0 (control), 0.01, 0.05, 0.1, 

0.5, 1 and 10% concentrations was 0, 0, 0, 0, 0, 2.5 and 100%, respectively. Based on nominal 

concentrations, the 96-hour LC50 in test 1 was 3.125%. In test 2, the 96-hour LC50 was 

3.046%, which equates to a detergent concentrate concentration of approximately 1.6 ppm. 

Because the car wash effluent used in the first toxicity test was generated in an uncontrolled 

manner it is not possible to make conclusive remarks about the LC50 results of the toxicity test. 

This is because the amount of detergent and water used was not measured; hence, detergent 

concentrations in the dilution series were not known. Also, no chemical analyses were 

performed to determine petroleum hydrocarbon or metals concentrations in the effluent. 

Nevertheless, the effluent water sample was collected from an actual fund-raising car wash event 

and the effluent water represented an actual potential impact to a local stream. On the other

hand, the laboratory-prepared simulated effluent solution used in the second fish toxicity test 

used measured quantities of detergent and water, which allowed exact calculation of detergent

concentrations in the dilution series water. Uncertainties associated with this test include lack of 

exposure to a petroleum-contaminated asphalt parking lot and lack of exposure to grime from a 

dirty car. 

This study is considered to be unacceptable.

96-hour LC50 (test 1) = 3.125%

96-hour LC50 (test 2) = 3.046% (~ 1.6 ppm)

Invertebrate Ecotoxicity Test:

(1) conducted a 48-hour toxicity test in water fleas 

(Daphnia magna) with an analog of the PMN substance (82% purity) under static conditions. 

This study was reported to follow OECD guideline No. 202 (2004) and Directive 67/548/EEC, 

Annex V, part C.2 (1989). Following a range-finding test, four replicates of five D. magna were 

exposed to a dilution water control (Dutch Standard Water (DSW) medium) and the test 

substance at nominal concentrations of 0.2, 0.4, 0.8, 1.6 and 3.22 mg/L. The mean measured 

concentrations at 0 (control), 0.2, 0.8 and 3.2 mg/L were < 0.1, 0.165, 0.783 and 3.25 mg/L, 

respectively, as determined by LCMS analysis (LOD = 0.02 mg/L). A stock solution of 1.004 

g/L was prepared by loading 0.1004 g of test substance, weighed out on an analytical balance, in 

a 100 mL volumetric flask. The flask was filled with test medium. The stock solution was then 

manually shaken until a homogenous solution was obtained. The stock solution was then diluted 

into freshly prepared test medium in order to obtain the desired nominal concentrations. Test 

vessels were covered by glass plates during the test. Over the course of the study, temperature 

ranged from 20.25-20.40oC, pH ranged from 7.7-8.2 and dissolved oxygen ranged from 8.9-9.2 

mg/L. The NPOC (non purgable organic carbon) content in the dilution water was ≤ 2.0 mg/L. 

A loading rate of 100 daphnids/L was calculated. The results of the chemical analyses show that 

the concentration of the test compound during the test remained within 80% of the concentration 

at the beginning of the test. A decrease of < 6% of test substance concentration during the 48 

hours of testing was observed. Sub-lethal effects, such as floating at the surface, were not 

observed in the test concentrations where no immobility was observed. Percent immobilization 

at 0 (control), 0.2, 0.4, 0.8, 1.6 and 3.2 mg/L was 0, 0, 0, 5, 85 and 100%, respectively. Based on 

nominal concentrations, the 48-hour EC50 was 1.21mg/L.

48-hour EC50 = 1.21 mg/L (82% trimethylalkyl amine ammonium salt)

48-hour EC50 = 1 mg/L (After correction to 100% a.i.)
(2) conducted a 21-day reproduction test in 

water fleas (Daphnia magna) with an analog of the PMN substance (50.8% purity) under 

semi-static conditions with renewal at least three times per week to ensure constant exposure to 

the test chemical. This study was reported to follow OECD test guideline No. 211 (2008) and 

OPPTS guideline 850.1300 (1996). The test was carried out using natural surface water 

originating from a protected natural spring with a naturally low Dissolved Organic Carbon 

(DOC) and Total Suspended Solids (TSS) content, allowing a more environmentally realistic 

determination of the effects of the test chemical to be made. Following a preliminary 

range-finding study, ten replicates of one D. magna were exposed to a blank control (natural 

surface water with standard Elendt M4 media vitamins) or the test substance at nominal 

concentrations of 0.09, 0.19, 0.36, 0.75 and 1.5 mg/L. Corresponding time weighted mean 

measured concentrations of 0.07, 0.15, 0.29, 0.64 and 1.335 mg/L were determined via 

LC-MS/MS analysis. 

To prepare the stock solutions for every water renewal, approximately 0.010 g of test substance 

was weighed on an analytical balance into a 100 ml volumetric flask. Then 100 mL of test 

media was added. The stock solution was stirred at a moderate speed (so as not to produce 

excessive foam) for at least 30 minutes. The test chemical was found to be readily soluble and a 

clear homogenous stock solution was achieved. A fresh stock solution was prepared in this 

manner for each solution change. The pH of each stock solution was checked and found to be 

consistently 7.85 – 8. 0 and was therefore not adjusted. Test solutions were prepared by further 

dilution of the stock solution with the test medium to achieve the desired test concentrations. 

Beakers were covered by glass plates during the test. 

Over the course of the study, temperature ranged from 19.8-20.2oC, pH ranged from 7.4-9.2 and 

dissolved oxygen ranged from 7.6-11.9 mg/L. Dilution water hardness was < 17.8 mg CaCO3/L 

and NPOC (non purgable organic carbon) content was 2.5 mg/L. In the 0 (control), 0.09, 0.19, 

0.36, 0.75 and 1.5 mg/L test groups, the number of parent daphnids that died during testing were 

1, 0, 0, 1, 1 and 9, respectively.. The recommended guideline criteria for the coefficient of 

variation of control fecundity (less than 25% in the control based on the number of living 

neonates for each parent animal surviving at the end of the test) was achieved. There were no 

statistically significant effects on reproduction. On day 9 in the 0.75 mg/L replicate dead 

neonates were observed. This was limited to day 9 only and the dead neonates were not used in 

the neonate counts for the reproduction endpoint. This was likely to be a physical rather than 

toxic effect as the juveniles were observed stuck together at the bottom of the test vessel covered 

in algae debris. The same situation was observed on days 14 and 16 in the 1.5 mg/L replicate. 

The time to first brood occurred in all test concentrations between day 7 and 9. The test 

substance is therefore considered to have had no effect on the time to first brood at all 

concentrations. Initial analytical recovery in the stock solutions and all test concentrations were 

consistently higher than 80% of the nominal values, demonstrating sufficient initial dosing of the 

test chemical. The old solutions prior to refreshment did fall in some cases to below 80% of the 

nominal concentrations. The parallel replicates demonstrated that this was not due lack of 

substance stability but due to adhesion to the algae and hence the associated difficulties with 

analysis. It was concluded that due to the stability of the test chemical and the fact the test 
substance associates strongly with the food eaten by the test organisms, that exposure to the test 

chemical was maximized as far as was possible. Nominal concentrations were therefore used for 

endpoint calculations. Based on nominal concentrations, the 21-day EC50 for reproduction was 

1.64 mg/L. The 21-day NOEC and LOEC values for reproduction were 0.75 and 1.5 mg/L, 

respectively. The 21-day NOEC and LOEC values for length and weight were 0.36 and 0.75 

mg/L, respectively. A ChV of 1.1 mg/L was calculated for reproduction and a ChV of 0.52 

mg/L was calculated for adult length and weight.

21-day EC50 (reproduction) = 1.64 mg/L

21-day NOEC (reproduction) = 0.75 mg/L

21-day LOEC (reproduction) = 1.5 mg/L

21-day ChV (reproduction) = 1.1 mg/L

21-day NOEC (adult length and weight) = 0.36 mg/L

21-day LOEC (adult length and weight) = 0.75 mg/L

21-day ChV (adult length and weight) = 0.52 mg/L

Algal Ecotoxicity Test: 

 conducted a 72-hour toxicity test in fresh water green 

algae (Pseudokirchneriella subcapitata) with an analog of the PMN substance (82% purity) under 

static conditions. This study was reported to follow OECD guideline No. 201 (2006), EEC 

(1992) and ISO 8692 (1989). Following a preliminary range-finding study, three replicates of P. 

subcapitata (1 x 104 cells/mL) were exposed to the test substance at nominal concentrations of 

0.0625, 0.125, 0.25, 0.5 and 1.0 mg/L. Mean measured concentrations at 0.0625, 0.25 and 1.0 

mg/L were 0.03, 0.2 and 1.0 mg/L, respectively, as determined by LCMS analysis (LOD = 0.02 

mg/L). Additionally, six replicates of P. subcapitata were exposed to a blank medium control 

under similar conditions. The algae were illuminated at a light intensity within the range of 

102-103 μmol/m2/s with constant shaking. A stock solution of 1 g/L was prepared by loading 

0.1022 g of test substance, weighed out on an analytical balance, into a 100 mL volumetric flask 

which was filled with deionized water. This solution was mechanically stirred until a 

homogenous solution of about 1 g/L was obtained. This stock solution was diluted 100 times by 

transferring 2.446 mL into a 250 mL volumetric flask using a pipette. The volumetric flask was 

filled up to about 75% with deionized water and then concentrated OECD medium salt solutions 

were added. The flask was then filled up with deionized water obtaining a 10 mg/L stock 

solution in OECD medium. Test solutions were prepared by further dilution of the stock 

solution with the test medium to achieve the desired test concentrations. The test flasks were 

closed with cotton-wool stoppers. Over the course of the study, temperature ranged from 

23.25-23.50oC and pH ranged from 8.0-8.8. Dilution water hardness was 212 mg CaCO3/L and 

TOC was ≤ 2.0 mg/L. The results of the chemical analyses show a decrease of the test substance 

of 11-30% during the test. This decrease is most likely due to the adsorption of the test substance 

to the algae. The algae were thus fully exposed to the initial concentration during the whole test 

and this initial concentration deviated less than 10% from the nominal test substance 

concentration at 0.25 and 1 mg/L. The mean cell density in the control cultures increased by a 

factor of 100 within 72 hours. Based on nominal concentrations, the 72-hour EC50 for biomass 

and growth rate was 0.48 and 1.90 mg/L, respectively. The 72-hour NOEC and LOEC values 

were 0.0625 and 0.125 mg/L, respectively, for biomass and growth rate. A ChV of 0.0884 mg/L 

was calculated. 
72-hour EC50 (biomass) = 0.48 mg/L (82% a.i.)

72-hour EC50 (biomass) = 0.39 mg/L (100% a.i.)

72-hour EC50 (growth rate) = 1.90 mg/L (82% a.i.)

72-hour EC50 (growth rate) = 1.56 mg/L (100% a.i.) 

72-hour NOEC (biomass and growth rate) = 0.0625 mg/L

72-hour NOEC (biomass and growth rate) = 0.051 mg/L (100% a.i.)

72-hour LOEC (biomass and growth rate) = 0.125 mg/L

72-hour LOEC (biomass and growth rate) = 0.103 mg/L (100% a.i.)

72-hour ChV (biomass and growth rate) = 0.088 mg/L

72-hour ChV (biomass and growth rate) = 0.072 mg/L (100% a.i.) 

 submitted several ecotoxicity studies (two on 

actual PMN substance, P-14-0423 and five on an analogous chemical: Quaternary ammonium 

compounds, coco alkyl (hydroxylethyl) dimethyl, ethoxylated, chlorides with CAS RN: 

863679-20-3).

The daphnia’s study on PMN (P-14-0563) is considered to be acceptable. However, a 

10-day toxicity test in marine crustaceans (Corophium volutator) with PMN is not acceptable 

based on the following information: 1) chemical purity was not specified; 2) under unspecified 

test conditions; and 3) lack of study details reported. 

For studies submitted on the analogous chemical with CASRN 863679-20-3 are:

1) This analog chemical is acceptable;

2) The studies are considered to be acceptable, except the “Practical” Fish Toxicity Test Report.

These test results will be used to calculate the concentrations of concern (COC) for P-14-563. 

For comparative purposes, the QSAR-predicted acute and chronic fish, Daphnia, and algae 

values for P-14-0563 are 35.4 mg/L, 1.2 mg/L, and 0.48 mg/L, respectively. The predicted 

chronic values for fish, Daphnia, and algae are 3.5 mg/L, 0.12 mg/L, and 0.088 mg/L, 

respectively. The acute COC for P-14-0563 is 98 ppb (390 ppb / 4 (uncertainty factor)), based 

on the experimentally-derived 72-hour EbC50 of green algae. The chronic COC for P-14-0563 

is 2 ppb (22 ppb / 10 (uncertainty factor)), based on the experimentally-derived 72-hour chronic 

algal value.

 Acute COC = 98 ppb

Chronic COC = 2 ppb

Ecotox Reviewer:

Date: 06/03/2014
The objective of this memorandum is to address the differences of the concentrations of concerns 

(CoCs) between P-14-0563 and when both cases used the same ecotoxicity data 

submitted to EPA from 

Background 

In the PMN submission of P-14-0563, analog data were submitted to be used to assess the PMN 

along with PMN data. The analog, quarternary ammonium compound; coco alkyl 

(hydroxyethyl) dimethyl, ethoxylated, chloride (CASRN: 863679-20-3), was identified as

Concerns for ecotoxicity were determined from submitted acute aquatic invertebrate test data on 

P-14-0563. Additionally, a chronic CoC of 7 ppb was determined from a 72-hour algal study for 

the analog CASRN 863679-20-3. Surface water concentrations (7Q10 values) exceeded the CC 

for more than 20 days for several PDM (probabilistic dilution model) scenarios for processing 

and use indicating a chronic toxicity risk. Because the PMN material is predicted to sorb 

strongly to soil, the FOCUS decision was to request a fish acute test mitigated with humic acid 

(OPPTS 850.1085). In addition, the submitter was also requested to conduct a fish early-life 

stage test (OPPTS 850.1400) and the chronic daphnia test (850.1300). Below is the hazard 

profile generated from ECOSAR (v. 0.99g) and included P08-0418 toxicity:

Summary

For , it appears that the chronic green algae value was not available or included in its 

assessment. Thus, the value used for final concern concentration was the chronic daphnid’s 

value. A fish acute toxicity test mitigated by humic acid was submitted and evaluated for the 

 submission, establishing a mitigation factor (MF) of 1.6. 

The fish acute toxicity test mitigated by humic acid study did not accompany the P-14-0563 

submission and was not factored into the original P-14-0563 assessment. The submitter sent in 

the finalized daphind’s study report that concluded the chronic toxicity value of 0.26 mg/L, and 

the chronic green algae value of 0.072 mg/L as the most sensitive and environmentally 

protective endpoint. 

After further review and inclusion of the MF of 1.6 from , the acute and chronic 

concern concentration values were recalculated. 

Conclusion

These test results will be used to calculate the CoC for P-14-563. For comparative purposes, the 

QSAR-predicted acute and chronic fish, Daphnia, and algae values for P-14-0563 are 35.4 mg/L, 

1.2 mg/L, and 0.48 mg/L, respectively. The predicted chronic values for fish, Daphnia, and 

algae are 3.5 mg/L, 0.12 mg/L, and 0.088 mg/L, respectively. 

The acute CoC for P-14-0563 is 156 ppb (390 ppb / 4 (uncertainty factor), then multiplied by MF 

of 1.6, based on the experimentally-derived 72-hour EbC50 of green algae. The chronic CoC for 
P-14-0563 is 11 ppb (70 ppb / 10 (uncertainty factor), then multiplied by MF of 1.6), based on 

the experimentally-derived 72-hour chronic algal value.

Acute CoC = 156 ppb

Chronic CoC = 11 ppb

Ecotox Reviewer: 

Date: 07/09/2014

Factors Values Comments

Assessment Factor

10

Concentration of Concern 

(ppb)

11

SARs cationic surfactants-quaternary 

ammonium

SAR Class surfactant-cationic-quaternary 

ammonium-C13

Ecotox Category Cationic (quaternary ammonium) 

surfactants

Ecotox Factors Comments: 

 SAT Chair: