U.S. Environmental Protection Agency
Hazard Characterization Document

June, 2015

SCREENING-LEVEL HAZARD CHARACTERIZATION

Zinc Naphthenate
(CASRN 12001-85-3)

The High Production Volume (HPV) Challenge Program1 was conceived as a voluntary initiative
aimed at developing and making publicly available screening-level health and environmental
effects information on chemicals manufactured in or imported into the United States in quantities
greater than one million pounds per year. In the Challenge Program, producers and importers of
HPV chemicals voluntarily sponsored chemicals; sponsorship entailed the identification and
initial assessment of the adequacy of existing toxicity data/information, conducting new testing if
adequate data did not exist, and making both new and existing data and information available to
the public. Each complete data submission contains data on 18 internationally agreed to "SIDS"
(Screening Information Data Set1'2) endpoints that are screening-level indicators of potential
hazards (toxicity) for humans or the environment.

The Environmental Protection Agency's Office of Pollution Prevention and Toxics (OPPT) is
evaluating the data submitted in the HPV Challenge Program on approximately 1400 sponsored
chemicals by developing hazard characterizations (HCs). These HCs consist of an evaluation of
the quality and completeness of the data set provided in the Challenge Program submissions.

They are not intended to be definitive statements regarding the possibility of unreasonable risk of
injury to health or the environment.

The evaluation is performed according to established EPA guidance2'3 and is based primarily on
hazard data provided by sponsors; however, in preparing the hazard characterization, EPA
considered its own comments and public comments on the original submission as well as the
sponsor's responses to comments and revisions made to the submission. In order to determine
whether any new hazard information was developed since the time of the HPV submission, a
search of the following databases was made from one year prior to the date of the HPV
Challenge submission to the present: (ChemID to locate available data sources including
Medline/PubMed, Toxline, HSDB, IRIS, NTP, AT SDR, IARC, EXTOXNET, EPA SRS, etc.),
STN/CAS online databases (Registry file for locators, ChemAbs for toxicology data, RTECS,
Merck, etc.), Science Direct and ECHA.4 OPPT's focus on these specific sources is based on
their being of high quality, highly relevant to hazard characterization, and publicly available.

OPPT does not develop HCs for those HPV chemicals which have already been assessed
internationally through the HPV program of the Organization for Economic Cooperation and
Development (OECD) and for which Screening Initial Data Set (SIDS) Initial Assessment
Reports (SIAR) and SIDS Initial Assessment Profiles (SIAP) are available. These documents are
presented in an international forum that involves review and endorsement by governmental
authorities around the world. OPPT is an active participant in these meetings and accepts these
documents as reliable screening-level hazard assessments.

1	U.S. EPA. High Production Volume (HPV) Challenge Program; http://www.epa.gov/chemrtk/index.htm.

2	U.S. EPA. HPV Challenge Program - Information Sources; http://www.epa.gov/chemrtk/pubs/general/guidocs.htm.

3	U.S. EPA. Risk Assessment Guidelines; http://cfpub.epa.gov/ncea/raf/rafguid.cfm.

4	European Chemicals Agency, http: //echa. europa.eu.


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These hazard characterizations are technical documents intended to inform subsequent decisions
and actions by OPPT. Accordingly, the documents are not written with the goal of informing the
general public. However, they do provide a vehicle for public access to a concise assessment of
the raw technical data on HPV chemicals and provide information previously not readily
available to the public.

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Chemical
Abstract Service
Registry
Number

12001-85-3

(CASRN)

Chemical
Abstract Index
Name

Naphthenic acids, zinc salts

Structural
Formula

-O

K—

Representative5 SMILES:

Q=C(0[Znl0C(CCCCCC4CCC3CCCC34)=0)CCCCCC2CCClCCCC12

Summary

Zinc naphthenate is a complex mixture that exists as either viscous liquids or cold, flowing
solids at room temperature. It possesses moderate water solubility and negligible vapor
pressure and is expected to have moderate mobility in soil. Volatilization of zinc naphthenate
is considered negligible since it's a salt. Zinc naphthenate is expected to dissociate in water to
the zinc cation and naphthenic acid or its conjugate base, both of which are stable in water.
The rate of atmospheric photooxidation is considered moderate; however, this is not a relevant
environmental degradation pathway since salts are not expected to exist in the vapor phase in
the atmosphere. Zinc naphthenate is expected to have low persistence (PI) and low
bioaccumulation potential (Bl).

The acute oral toxicity in rats is low, and the acute dermal toxicity in rabbits is low. In a
repeated-dose study in rabbits via the dermal route, decrease in body weight, increase in
relative kidney and adrenal weights and increase in neutrophils were observed at 1000 mg/kg-
day; the NOAEL for systemic toxicity is 300 mg/kg-day. In this study, irritation was observed
at the application site at all dose levels with zinc naphthenate and controls. In a dietary two-
generation reproductive toxicity study in rats, significant weight loss was observed in parental
animals at the high dose (estimated to be 367 mg/kg-bw/day); the NOAEL for systemic
toxicity was -73 mg/kg-bw/day. No adverse effects on reproductive parameters were
observed; the NOAEL for reproductive toxicity is -367 mg/kg-bw/day (highest dose tested).
In an oral (gavage) prenatal developmental toxicity studies in rats, no systemic effects in the
dams or developmental effects in fetuses were observed. The NOAEL for maternal and
developmental toxicity is 500 mg/kg-day (highest dose tested). In another prenatal
developmental study via gavage in rats, dams exhibited significant body weight changes and
clinical signs at 938 mg/kg-day; the NOAEL for maternal toxicity is 188 mg/kg-day.
Morphological changes in fetuses at all doses resulted in no established NOAEL for	

5 The ring type and carbon number distributions of naphthenic acids from an acidic Californian crude oil was
approximately 6% 0-ring naphthenic acids; 32% 1-ringed naphthenic acids; 38% 2-ringed naphthenic acids; 15% 3-
ringed napthenic acids; 5% 4-ringed napthenic acids; 3% 5-ringed napthenic acids; 1% 6-ringed napthenic acids.
See: Hsu CS; Dechert GJ; Robbins WK; et al. 2000. Napthenic Acids in Crude Oil Characterized by Mass
Spectroscopy. Energy & Fuels 14:217-223.

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developmental toxicity. Zinc naphthenate induced both gene mutations (mouse lymphoma
cells) and chromosomal aberrations (Chinese hamster ovary cells) in vitro, but did not induce
unscheduled DNA synthesis (rat hepatocytes) in vitro. Zinc naphthenate causes dermal
irritation in rabbits and guinea pigs in 24-hour studies, is not irritating to rabbit eyes, and is
considered a possible skin sensitizer in guinea pigs.

For zinc naphthenate (CASRN 12001-85-3), the 96-h LC50 for fish is 1.1 mg/L, the 48-h EC50
for aquatic invertebrates is 4.6 mg/L, and the 72-h EC50 for aquatic plants is 0.78 mg/L for
growth rate.

No data gaps were identified under the HPV Challenge Program.	

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The sponsor, OM Group, Inc., submitted a test plan and robust summaries to EPA for zinc
naphthenate (CASRN 12001-85-3; CA name: naphthenic acids, zinc salts) on December 22,
2003 as a member of the Metal Carboxylates Coalition from the Synthetic Organic Chemical
Manufacturers Association, or SOCMA6. Zinc napthenate was identified as a member of a large
category for Metals Carboxylates. EPA posted the submission on the ChemRTK HPV Challenge
website on January 23, 2003

(http://www.epa.gov/oppt/chemrtk/pubs/summaries/metalcarb/cl4172tc.htm). EPA comments on
this original submission were posted to the website on May 22, 2003.

Based on EPA (and other public comments), members of the Coalition proceeded to submit
revised test plans and robust summaries as separate submissions over the next few years. Thus,
the OM Group, Inc. submitted a revised submission dated December 28, 2005 for zinc
napthenate, which was posted to the website on March 15, 2006. A final submission was made
by OM Group Americas and Troy Corporation (dated June 22, 2008) and was posted to the
website on September 24, 2008.

As a registered pesticide, EPA has published evaluations of the health and environmental effects
data of zinc naphthenate.

Reregi strati on Eligibility Decision (RED) -
http://www.epa.gov/pesticides/reregistration/naphthenate-salts/

Supporting documentation for RED (docket) -

http://www.regulations. gov/#! searchResults:rpp=10:po=0:s=EPA-HQ-OPP-2007-0589
Antimicrobial documents:

http://www.regulations.gov/#!docketDetail;dct=FR%252BPR%252BN%252BO%252BSR;rpp=
25;po=0;D=EPA-HQ-QPP-2010-0455

Justification for Supporting Chemicals

All SIDS endpoints (except for biodegradation - see below under environmental fate) have been
met with test data on the sponsored chemical zinc naphthenate. Therefore, EPA did not use the
data on the dissociation products because data for the parent compound were available.

1. Chemical Identity

1.1 Identification and Purity

Zinc naphthenate is either viscous liquids or cold, flowing solids at room temperature, possessing
moderate water solubility and negligible vapor pressure.

6 In 2009, SOCMA changed its name to the Society of Chemical Manufacturers and Affiliates; resulting in a new
name, but no change in the acronym.

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There are four different forms of zinc naphthenate that have been evaluated in the submitted
studies:

•	Fungitrol Zinc 8% (a pesticide formulation; Fungitrol Zinc is a trade name for zinc
naphthenate)

•	2% zinc naphthenate in mineral spirits solvent

•	Technical grade zinc naphthenate (98.9% pure, containing 14.3% zinc)

•	zinc naphthenate (technical grade, purity not provided; 13.7% zinc)

Zinc naphthenate is described as a reaction product of zinc oxide and naphthenic acid; with
variable molecular weight and carbon content due to variation in the naphthenic acid source (a
petroleum product). Zinc naphthenate has large ranges in the number of carbon atoms (9-25) and
molecular weight (381-813). In addition, zinc content for zinc naphthenate is reported as 8-10%
in liquid forms and 16% in the solid form.

1.2 Physical-Chemical Properties

The physical-chemical properties of zinc naphthenate are summarized in Table 1.

Table 1. Physical-Chemical Properties of Zinc naphthenate1'2

Property

Value

CASRN

136-53-8

Molecular Weight

381-813

Physical State

Viscous liquid containing 8—10% zinc or a solid containing 16%
zinc

Melting Point

A distinct melting point could not be measured due to the
complexity of the mixture. The substance exists as a solid or viscous
liquid based on the mixture and zinc content.

Boiling Point

Initial boiling point at 116 °C and decomposes at 255EC (measured)

Vapor Pressure

<1.0x10"10 mm Hg at 25 °C (estimated)3'4

Henry's Law Constant

<1.0x10"10 atm-m3/mole (estimated)3'4

Water Solubility

80 mg/L at 20 °C (measured)

Log Kow

1.1 (measured)

'The Metal Carboxylates Coalition. 2006. Test Plan and Robust Summary for Naphthenic acids, zinc salts.
Available online at http://www.epa. gov/chemrtk/pubs/summaries/metalcarb/c 14172tc.htm as of October 28, 2011.
2According to the Test Plan, naphthenic acids, zinc salts have a molecular weight range of 381-813. The molecular
weight of the representative structure used in the estimations was 512.

3U.S. EPA. 2011. Estimation Programs Interface Suite™ for Microsoft® Windows, v4.10. U.S. Environmental
Protection Agency, Washington, DC, USA. Available online at
http://www.epa.gov/opptintr/exposure/pubs/episuitedl.htm as of October 28, 2011.

4Zinc salts are outside the estimation domain of EPIWIN.

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2. General Information on Exposure

2.1 Production Volume and Use Pattern

CASRN 12001-85-3 had an aggregated production and/or import volume in the United States
less than 500,000 pounds during calendar year 2005.

Non-confidential information in the IUR indicated that the industrial processing and uses of the
chemical include other basic organic chemical manufacturing as "other." Non-confidential
commercial and consumer uses of this chemical include "other."

2.2 Environmental Exposure and Fate

Zinc naphthenate is expected to have moderate mobility in soil. No biodegradation data exists for
this substance; however biodegradation data for commercial naphthenic acids suggest that
naphthenic acids, zinc salts will not be highly persistent in the environment. Commercial
mixtures of the sodium salts of naphthenic acids were shown to degrade and mineralize to CO2
when inoculated with microbial populations indigenous to oil sands tailings. Approximately 50%
of the organic carbon was converted to CO2 over a 24-day period. Three of four model
naphthenic acid compounds were also degraded by the enrichment cultures, with approximately
40-50% of the organic carbon converted to CO2 over a 24-day period. Additional studies
examined the concentration and composition of naphthenic acids in aerobic biodegradation
studies using sodium salts of naphthenic acids. Within 10 days of incubation with enrichment
cultures on naphthenic acid-degraders, naphthenic acids concentration dropped from about 100
to <10 mg/L, accompanied by release of about 60% of the carbon as CO2. The rate of
volatilization is negligible since it is a salt. Zinc naphthenate dissociates in water to the zinc
cation and naphthenic acid or its conjugate base, both of which are stable in water. The rate of
atmospheric photooxidation is considered moderate; however, this is not a relevant
environmental degradation pathway since salts are not expected to exist in the vapor phase in the
atmosphere. Naphthenic acids, zinc salts are expected to have low persistence (PI) and low
bioaccumulation potential (Bl).

The environmental fate properties of zinc naphthenate are summarized in Table 2.

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Table 2. Environmental Fate Characteristics of Naphthenic acids, zinc salts1

Property

Value

Photodegradation Half-
life

4.1 hours (estimated)2'3

Hydrolysis Half-life

Stable

Biodegradation

Half-life approximately 1 day

Bi oconcentrati on

BAF = 2.2 (estimated)2'3

Log Koc

5.8 (estimated)2'3

Fugacity

(Level III Model)2'3

Air (%)

<0.1

Water (%)

1.9

Soil (%)

46.9

Sediment (%)

51.2

Persistence4

PI (low)

Bi oaccumul ati on4

Bl (low)

'The Metal Carboxylates Coalition. 2006. Test Plan and Robust Summary for Naphthenic acids, zinc salts.
Available online at http://www.epa.gov/chemrtk/pubs/summaries/metalcarb/cl4172tc.htm as of October 28, 2011.
2U. S. EPA. 2011. Estimation Programs Interface Suite™ for Microsoft® Windows, v4.10. U. S. Environmental
Protection Agency, Washington, DC, USA. Available online at
http://www.epa.gov/opptintr/exposure/pubs/episuitedl.htm as of October 4, 2011.

3Zinc salts are outside the estimation domain of EPIWIN.

4Federal Register. 1999. Category for Persistent, Bioaccumulative, and Toxic New Chemical Substances. Federal
Register 64, Number 213 (November 4, 1999) pp. 60194-60204.

Conclusion: Zinc naphthenate is a complex mixture that exists as either viscous liquids or cold,
flowing solids at room temperature. It possesses moderate water solubility and negligible vapor
pressure and is expected to have moderate mobility in soil. Volatilization of zinc naphthenate is
considered negligible since it's a salt. Zinc naphthenate is expected to dissociate in water to the
zinc cation and naphthenic acid or its conjugate base, both of which are stable in water. The rate
of atmospheric photooxidation is considered moderate; however, this is not a relevant
environmental degradation pathway since salts are not expected to exist in the vapor phase in the
atmosphere. Zinc naphthenate is expected to have low persistence (PI) and low bioaccumulation
potential (Bl).

3. Human Health Hazard

A summary of the available health effects data submitted for SIDS endpoints is provided in
Table 3.

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Acute Oral Toxicity

(1)	Sherman-Wistar rats (5/sex/dose) were administered zinc naphthenate (Fungitrol zinc 8%
fungicide) via gavage at a single dose of 5000 mg/kg and observed for 14 days. No mortalities
were observed.

LDso > 5000 mg/kg

(2)	Sprague-Dawley rats (5/sex/dose) were administered zinc naphthenate (2% zinc naphthenate
in a mineral spirits solvent) via gavage at a single dose of 5000 mg/kg and observed for 14 days.
One of five females died and no deaths were observed among males.

LD50 > 5000 mg/kg

Acute Inhalation Toxicity

Albino rats (5/sex/dose) were exposed to zinc naphthenate (50% w/v suspension of Fungitrol
zinc 8% fungicide in mineral spirits) as an aerosol at a concentration of 11.6 mg/L for 4 hours
and observed for 14 days. No mortalities were observed.

LC50 > 11.6 mg/L

Acute Dermal Toxicity

(1)	Albino rabbits (5/sex/dose) were administered zinc naphthenate (Fungitrol zinc 8%
fungicide) via the dermal route at a single dose of 2 g/kg (2000 mg/kg) under occluded
conditions (backs were clipped, exposed skin was abraded) for 24 hours and observed for
14 days following dosing. No mortalities were observed.

LD50 > 2000 mg/kg

(2)	New Zealand albino rabbits (5/sex/dose) were administered zinc naphthenate (2% zinc
napththenate in mineral spirits) via the dermal route at a single dose of 2 g/kg (2000 mg/kg)
under occluded conditions (backs were clipped, exposed skin was abraded) for 24 hours and
observed for 14 days following dosing. No mortalities were observed. .

LD50 > 2000 mg/kg

Repeated-Dose Toxicity

In a 90-day dermal toxicity study, New Zealand white rabbits (10/sex/dose) were exposed to zinc
naphthenate (technical grade, purity 98.9%, 14.3% zinc) at doses of 100, 300 and 1000 mg/kg-
day. The test substance was diluted (50% by weight) in light mineral oil and applied to clipped,
intact skin. The treated area was wrapped in gauze (secured with tape) for six hours/day, five
days/week for 13 weeks. After six hours, the gauze was removed and the area was wiped with
paper towels moistened with mineral oil. Controls received mineral oil only and were treated the
same way. Dermal irritation was present at the application site in all groups, including the
control. Irritation increased in a dose-related manner, and histopathological evaluation revealed
treatment-related lesions characterized by hyperkeratosis of the epidermal surface and dermal
hyperplasia. Body weight decrease, relative kidney and adrenal weight increase and a slight
increase in neutrophils were reported in the 1000 mg/kg-day dose group.

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LOAEL (systemic toxicity) = 1000 mg/kg- day (based on body weight decrease, relative
kidney and adrenal weight increase and increase in neutrophils)

NOAEL (systemic toxicity) = 300 mg/kg- day

Reproductive Toxicity

Sprague-Dawley rats (30 rats/sex/dose) were administered zinc naphthenate (technical grade,
97% purity, 13.7% zinc) in corn oil via the oral route in a two-generation, continuous feeding
study at nominal concentrations in the feed of 500, 1000 and 5000 ppm. Parental animals were
given treated feed for a 10 week pre-mating period, after which females stayed on the test diets
through mating, gestation and lactation. Ten-week pre-mating doses in mg/kg-bw/day were
reported as follows: males (24-48, 48-98 and 237-487) and females (29-50, 61-98 and 305-497)
for the 500, 1000 and 5000 ppm groups, respectively. For this hazard characterization, the
estimated doses consist of the midpoint in the dose range (by combining both sexes per dose
group). The estimated doses are 37, 73 and 367 mg/kg-bw/day for the low, mid and high dose
groups, respectively. Parental animals were checked daily for clinical signs. After sacrifice,
animals were examined grossly and their target organ tissues (not specified) were examined
histologically. Total litter weights for pups were recorded on days 0, 4, 7, 14 and 21. No adverse
effects on reproductive function were observed over two generations. Rats in the high dose group
showed significant body weight loss. [Some study details were extracted from EPA-HQ-OPP-
2007-0589-0003, available at www.regulations.gov. See also
http://www.epa.gOv/pesticides/reregistration/naphthenate-salts/1

LOAEL (parental toxicity) ~ 367 mg/kg-bw/day (based on significant weight loss/reduced
weight gain)

NOAEL (parental toxicity) ~ 73 mg/kg-bw/day

NOAEL (reproductive toxicity) ~ 367 mg/kg-bw/day (based on no adverse effects on
reproductive parameters at the highest dose tested)

Developmental Toxicity

(1) Pregnant Sprague-Dawley rats (at least 33/dose) were administered zinc naphthenate
(technical grade, purity not provided; 13.7% zinc) in corn oil via gavage at measured
concentrations of 94, 188 and 938 mg/kg- day on days 6-15 of gestation. Females were sacrificed
on gestation day 20. In an unusual protocol, fetuses were examined for skeletal (only even-
numbered fetuses) or soft tissue (only odd-numbered fetuses) malformations. All uteri were
examined for number of corpora lutea, implantation sites, resorptions and fetuses. Signs of
maternal toxicity included clinical signs (lethargy, brown staining in urogenital area, red nasal
and oral exudates and generalized hair loss) and significant reduction in body weight at
938 mg/kg- day. Lower fetal body weights and increased incidence of resorptions (total
resorptions and resorptions/dam) were also observed in the high dose group. There was an
increase in the incidence of morphological deviations in all treatment groups compared to
controls. Although morphological deviations were considered minor, EPA presumed that these
were adverse effects based on lack of information in the available study summary. [Some study
details were extracted from EPA-HQ-OPP-2007-0589-0003, available at [Some study details

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were extracted from EPA-HQ-OPP-2007-0589-0003, available at www.regulations.gov. See also
http://www.epa.gOv/pesticides/reregistration/naphthenate-salts/1

LOAEL (maternal toxicity) = 938 mg/kg-day (based on clinical signs, reduced body weight
gain)

NOAEL (maternal toxicity) = 188 mg/kg-day

LOAEL (developmental toxicity) = 188 mg/kg-day (based on morphological deviations not
otherwise specified)

NOAEL (developmental toxicity) = Not established

(2) Pregnant Sprague-Dawley rats (25/dose group) were administered zinc naphthenate
(technical grade, 98.9% purity, 14.3% zinc) in corn oil via gavage at measured concentrations of
50, 250 and 500 mg/kg- day on days 6-15 of gestation. Females were sacrificed on gestation day
20. Fetuses were examined for external, skeletal, soft tissue malformations and developmental
variations. Uteri and ovaries were examined for number of corpora lutea, implantation sites,
early and late resorptions and the number and location of fetuses. Anogenital and/or urogenital
staining, staining around the mouth and salivation were observed at 500 mg/kg-day and to a
lesser extent at 250 mg/kg-day; however no systemic effects in the dams were observed. There
were no effects on developmental parameters.

NOAEL (maternal toxicity) = 500 mg/kg-day (based on no adverse systemic effects at the
highest dose tested)

NOAEL (developmental toxicity) = 500 mg/kg- day (based on no adverse developmental
effects at the highest dose tested)

Genetic Toxicity - Gene Mutation
In vitro

In a mammalian cell gene mutation assay, L5178Y mouse lymphoma cells were exposed to zinc
naphthenate (technical grade, 98.9% purity, 14.3% zinc) at various concentrations (1.3 to 100
|ig/mL- initial assay ;7.5 to 75 (ag/m L— confirmation assay) with ethanol as solvent. Cytotoxicity
was observed at 100 |ig/mL (without metabolic activation) and 1000 jag/m L (with metabolic
activation). No information was provided about the use of positive and negative controls. Results
indicated that zinc naphthenate was positive in this assay (increase in mutant frequencies were
observed) in both the initial and confirmation assays. The results were dose-dependent. An
increase in the proportion of small mutant colonies from treated cultures suggested clastogenic
activity7.

Zinc naphthenate was mutagenic in this assay.

7 See OPP review at: http://www.regulations.gov (Document ID EPA-HQ-OPP-2007-0589-0003)

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Genetic Toxicity - Chromosomal Aberrations
In vitro

In a chromosomal aberration assay, Chinese hamster ovary cells were exposed to zinc
naphthenate (technical grade, 98.9% purity, 14.3% zinc) in ethanol at concentrations of 5- 80
|ig/mL (without metabolic activation) and 10 - 160 |ag/m L (with metabolic activation) in an
initial assay and then at concentrations of 80- 200 |ag/m L (without metabolic activation) and 60-
140 |ig/mL (with metabolic activation) in a confirmatory assay. Positive and negative controls
were used. Cytotoxicity was evident at 80 |ig/mL. The test substance was considered positive in
this assay, although a breakdown of results (activation vs non-activation) was not provided8.

Zinc naphthenate induced chromosomal aberrations in this assay

Genetic Toxicity — Other
In vitro

In an unscheduled DNA synthesis study, Harlan Sprague-Dawley rat hepatocytes were exposed
to zinc naphthenate (technical grade, 98.0% purity, 14.3% zinc) at eight dose levels ranging from
0.015 to 35 |ig/mL (with ethanol as a solvent/vehicle). Positive (DMBA) and negative controls
were used. Cytotoxicity occurred at 15 |ig/mL. Results showed no significant increase in
unscheduled DNA synthesis in the primary hepatocytes.

Zinc naphthenate did not induce unscheduled DNA synthesis in this assay.

Additional Information
Skin Irritation

(1)	New Zealand albino rabbits (6/dose/study; gender not specified) were administered Fungitrol
Zinc 8%> fungicide via the dermal route under occluded conditions for 24 hours. Skin (location
not specified) was clipped and part of the area was abraded and part was kept intact. The test
material was applied (0.5 mL, undiluted) and the area covered for 24 hours. Examination for
erythema, eschar and edema was conducted at 24 and 72 hours. The test material was considered
irritating at both time points and under both intact and abraded skin (results were considered
similar across time points and abraded/intact conditions). The test was conducted twice and
similar results were observed (Draize scores of 6.29 and 4.29, respectively). This study is longer
than recommended irritation study guidelines (24 vs. 4 hours).

Zinc naphthenate was irritating to rabbit skin in this assay.

(2)	New Zealand albino rabbits (6/dose/study; gender not specified) were administered 2% zinc
naphthenate in solvent (assumed to be mineral spirits) via the dermal route under occluded

8 See OPP review at:http://\vww.regulations.gov/#!scarchRcsults:rDD=10:DO=0:s=EPA-HO-OPP-2007-0589
(Document ID EPA-HQ-OPP-2007-0589-0003)

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conditions for 24 hours. Skin (from the trunk) was clipped and two parts of the area were
abraded and another two parts were kept intact. The test material was applied undiluted (0.5 mL)
and the area covered for 24 hours. Examination for erythema, eschar and edema was conducted
at 24, 72 and 96 hours. No erythema was observed at 24 hours, but five animals had slight
erthyema at 72 hours. Slight to moderate edema was observed in two animals and only at 24
hours in the abraded skin portions of the test area. All signs of irritation subsided by 96 hours.
This study is longer than recommended irritation study guidelines (24 vs. 4 hours).

Zinc naphthenate was irritating to rabbit skin in this assay.

Eye Irritation

(1)	New Zealand albino rabbits (6/dose/study; gender not specified) were administered Fungitrol
Zinc 8% fungicide via direct instillation into the eye. A 0.1 mL sample (undiluted) of the test
material was put into the right eye (left eyes were untreated controls) and was not washed off.
Treated eyes were examined and scored using the Draize scale on days one, two, three, five and
seven days after instillation. Some irritation was observed according to the day-one scoring
(average of 7.0), but all scores were zero thereafter.

Zinc naphthenate was not irritating to rabbit eyes in this assay.

(2)	New Zealand albino rabbits (nine animals; gender not specified) were administered 2% zinc
naphthenate in solvent (not specified, assumed to be mineral spirits based on other robust
summaries for this test material) via direct instillation into the eye. A 0.1 mL sample (undiluted)
of the test material was put into the right eye (left eyes were untreated controls) of six animals
and was not washed off. The same thing was done with three other animals except that the eyes
were flushed with water about 20-30 seconds after treatment. Treated eyes were examined and
scored on days one, two, three, five and seven days after instillation. Scores were zero at all
times for all animals.

Zinc naphthenate was not irritating to rabbit eyes in this assay.

Skin Sensitization

Male albino guinea pigs (10/dose) were exposed to zinc naphthenate (Fungitrol zinc 8%
fungicide) via the dermal route at 0.5 mL (a 10% weight/volume suspension in mineral spirits)
under occluded conditions for 24 hours. The test material was applied again after a 24-hour
resting period. This dosing sequence was repeated ten times (induction phase of the study). In the
challenge phase, two weeks after the 10th induction application, a similar dose was placed on
different sites on the animal for 24 hours and then removed. Sites were examined for irritation
(24 hours after each induction application and both 24 and 48 hours after the challenge
application). Zinc naphthenate produced well defined erythema and very slight edema during the
induction period and the challenge dose produced slightly less severe effects. The robust
summary states that zinc naphthenate was"possibly a sensitizing agent in the guinea pig". The
US EPA Office of Pesticide Programs agreed with these results and considered zinc naphthenate
a possible sensitizing agent [HQ-OPP-2007-0589-0003, available at
http ://www. regulations, gov!.

Zinc naphthenate was irritating to guinea pig skin and a possible sensitizing agent in this
assay.

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Conclusion: The acute oral toxicity in rats is low, and the acute dermal toxicity in rabbits is low.
In a repeated-dose study in rabbits via the dermal route, decrease in body weight, increase in
relative kidney and adrenal weights and increase in neutrophils were observed at 1000 mg/kg-
day; the NOAEL for systemic toxicity is 300 mg/kg-day. In this study, irritation was observed at
the application site at all dose levels with zinc naphthenate and controls. In a dietary two-
generation reproductive toxicity study in rats, significant weight loss was observed in parental
animals at the high dose (estimated to be 367 mg/kg-bw/day); the NOAEL for systemic toxicity
was -73 mg/kg-bw/day. No adverse effects on reproductive parameters were observed; the
NOAEL for reproductive toxicity is -367 mg/kg-bw/day (highest dose tested). In an oral
(gavage) prenatal developmental toxicity studies in rats, no systemic effects in the dams or
developmental effects in fetuses were observed. The NOAEL for maternal and developmental
toxicity is 500 mg/kg-day (highest dose tested). In another prenatal developmental study via
gavage in rats, dams exhibited significant body weight changes and clinical signs at 938 mg/kg-
day; the NOAEL for maternal toxicity is 188 mg/kg-day. Morphological changes in fetuses at all
doses resulted in no established NOAEL for developmental toxicity. Zinc naphthenate induced
both gene mutations (mouse lymphoma cells) and chromosomal aberrations (Chinese hamster
ovary cells) in vitro, but did not induce unscheduled DNA synthesis (rat hepatocytes) in vitro.
Zinc naphthenate causes dermal irritation in rabbits and guinea pigs in 24-hour studies, is not
irritating to rabbit eyes, and is considered a possible skin sensitizer in guinea pigs.

Table 3. Summary of the Screening Information Data Sets Submitted under the US H PV

Challenge Program: Human Health Data

Endpoint

Zinc Naphthenate
(12001-85-3)

Acute Oral Toxicity
LD5o (mg/kg)

>5000

Acute Dermal Toxicity
LD5o (mg/kg)

>2000

Acute Inhalation Toxicity
LCso (mg/L)

>11.6

Repeated-Dose Toxicity
NOAEL/LOAEL
Dermal (mg/kg-day)

NOAEL = 300
LOAEL = 1000

Reproductive Toxicity
NOAEL/LOAEL
Oral (mg/kg-bw/day)

NOAEL = 367
(highest dose tested)

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Table 3. Summary of the Screening Information Data Sets Submitted under the US HPV

Challenge Program: Human Health Data

Endpoint

Zinc Naphthenate
(12001-85-3)

Developmental Toxicity
NOAEL/LOAEL
Oral (mg/kg-day)

Maternal

(rat)
NOAEL = 188
LOAEL = 938

Developmental

NOAEL = Not established
LOAEL= 188

Genetic Toxicity - Gene Mutation
In vitro

Positive

Genetic Toxicity - Chromosomal
Effects

Positive

Genetic Toxicity - Other
(unscheduled DNA synthesis)

Negative

Other Information

Skin Irritation
Eye Irritation
Skin Sensitization

Irritating
Not Irritating
Possible Sensitizer

Measured data in BOLD

4. Hazard to the Environment

A summary of aquatic toxicity data submitted for SIDS endpoints is provided in Table 4.

Acute Toxicity to Fish

(1)	Bluegill sunftsh (Lepomis macrochirus) were exposed to zinc naphthenate (98.9% purity) at
measured concentrations of 0.54, 1.0, 1.7, 3.1 or 5.0 mg/L under static-renewal conditions for 96
hours. Tests were conducted in closed systems. Complete mortality was observed at 3.1 and 5.0
mg/L after 96 hours of exposure.

96-h LCso = 1.5 mg/L

(2)	Rainbow trout (Oncorhynchus mykiss) were exposed to zinc naphthenate (98.9% purity) at
measured concentrations of 0.39, 0.66, 1.1, 1.8 or 3.2 mg/L under static conditions for 96 hours.
Complete mortality was observed at 1.8 and 3.2 mg/L, with 50% mortality at 1.1 mg/L. No
mortality was observed at the two lowest doses.

96-h LCso = 1.1 mg/L

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Acute Toxicity to Aquatic Invertebrates

Daphnia magna were exposed to zinc naphthenate (98.9% purity) at measured concentrations of
2.6, 4.6, 8.2, 14, 20 and 35 mg/L under static conditions for 48 hours. Complete immobilization
was observed at 8.2, 14, 20 and 35 mg/L, with 50% immobilization at 4.6 mg/L. No
immobilization was observed at the lowest test concentration.

48-h ECso = 4.6 mg/L

Toxicity to Aquatic Plants

Green algae (Pseudokirchneriella subcapitata) were exposed to zinc naphthenate (purity 67%) at
measured concentrations of 0.15, 0.2, 0.35, 0.79, 1.7, or 4.3 mg/L for 72 hours.

72-h EC50= 0.78 (growth rate)

Conclusion: For zinc naphthenate (CASRN 12001-85-3), the 96-h LC50 for fish is 1.1 mg/L,
the 48-h EC50 for aquatic invertebrates is 4.6 mg/L, and the 72-h EC50 for aquatic plants is 0.78
mg/L for growth rate.

Table 4: Summary of the Screening Information Data Set as Submitted under
the U.S. HPV Challenge Program - Aquatic Toxicity Data

Endpoint

Zinc Naphthenate
(12001-85-3)

Fish

96-h LCso (mg/L)

1.1

Aquatic Invertebrates
48-h ECso (mg/L)

4.6

Aquatic Plants
96-h ECso (mg/L)

(growth rate)
(biomass)

0.78

Bold = experimental data; i.e. derived from testing; - indicates that end-point was not addressed
for this chemical.

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