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

6-terf-Butyl-3-(chloromethyl)-2,4-xylenol (CASRN 23500-79-0)
(CA Index Name: Phenol, 3-(chloromethyl)-6-(l,l-dimethylethyl)-2,4-dimethyl-)

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


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

September 2008

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 (ChAMP)2. 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 Program3.
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.epa.gov/hpv/pubs/general/sppframework.htm.

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

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

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.epa.gov/ncea/raf/rafguid.cfm.

8	U.S. EPA - About HPV Chemical Hazard Characterizations: http://www.epa.gov/hpvis/abouthc.htm.

9	U.S. EPA - Basic IUR Information: http://www.epa.gov/opptintr/iur/pubs/guidance/basic-infonnation.h1m.

2


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

September 2008

(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.epa.gov/chemrtk/hpvis/pubdtsum.htm.

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

3


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

September 2008

QUALITATIVE SCREENING-LEVEL RISK CHARACTERIZATION
OF HIGH PRODUCTION VOLUME CHEMICALS

SPONSORED CHEMICAL

6-ferf-Butyl-3-(chloromethyl)-2,4-xylenol (CAS No. 23500-79-0)
[9th CI Name: 6-ferf-Butyl-3-(chloromethyl)-2,4-xylenol]

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

4


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

September 2008

QUALITATIVE SCREENING-LEVEL RISK CHARACTERIZATION FOR
6-terf-Butyl-3-(chloromethyl)-2,4-xylenol (CAS No. 23500-79-0)

1.	Physical-Chemical Properties and Environmental Fate

6-fert-Butyl-3-(chloromethyl)-2,4-xylenol is a solid at room temperature and has a moderate
vapor pressure. The water solubility of 6-/t'/7-butyl-3-(chloromethyl)-2,4-xylenol cannot be
accurately measured because the compound is unstable in water. It is expected to be minimally
mobile in soil. 6-fert-Butyl-3-(chloromethyl)-2,4-xylenol is considered to have low-to-moderate
volatility from moist soil and water given its Henry's Law constant; however, the rapid rate of
hydrolysis suggests volatilization is not an important environmental fate process. Its rate of
hydrolysis is considered rapid under environmental conditions (pH 5-9). The rate of vapor-phase
photooxidation in the ambient atmosphere is moderate. Its rate of biodegradation was low based
on the results of a ready biodegradation test; however, this study likely measured the rate of
biodegradation of the hydrolysis products not 6-/t77-butyl-3-(chloromethyl)-2,4-xylenol. Due to
the rapid rate of hydrolysis, 6-fe/V-butyl-3-(chloromethyl)-2,4-xylenol is judged to have low
persistence potential (PI) and low bioaccumulation potential (Bl).

2.	Hazard Characterization

Aquatic Organism Toxicity. The acute toxicity of 6-fert-butyl-3-(chloromethyl)-2,4-xylenol to
fish and aquatic invertebrates is low and to aquatic plants is moderate.

Human Health Toxicity. Acute oral and dermal toxicity of 6-fert-butyl-3-(chloromethyl)-2,4-
xylenol is low in rats and rabbits, respectively. 6-fert-Butyl-3-(chloromethyl)-2,4-xylenol is
highly irritating to rabbit skin and eyes. A combined oral repeated-

dose/reproductive/developmental toxicity study in rats showed high systemic and reproductive
toxicity in the parental females. There was no developmental toxicity. 6-fe/V-Butyl-3-
(chloromethyl)-2,4-xylenol did not induce gene mutation in bacteria. Chromosomal aberrations
were observed in vitro, but not in vivo.

3.	Exposure Characterization

Phenol, 6-/£/7-butyl-3-(chlorom ethyl )-2, 4-dimethyl-, also known as 6-fert-butyl-3-
(chloromethyl)-2,4-xylenol, has an aggregated production and/or import volume in the United
States of > 1 million to 10 million pounds. Non-confidential Inventory Update Rule (IUR)
information for this chemical indicates that it is used as an intermediate. No commercial/
consumer uses were reported in the IUR submissions or in the Hazardous Substances Data Bank.
Information submitted as part of the High Production Volume (HPV) Challenge Program
indicates that phenol, 6-fe/V-buty 1-3-(chlorornethyl)-2, 4-dimethyl- is used in the chemical
industry for synthesis.

5


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

September 2008

Potential for Exposures to Human 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 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. The Agency has reviewed the information in the HPV
submission or test plan and determined that the information satisfies the guidance to 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 this 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 Challenge Program submission or test
plan and determined that the HPV chemical satisfies the guidance to demonstrate that the
chemical is a closed-system intermediate (CSI). 6-/f/7-Butyl-3-(chloroinethyl)-2,4-xylenol 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 this chemical in accordance with IUR requirements.

Therefore, there is a low concern for potential risks to aquatic organisms and the general
population from environmental releases, and also to workers, consumers, and children.

6


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

September 2008

SCREENING-LEVEL HAZARD CHARACTERIZATION
OF HIGH PRODUCTION VOLUME CHEMICALS

SPONSORED CHEMICAL

6-ferf-Butyl-3-(chloromethyl)-2,4-xylenol (CAS No. 23500-79-0)
[9th CI Name: Phenol, 3-(chloromethyl)-6-(l,l-dimethylethyl)-2,4-dimethyl-]

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

7


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

September 2008

SCREENING-LEVEL HAZARD CHARACTERIZATION
6-ferf-Butyl-3-(chloromethyl)-2,4-xylenol (CAS No. 23500-79-0)

Introduction

The sponsor, Cytec Industries Inc., submitted a Test Plan and Robust Summaries to EPA for 6-fcrt-butyl-
3-(chloromethyl)-2,4-xylenol (CAS No. 23500-79-0; 9th CI name: phenol, 3-(chloromethyl)-6-(l,l-dimethylethyl)-
2,4-dimethyl-) on May 30, 2003. EPA posted the submission on the ChemRTK HPV Challenge Web site on July 8,
2003 (http://www.epa.gov/chemrtk/pubs/summaries/6tbutvl3/cl4526tc.htm). EPA comments on the original
submission were posted to the website on November 14, 2003. Public comments were also received and posted to
the website. The sponsor submitted updated/revised documents on November 25, 2003 and February 28, 2005,
which were posted to the ChemRTK website on January 13, 2004 and May 10, 2005, respectively.

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 2003 to May 2008: the NLM databases (ChemID to locate available data sources including Medline/PubMed,
Toxline, HSDB, IRIS, NTP, ATSDR, 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 stated that 6-tert-butyl-3-(chloromethyl)-2,4-xylenol is a commercially-isolated material that contains
11 - 13% methyl isobutyl ketone and 5.5% 6-terf-butyl-2,4-dimethyl phenol. The sponsor also claimed 6-terf-butyl-
3-(chloromethyl)-2,4-xylenol to be a closed system intermediate (CSI) chemical and submitted adequate information
to support this claim in its revised submissions. EPA considered that the submitter's information is adequate to meet
the guidance for claiming 6-ter/-butyl-3-(chloromethyl)-2,4-xylenol as a closed-system intermediate. Based on the
CSI status fortius chemical (the commercial product), the requirement for repeated-dose toxicity and reproductive
toxicity endpoints have been waived under the HPV Challenge Program. However, the sponsor provided data for a
combined repeated-dose/reproductive/developmental toxicity screening test to address the developmental toxicity
endpoint and this information has been summarized in this hazard assessment.

Hazard Characterization

6-ter/-Butyl-3-(chloromethyl)-2,4-xylenol is a solid at room temperature and has a moderate vapor pressure. The
water solubility of 6-ter/-butyl-3-(chloromethyl)-2,4-xylenol cannot be accurately measured because the compound
is unstable in water. It is expected to be minimally mobile in soil. 6-ter/-Butyl-3-(chloromethyl)-2,4-xylenol is
considered to have low-to-moderate volatility from moist soil and water given its Henry's Law constant; however
the rapid rate of hydrolysis suggests volatilization is not an important enviromnental fate process. Its rate of
hydrolysis is considered rapid under enviromnental conditions (pH 5-9). The rate of vapor-phase photooxidation in
the ambient atmosphere is moderate. Its rate of biodegradation was low based on the results of a ready
biodegradation test; however, this study likely measured the rate of biodegradation of the hydrolysis products not 6-
ter/-butyl-3-(chloromethyl)-2,4-xylenol. Due to the rapid rate of hydrolysis, 6-terf-butyl-3-(chloromethyl)-2,4-
xylenol is judged to have low persistence potential (PI) and low bioaccumulation potential (B1).

The acute toxicity of 6-terf-butyl-3-(chloromethyl)-2,4-xylenol to fish and aquatic invertebrates is low and to aquatic
plants is moderate.

Acute oral and dermal toxicity of 6-ter/-butyl-3-(chloromethyl)-2,4-xylenol is low in rats and rabbits, respectively.
6-ter/-Butyl-3-(chloromethyl)-2,4-xylenol is highly irritating to rabbit skin and eyes. Repeated-dose and
reproductive toxicity data were not required for the HPV Challenge Program because 6-tert-butyl-3-(chloromethyl)-
2.4-xylenol is a closed system intennediate. However a combined oral repeated-dose/reproductive/developmental

8


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

September 2008

toxicity study in rats was submitted and showed high systemic and reproductive toxicity in the parental females.
There was no developmental toxicity. 6-terM3utyl-3-(chloromethyl)-2,4-xylenol did not induce gene mutations in
bacteria. Chromosomal aberrations were observed in vitro but not in vivo.

No data gaps were identified under the HPV Challenge Program.

1. Physical-Chemical Properties and Environmental Fate

The physical-chemical properties of 6-tert-butyl-3-(chloromethyl)-2,4-xylenol are summarized in Table la, while its
enviromnental fate properties are given in Table lb. The structure of the compound is provided in the Appendix.

Physical-Chemical Properties Characterization

6-ter/-Butyl-3-(chloromethyl)-2,4-xylenol is a solid at room temperature. It has moderate vapor pressure. Water
solubility cannot be accurately measured because this chemical substance is unstable in water.

Table la. Physical-Chemical Properties of 6-to,f-Butyl-3-(chloromethyl)-2,4-xylenol1

Property

Value

CAS No.

23500-79-0

Molecular Weight

226.75

Physical State

Solid

Melting Point

45°C (measured)

Boiling Point

ca. 320°C at 1013 hPa (estimated)

Vapor Pressure

0.00042 hPa at 25°C (measured)

Henry's Law Constant

3.43xl0"6 (estimated)2

Water Solubility

3.46 mg/L at 20°C, pH 1.8-1.9 (measured; lower limit)
10.19 mg/L at 25°C (estimated)2

Log Kow

5.32 (estimated)2

Cytec Industries Inc. 2005. Revised Robust Summary and Test Plan for 6-ferf-Butyl-3-(chloromethyl)-2,4-xylenol.
http://www.epa.gov/chemrtk/pubs/summaries/6tbutvl3/cl4526tc.htm.

2USEPA. 2008. Estimation Programs Interface Suite™ for Microsoft® Windows, v3.20. United States
Enviromnental Protection Agency, Washington, DC, USA.
http://www.epa.gov/opptintr/exposure/pubs/episuite.htm.

Environmental Fate Characterization

6-ter/-Butyl-3-(chloromethyl)-2,4-xylenol is expected to partition primarily to soil and sediment, according to the
results of a Level III fugacity model. It is minimally mobile in soil. The Henry's Law constant indicates that it has
low-to-moderate volatility from moist soil and water; however, the rapid rate of hydrolysis suggests that
volatilization is not an important enviromnental fate process. Its rate of hydrolysis is considered rapid under
enviromnental conditions (pH 5-9). The rate of vapor-phase photooxidation in the ambient atmosphere is moderate.
Its rate of biodegradation was low based on the results of a ready biodegradation test; however, this study likely
measured the rate of biodegradation of the hydrolysis products, not 6-ter/-butyl-3-(chloromethyl)-2,4-xylenol. Due
to the rapid rate of hydrolysis, 6-tert-butyl-3-(chloromethyl)-2,4-xylenol is judged to have low persistence potential
(PI) and low bioaccumulation potential (Bl).

9


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

September 2008

Table lb. Environmental Fate Characteristics of 6-ferf-Butyl-3-(chloromethyl)-2,4-xylenol1

Property

Value

Photodegradation Half-life

8.9 hours (estimated)2

Biodegradation

7 % after 28 days (measured; not readily biodegradable)

Hydrolysis Half-life

<	9.8 min at pH 4 and 2 °C

<	6.4 min at pH 7 and 25°C
Spontaneous at pH 1.2 and 37°C
Spontaneous at pH 9 and 25°C

Bioconcentration

BCF = 795 (estimated)2

Koc

15,850 (estimated)2

Fugacity

(Level III Model)2

Air = 0.283 %
Water = 10.4%
Soil = 52.6 %
Sediment = 36.7 %

Persistence3

PI (low)

Bioaccumulation3

B1 (low)

1 Cytec Industries Inc. 2005. Revised Robust Summary and Test Plan for 6-tert-Butyl-3-(chloromethyl)-2,4-

xylenol. http://www.epa.gov/chemrtk/pubs/summaries/6tbutvl3/cl4526tc.htm.

2US EPA. 2008. Estimation Programs Interface Suite™ for Microsoft® Windows, v3.20. United States
Enviromnental Protection Agency, Washington, DC, USA.
http://www.epa.gov/opptintr/exposure/pubs/episuite.htm.

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

Conclusion: 6-tert-Butyl-3-(chloromethyl)-2,4-xylenol is a solid at room temperature and has a moderate vapor
pressure. The water solubility of 6-ter/-butyl-3-(chloromethyl)-2,4-xylenol cannot be accurately measured because
the compound is unstable in water. It is expected to be minimally mobile in soil. 6-terf-Butyl-3-(chloromethyl)-2,4-
xylenol is considered to have low-to-moderate volatility from moist soil and water given its Henry's Law constant;
however the rapid rate of hydrolysis suggests volatilization is not an important enviromnental fate process. Its rate
of hydrolysis is considered rapid under enviromnental conditions (pH 5-9). The rate of vapor-phase photooxidation
in the ambient atmosphere is moderate. Its rate of biodegradation was low based on the results of a ready
biodegradation test; however, this study likely measured the rate of biodegradation of the hydrolysis products not 6-
ter/-butyl-3-(chloromethyl)-2,4-xylenol. Due to the rapid rate of hydrolysis, 6-terf-butyl-3-(chloromethyl)-2,4-
xylenol is judged to have low persistence potential (PI) and low bioaccumulation potential (B1).

2. Environmental Effects - Aquatic Toxicity

The test substance is not stable in the aquatic enviromnent (hydrolysis half-life < 6.4 minutes at 25°C). During the
aquatic toxicity testing, the aquatic organisms were actually exposed to (6-tert-butyl-3-(hydroxymethyl)-2,4-xylenol,
the hydrolysis product of 6-tert-butyl-3-(chloromethyl)-2,4-xylenol.

Acute Toxicity to Fish

Rainbow trout (Oncorhvnchus mvkiss, 20/concentration) were exposed to 6-tert-butyl-3-(chloromethyl)-2,4-xylenol
at measured concentrations of 8.2, 10, 19, 28, or 47 mg/L under semi-static conditions (daily renewal) for 96 hours.
Mortality was 100% at 47 mg/L within 3 hours of exposure and at 28 mg/L after 6 hours of exposure. At 19 mg/L
all fish died after 48 hours of exposure. Mortality was 50% at 10 mg/L after 96 hours. None of the fish died in
control and 8.2 mg/L groups. Loss of equilibrium was noted at 10, 19 and 28 mg/L and moribund condition at 47
mg/L.

96-h LCS0 = 11 mg/L

10


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

September 2008

Acute Toxicity to Aquatic Invertebrates

Water fleas (Daphnia magna, 10/replicate) were exposed to 6-fer/-butyl-3-(chloromethyl)-2,4-xylenol at measured
concentrations of 0.56, 1.0, 1.8, 3.2, 5.8, 10, 18, 30 or 51 mg/L under static conditions for 48 hours. No
immobilization was seen at concentrations <3.2 mg/L. At 48 hours, 25, 45, 60 and 90% immobilization was seen at
5.8, 10, 30, and 51 mg/L, respectively.

48-h ECS0=19 mg/L

Toxicity to Aquatic Plants

Green algae (Pseudokirchneriella subcapitata) were exposed to 6-fer/-butyl-3-(chloromethyl)-2,4-xylenol at
measured concentrations of 5.1, 10.4, 21, 39, and 70 mg/L under static conditions for 72 hours. Significant effects
on area under growth were seen at and above 10.4 mg/L. No effect was seen at 5.1 mg/L.

72-h ECS0 (growth) = 6.6 mg/L

Conclusion: The acute toxicity of 6-fer/-butyl-3-(chloromethyl)-2,4-xylenol to fish and aquatic invertebrates is low
and to aquatic plants is moderate.

3. Human Health Effects
Acute Oral Toxicity

(1)	Wistar rats (5 males/dose) were administered 6-fer/-butyl-3-(chloromethyl)-2,4-xylenol via gavage at 5.0 or 10.0
mL/kg-bw (approximately 5220 or 10,440 mg/kg-bw) and observed for up to 14 days. Mortality occurred in the
high-dose group within 3 days of dosing. All animals had a sluggish, unsteady gait 1 hour after treatment. All
animals in the low-dose group recovered within 2 days. Animals that died exhibited distended, gas-filled and
injected stomachs with glandular portions mottled pink and yellow, red kidney medullae, distended, liquid, blood-
filled and injected intestines that were yellow and red in areas, and red adrenals. Survivors exhibited stomachs
adhered to abdominal walls and livers.

LDS0 ~ 8050 mg/kg-bw

(2)	Sprague-Dawley rats (3/sex) were administered 6-fer/-butyl-3-(chloromethyl)-2,4-xylenol via gavage at 2000
mg/kg-bw and observed for 14 days. No mortality occurred. Hunched posture and diarrhea were observed in all
animals. Lethargy and piloerection were observed in males. All animals recovered within 2 - 4 days of dosing. No
abnormal findings were observed at necropsy.

LDS0 > 2000 mg/kg-bw

Acute Dermal Toxicity

New Zealand White rabbits (2-4 males/dose) were administered 6-fer/-butyl-3-(chloromethyl)-2,4-xylenol dermally
on to clipped skin under occluded conditions for 24 hours and observed for 14 days. Three groups of four rabbits
were administered 3.2, 6.4 or 10.0 mL/kg-bw (approximately 3341, 6682 or 10,440 mg/kg-bw) and two rabbits were
administered 0.8 mL/kg-bw (approximately 835 mg/kg-bw). Mortality occurred at 3.2 and 10.0 mL/kg-bw.
Erythema, edema, ecchymosis, areas of necrosis and scabs were observed at the application site. Animals that died
exhibited red kidneys.

LDS0 ~ 10,420 mg/kg-bw

Repeated-Dose Toxicity

In a combined repeated-dose/reproductive/developmental toxicity screening test, Sprague-Dawley rats (10/sex/dose)
were administered 6-fer/-butyl-3-(chloromethyl)-2,4-xylenol (in polyethylene glycol 400) via gavage at 0, 15, 50 or
200 mg/kg-bw/day. Males were administered the test substance daily for a total of 34 days during the pre-mating
and mating periods. Females were dosed daily from 43 to 57 days during pre-mating, mating, gestation, and up until
lactation day 3. Dose-related mortality included one, two and five female deaths in the 15, 50 and 200 mg/kg-
bw/day, respectively. The deaths of one male and one female at the high dose were noted as dosing accidents.

11


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

September 2008

High-dose males exhibited a 45 - 65% decrease in body-weight gain and an 8 - 10% decrease in weekly mean body
weight throughout the study. Reductions in female body weight gains were noted at the high dose during the pre-
mating period and at all doses during the gestation period. Decreased food consumption and efficiency were noted
in high-dose males and females during the pre-mating period. Throughout gestation, reduced food consumption was
noted in females at 50 and 200 mg/kg-bw/day. Clinical observations included lung noise, diarrhea, hunched over
posture and stained fur in males at the high-dose. During the pre-mating period, stained fur, diarrhea, hunched over
posture and irregular respiration was observed in high-dose females. During the gestation period, females at all
doses exhibited clinical signs associated with dystocia, which included dehydration, diarrhea, immobility/lethargy,
pallor, ptosis and stained/wet fur. Irregular respiration and lung noise were noted in high-dose females during the
gestation and lactation periods. Test substance-related decreases in hindlimb grip strengths (males only) and motor
activity (males and females) were observed at the high-dose level. No other treatment-related effects were noted. A
treatment-related increase in cholesterol concentration was noted in some males of all treatment groups, some
females at 15 or 50 mg/kg-bw/day and in all high-dose females. There was an increase in liver weights in males and
females treated at and above 50 mg/kg-bw/day. Mean relative liver weights were increased 7, 16 and 45% in males
and 3,11 and 21% in females at 15, 50 and 200 mg/kg-bw/day, respectively. The absolute and relative liver weights
were markedly increased at the high-dose. Minimal hypertrophy of centrilobular hepatocytes were observed in the
livers of high-dose females and mid- and high-dose males. Minimal hypertrophy of thyroid follicular cells
characterized by an increase in the height of the columnar epithelium was noted in high-dose males and females.
Follicles were decreased in size, irregular in shape and contained a decreased amount of normal pink colloid.
LOAEL = 15 mg/kg-bw/day (based on mortality and reduced body weight of females during gestation)

NOAEL = Not established

Reproductive/Developmental Toxicity

In the combined repeated-dose/reproductive/developmental toxicity screening test described previously, maternal
toxicity was noted as reduction in body weight gain during gestation at all doses. A total of eight female rats died,
six of which were dystocia-related deaths and occurred at all doses. There were no effects on the mating and
fertility indices at any dose. No reproductive effects were observed in males. There were no adverse developmental
effects, embryo lethality or gross abnormalities at any dose.

LOAEL (systemic toxicity) = 15 mg/kg-bw/day (based on mortality and reduced body weight of females during
gestation)

NOAEL (systemic toxicity) = Not established

LOAEL (reproductive toxicity) = 15 mg/kg-bw/day (based on clinical observations associated with dystocia)
NOAEL (reproductive toxicity) = Not established
NOAEL (developmental toxicity) = 200 mg/kg-bw/day

Genetic Toxicity - Gene Mutation
In vitro

Salmonella typhimurium strains TA98, TA100, TA1535 and TA1537 were exposed to 6-fer/-butyl-
3-(chloromethyl)-2,4-xylenol at concentrations of 0, 5, 15, 50, 150, 500 or 1500 |ig/plate and Escherichia coli strain
WP2MvrA was exposed at concentrations of 0, 50, 150, 500, 1500 or 5000 |ig/plate in the absence and presence of
metabolic activation. Positive controls were tested concurrently and responded appropriately. Cytotoxicity was
observed at 500 ng/plate in S. typhimurium strains in the absence of metabolic activation and at 5000 |ig/plate for E.
coli in both the absence and presence of activation

6-terf-Butyl-3-(chloromethyl)-2,4-xylenol was not mutagenic in this assay.

Genetic Toxicity - Chromosomal Aberrations
In vitro

Human peripheral lymphocytes were exposed to 6-fer/-butyl-3-(chloromethyl)-2,4-xylenol at concentrations of 0,
17.5, 35, 70, 105, 140 or 280 ng/mL in the absence of metabolic activation and 0, 35, 70, 140, 210, 280 or 420
Hg/mL in the presence of metabolic activation. Positive controls were tested concurrently and responded
appropriately. The cytotoxic concentration was 140|ig/mL. There was an increase in the number of cells with

12


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

September 2008

aberrations at 105 and 140|ig/mL in the absence of metabolic activation and at 140|ig/mL in the presence of
metabolic activation.

6-terf-Butyl-3-(chloromethyl)-2,4-xylenol induced chromosomal aberrations in this assay.

In vivo

Male CD-I mice (seven/dose) were administered 6-fer/-butyl-3-(chloromethyl)-2,4-xylenol via gavage at 0, 250,
500 or 1000 mg/kg-bw. An additional high-dose, negative-control and positive-control groups (five mice) were
included in the study. No mortality occurred. Clinical signs included hunched posture, lethargy and ptosis at doses
of > 250 mg/kg-bw. One group of mice from each of the doses, the two vehicle-control groups and the positive-
control group were all sacrificed 24 hours after dosing. The additional high-dose group was sacrificed 48 hours after
dosing. There were no changes in the number of micronucleated PCEs.

6-terf-Butyl-3-(chloromethyl)-2,4-xylenol did not induce chromosomal aberrations in this assay.

Additional Information
Skin Irritation

Rabbits (6, sex not specified) were administered undiluted 6-fer/-butyl-3-(chloromethyl)-2,4-xylenol (0.5 mL)
dermally on to the intact and abraded skin under semi-occluded conditions for an unspecified period of time.

Dermal reactions were evaluated 24 and 72 hours after application and were scored according to the Draize method.
The structure of the tissue at the site of contact was destroyed or changed irreversibly in < 24 hours. The mean
values for erythema and edema at both intact and abraded sites at 72 hours were at the maximum possible value of
4.00.

6-terf-Butyl-3-(chloromethyl)-2,4-xylenol was highly irritating to rabbit skin in this study.

Eye Irritation

Rabbits (6, sex not specified) were instilled undiluted 6-fer/-butyl-3-(chloromethyl)-2,4-xylenol (0.1 mL) into the
conjunctival sac of one eye of each rabbit. Ocular reactions were evaluated for up to 72 hours and were scored
according to the Draize method. Irreversible changes/tissue destruction was observed within 24 hours of treatment.
Observations at all intervals included discernable opacity or ulceration of the cornea, inflammation of the iris, slight
circumcorneal injection, red appearance of the conjunctivae with individual vessels not easily discernable, swelling
of the conjunctivae (excluding cornea and iris) and partial eversion of the lids.
6-terf-Butyl-3-(chloromethyl)-2,4-xylenol was highly irritating to rabbit eyes in this study.

Conclusion: Acute oral and dermal toxicity of 6-fer/-butyl-3-(chloromethyl)-2,4-xylenol is low in rats and rabbits,
respectively. 6-fer/-Butyl-3-(chloromethyl)-2,4-xylenol is highly irritating to rabbit skin and eyes. Repeated-dose
and reproductive toxicity data were not required for the HPV Challenge Program because 6-fer/-butyl-3-
(chloromethyl)-2,4-xylenol is a closed system intermediate. However, a combined oral repeated-dose/ reproductive/
developmental toxicity study in rats was submitted and showed high systemic and reproductive toxicity in the
parental females. There was no developmental toxicity. 6-ter/-Butyl-3-(chloromethyl)-2,4-xylenol did not induce
gene mutations in bacteria. Chromosomal aberrations were observed in vitro but not in vivo.

13


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

September 2008

APPENDIX

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

Endpoints

SPONSORED CHEMICAL
6-/crf-Butyl-3-(chloromcthyl)-2,4-\ylcnol
(23500-79-0)

Structure













CI"""



Summary of Environmental Effects - Aquatic Toxicity Data

Fish

96-h LCS0 (mg/L)

11

Aquatic Invertebrates
48-h ECS0 (mg/L)

19

Aquatic Plants
72-h ECS0 (mg/L)

6.6

Summary of Human Health Data

Acute Oral Toxicity
LDS0 (mg/kg-bw)

>2000

Acute Dermal Toxicity
LDS0 (mg/kg-bw)

~ 10,420

Repeated-Dose/Reproductive/Developmental
Toxicity

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

Systemic Toxicity

NOAEL = Not established (57-d)
I.OAF.I. = 15 (57-d)

Reproductive Toxicity

NOAEL = Not established
LOAEL = 15

Developmental Toxicity

NOAEL = 200

Genetic Toxicity - Gene Mutation
In vitro

Negative

Genetic Toxicity - Chromosomal Aberrations
In vitro

Positive

Genetic Toxicity - Chromosomal Aberrations
In vivo

Negative

Additional Information
Skin Irritation
Eye Irritation

Highly irritating
Highly irritating

14


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

September 2008

Screening Level Exposure Characterization for HPV Challenge

Chemical

6-te/tf-Butyl-3-(chloromethyl)-2,4-xylenol

CAS # 23500-79-0

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

15


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

September 2008

Screening Level Exposure Characterization

6-terf-Butyl-3-(chloromethyl)-2,4-xylenol (CAS # 23500-79-0)

Non-CBI Executive Summary

Phenol, 6-/t'/V-buty 1 -3-(chloromethyl )-2, 4-dimethyl- (CAS # 23500-79-0), also known as 6-lerl-
butyl-3-(chloromethyl)-2,4-xylenol, has an aggregated production and/or import volume in the
United States of > 1 million to 10 million pounds.12 Non-confidential Inventory Update Rule
(IUR) information for this chemical indicates that it is used as an intermediate. No commercial/
consumer uses were reported in the IUR submissions or in the Hazardous Substances Data
Bank.13 Information submitted as part of the High Production Volume (HPV) Challenge
Program indicates that phenol, 6-fert-butyl-3-(chloromethyl)-2, 4-dimethyl- is used in the
chemical industry for synthesis.14

Potential for Exposures to Human 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. The Agency has reviewed the information in the HPV Challenge
Program submission or test plan and determined that the information satisfies the guidance to
demonstrate that the chemical is a closed system intermediate.15 Due to the rapid rate of
hydrolysis, the chemical is judged to have low persistence potential (PI) and low
bioaccumulation potential (Bl).16 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 this chemical in
accordance with IUR requirements.

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

13	HSDB, 2008. Hazardous Substances Data Bank. Accessed June 04, 2008. http://toxnet.nlm.nih.gov/

14	USEPA, 2008. High Production Volume Information System (HPVIS) and Screening Information Data Sets
(SIDS). Accessed May 22, 2008.

15	USEPA, 2003. EPA Comments on Chemical RTK HPV Challenge Submission. Letter dated November 11,
2003. Accessed June 13, 2008. http://www.epa.gov/chemrtk/pubs/summaries/6tbutvl3/cl4526tc.htm

16	USEPA, 2008. Screening-Level Hazard Characterization for Phenol, 6-tert-butyl-3-(chloromethyl)-2, 4-dimethyl-
(CAS # 23500-79-0).

16


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

September 2008

Non Confidential IUR Data Summary: Phenol, 6-fert-butyl-3-(chloromethyl)-2, 4-

dimethyl- (CAS # 23500-79-0)

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:*

> 1 million to 10 million pounds

Cytec Industries Inc. / Willow Island, WV

less than 100 (including those of manufacturing,

industrial processing and use)

confidential

liquid

* Note: There may be other companies/sites and physical forms that are claimed as confidential
business information (CBI).

** 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 Use Information



Reported in 2006 IUR



Processing Activity

Industrial Sector

Functional Use

Processing as a reactant

Other Clothing Stores***

Intermediates



Table 2





Commercial/ Consumer Uses



Reported in 2006 IUR



Commercial/ Consumer

Highest maximum concentration

Use in Children's Products

Product Category Description

range



None reported

*** Erroneous numerical code contained in submission.

17


-------