^^EZDy% United States
LhI	Environmental Protection Agency
Office of Chemical Safety and
Pollution Prevention
Proposed Designation of
Triphenyl Phosphate
(CASRN 115-86-6)
as a High-Priority Substance
for Risk Evaluation
August 22,2019

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Table of Contents
List of Tables	iii
Acronyms and Abbreviations	iv
1.	Introduction	1
2.	Production volume or significant changes in production volume	3
Approach	3
Results and Discussion	3
3.	Conditions of use or significant changes in conditions of use	3
Approach	3
CDR Tables	4
CDR Summary and Additional Information on Conditions of Use	8
4.	Potentially exposed or susceptible subpopulations	9
Approach	9
Results and Discussion	9
5.	Persistence and bioaccumulation	10
Approach	10
Physical and Chemical Properties and Environmental Fate Tables	10
Results and Discussion	13
6.	Storage near significant sources of drinking water	13
Approach	13
Results and Discussion	13
7.	Hazard potential	14
Approach	14
Potential Human Health and Environmental Hazard Tables	14
8.	Exposure potential	17
Approach	17
Results and Discussion	17
9.	Other risk-based criteria that EPA determines to be relevant to the designation of the
chemical substance's priority	20
10.	Proposed designation and Rationale	20
11.	References	21
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List of Tables
Table 1. 1986-2015 National Aggregate Production Volume Data (Production Volume in
Pounds)	3
Table 2. Triphenyl Phosphate (115-86-6) Categories and Subcategories of Conditions of Use
(2016 CDR Reporting Cycle)	5
Table 3. Triphenyl Phosphate (115-86-6) Categories and Subcategories of Conditions of Use
(2012 CDR Reporting Cycle)	6
Table 4. Uses in Children's Products Information	9
Table 5. Physical and Chemical Properties of Triphenyl Phosphate	10
Table 6. Environmental Fate Characteristics of Triphenyl Phosphate	12
Table 7. Potential Human Health Hazards Identified for Triphenyl Phosphate	14
Table 8. Potential Environmental Hazards Identified for Triphenyl Phosphate	15
Table 9. Exposure Information for Consumers	18
Table 10. Exposure Information for the Environment and General Population	19
in

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Acronyms and Abbreviations
Term
Description
ATSDR
Agency for Toxic Substances and Disease Registry
BOD
Biochemical oxygen demand
CAA
Clean Air Act
CASRN
Chemical Abstracts Service Registry Number
CBI
Confidential business information
CDR
Chemical Data Reporting
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
CPDat
Chemical and Products Database
ECHA
European Chemicals Agency
EPA
Environmental Protection Agency
EPCRA
Emergency Planning and Community Right-to-Know Act
HSDB
Hazardous Substances Data Bank
IUR
Inventory Update Rule
K
Thousand
Koc
Organic carbon-water partition coefficient
Kow
Octanol-water partition coefficient
M
Million
MITI
Ministry of International Trade and Industry
MP
Melting point
NIH
National Institutes of Health
NKRA
Not known or reasonably ascertainable
NR
Not reported
OECD
Organisation for Economic Co-operation and Development
OH
Hydroxyl radical
PEL
Permissible exposure limit
SIDS
Screening Information Data Sets
iv

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Term	Description
SMILES	Simplified molecular-input line-entry system
TLV	Threshold limit value
TPP	Triphenyl phosphate
TRI	Toxics Release Inventory
TSCA	Toxic Substances Control Act
VP	Vapor pressure
WS	Water solubility
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1. Introduction
In section 6(b)(1)(B) of the Toxic Substances Control Act (TSCA), as amended, and in the U.S.
Environmental Protection Agency's (EPA) implementing regulations (40 CFR 702.3)1, a high-
priority substance for risk evaluation is defined as a chemical substance that EPA determines,
without consideration of costs or other non-risk factors, may present an unreasonable risk of
injury to health or the environment because of a potential hazard and a potential route of
exposure under the conditions of use, including an unreasonable risk to potentially exposed or
susceptible subpopulations identified as relevant by EPA.
Before designating prioritization status, under EPA's regulations at 40 CFR 702.9 and pursuant
to TSCA section 6(b)(1)(A), EPA will generally use reasonably available information to screen
the candidate chemical substance under its conditions of use against the following criteria and
considerations:
	the hazard and exposure potential of the chemical substance;
	persistence and bioaccumulation;
	potentially exposed or susceptible subpopulations;
	storage near significant sources of drinking water;
	conditions of use or significant changes in the conditions of use of the chemical
substance;
	the chemical substance's production volume or significant changes in production volume;
and
	other risk-based criteria that EPA determines to be relevant to the designation of the
chemical substance's priority.
This document presents the review of the candidate chemical substance against the criteria and
considerations set forth in 40 CFR 702.9 for a may present risk finding. The information sources
used are relevant to the criteria and considerations and consistent with the scientific standards of
TSCA section 26(h), including, as appropriate, sources for hazard and exposure data listed in
Appendices A and B of the TSCA Work Plan Chemicals: Methods Document (February 2012)
(40 CFR 702.9(b)). Final designation of the chemical substance as a high-priority chemical
substance would immediately initiate the risk evaluation process as described in the EPA's final
rule, Procedures for Chemical Risk Evaluation Under the Amended Toxic Substances Control
Act (40 CFR 702).
Triphenyl phosphate (TPP) is one of the 40 chemical substances initiated for prioritization as
referenced in the March 21, 2019 notice (84 FR 10491)2. EPA has determined that TPP is a
suitable candidate for the proposed designation as a high-priority substance. The proposed
designation is based on the results of the review against the aforementioned criteria and
1	NOTE: For all 40 CFR 702 citations, please refer to:
https://www.govinfo.gov/content/pkg/CFR-2018-tiUe40-vol33/xml/CFR-2018-title40-vol33-part702.xml and
https://www.regulations.gov/document?D=EPA-HO-OPPT-2016-0654-01Q8
2	https://www.federalregister.gov/docnments/2019/03/21/2019-5404/in.itiation-of-prii3ritization-nnder-the-toxic-
substances-control-act-tsca
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considerations as well as review of the reasonably available information on TPP, including
relevant information received from the public and other information as appropriate.
EPA will take comment on this proposed designation for 90 days before finalizing its designation
of TPP. The docket number for providing comments on TPP is EPA-HQ-OPPT-2018-0458 and
is available at www.regulations.gov.
The information, analysis and basis used for the review of the chemical is organized as follows:
	Section 1 (Introduction): This section explains the requirements of the amended TSCA
and implementing regulations - including the criteria and considerations - pertinent to the
prioritization and designation of high-priority chemical substances.
	Section 2 (Production volume or significant changes in production volume): This section
presents information and analysis on national aggregate production volume of the
chemical substance.
	Section 3 (Conditions of use or significant changes in conditions of use): This section
presents information and analysis regarding the chemical substance's conditions of use
under TSCA.
	Section 4 (Potentially exposed or susceptible subpopulations): This section presents
information and analysis regarding potentially exposed or susceptible subpopulations,
including children, women of reproductive age, and workers, with respect to the chemical
substance.
	Section 5 (Persistence and bioaccumulation): This section presents information and
analysis regarding the physical and chemical properties of the chemical substance and the
chemical's fate characteristics.
	Section 6 (Storage near significant sources of drinking water): This section presents
information and analysis considered regarding the risk from the storage of the chemical
substance near significant sources of drinking water.
	Section 7 (HazardPotential): This section presents the hazard information relevant to the
chemical substance.
	Section 8 (Exposure Potential): This section presents information and analysis regarding
the exposures to the chemical substance.
	Section 9 (Other risk-based criteria): This section presents the extent to which EPA
identified other risk-based criteria that are relevant to the designation of the chemical
substance's priority.
	Section 10 (Proposed designation): Based on the results of the review performed and the
information and analysis presented, this section describes the basis used by EPA to
support the proposed designation.
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2. Production volume or significant changes in production volume
Approach
EPA considered current volume or significant changes in volume of the chemical substance
using information reported by manufacturers (including importers). EPA assembled reported
information for years 1986 through 2015 on the production volume for TPP reported under the
Inventory Update Reporting (IUR) rule and Chemical Data Reporting (CDR) rule.3 The national
aggregate production volume, which is presented as a range to protect individual site production
volumes that are confidential business information (CBI), is presented in Table 1.
Results and Discussion
Production volume of TPP in 2015, as reported to EPA during the 2016 CDR reporting period,
was between 1 and 10 million pounds. Production volume of TPP as reported to EPA has
generally decreased over the period 1986-2015, with significant fluctuations between some years
(Table 1).
Table 1.1986-2015 National Aggregate Production Volume Data (Production Volume in
Pounds) 										
Chemical
ID
1986
1990
1994
1998
2002
2006
2011
2012
2013
2014
2015
Triphenyl
phosphate
(TPP)
(115-86-6)
>10M
to 50M
>1M
tolOM
>10M
to 50M
>10M
to 50M
>10M
to 50M
lOMto
<50M
11M
lMto
10M
lMto
10M
10M
to
50M
lMto
10M
M = million
Reference: U.S. EPA (20.1.3) and U.S. EPA (20.1.7)
3. Conditions of use or significant changes in conditions of use
Approach
EPA assembled information to determine conditions of use or significant changes in conditions
of use of the chemical substance. TSCA section 3(4) defines the term "conditions of use" to
mean the circumstances, as determined by the Administrator, under which a chemical substance
3 Over time, the requirements for reporting frequency, production volume thresholds, and chemical substances under
the Chemical Data Reporting (CDR) rule have changed. CDR was formerly known as the Inventory Update Rule
(IUR). The first IUR collection occurred in 1986 and continued every four years through 2006. As part of two
rulemakings in 2003 and 2005, EPA made a variety of changes to the IUR, including to change the reporting
frequency to every five years to address burdens associated with new reporting requirements. Additional changes to
reporting requirements were made in 2011, including to suspend and replace the 2011 submission period with a
2012 submission period, return to reporting every four years, and require the reporting of all years beginning with
2011 production volumes. The reporting of production volumes for all years was added because of the mounting
evidence that many chemical substances, even larger production volume chemical substances, often experience wide
fluctuations in production volume from year to year. In addition, also as part of the 2011 IUR Modifications final
rule (76 FR 50816, Aug 16, 2011), EPA changed the name of the regulation from IUR to CDR to better reflect the
distinction between this data collection (which includes exposure-related data) and the TSCA Inventory itself (which
only involves chemical identification information).
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is intended, known, or reasonably foreseen to be manufactured, processed, distributed in
commerce, used, or disposed of.
A key source of reasonably available information that EPA considered for determining the
conditions of use for TPP was submitted by manufacturers (including importers) under the 2012
and 2016 CDR reporting cycles. CDR requires manufacturers (including importers) to report
information on the chemical substances they produce domestically or import into the United
States greater than 25,000 pounds per site, except if certain TSCA actions apply (in which case
the reporting requirement is greater than 2,500 pounds per site). CDR includes information on
the manufacturing, processing, and use of chemical substances. Based on the known
manufacturing, processing and uses of this chemical substance, EPA assumes distribution in
commerce. CDR may not provide information on other life-cycle phases such as distribution or
chemical end-of-life after use in products (i.e., disposal). While EPA may be aware of additional
uses, CDR submitters are not required to provide information on chemical uses that are not
regulated under TSCA.
For chemical substances under review that are included on the Toxics Release Inventory (TRI)
chemical list, information disclosed by reporting facilities in Part II Section 3 ("Activities and
Uses of the Toxic Chemical at the Facility") of their TRI Form R reports was used to supplement
the CDR information on conditions of use. There is not a one-to-one correlation between
conditions of use reported under CDR and information reported in Part II Section 3 of the TRI
Form R because facilities are not required to disclose in their Form R submissions the specific
uses of TRI chemical substances they manufactured on-site or imported.
TPP is not on the list of chemicals required to be reported to the TRI chemical list. For purposes
of this proposed prioritization designation, EPA assumed end-of-life pathways that include
releases to air, wastewater, and solid and liquid waste based on the conditions of use.
CDR Tables
Based on the publicly available4 manufacturing information, industrial processing and use
information, and consumer and commercial use information reported under CDR, EPA
developed a list of conditions of use for the 2016 and 2012 reporting cycles (Tables 2 and 3,
respectively).
4 Some specific chemical uses may be claimed by CDR submitters as confidential business information (CBI) under
section 14 of TSCA. In these cases, EPA indicated that the information is CBI.
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Table 2. Triphenyl Phosphate (115-86-6) Categories and Subcategories of Conditions of
Use (2016 CDR Reporting Cycle)5 		
Life-Cycle Stage
Category
Subcategory
Reference
Manufacturing
Domestic
manufacturing/Import
CBI6
U.S. EPA (2019)

Import
Import
U.S. EPA (2019)

Processing
Processing -
incorporation into
formulation, mixture,
or reaction product
Solvents (which become part of product
formulation or mixture) in photographic
film paper, plate, and chemical
manufacturing
U.S. EPA (2019)

Flame retardants in:
-	All other chemical product and
preparation manufacturing
-	Plastics product manufacturing
-	Utilities
-	Computer and electronic product
manufacturing
-	Plastic material and resin
manufacturing
-	Textiles, apparel, and leather
manufacturing
U.S. EPA (2019)
Paint additives and coating additives not
described by other categories used in paint
and coating manufacturing
U.S. EPA (2019)

Processing
Processing -
incorporation into
article
Solvents (which become part of product
formulation or mixture) in photographic
film paper, plate, and chemical
manufacturing
U.S. EPA (2019)

Plasticizers in plastics Product
manufacturing
U.S. EPA (2019)
Distribution in
commerce
Distribution in
commerce


Commercial Use
Photographic
supplies, film, and
photo chemicals
Photographic supplies, film, and photo
chemicals
i. ? = . EPA (2019)
Commercial Use
Plastic and rubber
products not covered
elsewhere
Plastic and rubber products not covered
elsewhere
U.S. EPA (2019)

5	Certain other uses that are excluded from TSCA are not captured in this table.
6	At this time, "CBI" indicates that a data element has been claimed CBI by the information submitter; it does not
reflect the result of an EPA substantiation review.
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Life-Cycle Stage
Category
Subcategory
Reference
Manufacturing
Domestic
manufacturing/Import
CBI6
U.S. EPA (2019)

Import
Import
U.S. EPA (2019)
Commercial Use
Lubricants and
greases
Lubricants and greases
U.S. EPA (2019)

Commercial Use
Paints and coatings
Paints and coatings
U.S. EPA (2019)
Consumer Use
Photographic
supplies, film, and
photo chemicals
Photographic supplies, film, and photo
chemicals
319)
Consumer Use
Plastic and rubber
products not covered
elsewhere
Plastic and rubber products not covered
elsewhere
U.S. EPA (2019)

Consumer Use
Foam seating and
bedding products
Foam seating and bedding products
U.S. EPA (2019)
a CDR includes information on the manufacturing, processing, and use of chemical substances. CDR may not
provide information on other life-cycle phases such as distribution or chemical end-of-life after use in products
(i.e., disposal). The table row is highlighted in gray to indicate that no information is provided for this life-cycle
stage.
b EPA is particularly interested in information from the public on distribution in commerce.
Table 3. Triphenyl Phosphate (115-86-6) Categories and Subcategories of Conditions of
Use7 (2012 CDR Reporting Cycle)
Life-Cycle Stage
Category
Subcategory
Reference
Manufacturing
Domestic
manufacturing
Domestic manufacturing
U.S. EPA (2019)

Manufacturing
Import
Import
U.S. EPA (2019)
Processing
Processing -
incorporation into
formulation, mixture
or reaction product
Flame retardants in:
-	Plastic material and resin manufacturing
-	Rubber product manufacturing
-	Utilities
-	Computer and electronic product
manufacturing
-	Photographic film paper, plate, and
chemical manufacturing
U.S. EPA (2019)

Processing
Processing -
incorporation into
formulation, mixture
or reaction product
Plasticizers in all other chemical product
and preparation manufacturing
U.S. EPA (2019)

7 Certain other uses which are excluded from TSCA are not captured in this table.
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Life-Cycle Stage
Category
Subcategory
Reference
Processing
Processing -
incorporation into
article
Flame Retardants in:
-	Furniture and related product
manufacturing
-	Plastics material and resin
manufacturing
-	Plastic products manufacturing
U.S. EPA (2019)
Distribution in
( ommcicc
Dislnliulion in
commerce


Commercial Use
Electrical and
electronic products
Electrical and electronic Products
U.S. EPA (2019)
Commercial Use
Foam seating and
bedding products
Foam seating and bedding products
U.S. EPA (2019)

Commercial Use
Furniture and
furnishings not
covered elsewhere
Furniture and furnishings not covered
elsewhere
U.S. EPA (2019)

Commercial Use
Lubricants and
greases
Lubricants and greases
U.S. EPA (2019)

Commercial Use
Photographic
supplies, film, and
photo chemicals
Photographic supplies, film, and photo
chemicals
U.S. EPA (2019)

Commercial Use
Plastic and rubber
products not covered
elsewhere
Plastic and rubber products not covered
elsewhere
U.S. EPA (2019)

Consumer
Plastic and rubber
products not covered
elsewhere
Plastic and rubber products not covered
elsewhere
U.S. EPA (2019)
Disposal
Disposal


CL)k includes information on the manufacturing, processing, and use of chemical substance. CDR may not
provide information on other life-cycle phases such as distribution or chemical end-of-life after use in products
(i.e., disposal). The table row is highlighted in gray to indicate that no information is provided for this life-cycle
stage.
b EPA is particularly interested in information from the public on distribution in commerce.
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CDR Summary and Additional Information on Conditions of Use
For the 2016 CDR, manufacturers and importers reported the following functional uses of TPP:
as a solvent, flame retardant, additive, and plasticizer. TPP was reported as used in industrial
sectors that manufacture chemical products, computer and electronics products, paints and
coatings, photographic products, plastic material and resin, and plastic products. TPP was also
used in the utilities sector. Companies reported commercial and consumer uses in photographic
supplies and in plastic and rubber products. Two additional commercial uses that were not also
reported as consumer uses were for lubricants and greases and for paints and coatings. An
additional consumer use for TPP was for foam seating and bedding products. Consumer uses
were also identified in additional databases, which are included in the Exposure Potential section
(Section 8).
The uses reported for the 2012 CDR were similar to the 2016 CDR except: 1) TPP was not used
as a solvent or additive; 2) it was used by the furniture and related product manufacturing sector
and in the rubber product manufacturing sector but not in the textiles or paints and coatings
sectors; 3) the chemical was used commercially for electrical and electronic products, foam
seating and bedding, and furniture but not for paints and coatings; and 4) consumer use was not
reported in photographic products or in foam seating and bedding (Tables 2 and 3, respectively).
In conclusion, according to CDR data, industrial, commercial and consumer uses have changed
somewhat between the 2012 and 2016 CDR.
Additional information on uses of TPP is available in public comments submitted to EPA on the
Initiation of Prioritization Process. The American Coatings Association reported use of TTP as a
plasticizer and additive in adhesives, sealants, and lubricants in concentrations between 0.1% and
10% (EPQ-HQ-OPPT-2018-0458-0003). The Aerospace Industries Association commented that
TPP is used in "hydraulic fluids, coating materials, foams, lubricants, and engine oils. Specific
aerospace industrial uses include, but may not be limited to: penetrants used for non-destructive
inspection, hydraulic fluids, engine and transmission oils, edge-filling and potting compounds,
epoxy adhesives for bonding inserts in honeycomb sandwich panels, ducts and construction of
structural composite parts, leveling compounds to assist in drainage, lubricants for bending and
swaging aluminum, titanium and corrosion resistant steel (CRES) tubes and ducts, flexible wing
coatings, heat resistant secondary fuel barriers, specialty foams for insulation and microwave
absorption, landing gear greases, oils and lubricants" (EPQ-HQ-OPPT-2018-0458-0004). More
information on uses may be found following this screening review.
Should the Agency decide to make a final decision to designate this chemical substance as a
high-priority substance, further characterization of relevant TSCA conditions of use will be
undertaken as part of the process of developing the scope of the risk evaluation.
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4. Potentially exposed or susceptible subpopulations
Approach
In this review, EPA considered reasonably available information to identify potentially exposed
or susceptible subpopulations, such as children, women of reproductive age, workers, consumers
or the elderly. EPA analyzed processing and use information included on the CDR Form U.
These data provide an indication about whether children or other susceptible subpopulations may
be potentially exposed. EPA also used human health hazard information to identify potentially
exposed or susceptible subpopulations.
Results and Discussion
Based on the 2012 and 2016 CDR data, TPP was not reported in children's products, although
there is potential for exposure to children from some consumer products that were reported to
CDR. While the most recent health effects assessments reviewed did not discuss the
susceptibility of children to potential adverse health effects of exposure to TPP, effects were
observed in developmental toxicity studies. Pregnant women or women of reproductive age are
therefore included as a potentially exposed or susceptible subpopulation with respect to TPP.
At this stage, EPA identified children, women of reproductive age, workers and consumers as
subpopulations who may be potentially exposed or susceptible subpopulations for TPP.
Children
EPA used data reported to the 2012 and 2016 CDR to identify uses in products and articles
intended for children over time for TPP. Table 4 summarizes the non-CBI CDR information
regarding commercial and consumer use and if the chemical substance was being used in
products intended for children. The 2012 and 2016 CDR did not include any uses in children's
products. However, some of the consumer products reported to CDR could potentially expose
children to TPP, including foam bedding and seating, and rubber and plastic products. EPA also
identified potential developmental hazards that would impact any stage of children's
development.
Table 4. Uses in Children's Products Information8
Chemical
Year
Product Category
Consumer or
Commercial
Used in
Products Intended
for Children
Triphenyl phosphate
(115-86-6)
2012
Plastic and rubber
products
Consumer
NKRA
2016
Plastic and rubber
products
Consumer
NKRA
Note(s): NKRA = not known or reasonably ascertainable
Reference: U.S. EPA (20.1.9)
Women of reproductive age (e.g., pregnant women per TSCA statute)
EPA identified developmental and reproductive toxicity studies following TPP exposure;
however, only developmental effects were observed (Section 7, Table 7). Although no
8 Certain other uses which are excluded from TSCA are not captured in this table
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reproductive hazards were identified, EPA considers women of reproductive age as potentially
exposed. During the scoping and risk evaluation process, reproductive hazards will be
considered again following a systematic search of the relevant scientific literature.
Consideration of women of reproductive age as a potentially exposed or susceptible
subpopulation was also based on exposure because women of reproductive age are potential
workers in the manufacturing, processing, distribution in commerce, use, or disposal of the
chemical substance.
Workers
Please refer to the Exposure Potential section (Section 8) for a summary of potential
occupational exposures, which EPA indicates that workers are potentially exposed or susceptible
subpopulations based on greater exposure.
Consumers
Please refer to the Exposure Potential section (Section 8) for a summary of potential consumer
exposures, which EPA indicates that consumers are potentially exposed or susceptible
subpopulations based on greater exposure.
5. Persistence and bioaccumulation
Approach
EPA reviewed reasonably available information, such as physical and chemical properties and
environmental fate characteristics, to understand on TPP's persistence and bioaccumulation.
Physical and Chemical Properties and Environmental Fate Tables
Table 5 and Table 6 summarize the physical and chemical properties and environmental fate
characteristics of TPP, respectively.
Table 5. Physical and Chemical Properties of Triphenyl Phosphate
Property or
Endpoint
Value3
Reference
Molecular Formula
Ci8H1504P
CRC Handbook (Rumble, 2018)
Molecular Weight
326.283 g/mole
CRC Handbook (Rumble, 2018)
Physical State
Solid
HSDB (2019) citina CRC
Handbook (Haynes, 2014)
Physical Form
Crystals, prisms, needles
CRC Handbook (Rumble, 2018)
Purity
100% and 99% reported in studies
HSDB (2019)
Melting Point
49.39 C
CRC Handbook (Rumble, 2018);
HSDB (2019)
Boiling Point
414 C
ECHA (2019)
Density
1.2055 g/cm3 at 50 Cb
CRC Handbook (Rumble, 2018)
1.21 g/cm3 at 50 C
ECHA (2019)
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Property or
Endpoint
Value3
Reference
Vapor Pressure
6.4 x 10"6 mm Hg at 25 C (extrapolated)13
ECHA (2019) citing Dorbv and
Keller (1957)
6.28 x 10"6 mm Hg at 25 C (extrapolated)
PlivsproD (2012)
Vapor Density
1.19 (relative vapor density to air =1)
HSDB (2019) citina Toscano
(2012)
Water Solubility
1.9 mg/L at 20 C
ECHA (20.1.9) citing Saeger et al.
(1979)
Log Kow
4.59
HSDB (20.1.9) citina Hansch et al.
(1995)
Henry's Law
Constant
3.31 x 10"6 (atm-m3/mol) at 25 C
(estimated)0
HSDB (20.1.9) citina EPI Suite
(2012)
Flash Point
220 C (closed cup)
HSDB (20.1.9) citina NFPA (2010)
Auto Flammability
Nonflammable
HSDB (20.1.9) citina O'Neil (2013)
Viscosity
11 mm2/s at 323 C
ECHA (20.1.9)
Refractive Index
1.55 at 60 C
HSDB (20.1.9) citina Larranaaa
(2016)
Dielectric Constant
TBD
TBD
Surface Tension
TBD
TBD
Notes:
aMeasured unless otherwise noted;
bSelected value;
EPI Suite physical property inputs: Log K0w = 4.59, MP = 50.5 C, VP = 6.4 x 10~6mm Hg, WS = 1,900 mg/L,
SMILES:0=P(0c(ccccl)cl)(0c(cccc2)c2)0c(cccc3)c3
TBD = to be determined, if reasonably available. EPA is particularly interested in information from the public
on these properties or endpoints.
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Table 6. Environmental Fate Characteristics of Triphenyl Phosphate
Property or Endpoint
Value3
Reference
Direct Photodegradation
Not expected to be susceptible to direct photolysis by
sunlight because the chemical does not absorb light at
wavelengths >290 nm
HSDB (2019)
Indirect Photodegradation
ti/2 = 12 hours
(based on -OH reaction rate constant of
1.11 x 10"11 cm3/mol-second at 25 C and 5 * 105 -OH
radicals/cm3; estimated)13
HSDB (2019) citina
EPI Suite (2012)
Hydrolysis
11/2 = 19 days (pH 7 at 25 C)
11/2 = 3 days (pH 9 at 25 C)
HSDB (2019) citina
Mayer (1981)
11/2 = 7.5 days (pH 8.2 at 21 C)
11/2 =1.3 days (pH 9.5 at 21 C)
HSDB (2019) citina
Howard (1979)
Biodegradation (Aerobic)
ti/2 = 2-4 days in river die-away tests (Mississippi River)
HSDB (2019) citina
Saeger(1979)
48% mineralization/32 days; ti/2 = 37 days (loamy sand)
HSDB (2019) citina
Anderson (1993)
100%/7-8 days (freshwater)
HSDB (2019) citina
Howard (1979)
83-94%/4 weeks based on BOD (Japanese MITI test)
HSDB (2019) citina
NITE (2019)
Biodegradation
(Anaerobic)
ti/2 = 32 days (loamy sand)
HSDB (2019) citina
Anderson (1993)
Wastewater Treatment
61% total removal (0.56% by biodegradation, 60% by
sludge and 0.07% by volatilization to air; estimated)13
EPI Suite (2012)
Bioconcentration Factor
180-280 (Salmo gairdneri) for Pydraul 50E, a hydraulic
fluid containing 35% TPP
HSDB (2019) citina
Lombardo (1979)
132-364 (Oncorhynchus mykiss)
HSDB (2019) citina
Mayer (1981)
573 (Oncorhynchus mykiss); 561 (Pimephales promelas)
HSDB (2019) citina
Muir (1983)
Bioaccumulation Factor
73 (estimated)13
EPI Suite (20.1.2)
Soil Organic
Carbon:Water Partition
Coefficient (Log K0c)
3.40, 3.55, and 3.44 (silty clay, loamy sand, and silt
loam, respectively)
HSDB (20.1.9) citina
Anderson (1993)
Notes:
aMeasured unless otherwise noted
bEPI Suitephysical property inputs: Log Kow = 4.59, MP = 50.5 C, VP = 6.4 x 10 6 mm Hg, WS = 1900 mg/L.
SMILES:0=P(0c(ccccl)cl)(0c(cccc2)c2)0c(cccc3)c3
OH = hydroxyl radical; BOD = biological oxygen demand; MITI = Ministry of International Trade and Industry
12

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Results and Discussion
TPP is a moderately water-soluble solid (1.9 mg/L). Its extrapolated vapor pressure (6.4 x 10"6
mm Hg) and estimated Henry's Law constant (3.31 x 10"6) indicate that this chemical has low to
moderate potential to volatilize from surface water and soil. Measured log Koc values of 3.40-
3.55 indicate that TPP will likely have moderate adsorption to soil. In air, vapor-phase TPP is
estimated to react with photochemically-produced hydroxyl radicals at a rate corresponding to a
TPP half-life of 12 hours.
In aerobic aquatic environments, TPP is readily biodegradable; it achieved 83-94 percent of its
theoretical biological oxygen demand (BOD) over a 28-day incubation period using a sewage
sludge inoculum and the Japanese MITI test method. In addition, TPP had a half-life of 32 days
in loamy sand under anaerobic conditions. TPP is likely to undergo slow hydrolysis due to a
measured half-life of 19 days at pH 7. Based on these results, this chemical is not likely to persist
in subsurface environments, groundwater, or enclosed pipes. Additionally, this chemical is
expected to have low bioaccumulation potential based on its measured bioconcentration factor of
132-573 for rainbow trout and an estimated bioaccumulation factor of 73.
6. Storage near significant sources of drinking water
Approach
To support the proposed designation, EPA screened each chemical substance under its conditions
of use with respect to the seven criteria in TSCA section 6(b)(1)(A) and 40 CFR 702.9. The
statute specifically requires the Agency to consider the chemical substance's storage near
significant sources of drinking water, which EPA interprets as direction to focus on the chemical
substance's potential human health hazard and exposure.
EPA reviewed reasonably available information, specifically looking to identify certain types of
existing regulations or protections for the proposed chemical substances. EPA considered the
chemical substance's potential human health hazards, including to potentially exposed or
susceptible subpopulations, by identifying existing National Primary Drinking Water
Regulations under the Safe Drinking Water Act (40 CFR Part 141) and regulations under the
Clean Water Act (CWA; 40 CFR 401.15). In addition, EPA considered the consolidated list of
chemical substances subject to reporting requirements under the Emergency Planning and
Community Right-to-Know Act (EPCRA; Section 302 Extremely Hazardous Substances and
Section 313 Toxic Chemicals), the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA; Hazardous Substances), and the Clean Air Act (CAA) Section 112(r)
(Regulated Chemicals for Accidental Release Prevention). Regulation by one of these authorities
is an indication that the substance is a potential health or environmental hazard which, if released
near a significant source of drinking water, could present an unreasonable risk of injury to human
health or the environment.
Results and Discussion
TPP is not currently subject to the federal regulations named in the previous paragraph.
13

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7. Hazard potential
Approach
EPA considered reasonably available information from peer-reviewed assessments and databases
to identify potential human health and environmental hazards for TPP (Tables 7 and 8,
respectively).
Because there are very few publicly available assessments for TPP with cited environmental
hazard data, EPA used the infrastructure of ECOTOXicology knowledgebase (ECOTOX) to
identify single chemical toxicity data for aquatic and terrestrial life (U.S. EPA, 2018). It uses a
comprehensive chemical-specific literature search of the open literature that is conducted
according to the Standard Operating Procedures (SOPs)9. The environmental hazard information
was populated in ECOTOX and is available to the public. In comparison to the approach used to
survey human health hazard data, EPA also used a read-across approach to identify additional
environmental hazard data for isomers of TPP, if available, to fill in potential data gaps when
there were no reported observed effects for specific taxa exposed to TPP (Table 8).
Potential Human Health and Environmental Hazard Tables
EPA identified potential human health environmental hazards based on a review of the
reasonable available information for TPP (Tables 7 and 8, respectively).
Table 7. Potential Human I
ealth Hazards Identified for Triphenyl Phosphate
Human Health Hazards
Tested for
Specific Effect
Effect
Observed
Data Source
Acute Toxicity
X

EPA (2015): UK (2009): OECD (2002)
Repeated Dose Toxicity
X
X
EPA (2015): UK (2009): OECD (2002)
Genetic Toxicity
X

EPA (2015): UK (2009): OECD (2002)
Reproductive Toxicity
X

EPA (2015): UK (2009): OECD (2002)
Developmental Toxicity
X
X
EPA (2015): UK (2009): OECD (2002)
Toxicokinetic



Irritation/Corrosion
X
X
EPA (2015): UK (2009): OECD (2002)
Dermal Sensitization
X

EPA (2015): UK (2009): OECD (2002)
Respiratory Sensitization



Carcinogenicity



Immunotoxicity
X

EPA (2015): UK (2009): OECD (2002)
Neurotoxicity
X

EPA (2015): UK (2009): OECD (2002)
Epidemiological Studies or
Biomonitoring Studies
X
X
EPA (2015)
Note: The X in the Effect Observed column indicates when a hazard effect was reported by one or more of the
referenced studies. Blank rows indicate when information was not identified during EPA's review of reasonably
available information to support the proposed designation.
9 The ECOTOX Standard Operating Procedures (SOPs) can be found at:
https://cfpub.epa.gov/ecotox/help.cfm?helptabs=tab4
14

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Table 8. Potential Environmental Hazards Identified for Triphenyl Phosphate
Media
Study
Duration
Taxa Groups
High-Priority
Chemical Candidate
Phosphoric Acid,
Triphenyl Ester
(CASRN 115-86-6)
Isome
Phospho
triphem
(CASRN
NO]
rs of
ric acid,
pi ester
115-86-6)
NE
Data Sources
Number
of Studies
Observed
Effects
Number
of Studies
Observed
Effects
Aquatic
Acute
exposure
Vegetation
1
X
-

Mayer et al. (1981)
Invertebrate
7
X


Huckins et al. (1991); Lo and Hsieh (2000);
Mayer et al. (1981); Scanlan et al. (2015);
Whyard et al. (1994)
Fish
15
X


Ahrens et al. (1978); Geiger et al. (1986);
Huckins et al. (1991); Isales et al. (2015); Liu et
al. (2013a); Liu et al. (2013b); Mayer and
Ellersieck (1986); Mayer et al. (1981); Palawski
etal. (1983); Sitthichaikasem (1978); Solomon
et al. (2000)
Non-Fish Vertebrates
(i.e., amphibians,
reptiles, mammals)





Chronic
exposure
Vegetation
-

-


Invertebrate
-

-


Fish
7
X


Kim et al. (2015); Liu et al. (2012); Liu et al.
(2013a); Liu et al. (2013b); Mayer et al. (1981);
Sitthichaikasem (1978)
Non-Fish Vertebrates
(i.e., amphibians,
reptiles, mammals)





15

-------
Media
Study
Duration
Taxa Groups
High-Priority
Chemical Candidate
Phosphoric Acid,
Triphenyl Ester
(CASRN 115-86-6)
Isome
Phospho
triphem
(CASRN
NO]
rs of
ric acid,
pi ester
115-86-6)
NE
Data Sources
Number
of Studies
Observed
Effects
Number
of Studies
Observed
Effects
Terrestrial
Acute
exposure
Vegetation
-

-


Invertebrate
25
X


Boyd et al. (2016); Kang et al. (2006); Wang et
al. (2005); Wang et al. (2012); Wang et al.
(2013); Wu and Jiang (2004); Wu et al. (2004);
Wu et al. (2007)
Vertebrates
-

-


Chronic
exposure
Vegetation
-

-


Invertebrate
-

-


Vertebrates
-

-


The dash indicates that no studies relevant for environmental hazard were identified during this initial screening and thus the "Observed Effects" column is left blank. The X in the
Observed Effects column indicates when a hazard effect was reported by one or more of the referenced studies. The N/A in the Observed Effects column indicates when a hazard
effect was not reported in the abstract of one of the referenced studies (full reference review has not been conducted).
16

-------
8. Exposure potential
Approach
EPA considered reasonably available information to identify potential environmental,
worker/occupational, consumer exposures, and general population to TPP.
Release potential for environmental and human health exposure
TPP is not included on the TRI chemical list. EPA considered conditions of use reported in CDR
and the physical and chemical properties to inform potential environmental releases of TPP.
Worker/Occupational and consumer exposure
EPA's approach for assessing exposure potential was to review the physical and chemical
properties, conditions of use reported in CDR, and information from the National Institutes of
Health Consumer Product Database and the Chemical and Products Database (CPDat) for TPP to
inform occupational and consumer exposure potential. The results of this review are detailed in
the following tables.
General population exposure
EPA identified environmental concentration, and ecological biomonitoring data to inform TPP's
exposure potential to the general population.
Results and Discussion
Release potential for environmental and human health exposure
When chemicals are incorporated into formulations, mixtures, or used as reaction products, the
industrial releases may be a relatively low percentage of the production volume. Lower
percentage releases occur when a high percentage of the volume is incorporated without
significant process losses during its incorporation into a formulation, mixture, or product. The
actual percentages, quantities, and media of releases of the reported chemical associated with this
processing or use are not known.
When chemical substances have industrial use as solvents in product formulations or mixtures,
the industrial and/or end use releases may be a relatively high percentage of the production
volume. Higher percentage releases occur when the chemical's intended use is as a solvent that
may evaporate into the atmosphere or may be collected and disposed to aqueous media. In some
cases, some engineering controls or capture for recycle or reclamation may reduce these losses.
The actual percentage and quantity of release of the reported chemical associated with this
category are not known but could be high.
Worker/Occupational exposures
Worker exposures to this chemical may be affected by many factors, including but not limited to
volume produced, processed, distributed, used and disposed of; physical form and concentration;
processes of manufacture, processing, and use; chemical properties such as vapor pressure,
solubility, and water partition coefficient; local temperature and humidity; and exposure controls
such as engineering controls, administrative controls, and the existence of a personal protective
equipment (PPE) program.
17

-------
TPP has an Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit
(PEL)10. The PEL is 3 milligrams (mg)/cubic meter (m3) over an 8-hour work day, time weighted
average (TWA). This chemical also has a National Institute for Occupational Safety and Health
(NIOSH) Recommended Exposure Limit (REL)11 of 3 mg/m3 TWA. The American Conference
of Governmental Industrial Hygienists (ACGIH) set the Threshold Limit Value (TLV) at 3 ppm
TWA.
TPP has a vapor pressure of approximately 6.3 x 10"6 mm Hg at 25 C/77 F. EPA assumes that
inhalation exposure is negligible when vapors are generated from liquids with vapor pressures
below 0.001 mm Hg at ambient room temperature conditions.
TPP is indicated as being used in paints and coatings. Products used as paints and coatings may
be applied via spray or roll application methods. These methods may generate mists to which
workers may be exposed.
Consumer exposure
CDR reporting indicate that TPP is used in consumer products, including foam seating and
bedding products, plastic and rubber products, and photographic supplies, film, and photo
chemicals (CDR 2016. ). The 2012 CDR also reported the use of TPP in electrical and
electronic products (CPL L)- The EPA's Chemical and Products Database (CPDat) reported
uses of TPP in consumer products are listed in
Table 9.
Table 9. Exposure
nformation for Consumers
Chemical Identity
Consumer Product Database
Consumer Uses (List)
Triphenyl Phosphate
(115-86-6)
Adhesive, antioxidant, arts crafts products, automotive, automotive care, building
material, electrical insulation, electronics, flooring, fluid property modulator,
furniture, insulation, lubricant, metal surface treatment, paint, photographic,
plastic building material, plastic, plastic softener, printing, rubber, softener,
solvent, stabilizer, textile, toys, wall building material
Reference: CPDat
General population exposure
Releases of TPP from certain conditions of use, such as manufacturing and processing activities,
as well as use and disposal of products containing TPP, may result in general population
exposures via drinking water ingestion. Results from EPA databases indicate TPP was reported
in water, soil, sediment, vegetation/diet, and other environmental matrices (Table 10).
Existing assessments also indicated TPP was detected in wastewater effluent, landfill leachate,
sewage sludge, ambient air, indoor air, and indoor dust, as well as in fish (including shellfish)
10	OSHA, 2019. Occupational Safety and Health Administration (OSHA) Permissible Exposure Limits (PELs).
https://www.osha.gov/dse/annotated-pels/tablez-l.html
11	NIOSH, 2005. NIOSH Pocket Guide to Chemical Hazards, https://www.cdc.gov/niosli/npg/npgd0644.html
18

-------
and dolphins (EPA 2015, UK 2009, OECD 2002). On the basis of its fate properties, such as the
Henry's Law constant and soil organic carbon-water partition coefficient, EPA anticipates
possible presence of TPP in soil and surface water. OECD indicated that general population
exposure to TPP through normal use is minimal (OECD 2002). Susceptible subpopulations will
respond differently to TPP exposure compared with the general population (Section 4).
Table 10. Exposure Information for the
Environment and General Population
Database Name
Env.
Concen.
Data
Present?
Human
Biomon.
Data
Present?
Ecological
Biomon.
Data
Present?
Reference
California Air Resources Board
no
no
no
CARB (2005)
Comparative Toxicogenomics Database
no
no
no
MDI (2002)
EPA Ambient Monitoring Technology
Information Center - Air Toxics Data
no
no
no
\ (1990)
EPA Discharge Monitoring Report Data
yes
no
no
\ (2007)
EPA Unregulated Contaminant Monitoring
Rule
no
no
no
\ (1996)
FDA Total Diet Study
yes
no
no

Great Lakes Environmental Database
no
no
no
\ (2018)
Information Platform for Chemical
Monitoring Data
no
no
no
EC (2018)
International Council for the Exploration of
the Sea
no
no
no
ICES (2018)
OECD Monitoring Database
no
no
no
OECD (2018)
Targeted National Sewage Sludge Survey
no
no
no
\ (2006)
The National Health and Nutrition
Examination Survey
no
no
no
CDC (2013)
USGS Monitoring Data -National Water
Quality Monitoring Council
yes
no
no
rS (1991a)
USGS Monitoring Data -National Water
Quality Monitoring Council, Air
no
no
no
rS(1991b)
USGS Monitoring Data -National Water
Quality Monitoring Council, Ground Water
yes
no
no
rS (1991c)
USGS Monitoring Data -National Water
Quality Monitoring Council, Sediment
yes
no
no
USGS (199Id)
USGS Monitoring Data -National Water
Quality Monitoring Council, Soil
yes
no
no
USGS (199le)
USGS Monitoring Data -National Water
Quality Monitoring Council, Surface Water
yes
no
no
USGS (199111
USGS Monitoring Data -National Water
Quality Monitoring Council, Tissue
no
no
yes
S(1991a)
aConcen.= concentration; bBiomon.= biomonitoring
19

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9.	Other risk-based criteria that EPA determines to be relevant to the designation of
the chemical substance's priority
EPA did not identify other risk-based criteria relevant to the designation of the chemical
substance's priority.
10.	Proposed designation and Rationale
Proposed Designation: High-priority substance
Rationale: EPA identified and analyzed reasonably available information for exposure and
hazard and is proposing to find that TPP may present an unreasonable risk of injury to health
and/or the environment, including potentially exposed or susceptible subpopulations (e.g.
workers, consumers, women of reproductive age, children). This is based on the potential hazard
and potential exposure of TPP under the conditions of use described in this document to support
the prioritization designation. Specifically, EPA expects that that the manufacturing, processing,
distribution, use and disposal of TPP may result in presence of the chemical in surface water,
ingestion of the chemical in drinking water, inhalation of the chemical in ambient and indoor air,
exposure to workers and exposure to the general population, including exposure to children. In
addition, EPA identified potential environmental (e.g., aquatic toxicity, terrestrial toxicity), and
human health hazards (e.g., repeated dose toxicity, developmental toxicity, irritation/corrosion,
and observations in epidemiological studies and biomonitoring studies).
20

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