EPA Document# EPA-740-D-20-010
April 2020
	| ia| United States	Office of Chemical Safety and
Environmental Protection Agency	Pollution Prevention
Draft Scope of the Risk Evaluation for
Triphenyl Phosphate
CASRN 115-86-6
April 2020

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TABLE OF CONTENTS
ACKNOWLEDGEMENTS	5
ABBREVIATIONS AND ACRONYMS	6
EXECUTIVE SUMMARY	8
1	INTRODUCTION	11
2	SCOPE OF THE EVALUATION	11
2.1	Reasonably Available Information	11
2.1.1	Search of Gray Literature	12
2.1.2	Search of Literature from Publicly Available Databases (Peer-Reviewed Literature)	13
2.1.3	Search of TSCA Submissions	19
2.2	Conditions of Use	19
2.2.1	Categories and Subcategories of Conditions of Use Included in the Scope of the Risk
Evaluation	20
2.2.2	Activities Excluded from the Scope of the Risk Evaluation	23
2.2.3	Production Volume	23
2.2.4	Overview of Conditions of Use and Lifecycle Diagram	23
2.3	Exposures	25
2.3.1	Physical and Chemical Properties	25
2.3.2	Environmental Fate and Transport	25
2.3.3	Releases to the Environment	25
2.3.4	Environmental Exposures	25
2.3.5	Occupational Exposures	26
2.3.6	Consumer Exposures	27
2.3.7	General Population Exposures	27
2.4	Hazards (Effects)	27
2.4.1	Environmental Hazards	27
2.4.2	Human Health Hazards	28
2.5	Potentially Exposed or Susceptible Subpopulations	28
2.6	Conceptual Models	28
2.6.1	Conceptual Model for Industrial and Commercial Activities and Uses	29
2.6.2	Conceptual Model for Consumer Activities and Uses	29
2.6.3	Conceptual Model for Environmental Releases and Wastes: Potential Exposures and
Hazards	32
2.7	Analysis Plan	34
2.7.1	Physical and Chemical Properties and Environmental Fate	34
2.7.2	Exposure	35
2.7.2.1	Environmental Releases	35
2.7.2.2	Environmental Exposures	37
2.7.2.3	Occupational Exposures	38
2.7.2.4	Consumer Exposures	40
2.7.2.5	General Population	41
2.7.3	Hazards (Effects)	44
2.7.3.1	Environmental Hazards	44
2.7.3.2	Human Health Hazards	45
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2.7.4 Summary of Risk Approaches for Characterization	47
2.8 Peer Review	47
REFERENCES	48
APPENDICES	55
Appendix A LIST OF GRAY LITERATURE SOURCES	55
Appendix B PHYSICAL AND CHEMICAL PROPERTIES	64
Appendix C ENVIRONMENTAL FATE AND TRANSPORT PROPERTIES	66
Appendix D REGULATORY HISTORY	67
D.l Federal Laws and Regulations												..........67
D.2 State Laws and Regulations														69
D.3	International Laws and Regulations........									.....70
Appendix E PROCESS, RELEASE AND OCCUPATIONAL EXPOSURE INFORMATION.. 72
E.l	Process Information..												72
E. 1.1 Manufacturing (Including Import)	72
E. 1.1.1 Domestic Manufacture	72
E.l. 1.2 Import	72
E. 1.2 Processing and Distribution	72
E. 1.2.1 Incorporation into a Formulation, Mixture or Reaction Product	72
E. 1.2.2 Incorporation into an Article	72
E.l.2.3 Recycling	72
E.l.3 Uses	73
E.l.4 Disposal	75
E.2 Preliminary Occupational Exposure Data.....													76
Appendix F SUPPORTING INFORMATION - CONCEPTUAL MODEL FOR INDUSTRIAL
AND COMMERCIAL ACTIVITIES AND USES	77
Appendix G SUPPORTING INFORMATION- CONCEPTUAL MODEL FOR CONSUMER
ACTIVITIES AND USES	88
Appendix H SUPPORTING INFORMATION - CONCEPTUAL MODEL FOR
ENVIRONMENTAL RELEASES AND WASTES	93
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LIST OF TABLES
Table 2-1 Results of Title Screening of Submissions to EPA under Various Sections of TSCA	19
Table 2-2 Categories and Subcategories of Conditions of Use Included in the Scope of the Risk
Evaluation	20
Table 2-3 Categories and Sources of Environmental Release Data	35
LIST OF FIGURES
Figure 2-1 Gray Literature Search Results for TPP	12
Figure 2-2 Peer-reviewed Literature - Physical-Chemical Properties Search Results for TPP	14
Figure 2-3 Peer-reviewed Literature - Fate and Transport Search Results for TPP	15
Figure 2-4 Peer-reviewed Literature - Engineering Search Results for TPP	16
Figure 2-5 Peer-reviewed Literature - Exposure Search Results for TPP	17
Figure 2-6 Peer-reviewed Literature - Hazard Search Results for TPP	18
Figure 2-7 TPP Life Cycle Diagram	24
Figure 2-8 TPP Conceptual Model for Industrial and Commercial Activities and Uses: Worker and ONU
Exposures and Hazards	29
Figure 2-9 TPP Conceptual Model for Consumer Activities and Uses: Consumer Exposures and Hazards
	31
Figure 2-10 TPP Conceptual Model for Environmental Releases and Wastes: Environmental and
General Population Exposure and Hazards	33
LIST OF APPENDIX TABLES
Table_Apx A-l List of Gray Literature Sources for TPP	55
TableApx B-l Physical and Chemical Properties of TPP	64
TableApx C-l Environmental Fate and Transport Properties of TPP	66
Table_Apx D-l Federal Laws and Regulations	67
Table_Apx D-2 State Laws and Regulations	69
Table Apx D-3 Regulatory Actions by other Governments, Tribes, and International Agreements	70
Table_Apx E-l Possible Unconfirmed Uses	74
Table Apx E-2 Potentially Relevant Data Sources for Exposure Monitoring and Area Monitoring Data
from NIOSH Health Hazard Evaluations for TPPa	76
Table Apx F-l Worker and Occupational Non-User Exposure Conceptual Model Supporting Table... 77
Table Apx G-l Consumer Exposure Conceptual Model Supporting Table	88
Table Apx H-l General Population and Environmental Exposure Conceptual Model Supporting Table
	93
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ACKNOWLEDGEMENTS
This report was developed by the United States Environmental Protection Agency (U.S. EPA), Office of
Chemical Safety and Pollution Prevention (OCSPP), Office of Pollution Prevention and Toxics (OPPT).
Acknowledgements
The OPPT Assessment Team gratefully acknowledges participation or input from intra-agency
reviewers that included multiple offices within EPA, inter-agency reviewers that included multiple
federal agencies, and assistance from EPA contractors GDIT (Contract No. HHSN316201200013W),
ERG (Contract No. EP-W-12-006), Versar (Contract No. EP-W-17-006), ICF (Contract
No.68HERC19D0003), Abt Associates (Contract No. EP-W-16-009) and SRC (Contract No.
68HERH19F0213). EPA also acknowledges the contributions of technical experts from EPA's Office of
Research and Development.
Docket
Supporting information can be found in public docket: J Q-QPPT-2018-0458.
Disclaimer
Reference herein to any specific commercial products, process or service by trade name, trademark,
manufacturer or otherwise does not constitute or imply its endorsement, recommendation or favoring by
the United States Government.
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ABBREVIATIONS AND ACRONYMS
ADME
Absorption, Distribution, Metabolism, and Excretion
AT SDR
Agency for Toxic Substances and Disease Registry
BAF
Bioaccumulation Factor
BCF
Bioconcentration Factor
BMF
Biomagnification factor
BOD
Biochemical oxygen demand
CAA
Clean Air Act
CASRN
Chemical Abstracts Service Registry Number
CBI
Confidential Business Information
CCL
Contaminant Candidate List
CDR
Chemical Data Reporting
CFR
Code of Federal Regulations
CWA
Clean Water Act
EC
Engineering control
ECHA
European Chemicals Agency
EPA
Environmental Protection Agency
ESD
Emission Scenario Document
FYI
For Your Information
GS
Generic Scenario
HAP
Hazardous Air Pollutant
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
NICNAS
National Industrial Chemicals Notification and Assessment Scheme
NIH
National Institutes of Health
NIOSH
National Institute for Occupational Safety and Health
OECD
Organisation for Economic Co-operation and Development
OH
Hydroxyl radical
OSHA
Occupational Safety and Health Administration
P-chem
Phy si cal -chemi cal
PEL
Permissible Exposure Limit
PESS
Potentially Exposed or Susceptible Subpopulation
PNOR
Particulates Not Otherwise Regulated
PPE
Personal Protective Equipment
RCRA
Resource Conservation and Recovery Act
SDWA
Safe Drinking Water Act
SIDS
Screening Information Data Sets
SMILES
Simplified molecular-input line-entry system
SVOC
Semi-volatile organic compound
STEL
Short-term Exposure Limit
TIAB
Title and abstract
TLV
Threshold Limit Value

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TMF
Trophic Magnification Factors
TRI
Toxics Release Inventory
TSCA
Toxic Substances Control Act
TWA
Time-weighted average
UMCR
Unregulated Contaminants Monitoring Rule
VP
Vapor Pressure
WS
Water solubility

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EXECUTIVE SUMMARY
In December 2019, EPA designated Triphenyl Phosphate (TPP; CASRN 115-86-6) as a high-priority
substance for risk evaluation following the prioritization process required by Section 6(b) of the Toxic
Substances Control Act (TSCA) and implementing regulations (40 CFR Part 702) (Docket ID: EPA-
H.Q-OPPT-2018-0476-0007). The first step of the risk evaluation process is the development of the
scope document and this document fulfills the TSCA regulatory requirement to issue a draft scope
document as described in 40 CFR 702.41(c)(7) (U.S. EPA, 2018a). The draft scope for TPP includes the
following information: the conditions of use, potentially exposed or susceptible subpopulations (PESS),
hazards, and exposures that EPA plans to consider in this risk evaluation, along with a description of the
reasonably available information, conceptual model, analysis plan and science approaches, and plan for
peer review for this chemical substance. EPA is providing a 45-day comment period on the draft scope.
Comments received on this draft scope document will help inform development of the final scope
document and the risk evaluation.
General Information. TPP is a colorless solid that is primarily used as a flame retardant with a total
production volume in the United States between 1 million and 10 million pounds.
Reasonably Available Information. EPA leveraged the data and information sources already described
in the document supporting the High-Priority Substance designation for TPP to inform the development
of this draft scope document. To further develop this draft scope document, EPA conducted a
comprehensive search to identify and screen multiple evidence streams (i.e., chemistry, fate, release and
engineering, exposure, hazard), and the search and screening results to date are provided in Section 2.1.
EPA is seeking public comment on this draft scope document and will consider additional information
identified following publication of this draft scope document, as appropriate, in developing the final
scope document. EPA is using the systematic review process described in the Application of Systematic
Review in TSCA Risk Evaluations document (U.S. EPA, 2018b) to guide the process of searching for
and screening reasonably available information, including information already in EPA's possession, for
use and inclusion in the risk evaluation. EPA is applying these systematic review methods to collect
reasonably available information regarding hazards, exposures, PESS, and conditions of use that will
help inform the risk evaluation for TPP.
Conditions of Use. EPA plans to evaluate risks from manufacturing, including importing; processing;
distribution in commerce; industrial, commercial and consumer uses; and disposal of TPP in the risk
evaluation. TPP is processed as a reactant, incorporated into a formulation, mixture, or reaction
products, and incorporated into articles. The identified processing activities also include the repackaging
of TPP. Several commercial uses were identified, such as paints and coatings and plastic and rubber
products. Several consumer uses were reported, including foam seating and bedding products. EPA
identified these conditions of use from information reported to EPA through Chemical Data Reporting
(CDR), published literature, and consultation with stakeholders for both uses currently in production and
uses whose production may have ceased. EPA is aware of information reporting TPP in manufacturing
nail polish and flea and tick collars; however, they are not conditions of use as defined in TSCA § 3(4).
Section 2.2 provides details about the conditions of use within the scope of the risk evaluation.
Conceptual Model. The conceptual models for TPP are presented in Section 2.6. Conceptual models are
graphical depictions of the actual or predicted relationships of conditions of use, exposure pathways
(e.g., media), exposure routes (e.g., inhalation, dermal, oral), hazards, and receptors throughout the life
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cycle of the chemical substance. EPA proposes to focus the risk evaluation for TPP on the following
exposures, hazards, and receptors with the understanding that updates may be made in the final scope
document after consideration of public comments and completion of the systematic review data
collection phase.
•	Exposures (Pathways and Routes), Receptors and PESS. EPA plans to analyze both human and
environmental exposures and releases to the environment resulting from the conditions of use of
TPP that EPA plans to consider in risk evaluation. Exposures to TPP are discussed in Section
2.3. EPA identified environmental monitoring data reporting the presence of TPP in surface
water, groundwater, biosolids and sediment. Additional information gathered through systematic
review searches will also inform expected exposures.
In Section 2.6.3, EPA presents the conceptual models describing the identified exposures
(pathways and routes), receptors and hazards associated with the conditions of use of TPP within
the scope of the risk evaluation.
Preliminarily, EPA plans to include the following human and environmental exposure pathways,
routes, receptors and PESS in the scope of the risk evaluation. However, EPA plans to consider
comments received on this draft scope and other reasonably available information when
finalizing this scope document, and to adjust the exposure pathways, exposure routes and
hazards included in the scope document as needed.
-	Occupational exposures associated with industrial and commercial conditions of use:
EPA plans to evaluate exposures to workers and/or occupational non-users via the
inhalation route and exposures to workers via the dermal route associated with the
manufacturing, import, processing, use and disposal.
-	Consumer and bystander exposures associated with consumer conditions of use: EPA
plans to evaluate the inhalation and dermal exposure to TPP when consumers are using
foam and upholstery, automobile upholstery, camping tents, cellulose acetate films,
thermoplastic products, vulcanization products, hydraulic fluids containing TPP, and
children's mouthing or products/articles containing TPP.
-	General population exposures: EPA plans to evaluate exposure to TPP via drinking
water, groundwater, ambient air, fish ingestion, human breast milk, and soil for the
general population.
-	Human receptors and PESS: EPA plans to evaluate children, women of reproductive age
(including, but not limited to pregnant women), workers, and consumers as receptors and
PESS in the risk evaluation.
-	Environmental exposures: EPA plans to evaluate exposure to TPP for aquatic and
terrestrial receptors via various pathways and receptors including surface water,
sediment, soil.
•	Hazards. Hazards for TPP are discussed in Section 2.4. EPA completed preliminary reviews of
information from peer-reviewed assessments and databases to identify potential environmental
and human health hazards for TPP as part of the prioritization process. Environmental hazard
effects were identified for aquatic and terrestrial organisms. Information collected through
systematic review methods and public comments may identify additional environmental hazards
that warrant inclusion in the environmental hazard assessment of the risk evaluation
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EPA plans use systematic review methods to evaluate the epidemiological and toxicological
literature for TPP. Relevant mechanistic evidence will also be considered, if reasonably
available, to inform the interpretation of findings related to potential human health effects and
the dose-response assessment. EPA plans to evaluate all of the potential human health hazards
for TPP identified in Section 2.4.2. The broad health effect categories include reproductive and
developmental, immunological, nervous system, genotoxicity, carcinogenicity, and irritation
effects.
Analysis Plan. The analysis plan for TPP is presented in Section 2.7. The analysis plan outlines the
general science approaches that EPA plans to use for the various evidence streams (i.e., chemistry, fate,
release and engineering, exposure, hazard) supporting the risk evaluation. The analysis plan is based on
EPA's knowledge of TPP to date which includes a partial, but ongoing, review of identified information
as described in Section 2.1. EPA plans continue to consider new information submitted by the public.
Should additional data or approaches become reasonably available, EPA may update its analysis plan in
the final scope document.
EPA plans seek public comments on the systematic review methods supporting the risk evaluation for
TPP, including the methods for assessing the quality of data and information and the approach for
evidence synthesis and evidence integration supporting the exposure and hazard assessments. The
details will be provided in a supplemental document that EPA anticipates releasing for public comment
prior to the finalization of the scope document.
Peer Review. The draft risk evaluation for TPP will be peer reviewed. Peer review will be conducted in
accordance with relevant and applicable methods for chemical risk evaluations, including using EPA's
Peer Review Handbook and other methods consistent with Section 26 of TSCA (See	02.45;
U.S. EPA, 2018c).
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1 INTRODUCTION
This document presents for comment the draft scope of the risk evaluation to be conducted for TPP
under the Frank R. Lautenberg Chemical Safety for the 21st Century Act. The Frank R. Lautenberg
Chemical Safety for the 21st Century Act amended the Toxic Substances Control Act (TSCA) on June
22, 2016. The new law includes statutory requirements and deadlines for actions related to conducting
risk evaluations of existing chemicals.
Under TSCA § 6(b), the Environmental Protection Agency (EPA) must designate chemical substances
as high-priority substances for risk evaluation or low-priority substances for which risk evaluations are
not warranted at the time, and upon designating a chemical substance as a high-priority substance,
initiate a risk evaluation on the substance. TSCA § 6(b)(4) directs EPA in conducting risk evaluations
for existing chemicals to "determine whether a chemical substance presents an unreasonable risk of
injury to health or the environment, without consideration of costs or other non- risk factors, including
an unreasonable risk to a potentially exposed or susceptible subpopulation identified as relevant to the
risk evaluation by the Administrator, under the conditions of use."
TSCA § 6(b)(4)(D) and implementing regulations require that EPA publish the scope of the risk
evaluation to be conducted, including the hazards, exposures, conditions of use and potentially exposed
or susceptible subpopulations that the Administrator expects to consider, within 6 months after the
initiation of a risk evaluation. In addition, a draft scope is to be published pursuant to	'02.41
(U.S. EPA, 2018a). In December 2019, EPA published a list of 20 chemical substances that have been
designated high priority substances for risk evaluations (	), as required by TSCA §
6(b)(2)(B), which initiated the risk evaluation process for those chemical substances. TPP is one of the
chemicals designated as a high priority substance for risk evaluation.
2 SCOPE OF THE EVALUATION
2.1	Reasonably Available Information
EPA conducted a comprehensive search for reasonably available information1 to support the
development of this draft scope document for TPP. EPA leveraged the data and information sources
already identified in the documents supporting the chemical substance's high-priority substance
designation. In addition, EPA searched for additional data and information on physical and chemical
properties, environmental fate, engineering, exposure, environmental and human health hazards that
could be obtained from the following general categories of sources:
1.	Databases containing publicly available, peer-reviewed literature;
2.	Gray literature, which is defined as the broad category of data/information sources not found in
standard, peer-reviewed literature databases.
3.	Data and information submitted under TSCA Sections 4, 5, 8(e), and 8(d), as well as "for your
information" (FYI) submissions.
Following the comprehensive search, EPA performed a title and abstract screening to identify
information potentially relevant for the risk evaluation process. This step also classified the references
1 Reasonably available information means information that EPA possesses or can reasonably generate, obtain, and synthesize
for use in risk evaluations, considering the deadlines specified in TSCA section 6(b)(4)(G) for completing such evaluation.
Information that meets the terms of the preceding sentence is reasonably available information whether or not the information
is confidential business information, that is protected from public disclosure under TSCA section 14. (40 CFR 702.33).

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into useful categories or tags to facilitate the sorting of information through the systematic review
process. The search and screening process was conducted based on EPA's general expectations for the
planning, execution and assessment activities outlined in the Application of Systematic Review in TSCA
Risk Evaluations document (U.S. EPA, 2018b). EPA plans publish supplemental documentation on the
systematic review methods supporting the TPP risk evaluation to explain the literature and screening
process presented in this document in the form of literature inventory trees. Please note that EPA
focuses on the data collection phase (consisting of data search, data screening, and data extraction)
during the preparation of the TSCA scope document, whereas the data evaluation and integration stages
will occur during the development of the draft risk evaluation and thus are not part of the scoping
activities described in this document.
The subsequent sections summarize the data collection activities completed up to date for the general
categories of sources and topic areas (or disciplines) using systematic review methods. EPA plans seek
public comments on the systematic review methods supporting the risk evaluation for TPP upon
publication of the supplemental documentation of those methods.
2.1.1_ Search of Gray Literature
EPA surveyed the gray literature2 and identified 117 search results relevant to EPA's risk assessment
needs for TPP. Appendix A lists the gray literature sources that yielded 117 discrete data or information
sources relevant to TPP. EPA further categorized the data and information into the various topic areas
(or disciplines) supporting the risk evaluation (e.g., physical chemistry, environmental fate, ecological
hazard, human health hazard, exposure, engineering) and the breakdown is shown in Figure 2-1. EPA is
currently identifying additional reasonably available information (e.g., public comments), and the
reported numbers in Figure 2-1 may change.
Gray Literature Tags by Discipline
Phvsical.Chcmieal
Human. Health. Hazard
Exposure
Environmental. I Iazard
Engineering
0	25	50	75	100
Percent Tagged (%)
Figure 2-1 Gray Literature Search Results for TPP
The percentages across disciplines do not add up to 100%, as each source may provide data or information for various topic
areas (or disciplines).
2 Gray literature is defined as the broad category of data/information sources not found in standard, peer-reviewed literature
databases (e.g., PubMed and Web of Science). Gray literature includes data/information sources such as white papers,
conference proceedings, technical reports, reference books, dissertations, information on various stakeholder websites, and
other databases.
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2.1.2 Search of Literature from Publicly Available Databases (Peer-Reviewed
Literature)
EPA is currently conducting a systematic review of the reasonably available literature. This includes
performing a comprehensive search of the reasonably available peer review literature on physical-
chemical (p-chem) properties, environmental fate and transport, engineering (environmental release and
occupational exposure), exposure (environmental, general population and consumer) and environmental
and human health hazards of TPP. Eligibility criteria were applied in the form of population, exposure,
comparator, outcome (PECO) or similar statements. Included references met the PECO or similar
criteria, whereas excluded references did not meet the criteria (i.e., not relevant), and supplemental
material was considered as potentially relevant. EPA plans to analyze the reasonably available
information identified for each discipline during the development of the risk evaluation. The literature
inventory trees depicting the number of references that were captured and those that were included,
excluded, or tagged as supplemental material during the screening process for each discipline area are
shown in Figure 2-2 through
Figure 2-6. "TIAB" in these figures refer to "title and abstract" screening. Note that the sum of the
numbers for the various sub-categories may be larger than the broader category because some studies
may be included under multiple sub-categories. In other cases, the sum of the various sub-categories
may be smaller than the main category because some studies may not be depicted in the sub-categories
if their relevance to the risk evaluation was unclear.
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Boiling Point
Melting Point
Water Solublity
log KOW
Henry's Law Constant
Vapor Pressure
Vapor Density
Density
Viscosity
Retrieved for Full-text
Review
Included for Data
Extraction and Data
Evaluation
Dielectric Constant
Refractive Index
Total for TIAB:
P-Chem
50
Supplemental Information
Exclusion
Exclusion
Figure 2-2 Peer-reviewed Literature - Physical-Chemical Properties Search Results for TPP
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©
Bioconcentration, Biomagnification, etc.
©
Biodegradation
0
Hydrolysis
0
Photolysis
©
Sorption
@
Volatilization
©
Wastewater Treatment
©
Other
Figure 2-3 Peer-reviewed Literature - Fate and Transport Search Results for TPP
Click here for interactive Health Assessment Workplace Collaborative (HAWC) Diagram.
©
Included
432
352
TSCA Fate TPP (2020)	Excluded
Q
Supplemental
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0
General Facility Estimate
166
Included
©
Environmental Release
TSCA Engineering TPP (2020)
Excluded
©
Occupational Exposure
®
Supplemental
Figure 2-4 Peer-reviewed Literature - Engineering Search Results for TPP
Click here for interactive HAWC Diagram.
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air
264
ambient all
©
soil
©
sediment
©
biosolids/sludge
J-©
surface water
©
ground water
©
drinking water
©
aquatic species
©
terrestrial species
©
epidemiological/human biomonitoring study
[25 ]
491
\	/	consumer uses and/or products
©
TSCA Exposure TPP (2020)
dietary
©
Supplemental	foreign language
Qy
Exclude
Figure 2-5 Peer-reviewed Literature - Exposure Search Results for TPP
Click here for interactive HAWC Diagram.
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©
Retrieved for Full-text Review
©
Human
©
Animal
©
Plant
©
Human Health Model
©
Ecotoxicological Model
1072
TSCA Hazard TPP (2020)
©
Exclusion
©
©
Supplemental Material
Mechanistic
©
EfTK/P
©
ADMEn"K/PBPK
Mixture
0
Case Study or Case Series
@
No Original Data
©
Conference Abstract
©
Susceptible Population
©
Non-English Record
©
Field Study
©
Agent to Induce Allergenic Response
©
PECO-Relevant Isomer Study
Figure 2-6 Peer-reviewed Literature - Hazard Search Results for TPP
Click here for interactive HAWC Diagram.
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2.1.3 Search of TSCA Submissions
Table 2-1 presents the results of screening the titles of data sources and reports submitted to EPA under
various sections of TSCA. EPA screened a total of 295 submissions using inclusion/exclusion criteria
specific to individual disciplines (see Table 2-1 for the list of disciplines). The details about the criteria
are not part of this document but will be provided in a supplemental document that EPA anticipates
releasing prior to the finalization of the scope document. EPA identified 153 submissions that met the
inclusion criteria in these statements and identified 130 submissions with supplemental data. EPA
excluded 12 submissions because the reports were identified as one of the following:
•	Summary of other reports
•	Draft of a published report that would be identified via peer literature searches
•	Submission on a different chemical
•	Data not relevant to any discipline
•	Letter with no attached report
•	Status report
•	Notification of study initiation
EPA plans to conduct additional deduplication at later stages of the systematic review process (e.g., full
text screening), when more information regarding the reports is reasonably available.
Table 2-1 Results of Title Screening of Submissions to EPA under Various Sections of TSCA
Discipline
Included "
Supplemental"
Physicochemical Properties
26
0
Environmental Fate and Transport
70
0
Environmental and General Population
Exposure
14
0
Occupational Exposure/Release Information
13
0
Environmental Hazard
58
70
Human Health Hazard
37
74
aA given submission may have information on multiple disciplines; therefore, the sum of submissions in each column is
greater than the total number of included or supplemental submissions.
2.2	Conditions of Use
As described in the Proposed Designation of Triphenyl Phosphate f'CASRN 115- 's a High-
Priority Substance for Risk Evaluation (U.S. EPA, 2019a), EPA assembled information from the CDR
and TRI programs to determine conditions of use3 or significant changes in conditions of use of the
chemical substance. EPA also consulted a variety of other sources to identify uses of TPP, including:
published literature, company websites, and government and commercial trade databases and
publications. To identify formulated products containing TPP, EPA searched for safety data sheets
(SDS) using internet searches, EPA Chemical and Product Categories (CPCat) data, and other resources
in which SDSs could be found. SDSs were cross-checked with company websites to make sure that each
product SDS was current. In addition, EPA incorporated communications with companies, industry
3 Conditions of use means the circumstances, as determined by the Administrator, under which a chemical substance is
intended, known, or reasonably foreseen to be manufactured, processed, distributed in commerce, used, or disposed of.

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groups, environmental organizations, and public comments to supplement the conditions of use
information.
EPA identified and described the categories and subcategories of conditions of use that EPA plans to
include in the scope of the risk evaluation (Section 2.2.1; Table 2-2). The conditions of use included in
the scope are those reflected in the life cycle diagrams and conceptual models.
After gathering the reasonably available information related to the manufacture, processing, distribution
in commerce, use, and disposal of TPP, EPA identified those categories or subcategories of use activities
for TPP the Agency determined not to be conditions of use or will otherwise be excluded during
scoping. These categories and subcategories are described in Section 2.2.2.
2.2.1 Categories and Subcategories of Conditions of Use Included in the Scope of the
Risk Evaluation
Table 2-2 lists the conditions of use that are included in the scope of the risk evaluation.
Table 2-2 Categories and Subcategories of Conditions of Use Included in the Scope of the Risk
Evaluation
l.il'e Cycle Stage"
Category1'
Subcategory'
References
Manufacturing
Domestic
Manufacturing
Domestic Manufacturing
CDR LS EPA
(2019b)
Import
Import repack
CDR US EPA
(2019b)
Processing
Incorporated into
formulation, mixture
or reaction product
Flame retardant used in all other
chemical product and preparation
manufacturing
CDR US EPA
(2019b)
Flame retardant used in computer and
electronic product manufacturing
CDR US EPA
(2019b)
Flame retardant used in photographic
film paper, plate, and chemical
manufacturing
CDR US EPA
(2019b)
Flame retardant used in plastic
material and resin manufacturing
CDR US EPA
(2019b)
Flame retardant used in plastic
product manufacturing
CDR US EPA
(2019b)
Flame retardant used in rubber
product manufacturing
CDR US EPA
(2019b)
Flame retardant used in textiles,
apparel, and leather manufacturing
CDR US EPA
(2019b)
Flame retardant used in utilities
CDR US EPA
(2019b)
Paint additive and coating additive
used in paint and coating
manufacturing
CDR US EPA
(2019b)
Solvent (which become part of
product formulation or mixture) used
CDR US EPA
(2019b)
20

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l.ife Cycle Slsi«e"
('silc«or\h
Subcategory''
References


in photographic film paper, plate, and
chemical manufacturing

Plasticizers in all other chemical
product and preparation
manufacturing
CDR US EPA
(2019b)
Flame retardant used in furniture and
related product manufacturing
CDR US EPA
(2019b)
Plasticizer, additive and impurity in
adhesives, sealants and lubricants
Public Comment
EPA-HQ-OPPT-
2018-0458-0003
Operational fluids, maintenance fluids
and semisolids, reactive fluids, and
solids used in aerospace industry
Public Comment
EPA-HQ-OPPT-
2018-0458-0004
Lubricants, shop materials, and other
products used by U.S. Army
U.S. Army
submittal to
CMRM (2020)
Processing
Incorporated into
article
Solvent (which become part of
product formulation or mixture) used
in photographic film paper, plate, and
chemical manufacturing
CDR US EPA
(2019b)
Plasticizer used in plastics product
manufacturing
CDR US EPA
(2019b)
Photographic supplies, film, and photo
chemicals
CDR US EPA
(2019b)
Processing
Recycling
Recycling

Distribution
Distribution in
commerce
Distribution in commerce

Commercial Use

Paints and coatings
CDR US EPA
(2019b)
Plastic and rubber products not
covered elsewhere
CDR US EPA
(2019b)
Photographic supplies, film, and photo
chemicals
CDR US EPA
(2019b)
Lubricants and greases
CDR US EPA
(2019b)
Electrical and electronic products
CDR US EPA
(2019b)
Foam seating and bedding products
CDR US EPA
(2019b)
Furniture and Furnishings not covered
elsewhere
CDR US EPA
(2019b)
Consumer Use

Foam seating and bedding products
CDR US EPA
(2019b)
Plastic and rubber products not
covered elsewhere

21

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l.ife Cycle Slsi«e"
('silc«or\h
Subcategory''
References



CDR US EPA
(2019b)
Photographic supplies, film, and photo
chemicals
CDR US EPA
(2019b)
Lubricants and greases
CDR US EPA
(2019b)
Electrical and electronic products
CDR US EPA
(2019b)
Disposal
Disposal
Disposal

•	The Agency has included information in this draft scope document sourced from the 2012 and 2016 Chemical Data
Reporting (CDR) Rule collections. In instances where representations of fact derived from CDR data included in this
document were claimed as confidential business information (CBI) in the CDR datasets, the Agency reviewed the claims
and secured the necessary declassifications.
•	Life Cycle Stage Use Definitions
-	"Industrial use" means use at a site at which one or more chemicals or mixtures are manufactured (including
imported) or processed.
-	"Commercial use" means the use of a chemical or a mixture containing a chemical (including as part of an article)
in a commercial enterprise providing saleable goods or services.
-	"Consumer use" means the use of a chemical or a mixture containing a chemical (including as part of an article,
such as furniture or clothing) when sold to or made available to consumers for their use.
22

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2.2.2	Activities Excluded from the Scope of the Risk Evaluation
As explained in the final rule, Procedures for Chemical Risk Evaluation Under the Amended Toxic
Substances Control Act, TSCA Section 6(b)(4)(D) requires EPA to identify the hazards, exposures,
conditions of use, and the potentially exposed or susceptible subpopulations the Administrator expects to
consider in a risk evaluation, suggesting that EPA may exclude certain activities that it determines to be
conditions of use on a case-by-case basis (82 FR 33726, 33729; July 20, 2017) (U.S. EPA, 2017a).
TSCA Section 3(4) also grants EPA the authority to determine what constitutes a condition of use for a
particular chemical substance. EPA does not plan to include in this scope or in the risk evaluation the
activities described below that the Agency has concluded do not constitute conditions of use.
EPA has found information indicating that TPP is used in the manufacture and use of nail polish and in
flea and tick collars. EPA has determined that these uses are not TSCA conditions of use and will not be
evaluated during the risk evaluation. Nail polish is a cosmetic and is covered by the Federal Food, Drug,
and Cosmetic Act, 21 U.S.C. § 321 and flea and tick collars are regulated by the Federal Insecticide,
Fungicide, and Rodenticide Act, 7 U.S.C. § 136 et seq. Therefore, TPP in nail polish and in flea and tick
collars are outside the scope of the definition of chemical substance as regulated by TSCA.
2.2.3	Production Volume
As reported to EPA during the 2016 CDR reporting period and described here as a range to protect
production volumes that were claimed as confidential business information (CBI), total production
volume of TPP in 2015 was between 1 million and 10 million pounds (U.S. EPA, 2017b). EPA also uses
pre-2015 CDR production volume information, as detailed in the Proposed Designation o f Triphenyl
Phosphate (CASRN115-86-6) as a High-Priority Substance for Risk Evaluation (U.S. EPA, 2019a) and
will include future production volume information as it becomes available to support the exposure
assessment.
2.2.4	Overview of Conditions of Use and Lifecycle Diagram
The life cycle diagram provided in Figure 2-7 depicts the conditions of use that are considered within
the scope of the risk evaluation for the various life cycle stages as presented in Section . The activities
that the EPA determined are out of scope are not included in the life cycle diagram. Appendix A
contains more detailed descriptions (e.g., process descriptions, worker activities, process flow diagrams)
for each manufacture, processing, distribution in commerce, use and disposal category.
The information in the life cycle diagram is grouped according to the CDR processing codes and use
categories (including functional use codes for industrial uses and product categories for industrial,
commercial and consumer uses). The production volume of TPP in 2015 is included in the lifecycle
diagram, as reported to EPA during the 2016 CDR reporting period, as a range between 1 million and 10
million pounds (Figure 2-7).

-------
MFG/IMPORT
PROCESSING
INDUSTRIAL, COMMERCIAL, CONSUMER USES
RELEASES and WASTE DISPOSAL
Manufacture
(Including Import)
(1.000,000-
10,000..000 lb/yr)
Incorporated into Formulation, Mixture, or
Reaction Product
(Flame retardant in: All other chemical product and
preparation manufacturing: Computer and electronic
pro duct manufacturing; Photographic film paper, plate,
and chemical manufacturing: Plastic material and resin
manufacturing: Plastic product manufacturing; Rubber
product manufacturing; Textiles, apparel, and leather
manufacturing; Utilities: furniture and related product
manufacturing. Paint and coating manufacturing-
Solvent usedin photographic film paper, plate, and
chemical manufacturing: Plasticizer in: all other
chemical product and preparation manufacturing,
adhesives, sealants and lubricants. Operational fluids)
Incorporated into Article
(Solvent in photographic film paper, plate, and
chemical manufacturing. Plasticizer usedin plastics
product manufacturing. Photographic supplies, film,
and photo chemicals)
Paint and Coatings1
Plastic and Rubber Products. Not Covered Elsewhere1-2
e.g. thermoplastics; \ulcanization accelerator
Photographic Supplies, Film, and Photo Chemicals1-2
e.g. cellulose acetate film, flame retardant in camping tents
Lubricants and Greases1-2
e.g. hydraulic fluids
Electrical and Electronic Products1-2
Foam Seating and Bedding Products1-2
e.g. foam and upholstery, plasticizer in automobile upholstery
Furniture and Furnishings Not Covered Elsewhere1
4
Recycling
Disposal
See Conceptual Model for
Environmental Releases and Wastes
J Manufacture (Including Import)
| Processing
I 1 Uses:
'	1 I. Industrial and or
Commercial
2. Consumer
Figure 2-7 TPP Life Cycle Diagram
Note: Volume is not depicted in the life cycle diagram for processing and industrial, commercial, and consumer uses as specific production volume is claimed
confidential business information (CBI), or withheld pursuant to TSCA Section § 14 or unknown.
24

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2.3	Exposures
For TSCA exposure assessments, EPA plans to analyze exposures and releases to the environment
resulting from the conditions of use within the scope of the risk evaluation for TPP. Release pathways and
routes will be described in Section 2.3.3 to characterize the relationship or connection between the
conditions of use of the chemical and the exposure to human receptors, including potentially exposed or
susceptible subpopulations, and environmental receptors. EPA plans take into account, where relevant, the
duration, intensity (concentration), frequency and number of exposures in characterizing exposures to
TPP.
2.3.1	Physical and Chemical Properties
Consideration of physical and chemical properties is essential for a thorough understanding or prediction
of environmental fate (i.e., transport and transformation) and the eventual environmental concentrations.
They can also inform the hazard assessment. EPA plans to use the physical and chemical properties
described in the Proposed Designation of Triphenyl Phosphate (CASRN115-86-6) as a High-Priority
Substance for Risk Evaluation (U.S. EPA, 2019a) to support the development of the risk evaluation for
TPP. The values for the physical and chemical properties (Appendix A) may be updated as EPA collects
additional information through systematic review methods.
2.3.2	Environmental Fate and Transport
Understanding of environmental fate and transport processes assists in the determination of the specific
exposure pathways and potential human and environmental receptors that need to be assessed in the risk
evaluation for TPP. EPA plans to use the environmental fate characteristics described in the Proposed
Designation of Triphenyl Phosphate (CASRN 115-8 a High-Priority Substance for Risk Evaluation
(U.S. EPA, 2019a) to support the development of the risk evaluation for TPP. The values for the
environmental fate properties (Appendix C) may be updated as EPA collects additional information
through systematic review methods.
2.3.3	Releases to the Environment
Releases to the environment from conditions of use are a component of potential exposure and may be
derived from reported data that are obtained through direct measurement, calculations based on empirical
data or assumptions and models.
TPP is not reported to the Toxics Release Inventory (TRI). There may be releases of TPP from industrial
sites to wastewater treatment plants (WWTP), surface water, air and landfill. Articles that contain TPP
may release TPP to the environment during use or through recycling and disposal. EPA plans to review
these data in conducting the exposure assessment component of the risk evaluation for TPP.
2.3.4	Environmental Exposures
The manufacturing, processing, distribution, use and disposal of TPP can result in releases to the
environment and exposure to aquatic and terrestrial receptors (biota) via surface water, sediment, soil and
ambient air. Environmental exposures to biota are informed by releases into the environment, overall
persistence, degradation, bioaccumulation and partitioning across different media. Concentrations of
chemical substances in biota provide evidence of exposure. EPA plans to review available environmental
exposure data in biota in the risk evaluation. Monitoring data were identified in EPA's search for
reasonably available information on environmental exposures in biota to inform development of the
environmental exposure assessment for TPP. Relevant and reliable monitoring studies provide
information that can be used in an exposure assessment. Monitoring studies that measure environmental
concentrations or concentrations of chemical substances in biota provide evidence of exposure.
25

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EPA plans to review available environmental monitoring data for TPP. TPP was detected in wastewater
effluent, landfill leachate, sediment, soil, ambient air, as well as in fish (including shellfish) and dolphins
(EPA 2015, UK 2009, OECD 2002). According to the USGS Monitoring Data - National Water Quality
Monitoring Council, TPP exists in various organisms (USGS, 1991g).
2.3.5 Occupational Exposures
EPA plans to analyze worker activities where there is a potential for exposure under the various
conditions of use described in Section 2.2.2. In addition, EPA plans analyze exposure to occupational
non-users (ONUs), workers who do not directly handle the chemical but perform work in an area where
the chemical is present. EPA also expects to consider the effect(s) that engineering controls (ECs) and/or
personal protective equipment (PPE) have on occupational exposure levels as part of the draft risk
evaluation.
EPA plans to evaluate potential exposures from the processing of TPP as it is incorporated into
formulations and products. TPP is used as an additive flame retardant. In general, EPA plans evaluate the
potential for exposure from additive flame retardants due to blooming and release from article
components during their manufacture and industrial/commercial use. TPP is also used as a component of
liquid products; including, but not limited to paints, coatings, lubricants and greases.
Worker activities associated with the conditions of use within the scope of the risk evaluation for TPP that
will be analyzed, include, but are not limited to:
•	Unloading and transferring TPP to and from storage containers to process vessels during
manufacturing, processing and use;
•	Handling, transporting and disposing of waste containing TPP during manufacturing, processing,
use and recycling;
•	Cleaning and maintaining equipment during manufacturing, processing, use and recycling;
•	Sampling chemicals, formulations or products containing TPP for quality control during
manufacturing, processing, use and recycling;
•	Repackaging chemicals, formulations or products containing TPP during manufacturing,
processing, use and recycling; and
•	Performing other work activities in or near areas where TPP is used.
TPP is a solid with a vapor pressure of approximately 6.3x 10-6 mm Hg at 25 °C/77 °F. (U.S. EPA, 2019a)
EPA anticipates inhalation of mist, dust, and other respirable particles as an exposure pathway for
workers and occupational non-users during the manufacture, processing, and commercial/industrial use of
various products containing TPP (e.g., particulate generated during manufacture and handling of foam and
plastics and incorporation of foam and plastics into finished products, and mist generated during
application to textiles and application of paints and coatings).
EPA generally does not evaluate occupational exposures through the oral route. Workers may
inadvertently transfer chemicals from their hands to their mouths, ingest inhaled particles that deposit in
the upper respiratory tract or consume contaminated food. The frequency and significance of this
exposure route are dependent on several factors including the p-chem properties of the substance during
expected worker activities, workers' awareness of the chemical hazards, the visibility of the chemicals on
the hands while working, workplace practices, and personal hygiene that is difficult to predict (Cherrie et
al., 2006). However, EPA will consider oral exposure on a case-by-case basis for certain COUs and
26

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worker activities where there is information and data on incidental ingestion of inhaled dust. EPA will
consider ingestion of inhaled dust as an inhalation exposure for TPP.
TPP has an Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL).
The PEL is 3 milligrams (mg)/cubic meter (m3) over an 8-hour workday, time weighted average (TWA).
This chemical also has a National Institute for Occupational Safety and Health (NIOSH) Recommended
Exposure Limit (REL) of 3 mg/m3 TWA. The American Conference of Governmental Industrial
Hygienists (ACGIH) set the Threshold Limit Value (TLV) at 3 ppm TWA. Also, the OSHA Permissible
Exposure Limit (PEL) for Particulates Not Otherwise Regulated (PNOR) (15 mg/m3) (29 CFR
) may be applicable if particulate matter is generated during industrial operations.
EPA anticipates dermal exposure to workers from contact with solids during packaging and repackaging
operations at manufacturing and import sites when TPP is handled as a dry powder. EPA also anticipates
dermal exposure to liquid if TPP is formulated with liquid chemical and handled as a liquid. Dermal
exposure by ONU is not expected for these conditions of use as they are not expected to directly handle
the chemical.
2.3.6	Consumer Exposures
CDR reporting indicate that TPP is used in consumer products used in indoor environments, including
foam seating and bedding products, plastic and rubber products, and photographic supplies, film, and
photo chemicals (CDR 2016, 2012). The 2012 CDR also reported the use of TPP in electrical and
electronic products (CDR 2012). Several of these products have the potential to be mouthed by children.
In addition, consumer handling of the disposal on TPP containing materials can lead to consumer and
bystander exposures. The main exposure routes for these uses where consumers interact with products and
articles containing TPP are dermal, inhalation, and dust ingestion, including children's mouthing of
articles (e.g., plastics, textiles, wood products) containing TPP.
2.3.7	General Population Exposures
Releases of TPP from certain conditions of use, such as manufacturing, processing, or disposal activities,
may result in general population exposures. TPP was detected in surface water, ground water, soil,
ambient air, indoor air, indoor dust, as well as in fish (including shellfish) and dolphins (EPA 2015, UK
2009, OECD 2002, USGS, 1991a,b,c,d,e,f,g). EPA plans to evaluate the available literature for the
presence of TPP in drinking water, ground water, ambient air, indoor air, fish, human breast milk, and
dust and soil, which may be mouthed or ingested.
2.4	Hazards (Effects)
2.4.1 Environmental Hazards
As described in the Promised Designation of Trmhenvl Phosphate fCASK	nL is a High-Priority
Substance for Risk Evaluation (U.S. EPA, 2019a), EPA considered reasonably available information from
peer-reviewed assessments and databases to identify potential environmental hazards for TPP. EPA
considers all the potential environmental hazards for TPP identified during prioritization (U.S. EPA,
2019) to be relevant for the risk evaluation and thus they remain within the scope of the evaluation. EPA
is in the process of identifying additional reasonably available information through systematic review
methods and public comments, which may update the list of potential environmental hazards associated
with TPP. If necessary, EPA plans to update the list of potential hazards in the final scope document of
TPP. Based on information identified during prioritization, environmental hazard effects were identified
for aquatic and terrestrial organisms.
27

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2.4.2 Human Health Hazards
As described in the Proposed Designation of Triyhenyl Phosphate (CA S.K \ ' i *• 
-------
2.6,1 Conceptual Model for Industrial and Commercial Activities and Uses
Figure 2-8 illustrates the conceptual model for the pathways of exposure from industrial and commercial
activities and uses of TPP that EPA plans to include in the risk evaluation. There is potential for exposure
to workers and/or occupational non-users via inhalation routes and exposures to workers via dermal
routes. Dermal exposure to TPP in both liquid and solid form is expected, as TPP can be used/transported
in solid form or suspended in solution. Inhalation exposure to dust is expected to be a significant exposure
pathway. Additionally, potential inhalation exposure to TPP in mist form is expected for certain
conditions of use. EPA plans to evaluate activities resulting in exposures associated with distribution in
commerce (e.g., loading, unloading) throughout the various lifecycle stages and conditions of use (e.g.,
manufacturing, processing, industrial use, commercial use, and disposal) rather than a single distribution
scenario. For each condition of use identified in Table 2-2, an initial determination was made as to
whether or not each combination of exposure pathway, route, and receptor will be assessed in the risk
evaluation. The supporting rationale are presented in Appendix F.
INDUSTRIAL AND COMMERCIAL	EXPOSURE PATHWAY	EXPOSURE ROUTE	RECEPTORS	HAZARDS
ACTIVITIES fUSES
.
Occupational Non-
Inhalation
7	7
Not Covers
Seating and Bedding
Furniture and Furnishings Not
Covered Elsewhere
Waste Handling, Treatment
	and Disposal	
Figure 2-8 TPP Conceptual Model for Industrial and Commercial Activities and Uses: Worker and
ONU Exposures and Hazards
The conceptual model presents the exposure pathways, exposure routes, and hazards to human receptors from industrial and
commercial activities and uses of TPP.
2.6.2 Conceptual Model for Consumer Activities and Uses
The conceptual model in Figure 2-9 presents the exposure pathways, exposure routes and hazards to
human receptors from consumer activities and uses of TPP that EPA plans to include in the risk
29

-------
evaluation. Inhalation is expected to be a route of exposure for consumers and plans to evaluate inhalation
exposures to TPP vapors, mists, and dusts for consumers and bystanders. Consumer oral exposures may
also result from direct contact with mists and powders or dust containing TPP during use. Dermal
exposures may result from liquids, and mists containing TPP. Bystanders are not expected to have
significant direct dermal or oral contact to TPP products. The supporting rationale for consumer pathways
considered for TPP are included in Appendix G.
30

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CONSUMER AC TIVITIE S
EXPOSURE
pathway
EXPOSURE
ROUTE
RECEPTORS
HAZARDS


Plastic and lubber


Products. Not Covered


Elsewhere


I Photographic Supplies.

Film, and Photo

| Chemicals



1.its and Greases 1


Efectacal aniEie:troiiie


Pror.ucti



Foam Seatme and


Bedding Products


u
... . -oatact
•<" Denna!
Indoor Ait'Bus!
Inhalation.
Vapor Mist
Hazards Potentially
and-'CH Chronic
Jsxposures
Wastewater. Liquid Wastes aid
Solid Wastes (See Environmental
Releases Conceptual Models)
Figure 2-9 TPP Conceptual Model for Consumer Activities and Uses: Consumer Exposures and Hazards
The conceptual model presents the exposure pathways, exposure routes and hazards to human receptors from consumer activities and uses of TPP.
31

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2.6.3 Conceptual Model for Environmental Releases and Wastes: Potential Exposures
and Hazards
Figure 2-10 presents the exposure pathways, exposure routes, and hazards to human and environmental
receptors for releases and waste streams associated with environmental releases of TPP. EPA plans to
evaluate pathways and routes of exposures to receptors (e.g., general population, aquatic, terrestrial
species) that may occur from industrial and/or commercial uses, releases to air, water or land, including
biosolids and soil, and other conditions of use. EPA expects humans to be exposed to TPP from air
emissions via inhalation as well as from water, liquid, and solid waste releases - orally via drinking
water, fish and soil ingestion, and dermally from contact with groundwater and soil. The supporting
rationale for general population and environmental pathways considered for TPP are included in
Appendix H.
32

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RELEASES AND WASTES FROM INDUSTRIAL /
COMMERCIAL / CONSUMER USES
EXPOSURE PATHWAYS
EXPOSURE ROUTES
RECEPTORS
Industrial Pre
Treatment or
Industrial WWT
Water, Sediment
Indirect discharge
t
Aquatic
Fish Ingestion
Wastewater or
POTW
Liquid Wastes
Underground
Injection
Drinking
Water
Biosohds
Hazardous and
Municipal Waste
Landfill
Land
Disposal
General
Dermal
Population
Ground
Water
Solid Wastes
Liquid Wastes
Hazardous and
Municipal Waste
Incinerators
Inhalation
Fugitive Emissions
Off-site Waste
Transfer
Terrestrial
Species
Recycling, Other
Treatment
Emissions to Air
Hazards Potentially
Associated with
Acute and/or Chronic
Exposures
1.	Drinking Water to inhalation would be if there was showering.
2.	For regulation of hazardous and municipal waste incinerators and hazardous and municipal waste landfills CAA and RCRA
have shared regulatory oversight.
Figure 2-10 TPP Conceptual Model for Environmental Releases and Wastes: Environmental and General Population Exposure and
Hazards
Industrial wastewater or liquid wastes may be treated on-site and then released to surface water (direct discharge), or pre-treated and released to Publicly Owned
Treatment Works (POTW) (indirect discharge). For consumer uses, such wastes may be released directly to POTW. Drinking water will undergo further treatment in
drinking water treatment plant. Ground water may also be a source of drinking water.
Receptors include potentially exposed or susceptible subpopulations (see Section 2.5).
33

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2.7	Analysis Plan
The analysis plan is based on EPA's knowledge of TPP to date which includes a partial, but not complete
review of reasonably available information as described in Section 1. EPA encourages submission of
additional data, such as full study reports or workplace monitoring from industry sources, that may be
relevant for EPA's evaluation of conditions of use, exposures, hazards and potentially exposed or
susceptible subpopulations during risk evaluation. Further, EPA may consider any relevant CBI in a manner
that protects the confidentiality of the information from public disclosure. EPA plans continue to consider
new information submitted by the public. Should additional data or approaches become reasonably
available, EPA may update its analysis plan in the final scope document. As discussed in Applications of
Systematic Review in TSCA Risk Evaluations (U.S. EPA, 2018b), targeted supplemental searches during the
analysis phase may be necessary to identify additional reasonably available information (e.g., commercial
mixtures) for the risk evaluation of TPP.
2.7.1 Physical and Chemical Properties and Environmental Fate
EPA plans to analyze the physical and chemical (p-chem) properties and environmental fate and transport
of TPP as follows:
1)	Review reasonably available measured or estimated p-chem and environmental fate endpoint
data collected using systematic review procedures and, where available, environmental
assessments conducted by other regulatory agencies.
EPA plans review data and information collected through the systematic review methods and public
comments about the p-chem properties (Appendix A) and fate endpoints (Appendix C) previously
summarized in the Proposed Designation of Triphenvl Phosphate fCASRN 115-86-6) as a Hish-
Priority Substance for Risk Evaluation (U.S. EPA, 2019a). All sources cited in EPA's analysis will
be reviewed according to the procedures described in the systematic review documentation that EPA
plans to publish prior to finalizing the scope document. Where the systematic review process fails to
identify experimentally measured chemical property values of sufficiently high quality, these values
will be estimated using chemical parameter estimation models as appropriate. Model-estimated fate
properties will be reviewed for applicability and quality.
2)	Using measured data and/or modeling, determine the influence of p-chem properties and
environmental fate endpoints (e.g., persistence, bioaccumulation, partitioning, transport) on
exposure pathways and routes of exposure to human and environmental receptors.
Measured data and, where necessary, model predictions of p-chem properties and environmental
fate endpoints will be used to characterize the persistence and movement of TPP within and across
environmental media. The fate endpoints of interest include volatilization, sorption to organic matter
in soil and sediments, water solubility, aqueous and atmospheric photolysis rates, aerobic and
anaerobic biodegradation rates, and potential bioconcentration and bioaccumulation. These
endpoints will be used in exposure calculations.
34

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3) Conduct a weight-of-evidence evaluation of p-chem and environmental fate data, including
qualitative and quantitative sources of information.
During risk evaluation, EPA plans to evaluate and integrate the p-chem and environmental fate
evidence identified in the literature inventory using the methods described in the systematic review
documentation that EPA plans to publish prior to finalizing the scope document.
2.7.2 Exposure
EPA plans to analyze exposure levels to TPP indoor air, ambient air, surface water, sediment, soil, aquatic
biota, and terrestrial biota. EPA has not yet determined the exposure levels in these media or how they may
be used in the risk evaluation. Exposure scenarios are combinations of sources (uses), exposure pathways,
and exposed receptors. Draft release/exposure scenarios corresponding to various conditions of use for TPP
are presented in Appendix F. EPA plans to analyze scenario-specific exposures.
Based on their p-chem properties, expected sources, and transport and transformation within the outdoor
and indoor environment, chemical substances are more likely to be present in some media and less likely to
be present in others. Exposure level(s) can be characterized through a combination of reasonably available
monitoring data and modeling approaches.
2.7.2.1 Environmental Releases
EPA plans to analyze releases to environmental media as follows:
1)	Review reasonably available published literature and other reasonably available information
on processes and activities associated with the conditions of use to analyze the types of releases
and wastes generated.
EPA has reviewed some key data sources containing information on processes and activities
resulting in releases, and the information found is described in Appendix A. EPA plans to continue
to review data sources identified in Appendix A during risk evaluation using the evaluation strategy
in the systematic review documentation that EPA plans to publish prior to finalizing the scope
document. Potential sources of environmental release data are summarized in Table 2-3 below:
Table 2-3 Categories and Sources of Environmental Release Data	
U.S. EPA Generic Scenarios	
OECD Emission Scenario Documents	
UK Environmental Risk Evaluation Report	
Discharge Monitoring Report (DMR) surface water discharge data for TPP from
NPDES-permitted facilities	
2)	Review reasonably available chemical-specific release data, including measured or estimated
release data (e.g., data from risk assessments by other environmental agencies).
EPA plans to continue to review relevant data sources as identified in Appendix Aduring the risk
evaluation. EPA plans to match identified data to applicable conditions of use and identify data gaps
where no data are found for particular conditions of use. EPA plans to attempt to address data gaps
identified as described in steps 3 and 4 below by considering potential surrogate data and models.
Additionally, for conditions of use where no measured data on releases are available, EPA plans to
use a variety of methods including release estimation approaches and assumptions in the Chemical
Screening Tool for Occupational Exposures and Releases (Chem.STEER) (	.013).
35

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3)	Review reasonably available measured or estimated release data for surrogate chemicals that
have similar uses and physical properties.
EPA has not yet identified surrogate chemicals and data that can be used to estimate releases from
uses of TPP. EPA plans to review release data for surrogate chemicals that have uses and chemical
and physical properties similar to TPP as it is identified. EPA may conduct targeted searches for
surrogate data.
4)	Review reasonably available data that may be used in developing, adapting or applying
exposure models to the particular risk evaluation.
This item will be performed after completion of #2 and #3 above. EPA plans to evaluate relevant
data to determine whether the data can be used to develop, adapt or apply models for specific
conditions of use (and corresponding release scenarios). EPA has identified information from
various EPA statutes (including, for example, regulatory limits, reporting thresholds or disposal
requirements) that may be relevant to release estimation. EPA plans to further consider relevant
regulatory requirements in estimating releases during risk evaluation.
5)	Review and determine applicability of OECD Emission Scenario Documents (ESDs) and EPA
Generic Scenarios to estimation of environmental releases.
The EPA has identified potentially relevant OECD Emission Scenario Documents (ESDs) and EPA
Generic Scenarios (GS) that correspond to some conditions of use; for example, the 2009 ESD on
Plastics Additives and the 2011 ESD on the Chemical Industry may be useful. The EPA plans to
critically review these generic scenarios and ESDs to determine their applicability to the conditions
of use.
EPA Generic Scenarios are available at the following: https://www.epa.gov/tsca-screening-
tools/chernsteer-chermcal-screening-tool~exposures-and-environrnental~releases
Generic Scenarios that contain information that may be related to the potential uses of TPP include,
but are not limited to:
•	EPA's Additives in Plastics Processing (Compounding) - Draft Generic Scenario for Estimating
Occupational Exposures and Environmental Releases (May 2004);
•	EPA's Spray Coatings in the Furniture Industry - Generic Scenario for Estimating Occupational
Exposures and Environmental Releases (April 2004);
•	EPA's Leather Dyeing - Generic Scenario for Estimating Occupational Exposures and
Environmental Releases (September 2000);
•	EPA's Fabric Finishing - Draft Generic Scenario for Estimating Occupational Exposures and
Environmental Releases (September 1994);
•	EPA's Application of Spray Polyurethane Foam Insulation - Generic Scenario for Estimating
Occupational Exposures and Environmental Releases (March 2019);
•	EPA's Industry Profile for the Flexible Polyurethane Foam Industry- Generic Scenario for
Estimating Occupational Exposures and Environmental Releases (February 2004); and,
•	EPA's Industry Profile for the Rigid Polyurethane Foam Industry - Draft Generic Scenario for
Estimating Occupational Exposures and Environmental Releases (September 2004).
OECD Emission Scenario Documents are available at the following: https://www.epa.gov/tsca-
screening~tools/chernsteer~chermcal-screening~tool-exposures~and-environmental~releases
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ESDs that contain information that may be related to the potential uses of TPP include, but are not
limited to:
•	OECD's Complementing Document to the E Plastic Additives: Plastic Additives During
the Use of End Products (May 2019);
•	OECD's Complementing Document for ESP on Coatins Industry: Application of Point Solvents
for Industrial Coating (December 2015);
•	OECD's ESP on the Chemical Industry (September 2011);
•	OECD's ESP on Radiation Curable Coatins, Inks, and Adhesives (July 2011);
•	OECD's ESP on Plastic Additives (July 2009); and
•	OECD's ESP on Coatins Industry (Paints, Lacquers and Varnishes) (July 2009).
6)	Map or group each condition of use to a release assessment scenario(s).
EPA has identified release scenarios and mapped (i.e., grouped) them to relevant conditions of use
as shown in Appendix C. EPA was not able to identify release scenarios corresponding to some
conditions of use (e.g. automotive care products, and recycling). EPA plans to perform targeted
research to understand those uses, which may inform identification of release scenarios. EPA may
further refine the mapping of release scenarios based on factors (e.g., process equipment and
handling, magnitude of production volume used, and release sources and usage rates of TPP and
polymer products and formulations containing TPP, or professional judgment) corresponding to
conditions of use as additional information is identified during risk evaluation.
7)	Evaluate the weight of the scientific evidence of environmental release data.
During risk evaluation, EPA plans to evaluate and integrate the exposure evidence identified in the
literature inventory using the methods described in the systematic review documentation that EPA
plans to publish prior to finalizing the scope document. The data integration strategy will be
designed to be fit-for-purpose in which EPA plans to use systematic review methods to assemble the
relevant data, evaluate the data for quality and relevance, including strengths and limitations,
followed by synthesis and integration of the evidence.
2.7.2.2 Environmental Exposures
EPA plans to analyze the following in developing its environmental exposure assessment of TPP:
1)	Review available environmental and biological monitoring data for all media relevant to
environmental exposure.
For TPP, environmental media which will be analyzed are sediment, biosolids, soil, air and water.
The environmental exposure pathways which have been identified in the literature include aquatic
and terrestrial.
2)	Review reasonably available information on releases to determine how modeled estimates of
concentrations near industrial point sources compare with available monitoring data.
EPA plans to analyze reasonably available environmental exposure models that meet the TSCA
Section 26(h) and (i) Science Standards and that estimate water, sediment, and soil concentrations
alongside reasonably available water, sediment, and soil monitoring data to characterize
environmental exposures. Modeling approaches to estimate surface water concentrations, sediment
concentrations and soil concentrations generally consider the following inputs: direct release into
water, sediment, or soil, indirect release into water, sediment, or soil (i.e., air deposition), fate and
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transport (partitioning within media) and characteristics of the environment (e.g., river flow, volume
of lake, meteorological data).
3)	Review reasonably available biomonitoring data for vegetation, invertebrates, fish, non-fish
vertebrates (i.e., amphibians, reptiles, mammals). Plan to consider whether these data could be
used to compare with comparable species or taxa-specific toxicological benchmarks.
EPA plans to analyze predatory bird species that consume fish with elevated levels of TPP. If
species-specific biomonitoring data matches toxicity studies, direct comparisons can be made. EPA
plans to consider refining data for other species by using body weight of the birds, fish ingestion rate
of birds, and typical fish species consumed.
4)	Determine applicability of existing additional contextualizing information for any monitored
data or modeled estimates during risk evaluation.
There have been changes to use patterns of TPP over the last few years. Monitoring data or modeled
estimates will be reviewed to determine how representative they are of applicable use patterns.
EPA plans to evaluate any studies which relate levels of TPP in the environment or biota with
specific sources or groups of sources.
5)	Group each condition(s) of use to environmental assessment scenario(s).
EPA plans refine and finalize exposure scenarios for environmental receptors by considering
sources (use descriptors), exposure pathways including routes, and populations exposed. For TPP,
the following are noteworthy considerations in constructing exposure scenarios for environmental
receptors:
Estimates of surface water concentrations, sediment concentrations and soil
concentrations near industrial point sources based on available monitoring data.
Modeling inputs such as releases into the media of interest, fate and transport and
characteristics of the environment.
Reasonably available biomonitoring data, which could be used to compare with species
or taxa-specific toxicological benchmarks.
Applicability of existing additional contextual information for any monitored data or
modeled estimates during risk evaluation. Review and characterize the spatial and
temporal variability, to the extent that data are available, and characterize exposed
aquatic and terrestrial populations.
Weight of the scientific evidence of environmental occurrence data and modeled
estimates.
6)	Evaluate the weight of the scientific evidence of environmental occurrence data and modeled
estimates.
During risk evaluation, EPA plans to evaluate and integrate the exposure evidence identified in the
literature inventory using systematic review methods.
2.7.2.3 Occupational Exposures
EPA plans to analyze both worker and occupational non-user exposures as follows:
1) Review reasonably available exposure monitoring data for specific condition(s) of use.
EPA plans to review exposure data including workplace monitoring data collected by government
agencies such as the Occupational Safety and Health Administration (OSHA) and the National
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Institute for Occupational Safety and Health (NIOSH), and monitoring data found in published
literature. These workplace monitoring data include personal exposure monitoring data (direct
exposures) and area monitoring data (indirect exposures).
2)	Review reasonably available exposure data for surrogate chemicals that have uses, volatility
and chemical and physical properties similar to TPP.
EPA plans to review literature sources identified and if surrogate data are found, these data will be
matched to applicable conditions of use for potentially filling data gaps.
3)	For conditions of use where data are limited or not available, review existing exposure models
that may be applicable in estimating exposure levels.
EPA has identified potentially relevant OECD ESDs and EPA Generic Scenarios corresponding to
some conditions of use. EPA plans to critically review these generic scenarios and ESDs to
determine their applicability to the conditions of use assessed. EPA may conduct industry outreach
efforts or perform supplemental, targeted literature searches to better understand the process steps
involved in conditions of use. EPA plans to also consider the applicability of exposure models in the
Chemical Screening Tool for Occupational Exposure and Releases (ChemSTEER) (U.S. EPA,
2016) tool that are routinely used for assessing new chemicals to assess exposures during various
conditions of use. For conditions of use where data are not available, EPA plans to review existing
exposure models that may be applicable in estimating exposure levels of TPP. EPA may also
perform targeted research to identify other models that EPA could use to estimate exposures for
certain conditions of use.
4)	Review reasonably available data that may be used in developing, adapting or applying
exposure models to a particular risk evaluation scenario.
This step will be performed after Steps #2 and #3 are completed. Based on information developed
from Steps #2 and #3, EPA plans to evaluate relevant data to determine whether the data can be
used to develop, adapt, or apply models for specific conditions of use (and corresponding exposure
scenarios). EPA may utilize existing, peer-reviewed exposure models developed by EPA/OPPT,
other government agencies, or available in the scientific literature, or EPA may elect to develop
additional models to assess specific condition(s) of use. Inhalation exposure models may be simple
box models or two-zone (near-field/far-field) models. In two-zone models, the near-field exposure
represents potential inhalation exposures to workers, and the far-field exposure represents potential
inhalation exposures to occupational non-users.
5)	Consider and incorporate applicable engineering controls (ECs) and/or personal protective
equipment (PPE) into exposure scenarios.
EPA plans to review potentially relevant data sources on ECs and PPE to determine their
applicability and incorporation into exposure scenarios during risk evaluation. EPA plans to assess
worker exposure pre- and post-implementation of ECs, using reasonably available information on
available control technologies and control effectiveness. For example, EPA may assess worker
exposure in industrial use scenarios before and after implementation of local exhaust ventilation.
6)	Map or group each condition of use to occupational exposure assessment scenario(s).
EPA has identified occupational exposure scenarios and mapped them to relevant conditions of use
(see Appendix C). As presented in Table Apx F-l, the EPA has grouped the scenarios into
representative release/exposure scenarios, all of which will be evaluated. EPA was not able to
identify occupational scenarios corresponding to some conditions of use (e.g. recycling, construction
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and demolition). The EPA may further refine the mapping/grouping of occupational exposure
scenarios based on factors (e.g., process equipment and handling, magnitude of production volume
used, and exposure/release sources) corresponding to conditions of use as additional information is
identified during risk evaluation.
7) Evaluate the weight of the scientific evidence of occupational exposure data, which may
include qualitative and quantitative sources of information.
During risk evaluation, EPA plans to evaluate and integrate the exposure evidence identified in the
literature inventory using the methods described in the systematic review documentation that EPA
plans to publish prior to finalizing the scope document. EPA plans to rely on the weight of the
scientific evidence when evaluating and integrating occupational data. The data integration strategy
will be designed to be fit-for-purpose in which EPA plans to use systematic review methods to
assemble the relevant data, evaluate the data for quality and relevance, including strengths and
limitations, followed by synthesis and integration of the evidence.
2.7.2.4 Consumer Exposures
EPA plans to analyze both consumers using a consumer product and bystanders associated with the
consumer using the product as follows:
1)	Group each condition of use to consumer exposure assessment scenario(s).
Refine and finalize exposure scenarios for consumers by considering combinations of sources
(ongoing consumer uses), exposure pathways including routes, and exposed populations.
For TPP, the following are noteworthy considerations in constructing consumer exposure scenarios:
Conditions of use and type of consumer product
Duration, frequency and magnitude of exposure
Weight fraction of chemical in products
Amount of chemical used
2)	Evaluate the relative potential of indoor exposure pathways based on reasonably available
data.
Indoor exposure pathways expected to be relatively higher include particle inhalation, dust
ingestion, and dermal contact as a result of indoor use of TPP consumer products. Indoor exposure
pathways expected to be relatively lower include inhalation of vapor and mist and liquid and mist
oral ingestion. The data sources associated with these respective pathways have not yet been
comprehensively evaluated, so quantitative comparisons across exposure pathways or in relation to
toxicity thresholds are not yet available.
3)	Review existing indoor exposure models that may be applicable in estimating indoor air,
indoor dust concentrations, or indoor dust surface loadings.
Indoor exposure models that estimate emission and migration of semi-volatile organic compounds
(SVOCs) into the indoor environment are available. These models generally consider mass transfer
as informed by the gas-phase mass transfer coefficient, the solid-phase diffusion coefficient, and the
material-air partition coefficient. These properties vary based on p-chem properties and properties of
the material. The OPPT's Indoor Environmental Concentrations in Buildings with Conditioned and
Unconditioned Zones (IECCU) model and other similar models can be used to estimate indoor air
and dust exposures from indoor sources.
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4)	Review reasonably available empirical data that may be used in developing, adapting or
applying exposure models to a particular risk evaluation scenario. For example, existing
models developed for a chemical assessment may be applicable to another chemical assessment
if model parameter data are available.
To the extent other organizations have already modeled a TPP consumer exposure scenario that is
relevant to the OPPT's assessment, EPA plans evaluate those modeled estimates. In addition, if
other chemicals similar to TPP have been modeled for similar uses, those modeled estimates will
also be evaluated. The underlying parameters and assumptions of the models will also be evaluated.
5)	Review reasonably available consumer product-specific sources to determine how those
exposure estimates compare with each other and with indoor monitoring data reporting TPP
in specific media (e.g., indoor air).
The availability of TPP concentration for various ongoing uses will be evaluated. This data provides
the source term for any subsequent indoor modeling. Source attribution between overall indoor air
levels and various indoor sources will be analyzed.
6)	Review reasonably available population- or subpopulation-specific exposure factors and
activity patterns to determine if potentially exposed or susceptible subpopulations need to be
further refined.
During risk evaluation, EPA plans to evaluate and integrate the exposure evidence identified in the
literature inventory using the methods described in the systematic review documentation that EPA
plans to publish prior to finalizing the scope document.
7)	Evaluate the weight of the scientific evidence of consumer exposure estimates based on
different approaches.
EPA plans rely on the weight of the scientific evidence when evaluating and integrating data related
to consumer exposure. The weight of the scientific evidence may include qualitative and
quantitative sources of information. The data integration strategy will be designed to be fit-for-
purpose in which EPA plans use systematic review methods to assemble the relevant data, evaluate
the data for quality and relevance, including strengths and limitations, followed by synthesis and
integration of the evidence.
2.7.2.5 General Population
EPA plans to analyze general population exposures as follows:
1) Refine and finalize exposure scenarios for general population by sources and uses, exposure
pathways including routes, and exposed populations.
For TPP, the following are noteworthy considerations in constructing exposure scenarios for the
general population: routes of exposure, releases to air, water or land resulting from industrial,
commercial, and other conditions of use, in addition to:
Review of reasonably available environmental and biological monitoring data for media to
which general population exposures are expected.
For exposure pathways where data are not available, review existing exposure models that
may be applicable in estimating exposure levels.
Consider and incorporate applicable media-specific regulations into exposure scenarios or
modeling.
Review reasonably available data that may be used in developing, adapting or applying
exposure models to the particular risk evaluation. For example, existing models developed
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for a chemical assessment may be applicable to another chemical assessment if model
parameter data are available.
Review reasonably available information on releases to determine how modeled estimates of
concentrations near industrial point sources compare with available monitoring data.
Review reasonably available population- or subpopulation-specific exposure factors and
activity patterns to determine if potentially exposed or susceptible subpopulations need be
further defined.
Evaluate the weight of the scientific evidence of general population exposure data.
Map or group each condition of use to general population exposure assessment scenario(s).
Environmental Exposure pathways regulated by non-TSCA EPA laws and regulations will
be excluded from analysis
EPA plans to evaluate a variety of data types to determine which types are most appropriate when
quantifying exposure scenarios. Environmental monitoring data, biomonitoring data, modeled
estimates, experimental data, epidemiological data, and survey-based data can all be used to
quantify exposure scenarios. In an effort to associate exposure estimates with sources of exposure
and/or conditions of use, EPA plans consider source apportionment across exposure scenarios
during risk evaluation. EPA anticipates that there will be a wide range in the relative exposure
potential of the exposure scenarios identified in Appendix G. Source apportionment characterizes
the relative contribution of any of the following: a use/source toward a total media concentration, a
media concentration toward a total exposure route, or an exposure route toward a total external or
internal dose. This consideration may be qualitative, semi-quantitative, or quantitative, and is
dependent upon reasonably available data and approaches. For example, EPA may consider the co-
location of TSCA industrial facilities with reasonably available monitoring data or modeled
estimates. EPA may compare modeled estimates for discrete outdoor and indoor sources/uses that
apply to unique receptor groups. If available, EPA plans to compare multiple scenario-specific and
background exposure doses estimated from media-specific concentrations and exposure factors with
available biomonitoring data. The forward-calculated and back-calculated exposures could be
compared to characterize the relative contribution from defined exposure scenarios.
After refining and finalizing exposure scenarios, EPA plans quantify concentrations and/or doses for
these scenarios. The number of scenarios will depend on how combinations of uses, exposure
pathways, and receptors are characterized. The number of scenarios is also dependent upon the
reasonably available data and approaches to quantify scenarios. When quantifying exposure
scenarios, EPA plans to use a tiered approach. First-tier analysis is based on data that is reasonably
available without a significant number of additional inputs or assumptions, and may be qualitative,
semi-quantitative, or quantitative. First-tier analyses were conducted during problem formulation
and are expected to continue during risk evaluation. The results of first tier analyses inform whether
scenarios require more refined analysis. Refined analyses will be iterative and require careful
consideration of variability and uncertainty. Should data become available that summarily alters the
overall conclusion of a scenario through iterative tiering, EPA can refine its analysis during risk
evaluation.
2) Review reasonably available environmental and biological monitoring data for exposure
pathways and media to which general population exposures are expected.
General population exposure pathways expected to be relatively higher include: ingestion of water
and food including fish, root crops, and mother's milk. General population exposure pathways
expected to be relatively lower include: dermal contact to TPP via liquids, and inhalation of TPP via
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vapors, mists and dusts. The data sources associated with these respective pathways have not been
comprehensively evaluated, so quantitative comparisons across exposure pathways or in relation to
toxicity thresholds are not yet available.
3)	For exposure pathways where empirical data is not available, review exposure models that
may be applicable in estimating exposure levels.
For TPP, EPA plans to consider exposure models for general population exposure, including models
that estimate, surface water concentrations, sediment concentrations, soil concentrations, and uptake
from aquatic and terrestrial environments into edible aquatic, and terrestrial organisms.
4)	Review reasonably available exposure modeled estimates. For example, existing models
developed for a previous TPP chemical assessment may be applicable to EPA's assessment. In
addition, another chemical's assessment may also be applicable if model parameter data are
available.
To the extent other organizations have already modeled TPP general population exposure scenario
that is relevant to the OPPT's assessment, EPA plans to evaluate those modeled estimates. In
addition, if modeled estimates for other chemicals with similar physical chemical properties and
similar uses are available, those modeled estimates will also be evaluated. The underlying
parameters and assumptions of the models will also be evaluated.
5)	Review reasonably available information on releases to determine how modeled estimates of
concentrations near industrial point sources compare with reasonably available monitoring
data.
For TPP, exposure scenarios that involve potentially exposed or susceptible subpopulations will
consider age-specific behaviors, activity patterns, and exposure factors unique to those
subpopulations. For example, children will have different intake rates for soil than adults.
6)	Review reasonably available information about population- or subpopulation-specific
exposure factors and activity patterns to determine if potentially exposed or susceptible
subpopulations need to be further defined (e.g., early life and/or puberty as a potential critical
window of exposure).
For TPP, exposure scenarios that involve potentially exposed or susceptible subpopulations will
consider age-specific behaviors, activity patterns, and exposure factors unique to those
subpopulations. For example, children will have different intake rates for dust, soil, and diet than
adults.
7)	Evaluate the weight of the scientific evidence of general population exposure estimates based
on different approaches.
During risk evaluation, EPA plans to evaluate and integrate the exposure evidence identified in the
literature inventory using the methods described in the systematic review documentation that EPA
plans to publish prior to finalizing the scope document
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2.7.3 Hazards (Effects)
2.7.3.1 Environmental Hazards
EPA plans to conduct an environmental hazard assessment of TPP as follows:
1)	Review reasonably available environmental hazard data, including data from alternative test
methods (e.g., computational toxicology and bioinformatics; high-throughput screening
methods; data on categories and read-across; in vitro studies).
EPA plans to analyze the hazards of TPP to aquatic and/or terrestrial organisms, including plants,
invertebrates (e.g., insects, arachnids, mollusks, crustaceans), and vertebrates (e.g., mammals, birds,
amphibians, fish, reptiles) across exposure durations and conditions if potential environmental
hazards are identified through systematic review results and public comments. Additional types of
environmental hazard information will also be considered (e.g., analogue and read-across data)
when characterizing the potential hazards of TPP to aquatic and/or terrestrial organisms.
Environmental hazard data will be evaluated using the environmental toxicity data quality criteria
outlined in the systematic review documentation that EPA plans to publish prior to finalizing the
scope document. The study evaluation results will be documented in the risk evaluation phase and
data from suitable studies will be extracted and integrated in the risk evaluation process.
Hazard endpoints (e.g., mortality, growth, immobility, reproduction) will be evaluated, while
considering data availability, relevance, and quality.
2)	Derive hazard thresholds for aquatic and/or terrestrial organisms.
Depending on the robustness of the evaluated data for a particular organism or taxa (e.g., aquatic
invertebrates), environmental hazard values (e.g., ECx. LCx, NOEC, LOEC) may be derived and
used to further understand the hazard characteristics of TPP to aquatic and/or terrestrial species.
Identified environmental hazard thresholds may be used to derive concentrations of concern (COC),
based on endpoints that may affect populations of organisms or taxa analyzed.
3)	Evaluate the weight of the scientific evidence of environmental hazard data.
During risk evaluation, EPA plans to evaluate and integrate the environmental hazard evidence
identified in the literature inventory using the methods described in the systematic review
documentation that EPA plans to publish prior to finalizing the scope document.
4)	Consider the route(s) of exposure, based on reasonably available monitoring and modeling
data and other available approaches to integrate exposure and hazard assessments.
EPA plans to consider aquatic (e.g., water and sediment exposures) and terrestrial pathways in the
TPP conceptual model. These organisms may be exposed to TPP via a number of environmental
pathways (e.g., surface water, sediment, soil, diet).
5)	Conduct an environmental risk characterization of TPP.
EPA plans to conduct a risk characterization of TPP to identify if there are risks to the aquatic
and/or terrestrial environments from the measured and/or predicted concentrations of TPP in
environmental media (i.e., water, sediment, soil). Risk quotients (RQs) may be derived by the
application of hazard and exposure benchmarks to characterize environmental risk (U.S. EPA. 1998;
Bamthouse et at.. 1982).
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6) Consider a Persistent, Bioaccumulative, and Toxic (PBT) Assessment of TPP.
EPA plans to consider the persistence, bioaccumulation, and toxic (PBT) potential of TPP after
reviewing relevant p-chem properties and exposure pathways. EPA plans assess the reasonably
available studies collected from the systematic review process relating to bioaccumulation and
bioconcentration (e.g., BAF, BCF) of TPP. In addition, EPA plans integrate traditional
environmental hazard endpoint values (e.g., LCso, LOEC) and exposure concentrations (e.g., surface
water concentrations, fish tissue concentrations) for TPP with the fate parameters (e.g., BAF, BCF,
BMF, TMF).
2.7.3.2 Human Health Hazards
EPA plans to analyze human health hazards as follows:
1)	Review reasonably available human health hazard data, including data from alternative test
methods (e.g., computational toxicology and bioinformatics; high-throughput screening
methods; data on categories and read-across; in vitro studies; systems biology).
Human health studies will be evaluated using the evaluation strategies laid out in the Applications of
Systematic Review under TSCA document.
Mechanistic data may include analyses of alternative test data such as novel in vitro test methods
and high throughput screening. The association between acute and chronic exposure scenarios to the
agent and each health outcome will also be integrated. Study results will be extracted and presented
in evidence tables or another appropriate format by organ/system.
2)	In evaluating reasonably available data, determine whether particular human receptor groups
may have greater susceptibility to the chemical's hazard(s) than the general population.
EPA plans to evaluate reasonably available human health hazard data to ascertain whether some
human receptor groups may have greater susceptibility than the general population to TPP hazard(s).
Susceptibility of particular human receptor groups to TPP will be determined by evaluating
information on factors that influence susceptibility.
EPA has reviewed some sources containing hazard information associated with potentially exposed
or susceptible populations, and lifestages such as pregnant women and infants. Pregnancy (i.e.,
gestation) and childhood are potential susceptible lifestages for TPP exposure. EPA plans to review
the current state of the literature in order to potentially quantify these differences for risk evaluation
purposes.
3)	Conduct hazard identification (the qualitative process of identifying non-cancer and cancer
endpoints) and dose-response assessment (the quantitative relationship between hazard and
exposure) for identified human health hazard endpoints.
EPA plans to identify and evaluate human health hazards from acute and chronic exposures by
analyzing the human and animal data that meet the systematic review data quality criteria described
in the systematic review documentation that EPA plans to publish prior to finalizing the scope
document. Hazards identified by studies meeting data quality criteria will be grouped by routes of
exposure relevant to humans (oral, dermal, inhalation) and by cancer and noncancer endpoints.
Dose-response assessment will be performed in accordance with EPA guidance (	12a.
201 lb. 1994). Dose-response analyses may be used if the data meet data quality criteria and if
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additional information on the identified hazard endpoints are not available or would not alter the
analysis.
The cancer mode of action (MOA) determines how cancer risks can be quantitatively evaluated. If
cancer hazard is determined to be applicable to TPP, EPA plans evaluate information on
genotoxicity and the mode of action for all cancer endpoints to determine the appropriate approach
for quantitative cancer assessment in accordance with the U.S. EPA Guidelines for Carcinogen Risk
Assessment (	|05).
4)	Derive points of departure (PODs) where appropriate; conduct benchmark dose modeling
depending on the available data. Adjust the PODs as appropriate to conform (e.g., adjust for
duration of exposure) to the specific exposure scenarios evaluated.
EPA plans to evaluate hazard data to determine the type of dose-response modeling that is
applicable. Where modeling is feasible, a set of dose-response models that are consistent with a
variety of potentially underlying biological processes will be applied to empirically model the dose-
response relationships in the range of the observed data consistent with EPA's Benchmark Dose
Technical Guidance Document. Where dose-response modeling is not feasible, NOAELs or
LOAELs will be identified. Non-quantitative data will also be evaluated for contribution to weight
of the scientific evidence or for evaluation of qualitative endpoints that are not appropriate for dose-
response assessment.
EPA plans evaluate whether the available PBPK and empirical kinetic models are adequate for
route-to-route and interspecies extrapolation of the POD, or for extrapolation of the POD to standard
exposure durations (e.g., lifetime continuous exposure). If application of the PBPK model is not
possible, oral PODs may be adjusted by BW3 4 scaling in accordance with	011). and
inhalation PODs may be adjusted by exposure duration and chemical properties in accordance with
U.S. EPA. (1994).
5)	Evaluate the weight of the scientific evidence of human health hazard data.
During risk evaluation, EPA plans to evaluate and integrate the human health hazard evidence
identified in the literature inventory under acute and chronic exposure conditions using the methods
described in the systematic review documentation that EPA plans to publish prior to finalizing the
scope document.
6)	Consider the route(s) of exposure (oral, inhalation, dermal), available route-to-route
extrapolation approaches, available biomonitoring data and available approaches to correlate
internal and external exposures to integrate exposure and hazard assessment.
At this stage of review, EPA believes there will be sufficient reasonably available data to conduct a
dose-response analysis and/or benchmark dose modeling for the oral route of exposure. EPA plans
also evaluate any potential human health hazards following dermal and inhalation exposure to TPP,
which could be important for the worker, consumer, and general population risk analyses.
Reasonably available data will be assessed to determine whether or not a POD can be identified for
the dermal and inhalation routes. This may include using route-to-route extrapolation methods
where appropriate and depending on the nature of available data.
If sufficient toxicity studies are not identified in the literature search to assess risks from dermal and
inhalation exposures, then a route-to-route extrapolation from oral toxicity studies would be needed
to assess systemic risks from dermal or inhalation exposures. Without an adequate PBPK model, the
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approaches described in EPA guidance document Risk Assessment Guidance for Superfund Volume
I: Human Health Evaluation Manual (PartE, Supplemental Guidance for Dermal Risk Assessment)
(	2004) could be applied to extrapolate from oral to dermal exposure. These approaches
may be able to further inform the relative importance of dermal exposures compared with other
routes of exposure. Similar methodology may also be used for assessing inhalation exposures.
2.7.4 Summary of Risk Approaches for Characterization
Risk characterization is an integral component of the risk assessment process for both environmental and
human health risks. EPA plans derive the risk characterization in accordance with EPA's Risk
Characterization Handbook (U.S. EPA. 2000). As defined in EPA's Risk Characterization Policy, "the risk
characterization integrates information from the preceding components of the risk evaluation and
synthesizes an overall conclusion about risk that is complete, informative and useful for decision makers."
Risk characterization is considered to be a conscious and deliberate process to bring all important
considerations about risk, not only the likelihood of the risk but also the strengths and limitations of the
assessment, and a description of how others have assessed the risk into an integrated picture.
The level of information contained in each risk characterization varies according to the type of assessment
for which the characterization is written. Regardless of the level of complexity or information, the risk
characterization for TSCA risk evaluations will be prepared in a manner that is transparent, clear,
consistent, and reasonable (	00) and consistent with the requirements of the Procedures for
Chemical Risk Evaluation Under the Amended Toxic Substances Control Act (82 FR 33726). For instance,
in the risk characterization summary, EPA plans further carry out the requirements under TSCA Section 26;
for example, by identifying and assessing uncertainty and variability in each step of the risk evaluation,
discussing considerations of data quality such as the reliability, relevance and whether the methods utilized
were reasonable and consistent, explaining any assumptions used, and discussing information generated
from independent peer review.
EPA plans also be guided by EPA's Information Quality Guidelines (U.S. 2.002) as it provides guidance for
presenting risk information. Consistent with those guidelines, EPA plans identify in the risk
characterization the following: (1) Each population addressed by an estimate of applicable risk effects; (2)
The expected risk or central estimate of risk for the potentially exposed or susceptible subpopulations
affected; (3) Each appropriate upper-bound or lower-bound estimate of risk; (4) Each significant
uncertainty identified in the process of the assessment of risk effects and the studies that would assist in
resolving the uncertainty; and (5) Peer reviewed studies known to the Agency that support, are directly
relevant to, or fail to support any estimate of risk effects and the methodology used to reconcile
inconsistencies in the scientific information.
2.8	Peer Review
Peer review will be conducted in accordance with EPA's regulatory procedures for chemical risk
evaluations, including using EPA's Peer Review Handbook and other methods consistent with section 26 of
TSCA (See 40 CFR 702.45; U.S. EPA, 2018c). As explained in the preamble to the Risk Evaluation Rule,
the purpose of peer review is for the independent review of the science underlying the risk assessment (See
82 Fed. Reg. 33726, 33744 (July 12, 2017). Peer review will therefore address aspects of the underlying
science as outlined in the charge to the peer review panel such as hazard assessment, assessment of dose-
response, exposure assessment, and risk characterization. The draft risk evaluation for TPP will be peer
reviewed.
47

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chapter53-subchapterl&num=0&saved=%7CZ3JhbnVsZWlkOlVTQylwcmVsaW0tdG10bGUxNSlz
ZWN0aW9uMjYyNQ%3D%3D%7CdHJlZXNvcnQ%3D%7CdHJlZQ%3D%3D%7C0%7Cfalse%7Cpreli
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12-60-50). Hawaii Department of Labor and Industrial Relations. HERO ID: 6305873
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characterization handbook [EPA Report], (EPA/100/B-00/002). Washington, D.C.: U.S. Environmental
Protection Agency, Science Policy Council, https://www.epa.gov/risk/risk-characterization-handbook.
HERO ID: 52149
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quality, objectivity, utility, and integrity of information disseminated by the Environmental Protection
Agency. (EPA/260/R-02/008). Washington, DC: U.S. Environmental Protection Agency, Office of
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(RAGS), volume I: Human health evaluation manual, (part E: Supplemental guidance for dermal risk
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https://assets.publishing.service.gov.Uk/government/uploads/system/uploads/attachment_data/file/290862/s
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[EPA Report], (EPA/600/R-090/052F). Washington, DC. http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?
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modifications: Chemical data reporting. Fed Reg 76: 50815-50879. HERO ID: 3808939
U.S. EPA (U.S. Environmental Protection Agency). (2012a). Benchmark dose technical guidance.
(EPA/100/R-12/001). Washington, DC: U.S. Environmental Protection Agency, Risk Assessment Forum.
https://www.epa.gov/risk/benchmark-dose-technical-guidance. HERO ID: 1239433
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Microsoft Windows, v 4.11 [Computer Program], Washington, DC. https://www.epa.gov/tsca-screening-
tools/epi-suitetm-estimation-program-interface. HERO ID: 2347246
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Washington, DC. https://www.epa.gov/tsca-screening-tools/epi-suitetm-estimation-program-interface.
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tool for exposures and environmental releases. Washington, D.C.
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Releases (Draft). HERO ID: 6305894
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52

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APPENDICES
Appendix A LIST OF GRAY LITERATURE SOURCES
Table Apx A-l List of Gray Literature Sources for TPP
Source/Agency
Source Name
Source Type
Source Category
AT SDR
AT SDR Tox Profile
Updates and
Addendum s
Other US Agency
Resources
Assessment or Related
Document
AT SDR
AT SDR Toxicological
Profiles (original
publication)
Other US Agency
Resources
Assessment or Related
Document
Australian Government
Department of Health
NICNAS Assessments
(human health, eco, Tier
I, II or III)
International Resources
Assessment or Related
Document
CAL EPA
Technical Support
Documents for
regulations: Drinking
Water Public Health
Goals
Other US Agency
Resources
Assessment or Related
Document
CAL EPA
Technical Support
Documents for
regulations: Reference
Exposure Levels (RELs)
Other US Agency
Resources
Assessment or Related
Document
CAL EPA
Technical Support
Documents for
regulations: Cancer
Potency Information
Other US Agency
Resources
Assessment or Related
Document
CAL EPA
Technical Support
Documents for
regulations: Proposition
65, Cancer
Other US Agency
Resources
Assessment or Related
Document
CAL EPA
Technical Support
Documents for
regulations: Proposition
65, Cancer, Notice
Other US Agency
Resources
Assessment or Related
Document
CAL EPA
Technical Support
Documents for
regulations: Proposition
65, Reproductive
Toxicity
Other US Agency
Resources
Assessment or Related
Document
55

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Source/Agency
Source Nsimc
Source Type
Source Csilcgorv
C-YL EPA
Technical Support
Documents for
regulations: Soil
Screening
Other LS Agency
Resources
Assessment or Related
Document
Canada Gov
Government of Canada -
Factsheet: Prohibition of
Certain Toxic
Substances Regulations
International Resources
Factsheet
Canada Gov
Government of Canada -
Substances Search
International Resources
General Search
CARB
Report to the California
Legislature Indoor Air
Pollution in California.
Other US Agency
Resources
Technical Report
CDC
CDC Biomonitoring
Tables
Other US Agency
Resources
Data
CDC
NHANES data
Other US Agency
Resources
Data
CPSC
Chronic Hazard
Advisory Panel Reports
Other US Agency
Resources
Assessment or Related
Document
CPSC
Technical Reports:
Exposure/Risk
Assessment
Other US Agency
Resources
Assessment or Related
Document
CPSC
Technical Reports:
Toxicity Review
Other US Agency
Resources
Assessment or Related
Document
EC
European Commission
International Resources
Assessment or Related
Document
EC
IPCHEM: Information
Platform for Chemical
Monitoring Data
International Resources
Database
ECHA
Annex XIV Restriction
Report
International Resources
Assessment or Related
Document
ECHA
Annex XV Restriction
Report
International Resources
Assessment or Related
Document
ECHA
Annex XVII Restriction
Reports
International Resources
Assessment or Related
Document
ECHA
Annex XVII To
REACH - Conditions of
Use
International Resources
Assessment or Related
Document
56

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Source/Agency
Source Nsimc
Source Type
Source Csilcgorv
iiCllA
Annex.W' Transilional
Report
Inlernalional Resources
Assessment or Related
Document
ECHA
ECHA Documents
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Env Canada
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Alternatives
Assessments


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(NEI) - Additional
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Appendix B PHYSICAL AND CHEMICAL PROPERTIES
This appendix provides p-chem information and data found in preliminary data gathering for triphenyl
phosphate. Table Apx B-l summarizes the p-chem property values preliminarily selected for use in the risk
evaluation from among the range of reported values collected as of March 2020. This table differs from that
presented in the Proposed Designation of Triyhenyl Phosphate fCA.SRN 115- is a High-Priority
Substance for Risk Evaluation (U.S. EPA, 2019a) and may be updated as EPA collects additional
information through systematic review methods. All p-chem property values that were extracted and
evaluated as of March 2020 are presented in the supplemental filq Data Extraction and Data Evaluation
Tables for Physical Chemical Property Studies (EPA-HQ-OPPT-2018-0451).
Table Apx B-l Physical and Chemical Properties of TPP
Properly or Kiulpoinl
\ illllC*11
Reference
Dala Quality
Ualing
Molecular formula
C18H15O4P1
NA
NA
Molecular weight
326.29 g/mol
NA
NA
Physical state
Solid crystals or prisms
Rumble, 2018
High
Physical properties
Colorless, crystalline
powder; odorless
NLM, 2018
High
Melting point
49.39°C
Rumble, 2018
High
Boiling point
413°G
U.S. EPA, 2019a
High
Density
1.2055 g/cm3 at 50°C
Rumble, 2018
High
Vapor pressure
6.28><10"6 mm Hg
U.S. EPA, 2019a
High
Vapor density
1.19 (air = 1)
NLM, 2018
High
Water solubility
1.9 mg/L at 25°C
NLM, 2018
High
Log Octanol/water partition
coefficient (Log Kow)
4.59
NLM, 2018
High
Henry's Law constant
1.42xl0"6 atmm3/mole
(Calculated from
VP/WS)
U.S. EPA, 2012c
High
Flash point
220°C
RSC, 2019
High
64

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Propcrlv or Kiulpoinl
\ illllC*11
UofomuT
Dsilsi Qimlilv
Killing
Auto flammability
Not available


Viscosity
Not available


Refractive index
1.550
NLM, 2018
High
Dielectric constant
Not available


a Measured unless otherwise noted.
NA = Not applicable
65

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Appendix C ENVIRONMENTAL FATE AND TRANSPORT
PROPERTIES
Table Apx C-l Environmental Fate and Transport Properties of TPP
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 C0irn
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
x 105 OH radicals/cm3; estimated)13
HSDB C0irn citing EPI Suite
(2012b)
Hydrolysis
11/2 = 19 days (pH 7 at 25 °C) 11/2 = 3 days
(pH 9 at 25 °C)
HSDB (J 01 rn citing Maver
(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) citing Howard
(1979)
Biodegradation (Aerobic)
ti/2 = 2-4 days in river die-away tests
(Mississippi River)
HSDB (2019) citing Saeger
(1979)

48% mineralization/32 days; ti/2 = 37 days
(loamy sand)
HSDB C01'"1) citing
Anders(

100%/7-8 days (freshwater)
HSDB C^r ^ citing Howard
(I979)

83-94%/4 weeks based on BOD (Japanese
MITI test)
HSDB CO n citing NITE
(201^)
Biodegradation
(Anaerobic)
ti/2 = 32 days (loamy sand)
HSDB ( siting
Anderson (1993)
Wastewater Treatment
61% total removal (0.56% by
biodegradation, 60% by sludge and 0.01%
by volatilization to air; estimated)13
EPI Suite (2012b)
Bioconcentration Factor
180-280 (Salmo gairdneri) for Pydraul 50E,
a hydraulic fluid containing 35% TPP
HSDB ( siting
Lombards (79)

132-364 (Oncorhynchus my kiss)
HSDB CO Inciting Maver
(1981)

573 (Oncorhynchus mykiss); 561
(Pimephales promelas)
HSDB ( siting Muir
(1983)
Bioaccumulation Factor
73 (estimated)13
EPI Suite (2012b)
Soil Organic
Carbon:Water Partition
Coefficient (Log Koc)
3.40, 3.55, and 3.44 (silty clay, loamy sand,
and silt loam, respectively)
HSDB (2019) citing
Anderson (1993)
aMeasured unless otherwise noted
bEPI SuiteTM physical 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
66

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Appendix D REGULATORY HISTORY
The chemical substance, TPP, is subject to federal and state laws and regulations in the United States
(TableApx D-l Federal Laws and Regulations and TableApx D-2 State Laws and Regulations).
Regulatory actions by other governments, tribes and international agreements applicable to TPP are listed in
TableApx D-3.
D.l Federal Laws and Regulations
Table Apx D-l Federal Laws and Regulations
Slaliilcs/Ucgulalion
s
Description of Aiilhorilv/Uegulalion
Description of Regulation
EPA Regulations
Toxic Substances
Control Act (TSCA) -
Section 6(b)
EPA is directed to identify high-priority
chemical substances for risk evaluation;
and conduct risk evaluations on at least
20 high priority substances no later than
three and one-half years after the date of
enactment of the Frank R. Lautenberg
Chemical Safety for the 21st Century
Act.
TPP is one of the 20 chemicals
EPA designated as a High-
Priority Substance for risk
evaluation under TSCA (84 FR
71924, December 30, 2019).
Designation of TPP as a high-
priority substance constitutes the
initiation of the risk evaluation on
the chemical.
Toxic Substances
Control Act (TSCA) -
Section 8(a)
The TSCA section 8(a) CDR Rule
requires manufacturers (including
importers) to give EPA basic exposure-
related information on the types,
quantities and uses of chemical
substances produced domestically and
imported into the United States.
TPP manufacturing (including
importing), processing and use
information is reported under the
CDR rule (76 FR 50816. August
16, 2011).
Toxic Substances
Control Act (TSCA) -
Section 8(b)
EPA must compile, keep current and
publish a list (the TSCA Inventory) of
each chemical substance manufactured
(including imported) or processed in the
United States.
TPP was on the initial TSCA
Inventory and therefore was not
subject to EPA's new chemicals
review process under TSCA
section 5 C60 FR 16309. March
29, 1995).
Toxic Substances
Control Act (TSCA) -
Section 8(e)
Manufacturers (including importers),
processors, and distributors must
immediately notify EPA if they obtain
information that supports the conclusion
that a chemical substance or mixture
presents a substantial risk of injury to
health or the environment.
EPA received one Substantial
Risk Report for TPP (1992).
67

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s
Description of Aiilhorhy/Ucgiiliilion
Description of Ucgiihilion
Toxic Substances
Control Act (TSCA) -
Section 4
Provides EPA with authority to issue
rules and orders requiring manufacturers
(including importers) and processors to
test chemical substances and mixtures.
Test rule for TPP.
EPA received 67 studies
including ecotox, environmental
fate, human health, and p-chem
properties. (U.S. EPA,
ChemView. Accessed January
24, 2020)
Other Federal Regulations
Occupational Safety
and Health Act
(OSHA)
Requires employers to provide their
workers with a place of employment free
from recognized hazards to safety and
health, such as exposure to toxic
chemicals, excessive noise levels,
mechanical dangers, heat or cold stress
or unsanitary conditions (29 U.S.C
section 651 et seq.). Under the Act,
OSHA can issue occupational safety and
health standards including such
provisions as Permissible Exposure
Limits (PELs), exposure monitoring,
engineering and administrative control
measures, and respiratory protection.
In 1970, OSHA issued
occupational safety and health
standards for TPP that included a
PEL of TWA of
3 mg/m3- and respirator
recommendations. (29 CFR
).
68

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D.2 State Laws and Regulations
Table Apx D-2 State Laws and Regulations
Stale Actions
Description of Action
State Prohibitions
California adopted a prohibition on the selling and distribution in commerce of
new, not previously owned juvenile products, mattresses, or upholstered
furniture that contains, or a constituent component of which contains, covered
flame retardant chemicals at levels above 1,000 parts per million (A.B. 2998,
Legislative Council, Sess. 2017-2018, C.A. 2018)
State PELs
California (PEL of 3 mg/m3)(Cal Code Regs. Title 8, § 5155)
Hawaii (PEL- TWA of 3 mg/m3)and STEL (6 mg/m3) (Hawaii Administrative
Rules section 12-60-50).
Minnesota (PEL of 3mg/m3) (MNOSHA Permissible Exposure Limits- Limits
for Air Contaminants)
State Right-to-
Know Acts
Massachusetts (105 Code Mass. Regs. § 670.000 Appendix A), New Jersey
(N.J.A C. 7:1C) and Pennsylvania (P.L. 734, No. 159 and 34 Pa. Code § 323).
Chemicals of
High Concern to
Children
One state has adopted a reporting law for chemicals in children's products
containing TPP: Washington State (Wash. Admin. Code 173-334-130).
Other
TPP is listed as a Candidate Chemical under California's Safer Consumer
Products Program established under Health and Safety Code § 25252 and
25253 (California, Candidate Chemicals List. Accessed April 18, 2019).
California lists TPP as a designated priority chemical for biomonitoring under
criteria established by California SB 1379 (Biomonitoring California, Priority
Chemicals, February 2019).
69

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D.3 International Laws and Regulations
Table Apx D-3 Regulatory Actions by other Governments, Tribes, and International Agreements
Country Oiuanizalion
Ret|LiiI'cnienls unci Restrictions
Canada
TPP is on the Domestic Substances List (Government of Canada.
Managing substances in the environment. Substances search. Database
accessed April 8, 2019)
European Union
TPP is registered for use in the EU. (European Chemicals Agency (ECHA)
database accessed April 9, 2019.)
TPP was evaluated under the 2017 Community Rolling Action Plan
(CoRAP) under regulation (European Commission [EC]) Nol907/2006 -
REACH (Registration, Evaluation, Authorisation and Restriction of
Chemicals). Additional information was requested and is due August
2020. (ECHA database accessed April 17, 2019).
Australia
TPP was assessed under Human Health Tier II of the Inventory Multi-
Tiered Assessment and Prioritisation (IMAP). Uses reported include: in
plastic products, in construction materials, in cellulose acetate films, in
lubricants and transmission oils, as an industrial sealant, as a plasticiser, as
a flame retardant, in nail polishes and enamels; in manicuring
preparations, in indoor and outdoor adhesives and sealants, in coatings,
lacquers, and varnishes; in paints and inks, in roofing paper, in
polyurethane foam, in plastics and rubber, in electronic products, in
textiles, and in hydraulic fluids and lubricants. The chemical is reported to
be present in foam-based furniture and baby products (Stapleton et al.,
2009; Staoleton et al.. 201 1) fNICNAS. 2016. Human Health Tier II
assessment for Pb.osDb.oric acid, triphenyl ester) (Accessed April 11,
2019/
Japan
TPP is regulated in Japan under the following legislation:
•	Act on the Evaluation of Chemical Substances and Regulation of
Their Manufacture, etc. (Chemical Substances Control Law;
•	CSCL) (National Institute of Technology and Evaluation
•	Act of Confirmation, etc. of Release Amounts of Specific
Chemical Substances in the Environment and Promotion of
Improvements to the Management Thereof;
•	Industrial Safety and Health Act (ISHA)
National Institute of Technology and Evaluation [NITE] Chemical Risk
Basel Convention
Organic phosphorus compounds are listed as a category of waste under the
Basel Convention. Although the United States is not currently a party to
the Basel Convention, this treaty still affects U.S. importers and exporters.
70

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Country Organization
Ret|Liircnieiils and Restrictions

2/mtgl/Basel convention Aidele 1 am! \11nexes.odf (Accessed April
19, 2019)
OECD Control of
Transboundary
Movements of Wastes
Destined for Recovery
Operations
Organic phosphorus compounds are listed as a category of constituents of
waste subject to The Amber Control Procedure under Council Decision C
(2001) 107/Final. httDs://legalinstrurnents.oecd.org/en/instruments/OECD-
LEGAL-0266
Australia, Austria,
Belgium, Canada,
Denmark, France,
Finland, Ireland,
New Zealand,
Romania, Singapore,
South Korea, Spain,
Switzerland, United
Kingdom
Occupational exposure limits for TPP ((GESTIS International limit values
for chemical agents (Occupational exposure limits, OELs) database.
Accessed January 13, 2019)).
71

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Appendix E PROCESS, RELEASE AND OCCUPATIONAL
EXPOSURE INFORMATION
This appendix provides information and data found in preliminary data gathering for TPP.
E.l Process Information
Process-related information potentially relevant to the risk evaluation may include process diagrams,
descriptions and equipment. Such information may inform potential release sources and worker exposure
activities.
E.l.l Manufacturing (Including Import)
E.l.1.1 Domestic Manufacture
TPP is prepared by reacting phosphorus pentoxide and phenol and by reaction of triethyl phosphate and
chloramine-T. On a larger scale phosphorus oxychloride and phenol are reacted in an esterification tank
with heating. The hydrogen chloride formed is trapped and condensed, while the crude triphenyl phosphate
runs into a large tank where it is purified (Snyder, 1990).
E.l.1.2 Import
EPA plans that imported chemicals are often stored in warehouses prior to distribution for further
processing and use. In some cases, the chemicals may be repackaged into differently sized containers,
depending on customer demand, and QC samples may be taken for analyses (U.S. EPA, 2018d).
E.1.2 Processing and Distribution
E.l.2.1 Incorporation into a Formulation, Mixture or Reaction Product
Incorporation into a formulation, mixture, or reaction product refers to the process of mixing or blending of
several raw materials to obtain a single product or preparation. TPP may undergo several processing steps
and the processing is dependent on its downstream incorporation into articles, which is discussed in the next
subsection (U.S. EPA, 2018e).
E.l.2.2 Incorporation into an Article
Incorporation into an article typically refers to a process in which a chemical becomes an integral
component of an article (as defined at 40 CFR 704.3) for distribution in commerce. Exact process
operations involved in the incorporation of TPP-containing formulations or reaction products are dependent
on the article (U.S. EPA, 2018e). For example, TPP may be incorporated into solvents for chemical
manufacturing, plastics products as a plasticizer, or photographic supplies, film, and photo chemicals (U.S.
EPA, 2019b). EPA plans to further investigate the use of TPP being incorporated into articles during risk
evaluation.
E. 1.2.3 Recycling
EPA did not identify TPP-specific information for recycling at this time; however, this chemical has been
identified in articles that are commonly recycled such as insulation, plastics and electronic materials. The
processes for recycling these materials may include grinding, washing, and rinsing the recycled material
and incorporating it into new formulations. Electronics waste recycling may involve recovery of plastics
72

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through similar recycling processes, which are described more generally in Kirk Othmer (Kirk-Othmer,
2006). EPA has not identified specific worker activities related to the recycling TPP-containing products.
Based on EPA's knowledge, worker activities are anticipated to be exposed to TPP from reclamation
activities such as sorting, materials grinding steps and loading recovered materials into transport containers.
E.1.3 Uses
Paints and Coatings
Based on 2019 CDR data, TPP may be used in various paints and coatings for industrial, commercial and
consumer applications. Typical process descriptions and worker activities for industrial and commercial
uses in coating applications include manual application with roller or brush, air spray systems, airless and
air-assisted airless spray systems, electrostatic spray systems, electrodeposition/electrocoating and
autodeposition, dip coating, curtain coating systems, roll coating systems and supercritical carbon dioxide
systems (U.S. EPA, 2018f; OECD, 2009).
Plastic and Rubber Products
The plastics manufacturing industry can be divided into three distinct phases: manufacturing of polymers
and chemical additives, compounding of polymer resins and chemical additives, and converting of the
compounded plastic into finished products. Compounders receive the polymer resins from these
manufacturers and produce master batches of plastics with specific properties by blending the polymer with
plastics additives (e.g., fillers, reinforcements). Converters receive the master batch of plastics from
compounders and convert it into the finished plastic product. Compounding and converting can take place
at the same facility (i.e., "in-house" manufacturing) or at separate facilities (U.S. EPA, 2014b).
Foam Seating and Bedding Products
2019 CDR Data indicate that TPP is used in foam seating and bedding products (U.S. EPA, 2019b).
However, specific TPP-containing foam seating and bedding products are unknown. EPA plans further
investigate the specific foam seating and bedding product use activities of TPP during the risk evaluation.
Furniture and Furnishings
2019 CDR Data indicate that TPP is used in furniture and furnishings (U.S. EPA, 2019b). However,
specific uses of TPP in furniture and furnishings are unknown. EPA plans further investigate the use of TPP
in furniture and furnishings during this risk evaluation.
Lubricants and Greases
2019 CDR Data indicate that TPP is used in lubricants and greases (U.S. EPA, 2019b). However, specific
types of lubricants and greases and their uses are unknown. EPA plans further investigate the use of TPP in
lubricants and greases during this risk evaluation.
Photographic Supplies, Film, and Photo Chemicals
2019 CDR Data indicate that TPP is used in photographic supplies, film, and photo paper (U.S. EPA,
2019b). EPA plans further investigate the use of TPP in photographic supplies, film, and photo paper during
this risk evaluation.
73

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Electrical and Electronic Products
2019 CDRData indicate that TPP is used in electrical and electronic products (U.S. EPA, 2019b). EPA
plans further investigate the use of TPP in electrical and electronic products during this risk evaluation.

I
scs with Minimal Siihslanlialion
I se
Expected
Users
Description of Use or Process and References


Used as a building/construction material in rigid urethane foam for
insulation of buildings and potentially in other materials. (Kirk
Othmer Encyclopedia of Chemical Technology, 2001)


NLM2018, SPIN 2019
Construction
Industrial
NLM's Hazardous Substances Databank (HSDB) reports that TPP is
used in impregnating roofing paper, citing the 2013 Merck Index.
SPIN identifies use of TPP in specialized construction activities, and
as construction materials in Nordic countries, as recently as 2017.
This use was categorized as Tier 2 because only outdated and
international sources could be identified.
Laboratory
Chemicals

Sigma Aldrich


Microcell 2006
Ink
Consumer
TPP is found in Microcell's Accustamp ink. However, the SDS is
from 2006 and it may be outdated. No other ink containing TPP
could be identified.
Repair and
installation of
machinery and
Industrial
SPIN 2019
SPIN identifies use of TPP in repair and installation of machinery
and equipment in Nordic countries, as recently as 2017.
equipment

This use was categorized as Tier 2 because only an international
source could be identified.


SPIN 2019
Reprographic agents
Industrial
SPIN identifies use of TPP in reprographic agents in Nordic
countries, as recently as 2017.
This use was categorized as Tier 2 because only an international
source could be identified.
74

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E.1.4 Disposal
Disposal of a chemical should take into consideration the chemical's potential impact on air quality,
migration to groundwater, effect on biological species, and disposal regulations (if any) (ATSDR, 2017).
Currently, TPP is not regulated as a hazardous waste. However, TPP may be disposed of as a hazardous
waste if it is present in or co-mingled with solvent mixtures that are RCRA regulated substances.
Demolished building materials are classified as Construction and Demolition (C&D) waste, which may be
disposed in municipal solid waste landfills (MSWLFs) or C&D landfills (U.S. EPA, 2014a).
75

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E.2 Preliminary Occupational Exposure Data
EPA presents below examples of occupational exposure-related information from the preliminary data gathering. EPA plans consider this
information and data in combination of other data and methods for use in the risk evaluation. Note there are no OSHA Chemical Exposure
and Health Data (CEHD) or NIOSH Health Hazard Evaluations for TPP within the last ten years.
Table Apx E-2 Potentially Relevant Data Sources for Exposure Monitoring and Area Monitoring Data from NIOSH Health Hazard
Evaluations for TPPa
Year of Publication
Ueporl Number
I'acilily Description
1985
HETA-83-156-1622
Plastics manufacturing facility
a Table includes HHEs identified to date
76

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Appendix F SUPPORTING INFORMATION - CONCEPTUAL MODEL FOR INDUSTRIAL
AND COMMERCIAL ACTIVITIES AND USES
Table Apx
-1 Worker and Occupational Non-User Exposure Conceptual Model Supporting Table
l.ili- ( \ik-
Slum-
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-------
l.ili- (\ik-
(;ik-»
-------
l.ili- (\ik-
Slum-
(;ik-»
-------
l.ili- (\ik-
Slum-
(;ik-»nr\
Sul)i;ik-»iir\
Ri'k'.isi- / I!\|)iisiiiv
Sii-nuriii
l'A|)IIMIIV
P;i 1 h\\ ;i\
l!\|)iisuiv
Koiili-
Ri'i'i'pliir /
Piipukiliiin
Pkilis In
l".\ ;illi;ik-
K;iliiill;ik-




Vapor, Mist
Inhalation
Workers.
ONIJ
No
Due to the volatility of TPP (VP
=2.00* 10A -6 Toit) at room
temperature, inhalation exposure to TPP
in the vapor phase is not expected. Mist
generation is not expected during
unloading or paint and coaling
manufacturing processes




Dust
Inhalation
Workers,
ONU
Yes
Dust generation is expected during
unloading operations as TPP can be
used/transported in various solid forms
(according to CDR data)




Liquid. Solid
Contact
Dermal
ONIJ
No
Dermal exposure by ONU is not
expected for this condition of use as
they are not expected to directly handle
the chemical.




Liquid
Contact
Dermal
Workers
Yes
The potential for exposures to workers
exists during unloading and transfer
operations as TPP can be
used/transported in liquid form
(suspended in solution, 30-60%)
(according to CDR data).

Incorporated
into
Formulation,
Mixture, or
Reaction
Product


Solid Contact
Dermal
Workers
Yes
The potential for exposures to workers
exists during unloading and transfer
operations as TPP can be
used/transported in various solid forms
(according to CDR data)
Processing
Solvent used in
Photographic
film, paper, and
chemical
manufacturing
Unloading/transfer to
process equipment/
product manufacturing
Vapor. Mist
Inhalation
Workers.
ONU
No
Due to the volatility of TPP (VP
=2.00* 10A -6 Toit) at room
temperature, inhalation exposure to TPP
in the vapor phase is not expected. Mist
generation is not expected during
unloading operations.




Dust
Inhalation
Workers,
ONU
Yes
Dust generation is expected during
unloading and transfer operations as
TPP can be used/transported in various
solid forms (according to CDR data)




I .iquid. Solid
Contact
I )ermal
ONIJ
No
Dermal exposure by ONU is not
expected for this condition of use as
they are not expected to directly handle
the chemical.
80

-------
l.ili- (\ik-
Slum-
(;ik-»nr\
Sul)i;ik-»iir\
Ri'k'.isi- / I!\|)iisiiiv
Sii-nuriii
l'A|)IIMIIV
P;i 1 h\\ ;i\
l!\|)iisuiv
Koiili-
Ki-ii-pliir /
Piipukiliiin
Pkilis In
l".\ ;illi;ik-
K;iliiill;ik-




Liquid
Contact
Dermal
Workers
Yes
The potential for exposures to workers
exists during unloading operations, as
TPP can be used/transported in liquid
form (suspended in solution, 30-60%)
(according to CDR data).


Solvent in
photographic
film paper,
plate, and
chemical
manufacturing

Solid Contact
Dermal
Workers
Yes
The potential for exposures to workers
exists during unloading operations, as
TPP can be used/transported in various
solid forms (according to CDR data)
Processing
Incorporated
into article
Unloading/
product manufacturing
Vapor. Mist
Inhalation
Workers,
ONI J
No
Due to the volatility of TPP (VP
=2.00* 10A -6 Ton') at room
temperature, inhalation exposure to TPP
in the vapor phase is not expected. Mist
generation is not expected during
unloading operations.




Dust
Inhalation
Workers,
ONU
Yes
Dust generation is expected during
unloading operations) as TPP can be
used/transported in various solid forms
(according to CDR data)




Liquid, Solid
Contact
I )ermal
ONLJ
No
Dermal exposure by ONU is not
expected lor this condition of use as
they are not expected to directly handle
the chemical.
81

-------
l.ili- (\ik-
Slum-
(;ik-»
-------
l.ili- (\ik-
Slum-
(;ik-»nr\
Sul)i;ik-»iir\
Ri'k'.isi- / I!\|)iisiiiv
Sii-nuriii
l'A|)IIMIIV
P;ilhu;i>
l!\|)iisuiv
Koiili-
Ri'i'i'pliir /
Piipukiliiin
Plans In
l".\ ullluk-
Kulimiak-




Liquid/
Solid Contact
I )ermal
ONIJ
No
I )ermal exposure by ONU is not
expected lor this condition of use as
they are no I expected lo directly handle
the chemical.
Industrial,
Commercial,
Use
Foam Seating
and Bedding
Products
e.g. foam and
upholstery,
plasticizer in
automobile
upholstery
Foam handling and
product assembly
Liquid
Contact
] )ermal
Workers
No
TPP and TPP-conlaining article
components are not expected to be
handled or used in the liquid lorni.
Solid Contact
Dermal
Workers
Yes
The potential for exposures to workers
exists during this use (Foam Seating and
Bedding Products), during the handling
of foam and manufacture of products
Vapor, Mist
Inhalation
Workers.
ONIJ
No
Due lo the volatility of TPP (VP
=2.00* 10A -6 Torr) at room
temperature, inhalation exposure to TPP
in the vapor phase is nol expected.
Dust
Inhalation
Workers,
ONU
Yes
Dust generation is expected during this
use (Foam Seating and Bedding
Products), as TPP-containing articles
may need to be cut during finishing
operations.
Liquid/
Solid Contact
Dermal
ONIJ
No
Dermal exposure by ONU is nol
expected for lliis condition of use as
lliey are nol expected lo direclly handle
the chemical.
Industrial,
Commercial,
Use
Plastic and
Rubber
Products, Not
Covered
Elsewhere
Plastic and
Rubber Products
Use of Plastic and
Rubber products
Liquid
Contact
I )ermal
Workers
No.
TPP and TPP-conlaining article
components are not expected to be
handled or used in the liquid form.
Solid Contact
Dermal
Workers
Yes
The potential for exposures to workers
exists during this use (Plastic and
Rubber Products, Not Covered
Elsewhere).
Vapor, Mist
Inhalation
Workers.
ONU
No
Due to the volatility of TPP (VP
=2.00* 10A -6 Torr) at room
temperature, inhalation exposure lo TPP
in the vapor phase is nol expected. Misl
generation is nol expected during this
use (Plastic and Rubber Products. Nol
Covered Elsewhere).
Dust
Inhalation
Workers,
ONU
Yes
Dust generation is expected during this
use (Plastic and Rubber Products, Not
Covered Elsewhere).
83

-------
l.ili- (\ik-
Slum-
(;ik-»nr\
Sul)i;ik-»iir\
Ri'k'.isi- / I!\|)iisiiiv
Sii-nuriii
l'A|)IIMIIV
P;i 1 h\\ ;i\
l!\|)iisuiv
Koiili-
Ri'i'i'pliir /
Piipukiliiin
Pkilis In
l".\ ;illi;ik-
K;iliiill;ik-




Liquid/
Solid Contact
I )ermal
ONIJ
No
1 )ermal exposure by ONU is not
expected lor this condition of use as
they are no I expected to directly handle
the chemical.




Liquid
Contact



There is potential exposure to liquids to
workers during the manufacture and use




Dermal
Workers
Yes
of Photographic Supplies, Film, and
Photo Chemicals.




Solid Contact
Dermal
Workers
Yes
The potential for exposures to workers
exists during this manufacture and
handling of Photographic Supplies,
Film, and Photo Chemicals.








Due to the volatility of TPP (VP
Industrial,
Commercial,
Use
Photographic
Supplies, Film,
and Photo
Chemicals
Photographic
Supplies, Film,
and Photo
Chemicals
Unloading/Spray
Coating Applications
Vapor
Inhalation
Workers,
o\r
No
=2.00* 10A -6 l'on') at room
temperature, inhalation exposure to TPP
in the vapor phase is not expected.
Mist
Inhalation
Workers,
ONU
Yes
The potential for exposure to TPP
suspended in mist exists during film and
photographic paper coating
applications, when spray coating
methods are utilized (Photographic
Supplies, Film, and Photo Chemicals)




Dust
Inhalation
Workers,
ONU
No
Dusl generation is not expected during
this use (Photographic Supplies, l-'ilm.
and Photo Chemicals)




Liquid/
Solid Contact
Dermal
ONU
No
Dermal exposure by ONU is not
expected lor this condition of use as
they are not expected to directly handle
the chemical.
84

-------
l.ili- (\ik-
Slum-
(;ik-»nr\
Sul)i;ik-»iir\
Ri'k'.isi- / I!\|)iisiiiv
Sii-nuriii
l'A|)IIMIIV
P;i 1 h\\ ;i\
l!\|)iisuiv
Koiili-
Ri'i'i'pliir /
Piipukiliiin
Pkilis In
l".\ ;illi;ik-
K;iliiill;ik-
Industrial,
Commercial,
Use
Paints and
Coatings
Paints and
Coatings
Unloading/
Spray Coating
Applications
Liquid
Contact
Dermal
Workers
Yes
The potential for exposures to workers
exists during unloading and application
of paints and coatings containing TPP.
Solid Contact
Dermal
Workers
No
Paints and coalings containing TPP are
not expected to be handled or used as
solids.
Vapor
Inhalation
Workers.
ON'I'
No
Due to the volatility of TPP (VP
=2.00* 10A -6 Torr) at room
temperature, inhalation exposure to TPP
in the vapor phase is not expected.
Mist
Inhalation
Workers,
ONU
Yes
The potential for exposure to TPP
suspended in mist exists during spray
coating applications (Paints and
Coatings)
Dust
Inhalation
Workers,
ONU
No
Handling and use of paints and coatings
is not expected to generate dust.
Liquid/Solid
Contact
Dermal
ONU
No
Dermal exposure by ()NI J is not
expected for this condition of use as
they are not expected to directly handle
the chemical.
Industrial,
Commercial,
Use
Lubricants and
Greases
Lubricants and
Greases
Use of lubricants and
greases
Liquid
Contact
Dermal
Workers
Yes
The potential for exposures to workers
exists during the use of Lubricants and
Greases
Solid Contact
I )ermal
Workers
No
Lubricants and greases containing TPP
are not expected to be handled or used
as solids.
Vapor, Mist
Inhalation
Workers,
ONU
Yes
Due to the volatility of TPP (VP
=2.00*10A -6 Torr) at room
temperature, inhalation exposure to TPP
in the vapor phase is not expected. Mist
generation is possible during the use of
some Lubricants and Greases.
Dust
Inhalation
Workers.
ONU
No
1 Iundling and use of lubricants and
greases is not expected to generate dust.
Liquid/Solid
Contact
I )ermal
ONU
No
Dermal exposure by ONU is not
expected lor this condition of use as
they are not expected to directly handle
the chemical.
85

-------
l.ili- (\ik-
Slum-
(;ik-»
-------
l.ili- (\ik-
Slum-
(;ik-»nr\
Sul)i;ik-»iir\
Ri'k'.isi- / I!\|)iisiiiv
Sii-nuriii
l'A|)IIMIIV
P;i 1 h\\ ;i\
l!\|)iisuiv
Koiili-
Ri'i'i'pliir /
Piipukiliiin
Pkilis In
l'.\ ;illi;ik'
K;iliiill;ik'




Solid Contact
Dermal
Workers
Yes
Dermal exposure is expected for this
condition of use.




Dust
Inhalation
Workers
Yes
TPP is solid at room temperature, EPA
plans to evaluate the inhalation
pathway.
Disposal
Waste Handling,
Treatment and
Disposal
Disposal of TPP
containing
wastes
Worker handling of
wastes
Liquid
Contact
Dermal
ONU
No
Dermal exposure by ONU is not
expected for this condition of use as
they are not expected to directly handle
the chemical.




Dust
Inhalation
ONU
Yes
TPP is solid at room temperature. 1-1 PA
plans to evaluate the inhalation
pulhwuy.
87

-------
Appendix G SUPPORTING INFORMATION- CONCEPTUAL MODEL FOR CONSUMER
ACTIVITIES AND USES
Table Apx G-l Consumer Exposure Conceptual Model Supporting Table
l.ile ( >cle
S(;i»e
("sik'Sion
Siibciik'jion
Uck'iisc from
sou rce
l.\|)(»suro
P;il liw
l.xposiire
Koulo
Km'plor
Pliins In
i:\iiliiiilc
K;ilinn;ilc
Consumer Use
Lubricants and
greases
Hydraulic fluids
Direct contact
through use of
products/articles
containing TPP
Air/Particulate
Inhalation
Consumers/
Bystanders
Yes
Inhalation via air and/or particulate
exposure may occur during
product/article use. EPA plans to
analyze inhalation exposure.
Article/Product
Contact
Dermal
Consumers
Yes
Dermal exposure may occur via use
of articles containing TPP. EPA
plans to analyze dermal exposure.
Air/Particulate
Inhalation
Consumers
and
Bystanders
Yes
Inhalation of air and/or particles
from articles/products containing
TPP may occur for this condition of
use. EPA plans to analyze inhalation
exposure.
Consumer Use
Electrical and
electronic
records
Electrical and
electronic
records
Direct contact
through use of
products/articles
containing TPP
Air/Particulate
Inhalation
Consumers/
Bystanders
Yes
Inhalation via air and/or particulate
exposure may occur during
product/article use. EPA plans to
analyze inhalation exposure.
Article/Product
Contact
Dermal
Consumers
Yes
Dermal exposure may occur via use
of articles containing TPP. EPA
plans to analyze dermal exposure.
Air/Particulate
Inhalation
Consumers
and
Bystanders
Yes
Inhalation of air and/or particles
from articles/products containing
TPP may occur for this condition of
use. EPA plans to analyze inhalation
exposure.
Dust
Ingestion
Consumers/
Bystanders
Yes
Ingestion of TPP sorbed onto dust
may occur for this condition of use.
EPA plans to analyze dust exposure
via ingestion.
88

-------
l.ile ( >cle
S(;i»o
("sik'Sion
Siibciik'jion
Uck'iisc from
sou rce
l.\|)(»suro
P;il liw
l.xposiire
Koulo
Km'plor
Pliins In
i:\iiliiiilc
K;ilinn;ilc




Air/Particulate
Inhalation
Consumers/
Bystanders
Yes
Inhalation via air and/or particulate
exposure may occur during
product/article use. EPA plans to
analyze inhalation exposure.


Thermoplastics
Direct contact
through use of
products/articles
containing TPP
Dust
Ingestion
Consumers/
Bystanders
Yes
Ingestion of TPP sorbed onto dust
may occur for this condition of use.
EPA plans to analyze dust exposure
via ingestion.


Article/Product
Contact
Dermal
Consumers
Yes
Dermal exposure may occur via use
of articles containing TPP. EPA
plans to analyze dermal exposure.
Consumer Use
Plastics and
rubber
products, not
covered


Article/Product
Mouthing
Ingestion
Bystanders
Yes
Ingestion via object to mouth or
subsequent hand to mouth from
product dermal contact. EPA plans
to analyze mouthing via ingestion.

elsewhere


Article/Product
Contact
Dermal
Consumers
Yes
Dermal exposure may occur for this
condition of use. EPA plans to
analyze dermal exposure.


Vulcanization
accelerator
Direct contact
through use of
products/articles
Dust
Ingestion
Consumers
Yes
Ingestion of TPP sorbed onto dust
may occur for this condition of use.
EPA plans to analyze dust exposure
via ingestion.



containing TPP
Air/Particulate
Inhalation
Consumers
and
Bystanders
Yes
Inhalation of air and/or particles
from articles/products containing
TPP may occur for this condition of
use. EPA plans to analyze inhalation
exposure.
Consumer Use
Photographic
Supplies, Film,
Cellulose acetate
Direct contact
through use of
Air/Particulate
Inhalation
Consumers/
Bystanders
Yes
Inhalation via air and/or particulate
exposure may occur during
product/article use. EPA plans to
analyze inhalation exposure.
and Photo
Chemicals
film
products/articles
containing TPP
Dust
Ingestion
Consumers/
Bystanders
Yes
Ingestion of TPP sorbed onto dust
may occur for this condition of use.
EPA plans to analyze dust exposure
via ingestion.
89

-------
l.ile ( >cle
S(;i»o
("sik'Sion
Subciik'jion
Uok'iise from
sou rco
l.\|)(»suro
P;il liw
l.xposiire
Kniilc
Km'plor
Pliins In
i:\iiliiiilc
K;ilinn;ilc




Article/Product
Contact
Dermal
Consumers
Yes
Dermal exposure may occur via use
of articles containing TPP. EPA
plans to analyze dermal exposure.




Article/Product
Mouthing
Ingestion
Bystanders
Yes
Ingestion via object to mouth or
subsequent hand to mouth from
product dermal contact. EPA plans
to analyze mouthing via ingestion.




Air/Particulate
Inhalation
Consumers/
Bystanders
Yes
Inhalation via air and/or particulate
exposure may occur during
product/article use. EPA plans to
analyze inhalation exposure.


Flame retardants
in camping tents
Direct contact
through use of
products/articles
containing TPP
Dust
Ingestion
Consumers/
Bystanders
Yes
Ingestion of TPP sorbed onto dust
may occur for this condition of use.
EPA plans to analyze dust exposure
via ingestion.


Article/Product
Contact
Dermal
Consumers
Yes
Dermal exposure may occur via use
of articles containing TPP. EPA
plans to analyze dermal exposure.




Article/Product
Mouthing
Ingestion
Bystanders
Yes
Ingestion via object to mouth or
subsequent hand to mouth from
product dermal contact. EPA plans
to analyze mouthing via ingestion.




Air/Particulate
Inhalation
Consumers/
Bystanders
Yes
Inhalation via air and/or particulate
exposure may occur during
product/article use. EPA plans to
analyze inhalation exposure.
Consumer Use
Foam setting
and bedding
Foam and
upholstery
Direct contact
through use of
products/articles
containing TPP
Dust
Ingestion
Consumers/
Bystanders
Yes
Ingestion of TPP sorbed onto dust
may occur for this condition of use.
EPA plans to analyze dust exposure
via ingestion.

products
Article/Product
Contact
Dermal
Consumers
Yes
Dermal exposure may occur via use
of articles containing TPP. EPA
plans to analyze dermal exposure.




Article/Product
Mouthing
Ingestion
Bystanders
Yes
Ingestion via object to mouth or
subsequent hand to mouth from
product dermal contact. EPA plans
to analyze mouthing via ingestion.
90

-------
l.ile ( >cle
S(;i»o
("sik'Sion
Siibciik'jion
Uok'iise from
sou rce
l.\|)(»suro
P;il liw
l.xposiire
Koulo
Km'plor
Pliins In
i:\iiliiiilc
K;ilinn;ilc




Air/Particulate
Inhalation
Consumers/
Bystanders
Yes
Inhalation via air and/or particulate
exposure may occur during
product/article use. EPA plans to
analyze inhalation exposure.


Plasticizer in
automobile
Direct contact
through use of
products/articles
containing TPP
Dust
Ingestion
Consumers/
Bystanders
Yes
Ingestion of TPP sorbed onto dust
may occur for this condition of use.
EPA plans to analyze dust exposure
via ingestion.


upholstery
Article/Product
Contact
Dermal
Consumers
Yes
Dermal exposure may occur via use
of articles containing TPP. EPA
plans to analyze dermal exposure.




Article/Product
Mouthing
Ingestion
Bystanders
Yes
Ingestion via object to mouth or
subsequent hand to mouth from
product dermal contact. EPA plans
to analyze mouthing via ingestion.




Article/Product
Contact
Dermal
Consumers
Yes
Dermal exposure may occur for this
condition of use. EPA plans to
analyze dermal exposure..



Direct contact
through use of
products/articles
Dust
Ingestion
Consumers
Yes
Ingestion of TPP sorbed onto dust
may occur for this condition of use.
EPA plans to analyze dust exposure
via ingestion.
Consumer
Handling of
Disposal and
Waste
Wastewater,
Liquid wastes
and solid
wastes
Wastewater,
Liquid wastes
and solid wastes
containing TPP
Air/Particulate
Inhalation
Consumers
and
Bystanders
Yes
Inhalation of air and/or particles
from articles/products containing
TPP may occur for this condition of
use. EPA plans to analyze inhalation
exposure.










Long-term
emission/mass-
transfer through
use of products
containing TPP
Dust
Ingestion
Consumers
Yes
Ingestion of TPP sorbed onto dust
may occur for this condition of use.
EPA plans to analyze dust exposure
via ingestion.
91

-------
l.ile ( >cle
S(;i»o
("sik'Sitin
Siibciik'jion
Release from
sou rco
l.\|)(»suro
P;il liw ;i>
l.xposiire
Koulo
Km'plor
Pliins In
i:\iiliiiilc
K;ilinn;ilc




Air/Particulate
Inhalation
Consumers
and
Bystanders
Yes
Inhalation of air and/or particles
from articles/products containing
TPP may occur for this condition of
use. EPA plans to analyze inhalation
exposure.
92

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Appendix H SUPPORTING INFORMATION - CONCEPTUAL MODEL FOR
ENVIRONMENTAL RELEASES AND WASTES
Table Apx H-l General
Population and Environmental Exposure Conceptual Model Supporting
Life C\ck

Ki'k'iisi*
l'l\|)OMIIV
Pillliw ;¦> /
Mod i;i
KxpuMiiv
Kcccplor /
I'lilllS lo
Kiilioiiiik-
S(;i»c
Koii les
Population
I.\;iIii;iK'



Near laalm
ambient air
Inhalation
General
Population
Yes
TPP deposition to nearby bodies
of water and soil are expected



concentrations


exposure pathways, not covered

Emissions to
Air
Emissions to Air
Indirect
deposition to
Oral
Dermal
General
Population
Yes
under other EPA regulations, and,
therefore in scope.



nearby bodies
of water and
soil catchments
TBD
Aquatic and
Terrestrial
Receptors
Yes






Aquatic and

EPA plans to analyze the release
of TPP into surface water and



Direct release
into surface
water and
indirect
partitioning to
sediment
TBD
Terrestrial
Yes
indirect partitioning to sediment




Receptors

exposure pathways to aquatic and
terrestrial receptors.
All
Wastewater
or Liquid
Wastes
Industrial pre-
treatment and
wastewater
treatment, or POTW
Oral
Dermal
General
Population
Yes
EPA plans to analyze the release
of TPP into surface water and
indirect partitioning to sediment
and bioaccumulation exposure
pathways to the general
population.

Drinking Water
Oral
Dermal and
General
Population

EPA plans to analyze the release
of TPP into surface water and


via Surface or
Ground Water
Inhalation
(e.g.
showering)
Yes
indirect partitioning to drinking
water.



Biosolids:
application to
soil and/or
migration to
groundwater
Oral (e.g.
ingestion of
soil)
Inhalation
General
Population
Yes
EPA plans to analyze the pathway
from biosolids to the general
population and terrestrial species.



and/or surface
TBD
Terrestrial
Yes




water
receptors

able
93

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Disposal
Solid and
Liquid
Wastes
Municipal landfill
and other land
disposal
Leachate to
soil, ground
water and/or
migration to
surface water
Ural
Dermal
General
Population
Yes
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from municipal landfills and other
land disposal to the general
population, aquatic and terrestrial
receptors.
TBD
Aquatic and
Terrestrial
Receptors
94

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