U.S. Environmental Protection Agency
Supporting Documents for Risk-Based Prioritization

September 2008

Supporting Documents for Initial Risk-Based Prioritization of
High Production Volume Chemicals

Cyclohexanone, Oxime (CASRN 100-64-1)

Contents:

•	Page 2: Background

•	Page 4: Screening-Level Risk Characterization: September 2008

•	Page 7: Screening-Level Hazard Characterization: September 2008

•	Page 15: Screening-Level Exposure Characterization: September 2008


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BACKGROUND

Screening-level hazard, exposure and risk characterizations for high production volume chemicals (HPV)
are important contributions to the chemicals cooperation work being done in North America1 through the
EPA Chemical Assessment and Management Program (ChAMPjr. These screening-level
characterizations are developed by EPA for individual chemicals or chemical categories to support initial
Risk-Based Prioritizations (RBPs) for HPV chemicals. These screening-level characterizations are
technical documents intended primarily to inform the Agency's internal decision-making process.
Accordingly, they are written for assessment professionals and assume a degree of technical
understanding. Each of the support documents is described below.

The Risk-Based Prioritizations are found in an accompanying document and are written for a general
audience. They present EPA's initial thinking regarding the potential risks presented by these chemicals
and future possible actions that may be needed.

Hazard Characterizations for HPV Chemicals

EPA's screening-level hazard characterizations are based primarily on the review of the summaries of
studies and other information submitted by the chemical sponsor(s) under the HPV Challenge Program'.
These studies included in the scope of the HPV Challenge comprise the Screening Information Data Set
(SIDS) of the Organization for Economic Cooperation and Development (OECD)4, an internationally
recognized battery of tests that provides the basic data necessary to make an initial evaluation of a
chemical's hazards and fate. In preparing the initial hazard characterizations, EPA also consulted a
variety of reliable sources5 for additional relevant information and 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 an HPV submission, EPA also searched publicly available databases6 for information entered
from one year prior to the HPV submission through May 2008. The screening-level hazard
characterization is performed according to established EPA guidance7. A more detailed description of the
hazard characterization process is available on the EPA website8.

With respect to chemicals for which internationally-accepted OECD SIDS Initial Assessment Profiles
(SIAP) and Initial Assessment Reports (SIAR) were available, EPA did not generate its own screening-
level hazard characterization, but did check for and incorporate updated information in the risk
characterization

Exposure Characterizations for HPV Chemicals

EPA recently received exposure-related data on chemicals submitted in accordance with the requirements
of Inventory Update Reporting (IUR)9. The 2006 IUR submissions pertain to chemicals manufactured in

1	U.S. EPA - U.S. Commitments to North American Chemicals Cooperation:
http: / /www. ep a. gov/hpv/pubs/general/sppframe work. htm.

2	U.S. EPA-ChAMP information: http://www.epa.gov/champ/.

3	U.S. EPA - HPV Challenge Program information: http://www.epa.gov/hpv.

4	U.S. EPA - Technical Guidance Document, OECD SIDS Manual Sections 3.4 and 3.5:
http: //www, epa. gov/chemrtk/pubs/general/sidsappb. htm

5	U.S. EPA - Public Database Hazard Information: http://www.epa. gov/hpvis/hazardinfo.htm

6	U.S. EPA - Public Database Update Information: http://www.epa.gov/chemrtk/hpvis/updateinfo.htm

7	U.S. EPA - Risk Assessment Guidelines: http: //cfpub. ep a. go v/ncea/raf/raf guid. cfm

8	U.S. EPA - About HPV Chemical Hazard Characterizations: http: //www .epa. go v/hp vi s/abouthc. htm

9	U.S. EPA-Basic IUR Information: http://www.epa.gov/opptintr/iur/pubs/guidance/basic-information.htm.

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(including imported into) the U.S. during calendar year 2005 in quantities of 25,000 pounds or more at a
single site. The reports include the identity, the quantity, and the physical form of the chemical
manufactured or imported, and the number of workers reasonably likely to be exposed during
manufacture of the chemical. For chemicals manufactured or imported in quantities of 300,000 pounds or
more at a single site, additional reported information includes: the industrial processing and uses of the
chemical; the number of industrial processing sites and workers reasonably likely to be exposed to the
chemical at those sites; the consumer and commercial uses of the chemical; and an indication whether the
chemical was used in products intended for use by children under 14 years of age.

EPA's screening-level exposure characterizations are based largely on the information submitted under
the IUR reporting, although other exposure information submitted to the Agency (for example, in HPV
submissions) or readily available through a limited set of publicly accessible databases10 was also
considered. The screening-level exposure characterizations identify a potential (high, medium, or low)
that each of five populations - the environment, the general population, workers, consumers, and children
- might be exposed to the chemical In most cases, this potential doesn't address the quantity, frequency,
or duration of exposure, but refers only to the likelihood that an exposure could occur.

In many instances EPA is not able to fully disclose to the public all the IUR exposure-related data
reviewed or relied upon in the development of the screening-level documents because some of the
material was claimed as confidential business information (CBI) when it was submitted to the Agency.
These CBI claims do limit the Agency's ability to be completely transparent in presenting some
underlying exposure and use data for chemicals in public documents. EPA does consider all data,
including data considered to be CBI, in the screening-level exposure and risk characterization process,
and endeavors whenever possible to broadly characterize supporting materials claimed as confidential in
ways that do not disclose actual CBI.

Risk Characterizations for HPV Chemicals

EPA combines the information from the screening-level exposure characterization with the screening-
level hazard characterization to develop a qualitative screening-level risk characterization, as described in
the Agency's guidance on drafting risk characterizations11. These screening-level risk characterizations
are technical documents intended to support subsequent priority-setting decisions and actions by OPPT.
The purpose of the qualitative screening-level risk characterization is two-fold: to support initial risk-
based decisions to prioritize chemicals, identify potential concerns, and inform risk management options;
and to identify data needs for individual chemicals or chemical categories.

These initial characterization and prioritization documents do not constitute a final Agency determination
as to risk, nor do they determine whether sufficient data are available to characterize risk. Recommended
actions reflect EPA's relative judgment regarding this chemical or chemical category in comparison with
others evaluated under this program, as well as the uncertainties presented by gaps that may exist in the
available data.

10	U.S. EPA - Summary of Public Databases Routinely Searched:
http: //www. ep a. go v/chemrtk/hp vis/pubdt sum. htm.

11	U.S. EPA - Risk Characterization Program: http://www.epa.gov/osa/spc/2riskchr.htm.

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QUALITATIVE SCREENING-LEVEL RISK CHARACTERIZATION
OF HIGH PRODUCTION VOLUME CHEMICALS

SPONSORED CHEMICAL

Cyclohexanone, Oxime (CAS No. 100-64-1)
[9th CI Name: Cyclohexanone, Oxime]

September 2008

Prepared by

Risk Assessment Division
Economics, Exposure and Technology Division
Office of Pollution Prevention and Toxics
Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460-0001

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Supporting Documents for Risk-Based Prioritization

September 2008

QUALITATIVE SCREENING-LEVEL RISK CHARACTERIZATION FOR
Cyclohexanone, Oxime (CAS No. 100-64-1)

1.	Physical-Chemical Properties and Environmental Fate

Cyclohexanone, oxime is a white, crystalline solid at room temperature. It has high water
solubility and moderate vapor pressure. It has moderate mobility in soil. Volatilization is
considered moderate based on its Henry's Law constant. Cyclohexanone, oxime is stable to
hydrolysis. In the atmosphere it is degraded by photochemically generated hydroxyl radicals at a
rate that is considered moderate. No data were provided for the biodegradation of
cyclohexanone, oxime. EPA estimates that the aerobic degradation half-life is on the order of
weeks and also estimates a bioconcentration factor of 3. Thus, cyclohexanone, oxime is
expected to have low persistence (PI) and low bioaccumulation potential (Bl).

2.	Hazard Characterization

Aquatic Organism Toxicity. The acute toxicity of cyclohexanone, oxime to fish is low. No data
were submitted by the sponsor for the acute toxicity of cyclohexanone, oxime to either aquatic
invertebrates or aquatic plants.

Human Health Toxicity. The acute oral toxicity of cyclohexanone, oxime to rats and the acute
dermal toxicity to rabbits are low. Repeated-dose and reproductive data were not required for
the HPV Challenge Program because cyclohexanone, oxime is a closed-system intermediate.
However, an oral repeated-dose toxicity study of cyclohexanone, oxime in rats was submitted
and showed high systemic toxicity. A repeated-dose toxicity study with mice exposed to
cyclohexanone, oxime via drinking water showed low systemic toxicity. A prenatal
developmental toxicity study of cyclohexanone (CAS No. 108-94-1), a major metabolite of
cyclohexanone,oxime, showed low maternal and developmental toxicity in rats. Cyclohexanone,
oxime induced gene mutations and gave an equivocal response for chromosomal aberrations in
vitro. However, it did not induce chromosomal aberrations in vivo.

3.	Exposure Characterization

Cyclohexanone, oxime (CAS No. 100-64-1) has an aggregated production and/or import volume
in the United States of 100 million to 500 million pounds. IUR information for this chemical
indicates that it is used as an industrial intermediate in the manufacturing of other basic organic
compounds. No commercial use is reported in the IUR submissions or other data sources.

Potential for Exposures to Humans and the Environment: Based on the information considered,
including IUR data and information from the HPV Challenge Program, and in combination with
the Agency's professional judgment, EPA identifies, for the purposes of risk-based prioritization,
a low relative ranking for each of the potentially exposed groups (including workers, general
population, consumers and children) and the environment. Persistence and bioaccumulation
ratings for this chemical are PI and Bl, respectively. The Pl/Bl rating suggests that the
chemical is not persistent and is not bioaccumulative. The Agency has reviewed the information
in the HPV submission and determined that the HPV chemical satisfies the guidance to

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demonstrate that the chemical is a closed system intermediate. The chemical is manufactured
and processed in systems that are expected to reduce the potential for worker exposure and
environmental releases that could lead to other human and environmental exposure. The
guidance for identifying this chemical substance as a closed-system intermediate was satisfied at
all sites reporting the chemical in accordance with IUR requirements.

4. Risk Characterization

The statements and rationale provided below are intended solely for the purpose of this
screening-level and qualitative risk characterization and will be used for prioritizing substances
for future work in the Chemical Assessment and Management Program (ChAMP).

Risk Statement and Rationale

The Agency has reviewed the information in the HPV submission or test plan and determined
that the HPV chemical satisfies the guidance to demonstrate that the chemical is a closed system
intermediate. Cyclohexanone, oxime is manufactured and processed in closed systems that are
expected to reduce the potential for worker exposure and environmental releases that could lead
to other human and environmental exposure. The guidance for identifying this chemical
substance as a closed-system intermediate was satisfied at all sites reporting the chemical in
accordance with IUR requirements. Therefore, there is low concern for potential risks to aquatic
organisms and the general population from environmental releases, and also to workers,
consumers, and children.

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U.S. Environmental Protection Agency
Supporting Documents for Risk-Based Prioritization

September 2008

SCREENING-LEVEL HAZARD CHARACTERIZATION
OF HIGH PRODUCTION VOLUME CHEMICALS

SPONSORED CHEMICAL

Cyclohexanone, Oxime (CAS No. 100-64-1)
[9th CI Name: Cyclohexanone, oxime]

September 2008

Prepared by

Risk Assessment Division
Economics, Exposure and Technology Division
Office of Pollution Prevention and Toxics
Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460-0001

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Supporting Documents for Risk-Based Prioritization

September 2008

SCREENING-LEVEL HAZARD CHARACTERIZATION
Cyclohexanone, Oxime (CAS No. 100-64-1)

Introduction

The sponsor, DSM Chemicals North America, Inc., submitted a Test Plan and Robust Summaries to EPA for
cyclohexanone, oxime (CAS No. 100-64-1; 9th CI name: cyclohexanone, oxime) on March 10, 2006. EPA posted
the submission on the ChemRTK HPV Challenge website on March 21, 2006

fhttp://www.epa.gov/chemrtk/pubs/summaries/cvcloxim/cl6215tc.htm'). EPA comments on the original submission
were posted to the website on November 14, 2007. Public comments were also received and posted to the website.

This screening level hazard characterization is based primarily on the review of the test plan and robust summaries
of studies submitted by the sponsor(s) under the HPV Challenge Program. 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 2005 to May 2008: the NLM databases (ChemID to locate available data sources including Medline/PubMed,
Toxline, HSDB, IRIS, NTP, AT SDR, EXTOXNET, EPA SRS, etc.), STN/CAS online databases (Registry file for
locators, ChemAbs for toxicology data, RTECS, Merck, etc.) and Science Direct. A summary table of SIDS
endpoint data with the structure(s) of the sponsored chemical(s) is included in the appendix. The screening-level
hazard characterization for environmental and human health effects is based largely on SIDS endpoints and is
described according to established EPA or OECD effect level definitions and hazard assessment practices.

The sponsor proposed reduced health effects testing claiming that cyclohexanone oxime is a closed-system
intermediate (CSI). EPA's evaluation of the original information indicated that the chemical meets the guidance to
support the CSI claim for this chemical. Cyclohexanone oxime is produced at a single site, is consumed in the in-
process reaction to make another substance and there are no offsite shipments. Therefore, EPA has determined that
the chemical qualifies for reduced testing and waiving of repeated-dose and reproductive toxicity testing for the
purposes of the HPV Challenge Program.

The sponsor did not submit data for the developmental toxicity endpoint but indicated in the test plan that a
developmental toxicity study following the OECD guidelines would be conducted. However, based on the rapid
metabolism of cyclohexanone, oxime in the mammalian system, EPA considered developmental toxicity data for
cyclohexanone (CAS No. 108-94-1), a metabolite of cyclohexanone, oxime, adequate for addressing the
developmental toxicity endpoint for the purposes of the HPV Challenge Program. These data are summarized in the
Developmental Toxicity section. Cyclohexanone has been assessed in the OECD HPV program and the published
data can be viewed at the following link: http://www.chem.unep.ch/irptc/sids/OECDSIDS/sidspub.html.

Iln/nnl C'hiiriK'U'ri/iilion

Cyclohexanone, oxime is a white, crystalline solid at room temperature. It has high water solubility and moderate
vapor pressure. It has moderate mobility in soil. Volatilization is considered moderate based on its I Ienrv's Law
constant. Cyclohexanone, oxime is stable to hydrolysis. In the atmosphere it is degraded by photochemieally
generated hydroxy 1 radicals at a rate that is considered moderate. No data were provided for the biodegradation of
cyclohexanone. oxime. IT'A estimates that the aerobic degradation half-life is on the order of w eeks and also
estimates a bioeoneenlration factor of 3. Thus, cyclohexanone, oxime is expected to have low persistence (P1) and
low bioaceumulation potential (HI).

The acute toxicity of cyclohexanone. oxime to fish is low.

The acute oral toxicity of cyclohexanone. oxime to rats and the acute dermal toxicity to rabbits are low. Repeated-
dose and reproductive data were not required for the IIPV Challenge Program because cyclohexanone. oxime is a
closed-system intermediate. I low ever, an oral repeated-dose toxicity study of cyclohexanone, oxime in rats w as
submitted and showed high systemic toxicity. A repeated-dose toxicity study with mice exposed to cyclohexanone
oxime via drinking water showed low systemic toxicity. A prenatal developmental toxicity studv ol'cvclohcxanone

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(CAS No. 108-94-1), a major metabolite of cyclohexanone,oxime, showed low maternal and developmental toxicity
in rats. Cyclohexanone, oxime induced gene mutations but gave an equivocal response for chromosomal aberrations
in vitro. However, it did not induce chromosomal aberrations in vivo.

Hydrolysis, ready biodegradation and acute toxicity for aquatic invertebrates and aquatic plants endpoints were
identified as data gaps under the HPV Challenge Program.

1. Phvsical-Chemical Properties and Environmental Fate

The physical-chemical properties of cyclohexanone, oxime are summarized in Table la, while the environmental
fate properties are given in Table lb. Its structure is provided in the Appendix.

Physical-Chemical Properties Characterization

Cyclohexanone, oxime is a white, crystalline solid at room temperature. It has high water solubility and moderate
vapor pressure.

Table la. Phvsical-Chemical Properties of Cvclohcxanonc, Oxime1

Property

Value

CAS No.

100-64-1

Molecular Weight

118.15

Physical State

White, crystalline solid

Melting Point

88-91°C (measured)

Boiling Point

208 °C (measured)

Vapor Pressure

0.029 mm Hg at 25°C (measured)2

Water Solubility

15,000 mg/L at 20°C (measured)2

Henry's Law Constant

8x10"^ atm-ffiVmole (estimated)2

Log Kow

0.84 (measured)2

'DMS Chemicals North America Inc. 2006. Robust Summary and Test Plan for Cyclohexanone, oxime :
httD://www.eDa.£ov/chemrtk/Dubs/summaries/cvcloxim/cl 6215tc.htm

9 TM

US EPA. 2008. Estimation Programs Interface Suite for Microsoft® Windows, v 3.20. United States
Environmental Protection Agency, Washington, DC, USA:
htto: //www .eoa.eov/oootintr/exoo sure/oub s/eoi suite. htm

Environmental Fate Characterization

Cyclohexanone, oxime is expected to partition primarily to soil and water, according to the results of a Level III
fugacity model that assumes equal emissions to air, water, and soil. In the atmosphere, cyclohexanone, oxime is not
expected to undergo hydrolysis and degraded by photochemically generated hydroxyl radicals at a rate that is
considered moderate. Volatilization of cyclohexanone, oxime is considered moderate based on its Henry's Law
constant. It has moderate mobility in soil and its bioaccumulation potential is ranked low (Bl) based on an
estimated BCF of 3. No biodegradation data are available for cyclohexanone, oxime. EPA estimates that aerobic
biodegradation half-life is several weeks (PI).

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Table lb. Environmental Fate Characteristics of Cyclohexanone, Oxime1

Property

Value

Photodegradation Half -life

1.5 days2

Hydrolysis Half-life

Data Gap; Stable (estimated by EPA)2

Biodegradation

Data Gap; Half-life = weeks (estimated by EPA)2

Bioconcentration

BCF = 3 (estimated)2

Log Koc

2.7 (estimated)2

Fugacity

(Level III Model)2

Air = 2%

Water = 41%

Soil = 56.8%
Sediment = 0.1%

•j

Persistence

PI (low)

Bioaccumulation3

Bl (low)

http://www.epa.gov/chemrtk/pubs/summaries/cvcloxim/cl6215tc.htm

2US EPA. 2008. Estimation Programs Interface Suite™ for Microsoft® Windows, v 3.20. United States
Environmental Protection Agency, Washington, DC, USA:
http: //www .epa.gov/opptintr/expo sure/pub s/epi suite. htm

3Federal Register. 1999. Category for Persistent, Bioaccumulative, and Toxic New Chemical Substances.
Federal Register 64, Number 213 (November 4, 1999) pp. 60194-60204.

Conclusion: Cyclohexanone, oxime is a white, crystalline solid at room temperature. It has high water solubility
and moderate vapor pressure. It has moderate mobility in soil. Volatilization is considered moderate based on its
Henry's Law constant. Cyclohexanone, oxime is stable to hydrolysis. In the atmosphere it is degraded by
photochemically generated hydroxyl radicals at a rate that is considered moderate. No data were provided for the
biodegradation of cyclohexanone, oxime. EPA estimates that aerobic degradation half-life is on the order of weeks
and also estimates a bioconcentration factor of 3. Cyclohexanone, oxime is expected to have low persistence low
persistence (PI) and low bioaccumulation potential (Bl).

2. Environmental Effects - Aquatic Toxicity

Acute Toxicity to Fish

The sponsor stated in the Revised Test Plan that study details were not available for the fathead minnow study
provided in their robust summary and therefore proposed to conduct an acute toxicity study for fish. EPA has
located the details of the fathead minnow study in EPA's ECOTOX database (www.epa. gov/ecotox) and in the
reference cited by the sponsor, deemed the study adequate and used it in this hazard characterization.

Fathead minnows (Pimephales promelas) were exposed to nominal concentrations of cyclohexanone, oxime of 72.8,
112, 172, 265 and 408 mg/L under flow-through conditions for 96 hours. Measured concentrations were 72.1, 102,
153, 236 and 374 mg/L.

96-h LCso = 208 mg/L

Acute Toxicity to Aquatic Invertebrates

Data gap

Toxicity to Aquatic Plants

Data gap

Conclusion: The acute toxicity of cyclohexanone, oxime to fish is low. Acute toxicity to aquatic invertebrates and
aquatic plants endpoints were identified as data gaps under the HPV Challenge Program.

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3. Human Health Effects
Acute Oral Toxicity

Fischer 344 rats (10/sex/dose) were administered cyclohexanone, oxime via gavage to seven doses (males, ranging
from 562 to 5000 mg/kg-bw) or five doses (females, ranging from 398 to 5000 mg/kg-bw). All animals were
observed for 14 days. The control group received distilled water.

LD50 = 1765 mg/kg-bw (males) and 883 mg/kg-bw (females)

Acute Dermal Toxicity

New Zealand white rabbits (5/sex/dose) were administered cyclohexanone, oxime dermally at 0 (distilled water
control), 800, 2000 or 5000 mg/kg -bw under occluded conditions for 24 hours and observed for 14 days. No
mortalities, clinical signs, changes in body or organ weights, or gross pathology were observed. Hematological
effects included elevated reticulocyte counts in males decreased hemoglobin values in high-dose females and
increased methemoglobin levels in males and females.

LD50 > 5000 mg/kg-bw

Repeated-Dose Toxicity

Although cyclohexanone, oxime is a CSI, the sponsor submitted data for the repeated-dose toxicity endpoint that are
summarized below and are used in this hazard characterization.

(1)	Fischer 344 rats were administered cyclohexanone, oxime via gavage at 0, 0.25, 2.5 or 25 mg/kg-bw/day, 5
days/week for 30 days (10/sex/dose), 60 days (10/sex/dose) or 90 days (20/sex/dose). No compound-related
mortality was noted. Clinical signs of toxicity occurred in males during the first 9 weeks and included red nasal
discharge at the high dose, chromodacryorrhea and swollen conjunctiva at the mid- and high dose and corneal
opacity at all dose levels. Clinical signs of toxicity occurred in females after 2 weeks and included
chromodacryorrhea at the high dose and corneal opacity at the mid - and high dose. No exposure-related effects
were noted for body weight, food consumption, urinalysis, neurobehavioral effects or clinical chemistry. A small
but progressive decrease in erythrocytes, hematocrit and total hemoglobin with time was seen in both sexes at the
high dose. A statistically significant increase in circulating reticulocytes at all doses demonstrated a dose response.
Increases in the degree of anisocytosis, poikilocytosis and polychromasia were evident and leukocyte and platelet
counts were also elevated at the high dose. Spleen weights were increased in males and females at the high dose.
Histopathological examination at 90 days revealed a progressive increase in splenic hemosiderin deposition and
hematopoiesis in the bone marrow and spleen at all doses. Liver and kidney weights were higher in the high-dose
females.

LOAEL = 0.25 mg/kg-bw/day (based on blood effects in bone marrow and spleen)

NOAEL = Not established

(2)	In a National Toxicology Program (NTP) study, B6C3F1 mice (10/sex/dose) were administered cyclohexanone,
oxime in drinking water at 0, 635, 1200, 2500, 5000, or 10,000ppm (-127, 240, 500, 1000 or 2000 mg/kg-bw/day)
for 90 days. Mortality was observed in the 10,000 ppm. Decreased body weight gain was noted at 5000 ppm in
females and 10,000 ppm in males and females. Increased absolute and/or relative spleen weights at 5000 and 10,000
ppm and increased absolute and relative liver weight at 10,000 ppm were seen. Histopathological examination
revealed hematopoietic cell proliferation in the spleen at 5000 and 10,000 ppm, hypertrophy of centrilobular
hepatocytes at 2500, 5000 and 10,000 ppm in males and at 5000 and 10,000 in females and olfactory epithelial
degeneration at all doses. No treatment-related effects were noted for clinical signs of toxicity, water consumption,
sperm motility or vaginal cytology parameters.

LOAEL = 500 mg/kg-bw/day (based on histopathological effects on the liver)

NOAEL = 240 mg/kg-bw/day

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Reproductive Toxicity

No data were submitted for this endpoint. The sponsor proposed reduced health effects testing claiming that
cyclohexanone, oxime is a CSI. EPA's evaluation of the original information indicated that the chemical meets the
guidance to support the CSI claim for this chemical. Therefore, testing for the reproductive toxicity endpoint is
waived for the purposes of the HP V Challenge Program.

Developmental Toxicity

Cyclohexanone (CAS No. 108-94-1, Metabolite of Cyclohexanone, oxime)

Pregnant Sprague-Dawley rats (23-24/dose) were exposed to cyclohexanone vapor via inhalation (whole -body) at 0,
300, 650, and 1400 ppm (~1.2, 2.6 and 5.6 mg/L) for 6 hours/day during days 6 to 19 of gestation with a necropsy
on day 20. Clinical signs included lacrimation at highest concentration with increased incidence and severity over
the course of the study. Nasal discharge, lethargy and vaginal discharge were also seen at this concentration in
several females. Observations of startle responses followed concentration and time related patterns. At 300 ppm
there were a few instances of sluggish responses. At 650 ppm, the incidence was higher and at 1400 ppm, there was
a high incidence of lethargy and many rats were essentially non-responsive for the duration of daily exposure. No
females aborted or delivered prematurely. Maternal body weight was markedly decreased (approximately 33-44%
less than the controls) at 1400 ppm. No significant differences were noted in the numbers of corpora lutea,
implantation sites, pups and resorptions or the sex ratio. Reduction in mean body weights of pups of both sexes
were noted at 1400 ppm. A slight distention of the renal pelvis was present at low incidence at 650 and 1400 ppm.
There was an increase in the incidence of generalized retardation of ossification at 1400 ppm; these include:
incomplete ossification of the cranial bones and/or ossification irregularities of the hyoid, incomplete or unossified
sternebrae and unossified metatarsals and forelimb phalanges.

LOAEL (maternal toxicity) = 5.6 mg/L/day (based on reduction in body weight and severe lethargy)

NOAEL (maternal toxicity) = 2.6 mg/L/day

LOAEL (developmental toxicity) = 5.6 mg/L/day (based on reduction in fetal body weight and increased
incidence of variation in and retardation of ossification)

NOAEL (developmental toxicity) = 2.6 mg/L/day

Genetic Toxicity - Gene Mutation

In vitro

In an NTP study, Salmonella typhimurium strains TA97, TA98, TA100 and TA1535 were exposed to
cyclohexanone, oxime up to 6666 (ig/plate in the presence and absence of metabolic activation. Positive and
negative controls produced appropriate responses. The cytotoxic concentration was > 3333 (ig/plate in the presence
of metabolic activation and > 6666 (ig/plate in the absence of metabolic activation. Mutagenicity was observed in
TA1535 in the presence of metabolic activation.

Cyclohexanone, oxime was mutagenic in this assay.

Genetic Toxicity - Chromosomal Aberrations
In vitro

In an NTP study, Chinese hamster ovary (CHO) cells were administered cyclohexanone, oxime at 500 - 5000
Hg/mL in the presence and absence of metabolic activation. Solvent and positive controls produced appropriate
responses. The cytotoxic concentration was > 5000 (ig/mL. In each of two trials, significant increase in aberrations
was observed at one of three doses in the absence of metabolic activation. No induction of aberrations was seen in
the presence of metabolic activation. The results were equivocal.

Cyclohexanone, oxime produced an equivocal response in this assay.

In vivo

(1) In an NTP study, B6C3F1 mice (5/sex/dose) were administered cyclohexanone, oxime in drinking water at 0,
625, 1250, 2500, 5000 or 10,000 ppm (approximately 127, 240, 500, 1000 or 2000 mg/kg-bw/day)for 90 days.
Peripheral blood normochromatic erythrocytes were scored for micronuclei. No information on the use or response
of positive controls was provided.

Cyclohexanone, oxime did not induce formation of micronuclei in this assay.

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September 2008

(2) In an NTP study, B6C3F1 mice (5/sex/dose) were administered cyclohexanone, oxime in corn oil via
intraperitoneal injection at 0, 400, 600, 800 or 1000 mg/kg-bw for 24 hours intervals over 3 days. Twenty-four
hours after the third injection, mice were sacrificed and smears of bone marrow cells were prepared to determine the
frequency of micronucleated polychromatic erythrocytes. Solvent and positive controls responded appropriately.
Cyclohexanone, oxime did not induce formation of micronuclei in this assay.

Additional Information
Metabolism

Cyclohexanone, oxime was found to be rapidly absorbed and cleared from the body within 24 hours after a single
oral administration of 1, 10 and 30 mg/kg-bw of 14C- cyclohexanone, oxime to the adult male F 344 rats. The
majority of 14C- cyclohexanone, oxime derived radioactivity (65-90% of the dose) was excreted in the urine.
Elimination in the feces accounted for 5-10% of the dose and very low levels (2-3% of the dose) were retained in the
tissues 24 hours after exposure. After intravenous administration of 1 mg/kg of 14C- cyclohexanone, oxime, it was
rapidly cleared from plasma with half -lives of 1.6 to 18.2 minutes. However when applied dermally at 30 mg/kg,
only 4-5% of the dose was recovered in urine, feces and the tissues. The majority of the dose volatilized from the
skin surface. However, the absorbed oxime was readily distributed and excreted and its metabolic fate was no
different when observed after oral administration. HPLC analysis of urine showed that the majority of the
radioactivity excreted was in the form of three metabolites, cyclohexaglucuronide and monoglucuronides of cis and
trans cyclohexane-1,2-diol. In vitro studies showed that these metabolites arise primarily by hydrolysis of the
oxime to cyclohexanone, which is then reduced to cyclohexanol and eliminated as the glucuronide conjugate. The
cyclohexanol in turn could be metabolized to cis and trans-cyclohexane-l,2-diols, which are excreted as their
mono glucuronide s.

(Parmar, D and Burka, L, Metabolism of cyclohexanone, oxime in male F-344 rats, Cyclohexanone, oxime, NTP
Toxicity Report Number 50).

Note: Although the main focus of the NTP study described above was metabolism of cyclohexanone, oxime and
further transformation of cyclohexanone, hydroxylamine is also formed simultaneously as a major metabolite during
the metabolism of cyclohexanone, oxime.

Conclusion: The acute oral toxicity of cyclohexanone, oxime to rats and the acute dermal toxicity to rabbits are
low. Repeated-dose and reproductive data were not required for the HPV Challenge Program because
cyclohexanone, oxime is a closed-system intermediate. An oral repeated-dose toxicity study of cyclohexanone,
oxime in rats showed high systemic toxicity. However, a repeated-dose toxic ity study of mice exposed to
cyclohexanone oxime via drinking water showed low systemic toxicity. A prenatal developmental toxicity study of
cyclohexanone (CAS No. 108-94-1), a major metabolite of cyclohexanone,oxime, showed low maternal and
developmental toxicity in rats. Cyclohexanone, oxime induced gene mutations and gave an equivocal response for
chromosomal aberrations in vitro. However, it did not induce chromosomal aberrations in vivo.

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U.S. Environmental Protection Agency
Supporting Documents for Risk-Based Prioritization

September 2008

APPENDIX

Summary Table of the Screening Information Data Set
as Submitted under the U.S. HPV Challenge Program

Endpoints

SPONSORED CHEMICAL
Cyclohexanone oxime
(100-64-1)

METABOLITE
Cyclohexanone
(108-94-1)

Structure

/OH

N

X

X

Summary of Environmental Effects-Aquatic Toxicity Data



Fish

96-h LC50 (mg/L)

208

	*

Aquatic Invertebrates
48-h ECS0 (mg/L)

Data gap

	*

Aquatic Plants
72-h EQ0 (mg/L)

Data gap

	*

Summary of Human Health Data

Acute Oral Toxicity
LD50 (mg/kg-bw)

1765 (males)
833 (females)

	*

Acute Dermal Toxicity
LD50 (mg/kg-bw)

> 5000

	*

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

NOAEL = Not established
LOAEL = 0.25

	*

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

Parental Systemic and Reproductive Toxicity

Endpoint waived because the chemical is a
closed system intermediate.

	*

Developmental Toxicity
NOAEL/LOAEL
Oral (mg/L)

Maternal and Developmental Toxicity

No Data
NOAEL = 2.6
LOAEL = 5.6
(RA)

NOAEL = 2.6
LOAEL = 5.6

Genetic Toxicity- Gene Mutation
In vitro

Positive

	*

Genetic Toxicity- Chromosomal Aberrations
In vitro

Negative

	*

Genetic Toxicity- Chromosomal Aberrations
In vivo

Negative

	*

- indicates that endpoint was not addressed for this chemical; * indicates endpoint not necessary for supporting chemical.


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U.S. Environmental Protection Agency
Supporting Documents for Risk-Based Prioritization

September 2008

Screening Level Exposure Characterization for HPV Challenge

Chemical

Cyclohexanone, Oxime

CAS # 100-64-1

September 2008

Prepared by

Exposure Assessment Branch
Chemical Engineering Branch
Economics, Exposure and Technology Division
Office of Pollution Prevention and Toxics
Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460-0001

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U.S. Environmental Protection Agency
Supporting Documents for Risk-Based Prioritization

September 2008

Screening Level Exposure Characterization

Cyclohexanone, oxime (CAS # 100-64-1)

Non-CBI Executive Summary

Cyclohexanone, oxime (CAS # 100-64-1) has an aggregated production and/or import volume in
the United States of 100 million to 500 million pounds.12 Non-confidential information in the
Inventory Update Reporting (IUR) indicates that this chemical was manufactured and/or
imported at the following companies and sites: DSM Chemicals/ Augusta, GA. Non-
confidential IUR information for this chemical indicates that it is used as an industrial
intermediate. No commercial use is reported in the IUR submissions or other data sources.
Information submitted as part of the High Production Volume (HPV) Challenge Program
indicates that 3- cyclohexanone, oxime is used in the chemical industry for synthesis of
caprolactam, which is used to produce polycaprolactam fibers and resins.13

Potential for Exposures to Humans and the Environment:

Based on the information considered, including IUR data and information from the HPV
Challenge Program information cited above, and in combination with Agency's professional
judgment, EPA identifies, for the purposes of risk-based prioritization, a low relative ranking for
each of the potentially exposed groups (including workers, general population, consumers and
children) and the environment. Persistence and bioaccumulation ratings for this chemical are PI
and Bl. 4 The Pl/Bl rating suggests that the chemical is not persistent and is not
bioaccumulative. The Agency has reviewed the information in the HPV submission or test plan
and determined that the HPV chemical satisfies the guidance to demonstrate that the chemical is
a closed system intermediate.15 The chemical is manufactured and processed in systems that are
expected to reduce the potential for worker exposure and environmental releases that could lead
to other human and environmental exposure. The guidance for identifying this chemical
substance as a closed-system intermediate was satisfied at all sites reporting the chemical in
accordance with IUR requirements.

12	USEPA, 2006. Partial Updating of TSCA Chemical Inventory.

13	DSM, 2006. High Production Volume Test Plan for Cyclohexanone Oxime. Submitted by DSM Chemicals.
Dated March 2006. http://www.epa.gov/chemrtk/pubs/summaries/cvcloxim/cl6215tc.htm Accessed May 22,
2008.

14	USEPA, 2008. Screening Level Hazard Characterization for High Production Volume Chemicals,
Cyclohexanone, Oxime.

1 USEPA, 2007. EPA Comments on Chemical RTK HPV Challenge Submission. Letter dated November, 2007.
http://www.epa.gov/chemrtk/pubs/summaries/cvcloxim/cl6215ct.pdf. Accessed June 20, 2008. Accessed June 20,
2008.

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U.S. Environmental Protection Agency
Supporting Documents for Risk-Based Prioritization

September 2008

Non Confidential IUR Data Summary Cyclohexanone, oxime (CAS # 100-64-1)

Manufacturing/Import Information

Production and import volume:

List of non-CBI companies/sites:
Maximum number of exposed workers:

Highest non-CBI maximum concentration:
Non-CBI physical forms:

100 million to 500 million pounds

DSM Chemicals /Augusta, GA*

less than 100 (including those of manufacturing,

industrial processing and use) **

greater than 90%*

liquid*

* There may be other companies/sites, concentrations and physical forms that are claimed
confidential.

** There may be additional potentially exposed industrial workers that are not included in this
estimate since not all submitters were required to report on industrial processing and use and/or
there may be at least one use that contains a "Not Readily Obtainable" (NRO) response among
the submissions.



Table 1



Industrial Processing and I se Information



Reported in 2006 Il k



Processing Activity

Industrial Sector

Functional Use

Processing as a reactant

Other Basic Organic Chemical

Intermediates



Manufacturing





Table 2





C ommercial/ C onsumer I scs



Reported in 2006 Il k



Commercial/ Consumer

Highest maximum concentration

Use in Children's Products

Product Category Description

range



None reported

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