DRAFT 

INITIAL REVIEW ENGINEERING REPORT 

PMN: 03-0285 ENGINEER: Prothero/JFC 

PV (kg/yr): 11,000 

SUBMITTER: Eastman Kodak Company 

USE: 

OTHER USES: 

MSDS: Yes Label: No 

General Eqp.: Safety glasses with side shields or goggles; 

impervious gloves and protective clothing. 

Respirator: NIOSH-approved with an APF of greater than or 

equal to 10. 

Health Effects: Harmful if inhaled, absorbed through 

skin, or swallowed; may be irritating to 

eyes; may cause nervous system damage 

based on animal data; the toxicological 

properties of this material have not 

been fully investigated. 

TLV/PEL (PMN or raw materials): Not given 

CRSS: 

Chemical Category: 1H-Benz[e]indolium, 1,1,2,3-tetramethyl, 

salt with 4-methylbenzenesulfonic acid 

(1:1) 

VP: <1E-06 torr @25EC 

S-H2O: <1 g/L 

MW: 395.5 

Phys State: NEAT: Solid (purple); MFG: Solid; PROC/FORM: 

NA; END USE: Destroyed. 

Consumer Use: No 

SAT (concerns): 

Migration to Groundwater = Anion rapid; Cation negl-slow 

PBT Potential = P2B1T2 

Health: 2: Moderate concern (Inhalation only) 

Eco: 2: All releases to water 

OCCUPATIONAL EXPOSURE RATING: 1-2 
INITIAL REVIEW ENGINEERING REPORT 

PMN: 03-0285 

ASSUMPTIONS: 

POLLUTION PREVENTION CONSIDERATIONS: 

EXPOSURE-BASED REVIEW: No 
INITIAL REVIEW ENGINEERING REPORT 

PMN: 03-0285 

MFG: 

Site/Location: 1 submitter site (Rochester, NY 14652) 

Days/yr: 58 (submission reports 58 batches/yr @ 24 

hours/batch) 

Process Description: 

ENVIRONMENTAL RELEASES (Eqpt. cleaning, container residue, etc.): 

WATER: 0.6 to 1.9 kg/site-day over 58 Days/year 

from: 

to: 

Basis: 

AIR: Negligible 

Basis: Solid PMN, VP < 0.01 torr 

INCINERATION: <PV 

NOTE: Submission estimates <1 kg/batch incinerated 

(<58 kg/yr). 

LANDFILL: Not required, per SAT 
INITIAL REVIEW ENGINEERING REPORT 

PMN: 03-0285 

MFG: continued 

OCCUPATIONAL EXPOSURE 

 Tot. # of workers: 15 (submission) 

 Days/yr: 58 (see above) 

Inhalation: particulate (Class I respirator): up to 150 mg/day 

Basis: OSHA PEL for nuisance dust = 15 mg/m3. Breathing 

rate = 1.25 m3/hr over 8 hours/day. 100% PMN 

concentration 

 Number of workers with inhalation exposure: 12 

Inhalation Monitoring Data Review 

1) Uncertainty (estimate based on model, regulatory limit, 

or data not specific to industry): YES 

2)a) Exposure level > 1 mg/day? YES 

b) Hazard rating for health of 2 or greater? YES 

Inhalation Monitoring data desired? YES

Dermal: contact with solids: up to 3,100 mg/day 

 100% concentration 

Basis: 
INITIAL REVIEW ENGINEERING REPORT 

PMN: 03-0285 

USE: Site-limited intermediate 

Site/Location: 1 submitter site (Rochester, NY 16452) 

Days/yr: 45 (submission) 

Process Description: 

ENVIRONMENTAL RELEASES (Eqpt. cleaning, container residue, etc.): 

WATER: Not expected 

Basis: 

AIR: Negligible 

Basis: Solid PMN, VP < 0.01 torr 

INCINERATION: <PV 

NOTE: 

LANDFILL: Not required, per SAT 
INITIAL REVIEW ENGINEERING REPORT 

PMN: 03-0285 

USE: continued 

OCCUPATIONAL EXPOSURE 

 Tot. # of workers: 6 (submission) 

 Days/yr: 45 (submission) 

Inhalation: particulate (Class I respirator): up to 150 mg/day 

Basis: OSHA PEL for nuisance dust = 15 mg/m3. Breathing 

rate = 1.25 m3/hr over 8 hours/day. 100% PMN 

concentration 

 Number of workers with inhalation exposure: 6 

Inhalation Monitoring Data Review 

1) Uncertainty (estimate based on model, regulatory limit, 

or data not specific to industry): YES 

2)a) Exposure level > 1 mg/day? YES 

c) Hazard rating for health of 2 or greater? YES 

Inhalation Monitoring data desired? YES 

Dermal: contact with solids: up to 3,100 mg/day 

 100% concentration 

Basis: