vvEPA
United States
Environmental Protection
Agency
u.s. era"
AN ALTERNATIVES ASSESSMENT FOR THE FLAME
RETARDANT DECABROMODIPHENYL ETHER (DecaBDE)
*
all
FINAL REPORT
January 2014
1
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An Alternatives Assessment for the Flame Retardant Decabromodiphenyl Ether
(DecaBDE) Executive Summary
This report provides detailed hazard information for 29 substances and mixtures that have been
identified as potentially viable alternatives to decabromodiphenyl ether (decaBDE) in a variety
of polymers and applications. Chemicals were selected for evaluation based on their potential as
substitutes to decaBDE, not because they are expected to be safer than decaBDE. The purpose of
the report is to provide human health and ecological hazard information; a fully informed choice
of alternatives will likely require consideration of other factors, such as cost and efficacy.
Efficacy of the flame retardant alternatives was not tested. The U.S. Environmental Protection
Agency (EPA) developed the report with input from a partnership of stakeholders from business,
government, academia, and environmental organizations. This report:
1. Identifies potentially viable and non-viable flame retardant alternatives for decaBDE in a
variety of applications and end-uses;
2. Provides a use, life-cycle, and exposure overview for decaBDE;
3. Supplies hazard profiles for decaBDE and 29 chemical alternatives; and
4. Presents a general discussion of factors relevant to substitution decisions.
The hazard profiles for decaBDE and its alternatives can be found in Chapter 4 of the report.
DecaBDE and the 29 alternatives evaluated in this alternative assessment fall into five general
chemical classes:
1. Discrete halogenated flame retardants;
2. Polymeric brominated flame retardants;
3. Discrete phosphorus flame retardants, nitrogen flame retardants, and phosphorus/nitrogen
flame retardants;
4. Polymeric phosphorus flame retardants and nitrogen flame retardants; and
5. Inorganic flame retardants.
Some of the alternatives have been in use for decades and others are relatively new to the market.
The hazard profiles show that some of the alternatives have similar hazard profiles to decaBDE;
other alternatives have trade-offs in hazard endpoints; some alternatives have preferable profiles
compared to decaBDE. Flame retardants with similar profiles are persistent, potentially
bioaccumulative, and tend to have hazards for carcinogenicity, developmental neurotoxicity and
repeated dose toxicity. Other alternatives are associated with the concern for hazard based on
different endpoints, for example aquatic toxicity, and present hazard trade-offs when compared
to decaBDE. The large polymers are anticipated to be safer because their large size limits
bioavailability. Unfortunately, their long-term fate in the environment is not known and some
stakeholders point out that halogenated polymers can generate halogenated dioxins and furans
during combustion; combustion by-products are not assessed in the report.
Some of the hazard profiles in this report are based largely on empirical data and others rely
heavily on estimated values. Uncertainty is associated with estimated concern for hazards.
Chemicals with limited empirical data that are currently or likely to be used at high volumes
should be priority for further testing.
11
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Background
In December 2009, EPA released the Polybrominated Diphenyl Ethers (PBDEs) Action Plan.
The PBDE Action Plan summarizes hazard, exposure, and use information for three commercial
PBDE mixtures, including decaBDE. DecaBDE is a flame retardant used in a variety of
applications, including textiles, plastics, wiring insulation, and building and construction
materials. Debromination (the physical or metabolic removal of bromine atoms) can convert
decaBDE to lower brominated PBDE congeners, contributing further to the potential risk from
exposure to these congeners. In March 2012, EPA initiated rulemaking and proposed a
simultaneous significant new use rule (SNUR) and test rule for PBDEs under the Toxic
Substances Control Act (TSCA). The proposed SNUR designates any use of decaBDE in
manufacturing, importation, or processing that is not ongoing as of December 31, 2013 as a
significant new use. Additionally, the manufacture (including import) or processing of any article
to which PBDEs have been added will also be considered a significant new use. The proposed
PBDE test rule requires testing of the health and environmental effects of PBDEs by
manufacturers and processors of decaBDE and/or articles containing decaBDE for any use after
December 31, 2013. In December 2009, the largest producers and suppliers of decaBDE in the
U.S. committed to end its production, importation, and sales for all uses by the end of 2013.
As part of the Agency's efforts to manage chemical risks, the Action Plan called upon the DfE
Program to conduct an alternatives assessment for decaBDE. A DfE Alternatives Assessment is a
process for identifying and comparing potential chemical alternatives that can be used as
substitutes to replace chemicals that the Agency has designated for action. DfE alternatives
assessments provide information on functional class, intrinsic hazard, exposure properties, and
environmental fate for chemical alternatives. It is expected that the information in DfE
Alternatives Assessments will influence the selection of safer, more sustainable alternatives
when combined with other information not highlighted in DfE Alternatives Assessments such as
performance, cost, and efficacy of the alternatives. Alternative materials and barrier
technologies could also be approaches for flame retardancy but were not a focus of this report.
Goal of the Partnership and Report
DfE convened a multi-stakeholder partnership to assess the potential human health and
environmental hazards of decaBDE and its alternatives. The information presented in this report
is based on the partnership's knowledge and the DfE Program's research. Chapter 1 of the report
provides background information on decaBDE and defines the report's purpose and scope.
Chapter 2 describes the materials and products in which decaBDE is used and briefly discusses
flammability standards relevant to products that contain decaBDE. Chapter 3 provides
background information on flame retardants and outlines which flame retardants are and are not
included in the alternatives assessment. Chapter 3 provides details on two flame-retardant
technologies not assessed in the report (inherently flame retardant materials and nanosilicates)
and describes flame retardant modes of action. Chapter 4 is the largest part of the report and
explains the hazard evaluation methodology and the hazard profiles for decaBDE and the 29
identified alternatives. Chapter 5 provides information on exposure and life-cycle considerations
for decaBDE and its alternatives. Chapter 6 discusses considerations for selecting flame
retardants and provides relevant resources for moving towards a substitution decision.
in
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Results
With the assistance of the partnership, EPA identified 29 potentially functional, viable
alternatives to decaBDE for use in select polyolefins, styrenics, engineering thermoplastics,
thermosets, elastomers, or waterborne emulsions and coatings. The scope of this assessment was
focused on the human health and environmental hazards of potential flame retardant substitutes.
The human health endpoints evaluated in DfE alternatives assessments include acute toxicity,
carcinogenicity, genotoxicity, reproductive toxicity, developmental toxicity, neurotoxicity,
repeated dose toxicity, skin sensitization, respiratory sensitization, eye irritation, and dermal
irritation. Large polymers were generally designated as Low concern for human health endpoints
compared to discrete chemicals because the large polymers generally cannot be absorbed or
easily metabolized. Although irritation can occur without absorption, it was not identified as a
hazard for any of the large polymers and therefore was not a distinguishing characteristic in this
assessment. Acute mammalian toxicity was Low for decaBDE and all but two of the alternatives:
tris(tribromoneopentyl) phosphate and the substituted amine phosphate mixture. Carcinogenicity
and genotoxicity hazards varied among the alternatives, with many Low or Moderate results.
None of the chemicals had High concerns for carcinogenicity and only zinc borate had a High
concern for genotoxicity. DecaBDE was Low for genotoxicity and Moderate for carcinogenicity.
Reproductive, developmental, neurological, and repeated dose toxicity varied from Low to High
across discrete chemicals. DecaBDE has High developmental toxicity, Moderate repeated dose
toxicity, and an estimated Low neurological hazard in adults. Irritation and sensitization
endpoints were generally not distinguishing, but five chemicals had at least one designation of
Moderate, High, or Very High for one or more irritation or sensitization endpoints, whereas
decaBDE has Low designations for these endpoints.
The aquatic toxicity endpoints evaluated in DfE alternatives assessments include acute and
chronic aquatic toxicity. Aquatic toxicity hazards varied significantly due to the diverse
chemistries of the alternatives. Large discrete chemicals and large polymers (both halogenated
and non-halogenated) had generally Low aquatic toxicity hazards. The larger chemicals and
compounds with high Kow values are not expected to be bioavailable in the water column. For
inorganic compounds, aquatic toxicity varied from Low to High. The metal species influences
toxicity, as does the type of anion with which it is associated (e.g., a metal hydroxide). Metal
compounds will have different solubilities depending on the anion involved, which will
contribute to the level of toxicity of the metal compound. The aluminum, antimony and zinc
compounds have Moderate to High aquatic toxicity. For ammonium polyphosphate, magnesium
hydroxide and red phosphorus, aquatic toxicity was Low. In addition to some of the inorganic
compounds, some of the phosphorus and/or nitrogen-containing compounds had High or Very
High measured or predicted aquatic toxicity.
Chemical flame retardants must be stable by design in order to maintain their flame retardant
properties throughout the lifetime of the product and most are designated as High or Very High
for persistence. Additionally, the High persistence associated with the large polymers in this
assessment is due to the limited bioavailability and lack of assimilation by microorganisms. The
alternatives without High persistence were triphenyl phosphate, which is readily biodegradable
(low persistence), as well as resorcinol bis-diphenyl phosphate, an inherently biodegradable
chemical that degrades slowly (Moderate persistence), however these substances have aquatic
toxicity hazards and bioaccumulation potential.
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The ability of a chemical to accumulate in living organisms is described by the bioconcentration,
bioaccumulation, biomagnification, and/or trophic magnification factors. DecaBDE has High
potential for bioaccumulation, as do its breakdown products (lower brominated diphenyl ether
congeners). Some of the alternatives assessed in this report also have a High potential for
bioaccumulation, including the discrete brominated chemicals and, based on presence of
oligomers below 1,000 daltons, some of the phenyl phosphates. The potential for a molecule to
be absorbed by an organism tends to be lower when the molecule is greater than 1,000 daltons in
size. This is reflected in the Low hazard designations for bioaccumulation for the polymeric
flame retardants without low molecular weight components below 1,000 daltons. The inorganic
flame retardants assessed in this report do not have High potential to bioaccumulate, nor do the
discrete nitrogen-based flame retardants.
How to Use This Report
Audiences for this report include stakeholders interested in chemical hazards and safer
alternatives, including but not limited to chemical manufacturers, component manufacturers,
product manufacturers, retailers, consumers, non-governmental organizations, consultants, and
state and federal regulators. Three potential uses of this report include:
Identification of potential substitutes. This report allows stakeholders interested in chemical
substitution to identify functional substitutes for decaBDE in certain plastics. The list of potential
alternatives introduced in Chapter 3 includes chemicals identified by stakeholders as viable,
functional alternatives as well as chemicals that are not considered functional alternatives and
information on inherently flame retardant polymers. The inclusion of a chemical in this
assessment does not indicate environmental- or health-based preferability. By identifying
potential functional alternatives, this report assists manufacturers in selecting chemicals for
additional performance testing.
Selection of alternative chemicals based on comparative chemical hazard assessment. This
report helps decision-makers understand and compare the hazards associated with potential
alternatives and supplement information on performance and cost. Some alternatives may be
associated with hazard concerns similar to those of decaBDE; others may be associated with
different hazard concerns. Use of the hazard information in Chapter 4 may help businesses avoid
the cost of repeated substitution. The information in Chapter 4 is a robust human health and
environmental profile for each chemical that is based on empirical data and enhanced with
modeling and expert judgment to fill data gaps. The profiles can help decision-makers
understand which potential alternatives may come under scrutiny in the future and choose the
safest possible alternative now in order to reduce future costs. In addition to reading the hazard
summary tables (Table 4-4, Table 4-5, and Table 4-6), decision-makers should review the full
hazard assessments for each chemical available in Section 4.8. The hazard assessments provide
more information on hazard criteria, data interpretation and information used to assign hazard
values in each category. Decision-makers should consider this information to ensure a complete
understanding of the hazard profiles of each alternative.
Use of hazard information for further analysis and decision-making. The information in this
report can be used to inform further analyses on preferred alternative chemicals, such as risk
v
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assessments or life-cycle assessments. For example, a decision-maker could identify several
functional alternatives with preferable hazard profiles, and conduct product-specific risk
assessments based on exposure expectations along the product's life-cycle. This type of
supplementary information may be helpful in guiding product-specific decision-making.
Information in this report also can be used to identify the Very Persistent Very Bioaccumulative
chemicals targeted under European REACH policy. This report does not evaluate the relative
hazards of alternatives, but GreenScreen™ (www.cleanproduction.org/Greenscreen.php) is one
tool that can be used for this purpose. The criteria used to develop the hazard assessments in this
report can also be used to inform Green Chemistry design if availability of safer alternatives is
limited.
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Hazard Summary Table
Table ES-1 Screening Level Hazard Summary for DecaBDE and Halogenated Flame Retardant Alternatives
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the substance
including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard information in the table.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , E and VH) were assigned
based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from predictive models and/or professional judgment.
§ Based on analogy to experimental data for a structurally similar compound.
a This alternative may contain impurities. These impurities have hazard designations that differ from the flame retardant alternative, Brominated poly(phenylether), as follows, based on
experimental data: HIGH for human health. HIGH for aquatic toxicity, and VERY HIGH for bioaccumulation.
' This chemical is subject to testing in an EPA consent order for this endpoint.
Chemical
(for full chemical name and relevant trade names see
the individual profiles in Section 4.8)
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
DecaBDE and Halogenated Flame Retardant Alternatives
DecaBDE and Discrete Halogenated FR Alternatives
Bis(hexachlorocyclopentadieno) Cyclooctane
13560-89-9
L
VL
VL
L
L
VL
L
L
L
VH
H
Brominated Poly(phenylether)
Confidential
L
La
L
VLn
Ma
La
La
L
L
VL
L
La
VHr
Hra
Decabromodiphenyl Ethane
84852-53-9
L
L
L
L
L
L
VL
VL
L
L
VH
H
Decabromodiphenyl Ether
1163-19-5
L
L
L
L
L
L
L
L
L
VH
H
Ethylene B is-T etrabromophthalimide
32588-76-4
L
M
L
L
L
L
L
VL
VL
L
L
VH
H
Tetrabromobisphenol A Bis (2,3-dibromopropyl)
Ether
21850-44-2
L
M
M
M
M
L
M
L
L
L
L
L
VH
H
Tris(tribromoneopentyl) Phosphate
19186-97-1
M
M
L
M
M
H
L
L
L
L
L
L
H
M
Tris(tribromophenoxy) Triazine
25713-60-4
L
L
L
L
L
L
L
L
L
VL
L
L
VH
H
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants that may
partition to sediment and particulates.
vii
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Table ES-1 Continued
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , E and VH) were assigned
based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from predictive models and/or professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations.
~ Different formulations of the commercial product are available. One of these many formulations lias an average MW of-1,600 and contains significant amounts of lower MW
components. These lower MW components have hazard designations different than the polymeric flame retardant, as follows: HIGH (estimated) for bioaccumulation; HIGH
(experimental) for acute aquatic toxicity; HIGH estimated for chronic aquatic toxicity; MODERATE (experimental) for developmental; and MODERATE (estimated) for
carcinogenicity, genotoxicity, repeated dose, reproductive, and skin and respiratory sensitization toxicity.
Chemical
(for Ml chemical name and relevant trade names see
the individual profiles in Section 4.8)
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Halogenated Flame Retardant Alternatives Continued
Polymeric Halogenated FR Alternatives1"
Brominated Epoxy Polymers
68928-70-1
L
/,~
L
/,~
/,~
L
zV
L
~
L
L
/,~
/,~
VH
/,~
Brominated Epoxy Polymer(s)
Confidential
L
/,~
/,~
/,~
/,~
L
zV
/,~
~
L
L
/,~
/,~
VH
/,~
Mixture of brominated epoxy polymer(s) and
bromobenzyl acrylate
Confidential
L
/,~
/,~
/,~
/,~
L
zV
/,~
~
L
L
/,~
/,~
VH
/,~
Brominated Epoxy Resin End-Capped with
Tribromophenol
135229-48-0
L
L
L
L
L
L
Ld
L
L
VL
L
L
VH
L
Brominated Polyacrylate
59447-57-3
L
L
L
L
L
L
Ld
L
L
L
L
L
VH
L
Brominated Polystyrene
88497-56-7
L
L
L
L
L
L
Ld
L
L
L
L
L
VH
L
Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame
retardants that may partition to sediment and particulates.
p The range of polymer molecular weight can be broad. The polymers listed here have low toxicity for human health and aquatic endpoints. Not all polymers will have this
low toxicity; hazards will vary with physical-chemical properties.
viii
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Table ES-2 Screening Level Hazard Summary for Organic Phosphorus or Nitrogen Flame Retardant Alternatives
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the substance
including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard information in the table.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , E and VH) were assigned
based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from predictive models and/or professional judgment.
§ Based on analogy to experimental data for a structurally similar compound.
1 The highest hazard designation of any of the oligomers withMW <1,000.
0 The highest hazard designation of a representative component of the oligomeric mixture with MWs <1,000.
Chemical
(for full chemical name and relevant trade names
see the individual profiles in Section 4.8)
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Organic Phosphorus or Nitrogen Flame Retardant (PFR or NFR) Alternatives
Discrete PFR, NFR and P/NFR Alternatives
Substituted Amine Phosphate Mixture1
Confidential
H
M
M
M
M
L
M
L
VL
M
L
H
L
Triphenyl Phosphate
115-86-6
L
M
L
L
L
L
H
L
L
VL
VH
VH
L
M
Polymeric PFR and NFR Alternatives
Bisphenol A bis-(diphenyl phosphate); BAPP
181028-79-5
L
M
L
L
L
L
L
L
L
L
H
Melamine Cyanurate1
37640-57-6
L
M
M
L
H
L
L
L
L
L
VH
L
Melamine Polyphosphate1
15541-60-3
L
M
M
L
M
L
L
VL
L
L
H
L
N-alkoxy Hindered Amine Reaction Products
191680-81-6
L
M
L
H
H
L
H
L
L
VL
H
H
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants that may
partition to sediment and particulates.
1 Hazard designations are based upon the component of the salt with the highest hazard designation, including the corresponding free acid or base.
IX
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Table ES-2 Continued
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , E and VH) were assigned
based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from predictive models and/or professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations
§ Based on analogy to experimental data for a structurally similar compound.
1 The highest hazard designation of any of the oligomers withMW <1,000.
v Phosphorate Oligomer, with a MW range of 1,000 to 5,000, may contain significant amounts of an impurity, depending on the final product preparation. This impurity has hazard
designations that differ from the polymeric flame retardant, as follows: MODERATE (experimental) for carcinogenicity, reproductive and repeated dose toxicity, skin sensitization
eye and dermal irritation; and HIGH (experimental) for developmental toxicity and acute and chronic aquatic toxicity.
Chemical
(for full chemical name and relevant trade names
see the individual profiles in Section 4.8)
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Organic Phosphorus or Nitrogen Flame Retardant (PFR or NFR) Alternatives Continued
Polymeric PFR and NFR Alternatives
Phosphonate Oligomer*
68664-06-2
L
M
M%
L*
L8*
M%
l¥
VH
Polyphosphonate
68664-06-2
L
L
L
L
L
L
L"
L
L
L
L
L
VH
L
Phosphoric acid, mixed esters with [l,l'-bisphenyl-
4,4'-diol] and phenol; BPBP
1003300-73-9
L
M
L
L
L
L
VL
VL
ifi
ifi
H
M%
Poly[phosphonate-co-carbonate]
77226-90-5
L
L
L
L
L
L
Ld
L
L
L
L
L
VH
L
Resorcinol Bis-Diphenylphosphate; RDP
125997-21-9
L
L
L
L
L
VL
VH
VH
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants that may
partition to sediment and particulates.
x
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Table ES-3 Screening Level Hazard Summary for Inorganic Flame Retardant Alternatives
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the substance
including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard information in the table.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , E and VH) were assigned
based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from predictive models and/or professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations.
R Recalcitrant: Substance is comprised of metallic species that will not degrade, but may change oxidation state or undergo complexation processes under enviromnental conditions.
* Ongoing studies may result in a change in this endpoint.
Chemical
(for full chemical name and relevant trade names
see the individual profiles in Section 4.8)
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Inorganic Flame Retardant Alternatives
Aluminum Diethylphosphinate
225789-38-8
L
L
L
VL
M
M
M
L
L
VL
Hr
L
Aluminum Hydroxide
21645-51-2
L
L
L
L
L
M
L
VL
VL
M
M
Hr
L
L
Ammonium Polyphosphate
68333-79-9
L
L
L
L
L
Ld
L
VL
L
L
L
VH
L
Antimony Trioxide1
1309-64-4
L
.
M
L
L
L
L
Hr
L
Magnesium Hydroxide
1309-42-8
L
L
L
L
L
L
L
L
L
L
L
Hr
L
Red Phosphorus
7723-14-0
L
L
M
L
L
L
L
L
L
L
L
Zinc Borate
1332-07-6
L
L
H
M
M
H
L
L
L
L
H
H
] R
L
Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants that may
partition to sediment and particulates.
1 This compound is included in the ongoing EPA Work Plan evaluation for Antimony Trioxide.
XI
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Acknowledgements
This project could not have been completed without the participation of the Flame-Retardant
Alternatives for DecaBDE Partnership. The Partnership includes the following stakeholders:
Academics
Alissa Cordner, Brown University
Julie Herbstman, Columbia University
Heather Stapleton, Duke University
Joseph G. Allen, Harvard School of Public Health
Carol Handwerker, Purdue University
Inez Hua, Purdue University
Jeffery W. Youngblood, Purdue University
Alexander B. Morgan, University of Dayton Research Institute
Ravi Mosurkal, University of Massachusetts - Lowell
Ramaswamy Nagarajan, University of Massachusetts - Lowell
Jack Geibig, University of Tennessee - Knoxville
Alexandra Bergstein, Yale University
Consultants
Andy Beevers, Applied Market Information
Cris A. Williams, ENVIRON
Ann Blake, Environmental and Public Health Consulting
Susan Hazen, Hazen Consulting
Mark Buczek, Independent Consultant
Bob Kerr, Pure Strategies
Ken Soltys, Pure Strategies
Pat Beattie, SciVera
Tom Osimitz, SciVera
Andy Hall, Sustainable Value Cycle Solutions
Emily Campbell, ToxServices
Margaret Whittaker, ToxServices
NGOs
Pamela Miller, Alaska Community Action on Toxics
Moira McKernan, while at the American Bird Conservancy
Sue Chiang, Center for Environmental Health
Anna Lennquist, ChemSec
Jerker Ligthart, ChemSec
Kathleen A. Curtis, Clean and Healthy New York
Sharyle Patton, Commonweal
Susan Klosterhaus, Cradle to Cradle Products Innovation Institute
Mike Belliveau, Environmental Health Strategy Center
Arlene Blum, Green Science Policy Institute
Alex Madonik, Green Science Policy Institute
Xll
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David Santillo, Greenpeace International
Gary Cohen, Health Care Without Harm (IGC)
Tom Lent, Healthy Building Network
Jim Vallette, Healthy Building Network
Joelle M. Fishkin, International Association of Fire Chiefs
Ken Kraus, while at International Association of Fire Chiefs
Ken LaSala, International Association of Fire Chiefs
Ed Plaugher, International Association of Fire Chiefs
Michael Murray, National Wildlife Federation
Brian Penttila, Pacific Northwest Pollution Prevention Resource Center
Ed Hopkins, Sierra Club
Sheila Davis, Silicon Valley Toxics Coalition
Baskut Tuncak, The Center for International Environmental Law
Pam Eliason, Toxics Use Reduction Institute
Laurie Valerian, Washington Toxics Coalition
Flame Retardant Industry
Hideo Kawasaki, ADEKA CORPORATION
Tetsuo Kamimoto, ADEKA CORPORATION
Ray Dawson, Albemarle
Susan Landry, Albemarle
Robert Simon, American Chemistry Council
Jackson Morrill, American Chemistry Council
Guru Zingde, Amfine
Jay Ghosh, BASF
Nikolas Kaprinidis, BASF
Martin Klatt, BASF
Rodrigo Lima, BASF
A1 Wiedow, while at BASF
Dick Stob, BurnGard
Tim Reilly, Clariant
Adrian Beard, Clariant
Geoffrey Gettliffe, Clariant
Thomas Kelley, Dover Chemical
Maggie Baumann, FRX Polymers®, Inc.
Marc Lebel, FRX Polymers®, Inc.
Jan-Pleun Lens, FRX Polymers®, Inc.
Robert Campbell, Great Lakes Solutions, A Chemtura Business
Mary Harscher, Great Lakes Solutions, A Chemtura Business
Steve Scherrer, Great Lakes Solutions, A Chemtura Business
Gary Rex, J. M. Huber Corp.
Pierre Georlette, ICL Industrial Products
Marc Leifer, ICL Industrial Products
Sergei Levchik, ICL Industrial Products
Hanna Silberberg, ICL Industrial Products
Joel Tenney, ICL Industrial Products
Xlll
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Andy Wang, ICL Industrial Products
Gerald Roston, InPore Technologies, Inc.
Karl-Heinz Spriesterbach, Nabaltec
Brigitte Dero, Phosphorus, Inorganic & Nitrogen Flame Retardants Association
Doug Hunter, Southern Clay Products
Compounders and Resin Manufacturers
Carmen Rodriquez, Altulgas International
Emile Homsi, DSM
John Friddle, Eagle Performance Products
Robert McKay, GE Plastics (part of Sabic)
Harald Wiedemann, Huntsman
Patricia Hubbard, PolyOne
Steve Paolucci, PolyOne
Automotive Industry
Filipa Rio, Alliance of Automobile Manufacturers
Amy Lilly, Hyundai KIA America Technical Center
Jake Welland, Hyundai KIA America Technical Center
John Kreitz, Sage Automotive Interiors
Lynn Smith, United States Council for Automotive Research
Bing Xu, United States Council for Automotive Research
Aerospace Industry
Lisa Goldberg, Aerospace Industry Association
Susan Baker, Boeing
Charles Ingebretson, Boeing
John Harris, Boeing
Chris T. Zervas, Boeing
Walter Desrosier, General Aviation Manufacturers Association
Jim Boyle, Majilite
Richard Forselius, Sikorsky Aircraft/United Technology Corporation
Electronics Industry
Angus Hsieh, Acer
Fern Abrams, Association Connecting Electronics Industries (IPC)
Albert Tsang, Dell
Helen Holder, Hewlett-Packard
Cory Robertson, Hewlett-Packard
Bob Pfahl, iNEMI
Christopher Cleet, Information Technology Industry Council
Mark Ezzo, Ingersoll Rand
Steve Tisdale, Intel
Tim McGrady, LG Electronics
David Thompson, Panasonic
Mike Moss, Samsung
xiv
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Keiko Hirai, Sony
Doug Smith, Sony
Craig Hershberg, Toshiba
Shipping Pallet Industry
Mike Mullin, Brambles
David Deal, CHEP
Larry Culleen, Arnold and Porter, for iGPS
Gary Glass, iGPS
Lewis Taffer, iGPS
Bruce Torrey, iGPS
Textile Industry
Janan Rabiah, Association for Contract Textiles
Brad Miller, Business and Institutional Furniture Manufacturer's Association
Dave Panning, Business and Institutional Furniture Manufacturer's Association
John Gant, Glen Raven, Inc.
Gabe Wing, Herman Miller
Ryan Trainer, International Sleep Products Association
Aaron Smith, Kimball International Hardy Poole, National Textile Association
Barry A. Cik, Naturepedic
Yan Chen, while at Schneller
Sarah Friedman, SEAMS
Bob Beaty, TSG Finishing
Recyclers
David Wagger, Institute of Scrap Recycling Industries, Inc.
George Martin, Leigh Fibers, Inc.
U.S. Federal Government
Rohit Khanna, Consumer Product Safety Commission
Dale Ray, Consumer Product Safety Commission
Treye Thomas, Consumer Product Safety Commission
Linda S. Birnbaum, National Institute of Environmental Health Sciences and National
Toxicology Program
June K. Dunnick, National Institute of Environmental Health Sciences
Rick Davis, National Institute of Standards and Technology
Jeffrey W. Gilman, National Institute of Standards and Technology
Shannon Cuniff, while at the Office of the Secretary of Defense
Paul J. Yaroschak, Office of the Secretary of Defense
Peggy Auerbach, U.S. Army
Nikki Bass, U.S. Army
George Murnyak, while at the U.S. Army
Andrew Rak, Noblis, for the U.S. Army
Gwendolyn Hudson, U.S. EPA - Office of Children's Health Protection (ASPH Fellow)
Onyemaechi Nweke, U.S. EPA - Office of Environmental Justice
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Linda Barr, U.S. EPA - Office of Resource Conservation and Recovery
Paul Randall, U.S. EPA - National Risk Management Research Laboratory
Bradley Grams, U.S. EPA - Region 5
Stephen Sturdivant, U.S. EPA - Region 6
John Katz, U.S. EPA - Region 9
Eileen Sheehan, U.S. EPA - Region 9
Barnett Rattner, U.S. Geological Survey
State and Local Governments
Bob Boughton, California Department of Toxic Substances Control
Robert Brushia, California Department of Toxic Substances Control
June Soo Park, California Department of Toxic Substances Control
Debbie Raphael, California Department of Toxic Substances Control
Tom Hornshaw, Illinois Environmental Protection Agency
Gary Styzens, Illinois Environmental Protection Agency
Andrea Lani, Maine Department of Environmental Protection
Deborah Rice, while at the Maine Department of Environmental Protection
Alister Innes, Minnesota Pollution Control Agency
Alex Stone, Washington State Department of Ecology
International
Pim Leonards, ENFIRO
Shannon Castellarin, Environment Canada
Kate McKlerlie, while at Environment Canada
Lothar Lissner, Kooperationsstelle Hamburg IFE GmbH
Raluca Aurora Stepa, Kooperationsstelle Hamburg IFE GmbH
Harry Baikowitz, Independent Consultant
DecaBDE Partnership EPA Contacts
Clive Davies, Design for the Environment
Emma Lavoie, Design for the Environment
Technical Consultant
Lauren Heine, Clean Production Action
Abt Associates Inc.
SRC Inc.
xvi
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Table of Contents
1 Introduction 1-1
1.1 Background 1-1
1.2 Purpose of the Flame-Retardant Alternatives Assessment 1-3
1.3 Scope of the Flame-Retardant Alternatives Assessment 1-3
1.4 Chemical Alternatives Assessment as a Risk Management Tool 1-5
1.5 References 1-8
2 Products and Materials 2-1
2.1 Materials Outlined in the Scope 2-1
2.1.1 Polyolefins 2-2
2.1.2 Styrenics 2-2
2.1.3 Engineering Thermoplastics 2-2
2.1.4 Thermosets 2-4
2.1.5 Elastomers 2-5
2.1.6 Waterborne Emulsions and Coatings 2-6
2.2 Uses of decaBDE 2-7
2.2.1 Electrical and Electronic Equipment 2-8
2.2.2 Textiles 2-9
2.2.3 Building and Construction 2-9
2.2.4 Transportation 2-10
2.2.5 Storage and Distribution Products 2-11
2.3 Flammability Tests 2-11
2.4 References 2-14
3 Background on Flame Retardants 3-1
3.1 General Information on Flame Retardants 3-1
3.2 Flame Retardants Included in this Assessment 3-4
3.3 Flame Retardants Not Included in this Assessment 3-15
3.3.1 Chemicals That Were Excluded from this Assessment 3-15
3.3.2 Inherently Flame Retardant Materials 3-19
3.3.3 Nanosilicates: Clays and Colloidal Solids 3-22
3.4 Flame Retardant Modes of Action 3-24
3.4.1 Chemical Action in Condensed and Gas Phases 3-24
3.4.2 Fillers / Diluents 3-27
3.4.3 Inorganic and Hydrated Compounds and Synergists 3-27
3.4.4 Melting and Dripping 3-28
3.4.5 Smoldering (Non-Flaming) Combustion 3-28
3.5 References 3-30
4 Hazard Evaluation of DecaBDE and Alternatives 4-1
4.1 Toxicological and Environmental Endpoints 4-1
4.1.1 Definitions of Each Endpoint Evaluated Against Criteria 4-1
4.1.2 Criteria 4-4
4.1.3 Endpoints Characterized but Not Evaluated 4-7
4.2 Data Sources and Assessment Methodology 4-8
4.2.1 Identifying and Reviewing Measured Data 4-8
4.2.2 Hierarchy of Data Adequacy 4-10
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4.2.3 Assessment of Polymers and Oligomers 4-11
4.3 Importance of Physical and Chemical Properties, Environmental Transport, and
Biodegradation 4-11
4.4 Evaluating Human Health Endpoints 4-18
4.4.1 Endpoints Characterized and Evaluated Against Criteria Based on Measured
Data 4-18
4.4.2 SAR - Application of SAR and Expert Judgment to Endpoint Criteria 4-20
4.5 Evaluating Environmental Toxicity and Fate Endpoints 4-21
4.5.1 Aquatic Toxicity 4-21
4.5.2 Bioaccumulation 4-22
4.5.3 Environmental Persistence 4-23
4.6 Endocrine Activity 4-26
4.7 Hazard Summary Table 4-29
4.8 Hazard Evaluations 4-34
Aluminum Diethylphosphinate 4-34
Aluminum Hydroxide 4-52
Ammonium Polyphosphate 4-69
Antimony Trioxide 4-90
Bis(hexachlorocyclopentadieno) Cyclooctane 4-124
Bisphenol A Bis-(diphenyl phosphate), BAPP 4-148
Brominated Epoxy Polymers 4-173
Brominated Epoxy Polymer(s) 4-184
Mixture of Brominated Epoxy Polymer(s) and Bromobenzyl Acrylate 4-195
Brominated Epoxy Resin End-Capped with Tribromophenol 4-206
Brominated Polyacrylate 4-218
Brominated Poly(phenyl ether) 4-229
Brominated Polystyrene 4-249
Decabromodiphenyl Ethane 4-261
Decabromodiphenyl Ether 4-289
Ethylene Bis-Tetrabromophthalimide (EBTBP) 4-339
Magnesium Hydroxide 4-360
Melamine Cyanurate 4-381
Melamine Polyphosphate 4-432
N-alkoxy Hindered Amine Reaction Products 4-467
Phosphonate Oligomer 4-491
Phosphoric acid, mixed esters with [1,1 '-bisphenyl-4,4'-diol] and phenol; BPBP ..4-519
Polyphosphonate 4-539
Poly[phosphonate-co-carbonate] 4-551
Red Phosphorus 4-562
Resorcinol Bis-Diphenylphosphate; RDP 4-587
Substituted Amine Phosphate Mixture 4-616
Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether 4-658
Triphenyl Phosphate 4-680
Tris(tribromoneopentyl) Phosphate 4-707
Tris(tribromophenoxy) Triazine 4-723
Zinc Borate 4-736
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4.9 References 4-756
5 General Exposure Information and Other Life-Cycle Considerations 5-1
5.1 Potential Exposure Pathways and Routes (General) 5-1
5.1.1 Occupational versus General Population Exposures 5-2
5.1.2 Inhalation Exposures 5-2
5.1.3 Dermal Exposures 5-3
5.1.4 Ingestion Exposures 5-4
5.1.5 Human and Environmental Exposure to DecaBDE 5-5
5.1.6 Physical-Chemical Properties for the Alternatives to DecaBDE included in this
Assessment that May Impact Exposure 5-6
5.2 Extraction 5-13
5.2.1 Inorganic Flame Retardants 5-13
5.2.2 Halogenated Flame Retardants 5-14
5.2.3 Phosphorous-Based Flame Retardants 5-15
5.2.4 Nitrogen-Based Flame Retardants 5-16
5.3 Chemical Manufacturing 5-16
5.4 Product Manufacturing 5-18
5.5 Use 5-20
5.6 End-of-Life 5-22
5.6.1 Electronics 5-22
5.6.2 Textiles 5-26
5.6.3 Storage and Distribution Products 5-27
5.7 References 5-28
6 Considerations for Selecting Flame Retardants 6-1
6.1 Preferable Human Health and Environmental Attributes 6-1
6.1.1 Low Human Health Hazard 6-2
6.1.2 Low Ecotoxicity 6-4
6.1.3 Readily Degradable: Low Persistence 6-5
6.1.4 Low Bioaccumulation Potential 6-7
6.1.5 Low Exposure Potential 6-8
6.2 Considerations for poorly or incompletely characterized chemicals 6-9
6.3 Social Considerations 6-10
6.4 Performance Considerations 6-12
6.5 Economic Considerations 6-13
6.6 Moving Towards a Substitution Decision 6-14
6.7 Relevant Resources 6-15
6.7.1 Resources for state and local government activities 6-15
6.7.2 Resources for EPA regulations and activities 6-15
6.7.3 Resources for global regulations 6-16
6.8 The ENFIRO project 6-16
6.9 References 6-18
Appendix A Additional Reading and Background References
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List of Acronyms and Abbreviations
ABS
Acrylonitrile butadiene styrene
ACR
Acute to chronic ratio
ASTM
American Society for Testing and Materials
BAF
Bioaccumulation factor
BCF
Bioconcentration factor
BUN
Blood urea nitrogen
CA-C
Chemical action in condensed phase
CA-G
Chemical action in gas phase
CASRN
Chemical Abstracts Service Registry Number
CDC
Centers for Disease Control and Prevention
CF
Char former
CFR
Code of Federal Regulations
CHL
Chinese hamster lung cells
CHO
Chinese hamster ovary cells
ChV
Chronic value
CPE
Chlorinated polyethylene
CPSC
Consumer Product Safety Commission
D
Dilution effect
DecaBDE
Decabromodiphenyl ether
Dffi
Design for the Environment
DMSO
Dimethyl sulfoxide
EbCso
Concentration at which 50% reduction of biomass is observed
EC50
Half maximal effective concentration
ECHA
European Chemicals Agency
ECOSAR
Ecological Structure Activity Relationships
EDSP
Endocrine Disruptor Screening Program
EEC
European Economic Community
EPA
U.S. Environmental Protection Agency
EPI
Estimation Program Interface
EPDM
Ethylene propylene diene monomer
ErCso
Concentration at which a 50% inhibition of growth rate is observed
ERMA
Environmental Risk Management Authority
EU
European Union
EVA
Ethylene vinyl acetate
FAA
Federal Aviation Administration
FM
Factory Mutual
FMVSS
Federal Motor Vehicle Safety Standard
GD
Gestation day
GHS
Globally Harmonized System of Classification and Labeling of Chemicals
GLP
Good laboratory practice
HIPS
High-impact polystyrene
HPLC
High performance liquid chromatography
HPV
High Production Volume
HS
Heat sink
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HSDB
Hazardous Substances Data Bank
ICC A
International Council of Chemical Associations
I
Intumescent
I ARC
International Agency for Research on Cancer
IC2
Interstate Chemicals Clearinghouse
IDso
Median ineffective dose
IFC
International Fire Code
IFR
Inherently flame retardant
IRIS
Integrated Risk Information System
IUCLID
International Uniform Chemical Information Database
Koc
Sediment/soil adsorption/desorption coefficient
Kow
Octanol/water partition coefficient
LbL
Layer-by-layer
LC50
Median lethal concentration
LC100
Absolute lethal concentration
LCA
Life cycle assessment
LCP
Liquid crystal polymer
LD50
Median lethal dose
LD
Lactation day
LFL
Lower limit of flammability
LOAEC
Lowest observed adverse effect concentration
LOAEL
Lowest observed adverse effect level
LOEC
Lowest observed effect concentration
LOEL
Lowest observed effect level
MF
Molecular formula
MITI
Japanese Ministry of International Trade and Industry
MMT
Montmorillonite clay
MSDS
Material Safety Datasheet
MSP
Mesoporous silicate particle
MW
Molecular weight
NAS
National Academy of Sciences
NCI
National Cancer Institute
NCP
New Chemicals Program
NES
No effects at saturation
NFPA
National Fire Protection Association
NGO
Non-governmental organization
NICNAS
National Industrial Chemicals Notification and Assessment Scheme
NOAEC
No observed adverse effect concentration
NOAEL
No observed adverse effect level
NOEC
No observed effect concentration
NOEL
No observed effect level
NTP
National Toxicology Program
OECD
Organisation of Economic Cooperation and Development
OPP
Office of Pesticide Programs
OPPT
Office of Pollution Prevention and Toxics
ORD
Office of Research and Development
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PBDE
Polybrominated diphenyl ether
PA
Polyamide
PBT
Polybutylene terephthalate
PBT Profiler
Persistent, Bioaccumulative, and Toxic Chemical Profiler
PC
Polycarbonate
PC-ABS
Polycarbonate-acrylonitrile butadiene styrene
PE
Polyethylene
PET
Polyethylene terephthalate
phr
Parts per hundred resin
PMN
Premanufacture Notice
PP
Polypropylene
PPE-HIPS
Polyphenylene ether - high-impact polystyrene
ppm
parts per million
PS
Polystyrene
PVC
Polyvinyl chloride
QSAR
Quantitative Structure Activity Relationship
REACH
Registration, Evaluation, Authorisation and Restriction of Chemicals
RoHS
Restriction of Hazardous Substances
RP-BR
Red phosphorus and butyl rubber
SAR
Structure Activity Relationship
Sb
Antimony
SF
Sustainable Futures
SIDS
Screening Information Data Set
SMILES
Simplified Molecular-Input Line-Entry System
SPARC
Sparc Performs Automated Reasoning in Chemistry
SVHC
Substance of Very High Concern
tdLo
Lowest toxic dose
TL5o
Median tolerance limit
TG
Test guidelines
TPU
Thermoplastic polyurethane
TRI
Toxics Release Inventory
TSCA
Toxic Substances Control Act
TSCATS
Toxic Substance Control Act Test Submission
UCLA
University of California, Los Angeles
UFL
Upper limit of flammability
UL
Underwriters Laboratory
UPE
Unsaturated polyester
VCCEP
Voluntary Children's Chemical Evaluation Program
WAF
Water accommodated fraction
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1 Introduction
1.1 Background
As part of its effort to enhance the Agency's current chemicals management program, U.S.
Environmental Protection Agency (EPA) has taken steps to identify chemicals that may pose
environmental and health concerns; in 2009-2011 EPA developed action plans to investigate
potential regulatory and voluntary actions. In December 2009, EPA released the Polybrominated
Diphenyl Ethers (PBDEs) Action Plan1 that summarizes hazard, exposure, and use information
for three commercial PBDE mixtures, including decabromodiphenyl ether (decaBDE). DecaBDE
is a flame retardant used in a variety of applications, including textiles, plastics, wiring
insulation, and building and construction materials.
As described in the Action Plan, EPA's Design for the Environment (DfE) Program initiated this
multi-stakeholder partnership alternatives assessment: Flame Retardant Alternatives for
Decabromodiphenyl Ether (decaBDE). DfE's partnerships provide a basis for informed decision-
making by developing an in-depth comparison of potential human health and environmental
impacts of chemical alternatives. The DfE Alternatives Assessment reports provide information
of interest to a number of stakeholder groups interested in chemical hazards. As part of the
partnership on flame retardant alternatives to decaBDE, representatives from industry, academia,
federal and state governments, and non-governmental organizations (NGOs) engaged with DfE
to select and evaluate flame retardant alternatives to decaBDE and develop this report. This
report is intended to provide information that will enable the selection of safer alternatives to
decaBDE, for a variety of products.
DecaBDE has been used at high volume in a broad range of products, but is now being phased
out in the U.S. by its manufacturers (U.S. EPA 2010a). The process leading to the phase-out
began with EPA's Voluntary Children's Chemical Evaluation Program (VCCEP)2. The VCCEP
developed industry-sponsored screening level risk assessments for pentaBDE, octaBDE, and
decaBDE to evaluate the potential risks to children and prospective parents from potential PBDE
exposures (U.S. EPA 2009a). In August 2005, EPA released its Data Needs Decision documents
on PBDEs (U.S. EPA 2009a). For decaBDE, EPA indicated a need to further understand fate and
transport of decaBDE in the environment, particularly with respect to the significance of its
breakdown products, as this could relate to its risk characterization (U.S. EPA 2005). The
decaBDE data needs were not met by the VCCEP sponsors and decaBDE was subsequently
terminated from the VCCEP program (U.S. EPA 2009a). EPA then announced its intention to
proceed with a test rule under Toxic Substances Control Act (TSCA) section 4 (U.S. EPA
2009a). Before a test rule was proposed, the main manufacturers or importers volunteered to
phase out manufacture, import and sales of decaBDE (U.S. EPA 2009a).
The use of decaBDE was restricted in particular electrical and electronic equipment under the
European Union Restriction of Hazardous Substances Directive, with some exemptions (Council
1 The Polybrominated Diphenyl Ethers (PBDEs) Action Plan is available online at:
http://www.epa.gov/opptintr/existingchemicals/pubs/pbdes ap 2009 1230 final.pdf
2 Information on VCCEP is available at: http://www.epa.gov/oppt/vccep.
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of the European Union 2003; Council of the European Union 2011). Additionally, in the U.S.,
the states of Maine, Maryland, Oregon, Vermont, and Washington have imposed restrictions on
the manufacture and/or use of decaBDE in certain applications (Washington 2006; Oregon
Legislative Assembly 2009; Vermont 2009; Maine 2010; Maryland 2010). Some additional
states have proposed legislation restricting the manufacture and/or use of decaBDE; up-to-date
information on state regulations can be found in the U.S. State-level Chemicals Policy Database
maintained by the Lowell Center for Sustainable Production:
http://www.chemicalspolicv.org/chemicalspolicv.us.state.database.php (Lowell Center for
Sustainable Production: University of Massachusetts Lowell 2012). In the private sector, the
retailer Wal-Mart has reported that they banned the purchase of all consumer products containing
PBDEs, including decaBDE, from their suppliers (Layton 2011).
DecaBDE is effective in meeting fire safety standards for plastics and textiles that are used for
the manufacture of consumer electronics, appliances, wire and cable insulation, building
materials (flooring, wall coverings, and roofing), seating, electronics and paneling for cars, buses
and airplanes, and storage and distribution products including plastic shipping pallets. Few
potential alternatives to decaBDE are "drop-in" replacements (those that require negligible
process changes). Use of alternatives may necessitate additional changes in product formulation
or movement to different classes of polymers. As companies that have been using decaBDE in
their products prepare for the phase out, this alternatives assessment will be an important
resource. The information will help reduce the potential for the unintended consequences that
could result if functional, but poorly understood alternatives are chosen.
This alternatives assessment evaluated flame retardant alternatives judged by knowledgeable
stakeholders3 as most likely to be used in applications that previously had been filled by
decaBDE. This report did not evaluate efficacy of these alternatives in regards to specific
materials, product applications or related standards; stakeholders provided professional judgment
about whether chemicals are likely to meet flammability tests in various uses. The alternatives
included in this assessment are potentially viable4 and functional but not necessarily preferable.
Selection of a chemical for evaluation in the report does not denote preferability in terms of
environmental or health hazard, or any other metric. Rather, the report provides information that
will help decision makers consider environmental and human health profiles for available
alternatives, so that they can choose the safest possible functional alternative. This information
focuses on the potential hazard associated with a particular chemical. This report also presents
general information on exposures to flame retardants, life-cycle considerations, and economic,
performance, and social factors. The report provides information that will enable informed
selection of alternative flame retardants to decaBDE.
Assessments of alternatives to decaBDE have been conducted by several organizations in the
past, including the Swedish Chemicals Inspectorate, European Commission, Danish Ministry of
3 In particular, chemists and engineers at ADEKA Corporation Albemarle, Amfine Chemical Corporation, BASF,
Boeing, Clariant, Eagle Performance Products, FRX Polymers®, Inc., Great Lakes Chemical - A Chemtura
Company, PolyOne, TSG Finishing, University of Dayton ICL Industrial Products, University of Dayton Research
Institute, and University of Massachusetts - Lowell.
4 Viability refers to the functional performance of a chemical as a flame retardant in certain plastics, not the
environmental preferability of the chemical.
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the Environment, State of Illinois, State of Washington, Clean Production Action, and the
University of Massachusetts at Lowell (Pure Strategies Inc. for the Lowell Center for Sustainable
Production 2005; Illinois Environmental Protection Agency 2006; Clean Production Action
2007; Danish Ministry of the Environment 2007; European Chemicals Bureau 2007; Washington
State Department of Health 2008; Pure Strategies Inc. for Maine Department of Environmental
Protection 2010). These assessments looked at decaBDE in a range of applications including
television enclosures, other electrical and electronic equipment, textiles, residential upholstered
furniture and plastics. A few of the studies acknowledged a lack of key information on a number
of chemicals, which prevented them from conducting a full hazard assessment of the potential
alternatives. In this alternatives assessment report, DfE filled gaps with modeled data estimations
and expert judgment, and included assessment of new-to-market decaBDE alternatives.
1.2 Purpose of the Flame-Retardant Alternatives Assessment
The purpose of this alternatives assessment is to identify potentially functional and viable
alternatives for decaBDE, evaluate their human health and environmental profiles, and inform
decision makers in order for organizations to choose safer alternatives to decaBDE.
1.3 Scope of the Flame-Retardant Alternatives Assessment
The partnership refined the scope of this assessment from the PBDEs Action Plan with
information supplied by experts in industries that use decaBDE in their products and from
academics, NGOs and government participants. The assessment provides hazard information
(human toxicity, ecotoxicity and environmental fate) on flame retardants that were selected for
evaluation in this report as potentially functional alternatives to decaBDE. While this project is
not designed to recommend specific flame retardants, it does evaluate potential alternatives to
decaBDE that have the potential to be functional and viable in certain applications. Therefore,
this evaluation can support informed substitution and has the potential to identify
environmentally preferable substitutes.
The partnership on flame retardant alternatives to decaBDE is an assessment of hazards of flame
"3
retardant chemicals that are potentially functional and viable alternatives to decaBDE. These
alternatives have the potential to enable a product to meet relevant flammability standards when
used in one or more of the material classes listed below. These materials include those in which
decaBDE is currently used or was used in the past. Additionally, polycarbonate (PC) and
polycarbonate-acrylonitrile butadiene styrene (PC-ABS) were included because they can be used
with some of the alternative flame retardants. The material types that are most relevant to this
project include:
1. Polyolefins
a. Polypropylene
b. Polyethylene
c. Ethylene vinyl acetate (EVA)
2. Styrenics
a. High-impact polystyrene
b. Acrylonitrile butadiene styrene
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3. Engineering thermoplastics
a. Polyesters
i. Polybutylene terephthalate
ii. Polyethylene terephthalate
b. Polyamides, e.g., nylon
c. PC and PC blends, e.g., PC-ABS
d. Polyphenylene ether - high-impact polystyrene
4. Thermosets
a. Unsaturated polyesters
b. Epoxies (electronics, building and aerospace applications)
c. Melamine-based resins
5. Elastomers
a. Ethylene propylene diene monomer rubber
b. Thermoplastic polyurethanes
c. EVA
6. Waterborne emulsions and coatings - including but not limited to those designed for textile
back coatings such as:
a. Acrylic emulsions
b. Polyvinyl chloride emulsions
c. Ethylene vinyl chloride emulsions
d. Urethane emulsions
The scope was outlined in terms of categories of materials rather than specific applications or
end-use products because decaBDE has many varied applications. In this approach, the
partnership intended to provide toxicity and environmental fate information on potential flame
retardant alternatives for product manufacturers who must make substitution decisions, as well as
for other interested or affected parties (e.g., end users, downstream processors).
The alternative flame retardant chemicals5 will be evaluated for hazard potential independent of
the materials in which they might be used or incorporated. While the assessment will not attempt
to include comprehensive life cycle assessment (LCA) information, it will, by both inclusion and
by reference, note relevant life-cycle considerations that may aid in the selection of alternatives.
Due to these constraints, this assessment does not provide all of the information that a decision
maker may need to be able to choose an alternative flame retardant.
The report is organized as follows:
5 For the purposes of this report, 'chemicals' include both discrete substances that can be represented by a definite
structural diagram (such as methane) and reaction mixtures that cannot. Reaction mixtures include those that are
well defined with a few components (such as propylene glycol), mixtures that may be difficult to characterize and/or
are of variable composition (such as polychlorinated biphenyls or Aroclors), and polymers.
1-4
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¦ Chapter 1 (Introduction): This chapter provides background on the Partnership on Flame
Retardant Alternatives to decaBDE proj ect, including the purpose and scope of the
partnership and of this report.
¦ Chapter 2 (Products and Materials): This chapter describes the products and materials in
which decaBDE has been used, as well as technical information about flammability
standards and other performance criteria.
¦ Chapter 3 (Background on Flame Retardants): This chapter describes chemical flame
retardants generally, as well as those specific to this assessment.
¦ Chapter 4 (Evaluation of Flame Retardants): This chapter explains the chemical
assessment method used in this report and summarizes the assessment of hazards
associated with each flame retardant chemical.
¦ Chapter 5 (General Exposure Information and Life Cycle Considerations): This chapter
includes potential exposure pathways associated with flame retardants along each stage
of their life-cycle and resources for life cycle impact information that decision makers
may need.
¦ Chapter 6 (Considerations for Selecting Flame Retardants): This chapter summarizes the
results of the assessment and identifies human health, environmental, economic,
performance and social considerations for selecting alternative flame retardants.
1.4 Chemical Alternatives Assessment as a Risk Management Tool
Among other actions, the Agency chose to conduct an alternatives assessment as a suitable risk
management tool for decaBDE in the PBDEs Action Plan. The Agency chose this tool to inform
the chemical substitution that may occur as an outcome of other activities described in the Action
Plan. Chemical alternatives assessments provide information on the environmental and human
health profiles of chemicals that may be used as substitutes so that industry and other
stakeholders can use this information, in combination with analyses of cost, performance, and
other factors to choose alternatives.
Chemical alternatives assessment, LCA, and risk assessment are all tools that can be used to
improve the sustainability profiles of chemicals and products. These tools, which can be
complementary, should be selected according to the ultimate action they are intended to support
and other regulatory and policy considerations. DfE alternatives assessments establish a
foundation that other tools, such as risk assessment and LCA, can build upon.
The focus of this DfE alternatives assessment report is a comparative hazard assessment of the
chemical alternatives that may be substituted for decaBDE in a variety of uses. Comparative
chemical hazard assessment is a comparison of chemicals within the same functional use group
(e.g., solvent, surfactant, flame retardant, ink developer) that evaluates alternatives across a
consistent and comprehensive set of hazard endpoints. Information about chemical hazards
derived from this type of comparative chemical hazard assessment can be used by decision-
1-5
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makers, in combination with other inputs, such as information on cost and performance, to select
safer alternative chemicals.
In many cases, the hazard status of chemicals included in DfE Alternatives Assessments is not
fully characterized by empirical data. A full data set would improve any assessment.
Unfortunately, a full empirical data set is not available for most chemicals. Because EPA
authority to require data is limited (e.g., EPA has no minimum measured data requirements for
new chemicals (U.S. EPA 2009b; U.S. EPA 2010b)) and because developing such data is
expensive and takes time, EPA has developed a suite of predictive modeling tools to estimate
chemical hazard (U.S. EPA 2010b). EPA uses modeled data and subject matter expertise to fill
data gaps for the TSCA new chemicals program when little or no experimental data are
submitted. Although modeled data should be interpreted with care, when combined with
available empirical data, the data set comprises the best available information. Even with a
reliance on modeled data for some endpoints information from DfE Alternatives Assessment can
support decision making concerning safer alternative chemicals.
Risk assessment and alternatives assessment are both based on the premise that risk is a function
of hazard and exposure. Risk assessment characterizes the nature and magnitude of hazard and
exposure from chemical contaminants and other stressors. The DfE alternatives assessment
evaluates and compares the nature of the chemical hazards and reflects a view that when
exposure is comparable, risk is reduced through the use of less hazardous chemicals. Alternatives
assessment strives to decrease the reliance on exposure controls thus reducing risk even when
exposure controls fail.
Chemical alternatives assessment differs substantially from LCA. An LCA can present a robust
picture of many environmental impacts associated with the material and energy inputs and
outputs throughout the life cycle of a product, and by doing so can identify opportunities for
reducing those impacts. However, unlike chemical alternatives assessment, LCA typically
provides a limited (if any) review of inherent toxicity.
DfE's 'functional use' approach to alternatives assessment orients chemical evaluations within a
given product type and functionality. Under this approach, factors related to exposure scenarios,
such as physical form and route of exposure, can be constant within a given functional use
analysis and will fall out of the comparison so that a reduction in hazard is a reduction of risk.
When less hazardous alternatives have different physical-chemical profiles or require different
use levels, it may be appropriate to also conduct an exposure assessment. DfE alternatives
assessments consider intrinsic properties of chemical substitutes that affect exposure potential,
including absorption potential, persistence, and bioaccumulation. Under this approach, the health
and environmental hazard profiles in the alternatives assessments become the key variable and
source of distinguishing characteristics. Information on key properties that can be used to
evaluate significant differences in environmental fate and transport, including persistence,
bioaccumulation, and physical properties, are included in Chapters 4 and 5.
Chemical alternatives assessment is most useful in identifying safer substitutes when available
alternatives meet performance requirements and are expected to present lower hazards for human
health and the environment. This report relied on literature review and expert stakeholders to
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select the chemicals now included in this report. These chemicals were chosen as likely, but not
necessarily proven, functional alternatives. While their performance in specific products must be
verified, the information in Table 3-2 of this report on functionality is, at a minimum, a good
start to understanding which alternatives might be valuable for a given functional use. Although
the information in Table 3-2 does provide useful information, performance and efficacy of the
alternatives are not the primary focus of this report. Product manufacturers transitioning to new
flame retardants may have to test a number of chemicals or chemical combinations to determine
if they meet performance requirements in final products. During decision-making, risk
assessment or LCA could be applied to the lower-hazard or potentially preferable alternatives to
complement the alternatives assessment findings. Alternatives assessment can identify scenarios
in which initial comparisons indicate that there may be no preferable alternatives to the chemical
being considered. However, this can guide innovation and product development by
understanding the characteristics of a safer alternative.
The DfE chemical alternatives assessment approach is aligned with green chemistry principles6.
Two of those principles are especially noteworthy:
¦ Principle 4: Design of safer chemicals - "Chemical products should be designed to effect
their desired function while minimizing their toxicity," and
¦ Principle 10: Design for degradability - "Chemical products should be designed so that at
the end of their function they break down into innocuous degradation products and do not
persist in the environment."
DfE incorporates these two green chemistry principles in its criteria and applies them in its
assessment of chemical hazard and fate in the environment. This approach enables identification
of safer substitutes that emphasize greener chemistry and points the way to innovation in safer
chemical design where hazard becomes a part of a performance evaluation.
6 http://www.epa. gov/sciencematters/iune2011/principles.htm
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1.5 References
Clean Production Action (2007). The Green Screen for Safer Chemicals: Evaluating Flame
Retardants for TV Enclosures.
Council of the European Union (2003). Restriction of Hazardous Substances European
Parliament and the Council of the European Union. Official Journal of the European
Union 2002/95/EC.
Council of the European Union (2011). Restriction of the use of certain hazardous substances in
electrical and electronic equipment (recast). European Parliament and the Council of the
European Union. Official Journal of the European Journal. Directive 2011/65/EU.
Danish Ministry of the Environment (2007). Health and Environmental Assessment of
Alternatives to Deca-BDE in Electrical and Electronic Equipment. Environmental
Protection Agency.
European Chemicals Bureau (2007). Review on production processes of decabromodiphenyl
ether (decaBDE) used in polymeric application in electrical and electronic equipment,
and assessment of the availability of potential alternatives to decaBDE. Institute on
Health and Consumer Protection.
Illinois Environmental Protection Agency (2006). A Report to the General Assembly and the
Governor In Response to Public Act 94-100 DecaBDE Study: A Review of Available
Scientific Research.
Layton, L. (2011). Wal-Mart bypasses federal regulators to ban controversial flame retardant.
Washington Post.
Lowell Center for Sustainable Production: University of Massachusetts Lowell. (2012). "U.S.
State-level Chemicals Policy Database." Retrieved January 5, 2012, from
http://www.chemicalspolicv.org/chemicalspolicv.us.state.database.php.
Maine (2010). Restriction on Sale and Distribution of Brominated Flame Retardants. Title 38
§1609.
Maryland (2010). Environment - Decabrominated Diphenyl Ether - Prohibitions. Senate Bill
556: Chapter 320.
Oregon Legislative Assembly (2009). Relating to decabrominated diphenyl ether; creating new
provisions; and amending ORS 453.005, 453.025 and 453.085. Senate Bill 596.
Pure Strategies Inc. for Maine Department of Environmental Protection (2010).
"Decabromodiphenyl Ether Flame Retardant in Plastic Pallets: A Safer Alternatives
Assessment."
Pure Strategies Inc. for the Lowell Center for Sustainable Production (2005).
Decabromodiphenyl ether: An Investigation of Non-Halogen Substitutes in Electronic
Enclosure and Textile Applications, University of Massachusetts Lowell.
U.S. EPA. (2005). "Voluntary Children's Chemical Evaluation Program: Data Needs Decision
Document of Decabromodiphenyl Ether, June, 2006." Retrieved November 18, 2013,
from http://www.epa.gov/oppt/vccep/pubs/finaldeca.pdf.
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U.S. EPA. (2009a). "Polybrominated Diphenyl Ethers (PBDEs) Action Plan." Retrieved
November 18, 2013, from
http://www.epa.gov/opptintr/existingchemicals/pubs/actionplans/pbdes ap 2009 1230 fi
nal.pdf.
U.S. EPA. (2009b). "Statement of Lisa P. Jackson Administrator, U.S. Environmental Protection
Agency Legislative Hearing on the Toxic Substances Control Act (TSCA) Senate
Committee on Environment and Public Works December 2, 2009." Retrieved November
18, 2013, from http://www.epa.gov/aging/press/epanews/2009/2009 1202 2.htm.
U.S. EPA. (2010a). "DecaBDE Phase-out Initiative." Retrieved March 23, 2011, from
http://www.epa.gov/oppt/existingchemicals/pubs/actionplans/deccadbe.html.
U.S. EPA. (2010b). "TSCA New Chemicals Program (NCP) Chemical Categories." Retrieved
November 18, 2013, from
http://www.epa.gov/oppt/newchems/pubs/npcchemicalcategories.pdf.
Vermont (2009). An Act Relating to Health Care Reform. H.444.
Washington (2006). An act relating to brominated flame retardant. House Bill (HB) 1488/Senate
Bill (SB) 5515.
Washington State Department of Health (2008). Alternatives to Deca-BDE in Televisions and
Residential Upholstered Furniture. Department of Ecology. Olympia, WA.
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2 Products and Materials
Decabromodiphenyl ether (decaBDE) is used for fire safety in a broad range of plastics and
polymers with product applications in diverse sectors. Presented below are the categories of
materials (Section 2.1) and sectors and products (Section 2.2) for which decaBDE has been or is
currently used. Flammability standards relevant for products containing decaBDE are discussed
briefly at the end of the chapter (Section 2.3).
2.1 Materials Outlined in the Scope
The materials included in this section are those in which decaBDE is currently or was used in the
past across the globe. Additionally, polycarbonate (PC) and polycarbonate-acrylonitrile
butadiene styrene (PC-ABS) were included because they can be used with some of the
alternative flame retardants. These materials are polymers, made up of chains of repeating
monomer units. Table 2-1 displays end-uses by polymer group, each of which may contain
several different polymers. A key characteristic of these polymers is whether or not they can be
reprocessed and therefore this is touched on in each section. The end-use products and sectors for
these materials are discussed in Section 2.2. DecaBDE may not be used in all polymer/end-use
application combinations; those relevant to decaBDE are noted in Section 2.2.
Table 2-1: Summary of Polymers and Their End-Use Application
Polymer Group
End-Use Applications
Electronics
Wire and
Cable
Public
Buildings
Construction
Materials
Automotive
Aviation
Storage and
Distribution
Products
Textiles
Waterborne
emulsions &
coatings
Polyolefins
s
s
~
~
~
~
Styrenics
s
~
~
~
Engineering
Thermoplastics
s
~
~
s
~
~
s
~
Thennosets
s
~
s
~
~
~
s
~
Elastomers
s
s
s
s
~
~
~
s
s
Waterborne
emulsions and
coatings1
s
s
s
s
s
s
Includes acrylic, polyvinyl chloride (PVC), ethylene vinyl chloride, and urethane emulsions
Source: Personal communication with members of the partnership
2-1
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2.1.1 Polyolefins
There are a variety of polyolefins but only three in which decaBDE is commonly used:
polypropylene (PP), which has the molecular formula (MF) (C3H6)n; polyethylene (PE), which
n
has the MF (C2H4)n; and ethylene vinyl acetate (EVA) , which is a copolymer of ethylene and
vinyl acetate, (C2H4)m (C4H602)n (Mark 2009). Polyolefins are polymers with single carbon
bonds, but are derived from hydrocarbons with carbon-carbon double bonds (e.g., ethylene). The
basic repeating unit has the MF (CnH2n). Polyolefins can soften and eventually melt upon
heating. As a result, they can be reprocessed which allows them to be remolded repeatedly
(Harper and Modern Plastics 2000; Rex 2011). Polyolefin materials can be flexible and are used
for applications such as garbage bags, undergarments for wet suits, foam shoes, seat cushions,
arm rests, shrink film, and other products (Mark 2009). Additional important polyolefins
applications include wire and cable, electrical connectors, battery casings, foamed sheets and
pipes for thermal insulations.
2.1.2 Styrenics
Styrenics are based on styrene monomers, also known as vinyl benzene, which consist of a
phenyl group attached to a two-carbon chain, CH2=CH(C6H5). There are several different types
of styrene plastics, two of which can contain decaBDE: high-impact polystyrene (HIPS) and
acrylonitrile butadiene styrene (ABS). Polystyrene (PS) and styrene copolymers tend to be
brittle, so rubber particles are added to increase impact resistance (Howe-Grant 1997a; Rex
2011). Like polyolefins, styrenics can soften and eventually melt upon heating. As a result, they
can also be reprocessed which allows them to be remolded repeatedly (Harper and Modern
Plastics 2000; Rex 2011). The following descriptions provide an overview of each material and
its general application.
HIPS. HIPS is produced by combining PS with rubber particles, which gives it the
mechanical properties that make it suitable for use in durable molded items. Its historical
use in television casings is a well-known example (Harper and Modern Plastics 2000).
ABS. ABS is a mixture of acrylonitrile, butadiene, and styrene. In general, ABS is widely
used in the casing of equipment for telephones, televisions, and computers (Harper and
Modern Plastics 2000).
2.1.3 Engineering Thermoplastics
Engineering thermoplastics are materials that are typically not cross-linked, can soften and
eventually melt upon heating, and have high levels of mechanical and thermal performance in
molded goods when compared to commodity thermoplastics (e.g., PP, PE, HIPS, etc.). As a
result, thermoplastics can be reprocessed (Harper and Modern Plastics 2000). This property of
thermoplastics allows them to be remolded repeatedly. There are several types of engineering
thermoplastics in which decaBDE can be used, including polyester, polyamide (PA), PC, and
7 EVA is a copolymer of ethylene (an olefin) and vinyl acetate, therefore it is considered to be a polyolefin.
However, EVA also has elastomeric properties. For this reason, this report classifies EVA as both a polyolefin and
an elastomer. For further discussion on EVA, see Section 2.1.5 on elastomers.
2-2
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polyethylene ether - high-impact polystyrene (PPE-HIPS). The following descriptions provide
an overview of each material and their general applications.
Polyesters. Polyesters (see Figure 2-1) are a broad class of thermoplastics characterized
by an ester linkage. Within this class, decaBDE can be used in polybutylene terephthalate
(PBT) and polyethylene terephthalate (PET). The only structural difference between PBT
and PET is the presence of four methylene repeat units in each PBT repeat unit rather
than the two present in each PET repeat unit. PBT has numerous automotive applications
such as the exterior as well as connectors for under-the-hood electronic controls. Another
major use of PBT is in glass-reinforced grades that are often in switches and connectors
for electrical equipment. PET has many commercial applications in injection moldings,
blow-molded bottles, and films (Harper and Modern Plastics 2000). Polyesters are also
used in commercial and domestic carpeting and textile fibers.
Figure 2-1: Chemical Structure of Polyester
o o o o
A A j-r' A A J-*.
H-O R cri O R 0*Tn O-H
PAs. PAs (see Figure 2-2), also referred to as nylons, are characterized by amide groups
along the polymer backbones. There are several types of PAs, the majority of which are
used in injection molding applications in information technologies and the transportation
industry, mostly for automobiles. PAs are used in automobile exteriors (e.g., wheel
covers and handles), interiors (e.g., chair and seat belt mechanisms and light housings),
under-the-hood applications, and commercial and domestic carpeting and textile fibers
(Howe-Grant 1997d). Glass-reinforced grades also use PAs in electrical switches and
connectors.
Figure 2-2: Chemical Structure of PA and
Nylon
o o
PA Nylon
PCs. PCs (see Figure 2-3) contain a carbonate group and have an excellent combination
of mechanical properties, which make them ideal for a variety of applications. PC is a
good choice for applications requiring higher use temperatures, lower flammability, and
greater impact strength, assuming that the application can afford the higher cost of PC.
They are commonly used to manufacture roofing panels, windows for aircraft, trains, and
schools, and to make automotive components, such as headlamps and bumpers.
Additionally, PC is used to make plastic bottles, CDs & DVDs, electrical equipment,
especially connectors, and motorcycle and football helmets. PC is also commonly
blended with other materials, such as ABS, to achieve lower cost and improved
2-3
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properties (Howe-Grant 1997e). For example, sometimes PC is added to polymers to
impart improved thermal deflection properties. PC-ABS blends are used for equipment
housing and structural parts that require high levels of stiffness, gloss, and impact
resistance (Weil and Levchik 2009).
Figure 2-3: Chemical Structure of PC
o
,, J--Fk JK J-Fk
H-on O Oli O-H
PPE-HIPS. PPE-HIPS, a polymer blend, imparts a higher heat resistance compared to PS.
PPE-HIPS is commonly used for dishwashers, washing machines, hair dryers, cameras,
instrument housings, and in television accessories (Harper and Modern Plastics 2000).
2.1.4 Thermosets
Thermosets (also referred to as 'thermoset plastics') undergo an irreversible chemical cross-
linking reaction upon curing. Unlike styrenics, polyolefins and thermoplastics, thermosets cannot
be reprocessed once they cure/polymerize; they are insoluble in most solvents and can only be
broken up by breaking chemical bonds (Mark 2009). While the inability to reprocess thermosets
presents some drawbacks, it also gives thermoset plastics enhanced properties that are
maintained in extreme conditions (Harper and Modern Plastics 2000). There are several types of
thermosets in which decaBDE can be used, including unsaturated polyesters (UPEs), epoxies,
and melamine-based resins. The following descriptions provide an overview of each material and
their general applications.
UPE. UPEs are produced from maleic anhydrides and alcohols, and are used to produce
molding compounds. UPEs contain an unsaturated diacid (typically maleic acid or
fumaric acid) which can be cross-linked during the curing process; additionally a reactive
solvent/monomer is also added before curing (American Composites Manufacturers
Association 2004). Other acids and alcohols are added for desired chemical properties.
Typical applications include automotive and building components, commercial
connectors, and various household articles (Harper and Modern Plastics 2000; Troitzsch
2004).
Epoxies. Epoxies are co-polymers formed from the reaction of two chemicals: a resin that
consists of a short chain polymer with epoxy groupings at either end and a hardening or
cross linking agent. The reaction forms a three-dimensional lattice. These epoxies have
excellent adhesion properties as well as chemical and heat resistance. As a result, they
can be used in thermal insulation as well as in electronics (Mark 2009). Epoxies are used
broadly, from high-performance military to commodity commercial applications, such as
connectors, relays, printed circuit boards, switches, coils, aircraft skins, and satellite parts
(Harper and Modern Plastics 2000).
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Melamine-BasedResins. Melamine-based resins are a type of amino resin made by
combining melamine (C3H6N6) with formaldehyde (CH2O). Melamine-based resins are
used as textile-finishing materials to provide wash-and-wear properties to cellulosic
fabrics (Howe-Grant 1997b).
2.1.5 Elastomers
Elastomers are rubberlike materials that can recover their original shape after being stretched or
compressed (Howe-Grant 1997c). There are three types of elastomers in which decaBDE can be
used: (1) ethylene propylene diene monomer (EPDM) rubber, (2) thermoplastic polyurethanes
o
(TPUs), and (3) EVA . The following descriptions provide an overview of each material and
their general applications.
EPDM. EPDM (see Figure 2-4) is a copolymer of ethylene, propylene, and a diene, and is
mainly used in automotive applications as radiator hoses and seals; in building and
construction as roofing membranes and pond liners; in cable and wire as insulation and
jacketing; and in appliances as molded components (Howe-Grant 1997c; Ciesielski
2000).
TPUs. TPUs contain carbamate groups, also referred to as urethane groups, in their
backbone structure (Howe-Grant 1997f). The mechanical properties of TPUs fall between
rubber polymers and thermoplastics, and they are made into products through injection or
extrusion. TPUs have a variety of uses in automobiles, as well as in medical equipment,
wire and cable, and other applications (Randall 2010).
8 EVA is a copolymer of ethylene (an olefin) and vinyl acetate, therefore it is considered to be a polyolefin.
However, EVA also has elastomeric properties. For this reason, this report classifies EVA as both a polyolefin and
an elastomer.
Figure 2-4: Chemical Structure of EPDM Polymer
EPDM
Common Example of EPDM.
Note: "a" is small compared to "b" and "c".
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EVA. EVA (see Figure 2-5) is typically used in 'hot-melt' formulations. EVA based hot-
melts have various applications, such as packaging, bookbinding and labeling
(SpecialChem 2011).
2.1.6 Waterborne Emulsions and Coatings
There are three types of waterborne emulsions and coatings in which decaBDE can be used:
acrylic, PVC and ethylene vinyl chloride, and urethane. The following descriptions provide an
overview of each material and their general applications.
Acrylic. Acrylic emulsions are aqueous, anionic, emulsion-polymerized dispersions of acrylate
copolymers. According to a manufacturer website, acrylic emulsions are used for their heat
sealability, resistance to heat and light discoloration, good initial color and clarity, and overall
durability (Lubrizol 2011). Acrylic emulsions may fade over time, depending on the quality of
the colorants or pigments used (Jones 2004; Friddle 2011). Acrylic emulsions span a wide range
of polymer and end-use properties. While acrylic emulsions are frequently used in nonwoven and
paper saturation applications, many are equally applicable for paint and coatings applications.
These formulations can be molded into very soft, flexible coatings or very hard, stiff coatings
(Friddle 2011).
PVC and Ethylene Vinyl Chloride. Vinyl chloride emulsions are aqueous anionic dispersions of
vinyl chloride and copolymers. These emulsions are primarily designed for coating,
impregnation and saturation of fibrous materials such as paper, nonwovens and textiles. Their
heat reactive nature poses excellent adhesion to various substrates, and they are commonly used
in wall covering and resilient flooring (Friddle 2011).
Vinyl chloride polymers are used in textile coatings, nonwovens, paper, paints, and graphic arts
applications. Ethylene vinyl chloride polymers are used in a variety of adhesive applications,
such as paper packaging, wood bonding, furniture, book binding, wall and ceiling coverings,
flooring, consumer glues, and film laminates (Friddle 2011).
Urethane. Polyurethanes (see Figure 2-6) are the most well-known polymers used to make
foams, though they can also be elastomers. Polyurethane materials are commonly formulated as
paints or finishing coats to protect or seal wood and textiles (Friddle 2011).
Figure 2-5: Chemical Structure of EVA
o
2-6
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2.2 Uses of decaBDE
The purpose of this section is to highlight the various uses of decaBDE. The profile of industries
and products using decaBDE has changed in recent years, mainly due to changing international
and state-based regulations. Segmentation of decaBDE uses by weight in the U.S. is suggested to
be 26 percent for textiles, 26 percent for automotive/transportation, 26 percent for building and
construction, 13 percent for electrical and electronic equipment, and 9 percent for other uses
(Levchik 2010). This data does not include imports of manufactured goods into the U.S. At the
time of publication of this report, this data was the most conclusive information located in light
of the shifting landscape of decaBDE uses in certain industries and products. For information on
exposure to flame retardants due to the use of these products, see Chapter 5. The uses of
decaBDE outlined in this chapter are global uses, however, in regards to any regulatory statutes
which require the use of flame retardants in this report, these are more U.S. based unless
otherwise stated.
Many electronics manufacturers have moved away from using decaBDE in HIPS, especially in
Europe, where the Restriction of Hazardous Substances (RoHS) Directive has banned the use of
decaBDE in electronics with certain exemptions (Council of the European Union 2003;
Washington State Department of Health 2008; Council of the European Union 2011). A use
profile of decaBDE for the years prior to RoHS was not available when this report was compiled.
However, in 2003 it was estimated that 80 percent of decaBDE was used in electronics (which
included television enclosures, central processing unit housing and wire and cable) and 10 to 20
percent of decaBDE was used in textiles (which included upholstered furniture and automotive
upholstery) (Hardy 2003). Additionally, although HIPS containing decaBDE was once used in
office machines such as printers, copiers, and fax machines, these products are now made using
other types of plastics that do not contain decaBDE (Pure Strategies Inc. for Maine Department
of Environmental Protection 2010). To the best of our knowledge decaBDE was not used in
mattresses or polyurethane foam for furniture, but can be used in textile back-coatings for
furniture (Trainer 2010). For further information on flame retardants for polyurethane foam, refer
to the Profiles of Chemical Flame-Retardant Alternatives for Low-Density Polyurethane Foam
report (U.S. EPA 2005).
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2.2.1 Electrical and Electronic Equipment
Historically, most decaBDE was used in
electrical and electronic equipment in plastic
casings, wire and cable and small electrical
components to meet fire safety standards
(see Table 2-2). The main use of decaBDE
was in the front and back panels of
televisions made of HIPS (Levchik 2010).
Additionally, decaBDE was often used in
electronic connectors made from glass-filled
PBT or nylons (Levchik 2010). With the
European RoHS Directive, many global
companies have phased out decaBDE in
these uses.
Despite this transition, decaBDE is still used
in a variety of electronic equipment
including household appliances and tools
such as vacuum cleaners (in both the casings
and internal components) and washing
machines (internal components only)
because the markets for these products are
more domestic than global and European Union regulations have not impacted the use of
decaBDE in these products as significantly (Levchik 2010). In these appliances, the housings are
typically made from PP, HIPS or ABS.
Another use of decaBDE is in small electrical parts, such as light sockets or decorative lights
(e.g., Christmas lights), and wires and cables. These products are usually made from high density
PE, PP or PPE (Levchik 2010). DecaBDE is also used in the plastics PBT and PA, which are
found in electrical, automotive, and plumbing parts such as housings, switches and other small
inner parts of larger electrical equipment (Weil and Levchik 2009). DecaBDE is also commonly
used in electrical components of cars and airplanes, which will be discussed in Section 2.2.4.
Box 2-1 DecaBDE is, or has been, used in the
following electric and electronic applications:
¦
Housings and internal components of TVs
¦
Mobile phones and fax machines
¦
Audio and video equipment
¦
Remote controls
¦
Communications cables
¦
Capacitor films
¦
Building cables
¦
Wire and cable, e.g., heat shrinkable tubes
¦
Connectors in electrical and electronic
equipment
¦
Circuit breakers
¦
Coils of bobbins (i.e., for use in
transformers)
¦
Printing and photocopy machine
components - e.g., plastic housing for
toner cartridges
¦
Scanner components
Source
Bromine Science and Environmental Forum
2007
2-8
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2.2.2 Textiles
Another major use of decaBDE is in textiles.
Flame retardants are applied to textiles in order to
meet required flammability standards (see Table
2-2). They are often applied to the back of a
fabric as part of a coating that also contains
antimony trioxide in an acrylic or EVA
copolymer (Pure Strategies Inc. for the Lowell
Center for Sustainable Production 2005).
The uses of decaBDE in textiles for the
automotive and aviation sectors are discussed in
more detail in Section 2.2.4. DecaBDE is not
used in consumer clothing (e.g., children's
pajamas) (Pure Strategies Inc. for the Lowell
Center for Sustainable Production 2005) or in
residential carpet (Levchik 2010). Residential
carpet is mainly flame retarded by addition of
aluminium hydroxide to the back coating.
Children's pajamas often meet flammability
standards without the use of flame retardants.
This is because children's pajamas need to pass the Consumer Product Safety Commission
(CPSC) ignition test (three seconds of flame exposure), which can be passed by synthetic fabrics
without addition of any flame retardant (Levchik 2010).
2.2.3 Building and Construction
DecaBDE is used in wall and roof panels, which
are typically made from UPE glass composites;
floor tiles; and commercial grade carpeting.
DecaBDE is also used in insulation materials,
foamed polyolefins, and in roofing materials
such as membranes and films for use under roofs
to protect building areas. DecaBDE can also be
found in ducting elements such as the duct
covering or insulation.
Box 2-2 DecaBDE is or has been used in the
following textile applications:
o
Transportation
¦ Public transit busses
¦ Trains
¦ Airplanes
¦ Ships
o
Public occupancy spaces
¦ Draperies of theatres, hotels,
conference rooms, student
dormitories
o
High-risk occupancy areas
¦ Furniture of nursing homes,
hospitals, prisons, hotels
o
Military
¦ Tarps
¦ Tents
¦ Protective clothing
Source
Bromine Science and Environmental
Forum 2007
Box 2-3 DecaBDE is used in the following
building and construction applications:
¦ Pipes
¦ Lamp holders
¦ Stadium seats
¦ Reinforced plastics
¦ Switches and connectors
¦ Facing laminates for insulation panel
¦ Film for use under the roof and to
protect building areas
¦ Electrical ducts and fittings
¦ Components in analytical equipment in
industrial
¦ Medical laboratories
¦ Air ducts for ventilation systems
¦ Pillars for telephone and
communication cables
Source: Bromine Science and Environmental Forum
2007
2-9
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2.2.4 Transportation
In automobiles, decaBDE is added to plastics used to house and insulate electrical and electronic
equipment under the hood. There are no broad federal fire safety standards or regulations for
these applications; safety standards are established by each manufacturer. Interior materials, such
as cushioning and fabric must meet the Federal Motor Vehicle Safety Standard (FMVSS) No.
302 (U.S. Department of Transportation and National Highway Traffic Safety Administration
1972; Levchik 2010). DecaBDE may also be used in parts of the heating, ventilation, and air
conditioning system close to or in contact with electrical parts (Levchik 2010).
In aircraft, decaBDE is used in electrical and electronic equipment (Levchik 2010), and interior
components. Materials used on aircraft must meet Federal Aviation Administration (FAA)
Technical Standard Orders (FAA 2010).
DecaBDE was likely also used in electronic parts for trains, ships, and elsewhere in the
transportation industry for which there was not direct stakeholder representation in the
partnership.
Box 2-4: DecaBDE is used in the following
Automotive uses:
aviation and automotive applications
o Electrical & electronic equipment
¦ Battery cases
Aviation uses:
¦ Battery trays
o Electrical wiring and cables
¦ Engine controls
o Interior components
¦ Electrical connectors
o Electric & electronic equipment
¦ Components of radio, disk, GPS
¦ Navigation and
and computer systems
telecommunications equipment
o Reinforced plastics
¦ Computers and computer
¦ Instrument panels
devices
¦ Interior trim
¦ Audio and video equipment
o Under hood and internal parts
¦ Electrical connectors
¦ Terminal/fuse block
¦ Galley appliances
¦ Higher amperage wire and cable
¦ Housings and internal
jacketing (ignition wires)
components of entertainment
o Fabric back coating
units
¦ Rear deck
¦ Remote controls
¦ Upholstery
¦ Communications cables
¦ Sun visor
¦ Capacitor films
¦ Head rest
¦ Cables
¦ Trim panel
¦ Circuit breakers
¦ Cartridges and connectors
¦ Air ducts for ventilation systems
¦ Electrical ducts and fittings
Source: Bromine Science and Environmental Forum
¦ Switches and connectors
2006; Baker 2011
2-10
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2.2.5 Storage and Distribution Products
There are approximately three billion shipping pallets in use in the U.S., of which over 900
million are plastic (Pure Strategies Inc. for Maine Department of Environmental Protection
2010). According to the National Fire Protection Association (NFPA), plastic pallets that have
not been treated with flame retardants are considered a greater fire hazard than wooden pallets.
Plastic pallets are typically made of polyolefins, which are very combustible if they are not flame
retarded.
Additionally, the International Fire Code (IFC), a widely adopted fire code but separate from the
NFPA, requires plastic pallets be protected by an approved specialized engineered fire protection
system unless they meet Underwriters Laboratory (UL) 2335 standards (see Table 2-2). Even
though wood ignites at a lower temperature than plastic, once a fire begins, plastic burns at a
higher temperature, and thus releases more heat (Pure Strategies Inc. for Maine Department of
Environmental Protection 2010). NFPA 13 and IFC provide the basis for all state and local fire
prevention laws and regulations governing warehouse construction and management throughout
the country (Pure Strategies Inc. for Maine Department of Environmental Protection 2010).
To comply with fire standard NFPA 13, plastic pallets must comply with one of the two
following options: (1) users must implement systems such as pallet storage management
practices (e.g., how high the pallets are stacked and how close together stacks of pallets are) or
sprinkler systems in warehouses that make it as safe as wooden pallets to use non-flame retarded
plastic pallets, or (2) the pallets must pass tests consistent with American National Standards
Institute/Factory Mutual (FM) 4996 (see Table 2-2) that demonstrate that the fire hazard of the
plastic pallet or other material handling product is less than or equal to the fire hazard of a
wooden pallet (FM Approvals 2013). In order to meet the fire code specifications, flame
retardants, often decaBDE, are integrated into plastic pallets to reduce the pallet's fire hazard
(Levchik 2010; Pure Strategies Inc. for Maine Department of Environmental Protection 2010).
2.3 Flammability Tests
DecaBDE is used as a flame retardant in certain products in the U.S. either because of state or
federal fire safety standards or for insurance purposes. Rather than specifying what flame
retardants should be used, such standards specify the performance standards a product must meet
under fire stress (Posner and Boras 2005). The stringency of the standard varies depending on the
application (e.g., flammability requirements established for aircraft are much more stringent than
those for clothing). Furthermore, decaBDE is sometimes added to products even without
manufacturer requirements due to concerns for brand image and market pressure (Illinois
Environmental Protection Agency 2007). Flammability standards may be developed by a variety
of entities, including regulatory agencies such as the CPSC, or companies such as UL.
Table 2-2 provides a brief overview of the flammability tests required for a variety of products in
which decaBDE is used. This list is not comprehensive but does address many of the standards
which lead to the use of decaBDE in the sectors discussed above.
2-11
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Table 2-2: Summary of Flammability Tests Relevant to decaBDE Uses.
Test
Sectors and Products that Use
Test
Description
UL 94
Electrical and Electronic
Equipment: electronic enclosures
Assesses resistance to ignition from small internal (short
circuit) or external (candle) ignition source. Small scale
ignition resistance test.
UL 746 pt C
Electrical and Electronic
Equipment: plastics in electronics
and electrical parts
Based onUL 94.
NFPA 701
Textiles: public occupancy
spaces: e.g., draperies of theatres,
hotels, conference rooms, student
dormitories
Assesses the propagation of a flame beyond the area exposed
to the ignition source. A burner flame is applied for 45
seconds. To pass the test an average weight loss for ten
specimens must be less than forty percent and fallen fragments
should not burn more than two seconds.
California
Technical
Bulletin 133
Textiles: high risk occupancy
areas: e.g., furniture of nursing
homes, hospitals, prisons, hotels
Uses a full scale piece of furniture or mock up. Designed as a
screening test. The fabric is exposed to a 1.5 inch methane
flame for twelve seconds. Drips, burn time and char lengths are
monitored along with temperature, mass lost, smoke and
carbon monoxide.
FM 4880
Building and Construction:
public occupancy decorative wall
and roof panels
Uses 750 lbs. of wood crib. The test ends when the flame
reaches the structural limits or the crib stops burning. Tested
material must not support self-propagating fire reaching
structural limits.
American
Society for
Testing and
Materials
(ASTM) E-
84
Building and Construction:
insulation materials, foamed
polyolefins, membranes, films
sheets, ducting elements, ducts
covering and insulation
Assesses the flame spread and smoke index. The tested
material is mounted on the ceiling of the tunnel. Two gas
burners are applied for ten minutes. The flame spread index
and smoke index are calculated in relation to the flame spread
and smoke density of red oak panels and concrete.
ASTM
E648-10el
Building and Construction:
public occupancy floor tiles and
carpeting
Measures the critical radiant flux, which is the minimum heat
flux needed for materials to propagate the flame. The burning
distance is converted to a critical radiant flux through the
known flux distribution along the length of the test sample.
FMVSS 302
Automotive and Aviation: car
seats, headliners, carpets, door
panels, dash panels
Assesses flame spread from cigarettes and matches in the
passenger compartment. A 1.5 inch flame is applied for fifteen
seconds and flame travel and its speed on a horizontal
specimen is recorded.
14 Code of
Federal
Regulations
(CFR) Part
25
regulations:
Sections
25.853,
25.855,
25.856,
25.869,
Appendix F
Aviation: flooring, sidewalls,
baggage compartment, insulation,
ducting, interior parts, wiring
Materials and parts must successfully pass test(s) in order to
show compliance. Nine different tests are specified in the CFR
and some materials/parts must pass multiple tests. Variations
of configurations require individual testing. For specific details
on the flammability tests see Appendix F of 14 CFR Part 25.
2-12
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Test
Sectors and Products that Use
Test
Description
UL 2335
Shipping Pallets
Assesses the performance of plastic pallets under fire stress.
The goal of this test is to match the performance of plastic
pallets to wood pallets. Six pallet stacks are ignited in the
middle. The time to activate the first and last sprinkler, the
number of sprinklers activated and the temperature at the
ceiling are all recorded. Sprinklers are mounted above the
stacks and are activated at 165°F. To pass the test no more than
six sprinklers can be activated.
FM 4996
Shipping Pallets
This standard sets fire performance requirements for plastic
pallets so that they can be assigned a classification as
equivalent to wood pallets in an effort to determine the demand
on a sprinkler system in the event of a fire. The test consists of
eight stacks of pallets placed in a specified arrangement.
Ignition is provided by four igniters placed at the center of the
array. Water is applied to the test array by a simulated
sprinkler. A calorimeter and water application apparatus
determine the quantities of water need to supress and control
the fire. The performance criteria require that the fire must be
controlled when a water application density of 0.15 gallons per
minute/ft2 is applied and that the controlled fire will not
continue to grow within the 10 minute test frame. If the pallets
tested meet or exceed the performance criteria, it is designated
"equivalent to wood."
Source: FM Approvals 2013; Levchik 2010; Baker 2011
2-13
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2.4 References
American Composites Manufacturers Association (2004) "Composite Basics: Materials."
Baker, S. (2011). Personal Communication. Uses of decaBDE in aviation. E-mail to Emma
Lavoie.
Bromine Science and Environmental Forum. (2007). "About Bromine." Retrieved October
2007, from http://www.bsef.com/bromine/what_is_bromine/index.php
Ciesielski, A. (2000). An Introduction to Rubber Technology. Shawbury, Shrewsbury,
Shropshire, UK, Rapra Technology Limited.
Council of the European Union (2003). Restriction of Hazardous Substances European
Parliament and the Council of the European Union. Official Journal of the European
Union 2002/95/EC.
Council of the European Union (2011). Restriction of the use of certain hazardous substances in
electrical and electronic equipment (recast). European Parliament and the Council of the
European Union. Official Journal of the European Journal. Directive 2011/65/EU.
FAA. (2010). "Technical Standard Orders." 2010, from
http://www.faa.gov/aircraft/air cert/design approvals/tso/.
FM Approvals (2013). American National Standard for Classification of Pallets and Other
Material Handling Products as Equivalent to Wood Pallets. Norwood, MA.
Friddle, J. (2011). Personal Communication - DfE Polymer Descriptions for Textiles. E. Lavoie.
Hardy, M. L. (2003). DBDPO VCCEP: Introduction and Hazard Assessment Peer Consultation
Meeting on Decabromodiphenyl Ether, Cincinnati, OH.
Harper, C. and Modern Plastics (2000). Modern Plastics Handbook. McGraw-Hill.
Howe-Grant, M. (1997a). Kirk-Othmer Encyclopedia of Chemical Technology
Howe-Grant, M. (1997b). Kirk-Othmer Encyclopedia of Chemical Technology - Amino Resins
and Plastics.
Howe-Grant, M. (1997c). Kirk-Othmer Encyclopedia of Chemical Technology - Elastomers.
Synthetic (survey).
Howe-Grant, M. (1997d). Kirk-Othmer Encyclopedia of Chemical Technology - Polyamides
(Plastics).
Howe-Grant, M. (1997e). Kirk-Othmer Encyclopedia of Chemical Technology - Polycarbonates.
Howe-Grant, M. (1997f). Kirk-Othmer Encyclopedia of Chemical Technology - Urethane
Polymers.
Illinois Environmental Protection Agency (2007). Report on Alternative to the Flame Retardant
DecaBDE: Evaluation of Toxicity, Availablity, Affordability, and Fire Safety Issues: A
report to the governor and the general assembly.
Jones, F. N. (2004). "Aspects of Longevity of Oil and Acrylic Paints." Just Paint (12).
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Levchik, S. (2010). Uses of Decabromodiphenyl Oxide (DecaBDE) Flammabilitv Standards
Design for the Environment Kick Off Meeting, Crystal City, VA.
Lubrizol. (2011). "Acrylic Emulsions." Retrieved November 1, 2011, from
http://www.lubrizol.com/Coatings/Acrylics.html.
Mark, J. E. (2009). Polymer Data Handbook. USA, Oxford University Press.
Posner, S. and L. Boras (2005). Survey and technical assessment of alternative to
Decabromodiphenyl ether (decaBDE) in plastics. The Swedish Chemicals Inspectorate.
Stockholm.
Pure Strategies Inc. for Maine Department of Environmental Protection (2010).
"Decabromodiphenyl Ether Flame Retardant in Plastic Pallets: A Safer Alternatives
Assessment."
Pure Strategies Inc. for the Lowell Center for Sustainable Production (2005).
Decabromodiphenyl ether: An Investigation of Non-Halogen Substitutes in Electronic
Enclosure and Textile Applications, University of Massachusetts Lowell.
Randall, D. L., Steve, eds. (2010). The Polvurethanes Book. John Wiley & Sons, Ltd.
Rex, G. (2011). Personal Communication. E-mail to E. Lavoie.
SpecialChem. (2011). "Ethylene Vinyl Acetate." Retrieved 2/15/2011, from
http ://www. special chem4adhesives. com/tc/ethylene-copol vmers/index. aspx?id=eva.
Trainer, R. (2010). Personal Communication with Ryan Trainer - DecaBDE Alternatives
Assesment (e-mail). L. M. Emma Lavoie.
Troitzsch, J. (2004). Plastics Flammabilitv Handbook: Principles. Regulations. Testing, and
Approval. Cincinnati, Hanser Gardner.
U.S. Department of Transportation and National Highway Traffic Safety Administration. (1972).
"Standard No. 302 - Flammability of Interior Materials - Passenger Cars, Multipurpose
Passenger Vehicles, Trucks, and Buses." Retrieved November 18, 2013, from
http://www.nhtsa.gOv/cars/rules/import/fmvss/index.html#SN302.
U.S. EPA. (2005). "Furniture Flame Retardancy Partnership: Environmental Profiles of
Chemical Flame-Retardant Alternatives for Low-Density Polyurethane Foam (EPA 742-
R-05-002A)." Retrieved November 18, 2013, from
http://www.epa.gov/dfe/pubs/flameret/ffr-alt.htm.
Washington State Department of Health (2008). Alternatives to Deca-BDE in Televisions and
Residential Upholstered Furniture. Department of Ecology. Olympia, WA.
Weil, E. D. and S. V. Levchik (2009). Flame Retardants for Plastics and Textiles: Practical
Applications. Hanser.
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3 Background on Flame Retardants
This chapter begins with background information on flame retardants, including their
classification (Section 3.1). Section 3.2 presents the flame retardants included in this assessment
and Section 3.3 discusses those which were considered but excluded from the assessment.
Section 3.4 presents the mechanisms by which flame retardants reduce or prevent combustion.
3.1 General Information on Flame Retardants
Flame retardants decrease the ignitability of materials and inhibit the combustion process,
limiting the amount of heat released. The simplest way, in theory, of preventing polymer
combustion is to design the polymer so that it is thermally stable. Thermally stable polymers are
less likely to decompose into combustible gases under heat stress, which prevents combustion
from initiating. Because thermally stable polymers are often difficult and expensive to process
and may have performance limitations, manufacturers use other means, such as flame-retardant
chemicals, to impart flame-retardant properties to polymers.
Flame retardants decrease the likelihood of a fire occurring and/or decrease a range of
undesirable consequences of a fire (Lyons 1970; Cullis and Hirschler 1981). However, in other
instances the incomplete combustion resulting from the use of flame retardants, where oxidation
and/or thermal transfer are inhibited, can produce negative by-products. Carbon monoxide (CO),
a by-product of incomplete combustion, acts as an asphyxiant in poorly-ventilated fire scenarios
and can lead to CO poisoning and death (Nelson 1998; Peck 2011). These by-products are in
addition to the production of other toxic chemicals (e.g., halogenated dioxins and furans)
generated during combustion of materials containing flame retardants.
Fire occurs in three stages: (1) thermal decomposition, where the solid, or condensed phase,
breaks down into gaseous decomposition products as a result of heat; (2) combustion chain
reactions in the gas phase, where thermal decomposition products react with an oxidant (usually
air) and generate more combustion products, which can then propagate the fire and release heat;
and (3) transfer of the heat generated from the combustion process back to the condensed phase
to continue the thermal decomposition process (Hirschler 1992; Beyler and Hirschler 2002).
The basic mechanisms of flame retardancy will vary depending on the flame retardant and
polymer system. Flame retardants can be classified based on the phase (solid or gas) in which
they act to reduce or prevent propagation of flame. Other flame retardants may form protective
barriers over a polymer which may insulate the flammable polymer from heat or reduce the
amount of polymer that is available to burn as fuel. In either state, gaseous or condensed, flame
retardants will act to decrease the release rate of heat (Hirschler 1994), thus reducing the burning
rate, flame spread, and/or smoke generation (Morose 2006). These mechanisms are discussed
further in Section 3.4.
Typically, flame retardants contain one or more of the following elements: chlorine, bromine,
aluminum, boron, nitrogen, phosphorus, or silicon (Lyons 1970; Cullis and Hirschler 1981).
There are a number of alternatives and synergists that are also effective. Some elements, such as
zinc (often used as zinc borate or zinc stannate) and molybdenum (often used as ammonium
molybdates), are effective primarily as smoke suppressants in mixtures of flame retardants. In
3-1
-------
addition, antimony trioxide can serve as an effective synergist in combination with halogenated
flame retardants.
The amount of flame retardant needed to pass a given flammability standard varies due to a
number of factors. In general, the lowest levels of flame retardants are required with bromine-
based chemistries, and higher levels are required when using mineral-type compounds. Ranges
of typical "loading levels" (how much of a flame retardant is added to a material) for common
flame retardants are shown in Table 3-1. Loading levels also depend on the polymers in which
the flame retardant is used. For example, bromine-based flame retardants are used in a wide
variety of products (e.g., polyolefins, styrene, polyamides (PAs), polyesters, polycarbonates
(PCs) and textiles) and thus have a wide range of loading levels9. This is demonstrated by the
fact that when used in polyesters, bromine-based flame retardants have a loading level of about 8
percent, whereas when bromine-based flame retardants are used in textiles, they are usually at
about a 17 percent loading. On the other hand, the flame retardants that are not used in such a
wide variety of products have much smaller loading ranges. For example, chlorophosphates have
a 9 percent loading in epoxy resins and a 10 percent loading in polyurethane and are not
reportedly used with other polymers (Weil and Levchik 2009).
Table 3-1: Typical Loading Levels of Common Flame Retardants
Type of Flame Retardant
Loading (wt %)
Bromine-based
2 to 25%'
Aluminum Hydroxide
13 to 60%
Magnesium Hydroxide
53 to 60%
Chlorophosphates
9 to 10%
Organophosphorus
5 to 30%
1 Polyethylene (PE) can require up to 31% of a bromine based flame retardant and 7-8 %
antimony trioxide. However, this is rarely practiced in the market thus the upper limit
displayed above is 25%.
Source: Weil and Levchik 2009
Flame-Retardant Classification
Flame retardants can be classified into four main categories according to chemical composition:
¦ Inorganic: This category includes flame retardants and synergists such as silicon dioxide,
metal hydroxides (e.g., aluminum hydroxide and magnesium hydroxide), antimony
compounds (e.g., antimony trioxide), boron compounds (e.g., zinc borate - which is often
used as a synergist for both halogenated and non-halogenated flame retardants), and other
metal compounds (molybdenum trioxide). As a group, these flame retardants represent
the largest fraction of total flame retardants in use (Norwegian Pollution Control Agency
2009).
¦ Halogenated. These flame retardants are primarily based on bromine and chlorine.
Typical halogenated flame retardants are halogenated paraffins, halogenated aliphatic and
These loading levels can be measured in percent by weight (i.e., percent in relation to the total weight of the
components or final product) or in parts per hundred resin (phr) (i.e., all plirs will be over 100). Information in Table
3-1 is presented as a percentage of the weight of the final product.
3-2
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aromatic compounds, and halogenated polymeric materials. Some halogenated flame
retardants also contain other elements, such as phosphorus or nitrogen. The effectiveness
of halogenated additives, as discussed below in Section 3.4, is due to their interference
with volatile substances which are created in the combustion process, decreasing their
combustibility. Brominated compounds represent approximately 18 to 21 percent (by
volume) of the global flame-retardant production (Hirschler 1998).
¦ Phosphorus-based: This category represents about 20 percent (by volume) of the global
production of flame retardants and includes organic and inorganic phosphates,
phosphonates, and phosphinates as well as red phosphorus, covering a wide range of
phosphorus compounds with different oxidation states. There are also halogenated
phosphate esters, often used as flame retardants for polyurethane foams or as flame-
retardant plasticizers, but not commonly used in electronics applications (Hirschler 1998;
Green 2000; Weil and Levchik 2004).
¦ Nitrogen-based. These flame retardants include melamine and melamine derivatives
(e.g., melamine cyanurate, melamine polyphosphate). Nitrogen-containing flame
retardants are often used in combination with phosphorus-based flame retardants, with
both elements in the same molecule (Morose 2006).
Halogenated flame retardants are commonly blended with a synergist, such as antimony trioxide.
A synergist multiplicatively enhances the flame retardant effect. Many flame-retardant synergists
do not have significant flame-retardant properties by themselves; their addition increases the
overall effectiveness of the flame-retardant system. It should also be noted that the synergists
may be very system specific; they are not universal. For example, antimony trioxide only shows
flame retardant synergism with halogenated flame retardants and has no effect when combined
with inorganic, phosphorus, or nitrogen-based flame retardants.
Flame retardants also can be classified by how they are incorporated into a polymer - additively
or reactively. No reactive-type flame retardants were identified as alternatives to
decabromodiphenyl ether (decaBDE) in this assessment.
¦ Additive: Additive flame retardants are incorporated into polymers via physical mixing,
and are not chemically bound to the polymer. Flame-retardant compounds are mixed with
existing polymers without undergoing any chemical reactions. As a result, the
polymer/additive mixture is less susceptible to combustion than the polymer alone. Since
additive flame retardants can be incorporated into the product up until the final stages of
manufacturing, it is usually easier for manufacturers to use additive flame retardants than
reactive flame retardants.
¦ Reactive: Reactive flame retardants are incorporated into polymers via chemical reactions
and must be incorporated at an early stage of manufacturing. Once introduced, they
become a permanent part of the polymer structure - i.e., the chemically-bound reactive
flame-retardant chemicals cease to exist as separate chemical entities. As a result,
reactive flame retardants have a greater effect on the chemical and physical properties of
the polymer into which they are incorporated than do additive flame retardants. For
3-3
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examples of reactive flame retardants, refer to the Flame Retardants in Printed Circuit
Boards Draft Report (U.S. EPA 2008).
Flame retardants can also be coated on the external surface of the polymer to form a protective
barrier or to improve their compatibility with the polymeric matrix.
Both reactive and additive flame retardants can significantly change the properties of the
polymers into which they are incorporated. Each flame retardant polymer combination is unique.
For example, they may change the viscosity, flexibility, density, electrical properties, tensile
strength, and flexural strength; and may also increase the susceptibility of the polymers to
photochemical and thermal degradation.
3.2 Flame Retardants Included in this Assessment
With the assistance of the partnership, the U.S. Environmental Protection Agency (EPA)
identified 29 alternatives to decaBDE which fit the scope of this project: to identify potentially
functional, viable alternatives for use in the identified polyolefins, styrenics, engineering
thermoplastics, thermosets, elastomers or waterborne emulsions and coatings (see Chapter 1).
The impetus behind this alternatives assessment is the potential for adverse human health and
environmental effects through decaBDE exposure. DecaBDE can break down into other
polybrominated diphenyl ether congeners, which may be persistent, bioaccumulative, and toxic
to both humans and the environment (U.S. EPA 2009). It is important to stress that these
alternatives were not chosen based on environmental preferability but based on their
functionality and viability. These alternatives were identified through the following process:
1) EPA developed an initial list of alternatives based on a review of the literature (Posner
and Boras 2005; Danish Ministry of the Environment 2007; European Chemicals Bureau
2007; Washington State Department of Health 2008; Pure Strategies Inc. for Maine
Department of Environmental Protection 2010) and consultation with industry experts.
2) This list was presented to the partnership, and through multiple discussions EPA
confirmed which chemicals were potentially viable alternatives and identified any
additional alternatives which were not found through the literature review process.
3) Chemicals that were initially included as potential alternatives (identified through the
literature review) but were not deemed viable by the experts on the partnership were
excluded from the assessment (see Section 3.3).
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Chemical Alternatives and the Toxic Substances Control Act
EPA's Design for the Environment (DfE) program is administered by the Office of Pollution Prevention and
Toxics (OPPT), which is charged with the implementation of the Toxic Substances Control Act (TSCA) and the
Pollution Prevention Act (PPA).
Central to the administration of TSCA is the management of the TSCA Inventory. Section 8 (b) of TSCA requires
EPA to compile, keep current, and publish a list of each chemical substance that is manufactured or processed in
the United States. Companies are required to verify the TSCA status of any substance they wish to manufacture or
import for a TSCA-related purpose. For more information, please refer to the TSCA Chemical Substance
Inventory website: http://www.epa.gov/opptintr/existingchemicals/pubs/tscainventorv/basic.html.
TSCA and DfE Alternatives Assessments
Substances selected for evaluation in a DfE Alternatives Assessment generally fall under the TSCA regulations
and therefore must be listed on the TSCA inventory, or be exempt or excluded from reporting before being
manufactured in or imported to, or otherwise introduced in commerce in, the United States. For more information
see http://www.epa.gov/oppt/newchems/pubs/whofiles.htm.
To be as inclusive as possible, DfE Alternatives Assessments may consider substances that may not have
been reviewed under TSCA, and therefore may not be listed on the TSCA inventory. DfE lias worked with
stakeholders to identify and include chemicals that are of interest and likely to be functional alternatives,
regardless of their TSCA status. Chemical identities are gathered from the scientific literature and from
stakeholders and, for non-confidential substances, appropriate TSCA identities are provided.
Persons are advised that substances, including DfE-identified functional alternatives, may not be introduced into
U.S. commerce unless they are in compliance with TSCA. Introducing such substances without adhering to the
TSCA provisions may be a violation of applicable law. Those who are considering using a substance discussed in
this report should check with the manufacturer or importer about the substance's TSCA status. If you have
questions about reportability of substances under TSCA, please contact the OPPT Industrial Chemistry Branch at
202-564-8740.
Table 3-2 presents the potentially viable flame retardant alternatives included in this assessment,
along with a summary of the polymers in which they are most often used, and end-use products
into which the polymers are incorporated. The chemicals in Table 3-2 are additive flame
retardants unless otherwise noted. Their modes of flame-retardant action are also given in Table
3-2 and discussed in Section 3.4. These modes of action include:
¦ CA - C: Chemical action in condensed phase,
¦ CA - G: Chemical action in gas phase,
¦ HS: Heat sink,
¦ CF: Char former,
¦ I: Intumescent10, and
¦ D: Dilution effect
111 Intumescence is when a compound swells as a result of heat exposure, thus increasing in volume, and decreasing
in density.
3-5
-------
Table 3-2: Summary of
Chemicals for Assessment with Polymer and End-Use Application
Chemical
End-Use Applications3
Flame Retardant Chemicals
Abstracts
Service
Polymer
QC
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for Assessment1
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Applications2
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•-
-------
Flame Retardant Chemicals
for Assessment1
Chemical
Abstracts
Service
Registry
Number
(CASRN)
Polymer
Applications2
End-Use Applications3
Mode of
Action4
Electronics
Wire and
Cable
Public
Buildings
Construction
Materials
Automotive
Aviation
Storage and
Distribution
Products
Textiles
Waterborne
emulsions &
coatings
Aluminum hydroxide
21645-51-2;
8064-00-4
Elastomers
HS + I
Emulsions
Ethylene vinyl
acetate (EVA)
PE
Thennosets
Ammonium polyphosphate
68333-79-9;
14728-39-3
Elastomers
CA - C +1
Emulsions
PE
PP
Thennosets
Antimony trioxide
(Used as a synergist only)
1309-64-4
Elastomers
CA-G
(synergists)
Emulsions
Engineering
Thermoplastic
HIPS
PE
PP
Polyvinyl
chloride (PVC)
Thennosets
2If a polymer is not listed for any specific flame retardant, then the flame retardant is not functional in that material application
3A11 categories may include military use
4CA - C: Chemical action in condensed phase, CA - G: Chemical action in gas phase. Physical action can be HS: Heat sink, CF: Char former, I: Intumescent, or D: Dilution effect.
3-7
-------
Chemical
End-Use Applications3
Flame Retardant Chemicals
Abstracts
Service
Polymer
"S
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Mode of
for Assessment1
Registry
Number
(CASRN)
Applications2
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Action4
CPE
Elastomers
CA-G +
CF; CA - G
+ CA-C
(with metal
Bis
Engineering
Thermoplastic
(hexachlorocyclopentadieno)
cyclooctane
13560-89-9
HIPS
s
PE
s
hydroxide
oxide [HS])
PP
s
Thennosets
s
Bisphenol A bis-(diphenyl
phosphate)
5945-33-5;
Polyphenylene
ether - high-
impact
polystyrene
(PPE-HIPS)
s
CA - C + CF;
(synergist)
181028-79-5
(reaction
products)
PC
Polycarbonate-
acrylonitrile
butadiene
styrene (PC-
ABS)
s
Acrylonitrile
butadiene
s
Brominated Epoxy Polymer(s)
Confidential
styrene (ABS)
CA-G
HIPS
s
PE
TFor full chemical name and relevant trade names see the synonym section of the individual profiles in Section 4.8.
2If a polymer is not listed for any specific flame retardant, then the flame retardant is not functional in that material application
3A11 categories may include military uses
4CA - C: Chemical action in condensed phase, CA - G: Chemical action in gas phase. Physical action can be HS: Heat sink, CF: Char former, I: Intumescent, or D: Dilution effect.
3-8
-------
Flame Retardant Chemicals
for Assessment1
Chemical
Abstracts
Service
Registry
Number
(CASRN)
Polymer
Applications2
End-Use Applications3
Mode of
Action4
Electronics
Wire and
Cable
Public
Buildings
Construction
Materials
Automotive
Aviation
Storage and
Distribution
Products
Textiles
Waterborne
emulsions &
coatings
Brominated Epoxy Polymers
68928-70-1
ABS
CA - G + CA
- C (with
metal
hydroxide
[HS])
HIPS
Nylon
PBT
Unsaturated
polyester (UPE)
Mixture of Brominated Epoxy
Polymer(s) and Bromobenzyl
Acrylate
Confidential
ABS
CA-G
HIPS
PE
Brominated epoxy resin end-
capped with tribromophenol
135229-48-0
ABS
CA - G + CA
- C (with
metal
hydroxide
' [HS])
HIPS
Nylon
PBT
UPE
Brominated polyacrylate
59447-57-3
PA
CA-G
PBT
PP
PE
2If a polymer is not listed for any specific flame retardant, then the flame retardant is not functional in that material application
3A11 categories may include military uses
CA - C: Chemical action in condensed phase, CA - G: Chemical action in gas phase. Physical action can be HS: Heat sink, CF: Char former, I: Intumescent, or D: Dilution effect.
3-9
-------
Flame Retardant Chemicals
for Assessment1
Chemical
Abstracts
Service
Registry
Number
(CASRN)
Polymer
Applications2
End-Use Applications3
Mode of
Action4
Electronics
Wire and
Cable
Public
Buildings
Construction
Materials
Automotive
Aviation
Storage and
Distribution
Products
Textiles
Waterborne
emulsions &
coatings
Brominated poly(phenylether)
Confidential
CPE
CA-G
Elastomers
Emulsions
Engineering
Thermoplastics
HIPS
PE
PP
Thennosets
Brominated polystyrene
88497-56-7
PA
CA-G
PET
PBT
Thermoplastic
polyester
Thennoset
polyester
2If a polymer is not listed for any specific flame retardant, then the flame retardant is not functional in that material application
3A11 categories may include military uses
4CA - C: Chemical action in condensed phase, CA - G: Chemical action in gas phase. Physical action can be HS: Heat sink, CF: Char former, I: Intumescent, or D: Dilution effect.
3-10
-------
Flame Retardant Chemicals
for Assessment1
Chemical
Abstracts
Service
Registry
Number
(CASRN)
Polymer
Applications2
End-Use Applications3
Mode of
Action4
Electronics
Wire and
Cable
Public
Buildings
Construction
Materials
Automotive
Aviation
Storage and
Distribution
Products
Textiles
Waterborne
emulsions &
coatings
Decabromodiphenyl ethane
84852-53-9
CPE
CA-G +
CA - C (with
metal
hydroxide
[HS])
Elastomers
Emulsions
Engineering
Thermoplastics
HIPS
PE
PP
Thennosets
Ethylene bis-
tetrabromophthalimide
32588-76-4
CPE
CA-G;
CA-C
(Increased
thermal
stability)
Elastomers
Engineering
Thermoplastic
HIPS
PE
PP
Magnesium hydroxide5
1309-42-8
Elastomers
CF + HS
EVA
PA
PE
PP
2If a polymer is not listed for any specific flame retardant, then the flame retardant is not functional in that material application
3A11 categories may include military uses
4CA - C: Chemical action in condensed phase, CA - G: Chemical action in gas phase. Physical action can be HS: Heat sink, CF: Char former, I: Intumescent, or D: Dilution effect.
'Previously assessed by Design for the Environment (DfE) in other alternatives assessments (http://www.epa.gov/dfe/altemative assessments.html)
3-11
-------
Flame Retardant Chemicals
for Assessment1
Chemical
Abstracts
Service
Registry
Number
(CASRN)
Polymer
Applications2
End-Use Applications3
Mode of
Action4
Electronics
Wire and
Cable
Public
Buildings
Construction
Materials
Automotive
Aviation
Storage and
Distribution
Products
Textiles
Waterborne
emulsions &
coatings
Melamine cyanurate
37640-57-6
PA
HS + D
PBT
TPU
UPE
Melamine polyphosphate5'6
15541-60-3
Epoxy resins
HS + D + CF
PA
PBT
PE
Phenolic based
composites
PP
TPU
UPE
N-alkoxy hindered amine
reaction products
191680-81-6
PE thin films
CA-G
PP thin films and
fibers
Phosphonate oligomer7
68664-06-2
Thennosets
CA - C; CF
For full chemical name and relevant trade names see the synonym section of the individual profiles in Section 4.8.
2If a polymer is not listed for any specific flame retardant, then the flame retardant is not functional in that material application
3A11 categories may include military uses
4CA - C: Chemical action in condensed phase, CA - G: Chemical action in gas phase. Physical action can be HS: Heat sink, CF: Char former, I: Intumescent, or D: Dilution effect.
'Previously assessed by DfE in other alternatives assessments fhttp://www.epa.gov/dfe/alternative assessments.html)
"This CASRN is specifically for Melamine Pyrophosphate. Please consult the Chemical Considerations section of this chemical's hazard profile for additional identity information on
the closely related melamine phosphate salts that are anticipated to have similar hazard profiles.
7A1so available as a reactive oligomer to react with the host polymer system
3-12
-------
Flame Retardant Chemicals
for Assessment1
Chemical
Abstracts
Service
Registry
Number
(CASRN)
Polymer
Applications2
End-Use Applications3
Mode of
Action4
Electronics
Wire and
Cable
Public
Buildings
Construction
Materials
Automotive
Aviation
Storage and
Distribution
Products
Textiles
Waterborne
emulsions &
coatings
Phosphoric acid, mixed esters
with [1.1' -bisphenol-4,4' -diol]
and phenol
1003300-73-9
PPE-HIPS
CA-C +
CF;
(synergist)
PC
PC-ABS
Polyphosphonate
68664-06-2
Elastomers
CA - C; CF
Engineering
Thermoplastic
Poly[phosphonate-co-
carbonate]
77226-90-5
Elastomers
CA - C; CF
Engineering
Thermoplastic
Red phosphorus
7723-14-0
Elastomers
CA - G + CA
-C
Emulsions
Epoxy resins
PA
PA 66 GF
PP
Resorcinol bis-
diphenylphosphate
125997-21-9;
57583-54-7
PPE-HIPS
CA - C + CF;
synergist
PC-ABS
For full chemical name and relevant trade names see the synonym section of the individual profiles in Section 4.8
2If a polymer is not listed for any specific flame retardant, then the flame retardant is not functional in that material application
3A11 categories may include military uses
4CA - C: Chemical action in condensed phase, CA - G: Chemical action in gas phase. Physical action can be HS: Heat sink, CF: Char former, I: Intumescent, or D: Dilution effect.
3-13
-------
Flame Retardant Chemicals
for Assessment1
Chemical
Abstracts
Service
Registry
Number
(CASRN)
Polymer
Applications2
End-Use Applications3
Mode of
Action4
Electronics
Wire and
Cable
Public
Buildings
Construction
Materials
Automotive
Aviation
Storage and
Distribution
Products
Textiles
Waterborne
emulsions &
coatings
Substituted amine phosphate
mixture
66034-17-1
and
confidential
Elastomers
CA - C; CF +
I
EVA
PE
PP
TPU
Tetrabromobisphenol A bis
(2,3-dibromopropyl ether)
21850-44-2
Elastomers
CA - G + CA
- C (with
metal
hydroxide
' [HS])
PP
Triphenyl phosphate5
115-86-6
PPE-HIPS
CA - C + CF
PC-ABS
Tris(tribromoneopentyl)
phosphate
19186-97-1
PP
CA - G + CA
- C + CF +1
Tris(tribromophenoxy) triazine
25713-60-4
ABS
CA-G +
CF + D
HIPS
Zinc borate (Synergist for
halogen and non-halogen)
138265-88-0;
1332-07-6
EVA
HS + CF +
CA-C
PE
PP
s
2If a polymer is not listed for any specific flame retardant, then the flame retardant is not functional in that material application
3A11 categories may include military uses
4CA - C: Chemical action in condensed phase, CA - G: Chemical action in gas phase. Physical action can be HS: Heat sink, CF: Char former, I: Intumescent, or D: Dilution effect.
'Previously assessed by DfE in other alternatives assessments (http://www.epa. gov/dfe/alternative assessments.html)
Source: Personal communication with members of the partnership.
3-14
-------
3.3 Flame Retardants Not Included in this Assessment
In addition to the chemicals listed in Table 3-2, the partnership considered other flame retardants
for the assessment, including individual chemicals and materials. Section 3.3.1 describes
chemicals that were identified as possible alternatives to decaBDE and the reasons they were
excluded from the assessment. Sections 3.3.2 and 3.3.3 describe two general types of
nanomaterials that were not assessed because EPA does not have sufficient experience to apply
data from one form of a chemical substance (such as a bulk material) to a particular nanoform of
that chemical.
3.3.1 Chemicals That Were Excluded from this Assessment
The chemicals listed in this section were identified as possible alternatives to decaBDE, but were
not included in the alternatives assessment. Reasons for exclusion included:
¦ Not commercially available11;
¦ The flame retardant is a blend of which a majority of the chemicals are included in the
assessment;
¦ Compared to other chemicals being assessed, the flame retardant is used or has the
potential to be used in only small quantities;
¦ Outside the scope of the project: not a flame retardant or not relevant to materials in the
scope;
¦ The Hazard Evaluation Criteria (U.S. EPA 2011) cannot yet be applied to evaluation of
nanomaterials;
¦ Regulatory action has been proposed or implemented making future use unlikely;
¦ Will be addressed qualitatively in this report;
¦ Limited use as a decaBDE replacement due to toxic byproducts or regulations; and
¦ Not functional in materials in which decaBDE has been used.
A summary of the chemicals which were discussed but not included in this assessment are listed
in Table 3-3 with the reason for exclusion. Additionally, it is likely that the Partnership omitted
some potential alternatives. For example, TBBPA carbonate oligomer (CASRN 94334-64-2;
71342-77-3) was mentioned but not identified as a high priority alternative and tetradecabromo-
1,4-diphenoxybenzene (CASRN 58965-66-5) was not brought up during the survey of available
alternatives. These chemicals and others not yet identified or currently under development may
be included in future versions of this report.
11 Some flame retardants that are currently in the process of market commercialization are included in the list of
flame retardants in Section 3.2.
3-15
-------
Table 3-3: Chemicals Considered but Not Included in the Final Alternatives Assessment
Chemical Name
CASRN
Justification for Exclusion
1.2 - bis(pentabromophenoxy) ethane
61262-53-1
This chemical is no longer on the market. Neither is the similar but lower brominated
1,2 - bis(tribromophenoxy) ethane.
Ammonium polyphosphate + melamine +
pentaerythritol
The flame retardant is a blend, of which the ammonium polyphosphate and melamine
are included in the assessment.
Boehmite (Aluminum hydroxide oxide)
1318-23-6
Compared to other chemicals being assessed, it is used and/or has the potential to be
only in small quantities. A similar but different compound to aluminum hydroxide.
Calcium molybdate (Powellite)
7789-82-4
This is more of a smoke suppressant than a stand-alone flame retardant and is for PVC.
Diphenyl cresyl phosphate (DPK)
26444-49-5
DPK is mostly used as plasticizer in PVC, and is not used as a decaBDE replacement.
Ethylenediamine-o-phosphate
14852-17-6
Compared to other chemicals being assessed, it is used and/or has the potential to be
used in small quantities.
"Green Armor"
Confidential
The chemical is undergoing the Premanufacture Notice (PMN) review process at EPA.1
The manufacturer prefers not to include this substance in the DfE process until PMN
review is complete.
Huntite / hydromagnesite
Mg3Ca(C03)(0H)23H20
Compared to other chemicals being assessed, it is used and/or lias the potential to be
used in small quantities.
KSS - Potassium 3-
(phenylsulfonyl)benzenesulfonate
63316-43-8
(monosulfonate);
63316-33-6 (disulfonate)
KSS is mainly used in PCs, and not in PC blends.
Mesoporous silicate particles (MSPs)
The DfE Hazard Evaluation Criteria (U.S. EPA 2011) cannot yet be applied to
evaluation of nanomaterials. EPA does not have sufficient experience to apply data
from one form of a chemical substance (such as a bulk material) to a particular
nanofonn of that chemical. These materials are not assessed in this report but they are
still of interest and are discussed in Section 3.3.3.
Anyone who plans to manufacture or import a new chemical substance for a non-exempt commercial purpose is required by section 5 of TSCA to provide EPA with a
PMN which must be submitted at least 90 days prior to the manufacture or import of the chemical.
3-16
-------
Chemical Name
CASRN
Justification for Exclusion
Nanoclays
The DfE Hazard Evaluation Criteria (U.S. EPA 2011) cannot yet be applied to
evaluation of nanomaterials. EPA does not have sufficient experience to apply data
from one form of a chemical substance (such as a bulk material) to a particular
nanofonn of that chemical. These materials are not assessed in this report but they are
still of interest and are discussed in Section 3.3.3.
Pentaerythritol
115-77-5
In contrast to melamine cyanurate and melamine polyphosphate, which are included in
the assessment and can be used as flame retardants by themselves, pentaerythritol must
be combined with melamine AND a phosphate to be effective and so is not included in
this assessment as a stand-alone flame retardant
Phosphonic acid, (3-{[hydroxymethyl]amino}-3-
oxopropyl)-dimethyl ester
20120-33-6
Limited use as a decaBDE replacement: this compound's use in the United States is
almost zero because it is used with compounds which can release formaldehyde.
Poly(aryl ether ketone) (PAEK - various
suppliers - covers PEK, PEEK, PEKK, etc.)
Will be addressed qualitatively in the report: this is an inherently flame retardant (IFR)
polymer (see Section 3.3.2).
Polyetherimde
61128-46-9
Will be addressed qualitatively in the report: this is an IFR polymer (see Section 3.3.2)
PET with built-in phosphorus on polyester
backbone
25038-59-9
Not effective in most materials where decaBDE is currently used to meet required
flammability standards. Therefore, the use of this chemical is limited and not a priority
for assessment.
Short-Chain Chlorinated Paraffins (SCCPs)
Medium-Chain Chlorinated Paraffins (MCCPs)
Long-Chain Chlorinated Paraffins (LCCPs)
very Long-Chain Chlorinated Paraffins (vLCCPs)
Chlorinated paraffins are
categories of chemicals and
defined as:
Cx H,2x-y+2) Cly
SCCPs: 1021, y>5
EPA has entered into Consent Decrees with the major manufacturers of SCCPs that
end manufacture and distribution of these substances in U.S. commerce. EPA has also
proposed a Significant New Use Rule for any use of "alkanes, C12-13, chloro"
(CASRN 71011-12-6).
EPA is requiring all manufacturers of all CPs (which are not correctly listed on the
TSCA Inventory) to submit TSCA section 5 premanufacture notices for these
substances, where they will be evaluated for potential regulatory action. In addition
EPA is evaluating whether the manufacturing, processing, distribution in commerce,
use and/or disposal of MCCPs and LCCPs should also be addressed under TSCA
section 6(a).
Tetrabromobisphenol A
79-94-7
Was not identified as a prevalent alternative to decaBDE. Additionally, a full
discussion of TBBPA manufacturing, process and hazard is provided in a previous DfE
report (U.S. EPA 2008).
Tetrakis (hydroxymethyl) phosphonium, urea.
124-64-1
Not effective in most materials where decaBDE is currently used to meet required
3-17
-------
Chemical Name
CASRN
Justification for Exclusion
chloride salts
flammability standards. Therefore, the use of this chemical is limited and not a priority
for assessment.
Tricresyl phosphate
1330-78-5
Outside of the scope of this project: this is a plasticizer for PVC.
Tris (l,3-dichloropropyl-2) phospliate
13674-87-8
Previously assessed and limited use as a decaBDE replacement: this chemical is not
used as a primary flame retardant in textile backcoatings and TDCPP was reviewed in
DfE's Furniture Flame Retardancy Report (U.S. EPA 2005).
Tris (2-hydroxyethyl) isocyanurate
839-90-7
Not a flame retardant; part of a curing system for coatings.
Zinc molybdate
13767-32-3
Limited use as a decaBDE replacement: this is a potential alternative synergist to
antimony trioxide when used in textiles. It is also a smoke suppressant. However, it is
not a particularly viable alternative synergist because of cost and municipal water
discharge restrictions.
3-18
-------
3.3.2 Inherently Flame Retardant Materials
In addition to the use of flame retardant chemicals, flame retardancy can be achieved through the
use of IFRs. IFR materials meet fire code standards without special processing or chemical
additives. IFRs are not flammable, which means that the protection is built into the fiber and is
less likely to be worn away or washed out (DuPont 2010). IFRs can be used in a multitude of
materials, and are not limited to fibers. IFR technologies are used in textiles, electronics, aircraft,
and ground transportation vehicles and may be used in place of decaBDE in some instances.
Table 3-4 includes a few examples of IFRs, their attributes, and end-use products relevant to this
assessment. Flame retardancy can also be achieved through the use of inherently flame retardant
barriers that physically prevent fire spread to flammable materials. This report assessed flame
retardant additives and did not assess polymers in which these additives are used nor these IFR
materials for their own inherent hazard.
3-19
-------
Table 3-4: Examples and Descriptions of Inherently Flame Retardant Materials
Inherently Flame
Retardant Material
Description and Attributes
End Uses Relevant to this Assessment
Graphite impregnated
foam
¦ Relatively new technology which is self-
extinguishing and highly resistant to combustion.
¦ Can meet airline fire safety standards for the seats
with a reduced dependency on flame-retarded fabric.
(U.S. EPA 2005)
¦ Largely used in niche markets, e.g., general aircraft seating
(U.S. EPA 2005)
Low heat release plastics
(Nomex, Teflon)
¦ Characterized by lower heat release capacities.
¦ High melt temperature (if any), hard to process using
conventional plastics processing methods.
(Walters and Lyon 2003)
¦ Aircraft
¦ Firefighter apparel
¦ Soldier protection fabric
¦ Flame retardant tents
(Nagarajan 2012)
Polyimides
¦ Linear polymers which contain a ring structure along
the backbone. This backbone structure gives the
polymer good high temperature properties.
¦ Pis have excellent physical properties and are used in
applications where parts are exposed to harsh
enviromnents.
¦ Oxidative stability allows them to withstand
continuous service in air at temps of 260 C. Pis will
burn but they have a self-extinguishing property.
(Modern Plastics and Charles A. Harper 1999)
¦ Wire enamel
¦ Bearings for appliances in aircrafts, seals and gaskets
¦ Flexible wiring and electrical motor insulation - used with film
version of PI
(Modern Plastics and Charles A. Harper 1999)
Polyketones
¦ Family of aromatic polyether ketones includes
structures which vary in the location and number of
ketonic and ether linkages on their repeat units
including PEK, PEEK, PEEKK and other
combinations.
¦ All have very high thermal properties due to their
aromaticity of their back bones and are readily
processed via injection molding.
¦ Toughness is high for such high-heat resistance
materials.
¦ Low moisture absorption and good hydrolytic
stability lend these materials to their applications.
(Modern Plastics and Charles A. Harper 1999)
¦ Airplane and automobile engines
(Modern Plastics and Charles A. Harper 1999)
3-20
-------
Inherently Flame
Retardant Material
Description and Attributes
End Uses Relevant to this Assessment
Geopolymers
¦ Polysialate family of inorganic matrices.
¦ Geopolymer is a two-part system consisting of an
alumina liquid and a silica powder that cures at around
150°C.
¦ Low curing temperatures, high temperature resistance,
and low cost.
¦ Compatible with carbon glass, Kevlar, steel,
cellulosics.
(Nagarajan2012)
¦ Items with high-use temperatures anticipated
¦ Engine exhaust system
¦ Aircrafts
(Nagarajan 2012)
Liquid Crystal Polymer
(LCP)
¦ Aromatic copolyesters - the presence of phenyl rings
in the backbone gives chain rigidity, forming rod-
like chain structures.
¦ Self-reinforcing with high mechanical properties.
¦ Known for high-temperature resistance, particularly
heat-distortion temperature.
¦ Excellent mechanical properties, especially in flow
direction. Good electrical insulation properties and
low flammability. LCPs show little dimensional
change when exposed to high temperatures and a low
coefficient of thermal expansion.
¦ Can be high priced and often exhibit poor abrasion
resistance.
¦ Can be injection molded on conventional equipment
and regrind may be used.
(Modern Plastics and Charles A. Harper 1999)
¦ Automotive
¦ Electrical chemical processing
¦ Household applications such as in ovens or microwave cookware
(Modern Plastics and Charles A. Harper 1999)
Polyarylates
¦ Amorphous, aromatic polyesters prepared from
dicarboxylic acids and bisphenols.
¦ Aromatic rings give the polymer good temperature
resistance.
¦ Shows good toughness and ultraviolet resistance.
¦ Transparent and has good electrical properties.
¦ Abrasion resistance of polyarylates is superior to PC.
¦ Extreme rigidity of polymer chains (due to aromatic
rings) leads to difficulty in processing.
¦ Polyarylates, while having low heat release, may not
be IFR in all fire risk scenarios.
(Modern Plastics and Charles A. Harper 1999)
¦ Automotive applications such as door handles, brackets, and
headlamp and mirror housings
¦ Electrical applications for connectors and fuses
(Modern Plastics and Charles A. Harper 1999)
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3.3.3 Nanosilicates: Clays and Colloidal Solids
Nanosilicate clays and colloidal solids may be relevant considerations for alternative flame
retardant formulations. The DfE Hazard Evaluation Criteria cannot yet be applied to evaluation
of nanomaterials. EPA does not have sufficient experience to apply data from one form of a
chemical substance (such as a bulk material) to a particular nanoform of that chemical.
Nanomaterials are not assessed in this report but they are still of interest to the partnership and
this section provides a brief overview, including applications and available hazard information
on two relevant example materials: organoclays and mesoporous silicate particles (MSPs). The
information in this section is not intended to be comprehensive but is rather a starting point to
help the reader conduct further research. Additional books and peer-reviewed publication
references on nanosilicate flame retardants are provided in Appendix A.
Organoclays
Organoclays were developed in the 1930s and 1940s (Theng 1974) and were originally used as
rheological modifiers, additives used to thicken coating materials. They have since been
modified and Cloisite organoclays are now designed for use in plastics and rubbers for
applications including flame retardant synergists. The use of bentonite (Mehta and Weiss 1978)
and organoclays (Jonas 1970; Breitenfellner and Kainmiille 1985; Shain 1987) as additives to
flame retardant formulations is claimed in several older patents; just over ten years ago Gilman,
Kashiwagi and Lichtenhan (1997) published a paper on "Nanocomposites as a revolutionary new
flame retardant approach." However, in the years that followed, it was discovered that adding
organoclays to materials does not, by itself, enable materials to pass flame tests (Morgan 2006;
Morgan and Wilke 2007). Organoclays improve flame retardant performance through synergistic
actions, which has been documented for a variety of flame retardant additive types. When
burned, organoclay particles in a nanocomposite move to the surface of the specimen increasing
char strength and serving as a drip suppressant through formation of an insulating layer that can
delay gasification. The typical loading amount varies between approximately three and six
percent by weight (Gilman 1999; Gilman, Jackson et al. 2000).
Organoclays may pose a hazard to human health (minimal to moderate eye irritation, respiratory
irritation observed in acute studies using high exposure levels, potential carcinogenicity)
(US/International Council of Chemical Associations (ICCA) 2007), but the Organisation of
Economic Cooperation and Development (OECD) has determined that organoclays are "of low
priority for further work" (US/ICCA 2007).
Mesoporous silicate particles
MSPs can be thought of as holey silica 'beads.' Due to the large size of the pores, polymers
interact with both the internal surfaces of the pores and the external surfaces of the particle,
thereby forming a physically cross-linked polymer-particle network. The network created by the
MSP, combined with their surface chemistry, improves the char barrier formed during
combustion that reduces flame intensity while simultaneously improving the mechanical
performance of the polymer into which they are compounded. (Some MSPs have surface areas in
the range 200 to 1,200 m2/g, uniform pores in the mesometric size range of 2 to 50 nm, and pore
"3
volumes between 0.20 and 2.0 cm /g (Pinnavaia, Roston et al.)). As with organoclays, MSPs on
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their own will not typically result in achieving flame retardancy, but by replacing a portion of the
flame retardant loading with about 0.5 to 3 percent by weight MSPs, flame retardancy may be
reached (Roston 2011).
Some MSP materials have been tested in various thermosets (e.g., glassy epoxy and polyester),
and thermoplastics (e.g., PP, PE, and nylon 6) to assess their effectiveness as both a flame
retardant agent and mechanical reinforcing agent. Some particles have demonstrated the ability
to reduce fire intensity while simultaneously increasing the strength of the composite (Pinnavaia,
Roston et al.). Test results have also shown a reduction in dripping during fires (Pinnavaia,
Roston et al.). Manufacturer brochures state that their MSPs are low-toxicity submicron
inorganic compositions that can be easily dispersed in a polymer matrix without the use of
organic surface modification (University of California, Los Angeles (UCLA) 2009).
Layer-by-layer technology
Layer-by-layer (LbL) coatings are nanocomposite structures assembled by an alternate
deposition of anionic and cationic monolayers onto a substrate (Li, Schulz et al. 2009; Kim,
Harris et al. 2012). The deposition of the anionic monolayer and the cationic monolayer
(collectively known as a bilayer) is repeated until a coating with the desired properties is created
(Li, Schulz et al. 2009). Electrostatic, van der Waals, covalent, and hydrogen bonds hold the
monolayers together in LbL coatings (Kim, Harris et al. 2012; Carosio, Blasio et al. 2013). The
LbL deposition technique was discovered in 1966, developed in the 1990s, and was reported in
2009 as being used for developing flame-retardant coatings (Li, Schulz et al. 2009; Li, Schulz et
al. 2010; Apaydin, Laachachi et al. 2013). Flame-retardant LbL coatings are gaining attention
beyond just the areas of academic research and development. Some industrial companies are now
pursuing internal studies on the effectiveness of LbL coatings as flame retardants in commercial
products including fabrics, foams, and films. Research has shown that LbL coatings can be
effective flame retardants for a number of different substrates including cotton fabric (Li, Schulz
et al. 2009; Laufer, Kirkland et al. 2012b), polyurethane foam (Kim, Harris et al. 2012; Laufer,
Kirkland et al. 2012a), PC (Carosio, Blasio et al. 2013), nylon 6 (Apaydin, Laachachi et al.
2013), and PET (Carosio, Laufer et al. 2011). Specifically, some clay-based LbL coatings have
been shown to effectively decrease the flammability of materials by generating a protective
intumescent char layer when exposed to flames that limits heat and mass transfer (Li, Mannen et
al. 2011; Kim, Harris et al. 2012; Laufer, Kirkland et al. 2012a; Apaydin, Laachachi et al. 2013).
Montmorillonite clay (MMT) has proved to be compatible in the LbL process and effective as a
flame retardant; the clay requires little processing prior to deposition because it is a naturally-
occurring, inherently anionic material that is known to catalyze char formation (Bourbigot,
Gilman et al. 2004; Kim, Harris et al. 2012; Apaydin, Laachachi et al. 2013). Recently, LbL
flame retardant formulations formed solely from natural feedstocks (Chitosan and MMT) were
used to provide flame retardancy for polyurethane foam with significant reductions in flame
spread and heat release (Laufer, Kirkland et al. 2012a). Another system using strictly plant-based
matter (Chitosan and phytic acid) was found to deliver localized intumescent protection for
cotton fabrics from 100% renewable resources (Laufer, Kirkland et al. 2012b).
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3.4 Flame Retardant Modes of Action
Polymer combustion is a complex process involving a number of interrelated and interdependent
stages. It is possible to decrease the overall rate of polymer combustion by interfering with one
or more of these stages. The basic mechanisms of flame retardancy will vary depending on the
flame retardant and polymer system. Flame retardants can be classified based on the phase (solid
or gas) in which they act to reduce or prevent propagation of flame. Other flame retardants may
form protective barriers over a polymer which may insulate the flammable polymer from heat or
reduce the amount of polymer that is available to burn as fuel.
3.4.1 Chemical Action in Condensed and Gas Phases
During fire, significant polymer degradation can occur due to heat in the condensed phase (1 mm
from the flame/polymer interface), giving rise to volatile species that are liberated into the gas
phase of the flame. Flame retardant compositions can either act on the condensed phase or the
gas phase.
Radical Scavengers in the Gas Phase
Radical scavengers are also classified as chemical action flame retardant additives as they
modify the radical process in the gas phase through chemical interaction with highly reactive
species.
Halogenated Flame Retardants:
Halogenated flame retardants (e.g., decaBDE) mainly work through this mode of action by
interfering with the gas phase of the combustion process (Troitzsch 1998). The mechanism of
action of these types of flame retardants is shown in Figure 3-1. First, the flame retardant
material breaks down and releases halogen radicals (X*) that react with the polymeric material
(RH). The resulting reaction forms the corresponding halide (HX). The highly reactive radicals,
hydrogen (Ft*) and hydroxyl (OH*), are responsible for degradation of volatile polymeric species
into low molecular weight (MW) fragments. These radicals react with HX to produce less
reactive (more stable) species, in some cases water, as shown in Figure 3-1. The addition of a
catalytic amount of HX reduces the overall rate of combustion in this chain reaction (Hastie
1973). Consequently, the heat release rate and the heat transferred to the polymer are also
reduced. When the gas phase is saturated with less reactive radicals or species, the conditions for
limiting combustion can be reached, thus extinguishing the flame.
Figure 3-1: Mechanism of action of halogenated flame retardant
X* + RH —~ R* + HX
HX + H* —~ H2 + X*
HX + OH* -> H20 + X*
Source: Troitzsch 1998
Many aliphatic and aromatic halogenated flame retardants have been developed to meet specific
compatibility requirements with commercial plastics. Brominated flame retardants are the
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preferred choice of halogenated flame retardants from a manufacturing standpoint due to their
cost effectiveness, effectiveness at low loading levels for some applications, and ease of
processing (minimal/no detrimental effect on polymer processing). This preferability does not
consider hazard, risk, or performance.
Intumescents, Organic Char Forming Compounds and Radical Scavengers in the
Condensed Phase
In the condensed phase, flame retardants can form protective barriers, which may be through
intumescence or char formation, to prevent the propagation of flames. Phosphorous-based (e.g.,
ammonium polyphosphate, melamine polyphosphate) and nitrogen-based (e.g., melamine
cyanurate) flame retardants both act in this way.
Some flame retardants cover the flammable polymer surface with a non-flammable protective
coating. This helps insulate the polymer from the source of heat, reducing the formation of
combustible breakdown products and release to the gas phase. The non-flammable coating may
also prevent gaseous oxidants (e.g., oxygen from the air) from contacting the polymer surface.
Intumescent compounds, which swell as a result of heat exposure, lead to the formation of a
protective barrier in which the gaseous products of polymer decomposition are trapped.
Alternatively, a non-flammable layer can be directly applied to the surface of the polymer to
form a non-intumescent barrier coating. The formation of a thermally insulating char layer
significantly influences subsequent degradation by serving as a protective coating layer
preventing oxygen supply to the condensed phase. The properties of the char layer can further be
bolstered by the presence of inorganic compounds. Many phosphorus-containing compounds
form such non-intumescent surface chars. Char formation has several roles in flame retarding
action. Char formation during combustion is an energy intensive process and occurs at the
expense of other undesirable degradation reactions. There is dilution of the flame zone, and
reduction in the amount of fuel available for further degradation (Kuryla 1979).
As mentioned above, both phosphorous- and nitrogen-based flame retardants work in the
condensed phase. Below is a discussion on the modes of actions for these flame retardants.
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Phosphorous Based Flame Retardants:
Phosphorous based flame retardants work efficiently in the condensed phase during combustion
of a polymer. When heated, phosphorous reacts to produce phosphoric acid derivatives as shown
in Figure 3-2. This acid is responsible for the formation of a glassy layer, which prevents flame
propagation. Phosphorous-based flame retardants also generate intumescent char which acts as a
two way barrier, namely hindering passage of combustible gas from the polymer to the flame and
shielding the polymer layer from the flame. A range of phosphorous-based compounds including
phosphines, phosphine oxides, phosphonium compounds, phosphonates, phosphinates, elemental
red phosphorus, phosphites and phosphates are used as flame retardant additives. Phosphorus
based flame retardants also include ammonium polyphosphate, melamine polyphosphate, and
phosphate esters. Even though their predominant mode of action is through physical action
(charring), there are certain proposed radical reactions that can take place during the combustion
process as shown in Figure 3-2 (Carnaham, Haaf et al. 1979).
Figure 3-2: Mechanisms of flame retardant action in phosphorous based flame retardants
Radical reactions - phosphorous compounds
Phosphorous compounds
"\
Reactions in the gas phase
(Vapor phase FR Triphettylphosphineoxide)
P* and PO* radicals are liberated
HO + PO* *- HPO+ o"
H + HPO H2 + PO*
p + o" *- P*+PO*
p" + OH PO* - H
¦ Similar to halogen radical trap mechanism
¦ Hydrogen recombination
¦ Scavenging of oxygen radicals by
molecular phosphorous
Source: Carnaham, Haaf et al. 1979
Inorganic phosphorus compounds are primarily used in PAs and phenolic resins, or as
components in intumescent formulations. In the case of an intumescent material, a foamed char
is developed on the surface upon combustion. In addition to char, intumescent materials can
adhere to molten polymer, and help prevent dripping, which is necessary in fire quenching.
Reactions in the condensed phase
r OH >H
~ \ H°" °'n
HO* 't)H OH
Phosphoric acid Polyphosphoricacid
(
Forms a molten viscous layer
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Nitrogen Based Flame Retardants:
Nitrogen-based compounds are often intumescent and were originally used in nitrogen-
containing polymers such as polyurethanes and PAs. Melamine, melamine cyanurate, other
melamine salts and guanidine compounds are currently the most used group of nitrogen-
containing flame retardants. Melamine is used as a flame retardant additive for PP and PE.
Melamine cyanurate is used as a flame retardant for PAs and polyesters (PET/PBT), epoxies and
polyurethane resins. Melamine phosphate is also used in polyesters (PET/PBT).
3.4.2 Fillers / Diluents
Another mode of action is that exerted by inert solids incorporated into polymers. Such materials
are known as fillers. Fillers include minerals like calcium carbonate or wollastonite. Sometimes
the term filler gets used with magnesium and aluminum hydroxides due to their mineral
structure. These mineral hydroxide fillers that impart flame retardant properties can be
categorized as functional fillers. Metal hydroxides decompose with endothermicity when
exposed to a fire and dilute the condensed phase of the burning polymer. These additives act as a
heat sink, releasing water and/or carbon monoxide that interfere with combustion products in the
vapor phase. As a result, fillers keep polymers cool and prevent them from thermally
decomposing. Since fillers act predominantly via a physical rather than a chemical process, large
loadings of fillers are needed to meet flammability standards.
3.4.3 Inorganic and Hydrated Compounds and Synergists
Metal hydroxides are the largest (by tonnage) class of all flame retardants used commercially and
are employed alone or in combination with other flame retardants to achieve necessary
improvements in flame retardancy. Metal hydroxides can function both in the condensed and gas
phases of a fire by absorbing heat and decomposing to release their water. This process cools
both the polymer and the flame and dilutes the flammable gas mixture. The high concentrations
(typically 13 to 60 percent or greater by weight) required to impart flame retardants properties
often adversely affect the mechanical properties of the polymer into which they are incorporated.
Aluminum hydroxide, also known as alumina trihydrate, is the largest volume flame retardant in
use today. The low decomposition temperature (220-230°C), limits the polymers in which it can
be incorporated. Magnesium hydroxide is stable to temperatures above 330-350°C and can be
processed into several polymers.
Antimony trioxide may not be considered a flame retardant by itself but is often used as a
synergist. It is used in plastics, rubbers, textiles, paper and paints with organochlorine and
organobromine compounds to diminish the flammability of a wide range of plastics and textiles.
Boron compounds display synergism with antimony oxide. Zinc borate can function as a flame
retardant and smoke suppressant.
Antimony-based compounds are synergistic co-additives used in combination with halogenated
flame retardants, facilitating the reduction in total amount of flame retardants required to achieve
a desired level of flame retardancy. Antimony oxides and antimonates are converted to volatile
species by halogen acids in the fire. The halogen acids react with the antimony-containing
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materials to form antimony trihalide and/or antimony halide oxide. The higher MWs of antimony
halides in comparison to hydrogen halides, allow them to remain in the combustion zone longer,
thus improving the efficiency of flame retardancy. This synergism only occurs in the presence of
halogen flame retardants, as antimony does not react to form any other species in the presence of
non-halogenated flame retardants.
Antimony oxychloride or trichloride reduces the rate at which the halogen leaves the flame zone,
thus increasing the probability of reaction with the reactive species (i.e., hydroxyl radicals). The
mechanism of action also involves radical scavenging as shown in Figure 3-3.
Figure 3-3: Synergistic Mechanism of Metal Halides Produced by a Combination of
Halogen and Metal Oxides
MX3+H# MX* - H-X
MX* + H* MX**+H-X
MX**+ H* ^ M - H-X H-X used quenching H* and OH* radicals
M + o ** (MO) If M is Sb - Flame propagation inhibitor
M + OH * ^ MOH
Other Metal Based Compounds
Molybdenum compounds have been used as flame retardants in cellulosic materials and PVCs
for many years and more recently with other polymers, mainly as smoke suppressants. Zinc
compounds, such as zinc stannate and zinc hydroxy-stannate, are also used as synergists and as
partial replacements for antimony trioxide.
3.4.4 Melting and Dripping
Some flame-retardant chemicals inhibit combustion by interfering with the transfer of heat from
combustion back to the polymer (e.g., melamine cyanurate). Certain chemicals may promote
depolymerization, which lowers the MW of the polymer and facilitates melting. As the burning
melt drips away from the bulk of the polymer it carries with it a proportion of the heat that would
otherwise contribute to polymer decomposition and volatilization. By reducing the release of
volatile decomposition products into the gas phase, these flame retardants reduce the amount of
gaseous decomposition products available to feed the flame. While enhanced melting should
decrease flammability in theory, in practice droplets of burning molten polymer may help spread
a fire to other combustible materials.
3.4.5 Smoldering (Non-Flaming) Combustion
Smoldering (non-flaming) combustion and the closely related phenomenon of glowing
combustion (i.e., only embers are present) occur primarily with high-surface area polymeric
materials that break down during combustion to form a residual carbonaceous char (typically
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cellulosic materials). In general, it is possible to inhibit non-flaming combustion either by
retarding or preventing the initial breakdown of the polymer to form a char, or by interfering
with the further combustion of this char. Boric acid and phosphates are the primary flame
retardants used for preventing non-flaming combustion of organic polymers.
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483-492.
Breitenfellner, B. and T. Kainmiille (1985). Flame-retarding, reinforced molding material based
on thermoplastic polyesters and the use thereof. U.S.
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Carosio, F., A. D. Blasio, et al. (2013). "Layer by layer nanoarchitectures for the surface
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Carosio, F., G. Laufer, et al. (2011). "Layer-by-layer assembly of silica-based flame retardant
thin film on PET fabric." Polymer Degradation and Stability 96: 745-750.
Cullis, C. F. and M. M. Hirschler (1981). The Combustion of Organic Polymers. Oxford, Oxford
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(clay) nanocomposities." Applied Clay Science 15: 31-49.
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Hastie, J. W. (1973). "Molecular basics of flame inhibition." Journal of Research of the National
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Wiley & Sons.
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Emma Lavoie.
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Nelson, G. L. (1998). "Carbon Monoxide and Fire Toxicity: A Review and Analysis of Recent
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4 Hazard Evaluation of DecaBDE and Alternatives
This chapter summarizes the toxicological and environmental hazards of decabromodiphenyl
ether (decaBDE) and each alternative chemical that was identified as a potential functional
substitute for decaBDE. Evaluations of chemical formulations may also include associated
substances (e.g., starting materials, byproducts, and impurities) if their presence is specifically
required to allow that alternative to fully function in the assigned role. Otherwise, pure
substances were analyzed in this assessment. Users of the alternative assessments should be
aware of the purity of the trade product they purchase, as the presence of impurities may alter
the assessment of the alternative. This report is a hazard assessment, not a risk assessment.
Hazard assessment as a risk management tool is discussed in more detail in Section 1.4.
Toxicological and environmental endpoints included in the hazard profiles are discussed in
Section 4.1 along with the criteria used to evaluate each hazard endpoint. Data sources and the
review methodology are described in Section 4.2. The report then offers a detailed description of
the utility of physical-chemical properties in understanding hazard in Section 4.3 and the process
of evaluating human health and environmental endpoints in Sections 4.4 and 4.5, respectively. A
discussion of the evaluation of endocrine activity is included in Section 4.6. The characteristics
of each chemical included in the alternatives assessment are summarized in the comparative
hazard summary table in Section 4.7. Lastly, the collected data and hazard profile of each
chemical are presented in Section 4.8.
4.1 Toxicological and Environmental Endpoints
The assessment of endpoints with the intent to create hazard profiles for a Design for the
Environment (DfE) alternatives assessment follows the guidance of the "Alternatives
Assessment Criteria for Hazard Evaluation" (U.S. EPA 201 lb). The definitions for each
endpoint evaluated following these criteria are outlined in Section 4.1.1 and the criteria by which
these endpoints are evaluated are outlined in Section 4.1.2. Lastly, there are endpoints which DfE
characterizes but does not assign criteria to and these are summarized in Section 4.1.3.
4.1.1 Definitions of Each Endpoint Evaluated Against Criteria
Hazard designations for each chemical discussed in this report were made by direct comparison
of the experimental or estimated data to the DfE "Alternatives Assessment Criteria for Hazard
Evaluation " (U.S. EPA 201 lb). Table 4-1 provides brief definitions of human health toxicity,
environmental toxicity and environmental fate endpoints.
Table 4-1: Definitions of Toxicological and Environmental Endpoints for Hazard
Assessment
Endpoint
Category
Endpoint
Definition
Human Health
Effects
Acute Mammalian Toxicity
Adverse effects occurring following oral or dermal
administration of a single dose of a substance, or multiple
doses given within 24 hours, or an inhalation exposure of
4 hours.
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Endpoint
Category
Endpoint
Definition
Carcinogenicity
Capability of a substance to increase the incidence of
malignant neoplasms, reduce their latency, or increase
their severity or multiplicity.
Mutagenicity/Genotoxicity
Mutagenicity - The ability of an agent to induce
permanent, transmissible changes in the amount, chemical
properties or structure of the genetic material. These
changes may involve a single gene or gene segment, a
block of genes, parts of chromosomes, or whole
chromosomes. Mutagenicity differs from genotoxicity in
that the change in the former case is transmissible to
subsequent cell generations.
Genotoxicity - The ability of an agent or process to alter
the structure, information content, or segregation of DNA,
including those which cause DNA damage by interfering
with normal replication process, or which in a non-
physiological manner (temporarily) alter its replication.
Reproductive Toxicity
The occurrence of biologically adverse effects on the
reproductive systems of females or males that may result
from exposure to enviromnental agents. The toxicity may
be expressed as alterations to the female or male
reproductive organs, the related endocrine system, or
pregnancy outcomes. The manifestation of such toxicity
may include, but is not limited to: adverse effects on onset
of puberty, gamete production and transport, reproductive
cycle normality, sexual behavior, fertility, gestation
parturition lactation, developmental toxicity, premature
reproductive senescence or modifications in other
functions that were dependent on the integrity of the
reproductive systems.
Developmental Toxicity
Adverse effects in the developing organism that may
result from exposure prior to conception (either parent),
during prenatal development, or postnatally to the time of
sexual maturation. Adverse developmental effects may be
detected at any point in the lifespan of the organism. The
major manifestations of developmental toxicity include:
(1) death of the developing organism, (2) structural
abnormality, (3) altered growth, and (4) functional
deficiency.
Neurotoxicity
An adverse change in the structure or function of the
central and/or peripheral nervous system following
exposure to a chemical, physical or biological agent.
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Endpoint
Category
Endpoint
Definition
Repeated Dose Toxicity
Adverse effects (immediate or delayed) that impair
normal physiological function (reversible and irreversible)
of specific target organs or biological systems following
repeated exposure to a chemical substance by any route
relevant to humans. Adverse effects include biologically
significant changes in body and organ weights, changes
that affect the function or morphology of tissues and
organs (gross and microscopic), mortality, and changes in
biochemistry, urinalysis, and hematology parameters that
are relevant for human health; may also include
immunological and neurological effects.
Respiratory Sensitization
Hypersensitivity of the airways following inhalation of a
substance.
Skin Sensitization
A cell-mediated or antibody-mediated allergic response
characterized by the presence of inflammation that may
result in cell death, following an initial induction exposure
to the same chemical substance, i.e., skin allergy.
Eye Irritation/Corrosivity
Irritation or corrosion to the eye following the application
of a test substance.
Skin Irritation/Corrosion
Skin irritation- reversible damage to the skin following the
application of a test substance for up to 4 hours. Skin
corrosion- irreversible damage to the skin namely, visible
necrosis through the epidermis and into the dermis
following the application of a test substance for up to 4
hours.
Environmental toxicity refers to adverse effects observed in living organisms that typically
inhabit the wild; the assessment is focused on effects in three groups of surrogate aquatic
organisms (freshwater fish, invertebrates, and algae).
Environmental
Toxicity
Aquatic Toxicity (Acute)
The property of a substance to be injurious to an organism
in a short-term aquatic exposure to that substance.
Aquatic Toxicity (Chronic)
The property of a substance to cause adverse effects to
aquatic organisms during aquatic exposures which were
determined in relation to the life-cycle of the organism.
Environmental Persistence
The length of time the chemical exists in the enviromnent,
expressed as a half-life, before it is destroyed (i.e.,
transformed) by natural or chemical processes. For
alternative assessments, the amount of time for complete
assimilation (ultimate removal) is preferred over the initial
step in the transformation (primary removal).
Environmental
Fate
Bioaccumulation
The process in which a chemical substance is absorbed in
an organism by all routes of exposure as occurs in the
natural enviromnent, e.g., dietary and ambient
enviromnent sources. Bioaccumulation is the net result of
competing processes of chemical uptake into the organism
at the respiratory surface and from the diet and chemical
elimination from the organism including respiratory
exchange, fecal egestion, metabolic biotransformation of
the parent compound and growth dilution.
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The hazard profile for each chemical contains endpoint specific summary statements (see Section
4.8). For each of the endpoints listed in Table 4-1, these summary statements provide the hazard
designation, the type of data (experimental or estimated) and the rationale. The endpoint
summaries may also include explanatory comments, a discussion of confounding factors or an
indication of the confidence in the data to help put the results in perspective.
4.1.2 Criteria
Table 4-2 summarizes the criteria that were used by the U.S. Environmental Protection Agency
(EPA) DfE Program to interpret the data presented in the hazard evaluations. The DfE
Alternatives Assessment Criteria for Hazard Evaluation underwent internal and public comment,
and were finalized in 2011 (U.S. EPA 201 lb). A hazard designation for each human health
endpoint was not given for each route of exposure but rather was based on the exposure route
with the highest hazard designation. Data may have been available for some or all relevant routes
of exposure.
The details as to how each endpoint was evaluated are described below and in the DfE full
criteria document, DfE Alternatives Assessment Criteria for Hazard Evaluation, available at:
http://www.epa.gov/dfe/alternatives assessment criteria for hazard eval.pdf.
Table 4-2: Criteria Used to Assign Hazard Designations
Endpoint
Very High
High
Moderate
Low
Very Low
Human Health Effects
Acute mammalian toxicity
Oral median lethal dose
(LD50) (mg/kg)
<50
>50-300
>300-2000
>2000
-
Dermal LD50 (mg/kg)
<200
>200-1000
>1000-2000
>2000
-
Inhalation median lethal
concentration (LC50) -
vapor/gas
(mg/L)
<2
>2-10
>10-20
>20
Inhalation LC50 - dust/mist/
fume (mg/L)
<0.5
>0.5-1.0
>1-5
>5
-
Carcinogenicity
Carcinogenicity
Known or
presumed
human
carcinogen
(equivalent to
Globally
Harmonized
System of
Classification
and Labeling of
Chemicals
(GHS)
Categories 1A
and IB)
Suspected
human
carcinogen
(equivalent to
GHS Category
2)
Limited or
marginal
evidence of
carcinogenicity
in animals
(And inadequate
evidence in
humans)
Negative studies
or robust
mechanism-
based Structure
Activity
Relationship
(SAR)
(As described
above)
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Endpoint
Very High
High
Moderate
Low
Very Low
Mutagenicity/Genotoxicity
GHS Category
1A or IB:
Substances
known to
induce heritable
GHS Category
2: Substances
which cause
concern for
humans owing
to the
possibility that
they may
induce heritable
mutations in the
germ cells of
humans
OR
Germ cell mutagenicity
mutations or to
be regarded as
if they induce
heritable
mutations in the
germ cells of
humans
Evidence of
mutagenicity
supported by
positive results
in in vitro OR in
vivo somatic
Negative for
chromosomal
aberrations and
gene mutations,
or no structural
Evidence of
cells of humans
alerts.
mutagenicity
supported by
or animals
Mutagenicity and
genotoxicity in somatic
cells
positive results
in in vitro AND
in vivo somatic
cells and/or
germ cells of
humans or
animals
Reproductive toxicity
Oral (mg/kg/day)
-
<50
50-250
>250-1000
>1000
Dermal (mg/kg/day)
-
<100
100-500
>500-2000
>2000
Inhalation - vapor, gas
-
<1
1-2.5
>2.5-20
>20
(mg/L/day)
Inhalation - dust/mist/fume
-
<0.1
0.1-0.5
>0.5-5
>5
(mg/L/day)
Developmental toxicity
Oral (mg/kg/day)
-
<50
50-250
>250-1000
>1000
Dermal (mg/kg/day)
-
<100
100-500
>500-2000
>2000
Inhalation - vapor, gas
-
<1
1-2.5
>2.5-20
>20
(mg/L/day)
Inhalation - dust/mist/fume
-
<0.1
0.1-0.5
>0.5-5
>5
(mg/L/day)
Neurotoxicity
Oral (mg/kg/day)
-
<10
10-100
>100
-
Dermal (mg/kg/day)
-
<20
20-200
>200
-
Inhalation - vapor, gas
-
<0.2
0.2-1.0
>1.0
-
(mg/L/day)
Inhalation - dust/mist/fume
-
<0.02
0.02-0.2
>0.2
-
(mg/L/day)
Repeated-dose toxicity
Oral (mg/kg/day)
-
<10
10-100
>100
-
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Endpoint
Very High
High
Moderate
Low
Very Low
Dermal (mg/kg/day)
-
<20
20-200
>200
-
Inhalation - vapor, gas
(mg/L/day)
-
<0.2
0.2-1.0
>1.0
-
Inhalation - dust/mist/fume
(mg/L/day)
-
<0.02
0.02-0.2
>0.2
-
Sensitization
Skin sensitization
High frequency
of sensitization
in humans
and/or high
potency in
animals (GHS
Category 1A)
Low to moderate
frequency of
sensitization in
human and/or
low to moderate
potency in
animals (GHS
Category IB)
Adequate data
available and not
GHS Category
1A or IB
Respiratory sensitization
Occurrence in
humans or
evidence of
sensitization in
humans based
on animal or
other tests
(equivalent to
GHS Category
1A and IB)
Limited
evidence
including the
presence of
structural alerts
Adequate data
available
indicating lack
of respiratory
sensitization
Irritation/corrosivity
Eye irritation/corrosivity
Irritation
persists for
>21 days or
corrosive
Clearing in 8-
21 days,
severely
irritating
Clearing in
<7 days,
moderately
irritating
Clearing in
<24 hours,
mildly irritating
Not irritating
Skin irritation/corrosivity
Corrosive
Severe
irritation at
72 hours
Moderate
irritation at
72 hours
Mild or slight
irritation at
72 hours
Not irritating
Endocrine activity
Endocrine Activity
For this endpoint, High/Moderate/Low etc. characterizations will not apply. A
qualitative assessment of available data will be prepared.
Environmental Toxicity and Fate
Aquatic toxicity
Acute aquatic toxicity -
LC50 or half maximal
effective concentration
(EC50) (mg/L)
<1.0
1-10
>10-100
>100 or No
Effects at
Saturation
(NES)
Chronic aquatic toxicity -
lowest observed effect
concentration (LOEC) or
chronic value (ChV)
(mg/L)
<0.1
0.1-1
>1-10
>10 or NES
Environmental persistence
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Endpoint
Very High
High
Moderate
Low
Very Low
Persistence in water, soil,
or sediment
Half-life
>180 days or
recalcitrant
Half-life of 60-
180 days
Half-life <60
but >16 days
Half-life
<16 days OR
passes Ready
Biodegradability
test not
including the
10-day window.
No degradation
products of
concern.
Passes Ready
Biodegradability
test with 10-day
window. No
degradation
products of
concern.
Persistence in air (half-life
days)
For this endpoint, High/Moderate/Low etc. characterizations will not apply. A
qualitative assessment of available data will be prepared.
Bioaccumulation
Bioconcentration Factor
(BCF)/Bioaccumulation
Factor (BAF)
>5000
5000-1000
<1000-100
<100
Log BCF/BAF
>3.7
3.7-3
<3-2
<2
-
Very High or Very Low designations (if an option for a given endpoint in Table 4-2) were assigned only when there were experimental data
located for the chemical under evaluation. In addition, the experimental data must have been collected from a well conducted study specifically
designed to evaluate the endpoint under review. If the endpoint was estimated using experimental data from a close structural analog, by
professional judgment, or from a computerized model, then the next-level designation was assigned (e.g., use of data from a structural analog
that would yield a designation of very high would result in a designation of high for the chemical in review). One exception is for the estimated
persistence of polymers with an average molecular weight (MW) >1,000 daltons, which may result in a Very High designation.
4.1.3 Endpoints Characterized but Not Evaluated
Several additional endpoints were characterized, but not evaluated against hazard criteria. This is
because the endpoints lacked a clear consensus concerning the evaluation criteria (endocrine
activity), data and expert judgment were limited for industrial chemicals (persistence in air,
terrestrial ecotoxicology), or the information was valuable for the interpretation of other toxicity
and fate endpoints (including toxicokinetics and transport in the environment).
Table 4-3: Definitions of Endpoints and Information Characterized but Not Evaluated
Against Hazard Criteria
Toxicological Endpoint
Definition
Toxicokinetics
The determination and quantification of the time course of absorption distribution,
biotransformation, and excretion of chemicals (sometimes referred to as
pharmacokinetics).
Biomonitoring
Information
The measured concentration of a chemical in biological tissues where the analysis
samples were obtained from a natural or non-experimental setting.
Environmental Transport
The potential movement of a chemical, after it is released to the enviromnent, within
and between each of the enviromnental compartments, air, water, soil, and sediment.
Presented as a qualitative summary in the alternative assessment based on physical-
chemical properties, enviromnental fate parameters, and simple volatilization models.
Also includes distribution in the enviromnent as estimated from a fugacity model1.
Persistence in Air
The half-life for destructive removal of a chemical substance in the atmosphere. The
primary chemical reactions considered for atmospheric persistence include hydrolysis,
direct photolysis, and the gas phase reaction with hydroxyl radicals, ozone, or nitrate
radicals. Results are used as input into the enviromnental transport models.
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Toxicological Endpoint
Definition
Immunotoxicology
Adverse effects on the normal structure or function of the immune system caused by
chemical substances (e.g., gross and microscopic changes to immune system organs,
suppression of immunological response, autoimmunity, hypersensitivity,
inflammation, and disruption of immunological mechanistic pathways).
Terrestrial Ecotoxicology
Reported experimental values from guideline and nonguideline studies on adverse
effects on the terrestrial enviromnent. Studies on soil, plants, birds, mammals,
invertebrates were also included.
Endocrine Activity
A change in endocrine homeostasis caused by a chemical or other stressor from
human activities (e.g., application of pesticides, the discharge of industrial chemicals
to air, land, or water, or the use of synthetic chemicals in consumer products.)
A fugacity model predicts partitioning of chemicals among air, soil, sediment, and water under steady state
conditions for a default model "environment" (U.S. EPA 201 le).
4.2 Data Sources and Assessment Methodology
This section explains how data were collected (Section 4.2.1), prioritized and reviewed (Section
4.2.2) for use in the development of hazard profiles. High-quality experimental studies lead to a
thorough understanding of behavior and effects of the chemical in the environment and in living
organisms. Analog approaches and SAR-based estimation methods are also useful tools and are
discussed throughout this section. Information on how polymers differ from discrete chemicals
in terms of how they are evaluated is presented in Section 4.2.3.
4.2.1 Identifying and Reviewing Measured Data
For each chemical assessed, data were collected in a manner consistent with the High Production
Volume (HPV) Chemical Challenge Program Guidance (U.S. EPA 1999b) on searching for
existing chemical information. This process resulted in a comprehensive search of the literature
for available experimental data. For chemicals well characterized by experimental studies this
usually resulted in the collection of recent high-quality reviews or peer-reviewed risk
assessments. These were supplemented by primary searches of scientific literature published
after these secondary sources were released, this explained in greater detail below. For chemicals
that are not as well characterized, that is, where these secondary sources were not available or
lacked relevant or adequate data, a comprehensive search of the primary scientific literature was
done. Subsequently, these searches led to the collection and review of articles from the scientific
literature, industrial submissions, encyclopedic sources, and government reports. In addition,
data presented in EPA public databases (e.g., integrated risk information system (IRIS); the High
Production Volume Information System) and confidential databases were obtained for this
project. Generally, foreign language (non-English) reports were not used unless they provided
information that was not available from other sources.
Chemical assessments were performed by first searching for experimental data for all endpoints
in Table 4-2. For most alternatives assessed, high quality secondary sources were not available;
therefore a comprehensive search of the literature was performed to identify experimental data.
In some cases, confidential studies submitted to EPA by chemical manufacturers were also
available to support hazard designations. For those chemicals that were expected to form stable
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metabolites, searches were performed to identify relevant fate and toxicity information for the
metabolite or degradation product.
Well Studied Chemicals - Literature Search Strategy
As mentioned above, for chemicals that have been well characterized, the literature review
focused primarily on the use of secondary sources, such as Agency for Toxic Substances and
Disease Registry Toxicological Profiles or IRIS assessments. Using high-quality secondary
sources maximized available resources and eliminated potential duplication of effort. However,
more than one secondary source was typically used to verify reported values, which also reduced
the potential for presenting a value that was transcribed incorrectly from the scientific literature.
Although other sources might also contain the same experimental value for an endpoint, effort
was not focused on building a comprehensive list of these references, as it would not have
enhanced the ability to reach a conclusion in the assessment. When data for a selected endpoint
could not be located in a secondary source for an otherwise well studied chemical, the primary
literature was searched by endpoint and experimental studies were assessed for relevant
information.
Making Predictions in the Absence of Measured Data
In the absence of primary or secondary data, hazard designations were based on (1) Quantitative
Structure Activity Relationships (QSAR)-based estimations from the EPA New Chemical
Program's predictive methods; (2) analog data; (3) class-based assignments from the EPA
Chemical Categories document and (4) expert judgment by EPA subject matter experts.
For chemicals that lacked experimental information, QSAR assessments were made using either
EPA's Estimation Program Interface (EPISuite™) for physical-chemical property and
environmental fate endpoints or EPA's Ecological Structure Activity Relationships
(ECOSAR™) QSARs for ecotoxicity. For the cancer endpoint, estimates were also obtained
from EPA's OncoLogic expert system. These estimation methods have been automated, and are
available for free (U.S. EPA 2012c). Often analog data were used to support predictions from
models. These approaches were described in the EPA Pollution Prevention (P2) Framework and
Sustainable Futures (SF) program (U.S. EPA 2005b; U.S. EPA 201 le).
For some physical-chemical properties that could not be estimated using EPISuite™, such as
acid/base dissociation constants, other available methods (e.g., the Sparc Performs Automated
Reasoning in Chemistry website for dissociation constants) were used. All estimation methods
employed were limited to those freely available in the public domain.
The methodology and procedures used to assess polymers are described in Section 4.2.3. In
addition, the endpoints for impurities or oligomers with a MW >1,000 daltons were estimated
using professional judgment and the results assessed for inclusion in the overall hazard
designation. This process is described, as appropriate, under the corresponding endpoints
appearing in Section 4.3.
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When QSAR models were not available, professional judgment was used to identify hazards for
similar chemicals using the guidance from EPA's New Chemicals Categories (U.S. EPA 2010f).
The categories identify substances that share chemical and toxicological properties and possess
potential health or environmental concerns (U.S. EPA 2010a). In the absence of an identified
category, analogs for which experimental data are available were identified using EPA's Analog
Identification Methodology (AIM) or by substructure searches of confidential EPA databases
(U.S. EPA 2012a). If a hazard designation was still not available, the expert judgment of
scientists from EPA's New Chemical Program would provide an assessment of the physical-
chemical properties, environmental fate, aquatic toxicity and human health endpoints to fill
remaining data gaps.
4.2.2 Hierarchy of Data Adequacy
Once the studies were obtained, they were evaluated to establish whether the hazard data were of
sufficient quality to meet the requirements of the assessment process. The adequacy and quality
of the studies identified in the literature review are described in the Data Quality field of the
chemical assessments presented in Section 4.8. The tiered approach described below represents a
general preferred data hierarchy, but the evaluation of toxicological data also requires flexibility
based on expert judgment.
1. One or more studies conducted in a manner consistent with established testing
guidelines
2. Experimentally valid but nonguideline studies (i.e., do not follow established testing
guidelines)
3. Reported data without supporting experimental details
4. Estimated data using SAR methods or professional judgment based on an analog
approach
5. Expert judgment based on mechanistic and structural considerations
In general, data were considered adequate to characterize an endpoint if they were obtained using
the techniques identified in the HPV data adequacy guidelines (U.S. EPA 1999b). Studies
performed according to Harmonized EPA or Organisation for Economic Cooperation and
Development guidelines were reviewed to confirm that the studies followed all required steps.
Experimental studies published in the open literature were reviewed for their scientific rigor and
were also compared and contrasted to guideline studies to identify potential problems arising
from differences in the experimental design. Data from adequate, well-performed, experimental
studies were used to assign hazard designations in preference to those lacking in sufficient
experimental detail. When multiple adequate studies were available for a given endpoint, any
discrepancies that were identified within the set of data were examined further and addressed
using a weight-of-evidence approach that was described in the data entry to characterize the
endpoint whenever possible.
When available, experimental data from guideline or well-performed experimental studies were
preferred (Items 1 and 2 in the hierarchy list). Information from secondary sources such as
Material Safety Data Sheets, or online databases (such as the National Library of Medicine's
Hazardous Substances Data Bank, Item 3 in the hierarchy list) was considered appropriate for
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some endpoints when it included numerical values for effect levels that could be compared to the
evaluation criteria.
4.2.3 Assessment of Polymers and Oligomers
The methodology and procedures used to assess polymers were slightly different than those used
for oligomers, discrete compounds and simple mixtures. Although experimental data for
polymers were identified using the literature search techniques discussed above in Section 4.2.1,
in the absence of experimental data, estimates were performed using professional judgment as
presented in the literature and the SF Polymer Assessment guidance (U.S. EPA 2010d). The
polymers are a mixture of molecules with a distribution of components (e.g., different chain
lengths) that depend on the monomers used, their molar ratios, the total number of monomeric
units in the polymer chain, and the manufacturing conditions. To account for this variation, the
average MW profile (also referred to as the number average molecular weight MWn) was used in
their assessment as the individual chains rarely have the same degree of polymerization and
weight yet their physical, chemical, and environmental properties are essentially identical for the
purposes of this assessment. The polymers evaluated as alternatives typically have average MWs
ranging from >1,000 to <100,000 daltons.
For polymers with relatively low average MWs (i.e., those with average MWs generally less than
2,000), the alternative assessment also determined the amount of oligomers and unchanged
monomers (starting materials) in the MW profile with MWs <1,000 daltons. Special attention
was paid to materials that have a MW <1,000 daltons as these materials often have the highest
hazard (potentially bioavailable substances) in the mixture. This type of assessment was similar
to the evaluation of the hazards of impurities present in discrete chemical products.
Methodological differences between the evaluation of discrete products and polymers are
discussed in Section 4.3.
For the Alternatives Assessment, there were chemicals that are mixtures of low MW oligomers
comprised of 2 or 3 repeating units. The hazard assessment evaluated all oligomers present.
From all the oligomers, the higher concern material was used to assign the hazard designation.
This process is essentially identical to the evaluation of the hazards associated with impurities or
byproducts present in discrete chemical products. As a result, the alternatives assessment process
determined the amount of oligomers and unchanged monomers (starting materials) present and
considered their potential hazards in the alternatives designation.
4.3 Importance of Physical and Chemical Properties, Environmental Transport, and
Biodegradation
Physical-chemical properties provide basic information on the characteristics of a chemical
substance and were used throughout the alternatives assessment process. These endpoints
provide information required to assess potential environmental release, exposure, and
partitioning as well as insight into the potential for adverse toxicological effects. The physical-
chemical properties are provided in the individual chemical hazard profiles presented in Section
4.8. For information on how key physical-chemical properties of alternatives can be used to
address the potential for human and environmental exposure, please refer to Table 5-1.
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Descriptions of relevant physical-chemical properties and how they contribute to the hazard
assessments are presented below.
Molecular Weight (MW)
MW informs how a chemical behaves in a physical or biological system including bioavailability
and environmental fate. In general, but not strictly, larger compounds tend to be less mobile in
biological and environmental systems. Their large size restricts their transport through biological
membranes and lowers their vapor pressure. Polymers and oligomers evaluated in this
alternatives assessment were mixtures that contain a distribution of components and they may
not have a unique MW (see also Section 4.2.3). To account for variation in these mixtures, the
average MW or MWn, determined experimentally (typically using high pressure liquid
chromatography, viscosity, or light-scattering), was used in the assessment of polymers. The
assessment of polymers also includes oligomers and unchanged monomers (starting materials)
that have MW of <1,000 daltons as these were often the highest concern materials (bioavailable
substances) in the mixture.
Melting Point and Boiling Point
These two properties provide an indication of the physical state of the material at ambient
temperature. Chemicals with a melting point more than 25°C were assessed as a solid. Those
with a melting point less than 25°C and a boiling point more than 25°C were assessed as a liquid
and those with a boiling point less than 25°C were assessed as a gas. The physical state was used
throughout the assessment, such as in the determination of potential routes of human and
environmental exposure, as described in Section 5.2. The melting and boiling points were also
useful in determining the potential environmental fate, ecotoxicity, and human health hazards of
a chemical. For example, organic compounds with high melting points generally have low water
solubility and low rates of dissolution. These properties influence a material's bioavailability and
were therefore taken into account in both the assessment process and the evaluation of
experimental studies. Similarly, chemicals with a low melting point also have a higher potential
to be absorbed through the skin, gastrointestinal tract, and lungs.
In the absence of experimental data, the melting point value was not reported and no estimations
were performed. If a chemical decomposes before it melts, this information was included in the
assessment. For boiling point, the maximum value reported in the assessment was 300°C for
high boiling materials including polymers (U.S. EPA 1999b). Melting points for polymers and/or
oligomers were not reported as these materials typically reach a softening point and do not
undergo the phase change associated with melting (i.e., solid to liquid).
Vapor Pressure
Vapor pressure is useful in determining the potential for a chemical substance to volatilize to the
atmosphere from dry surfaces, from storage containers, or during mixing, transfer, or
loading/unloading operations (see Section 5.2). In the assessment process, chemicals with a
vapor pressure less than 1 x 10"6 mm Hg have a low potential for inhalation exposure resulting
from gases or vapors. Vapor pressure is also useful for determining the potential environmental
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fate of a substance. Substances with a vapor pressure more than 1 x 10"4 mm Hg generally exist
in the gas phase in the atmosphere. Substances with a vapor pressure between 1 x 10"4 and 1 x
8 8
10" mm Hg exist as a gas/particulate mixture. Substances with a vapor pressure less than 1x10"
mm Hg exist as a particulate. The potential atmospheric degradation processes described below
in the reactivity section generally occur when a chemical exists in the gas phase. Gases in the
atmosphere also have the potential to travel long distances from their original point of release.
Materials in the liquid or solid (particulate) phases in the atmosphere generally undergo
deposition onto the Earth's surface.
o
A maximum vapor pressure of 1 x 10" mm Hg was assigned for chemicals without experimental
data or for those substances that were anticipated by professional judgment to be nonvolatile
o
(U.S. EPA 201 le). The maximum vapor pressure of 1 x 10" mm Hg was also the default value
reported for the vapor pressure of polymers with a MW >1,000 daltons (U.S. EPA 2010d).
Water Solubility
The water solubility of a chemical provides an indication of its distribution between
environmental media, potential for environmental exposure through release to aquatic
compartments, and potential for human exposure through ingestion of drinking water. Water
solubility was also used extensively to determine potential human health and ecotoxicity hazards.
In general, chemicals with water solubility less than 1 x 10"5 g/L indicate a lower concern for
both the expression of adverse effects, and potential aquatic and general population exposure due
to their low bioavailability. However, chemicals with a low bioavailability also tend to be more
environmentally persistent. Low bioavailability is different than no bioavailability, and the two
should not be used interchangeably.
Within the context of this alternatives assessment, the following descriptors were used according
to ranges of water solubility values: more than 10,000 mg/L was considered very soluble; 1,000-
10,000 mg/L represents soluble; 100-1,000 mg/L represents moderately soluble, 1-100 mg/L
represents slightly soluble, and less than 1 mg/L represents insoluble, noting that these guidelines
were not followed consistently within the scientific literature (U.S. EPA 201 le). Chemicals with
higher water solubility were more likely to be transported into groundwater with runoff during
storm events, be absorbed through the gastrointestinal tract or lungs, partition to aquatic
compartments, undergo atmospheric removal by rain washout, and possess a greater potential for
human exposure through the ingestion of contaminated drinking water. Chemicals with lower
water solubility are generally more persistent and have a greater potential to bioconcentrate.
The water solubility of a substance was also used to evaluate the quality of experimental aquatic
toxicity and oral exposure human health studies as well as the reliability of aquatic toxicity
estimates. If the water solubility of a substance was lower than the reported exposure level in
these experiments, then the study was likely to be regarded as inadequate due to potentially
confounding factors arising from the presence of un-dissolved material. For aquatic toxicity
estimates obtained using SARs, when the estimated toxicity was higher than a chemical's water
solubility (i.e., the estimated concentration in water at which adverse effects appear cannot be
reached because it was above the material's water solubility), the chemical was described as
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having NES. An NES designation is equivalent to a low aquatic toxicity hazard designation for
that endpoint.
While assessing the water solubility of a chemical substance, its potential to disperse in an
aqueous solution was also considered. Ideally, a chemicals potential to disperse would be
obtained from the scientific literature. In the absence of experimental data, the potential for
dispersion can be determined from chemical structure and/or comparison to closely related
analogs. There are two general structural characteristics that lead to the formation of dispersions
in water: (1) chemicals that have both a hydrophilic (polar) head and a hydrophobic (nonpolar)
tail (e.g., surfactants), and (2) molecules that have a large number of repeating polar functional
groups (e.g., polyethylene oxide).
The potential for a chemical to disperse influences potential exposure, environmental fate, and
toxicity. Dispersible chemicals have greater potential for human and environmental exposure,
leachability, and aquatic toxicity than what might be anticipated based on the material's water
solubility alone.
Chemicals without experimental data or chemicals that were anticipated by professional
judgment to be sufficiently insoluble and thus were not bioavailable were assigned a water
solubility maximum value of 1 x 10"3 mg/L (U.S. EPA 201 le). A water solubility of 1 x 10"3
mg/L is the default value used for discrete organics as well as non-ionic polymers with a MW
>1,000 daltons according to information contained in the literature concerning polymer
assessment and the SF Polymer Assessment guidance (U.S. EPA 2010d). This assignment is
consistent with an analysis of the chemicals used in the development of the water solubility
estimation program in EPA's EPISuite™ software. The training set for this model included
1,450 chemicals with a MW range 27-628 daltons and experimental water solubility values
ranging from miscible to 4 x 10" mg/L (Meylan, Howard et al. 1996; U.S. EPA 201 li). Given
"3
that water solubility decreases with MW, a default value of 1 x 10" mg/L is consistent with the
limited bioavailability expected for materials with a MW >1,000 daltons.
Octanol/Water Partition Coefficient (K<,w)
The octanol/water partition coefficient, commonly expressed as its log value (i.e., log Kow) is one
of the most useful properties for performing a hazard assessment. The log Kow indicates the
partitioning of a chemical between octanol and water, where octanol is used to mimic fat and
other hydrophobic components of biological systems. Chemicals with a log Kow less than 1 are
highly soluble in water (hydrophilic), while those with a log Kow more than 4 are not very
soluble in water (hydrophobic). A log Kow more than 8 indicates that the chemical is not readily
bioavailable and is essentially insoluble in water. In addition, a log Kow greater than
approximately 8 may be difficult to obtain experimentally.
The log Kow can be used as a surrogate for the water solubility in a hazard assessment and is
frequently used to estimate the water solubility if an experimental value is not available. It can
also be used to estimate other properties important to the assessment, including bioconcentration
and soil adsorption, and is a required input for SAR models used to estimate ecotoxicity values.
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For chemicals without data, that are not within the domain of EPISuite™ or that were expected
"3
to be insoluble in water (WS <1x10" mg/L), a minimum value of 10 was assigned for the log
Kow (U.S. EPA 201 le). Insoluble chemicals that could be run through EPISuite M software may
use a log Kow >10 if the result appeared to be valid based on expert review. This assignment is
consistent with an analysis of the chemicals ("training set") used in the development of the
octanol/water partition coefficient estimation program in the EPISuite™ software. The training
set for this model included 10,946 chemicals with a MW range 18-720 daltons and experimental
log Kow values ranging from -3.89 to 8.70 (Meylan and Howard 1995; U.S. EPA 201 lh). Given
that log Kowincreases with MW, a default value of 10 is consistent with the limited
bioavailability expected for materials with a MW >1,000 daltons. A maximum log Kow of -2 was
used for water soluble materials. For most polymers and other materials that are anticipated to be
insoluble in both water and octanol, the log Kow cannot be measured and was therefore not listed.
Flammability (Flash Point)
The flash point of a substance is defined as the minimum temperature at which the substance
emits sufficient vapor to form an ignitable mixture with air. Flash point can be used to identify
hazards associated with the handling of volatile chemicals. Substances with a flash point above
37.8°C (100°F) were commonly referred to as non-flammable, as this is the flammability
definition used in the shipping industry. There are exceptions to this definition such as chemicals
that may form explosive mixtures in the presence of air.
Explosivity
Explosivity refers to the potential for a chemical to form explosive mixtures in air and can be
defined using the limits of flammability. The lower limit of flammability (LFL) is defined as the
minimum concentration of a combustible substance that is capable of propagating a flame
through a homogenous mixture in the presence of an ignition source. The upper limit of
flammability (UFL) is similarly defined as the highest concentration that can propagate a flame.
LFLs and UFLs are commonly reported as the volume percent or volume fraction of the
flammable component in air at 25°C. If the ambient air concentration of the gas (or vapor) is
between the upper and lower explosion limit, then the material has the potential to explode if it
comes in contact with an ignition source. Knowledge regarding the explosivity of a given
material in air is also useful in identifying potential hazards associated with the manufacture and
use of that material.
pH
The pH scale measures how acidic or basic a substance is on a range from 0 to 14. A pH of 7 is
neutral. A pH less than 7 is acidic, and a pH greater than 7 is basic. This scale is used primarily
to identify potential hazards associated with skin or eye contact with a chemical or its aqueous
solutions. The corrosive nature of chemicals that form either strongly basic (high pH) or strongly
acidic (low pH) solutions are generally likely to result in harm to skin and other biological
membranes. For corrosive chemicals, some experimental studies, such as biodegradation tests,
require additional analysis to determine if the tests were performed at concentrations that cause
harm to microbes in the test (and, therefore, may result in incorrectly identifying a chemical as
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persistent in the environment). For chemicals that form moderately basic or acidic solutions in
water, the pH of the resulting solution can be used in lieu of a measured dissociation constant.
Dissociation Constant in Water (pKa)
The dissociation constant determines if a chemical will ionize under environmental conditions.
The dissociation constant in water provides the amount of the dissociated and undissociated
forms of an acid, base, or organic salt in water. Knowledge of the dissociation constant is
required to assess the importance of the other physical-chemical properties used in the hazard
assessment. As the percentage of ionization increases, the water solubility increases while the
vapor pressure, Henry's Law constant, and octanol/water partition coefficient decrease. For acids
and bases, the dissociation constant is expressed as the pKa and pKn. respectively.
Henry's Law Constant
Henry's Law constant is the ratio of a chemical's concentration in the gas phase to that in the
liquid phase (at equilibrium). In environmental assessments, the Henry's Law constant is
typically measured in water at 25°C. The Henry's Law constant provides an indication of a
chemical's volatility from water, which can be used to derive partitioning within environmental
compartments and the amount of material removed by stripping in a sewage treatment plant.
Henry's Law constant values less than 1 x 10"7 atm-m3/mole indicate slow volatilization from
n
water to air (the Henry's Law constant for the volatilization of water from water is 1 x 10" atm-
3 3 3
m /mole) and values more than 1x10" atm-m /mole indicate rapid volatilization from water to
air. To aid in determining the importance of volatilization, the assessment uses two models based
on the Henry's Law constant. These models determine the half-life for volatilization from a
8 3
model river and a model lake. A maximum value of 1 x 10" atm-m /mole for the Henry's Law
constant was assigned for chemicals without experimental data or for those that were anticipated
by professional judgment to be nonvolatile.
Sediment/Soil Adsorption/Desorption Coefficient (KoC)
The soil adsorption coefficient provides a measure of a chemical's ability to adsorb to the
organic portion of soil and sediment. This provides an indication of the potential for the chemical
to leach through soil and be introduced into groundwater, which may lead to environmental
exposures to wildlife or humans through the ingestion of drinking water drawn from
underground sources. Chemicals with high soil adsorption coefficients are expected to be
strongly adsorbed to soil and are unlikely to leach into ground water. The soil adsorption
coefficient also describes the potential for a chemical to partition from environmental waters to
suspended solids and sediment. The higher the Koc the more strongly a chemical is adsorbed to
soil. Strong adsorption may impact other fate processes, such as the rate of biodegradation, by
making the chemical less bioavailable.
The soil adsorption coefficient, Koc, is normalized with respect to the organic carbon content of
the soil to account for geographic differences. The assignments for the degree that a chemical is
adsorbed to soil within the context of the assessment were described qualitatively as very strong
(above 30,000), strong (above 3,000), moderate (above 300), low (above 30), and negligible
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(above 3). When determining the potential for a chemical to adsorb to soil and suspended organic
matter, the potential for a chemical to form chemical bonds with humic acids and attach to soil
also needs to be considered, although this process is generally limited to a small number of
chemical classes.
A maximum value of 30,000 for the Koc was assigned for chemicals without experimental data or
for those that were anticipated by professional judgment to be strongly absorbed to soil (U.S.
EPA 201 le). A default Koc of 30,000 was used for polymers with a MW >1,000 daltons.
Reactivity
The potential for a substance to undergo irreversible chemical reactions in the environment can
be used in the assessment of persistence. The primary chemical reactions considered in an
environmental fate assessment are: hydrolysis, photolysis, and the gas phase reaction with
hydroxyl radicals, ozone or nitrate radicals. The most important reaction considered in the hazard
assessment of organic compounds is hydrolysis, or the reaction of a chemical substance with
water. Because the rate of hydrolysis reactions can change substantially as a function of pH,
studies performed in the pH range typically found in the environment (pH 5-9) were considered.
The second reaction considered in the assessment is photolysis, the reaction of a chemical with
sunlight. Both hydrolysis and photolysis occur in air, water, and soil, while only hydrolysis was
considered in sediment. The half-lives for reactive processes, if faster than removal via
biodegradation, were used to assign the hazard designation by direct comparison to the DfE
persistence criteria.
For the atmospheric compartment, persistence also includes the evaluation of oxidative gas-
phase processes. These processes include the reaction with ozone, hydroxyl radicals, and nitrate
radicals. Since the average concentration of these oxidative species in the atmosphere has been
measured, the experimental or estimated rate constants were converted to, and reported as, a
half-life in the assessment using standard pseudo first-order kinetics (U.S. EPA 201 If; U.S. EPA
201 Id).
For inorganic compounds, an additional chemical process was considered, the potential to be
reduced or oxidized (undergo a redox reaction) under environmental conditions. Redox reactions
change the oxidation state of the species through the transfer of electrons to form another
compound (such as the reduction of Cr(VI) to Cr(III)). A change in the oxidation state of a metal
or inorganic species can result in significant changes in the material's hazard designation. In this
example, going from Cr(VI) to Cr(III) makes the compound less toxic.
Environmental Transport
The persistence of a chemical substance is based on determining the importance of removal
processes that may occur once a chemical enters the environment. As noted in Section 4.3,
chemicals with a half-life of less than 60 days are expected to be at most a Moderate hazard
designation for persistence. Persistence does not directly address the pathways in which a
chemical substance might enter the environment (e.g., volatilization or disposal in a landfill) and
focuses instead on the removal processes that are expected to occur once it is released into air,
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water, soil, or sediment. Similarly, the persistence assessment does not address what might
happen to a chemical substance throughout its life cycle, such as disposal during incineration of
consumer or commercial products. Understanding the environmental transport of a chemical
substance can help identify processes relevant to environmental assessment. For example, if a
chemical is toxic to benthic organisms and partitions primarily to sediment, its potential release
to water should be carefully considered in the selection of alternatives.
Biodegradation
In the absence of rapid hydrolysis or other chemical reactions, biodegradation is typically the
primary environmental degradation process for organic compounds. Determining the importance
of biodegradation is, therefore, an important component of the assessment. Biodegradation
processes are divided into two types. The first is primary biodegradation, in which a chemical
substance is converted to another substance. The second is ultimate biodegradation, in which a
chemical is completely mineralized to small building-block components (e.g., CO2 and water).
DfE persistence criteria use data that are reported as percent of theoretical ultimate degradation
in the guideline Ready Biodegradability test or as a half-life in other experimental studies; both
of these measurements can be compared directly to the DfE criteria in 4.1.2. When considering
primary degradation, the assessment process includes an evaluation of the potential for the
formation of metabolites that were more persistent than the parent materials. Chemical
substances that undergo rapid primary degradation but only slow ultimate biodegradation were
considered to have stable metabolites. In the absence of measured data on the substance of
interest, DfE evaluated the potential for biodegradation for chemicals with a MW <1,000 daltons
using the EPA EPISuite™ models. EPISuite™ estimates the probability for ready biodegradation
as well as the potential for primary and ultimate removal, as described in Section 4.3. A default
Very High persistence hazard designation was assigned for polymers with a MW >1,000 daltons
according to information contained in the literature concerning polymer assessment and the SF
Polymer Assessment guidance (U.S. EPA 2010d).
4.4 Evaluating Human Health Endpoints
After data collection and analysis of the physical-chemical properties for the chemicals being
assessed the comparison of the data against the hazard criteria can begin. Section 4.4.1 discusses
how measured data are used to make hazard designations for human health endpoints and
Section 4.4.2 presents the approach for filling in data gaps to make these hazard designations.
4.4.1 Endpoints Characterized and Evaluated Against Criteria Based on Measured Data
This section provides a short description of how measured data were used to designate the level
of hazard for each endpoint. As a reminder, the criteria for the hazard designations are in Table
4-2.
For acute mammalian toxicity the median lethal doses or concentrations were used to assign the
hazard designation. Four levels of hazard designation have been defined ranging from Low to
Very High.
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For cancer the hazard designation was contingent on the level of evidence for increased
incidence of cancer, and not potency. The definitions applied in DfE criteria are based on
International Agency for Research on Cancer levels of evidence (International Agency for
Research on Cancer 2006). For example, a designation of Very High concern requires that the
substance be characterized as a "known or presumed human carcinogen", whereas a designation
of Low concern requires either negative studies or robust SAR conclusions. A designation of
Moderate was applied as a default value when there was an absence of data suggesting High
carcinogenicity, and an absence of data supporting Low carcinogenicity (i.e., a lack of negative
studies or weak SAR conclusions).
Similarly, the hazard designation for mutagenicity/genotoxicity was also based on the level of
evidence rather than potency. Complete data requirements for this endpoint were both gene
mutation and chromosomal aberration assays. For instances of incomplete or inadequate
mutagenicity/genotoxicity data, a Low hazard designation cannot be given.
For chronic endpoints, such as reproductive, developmental, neurological and repeated dose
toxicity, the hazard designation was based on potency. The evaluation considers both lowest
observed adverse effect levels (LOAELs) and identification of no observed adverse effect levels
(NOAELs) when available. The LOAEL and the NOAEL are experimental dose levels, and their
reliability is dictated by the study design. In studies for which the lowest dose tested resulted in
an adverse effect (and therefore a NOAEL was not established), and in studies for which the
highest dose tested was a NOAEL, a conservative approach using professional judgment was
used to address uncertainty regarding the lowest dose or exposure level that might be expected to
cause a particular adverse effect. For example, in the absence of an established a NOAEL, an
identified LOAEL might fall within the range of a Moderate hazard; however, it is uncertain if a
lower dose, such as one that falls within the range of High hazard exists because no lower doses
were tested. In such cases, professional judgment was applied to assign a hazard designation
when possible. Some degree of uncertainty was evident in results from studies in which a
NOAEL may fall within one hazard range (e.g., Moderate hazard) and the identified LOAEL
falls within a different hazard range (e.g., Low hazard) because the true LOAEL may fall in
either category, but there were not enough experimental data points to determine the true
LOAEL. Professional judgment was also applied to these cases to assign a hazard descriptor
when possible and the rationale used was described in the assessment. Developmental
neurotoxicity was considered and was evaluated using the developmental toxicity criteria, which
are more stringent than the criteria for neurotoxicity, and thus designed to be more protective
(U.S. EPA 2011b).
The criteria for skin and respiratory sensitization, which are immune-based responses, consider
the frequency and potency of the reactions. For skin sensitization, categories were based on the
19
weight of evidence from traditional animal bioassays, but in vitro alternative studies were also
considered. At this time, there are no standard test methods for respiratory sensitization; as a
result there was often no designation for this endpoint.
The evaluation of skin and eye irritation and corrosivity were based on the time to recovery.
12 Generally, weight of evidence is defined as the process for characterizing the extent to which the available data
support a hypothesis that an agent causes a particular effect (U.S. EPA 1999a).
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4.4.2 SAR - Application of SAR and Expert Judgment to Endpoint Criteria
If measured data pertaining to human health criteria were not available, potential adverse effects
were estimated with SAR analysis. To make these estimates, DfE relied on the expertise of
scientists in EPA's New Chemicals Program who have reviewed thousands of chemicals and
associated data using these methods. SAR uses the molecular structure of a chemical to infer a
physicochemical property that can be related to specific effects on human health. These
correlations may be qualitative ("simple SAR") or quantitative (QSAR). Information on EPA's
use of SAR analysis has been published by U.S. EPA (1994a). Public access to free validated
quantitative SAR models for human health endpoints is far more limited than physical-chemical
properties, environmental fate parameters, or ecotoxicology. Carcinogenicity was assessed using
the OncoLogic expert system that provides a qualitative result directly applicable to the DfE
criteria. For other endpoints that required SAR approaches, an analog approach using expert
judgment was used as discussed in Section 4.2. All estimates obtained in this project were
reviewed by EPA scientists having subject matter expertise. Estimates for the other human health
endpoints were based on expert judgment using an analog approach and not through the use of
computerized SAR methodologies.
Carcinogenicity
The potential for a chemical to cause cancer in humans was estimated using OncoLogic expert
system. This program uses a decision tree based on the known carcinogenicity of chemicals with
similar chemical structures, information on mechanisms of action, short-term predictive tests,
epidemiological studies, and expert judgment.
Polymer Assessment
Estimates for polymers were obtained using information contained in the literature concerning
polymer assessment and the SF Polymer Assessment guidance based on the MW profile (U.S.
EPA 2010d). Those polymers with MW >1,000 were assessed using an appropriate
representative structure that has a MW less than or equal to the average MW. For polymers with
an average MW >1,000 daltons and a significant amount of low MW material <1,000 daltons,
the low MW components were also assessed for their environmental fate and potential toxicity in
order to identify any possible hazards for the most bioavailable fraction. Similarly, the presence
of unreacted monomers requires that the assessment consider these components for polymers of
any MW range. The properties for polymers with an average MW >1,000 with no low MW
components were generally evaluated as a single high MW material for each of the properties
described below. In general, polymers with an average MW >1,000 were not amenable to the
available SAR estimation methods and based on the literature are assumed to have low to no
bioavailability. Polymers with MW >1,000 that were not degradable or reactive are also typically
not bioavailable. Polymers with an average MW >10,000 have potential for adverse effects due
to lung overloading when respirable particles are present (less than ten microns). The potential
for fibrosis or cancer are not assumed with high MW compounds. There may be exceptions to
the rules of thumb outlined above and as such this guidance should not be held as absolute
thresholds.
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Polymers and oligomers with MWs <1,000 were assessed using a representative structure for all
the MW species anticipated to be present in the mixture. The procedures were essentially
identical to those employed for the evaluation of impurities or byproducts in discrete chemicals,
although in this case the oligomer with the highest concern was used to drive the hazard
designation. Unreacted monomers, if present, were also assessed and considered in the hazard
evaluation.
4.5 Evaluating Environmental Toxicity and Fate Endpoints
As with endpoints previously mentioned, the preferred method for the evaluation of
environmental endpoints is the use of experimental data. In their absence, the alternatives
assessment uses computerized QSAR models developed by EPA for the evaluation of
environmental endpoints that can be directly compared to the DfE criteria. When measured data
were not available, the aquatic toxicity was estimated using EPA's ECOSAR™ software and the
persistence designation was estimated using models in EPA's EPISuite™ software. The hazard
designation was determined by applying the criteria to these estimates. As a direct result of the
design of these models and their direct application to DfE criteria, the evaluation of
environmental endpoints using experimental or estimated data was discussed together in the
following subsections.
4.5.1 Aquatic Toxicity
For ecological toxicity, the alternatives assessment focused on the hazard designations for acute
and chronic studies on freshwater species of algae, invertebrates, and fish, (often referred to as
the "three surrogate species"). Aquatic toxicity values were reported in the assessment as
follows:
¦ Acute (estimated or experimental) - LC50 or EC50 in mg/L
¦ Chronic (experimental) - No observed effect concentration (NOEC) in mg/L
¦ Chronic (estimated) - ChV, or the geometric mean between the NOEC and the LOEC, in
mg/L
Experimental data and estimates reported in the alternatives assessment include information on
the species tested and typically focus on freshwater aquatic organisms. Test data on other
organisms (e.g., worms) were included in the assessment if data or models were readily
available. These data would be evaluated using professional judgment in support of the hazard
designations assigned using the three surrogate freshwater species; however, they were not used
exclusively to assign a hazard designation as DfE criteria are not available. For the estimated
results from ECOSAR™, the equations are derived from surrogate species of fish, zooplankton,
and phytoplankton. While these surrogate species can comprise several genera as well as
families, the equations are not intended to be species specific, but rather estimate toxicity to the
general trophic levels they represent (Mayo-Bean, Nabholz et al. 2011).
If an experimental or estimated effect level exceeded the known water solubility of a chemical
substance, or if the log Kow exceeded the ECOSAR™ cut-off values for acute and chronic
endpoints (which are class specific), No Effects at Saturation (NES) were determined for the
aquatic toxicity endpoints. NES indicates that at the highest concentration achievable, which is
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the limit of a chemical's water solubility, no adverse effects were observed (or would be
expected). In these cases, a Low hazard designation was assigned. In the cases where both an
estimated water solubility and ECOSAR™ estimate were used, then an additional factor of ten
was applied to the water solubility before a NES designation was assigned to account for the
combined uncertainty in the model estimates.
In the case where an experimental aquatic toxicity value was significantly higher than the
chemical's water solubility, it was likely the result of a poorly conducted study. In this
circumstance, which is generally more frequent for formulated products or mixtures, additional
details were provided in the data quality section to describe why the reported values could not be
used to assign a hazard designation. No effects at saturation are also expected in most cases for
insoluble organics, oligomers, or non-ionic polymers with a MW >1,000 daltons resulting in an
overall low hazard concern for aquatic toxicity (Nabholz, Clements et al. 1993).
EPA's ECOSAR™ estimation program uses chemical structure to estimate toxicity of a
substance using class-specific QSARs. ECOSAR™ automatically determines all classes that a
chemical may be related to based on the molecular features of the substance and, therefore, may
provide multiple class-specific estimates for some or all of the species and durations estimated
(Mayo-Bean, Nabholz et al. 2011). Modeled results are dependent on the functional groups
present on the molecule as well as the diversity of chemicals with experimental data used to
build the models (the training set). The hazard profiles report estimates for every class identified
by ECOSAR™. However, the hazard designation was based on the most conservative
ECOSAR™ estimate (highest hazard value). If professional judgment indicates that certain
class-specific estimates were not appropriate for a particular substance, the narcosis (baseline
toxicity) associated with the neutral organic class will be used. Experimental log Kow values were
used preferentially as input into ECOSAR™. In their absence, estimated log Kowvalues from
EPISuite™ were used. ECOSAR™ is maintained and developed as a stand-alone program
(http://www.epa.gov/oppt/newchems/tools/21ecosar.htm), but is also accessible through the EPA
EPISuite™ program after it is installed; therefore the Estimations Program Interface (EPI)
program may also be used as a citation for the ECOSAR™ values in this report.
There were instances where sufficient experimental data are not available to build a chronic
QSAR for some of the three surrogate species. When ECOSAR™ did not provide chronic
estimates, the acute value (experimental or estimated) was divided by an acute to chronic ratio
(ACR) to arrive at the ChV. ACRs of 10 were used for fish and daphnid and an ACR of 4 was
used for algae (Rand, Wells et al. 1995).
4.5.2 Bioaccumulation
Bioaccumulation is a process in which a chemical substance is absorbed in an organism by all
routes of exposure as occurs in the natural environment, e.g., from dietary and ambient
environment sources. Bioaccumulation is the net result of the competing processes; this includes
uptake, metabolism and elimination of a chemical in an organism. Bioaccumulation can be
evaluated using the BAF, the steady state ratio of a chemical in an organism relative to its
concentration in the ambient environment, where the organism is exposed through ingestion and
direct contact. Experimental B AFs have not been widely available in the scientific literature and,
as a result, experimental BCFs are more commonly used to evaluate the bioaccumulation hazard.
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BCFs are defined as the ratio of the concentration of a chemical in an organism to the
concentration of the chemical in the organism's surroundings; BCFs are typically measured for
fish (in water) using guideline studies.
Experimental BAF or BCF values can be compared directly to the DfE criteria for this endpoint
to assign a hazard designation. The BCF/BAF designations range from <100 for a Low
designation to >5,000 for a Very High designation (see 4.1.2). If experimental values were
available for both of these endpoints, and the BCF and BAF were >100 (i.e., above the Low
designation), the largest factor was used to assign hazard designation. If experimental BCFs
<100 were available, the estimated upper trophic BAF from EPISuite™ was used preferentially
if its use resulted in a more conservative hazard designation and if the potential for metabolism
was accurately accounted for within the model estimates.
In the absence of experimental data, evaluation of bioaccumulation potential can be done using
the log Kow and the log octanol/air partition coefficient Koa as estimated by EPISuite™.
However, analysis using Koa requires the use of metabolism data for higher trophic, air breathing
organisms, which can be difficult to obtain from the scientific literature and cannot be readily
estimated. BAFs and BCFs from EPISuite™ were, therefore, typically used for the
bioaccumulation hazard designation when experimental data were lacking. These values can be
compared directly to DfE criteria and the most conservative result was used for the hazard
designation. For chemicals that had estimated bioaccumulation data, available experimental
monitoring data were used to provide insight into the reliability of the model results. For
example, an estimated Low bioaccumulation potential may be increased to a Moderate
designation if a chemical was routinely identified in samples from higher trophic levels, or a
High designation if the chemical was routinely measured in animals at the top of the food chain.
An estimate of Low is the default value used for discrete organics with a MW >1,000 daltons in
the assignment of bioaccumulation hazard. This assignment is consistent with an analysis of the
chemicals used in the development of the bioconcentration and bioaccumulation estimation
programs in the EPISuite™ software (U.S. EPA 201 lg). The training sets for these models
included 527 and 421 chemicals, respectively, with aMW range 68-992 daltons (959 daltons for
BAF). Given that BCF and BAF reach a maximum and then decrease with increasing log Kow, a
default value of Low is, in general, consistent with the limited bioavailability expected for
materials with a MW >1,000 daltons. DfE will use all available well-conducted studies when
evaluating bioaccumulation potential for materials with a MW >1,000, including environmental
biomonitoring data on higher trophic levels.
In general, for polymers with a MW >1,000 daltons, the default bioaccumulation designation of
Low was assigned, arising from their predicted limited bioavailability (U.S. EPA 2010d). A
more detailed analysis was performed for compounds at or near this bright line cutoff as well as
for polymers with components where residuals <1,000 had the potential to be present.
4.5.3 Environmental Persistence
A chemical's persistence in the environment is evaluated by determining the type and rate of
potential removal processes. These removal processes were generally divided into two
categories: chemical and biological. Of the chemical degradation processes, an evaluation of
4-23
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environmental persistence includes the reaction of a chemical with water, also known as
hydrolysis, because water is ubiquitous in the environment. Hydrolysis rate constants can be
obtained from the literature or estimated, and the resulting half-lives can be compared directly to
DfE criteria. For commercial chemicals, hydrolysis tends to be a slower environmental removal
process than biodegradation. Direct and indirect photolysis also represents other potential
chemical degradation processes that are considered in the alternative assessment, and they are
discussed later in this section.
Biodegradation, the most prevalent biological removal process, was divided into two types. The
first is primary biodegradation, in which a chemical substance is converted to another substance
through a single transformation. The second is ultimate biodegradation, in which a chemical is
completely degraded to CO2, water, and mineral oxides (such as phosphates for chemicals
containing phosphorus). DfE criteria utilize ultimate biodegradation preferentially for the
persistence hazard designation, although primary removal rates were informative in assigning
hazard designations particularly for materials that were transformed slowly, and to a lesser extent
for those that are transformed rapidly.
If ultimate biodegradation data were not available, primary removal data were used in some
cases. For primary removal processes, the potential for the formation of degradation products
that are more persistent than the parent compounds must be considered in the hazard designation.
When present, the persistent degradation products should be evaluated for fate and toxicity. Half-
life data on the persistent degradation products, if available, were used to determine the
assignment for the persistence designation. In the absence of persistent degradation products,
primary biodegradation half-life data were compared directly to the DfE criteria to assign a
hazard designation.
Biodegradation processes can be classified as either aerobic or anaerobic. Aerobic
biodegradation is an oxidative process that occurs in the presence of oxygen. Anaerobic
biodegradation is a reductive process that occurs only in the absence of oxygen. Aerobic
biodegradation is typically assessed for soil and water, while anaerobic biodegradation is
generally assessed in sediment. For determining the persistence hazard, the importance of both
aerobic and anaerobic biodegradation as well as partitioning and transport in the environment
were considered to determine what removal processes were most likely to occur. Anaerobic
degradation may use any of several electron acceptors depending on their availability in a given
environment and the prevailing redox potential (Eh). The biodegradative populations that are
dominant in a given environment vary with the conditions and so do their biodegradative
capabilities.
One aspect of the assessment is to determine the potential for removal of a chemical substance,
and especially removal attributable to biodegradation within a sewage treatment plant and other
environments. In this assessment, the term "ready biodegradability" refers to a chemical's
potential to undergo ultimate degradation in guideline laboratory studies. A positive result in a
test for ready biodegradability can be considered as indicative of rapid and ultimate degradation
in most environments including biological sewage treatment plants. Ready tests typically
include a 10-day window, beginning when the biodegradation parameter (e.g., disappearance of
dissolved organic carbon from test substance, or theoretical oxygen demand) reaches 10%. The
4-24
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10-day window must occur within the 28-day length of the test. If the pass level of the test (60%
for oxygen demand and C02 production; 70% for dissolved organic carbon disappearance) is
met in the 10-day window, the chemical received a Very Low hazard designation. Those that did
not pass the 10-day window criterion but met the pass level in 28 days received a Low hazard
designation. If ready biodegradability test data were available but the chemical did not meet the
pass level, the chemical was evaluated based on measured data using the DfE half-life criteria
(Table 4-1). These half-life criteria were also used to assign a hazard designation for
nonguideline ultimate biodegradation studies reported in the scientific literature.
In the absence of a reported half-life, experimental data were also used to approximate half-life
as appropriate. For example, a chemical that undergoes <5% removal in 30 days would be
expected to have a half-life >60 days and would be assigned a High persistence concern.
When experimental data on the biodegradation of a chemical substance were not available, the
potential of that substance to undergo this removal process was assessed from the results of the
EPISuite™ models. These models fall into one of four classes: Rapid biodegradation models
based on linear and non-linear regressions that estimate the probability that a chemical substance
will degrade fast; expert survey models that estimated the rate of ultimate and primary
biodegradation using semi-quantitative methods; probability of ready biodegradability in the
Organisation of Economic Cooperation and Development (OECD) 301C test; and probability of
rapid biodegradation under methanogenic anaerobic conditions. Each of these is discussed in the
following paragraphs.
The first models (Biowin 5 and 6) used in the screening assessment estimated ready
biodegradability in the OECD 301C test and are also known as Japanese Ministry of
International Trade and Industry (MITI) models. These models provided the probability that a
material passes this standardized test. Those chemicals that were estimated to pass the ready
biodegradability test received a Low persistence designation. If a chemical was not estimated to
pass the MITI test, the results of the other EPISuite1 biodegradation models were used.
The rapid biodegradation potential models within EPISuite™ (Biowin 1 and 2) were useful for
determining if a chemical substance was expected to biodegrade quickly in the environment. If a
chemical was likely to biodegrade quickly, it was generally assigned a Low hazard designation
for persistence. The results of the estimates from these models may be used in concert with the
semi-quantitative output from a second set of models, which include ultimate and primary
biodegradation survey models (Biowin 3 and 4) for evaluating persistence. These models
provided a numeric result, ranging from 1 to 5, which relates to the amount of time required for
complete ultimate degradation (Biowin 3) and removal of the parent substance by primary
degradation (Biowin 4) of the test compound. The numeric result from Biowin 3 was converted
to an estimated half-life for removal that can be compared directly to DfE criteria. If results from
different models (other than the MITI models) led to a different hazard designation, then the
ultimate biodegradation model results were used preferentially. If the transport properties
indicate the potential for the material to partition to sediment, an anoxic compartment, then the
results of the anaerobic probability model (Biowin 7) will also be evaluated.
4-25
-------
Half-lives for hydrolysis from experimental studies or EPISuite™ estimates were used in
preference to biodegradation data when they suggested that hydrolysis is a more rapid removal
process. Hydrolysis half-lives were compared directly to DfE criteria to assign the persistence
designation. Similar to primary biodegradation, breakdown products resulting from hydrolysis
were evaluated for fate and toxicity when they were expected to be more persistent than the
parent compound.
Photolysis may also be an important environmental removal process. In general, environmental
removal rates from photolysis do not compete with biodegradation or hydrolysis although there
are exceptions such as iodides. Photolysis may be an important removal process for chemicals
that were not bioavailable because of their limited water solubility. Estimation methods for
photolysis rates were not available using computerized SAR tools. If experimental or suitable
analog data were available, the rate of photolysis was evaluated relative to other removal
processes.
When evaluating the environmental persistence designation, it should be noted that chemicals
with a High or Very High designation can degrade over time, although this process may occur at
a very slow rate. As a result, a Very High designation may have been assigned if persistent
degradates were expected to be produced, even at a very slow rate, in the absence of
experimental biodegradation data for the parent substance.
Chemicals that contain a metal were assigned a High persistence designation in the assessment,
as these inorganic moieties are recalcitrant. In this instance, an 'R' footnote was added to the
hazard summary table to indicate that the persistence potential was based on the presence of a
recalcitrant inorganic moiety. The assessment process also included the evaluation of the
potential chemical reactions of metal-containing and inorganic moieties to determine if they were
potentially transformed to more or less hazardous forms.
Polymers with a MW >1,000 generally received a Very High persistence designation due to their
lack of bioavailability.
4.6 Endocrine Activity
Chemicals included in DfE alternatives assessments were screened for potential endocrine
activity, consistent with the DfE Alternatives Assessment Criteria. Endocrine activity refers to a
change in endocrine homeostasis caused by a chemical or other stressor. An endocrine
disruptor is an external agent that interferes in some way with the role of natural hormones in
the body, in a manner causing adverse effects. Relevant data are summarized in the hazard
assessments for each chemical, located in Section 4.8. Data on endocrine activity were available
for decaBDE and some of the alternatives included in this report. For chemicals without
available data on endocrine activity, this was acknowledged with a "no data located" statement.
When endocrine activity data were available, the data are summarized as a narrative. A unique
hazard designation of Low, Moderate or High is not provided for this endpoint in Table 4-2, for
reasons discussed below.
The document Special Report on Environmental Endocrine Disruption: An Effects Assessment
and Analysis describes EPA's activities regarding the evaluation of endocrine disruption (U.S.
4-26
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EPA 1997). This report was requested by the Science Policy Council and prepared by EPA's
Risk Assessment Forum. This report states that "Based on the current state of the science, the
Agency does not consider endocrine disruption to be an adverse endpoint per se, but rather to be
a mode or mechanism of action potentially leading to other outcomes, for example, carcinogenic,
reproductive or developmental effects, routinely considered in reaching regulatory decisions"
(U.S. EPA 1997). The report also states that "Evidence of endocrine disruption alone can
influence priority setting for further testing and the assessment of results of this testing could
lead to regulatory action if adverse effects are shown to occur" (U.S. EPA 1997).
The 1996 Food Quality Protection Act (FQPA) directed EPA to develop a scientifically validated
screening program to determine whether certain substances may cause hormonal effects in
humans. In response, EPA established the Endocrine Disruptor Screening Program (EDSP) (U.S.
EPA 2012b). The EDSP is developing requirements for the screening and testing of thousands of
chemicals for their potential to affect the endocrine system. When complete, EPA will use these
screening and testing approaches to set priorities and conduct further testing when warranted.
The science related to measuring and demonstrating endocrine disruption is relatively new, and
validated testing methods at EPA are still being developed.
The EDSP proposes a two-tiered approach that includes initial screening followed by more in-
depth testing when warranted (U.S. EPA 201 la). The Tier 1 screening battery is intended to
identify chemicals with the potential to interact with the estrogen, androgen, or thyroid hormone
systems through any of several recognized modes of action. Positive findings for Tier 1 tests
identify the potential for an interaction with endocrine systems, but do not fully characterize the
nature of possible effects in whole animals. Tier 2 testing is intended to confirm, characterize,
and quantify the effects for chemicals that interact with estrogen, androgen, and thyroid hormone
systems. These test methods must undergo a four-stage validation process (protocol
development, optimization/prevalidation, validation, and peer-review) prior to regulatory
13
acceptance and implementation. Validation is ongoing for Tier 1 and Tier 2 methods . Once
validated test methods have been established for screening and testing of potential endocrine
disruptors, guidance must be developed for interpretation of these test results using an overall
weight-of-evidence characterization.
To assess the data on endocrine activity, DfE applies the weight of evidence approach developed
by the EDSP (U.S. EPA 201 lc). This process integrates and evaluates data, and always relies on
professional judgment (U.S. EPA 201 lc). To evaluate endocrine activity with this weight of
evidence approach, DfE examined multiple lines of evidence (when available) and considered
the nature of the effects within and across studies, including number, type, and
severity/magnitude of effects, conditions under which effects occurred (e.g., dose, route,
duration), consistency, pattern, range, and interrelationships of effects observed within and
among studies, species, strains, and sexes, strengths and limitations of the in vitro and in vivo
information, and biological plausibility of the potential for an interaction with the endocrine,
androgen, or thyroid hormonal pathways.
Most test data for chemicals in this report consist of in vitro assays, but results of in vitro assays
13 Information on the status of assay development and validation efforts for each assay in EPA's EDSP can be found
at: http://www.epa.gov/oscpmont/oscpendo/pubs/assaYvalidation/status.htm
4-27
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alone were not generally expected to provide a sufficient basis to support a hazard designation
for endocrine disruption. EPA expects that in vivo evidence would typically be given greater
Chemical Alternatives and the Toxic Substances Control Act
EPA's DfE program is administered by the Office of Pollution Prevention and Toxics (OPPT), which is charged
with the implementation of the Toxic Substances Control Act (TSCA) and the Pollution Prevention Act (PPA).
Central to the administration of TSCA is the management of the TSCA Inventory. Section 8 (b) of TSCA requires
EPA to compile, keep current, and publish a list of each chemical substance that is manufactured or processed in
the United States. Companies are required to verify the TSCA status of any substance they wish to manufacture or
import for a TSCA-related purpose. For more information, please refer to the TSCA Chemical Substance
Inventory website: http://www.epa.gov/opptintr/existingchemicals/pubs/tscainventorv/basic.html.
TSCA and DfE Alternatives Assessments
Substances selected for evaluation in a DfE Alternatives Assessment generally fall under the TSCA regulations
and therefore must be listed on the TSCA inventory, or be exempt or excluded from reporting before being
manufactured in or imported to, or otherwise introduced in commerce in, the United States. For more information
see http://www.epa.gov/oppt/newchems/pubs/whofiles.htm.
To be as inclusive as possible, DfE Alternatives Assessments may consider substances that may not have
been reviewed under TSCA, and therefore may not be listed on the TSCA inventory. DfE has worked with
stakeholders to identify and include chemicals that are of interest and likely to be functional alternatives,
regardless of their TSCA status. Chemical identities are gathered from the scientific literature and from
stakeholders and, for non-confidential substances, appropriate TSCA identities are provided.
Persons are advised that substances, including DfE-identified functional alternatives, may not be introduced into
U.S. commerce unless they are in compliance with TSCA. Introducing such substances without adhering to the
TSCA provisions may be a violation of applicable law. Those who are considering using a substance discussed in
this report should check with the manufacturer or importer about the substance's TSCA status. If you have
questions about reportability of substances under TSCA, please contact the OPPT Industrial Chemistry Branch at
202-564-8740.
overall influence in the weight of evidence evaluation than in vitro findings because of the
inherent limitations of such assays. Although in vitro assays can provide insight into the mode of
action, they have limited ability to account for normal metabolic activation and clearance of the
compound, as well as normal intact physiological conditions (e.g., the ability of an animal to
compensate for endocrine alterations).
As described in the DfE Alternatives Assessment Criteria, endocrine activity was summarized in
a narrative, rather than by High, Moderate or Low hazard designation. The endocrine activity
summaries can be found in the hazard profiles. This is an appropriate approach because there is
no consensus on what constitutes high, moderate or low concern for this endpoint. The summary
of endocrine activity largely relies on representative studies and expert review summaries.
4-28
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4.7 Hazard Summary Table
Table 4-4 Screening Level Hazard Summary for DecaBDE and Halogenated Flame Retardant Alternatives
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the substance
including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard information in the table.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , E and VH) were assigned
based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from predictive models and/or professional judgment.
§ Based on analogy to experimental data for a structurally similar compound, a This alternative may contain impurities. These impurities have hazard designations that differ from the
flame retardant alternative, Brominated poly(phenylether), as follows, based on experimental data: HIGH for human health, HIGH for aquatic toxicity, VERY HIGH for bioaccumulation.
and VERY HIGH for persistence/ This chemical is subject to testing in an EPA consent order for this endpoint.
Chemical
(for full chemical name and relevant trade names see
the individual profiles in Section 4.8)
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
DecaBDE and Discrete Halogenated FR Alternatives
Bis(hexachlorocyclopentadieno) Cyclooctane
13560-89-9
L
VL
VL
L
L
VL
L
L
L
VH
H
Brominated Poly(phenylether)
Confidential
L
La
L
VLn
Ma
La
La
L
L
VL
L
La
VHr
Hra
Decabromodiphenyl Ethane
84852-53-9
L
L
L
L
L
L
VL
VL
L
L
VH
H
Decabromodiphenyl Ether
1163-19-5
L
M
M
L
L
L
L
L
L
L
L
VH
H
Ethylene B is-T etrabromophthalimide
32588-76-4
L
L
L
L
L
L
VL
VL
L
L
VH
H
Tetrabromobisphenol A Bis (2,3-dibromopropyl)
Ether
21850-44-2
L
M
M
M
M
L
M
L
L
L
L
L
VH
H
Tris(tribromoneopentyl) Phosphate
19186-97-1
M
M
L
M
M
H
L
L
L
L
L
L
H
M
Tris(tribromophenoxy) Triazine
25713-60-4
L
L
L
L
L
L
L
L
L
VL
L
L
VH
H
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants that may
partition to sediment and particulates.
4-29
-------
Table 4-4 Continued
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , E and VH) were assigned
based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from predictive models and/or professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations.
~ Different formulations of the commercial product are available. One of these many formulations has an average MW of-1,600 and contains significant amounts of lower MW
components. These lower MW components have hazard designations different than the polymeric flame retardant, as follows: HIGH (estimated) for bioaccumulation; HIGH
(experimental) for acute aquatic toxicity; HIGH estimated for chronic aquatic toxicity; MODERATE (experimental) for developmental; and MODERATE (estimated) for
carcinogenicity, genotoxicity, repeated dose, reproductive, and skin and respiratory sensitization toxicity.
Chemical
(for Ml chemical name and relevant trade names see
the individual profiles in Section 4.8)
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Halogenated Flame Retardant Alternatives Continued
Polymeric Halogenated FR Alternatives1"
Brominated Epoxy Polymers
68928-70-1
L
/,~
L
/,~
/,~
L
zV
L
~
L
L
/,~
/,~
VH
/,~
Brominated Epoxy Polymer(s)
Confidential
L
/,~
/,~
/,~
/,~
L
zV
/,~
~
L
L
/,~
/,~
VH
/,~
Mixture of brominated epoxy polymer(s) and
bromobenzyl acrylate
Confidential
L
/,~
/,~
/,~
/,~
L
zV
/,~
~
L
L
/,~
/,~
VH
/,~
Brominated Epoxy Resin End-Capped with
Tribromophenol
135229-48-0
L
L
L
L
L
L
Ld
L
L
VL
L
L
VH
L
Brominated Polyacrylate
59447-57-3
L
L
L
L
L
L
Ld
L
L
L
L
L
VH
L
Brominated Polystyrene
88497-56-7
L
L
L
L
L
L
Ld
L
L
L
L
L
VH
L
Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants that may
partition to sediment and particulates.
p The range of polymer molecular weight can be broad. The polymers listed here have low toxicity for human health and aquatic endpoints. Not all polymers will have this low toxicity;
hazards will vary with physical-chemical properties.
4-30
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Table 4-5 Screening Level Hazard Summary for Organic Phosphorus or Nitrogen Flame Retardant Alternatives
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the substance
including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard information in the table.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , E and VH) were assigned
based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from predictive models and/or professional judgment.
§ Based on analogy to experimental data for a structurally similar compound.
1 The highest hazard designation of any of the oligomers withMW <1,000.
0 The highest hazard designation of a representative component of the oligomeric mixture with MWs <1,000.
Chemical
(for full chemical name and relevant trade names
see the individual profiles in Section 4.8)
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Organic Phosphorus or Nitrogen Flame Retardant (PFR or NFR) Alternatives
Discrete PFR, NFR and P/NFR Alternatives
Substituted Amine Phosphate Mixture1
Confidential
H
M
M
M
M
L
M
L
VL
M
L
H
L
Triphenyl Phosphate
115-86-6
L
M
L
L
L
L
H
L
L
VL
VH
VH
L
M
Polymeric PFR and NFR Alternatives
Bisphenol A bis-(diphenyl phosphate); BAPP
181028-79-5
L
M
L
L
L
L
L
L
L
L
H
Melamine Cyanurate1
37640-57-6
L
M
M
L
H
L
L
L
L
L
VH
L
Melamine Polyphosphate1
15541-60-3
L
M
M
L
M
L
L
VL
L
L
H
L
N-alkoxy Hindered Amine Reaction Products
191680-81-6
L
M
L
H
H
L
H
L
L
VL
H
H
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants that may
partition to sediment and particulates.
1 Hazard designations are based upon the component of the salt with the highest hazard designation, including the corresponding free acid or base.
4-31
-------
Table 4-5 Continued
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , E and VH) were assigned
based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from predictive models and/or professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations
§ Based on analogy to experimental data for a structurally similar compound.
1 The highest hazard designation of any of the oligomers withMW <1,000.
v Phosphorate Oligomer, with a MW range of 1,000 to 5,000, may contain significant amounts of an impurity, depending on the final product preparation. This impurity has hazard
designations that differ from the polymeric flame retardant, as follows: MODERATE (experimental) for carcinogenicity, reproductive and repeated dose toxicity, skin sensitization
eye and dermal irritation; and HIGH (experimental) for developmental toxicity and acute and chronic aquatic toxicity.
Chemical
(for full chemical name and relevant trade names
see the individual profiles in Section 4.8)
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Organic Phosphorus or Nitrogen Flame Retardant (PFR or NFR) Alternatives Continued
Polymeric PFR and NFR Alternatives
Phosphonate Oligomer*
68664-06-2
L
M
M%
L*
L8*
M%
l¥
VH
Polyphosphonate
68664-06-2
L
L
L
L
L
L
L"
L
L
L
L
L
VH
L
Phosphoric acid, mixed esters with [l,l'-bisphenyl-
4,4'-diol] and phenol; BPBP
1003300-73-9
L
M
L
L
L
L
VL
VL
ifi
ifi
H
M%
Poly[phosphonate-co-carbonate]
77226-90-5
L
L
L
L
L
L
Ld
L
L
L
L
L
VH
L
Resorcinol Bis-Diphenylphosphate; RDP
125997-21-9
L
L
L
L
L
VL
VH
VH
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants that may
partition to sediment and particulates.
4-32
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Table 4-6 Screening Level Hazard Summary for Inorganic Flame Retardant Alternatives
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the substance
including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard information in the table.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , E and VH) were assigned
based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from predictive models and/or professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations.
R Recalcitrant: Substance is comprised of metallic species that will not degrade, but may change oxidation state or undergo complexation processes under enviromnental conditions.
* Ongoing studies may result in a change in this endpoint.
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Chemical
(for full chemical name and relevant trade names
see the individual profiles in Section 4.8)
CASRN
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Inorganic Flame Retardant Alternatives
Aluminum Diethylphosphinate
225789-38-8
L
L
L
VL
M
M
M
L
L
VL
Hr
L
Aluminum Hydroxide
21645-51-2
L
L
L
L
L
M
L
VL
VL
M
M
Hr
L
Ammonium Polyphosphate
68333-79-9
L
L
L
L
L
L
Ld
L
VL
L
L
L
VH
L
Antimony Trioxide1
1309-64-4
L
.
M
L
L
L
L
Hr
L
Magnesium Hydroxide
1309-42-8
L
L
L
L
L
L
L
L
L
L
L
Hr
L
Red Phosphorus
7723-14-0
L
L
M
L
L
L
L
L
L
L
L
Zinc Borate
1332-07-6
L
L
H
M
M
H
L
L
L
L
H
H
] R
L
Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants that may
partition to sediment and particulates.
1 This compound is included in the ongoing EPA Work Plan evaluation for Antimony Trioxide.
4-33
-------
4.8 Hazard Evaluations
Aluminum Diethylphosphinate
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
R Recalcitrant: Substance is comprised of metallic species that will not degrade, but may change oxidation state or undergo complexation processes under enviromnental conditions.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Aluminum Diethylphosphinate
225789-38-8
L
L
L
VL
M
M
M
L
L
VL
Hr
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants that
may partition to sediment and particulates.
4-34
-------
Aluminum Diethylphosphinate
\ N /
1 _
0
Al3
~\ /0 oN /
p.
° \ /s0
/ \
CASRN: 225789-38-8
MW: 390.27
MF: 3 C4H„P02 A1
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: CCP(=0)(CC)0[A1](0P(=0)(CC)CC)0P(=0)(CC)CC
Synonyms: Exolit OP 930; Aluminium diethylphosphinate; Aluminium tris(diethylphosphinate)
Chemical Considerations: This alternative is an inorganic compound and in the absence of experimental data, professional judgment using chemical class and
structural considerations were used to complete this hazard profile.
Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: None
Analog: Confidential aluminum metal salts
Endpoint(s) using analog values: Absorption, distribution, metabolism &
excretion, carcinogenicity, developmental toxicity, immunotoxicity,
neurotoxicity, repeated dose effects
Analog Structure: Not applicable
Structural Alerts: Not applicable
Risk Phrases: Not classified by Annex VI Regulation (EC) No 1272/2008 (ESIS, 2011).
Hazard and Risk Assessments: Hazard assessment in Design for the Environment Alternatives Assessment for Flame Retardants in Printed Circuit Boards, Review
Draft, November 8, 2008 (EPA, 2008).
4-35
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
Decomposes at 315 (Measured)
Submitted confidential study
Adequate.
Decomposes at 300 (Measured)
Submitted confidential study
>400 according to EU Method A. 1
using differential scanning calorimetry
(Measured)
ECHA, 2013; Submitted
confidential study
Decomposes at 330 (Measured)
De Boysere and Dietz, 2005
Sufficient details were not available
to assess the quality of this study.
Decomposes at >300 (Measured)
Clariant, 2007
Sufficient details were not available
to assess the quality of this study.
>400 (Measured)
NICNAS, 2005
Sufficient details were not available
to assess the quality of this study.
Reported for a commercial
formulation.
Boiling Point (°C)
Expected to decompose before boiling
(Estimated)
Professional judgment
Based on available data for melting
point.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; EPA,
1999
Cutoff value for compounds that are
anticipated to be nonvolatile,
according to HPV assessment
guidance.
4-36
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Water Solubility (mg/L)
2.5* 103 (Measured)
Submitted confidential study
Sufficient details were not available
to assess the quality of this study.
Aluminum diethylphosphinate has
low wettability and very slow
dissolution. This gives a kinetically
controlled solubility of <1 mg/L by
guideline 92/69/ European Economic
Community (EEC) A.6. If aluminum
diethylphosphinate is formed by
precipitation of a soluble salt, the
remaining equilibrium solubility of
2.5 x 103 mg/L is found. This can be
assumed to be the true limit of
solubility under ideal conditions.
<1 (Measured)
According to EU Method A.6
ECHA, 2013;
Submitted confidential study
Guideline study; aluminum
diethylphosphinate has low
wettability and very slow dissolution.
If aluminum diethylphosphinate is
formed by precipitation of a soluble
salt, the remaining equilibrium
solubility of 2.5 x 103 mg/L is found,
which can be assumed to be the true
limit of solubility under ideal
conditions.
<1 (Measured)
According to EU Method A.6
NICNAS, 2005;
Submitted confidential study
Reported in a secondary source for a
commercial formulation.
Log Kow
-0.44 (Estimated)
Stuer-Lauridsen et al., 2007;
Beard and Marzi, 2005
Reported in a secondary source; it is
unclear whether this value reflects the
chemical's low water solubility or its
lipophobicity.
4-37
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Flammability (Flash Point)
Not readily combustible according to
guideline 96/69/EEC, test A. 10.
(Measured)
Submitted confidential study
Guideline study.
No self-ignition below 402°C (Measured)
ECHA, 2013; Submitted
confidential study
Adequate.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
Pyrolysis
Major products are diethylphosphinic acid,
ethylphosphonic acid, phosphoric acid,
and their respective salts (Measured)
Beard and Marzi, 2005
Study details and test conditions were
not available.
pH
4.0 (Measured)
Beard and Marzi, 2005
Value was reported in conference
presentation authored by Clariant
Corp. and UMSICHT. Value suggests
the potential for dissolution.
pKa
Dissociated within 24 hours at pH 4.5
during Japanese Ministry of International
Trade and Industry (MITI) test (Measured)
NICNAS, 2005
Available data suggest that this
compound is likely to dissociate
under environmental conditions.
However, it has potential for
dissociation as a function of pH that
will have a significant influence on
its environmental fate. Available data
are not adequate to assess its
dissociation under typical
environmental conditions. Reported
for a commercial formulation.
4-38
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
Based on estimates of physical and chemical properties, analogs, and professional judgment, aluminum
diethylphosphinate is determined to not be readily absorbed through skin but is absorbed through the
inhalation of dust and oral exposure.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
Absorption as neat solid negligible
through skin. Absorption good through
lungs. Absorption good through
gastrointestinal tract. (Estimated)
Professional judgment
Estimates based on
physical/chemical properties and
confidential analogs.
Male rats (2/dose group) administered
(unradiolabeled) test substance via single
oral gavage at 180 and 1,000 mg/kg
bw/day.
Only a small amount of the administered
dose was absorbed by the gastro-
intestinal tract. The major route of
elimination was in the feces (unabsorbed
fraction) and a small amount of free test
substance was detected in the urine.
After 36 hours, no test substance was
detected.
Submitted confidential study
Study details from an abstract
reported in a confidential
submission; study conducted
according to Organisation of
Economic Cooperation and
Development (OECD) 417; small
number of animals tested.
Acute Mammalian Toxicity
LOW: Experimental studies indicate that oral and dermal routes to rats do not produce substantial
mortality at levels up to 2,000 mg/kg. No lethality data were located for inhalation exposure.
Acute Lethality
Oral
Rat oral LD50 >2,000 mg/kg
NICNAS, 2005; Submitted
confidential study
Reported in a secondary source for
a commercial formulation. Test
substance was Exolit OP 930.
Dermal
Rat dermal LD50 >2,000 mg/kg
NICNAS, 2005; Submitted
confidential study
Reported in a secondary source for
a commercial formulation. Test
substance was Exolit OP 930.
Inhalation
No data located.
Carcinogenicity
LOW: Aluminum diethylphosphinate is estimated to be of low hazard for carcinogenicity based on
comparison to analogous metal salts and professional judgment.
4-39
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
OncoLogic Results
No data located.
Carcinogenicity (Rat
and Mouse)
Not expected to be carcinogenic
(Estimated)
Professional judgment
Estimated based on analogy to
confidential metal salts.
Combined Chronic
Toxicity/
Carcinogenicity
No data located.
Genotoxicity
LOW: Experimental studies indicate that aluminum diethylphosphinate does not cause gene mutations in
bacteria or chromosomal aberrations in mammalian cells.
Gene Mutation in vitro
Negative, Salmonella typhimurium
strains TA1535, TA1537, TA98 and
TA100 with and without metabolic
activation
NICNAS, 2005; Submitted
confidential study
Reported in a secondary source for
a commercial formulation.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
Negative, chromosomal aberrations in
Chinese hamster lung cells with and
without metabolic activation
NICNAS, 2005; Submitted
confidential study
Reported in a secondary source for
a commercial formulation.
Chromosomal
Aberrations in vivo
Negative, mammalian erythrocyte
micronucleus test in NMRI mice; oral
(unspecified)
Submitted confidential study
Study reported in a submitted
confidential study; Study conducted
according to OECD Guideline 474
(Mammalian Erthrocyte
Micronucleus Test).
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
Reproductive Effects
VERY LOW: There were no reproducti
in rats at doses up to 1,000 mg/kg-day.
hazard for reproductive effects resulting
judgment based on a comparison to ana
ve effects reported in a reproduction/developmental toxicity screen
n addition, aluminum diethylphosphinate is estimated to be of low
from the presence of a bioavailable metal species, by professional
ogous metal salts.
Reproduction/
Developmental Toxicity
Screen
Expected to have low hazard potential
for reproductive effects (Estimated)
Professional judgment
Estimated based on analogy to
confidential metal salts.
4-40
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Rats (Sprague Dawley); oral
administration of 250 and 1,000 mg/kg
bw-day; 15 days prior to mating and
throughout gestation and lactation up to
post-partum Day 3.
Submitted confidential study
Study reported in a submitted
confidential study; Study conducted
according to OECD Guideline 421
(Reproductive/Developmental
Toxicity Screening Test).
No clinical signs of toxicity or change in
food consumption. Slight reduction in
body weight and body weight gain (both
sexes, 1,000 mg/kg-day); Reduced
terminal body weight and absolute and
relative kidney weights (males, 1,000
mg/kg-day).
No adverse effect on oestrus cycle,
implantation, gestation length, corpora
lutea or sex ratios. No effect on sperm
(motility, morphology, concentration).
Increase in the number of days of pre-
coital interval and a reduction in
copulation plugs (1,000 mg/kg-day).
No treatment-related macroscopic
anomalies in pups dying or sacrificed at
term.
NOAEL = 1,000 mg/kg-day
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
Reproduction and
Fertility Effects
No data located.
4-41
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Developmental Effects
MODERATE: There were no developmental effects reported in a reproduction/developmental toxicity
screen in rats at doses up to 1,000 mg/kg-day. There is moderate hazard for aluminum diethylphosphinate
given exposure may result in neurodevelopmental effects based on the presence of a phosphinate; there
were no experimental studies specifically designed to evaluate the neurodevelopmental endpoint located.
The potential for neurodevelopmental effects cannot be ruled out.
Reproduction/
Developmental Toxicity
Screen
Expected to have a moderate hazard
potential for developmental and
neurodevelopmental effects resulting
from the presence of a phosphinate.
(Estimated)
Professional judgment
Estimated based on analogy to
phosphate esters and associated
cholinesterase inhibition.
4-42
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Rats (Sprague Dawley); oral
administration of 250 and 1,000 mg/kg
bw-day; 15 days prior to mating and
throughout gestation and lactation up to
post-partum Day 3.
No clinical signs of toxicity or change in
food consumption. Slight reduction in
body weight and body weight gain;
reduced terminal body weight and
absolute and relative kidney weights
(males, 1,000 mg/kg-day). No adverse
effect on estrus cycle, implantation,
gestation length, corpora lutea or sex
ratios. No effect on sperm (motility,
morphology, concentration). Increase in
the number of days of pre-coital interval
and a reduction in copulation plugs
(1,000 mg/kg-day).
Submitted confidential study
Study details reported in a
confidential submission; Study
conducted according to OECD
Guideline 421
(Reproductive/Developmental
Toxicity Screening Test).
No treatment-related macroscopic
anomalies in pups dying or sacrificed at
term.
NOAEL = 1,000 mg/kg-day
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
Prenatal Development
No data located.
Postnatal Development
No data located.
4-43
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Neurotoxicity
MODERATE: Aluminum diethylphosphinate is estimated to be of moderate hazard for neurotoxicity, due
to the presence of a bioavailable metal species and based on comparison to aluminum hydroxide with
professional judgment.
Neurotoxicity Screening
Battery (Adult)
Expected to have a moderate hazard
potential for neurotoxic effects resulting
from the presence of bioavailable metal
species. (Estimated)
Professional judgment
Estimated based on professional
judgment and analogy to aluminum
hydroxide.
Rat NOAEL >1,000 mg/kg
Beard and Marzi, 2005
Study details and test conditions
were not available.
90-day Rat, oral gavage, impaired
learning in a labyrinth maze test
NOAEL = Not established
LOAEL = 35 mg Al/kg-day as aluminum
hydroxide with citric acid (only dose
tested)
(Estimated by analogy)
Bilkei-Gorzo, 1993 (as cited in
ATSDR, 2008)
Reported in a secondary source;
dose reported as 35 mg/kg-day as
aluminum hydroxide with citric
acid; citric acid was added to
increase absorption; it is not proven
that negative effects only related to
aluminum hydroxide and not based
on citric acid; also, the background
aluminum content of the diet fed to
rats was not reported; only one dose
tested.
90-day Rat, oral gavage, impaired
learning in a labyrinth maze test
NOAEL = Not established
LOAEL = 300 mg Al/kg-day as
aluminum hydroxide (only dose tested)
(Estimated by analogy)
Bilkei-Gorzo, 1993
The background aluminum content
of the diet fed to rats was not
reported; only one dose tested;
study description lacks sufficient
details on individual results.
Repeated Dose Effects
MODERATE: Estimated to be of moderate hazard for immunotoxicity, due to the presence of a
bioavailable metal species, based on comparison to analogous metal salts and professional judgment.
Experimental studies indicate that oral exposure to rats produces no adverse effects at levels up to 1,000
mg/kg- day.
28- day NOAEL >1,000 mg/kg-day, rats
NICNAS, 2005; Submitted
confidential study
Reported in a secondary source for
a commercial formulation. Test
substance was Exolit OP 930.
4-44
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Immune System Effects
Expected to have a moderate hazard
potential for immunotoxicity effects
resulting from the presence of
bioavailable metal species.(Estimated)
Professional judgment
Estimated based on analogy to
confidential metal salts.
Skin Sensitization
LOW: Negative for skin sensitization in guinea pigs.
Skin Sensitization
Non-sensitizing, guinea pigs
NICNAS, 2005; Submitted
confidential study
Reported in a secondary source for
a commercial formulation.
Respiratory Sensitization
No data located.
Respiratory Irritation
No data located.
Eye Irritation
LOW: Aluminum diethylphosphinate is slightly to non-irritating in rabbit eyes.
Eye Irritation
Slightly irritating, rabbits
NICNAS, 2005
Reported in a secondary source for
a commercial formulation.
Not irritating, rabbits
Submitted confidential study
Study reported in a submitted
confidential study.
Dermal Irritation
VERY LOW: Aluminum diethylphosphinate is not irritating to rabbit skin.
Dermal Irritation
Non-irritating, rabbit
NICNAS, 2005; Submitted
confidential study
Reported in a secondary source for
a commercial formulation.
Endocrine Activity
No data located.
No data located.
Immunotoxicity
Aluminum diethylphosphinate is estimated to be of moderate hazard for immunotoxicity, due to the
presence of a bioavailable metal species, based on comparison to analogous metal salts and professional
judgment.
Immune System Effects
Expected to have a moderate hazard
potential for immunotoxicity effects
resulting from the presence of
bioavailable metal species. (Estimated)
Professional judgment
Estimated based on analogy to
confidential metal salts.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
MODERATE: The measured green algae ECS0 is between 10 and 100 mg/L. For fish and Daphnia, adequate
toxicity values have not been determined; reported values are not LCS0 but the highest dose tested.
Fish LC50
Danio rerio (Zebra fish) 96-hour LC50
>11 mg/L (Experimental)
NICNAS, 2005
Reported in a secondary source for
a commercial formulation.
4-45
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Danio rerio (Zebra fish) 96-hour LC50
>9.2 mg/L (Experimental)
Submitted confidential study
Study reported in a submitted
confidential study.
Danio rerio (Zebra fish) 96-hour LC50
>100 mg/L (Experimental)
Submitted confidential study
Study reported in a submitted
confidential study; Study conducted
according to EU Method C.l
(Acute Toxicity for Fish).
Daphnid LCS0
Daphnia magna 48-hour LC50 >33.7
mg/L (Experimental)
NICNAS, 2005
Reported in a secondary source for
a commercial formulation.
Daphnia magna 48-hour LC50 >33 mg/L
(Experimental)
Submitted confidential study
Study reported in a submitted
confidential study.
Daphnia magna 48-hour EC50 >100
mg/L; 48-hour NOEC = 100 mg/L
Submitted confidential study
Study reported in a submitted
confidential study; Study conducted
according to OECD Guideline 202
(Daphnia sp. Acute Immobilization
Test).
Green Algae ECS0
Scenedesmus subspicatus 72-hour EbC50
of 60 mg/L (Experimental);
Scenedesmus subspicatus 72-hour ErC50
of 76 mg/L (Experimental)
NICNAS, 2005
Reported in a secondary source for
a commercial formulation.
72-hour EC50 = 50mg/L (Experimental)
Submitted confidential study
Study reported in a submitted
confidential study.
Scenedesmus subspicatus 72-hour EC50
>180 mg/L (Experimental)
Submitted confidential study
Study reported in a submitted
confidential study; Study conducted
according to EU Method c.3 (Algal
Inhibition Test).
Chronic Aquatic Toxicity
MODERATE: An experimental value of 1.8 mg/L was reported for green algae, while measured toxicity
values for fish and Daphnia are >10 mg/L.
Fish ChV
48 mg/L (Estimated)
Submitted confidential study
Study reported in a submitted
confidential study.
Danio rerio (Zebra fish) 28-day NOEC =
100 mg/L; LOEC >100 mg/L
(Experimental)
Submitted confidential study
Study reported in a submitted
confidential study; Study conducted
according to OECD Guideline 215
(Fish, Juvenile Growth Test).
4-46
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid ChV
Daphnia magna 21-day EC50 = 22.3
mg/L for immobility (Experimental)
Daphnia magna 21-day EC50 = 46.2
mg/L for reproduction (Experimental)
Daphnia magna 21-day LOEC = 32
mg/L for immobility and reproduction
(Experimental)
Daphnia magna 21-day NOEC = 10
mg/L for immobility and reproduction
(Experimental)
NICNAS, 2005; Submitted
confidential study
Reported in a secondary source for
a commercial formulation.
Green Algae ChV
1.8 mg/L (Experimental)
Submitted confidential study
Study reported in a submitted
confidential study.
ENVIRONMENTAL FATE
Transport
Although the behavior of metal salts under environmental conditions is dependent on the characteristics of
the local environment (predominately pH), transport of both the metal species and the organic anion is
anticipated to be dominated by leaching through soil, runoff to aqueous environments, adsorption and/or
precipitation of the metal ion onto soil or sediment, and wet and dry deposition of dust particulates in air to
land or surface water. Volatilization of this ionic compound from either wet or dry surfaces is not expected to
be an important fate process. Nevertheless, the environmental fate of this organic salt will be dependent on its
pH-dependent dissociation, and adequate data are not available.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment
Cutoff value for nonvolatile
compounds.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
Approximately 0.38 according to OECD
Guideline 121 (Measured)
ECHA, 2013; Submitted
confidential study
Guideline study.
Level III Fugacity Model
This substance is not amenable to the
model.
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Persistence
HIGH: For the organic counter-ion, estimates indicate that the half-life for ultimate aerobic biodegradation
in water is less than 60 days, which converts to moderate potential for persistence. However, the metal ion is
recalcitrant to biodegradation or other typical environmental removal processes.
Water
Aerobic Biodegradation
Organic counter-ion:
Days-weeks (primary survey model)
Weeks (ultimate survey model)
(Estimated)
EPI
Metal ion: Recalcitrant (Estimated)
Professional judgment
Metal ions will not degrade in the
environment.
Not readily biodegradable according to
OECD Guideline 301 F (Measured)
ECHA, 2013; Submitted
confidential study
Guideline study.
Not inherently biodegradable according to
OECD Guideline 302 C (Inherent
Biodegradability: Modified MITI Test (II))
(Measured)
ECHA, 2013; Submitted
confidential study
Guideline study.
Not inherently biodegradable (Measured)
Stuer-Lauridsen et al., 2007
Sufficient details were not available
to assess the quality of this study.
Not readily biodegradable (Measured)
NICNAS, 2005
Reported in a secondary source for a
commercial formulation.
Not readily biodegradable (Measured)
Stuer-Lauridsen et al., 2007
Sufficient details were not available
to assess the quality of this study.
Volatilization Half-life for
Model River
Not a significant fate process (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Volatilization Half-life for
Model Lake
Not a significant fate process (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Soil
Aerobic Biodegradation
Respiration inhibition of activated sludge
microorganisms LC50 = 1968 mg/L, NOEC
= 483 mg/L (Measured)
NICNAS, 2005; Submitted
confidential study
Reported in a secondary source for a
commercial formulation.
Anaerobic
Biodegradation
No degradation according to ISO/DIS
14853 (Measured)
Stuer-Lauridsen et al., 2007
Guideline study reported in a
secondary source.
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Aluminum Diethylphosphinate CASRN 225789-38-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Soil Biodegradation w/
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
Not a significant fate process (Estimated)
Professional judgment
This chemical is expected to exist
entirely in particulate form in air.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Mill, 2000;
Professional judgment
The substance does not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
Hydrolysis
Metal salts form a variety of hydroxylation
products as a function of pH. Hydrolysis
of the organic counter-ion is not expected
to be a significant fate process (Estimated)
Wolfe and Jeffers, 2000;
Professional judgment
The organic counter ion does not
contain functional groups that would
be expected to hydrolyze readily
under environmental conditions.
Environmental Half-life
Organic counter-ion: <60 days
Metal ion: Recalcitrant
(Estimated)
EPI; Professional judgment
Based on estimated biodegradation
half-lives for the organic counter-ion
and metal ions will not degrade in the
environment.
Bioaccumulation
LOW: Aluminum diethylphosphinate is not expected to have potential for bioaccumulation.
Fish BCF
<100 (Estimated)
Professional judgment
Available data suggests this chemical
will dissociate under environmental
conditions.
BAF
No data located.
Metabolism in fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-49
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ATSDR (Agency for Toxic Substances and Disease Registry). Draft toxicological profile for aluminum. [Online] U.S. Department of
Health and Human Services: September 2008. http://www.atsdr.cdc.gov/toxprofiles/tp22.pdf.
Beard, A; Marzi, T. New phosphorus based flame retardants for E&E applications: A case study on their environmental profile in
view of European legislation on chemicals and end-of-life (REACH), WEEE, RoHS). In Addcon 2005, September 20-21, 2005,
Hamburg, Germany. 2005. http://www.flameretardants-online.com/images/userdata/pdf/175 EN.pdf
Bilkei-Gorzo, A. Neurotoxic effect of enteral aluminum. Food Chem Toxicol. 1993. 31(5):357-361.
Clariant. Exolit OP 930 Product Data Sheet; 2007.
De Boysere, J.; Dietz, M. Halogen-free flame retardants for electronic applications. OnBoard Technology. [Online] 2005, 20.
http://www.onboard-technology.com/pdf febbraio2005/020505.pdf
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
May 10, 2011).
ECHA (European Chemicals Agency). Information on registered substances. 2013. http://echa.europa.eu/web/guest/information-on-
chemicals/registered-substances (accessed Jan, 22, 2013).
EPA (U.S. Environmental Protection Agency). Alternatives Assessment for Flame Retardants in Printed Circuit Boards, Review Draft.
2008. http://www.epa.gov/dfe/pubs/proiects/pcb/full report pcb flame retardants report draft 11 10 08 to e.pdf.
EPI (EPIWIN EPISUITE) Estimation Program Interface for Windows, Version 3.20. U.S. Environmental Protection Agency:
Washington, DC. http://www.epa.gov/opptintr/exposure/.
ESIS (European chemical Substances Information System) Classification, Labeling and Packaging of Dangerous Substances Annex
VI to Regulation (EC) No 1272/2008 [Online] http://esis.irc.ec.europa.eu/ (accessed on May 10, 2011).
Mill, T. (2000) Photoreactions in Surface Waters. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for
Chemicals, Environmental Health Sciences (355-382). Boca Raton: Lewis Publishers.
4-50
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NICNAS (National Industrial Chemicals Notification and Assessment Scheme). Full public report on chemical in Exolit OP 1312.
[Online] 2005.
http://www.nicnas.gov.au/publications/car/new/std/stdfullr/stdl000fr/stdll68fr.pdf
Stuer-Lauridsen, F.; Karl-Heinz, C.; Andersen, T. T. Health and Environmental Assessment of Alternatives to Deca-BDE in Electrical
and Electronic Equipment; Environmental Project No. 1142; [Online] Danish Ministry for the Environment, Danish Environmental
Protection Agency. 2007. http://www2.mst.dk/Udgiv/publications/2007/978-87-7052-351-6/pdf/978-87-7052-352-3.pdf
U.S. EPA (Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing
Data. U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
Wolfe, N; Jeffers, P. (2000) Hydrolysis. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for Chemicals,
Environmental Health Sciences (311-334). Boca Raton: Lewis Publishers.
4-51
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Aluminum Hydroxide
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
R Recalcitrant: Substance is comprised of metallic species that will not degrade, but may change oxidation state or undergo complexation processes under enviromnental conditions.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Aluminum Hydroxide
21645-51-2
L
L
L
L
L
M
L
VL
VL
M
M
Hr
L
**Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-52
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Aluminum Hydroxide
HO
\
Al-
¦OH
/
HO
CASRN: 21645-51-2
MW: 78.01
MF: AIH3O3
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: 0[A1](0)0
Synonyms: Aluminum hydroxide (Al(OH)3); Aluminum trioxide; Gibbsite; Bayersite; Nordstrandite; Aluminum trihydrate
Chemical Considerations: This alternative is an inorganic compound and in the absence of experimental data, professional judgment using chemical class and
structural considerations were used to complete this hazard profile.
Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: None
Analog: Unspecified analogous aluminum compounds were discussed in the
structural based professional judgment rationale.
Endpoint(s) using analog values: Carcinogenicity, reproductive effects,
immunotoxicity
Analog Structure: Not applicable
Structural Alerts: Aluminum compounds (EPA, 2010).
Risk Phrases: Not classified by Annex I Directive 67/548/ European Economic Community & IUCLID (Pakalin et al., 2007).
Hazard and Risk Assessments: Risk assessment completed for aluminum hydroxide by the National Research Council Subcommittee on Flame-Retardant Chemicals
(NRC, 2000). Hazard assessment completed for Design for the Environment (DfE) Alternatives Assessment for Flame Retardants in Printed Circuit Boards, Review
Draft, November 8, 2008 (EPA, 2008).
4-53
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Aluminum Hydroxide CASRN 21645-51-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
Decomposes at approximately 200
(Measured)
European Commission, 2000
Adequate.
Decomposes at approximately 150-220 to
A1203 and H20 (Measured)
European Commission, 2000
Decomposes (loses water) at 300
(Measured)
Lewis, 2000
Boiling Point (°C)
The substance is expected to decompose
before boiling (Estimated)
Professional judgment
Based on the values included in the
melting point section of this
assessment.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; EPA,
1999
Cutoff value for compounds that are
anticipated to be nonvolatile,
according to HPV assessment
guidance.
Water Solubility (mg/L)
<0.09 at pH 6-7
Organisation of Economic Cooperation
and Development (OECD) Guideline 105
Purity calculated based on aluminum oxide
(Measured)
ECHA, 2013
Guideline study reporting non-
specific value that is in agreement
with other experimental values
indicating poor solubility.
4-54
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Aluminum Hydroxide CASRN 21645-51-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
0.0117 to 0.0947 at pH 7.5-8.1 and 21-
24 C.
Submitted study
Reported in a nonguideline study
done to prepare for toxicity testing.
Reported as 11.7 to 94.7 |a,g/L Al(OH)3
and 4.06 to 32.75 |a,g/L Al.
100 mg of Al(OH)3 was dissolved in 100
mL distilled water or test media prepared
according to OECD 201, 202 or 211,
filtered, and then analyzed using Graphite
Furnace Atomic Absorption Spectrometry
(GF AAS) and Inductively Coupled
Plasma Atomic Emission Spectroscopy
(ICP-AES). (Measured)
1.5 at 20 C at pH 7 (Measured)
European Commission, 2000
Measured values were not
1.5xl0"2 at 20 C at pH 8-9 (Measured)
European Commission, 2000
consistently reported, but are
sufficient for subsequent components
of the hazard assessment.
Insoluble in water (Estimated)
Lide, 2006
Practically insoluble in water (Estimated)
O'Neil, 2001; Lewis, 2000
Log K0„
No data located. This inorganic
compound is not amenable to
available estimation methods.
Flammability (Flash Point)
Not flammable (Estimated)
European Commission, 2000
Adequate.
Explosivity
Not explosive (Estimated)
European Commission, 2000
Adequate.
Pyrolysis
No data located.
pH
pH of a saturated solution in water was 6
to 7 (Measured)
ECHA, 2013
Determined in a water solubility
study.
pKa
Not applicable (Estimated)
Professional judgment
Determination of dissociation
constant is not possible due to the
insolubility of the test substance.
4-55
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Aluminum Hydroxide CASRN 21645-51-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
Toxicokinetic data suggest that aluminum hydroxide is not readily absorbed in humans following oral
exposure. Excretion occurs primarily through feces, and less so in urine. Animal studies indicated that
aluminum accumulated in intestinal cells but was not found in other tissues.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
26A1 labeled aluminum hydroxide (in
water suspension) was administered to
rats by oral gavage.
The mean fractional uptake of26A1 from
aluminum hydroxide was 0.025±0.041%
compared to a mean fractional uptake of
0.079±0.0057% from 26A1 labeled
aluminum citrate in solution. Aluminum
hydroxide as an insoluble compound is
less bioavailable than soluble
compounds.
ECHA, 2013
Reported in a secondary source.
Adequate, performed in accordance
with OECD guidelines and good
laboratory practice (GLP);
Aluminium hydroxide, was
suspended in water with added 1%
carboxymethylcellulose (to
maintain a suspension).
After rats were exposed to aluminum
hydroxide in drinking water for 10
weeks, aluminum accumulated in
intestinal cells but not in other tissues.
HSDB, 2013
Reported in a secondary source,
study details and test conditions
were not provided.
In metabolic studies in humans, 12% of
an oral load of aluminum hydroxide was
retained, but absorption was not
calculated.
HSDB, 2013
Reported in a secondary source,
study details and test conditions
were not provided.
The absorbed fraction of aluminum
hydroxide in two human males dosed
orally was 0.01%.
HSDB, 2013
Reported in a secondary source,
study details and test conditions
were not provided.
Adult humans with renal failure who
ingested 1.5-3.0 g aluminum hydroxide
per day for 20-32 days absorbed between
100 and 568 mg aluminum per day (7-
19% of the dose).
HSDB, 2013
Reported in a secondary source,
study details and test conditions
were not provided.
4-56
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Aluminum Hydroxide CASRN 21645-51-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Adult humans taking aluminum antacids
had a 3-fold increase of aluminum levels
in the urine; minimal aluminum was
absorbed and was mostly excreted in the
feces.
ATSDR, 2008
Reported in a secondary source,
study details were not provided.
Acute Mammalian Toxicity
LOW: Aluminum hydroxide has low acute toxicity based on oral LDS0 >2,000 mg/kg-bw in rats.
Acute Lethality
Oral
Rat oral LD50 >5,000 mg/kg bw
European Commission, 2000
Reported in a secondary source,
study details and test conditions
were not provided.
Rat oral LD50 >2,000 mg/kg bw
ECHA, 2013
Reported in a secondary source.
Performed in accordance with
OECD guidelines and GLP.
Dermal
No data located.
Inhalation
No data located.
Carcinogenicity
LOW: Aluminum hydroxide is estimated to be of low hazard for carcinogenicity based on professional
judgment and comparison to analogous aluminum compounds.
OncoLogic Results
Low potential for carcinogenicity
(Estimated)
Professional judgment
Estimated based on professional
judgment and comparison to
analogous aluminum compounds.
Carcinogenicity (Rat
and Mouse)
Combined Chronic
Toxicity/
Carcinogenicity
Genotoxicity
LOW: Aluminum hydroxide did not cause mutations in bacteria in vitro and did not cause chromosomal
aberrations in vitro.
Gene Mutation in vitro
Negative in mouse lymphoma cells with
and without metabolic activation
ECHA, 2013
Adequate, performed in accordance
with OECD guidelines and GLP.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
No data located.
Chromosomal
Aberrations in vivo
Negative for induction of micronuclei in
polychromatic erythrocytes of bone
marrow in Sprague-Dawley rats
ECHA, 2013
Adequate, performed in accordance
with OECD guidelines and GLP.
4-57
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Aluminum Hydroxide CASRN 21645-51-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
Reproductive Effects
LOW: Aluminum hydroxide is estimated to be of low hazard for reproductive effects based on professional
judgment and comparison to analogous aluminum compounds.
Reproduction/
Developmental Toxicity
Screen
Low potential for reproductive effects
(Estimated)
Professional judgment
Estimated based on professional
judgment and comparison to
analogous aluminum compounds.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Reproduction and
Fertility Effects
Developmental Effects
LOW: Aluminum hydroxide does not show developmental toxicity when administered orally to rats or mice
at dose levels up to 266 mg/kg-day. There were no data located regarding developmental neurotoxicity.
Reproduction/
Developmental Toxicity
Screen
No data located.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
Prenatal Development
Low potential for developmental
neurotoxicity
(Estimated)
Professional judgment
Estimated based on analogy to
structurally similar compounds.
Mouse, oral, no developmental effects,
NOAEL = 266 mg/kg-day (highest dose
tested)
Domingo et al., 1989
Adequate.
4-58
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Aluminum Hydroxide CASRN 21645-51-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Mouse, oral, NOAEL = 268 mg/kg-day
(highest dose tested)
Gomez et al., 1989
Abstract only.
Mouse, oral, NOAEL = 300 mg/kg-day
(only dose tested)
Colomina et al., 1994
Abstract only.
Rat, oral, NOAEL = 768 mg/kg-day
(highest dose tested)
Gomez etal., 1990
Abstract only.
Rat, oral, NOAEL = 384 mg/kg-day
(only dose tested)
Llobet et al., 1990
Abstract only.
Postnatal Development
No data located.
Neurotoxicity
MODERATE: Aluminum hydroxide is expected to be of moderate hazard for neurotoxicity based on
impaired learning in a labyrinth maze test in a 90-day oral study in rats at 35 mg Al/kg/day as aluminum
hydroxide with citric acid. Impaired learning in a labyrinth maze test was also reported in rats orally
exposed to 300 mg Al/kg/day as aluminum hydroxide; there is uncertainty in the threshold of response, the
possibility that effects occur at doses <100 mg/kg/day (in the Moderate - High hazard designation range)
cannot be ruled out.
Neurotoxicity Screening
Battery (Adult)
30-day Rat, oral diet, no significant
effects noted, NOAEL = 1,252 mg
Al/kg-day
Thome et al. 1986, 1987 (as
described in ATSDR, 2008)
Reported in a secondary source.
90-day Rat, oral gavage, impaired
learning in a labyrinth maze test
NOAEL = Not established
LOAEL = 35 mg Al/kg-day as aluminum
hydroxide with citric acid (only dose
tested)
Bilkei-Gorzo, 1993 (as
described in ATSDR, 2008)
Reported in a secondary source;
dose reported as 35 mg/kg-day as
aluminum hydroxide with citric
acid; citric acid was added to
increase absorption; it is not proven
that negative effects only related to
aluminum hydroxide and not based
on citric acid; also, the background
aluminum content of the diet fed to
rats was not reported; only one dose
tested.
90-day Rat, oral gavage, impaired
learning in a labyrinth maze test
NOAEL = Not established
LOAEL = 300 mg Al/kg-day as
aluminum hydroxide (only dose tested)
Bilkei-Gorzo, 1993
The background aluminum content
of the diet fed to rats was not
reported; only one dose tested;
study description lacks sufficient
details on individual results.
4-59
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Aluminum Hydroxide CASRN 21645-51-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Repeated Dose Effects
MODERATE: Aluminum hydroxide is estimated to have potential for immunotoxicity based on
professional judgment and comparison to analogous aluminum compounds. Aluminum hydroxide is of low
hazard for repeated dose effects based on an experimental study indicating no adverse effects in rats
following oral doses up to 14,470 ppm (302 mg/kg-day). In addition, a low potential for repeated dose effect
is estimated based on professional judgment and comparison to analogous aluminum compounds.
Low potential for repeated dose effects
but moderate potential for
immunotoxicity.
(Estimated)
Professional judgment
Estimated based on professional
judgment and comparison to
analogous aluminum compounds.
28-day Rat (male), oral diet, no systemic
effects noted.
NOAEL = 14,470 ppm/diet (302 mg
Al/kg-day)
Hicks et al., 1987
Study details from primary source.
6-Week human, oral, LOAEL = 25 mg
Al/kg-day (Reduction in primed
cytotoxic T-cells, only dose tested)
ATSDR, 2008
Reported in a secondary source.
Skin Sensitization
LOW: Aluminum hydroxide is not a skin sensitizer in guinea pigs.
Skin Sensitization
Low potential for skin sensitization
(Estimated)
Professional judgment
Estimated based on professional
judgment and comparison to
analogous aluminum compounds.
Not sensitizing to guinea pigs in an in
vivo maximization test
ECHA, 2013
Reported in a secondary source;
conducted in accordance with
OECD guidelines and GLP.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
VERY LOW: Aluminum hydroxide is not irritating to rabbit eyes.
Eye Irritation
Not irritating, rabbits
ECHA, 2013
Reported in a secondary source;
Conducted in accordance with
OECD guidelines and GLP.
4-60
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Aluminum Hydroxide CASRN 21645-51-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Dermal Irritation
VERY LOW: Aluminum hydroxide is not irritating to skin.
Dermal Irritation
Not irritating, rabbits
ECHA, 2013
Reported in a secondary source.
Conducted in accordance with
OECD guidelines and GLP.
Not irritating, rabbits, mice and pigs
ECHA, 2013
Reported in a secondary source;
nonguideline studies.
Endocrine Activity
No data located.
No data located.
Immunotoxicity
Aluminum hydroxide is estimated to have potential for immunotoxicity based on professional judgment and
comparison to analogous aluminum compounds.
Immune System Effects
Moderate potential for immunotoxicity
(Estimated)
Professional judgment
Estimated based on professional
judgment and comparison to
analogous aluminum compounds.
6-Week human, oral LOAEL = 25 mg
Al/kg-day (Reduction in primed
cytotoxic T-cells, only dose tested)
ATSDR, 2008
Reported in a secondary source.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
MODERATE: Aluminum hydroxide is estimated to be of moderate hazard for acute aquatic toxicity based
on potential for dissolved aluminum species to cause adverse effects in aquatic species, as described in the
EPA New Chemical Categories document which includes inorganic salts of aluminum (Professional
judgment; EPA, 2010). Additional studies for acute toxicity to daphnia and algae are ongoing; the results of
these studies may affect the acute aquatic hazard designation.
Fish LC50
Salmo trutta 96-hour NOEC >100 mg/L
(Experimental)
European Commission, 2000
Reported in a secondary source.
The effect concentration is greater
than the measured water solubility.
Daphnid LC50
Daphnia magna 48-hour NOEC >100
mg/L
(Experimental)
European Commission, 2000
Reported in a secondary source.
Study details and test conditions
were not available and the effect
concentration is greater than the
measured water solubility.
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Aluminum Hydroxide CASRN 21645-51-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnia magna 48-hour NOEC >0.135
mg/L
(Experimental)
ECHA, 2013
Study conducted with aluminum
powder.
Daphnia magna 48-hr EC50 = 0.8240
mg/L
(Experimental)
TSCATS, 1996
Study incorrectly cited in source;
results are for a different test
substance, vanadium hydroxide
oxide.
Green Algae EC50
Selenastrum capricornutum 72-hour
NOEC >100 mg/L
(Experimental)
European Commission, 2000
Reported in a secondary source.
The effect concentration is greater
than the measured water solubility.
Selenastrum capri cornutum 96-hr EC50
= 0.6560 mg/L
(Experimental)
TSCATS, 1996
Study incorrectly cited in source;
results are for a different test
substance, vanadium hydroxide
oxide.
Pseudokirchnerella subcapitata 96-hr
EC50 = 0.46 mg/L
(Experimental)
ECHA, 2013
Reported in a secondary source.
EC50 range: 0.57 mg/L at pH of 7.6
and 0.46 mg/L at pH of 8.2. The
water solubility of aluminum
hydroxide under basic pH
conditions is not available;
experimental details are not
sufficient to address the confidence
limits of these data points.
Pseudokirchnerella subcapitata 72-hour
NOEC = 0.004 - 0.052 mg/L
(Experimental)
ECHA, 2013
Reported in a secondary source.
DfE criteria are based on LC and
EC50 values; therefore a NOEC
value is not sufficient to determine
a hazard designation.
Chronic Aquatic Toxicity
MODERATE: Aluminum hydroxide is estimated to be of moderate hazard for chronic aquatic toxicity
based on potential for dissolved aluminum species to cause adverse effects in aquatic species, as described in
the EPA Chemical Categories document which includes inorganic salts of aluminum (Professional
judgment; EPA, 2010). An additional study for chronic toxicity to daphnia is ongoing; the results of this
study may affect the chronic aquatic hazard designation.
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Aluminum Hydroxide CASRN 21645-51-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish ChV
Pimephcdes promelas 42-day NOEC =
0.102 mg/L, LOEC = 0.209 mg/L
(Experimental)
TSCATS, 1996
Study incorrectly cited in source;
results are for a different test
substance, vanadium hydroxide
oxide.
Daphnid ChV
Daphnia magna 21-day NOEC = 0.091
mg/L, LOEC = 0.197 mg/L
(Experimental)
TSCATS, 1996
Study incorrectly cited in source;
results are for a different test
substance, vanadium hydroxide
oxide.
Green Algae ChV
No data located.
ENVIRONMENTAL FATE
Transport
Although the behavior of aluminum salts under environmental conditions is dependent on the characteristics
of the local environment (predominately pH), transport of the aluminum (III) species is anticipated to be
dominated by leaching through soil; runoff to aqueous environments; adsorption and/or precipitation of the
metal ion onto soil or sediment; and wet and dry deposition dust particulates in air to land or surface water.
Volatilization of this ionic compound from either wet or dry surfaces is not expected to be an important fate
process. Under acidic pHs typically encountered in the environment, it may form insoluble polymeric
aluminum hydroxide colloids while under basic conditions; anionic aluminum hydroxide is expected to
predominate. Other factors influencing its behavior include the presence of dissolved organic matter, the
extent of absorption on suspended particles, and the presence of other aluminum species.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment
Cutoff value for non-volatile
compounds.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
Professional judgment; EPA,
2004
Cutoff value for non-mobile
compounds.
Level III Fugacity Model
No data located.
Persistence
HIGH: As an inorganic material, aluminum hydroxide is not expected to biodegrade or oxidize under typical
environmental conditions. Aluminum hydroxide does not absorb light at environmentally relevant
wavelengths and is not expected to photolyze. No degradation processes for aluminum hydroxide under
typical environmental conditions were identified.
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Aluminum Hydroxide CASRN 21645-51-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Water
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment
Substance is or contains inorganic
elements, such as metal ions or
oxides, that are expected to be found
in the environment >180 days after
release.
Volatilization Half-life for
Model River
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law constant.
Volatilization Half-life for
Model Lake
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law constant.
Soil
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment
Substance contains inorganic
elements.
Anaerobic
Biodegradation
Recalcitrant (Estimated)
Professional judgment
Substance contains inorganic
elements.
Soil Biodegradation w/
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
>1 year (Estimated)
Professional judgment
Substance contains inorganic
elements.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Professional judgment
Aluminum hydroxide does not absorb
UV light at environmentally relevant
wavelengths and is not expected to
undergo photolysis.
Hydrolysis
Dissociation of aluminum hydroxide
in environmental waters is dependent
both on the pH and the local
concentration of other aluminum
species; dissociation will not occur
unless in highly acidic waters, e.g.,
pH 3.
4-64
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Aluminum Hydroxide CASRN 21645-51-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Environmental Half-Life
No data located. Inorganic
compounds are outside the estimation
domain (EPI).
Bioaccumulation
LOW: Aluminum hydroxide is not expected to bioaccumulate.
Fish BCF
<100 (Estimated)
Professional judgment
Aluminum hydroxide is an inorganic
compound and is not anticipated to
bioaccumulate or bioconcentrate.
This inorganic compound is not
amenable to available quantitative
structure activity relationship models.
BAF
<100 (Estimated)
Professional judgment
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-65
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ATSDR (Agency for Toxic Substances and Disease Registry). Draft toxicological profile for aluminum. [Online] U.S. Department of
Health and Human Services: September 2008. http://www.atsdr.cdc.gov/toxprofiles/tp22.pdf.
Bilkei-Gorzo, A. Neurotoxic effect of enteral aluminum. Food Chem Toxicol. 1993, 31(5):357-361.
Colomina, M. T.; Gomez, M.; Domingo, J. L.; et al. Lack of maternal and developmental toxicity in mice given high doses of
aluminum hydroxide and ascorbic acid during gestation. Pharmacol Toxicol. 1994, 74(4-5):236-239 (Abstract Only).
CDC (Centers for Disease Control and Prevention). Fourth National Report on Raman Exposure to Environmental Chemicals,
Updated Tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf as of
May 10, 2011.
Domingo, J. L.; Gomez, M.; Bosque, M. A.; et al. Lack of teratogenicity of aluminum hydroxide in mice. Life Sciences. 1989,
45(3):243-247.
ECHA (European Chemicals Agency). Information on registered substances. 2013.
http://apps.echa.europa.eu/registered/data/dossiers/DISS-9e9ede9a-0fd5-2b35-e044-00144f67d031/DISS-9e9ede9a-0fd5-2b35-e044-
00144f67d031 PISS-9e9ede9a-0fd5-2b3 5-e044-00144f67d031 .html (accessed December, 2013).
EPA (Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing Data.
U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
EPA. 2004. The Pollution Prevention (P2) Framework, EPA-748-B-03-001. Office of Pollution Prevention and Toxics 7403M, U.S.
Environmental Protection Agency, Washington, DC. 20460. October 2003 version updated in January 2004. Latest version available
at http://www.epa.gov/opptintr/newchems/pubs/sustainable/p2frame-iune05a2.pdf
EPA (U.S. Environmental Protection Agency). Alternatives Assessment for Flame Retardants in Printed Circuit Boards, Review Draft.
2008. http://www.epa.gov/dfe/pubs/proiects/pcb/full report pcb flame retardants report draft 11 10 08 to e.pdf.
EPA (U.S. Environmental Protection Agency). TSCANew Chemicals Program (NCP) Chemical Categories. Washington D.C. 2010.
http://www.epa.gov/oppt/newchems/pubs/npcchemicalcategories.pdf (accessed on Sept. 8, 2011).
4-66
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European Commission - Aluminium hydroxide IUCLID Dataset. European Chemicals Bureau. 2000.
Gomez, M.; Domingo, J. L.; Bosque, A.; et al. Teratology study of aluminum hydroxide in mice. Toxicologist 1989, 9(1):273
(Abstract Only).
Gomez, M.; Bosque, M. A.; Domingo, J.; et al. Evaluation of the maternal and developmental toxicity of aluminum from high doses
of aluminum hydroxide in rats. Vet. Hum. Toxicol. 1990, 32(6):545-548 (Abstract Only).
Hicks, J. S.; Hackett, D. S.; Sprague, G. L. Toxicity and aluminum concentration in bone following dietary administration of two
sodium aluminum phosphate formulations in rats. FoodChem. Toxic. 1987, 25(7):533-538.
HSDB (Hazardous Substances Data Bank). Aluminum hydroxide. National Library of Medicine. 2013. http://toxnet.nlm.nih.gov/cgi-
bin/sis/htmlgen?HSDB (accessed December, 2013).
Lewis, R. L., Sr. Sax's Dangerous Properties of Industrial Materials, 10th ed.; John Wiley & Sons, Inc.: New York, NY. 2000.
Lide, D. R, ed. CRC Handbook of Chemistry and Physics, 86th edition, CRC Press Taylor & Francis: Boca Raton, FL. 2006.
Llobet, J. M.; Gomez, M.; Domingo, J. L.; et al. Teratology studies of oral aluminum hydroxide, aluminum citrate, and aluminum
hydroxide together with citric acid in rats. Teratology 1990, 42(2):27A (Abstract Only).
NRC (National Research Council). Toxicological Risks of Selected Flame Retardant Chemicals. Subcommittee on Flame-Retardant
Chemicals, National Academy Press: Washington D.C. 2000.
O'Neil, ed. Merck Index, 13th ed.; Merck & Co., Inc.: Whitehouse Station, NJ. 2001.
Pakalin, S.; Cole, T.; Steinkellner, J.; et al. Review on production processes of decabromodiphenyl ether (DECABDE) used in
polymeric applications in electrical and electronic equipment, and assessment of the availability of potential alternatives to
DECABDE. [Online] January 2007. http://ecb.irc.ec.europa.eu/documents/Existing-
Chemicals/Review on production process of decaBDE.pdf (accessed on January 20, 2011).
TSCATS (Toxic Substance Control Act Test Submission Database). 1996.
4-67
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Thorne, B.M.; Cook, A.; Donohoe, T.; et al. Aluminum toxicity and behavior in the weanling Long-Evans rat. BullPyschon Soc.
1987. 25:129-132.
Thorne, B.M.; Donohoe, T.; Lin, K-N., et al. Aluminum ingestion and behavior in the Long-Evans rat. Physiol Behav. 1986. 36(1):63-
67.
4-68
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Ammonium Polyphosphate
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Ammonium Polyphosphate
68333-79-9
L
L
L
L
L
L
Ld
L
VL
L
L
L
VH
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants that
may partition to sediment and particulates.
4-69
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Ammonium Polyphosphate
HO'
0
-P.
1
o
nh4+
0"1
o
/P—OH
n I
OH
CASRN: 68333-79-9
MW: -100,000
MF: (NH4)k-H(n+2_k)PnO(3n+i)(NAS,
2000)
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: This polymer inorganic salt with MW >1,000 and no low MW components is not amenable to SMILES notation.
Synonyms: Polyphosphoric acids, ammonium salts; APPII; AP 422; AP 462; APP (fireproofing agent); APP 422; Albaplas AP 95; Amgard CL; Amgard MC;
Amgard TR; Ammonium polyphosphate; Ammonium polyphosphates; Antiblaze MC; Antiblaze MCM; Budit 3076; Budit 3076DC; Budit 3077; Budit 365; DFP-I;
EINECS 269- 789-9; Exolit 462; Exolit 263; Exolit 422; Exolit 442; Exolit 454; Exolit 455; Exolit 462; Exolit 470; Exolit AP 422; Exolit AP 423; Exolit AP 462; FR-
Cros 480; FR-Cros 484; Fire-Trol LCG-R; Flameguard PT 8; Hostaflam 423; Hostaflam AP 420; Hostaflam AP 422; Hostaflam AP 462; Hostaflam AP 464;
Hostaflam TP-AP 751; Hostaflam TP-AP 752; Novawhite; Phos-Chek P 30; Phos-Chek P 40; Phos-Chek P 60; Poly-N 10-34-0; Poly-N 11-37-0; Polymetaphosphoric
acid, ammonium salt; Polyphosphoric acid, ammonium salt; Sumisafe; Taien A; Taien H
Chemical Considerations: High-MW ammonium polyphosphate (n>50) with a minimum of water-soluble fractions are being used to an increasing extent in flame
retardants (Gard, 2005, Schrodter et al., 2005). These insoluble ammonium polyphosphates are long chain, ionic phosphate polymers with the following MF:
(NH4)k-H(n+2 -k)PnO(3n+i) where n typically can range from 70 (Wanjie International Co., 2007) to >1,000 (PINFA, 2010) and k represents the degree of replacement of
hydrogen ions with ammonium ions. MWs can be as high as 100,000 g/mole and oligomers with a MW <1,000 are not expected. The high MW inorganic polymer
was assessed as a non-bioavailable material. Prior assessments for similar polyphosphates evaluated the lower, water soluble moieties, which also have application as
a flame retardant.
Polymeric: Yes
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: Ammonia; phosphate (Leisewitz et al., 2000)
Analog: No analogs
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: Not applicable
Risk Phrases: Not classified by Annex I Directive 67/548/European Economic Community & IUCLID (Pakalin et al., 2007).
Hazard and Risk Assessments: The Maine Department of Environmental Protection (MDEP) Safer Alternative Assessment for Decabromodiphenyl Ether Flame
Retardant in Plastic Pallets includes a Green Screen Assessment of Ammonium Polyphosphate (MDEP, 2007) although this was performed on lower MW materials.
4-70
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
Decomposes at > 275°C (Measured)
IUCLID, 2000
Consistent with values reported in
other secondary sources.
Decomposes at 300°C for long chain
ammonium polyphosphate (Measured)
OECD SIDS, 2007
Consistent with values reported in
other secondary sources.
Decomposes at approx. 150°C for short
chain ammonium polyphosphate
(Measured)
OECD SIDS, 2007
Reported for the low MW
ammonium polyphosphate.
Boiling Point (°C)
>275, decomposition with evolution of
ammonia and phosphoric acid (Measured)
Clariant, 2011
Reported in chemical datasheet,
consistent with the high melting
point expected for this chemical.
Vapor Pressure (mm Hg)
<10"8 at 25°C (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value for large high MW
polymers.
<0.75 at 20°C
reported as < 1 hPa (Measured)
IUCLID, 2000; OECD SIDS,
2007
Ammonium polyphosphate will have
negligible vapor pressure as an
inorganic salt. Any measurable vapor
pressure is due to decomposition and
the release of ammonia gas.
Water Solubility (mg/L)
0.5% (w/w) at 25°C in 10% suspension
(Measured)
Clariant, 2011
Reported in chemical datasheet.
0.5-0.05% max. at 25°C in 10%
suspension (Measured)
Wanjie International Co., 2007
Inadequate. This value likely
represents a dispersion and is not an
indication of the material's true
water solubility.
Log Kow
No data located; polymers with a
MW >1,000 are outside the domain
of the available estimation methods.
Flamm ability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Pyrolysis
No data located.
pH
5.5-7.5 at 25°C in 10% suspension
(Measured)
Clariant, 2011
Measured by chemical supplier. Data
are likely for the formulated material
in water, and would be dependent on
the ammonium/polyphosphate ratios.
pKa
No data located.
4-72
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
Absorption is not expected for any route of exposure. This inorganic polymer moiety is large with a MW
>1,000. Based on professional judgment, it is expected to have limited bioavailability and therefore is not
expected to be readily absorbed, distributed or metabolized in the body.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or
Inhaled
Gastrointestinal absorption of higher
polyphosphates following ingestion is
probably low; they are most likely
hydrolyzed by stomach acids to
phosphate and ammonium ions.
NAS, 2000
Limited study details reported in a
secondary source.
Other
No absorption is expected for all routes
of exposure if insoluble in water
(Estimated)
Professional judgment
Estimated based on
physical/chemical properties and
limited bioavailability.
Acute Mammalian Toxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and
therefore is of low potential for acute mammalian toxicity. This low hazard designation is also supported
by a rat oral median lethal dose (LDS0) of >2,000 mg/kg, a rat dermal LDS0 of >2,000 mg/kg, and a 4-hour
rat median lethal concentration (LCS0) of >5.09 mg/L.
Acute Lethality
Oral
Rat oral LD50 >2,000 mg/kg
UNEP, 2008
Although limited study details were
reported in a secondary source,
results indicated that LD50 values
were greater than the high dosages
tested.
Rat oral LD50 = 4,740 mg/kg
IUCLID, 2000; Clariant, 2009
Although limited study details were
reported in a secondary source,
results indicated that LD50 values
were greater than the high dosages
tested; data for commercial mixture
Exolit 422 (purity not specified).
Rabbit oral LD50 >2,000 mg/kg
UNEP, 2008
Although limited study details were
reported in a secondary source,
results indicated that LD50 values
were greater than the high dosages
tested.
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Dermal
Rat dermal LD50 >5,000 mg/kg
IUCLID, 2000; UNEP, 2008
Although limited study details were
reported in a secondary source,
results indicated that LD50 values
were greater than the high dosages
tested; data for commercial mixture
Exolit 456 (90% ammonium
polyphosphate and 10%
monoammonium phosphate).
Rat dermal LD50 >2,000 mg/kg
UNEP, 2008
Although limited study details were
reported in a secondary source,
results indicated that LD50 values
were greater than the high dosages
tested.
Inhalation
Rat Inhalation 4-hour LC50 >5.09 mg/L
UNEP, 2008
Although limited study details were
reported in a secondary source,
results indicate that LC50 values are
greater than the highest
concentration tested; it is
unspecified if the inhaled substance
is a vapor/gas or dust/mist/fume.
Carcinogenicity
LOW: This polymer is large, with a MW >1,000. It is expected to have few to no residual monomers.
Additionally, crosslinking, swellability, dispersability, reactive functional groups, inhalation potential, and
hindered amine groups are not expected. Therefore, there is low potential for carcinogenicity based on
professional judgment. No data located.
OncoLogic Results
Limited bioavailability expected;
crosslinking swellability, dispersability,
reactive functional groups, inhalation
potential, and hindered amine groups
are not expected.
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff value for large
high MW polymers.
Carcinogenicity (Rat
and Mouse)
Combined Chronic
Toxicity/
Carcinogenicity
Genotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and
therefore has low potential for genotoxicity.
Gene Mutation in vitro
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff value for large
high MW polymers.
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Negative, Ames assay, Salmonella
Typhimurium TA98. TA100, TA1535,
TA1537, TA1538, and E. coli
WP2uvrA; with and without metabolic
activation
ESIS, 2000
Reported in a secondary source,
study details and test conditions
were not provided.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
No data located.
Chromosomal
Aberrations in vivo
No data located.
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
Reproductive Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and
therefore has low potential for reproductive effects based on professional judgment and the polymer
assessment literature. No data located.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff value for large
high MW polymers.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Reproduction and
Fertility Effects
4-75
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Developmental Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and
therefore has low potential for developmental effects based on professional judgment and the polymer
assessment literature. No data located.
Reproduction/
Developmental Toxicity
Screen
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Prenatal Development
Postnatal Development
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Neurotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and
therefore has low potential for neurotoxicity based on professional judgment and the polymer assessment
literature. No data located.
Neurotoxicity
Screening Battery
(Adult)
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Repeated Dose Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability; however,
because the MWn is >10,000, there is the possibility of lung overloading if >5% of the particles are in the
respirable range as a result of dust forming operations. No experimental data located.
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
This polymer MWn is >10,000; There is
uncertain potential for lung effects from
lung overload if respirable particles are
inhaled; Polymers with a MW >10,000
have the potential for irreversible lung
damage as a result of lung overloading.
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Skin Sensitization
LOW: Not a skin sensitizer in guinea pigs.
Skin Sensitization
Not a skin sensitizer, guinea pigs
Safepharm, 1993 (as described
in NAS, 2000)
Reported in chemical data sheet;
adequate study details provided.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
VERY LOW: Mixtures containing primarily ammonium polyphosphate were not irritating to rabbit eyes.
Eye Irritation
Not irritating, rabbits
UNEP, 2008
Reported in secondary source;
study details and test conditions
were not provided; data for
commercial mixture (70%
ammonium polyphosphate and
30% monoammonium phosphate).
Not irritating, rabbits
ESIS, 2000
Reported in a secondary source;
study details and test conditions
were not provided; data for
commercial mixture Exolit 456
(90% ammonium polyphosphate
and 10% monoammonium
phosphate). Study in accordance
with Organisation of Economic
Cooperation and Development
(OECD) 405 guideline.
Dermal Irritation
LOW: Mixtures containing primarily ammonium polyphosphate were not irritating to slightly irritating to
skin of rabbits.
Dermal Irritation
Not irritating, rabbits 4-hour occlusion
UNEP, 2008
Reported in a secondary source;
study details and test conditions
were not provided; data for
commercial mixture (70%
ammonium polyphosphate and
30% monoammonium phosphate).
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Slightly irritating, rabbits; 24-hour
occlusive patch test
ESIS, 2000; IUCLID, 2000
Reported in a secondary source;
study details and test conditions
were not provided; data for
commercial mixture Exolit 422
(purity not specified).
Not irritating
ESIS, 2000; IUCLID, 2000
Reported in a secondary source;
study details and test conditions
were not provided; data for
commercial mixture Exolit 456
(90% ammonium polyphosphate
and 10% monoammonium
phosphate). Study in accordance
with OECD 404 guideline.
Not irritating, rabbits. Very slight
erythema in 2/3 animals 1-hour after
exposure to AMGARD LR4; however,
no skin reaction was observed after 24
and 72 hours.
NAS, 2000
Limited study details reported in a
secondary source. Study was
conducted using AMGARD LR2
(liquid containing test substance,
urea and water) and AMGARD L4
(powder).
Not irritating, rabbits exposed 5 times
(23 hours for each exposure) to fabric
treated with LR2
NAS, 2000
Limited study details reported in a
secondary source. Study was
conducted using AMGARD LR2
(liquid containing test substance,
urea and water).
Not irritating, human volunteers
NAS, 2000
Limited study details reported in a
secondary source. Study was
conducted using AMGARD LR2
(liquid containing test substance,
urea and water).
Endocrine Activity
This polymer is large, with a MW >1,0(
bioavailability and inability to be readi
)0. It is not expected to have endocrine activity due to its poor
y metabolized in the body based on professional judgment.
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Immunotoxicity
This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore has
low potential for immunotoxicity based on professional judgment and the polymer assessment literature.
No data located.
Immune System Effects
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
LOW: Water insoluble polymers with a MW >1,000 that do not contain reactive functional groups and are
comprised of minimal low MW oligomers are estimated to have no effects at saturation (NES). These
polymers have NES because the amount dissolved in water is not anticipated to reach a concentration at
which adverse effects may be expressed. Based on professional judgment, guidance for the assessment of
aquatic toxicity hazard leads to a low potential for hazard for those materials that display NES.
Experimental data are also consistent with this hazard designation.
Fish LC50
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Oncorhvnchus mvkiss 96-hour LCWI
>101 mig/L
(Experimental)
IUCLID, 2000; UNEP, 2008
Inadequate; limited study details
reported in a secondary source and
value is much greater than the
anticipated water solubility.
Danio rerio 96-hour LC50 = 100 -
1,000 mg/L
(Experimental)
Clariant, 2009
Inadequate; limited study details
reported in a secondary source and
value is much greater than the
anticipated water solubility.
Brachydcmio rerio 96-hour LC50
>500 mg/L
(Experimental)
IUCLID, 2000
Guideline study red in a secondary
source with limited study details;
OECD 203. Test substance: Exolit
456 (90% ammonium
polyphosphate and 10% of
ammonium phosphate).
4-79
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Freshwater fish (Oncorhvnchus mykiss)
96-hour LC5n= 123,000- 1,326,000
(ig/L (123 - 1,326 mg/L)
(Experimental)
ECOTOX
Limited study details reported in a
secondary source.
Freshwater fish (Oncorhvnchus
tshcrwytscha) 96-hour LC5n = 685 -
1,195 mg/L
(Experimental)
Buhl and Hamilton, 1998
Limited study details reported in a
secondary source. Study conducted
with Fire-Trol LCG-R (composed
primarily of liquid ammonium
polyphosphate with attapulgite
clay, a corrosion inhibitor and iron
oxide).
Freshwater fish (Oncorhvnchus mykiss)
LC50 = 872 ->10,000 mg/L
(Experimental)
Gaikowski et al., 1996
Limited study details reported in a
secondary source. Study conducted
with Fire-Trol LCG-R (composed
primarily of liquid ammonium
polyphosphate with attapulgite
clay, a corrosion inhibitor and iron
oxide).
Freshwater fish (Oncorhvnchus mykiss)
96-hour LCjn = 1,006,000 - 10,000,000
jig/L (1,006- 10,000 mg/L)
(Experimental)
ECOTOX
Limited study details reported in a
secondary source.
Freshwater fish (Pimephcdes promelas)
96-hour LCjn = 519,000 - 2,317,000
(ig/L (519 - 1,080 mg/L)
(Experimental)
ECOTOX
Limited study details reported in a
secondary source.
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid LCS0
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Hycdella ctztecct 96-hour LC50 = 73
mg/L
(Experimental)
McDonald et al., 1997
Limited study details reported in a
secondary source. Study conducted
with Fire-Trol LCG-R (composed
primarily of liquid ammonium
polyphosphate with attapulgite
clay, a corrosion inhibitor and iron
oxide).
Daphnict magna 48-hour EC5n = 90,890
pg/L (90.89 mg/L)
(Experimental)
ECOTOX
Limited study details provided in a
secondary source.
Daphnia magna 48-hour EC50 =
848,000 - 1,036,000 pg/L (848 - 1,036
mg/L)
(Experimental)
ECOTOX
Limited study details reported in a
secondary source.
Daphnia magna 24-hour EC50 =
1,007,000 - 1,976,000 (1,007 - 1,676
mg/L)
(Experimental)
ECOTOX
Limited study details reported in a
secondary source.
Green Algae ECS0
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Chronic Aquatic Toxicity
LOW: Water insoluble polymers with a MW >1,000 that do not contain reactive functional groups and are
comprised of minimal low MW oligomers are estimated to have NES. These polymers have NES because
the amount dissolved in water is not anticipated to reach a concentration at which adverse effects may be
expressed. Based on professional judgment, guidance for the assessment of aquatic toxicity hazard leads to
a low potential for those materials that display NES.
4-81
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Daphnid ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Green Algae ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
ENVIRONMENTAL FATE
Transport
The estimated negligible water solubility and estimated negligible vapor pressure indicate that this ionic
polymer is anticipated to partition predominantly to soil and sediment. The estimated Henry's Law
Constant of <10"8 atm-m3/mole indicates that it is not expected to volatilize from water to the atmosphere.
The estimated Koc of >30,000 indicates that it is not anticipated to migrate from soil into groundwater and
also has the potential to adsorb to sediment.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value for large high MW
polymers.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
Professional judgment; Boethling
etal., 1997
High MW polymers are expected to
adsorb strongly to soil and sediment.
Level III Fugacity Model
This substance is not amenable to the
model.
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Persistence
VERY HIGH: This polymer is large, with a MW >1,000. It is expected to have negligible water solubility
and poor bioavailability to microorganisms indicating that biodegradation is not expected to be an
important removal process in the environment. Hydrolysis is expected for ammonium polyphosphates,
mainly via end-clipping of a monophosphate unit to form monoammonium phosphate. Hydrolysis rates
increase with increasing chain lengths, but reach a limit when n>50. Qualitative statements from
manufacturers indicate hydrolysis is slow, but increases with prolonged exposure to water and elevated
temperatures. Therefore, hydrolysis is not expected to occur at a rate that would greatly reduce the
polymeric chain. Furthermore, long-chain ammonium polyphosphates produced for flame retardant
applications may be formulated with melamine or other stabilizers that impede hydrolysis. The polymer
does not contain functional groups that would be expected to absorb light at environmentally-relevant
wavelengths. Evaluation of these degradation values suggest a half-life for the polymer is >180 days.
Water
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value for large high MW
polymers.
Volatilization Half-life
for Model River
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Volatilization Half-life
for Model Lake
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Soil
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment
The substance has a MW >1,000 and
is not anticipated to be assimilated by
microbial populations; therefore,
biodegradation is not expected.
The half-life values ranged from 5.2-8.7
days in soil under aerobic conditions for
liquid ammonium polyphosphate. Liquid
ammonium polyphosphate hydrolyzed
faster than solid ammonium
polyphosphate and anaerobic conditions,
caused by subsequent flooding,
accelerated hydrolysis. (Measured)
OECD SIDS, 2007
Not applicable; this non-guideline
study is for the low MW, liquid form
of ammonium polyphosphate.
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Study results: None/not reported
Test method: Field Test
Ammonium polyphosphate breaks down
to ammonia and phosphate rapidly in soil
and sewage sludge. (Measured)
Leisewitz et al., 2000
Not applicable; biodegradation data
is expected for the more soluble low
MW ammonium polyphosphate.
Reported in a secondary source.
Anaerobic
Biodegradation
Recalcitrant (Estimated)
Professional judgment
The substance has a MW >1,000 and
is not anticipated to be assimilated by
microbial populations; therefore,
biodegradation is not expected.
Polyphosphate hydrolyzed faster than
solid ammonium polyphosphate and
anaerobic conditions, caused by flooding,
accelerated hydrolysis. (Measured)
OECD SIDS, 2007
Not applicable; this non-guideline
study is for the liquid form of
ammonium polyphosphate.
Soil Biodegradation w/
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
Not a significant fate process (Estimated)
Professional judgment
This substance is expected to exist
entirely in particulate form in air and
is not anticipated to undergo gas-
phase chemical reactions.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Mill, 2000; Professional judgment
The substance does not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Hydrolysis
Not a significant fate process (Estimated)
Gard, 2005; Wanjie International
Co., 2007; PINFA, 2010; EFRA,
2011; Professional judgment
Hydrolysis is expected, mainly via
end-clipping of a monophosphate
unit to form monoammonium
phosphate. Qualitative statements
from manufacturers indicate
hydrolysis is slow, but increases with
prolonged exposure to water and
elevated temperatures. Hydrolysis is
not expected to occur at a rate that
would greatly reduce the polymeric
chain to a MW <1,000 g/mole.
Chemical hydrolysis of polyphosphates
proceeds slowly in sterile, neutral
solutions at room temperature.
Solubility is pH dependent: at pH > 7 the
substance will completely hydrolyze to
HP042" and at pH 4-7 the substance will
completely hydrolyze to H2P04\
(Measured)
OECD SIDS, 2007
Consistent with values reported in
other secondary sources.
Environmental Half-life
>180 days (Estimated)
Professional judgment
The substance has a MW >1,000 and
is not anticipated to be assimilated by
microorganisms. Therefore,
biodegradation is not expected to be
an important removal process. It is
also not expected to be removed by
other degradative processes under
environmental conditions because of
limited water solubility and limited
partitioning to air.
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Ammonium Polyphosphate CASRN 68333-79-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Bioaccumulation
LOW: This ionic polymer is large, with a MW >1,000. It is expected to have negligible water solubility and
poor bioavailability indicating that it will have low potential for bioaccumulation based on professional
judgment.
Fish BCF
<100 (Estimated)
Professional judgment
The substance has a MW >1,000 and
is not anticipated to be assimilated by
aquatic organisms; therefore,
bioconcentration is not expected.
BAF
No data located.
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-86
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Boethling, Robert S. and Nabholz, J. Vincent "Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act",
pp. 187-234, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs, Hamilton, John D.
and Sutcliffe, Roger (eds.), (1997) Van Nostrand Reinhold.
Buhl KJ and Hamilton SJ (1998) Acute toxicity of fire-retardant and foam-suppressant chemicals to early life stages of Chinook
salmon (Oncorhynchus Tshawytscha). Environmental Toxicology and Chemistry 17(8): 1589-1599.
Clariant. Clariant Additives Exolit AP 422. 2011. Available:
http://www.additives.clariant.com/bu/additives/PDS Additives.nsf/www/DS-OSTS-7SHDAQ?open
Clariant. Exolit AP 422 Safety Data Sheet. 2009. Available:
ec.europa.eu/environment/waste/stakeholders/individual_bus/clariant/att_4a.pdf
Centers for Disease Control and Prevention (CDC). Fourth National Report on Raman Exposure to Environmental Chemicals,
Updated Tables. Department of Health and Human Services. 2011. Available at:
http://www.cdc.gov/exposurereport/pdf/Updated_Tables.pdf as of May 10, 2011.
ECOTOX database. U.S. Environmental Protection Agency, http://cfpub.epa.gov/ecotox/. (Accessed December, 2013).
European Chemical Substances Information System (ESIS). IUCLID Dataset for ammonium polyphosphate. European Commission
Joint Research Centre. 2000. Available: ecb.jrc.ec.europa.eu/iuclid-datasheet/68333799.pdf
European Flame Retardants Association (EFRA). 2011. Flame Retardants Fact Sheet: Ammonium polyphosphate (APP). Available at:
http://www.cefic-efra.com/images/stories/factsheet/6APPFactSheetAB-l OO.pdf. As of March 2, 2011
Gaikowski MP, Hamilton SJ, Buhl KJ, et al. (1996) Acute toxicity of three fire-retardant and two fire-suppressant foam formulations
to the early life stages of rainbow trout (Oncorhynchus Mykiss). Environmental Toxicology and Chemistry 15(8): 1365-1374.
Gard, D.R. Phosphoric Acids and Phosphates. Kirk-Othmer Encyclopedia of Chemical Technology. Wiley-Interscience. 2005.
Published Online: July 15, 2005.
IUCLID (International Uniform Chemical Information Database). Polyphosphoric acids, ammonium salts. CAS No. 68333-79-9.
European Commission -European Chemicals Bureau. 2000.
4-87
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Leisewitz A., Kruse H, Schramm E (2000) Substituting environmentally relevant flame retardants: Assessment fundamentals Volume
1: Results and summary overview.
Maine Department of Environmental Protection (MDEP). Decabromodiphenyl ether flame retardant in plastic pallets. A safer
alternatives assessment. Appendices. Prepared by Pure Strategies, Inc., Gloucester, MA. 2007.
McDonald SF, Hamilton SJ, Buhl KJ, et al. (1997) Acute toxicity of fire-retardant and foam-suppressant chemicals to Hyalella Azteca
(Saussure). Environmental Toxicology and Chemistry 16(7): 1370-1376.
Mill, T. (2000) Photoreactions in Surface Waters. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for
Chemicals, Environmental Health Sciences (355-382). Boca Raton: Lewis Publishers.
NAS (National Academy of Sciences). Toxicological risks of selected flame-retardant chemicals. Subcommittee on Flame-Retardant
Chemicals, Committee on Toxicology, Board on Environmental Studies and Toxicology, National Research Council. 2000. Available:
www, nap. edu/catalog/9841, html.
Pakalin, S.; Cole, T.; Steinkellner, J.; et al. Review on production processes of decabromodiphenyl ether (DECABDE) used in
polymeric applications in electrical and electronic equipment, and assessment of the availability of potential alternatives to
DECABDE. [Online] 2007. Available at:
http://publications.irc.ec.europa.eu/repository/bitstream/l 1111111 l/5259/l/EUR%2022693.pdf as of January 20, 2011.
PINFA. Flame Retardant Fact Sheet. 2010. Available: www.pinfa.eu/uploads/Documents/Exolit AP.pdf
Safepharm Laboratories, Ltd (Safepharm). AMGARD LR4: Magnusson & Kligman Maximization study in the guinea pig. Project
74/162. Derby, UK. 1993.
Schrodter, K.; Bettermann, G.; Staffel, T.; et al. Phosphoric Acid and Phosphates Ullmann's Encyclopedia of Industrial Chemistry.
Wiley-Interscience. 2005. Published Online: July 15, 2005.
United Nations Environmental Programme (UNEP). Screening Information Dataset (SIDS) for ammonium polyphosphate.
Organization for Economic Development (OECD). 2008. http://webnet.oecd.org/Hpv/UI/handler.axd?id=a394f'471-d429-4a3a-a4cc-
556e354363b7
4-88
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Wanjie International Co., Ltd. Product fact sheet for ammonium polyphosphate. 2007. Available at:
http://www.wuzhouchem.com/cataloged/indu/ammonium polyphosphate.htm as of February 16. 2011.
4-89
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Antimony Trioxide
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H =
= High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , [, and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
R Recalcitrant: Substance is comprised of metallic species that will not degrade, but may change oxidation state or undergo complexation processes under enviromnental conditions.
Ongoing studies may result in a change in this endpoint.
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Chemical
CASRN
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Antimony Trioxide1
1309-64-4
L
IV *
M
L
L
L
L
HR
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame
retardants that may partition to sediment and particulates.
1 This compound is included in the ongoing EPA Work Plan evaluation for Antimony Trioxide.
4-90
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Antimony Trioxide
Sb
^Sb
° / ?
O |
.Sb
/
Sb
Representative Structure
CASRN: 1309-64-4
MW: 291.5
MF: Sb203 (Empirical)
Physical Forms:
Neat: Solid
Use: Flame retardant synergist
SMILES: 0=[Sb]0[Sb]=0 (Empirical)
Synonyms: Antimony oxide; Antimony white; Antimony (III) oxide; Antimonious oxide; Antimony sesquioxide; C.I. Pigment White 11; Diantimony trioxide; Patox
C; Thermoguard B; Timonox; Timonox White Star; Flowers of antimony; Exitelite; Senarmonite; Valentinite; Weiss-piessglanz
Chemical Considerations: This alternative is an inorganic compound. In the absence of experimental data, professional judgment using chemical class and structural
considerations were used to complete this hazard profile.
Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: None
Analog: Confidential antimony-containing salts and compounds
Endpoint(s) using analog values: neurological toxicity
Analog Structure: The analogs are confidential and cannot be suitably
represented here.
Structural Alerts: None
Risk Phrases: R40: Limited evidence of a carcinogenic effect (EU RAR, 2008) and H351: Suspected of causing cancer by inhalation (ESIS, 2012).
Hazard and Risk Assessments: Risk assessments completed for antimony trioxide by the European Union in 2008 (EU RAR, 2008) and the Subcommittee on
Flame-Retardant Chemicals (NRC, 2000).
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
656 (Measured)
ICSC, 2005
Adequate; measured in the absence
of oxygen.
655 (Measured)
OECD SIDS, 2008
655 for the mineral valentinite
570 for the mineral senarmontite
(Measured)
Lide, 2008
Boiling Point (°C)
1,425 (Measured)
ICSC, 2005; Lide, 2008; O'Neil,
2011
Adequate; decomposes on heating.
1,550 (Measured)
ATSDR, 1992; ICSC, 2005; OECD
SIDS, 2008
Reported as sublimation
temperature.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; 1999
Cutoff value for compounds that are
anticipated to be non-volatile
1 mm Hg at 574°C (Measured)
Sax, 1979; EU RAR, 2008
Value measured at a nonstandard
temperature. Result consistent with
a vapor pressure below criteria
cutoffs.
Water Solubility (mg/L)
14 at 30°C (Measured)
ICSC, 2005
Water solubility of antimony
trioxide is pH dependent; pH for this
measurement not provided.
20 at pH 5;
30 at pH 9
(Measured)
UBA, 2001
Reported values, which span a
relatively narrow range, are
consistently reported in secondary
sources.
19.7 at pH 5;
25.6 at pH 7;
28.7 at pH 9
Ten grams of the Sb203 was mixed with
100 mL distilled water; agitated for 24
hours at 20°C, filtered an analyzed using
atomic absorption. (Measured)
EU RAR, 2008
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
2.76 at pH 8
100 mg Sb203 in 1-L reconstituted water
after 7 days (Measured)
Canada, 2010; OECD SIDS, 2008
This value, reported in secondary
sources with limited details, is one
order of magnitude (10 times) less
than other reported values listed
above. The difference between these
values (approximately 3 and 30 mg)
has no impact on the other endpoints
in this assessment and may be a
result of a typographical error in
either study or differences in study
methods, analysis, or reporting.
<28.7 (Measured)
ERMA, 2011
Sufficient details were not available
to assess the quality of this study.
Dissolution in water decreases from pH 1
to pH 7. Above pH 7, the solubility
increases rapidly to pH 8, at which point a
new equilibrium is established.
(Measured)
OECD SIDS, 2008
Within multiple studies the data
demonstrate the pH dependency of
antimony trioxide solubility.
Log K0„
No data located; inorganic
compounds are outside the
estimation domain of EPI.
Flammability (Flash Point)
Not combustible (Measured)
ICSC, 2005
Adequate.
Explosivity
Not expected (Estimated)
Professional judgment
No data located; based on its use as
a flame retardant.
Pyrolysis
Not applicable (Estimated)
Professional judgment
Inorganic compounds do not
undergo pyrolysis.
pH
Professional judgment
This substance is not expected to
produce ions that would alter the pH
of the solution in aqueous
conditions.
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
pKa
Not applicable; inorganic
compounds are outside the
estimation domain of SPARC
(2009).
HUMAN HEALTH EFFECTS
Toxicokinetics
Antimony trioxide is expected to have no absorption through skin and has poor absorption through the
lungs and gastrointestinal (GI) tract according to experimental data. Following oral exposure, the majority
of antimony trioxide is excreted in the feces. The compound accumulates in lungs with inhalation exposure
due to slow absorption and clearance.
Dermal Absorption in vitro
A percutaneous study in human skin
showed 0.26% absorption
OECD SIDS, 2008
Reported in a secondary source,
limited study details provided.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal, or
Inhaled
Not absorbed through the skin; poor
absorption through the lung and GI tract
(Estimated by analogy)
Professional judgment
Based on closely related
confidential analogs with similar
structures, functional groups, and
physical/chemical properties.
Absorption in rats orally administered
2% antimony trioxide in the diet was
distributed to the thyroid, GI contents,
spleen, heart, bone, muscle, lungs, liver,
and GI tissue. The highest
concentrations (concentrations not
specified) were found in the whole
blood, thyroid, and bones. The majority
(99%) is excreted in the feces and also in
urine within 7 days post-exposure.
NTP, 2005; OECD SIDS, 2008
Reported in a secondary source,
limited study details provided.
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Six groups of Sprague-Dawley rats were
administered antimony trioxide IP, IV,
or by gavage (100 or 1,000 mg/kg-bw).
Following oral administration, antimony
trioxide had low absorption (0.3% of
100 mg/kg-bw; 0.05% of 1,000 mg/kg-
bw), with a Cmax at 24 hours and slower
elimination from the blood. Antimony
underwent significant distribution to the
tissues with the majority being found in
bone marrow and thyroid, followed by
the ovaries, spleen, liver, lung, heart,
femur, and skin. The majority of
antimony trioxide was excreted in the
feces and also in urine.
ECHA, 2011
Reported in a secondary source.
Occupationally exposed smelter workers
had increased (unspecified) levels of
antimony in blood and urine following
inhalation exposure
NTP, 2005
Reported in a secondary source,
occupational reports, no exposure
or duration details; detected
concentrations not specified.
Antimony has been detected in low
(unspecified) amounts in human breast
milk, placenta, amniotic fluid, umbilical
cord blood, and fetal liver
OECD SIDS, 2008
Reported in a secondary source,
limited study details provided;
detected concentrations not
specified.
Dermal
No data located.
Inhalation
Occupational studies measured elevated
antimony levels in the lungs of smelter
workers both deceased and still living
(retired -20 years) indicating that
antimony accumulates and is retained in
the lungs long after exposure stopped;
measured antimony in the lungs of
deceased smelter workers was 12 times
greater than in the lungs of unexposed
referents
EPA, 2002; NTP, 2005
Reported in a secondary source,
limited study details provided;
detected concentrations not
specified.
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fischer 344 rats (65/sex/group) were
exposed (whole-body) to antimony
trioxide dust at target concentrations of
0, 0.05, 0.5, or 5.0 mg/m3 (duration-
adjusted concentrations: 0, 0.01, 0.09, or
0.80 mg/irf) for 6 hours/day, 5
days/week, for 1 year. The mass median
aerodynamic diameter (MMAD) was 3.7
microns, and sigma g was 1.7 for all
concentrations. Some animals were held
for an additional 1-year recovery period
and interim sacrifices were made at the
end of 6 and 12 months during exposure
as well as the end of the 6- and 12-
month post-exposure recovery time.
EPA, 2002; Newton et al., 1994
The antimony trioxide atmosphere
for treated rats was generated
using fluidizing bed generators;
resulting dust-laden streams were
then delivered into inhalation
chambers.
Lung clearance times were 2.3, 3.6, and
9.5 months for the low, mid-, and high-
concentration groups, exposed animals
retained 10.6, 120, and 1,460
micrograms/g lung tissue in the three
exposure groups, respectively, after 1
year of exposure.
Hamsters were exposed to pure
antimony trioxide (volume median
diameter of 7.0 microns) or dust
containing 1.6% antimony (by weight)
via intratracheal instillation and lung
clearance was determined. The half-life
of elimination from hamster lungs was
20-40 days.
EPA, 2002
Reported in a secondary source,
limited study details provided.
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Acute Mammalian Toxicity
LOW: Antimony trioxide is considered of low acute toxicity for oral, dermal, and inhalation exposure.
Acute Lethality
Oral
No deaths were reported in rats
administered antimony trioxide in food
at <16,714 mg/kg-day
ATSDR, 1992
Reported in a secondary source,
limited study details provided.
Rat oral LD50 >20,000 mg/kg
EU RAR, 2008
Reported in a secondary source
Dermal
Rabbit dermal LD50
>8,300 mg/kg-bw
OECD SIDS, 2008
Reported in a secondary source,
limited study details provided.
Inhalation
Rat 4-hour LC50
>5,200 mg/irf dust (5.2 mg/L)
OECD SIDS, 2008
Reported in a secondary source,
limited study details provided.
Carcinogenicity
MODERATE: There is limited evidence that inhalation of antimony trioxide is carcinogenic in rats. There
was no carcinogenicity following inhalation to antimony trioxide dust in rats for 1 year. Other inhalation
studies reported a potential for lung tumors; however, these studies may be considered unreliable due to
study limitations. A 2 year cancer bioassay is in progress at National Toxicology Program (NTP).
OncoLogic Results
No data located. This inorganic
compound is not amenable to
available estimation methods.
Carcinogenicity (Rat
and Mouse)
No data located.
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Combined Chronic
Toxicity/
Carcinogenicity
Wistar rats (45/sex/group) were exposed
to 45 mg/irf antimony trioxide dust
(duration-adjusted concentration = 94
mg/irf: MMAD = 2.80) or 36-40 mg/irf
antimony ore (duration-adjusted = 7.9
mg/irf: MMAD = 4.78) up to 52 weeks
at 7 hours/day, 5 days/week. Interim
sacrifices were performed at 6, 9, and 12
months (5/sex/group) and the remaining
animals were allowed to recover for 20
weeks.
Slight decreases in body weight, and
slightly raised white and yellow foci
were observed on pleural surfaces in
lung. After 6 months, all animals
developed interstitial fibrosis, alveolar-
wall cell hypertrophy, and hyperplasia,
and cuboidal and columnar cell
metaplasia of the lungs. The affected
area increased in size after 12 months
and the extent of fibrosis increased after
4-5 months recovery.
An increased incidence (27%) of lung
tumors (squamous-cell carcinomas,
bronchoalveolar adenomas,
bronchoalveolar carcinomas, and
scirrhous carcinomas) was observed in
females only, while no lung tumors were
reported for controls.
Groth et al., 1986; EPA, 2002
Reported in a secondary source,
limited study details provided.
Only one concentration was tested.
Study conducted prior to the
implementation of guideline
studies developed from
standardized methodologies. The
chemical substance used in testing
also contained detectable levels of
arsenic, a known human
carcinogen.
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Rats exposed via inhalation to 4.01 mg
antimony/irf as antimony trioxide dust
for 6 hours/day, 5 days/week for 1 year
did not exhibit an increase in the
incidence of lung tumors.
Newton et al. 1994; ATSDR,
1992; EPA, 2002
Reported in a secondary source,
limited study details provided.
Units measured as mg
antimony/irf as antimony trioxide.
Increased incidence of lung tumors was
observed in female rats exposed to 4.2 or
36 mg antimony/irf as antimony trioxide
dust 6 hours/day, 5 days/week, for 1
year.
Watt, 1980, 1983; ATSDR, 1992
Reported in a secondary source,
limited study details provided.
Units measured as mg
antimony/irf as antimony trioxide.
Only female rats were tested.
Study conducted prior to the
implementation of guideline
studies developed from
standardized methodologies.
Genotoxicity
MODERATE: Antimony trioxide does not appear to cause gene mutations in bacteria or mouse lymphoma
cells in vitro. While antimony trioxide caused chromosomal aberrations in B6C3F1 mouse bone marrow,
there were also negative results for chromosomal aberrations and micronuclei in in vivo studies of mice and
rats. Positive results were found in an in vivo inhalation micronucleus assay in B6C3F1 mouse peripheral
blood and bone marrow cells and for chromosomal aberrations in mouse bone marrow following oral
exposure for 21 days but the study had limitations. In vitro induction of sister chromatid exchange (SCE)
occurred in human lymphocytes and Chinese hamster V79 cells. Positive results were also observed in a
cytogenetic assay in human lymphocytes.
Gene Mutation in vitro
Negative in two Ames tests using
Salmonella strains TA1535, TA1537,
TA100, TA98, and E. coli strains
WP2PuvrA and WP2P.
EU RAR, 2008
Reported in a secondary source.
Performed according to
Organisation of Economic
Cooperation and Development
(OECD) Guideline 471 and good
laboratory practice (GLP).
Negative in the mouse lymphoma
L5178Y mutation assay.
EU RAR, 2008
Reported in a secondary source.
Performed according to OECD
Guideline 476 and GLP.
Gene Mutation in vivo
No data located.
4-99
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Chromosomal
Aberrations in vitro
Positive in a cytogenetic assay using
human lymphocytes isolated from two
different donors, with and without
metabolic activation.
EU RAR, 2008
Reported in a secondary source.
Performed according to OECD
Guideline 473 and GLP.
Positive for inducing SCE in human
lymphocytes and V79 Chinese hamster
cells.
EU RAR, 2008
Reported in a secondary source.
Chromosomal
Aberrations in vivo
Positive in micronucleus bone marrow
and peripheral blood assay in B6C3F1
male and female mice, inhalation
exposure.
NTP, 2011
Reported in a secondary source.
Study results are limited because
antimony trioxide appears to have
effects on erythroid colony
development.
Negative for an increase in the incidence
of micronuclei in CD-I mice following
single (5,000 mg/kg) or repeat (400, 667,
or 1,000 mg/kg/day; males only) oral
administration of antimony trioxide
(bone marrow micronucleus assay).
EU RAR, 2008
Reported in a secondary source.
Performed according to OECD
Guideline 474 and GLP). No
lethality reported.
Negative in a chromosomal aberrations
test in mouse bone marrow following
single gavage administration of 400, 667
or 1,000 mg/kg bw to male and female
Swiss albino mice (5/sex/group).
Observations were made 6, 12, 18 and
24 hours post exposure.
EU RAR, 2008
Reported in a secondary source.
Study results are limited because
no positive control was used and is
inadequate for determining hazard
designation.
4-100
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Positive in a chromosomal aberrations
test in mouse bone marrow following
repeated gavage administration of 400,
667 or 1,000 mg/kg bw to male Swiss
albino mice (5/sex/group) daily for 21
days. Observations were made on days
7, 14, and 21. Frequencies of
chromosomal aberrations were
significantly increased in a dose-
dependent manner, but did not show a
duration-dependent association.
EU RAR, 2008
Reported in a secondary source.
Study results are limited because
only male mice were tested,
exposure to the highest dose was
lethal by day 20 of treatment, and
no positive control was used.
Lethality in this study was not
seen in other studies at similar
doses. Due to lethality, no
chromosomal aberrations were
evaluated in the high dose group
on the day 21 observation. The EU
RAR considers these results to be
questionable due to the
unexplained lethality in the high
dose group, and inconsistencies in
reporting.
Negative for chromosome aberrations
and micronuclei in the bone marrow of
male and female Sprague-Dawley rats
(6/group) administered 250, 500, or
1,000 mg/kg bw/day for 21 days. The
mitotic index and percentage of
polychromatic erythrocytes showed no
evidence of bone marrow toxicity.
EU RAR, 2008
Reported in a secondary source.
No lethality reported.
DNA Damage and
Repair
Positive in two Bacillus subtilis Rec
assays using strains HI7 (Rec+) and M45
(Rec).
EU RAR, 2008
Reported in a secondary source.
Negative in a rat liver unscheduled DNA
synthesis study in male Alderly Park
AlPk:ApfSD rats (5/dose) following a
single oral dose of 3,200 or 5,000 mg/kg.
EU RAR, 2008
Performed according to OECD
Guideline 486 and GLP.
Other (Mitotic Gene
Conversion)
No data located.
4-101
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
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DATA QUALITY
Reproductive Effects
MODERATE: Reproductive effects following inhalation exposure to antimony trioxide cannot be ruled out.
A single reproductive study is available reporting a measured LOEC value of 0.21 mg/L antimony trioxide
dust in rats for difficulty conceiving and reduced numbers of offspring however, this study has limitations.
Oral repeated dose studies did not report changes in reproductive organs.
Reproduction/
Developmental Toxicity
Screen
No data located.
Combined Repeated
Dose with
No data located.
Reproduction/
Developmental Toxicity
Screen
Reproduction and
Fertility Effects
Rats exposed to 250 mg antimony
trioxide dust/irf for 4 hours/day
beginning 3-5 days before estrus,
through mating and gestation, until 3-5
days before birth (total 63-78 days) had
difficulty conceiving and delivered
reduced numbers of offspring.
LOAEC = 209 mg/m3 (0.21 mg/L)
ATSDR, 1992; EPA, 2002
Reported in secondary sources; a
NOAEC was not identified. There
is uncertainty as to the lowest
concentration at which effects
might occur. It is possible effects
may occur at lower concentrations.
Only one concentration was tested.
Study conducted prior to the
implementation of guideline
studies developed from
standardized methodologies.
Changes in menstrual cycles,
spontaneous late abortions, and early
interruption of pregnancies were
reported for female workers exposed to
antimony dusts at an antimony
metallurgical plant
ATSDR, 1992; EPA, 2002
Occupational exposures involving
mixed compounds, undefined
control group; reported in a
secondary source, limited study
details provided.
Rat and Mouse, oral (gavage), 4-week
repeated dose study; No effects on
testicular toxicity.
NOAEL = 1,200 mg/kg-day (highest
dose tested)
OECD SIDS, 2008
Reported in a secondary source;
study was not designed as a
reproductive study. It was not
specified if other reproductive
parameters were examined.
4-102
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Wistar rats, male and female, dietary
exposure 84-1,879 mg/kg-day for 90
days. No effects in testes <1,686 mg/kg-
day; No effects in ovaries and uterus
<1,879 mg/kg-day.
NOAEL = 1,686 mg/kg-day (male)
NOAEL = 1,879 mg/kg-day (female)
LOAEL = not identified
OECD SIDS, 2008
Reported in a secondary source,
study details and test conditions
were not provided. Did not
conduct a comprehensive
evaluation of reproductive
parameters, but did examine
reproductive organs. Sources cited
four significant figures in results.
Developmental Effects
LOW: Low potential for developmental effects based on expert judgment. Available data are insufficient to
determine a hazard designation for this endpoint. The highest concentration tested was identified as a
NOAEC (0.0063 mg/L), but a LOAEC was not identified. It is possible that effects could occur at
concentrations that could be designated as Moderate or High potential for hazard if tested at higher
concentrations.
Reproduction/
Developmental Toxicity
Screen
Low potential for developmental effects
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
4-103
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Prenatal Development
Rats (strain not specified; 26
females/group) received 0, 1.5, 3.0, or
6.0 mg/irf antimony trioxide (actual
concentrations delivered: 2.6, 4.4, or 6.3
mg/irf) by nose-only inhalation on
gestation days (GD) 0 through 19 (6
hours/day). Particle size ranged from
1.59 - 1.82 microns.
No mortalities and no treatment-related
effects in the dams were reported for
clinical signs, body weight change, or
food consumption.
No evidence of fetotoxicity was
observed on GD 20 for implantation
rate, fetal sex ratios, fetal body weights
or crown-rump length, or fetal external,
visceral, or skeletal examinations.
Maternal gross examination revealed no
treatment-related effects for clinical
signs, food consumption or body weight
changes; however, histopathologic
examination found increased lung
weight (24%, 31%, and 39% over
controls at 2.6, 4.4, or 6.3 mg/m3,
respectively) at every dose level, with
diffuse accumulation of pigmented
alveolar macrophages, likely due to
phagocytosis and accumulation of
particulate matter of the test substance.
NOAEC developmental = 6.3 mg/irf
(0.0063 mg/L, highest dose tested)
LOAEC developmental = not established
NOAEC maternal = not established
LOAEC maternal = 2.6 mg/irf (0.0026
mg/L)
International Antimony Oxide
Industry Association, 2004
Reported in secondary source; a
LOAEL for developmental
toxicity was not identified in the
study. The highest dose tested did
not result in developmental
effects.
4-104
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Increased incidence of spontaneous
abortions in female workers at an
antimony metallurgy plant.
ATSDR, 1992
Reported in a secondary source,
limited study details provided.
Occupational exposures involving
mixed compounds, undefined
control group.
Postnatal Development
No data located.
Neurotoxicity
LOW: Potential for neurotoxicity based on professional judgment. The experimental LOAEL values (6,544
mg/kg-day) for dogs and rabbits fall into the LOW hazard criteria range.
Neurotoxicity Screening
Battery (Adult)
No data located.
Developmental
Neurotoxicity
No data located.
Other Neurotoxicity
Dogs developed muscle weakness and
difficulty moving the hind limbs when
administered antimony trioxide by
gavage for 32 days.
LOAEL = 6,544 mg/kg-day (only dose
tested)
ATSDR, 1992
Reported in a secondary source,
no study details or test conditions
provided. A NOEL was not
identified. There is uncertainty as
to the lowest dose at which effects
might occur. It is possible effects
may occur at lower doses that
would warrant a moderate or high
hazard designation.
Abnormal gait was observed in rabbits
following a single dermal application
LOAEL= 6,685 mg/kg-day (only dose
tested).
ATSDR, 1992
Reported in a secondary source,
limited study details provided.
This was a lethal dose in the range
finding study. A NOEL was not
identified. There is uncertainty as
to the lowest dose at which effects
might occur. It is possible effects
may occur at lower doses that
would warrant a moderate or high
hazard designation.
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
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DATA QUALITY
Repeated Dose Effects
HIGH: Based on inhalation repeated dose LOAEC values ranging from 0.00092 to 0.045 mg/L dust in
experimental animals. Toxicity following inhalation of antimony trioxide dust is due to impaired lung
clearance and particle overload followed by inflammatory responses and fibrosis. LOAEL values indicate a
low hazard for repeated dose effects following oral administration and toxicokinetic studies indicate that
antimony trioxide is poorly absorbed when administered orally. A 2-year inhalation cancer bioassay in rats
and mice is in progress at NTP.
Several occupational studies examined
mine and smelter workers exposed to
airborne dust concentrations of up to 138
mg/irf antimony trioxide (0.138 mg/L),
and particle size averaging <5 mm,
concentrated in the mid lung region. A
common finding in the subjects
examined was antimony pneumoconiosis
characterized by diffuse, densely
distributed punctuate opacities, having a
round, polygonal or irregular shape, and
averaging <1 mm diameter.
EPA, 2002
Reported in a secondary source;
occupational exposures to airborne
mixtures of antimony trioxide
and/or pentoxide.
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
24 guinea pigs were exposed to 45 4
mg/irf antimony trioxide dust
(approximately 38.1 mg antimony/irf) 2
hours/day, 7 days/week for 2 weeks
followed by 3 hours/day for 8-265 days.
Particle size was assumed to be <1
micron. Necropsy revealed increased
lung weight, interstitial pneumonitis, and
subpleural petechial hemorrhages in
animals exposed for >30 days.
EPA, 2002
Reported in a secondary source,
study details and test conditions
were not provided. Only one
concentration tested. Study
conducted prior to the
implementation of guideline
studies developed from
standardized methodologies.
Increased liver weight, fatty
degeneration, and cloudy swelling of the
liver were noted in animals exposed for
>48 days, and decreased white blood
counts and splenic hypertrophy and
hyperplasia were seen in about 50% of
the exposed animals.
LOAEC = 45.4 mg/m3 (0.045 mg/L)
Inhalation exposure of rats, 6 hours/day,
5 days/week >13 weeks resulted in
proliferation of alveolar macrophages.
LOAEC = 0.92 mg/m3 (0.00092 mg/L)
ATSDR, 1992
Reported in a secondary source,
study details and test conditions
were not provided. Study
conducted prior to the
implementation of guideline
studies developed from
standardized methodologies.
Dogs developed severe diarrhea and
muscle weakness when administered
antimony trioxide by gavage for 32 days.
LOAEL = 6,544 mg/kg/day
ATSDR, 1992
Reported in a secondary source,
study details and test conditions
were not provided.
4-107
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
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DATA QUALITY
Fischer 344 rats (50/sex/group) were
exposed to target concentrations of 0,
0.2, 1.0, 5.0, or 25.0 mg/m3 (actual
concentrations were 0, 0.25, 1.08, 4.92,
or 23.46 mg/irf) for 6 hours/day, 5
days/week, 13 weeks (duration-adjusted
concentrations = 0, 0.05, 0.19, 0.88, or
4.20 mg/ nr. respectively). Interim
sacrifices (5/sex/group) were conducted
at weeks 1, 2, 4, 8, and 13, and some
animals were held an additional 27
weeks for recovery. Complete gross and
histopathological examinations were
conducted on all animals, while
hematology and clinical chemistry
analysis were performed for 5/sex/group
at exposure and recovery weeks 1,2,4,8,
and 13.
Newton et al., 1994; EPA, 2002
Reported in a secondary source.
Body weight in males and females was
reduced at the two highest
concentrations, and mean and absolute
lung weights were increased in both
sexes at the two highest concentrations
during exposure and early part of
recovery. Gross necropsy revealed
discolored lungs and microscopic
examination found particle-laden and
degenerating macrophages, cellular
debris in the lumen of the alveoli,
pneumatocyte hyperplasia, and alveolar
wall thickening, which were still present
at week 27 of recovery.
NOAEL = 1.08 mg/m3 (0.0011 mg/L)
LOAEL = 4.92 mg/m3 (0.0049 mg/L)
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fischer 344 rats (65/sex/group) were
exposed (whole-body) to antimony
trioxide at target concentrations of 0,
0.05, 0.5, or 5.0 mg/m3 (duration-
adjusted concentrations: 0, 0.01, 0.09, or
0.80 mg/ lrf) for 6 hours/day, 5
days/week for 1 year. Some animals
were held for an additional 1 -year
recovery period and interim sacrifices
were made at the end of 6 and 12 months
during exposure as well as the end of the
6- and 12-month post-exposure recovery
time.
Gross and histopathological
examinations were conducted on all
animals and hematology analyses were
performed on subgroups at 12, 18, and
24 months.
Ophthalmoscopic evaluation found an
11, 2, 28 and 32% increased incidence of
cataracts from lowest to highest test
concentration, respectively.
Interstitial inflammation and
granulomatous inflammation were
observed at all concentrations. Statistical
analysis indicated a significant increase
in incidence and severity of these effects
at the high exposure in both sexes.
Pulmonary clearance was decreased by
80% in the high concentration group and
the clearance halftime was increased
from 2 months to 10 months.
LOAEC = 0.05 mg/m3 (0.0005 mg/L)
Newton et al., 1994; EPA, 2002
Reported in a secondary source,
not a guideline study.
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Wistar rats (50 females/group) and
Sinclair S-l miniature pigs (3
females/group) to 0, 1.9, or 5.0 mg/irf
(duration-adjusted concentrations = 0,
0.3, and 0.9 mg/irf. respectively)
antimony trioxide for 6 hours/day, 5
days/week for 1 year. Particle size was
0.44 and 0.40 microns for the low and
high concentrations, respectively.
EPA, 2002
Reported in a secondary source.
Study conducted prior to the
implementation of guideline
studies developed from
standardized methodologies.
Survival, hematology and clinical
chemistry were not affected by exposure
for either species. Lung weights were
increased and pulmonary focal fibrosis,
adenomatous hyperplasia,
multinucleated giant cells, cholesterol
clefts, pneumonocyte hyperplasia, and
pigmented macrophages were observed.
Necropsy revealed pulmonary
discoloration and increased alveolar-
intralveolar macrophages in both
exposure groups, while focal subacute-
chronic interstitial inflammation and
granulomatous inflammation observed in
the high exposure group.
LOAEC = 1.9 mg/m3 (0.0019 mg/L,
lowest concentration tested)
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Wistar rats, male and female, dietary
exposure of 0, 1,000, 5,000, or 20,000
ppm (male: 0, 84, 421, 1,686 mg/kg-day;
female: 0, 97, 494, 1,879 mg/kg-day) for
90 days. In high-dose males: increased
triglycerides, red blood cells, and urine
volume; decreased alkaline phosphatase
activity. In high-dose females: increased
red blood cells, urine volume, serum
cholesterol, and aspartate and alanine
aminotransferase; decreased alkaline
phosphatase activity (mid-dose too) and
urine specific gravity.
NOAEL = 5,000 ppm (494 and 421
mg/kg-day in females and males,
respectively)
LOAEL = 20,000 ppm (1,879 and 1,686
mg/kg-day in females and males,
respectively)
NTP, 2005
Reported in a secondary source.
Male Wistar rats, dietary exposure, 500
or 1,000 mg antimony trioxide/kg-day,
for 24 weeks. Decreased red blood cell
count; increased serum glutamic
oxaloacetic transaminase.
LOAEL = 500 mg/kg-day
NTP, 2005
Reported in a secondary source,
study details and test conditions
were not provided.
Rats (strain and sex not given), dietary
exposure, 670 mg antimony trioxide/kg-
day, for 12 weeks. Decreased weight
gain, spleen weight, and heart weight;
increased lung weight.
LOAEL = 670 mg/kg-day
(only dose tested)
NTP, 2005
Reported in a secondary source,
study details and test conditions
were not provided.
4-111
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Rats (strain and sex not given), dietary
exposure, 420-490 mg antimony
trioxide/kg-day for 24 weeks. Decreased
weight gain, decreased red blood cells,
and cloudy swelling in hepatic cords.
LOAEL = 418 mg/kg-day
ATSDR, 1992; NTP, 2005
Reported in a secondary source,
study details and test conditions
were not provided.
Skin Sensitization
LOW: Antimony trioxide was not sensitizing in guinea pigs.
Skin Sensitization
Not sensitizing to guinea pigs.
OECD SIDS, 2008
Reported in a secondary source,
limited study details provided.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
LOW: Antimony trioxide is mildly irritating to rabbit eyes.
Eye Irritation
Instillation of 34.5-83.6 mg antimony
(as antimony trioxide) into the eyes of
rabbits did not produce irritation.
ATSDR, 1992
Reported in a secondary source,
limited study details provided.
Two studies showed reversible mild eye
irritation in rabbits.
OECD SIDS, 2008
Reported in a secondary source,
limited study details provided.
Dermal Irritation
MODERATE: Antimony trioxide is reported to produce skin irritation in workers.
Dermal Irritation
Human case study reports have indicated
that antimony trioxide may cause
dermatitis on damp skin; irritation
associated with sweat ducts.
OECD SIDS, 2008
Reported in a secondary source,
human case study reports.
Endocrine Activity
No data located.
No data located.
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
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DATA QUALITY
Immunotoxicity
Inhalation exposure to antimony trioxide caused decreased white blood counts and splenic hypertrophy and
hyperplasia in guinea pigs.
Immune System Effects
24 guinea pigs were exposed to 45 4
mg/irf antimony trioxide dust
(approximately 38.1 mg antimony/irf) 2
hours/day, 7 days/week for 2 weeks
followed by 3 hours/day for 8-265 days.
Particle size was assumed to be < 1
micron.
Decreased white blood counts and
splenic hypertrophy and hyperplasia
were seen in about 50% of the exposed
animals.
LOAEC = 45.4 mg/m3 (0.045 mg/L)
EPA, 2002
Reported in a secondary source,
no study details and test conditions
were provided. Only one
concentration tested.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
HIGH: Based on the acute toxicity value of 1.77 mg antimony (Sb)/L in Chlorohydra viridissima. Some
experimental acute toxicity values for fish and daphnia were in the Moderate hazard range, while other
experimental aquatic toxicity values for fish and daphnia exceed the water solubility of the compound.
Studies for algae were inadequate due to study limitations and uncertainties.
Fish LC50
Lepomis macrochirns 96-hour LC50
>530 mg/L (Experimental)
ECOTOX
Inadequate; data exceeds
measured water solubility of
compound; limited data make it
difficult to determine whether the
data refer to antimony ion or
antimony trioxide.
Danio rerio 96-hour LC50 >1,000 mg/L
(Experimental)
IUCLID, 2000
Inadequate; data exceeds
measured water solubility of
compound; limited data make it
difficult to determine whether the
data refer to antimony ion or
antimony trioxide.
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Pimephcdes promelas 96-hour LC50
>80 mg/L (Experimental)
ECOTOX
Inadequate; data exceeds
measured water solubility of
compound; limited data make it
difficult to determine whether the
data refer to antimony ion or
antimony trioxide.
Pimephcdes promelas 96-hour LC50 =
14.4 mg Sb/L (Experimental)
EU RAR, 2008
Reported in a secondary source.
Test substance identified as SbCl3.
Pagrns major (marine) 96-hour LC50 =
6.9 mg Sb/L (Experimental)
EU RAR, 2008
Reported in a secondary source.
Test substance identified as SbCl3;
uncertainties exist regarding test
concentrations and speciation so
this study was not considered
when designating hazard for this
endpoint.
Daphnid LCS0
Daphnia magna 48-hour EC50 =
423 mg/L (Experimental)
ECOTOX
Inadequate; data exceeds
measured water solubility of
compound; limited data make it
difficult to determine whether the
data refer to antimony ion or
antimony trioxide.
Daphnia magna 48-hour EC50
>1,000 mg/L (Experimental)
IUCLID, 2000
Inadequate; data exceeds
measured water solubility of
compound; limited data make it
difficult to determine whether the
data refer to antimony ion or
antimony trioxide.
Daphnia magna 48-hour LC50 = 12.1 mg
Sb/L (Experimental)
EU RAR, 2008
Reported in a secondary source.
Other Aquatic Invertebrates
Chlorohydra viridissima (hydra), 96-
hour LC50 = 1.77 - 1.95 mg Sb/L;
measured filtered (Experimental)
EU RAR, 2008
Reported in a secondary source.
Test substance identified as SbCl3;
reliable study conducted in a
sensitive species.
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green Algae ECS0
Pseiidokirchneriella subcapitata 72-hour
EC50 = 0.73 mg /L (Estimated; based on
chlorophyll A concentration)
ECOTOX
Inadequate; reported in a
secondary source; not a traditional
endpoint for determining hazard
potential; Pseiidokirchneriella
subcapitata is more recently
known as Raphidocelis
subcapitata.
Rctphidocelis subcapitata 72-hour EC50
>36.6 mg Sb/L (growth rate)
NOEC = 2.11 mg Sb/L (Experimental)
EU RAR, 2008
Reported in a secondary source.
Test substance identified as SbCl3.
Raphidocelis subcapitata 72-hour EC50
>2.4 mg Sb/L (growth rate)
There was a 3% inhibition of growth rate
at the limit concentration (2.4 mg/L)
NOEC = 0.396 mg Sb/L
LOEC = 1.32 mg Sb/L
(Experimental)
EU RAR, 2008
Reported in a secondary source.
Test substance identified as
Sb203; uncertainties exist
regarding the concentration
response since the limit
concentration resulted in only a
3% inhibition of growth rate
which is considered the most
sensitive endpoint; it is unclear
where a significant inhibition of
growth would occur.
Lemma minor 96-hour EC™ >25.5 mg
Sb/L;
NOEC = 12.5 mg Sb/L
LOEC = 25.5 mg Sb/L (reduction in
frond production)
(Experimental)
EU RAR, 2008
Reported in a secondary source.
Test substance identified as SbCl3.
Chronic Aquatic Toxicity
MODERATE: Based on experimental LOECs ranging from 2.31 to 4.50 mg Sb/L in fish and daphnia.
Fish ChV
Pimephales promelas 28-day NOEC =
2.31 mg Sb/L; LOEC 4.50 mg Sb/L
(growth - weight)
(Experimental)
EU RAR, 2008
Reported in a secondary source.
Test substance identified as SbCl3.
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Pimephcdes promelas 28-day NOEC =
1.13 mg Sb/L (growth - length); LOEC
= 2.31 mg Sb/L
(Experimental)
EU RAR, 2008
Reported in a secondary source.
Test substance identified as SbCl3.
Pimephcdes promelas 28-day NOEC
>0.0075 mg Sb/L (growth)
(Experimental)
EU RAR, 2008
Reported in a secondary source.
There were no effects reported at
the highest dose tested. Test
substance identified as Sb203.
Daphnid ChV
Daphnia magna 21-day NOEC =1.74
mg Sb/L; LOEC = 3.13 mg Sb/L
(Experimental)
EU RAR, 2008
Reported in a secondary source.
Test substance identified as SbCl3.
Daphnia ChV = 3.8 mg/L
(Estimated)
EPI; Professional judgment
Based on SARs (not
computerized) developed for
confidential antimony salts.
Green Algae ChV
No data located.
Chronic Toxicity to Soil Invertebrates
Folsomia Candida (springtails) in Sb203-
amended soil at measured concentrations
of 90, 322, 999, 2,930, and 10,119 mg
Sb/kg soil dry weight (dw).
Controls of uncontaminated field soil
and an untreated artificial soil were used
and a positive control using the herbicide
Betosip was used.
28-day LC50 and EC50 (reproduction)
>10,119 mg Sb/kg dw
Moser, 2007
Study conducted according to
OECD 207.
NOEC (reproduction) = 999 mg Sb/kg
dw
LOEC (reproduction) = 2,930 mg Sb/kg
dw
(Experimental)
4-116
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL FATE
Transport
The limited mobility observed under experimental conditions and the low vapor pressure indicates that
antimony trioxide is anticipated to partition predominantly to soil and sediment. It will not volatilize from
water. Soil mobility and sediment adsorption tests indicate that antimony trioxide will be immobile in soil,
and therefore will not be expected to migrate into groundwater.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment
Cutoff value for non-volatile
compounds. This inorganic
compound is not amenable to
available estimation methods.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
No significant evidence of mobility in
sand, clay, or sandy and silt loams when
tested at 100 |a,L concentration after 24
hours (Non-TSCA Protocol/Guideline)
(Measured)
EPA, 2006; EPA, 2004
Although not a guideline study, the
data suggest that antimony trioxide
will have a Koc >30,000, the cutoff
value for non-mobile substances.
Level III Fugacity Model
Not all input parameters for this
model were available to run the
estimation software (EPI).
Persistence
HIGH: Antimony trioxide is an inorganic substance containing metallic atoms that are likely to be found in
the environment for more than 180 days after release, resulting in a very high persistence/recalcitrant hazard
designation. Based on water solubility studies under a range of pH values, antimony trioxide is expected to
slowly dissolve resulting in the release of antimony ions and, depending on pH, be oxidized or reduced to
other oxidation states. Additionally, results from a pure culture study using autotrophic bacterium indicate
that antimony may be oxidized by bacteria. Antimony trioxide is not anticipated to undergo hydrolysis under
environmental conditions. Antimony trioxide does not contain functional groups expected to absorb light at
environmentally significant wavelengths, and therefore is not expected to photolyze. No degradation processes
for antimony trioxide under typical environmental conditions were identified.
Water
Aerobic Biodegradation
No data located.
Volatilization Half-life for
Model River
No data located.
Volatilization Half-life for
Model Lake
No data located.
4-117
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Soil
Aerobic Biodegradation
Autotrophic bacteria, Stibiobacter
senarmontii, were grown in a mineral
medium containing antimony trioxide
during a pure culture study. Antimony
trioxide was oxidized at rates of 45.5-51.6
and 13.5-19.3 mg/month for senarmonite
and valentinite, respectively; little
oxidation occurred in the sterile medium.
(Measured)
EPA, 1985
Nonguideline study that
demonstrated that the half-life of
antimony trioxide is anticipated to
be >180 days.
Anaerobic
Biodegradation
No data located.
Soil Biodegradation w/
Product Identification
No data located.
Sediment/Water
Biodegradation
10 and 100 ppm antimony trioxide with
added nutrients were incubated with
natural bottom sediment from Puget
Sound under aerobic or anaerobic
conditions for up to 120 days.
Three organoantimony biotransformation
products were found in solution after 60
days. Two of these were identified as
methylstibonic acid and dimethylstibonic
acid. No determination of rate or
conditions affecting the transformation
was made. However, it was estimated that
much less than 0.1% of the antimony
present was transformed. (Measured)
ATSDR, 1992
Nonguideline study reported in a
secondary source that demonstrated
limited biodegradation.
Air
Atmospheric Half-life
No data located.
4-118
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reactivity
Photolysis
Not a significant fate process (Estimated)
Boethling and Mackay, 2000;
Professional judgment
The substance does not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
Hydrolysis
Reacts with acids producing Sb1
compounds and bases producing
[Sb(OH)4]" (Measured)
UBA, 2001
Although hydrolysis may occur
upon contact with strong acids or
bases, these data do not address the
potential for hydrolysis under
environmental conditions.
Environmental Half-Life
>180 days (Estimated)
Professional judgment
Antimony trioxide is an inorganic
compound. Antimony ions, oxides,
or hydroxides are expected to be
found in the environment >180 days
after release.
Bioaccumulation
LOW: Antimony trioxide is an inorganic compound and is not expected to bioaccumulate.
Fish BCF
<100 (Estimated)
Professional judgment
Antimony trioxide is an inorganic
compound and is not anticipated to
bioaccumulate or bioconcentrate.
This inorganic compound is not
amenable to available quantitative
structure activity relationship
models.
No reliable bioaccumulation or
bioconcentration studies located.
OECD SIDS, 2008
BAF
<100 (Estimated)
Professional judgment
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
Antimony trioxide has been detected in dust samples collected downwind from a copper smelting plant in
Washington state (Crecelius et al., 1975, as described in EPA, 1985). Antimony is thought to oxidize to antimony
trioxide in combustion and incineration processes (EU RAR, 2008). Antimony trioxide is found naturally occurring
in ores such as senarmonite, valentinite and exitelite (Canada, 2010).
Ecological Biomonitoring
No data located.
4-119
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Antimony Trioxide CASRN 1309-64-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Human Biomonitoring
Women working in an antimony metallurgical plant, exposed to unspecified amounts of antimony trioxide, metallic
antimony, and antimony pentasulfides were compared with a similar group of women not exposed to antimony. The
plant workers had ten times the antimony concentration in their blood compared to controls; additional sampling was
performed on urine, breast milk, placental tissue, amniotic fluid and umbilical cord blood samples (EPA, 1985). This
chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report (CDC,
2011). Additionally, it was reported that antimony has been found in fetal liver as well as in human breast milk,
placenta, amniotic fluid and umbilical cord blood (EU RAR, 2008).
4-120
-------
ATSDR (Agency for Toxic Substances and Disease Registry). Toxicological profile for antimony and compounds. 1992.
Boethling, R.; McKay, D. Handbook of Property Estimation Methods for Chemicals, Environmental Health Sciences. Boca Raton:
Lewis Publishers. 2000.
Canada. Environment Canada Health Canada Screening Assessment for the Challenge for Antimony trioxide. 2010.
http://www.ec.gc.ca/ese-ees/9889ABB5-3396-435B-8428-F270074EA2A7/batch9 1309-64-4 en.pdf (accessed on May 16, 2011).
Crecelius E.; Bothner, M.; Carpenter, R. Geochemistries of arsenic, antimony, mercury, and related elements in sediments of Puget
Sound. Environ. Sci. Technol. 1975, 9(4):325-33.
CDC (Centers for Disease Control and Prevention). Fourth National Report on Human Exposure to Environmental Chemicals,
Updated Tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf as of
May 10, 2011.
ECOTOX database. U.S. Environmental Protection Agency, http://cfpub.epa.gov/ecotox/. (Accessed May 16, 2011).
ECHA (European Chemicals Agency). 2011. http://apps.echa.europa.eu/registered/registered-sub.aspx#search.
EPA. Health and environmental effects profile for antimony oxides. 1985. EPA 600/x-85/271
EPA. TSCA Section 4 Chemicals; Antimony Compounds, http://www.epa.gov/oppt/chemtest/pubs/antim.pdf. 2006.
EPA (Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing Data.
U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
EPA. IRIS (Integrated Risk Information System). Toxicological review of antimony trioxide (1309-64-4). 2002.
http://www.epa.gov/iris/subst/0676.htm (accessed on May 16, 2011).
EPA. 2004. The Pollution Prevention (P2) Framework, EPA-748-B-03-001. Office of Pollution Prevention and Toxics 7403M, U.S.
Environmental Protection Agency, Washington, DC. 20460. October 2003 version updated in January 2004. Latest version available
at http://www.epa.gov/opptintr/newchems/pubs/sustainable/p2frame-june05a2.pdf
4-121
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EPI (EPIWIN EPISUITE) Estimation Program Interface for Windows, Version 4.00. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
ERMA (Environmental Risk Management Authority). New Zealand. HSNO Chemical Classification Information Database (Antimony
trioxide). 2011. www.ermanz.govt.nz.
European chemical Substances Information System (ESIS) Classification, Labeling and Packaging of Dangerous Substances Annex
VI to Regulation (EC) No 1272/2008 [Online] available at: http://ecb.irc.ec.europa.eu/esis/index.php?PGM=cla as of January 19,
2012
EU RAR. Draft European Union Risk Assessment Report for Diantimony Trioxide. 2008. http://esis.irc.ec.europa.eu/doc/existing-
chemicals/risk assessment/REPORT/datreport415.pdf as of March 14, 2012.
Groth, D. H.; Stettler, L. E.; Burg, J. R.; Busey, W. M.; Grant, G. C.; Wong, L. 1986. Carcinogenic effects of antimony trioxide and
antimony ore concentrate in rats. J. Toxicol. Environ. Health 18(4): 607-626.
IUCLID (International Uniform Chemical Information Database). Dataset for diantimony trioxide. European Commission - European
Chemicals Bureau. 2000
ICSC. IPCS INCHEM. Antimony trioxide. http://www.inchem.org/documents/icsc/icsc/eics0012.htm. 2005.
International Antimony Oxide Industry Association. TSCA Section 8(e) Notification on Antimony Oxide (CAS No. 1309-64-4). Doc.
No. 8EHQ-04-15523. Received by U.S. EPA OPPT Feb. 4, 2004. Lide, D. R., ed. CRC Handbook of Chemistry and Physics, 88th
edition, CRC Press: Boca Raton. 2008.
Moser, T. (2007). Acute and reproduction toxicity of antimony trioxide aged residues in contaminated soil according to the
International Standard ISO 11267 (1999) "Soil Quality - Inhibition of reproduction of Collembola (Folsomia Candida) by soil
pollutants". International Antimony Association, Brussels, Belgium.
Newton P.; Bolte H.; Daly I.; et al. Subchronic and chronic inhalation toxicity of antimony trioxide in the rat. Fundam. Appl. Toxicol.
1994. 22:561-576.
4-122
-------
NRC (National Research Council). Subcommittee on Flame-Retardant Chemicals; Toxicological risks of selectedflame retcirdcmt
chemicals. Washington D.C.: National Academy Press 2000.
NTP (National Toxicology Program). Antimony Trioxide. Brief review of toxicological literature. 2005.
NTP (National Toxicology Program). Database search application; micronucleus: study summary. [Online] Available online at:
http://ntp-
apps.niehs.nih.gov/ntp tox/index.cfm?current%5Fstrain%5Fid=B6C3Fl&activetab=summary&endpointlist=MN&fuseaction=micron
ucleus%2EmicronucleusData&cas%5Fno=1309%2D64%2D4&studv%5Fno=G10676B as of May 16, 2011.
OECD SIDS (Organisation of Economic Cooperation and Development Screening Information Dataset) 2008. Initial Assessment
Profile. http://webnet.oecd.org/Hpv/UI/handler.axd?id=13e93c97-6605-4eac-961f-8af23cc6ad32 (accessed on May 16, 2011).
O'Neil, M.; Heckelman, P.E.; Koch, C.B.; et al. eds. e-Merck Index. 14th ed. Basic Search. Whitehouse Station, NJ: Merck & Co.,
Inc. 2011. https://themerckindex.cambridgesoft.com/TheMerckIndex/index.asp (accessed on May 16, 2011).
Sax, N.I. Dangerous properties of industrial materials. 5th ed. New York: Van Nostrand Rheinhold, 1979.
SPARC. SPARC On Line Calculator pKaproperty server. Ver 4.5 September, 2009. Available from,
http://ibmlc2.chem.uga.edu/spare/ (accessed on March 14, 2012).
UBA (Umweltbundesamt). Substituting Environmentally Relevant Flame Retardants: Assessment Fundamentals. Results and
summary overview. Environmental Research of the Federal Ministry of the Environment, Nature Conservation and Nuclear Industry.
Berlin, 2001.
Watt, W.D. 1980. Chronic inhalation toxicity of antimony trioxide: Validation of the T.L.V.-progress report-summary of results.
OTS206195.
Watt, W. D. 1983. Chronic inhalation toxicity of antimony trioxide: Validation of the threshold limit value. Wayne State University,
Detroit, Michigan, (as cited in EU RAR, 2008).
4-123
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Bis(hexachlorocyclopentadieno) Cyclooctane
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard I = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , I, and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
§ Based on analogy to experimental data for a structurally similar compound.
Chemical
CASRN
Human Health Effects
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Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-124
-------
Bis(hexachlorocyclopentadieno) Cyclooctane
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Cl
CASRN: 13560-89-9
MW: 653.73
MF: C18H12C112
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: C(=C(C(C1(C1)C1)(C(C2CCC(C(C(=C(C34C1)C1)C1)(C3(C1)C1)C1)C4C5)C5)C1)C1)(C12C1)C1
Synonyms: l,4:7,10-Dimethanodibenzo[a,e]cyclooctene, l,2,3,4,7,8,9,10,13,13,14,14-dodecachloro-l,4,4a,5,6,6a,7,10,10a,l l,12,12a-dodecahydro-; 1,2,3,4,7,8,9,-
10,13,13,14,14-Dodecachloro-1,4,4a, 5,6,6a, 7,10,10a, 11,12,12a-dodechydro-1,4:7,10-dimethanodibenzo [a,e] cyclooctene; 1,4:7,10-
Dimethanodibenzo(a,e)cyclooctene,l,2,3,4,7,8,9,10,13,13,14,14-dodecachloro-l,4,4a,5,6,6a,7,10,10a,ll,12,12a-dodecahydro-; 1,6,7,8,9,14,15,16,17,17,18,18-
Dodecachloropentacyclo(12.2.1.16,9.02,13.05,10)octadeca-7,15-diene; Bis(hexachlorocyclopentadieno)cyclooctane; Dechloran A; Dechlorane 605; Dechlorane Plus;
Dechlorane Plus 1000; Dechlorane Plus 25; Dechlorane Plus 2520; Dechlorane Plus 35; Dechlorane Plus 515;
Dodecachlorododecahydrodimethanodibenzocyclooctane; Dodecachlorododecahydrodimethanodibenzocyclooctene; Dodecachloropenta-cycloctadeca-7,15 diene
Chemical Considerations: This is a discrete organic chemical with a MW below 1,000. EPI v 4.0 was used to estimate physical/chemical and environmental fate
values due to an absence of experimental data. Measured values from experimental studies were incorporated into the estimations.
4-125
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4-126
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
Decomposes at 350°C (Measured)
Occidental Chemical Company,
2009
Material decomposes before melting.
Boiling Point (°C)
Decomposes at 350°C (Measured)
Occidental Chemical Company,
2009
Material decomposes before boiling.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
EPI; EPA, 1999
Cutoff value for non-volatile
compounds according to HPV
assessment guidance.
0.006 at 200°C (Measured)
Occidental Chemical Company,
2009
Value reported at an elevated
temperature.
Water Solubility (mg/L)
4.4xl0"5 (Measured)
Occidental Chemical Company,
2009
Adequate, nonguideline study.
2.49xl0~4 (Measured)
Occidental Chemical Company,
2009
2.07xl0"4 to 5.72xl0"4(Measured)
Chou et al., 1979
Log Kow
11 (Estimated)
EPI; EPA, 1999
Estimated value is greater than the
cutoff value, >10, according to
methodology based on HPV
assessment guidance.
Flammability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
Pyrolysis
No data located.
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize in
environmental conditions.
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize in
environmental conditions.
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
As a neat material, bis(hexachlorocyclopentadieno) cyclooctane is estimated to not be absorbed through the
skin and it is also estimated to have poor skin absorption when in solution. This compound is expected to be
poorly absorbed via the lungs and gastrointestinal tract. Bis(hexachlorocyclopentadieno) cyclooctane is not
easily absorbed in the gastrointestinal tract with 93-98% of an administered dose excreted through the feces
unchanged. Plasma levels peaked at 10 hours after administration; the highest levels of
bis(hexachlorocyclopentadieno) cyclooctane were found in the liver, where metabolism is thought to take
place, and in the ovaries. Bis(hexachlorocyclopentadieno) cyclooctane is excreted slowly if it is absorbed.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal, or
Inhaled
Not absorbed through the skin as the neat
material; poor skin absorption if in
solution; poor absorption from the lung
and gastrointestinal tract
(Estimated)
Professional judgment
Based on closely related
confidential analogs with similar
structures, functional groups, and
physical/chemical properties.
In a toxicokinetic study, most excretion
occurred through the feces unchanged
(93-98%), less than 0.1% was excreted in
urine and 0.004% excreted in expired air;
plasma levels peaked at 10 hours, and
tissue levels did not increase
proportionally with dose; after 4 days,
26% of radiolabeled chemical was
remaining in carcass; the highest levels
were found in the ovaries and liver.
IUCLID, 2003
Guideline study.
Oral
In a toxicokinetic study in rats, very little
of the chemical is absorbed in the gastro-
intestinal tract; 95% of administered
radioactive dose was excreted in the
feces; the small amount of chemical that
did absorb was then excreted slowly;
after absorption, the highest amount was
found in the liver where metabolism
takes place
Chou et al., 1979
Unpublished study, but sufficient
study details reported.
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Acute Mammalian Toxicity
LOW: Based on the acute oral and dermal toxicity values >3,160 mg/kg in rats and >8,000 mg/kg in rabbits,
respectively. Although the acute inhalation study in rats produced no deaths, the LCS0 value of >2.25 mg
dust/L air (highest concentration tested) was not included in the hazard designation because there is
uncertainty regarding the potential for adverse effects between 2.25 and 5 mg/L.
Acute Lethality
Oral
Rat (Sherman-Wistar) oral LD50
>25,000 mg/kg; no mortalities at highest
dose tested (25,000 mg/kg)
Occidental Chemical
Company, 1992
Not specified as a guideline study,
but follows general Organisation of
Economic Cooperation and
Development (OECD) guidelines.
Rat (Sprague-Dawley) oral LD50
>3,160 mg/kg; no mortalities at the
highest dose tested (3,160 mg/kg)
IUCLID, 2003
Not specified as a guideline study
and reported in a secondary source,
but follows general OECD
guidelines.
Dermal
Rabbit dermal LD50 >8,000 mg/kg; no
mortalities at highest dose tested (8,000
mg/kg)
Occidental Chemical
Company, 1992
Not specified as a guideline study,
but follows general OECD
guidelines.
Inhalation
Rat inhalation 1-hour LC50>300 mg
dust/L air; no mortalities at highest dose
tested (300 mg dust /L air)
IUCLID, 2003
Limited study details reported in a
secondary source; not the preferred
4-hour exposure.
Rat inhalation 4-hour LC50 >2.25 mg
dust/L air (2,250 mg/irf): no mortalities
at highest dose tested (2.25 mg dust/L
air)
Occidental Chemical
Company, 1992
Not specified as a guideline study,
but follows general OECD
guidelines.
Carcinogenicity
MODERATE: There is potential for carcinogenicity based on analogy to chlordane and decaBDE, the latter
for expression of adverse effects in longer term studies. No carcinogenicity data regarding exposure to
Bis(hexachlorocyclopentadieno) cyclooctane located.
OncoLogic Results
Not amenable to available
estimation method.
Carcinogenicity (Rat
and Mouse)
There is potential for oncogenicity
(Estimated by analogy)
Professional judgment
Estimated by analogy to chlordane.
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Potential for carcinogenicity; increased
incidence of neoplastic nodules of the
liver in rats; equivocal evidence of
increased incidences of hepatocellular
adenomas or carcinomas and thyroid
gland follicular cell adenomas or
carcinomas in male mice.
(Estimated by analogy)
Professional judgment
Estimated based on the high
potential for bioaccumulation and
by analogy to observations on
decaBDE where adverse effects
were not present in 90-day studies
but were expressed following
chronic exposure in a National
Toxicology Program (NTP) study.
Combined Chronic
Toxicity/
Carcinogenicity
No data located.
Genotoxicity
MODERATE: There is estimated to be an uncertain potential for mutagenicity based on analogy to
chlordane. Bis(hexachlorocyclopentadieno) cyclooctane did not cause mutations in bacterial cells or
mammalian cells in vitro. A moderate hazard designation is assigned because of the uncertain potential for
genotoxicity based on chlordane and because there were no data located regarding the potential for
bis(hexachlorocyclopentadieno) cyclooctane to cause chromosomal aberrations.
Gene Mutation in vitro
Uncertain potential for mutagenicity
(Estimated by analogy)
Professional judgment
Estimated by analogy to chlordane.
Negative, Ames assay in Salmonella
typhimurium strains TA98, TA100,
TA1535, TA1537, TA1538 with and
without metabolic activation.
IUCLID, 2003
Not specified as a guideline study
and reported in a secondary source,
but follows general OECD
guidelines.
Negative, Mouse lymphoma assay in
L5178Y TK +/- cells with and without
metabolic activation.
IUCLID, 2003
Not specified as a guideline study
and reported in a secondary source,
but follows general OECD
guidelines.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
No data located.
Chromosomal
Aberrations in vivo
No data located.
DNA Damage and
Repair
No data located.
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Other (Mitotic Gene
Conversion)
No data located.
Reproductive Effects
VERY LOW: Bis(hexachlorocyclopentadieno) cyclooctane did not cause reproductive effects at oral doses
as high as 5,000 mg/kg-day in a combined repeated dose/reproduction/developmental toxicity study in rats.
Reproduction/
Developmental Toxicity
Screen
No data located.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No adverse effects were observed in an
oral (gavage) developmental and
reproductive toxicity study in male and
female rats (exposure to males: 21 days
premating, 14 day mating period, and 28
days after completion of mating period;
exposure to females: 21 days premating,
14 days mating, and up to 25 days after
mating [gestation days (GD) 0 - lactation
day (LD) 3]); no effects on reproductive
or fertility indices through LD 4, and no
effects on implantation or fetal indices
through GD 20.
NOEL = 5,000 mg/kg-day (highest dose
tested)
Brock et al., 2010
Guideline study (OECD 422).
Reproduction and
Fertility Effects
No data located.
Developmental Effects
VERY LOW: Bis(hexachlorocyclopentadieno) cyclooctane did not cause developmental effects at oral doses
as high as 5,000 mg/kg-day in a combined repeated dose/reproduction/developmental toxicity study in rats.
Reproduction/
Developmental Toxicity
Screen
No data located.
4-131
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No adverse effects were observed in an
oral (gavage) developmental and
reproductive toxicity study in male and
female rats (exposure to males: 21 days
premating, 14 day mating period, and 28
days after completion of mating period;
exposure to females: 21 days premating,
14 days mating, and up to 25 days after
mating [GD 0-LD 3]); no effects on fetal
development through LD 4, and no
effects on external and visceral
examinations through GD 20.
NOEL = 5,000 mg/kg-day (highest dose
tested)
Brock et al., 2010
Guideline study (OECD 422).
Prenatal Development
No data located.
Postnatal Development
No data located.
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Neurotoxicity
LOW: Bis(hexachlorocyclopentadieno) t
5,000 mg/kg-day in a combined repeatet
yclooctane did not cause neurotoxic effects at oral doses as high as
dose/reproduction/developmental toxicity study in rats.
Neurotoxicity Screening
Battery (Adult)
No adverse effects were observed in a
28-day oral (gavage) study in male and
female rats; no effects observed in
functional observational battery
evaluations (activity/arousal, autonomic,
neuromuscular, physiological, and
sensimotor); a significant lower
frequency of urination was observed in
females exposed to 750 and 5,000 mg/kg-
day, but was not considered biologically
significant; a significant increase in
rearing counts for males exposed to 1,500
mg/kg-day during 20-30-min. trials, but
was considered not to be treatment
related.
NOEL = 5,000 mg/kg-day (highest dose
tested)
Brock et al., 2010
Guideline study (OECD 422).
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Repeated Dose Effects
MODERATE: Bis(hexachlorocyclopentadieno) cyclooctane caused adverse liver and lung effects in rats
following inhalation exposure to 0.64 mg dust/L (lowest concentration tested). No NOAEL was identified in
this study so it is possible that effects could occur at lower concentrations. Bis(hexachlorocyclopentadieno)
cyclooctane did not cause systemic effects at oral doses up to 5,000 mg/kg-day in a 28-day combined
repeated dose/reproduction/developmental toxicity study in rats, in a 90-day dietary exposure study in rats
at concentrations up to 100,000 ppm in the diet, or in a 28-day dermal exposure study in rabbits at doses up
to 2,000 mg/kg-day.
There is potential for chloracne estimated by analogy to organochlorine pesticides and potential for
systemic effects estimated based on the high potential for bioaccumulation and potential for expression of
adverse effects in longer term studies by analogy to decaBDE.
There is a potential for chloracne.
(Estimated by analogy)
Professional judgment
Estimated by analogy to
organochlorine pesticides.
No adverse effects were observed in a
28-day oral (gavage) study in male and
female rats; no effects on in-life
parameters (clinical signs, food
consumption, body weight), clinical
pathology (hematology, coagulation,
clinical chemistry), or anatomic
pathology (organ weight, abnormalities,
microscopic).
NOEL = 5,000 mg/kg-day (highest dose
tested)
Brock et al., 2010
Guideline study (OECD 422).
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
In a 2 8-day inhalation (dust) study (6
hour/day, 5 days/week) in rats, a
significantly increased absolute liver
weight with hepatocytomegaly of
centrilobular hepatocytes, increased
absolute lung weights, and increased
numbers of macrophages in the alveoli in
both males and females were observed.
There were no effects on body weight,
signs of toxicity, urinalysis, hematology,
clinical chemistry, or gross pathology.
Occidental Chemical
Corporation, 1992
Not specified as a guideline study,
but follows general OECD
guidelines.
LOAEC = 0.64 mg/L (lowest
concentration tested)
In a 90-day oral (dietary) study in rats,
there were no significant treatment-
related effects observed; no effects on
body or organ weights, urinalysis,
clinical chemistry or hematology; there
was a non-significant increased absolute
and relative liver weights that were not
associated with histopathological lesions.
NOAEL = 100,000 ppm (highest dose
tested)
Occidental Chemical
Corporation, 1992
Not specified as a guideline study,
but follows general OECD
guidelines.
4-135
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
In a 28-day dermal exposure (5
day/week, on shaved abraded skin) study
in rabbits, no significant treatment-
related adverse effects were observed. No
effects on body weights, urinalysis,
hematology, clinical chemistry, gross
pathology, or histopathology; a
significant decrease in liver and ovary
weights were reported in female rats,
though there were no associated changes
in absolute organ weights or
histopathological effects.
Occidental Chemical
Corporation, 1992
Not specified as a guideline study,
but follows general OECD
guidelines.
NOAEL = 2,000 mg/kg-day (highest
dose tested)
Potential for repeated dose effects
(Estimated by analogy and
bioaccumulation)
Professional judgment
Estimated based on the high
potential for bioaccumulation and
by analogy to observations on
decaBDE where adverse effects
were not present in 90-day studies
but were expressed following
chronic exposure in a NTP study.
Skin Sensitization
LOW: Bis(hexachlorocyclopentadieno) cyclooctane was not a skin sensitizer in one study of guinea pigs.
Skin Sensitization
Negative for skin sensitization, guinea
pigs
Brett, 1975
Not specified as a guideline study,
but follows general OECD
guidelines (modified Buehler).
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
VERY LOW: Bis(hexachlorocyclopentadieno) cyclooctane is not an eye-irritant in rabbits.
Eye Irritation
Non-irritant, rabbit
Occidental Chemical
Corporation, 1992
Not specified as a guideline study,
but follows general OECD
guidelines.
Dermal Irritation
LOW: Estimated not to cause dermal irritation based on expert judgment.
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Dermal Irritation
Low potential for dermal irritation.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Endocrine Activity
No data located.
No data located.
Immunotoxicity
No potential immunotoxic effects identified by expert judgment.
Immune System Effects
No data located.
ECOTOXICITY
ECOSAR Class
Vinyl/allyl halides
Acute Toxicity
LOW: Estimated data suggest no effects at saturation (NES) for the acute aquatic toxicity endpoints;
experimental study details provided are insufficient to assess the hazard of acute aquatic toxicity, but are
consistent with this hazard call.
Fish LC50
Lepomis macrochims (bluegill) 96-hour
TL50 >100 mg/L - highest dose tested
(flow-through conditions) (Experimental)
IUCLID, 2003
Sufficient details were not available
to assess the quality of this study
(non-good laboratory practice
(GLP), study was given a Klimish
code of 3 - invalid).
Lepomis macrochims (bluegill) 96-hour
TL50 >100 mg/L - highest dose tested
(static conditions) (Experimental)
IUCLID, 2003
Sufficient details were not available
to assess the quality of this study
(non-GLP, study was given a
Klimish code of 3 - invalid).
Fish 96-hour LC50 = 1.89xl0"6 mg/L
(Estimated)
ECOSAR: Vinyl/allyl halides
ECOSAR version 1.11
NES: The log Kow of 11 for this
chemical exceeds the structure
activity relationship (SAR)
limitation for log K0„ of 5.0; NES
are predicted for these endpoints.
4-137
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish 96-hour LC50 = 7.2xl0"6 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 5.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Daphnid LCS0
Daphnid 96-hour LC50 = 2.07x10 s mg/L
(Estimated)
ECOSAR: Vinyl/allyl halides
ECOSAR version 1.11
NES: The log Kow of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 5.0; NES
are predicted for these endpoints.
Daphnid 96-hour LC50 = 1.27xl0"5 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 11 for this
chemical exceeds the SAR
limitation for log Kow of 5.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Green Algae Green Algae ECS0
Green algae 96-hour EC50 =
5.4xl0"6 mg/L
(Estimated)
ECOSAR: Vinyl/allyl halides
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 6.4; NES
are predicted for these endpoints.
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae 96-hour EC5o =
0.00025 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 6.4; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Chronic Aquatic Toxicity
LOW: Estimated data suggest NES for chronic aquatic toxicity endpoints.
Fish ChV
Fish 30-day ChV = 1.31x10 s mg/L
(Estimated)
ECOSAR: Vinyl/allyl halides
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log Kow of 8.0; NES
are predicted for these endpoints.
Fish 30-day ChV = 5.57xl0"7 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log Kow of 8.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
4-139
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid ChV
Daphnid ChV = 6.06xl0"6 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Green Algae ChV
Green algae ChV = 6.52xl0"5 mg/L
(Estimated)
ECOSAR: Vinyl/allyl halides
ECOSAR version 1.11
Chemical may not be soluble
enough to measure this predicted
effect; the toxicity value was
determined from a predicted SAR
using established acute to chronic
ratios (ACRs) and ECOSAR
regression techniques; NES: the log
Kow of 11 for this chemical exceeds
the SAR limitation for log K0„ of
8.0; NES are predicted for these
endpoints.
4-140
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae ChV = 0.00049 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Chemical may not be soluble
enough to measure this predicted
effect; the toxicity value was
determined from a predicted SAR
using established ACRs and
ECOSAR regression techniques;
NES: the log K0„ of 11 for this
chemical exceeds the SAR
limitation for log Kow of 8.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
ENVIRONMENTAL FATE
Transport
Based on the Level III fugacity models incorporating the available experimental property data,
bis(hexachlorocyclopentadieno) cyclooctane is expected to partition primarily to soil.
Bis(hexachlorocyclopentadieno) cyclooctane is expected to be immobile in soil based on its estimated Koc.
Estimated volatilization half-lives indicate that it will be slightly volatile from surface water. Volatilization
from dry surface is also not expected based on its estimated vapor pressure. In the atmosphere,
bis(hexachlorocyclopentadieno) cyclooctane is expected to exist solely in the particulate phase, based on its
estimated vapor pressure. Particulates may be removed from air by wet or dry deposition.
4-141
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Henry's Law Constant
(atm-m3/mole)
7.4x 1 ()'' (Estimated)
EPI
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
EPI; EPA, 2004
Cutoff value for non-mobile
compounds.
4,500,000 (Measured)
IUCLID, 2003 (citing from Chou
etal., 1979)
Insufficient details were reported to
assess the quality of this nonguideline
study; however the results are
consistent with other high MW,
highly halogenated compounds.
Level III Fugacity Model
Air <1% (Estimated)
Water = 5%
Soil = 92%
Sediment = 3%
EPI
Persistence
VERY HIGH: The persistence for bis(hexachlorocyclopentadieno) cyclooctane is a result of experimental
degradation studies and estimations based on quantitative structure activity relationships (QSARs). Studies
with aerobic and anaerobic sewage-sludge microorganisms reported no biodegradation in 2-3 to 6 weeks,
respectively. Bis(hexachlorocyclopentadieno) cyclooctane has low water solubility and hydrolysis is not
expected to be an important fate process; the two allylic chlorines capable of hydrolysis are at bridgehead
locations which renders them resistant to displacement. Photolysis is not expected to be an important removal
process with a measured degradation rate of <10% after 168 hours. Compiled, these degradation endpoints
suggest a half-life >180 days. Environmental monitoring data supports a designation of very high persistence.
Bis(hexachlorocyclopentadieno) cyclooctane has been detected in many places, including remote Arctic and
Antarctic locations.
Water
Aerobic Biodegradation
0% degradation after 21 days;
0.001 and 100 mg/L
bis(hexachlorocyclopentadieno)
cyclooctane dilutions made in water
inoculated with 2 mL/L settled sewage-
sludge containing microorganisms
(Measured)
IUCLID, 2003; Occidental
Chemical Company, 2009
Adequate, nonguideline study.
0% after 14 days; not readily
biodegradable (Measured)
IUCLID, 2003; Occidental
Chemical Company, 2009
Adequate, nonguideline study.
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Volatilization Half-life for
Model River
8 days (Estimated)
EPI
Volatilization Half-life for
Model Lake
100 days (Estimated)
EPI
Soil
Aerobic Biodegradation
<1% degradation after 2 weeks;
OECD 301C measuring biochemical
oxygen demand; 100 ppm
bis(hexachlorocyclopentadieno)
cyclooctane with 30 ppm activated sludge
inoculum (Measured)
MITI, 1998
Adequate, guideline study.
Anaerobic
Biodegradation
Not probable (Anaerobic-methanogenic
biodegradation probability model)
(Estimated)
EPI
0% after 2-6 weeks;
Using C-14 labeled
bis(hexachlorocyclopentadieno)
cyclooctane; with anaerobic sewage sludge
inoculum (Measured)
IUCLID, 2003; Occidental
Chemical Company, 2009
Nonguideline study; sufficient details
were not available to assess the
quality of this study.
Soil Biodegradation w/
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
5.6 hours (Estimated)
EPI
Reactivity
Photolysis
Half-life: >24 years (Measured)
Reported as <10% after 168 hours
IUCLID, 2003
Adequate; nonguideline study.
Hydrolysis
Not a significant fate process (Estimated)
Wolfe and Jeffers, 2000;
Professional judgment
The substance does not contain
functional groups that would be
expected to hydrolyze readily under
environmental conditions.
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Bis(hexachlorocyclopentadieno) Cyclooctane CASRN 13560-89-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Environmental Half-life
>180 days (Estimated)
EPI; PBT Profiler
Half-life estimated for the
predominant compartment, as
determined by EPI and the PBT
Profiler methodology.
Bioaccumulation
HIGH: Estimated BAF and available monitoring data suggest very high potential for
bis(hexachlorocyclopentadieno) cyclooctane bioaccumulation.
Fish BCF
23 to 121 (carp) (Measured);
14 to 96 (bluegill) (Measured)
MITI, 1998
Guideline study measured at a water
solubility of 0.0027 mg/L.
1.97 at 96 hours to 7.02 at 48 hours
Lepomis macrochims
(Measured)
IUCLID, 2003
Nonguideline study.
BAF
23,000 (Estimated)
EPI
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
Bis(hexachlorocyclopentadieno) cyclooctane was detected in the particulate phase of air samples at 6 locations in
the Great Lakes region and Lake Erie and Lake Michigan sediment (Hoh et al., 2006); in Japanese industrial zones
along the Pacific coast (Kubota, 1979); in Ottawa, Canada residential indoor dust samples (Zhu et al., 2007; Dodson,
2012); in indoor dust collected from an e-waste recycling area and two control areas (rural and urban) in South
China (Zheng et al., 2010); and in atmosphere and seawater samples taken from East Greenland Sea and the
northern and southern Atlantic, toward Antarctica (Moller et al., 2010, 2011).
Ecological Biomonitoring
Bis(hexachlorocyclopentadieno) cyclooctane has been detected in archived fish (walleye) samples from Lake Erie
(Hoh et al., 2006); Ring-Billed Gulls from Canada (Gentes et al., 2012); fish from Lake Winnipeg and Lake Ontario
food webs; five different fish species in South Korea; and plasma of nestling bald eagles (Sverko et al., 2011 citing
Tomy et al., 2007; Kang et al., 2009 and Venier et al., 2010 ).
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011). Bis(hexachlorocyclopentadieno) cyclooctane was measured in human hair and indoor dust collected
from an e-waste recycling area and two control areas in South China (Zheng et al., 2010); it was detected in serum
samples in Guiyu and Haojiang (Ren et al., 2009) and Laizhou Bay residents (He et al., 2013).
4-144
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Brett, B. Report to Hooker Chemical Corporation. Skin sensitization tests with five samples in albino guinea pigs. Industrial Bio-Test
Laboratories, Inc. TSCATS submission OTS0205956. 1975.
Brock, W.J.; Schroeder, R.R.; McKnight, C.A.; et al. Oral repeat dose and reproductive toxicity of the chlorinated flame retardant
dechlorane plus. Int. J. Toxicol. 2010, 29(6):582-593.
Chou, T.W.; Liu, D.H.; Mabey, W.R.; et al. Metabolism and environmental screening studies on Dechlorane Plus. Hooker Research
Center. TSCATS submission OTS0535793. 1979.
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
May 10, 2011).
Dodson, R. Perovich, L., Covaci, A., et al. After the PBDE Phase-Out: A Broad Suite of Flame Retardants in Repeat House Dust
Samples from California. Environ. Sci. Technol. 2012. Article ASAP
ECOSAR/EPI (EPIWIN EPISUITE) Estimations Progi'ams Interface for Windows, Version 1.11. U.S. Environmental Protection
Agency: Washington D.C. http://www.epa.gov/opptintr/exposure/.
U.S. EPA (Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing
Data. U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
EPA (U.S. Environmental Protection Agency) Sustainable Futures. Using NonCancer Screening within the SFInitiative. U.S.
Environmental Protection Agency: Washington DC. 2011. http://www.epa.gOv/opptintr/sf/pubs/noncan-screen.htm#svstemic
(accessed on February 09, 2011).
EPA. 2004. The Pollution Prevention (P2) Framework, EPA-748-B-03-001. Office of Pollution Prevention and Toxics 7403M, U.S.
Environmental Protection Agency, Washington, DC. 20460. October 2003 version updated in January 2004. Latest version available
at http://www.epa.gov/opptintr/newchems/pubs/sustainable/p2frame-iune05a2.pdf
EPI (EPIWIN/EPISUITE) Estimation Program Interface for Windows, Version 4.0. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
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Gentes, M; Letcher, RJ; Caron-Beaudoin, E; Verreault, J. (2012.) Novel flame retardants in urban-feeding ring-billed gulls from the
St. Lawrence River, Canada. Environ Sci Technol: [Epub ahead of print]
He, S.; Li, M.; Jin, J.; Wang, Y.; Bu, Y.; Xu, M.; Yeng, X.; Liu, A. Concentrations and trends of halogenated flame retardants in the
pooled serum of residents of Laizhou Bay, China. Environ Toxicol Chem. 2013. [Epub ahead of print]
Hoh, E.; Zhu, L.; Hites, R. Dechlorane Plus, a chlorinated flame retardant, in the Great Lakes. Environ. Sci. Technol. 2006, 40:1184-
1189.
IUCLID (International Uniform Chemical Information Database). Dataset for Dechlorane Plus. European Commission - European
Chemicals Bureau. 2003
Kang, J. H.; Kim, J. C.; Chang, Y. S. Dechlorane Plus in fish from urban-industrial rivers. Organohalogen Compd. 2009, 71, 1356-
1359.
Kubota, Y. Experience with the chemical substances control law in Japan. Ecotoxicol. Environ. Saf. 1979, 3:256-268
MITI (Japanese Ministry of International Trade and Industry). Biodegradation and bioaccumulation data of existing chemicals based
on the CSCL Japan. 1998, Compiled under the supervision of Chemical Products Safety Division, Basic Industries Bureau, Ministry
of International Trade & Industry, Japan; Chemicals Inspection & Testing Institute, Japan. Ed.; Japan Chemical Industry Ecology-
Toxicology & Information Center. 1998.
Moller, A.; Xie, Z.; Sturm, R.; et al.; Large-scale distribution of dechlorane plus in air and seawater from the Arctic to Antarctica.
Environ. Sci. Technol. 2010, 44(23):8977-8982.
Moller, A.; Xie, Z.; Cai, M.; et al. Polybrominated diphenyl ethers vs. alternate brominated flame retardants and dechloranes from
East Asia to the Arctic. Environ. Sci. Technol. 2011, 45(16):6793-6799.
Occidental Chemical Corporation. Initial Submission: Letter Submitting Toxiciological Reviews on Dechlorane Plus and 2,5-
Dichlorobenzotrijluoride with attachments. Occidental Chemical Corporation: Wayne, NJ, 1958 (as cited in TSCA Section 8(e))
Substantial Risk Notice. U.S. EPA. 8EHQ-0292-2490). 1992.
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Occidental Chemical Company. Revised test plan and robust summary for Dechlorane Plus. 2009.
http://www.epa.gov/chemrtk/pubs/summaries/dechlorp/cl5635tc.htm (accessed on January 6, 2011).
PBT Profiler Persistent (P), Bioaccumulative (B), and Toxic (T) Chemical (PBT) Profiler. U.S. Environmental Protection Agency:
Washington D.C. www.pbtprofiler.net.
Pakalin, S.; Cole, T.; Steinkellner, J.; et al. Review on production processes of decabromodiphenyl (DECABDE) used in polymeric
applications in electrical and electronic equipment, and assessment of the availability of potential alternatives to DECABDE.
European Chemicals Bureau. 2007. http://ecb.jrc.ec.europa.eu/documents/Existing-
Chemicals/Review_on_production_process_of_decaBDE.pdf (accessed on February 08, 2011).
Ren, G.; Yu, Z.; Ma, S.; et al. Determination of Dechlorane Plus in serum from electronics dismantling workers in south china.
Environ. Sci. Technol. 2009, 43:9453-9457.
Sverko, E.; Tomy, G.T.; Reiner, E.J.; Li, Y-F.; McCarry, B.E.; Arnot, J.A.; Law, R.J. and A. Hites, R.A. Dechlorane Plus and Related
Compounds in the Environment: A Review. Environmental Science & Technology. 2011, 45:5088-5098.
Tomy, G. T.; Pleskach, K.; Ismail, N.; Whittle, D. M.; Helm, P. A.; Sverko, E.; Zaruk, D.; Marvin, C. H. Isomers of Dechlorane Plus
in Lake Winnipeg and Lake Ontario food webs. Environ. Sci. Technol. 2007, 41, 2249-2254.
Venier, M.; Wierda, M.; Bowerman, W.; et al. Flame retardants and organochlorine pollutants in bald eagle plasma from the Great
Lakes region. Chemosphere 2010, 80(10): 1234-1240.
Wolfe, N.; Jeffers, P. (2000) Hydrolysis. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for Chemicals,
Environmental Health Sciences (311-334). Boca Raton: Lewis Publishers.
Zheng, J.; Wang, J.; Luo, X.; et al. Dechlorane Plus in human hair from an e-waste recycling area in South China: Comparison with
dust. Environ. Sci. Technol. 2010, 44:9298-9303.
Zhu J.; Feng Y.; Shoeib M. Detection of Dechlorane Plus in residential indoor dust in the city of Ottawa, Canada. Environ. Sci.
Technol. 2007, 41:7694-7698.
4-147
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Bisphenol A Bis-(diphenyl phosphate), BAPP
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
§ Based on analogy to experimental data for a structurally similar compound.
0 The highest hazard designation of a representative component of the oligomeric mixture with MWs <1,000.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Bisphenol A Bis-(diphenyl phosphate);
BAPP
181028-79-5
L
M
L
L
L
L
L
L
L
L
H
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-148
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BAPP
MW: 693 (n = 1); >1,000 (n = 2)
MF:
C39H3408P2 (n = 1; CASRN 5945-33-5)
CASRN: 181028-79-5
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: cl(C(C)(C)c2ccc(0P(=0)(0c3ccccc3)0c3ccccc3)cc2)ccc(0P(=0)(0c2ccccc2)0c2ccccc2)ccl (n = 1; CASRN 5945-33-5)
Synonyms: Phosphoric trichloride, reaction products with bisphenol A and phenol; Phosphoric acid, isopropylidene di-p-phenylene tetraphenyl ester; 2,2-Bis[4-
[bis(phenoxy)phosphoryloxy]phenyl]propane; 4,4'-(Isopropylidenediphenyl) bis(diphenyl phosphate); Bisphenol A bis(diphenyl phosphate); Bisphenol A tetraphenyl
diphosphate; BADP; BDP; BPADP; Fyrolflex BDP; Phosphoric acid, P,P'-[(l-methylethylidene)di-4,l-phenylene] P,P,P',P'-tetraphenyl ester for 5945-33-5
Chemical Considerations: This alternative is a polymer. The oligomer where n = 1 (also referred to as CASRN 5945-33-5) has a MW <1,000 and is amenable to EPI
v4.0 estimation methods for physical/chemical and environmental fate values in the absence of experimental data. In commerce, CASRN 5945-33-5 is used
interchangeably with 181028-79-5 and both represent in practice a substance that is 80+% BAPP with higher homologues (n=l, 2 or 3). Bisphenol A (CASRN 80-05-
1), triphenyl phosphate (CASRN 115-86-6) and phenol (CASRN 108-95-2) are potential impurities in commercial formulations (NICNAS NA/773, 2000). The higher
MW oligomers that have MWs >1,000 are assessed together using information contained in the literature concerning polymer assessment and professional judgment
(Boethling et al., 1997).
4-149
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Polymeric: Yes
Oligomers: The n = 1 structure comprises 80-85% of the mixture, with the balance primarily made up of higher oligomers (n = 2, 3, 4, etc.). The commercial mixture
contains triphenyl phosphate as an impurity.
Metabolites, Degradates and Transformation Products: None identified. Degradation of BAPP has been demonstrated in experimental studies (Iwami, 1994;
Hogg, 1997; Armstrong and White, 1999); however the degradates have not been identified. Degradation of BAPP by sequential dephosphorylation could produce
phenol (CASRN 108-95-2), diphenyl phosphate (CASRN 838-85-7), and bisphenol A (CASRN 80-05-1). The importance of dephosphorylation relative to possible
competing pathways has not been demonstrated in a published study. Therefore the hazards of the theoretical degradation products were not considered in this hazard
assessment.
Analogs: Confidential compounds
Endpoint(s) using analog values: Developmental effects; neurotoxicity
Analog Structures: No structure provided for confidential compounds.
Structural Alerts: None
Risk Phrases: For CASRN 5945-33-5 R53 - May cause long-term adverse effects in the aquatic environment (ESIS, 2012; under review CLH, 2011).
Hazard and Risk Assessments: Risk assessment completed for BAPP by the National Industrial Chemicals Notification and Assessment Scheme (NICNAS NA/869,
2000; NICNAS NA/773, 2000).
4-150
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
41.3-68.6 (Measured)
Hogg, 1997; NICNAS NA/773,
2000
Results from differential scanning
calorimetry analysis were originally
reported as a boiling point range of
41.3-68.6°C in the NICNAS
document. The melting point range is
likely from a commercial product or
mixture.
7; OECD 102 (Measured)
Chemtura, 2011
Reported for oligomer where n=l
(CASRN 5945-33-5).
Boiling Point (°C)
>201 (decomposes) (Measured)
Hogg, 1997
Reported to decompose without
boiling at temperatures above
201°C.
>240 - 250 (Measured)
Lightbody, 1999
Inadequate; the reported data are for
a commercial mixture.
Decomposes above 350 without boiling;
Organisation of Economic Cooperation
and Development (OECD) 103
(Measured)
Chemtura, 2011
Reported for oligomer where n=l
(CASRN 5945-33-5).
Vapor Pressure (mm Hg)
<9xl0"6at 25 °C (Extrapolated)
Tremain, 1997
Although a definitive value could not
be reported in this study, the test
chemical contained l-3%triphenyl
phosphate and residual phenol,
which may have contributed to
scatter in the data. These results
suggest, however, that the EPI
estimates for this endpoint are
reasonable.
4-151
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
2.1xl0"8 (Estimated, n = 1)
EPI; Boethling et al., 1997
Although the higher MW oligomers
are outside the domain of the
available estimation methods, their
vapor pressures are anticipated to be
below the cutoff values.
2.3xl0"lsat 25°C (Extrapolated)
Tremain, 2000; Boethling et al.,
1997
Inadequate; the data are for the
commercial mixture extrapolated to
25 °C. However, the data are
consistent with a vapor pressure
below the cutoff values for the higher
MW oligomers.
lxlO"6; OECD 104 (Measured)
Chemtura, 2011
Reported for oligomer where n=l
(CASRN 5945-33-5).
Water Solubility (mg/L)
0.389 - 0462 (Measured)
Hogg, 1997
Although the commercial mixture
was likely used as test material, the
reported value provides an upper
boundary for the most soluble
component of the mixture, the
oligomer with n = 1. The experiment
was performed in acidic conditions
(pH 5.5-6) and the purity of the test
chemical was not specified.
<10° (Estimated)
EPI; Boethling et al., 1997
Estimated data based on the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture. Although the
higher MW oligomers are outside the
domain of the available estimation
methods, their water solubility values
are anticipated to be below the cutoff
values.
4-152
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
<2x10"2 (Measured)
Lightbody, 1999
Inadequate; the reported data are for
a commercial mixture.
Log Kow
>6 (Measured)
Iwami, 1995
The commercial mixture was likely
used as test material; cutoff too low
to address endpoints for the hazard
assessment.
>10 (Estimated)
EPI; Boethling et al., 1997
Estimated data based on the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture. Although the
higher MW oligomers are outside the
domain of the available estimation
methods, their Kow values are
anticipated to be above the cutoff
values.
4.0 (n = 1); 5.2 (n = 2) (Measured)
Lightbody, 1999
Inadequate; the reported data are for
a commercial mixture. The results
are more consistent with the
measured value for the triphenyl
phosphate impurity (log Kow=4.59)
than with the BAPP oligomers.
4.5, >4.9; OECD 107 (Measured)
Chemtura, 2011
Reported for oligomer where n=l
(CASRN 5945-33-5).
Flammability (Flash Point)
>300 (Measured)
NICNAS NA/773, 2000
Reported in a secondary source,
study details and test conditions were
not provided.
>360, closed cup (Measured)
NICNAS NA/869, 2000
281; European Economic Community
(EEC) method No A9 (Measured)
Chemtura, 2011
Reported for oligomer where n=l
(CASRN 5945-33-5).
Explosivity
Not explosive; EEC method No A14
(Measured)
Chemtura, 2011
Reported for oligomer where n=l
(CASRN 5945-33-5).
Pyrolysis
No data located.
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
HUMAN HEALTH EFF
ECTS
Toxicokinetics
Based on professional judgment, absorption is not expected for any route
Poor absorption of the low MW fraction in solution can be expected in al
of exposure for the neat material,
routes.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
No absorption is expected for any route
of exposure; poor absorption of low MW
fraction (0% <500, 85% <1,000) in
solution by all routes
(Estimated by analogy)
Professional judgment
Based on closely related
confidential analogs with similar
structures, functional groups, and
physical/chemical properties.
Acute Mammalian Toxicity
LOW: Based on oral and dermal LDS0 values of >2,000 mg/kg in rats for both the commercial mixture and
its predominant component. No data located regarding the acute inhalation hazard.
Acute Lethality
Oral
Rat oral LD50 >2,000 mg/kg
NICNAS NA/869, 2000
Reported in a secondary source.
Study conducted according to
OECD guidelines (OECD 401).
Data are for commercial mixture.
Rat oral LD50 >2,000 mg/kg
NICNAS NA/773, 2000
Reported in a secondary source.
Study conducted according to
EEC/OECD guidelines (OECD
401). Data are for the predominant
component.
Dermal
Rat dermal LD50 >2,000 mg/kg
NICNAS NA/869, 2000
Reported in a secondary source.
Study conducted according to
EEC/OECD guidelines (OECD
402). Data are for commercial
mixture.
4-154
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Rat dermal LD50 >2,000 mg/kg
NICNAS NA/773, 2000
Reported in a secondary source.
Study conducted according to
EEC/OECD guidelines (OECD
402). Data are for the predominant
component.
Inhalation
No data located.
Carcinogenicity
MODERATE: BAPP may have low potential for carcinogenicity based on expert judgment; there were no
structural alerts in the molecule. However, there is uncertainty regarding the carcinogenicity of BAPP due
to the lack of data for this substance. Carcinogenic effects cannot be completely ruled out.
OncoLogic Results
No data located; not amenable to
available estimation methods.
Carcinogenicity (Rat
and Mouse)
Low potential for carcinogenicity.
(Estimated)
Expert judgment
Estimated based on expert
judgment; no data located.
Combined Chronic
Toxicity/
Carcinogenicity
Genotoxicity
LOW: There is uncertain potential for mutagenicity based on experimental studies. Neither the commercial
mixture nor the predominant component induced gene mutations in several in vitro assays in bacteria and
did not induce chromosomal aberrations in Chinese hamster ovary (CHO) or Chinese hamster lung (CHL)
cells in vitro. The commercial mixture did not increase micronucleated polychromatic erythrocytes in
mouse bone marrow cells in vivo.
Gene Mutation in vitro
Negative, Ames assay (standard plate) in
Salmonella typhimiirium strains TA98,
TA100, TA1537, TA1535, and E. coli
WP2uvrA with and without metabolic
activation
NICNAS NA/869, 2000
Sufficient study details were
reported in a secondary source;
used OECD test guidelines (OECD
471 & 472). Data are for
commercial mixture.
Negative, Ames assay (standard plate) in
Salmonella typhimiirium strains TA98,
TA100, TA 1537, TA 1535, and E. coli
WP2uvrA with and without metabolic
activation
NICNAS NA/773, 2000
Sufficient study details were
reported in a secondary source;
used OECD test guidelines (OECD
471 & 472). Data are for the
predominant component.
Gene Mutation in vivo
No data located.
4-155
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Chromosomal
Aberrations in vitro
Uncertain potential for mutagenicity
based on a positive result for
chromosome aberrations in CHL cells
(Estimated by analogy)
Professional judgment
Based on a structurally similar
confidential analog.
Negative, did not produce chromosomal
aberrations in CHO cells with and
without metabolic activation
NICNAS NA/869, 2000
Sufficient study details were
reported in a secondary source;
used OECD test guidelines (OECD
473). Data are for commercial
mixture.
Negative, did not produce chromosomal
aberrations in CHL cells with and
without metabolic activation
NICNAS NA/773, 2000
Sufficient study details were
reported in a secondary source;
used EC/EEC test guidelines (EC
Directives 87/18/EEC and
88/320/EEC). Data are for the
predominant component.
Chromosomal
Aberrations in vivo
Negative; did not increase
micronucleated polychromatic
erythrocytes in bone marrow cells of
mice treated with 2,000 mg/kg at 0 and
24 hours. No mortalities or adverse
effects were observed in treated animals.
NICNAS NA/869, 2000
Sufficient study details were
reported in a secondary source;
used OECD test guidelines (OECD
474). Data are for commercial
mixture.
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
Reproductive Effects
LOW: Estimated to have low potential for reproductive effects based on expert judgment. No data located.
Reproduction/
Developmental Toxicity
Screen
Low potential for reproductive effects.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
4-156
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproduction and
Fertility Effects
Developmental Ef:
ects
LOW: Estimated to have low potential for developmental effects based on a structurally similar
confidential analog. No fetal effects reported. Experimental data located are inadequate to designate a
hazard for this endpoint. Although predicted to have low hazard, there is high uncertainty due to lack of
data related to developmental neurotoxicity.
Reproduction/
Developmental Toxicity
Screen
Oral, developmental study; no fetal
effects reported.
(Estimated by analogy)
Professional judgment
Based on a structurally similar
confidential analog.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
Prenatal Development
14-day developmental study in rats via
oral gavage
NOAEL: 1,000 mg/kg-day
Illinois EPA, 2007; WA
Department of Health, 2006
Insufficient study details reported
in a secondary source. Data are for
commercial mixture.
Postnatal Development
No data located.
4-157
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Neurotoxicity
LOW: Estimated based on analogy to phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and
phenol (BPBP). In one experimental study of BPBP, there were no neurotoxic effects observed at doses up
to 1,000 mg/kg-day following 28-day oral administration of the commercial mixture to rats. This study was
not designed to assess all neurological parameters; however, it supports the estimated Low hazard
designation. Although low hazard is predicted, there is uncertainty due to lack of data on cholinesterase
inhibition which is associated with phosphate esters.
Neurotoxicity Screening
Battery (Adult)
In a 28-day oral (gavage) study of
Sprague-Dawley rats, there were no
treatment-related changes in any of the
parameters measured (body weight gain,
food consumption, clinical signs, organ
weights, clinical chemistry, hematology,
gross necropsy, histopathology). There
were no notable neurotoxicological
abnormalities reported in weekly
evaluations.
>1,000 mg/kg-day (highest dose tested)
NICNAS NA/869, 2000
28-day oral (gavage) study
NOAEL = 1,000 mg/kg
(Estimated by analogy)
Confidential study submitted
for analog and Professional
judgment
Limited study details were reported
for the neurotoxicity endpoint; it is
unclear what neurological
parameters were evaluated; it
appears that this study was not
designed to assess all neurological
parameters; therefore neurotoxicity
cannot be ruled out; used OECD
test guidelines (OECD 407). Data
are for commercial mixture.
Estimated based on analogy to
phosphoric acid, mixed esters with
11.1 '-bisphenyl-4.4'-diol | and
phenol (CASRN 1003300-73-9).
4-158
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Repeated Dose Effects
LOW: There were no treatment-related changes in systemic toxicity parameters measured at doses up to
1,000 mg/kg-day in a 28-day oral study in Sprague-Dawley rats. Although only one species has been
studied, these were comprehensive OECD or EEC guideline studies that found no dose-related effects for
either the commercial mixture or its predominant component.
In a 28-day oral (gavage) study in
Sprague-Dawley rats, there were no
treatment-related changes in any of the
parameters measured (body weight gain,
food consumption, clinical signs,
neurotoxicology parameters, organ
weights, clinical chemistry, hematology,
gross necropsy, histopathology)
NOEL >1,000 mg/kg-day (highest dose
tested)
NICNAS NA/869, 2000
Sufficient study details were
reported; used OECD test
guidelines (OECD 407). Data are
for commercial mixture.
In a 28-day oral (gavage) study in
Sprague-Dawley rats, there were no
treatment-related changes in any of the
parameters measured (clinical signs,
organ weights, clinical chemistry,
hematology, gross necropsy,
histopathology)
NOEL >1,000 mg/kg-day (highest dose
tested)
NICNAS NA/773, 2000
Sufficient study details were
reported; used EEC test guidelines
(EEC Directive 92/69/EEC,
Method B7). Data are for the
predominant component.
Immune System Effects
Low potential for immunotoxicity.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Skin Sensitization
LOW: Commercial mixture and its pre(
guinea pigs.
ominant component were not skin sensitizers in two studies of
Skin Sensitization
Non-sensitizing, guinea pig
NICNAS NA/869, 2000
Conducted according to
EEC/OECD guidelines (OECD
406). Data are for commercial
mixture.
4-159
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Non-sensitizing, guinea pig
NICNAS NA/773, 2000
Conducted according to
EEC/OECD guidelines (OECD
406). Data are for the predominant
component.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
LOW: Commercial mixture was slightly irritating and predominant component was non-irritating to
rabbit eyes.
Eye Irritation
Slightly irritating, rabbit
NICNAS NA/869, 2000
Conducted according to
EEC/OECD guidelines (OECD
405). Data are for commercial
mixture.
Non-irritant, rabbit
NICNAS NA/773, 2000
Conducted according to
EEC/OECD guidelines (OECD
405). Data are for the predominant
component.
Dermal Irritation
LOW: Commercial mixture was slightly irritating and predominant component was non-irritating to
rabbit skin.
Dermal Irritation
Slightly irritating, rabbit
NICNAS NA/869, 2000
Conducted according to
EEC/OECD guidelines (OECD
404). Data are for commercial
mixture.
Non-irritant, rabbit
NICNAS NA/773, 2000
Conducted according to
EEC/OECD guidelines (OECD
404). Data are for the predominant
component.
Endocrine Activity
No experimental data were located to evaluate and determine if BAPP af
ects endocrine activity.
Low potential for endocrine activity.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Immunotoxicity
Estimated to have low potential for immunotoxicity based on expert judgment. No experimental data for
this substance were located.
Immune System Effects
Low potential for immunotoxicity.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
ECOTOXICITY
ECOSAR Class
Acute Toxicity
LOW: Experimental data for both the predominant component (n = 1) and the commercial mixture for
fish, daphnia, and algae indicate no effects up to the limits of the water solubility. Estimates are consistent
with NES.
Fish LC50
Oncorhvnchiis mykiss (rainbow trout),
96-hour LC50 >0.025 mg/L
NOEC = 0.025 mg/L
(Experimental)
NICNAS NA/869, 2000
Conducted according to OECD
guidelines (OECD 203); not toxic
up to the limits of its water
solubility.
Oncorhvnchiis mykiss (rainbow trout),
96-hour LC50 >1 mg/L
NOEC >1 mg/L
(Experimental)
NICNAS NA/773, 2000
Conducted according to OECD
guidelines (OECD 203); not toxic
up to the limits of its water
solubility. Data are for the
predominant component.
Fish 96-hour LC50 = NES
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimated data based on the high
K0„ of the predominant oligomer
component, n = 1, representing
85% of the commercial mixture.
Although the higher MW
oligomers are outside the domain
of the estimation method, they are
also anticipated to display NES.
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid LCS0
Daphnia magna, 48-hour EC50
>0.034 mg/L;
NOEC = 0.034 mg/L
(immobilization)
(Experimental)
NICNAS NA/869, 2000
Conducted according to OECD
guidelines (OECD 202); not toxic
up to the limits of its water
solubility. Data are for commercial
mixture.
Daphnia magna, 48-hour EC5n >1 mg/L;
NOEC >1 mg/L
(immobilization)
(Experimental)
NICNAS NA/773, 2000
Conducted according to OECD
guidelines (OECD 202); not toxic
up to the limits of its water
solubility. Data are for the
predominant component.
Daphnid 48-hour LC50 = NES
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimated data based on the high
Kow of the predominant oligomer
component, n = 1, representing
85% of the commercial mixture.
Although the higher MW
oligomers are outside the domain
of the estimation method, they are
also anticipated to display NES.
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
Green Algae ECS0
Selanastrum subspicatiis 72-hour EbC5o
>0.02 mg/L;
NOEC = 0.02 mg/L
(growth)
(Experimental)
NICNAS NA/869, 2000
Conducted according to OECD
guidelines (OECD 201); not toxic
up to the limits of its water
solubility. Data are for commercial
mixture.
Selanastrum subspicatiis 72-hour EbC50
>1 mg/L;
NOEC >1 mg/L
(growth)
(Experimental)
NICNAS NA/773, 2000
Conducted according to OECD
guidelines (OECD 201); not toxic
up to the limits of its water
solubility. Data are for the
predominant component.
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae 96-hour LC50 = NES
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimated data based on the high
Kow of the predominant oligomer
component, n = 1, representing
85% of the commercial mixture.
Although the higher MW
oligomers are outside the domain
of the estimation method, they are
also anticipated to display NES.
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
Chronic Aquatic Toxicity
LOW: Experimental data for the comm
limits of the water solubility. Estimates
ercial mixture in Daphnia indicate no toxicity effects up to the
'or fish and algae also suggest no effects at saturation (NES).
Fish ChV
Fish ChV = NES
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimated data based on the high
K0„ of the predominant oligomer
component, n = 1, representing
85% of the commercial mixture.
Although the higher MW
oligomers are outside the domain
of the estimation method, they are
also anticipated to display NES.
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
4-163
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid ChV
Daphnia magna, 21-day EC50
>0.02 mg/L;
NOEC = 0.02 mg/L
(reproduction test)
(Experimental)
NICNAS NA/869, 2000
Conducted according to OECD
guidelines (OECD 211); not toxic
up to the limits of its water
solubility. Data are for commercial
mixture.
Daphnia ChV = NES
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimated data based on the high
Kow of the predominant oligomer
component, n = 1, representing
85% of the commercial mixture.
Although the higher MW
oligomers are outside the domain
of the estimation method, they are
also anticipated to display NES.
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
Saltwater Invertebrate ChV
No data located.
Green Algae ChV
Green algae ChV = NES
(Estimated)
ECOSAR neutral organics
ECOSAR version 1.11
Estimated data based on the high
K0„ of the predominant oligomer
component, n = 1, representing
85% of the commercial mixture.
Although the higher MW
oligomers are outside the domain
of the estimation method, they are
also anticipated to display NES.
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
4-164
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL FATE
Transport
The environmental fate is described using estimates on the lowest MW oligomer of BAPP, which is the
predominant component. Based on the Level III fugacity models incorporating the available experimental
property data, the lowest MW oligomer is expected to partition primarily to soil and sediment. BAPP is
expected to be immobile in soil based on its estimated Koc. Leaching of BAPP through soil to groundwater is
not expected to be an important transport mechanism. Estimated volatilization half-lives indicate that BAPP
will be nonvolatile from surface water. Volatilization from dry surface is also not expected based on its vapor
pressure. In the atmosphere, BAPP is expected to exist solely in the particulate phase, based on its estimated
vapor pressure. Particulates may be removed from air by wet or dry deposition. The higher MW components
of the commercial mixture are anticipated to behave similarly to that described above.
Henry's Law Constant
(atm-m3/mole)
Predominant component (5945-33-5):
<10"8 (Estimated)
EPI; Professional judgment
Estimated data based on the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture. The higher MW
oligomers are also expected to have
Henry's Law Constant values below
this cutoff.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>3.39xl04 (Measured)
Hogg, 1997
Data obtained using a high
performance liquid chromatography
(HPLC) method similar to OECD
TGP/94.75 method. Although a
commercial mixture was likely used
as test material, the reported value
provides a lower boundary for the
most mobile component of the
mixture, the oligomer with n = 1.
Predominant component (5945-33-5):
30,000 (Estimated)
EPI
Estimated data based on the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture.
4-165
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Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Level III Fugacity Model
Air = <1% (Estimated)
Water =1.1%
Soil = 42%
Sediment = 57%
EPI
Estimated data based on the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture.
Persistence
HIGH: Experimental studies were on the commercial mixture which is estimated to contain approximately
85% BAPP. BAPP is not readily biodegradable. In a Japanese Ministry of International Trade and
Industry (MITI)-I (OECD Test TG 301C) test 6% biodegradation occurred over 28 days in sewage sludge.
BAPP does not contain chromophores that absorb at wavelengths >290 nm, and therefore is not expected to
be susceptible to direct photolysis by sunlight. The atmospheric half-life of BAPP is estimated to be 5.5 hours,
although it is expected to exist primarily in the particulate phase in air. Enzymatic or basic hydrolysis
leading to the production of phenol (CASRN 108-95-2), diphenyl phosphate (CASRN 838-85-7), and
bisphenol A (CASRN 80-05-1) through sequential dephosphorylation is theoretically possible but has not
been demonstrated.
Water
Aerobic Biodegradation
Days-weeks (Primary survey model)
Months (Ultimate survey model)
(Estimated)
EPI
Estimated data based on the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture.
6% biodegradation detected after 28 days
in activated sludge according to a MITI-I
Ready Test (OECD TG 301C)
(Measured)
Iwami, 1994
The commercial mixture was likely
used as test material.
2% biodegradation detected after 28 days
in sewage sludge according to Ready Test
Modified Sturm Test (OECD TG 301).
(Measured)
Armstrong and White, 1999
The data are for the commercial
mixture.
Volatilization Half-life for
Model River
>1 year (Estimated)
EPI
Estimated data based on the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture.
4-166
-------
Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Volatilization Half-life for
Model Lake
>1 year (Estimated)
EPI
Estimated data based on the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture.
Soil
Aerobic Biodegradation
No data located.
Anaerobic
Biodegradation
Not probable (Anaerobic-methanogenic
biodegradation probability model)
(Estimated)
EPI
Estimated data based on the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture.
Soil Biodegradation with
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
5.5 hours (Estimated)
EPI
Estimated data based on the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Mill, 2000; Professional
judgment
The substance does not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
Hydrolysis
>1 year at 25°C and pH 4.0, 7.0 and 9.0
(Measured)
Hogg, 1997
The commercial mixture was likely
used as test material. Data indicate
the resistance of the material to
hydrolysis under environmental
conditions. Purity of the test
chemical was not specified.
4-167
-------
Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
>1 year at pH 5 and pH 7;
6.3 days at pH 9
15 hours at pH 10 (Estimated)
EPI
Estimated data based on the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture. Hydrolysis
rates are expected to be pH-
dependent and may be limited by the
low water solubility of this
compound. Under basic conditions,
sequential dephosphorylation
reactions may occur.
Environmental Half-Life
>1 year (Estimated)
EPI; PBT Profiler
Half-life estimated for the
predominant compartment, as
determined by EPI and the PBT
Profiler methodology for the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture.
Bioaccumulation
HIGH: Although measured BCF values for the components of the polymeric mixture result in a Moderate
bioaccumulation hazard designation, the overall bioaccumulation designation for BAPP is high based on an
estimated BAF value. The estimated BAF of 1,100 for the predominant component of the mixture with a MW
<1,000 daltons, suggests that BAPP may bioaccumulate in higher trophic levels.
Fish BCF
<100 (Measured)
According to a method equivalent to
OECD 3 05 C in Cyprinus carpio with
HPLC analysis of the n=l, n=2 and n=3
components
BCF range: 6.8 - 62
Submitted confidential study
Although the commercial mixture
was used as the test material, the
BCF for each individual oligomer
was measured.
BCF range: <1.1 - <159
BCF range: 6.8 - 62 (Estimated by
analogy)
Chemtura, 2011
Reported for oligomer where n=l
CASRN 5945-33-5.
4-168
-------
Bisphenol A Bis-(diphenyl phosphate) CASRN 181028-79-5 and 5945-33-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
66 (Estimated)
EPI
Estimated data based on the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture.
BAF
1,100 (Estimated)
EPI
Estimated data based on the
predominant oligomer component,
n = 1, representing 85% of the
commercial mixture.
Metabolism in fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-169
-------
Armstrong, K.; White, D. NcendX P-30 Determination of Ready Biodegradability by Modified Sturm Test. Inveresk Report No. 18,
Inveresk Research. 1999.
Chemtura Corporation. Proposal for Harmonised Classification and Labelling. CLH REPORT FOR EC NO. 425-220-8. 2011.
http://echa.europa.eu/documents/10162/13626/clh 1 -methylethylidene en.pdf.
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
May 10, 2011).
CLH report Proposal for Harmonised Classification and Labelling Substance Name: (1-methylethylidene)di-4,1 -phenylene tetraphenyl
diphosphate; aka Bisphenol A Diphosphate; aka Bisphenol A Polyphosphate. 2011.
http://www.google.com/url?sa=t&rct=i&q=clh%20report%20for%20ec%20no.%20425-220-
8&source=web&cd=l&cad=ria&ved=0CC0OFiAA&url=http%3A%2F%2Fecha.europa.eu%2Fdocuments%2F10162%2F13626%2Fc
lh 1-methylethylidene en.pdf&ei=x3i UP6YPIq8QOHmqIDICO&usg=AFOiCNFXY3wOdSulFtHOm5xqlAHACWcvOA
(accessed on December 5, 20120.
ECOSAR/EPI (EPIWIN EPISUITE) Estimations Programs Interface for Windows, Version 1.11. U.S. Environmental Protection
Agency: Washington D.C. http://www.epa.gov/opptintr/exposure/.
EPA (Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing Data.
U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
EPA. 2004. The Pollution Prevention (P2) Framework, EPA-748-B-03-001. Office of Pollution Prevention and Toxics 7403M, U.S.
Environmental Protection Agency, Washington, DC. 20460. October 2003 version updated in January 2004. Latest version available
at http://www.epa.gov/opptintr/newchems/pubs/sustainable/p2frame-june05a2.pdf
EPI (EPIWIN EPISUITE) Estimation Program Interface for Windows. Version 4.0. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
ESIS (European chemical Substances Information System). Classification, labeling and packaging of dangerous substances annex VI
to regulation (EC) No 1272/2008. [Online] http://esis.irc.ec.europa.eu/index.php?PGM=cla (accessed on April 6, 2012).
4-170
-------
Hogg, A.S. Determination of General Physico-Chemical Properties. Project No. 106/010, Safepharm Laboratories Limited, Derby.
1997
Illinois Environmental Protection Agency. Report on Alternatives to Flame Retardant DecaBDE: Evaluation of Toxicity, Availability,
Affordability, and Fire Safety Issues. A report to the governor and general assembly. 2007.
Iwami, S. Ready Biodegradability TestofE-890. Project No. 4F020G, Mitsubisi-kasei Institute of Environmental Science, Japan.
1994
Iwami, S. Determination of 1-octanol water Partition Coefficient of E-890 by HPLC Method. Project No. Mitsubishi Chemical Safety
Institute Ltd, Japan. 1995.
Lightbody, S.M. Physico-Chemical Testing with NcendXP-30 (BoilingPoint, Water Solubility, Partition Co-efficient,
Adsorption Desorption Co-efficient). Inveresk Report No. 17979, Inveresk Research. 1999.
Mill, T. (2000) Photoreactions in Surface Waters. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for
Chemicals, Environmental Health Sciences (355-382). Boca Raton: Lewis Publishers.
NICNAS NA/773 (National Industrial Chemicals Notification and Assessment Scheme). Phosphoric acid, (1-methylethylidene) di-
4,1-phenylene tetraphenyl ester (FyrolflexBDP). File No. NA/773. 2000.
NICNAS NA/869 (National Industrial Chemicals Notification and Assessment Scheme). Phosphoric Trichloride, Reaction Products
with Bisphenol A and Phenol). File No. NA/869. 2000.
PBT Profiler. Persistent (P), Bioaccumulative (B), and Toxic (T) Chemical (PBT) Profiler. U.S. Environmental Protection Agency:
Washington D.C. www.pbtprofiler.net.
Tremain, S.P. Determination of Vapour Pressure. Project No. 106/012, Safepharm Laboratories Limited, Derby. 1997.
Tremain, S3*. Determination of Vapour Pressure. SPL Project No. 685/013, Safepharm Laboratories Limited. 2000.
4-171
-------
Washington Department of Health. Washington State polybrominated diphenyl ether (PBDE) chemical action plan: Final plan. Deca-
BDE alternatives assessment. Washington State Department of Health. January 19, 2006. Department of Health publication No. 334-
079. 2006.
4-172
-------
Brominated Epoxy Polymers
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard I = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , I, and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations.
~ Different formulations of the commercial product are available. One of these many formulations lias an average MW of-1,600 and contains significant amounts of lower MW
components. These lower MW components have hazard potentials different than the polymeric flame retardant, as follows: HIGH estimated potential for bioaccumulation;
HIGH experimental for acute aquatic toxicity; HIGH estimated for chronic aquatic toxicity; MODERATE experimental for developmental toxicity; and MODERATE
estimated for carcinogenicity, repeated dose, reproductive, and respiratory sensitization toxicity.
Chemical
CASRN
Human Health Effects
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68928-70-1
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Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-173
-------
Brominated Epoxy Polymers
CASRN: 68928-70-1
MW: 10,000 to >50,000; 0% <1,000
MF: (C21H20Br4O4 C15H12Br402)n
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: The polymer component with MW >1,000 is not amenable to SMILES notation.
Synonyms: Phenol, 4,4'-(l-methylethylidene)bis[2,6-dibromo-, polymer with 2,2'-[(l-methylethylidene)bis[(2,6-dibromo-4,l-phenylene)oxymethylene]]bis[oxirane];
4,4'-propane-2,2-diylbis(2,6-dibromophenol) - 2,2'-{propane-2,2-diylbis[(2,6-dibromobenzene-4,l-diyl)oxymethanediyl]}dioxirane (1:1); Tetrabromobisphenol A -
Tetrabromobisphenol A diglycidyl ether polymer; Tetrabromobisphenol A, 2,2-bis(4-(2,3-epoxypropyloxy)dibromophenyl)propane polymer
Chemical Considerations: This alternative is a high MW polymer. The extent of polymerization and thus average MW is formulation dependent. The higher MW
oligomers, with a MW >1,000, are assessed together using professional judgment and information contained in the literature concerning polymer assessment
(Boethling et al., 1997). However, it should be noted that at least one formulation of CASRN 68928-70-1 has a number average molecular weight (MWn) of 1,600
with 12.7% <1,000 resulting from the presence of unchanged starting materials. The summary of the hazards of these unchanged starting materials, if present in the
commercial formulation, are provided in Table 4-4 as a footnote (~).
Polymeric: Yes
Oligomers: Commercial brominated epoxy polymer products represented by CASRN 68928-70-1 typically are comprised of high MW epoxy-terminated oligomers.
Metabolites, Degradates and Transformation Products: None
Analog: No analog
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: None identified
Risk Phrases: Not classified by Annex VI Regulation (EC) No 1272/2008 (ESIS, 2011).
Hazard and Risk Assessments: None identified
4-174
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Brominated Epoxy Polymers CASRN 68928-70-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
135-150 (Measured)
ICL Industrial Products, 2011
For the commercial product F-
2300H. The melting points reported
cover a broad range and are
anticipated to be formulation specific
liquid-glass transition temperatures.
105-115;
150 ± 5 (Measured)
NICNAS, 2001
For the commercial product F-
2300H. The melting points reported
cover a broad range and are
anticipated to be formulation specific
liquid-glass transition temperatures.
Boiling Point (°C)
>300 (Estimated)
Professional judgment
Cutoff value used for large, high MW
solids.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value for large, high MW non-
ionic polymers.
Water Solubility (mg/L)
<10° (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value for large, high MW non-
ionic polymers.
Insoluble (Measured)
ICL Industrial Products, 2011;
NICNAS, 2001
For the commercial product F-
2300H; qualitative value that cannot
be used to evaluate other endpoints
within the hazard assessment.
Log Kow
No data located; polymers with a
MW >1,000 are outside the domain
of the available estimation methods.
Flammability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Pyrolysis
No data located.
4-175
-------
Brominated Epoxy Polymers CASRN 68928-70-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
HUMAN HEALTH EFFECTS
Toxicokinetics
There is no absorption expected for any route of exposure. This polymer is large, with a MW >1,000. It is
expected to have limited bioavailability and therefore is not expected to be readily absorbed, distributed or
metabolized in the body. However, there are formulations of the commercial product available that may
contain significant amounts of lower MW components; absorption may occur more readily in this case.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral
No absorption is expected for any route
of exposure
(Estimated)
Professional judgment
Estimated based on professional
judgment.
Acute Mammalian Toxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for acute mammalian toxicity.
Acute Lethality
Oral
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Dermal
Inhalation
Carcinogenicity
LOW: This polymer is large, with a MW >1,000. It is expected to have few to no residual monomers,
crosslinking, swellability, dispersability, potential for inhalation, nor hindered amine groups and therefore
has low potential for carcinogenicity.
OncoLogic Results
No data located.
Carcinogenicity (Rat
and Mouse)
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Combined Chronic
Toxicity/
Carcinogenicity
4-176
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Brominated Epoxy Polymers CASRN 68928-70-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Genotoxicity
LOW: Brominated Epoxy Polymers were not mutagenic in bacteria and did not cause chromosomal
aberrations in human lymphocytes. In addition, these polymers are large, with a MW >1,000. They are
expected to have limited bioavailability and therefore low potential for genotoxicity.
Gene Mutation in vitro
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Negative, Salmonella typhimurium
strains TA1535, TA1537, TA98 and
TA100 and Escherichia coli strain
WP2uvrA with and without metabolic
activation.
Submitted confidential study
Reported in a submitted
confidential study; Study conducted
in accordance with Good laboratory
practice (GLP) and Organisation of
Economic Cooperation and
Development (OECD) principles.
Gene Mutation in vivo
Chromosomal
Aberrations in vitro
Negative, chromosomal aberrations in
human lymphocytes with and without
metabolic activation. Test material was
considered to be non-clastogenic.
Submitted confidential study
Reported in a submitted
confidential study; Study conducted
in accordance with GLP and OECD
principles.
Chromosomal
Aberrations in vivo
DNA Damage and
Repair
Other (Mitotic Gene
Conversion)
Reproductive Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for reproductive effects.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
4-177
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Brominated Epoxy Polymers CASRN 68928-70-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproduction and
Fertility Effects
Developmental Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for developmental effects.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Prenatal Development
Postnatal Development
Neurotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for neurotoxicity.
Neurotoxicity Screening
Battery (Adult)
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Repeated Dose Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability; however,
because the MWn is >10,000, there is the possibility of lung overloading if >5% of the particles are in the
respirable range as a result of dust forming operations.
This polymer MWn is >10,000; potential
for irreversible lung damage as a result
of lung overloading
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Skin Sensitization
LOW: Not a skin sensitizer in a local lymph node assay in mice.
Skin Sensitization
Low potential for skin sensitization.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Not sensitizing, local lymph node assay
in mice; application of test substance to
the dorsal surface of the ear
Submitted confidential study
Reported in a submitted
confidential study; Study conducted
in accordance with GLP and OECD
guideline 429 ("Skin Sensitization:
Local Lymph Node Assay")-
4-178
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Brominated Epoxy Polymers CASRN 68928-70-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
LOW: Estimated not to have potential for eye irritation based on expert
udgment. No data located.
Eye Irritation
Low potential for skin sensitization.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Dermal Irritation
LOW: Estimated not to have potential for dermal irritation based on expert judgment. No data located.
Dermal Irritation
Low potential for skin sensitization.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Endocrine Activity
This polymer is large, with a MW >1,000. It is not expected to have endocrine activity due to its poor
bioavailability and inability to be readily metabolized in the body.
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Immunotoxicity
This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore has
low potential for immunotoxicity.
Immune System Effects
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
LOW: Non-ionic polymers with a MW >1,000 and negligible water solubility are estimated to display no
effects at saturation (NES). These polymers display NES because the amount dissolved in water is not
anticipated to reach a concentration at which adverse effects may be expressed. Guidance for the
assessment of aquatic toxicity hazard leads to a low potential for those materials that display NES.
Fish LC50
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
4-179
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Brominated Epoxy Polymers CASRN 68928-70-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid LCS0
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Green Algae ECS0
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Chronic Aquatic Toxicity
LOW: Non-ionic polymers with a MW >1,000 and negligible water solubility are estimated to display NES.
These polymers display NES because the amount dissolved in water is not anticipated to reach a
concentration at which adverse effects may be expressed. Guidance for the assessment of aquatic toxicity
hazard leads to a low potential for those materials that display NES.
Fish ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Daphnid ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Green Algae ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
ENVIRONMENTAL FATE
Transport
The estimated negligible water solubility and estimated negligible vapor pressure indicate that this polymer
is anticipated to partition predominantly to soil and sediment. The estimated Henry's Law Constant of
<10"8 atm-m3/mole indicates that it is not expected to volatilize from water to the atmosphere. The estimated
Koc of >30,000 indicates that it is not anticipated to migrate from soil into groundwater and also has the
potential to adsorb to sediment.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment; Boethling
etal., 1997
High MW polymers are expected to
have low vapor pressure and are not
expected to undergo volatilization.
4-180
-------
Brominated Epoxy Polymers CASRN 68928-70-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value used for large, high MW
polymers. High MW polymers are
expected to adsorb strongly to soil
and sediment.
Level III Fugacity Model
No data located.
Persistence
VERY HIGH: This polymer is large, with a MW >1,000. It is expected to have negligible water solubility and
poor bioavailability to microorganisms indicating that neither biodegradation nor hydrolysis are expected to
be important removal processes in the environment. Although debromination by photodegradation of
polybrominated benzenes has been observed, this process is not anticipated to lead to ultimate removal of the
material. As a result, a half-life for this high MW polymer of >180 days leads to a potential for very high
persistence.
Water
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment; Boethling
etal., 1997
High MW polymers are expected to
be non-biodegradable.
Volatilization Half-life for
Model River
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Volatilization Half-life for
Model Lake
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Soil
Aerobic Biodegradation
No data located.
Anaerobic
Biodegradation
No data located.
Soil Biodegradation with
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
No data located.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Professional judgment
Bromine substituents may be
susceptible to photolysis in the
environment; however, this is
expected to be a relatively slow
process for a high MW brominated
4-181
-------
Brominated Epoxy Polymers CASRN 68928-70-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
epoxy polymer and is not anticipated
to result in the ultimate degradation
of this substance.
Hydrolysis
>1 year (Estimated)
Professional judgment
Given the limited solubility estimated
for this material, hydrolysis is not
anticipated to occur to an appreciable
extent.
Environmental Half-Life
>180 days (Estimated)
Professional judgment
The substance is a high MW polymer
and is not anticipated to be
assimilated by microorganisms.
Therefore, biodegradation is not
expected to be an important removal
process. It is also not expected to
undergo removal by other
degradative processes under
environmental conditions.
Bioaccumulation
LOW: Due to the large size and limited bioavailability of the high MW brominated epoxy polymer, it has low
potential for bioconcentration or bioaccumulation.
Fish BCF
<100 (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value for large, high MW,
insoluble polymers.
BAF
No data located.
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-182
-------
Boethling, Robert S. and Nabholz, J. Vincent "Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act",
pp. 187-234, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs, Hamilton, John D.
and Sutcliffe, Roger (eds.), (1997) Van Nostrand Reinhold.
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
May 10, 2011).
ESIS (European chemical Substances Information System) Classification, labeling and packaging of dangerous substances annex VI
to regulation (EC) No 1272/2008 [Online], http://ecb.irc.ec.europa.eu/esis/index.php?PGM=cla (accessed on May 10, 2011).
ICL Industrial Products. F-2300H. Brominated Epoxy Polymer MSDS. http://www.icl-
ip.com/brome/brome.nsf/viewAHBvUNID/6A59162E67EFC8E2C22570290051 lDB6/$file/9223 enF-2300H.pdf (accessed on July 1,
2011)
NICNAS (National Industrial Chemicals Notification and Assessment Scheme). Polybrominated flame retardants (PBFRs). Priority
Existing Chemical Assessment Report No. 20. National Industrial Chemicals Notification and Assessment Scheme, June 2001.
4-183
-------
Brominated Epoxy Polymer(s)
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame-retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations.
~ Different formulations of the commercial product are available. One of these many formulations lias an average MW of-1,600 and contains significant amounts of lower MW
components. These lower MW components have hazard potentials different than the polymeric flame retardant, as follows: HIGH estimated potential for bioaccumulation;
HIGH experimental for acute aquatic toxicity; HIGH estimated potential for chronic aquatic toxicity; MODERATE experimental for developmental; and MODERATE
estimated for carcinogenicity, genotoxicity, repeated dose and reproductive toxicity, and skin and respiratory sensitization.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Brominated Epoxy Polymer(s)
Confidential
L
L
zV
~
L
L
VH
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-184
-------
Brominated Epoxy Polymer(s)
CASRN: Confidential CASRNs
MW: Average MW 40,300;
<5% MW <1,000 (for Polyquel 241)
Average MW 50,000;
0% MW <1,000 (for Polyquel 240)
MF: Confidential MFs
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: These confidential materials are not amenable to the generation of a single SMILES notation.
Synonyms: Polyquel 240, Brominated epoxy polymer; Polyquel 241, Brominated epoxy polymer, containing low MW components
Chemical Considerations: This alternative is a polymer; the majority of this polymer is comprised of high MW oligomers. The higher MW oligomers, with a MW
>1,000, are assessed together using professional judgment and information contained in the literature concerning polymer assessment (Boethling et al., 1997).
However, for some formulations it should be noted that <5% of this commercial product consists of components with a MW <1,000. A summary of the hazards of the
MW <1,000 materials are provided in Table 4-4 as a footnote (~).
Polymeric: Yes
Oligomers: Polyquel 241: The majority of this confidential commercial product (>95%) is comprised of high MW epoxy-terminated oligomers. Polyquel 240: The
confidential commercial product is comprised of only high MW epoxy-terminated oligomers.
Metabolites, Degradates and Transformation Products: None
Analog: Confidential
Endpoint(s) using analog values: Boiling point
Analog Structure: Not applicable
Structural Alerts: None identified
Risk Phrases: Not classified by Annex VI Regulation (EC) No 1272/2008 (ESIS, 2011).
Hazard and Risk Assessments: None identified
4-185
-------
Brominated Epoxy Polymer(s)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
145-155 (Measured)
Warmington, 2010
Formulation specific liquid-glass
transition temperatures for the
commercial products Polyquel 240
and Polyquel 241.
Boiling Point (°C)
Decomposes (Estimated)
Submitted Confidential Study
Based on analogy to a confidential
polymer with a similar structure and
functional groups.
>300 (Estimated)
Professional judgment
Cutoff value used for large, high MW
solids.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; EPA,
1999
Cutoff value for large, high MW non-
ionic polymers according to HPV
polymer assessment guidance.
Water Solubility (mg/L)
<10° (Estimated)
Professional judgment; EPA,
1999
Cutoff value for large, high MW non-
ionic polymers according to HPV
polymer assessment guidance.
Log Kow
No data; polymers with a MW
>1,000 are outside the domain of the
available estimation methods.
Flammability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
Pyrolysis
No data located.
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
4-186
-------
Brominated Epoxy Polymer(s)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
There is no absorption expected for any route of exposure. This polymer is large, with a MW >1,000. It is
expected to have limited bioavailability and therefore is not expected to be readily absorbed, distributed or
metabolized in the body. However, there are formulations of the commercial product available that may
contain significant amounts of lower MW components; absorption may occur more readily in this case.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral
No absorption is expected for any route
of exposure
(Estimated)
Professional judgment
Estimated based on professional
judgment.
Acute Mammalian Toxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for acute mammalian toxicity.
Acute Lethality
Oral
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Dermal
Inhalation
Carcinogenicity
LOW: This polymer is large, with a MW >1,000. It is expected to have few to no residual monomers,
crosslinking, swellability, dispersability, potential for inhalation, nor hindered amine groups and therefore
has low potential for carcinogenicity.
OncoLogic Results
No data located.
Carcinogenicity (Rat
and Mouse)
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Combined Chronic
Toxicity/
Carcinogenicity
Genotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for genotoxicity.
Gene Mutation in vitro
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Gene Mutation in vivo
Chromosomal
Aberrations in vitro
Chromosomal
Aberrations in vivo
4-187
-------
Brominated Epoxy Polymer(s)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
DNA Damage and
Repair
Other (Mitotic Gene
Conversion)
Reproductive Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for reproductive effects.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Reproduction and
Fertility Effects
Developmental Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for developmental effects.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Prenatal Development
Postnatal Development
Neurotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for neurotoxicity.
Neurotoxicity Screening
Battery (Adult)
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
4-188
-------
Brominated Epoxy Polymer(s)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Repeated Dose Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability; however,
because the MWn is >10,000, there is the possibility of lung overloading if >5% of the particles are in the
respirable range as a result of dust forming operations.
This polymer MWn is >10,000; potential
for irreversible lung damage as a result
of lung overloading
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Skin Sensitization
LOW: Estimated not to have potential for skin sensitization based on expert judgment. No data located.
Skin Sensitization
Low potential for skin sensitization.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
LOW: Estimated not to have potential for eye irritation based on expert
udgment. No data located.
Eye Irritation
Low potential for skin sensitization.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Dermal Irritation
LOW: Estimated not to have potential for dermal irritation based on expert judgment. No data located.
Dermal Irritation
Low potential for skin sensitization.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Endocrine Activity
This polymer is large, with a MW >1,000. It is not expected to have endocrine activity due to its poor
bioavailability and inability to be readily metabolized in the body.
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Immunotoxicity
This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore has
low potential for immunotoxicity.
Immune System Effects
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
LOW: Non-ionic polymers with a MW >1,000 and negligible water solubility are estimated to display no
effects at saturation (NES). These polymers display NES because the amount dissolved in water is not
anticipated to reach a concentration at which adverse effects may be expressed. Guidance for the
assessment of aquatic toxicity hazard leads to a low potential for those materials that display NES.
4-189
-------
Brominated Epoxy Polymer(s)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish LC50
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Daphnid LCS0
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Green Algae ECS0
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Chronic Aquatic Toxicity
LOW: Non-ionic polymers with a MW >1,000 and negligible water solubility are estimated to display NES.
These polymers display NES because the amount dissolved in water is not anticipated to reach a
concentration at which adverse effects may be expressed. Guidance for the assessment of aquatic toxicity
hazard leads to a low potential for those materials that display NES.
Fish ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Daphnid ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Green Algae ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
4-190
-------
Brominated Epoxy Polymer(s)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL FATE
Transport
The estimated negligible water solubility and estimated negligible vapor pressure indicate that this polymer
is anticipated to partition predominantly to soil and sediment. The estimated Henry's Law Constant of
<10"8 atm-m3/mole indicates that it is not expected to volatilize from water to the atmosphere. The estimated
Koc of >30,000 indicates that it is not anticipated to migrate from soil into groundwater and also has the
potential to adsorb to sediment.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment; Boethling
etal., 1997
High MW polymers are expected to
have low vapor pressure and are not
expected to undergo volatilization.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value used for large, high MW
polymers. High MW polymers are
expected to adsorb strongly to soil
and sediment.
Level III Fugacity Model
No data located.
Persistence
VERY HIGH: This polymer is large, with a MW >1,000. It is expected to have negligible water solubility and
poor bioavailability to microorganisms indicating that neither biodegradation nor hydrolysis are expected to
be important removal processes in the environment. Although debromination by photodegradation of
polybrominated benzenes has been observed, this process is not anticipated to lead to ultimate removal of the
material. As a result, a half-life for this high MW polymer of >180 days leads to a potential for very high
persistence.
Water
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment; Boethling
etal., 1997
High MW polymers are expected to
be non-biodegradable.
Volatilization Half-life for
Model River
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Volatilization Half-life for
Model Lake
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Soil
Aerobic Biodegradation
No data located.
Anaerobic
Biodegradation
No data located.
4-191
-------
Brominated Epoxy Polymer(s)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Soil Biodegradation with
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
No data located.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Professional judgment
Bromine substituents may be
susceptible to photolysis in the
environment; however, this is
expected to be a relatively slow
process for a high MW brominated
epoxy polymer and is not anticipated
to result in the ultimate degradation
of this substance.
Hydrolysis
>1 year (Estimated)
Professional judgment
Given the limited solubility estimated
for this material, hydrolysis is not
anticipated to occur to an appreciable
extent.
Environmental Half-Life
>180 days (Estimated)
Professional judgment
The substance is a high MW polymer
and is not anticipated to be
assimilated by microorganisms.
Therefore, biodegradation is not
expected to be an important removal
process. It is also not expected to
undergo removal by other
degradative processes under
environmental conditions.
Bioaccumulation
LOW: Due to the large size and limited bioavailability of the polymer, it is of low potential for
bioconcentration or bioaccumulation.
Fish BCF
<100 (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value for large, high MW,
insoluble polymers.
BAF
No data located.
4-192
-------
Brominated Epoxy Polymer(s)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-193
-------
Boethling, Robert S. and Nabholz, J. Vincent "Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act",
pp. 187-234, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs, Hamilton, John D.
and Sutcliffe, Roger (eds.), (1997) Van Nostrand Reinhold.
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
May 10, 2011).
EPA (Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing Data.
U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
ESIS (European chemical Substances Information System) Classification, labeling and packaging of dangerous substances annex VI
to regulation (EC) No 1272/2008 [Online], http://ecb.irc.ec.europa.eu/esis/index.php?PGM=cla (accessed on May 10, 2011).
Warmington, A (ed). Speciality Chemicals Magazine. Quartz business Media ltd., September 2010, v.30(9) p. 40-1. 2010.
4-194
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Mixture of Brominated Epoxy Polymer(s) and Bromobenzyl Acrylate
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations.
~ Different formulations of the commercial product are available. One of these many formulations has an average MW of-1,600 and contains significant amounts of lower MW
components. These lower MW components have hazard potentials different than the polymeric flame retardant, as follows: HIGH estimated potential for bioaccumulation;
HIGH experimental for acute aquatic toxicity; HIGH estimated for chronic aquatic toxicity; MODERATE experimental for developmental; and MODERATE estimated for
carcinogenicity, genotoxicity, repeated dose and reproductive toxicity, and skin and respiratory sensitization.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Mixture of brominated epoxy polymer(s)
and bromobenzyl acrylate
Confidential
L
L
zV
~
L
L
VH
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-195
-------
Mixture of Brominated Epoxy Polymer(s) and Bromobenzyl Acrylate
CASRN: Confidential CASRNs
MW: Average MW 61,200;
<1% MW <1,000 (Polyquel 145)
Average MW 45,000;
<2% MW <1,000 (Polyquel 146)
MF: Confidential MFs
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: These mixtures containing confidential material are not amenable to the generation of a single SMILES notation.
Synonyms: Polyquel 145, Mixture of brominated epoxy polymers and bromobenzyl acrylate homopolymer; Polyquel 146, Mixture of brominated epoxy polymer and
bromobenzyl acrylate homopolymer
Chemical Considerations: These alternatives are confidential mixtures comprised of high MW polymers. All components are high MW oligomers, with a MW
>1,000, and are assessed using professional judgment and information contained in the literature concerning polymer assessment (Boethling et al., 1997). The final
hazard evaluation, presented in Table 4-4, is based on the most hazardous material typically present in the commercial product, using a conservative approach.
Polyquel 145 contains <1% of components with a MW <1,000. Polyquel 146 contains <2% of components with a MW <1,000. A summary of the hazards of the
MW <1,000 materials are provided in Table 4-4 as a footnote (~).
Polymeric: Yes
Oligomers: These commercial products are confidential mixtures comprised of two or three high MW polymers: a brominated epoxy polymer, a brominated
polyacrylate and for Polyquel 145, an end capped brominated epoxy polymer.
Metabolites, Degradates and Transformation Products: None
Analog: Confidential
Endpoint(s) using analog values: Boiling point
Analog Structure: Confidential structure
Structural Alerts: None identified
Risk Phrases: Not classified by Annex VI Regulation (EC) No 1272/2008 (ESIS, 2011).
Hazard and Risk Assessments: None identified
4-196
-------
Mixture of Brominated Epoxy Polymer(s) and Bromobenzyl Acrylate
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
No data located.
Boiling Point (°C)
Decomposes (Estimated)
Professional judgment
Based on analogy to a confidential
polymer with a similar structure and
functional groups.
>300 (Estimated)
Professional judgment
Cutoff value used for large, high MW
solids.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value for large, high MW non-
ionic polymers.
Water Solubility (mg/L)
<10° (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value for large, high MW non-
ionic polymers.
Log Kow
No data located. Polymers with a
MW >1,000 are outside the domain
of the available estimation methods.
Flammability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
Pyrolysis
No data located.
pH
Not applicable
Professional judgment
This polymer mixture does not
contain functional groups that would
be expected to ionize.
pKa
Not applicable
Professional judgment
This polymer mixture does not
contain functional groups that would
be expected to ionize.
4-197
-------
Mixture of Brominated Epoxy Polymer(s) and Bromobenzyl Acrylate
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
There is no absorption expected for any route of exposure. These polymers are large, with MW >1,000.
They are expected to have limited bioavailability and therefore are not expected to be readily absorbed,
distributed or metabolized in the body.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral
No absorption is expected for any route
of exposure (Estimated)
Professional judgment
Estimated based on professional
judgment.
Acute Mammalian Toxicity
LOW: These polymers are large, with MW >1,000. They are expected to have limited bioavailability and
therefore have low potential for acute mammalian toxicity.
Acute Lethality
Oral
Dermal
Inhalation
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Carcinogenicity
LOW: These polymers are large, with MW >1,000. They are expected to have few to no residual monomers,
crosslinking, swellability, dispersability, potential for inhalation, nor hindered amine groups and therefore
have low potential for carcinogenicity.
OncoLogic Results
No data located.
Carcinogenicity (Rat
and Mouse)
Combined Chronic
Toxicity/
Carcinogenicity
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Genotoxicity
LOW: These polymers are large, with MW >1,000. They are expected to have limited bioavailability and
therefore have low potential for genotoxicity.
Gene Mutation in vitro
Gene Mutation in vivo
Chromosomal
Aberrations in vitro
Chromosomal
Aberrations in vivo
DNA Damage and
Repair
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
4-198
-------
Mixture of Brominated Epoxy Polymer(s) and Bromobenzyl Acrylate
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Other (Mitotic Gene
Conversion)
Reproductive Effects
LOW: These polymers are large, with MW >1,000. They are expected to have limited bioavailability and
therefore have low potential for reproductive effects.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Reproduction and
Fertility Effects
Developmental Effects
LOW: These polymers are large, with MW >1,000. They are expected to have limited bioavailability and
therefore have low potential for developmental effects.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Prenatal Development
Postnatal Development
Neurotoxicity
LOW: These polymers are large, with MW >1,000. They are expected to have limited bioavailability and
therefore have low potential for neurotoxicity.
Neurotoxicity Screening
Battery (Adult)
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
4-199
-------
Mixture of Brominated Epoxy Polymer(s) and Bromobenzyl Acrylate
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Repeated Dose Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability; however,
because the MWn is >10,000, there is the possibility of lung overloading if >5% of the particles are in the
respirable range as a result of dust forming operations.
The polymer mixture MWn is >10,000;
potential for irreversible lung damage as
a result of lung overloading
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Skin Sensitization
LOW: Estimated not to have potential for skin sensitization based on expert judgment. No data located.
Skin Sensitization
Low potential for skin sensitization.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
LOW: Estimated not to have potential for eye irritation based on expert
udgment. No data located.
Eye Irritation
Low potential for eye irritation.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Dermal Irritation
LOW: Estimated not to have potential for dermal irritation based on expert judgment. No data located.
Dermal Irritation
Low potential for dermal irritation.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Endocrine Activity
These polymers are large, with MW >1,000. They are not expected to have endocrine activity due to poor
bioavailability and inability to be readily metabolized in the body.
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Immunotoxicity
These polymers are large, with MW >1,000. They are expected to have limited bioavailability and therefore
have low potential for immunotoxicity.
Immune System Effects
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
LOW: Non-ionic polymers with a MW >1,000 and negligible water solubility are estimated to display no
effects at saturation (NES). These polymers display NES because the amount dissolved in water is not
anticipated to reach a concentration at which adverse effects may be expressed. Guidance for the
assessment of aquatic toxicity hazard leads to a low potential for those materials that display NES.
4-200
-------
Mixture of Brominated Epoxy Polymer(s) and Bromobenzyl Acrylate
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish LC50
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Daphnid LCS0
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Green Algae ECS0
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Chronic Aquatic Toxicity
LOW: Non-ionic polymers with a MW >1,000 and negligible water solubility are estimated to display NES.
These polymers display NES because the amount dissolved in water is not anticipated to reach a
concentration at which adverse effects may be expressed. Guidance for the assessment of aquatic toxicity
hazard leads to a low potential for those materials that display NES.
Fish ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Daphnid ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Green Algae ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
4-201
-------
Mixture of Brominated Epoxy Polymer(s) and Bromobenzyl Acrylate
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL FATE
Transport
The estimated negligible water solubility and estimated negligible vapor pressure indicate that these
polymers are anticipated to partition predominantly to soil and sediment. The estimated Henry's Law
Constant of <10"8 atm-m3/mole indicates that they are not expected to volatilize from water to the
atmosphere. The estimated Koc of >30,000 indicates that they are not anticipated to migrate from soil into
groundwater and also have the potential to adsorb to sediment.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment; Boethling
etal., 1997
High MW polymers are expected to
have low vapor pressure and are not
expected to undergo volatilization.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value used for large, high MW
polymers. High MW polymers are
expected to adsorb strongly to soil
and sediment.
Level III Fugacity Model
No data located.
Persistence
VERY HIGH: These polymers are large, with MW >1,000. They are expected to have negligible water
solubility and poor bioavailability to microorganisms indicating that neither biodegradation nor hydrolysis
are expected to be important removal processes in the environment. Although debromination by
photodegradation of polybrominated benzenes has been observed, this process is not anticipated to lead to
ultimate removal of the material. As a result, a half-life for these high MW polymer of >180 days leads to a
potential for very high persistence.
Water
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment; Boethling
etal., 1997
High MW polymers are expected to
be non-biodegradable.
Volatilization Half-life for
Model River
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Volatilization Half-life for
Model Lake
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Soil
Aerobic Biodegradation
No data located.
Anaerobic
Biodegradation
No data located.
Soil Biodegradation with
Product Identification
No data located.
4-202
-------
Mixture of Brominated Epoxy Polymer(s) and Bromobenzyl Acrylate
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
No data located.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Professional judgment
Bromine substituents may be
susceptible to photolysis in the
environment; however, this is
expected to be a relatively slow
process for a high MW brominated
epoxy polymer and is not anticipated
to result in the ultimate degradation
of this substance.
Hydrolysis
>1 year (Estimated)
Professional judgment
Given the limited solubility estimated
for this material, hydrolysis is not
anticipated to occur to an appreciable
extent.
Environmental Half-Life
>180 days (Estimated)
Professional judgment
The substance is a high MW polymer
and is not anticipated to be
assimilated by microorganisms.
Therefore, biodegradation is not
expected to be an important removal
process. It is also not expected to
undergo removal by other
degradative processes under
environmental conditions.
Bioaccumulation
LOW: Due to the large size and limited bioavailability of the high MW polymer mixtures, they have low
potential for bioconcentration or bioaccumulation.
Fish BCF
<100 (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value for large, high MW,
insoluble polymers.
BAF
No data located.
Metabolism in Fish
No data located.
4-203
-------
Mixture of Brominated Epoxy Polymer(s) and Bromobenzyl Acrylate
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-204
-------
Boethling, Robert S. and Nabholz, J. Vincent "Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act",
pp. 187-234, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs, Hamilton, John D.
and Sutcliffe, Roger (eds.), (1997) Van Nostrand Reinhold.
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
May 10, 2011).
ESIS (European chemical Substances Information System) Classification, labeling and packaging of dangerous substances annex VI
to regulation (EC) No 1272/2008 [Online], http://ecb.irc.ec.europa.eu/esis/index.php?PGM=cla (accessed on May 10, 2011).
4-205
-------
Brominated Epoxy Resin End-Capped with Tribromophenol
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Brominated Epoxy Resin End-Capped with
Tribromophenol
135229-48-0
L
L
L
L
L
L
Ld
L
L
VL
L
L
VH
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-206
-------
Brominated Epoxy Resin End-Capped with Tribromophenol
CASRN: 135229-48-0
MW: 15,000; 0% <1,000
MF: (C15H12Br402 C6H3Br30 C3H5C10)n
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: This polymer with MW >1,000 and no low MW components is not amenable to SMILES notation.
Synonyms: 2,2'-[(l-Methylethylidene)bis[(2,6-dibromo-4,l-phenylene)oxymethylene]]bisoxirane polymer with 2,2',6,6'-tetrabromo-4,4'-isopropylidenediphenol and
2,4,6-tribromophenol; Phenol, 4,4'-(l-methylethylidene)bis[2,6-dibromo-, polymer with (chloromethyl)oxirane and 2,4,6-tribromophenol
Chemical Considerations: This alternative is a polymer. The extent of polymerization and thus average MW is formulation dependent. The higher MW oligomers
with a MW >1,000 are assessed together using information contained in the literature concerning polymer assessment and professional judgment (Boethling
et al., 1997). Additionally, lower MW formulations of brominated epoxy resin end-capped with tribromophenol exist and the simplest oligomer, comprised of each
monomer, has a MW of 970. Although below the cutoff of 1,000 used in the polymer assessment criteria, this oligomer is anticipated to possess physical/chemical
properties similar to that of the higher MW material, including limited absorption in biological systems. As a result, the assessment of the oligomers with a MW
<1,000 were performed in a manner identical to the remaining components of the polymer.
Polymeric: Yes
Oligomers: This substance is a brominated epoxy polymer end-capped with tribromophenol. Tribromophenol end-capped epoxy polymer typically consists of
oligomers with an average MW of 15,000 with 0% MW
-------
Brominated Epoxy Resin End-Capped with Tribromophenol CASRN 135229-48-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
180-220 (Measured)
ICL Industrial Products, 2009
The melting points reported cover a
broad range and are anticipated to be
formulation specific liquid-glass
transition temperatures for the
commercial product F-3100.
105-120 (Measured)
NICNAS, 2006
The melting points reported cover a
broad range and are anticipated to be
formulation specific liquid-glass
transition temperatures for the
commercial product F-3 020, the
brominated epoxy resin end-capped
with tribromophenol with low MW
oligomers that is expected to behave
similarly to the high MW polymer.
Boiling Point (°C)
>300 (Estimated)
Professional judgment
Cutoff value used for large, high MW
non-ionic polymers.
Decomposition temperature: 340
(Measured)
ICL Industrial Products, 2009
The melting points reported cover a
broad range and are anticipated to be
formulation specific liquid-glass
transition temperatures for the
commercial product F-3100.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; Boethling
et al., 1997
Cutoff value for large, high MW non-
ionic polymers.
Water Solubility (mg/L)
<10° (Estimated)
Professional judgment; Boethling
et al., 1997
Cutoff value for large, high MW non-
ionic polymers.
Log Kow
No data located; polymers with a
MW >1,000 are outside the domain
of the available estimation methods.
Flammability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
4-208
-------
Brominated Epoxy Resin End-Capped with Tribromophenol CASRN 135229-48-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
Pyrolysis
No data located.
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
HUMAN HEALTH EFF
ECTS
Toxicokinetics
There is no absorption expected for any route of exposure. This polymer is large, with a MW >1,000. It is
expected to have limited bioavailability and therefore is not expected to be readily absorbed, distributed or
metabolized in the body.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
No absorption is expected for all routes
of exposure
(Estimated)
Professional judgment
Estimated based on limited
bioavailability and professional
judgment.
Acute Mammalian Toxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for acute mammalian toxicity.
Oral
Rat Oral LD50 >2,000 mg/kg (Acute Oral
Toxicity-Limit Test).
NICNAS, 2006
Reported in a secondary source.
Conducted according to
Organisation of Economic
Cooperation and Development
(OECD) TG 401 guideline study
for the commercial product F-3020,
the brominated epoxy resin end-
capped with tribromophenol with
low MW oligomers that is expected
to behave similarly to the high MW
polymer.
Dermal
No data located.
4-209
-------
Brominated Epoxy Resin End-Capped with Tribromophenol CASRN 135229-48-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Carcinogenicity
LOW: This polymer is large, with a MW >1,000. It is expected to have few to no residual monomers,
crosslinking, swellability, dispersability, reactive functional groups, potential for inhalation nor hindered
amine groups and therefore has low potential for carcinogenicity.
OncoLogic Results
No data located.
Carcinogenicity (Rat
and Mouse)
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large,
high MW polymers.
Combined Chronic
Toxicity/
Carcinogenicity
Genotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for genotoxicity. Bacterial reverse mutation test is negative for gene mutations.
Gene Mutation in vitro
Negative for gene mutations in
Salmonella typhimurium strains TA1535,
TA1537, TA1538, TA100, TA98 with
and without exogenous metabolic
activation
NICNAS, 2006
Reported in secondary sources.
Guideline study according to
OECD TG 471 for the commercial
product F-3020, the brominated
epoxy resin end-capped with
tribromophenol with low MW
oligomers that is expected to
behave similarly to the high MW
polymer.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
No data located.
Chromosomal
Aberrations in vivo
No data located.
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
4-210
-------
Brominated Epoxy Resin End-Capped with Tribromophenol CASRN 135229-48-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproductive Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for reproductive effects.
Reproduction/
Developmental Toxicity
Screen
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Reproduction and
Fertility Effects
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large,
high MW polymers.
Developmental Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for developmental effects.
Reproduction/
Developmental Toxicity
Screen
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Prenatal Development
Postnatal Development
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large,
high MW polymers.
Neurotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for neurotoxicity.
Neurotoxicity Screening
Battery (Adult)
No data located.
Repeated Dose Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability; however,
because the MWn is >10,000, there is the possibility of lung overloading if >5% of the particles are in the
respirable range as a result of dust forming operations. No experimental data located.
4-211
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Brominated Epoxy Resin End-Capped with Tribromophenol CASRN 135229-48-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
This polymer MWn is >10,000; potential
for irreversible lung damage as a result
of lung overloading
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large,
high MW polymers.
Skin Sensitization
LOW: No evidence of reactions indicative of skin sensitization to brominated epoxy resin end-capped with
tribromophenol in a study of guinea pigs.
Skin Sensitization
No evidence of reactions indicative of
skin sensitization, guinea pig skin
sensitization - Magnusson & Kligman
maximization test.
NICNAS, 2006
Reported in a secondary source.
Conducted according to OECD TG
406 guideline study for the
commercial product F-3020, the
brominated epoxy resin end-capped
with tribromophenol with low MW
oligomers that is expected to
behave similarly to the high MW
polymer.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
LOW: Brominated epoxy resin end-capped with tribromophenol is a mild eye irritant in rabbits; irritation
begins to clear within 24 hours and is completely cleared within 48 hours.
Eye Irritation
Minimally irritating, rabbit; clearing
within 24 hours and complete clearing
within 48 hours; acute eye
irritation/corrosion study.
NICNAS, 2006
Reported in a secondary source.
Conducted according to OECD TG
405 guideline study for the
commercial product F-3020, the
brominated epoxy resin end-capped
with tribromophenol with low MW
oligomers that is expected to
behave similarly to the high MW
polymer.
4-212
-------
Brominated Epoxy Resin End-Capped with Tribromophenol CASRN 135229-48-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Dermal Irritation
VERY LOW: Brominated epoxy resin end-capped with tribromophenol is not irritating to the skin of
rabbits.
Dermal Irritation
Non-irritating to the skin of rabbits,
acute dermal irritation/corrosion study.
NICNAS, 2006
Reported in a secondary source.
Conducted according to OECD TG
404 guideline study for the
commercial product F-3020, the
brominated epoxy resin end-capped
with tribromophenol with low MW
oligomers that is expected to
behave similarly to the high MW
polymer.
Endocrine Activity
This polymer is large, with a MW >1,000. It is not expected to have endocrine activity due to its poor
bioavailability and inability to be readily metabolized in the body.
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large,
high MW polymers.
Immunotoxicity
This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore has
low potential for immunotoxicity.
Immune System Effects
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large,
high MW polymers.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
LOW: Non-ionic polymers with a MW >1,000 that do not contain reactive functional groups and are
comprised of minimal low MW oligomers are estimated to display no effects at saturation (NES). These
polymers display NES because the amount dissolved in water is not anticipated to reach a concentration at
which adverse effects may be expressed. Guidance for the assessment of
low potential for acute aquatic toxicity for those materials that display N
iquatic toxicity hazard leads to a
ES.
Fish LC50
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
4-213
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Brominated Epoxy Resin End-Capped with Tribromophenol CASRN 135229-48-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid LCS0
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Green Algae ECS0
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Chronic Aquatic Toxicity
LOW: Non-ionic polymers with a MW >1,000 that do not contain reactive functional groups and are
comprised of minimal low MW oligomers are estimated to display NES. These polymers display NES
because the amount dissolved in water is not anticipated to reach a concentration at which adverse effects
may be expressed. Guidance for the assessment of aquatic toxicity hazard leads to a low potential for
chronic aquatic toxicity for those materials that display NES.
Fish ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Daphnid ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Green Algae ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
ENVIRONMENTAL FATE
Transport
The estimated negligible water solubility and estimated negligible vapor pressure indicate that this polymer
is anticipated to partition predominantly to soil and sediment. The estimated Henry's Law Constant of <10"8
atm-m3/mole indicates that it is not expected to volatilize from water to the atmosphere. The estimated Koc of
>30,000 indicates that it is not anticipated to migrate from soil into groundwater and also has the potential to
adsorb to sediment.
4-214
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Brominated Epoxy Resin End-Capped with Tribromophenol CASRN 135229-48-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment; Boethling
et al., 1997
High MW polymers are expected to
have low vapor pressure and are not
expected to undergo volatilization.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
Professional judgment; Boethling
et al., 1997
Cutoff value used for large, high MW
polymers. High MW polymers are
expected to adsorb strongly to soil
and sediment.
Level III Fugacity Model
No data located.
Persistence
VERY HIGH: This polymer is large, with a MW >1,000. It is expected to have negligible water solubility and
poor bioavailability to microorganisms indicating that neither biodegradation nor hydrolysis are expected to
be important removal processes in the environment. Although debromination by photodegradation of
polybrominated benzenes has been observed, this process is not anticipated to lead to ultimate removal of the
material. As a result, a half-life for this high MW polymer of >180 days leads to a potential for very high
persistence.
Water
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment; Boethling
et al., 1997
Cutoff value for large, high MW
polymers.
Volatilization Half-life for
Model River
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Volatilization Half-life for
Model Lake
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Soil
Aerobic Biodegradation
No data located.
Anaerobic
Biodegradation
No data located.
Soil Biodegradation with
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
No data located.
4-215
-------
Brominated Epoxy Resin End-Capped with Tribromophenol CASRN 135229-48-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reactivity
Photolysis
Not a significant fate process (Estimated)
Professional judgment
Bromine substituents are susceptible
to photolysis however; this is
expected to be a relatively slow
process for brominated epoxy resin
end-capped with tribromophenol and
is not anticipated to lead to ultimate
removal of the material.
Hydrolysis
>1 year (Estimated)
Professional judgment
Given the limited solubility estimated
for this material, hydrolysis is not
anticipated to occur to an appreciable
extent.
Environmental Half-Life
>180 days (Estimated)
Professional judgment
The substance has a MW >1,000 and
is not anticipated to be assimilated by
microorganisms. Therefore,
biodegradation is not expected to be
an important removal process. Other
degradative processes under
environmental conditions are not
anticipated to be facile.
Bioaccumulation
LOW: Due to the large size and water insolubility of this high MW polymer, it is of low potential for
bioconcentration or bioaccumulation.
Fish BCF
<100 (Estimated)
Professional judgment; Boethling
et al., 1997
Cutoff value for large, high MW,
insoluble polymers according to
polymer assessment literature.
BAF
No data located.
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-216
-------
Boethling, Robert S. and Nabholz, J. Vincent "Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act",
pp. 187-234, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs, Hamilton, John D.
and Sutcliffe, Roger (eds.), (1997) Van Nostrand Reinhold.
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
May 10, 2011).
EPA (U.S. Environmental Protection Agency). Office of Pollution Prevention and Toxics. Screening-Level Hazard Characterization
Document for Phosphoryl Chloride, Polymer with Resorcinol Phenyl Ester (CASRN125997-21-9). U.S. Environmental Protection
Agency: Washington D.C. 2010.
http://www.epa.gov/chemrtk/hpvis/hazchar/125997219_Phosphoryl%20chloride,%20polymer%20with%20resorcinol%20phenyl%20e
ster_%20June%202010.pdf (accessed April 5, 2012).
ESIS (European chemical Substances Information System) Classification, labeling and packaging of dangerous substances annex VI
to regulation (EC) No 1272/2008 [Online] available at: http://ecb.irc.ec.europa.eu/esis/index.php?PGM=cla as of May 10, 2011.
ICL Industrial Products. Material Safety Data Sheet (MSDS) for F-3100. www.icl-ip.com. 2009.
NICNAS (National Industrial Chemicals Notification and Assessment Scheme). Phenol, 4,4'-(l-methylethylidene)bis[2,6-dibromo-,
polymer with (chloromethyl)oxirane and 2,4,6-tribromophenol (F-3020). File No. LTD/1261. 2006.
4-217
-------
Brominated Polyacrylate
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Brominated Polyacrylate
59447-57-3
L
L
L
L
L
L
Ld
L
L
L
L
L
VH
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame
retardants that may partition to sediment and particulates.
4-218
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Brominated Polyacrylate
CASRN: 59447-57-3
MW: 80,000 (Measured); 0% <1,000
MF: (C10H5Br5O2)n
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: This polymer with MW >1,000 and no low MW components is not amenable to SMILES notation.
Synonyms: 2-Propenoic acid, (2,3,4,5,6-pentabromophenyl)methyl ester, homopolymer; 2-Propenoic acid, (pentabromophenyl)methyl ester, homopolymer;
Ameribrom FR 1025; FR 1025; FR 1025P; PBB-PA; Pentabromo-benzyl-acrylate, polymer; (Poly)pentabromobenzyl acrylate; Poly(2,3,4,5,6-pentabromobenzyl
acrylate); Polymer of 2,3,4,5,6-pentabromobenzyl acrylate; Pentabromobenzyl acrylate homopolymer; Ameribrom FR 1025; FR 1025; FR 1025P; PBB-PA
Chemical Considerations: This alternative is a high MW polymer. The high MW (MW >1,000) oligomers were assessed together using information contained in
the literature concerning polymer assessment and professional judgment (Boethling et al., 1997).
Polymeric: Yes
Oligomers: The formula for this polymer is (CioILBrjC^nand the average MW is approximately 80,000 daltons (NICNAS, 2001) with oligomers below 500 or 1,000
not expected.
Metabolites, Degradates and Transformation Products: None
Analog: No analog
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: None identified
Risk Phrases: Not classified by Annex I Directive 67/548/European Economic Community & IUCLID (Pakalin et al., 2007).
Hazard and Risk Assessments: None identified
4-219
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Brominated Polyacrylate CASRN 59447-57-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
180 (glass transition temperature)
(Measured)
Sigma-Aldrich, 2011
The melting points reported cover a
broad range and are anticipated to be
formulation specific liquid-glass
transition temperatures.
190-220 (glass transition temperature)
(Measured)
NICNAS, 2001; Mack, 2004
Boiling Point (°C)
>300 (Estimated)
Professional judgment
Cutoff value used for large, high MW
solid.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; Boethling
et al., 1997
Cutoff value for large, high MW
polymers.
<0.075 (Measured)
NICNAS, 2001
Reported in a secondary source.
Insufficient information provided to
assess the quality of the data.
Water Solubility (mg/L)
<10° (Estimated)
Professional judgment; Boethling
et al., 1997
Cutoff value for large, high MW
polymers.
3.5-3.8 (Measured)
NICNAS, 2001
Reported in a secondary source;
value inconsistent with that expected
for a highly halogenated polymer
with a MW >10,000.
Log Kow
No data located; polymers with a
MW >1,000 are outside the domain
of the available estimation methods.
Flammability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
Pyrolysis
No data located.
pH
No data located.
pKa
No data located.
4-220
-------
Brominated Polyacrylate CASRN 59447-57-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
Brominated polyacrylate has a MW >1,000 and limited water solubility. There is no absorption expected for
any route of exposure for this compound; therefore it is not expected to be absorbed, distributed or
metabolized in the body. The lack of absorption is expected to result in low hazard potential.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
No absorption is expected for all routes of
exposure
(Estimated by analogy)
Professional judgment
Estimated based on professional
judgment.
Acute Mammalian r
oxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has a low potential for acute mammalian toxicity. No data located.
Acute Lethality
Oral
Dermal
Inhalation
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
et al., 1997
Based on polymer assessment
literature.
Carcinogenicity
LOW: This polymer is large, with a MW >1,000. It is expected to have few to no residual monomers.
Additionally, crosslinking, swellability, dispersability, reactive functional groups, inhalation potential, and
hindered amine groups are not expected and therefore this chemical has a low potential for carcinogenicity.
No data located.
OncoLogic Results
Carcinogenicity (Rat and
Mouse)
Combined Chronic
Toxicity/ Carcinogenicity
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
et al., 1997
Based on cutoff values for large high
MW polymers.
Genotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has a low potential for genotoxicity. No data located.
Gene Mutation in vitro
Gene Mutation in vivo
Chromosomal
Aberrations in vitro
Chromosomal
Aberrations in vivo
DNA Damage and Repair
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
et al., 1997
Based on cutoff values for large high
MW polymers.
4-221
-------
Brominated Polyacrylate CASRN 59447-57-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Other (Mitotic Gene
Conversion)
Reproductive Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has a low potential for reproductive effects. No data located.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
et al., 1997
Based on cutoff values for large high
MW polymers.
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
Reproduction and
Fertility Effects
Developmental Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has a low potential for developmental effects. No data located.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
et al., 1997
Based on cutoff values for large high
MW polymers.
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
Prenatal Development
Postnatal Development
Neurotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has a low potential for neurotoxicity. No data located.
Neurotoxicity Screening
Battery (Adult)
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
et al., 1997
Based on cutoff values for large high
MW polymers.
4-222
-------
Brominated Polyacrylate CASRN 59447-57-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Repeated Dose Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have lim
because the MWn is >10,000, there is the possibility of lung overloading if
respirable range as a result of dust forming operations. No experimental (
ited bioavailability; however,
>5% of the particles are in the
ata located.
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
et al., 1997
Based on cutoff values for large high
MW polymers.
This polymer MWn is >10,000; potential
for irreversible lung damage as a result of
lung overloading
(Estimated by analogy)
Professional judgment; Boethling
et al., 1997
Based on cutoff values for large high
MW polymers.
Skin Sensitization
LOW: Estimated not to have potential for skin sensitization based on expert judgment.
Skin Sensitization
Low potential for skin sensitization
(Estimated)
Expert judgment
Estimated based on expert judgment.
Respiratory Sensitization
No data located.
Respiratory Sensitization
No data located.
Eye Irritation
LOW: Estimated not to have potential for eye irritation based on expert judgment.
Eye Irritation
Low potential for eye irritation
(Estimated)
Expert judgment
Estimated based on expert judgment.
Dermal Irritation
LOW: Estimated not to have potential for dermal irritation based on expert judgment.
Dermal Irritation
Low potential for dermal irritation
(Estimated)
Expert judgment
Estimated based on expert judgment.
Endocrine Activity
This polymer is large, with a MW >1,000. It is not expected to have endocrine activity due to its limited
bioavailability and inability to be readily metabolized in the body.
No data located.
Immunotoxicity
This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore has a low
potential for immunotoxicity. No data located.
Immune System Effects
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
et al., 1997
Based on cutoff values for large high
MW polymers.
ECOTOXICITY
ECOSAR Class
Not applicable
4-223
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Brominated Polyacrylate CASRN 59447-57-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Acute Toxicity
LOW: Non-ionic polymers with a MW >1,000 that do not contain reactive functional groups and are
comprised of minimal low MW oligomers are estimated to display no effects at saturation (NES). These
polymers display NES because the amount dissolved in water is not anticipated to reach a concentration at
which adverse effects may be expressed. Guidance for the assessment of aquatic toxicity hazard results in a
Low hazard categorization for those materials that display NES.
Fish LC50
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Daphnid LCS0
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Green Algae ECS0
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Chronic Aquatic Toxicity
LOW: Non-ionic polymers with a MW >
comprised of minimal low MW oligomers
the amount dissolved in water is not antit
,000 that do not contain reactive functional groups and are
are estimated to display NES. These polymers display NES because
:ipated to reach a concentration at which adverse effects may be
expressed. Guidance for the assessment of aquatic toxicity hazard results in a low hazard categorization for
those materials that display NES.
Fish ChV
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Daphnid ChV
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Green Algae ChV
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
4-224
-------
Brominated Polyacrylate CASRN 59447-57-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL FATE
Transport
The estimated negligible water solubility and estimated negligible vapor pressure indicate that this polymer is
anticipated to partition predominantly to soil and sediment. The estimated Henry's Law Constant of <10"8
atm-m3/mole indicates that it is not expected to volatilize from water to the atmosphere. The estimated Koc of
>30,000 indicates that it is not anticipated to migrate from soil into groundwater and also has the potential to
adsorb to sediment.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment; Boethling
et al., 1997
High MW polymers are expected to
have low vapor pressure and are not
expected to undergo volatilization.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
Professional judgment; Boethling
et al., 1997
High MW polymers are expected to
adsorb strongly to soil and sediment.
Level III Fugacity Model
No data located.
Persistence
VERY HIGH: This polymer is large, with a MW >1,000. It is expected to have negligible water solubility and
limited bioavailability to microorganisms indicating that neither biodegradation nor hydrolysis are expected
to be important removal processes in the environment. Although photodegradation of polybrominated
benzenes has been observed, this process is not anticipated to lead to ultimate removal of the material. As a
result, a half-life for this high MW polymer of >180 days leads to the potential for very high persistence.
Water
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment; Boethling
et al., 1997
High MW polymers are expected to
be non-biodegradable.
Volatilization Half-life for
Model River
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Volatilization Half-life for
Model Lake
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Soil
Aerobic Biodegradation
No data located.
Anaerobic
Biodegradation
No data located.
Soil Biodegradation with
Product Identification
No data located.
4-225
-------
Brominated Polyacrylate CASRN 59447-57-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
No data located.
Reactivity
Photolysis
Professional judgment
Bromine substituents are susceptible
to photolysis; however this is
expected to be a relatively slow
process for brominated polyacrylate
and is not anticipated to lead to
ultimate removal of the material.
Hydrolysis
>1 year (Estimated)
Professional judgment
Given the limited solubility estimated
for this material, hydrolysis is not
anticipated to occur to an appreciable
extent.
Environmental Half-Life
>180 days (Estimated)
Professional judgment
The substance has a MW >1,000 and
is not anticipated to be assimilated by
microorganisms. Therefore,
biodegradation is not expected to be
an important removal process. Other
degradative processes under
environmental conditions are also not
anticipated.
Bioaccumulation
LOW: Due to the large size and limited bioavailability of this polymer, it has low potential for
bioconcentration or bioaccumulation.
Fish BCF
<100 (Estimated)
Professional judgment; Boethling
et al., 1997
Cutoff value for large, high MW,
insoluble polymers.
BAF
No data located.
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
4-226
-------
Brominated Polyacrylate CASRN 59447-57-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-227
-------
Boethling, Robert S. and Nabholz, J. Vincent "Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act",
pp. 187-234, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs, Hamilton, John D.
and Sutcliffe, Roger (eds.), (1997) Van Nostrand Reinhold.
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
May 10, 2011).
EPA (U.S. Environmental Protection Agency) Sustainable Futures. Using NonCancer Screening within the SFInitiative. U.S.
Environmental Protection Agency: Washington D.C. 2010. http://www.epa.gOv/opptintr/sf/pubs/noncan-screen.htm#svstemic
(accessed February 09, 2011).
Mack, A. Flame retardants, Halogenated. Kirk-Othmer Encyclopedia of Chemical Technology. Wiley-Interscience. Published
Online: July 15, 2004.
NICNAS (National Industrial Chemicals Notification and Assessment Scheme). Priority Existing Chemical Assessment Report No.
20. Polybrominated Flame Retardants (PBFRs) [Online] June 2001.
http://www.nicnas.gov.au/publications/car/pec/pec20/pec 20 full report pdf.pdf
Pakalin, S.; Cole, T.; Steinkellner, J.; et al. Review on production processes of decabromodiphenyl ether (DECABDE) used in
polymeric applications in electrical and electronic equipment, and assessment of the availability of potential alternatives to
DECABDE. [Online] January 2007. http://ecb.irc.ec.europa.eu/documents/Existing-
Chemicals/Review on production process of decaBDE.pdf (accessed on January 20, 2011).
Sigma-Aldrich. On-line Catalog 2011. http://www.sigmaaldrich.com/catalog/ (accessed on April 14, 2011).
4-228
-------
Brominated Poly(phenylether)
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
a This alternative may contain impurities. These impurities have hazard designations that differ from the flame retardant alternative, Brominated poly(phenylether), as follows, based
on experimental data: HIGH for human health, HIGH for aquatic toxicity, VERY HIGH for bioaccumulation. and VERY HIGH for persistence.
' This chemical is subject to testing in an EPA consent order for this endpoint.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Brominated Poly(phenylether)
Confidential
L
La
L
VLn
Ma
La
La
L
L
VL
L
La
VH7
H'a
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants that
may partition to sediment and particulates.
4-229
-------
Brominated Poly(phenylether)
CASRN: Confidential CASRN
MW: >1,000
MF: Confidential MF
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: Confidential SMILES notation; not amenable to the generation of a SMILES notation
Synonyms: Emerald Innovation 1000™; Brominated PPE; Br PPE
Chemical Considerations: This material was assessed using guidance from High Production Volume criteria, information contained in the literature concerning
polymer assessment, and by analysis of confidential materials with similar structures, substituents, and MWs, in the absence of experimental values (EPA, 1999;
Boethling et al., 1997). Impurities have been found in analogous substances and could potentially be present in this substance. A summary of the hazard designations
for the impurities are provided in the hazard summary table. This chemical is subject to testing for persistence and bioaccumulation endpoints. Testing for the
presence of impurities is also required under consent order.
Polymeric: Not a polymer by EPA definition (EPA, 1997)
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: Photodegradation - potential for debromination (Professional judgment)
Analog: None
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: None identified
Risk Phrases: Not classified by Annex VI Regulation (EC) No 1272/2008 (ESIS, 2012).
Hazard and Risk Assessments: None identified
4-230
-------
Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
186-307 (Measured)
According to a modified capillary
method/melting temperature device with
liquid bath method and designed to be
compatible with Organisation of
Economic Cooperation and Development
(OECD) Guideline 102
Submitted confidential study
Adequate, guideline study.
270-329 (Measured)
According to an OECD guideline study.
Submitted confidential study
Adequate, guideline study.
Boiling Point (°C)
>450 at 102.81 kPa (Measured)
According to a differential scanning
calorimetry procedure American Society
for Testing and Materials (ASTM) E537-
86, designed to be compatible with OECD
Guideline 103
Submitted confidential study
Cutoff value obtained from guideline
study.
Vapor Pressure (mm Hg)
<9.8xl0"7 at 25°C (Measured)
According to OECD Guideline 104
Submitted confidential study
Cutoff value obtained from guideline
study.
Water Solubility (mg/L)
<6.63xl0"5 at20°C (Measured)
Determined to be less than the limit of
quantitation (LOQ) according to the
column elution method, Test Guidelines,
OPPTS 830.7840
Submitted confidential study
Cutoff value obtained from a
guideline study.
<7.96xl0"2 at20°C (Measured)
According to the column elution method,
designed to be compatible with OECD
Guideline 105
Submitted confidential study
Cutoff value obtained from a study
equivalent to a guideline study.
Log Kow
>9.4 (Measured)
According to high performance liquid
chromatography (HPLC) Method designed
to be compatible with for OECD
Guideline Method 117
Submitted confidential study
Cutoff value obtained from guideline
study.
4-231
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Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Flammability (Flash Point)
Not highly flammable (Measured)
According to Method A10 Flammability
(Solids) of Commission Regulation (EC)
No 440/2008
Submitted confidential study
Adequate, guideline studies.
No relative self-ignition temperature
below its melting temperature (Measured)
According to a study compatible with
method A16 Relative Self-Ignition
Temperature for Solids of Commission
Regulation (EC) No 44012008
Submitted confidential study
>10 J is the lowest spark energy capable of
igniting a dispersed dust of this mixture
according to ASTM E 2019 Standard Test
Method for the Minimum Ignition Energy
of a Dust
Cloud in Air and IEC 61241-2-3 Part 2
Section 3 (Measured)
Submitted confidential study
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Pyrolysis
No data located.
pH
Not applicable
Professional judgment
This material does not contain any
function groups that are anticipated to
ionize in solution.
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
4-232
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Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
Poor absorption is expected. Even though this substance is large and poorly soluble in water, its structure and
potential for debromination suggest it could be bioavailable. No data located.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
Poor absorption is expected for all routes
of exposure based on physical/chemical
properties (Estimated)
Professional judgment
Professional judgment based on the
analysis of confidential materials with
similar structures, substituents, and
MW.
Acute Mammalian Toxicity
LOW: Available experimental data indicate a Low hazard designation. Based on oral and dermal LDS0
>2,000 mg/kg. There were no acute toxicity data located for the inhalation route.
Acute Lethality
Oral
Limited bioavailability expected
(Estimated)
Professional judgment
Professional judgment based on the
analysis of confidential materials with
similar structures, substituents, and
MW.
Rat, oral LD50 >2,000 mg/kg
Confidential study
Reported in a submitted confidential
study; study conducted according to
OECD 420.
Dermal
Rat, oral LD50 >2,000 mg/kg
Confidential study
Reported in a submitted confidential
study; study conducted according to
OECD 402.
Inhalation
No data located.
Carcinogenicity
LOW: This material has a MW >1,000 and limited water solubility. It is expected to have limited
bioavailability and few to no low MW components. Additionally, no crosslinking, swellability, dispersability,
reactive functional groups, potential for inhalation, or hindered amine groups are expected and therefore this
chemical has a low potential for carcinogenicity. No experimental data located.
OncoLogic Results
No data located.
Carcinogenicity (Rat and
Mouse)
Limited bioavailability expected
(Estimated)
Professional judgment
Professional judgment based on the
analysis of confidential materials with
similar structures, substituents, and
MW.
Combined Chronic
Toxicity/ Carcinogenicity
4-233
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Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Genotoxicity
LOW: This material did not cause gene mutations in bacteria or in L5178Y TK +/- mouse cells, and did not
cause chromosomal aberrations in human lymphocyte cells in vitro.
Gene Mutation in vitro
Negative, Ames assay of Salmonella
typhi murium strains TA98, TA100,
TA1535, TA1537 and Escherichia coli
WP2 uvrA both with and without
metabolic activation.
Submitted confidential study
Study conducted according to OECD
test guideline 471.Test substance
purity: 100%.
Negative for mutagenicity in a L5178Y
TK +/- mouse lymphoma assay with or
without metabolic activation
Confidential study
Study details reported in a submitted
confidential study; conducted
according to OECD 476; test
substance purity: 100%.
Gene Mutation in vivo
Limited bioavailability expected
(Estimated)
Professional judgment
Professional judgment based on the
analysis of confidential materials with
similar structures, substituents, and
MW.
Chromosomal
Aberrations in vitro
Negative for chromosomal aberrations in
human lymphocytes both with and without
metabolic activation.
Submitted confidential study
Study conducted according to OECD
test guideline 473. Test substance
purity: 100%.
Chromosomal
Aberrations in vivo
Limited bioavailability expected
(Estimated)
Professional judgment
Professional judgment based on the
analysis of confidential materials with
similar structures, substituents, and
MW.
DNA Damage and Repair
No data located.
Other
No data located.
Reproductive Effects
VERY LOW: No reproductive effects were noted in a reproduction/developmental toxicity screening test in
rats at doses up to 1,000 mg/kg-day.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment
Professional judgment based on the
analysis of confidential materials with
similar structures, substituents, and
MW.
4-234
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Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproduction/developmental toxicity
screening test in rats orally (gavage)
exposed to 0, 100, 300, or 1,000 mg/kg-
day for up to 8 weeks (2 week maturation
phase, pairing, gestation and early
lactation (females). Maternal toxicity:
there were no effects on body weight or
food and water consumption; No
treatment-related effects on mating,
conception rates or gestation lengths were
reported
Confidential study
Study details reported in a submitted
confidential study; conducted
according to OECD 421.
NOAEL = 1,000 mg/kg-day (highest dose
tested)
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
No data located.
Reproduction and
Fertility Effects
No data located.
Developmental Effects
MODERATE: No developmental effects were noted in a reproduction/developmental toxicity screening test in
rats at doses up to 1,000 mg/kg-day. Potential for developmental neurotoxicity by analogy to brominated
diphenyl ethers cannot be ruled out therefore a moderate designation is applied conservatively.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected although
similarity to brominated diphenyl ethers
raises a structural alert associated with
developmental neurotoxicity (Estimated)
Professional judgment
Professional judgment based on the
analysis of substances with similar
structures, substituents, and MW.
Reproduction/developmental toxicity
screening test in rats orally (gavage)
exposed to 0, 100, 300, or 1,000 mg/kg-
day for up to 8 weeks (2 week maturation
phase, pairing, gestation and early
Confidential study
Study details reported in a submitted
confidential study; conducted
according to OECD 421.
4-235
-------
Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
lactation (females);
Maternal toxicity: there were no effects on
body weight or food and water
consumption;
Developmental effects: There were no
changes in litter size at birth and on post-
partum days 1 and 4 compared to controls;
offspring body weight gain and litter
weights on post-partum days 1 and 4 were
also comparable to controls; No clinical
signs of toxicity or changes in organ
weights were observed in offspring; in
addition there were no relevant
macroscopic or microscopic abnormalities
observed.
Maternal and Developmental:
NOAEL = 1,000 mg/kg-day (highest dose
tested)
LOAEL >1,000 mg/kg-day
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
No data located.
Prenatal Development
No data located.
Postnatal Development
No data located.
Neurotoxicity
LOW: Estimated based on physical chemical properties and limited experimental data. This material has a
MW >1,000 and limited water solubility. It is expected to have limited bioavailability and therefore is of low
potential for neurotoxicity. There were no treatment-related changes in behavioral parameters, functional
performance tests or sensory reactivity in a 28-day repeated dose study in rats; this study was not designed as
a comprehensive neurotoxicity study.
4-236
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Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Neurotoxicity Screening
Battery (Adult)
Limited bioavailability expected
(Estimated)
Professional judgment
Professional judgment based on the
analysis of confidential materials with
similar structures, substituents, and
MW.
28-day repeated dose oral (gavage) study
in rats exposed to 0, 30, 300, or 1,000
mg/kg-day;
There were no treatment-related changes
in behavioral parameters, functional
performance tests or sensory reactivity.
Confidential study
Reported in a submitted confidential
study; study conducted according to
OECD 407.
NOAEL = 1,000 mg/kg-day (highest dose
tested)
LOAEL >1,000 mg/kg-day
Repeated Dose Effects
LOW: Available experimental data reported no effects in rats at a dose of 1,000 mg/kg-day (highest dose
tested) following 7- or 28-day repeated dose studies.
Limited bioavailability expected
(Estimated)
Professional judgment
Professional judgment based on the
analysis of confidential materials with
similar structures, substituents, and
MW.
4-237
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Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
28-day repeated dose oral (gavage) study
in rats exposed to 0, 30, 300, or 1,000
mg/kg-day;
No mortality or clinical signs reported; No
changes in body weight, food
consumption, water consumption,
hematology, blood chemistry, urinalysis,
organ weights or thyroid hormone levels
were observed; necropsy and
histopathology did not reveal any
treatment related abnormalities; In
addition, there were no treatment-related
changes in behavioral parameters,
functional performance tests or sensory
reactivity.
Confidential study
Reported in a submitted confidential
study; study conducted according to
OECD 407; test substance purity:
100%.
NOAEL = 1,000 mg/kg-day (highest dose
tested)
LOAEL >1,000 mg/kg-day
7-day repeated dose oral (gavage) range-
finding toxicity study in rats exposed to 0,
250, 500, or 1,000 mg/kg-day;
No mortality or clinical signs of toxicity
reported; no effects on body weight or
food and water consumption were
reported; No macroscopic abnormalities
were reported.
Confidential study
Reported in a submitted confidential
study; test substance purity: 100%.
NOAEL = 1,000 mg/kg-day
LOAEL >1,000 mg/kg-day
4-238
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Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Skin Sensitization
LOW: This test substance is not a skin sensitizer based on results of a local lymph node assay in mice.
Skin Sensitization
Low potential for skin sensitization
(Estimated)
Expert judgment
Professional judgment based on the
analysis of confidential materials with
similar structures, substituents, and
MW.
Not a skin sensitizer in a local lymph node
assay in mice.
Confidential study
Study details reported in a submitted
confidential study; conducted
according to OECD 429; test
substance purity: 100%.
Respiratory Sensitization
No data located.
Respiratory Sensitization
No data located.
Eye Irritation
LOW: This material was a minimal eye irritant in rabbits.
Eye Irritation
Minimally irritating in rabbits; clearing
within 24 hours.
Submitted confidential study
Study conducted according to OECD
test guideline 405. Test substance
purity: 100%.
Dermal Irritation
VERY LOW: This material was not a skin irritant in rabbits.
Dermal Irritation
No evidence of skin irritation in rabbits.
Submitted confidential study
Study conducted according to OECD
test guideline 404; single 4-hour,
semi-occluded application to intact
skin. Test substance purity: 100%.
Endocrine Activity
No data located. This material has a MW >1,000 and limited water solubility. It is not expected to have
endocrine activity due to its poor bioavailability and inability to readily metabolize in the body.
Limited bioavailability expected
(Estimated)
Professional judgment
Professional judgment based on the
analysis of confidential materials with
similar structures, substituents, and
MW.
4-239
-------
Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Immunotoxicity
This material has a MW >1,000 and limited water solubility. It is expected to have limited bioavailability and
therefore is of low potential for immunotoxicity. No experimental data located.
Immune System Effects
Limited bioavailability expected
(Estimated)
Professional judgment
Professional judgment based on the
analysis of confidential materials with
similar structures, substituents, and
MW.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
LOW: Experimental data in fish, daphnia, and algae indicate no effects at saturation (NES). In addition,
non-ionic solids with a MW >1,000 that do not contain reactive functional groups and are comprised of
minimal low MW components are estimated to display NES. These solids display NES because the amount
dissolved in water is not anticipated to reach a concentration at which adverse effects may be expressed.
Guidance for the assessment of aquatic toxicity hazard leads to a low potential for hazard for those materials
that display NES.
Fish LC50
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Oncorhvnchiis mykiss (rainbow trout) 96-
hour Lethal Loading Rate (LL50) >100
mg/L;
No Observed Effect Loading rate = 100
mg/L
(Experimental)
Submitted confidential study
Conducted according to OECD 203;
test substance purity was described as
"natural complex substance"; fish
were exposed to water accommodated
fraction (WAF) at a single nominal
loading rate of 100 mg/L). The
concentration in the WAF ranged
from 0.184 to 0.0270 mg/L between
zero and 96 hours of the test.
Toxicity cannot be attributed to a
single component of the mixture and
is based on nominal loading rates;
There were no adverse effects at the
limit of water solubility; therefore,
NES is predicted.
4-240
-------
Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid LCS0
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Daphnia magna 4 8-hour Effective
Loading Rate (EL50) >100 mg/L;
No Observed Effect Loading rate = 100
mg/L
(static test conditions)
(Experimental)
Submitted confidential study
Conducted according to OECD 202;
test substance purity was described as
"natural complex substance"; Daphnia
exposed to WAF at a single nominal
loading rates of 100 mg/L). The
concentration in the WAF ranged
from 0.0436 mg/L to the limit of
quantitation between zero and 48
hours of the test. Toxicity cannot be
attributed to a single component of the
mixture and are based on nominal
loading rates; There were no adverse
effects at the limit of water solubility;
therefore, NES is predicted.
Green Algae ECS0
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Pseiidokirchneriella subcapitata 72-hour
Effective Loading rate (EL50) >100 mg/L
(growth rate);
No Observed Effect Loading rate = 100
mg/L
(Experimental)
Submitted confidential study
Conducted according to OECD 201;
test substance purity: 100%; algae
exposed to WAF at a single nominal
loading rates of 100 mg/L). The
concentration in the WAF ranged
from less than the limit of quantitation
to 0.19 mg/L between zero and 72
hours of the test. Toxicity cannot be
attributed to a single component of the
mixture and are based on nominal
loading rates; There were no adverse
effects at the limit of water solubility;
therefore, NES is predicted.
4-241
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Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Chronic Aquatic Toxicity
LOW: Test data regarding chronic aquatic toxicity for fish and algae were not located on this substance
therefore potential for hazard is uncertain. Test data for daphnids included water accommodated fractions
with test substance below limit of quantitation suggesting NES due to poor solubility.
Fish ChV
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Daphnid ChV
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Daphnia magna 21- day; Semi-static test
conditions
21-day EL50 (reproduction) >100 mg/L)
NOEC (reproduction) = 100 mg/L
LOEC (reproduction) >100 mg/L
21-day EL50 (growth) >100 mg/L
NOEC (growth) = 100 mg/L
LOEC (growth) >100 mg/L
(Experimental)
Submitted confidential study
Conducted according to OECD 211;
test substance composition and/or
purity not specified; Daphnia exposed
to WAF at nominal loading rates of
1.0, 3.2, 10, 32, and 100 mg/L. The
concentration in the WAF was below
the limit of quantitation at on day 0, 2,
9, 12, 19 and 21 in both fresh and old
media.
Green Algae ChV
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
ENVIRONMENTAL FATE
Transport
The estimated negligible water solubility and estimated negligible vapor pressure indicate that this substance
is anticipated to partition predominantly to soil and sediment. The estimated Henry's Law Constant of <10"8
atm-m3/mole indicates that it is not expected to volatilize from water to the atmosphere. The measured Koc of
>430,000 indicates that it is not anticipated to migrate from soil into groundwater and also has the potential
to adsorb to sediment.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment
Cutoff value for nonvolatile
compounds.
4-242
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Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
EPA, 2004; Professional
judgment
Cutoff value for nonmobile
compounds.
Koc >430,000 (Measured)
According to an HPLC screening method,
designed to be compatible to OECD
Guideline 121
Submitted confidential study
Cutoff value obtained from guideline
study.
Level III Fugacity Model
No data located.
Persistence
VERY HIGH: This substance has a MW >1,000. It is expected to have negligible water solubility and poor
bioavailability to microorganisms indicating that biodegradation is not expected to be an important removal
processes in the environment. One experimental biodegradation test using activated sludge resulted in no
degradation after 28 days. Estimated hydrolysis half-lives of >1 year indicate that this will not be an
important environmental removal process. Although photodegradation of brominated aromatic compounds
has been observed, this process is not anticipated to lead to ultimate removal of the material. As a result, a
half-life for this high MW solid is expected to be >180 days.
While test data from environmental fate studies were not located on this substance, EPA has predicted its
behavior in the environment based upon physical-chemical properties and data on structurally similar
chemicals. To enable a reasoned evaluation of the human health and environmental effects of the
Premanufacture Notice (PMN) substance and potential degradation products, EPA requires the
manufacturer to provide test data on this substance using the OPPTS 835.4400 test guideline on anaerobic
metabolism in aquatic sediment 24 months from commencement of manufacture or prior to a confidential
production volume, whichever comes later. EPA and the manufacturer are also negotiating additional
requirements for toxicity and environmental fate testing.
4-243
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Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Water
Aerobic Biodegradation
Not readily degradable (Measured)
0% degraded/biochemical oxygen demand
after 28 days; activated sludge ready
biodegradability test;
Method Relating to New Chemical
Substances - Biodegradability Test of
Chemical Substances by Microorganisms
Yakushokuhatsu 0331 No. 7, Heisei
23.0329
c- Seikyoku No. 5, Kanpokihatsu No.
110331009
Submitted confidential study
Study performed according to a
standardized method.
Not readily degradable (Measured)
0% degraded/C02 evolution after 28 days;
Submitted confidential study
Study performed according to a
standardized method.
Method designed to be compatible with
OECD301B
Toxicity of the test material to a mixed
population of activated sewage sludge
microorganisms was determined:
Submitted confidential study
Supporting information provided in
study performed according to a
standardized method.
EC50 >1000 mg/L after 3-hours
NOEC = 1000 mg/L after 3 hours
(Measured)
According to OECD 209, method C. 11 of
EC No. 440/2008 and US EPA Draft
Ecological Effects Test Guidelines OPPTS
850.6800
Recalcitrant (Estimated)
Professional judgment
High MW solids are expected to be
non-biodegradable due to their limited
bioavailability.
Volatilization Half-life for
Model River
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law constant.
4-244
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Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Volatilization Half-life for
Model Lake
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law constant.
Soil
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment
High MW solids are expected to be
nonbiodegradable due to their limited
bioavailability.
Anaerobic
Biodegradation
Recalcitrant (Estimated)
Professional judgment
High MW solids are expected to be
resistant to removal under anoxic
conditions biodegradable due to their
limited bioavailability.
Soil Biodegradation w/
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
Not a significant fate process (Estimated)
Professional judgment
This chemical is expected to exist in
the particulate phase in the
atmosphere.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Professional judgment
The bromine substituent is susceptible
to photolysis however; this is
expected to be a relatively slow
process and is not anticipated to lead
to ultimate removal of the material.
Hydrolysis
>1 year (Estimated)
Professional judgment
Given the limited solubility estimated
for this material, hydrolysis is not
anticipated to occur to an appreciable
extent.
4-245
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Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Environmental Half-Life
>180 days (Estimated)
Professional judgment
The substance has a MW greater than
1,000 and is not anticipated to be
assimilated by microorganisms.
Therefore, biodegradation is not
expected to be an important removal
process. It is also not expected to be
readily removed by other degradative
processes under environmental
conditions because of limited water
solubility and lack of reactive
functional groups.
Bioaccumulation
HIGH: The bioaccumulation designation for this compound is based upon physical-chemical properties and
by analogy to structurally similar chemicals. As test data regarding bioaccumulation were not located on this
substance, the potential for bioconcentration or bioaccumulation is uncertain. To enable a reasoned
evaluation of the human health and environmental effects of the PMN substance and potential degradation
products, EPA requires the manufacturer to provide test data on this substance using the OECD 305 test
guideline for bioaccumulation in fish with dietary exposure, 36 months from commencement of manufacture
or prior to attaining a confidential production volume, whichever comes later. Although this substance is
large and insoluble in water, its structure and potential for debromination suggest it could be bioavailable
with potential to accumulate, therefore a high hazard designation is applied conservatively.
Fish BCF
<100 (Estimated)
Professional judgment
The substance has a MW >1,000 and
is not anticipated to be assimilated by
aquatic organisms; therefore,
bioconcentration is not expected.
BAF
Potential for bioaccumulation using
criteria for a conservative approach
(Estimated)
Professional judgment
This compound is outside the MW
domain of the corresponding EPI
models. The potential for
bioaccumulation is based on analogy
to a structurally similar confidential
analog.
Metabolism in Fish
No data located.
4-246
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Brominated Poly(phenylether)
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-247
-------
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
January 16, 2012).
ESIS (European chemical Substances Information System) Classification, labeling and packaging of dangerous substances annex VI
to Regulation (EC) No 1272/2008 [Online] http://esis.irc.ec.europa.eu/index.php?PGM=cla (accessed on accessed on January 16,
2012).
EPA. (1997). "Polymer Exemption Guidance Manual." Retrieved December 18, 2013, from
http://www.epa.gov/oppt/newchems/pubs/polyguid.pdf.
EPA (U.S. Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing
Data. U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
EPA. 2004. The Pollution Prevention (P2) Framework, EPA-748-B-03-001. Office of Pollution Prevention and Toxics 7403M, U.S.
Environmental Protection Agency, Washington, DC. 20460. October 2003 version updated in January 2004. Latest version available
at http://www.epa.gov/opptintr/newchems/pubs/sustainable/p2frame-iune05a2.pdf
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Brominated Polystyrene
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Brominated Polystyrene
88497-56-7
L
L
L
L
L
L
Ld
L
L
L
L
L
VH
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-249
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Brominated Polystyrene
J\.Br
V
Br
Representative Structure
CASRN: 88497-56-7
MW: 80,000 - 800,000 (Measured);
0%< 1,000
MF: (C8H8 mBrm)n
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: This polymer with MW >1,000 and no low MW components is not amenable to SMILES notation.
Synonyms: Benzene, ethenyl-, homopolymer, brominated; Brominated ethenylbenzene homopolymer; Firemaster BP-411; Firemaster CP-44HF; FR-803P;
Polystyrene, brominated; Pyro-Chek 68PB/BC; Saytex HP-775; Saytex HP-3010; Saytex HP-7010P; Saytex HP-7010G; Saytex HP-3010. Related trade name: PDBS
80 (CASRN 148993-99-1).
Chemical Considerations: This alternative is a high MW polymer. The number and locations of the bromines on the phenyl rings are unspecified and expected to be
a variable mixture of mono, di, tri and tetra brominated materials. The ratio of m and n in the MF (C8H8.mBrm)n are product specific; although bromine content of 66-
68% (m = 2.6-2.7) are typical (Mack, 2004). These high MW oligomers were assessed together using information contained in the literature concerning polymer
assessment and professional judgment (Boethling et al., 1997). Closely related materials are indicated in the analog section.
Polymeric: Yes
Oligomers: The general formula for this polymer is (C8H8.mBrm)n and the average MW is 80,000 to 800,000 daltons (NICNAS, 2001) with oligomers MW <1,000 not
expected.
Metabolites, Degradates and Transformation Products: None
Analog: Tribrominated polystyrene (CASRN 57137-10-7); Benzene, ethenyl-, ar-
bromo derivs., homopolymers (CASRN 148993-99-1)
Endpoint(s) using analog values: Decomposition
Analog Structures:
Br Br
Representative Structure
CASRN 57137-10-7 CASRN 148993-99-1
4-250
-------
Structural Alerts: None identified
Risk Phrases: Not classified by Annex I Directive 67/548/European Economic Community & IUCLID (Pakalin et al., 2007).
Hazard and Risk Assessments: None identified
4-251
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Brominated Polystyrene CASRN 88497-56-7
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
195 (glass transition temperature)
(Measured)
Ioffe and Kampf, 2002
The melting points reported cover a
broad range and are anticipated to be
formulation specific liquid-glass
transition temperature.
130-140 (glass transition temperature)
(Measured)
Ioffe and Kampf, 2002
Boiling Point (°C)
Decomposes (Estimated by analogy)
Professional judgment
Based on data from 148993-99-1.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value for large, high MW
polymers.
Water Solubility (g/L)
<10"6 (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value for large, high MW non-
ionic polymers.
Log Kow
No data located; polymers with a MW
>1,000 are outside the domain of the
available estimation methods.
Flammability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No data located; based on its use as a
flame retardant.
Pyrolysis
No data located.
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
4-252
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Brominated Polystyrene CASRN 88497-56-7
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
There is no absorption expected for any route of exposure. This polymer is large, with a MW >1,000. It is
expected to have limited bioavailability and therefore is not expected to be readily absorbed, distributed or
metabolized in the body.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
No absorption is expected for any route of
exposure
(Estimated)
Professional judgment
Estimated based on professional
judgment.
Acute Mammalian r
oxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have lim
of low potential for acute mammalian toxicity as confirmed by the availab
ited bioavailability and therefore is
e data.
Acute Lethality
Oral
Rat Oral LD50 >15,380 mg/kg
Industrial Bio-Test Laboratories,
1977b
Guideline study.
Dermal
Rabbit Dermal LD50 >3,038 mg/kg
Industrial Bio-Test Laboratories,
1977a
Guideline study.
Inhalation
Rat Inhalation (dust) 4-hour LC50 >5.25
mg/L
No gross tissue changes were observed
(a mean aerodynamic diameter of 3.8 ±
1.97 microns)
Springborn Labs Inc., 1991
Guideline study.
Carcinogenicity
LOW: This polymer is large, with a MW >1,000. Based on professional judgment, It is expected to have few to
no residual monomers. Additionally, crosslinking, swellability, dispersability, reactive functional groups,
inhalation potential, and hindered amine groups are not expected. Therefore there is low potential for
carcinogenicity. No data located.
OncoLogic Results
Limited bioavailability expected;
crosslinking, swellability, dispersability,
reactive functional groups, inhalation
potential, and hindered amine groups are
not expected.
(Estimated)
Professional judgment; Boethling
etal., 1997
Based on cutoff values for large high
MW polymers.
Carcinogenicity (Rat and
Mouse)
Combined Chronic
Toxicity/ Carcinogenicity
4-253
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Brominated Polystyrene CASRN 88497-56-7
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Genotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore has
low potential for genotoxicity. In vitro Ames test is negative for gene mutations.
Gene Mutation in vitro
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
etal., 1997
Based on cutoff values for large high
MW polymers.
Negative for gene mutations in Salmonella
typhimurium strains TA1535, TA1537,
TA1538, TA100, and TA98 with and
without exogenous metabolic activation
Microbiological Associates, 1978
Guideline study.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
No data located.
Chromosomal
Aberrations in vivo
No data located.
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
Reproductive Effects
LOW: This polymer is large, with a MW
a low potential for reproductive effects. >
>1,000. It is expected to have limited bioavailability and therefore has
o data located.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
etal., 1997
Based on cutoff values for large high
MW polymers.
Combined Repeated
Dose with Reproduction/
Developmental Toxicity
Screen
Reproduction and
Fertility Effects
Developmental Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore has
a low potential for developmental effects. No data located.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
etal., 1997
Based on cutoff values for large high
MW polymers.
4-254
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Brominated Polystyrene CASRN 88497-56-7
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Combined Repeated
Dose with Reproduction/
Developmental Toxicity
Screen
Prenatal Development
Postnatal Development
Neurotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore has
a low potential for neurotoxicity. No data located.
Neurotoxicity Screening
Battery (Adult)
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
etal., 1997
Based on cutoff values for large high
MW polymers.
Repeated Dose Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have lim
because the MWn is >10,000, there is the possibility of lung overloading if
respirable range as a result of dust forming operations. No experimental t
ited bioavailability; however,
>5% of the particles are in the
ata located.
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
etal., 1997
Based on cutoff values for large high
MW polymers.
This polymer MWn is >10,000; potential
for irreversible lung damage as a result of
lung overloading (Estimated by analogy)
Professional judgment; Boethling
etal., 1997
Based on cutoff values for large high
MW polymers.
Skin Sensitization
LOW: Estimated not to have potential for skin sensitization based on expert judgment. No data located.
Skin Sensitization
Not expected to be a skin sensitizer
(Estimated)
Expert judgment
Estimated based on expert judgment.
Respiratory Sensitization
No data located.
Respiratory Sensitization
No data located.
Eye Irritation
LOW: Brominated polystyrene is a mild eye irritant in rabbits; irritation begins to clear within 24 hours and is
completely cleared within 48 hours.
Eye Irritation
Minimally irritating, rabbit clearing within
24 hours
Industrial Bio-Test Laboratories,
1977b
Adequate, guideline study.
Dermal Irritation
LOW: Estimated not to have potential for dermal irritation. Available experimental data are inadequate to
make a hazard designation for this endpoint.
Dermal Irritation
Not expected to be a skin irritant
(Estimated)
Expert judgment
Estimated based on expert judgment.
4-255
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Brominated Polystyrene CASRN 88497-56-7
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Moderately irritating, rabbit. Skin reactions
characterized by pale red to red, well-
defined erythema and moderate to severe
edema that subsided by 7 days. Slight
desquamation at test skin site at 14 days.
(Test substance was administered as a fine
powder in a slurry containing 1.0% aqueous
methylcellulose)
Industrial Bio-Test Laboratories,
1977a
Result likely due to the presence of an
impurity.
Endocrine Activity
This polymer is large, with a MW >1,000. It is not expected to have endocrine activity due to its poor
bioavailability and inability to readily metabolize in the body. No data located.
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
etal., 1997
Based on cutoff values for large high
MW polymers.
Immunotoxicity
This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore has a low
potential for immunotoxicity. No data located.
Immune System Effects
Limited bioavailability expected
(Estimated)
Professional judgment; Boethling
etal., 1997
Based on cutoff values for large high
MW polymers.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
LOW: Non-ionic polymers with a MW >1,000 that do not contain reactive functional groups and are
comprised of minimal low MW oligomers. These polymers display no effects at saturation (NES) because the
amount dissolved in water is not anticipated to reach a concentration at which adverse effects may be
expressed. Bioavailability is limited because this chemical cannot be absorbed through membranes due to large
size.
Fish LC50
Fish (Orizias latipes) 48-hour TLm >500
mg/L (Experimental)
Nissan Ferro Organic Chem Inc,
1990
Inadequate; Organisation of Economic
Cooperation and Development
(OECD) guidelines recommend study
duration of 96-hours for this endpoint.
Units are not applicable to screening
methodology.
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
4-256
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Brominated Polystyrene CASRN 88497-56-7
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid LCS0
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Green Algae ECS0
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Chronic Aquatic Toxicity
LOW: Brominated polystyrene is comprised of non-ionic polymers with a MW >1,000 that do not contain
reactive functional groups and are comprised of minimal low MW oligomers. These polymers display NES
because the amount dissolved in water is not anticipated to reach a concentration at which adverse effects may
be expressed. Bioavailability is limited because this chemical cannot be absorbed through membranes due to
large size.
Fish ChV
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Daphnid ChV
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
Green Algae ChV
NES
Professional judgment
The large MW, limited bioavailability
and low water solubility suggest there
will be NES.
ENVIRONMENTAL FATE
Transport
The estimated negligible water solubility and estimated negligible vapor pressure indicate that this polymer is
anticipated to partition predominantly to soil and sediment. The estimated Henry's Law Constant of <10"8
atm-m3/mole indicates that it is not expected to volatilize from water to the atmosphere. The estimated Koc of
>30,000 indicates that it is not anticipated to migrate from soil into groundwater and also has the potential to
adsorb to sediment.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment; Boethling
etal., 1997
High MW polymers are expected to
have low vapor pressure and are not
expected to undergo volatilization.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
Professional judgment Boethling
etal., 1997
Cutoff value used for large, high MW
polymers. High MW polymers are
expected to adsorb strongly to soil and
sediment.
4-257
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Brominated Polystyrene CASRN 88497-56-7
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Level III Fugacity Model
No data located.
Persistence
VERY HIGH: This polymer is large, with a MW >1,000. It is expected to have negligible water solubility and
poor bioavailability to microorganisms indicating that neither biodegradation nor hydrolysis are expected to
be important removal processes in the environment. Although photodegradation of brominated polystyrenes
has been observed, this process is not anticipated to lead to ultimate removal of the material. As a result, a
half-life for this high MW polymer of >180 days leads to the potential for very high persistence.
Water
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment; Boethling
etal., 1997
High MW polymers are expected to be
non-biodegradable.
Volatilization Half-life
for Model River
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Volatilization Half-life
for Model Lake
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Soil
Aerobic Biodegradation
No data located.
Anaerobic
Biodegradation
No data located.
Soil Biodegradation with
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
No data located.
Reactivity
Photolysis
Photodegradation observed based on a
decreased MW of brominated polystyrene
(Measured)
Kaeriyama et al., 1972
The bromine substituent is susceptible
to photolysis; however, this is
expected to be a relatively slow
process for brominated polystyrene
and is not anticipated to lead to
ultimate removal of the material.
Hydrolysis
>1 year (Estimated)
Professional judgment
Given the limited solubility estimated
for this material, hydrolysis is not
anticipated to occur to an appreciable
extent.
4-258
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Brominated Polystyrene CASRN 88497-56-7
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Environmental Half-life
>180 days (Estimated)
Professional judgment
The substance has a MW >1,000 and
is not anticipated to be assimilated by
microorganisms. Therefore,
biodegradation is not expected to be
an important removal process. Other
degradative processes under
environmental conditions are also not
anticipated.
Bioaccumulation
LOW: Due to the large size and water insolubility of this high MW polymer, it is of low potential for
bioconcentration or bioaccumulation.
Fish BCF
<100 (Estimated)
Professional judgment; Boethling
etal., 1997
Cutoff value for large, high MW,
insoluble polymers.
BAF
No data located.
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-259
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Boethling, Robert S. and Nabholz, J. Vincent "Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act",
pp. 187-234, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs, Hamilton, John D.
and Sutcliffe, Roger (eds.), (1997) Van Nostrand Reinhold.
CDC (Centers for Disease Control and Prevention). (2011). Fourth national report on human exposure to environmental chemicals,
updated tables. Department of Health and Human Services.
Industrial Bio-Test Laboratories Inc. (1977a). Report to Ferro Corporation, Acute dermal toxicity study with JM-631 in Albino
rabbits. EPA Document No. 86-900000142. FicheNo. OTSQ522213.
Industrial Bio-Test Laboratories Inc. (1977b). Report to Ferro Corporation, Acute toxicity studies with Jm-631. EPA Document No.
86-900000140. FicheNo. OTSQ522211.
Ioffe, D. and A. Kampf (2002). Bromine - Organic Compounds. Kirk-Othmer Encyclopedia of Chemical Technology, Wiley-
Interscience.
Kaeriyama, K., Y. Shimura, et al. (1972). "Photodegradation of brominated polystyrene." J. Appl. Polym. Sci. 16(11): 3035-3038.
Mack, A. G. (2004). Flame Retardants, Halogenated. Kirk-Othmer Encyclopedia of Chemical Technology., Wiley-Interscience.
Microbiological Associates (1978). Report to Ferro Corporation, Activity of JM-631 in the Salmonella/Microsomal assay for bacterial
mutagenicity. EPA Document No. 86-90000014. FicheNo. OTSQ522214.
Nissan Ferro Organic Chem Inc. (1990). Toxic level test and bioaccumulation test with brominated polystyrene (Sample $S-346) in
fish with test data. EPA Document No. 86-900000145. FicheNo. OTSQ522216.
Pakalin, S., T. Cole, et al. (2007). Review on production processes of decabromodiphenyl ether (DECABDE) used in Polymeric
applications in electrical and electronic equipment, and assessment of the availability of potential alternatives to DECABDE.
European Commission Joint Research Centre.
Springborn Labs Inc. (1991). Acute inhalation toxicity study in rats with Pyro-Chek LM (amended final report). EPA Document No.
86-910000862. FicheNo. QTS0530450.
4-260
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Decabromodiphenyl Ethane
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
§ Based on analogy to experimental data for a structural similar compound.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Decabromodiphenyl Ethane
84852-53-9
L
L
L
ifi
L
L
L
VL
VL
L
L
VH
H
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants that
may partition to sediment and particulates.
4-261
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Decabromodiphenyl Ethane
Br
Br BrY'W'"Br
Br '"-js """Br Br
Br
CASRN: 84852-53-9
MW: 971.2
MF: C14H4Br10
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: c 1 (Br)c(Br)c(Br)c(Br)c(Br)c 1 CCc 1 c(Br)c(Br)c(Br)c(Br)c 1 Br
Synonyms: Benzene, l,l'-(l,2-ethanediyl)bis[2,3,4,5,6-pentabromo-]; l,l'-(l,2-Ethanediyl) bis[2,3,4,5,6-pentabromo-benzene]; Ethane l,2-(bispentabromophenyl);
EBP; Bis(pentabromophenyl) ethane; l,l'-(ethane-l,2-diyl)bis[pentabromobenzene]; Decabromodiphenyl ethane; DBDP-Ethane; DBDPE; DBDiPhEt; DBDE; EBPE;
DeBrPylE; Saytex 8010; Firemaster 2100
Chemical Considerations: This is a discrete organic chemical with a MW <1,000. EPI v 4.0 was used to estimate physical/chemical and environmental fate values
due to an absence of experimental data. Measured values from experimental studies were incorporated into the estimations.
Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: Photodegradation - potential to form lower brominated congeners (Wang et al., 2010)
Analog: Decabromodiphenyl ether (decaBDE), confidential analogs
Endpoint(s) using analog values: Carcinogenicity; developmental toxicity;
neurotoxicity; absorption, distribution, metabolism & excretion
Analog Structure: Br Br
r^Br
Br^V^Br Br^Y^^Br
Br Br
DecaBDE
(1163-19-5)
Structural Alerts: Immunotoxicity, polyhalogenated aromatic hydrocarbons (EPA, 2011); test data are available to address this category.
Risk Phrases: Not classified by Annex I Directive 67/548/European Economic Community & IUCLID (Pakalin et al., 2007).
Hazard and Risk Assessments: An environmental risk evaluation report was completed by the UK government Environment Agency (Dungey et al., 2007).
4-262
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
350 (Measured)
Mack, 2004
Adequate.
Boiling Point (°C)
>350 (Estimated)
Professional judgment
Based on the reported experimental
melting point value.
Vapor Pressure (mm Hg)
<7.5 xlO"7 (Measured)
Hardy, 2004
Adequate.
Water Solubility (mg/L)
7.2xl0~4 (Measured)
Hardy, 2004
Adequate.
Log Kow
14 (Estimated)
EPI; EPA, 1999
Estimated value is greater than the
cutoff value, >10, according to
methodology based on HPV
assessment guidance.
3.55
According to column elution method
OPPTS 830.7560. The concentration in the
water phase was very close to the
measured water solubility. It was noted
that a higher stock solution concentration
could have led to a higher K0w value using
this technique. (Measured)
Pakalin et al., 2007 and Dungey
et al., 2007
The value was reported in a
secondary source and was obtained
using a guideline study, however, it is
considered unreliable based on
comparison to other substances that
contain multiple bromine atoms.
Flammability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Pyrolysis
No data located.
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
4-263
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
Decabromodiphenyl ethane, as a neat material, is estimated to not be absorbed through the skin and to have
poor skin absorption when in solution. Decabromodiphenyl ethane is expected to have poor absorption via
the lungs and gastrointestinal (GI) tract. Decabromodiphenyl ethane is poorly absorbed in the GI tract
following oral exposure and is mainly excreted in the feces. If absorption does occur, decabromodiphenyl
ethane is distributed to the serum, liver, kidney, and adipose tissues and undergoes biotransformation to
form metabolites.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
Not absorbed through the skin as the neat
material; poor absorption through skin if
in solution; poor absorption from the
lung and GI tract.
(Estimated by analogy)
Professional judgment
Based on closely related
confidential analogs with similar
structures, functional groups, and
physical/chemical properties.
In an acute (single dose) oral study in
rats, decabromodiphenyl ethane was
poorly absorbed (if at all) in the GI tract
and was excreted in the feces. There
were no detectable levels of
decabromodiphenyl ethane in bile, blood
or urine. This finding is consistent with
the poor solubility and the MW of
decabromodiphenyl ethane.
Hardy, 2004
Guideline study (performed
according to good laboratory
practice (GLP)); reported in a
secondary source; test substance:
Saytex 8010.
Rats, single oral (gavage) dose of 100
mg/kg-day of unlabeled and 14C-labeled
decabromodiphenyl ethane; tissues, bile
and feces and urine were assayed for
radiochemical content.
In one group of rats that were euthanized
168 hours post dosing, 89% of
radioactive content was recovered in the
feces with none in urine; radioactivity in
tissues were generally below the limit of
detection with <0.2% of the dose found
Black, 2012
Unpublished study; the study
suggests decabromodiphenyl ethane
is poorly absorbed by the oral route.
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
in tissues.
In another group of rats assayed 8-24
hours post-dosing by bile duct
annulation, no bile samples had
increased levels of radioactivity
compared to controls.
A group of jugular catheterized rats
assayed at 0.25, 0.5, 1, 2, 6, 12, 24, 48,
and 72 hours found that levels of
radioactive content in blood and plasma
were below the limit of detection at all
time points; tissues from rats sacrificed
at 2, 24, and 72 hours post exposure
found the majority of radioactivity in the
GI tract through 24 hours with no
radioactivity found by 72 hours post
exposure; it was presumed to have been
excreted in the feces.
Rats, 90-day oral exposure;
decabromodiphenyl ethane was found to
be distributed to all tissues examined
(serum, liver, kidney, and adipose);
biotransformation occurred in rats,
though debromination to lower
brominated bromodiphenyl ethanes was
not the primary metabolic pathway;
proposed metabolites were identified as
MeS02-nona-BDPE and EtS02-nona
BDPE
Wang et al., 2010
The study suggests
decabromodiphenyl ethane is
absorbed by the oral route and
biotransformation occurred.
4-265
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Acute Mammalian Toxicity
LOW: Based on a rat oral LDS0 of >5,000 mg/kg and a rabbit dermal LDS0 of >2,000 mg/kg. No acute
inhalation hazard data located.
Acute Lethality
Oral
Rat oral LD50 >5,000 mg/kg
Hardy et al., 2002; Hardy, 2004
Guideline study; test substance:
Saytex 8010.
Dermal
Rabbit dermal LD50 >2,000 mg/kg
Hardy et al., 2002; Hardy, 2004
Guideline study, reported in a
secondary source; test substance:
Saytex 8010.
Inhalation
No data located.
Carcinogenicity
MODERATE: Potential for carcinogenicity based on analogy to decaBD
experimental carcinogenicity data for exposure to decabromodiphenyl et
L and professional judgment. No
lane was located.
OncoLogic Results
Structure could not be evaluated by
OncoLogic.
Carcinogenicity (Rat
and Mouse)
Potential for carcinogenicity; increased
incidence of neoplastic nodules of the
liver in rats; equivocal evidence of
increased incidences of hepatocellular
adenomas or carcinomas and thyroid
gland follicular cell adenomas or
carcinomas in male mice.
(Estimated by analogy)
Professional judgment
Estimated based on the high
potential for bioaccumulation and
by analogy to decaBDE which
resulted in potential carcinogenic
effects following chronic exposure
in a National Toxicology Program
study.
Combined Chronic
Toxicity/
Carcinogenicity
No data located.
4-266
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Genotoxicity
LOW: Based on negative experimental results for gene mutations in Salmonella and chromosomal
aberrations in Chinese hamster ovary (CHO) cells.
Gene Mutation in vitro
Negative for gene mutations in
Salmonella typhimurium strains TA98,
TA100, TA1535, TA1537 and
Escherichia coli WP2 uvrA with and
without exogenous metabolic activation.
Hardy et al., 2002; Hardy, 2004
Guideline study (according to
Japanese Ministry of International
Trade and Industry (MITI) and GLP
guidelines), reported in a secondary
source; test substance: Saytex 8010.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
Negative for chromosomal aberrations in
CHO cells with and without metabolic
activation.
Hardy et al., 2002; Hardy, 2004
Guideline study (according to MITI
and GLP guidelines), reported in a
secondary source; test substance:
Saytex 8010.
Chromosomal
Aberrations in vivo
No data located.
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
Reproductive Effects
LOW: The located data suggest no reproductive effects based on a NOEL for maternal and fetal toxicity of
>1,250 mg/kg/day in rats and rabbits. However, there is uncertainty in this hazard designation because the
exposure was of subchronic (gestational) duration and the studies were not experimentally designed as a
reproduction toxicity screen or combined repeated dose/reproduction/developmental toxicity screen.
Reproduction/
Developmental Toxicity
Screen
No data located.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
4-267
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproduction and
Fertility Effects
There was no evidence of treatment-
related adverse effects on the
reproductive system in two
developmental toxicity studies in rats
and rabbits.
NOEL (maternal and fetal) >1,250
mg/kg/day (highest dose tested)
LOEL: not established
Hardy, 2004, Hardy et al., 2010
Guideline study (according to US
Toxic Substances Control Act
(TSCA) Guidelines and GLP)
reported in a secondary source; test
substance: Saytex 8010.
Developmental Effects
HIGH: Estimated to be High for developmental neurotoxicity based on analogy to decaBDE. There were no
maternal or fetal toxicity effects in rats or rabbits exposed during gestation to doses up to 1,250 mg/kg/day
decabromodiphenyl ethane. Some rodent developmental neurotoxicity studies of the analog decaBDE
indicate adverse effects for the neurodevelopmental endpoint. There were no developmental neurotoxicity
studies located for decabromodiphenyl ethane. Due to the analogous properties of decaBDE and
decabromodiphenyl ethane, neurodevelopmental toxicity is predicted.
Reproduction/
Developmental Toxicity
Screen
No data located.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
Prenatal Development
In two developmental oral gavage
studies in mated female rats (gestation
days (GD) 6-15) and rabbits (GD 6-18),
there were no treatment-related fetal
malformations or developmental
variations. No maternal toxicity was
evident.
NOEL (maternal and fetal)
>1,250 mg/kg/day (highest dose tested)
LOEL: Not established
Hardy et al., 2002; Hardy,
2004; Hardy et al., 2010
Guideline study (according to US
TSCA Guidelines and GLP)
reported in a secondary source; test
substance: Saytex 8010.
4-268
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Postnatal
Development/Developm
ental Neurotoxicity
Evaluation of locomotor activity in
C57BL6/J mice.
NOAEL: not established
LOAEL: 6 mg/kg-day (based on
decreased T4 levels in male mice and
effects on locomotor
(Estimated by analogy)
EPA, 2008; Washington DOE,
2008; Professional judgment
Estimated based on analogy to
decaBDE; study details reported in
a secondary source.
Single dose gavage in male Sprague
Dawley rats;
NOAEL: Not established
LOAEL: 6.7 mg/kg (Dose-related
disruption in habituation [changes in
locomotion, rearing, total activity] at
both doses).
EPA, 2008; Professional
judgment
Estimated based on analogy to
decaBDE; each dose administered a
single time; not a guideline study.
Study details reported in a
secondary source.
(Estimated by analogy)
NMRI male mice gavaged with
decaBDE (99% pure) at 0, 2.22, or 20.1
mg/kg on PNDs3-19 or 0, 1.34, 13.4 or
20.1 mg/kg on PND10.
Dose-related disruption in habituation
(changes in locomotion, rearing, total
activity) at 2, 4, and 6 months following
exposure to 20.1 mg/kg on PND3.
European Chemicals Bureau
2002; EPA, 2008; Professional
judgment
Estimated based on analogy to
decaBDE; each dose administered a
single time; not a guideline study.
Study details reported in a
secondary source.
NOAEL: 2.22 mg/kg
LOAEL: 20.1 mg/kg
(Estimated by analogy)
4-269
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Neurotoxicity
LOW: There were no adult neurotoxicity studies of decabromodiphenyl ethane located. Developmental
neurotoxicity is associated with the analog decaBDE, but does not directly trigger a hazard potential for
adult neurotoxicity. There is no reported evidence to support a potential for hazard for adult neurotoxicity
for this compound or analogous highly brominated compounds.
Neurotoxicity Screening
Battery (Adult)
Low potential for neurological effects.
(Estimated)
Professional judgment
Estimated based on the absence of
structural alerts that have been
[experimentally] associated with the
adult neurotoxicity endpoint.
Repeated Dose Effects
LOW: Based on a NOAEL and LOAEL of >1,000 mg/kg/day in 28 and 90-day oral rat studies, respectively.
Experimental data for decabromodiphenyl ethane reported increased liver weights associated with minimal
and transient hepatocellular vacuolization following a 90-day oral exposure. The increase in liver weights
was associated with minimal to slight hepatocellular vacuolation, which had no long-term effect and was
resolved after a 28-day recovery period at the highest doses tested (1,000 mg/kg/day). A LOAEL was not
established in the 28-day study, as the highest doses tested did not produce adverse effects.
In a 28-day oral gavage study in rats,
there was no mortality or clinical signs
of toxicity, and no treatment-related
statistically significant effects for
changes in body weight, food
consumption, body weight gain,
hematology, serum chemistry, urinalysis,
gross necropsy, relative and absolute
organ weight, or histopathology.
Hardy, 2004
Guideline study (according to US
TSCA Guidelines and GLP),
reported in a secondary source
Organisation for Economic
Cooperation and Development
(OECD) 407; test substance: Saytex
8010.
NOAEL >1,250 mg/kg/day (highest dose
tested)
LOAEL: not established
4-270
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
In a 90-day oral gavage study in rats,
there was no mortality, clinical or
systemic signs of toxicity or ocular
lesions; no changes in urine or serum
chemistry, hematology, body weight,
body weight gain or food consumption.
Mean liver weights increased in males at
the highest dose tested (but not at lower
doses). Increased liver weight was
associated with minimal to slight
hepatocellular vacuolation and minimal
to slight centrilobular hepatocytomegaly;
liver changes returned to normal after a
28-day recovery period; no changes in
female rat livers. There were no
immunotoxicity effects, noted in a 90-
day oral gavage study in rats.
Hardy et al., 2002; Hardy, 2004
Guideline study (according to US
TSCA Guidelines and GLP),
reported in a secondary source;
OECD 408; test substance: Saytex
8010.
NOAEL >320 mg/kg/day
LOAEL = 1,000 mg/kg/day (highest
dose tested)
In a 90-day oral study in rats, there were
no significant changes in body weight, or
absolute and relative liver and kidney
weights; hepatotoxicity indicated by
changes in serum chemistry including
increased TBA levels, decreased Cr,
AST, and ALP activities; increased
serum T3 thyroid hormone levels;
increased CYP3A2 mRNA expression.
Wang et al., 2010
Only one dose tested; a NOAEL
was not established; no
histopathological assessments were
made on the liver; data are
insufficient to determine a hazard
designation for this endpoint.
LOAEL =100 mg/kg/day (only dose
tested)
4-271
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Skin Sensitization
LOW: Experimental data for decabromodiphenyl ethane were negative for skin sensitization in the guinea
pig.
Skin Sensitization
Negative for skin sensitization, guinea
pigs
Hardy et al., 2002; Hardy, 2004
Guideline study, reported in a
secondary source; test substance:
Saytex 8010.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
VERY LOW: Decabromodiphenyl ethane is not an eye irritant in rabbits.
Eye Irritation
Non-irritant, rabbit
Hardy et al., 2002; Hardy, 2004
Guideline study, reported in a
secondary source; test substance:
Saytex 8010.
Dermal Irritation
VERY LOW: Decabromodiphenyl ethane is not a skin irritant in rabbits.
Dermal Irritation
Non-irritant, rabbit
Hardy et al., 2002; Hardy, 2004
Guideline study, reported in a
secondary source; test substance:
Saytex 8010.
Endocrine Activity
There were limited data located for this endpoint.
90-day oral study in rats; increased
serum T3 thyroid hormone levels; no
effects on thyroxine levels
Wang et al., 2010
Only one dose tested; a NOAEL
was not established, so it is
uncertain where effects would
occur; did not evaluate thyroid
weight, or histopathology.
Immunotoxicity
There were no immunotoxicity effects noted in a 90-day oral gavage study in rats.
Immune System Effects
There were no immunotoxicity effects,
noted in a 90-day oral gavage study in
rats.
Hardy et al., 2002; Hardy, 2004
Guideline study (according to US
TSCA Guidelines and GLP),
reported in a secondary source;
OECD 408; test substance: Saytex
8010.
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ECOTOXICITY
ECOSAR Class
Acute Toxicity
LOW: Experimental values for daphnia and fish, and ECOSAR estimations for green algae and saltwater
invertebrate suggest that decabromodiphenyl ethane exhibits no effects at saturation (NES) and is not
acutely toxic to fish, daphnia or green algae
Fish LC50
Rainbow trout (Oncorhvnchus mykiss)
96-hour LLR50 >110 mg/L (static,
nominal)
(Experimental)
Hardy et al., 2012
The reported value was determined
using a water accommodated
fraction (WAF). According to
OECD guidelines, WAFs should
only be used to determine toxicity
of multi-component substances. As
a result, the reported value is greater
than this material's water solubility.
Fish 96-hour LC50 = 4.29xl0"8 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 14 for this
chemical exceeds the structure
activity relationship (SAR)
limitation for log Kow of 5.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided by
ECOSAR classes that have a more
specific mode of action relative to
narcosis.
4-273
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid LCS0
Daphnia (Daphnia magna) 4 8-hour
LLR50 >110 mg/L (static, nominal)
(Experimental)
Hardy et al., 2012
The reported value was determined
using a WAF. According to OECD
guidelines, WAFs should only be
used to determine toxicity of multi-
component substances. As a result,
the reported value is greater than
this material's water solubility.
Daphnia (Daphnia magna) 48-hour EC50
= 19 pg/L (0.019 mg/L, nominal)
(Experimental)
Nakari and Huhtala, 2010
Although in a guideline study (ISO
6341, 1996), the reported value is
greater than the substance's water
solubility (0.72 pg/L).
Daphnia 48-hour LC50 = 1.35xl0~7 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 14 for this
chemical exceeds the SAR
limitation for log K0„ of 5.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided by
ECOSAR classes that have a more
specific mode of action relative to
narcosis.
Saltwater Invertebrate LCS0
Mysid Shrimp 96-hour LC50 = 28 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 14 for this
chemical exceeds the SAR
limitation for log Kow of 5.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided by
ECOSAR classes that have a more
specific mode of action relative to
4-274
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
narcosis.
Green Algae ECS0
Green Algae (Pseiidokirchneriella
subcapitata) 96-hour EL50 and NOAEL
>110 mg/L (static, nominal)
(Experimental)
Hardy et al., 2012
The reported value was determined
using a WAF. According to OECD
guidelines, WAFs should only be
used to determine toxicity of multi-
component substances. As a result,
the reported value is greater than
this material's water solubility.
Green Algae 96-hour EC5n =
l.OlxlO"5 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 14 for this
chemical exceeds the SAR
limitation for log K0„ of 6.4; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided by
ECOSAR classes that have a more
specific mode of action relative to
narcosis.
4-275
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Chronic Aquatic Toxicity
LOW: Estimated data suggest NES for chronic aquatic toxicity endpoints.
Fish ChV
Zebra fish (Danio rerio) static-renewal
(48-hr renewal intervals) egg-larvae test:
LOEC = 12.5 pg/L (0.0125 mg/L,
nominal) based on mortality of eggs and
hatched larvae;
NOEC <12.5 pg/L (0.0125 mg/L,
nominal)
(Experimental)
Nakari and Huhtala, 2010
Not a standard test for the
determination of hazard for which
emphasis is strongly placed on
whole organism studies; Supporting
information presented in a non-
standard, guideline study (ISO
12890, 1999) with insufficient study
details.
The solvent dimethyl sulfoxide was
used to solubilize test substance into
solution. Non-standard dilution
water was used. Test concentrations
were above the identified water
solubility value (0.72 pg/L).
Fish 30-day ChV = 9.76xl0"9 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 14 for this
chemical exceeds the SAR
limitation for log Kow of 8.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided by
ECOSAR classes that have a more
specific mode of action relative to
narcosis.
Daphnid ChV
Daphnid ChV = 9. 91x10 s mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 14 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
4-276
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided by
ECOSAR classes that have a more
specific mode of action relative to
narcosis.
Saltwater Invertebrate ChV
Mysid Shrimp ChV = 2.91xl014 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 14 for this
chemical exceeds the SAR
limitation for log Kow of 8.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided by
ECOSAR classes that have a more
specific mode of action relative to
narcosis.
Green Algae ChV
Green Algae ChV = 2.68xl0"5 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 14 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided by
ECOSAR classes that have a more
specific mode of action relative to
narcosis.
4-277
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sediment Dwelling Organisms ChV
Midge (Chironmus riparins) 28-day;
there were no treatment-related effects
for mean development times, emergence
rates and development rates.
NOEC = 5,000 mg/kg dry sediment
(highest concentration tested)
LOEC >5,000 mg/L
(Experimental)
Hardy, 2004; Hardy et al., 2012
Adequate, guideline study
(according to OECD, OPPTS and
GLP); the LOEC and NOEC were
determined from visual
interpretation of the concentration-
response-curve and statistical
analysis of the survival/reproduction
and dry weight data.
Oligochaete (Lumbriculus variegates)
28-day; there were no significant
treatment-related effects on mean dry
weight/oligochaete. NOEC = 5,000
mg/kg dry sediment (highest
concentration tested)
LOEC >5,000 mg/L
(Experimental)
Hardy, 2004; Hardy et al., 2012
Adequate, guideline study
(according to OECD, OPPTS and
GLP); the LOEC and NOEC were
determined from visual
interpretation of the concentration-
response-curve and statistical
analysis of the survival/reproduction
and dry weight data.
Earthworm Subchronic Toxicity
Earthworm 2 8-day survival and
reproduction test:
NOEC (survival) = 3,720 mg/kg dry soil
(highest dose tested);
LOEC (reproduction) = 3,720 mg/kg dry
soil;
NOEC (reproduction) = 1,910 mg/kg dry
soil
(Experimental)
Hardy, 2011
Adequate, guideline study
(according to OECD, OPPTS and
GLP).
4-278
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL FATE
Transport
Based on the Level III fugacity models incorporating the located experimental property data,
decabromodiphenyl ethane is expected to partition primarily to soil. Decabromodiphenyl ethane is expected
to be immobile in soil based on its estimated Koc. Leaching of decabromodiphenyl ethane through soil to
groundwater is not expected to be an important transport mechanism. Estimated volatilization half-lives
indicate that it will be non-volatile from surface water. Volatilization from dry surface is also not expected
based on its vapor pressure. In the atmosphere, decabromodiphenyl ethane is expected to exist solely in the
particulate phase, based on its estimated vapor pressure. Particulates may be removed from air by wet or dry
deposition.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
EPI; Professional judgment
Cutoff value for nonvolatile
compounds based on the ionic nature
of the material.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
EPI; EPA, 2004
Cutoff value for nonmobile
compounds.
Level III Fugacity Model
Air = <1%
Water = 4.5%
Soil = 95%
Sediment = <1% (Estimated)
EPI
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Persistence
VERY HIGH: Very high persistence of decabromodiphenyl ethane is expected based on experimental
biodegradation data. Decabromodiphenyl ethane was determined to not be readily biodegradable in a 28-day
MITI test nor was it inherently degradable in a 90-day aerobic sewage/soil test using pre-exposed inoculum.
Decabromodiphenyl ethane is not expected to undergo hydrolysis since it does not contain hydrolysable
functional groups. The atmospheric half-life of decabromodiphenyl ethane is estimated to be 4.5 days,
although it is expected to exist primarily in the particulate phase in air. Laboratory studies have
demonstrated photolysis of decabromodiphenyl ethane, although the rate of this process under environmental
conditions has not been established.
Water
Aerobic Biodegradation
Not inherently biodegradable according to
OECD, 2000 guideline study (Measured).
The decabromodiphenyl ethane treated
bottles evolved an amount of the
theoretical inorganic carbon (ThIC)
equivalent to that of the untreated controls.
Transformation of [14C]-labeled
decabromodiphenyl ethane was not
observed in the 90-d aerobic study.
Hardy, 2004
Adequate, guideline study.
Not readily biodegradable by activated
sewage sludge over 28 days (MITI/OECD
301C Modified MITI)
(Measured)
Hardy, 2004
Adequate, guideline study.
Volatilization Half-life for
Model River
>1 year (Estimated)
EPI
Volatilization Half-life for
Model Lake
>1 year (Estimated)
EPI
Soil
Aerobic Biodegradation
No data located.
Anaerobic
Biodegradation
Not biodegradable by anaerobic sewage
bacteria within 60 days (Measured)
Schaeffer and Mathews, 2011
Adequate nonguideline study.
Soil Biodegradation w/
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Air
Atmospheric Half-life
4.5 days (Estimated)
EPI
Reactivity
Photolysis
Debrominated congeners identified by a
photolytic degradation with a 125W high-
pressure mercury lamp experiment using
GC/EI-MS and GC/ECNI-MS analysis.
(Measured)
Wang et al., 2010
Nonguideline study that demonstrates
the potential for both direct and
indirect photolysis in the
environment. The significance of the
laboratory removal rates under
environmental conditions cannot be
determined.
Hydrolysis
Not a significant fate process (Estimated)
Wolfe and Jeffers, 2000;
Professional judgment
The substance does not contain
functional groups that would be
expected to hydrolyze readily under
environmental conditions.
Environmental Half-Life
>1 year (Estimated)
EPI; PBT Profiler
Half-life estimated for the
predominant compartment, as
determined by EPI and the PBT
Profiler methodology.
Bioaccumulation
HIGH: The bioaccumulation hazard designation is estimated based on decabromodiphenyl ethane monitoring
data reporting detections in many different species including those higher on the food chain. Although the
estimated bioaccumulation factor is low, the persistence of decabromodiphenyl ethane and its detection in
many species from different habitats and trophic levels indicates high potential for bioaccumulation hazard in
aquatic or terrestrial species.
Fish BCF
<2.5 at a concentration of 0.5 mg/L after
8 weeks in carp (Cyprinus cctrpio)
(Measured)
Hardy, 2004
Adequate.
<25 at a concentration of 0.05 mg/L after 8
weeks in carp (Cyprinus cctrpio)
(Measured)
Hardy, 2004
Adequate.
BAF
62 (Estimated)
EPI
Metabolism in Fish
No data located.
4-281
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
Decabromodiphenyl ethane was reported in sludge, sediment, and collected from 2001-2002 (Kierkegaard, 2004).
Decabromodiphenyl ethane was reported in ambient air samples (Egeback, 2012), air around the Great Lakes
(Venier, 2008) and house dust (Karlsson, 2007; Ali, 2011; Stapleton, 2008; Harrad, 2008, Dirtu, 2011; Takigami,
2009; Dodson et al., 2012).The presence of decabromodiphenyl ethane was reported in Swedish lake sediment
(Ricklund et al., 2010). The presence of decabromodiphenyl ethane in sludge from countries worldwide (Ricklund et
al., 2008). A review article by Betts (2009) refers to a number of articles reporting decabromodiphenyl ethane in the
environment.
Ecological Biomonitoring
Decabromodiphenyl ethane was detected in walleye (5 samples), emerald shiner (5 samples), goldeye (3 samples),
white sucker (5 samples), and burbot (5 samples) from Lake Winnipeg, Canada at concentrations that ranged from
below the detection limit up to 2.71 (mean 1.01), 1.51 (mean 0.30), 1.63 (mean 0.62), 0.24 (mean 0.08), and 3.30
(mean 0.66) ng/g lipid weight, respectively. Decabromodiphenyl ethane was found in various tissues of 21 of 26
captive giant and red pandas from China with concentrations ranging from not detected to 863 ng/g lipid weight
(87% detection frequency) and not detected to 40.9 ng/g lipid weight (71% detection frequency), respectively, where
the limit of detection was 0.053-2.49 ng/g. In wild water birds from China's Pearl River Delta, decabromodiphenyl
ethane was detected in the muscle of 28 of 29 birds. It was detected in white-breasted water hen (n=l 1), slaty-
breasted rail (n=5), ruddy-breasted crake (n=5), Chinese-pond heron (n=5), and common snipe (n=3) at
concentrations ranging from not detected to 220, 5-62, 4-16, 33-800, and 29-110 ng/g lipid weight, respectively.
Decabromodiphenyl ethane was detected in 54% of eggs sampled of five species of wild aquatic birds, one species
of wild terrestrial bird, and two species of captive birds collected from North China in 2008. Detected concentrations
(ng/g lipid weight) in the eggs ranged from not detected (nd) to 0.9 in Saunders gull (n=12), nd-0.1 in common tern
(n=9), nd-0.9 in Kentish plover (n=8), 0.3-2.2 in black-winged stilt (n=6), 0.4-0.7 in common coot (n=4), 0.9-2.4 in
ring-necked pheasant (n=4), 0.1-1.0 in mallard (n=l 1), and nd-1.7 in swan goose (n=9). Pools of eggs from seven
colonies of herring gulls from the Laurentian Great Lakes of North America collected between 1982 and 2006 were
analyzed and decabromodiphenyl ethane was detected in two out of seven pools showing concentrations at 9.3 and
44 ng/g w.w. The occurrence and concentrations of decabromodiphenyl ethane detected in herring gull eggs
collected from the Great Lakes increased from 2004 to 2006. From 2004 to 2006, the eggs contained concentrations
ranging from 13 to about 200 ng/g, lipid weight. In 2005, concentrations were up to 2880 ng/g at two locations of
Lakes Michigan and Huron. In a study of 25 peregrine falcon eggs from Canada and Spain, decabromodiphenyl
ethane was detected once at 8.2 ng/g fat (LOD = 1.1 ng/g fat, LOQ = 5.2 ng/g fat). Six pooled samples of juvenile
common sole from three nursery zones along the French Atlantic coast collected in 2003 and 2004 contained
decabromodiphenyl ethane concentrations ranging from 0.18 to 3.90 ng/g fat. In a further study, muscle and liver of
the same species (common sole) collected in 2007, 2008 and 2009 from the same three nursery zones plus an
4-282
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Decabromodiphenyl Ethane CASRN 84852-53-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
additional one contained mean concentrations in sole muscle samples ranging from 0.9 to 1.9 pg/g w.w. (or from
0.28 to 1.13 ng/g fat), and from
-------
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4-285
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Decabromodiphenyl Ether
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Decabromodiphenyl Ether
1163-19-5
L
L
L
L
L
L
L
L
L
VH
H
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
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Decabromodiphenyl Ether
CASRN: 1163-19-5
MW: 959.2
MF: C12Br10O
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: 0(clc(c(c(c(clBr)Br)Br)Br)Br)clc(c(c(c(clBr)Br)Br)Br)Br
Synonyms: DecaBDE; Benzene, l,l'-oxybis[2,3,4,5,6-pentabromo-; l,l'-Oxybis(2,3,4,5,6-pentabromobenzene); Adine 505; BDE 209; BDE-209;Berkflam B;
Bis(pentabromophenyl) ether, Bis(pentabromophenyl) oxide; Bromkal 83-0DE; Decabromodiphenyl oxide (DBDPO); DE 83; De 83R; Decabrom;
Decabromodiphenyl oxide; Decabromobiphenyl ether; Decabromobiphenyl oxide; FR 300; FR 300BA; PBED 209; Saytex 102; Saytex 102E; Tardex 100
Unverifiable Synonyms: AFR 1021; BR 55N; Bromkal 82-10DE; Caliban F/R-P 39P; DB 10; DB 101; DB 102; DP 10F; EB 10; EB 10FP; EB 10W; EB 10WS; EBR
700; F/R-P 53; Fire Cut 83D; Flame Cut 110R; Flame Cut Br 100; FR 10; FR-PE; FR-PE(H); FRP 53; Nonnen DP 10; Nonnen DP 10(F); PBED 209; Planelon DB;
Planelon DB 100; Planelon DB 101; Plasafety EB 10; Plasafety EBR 700
Chemical Considerations: This is a discrete organic chemical with a MW <1,000. EPI v 4.0 was used to estimate physical/chemical and environmental fate values in
the absence of experimental data. Measured values from experimental studies were incorporated into the estimations.
Decabromodiphenyl ether (decaBDE) is part of the Polybrominated Diphenyl Ether (PBDEs) Action Plan which addresses: the voluntary phase-out of manufacture
and import of decaBDE by manufacturers in the U.S.; development of a Significant New Use Rule and combined Section 4 test rule where the significant new use
would be manufacture, (including import) of decaBDE or articles to which decaBDE has been added (EPA, 2009).
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Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: Photodegradation - potential to form lower brominated diphenyl ether congeners and possibly
polybrominated dibenzofurans (European Chemicals Bureau, 2002); Fish metabolism - lower brominated diphenyl ether (BDE) congeners a range of penta- to
nonaBDEs (with 2,2',4,4',5,6'-hexabromodiphenyl ether being most prevalent) (Noyes et. al., 2011); Anaerobic Biodegradation - lower brominated diphenyl ether
congeners (Illinois EPA, 2007); Pyrolysis - polybrominated dibenzofurans and polybrominated dibenzo-p-dioxins (European Chemicals Bureau, 2002)
Analog: No analog
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: Polyhalogenated aromatic hydrocarbons, immunotoxicity (EPA 2011); test data are available to address this category.
Risk Phrases: Not classified by Annex VI Regulation (EC) No 1272/2008 (ESIS, 2012).
Hazard and Risk Assessments: Hazard assessment completed by EPA - IRIS Toxicological Review of Decabromodiphenyl ether (2008). Assessments were prepared
for decaBDE by the Washington Department of Ecology and Department of Health (2008), Illinois Environmental Protection Agency (2007), Danish Environmental
Protection Agency (2007), European Chemicals Bureau (2002), German Federal Ministry of the Environment (2001), and the National Academy of Sciences National
Research Council (2000). The Maine Department of Environmental Protection, Safer Alternatives Assessment for Decabromodiphenyl Ether Flame Retardant in
Plastic Pallets, includes a Green Screen Assessment of decaBDE (Maine DEP, unpublished). DecaBDE was also part of the High Production Volume Data Summary
and Test Plan (EPA, 2005) and the Voluntary Children's Chemical Evaluation Program (EPA, 2012).
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
300-310 (Measured)
European Chemicals Bureau,
2000; European Chemicals
Bureau, 2002
Adequate; consistent values, which
span a relatively narrow range, have
been reported in a secondary sources.
305 (Measured)
Lide, 2008
Adequate value cited from standard
reference source.
307 (Measured)
Fu and Suuberg, 2011
Adequate value obtained from
differential scanning calorimeter.
Boiling Point (°C)
>320 (decomposes) (Measured)
European Chemicals Bureau,
2002
Adequate; reported in a secondary
source.
Vapor Pressure (mm Hg)
3.5><10"8at 21°C (Measured)
Good laboratory practice (GLP) Spinning
Rotor Method
Stenzel and Nixon, 1997a;
European Chemicals Bureau,
2002
Adequate, guideline study.
9.02xl0"l3at 25°C (Extrapolated)
Knudsen Effusion Method
Fu and Suuberg, 2011
Adequate value for low volatility
substance; obtained using an indirect
measurement technique.
Water Solubility (mg/L)
<1.00xl0"4at 25°C (Measured)
GLP Column Elution Method
Organisation of Economic Cooperation
and Development (OECD) 105
Value reported was the detection limit
(<0.1 ppb)
Stenzel and Nixon, 1997b;
European Chemicals Bureau,
2002
Adequate; guideline study.
2 x 10° to 3 x 10"3 (Measured)
European Chemicals Bureau,
2000
Sufficient details were not available
to assess the quality of this study
reported in a secondary source.
Log Kow
627 (Measured)
OPPTS 830.7560.GLP Generator Column
Method
MacGregor and Nixon, 1997;
European Chemicals Bureau,
2002
Adequate, guideline study.
Flammability (Flash Point)
Not flammable (Estimated)
European Chemicals Bureau,
2000
Adequate; value reported in a
secondary source.
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Pyrolysis
Polybrominated dibenzo-p-dioxins
(PBDDs) and polybrominated
dibenzofurans (PBDFs) are formed by
thermal reaction involving a free radical
mechanism (Measured)
European Chemicals Bureau,
2000
Supporting information reported in a
secondary source.
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
pKa
Not applicable
Professional judgment
Dissociation is not expected; the
chemical does not contain ionizable
functional groups.
HUMAN HEALTH EFF]
ECTS
Toxicokinetics
Although experimental findings in human and animal studies suggest that decaBDE is poorly absorbed
following oral and dermal administration, even low levels of decaBDE are physiologically relevant due to its
chemical properties. 82.5-91.3% of decaBDE is eliminated from the body in the feces with <0.05% excreted in
urine. DecaBDE is mainly excreted as unchanged parent compound but may also be excreted in the form of
metabolites. Some conversion of parent compound may be mediated by intestinal epithelium or microflora.
Monitoring studies in humans, with unknown levels of exposure, demonstrate that decaBDE can be absorbed,
distributed to mammary tissue and secreted in human breast milk during lactation.
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Dermal Absorption in vitro
Skin of female hairless mice were exposed
in a flow-through diffusion cell system to
carrier-free 14C-labeled decaBDE (>98%
pure) at doses of 6, 30 or 60 nmol.
% absorption was determined at 6, 12, 18
and 24 hours.
EPA, 2008
Reported in a secondary source. The
results of this may overestimate the
amount of decaBDE that would be
absorbed by human skin, as mouse
skin has been found to be more
permeable to several chemicals.
Most of dose was taken up within the first
6 hours and very little compound was
absorbed (0.04-0.34%). Total dose retained
in the skin and transported to receptor fluid
was 20.5%, 3.3% and 1.9% for 6, 30 and
60 nmol doses, respectively.
Absorption,
Distribution,
Metabolism, and
Excretion
Oral
Uptake and disposition of 14C-DecaBDE
after dietary exposure: F344/N male rats
fed 238 to 51,000 ppm unlabeled Deca-
BDE (97.9-99.2% pure) in the diet on days
1-7 and equal doses of 14C-DecaBDE on
day 8. Average daily consumption
estimated to be 3,718 mg/kg-day. Analysis
of day 12 liver and fat.
91.3% of radioactivity was recovered in
the feces 72 hours after exposure.
Recovery was not related to administered
unlabeled dose. Low level of radioactivity
in the liver (mean = 0.02% of the 14C-dose
of 6 groups; range: 0.006 - 0.064% and fat
(mean of 0.11% of the 14C-dose; range:
0.072-0.161%)
European Chemicals Bureau,
2002
Study details reported in a secondary
source.
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Uptake and disposition of 14C-DecaBDE
after dietary exposure: F344/N male rats
fed 277 or 48,000 ppm unlabeled
DecaBDE on days 1-7 and equal amounts
of 14C -DecaBDE on day 8. Doses were
equivalent to 22-25 and 4,500-5,000
mg/kg-day; rats were sacrificed 24-, 48-, or
72-hours post-exposure with the radiolabel.
Blood, urine, feces, liver, kidney, lung,
muscle, fat, skin, brain, gut contents and
gut tissue were analyzed.
82.5% to 86.4% of radioactivity was
recovered in feces. Recovery was not
related to administered unlabeled dose or
time of sacrifice. Excretion in the urine
was <0.01%. Trace levels of radioactivity
were found in all major organs and tissues
with the highest concentration found in the
liver, kidney, lung, skin and adipose tissue.
DecaBDE and 3 main metabolites were
detected in the feces. % of metabolites
increased with increasing DecaBDE
concentration in diet, but DecaBDE was
primary compound eliminated.
European Chemicals Bureau,
2002
Study details reported in a secondary
source.
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sprague-Dawley rats given single oral dose
of 6 (Hnol/kg (-2.9 mg/kg) 14C DBDPO.
Major route of excretion (-90% of the dose
within 3 days) was via the feces, with only
minor amounts (<0.05% of the dose)
excreted via urine. Excretion via bile was
-9.5% of dose within 3 days.
-3% of total administered radioactivity
was detected in tissues 3 days after dosing
(liver (-0.9%), muscle (-0.7%), skin
(-0.4%), adipose tissue (-0.3%), colon
wall (-0.25%), jejunum wall (-0.05%),
jejunum content (-0.05%), with minor
amounts (<0.05%) in plasma, kidney,
heart, lung, adrenals, testis, red blood cells,
thymus and spleen). 8 phenolic metabolites
were present in feces, but the majority of
radioactivity was identified as unchanged
DBDPO.
DBDPO was metabolized via
debromination.
European Chemicals Bureau,
2002
Study details reported in a secondary
source.
Rats were fed diets containing 1.0 mg/kg-
day technical decaBDE for 2 years.
3-fold higher bromine concentrations were
measured in adipose tissue, suggesting that
bioaccumulation is low but retention in
body fat may be pronounced.
Darnerud et al., 2001
Sufficient study details reported in a
secondary source; test substance is
identified as a commercial product
composed of 77.4% BDE209, 21.8%
nonaBDE, and 0.8% octaBDE.
Analytical methods were not specific
for DecaBDE or any specific
congener; the bromine levels in
adipose tissue cannot be ascribed to
any particular congener or mixture of
congeners of BDE.
4-296
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sprague-Dawley rats (dams, fetuses and/or
nursing pups) were administered DecaBDE
by gavage at doses of 10, 100, or 1,000
mg/kg-day on gestation days (GD) 6 -
lactation day (LD) 4.
Levels of DecaBDE were similar in the
plasma of dams, fetal litters and neonatal
pups following oral doses of 10 mg/kg-
day. Plasma concentrations appear to
plateau at oral doses of >10 mg/kg-day.
Rats exposed to higher doses of DecaBDE
did not have higher levels in their plasma
than the low-dose group did. Levels of
DecaBDE were lower in the plasma of
fetuses and in maternal milk than in plasma
of dams, while neonatal plasma levels were
similar to or higher than maternal plasma
levels.
Steady-state plasma levels were achieved
within 14 days with adipose half-lives
ranging from 0.4 to 2.8 days. Absorption
from the gastrointestinal route exhibited
zero order uptake kinetics.
Biesemeier et al., 2010
Adequate; corn oil or
soyaphospholipon/Lutrol F127-water
were used as gavage vehicle for this
compound; higher concentrations of
DecaBDE were detected in plasma
and in milk with corn oil as the
vehicle compared to
soyaphospholipon/Lutrol F127-water.
Inhalation
Although pulmonary exposure may occur
as a result of small particle size (<5
systemic absorption via this route is
unknown.
European Chemicals Bureau,
2002
Brief statement reported in a
secondary source.
4-297
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Other
Disposition of 14C-decaBDE after IV
dosing: intravenous study in F344/N rats
injected with 1.07 mg/kg 14C-decaBDE
75% of intra-venous dose was detected in
feces and gut contents after 72 hours
(suggests biliary excretion). Remaining
14C-decaBDE was detected in tissues,
mainly in muscle, skin, liver and fat. Trace
amounts of radioactivity were detected in
urine, the spleen and brain. Excreted
material in the feces was primarily
unchanged decaBDE.
European Chemicals Bureau,
2002
Study details reported in a secondary
source; 9.5% of the administered dose
was found in the tail indicating that
the dose was delivered incompletely
and an unknown amount was given
through the tail vein.
Biliary excretion of 14C-decaBDE after IV
administration: intravenous study in
F344/N rats injected with 0.9 mg/kg 14C-
decaBDE.
7.17% of administered dose was detected
in the bile within 4 hours. Rate of excretion
was 2.2% of the dose per hour. Metabolite
identification was not carried out in this
study
European Chemicals Bureau,
2002
Study details reported in a secondary
source; 5.38 % of the administered
dose was found in the tail indicating
that the dose was delivered
incompletely and an unknown amount
was given through the tail vein.
Study conducted to study levels of PBDEs
in human breast milk. Mean concentration
of decaBDE was 0.9 ng/g lw (1.2% of total
PBDEs in the milk), suggesting that some
decaBDE is absorbed, distributed to
mammary tissue and secreted in human
breast milk during lactation.
EPA, 2008
Reported in a secondary source.
Information is from monitoring data
in human populations. No measured
dosing studies have been conducted to
determine if BDE-209 distributes to
other tissues as well.
4-298
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Milk samples collected from 40-first time
mothers with 8 week old infants. Mean and
total concentrations of 12 triBDE through
decaBDE congeners were 96 and 50 ng/g
lw, respectively. BDE-47 was found at the
highest level, followed by hexaBDE and
pentaBDE-99 and 100. DecaBDE-209 was
a minor congener in breast milk (0.8 and
0.4 ng/g lw, respectively).
EPA, 2008
Reported in a secondary source.
Information is from monitoring data
in human populations. No measured
dosing studies have been conducted to
determine if BDE-209 distributes to
other tissues as well.
Acute Mammalian r
oxicity
LOW: Based on acute oral and dermal LDS0 values >2000 mg/kg in rats and rabbits and an acute inhalation
LCso >48.2 mg/L in rats.
Acute Lethality
Oral
Rat LD50 >2,000 mg/kg
European Chemicals Bureau,
2002
Reported in a secondary source;
guideline study.
Rat LD50 >5,000 mg/kg
European Chemicals Bureau,
2002
Reported in a secondary source;
nonguideline study; necropsies were
not performed.
Dermal
Rabbit LD50 >2,000 mg/kg
European Chemicals Bureau,
2002
Reported in a secondary source;
nonguideline study. Clinical signs of
toxicity were not reported and
necropsies were not performed.
Inhalation
Rat 1-hour LC50 >48.2 mg/L dust
Spartan rats exposed for 1 hour to 2,000 or
48,200 mg/m3 (2.0 or 48.2 mg/L) dust;
No deaths or effect on body weight;
Dyspnea, ocular discharge, and eye squint,
increased motor activity were observed at
48.2 mg/L.
European Chemicals Bureau,
2002
Reported in a secondary source;
nonguideline study. Necropsy was not
performed and the particle size
distribution was not given.
4-299
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Single intratracheal injection to male
Sprague Dawley rats (n = 50)
Dose: 20 mg decaBDE (77.4%) dust
(length mean diameter 3.17 |im). Scattered
focal aggregates of alveolar macrophages
in the lungs showing clear, angulated,
cytoplasmic vacuoles; slight thickening of
the interalveolar septa.
European Chemicals Bureau,
2002
Reported in a secondary source;
nonguideline study.
Carcinogenicity
MODERATE: Based on National Toxico ogy Program (NTP) determinations of equivocal evidence of
carcinogenicity in male mice (increased incidence of hepatocellular adenomas or carcinomas and thyroid
gland follicular cell adenomas or carcinomas) and some evidence of carcinogenicity in male and female rats
(increased incidences of non-neoplastic nodules in the liver). Classified as "Suggestive evidence of
carcinogenic potential" by IRIS.
Carcinogenicity (Rat and
Mouse)
OncoLogic Results
Combined Chronic
Toxicity/ Carcinogenicity
2-year carcinogenicity study (dietary) in
B6C3F1 mice (50/sex/group).
Doses: 0, 25,000, 50,000 ppm
Average daily consumption:
Males: 0, 3,200 and 6,650 mg/kg
Females: 0, 3,760 and 7,780 mg/kg
Increased incidence of granulomas in the
liver (25,000 ppm, males); centrilobular
hypertrophy with enlarged hepatocytes
with frothy vacuolatedcytoplasm (25,000
and 50,000 ppm, males); follicular cell
hyperplasia of the thyroid gland (25,000
and 50,000 ppm, males); and increased
incidence of stomach ulcers (50,000 ppm,
females).
No clinical signs of toxicity and no adverse
NTP, 1986; European Chemicals
Bureau, 2002
No data located.
No data located.
Study details provided in secondary
sources; guideline study in
accordance with GLP procedures.
NTP concludes that there was
equivocal evidence of carcinogenicity
for male mice based on increased
combined incidence of both
hepatocellular adenomas and
carcinomas in the low dose group and
on thyroid gland follicular cells
adenomas or carcinomas (combined)
in both groups; results are based on
Kaplan Meier estimated tumor
incidences at the end of the study after
adjusting for early mortality.
4-300
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
effects on survival, food consumption or
body weight. No evidence of
carcinogenicity in females.
NOAEL: not established
LOAEL (systemic): 25,000 ppm (3,200
mg/kg-day) based on increased incidence
of non-neoplastic lesions in several tissues
in males
2-year carcinogenicity study (dietary) in
Fisher 344/N rats (50/sex/group)
Doses: 0, 25,000, 50,000 ppm
Average daily consumption:
Males: 0, 1,120 and 2,240 mg/kg
Females: 0, 1,200 and 2,550 mg/kg
Increased incidence of thrombosis and
degeneration in the liver without foci of
necrosis associated and fibrosis of the
spleen and lymphoid hyperplasia of the
mandibular lymph nodes (50,000 ppm,
males); hematopoiesis in the spleen
(25,000 and 50,000, female); acanthosis of
the fore stomach (25,000 and 50,000,
males); and dose dependent decreased
incidence of C-cell hyperplasia of the
thyroid gland (males).
No clinical signs of toxicity and no adverse
effects on survival, food consumption or
body weight.
NOAEL (systemic): 25,000 ppm (1,120
and 1,200 mg/kg-day in males and females,
NTP, 1986; European Chemicals
Bureau, 2002
Study details provided in secondary
sources; guideline study in
accordance with GLP procedures.
NTP concludes that there was some
evidence of carcinogenicity for male
and female rats based on increased
incidences of non-neoplastic nodules
in the liver in the low dose males and
high dose males and females.
4-301
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
respectively)
LOAEL (systemic): 50,000 ppm (2,240
and 2,550 mg/kg-day in male and females,
respectively) based on neoplastic lesions,
degeneration in the liver, spleen fibrosis,
lymphoid hyperplasia of the mandibular
lymph nodes.
LOAEL (local effects): 25,000 ppm based
on the slight increase in fore stomach
acanthosis
2-year carcinogenicity study (dietary) in
Sprague-Dawley rats (25/sex/group)
Doses: 0, 0.01, 0.1, 1 mg/kg-day.
Kociba et al., 1975; European
Chemicals Bureau, 2002
Test substance: 77.4% decaBDE,
21.8% nonaBDE, 0.8% octaBDE.
There was no increased incidence of
tumors or changes in organ histopathology
in treated rats compared to controls.
No clinical signs of toxicity and no effects
on survival, food consumption, body
weight, hematology, urinalysis, clinical
chemistry, organ weights.
Classified as "Suggestive evidence of
carcinogenic potential" by EPA IRIS;
weight of evidence suggests
carcinogenicity and the potential for
possible carcinogenic effects in humans.
EPA, 2008
Summary of overall weight of
evidence reviewed by IRIS.
4-302
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Genotoxicity
LOW: Based on negative results for gene mutations in bacterial and mammalian cells and lack of
chromosomal aberrations in Chinese hamster ovary (CHO) cells in vitro.
Gene Mutation in vitro
Negative in Salmonella typhimurium
strains TA98, TA100, TA1535, TA1537
and Escherichia coli WP2 nvrA in the
presence or absence of exogenous
metabolic activation.
No evidence of cytotoxicity.
European Chemicals Bureau,
2002; EPA, 2008
Guideline study in accordance with
GLP procedures; study details
reported in a secondary source.
Positive in Salmonella typhimurium strains
TA1535, TA98, TA100) in the presence or
absence of exogenous metabolic activation.
Doses: 50, 150, 500, 1500, 5000 (ig/plate
European Chemicals Bureau,
2002
Positive results were only observed at
500 (ig/plate and may be a result of
the presence of an impurity. In
addition, the purity of decaBDE used
in the study is unknown (data reported
in a secondary source).
Negative in Saccharomyces cerevisiae with
and without metabolic activation
Darnerud et al., 2001
Study details provided in summary
reported in a secondary source.
Negative, mouse lymphoma L 5178
Y/TK+/- assay
Doses: 7, 8, 9, 10 (ig/plate in dimethyl
sulfoxide (DMSO)
European Chemicals Bureau,
2002; EPA, 2008
Guideline study in accordance with
GLP procedures. Results may be
weighted less heavily due to the
narrow range of test concentrations
used in the study; study details
reported in a secondary source.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
Negative, sister chromatid
exchange/chromosomal aberrations in
CHO cells in the presence or absence of
exogenous metabolic activation.
Doses: 50, 100, 200, 500 (ig/ml in DMSO
European Chemicals Bureau,
2002; EPA, 2008
Guideline study in accordance with
GLP procedures; study details
reported in a secondary source.
Chromosomal
Aberrations in vivo
Negative, mammalian chromosomal
aberration test in rat bone marrow cells.
Doses: 3, 30, 100 mg/kg/day in diet
European Chemicals Bureau,
2002
Limited study details reported in a
secondary source.
DNA Damage and Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
4-303
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproductive Effects
LOW: Based on a LOAEL of 500 mg/kg-day in mice for adverse effects on sperm and no adverse
reproductive effects following 13 week and 2 year exposures in rats and mice.
Reproduction/
Developmental Toxicity
Screen
No data located.
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
No data located.
Reproduction and
Fertility Effects
One generation reproductive study in
Sprague Dawley rats (10 males, 20 females
in low dose groups; 15 males, 30 females
in high dose groups).
Doses: 0, 3, 30 or 100 mg decaBDE/kg
body weight/day in the diet.
Study duration: 60 days prior to mating, 15
days during mating, and throughout
gestation and weaning.
No adverse effects on fertility
NOAEL: lOOmg/kg/day
LOAEL: not established as highest dose
tested did not produce adverse effects
European Chemicals Bureau,
2002
Reported in a secondary source.
Results may be weighted less heavily
due to the fact that the highest dose
tested did not produce parental
toxicity. In addition, individual data
were not available (only a summary
provided in secondary source); Test
substance composition identified as
commercial DBDPO (77.4%
decaBDE, 21.8% nonaBDE, 0.8%
octaBDE).
4-304
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Oral gavage study in male CD-I mice
(50/group)
Doses: 0, 10, 100, 500 or 1500 mg/kg-day
on PNDs 21-70
EPA, 2008
Study details reported in a secondary
source.
Reduced amplitude of sperm lateral head
displacement, reduced sperm
mitochondrial membrane potential,
increased sperm H202 generation.
NOAEL: 100 mg/kg-day
LOAEL: 500 mg/kg-day
13 week and 2 year carcinogenicity studies
in B6C3F1 mice and F344/N rats did not
produce adverse macroscopic or
histological changes in the testes, prostate
ovaries, or uterus.
NTP, 1986; European Chemicals
Bureau, 2002
Guideline studies reported in a
secondary source.
Doses: 0, 3,100, 6,200, 12,500, 25,000, or
50,000 ppm (13 week study) or 0, 25,000
or 50,000 ppm (2 year studies)
4-305
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
2 8-day oral study in Wistar rats
(10/sex/group)
Doses: 0, 1.87, 3.75, 7.5, 15, 30, 60 mg/kg-
day; 2 doses of 30 mg/kg at 4-hour
intervals were used for the 60 mg/kg-day
group due to the limited solubility of the
test substance;
There was a significant dose-dependent
change in epididymis weight and seminal
vesicle weight, though there were no
effects on sperm counts or epididymal
sperm morphology.
Van der Ven et al., 2008 (as
described in Hardy et al., 2009)
Reported in a review; test substance
described as consisting of a composite
of equal proportions from 3
manufacturer's products (purity
>97%); data were evaluated using
benchmark dose analysis; this study
was not designed as a reproductive
study, and did not evaluate all
reproductive parameters.
NOAEL = 30 mg/kg-day
LOAEL = 60 mg/kg-day (decreased
epididymis and seminal vesicle weight)
Developmental Effects
HIGH: A number of rodent developmental neurotoxicity studies addressing decaBDE exposure have been
published. The hazard designation for this endpoint is based on the most conservative NOAEL and LOAEL
values in the located studies. The adverse effects in these studies were reduced thyroid hormone levels and
abnormal behavior. DecaBDE was also developmentally toxic in rats via oral exposure to a low purity
product where resorptions were increased at 10 and 100 mg/kg, but not for a high purity product.
Reproduction/
Developmental Toxicity
Screen
No data located.
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
No data located.
4-306
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Prenatal Exposure
Oral gavage study in pregnant Sprague
Dawley rats (n = 20)
Dose: 0, 10, 100 or 1,000 mg decaBDE/kg
body weight/day
Study duration: GD 6-15
Statistically significant increase in
resorptions (10 and 100 mg/kg-day)
No gross external abnormalities.
Significant increase in the number of litters
with subcutaneous edema and delayed
ossification of normally developed bones
of the skull (1,000 mg/kg/day).
NOAEL (maternal) = 1,000 mg/kg/day
LOAEL (conceptus) = 10 mg/kg/day
European Chemicals Bureau,
2002
Study results may be weighted less
heavily due to the low compound
purity; test substance identified as a
commercial mixture (77.4%
decaBDE, 21.8% nonabromodiphenyl
ether, 0.8% octabromodiphenyl ether)
used in the study), which is lower
than the purity of the products
currently supplied in the EU. Study
details reported in a secondary source.
Oral gavage study in pregnant Sprague
Dawley rats (25/group)
Dose: 0, 100, 300 or 1,000 mg/kg/day of
decaBDE (purity of 97.34%)
Study duration: GD 0-19
No adverse maternal clinical findings or
effects on body weight, body weight gain
or liver weights.
No adverse treatment-related effects on
external malformations or variations,
skeletal variation or ossification. No
adverse effects on fetal weight, sex ratio,
total/late resorptions.
NOAEL (maternal, developmental): 1,000
mg/kg-day
European Chemicals Bureau,
2002; EPA, 2008
Guideline study in accordance with
GLP procedures. Study details
reported in a secondary source.
4-307
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Oral gavage (corn oil) study in rats, 0, 100,
300, 1,000 mg/kg/day, (half exposed GD6-
20, other half exposed GD6 through LD4).
Biesemeier et al., 2010
LOAEL not identified.
No maternal treatment-related effects on
mortality, clinical signs of toxicity, body
weight, body weight gain, or food
consumption.
No effects on gestational or litter
parameters (mean gestational length, mean
number of pups born, percentage of males
at birth, mean live litter size, postnatal
survival, mean offspring body weight and
weight gains through PND 21).
NOAEL = 1,000 mg/kg/day (highest dose
tested)
Rat, neurodevelopmental study, oral
(gavage) administered 0, 1, 10, 100, or
1,000 mg/kg/day, GD 6 through weaning.
Biesemeier et al., 2011
LOAEL not identified; GLP/guideline
compliant study.
No treatment-related neurobehavioral
effects were observed (startle response,
learning, and memory tests assessed);
No changes in were reported in motor
activity evaluations at 2, 4, or 6 months of
age;
No neuropathological or morphometric
changes reported.
NOAEL = 1,000 mg/kg/day (highest dose
tested)
4-308
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Postnatal
Exposure/Developmental
neurotoxicity
Evaluation of locomotor activity in
C57BL6/J mice
Dose: 0, 6 or 20 mg/kg on PNDs 2-15 with
observation after placement in a novel
environment on PND70 and using special
functional observational battery
No adverse effects on developmental
endpoints (on pinnae detachment, incisor
eruption, eye opening, vaginal opening or
testes descent).
Declined locomotor activity in males and
females on PND70 (decline was
significantly different for males at 6 and 20
mg/kg compared to controls);
Decreased % of pups performing the
palpebral reflex on PND 14 compared to
controls (6 or 20 mg/kg-day);
Decreased number of pups (males)
adequately performed an effective forelimb
grip (PND 14 and 16) compared with
same-sex controls (20 mg/kg-day);
Increased struggling behavior (males) on
PND20, decreased T4 levels (males) on
PND70;
Decreased T4 levels (males) on PND70.
NOAEL: not established
LOAEL: 6 mg/kg-day (based on decreased
T4 levels in male mice and effects on
locomotor activity in male mice on
PND70)
EPA, 2008; Washington DOE,
2008
Study details reported in a secondary
source.
4-309
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Single dose gavage in male Sprague
Dawley rats (20 rats from 3-5 litters/group)
Doses: 0, 6.7 or 20.1 mg/kg on PND3
EPA, 2008
Each dose administered a single time;
not a guideline study. Study details
reported in a secondary source.
Dose-related disruption in habituation
(changes in locomotion, rearing, total
activity) at both doses.
NOAEL: Not established
LOAEL: 6.7 mg/kg
NMRI male mice (10 mice from 3-5
litters/group) gavaged with decaBDE (99%
pure) at 0, 2.22, or 20.1 mg/kg on PNDs3-
19 or 0, 1.34, 13.4 or 20.1 mg/kg on
PND10.
European Chemicals Bureau
2002; EPA, 2008
Each dose administered a single time;
not a guideline study. Study details
reported in a secondary source.
Dose-related disruption in habituation
(changes in locomotion, rearing, total
activity) at 2, 4, and 6 months following
exposure to 20.1 mg/kg on PND3.
NOAEL (NMRI mice): 2.22 mg/kg
LOAEL (NMRI mice): 20.1 mg/kg
Neurotoxicity
LOW: There were no neurotoxicity studies addressing decaBDE exposure located. While developmental
neurotoxicity studies indicated a potential for hazard, these positive indications do not trigger a hazard
potential for adult neurotoxicity. There is no reported evidence to support a hazard potential for adult
neurotoxicity for this compound or analogous highly brominated compounds.
Neurotoxicity Screening
Battery (Adult)
Low potential for neurological effects.
(Estimated)
Professional judgment
Estimated based on the absence of
structural alerts that have been
[experimentally] associated with the
adult neurotoxicity endpoint.
4-310
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Repeated Dose Effects
MODERATE: Based on a LOAEL of 80 mg/kg-day for adverse liver and thyroid effects following a 30-day
oral exposure in rats. A NOAEL was not established in the 2-year carcinogenicity study. The LOAEL of 3,200
mg/kg/day yields uncertainty to the dose levels where adverse effects may begin. These subchronic effects
appear consistent with the observed chronic effects although the latter were observed at higher doses.
30-day dietary study in male Sprague-
Dawley rats (number/group not specified)
Doses: 0, 100, 1,000, 10,000 ppm
(~0, 8, 80, 800 mg/kg/day)
Enlarged livers (1,000 ppm); thyroid
hyperplasia (1,000 and 10,000 ppm);
hepatic centrilobular cytoplasmic
enlargement and vacuolisation and renal
hyaline degenerative cytoplasmic changes
(10,000 ppm).
No clinical signs of toxicity and no adverse
effects on food consumption, body weight,
organ weight or hematological/urinary
parameters.
NOAEL: 100 ppm (8 mg/kg/day)
LOAEL: 1,000 ppm (80 mg/kg/day) based
on incidence of enlarged livers
European Chemicals Bureau,
2002
Results may be weighted less heavily
due to the low compound purity
(77.4% decaBDE-21.8%
nonabromodiphenyl oxide) used in
the study, which is lower than the
purity of the products currently
supplied in the EU; study details
reported in a secondary source;
Design for the Environment (DfE)
Alternatives Assessment criteria
values are tripled for chemicals
evaluated in 28-day studies; the
LOAEL of 80 mg/kg-day falls within
the Moderate hazard criteria.
4-311
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
14-day dietary study in B6C3F1 mice and
F344/N rats (5/sex/group).
Doses: 0, 5,000, 10,000, 20,000, 50,000, or
100,000 ppm decaBDE (99% purity).
Estimated average doses:
Mice: 0, 1,027, 2,143, 4,246, 10,536, or
20,994 mg/kg-day in male mice and 0,
1,146, 2,286, 4,627, 11,348, or 23,077
mg/kg-day in female mice.
Rats: 0, 472, 928, 1,846, 4,569, or 9,326
mg/kg-day in male rats and 0, 538, 1,061,
2,137, 5,323, or 10,853 mg/kg-day in
female rats.
No adverse effects on health, survival body
weight, clinical signs or gross pathology.
NOAEL (mice): 20,994 mg/kg-day in male
mice and 23,077 mg/kg-day in female mice
LOAEL: Not established, as highest dose
tested did not produce adverse effects
NOAEL (rats): 9,326 mg/kg-day in male
rats and 10,853 mg/kg-day in female rats
LOAEL: Not established, as highest dose
tested did not produce adverse effects
European Chemicals Bureau,
2002; Maine, unpublished; EPA,
2008
Guideline study in accordance with
GLP procedures; study details
reported in a secondary source.
4-312
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
13-week dietary study in B6C3F1 mice and
F344/N rats (10/sex/group)
Doses: 0, 3,100, 6,200, 12,500, 25,000,
50,000 ppm
Estimated average doses:
Mice: 0, 666, 1,355, 2,659, 5,278, or
10,233 mg/kg-day in males and 0, 702,
1,437, 2,899, 5,687, or 11,566 mg/kg-day
in females
Rats: 0, 191, 372, 781, 1,536, or 3,066
mg/kg-day in male rats and 0, 238, 504,
967, 1,955, or 3,944 mg/kg-day in female
rats
No adverse effects on health, survival body
weight, clinical signs or gross pathology.
NOAEL (mice): 10,233 mg/kg-day in
males and 11,566 mg/kg-day in females
LOAEL (mice): Not established, as highest
dose tested did not produce adverse effects
NOAEL (rats): 3,066 mg/kg-day in male
rats and 3,944 mg/kg-day in female rats
LOAEL (rats): Not established, as highest
dose tested did not produce adverse effects
European Chemicals Bureau,
2002; Maine, unpublished; EPA,
2008
Guideline study in accordance with
GLP procedures; study details
reported in a secondary source.
4-313
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
28-day dietary study in F344/N rats
(10/sex/group)
Doses: 0, 100, 1,000 ppm (0, 7, 70
mg/kg/day (M); 0, 8, 80 mg/kg/day (F))
No adverse effects on health, survival body
weight, food consumption, behavior, or
gross pathology.
NOAEL: 1,000 ppm (70 or 80 mg/kg-day
for males and females, respectively)
LOAEL: Not established, as highest dose
tested did not produce adverse effects
European Chemicals Bureau,
2002; EPA, 2008
Guideline study; study details
reported in a secondary source; DfE
Alternatives Assessment criteria
values are tripled for chemicals
evaluated in 28-day studies; while the
LOAEL was not established, the
NOAEL of -70-80 mg/kg-day
(highest dose tested) falls within the
Moderate hazard criteria (30 - 300
mg/kg-day); it is uncertain if repeated
dose effects may occur within this
range.
2 8-day oral study in Wistar rats
(10/sex/group)
Doses: 0, 1.87, 3.75, 7.5, 15, 30, 60 mg/kg-
day; 2 doses of 30 mg/kg at 4-hour
intervals were used for the 60 mg/kg-day
group due to the limited solubility of the
test substance;
There were no changes in appearance,
behavior, food consumption or body
weight reported;
Occasional slight hepatic centrilobular
hypertrophy occurred in male rats; there
were no changes in plasma alanine
aminotransferase in males or females and
no changes in plasma alkaline phosphatase
(ALP) in male rats reported; decreased
ALP levels were reported in female rats at
the highest dose; increased hepatic
CYPlAmRNA, CYP2B mRNA, CYP1A1
protein, and 7-pentoxyresorufin O-
deethylase (EROD) activity was reported
Van der Ven et al., 2008 (as
described in Hardy et al., 2009)
Study reported in a review; test
substance described as consisting of a
composite of equal proportions from 3
manufacturer's product (purity
>97%); data were evaluated using
benchmark dose analysis; DfE
Alternatives Assessment criteria
values are tripled for chemicals
evaluated in 28-day studies; the
LOAEL of 60 mg/kg-day falls within
the Moderate hazard criteria;
however, these effects may be the
result of an adaptive response by the
liver and not considered adverse.
4-314
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
in both males and females in the 60 mg/kg-
day group;
T3 levels were increased in female rats, but
not male rats in the high dose group; there
was no effect on T4 levels in males. There
were also no histological or weight
changes in the thyroids or pituitaries
reported;
There was decreased adrenal CYP17
adrenal activity observed in females but
not males. No other histopathological or
weight changes in the adrenal glands were
reported
In the absence of histopathological
alterations, changes in hepatic enzymes
may be the result of an adaptive response
by the liver.
NOAEL = 30 mg/kg-day
LOAEL = 60 mg/kg-day (changes in
hepatic enzyme and enzyme mRNA
levels)
4-315
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
2-year carcinogenicity study (dietary) in
B6C3F1 mice (50/sex/group)
Doses: 0, 25,000, 50,000 ppm
Average daily consumption:
Males: 0, 3,200 and 6,650 mg/kg/day
Females: 0, 3,760 and 7,780 mg/kg/day
Increased incidence of granulomas in the
liver (25,000 ppm, males); centrilobular
hypertrophy with enlarged hepatocytes
with frothy vacuolated cytoplasm (25,000
and 50,000 ppm, males); follicular cell
hyperplasia of the thyroid gland (25,000
and 50,000 ppm, males); increased
incidence of stomach ulcers (50,000 ppm,
females).
No clinical signs of toxicity and no adverse
effects on survival, food consumption or
body weight.
NOAEL: Not established
LOAEL: 25,000 ppm (3,200 mg/kg-day)
based on increased incidence of non
neoplastic lesions in several tissues
European Chemicals Bureau,
2002; EPA, 2008
Guideline study in accordance with
GLP procedures; study details
reported in a secondary source.
4-316
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
2-year carcinogenicity study (dietary) in
Fisher 344/N rats (50/sex/group)
Doses: 0, 25,000, 50,000 ppm
Average daily consumption:
Males: 0, 1,120 and 2,240 mg/kg
Females: 0, 1,200 and 2,550 mg/kg
Increased incidence of thrombosis and
degeneration in the liver without foci of
necrosis associated, fibrosis of the spleen
and lymphoid hyperplasia of the
mandibular lymph nodes (50,000 ppm,
males); hematopoiesis in the spleen
(25,000 and 50,000, female); acanthosis of
the fore stomach (25,000 and 50,000,
males); dose-dependent decreased
incidence of C-cell hyperplasia of the
thyroid gland (males).
No clinical signs of toxicity and no
compound-related effects on survival
NOAEL (systemic): 25,000 ppm (1,120
mg/kg-day)
LOAEL (systemic): 50,000 ppm (2,240
mg/kg-day) based on neoplastic lesions,
degeneration in the liver, spleen fibrosis,
lymphoid hyperplasia of the mandibular
lymph nodes
LOAEL (local effects): 25,000 ppm (1,120
mg/kg-day) based on the slight increase in
fore stomach acanthosis
European Chemicals Bureau,
2002; EPA, 2008
Guideline study in accordance with
GLP procedures; study details
reported in a secondary source.
4-317
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
4-day oral gavage study in Long-Evans
female weanling rats (8/group).
Doses: 0, 0.3, 1, 3, 10, 30, 60 or 100
mg/kg-day
EPA, 2008
A 4-day exposure study may not be a
good indicator of chronic exposure
effects; study details reported in a
secondary source.
No dose-related effects on body weight,
liver weight or changes in TSH, T3 or T4
levels.
NOAEL: 100 mg/kg/day
LOAEL: not established, as highest dose
tested did not produce adverse effects
In chronic dietary studies in male rats,
decaBDE has caused histological changes
in lymphoid organs (spleen, mandibular
lymph nodes) at 2,240 mg/kg-day.
EPA, 2008
Study details reported in a secondary
source.
No cytotoxic effects in splenocytes from
C57BL/6 mice incubated in culture with 3
(imol/L decaBDE (purity not specified).
EPA, 2008
Study details reported in a secondary
source.
No attenuation of interleukin-2-receptor a
chain (CD25) expression (demonstrating a
lack of effect on the immune system in an
immunosuppressive manner).
Skin Sensitization
LOW: Based on negative results for skin
sensitization in guinea pigs and human volunteers.
Skin Sensitization
Negative, guinea pigs
European Chemicals Bureau,
2002
Reported in a secondary source; study
was performed using a mixture of
polybrominated diphenyl oxides
(commercial octaBDE) which
comprised of <3% decaBDE.
Negative, human volunteers
European Chemicals Bureau,
2002
Reported in a secondary sources;
concentrations tested were very low
(2-5%).
4-318
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Respiratory Sensitization
No data located.
Respiratory Sensitization
No data located.
Eye Irritation
LOW: DecaBDE is a mild eye irritant in rabbits.
Eye Irritation
Transient, mild irritation, rabbits
(reversible in 48 hours)
European Chemicals Bureau,
2002
Reported in a secondary source;
guideline study in accordance with
GLP procedures.
Dermal Irritation
LOW: DecaBDE is a slight skin irritant in humans.
Dermal Irritation
Non-irritant, rabbit
European Chemicals Bureau,
2002
Reported in a secondary source;
guideline study using commercial
decaBDE as dry solid.
Slight irritation, human volunteers
European Chemicals Bureau,
2002
Reported in a secondary source.
Endocrine Activity
Limited studies were located on the ability of decaBDE to interact with the endocrine system. However, some
metabolites of decaBDE are known to produce estrogenic effects. In addition, decaBDE is listed as a potential
endocrine disrupter on the EU Priority List of Suspected Endocrine Disrupters and on the Red List of
chemicals (EU, 2012; CPA, 2009).
Pimephcdes promelas (fathead minnows)
fed 3 or 300 ng/g bw-day BDE-209 or 15
|a,g/g bw-day 6-propyl-2-thiouricil (PTU)
as a positive control for 28 days followed
by a 14 day depuration.
3 ng/g bw-day: 53% decline in TT4; 46%
decline in TT3
300 ng/g bw-day: 59% decline in TT4;
62% decline in TT3
Both doses: 62% reduced brain deiodinase
activity and elevated relative mRNA
expression in genes associated with thyroid
pathways. Decreased gonadal-somatic
index and increased mortality.
Noyes et al., 2013
Study details reported in a primary
source. It is not known if the parent
BDE-209 or its metabolites were
driving the effects.
4-319
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Pimephcdes promelas (fathead minnows)
fed 0.16 (ig/g BDE-209 for 28 days.
Reduced rates of outer and inner ring
deiodination of thyroxine (74%).
Significantly increased thyroid follicular
epithelial cell heights
Noyes et al., 2011
Study details from primary source.
Ongoing unpublished studies at the
University of Southern Maine indicate
effects on blood concentrations of hormone
T4 in male mice and no effects on treated
females.
Maine, unpublished
This is an ongoing study at the
University of Southern Maine. No
definitive conclusions regarding the
potential for decaBDE to produce
endocrine disruption have been made.
DecaBDE is listed as a potential endocrine
disruptor on the EU Priority List of
Suspected Endocrine Disruptors.
European Commission, 2012
"Potential for endocrine disruption. In
vitro data indicating potential for
endocrine disruption in intact
organisms. Also included effects in-
vivo that may, or may not, be
endocrine disruption-mediated. May
include structural analyses and
metabolic considerations".
4-day oral gavage study in Long-Evans
female weanling rats (8/group).
Doses: 0, 0.3, 1, 3, 10, 30, 60 or 100
mg/kg-day
No dose-related effects on TSH, T3 or T4
levels.
NOAEL: 100 mg/kg/day
LOAEL: not established, as highest dose
tested did not produce adverse effects
EPA, 2008
A 4-day exposure study may not be a
good indicator of chronic exposure
effects; study details reported in a
secondary source.
4-320
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
2 8-day oral study in Wistar rats
(10/sex/group)
Doses: 0, 1.87, 3.75, 7.5, 15, 30, 60 mg/kg-
day; 2 doses of 30 mg/kg at 4-hour
intervals were used for the 60 mg/kg-day
group due to the limited solubility of the
test substance;
T3 levels were increased in female rats, but
not male rats in the high dose group; there
was no effect on T4 levels in males. There
were also no histological or weight
changes in the thyroids or pituitaries
reported;
There was decreased adrenal CYP17
adrenal activity observed in females but
not males. No other histopathological or
weight changes in the adrenal glands were
reported.
Van der Ven et al., 2008 (as
described in Hardy et al., 2009)
Study reported in a review; test
substance describes as consisting of a
composite of equal proportions from 3
manufacturer's product (purity
>97%).
2-year carcinogenicity study (dietary) in
Sprague-Dawley rats (25/sex/group)
Doses: 0, 0.01, 0.1, 1 mg/kg-day;
There were no changes in organ
histopathology in treated rats compared to
controls;
No clinical signs of toxicity and no effects
on survival, food consumption, body
weight, hematology, urinalysis, clinical
chemistry, organ weights.
Kociba et al., 1975; European
Chemicals Bureau, 2002
Test substance: 77.4% decaBDE,
21.8% nonaBDE, 0.8% octaBDE.
4-321
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Immunotoxicity
Histological changes in lymphoid organs occurred at 2,240 mg/kg-day in a chronic study of rats.
Immune System Effects
In chronic dietary studies in male rats,
decaBDE has caused histological changes
in lymphoid organs (spleen, mandibular
lymph nodes) at 2,240 mg/kg-day.
EPA, 2008
Study details reported in a secondary
source.
No cytotoxic effects in splenocytes from
C57BL/6 mice incubated in culture with 3
(imol/L decaBDE (purity not specified).
No attenuation of interleukin-2-receptor a
chain (CD25) expression (demonstrating a
lack of effect on the immune system in an
immunosuppressive manner).
EPA, 2008
Study details reported in a secondary
source.
ECOTOXICITY
Aquatic Toxicity
ECOSAR Class
Acute Toxicity
LOW: The log Kow of the compound (6.27) exceeds the ECOSAR cutoff value of 5.0 for acute endpoints and
therefore, no effects at saturation (NES) are predicted. Although experimental studies were located for fish
and green algae, they were considered to be inadequate due to deviations from standard protocols and
resulting toxicity values that exceed the compound's water solubility.
Fish LC50
Oryzias latipes 48 hour LC50 >500 mg/L
(Experimental)
European Chemicals Bureau,
2002
OECD guidelines for acute aquatic
toxicity (203) state that the preferred
exposure duration is 96 hours.
96 hour LC50= 0.129 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
The log Kow exceeds the ECOSAR
cutoff value of 5.0 for acute endpoints
and therefore, NES are predicted.
Narcosis classes (neutral organics) are
provided for comparative purposes;
DfE assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
4-322
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid LCS0
48 hour LC50= 0.137 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
The log K0„ exceeds the ECOSAR
cutoff value of 5.0 for acute endpoints
and therefore, NES are predicted.
Narcosis classes (neutral organics) are
provided for comparative purposes;
DfE assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Other Freshwater Invertebrate LCS0
Mysid shrimp 96 hour LC50 = 0.006 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
The log K0„ exceeds the ECOSAR
cutoff value of 5.0 for acute endpoints
and therefore, NES are predicted.
Narcosis classes (neutral organics) are
provided for comparative purposes;
DfE assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Green Algae ECS0
Skeletonema costatum, Thalassiosira
pseudonanct 72 hour EC50>1 mg/L
(Experimental)
European Chemicals Bureau,
2002
Reported in a secondary source; the
reported toxicity limit exceeds the
compound's water solubility.
Chlorella sp. 96 hour EC50>1 mg/L
(Experimental)
European Chemicals Bureau,
2002
Reported in a secondary source, the
reported toxicity limit exceeds the
compound's water solubility.
4-323
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
96 hour EC50 = 0416 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
The log K0„ exceeds the ECOSAR
cutoff value of 5.0 for acute endpoints
and thus, NES are predicted. Narcosis
classes (neutral organics) are provided
for comparative purposes; DfE
assessment methodology will use the
lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Chronic Aquatic Toxicity
LOW: Based on estimated values for fish
therefore predicted to have NES. Althou
dietary fish study identified decreased th1
mortality, after dietary exposure to part
, daphnia and algae that exceed the water solubility and are
gh not currently applicable to DfE aquatic toxicity criteria, a chronic
yroid hormone, deiodinase activity and gonad size, plus increased
per billion doses of decaBDE.
Fish ChV
Pimephcdes promelas (fathead minnows)
fed 3 or 300 ng/g bw-day BDE-209 or 15
|a,g/g bw-day 6-propyl-2-thiouricil (PTU)
as a positive control for 28 days followed
by a 14 day depuration.
3 ng/g bw-day: 53% decline in TT4; 46%
decline in TT3
300 ng/g bw-day: 59% decline in TT4;
62% decline in TT3
Both doses: 62% reduced brain deiodinase
activity and elevated relative mRNA
expression in genes associated with thyroid
pathways. Decreased gonadal-somatic
index and increased mortality.
Noyes et al., 2013
Study details reported in a primary
source. It is not known if the parent
BDE-209 or its metabolites were
driving the effects.
4-324
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
30-day ChV = 0.018 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
The ChV value exceeds the water
solubility by more than a factor of 10,
and therefore, NES are predicted.
Narcosis classes (neutral organics) are
provided for comparative purposes;
DfE assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Daphnid ChV
ChV = 0.031 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
The ChV value exceeds the water
solubility by more than a factor of 10
and therefore, NES are predicted.
Narcosis classes (neutral organics) are
provided for comparative purposes;
DfE assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Saltwater Invertebrate ChV
Mysid shrimp ChV = 0.00015 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
This chemical may not be soluble
enough to measure this predicted
effect. Narcosis classes (neutral
organics) are provided for
comparative purposes; DfE
assessment methodology will use the
lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
4-325
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green Algae ChV
ChV = 0.324 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
The ChV value exceeds the water
solubility by more than a factor of 10,
and therefore, NES are predicted.
Narcosis classes (neutral organics) are
provided for comparative purposes;
DfE assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Sediment Dwelling Organisms ChV
Lumbricuius variegatus NOEC >5,000
mg/kg dry weight based on nominal
concentrations (Experimental)
European Chemicals Bureau,
2002
Reported in a secondary source;
guideline study (American Society for
Testing and Materials 1706-95b and
OPPTS No. 850.1736).
DfE has not established hazard
criteria for studies based on sediment
concentrations nor sediment dwelling
organisms at the time of this report.
Terrestrial Ecotoxicity
Chicken embryo toxicity
Chicken embryo LD50 = 740 ng/g ww; egg
injection study (Experimental)
Sifleet, 2009
Test substance identified as BDE-209.
Earthworm Subchronic Toxicity
56-day NOEC (survival or reproduction)
>4,910 mg/kg dry weight using nominal
concentrations (Experimental)
European Chemicals Bureau,
2002
Reported in a secondary source;
guideline study (OECD 207 test
guideline).
4-326
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL FATE
Transport
The transport evaluation for decaBDE is based on both estimated and experimental physical and chemical
properties. Based on the Level III fugacity models incorporating the located experimental property data,
decaBDE is expected to partition primarily to soil. It is not expected to dissociate at environmentally-relevant
pHs. DecaBDE is expected to have low mobility in soil based on its estimated Koc. Therefore, leaching of
decaBDE through soil to groundwater is not expected to be an important transport mechanism. Estimated
volatilization half-lives for a model river indicate that it will have moderate potential to volatilize from
surface water. Volatilization potential from a model lake is expected to be low. In the atmosphere, decaBDE
is expected to exist primarily in the particulate phase. Particulate phase decaBDE will be removed from air
by wet or dry deposition.
Henry's Law Constant
(atm-m3/mole)
4.4x 10"4 at 25°C (Estimated)
EPI
Value was obtained from the
measured vapor pressure and water
solubility.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
2.8xl05 (Estimated)
EPI
Level III Fugacity Model
Air: <1% (Estimated)
Water = 1.5%
Soil = 63%
Sediment = 35%
EPI
In addition to EPI estimates, these
results were obtained by using the
measured vapor pressure, log K0„,
and water solubility.
Persistence
VERY HIGH: The persistence potential for decaBDE is Very High; it is not expected to degrade rapidly
under aerobic conditions. Slow degradation through debromination may occur under anaerobic conditions.
The anaerobic experimental results are indicative of limited removal but at very low rates that are possibly
background level degradation under the test conditions. Experimental studies indicate no degradation after 2
weeks in a ready biodegradation test, but no data were located for soil or water. Results from biodegradation
estimation models also suggest decaBDE is recalcitrant under aerobic conditions. Nonguideline experimental
studies indicate decaBDE may be capable of undergoing limited anaerobic biodegradation; however the
removal rate also suggests Very High persistence. The initially formed degradation products are also
expected to be persistent. DecaBDE is not expected to hydrolyze in the environment based on experimental
data. Experimental data indicate that decaBDE may undergo photolysis to debrominated transformation
products. Data concerning the kinetics of these photolysis reactions were not located.
4-327
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Water
Aerobic Biodegradation
No degradation after 2 weeks (Measured)
OECD Test Guideline 301C
MITI, 1998
Guideline study; reported 80%
retention in water (control) and
sludge. Study hypothesized that loss
of compound is due to decaBDE
converting to an intermediate product
under the study conditions.
Volatilization Half-life for
Model River
7.3 hours (Estimated)
EPI
Estimation model was calculated
using all applicable measured input
values and the Henry's Law Constant
obtained from the measured vapor
pressure and water solubility.
Volatilization Half-life for
Model Lake
340 days (Estimated)
EPI
Estimation model was calculated
using all applicable measured input
values and the Henry's Law Constant
obtained from the measured vapor
pressure and water solubility.
Soil
Aerobic Biodegradation
BDE 209 (decaBDE) showed no
significant degradation after 160 days
(Measured)
Nyholm et al., 2010
Nonguideline study, although the low
rate of removal is consistent with
aerobic degradation experiments in
water.
Soils spiked with 1,10, and 100 mg/kg
BDE 209 (decaBDE) and incubated for up
to 180 days; No degradation of BDE 209
was observed. (Measured)
Liu et al., 2011
Nonguideline study, although the low
rate of removal is consistent with
other aerobic degradation
experiments.
Anaerobic
Biodegradation
No degradation after 4 months in
incubated, acclimated anaerobic sediments
(Measured)
European Chemicals Bureau,
2002
Reported in a secondary source with
limited study details.
<1% degradation after 32 weeks in
anaerobic river sediments (Measured)
Schaefer and Siddiqui, 2001;
European Chemicals Bureau,
2002
Reported in a secondary source.
Study used C-14 labeled test
substance, analyzed by high
performance liquid chromatography.
4-328
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
DecaBDE in sewage sludge was broken
down into octa- and nona- BDEs; study
run with and without organic chemical
primers; half-life -700 days with primers,
longer without primers. (Measured)
Gerecke et al., 2005 and Gerecke
et al., 2006 (as described in
Illinois EPA, 2007)
Reported in a secondary source with
limited study details.
Breakdown to hexa- and nona-BDEs in
anaerobic sediment cultures after 3.5
years. Half-life = 10 years. Mole fraction
distribution of presumed metabolites with
<9 Br is <3% (Measured)
Nies et al., 2005 (as described in
Illinois EPA, 2007)
Reported in a secondary source with
limited study details.
Rapid breakdown to nonaBDEs in
anaerobic sediment cultures in the
presence of organic solvents. (Measured)
Skoczynska et al., 2005 (as
described in Illinois EPA, 2007)
Reported in a secondary source with
limited study details. Primary source
not available to be verified.
Debromination of decaBDE was found to
occur in species specific studies with
Sulfiirospillum multivorans to hepta- and
octa- BDEs in the presence of
trichloroethylene. Dehctlococcoides
species were not able to debrominate
decaBDE. (Measured)
He et al., 2006 (as described in
Illinois EPA, 2007)
Reported in a secondary source with
limited study details.
Soil Biodegradation w/
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
320 days (Estimated)
EPI
Reactivity
Photolysis
Degradation to lower brominated diphenyl
ether congeners and sometimes
polybrominated dibenzofurans reported
under varying conditions in several
laboratory studies using UV and natural
sunlight. (Measured)
European Chemicals Bureau,
2002
Based on a summary of several
laboratory studies under varying
conditions, using UV and natural
light.
4-329
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
DecaBDE absorbed into clays and organic
rich sediments experienced debromination
in UV and natural light. Debromination of
decaBDE absorbed on three metal oxides
did not occur. (Measured)
Ahn et al., 2006 (as described in
Illinois EPA, 2007)
Reported in a secondary source with
limited study details.
No evidence of light-mediated
debromination of decaBDE applied to soil
in sewage sludge in a field study. The soils
were plowed under which may have
impacted sunlight exposure. (Measured)
Sellstrom et al., 2005 (as
described in Illinois EPA, 2007)
Reported in a secondary source with
limited study details.
No significant degradation of BDE-209
(decaBDE) occurred in personal vehicle
dust samples after 56 days of constant
UVA irradiation under laboratory
conditions; however degradation occurred
when the study was performed with
decaBDE absorbed to sodium sulfate.
(Measured)
Lagalante et al., 2011
Nonguideline study demonstrating
the relative stability of decaBDE
under the test conditions.
BDE-209 (decaBDE) spiked and non-
spiked (natural) dust samples were
exposed to sunlight for 200 cumulative
hours. <38% of the original decaBDE
mass was degraded in the spiked dust,
25% of which could not be accounted for
and was lost to unknown pathways and/or
products. The remaining 13% was
accounted for by the formation of lower
brominated congeners. (Measured)
Stapleton and Dodder, 2008
Nonguideline study demonstrating
the potential for photolytic
degradation of similar highly
brominated materials.
Hydrolysis
No degradation at pH 5 and 7 at 100°C
after six weeks. (Measured)
European Chemicals Bureau,
2002
Reported in a secondary source.
4-330
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Environmental Half-life
360 days (Estimated)
PBT Profiler,
Professional judgment
Half-life estimated for the
predominant compartment, as
determined by EPI and the PBT
Profiler methodology.
Bioaccumulation
HIGH: Based on estimated BAF values suggesting that the potential for bioaccumulation is high and located
monitoring data indicating that decaBDE has been detected in higher trophic level organisms. DecaBDE
degradation, transformation and metabolism products also contribute to the high bioaccumulation hazard
designation. These compounds are lower brominated congeners and also have been detected in monitoring
studies (ATSDR, 2004).
Fish BCF
<5 to <50 (Measured)
6 week exposure in Cyprimis cctrpio with
sample concentrations of 60 ppb and 6
ppb, respectively using a method identified
as flow-through bioaccumulation test of a
chemical substance in fish or shellfish
MITI, 1998 (as described in
European Chemicals Bureau,
2002); J-Check, 2013
Nonguideline study of a commercial
product mixture containing >75%
decaBDE, approximately 17%
nonaBDE and 8% octaBDE.
BAF
49,000 (Estimated)
EPI
0.0% uptake from diet after 90 days in
Cyprinus cctrpio (Measured)
Stapleton et al., 2004
Adequate, nonguideline study.
0.005% uptake from diet after 120 days in
Oncorhvnchiis mykiss (Measured)
Kierkegaard et al., 1999
Adequate, nonguideline study.
Metabolism in Fish
Little or no uptake from water phase
exposure; limited uptake (-0.02-0.13%)
observed when exposed from food, after
120-day exposure period. (Measured)
European Chemicals Bureau,
2002
Reported in a secondary source.
Found to be metabolized in juvenile
fathead minnows and to accumulate after
28-day treatment at 9.8 j_ig/g food. A range
of penta- to octaBDEs metabolites were
detected with 2,2",4,4",5,6"-
hexabromodiphenyl ether being most
prevalent. (Measured)
Noyes et. al., 2011
Adequate, nonguideline study.
4-331
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Decabromodiphenyl Ether CASRN 1163-19-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
In vitro metabolism of BDE-209
(decaBDE) by microsomal fractions of
Chinese sturgeon found that BDE-209 was
biotransformed in liver. Debrominated
products: BDE-126, BDE-154, BDE-188,
BDE-184, BDE-183, BDE-202, BDE-201,
and BDE-204/197; after incubation.
(Measured)
A physiologically based pharmacokinetic
model (PBPK) of BDE-209 in Chinese
sturgeon was used to develop a Bayesian
hierarchical model to estimate partition
coefficients. The low calculated partition
ratios from blood to tissues would lead to
high bioaccumulation of BDE-209,
especially in absorbing organs. (Estimated)
Wan et al., 2013
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
Detected in surface water particulates; wet and dry deposition samples; sludge and effluents from wastewater
treatment plants; sediments and soils worldwide; urban, rural, and suburban atmospheric air; indoor air and house
dust (HSDB, 2011; Dodson et al., 2012).
Ecological Biomonitoring
Detected in tree bark; fish and shellfish worldwide; in cats; owl and peregrine falcon eggs in Belgium and Sweden,
respectively (HSDB, 2011); peregrine falcon eggs in California (Park et al., 2009); birds of prey, herbivore and
predator mammals, marine fish, marine invertebrates, marine mammals, marine/aquatic/other birds and vegetation
(Canada, 2010); eucalyptus leaves and pine needles (Tian, 2013).
Human Biomonitoring
Detected in breast milk (HSDB, 2011); serum (Thuresson, 2006; He et al., 2013) and blood (EPA, 2008). This
chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report (CDC,
2011).
4-332
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Ahn M-Y, Filley TR, Jafvert CT, et al. Photodegradation of decabromodiphenyl ether adsorbed onto clay minerals, metal oxides, and
sediment. Environ. Sci. Technol. 2006, 40: 215-220.
ATSDR (Agency for Toxic Substances and Disease Registry). Toxicological Profile for Polybrominated Biphenyls and
Polybrominated Diphenyl Ethers. U.S. Department of Health and Human Services: September 2004.
http://www.atsdr.cdc.gov/toxprofiles/tp68.pdf
Biesemeier J., Beck M., Silberberg H., et al. Effects of dose, administration route, and/or vehicle on decabromodiphenyl ether
concentrations in plasma of maternal, fetal, and neonatal rats and in milk of maternal rats. Drug Metab. Dispos. 2010. 38(10): 1648-
1654.
Biesemeier J., Beck M., Silberberg H., et al. 2011. An oral developmental neurotoxicity study of decabromodiphenyl ether
(DecaBDE) in rats. Birth Defects Res B Dev Reprod Toxicol 92(1): 17-35.
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
May 10, 2011).
Canada, 2010. Ecological State of the Science Report on Decabromodiphenyl Ether (decaBDE) September 7, 2010. Environment
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Electronic Equipment. DHI Water and Environment. Environmental Project No. 1142. 2007.
Darnerud PO; Erikson GS; Johannesson T; et al. VilukelaM. Polybrominated diphenyl ethers: Occurrence, dietary exposure, and
toxicology. Environ. Health. Perspect. 2001, 109(l):49-68.
Dodson, R. Perovich, L., Covaci, A., et al. After the PBDE Phase-Out: A Broad Suite of Flame Retardants in Repeat House Dust
Samples from California. Environ. Sci. Technol. 2012. 46(24): 13056-13066.
ECOSAR/EPI (EPIWIN/EPISUITE) Estimations Programs Interface for Windows, Version 1.11. U.S. Environmental Protection
Agency: Washington D.C. http://www.epa.gov/opptintr/exposure/.
4-333
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EPA (U.S. Environmental Protection Agency). High Production Volume (HPV) Data Summary for benzene l,l'-ioxybis[2,3,4,5-
pentabromo (a.k.a.Decabromodiphenyl oxide, Decabromodiphenyl ether). 2005.
EPA (U.S. Environmental Protection Agency). Toxicological Review of Decabromodiphenyl ether (BDE-209) (CAS No. 1163-19-5).
In Support of Summary Information on the Integrated Risk Information System (IRIS). EPA/635/R-07/008F. 2008.
EPA (U.S. Environmental Protection Agency). Polybrominated Diphenyl Ethers (PBDEs) Action Plan. 2009.
http://www.epa.gov/opptintr/existingchemicals/pubs/actionplans/pbdes ap 2009 1230 final.pdf.
EPA (U.S. Environmental Protection Agency) Sustainable Futures. Using NonCcmcer Screening within the SFInitiative. U.S.
Environmental Protection Agency: Washington DC. 2011. http://www.epa.gOv/opptintr/sf/pubs/noncan-screen.htm#svstemic
(accessed on February 09, 2011).
EPA, 2012. Voluntary Children's Chemical Evaluation Program (VCCEP): Decabromodiphenyl Ether (A.K. A. Decabromodiphenyl
Oxide (DBDPO). CAS # 1163-19-5. Available at: http://www.epa.gov/oppt/vccep/pubs/chem21.html
EPI (EPIWIN EPISUITE) Estimation Program Interface for Windows, Version 4.0. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
ESIS. European chemical Substances Information System. 2012. European Commission, http://esis.irc.ec.europa.eu/.
European Chemicals Bureau. EU Risk Assessment Report for Bis(Pentabromophenyl) Ether. CAS No. 1163-19-5. EINECS No. 214-
604-9. 2002.
European Chemicals Bureau. IUCLID Dataset: Bis(Pentabromophenyl) Ether. 2000. http://ecb.irc.ec.europa.eu/esis/ (accessed March
1,2011).
European Commission. EU priority list of suspected endocrine disruptors. 2012.
http://ec.europa.eu/environment/endocrine/strategy/substances en.htm#prioritv list (accessed April, 2012).
Fu, J; Suuberg, E.M. Vapor pressure of solid polybrominated diphenyl ethers determined via Knudsen effusion method. Environ. Sci.
Technol. 2011, 30:2216-2219.
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German Federal Ministry of the Environment. Substituting Environmentally Relevant Flame Retardants: Assessment Fundamentals:
Results and summary overview. Berlin, Germany: Federal Environmental Agency (Umweltbundesamt), June 2001.
Gerecke AC, Giger W, Hartmann PC, et al. Anaerobic degradation of brominated flame retardants in sewage sludge. Chemosphere
2006, 64: 311-317.
HSDB (Hazardous Substances Data Bank), 2011. Decabromodiphenyl ether (CASRN: 1163-19-5). Hazardous Substances Data Bank.
Database if the National Library of Medicine's TOXNET system, http://toxnet.nlm.nih.gov. (Accessed on July 18, 2011).
Hardy et al. 2009. Toxicology and Human Health Risk Assessment of Decabromodiphenyl Ether. Critical Reviews in Toxicology
39(S3):l-44.
He J, Robrock KR, and Alverez-Cohen L. Microbial reductive debromination of polybrominated diphenyl ethers (PBDEs). Environ.
Sci. Technol. 2006, 40: 4429-4434.
He S, Li M, Jin J, Wang Y, Bu Y, Xu M, Yeng X, Liu A. Concentrations and trends of halogenated flame retardants in the pooled
serum of residents of Laizhou Bay, China. Environ Toxicol Chem. 32(6): 1242-1247. 2013.
Illinois Environmental Protection Agency. Report on alternatives to the flame retardant decaBDE: evaluation of toxicity, availability,
affordability, and fire safety issues: A report to the governor and the general assembly. 2007.
J-Check (Japan CHEmicals Collaborative Knowledge database). Bioaccumulation: aquatic/sediment study for CASRN 1163-19-5.
2013. http://www.safe.nite.go.ip/icheck/english/template.action (accessed February 12, 2013).
Kierkegaard, A.; Balk, L.; Tjarnlund, U.; de Wit, C.; Jansson. B. Dietary Uptake and Biological Effects of Decabromodiphenyl Ether
in Rainbow Trout (Oncorhynchus mykiss). Environ. Sci. Technol. 33(10): 1612-1617. 1999.
Kociba, RJ; Frauson, LO; Humiston, CG; et al. Results of a two-year dietary feeding study with decabromodiphenyl oxide (DBDPO)
in rats. J Combust Toxicol 2:267-285. 1975.
Lagalante, A.; Shedden, C.; Greenbacker, P. Levels of polybrominated diphenyl ethers (PBDEs) in dust from personal automobiles in
conjunction with studies on the photochemical degradation of decabromodiphenyl ether (BDE-209). Environ Int. 2011, 37(5): 899-906
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Lide, D.R. CRC Handbook of Chemistry and Physics 88TH Edition 2007-2008. CRC Press, Taylor & Francis, Boca Raton, FL, p. 3-
134. 2008.
Liu, L.; Zhu, W.; Xiao, L. Yang, L. Effect of decabromodiphenyl ether (BDE 209) and dibromodiphenyl ether (BDE 15) on soil
microbial activity and bacterial community composition, Journal of Hazardous Materials, Volume 186, 883-890, 2011.
MacGregor, J.; Nixon, W. Decabromodiphenyl oxide (DBDPO): Determination of the n-octanol water partition coefficient. Wildlife
International, Ltd. Easton, MD. 1997.
Maine, unpublished. Decabromodiphenyl Ether Flame Retardant in Plastic Pallets. A Safer Alternatives Assessment Maine
Department of Environmental Protection; Maine Center for Disease Control & Prevention.
MITI (Japanese Ministry of International Trade and Industry). Biodegradation and bioaccumulation data of existing chemicals based
on the CSCL Japan. Compiled under the supervision of Chemical Products Safety Division, Basic Industries Bureau, Ministry of
International Trade & Industry, Japan; Chemicals Inspection & Testing Institute, Japan. Ed.; Japan Chemical Industry Ecology-
Toxicology & Information Center. 1998.
NAS (National Academy of Sciences) Toxicological risks of selected flame-retardant chemicals. Washington, DC: The National
Academies Press, p. 131-145. 2000. http://www.nap.edu/openbook.php7record id=9841&page=139#p2000a45a9960139001
(accessed June 23, 2008).
Nies L, Ahn M-Y, Filley T, et al. Progress Report: Anaerobic microbial reductive debromination of polybrominated diphenyl ethers.
U.S. EPA National Center for Environmental Research. EPA Grant No. R830251. 2005.
Noyes, P; Hinton, D; Stapleton H. Accumulation and debromination of decabromodiphenyl 1 ether (BDE-209) in juvenile fathead
minnows {Pimephalespromelas) induces thyroid disruption and liver alterations. Toxicol. Sci. 2011, 122(2): 265-274.
Noyes, P; Lema, S; Macauly, L; Douglas, N; Stapleton, H. Low Level Exposure to the Flame Retardant BDE-209 Reduces Thyroid
Hormone Levels and Disrupts Thyroid Signaling in Fathead Minnows. Environ. Sci. Technol. 2013, 47(17): 10012-10021.
NTP (National Toxicology Program). Toxicology and carcinogenesis studies of decabromodiphenyl oxide (CAS No. 1163-19-5) in
F344/N rats and B6C3F1 mice (feed studies). National Toxicology Program, Research Triangle Park, NC. NIH Publication No. 83-
2565. 1986.
4-336
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Nyholm, J.R.; Lundberg, C.; Andersson, P.L. Biodegradation kinetics of selected brominated flame retardants in aerobic and
anaerobic soil, Environmental Pollution, Volume 158, Issue 6, Pages 2235-2240. 2010.
Park, J; Holden, A; Chu, V; et al. Time-trends and congener profiles of PBDEs and PCBs in California Peregrine Falcons (Falco
peregrinus). Environ. Sci. Techno1. 43 (23):8744-8751. 2009.
PBT Profi 1 er Persistent (P), Bioaccumulative (B), and Toxic (T) Chemical (PBT) Profiler. U.S. Environmental Protection Agency:
Washington D.C. www.pbtprofiler.net.
Schaefer, E.; Siddiqui. A. Decabromodiphenyl oxide (DBDPO): An activated sludge, respiration inhibition test. Wildlife International,
Ltd. Easton, MD. 2001.
Sellstrom U, DeWit CA, Lundgren N, et al. Effect of sewage-sludge application on concentrations of higher-brominated diphenyl
ethers in soil and earthworms. Environ. Sci. Techno1. 2005, 39: 9064-9070.
Sifleet S. Toxicology of decabromodiphenyl ether in avian embryos: disposition of the flame retardant BDE-209 in yolk-injected
chicken embryos (Gallus gallus). 2009. A thesis presented to the Faculty of the School of Marine Science; College of William and
Mary, Virginia; Master of Science thesis. http://web.vims.edu/library/Theses/Sifleet09.pdf
Skoczynska E, Zegers B, deVoogt P, et al. Reductive debromination of polybrominated diphenyl ethers (PBDEs) by anaerobic
sediment microorganisms. Organohal. Comp. 2005, 67: 572-574;
Stapleton, H.; Alaee, M.; Letcher, R.; Baker, J. 1 .Debromination of the Flame Retardant Decabromodiphenyl Ether by Juvenile Carp
(Cyprinus carpio) following Dietary Exposure. Environ Sci Technol 38:112-119. 2004.
Stapleton, H.; Dodder, N. Photodegradation of decabromodiphenyl ether in house dust by natural sunlight. Environ Toxicol Chem.
27(2): 306-312. 2008.
Stenzel, J.; Nixon, W. Decabromodiphenyl oxide (DBDPO): Determination of the vapor pressure using a spinning rotor gauge.
Wildlife International, Ltd. Easton, MD. 1997a.
Stenzel, J.; Nixon, W. Decabromodiphenyl oxide (DBDPO): Determination of the water solubility. Wildlife International, Ltd. Easton,
MD 1997b
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Tian, M.; Chen, S-J.; Luo, Y.; Wang, J.; Zhu, Z-C.; Luo, X-J.; Mai, B-X. Air-plant exchange of brominated flame retardants at a rural
site: Influencing factor, interspecies difference, and forest scavenging. Environ Toxicol Chem.32(6): 1248-1253. 2013.
Thuresson K, Hoglund P, Hagmar L, Sjodin A, Bergman A, Jakobsson K. Apparent half-lives of hepta- to decabrominated diphenyl
ethers in human serum as determined in occupationally exposed workers. Environ Health Perspect. 2006 Feb; 114(2): 176-81.
Washington Department of Ecology. Alternatives to Deca-BDE in Televisions and Computers and Residential Furniture.
Implementation of RCW 70.76: Identifying safer and technically feasible alternatives to the flame retardant called Deca-BDE used in
the electronic enclosures of televisions and computers and in residential upholstered furniture Final report. Department of Ecology
Publication No. 09-07-041; Department of Health Publication No. 334-181. 2008. Available at:
http://www.ecv.wa.gov/biblio/0907041.html.
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Chinese Sturgeon (Acipenser sinensis) as an Example. Environ Sci TechnolAl(5): 2279-2286. 2013.
4-338
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Ethylene Bis-Tetrabromophthalimide (EBTBP)
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
§ Based on analogy to experimental data for a structurally similar compound.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Ethylene Bis-Tetrabromophthalimide
32588-76-4
L
M
L
L
L
L
L
VL
VL
L
L
VH
H
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
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Ethylene Bis-Tetrabromophthalimide (EBTBP)
CASRN: 32588-76-4
MW: 951.5
MF: C18H4Br8N204
Physical Forms: Solid
Neat:
Use: Flame retardant
SMILES: 0=ClN(C(=0)c2c(c(c(c(cl2)Br)Br)Br)Br)CCNlC(=0)c2c(c(c(c(c2Br)Br)Br)Br)Cl=0
Synonyms: lH-Isoindole-l,3(2H)-dione, 2,2'-(l,2-ethanediyl)bis[4,5,6,7-tetrabromo-; Saytex BT 93; Ethylene bis(tetrabromophthalimide); 2,2'-(l,2-
Ethanediyl)bis(4,5,6,7-tetrabromo-lH-isoindole-l,3(2H)-dione); N,N'-Ethylenebis(3,4,5,6-tetrabromophthalimide); EBTPI
Chemical Considerations: This alternative is a discrete organic chemical with a MW <1,000. EPI v 4.1 was used to estimate physical-chemical and fate values. No
measured values were incorporated due to an absence of experimental data.
Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: None
Analog: Decabromodiphenyl Ether (CASRN 1163-19-5)
Endpoint(s) using analog values: Developmental Effects
Analog Structure:
Br Br
Decabromodiphenyl Ether (CASRN 1163-19-5)
Structural Alerts: None identified
Risk Phrases: Not classified by Annex I Directive 67/548/European Economic Community & IUCLID (Pakalin et al., 2007)
Hazard and Risk Assessments: Risk assessment completed for Ethylene bis-tetrabromophthalimide (EBTBP) by Denmark in 2007 (Stuer-Lauridsen, 2007) and a
dossier was completed by Albemarle Corporation for EPA's High Production Volume Program (EPA, 2008a).
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
446 (Measured)
NIEHS, 1999
Nonguideline study, yet established
method considered sufficient for a
screening assessment.
Boiling Point (°C)
>300 (Estimated)
EPI; EPA, 1999
Cutoff value for high boiling point
compounds according to High
Production Volume (HPV)
assessment guidance.
Vapor Pressure (mm Hg)
0.0000017 (Measured)
Reported as 2.27 xlO"4 Pa at 20°C using
the spinning rotor gauge method
Organisation of Economic Cooperation
and Development (OECD) 104
Lezotte et al., 2005
Guideline study with commercial
product. Purity of the sample was not
provided or determined.
Water Solubility (mg/L)
<10° (Estimated)
EPI; EPA, 1999
Cutoff value for non-soluble
compounds according to HPV
assessment guidance.
Log Kow
9.8 (Estimated)
EPI; EPA, 1999
Near cutoff value for non-soluble
compounds according to HPV
assessment guidance.
Flammability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Pyrolysis
No data located.
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
pKb
5.48 (Estimated)
SPARC
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
Ethylene bis-tetrabromophthalimide as a neat material is estimated to nc
exposure and is expected to have poor absorption for all routes when in s
tetrabromophthalimide is distributed through tissues, but dissipates afte
primarily in the feces and urine. There were no data located regarding a
>t be absorbed by any route of
olution. Ethylene bis-
r exposure ceases; it is excreted
)sorption or metabolism.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
No absorption through all routes as neat
material; poor absorption through all
routes when in solution (Estimated by
analogy)
Professional judgment
Based on closely related
confidential analogs with similar
structures, functional groups, and
physical/chemical properties.
Rat, oral (gavage), 14-day exposure to
14C-labeled BT93; excreted primarily in
the feces (65% of total dose) and urine
(15% of total dose); minor amounts of
14C-label was found in tissues, but
dissipated within the 30-day withdrawal
period.
NIEHS 1999; IUCLID 2000
Reported in a secondary source
with limited study details.
Acute Mammalian Toxicity
LOW: Based on acute oral and dermal LDS0 values of >2000 mg/kg and the inhalation LCS0 value of
>20 mg/L.
Acute Lethality
Oral
Rat oral LD50 >5,000 mg/kg
IUCLID, 2000
Reported in a secondary source;
limited study details provided.
Rat oral LD50 >7,500 mg/kg
NIEHS 1999; EPA, 2008a
Reported in a secondary source;
some study details provided.
Dermal
Rabbit dermal LD50 >2,000 mg/kg
IUCLID, 2000
Reported in a secondary source;
some study details provided.
Inhalation
Rat inhalation 1 hr LC50 >203 mg/L
NIEHS, 1999; IUCLID, 2000
Reported in a secondary source;
limited study details provided; not
the preferred 4-hour exposure.
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Other Acute
Effects
Rat 1-hour inhalation to a dust
atmosphere of ethylene bis
(tetrabromophthalimide) of 4,500 ±
3,000 mg/irf resulted in dyspnea, and
dry, red, brown matter around the
muzzle. There were no changes in body
weight gain during a 14-day observation
period.
LOAEL = 4,500 ± 3,000 mg/m3
NIEHS, 1999
Reported in a secondary source;
limited study details provided; the
rats were only exposed to one
concentration of the test substance
and the mean concentration the rats
were exposed to was quite variable,
as indicated by a large standard
deviation.
Carcinogenicity
MODERATE: Estimated based on lack
suitable analog; carcinogenicity cannot
of experimental carcinogenicity data for this compound or a
)e ruled out.
OncoLogic Results
Not amenable to available
estimation method.
Carcinogenicity (Rat
and Mouse)
No data located.
Combined Chronic
Toxicity/
Carcinogenicity
No data located.
Genotoxicity
LOW: Ethylene bis-tetrabromophthalimide did not cause mutations in bacterial cells or chromosomal
aberrations in mammalian cells in vitro.
Gene Mutation in vitro
Negative, S. typhimiirium TA98, TA100,
TA1535, TA1537, TA1538; E. coli
WP2uvrA with and without metabolic
activation.
NIEHS, 1999; IUCLID, 2000;
EPA, 2008a; CCRIS, 2011;
NTP, 2011
Reported in secondary sources;
sufficient study details provided.
Negative, S. typhimiirium TA98,
TA1535, TA1537 with and without
metabolic activation.
Zeigeretal., 1985
Reported in a primary source;
adequate study details provided.
Negative, S. typhimiirium TA98, TA100,
TA1535, TA1537, TA1538; ,S'. cerevisiae
D4 with and without metabolic
activation.
NIEHS, 1999; IUCLID, 2000;
EPA, 2008a
Reported in a secondary source;
sufficient study details provided.
Gene Mutation in vivo
No data located.
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Chromosomal
Aberrations in vitro
Negative, Chinese hamster ovary cells
with and without metabolic activation.
EPA, 2008a
Reported in a secondary source;
sufficient study details provided.
Chromosomal
Aberrations in vivo
No data located.
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
Reproductive Effects
LOW: Based on professional judgment, there is low potential for reproductive toxicity.
Reproduction/
Developmental Toxicity
Screen
Low potential for reproductive toxicity.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Reproduction and
Fertility Effects
Developmental Effects
MODERATE: Ethylene bis-tetrabromophthalimide did not cause developmental effects in rats or rabbits
following gestational exposure at oral doses as high as 1,000 mg/kg bw-day. However, there is a lack of
developmental neurotoxicity data for this compound. A concern for developmental neurotoxicity has been
identified for DecaBDE, an analog that shares a key structural feature with ethylene bis-
tetrabromophthalimide. Ethylene bis-tetrabromophthalimide also possesses structural features that are not
present in DecaBDE and, as a result, the confidence in this assignment is low. Given the absence of
developmental neurotoxicity data, potential concerns cannot be ruled out, and an estimated Moderate
hazard designation is consistent with the assessment methodology discussed in Chapter 4.
Reproduction/
Developmental Toxicity
Screen
No data located.
4-344
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
Prenatal Development
Sprague-Dawley rats (25/group) were
administered ethylene bis-
tetrabromophthalimide by gavage at 0,
100, 500, or 1,000 mg/kg bw-day on
gestation days (GD) 6-15. There were no
treatment-related effects on maternal
survival, body weight gains, food
consumption. There were no treatment-
related changes in intrauterine survival
and fetal weight, and no changes in the
incidence of developmental
malformations and variations compared
to controls
Parental toxicity:
NOAEL >1,000 mg/kg bw-day (highest
dose tested)
Reproductive toxicity:
NOAEL >1,000 mg/kg bw-day (highest
dose tested)
NIEHS, 1999; IUCLID, 2000;
EPA, 2008a
Reported in secondary sources;
sufficient study details provided;
follows OECD guidelines. The
study is in accordance with EPA
OPPTS method 870.3700.
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
New Zealand white rabbits (20/group)
were administered ethylene bis-
tetrabromophthalimide by gavage at 0 or
1,000 mg/kg bw-day on GD 7-19. There
were no treatment-related effects on
maternal survival, body weight gains,
food consumption. There were no
treatment-related changes in intrauterine
survival and fetal weight, and no changes
in the incidence of developmental
malformations and variations compared
to controls
Parental toxicity:
NOAEL >1,000 mg/kg bw-day (highest
dose tested
Reproductive toxicity:
NOAEL >1,000 mg/kg bw-day (highest
dose tested
NIEHS, 1999; IUCLID, 2000;
EPA, 2008a
Reported in secondary sources;
sufficient study details provided.
The study is in accordance with
OPPTS method 870.3700; only one
dose level tested.
Postnatal Development/
Developmental
Neurotoxicity
Evaluation of locomotor activity in
C57BL6/J mice.
NOAEL: not established
LOAEL: 6 mg/kg-day (based on
decreased T4 levels in male mice and
effects on locomotor
(Estimated by analogy)
EPA, 2008b; Washington DOE,
2008; Professional judgment
Estimated based on analogy to
decaBDE which contains similar
structural features; study details
reported in a secondary source. It
should also be noted that ethylene
bis-tetrabromophthalimide contains
structural features that are not
present in decaBDE. Analogs
possessing experimental data and
containing all of the structural
features of ethylene bis-
tetrabromophthalimide were not
located.
4-346
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Single dose gavage in male Sprague
Dawley rats;
NOAEL: Not established
LOAEL: 6.7 mg/kg (Dose-related
disruption in habituation [changes in
locomotion, rearing, total activity] at
both doses).
(Estimated by analogy)
EPA, 2008b; Professional
judgment
Estimated based on analogy to
decaBDE; each dose administered a
single time; not a guideline study.
Study details reported in a
secondary source. It should also be
noted that ethylene bis-
tetrabromophthalimide contains
structural features that are not
present in decaBDE. Analogs
possessing experimental data and
containing all of the structural
features of ethylene bis-
tetrabromophthalimide were not
located.
NMRI male mice gavaged with
decaBDE (99% pure) at 0, 2.22, or 20.1
mg/kg on PNDs3-19 or 0, 1.34, 13.4 or
20.1 mg/kg on PND10.
Dose-related disruption in habituation
(changes in locomotion, rearing, total
activity) at 2, 4, and 6 months following
exposure to 20.1 mg/kg on PND3.
NOAEL: 2.22 mg/kg
LOAEL: 20.1 mg/kg
(Estimated by analogy)
European Chemicals Bureau
2002; EPA, 2008b; Professional
judgment
Estimated based on analogy to
decaBDE; each dose administered a
single time; not a guideline study.
Study details reported in a
secondary source. It should also be
noted that ethylene bis-
tetrabromophthalimide contains
structural features that are not
present in decaBDE. Analogs
possessing experimental data and
containing all of the structural
features of ethylene bis-
tetrabromophthalimide were not
located.
4-347
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Neurotoxicity
LOW: Estimated to have Low potential for neurotoxicity effects estimate
structural alerts that have been [experimentally] associated with the neu
experimental data located on this endpoint for ethylene bis-tetrabromop
d based on the absence of
rotoxicity endpoint. There were no
ithalimide or an analog.
Neurotoxicity Screening
Battery (Adult)
Low potential for neurological effects.
(Estimated)
Professional judgment
Estimated based on the absence of
structural alerts that have been
[experimentally] associated with the
neurotoxicity endpoint.
Repeated Dose Effects
LOW: A 28- or 90-day dietary exposure to ethylene bis-tetrabromophthalimide in rats at doses as high as
1,000 mg/kg bw-day did not cause adverse effects on growth parameters, clinical chemistry, organ weights
and weight ratios, or macro and micro pathology. By analogy to decaBDE and with the potential for
bioaccumulation, there is potential for expression of adverse effects in longer term studies.
Potential for repeated dose effects
(Estimated by analogy and
bioaccumulation)
Professional judgment
Estimated based on the high
potential for bioaccumulation and
by analogy to observations on
decaBDE where adverse effects
were not present in 90-day studies
but were expressed following
chronic exposure in a National
Toxicology Program study.
In a 2 8-day oral (dietary) study in male
rats (10/group) fed 0, 0.01, 0.1, or 1%
ethylene bis-tetrabromophthalimide,
there were no treatment-related changes
in growth parameters or food
consumption, clinical chemistry,
terminal organ weights or weight ratios,
or gross and microscopic tissues.
NOAEL >1% in diet (>1,000 mg/kg-
bw-day) (highest dose tested)
NIEHS, 1999; IUCLID, 2000;
EPA, 2008a
Reported in a secondary source;
sufficient study details provided.
The study does not conform to
current guidelines.
4-348
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
In a 90-day oral (dietary) study in rats
fed 0, 0.01, 0.1, or 1% ethylene bis-
tetrabromophthalimide, there were no
treatment-related changes in growth
parameters or food consumption, clinical
chemistry, terminal organ weights or
weight ratios, or gross and microscopic
tissues; there were unspecified changes
in urinalysis.
NOAEL >1% in diet (>1,000 mg/kg bw-
day) (highest dose tested)
NIEHS 1999; IUCLID 2000;
EPA, 2008a
Reported in a secondary source;
sufficient study details provided.
The study does not conform to
current guidelines.
Skin Sensitization
LOW: Estimated to have Low potential for skin sensitization based on expert judgment.
Skin Sensitization
Low potential for skin sensitization
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
VERY LOW: Ethylene bis-tetrabromophthalimide is not an eye irritant in rabbits.
Eye Irritation
Not irritating, New Zealand white rabbit
NIEHS, 1999; IUCLID, 2000
Reported in a secondary source;
some study details provided.
Not irritating, albino rabbit
IUCLID, 2000
Reported in a secondary source;
limited study details provided.
Dermal Irritation
VERY LOW: Ethylene bis-tetrabromophthalimide is not a skin irritant in rabbits.
Dermal Irritation
Not irritating, rabbit; 24-hour occlusive
dressing
IUCLID, 2000
Reported in a secondary source;
limited study details provided.
Not irritating, rabbit; 24-hour abraded
and nonabraded sites; 24-hour occlusive
dressing
NIEHS, 1999; IUCLID, 2000
Reported in secondary sources;
sufficient study details provided.
Endocrine Activity
No data located.
No data located.
Immunotoxicity
Estimated to have no potential for immunotoxicity based on expert judgment.
Immune System Effects
Expected to not have potential for
immunotoxicity (Estimated)
Expert judgment
Estimated based on expert
judgment.
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ECOTOXICITY
ECOSAR Class
Imides; Amides
Acute Toxicity
LOW: Estimated data suggest no effects at saturation (NES) for the acute aquatic toxicity endpoints;
experimental results are too short a duration to assess the hazard of acute aquatic toxicity, but are
consistent with this hazard designation.
Fish LC50
Oryzias latipes (orange-red killifish)
48-hour LC50 >500 mg/L (static)
(Experimental)
NIEHS, 1999; IUCLID, 2000;
EPA, 2008a
48-hour exposure study as opposed
to preferred 96-hour study;
according to Japanese Ministry of
International Trade and Industry
(MITI) guidelines.
Fish
96-hour LC50 = 0.000084 mg/L
(Estimated)
ECOSAR: Amides
ECOSAR version 1.11
NES: The log K0„ of 9.8 for this
chemical exceeds the structure
activity relationship (SAR)
limitation for log Kow of 5.0; NES
are predicted for these endpoints.
Fish 96-hour LC50 = 0.00022 mg/L
(Estimated)
ECOSAR: Imides
ECOSAR version 1.11
NES: The log K0„ of 9.8 for this
chemical exceeds the SAR
limitation for log K0„ of 5.0; NES
are predicted for these endpoints.
Fish 96-hour LC50 = 0.00019 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 9.8 for this
chemical exceeds the SAR
limitation for log K0„ of 5.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid LCS0
Daphnid
48-hour LC50 = 0.000274 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 9.8 for this
chemical exceeds the SAR
limitation for log K0„ of 5.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Daphnid
48-hour LCso = 0.000469 mg/L
(Estimated)
ECOSAR: Imides
ECOSAR version 1.11
NES: The log Kow of 9.8 for this
chemical exceeds the SAR
limitation for log K0„ of 5.0; NES
are predicted for these endpoints.
Daphnid
48-hour LCso = 0.000695 mg/L
(Estimated)
ECOSAR: Amides
ECOSAR version 1.11
NES: The log Kow of 9.8 for this
chemical exceeds the SAR
limitation for log Kow of 5.0; NES
are predicted for these endpoints.
Green Algae ECS0
Green algae
96-hour ECso = 0.003 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 9.8 for this
chemical exceeds the SAR
limitation for log Kow of 6.4; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
4-351
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae
96-hour EC50 = 0.02 mg/L
(Estimated)
ECOSAR: Imides
ECOSAR version 1.11
NES: The log K0„ of 9.8 for this
chemical exceeds the SAR
limitation for log K0„ of 6.4; NES
are predicted for these endpoints.
Green algae
96-hour EC50 = 0.014 mg/L
(Estimated)
ECOSAR: Amides
ECOSAR version 1.11
NES: The log Kow of 9.8 for this
chemical exceeds the SAR
limitation for log K0„ of 6.4; NES
are predicted for these endpoints.
Chronic Aquatic Toxicity
LOW: Estimated data suggest NES for chronic aquatic toxicity endpoints.
Fish ChV
Fish
30-day ChV = 0.000000494 mg/L
(Estimated)
ECOSAR: Amides
ECOSAR version 1.11
NES: The log Kow of 9.8 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted for these endpoints.
Fish
30-day ChV = 0.0000196 mg/L
(Estimated)
ECOSAR: Imides
ECOSAR version 1.11
NES: The log Kow of 9.8 for this
chemical exceeds the SAR
limitation for log Kow of 8.0; NES
are predicted for these endpoints.
Fish
30-day ChV = 0.0000148 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 9.8 for this
chemical exceeds the SAR
limitation for log Kow of 8.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Daphnid ChV
Daphnid ChV = 0.00000917 mg/L
(Estimated)
ECOSAR: Amides
ECOSAR version 1.11
NES: The log Kow of 9.8 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted for these endpoints.
4-352
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid ChV = 0.000115 mg/L
(Estimated)
ECOSAR: Imides
ECOSAR version 1.11
NES: The log K0„ of 9.8 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted for these endpoints.
Daphnid ChV = 0.000101 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 9.8 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Green Algae ChV
Green algae
ChV = 0.004 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 9.8 for this
chemical exceeds the SAR
limitation for log Kow of 8.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Green algae
ChV = 0.008 mg/L
(Estimated)
ECOSAR: Imides
ECOSAR version 1.11
NES: The log K0„ of 9.8 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted for these endpoints.
4-353
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae
ChV = 1.59 mg/L
(Estimated)
ECOSAR: Amides
ECOSAR version 1.11
NES: The log K0„ of 9.8 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted for these endpoints.
ENVIRONMENTAL FATE
Transport
The transport evaluation for ethylene bis-tetrabromophthalimide is based on estimated physical and
chemical properties. Based on the Level III fugacity models incorporating the located experimental property
data, ethylene bis-tetrabromophthalimide is expected to partition primarily to soil. It is not expected to
dissociate at environmentally-relevant pH. Ethylene bis-tetrabromophthalimide is expected to have low
mobility in soil based on its estimated Koc. Therefore, leaching of ethylene bis-tetrabromophthalimide
through soil to groundwater is not expected to be an important transport mechanism. Estimated
volatilization half-lives indicate that it will be non-volatile from surface water. In the atmosphere, ethylene
bis-tetrabromophthalimide is expected to exist in the particulate phase, based on its estimated vapor
pressure. Particulates will be removed from air by wet or dry deposition.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
EPI; Professional judgment
Cutoff value for nonvolatile
compounds.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
EPI; EPA, 2004
Cutoff value for nonmobile
compounds.
Level III Fugacity Model
Air <1%
Water = 5.4%
Soil = 95%
Sediment <1% (Estimated)
EPI
Persistence
VERY HIGH: The very high persistence for ethylene bis-tetrabromophthalimide is based on limited
experimental data and quantitative structure activity relationship (QSAR) estimates. No degradation
observed in activated sludge during a MITI test, indicating it is not biodegradable under the stringent test
conditions. Results from biodegradation models provided similar results and indicate that it will be
recalcitrant under aerobic conditions. Anaerobic degradation under methanogenic conditions is not
considered probable. The atmospheric half-life of ethylene bis-tetrabromophthalimide is estimated to be 3.3
hours, although it is expected to exist primarily in the particulate phase in air. Resistance to most
environmental fate processes indicates that ethylene bis-tetrabromophthalimide is expected to be persistent in
the environment.
4-354
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Water
Aerobic Biodegradation
Recalcitrant (Primary and Ultimate Survey
Model) (Estimated)
EPI
Volatilization Half-life for
Model River
>1 year (Estimated)
EPI
Volatilization Half-life for
Model Lake
>1 year (Estimated)
EPI
Soil
Aerobic Biodegradation
0% after 28 days
MITI test
(Measured)
EPA, 2008a
Guideline study reported in a
secondary source.
Anaerobic
Biodegradation
Not probable (Anaerobic-methanogenic
biodegradation probability model)
(Estimated)
EPI
Soil Biodegradation w/
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
3.3 hours (Estimated)
EPI
Reactivity
Photolysis
No data located.
Hydrolysis
No data located.
Environmental Half-life
>180 days (Estimated)
EPI; PBT Profiler
Half-life estimated for the
predominant compartment, as
determined by EPI and the PBT
Profiler methodology.
Bioaccumulation
HIGH: The potential for bioaccumulation of ethylene bis-tetrabromophthalimide is high based on the
estimated BAF. When a single BCF measurement is available Design for the Environment assessment criteria
indicate that estimated BAF values are used in a conservative approach. The BAF estimate is consistent with
that anticipated for high MW chemicals with a high degree of bromination.
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Ethylene Bis-Tetrabromophthalimide CASRN 32588-76-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish BCF
<0.3 - <3 depending on the concentration
tested; in Japanese carp using OECD Test
Guideline 305C (Measured)
Hardy, 2004
Guideline study reported in a
secondary source. This study is most
appropriately applied to organic
chemicals with K0w values of 1.5-
6.0; the experimental set up did not
include exposure through food.
BAF
1.7x 105 (Estimated)
EPI
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-356
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CCRIS. Chemical Carcinogenesis Research Information System. l,2-bis(tetrabromophthalimide) ethane. 2011.
http://toxnet.nlm.nih.gov (Accessed on March, 2011).
Centers for Disease Control and Prevention (CDC). Fourth National Report on Raman Exposure to Environmental Chemicals,
Updated Tables. Department of Health and Human Services 2011. Available at:
http://www.cdc.gov/exposurereport/pdf/Updated_Tables.pdf as of May 10, 2011.
[HPV Assessment Guidance] EPA (U.S. Environmental Protection Agency/ Determining the Adequacy of Existing Data. U.S.
Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadeqfn.pdf
ECOSAR/EPI (EPIWIN/EPISUITE) Estimations Programs Interface for Windows, Version 1.11. U.S. Environmental Protection
Agency: Washington D.C. http://www.epa.gov/opptintr/exposure/.
U.S. EPA (Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing
Data. U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
EPA. 2004. The Pollution Prevention (P2) Framework, EPA-748-B-03-001. Office of Pollution Prevention and Toxics 7403M, U.S.
Environmental Protection Agency, Washington, DC. 20460. October 2003 version updated in January 2004. Latest version available
at http://www.epa.gov/opptintr/newchems/pubs/sustainable/p2frame-iune05a2.pdf
EPA (U.S. Environmental Protection Agency). High Production Volume Challenge. Robust summaries and test plans: lH-isonindole-
l,3(2H)-dione, 2,2'-(l,2-ethanediyl)bis(4,5,6,7-tetrabromo-. 2008a.
http://www.epa.gov/chemrtk/pubs/summaries/lhisoind/cl5090tc.htm
EPA (U.S. Environmental Protection Agency). Toxicological Review of Decabromodiphenyl ether (BDE-209) (CAS No. 1163-19-5).
In Support of Summary Information on the Integrated Risk Information System (IRIS). EPA/635/R-07/008F. 2008b.
EPI (EPIWIN/EPISUITE) Estimation Program Interface for Windows, Version 4.10. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
European Chemicals Bureau. EU Risk Assessment Report for Bis(Pentabromophenyl) Ether. CAS No. 1163-19-5. EINECS No. 214-
604-9. 2002.
4-357
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Hardy, ML. A comparison of the fish bioconcentration factors for brominated flame retardants with their nonbrominated analogues.
Environ Toxicol Chem 2004, 23:657-661.
IUCLID (International Uniform Chemical Information Database). N,N'-ethylenebis(3,4,5,6-tetrabromophthalimide (32588-76-4).
European Commission. European Chemicals Bureau. 2000. http://ecb.irc.ec.europa.eu/iuclid-datasheet/32588764.pdf
Lezotte, F.; Nixon, W. Determination of the vapor pressure of Saytex BT93 using the spinning rotor gauge method. Wildlife
International, Ltd. Easton, MD. 2005.
NIEHS (National Institute of Environmental Health Sciences). Ethylenebis(tetrabromophthalimide) [CASRN 32588-76-4], Review of
toxicological literature. National Institute of Environmental Health Sciences 1999.
http://ntp.niehs.nih.gov/ntp/htdocs/Chem Background/ExSumPdf/Ethylenebistet.pdf
NTP (National Toxicology Program). Genetic toxicology studies for ethylenebis(tetrabromophthalimide).National Toxicology
Program. 2011. http://ntp-apps.niehs.nih.gov/ntp tox/index.cfm?searchterm=32588-76-4&fuseaction=ntpsearch.searchresults
PBT Profi 1 er Persistent (P), Bioaccumulative (B), and Toxic (T) Chemical (PBT) Profiler. U.S. Environmental Protection Agency:
Washington D.C. www.pbtprofiler.net.
Pakalin, S., Cole, T., Steinkellner, J., et al. Review on production processes of decabromodiphenyl ether (DECABDE) used in
Polymeric applications in electrical and electronic equipment, and assessment of the availability of potential alternatives to
DECABDE. [Online] 2007. Available at: http://ecb.irc.ec.europa.eu/documents/Existing-
Chemicals/Review on production process of decaBDE.pdf as of January 20, 2011.
SPARC. SPARC On Line Calculator pKaproperty server. Ver4.5 September, 2009. Available at: http://archemcalc.com/sparc/ as of
May 10, 2011.
Stuer-Lauridsen, F; Cohr, K-H; Andersen T.T. Assessment of Alternatives to Deca-BDE in Electrical and Electrical Equipment.
Danish Ministry of the Environment. Health and Environmental 2007. Environmental Project No. 1142.
4-358
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Washington Department of Ecology. Alternatives to Deca-BDE in Televisions and Computers and Residential Furniture.
Implementation of RCW 70.76: Identifying safer and technically feasible alternatives to the flame retardant called Deca-BDE used in
the electronic enclosures of televisions and computers and in residential upholstered furniture Final report. Department of Ecology
Publication No. 09-07-041; Department of Health Publication No. 334-181. 2008. Available at:
http://www.ecv.wa.gov/biblio/0907Q41.html.
Zeiger E., Haworth S., Mortelmans K, et al. Mutagenicity testing of di(2-ethylhexyl)phthalate and related chemicals in Salmonella.
Environ. Mutagen. 1985, 7:213-232
4-359
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Magnesium Hydroxide
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
R Recalcitrant: Substance is comprised of metallic species that will not degrade, but may change oxidation state or undergo complexation processes under enviromnental conditions.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Magnesium Hydroxide
1309-42-8
L
L
L
L
L
L
L
L
L
L
L
Hr
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
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Magnesium Hydroxide
OH
HO"*M9
CASRN: 1309-42-8
MW: 58.32
MF: MgH202
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: 0[Mg]0
Synonyms: Magnesium hydroxide (Mg(OH)2); Brucite; Milk of Magnesia; AlcanexNHC 25; Asahi Glass 200-06; Baschem 12; Combustrol 500; Duhor; DuhorN;
Ebson RF; FloMag H; FloMag HUS; Hydro-mag MA; Hydrofy G 1.5; Hydrofy G 2.5; Hydrofy N; Kisuma 4AF; Kisuma 5; Kisuma 5A; Kisuma 5B; Kisuma 5B-N;
Kisuma 5BG; Kisuma 5E; Kisuma 78; Kisuma S 4; Kyowamag F; Lycal 96 HSE; Mag Chem MH 10; Magnesia hydrate; MagneClear 58; Magnesia magma;
Magnesiamaito; Magnesium dihydroxide; Magnesium hydroxide gel; Magnesium(II) hydroxide; Magnifin H 10; Magox; Marinco H; Marinco H 1241; Martinal VPF
8812; Milmag; Mint-O-Mag; Nemalite; Oxaine M; Phillips Magnesia Tablets; Phillips Milk of Magnesia Liquid; Reachim; Star 200; Versamag
Chemical considerations: This alternative is an inorganic compound. In the absence of experimental data, professional judgment using chemical class and structural
considerations were used to complete this hazard profile.
Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: Not applicable
Analog: No analogs; Mg + ions are expected to form when Mg(OH) 2 and other
magnesium containing compounds dissociate in aqueous conditions. Studies
included in this assessment include other sources of Mg2+ like MgCl2.
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: None
Risk Phrases: Not classified by Annex VI Regulation (EC) No 1272/2008 (ESIS, 2011).
Hazard and Risk Assessments: Risk assessment completed for magnesium hydroxide by the National Academy of Sciences in 2000 (NAS, 2000).
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
Decomposes at 350 (Measured)
Hodgman, 1959; Lewis, 1997;
Lewis, 2000
MgO and H20 are decomposition
products.
Decomposes at 380 (Measured)
IUCLID, 2000
350 (Measured)
Lide, 2000; Aldrich, 2006
Boiling Point (°C)
Will decompose before boiling (Measured)
IUCLID, 2000
Decomposition occurs upon melting
as described in additional sources
above.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; EPA,
1999
Cutoff value for nonvolatile
compounds according to HPV
assessment guidance. This inorganic
compound is not amenable to
available estimation methods.
Water Solubility (mg/L)
1.78 at 20°C, pH 8.3 (Measured)
According to Organisation of Economic
Cooperation and Development (OECD)
105 column elution method
ECHA, 2013
Guideline study; results are in
agreement with other experimental
values.
9 at 18°C (Measured)
Hodgman, 1959; IUCLID, 2000
Measured values, which span a
relatively narrow range, are
consistently reported in numerous
sources.
1 at 20°C (Measured)
IUCLID, 2000
6 at 20°C (Measured)
IUCLID, 2000
<8 at 20°C (Measured)
IUCLID, 2000
40 at 100°C (Measured)
Hodgman, 1959
Value obtained at an elevated
temperature.
Log Kow
No data located; inorganic
compounds are outside the estimation
domain of EPI.
Flammability (Flash Point)
Not flammable (Estimated)
IUCLID, 2000
Adequate.
Explosivity
Not explosive (Estimated)
IUCLID, 2000
Adequate.
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Pyrolysis
Not applicable (Estimated)
Professional judgment
Inorganic compounds do not undergo
pyrolysis.
pH
9.5-10.5 (Measured)
O'Neiletal., 2011
Adequate.
pH of a saturated solution in water was 8.3
(Measured)
ECHA, 2013
Reported in a secondary source,
determined from a water solubility
study.
pKa
No data located; inorganic
compounds are outside the estimation
domain of the SPARC model.
HUMAN HEALTH EFF
ECTS
Toxicokinetics
Some magnesium hydroxide is absorbet
following ingestion and is excreted primarily in urine.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
The magnesium ion is poorly absorbed;
when taken orally, only 5-15% of the
magnesium from a dose of magnesium
hydroxide is absorbed and this
magnesium is readily excreted in the
urine, if kidney function is normal.
IUCLID, 2000
Reported in a secondary source,
limited study details provided.
Acute Mammalian Toxicity
LOW: Acute lethality values suggest tha
exposure. There were no adequate data
t magnesium hydroxide has Low hazard for acute toxicity for oral
ocated regarding acute dermal and inhalation exposure.
Acute Lethality
Oral
Rat oral LD50 = 8,500 mg/kg-bw
Lewis, 2000
Reported in a secondary source,
limited study details provided.
Mouse oral LD50 = 8,500 mg/kg-bw
Lewis, 2000
Reported in a secondary source,
limited study details provided.
Human infant oral TDLo (behavioral) =
2,747 mg/kg
Lewis, 2000
Reported in a secondary source,
limited study details provided.
Probable human oral lethal dose =
5-15 g/kg-bw
HSDB, 2013
Reported in a secondary source,
limited study details provided.
Dermal
No data located.
Inhalation
Rat inhalation LC50>2.1 mg/L
ECHA, 2013
Reported in a secondary source.
There was no mortality at the
highest dose tested (2.1 mg/L).
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Carcinogenicity
LOW: Experimental studies indicate that magnesium hydroxide has low hazard for carcinogenicity.
OncoLogic Results
Structure could not be evaluated by
OncoLogic.
Carcinogenicity (Rat
and Mouse)
5 -week, repeated-dose/carcinogenicity
study, oral (diet), rat;
Decreased number of carcinogen-
induced DNA synthesis in the large
bowel epithelial cells.
NOAEL >2,000 ppm (approximately 100
mg/kg/day, highest dose tested)
BIBRA, 1993
Reported in a secondary source,
limited study details provided.
Combined Chronic
Toxicity/
Carcinogenicity
96-week chronic toxicity/carcinogenicity
study on MgCl2, oral, mouse; no
significant differences in tumor
incidence between treated and control
animals except for dose-related decrease
in the incidence of hepatocellular
carcinomas in males.
Kurataetal., 1989
Sufficient study details reported in a
primary source.
227-day, chronic toxicity/
carcinogenicity study, oral (diet), rat;
decreased number of colon tumors in rats
pretreated with a known colon
carcinogen.
NOAEL >50 mg/kg/day (highest dose
tested)
BIBRA, 1993
Reported in a secondary source,
limited study details provided.
16-week carcinogenicity study, oral
(diet), rat; inhibitory effects on colon
carcinogenesis, carcinogen-induced
expression of c-myc proto-oncogene and
cell proliferation.
NOAEL = 0.2% in diet (highest
concentration tested)
Wang et al., 1993
Sufficient study details reported in a
primary source.
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Inhalation exposure of male rats to short
(4.9x0.31 mm) or long (12 x 0.44 mm)
MgSOV5Mg(OH)2 3H20 filaments for 6
hour/day, 5 day/week for up to 1 year did
not increase the incidence of any tumor
types in animals sacrificed 1 day or 1
year after cessation of exposure.
NAS, 2000
Reported in a secondary source,
limited study details provided.
Genotoxicity
LOW: Experimental studies indicate that magnesium hydroxide is not mutagenic to bacteria or mammalian
cells in vitro and does not cause chromosomal aberrations in human lymphocytes in vitro.
Gene Mutation in vitro
Negative, Ames Assay in Salmonella and
Escherichia coli
BIBRA, 1993
Reported in a secondary source,
limited study details provided. Only
3 strains of Salmonella were tested;
current regulatory guidelines
suggest that at least 4 strains be
used in Ames tests.
Negative; mouse lymphoma assay,
L5178Y cells; with and without
metabolic activation
ECHA, 2013
Reported in a secondary source.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
Negative; did not induce chromosomal
aberrations in human lymphocytes; with
and without metabolic activation
ECHA, 2013
Reported in a secondary source.
Chromosomal
Aberrations in vivo
No data located.
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproductive Effects
LOW: There were no reproductive effects observed in rats in a repeated dose toxicity study with the
reproduction/developmental toxicity screen at doses of magnesium hydroxide as high as 1,000 mg/kg-day. In
addition, magnesium hydroxide is expected to have low hazard for reproductive effects based on a
nonstandard experimental study indicating magnesium chloride produces no adverse effects on
reproductive performance or outcomes at levels up to 96 mg/kg/day of Mg2+ion.
Reproduction/
Developmental Toxicity
Screen
10-day (gestation days (GDs) 6-15)
reproductive/developmental study on
MgCl2, oral, rat; no maternal or
reproductive effects.
NOAEL >96 mg/kg/day for Mg2+ ion
(highest dose tested)
LOAEL: Not established
NAS, 2000
Reported in a secondary source,
limited study details provided.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Repeated dose toxicity study with the
reproduction/developmental toxicity
screen; rat, oral (gavage), 0, 110, 330,
1,000 mg/kg-day magnesium hydroxide.
Males exposed for 29 days: 2 weeks
prior to mating, during mating and up to
termination; females exposed for 41-45
days: 2 weeks premating, during mating,
post coitum, and 4 days of lactation.
There were no reproductive effects
observed in any dose group.
NOAEL >1,000 mg/kg-day
LOAEL: Not established
ECHA, 2013
Reported in a secondary source.
Study conducted according to
OECD 422.
Reproduction and
Fertility Effects
No data located.
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Developmental Effects
LOW: Magnesium hydroxide is expected to have low hazard for developmental effects based on a
nonstandard experimental study indicating magnesium chloride produces no adverse effects on
developmental outcomes at levels up to 96 mg/kg/day of Mg2+ ion and an experimental study from a
secondary source showing no effect on human newborns. In addition, there were no developmental effects
observed in rats in a repeated dose toxicity study with the reproduction/developmental toxicity screen at
doses as high as 1,000 mg/kg-day.
Reproduction/
Developmental Toxicity
Screen
10-day (GD 6-15)
reproductive/developmental study on
MgCl2, oral, rat; no maternal or
reproductive effects.
NOAEL >96 mg/kg/day for Mg2+ ion
(highest dose tested)
LOAEL: Not established
NAS, 2000
Reported in a secondary source,
limited study details provided.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Repeated-dose/developmental study
(fetal exposure at unspecified dose levels
during 3rd trimester), 27 hypertensive
women treated with magnesium
hydroxide, no effect on newborns except
slightly increased body weight and
hypermagnesiumemia. Cord serum Mg
levels reported to be 70-100% of
maternal levels after treatment
(potentially causing neurological
depression in neonate, characterized by
respiratory depression, muscle weakness,
decreased reflexes). Prolonged
magnesium treatment during pregnancy
may be associated with maternal and
fetal hypocalcemia and adverse effects
on fetal bone mineralization.
HSDB, 2013
Reported in a secondary source,
limited study details provided.
Maternal treatment doses not
specified.
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Repeated dose toxicity study with the
reproduction/developmental toxicity
screen; rat, oral (gavage), 0, 110, 330,
1,000 mg/kg-day. Males exposed for 29
days: 2 weeks prior to mating, during
mating and up to termination; females
exposed for 41-45 days: 2 weeks
premating, during mating, post coitum,
and 4 days of lactation.
There were no developmental effects
observed in any dose group.
NOAEL >1,000 mg/kg-day
LOAEL = Not established
ECHA, 2013
Reported in a secondary source.
Study conducted according to
OECD 422.
Prenatal Development
No data located.
Postnatal Development
No data located.
Neurotoxicity
LOW: Magnesium hydroxide is expected to be of low hazard for neurotoxicity based on expert judgment.
Neurotoxicity Screening
Battery (Adult)
Low potential for neurotoxicity.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Repeated Dose Effects
LOW: Experimental studies indicate magnesium ions produce no adverse systemic effects in rats or mice at
magnesium levels >1,000 mg/kg/day of magnesium hydroxide.
96-week repeated-dose study for MgCl2,
oral (0, 0.5, 2% in the diet), mouse;
decreased body weight gain, increased
food/water consumption and increased
relative brain, heart and kidney weights
in high dose (2%) females, no effects in
males.
Female:
NOAEL = 87 mg/kg-day for Mg2+ ion
LOAEL = 470 mg/kg/day for Mg2+ ion
Male:
NOAEL = 336 mg/kg-day for Mg2+ ion
(highest dose tested)
LOAEL: Not established
Kurataetal., 1989
Adequate, primary source.
90-day repeated-dose study for MgCl2,
oral, mouse (M: 73, 146, 322, 650, 1,368
mg/kg-day; F: 92, 190, 391, 817, 1,660
mg/kg-day); decreased body weight gain
in males and females at highest doses
tested (1,660 mg/kg-day); renal tubular
vacuolation in males administered 650
mg/kg-day for Mg2+ ion.
Female:
NOAEL = 817 mg/kg/day for Mg2+ ion
LOAEL = 1,660 mg/kg/day for Mg2+ ion
Male:
NOAEL = 322 mg/kg/day for Mg2+ ion
LOAEL = 650 mg/kg/day for Mg2+ ion
NAS, 2000
Reported in a secondary source, no
study details provided.
4-369
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
90-day repeated-dose study for MgCl2,
oral, mouse; decreased body weight gain,
renal tubular vacuolation in males.
Female:
NOAEL = 587 mg/kg/day for Mg2+ ion
Male:
LOAEL = 840 mg/kg-day
NOAEL = 420 mg/kg/day for Mg2+ ion
NAS, 2000
Reported in a secondary source, no
study details provided.
32-week repeated-dose study, diet, rat;
no effects on body weight or liver
weight.
NOAEL >1,000 ppm (approximately 50
mg/kg/day)
BIBRA, 1993
Reported in a secondary source, no
study details provided.
Inhalation exposure of male rats to short
(4.9x0.31 mm) or long (12 x 0.44 mm)
MgSOV5Mg(OF[)2 3FI20 filaments for 6
hour/day, 5 day/week for up to 1 year
(concentration not specified) exhibited a
slight increase in the incidence of
pulmonary lesions 1 year after cessation
of exposure. Histopathological
examination revealed a slight increase in
segmental calcification of the pulmonary
artery and thickening of the lung pleura
in rats exposed to both short and long
filaments for 4 weeks or 1 year. There
were no effects on survival or body,
lung, liver, kidney and spleen weights of
animals sacrificed 1 day or 1 year
following a 1-year exposure period.
NAS, 2000
Reported in a secondary source, no
study details provided.
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
4-week repeated-dose study, oral,
human; caused diarrhea, abdominal
discomfort, and increased serum
magnesium levels.
LOAEL = 400 mg/day
BIBRA, 1993
Reported in a secondary source, no
study details provided.
Repeated dose toxicity study with the
reproduction/developmental toxicity
screen; rat, oral (gavage), 0, 110, 330,
1,000 mg/kg-day. Males exposed for 29
days: 2 weeks prior to mating, during
mating and up to termination; females
exposed for 41-45 days: 2 weeks
premating, during mating, post coitum,
and 4 days of lactation.
There were no toxicologically relevant
changes in any of the parental parameters
examined.
NOAEL >1,000 mg/kg-day
LOAEL: Not established
ECHA, 2013
Reported in a secondary source.
Study conducted according to
OECD 422.
Human systemic effects: chlorine level
changes, coma, somnolence.
Lewis, 2000
Reported in a secondary source, no
study details provided.
Repeated use in humans may rarely
cause rectal stones composed of
magnesium carbonate and magnesium
hydroxide.
IUCLID, 2000
Reported in a secondary source, no
study details provided.
Immune System Effects
Low potential for immunotoxicity.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Skin Sensitization
LOW: Magnesium hydroxide is not estimated to cause skin sensitization based on professional judgment.
Skin Sensitization
Does not cause skin sensitization
(Estimated)
Professional judgment
Estimated by professional judgment.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Eye Irritation
MODERATE: Based on irritation and damage to the corneal epithelium in rabbits that cleared within 2-3
days.
Eye Irritation
Moderately irritating to rabbit eyes.
IUCLID, 2000
Reported in a secondary source,
limited study details provided.
Administration of milk of magnesia
twice a day for 3-4 days caused damage
to corneal epithelium of rabbit eyes;
however, effects disappeared within 2-3
days.
HSDB, 2013
Reported in a secondary source,
limited study details provided. Milk
of magnesia is a mixture containing
magnesium hydroxide and inactive
ingredients.
Dermal Irritation
LOW: An experimental study indicates that magnesium hydroxide is not an irritant to rabbit skin.
Dermal Irritation
Moderate potential for dermal irritation
based on experimental aqueous pH
values. (Estimated)
Expert judgment
Estimated based on expert
judgment.
Causes skin irritation
Fisher Scientific, 2007
Reported in a secondary source, no
experimental study was identified or
study details provided.
Not corrosive in an in vitro human skin
corrosion test.
ECHA, 2013
Reported in a secondary source.
Study conducted according to
OECD guideline 431.
Not irritating in an in vitro skin irritation
test.
ECHA, 2013
Reported in a secondary source. In
vitro skin irritation: reconstructed
human epidermis model test.
Not irritating, rabbits
Submitted confidential study
Reported in a submitted confidential
study.
Endocrine Activity
No data located.
No data located.
Immunotoxicity
Magnesium hydroxide is expected to have low potential for immunotoxicity based on expert judgment.
Immune System Effects
Low potential for immunotoxicity
(Estimated)
Expert judgment
Estimated based on expert
judgment.
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
LOW: Estimated LCS0 values for all of the standard toxicity test organisms are greater than 100 mg/L.
Experimental LCS0 values are much greater than the anticipated water solubility, suggesting no effects at
saturation (NES).
Fish LC50
96-hour LC50 = 1,110 mg/L
(Estimated)
Mount et al., 1997
Estimated from the measured LC50s
for MgCl2 and MgS04, modified by
a MW adjustment for Mg(OH)2;
expected to display NES because
the amount dissolved in water is not
anticipated to reach a concentration
at which adverse effects may be
expressed.
Pimephalis promelas 96-hour LC50 =
511 mg/L; static conditions
(Experimental)
ECHA, 2013
Reported in a secondary source.
Test material diluted to 61% in
aqueous suspension.
Onchorinchns mykiss 96-hour LC50 =
775.8 mg/L; static conditions
(Experimental)
ECHA, 2013
Reported in a secondary source.
Test material diluted to 61% in
aqueous suspension.
Daphnid LCS0
48-hour LC50 = 648 mg/L
(Estimated)
Biesinger and Christensen,
1972; Mount et al., 1997
Estimated from the measured LC50s
for MgCl2 and MgS04, modified by
a MW adjustment for Mg(OH)2;
expected to display NES because
the amount dissolved in water is not
anticipated to reach a concentration
at which adverse effects may be
expressed.
Daphnict magna 48-hour LC50 = 284.76
mg/L; static conditions
(Experimental)
ECHA, 2013
Reported in a secondary source.
Test material diluted to 61% in
aqueous suspension.
Other Freshwater Invertebrate LCS0
Gammanis lacustris LC50 = 64.7 mg/L
(Experimental)
O'Connell et al., 2004
Reported in a secondary source,
study details and test conditions
were not provided. Not a standard
test species.
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green Algae ECS0
96-hour EC50 =2,111 mg/L
(Estimated)
Professional judgment
Estimated using an acute to chronic
ratio (ACR) of 4; expected to
display NES because the amount
dissolved in water is not anticipated
to reach a concentration at which
adverse effects may be expressed.
Scenedesmus subspicatus and
Selenastriim cctpricornutum 72-hour
EC50 >100 mg/L (for growth and
biomass) (Experimental)
ECHA, 2013
Reported in a secondary source.
Chronic Aquatic Toxicity
LOW: Estimated ChVs are all >10 mg/L and exceed the anticipated water solubility, suggesting NES.
Fish ChV
403 mg/L
(Estimated)
Professional judgment
Estimated using an ACR of 3:3;
expected to display NES because
the amount dissolved in water is not
anticipated to reach a concentration
at which adverse effects may be
expressed.
Daphnid ChV
197 mg/L
(Estimated)
Suter, 1996
Estimated from the measured ChV
for Mg2+ ion, modified by a MW
adjustment for Mg(OH)2; expected
to display NES because the amount
dissolved in water is not anticipated
to reach a concentration at which
adverse effects may be expressed.
Green Algae ChV
528 mg/L
(Estimated)
ECOTOX
Estimated from the measured
NOEC and LOEC for MgS04,
modified by a MW adjustment for
Mg(OH)2; expected to display NES
because the amount dissolved in
water is not anticipated to reach a
concentration at which adverse
effects may be expressed.
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL FATE
Transport
The low water solubility, the estimated vapor pressure of 30,000 and
estimated Henry's Law Constant of 30,000 (Estimated)
Professional judgment; EPA,
2004
Cutoff value for nonmobile
compounds.
Level III Fugacity Model
Not all input parameters for this
model were available to run the
estimation software (EPI).
Persistence
HIGH: As an inorganic compound, magnesium hydroxide is not expected to biodegrade, oxidize in air, or
undergo hydrolysis under environmental conditions. Magnesium hydroxide does not absorb light at
environmentally relevant wavelengths and is not expected to photolyze. Magnesium hydroxide is recalcitrant
and it is expected to be found in the environment >180 days after release. As a naturally occurring compound,
it may participate in natural cycles and form complexes in environmental waters.
Water
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment
Substance is or contains inorganic
elements, such as metal ions or
oxides, that are expected to be found
in the environment >180 days after
release.
Volatilization Half-life for
Model River
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Volatilization Half-life for
Model Lake
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Soil
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment
This inorganic compound is not
amenable to available estimation
methods.
4-375
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Anaerobic
Biodegradation
Recalcitrant (Estimated)
Professional judgment
This inorganic compound is not
amenable to available estimation
methods.
Soil Biodegradation with
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
>1 year (Estimated)
Professional judgment
Substance does not contain functional
groups amenable to atmospheric
degradation processes.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Professional judgment
Magnesium hydroxide does not
absorb UV light at environmentally
relevant wavelengths and is not
expected to undergo photolysis.
Hydrolysis
Not a significant fate process (Estimated)
Professional judgment
Substance does not contain functional
groups amenable to hydrolysis.
Environmental Half-life
Not all input parameters for this
model were available to run the
estimation software (EPI).
Bioaccumulation
LOW: Magnesium hydroxide is not expected to bioaccumulate based on professional judgment.
Fish BCF
<100 (Estimated)
Professional judgment
This inorganic compound is not
amenable to available estimation
methods.
BAF
<100 (Estimated)
Professional judgment
This inorganic compound is not
amenable to available estimation
methods.
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
Magnesium hydroxide is a mineral that occurs naturally in the environment.
Ecological Biomonitoring
No data located.
4-376
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Magnesium Hydroxide CASRN 1309-42-8
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-377
-------
Aldrich. 2007-2008 Handbook of Fine Chemicals. Milwaukee, WI: Aldrich Chemical Co. 2006.
BIBRA International. Toxicity profile: Magnesium hydroxide, 1st Ed. Great Britain: BIBRA. 1993.
Biesinger, K.E.; Christensen, G.M. Effects of various metals on survival, growth, reproduction and metabolism of Daphnia magna. J.
Fish Res. Board Can. 1972, 29(12): 1691-1700.
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
May 10, 2011).
ECHA (European Chemicals Agency). Information on registered substances. 2013.
http://apps.echa.europa.eu/registered/data/dossiers/DISS-9ea79197-lfe4-5688-e044-00144f67d031/AGGR-b7f868G-337e-48ac-8f47-
d5d7445c8973 DISS-9ea79197-lfe4-5688-e044-00144f67d031.html#L-9adf9459-3347-4fcc-blc9-47f4c891001f(accessed
December, 2013).
ECOTOX database. U.S. Environmental Protection Agency, http://cfpub.epa.gov/ecotox/. (Accessed July 3, 2008).
EPA (Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing Data.
U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
EPA. 2004. The Pollution Prevention (P2) Framework, EPA-748-B-03-001. Office of Pollution Prevention and Toxics 7403M, U.S.
Environmental Protection Agency, Washington, DC. 20460. October 2003 version updated in January 2004. Latest version available
at http://www.epa.gov/opptintr/newchems/pubs/sustainable/p2frame-iune05a2.pdf.
EPI (EPIWIN/EPISUITE) Estimation Program Interface for Windows, Version 4.0. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
ESIS (European chemical Substances Information System). Classification, labelling and packaging of dangerous substances annex VI
to regulation (EC) No 1272/2008 [Online] http://esis.irc.ec.europa.eu/index.php?PGM=cla (accessed on May 10, 2011).
Fisher Scientific. Magnesium hydroxide. Material Safety Data Sheet. 2007. https://fscimage.fishersci.com/msds/13405.htm. (accessed
on May 13, 2011).
4-378
-------
Hodgman, C.D., ed. 1959-1960 CRC handbook of chemistry and physics, 41st ed. Cleveland, OH: Chemical Rubber Publishing
Company. 1959.
HSDB (Hazardous Substances Data Bank). National Library of Medicine. 2013. http://toxnet.nlm.nih.gov/. (Accessed December,
2013)
IUCLID (International Uniform Chemical Information Database). Dataset for magnesium hydroxide. European Commission -
European Chemicals Bureau. 2000.
Kurata, Y.; Tamano, S.; Shibata, M.-A.; et al. Lack of carcinogenicity of magnesium chloride in a long-term feeding study in B6C3F1
mice. FoodChem. Toxicol. 1989, 27(9):559-563.
Lewis, R.J. Sr., ed. Hawley's condensed chemical dictionary. 13th ed. New York, NY: John Wiley & Sons, Inc., p. 691. 1997.
Lewis, R.J., Sr., ed. Sax's dangerous properties of industrial materials. 10th ed. New York: John Wiley & Sons, Inc. 2000.
Lide, D.R., ed. 2000-2001 CRC Handbook of Chemistry and Physics, 81st ed. Boca Raton, 2000.
O'Neil, M.; Heckelman, P.E.; Koch, C.B.; et al. eds. e-Merck Index. 14th ed. Basic Search. Whitehouse Station, NJ: Merck & Co.,
Inc. 2011. https://themerckindex.cambridgesoft.com/TheMerckIndex/index.asp (accessed on May 16, 2011).
Mount, D.R.; Gulley, D.D.; Hockett, J.R.; et al. Statistical models to predict the toxicity of major ions to Ceriodaphnia dubia,
Daphnia magna and Pimephalespromelas (Fathead Minnows). Environ. Toxicol. Chem. 1997, 16:2009-2019.
NAS (National Academy of Sciences) Toxicological risks of selected flame-retardant chemicals. Washington, DC: The National
Academies Press, p. 131-145. 2000. http://www.nap.edu/openbook.php7record id=9841&page=139#p2000a45a9960139001
(accessed June 23, 2008).
O'Connell, S.; Whitley, A.; Burkitt, J.; et al. DfE Phase II Rev 0.6. Scottsdale, AZ: HDP User Group International, Inc. 2004.
http://www.dell.com/downloads/global/corporate/environ/HDPUG DfE 2.pdf (accessed June 23, 2008).
4-379
-------
SPARC. SPARC On Line CalculatorpKaproperty server. Ver4.6 October, 2011. Available from, http://ibmlc2.chem.uga.edu/sparc/
as of March 16, 2012.
Suter, G.W. II. Toxicological benchmarks for screening contaminants of potential concern for effects on freshwater biota. Environ.
Toxicol Chem. 1996. 15:1232-1241.
Wang, A.; Yoshimi, N.; Tanaka, T.; et al. Inhibitory effects of magnesium hydroxide on c-myc expression and cell proliferation
induced by methylazoxymethanol acetate in rat colon. Cancer Lett. 1993, 75:73-78.
4-380
-------
Melamine Cyanurate
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
§ Based on analogy to experimental data for a structurally similar compound.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Melamine Cyanurate1
37640-57-6
L
M
M
L
L
L
L
L
L
VH
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame
retardants that may partition to sediment and particulates.
1 Hazard designations are based upon the component of the salt with the highest hazard designation, including the corresponding free acid or base.
4-381
-------
Melamine Cyanurate
,o
CL
, O
>k
N
O.
H^H-Vr6-"
'f N N^h
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" H. A A ,K - ""H.mAnAm.H-"
N N N N N N
i : i i : i
H H H H ^ H
-H' T T -H
H
,6
~H,
N
HT
.ISL
*N N' o. Vi V -O
v^-.nXn-^p,tPKh-.a„..
cx
^H'
Nk
N
1
N' ^N'
~l_l H' ^H' H\
n K,^ \K,^' 1 M M M M M ^
.H'
N N
I
H
N
I
H
N N
I
H
N
I
H
N N
I
H
N
I
H
CASRN: 37640-57-6
MW: 255 (Empirical)
MF: C3H6N6 C3H3N3O3
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: nlc(N)nc(N)nclN(H)(H)(H)N2C(=0)NC(=0)NC2=0 (Empirical)
Synonyms: l,3,5-Triazine-2,4,6(lH,3H,5H)-trione, compd. with l,3,5-triazine-2,4,6-triamine (1:1); l,3,5-triazinane-2,4,6-trione - l,3,5-triazine-2,4,6-triamine (1:1);
Melapur MC XL; Melamine isocyanurate
4-382
-------
Chemical Considerations: This alternative is an organic salt of melamine (CASRN 108-78-1) and cyanuric acid (CASRN 108-80-5) organized in a well ordered
crystalline complex, with extensive intramolecular hydrogen bonding. The abundance of complimentary hydrogen bonds effectively link melamine and cyanuric acid
into stable lattice chains. The potential for dissolution of these chains are dependent on pH. The simplest 1:1 melamine cyanurate complex has an empirical MW of
255; although higher MW networks are expected because the integrated melamine cyanurate complex has a higher degree of stabilization than isolated components
(Perdigao et al., 2006). This assessment will consider the worst case hazard concerns which may include those from the dissolution of melamine and cyanuric acid
from the complex.
Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: Melamine (CASRN 108-78-1); cyanuric acid (CASRN 108-80-5)
Analogs: Confidential analog, nitrogen heterocycles
Endpoint(s) using analog values: Reproductive effects; developmental effects
Analog Structures: Confidential; nitrogen heterocycles is a class of cyclic
compounds that have nitrogen atoms and at least one other element as members
of its ring.
Structural Alerts: Aromatic amine (EPA, 2011)
Risk Phrases: Xn- harmful; R48/22 - harmful: danger of serious damage to health by prolonged exposure if swallowed (ECHA, 201 la).
Hazard and Risk Assessments: None identified
4-383
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
No data located.
Boiling Point (°C)
>350 decomposes (Measured)
Leisewitz et al., 2001; ECHA,
2011a
Based on the reported thermal
stability value.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; EPA,
1999
Cutoff value for nonvolatile
compounds according to HPV
assessment guidance; based on the
ionic nature of the material.
Water Solubility (mg/L)
Approximately 27 at 20°C
(Organisation of Economic Cooperation
and Development (OECD) 105)
(Measured)
ECHA, 2011a
Guideline study.
10 at 20°C (Measured)
ECHA, 2011a
Nonguideline studies at neutral pH
that substantiate the limited solubility
anticipated under neutral conditions.
1 at 20°C (Measured)
ECHA, 2011a
2 at 25 °C (Measured)
Ciba, 2001
1.5 at 37°C (Measured)
ECHA, 2011a
Under neutral conditions melamine and
cyanuric acid form a stable and insoluble
hydrogen-bonded network; the network is
destabilized at pH extremes (Measured)
Rovner, 2008
Non-quantitative supporting
information that describes the
behavior of the compound in water.
Very insoluble in water (Measured)
Crews, 2006
Inadequate; qualitative, nonspecific
value.
Not soluble at room temperature
(Measured)
ICL Industrial Products (IP),
2011
Log Kow
Melamine Cyanurate: <0 (Estimated)
Melamine: -1.37 (Measured)
Cyanuric Acid: -0.47 (Measured)
ECHA, 2011a; Hansch, 1995;
Kaune et al., 1998; Pakalin et al.,
2007
Inadequate, based on experimental
water solubility data. These values
are not applicable for the melamine
cyanurate complex.
4-384
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Flammability (Flash Point)
Self-ignition temperature: >400°C
(Measured)
ECHA, 2011a
Adequate.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Pyrolysis
No data located.
pH
5-6 (Measured)
ECHA, 2011a
Inadequate, these data are not
consistent with the well conducted
water solubility studies; purity of test
material not reported.
5.5 (Measured)
Ciba, 2001
pKa
Melamine: 5 (Measured)
Cyanuric Acid: 6.88, 11.4, 13.5
(Measured)
ECHA, 2011a
Inadequate, these data values are not
applicable for the melamine
cyanurate complex.
HUMAN HEALTH EFF]
ECTS
Toxicokinetics
The melamine cyanurate complex is expected to have limited bioavailability for dermal and inhalation
routes of exposure due to its low water solubility under neutral conditions. It is expected to not be absorbed
through skin and to have poor absorption through the lung and gastrointestinal tract. The dissolution of
melamine cyanurate and the solubility and precipitation of melamine and cyanuric acid appear to be pH-
dependent indicating that ingestion of this compound may enhance bioavailability. Melamine is distributed
to the stomach, small intestine, cecum, and large intestine, and found in blood and urine of rats. Cyanuric
acid distributes rapidly following oral administration with the highest concentrations found in blood, liver
and kidney. The elimination phase half-life for melamine is approximately 3 hours. Cyanuric acid is quickly
excreted primarily in the urine as the unchanged compound.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
Melamine cyanurate: Not absorbed
through skin; poor absorption through
lung and gastrointestinal tract
(Estimated)
Professional judgment.
Estimated based on limited
bioavailability and not expected to
be readily absorbed; however,
ingested melamine cyanurate could
be dissociated to form melamine
and cyanuric acid in the low pH
environment found in the stomach.
4-385
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine and cyanuric acid co-
exposure: The solubility of melamine
and cyanuric acid in urine was higher
than in water suggesting a pH-dependent
effect. The lowest solubility was at a pH
of 5-5.5; Solubility in human urine was
in the range of 250 mg/L at pH 3 and 8.
The solubility limits for melamine and
cyanurate increased with increasing pH
over the range of 5-8.3 and solubility at
pH 5 was 30 mg/L in rats.
There is a pH-dependent precipitation of
melamine and cyanuric acid in rat and
human urine. No difference in crystal
formation was observed at the 1 - or 24-
hour time point.
ECHA, 2011a
Study details reported in a
secondary source.
Melamine and cyanuric acid co-
exposure: Melamine and cyanuric acid
orally (gavage) administered separately
formed crystals of melamine cyanurate
in the kidneys of rats. There was
decreased creatinine clearance, increased
in serum creatinine and Blood Urea
Nitrogen (BUN) ratio; increased absolute
and relative kidney weight.
ECHA, 2011a
Sufficient details reported in a
secondary source.
Melamine: The elimination phase half-
life calculated from plasma data was 2.7
hours, and the urinary half-life was 3.0
hours. The renal clearance was
determined to be 2.5 mL/min.
Mast et al., 1983
Adequate, nonguideline study.
Melamine: Distributed to stomach,
small intestine, cecum, and large
intestine, and found in blood and urine of
rats.
ECHA, 2011b
Study details reported in a
secondary source.
4-386
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: There was 98% recovery
of ingested cyanuric acid in urine of 2
volunteers; elimination half-life
estimated to be 2.2-3.5 hours; consistent
with the one-compartment open model
with first order input and elimination;
cyanuric acid is excreted rapidly and
nearly completely after ingestion.
OECD SIDS, 1999b
Study details reported in a
secondary source.
Cyanuric acid: Distributes rapidly
following oral administration to rats;
highest concentrations found in blood,
liver and kidney with maximum
concentrations 30 minutes after dosing;
excreted primarily in urine as unchanged
substance; poor dermal absorption.
ECHA, 2011b
Sufficient details reported in a
secondary source; test substance
identified as 2,4,6-isocyanuric acid.
Acute Mammalian Toxicity
LOW: Estimated based on measured acute oral, dermal, and inhalation toxicity values for the dissolution
products melamine and cyanuric acid. The melamine cyanurate complex is also estimated to have limited
bioavailability and water solubility that is consistent with a low hazard for dermal and inhalation routes of
exposure.
Acute Lethality
Oral
Melamine: Rat LD50 = 3,161 mg/kg b.w.
(male), 3,828 mg/kg (female)
NTP, 1983; Melnick et al.,
1984
Sufficient study details reported.
Melamine: Mouse LD50 = 3,296 mg/kg
(male), 7,014 mg/kg (female)
NTP, 1983; Melnick et al.,
1984
Sufficient study details reported.
Melamine: Mouse LD50 = 4,550 mg/kg
American Cyanamid Company,
1955; May, 1979;
Trochimowicz et al., 2001
Sufficient study details were not
available. Reported in secondary
sources.
Melamine: Rat LD50 = 3,160 mg/kg
(male), 3,850 mg/kg (female)
Trochimowicz et al., 2001
Sufficient study details were not
reported.
Melamine: Rat LD50 >6,400 mg/kg
BASF, 1969 (as described in
IUCLID, 2000 and OECD
SIDS, 1999a)
Sufficient study details were not
available.
Melamine: LD50 ~ 4,800 mg/kg
Hoechst, 1963 (as described in
IUCLID, 2000)
Sufficient study details were not
available.
4-387
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: Rat LD50 >5,000 mg/kg
ECHA, 2011b
Sufficient study details reported in a
secondary source; OECD guideline
420.
Cyanuric acid: Rat LD50 = 7,700 mg/kg
OECD SIDS, 1999b
Reported in a secondary source with
limited study details provided;
purity unknown.
Cyanuric acid: Mouse LD50 = 3,400
mg/kg
OECD SIDS, 1999b
Reported in a secondary source with
limited study details provided;
purity unknown.
Cyanuric acid: Rabbit LD50 >10 mg/kg
OECD SIDS, 1999b
Reported in a secondary source with
limited study details provided;
purity unknown.
Dermal
Melamine cyanurate: Estimated to have
limited bioavailability and therefore has
low potential for hazard for the dermal
route of exposure (Estimated)
Professional judgment
Based on physical chemical
properties including limited
bioavailability and low water
solubility.
Melamine: Rabbit LD50 >1,000 mg/kg
Unknown, 1990
Sufficient study details were not
available.
Cyanuric acid: Rabbit LD50 >7,940
mg/kg
OECD SIDS, 1999b
Reported in a secondary source with
limited study details provided;
purity unknown.
Cyanuric acid: Rabbit LD50 >5,000
mg/kg
ECHA, 2011b
Sufficient study details reported in a
secondary source; OECD guideline
402.
Inhalation
Melamine cyanurate: Estimated to have
limited bioavailability and therefore has
low potential for hazard for the
inhalation route of exposure (Estimated)
Professional judgment
Based on physical chemical
properties including limited
bioavailability and low water
solubility.
Melamine: Rat LC50 = 3.248 mg/L
Ubaidullajev, 1993
The study details, if present, were
not translated into English.
Cyanuric acid: Rat LC50 >5.25 mg/L
ECHA, 2011b
Sufficient study details reported in a
secondary source; OECD guideline
403.
4-388
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Carcinogenicity
MODERATE: Estimated based on the dissolution product melamine. There is evidence that oral melamine
exposure causes carcinogenicity in experimental animals; however, there was no evidence located as to its
carcinogenicity to humans. Tumor formation in animals appears to happen in a mechanical nature under
conditions in which it produces bladder calculi. Cyanuric acid is not carcinogenic. There were no data
located as to the carcinogenic potential of the melamine cyanurate complex. The International Agency for
Research on Cancer (IARC) classifies melamine as Group 3: not classifiable as to its carcinogenicity to
humans.
OncoLogic Results
Melamine: Marginal (Estimated)
OncoLogic, 2008
Carcinogenicity (Rat
and Mouse)
Melamine: Group 3: melamine is not
classifiable as to its carcinogenicity to
humans; there is inadequate evidence in
humans for the carcinogenicity of
melamine, and there is sufficient
evidence in experimental animals for the
carcinogenicity of melamine under
conditions in which it produces bladder
calculi.
IARC, 1999
IARC classification statement.
Melamine: Significant formation of
transitional cell carcinomas in the
urinary bladder of dosed male rats and
significant chronic inflammation in the
kidney of dosed female rats were
observed following exposure in the feed
for up to 103 weeks. Carcinoma
formation was significantly correlated
with the incidence of bladder stones. A
transitional-cell papilloma was observed
in the urinary bladder of a single high
dose male rat, and compound related
lesions were observed in the urinary tract
of dosed animals.
NTP, 1983; Huff, 1984;
Melnick et al., 1984
Sufficient study details reported.
4-389
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Increased incidence of acute
and chronic inflammation and epithelial
hyperplasia of the urinary bladder were
observed in male mice following oral
(feed) exposure for up to 103 weeks.
Bladder stones and compound related
lesions were observed in the urinary tract
of test animals. There was no evidence of
bladder tumor development. Melamine
was not considered carcinogenic.
NTP, 1983; Huff, 1984;
Melnick et al., 1984
Sufficient study details reported.
Melamine: Melamine-induced
proliferative lesions of the rat urinary
tract were directly due to the irritant
stimulation of calculi, and not to
molecular interactions between
melamine or its metabolites with the
bladder epithelium.
Okumura et al., 1992
Sufficient study details reported.
Melamine: Water intake, used as an
index of urinary output, was increased by
NaCl treatment. Calculus formation
resulting from melamine administration
was suppressed dose-dependently by the
simultaneous NaCl treatment. The main
constituents of calculi were melamine
and uric acid (total contents 61.1—
81.2%). The results indicate that
melamine-induced proliferative lesions
of the urinary tract of rats were directly
due to the irritation induced-stimulation
of calculi, and not molecular interactions
between melamine itself or its
metabolites with the bladder epithelium.
Ogasawara et al., 1995
Sufficient study details reported.
4-390
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: As an initiator, melamine
caused no significant increase in
papillomas per mouse when compared to
controls.
Perrella and Boutwell, 1983
Sufficient study details reported;
nonguideline study.
Melamine: Diffuse papillary hyperplasia
of the bladder epithelium and bladder
calculi were observed in all melamine
treated rats. Elevated
spermidine/spermine Nl-
acetyltransferase activity following
melamine treatment was considered to be
an indicator of cell proliferation.
Matsui-Yuasa et al., 1992
Sufficient study details reported;
nonguideline study.
Melamine: Decreased antitumor activity
was correlated with increasing
demethylation; melamine was considered
inactive as an antitumor drug.
Rutty and Connors, 1977
Sufficient study details were not
available.
Melamine: In an in vitro cytotoxicity
study in cultured ADJ/PC6
plasmacytoma ascites tumor cells the
ID50 was 470 (ig/mL after 72 hours of
treatment.
Rutty and Abel, 1980
Sufficient study details were not
available.
Combined Chronic
Toxicity/
Carcinogenicity
Melamine: No effects were observed in
rats fed 1,000 ppm of melamine. Four of
the 10 rats fed 10,000 ppm of melamine
had bladder stones associated with the
development of benign papillomas.
Anonymous, 1958 (as described
in EPA, 1992)
Sufficient study details were not
available.
Melamine: Increased incidence of
urinary bladder stones (6/20 rats) was
noted in the 10,000 ppm dose group, and
was associated with an increase in
benign papillomata. The NOAEL was
determined to be 1,000 ppm (67 mg/kg).
American Cyanamid Company,
1955
Sufficient study details were not
available.
4-391
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: Rat, oral (drinking
water), 2-year toxicity and oncogenicity
study; there was no evidence of
treatment-related carcinogenic effects in
tissues or organs in any treatment group.
ECHA, 2011b
Sufficient study details reported in a
secondary source; EU Method B.33
(combined chronic
toxicity/carcinogenicity test); test
substance identified as s-
triazinetriol, monosodium salt
(monosodium cyanurate
monohydrate) 99.7% (equivalent to
77.4% cyanuric acid).
Cyanuric acid: Mouse, oral (drinking
water), 2-year toxicity and oncogenicity
study; there was no evidence of
treatment-related carcinogenic effects in
tissues or organs in any treatment group.
ECHA, 2011b
Sufficient study details reported in a
secondary source; EU Method B.33
(combined chronic
toxicity/carcinogenicity test); test
substance identified as monosodium
cyanurate monohydrate (equivalent
to 77.5% cyanuric acid).
Genotoxicity
MODERATE: Melamine cyanurate is estimated to be a moderate hazard for genotoxicity based on the data
for melamine. For melamine, positive results were observed for in vivo chromosome aberration and sister
chromatid exchange assays conducted by National Toxicology Program (NTP) in 1988 and 1989. Available
in vitro genotoxicity testing was conducted with metabolic activation systems from the liver. NTP suggests
this may not account for potential activation from bladder epithelial cells, which is the target organ.
Proposed genotoxicity testing using a metabolic activation system from bladder epithelial cells (NTP, 1983)
was never conducted (Personal Communication, 2007; 2008). Cyanuric acid does not cause gene mutations
or chromosomal aberrations in vitro. There was one study located for melamine cyanurate, which
demonstrated negative results for an in vitro chromosomal aberration study.
Gene Mutation in vitro
Melamine: Bacterial forward mutation
assay: Negative with and without liver
activation
Melamine: Bacterial forward mutation
assay: Negative
Melamine: Bacterial reverse mutation
assay: Negative with and without liver
activation
Haworth et al., 1983; NCI/NTP,
2007
Seiler, 1973
Lusbyetal., 1979
Sufficient study details reported.
Sufficient study details were not
available.
Sufficient study details were not
available.
4-392
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Bacterial reverse mutation
assay: Negative with and without
unspecified metabolic activation
Mast et al., 1982a
Sufficient study details were not
available.
Melamine: In vitro mouse lymphoma
test: Negative with and without liver
activation
McGregor et al., 1988;
NCI/NTP, 2007
Sufficient study details reported.
Melamine: Chinese hamster ovary
(CHO) cells/hypoxanthine-guanine
phosphoribosyl-transferase forward
mutation assay: Negative with and
without liver activation
Mast et al., 1982a
Sufficient study details were not
available.
Cyanuric acid: Negative for
mutagenicity to S. typhimurium TA1535,
TA1537, TA98, TA100 with and without
metabolic activation
OECD SIDS, 1999b
Reported in a secondary source with
limited study details provided;
purity unknown.
Cyanuric acid: Negative for
bacteriophage Lambda induction in E.
coli with and without metabolic
activation
OECD SIDS, 1999b
Reported in a secondary source with
limited study details provided;
purity unknown.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
Melamine cyanurate: In vitro
chromosomal aberrations test: Negative
in Chinese hamster lung fibroblasts
(V79) with and without metabolic
activation
ECHA, 2011a
OECD guideline 473.
Melamine: In vitro chromosomal
aberrations test: Negative in CHO with
and without liver activation
Galloway et al., 1987;
NCI/NTP, 2007
Sufficient study details reported.
Melamine: In vitro sister chromatid
exchange assay: Negative in CHO with
and without liver activation
Galloway et al., 1987;
NCI/NTP, 2007
Sufficient study details reported.
4-393
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: In vitro sister chromatid
exchange assay: Negative in CHO with
and without liver activation
Mast et al., 1982a
Sufficient study details were not
available.
Cyanuric acid: Negative for
chromosomal aberrations in Chinese
hamster lung cells with and without
metabolic activation
OECD SIDS, 1999b
Reported in a secondary source with
limited study details provided;
99.5% purity.
Cyanuric acid: Negative for sister
chromatid exchange in CHO cells with
and without metabolic activation
OECD SIDS, 1999b; ECHA,
2011b
Sufficient study details reported in
secondary sources; purity
equivalent to 77% cyanurate.
Chromosomal
Aberrations in vivo
Melamine: In vivo mouse micronucleus
test: The initial test gave a positive trend
(P = 0.003) for chromosomal damage;
however, both peripheral blood smears
and the repeat bone marrow test were
negative. The overall conclusion was that
melamine does not induce chromosomal
damage.
NTP, 1983; Shelby etal., 1993
Sufficient study details reported.
Melamine: In vivo mouse micronucleus
test: Negative without activation
Mast et al., 1982b
Sufficient study details were not
available.
Melamine: In vivo chromosome
aberrations test in mice: Positive
NCI/NTP, 2007
Sufficient study details reported.
Melamine: In vivo sister chromatid
exchange assay in mice: Positive
NCI/NTP, 2007
Sufficient study details reported.
DNA Damage and
Repair
Melamine: In vivo and in vitro
unscheduled DNA synthesis (UDS) test:
None of the tested chemicals, including
melamine, were genotoxic
hepatocarcinogens in the in vivo assay,
and melamine was negative for UDS in
the in vitro assay.
Mirsalis et al., 1983
Sufficient study details were not
available.
Melamine: SOShimn test: Negative for
its ability to result in DNA damage and
induce the expression of the limn operon
Reifferscheid and Heil, 1996
Nonguideline study.
4-394
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Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: DNA synthesis-inhibition
test in Hela S3 cells: Inhibits DNA
synthesis by 50% at >300 |iM
Heil and Reifferscheid, 1992
Sufficient study details were not
available.
Other
Melamine: Sex-linked recessive
lethal/reciprocal translocation: Results
were considered equivocal based on
0.18% and 0.36% total lethal following
oral and injection exposure, respectively,
compared to control total lethal of 0.07%
for oral and 0.09% for injection.
NCI/NTP, 2007
Sufficient study details reported.
Melamine: Drosophila Muller-5 test:
Negative for mutagenicity
Rohrborn, 1959
Sufficient study details were not
available.
Melamine: Drosophila melanogaster
Sex-linked recessive lethal: No
mutagenic effects were observed.
Luers and Rohrborn, 1963
Sufficient study details were not
available.
Melamine: In vitro flow cytometric
DNA repair assay: Negative for
genotoxic effects
Seldon et al., 1994
Nonguideline study.
Melamine: Microscreen assay: Positive
for genetic toxicity in E.coli WP2s
Rossman et al., 1991
Nonguideline study.
Melamine: Growth and genotoxic
effects to bacteria (Salmonella
typhimurium) and yeast (Saccharomyces
cerevisiae): Non-mutagenic in
S. typhi murium with or without S-9 mix.
The growth of eight out of nine strains
tested was delayed by 10 mM melamine
during 24-hour cultivation. S. cerevisiae
strain was tested, and did not recover its
growth following 48-hour cultivation.
Ishiwata et al., 1991
Sufficient study details were not
available.
4-395
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Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproductive Effects
MODERATE: Potential for reproductive toxicity estimated based on data for a confidential analog that
reports a NOAEL of 1,600 ppm (191-341 mg/kg/day) in rats orally exposed. Data based on the dissolution
products indicate no effects on reproductive parameters in rats orally exposed to cyanuric acid for up to 3
generations or when exposed to melamine in a 13-week toxicity study. There were no data located regarding
reproductive toxicity following exposure to melamine cyanurate.
Reproduction/
Developmental Toxicity
Screen
Rat, oral; potential for reproductive
toxicity
NOAEL = 1,600 ppm (191-341
mg/kg/day)
(Estimated by analogy)
Professional judgment
Estimated based on analogy to
confidential analog; LOAEL not
identified; study details not
provided.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Cyanuric acid: Rat, oral (gavage),
males exposed for 45 days, females
exposed from 14 days prior to mating to
lactation day (LD) 3; there were no
effects on reproductive parameters
including copulation index, fertility
index, gestation length, numbers of
corpora lutea or implantations,
implantation index, gestation index,
delivery index and behavior at delivery
and lactation.
NOAEL >600 mg/kg/day (highest dose
tested)
OECD SIDS, 1999b
Reported in a secondary source;
conducted according to OECD
guidelines; 99.8% purity. LOAEL
not established for reproductive
toxicity.
4-396
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: Rat, oral, exposure
initiated at 36 days of age to F0
generation, 21 days to Fi and F2 parents
and administered until termination of
each generation; F0 males and females
exposed minimum of 100 days, Fj and F2
male and females exposed a minimum of
120 days; There were no treatment-
related reproductive effects observed.
ECHA, 2011b
Sufficient study details reported in
secondary source; EU Method B.35
(two-generation reproduction
toxicity test); test substance
identified as sodium salt of cyanuric
acid (equivalent to 77.5% cyanuric
acid).
NOAEL F0 >~470 mg/kg-day (male)
NOAEL F0 >~950 mg/kg-day (female)
Reproduction and
Fertility Effects
Melamine: Reproductive dysfunction
was observed at 0.5 mg/nr and included
effects on spermatogenesis (genetic
material, sperm morphology, motility,
and count), effects on the embryo/fetus
(fetal death), pre-implantation mortality
(reduction in the number of implants per
female), and total number of implants
per corpora lutea.
Ubaidullajev, 1993
Study details, if present, were not
translated into English; insufficient
study details reported.
Melamine: There were no treatment-
related macroscopic or microscopic
effects on mammary glands, ovaries,
prostate, seminal vesicles, testes and
uterus in rats and mice in a 13-week
study.
OECD SIDS, 1999a
Study details, including
administered dose information,
were not provided.
Developmental Effects
MODERATE: Estimated based on analogy to nitrogen heterocycles. Data for dissolution products
melamine and cyanuric acid indicate no developmental effects in rats orally exposed to cyanuric acid or
melamine during gestation. There were no data located regarding developmental toxicity following
exposure to melamine cyanurate.
Reproduction/
Developmental Toxicity
Screen
Potential for developmental toxicity
(Estimated by analogy)
Professional judgment
Estimated based on analogy to
nitrogen heterocycles.
4-397
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Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Cyanuric acid: Rat, oral (gavage),
males exposed for 45 days, females
exposed from 14 days prior to mating to
LD 3. There were no effects in offspring
parameters including number sex ratio,
live birth and viability indices, body
weight, or incidences of external and
visceral abnormalities.
NOAEL >600 mg/kg/day (highest dose
tested)
OECD SIDS, 1999b
Reported in a secondary source;
conducted according to OECD
guidelines; 99.8% purity. LOAEL
not established for developmental
toxicity.
Cyanuric acid: Rat, oral, exposure
initiated at 36 days of age to F0
generation, 21 days to Fi and F2 parents
and administered until termination of
each generation; F0 males and females
exposed minimum of 100 days, Fi and F2
male and females exposed a minimum of
120 days. There were no treatment-
related developmental effects observed.
ECHA, 2011b
Sufficient study details reported in
secondary source; EU Method B.35
(two-generation reproduction
toxicity test); test substance
identified as sodium salt of cyanuric
acid (equivalent to 77.5% cyanuric
acid).
NOAEL F0 >~470 mg/kg-day (male)
NOAEL F0 >~950 mg/kg-day (female)
Prenatal Development
Melamine: Signs of maternal toxicity at
136 mg/kg-day included decreased body
weight and feed consumption, hematuria
(23/25 rats), indrawn flanks (7/25 rats),
and piloerection (1/25 rats). No adverse
effects on gestational parameters and no
signs of developmental toxicity were
noted.
NOAEL >1,060 mg/kg-day
Hellwig et al., 1996 (as cited in
OECD SIDS, 1999a)
Study details reported in a
secondary source.
4-398
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: Rat, oral (gavage);
exposure on gestation days 6-15; There
were no developmental effects observed.
NOAEL = 5,000 mg/kg-day (highest
dose tested)
ECHA, 2011b
Sufficient study details reported in a
secondary source; EU method B.31
(prenatal developmental toxicity
study); test substance identified as
monosodium cyanurate
monohydrate; 99% purity
(equivalent to 77.4% cyanuric acid).
Postnatal Development
Melamine: Only minor effects on the
fetuses or litters, including a non-
significant increase in resorptions in the
group treated on the 4th and 5th days of
gestation, were observed.
Thiersch, 1957
Sufficient study details were not
available.
Neurotoxicity
LOW: Estimated to not have potential for neurotoxicity based on expert judgment.
Neurotoxicity Screening
Battery (Adult)
Potential for neurotoxicity is expected to
be low
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Repeated Dose Effects
HIGH: Based on kidney toxicity following repeated oral exposure to melamine cyanurate and simultaneous
co-exposure to melamine and cyanuric acid in rats. Kidney effects included increased plasma blood urea
nitrogen and creatinine levels, the formation of precipitates in the kidney and acute renal failure. Repeated
oral exposure to the dissolution product melamine also results in urinary bladder stones at doses in the
moderate hazard range. The hazard designation for cyanuric acid is considered to be low.
4-399
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine cyanurate: Rat, 7-day
feeding study. Increased plasma BUN
and creatinine levels at 666 ppm (66.6
mg/kg/day; nominal); severe kidney
toxicity at 2,000 ppm (200 mg/kg-day);
and formation of precipitates in the
kidney. There were also mortality, signs
of toxicity, decreased body weight and
food consumption, changes in organ
weights, gross pathology and non-
neoplastic histopathology at higher
doses.
NOAEL: 200 ppm (-10 mg/kg-day)
LOAEL: 660 ppm (~ 66.6 mg/kg-day) -
based on increased plasma BUN and
creatinine levels.
ECHA, 2011a
Reported in a secondary source.
Study designed to test kidney
toxicity; test substance identified as
melaminzyanurat; purity >99%.
Melamine and cyanuric acid co-
exposure: Rat, oral 14-day oral (gavage)
study of melamine and cyanuric acid co-
exposure (each at 1.2, 12, 120 mg/kg-
day); crystal formation in renal distal
tubular lumens and collecting ducts were
observed on day 3 in the 12 mg/kg-day
group; crystal in proximal tubular
lumens of renal cortex on day 3 and
mortal acute renal failure on day 7
occurred at doses of 120 mg/kg-day.
ECHA, 2011a
Reported in a secondary source.
Study focused on renal crystal
formation.
NOEL: 1.2 mg/kg-day
LOEL: 12 mg/kg-day (based on crystals
of melamine cyanurate in kidneys)
4-400
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine and cyanuric acid co-
exposure: 7-day feeding study in rats;
Signs of toxicity evident, at doses of 33
mg/kg-day, there were pale yellow and
enlarged kidneys and increased BUN and
serum creatinine; histopathological
evaluation showed golden brown crystals
in renal tubules of all rats at this dose.
There were no significant differences in
kidney weights or crystals or tubular
changes in rats administered melamine
(200 mg/kg-day) or cyanuric acid (200
mg/kg-day) alone.
ECHA, 201 la; Jacob et al.,
2011
Both melamine and cyanurate were
added to feed with a 1:1 ratio;
primary source.
NO AEL: 10 mg/kg -day
LOAEL: 33 mg/kg-day (based on kidney
toxicity)
Melamine and cyanuric acid co-
exposure: Melamine and cyanuric acid
orally (gavage) administered separately
formed crystals of melamine cyanurate
in kidney of rats. There was decreased
creatinine clearance, increased in serum
creatinine and BUN; increased absolute
and relative kidney weight.
ECHA, 2011a
Reported in a secondary source.
Effect levels not identified.
4-401
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Rat 28-day dietary toxicity
study: Clinical signs included a dose-
related increase in pilo-erection,
lethargy, bloody urine spots in the cage
and on the pelage of animals, and
chromodacryorrhea. The incidence of
urinary bladder calculi and urinary
bladder hyperplasia in treated animals
was dose-dependent, with a significant
relationship between the calculi and
hyperplasia. Calculi composition
indicated the presence of an organic
matrix containing melamine,
phosphorus, sulfur, potassium, and
chloride. Crystals of dimelamine
monophosphate were identified in the
urine.
RTI, 1983
Sufficient study details reported.
NOAEL: 2,000 ppm (240 mg/kg/day),
excluding the observed increase in water
consumption and the incidence of
crystalluria.
LOAEL: 4,000 ppm (475 mg/kg/day)
based on the formation of calculi.
Melamine: Rabbit and dog 28-day
dietary toxicity study: No significant rise
in the body temperature of rabbits was
noted. Gross histological examination of
the heart, lung, liver, spleen, thyroid,
pancreas, intestines, kidneys and bladder
did not show pathological changes. A
zone of fat was found in the inner part of
the renal cortex in two dogs, but also in
the kidneys of 3 control dogs.
Lipschitz and Stokey, 1945
Sufficient study details were not
available.
4-402
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Rat 28-day dietary toxicity
study: Incidence and size of bladder
stones were directly related to the
amount of substance administered. The
larger stones were found to be
unchanged melamine in a matrix of
protein, uric acid and phosphate.
American Cyanamid Company,
1984
Sufficient study details were not
available.
Lowest effect dose (LED): 1,500 ppm
(-125 mg/kg) in males.
Melamine: Rat 90-day dietary toxicity
study: One male rat receiving 18,000
ppm and two males receiving 6,000 ppm
died. Mean body weight gain and feed
consumption were reduced. Stones and
diffuse epithelial hyperplasia in the
urinary bladders were observed in male
rats of all treatment groups. Focal
epithelial hyperplasia was observed in
only 1 male. A second and third 13-week
repeated dose toxicity study was
conducted in rats at a dose range of 750
to 18,000 ppm; bladder stones were
observed at all dose levels. At 18,000
ppm, stones occurred in diets with and
without the addition of ammonium
chloride to drinking water.
NTP, 1983; Melnick et al.,
1984; ECHA, 2011a
Sufficient study details reported.
LOAEL = 700 ppm (72 mg/kg/day)
4-403
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Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Mouse 90-day dietary
toxicity study: a single female mouse
died after receiving 9,000 ppm. Mean
body weight gain relative to controls was
depressed. The incidence of mice with
bladder stones was dose-related and was
greater in males than in females. Sixty
percent of mice having bladder ulcers
also had urinary bladder stones. Bladder
ulcers were multifocal or associated with
inflammation (cystitis). Epithelial
hyperplasia and bladder stones were
observed together in 2 mice. Also,
epithelial cell atypia was seen.
NTP, 1983; Melnick et al.,
1984
Sufficient study details reported.
NOAEL: 6,000 ppm (600 mg/kg-day)
LOAEL: 9,000 ppm (900 mg/kg-day)
Melamine: Increased incidence of acute
and chronic inflammation and epithelial
hyperplasia of the urinary bladder was
observed in mice following oral (feed)
exposure for up to 103 weeks. There was
also increased incidence of bladder
stones in male mice.
NTP, 1983; ECHA, 2011a
Repeated dose effects described in a
carcinogenicity bioassay study.
LOAEL = 2,250 mg/kg diet (lowest dose
tested)
Melamine: Dog 1-year dietary toxicity
study: crystalluria started 60 to 90 days
into treatment, and persisted during the
study period. No other effects
attributable to melamine were observed.
American Cyanamid Company,
1955
Sufficient study details were not
available.
4-404
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Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Rat 30-month dietary
toxicity study: Neither accumulation of
calculi nor any treatment-related urinary
bladder lesions were found.
Mast et al., 1982c (as described
in EPA, 1992)
Sufficient study details were not
available.
Melamine: Rat 24- to 30-month dietary
toxicity study: A dose-related trend for
dilated glands in glandular gastric
mucosa and inflammation in non-
glandular gastric mucosa was observed.
Urinary bladder calculi formation was
not observed.
American Cyanamid Company,
1983 (as described in OECD
SIDS, 1999a)
Sufficient study details were not
available.
4-405
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Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: Rat, oral (gavage),
combined repeat dose and
reproductive/developmental toxicity
screening test; males exposed for 44
days, females exposed from 14 days
prior to mating to LD 3. Toxic effects
included: reddish urine, decreased body
weight gain (males), increased
erythrocytes and leukocytes in urine,
decreased erythrocyte count,
hemoglobin, and hematocrit (male),
increased urea nitrogen and creatinine,
decreased sodium (male), dilation of
renal tubules, necrosis or hyperplasia of
the tubular epithelium, increased
basophilic tubules, neutrophilic
infiltration, mineralization and fibrosis in
the kids, hyperplasia of the mucosal
epithelium in urinary bladder and
vacuolization of the zona fasciculate in
the adrenals, increased absolute and
relative kidney weight and relative
adrenal weights (both sexes), atrophic
thymus (females).
NOAEL =150 mg/kg/day
LOAEL = 600 mg/kg/day
OECD SIDS, 1999b
Reported in a secondary source with
limited study details provided;
99.8% purity.
4-406
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Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: Rat, oral (drinking
water), 2-year toxicity and oncogenicity
study; red urine in males at the highest
dose was observed (371 mg/kg-day);
there were no treatment-related changes
in hematology, clinical chemistry,
urinalysis, or organ weights; non-
neoplastic lesion in urinary tracts and
heart and urinary tract lesions of males
exposed to 5,375 ppm (371 mg/kg-day)
for 6-12 months; There were no
treatment-related lesions in rats exposed
for 18 or 24 months.
ECHA, 2011b
Sufficient study details reported in a
secondary source; EU Method B.33
(combined chronic
toxicity/carcinogenicity test); test
substance identified as s-
trazinetriol, monosodium salt
(monosodium cyanurate
monohydrate) 99.7% (equivalent to
77.4% cyanuric acid).
NOAEL =154 mg/kg-day (male)
LOAEL = 371 mg/kg-day (male)
Cyanuric acid: Mouse, oral (drinking
water), 2-year toxicity and oncogenicity
study; there were no treatment-related
effects.
NOAEL >1,520 mg/kg-day (male)
NOAEL >1,580 mg/kg-day (female)
ECHA, 2011b
Sufficient study details reported in a
secondary source; EU Method B.33
(combined chronic
toxicity/carcinogenicity test); test
substance identified as monosodium
cyanurate monohydrate (equivalent
to 77.5% cyanuric acid).
Cyanuric acid: Mouse, oral (drinking
water), 13-week subchronic toxicity
study; there were no treatment related
effects at doses as high as 1,523 mg/kg-
day (males) and 1,582 mg/kg-day
(females)
ECHA, 2011b
Sufficient study details reported in a
secondary source; test substance
identified as s-trazinetriol,
monosodium salt (monosodium
cyanurate monohydrate) 99.5%
(equivalent to 76.9% cyanuric acid).
NOAEL >1,523 mg/kg-day (male)
NOAEL >1,582 mg/kg-day (female)
4-407
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: Rat, oral (drinking
water, 13-week toxicity study; there were
no treatment-related effects
NOAEL >521 mg/kg-day (male)
NOAEL >717 mg/kg-day (female)
ECHA, 2011b
Sufficient study details reported in a
secondary source; test substance
identified as s-trazinetriol,
monosodium salt (monosodium
cyanurate monohydrate) (equivalent
to 77.34% cyanuric acid).
Immune System Effects
Melamine: Did not inhibit the
mitogenesis of B- and T- lymphocytes in
an in vitro mouse lymphocyte
mitogenesis test.
ECHA, 2011a
Reported in a secondary source.
Skin Sensitization
LOW: Estimated based on evidence of mild skin sensitization following exposure to the dissolution product
cyanuric acid in mice. Melamine, also a dissolution product of melamine cyanurate, was not a skin sensitizer
to humans or guinea pigs. There were no data located for melamine cyanurate for skin sensitization.
Skin Sensitization
Melamine: No evidence of primary
dermal irritation or sensitization in a
human patch test
American Cyanamid Company,
1955; Trochimowicz et al.,
2001
Sufficient study details were not
available.
Melamine: Non-sensitizing to guinea
pigs
Fasset and Roudabush,
1963/1981 (as described in
OECD SIDS, 1999a and
Trochimowicz et al., 2001);
Trochimowicz et al., 2001
Sufficient study details were not
available.
Cyanuric acid: Borderline or mild skin
sensitization in mice.
ECHA, 2011b
Sufficient study details reported in a
secondary source; OECD guideline
429.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
LOW: Estimated based on mild-to-moderate irritation to rabbit eyes following exposure to the dissolution
products melamine and cyanuric acid. There were no data located for melamine cyanurate for eye
irritation.
Eye Irritation
Melamine: Non-irritating to rabbit eyes
BASF, 1969 (as described in
OECD SIDS, 1999a and
IUCLID, 2000)
Sufficient study details were not
available.
4-408
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Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Non-irritating to rabbit eyes
following 0.5 mL of 10% melamine
American Cyanamid Company,
1955; Trochimowicz et al.,
2001
Sufficient study details were not
available.
Melamine: Mild irritant to rabbit eyes
following exposure to 30 mg of dry
powder
American Cyanamid Company,
1955; Trochimowicz et al.,
2001
Sufficient study details were not
available.
Melamine: Slightly irritating to rabbit
eyes
Marhold, 1972 (as described in
IUCLID, 2000 and RTECS,
2009)
Sufficient study details were not
available.
Cyanuric acid: Slightly to moderately
irritating to rabbit eyes
OECD SIDS, 1999b
Sufficient study details reported in
secondary source; OECD guideline
405.
Cyanuric acid: Slightly irritating to
rabbit eyes; fully reversible within 3 days
ECHA, 2011b
Sufficient study details reported in a
secondary source; OECD guideline
405.
Dermal Irritation
LOW: Estimated based on slight irritation to rabbit skin following exposure to the dissolution product
cyanuric acid. Melamine, also a dissolution product of melamine cyanurate was not irritating to rabbit skin.
There were no data located for melamine cyanurate for skin irritation.
Dermal Irritation
Melamine: Not irritating to rabbit skin
Rijcken, 1995 (as described in
OECD SIDS, 1999a)
OECD 404 guideline study.
Melamine: Not irritating to rabbit skin
BASF, 1969 (as described in
OECD SIDS, 1999a and
IUCLID, 2000)
Sufficient study details were not
available.
Melamine: Not irritating to rabbit skin
American Cyanamid Company,
1955; Trochimowicz et al.,
2001
Sufficient study details were not
available.
Melamine: Not irritating to rabbit skin
Fasset and Roudabush,
1963/1981 (as described in
OECD SIDS, 1999a and
Trochimowicz et al., 2001);
Trochimowicz et al., 2001
Sufficient study details were not
available.
4-409
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: Slightly irritating to
rabbit skin
OECD SIDS, 1999b; ECHA,
2011b
Sufficient study details reported in a
secondary source; OECD guideline
404.
Endocrine Activity
There were insufficient data located to t
In one study, melamine did not exhibit e
escribe the effect of melamine cyanurate on the endocrine system,
strogenic activity in vitro in a yeast two-hybrid assay.
Melamine: Showed no estrogenic
activity (no change in B-galactosidase
activity) in an in vitro yeast two-hybrid
assay in Sacchctromyces cerevisicte Y
190
ECHA, 2011a
Reported in a secondary source.
Nonguideline study.
Immunotoxicity
Located data were not sufficient to determine the hazard potential for this endpoint.
Immune System Effects
Melamine: Did not inhibit the
mitogenesis of B- and T- lymphocytes in
an in vitro mouse lymphocyte
mitogenesis test.
ECHA, 2011a
Reported in a secondary source.
ECOTOXICITY
ECOSAR Class
Melamine: Anilines (amino-meta), Melamines; Cyanuric acid: Aromatic triazines
Acute Toxicity
LOW: Melamine cyanurate has low water solubility and therefore it is estimated that it will display no
effects at saturation (NES) because the amount dissolved in water is not anticipated to reach a
concentration at which adverse effects may be expressed. A Low hazard potential is also assigned for the
dissociation products, melamine and cyanuric acid, based on experimental data.
Fish LC50
Melamine cyanurate:
No data located.
Not amenable to estimation by
available models that cannot accept
chemicals with complex organic
cations and anions.
Melamine cyanurate: Melamine
cyanurate has low water solubility and
therefore it is estimated that it will
display NES.
Professional judgment
The amount of melamine cyanurate
dissolved in water is not anticipated
to reach a concentration at which
adverse effects may be expressed.
Melamine : Leuciscus idas melanotus
48-hour LC50 >500 mg/L (Experimental)
OECD SIDS, 1999a
Study details reported in a
secondary source.
4-410
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Oryzias latipes 48-hour LC50
= 1,000 mg/L
(Experimental)
OECD SIDS, 1999a
Study details reported in a
secondary source.
Melamine: Poecilia reticulata 96-hour
LC50 >3,000 mg/L
(Experimental)
OECD SIDS, 1999a
Study details reported in a
secondary source.
Melamine: Poecilia reticulata 4,400
mg/L dose lethal to <10%
(Experimental)
OECD SIDS, 1999a
Study details reported in a
secondary source.
Melamine: Fish 96-hour LC50 = 2,680
mg/L
(Estimated)
ECOSAR: Anilines (amino-meta)
ECOSAR version 1.11
Melamine: Fish 96-hour LC50 = 391
mg/L
(Estimated)
ECOSAR: Melamines
ECOSAR version 1.11
Melamine: Fish 96-hour LC50 = 14,272
mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Cyanuric acid: Oryzias latipes 96-hour
LC50 >100 mg/L
Semi-static and flow-through open
conditions (Experimental)
OECD SIDS 1999b
99.7% purity; study details reported
in a secondary source; separate
experiments conducted with flow-
through and semi-static conditions
according to OECD TG203
guidelines.
4-411
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: Lepomis macrochirns
(fathead minnow) 96-hour LC50 >1,000
mg/L
Static conditions
(Experimental)
ECHA, 2011b
Purity unknown; not a guideline
study but well-reported in a
secondary source.
Cyanuric acid: Pimephcdes promelas
(bluegill sunfish) 96-hour LC50 >2,100
mg/L
Static conditions
(Experimental)
ECHA, 2011b
Well-reported in a secondary
source.
Cyanuric acid: Fish 96-hour LC50 =
72.04 mg/L
(Estimated)
ECOSAR: Aromatic triazines
ECOSAR version 1.11
Cyanuric acid: Fish 96-hour LC50 =
116.98 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Daphnid LCS0
Melamine cyanurate:
No data located.
Not amenable to estimation by
available models that cannot accept
chemicals with complex organic
cations and anions.
Melamine cyanurate: Melamine
cyanurate has low water solubility and
therefore it is estimated that it will
display NES.
Professional judgment
The amount of melamine cyanurate
dissolved in water is not anticipated
to reach a concentration at which
adverse effects may be expressed.
Cyanuric acid: Daphnict magna 48-hour
EC50 = 1,000 mg/L (immobilization);
static, open-system conditions
(Experimental)
OECD SIDS, 1999b
99.7% purity; study details reported
in a secondary source; study
conducted according to OECD
TG202 guidelines guideline study;
4-412
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
1,000 mg/L was the highest dose
tested.
Cyanuric acid: Daphnia magna 48-hour
LCso >1,000 mg/L
Static conditions
(Experimental)
ECHA, 2011b
Not a guideline study, but well-
reported in a secondary source;
purity not known.
Cyanuric acid: Daphnid 48-hour LC50 =
34.65 mg/L
(Estimated)
ECOSAR: Aromatic triazines
ECOSAR version 1.11
Cyanuric acid: Daphnid 48-hour LC50 =
61.33 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Melamine: Daphnid 48-hour LC50 =
6.23 mg/L
(Estimated)
ECOSAR: Anilines (amino-meta)
ECOSAR version 1.11
Melamine: Daphnid 48-hour LC50 =
144.34 mg/L
(Estimated)
ECOSAR: Melamines
ECOSAR version 1.11
Melamine: Daphnid 48-hour LC50 =
4,805 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
4-413
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green Algae ECS0
Melamine cyanurate:
No data located.
Not amenable to estimation by
available models that cannot accept
chemicals with complex organic
cations and anions.
Melamine cyanurate: Melamine
cyanurate has low water solubility and
therefore it is estimated that it will
display NES.
Professional judgment
The amount of melamine cyanurate
dissolved in water is not anticipated
to reach a concentration at which
adverse effects may be expressed.
Melamine: Scenedesmus pannonicus 4-
day EC50 = 940 mg/L
(Experimental);
4-day NOEC = 320 mg/L
(Experimental)
OECD SIDS, 1999a
Reported in a secondary source,
study details and test conditions
were not provided.
Melamine: Green algae 96-hour EC50 =
2.79 mg/L
(Estimated)
ECOSAR class: Anilines (amino-meta)
ECOSAR version 1.11
Melamine: Green algae 96-hour EC50 =
325 mg/L
(Estimated)
ECOSAR class: Melamines
ECOSAR version 1.11
Melamine: Green algae 96-hour EC50 =
4,396 mg/L
(Estimated)
ECOSAR class: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Cyanuric acid: Selenastrum
cctpricornuturn 72-hour EC50 = 620 mg/L
(biomass)
72-hour NOEC = 62.5 mg/L
(Experimental)
OECD SIDS, 1999b
Cyanuric acid (99.7% purity); study
details reported in a secondary
source; study conducted according
to OECD TG201 guidelines.
4-414
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: Green algae 96-hour
EC50 = 0.11 mg/L
(Estimated)
ECOSAR: Aromatic triazines
ECOSAR version 1.11
Cyanuric acid: Green algae 96-hour
EC50 = 56.87 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Chronic Aquatic Toxicity
LOW: Melamine cyanurate has low water solubility and therefore it is estimated that it will display NES
because the amount dissolved in water is not anticipated to reach a concentration at which adverse effects
may be expressed. A Low potential for hazard is also for assigned for the dissociation products, melamine
and cyanuric acid, based on experimental data.
Fish ChV
Melamine cyanurate:
No data located.
Not amenable to estimation by
available models that cannot accept
chemicals with complex organic
cations and anions.
Melamine cyanurate: Melamine
cyanurate has low water solubility and
therefore it is estimated that it will
display NES.
Professional judgment
The amount of melamine cyanurate
dissolved in water is not anticipated
to reach a concentration at which
adverse effects may be expressed.
Melamine: Jordanellct floridcte 35-day
NOEC >1,000 mg/L (Experimental)
OECD SIDS, 1999a
Reported in a secondary source,
study details and test conditions
were not provided.
Melamine: Sctlmo gctirdneri NOEC
(macroscopic) = 500 mg/L
(Experimental);
NOEC (microscopic) <125 mg/L
(Experimental)
OECD SIDS, 1999a
Reported in a secondary source,
study details and test conditions
were not provided.
4-415
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Daphnia magna 21-day LC50
= 32-56 mg/L, 21-day LCKlo = 56 mg/L,
21-day NOEC =18 mg/L (Experimental)
OECD SIDS, 1999a
Reported in a secondary source,
study details and test conditions
were not provided.
Melamine: Fish ChV = 263 mg/L
(Estimated)
ECOSAR: Anilines (amino-meta)
ECOSAR version 1.11
The toxicity value was estimated
through application of acute to
chronic ratios (ACRs).
Melamine: Fish ChV = 1,102 mg/L
(Estimated)
ECOSAR: Melamines
ECOSAR version 1.11
Melamine: Fish ChV = 1,076 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Cyanuric acid: Oncorhynchus mykiss
(rainbow trout) 28-day LOEC >1,000
mg/L (based on growth rate)
Semi-static conditions (OECD guideline
215)
(Experimental)
ECHA, 2011b
Guideline study; well-reported in a
secondary source; >97% purity.
Cyanuric acid: Fish ChV =1.85 mg/L
(Estimated)
ECOSAR: Aromatic triazines
ECOSAR version 1.11
4-416
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: Fish ChV = 11.38 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Daphnid ChV
Melamine cyanurate:
No data located.
Not amenable to estimation by
available models that cannot accept
chemicals with complex organic
cations and anions.
Melamine cyanurate: Melamine
cyanurate has low water solubility and
therefore it is estimated that it will
display NES.
Professional judgment
The amount of melamine cyanurate
dissolved in water is not anticipated
to reach a concentration at which
adverse effects may be expressed.
Cyanuric acid: Daphnia magna 21-day
EC5n = 65.9 mg/L (reproduction rate);
NOEC = 32.0 mg/L
Semi-static, open-system conditions
(OECD TG202)
(Experimental)
OECD SIDS, 1999b
99.7% purity; study details reported
in a secondary source; guideline
study.
Cyanuric acid: Daphnia magna 21-day
EC50 = 2,117 mg/L cyanuric acid
(immobilization)
LOEC = 378 mg/L cyanuric acid
(mortality and reproduction)
NOEC = 121 mg/L cyanuric acid
Static conditions (OECD guideline 211)
(Experimental)
ECHA, 2011b
Guideline study; well-reported in a
secondary source; >97% purity.
Cyanuric acid: Daphnid ChV = 1.49
mg/L
(Estimated)
ECOSAR class: Aromatic triazines
ECOSAR version 1.11
4-417
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: Daphnid ChV = 6.37
mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Melamine: Daphnid ChV = 0.078 mg/L
(Estimated)
ECOSAR class: Anilines (amino-meta)
ECOSAR version 1.11
Melamine: Daphnid ChV = 14.85 mg/L
(Estimated)
ECOSAR: Melamines
ECOSAR version 1.11
The toxicity value was estimated
through application of ACRs.
Melamine: Daphnid ChV = 343.93
mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Green Algae ChV
Melamine cyanurate:
No data located.
Not amenable to estimation by
available models that cannot accept
chemicals with complex organic
cations and anions.
Melamine cyanurate: Melamine
cyanurate has low water solubility and
therefore it is estimated that it will
display NES.
Professional judgment
The amount of melamine cyanurate
dissolved in water is not anticipated
to reach a concentration at which
adverse effects may be expressed.
Melamine: Green algae ChV = 0.70
mg/L
(Estimated)
ECOSAR: Anilines (amino-meta)
ECOSAR version 1.11
The toxicity value was estimated
through application of ACRs.
4-418
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Green algae ChV = 81.26
mg/L
(Estimated)
ECOSAR: Melamine s
ECOSAR version 1.11
The toxicity value was estimated
through application of ACRs.
Melamine: Green algae ChV = 313.17
mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Cyanuric acid: Navicula pelliculosa 72-
hour EC50 = 2,041 mg/L cyanuric acid
(biomass)
96-hour EC50 >3,780 mg/L cyanuric acid
(biomass)
72-hour EC50 >3,780 mg/L cyanuric acid
(growth rate)
96-hour EC50 >3,780 mg/L cyanuric acid
(growth rate)
72-hour NOEC= 945 mg/L cyanuric acid
96-hour NOEC= 3,780 mg/L cyanuric
acid
Static conditions (ISO 10253)
(Experimental)
ECHA, 2011b
Guideline study; well-reported in a
secondary source; 99.1% purity.
4-419
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Cyanuric acid: Selenastrum
cctpri cornu turn
24-hour EC50 >1,000 mg/L (based on
decreased in vivo chlorophyll alpha)
48-hour EC50 >1,000 mg/L (based on
decreased in vivo chlorophyll alpha)
72-hour EC50 = 872 mg/L (based on
decreased number of cells)
96-hour EC50 >712 mg/L (based on
decreased number of cells)
(Experimental)
ECHA, 2011b
Cyanuric acid; not a guideline
study, but test procedures followed
those of U.S. EPA Algal Assay
Procedure: Bottle test (1971); well-
reported in a secondary source;
77.5% purity.
Cyanuric acid: Green algae ChV = 0.06
mg/L
(Estimated)
ECOSAR: Aromatic triazines
ECOSAR version 1.11
Cyanuric acid: Green algae ChV =
12.55 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
ENVIRONMENTAL FATE
Transport
The measured low water solubility and estimated low vapor pressure indicate that melamine cyanurate is
anticipated to partition predominantly to soil and sediment. Melamine cyanurate is not expected to migrate
from soil to groundwater; aromatic amines tend to bind with humic matter in soil. It is not expected to
volatilize from water. Volatilization from dry surface is also not expected based on its vapor pressure. In the
atmosphere, melamine cyanurate is expected to exist solely in the particulate phase, based on its estimated
vapor pressure. Particulates may be removed from air by wet or dry deposition.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment
Cutoff value for nonvolatile
compounds based on the ionic nature
of the material.
4-420
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>1,000 (Estimated)
Professional judgment
Driven by structural analysis of
melamine; aromatic amines form
covalent bonds to humic matter in
soils and sediments, binding
irreversibly.
Level III Fugacity Model
Not all input parameters for this
model were available to run the
estimation software (EPI) for the
hydrogen bonded melamine cyanurate
complex.
Persistence
VERY HIGH: Based on an experimental biodegradation study (OECD 301B) that demonstrated it was not
readily biodegradable. This result is consistent with its negligible water solubility suggesting that it is not
likely to be readily assimilated by microorganisms. Other degradative processes are not expected to be
operative under environmental conditions. Melamine cyanurate is not expected to undergo complete
dissolution under neutral conditions, nor under the pHs typically found in the environment. However, it
rapidly dissociates under pH extremes. It is least soluble at pH 5 but most soluble at pH 3.5 and below.
Melamine cyanurate does not contain chromophores that absorb at wavelengths >290 nm, indicating that it is
not expected to be susceptible to direct photolysis by sunlight. The dissociation products, melamine and
cyanuric acid salts, have experimental studies indicating that they are not expected to biodegrade under
aerobic conditions when assessed as their corresponding neutral organic components. However, experimental
studies indicate that cyanuric acid may degrade in anoxic environs.
Water
Aerobic Biodegradation
Melamine cyanurate: Not readily
biodegradable according to OECD
Guideline 301 B (Ready Biodegradability:
C02 Evolution Test) (Measured)
ECHA, 2011a
Adequate, guideline study.
Volatilization Half-life for
Model River
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
Volatilization Half-life for
Model Lake
>1 year (Estimated)
Professional judgment
Based on the magnitude of the
estimated Henry's Law Constant.
4-421
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Soil
Aerobic Biodegradation
Melamine: Not readily biodegradable: 0%
biodegradation detected after 2 weeks with
100 ppm in 30 ppm activated sludge
(OECD TG 301C) (Measured); 0%
degradation after 28 days with 100 mg
DOC/L in activated sludge (Zahn-Wellens
test, OECD 302B) (Measured)
Cyanuric Acid: Not readily
biodegradable: 0% biodegradation
detected after 2 weeks with 100 ppm in 30
ppm activated sludge (0% biochemical
oxygen demand; 7.8% total organic
carbon) (OECD TG 301C) (Measured)
MITI, 1998; OECD SIDS, 1999a
Adequate values from guideline
studies for the melamine cyanurate
complex components.
Anaerobic
Biodegradation
Cyanuric Acid: 100% degradation after
72-96 hours in anaerobic sewage at 10
(ig/mL (Measured); 0% methane
production after 1-year incubation in
anoxic aquifer slurries (Measured)
Saldick, 1974; Adrian and
Suflita, 1994
Inadequate, these data values are not
applicable for the melamine
cyanurate complex.
Melamine: 0-8.9% nitrification was
observed after 28 days incubation with
bacteria in Webster silty clay loam under
anaerobic conditions (Measured)
IUCLID, 2000
This value is for melamine. Reported
in a secondary source, study details
and test conditions were not provided.
Soil Biodegradation w/
Product Identification
Melamine: Nitrification of melamine
occurs in soil at a low rate (0.7 % organic
N found as N03-N in week 10, and 0% in
week 28). (Measured)
Cyanuric Acid: 35 % nitrification at week
10 and 73 % at week 28. (Measured)
ECHA, 2011a
Nonguideline studies for the
melamine cyanurate complex
components.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
Melamine: 16 days (Estimated)
Cyanuric Acid: 43 hours (Estimated)
EPI
4-422
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine Cyanurate: The test substance
was found to be thermally stable within the
range 40-290°C according to a method
similar to OECD Guideline 113 (Screening
Test for Thermal Stability and Stability in
Air) (Measured)
ECHA, 2011a
Nonguideline study.
Reactivity
Photolysis
Melamine Cyanurate, Melamine and
Cyanuric acid: Not a significant fate
process (Estimated)
Mill, 2000; Professional
judgment
These substances do not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
Hydrolysis
Melamine Cyanurate: The effect of pH
on the solubility of melamine cyanurate
has established that the minimum lies at
pH 5. Decreasing the pH results in the
formation of melamine cations and
cyanuric acid in solution at pH 3.5 and
below. Increasing the pH from 5 to 7.5
results in only a marginal increase in the
dissolution of the melamine cyanurate
complex. (Measured)
WHO, 2009
These results are consistent with that
expected in a closed system. Under
environmental conditions, infinite
dilution may alter the equilibrium of
the process towards enhanced
dissolution.
Environmental Half-life
Melamine Cyanurate: >1 year
(Estimated)
Melamine: 75 days (Estimated)
Cyanuric Acid: 30 days (Estimated)
Professional judgment; EPI; PBT
Profiler
Melamine cyanurate is not anticipated
to be assimilated by microorganisms.
Therefore, biodegradation is not
expected to be an important removal
process. It is also not expected to be
removed by other degradative
processes under environmental
conditions because of its limited
water solubility and limited
partitioning to air.
4-423
-------
Melamine Cyanurate CASRN 37640-57-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Bioaccumulation
LOW: Melamine cyanurate has negligible water solubility under near neutral conditions and is expected to
have poor bioavailability resulting in low potential for bioaccumulation. In addition, experimental BCF data
for the organic components of melamine cyanurate, melamine and cyanuric acid are <100. These
experimental values also indicate a low potential for bioaccumulation.
Fish BCF
Melamine Cyanurate: <100 (Estimated)
Professional judgment
This estimated value is based on the
BCF results for the components
melamine and cyanurate.
Melamine: <0.38 in carp (Cyprinus
carpio) after 6 weeks at 2.0 ppm
concentration;
<3.8 in carp (Cyprinus cctrpio) after 6
weeks at 0.2 ppm concentration (OECD
302B) (Measured)
Cyanuric Acid: <0.1 in carp (Cyprinus
carpio) after 6 weeks at 10 ppm
concentration;
<0.5 in carp (Cyprinus carpio) after 6
weeks at 1 ppm concentration (Measured)
MITI, 1998
Adequate values from guideline
studies for the melamine cyanurate
complex components.
BAF
Melamine: <1 (Measured)
Cyanuric Acid: 2.1 (Estimated)
OECD SIDS, 1999a; IUCLID,
2000; EPI
These values are for the individual
components.
Metabolism in Fish
Melamine: Uptake, bioaccumulation and
elimination study with 14C-melamine in
fathead minnow (BCF = 0.48 and 0.26)
and rainbow trout (BCF = 0.11, 0.05, 0.03)
(Measured)
ECHA, 2011a
Nonguideline studies that support the
low bioaccumulation potential for this
substance.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-424
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Adrian, NR; Suflita, JM. Anaerobic biodegradation of halogenated and nonhalogenated N-, S-, and other O-heterocyclic compounds
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4-425
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7c0133al3252 DISS-9c7f523d-20c7-373f-e044-00144f67d249.html#AGGR-3fddcbaa-68ea-4e97-bb90-7c0133al3252 (accessed on
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4-431
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Melamine Polyphosphate
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame-retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance, including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
§ Based on analogy to experimental data for a structurally similar compound.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Melamine Polyphosphate1
15541-60-3
L
M
M
L
M
L
L
VL
L
L
H
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
1 Hazard designations are based upon the component of the salt with the highest hazard designation, including the corresponding free acid or base.
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Melamine Polyphosphate
CASRN: 15541-60-3
MW: >1,000
MF: C3H6N6 (H3P04)n
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: n(c(nc(nl)N)N)clN(H)(H)0P(=0)(0)QP(=0)(0)0 (n =1)
Synonyms: Diphosphoric acid, compound with l,3,5-triazine-2,4,6-triamine; Polyphosphoric acids, compounds with melamine. The CASRN for the compound
melamine pyrophosphate is 15541-60-3. The CASRN 218768-84-4 is associated with the product Melapur 200, not the chemical melamine polyphosphate.
Chemical Considerations: This alternative contains a polymeric moiety. Although the chain length of the polyphosphoric acid is not specified, the smaller, water-
soluble polyphosphate ions were used in assessment (generally as the diphosphate ion, n=l). Melamine polyphosphate will freely dissociate under environmental
conditions. Measured values from studies on the dissociated components were used to supplement data gaps as appropriate and EPI v 4.0 was used to estimate
physical/chemical and environmental fate values in the absence of experimental data. Measured values from experimental studies were incorporated into the
estimations.
Polymeric: Yes
Oligomers: Melamine polyphosphate is a complex mixture consisting of melamine and polyphosphate chains of varying length.
Metabolites, Degradates and Transformation Products: Melamine (CASRN 108-78-1)
Analogs: Confidential structurally similar polymers; Polyphosphoric acid (8017-16-1) and melamine (108-78-1) Analog Structure:
are the dissociated components of this salt
Endpoint(s) using analog values: Reproductive effects; neurotoxicity; immunotoxicity H2N\r^N^T/NH2 Q Q
I T ii ii
NV>N J"P-OH
T Hon i ^o-tT I
NH2 OH OH
Structural Alerts: Aromatic amine, genetic toxicity (EPA, 2010)
Risk Phrases: Not classified by Annex I Directive 67/548/European Economic Community & IUCLID (Pakalin et al., 2007).
Hazard and Risk Assessments: Australian Safety and Compensation Council National Industrial Chemicals Notification and Assessment Scheme (NICNAS),
October 30, 2006 (Australia, 2006); U.S. EPA Design for the Environment Alternatives Assessment for Flame Retardants in Printed Circuit Boards, Review Draft,
November 8, 2008 (EPA, 2008).
H2N
H
l +
,N„
YY
N^N
NH,
NH,
O
-Pv
Cf
O
H0-^CP\^0^P\
-OH
OH
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Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
>400 (Measured)
Submitted confidential study
Adequate; value for the melamine
polyphosphate salt.
>400 (Measured)
Australia, 2006
Adequate; value for the melamine
polyphosphate salt.
Boiling Point (°C)
>300 (Estimated)
EPI; Professional judgment
As an organic salt, it is expected to
decompose before boiling.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
EPI; Boethling et al., 1997
Cutoff value for nonvolatile
compounds
Water Solubility (mg/L)
20,000 (Measured)
Submitted confidential study
Adequate; value for the melamine
polyphosphate salt.
20,000 (Measured)
Australia, 2006
Adequate.
Log Kow
<-2 (Estimated)
EPI
Cutoff value for highly water soluble
substances.
Flammability (Flash Point)
Not highly flammable (Measured)
Submitted confidential study
Adequate.
Explosivity
Not a potential explosive (Measured)
Submitted confidential study
Adequate.
Not a potential explosive (Measured)
Australia, 2006
Adequate.
Pyrolysis
No data located.
pH
No data located.
pKa
No data located.
HUMAN HEALTH EFF]
ECTS
Toxicokinetics
No toxicokinetic data located for melamine polyphosphate or polyphosphoric acid; limited data for melamine
indicate an elimination phase half-life of 2.7 hours from plasma and 3.0 hours for urine.
Dermal Absorption in vitro
No data located.
Absorption, Oral, Dermal or Inhaled
Distribution,
Melamine polyphosphate: Low for all
routes (Estimated)
Professional judgment
Estimates based on physical/chemical
properties.
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Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Metabolism &
Excretion
Melamine: The elimination phase half-life
calculated from plasma data was 2.7 hours,
and the urinary half-life was 3.0 hours. The
renal clearance was determined to be 2.5
mL/minute.
Mast et al., 1983
Adequate, nonguideline study.
Melamine: Distributed to stomach, small
intestine, cecum, and large intestine, and
found in blood and urine of rats.
ECHA, 2011b
Study details reported in a secondary
source.
Acute Mammalian Toxicity
LOW: Melamine polyphosphate is expected to be of low hazard for acute toxicity based on experimental
evidence for melamine polyphosphate, phosphoric acids and melamine. The weight of evidence indicates that
when administered orally and dermally to rats, mice and rabbits, melamine polyphosphate, polyphosphoric
acid, and melamine do not produce mortality at doses >1,000 mg/kg.
Acute Lethality
Oral
Melamine polyphosphate: Rat (Gavage)
LD50 >2,000 mg/kg
Ciba, 2005 (as described in
Australia, 2006)
Sufficient study details reported.
Melamine polyphosphate: Rat LD50
>2,000 mg/kg bw
NOTOX B.V., 1998 (as described
in Australia, 2006)
Limited study details reported.
Melamine polyphosphate: Rat (Gavage)
LD50 >2,000 mg/kg
Submitted confidential study
Study details reported in a
confidential study.
Melamine polyphosphate: Rat LD5n
>2,000 mg/kg
Submitted confidential study
Limited study details reported in a
confidential study.
Polyphosphoric acid: LD50 = 4,000 mg/kg
(species unknown)
ARZNAD, 1957
Limited study details reported. The
test substance was identified as
polyphosphates, and was described as
containing 1/3 Kurrol's potassium salt
and 2/3 pyrophosphate.
4-435
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Rat LD50 = 3,161 mg/kg
(male), 3,828 mg/kg (females)
NTP, 1983; Melnick et al., 1984
Sufficient study details reported.
Melamine: Mouse LD50 = 3,296 mg/kg
(male), 7,014 mg/kg (female)
NTP, 1983; Melnick et al., 1984
Sufficient study details reported.
Melamine: Mouse LD50 = 4,550 mg/kg
Trochimowicz et al., 2001;
American Cyanamid Company,
1955; May, 1979
Limited study details reported.
Melamine: Rat LD50 = 3,160 mg/kg
(male) and 3,850 mg/kg (female)
Trochimowicz et al., 2001
Limited study details reported.
Melamine: Rat LD50 >6,400 mg/kg
BASF, 1969 (as described in
OECD SIDS, 1999 and IUCLID,
2000a)
Limited study details reported.
Melamine: LD50 ~ 4,800 mg/kg
Hoechst, 1963 (as described in
IUCLID, 2000a)
Limited study details reported.
Dermal
Melamine: Rabbit LD50 >1,000 mg/L
Unknown, 1990
Limited study details reported.
Inhalation
Melamine: Rat LC50 = 3.248 mg/L
Ubaidullajev, 1993
Limited study details reported.
Carcinogenicity
MODERATE: Estimated based on the dissolution product melamine. There is experimental evidence that
oral melamine exposure causes carcinogenicity in animals; however, no data were located to support its
carcinogenicity in humans. Tumor formation in animals appeared to happen in a mechanical nature under
conditions in which it produced bladder calculi. No carcinogenicity data for melamine polyphosphate were
located. The International Agency for Research on Cancer (IARC) classifies melamine as Group 3: not
classifiable as to its carcinogenicity to humans.
OncoLogic Results
Melamine: Marginal (Estimated)
OncoLogic, 2008
Carcinogenicity (Rat and
Mouse)
Melamine: Group 3: melamine is not
classifiable as to its carcinogenicity to
humans; there is inadequate evidence in
humans for the carcinogenicity of
melamine, and there is sufficient evidence
in experimental animals for the
carcinogenicity of melamine under
conditions in which it produces bladder
calculi.
IARC, 1999
IARC classification statement.
4-436
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Significant formation of
transitional cell carcinomas in the urinary
bladder of male rats and significant
chronic inflammation in the kidney of
dosed female rats were observed.
Carcinoma formation was significantly
correlated with the incidence of bladder
stones. A transitional-cell papilloma was
observed in the urinary bladder of a single
high dose male rat, and compound related
lesions were observed in the urinary tract
of dosed animals.
NTP, 1983; Huff, 1984; Melnick
et al., 1984
Sufficient study details reported.
Melamine: Increased incidence of acute
and chronic inflammation and epithelial
hyperplasia of the urinary bladder were
observed in male mice. Bladder stones and
compound-related lesions were observed
in the urinary tract of test animals.
Melamine was not considered
carcinogenic.
NTP, 1983; Huff, 1984; Melnick
et al., 1984
Sufficient study details reported.
Melamine: Melamine-induced
proliferative lesions of the rat urinary tract
were directly due to the irritant stimulation
of calculi, and not to molecular
interactions between melamine or its
metabolites with the bladder epithelium.
Okumura et al., 1992
Sufficient study details reported.
4-437
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Water intake, used as an index
of urinary output, was increased by NaCl
treatment. Calculus formation resulting
from melamine administration was
suppressed dose-dependently by the
simultaneous NaCl treatment. The main
constituents of calculi were melamine and
uric acid (total contents 61.1-81.2%). The
results indicate that melamine-induced
proliferative lesions of the urinary tract of
rats were directly due to the irritation
stimulation of calculi, and not molecular
interactions between melamine itself or its
metabolites with the bladder epithelium.
Ogasawara et al., 1995
Sufficient study details reported.
Melamine: As an initiator, melamine
caused no significant increase in
papillomas per mouse when compared to
controls.
Perrella and Boutwell, 1983
Nonguideline study.
Melamine: Diffuse papillary hyperplasia
of the bladder epithelium and bladder
calculi were observed in all melamine
treated rats. Elevated spermidine/spermine
N1 -acetyltransferase activity following
melamine treatment was considered to be
an indicator of cell proliferation.
Matsui-Yuasa et al., 1992
Nonguideline study.
Melamine: Decreased antitumor activity
was correlated with increasing
demethylation; melamine was considered
inactive as an antitumor drug.
Rutty and Connors, 1977
Limited study details reported.
Melamine: In an in vitro cytotoxicity
study in cultured ADJ/PC6 plasmacytoma
ascites tumor cells, the ID50 was 470
(ig/mL after 72 hours of treatment.
Rutty and Abel, 1980
Limited study details reported.
4-438
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Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Combined Chronic
Toxicity/ Carcinogenicity
Melamine: No effects were observed in
rats fed 1,000 ppm of melamine. Four of
the 10 rats fed 10,000 ppm melamine had
bladder stones associated with the
development of benign papillomas.
Anonymous, 1958 (as described
in EPA, 1992)
Limited study details reported.
Melamine: Increased incidence of urinary
bladder stones (6/20 rats) was noted in the
10,000 ppm dose group, and was
associated with an increase in benign
papillomata. The NOAEL was determined
to be 1,000 ppm (67 mg/kg).
American Cyanamid Company,
1955
Limited study details reported.
Genotoxicity
MODERATE: Melamine polyphosphate is estimated to be a moderate hazard for genotoxicity based on the
data for melamine. For melamine, positive results were observed for in vivo chromosome aberration and
sister chromatid exchange assays conducted by National Toxicology Program (NTP) in 1988 and 1989.
Available in vitro genotoxicity testing was conducted with metabolic activation systems from the liver. NTP
suggests this may not account for potential activation from bladder epithelial cells, which is the target organ.
Proposed genotoxicity testing using a metabolic activation system from bladder epithelial cells (NTP, 1983)
was never conducted (Personal Communication, 2007; 2008).
Gene Mutation in vitro
Melamine: Bacterial forward mutation
assay: Negative with and without liver
activation
Haworth et al., 1983; NCI/NTP,
2007
Sufficient study details reported.
Melamine: Bacterial forward mutation
assay: Negative
Seiler, 1973
Limited study details reported.
Melamine: Bacterial reverse mutation
assay: Negative with and without liver
activation
Lusby et al., 1979
Limited study details reported.
Melamine: Bacterial reverse mutation
assay: Negative with and without
unspecified metabolic activation
Mast et al., 1982a
Limited study details reported.
Melamine: In vitro mouse lymphoma test:
Negative with and without liver activation
McGregor et al., 1988; NCI/NTP,
2007
Sufficient study details reported.
4-439
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Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Chinese hamster ovary (CHO)
cells/hypoxanthine-guanine
phosphoribosyl-transferase forward
mutation assay: Negative with and without
liver activation
Mast et al., 1982a
Limited study details reported.
Gene Mutation in vivo
No data located.
Chromosomal Aberrations
in vitro
Melamine: In vitro chromosomal
aberrations test: Negative in CHO with and
without liver activation
Galloway et al., 1987; NCI/NTP,
2007
Sufficient study details reported.
Melamine: In vitro sister chromatid
exchange assay: Negative in CHO with
and without liver activation
Galloway et al., 1987; NCI/NTP,
2007
Sufficient study details reported.
Melamine: In vitro sister chromatid
exchange assay: Negative in CHO with
and without liver activation
Mast et al., 1982a
Limited study details reported.
Chromosomal Aberrations
in vivo
Melamine: In vivo mouse micronucleus
test: The initial test gave a positive trend
(P = 0.003) for chromosomal damage;
however, both peripheral blood smears and
the repeat bone marrow test were negative.
The overall conclusion was that melamine
does not induce chromosomal damage.
NTP, 1983; Shelby et al., 1993
Sufficient study details reported.
Melamine: In vivo mouse micronucleus
test: Negative without activation
Mast et al., 1982b
Limited study details reported.
Melamine: In vivo chromosome
aberrations test in mice: Positive
NCI/NTP, 2007
Sufficient study details reported.
Melamine: In vivo sister chromatid
exchange assay in mice: Positive
NCI/NTP, 2007
Sufficient study details reported.
4-440
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
DNA Damage and Repair
Melamine: In vivo and in vitro
unscheduled DNA synthesis (UDS) test:
None of the tested chemicals, including
melamine, were genotoxic
hepatocarcinogens in the in vivo assay, and
melamine was negative for UDS in the in
vitro assay.
Mirsalis et al., 1983
Limited study details reported.
Melamine: SOShimn test: Negative for its
ability to result in DNA damage and
induce the expression of the limn operon
Reifferscheid and Heil, 1996
Nonguideline study.
Melamine: DNA synthesis-inhibition test
in Hela S3 cells: Inhibits DNA synthesis
by 50% at greater than 300 (j,M
Heil and Reifferscheid, 1992
Limited study details reported.
Other
Melamine: Sex-linked recessive
lethal/reciprocal translocation: Results
were considered equivocal based on 0.18%
and 0.36% total lethal following oral and
injection exposure, respectively, compared
to control total lethal of 0.07% for oral and
0.09% for injection.
NCI/NTP, 2007
Sufficient study details reported.
Melamine: Drosophila Muller-5 test:
Negative for mutagenicity
Rohrborn, 1959
Limited study details reported.
Melamine: Drosophila melanogaster Sex-
linked recessive lethal: No mutagenic
effects were observed
Luers and Rohrborn, 1963
Limited study details reported.
Melamine: In vitro flow cytometric DNA
repair assay: Negative for genotoxic
effects
Seldonetal., 1994
Nonguideline study.
Melamine: Microscreen assay: Positive
for genetic toxicity in E. coli WP2 cells
Rossman et al., 1991
Nonguideline study.
4-441
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Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Growth and genotoxic effects
to bacteria (Salmonella typhimurium) and
yeast (Saccharomyces cerevisiae): Non-
mutagenic in S. typhimurium with or
without S-9 mix. The growth of eight out
of nine strains tested was delayed by 10
mM melamine during 24 hour cultivation.
S. cerevisiae strain was tested, and did not
recover its growth following 48 hour
cultivation.
Ishiwata et al., 1991
Limited study details reported.
Reproductive Effects
LOW: Estimated based on analogy to structurally similar compound and professional judgment. There were
no data for melamine polyphosphate located. Experimental data for the melamine component also support a
low hazard designation.
Reproduction/
Developmental Toxicity
Screen
Rat, oral; potential for reproductive
toxicity
(Estimated by analogy)
Professional judgment
Estimated based on analogy to
confidential analog; LOAEL not
identified; study details not provided.
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
No data located.
Reproduction and Fertility
Effects
Melamine: Reproductive dysfunction was
observed at 0.5 mg/irf and included effects
on spermatogenesis (genetic material,
sperm morphology, motility, and count),
effects on the embryo/fetus (fetal death),
pre-implantation mortality (reduction in
the number of implants per female), and
total number of implants per corpora lutea.
Ubaidullajev, 1993
Study details, if present, were not
translated into English.
Melamine: There were no treatment-
related macroscopic or microscopic effects
on mammary glands, ovaries, prostate,
seminal vesicles, testes and uterus in rats
and mice in a 13-week study.
OECD SIDS, 1999
Study details, including administered
dose information, were not provided.
4-442
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Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Developmental Effects
LOW: Melamine polyphosphate is estimated to have Low hazard for developmental effects based on the data
for melamine. For melamine, no adverse effects on gestational parameters, no signs of developmental toxicity.
Reproduction/
Developmental Toxicity
Screen
No data located.
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
No data located.
Prenatal Development
Melamine: Signs of maternal toxicity at
136 mg/kg-day included decreased body
weight and feed consumption, hematuria
(23/25 rats), indrawn flanks (7/25 rats),
and piloerection (1/25 rats). No adverse
effects on gestational parameters and no
signs of developmental toxicity were
noted.
NOAEL >1,060 mg/kg-day
Hellwig et al., 1996 (as cited in
OECD SIDS, 1999)
Sufficient study details reported.
Postnatal Development
Melamine: Only minor effects on the
fetuses or litters, including a non-
significant increase in resorptions in the
group treated on the 4th and 5th days of
gestation, were observed.
Thiersch, 1957
Sufficient study details were not
available.
Neurotoxicity
LOW: Based on professional judgment t
irough analogy to structurally similar polymers.
Neurotoxicity Screening
Battery (Adult)
Potential for neurotoxicity is expected to
be low
(Estimated)
Professional judgment
Estimated based on analogy and
professional judgment.
4-443
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Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Repeated Dose Effects
MODERATE: Melamine polyphosphate is expected to have moderate hazard for repeated dose effects based
on the data for melamine. Stones and diffuse epithelial hyperplasia in the urinary bladders were observed in
male rats at doses as low as 700 ppm (72 mg/kg/day).
Polyphosphoric Acid: Rat Repeated-Dose
Toxicity Study: An oral repeated-dose
toxicity test in rats resulted in a TDLo of
450 mg/kg. The test substance was
identified as polyphosphates, and was
described as containing 1/3 Kurrol's
potassium salt and 2/3 pyrophosphate.
Toxic effects included changes in liver
weight, changes in tubules (including acute
renal failure, acute tubular necrosis), and
weight loss or decreased weight gain.
ARZNAD, 1957
Sufficient study details were not
available.
4-444
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Rat 28-day dietary toxicity
study: Clinical signs included a dose-
related increase in pilo-erection, lethargy,
bloody urine spots in the cage and on the
pelage of animals, and chromodacryorrhea.
The incidence of urinary bladder calculi
and urinary bladder hyperplasia in treated
animals was dose-dependent, with a
significant relationship between the calculi
and hyperplasia. Calculi composition
indicated the presence of an organic matrix
containing melamine, phosphorus, sulfur,
potassium, and chloride. Crystals of
dimelamine monophosphate were
identified in the urine.
RTI, 1983
Sufficient study details reported.
NOAEL = was estimated to be 2,000 ppm
(240 mg/kg/day), excluding the observed
increase in water consumption and the
incidence of crystalluria.
LOAEL was determined to be 4,000 ppm
(475 mg/kg/day) based on the formation of
calculi.
Melamine: Rabbit and dog 28-day dietary
toxicity study: No significant rise in the
body temperature of rabbits was noted.
Gross histological examination of the
heart, lung, liver, spleen, thyroid, pancreas,
intestines, kidneys and bladder did not
show pathological changes. A zone of fat
was found in the inner part of the renal
cortex in two dogs, but also in the kidneys
of 3 control dogs.
Lipschitz and Stokey, 1945
Sufficient study details were not
available.
4-445
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Rat 28-day dietary toxicity
study: Incidence and size of bladder stones
were directly related to the amount of
substance administered. The larger stones
were found to be unchanged melamine in a
matrix of protein, uric acid and phosphate.
American Cyanamid Company,
1984
Sufficient study details were not
available.
Lowest effective dose: 1,500 ppm (-125
mg/kg) in males.
Chronic
Melamine: Rat 90-day dietary toxicity
study: one male rat receiving 18,000 ppm
and two males receiving 6,000 ppm died.
Mean body weight gain and feed
consumption were reduced. Stones and
diffuse epithelial hyperplasia in the urinary
bladders were observed in male rats of all
treatment groups. Focal epithelial
hyperplasia was observed in only 1 male.
A second and third 13-week repeated dose
toxicity study was conducted in rats at a
dose range of 750 to 18,000 ppm; bladder
stones were observed at all dose levels.
LOAEL = 700 ppm (72 mg/kg/day)
NTP, 1983; Melnick et al., 1984;
ECHA, 2011b
Sufficient study details reported.
4-446
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Mouse 90-day Dietary
Toxicity Study: A single female mouse
died after receiving 9,000 ppm. Mean body
weight gain relative to controls was
depressed. The incidence of mice with
bladder stones was dose-related and was
greater in males than in females. Sixty
percent of mice having bladder ulcers also
had urinary bladder stones. Bladder ulcers
were multifocal or associated with
inflammation (cystitis). Epithelial
hyperplasia and bladder stones were
observed together in 2 mice. Also,
epithelial cell atypia was seen.
NOAEL: 6,000 ppm (600 mg/kg-day)
LOAEL: 9,000 ppm (900 mg/kg-day)
NTP, 1983; Melnick et al., 1984
Sufficient study details reported.
Melamine: Increased incidence of acute
and chronic inflammation and epithelial
hyperplasia of the urinary bladder was
observed in mice following oral (feed)
exposure for up to 103 weeks. There was
also increased incidence of bladder stones
in male mice.
LOAEL = 2,250 ppm (lowest dose tested)
NTP, 1983; ECHA, 2011a
Repeated dose effects described in a
carcinogenicity bioassay study.
Melamine: Dog 1-year dietary toxicity
study: crystalluria started 60 to 90 days
into treatment, and persisted during the
study period. No other effects attributable
to melamine were observed.
American Cyanamid Company,
1955
Sufficient study details were not
available.
Melamine: Rat 30-month dietary toxicity
study: neither accumulation of calculi nor
any treatment-related urinary bladder
lesions were found.
Mast et al., 1982c (as cited in
EPA, 1992)
Sufficient study details were not
available.
4-447
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Rat 24- to 30-month dietary
toxicity study: a dose-related trend for
dilated glands in glandular gastric mucosa
and inflammation in non-glandular gastric
mucosa was observed. Urinary bladder
calculi formation was not observed.
American Cyanamid Company,
1983 (as cited in OECD SIDS,
1999)
Sufficient study details were not
available.
Immune System Effects
Melamine: Did not inhibit the mitogenesis
of B- and T- lymphocytes in an in vitro
mouse lymphocyte mitogenesis test.
ECHA, 2011b
Reported in a secondary source.
Skin Sensitization
LOW: Melamine polyphosphate is not expected to be a skin sensitizer based on the data for melamine.
Skin Sensitization
Melamine: No evidence of primary
dermal irritation or sensitization in a
human patch test
American Cyanamid Company,
1955; Trochimowicz et al., 2001
Limited study details reported.
Melamine: Non-sensitizing to guinea pigs
Fasset and Roudabush, 1963/1981
(as cited in OECD SIDS, 1999
and Trochimowicz et al., 2001);
Trochimowicz et al., 2001
Limited study details reported.
Respiratory Sensitization
No data located.
Respiratory Sensitization
No data located.
Eye Irritation
LOW: Melamine polyphosphate is slight
y irritating to rabbit eyes.
Eye Irritation
Melamine polyphosphate: Slightly
irritating
NOTOX B.V., 1998 (as cited in
Australia, 2006)
Limited study details reported.
Melamine polyphosphate: Slightly
irritating
Submitted confidential study
Limited study details reported.
Melamine: Non-irritating to rabbit eyes
BASF, 1969 (as cited in OECD
SIDS, 1999 and IUCLID, 2000a)
Limited study details reported.
Melamine: Non-irritating to rabbit eyes
following 0.5 mL of 10% melamine
American Cyanamid Company,
1955; Trochimowicz et al., 2001
Limited study details reported.
Melamine: Mild irritant to rabbit eyes
following exposure to 30 mg of dry
powder
American Cyanamid Company,
1955; Trochimowicz et al., 2001
Limited study details reported.
4-448
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Slightly irritating to rabbit
eyes
Marhold, 1972 (as cited in
IUCLID, 2000a and RTECS,
2009)
Limited study details reported.
Dermal Irritation
VERY LOW: Melamine polyphosphate is not a skin irritant in rabbits.
Dermal Irritation
Melamine polyphosphate: Not irritating
NOTOX B.V., 1998 (as cited in
Australia, 2006)
Limited study details reported.
Melamine polyphosphate: Not irritating
Submitted confidential study
Limited study details reported.
Melamine: Not irritating to rabbit skin
Rijcken, 1995 (as cited in OECD
SIDS, 1999)
Organisation of Economic
Cooperation and Development
(OECD) 404 guideline study
Melamine: Not irritating to rabbit skin
BASF, 1969 (as cited in OECD
SIDS, 1999 and IUCLID, 2000a)
Limited study details reported.
Melamine: Not irritating to rabbit skin
American Cyanamid Company,
1955; Trochimowicz et al., 2001
Limited study details reported.
Melamine: Not irritating to rabbit skin
Fasset and Roudabush, 1963/1981
(as cited in OECD SIDS, 1999
and Trochimowicz et al., 2001);
Trochimowicz et al., 2001
Limited study details reported.
Endocrine Activity
There were insufficient data located to describe the effect of melamine po
system. In one study, melamine did not exhibit estrogenic activity in vitro
yphosphate on the endocrine
in a yeast two-hybrid assay.
Melamine: Showed no estrogenic activity
(no change in B-galactosidase activity) in
an in vitro yeast two-hybrid assay in
Saccharomvces cerevisicte Y 190
ECHA, 2011a
Reported in a secondary source.
Nonguideline study.
Immunotoxicity
Potential for immunotoxic effects based on analogy to structurally similar polymers and professional
judgment.
Immune System Effects
Melamine: Did not inhibit the mitogenesis
of B- and T- lymphocytes in an in vitro
mouse lymphocyte mitogenesis test.
ECHA, 2011b
Reported in a secondary source.
ECOTOXICITY
ECOSAR Class
Anilines (amino-meta), Triazines
4-449
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Acute Toxicity
LOW: Melamine polyphosphate is expected to be of low hazard for acute toxicity to aquatic organisms based
on experimental data for melamine polyphosphate and melamine. For melamine, the weight of evidence
suggests that the acute values are >100 mg/L. For melamine polyphosphate, no effects were observed at the
highest concentration tested (3.0 mg/L). Melamine polyphosphate is not predicted to cause eutrophication
based on laboratory testing.
Fish LC50
Melamine polyphosphate: Freshwater
fish 96-hour LC50 =100 mg/L
(Experimental)
Ciba, 2005 (as cited in Australia,
2006)
Reported in a secondary source, study
details and test conditions were not
reported.
Melamine: Leuciscus idas melanotus 48-
hour LC50 >500 mg/L (Experimental)
OECD SIDS, 1999
Study details reported in secondary
source.
Melamine: Oryzias latipes 48-hour LC50 =
1,000 mg/L (Experimental)
OECD SIDS, 1999
Study details reported in secondary
source.
Melamine: Poecilia reticulata 96-hour
LC50 >3,000 mg/L (Experimental)
OECD SIDS, 1999
Study details reported in secondary
source.
Melamine: Poecilia reticulata 4,400 mg/L
dose lethal to <10% (Experimental)
OECD SIDS, 1999
Study details reported in secondary
source.
Melamine: Fish 96-hour LC50 = 2,680
mg/L (Estimated)
ECOSAR: Anilines (amino-meta)
ECOSAR version 1.11
Melamine: Fish 96-hour LC50 = 391 mg/L
(Estimated)
ECOSAR: Melamines
ECOSAR version 1.11
Melamine: Fish 96-hour LC50 = 14,272
mg/L (Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics) are
provided for comparative purposes;
DfE assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Daphnid LCS0
Melamine polyphosphate: Daphnia
magna 48-hour EC50 >100 mg/L
Ciba, 2005 (as cited in Australia,
2006)
Reported in a secondary source, study
details and test conditions were not
reported.
4-450
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Daphnia magna 48-hour LC50
>2,000 mg/L (Experimental)
OECD SIDS, 1999
Study details reported in secondary
source.
Melamine: Daphnid 48-hour LC50 = 6.23
mg/L (Estimated)
ECOSAR: Anilines (amino-meta)
ECOSAR version 1.11
Melamine: Daphnid 48-hour LC50 =
144.34 mg/L (Estimated)
ECOSAR: Melamines
ECOSAR version 1.11
Melamine: Daphnid 48-hour LC50 = 4,805
mg/L (Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics) are
provided for comparative purposes;
DfE assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Green Algae ECS0
Melamine polyphosphate: Selenastrum
capricorniitiim 96-hour EC50 >3.0 mg/L
(Experimental); 96-hour NOEC = 3.0
mg/L (Experimental)
Submitted confidential study
No effects observed at highest
concentration tested.
Melamine polyphosphate: Selenastrum
capricorniitiim 96-hour EC50 >3.0 mg/L
(Experimental); 96-hour NOEC = 3.0
mg/L (Experimental)
Australia, 2006
Reported in a secondary source, study
details and test conditions were not
provided; no effects observed at
highest concentration tested.
Melamine polyphosphate: In a 96-hour
control growth test (Selenastrum
capricorniitiim), melamine polyphosphate
causes increased algal growth, but growth
is 95% less than growth in standard
medium with adequate phosphorous. This
indicates that melamine polyphosphate is
not a good source of phosphorous for algal
growth and does not cause eutrophication.
(Experimental)
Submitted confidential study
Sufficient study details reported in a
confidential study.
4-451
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Green algae 96-hour EC50 =
2.79 mg/L (Estimated)
ECOSAR: Anilines (amino-meta)
ECOSAR version 1.11
Melamine: Green algae 96-hour EC50 =
325 mg/L (Estimated)
ECOSAR: Melamines
ECOSAR version 1.11
Melamine: Green algae 96-hour EC50 =
4,396 mg/L (Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics) are
provided for comparative purposes;
DfE assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Melamine: Scenedesmus pannonicus 4-
day EC50 = 940 mg/L (Experimental); 4-
day NOEC = 320 mg/L (Experimental)
OECD SIDS, 1999
Reported in a secondary source, study
details and test conditions were not
provided.
Chronic Aquatic Toxicity
LOW: Melamine polyphosphate is expected to be of low hazard for chronic toxicity to aquatic organisms
based on experimental data for melamine. For melamine, the weight of evidence suggests that the ChVs are
>10 mg/L.
Fish ChV
Melamine: Jordanella floridae 35-day
NOEC >1,000 mg/L (Experimental)
OECD SIDS, 1999
Reported in a secondary source, study
details and test conditions were not
provided.
Melamine: Sctlmo gairdneri NOEC
(macroscopic) = 500 mg/L (Experimental);
NOEC (microscopic) <125 mg/L
(Experimental)
OECD SIDS, 1999
Reported in a secondary source, study
details and test conditions were not
provided.
Melamine: Fish ChV = 263 mg/L
(Estimated)
ECOSAR: Anilines (amino-meta)
ECOSAR version 1.11
The toxicity value was estimated
through application of acute to
chronic ratios (ACRs).
Melamine: Fish ChV = 1,102 mg/L
(Estimated)
ECOSAR: Melamines
ECOSAR version 1.11
4-452
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Fish ChV = 1,076 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics) are
provided for comparative purposes;
DfE assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Daphnid ChV
Melamine: Daphnia magna 21-day LC50 =
32-56 mg/L, 21-day LCKlo = 56 mg/L,
21day NOEC = 18 mg/L (Experimental)
OECD SIDS, 1999
Reported in a secondary source, study
details and test conditions were not
provided.
Melamine: Daphnid ChV = 0.078 mg/L
(Estimated)
ECOSAR: Anilines (amino-meta)
ECOSAR version 1.11
Melamine: Daphnid ChV = 14.85 mg/L
(Estimated)
ECOSAR: Melamines
ECOSAR version 1.11
The toxicity value was estimated
through application of ACRs.
Melamine: Daphnid ChV = 343.93 mg/L
(Estimated)
ECOSAR class: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics) are
provided for comparative purposes;
DfE assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Green Algae ChV
Melamine: Green algae ChV = 0.70 mg/L
(Estimated)
ECOSAR: Anilines (amino-meta)
ECOSAR version 1.11
The toxicity value was estimated
through application of ACRs.
Melamine: Green algae ChV = 81.26
mg/L
(Estimated)
ECOSAR: Melamines
ECOSAR version 1.11
4-453
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: Green algae ChV = 313.17
mg/L (Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics) are
provided for comparative purposes;
DfE assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
ENVIRONMENTAL FATE
Transport
Melamine polyphosphate has a high measured water solubility of 20 g/L and its Henry's Law Constant and
vapor pressure are below cutoff values. It is expected to partition predominately to water and soil. It may
migrate from soil into groundwater. As a salt, volatilization from either wet or dry surfaces is not expected to
be an important fate process.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
EPI; Professional judgment
Cutoff value for nonvolatile
compounds.
Sediment/Soil Adsorption/
Desorption
Coefficient - Koc
Melamine polyphosphate: 13
(Estimated)
EPI
Level III Fugacity Model
Melamine polyphosphate:
Air = 0%
Water = 37%
Soil = 63%
Sediment = 0% (Estimated)
EPI
4-454
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Persistence
HIGH: Melamine polyphosphate is expected to show high persistence in the environment based on the data
for melamine, which is expected to be fully dissociated under environmental conditions. The weight of
evidence suggests that melamine will biodegrade, at rates consistent with a High hazard designation.
Although pure culture studies showed evidence of biodegradation by enzymatic hydrolytic deamination in
less than 10 days, an original MITI test detected less than 30% degradation after 14 days and two separate
guideline OECD 302B studies observed no degradation after 28 days and 16% degradation after 20 days.
This results in an expected environmental persistence half-life between 60 and 180 days. Degradation of
melamine or its cation by hydrolysis or direct photolysis is not expected to be significant as the functional
groups present on this molecule do not tend to undergo these reactions under environmental conditions.
Polyphosphoric acid is expected to have low persistence in the environment. The weight of evidence suggests
that polyphosphoric acid will hydrolyze under environmental conditions. The phosphates formed are
expected to participate in natural cycles and be readily assimilated.
Water
Aerobic Biodegradation
Melamine polyphosphate:
Weeks (Primary survey model)
Months (Ultimate survey model)
(Estimated)
EPI
Melamine: 16% removal after 20 days
with activated sludge, 14% removal after
10 days with adapted sludge (Measured)
OECD SIDS, 1999
These values are for the dissociated
component, melamine. Reported in a
secondary source, study details and
test conditions were not provided.
Melamine: 0% removal after 28 days with
activated sludge (Measured)
OECD SIDS, 1999
Melamine: 0% removal after 14 days with
activated sludge (Measured)
OECD SIDS, 1999
Melamine: <30% removal after 14 days
with activated sludge (Measured)
OECD SIDS, 1999
Melamine: <1% removal after 5 days with
an adapted inoculum (Measured)
IUCLID, 2000a
Melamine: 0% removal after 14 days with
activated sludge (Measured)
IUCLID, 2000a
Melamine: <30% removal after 14 days
with activated sludge (Measured)
IUCLID, 2000a
4-455
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Melamine: <20% removal after 20 days,
14% removal after 10 days with adapted
inoculum (Measured)
IUCLID, 2000a
Study results: 100%/<10 days
Test method: Other: Pure culture study
Bacterium, Nocctrdioides sp. strain ATD6
rapidly degraded melamine and
accumulated cyanuric acid and
ammonium, via the intermediates
ammeline and ammelide. (Measured)
Takagi et al., 2012
Melamine degradation was found to
occur in species specific
biodegradation studies.
Volatilization Half-life for
Model River
Melamine polyphosphate: >1 year
(Estimated)
EPI
Based on the magnitude of the
estimated Henry's Law Constant.
Volatilization Half-life for
Model Lake
Melamine polyphosphate: >1 year
(Estimated)
EPI
Based on the magnitude of the
estimated Henry's Law Constant.
Soil
Aerobic Biodegradation
Melamine: Not readily biodegradable: 0%
biodegradation detected after 2 weeks with
100 ppm in 30 ppm activated sludge
(OECD TG 301C) (Measured); 0%
degradation after 28 days with 100 mg
DOC/L in activated sludge (Zahn-Wellens
test, OECD 302B) (Measured)
MITI, 1998; OECD SIDS, 1999
Adequate values from guideline
studies for the dissociated
component, melamine.
Study results: 100%/4 days
Test method: Other: Pure culture study
Bacterium, A. citriilli strain B-12227
rapidly degraded melamine and
accumulated cyanuric acid, ammeline and
ammelide, via the intermediates ammeline
and ammelide. (Measured)
Shiomi and Ako, 2012
Melamine degradation was found to
occur in species specific
biodegradation studies.
4-456
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
A set of soil bacteria has been identified
whose members rapidly metabolize
melamine as their source of nitrogen to
support growth; these bacteria contain an
enzyme which hydrolytically deaminate
melamine (Measured)
Cook and Hutter, 1984; Cook and
Hutter, 1981
Melamine degradation was found to
occur in species specific
biodegradation studies.
Anaerobic Biodegradation
Melamine: 0-8.9% nitrification was
observed after 28 days incubation with
bacteria in Webster silty clay loam under
anaerobic conditions (Measured)
IUCLID, 2000a
This value is for the dissociated
component, melamine. Reported in a
secondary source, study details and
test conditions were not provided.
Soil Biodegradation w/
Product Identification
Melamine: Nitrification of melamine
occurs in soil at a low rate (0.7% organic
N found as N03-N in week 10, and 0% in
week 28). (Measured)
ECHA, 2011a, 2011b
Nonguideline studies for the
dissociated component, melamine.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
Melamine polyphosphate: 21 days
(Estimated)
EPI
Reactivity
Photolysis
Melamine polyphosphate: Not a
significant fate process (Estimated)
Mill, 2000; Professional
judgment
The substance does not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
Hydrolysis
Polyphosphoric acid: The half-life for the
hydrolysis to phosphoric acid is several
days at 25 °C (Measured)
Kirk-Othmer, 2005
This value is for the dissociated
component, polyphosphoric acid.
These studies indicate
polyphosphoric acid would undergo
hydrolysis under environmental
conditions to phosphate ions.
Reported in a secondary source, study
details and test conditions were not
provided.
4-457
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Polyphosphoric acid: Hydrolysis occurs
in 2 months at 20°C (Measured)
IUCLID, 2000b
This value is for the dissociated
component, polyphosphoric acid.
Reported in a secondary source, study
details and test conditions were not
provided available.
Environmental Half-life
Melamine polyphosphate: 120 days
(Estimated)
EPI; PBT Profiler
Half-life estimated for the
predominant compartment, as
determined by EPI and the PBT
Profiler methodology.
Bioaccumulation
LOW: Based on the relatively high water solubility of melamine polyphosphate (20 g/L) and an estimated
BCF of 3.2. In addition, the experimental bioconcentration values for the melamine component are low, BCF
<3.8, and estimated BAF <1.
Fish BCF
Melamine polyphosphate: 3.2
(Estimated)
EPI
Melamine: <0.38 in carp (Cyprinus
carpio) after 6 weeks at 2.0 ppm
concentration;
<3.8 in carp (Cyprinus carpio) after 6
weeks at 0.2 ppm concentration (OECD
302B) (Measured)
MITI, 1998
Adequate values from guideline
studies for the dissociated
component, melamine.
BAF
Melamine polyphosphate: 0.9
(Estimated)
EPI
Melamine: <1 (Measured)
OECD SIDS, 1999; IUCLID,
2000a
This value is for the dissociated
component, melamine.
Metabolism in Fish
Melamine: Uptake, bioaccumulation and
elimination study with 14C-melamine in
fathead minnow and rainbow trout: BCFs
<1 (Measured)
ECHA, 2011a, 2011b
Nonguideline studies that support the
low potential for bioaccumulation of
this substance.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
4-458
-------
Melamine Polyphosphate CASRN 15541-60-3
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-459
-------
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4-466
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N-alkoxy Hindered Amine Reaction Products
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
1 The highest hazard designation of any of the oligomers with MW <1,000
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
N-alkoxy Hindered Amine Reaction
Products
191680-81-6
L
M
L
H
H
L
H
L
L
VL
H
H
H
H*
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-467
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N-alkoxy Hindered Amine Reaction Products
N^N
Cr°
Representative Structure
CASRN: 191680-81-6
MW: >1,300 (92%);
670-1,300 (3%);
<670 (5%)
MF:
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: N4C(N(CCNCCCN)CCCN)=NC(N(C2CC(C)(C)N(0C3CCCCC3)C(C)(C)C2)CCCC)=NC=4N(C1CC(C)(C)NC(C)(C)C1)CCCC (Representative
Structure)
Synonyms: 1,3-Propanediamine, Nl,Nl'-l,2-ethanediylbis-, reaction products with cyclohexane and peroxidized N-butyl-2,2,6,6-tetramethyl-4-piperidinamine-2,4,6-
trichloro-l,3,5-triazine reaction products; Flamestab Nor 116
Chemical Considerations: This alternative is a polymer. The structure shown is the simplest depiction of an oligomer with a MW <1,000 (approximately 770) that
includes all combinations of monomers. This review assesses oligomers with a MW <1,000 using a representative structure. The representative structure lies within
the domain of the available estimation methods. EPI v4.0 estimation methods were used for physical/chemical and environmental fate values in the absence of
experimental data. The higher MW oligomers with a MW >1,000 are assessed together using information contained in the literature concerning polymer assessment
and professional judgment (Boethling et al., 1997).
4-468
-------
Polymeric: Yes
Oligomers: The MF and MW of this polymer are variable; approximately 90% of the oligomers in this polymer have a MW >1,300 (NICNAS, 2001). The mixture is
based on a substituted aliphatic tetra amine, where the substituents on the amine groups are variable. The presence of material in the commercial product with a MW
<670 is likely the result of unchanged starting materials.
Metabolites, Degradates and Transformation Products: None
Analog: No analog
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: Hindered amines (EPA, 2010)
Risk Phrases: Not classified by Annex VI Regulation (European Commission) No 1272/2008 (ESIS, 2011).
Hazard and Risk Assessments: This polymer has been assessed by NICNAS (NICNAS, 2001).
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N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
113-121 softening point
(Measured)
Ciba Additives, 1997a
Value is a result from differential
scanning calorimetry analysis on the
commercial product, with a reported
endotherm trough at 120.43°C. The
value of 113°C likely corresponds to
a softening point for the polymer.
Boiling Point (°C)
Decomposes (Measured)
Ciba Additives, 1997b
The commercial product was found to
decompose without boiling at 260°C
at a reduced pressure of 6 kPa.
>300 (Estimated)
EPI; EPA, 1999
Estimate based on a representative
oligomer with a MW <1,000 that
includes all monomers. Cutoff value
according to High Production
Volume (HPV) assessment guidance.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
EPI; EPA, 1999
Estimate based on a representative
oligomer with a MW <1,000 that
includes all monomers. Cutoff value
according to HPV polymer
assessment guidance.
Water Solubility (mg/L)
<10"3 (Estimated)
EPI; EPA, 1999
Estimate based on a representative
oligomer with a MW <1,000 that
includes all monomers. Cutoff value
according to HPV assessment
guidance.
Log Kow
10 (Estimated)
EPI; EPA, 1999
Estimate based on a representative
oligomer with a MW <1,000 that
includes all monomers. Estimated
value is greater than the cutoff value,
>10, according to methodology based
on HPV assessment guidance.
4-470
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Flammability (Flash Point)
>110°C (Measured)
NICNAS, 2001
Sufficient details were not available
to assess the quality of this study.
Explosivity
Not explosive
European Economic Community method
A. 14 (Measured)
NICNAS, 2001
Adequate; guideline study.
Pyrolysis
No data located.
pH
No data located.
pKa
2.4 to 10.2 (Estimated)
NICNAS, 2001
Inadequate. Compound only contains
basic functional groups.
HUMAN HEALTH EFF
ECTS
Toxicokinetics
As a neat material, N-alkoxy hindered amine reaction products is estimated to not be absorbed by any route
of exposure. This compound is expected to have poor absorption through all routes when in solution. This
material is predominately a polymer with a MW >1,000 however at present there is no MW cutoff for the
hindered amine category of new chemicals (EPA, 2010b ).
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
Not absorbed by any route as a neat
material; poor absorption for all routes
when in solution
Professional judgment
Based on closely related
confidential analogs with similar
structures, functional groups, and
physical/chemical properties.
Acute Mammalian Toxicity
LOW: Based on an acute oral LDS0 >5,000 mg/kg and an acute dermal L
);o >2,000 mg/kg for rats.
Acute Lethality
Oral
Rat Oral LD50 >5,000 mg/kg bw
NICNAS, 2001
Reported in a secondary source.
Guideline study
(Organisation of Economic
Cooperation and Development
(OECD) 401, limit test).
Dermal
Rat Dermal LD50 >2,000 mg/kg bw
NICNAS, 2001
Reported in a secondary source.
Guideline study
(OECD 402, limit test).
Inhalation
No data located.
Carcinogenicity
MODERATE: There is uncertainty due to lack of data for this substance. EPA does not expect this
substance to be carcinogenic however such effects cannot be ruled out.
4-471
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
OncoLogic Results
This polymer is not amenable to
available estimation methods.
Carcinogenicity (Rat
and Mouse)
No data located.
Combined Chronic
Toxicity/
Carcinogenicity
No data located.
Genotoxicity
LOW: N-alkoxy hindered amine reaction products did not induce gene mutations in Salmonella
typhimurium or Escherichia coli and did not induce chromosomal aberrations in Chinese hamster ovary
(CHO) cells in the presence and absence of metabolic activation.
Gene Mutation in vitro
Negative for gene mutations in
Salmonella typhimurium strains TA1535,
TA1537, TA98, TA100 and E. coli strain
WP2uvrA with and without metabolic
activation.
NICNAS, 2001
Reported in a secondary source.
Guideline study (OECD 471,
bacterial reverse mutation test).
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
Negative for chromosomal aberrations in
CHO cells with and without metabolic
activation. No evidence of
clastogenicity.
NICNAS, 2001
Reported in a secondary source.
Guideline study (OECD 473, in
vitro mammalian chromosomal
aberration test).
Chromosomal
Aberrations in vivo
No data located.
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
4-472
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproductive Effects
HIGH: Estimated potential for reproductive effects based on analogy to other hindered amines similar in
structure.
Reproduction/
Developmental Toxicity
Screen
No data located.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
Reproduction and
Fertility Effects
Toxicity to male reproductive system
(Estimated by analogy)
Professional judgment, Toxic
Substances Control Act (TSCA)
New Chemicals Program -
Chemical Categories
Estimated based on analogy to
hindered amines similar in
structure.
Developmental Effects
HIGH: Estimated potential for developmental effects based on analogy to other hindered amines similar in
structure.
Reproduction/
Developmental Toxicity
Screen
Delayed skeletal maturation
LOAEL = 1,200 mg/kg/day
(Estimated by analogy)
Professional judgment
Estimated based on analogy to
hindered amines similar in
structure.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
Prenatal Development
No data located.
Postnatal Development
No data located.
Neurotoxicity
LOW: Estimated not to have potential for neurotoxicity based on expert judgment. No data located.
Neurotoxicity Screening
Battery (Adult)
No potential for neurotoxicity
(Estimated)
Expert judgment
Estimated based on expert
judgment.
4-473
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Repeated Dose Effects
HIGH: Estimated potential for repeated dose effects based on analogy to other hindered amines similar in
structure. Experimental data reported that N-alkoxy hindered amine reaction products did not produce
adverse effects in a 28-day oral gavage study in rats at oral doses up to 1,000 mg/kg/day; however
uncertainty remains for exposures of longer duration.
Toxicity to liver, blood, and
gastrointestinal tract
(Estimated by analogy)
Professional judgment, TSCA
New Chemicals Program -
Chemical Categories
Estimated based on analogy
hindered amines similar in
structure.
2 8-day oral gavage study in Sprague-
Dawley rats. No treatment-related
clinical effects or changes in clinical
chemistry, hematology, urinalysis or
organ weight.
NOAEL = 1,000 mg/kg/day
LOAEL = not established as highest
dose tested did not produce adverse
effects
NICNAS, 2001
Reported in a secondary source.
Guideline study (OECD 407). The
hindered amines category suggests
need for a 90-day oral test.
Immune System Effects
Effects on thymus, spleen, lymph and
nodes
(Estimated by analogy)
Professional judgment, TSCA
New Chemicals Program -
Chemical Categories
Estimated based on analogy
hindered amines similar in
structure.
Skin Sensitization
LOW: N-alkoxy hindered amine reaction products did not produce skin sensitization in an experimental
study in guinea pigs.
Skin Sensitization
No evidence of sensitization, guinea pig
NICNAS, 2001
Reported in a secondary source.
Guideline study (OECD 406).
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
LOW: N-alkoxy hindered amine reaction products are slightly irritating to rabbit eyes with clearing within
24 hours.
Eye Irritation
Slightly irritating, rabbit.
Most symptoms cleared in 24 hours or
less. Redness persisted for 48 hours.
NICNAS, 2001
Reported in a secondary source.
Guideline study (OECD 405, acute
eye irritation/corrosion).
4-474
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Dermal Irritation
VERY LOW: N-alkoxy hindered amine reaction products are not irritating to rabbit skin.
Dermal Irritation
Non-irritating, rabbit
NICNAS, 2001
Reported in a secondary source.
Guideline study (OECD 404, acute
dermal irritation/corrosion).
Endocrine Activity
No data located.
No data located.
Immunotoxicity
Estimated potential for immunotoxic effects based on analogy to other hindered amines similar in structure.
Immune System Effects
Effects on thymus, spleen, lymph and
nodes
(Estimated by analogy)
Professional judgment, TSCA
New Chemicals Program -
Chemical Categories
Estimated based on analogy
hindered amines similar in
structure.
ECOTOXICITY
ECOSAR Class
Polycationic Polymers; Aliphatic Amines; Triazines
Acute Toxicity
HIGH: Based on estimated acute aquatic toxicity values for fish, daphnid, and green algae using
polycationic polymer SAR.
Fish LC50
Pimephcdes promelas 96-hour LC5n
>0.268 mg/L, NOEC = 0.268 mg/L (48-
hour static-renewal, mean measured)
(OECD TG 203) (Experimental)
NICNAS, 2001
Reported in a secondary source.
Guideline study; reported values are
greater than the water solubility; no
effects at saturation (NES) were
observed for this endpoint.
Fish 96-hour LC50 = 0.280 mg/L
(Estimated)
Professional judgment
Predictions based on SARs for
polycationic polymers with >3.5%
amine-N.
Fish 96-hour LC50 = 0.0015 mg/L
(Estimated)
ECOSAR: Aliphatic amines
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log Kow of 10 for this chemical
exceeds the SAR limitation of 6.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
4-475
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish 96-hour LC50 = 3.28 xlO"8 mg/L
(Estimated)
ECOSAR: Triazines
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 5.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
Fish 96-hour LC50 = 6.56 xlO"5 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 5.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Daphnid LCS0
Daphnia 48-hour EC50 >0.312 mg/L,
NOEC = 0.312 mg/L (24- hour static-
renewal, mean measured) (OECD TG
202) (Experimental)
NICNAS, 2001
Reported in a secondary source.
Guideline study; reported values are
greater than the water solubility;
NES were observed for this
endpoint.
4-476
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid 48-hour LC50 = 0.1 mg/L
(Estimated)
Professional judgment
Predictions based on SARs for
polycationic polymers with >3.5%
amine-N.
Daphnid 48-hour LC50 = 0.000846 mg/L
(Estimated)
ECOSAR: Aliphatic amines
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 5.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
Daphnid 48-hour LC50 = 1.05 xlO"5 mg/L
(Estimated)
ECOSAR: Triazines
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log Kow of 10 for this chemical
exceeds the SAR limitation of 5.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
4-477
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid 48-hour LC50 = 1.05xl0~5 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 5.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Green Algae ECS0
Green Algae (Pseiidokirchneriella
subcapitata) 72-hour EbC5n
>0.083 mg/L, NOEC = 0.083 mg/L
(static, measured at study termination)
(OECD TG 201) (Experimental)
NICNAS, 2001
Reported in a secondary source.
Guideline study; reported values are
greater than the water solubility;
NES were observed for this
endpoint.
Green algae 96-hour EC50 = 0.04 mg/L
(Estimated)
Professional judgment
Predictions based on SARs for
polycationic polymers with >3.5%
amine-N.
4-478
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae 96-hour LC50 = 0.005 mg/L
(Estimated)
ECOSAR: Aliphatic amines
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 7.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
Green algae 96-hour LC50 = 0.000657
mg/L
(Estimated)
ECOSAR: Triazines
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 6.4;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
4-479
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae 96-hour LC50 = 1.05xl0~5
mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 6.4;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Chronic Aquatic Toxicity
HIGH: Based on estimated chronic aquatic toxicity values for fish, daphnid, and green algae using
polycationic polymer SARs.
Fish ChV
Fish ChV = 0.016 mg/L
(Estimated)
Professional judgment
Predictions based on SARs for
polycationic polymers with >3.5%
amine-N.
ChV = 5.3lxlO-5 mg/L
(Estimated)
ECOSAR: Aliphatic amines
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log Kow of 10 for this chemical
exceeds the structure activity
relationship (SAR) limitation of
8.0; NES are predicted for these
endpoints. The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
4-480
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish ChV = 5.19xl0"6 mg/L
(Estimated)
ECOSAR: Triazines
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 8.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
Fish ChV = 5.19xl0"6 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 8.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
4-481
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid ChV
ChV = 0.014 mg/L
(Estimated)
ECOSAR: Aliphatic amines
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 8.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
ChV = 4.67xl0"5 mg/L
(Estimated)
ECOSAR: Triazines
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 8.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
4-482
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ChV = 4.04x10 xlO"5
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 8.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
ChV = 0.007 mg/L
(Estimated)
Professional judgment
Predictions based on SARs for
polycationic polymers with >3.5%
amine-N.
Saltwater Invertebrate ChV
ChV = 0.014 mg/L
(Estimated)
ECOSAR: Aliphatic amines
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 8.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
4-483
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green Algae ChV
ChV = 0.000234 mg/L
(Estimated)
ECOSAR: Aliphatic amines
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 7.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
ChV = 0.002 mg/L
(Estimated)
ECOSAR: Triazines
ECOSAR version 1.11
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 7.0;
NES are predicted for these
endpoints. The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
4-484
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ChV = 0.002 mg/L
(Estimated)
ECOSAR: Neutral organics
NES: Estimate based on a
representative oligomer with a MW
<1,000 that includes all monomers.
The log K0„ of 10 for this chemical
exceeds the SAR limitation of 8.0;
NES are predicted for these
endpoints The higher oligomers
outside the domain of the estimation
method are anticipated to display
NES.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
ChV = 0.02 mg/L
(Estimated)
Professional judgment
Predictions based on SARs for
polycationic polymers with >3.5%
amine-N.
ENVIRONMENTAL FATE
Transport
Based on the Level III fugacity models incorporating the available property data, N-alkoxy hindered amine
reaction products are expected to partition primarily to soil and sediment. This compound is expected to be
immobile in soil based on its estimated Koc. Leaching of N-alkoxy hindered amine reaction products through
soil to groundwater is not expected to be an important transport mechanism. Estimated volatilization half-
lives indicate that it will be non-volatile from surface water. Volatilization from dry surface is also not
expected based on its vapor pressure. In the atmosphere, this compound is expected to exist solely in the
particulate phase, based on its estimated vapor pressure. Particulates may be removed from air by wet or dry
deposition.
4-485
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
EPI; Professional judgment
Estimate based on a representative
oligomer with a MW <1,000 that
includes all monomers. Cutoff value
for nonvolatile compounds.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
EPI; EPA, 2004
Estimate based on a representative
oligomer with a MW <1,000 that
includes all monomers. Cutoff value
for non-mobile compounds.
Level III Fugacity Model
Air: <1% (Estimated)
Water: <1%
Soil = 53%
Sediment = 47%
EPI
Estimate based on a representative
oligomer with a MW <1,000 that
includes all monomers.
Persistence
HIGH: The persistence for N-alkoxy hindered amine reaction products is based on an experimental guideline
biodegradation study (4% removal after 28 days). Although a biodegradation half-life was not calculated
based on this study, it indicates that biodegradation of N-alkoxy hindered amine reaction products is possible
under the stringent test conditions. Approximately 90% of the commercial N-alkoxy hindered amine
reaction products substance has a MW >1,300 and is not anticipated to be assimilated by microorganisms.
This polymer is not expected to be removed by other degradative processes under environmental conditions,
such as hydrolysis, since it lacks the functional groups that hydrolyze under environmental conditions. This
polymer does not contain chromophores that absorb at wavelengths >290 nm, and therefore it is not expected
to be susceptible to direct photolysis by sunlight. The atmospheric half-life is estimated to be 19 minutes,
although it is expected to exist primarily in the particulate phase in air.
Water
Aerobic Biodegradation
Ready Test: Modified Sturm Test (OECD
TG 30IB); 4.37% biodegradation detected
after 28 days in sewage sludge (Measured)
Toxicon, 1997
Adequate, guideline study.
Volatilization Half-life for
Model River
>1 year (Estimated)
EPI
Volatilization Half-life for
Model Lake
>1 year (Estimated)
EPI
Soil
Aerobic Biodegradation
No data located.
4-486
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Anaerobic
Biodegradation
Not probable (Anaerobic-methanogenic
biodegradation probability model)
(Estimated)
EPI
Estimate based on a representative
oligomer with a MW <1,000 that
includes all monomers.
Soil Biodegradation with
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
19 minutes (Estimated)
EPI
Estimate based on a representative
oligomer with a MW <1,000 that
includes all monomers.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Mill, 2000; Professional
judgment
The substance does not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
Hydrolysis
Not a significant fate process (Estimated)
Wolfe and Jeffers, 2000;
Professional judgment
The substance does not contain
functional groups that would be
expected to hydrolyze readily under
environmental conditions.
Environmental Half-Life
>180 days (Estimated)
EPI; PBT Profiler
Half-life estimated for the
predominant compartment, as
determined by EPI and the PBT
Profiler methodology, for a
representative oligomer with a MW
<1,000.
Bioaccumulation
HIGH: A representative oligomer (with MW 770) that includes all combinations of monomers has an
estimated BAF of 2,300; this BAF value, which accounts for metabolism, suggests that this substance has
potential to bioaccumulate in higher trophic levels.
Fish BCF
27 (Estimated)
EPI
Estimate based on a representative
oligomer with a MW <1,000 that
includes all monomers.
4-487
-------
N-alkoxy Hindered Amine Reaction Products CASRN 191680-81-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
BAF
2,300 (Estimated)
EPI
Estimate based on a representative
oligomer with a MW <1,000 that
includes all monomers.
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-488
-------
Boethling, Robert S. and Nabholz, J. Vincent "Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act",
pp. 187-234, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs, Hamilton, John D.
and Sutcliffe, Roger (eds.), (1997) Van Nostrand Reinhold.
Ciba Additives. Thermal Analysis Report of CGL-116\ Ciba Additives Analytical Research Department, Tarrytown NY USA. 1997a.
Ciba Additives. Characterisation of CGL-116\ Ciba Additives Analytical Research Department, Tarrytown NY USA. 1997b.
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
May 10, 2011).
[HPV Assessment Guidance] EPA (U.S. Environmental Protection Agency). Determining the Adequacy of Existing Data. U.S.
Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadeqfn.pdf
ECOSAR/EPI (EPIWIN/EPISUITE) Estimations Programs Interface for Windows, Version 1.11. U.S. Environmental Protection
Agency: Washington D.C. http://www.epa.gov/opptintr/exposure/.
EPA (U.S. Environmental Protection Agency). TSCANew Chemicals Program (NCP) Chemical Categories. U.S. Environmental
Protection Agency: Washington D.C. 2010. http://www.epa.gov/oppt/newchems/pubs/npcchemicalcategories.pdf (accessed on Sept. 8,
2011).
EPI (EPIWIN/EPISUITE) Estimation Program Interface for Windows, Version 4.0. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
ESIS (European chemical Substances Information System) Classification, labeling and packaging of dangerous substances annex VI
to Regulation (EC) No 1272/2008 [Online] http://ecb.irc.ec.europa.eu/esis/index.php?PGM=cla (accessed on May 10, 2011).
Mill, T. (2000) Photoreactions in Surface Waters. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for
Chemicals, Environmental Health Sciences (355-382). Boca Raton: Lewis Publishers.
4-489
-------
NICNAS NA/999 (National Industrial Chemicals Notification and Assessment Scheme). 1,3-Propanediamine, N,N"-1,2-
ethanediylbis- reaction products with cyclohexane andperoxidized N-bntyl-2,2,6,6-tetramethyl-4-piperidinamine-2,4,6-trichloro-
1,3,5-triazine reaction products (Flamestab NOR 116FF/TKA 45009). File No. NA/869. 2001.
PBT Profi 1 er Persistent (P), Bioaccamidative (B), and Toxic (T) Chemical (PBT)Profiler, U.S. Environmental Protection Agency:
Washington D.C. www.pbtprofiler.net.
Toxicon. TKA 45009: "Ready" Biodegradability: Carbon Dioxide Evolution Test (Modified Sturm Test), Toxicon Project J9703009e;
Toxicon Environmental Sciences, 106 Coastal Way, Jupiter, Florida US. 1997.
Wolfe, N; Jeffers, P. (2000) Hydrolysis. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for Chemicals,
Environmental Health Sciences (311-334). Boca Raton: Lewis Publishers.
4-490
-------
Phosphonate Oligomer
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard I = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , I, and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
§ Based on analogy to experimental data for a structurally similar compound.
1 The highest hazard designation of any of the oligomers with MW <1,000.
v Phosphonate Oligomer, with a MW range of 1,000 to 5,000, may contain significant amounts of an impurity, depending on the final product preparation. This impurity has hazard
designations that differ from the polymeric flame retardant, as follows: MODERATE (experimental) designation for carcinogenicity, reproductive and repeated dose toxicity,
skin sensitization, eye and dermal irritation; and HIGH (experimental) designation for developmental toxicity and acute & chronic aquatic toxicity.
Chemical
CASRN
Human Health Effects
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Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-491
-------
Phosphonate Oligomer
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Representative Structure
CASRN: 68664-06-2
MW: 1,000-5,000; 25% MW <1,000
MF: C15H1602(C16H1703P)„
C31H33O5P (n =1);
C47H50OSP2 (n =2)
Physical Forms: Solid
Use: Flame retardant
SMILES: The polymer components with MW >1,000 are not amenable to SMILES notation.
Phosphonate Oligomer: cl(0)ccc(C(C)(C)c2ccc(0P(C)(=0)0c3ccccc3)cc2)ccl (n=0; MW = 382);
cl(0)ccc(C(C)(C)c2ccc(0P(C)(=0)0c3ccc(C(C)(C)c4ccc(0)cc4)cc3)cc2)ccl (representative structure for n = 1; MW = 516);
cl(0)ccc(C(C)(C)c2ccc(0P(C)(=0)0c3ccc(C(C)(C)c4ccc(0P(C)(=0)0c5ccc(C(C)(C)c6ccc(0)cc6)cc5)cc4)cc3)cc2)ccl (representative structure for n = 2, MW =
805); impurity: confidential SMILES.
Synonyms: Nofia® oligomers; FRX Oligomers (phosphonate oligomers); Phosphonic acid, P-methyl-, diphenyl ester, polymer with 4,4'-(l-
methylethylidene)bis[phenol] (not a copolymer)
Chemical Considerations: This alternative is a polymer consisting of a large portion of higher (>1,000) MW oligomers and a smaller portion of lower (<1,000) MW
oligomers. The higher MW oligomers, with a MW >1,000, are assessed together using information contained in the literature concerning polymer assessment and
professional judgment (Boethling et al., 1997).The n=l and n=2 oligomers are those with a MW <1,000 and are assessed with EPI v4.1 due to an absence of
experimental physical/chemical, environmental fate and aquatic toxicity values. Multiple n=l and n=2 oligomer structures are possible from various starting material
combinations. A representative structure was selected for determining the estimated n=l and n=2 values, as identified in the SMILES section above. The human
health designations for the lower MW oligomers are a result of identified structural alerts and experimental data from analogous compounds. Additionally, a
confidential impurity may be present in polymer. The overall hazard designation for each endpoint represents the most conservative value of the higher MW
oligomers and lower MW oligomers. A summary of the hazards of the confidential impurity is provided in hazard summary table as a footnote (¥).
4-492
-------
Polymeric: Yes
Oligomers: The polymers are produced from the trans-esterification of methyldiphenylphosphonate and bisphenol A. The MW of Phosphonate Oligomer ranges
between 1,000 and 5,000. Oligomers with MW <1,000 are expected to be present in 25% of the Phosphonate Oligomer formulation.
Metabolites, Degradates and Transformation Products: None
Analog: BAPP (181028-79-5)
Endpoint(s) using analog values: Genotoxicity; skin sensitization; repeated dose
Analog Structure:
BAPP (181028-79-5)
Structural Alerts: Phenols, neurotoxicity (EPA, 2010).
Risk Phrases: Not classified by Annex VI Regulation (EC) No 1272/2008 (ESIS, 2011).
Hazard and Risk Assessments: None identified.
4-493
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
90 softening point (Measured)
FRX Polymers, Inc., 2009
The value corresponds to a softening
point for the polymer.
Boiling Point (°C)
>300 (Estimated for n >3 oligomers)
Professional judgment
Cutoff value used for large, high MW
solid.
>300 (Estimated for n=l; n=2 oligomers)
EPI; EPA, 1999
Cutoff value for high boiling point
compounds according to High
Production Volume (HPV)
assessment guidance.
Vapor Pressure (mm Hg)
<10"8 (Estimated for n >3 oligomers)
Professional judgment; Boethling
et al., 1997
Cutoff value for large, high MW
polymers.
<10"8 (Estimated for n=l; n=2 oligomers)
EPI; EPA, 1999
Cutoff value for nonvolatile
compounds according to HPV
assessment guidance.
Water Solubility (mg/L)
<10° (Estimated for n >3 oligomers)
Professional judgment; Boethling
et al., 1997
Cutoff value for large, high MW non-
ionic polymers.
0.0015 (Estimated for n=l)
EPI
<10° (Estimated for n=2)
EPI; EPA, 1999
Cutoff value for non soluble
compounds according to HPV
assessment guidance.
Log Kow
No data located for n >3 oligomers
Professional judgment
This polymer is not amenable to
available estimation methods.
7.2 (Estimated for n=l)
EPI
11 (Estimated for n=2)
EPI; EPA, 1999
Estimated value is greater than the
cutoff value, >10, according to
methodology based on HPV
assessment guidance.
Flammability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
4-494
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Pyrolysis
No data located.
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
HUMAN HEALTH EFF
ECTS
Toxicokinetics
No absorption is expected for any route of exposure for the neat material of Phosphonate Oligomer. The
lower MW fraction, in solution, is predicted to have poor absorption for all routes. The higher MW
oligomers are large, with a MW >1,000. Based on professional judgment, Phosphonate Oligomer is
expected to have limited bioavailability and therefore is not expected to be readily absorbed, distributed or
metabolized in the body.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
No absorption of Phosphonate Oligomer
is expected for any route; poor
absorption of the low MW fraction when
in solution is expected for all routes.
(Estimated)
Professional judgment
Estimated based on
physical/chemical properties and
limited bioavailability.
Acute Mammalian Toxicity
LOW: Based on experimental LDS0 values of >2,000 mg/kg. The majority of this polymer consists of high
MW oligomers. Thus, this compound is also expected to have limited bioavailability and therefore has low
potential for acute mammalian toxicity.
Oral
Rat oral LD50 >2,000 mg/kg
FRX Polymers, Inc., 2010
Conducted according to
Organisation of Economic
Cooperation and Development
(OECD) 420; test substance: FRX
oligophosphonate.
Dermal
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff value for large,
high MW non-ionic polymers.
Inhalation
4-495
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Carcinogenicity
MODERATE: There is uncertainty for Phosphonate Oligomer due to the lack of data for this substance.
Carcinogenic effects cannot be ruled out.
OncoLogic Results
This polymer is not amenable to
available estimation methods.
Carcinogenicity (Rat
and Mouse)
No data located.
Combined Chronic
Toxicity/
Carcinogenicity
No data located.
Genotoxicity
LOW: Estimated for Phosphonate Oligomer based on analogy to BAPP i
181028-79-5).
Gene Mutation in vitro
Limited bioavailability expected for the
high MW (>1,000) components.
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on polymer assessment
literature.
Negative, Ames assay (standard plate) in
Salmonella typhimurium strains TA98,
TA100, TA1537, TA1535, and E. coli
WP2uvrA with and without metabolic
activation. (Estimated by analogy)
NICNAS NA/869, 2000;
Professional judgment
Based on analogy to BAPP;
Sufficient study details were
reported in a secondary source;
used OECD test guidelines (OECD
471 & 472). Data are for
commercial mixture of BAPP.
Negative, Ames assay (standard plate) in
Salmonella typhimurium strains TA98,
TA100, TA 1537, TA 1535, and E. coli
WP2uvrA with and without metabolic
activation. (Estimated by analogy)
NICNAS NA/773, 2000;
Professional judgment
Based on analogy to BAPP.
Sufficient study details were
reported in a secondary source;
used OECD test guidelines (OECD
471 & 472). Data are for the
predominant component of BAPP.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
Negative for chromosome aberrations in
Chinese hamster lung (CHL)/IU cells
with and without metabolic activation.
FRX Polymers, Inc, 201 lc
Conducted in compliance with
good laboratory practice.
4-496
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Negative, did not produce chromosomal
aberrations in CHO cells with and
without metabolic activation. (Estimated
by analogy)
NICNAS NA/869, 2000;
Professional judgment
Based on analogy to BAPP.
Sufficient study details were
reported in a secondary source;
used OECD test guidelines (OECD
473). Data are for commercial
mixture of BAPP.
Negative, did not produce chromosomal
aberrations in CHL cells with and
without metabolic activation. (Estimated
by analogy)
NICNAS NA/773, 2000;
Professional judgment
Based on analogy to BAPP.
Sufficient study details were
reported in a secondary source;
used EC/European Economic
Community (EEC) test guidelines
(EC Directives 87/18/EEC and
88/320/EEC). Data are for the
predominant component of BAPP.
Chromosomal
Aberrations in vivo
Negative; did not increase
micronucleated polychromatic
erythrocytes in bone marrow cells of
mice. (Estimated by analogy)
NICNAS NA/869, 2000;
Professional judgment
Based on analogy to BAPP.
Sufficient study details were
reported in a secondary source;
used OECD test guidelines (OECD
474). Data are for commercial
mixture of BAPP.
DNA Damage and
Repair
No data located.
Other
No data located.
Reproductive Effects
LOW: The high MW components of Phosphonate Oligomer are expectet
and therefore have low potential for reproductive effects based on profes
assessment literature. No structural alerts or mechanistic pathways assoc
were identified for the lower MW oligomeric material (n=l and n=2).
to have limited bioavailability
sional judgment and the polymer
iated with reproductive effects
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected.
(Estimated for n >3 oligomers)
Professional judgment;
Boethling et al., 1997
Based on cutoff value for large,
high MW non-ionic polymers.
No data located
(Forn=l andn=2 oligomers)
Professional judgment
No structural alerts or mechanistic
pathways associated with
reproductive effects were identified
for the lower MW oligomeric
material.
4-497
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected.
(Estimated for n>3 oligomers)
Professional judgment;
Boethling et al., 1997
Based on cutoff value for large,
high MW non-ionic polymers.
No data located
(Forn=l andn=2 oligomers)
Professional judgment
No structural alerts or mechanistic
pathways associated with
reproductive effects were identified
for the lower MW oligomeric
material.
Reproduction and
Fertility Effects
Limited bioavailability expected.
(Estimated for n >3 oligomers)
Professional judgment;
Boethling et al., 1997
Based on cutoff value for large,
high MW non-ionic polymers.
No data located
(Forn=l andn=2 oligomers)
Professional judgment
No structural alerts or mechanistic
pathways associated with
reproductive effects were identified
for the lower MW oligomeric
material.
Developmental Effects
LOW: The high MW polymeric materia
potential for developmental effects base<
No structural alerts or mechanistic path
lower MW oligomeric material (n=l am
1 is expected to have limited bioavailability and therefore has low
i on professional judgment and the polymer assessment literature,
ways associated with developmental effects were identified for the
n=2).
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected.
(Estimated for n>3 oligomers)
Professional judgment;
Boethling et al., 1997
Based on cutoff value for large,
high MW non-ionic polymers.
No data located
(Estimated for n=l and n=2 oligomers)
Professional judgment
No structural alerts or mechanistic
pathways associated with
reproductive effects were identified
for the lower MW oligomeric
material.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected.
(Estimated for n>3 oligomers)
Professional judgment;
Boethling et al., 1997
Based on cutoff value for large,
high MW non-ionic polymers.
No data located
(Estimated for n=l and n=2 oligomers)
Professional judgment
No structural alerts or mechanistic
pathways associated with
reproductive effects were identified
for the lower MW oligomeric
material.
4-498
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Neurotoxicity
MODERATE: A moderate hazard is est
neurotoxicity based on the presence of t
imated for the Phosphonate Oligomer. There is potential for
le phenol structural alert.
Neurotoxicity Screening
Battery (Adult)
Limited bioavailability expected.
(Estimated for n>3 oligomers)
Professional judgment;
Boethling et al., 1997
Based on cutoff value for large,
high MW non-ionic polymers.
Other
Potential for neurotoxic effects based on
a structural alert for organophosphates
(Estimated by analogy)
Professional Judgment
Estimated based on a structural
alert for organophosphates and
professional judgment.
Repeated Dose Effects
LOW: A low hazard is estimated for the
to BAPP (181028-79-5), which has a low
oligomers with n >3 is also of low hazarc
lower MW oligomers of Phosphonate Oligomer based on analogy
hazard potential for this endpoint. The hazard designation for
potential based on limited bioavailability.
Limited bioavailability expected.
(Estimated for n>3 oligomers)
Professional judgment;
Boethling et al., 1997
Based on cutoff value for large,
high MW non-ionic polymers.
In a 28-day oral (gavage) study in
Sprague-Dawley rats, there were no
treatment-related changes in any of the
parameters measured.
NOEL >1,000 mg/kg-day (highest dose
tested) (Estimated by analogy)
NICNAS NA/869, 2000;
Professional judgment
Based on analogy to BAPP.
Sufficient study details were
reported; used OECD test
guidelines (OECD 407). Data are
for commercial mixture of BAPP.
In a 28-day oral (gavage) study in
Sprague-Dawley rats, there were no
treatment-related changes in any of the
parameters measured NOEL >1,000
mg/kg-day (highest dose tested).
(Estimated by analogy)
NICNAS NA/773, 2000;
Professional judgment
Based on analogy to BAPP.
Sufficient study details were
reported; used EEC test guidelines
(EEC Directive 92/69/EEC,
Method B7). Data are for the
predominant component of BAPP.
Skin Sensitization
LOW: Based on expert judgment, Phosphonate Oligomer is not estimated to have potential for skin
sensitization. No experimental data were located for this compound. For the lower MW oligomers, the
hazard designation is low based on analogy to BAPP (181028-79-5).
Skin Sensitization
Not expected to be a skin sensitizer
(Estimated for n>3 oligomers)
Expert judgment
Estimated based on expert
judgment.
4-499
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Non-sensitizing, guinea pig
(Estimated by analogy)
NICNAS NA/869, 2000;
Professional judgment
Based on analogy to BAPP.
Conducted according to
EEC/OECD guidelines (OECD
406). Data are for commercial
mixture of BAPP.
Non-sensitizing, guinea pig
(Estimated by analogy)
NICNAS NA/773, 2000;
Professional judgment
Based on analogy to BAPP.
Conducted according to
EEC/OECD guidelines (OECD
406). Data are for the predominant
component of BAPP.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
MODERATE: There is potential for irritation for Phosphonate Oligomer based on the phenol moieties.
Eye Irritation
Uncertain potential for irritation based
on the phenol moieties. (Estimated)
Professional judgment
Estimated based on phenol
moieties.
Dermal Irritation
MODERATE: There is potential for irritation for Phosphonate Oligomer based on the phenol moieties
structural alert.
Dermal Irritation
Uncertain potential for irritation based
on the phenol moieties. (Estimated)
Professional judgment
Estimated based on phenol
moieties.
Endocrine Activity
Based on expert judgment; Phosphonate Oligomer is not expected to have endocrine activity due to its poor
bioavailability and inability to be readily metabolized in the body.
Limited bioavailability expected.
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff value for large,
high MW non-ionic polymers.
Immunotoxicity
Based on expert judgment; Phosphonate Oligomer is expected to have limited bioavailability and therefore
has low potential for hazard.
Immune System Effects
Limited bioavailability expected.
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff value for large,
high MW non-ionic polymers.
4-500
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ECOTOXICITY
ECOSAR Class
Not applicable for n>3 oligomers. Polyphenols for n=l and n=2.
Acute Toxicity
LOW: Estimated data for Phosphonate Oligomer suggest no effects at saturation (NES) for the acute
aquatic toxicity endpoints for the n=l and n=2 oligomers and the non-ionic polymers with a MW >1,000
that do not contain reactive functional groups and are estimated to have NES. These polymers display NES
because the amount dissolved in water is not anticipated to reach a concentration at which adverse effects
may be expressed. Bioavailability is limited because this chemical cannot be absorbed through membranes
due to large size.
Fish LC50
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Fish
96-hour LC50 = 0.022 mg/L
(Estimated for n=l)
ECOSAR: Phenols, Poly
ECOSAR version 1.11
NES: The log Kow of 7.2 for this
chemical exceeds the SAR
limitation for log K0„ of 5.5; NES
are predicted for these endpoints.
Fish
96-hour LC50 = 0.009 mg/L
(Estimated for n=l)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 7.2 for this
chemical exceeds the SAR
limitation for log K0„ of 5.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis. ECOSAR also
provided results for the Esters, and
Esters (phosphate) classes;
however, professional judgment
indicates that this compound does
not lie within the domain of the
ECOSAR model.
4-501
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish
96-hour LC50 = 0.00026 mg/L
(Estimated for n=2)
ECOSAR: Phenols, Poly
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 5.5; NES
are predicted for these endpoints.
Fish
96-hour LC50 = 0.0000087 mg/L
(Estimated for n=2)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 5.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis. ECOSAR also
provided results for the Esters, and
Esters (phosphate) classes;
however, professional judgment
indicates that this compound does
not lie within the domain of the
ECOSAR model.
Daphnid LCS0
Daphnia magna 48-hour EC50 >0.275
mg/L; semi static conditions.
(Experimental)
FRX Polymers, Inc, 201 la
Study conducted according to
guidelines for daphnia acute
immobilization test; test substance
purity = 96.39%. It is not clear if
the reported value represents
nominal or actual concentrations of
dissolved species.
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
4-502
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid
48-hour LC50 = 0.022 mg/L
(Estimated for n=l)
ECOSAR: Phenols, Poly
ECOSAR version 1.11
NES: The log K0„ of 7.2 for this
chemical exceeds the SAR
limitation for log K0„ of 5.5; NES
are predicted for these endpoints.
Daphnid
48-hour LC50 = 0.013 mg/L
(Estimated for n=l)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 7.2 for this
chemical exceeds the SAR
limitation for log K0„ of 5.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis. ECOSAR also
provided results for the Esters, and
Esters (phosphate) classes;
however, professional judgment
indicates that this compound does
not lie within the domain of the
ECOSAR model.
Daphnid
48-hour LC50 = 0.000061 mg/L
(Estimated for n=2)
ECOSAR: Phenols, Poly
ECOSAR version 1.11
NES: The log Kow of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 5.5; NES
are predicted for these endpoints.
4-503
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid
48-hour LC50 = 0.000024 mg/L
(Estimated for n=2)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 5.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis. ECOSAR also
provided results for the Esters, and
Esters (phosphate) classes;
however, professional judgment
indicates that this compound does
not lie within the domain of the
ECOSAR model.
Green Algae ECS0
Pseiidokirchneriella subcapitata 72-hour
EC50 >0.124 mg/L (Experimental)
FRX Polymers, Inc, 201 lb
Study conducted according to
guidelines for algal growth
inhibition test; test substance purity
= 96.39%. It is not clear if the
reported value represent nominal or
actual concentrations of dissolved
species.
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Green algae
96-hour EC50 = 0.19 mg/L
(Estimated for n=l)
ECOSAR: Phenols, Poly
ECOSAR version 1.11
NES: The log Kow of 7.2 for this
chemical exceeds the SAR
limitation for log K0„ of 6.4; NES
are predicted for these endpoints.
4-504
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae
96-hour EC50 = 0.012 mg/L
(Estimated for n=l)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 7.2 for this
chemical exceeds the SAR
limitation for log K0„ of 6.4; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis. ECOSAR also
provided results for the Esters, and
Esters (phosphate) classes;
however, professional judgment
indicates that this compound does
not lie within the domain of the
ECOSAR model.
Green algae
96-hour EC50 = 0.018 mg/L
(Estimated for n=2)
ECOSAR: Phenols, Poly
ECOSAR version 1.11
NES: The log Kow of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 6.4; NES
are predicted for these endpoints.
4-505
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae
96-hour EC50 = 0.000024 mg/L
(Estimated for n=2)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 6.4; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis. ECOSAR also
provided results for the Esters, and
Esters (phosphate) classes;
however, professional judgment
indicates that this compound does
not lie within the domain of the
ECOSAR model.
Chronic Aquatic Toxicity
HIGH: Based on estimated data for chr<
should be noted that the estimated value
estimation model and there is a high deg
jnic aquatic toxicity endpoints for the n=l and n=2 oligomers. It
s may be near the limit of the domain of applicability for this
ree of uncertainty in these estimated results.
Fish ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Fish
30-day ChV = 0.005 mg/L
(Estimated for n=l)
ECOSAR: Phenols, Poly
ECOSAR version 1.11
The estimated value is close to the
cutoff value of this ECOSAR class.
There is a high degree of
uncertainty as the estimates for this
compound are at the limits of the
domain for this estimation model.
4-506
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish
30-day ChV = 0.0015 mg/L
(Estimated for n=l)
ECOSAR: Neutral organics
ECOSAR version 1.11
The estimated value is close to the
cutoff value of this ECOSAR class.
There is a high degree of
uncertainty as the estimates for this
compound are at the limits of the
domain for this estimation model.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis. ECOSAR also
provided results for the Esters, and
Esters (phosphate) classes;
however, professional judgment
indicates that this compound does
not lie within the domain of the
ECOSAR model.
Fish
30-day ChV = 0.000037 mg/L
(Estimated for n=2)
ECOSAR: Phenols, Poly
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log Kow of 8.0; NES
are predicted for these endpoints.
4-507
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish
30-day ChV = 0.0000022 mg/L
(Estimated for n=2)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis. ECOSAR also
provided results for the Esters, and
Esters (phosphate) classes;
however, professional judgment
indicates that this compound does
not lie within the domain of the
ECOSAR model.
Daphnid ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Daphnid
Daphnid ChV = 0.006 mg/L
(Estimated for n=l)
ECOSAR: Phenols, Poly
ECOSAR version 1.11
The estimated value is close to the
cutoff value of this ECOSAR class.
There is a high degree of
uncertainty as the estimates for this
compound are at the limits of the
domain for this estimation model.
4-508
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid
Daphnid ChV = 0.003 mg/L
(Estimated for n=l)
ECOSAR: Neutral organics
ECOSAR version 1.11
The estimated value is close to the
cutoff value of this ECOSAR class.
There is a high degree of
uncertainty as the estimates for this
compound are at the limits of the
domain for this estimation model.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis. ECOSAR also
provided results for the Esters, and
Esters (phosphate) classes;
however, professional judgment
indicates that this compound does
not lie within the domain of the
ECOSAR model.
Daphnid
Daphnid ChV = 0.000013 mg/L
(Estimated for n=2)
ECOSAR: Phenols, Poly
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log Kow of 8.0; NES
are predicted for these endpoints.
4-509
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid
Daphnid ChV = 0.00001 mg/L
(Estimated for n=2)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis. ECOSAR also
provided results for the Esters, and
Esters (phosphate) classes;
however, professional judgment
indicates that this compound does
not lie within the domain of the
ECOSAR model.
Green Algae ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Green algae
ChV = 0.054 mg/L
(Estimated for n=l)
ECOSAR: Phenols, Poly
ECOSAR version 1.11
Chemical may not be soluble
enough to measure this predicted
effect; ChV value exceeds water
solubility.
4-510
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae
ChV = 0.034 mg/L
(Estimated for n=l)
ECOSAR: Neutral organics
ECOSAR version 1.11
Chemical may not be soluble
enough to measure this predicted
effect; ChV value exceeds water
solubility.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis. ECOSAR also
provided results for the Esters, and
Esters (phosphate) classes;
however, professional judgment
indicates that this compound does
not lie within the domain of the
ECOSAR model.
Green algae
ChV = 0.009 mg/L
(Estimated for n=2)
ECOSAR: Phenols, Poly
ECOSAR version 1.11
NES: The log Kow of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted for these endpoints.
4-511
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae
ChV = 0.00037 mg/L
(Estimated for n=2)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 11 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis. ECOSAR also
provided results for the Esters, and
Esters (phosphate) classes;
however, professional judgment
indicates that this compound does
not lie within the domain of the
ECOSAR model.
ENVIRONMENTAL FATE
Transport
The estimated negligible water solubility and estimated negligible vapor pressure indicate that this polymer
is anticipated to partition predominantly to soil and sediment. The estimated Henry's Law Constant of
<10"8 atm-m3/mole indicates that it is not expected to volatilize from water to the atmosphere. The estimated
Koc of >30,000 indicates that it is not anticipated to migrate from soil into groundwater and also has the
potential to adsorb to sediment.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated for n>3 oligomers)
Professional judgment; Boethling
et al., 1997
Cutoff value used for large, high MW
polymers. High MW polymers are
expected to have low vapor pressure
and are not expected to undergo
volatilization.
<10"8 (Estimated for n=l and n=2)
EPI; Professional judgment
Cutoff value for nonvolatile
compounds.
4-512
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated for n>3 oligomers)
Professional judgment; Boethling
et al., 1997
Cutoff value used for large, high MW
polymers. High MW polymers are
expected to adsorb strongly to soil
and sediment
>30,000 (Estimated for n=l and n=2)
EPI; EPA, 2004
Cutoff value for non-mobile
compounds.
Level III Fugacity Model
Air <1%
Water <1%
Soil = 53%
Sediment = 46%
(Estimated for n = 1 and n = 2)
EPI
No data located for the high MW
component of the polymers.
Persistence
VERY HIGH: The high MW components (MW >1,000) of this polymer are expected to have negligible water
solubility and poor bioavailability to microorganisms indicating that neither biodegradation nor hydrolysis
are expected to be important removal processes in the environment. The polymer does not contain functional
groups that would be expected to absorb light at environmentally significant wavelengths. Evaluation of these
degradation values suggest a half-life of >180 days.
Water
Aerobic Biodegradation
Recalcitrant (Estimated for n >3
oligomers)
Professional judgment; Boethling
et al., 1997
High MW polymers are expected to
be non-biodegradable.
Weeks (Primary Survey Model)
Recalcitrant (Ultimate Survey Model) for
n=l (Estimated)
EPI
Weeks-months (Primary Survey Model
Recalcitrant (Ultimate Survey Model) for
n=2 (Estimated)
EPI
Volatilization Half-life for
Model River
>1 year (Estimated)
Professional judgment
This polymer is anticipated to be
nonvolatile.
Volatilization Half-life for
Model Lake
>1 year (Estimated)
Professional judgment
This polymer is anticipated to be
nonvolatile.
Soil
Aerobic Biodegradation
Recalcitrant (Estimated for n >3
oligomers)
Professional judgment; Boethling
et al., 1997
High MW polymers are expected to
be non-biodegradable.
4-513
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Anaerobic
Biodegradation
Recalcitrant (Estimated for n >3
oligomers)
Professional judgment; Boethling
et al., 1997
High MW polymers are expected to
be resistant to removal under anoxic
conditions due to their limited
bioavailability.
Soil Biodegradation w/
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
No data located.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Mill, 2000; Professional
judgment
The substance does not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
Hydrolysis
>1 year (Estimated)
Professional judgment
Given the limited solubility estimated
for this material, hydrolysis is not
anticipated to occur to an appreciable
extent.
Environmental Half-life
>180 days (Estimated)
Professional judgment
The majority of this substance has a
MW >1,000 and is not anticipated to
be assimilated by microorganisms.
Therefore, biodegradation is not
expected to be an important removal
process. It is also not expected to be
removed by other degradative
processes under environmental
conditions because of limited water
solubility and limited partitioning to
air.
4-514
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Bioaccumulation
HIGH: Although measured BCF values are available, estimated BAF values are incorporated for a
conservative approach. The BAF estimates are consistent with the potential for bioaccumulation that is
anticipated. The high MW oligomers do not contribute to the bioaccumulation designation. The high MW
oligomers are expected to have poor bioavailability and are not expected to be bioaccumulative.
Fish BCF
Eight components of this polymer with
MW <1,000 were tested according to
"Bioconcentration test of chemical
substances in fish and shellfish" in
Cyprinus carpio. Test concentrations of
0.01 and 0.001 mg/L.
Results:
Mass
to
High
charge
Cone.
ratio
Level
Low Cone.
(m/z)
BCF
Level BCF
383
<41
<222
517
<85
<223-242
688
<60
<142
822
<67
<114-280
976
<53
<128
537
274
<200-560
577
82-250
<200-534
825
<20-52
<200
<100 (Estimated for n>3 oligomers)
10,000 (Estimated for n=l)
190 (Estimated for n=2)
FRX Polymers Inc., 2012
Professional judgment
EPI
EPI
Reported as Japanese notification,
guideline study.
The substance has a MW >1,000 and
is not anticipated to be taken up by
aquatic organisms; therefore,
bioconcentration is not expected.
4-515
-------
Phosphonate Oligomer CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
BAF
For n >3 oligomers
No data located.
780,000 (Estimated for n=l)
EPI
64,000 (Estimated for n=2)
EPI
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-516
-------
Boethling, Robert S. and Nabholz, J. Vincent "Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act",
pp. 187-234, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs, Hamilton, John D.
and Sutcliffe, Roger (eds.), (1997) Van Nostrand Reinhold.
CDC (Centers for Disease Control and Prevention). Fourth National Report on Raman Exposure to Environmental Chemicals,
Updated Tables. Department of Health and Human Services 2011. Available at: http://www.cdc.gov/exposurereport/ as of May 10,
2011
[HPV Assessment Guidance] EPA (U.S. Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining
the Adequacy of Existing Data. U.S. Environmental Protection Agency: Washington D.C. 1999.
http://www.epa. gov/hpv/pub s / general/datadfin.htm
ECOSAR/EPI (EPIWIN/EPISUITE) Estimations Programs Interface for Windows, Version 1.11. U.S. Environmental Protection
Agency: Washington D.C. http://www.epa.gov/opptintr/exposure/.
EPI (EPIWIN/EPISUITE) Estimation Program Interface for Windows, Version 4.1. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/
U.S. EPA. 2004. The Pollution Prevention (P2) Framework, EPA-748-B-03-001. Office of Pollution Prevention and Toxics 7403M,
U.S. Environmental Protection Agency, Washington, DC. 20460. October 2003 version updated in January 2004. Latest version
available at http://www.epa.gov/opptintr/newchems/pubs/sustainable/p2frame-iune05a2.pdf
EPA Sustainable Futures. UsingNon Cancer Screening within the SFInitiative. U.S. Environmental Protection Agency: Washington
D.C. 2010. http://www.epa.gOv/opptintr/sf/pubs/noncan-screen.htm#systemic as of February 19, 2012.
EPA. TSCANew Chemicals Program Chemical Categories. U.S. Environmental Protection Agency: Washington, DC. 2010c.
http://www.epa.gov/oppt/newchems/pubs/npcchemicalcategories.pdf as of November 25. 2013.
European Chemical Substances Information System (ESIS) Classification, Labeling and Packaging of Dangerous Substances Annex
VI to Regulation (EC) No 1272/2008 [Online] available at: http://esis.jrc.ec.europa.eu/home.php as of May 10, 2011.
FRX Polymers. FRX100 Homopolymer Material Safety Data Sheet (MSDS). Revised October 2, 2009.
4-517
-------
FRX Polymers, Inc. FRX oligophosphonate: Acute oral toxicity in the rat - fixed dose method. FRX Polymers, Inc. Chelmsford, MA.
Project number 41003294. 2010. (Submitted unpublished study).
FRX Polymers, Inc. Final report. Acute immobilization test of FRX OL 1001 with Daphnia magna. Study No. A100584. 2011a.
(Submitted unpublished study).
FRX Polymers, Inc. Final report. Growth inhibition test of FRX OL 1001 with green algae. Study No. A100583. 2011b. (Submitted
unpublished study).
FRX Polymers, Inc. Chromosomal aberration study of FRX OL 1001 in cultured mammalian cells. FRX Polymers, Inc. Chelmsford,
MA. B1001175. 2011c. (Submitted unpublished study).
FRX Polymers, Inc. Final report. Bioconcentration Study of FRX OL 1001 with Carp. Study No. A100581. 2012. (Submitted
unpublished study).
Mill, T. (2000) Photoreactions in Surface Waters. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for
Chemicals, Environmental Health Sciences (355-382). Boca Raton: Lewis Publishers.
NICNAS NA/773 (National Industrial Chemicals Notification and Assessment Scheme). Phosphoric acid, (1-methylethylidene) di-
4,1-phenylene tetraphenyl ester (FyrolflexBDP). File No. NA/773. 2000.
NICNAS NA/869 (National Industrial Chemicals Notification and Assessment Scheme). Phosphoric Trichloride, Reaction Products
with Bisphenol A and Phenol). File No. NA/869. 2000.
4-518
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol; BPBP
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
1 The highest hazard designation of any of the oligomers with MW <1,000.
§ Based on analogy to experimental data for a structurally similar compound.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Phosphoric acid, mixed esters with [1,1'-
bisphenyl-4,4'-diol] and phenol; BPBP
1003300-73-9
L
M
L
L
L
L
VL
VL
H
M%
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-519
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-dioll and phenol; BPBP
9
o °
6
n = 1-4
CASRN: 1003300-73-9
MW: 650.6 (n = 1); 974.8 (n = 2);
>1000 (n >3)
MF: C36H28 08P2 (n = 1)
Physical Forms:
Neat: Solid or liquid (depending on
oligomer distribution)
Use: Flame retardant
SMILES: 0=P(0clcccccl)(0clcccccl)0clccc(ccl)clccc(ccl)0P(=0)(0clcccccl)0clcccccl (n= 1)
c 1 (c6cc(0P(=0)(0c8ccc(c4ccc(0P(=0)(0c9ccccc9)0c5ccccc5)cc4)cc8)0c3ccccc3)ccc6)ccc(0P(=0)(0c7ccccc7)0c2ccccc2)cc 1 (n = 2)
Synonyms: Phosphoric acid, P,P'-[l,l'-biphenyl]-4,4'-diyl P,P,P',P'-tetraphenyl ester; Biphenyl-4,4'-diyl tetraphenyl bis(phosphate); BPBP; ADK STAB FP-800; T-
1752F.
Chemical Considerations: The n = 1 (>80% of composition) and n = 2 oligomers are amenable to EPI v4.1 estimation methods for physical/chemical and
environmental fate values and ECOSAR vl. 11 for ecotoxicity values in the absence of experimental data. The higher MW oligomers (n = 2-4) that have MWs >1,000
are assessed together using information contained in the literature concerning polymer assessment and professional judgment (Boethling et al., 1997).
Polymeric: Yes
Oligomers: The n = 1 structure comprises >80% of the mixture, with the balance
primarily made up of higher oligomers (n = 2, 3, 4, etc.).
Analog: Confidential compounds
Endpoint(s) using analog values: Acute and chronic aquatic toxicity,
reproductive and developmental effects
Analog Structure: No structure provided for confidential compounds.
Metabolites, Degradates and Transformation Products: None identified. Degradation of Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol
has not been well demonstrated in experimental studies (Submitted confidential study); no degradates have been identified. Degradation of Phosphoric acid, mixed
esters with [l,l'-bisphenyl-4,4'-diol] and phenol by sequential dephosphorylation could produce phenol (CASRN 108-95-2), 4,4'-dihydroxybiphenyl (CASRN 92-88-
6) and diphenyl phosphate (CASRN 838-85-7). The importance of dephosphorylation relative to possible competing pathways has not been demonstrated in a
published study. Therefore the hazards of the theoretical degradation products were not considered in this hazard assessment.
Structural Alerts: None identified
Risk Phrases: None
Hazard and Risk Assessments: None
4-520
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
53 - 83 (Measured)
According to Organisation of Economic
Cooperation and Development (OECD)
102; using good laboratory practice (GLP)
Submitted confidential studies
Guideline study reported in a
submitted confidential study for the
polymeric mixture.
65-85 (Measured)
Adeka-Palmarole, 2013
Guideline study reported for the
commercial product ADK STAB FP-
800.
Boiling Point (°C)
Not determinable; decomposes above
260°C before boiling according to OECD
103 study; using GLP (Measured)
Submitted confidential studies
Guideline study reported in a
submitted confidential study for the
polymeric mixture.
>300 (Estimated for n=l; n=2 oligomers)
EPI; EPA, 1999
Estimate based on the representative
oligomers (n=l and n=2) with a MW
<1,000. Cutoff value for high boiling
point compounds according to High
Production Volume (HPV)
assessment guidance.
>300 (Estimated for n >3 oligomers)
Professional judgment
Cutoff value for high boiling point
compounds according to HPV
assessment guidance.
Vapor Pressure (mm Hg)
4.0xl0"7 (Measured)
According to OECD 104 study; using
GLP.
Submitted confidential studies
Guideline study reported in a
submitted confidential study for the
polymeric mixture.
<10"8 (Estimated for n >3 oligomers)
Professional judgment; Boethling
et al., 1997
Cutoff value for large, high MW
polymers.
2.1x10 s (Estimated for n=l; n=2
oligomers)
EPI
Estimate based on the representative
oligomers (n=l and n=2) with a MW
<1,000.
4-521
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Water Solubility (mg/L)
<0.01 (Measured)
According to OECD 105 study; using GLP
Submitted confidential studies
Guideline study reported in a
submitted confidential study.
<10° (Estimated) for n=l; n=2
EPI; EPA, 1999
Cutoff value for non soluble
compounds according to HPV
assessment guidance.
<10° (Estimated for n >3 oligomers)
Professional judgment; Boethling
et al., 1997
Cutoff value for large high MW
polymers.
Log Kow
5.5 (Measured)
According to GLP OECD 117 study; high
performance liquid chromatography
(HPLC) method
Submitted confidential studies
Reported in a submitted confidential
study. Sufficient experimental details
are not available to evaluate the
results, although the reported value is
likely for the commercial mixture and
not a specific oligomer.
9.2 (Estimated for n=l);
14 (Estimated for n=2)
EPI; EPA, 1999
Estimated value for n=2 oligomer is
greater than the cutoff value, >10,
according to methodology based on
HPV assessment guidance.
No data located (for n >3 oligomers)
Professional judgment
This polymer is not amenable to
available estimation methods.
Flammability (Flash Point)
Not highly flammable (Measured)
According to a GLP EC method A. 14
study
Submitted confidential studies
Reported in a submitted confidential
study.
Explosivity
Not explosive (Measured)
Submitted confidential studies
Reported in a submitted confidential
study.
Pyrolysis
>400°C (Measured)
Auto-ignition temperature; GLP EC
method A. 15 study
Submitted confidential studies
Reported in a submitted confidential
study.
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
4-522
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
HUMAN HEALTH EFF
ECTS
Toxicokinetics
There were no experimental studies available on the absorption, distribution, metabolism and/or excretion
(ADME) of BP BP. Its absorption and systemic availability after topical or oral administration is expected to
be limited, because of its MW (650.6), low water solubility (<0.01 mg/L at 20°C) and high lipophilicity (Log
Kow = 5.5 at 25°C) and because of the absence of relevant toxicity findings in available toxicity studies.
Based on professional judgment, only limited absorption is expected by any route, followed by rapid
excretion in feces and urine. This judgment is supported by a closely related analog.
Availability of BPBP under a vapor state is unlikely because of its low vapor pressure (4.0 x 10"7 mm Hg at
25°C) and its decomposition at high temperatures prior to boiling. Its availability as an inhalable aerosol is
unlikely because of its particle size.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
Estimated low potential for absorption
expected by any route, followed by rapid
excretion in feces and urine (Estimated
by analogy)
Submitted confidential studies;
Professional judgment
Based on physical-chemical
properties and confidential
structural analogs.
No absorption is expected for any route
of exposure; poor absorption may be
assumed of low MW oligomers (0%
<600; 85% <1000) in solution in all
routes
(Estimated by analogy)
Acute Mammalian Toxicity
LOW: Based on oral and dermal LDS0 values of >2000 mg/kg in rats for
available for the inhalation route, but due to mist particle size and solubi
potential is estimated to be low.
JPBP. No experimental data were
lity properties, the inhalation
Acute Lethality
Oral
LD50 >2000 mg/kg (no deaths)
Submitted confidential study
GLP OECD 420 (fixed dose) study;
reported in a submitted confidential
study.
Dermal
LD50 >2000 mg/kg (no deaths)
Submitted confidential study
GLP OECD 402 study; reported in
a submitted confidential study.
4-523
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Inhalation
No data available; due to particle
size and solubility properties
assumed low hazard.
Carcinogenicity
MODERATE: BPBP may have low pote
were no structural alerts in the molecule
However, there is uncertainty regarding
substance. Carcinogenic effects cannot
ntial for carcinogenicity based on professional judgment; there
, and a similar confidential analog was negative for carcinogenicity,
the carcinogenicity of BPBP due to the lack of data for this
)e completely ruled out.
OncoLogic Results
No data located; not amenable to
available estimation methods.
Carcinogenicity (Rat
and Mouse)
Low potential for carcinogenicity
(Estimated based on analogy)
Professional judgment
Professional judgment (based on
similar confidential analog); no data
located.
Combined Chronic
Toxicity/
Carcinogenicity
Genotoxicity
LOW: BPBP was not mutagenic to bacteria in vitro or in mouse lymphocyte (L5178Y) cells. No
chromosomal aberrations were detected in an in vitro mammalian chromosomal aberration assay with
Chinese hamster fibroblasts.
Gene Mutation in vitro
Negative for mutagenicity in S.
typhimiirium and E. coli (strains not
specified; metabolic activation not
specified);
No relevant cytotoxicity
Submitted confidential study
GLP OECD 471 study; reported in
a submitted confidential study.
Negative for mutagenicity in mouse
lymphocyte (L5178Y) cells (metabolic
activation unspecified);
No relevant cytotoxicity
Submitted confidential study
GLP OECD 476 study; reported in
a submitted confidential study.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
Negative for chromosomal aberrations in
Chinese hamster fibroblasts (metabolic
activation unspecified);
No relevant cytotoxicity
Submitted confidential study
GLP OECD 473 study; reported in
a submitted confidential study.
Chromosomal
Aberrations in vivo
No data located.
4-524
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
Reproductive Effects
LOW: Estimated based on analogy to a similar confidential analog. There were no reproductive effects
reported in studies using a confidential structural analog at doses up to 1,000 mg/kg-day.
Reproduction/
Developmental Toxicity
Screen
Low potential based on structural analog;
No maternal or fetal toxicity reported at
1,000 mg/kg-day
NOAEL = 1,000 mg/kg-day (highest
dose tested)
(Estimated by analogy)
Submitted confidential study;
Professional judgment
Estimate based on professional
judgment (based on similar
confidential analog - GLP OECD
421 study; reported in a submitted
confidential study.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
Reproduction and
Fertility Effects
No data located
Developmental Effects
LOW: Estimated based on analogy to a similar confidential analog. There were no developmental effects
reported in a confidential structural analog at doses up to 1,000 mg/kg-day. Although predicted to have low
hazard, there is high uncertainty due to lack of data related to developmental neurotoxicity.
Reproduction/
Developmental Toxicity
Screen
Low potential based on structural analog
No maternal or fetal toxicity reported at
1,000 mg/kg-day
NOAEL = 1,000 mg/kg-day (highest
dose tested)
(Estimated by analogy)
Submitted confidential study;
Professional judgment
Estimate based on professional
judgment (based on similar
confidential analog - GLP OECD
421 study; reported in a submitted
confidential study.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
4-525
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Prenatal Development
No data located.
Postnatal Development
No data located.
Neurotoxicity
LOW: There were no neurotoxic effects
study. Although low hazard is predictec
inhibition which is associated with phos
observed at doses up to 1,000 mg/kg in a 28-day rat oral (gavage)
1, there is uncertainty due to lack of data on cholinesterase
ahate esters.
Neurotoxicity Screening
Battery (Adult)
In a 28-day oral (gavage) study, no
effects from BPBP on: clinical
observations, neurotoxicity parameters,
body weight, food intake, hematology,
blood chemistry, urine analysis, or
pathology. No abnormal observations in
the recovery group.
NOAEL = 1,000 mg/kg (gavage)
Submitted confidential study
GLP OECD 407 study; reported in
a submitted confidential study.
Repeated Dose Effects
LOW: No treatment-related effects were reported in a sub-acute 28-day rat oral (gavage) study with BPBP,
indicating a NOAEL of 1,000 mg/kg.
In a 28-day study, no effects from BPBP
in clinical observations, neurotoxicology
parameters, body weight, food intake,
hematology, blood chemistry, urine
analysis, or pathology. No abnormal
observations in the recovery group.
NOAEL = 1,000 mg/kg (gavage)
Submitted confidential study
GLP OECD 407 study; reported in
a submitted confidential study.
Low potential based on a 90-day study
for a confidential structural analog
(Estimated based on analogy)
Professional judgment
Estimate based on professional
judgment and data from a
confidential structural analog
Immune System Effects
Low potential for immunotoxicity.
(Estimated)
Expert judgment
No data located. Estimated based on
expert judgment.
Skin Sensitization
LOW: No sensitizing effect detected in a Mouse Local Lymph Node Assay (LLNA) with BPBP.
Skin Sensitization
Not sensitizing; no irritation or relevant
increase in ear thickness (LLNA-test)
Submitted confidential study
GLP OECD 429 study; reported in
a submitted confidential study.
4-526
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
VERY LOW: BP BP is not an eye irritant in rabbits.
Eye Irritation
Not irritating, rabbits; only minor
findings at 1 hour post installation
Submitted confidential study
GLP OECD 405 study; reported in
a submitted confidential study.
Dermal Irritation
VERY LOW: BP BP is not a skin irritant in rabbits.
Dermal Irritation
Not irritating, rabbits; no signs of
irritation at any observation time point of
the study
Submitted confidential study
GLP OECD 404 study; reported in
a submitted confidential study.
Endocrine Activity
No experimental data were located.
No data located.
Immunotoxicity
BPBP is estimated to have low potential for immunotoxicity based on expert judgment. No experimental
data for this substance were located.
Immune System Effects
Low potential for immunotoxicity.
(Estimated)
Expert judgment
No data located. Estimated based on
expert judgment.
ECOTOXICITY
ECOSAR Class
Acute Toxicity
HIGH: Estimated based on an ECS0 value of <1.0 mg/L in algae for a structurally similar confidential
analog. While ECOSAR estimates for algae indicate no effects at saturation (NES), experimental data is
preferred over estimates to determine the hazard designation. The results of experimental studies and
estimates for fish and daphnia indicate NES.
Fish LC50
LC50 >100 mg/L
Submitted confidential study
GLP OECD 203 study; reported in
a submitted confidential study;
sufficient experimental details are
not available to address why the
reported LC50 is higher than the
water solubility.
4-527
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish
96-hour LC50 = 0.000193 mg/L
(Estimated for n=l)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000; NES: The
log K0„ of 9.2 for this n=l oligomer
exceeds the S AR limitation of log
Kow 5.0. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
Fish
96-hour LC5o = 0.0000000279 mg/L
(Estimated for n=2)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000; NES: The
log K0„ of 14 for this n=2 oligomer
exceeds the S AR limitation of log
K0„ 5.0. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
Daphnid LCS0
EC50 >100 mg/L
Submitted confidential study
GLP OECD 202 study; reported in
a submitted confidential study;
sufficient experimental details are
not available to address why the
reported LC50 is higher than the
water solubility.
4-528
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid
48-hour LC50 = 0.000213 mg/L
(Estimated for n=l)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000; NES: The
log K0„ of 9.2 for this n=l oligomer
exceeds the S AR limitation of log
Kow 5.0. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
Daphnid
48-hour LC5o = 0.0000000465 mg/L
(Estimated for n=2)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000; NES: The
log K0„ of 14 for this n=2 oligomer
exceeds the S AR limitation of log
K0„ 5.0. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
Green Algae ECS0
Green algae NOEC >100 mg/L
Submitted study
GLP OECD 201 study submitted to
EPA; study methodology has
limitations due to the limited water
solubility of this substance.
Sufficient experimental details are
not available to address why the
reported NOEC is higher than the
water solubility.
Green algae EC50 <1.0 mg/L
Submitted confidential study
Reported in a submitted
confidential study.
4-529
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae
96-hour EC50 = 0.002 mg/L
(Estimated for n=l)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000; NES: The
log K0„ of 9.2 for this n=l oligomer
exceeds the S AR limitation of log
Kow 6.4. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
Green algae
96-hour EC50 = 0.00000295 mg/L
(Estimated for n=2)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000; NES: The
log K0„ of 14 for this n=2 oligomer
exceeds the S AR limitation of log
K0„ 6.4 ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
4-530
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Toxicity to microorganisms
NOEC >1,000 mg/L
Submitted confidential study
GLP OECD 209 study; reported in
a submitted confidential study.
Chronic Aquatic Toxicity
HIGH: Estimated based on a NOEC val
analog. While ECOSAR estimates for a
to determine the hazard designation. T
ue of <0.1 mg/L in algae for a structurally similar confidential
gae indicate NES, experimental data are preferred over estimates
le results of estimates for fish and daphnia indicate NES.
Fish ChV = 0.0000413 mg/L
(Estimated for n=l)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000. NES: The
log Kow of 9.2 for this n=l oligomer
exceeds the S AR limitation of log
K0„ 8.0. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
Fish ChV = 0.00000000971 mg/L
(Estimated for n=2)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000. NES: The
log Kow of 14 for this n=2 oligomer
exceeds the S AR limitation of log
K0„ 8.0. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
4-531
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid ChV
Daphnid
Daphnid ChV = 0.000131 mg/L
(Estimated for n=l)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000. NES: The
log K0„ of 9.2 for this n=l oligomer
exceeds the S AR limitation of log
Kow 8.0. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
Daphnid
Daphnid ChV = 0.0000000903 mg/L
(Estimated for n=2)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000. NES: The
log K0„ of 14 for this n=2 oligomer
exceeds the S AR limitation of log
K0„ 8.0. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
4-532
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green Algae ChV
Green algae NOEC <0.1 mg/L
(Estimated by analogy)
Submitted confidential study
Reported in a submitted
confidential study.
Green algae
ChV = 0.003 mg/L
(Estimated for n=l)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000. NES: The
log Kow of 9.2 for this n=l oligomer
exceeds the S AR limitation of log
K0„ 8.0. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
Green algae
ChV = 0.00000847 mg/L
(Estimated for n=2)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000. NES: The
log Kow of 14 for this n=2 oligomer
exceeds the S AR limitation of log
Kow 8.0. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
4-533
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL FATE
Transport
The environmental fate is described using estimates on the lowest MW oligomer of BPBP, which is the
predominant component. Based on the Level III fugacity models incorporating the available experimental
property data, the lowest MW oligomer is expected to partition primarily to soil and sediment. BPBP is
expected to be immobile in soil based on the measured Koc of the commercial mixture. Leaching of BPBP
through soil to groundwater is not expected to be an important transport mechanism. Estimated
volatilization half-lives indicate that BPBP will be non-volatile from surface water. Volatilization from dry
surfaces is also not expected based on its vapor pressure. In the atmosphere, BPBP is expected to exist solely
in the particulate phase, based on its measured vapor pressure. Particulates may be removed from air by wet
or dry deposition. The higher MW components of the commercial product are anticipated to behave similarly
to that described above.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated for the n=l; n=2
oligomers)
EPI; Professional judgment
Estimated based on predominant
oligomer components. The higher
MW oligomers are also expected to
have Henry's Law Constant values
below this cutoff.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
4.6 x 105 (Measured)
Calculated from the reported Login Koc =
5.7; according to HPLC method OECD
121 study; using GLP
Submitted confidential study
Confidential guideline study.
Level III Fugacity Model
Air: <1% (Estimated)
Water: 1%
Soil: 42%
Sediment: 57%
EPI
Estimated data based on the
predominant oligomer component, n
= 1, representing 80% of the
commercial mixture.
Air: <1% (Estimated)
Water: 3.7%
Soil: 94%
Sediment: 2%
EPI
Estimate based on the n=2 oligomer
component.
4-534
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Persistence
HIGH: BPBP was not readily biodegradable in a guideline Japanese Ministry of International Trade and
Industry (MITI)-I test (1% biodegradation in OECD TG 301C). The n>3 oligomers, with a MW >1,000 are
expected to have negligible water solubility and poor bioavailability to microorganisms indicating that
biodegradation is not expected to be an important removal process in the environment. Abiotic degradation
by hydrolysis is limited due to the low water solubility of BPBP (<0.01 mg/L). Similar to other phosphate
esters, BPBP hydrolysis is expected to be dependent on pH, occurring slowest under neutral and acidic
conditions. BPBP oligomers (n=l and n=2) do not contain chromophores that absorb at wavelengths >290
nm, and therefore, are not expected to be susceptible to direct photolysis by sunlight. Enzymatic or basic
hydrolysis leading to the production of phenol (CASRN 108-95-2), 4,4'-dihydroxybiphenyl (CASRN 92-88-6)
and diphenyl phosphate (CASRN 838-85-7) through sequential dephosphorylation is theoretically possible
but has not been demonstrated.
Water
Aerobic Biodegradation
Not readily biodegradable
1% biodegradation detected after 28 days
in activated sludge; GLP OECD 301C
MITI-I study (Measured)
Submitted confidential study
Confidential guideline study.
Days (Primary survey model)
Months (Ultimate survey model)
(Estimated)
EPI
Estimated data based on the
predominant oligomer component, n
= 1, representing 80% of the
commercial mixture.
Days (Primary survey model)
Recalcitrant (Ultimate survey model)
(Estimated)
EPI
Estimated data based on the n=2
oligomer.
Recalcitrant (Estimated for n >3
oligomers)
Professional judgment; Boethling
et al, 1997
High MW polymers are expected to
be non-biodegradable.
Volatilization Half-life for
Model River
>1 year (Estimated for the n=l; n=2
oligomers)
EPI
Estimate based on the n= 1 and n=2
oligomer components.
Volatilization Half-life for
Model Lake
>1 year (Estimated for the n=l; n=2
oligomers)
EPI
Estimate based on the n= 1 and n=2
oligomer components.
4-535
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Soil
Aerobic Biodegradation
No data available.
Anaerobic
Biodegradation
Not probable (Anaerobic-methanogenic
biodegradation probability model)
(Estimated)
EPI
Estimated data based on the n=l and
n=2 oligomers.
Soil Biodegradation w/
Product Identification
No data available.
Sediment/Water
Biodegradation
No data available.
Air
Atmospheric Half-life
6.5 hours (Estimated)
EPI
Estimate based on the n= 1 oligomer
component.
3.9 hours (Estimated)
EPI
Estimate based on the n=2 oligomer
component.
Reactivity
Photolysis
Not a significant fate process
Mill, 2000; Professional
judgment
The substance does not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
Hydrolysis
>1 year at pH 7;
44 days at pH 8
4.4 days at pH 9 (Estimated for n=l)
EPI
Hydrolysis rates are expected to be
pH-dependent and may be limited the
by low water solubility of this
compound. Under basic conditions,
sequential dephosphorylation
reactions may occur.
>1 year at pH 7;
40 days at pH 8
4 days at pH 9 (Estimated for n=2)
EPI
Environmental Half-Life
>1 year (Estimated for n=l)
EPI; PBT Profiler
Half-life estimated for the
predominant compartment
(sediment), as determined by EPI and
the PBT Profiler methodology.
>1 year (Estimated for n=2)
EPI; PBT Profiler
Half-life estimated for the
predominant compartment (soil), as
determined by EPI and the PBT
Profiler methodology.
4-536
-------
Phosphoric acid, mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol CASRN 1003300-73-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Bioaccumulation
MODERATE: Although measured BCF values for a commercial mixture result in a Low bioaccumulation
hazard designation, the overall bioaccumulation designation is Moderate based on the estimated BCF value
for the predominant oligomer component, n = 1, representing 80% of the commercial mixture. The higher
MW oligomers that may be found in this mixture (n=2, 3, 4) are expected to have low potential for
bioaccumulation.
Fish BCF
172 (Estimated for n=l)
3.2 (Estimated for n=2)
EPI
<100 (Estimated for n>3 oligomers)
Professional judgment
The components with a MW >1,000
are not anticipated to be taken up by
aquatic organisms; therefore,
bioconcentration is not expected.
12 (Measured)
According to GLP OECD 305C;
on the commercial product
Confidential study
Guideline study on the commercial
product mixture. This study did not
assess the concentration of each
oligomer in either the water or the
fish. Therefore the BCF of the
individual components of the mixture
could not be determined.
BAF
34 (Estimated for n=l)
27 (Estimated for n=2)
EPI
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2013).
4-537
-------
Adeka-Palmarole. Product information sheet. 2013. http://www.adeka-palmarole.com/additives/flame-retardants/443-adk-stab-fp-
800.html (accessed on April 16, 2013).
Boethling, Robert S. and Nabholz, J. Vincent "Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act",
pp. 187-234, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs, Hamilton, John D.
and Sutcliffe, Roger (eds.), (1997) Van Nostrand Reinhold.
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2013.
http://www.cdc.gov/exposurereport/pdf/FourthReport UpdatedTables Mar2013.pdf (accessed on April 16, 2013).
[HPV Assessment Guidance] EPA (U.S. Environmental Protection Agency). Determining the Adequacy of Existing Data. U.S.
Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadeqfn.pdf
U.S. EPA (Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing
Data. U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
ECOSAR/EPI (EPIWIN/EPISUITE) Estimations Programs Interface for Windows, Version 1.11. U.S. Environmental Protection
Agency: Washington D.C. http://www.epa.gov/opptintr/exposure/.
EPI (EPIWIN/EPISUITE) Estimation Program Interface for Windows. Version 4.1. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
Mill, T. (2000) Photoreactions in Surface Waters. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for
Chemicals, Environmental Health Sciences (355-382). Boca Raton: Lewis Publishers.
PBT Profiler. Persistent (P), Bioaccumulative (B), and Toxic (T) Chemical (PBT) Profiler. U.S. Environmental Protection Agency:
Washington D.C. www.pbtprofiler.net.
4-538
-------
Polyphosphonate
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Polyphosphonate
68664-06-2
L
L
L
L
L
L
Ld
L
L
L
L
L
VH
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-539
-------
Polyphosphonate
Representative structure
CASRN: 68664-06-2
MW: 10,000 to 50,000;
<1%MW <1,000
MF: C15H1602(C16H1703P)n
Physical Forms: Solid
Use: Flame retardant
SMILES: The polymer components with MW >1,000 are not amenable to SMILES notation.
Synonyms: Nofia® HM1100; FRX 100 (polyphosphonate) (Polymeric additive); FRX100; Phosphonic acid, P-methyl-, diphenyl ester, polymer with 4,4'-(l-
methylethylidene)bis[phenol]
Chemical Considerations: This alternative is a high MW polymer with <1% low (<1,000) MW oligomers. The high MW oligomers, with a MW >1,000, are assessed
together using the professional judgment and information contained in the literature concerning polymer assessment (Boethling et al., 1997).
Polymeric: Yes
Oligomers: The polymer is produced from the condensation of methyldiphenylphosphonate and bisphenol A equivalents. The MW of polyphosphonate ranges
between 10,000 and 50,000. Oligomers with MW <1,000 are expected to be present at <1% in the polyphosphonate mixture. Phenoxy terminated oligomers are
anticipated to predominate.
Metabolites, Degradates and Transformation Products: None
Analog: No analog
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: No data located.
Risk Phrases: Not classified by Annex VI Regulation (EC) No 1272/2008 (ESIS, 2011).
Hazard and Risk Assessments: None identified.
4-540
-------
Polyphosphonate CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
90 softening point (Measured)
FRX Polymers, Inc., 2009
The value corresponds to a softening
point for the polymer.
Boiling Point (°C)
>300 (Estimated)
Professional judgment
Cutoff value used for large, high MW
solids.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment;
Boethling et al., 1997
Cutoff value for large, high MW
polymers.
Water Solubility (mg/L)
<10° (Estimated)
Professional judgment; Boethling
et al., 1997
Cutoff value for large, high MW non-
ionic polymers.
Log Kow
No data located; polymers with a
MW >1,000 are outside the domain
of the available estimation methods.
Flammability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Pyrolysis
No data located.
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
4-541
-------
Polyphosphonate CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
No absorption is expected for any route of exposure for polyphosphonate. This polymer is large, with a MW
>1,000. Based on professional judgment, it is expected to have limited bioavailability and therefore is not
expected to be readily absorbed, distributed or metabolized in the body.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
No absorption is expected for any route
of exposure
(Estimated)
Professional judgment
Estimated based on professional
judgment.
Acute Mammalian Toxicity
LOW: Based on experimental LDS0 values >2,000 mg/kg. This compound is also expected to have limited
bioavailability and therefore has low potential for acute mammalian toxicity.
Oral
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoffs for large high MW
polymers
Rat oral LD50 >2,000 mg/kg
FRX Polymers, Inc., 2011
Conducted according to
Organisation of Economic
Cooperation and Development420;
test substance: FRX
polyphosphonate.
Dermal
No data located.
Inhalation
No data located.
Carcinogenicity
LOW: This polymer is large, with a MW >1,000. Based on professional judgment, it is expected to have few
to no residual monomers. Additionally, crosslinking, swellability, dispersability, reactive functional groups,
inhalation potential, and hindered amine groups are not expected. Therefore, there is low potential for
carcinogenicity.
OncoLogic Results
No data located.
Carcinogenicity (Rat
and Mouse)
Limited bioavailability expected;
crosslinking, swellability, dispersability,
reactive functional groups, inhalation
potential, and hindered amine groups are
not expected.
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoffs for large high MW
polymers.
Combined Chronic
Toxicity/
Carcinogenicity
4-542
-------
Polyphosphonate CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Genotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for genotoxicity.
Gene Mutation in vitro
Gene Mutation in vivo
Chromosomal
Aberrations in vitro
Chromosomal
Aberrations in vivo
DNA Damage and
Repair
Other (Mitotic Gene
Conversion)
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Reproductive Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for reproductive effects.
Reproduction/
Developmental Toxicity
Screen
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Reproduction and
Fertility Effects
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Developmental Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for developmental effects.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al.,1997
Based on cutoff values for large
high MW polymers.
4-543
-------
Polyphosphonate CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Prenatal Development
Postnatal Development
Neurotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for neurotoxicity.
Neurotoxicity Screening
Battery (Adult)
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Repeated Dose Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability; however,
because the MWn is >10,000, there is the possibility of lung overloading if >5% of the particles are in the
respirable range as a result of dust forming operations.
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
This polymer's MWn is >10,000;
potential for irreversible lung damage as
a result of lung overloading.
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Skin Sensitization
LOW: Based on expert judgment, polyphosphonate is estimated not to have potential for skin sensitization
Skin Sensitization
Not expected to be a skin sensitizer
(Estimated)
Expert judgment
Estimated based on expert
judgment by analogy to other high
MW polymers with similar
structural features.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
LOW: Based on expert judgment, polyphosphonate is estimated not to have potential for eye irritation.
Eye Irritation
Not expected to be an eye irritant
(Estimated)
Expert judgment
Estimated based on expert
judgment by analogy to other high
MW polymers with similar
structural features.
4-544
-------
Polyphosphonate CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Dermal Irritation
LOW: Based on expert judgment, polyphosphonate is estimated not to have potential for dermal irritation.
Dermal Irritation
Not expected to be a skin irritant
(Estimated)
Expert judgment
Estimated based on expert
judgment by analogy to other high
MW polymers with similar
structural features.
Endocrine Activity
No data located. This polymer is large, with a MW >1,000. Based on pro
polyphosphonate is not expected to have endocrine activity due to its poc
readily metabolized in the body.
essional judgment,
r bioavailability and inability to be
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Immunotoxicity
Based on professional judgment polyphosphonate is expected to have limited bioavailability and therefore
has low potential for hazard.
Immune System Effects
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
LOW: Non-ionic polymers with a MW >1,000 that do not contain reactive functional groups and are
comprised of minimal low MW oligomers are estimated to have no effects at saturation (NES). These
polymers display NES because the amount dissolved in water is not anticipated to reach a concentration at
which adverse effects may be expressed. Bioavailability is limited because this chemical cannot be absorbed
through membranes due to its large size.
Fish LC50
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
4-545
-------
Polyphosphonate CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Chronic Aquatic Toxicity
LOW: Non-ionic polymers with a MW >1,000 that do not contain reactive functional groups and are
comprised of minimal low MW oligomers are estimated to display NES. These polymers display NES
because the amount dissolved in water is not anticipated to reach a concentration at which adverse effects
may be expressed. Bioavailability is limited because this chemical cannot be absorbed through membranes
due to its large size.
Fish ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Daphnid ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Green Algae ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
ENVIRONMENTAL FATE
Transport
The estimated negligible water solubility and estimated negligible vapor pressure indicate that this polymer is
anticipated to partition predominantly to soil and sediment. The estimated Henry's Law Constant of
<10"8 atm-m3/mole indicates that it is not expected to volatilize from water to the atmosphere. The estimated
Koc of >30,000 indicates that it is not anticipated to migrate from soil into groundwater and also has the
potential to adsorb to sediment.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment; Boethling
et al., 1997
Cutoff value used for large, high MW
polymers. High MW polymers are
expected to have low vapor pressure
and are not expected to undergo
volatilization.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
Professional judgment; Boethling
et al., 1997
Cutoff value used for large, high MW
polymers. High MW polymers are
expected to adsorb strongly to soil
and sediment.
4-546
-------
Polyphosphonate CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Level III Fugacity Model
No data located.
Persistence
VERY HIGH: This polymer is large, with a MW >1,000. It is expected to have negligible water solubility and
poor bioavailability to microorganisms indicating that neither biodegradation nor hydrolysis are expected to
be important removal processes in the environment. The polymer does not contain functional groups that
would be expected to absorb light at environmentally significant wavelengths. Evaluation of these
degradation values suggest a half-life of >180 days.
Water
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment; EPA,
2010
High MW polymers are expected to
be non-biodegradable.
Volatilization Half-life for
Model River
>1 year (Estimated)
Professional judgment
This high MW polymer is anticipated
to be nonvolatile.
Volatilization Half-life for
Model Lake
>1 year (Estimated)
Professional judgment
This high MW polymer is anticipated
to be nonvolatile.
Soil
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment; Boethling
et al., 1997
High MW polymers are expected to
be non-biodegradable.
Anaerobic
Biodegradation
Recalcitrant (Estimated)
Professional judgment; Boethling
et al., 1997
High MW polymers are expected to
be resistant to removal under anoxic
conditions due to their limited
bioavailability.
Soil Biodegradation w/
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
No data located.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Mill, 2000; Professional
judgment
The substance does not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
4-547
-------
Polyphosphonate CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Hydrolysis
>1 year (Estimated)
Professional judgment
Given the limited solubility estimated
for this material, hydrolysis is not
anticipated to occur to an appreciable
extent.
Environmental Half-life
>180 days (Estimated)
Professional Judgment
The majority of this substance has a
MW >1,000 and is not anticipated to
be assimilated by microorganisms.
Therefore, biodegradation is not
expected to be an important removal
process. It is also not expected to be
removed by other degradative
processes under environmental
conditions because of limited water
solubility and limited partitioning to
air.
Bioaccumulation
LOW: This polymer is large, with a MW >1,000. It is expected to have poor bioavailability indicating that
this polymer should be of low potential for bioaccumulation.
Fish BCF
<100 (Estimated)
Professional judgment
The majority of this substance has a
MW >1,000 and is not anticipated to
be taken up by aquatic organisms;
therefore, bioconcentration is not
expected.
BAF
No data located.
Metabolism in Fish
No data located.
4-548
-------
Polyphosphonate CASRN 68664-06-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-549
-------
Boethling, Robert S. and Nabholz, J. Vincent "Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act",
pp. 187-234, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs, Hamilton, John D.
and Sutcliffe, Roger (eds.), (1997) Van Nostrand Reinhold.
CDC (Centers for Disease Control and Prevention). Fourth National Report on Raman Exposure to Environmental Chemicals,
Updated Tables. Department of Health and Human Services 2011. Available at: http://www.cdc.gov/exposurereport/ as of May 10,
2011
European Chemical Substances Information System (ESIS) Classification, Labeling and Packaging of Dangerous Substances Annex
VI to Regulation (EC) No 1272/2008 [Online] available at: http://esis.jrc.ec.europa.eu/home.php as of May 10, 2011.
FRX Polymers. FRX100 Homopolymer Material Safety Data Sheet (MSDS). Revised October 2, 2009.
FRX Polymers, Inc. FRX polyphosphonate: Acute oral toxicity in the rat - fixed dose method. FRX Polymers, Inc. Chelmsford, MA.
Project number 3224/0001. 2011. (Submitted unpublished study).
Mill, T. (2000) Photoreactions in Surface Waters. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for
Chemicals, Environmental Health Sciences (355-382). Boca Raton: Lewis Publishers.
4-550
-------
Poly[phosphonate-co-carbonate]
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame-retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
d This hazard designation would be assigned MODERATE if >5% of the particles are in the respirable range as a result of dust forming operations.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environ-
mental Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Poly[phosphonate-co-carbonate]
77226-90-5
L
L
L
L
L
L
Ld
L
L
L
L
L
VH
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-551
-------
Poly[phosphonate-co-carbonate]
Representative structure
CASRN: 77226-90-5
MW: >1,000; <1% <1,000
MF: C15H1602(C16H1403)„(C16H1703P)n
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: This polymer with MW >1,000 and <1% low MW components is not amenable to SMILES notation.
Synonyms: Nofia® C03000; Nofia® C06000; Carbonic acid, diphenyl ester, polymer with diphenyl P-methylphosphonate and 4,4'- (1-
methylethylidene)bis[phenol]; FRX C035; FRX CO60
Chemical Considerations: This alternative is a polymer. Poly[phosphonate-co-carbonate] polymers differ in their ratio of polyphosphonate/polycarbonate (m to n)
but would have identical hazard characterizations. The MW of the oligomers are generally >1,000 and are assessed using information contained in the literature
concerning polymer assessment and professional judgment (Boethling et al., 1997). Representative structure drawn to show simplest combination of all feedstock.
Polymeric: Yes
Oligomers: The MW for the Poly[phosphonate-co-carbonate] polymers range between 10,000 and 50,000; with <1% MW <1,000 oligomers expected. Phenoxy
terminated oligomers are anticipated to predominate.
Metabolites, Degradates and Transformation Products: None
Analog: No analog
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: None identified.
Risk Phrases: Not classified by Annex VI Regulation (EC) No 1272/2008 (ESIS, 2011).
Hazard and Risk Assessments: None identified.
4-552
-------
Poly[phosphonate-co-carbonate] CASRN 77226-90-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
220-250 (glass transition temperature)
(Measured)
FRX Polymers, Inc., 2009
The melting points reported cover a
broad range and are anticipated to be
the formulation specific liquid-glass
transition temperature or softening
point.
120 (softening point)
(Measured)
FRX Polymers, Inc., 2009
Boiling Point (°C)
>300 (Estimated)
Professional judgment
Cutoff value used for large, high MW
solid.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; Boethling
et al., 1997
Cutoff value for large, high MW
polymers.
Water Solubility (mg/L)
<10"3 (Estimated)
Professional judgment, Boethling
et al., 1997
Cutoff value for large, high MW non-
ionic polymers.
Insoluble (Measured)
FRX Polymers, Inc., 2009
Nonspecific value provided by
commercial supplier.
Log Kow
No data located.
Flammability (Flash Point)
>450°C (Measured)
FRX Polymers, Inc., 2009
Sufficient details were not available
to assess the quality of this study.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Pyrolysis
No data located.
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
4-553
-------
Poly[phosphonate-co-carbonate] CASRN 77226-90-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
There is no absorption expected for any route of exposure for the neat material. Poor absorption of the low
MW fraction in solution can be expected for all routes. This polymer is large, with a MW >1,000. Based on
professional judgment, it is expected to have limited bioavailability and therefore is not expected to be
readily absorbed, distributed or metabolized in the body.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
No absorption of the neat material is
expected for any route of exposure; poor
absorption of low MW fraction in
solution for all routes.
(Estimated)
Professional judgment
Estimated based on
physical/chemical properties and
limited bioavailability.
Acute Mammalian Toxicity
LOW: Based on experimental LDS0 values >2,000 mg/kg. This compound is also expected to have limited
bioavailability and therefore is of low potential for acute mammalian toxicity.
Acute Lethality
Oral
Rat oral LD50 >2,000 mg/kg
FRX Polymers, Inc., 2011
Conducted according to
Organisation of Economic
Cooperation and Development420;
test substance: FRX
polyphosphonate.
Dermal
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Inhalation
Carcinogenicity
LOW: This polymer is large, with a MW >1,000. Based on expert judgment, it is expected to have few to no
residual monomers. Additionally, crosslinking, swellability, dispersability, reactive functional groups,
inhalation potential, and hindered amine groups are not expected. Therefore, there is low potential for
carcinogenicity based on professional judgment and the polymer assessment literature. No data located.
OncoLogic Results
Limited bioavailability expected;
crosslinking, swellability, dispersability,
reactive functional groups, inhalation
potential, and hindered amine groups are
not expected.
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Carcinogenicity (Rat
and Mouse)
Combined Chronic
Toxicity/
Carcinogenicity
4-554
-------
Poly[phosphonate-co-carbonate] CASRN 77226-90-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Genotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for genotoxicity based on professional judgment.
Gene Mutation in vitro
Gene Mutation in vivo
Chromosomal
Aberrations in vitro
Chromosomal
Aberrations in vivo
DNA Damage and
Repair
Other (Mitotic Gene
Conversion)
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Reproductive Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for reproductive effects based on professional judgment.
Reproduction/
Developmental Toxicity
Screen
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Reproduction and
Fertility Effects
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
4-555
-------
Poly[phosphonate-co-carbonate] CASRN 77226-90-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Developmental Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for developmental effects based on professional judgment.
Reproduction/
Developmental Toxicity
Screen
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Prenatal Development
Postnatal Development
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Neurotoxicity
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability and therefore
has low potential for neurotoxicity based on professional judgment.
Neurotoxicity Screening
Battery (Adult)
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Repeated Dose Effects
LOW: This polymer is large, with a MW >1,000. It is expected to have limited bioavailability; however,
because the MWn is >10,000, there is the possibility of lung overloading if >5% of the particles are in the
respirable range as a result of dust forming operations.
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
This polymer's MWn is >10,000;
potential for irreversible lung damage as
a result of lung overloading
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Skin Sensitization
LOW: Estimated not to have potential for skin sensitization based on expert judgment. No data located.
Skin Sensitization
Not expected to be a skin sensitizer
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
4-556
-------
Poly[phosphonate-co-carbonate] CASRN 77226-90-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Eye Irritation
LOW: Uncertain potential for irritation based on the phenol moieties and professional judgment. No data
located.
Eye Irritation
Uncertain potential for irritation based
on the phenol moieties.
(Estimated)
Professional judgment
Estimated based on cutoff values
for large high MW polymers.
Dermal Irritation
LOW: Uncertain potential for irritation based on the phenol moieties and professional judgment. No data
located.
Dermal Irritation
Uncertain potential for irritation based
on the phenol moieties.
(Estimated)
Professional judgment
Estimated based on cutoff values
for large high MW polymers.
Endocrine Activity
No data located. This polymer is large, with a MW >1,000. Based on expert judgment, it is not expected to
have endocrine activity due to its poor bioavailability and inability to be readily metabolized in the body.
Limited bioavailability expected
(Estimated)
Professional judgment
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
Immunotoxicity
This polymer is large, with a MW >1,000. Based on expert judgment, it is expected to have limited
bioavailability and therefore has low potential for hazard.
Immune System Effects
Limited bioavailability expected
(Estimated)
Professional judgment;
Boethling et al., 1997
Based on cutoff values for large
high MW polymers.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
LOW: Non-ionic polymers with a MW >1,000 that do not contain reactive functional groups and are
comprised of minimal low MW oligomers are estimated to display no effects at saturation (NES). These
polymers display NES because the amount dissolved in water is not anticipated to reach a concentration at
which adverse effects may be expressed. Bioavailability is limited because this chemical cannot be absorbed
through membranes due to large size.
Fish LC50
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Daphnid LCS0
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
4-557
-------
Poly[phosphonate-co-carbonate] CASRN 77226-90-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green Algae ECS0
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Chronic Aquatic Toxicity
LOW: Non-ionic polymers with a MW >1,000 that do not contain reactive functional groups and are
comprised of minimal low MW oligomers are estimated to display NES. These polymers display NES
because the amount dissolved in water is not anticipated to reach a concentration at which adverse effects
may be expressed. Guidance for the assessment of aquatic toxicity hazard leads to a low potential for hazard
for those materials that display NES.
Fish ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will NES.
Daphnid ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
Green Algae ChV
NES
Professional judgment
The large MW, limited
bioavailability and low water
solubility suggest there will be
NES.
ENVIRONMENTAL FATE
Transport
The estimated negligible water solubility and estimated negligible vapor pressure indicate that these polymers
are anticipated to partition predominantly to soil and sediment. The estimated Henry's Law Constant of <10"
8 atm-m3/mole indicates that these are not expected to volatilize from water to the atmosphere. The estimated
Koc of >30,000 indicates that they are not anticipated to migrate from soil into groundwater and have the
potential to adsorb to sediment.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment; Boethling
et al., 1997
High MW polymers are expected to
have low vapor pressure and are not
expected to undergo volatilization.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
Professional judgment; Boethling
et al., 1997
High MW polymers are expected to
adsorb strongly to soil and sediment.
4-558
-------
Poly[phosphonate-co-carbonate] CASRN 77226-90-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Level III Fugacity Model
No data located.
Persistence
VERY HIGH: A very limited fraction of these polymers is expected to have a MW of <1,000; therefore, they
are not anticipated to be assimilated by microorganisms and biodegradation is not expected to be an
important removal process. They are also not expected to be removed by other degradative processes under
environmental conditions because of limited water solubility and limited partitioning to air. They are
expected to partition primarily to sediment and soil, where their estimated half-life is >1 year. The polymers
lack the functional groups that hydrolyze under environmental conditions. These polymers do not contain
chromophores that absorb at wavelengths >290 nm, and therefore, they are not expected to be susceptible to
direct photolysis by sunlight.
Water
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment; Boethling
et al., 1997
Most high MW polymers are
expected to be non-biodegradable.
Volatilization Half-life for
Model River
>1 year (Estimated)
Professional judgment
This high MW polymer is anticipated
to be nonvolatile.
Volatilization Half-life for
Model Lake
>1 year (Estimated)
Professional judgment
This high MW polymer is anticipated
to be nonvolatile.
Soil
Aerobic Biodegradation
Recalcitrant (Estimated)
Professional judgment; Boethling
et al., 1997
High MW polymers are expected to
be non-biodegradable.
Anaerobic
Biodegradation
Recalcitrant (Estimated)
Professional judgment
High MW polymers are expected to
be resistant to removal under anoxic
conditions due to their limited
bioavailability.
Soil Biodegradation with
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
No data located.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Mill, 2000; Professional judgment
The substance does not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
4-559
-------
Poly[phosphonate-co-carbonate] CASRN 77226-90-5
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Hydrolysis
>1 year (Estimated)
Professional judgment
Given the limited solubility estimated
for this material, hydrolysis is not
anticipated to occur to an appreciable
extent.
Environmental Half-Life
>180 days (Estimated)
Professional judgment
The substance has a MW >1,000 and
is not anticipated to be assimilated by
microorganisms. Therefore,
biodegradation is not expected to be
an important removal process. It is
also not expected to be removed by
other degradative processes under
environmental conditions because of
limited water solubility and limited
partitioning to air.
Bioaccumulation
LOW: These polymers are expected to have negligible water solubility and poor bioavailability indicating
that these polymers should have low potential for bioaccumulation.
Fish BCF
<100 (Estimated)
Professional judgment
The substance has a MW >1,000 and
is not anticipated to be assimilated by
aquatic organisms; therefore,
bioconcentration is not expected.
BAF
No data located.
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-560
-------
Boethling, Robert S. and Nabholz, J. Vincent "Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act",
pp. 187-234, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs, Hamilton, John D.
and Sutcliffe, Roger (eds.), (1997) Van Nostrand Reinhold.
CDC (Centers for Disease Control and Prevention). Fourth National Report on Raman Exposure to Environmental Chemicals,
Updated Tables. Department of Health and Human Services 2011. Available at: http://www.cdc.gov/exposurereport/ as of May 10,
2011
European Chemical Substances Information System (ESIS) Classification, Labeling and Packaging of Dangerous Substances Annex
VI to Regulation (EC) No 1272/2008 [Online] available at: http://esis.jrc.ec.europa.eu/home.php as of May 10, 2011.
FRX Polymers, Inc. Material Safety Data Sheet. FRX CO 35 Polyphosphonate Copolymer (CAS 77226-90-5). Chelmsford, MA. 2009.
FRX Polymers, Inc. FRX polyphosphonate: Acute oral toxicity in the rat - fixed dose method. FRX Polymers, Inc. Chelmsford, MA.
Project number 41103591. 2011. (Submitted unpublished study).
Mill, T. (2000) Photoreactions in Surface Waters. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for
Chemicals, Environmental Health Sciences (355-382). Boca Raton: Lewis Publishers.
4-561
-------
Red Phosphorus
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance, including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Red Phosphorus
7723-14-0
L
L
M
L
L
L
L
L
L
L
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-562
-------
Red Phosphorus
A p
p p p pp.
P P
CASRN: 7723-14-0
MW: >1,000 (Estimated)
MF: (P4)n
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: This polymeric form of elemental phosphorous is not amenable to SMILES notation.
Synonyms: Phosphorus; Red amorphous phosphorus; Violet phosphorus; Exolit RP 605; Exolit RP 650; Exolit RP 652; Exolit RP 654; Hishigado; Hishigado AP;
Hishigado CP; Hishigado NP 10; Hishigado PL; Hostaflam RP 602; Hostaflam RP 614; Hostaflam RP 622; Hostaflam RP 654; Novared 120UF; Novared 120UFA;
Novared 120VFA; Novared 140; Novared 280; Novared C 120; Novared F 5; Novaexcel 140; Novaexcel 150; Novaexcel F 5; Novaexcel ST 100; Novaexcel ST 140;
Novaexcel ST 300
Chemical Considerations: This alternative is an inorganic compound. Red phosphorus refers specifically to the crystalline and amorphous forms of elemental
phosphorus which are red in color and consist of random networks of P4-tetrahedron links. This assessment on red phosphorous does not address other allotropes of
elemental phosphorus. White, yellow or black phosphorus do not necessarily have the same properties, fate, or toxicity as red phosphorus. Not all literature entries
identify which allotropic form is discussed (Daubert and Danner, 1989; Kelly, 2006).
Polymeric: The elemental form of red phosphorous produced commercially is an amorphous solid (Brummer et al., 2005).
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: Phosphine (CASRN 7803-51-2), phosphorus oxides, hypophosphorus acid (CASRN 6303-21-5),
phosphoric acid (CASRN 7664-38-2)
Analog: No analog
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: None
Risk Phrases: 11- Highly flammable; 16- Explosive when mixed with oxidizing substances; 52/53- Harmful to aquatic organisms; may cause long-term adverse
effects in the aquatic environment (ESIS, 2011). The risk phrases 52/53 are likely to be appropriate only for the yellow/white allotrope of phosphorus which shares a
CASRN and an EINECS number with red phosphorus and is generally considered more toxic and reactive than red phosphorus.
Hazard and Risk Assessments: Risk assessments completed in 2007 for red phosphorus by the Danish Environmental Protection Agency (Stuer-Lauridsen et al.,
2007) and the Maine Department of Environmental Protection (Maine DEP, 2007).
4-563
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
Sublimation point: 416°C (Measured)
Triple point: 589.5°C at 43.1 atm
O'Neil, 2010
This substance sublimes.
Sublimation point: 431°C (Measured)
Triple point: 590°C
Lide, 2008
>590°C (Measured)
IUCLID, 2000
Inadequate; nonspecific value.
Boiling Point (°C)
Sublimation point: 416°C (Measured)
Triple point: 589.5°C at 43.1 atm
O'Neil, 2010
This substance sublimes.
Sublimation point: 431°C (Measured)
Triple point: 590°C
Lide, 2008
>400°C (Measured)
IUCLID, 2000
Inadequate; appears to be a cutoff
value, and is inconsistent with the
reported ability for red phosphorous
to sublime.
Vapor Pressure (mm Hg)
0.03 at 21 °C (Measured)
Sigma-Aldrich, 2011
Adequate, consistent values, which
span a relatively narrow range.
0.05 at 25°C (Measured)
EPA, 2010
1 at 237°C (Measured)
Spanggord et al., 1983
This value was measured at an
elevated temperature.
<0.075 at 20°C (Measured)
IUCLID, 2000
Inadequate; nonspecific value.
Water Solubility (mg/L)
<10"3 (Estimated)
Professional judgment; EPA,
1999
Based on this chemical's high MW
amorphous structure; cutoff value for
substances that are not anticipated to
display appreciable water solubility
according to the High Production
Volume (HPV) assessment guidance.
Not soluble or insoluble (Measured)
IUCLID, 2000; Stuer-Lauridsen
et al., 2007; Lide, 2008
Qualitative descriptions consistent
with the low water solubility
anticipated for red phosphorous.
Red phosphorus does not dissolve in water
without decomposition (Measured)
Beard, 2000
4-564
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Log K0„
No data located; elemental inorganic
materials are outside the estimation
domain of EPI estimation models.
Flammability (Flash Point)
Red phosphorus ignites in air at
approximately 300°C (Measured)
Diskowski and Hofmann, 2000
Adequate.
Highly flammable (Measured)
Stuer-Lauridsen et al., 2007
Supporting qualitative value.
Ignited by friction, static electricity,
heating or by oxidizing agents (Measured)
EPA, 2010; Clariant, 2010
Reported in a secondary source, no
study details provided.
Explosivity
May explode when exposed to heat or by
chemical reaction with oxidizers. It does
not react until >260°C. (Measured)
Stuer-Lauridsen et al., 2007
Adequate.
Pyrolysis
Releases phosphorus oxides and
phosphorus acids depending on the
available oxygen content while burning.
(Measured)
Leisewitz et al., 2001
Adequate.
pH
5-6 at 100 g/L and 20 C (Measured)
IUCLID, 2000
Red phosphorous slowly hydrolyzes
to phosphoric acid in the presence of
oxygen; therefore the pH of a water
solution would be dependent on both
its age and concentration.
pKa
Professional judgment
The substance does not contain
functional groups that would be
expected to ionize.
4-565
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
HUMAN HEALTH EFFECTS
Toxicokinetics
Red phosphorus is not absorbed through the skin and is expected to have poor absorption from the lung and
the gastrointestinal tract.
Dermal Absorption in vitro
Red phosphorus is practically unabsorbable
HSDB, 2011
Reported in a secondary source;
limited study details provided.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
Not absorbed from the skin, poor
absorption from the lung and
gastrointestinal tract
(Estimated by analogy)
Professional judgment
Based on analogy to similar
compounds.
Not absorbed through the gastrointestinal
tract and, therefore, relatively harmless
when ingested
HSDB, 2011
Reported in a secondary source;
limited study details provided.
Acute Mammalian r
oxicity
LOW: Based on oral LDS0 values >10,000 mg/kg in rats. Several studies reported values that fall within the
criteria range for a Very High hazard designation; however, the allotrope of phosphorous used could not be
verified and the experimental details from the studies could not be assessed. Some studies of red phosphorus
in mixtures with butyl rubber showed toxicity: red phosphorus and butyl rubber (RP-BR) smoke at
concentrations between 0.1-5.3 mg/L caused mild histological changes in the respiratory tract, respiratory
distress, laryngeal lesions and pulmonary congestion in several animal studies (including human) following
exposure. This profile is not assessing mixtures.
Acute Lethality
Oral
Rat, mouse LD50: 11.5 mg/kg
RTECS; Maine DEP, 2007
Reported in secondary sources; the
form of phosphorus is not specified
therefore this value is unverifiable.
Rabbit LD50: 105 mg/kg
RTECS
Reported in a secondary source; this
value is unverifiable.
Cat, dog LD50: 5 mg/kg
RTECS
Reported in a secondary source; this
value is unverifiable.
Rat LD50 >10,000 mg/kg-bw - 15,000
mg/kg-bw
ECHA, 2012; NRC, 1997; Maine
DEP, 2007
Unpublished studies reported in
secondary sources; studies conducted
according to Organisation of
Economic Cooperation and
Development guidelines.
4-566
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Single dosage of 0.66 mg/kg did not
produce mortality in rabbits or guinea pigs.
Cirrhosis-like symptoms were observed.
Maine DEP, 2007
Reported in secondary sources.
Inhalation
Rat, rabbit LCLo = 0.15 mg/L (150 mg/irf)
Cardiac: EKG changes not diagnostic of
specified effects; Liver: fatty liver,
degeneration; Kidney/ureter/bladder: other
changes.
RTECS
Reported in a secondary source.
Rat LC50 (1 -hour exposures): 2.32-4.3
mg/L (2,320 - 4,300 mg/m3)
NRC, 1997; Maine DEP, 2007
Reported in secondary sources.
Sprague Dawley rats and Beagle dogs
exposed to RP-BR and black powder
mixture at 1.128-1.882 mg/L (1,128-1,882
mg/m3).
Exposure: 60-240 minutes (rats) or 30-240
minutes (dogs)
EPA, 2010
Adequate; however, study details are
not available; reported in a secondary
source.
Respiratory distress (leading to prostration
and death in some cases). Transient
hypoactivity, salivation, conjunctivitis.
4-567
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sprague Dawley rats exposed to an aerosol
generated by combustion of RP/BR for 1 or
4 hours.
1 hour exposures: 3.15, 4.33, 5.36 or 8.46
mg/L (3,150, 4,330, 5,360, 8,460 mg/m3)
4 hour exposure: 1.53 mg/L (1,530 mg/m3)
EPA, 2010
Reported in a secondary source.
1-hour LC50 = 4.597 mg/L (4,597 mg/m3)
Slightly-moderately deformed epiglottis
(blunted tip or partially to virtually absent,
ulceration, edema); laryngeal lesions
(severe ulceration and edema with fibrin
substance on the mucosal surface of the
ventral larynx); moderate-severe
pulmonary congestion, edema,
hemorrhage.
Porton Wistar rats exposed to combustion
aerosols of red phosphorus at 3.1 or 3.2
mg/L (3,100 or 3,200 mg/m3) for 30
minutes.
EPA, 2010
Reported in a secondary source.
Laryngeal inflammation, blood in tracheal
lumen, severe pulmonary congestion and
edema, hepatic congestion.
4-568
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Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Rats, mice, and rabbits exposed to
unformulated pure red phosphorus smoke
as ortho-phosphoric acid for 1 hour.
Rat 1-hour LC50 =1.217 mg/L (1,217
mg/irf as phosphorus)
Mouse 1-hour LC50 = 0.856 mg/L (856
mg/irf as phosphorus)
Rabbit 1-hour LC50 = 5.337 mg/L (5,337
mg/irf as phosphorus)
EPA, 2010
Reported in a secondary source;
inhalation toxicity to the red
phosphorous smoke may be the result
of exposure to the phosphoric acid
that is generated by combustion of the
smoke generating device used to
make the aerosol.
Death, necrosis and inflammation in the
larynx and trachea, pulmonary congestion,
hemorrhage, edema, pneumonitis,
congestion in liver and kidney (rats, mice
guinea pig), cortical necrosis in kidney
(mice).
Guinea pigs exposed to RP-BR smoke at
120-2.277 mg/L (2,277 mg/m3) for 5-150
minutes.
EPA, 2010
Reported in a secondary source.
Death, respiratory distress
Mild histological changes in the respiratory
tract of rabbits and rats (abnormalities in
the larynx and trachea, alveolitis, frank
pneumonia) exposed to pyrotechnic
mixtures containing red phosphorus.
Marrs, 1984
Adequate. Histological effects seem
to be a result of orthophosphoric acid
aerosol.
Reversible symptoms of respiratory
distress in workers exposed to 0.1-0.7
mg/L (100-700 mg/m3) red phosphorus
smoke for <15 minutes.
EPA, 2010
Reported in a secondary source.
4-569
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Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Carcinogenicity
LOW: Estimated not to have potential for carcinogenicity based on expert judgment. Red phosphorus is not
listed as a known carcinogen by the International Agency for Research on Cancer (IARC), National
Toxicology Program, EPA or California Proposition 65; however, no long-term carcinogenicity studies were
located for red phosphorus smoke.
OncoLogic Results
Low potential for carcinogenicity.
(Estimated)
Expert judgment
Estimated based on expert judgment.
Carcinogenicity (Rat and
Mouse)
Combined Chronic
Toxicity/ Carcinogenicity
Genotoxicity
MODERATE: Uncertain potential for mutagenicity based on expert judgment. There is a lack of gene
mutation data, genotoxic effects cannot be ruled out. Negative results for both chromosomal aberrations and
gene mutation assays are required for a categorization of Low.
Gene Mutation in vitro
Uncertain potential for mutagenicity.
(Estimated)
Expert judgment
Estimated based on expert judgment.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
No data located.
Chromosomal
Aberrations in vivo
Micronucleus test in rat bone marrow
polychromatic and normachromatic red
blood cells.
Weak clastogenic effect in both bone
marrow and red blood cells following
exposure to 1,000 mg/irf for 2 weeks.
NRC, 1997; Maine DEP, 2007
Reported in secondary sources.
DNA Damage and Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
Reproductive Effects
LOW: Estimated not to have potential for reproductive effects based on expert judgment. No adequate data
located.
Reproduction/
Developmental Toxicity
Screen
Low potential for reproductive effects.
(Estimated)
Expert judgment
Estimated based on expert judgment.
4-570
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
No data located.
Reproduction and
Fertility Effects
Sprague Dawley rats exposed to RP-BR
smoke at 132 or 1,186 mg/irf 5 days/week
for 10 weeks.
No dominant lethal or single generation
reproductive effects. No effects on
testicular toxicity; however, the fixative
used to judge histopathology was not clear.
NOAEL = not established
NRC, 1997
Reported in a secondary source;
limited details provided on specific
reproductive/fertility parameters
measured in the study.
Developmental Effects
LOW: Estimated not to have potential for developmental effects based on expert judgment. No adequate
experimental data were located.
Reproduction/
Developmental Toxicity
Screen
Low potential for developmental effects.
(Estimated)
Expert judgment
Estimated based on expert judgment.
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
Pregnant Sprague Dawley rats exposed to
RP-BR smoke at 0.132 or 1.183 mg/L (132
or 1,186 mg/m3)
5 days/week on gestation days 6-15.
No dose-related increases in malformations
or variations.
In a single-generation using same exposure
concentrations, decrease in birth weight on
PND lfor rats in the 1.183 mg/L group
(recovered on PDNs 14 and 21).
NRC, 1997
Reported in a secondary source;
developmental endpoints were not
fully evaluated.
Prenatal Development
No data located.
Postnatal Development
No data located.
4-571
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Neurotoxicity
LOW: Estimated not to have potential for neurotoxicity based on expert judgment. Exposure to red
phosphorus/butyl rubber (RB-BR) aerosols increased locomotor activity in rats with incomplete recovery
post-exposure.
Neurotoxicity Screening
Battery (Adult)
Low potential for neurotoxicity.
(Estimated)
Expert judgment
Estimated based on expert judgment.
Sprague Dawley rats exposed to RP-BR
aerosols at 400-1,200 mg/m3 2.25
hour/day, 4 days/week for 4 weeks;
increased motor activity with incomplete
recovery after 2 weeks (M).
LOAEL = 0.4 mg/L
NRC, 1997
Reported in a secondary source;
limited details provided.
Developmental
Neurotoxicity
Phosphorus is classified as a potential
developmental neurotoxicant on the Clean
Production Action Red List.
Grandjean and Landrigan, 2006
It is unclear if the data pertain to red
phosphorus or white phosphorus,
which is more toxic.
Repeated Dose Effects
LOW: Estimated not to have potential for repeated dose effects based on professional judgment.
Experimental toxicity values located are based on inhalation exposure to a pyrotechnic mixture of red
phosphorus- and red phosphorus/butyl rubber (RP-BR) smoke and not solely red phosphorous; reported
toxicity in studies using the RP-BR mixtures as the test substance cannot be specifically attributed to red
phosphorus.
Low potential for repeated dose effects.
(Estimated)
Professional judgment
Estimated based on professional
judgment.
4-572
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Female Portan-strain mice, female Wistar
rats and female Dunkin-Hartley guinea
pigs exposed to a pyrotechnic mixture of
red phosphorus smoke
1 hour/day, 5 days/week for 180 or 200
exposures.
Concentrations: 15 and 130 mg/m3 (0.015-
0.13 mg/L)
Over 50% of mice died in each dose group;
80% of rats died in the high dose group;
38% of guinea pigs died in the low dose
group and all died during or immediately
after exposure to the high dose (death
appeared due to pulmonary congestion).
Depressed growth at both doses (mice,
rats).
Increased incidence of aggregates of
macrophages containing granules in the
lungs (mice); severe congestion in the
lungs (guinea pigs), though no dose-related
changes in rat lungs.
Other findings: renal disease (mice, rats,
guinea pigs), chronic interstitial nephritis
(mice, guinea pigs), nephropathy (rats).
LOAEL = 0.015 mg/L
Marrs et al., 1989
Adequate, guideline study; the test
substance for this study was a
pyrotechnic mixture of red
phosphorus smoke; the toxicity
reported cannot be attributed to any
one component of the mixture
including red phosphorus.
4-573
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Rats (60/group) were exposed to RP-BR
smoke at 0, 22, and 165 mg/m3 (0.022,
0.165 mg/L) for 12 weeks (8 minutes/day,
5 days/week).
Reddening and swelling of the eyelids that
subsided at study termination.
NRC, 1997
Reported in a secondary source;
limited study details provided.
4-574
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Rats (Sprague Dawley and Fisher 344),
mice (Swiss and A-strain), guinea pigs and
rabbits were exposed to 8-43 mg/nr (low
exposure) or 80-288 mg/irf (high
exposure) RP-BR 5 days/week for 12
weeks.
Daily average exposures were 22 and 165
mg/irf (0.022 and 0.165 mg/L) for low and
high concentrations, respectively.
Increased breathing rate (rats); histological
changes in the lungs, trachea, upper
respiratory tract and other organs (rats,
mice). Authors concluded that these
changes were not related to the exposure
(sporadic, not unlike what was observed in
controls).
Morphological lesions in the lung, trachea,
nasal turbines, liver, kidney, heart, testes,
ovaries, urinary bladder and other organs,
however these changes were also seen in
controls (guinea pigs, rabbits).
NOAEL: 0.165 mg/L (165 mg/m3)
LOAEL: not established as highest
concentration tested did not produce
adverse effects.
NRC, 1997
Reported in a secondary source.
4-575
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sprague-Dawley rats were exposed to RP-
BR aerosols at 400-1,200 mg/m3 for 2.25
hour/day, 4 days/week for 4 weeks.
NRC, 1997
Reported in a secondary source;
limited study details provided.
Wheezing, labored breathing (males at high
dose); deceased body weight and food
consumption that returned to normal during
14-day recovery period;
Pulmonary edema (resolved during
recovery); terminal bronchial fibrosis (400
mg/irf) that did not exhibit recovery during
the observation period.
LOAEL = 0.4 mg/L (based on terminal
incidences of bronchial fibrosis)
Sprague-Dawley (males only) exposed to
RP-BR smoke at 50, 180, 300, 750 and
1,200 mg/m3 for 13 weeks.
NRC, 1997
Reported in a secondary source.
Most of the animals died during the first 2
weeks of exposure. Decrease in body
weight (750 and 1,200 mg/m3); 10.8%
spontaneous death or in moribund state
(1,200 mg/irf): congestion/hemorrhage in
lungs; terminal bronchiolar fibrosis and
erosions of the laryngeal mucosa with
deposition of fibrin on the surface. No
deaths at 300 mg/irf or less.
NOAEL: 0.05 mg/L (50 mg/m3)
LOAEL: 0.18 mg/L (180 mg/m3) based on
incidence of terminal bronchiolar fibrosis
4-576
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sprague Dawley rats exposed to RP-BR
aerosols at 400-1,200 mg/m3 2.25
hours/day, 4 days/week for 4 weeks.
NRC, 1997
Reported in a secondary source;
limited study details provided.
Decreased cholesterol and blood urea
nitrogen (BUN) at (400 mg/irf. female;
750 mg/irf. male). Increased triglycerides
(400 mg/irf. female).
Female rats exposed to 1,000 mg/irf
(1 mg/L) had significant decreases in
cholesterol and triglycerides and those
exposed to 750 mg/irf (0.75 mg/L) had
decreased BUN after the recovery period.
LOAEL = 0.4 mg/L (based on decreased
cholesterol and BUN in female rats)
Immune System Effects
Low potential for immunotoxicity
(Estimated)
Expert judgment
Estimated based on expert judgment.
Sprague Dawley rats exposed to RP-BR
aerosols at 400-1,200 mg/m3 2.25
hours/day, 4 days/week for 4 weeks.
NRC, 1997
Reported in a secondary source;
limited study details provided.
Decreased white blood cell count in males
and increased blood lymphocytes in
females at 750 mg/nr\
Decreased activity of plasma membrane-
associated extoenzyme 5"-nucleotidase in
macrophages at 750 mg/nr\ Decreased
alkaline phosphatase in macrophages after
14-day recovery period (male).
4-577
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sprague Dawley rats exposed to RP-BR
aerosols 2.25 hour/day, 4 days/week for 13
weeks.
NRC, 1997
Reported in a secondary source;
limited study details provided.
Increased ATP levels at 300 mg/nr:
decreased activity of 5"-nucleotidase at 750
mg/nr\
Skin Sensitization
LOW: Based on experimental data showing a lack of sensitization in guinea pigs.
Skin Sensitization
Not sensitizing, guinea pigs
Maine DEP, 2007
Reported in a secondary source, data
are for red phosphorus; limited study
details provided.
Respiratory Sensitization
No data located.
Respiratory Sensitization
No data located.
Eye Irritation
MODERATE: Exposure to red phosphorus may cause corneal injury.
Eye Irritation
May cause corneal injury, rabbit
(development of numerous fine blood
vessels, dilation)
HSDB, 2011
Reported in a secondary source.
Conjunctivitis, rats (1,813 mg/nr' for 180
minutes or 1,128 mg/irf for 60 minutes)
and dogs (1,882 mg/nr' for 240 minutes)
NRC, 1997; EPA, 2010
Reported in secondary sources.
Exposure to red phosphorus smoke.
Symptoms resolved within 3 days post-
exposure.
Negative, rabbit (100 mg)
NRC, 1997
Reported in a secondary source.
Reversible irritation of the eyes and
mucous membranes in workers exposed to
0.1-0.7 mg/L (100-700 mg/m3) red
phosphorus smoke for <15 minutes.
EPA, 2010
Reported in a secondary source.
Dermal Irritation
MODERATE: Prolonged contact with red phosphorus may cause skin irritation. Red phosphorus was not a
skin irritant in guinea pigs.
Dermal Irritation
Negative, guinea pigs (0.5 g on application
site)
NRC, 1997
Reported in a secondary source.
4-578
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Severe irritation, rabbits
Application of RP-BR residue
NRC, 1997
Reported in a secondary source;
substance tested was a commercial
material comprised of a combination
of red phosphorus with butyl/rubber.
Prolonged or repeated contact may cause
skin irritation
Maine DEP, 2007
Reported in a secondary source;
information originally reported in a
MSDS for red phosphorus; no study
details were provided.
Endocrine Activity
Estimated not to have potential for endocrine activity based on expert jud
gment.
Low potential for endocrine activity
(Estimated)
Expert judgment
Estimated based on expert judgment.
Immunotoxicity
Estimated not to have potential for immunotoxicity based on expert judgment. Exposure to red
phosphorus/butyl rubber (RP-BR) aerosols may cause decreases in white blood cell and lymphocyte counts,
decreased activity of 5'nucleotides in macrophages, and increased ATP activity.
Immune System Effects
Low potential for immunotoxicity
(Estimated)
Expert judgment
Estimated based on expert judgment.
Sprague Dawley rats exposed to RP-BR
aerosols at 400-1,200 mg/m3 2.25
hours/day, 4 days/week for 4 weeks.
Decreased white blood cell count in males
and increased blood lymphocytes in
females at 750 mg/nr\
Decreased activity of plasma membrane-
associated extoenzyme 5"-nucleotidase in
macrophages at 750 mg/nr\ Decreased
alkaline phosphatase in macrophages after
14-day recovery period (male).
NRC, 1997
Reported in a secondary source;
limited study details provided.
4-579
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sprague Dawley rats exposed to RP-BR
aerosols 2.25 hour/day, 4 days/week for 13
weeks.
NRC, 1997
Reported in a secondary source;
limited study details provided.
Increased ATP levels at 300 mg/nr:
decreased activity of 5"-nucleotidase at 750
mg/nr\
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
LOW: Experimental LCS0 values are higher than the water solubility of the test substance; no effects at
saturation (NES) can be assigned.
Fish LC50
96-hour LC50= 33 mg/L (Experimental)
ERMA
Reported in a secondary source;
limited study details provided. Effect
level higher than the water solubility
therefore NES can be predicted.
Daphnid LCS0
LC50 = 10.5 mg/L (Experimental)
ERMA
Reported in a secondary source;
limited study details provided. Effect
level higher than the water solubility
therefore NES can be predicted.
48-hour LC5o= 1,051 mg/L (Experimental)
Maine DEP, 2007
Reported in a secondary source;
limited study details provided. Effect
level higher than the water solubility
therefore NES can be predicted.
Green Algae ECS0
ECb50 = 9.5 mg/L (Experimental)
ERMA
Reported in a secondary source;
limited study details provided. It is
not clear which allotrope of
phosphorous was used in this study.
Effect level higher than the water
solubility therefore NES can be
predicted.
4-580
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Chronic Aquatic Toxicity
LOW: Experimental toxicity value is higher than the water solubility of the test substance; NES can be
assigned.
Fish ChV
Pimephcdespromelas 30-day NOEC) =
0.007 mg/L (0.7 (ig/L) (Experimental)
ERMA
Reported in a secondary source;
limited study details provided. Effect
level higher than the water solubility
therefore NES can be predicted.
Daphnid ChV
No data located.
Green Algae ChV
No data located.
ENVIRONMENTAL FATE
Transport
The low water solubility, relatively low vapor pressure and estimated Koc of >30,000 indicate that red
phosphorus will be relatively immobile in the environment and will partition primarily to soil and sediment.
Henry's Law Constant
(atm-m3/mole)
This inorganic compound is not
amenable to available estimation
methods.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
Professional judgment; 2004
Cutoff value for non-mobile
compounds.This inorganic compound
is not amenable to available
estimation methods.
Level III Fugacity Model
Not all input parameters for this
model were available for it to be run
for this inorganic compound.
Persistence
HIGH: Red phosphorus is estimated to display high persistence in the environment. Elemental red
phosphorus is relatively nonreactive under typical environmental conditions. Measured data indicate that red
phosphorus will slowly undergo hydrolysis under environmental conditions (<3% in 4 months) and will
eventually convert to phosphine and hypophosphorous acid. Subsequent oxidation of these hydrolysis
products will lead to the formation of phosphoric oxides and acids.
Water
Aerobic Biodegradation
No data located; elemental inorganic
materials are outside the domain of
the EPI estimation models.
Volatilization Half-life for
Model River
No data located.
4-581
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Volatilization Half-life for
Model Lake
No data located.
Soil
Aerobic Biodegradation
No data located.
Anaerobic
Biodegradation
No data located.
Soil Biodegradation w/
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
No data located.
Reactivity
Photolysis
Not a significant fate process (Estimated)
Professional judgment
The substance does not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
Hydrolysis
0.7% after 24 hours,
3.7% after 700 hours
(Measured)
Walz and Beard, 2000
These nonguideline studies indicate
that hydrolysis will occur slowly
under environmental conditions.
Red phosphorus conversion rate of 2.7%
over 4 months at room temperature
(Measured)
Walz and Beard, 2000; Stuer-
Lauridsen et al., 2007
Red phosphorus does not dissolve readily
in water; atoms on the surface of the
amorphous solid react slowly with water
initially forming phosphine (7803-51-2)
and hypophosphorous acid (6303-21-5).
(Measured)
Leisewitz et al., 2001
Environmental Half-life
No data located.
4-582
-------
Red Phosphorus CASRN 7723-14-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Bioaccumulation
LOW: Due to the large size, water insolubility and amorphous nature of this inorganic substance, elemental
phosphorous has a low potential for bioconcentration or bioaccumulation as it is unlikely to pass through
biological membranes.
Fish BCF
<100 (Estimated)
Professional judgment
Red phosphorus has very low water
solubility. It is also a large,
amorphous solid and is unlikely to
pass through biological membranes.
BAF
No data located.
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-583
-------
Beard, A. Exolit'W Red Phosphorus - Environmental Information. Clariant GmbH. Hiirth-Knapsack, Germany. 2000.
Brummer, J.; Keely, J.; Munday, T. Kirk-Othmer Encyclopedia of Chemical Technology. Phosphorus. Online Posting Date: August
19, 2005.
Clariant GmbH. Safety Precautions in Handling Red Phosphorus Powder Grades. Clariant Produkte (Deutschland) GmbH BU
Additives - BL Flame Retardants. Huerth-Knapsack, Germany. 2010.
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
June 10,2011).
Daubert, T.; Danner, R. Physical and thermodynamic properties of pure chemicals: data compilation; design institute for physical
property data. American Institute of chemical Engineers. New York, NY: Hemisphere Pub. Corp. 1989.
Diskowski, H.; Hofmann, T. Ullmann's Encyclopedia of Industrial Chemistry. Phosphorus. New York, NY: John Wiley & Sons.
Online Posting Date: June 15, 2000.
ECHA (European Chemicals Agency). Information on registered substances. 2012. http://apps.echa.europa.eu/registered/registered-
sub.aspx.
EPA. 2004. The Pollution Prevention (P2) Framework, EPA-748-B-03-001. Office of Pollution Prevention and Toxics 7403M, U.S.
Environmental Protection Agency, Washington, DC. 20460. October 2003 version updated in January 2004. Latest version available
at http://www.epa.gov/opptintr/newchems/pubs/sustainable/p2frame-june05a2.pdf
EPA (U.S. Environmental Protection Agency). Proposed acute exposure guideline levels (AEGLs) for red phosphorus. U.S.
Environmental Protection Agency, Office of Pollution Pesticides and Toxins (OPPT). 2010.
http://www.epa.gov/oppt/aegl/pubs/red phosphorus proposed mar 2010 vl.pdf
EPA (U.S. Environmental Protection Agency). Sustainable Futures. UsingNonCancer Screening within the SF Initiative. U.S.
Environmental Protection Agency: Washington D.C. available at: http://www.epa.gOv/opptintr/sf/pubs/noncan-screen.htm#svstemic
as of February 09, 2011a.
4-584
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[HPV Assessment Guidance] EPA (U.S. Environmental Protection Agency). Determining the Adequacy of Existing Data. U.S.
Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadeqfn.pdf
EPI (EPIWIN EPISUITE) Estimation Program Interface for Windows, Version 4.0. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
ERMA (Environmental Risk Management Authority). Phosphorus, amorphous (red) New Zealand, http://www.ermanz.govt.nz/search-
databases/Pages/ccid-details.aspx?SubstanceID= 1732. (Accessed on March 25, 2011)
ESIS (European chemical Substances Information System). Classification, labeling and packaging of dangerous substances annex VI
to regulation (EC) No 1272/2008. [Online] http://ecb.irc.ec.europa.eu/esis/index.php?PGM=cla (accessed on June 30, 2011).
IUCLID (International Uniform Chemical Information Database). Dataset for phosphorus. European Commission Joint Research
Centre. 2000. http://ecb.irc.ec.europa.eu/iuclid-datasheet/7723140.pdf
Grandjean, P.; Landrigan, P.J. Developmental neurotoxicity of industrial chemicals. Lancet 2006, 368:2167-2178.
HSDB (Hazardous Substances Data Bank). Phosphorus, elemental (CASRN: 7723-14-0) National Library of Medicine.
http://toxnet.nlm.nih.gOv/cgi-bin/sis/search/f7./ternp/~vrSOqf:l. (Accessed on March 19, 2011)
Kelly, P. Encyclopedia of inorganic chemistry. Phosphorus: Inorganic Chemistry. New York, NY: John Wiley & Sons. Online
Posting Date: March 15, 2006.
Leisewitz, A., Kruse, H.; Schramm. E. Substituting environmentally relevant flame retardants: assessment fundamentals.
Results and summary overview. June 2001.
http://www.oekorecherche.de/english/berichte/volltext/Flame%20Retardants.pdf.
Lide, D.R, ed. CRC Handbook of Chemistry and Physics, 88th edition. Boca Raton, FL: CRC Press Taylor & Francis, 2008.
Maine DEP. Decabromodiphenyl ether flame retardant in plastic pallets. A safer alternatives assessment. Prepared for: Maine
Department of Environmental Protection. By: Pure Strategies, Inc. Gloucester, MA, 2007.
4-585
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Marrs TC. Histological changes produced by exposure of rabbits and rats to smokes produced from red phosphorus, Toxicol. Lett.
1984,21:141-146.
Marrs, T.C., Colgrave, H.; Edginton, J.; et al. The toxicity of a red phosphorus smoke after repeated inhalation. J. Haz. Mat. 1989,
22:269-282.
O'Neil, M., ed. e-Merck Index. 14th ed. Basic Search. Whitehouse Station, NJ: Merck & Co., Inc. 2010.
https://themerckindex.cambridgesoft.com/TheMerckIndex/index.asp as of July 1, 2011.
NRC (National Research Council). Toxicity of military smokes and obscurants, Volume 1. Committee on Toxicology, Commission on
Life Sciences, National Research Council. 1997. http://www.nap.edu/catalog/5582.html.
RTECS. Registry of Toxic Effects of Chemical Substances (RTECS). National Institute for Occupational Safety and Health (NIOSH).
Spanggord, R.; Podoll, R.; Rewick, R.; et al. Environmental fate of white phosphorus/felt and red phosphorus/butyl rubber military
screening smokes. Phase 1. Literature review. Menlo Park, CA: SRI International 1983.
Sigma-Aldrich. Material Safety Data Sheet (MSDS) for Phosphorus, red. http://www.sigmaaldrich.com/ (accessed on June 30, 2011).
Stuer-Lauridsen, F.; Cohr, K-H.; Andersen, T. Health and environmental assessment of alternatives to Deca-BDE in electrical and
electronic equipment. Danish Environmental Protection Agency. February 2007. http://www2.mst.dk/Udgiv/publications/2007/978-
87-7052-35 l-6/pdf/978-87-7052-3 52-3.pdf.
Walz, R.; Beard, A. Chemical Behaviour of Red Phosphorus in Water. Clariant GmbH. Sulzbach, Germany. 2000.
4-586
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Resorcinol Bis-Diphenylphosphate; RDP
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance, including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
1 The highest hazard designation of any of the oligomers with MW <1,000.
§ Based on analogy to experimental data for a structural similar compound.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Resorcinol Bis-Diphenylphosphate; RDP
125997-21-9
L
L
L
L
L
VL
VH
VH
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-587
-------
Resorcinol Bis-Diphenylphosphate; RDP
9
O0T°^Cr°1
6
n= 1-7
CASRN: 125997-21-9
MW:
574.46 (n=l; CASRN 57583-54-7);
822.64 (n=2; CASRN 98165-92-5)
MF:
C3oH2408P2(n=l; CASRN 57583-54-7);
C42H33012P3 (n=2; CASRN 98165-92-5)
Physical Forms:
Neat: Liquid
Use: Flame retardant
SMILES: clcccccl0P(0c2ccccc2)(=0)0c3cccc(c3)0P(=0)(0c4ccccc4)0c5ccccc5 (CASRN 57583-54-7; n=l);
c 1 (0P(=0)(0c2ccccc2)0c2ccccc2)cc(0P(=0)(0c2cc(0P(=0)(0c3ccccc3)0c3ccccc3)ccc2)0c2ccccc2)ccc 1 (CASRN 98165-92-5; n=2)
Synonyms: Phosphoric trichloride, polymer with 1,3-benzenediol, phenyl ester; Fyrolflex RDP; Plamtar-RDP; RBBPP; Reofos RDP; Resorcinol bis (biphenyl
phosphate); Phosphoric acid, 1,3-phenylene tetraphenyl ester; Phosphorous oxychloride, reaction product with resorcinol and phenol; Resorcinol bis-
diphenylphosphate; Tetraphenyl resorcinol diphosphate
Chemical Considerations: This alternative is a polymer; the n=l and n=2 oligomers are those with a MW <1,000. EPI v4.0 was used to estimate physical/chemical
and environmental fate values due to an absence of experimental data. The higher MW oligomers are anticipated to behave similar to the oligomer where n=2.
The material used by industry for flame retardant applications is most likely the polymeric material with CAS number 125997-21-9, although the CAS number for the
discrete organic where n=l, 57583-54-7 (Phosphoric acid, P,P'-1,3-phenylene P,P,P',P'-tetraphenyl ester), has been used interchangeably with 125997-21-9 in the
publicly available literature.
4-588
-------
Polymeric: Yes
Oligomers: The major component of this polymer is the oligomer where n=l, which typically comprises 95-99% of the mixture (EPA, 2010a). The balance is made
up of higher oligomers (n=2, 3, etc.) and a triphenyl phosphate impurity (1-5% w/w).
Metabolites, Degradates and Transformation Products: Hydroxy-RDP, dihydroxy-RDP, resorcinol diphenyl phosphate, and hydroxyl-resorcinol diphenyl
phosphate, resorcinol (108-46-3), resorcinol conjugates, resorcinyl glucuronide and resorcinyl sulfate were identified as metabolites (Freudenthal et al., 2000).
Environmental degradation of RDP has been demonstrated in experimental studies (IUCLID, 2001); however the degradates have not been identified. Degradation of
RDP by sequential dephosphorylation could produce phenol (CASRN 108-95-2), diphenyl phosphate (CASRN 838-85-7), or resorcinol (CASRN 108-46-3). The
importance of dephosphorylation relative to possible competing pathways has not been demonstrated in a published study.
Analog: Aryl phosphates and other confidential analogs
Endpoint(s) using analog values: Carcinogenicity and neurotoxicity
Analog Structure: The analogs are structural classes or confidential and cannot
be suitably represented here.
Structural Alerts: Organophosphates, neurotoxicity (EPA, 2011a).
Risk Phrases: Not classified by Annex I Directive 67/548/European Economic Community (EEC) & IUCLID (Pakalin et al., 2007).
Hazard and Risk Assessments: An assessment was completed for resorcinol bis-diphenylphosphate by Washington State in 2006 (Laflamme, 2006).
4-589
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
-12 (Measured)
AkzoNobel, 1998; Bayer, 2002;
Weil, 2001; Supresta, 2011
The reported values are for the pour
point of the commercial polymeric
mixture, which is a liquid at room
temperatures.
-13 (Measured)
Great Lakes, 2003
-16.7 (Measured)
AkzoNobel, 1998
Boiling Point (°C)
300 (Measured)
UBA, 2001a, 2003
Decomposition may occur before the
boiling point is reached.
>300 (Measured)
AkzoNobel, 1998; Bayer, 2002;
UBA, 2001b; Supresta, 2011
>300 decomposes (Measured)
UBA, 2001b; Great Lakes, 2003
370 decomposes (Measured)
Supresta, 2011
>400 decomposes (Measured)
Bayer, 2002
38 at 138 Pa (Measured)
UBA, 2001a; 2001b; 2003
Vapor Pressure (mm Hg)
1.9xl0"5 at 20°C (Measured)
EPA, 2010
The reported experimental data is for
the commercial polymeric mixture.
0.007 at 38°C (Measured)
UBA, 2001a, 2001b, 2003
0.28 (Measured)
Supresta, 2011
<0.075 at 38°C (Measured)
IUCLID, 2001
Water Solubility (mg/L)
1.05 mg/L at 20°C (Measured)
EPA, 2010a
The reported experimental data is for
the commercial polymeric mixture.
Log Kow
4.93 (Measured)
EPA, 2010a; Wildlife
International Ltd., 2003
The reported experimental data is for
the commercial polymeric mixture.
4.9 (Measured)
ICL Industrial, 2009
Flammability (Flash Point)
>230°C (Measured)
ICL Industrial, 2009
Adequate.
>240°C (Measured)
Chang Chun, no date
302°C (Measured)
Bayer, 2002
Explosivity
Not explosive (Measured)
IUCLID, 2001; ICL Industrial,
2009
Insufficient study details to assess the
quality of this value.
Pyrolysis
No data located.
4-590
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
pH
Not applicable
Professional judgment
This polymer does not contain
functional groups that would be
expected to ionize.
pKa
Not applicable
Professional judgment
This polymer does not contain
functional groups that would be
expected to ionize.
HUMAN HEALTH EFF
ECTS
Toxicokinetics
Resorcinol bis-diphenylphosphate was readily absorbed via the oral route and was absorbed to a lesser
extent following dermal exposure. Metabolism was extensive with metabolites excreted in feces, urine, and
in expired air as C02.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
Studies were conducted on rats, mice and
monkeys following exposure to
radiolabeled tetraphenyl resorcinol
diphosphate (purity: 99%) via
intravenous injection, oral, inhalation,
and dermal routes of exposure.
Blood, urine and feces were collected for
approximately 7 days and metabolites
were isolated and characterized; the
brain, mesenteric fat, kidneys, liver,
lungs, tests/ovaries and spleen were
collected from rats at time of necropsy.
RDP was absorbed and was extensively
metabolized; Metabolism was consistent
between species, sexes, and individual
animals; Excretion occurred primarily in
the feces and then urine.
The major metabolites in the feces
included resorcinol diphenylphosphate
Freudenthal et al., 2000; UK
Environment Agency, 2009
Nonguideline study.
4-591
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
(RDP half ester), hydroxy-RDP half
ester, dihydroxy-RDP, and hydroxy-
RDP; Metabolites found in urine
included resorcinol, resorcinyl
glucuronide, and resorcinyl sulfate.
Rats and mice were administered a single
intravenous dose of 100 mg/kg
radiolabeled tetraphenyl resorcinol
diphosphate (purity: 99%).
Freudenthal et al., 2000; UK
Environment Agency, 2009
Nonguideline study.
In rats, 13%, 45%, and 7% of the
administered intravenous dose was
excreted in urine, feces, and expired air
(as C02), respectively, 7 days after
exposure.
In monkeys, 24% and 26% was excreted
in urine and feces, respectively; expired
air was not measured.
There were no data reported for mice
following intravenous exposure.
4-592
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Rats were exposed to radiolabeled
tetraphenyl resorcinol diphosphate
(purity: 99%) via a single oral gavage
dose of 100 mg/kg.
Freudenthal et al., 2000; UK
Environment Agency, 2009
Nonguideline study.
83% of the administered dose of RDP
was absorbed; 80% of the absorbed
radiolabeled dose was excreted in the
feces as metabolites, 7% was excreted in
the urine and 5% was excreted as C02 in
expired air.
Un-metabolized RDP was found in the
feces following oral exposure, indicating
that some of the administered oral dose
was not absorbed through the
gastrointestinal route.
Rats and monkeys were administered a
dermal dose of 100 mg/kg radiolabeled
14C-tetraphenyl resorcinol diphosphate
(purity: 99%) for 6 hours.
Freudenthal et al., 2000; UK
Environment Agency, 2009
Nonguideline study.
20% of RDP was absorbed in the
systemic circulation in rats following the
six-hour exposure and <10% was
absorbed in monkeys.
7 days post-exposure, rats eliminated 7,
32, and 1% of administered dose in the
urine, feces, and expired air,
respectively.
1% of the administered dose was
eliminated in expired air in monkeys
after 7 days; the remaining absorbed
dose was excreted by day 28.
4-593
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Rats were exposed to radiolabeled
tetraphenyl resorcinol diphosphate via
nose-only inhalation for 6 hours at a
target delivered dose of 100 mg/kg
60% of RDP was excreted in the feces in
males and 52% in females following
exposure.
10% in males and 7% in females was
excreted in the urine.
Freudenthal et al., 2000; UK
Environment Agency, 2009
Nonguideline study; doses are not
reported in standard mg/L units; the
authors state that actual retained
dose in the lung cannot be measured
accurately for the inhalation study.
Acute Mammalian Toxicity
LOW: Based on an oral LDS0 >5,000 mg/kg-bw and a dermal LDS0 >2,000 mg/kg-bw in rats. The acute
inhalation study in rats produced no deaths at the highest dose tested. The LCS0 of >4.14 mg/L could not be
used to evaluate the hazard designation because it is uncertain at which dose the LCS0 would occur; the
criteria threshold for Low is 5 mg/L for mists. Though unlikely, it is uncertain if the LCS0 could occur
between 4.15 mg/L and 5.0 mg/L (a Moderate hazard designation).
Acute Lethality
Oral
Dermal
Inhalation
Rat Oral LD50 >5,000 mg/kg-bw
EPA. 2010
Rat Dermal LD50 >2,000 mg/kg-bw
EPA. 2010
Rat Inhalation (aerosol, nose-only) LC50
>4.14 mg/L
EPA. 2010
Guideline study reported in a
secondary source. Data are for the
commercial polymeric mixture.
Guideline study reported in a
secondary source. Data are for the
commercial polymeric mixture.
The study is a quality guideline
study reported in a secondary
source; It cannot be used to
determine a hazard designation
because there were no effects at the
highest concentrations tested (4.14
mg/L); From this data, it cannot be
determined if effects happened at
4.15 mg/L (Moderate) or at a
concentration that can be
considered Low; therefore, this
study cannot be used to determine a
hazard designation.
4-594
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Carcinogenicity
MODERATE: Estimated to have uncertain potential for carcinogenicity based on analogy to aryl phosphate
analogs and professional judgment.
OncoLogic Results
Structure could not be evaluated by
OncoLogic.
Carcinogenicity (Rat
and Mouse)
Uncertain potential for oncogenicity
(Estimated by analogy)
Professional judgment
Estimated by analogy to aryl
phosphates.
Combined Chronic
Toxicity/
Carcinogenicity
No data located.
Genotoxicity
LOW: Resorcinol bis-diphenylphosphate did not cause gene mutations or chromosomal aberrations in vitro
and did not produce an increase in micronuclei in mice in vivo.
Gene Mutation in vitro
Negative in Salmonella typhi murium
(strains not indicated) with and without
metabolic activation at concentrations up
to 5,000 (ig/plate.
No cytotoxicity was evident.
Pakalin et al., 2007; EPA, 2010
Guideline study. Data are for the
commercial polymeric mixture.
Negative in Escherichia coli (strains not
indicated) with and without metabolic
activation at concentrations up to 5,000
(ig/plate.
Pakalin et al., 2007; EPA, 2010
Guideline study. Data are for the
commercial polymeric mixture.
No cytotoxicity was evident.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
Negative in chromosomal aberration test
(cultured human lymphocytes) with and
without metabolic activation at
concentrations up to 625 |ig/mL.
Cytotoxicity data not indicated.
Pakalin et al., 2007; EPA, 2010
Guideline study. Data are for the
commercial polymeric mixture.
Chromosomal
Aberrations in vivo
Negative in mammalian erythrocyte
micronucleus test (Swiss mice) following
a single oral dose of 5,000 mg/kg-bw.
Pakalin et al., 2007; EPA, 2010
Guideline study. Data are for the
commercial polymeric mixture.
4-595
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Negative in mammalian erythrocyte
micronucleus test (mice) following
single oral dose of 500 mg/kg bw.
UK Environment Agency, 2009
Study details reported in a
secondary source; Study was
conducted in accordance with good
laboratory practice (GLP) and
Organisation of Economic
Cooperation and Development
(OECD) Guideline 474.
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
Reproductive Effects
LOW: Experimental data for resorcinol bis-diphenylphosphate indicate no adverse effects on reproductive
performance or fertility parameters at doses up to 1,000 mg/kg-day (highest dose tested) in a two generation
dietary study in rats. There may be potential for reproductive toxicity based on analogy to confidential
analog.
Reproduction/
Developmental Toxicity
Screen
No data located.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
4-596
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproduction and
Fertility Effects
Two generation dietary reproduction
study in rats. Sprague-Dawley rats
(30/sex/dose) were fed 0, 50, 500, or
1,000 mg/kg/day resorcinol bis-
diphenylphosphate in the diet for 10
weeks.
No clinical signs of toxicity. No effects
on litter survival. No adverse effects on
any reproductive or fertility parameter
measured. No treatment-related lesions
in any reproductive organ.
NOAEL (parental systemic and
reproductive toxicity) = ~ 1,000 mg/kg
bw/day
LOAEL: not established as highest
concentration tested did not produce
adverse effects.
Pakalin et al., 2007; EPA, 2010
Guideline study. Data are for the
commercial polymeric mixture.
Potential for reproductive toxicity; no
pregnancies (1,000 mg/kg/day); reduced
litter size and weight (250 mg/kg/day)
Professional judgment;
Confidential study
Estimated by analogy to
confidential analog.
NOEL = 50 mg/kg-day
LOEL = 250 mg/kg/day
(Estimated by analogy)
Developmental Effects
MODERATE: Based on a NOAEL of 50 mg/kg bw-day in a two generation dietary reproduction study in
rats. Adverse effects included delayed vaginal opening and preputial separation at a dose of 500 mg/kg bw-
day. No adverse developmental effects were observed in rabbits following oral administration of resorcinol
bis-diphenylphosphate at doses up to 1000 mg/kg bw-day.
Reproduction/
Developmental Toxicity
Screen
No data located.
4-597
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Two generation dietary reproduction
study in rats. Sprague-Dawley rats
(30/sex/dose) were fed 0, 50, 500, or
1,000 mg/kg/day resorcinol bis-
diphenylphosphate in the diet for 10
weeks.
Vaginal opening and preputial separation
were delayed at 500 and 1,000 mg/kg,
but effect was considered secondary to
reduction of body weight in Fi
generation during week 1 (treated
animals had decreased body weights
compared to controls during week 1,
reportedly due to an initial aversion to
taste of diet).
NOAEL: 50 mg/kg bw-day (for vaginal
opening and preputial separation)
LOAEL: 500 mg/kg bw-day
Pakalin et al., 2007; EPA, 2010
Guideline study. Data are for the
commercial polymeric mixture.
4-598
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Developmental oral gavage study in
rabbits. Pregnant New Zealand white
rabbits (27/group) were dosed with 0, 50,
200 or 1,000 mg/kg resorcinol bis-
diphenylphosphate by oral gavage on
gestation days (GDs) 6-28.
No clinical signs of toxicity. No adverse
effects on maternal food consumption,
body weight gain or organ weights. No
adverse effects on fetal body weights,
viability, or any developmental endpoint
measured.
NOAEL (maternal and developmental
toxicity) = 1,000 mg/kg
LOAEL: not established as highest
concentration tested did not produce
adverse effects
EPA, 2010
Guideline study reported in a
secondary source. Data are for the
commercial polymeric mixture.
4-599
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Prenatal Development
Pregnant rabbits; oral gavage; GD 6-23;
0, 50, 200 or 1,000 mg/kg test material
No deaths or clinical signs of toxicity.
No significant effect on body weight,
body weight gain, food consumption or
organ weight.
No significant effect on litter weight or
pup viability. No gross external, skeletal
or soft tissues malformations or
anomalies.
NOAEL = 1,000 mg/kg-day (highest
dose tested)
LOAEL = Not established
UK Environment Agency, 2009
Study details reported in a
secondary source; Study conducted
according to GLP
Postnatal Development
No data located.
Neurotoxicity
MODERATE: Based on a 28-day inhalation LOAEL of 0.5 mg/L for inhibition of plasma ChE in rats
(NOAEL = 0.1 mg/L); criteria values are tripled for chemicals evaluated in 28-day studies; the LOAEL of
0.5 mg/kg-day falls within the Moderate hazard criteria (0.06 - 0.6 mg/L).
Neurotoxicity Screening
Battery (Adult)
28-day oral (gavage) study
NOAEL = 1,000 mg/kg (Estimated by
analogy)
Submitted confidential study;
Professional judgment
Estimated based on analogy to
phosphoric acid, mixed esters with
11.1 '-bisphenyl-4.4'-diol | and
phenol (CASRN 1003300-73-9)
4-600
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
28-day inhalation study in rats; 0, 0.1,
0.5 and 2.0 mg/L (aerosol);
Significant inhibition of plasma ChE (0.5
and 2.0 mg/L). No clinical signs
suggestive of neurotoxic effect and ChE
was not affected after study termination
NOAEL : 0.1 mg/L
LOAEL : 0.5 mg/L (plasma ChE
inhibition)
UK Environment Agency,
2009; Heinrich et al., 2000
Study details reported in a
secondary source; study was not
designed to assess all neurological
parameters; criteria values are
tripled for chemicals evaluated in
28-day studies; the LOAEL of 0.5
mg/kg-day falls within the
Moderate hazard criteria (0.06 - 0.6
mg/L).
28-day oral (gavage) study in mice; 0,
500, 1,500, 5,000 mg/kg "
Dose-related decrease in plasma ChE
compared to controls, which was no
longer apparent after the 60 day recovery
period.
UK Environment Agency, 2009
Study details reported in a
secondary source; study was not
designed to assess all neurological
parameters; cannot rule out all
neurotoxicity.
No NOAEL/LOAEL determined
Repeated Dose Effects
MODERATE: Experimental data for resorcinol bis-diphenylphosphate reported alveolar histiocytosis in
rats following a 4-week inhalation exposure to 0.5 mg/L aerosol (NOAEL = 0.1 mg/L). The Design for the
Environment criteria threshold for a low hazard designation is 0.2 mg/L for mists based on 90-day repeated
dose studies; criteria values are tripled for 28-day study evaluations making the Moderate hazard range
from 0.06 - 0.6 mg/L. No other exposure-related gross or microscopic pathology was identified in any
organ. There is also potential for liver toxicity based on a confidential analog, though no effects occurred at
300 mg/kg/day for that analog (higher than the criteria threshold for a low hazard designation).
Repeated dose effects
2 8-day oral study, rats
Potential for liver toxicity.
NOEL = 300 mg/kg/day
(Estimated based on analogy)
Professional judgment;
Confidential study
Estimated based on analogy to
confidential analog.
4-601
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
In a 4-week inhalation study Sprague-
Dawley rats (10/sex/group) were
exposed (aerosol, nose only) to 0, 100,
500 or 2,000 mg/m3 (0, 0.1, 0.5, or 2
mg/L) resorcinol bis-diphenylphosphate.
No deaths or clinical signs of toxicity.
Decreased body weight and food
consumption in males and significant
inhibition of plasma choline sterase in
females at 2,000 mg/nr\ White foci in
the lungs at 2,000 mg/irf and alveolar
histiocytosis at 500 and 2,000 mg/nr\
Although lung changes are relevant, they
were not considered to be a reflection of
a specific toxic response to resorcinol
bis-diphenylphosphate; these changes are
characteristic of exposure to non-
cytotoxic water-insoluble materials.
No other gross or microscopic pathology
in any organ.
NOAEC: 100 mg/m3 (0.1 mg/L)
LOAEC: 500 mg/m3 (0.5 mg/L) based
on alveolar histiocytosis
EPA, 2010
Guideline study reported in a
secondary source. Data are for the
commercial polymeric mixture.
4-602
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Immune System Effects
Negative, oral gavage study in mice.
Female B6C3F1 mice (50/group) were
exposed via oral gavage to 0, 500, 1,500,
or 5,000 mg/kg-day resorcinol bis-
diphenylphosphate for 28 days.
No deaths, clinical signs of toxicity, or
effects on body or organ weights. No
adverse histopathological changes or
necropsy findings. No treatment-related
changes in peritoneal cell numbers or
cell types, peritoneal macrophage
phagocytic activity or host susceptibility
to infection. No adverse effect on splenic
natural killer cell activity, lymphocyte
blastogenesis, or antibody-forming cell
function. There were significant
decreases in erythrocyte cholinesterase
activity and plasma pseudocholinesterase
activity in all dose groups, but both
enzyme activities returned to control
levels at the end of the 60 day recovery
period.
NOAEL: 5,000 mg/kg-day
LOAEL: not established, as highest dose
tested did not produced adverse effects.
EPA, 2010
Guideline study reported in a
secondary source. Data are for the
commercial polymeric mixture.
Skin Sensitization
LOW: Estimated not to have potential for skin sensitization based on expert judgment.
Skin Sensitization
No potential for skin sensitization
(Estimated)
Expert judgment
Estimated by expert judgment.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
4-603
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Eye Irritation
LOW: Resorcinol bis-diphenylphosphate produced mild irritation in rabbit eyes; however, clearing
occurred within 24 hours.
Eye Irritation
Rabbit, minimally irritating.
0.1 ml instilled into the left eyes of 3
rabbits produced slight conjunctival
redness and chemosis that was reversible
by 24 hours.
EPA, 2010
Guideline study reported in a
secondary source. Data are for the
commercial polymeric mixture.
Dermal Irritation
VERY LOW: Resorcinol bis-diphenylphosphate is not a dermal irritant in rabbits.
Dermal Irritation
Rabbit, not irritating
EPA, 2010
Guideline study reported in a
secondary source. Data are for the
commercial polymeric mixture.
Endocrine Activity
No experimental data were located to evaluate and determine if RDP affects endocrine activity.
However, resorcinol, a metabolite of RDP, is listed as a suspected endocrine disruptor by the EU.
Resorcinol is listed as a potential
endocrine disruptor on the EU Priority
List of Suspected Endocrine Disruptors.
European Commission, 2012
"Potential for endocrine disruption.
In vitro data indicating potential for
endocrine disruption in intact
organisms. Also included effects in-
vivo that may, or may not, be
endocrine disruption-mediated. May
include structural analyses and
metabolic considerations".
4-604
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Immunotoxicity
Resorcinol bis-diphenylphosphate had n
day (highest dose tested) in an oral gava
o effect on immunological parameters at doses up to 5,000 mg/kg-
ge study in mice.
Immune System Effects
Negative, oral gavage study in mice.
Female B6C3F1 mice (50/group) were
exposed via oral gavage to 0, 500, 1,500,
or 5,000 mg/kg-day resorcinol bis-
diphenylphosphate for 28 days.
No deaths, clinical signs of toxicity, or
effects on body or organ weights. No
adverse histopathological changes or
necropsy findings. No treatment-related
changes in peritoneal cell numbers or
cell types, peritoneal macrophage
phagocytic activity or host susceptibility
to infection. No adverse effect on splenic
natural killer cell activity, lymphocyte
blastogenesis, or antibody-forming cell
function. There were significant
decreases in erythrocyte cholinesterase
activity and plasma pseudocholinesterase
activity in all dose groups, but both
enzyme activities returned to control
levels at the end of the 60 day recovery
period.
NOAEL: 5,000 mg/kg-day
LOAEL: not established, as highest dose
tested did not produced adverse effects.
EPA, 2010
Guideline study reported in a
secondary source. Data are for the
commercial polymeric mixture.
4-605
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ECOTOXICITY
ECOSAR Class
Acute Toxicity
VERY HIGH: Based on measured ECS0 values for daphnia. Measured values for fish and algae are higher
than the water solubility limit, suggesting no effects at saturation (NES).
Fish LC50
Brachydcmio rerio 96-hour LC50 =12.3
mg/L (OECD Guideline 203)
(Experimental)
EPA, 2010
Guideline study reported in a
secondary source. Data are for the
commercial polymeric mixture.
Given that the reported value is
greater than the water solubility,
NES were observed for this
endpoint.
Fish 96-hour LC50 = NES
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000; NES are
estimated for the n=l and higher
oligomers. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
Daphnid LCS0
Dapnhia magna 48-hour EC50 =
0.7 mg/L (U.S. EPA OPPTS 850.1010)
(Experimental)
EPA, 2010
Guideline study reported in a
secondary source.
Daphnid 48-hour LC50 = NES
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000; NES are
estimated for the n=l and higher
oligomers. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
4-606
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Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Other Freshwater Invertebrate LCS0
No data located.
Green Algae ECS0
Pseiidokirchneriella subcapitata 72-hour
EC50 = 48.6 mg/L (OECD Guideline
201) (Experimental)
EPA, 2010
Guideline study reported in a
secondary source. Data are for the
commercial polymeric mixture.
Given that the reported value is
greater than the water solubility,
NES was observed for this
endpoint.
Pseiidokirchneriella subcapitata 72-hour
NOEC = 10 mg/L (water accommodated
fraction (WAF))
72-hour LOEC = 100 mg/L (WAF)
(OECD Guideline 201) (Experimental)
UK Environment Agency, 2009
Study details reported in a
secondary source. Study conducted
according to GLP.
Green algae 96-hour EC50 = NES
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000; NES are
estimated for the n=l and higher
oligomers. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
4-607
-------
Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Chronic Aquatic Toxicity
VERY HIGH: Based on an experimental 21-day NOEC 0.021 mg/L in Daphnia magna. Estimated ChV
values suggest a High hazard with the n = 1 oligomer (phosphate esters ECOSAR class) of 0.0093 mg/L for
fish.
Fish ChV
ChV - NES
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000; NES are
estimated for the n=l and higher
oligomers. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
Daphnid ChV
Daphnia magna 21d-NOEC = 0.021
mg/L
21-dEC50 = 0.037 mg/L
Semi-static (OECD guideline 211)
(Experimental)
Submitted confidential study
Reported in a submitted
confidential study; Guideline study
conducted according to GLP; test
substance is identified as the n=l
oligomer (CASRN: 57583-54-7); it
is reported that the toxicity may be
a result of the presence of
undissolved test substance, although
toxicity by the dissolved substance
could not be ruled out.
ChV - NES
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000; NES are
estimated for the n=l and higher
oligomers. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
4-608
-------
Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green Algae ChV
ChV - NES
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Estimates were performed on
oligomers of the polymeric mixture
that have a MW <1,000; NES are
estimated for the n=l and higher
oligomers. ECOSAR also provided
results for the Esters, and Esters
(phosphate) classes; however,
professional judgment indicates that
this compound does not lie within
the domain of the ECOSAR model.
ENVIRONMENTAL FATE
Transport
The environmental fate is described for the oligomer where n=l, which is the primary component of the
commercial product. Based on the Level III fugacity models incorporating the located experimental property
data, resorcinol bis-diphenylphosphate is expected to partition primarily to soil and sediment. Resorcinol bis-
diphenylphosphate is expected to be immobile in soil based on its estimated Koc. Leaching of resorcinol bis-
diphenylphosphate through soil to groundwater is not expected to be an important transport mechanism.
Estimated volatilization half-lives indicate that it will be non-volatile from surface water. Volatilization from
dry surface is also not expected based on its vapor pressure. In the atmosphere, resorcinol bis-
diphenylphosphate is expected to exist solely in the particulate phase, based on its estimated vapor pressure.
Particulates may be removed from air by wet or dry deposition. The higher MW components of the
commercial product are anticipated to behave similarly to that described above.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated for n=l and n=2)
EPI
Cutoff value for nonvolatile
compounds. Higher MW components
are also expected to have Henry's
Law Constant values below this
cutoff.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated for n=l and n=2)
EPI; EPA, 1999
Cutoff value for non mobile
compounds according to HPV
assessment guidance. Higher MW
components are also expected to have
Koc values above this cutoff.
4-609
-------
Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Level III Fugacity Model
Air: <1% (Estimated for n=l)
Water =1%
Soil = 40%
Sediment = 59%
Air: <1% (Estimated for n=2)
Water =1%
Soil = 42%
Sediment = 57%
EPI
Estimates were performed on
representative components of the
polymer.
Persistence
MODERATE: Moderate persistence is expected for resorcinol bis-diphenylphosphate based on experimental
biodegradation studies that indicate the potential for biodegradation of the commercial polymeric mixture.
The commercial mixture was determined to be inherently biodegradable using the guidelines of Directive
84/449/EEC, C.6 "Biotic degradation - the Closed Bottle test" test. After 28 days, 37% biodegradation
occurred and after 56 days, 66% biodegradation occurred. Resorcinol bis-diphenylphosphate oligomers (n=l
and n=2) do not contain chromophores that absorb at wavelengths >290 nm, and therefore, are not expected
to be susceptible to direct photolysis by sunlight. The atmospheric half-life of resorcinol bis-
diphenylphosphate oligomers are estimated to be 6.1 (n=l) and 4.1 (n=2) hours, although they are expected to
exist primarily in the particulate phase in air. Enzymatic or basic hydrolysis leading to the production of
phenol (CASRN 108-95-2), diphenyl phosphate (CASRN 838-85-7), and resorcinol (CASRN 108-46-3)
through sequential dephosphorylation is theoretically possible but has not been demonstrated.
Water
Aerobic Biodegradation
37% degradation after 28 days;
66% degradation after 56 days
Using Directive 84/449/EEC, C.6;
inherent biodegradation, 2.7 mg/L of
compound in activated sludge (Measured)
IUCLID, 2001
The data is for the commercial
polymeric mixture (CASRN 125997-
21-9).
Volatilization Half-life for
Model River
>1 year (Estimated for n=l and n=2)
EPI
Based on the magnitude of the
estimated Henry's Law Constant.
Volatilization Half-life for
Model Lake
>1 year (Estimated for n=l and n=2)
EPI
Based on the magnitude of the
estimated Henry's Law Constant.
Soil
Aerobic Biodegradation
No data located.
4-610
-------
Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Anaerobic
Biodegradation
Not probable
(Anaerobic-methanogenic biodegradation
probability model for n=l and n=2)
(Estimated)
EPI
Soil Biodegradation with
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
6.1 hours (Estimated for n=l)
4.1 hours (Estimated for n=2)
EPI
Reactivity
Photolysis
Not a significant fate process
(Estimated for n=l and n=2)
Mill, 2000; Professional
judgment
The substance does not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
Hydrolysis
Half-life = 320 days at pH 7
Half-life = 32 days at pH 8
Half-life = 3 days pH 9 (Estimated for
n=l)
Half-life = 240-320 days at pH 7
Half-life = 24-32 days at pH 8
Half-life = 2-3 days pH 9 (Estimated for
n=2)
EPI
Hydrolysis rates are expected to be
pH-dependent and may be limited by
the low water solubility of this
compound. Under basic conditions,
sequential dephosphorylation
reactions may occur.
4-611
-------
Resorcinol Bis-Diphenylphosphate CASRN 125997-21-9
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Half-life =11 days (20°C; pH 4)
Half-life = 17 days (20°C; pH 7)
Half-life = 21 days (20°C; pH 9)
OECD 111 (Measured)
IUCLID, 2001
Inadequate. Although reported as a
guideline study, phosphate esters as a
chemical class have been observed to
hydrolyze more rapidly under basic
pHs then under neutral or acidic
conditions. The reported half-lives do
not follow this trend, and are
therefore suspect. Under basic
conditions, sequential
dephosphorylation reactions may
occur.
Environmental Half-life
>180 days (Estimated for n=l and n=2)
EPI; PBT Profiler
Half-life estimated for the
predominant compartment, as
determined by EPI and the PBT
Profiler methodology.
Bioaccumulation
HIGH: The estimated BCF value for the n=l component has high potential for bioaccumulation. The higher
MW oligomers that may be found in this mixture (n=2, 3, 4...) are expected to have moderate or low potential
for bioaccumulation based on their large size and low solubility according to the polymer assessment
literature (Boethling et al., 1997).
Fish BCF
1,300 (Estimated for n=l)
59 (Estimated for n=2)
EPI
BAF
81 (Estimated for n=l)
7 (Estimated for n=2)
EPI
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the biomonitoring report (CDC, 2011).
4-612
-------
AkzoNobel (AkzoNobel Functional Chemicals). AkzoNobel. Fyrolflex RDP technical data sheet. December 1, 1998.
Bayer. Disflammoll RDP Material Safety Data Sheet, MSDS No. 821601/05. February 4, 2002.
Boethling, Robert S. and Nabholz, J. Vincent "Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act",
pp. 187-234, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs, Hamilton, John D.
and Sutcliffe, Roger (eds.), (1997) Van Nostrand Reinhold.
Chang Chun. (Chang Chun Plastics Co., Ltd). No date. Phosphorus Flame Retardant (PFR) Material Safety Data Sheet.
CDC (Centers for Disease Control and Prevention). Fourth National Report on Raman Exposure to Environmental Chemicals,
Updated Tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf as of
May 10, 2011.
UK Environment Agency. Environmental risk evaluation report: Tetraphenyl resorcinol diphosphate (CAS no. 57586-54-7). 2009.
http://www.environment-agencv.gov.uk/
U.S. EPA (Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing
Data. U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
EPA (U.S. Environmental Protection Agency). Screening level hazard characterization phosphoryl chloride, polymer with resorcinol
phenyl ester (CASRN 125997-21-9). 2010.
http://www.epa.gov/chemrtk/hpvis/hazchar/125997219 Phosphorvl%20chloride.%20polvmer%20with%20resorcinol%20phenyl%20e
ster %20June%202010.pdf (accessed on February 08, 2010).
EPA Sustainable Futures. Using NonCancer Screening within the SF Initiative. U.S. Environmental Protection Agency: Washington
D.C. available at: http://www.epa.gOv/opptintr/sf/pubs/noncan-screen.htm#svstemic as of February 09, 2011.
ECOSAR/EPI (EPIWIN/EPISUITE) Estimations Programs Interface for Windows, Version 1.11. U.S.
Environmental Protection Agency: Washington D.C. http://www.epa.gov/opptintr/exposure/.
EPI (EPIWIN/EPISUITE) Estimation Program Interface for Windows, Version 4.0. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
4-613
-------
European Commission. EU priority list of suspected endocrine disruptors. 2012.
http://ec.europa.eu/environment/endocrine/strategy/substances en.htm#prioritv list (accessed June, 2013).
Freudenthal, R., McDonald, L., Johnson, J., et al. Comparative metabolism and toxicokinetics of 14C-resorcinol bis-
diphenylphosphate (RDP) in the rat, mouse, and monkey. International Journal of Toxicology 19:233-242. 2000.
Great Lakes. (Great Lakes Chemical Corporation). Reophos PDP Material Safety Data Sheet, MSDS No. 00660. February 25, 2003.
Henrich, R., Ryan, B.M., Selby, R., Garthawaite, S., Morrissey, R. and Freudenthal, R.I., 2000. Two-generation oral (diet)
reproductive toxicity study of resorcinol bis-diphenylphosphate (Fyrolflex RDP). International Journal of Toxicology, 19 (4), 243-
255.
ICL Industrial. 2009. Fyroflex Material Safety Data Sheet, March 6, 2009.
IUCLID (International Uniform Chemical Information Database). Dataset for Phosphoryl chloride, polymer with resorcinol phenyl
ester. 2001. European Commission - European Chemicals Bureau.
Laflamme, D. Flame Retardant Alternatives. Washington State Department of Health. February 2006.
Mill, T. (2000) Photoreactions in Surface Waters. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for
Chemicals, Environmental Health Sciences (355-382). Boca Raton: Lewis Publishers.
PBT Profi 1 er Persistent (P), Bioaccumulative (B), and Toxic (T) Chemical (PBT) Profiler, U.S. Environmental Protection Agency:
Washington D.C. www.pbtprofiler.net.
Pakalin, S.; Cole, T.; Steinkellner, J.; et al. review on production processes of decabromodiphenyl (DECABDE) used in polymeric
applications in electrical and electronic equipment, and assessment of the availability of potential alternatives to DECABDE.
Supresta. Product bulletin for Fyrolflex-RDP. 2011. http://www.supresta.com/pdfs/Fvrolflex-RDP-product-bulletin.pdf.
UBA (Umweltbundesamt). Substituting Environmentally Relevant Flame Retardants: Assessment Fundamentals, Volume 1: Results
and Summary Overview. Berlin, Germany: Umweltbundesamt (Federal Environmental Agency) p97. 2001a.
4-614
-------
UBA (Umweltbundesamt). Substituting Environmentally Relevant Flame Retardants: Assessment Fundamentals, Volume 3:
Toxicological and Ecotoxicological Substance Profiles of Selected Flame Retardants. Berlin, Germany: Umweltbundesamt (Federal
Environmental Agency), pl51. 2001b.
UBA (Umweltbundesamt). Emission of Flame Retardants from Consumer Products and Building Materials. Berlin, Germany:
Umweltbundesamt (Federal Environmental Agency), pi85. 2003.
Weil, E.D. Flame Retardants, Phosphorus. Kirk-Othmer Encyclopedia of Chemical Technology. Wiley-Interscience. Posted online:
October 18, 2001.
Wildlife International Ltd. Determination of the n-Octanol/Water Partition Coefficient of Fyroflex RDP by the Shake Flask Method.
Unpublished Study. 2003.
4-615
-------
Substituted Amine Phosphate Mixture
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
§ Based on analogy to experimental data for a structurally similar compound.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Substituted Amine Phosphate Mixture1
Confidential
H
M
M
M
M
L
M
L
VL
M
L
H
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
1 Hazard designations are based upon the component of the salt with the highest hazard designation, including the corresponding free acid or base.
4-616
-------
Substituted Amine Phosphate Mixture
H
0 0
\ II ||
lj ^P—OH
2 0 1 0 1
OH OH
mixture with confidential substituted amine phosphate
CASRN:
66034-17-1 (Piperazine pyrophosphate) and
confidential CASRN (substituted amine
phosphate)
MW: 264 (Piperazine pyrophosphate) and
confidential MW (substituted amine phosphate)
MF:
C4H„N2+1 •PjOyHs'and
confidential MF (substituted amine phosphate)
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: This mixture containing confidential material is not amenable to the generation of a single SMILES notation.
Synonyms: ADK STABILIZER FP-2100J; ADK STABILIZER FP-2200; ADK STABILIZER FP-2200S; ADK STABILIZER FP-2400
Chemical Considerations: This alternative is a mixture. The substituted amine phosphate mixture represents the ADK Stabilizer series of commercial mixtures that
are comprised of approximately 50% of piperazine pyrophosphate (Diphosphoric acid, compd. with piperazine (1:1), CAS 66034-17-1, MW=264) and a substituted
amine phosphate. Piperazine pyrophosphate will dissociate into piperazine and pyrophosphate (diphosphoric acid) anions under environmental conditions and,
therefore, the relevant dissociation products piperazine or pyrophosphate was used in each endpoint as appropriate. The same approach was used for the substituted
amine phosphate anions. Measured or estimated values for the dissociated components were used to fill assessment data gaps as appropriate.
4-617
-------
Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: Pyrophosphoric acid (2466-09-3), Piperazine (110-85-0), glycine (56-40-6) and other confidential
substances.
Analog: Piperazine (110-85-0); and confidential analogs, piperazine-containing compounds.
Endpoint(s) using analog values: Respiratory sensitization
Analog Structure:
H
N
H
Piperazine
Structural Alerts: Amines, potential nephrotoxins (EPA, 2011).
Risk Phrases: Not classified by Annex VI Regulation (EC) No. 1272/2008 (ESIS, 2011).
Hazard and Risk Assessments: None identified.
4-618
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
>300 (Estimated)
Professional judgment
The components of this mixture are
ionic compounds and are
anticipated to be high melting
solids. Cutoff value for high
melting compounds.
Boiling Point (°C)
>270 decomposes (Measured)
Adeka-Palmarole, 2011
Product information for FP-2100J;
refers to the ionic compounds in
ADK stabilizers.
>260 decomposes (Measured)
Adeka-Palmarole, 2011
Product information for FP-2200;
refers to the ionic compounds in
ADK stabilizers.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; EPA,
1999
Cutoff value for nonvolatile
compounds according to HPV
assessment guidance. Applies to
both ionic solids present in the
substituted amine phosphate
mixture.
Water Solubility (mg/L)
Piperazine pyrophosphate: >1,000,000
(Estimated)
EPI
Substituted amine phosphate
component: >1,000,000 (Estimated)
EPI
Substituted amine phosphate
component:
approximately 800; 900 (Measured)
Confidential MSDS, 2011;
Weil, 2001
Inadequate; these reported values
are inconsistent with structurally
similar phosphates.
Log Kow
Piperazine pyrophosphate: <-2
(Estimated)
EPI
Substituted amine phosphate
component: <-2 (Estimated)
EPI
4-619
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Flammability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No experimental data located;
based on its use as a flame
retardant.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located;
based on its use as a flame
retardant.
Pyrolysis
No data located.
pH
No data located.
pKa
No data located.
HUMAN HEALTH EFF
ECTS
Toxicokinetics
No toxicokinetic data were located for the substituted amine phosphate mixture. The substituted amine
phosphate mixture is estimated to not be absorbed through the skin and absorption is expected through the
lung and gastrointestinal (GI) tract. Following absorption, limited data suggest distribution throughout the
GI system, liver, and kidney for the substituted amine phosphate and piperazine components. Data for the
substituted amine phosphate component indicate an elimination phase half-life of 2.7 hours from plasma
and 3 hours for urine. Data for the piperazine component indicate rapid elimination from blood and kidney.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Oral, Dermal or Inhaled
Substituted amine phosphate mixture:
Not absorbed from the skin, absorption
Professional judgment
Based on closely related analogs
with similar structures, functional
Metabolism &
Excretion
through lung and GI tract.
(Estimated by analogy)
groups, and physical/chemical
properties.
Substituted amine phosphate
component: The elimination phase half-
life calculated from plasma data was 2.7
Confidential study
Nonguideline study.
hours, and the urinary half-life was 3.0
hours. The renal clearance was
determined to be 2.5 mL/min. (Measured
for the free base)
4-620
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Distributed to stomach,
small intestine, cecum, and large
intestine, and found in blood, and urine
of rats. (Measured for the free base)
Confidential study
Study details reported in a
secondary source.
Piperazine: Pig, oral (gavage); peak
plasma concentrations occurred 1 hour
after exposure; quickly eliminated from
blood. Distributed primarily to kidneys
and liver; eliminated quickly from
kidney, and slower from liver, skeleton,
muscle, fat and skin. Low potential for
bioaccumulation. (Measured for the free
base)
ECHA, 2011
Study details reported in a
secondary source.
Acute Mammalian Toxicity
HIGH: Using a conservative approach, acute toxicity hazard potential for the substituted amine phosphate
mixture is estimated based on toxicity for inhalation exposure to the piperazine moiety in rats. The hazard
is estimated to be low for oral and dermal routes of exposure to the substituted amine phosphate and
piperazine components of the mixture.
Acute Lethality
Oral
Substituted amine phosphate
component: Rat LD50 = 3,161 mg/kg
b.w. (male), 3,828 mg/kg (females)
(Measured for the free base)
Confidential study
Adequate.
Substituted amine phosphate
component: Mouse LD50 = 3,296 mg/kg
(male), 7,014 mg/kg (female) (Measured
for the free base)
Confidential study
Adequate.
Substituted amine phosphate
component: Mouse LD50 = 4,550 mg/kg
(Measured for the free base)
Confidential study
Limited study details reported in a
confidential study.
Substituted amine phosphate
component: Rat LD50 = 3,160 mg/kg
(male) and 3850 mg/kg (female)
(Measured for the free base)
Confidential study
Limited study details reported in a
confidential study.
4-621
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Rat LD50 >6,400 mg/kg
(Measured for the free base)
Confidential study
Limited study details reported in a
confidential study.
Substituted amine phosphate
component: LD50 ~ 4,800 mg/kg
Confidential study
Limited study details reported in a
confidential study.
Piperazine: Rat LD50 = 1,900-4,500
mg/kg
IUCLID, 2000
Reported results taken from 3
studies. Limited study details
reported in a secondary source.
Piperazine: Mouse LD50 = 600-4,200
mg/kg
IUCLID, 2000
Reported results taken from 3
studies. Limited study details
reported in a secondary source.
Piperazine: Rat LD50 = 2,500 mg/kg
ECHA, 2011
Study details reported in a
secondary source; according to
Organisation of Economic
Cooperation and Development
(OECD) Guideline 401.
Piperazine: Rat LD50 = 3,200 mg/kg
ECHA, 2011
Study details reported in a
secondary source; according to
OECD Guideline 401.
Piperazine: Rat LD50 = 2,600 mg/kg
ECHA, 2011
Study details reported in a
secondary source; according to
OECD Guideline 401.
Dermal
Piperazine: Rabbit LD50 = 4,000 mg/L
ECHA, 2011
Limited study details provided in a
secondary source.
Substituted amine phosphate
component: Rabbit LD50 >1,000 mg/L
Confidential study
Limited study details reported in a
confidential study.
Inhalation
Substituted amine phosphate
component: Rat LC50 = 3 248 mg/L
Confidential study
Study details, if present, were not
translated into English; reported in
a confidential study.
Piperazine: Rat 4-hour LC50 = 2.0 mg/L
ECHA, 2011
Study details reported in a
secondary source.
Piperazine: Rat 4-hour LC50 = 0.8 mg/L
ECHA, 2011
Study details reported in a
secondary source.
4-622
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Piperazine: Rat 2-hour LC50 = 5.4 mg/L.
IUCLID, 2000
Limited study details reported in a
secondary source.
Carcinogenicity
MODERATE: The carcinogenicity hazard potential for the substituted amine phosphate mixture is
estimated to be Moderate based on the substituted amine phosphate component. There is evidence that oral
exposure to the substituted amine phosphate component causes carcinogenicity in experimental animals.
However, there is no evidence located as to the substituted amine phosphate component's carcinogenicity to
humans. Tumor formation in animals appeared to happen in a mechanical nature under conditions in
which it produced bladder calculi. No data were located as to the carcinogenic potential of the substituted
amine phosphate mixture or salts. The International Agency for Research on Cancer (IARC) classifies the
substituted amine phosphate component as Group 3: not classifiable as to its carcinogenicity to humans.
OncoLogic Results
Substituted amine phosphate
component: Marginal (Estimated for
free base)
OncoLogic, 2008
Carcinogenicity (Rat
and Mouse)
Substituted amine phosphate
component: Group 3: It is not
classifiable as to its carcinogenicity to
humans; there is inadequate evidence in
humans for carcinogenicity, and there is
sufficient evidence in experimental
animals for carcinogenicity under
conditions in which it produces bladder
calculi. (Measured for the free base)
IARC
Classification statement.
4-623
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Significant formation of
transitional cell carcinomas in the
urinary bladder of male rats and
significant chronic inflammation in the
kidney of dosed female rats were
observed following exposure in the feed
for up to 103 weeks. Carcinoma
formation was significantly correlated
with the incidence of bladder stones. A
transitional-cell papilloma was observed
in the urinary bladder of a single high
dose male rat, and compound related
lesions were observed in the urinary tract
of dosed animals. (Measured for the free
base)
Confidential study
Reported in a confidential study.
Substituted amine phosphate
component: Increased incidence of
acute and chronic inflammation and
epithelial hyperplasia of the urinary
bladder were observed in male mice
following oral (feed) exposure for up to
103 weeks. Bladder stones and
compound related lesions were observed
in the urinary tract of test animals. There
was no evidence of bladder tumor
development. The compound was not
considered carcinogenic. (Measured for
the free base)
Confidential study
Reported in a confidential study.
4-624
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Proliferative lesions of the
rat urinary tract were directly due to the
irritant stimulation of calculi, and not to
molecular interactions between it or its
metabolites with the bladder epithelium.
(Measured for the free base)
Confidential study
Reported in a confidential study.
Substituted amine phosphate
component: Water intake, used as an
index of urinary output, was increased by
NaCl treatment. Calculus formation
resulting from administration was
suppressed dose-dependently by the
simultaneous NaCl treatment. The main
constituents of calculi were the
substituted amine phosphate component
and uric acid (total contents 61.1—
81.2%). The results indicated
proliferative lesions of the urinary tract
of rats were directly due to the irritation-
induced stimulation of calculi, and not
molecular interactions between itself or
its metabolites with the bladder
epithelium. (Measured for the free base)
Confidential study
Reported in a confidential study.
Substituted amine phosphate
component: As an initiator, it caused no
significant increase in papillomas per
mouse when compared to controls.
Confidential study
Reported in a confidential study;
nonguideline study.
4-625
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Diffuse papillary
hyperplasia of the bladder epithelium
and bladder calculi were observed in all
the treated rats. Elevated
spermidine/spermine Nl-
acetyltransferase activity following
treatment was considered to be an
indicator of cell proliferation. (Measured
for the free base)
Confidential study
Reported in a confidential study;
nonguideline study.
Substituted amine phosphate
component: Decreased antitumor
activity was correlated with increasing
demethylation; the component was
considered inactive as an antitumor drug.
(Measured for the free base)
Confidential study
Limited study details reported in a
confidential study.
Substituted amine phosphate
component: In an in vitro cytotoxicity
study in cultured ADJ/PC6
plasmacytoma ascites tumor cells, the
ID50 was 470 |a,g/mL after 72 hours of
treatment. (Measured for the free base)
Confidential study
Limited study details reported in a
confidential study.
Combined Chronic
Toxicity/
Carcinogenicity
Substituted amine phosphate
component: No effects were observed in
rats fed 1,000 ppm. 4 of the 10 rats fed
10,000 ppm had bladder stones
associated with the development of
benign papillomata.
(Measured for the free base)
Confidential study
Limited study details reported in a
confidential study.
4-626
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Increased incidence of
urinary bladder stones (6/20 rats) was
noted in the 10,000 ppm dose group, and
was associated with an increase in
benign papillomata. The NOAEL was
determined to be 1,000 ppm (67 mg/kg).
(Measured for the free base)
Confidential study
Limited study details reported in a
confidential study.
Genotoxicity
MODERATE: Estimated based on positive results for chromosomal aberrations in vivo in mice exposed to
the substituted amine phosphate component and positive results for gene mutations following in vitro
exposure to the piperazine component in mouse lymphoma assays. There were also positive results in vitro
for DNA synthesis-inhibition in Hela S3 cell and genetic toxicity in Escherichia coli WP2s in a microscreen
assay following exposure to the substituted amine phosphate component. No data were located for the
substituted amine phosphate mixture sa ts regarding the genotoxicity endpoint.
Gene Mutation in vitro
Substituted amine phosphate
component: Bacterial forward mutation
assay: Negative with and without liver
activation (Measured for the free base)
Confidential study
Reported in a confidential study.
Substituted amine phosphate
component: Bacterial forward mutation
assay: Negative (Measured for the free
base)
Confidential study
Limited study details reported in a
confidential study.
Substituted amine phosphate
component: Bacterial reverse mutation
assay: Negative with and without liver
activation (Measured for the free base)
Confidential study
Limited study details reported in a
confidential study.
Substituted amine phosphate
component: Bacterial reverse mutation
assay: Negative with and without
unspecified metabolic activation
(Measured for the free base)
Confidential study
Limited study details reported in a
confidential study.
4-627
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: In vitro mouse lymphoma
test: Negative with and without liver
activation (Measured for the free base)
Confidential study
Reported in a confidential study.
Substituted amine phosphate
component: Chinese hamster ovary
(CHO) cells/hypoxanthine-guanine
phosphoribosyl-transferase forward
mutation assay: Negative with and
without liver activation (Measured for
the free base)
Confidential study
Limited study details reported in a
confidential study.
Piperazine: S. typhimurium TA98,
TA100, TA1535, TA1537 gene mutation
assay: Negative with and without
metabolic activation (Measured for the
free base)
IUCLID, 2000; ECHA, 2011
Study details reported in a
secondary source; according to
OECD Guideline 471.
Piperazine: E. coli reverse mutation
assay: Negative without metabolic
activation
IUCLID, 2000
Results taken from several studies.
Limited study details reported in a
secondary source.
Piperazine: Mouse lymphoma assay:
Positive
IUCLID, 2000
Limited study details reported in a
secondary source.
Piperazine: Mammalian cell gene
mutation assay; mouse lymphoma
L5178Y cells; toxicity-related increases
in gene mutations in the presence of
metabolic activation and negative
without metabolic activation
ECHA, 2011
Study details reported in secondary
source; equivalent to OECD
Guideline 476; test substance
identified as piperazine
polyphosphate.
4-628
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Gene Mutation in vivo
Substituted amine phosphate
component: In vivo mouse micronucleus
test: The initial test gave a positive trend
(P=0.003) for chromosomal damage;
however, both peripheral blood smears
and the repeat bone marrow test were
negative. The overall conclusion was that
the substituted amine phosphate
component does not induce
chromosomal damage. (Measured for the
free base)
Confidential study
Reported in a confidential study.
Substituted amine phosphate
component: In vivo mouse micronucleus
test: Negative without activation
(Measured for the free base)
Confidential study
Limited study details reported in a
confidential study.
Piperazine: E. coli reverse mutation
IUCLID, 2000
Results taken from several studies.
assay: Negative without metabolic
Limited study details reported in a
activation
secondary source.
Chromosomal
Aberrations in vitro
Substituted amine phosphate
component: In vitro chromosomal
aberrations test: Negative CHO cells
with and without liver activation
(Measured for the free base)
Confidential study
Reported in a confidential study.
Substituted amine phosphate
component: In vitro sister chromatid
exchange assay: Negative in CHO cells
with and without liver activation
Confidential study
Reported in a confidential study.
(Measured for the free base)
Substituted amine phosphate
component: In vitro sister chromatid
exchange assay: Negative in CHO cells
with and without liver activation
Confidential study
Limited study details reported in a
confidential study.
(Measured for the free base)
4-629
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Piperazine: Chromosomal aberration
assay: Negative in CHO cells with and
without metabolic activation
ECHA, 2011
Study details reported in secondary
source; equivalent to OECD
Guideline 473.
Chromosomal
Aberrations in vivo
Substituted amine phosphate
component: In vivo chromosome
aberrations test in mice: Positive
(Measured for the free base)
Confidential study
Reported in a confidential study.
DNA Damage and
Repair
Substituted amine phosphate
component: In vivo and in vitro
unscheduled DNA synthesis (UDS) test:
None of the tested chemicals, including
the substituted amine phosphate
component were genotoxic
hepatocarcinogens in the in vivo assay.
They were also negative for UDS in the
in vitro assay. (Measured for the free
base)
Confidential study
Limited study details reported in a
confidential study.
Substituted amine phosphate
component: SOShimn test: Negative for
its ability to result in DNA damage and
induce the expression of the limn operon
Confidential study
Reported in a confidential study;
nonguideline study.
Substituted amine phosphate
component: DNA synthesis-inhibition
test in Hela S3 cells: Inhibits DNA
Confidential study
Limited study details reported in a
confidential study.
synthesis by 50% at greater than 300 (iM
(Measured for the free base)
4-630
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Other
Substituted amine phosphate
component: Sex-linked recessive
lethal/reciprocal translocation: Results
were considered equivocal based on
0.18% and 0.36% total lethality
following oral and injection exposure,
respectively, compared to control total
lethal of 0.07% for oral and 0.09% for
injection (Measured for the free base)
Confidential study
Reported in a confidential study.
Substituted amine phosphate
component: Drosophila Muller-5 test:
Negative for mutagenicity (Measured for
the free base)
Confidential study
Insufficient study details were
reported in a confidential study.
Substituted amine phosphate
component: Drosophila melanogaster
Sex-linked recessive lethal: No
Confidential study
Limited study details reported in a
confidential study.
mutagenic effects were observed
(Measured for the free base)
Substituted amine phosphate
component: In vitro flow cytometric
DNA repair assay: Negative for
genotoxic effects (Measured for the free
base)
Confidential study
Reported in a confidential study;
nonguideline study.
Substituted amine phosphate
component: Microscreen assay: Positive
for genetic toxicity in E.coli WP2 cells
Confidential study
Reported in a confidential study;
nonguideline study.
4-631
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Growth and genotoxic
effects to bacteria (Salmonella
typhimurium) and yeast (Saccharomyces
cerevisiae): Non-mutagenic in
S. typhi murium with or without S-9 mix.
The growth of eight out of nine strains
tested was delayed by 10 mM during 24
hr cultivation. S. cerevisiae strain was
tested, and did not recover its growth
following 48 hour cultivation. (Measured
for the free base)
Confidential study
Limited study details reported in a
confidential study.
Piperazine: Mammalian cell
transformation test: Negative in mouse
BALB/3T3 cells; piperazine did not
induce transformed foci
ECHA, 2011
Study details reported in secondary
source; according to EU method
B.21.
Reproductive Effects
MODERATE: Hazard potential for reproductive toxicity of the substituted amine phosphate mixture is
estimated to be Moderate based on data for the piperazine moiety from piperazine dihydrochloride; rats
exposed to 300 mg/kg/day had decreased litter size in both generations. The NOAEL is identified at 125
mg/kg/day; there is uncertainly if effects could occur at doses between 125 and 250 mg/kg/day (the criteria
cutoff dose for a Low hazard designation is >250 mg/kg/day). There were no adequate reproductive toxicity
data located for the substituted amine phosphate mixture or substituted amine phosphate component of the
mixture.
Reproduction/
Developmental Toxicity
Screen
No data located.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
4-632
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproduction and
Fertility Effects
Piperazine: Rat, oral, 2-generation
reproduction toxicity study; at 300
mg/kg/day: Decreased body weight gain
in F0 males and in both sexes of Fi
parental generation; no effect on number
of pregnancies; decreased litter size in
both generations (91% - F0, 85% - Fi
offspring); reduction of implantation
sites in F, females; no difference in
offspring sex ratios.
NOAEL = 227 mg/kg/day piperazine
dihydrochloride (-125 mg/kg/day
piperazine base)
LOAEL = 544 mg/kg/day piperazine
dihydrochloride (-300 mg/kg/day
piperazine base)
ECHA, 2011
Reported in a secondary source.
Test substance identified as
piperazine dihydrochloride.
Piperazine: Rat, oral; potential for
reproductive toxicity
NOAEL = 250 mg/kg/day
Professional judgment;
Confidential study
Test substance is identified as
piperazine dihydrochloride; a
LOAEL was not identified.
Reported in a confidential study.
Substituted amine phosphate
component: There were no treatment-
related macroscopic or microscopic
effects on mammary glands, ovaries,
prostate, seminal vesicles, testes and
uterus in rats and mice in a 13-week
study. (Measured for the free base)
Confidential study
Limited study details reported in a
confidential study.
4-633
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Developmental Effects
MODERATE: Hazard potential for developmental toxicity of the substituted amine phosphate mixture is
estimated to be Moderate based on data for piperazine moiety from piperazine phosphate and professional
judgment. There is uncertainty if effects could occur at doses between 94 and 250 mg/kg/day because a
LOAEL was not identified (the criteria cutoff dose for a Low hazard designation is >250 mg/kg/day).
Embryotoxicity was reported in conjunction with maternal toxicity and was considered to be a secondary
effect. Data for the substituted amine phosphate component showed no developmental effects in rats
exposed during gestation to doses up to 1,060 mg/kg-day. A conservative approach was used since there
were no measured values for the substituted amine phosphate mixture.
Reproduction/
Developmental Toxicity
Screen
Piperazine: Rabbit, oral; potential for
developmental toxicity
NOEL = 225 mg/kg/day
Professional judgment;
Confidential study
Test substance identified as
piperazine phosphate; a LOAEL
was not identified. Reported in a
confidential study.
Piperazine: Rat, oral; potential for
developmental toxicity
NOEL = 1,000 mg/kg/day
Professional judgment;
Confidential study
Test substance identified as
piperazine phosphate; a LOAEL
was not identified. Reported in a
confidential study.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
Prenatal Development
Substituted amine phosphate
component: Signs of maternal toxicity
at 136 mg/kg/day included decreased
body weight and feed consumption,
hematuria (23/25 rats), indrawn flanks
(7/25 rats), and piloerection (1/25 rats).
No adverse effects on gestational
parameters and no signs of
developmental toxicity were noted.
NOAEL >1,060 mg/kg/day (Measured
for the free base)
Confidential study
Reported in a confidential study.
4-634
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Piperazine: Rabbit, oral, gestation days
(GDs) 6-18. At 210 mg/kg/day
piperazine base: maternal neurotoxicity,
decreased body weight and food
consumption; embryotoxic effects as
resorption, retardation of ossification,
and reduced fetal weight. These effects
were considered secondary to maternal
toxicity; no developmental effects or
significant maternal toxicity was
reported in the 94 mg/kg/day dose group.
NOAEL (maternal toxicity) = 42
mg/kg/day piperazine base
LOAEL (maternal toxicity) = 94
mg/kg/day piperazine base
NOAEL (developmental) = 94
mg/kg/day piperazine base
ECHA, 2011
Reported in a secondary source.
Test substance identified as
piperazine phosphate;
Developmental effects occurred at
210 mg/kg/day piperazine base;
however, these effects occurred in
conjunction with maternal toxicity
and are considered secondary
effects.
Piperazine: Rat, oral, GD 6-15. At 210
mg/kg/day piperazine base: maternal
toxicity: excessive salivation, lethargy
and reduced body weight gain, body
weight and food consumption at 2,100
mg/kg/day; No embyrotoxic effects
reported.
NOAEL (maternal toxicity) = 420
mg/kg/day piperazine base
LOAEL (maternal toxicity) = 2,100
mg/kg/day piperazine base
NOAEL (developmental) = 2,100
mg/kg/day piperazine base
ECHA, 2011
Reported in a secondary source.
Test substance identified as
piperazine phosphate.
Piperazine: Rabbit, oral; potential for
developmental effects
NOAEL = 225 mg/kg/day
Professional judgment
Estimated based on professional
judgment.
Postnatal Development
No data located.
4-635
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Neurotoxicity
LOW: Neurotoxicity hazard potential of the substituted amine phosphate mixture is estimated to be low
based on expert judgment.
Neurotoxicity Screening
Battery (Adult)
Potential for neurotoxicity is expected to
be low.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
4-636
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Repeated Dose Effects
MODERATE: Repeated dose effects from the substituted amine phosphate mixture is estimated based on
effects following repeated oral exposure to the substituted amine phosphate component in rats. Decreased
body weight gain and feed consumption along with stones and diffuse epithelial hyperplasia in the urinary
bladder were reported at a dose of 72 mg/kg/day. No data were located for the substituted amine phosphate
mixture or salts.
Substituted amine phosphate
component: Rat 28-day dietary toxicity
study: Clinical signs included a dose-
related increase in piloerection, lethargy,
bloody urine spots in the cage and on the
pelage of animals, and
chromodacryorrhea. The incidence of
urinary bladder calculi and urinary
bladder hyperplasia in treated animals
was dose-dependent, with a significant
relationship between the calculi and
hyperplasia. Calculi composition
indicated the presence of an organic
matrix containing the substituted amine
phosphate component, phosphorus,
sulfur, potassium, and chloride. Crystals
of its monophosphate were identified in
the urine.
NOAEL: 2,000 ppm (240 mg/kg/day),
excluding the observed increase in water
consumption and the incidence of
crystalluria
LOAEL: 4,000 ppm (475 mg/kg/day)
based on the formation of calculus
(Measured for the free base)
Confidential study
Reported in a confidential study.
4-637
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Rabbit and dog 28-day
dietary toxicity study: No significant rise
in the body temperature of rabbits was
noted. Gross histological examination of
the heart, lung, liver, spleen, thyroid,
pancreas, intestines, kidneys and bladder
did not show pathological changes. A
zone of fat was found in the inner part of
the renal cortex in 2 dogs, but also in the
kidneys of 3 control dogs. (Measured for
the free base)
Confidential study
Insufficient study details were
reported in a confidential study.
Unspecified number of animals
tested.
Substituted amine phosphate
component: Rat 28-day dietary toxicity
study: Incidence and size of bladder
stones were directly related to the
amount of substance administered. The
larger stones were found to be
unchanged in a matrix of protein, uric
acid and phosphate.
Confidential study
Insufficient study details were
reported in a confidential study.
Lowest effective dose (LED): 1,500 ppm
(-125 mg/kg) in males (Measured for the
free base)
4-638
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Rat 90-day dietary toxicity
study: 1 male rat administered 18,000
ppm and 2 males administered 6,000
ppm died. Mean body weight gain and
feed consumption were reduced. Stones
and diffuse epithelial hyperplasia in the
urinary bladders were observed in male
rats of all treatment groups. Focal
epithelial hyperplasia was observed in
only 1 male. A second and third 13-week
repeated dose toxicity study was
conducted in rats at a dose range of 750
to 18,000 ppm bladder stones were
observed at all dose levels.
LOAEL: 750 ppm (72 mg/kg-day) based
on urinary bladder stones (Measured for
the free base)
Confidential study
Reported in a confidential study.
4-639
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Mouse 90-day dietary
toxicity study: A single female mouse
died after receiving 9,000 ppm. Mean
body weight gain relative to controls was
depressed. The incidence of mice with
bladder stones was dose-related and was
greater in males than in females. 60% of
mice having bladder ulcers also had
urinary bladder stones. Bladder ulcers
were multifocal or associated with
inflammation (cystitis). Epithelial
hyperplasia and bladder stones were
observed together in 2 mice. Also,
epithelial cell atypia was seen.
NOAEL: 6,000 ppm (600 mg/kg-day)
LOAEL: 9,000 ppm (900 mg/kg-day)
(Measured for the free base)
Confidential study
Reported in a confidential study.
Substituted amine phosphate
component: Increased incidence of
acute and chronic inflammation and
epithelial hyperplasia of the urinary
bladder was observed in mice following
oral (feed) exposure for up to 103 weeks.
There was also increased incidence of
bladder stones in male mice.
LOAEL = 2,250 mg/kg diet (lowest dose
tested) (Measured for the free base)
Confidential study
Reported in a confidential study.
Repeated dose effects described in
a carcinogenicity bioassay study.
Substituted amine phosphate
component: Dog 1-Year dietary toxicity
study: Crystalluria started 60 to 90 days
into treatment and persisted during the
study period. No other effects were
observed.
Confidential study
Insufficient study details were
reported in a confidential study.
4-640
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Rat 30-month dietary
toxicity study: Neither accumulation of
calculi nor any treatment-related urinary
bladder lesions were found. (Measured
for the free base)
Confidential study
Insufficient study details were
reported in a confidential study.
Substituted amine phosphate
component: Rat 24 to 30-month dietary
toxicity study: A dose-related trend for
dilated glands in glandular gastric
mucosa and inflammation in
nonglandular gastric mucosa was
observed. Urinary bladder calculi
formation was not observed. (Measured
for the free base)
Confidential study
Insufficient study details were
reported in a confidential study.
Piperazine: Rat 90-day dietary toxicity
study: Only effect noted was a treatment-
related decrease in body weight gain
(>10%)
NOAEL: 627 mg/kg-day
LOAEL = 2,394 mg/kg-day
ECHA, 2011
According to guideline: FDA 1986,
Toxicological principles for Safety
Assessment of Direct Food
Additives and Color Additives
Used in Food; sufficient study
details reported in a secondary
source; dose recalculated to
piperazine base.
Immune System Effects
Potential for immunotoxicity is expected
to be low.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Substituted amine phosphate
component: No inhibition of in vitro
murine lymphocyte mitogenesis.
(Measured for the free base)
Confidential study
Reported in a confidential study.
4-641
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Skin Sensitization
LOW: Neither the substituted amine phosphate mixture nor the piperazine pyrophosphate component are
skin sensitizers.
Skin Sensitization
Substituted amine phosphate mixture:
No skin sensitization in guinea pigs
using Magnusson-Kligman assay
(Estimated by analogy)
Professional judgment;
Confidential study
Based on closely related analogs
with similar structures, functional
groups, and physical/chemical
properties.
Substituted amine phosphate mixture:
Not a skin sensitizer based on local
lymph node assay (LLNA) in the mouse.
Submitted confidential study
Study details reported in a
confidential study; conducted
according to OECD 429;
Piperazine pyrophosphate: No skin
sensitization in guinea pigs using
Magnusson-Kligman assay
Submitted confidential study
Study details reported in a
confidential study; test substance
purity >95%; study conducted
according to OECD 406
Respiratory Sensitization
MODERATE: Respiratory sensitization hazard potential for the substituted amine phosphate mixture is
estimated to be Moderate based on analogy to the piperazine-containing compounds.
Respiratory
Sensitization
Piperazine moiety: Hazard potential for
respiratory sensitization.
(Estimated by analogy)
Professional judgment
Estimated based on analogy to
piperazine-containing compounds.
Eye Irritation
MODERATE: Based on indications of mild to moderate eye irritation in rabbits for both the substituted
amine phosphate and piperazine pyrophosphate components of the substituted amine phosphate mixture.
In addition, eye irritation hazard due to the substituted amine phosphate mixture is estimated to be
Moderate based on data for a confidential analog showing eye irritation in rabbits.
Eye Irritation
Substituted amine phosphate mixture:
Moderate eye irritation in rabbits.
(Estimated by analogy)
Professional judgment;
Confidential studies
Reported in a confidential study.
Based on two closely related
analogs with similar structures,
functional groups, and physical/
chemical properties.
Substituted amine phosphate
component: Mildly irritating to rabbit
eyes.
Submitted confidential study
Limited study details reported in a
confidential study.
Piperazine pyrophosphate: Moderately
irritating to rabbit eyes.
Submitted confidential study
Study details reported in a
submitted confidential study.
4-642
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Dermal Irritation
VERY LOW: Based on no indication of dermal irritation for the substituted amine phosphate component
and no irritation to mild irritation for the piperazine pyrophosphate component of the substituted amine
phosphate mixture.
Dermal Irritation
Substituted amine phosphate mixture:
Not irritating to rabbit skin.
(Estimated by analogy)
Professional judgment;
Submitted confidential study
Reported in a confidential study.
Based on closely related analogs
with similar structures, functional
groups, and physical/chemical
properties.
Substituted amine phosphate
component: Not irritating to rabbit skin.
Submitted confidential study
Study details reported in a
confidential study.
Piperazine pyrophosphate: Not
irritating to mild irritation to rabbit skin.
Submitted confidential study
Study details reported in a
submitted confidential study.
Endocrine Activity
There were insufficient data located to t
endocrine system. In one study, the subs
activity in vitro in a yeast two-hybrid ass
escribe the effect of the substituted amine phosphate mixture on the
tituted amine phosphate component did not exhibit estrogenic
ay.
Substituted amine phosphate
component: Showed no estrogenic
activity (no change in B-galactosidase
activity) in an in vitro yeast two-hybrid
assay in Sacchctromyces cerevisicte Y
190. (Measured for the free base)
Confidential study
Reported in a confidential study.
No guideline followed.
Immunotoxicity
There is estimated to be no potential for immunotoxicity of the substituted amine phosphate mixture based
on expert judgment. Data located for the substituted amine phosphate component are not sufficient to
determine the hazard potential for this endpoint.
Immune System Effects
Potential for immunotoxicity is expected
to be low.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Substituted amine phosphate
component: No inhibition of in vitro
murine lymphocyte mitogenesis.
(Measured for the free base)
Confidential study
Reported in a confidential study.
4-643
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ECOTOXICITY
ECOSAR Class
Substituted amine phosphate component: Confidential structure class; Piperazine pyrophosphate: Aliphatic
amines.
Acute Toxicity
MODERATE: Acute toxicity hazard for the substituted amine phosphate mixture is estimated based on an
experimental LCS0 value of 21 mg/L in Daphnia magna for the piperazine moiety of the ionized mixture
which represents the most conservative value. Although measured toxicity values for the substituted amine
phosphate free base indicate a low hazard designation for this component of the mixture, a conservative
approach was used since there are no measured values for the substituted amine phosphate mixture.
Fish LC
50
Substituted amine phosphate
component: Leuciscus idas melanotus
48-hour LC50 >500 mg/L (Experimental)
Substituted amine phosphate
component: Oryzias latipes 48-hour
LC50 = 1,000 mg/L
(Experimental)
Substituted amine phosphate
component: Poecilia reticulata 96-hour
LC50 >3,000 mg/L
(Experimental)
Substituted amine phosphate
component: Poecilia reticulata 4,400
mg/L dose lethal to <10%
(Experimental)
Piperazine: Poecilia reticulata (guppy)
96-hour LC50 >1,800 mg/L
Semi-static conditions
(Experimental)
Substituted amine phosphate
component: Fish 96-hour LC50 = 391
mg/L
(Estimated)
ECOSAR: Confidential structure class
Confidential study
Confidential study
Confidential study
Confidential study
ECHA, 2011
ECOSAR version 1.11
Study details reported in a
confidential study.
Study details reported in a
confidential study.
Study details reported in secondary
source.
Study details reported in a
confidential study; unspecified
exposure duration.
Study details reported in a
secondary source; according to EU
Method C.l.
4-644
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Fish 96-hour LC50 = 14,272
mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Piperazine pyrophosphate: Fish 96-
hour LC50 >10,000 mg/L
(Estimated)
ECOSAR: Aliphatic amines
ECOSAR version 1.11
No effects at saturation (NES): The
LC50 value exceeds the water
solubility (1.0e+6 mg/L); NES are
predicted for these endpoints.
Piperazine pyrophosphate: Fish 96-
hour LC50 >10,000 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The LC50 value exceeds the
water solubility (1.0e+6 mg/L); NES
are predicted for these endpoints.
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Daphnid LCS0
Substituted amine phosphate
component: Daphnict magna 48-hour
LC50 >2,000 mg/L
(Experimental)
Confidential study
Study details reported in a
confidential study.
Piperazine: Daphnia magna 48-hour
LC50 = 21 mg/L
Static conditions
(EU Method C.2)
(Experimental)
ECHA, 2011
Study details reported in a
secondary source; guideline study.
4-645
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Daphnid 48-hour LC5n =
144 mg/L
(Estimated)
ECOSAR: Confidential structure class
ECOSAR version 1.11
Substituted amine phosphate
component: Daphnid 48-hour LC50 =
4,805 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Piperazine pyrophosphate: Daphnid
48-hour LC50 >10,000 mg/L
(Estimated)
ECOSAR: Aliphatic amines
ECOSAR version 1.11
Piperazine pyrophosphate: Daphnid
48-hour LC50 >10,000 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The LC50 value exceeds the
water solubility (l.OxlO6 mg/L);
NES are predicted for these
endpoints. Narcosis classes (neutral
organics) are provided for
comparative purposes; DfE
assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of
action relative to narcosis.
Substituted amine phosphate
component: Scenedesmus pannonicus 4-
day EC50 = 940 mg/L
(Experimental);
4-day NOEC = 320 mg/L
(Experimental)
Confidential study
Reported in a confidential study.;
Study details and test conditions
were not provided.
4-646
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Green algae 96-hour EC5n =
325 mg/L
(Estimated)
ECOSAR: Confidential structure class
ECOSAR version 1.11
Substituted amine phosphate
component: Green algae 96-hour EC50 =
4,396 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Piperazine pyrophosphate: Green algae
96-hour EC50 >10,000 mg/L
(Estimated)
ECOSAR: Aliphatic amines
ECOSAR version 1.11
Piperazine pyrophosphate: Green algae
96-hour EC50 >10,000 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The LC50 value exceeds the
water solubility (l.OxlO6 mg/L);
NES are predicted for these
endpoints.
Chronic Aquatic Toxicity
LOW: The substituted amine phosphate mixture chronic toxicity hazard potential is estimated based on
measured chronic toxicity values for the piperazine moiety, on estimated values for piperazine
pyrophosphate, and on estimated values for the substituted amine phosphate component of the mixture, for
all three surrogate species.
Fish ChV
Substituted amine phosphate
component: Jordanellct floridcte 35-day
NOEC >1,000 mg/L (Experimental)
Confidential study
Reported in a confidential study;
study details and test conditions
were not provided.
Substituted amine phosphate
component: Sctlmo gctirdneri NOEC
(macroscopic) = 500 mg/L
(Experimental);
NOEC (microscopic) <125 mg/L
(Experimental)
Confidential study
Reported in a confidential study;
study details and test conditions
were not provided.
4-647
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
component: Daphnia magna 21-day
LC50 = 32-56 mg/L, 21-day LC100 = 56
mg/L, 21 day NOEC = 18 mg/L
(Experimental)
Confidential study
Reported in a confidential study;
study details and test conditions
were not provided.
Substituted amine phosphate
component: Fish ChV = 1,102 mg/L
(Estimated)
ECOSAR: Confidential structure class
ECOSAR version 1.11
Substituted amine phosphate
component: Fish ChV = 1,076 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Piperazine pyrophosphate: Fish ChV
>10,000 mg/L
(Estimated)
ECOSAR: Aliphatic amines
ECOSAR version 1.11
Piperazine pyrophosphate: Fish ChV
>10,000 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The LC50 value exceeds the
water solubility (l.OxlO6 mg/L);
NES are predicted for these
endpoints. Narcosis classes (neutral
organics) are provided for
comparative purposes; DfE
assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of
action relative to narcosis.
4-648
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnid ChV
Piperazine: Daphnia magna 21-day
NOEC = 12.5 mg/L (immobile neonates)
LOEC = 25 mg/L (immobile neonates)
NOEC = 50 mg/L (reproduction)
NOEC = 25 mg/L (growth)
Semi-static conditions
(OECD Guideline 211)
(Experimental)
ECHA, 2011
Study details reported in a
secondary source; guideline study.
Substituted amine phosphate
component: Daphnid ChV = 14.85
mg/L
(Estimated)
ECOSAR: Confidential structure class
ECOSAR version 1.11
The toxicity value was estimated
through application of acute to
chronic ratios (ACRs).
Substituted amine phosphate
component: Daphnid ChV = 343.93
mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
Piperazine pyrophosphate: Daphnid
ChV = 2,408 mg/L
(Estimated)
ECOSAR: Aliphatic amines
ECOSAR version 1.11
Piperazine pyrophosphate: Daphnid
ChV >10,000 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The LC50 value exceeds the
water solubility (l.OxlO6 mg/L);
NES are predicted for these
endpoints.
4-649
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green Algae ChV
Piperazine: Selenastrum cctpricornutum
(Pseiidokirchnerella subcapitata) 72-
hour NOEC >1,000 mg/L (growth rate)
Static conditions
(OECD Guideline 201)
(Experimental)
ECHA, 2011
Study details reported in secondary
source; guideline study.
Substituted amine phosphate
component: Green algae ChV = 0.70
mg/L
(Estimated)
ECOSAR: Confidential structure class
ECOSAR version 1.11
The toxicity value was estimated
through application of ACRs.
Substituted amine phosphate
component: Green algae ChV = 81.26
mg/L
(Estimated)
ECOSAR: Confidential structure class
ECOSAR version 1.11
The toxicity value was estimated
through application of ACRs.
Substituted amine phosphate
component: Green algae ChV = 313.17
mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Piperazine pyrophosphate: Green algae
ChV >10,000 mg/L
(Estimated)
ECOSAR: Aliphatic amines
ECOSAR version 1.11
Piperazine pyrophosphate: Green algae
ChV = 259,000 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
Narcosis classes (neutral organics)
are provided for comparative
purposes; DfE assessment
methodology will use the lowest
estimated toxicity value provided
by ECOSAR classes that have a
more specific mode of action
relative to narcosis.
4-650
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL FATE
Transport
The substituted amine phosphate mixture is comprised of approximately 50% piperazine pyrophosphate and
50% of a substituted amine phosphate. Both of these ionic compounds have high estimated water solubility.
Therefore, this mixture can be expected to partition predominately to water and soil. The components are
anticipated to migrate from soil into groundwater based on the estimated Koc values of <100. Volatilization
from either wet or dry surfaces is not expected to be an important fate process based on the estimated vapor
pressure of this mixture.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment
In water, the substituted amine
phosphate mixture components are
expected to be fully dissociated.
Volatilization of the dissociated
species from either wet surfaces is
not expected to be an important fate
process.
Piperazine pyrophosphate: <10 10
(Estimated)
EPI
Substituted amine phosphate: <10 10
(Estimated)
EPI
Sediment/Soil
Adsorption/Desorption
Piperazine pyrophosphate: 62
(Estimated)
EPI
Coefficient - Koc
Substituted amine phosphate: 13
(Estimated)
EPI
Level III Fugacity Model
Piperazine pyrophosphate:
Air: <1% (Estimated)
Water = 20%
Soil = 80%
Sediment: <1%
EPI
4-651
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate:
Air: <1% (Estimated)
Water = 35%
Soil = 65%
Sediment: <1%
EPI
Persistence
HIGH: The substituted amine phosphate mixture is estimated to show high persistence in the environment
based on experimental data for the organic components. The persistence of the inorganic phosphate
components of this mixture were not considered to be a factor in the assignment of this hazard designation.
The organic component of the confidential substituted amine phosphate undergoes biodegradation according
to measured results; however the rates of removal are slow. The organic portion of the substituted amine
phosphate component is considered to be inherently biodegradable, not readily biodegradable.
Water
Aerobic Biodegradation
Piperazine pyrophosphate:
Days-Weeks (Primary survey model)
Weeks-Months (Ultimate survey model)
(Estimated)
EPI
Piperazine: Not readily biodegradable
according to OECD 301C; 1.4%
degradation after 2 weeks. (Measured for
free base)
MITI, 1998
Measured biodegradation indicate
slow removal by this pathway for the
dissociated species, piperazine.
Piperazine: Readily biodegradable
according to OECD 30IF; 65-70% in 2
weeks by 02 and C02 and 39% by
dissolved organic carbon and OECD
30ID; 90% in 2 weeks. Inherently
biodegradable according to 302A; 96%
degradation after 52 days. (Measured for
free base)
ECHA, 2011
Measured biodegradation indicate
potential for biodegradation for the
dissociated species, piperazine.
Substituted amine phosphate:
Weeks (Primary survey model)
Months (Ultimate survey model)
(Estimated)
EPI
4-652
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Substituted amine phosphate
dissociation product: The range of
reported aerobic biodegradation rates span
from 0% removal to <30% removal after
14 days with activated sludge. (Measured
for dissociation species)
Confidential study
Measured biodegradation indicate
limited removal by this pathway for a
dissociated species of the substituted
amine phosphate.
Volatilization Half-life for
Model River
>1 year (Estimated)
Professional judgment
Based on the estimated Henry's Law
Constant and the low rates of
volatilization for completely
dissociated species; applies to both
ionic solids present in the substituted
amine phosphate mixture.
Volatilization Half-life for
Model Lake
>1 year (Estimated)
Professional judgment
Based on the estimated Henry's Law
Constant and the low rates of
volatilization for completely
dissociated species; applies to both
ionic solids present in the substituted
amine phosphate mixture.
Soil
Aerobic Biodegradation
Substituted amine phosphate
dissociation product: Not readily
biodegradable: 0% biodegradation
detected after 2 weeks with 100 ppm in 30
ppm activated sludge (OECD TG 301C)
(Measured); 0% degradation after 28 days
with 100 mg DOC/L in activated sludge
(Zahn-Wellens test, OECD 302B).
(Measured)
Piperazine: In a variety of soil samples,
complete degradation took 24 to 68 days
with a lag period of 15 to 60 days
respectively. Some samples reported no
degradation at 3 months. (Measured for
free base)
Confidential study; EU RAR,
2005
Value for dissociation product of the
substituted amine phosphate
component and piperazine
pyrophosphate dissociation species,
piperazine. Measured biodegradation
demonstrate removal by this
pathway.
4-653
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Anaerobic
Biodegradation
Substituted amine phosphate
dissociation product: 0-8.9% nitrification
was observed after 28 days incubation
with bacteria in Webster silty clay loam
under anaerobic conditions. (Measured)
Piperazine: No degradation after 6
months under denitrifying, sulfate
reducing, or methanogenic conditions.
(Measured for free base)
Confidential study; Bae, 2002
Value for dissociated component of
the substituted amine phosphate and
piperazine pyrophosphate
dissociation species, piperazine.
Measured biodegradation rates
demonstrate no removal by this
pathway.
Soil Biodegradation with
Product Identification
Substituted amine phosphate
dissociation product: Nitrification occurs
in soil at a low rate (0.7 % organic N
found as N03-N in week 10, and 0 % in
week 28). (Measured)
Confidential study
Nonguideline study for the
dissociated product of the substituted
amine phosphate component.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
No data located.
Reactivity
Photolysis
Substituted amine phosphate: Not a
significant fate process (Estimated)
Mill, 2000; Professional judgment
This compound does not contain
functional groups that would be
expected to absorb light at
environmentally significant
wavelengths.
Piperazine: 0.8 hour half-life
(Measured for free base)
OECD SIDS, 2004
Value for piperazine pyrophosphate
dissociation species, piperazine.
Hydrolysis
Not a significant fate process (Estimated)
Wolfe and Jeffers, 2000;
Professional judgment
Both ionic solids present in the
substituted amine phosphate mixture
do not contain functional groups that
would be expected to hydrolyze
readily under environmental
conditions.
4-654
-------
Substituted Amine Phosphate Mixture
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Environmental Half-Life
Substituted amine phosphate: 120 days
(Estimated)
EPI; PBT Profiler
Half-life estimated for the
predominant compartment, as
determined by EPI and the PBT
Profiler methodology.
Piperazine pyrophosphate: 75 days
(Estimated)
EPI; PBT Profiler
Bioaccumulation
LOW: The substituted amine phosphate mixture is expected to have low potential for bioconcentration and
bioaccumulation based on estimated BCF and BAF values of <100 for the two components of the mixture,
piperazine pyrophosphate and substituted amine phosphate.
Fish BCF
Piperazine pyrophosphate: 3.2
(Estimated)
EPI
Substituted amine phosphate
component: 3.2 (Estimated)
EPI
BAF
Piperazine pyrophosphate: 0.9
(Estimated)
EPI
Substituted amine phosphate
component: 0.9 (Estimated)
EPI
Metabolism in Fish
Substituted amine phosphate
dissociation product: Uptake,
bioaccumulation and elimination study
with 14C-labeled compound in fathead
minnow (BCF = 0.48 and 0.26) and
rainbow trout (BCF = 0.11, 0.05, 0.03)
(Measured)
Confidential study
Nonguideline study that supports the
low bioaccumulation potential for
this substance and its dissociation
products.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
These chemicals were not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-655
-------
Adeka-Palmarole. Product information sheet. 2011. http://www.adeka-
palmarole.com/index.php?option=com content&view=article&id=195%3Aadk-stab-fp-2100i&catid=58&Itemid=156 (accessed on
June 07, 2011).
Bae, HS; Cho, YG; Oh, SE; et al. Anaerobic degradation of pyrrolidine and piperidine coupled with nitrate reduction. Chemosphere
2002, 48:329-334.
CDC (Centers for Disease Control and Prevention). Fourth National Report on Human Exposure to Environmental Chemicals,
Updated Tables, February 2011. Available at: http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf as of May 10, 2011.
ECHA (European Chemicals Agency). Information on registered substances. 2011. http://apps.echa.europa.eu/registered/registered-
sub.aspx (accessed on July 13, 2011).
ECOSAR/EPI (EPIWIN/EPISUITE) Estimations Programs Interface for Windows, Version 1.11. U.S. Environmental Protection
Agency: Washington D.C. http J/www, epa. gov/opptintr/exposure/.
U.S. EPA (Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing
Data. U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
EPA Sustainable Futures. UsingNonCcmcer Screening within the SFInitiative. U.S. Environmental Protection Agency: Washington
D.C. available at: http://www.epa.gOv/opptintr/sf/pubs/noncan-screen.htm#svstemic as of February 09, 2011.
EPI (EPIWIN/EPISUITE) Estimation Program Interface for Windows, Version 4.0. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
European Union Risk Assessment Report. Piperazine Risk Assessment CAS No: 110-85-0 EINECS No: 203-808-3. European
Chemicals Bureau. 3rd Priority List v. 56. 2005.
European chemical Substances Information System (ESIS) Classification, Labeling and Packaging of Dangerous Substances Annex
VI to Regulation (EC) No 1272/2008 [Online] available at: http://esis.irc.ec.europa.eu/index.php?PGM=cla as of March 14, 2012.
IARC. International Agency for Research on Cancer World Health Organization.
4-656
-------
IUCLID (International Uniform Chemical Information Database). Dataset for Piperazine. European Commission - European
Chemicals Bureau. 2000.
MITI (Japanese Ministry of International Trade and Industry). Biodegradation and bioaccwmrfation data of existing chemicals based
on the CSCL Japan. Compiled under the supervision of Chemical Products Safety Division, Basic Industries Bureau, Ministry of
International Trade & Industry, Japan; Chemicals Inspection & Testing Institute, Japan. Ed.; Japan Chemical Industry Ecology-
Toxicology & Information Center: 1998.
Mill, T. (2000) Photoreactions in Surface Waters. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for
Chemicals, Environmental Health Sciences (355-382). Boca Raton: Lewis Publishers.
OECD SIDS (Organisation of Economic Cooperation and Development Screening Information Dataset). Initial Assessment Profile.
SIAM 18, 20-23. 2004. http://webnet.oecd.org/Hpv/UI/handler.axd?id=fab0c5dd-0473-446e-9c90-a839404aa31f (accessed on July,
13, 2011).
OncoLogic. U.S. EPA and LogiChem, Inc. Version 7.0. 2008.
PBT Profiler. Persistent (P), Bioaccumulative (B), and Toxic (T) Chemical (PBT) Profiler. U.S. Environmental Protection Agency:
Washington D.C. www.pbtprofiler.net.
Weil, E. Kirk-Othmer Encyclopedia of Chemical Technology. New York, NY: John Wiley & Sons; Flame Retardants, Phosphorus.
Online Posting Date: October 18, 2001. 2001.
Wolfe, N; Jeffers, P. (2000) Hydrolysis. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for Chemicals,
Environmental Health Sciences (311-334). Boca Raton: Lewis Publishers.
4-657
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Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Tetrabromobisphenol A Bis (2,3-
dibromopropyl) Ether
21850-44-2
L
M
M
M
M
L
M
L
L
L
L
L
VH
H
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-658
-------
Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether
CASRN: 21850-44-2
MW: 943.62
MF: C2iH2oBr802
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: 0(clc(cc(cclBr)C(clcc(c(OCC(Br)CBr)c(cl)Br)Br)(C)C)Br)CC(Br)CBr
Synonyms: Benzene, l,r-(l-methylethylidene)bis[3,5-dibromo-4-(2,3-dibromopropoxy)-; l,r-(l-Methylethylidene)bis(3,5-dibromo-4-(2,3-
dibromopropoxy))benzene; l,r-(l-Methylethylidene)bis[3,5-dibromo-4-(2,3-dibromopropoxy)]benzene; l,l'-(Isopropylidene)bis(3,5-dibromo-4-(2,3-
dibromopropoxy)benzene); 1,1 '-(isopropylidene)bis [3,5 -dibromo-4-(2,3 -dibromopropoxy)benzene]; 1,1 '-propane-2,2-diylbis [3,5 -dibromo-4-(2,3 -
dibromopropoxy)benzene]; 2,2-Bis[3,5-dibromo-4(2,3-dibromopropoxy)phenyl]propane; 2,2-Bis[3,5-dibromo-4-(2,3-dibromopropyloxy)phenyl]propane; 2,2-Bis[4-
(2,3-dibromopropoxy)-3,5-dibromophenyl]propane; 3,3',5,5'-TetrabromobisphenolA bis92,3-dibromopropyl) ether; 4,4'-Isopropylidenebis[2,6-dibromo-l-(2,3-
dibromopropoxy)benzene]; 403AF; Bis(2,3-dibromopropoxy)tetrabromobisphenol A; Bromcal 66.8; Bromkal 66-8; D 5532; Dibromopropydian; FG 3100; FR 720;
Fire guard 3100; Flame Cut 121K; Flame Cut 121R; GX 5532; Propane, 2,2-bis[3,5-dibromo-4-(2,3-dibromopropoxy)phenyl]-; PE-68; Pyroguard SR 720; SR 720;
SAYTEX HP-800 A; HP-800 AG; HP-800 AGC; Tetrabromobisphenol A bis(2,3-dibromopropyl ether); Tetrabromobisphenol A bis(2,3-dibromopropyl) ether;
Tetrabromobisphenol-A-bis-2,3-dibromopropyl ether Tetrabromobisphenol-A-bis-2,3-dibromopropylether; TBBPA-DBPE
Chemical Considerations: This is a discrete organic chemical with a MW below 1,000. EPI v 4.0 was used to estimate physical/chemical and environmental fate
values as required. Measured values for available endpoints were incorporated into the estimations.
Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: None identified; although this compound contains a TBBPA backbone, degradation of this compound to
TBBPA has not been demonstrated in a published study. The hazards of the theoretical degradation products were not considered in this hazard assessment.
Analog: No analog
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: Polyhalogenated aromatic hydrocarbons, immunotoxicity (EPA, 2011).
Risk Phrases: Not classified by Annex I Directive 67/548/European Economic Community & IUCLID (Pakalin et al., 2007).
Hazard and Risk Assessments: Risk assessment complete for TBBPA bis (2,3-dibromopropyl) ether by the European Chemicals Bureau in 2007 (Pakalin et al.,
2007).
4-659
-------
Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
117 (Measured)
Tokyo Chemical Industry Co.,
2010; ChemSpider, 2011
Selected value for assessment.
114 (Measured)
NICNAS, 2001
Sufficient details were not available
to assess the quality of this study;
value reported in a secondary source.
90-100 (Measured)
IPCS, 1995; Great Lakes
Chemical Corporation, 1982a
These reported values may be for a
commercial mixture.
95 (Measured)
Mack, 2004
107.3 (Measured)
Reported as a range 104.3-116.6 using
Optical melting determination
ECHA, 2013
Nonguideline, non-good laboratory
practice (GLP) study reported in a
secondary source.
113.39 (Measured)
Differential scanning calorimeter
ECHA, 2013
Nonguideline, non-GLP study
reported in a secondary source.
Boiling Point (°C)
Decomposition at >270 (Measured)
IPCS, 1995
Decomposition is expected before the
boiling point is reached.
Vapor Pressure (mm Hg)
2.2 ± 0.15 x 10"4 at 20°C
Static test according to Organisation of
Economic Cooperation and Development
(OECD) TG 104 (Vapor pressure curve)
and EU Method A.4 (Vapor Pressure);
GLP study; Purity of test substance 95.1%
(Measured)
ECHA, 2013
Guideline study reported for FR-720
in a secondary source.
<10"8 (Estimated)
EPI; EPA, 1999
Cutoff value for nonvolatile
compounds according to HPV
assessment guidance.
4-660
-------
Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Water Solubility (mg/L)
<10° (Estimated)
EPI; EPA, 1999
Cutoff value for non soluble
compounds according to High
Production Volume assessment
guidance.
lxlO3 (Measured)
IPCS, 1995
Inadequate; these values are not
consistent with a non polar, highly
brominated material with a MW near
1,000.
99%.
ECHA, 2013
Cutoff value from a guideline study
reported in a secondary source.
Log K0„
12 (Estimated)
EPI; EPA, 1999
Estimated value is greater than the
cutoff value, >10, according to
methodology based on HPV
assessment guidance.
Flammability (Flash Point)
Autoignition: 740°C (Measured)
Ignition produced orange flame; according
to IEC 61241-2-1 Method B Minimum
ignition; GLP study
ECHA, 2013
Nonguideline study; purity of test
substance TDBPE 720 not stated.
Reported in a secondary source.
Autoignition: >500 mJ (Measured)
No ignition was observed; according to
IEC 61241-2-3 Minimum ignition energy;
GLP study
ECHA, 2013
Nonguideline; purity of test substance
TDBPE 720 not stated. Reported in a
secondary source.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Pyrolysis
No data located.
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
4-661
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Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
HUMAN HEALTH EFF
ECTS
Toxicokinetics
TBBPA bis (2,3-dibromopropyl) ether, as a neat material, is estimated not to be absorbed through the skin,
to have poor skin absorption when in solution, and to have poor absorption via the lungs and
gastrointestinal tract. An experimental study in rats showed that the majority (95%) of TBBPA bis (2,3-
dibromopropyl) ether is rapidly eliminated in the feces following single or multiple oral doses and
absorption is slow and minimal. However, if absorbed, TBBPA bis (2,3-dibromopropyl) ether is slowly
eliminated from the blood, with the liver being the main organ for deposition.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
Not absorbed through the skin as a neat
material and poor absorption through
skin when in solution; poor absorption
through the lung and gastrointestinal
tract. (Estimated by analogy)
Professional judgment
Based on closely related
confidential analogs with similar
structures, functional groups, and
physical/chemical properties.
Following single or repeated (5 or 10
days) oral administrations of 20 mg/kg
[14C]-TBBPA bis (2,3-dibromopropyl)
ether to male F-344 rats, the compound
was poorly absorbed from the
gastrointestinal tract and uptake to the
systemic circulation was considered
slow. The Cmax (0.6 (ig/mL) occurred at
7.4 hours after dosing. Distribution to the
tissues accounted for <1% of the dose at
96 hours while 95% of the dose (in [14C]
equivalents) was excreted in the feces
within 36 hours of administration.
Elimination in the urine accounted for
<0.1% of the administered dose and 1%
of the dose (as metabolites) was excreted
in the bile after 24 hours.
Knudsen et al., 2007; ECHA,
2013
Study details reported in primary
source.
4-662
-------
Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Other
Male Fischer-344 rats were dosed with
TBBA-DBPE by IV administration.
Fecal excretion of [14C] equivalents was
27% by 36h, 71% by 96h. Urinary
elimination was minimal (<0.1%). A
single peak that co-eluted with the
standard of TBBA-DBPE was detected
in extracts of whole blood following IV
administration. TBBA-DBPE
elimination from the blood was slow.
Kinetic constants following IV dosing
were: ti^: 24.8h; CLb: O.lmL/min.
Systemic bioavailability was 2.2%. Liver
was the major site of disposition.
ECHA, 2013
Well conducted study. Not
performed according to GLP and
standard testing guidelines.
Acute Mammalian Toxicity
LOW: Based on oral and dermal LDS0 values >2, 000 mg/kg and an inhalation LCS0 value >20 mg/L.
Acute Lethality
Oral
Mouse LD50 >20,000 mg/kg
IPCS, 1995
Limited study details reported in a
secondary source.
Rat oral LD50 > 2,000 mg/kg
ECHA, 2013
Sufficient study details reported in a
secondary source. GLP study
conducted using OECD guidelines.
Dermal
Mouse LD50 >20,000 mg/kg
IPCS, 1995
Limited study details reported in a
secondary source.
Rat dermal LD50 > 2,000 mg/kg
ECHA, 2013
Sufficient study details reported in a
secondary source. GLP study
conducted using OECD guidelines.
Inhalation
Mouse LC50 >87,000 mg/m3 (87 mg/L)
Great Lakes Chemical
Corporation, 1982b
Limited study details reported in a
secondary source.
Rat 1 hr-inhalation LC50 >24.4 mg/L;
Whole-body exposure to dust.
ECHA, 2013
Sufficient study details reported in a
secondary source.
Carcinogenicity
MODERATE: No data located. Estimated to have potential for carcinogenicity based on the potential for
alkylation and professional judgment.
OncoLogic Results
No data located.
4-663
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Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Carcinogenicity (Rat
and Mouse)
There is potential for carcinogenicity
effects based on a mechanistic
consideration of the potential for
alkylation (Estimated)
Professional judgment
Based on mechanistic
considerations.
Combined Chronic
Toxicity/
Carcinogenicity
No data located.
Genotoxicity
MODERATE: TBBPA bis (2,3-dibromopropyl) ether was mutagenic to Salmonella typhimurium in one
assay, while it was negative in other assays in S. Typhimurium and E. coli. This substance was also negative
for mutagenicity in mouse lymphoma cells. TBBPA bis (2,3-dibromopropyl) ether is also estimated to have
potential for genotoxicity based on the potential for alkylation. TBBPA bis (2,3-dibromopropyl) ether did
not cause chromosomal aberrations or sister chromatid exchanges in Chinese hamster ovary (CHO) cells
(in vitro), was negative in an in vivo micronucleus assay in mice and did not produce unscheduled DNA
synthesis in rats.
Gene Mutation in vitro
There is potential for mutagenicity based
on a mechanistic consideration of the
potential for alkylation. (Estimated)
Professional judgment
Based on closely related
confidential analogs with similar
structures and functional groups.
Positive, Ames assay (standard plate) in
Salmonella typhimurium strains TA1535
and TA100 with and without metabolic
activation and TA98 without metabolic
activation.
Great Lakes Chemical
Corporation, 1982a; ECHA,
2013
Sufficient study details reported.
Negative, Salmonella typhimurium
strains TA1535, TA1537, TA100 and
TA98 and Escherichia coli Wp2uvrA
with and without metabolic activation.
Submitted confidential study;
ECHA, 2013
Reported in a submitted confidential
study; Study conducted according to
GLP.
Negative, mouse lymphoma L5178Y
cells with and without metabolic
activation.
Submitted confidential study;
ECHA, 2013
Reported in a submitted confidential
study; Study conducted according to
GLP.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
Negative chromosomal aberrations in
CHO cytogenetic assay with and without
metabolic activation (precipitation was
observed at the highest concentration).
IPCS, 1995
Reported in a secondary source.
4-664
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Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Negative, sister chromatid exchanges in
CHO cells with and without metabolic
activation.
Submitted confidential study
Reported in a submitted confidential
study; Study conducted according to
GLP.
Chromosomal
Aberrations in vivo
Negative for micronucleated
polychromatic erythrocytes in B6C3F1
mice.
NTP, 2011; ECHA, 2013
Reported in a secondary source.
DNA Damage and
Repair
Negative for unscheduled DNA synthesis
assay in Sprague Dawley rats at 10, 50,
100, 500 or 1,000 (ig/mL.
IPCS, 1995
Reported in a secondary source.
Other (Mitotic Gene
Conversion)
Negative, unscheduled DNA synthesis,
rat hepatocytes.
Submitted confidential study
Reported in a submitted confidential
study; Study conducted according to
GLP.
Reproductive Effects
MODERATE: Estimated to have potential for reproductive effects baset
professional judgment.
on the potential for alkylation and
Reproduction/
Developmental Toxicity
Screen
There is potential for reproductive
effects based on a mechanistic
consideration of the potential for
alkylation (Estimated)
Professional judgment
Based on mechanistic
considerations.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
Reproduction and
Fertility Effects
No data located.
4-665
-------
Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Developmental Effects
MODERATE: Estimated to have potential for developmental effects based on the potential for alkylation
and professional judgment.
Reproduction/
Developmental Toxicity
Screen
There is potential for developmental
effects based on a mechanistic
consideration of the potential for
alkylation (Estimated)
Professional judgment
Based on mechanistic
considerations.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
Prenatal Development
No data located.
Postnatal Development
No data located.
Neurotoxicity
LOW: Estimated not to have potential for neurotoxicity based on expert judgment; no data located.
Neurotoxicity Screening
Battery (Adult)
Low potential for neurotoxicity.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Repeated Dose Effects
MODERATE: There is potential for liver toxicity because TBBPA bis (2,3-dibromopropyl) ether is a highly
brominated compound and potential for immunotoxicity associated with polyhalogenated aromatic
hydrocarbon structure. Located data were insufficient.
Potential for liver effects based on a
mechanistic consideration of this highly
brominated compound
(Estimated)
Professional judgment
Based on closely related
confidential analogs with similar
structures and functional groups.
Mice were administered TBBPA bis
(2,3-dibromopropyl) ether in their diet at
200 or 2,000 mg/kg-day for 90 days. No
deaths, or abnormal symptoms observed
in gross pathological examination.
NOAEL = 2,000 mg/kg-day (highest
dose tested)
IPCS, 1995; ECHA, 2013
Limited study details reported in a
secondary source. Reported study
details were not sufficient to
evaluate the study quality and were
considered insufficient to determine
a hazard designation.
Potential for immunotoxicity based on
polyhalogenated aromatic hydrocarbons
structure.
EPA, 201 la; Professional
judgment
Estimated based on the presence of
a structural alert.
4-666
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Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Skin Sensitization
LOW: Not a skin sensitizer in guinea pigs. There is potential for skin sensitization based on the potential
for alkylation.
Skin Sensitization
There is potential for skin sensitization
based on a mechanistic consideration of
the potential for alkylation.
(Estimated by analogy)
Professional judgment
Based on mechanistic
considerations.
Not sensitizing, guinea pigs
Submitted confidential study;
ECHA, 2013
Reported in a submitted confidential
study; Study conducted according to
GLP.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
LOW: Minimal eye irritation in rabbits clearing within 48 hours.
Eye Irritation
Low potential for eye irritation.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Workers report development of eye
irritation following exposure to a
complex mixture of airborne
contaminants that included TBBPA bis
(2,3-dibromopropyl) ether.
Great Lakes Chemical
Corporation, 1999
Evidence is based on isolated
incidents and workers were exposed
to a complex mixture of airborne
contaminants while melt processing
that uses thermoplastic resin
formulators containing this
substance as an additive.
Minimal irritation, rabbits; irritation was
reversed within 24-48 hours.
Submitted confidential study;
ECHA, 2013
Reported in a submitted confidential
study; Study conducted according to
GLP and OECD guidelines.
Dermal Irritation
LOW: Not a skin irritant in rabbits.
Dermal Irritation
Low potential for dermal irritation.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Negative, rabbits
Submitted confidential study;
ECHA, 2013
Reported in a submitted confidential
study; Study conducted according to
GLP and OECD guidelines.
4-667
-------
Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Workers report development of dermal
irritation following exposure to a
complex mixture of airborne
contaminants that included TBBPA bis
(2,3-dibromopropyl) ether.
Great Lakes Chemical
Corporation, 1999
Evidence is based on isolated
incidents and workers were exposed
to a complex mixture of airborne
contaminants while melt processing
that uses thermoplastic resin
formulators containing this
substance as an additive.
Endocrine Activity
Based on 4 in vitro assays, TBBPA bis (2,3-dibromopropyl) ether can interact with the endocrine system.
TBBPA bis (2,3-dibromopropyl) ether may have potential estrogenic and transthyretin-binding effects.
TBBPA bis (2,3-dibromopropyl) ether appears to inhibit sulfation of estradiol (E2), but does not exhibit
estrogenic activity via interference with estrogen receptors (ER). TBBPA bis (2,3-dibromopropyl) ether also
does not appear to interfere with AhR-mediated, androgenic or progestagenic pathways. TBBPA bis (2,3-
dibromopropyl) ether competed with thyroid hormone precursor thyroxine (T4) for binding to human
transthyretin (TTR), but did not exhibit thyroid hormone (T3) mimicking activity.
Negative; did not cause inhibition of
CYP17 catalytic activity in human
H295R adrenocortical carcinoma cells.
Positive for estradiol sulfotransferase
(E2SULT)-enzyme inhibition in
E2SULT assay.
Negative for agonistic and antagonistic
interactions with aryl hydrocarbon
(AhR), androgen (AR), progesterone
(PR), and estrogen (ER) receptors in
series of CALUX assays.
Positive for displacement of thyroid
hormone precursor thyroxine (T4) from
plasma transport protein in TTR binding
assay.
Negative for potentiating and
antagonistic activity with T3-mediated
cell proliferation in T-screen.
Canton et al., 2006
Data taken from primary study.
Hamers et al., 2006
Data taken from primary study.
Hamers et al., 2006
Data taken from primary study.
Hamers et al., 2006
Data taken from primary study.
Hamers et al., 2006
Data taken from primary study.
4-668
-------
Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Immunotoxicity
Potential for immunotoxicity based on the presence of polyhalogenated aromatic hydrocarbon structure
and professional judgment.
Immune System Effects
Potential for immunotoxicity based on
the presence of polyhalogenated
aromatic hydrocarbon structure.
(Estimated)
EPA, 2011; Professional
judgment
Estimated based on the presence of
a structural alert.
ECOTOXICITY
ECOSAR Class
Halo ethers
Acute Toxicity
LOW: Based on experimental and estimated acute toxicity values for fish, daphnid, and algae that suggest
no effects at saturation (NES).
Fish LC50
Fish 96-hour LC50 = 1.5xl0"5 mg/L
(Estimated)
ECOSAR: Halo ethers
ECOSAR version 1.11
NES: The log Kow of 12 for this
chemical exceeds the structure
activity relationship (SAR)
limitation for log Kow of 5.0; NES
are predicted.
Fish 96-hour LC50 = 2.2xl0"6 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 12 for this
chemical exceeds the SAR
limitation for log Kow of 5.0; NES
are predicted. Narcosis classes
(neutral organics) are provided for
comparative purposes; DfE
assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Fish (Oryzias latipes) 96-hour LC50 >
500 mg/L;
Semi-static conditions.
ECHA, 2013
Sufficient study details reported in a
secondary source. GLP study
conducted using OECD and
Japanese guidelines. The value
exceeds the estimated water
solubility; NES are predicted.
4-669
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Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish (Oncorhvnchus mykiss) 96-hour
LC50> 100 mg/L;
Static conditions.
ECHA, 2013
Sufficient study details reported in a
secondary source. GLP study
conducted using OECD guidelines.
The value exceeds the estimated
water solubility; NES are predicted.
Daphnid LCS0
Daphnia 48-hour LC50 = 3.01xl0"6 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 12 for this
chemical exceeds the SAR
limitation for log K0„ of 5.0; NES
are predicted. Narcosis classes
(neutral organics) are provided for
comparative purposes; DfE
assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Daphnia magna 48-hour EC50 >100
mg/L;
Water accommodated fraction (WAF)
nominal concentration.
ECHA, 2013
Sufficient study details reported in a
secondary source. GLP study
conducted using OECD guidelines.
The value exceeds the estimated
water solubility; NES are predicted.
Green Algae ECS0
Green algae 96-hour EC50= 8.48xl0"5
mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 12 for this
chemical exceeds the SAR
limitation for log Kow of 6.4; NES
are predicted. Narcosis classes
(neutral organics) are provided for
comparative purposes; DfE
assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
4-670
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Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae (Pseudokirchnerella
subcapitata) 48 and 72-hour EC50
(growth rate/biomass) >100mg/L;
WAF nominal concentration.
ECHA, 2013
Sufficient study details reported in a
secondary source. GLP study
conducted using OECD guidelines.
The value exceeds the estimated
water solubility; NES are predicted.
4-671
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Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Chronic Aquatic Toxicity
LOW: Based on estimated chronic toxicity values for fish, daphnid and green algae that suggest NES.
Fish ChV
Fish ChV = 8.78xl0"7 mg/L
(Estimated)
ECOSAR: Halo ethers
ECOSAR version 1.11
NES: The log Kow of 12 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted.
Fish ChV = 6.6xl0"7 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 12 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted. Narcosis classes
(neutral organics) are provided for
comparative purposes; DfE
assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
Daphnid ChV
Daphnid ChV = 3.38xl0"6 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log Kow of 12 for this
chemical exceeds the SAR
limitation for log Kow of 8.0; NES
are predicted. Narcosis classes
(neutral organics) are provided for
comparative purposes; DfE
assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
4-672
-------
Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green Algae ChV
Green Algae ChV = 0.000157 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The log K0„ of 12 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0; NES
are predicted. Narcosis classes
(neutral organics) are provided for
comparative purposes; DfE
assessment methodology will use
the lowest estimated toxicity value
provided by ECOSAR classes that
have a more specific mode of action
relative to narcosis.
ENVIRONMENTAL FATE
Transport
Evaluation of TBBPA bis (2,3-dibromopropyl) ether transport is based entirely on estimations from
quantitative structure activity relationships. TBBPA bis (2,3-dibromopropyl) ether is expected to have low
mobility in soil based on estimations indicating strong absorption to soil. If released to the atmosphere,
TBBPA bis (2,3-dibromopropyl) ether is likely to exist solely as particulate. As a particulate, atmospheric
oxidation is not expected to be a significant route of environmental removal. Based on the Henry's Law
Constant, volatilization from water or moist soil is not expected to occur at an appreciable rate. Level III
fugacity models indicate that TBBPA bis (2,3-dibromopropyl) ether will partition predominantly to sediment
and soil.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
EPI; Professional judgment
Cutoff value for nonvolatile
compounds.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
EPI; EPA, 1999
Cutoff value for nonmobile
compounds according to HPV
assessment guidance.
>30,000 (Measured)
Reported as log K0c »5.63at 25°C;
OECD TG 121: Estimation of Adsorption
Coefficient on Soil and Sewage Sludge
(HPLC); GLP-study
ECHA, 2013
Guideline study reported in a
secondary source, although the
experimental values were outside the
scope of the protocol (log K0c 1.5-
5.0); radiochemical purity of test
substance (TBBA-bis(2,3-
dibromopropyl ether)) >99%.
4-673
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Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
>30,000 (Measured)
Reported as log K0c values of 6.1 (soil)
and 7.6 (sludge) at pH 7.0; OECD
Guideline 121: Estimation of Adsorption
Coefficient on Soil and Sewage Sludge
(HPLC); GLP-study
ECHA, 2013
Guideline study reported in a
secondary source, although the
experimental values were outside the
scope of the protocol (log K0c 1.5-
5.0); purity of test substance (FR-720)
not stated.
Level III Fugacity Model
Air: <1% (Estimated)
Water = 5%
Soil = 95%
Sediment: <1%
EPI
Persistence
VERY HIGH: High persistence of TBBPA bis (2,3-dibromopropyl) ether is expected as a result of located
biodegradation studies and the absence of other expected likely removal processes under environmental
conditions. In the course of a 28-day Japanese Ministry of International Trade and Industry (MITI) test, only
1% of TBBPA bis (2,3-dibromopropyl) ether was degraded. TBBPA bis (2,3-dibromopropyl) ether will exist
primarily in the particulate phase in the atmosphere and is not expected to undergo removal by gas phase
oxidation reactions. It is also not anticipated to undergo removal by hydrolysis.
Water
Aerobic Biodegradation
1% after 4 weeks
OECD 301C; test concentration of
100 mg/L and concentration of activated
sludge inoculum of 30 mg/L (Measured)
MITI, 2007
Adequate, guideline study.
Passes Ready Test: No
Test method: OECD TG 30IB: C02
Evolution Test
ECHA, 2013
Adequate, guideline study reported in
a secondary source; purity of test
substance FR-720 is 95%.
1% degradation after 29 days using an
activated sludge inoculum. (Measured)
Volatilization Half-life for
Model River
>1 year (Estimated)
EPI
Volatilization Half-life for
Model Lake
>1 year (Estimated)
EPI
4-674
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Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Soil
Aerobic Biodegradation
0% degradation after 120 days in soil;
OECD TG 307 Aerobic and Anaerobic
Transformation in Soil; test concentration
of 70.0 kBq/40 g soil dry weight; GLP-
study (Measured)
ECHA, 2013
Adequate guideline study reported in
a secondary source with 14C-TBBPA-
DBPE. No transformation products
were observed; degradation assessed
with 4 different soil types.
Anaerobic
Biodegradation
0% degradation after 100 days in natural
sediment; OECD TG 308: Aerobic and
Anaerobic Transformation in Aquatic
Sediment Systems; GLP-study (Measured)
ECHA, 2013
Adequate, guideline study reported in
a secondary source with 14C-TBBPA-
DBPE.Degradation results assessed
with 2 sediment types, material mass
balance was reported for both types:
1.98% in water and 84.48% in
sediment.
Soil Biodegradation w/
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
12 hours (Estimated)
EPI
Reactivity
Photolysis
No data located.
Hydrolysis
50%/>l year at 50°C and pH 4, 7, and 9
OECD TG 111: Hydrolysis as a function
of pH and OPPTS 835.21 10: Hydrolysis
as a function of pH; GLP study
Adequate, guideline study reported in
a secondary source. Test substance
purity (PE-68; CASRN 21850-44-2)
not stated, no degradation was
observed after 5 days in triplicate
samples prepared for each pH level.
The substance does not contain
functional groups that would be
expected to hydrolyze readily under
environmental conditions.
Environmental Half-life
>180 days (Estimated)
EPI; PBT Profiler
Half-life estimated for the
predominant compartment, as
determined by EPI and the PBT
Profiler methodology.
4-675
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Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether CASRN 21850-44-2
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Aquatic mesocosm study; a controlled
source of TBBPA bis (2,3-dibromopropyl)
ether was applied and analyzed by GC-MS
over the course of the study. TBBPA bis
(2,3-dibromopropyl) ether was detected in
both the particulate and sediment
compartments. Degradation products were
detected but not all were identified.
(Measured)
de Jourdan, et al., 2013
Nonguideline field study providing
supporting data about the partitioning
and fate/persistence of this compound
under environmental conditions.
Bioaccumulation
HIGH: Based on an estimated BAF of 12,000 and its detection in Great Lakes Herring gull eggs, potential for
bioaccumulation is high.
Fish BCF
3.4 to 43 (15 |a,g/L concentration)
<17 to 130(1.5 |a,g/L concentration)
(Measured)
MITI, 2007
Adequate, guideline study.
BAF
12,000 (Estimated)
EPI
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
TBBPA bis (2,3-dibromopropyl) ether was identified in dust collected near an artificial stream and pond system in
Berlin, Germany (Haiju et al., 2009); in sewage sludge samples from southern China; in sediments from southern
China (Shi et al., 2009) and in water, sediment and soil along the Liuyang River in China (Qu et al., 2011).
Ecological Biomonitoring
Detected in Great Lakes Herring gull eggs (Letcher and Chu, 2010).
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-676
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Canton, R.; Sanderson, J.; Nijmeijer, S.; et al. In vitro effects of brominated flame retardants and metabolites on CYP17 catalytic
activity: A novel mechanism of action? Toxicol. Appl. Pharmacol. 2006, 274:274-281.
ChemSpider; Structure-based Chemistry Information. Royal Society of Chemistry: London. 2011. http://www.chemspider.com
(accessed on January 20, 2011).
CDC (Centers for Disease Control and Prevention). Fourth National Report on Raman Exposure to Environmental Chemicals,
Updated Tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf
(accessed on May 10, 2011).
de Jourdan, B.; Hanson, M.; Muir, D.; Solomon, K. Environmental fate of three novel brominated flame retardants in aquatic
mesocosms. Environ Toxicol Chem. 32(5): 1060-1068. 2013.
ECHA (2013). l,r-(isopropylidene)bis[3,5-dibromo-4-(2,3-dibromopropoxy)benzene]. Registered substances. European Chemicals
Agency. http://apps.echa.europa.eu/registered/data/dossiers/DISS-d6b26f7d-78a6-4269-e044-00144f67d031/DISS-d6b26f7d-78a6-
4269-e044-00144f67d031_DISS-d6b26f7d-78a6-4269-e044-00144f67d031.html 11/4/2013.
ECOSAR/EPI (EPIWIN/EPISUITE) Estimations Programs Interface for Windows, Version 1.11. U.S. Environmental Protection
Agency: Washington D.C. http://www.epa.gov/opptintr/exposure/.
EPA Sustainable Futures. Using NonCancer Screening within the SF Initiative. U.S. Environmental Protection Agency: Washington
D.C. http://www.epa.gOv/opptintr/sf/pubs/noncan-screen.htm#svstemic (accessed on February 09, 2011).
[HPV Assessment Guidance] EPA (U.S. Environmental Protection Agency). Determining the Adequacy of Existing Data. U.S.
Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadeqfn.pdf
EPI (EPIWIN/EPISUITE) Estimation Program Interface for Windows, Version 4.0. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
Great Lakes Chemical Corporation. Letter from Great Lakes Chemical Corporation to U.S. EPA regarding skin and eye irritation in
workers exposed to bis(2,3,-Dibromopropyl)Ether, Tetrabromobisphenol A-. TSCA Section 8E Report, OTS05573935. U.S. EPA
Doc. No. 88990000194. 1999.
4-677
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Great Lakes Chemical Corporation. Ames/Salmonella plate assay report on bis(2,3-dibromopropyl)ether of tetrabromobisphenol A
with attachments. TSCA Section 8E, OTS0503680. U.S. EPA Doc. No. 8888200436. 1982a.
Great Lakes Chemical Corporation. Ames/Salmonella plate assay report on bis(2,3-dibromopropyl)ether of tetrabromobisphenol A
with attachments. TSCA Section 8E Report, OTS0503680. U.S. EPA Doc. No. 8888200426. 1982b
Hamers, T.; Kamstra, J.; Sonneveld, E.; et al. In vitro profiling of the endocrine-disrupting potency of brominated flame retardants.
Toxicol Sci. 2006, 92(1): 157-173.
Harju, M.; Heimstad, E.; Herzke, D.; et al. Current state of knowledge and monitoring requirements - emerging "new" brominated
flame retardants in flame retarded products and the environment (TA-2462/2008) [Online] Norwegian Pollution Control Authority.
2009. www.klif.no/publikasioner/2462/ta2462.pdf (accessed on January 20, 2011).
IPCS (International Programme on Chemical Safety). Environmental Health Criteria 172. Tetrabromobisphenol A and derivatives.
1995. http://www.inchem.org/documents/ehc/ehc/ehcl72.htm (accessed on January 14, 2011).
Knudsen, G.A.; Jacobs, L.M.; Kuester, R.K.; et al. Absorption, distribution, metabolism and excretion of intravenously and orally
administered tetrabromobisphenol A [2,3-dibromopropyl ether] in male Fischer-344 rats. Toxicology 2007, 237:158-167.
Letcher, R.; Chu, S. High-sensitivity method for determination of tetrabromobisphenol-S and tetrabromobisphenol-A derivative flame
retardants in great lakes herring gull eggs by liquid chromatography-atmospheric pressure photoionization-tandem mass spectrometry.
Environ Sci Technol 2010, 44(22):8615-8621.
Mack, A.G. Flame Retardants, Halogenated. Kirk-Othmer Encyclopedia of Chemical Technology. Wiley-Interscience. Posted online:
September 17, 2004.
MITI (Japanese Ministry of International Trade and Industry). Bi ode gradation and bioaccwmrfation data of existing chemicals based
on the CSCL Japan. Compiled under the supervision of Chemical Products Safety Division, Basic Industries Bureau, Ministry of
International Trade & Industry, Japan; Chemicals Inspection & Testing Institute, Japan. Ed.; Japan Chemical Industry Ecology-
Toxicology & Information Center: 2007.
4-678
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NICNAS (National Industrial Chemicals Notification and Assessment Scheme). Priority Existing Chemical Assessment Report No.
20. Polybrominated Flame Retardants (PBFRs) [Online] 2001.
http://www.nicnas.gov.au/publications/car/pec/pec20/pec 20 full report pdf.pdf.
NTP (National Toxicology Program). Tetrabromobisphenol A-bis(2,3-dibromopropyl ether) National Toxicology Program,
Department of Health and Human Services. 2011. http://ntp-apps.niehs.nih.gov/ntp tox/index.cfm?searchterm=21850-44-
2&fuseaction=ntpsearch.searchresults.
PBT Profiler Persistent (P),Bioaccwmrfative (B), and Toxic (T) Chemical (PBT)Profiler, U.S. Environmental Protection Agency:
Washington D.C. www.pbtprofiler.net.
Pakalin, S., Cole, T., Steinkellner, J., et al. Review on production processes of decabromodiphenyl ether (DECABDE) used in
polymeric applications in electrical and electronic equipment, and assessment of the availability of potential alternatives to
DECABDE. [Online], 2007. http://ecb.irc.ec.europa.eu/documents/Existing-
Chemicals/Review on production process of decaBDE.pdf (accessed on January 20, 2011).
Qu, G.; Shi, J.; Wang, T.; et al. Identification of tetrabromobisphenol A diallyl ether as an emerging neurotoxicant in environmental
samples by bioassay-directed fractionation and HPLC-APCI-MS/MS. Environ. Sci. Technol. 2011, 45(11):5009-5016.
Shi, T.; Chen, S.-J.; Luo, X.-J.; et al. Occurrence of brominated flame retardants other than polybrominated diphenyl ethers in
environmental and biota samples from southern China. Chemosphere 2009, 74:910-916.
Tokyo Chemical Industry Co., LTD. Safety Data Sheet for 2,2-Bis[3,5-dibromo-4-(2,3-dibromopropoxy)phenyl]propane [Online]
2010. http://www.tciamerica.com/catalog/B2022.html (accessed on May 31, 2011).
4-679
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Triphenyl Phosphate
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Triphenyl Phosphate
115-86-6
L
M
L
L
L
L
L
L
VL
VH
VH
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-680
-------
Triphenyl Phosphate
CASRN: 115-86-6
MW: 326.29
MF: C1SH„04P
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: 0=P(0c 1 ccccc 1 )(0c 1 ccccc 1 )0c 1 ccccc 1
Synonyms: Phosphoric acid, triphenyl ester; TPP
Chemical Considerations: This is a discrete organic chemical with a MW <1,000. EPI v 4.0 was used to estimate physical/chemical and environmental fate values
due to an absence of experimental data. Measured values from experimental studies were incorporated into the estimations.
Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: Diphenyl phosphate (CASRN 838-85-7) and phenol (CASRN 108-95-2)
Analog: No analog
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: Organophosphates; Neurotoxicity (EPA, 2012).
Risk Phrases: R50/53: Very toxic to aquatic organisms. May cause long-term adverse effects in the aquatic environment (OECD SIDS, 2002).
Hazard and Risk Assessments: Design for the Environment (DfE) Alternatives Assessment for Furniture Flame Retardancy Partnership, September, 2005 (EPA,
2005)
4-681
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
50.5 (Measured)
Lide, 2008
Adequate.
49
Reported as 49-50°C (Measured)
EC, 2000
Reported in a secondary source;
consistent with value reported in
primary source.
Boiling Point (°C)
245
Reported at 11 mmHg (Measured)
O'Neil, 2006
Adequate.
>300 (Estimated)
EPI; EPA, 1999
Cutoff value for high boiling point
compounds according to High
Production Volume assessment
guidance.
220
Reported at 5 mmHg (Measured)
EC, 2000
Reported in a secondary source;
consistent with value reported in
primary source.
Vapor Pressure (mm Hg)
6.28xl0"6 (Extrapolated)
Dobry and Keller, 1957
Adequate.
1.5xl0"6 (Measured)
EC, 2000
Reported in a secondary source.
Water Solubility (mg/L)
1.9 (Measured)
Saegeretal., 1979
Adequate.
0.75 (Measured)
OECD Guideline 105
EC, 2000
Guideline study reported in a
secondary source.
0.025 (Measured)
EC, 2000
Reported in a secondary source; not
consistent with other measured
values.
Log Kow
4.59 (Measured)
Hansch and Leo, 1995
Adequate.
4.76 (Measured)
OECD SIDS, 2002
Reported in a secondary source;
consistent with value reported in
primary source.
Flammability (Flash Point)
220°C (Measured)
Lewis, 2001
Adequate.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Pyrolysis
No data located.
4-682
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
HUMAN HEALTH EFF
ECTS
Toxicokinetics
Triphenyl phosphate is hydrolyzed in the
TPP can be detected in human breast mi
liver to produce diphenyl phosphate as the primary metabolite,
k.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
Triphenyl phosphate is hydrolyzed in rat
liver homogenate to produce the metabolite
diphenyl phosphate. (Measured)
OECD SIDS, 2002
Reported in a secondary source.
Other
TPP concentraions in milk were analyzed
in a human cohort study conducted
between 1997 and 2007. Median
concentration across all subjects was 8.5
ng/g (min-max values: 3.2-11 ng/g).
ECHA, 2012
Limited study details reported in a
secondary source.
Acute Toxicity
LOW: Oral LDS0 in rats and mice is >5,000 mg/kg and the dermal LDsoin rabbits is >7,900 mg/kg. No
adequate data were located to assess the toxicity of inhalation exposure.
Acute Lethality
Oral
Rat, mouse, oral LD50 >5,000 mg/kg
OECD SIDS, 2002
Reported in a secondary source.
Several rat, oral, LD50 >6,400 mg/kg
ATSDR, 2009
Reported in a secondary source.
Dermal
Rabbit dermal LD50 >10,000 mg/kg
OECD SIDS, 2002
Reported in a secondary source.
Rabbit dermal LD50 >7,900 mg/kg
ATSDR, 2009
Reported in a secondary source.
Inhalation
Rat LC50 >200,000 mg/irf (dust), 1-hour
exposure, 14-day observation
ATSDR, 2009
Reported in a secondary source.
Insufficient exposure time (1 hour),
no data on method or good laboratory
practice.
Carcinogenicity
MODERATE: OncoLogic modeling indicates a marginal to low potential
carcinogenicity assays were found.
'or carcinogenicity. No long-term
OncoLogic Results
Marginal to Low (Estimated)
OncoLogic, 2008
4-683
-------
Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Carcinogenicity (Rat and
Mouse)
Mouse lung adenoma test: Male A/St mice
(20/group) received IP injections of either
20 mg/kg (18/6 weeks); 40 mg/kg (3/1
week); or 80 mg/kg. No significant
increase in incidence of adenoma
compared to negative controls, and
positive control (urethane) produced 19.6
tumors/mouse with 100% survival.
OECD SIDS, 2002
Reported in a secondary source.
Nonstandard study, limited
histopathology and short-duration,
reported in a secondary source.
Combined Chronic
Toxicity/ Carcinogenicity
No data located.
Genotoxicity
LOW: Triphenyl phosphate was not mutagenic in bacteria or mammalian cells in vitro and did not cause
chromosomal aberrations in vitro. In addition, triphenyl phosphate did not result in DNA damage in hamster
fibroblast cells.
Gene Mutation in vitro
Negative, Ames assay in Salmonella
typhi murium strains TA98, TA100,
TA1537, TA1538 with and without
metabolic activation.
ATSDR, 2009; ECHA, 2012
Reported in a secondary source.
Negative, forward mutation assay in mouse
lymphoma L5178Y cells.
OECD SIDS, 2002; ECHA, 2012
Reported in a secondary source.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
Negative in chromosome aberration test in
Chinese hamster V79 cells; with and
without metabolic activation.
ECHA, 2012
Reported in a secondary source.
Chromosomal
Aberrations in vivo
No data located.
DNA Damage and Repair
Negative, unscheduled DNA synthesis in
hamster fibroblast cells.
OECD SIDS, 2002
Reported in a secondary source.
Other (Mitotic Gene
Conversion)
Negative, mitotic gene conversion assay in
Saccharomyces cerevisiae with and
without activation.
OECD SIDS, 2002
Reported in a secondary source.
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproductive Effects
LOW: Based on a rat oral reproductive/developmental NOAEL = 690 mg/kg-bw/day for reproductive effects
(highest dose tested). In addition, no histopathological effects on reproductive organs were reported following
3 weeks of dermal exposure in rabbits. Correlation of TPP in house dust and decreased sperm counts in
humans has been reported, however rat studies did not measure the same endpoint, so there are insufficient
data for this effect.
Reproduction/
Developmental Toxicity
Screen
Reproductive/developmental dietary study
(91 days premating and continuing through
gestation), 40 male and 40 female
rats/group, test compound concentrations
of 0, 0.25, 0.50, 0.75, or 1.0% (~0, 166,
341, 516 or 690 mg/kg-bw/day,
respectively). No signs of parental toxicity,
no reproductive effects (number pregnant,
corpora lutea, implantations, implantation
efficiency, resorptions).
NOAEL (reproductive effects) = 690
mg/kg-bw/day (highest dose tested)
LOAEL = not identified; there were no
effects at the highest dose tested.
OECD SIDS, 2002; ATSDR,
2009
Reported in a secondary source. A
LOAEL was not identified; there
were no effects at the highest dose
tested.
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
No data located.
Reproduction and
Fertility Effects
Rabbits, dermal (clipped, intact), 5x/week,
3 weeks, 50% solution in ethanol; no effect
on the reproductive organs reported up to
the highest dose tested (1,000 mg/kg/day)
NOAEL = 1,000 mg/kg/day
OECD SIDS, 2002
Reported in a secondary source.
Organs examined by histopathology;
there were no effects at the highest
dose tested; dermal repeated-dose
study.
4-685
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Other
Men living in homes with higher amounts
of TPP in house dust had reduced sperm
count and altered hormone levels related to
fertility and thyroid function. Each
interquartile range (IQR) TPP increase in
house dust samples was associated with a
19% decrease in sperm concentrations and
a 10% increase in prolactin levels.
Betts, 2010; Meeker and
Stapleton, 2010
The actual exposure to TPP is
unknown; it is not known if TPP or
other substances found in the
household dust caused or contributed
to the reported toxicity.
Developmental Effects
LOW: Based on a rat oral reproductive/c
dose tested). There were no data located
cholinesterase activity in pregnant lab an
development. As a result, there is uncerta
evelopmental NOAEL = 690 mg/kg-bw/day for fetal effects (highest
or the developmental neurotoxicity endpoint. Decreased
imals has been shown to have a negative impact on fetal brain
lin potential for developmental neurotoxicity for this substance.
Reproduction/
Developmental Toxicity
Screen
Reproductive/developmental (dietary)
study, 91 days premating (males and
females), continuing through gestation and
lactation (females only), 40 male and 40
female rats/group, test compound
concentrations of 0, 0.25, 0.50, 0.75, or
1.0% (~0, 166, 341, 516or690mg/kg-
bw/day, respectively), no effects on fetal
endpoints (viability, early or late deaths,
fetal weight, length or distribution) or
skeletal anomalies.
NOAEL (developmental effects) = 690
mg/kg-bw/day
OECD SIDS, 2002; ATSDR,
2009
Reported in a secondary source. A
LOAEL was not identified; there
were no effects at the highest dose
tested.
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
No data located.
Prenatal Development
No data located.
Postnatal Development
No data located.
4-686
-------
Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Developmental
Neurotoxicity
There were no data located for the
developmental neurotoxicity endpoint.
Decreased cholinesterase activity in
pregnant lab animals has been shown to
have a negative impact on fetal brain
development. As a result, there is uncertain
potential for developmental neurotoxicity
for this substance.
Professional judgment
No data located.
Other
No data located.
Neurotoxicity
LOW: Based on an adult rat neurotoxicity screening battery NOAEL = 71
experimental results are consistent with this hazard designation.
1 mg/kg-bw/day; all other
Acute and 28-day Delayed
Neurotoxicity of
Organophosphorus
Substances (Hen)
Two female hens/dose in delayed
neurotoxicity test, gavage, 2,000, 3,000,
5,000, 8,000, or 12,500 mg/kg, no signs of
toxicity in-life or at necropsy
NOAEL >12,500 mg/kg
OECD SIDS, 2002
Reported in a secondary source. No
data on test substance purity.
Several acute oral studies in hens,
administered doses up to 12,500 mg/kg,
generally found no signs of paralysis,
histopathological changes in examined
nerve tissues, or behavior immediately
after or during observation periods of up to
36 days. However, blood cholinesterase
was decreased by up to 87% in studies
where it was measured.
NOAEL >12,500 mg/kg
OECD SIDS, 2002
Reported in a secondary source. No
data on test substance purity.
4-687
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Neurotoxicity Screening
Battery (Adult)
Other
4-month dietary study, 10 rats/dose, 0.25,
0.5, 0.75 or l%test concentration (161,
345, 517 or 711 mg/kg-bw/day,
respectively), no neurobehavioral effects
(open field, accelerating rotarod, forelimb
grip strength and negative geotaxis
examinations).
NOAEL = 711 mg/kg-bw-day (highest
dose tested)
ATSDR, 2009
Reported in a secondary source.
There is potential for neurotoxic effects
based on a structural alert for
organophosphates
(Estimated)
Professional judgment
Estimated based on a structural alert
for organophosphates and
professional judgment.
Repeated Dose Effects
HIGH: Based on weight of evidence including reduced body weight in ma e rats administered triphenyl
phosphate in the diet for 28 days. The NOAEL of 23.5 mg/kg-day and the LOAEL of 161.4 mg/kg-day span
across the High and Moderate hazard designation ranges (DfE criteria are for 90-day repeated dose studies;
criteria values are tripled for chemicals evaluated in 28-day studies making the High hazard range < 30
mg/kg-day and the Moderate hazard range between 30 and 300 mg/kg-day).
28-day repeated dose oral exposure study
in rats. 0, 250, 1,000, 4,000 ppm in diet.
Effects on body weights were observed
Male:
NOAEL = 250 ppm (23.5 mg/kg-day)
LOAEL = 1,000 ppm (161.4 mg/kg-day)
ECHA, 2012
Reported in secondary source. DfE
criteria are for 90-day repeated dose
studies. Criteria values are tripled for
chemicals evaluated in 28-day
studies.
4-688
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
3 5-day repeated-dose oral (dietary) study,
5 male rats/group, test compound
concentrations of 0, 0.5, and 5.0% (~0,
350, and 3,500 mg/kg-day, respectively),
with a 0.1% (-70 mg/kg-day) dose
replacing the high dose group after 3 days.
Slight reduction in body weight gain and
increase in liver weight in 350 mg/kg-day
dose group.
OECD SIDS, 2002
Reported in a secondary source.
Limited study details provided.
NOAEL = 70 mg/kg-day
LOAEL = 350 mg/kg-day
4-month repeated-dose dietary study,
Sprague-Dawley rats, 10 rats/dose, 0.25,
0.5, 0.75 or l%test concentration (161,
345, 517 or 711 mg/kg-bw/day,
respectively), reduced body weight gain
(11%) at 345 mg/kg-bw/day.
ATSDR, 2009
Reported in a secondary source.
NOAEL =161 mg/kg-bw/day
LOAEL = 345 mg/kg-bw/day
4-689
-------
Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
21-day repeated-dose dermal study, 10
male and 10 female rabbits/group, test
compound concentrations of 0, 100, and
1,000 mg/kg-bw/day, no mortality, clinical
symptoms, or changes in body weight,
hematology, clinical chemistry, necropsy,
organ weights and histopathology reported;
only decreased acetyl cholinesterase levels
in plasma, erythrocytes and brain were
reported and not considered to be of
toxicological relevance as there was no
clinical or histological correlation.
OECD SIDS, 2002
Reported in a secondary source.
Treatment period only 21 days.
NOAEL = 1,000 mg/kg-bw/day
In a 3-month study, rats were orally
gavaged with test substances at 0, 380 and
1900 mg/kg-day. No toxic effects were
observed.
ATSDR, 2009
Limited study details reported in a
secondary source. Primary source is
an abstract with few experimental
NOEL: 1900 mg/kg-day; highest dose
tested
LOEL: Not established
4-690
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Immune System Effects
120-day dietary study, rats, 0, 0.25, 0.5,
0.75, and 1% of triphenyl phosphate (~0,
161, 345, 517 and 711 mg/kg-bw/day);
initial, secondary, and tertiary
immunizations with sheep red blood cells
performed at 60, 81, and 102 days,
respectively. No significant effects were
reported on the weight and histopathology
of the spleen, thymus and lymph nodes,
and no significant changes to the humoral
response were reported.
NOEL = 711 mg/kg/day
ATSDR, 2009
Reported in a secondary source.
Rabbits exposed to up to 1,000 mg/kg-
bw/day, applied 5 days/week for 3 weeks
to intact or abraded skin, had no gross or
microscopic effects on the spleen, thymus,
or lymph nodes.
ATSDR, 2009
Reported in a secondary source.
Skin Sensitization
LOW: Based on an experimental study in guinea pigs indicating that triphenyl phosphate is not a skin
sensitizer.
Skin Sensitization
Several human case studies have reported
allergic dermatitis; 15 of 23,192 (0.065%)
human volunteers patch tested from 1950
to 1962 had positive reactions to cellulose
acetate film containing 7-10% triphenyl
phosphate and 3-4% phthalic esters.
OECD SIDS, 2002
Reported in a secondary source.
Limited study details provided; patch
tests conducted with mixtures;
unclear which component of mixture
caused low incidence of sensitization.
A confidential skin sensitization study with
negative results in guinea pigs.
Confidential study
Reported in a confidential study.
None of the patients tested in two separate
studies of 343 and 174 patients,
respectively, had sensitization reactions to
triphenyl phosphate.
OECD SIDS, 2002
Reported in a secondary source.
Limited study details provided.
4-691
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Not sensitizing, guinea pig maximization
test
OECD SIDS, 2002
Study reported in a secondary source;
conducted according to OECD
Guideline 406.
Respiratory Sensitization
No data located.
Respiratory Sensitization
No data located.
Eye Irritation
LOW: Triphenyl phosphate is mildly irritating to rabbit eyes with effects clearing within 72 hours.
Eye Irritation
Not irritating, rabbits
OECD SIDS, 2002
Study reported in a secondary source;
conducted according to OECD
Guideline 405.
Mild irritation in rabbit eyes, clearing
within 72 hours.
OECD SIDS, 2002
Reported in a secondary source.
Dermal Irritation
VERY LOW: Triphenyl Phosphate is not a skin irritant in rabbits.
Dermal Irritation
Not irritating, rabbits; semi-occlusive or
occlusive conditions for 4, 24, or 72 hours
OECD SIDS, 2002
Study reported in a secondary source;
conducted according to OECD
Guideline 404.
Non-irritant, rabbit
ATSDR, 2009
Reported in a secondary source.
Endocrine Activity
Triphenyl phosphate was found to be inactive in an estrogen-receptor binding assay; however, it was shown
to be a moderate androgen-receptor (AR) binder in a competitive binding assay. Triphenyl phosphate was
shown to inhibit human AR in the absence of agonist and to inhibit testosterone-induced AR activity. In
addition, triphenyl phosphate significantly impaired reproduction in zebrafish and was correlated with
decreased sperm count and altered hormone levels in men.
21-day reproduction study in zebrafish.
Significant decrease in fecundity,
significant increases of plasma 17B-
estradiol (E2) concentrations, vitellogenin
(VTG) levels, and E2/testosterone (T) and
E2/11-ketotestosterone (11-KT) ratios.
Sex-dependent changes in transcriptional
profiles of several genes of the
hypothalamus-pituitary-gonad (HPG) axis.
Liu et al., 2013
Adequate primary source.
4-692
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Study conducted to determine effects of
triaryl phosphates on mouse and human
nuclear receptors. Mouse constitutively
active receptor (CAR) was activated by
1.3-fold following exposure to TPP.
Testosterone -induced AR-dependent
activity was lowered by 30-40%.
Honkakoski et al., 2004
Adequate primary source.
Exposure to TPP in zebrafish resulted in
severe pericardial edema and blocked
looping of the atrium and ventricle. TPP-
induced cardiotoxicity in zebrafish
embryos is mediated through an AHR
independent pathway.
McGee et al., 2013
Adequate primary source.
In a luciferase reporter-gene assay using
cultured cells, TPP inhibited the luciferase
expression induced by dihydrotestosterone
(10"9M).
Ohyama et al., 2006
Primary source in Japanese with
English abstract.
IC5o for antiandrogenic activity = 0.000047
- 0.0006 M
4-693
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Endocrine disrupting potential was
investigated using human cells lines
(H295R, MVLN) and zebrafish plasma.
TPP was cytotoxic to H295R cells
(showing <80% cell viability at > 10 mg/L)
and significantly increased E2 and T
production. Transcription of CYP19A1
was significantly up-regulated and
transcription of SULT1E1 gene was down-
regulated. No binding affinity to E2
receptor in MVLN cells, but binding of E2
to ER was reduced in a dose-dependent
manner. Plasma E2 was significantly
increased in fish plasma and T and 11 -KT
were decreased (1 mg/L). Changes in
transcription of steroidogenic genes and
vitellogenin gene were observed.
Liu et al., 2012
Adequate, primary source.
Men living in homes with higher amounts
of TPP in house dust had reduced sperm
count and altered hormone levels related to
fertility and thyroid function. Each
interquartile range (IQR) TPP increase in
house dust samples was associated with a
19% decrease in sperm concentrations and
a 10% increase in prolactin levels.
Betts, 2010; Meeker and
Stapleton, 2010
The actual exposure to TPP is
unknown; it is not known if TPP or
other substances found in the
household dust caused or contributed
to the reported toxicity.
Inactive in a binding assay with the rat
uteri estrogen receptor from
ovariectomized Sprague-Dawley rats
ATSDR, 2009
Reported in a secondary source.
Moderate binding in a competitive
androgen-receptor (AR) binding assay
using recombinant rat protein expressed in
Escherichia coli.
ATSDR, 2009
Reported in a secondary source.
4-694
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Inhibited AR activity in COS-1 cells
transfected with human AR both in the
absence of agonist, as well as inhibited
testosterone-induced AR activity by
30-40%.
ATSDR, 2009
Reported in a secondary source.
Immunotoxicity
Oral exposure of rats to triphenyl phospli
produced no effects on immune function
late for 4 months and dermal exposure of rabbits for 3 weeks
parameters.
Immune System Effects
120-day dietary study, rats, 0, 0.25, 0.5,
0.75, and 1% of triphenyl phosphate (~0,
161, 345, 517 and 711 mg/kg-bw/day);
initial, secondary, and tertiary
immunizations with sheep red blood cells
performed at 60, 81, and 102 days,
respectively. No significant effects were
reported on the weight and histopathology
of the spleen, thymus and lymph nodes,
and no significant changes to the humoral
response were reported.
NOEL = 711 mg/kg/day
ATSDR, 2009
Reported in a secondary source.
Rabbits, up to 1,000 mg/kg-bw/day,
applied 5 days/week for 3 weeks to intact
or abraded skin had no gross or
microscopic effects on the spleen, thymus,
or lymph nodes.
ATSDR, 2009
Reported in a secondary source.
ECOTOXICITY
ECOSAR Class
Esters (phosphate), Esters
Acute Toxicity
VERY HIGH: Based on experimental fis
1 96-hour LC50 values of 0.4 and 0.85 mg/L.
Fish LC50
Fish 96-hour LC50 = 0.4 mg/L
(Experimental)
OECD SIDS, 2002
Reported in a secondary source.
Fish 96-hour LC50 = 0.85 mg/L
(Experimental)
OECD SIDS, 2002
Reported in a secondary source.
Guideline study.
4-695
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish 96-hour LC50 = 290 mg/L
(Experimental)
OECD SIDS, 2002
Limited study details reported in a
secondary source. The study does not
meet important criteria for standard
methods (e.g. test substance
concentration at solubility threshold
in water).
Fish 96-hour LC50 = 1.62 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
Daphnid LCS0
Daphnid 48-hour LC50 = 1.28 mg/L
(Experimental)
FMC Industrial Chemical
Division, 1979
Sufficient study details reported.
Daphnid 48-hour EC50 = 1.35 mg/L
(Experimental)
OECD SIDS, 2002
Study reported in a secondary source;
conducted according to US EPA
660/3-75-009.
Daphnid 48-hour LC50 = 1.28 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
Daphnid 48-hour LC50 =1.0 mg/L
(Experimental)
Mayer et al., 1981
Sufficient study details reported.
Other Freshwater Invertebrate LCS0
Mysidopsis bahia 96-hour LC50 >0.18 -
0.32 mg/L
(Experimental)
OECD SIDS, 2002
Reported in a secondary source.
Green Algae ECS0)
Green algae 96-hour EC50 = 2.0 mg/L
(Experimental)
OECD SIDS, 2002
Reported in a secondary source.
Green algae 96-hour EC50 = 2.0 mg/L
(Experimental)
Mayer et al., 1981
Sufficient study details reported
4-696
-------
Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green algae (Scenedesmus subspicatiis)
72-hour LOEC = 0.5-5 mg/L
NOEC = 0.25 - 2.5 mg/L
(Experimental)
OECD SIDS, 2002
Study reported in secondary source;
conducted according to OECD
guideline 201.
Green algae 96-hour EC50 = 1.59 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
Chronic Aquatic Toxicity
VERY HIGH: Based on an experimental fish 30-day LOEC = 0.037 mg/L. No chronic experimental data were
available for daphnia or algae.
Fish ChV
Fish 30-day LOEC = 0.23 mg/L
(Experimental)
OECD SIDS, 2002
Reported in a secondary source.
Guideline study.
Oncorhvnchiis mykiss 30-day LOEC =
0.037 mg/L
(Experimental)
ECHA, 2012
Reported in a secondary source.
Fish ChV = 0.15 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
Daphnid ChV
Daphnid ChV = 0.186 mg/L
(Estimated)
ECOSAR: Neutral organic
ECOSAR version 1.11
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
Green Algae ChV
Green algae ChV = 0.925 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
4-697
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
ENVIRONMENTAL FATE
Transport
Level III fugacity models incorporating available physical and chemical property data indicate that at steady
state TPP is expected to be found primarily in soil and to a lesser extent, water Triphenyl phosphate is
expected to have moderate mobility in soil, based on measured Koc values in silty clay, loamy sand and silt
loam. Leaching through soil to groundwater may occur, though it is not expected to be an important
transport mechanism. Triphenyl phosphate may volatilize from moist soil and water surfaces based on its
Henry's Law constant. Volatilization from dry surface is not expected based on its vapor pressure. In the
atmosphere, triphenyl phosphate is expected to exist in both the vapor phase and particulate phase.
Particulates may be removed from air by wet or dry deposition.
Henry's Law Constant
(atm-m3/mole)
1,2xl0"5 (Measured)
Mayer et al., 1981; Huckins et al.,
1991
Adequate.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
2,514-3,561 in silty clay, loamy sand and
silt loam (Measured)
Anderson et al., 1993
Adequate.
Level III Fugacity Model
Air: <1% (Estimated)
Water = 15%
Soil = 75%
Sediment = 9.6%
EPI
Reported in a Level III Fugacity
model. Experimental data is
consistent with partitioning to
sediment.
Persistence
LOW: The persistence of triphenyl phosphate is based on experimental data. Under aerobic conditions in a
Japanese MITI ready biodegradability test (OECD Test Guidelines (TG) 301C), 90% biodegradation of
triphenyl phosphate occurred after 28 days, and 93.8% triphenyl phosphate removal as dissolved organic
carbon (DOC) occurred over 20 days in an OECD 303A guideline study. TPP does not meet the criteria for
very low persistence because the percent removal in the criteria does not occur within a 10-day window. In
loamy sand, a half-life of 37 days was observed under aerobic conditions. Triphenyl phosphate was
determined to be inherently biodegradable in a river die-away test, after degrading 100% over 3 days in
river water. Triphenyl phosphate may degrade under anaerobic conditions, with primary degradation of
31.1% after 3 days (89.7% after 40 days) in river sediment. However, removal under anaerobic conditions is
not anticipated to be an important fate process. Triphenyl phosphate will undergo hydrolysis under alkaline
conditions, with half-lives of 3 days at pH 9; it is relatively stable to hydrolysis under neutral and acidic
conditions, with half-lives of 28 days at pH 5 and 19 days at pH 7. Triphenyl phosphate is not expected to be
susceptible to direct photolysis by sunlight, since it does not absorb light at wavelengths >290 nm. The
atmospheric half-live of vapor-phase triphenyl phosphate is estimated to be 12 hours.
4-698
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Water
Aerobic Biodegradation
Inherently Biodegradable: Degraded 100%
after 3 days in river water (River die-away
test) (Measured)
OECD SIDS, 2002
Adequate, guideline study.
Passes Ready Test: Yes
Test method: OECD TG 301C: Modified
MITI Test (I)
OECD-SIDS, 2002
Reported in a guideline study.
83-94% biodegradation after 28 days at
100 mg/L of test substance. (Measured)
Volatilization Half-life for
Model River
13 days (Estimated)
EPI
Volatilization Half-life for
Model Lake
150 days (Estimated)
EPI
Soil
Aerobic Biodegradation
Study results: 93.8%/20 days
Test method: 303A: Activated Sludge
Units - Simulation Test
Removal as DOC, using initial
concentration of 5 mg/L with activated
sludge. Reported as inherently
biodegradable. (Measured)
OECD SIDS, 2002; EC, 2000
Adequate, guideline study.
Study results: 77%/28 days
Test method: Other
Reported as ultimately biodegradable.
Monsanto Shake Flask Procedure
(precursor to Closed bottle test).
(Measured)
OECD SIDS, 2002
Reported in a secondary source.
Study results: 82%/28 days
Test method: C02 Evolution
Modified Sturm test. Reported as
ultimately biodegradable. Measured in
domestic, adapted activated sludge.
(Measured)
OECD SIDS, 2002
Reported in a secondary source.
4-699
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Study results: 93%/49 days
Test method: 302A: Inherent - Modified
SCAS Test
Reported as inherently biodegradable.
(Measured)
OECD SIDS, 2002
Reported in a guideline study.
Anaerobic
Biodegradation
Primary degradation: 31.1% removal after
3 days in river sediment; 89.7% removal
after 40 days (Measured)
OECD SIDS, 2002
Adequate, guideline study.
Soil Biodegradation with
Product Identification
No data located.
Sediment/Water
Biodegradation
Primary degradation: 43.3% removal after
3 days in river sediment; 86.9% removal
after 40 days (Measured)
OECD SIDS, 2002
Adequate, guideline study.
Air
Atmospheric Half-life
12 hours (Estimated)
EPI
Reactivity
Photolysis
Not a significant fate process (Estimated)
Mill, 2000; Professional
judgment
Triphenyl phosphate does not contain
functional groups that would be
expected to absorb light of
wavelengths >290 nm.
A 0.1 mg/L solution (with acetone) was
exposed to a mercury lamp to examine the
effect of UV light on the degradation of
TPP.
High pressure lamp (100W): 100%/20
mins
Low pressure lamp (15W): 100%/1 hour
(Measured)
EC, 2000
Reported in a secondary source under
laboratory conditions.
Hydrolysis
Half-lives at 25°C:
>28 days at pH 5;
19 days at pH 7;
3 days at pH 9 (Measured)
OECD SIDS, 2002
Adequate, guideline study.
4-700
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
50%/7.5 days
Reported at pH 8.2 in river/lake water
(Measured)
EC, 2000
Reported in a secondary source.
50%/1.3 days
Reported at pH 9.5 in river/lake water
(Measured)
EC, 2000
Reported in a secondary source.
100%/10 minutes at pH 13 (Measured)
ECHA, 2013
Reported in secondary source.
Documentation of study details was
not sufficient to assess its reliability.
Environmental Half-Life
In loamy sand, observed half-lives of 37
days (aerobic) and 21 days (anaerobic)
(Measured)
OECD SIDS, 2002
Adequate, guideline study.
75 days (Estimated)
EPI; PBT Profiler
Half-life estimated for the
predominant compartment, as
determined by EPI and the PBT
Profiler methodology.
Bioaccumulation
MODERATE: There is moderate potential for bioaccumulation based on experimental BCF values.
Fish BCF
132-364 (Rainbow trout)
(Measured)
Mayer et al., 1981
Adequate.
271 (Rainbow trout)
(Measured)
EC, 2000
Reported in a secondary source.
364
Reported as 132-364 in rainbow trout
(Measured)
OECD SIDS, 2002
Insufficient study details to assess the
quality of the reported values.
193
Reported as 84-193 in Medaka (Measured)
EC, 2000
Reported in a secondary source.
160
Reported as 68-160 in Fathead minnow
(Measured)
EC, 2000
Reported in a secondary source.
144
Medaka (Measured)
OECD SIDS, 2002
Reported in a secondary source.
4-701
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Triphenyl Phosphate CASRN 115-86-6
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
110
Goldfish (Measured)
OECD SIDS, 2002
Reported in a secondary source.
BAF
73 (Estimated)
EPI
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
Triphenyl phosphate has been detected in drinking water in samples collected by the USGS. It has also been
detected in household dust in the United States (at concentrations of (<173-1,798,100 ng/g), Pakistan, New Zealand,
Belgium, Spain and Japan. Triphenyl phosphate has been detected in sediment from Taihu Lake in China at
concentrations ranging from 0.41-5.54 j^ig/kg and in sediment in the U.S. It has also been detected in river water,
seawater, rainwater, snow, wastewater effluent, ambient air, and indoor air. (OECD SIDS, 2002; Betts, 2010;
vanderVeen and deBoer, 2012; Stiles et al., 2008; Stapleton et al., 2009; Cao et al., 2012; Ali et al., 2012; HSDB,
2013; Salamova et al., 2013)
Ecological Biomonitoring
Triphenyl phosphate has been detected in fish tissues. It has also been detected in the blubber of bottlenose dolphins
collected from the Gulf of Mexico (Campone et al., 2010; Kuehl and Haebler, 1995).
Human Biomonitoring
Triphenyl phosphate was detected in human milk, adipose tissue and human plasma. This chemical was not
included in the NHANES biomonitoring report (CDC, 2013; Shah et al., 2006; ECHA, 2012).
4-702
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Ali N, Van den Eede N, Dirtu AC, et al. (2012) Assessment of human exposure to indoor organic contaminants via dust ingestion in
Pakistan. Indoor Air 22(3):200-211.
Anderson, C; Wischer, D; Schmieder, A; et al. Fate of triphenyl phosphate in soil. Chemosphere 1993, 27(5):869-879.
ATSDR (Agency for Toxic Substances and Disease Registry). Draft toxicological profile for phosphate ester flame retardants. U. S.
Department of Health and Human Services, Public Health Service, 2009.
Betts KS (2010) Endocrine damper? Flame retardants linked to male hormone, sperm count changes. Environmental Health
Perspectives 118(3):A 130
Campone L, Piccinelli Anna L, Ostman C, et al. (2010) Determination of organophosphorus flame retardants in fish tissues by matrix
solid-phase dispersion and gas chromatography. Analytical and Bioanalytical Chemistry 397(2):799-806
Cao S, Zeng X, Song H, et al. (2012) Levels and distributions of organophosphate flame retardants and plasticizers in sediment from
Taihu Lake, China. Environmental Toxicology and Chemistry 31(7): 1478-1484.
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tables. Department of Health and Human Services. 2013.
http://www.cdc.gov/exposurereport/pdf/FourthReport UpdatedTables Mar2013.pdf.
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ECHA (European Chemicals Agency). Information on registered substances. 2012.
http://apps.echa.europa.eu/registered/data/dossiers/DISS-9c823fa6-50fe-0b74-e044-00144f67d249/AGGR-25e8a69c-b7a3-48f4-8aa3-
df36b0a9735f DISS-9c823fa6-50fe-0b74-e044-00144f67d249.html#section 1.1 (accessed April, 2012).
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Agency: Washington D.C. http://www.epa.gov/opptintr/exposure/.
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EPA (U.S. Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing
Data. U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
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retardant alternatives for low-density polyurethane foam volumes 1 and 2. U.S. EPA. September, 2005.
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FMC Industrial Chemical Division. Acute aquatic toxicity of triphenyl phosphate. ICG/T-79-064. 1979.
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Chemical Society., p. 155. 1995.
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bin/si s/html gen?HSDB.
Honkakoski P, Palvimo Jorma J, Penttila L, et al. (2004) Effects of triaryl phosphates on mouse and human nuclear receptors.
Biochemical Pharmacology 67(1):97-106.
Huckins, J; Fairchild, J; Boyle, T. Role of exposure mode in the bioavailability of triphenyl phosphate to aquatic organisms. Arch.
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115E. Aquatic Toxicology and Hazard Assessment: Fourth Conference, ASTM STP 737, Branson, D and K. Dickinson, Eds.
American Society for Testing and Materials, pl03-123. 1981.
McGee SP and Konstantinov A Stapleton HM Volz DC (2013) Aryl phosphate esters within a major pentaBDE replacement product
induce cardiotoxicity in developing zebrafish embryos: Potential role of the aryl hydrocarbon receptor. Toxicological Sciences
133(1): 144-156.
Meeker JD and Stapleton HM (2010) House dust concentrations of organophosphate flame retardants in relation to hormone levels
and semen quality parameters. Environmental Health Perspectives 118(3):318-323.
Mill, T. (2000) Photoreactions in Surface Waters. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for
Chemicals, Environmental Health Sciences (355-382). Boca Raton: Lewis Publishers.
O'Neil MJ, ed; The Merck Index. 14th ed. Whitehouse Station, NJ: Merck and Co., Inc. 2006.
OECD SIDS (Organisation for Economic Cooperation and Development Screening Information Dataset). 2002. SIDS Initial
Assessment Report for Triphenyl Phosphate. http://www.chem.unep.ch/irptc/sids/OECDSIDS/115866.pdf
Ohyama K, Nagata S, Hosogoe N, et al. (2006) Hormonal effects of organic phosphate triesters study by the reporter gene assay.
Tokyo-to Kenko Anzen Kenkyu Senta Kenkyu Nenpo 56:333-338.
Oncologic. U.S. EPA and LogiChem, Inc., Version 7.0. 2008.
PBT Profi 1 er Persistent (P), Bioaccumulative (B), and Toxic (T) Chemical (PBT)Profiler, U.S. Environmental Protection Agency:
Washington D.C. www.pbtprofiler.net.
4-705
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Saeger, V; Hicks, O; Kaley, R; et al. Environmental fate of selected phosphate esters. Environ. Sci. Technol. 1979, 13:840-844.
Salamova A, Ma Y, Venier M, et al. (2013) High levels of organophosphate flame retardants in the Great Lakes atmosphere.
Environmental Science and Technology Letters epub.
Shah M, Meija J, Cabovska B, et al. (2006) Determination of phosphoric acid triesters in human plasma using solid-phase
microextraction and gas chromatography coupled to inductively coupled plasma mass spectrometry. Journal of Chromatography. A
1103(2):329-336.
Stapleton HM, Klosterhaus S, Eagle S, et al. (2009) Detection of organophosphate flame retardants in furniture foam and U.S. house
dust. Environmental science & technology 43(19):7490-7495.
Stiles R, Yang I, Lippincott RL, et al. (2008) Measurement of drinking water contaminants by solid phase microextraction initially
quantified in source water samples by the USGS. Environmental science & technology 42(8):2976-2981.
van der Veen I and de Boer J (2012) Phosphorus flame retardants: Properties, production, environmental occurrence, toxicity and
analysis. Chemosphere 88(10): 1119-1153.
4-706
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Tris(tribromoneopentyl) Phosphate
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Tris(tribromoneopentyl) Phosphate
19186-97-1
M
M
L
M
M
H
L
L
L
L
L
L
H
M
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-707
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Tris(tribromoneopentyl) Phosphate
CASRN: 19186-97-1
MW: 1,018.5
MF: C,,H24Br904P
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: C(C(CBr)(CBr)CBr)OP(=0)(OCC(CBr)(CBr)CBr)OCC(CBr)(CBr)CBr
Synonyms: 1-Propanol, 3-bromo-2,2-bis(bromomethyl)-, 1,1',1 "-phosphate; 1-Propanol, 3-bromo-2,2-bis(bromomethyl)-, phosphate (3:1); 3-Bromo-2,2-
bis(bromomethyl)propan-l-ol, phosphate (3:1); Tris[3-bromo-2,2-bis(bromomethyl)propyl]phosphate; Tris(tribromoneopentyl) phosphate; Tris[2,2-
bis(bromomethyl)-3-bromopropyl] phosphate; Tris[3-bromo-2,2-bis(bromomethyl)propyl] phosphate; CR-900; Flame Cut 175; Flame Cut 175R; TPB 3070; FR370;
FR 372; Kronitex PB 370; Reoflam FR 370
Chemical Considerations: This is a discrete organic chemical with a MW slightly greater than 1,000. EPI v 4.0 was used to estimate physical/chemical and
environmental fate values due to an absence of experimental data. To provide robust estimates, physical-chemical property data from experimental studies were
incorporated into the estimation software.
Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: None
Analog: No analog
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: None
Risk Phrases: Not classified by Annex VI Regulation (EC) No 1272/2008 (ESIS, 2011).
Hazard and Risk Assessments: None identified.
4-708
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Tris(tribromoneopentyl) Phosphate CASRN 19186-97-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
183 (Measured)
Fisk et al., 2003
Adequate. Consistent values, which
span a relatively narrow range, have
been reported in secondary sources.
182-184 (Measured)
NICNAS, 2001
180-182 (Measured)
Haiju et al., 2009
Boiling Point (°C)
>300 (Estimated)
EPI; EPA, 1999
Cutoff value for high boiling
compounds according to High
Production Volume assessment
guidance.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
EPI; EPA, 1999
Cutoff value for nonvolatile
compounds according to HPV
assessment guidance.
Water Solubility (mg/L)
0.9 (Measured)
NICNAS, 2001; Fisk et al., 2003
Adequate.
Log Kow
8.1 (Estimated)
EPI
This compound may lie just outside
of the MW domain for the estimation
method, although the results are
consistent with a high MW material
with limited water solubility.
3.7 (Measured)
NICNAS, 2001; Fisk et al., 2003
Value inconsistent with measured
water solubility. Reported in a
secondary source; study details and
test conditions were not provided.
Flammability (Flash Point)
388.8°C (Measured)
ChemNet, 2011
Adequate.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Pyrolysis
No data located.
pH
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
4-709
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Tris(tribromoneopentyl) Phosphate CASRN 19186-97-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
pKa
Not applicable
Professional judgment
Does not contain functional groups
that are expected to ionize under
environmental conditions.
HUMAN HEALTH EFF
ECTS
Toxicokinetics
Tris(tribromoneopentyl) phosphate is poorly absorbed in rats following oral (gavage) exposure. In
addition, as a neat material, this substance is estimated to not be absorbed through the skin and to have
poor skin absorption when in solution. Tris(tribromoneopentyl) phosphate is expected to have poor
absorption via the lungs and gastrointestinal (GI) tract. This material is a potential alkylating and
crosslinking agent.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
Not absorbed through the skin as a neat
material and poor absorption through
skin when in solution; poor absorption
through the lung and GI tract.
(Estimated by analogy)
Professional judgment
Based on closely related
confidential analogs with similar
structures, functional groups, and
physical/chemical properties.
Rats administered test substance via oral
gavage;
1% of administered dose was absorbed,
with the proportion of radioactive
material excreted as unchanged test
material in urine or feces within 48 hours
of dosing.
Submitted confidential study
Reported in a submitted confidential
study; Study conducted according to
good laboratory practice (GLP).
This material is a potential alkylating and
crosslinking agent
(Estimated)
Professional judgment
Estimated based on professional
judgment.
Acute Mammalian Toxicity
MODERATE: Estimated to have potential for acute toxicity based on alkylation and expert judgment; no
data located.
Acute Lethality
Oral
Potential for acute toxicity based on a
consideration of the mechanistic
potential for alkylation
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Dermal
Inhalation
4-710
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Tris(tribromoneopentyl) Phosphate CASRN 19186-97-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Carcinogenicity
MODERATE: Estimated to have moderate potential for carcinogenicity based on a mechanistic
consideration of the potential for alkylation and crosslinking using professional judgment.
OncoLogic Results
No data located.
Carcinogenicity (Rat
and Mouse)
There is potential for carcinogenicity
based on a consideration of the
mechanistic potential for alkylation and
crosslinking.
(Estimated by analogy)
Professional judgment
Estimated based on professional
judgment.
Combined Chronic
Toxicity/
Carcinogenicity
Genotoxicity
LOW: Tris(tribromoneopentyl) phosphate was not mutagenic in bacteria
not cause chromosomal aberrations in Chinese hamster ovary (CHO) eel
or mouse lymphoma cells and did
s in vitro.
Gene Mutation in vitro
There is potential for mutagenicity based
on the potential for alkylation and
crosslinking.
(Estimated by analogy)
Professional judgment
Estimated based on professional
judgment.
Negative, Salmonella typhimurium
strains TA98, TA100, TA1535, TA1537,
TA1538 with and without metabolic
activation.
Submitted confidential study
Reported in a submitted confidential
study; Study conducted according to
GLP.
Negative, mouse lymphoma L5178Y
cells, with and without metabolic
activation.
Submitted confidential study
Reported in a submitted confidential
study.
Gene Mutation in vivo
Chromosomal
Aberrations in vitro
Negative, CHO cells, with and without
metabolic activation. Equivocal results
in cytogenic assay for numerical
aberrations.
Submitted confidential study
Reported in a submitted confidential
study.
Chromosomal
Aberrations in vivo
No data located.
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
4-711
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Tris(tribromoneopentyl) Phosphate CASRN 19186-97-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproductive Effects
MODERATE: Estimated to have potential for reproductive effects based on alkylation and expert
judgment; no data located.
Reproduction/
Developmental Toxicity
Screen
Potential for reproductive toxicity based
on a consideration of the mechanistic
potential for alkylation
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Reproduction and
Fertility Effects
Developmental Effects
MODERATE: For developmental toxicity a NOAEL of 300 mg/kg-day and a LOAEL of 1,000 mg/kg-day
(for slightly reduced fetal weight and marginally increased placental weight) were reported for rats orally
exposed on gestation days (GDs) 1-19 which aligns with a low hazard designation. However, there is
moderate potential for neurodevelopmental effects from exposure to tristribromoneopentyl phosphate
based on presence of alkylating groups and potential for cholinesterase inhibition. There were no studies
located that were specifically designed to evaluate the neurodevelopmental endpoint.
Reproduction/
Developmental Toxicity
Screen
There is potential for developmental and
neurodevelopmental effects based on a
mechanistic consideration of the
potential for alkylation and crosslinking,
and cholinesterase inhibition.
(Estimated by analogy)
Professional judgment
Estimated based on cholinesterase
inhibition by analogy to tris (1,3-
dichloro-2-propyl phosphate.
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
No data located.
4-712
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Tris(tribromoneopentyl) Phosphate CASRN 19186-97-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Prenatal Development
Pregnant rats; oral gavage; GDsl-19;
100, 300 or 1,000 mg/kg-day test
substance.
Maternal:
No deaths. No significant clinical signs
or toxicity or changes in bodyweight or
food consumption. No adverse effects on
mean implantation count, incidence of
pre-or post-implantation losses or
numbers of live young.
Fetal:
Slightly reduced fetal weight and
marginally increased placental weight
(1,000 mg/kg); No skeletal or visceral
anomalies.
NOAEL = 300 mg/kg-day for fetuses
based on slight reduction of fetal growth
LOAEL = 1,000 mg/kg-day (slightly
reduced fetal weight; marginally
increased placental weight)
Submitted confidential study
Reported in a submitted confidential
study; Study conducted in
accordance with GLP.
Postnatal Development
No data located.
Neurotoxicity
HIGH: Estimated to have high potential for neurotoxicity based on the potential for the neopentyl alcohol
groups acting as leaving groups, based on professional judgment.
Neurotoxicity Screening
Battery (Adult)
There is a potential for neurotoxicity
using a mechanistic analysis based on the
formation of neopentyl alcohol groups
due to their ability to act as good leaving
groups.
(Estimated by analogy)
Professional judgment
Estimated based on professional
judgment.
4-713
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Tris(tribromoneopentyl) Phosphate CASRN 19186-97-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Repeated Dose Effects
LOW: There were no treatment-related effects in rats following 28- or 90-day exposures at oral doses up to
20,000 ppm (1,358 and 1,685 mg/kg/day for males and females, respectively in the 90 day dietary study in
rats). There is uncertain potential for liver effects based on the bromo substituents of
tris(tribromoneopentyl) phosphate, based on professional judgment.
There is an uncertain potential for liver
effects based on a mechanistic
consideration of the reactions of the
bromo substituents of this chemical.
(Estimated by analogy)
Professional judgment
Estimated based on professional
judgment.
28-day study, rats, oral gavage, 0, 400,
8,000, 20,000 ppm test material.
No deaths. No treatment-related clinical
signs of toxicity or significant changes in
body weight, overall body weight gains
or food consumption. No changes in
hematological or clinical chemistry
parameters or in organ weights. No
compound-related macroscopic or
microscopic effects.
Submitted confidential study
Reported in a submitted confidential
study; Conducted in accordance
with GLP.
NOAEL = 20,000 ppm (highest dose
tested)
4-714
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Tris(tribromoneopentyl) Phosphate CASRN 19186-97-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
90-day dietary study in rats; 0, 2,000,
10,000, or 20,000 ppm test material.
No treatment-related deaths or clinical
signs of toxicity. No treatment-related
changes in body weight, ophthalmic
lesions or urinalysis/clinical
chemistry/hematological parameters. No
treatment-related findings during
necropsy or changes in organ weight. No
histopathological changes.
NOAEL = 20,000 ppm (1,358 and 1,685
mg/kg/day for males and females,
respectively); highest dose tested.
Submitted confidential study
Reported in a submitted confidential
study; Conducted in accordance
with GLP.
Skin Sensitization
LOW: Not a skin sensitizer in guinea pigs. There is some potential for sk
mechanistic consideration of the potential for alkylation and crosslinking
in sensitization based on a
, based on professional judgment.
Skin Sensitization
There is potential for skin sensitization
based on a mechanistic consideration of
the potential for alkylation and
crosslinking.
(Estimated by analogy)
Professional judgment
Based on closely related
confidential analogs with similar
structures, functional groups, and
physical/chemical properties.
Not sensitizing, guinea pigs
Submitted confidential study
Reported in a submitted confidential
study.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
LOW: Estimated to have low potential for eye irritation based on expert judgment.
Eye Irritation
Low potential for eye irritation.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
Dermal Irritation
LOW: Estimated to have low potential for dermal irritation based on expert judgment.
Dermal Irritation
Low potential for skin irritation.
(Estimated)
Expert judgment
Estimated based on expert
judgment.
4-715
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Tris(tribromoneopentyl) Phosphate CASRN 19186-97-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Endocrine Activity
No data located.
No data located.
Immunotoxicity
No data located.
Immune System Effects
No data located.
ECOTOXICITY
ECOSAR Class
Acute Toxicity
LOW: Tris(tribromopentyl) phosphate's large MW, limited bioavailability and low water solubility suggest
there will be no effects at saturation (NES). The estimated log Kow of 8.1 also is indicative of NES based on
ECOSAR cutoff values.
Fish LC50
Fish 96-hour LC50 >10 mg/L (test
concentration exceeded water solubility)
Fisk et al., 2003
Inadequate; details are missing as
this is a review on various
chemicals. In addition, the LC50 is
greater than the highest test
concentration.
Fish 96-hour LC50 = 0.006 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The large MW, limited
bioavailability and low water
solubility suggest there will be
NES; the log Kow of 8.1 for this
chemical exceeds the SAR
limitation for log K0„ of 5.0.
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
4-716
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Tris(tribromoneopentyl) Phosphate CASRN 19186-97-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Daphnia 48-hour LC50 = 0.007 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The large MW, limited
bioavailability and low water
solubility suggest there will be
NES; the log K0„ of 8.1 for this
chemical exceeds the SAR
limitation for log Kow of 5.0.
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
Green Algae ECS0
Green algae 96-hour EC50 = 0.037 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The large MW, limited
bioavailability and low water
solubility suggest there will be
NES; the log Kow of 8.1 for this
chemical exceeds the SAR
limitation for log K0„ of 6.4.
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
Chronic Aquatic Toxicity
LOW: The large MW, limited bioavaila
estimated log Kow of 8.1 is indicative of P
jility, and low water solubility suggest there will be NES. The
4ES based on ECOSAR cutoff values.
4-717
-------
Tris(tribromoneopentyl) Phosphate CASRN 19186-97-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish ChV
Fish ChV = 0.000495 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The large MW, limited
bioavailability and low water
solubility suggest there will be
NES; the log K0„ of 8.1 for this
chemical exceeds the SAR
limitation for log Kow of 8.0.
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
Daphnid ChV
Daphnid ChV = 0.00192 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The large MW, limited
bioavailability and low water
solubility suggest there will be
NES; the log Kow of 8.1 for this
chemical exceeds the SAR
limitation for log K0„ of 8.0.
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
4-718
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Tris(tribromoneopentyl) Phosphate CASRN 19186-97-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green Algae ChV
Green algae ChV = 0.040 mg/L
(Estimated)
ECOSAR: Neutral organics
ECOSAR version 1.11
NES: The large MW, limited
bioavailability and low water
solubility suggest there will be
NES; the log K0„ of 8.1 for this
chemical exceeds the SAR
limitation for log Kow of 8.0.
ECOSAR also provided results for
the Esters, and Esters (phosphate)
classes; however, professional
judgment indicates that this
compound does not lie within the
domain of the ECOSAR model.
ENVIRONMENTAL FATE
Transport
Evaluation of tris(tribromoneopentyl) phosphate transport is based entirely on estimations from quantitative
structure activity relationships. Tris(tribromoneopentyl) phosphate is expected to have low mobility in soil
based on its expected strong absorption to soil. If released to the atmosphere, tris(tribromoneopentyl)
phosphate is likely to exist solely as particulate. As a particulate, atmospheric oxidation is not expected to be a
significant route of environmental removal. Based on the Henry's Law constant, volatilization from water or
moist soil is not expected to occur at an appreciable rate. Level III fugacity models indicate that
tris(tribromoneopentyl) phosphate will partition predominantly to the soil.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
EPI; Professional judgment
Cutoff value for nonvolatile
compounds.
Sediment/Soil Adsorption/
Desorption
Coefficient - Koc
>30,000 (Estimated)
EPI; EPA, 1999
Cutoff value for nonmobile
compounds according to HPV
assessment guidance.
Level III Fugacity Model
Air: <1% (Estimated)
Water =1%
Soil = 64%
Sediment = 35%
EPI
4-719
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Tris(tribromoneopentyl) Phosphate CASRN 19186-97-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Persistence
HIGH: This substance has a MW slightly >1,000. It is expected to have negligible water solubility and poor
bioavailability to microorganisms indicating that biodegradation is not expected to be an important removal
process in the environment. Estimated hydrolysis half-lives of approximately 10 years indicate that this will
not be an important environmental removal process. Tris(tribromoneopentyl) phosphate does not contain
functional groups that would be expected to absorb light at environmentally significant wavelengths. As a
result, tris(tribromoneopentyl) phosphate is expected to have high potential for environmental persistence.
Water
Aerobic Biodegradation
Weeks-months (primary survey model);
Recalcitrant (ultimate survey model)
(Estimated)
EPI
Although this compound may lie just
outside of the MW domain for the
estimation method, the results are
consistent with a high MW material
that is not expected to be readily
assimilated.
Volatilization Half-life for
Model River
>1 year (Estimated)
EPI
Based on the magnitude of the
estimated Henry's Law Constant.
Volatilization Half-life for
Model Lake
>1 year (Estimated)
EPI
Based on the magnitude of the
estimated Henry's Law Constant.
Soil
Aerobic Biodegradation
No data located.
Anaerobic
Biodegradation
Probable (Anaerobic-methanogenic
biodegradation probability model)
(Estimated)
EPI; Professional judgment
The model predictions are being
driven by reduction of the bromine
substituent. Under environmental
conditions, the rate for anaerobic
degradation will likely be attenuated
due to the low water solubility and
limited bioavailability of this
material.
Soil Biodegradation with
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
Not a significant fate process (Estimated)
Professional judgment
This chemical is expected to exist in
the particulate phase in the
atmosphere.
4-720
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Tris(tribromoneopentyl) Phosphate CASRN 19186-97-1
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reactivity
Photolysis
No data located.
Hydrolysis
pH 7 = 9.9 years (Estimated)
pH 8 = 9.9 years
EPI
Pyrolysis
No data located.
Environmental Half-life
>180 days (Estimated)
Professional judgment
The substance has a MW slightly
>1,000 and is not anticipated to be
assimilated by microorganisms.
Therefore, biodegradation is not
expected to be an important removal
process. It is also not expected to be
readily removed by other degradative
processes under environmental
conditions because of limited water
solubility and lack of reactive
functional groups.
Bioaccumulation
MODERATE: The estimated BCF is >100 and <1,000.
Fish BCF
609 (Estimated)
EPI
BAF
8.8 (Estimated)
EPI
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-721
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CDC (Centers for Disease Control and Prevention). Fourth National Report on Human Exposure to Environmental Chemicals,
Updated Tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf as of
May 10, 2011.
ChemNet. ChemNet.com Physical and chemical property page for 19186-97-1 2,2-Bis-(bromomethyl)-3-bromo-l-propanol
phosphate. http://www.chemnet.com/cas/en/19186-97-l/Tris(tribromoneopentv0phosphate.html (accessed January 19, 2011).
[HPV Assessment Guidance] EPA (U.S. Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining
the Adequacy of Existing Data. U.S. Environmental Protection Agency: Washington D.C. 1999.
http://www.epa.gov/hpv/pub s/general/datadfin.htm
ECOSAR/EPI (EPIWIN/EPISUITE) Estimations Programs Interface for Windows, Version 1.11. U.S. Environmental Protection
Agency: Washington D.C. http J/www, epa. gov/opptintr/exposure/.
EPI (EPIWIN/EPISUITE) Estimation Program Interface for Windows, Version 4.0. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
ESIS (European chemical Substances Information System) Classification, labeling and packaging of dangerous substances annex VI
to regulation (EC) No 1272/2008 [Online] available at: http://esis.jrc.ec.europa.eu/clp-ghs as of May 10, 2011.
Fisk, P. R., Girling, A. E., Wildey. Prioritization of flame retardants for environmental risk assessment. Environment Agency,
Chemicals Assessment Section, 2003.
Harju, M.; Heimstad, E.; Herzke, D.; et al. Current state of knowledge and monitoring requirements - Emerging "new" brominated
flame retardants in flame retarded products and the environment (TA-2462/2008). Norwegian Pollution Control Authority, Oslo,
Norway. 2009.
NICNAS (National Industrial Chemicals Notification and Assessment Scheme). Polybrominated flame retardants (PBFRs) priority
existing chemical assessment Report No. 20 National Occupational Health and Safety Commission, Australia. 2001.
4-722
-------
Tris(tribromophenoxy) Triazine
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Tris(tribromophenoxy) Triazine
25713-60-4
L
L
L
L
L
L
L
L
L
VL
L
L
VH
H
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-723
-------
Tris(tribromophenoxy) Triazine
Br
j6l
Br Br Br
N O
Mj?.
A,
CASRN: 25713-60-4
MW: 1,067.43
MF: C2iH6Br9N303
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: cl(Br)c(Oc2nc(Oc3c(Br)cc(Br)cc3Br)nc(Oc3c(Br)cc(Br)cc3Br)n2)c(Br)cc(Br)cl
Synonyms: 1,3,5-Triazine, 2,4,6-tris(2,4,6-tribromophenoxy)-; Tris(tribromophenoxy) triazine; FR245; Tris(2,4,6-tribromophenoxy)-s-triazine;
Tris(tribromophenoxy)-s-triazine; Tris(tribromophenyl) cyanurate
Chemical Considerations: This is a discrete organic chemical with a MW slightly greater than 1,000. EPI v 4.0 was used to estimate physical/chemical and
environmental fate values due to an absence of experimental data.
Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: Tribromophenol (NICNAS, 2006)
Analog: No analog
Endpoint(s) using analog values: Not applicable
Analog Structure: Not applicable
Structural Alerts: Reproductive toxicity, triazines (EPA, 2011)
Risk Phrases: Not classified by Annex I Directive 67/548/European Economic Community (EEC) & IUCLID (Pakalin et al., 2007).
Hazard and Risk Assessments: None identified.
4-724
-------
Tris(tribromophenoxy) Triazine CASRN 25713-60-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
228-229 (Measured)
EC Directive 92/69/EEC A.l
NICNAS, 2006
Adequate; reported in a secondary
source. Melting started at 216-218°C,
likely due to impurities in test
substance.
Boiling Point (°C)
Decomposition at >275 (Measured)
EC Directive 92/69/EEC A.l using 99.5%
pure test substance
NICNAS, 2006
Adequate; reported in a secondary
source.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
EPI; EPA, 1999
Cutoff value for nonvolatile
compounds according to HPV
assessment guidance.
Water Solubility (mg/L)
<10"3at 20°C
(Measured)
Organisation of Economic Cooperation
and Development (OECD) TG 105, Good
laboratory practice compliant
NICNAS, 2006
Adequate; reported in a secondary
source. Reported value also
corresponds to the cutoff value for
nonsoluble compounds according to
High Production Volume assessment
guidance.
Log Kow
>10 (Estimated)
EPI; EPA, 1999
Although this material may be
outside the MW domain for the
estimation model, the resulting value
is consistent with that anticipated for
a highly brominated, high MW
substance. Cutoff value used
according to HPV assessment
guidance.
Flammability (Flash Point)
Nonflammable (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Explosivity
Not expected to form explosive mixtures
with air (Estimated)
Professional judgment
No experimental data located; based
on its use as a flame retardant.
Pyrolysis
No data located.
pH
No data located.
4-725
-------
Tris(tribromophenoxy) Triazine CASRN 25713-60-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
pKa
No data located; the high MW
precludes the use of available
estimation methods.
HUMAN HEALTH EFF
ECTS
Toxicokinetics
Tris(tribromophenoxy) triazine has a MW >1,000 and limited water solubility. There is no absorption
expected for any route of exposure for this compound and is not expected to be absorbed, distributed or
metabolized in the body. The lack of absorption is expected to result in low hazard potential.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
No absorption expected for any route of
exposure
(Estimated)
Professional judgment
Estimated based on professional
judgment.
Acute Mammalian Toxicity
LOW: Tris(tribromophenoxy) triazine has a MW >1,000 and limited water solubility. It is expected to have
limited bioavailability and therefore has low potential for acute mammalian toxicity. In addition, oral and
dermal LDS0 values >2,000 indicate a low level of toxicity.
Acute Lethality
Oral
Limited bioavailability expected
(Estimated)
Professional judgment; EPA,
1999
Based on HPV discrete organic
chemicals assessment guidance.
Rat oral LD50 >2,000 mg/kg
NICNAS, 2006
Reported in a secondary source.
Dermal
Rat dermal LD50 >2,000 mg/kg
NICNAS, 2006
Reported in a secondary source.
Inhalation
No data located.
Carcinogenicity
LOW: Tris(tribromophenoxy) triazine is expected to have limited bioavailability. It is estimated to have low
potential for carcinogenicity based on professional judgment.
OncoLogic Results
Limited bioavailability expected
(Estimated)
Professional judgment; EPA,
1999
Based on HPV discrete organic
chemicals assessment guidance.
Carcinogenicity (Rat
and Mouse)
Combined Chronic
Toxicity/
Carcinogenicity
4-726
-------
Tris(tribromophenoxy) Triazine CASRN 25713-60-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Genotoxicity
LOW: Tris(tribromophenoxy) triazine was not mutagenic in Salmonella typhimurium and did not induce
chromosome aberrations in human peripheral lymphocytes or L5178Y mouse lymphoma cells.
Tris(tribromophenoxy) triazine is expected to have limited bioavailability and therefore has low potential
for genotoxicity.
Gene Mutation in vitro
Limited bioavailability expected
(Estimated)
Professional judgment; EPA,
1999
Based on HPV discrete organic
chemicals assessment guidance.
Negative, Ames assay in Salmonella
typhimurium strains TA1535, TA1537,
TA98, TA100, with and without
activation.
NICNAS, 2006
Reported in a secondary source.
Gene Mutation in vivo
No data located.
Chromosomal
Aberrations in vitro
Negative, Mammalian Chromosome
Aberration Test in cultured human
peripheral lymphocytes, with and
without activation. Precipitation was
noted at the highest concentration tested.
NICNAS, 2006
Reported in a secondary source.
Negative, Mammalian Cell Gene
Mutation Test in L5178Y mouse
lymphoma cells with and without
activation. Precipitation was noted at the
highest concentration tested.
NICNAS, 2006
Reported in a secondary source.
Chromosomal
Aberrations in vivo
No data located.
DNA Damage and
Repair
No data located.
Other (Mitotic Gene
Conversion)
No data located.
Reproductive Effects
LOW: Tris(tribromophenoxy) triazine is expected to have limited bioavailability. It is estimated to have low
potential for reproductive effects based on professional judgment.
Reproduction/
Developmental Toxicity
Screen
Limited bioavailability expected
(Estimated)
Professional judgment; EPA,
1999
Based on HPV discrete organic
chemicals assessment guidance.
4-727
-------
Tris(tribromophenoxy) Triazine CASRN 25713-60-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Reproduction and
Fertility Effects
Developmental Effects
LOW: Tris(tribromophenoxy) triazine is expected to have limited bioavailability. It is estimated to have low
potential for developmental effects based on professional judgment.
Reproduction/
Developmental Toxicity
Screen
Combined Repeated
Dose with
Reproduction/
Developmental Toxicity
Screen
Prenatal Development
Postnatal Development
Limited bioavailability expected
(Estimated)
Professional judgment; EPA,
1999
Based on HPV discrete organic
chemicals assessment guidance.
Neurotoxicity
LOW: Tris(tribromophenoxy) triazine i
potential for neurotoxicity based on pro
s expected to have limited bioavailability. It is estimated to have low
essional judgment.
Neurotoxicity Screening
Battery (Adult)
Limited bioavailability expected
(Estimated)
Professional judgment; EPA,
1999
Based on HPV discrete organic
chemicals assessment guidance.
Repeated Dose Effects
LOW: Tris(tribromophenoxy) triazine is expected to have limited bioavailability. It is estimated to have low
potential for repeated dose effects based on professional judgment. Results from a 28-day repeated dose
study are consistent with this low hazard designation.
Limited bioavailability expected
(Estimated)
Professional judgment; EPA,
1999
Based on HPV discrete organic
chemicals assessment guidance.
4-728
-------
Tris(tribromophenoxy) Triazine CASRN 25713-60-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
In a 28-day repeated dose study, rats
(6/sex) were orally exposed to 0, 10, 50,
250, or 1,000 mg/kg bw-day. There was
neither mortality nor treatment-related
clinical signs of toxicity. There was a
decreased reticulocyte count and relative
adrenal weight in females and increased
relative liver weight and decreased
relative kidney weight in males;
however, these effects were not
considered dose- or treatment-related.
NICNAS, 2006
Reported in a secondary source.
NOAEL = 1,000 mg/kg bw/day (highest
dose tested)
Skin Sensitization
LOW: Tris(tribromophenoxy) triazine is not a skin sensitizer in guinea pigs.
Skin Sensitization
Negative results in a skin sensitization
maximization test in guinea pigs (0-6%
response rate).
NICNAS, 2006
Reported in a secondary source.
Respiratory Sensitization
No data located.
Respiratory
Sensitization
No data located.
Eye Irritation
LOW: Tris(tribromophenoxy) triazine is a slight eye irritant in rabbits.
Eye Irritation
Slightly irritating to rabbit eyes
NICNAS, 2006
Reported in a secondary source.
Dermal Irritation
VERY LOW: Tris(tribromophenoxy) triazine is not a skin irritant in rabbits.
Dermal Irritation
Non-irritating to rabbit skin
NICNAS, 2006
Reported in a secondary source.
Endocrine Activity
Tris(tribromophenoxy) triazine is expected to have limited bioavailability based on its MW. It is estimated
to have low potential for endocrine activity based on professional judgment. No data located.
Limited bioavailability expected
(Estimated)
Professional judgment; EPA,
1999
Based on HPV discrete organic
chemicals assessment guidance.
4-729
-------
Tris(tribromophenoxy) Triazine CASRN 25713-60-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Immunotoxicity
No data located. Tris(tribromophenoxy) triazine is expected to have limited bioavailability based on its MW
that is slightly above 1,000 daltons. It is estimated to have low potential for immunotoxicity based on
professional judgment with some uncertainty because the MW of this compound is near the cutoff of 1,000
daltons.
Immune System Effects
Limited bioavailability expected
(Estimated)
Professional judgment; EPA,
1999
Based on HPV discrete organic
chemicals assessment guidance.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
LOW: Tris(tribromophenoxy) triazine is expected to display no effects at saturation (NES) because the
amount dissolved in water is not anticipated to reach a concentration at which adverse effects may be
expressed.
Fish LC50
NES
Professional judgment
The MW >1,000, limited
bioavailability and low water
solubility suggest there will be
NES.
Daphnid LCS0
NES
Professional judgment
The MW >1,000, limited
bioavailability and low water
solubility suggest there will be
NES.
Green Algae ECS0
NES
Professional judgment
The MW >1,000, limited
bioavailability and low water
solubility suggest there will be
NES.
Chronic Aquatic Toxicity
LOW: Tris (tribromophenoxy) triazine is expected to display NES because the amount dissolved in water is
not anticipated to reach a concentration at which adverse effects may be expressed.
Fish ChV
NES
Professional judgment
The MW >1,000, limited
bioavailability and low water
solubility suggest there will be
NES.
Daphnid ChV
NES
Professional judgment
The MW >1,000, limited
bioavailability and low water
solubility suggest there will be
NES.
4-730
-------
Tris(tribromophenoxy) Triazine CASRN 25713-60-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Green Algae ChV
NES
Professional judgment
The MW >1,000, limited
bioavailability and low water
solubility suggest there will be
NES.
ENVIRONMENTAL FATE
Transport
The transport assessment for tris(tribromophenoxy) triazine is based almost entirely on behavior anticipated
for high MW (>1,000), water insoluble, nonvolatile materials. Leaching of tris(tribromophenoxy) triazine
through soil to groundwater is not expected to be an important transport mechanism. Estimated
volatilization half-lives indicate that it will be nonvolatile from surface water. Volatilization from dry surface
is also not expected based on its vapor pressure. In the atmosphere, this compound is expected to exist solely
in the particulate phase, based on its estimated vapor pressure. Particulates may be removed from air by wet
or dry deposition.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
EPI; Professional judgment
Although this material may be
outside the MW domain for the
estimation model, the resulting value
is consistent with that anticipated for
a highly brominated, high MW
substance. Cutoff value used for
nonvolatile compounds.
Sediment/Soil
Adsorption/Desorption
Coefficient - Koc
>30,000 (Estimated)
EPI; EPA, 1999
Although this material may be
outside the MW domain for the
estimation model, the resulting value
is consistent with that anticipated for
a highly brominated, high MW
substance. Cutoff value for non
mobile compounds according to HPV
assessment guidance.
Level III Fugacity Model
Air: <1% (Estimated)
Water = 4.2%
Soil = 93%
Sediment = 2.8%
EPI
Although this material may be
outside the MW domain for the
estimation model, the resulting value
is consistent with that anticipated for
a highly brominated, high MW
substance.
4-731
-------
Tris(tribromophenoxy) Triazine CASRN 25713-60-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Persistence
VERY HIGH: Biodegradation is not expected to be a major removal process based on experimental data. No
biodegradation occurred in a 28-day ready biodegradation test. In a guideline inherent biodegradation test,
only 4% of the test substance was removed in 72 days. Therefore, biodegradation is not expected to be a
major removal process. Volatilization, atmospheric photooxidation, and hydrolysis are also not expected to
occur. Therefore, tris(tribromophenoxy) triazine is expected to be highly persistent in the environment.
Water
Aerobic Biodegradation
Not readily biodegradable after 28 days;
no degradation measured by biochemical
oxygen demand using microorganisms
obtained from activated sludge, 6%
measured by high performance liquid
chromatography (Measured)
NICNAS, 2006
Adequate; value reported in a
secondary source.
Not inherently biodegradable after 72
days; 4% degradation according to OECD
302D (Measured)
NICNAS, 2006
Adequate; value reported in a
secondary source.
Recalcitrant (Estimated)
EPI; Professional judgment
Although this material may be
outside the MW domain for the
estimation model, the resulting value
is consistent with that anticipated for
a highly brominated, high MW
substance.
Not probable (Anaerobic-methanogenic
biodegradation probability model)
(Estimated)
EPI; Professional judgment
Although this material may be
outside the MW domain for the
estimation model, the resulting value
is consistent with that anticipated for
a highly brominated, high MW
substance.
Volatilization Half-life for
Model River
>1 year (Estimated)
EPI; Professional judgment
Although this material may be
outside the MW domain for the
estimation model, the resulting value
is consistent with that anticipated for
a highly brominated, high MW
substance.
4-732
-------
Tris(tribromophenoxy) Triazine CASRN 25713-60-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Volatilization Half-life for
Model Lake
>1 year (Estimated)
EPI; Professional judgment
Although this material may be
outside the MW domain for the
estimation model, the resulting value
is consistent with that anticipated for
a highly brominated, high MW
substance.
Soil
Aerobic Biodegradation
No data located.
Anaerobic
Biodegradation
No data located.
Soil Biodegradation with
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
Not a significant fate process (Estimated)
Professional judgment
This chemical is expected to exist in
the particulate phase in the
atmosphere.
Reactivity
Photolysis
No data located.
Hydrolysis
Not a significant fate process (Estimated)
Wolfe and Jeffers, 2000;
Professional judgment
The substance does not contain
functional groups that would be
expected to hydrolyze and has
negligible water solubility.
Environmental Half-life
>180 days (Estimated)
EPI; Professional judgment
Although this material may be
outside the MW domain for the
estimation model, the resulting value
is consistent with that anticipated for
a highly brominated, high MW
substance.
Bioaccumulation
HIGH: The estimated BAF for this chemical is >5,000. Although measured BCF values were located,
estimated BAF values are incorporated for a conservative approach. The BAF estimate is consistent with the
potential for bioaccumulation that is anticipated for high MW chemicals with a high degree of bromination.
4-733
-------
Tris(tribromophenoxy) Triazine CASRN 25713-60-4
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Fish BCF
<0.8 to 9;
<8 to 18 Carp
(Measured)
Using continuous flow-through test
NICNAS, 2006
Results are consistent with chemicals
with low water solubility and high
MW, suggesting limited transport
through gills.
BAF
8,800 (Estimated)
EPI
Although this material may be
outside the MW domain for the
estimation model, the resulting value
is consistent with that anticipated for
a highly brominated, high MW
substance. Assessment criteria
indicate estimated BAF may be used
in preference to measured BCF
values.
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-734
-------
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
May 10, 2011).
U.S. EPA (Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing
Data. U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
EPA Sustainable Futures. Using NonCancer Screening within the SF Initiative. U.S. Environmental Protection Agency: Washington
D.C. 2011. http://www.epa.gOv/opptintr/sf/pubs/noncan-screen.htm#svstemic (accessed on February 09, 2011).
EPI (EPIWIN EPISUITE) Estimation Program Interface for Windows, Version 4.0. U.S. Environmental Protection Agency:
Washington D.C. http://www.epa.gov/opptintr/exposure/.
NICNAS (National Industrial Chemicals Notification and Assessment Scheme). Full Study Report, File No:STD/l 132, 2006.
http://www.nicnas.gov.au/publications/car/new/std/stdfullr/stdl000fr/stdll32fr.pdf (accessed on April 11, 2011).
Pakalin, S.; Cole, T.; Steinkellner, J.; Nicolas, R.; Tissier, C.; Munn, S.; Eisenreich, S. Review on Production Processes of
Decabromodiphenyl Ether (DECABDE) used in Polymeric Applications in Electrical and Electronic Equipment, and Assessment of
the Availability of Potential Alternatives to DECABDE. [Online] 2007.
http://publications.irc.ec.europa.eu/repository/handle/l 11111111/5259 (accessed on January 20, 2011).
Wolfe, N; Jeffers, P. (2000) Hydrolysis. In Boethling, R.; Mackay, D., Handbook of Property Estimation Methods for Chemicals,
Environmental Health Sciences (311-334). Boca Raton: Lewis Publishers.
4-735
-------
Zinc Borate
Screening Level Hazard Summary
This table only contains information regarding the inherent hazards of flame retardant chemicals. Evaluation of risk considers both the hazard and exposure associated with the
substance including combustion and degradation by-products. The caveats listed in the legend and footnote sections must be taken into account when interpreting the hazard
information in the table below.
VL = Very Low hazard L = Low hazard = Moderate hazard H = High hazard VH = Very High hazard — Endpoints in colored text (VL, L, , H and VH) were
assigned based on empirical data. Endpoints in black italics (VL, L, M, H, and VH) were assigned using values from estimation software and professional judgment.
R Recalcitrant: substance is or contains inorganics, such as metal ions or elemental oxides, that are expected to be found in the enviromnent >60 days after release.
Chemical
CASRN
Human Health Effects
Aquatic
Toxicity"
Environmental
Fate
Acute Toxicity
Carcinogenicity
Genotoxicity
Reproductive
Developmental
Neurological
Repeated Dose
Skin Sensitization
Respiratory
Sensitization
Eye Irritation
Dermal Irritation
Acute
Chronic
Persistence
Bioaccumulation
Zinc Borate
1332-07-6
L
L
H
M
M
H
L
L
L
L
H
H
Hr
L
"Aquatic toxicity: EPA/DfE criteria are based in large part upon water column exposures which may not be adequate for poorly soluble substances such as many flame retardants
that may partition to sediment and particulates.
4-736
-------
CASRN: 1332-07-6, 138265-88-0
MW: 125
MF: ZnB03H (Empirical)
Physical Forms:
Neat: Solid
Use: Flame retardant
SMILES: Not applicable
Synonyms: Boric acid, zinc salt; Boron zinc hydroxide oxide; Alcanex FR 100; Alcanex FRC 600; Bonrex FC; Borax 2335; Borogard ZB; Climax; ZB 467; 128859;
FRC 600; Firebrake 415; Firebrake 500; Firebrake ZB; Flamtard Z 10; JS 9502; SZB 2335; Storshield ZB2335; XPI 187; ZB 112; ZB 113; ZB 223; ZB 237; ZB 325;
ZB 467 Lite; ZB-Shield; ZN 100; ZSB 2335; ZT; Zinc borate
Chemical Considerations: This alternative is an inorganic compound. Zinc borates have the general formula xZnO • yB203 • zH20. Zinc borate hydrate analogs may
have differing and possibly complex ratios for the water of hydration. In the absence of experimental data, professional judgment using chemical class and structural
considerations were used to complete this hazard profile.
Polymeric: No
Oligomers: Not applicable
Metabolites, Degradates and Transformation Products: Zinc (23713-49-7), borate (39201-27-9), zinc oxide (1314-13-2), zinc hydroxide, boric acid (10043-35-3;
11113-50-1)
Analogs: Zinc borate hydrate analogs include CASRNs 12447-61-9, 12513-27-8, 27043-84-1,
12280-01-2, 12429-73-1, 12536-65-1, 147749-62-2 (Briggs, 2004; Smith, 2002; Lide, 2008; Touval,
2000; Goodwin, 2006); analog data from other confidential compounds was also used.
Endpoint(s) using analog values: Not applicable
Structural Alerts: Boron containing compounds, developmental toxicity (EPA, 201 la).
Risk Phrases: R50/53 - Very toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment. Zinc borate's dissolution produces soluble
zinc ions (U.S. Borax, Inc., 2002). Not classified by Annex VI Regulation (EC) No 1272/2008 (ESIS, 2011).
Hazard and Risk Assessments: Risk assessment completed for zinc borate by the National Academy of Sciences (NAS, 2000); Pesticide Registration Review
completed by EPA (201 lb).
Zn
2+
HOx /O
B
I
OH
Analog Structure:
Zn
2+
HO. .0
B
I
OH
%-H
4-737
-------
Zinc Borate CASRN 1332-07-6,138265-88-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
PHYSICAL/CHEMICAL PROPERTIES
Melting Point (°C)
980 (for 12513-27-8 and 138265-88-0)
(Estimated by analogy)
Lewis, 1993; NAS, 2000; Gowda,
2007; Lide, 2008
The values reported for the zinc
borate and its hydrates are consistent
with that expected for these inorganic
salts, which are characterized by high
melting points. At elevated
temperatures, the hydrated materials
may lose their waters of hydration.
Phase change at 650
(Measured)
U.S. Borax Inc., 2002
>550 (for 12447-61-9)
(Estimated by analogy)
EPA, 1991 (as described in
Maine DEP, 2007)
Boiling Point (°C)
>500, Decomposes (Estimated)
Professional judgment
Adequate; decomposition occurs
upon melting as described in located
sources above. This is anticipated to
occur at or above the melting point.
Vapor Pressure (mm Hg)
<10"8 (Estimated)
Professional judgment; EPA,
1999
Cutoff value for nonvolatile materials
according to HPV assessment
guidance; expected for an inorganic
salt.
Negligible (Measured)
HDP, 2004
Qualitative, nonspecific value.
Water Solubility
<0.28% at 25°C (Measured)
Clayton and Clayton, 1994; HDP,
2004; U.S. Borax Inc., 2002
The values reported for the zinc
borate hydrates indicate that its
dissolution is pH dependent and
includes the pH range 5-7 that is
typically found in the environment.
0.1% at pH 5 and 7 and 23°C
0.03% at pH 9 and 23°C
(for 12447-61-9) (Estimated by analogy)
Lindsay, 1991
Zinc borate is slightly soluble in water. At
low pH, zinc borate can dissociate to zinc
and borate ions (for 12447-61-9)
(Estimated by analogy)
Sanders, 2007
Indicates the potential for liberation
of zinc ions under acid conditions
such as those found in the stomach.
Log Kow
No data located. Compound is not
amenable to available estimation
techniques.
Flamm ability (Flash Point)
Nonflammable (Measured)
Sax and Lewis, 1987
Adequate.
4-738
-------
Zinc Borate CASRN 1332-07-6,138265-88-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Explosivity
Not explosive (Measured)
U.S. Borax, Inc., 2002
Adequate.
Pyrolysis
Not applicable (Estimated)
Professional judgment
Inorganic compounds do not undergo
pyrolysis.
pH
7.6 (for 12447-61-9)
(Estimated by analogy)
In a 1% suspension of product to distilled
water by mass concentration (w:w).
Gowda, 2007
Adequate; indicates that this
substance is a weak base in solution.
pKa
No data located; inorganic
compounds are outside the estimation
domain of SPARC.
HUMAN HEALTH EFF]
ECTS
Toxicokinetics
Zinc borate is estimated to not be absorbed through skin. Absorption is expected through lungs and
gastrointestinal (GI) tract. Limited toxicokinetic data suggest that zinc borate breaks down readily in the
stomach to zinc oxide and boric acid.
Dermal Absorption in vitro
No data located.
Absorption,
Distribution,
Metabolism &
Excretion
Oral, Dermal or Inhaled
No exposure expected through skin but
absorption expected through lungs and GI
tract.
(Estimated by analogy)
Professional judgment
Based on closely related confidential
analogs with similar structures,
functional groups, and physical/
chemical properties.
Zinc borate readily breaks down to zinc
oxide and boric acid in the stomach.
NAS, 2000
Limited study details reported in a
secondary source.
Acute Mammalian r
oxicity
LOW: Based on acute toxicity values >2,000 mg/kg for the oral and dermal routes of exposure. Data are
inadequate to assess inhalation exposure.
Acute Lethality
Oral
Zinc borate: Rat oral LD50 >10,000 mg/kg
EPA, 1991 (as described in Maine
DEP, 2007)
Limited study details reported in a
secondary source.
Zinc borate: Rat oral LD50 >5,000 mg/kg
Cervan, 1992 (as described in
Maine DEP, 2007)
Limited study details reported in a
secondary source.
Zinc borate: Rat oral LD50 >10,000 mg/kg
Daniels et al., 1969 (as described
in Maine DEP, 2007)
Limited study details reported in a
secondary source.
Dermal
Zinc borate: Rabbit dermal LD50 >10,000
mg/kg
EPA, 1991 (as described in Maine
DEP, 2007)
Limited study details reported in a
secondary source.
4-739
-------
Zinc Borate CASRN 1332-07-6,138265-88-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Inhalation
Zinc borate: (species unspecified)
inhalation LC50 >5 mg/L
EFRA, 2006
Inadequate; no study details reported
in a secondary source. Species not
identified; not specified if aerosol or
dust/fume form.
Carcinogenicity
LOW: There is no evidence of carcinogenicity following exposure to zinc borate or its metabolites zinc oxide
and boric acid. Zinc borate is not listed as a known carcinogen by the International Agency for Research on
Cancer (IARC), National Toxicology Program (NTP), U.S. EPA or California Proposition 65.
OncoLogic Results
No data located.
Carcinogenicity (Rat and
Mouse)
Zinc borate: Not listed as a known
carcinogen by IARC, NTP, U.S. EPA, or
California Proposition 65.
Vlaine DEP, 2007
Boric acid: 2-year feeding study in rats
and dogs. No carcinogenic effects
observed in either rats or dogs at doses as
high as 58.5 and 40.8 mg/kg-day,
respectively.
Weir and Fisher, 1972 (as
described in Maine DEP, 2007
and HERA, 2005)
Limited study details reported in a
secondary source.
Boric acid: No carcinogenic effects
reported in mice exposed to doses as high
as 201 mg/kg-day in an NTP bioassay.
NTP, 1987 (as described in Maine
DEP, 2007)
Limited study details reported in a
secondary source.
Combined Chronic
Toxicity/ Carcinogenicity
No data located.
Genotoxicity
HIGH: Potential for mutagenicity based on exposure to zinc. Zinc borate did not cause gene mutations or
chromosomal aberrations in vitro. In addition, in vitro and in vivo assays for the metabolite boric acid were
negative for genotoxicity.
Gene Mutation in vitro
Zinc: Potential for mutagenicity based on
exposure to zinc
(Estimated)
Professional judgment
Estimated based on professional
judgment.
Zinc borate: Ames assay in Salmonella
typhi murium: Negative with and without
metabolic activation
EPA, 1991 (as described in Maine
DEP, 2007)
Limited study details reported in a
secondary source.
4-740
-------
Zinc Borate CASRN 1332-07-6,138265-88-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Boric acid: Mutation assays in S.
typhi murium, Escherichia coli, and
mammalian cells (L5178Y mouse
lymphoma, V79 Chinese hamster cells,
C3H/10T1/2 cells): Negative
Haworth et al., 1983; Landolph,
1985; NTP, 1987; Bakke, 1991;
Stewart, 1991 (as described in
Maine DEP, 2007)
Limited study details reported in a
secondary source.
Gene Mutation in vivo
Boric acid: In vivo mouse bone marrow
micronucleus assay: Negative
O'Loughlin. 1991 (as described in
Maine DEP, 2007)
Limited study details reported in a
secondary source.
Chromosomal
Aberrations in vitro
Zinc borate: Did not induce chromosomal
aberrations in vitro: Negative
EPA, 1991 (as described in Maine
DEP, 2007)
Limited study details reported in a
secondary source.
Boric acid: Chromosomal aberration and
sister chromatid exchanges in mammalian
cells: Negative
Haworth et al., 1983; Landolph,
1985; NTP, 1987; Bakke, 1991,
Stewart, 1991 (as described in
Maine DEP, 2007)
Limited study details reported in a
secondary source.
Chromosomal
Aberrations in vivo
No data located.
DNA Damage and Repair
Boric acid: Negative in bacterial DNA-
damage assay, unscheduled DNA synthesis
in hepatocytes
Haworth et al., 1983; Landolph,
1985; NTP, 1987; Bakke, 1991,
Stewart, 1991 (as described in
Maine DEP, 2007)
Limited study details reported in a
secondary source.
Other (Mitotic Gene
Conversion)
No data located.
4-741
-------
Zinc Borate CASRN 1332-07-6
, 138265-88-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reproductive Effects
MODERATE: Estimated based on reproductive system effects following exposure to boric acid. Exposure to
boric acid resulted in male reproductive toxicity including increased incidence of testicular atrophy, reduced
sperm count, and degeneration of seminiferous tubules.
Reproduction/
Developmental Toxicity
Screen
Boric acid: Rat 3-generation study;
increased incidence of testicular atrophy,
degeneration of seminiferous tubules,
reduced sperm count and reduced fertility.
NOAEL = 17.5 mg boron/kg-day
(corresponding to 100 mg boric acid/kg -
day)
LOAEL = 58.5 mg boron/kg-day
(corresponding to 334 mg boric acid/kg -
day)
Weir and Fisher, 1972 (as
described in Maine DEP, 2007
and HERA, 2005)
Study details reported in a secondary
source.
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
No data located.
Reproduction and
Fertility Effects
Boric acid: Increased incidence of
reversible disruption of tubular
spermiation in rats administered 175
mg/kg-day
LOAEL =175 mg/kg-day
Linder et al., 1990 (as described in
Maine DEP, 2007 and HERA,
2005)
Limited study details reported in a
secondary source.
Boric acid: No reproductive effects
reported in rats following exposure to a
single dose of 2,000 mg/kg-day
NOAEL = 2,000 mg/kg-day
Bouissous and Castagnol, 1965
(as described in Maine DEP,
2007)
Limited study details reported in a
secondary source.
Boric acid: Increased incidence of
reversible inhibition of spermiation in rats
administered 217 mg/kg-day for 14 days
LOAEL = 217 mg/kg-day
Ku et al., 1993 (as described in
Maine DEP, 2007)
Limited study details reported in a
secondary source.
4-742
-------
Zinc Borate CASRN 1332-07-6,138265-88-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Developmental Effects
MODERATE: Estimated based on developmental effects following exposure to zinc oxide, known to be
formed from zinc borate in the stomach. Exposure to zinc oxide resulted in increased incidence of stillborn
pups. Developmental toxicity data for boric acid exposure in rabbits, rats and mice are consistent with this
hazard designation.
Reproduction/
Developmental Toxicity
Screen
No data located.
Combined Repeated Dose
with Reproduction/
Developmental Toxicity
Screen
No data located.
Prenatal Development
Zinc oxide: Rat, oral (diet) exposure from
gestation days (GDs) 0 to lactation day 14;
no external malformations were observed.
There were no effects on maternal weight,
daily food intake, duration of gestation
and number of viable young/litter
decreased pup dry liver weights. There
were 4 stillborn pups (not edematous) in
dams of rats exposed to 150 mg/kg-day
and 2 females had stillborn litters
containing edematous pups in rats exposed
to 375 mg/kg-day.
LOAEL =150 mg ZnO/kg-day
Ketcheson et al. 1969 (as
described in Maine DEP, 2007
and ESIS, 2008)
Limited study details reported in a
secondary source.
4-743
-------
Zinc Borate CASRN 1332-07-6
, 138265-88-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Boric acid: Rabbit; GD 6-19, oral
(gavage); developmental effects.
Rabbit:
Maternal and Developmental NOAEL =
125 mg/kg-day
Maternal and Developmental LOAEL =
250 mg/kg-day
U.S. Borax and Chemical Corp,
1992a.
Limited study details reported;
TSCATS submission.
Rat:
NOAEL = 78 mg/kg-day
Mouse:
NOAEL = 248 mg/kg- day
Postnatal Development
No data located.
Neurotoxicity
HIGH: Estimated based on analogy to data for boric acid. Limited data indicate a 4-hour inhalation exposure
to boric acid may cause neurotoxic effects in rats at 0.16 mg/L. Limited data were located regarding
neurotoxic effects caused by exposure to zinc borate or zinc oxide. There is also potential for developmental
neurotoxicity based on boric acid using expert judgment.
Neurotoxicity
Boric acid: Rat 4-hour dust inhalation;
caused reduced righting reflex, hunched
posture, lacrimation and rales
LOAEL = 0.16 mg/L
U.S. Borax and Chemical Corp.,
1992b
Limited study details reported;
TSCATS submission.
Boric acid: Potential for developmental
neurotoxicity
(Estimated)
Expert judgment
Estimated based on expert judgment.
Zinc borate: Not classified as a
developmental neurotoxicant.
Grandjean and Landrigan, 2006
(as described in Maine DEP,
2007)
Limited study details reported in a
secondary source.
Zinc borate: Not listed as a potential
neurotoxicant on the Red List of
Chemicals
CPA, 2009 (as described in Maine
DEP, 2007)
Limited study details reported in a
secondary source.
4-744
-------
Zinc Borate CASRN 1332-07-6,138265-88-0
PROPERTY/ENDPOINT
DATA
REFERENCE DATA QUALITY
Zinc oxide: Rat, 10-day gavage exposure;
degenerative changes and histoenzymatic
changes, degenerative changes of
neurocytes, accompanied with
proliferation of the oligodendroglia, and
glial proliferation in the white matter.
Histoenzymatic changes including
decreased ACP, ATPase, AChE, BChE
activity and increased TTPase and NSE
activity.
Kozik et al., 1980 (as described in
Maine DEP, 2007)
Limited study details reported in a
secondary source.
Repeated Dose Effects
LOW: Estimated based on data for boric acid (a dissociation product of zinc borate). Limited data indicate
repeated exposure to boric acid may cause effects including decreased food consumption and body weight
gain, clinical signs of toxicity and changes in hematological parameters, though these effects occur at doses of
>100 mg/kg-day of boric acid. No repeated dose toxicity data were located for zinc borate or zinc (a
dissociation product of zinc borate). There is uncertain potential for immunotoxic effects based on
confidential data for other Zn2+ compounds.
Zinc oxide: Ferrets; oral (feed) 21-day
exposure; pale livers with fatty infiltration
and enlarged kidneys; macrocytic
hypochromic anemia, increased
reticulocytes and leucocytosis. Increased
severity at higher doses.
NOAEL = 81.3 mg/kg-day
LOAEL = 243.8 mg/kg-day
Straube et al., 1980 (as described
in Maine DEP, 2007)
Limited study details reported in a
secondary source. Data are for zinc
oxide.
4-745
-------
Zinc Borate CASRN 1332-07-6,138265-88-0
PROPERTY/ENDPOINT
DATA
REFERENCE DATA QUALITY
Boric acid: 2-year feeding study in rats
and dogs; effects in rats included
decreased food consumption and body
weight gain, course hair coats, hunched
position, swollen pads, inflamed bleeding
eyes and changes in hematological
parameters. Diarrhea and soft stool was
observed in dogs. Testicular effects were
reported for both rats and dogs.
NOAEL =100 mg boric acid/kg-day
LOAEL = 334 mg boric acid/kg-day
Weir and Fisher, 1972 (as
described in Maine DEP, 2007
and HERA, 2005)
Limited study details reported in a
secondary source. Values from
primary source are reported as boron
equivalent doses. Doses as boric acid
were not reported but are calculated
by dividing the boron equivalent
doses with the MW of boric acid
(0.1750).
i.e., NOAEL = 17.5 mg boron/kg-day
(corresponding to 100 mg boric
acid/kg-day)
LOAEL = 58.5 mg boron/kg-day
corresponding to 334 mg boric
acid/kg-day)
Immune System Effects
Uncertain potential for immunotoxic
effects
(Estimated by analogy)
Professional judgment
Based on confidential data for other
Zn2+ compounds.
Skin Sensitization
LOW: Zinc borate is not a skin sensitizer in guinea pigs.
Skin Sensitization
Zinc borate: Not a skin sensitizer in
guinea pigs
U.S. Borax Inc., 1996 (as
described in Maine DEP, 2007
andNAS, 2000)
Limited study details reported in a
secondary source.
Boric acid: Not a skin sensitizer in
humans or animals
Wnorowski, 1994a,b,c; Bruze et
al., 1995 (as described in Maine
DEP, 2007)
Limited study details reported in a
secondary source.
Respiratory Sensitization
No data located.
Respiratory Sensitization
No data located.
Eye Irritation
LOW: Zinc borate causes no irritation to mild irritation.
Eye Irritation
Contact with eyes causes irritation
HSDB, 2011
Limited study details reported in a
secondary source.
Mild conjunctivitis; not considered to be
and eye irritant or corrosive, rabbit
U.S. Borax Inc., 1996 (as
described in Maine DEP, 2007
andNAS, 2000)
Limited study details reported in a
secondary source.
4-746
-------
Zinc Borate CASRN 1332-07-6,138265-88-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Eye irritant with mild conjunctivitis, rabbit
EPA, 1991 (as described in Maine
DEP, 2007)
limited study details reported in a
secondary source.
Dermal Irritation
LOW: Zinc borate may cause skin irritation, but is not corrosive.
Dermal Irritation
Contact with skin causes irritation
HSDB, 2011
No study details reported in a
secondary source.
Mot irritant or corrosive
EPA, 1991 (as described in Maine
DEP, 2007)
No study details reported in a
secondary source.
Endocrine Activity
Does not have potential for endocrine activity based on expert judgment.
Mo potential for endocrine activity
(Estimated)
Expert judgment
Estimated based on expert judgment.
Immunotoxicity
There is uncertain potential for immunotoxicity based on exposure to zinc ions.
Immune System Effects
Uncertain potential for immunotoxic
effects
(Estimated by analogy)
Professional judgment
Based on confidential data for other
Zn2+ compounds.
ECOTOXICITY
ECOSAR Class
Not applicable
Acute Toxicity
HIGH: Based on estimated potential for dissolved zinc species to cause adverse effects in aquatic species, as
described in the EPA Chemical Categories document which includes all soluble complexes of zinc.
(Professional judgment)
Fish LCso
Potential for adverse effects in aquatic
species.
(Estimated)
Professional judgment
Estimated based on aquatic toxicity
effects from dissolve zinc species as
described in the EPA Chemical
Categories document.
Zinc borate: Classified as Dangerous to
the Environment, R50/R53, very toxic to
aquatic organisms may cause long-term
effects in the aquatic environment.
(Experimental)
EFRA, 2006 (as described in
Maine DEP, 2007)
Limited study details reported in the
database.
Zinc borate: Lepomis macrochirns
(bluegill) 96-hour LC50 = 335 mg/L
(Experimental)
ECOTOX
Limited study details reported in the
database.
4-747
-------
Zinc Borate CASRN 1332-07-6,138265-88-0
PROPERTY/ENDPOINT
DATA
REFERENCE DATA QUALITY
Zinc borate: Oncorhvnchiis mykiss
(rainbow trout) 96-hour LC50 = 2.7 mg/L
(Experimental)
ECOTOX
Limited study details reported in the
database.
Daphnid LCS0
Zinc borate: Daphnia magna 48-hour
EC50 = 75 mg/L (Experimental)
ECOTOX
Limited study details reported in the
database.
Green Algae ECS0
No data located.
Chronic Aquatic Toxicity
HIGH: Based on estimated potential for dissolved zinc species to cause adverse effects in aquatic species, as
described in the EPA Chemical Categories document which includes all soluble complexes of zinc.
(Professional judgment)
Fish ChV
Potential for adverse effects in aquatic
species.
(Estimated)
Professional judgment
Estimated based on aquatic toxicity
effects from dissolve zinc species as
described in the EPA Chemical
Categories document.
Zinc borate: Classified as Dangerous to
the Environment, R50/R53, very toxic to
aquatic organisms may cause long-term
effects in the aquatic environment.
(Experimental)
EFRA, 2006 (as described in
Maine DEP, 2007)
Limited study details reported in the
database.
Daphnid ChV
No data located.
Green Algae ChV
No data located.
ENVIRONMENTAL FATE
Transport
The transport evaluation for zinc borate is based on located experimental and estimated physical/chemical
properties. The low water solubility, low vapor pressure (10 8), estimated high soil adsorption and Henry's
Law Constant (<10 8) indicate that zinc borate will be relatively immobile in the environment. Transport is
more likely to occur in water and at low pH, where zinc borate dissociates into zinc and borate ions.
Henry's Law Constant
(atm-m3/mole)
<10"8 (Estimated)
Professional judgment
Cutoff value for nonvolatile
compounds such as inorganic salts.
This inorganic compound is not
amenable to available estimation
methods.
4-748
-------
Zinc Borate CASRN 1332-07-6,138265-88-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Sediment/Soil Adsorption/
Desorption
Coefficient - Koc
Zinc borate is sparingly soluble in water
and is not expected to leach through soil.
(Estimated)
Professional judgment
Available methods for estimating Koc
values cannot be directly applied to
inorganic salts.
Level III Fugacity Model
Not all input parameters for this
model were available to run the
estimation software (EPI).
Persistence
HIGH: Zinc borate is expected to have high persistence in the environment because of the persistence of
Zn2+ ions. The behavior of zinc borate in water is complex. In acidic aqueous conditions zinc borate releases
Zn2+ and boric acid; the Zn2+ will not undergo further degradation (but can undergo precipitation, sorption,
or ligand exchange reactions in the environment). In basic aqueous conditions, zinc borate forms boric acid
and hydrated zinc oxide. Zinc borate was found to be stable in sunlight, under normal and elevated
temperatures, according to an EPA guideline study.
Water
Aerobic Biodegradation
No data located.
Volatilization Half-life for
Model River
No data located.
Volatilization Half-life for
Model Lake
No data located.
Soil
Aerobic Biodegradation
No data located.
Anaerobic Biodegradation
No data located.
Soil Biodegradation with
Product Identification
No data located.
Sediment/Water
Biodegradation
No data located.
Air
Atmospheric Half-life
>1 year (Estimated)
Professional judgment
Substance is or contains inorganic
elements such as metal ions or oxides
that are not amenable to atmospheric
degradation processes.
4-749
-------
Zinc Borate CASRN 1332-07-6,138265-88-0
PROPERTY/ENDPOINT
DATA
REFERENCE
DATA QUALITY
Reactivity
Photolysis
Stability to sunlight, normal and elevated
temperature, according to EPA Method
830.6313 for metals/metal ions (for
12447-61-9) (Estimated by analogy)
Gowda, 2007
Adequate; guideline study.
Hydrolysis
<10 minutes at pH 6
48 hours at pH 9
(for 12447-61-9) (Estimated by analogy)
Lords, 2007
Adequate; formation of insoluble
hydrated zinc oxide precipitate occurs
atapH of 9.
Environmental Half-life
Not all input parameters for this
model were available to run the
estimation software (EPI).
Bioaccumulation
LOW: Zinc borate is not expected to be very soluble in water and therefore does not have potential for
bioaccumulation.
Fish BCF
<100 (Estimated)
Professional judgment
This inorganic compound is not
amenable to available estimation
methods.
BAF
<100 (Estimated)
Professional judgment
This inorganic compound is not
amenable to available estimation
methods.
Metabolism in Fish
No data located.
ENVIRONMENTAL MONITORING AND BIOMONITORING
Environmental Monitoring
No data located.
Ecological Biomonitoring
No data located.
Human Biomonitoring
This chemical was not included in the National Health and Nutrition Examination Survey biomonitoring report
(CDC, 2011).
4-750
-------
Bakke, J.P. Evaluation of the potential of boric acid to induce unscheduled DNA synthesis in the in vitro hepatocyte DNA repair assay
using the male F-344 Rat. Study No. 2389-V500-91; and Amendment 1 to the Original Report, Unpublished Report to US Disodium
tetraborate decahydrate. SRI International: MenloPark, CA. 1991.
Briggs, M. Kirk-Othmer Encyclopedia of Chemical Technology. New York, NY: John Wiley & Sons; Boron Oxides, Boric Acid, and
Borates. Online Posting Date: July 13, 2001. 2004.
Bruze, M., E. Hradil, I-L. Eriksohn, B. Gruvberger, and L.Widstrom. Occupational allergic contact dermatitis from alkanolamine
borates in metalworking fluids. Contact Dermatitis. 1995, 32:24-27.
Bouissou, H. and R. Castagnol. Action de l'acide borique dur le testicule de rat. Archives des Maladies Professionelles de Medecin du
Travail et de Securite Social, 1965, T286, 293-306.
CDC (Centers for Disease Control and Prevention). Fourth national report on human exposure to environmental chemicals, updated
tables. Department of Health and Human Services. 2011. http://www.cdc.gov/exposurereport/pdf/Updated Tables.pdf (accessed on
May 10, 2011).
Clayton, G.D. Clayton, F.E. (eds.) Patty's industrial hygiene and toxicology. Volumes 2A, 2B, 2C, 2D, 2E, 2F: Toxicology. 4th ed.
New York, NY: John Wiley & Sons Inc., 1993-1994, p. 4416
CPA (Clean Production Action). Red List of Chemicals. 2009.
ECOTOX. EPA (U.S. Environmental Protection Agency). ECOTOX database. Accessed July 2011.
http://cfpub.epa.gov/ecotox/quick query.htm.
EFRA (European Flame Retardants Association) Flame Retardant Fact Sheet. European Chemical Industry Council, 2006.
EPA (U.S. Environmental Protection Agency). Sustainable Futures. UsingNonCancer Screening within the SFInitiative. U.S.
Environmental Protection Agency: Washington D.C. 2011a. http://www.epa.gOv/opptintr/sf/pubs/noncan-screen.htm#svstemic
(accessed on February 9, 2011).
EPA (Environmental Protection Agency). Pesticide Registration review. 2011b.
http://www.epa.gov/oppsrrdl/registration_review/zinc_borate/
4-751
-------
EPA (U.S. Environmental Protection Agency). 1991. Pesticide Fact Sheet for Zinc Borate. Available:
http://www.epa.gov/nscep/index.html
U.S. EPA (Environmental Protection Agency). High Production Volume (HPV) Challenge. Determining the Adequacy of Existing Data.
U.S. Environmental Protection Agency: Washington D.C. 1999. http://www.epa.gov/hpv/pubs/general/datadfin.htm
European Chemical Substances Information System (ESIS). 2008. Risk Assessment Report for Zinc Oxide. European Commission Joint
Research Centre. Available: http://ecb.jrc.ec.europa.eu/esis/index.php?PGM=ein
European Chemical Substances Information System. (ESIS) Classification, Labeling and Packaging of Dangerous Substances Annex
VI to Regulation (EC) No 1272/2008 [Online] 2011. http://esis.irc.ec.europa.eu/clp-ghs/ (accessed on March 19, 2012).
Goodwin, F. Kirk-Othmer Encyclopedia of Chemical Technology. NY, NY: John Wiley & Sons; Zinc Compounds. Online Posting
Date: February 17, 2006. 2006.
Gowda, S. Summary of Product Chemistry, Environmental Fate and Ecotoxicity Data for the Zinc Borate Registration Review
Decision Document. U.S. EPA, EPA-HQ-OPP-2007-0675-004. 2007.
Grandjean, P. and P.J. Landrigan. Developmental neurotoxicity of industrial chemicals. Lancet. 2006, 368: 2167-2178.
Haworth, S; Lawlor, T; Mortelmans, K. Salmonella mutagenicity test results for 250 chemicals. Environ. Mutcit. 1983, Suppl 1:3-142.
HSDB (Hazardous Substances Data Bank). Entry for zinc borate. United States National Library of Medicine. 2011.
HDP (High Density Packaging). User Group International, Inc. The High Density Packaging User Group Design for Environment
Phase II project report. January 15, 2004. www.dell.com/downloads/global/corporate/environ/HDPUG DfE 2.pdf (accessed on
February 15, 2011).
Human & Environmental Risk Assessment on ingredients of European household cleaning products (HERA). 2005. Boric Acid.
Edition 1.0. Available: http://www.heraproiect.com/files/27-F-06 HERA Boric Acid%20 Jan 2005.pdf
4-752
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Ketcheson, M.R., G.P. Barron, and D.H. Cox. 1969. Relationship of maternal dietary zinc during gestation and lactation to
development and zinc, iron, and copper content of the postnatal rat. J Nutr 98:303-311.
Kozik, M.B., L. Maziarz, and A. Godlewski. Morphological and histochemical changes occurring in the brain of rats fed large doses
of zinc oxide. Folia. Histochem. Cytochem. 1980, 18:201-206.
Ku, W.W., R.E. Chapin, R.N. Wine, and B.C. Gladen. Testicular toxicity of boric acid (BA): Relationship of dose to lesion
development and recovery in the F344 rat. Reprod. Toxicol. 1993, 7:305-319.
Landolph, L.R. Cytotoxicity and negligible genotoxicity of disodium tetraborate decahydrate ores to cultured mammalian cells. Am. J.
Ind. Med. 1985, 7:31-43.
Lewis, R.J., Sr (Ed.). Hawley's Condensed Chemical Dictionary. 12th ed. New York, NY: Van Nostrand Rheinhold Co., p. 1243.
1993
Lide, D. R, ed. CRC Handbook of Chemistry and Physics, 88th edition; CRC Press Taylor & Francis: Boca Raton, FL. 2008.
Linder, R.E., L.F. Strader, and G.L. Rehnberg. Effect of acute exposure to boric acid on the male reproductive system of the rat. J.
Toxicol. Environ. Health. 1990, 31:133-146.
Lindsay, A. Registration of Zinc Borate (New Chemical), Briefing Memorandum U.S. EPA, EPA-HQ-OPP-2007-0675-005. 1991.
Lords, F. Zinc Borate Response Document October 2007. U.S. EPA, Docket Number:EPA-HQ-OPP-2007-0675-011. 2007.
Maine DEP. Maine Department of Environmental Protections. Decabromodiphenyl ether flame retardant in plastic pallets. Prepared
by Pure Strategies, Inc. Gloucester, MA. 2007.
NAS (National Academy of Sciences). Subcommittee on Flame-Retardant Chemicals; Toxicological Risks of Selected Flame
Retardant Chemicals. National Academy Press: Washington D.C. 2000.
NTP (National Toxicology Program). Toxicology and carcinogenesis studies of boric acid (CAS #10043-35-3) in B6C3F1 mice.
Technical Report Series No. 324. United States National Library of Medicine. 1987.
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O'Loughlin, K.G. Bone marrow erythrocyte micronucleus assay of boric acid in Swiss-Webster mice. Study No. 2389-C400-91,
Unpublished report to US Disodium tetraborate decahydrate. SRI International: Menlo Park, CA. 1991.
Sanders, F. Zinc Borate Summary Document Registration Review: Initial Docket September 2007. U.S. EPA, Docket Number:EPA-
HQ-OPP-2007-0675-002. 2007.
Sax, N.I. and R.J. Lewis, Sr. (eds.). Hawley's Condensed Chemical Dictionary. 11th ed. New York: Van Nostrand Reinhold Co., p.
1251. 1987.
Smith, R. Ullmann's Encyclopedia of Industrial Chemistry. New York, NY: John Wiley & Sons; Boric Oxide, Boric Acid, and
Borates. Online Posting Date: June 15, 2000. 2002.
SPARC. SPARC On Line Calculator pKa property server. Ver 4.5 September, 2009. Available from,
http://ibmlc2.chem .uga.edu/spare/ (accessed on March 14, 2012).
Stewart, KR. Salmonella/microsome plate incorporation assay of boric acid. Study No. 2389-A200-91, Unpublished report to U.S.
Disodium tetraborate. SRI International: Menlo Park CA. 1991.
Straube, E.F., Schuster, N.H.; Sinclair, A.J. Zinc toxicity in the ferret. J. Comp. Pathol. 1980, 90:355-361.
Touval, I. Kirk-Othmer Encyclopedia of Chemical Technology. New York, NY: John Wiley & Sons; Flame Retardants, Antimony
and Other Inorganic Agents. Online Posting Date: December 4, 2000. 2000.
U.S. Borax and Chemical Corporation. Initial submission: Developmental toxicity of boric acid in New Zealand white rabbits (final
report) with attachments and cover letter dated 010692. U.S. EPA TSCATS submission OTS 0535248. 1992a.
U.S. Borax and Chemical Corporation. Acute/sub acute toxicity of boric acid. U.S. EPA TSCATS submission 8EHQ-0592-04638A.
1992b.
U.S. Borax, Inc. Material Safety Data Sheet: Firebrake ZB. Valencia, CA: U.S.Borax. 1996.
U.S. Borax, Inc. Material Safety Data Sheet for Firebrake ZB. 2002. Available at:
http://www.sfm.state.or.us/CR2K_SubDB/MSDS/ZINC_BORATE.PDF.
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Weir, R.J. and R.S. Fisher. Toxicologic studies on borax and boric acid. Toxicol. Appl. Pharmacol. 1972, 23: 351-364.
Wnorowski, G. Dermal sensitization test - Buehler method on boric acid, Study - 3310. Product Safety Labs, East Brunswick, NJ
08816. Unpublished report to US Borax. 1994a.
Wnorowski, G. Dermal sensitization test -Buehler method on sodium tetraborate decahydrate, Study - 3308. Product Safety Labs, East
Brunswick, NJ 08816. Unpublished report to US Borax. 1994b.
Wnorowski, G. Dermal sensitization test - Buehler method on sodium tetraborate pentahydrate, Study - 3306. Product Safety Labs,
East Brunswick, NJ 08816. Unpublished report to US Borax. 1994c.
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4.9 References
International Agency for Research on Cancer. (2006). "Preamble to the IARC Monographs."
Retrieved April 17, 2012, from
http://monographs.iarc.fr/ENG/Preamble/currentb6evalrationale0706.php.
Mayo-Bean, K., K. V. Nabholz, et al. (2011). Methodology Document for the Ecological
Structure-Activity Relationship Model (ECOSAR) Class Program. Office of Pollution
Prevention and Toxics. Washington, DC.
Meylan, W. M. and P. H. Howard (1995). "Atom/fragment contribution method for estimating
octanol-water partition coefficients." J Pharm Sci 84(1): 83-92.
Meylan, W. M., P. H. Howard, et al. (1996). "Improved method for estimating water solubility
from octanol/water partition coefficient." Environ Toxicol Chem 15(2): 100-106.
Nabholz, J. V., R. G. Clements, et al. (1993). Validation of Structure Activity Relationships
Used by the USEPA's Office of Pollution Prevention and Toxics for the Environmental
Hazard Assessment of Industrial Chemcials. Environmental Toxicology and Risk
Assessment. J. W. Gorsuch, F. J. Dwyer, C. G. Ingersoll and T. W. La Point.
Philadelphia, American Society for Testing and Materials. 2: 571-590.
Rand, G., P. Wells, et al. (1995). Chapter 1: Introduction to Aquatic Toxicology. Fundamentals
of Aquatic Toxicology. G. Rand. Washington DC, Taylor & Francis: 53-54.
U.S. EPA. (1994). "Joint Project on the Evaluation of (Quantitative) Structure Activity
Relationships." Retrieved November 18, 2013, from
http://www.epa.gov/oppt/newchems/pubs/ene4147.pdf.
U.S. EPA. (1997). "Special Report on Environmental Endocrine Disruption: An Effects
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http://www.epa.gov/raf/publications/pdfs/ENDOCRINE.PDF.
U.S. EPA. (1999a). "Guidelines for Carcinogen Risk Assessment, Review Draft." Retrieved
November 18, 2013, from
http://www.epa.gov/raf/publications/pdfs/CANCER GLS.PDF.
U.S. EPA. (1999b). "High Production Volume (HPV) Challenge: Determining the Adequacy of
Existing Data." Retrieved November 18, 2013, from
http://www.epa. gov/hpv/pub s/ general/datadfin.htm.
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2012, from http://www.epa. gov/scipolv/oscpendo/index.htm.
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http://www.epa.gov/oppt/sf/tools/methods.htm.
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5 General Exposure Information and Other Life-Cycle
Considerations
The purpose of this chapter is to provide general information on exposure and life-cycle
considerations for flame retardant chemicals. Section 5.1 includes an overview of exposure
considerations and also includes data on some of the physical-chemical properties which impact
the probability of exposure to decabromodiphenyl ether (decaBDE) and the alternatives included
in the assessment. A quantitative exposure assessment is outside the scope of this project and is
not necessary for a comparative hazard assessment. This discussion is framed in the context of
five life-cycle stages: extraction (Section 5.2), chemical manufacture (Section 5.3), product
manufacture (Section 5.4), product use (Section 5.5) and end-of-life (Section 5.6), as shown in
Figure 5-1. Depending on the product type, intermediate steps between chemical and product
manufacturing may be relevant; these are briefly discussed in Section 5.4. The chapter is
intended to help the reader understand the factors that affect exposure to decaBDE and
alternative flame retardants across the life-cycle.
Figure 5-1: Life Cycle Stages Included in this Chapter
-1 7s* *
Raw Material
Extraction
Chemical
Manufacture
„ Resin Manufacture and Other
Intermediate Steps
Recycling
(unregulated)
Recycling
(regulated)
End-of-life
Processes
Building and
Construction Materials
Product
Manufacture
Landfills
Storage and
Distribution Products
Electronics
5.1 Potential Exposure Pathways and Routes (General)
Exposure can occur at many points in the life cycle of a flame retardant chemical. Occupational
5-1
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exposures may occur during raw material extraction, chemical and product manufacturing and at
product end-of-life (i.e., reuse, refurbishing, recycling, incinerating or landfilling). Consumers
may be exposed while the flame retarded product is being used. Exposures to the general
population and environment may result from product manufacturing, use, storage, and end-of-life
processes.
The risk associated with a given chemical or substance is influenced by how the exposure occurs.
For example, the risk associated with inhaling a chemical can be different from the risk due to
ingestion of the same chemical. As a result, exposure is typically characterized by pathway and
route. An exposure pathway is the physical course a chemical takes from the source of release to
the organism that is exposed. The exposure route is how a chemical gets inside the organism.
The three primary routes of exposure are inhalation, dermal absorption, and ingestion. Each
chemical's specific physical-chemical properties influence pathways and routes of exposure.
5.1.1 Occupational versus General Population Exposures
Exposures to the general population are different from exposures to workers and should be
evaluated separately. Occupational exposures may be both acute and chronic because of direct
contact with chemicals at relatively high concentrations while workers are conducting specific
tasks such as manufacturing and processing of chemicals. However, certain occupations such as
firefighting may result in unique occupational exposure scenarios. It may be more likely for
consumers to be exposed chronically, over a long period, but to chemicals incorporated into
products or released to the environment from a manufacturing facility. Information on sources of
human exposure to decaBDE can be found in Section 5.1.5.
5.1.2 Inhalation Exposures
The physical state of the chemical during chemical manufacturing, downstream processing,
incorporation into consumer products, and after release to the environment significantly
influences the potential for inhalation exposure. In particular, there are three types of inhalation
exposures that may be relevant for evaluation: dust, vapor, and/or mist.
Dust: "Dust is defined as solid particles of a substance or mixture suspended in a gas (usually
air)" (United Nations 2011). Chemicals that are manufactured, processed, stored, or used as
solids, have the potential to result in fugitive dust which may result in occupational exposures.
The potential for fugitive dust formation depends on whether the solid chemical is handled in the
crystalline form, as an amorphous solid, or as a fine powder. The particle size distribution and
handling techniques can also impact the potential for fugitive dust. It is important to note the
physical state of the chemical at the potential point of release and contact. For example, the pure
chemical may be manufactured as a solid powder, indicating a potential occupational exposure to
dust, but it may be formulated into solution before the majority of people come in contact with it,
thereby eliminating inhalation exposure to dust as a possible exposure route. The material safety
data sheet and best practice should inform the occupational worker when inhalation exposure to
the chemical is likely to occur and what respiratory safety measures should be used.
Furthermore, there is potential for a chemical to be released from a manufacturing facility and
enter a home either through air, dirt or dust. For example, dirt or dust from a workplace may
enter a home on a worker's clothing and be subsequently inhaled by other members of the
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household. Additionally, certain chemicals may be released from a product during consumer use
and become incorporated into indoor dust. Consumer exposures are dependent on how a
chemical is incorporated into a product and on the chemical's physical-chemical properties.
If there is exposure to dust, particle size influences the degree to which the chemical enters the
lungs. Particles less than 10 microns in diameter are "respirable" with potential to reach and
attach to tissues in the respiratory tract and deep lung where they may be absorbed into the body.
Once released into air or other media, the chemical can associate with particulate material
through sorption onto particles or as particulates. For example, vapor phase chemicals can
partition onto house dust and contribute to ingestion and dermal exposure pathways as well as
inhalation.
Design of transfer facilities, engineering controls, and the use of personal protective equipment
will have a greater impact on exposure potential in industrial settings than the size of the dust
particles. However, the size of the particles in a manufacturing setting can be considered by
individual decision-makers. Compounders may specify that the neat flame retardant be produced
in a way that minimizes the low particle size fraction. Although manufacturer-specific, the
particle size of the flame retardant chemical can be screened to remove the fine material that can
then be returned to the manufacturing process. In residential settings, the flame retardants in
electrical equipment and furniture, for example, may migrate to the surface of a material and
escape from the polymer matrix, then likely becoming part of house dust. Exposure to flame
retardants in house dust can be reduced by dusting frequently and using a vacuum cleaner with a
HEP A filter.
Vapor: Vapor is defined as "the gaseous form of a substance or mixture released from its liquid
or solid state" (United Nations 2011). Exposure to vapors can occur when chemicals volatilize
during manufacturing, processing, storage, and use or are associated with particulates in air.
Most chemical manufacturing operations occur in closed systems. However, fugitive emissions
are expected during open mixing operations, transfer operations, and loading/unloading of raw
materials. The more volatile the chemical the greater the fugitive releases and the higher
occupational exposures are likely to be. Therefore, vapor pressure (a measure of volatility) is a
key indicator of potential occupational exposures to vapors. Particulate exposures can result from
the physical breakdown of products, erosion of materials from surfaces or other similar
processes.
Mist: Mist is defined as "liquid droplets of a substance or mixture suspended in a gas (usually
air)" (United Nations 2011). Both volatile and non-volatile liquids can result in inhalation
exposure if manufacturing or use result in the formation of mist. Particle size is an important
consideration in determining exposure to chemicals released as a mist. However, it is unlikely
that flame retardant chemicals will be dispersed as a mist.
5.1.3 Dermal Exposures
Dermal exposure is also affected by the physical state of the chemical at the point of release and
contact. Additionally, studies have shown that the amount of a chemical that is absorbed through
the skin is dependent on where on the body the exposure occurs (U.S. EPA 1992). Dermal
exposure is generally assumed to be proportional to the concentration of chemical in the
5-3
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formulation (an exception would be if the solution contains ingredients that enhance dermal
transfer). For example, the dermal exposure from contacting a pure chemical is greater than the
exposure from contacting a solution that contains only 10 percent of the chemical. In addition to
chemical concentration, the extent to which skin will absorb a chemical that it has to come in
contact with depends on the chemical's lipophilicity, solubility, polarity volatility, structure and
state (e.g., liquid, solid) (U.S. EPA 1992). To be successfully absorbed, compounds must be able
to diffuse across both the aqueous pathways and lipid pathways in the skin. To do this, a
chemical must first dissolve into the stratum corneum, a stable lipid barrier that is the outermost
layer of the skin and the water-based portions of the skin and into the body, which is also water-
based (U.S. EPA 2007a). Therefore, the best skin penetrants are "those that exhibit fat- and
water-solubility and low levels of crystallinity" (p. 35 U.S. EPA 1992). Dermal exposure to
volatile substances is unlikely to occur.
For occupational exposures, screening-level evaluations of dermal exposure can be based on the
worker activities involving the chemical. For example, there may be exposure when workers
handle bags of solid materials during loading and transfer operations. Maintenance and cleanup
activities during shutdown procedures, connecting transfer lines, and sampling activities also
result in potential for dermal exposures. For consumers, dermal exposure can occur if a chemical
is released from a product that a consumer is handling or is in dust to which an individual comes
into contact. Children may have higher dermal exposure because they crawl, roll, or sit on
surfaces treated with chemicals and play with objects where residues may settle (U.S. EPA
2008). However, as stated above, absorption of a chemical through the skin is dependent on the
properties of the chemical (U.S. EPA 1992).
5.1.4 Ingestion Exposures
Exposures via ingestion typically occur unintentionally when individuals eat food or drink water
that has become contaminated with chemicals or ingest dust on hands. Several pathways should
be considered. In regards to occupational exposures, often the primary pathway is poor worker
hygiene (eating, drinking, or smoking with unwashed hands.) Additionally, dust particles may
spread throughout the facility and settle (or deposit) on tables, lunchroom surfaces, or even on
food itself. Vapors may similarly spread throughout the facility and may deposit near food or
drinks. Another potential pathway for ingestion occurs from dust particles that are too large to be
absorbed through the lungs. These "non-respirable particles" can be swallowed, resulting in
exposures from this route. Consumers in the general population may also be exposed through
ingestion if a chemical is released from a product and incorporated into dust, which can get on
hands or deposit on food and thus be consumed inadvertently. This is an important route of
exposure for children, particularly infants and toddlers, who may ingest dust and soil through
repeated hand-to-mouth behavior (U.S. EPA 2008). Compared to inhalation and dermal
exposures, ingestion is typically considered a less significant exposure pathway from an
occupational health standpoint. However, ingestion can be an equally or more significant
exposure pathway for the general population, especially children's ingestion of house dust, than
inhalation and dermal exposures.
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5.1.5 Human and Environmental Exposure to DecaBDE
This section summarizes the literature on occupational, consumer and environmental exposures
to decaBDE. This information on decaBDE exposure can be instructive. Similar patterns of
exposure may occur for alternative chemicals. However, exposure information and data are
limited and only available for some of the alternatives (Stapleton, Allen et al. 2008; Betts 2009;
Dodge, Pollock et al. 2009; Petito Boyce, Sax et al. 2009; Luo, Chen et al. 2010). Information on
products and materials in which decaBDE has been used can be found in Chapter 2.
Human Exposures
According to U.S. Environmental Protection Agency (EPA)'s 2010 exposure assessment of
polybrominated diphenyl ethers (PBDEs), individuals in occupations that would lead to higher
exposures to specific congeners have higher concentrations of PBDE congeners in their blood
than the general public (U.S. EPA 2010a). Workers involved in the manufacturing or recycling
and disposal of products containing PBDE flame retardants have greater exposure to the
chemical compared to the general population (Sjodin, Hagmar et al. 1999; Thomsen, Lundanes et
al. 2001; Thuresson, Hoglund et al. 2006).
Consumer exposure to decaBDE is possible given that it can be released from common home
products and become a component in house dust (Stapleton, Alaee et al. 2004; Takigamie,
Suzuki et al. 2008) (for a list of products where decaBDE may be used, refer to Section 2.2). It is
also possible that workers exposed to decaBDE may inadvertently carry particles containing the
chemical home with them. This may lead to exposure to family members through household dust
or direct contact, as has been proven with other hazardous chemicals such as pesticides and lead
(Thompson, Coronado et al. 2003; Minnesota Department of Health 2010). DecaBDE has been
found in dust within automobiles (Lagalante, Oswald et al. 2009) and automobile air
(Mandalakis, Stephanou et al. 2008). The primary route of consumer exposure to decaBDE is
through the ingestion of dust or, for infants, ingestion of breast milk, followed by food and water
ingestion and dermal absorption (Lorber 2008; Petito Boyce, Sax et al. 2009; U.S. EPA 2010a).
Inhalation may also be a relevant route of exposure (U.S. EPA 2010a). Children have higher
levels of exposure to decaBDE than do adults (Petito Boyce, Sax et al. 2009) likely due to higher
hand to mouth behavior.
Environmental Exposures
Environmental releases of decaBDE can occur during each stage of a product's life cycle,
including chemical manufacturing, product manufacturing, product storage and use, and end-of-
life handling (U.S. EPA 2009). In general, levels of PBDEs in humans and the environment are
higher in North America than in other regions of the world, likely due to their greater use in
North America (Trudel, Scheringer et al. 2011).
Empirical and predicted data indicate that all PBDEs (including decaBDE) are highly persistent
in the environment (Environment Canada 2006) and decaBDE has been found in high and
increasing concentrations in the sediment of lakes, rivers, streams and estuaries (Song, Li et al.
2005; Environment Canada 2006; Illinois Environmental Protection Agency 2006). Additionally,
decaBDE has also been measured in ambient atmospheric particulates (Illinois Environmental
5-5
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Protection Agency 2006) and in the Arctic environment, providing evidence that it is subject to
long-range transport (Environment Canada 2006).
Laboratory studies demonstrate decaBDE's bioavailability and metabolism in fish (Illinois
Environmental Protection Agency 2006). DecaBDE has been detected in some but not all species
of fish studied (Dodder, Strandberg et al. 2002; European Chemicals Bureau 2002; Johnson-
Restrepo, Kannan et al. 2005; Environment Canada 2009; Roberts, Noyest et al. 2011). Also,
decaBDE has been measured in birds and their eggs (Lindberg, Sellstrom et al. 2004; Vorkamp,
Thomsen et al. 2005) and in mammals including polar bears, seals, marmots and foxes
(Christensen, MacDuffee et al. 2005; Illinois Environmental Protection Agency 2006;
Voorspoels, Covaci et al. 2006; Environment Canada 2009). Further, terrestrial species tend to
have higher levels of decaBDE than aquatic species for both birds (Jaspers, Covaci et al. 2006)
and mammals (Christensen, MacDuffee et al. 2005). These observations indicate bioavailability
of decaBDE to wildlife and human food sources with potential for bioaccumulation and
biomagnification of decaBDE and/or its degradation products.
5.1.6 Physical-Chemical Properties for the Alternatives to DecaBDE included in this
Assessment that May Impact Exposure
Table 5-1 highlights key physical-chemical properties that affect the likelihood of exposure
along with the physical-chemical property's relevance to exposure. The properties included in
the table are: the physical state of the chemical, vapor pressure, water solubility, dispersibility,
log Kow, bioaccumulation potential, and persistence. Descriptions of these properties and how
they can be used to predict environmental behavior and hazard potential can be found in Section
4.3. More detailed information on the physical, chemical, and fate properties of each flame
retardant chemical can be found in the full chemical summary assessments in Section 4.8.
5-6
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Table 5-1: Key Physical/Chemical and Fate Properties of Flame Retardant Chemicals
Physical State of Chemical (ambient conditions)
Relevance to exposure: Indicates if a chemical substance is a solid, liquid, or gas under ambient conditions. This is determined from the melting and boiling points. Chemicals with a melting
point more than 25°C are considered solid. Those with a melting point less than 25°C and a boiling point more than 25°C are considered liquid and those with a boiling point less than 25°C are
considered a gas. Physical state influences potential for dermal and inhalation exposure. For chemicals that exist as a gas, there is generally a potential for direct inhalation but not dermal
exposure. For solids, there is potential for the inhalation and ingestion of dust particles and dermal contact. For liquids, there is potential for direct dermal contact but not for direct inhalation of
the liquid (except in operations that produce aerosols).
Decabromodiphenyl
Ether
Aluminum Diethyl-
phosphinate
Aluminum Hydroxide
Ammonium
Polyphosphate
Antimony Trioxide
Bis
(hexachlorocyclopenta
dieno) Cyclooctane
Bisphenol A bis-
(diphenylphosphate)
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Brominated Epoxy
Polymer(s)
Brominated Epoxy
Polymers
Mixture of Brominated
Epoxy Polymer(s) and
Bromobenzyl Acrylate
Brominated Epoxy
Resin End-Capped
with Tribromophenol
Brominated
Polyacrylate
Brominated
Poly(phenylether)
Brominated
Polystyrene
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Decabromodiphenyl
Ethane
Ethylene bis-
tetrabromo-
phthalimide
Magnesium Hydroxide
Melamine Cyanurate
Melamine
Polyphosphate
N-alkoxy Hindered
Amine Reaction
Products
Phosphonate Oligomer
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Phosphoric Acid,
mixed esters with [1,1'-
bisphenyl-4,4' -diol]
and phenol
Polyphosphonate
Poly[phosphonate-co-
carbonate]
Red Phosphorous
Resorcinol bis-
diphenylphosphate
Substituted Amine
Phosphate Mixture
Tetrabromobisphenol
A bis (2,3-
dibromopropyl ether)
Solid or Liquid1
Solid
Solid
Solid
Liquid
Solid
Solid
Triphenyl Phosphate
Tris
(tribromoneopentyl)
Phosphate
Tris (tribromo-
phenoxy)
Triazine
Zinc Borate
Solid
Solid
Solid
Solid
1 Depends on the oligomer distribution
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Vapor Pressure (mm Hg) at 25°C (unless otherwise noted)
Relevance to exposure: Indicates the potential for a chemical to volatilize into the atmosphere. If a chemical has a vapor pressure leading to volatilization at room temperature or typical
environmental conditions, then the chemical may evaporate and present the potential for inhalation of the gas or vapor. For a Design for the Environment (DfE) chemical alternatives
assessment, inhalation exposure is assumed to occur if the vapor pressure is greater than 1 x 10"8 mm Hg. A default value of <10"8 was assigned for chemicals without data that are anticipated to
be non-volatile this is based on EPA HPV assessment guidance (U.S. EPA 201 lb).
Decabromodiphenyl
Ether
Aluminum Diethyl
phosphinate
Aluminum Hydroxide
Ammonium
Polyphosphate
Antimony Trioxide
Bis
(hexachlorocyclopenta
dieno) Cyclooctane
Bisphenol A bis-
(diphenylphosphate)
3.5xlO"sat21°C
<10"8d
<10"8c
<10"8b
<10"8
<10"8c
<9xl0"°a
Brominated Epoxy
Polymer(s)
Brominated Epoxy
Polymers
Mixture of Brominated
Epoxy Polymer(s) and
Bromobenzyl Acrylate
Brominated Epoxy
Resin End-Capped
with Tribromophenol
Brominated
Polyacrylate
Brominated
Poly(phenylether)
Brominated
Polystyrene
<10"8b
at 20°C
<10"8c
<10"8d
Triphenyl Phosphate
Tris (tribromoneo-
pentyl) Phosphate
Tris (tribromo-
phenoxy) Triaz ine
Zinc Borate
6.28xl0"°a
<10"8d
<10"8d
<10"8b
a Extrapolated. b Estimated based on polymer assessment literature (Boethling et al., 1997).c Estimated based on HPV guidance for nonvolatile compounds. d Estimated.
5-8
-------
Water Solubility (mg/L)
Relevance to exposure: Indicates the potential of a chemical to dissolve in water and form an aqueous solution. Water soluble chemicals present a higher potential for human exposure through
the ingestion of contaminated drinking water (including well water). In general, absorption after oral ingestion of a chemical with a water solubility less than 10"3 mg/L is not expected. Water
soluble chemicals are more likely to be transported into groundwater, absorbed through the gastrointestinal tract or lungs, partition to aquatic compartments, and undergo atmospheric removal
by rain washout. A water solubility of 10"3 mg/L is used for large, high molecular weight non-ionic polymers according to the literature concerning polymer assessment (Boethling et al., 1997).
A substance with water solubility at or below 10"3 mg/L is considered insoluble.
Decabromodiphenyl
Ether
Aluminum Diethyl
phosphinate
Aluminum Hydroxide
Ammonium
Polyphosphate
Antimony Trioxide
Bis
(hexachlorocyclopenta
dieno) Cyclooctane
Bisphenol A bis-
(diphenylphosphate)
2)b
Phosphoric Acid,
mixed esters with [1,1'-
bisphenyl-4,4' -diol]
and phenol
Polyphosphonate
Poly [phosphonate-co-
carbonate]
Red Phosphorous
Resorcinol bis-
diphenylphosphate
Substituted Amine
Phosphate Mixture
Tetrabromobisphenol
A bis (2,3-
dibromopropyl ether)
<0.01
<10"3b
<10"3c
<10"3a
1.05 at 20°C
>lxl06b
<10"3b
Triphenyl Phosphate
Tris (tribromoneo-
pentyl) Phosphate
Tris (tribromo-
phenoxy)T riazine
Zinc Borate
1.9
0.9
<10"3
0.28%*
*The water solubility of zinc borate is expressed as a percentage and is <0.28% at neutral pH. Its dissolution is pH dependent and will vary within the range 5-7 that is typically found in the
environment. Good water solubility data for zinc borate are not available.
a Estimated based on EPA High Production Volume assessment guidance. b Estimated.c Estimated based on polymer assessment literature (Boethling et al., 1997).
5-9
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Log K„w
Relevance to exposure: Indicates a chemical's tendency to partition between water and lipids in biological organisms. A high log Kow value indicates that the chemical is more soluble in
octanol (lipophilic) than in water, while a low log Kow value means that the chemical is more soluble in water than in octanol. Log Kow can be used to evaluate absorption and distribution in
biological organisms, potential aquatic exposure, and potential general population exposure via ingestion. Generally, chemicals with a log Kow <4 are water soluble and bioavailable, chemicals
with a log Kow >4 tend to bioaccumulate. Chemicals with a high log Kow also tend to bind strongly to soil and sediment. Log Kow cannot be measured for inorganic substances, polymers, and
other materials that are not soluble in either water or octanol. This is indicated in the table with "No data".
Decabromodiphenyl
Ether
Aluminum Diethyl
phosphinate
Aluminum Hydroxide
Ammonium
Polyphosphate
Antimony Trioxide
Bis
(hexachlorocyclopenta
dieno) Cyclooctane
Bisphenol A bis-
(diphenylphosphate)
6.27
-0.44a
No data
No data
No data
lla
>10a
Brominated Epoxy
Polymer(s)
Brominated Epoxy
Polymers
Mixture of Brominated
Epoxy Polymer(s) and
Bromobenzyl Acrylate
Brominated Epoxy
Resin End-Capped
with Tribromophenol
Brominated
Polyacrylate
Brominated
Poly(phenylether)
Brominated
Polystyrene
No data
No data
No data
No data
No data
>9
No data
Decabromodiphenyl
Ethane
Ethylene bis-
tetrabromophthalimid
e
Magnesium Hydroxide
Melamine Cyanurate
Melamine
Polyphosphate
N-alkoxy Hindered
Amine Reaction
Products
Phosphonate Oligomer
14a
9.8a
No data
<0a
<-T
10
7.2 (n=l)a;
11 (n=2 )a
Phosphoric Acid,
mixed esters with [1,1'-
bisphenyl-4,4' -diol]
and phenol
Polyphosphonate
Poly[phosphonate-co-
carbonate]
Red Phosphorous
Resorcinol bis-
diphenylphosphate
Substituted Amine
Phosphate Mixture
Tetrabromobisphenol
A bis (2,3-
dibromopropyl ether)
5.5
No data
No data
No data
4.93
<-T
12a
Triphenyl Phosphate
Tris (tribromoneo-
pentyl) Phosphate
Tris (tribromo-
phenoxy)T riazine
Zinc Borate
4.59
8.1a
>10
No data
a Estimated data.
5-10
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Bioaccumulation Potential
Relevance to exposure: Indicates the degree to which a chemical substance may increase in concentration within a trophic level. Bioconcentration describes the increase in tissue concentration
relative to the water concentrations (environmental sources); bioaccumulation generally includes dietary and environmental sources. As chemicals bioconcentrate or bioaccumulate, there is a
higher potential for them to reach a level where a toxic effect may be expressed. Estimated and/or measured bioconcentration and bioaccumulation values are presented as ranges based on
relevant DfE hazard categories for each chemical. The DfE criteria for bioaccumulation designations are assigned by the bioaccumulation factor (BAF) or log BAF Hie designations for
bioaccumulation potential are as follows: Very High (VH) if the BAF (log BAF) is >5,000 ( >3.7); High (H) if the BAF is between 5,000 (3.7-3) and 1,000; Moderate (M) if the BAF is
between <1,000 and 100 (<3-2); and Low (L)'if the BAF is <100 ( <2) (U.S. EPA 201 la).
Decabromodiphenyl
Ether
Aluminum Diethyl
phosphinate
Aluminum
Hydroxide
Ammonium
Polyphosphate
Antimony Trioxide
Bis
(hexachlorocyclopenta
dieno) Cyclooctane
Bisphenol A bis-
(diphenylphosphate)
High
(1,000-5,000)b
Low
(<100)a
Low
(<100)a
Low
(<100)a
Low
(<100)a
High
(1,000-5,000 )b
High
(1,000-5,000 )b
Brominate Epoxy
Polymer(s)
Brominated Epoxy
Polymers
Mixture of
Brominated Epoxy
Polymer(s) and
Bromobenzyl
Acrylate
Brominated Epoxy
Resin End-Capped
with Tribromophenol
Brominated
Polyacrylate
Brominated
Poly(phenylether)
Brominated
Polystyrene
Low
(<100)c
Low
(<100)c
Low
(<100)c
Low
(<100)b
Low
(<100)c
Moderate
(
-------
Persistence
Relevance to exposure: Indicates the length of time required for a chemical substance to be completely converted to small building blocks including water, carbon dioxide, and ammonia
("ultimate degradation"). Persistence is typically expressed as a 'half-life', which is the time for the amount of the substance to be reduced by one half. For a DfE chemical alternatives
assessment, persistent chemicals include those that have metabolic or degradation products that have long half-lives. The longer a chemical or its degradation/metabolism products exist in the
environment, the higher the likelihood for human or environmental exposure. "Compartments" refer to those environmental media to which chemicals may partition and include soil, sediment,
water and air as standard compartments for fate assessment. Persistence is considered Very High (VH) if the half-life is >180 days or recalcitrant; High (H) if the half-life is 60-180 days;
Moderate (M) if the half-life is <60 days but >16 days; Low (L) if half-life is <16 days OR readily passes biodegradability test not including the 10- day window (see DfE Program Alternatives
Assessment Criteria for Hazard Evaluation); and Very Low (VL) if passes biodegradability test with 10-day window (see DfE Program Alternatives Assessment Criteria for Hazard
Evaluation).
Decabromodiphenyl
Ether
Aluminum Diethyl
phosphinate
Aluminum
Hydroxide
Ammonium
Polyphosphate
Antimony Trioxide
Bis
(hexachlorocyclopenta
dieno) Cyclooctane
Bisphenol A bis-
(diphenylphosphate)
Very High
(>180 days)
High
(60-180 days)b
High
(60-180 days)b
Very High
(>180 days)c
High
(60-180 days)b
Very High
(>180 days)
High
(60-180 days)
Brominate Epoxy
Polymer(s)
Brominated Epoxy
Polymers
Mixture of
Brominated Epoxy
Polymer(s) and
Bromobenzyl
Acrylate
Brominated Epoxy
Resin End-Capped
with Tribromophenol
Brominated
Polyacrylate
Brominated
Poly(phenylether)
Brominated
Polystyrene
Very High
(>180 days)c
Very High
(>180 days)c
Very High
(>180 days)c
Very High
(>180 days)c
Very High
(>180 days)c
Very High
(>180 days)c
Very High (>180 days)c
Decabromodiphenyl
Ethane
Ethylene bis-
tetrabromophthalimide
Magnesium
Hydroxide
Melamine Cyanurate
Melamine
Polyphosphate
N-alkoxy Hindered
Amine Reaction
Products
Phosphonate Oligomer
Very High
(>180 days)
Very High
(>180 days)
High
(60 - 180 days)b
Very High
(>180 days)
High
(60-180 days)b
High
(60-180 days)
Very High
(>180 days)3
Phosphoric Acid,
mixed esters with [1,1'-
bisphenyl-4,4' -diol]
and phenol
Polyphosphonate
Poly[phosphonate-co-
carbonate]
Red Phosphorous
Resorcinol bis-
diphenylphosphate
Substituted Amine
Phosphate Mixture
Tetrabromobisphenol
A bis (2,3-
dibromopropyl ether)
High b
Very High
(>180 days)3
Very High
(>180 days)3
High
(60-180 days)
Moderate
(60 - 16 days)
High
(60 - 180 days)b
Very High
(>180 days)
Triphenyl Phosphate
Tris (tribromoneo-
pentyl) Phosphate
Tris (tribromo-
phenoxy) Triaz ine
Zinc Borate
Low
(<16 days)
High
(60-180 days)3
Very High
(>180 days)
High
(60-180 days)b
3 Based on results from biodegradation estimation model. b Based on professional judgment. c Estimated based on polymer assessment literature (Boethling et al., 1997).
5-12
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5.2 Extraction
This section describes the first step in manufacturing a flame retardant, extracting or synthesizing
the basic components which make up the final chemical. As stated in Chapter 3, there are four
main categories of flame retardants: inorganic (i.e., metal salts), halogenated (bromine or
chlorine), phosphorous-based, or nitrogen-based. Descriptions by category are given below
demonstrating how the basic elements of each of the flame retardants for this assessment are
extracted, and some exposure considerations associated with extraction are also included. This
report is not evaluating the synthesis and processing of each of these materials but is providing
information on the primary source of each of their components. In general, the organic flame
retardants are derived from petroleum and the inorganic flame retardants are derived from other
naturally occurring mineral deposits.
5.2.1 Inorganic Flame Retardants
The inorganic flame retardants considered in this report include the following base elements:
Aluminum
Aluminum, used in aluminum hydroxide (Al(OH)3), is one of the most plentiful elements in the
earth's crust and is usually present as bauxite ore. Bauxite can contain three different aluminum
minerals, including gibbsite (Al(OH)3), bohmite, and diaspore (crystalline structures of
AIO(OH)). Bauxite ore also typically contains clay, silt, iron oxides, and iron hydroxides. The
majority of bauxite is mined from surface deposits, but some is excavated from underground
deposits (International Aluminium Institute 2007). Nearly all of the bauxite consumed in the
United States is imported (USGS 2007). By refining bauxite ore using the Bayer process
aluminum hydroxide can be made (U.S. EPA 1995b). This process requires mixing finely ground
bauxite with sodium hydroxide to form a slurry that is then placed under steam pressure and heat
(U.S. EPA 1995a). This creates a mixture of dissolved aluminum oxides and bauxite residues
and precipitates out most of the impurities. The remaining slurry contains sodium aluminate that
is flash cooled by evaporation and clarified to remove any other fine impurities (U.S. EPA
1995a). Lastly, the solution is sent to a precipitation tank where it is cooled and gibbsite "seeds"
(usually from a previous cycle) are added to promote the precipitation of solid aluminum
hydroxide crystals (U.S. EPA 1995a).
Magnesium
The mineral form of magnesium hydroxide (Mg(OH)2), also called brucite, is found throughout
the world (Amethyst Galleries Inc 2008; USGS 2008). However, magnesium hydroxide is
typically recovered from seawater and magnesia-bearing brines, which constitutes an even
greater and more readily available resource than brucite. In 2007, magnesium oxide and other
magnesia compounds (including magnesium hydroxide) were recovered from both seawater and
well brines in the U.S. (USGS 2008).
5-13
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Antimony
Antimony (Sb), used in antimony trioxide (Sb2C>3), can be mined, recovered as a byproduct from
the smelting of lead and silver-copper ores, or derived from scrap source materials, including
lead-acid batteries (Carlin Undated). Six U.S. companies produce antimony metal and oxide
using domestic and foreign feed material (Carlin Undated). However, recycling and domestic
mine output supplied less than half of the estimated U.S. demand for antimony, meaning a
significant amount of antimony in the U.S. is imported (Carlin Undated). Antimony is mined as a
principal product and recovered as a byproduct of the smelting of base metal ores in 23
countries. China, Bolivia, Russia and South Africa account for more than 90 percent of mine
production (Carlin Undated). More than 50 percent of available antimony is used in flame
retardants (Carlin Undated).
Zinc
Zinc most often occurs in association with the sulfide mineral group as sphalerite (ZnS), which is
the principal mineral mined to recover zinc. Other metals associated with sulfide ores include
copper, iron, mercury, cadmium, silver and small quantities of gold (U.S. EPA 1994). These
metals occur in varying amounts, and depend on the nature of the ore. Zinc ore is recovered from
three types of deposits: strata-bound deposits, replacement deposits and vein deposits (U.S. EPA
1994). The largest and most productive deposits are associated with expansive, relatively flat
lying sedimentary deposits. The strata-bound zinc ore in these deposits are restricted to well-
defined stratigraphic units (a distinct layer of sedimentary or igneous rock), typically limestone,
dolomite, or shale (U.S. EPA 1994). Replacement and vein type deposits make up a smaller
portion of mined zinc. For the most part, zinc is mined in underground operations, although there
are a few surface operations (U.S. EPA 1994).
5.2.2 Halogenated Flame Retardants
Bromine
Bromine is collected from salt brines in the United States and China, from the Dead Sea in Israel
and Jordan, and from ocean water in Wales and Japan (Sjodin, Hagmar et al. 1999; Thuresson,
Bergman et al. 2006; Bromine Science and Environmental Forum 2007; Qu, Bi et al. 2007).
Bromine is typically isolated via a series of redox reactions involving chlorine, sulfur dioxide
and acid (MIT 2003; The University of York). During these reactions the brine or seawater is
acidified and then chlorinated to oxidize bromide to elemental bromine. At this stage, the
bromine is volatilized from the seawater, but it is not concentrated enough for collection or
liquefying, so sulfur dioxide is added to reduce the bromine to hydrobromic acid. Chlorine is
then added to re-oxidize hydrobromic acid to bromine gas (Br2). At this point, bromine gas is
collected and condensed (Grebe, Bauman et al. 1942). While caustic substances are involved in
these processes, they are typically contained in an enclosed tower to prevent worker exposure
and environmental release.
5-14
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Chlorine
Chlorine, one of the most abundant elements on earth (Kostick 2001), is found primarily as the
chloride ion (CI"), which is a component of salt found deposited in the earth or dissolved in the
oceans. Chlorine is produced industrially via the chloralkali process, which involves the
electrolysis of an aqueous sodium chloride (a brine) through an ion exchanging membrane (ERG
2006). Chloride ions are oxidized at an anode on the membrane into chloride. In addition to
chlorine, this chloralkali process yields hydrogen gas (H2) and sodium hydroxide (NaOH). The
chloralkali process accounts for more than 95 percent of global chlorine production (ERG 2006).
5.2.3 Phosphorous-Based Flame Retardants
Phosphorus-based flame retardants are commonly synthesized from phosphate rock, which
contains the mineral apatite (an impure tri-calcium phosphate). Phosphate esters can also be
derived from yellow phosphorus. Large deposits of phosphate rock are found in Russia,
Morocco, Florida, Tennessee, Utah, and Idaho (Lide 1993/94). Tri-calcium phosphate, the
essential component of phosphate rock, is heated in the presence of carbon and silica in an
electric furnace or fuel-fired furnace. Elementary phosphorus is liberated as vapor and may be
collected underwater (Lide 1993/94). While elementary phosphorus can form a diatomic
molecule with a triple bond, it more readily forms a tetrahedral P4 molecule. At room
temperature, phosphorus can exist in an amorphous or semi-crystalline state, called red
phosphorus, which is produced from white phosphorus by extended heating in an inert
atmosphere (Calvert 2004).
As for yellow phosphorous, approximately 80 percent of the global phosphorus is mined in
China in the form of phosphate ore (Shigeru 2007). Extracting yellow phosphorus from
phosphate ore also involves the co-extraction of arsenic, mercury, lead and other heavy metals as
impurities that should be well controlled and treated before disposal of wastewater. If producers
of yellow phosphorus appropriately treat their wastewater, then environmental releases and
human exposures can be prevented. However, improperly treated wastewater can lead to major
adverse environmental impacts (Shigeru 2007).
Predictions suggest that the world may be approaching 'peak phosphorous', or the point in time
when the maximum production rate is reached. Phosphate-rich rocks are becoming harder to find
and the demand for rock phosphate will soon exceed supply (Ulrich, Malley et al. 2009;
Beardsley 2011). Depending on the calculation, predictions of peak phosphorous are broad
(between twenty and several hundred years away), with some researchers predicting that peak
extraction could occur as early as 2030 (Ulrich, Malley et al. 2009). This could have serious
economic consequences in that it could raise the cost of products which use phosphorous (Ulrich,
Malley et al. 2009) such as fertilizer or phosphorous-based flame retardants. It is suggested that
there are ways to manage and mitigate peak phosphorous given that there is "an abundant but
often ignored source of phosphorous" in human and animal waste (Beardsley 2011) but
technology to extract and use phosphorous from these sources is still in its infancy (Ulrich,
Malley et al. 2009).
5-15
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5.2.4 Nitrogen-Based Flame Retardants
Nitrogen is the largest constituent of the earth's atmosphere and is also present in all living
organisms, proteins, and nucleic acids (Kramer 2000). Anhydrous ammonia is produced
commercially through the Haber-Bosch process, in which nitrogen and hydrogen react under
high temperatures and pressure to produce ammonia (Kramer 2000). In this reaction, the source
of nitrogen is air, which is almost 80 percent nitrogen. Additionally, small quantities of nitrates
are mined from mineral resources principally in Bolivia and Chile (Kramer 2000). Although the
U.S. produces most of its ammonia, the U.S. does import some ammonia mainly from Canada,
Russia, and Trinidad and Tobago.
5.3 Chemical Manufacturing
After the extraction or synthesis of the flame retardant's basic components, the flame retardant
chemical itself can be manufactured. Unit operations, operating conditions, transfer procedures,
and packaging operations vary with the manufacture of different flame retardants and resin
chemicals. Potential releases and occupational exposures will depend on each of these
parameters. While it is outside the scope of this report to identify and quantify the releases and
exposures associated with individual chemicals, this section presents a general description of
typical chemical manufacturing processes and identifies potential releases.
Figure 5-2 is a generic process flow diagram for chemical manufacturing. Production volumes
and batch sizes associated with flame retardants typically require the raw materials to be stored
in large tanks or drums until use. The first step in most chemical manufacturing processes is to
load or charge raw materials into some type of reactor or mix tank. Production volumes and
batch sizes associated with flame retardant chemicals typically require the raw materials to be
stored in large tanks or drums until use. Large-quantity liquids are typically pumped into the
reactor, and solids are weighed and transferred via conveyorized, mechanical systems. Small-
quantity raw materials may be manually introduced or carefully metered via automated systems.
Releases and exposures that are expected from these operations are associated with the raw
materials, not the finished flame retardant product (U.S. EPA 2005).
Throughout the chemical manufacturing process, there are several release points that may pose
an opportunity for exposures to workers (see Figure 5-2) including packaging operations, leaks
from pumps and tanks, fugitive emissions from equipment, cleaning of process equipment, and
product sampling activities. Additionally, crude or finished products are often stored on-site in
drums, day-tanks, or more permanent storage vessels until the chemical is packaged and shipped
to the next user. The transfer and packaging operations, waste management activities, as well as
any routine and unplanned maintenance activities, and spills or accidents may result in releases
and exposures.
5-16
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Figure 5-2: Generic Chemical Manufacturing Process Flow Diagram
Raw Materials
Fugitive Air Emission
i
s
Fugitive
Air
Emission
~
Samples1
Fugitive Dust
Emissions
Separation
(Distillation
Column or
Filtration Unit)
Drying Operations
(e.g., drying oven
or spray dryer}
Sample
Equipment*
Fugitive Air
Emission
a
Temporary
Storage and
Filling Operations*
v Spent Filters
Separation Waste
and Filtrate
"Occupational Exposure Expected
Air Releases
~
Liquid Releases
^ Solid Releases
Miscellaneous:
•Equipment
Cleaning
•Area Washdowns
Source: U.S. EPA 2005
5-17
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Crude or intermediate products may be transferred through a series of reactors, distillation
columns, filtration systems, drying ovens, spray dryers, and other unit operations. These
processes typically occur in closed systems, with engineering controls that serve both to regulate
operating parameters such as temperature and pressure as well as to minimize fugitive releases.
However, there is potential for a variety of solid and liquid releases from these operations, from
cleaning process equipment and from sampling activity. Additionally, crude or finished products
may be stored on-site in drums, day-tanks, or more permanent storage vessels until the flame
retardant formulation is packaged and shipped to customers (e.g., foam and textile
manufacturers). The transfer and packaging operations, including storage, are expected to result
in releases of the flame retardant chemicals. Finally, miscellaneous operations, such as routine
and unplanned maintenance or waste management activities, can result in considerable releases
and exposures (U.S. EPA 2005).
After the flame retardant is manufactured, it may need to be formulated into a solution, slurry, or
mixture prior to its introduction into the commercial flame retardant formulation. For example,
fine powders of a chemical may be formulated into an agglomerated powder or into a solution.
The formulation steps usually occur at the chemical manufacturing facility, but additional mixing
steps can occur at the formulator's manufacturing plant.
Release points from manufacturing and formulating can include: transfer and packaging
operations involving handling a chemical product; routine and unplanned maintenance activities;
leaks from pumps and pipelines; fugitive emissions from equipment; product sampling; waste
management; and cleaning of equipment for transport and storage vessels.
5.4 Product Manufacturing
Given that decaBDE and its alternatives are used in a wide variety of products (see Chapter 2),
this assessment does not include a discussion of the manufacturing process for each end-use
product. However, a general discussion of how flame retardants are incorporated into plastics
and textiles is included below in an attempt to understand where along the manufacturing process
human or environmental exposures may occur. The production of flame retardants and their
incorporation into a product is a complex process which involves multiple companies and
specialties (European Chemicals Bureau 2002). With this in mind, the description of product
manufacturing provided in this report is a generic one that understands that exposure is likely to
vary at different facilities. Figure 5-3 displays the various steps flame retardants go through
before they are incorporated into a final product for sale. The left side of the figure depicts the
textile manufacturing process whereas the right side of the figure depicts the plastic
manufacturing process (the plastic is subsequently used to make equipment such as televisions or
computers). Supply chains may be more intricate for complex durable goods if materials or parts
containing decaBDE are used to build subcomponents that are later aggregated into the final
product. This type of assembly may also be considered when choosing chemical alternatives in
complex finished goods.
5-18
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Depending on the processes and equipment used, exposure can occur at each stage of the
manufacturing process. For non-textile based polymers (the right half of Figure 5-3) exposure
can occur anywhere along the process such as during compounding14 or masterbatch15
production and these processes may or may not be carried out in the same facility. The type of
polymer being manufactured does not affect release volumes; release is dependent on the type of
system used (i.e., closed or open) and the amount of flame retardant used (European Chemicals
Bureau 2002).
Exposure potential is highest during the handling of the raw flame retardant (European
Chemicals Bureau 2002). For decaBDE, any losses during this stage will be to the air but it is
expected that the dust will rapidly settle within the facility. Therefore, exposure may occur
dermally or through inhalation. To understand the fate and potential exposure routes of the other
alternatives, an understanding of their physical-chemical properties is essential (see Table 5-1).
Additionally, compounding is prone to dust generation but losses are thought to be lower than
the handling of the flame retardant itself. It is possible that losses may occur early in the mixing
cycle and that localized containment may be used to recover the material (European Chemicals
Bureau 2002). There may be releases to the air and to the atmosphere at this stage of the
manufacturing process.
Textile manufacturing (the left half of Figure 5-3) is a complex process which involves fiber
preparation, spinning, knitting, weaving, and dyeing among many other steps, all of which occur
in the finishing or upholstery manufacturing steps. The addition of additive flame retardants in
textiles occurs in the final stage of wet processing, which occurs before the product is cut and
sewn. According to the International Agency for Research on Cancer (IARC), "textile workers
are exposed to textile related dusts through the manufacturing process. During the spinning,
14 Blending of the polymer with various additives
15 Plastic compounds that contain high concentrations of additives which are subsequently mixed in the main
polymer matrix.
5-19
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weaving and knitting operations, exposure to chemicals is generally limited." During the
finishing processes when flame retardant chemicals are applied, IARC states that workers
typically have exposures to multiple chemicals, including crease-resistance agents, antimicrobial
agents, and flame retardants (IARC 1990).
When incorporating flame retardants into textiles, surface treatment is often used. There are two
types of surface treatments: finishes and coatings. Finishes are applied by impregnating the
fabrics in an aqueous solution of the chemical. Coatings are applied by incorporating a layer of
flame retardant to the fabric, generating a heterogeneous fabric/polymer composite. Flame
retardants used for finishes include phosphates and polyphosphates, phosphorous amides,
phosphonium derivatives, antimony trioxide, borax and boric acid or halogenated flame
retardants. Flame retardants used for coatings include phosphates, phosphonates, and brominated
derivatives, which may be applied as backcoatings in the form of a paste or foam (GnoSys UK
LtD for the Department of Environment Food and Rural Affairs 2010). As of 2008, the leading
flame retardant in backcoating on a wide range of fabrics including synthetic blends, is
decaBDE, used with antimony oxide. New chemicals in development for textile coatings are
polymers and copolymers of pentabromobenzyl acrylate (CAS Number: 59447-55-1).
Additionally, insoluble ammonium phosphates have also been found to work well on charrable
fabrics (Weil and Levchik 2008).
Flame retardants in textiles are classified according to their "laundry durability." A non-durable
flame retardant is washed off immediately when soaked in water, but may resist dry cleaning.
Semi-durable flame retardants resist water soaking and possibly a few washes, while durable
flame retardants resist 50 to 100 washes (Weil and Levchik 2008). Washing of flame retarded
fabric could result in releases to waste water treatment plants and eventually to the environment.
Flame retardants based mostly on phosphate or phosphonate salts are typically used on
infrequently washed or disposable goods given that they are non- or semi-durable. In regards to
durable finishes, tetrakis(hydroxymethyl)phosphonium salts reacted with urea and cured with
gaseous ammonia have been used for about 50 years in cellulosic fabrics. Other competitive
wash-durable phosphorus-based finishes are also in development. Furthermore, polyesters are
flame retarded with phosphonate or hexabromocyclododecane in a "thermosol16" process (Weil
and Levchik 2008).
5.5 Use
As discussed in Chapter 2, decaBDE and its alternatives are used in a wide variety of polymers
and products, allowing for potential release into a home, office or vehicle. Given that all of the
flame retardants in this assessment are additive (as opposed to reacted into the polymer matrix),
the potential for the flame retardant chemical to migrate or be released from a product is present.
As discussed in Section 3.1, additive flame retardants are incorporated into the product through
physical mixing and are not chemically reacted into the polymer. Empirical data on decaBDE
16 The thermosol process is the process of incorporating flame retardants into synthetic fibers. To run this process, liquid flame
retardants are dissolved or dispersed in water (emulsion). Freshly spun hot fiber passes through this solution and the flame
retardant penetrates the surface of the fiber because its affinity to the polymer is higher than to water. When the fiber cools down
the flame retardant stays close to the surface.
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and other PBDEs in house dust demonstrate that additive flame retardants are being released
from products into the surrounding environment (Stapleton, Dodder et al. 2004). However, it is
difficult to identify or quantify the primary sources of the additive flame retardants, given
consumer products are not labeled or identified by specific treatments with flame retardant
additives.
There are peer reviewed studies about PBDE and decaBDE exposures. For example, Trudel,
17
Scherinder et al. (2011) found that the body burden of PBDE mixtures is generally higher in
the United States and Canada than in other countries, likely due to the more stringent fire safety
performance standards in North America and the greater number of consumer products
containing these flame retardants. Again using PBDEs as an example, it has been shown that in
the U.S., a primary exposure pathway for PBDEs among consumers is inhalation or ingestion of
house dust (Johnson, Stapleton et al. 2010). In contrast, the diet constitutes a primary exposure
pathway for consumers in Europe, China, and many other countries worldwide (Trudel,
Scheringer et al. 2011). PBDE's have a tendency to bioaccumulate in the food chain, particularly
in fatty tissues of animals. Consequently, meat and dairy products have higher concentrations of
PBDEs than fruit and vegetables (Schecter, Haffner et al. 2010). Additionally, a large number of
human samples have been analyzed and PBDE concentrations have increased by nearly a factor
of 100 during the last 30 years (U.S. EPA 2009). The bioaccumulation potential of the other
alternatives in this assessment is addressed in the Chapter 4 in each chemical's hazard profile.
Exposure levels and routes also vary by age group. Given children's predisposition to put hands
and toys in their mouth, they can inadvertently ingest larger amounts of house dust than adults.
Some children may be at a higher risk of exposure if family members work with PBDEs and
bring dust containing the chemical home with them (Washington State Department of Labor &
Industries Undated). The Agency for Toxic Substances and Disease Registry (2004) and the
Child-Specific Exposure Factors Handbook (2008) both state that a child's exposure may differ
from that of adults because children drink more fluids, eat more food, breathe more air per
kilogram of body weight, and have a larger skin surface area in proportion to body volume.
Additionally, it is possible for infants to be exposed to bioaccumulative chemicals through breast
milk.
In addition to considering consumer exposures to a specific flame retardant, it is important to
consider degradation products. For example, under certain conditions, decaBDE can degrade to
less brominated congeners, which are potentially more toxic. Photolysis is expected to be the
primary degradation process for decaBDE when it is significantly exposed to UV light (U.S.
EPA 2009). DecaBDE can undergo photolytic debromination in house dust (Stapleton and
Dodder 2008) and in organic films exposed to sunlight through automobile windshields (Ecology
Center 2008), demonstrating that debromination may be possible within an automobile.
Metabolic debromination of decaBDE can occur in fish, birds, cows, and rats, although its
overall significance when compared with other degradation processes is unclear (U.S. EPA
2009). Uncertainty exists for the degradation products of some decaBDE alternatives.
Debromination and other degradation processes may be relevant for some of the alternatives.
Chapter 4 of this report provides a summary of the chemical-specific information available at the
time of publication.
17 Body burden refers to the amount of a toxic substance present in the human body at a given time.
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5.6
End-of-Life
When products reach their end-of-life, there are multiple pathways which they could take,
including unregulated and/or regulated recycling (including reuse and refurbishment),
landfilling, or incineration. The manner in which a product is handled after use contributes to its
environmental and human health impacts. The following sections consider end-of-life issues for
some of the types of products requiring flame retardants. Note that there may be overlap in the
information presented for each product sector.
5.6.1 Electronics
The amount of used and end-of-life electronic equipment generated annually in the United States
is growing rapidly. In 2010, the U.S. electronics recycling industry processed over 3.5 million
tons of used and end-of-life electronic equipment (a large increase compared to the 650,000 tons
processed in 2002) (Institute of Scrap Recycling Industries Inc 2011), whereas 3.2 million tons,
predominately from households, is still sent to landfills (U.S. EPA 2010b). However, the amount
being sent to landfills is likely to decline as there is a growing trend of state laws that requires
the recycling of used and end-of-life electronics equipment (U.S. EPA 2010b).
Recycling Electronics
The U.S. electronics recycling industry has grown over the past ten years and has the capacity to
handle additional tonnage. The biggest challenge is the need to educate households, businesses
and government entities on the importance of responsibly recycling their used electronics
equipment (Harris 2011; Institute of Scrap Recycling Industries Inc 2011).
The U.S. electronics recycling industry has seen a significant increase in the use of third-party
certifications for electronic waste management and recycling (Harris 2011; Institute of Scrap
Recycling Industries Inc 2011). Electronics recyclers may be certified to the Responsible
Recycling Practices for Use in Accredited Certification Programs for Electronics Recyclers -
better known as the "R2 Practices", (or simply "R2") or the e-Stewards Standardfor Responsible
Recycling and Reuse of Electronic Equipment®, (as known as "the e-Stewards Standard").18. The
e-Stewards Standard is another certification program by which electronics recyclers may be
certified. The certification process helps to ensure that electronics recyclers use the best available
practices to protect worker health by minimizing exposure.
In the United States, used and end-of-life electronic equipment is typically collected by the
recycling industry (i.e., collectors, repair/refurbishers, recyclers, and brokers). The collected
equipment then undergoes a series of tests, or is "triaged", to determine its condition and market
value, if any. If a device or component's key functions are in good working condition it can be
resold directly as a used product or refurbished (e.g., updated operating systems or cosmetic
changes) and then sold as a product on the domestic and global marketplace.
18 Information about electronics recycling facilities certified to the R2 Practices is available from R2 Solutions at
www.R2Solutions.org. For more information about electronics recycling facilities certified to the e-Stewards
Standard, go to www.e-stewards.org.
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After the triage process, the remaining equipment is disassembled, either manually or
mechanically, and segregated into commodity grade streams (e.g., steel, aluminum, plastic, glass,
circuit boards that include copper, gold, silver, platinum, palladium, and rare earth oxides) that
are then sold into the domestic and international commodities market. Many of the markets for
processed raw materials are also outside of the U.S. and the manner in which used electronics are
disposed of or recycled will affect the potential environmental and human health impacts.
Figure 5-4 is a depiction of the general electronic recycling process and shows that this process
can involve both thermal processing, such as smelting to recover precious metals, and
nonthermal processing, such as disassembly, shredding, separation, and chemical treatment
(Kang and Schoenung 2005). The potential level of exposure to workers and the general
population that results from these processes will vary depending on the management practices
used within a facility.
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Figure 5-4: Electronics Recycling Process
Source: Adapted from Kang and Schoenung 2005
The potential for emissions of halogenated dioxins and furans, mercury, lead, antimony, and
other toxic substances exists with smelting operations that may be a part of the recycling process.
In addition to the potential emission of toxic chemicals, high operating temperatures may create
an occupational hazard and high loads of bromine or chlorine may induce corrosion of gas-
cleaning equipment. In sensitive areas, a process step for halide recovery may need to be added
(Lehrner 2008). Controlled smelting operations are able to handle high loads of halogenated
electronic scrap and effectively control emissions.
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Some post-use electronics are exported for reuse, refurbishment and recycling. Unfortunately, a
number of these exported electronics end up in countries that do not have the technology to
recycle the electronics in a way that does not pose exposure concerns. In the absence of proper
practices, procedures and equipment, unregulated recycling processes may pose risks to workers
and the public through exposure to toxic chemicals.
Additionally, a 2007 U.S. EPA study examined the waste management of computer, television,
hard-copy devices, and cellular devices. The study indicated that 15 to 20 percent of post-use
consumer electronics was recycled, and 80 to 85 percent was disposed of in landfills or through
incineration (U.S. EPA 2007b).
The methods employed at unregulated recycling sites are sometimes crude and may include the
open burning of printed circuit boards, cables, and plastics; acid or cyanide leaching of circuit
boards; and gold recovery with cyanide salt leaching or nitric acid and mercury amalgamation
(Williams, Kahhat et al. 2008; Sepulveda, Schluep et al. 2010; Yu, Williams et al. 2010). These
methods may pose concern for human and environmental health. Toxic substances released from
these processes include leachates, particulate matter, fly and bottom ash, fumes, wastewater, and
other effluents, which are released to the soil, groundwater, surface water, sediments, and air
(Sepulveda, Schluep et al. 2010). For example, the burning of electronic components containing
flame retardants can produce a range of toxic by-products including halogenated dioxins and
furans (U.S. EPA 1998; Tohka and Zevenhoven 2002).
Landfilling Electronics
More than 3.2 million tons of end-of-life electronics, predominately from households, are sent to
landfills (U.S. EPA 2010b). Landfills in the United States are for the most part well managed and
regulated, but in non-regulated and non-lined landfills, these post-use electronics can contribute
to leachate (i.e., the mixture of rainwater and liquids within the waste). This leachate has the
potential to seep into the ground or drain into nearby surface water, transporting chemicals where
humans and wildlife may be exposed. Additive flame retardants have a higher potential than
reactive flame retardants to be released from electronic products (KemI 1995). No reactive flame
retardants were identified as alternatives to decaBDE.
To date, most leachability studies in the literature have focused on the potential for discarded
electronic devices to release lead and other heavy metals. A small number of studies have
investigated leaching potential of brominated flame retardants. For example, Osako et al, found
that the levels of several PBDE congeners in both raw and treated leachate were below the limit
of detection of 4,000 pg/L (Osako, Kim et al. 2004). Additionally, a study conducted by Beard
and Marzi investigated the leachability potential of phosphorus-based and brominated flame
retardants from thermoplastic polymers and found that small amounts of phosphorus and
bromine, respectively, leached from the polymer (Beard and Marzi 2006). Osako et al. also
concluded that the amount of leaching that occurs is dependent upon the chemical properties of
the landfill (Osako, Kim et al. 2004).
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Incineration of Electronics
According to EFRA, flame retarded plastics can be incinerated in municipal refuse incinerators
as long as they are equipped with the proper gas cleaning devices (EFRA 2006). The flame
retardant treatment will not prevent incineration at operating temperature.
EPA has done an alternatives assessment for flame retardants used in printed circuit boards, the
final report of which will include data on combustion by-products for different burning
scenarios. The final report will be posted to the DfE webpage:
http://epa.gov/dfe/pubs/projects/pcb/index.htm
5.6.2 Textiles
DecaBDE and its alternatives are often used in the textiles which make up office furniture,
commercial grade carpet, or military supplies such as tents, tarps and uniforms. Below is a
summary of information on the various textiles, specifically office furniture and commercial
grade carpet, which may enter each end-of-life pathway.
Recycling Textiles
Only ten percent of the six billion pounds of carpet disposed of in 2010 was recycled,
reconditioned, or reused (Carpet America Recovery Effort (CARE) 2010). As a response to the
high rate of carpet disposal in landfills, members of the carpet industry, representatives of
government agencies at the federal, state, and local levels (such as the U.S. EPA), and non-
governmental organizations created a voluntary partnership in 2002 to increase the amount of
post-consumer carpet reused, reconditioned, or recycled. The goal of the ten-year partnership is
to reduce the amount of carpet discarded in landfills by 40 percent by 2012 by diverting the
carpet to one of four routes: reuse, recycling, waste to energy (incineration technology that uses
recovered carpet as a fuel source to generate electricity), or cement kilns (the use of a recovered
carpet as an alternative fuel source and as an additive in cement production) (CARE 2006). In
order to achieve this benchmark, the carpet industry created the CARE, which, with members of
the carpet industry and government, is responsible for monitoring, evaluating, and assessing
progress toward the negotiated goals (CARE 2006).
Landfilling Textiles
The frequent replacement of office furniture results in the increased production of products and
leads to large volumes of furniture discarded in landfills. Landfilling is also the most common
fate of used carpeting. Even though almost all of the components in carpet can be recycled or
reused, the total estimated amount of U.S. carpet discarded in 2010 was six billion pounds
(CARE 2010).
Research with the objective of investigating the release and transformation of additive and
reactive flame retardants from textiles in simulated landfill environments was conducted in 2008
(Horsing 2008). The study found that the environmental conditions of a landfill (e.g.,
temperature, microbial activity, and pH), the way additives are applied (i.e., additive or reactive),
and the nature of the material all affected the leaching of the flame retardants. Based on the
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findings of the impact of the different landfill conditions on additive flame retardants, the author
concluded that additive flame retardants may "leach and contribute to the contamination of water
but not so much in new, well-managed landfills and in developed countries as in old landfills in
countries where landfills are poorly managed" (Horsing 2008). Additionally, they found that the
only leaching that occurred from products treated with reactive flame retardants was washout
from unreacted manufacturing residuals.
Incineration of Textiles
Incineration of textile waste from production sites is difficult given that pieces of fabrics are too
long and can cause fire outside the incinerator. The textiles are usually too strong to be ground
prior to incineration. Therefore large amounts of textile waste from textile plants are landfilled
instead of incinerated (Dahllof 2004). However, smaller flame-retarded textiles and foams can be
incinerated. This method is preferred as long as the incinerators are equipped with the proper gas
cleaning devices (EFRA 2006).
5.6.3 Storage and Distribution Products
A total of two to three billion storage and distribution pallets, composed of a variety of
components including wood, plastic, aluminum, steel, corrugated paperboard, and composite
wood, are believed to be in use in the United States (Buehlmann, Bumgardner et al. 2009; Pure
Strategies Inc. for Maine Department of Environmental Protection 2010). Wood currently
dominates the pallet market and is estimated to comprise 80 to 95 percent of pallets (Buehlmann,
Bumgardner et al. 2009; Pure Strategies Inc. for Maine Department of Environmental Protection
2010). Wood's overwhelming presence in the pallet market is due to its low material and
production costs and its relative abundance as a raw material. However, the use of plastic pallets
is becoming increasingly popular because plastic often is more durable, lighter, and more easily
sanitized than wood. In 2010, over 900 million plastic pallets were estimated to be in use (Pure
Strategies Inc. for Maine Department of Environmental Protection 2010).
Depending on the materials and construction, and the manner in which they are used, plastic
pallets could have an expected lifetime of 20 years. Many plastic pallets are made from recycled
plastic and are fully recyclable at the end of their lives (Pure Strategies Inc. for Maine
Department of Environmental Protection 2010). When plastic pallets are no longer usable, they
are removed from service and can enter a full recycling process (ERM 2008). One manufacturer
of high-density polyethylene (HDPE) pallets shreds or grinds damaged pallets for reuse as a raw
material, which, in turn, is molded into new pallets. Currently, new plastic pallets are sometimes
made with a combination of recycled and new HDPE but the recycled content may increase in
the long term. According to one producer of plastic pallets, small quantities of HDPE that might
be trimmed or removed during fabrication, handling and processing of extruded plastic are
collected for reuse at the pallet production facility.
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6 Considerations for Selecting Flame Retardants
Selecting an alternative chemical flame retardant involves considering a range of factors. Design
for the Environment (DfE) chemical alternatives assessments provide extensive information on
chemical hazards and provide a more general discussion of other factors relevant to substitution
decisions, such as: use information and exposure and life cycle considerations. Decision-makers
will likely supplement the human health and environmental information provided in this report
with information on cost and performance that may vary depending on the supplier, the materials
involved, and the intended application. Alternative flame retardants must not only have a
favorable environmental profile, but also must provide satisfactory (or superior) fire safety, have
an acceptable cost, and attain the appropriate balance of properties (e.g., mechanical, thermal,
aesthetic) in the final product. Users of information in this report may wish to contact the
manufacturers of alternative flame retardants for engineering assistance in designing their
products with the alternatives.
This chapter outlines attributes that are appropriate for a decision maker to consider in choosing
an alternative to decabromodiphenyl ether (decaBDE) and gives a summary of the results of this
assessment including certain caveats specific to this assessment that the reader should consider.
The chapter begins by describing five general attributes evaluated in this assessment that can
inform decision-making about chemical hazards: (1) human health, (2) ecotoxicity, (3)
persistence, (4) bioaccumulation potential and (5) exposure potential. The chapter gives special
attention to discussion of data gaps in the full characterization of chemicals included in this
assessment. The chapter also includes information on the social, performance, and economic
considerations that may affect substitution and the chapter concludes by providing additional
resources related to state, federal, and international regulations.
The scope of this assessment was focused on the human health and environmental hazards of
potential flame retardant substitutes. The report does not include a review or analysis of any
additional life-cycle impacts, such as energy and water consumption or global warming potential,
associated with any of the baseline or alternative chemicals, or the materials in which they are
used. If selection of an alternative flame retardant requires significant material or process
changes, relevant life-cycle analyses can be applied to the potentially viable alternatives
identified through this hazard-based alternatives assessment, and to the materials in which they
are used. Manufacturers may also wish to analyze the life-cycle impacts of materials that do not
require the use of a flame retardant, in order to select materials that pose the fewest life-cycle
impacts.
6.1 Preferable Human Health and Environmental Attributes
This section identifies a set of positive attributes for consideration when formulating or selecting
a flame retardant that will meet flammability standards. In general, a safer chemical has lower
human health hazard, lower ecotoxicity, better degradability, lower potential for bioaccumulation
and lower exposure potential. As described in Chapter 4, the toxicity information available for
each of the alternatives varies. Some hazard characterizations are based on measured data,
ranging from one study to many detailed studies examining multiple endpoints, doses and routes
of exposures. For other chemicals, there is no chemical-specific toxicity information available,
and in these cases either structure activity relationship (SAR) or professional judgment must be
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used. In Table 4-4, Table 4-5, and Table 4-6, the hazard designations based on SAR or
professional judgment are listed in black italics, while those with hazard designations based on
measured test data are listed in color. Readers are encouraged to review the detailed hazard
assessments available for each chemical in Chapter 4.
Residual starting materials should be considered and ideally disclosed by the manufacturer in a
hazard assessment. For example, several flame retardants are synthesized with bisphenol A or
tetrabromobisphenol A. If residual monomers were identified as more than 0.1 percent of the
product they were considered in the hazard assessment. It is possible DfE was not aware of/did
not predict residuals for some products. The user/purchaser of the flame retardants can ask the
manufacturer for detailed product certification to answer questions about residuals, oligomer
content or synthesis by-products.
6.1.1 Low Human Health Hazard
The DfE alternatives assessment criteria address a consistent and comprehensive list of human
health hazard endpoints. Chemical hazards to human health assessed in this report are: acute
toxicity, carcinogenicity, genotoxicity, reproductive and developmental toxicity, neurotoxicity,
repeated dose toxicity, skin sensitization, respiratory sensitization, eye irritation and dermal
irritation. The DfE criteria describe thresholds to define low, moderate, and high hazard. As
described in Chapter 4, where data for certain endpoints were not available or were inadequate,
hazard values were assigned using data for structural analogs, SAR modeling and professional
judgment. In some cases (e.g., respiratory sensitization) it was not possible to assign hazard
values due to a lack of data, models or structural analogs.
For the flame retardant chemicals evaluated in the report, human health hazard endpoints varied
due to the different chemistries of decaBDE and the 29 alternatives. Some general trends include
the following:
1. Large polymers (greater than 1,000 daltons) were generally designated as low concern
compared to discrete chemicals, because the large polymers generally cannot be absorbed
or easily metabolized. Chemicals with molecular weights (MWs) close to 1,000 may have
potential for absorption whereas those with MWs much larger than 1,000 have a much
lower potential for absorption (U.S. EPA 2010). Without absorption there cannot be
systemic effects. Although irritation can occur without absorption, it was not identified as
a hazard for any of the large polymers and therefore was not a distinguishing
characteristic in this assessment. The entire MW range of polymeric components was
considered. All representative oligomers and low MW polymers were assessed and when
they were responsible for the hazard designation, it was indicated as such using footnotes.
The presence of oligomers and low MW polymers is dependent upon specific synthesis
conditions and final MW range, can vary by application/trade product even for a given
CAS Number.
2. Acute mammalian toxicity was low for decaBDE and all the alternatives except for
tris(tribromoneopentyl) phosphate and the substituted amine phosphate mixture.
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3. Irritation and sensitization endpoints were generally not distinguishing, but five
chemicals had at least one designation of moderate, high, or very high for one or more
irritation or sensitization endpoint, whereas decaBDE had low designations for these
endpoints.
4. Carcinogenicity and mutagenicity hazards varied among the alternatives, with many low
or moderate results. None of the chemicals had high concerns for carcinogenicity. Only
zinc borate had a high concern for mutagenicity. DecaBDE was low for genotoxicity and
moderate for carcinogenicity. For the alternatives, many of the moderate designations for
carcinogenicity and mutagenicity result from a lack of data or SAR. DfE criteria are
conservative for both of these endpoints in that a lack of data or SAR to designate the
hazard as low triggers a default designation of moderate.
5. Reproductive, developmental, neurological, and repeated dose toxicity varied from very
low to high across discrete chemicals. DecaBDE has high developmental toxicity and
moderate repeated dose toxicity.
Examples of DfE Approaches for Neurotoxicity and Degradation Products
This assessment used the DfE hazard criteria that were published in 2011. The 2011 criteria do
not specifically address two factors that were important for this assessment of flame retardants:
developmental neurotoxicity in the face of incomplete data sets, and theoretical but
undemonstrated degradation products. Special consideration, which is summarized below, was
given to these factors and used to complement the hazard profiles where relevant.
Some of the alternatives have structures that result in questions about potential for degradation
products. For example, some of the decaBDE alternatives are synthesized from TBBPA and
contain a TBBPA backbone (e.g., tetrabromobisphenol A bis (2,3 dibromopropyl ether) (21850-
44-0), brominated epoxy resin end-capped with tribromophenol (135229-48-0), brominated
epoxy polymers (68928-70-1)). It is not evident that TBBPA will be released from these
substances and the conditions necessary for such degradation are not known. If TBBPA is
released through the degradation of these substances, the associated hazard profiles would be
influenced by any toxicity associated with TBBPA19. There is a lack of data to determine if
20
TBBPA might be a degradation product of, for example, TBBPA-bis (2,3 dibromopropyl) ether
under environmental conditions. Further testing is needed to answer this question. The chemical
considerations section of the profiles for the brominated epoxy resin end-capped with
tribromophenol and the brominated epoxy polymers describes the potential for low MW
components to inform readers how this pathway was considered during the assessment process.
For the profiles of the three substances identified above, formation of TBBPA was not explicitly
considered when assigning the hazard designations.
There is also inadequate information to fully understand the neurotoxicity of decaBDE and its
alternatives. There are two types of neurotoxicity: neurotoxicity which is a result of an exposure
19 TBBPA has been evaluated in a 2-year carcinogenicity study at the National Toxicology Program (NTP) (NTP
2013b) and in the DfE's Partnership to Evaluate Flame Retardants in Printed Circuit Boards (U.S. EPA 2008b).
20 TBBPA bis (2,3 -dibromopropyl) ether has been nominated for consideration for a 2-year cancer bioassay at NTP
(Haneke 2002; NTP 2013a).
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to a substance during gestation or lactation, referred to as developmental neurotoxicity, and
neurotoxicity as a result of exposure to a substance as an adult. Developmental neurotoxicity has
been associated with decaBDE (European Chemicals Bureau 2002; U.S. EPA 2008a;
Washington Department of Ecology 2008), and organophosphate esters as a class are associated
with neurotoxicity. Therefore it is of interest to assess the developmental and adult neurotoxicity
of the decaBDE alternatives. The assessment of the neurotoxicity hazard (developmental and
adult) of the chemicals assessed in this report presented some challenges as outlined below.
For the highly brominated discrete organics, such as decabromodiphenyl ethane and ethylene
bistetrabromophthalimide, data exist for developmental neurotoxicity for some substances but
there are no data for adult neurotoxicity. Filling data gaps for neurotoxicity was challenging.
One possible approach was to predict that any developmental neurotoxicant is also an adult
neurotoxicant (or vice versa). While some substances can be both developmental and adult
neurotoxicants, it is also possible for substances to be either developmentally neurotoxic or
neurotoxic in adults and not both; therefore, this approach was not used. A second potential
approach was to look for neurotoxicity data for a wide range of analogs for highly brominated
compounds. Unfortunately, none of the analogs that U.S. Environmental Protection Agency
(EPA) identified had any neurotoxicity data based upon adult exposures. The third approach,
which was used for this assessment, was to use professional judgment to determine if there are
structural alerts to consider highly brominated compounds to be adult neurotoxi cants based upon
the DfE hazard criteria (see Section 4.1.2). EPA determined there was no evidence of structural
alerts and therefore gave the highly brominated discrete organics a hazard designation of
estimated Low for adult neurotoxicity. For developmental toxicity, EPA gave substances
21
analogous to decaBDE a hazard designation of High based on measured developmental
neurotoxicity data22 for decaBDE.
Neurotoxicity was also considered for the phosphates as a group. Although many organic
phosphates ("organophosphates") are associated with neurotoxicity (e.g., tri-ortho cresyl
phosphate and parathion, neither of which is included in this assessment), neurotoxicity data are
limited for the organic phosphates in this report. The available data and physical-chemical
properties of the discrete phosphate alternatives in this report do not suggest concern for
neurotoxicity or developmental neurotoxicity. With some exceptions, phosphates and inorganics
are estimated or measured Low for adult neurotoxicity and developmental toxicity in this report.
Additional experimental data would help to verify EPA's estimations.
6.1.2 Low Ecotoxicity
Ecotoxicity includes adverse effects observed in wildlife. An aquatic organism's exposure to a
substance in the water column has historically been the focus of environmental toxicity
considerations by industry and government during industrial chemical review. Surrogate species
of fish, aquatic invertebrates and algae are traditionally assessed to consider multiple levels of
the aquatic food chain. Aquatic organisms are a focus also because the majority of industrial
21 Measured data were available for decaBDE resulting in a measured High designation. DecaBDE is an analog for
decabromodiphenyl ethane resulting in an estimated High designation.
22 Developmental toxicity considers additional endpoints beyond neurotoxicity, such as teratogenicity. However, in
the case of decaBDE the developmental neurotoxicity data informed the High hazard designation.
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chemicals are released to water. Both acute and chronic aquatic toxicity should be considered in
choosing a chemical flame retardant. It is common to have limited data on industrial chemicals
for terrestrial wildlife. Some human health data (i.e., toxicity studies which use rodents) can be
relevant to non-human vertebrates in ecotoxicity evaluations. When evaluating potential
concerns for higher trophic level organisms (including humans), bioaccumulation potential
(discussed in Section 6.1.4) is an important consideration in conjunction with toxicity for
choosing a safer alternative.
For the flame retardant chemicals evaluated in the report, ecotoxicity hazards varied significantly
due to the diverse chemistries of the alternatives. Some general trends include the following:
1. Large discrete chemicals and large polymers (both halogenated and non-halogenated)
had generally low ecotoxicity hazards. The larger chemicals and compounds with high
Kow values are not expected to be bioavailable in the water column. Without absorption
there cannot be systemic effects. For almost all the chemicals included in this
assessment (including decaBDE) the hazard designation was based on professional
judgment and/or SAR predicting 'no effects at saturation'.
2. For inorganic compounds, aquatic toxicity varied from Low to High hazard. The metal
species influences toxicity, as does the type of anion with which it is associated (e.g., a
metal hydroxide). Metal compounds will have different solubilities depending on the
anion involved, which will contribute to the level of toxicity of the metal compound.
The aluminum, antimony and zinc compounds have Moderate to High aquatic toxicity
hazard. For aluminum hydroxide, sufficient data are not available to rule out a
Moderate concern. For magnesium hydroxide and red phosphorus, aquatic toxicity was
Low based on predicted and measured data, respectively.
3. In addition to some of the inorganic compounds, some of the phosphorus and/or
nitrogen-containing compounds also had High or Very High measured or predicted
aquatic toxicity.
4. Ecotoxicity data for terrestrial species was limited or completely absent for the
chemicals assessed. Therefore, potential for impacts of the alternatives on high trophic
level and terrestrial wildlife is unclear and could not be fully assessed.
6.1.3 Readily Degradable: Low Persistence
Persistence describes the tendency of a chemical to resist degradation and removal from
environmental media, such as air, water, soil and sediment. Chemical flame retardants must be
stable by design in order to maintain their flame retardant properties throughout the lifetime of
the product. Therefore, it is not surprising that all but two of the chemicals assessed in this
report, including decaBDE, had a persistence value of high or very high. The alternatives without
high concern for persistence were triphenyl phosphate, which is readily biodegradable (low
persistence), as well as resorcinol bis-diphenyl phosphate (inherently biodegradable), which
degrades slowly (moderate persistence).
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The half-life for a given removal process is used to assign a persistence designation. The half-life
measured or estimated to quantify persistence of organic chemicals is not a fixed quantity as is it
for a linear decay process such as for the half-life of a radioisotope. Chemicals with half-lives
that suggest low or no persistence can still present environmental problems. "Pseudo
persistence" can occur when the rate of input (i.e., the emission rate) of a substance exceeds the
rate of degradation in, or movement out of, a given area. Even though triphenyl phosphate is by
definition not persistent, it demonstrates pseudo persistent properties (Waaijers 2013). With the
current criteria, DfE did not address pseudo persistence in the assessment which should include
analysis of volumes of production and release.
A number of the alternatives are high MW polymers (>10,000 daltons) that are predicted to be
highly persistent because they are not bioavailable or assimilated by microorganisms. Highly
persistent chemicals may ultimately degrade in the right environmental conditions, but time to
degradation is much longer than other chemicals, often several months or years.
If the use of higher MW chemicals and polymers for flame retardant applications increases, there
would be a need for further information regarding the environmental fate of these chemicals to
understand how they behave in the environment, including their persistence in various
environmental settings and the identity and toxicity of their degradation products. Environmental
monitoring information exists for some of the (non-polymeric) alternatives, including the
degradation products, which have been in the marketplace for more than a few years. However,
no information was available for other alternative chemicals.
Environmental monitoring could bolster hazard assessments by confirming that environmental
fate is as predicted. The lack of such information should not be taken as evidence that
environmental releases are not occurring. Environmental detection is not equivalent to
environmental persistence; detection in remote areas (e.g., the Arctic) where a chemical is not
manufactured is considered to be a sign of persistence and transport from the original point of
release. An ideal safer chemical would be stable in the material to which it is added and have low
toxicity, but also be degradable at end of life of that material, i.e., persistent in use but not after
use. This quality is difficult to achieve for flame retardants.
In addition to the rate of degradation or measured half-life, it is important to be aware of the
byproducts formed through the degradation process. In some cases, degradation products might
be more toxic, bioaccumulative or persistent than the parent compound. Some of these
degradation products are discussed in the hazard profiles, but a complete analysis of this issue is
beyond the scope of this assessment. This issue was discussed earlier, in Section 6.1.1 of this
chapter, in the context of compounds with a TBBPA backbone that may not degrade to TBBPA.
Experimental studies describing this degradation pathway were not available. The report did not
consider toxicity from this potential degradation route.
Additionally, a group of three phosphate esters, resorcinol bis-diphenyl phosphate (125997-21-9
"RDP"), bisphenol A bis-(diphenyl phosphate) (181028-79-5 "BAPP") and phosphoric acid,
mixed esters with [l,l'-bisphenyl-4,4'-diol] and phenol (1003300-73-9 "BPBP"), could
theoretically release biphenol-type structures during degradation by alkaline hydrolysis.
However, RDP and BAPP are poorly soluble substances possibly making hydrolysis a less
prevalent degradation pathway. Both RDP and BAPP are in commerce and are used in plastics
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for electronics. Questions have been raised about whether these substances can release resorcinol
and bisphenol A, respectively, during degradation. Experimental data on whether RDP or BAPP
release resorcinol or bisphenol-A through degradation are not available. Resorcinol and
bisphenol A are associated with endocrine activity; bisphenol A is a priority chemical for
regulatory activity and research.
The BPBP alternative is a new to market substance. Applying the same questions and analysis to
BPBP, this substance may also have a biphenol type degradant, 4, 4'-dihydroxybiphenyl, that
based on its structure, may have potential for endocrine activity.
For the phosphate esters described above, DfE cannot determine the likelihood of release of
degradates. DfE includes this information in the hazard profiles of relevant chemicals. Only
degradants that were known or predicted to be likely were included in the hazard assessments in
this report. Stakeholders are encouraged to conduct additional analyses of the degradation
products of preferable alternatives using the assessment methods described in Chapter 4.
In general, metal-containing chemicals are persistent. This is because the metal moiety remains
in the environment. Metal-containing compounds can be transformed in chemical reactions that
could change their oxidation state, physical/chemical properties, or toxicity. A metal-containing
compound may enter into the environment in a toxic (i.e., bioavailable) form, but degrade over
time into its inert form. The converse may also occur. The chemistry of the compounds and the
environmental conditions it encounters will determine its biotransformation over time. For
metals, information relevant to environmental behavior is provided in each chemical assessment
in Chapter 4 and should be considered when choosing an alternative.
6.1.4 Low Bioaccumulation Potential
The ability of a chemical to accumulate in living organisms is described by the bioconcentration,
bioaccumulation, biomagnification, and/or trophic magnification factors. DecaBDE has high
potential hazard for bioaccumulation, as do its break down products (lower brominated diphenyl
ether congeners). Some of the alternatives assessed in this report also have a high level of
potential for bioaccumulation, including the discrete brominated chemicals and, based on
presence of oligomers below 1,000 daltons, also some of the phenyl phosphates. Based on
structure activity relationships, the potential for a molecule to be absorbed by an organism tends
to be lower when the molecule is larger than 1,000 daltons. This is reflected in the low hazard
designations for bioaccumulation for the large polymeric flame retardants without low MW
components below 1,000 daltons. The inorganic flame retardants assessed in this report do not
have high potential to bioaccumulate. Note that care should be taken not to consider the 1,000
daltons size to be an absolute threshold for absorption - biological systems are dynamic and even
relatively large chemicals might be absorbed under certain conditions. In the past, available data
suggested that the large size of decaBDE would preclude transport across biological membranes
and that its limited water solubility would decrease the potential for absorption (Toxicology
Excellence for Risk Assessment 2003). Absorption of decaBDE is poor, whereas lower
brominated polybrominated diphenyl ethers (PBDEs) are readily absorbed (ATSDR 2004).
Subsequent studies using more sensitive analysis techniques have detected decaBDE in
biological samples demonstrating its potential to be absorbed (Lorber 2008). DecaBDE has a
MW of 959 daltons. This provides a basis to suggest that the potential for absorption and
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potential for bioaccumulation of large molecules around 1,000 daltons is not well understood.
Furthermore the initial 1,000 Dalton threshold was established based on the consideration of
BCFs. Corresponding thresholds for hazard assessments based on BAF have not yet been
rigorously established.
Chemical manufacturers have reduced absorption and bioaccumulation potential of certain
substances through the design of larger molecules. Making a molecule bigger (often by making
large polymeric molecules) can reduce bioavailability, or minimize the likelihood of low MW
components and residuals of concern. A larger polymeric flame retardant molecule may also
impact performance properties of the material to which the flame retardant is added in positive or
negative ways. A safer molecule also has to perform well in the intended application.
The test guidelines available to predict potential for bioaccumulation have some limitations. For
example, they do not require the measurement for the BCFs of different components of a
mixture, even if they are known to be present in the test material and sufficiently precise
analytical methods are available. This situation often arises for lower MW oligomers or
materials that have varying degree of substitution. Bioconcentration tests tend to be limited for
chemicals that have low water solubility (hydrophobic), and many flame retardants have low
water solubility. Even if performed properly, a bioconcentration test may not adequately measure
bioaccumulation potential if dietary exposure dominates over respiratory exposure (i.e., uptake
by fish via food versus via their gills). The Organisation for Economic Cooperation and
Development program recently updated the fish bioconcentration test, in which dietary uptake is
included for the first time (OECD 2012). Dietary uptake is of critical importance and may be a
more significant route of exposure for hydrophobic chemicals.
6.1.5 Low Exposure Potential
For humans, chemical exposure may occur at different points throughout the chemical and
product lifecycle; by dermal contact, by inhalation, and/or by ingestion; and is affected by
multiple physicochemical factors that are discussed in Chapter 5. The DfE alternatives
assessment assumes exposure scenarios to chemicals and their alternatives within a 'functional-
use' class to be roughly equivalent. The assessment also recognizes that in some instances
chemical properties, manufacturing processes, chemical behavior in particular applications, or
use patterns may affect exposure scenarios. For example, some decaBDE flame retardant
alternatives may require different loadings to achieve the same flammability protection.
Stakeholders should evaluate carefully whether and to what extent manufacturing changes,
lifecycle considerations, and physicochemical properties will result in markedly different
patterns of exposure as a result of informed chemical substitution. For example, a replacement
may leach out, or "bloom" out of the polymer it is flame retarding faster than decaBDE, thus
increasing its relative exposure during use or disposal. The combination of high persistence and
high potential for bioaccumulation makes an alternative less desirable. Even if human toxicity
and ecotoxicity hazards are measured or estimated to be low, dynamic biological systems don't
always behave as laboratory experiments might predict. High persistence, high bioaccumulation
chemicals, or their degradation products, have high potential for exposure and unpredictable
hazards following chronic exposures that may not be captured in the hazard screening process.
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6.2 Considerations for Poorly or Incompletely Characterized Chemicals
Experimental data for hazard characterization of industrial chemicals are limited. As described in
Chapter 4, for chemicals in this report without full data sets, analogs, SAR modeling, and
professional judgment were used to estimate values for those endpoints lacking empirical data.
No alternative chemical had empirical data for all of the hazard categories. Nine chemicals had
no empirical data at all, and all of their respective endpoints were predicted; an additional six
lacked data on at least 10 of the hazard endpoints. Several chemicals included in this analysis
appear to have more preferable profiles, with low human health and ecotoxicity endpoints,
although they are highly persistent, a frequent property for flame retardants (see Table 4-4, Table
4-5, and Table 4-6). There is less confidence in the results of some seemingly preferable
chemicals in which the majority of hazard profile designations are based on estimated effect
levels compared to chemicals with full experimental data sets. Empirical data would allow for a
more robust assessment that would confirm or refute professional judgments and then support a
more informed choice among alternatives for a specific use. Estimated values in the report can,
therefore, also be used to prioritize testing needs.
Examples where data are lacking for endpoints reviewed for chemicals in this report include the
following:
1. The environmental fate of large discrete or polymeric flame retardants (MW
approaching or exceeding 1,000 daltons) is uncertain. This is true for both halogenated
and non-halogenated chemicals. Polymeric flame retardants are assessed in this report.
Some of these polymeric chemicals were designed to be safer alternatives to decaBDE.
While SAR analysis shows these chemicals are anticipated to be associated with low
hazard, chemical-specific data to support these predictions are lacking. In general, large
polymeric flame retardants are predicted to have high persistence but low concern for
toxicity or potential for bioaccumulation. Further research is needed to fully understand
the environmental fate of polymers approaching or exceeding 1,000 daltons.
2. For discrete brominated chemicals with MW and (or) functional groups similar to
decaBDE, e.g., decabromodiphenyl ethane and ethylene bistetrabromophthalimide,
hazard designations were based on analogy to decaBDE. Because of reactivity,
physicochemical and structural properties similar to those of decaBDE, chronic
exposure studies are needed to rule out concerns similar to those that have been raised
regarding long-term exposure to decaBDE.
3. Empirical data is needed to confirm low toxicity and bioaccumulation predictions.
Flame retardants are usually highly persistent chemicals by design since they need to
maintain their properties throughout the lifetime of the flame retarded product;
however, the persistence can be less of a concern for chemicals with a preferable
toxicity and bioaccumulation profile. Empirical data for several chemicals identifies
them as high or very highly persistent but predicted information identifies them as
having low toxicity and/or bioaccumulation hazards.
4. An evaluation of potential combustion by-products was not a hazard category in this
alternatives assessment. When considering preferred substitutes, a product
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manufacturer may wish to consider the types of combustion by-products that may occur
when a flame retarded product burns.
In the absence of measured data, DfE encourages users of this alternatives assessment to be
cautious in the interpretation of hazard profiles. Chemicals used at high volumes, or likely to be
in the future, should be given priority for further testing. Decision-makers are advised to read the
full hazard assessments for each chemical, available in Chapter 4, which may inform whether
additional assessment or testing is needed. Contact DfE with any questions on the criteria
included in hazard assessments or the thresholds, data, and prediction techniques used to arrive at
hazard values (www.epa.gov/dfe).
Where hazard characterizations are based on measured data, there are often cases where the
amount of test data supporting the hazard rating varies considerably between alternative
chemicals. In Table 4-4, Table 4-5, and Table 4-6 the hazard characterizations based on SAR or
professional judgment are listed in black italics, while those with hazard characterizations based
on measured test data are listed in color. The amount of test data behind these hazard
characterizations shown in color can vary from only one study of one outcome or exposure, to
many studies in many species and different routes of exposure and exposure duration. In some
instances, testing may go well beyond basic guideline studies, and it can be difficult to compare
data for such chemicals against those with only a single guideline study, even though hazard
designations for both chemicals would be considered "based on empirical data" and thus come
with a higher level of confidence. Cases where one chemical has only one study but a second
chemical has many studies are complex and merit careful consideration. For hazard screening
assessments, such as the DfE approach, a single adequate study can be sufficient to make a
hazard rating. Therefore, some designations that are based on empirical data reflect assessment
based on one study while others reflect assessment based on multiple studies of different design.
The hazard rating does not convey these differences - the full hazard profile should be consulted
to understand the range of the available data.
6.3 Social Considerations
Decision-makers should be mindful of social considerations when choosing alternative
chemicals. This section highlights occupational, consumer, and environmental justice
considerations. Stakeholders may identify additional social considerations for application to their
own decision-making processes.
Occupational considerations: Workers might be exposed to flame retardant chemicals from
direct contact with chemicals at relatively high concentrations while they are conducting specific
tasks related to manufacturing, processing, and application of chemicals (see Section 5.1.1).
Many facilities have established risk management practices which are required to be clearly
communicated to all employees. The National Institute for Occupational Safety and Health
23
(NIOSH) has established a hierarchy of exposure control practices . From best to worst, the
practices are: elimination, substitution, engineering controls, administrative controls and personal
protection. Switching from high hazard chemicals to inherently lower hazard chemicals can
benefit workers by decreasing workplace risks through the best exposure control practices:
23 http://www.cdc.gov/niosli/topics/engcontrols/
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elimination and substitution of hazardous chemicals. While occupational exposures are different
to consumer exposures, workers are also consumers and as such workers are relevant to both
exposure groups.
Consumer considerations: Consumers are potentially exposed to flame retardant chemicals
through multiple pathways described in Chapter 5. As detailed in Section 5.1.5, exposure
research documents that people carry body burdens of flame retardants, including decaBDE and
its breakdown products. These findings have created pressure throughout the value-chain for
substitution, which impacts product manufacturers. DfE alternatives assessments can assist
companies in navigating these substitution pressures.
In recent years there has been a greater emphasis on 'green' products. In addition to substituting
in alternative chemicals, some organizations advocate for moving away from certain classes of
chemicals entirely (e.g., halogenated flame retardants), with product re-design, to avoid future
substitutions altogether. Product manufacturers should be mindful of the role of these
organizations in creating market pressure for alternative flame retardant chemicals and strategies,
and should choose replacement chemicals - or re-designs - that meet the demands of their
customers.
Environmental justice considerations: At EPA, environmental justice concerns refer to the
disproportionate impacts on people based on race, color, national origin, or income that exist
prior to or that may be created by the proposed action. These disproportionate impacts arise
because these population groups may experience higher exposures, are more susceptible in
response to exposure, or experience both conditions. Factors that are likely to influence
resilience/ability to withstand harm from a toxic insult can vary with sociodemographics (e.g.,
co-morbidities, diet, metabolic enzyme polymorphisms) and are therefore important
considerations. Adverse outcomes associated with exposure to chemicals may be
disproportionately borne by people of a certain race, national origin or income bracket. Insights
into EPA's environmental justice policy can be accessed at:
www.epa.gov/compliance/ei/resources/policv/considering-ei-in-rulemaking-auide-07-2010.pdf.
Some populations have higher exposures to certain chemicals in comparison to the average
member of the general population. Low-income populations are over-represented in the
manufacturing sector, increasing their occupational exposure to chemicals. Higher exposures to
environmental chemicals may also be attributable to atypical product use patterns and exposure
pathways. This may be due to a myriad of factors such as cultural practices, language and
communication barriers, and economic conditions. The higher exposures may also be a result of
the proximity of these populations to sources that emit the environmental chemical (e.g.,
manufacturing industries, industries that use the chemical as production input, hazardous waste
sites, etc.), access to and use of consumer products that may result in additional exposures to the
chemical, or higher employment of these groups in occupations associated with exposure to the
chemical.
Some populations are disproportionately exposed to chemicals no longer manufactured in the
U.S., including some flame retardants like the components of commercial octa- and
pentabromodiphenyl ethers (Zota, Adamkiewicz et al. 2010). Low-income households may have
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older furniture and other consumer goods, leading to higher exposure to flame retardants as the
materials break down over time and chemicals migrate out of products. It is possible that low-
income households are less able than higher income households to replace their furniture with
new products possibly containing less hazardous materials. Minorities and low income
populations tend to live in low income housing, which is typically low quality housing stock and
may be poorly ventilated and contain old carpeting, which is a significant source of household
dust, and low-income populations may be less able to afford high quality vacuum cleaners to
reduce levels of dust in the home. Also, research has documented that certain communities may
have greater exposure to industrial waste, making them more exposed to releases from
manufacturing facilities (United Church of Christ 1987; Faber and Krieg 2005; Bullard, Mohai et
al. 2007; Mohai, Pellow et al. 2009). Finally, certain populations may experience high exposures
to toxic chemicals due to geography, food sources, and cultural practices (Burger and Gochfeld
2011). There is research showing that Alaska Natives are disproportionately impacted by certain
flame retardants and other persistent organic pollutants, both because of atmospheric transport of
persistent chemicals and because of the biomagnification of chemicals in traditional subsistence
food webs (Arctic Monitoring and Assessment Program 2009).
Considering environmental justice in the assessment of an alternative chemical may include
exploring product use patterns, pathways and other sources of exposure to the substitute,
recognizing how upstream factors such as socio-economic position, linguistic and
communication barriers, may alter typical exposure considerations. One tool available to these
populations is the Toxics Release Inventory (TRI), which was established under the Emergency
Planning and Community Right-to-Know Act to provide information about the presence,
releases, and waste management of toxic chemicals. Communities can use information reported
to TRI to learn about facilities in their area that release toxic chemicals and to enter into
constructive dialogue with those facilities. This information can empower impacted populations
by providing an understanding about chemical releases and the associated environmental impacts
in their community. Biomonitoring data for the alternative chemical, if available, can also signal
the potential for disproportionate exposure among populations with EJ issues.
6.4 Performance Considerations
The DfE approach allows companies to examine hazard profiles of potential replacement
chemicals so they can consider the human health and environmental attributes of a chemical in
addition to cost and performance considerations. This is intended to allow companies to develop
marketable products that meet performance requirements while reducing hazard. This section
identifies some of the performance attributes that companies should consider when formulating
or selecting a flame retardant, in addition to health and environmental consideration.
Performance attributes are critical to the overall function and marketability of flame retardants
and should be considered along with other factors. Chapter 2 includes a detailed discussion of the
categories of materials, sectors, and products relevant to the chemicals in this assessment, along
with a discussion of relevant flammability standards.
The ability of a product to meet required flammability standards is an essential performance
consideration for all flame retardant chemicals. The fire safety requirements influence the
amount and type of flame retardant, if any, that needs to be added to a resin. Formulations are
optimized for cost and performance, so that in some instances it may be equally viable to use a
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small quantity of an expensive, highly efficient flame retardant or a larger quantity of a less
expensive, less efficient chemical.
In addition to flame retardancy properties, the flame-retarded product must meet all required
specifications and product standards (e.g., rigidity, compression strength, weight). The
polymer/fire retardant combination used in many of the products which contain decaBDE may
be complex chemical formulations. In some instances, replacements exist which could allow for
relatively easy substitution of the flame retardant. However, a true "drop-in" exchange of flame
retardants is rare; some adjustment of the overall formulation, product re-design, or use of
inherently flame retardant materials is usually required. An alternative with similar physical and
chemical properties such that existing storage and transfer equipment as well as flame retardant
manufacturing technologies could be used without significant modifications. Unfortunately,
chemicals that are closer to being "drop-in" substitutes generally have similar physical and
chemical properties, and therefore are likely to have similar hazard and exposure profiles. Those
seeking alternatives to decaBDE should work with flame retardant manufacturers and/or
chemical engineers to develop the appropriate flame retardant formulation for their products.
6.5 Economic Considerations
This section identifies economic attributes that companies often consider when formulating or
selecting a flame retardant. Economic factors are best addressed by decision-makers within the
context of their organization. Accurate cost estimations must be company-specific; the impact of
substituting chemicals on complex product formulations can only be analyzed in-house; and a
company must determine for itself how changes will impact market share or other business
factors. Cost considerations may be relevant at different points in the chemical and/or product
lifecycle. These attributes are critical to the overall function and marketability of flame retardants
and flame retarded products and should be considered jointly with performance attributes, social
considerations, and human health and environmental attributes.
Substituting chemicals can involve significant costs, as industries must adapt their production
processes, and have products re-tested for all required performance and product standards.
Decision-makers are advised to see informed chemical substitution decisions as long-term
investments, and to replace the use of decaBDE with a chemical they anticipate using for many
years to come. This includes attention to potential future regulatory actions motivated by adverse
human health and environmental impacts, as well as market trends. One goal is to choose from
among the least hazardous options to avoid being faced with the requirement to substitute again.
Flame retardants that are either more expensive per pound or require more flame retardant per
unit area to meet the fire safety standards will increase raw material costs. In this situation, a
product manufacturer substituting away from decaBDE may pass the cost of a more expensive
flame retardant on to customers (e.g., a television manufacturer), who subsequently may pass the
cost on to retailers and consumers. In some cases the price premium significantly diminishes
over the different stages of the value chain. However, market conditions, competing
technologies, and intellectual property issues may influence flame retardant selection when
replacing decaBDE.
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Handling, disposal, and treatment costs, as well as options for mechanical recycling, may be
important considerations when evaluating alternatives. Inherently high hazard chemicals may
require special engineering controls and worker protections that are not required of less
hazardous alternatives. Disposal costs for high hazard chemicals may also be much higher than
for low hazard alternatives. High hazard chemicals may be more likely to result in unanticipated
and costly clean-up requirements or enforcement actions should risk management protections fail
or unanticipated exposures or spills occur. Also, some chemicals may require specific treatment
technologies prior to discharge through wastewater treatment systems. These costs can be
balanced against potentially higher costs for the purchase of the alternative chemical. Finally,
initial chemical substitution expenses may reduce future costs of mitigating consumer concerns
and perceptions related to hazardous chemicals.
It should be noted that, while some assessed alternative chemicals included in this report are
currently manufactured in high volume, not all are currently available in quantities that would
allow their widespread use immediately. However, prices and availability may change if demand
increases.
6.6 Moving Towards a Substitution Decision
As stakeholders proceed with their substitution decisions for decaBDE, the functionality and
technical performance of each product must be maintained, which may include product
performance in extreme environments over a lifecycle of many years. Critical requirements, such
as product safety during operation cannot be compromised. When alternative formulations are
developed, the stakeholders should also consider the hazard profiles of the chemicals used to
meet product performance, with a goal to drive towards safer chemistry on a path of continuous
improvement.
When chemical substitution is the necessary approach, the information in this report can help
with selection of safer, functional alternatives. The hazard characterization, performance,
economic, and social considerations are all factors that will impact the substitution decision.
When choosing safer chemicals, alternatives should ideally have a lower human health hazard,
lower ecotoxicity, better degradability, lower potential for bioaccumulation, and lower exposure
potential. Where limited data are available characterizing the hazards of potential alternatives,
further testing may be necessary before a substitution decision can be made.
Switching to an alternative chemical is a complex decision that requires balancing all of the
above factors as they apply to a particular company's cost and performance requirements.
DecaBDE is used in a range of polymers and end products; it is therefore unlikely that a single
alternative evaluated by this report will fulfill all of the current applications of decaBDE. This
report provides hazard information about alternatives to decaBDE to support the decision-
making process. Companies seeking a safer alternative should identify the alternatives that may
be used in their product (see Table 3-2), and then apply the information provided in this report to
aid in their decision-making process.
Alternative chemicals are often associated with trade-offs. For any chemical identified as a
potential alternative, some endpoints may appear preferable while other endpoints indicate
increased concern relative to the original chemical. A chemical may be designated as a lower
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concern for human health but a higher concern for aquatic toxicity or persistence. For example,
in the case of high MW polymers, where health hazards and potential bioaccumulation are
predicted to be low, one trade-off is high persistence. Additionally, there may be limited
information about the polymer's combustion byproducts, or how the polymer behaves in the
environment and eventually degrades.
Trade-offs can be difficult to evaluate, and such decisions must be made by stakeholders taking
into account relevant information about the chemical's hazard, expected product use, and life-
cycle considerations. For example, chemicals expected to have high levels of developmental or
reproductive toxicity should be avoided for products intended for use by children or women of
child-bearing age. Chemicals with high aquatic toxicity concerns should be avoided if releases to
water cannot be mitigated. Nonetheless, even when certain endpoints are more relevant to some
uses than others, the full hazard profile must not be ignored.
6.7 Relevant Resources
In addition to the information in this report, a variety of resources provide information on
regulations and activities that include review or action on flame retardants at the state, national
and global levels, some of which are cited in this section.
6.7.1 Resources for state and local government activities
University of Massachusetts at Lowell created a database which "houses more than 700 state and
local legislative and executive branch policies from all 50 states from 1990 to the present. The
online database makes it simple to search for policies that your state has enacted or introduced,
such as those that regulate or ban specific chemicals, provide comprehensive state policy reform,
establish biomonitoring programs, or foster "green" chemistry..." (National Caucus of
Environmental Legislators 2008).
http://www.chemicalspolicv.org/chemicalspolicv.us.state.database.php
The Interstate Chemicals Clearinghouse (IC2) is an association of state, local, and tribal
governments that promotes a clean environment, healthy communities, and a vital economy
through the development and use of safer chemicals and products. The IC2 also created a wiki
page to allow stakeholders and members of state organizations to share resources for conducting
safer alternatives assessments.
http://www.newmoa.org/prevention/ic2/
http://www.ic2saferalternatives.org/
6.7.2 Resources for EPA regulations and activities
EPA's website has a number of resources regarding regulation development and existing
regulations, along with information to assist companies in staying compliant. Some of these sites
are listed below.
Laws and Regulations
http ://www. epa. gov/1 awsregs/
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Office of Pollution Prevention and Toxics (OPPT): Information on PDBEs
http://www.epa.gov/oppt/pbde/
EPA - OPPT's Existing Chemicals Program
http://www.epa.gov/oppt/existingchemicals/index.html
America's Children and the Environment
http ://www. epa. gov/ace/
Integrated Risk Information System (IRIS)
http ://www. epa. gov/IRIS/
Design for the Environment Program (DfE)
http://www.epa.gov/dfe
6.7.3 Resources for global regulations
The European Union (EU)'s REACH (Registration, Evaluation, Authorisation and Restriction of
Chemical substances) legislation was enacted in 2007 and has an "aim to improve the protection
of human health and the environment through the better and earlier identification of the intrinsic
properties of chemical substances" (European Commission 2011a). Their website contains
information on legislation, publications and enforcement.
http://ec.europa.eu/environment/chemicals/reach/enforcement en.htm
Under REACH, applicants for authorization are required to control the use of Substances of Very
High Concern (SVHC). If a SVHC does not have available alternatives, applicants must carry
out their own alternatives assessments. The European Chemicals Agency has published a
guidance document for this application that provides direction for conducting an alternatives
assessment, as well as creating a substitution plan.
http://echa.europa.eu/documents/10162/17229/authorisation application en.pdf
The EU also has issued the Restriction of Hazardous Substances directive which ensures that
new electrical and electronic equipment put on the market does not contain any of the six banned
substances: lead, mercury, cadmium, hexavalent chromium, poly-brominated biphenyls or
PBDEs above specified levels (European Commission 201 lb).
http://www.bis.gov.uk/nmo/enforcement/rohs-home
6.8 The ENFIRO project
ENFIRO, Life Cycle Assessment of Environment-Compatible Flame retardants: Prototypical
Case Study (see http://www.enfiro.eu/). is a European Commission FP7 funded research project
(Contract-No. 226563) that evaluates viable substitution options for a number of brominated
flame retardants for better, safer alternatives (ENFIRO 2011). The consortium is a collaboration
between industries, small and medium enterprises and universities. The project delivers a
comprehensive dataset on viability of production and application, environmental safety, and a
life cycle assessment (LCA) of the alternative flame retardants. Different combinations of the
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flame retardant with the product are studied in five applications: printed circuit boards, electronic
components, injection-molded products, textile coatings, intumescent paint. Three types of
halogen free flame retardants (metal-, phosphorous- and nanoclay-based) are investigated in
relation to 1) environmental and toxicological risks, 2) viability of industrial implementation,
i.e., production of the flame retardant, 3) fire safety, and 4) application of the flame retardant into
the material. The fourteen flame retardants that were considered are: aluminum
diethylphosphinate, aluminum trihydroxide, ammonium polyphosphate, bisphenol A
bis(diphenyl phosphate), resorcinol bis(diphenyl phosphate), triphenyl phosphate, nanoclay,
melamine polyphosphate, zinc borate, zinc stannate, zinc hydroxystannate, dihydro
oxaphosphaphenantrene oxide, melamine cyanurate, and pentaerythritol. The project approach is
based on the chemical substitution cycle in which the alternative flame retardants are evaluated
regarding their environmental and toxicological properties, their flame retardant properties, and
their influence on the function of products once incorporated. The main objectives of ENFIRO
are 1) to deliver a comprehensive dataset on viability of production and application,
environmental safety, and a LCA of the alternative flame retardants, and 2) to recommend
certain flame retardant/product combinations for future study based on LCA, life cycle costing
and risk assessment studies. The outcome of that assessment together with socio-economic
information is used in a LCA. The ENFIRO approach and the results are useful for similar
substitution studies, e.g., in REACH. An ENFIRO Stakeholder Forum with members
representing flame retardant users (e.g., formulators and users of flame retardants, waste
(processing) plants) and other institutes such as non-governmental organizations and policy-
related ones, guide the project.
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6.9 References
Arctic Monitoring and Assessment Program (2009). AMAP Assessment 2009: Human Health in
the Arctic. Oslo, Norway.
ATSDR (2004). Toxicological Profile for Polybrominated Diphenyl Ethers and Polybrominated
Biphenyls.
Bullard, R. D., P. Mohai, et al. (2007). Toxic Wastes and Race at Twenty: 1987-2007. Grassroots
Struggles to Dismantle Environmental Racism in the U.S. Cleveland, United Church of
Christ Justice and Witness Ministries.
Burger, J. and M. Gochfeld (2011). "Conceptual environmental justice model for evaluating
chemical pathways of exposure in low-income, minority, native American, and other
unique exposure populations." Am J Public Health 101(S1): S64-S73.
ENFIRO. (2011). "Life Cycle Assessment of Environment-Compatible Flame Retardants:
Prototypical Case Study." Retrieved November 2011, from http://www.enfiro.eu/.
European Chemicals Bureau (2002). European Union Risk Assessment Report
Bis(Pentabromophenyl) Ether: Risk Assessment. CAS No. 1163-19-5. EINECS No. 214-
604-9. Luxemborg.
European Commission. (201 la). "REACH." Retrieved March 30, 2011, from
http://ec.europa.eu/environment/chemicals/reach/reach intro.htm.
European Commission. (201 lb). "Working with EEE producers to ensure RoHS compliance
through the European Union." Retrieved March 30, 2011, from
http://www.rohs.eu/english/index.html.
Faber, D. R. and E. J. Krieg (2005). Unequal Exposure to Ecological Hazards 2005:
Environmental Injustices in the Commonwealth of Massachusetts. Boston, Philanthropy
and Environmental Justice Research Project, Northeastern University.
Haneke, K. E. (2002). Tetrabromobisphenol A bis(2,3-dibromopropyl ether) [21850-44-2]:
Review of Toxicological Literature. November 2002. Prepared for National Institute of
Environmental Health.
Lorber, M. (2008). "Exposure of Americans to polybrominated diphenyl ethers." Journal of
Exposure Science 18(2-19).
Mohai, P., D. Pellow, et al. (2009). "Environmental Justice." Annual Review of Environment
and Resources 34.
National Caucus of Environmental Legislators. (2008). "Lowell Center Releases Searchable
State Chemical Policy Database." Retrieved March 30, 2011, from
http://www.ncel.net/newsmanager/news article, cgi? news id=193.
National Toxicology Program (NTP). (2013a). "Testing Status: Tetrabromobisphenol A-bis(2,3-
dibromopropyl ether)." Retrieved May 3, 2013, from
http://ntp.niehs.nih.gov/?objectid=BD48F894-123F-7908-7B7E35D7CFAA5298.
National Toxicology Program (NTP). (2013b). "TR-587: Technical Report Pathology Tables and
Curves. Pathology Tables, Survival and Growth Curves from NTP Long-Term Studies.
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TR-587: Tetrabromobisphenol A (TBBPA)." Retrieved May 3, 2013, from
http://ntp.niehs.nih.gov/7objecticNlAF3931A-FF57-C2F8-3948D37883F3B052.
OECD. (2012). "Section 3: Degradation and Accumulation." Retrieved April 9, 2012, from
http://www.oecd.Org/document/57/0.3746.en 2649 34377 2348921 111 1.00.html.
Toxicology Excellence for Risk Assessment (2003). Report of the Peer Consulation Meeting on
Decabromodiphenyl Ether. Cincinnati, OH.
U.S. EPA. (2008a). "Toxicological Review of DecaBromodiphenyl Ether (BDE-209) (CAS No.
1163-19-5). In Support of Summary Information on the Integrated Risk Information
System (IRIS). EPA/635/R-07/008F." Retrieved November 18, 2013, from
http://www.epa.gov/iris/toxreviews/0035tr.pdf.
U.S. EPA. (2008b). "Flame Retardants in Printed Circuit Boards (Review Draft)." Retrieved
November 18, 2013, from
http://www.epa.gov/dfe/pubs/projects/pcb/full_report_pcb_flame_retardants_report_draft
_1 l_10_08_to_e.pdf.
U.S. EPA. (2010). "Interpretive Assistance Document for Assessment of Polymers. Sustainable
Futures Summary Assessment." Retrieved November 18, 2013, from
http://www.epa.gov/oppt/sf/pubs/iad polymers 092011.pdf.
United Church of Christ (1987). Toxic Wasate and Race in the United States: A National Report
on the Racial and Socio-Economic Characteristics of Communities with Hazardous
Waste Sites, Commission for Racial Justice.
Waaijers, S. L., Kong D, Hendriks H.S., de Wit C.A., Cousins, I.T., R.H.S. Westerink, M.H.S.
Kraak, W. Admiraal, P.E.G. Leonards, P. de Voogt & J.R. Parsons (2013). "Persistence,
bioaccumulation and toxicity of halogen-free flame retardants. ." Reviews of
Environmental Contamination and Toxicology 222: 1-71.
Washington Department of Ecology (2008). Alternatives to Deca-BDE in Televisions and
Computers and Residential Furniture. Implementation of RCW 70.76: Identifying safer
and technically feasible alternatives to the flame retardant called Deca-BDE used in the
electronic enclosures of televisions and computers and in residential upholstered furniture
Final report, Department of Ecology Publication No. 09-07-041; Department of Health
Publication No. 334-181.
Zota, A., G. Adamkiewicz, et al. (2010). "Are PBDEs an environmental equity concern?
Exposure disparities by economic status." Environ Sci Technol 44(15): 5691-5692.
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Appendix A. Additional Reading and Background References
This report is not intended to be a comprehensive resource on all aspects of flame retardant or
polymer nanocomposite technology. This section includes additional books and peer-reviewed
publications which can provide additional information to the reader.
In many of the polymers which are included in the scope, a synergist is used to enhance the
flame retardant performance. An enhancement in flame retardant performance could mean
anything from a greater than expected reduction in heat release rate/flame spread rate, to reduced
smoke release/afterglow time, to enhanced onset of ignition time/higher ignition temperature.
While there are some known specific chemical synergistic interactions in regards to flame
retardancy (antimony-halogen, phosphorus-halogen, phosphorus-nitrogen) there are too many to
mention them all. Overall, synergism approaches are not as universal as the use of various flame
retardants given that synergism is very fire test/polymer/flame retardant chemistry combination
specific. Synergism may only be observed in one specific system and not in any others.
However, here are some other minor synergisms (including more information below):
• Inorganic enhancement of intumescent chars
• Metal oxides with halogenated FR
• Metal compounds to enhance char formation in polyvinyl chloride
• Zinc stannates for enhanced smoke reduction
• Borates with halogenated FR and some char forming FR additives
Similar to flame retardants, polymer nanocomposites can be used in a variety of systems. While
polymer nanocomposites act as a nearly universal synergist for lowering polymer flammability,
in some cases they may have antagonistic interactions with the other flame retardant, or may
bring some other undesirable property change to the final formulation. As with synergists, the
number of solutions for decreasing flammability with polymer nanocomposites is vast. Studying
the literature is necessary to understand what is possible, probable, and currently unknown.
In addition to the fire retardants being assessed in this document other potential technologies for
flame retardancy are listed in the references below. These alternative technologies may not yet
be commercially viable, or have not yet been assessed by the U.S. Environmental Protection
Agency (EPA) Design for the Environment (DfE) program. So while the technology may show
an alternate way of providing fire safety to a product, their environmental impact may be
unknown. However, the technologies show what is possible and what works, so the reader may
be able to develop new fire safe technologies for their product in case other flame retardants are
not economically or environmentally viable.
The references are divided into nanocomposite technology and flame retardancy topics below.
Most of the references are peer-reviewed papers and there are a few useful books. The field of
fire safety is constantly changing and therefore the reader is encouraged to use this list as a
starting point to their own literature search.
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Polymer Nanocomposite References:
"Polymer/layered silicate nanocomposites: a review from preparation to processing" Ray, S. S.;
Okamoto, M. Prog. Polym. Sci.2003, 28, 1539-1641.
"An overview on the degradability of polymer nanocomposites" Pandey, J. K.; Reddy, K. R.;
Kumar, A. P.; Singh, R. P. Polym. Degrad. Stab.2005, 88, 234-250
"Polymer nanocomposite foams" Lee, L. J.; Zeng, C.; Cao, X.; Han, X.; Shen, J.; Xu, G.
Composites Science and Technology2005, 65, 2344-2364
"Polymer Nanocomposites Containing Carbon Nanotubes" Moniruzzaman, M.; Winey, K. I.
Macromolecules2006, 39, 5194-5205.
"Polymer/montmorillonite nanocomposites with improved thermal properties Part I. Factors
influencing thermal stability and mechanisms of thermal stability improvement" Leszczynska,
A.; Njuguna, J.; Pielichowski, K.; Banerjee, J. R. Thermochimca ActalWSl, 435, 75-96.
"Polymer/montmorillonite nanocomposites with improved thermal properties Part II. Thermal
stability of montmorillonite nanocomposites based on different polymer matrixes" Leszczynska,
A.; Njuguna, J.; Pielichowski, K.; Banerjee, J. R. Thermochimica Acta 2007, 454, 1-22.
"Synthetic, layered nanoparticles for polymeric nanocomposites" Utracki, L. A.; Sepehr, M.;
Boccaleri, E. Polym. Adv. Technol.2007, 18, 1-37.
"Twenty Years of Polymer-Clay Nanocomposites" Okada, A.; Usuki, A. Macromol. Mater.
Eng.2001, 291, 1449-1476.
"Polymer Nanocomposites with Prescribed Morphology: Going beyond Nanoparticle-Filled
Polymers" Vaia, R. A.; Maguire, J. F. Chem. Mater.2007, 19, 2736-2751.
"HowNano are Nanocomposites?" Schaefer, D. W.; Justice, R. S. Macromolecules2007, 40,
8501-8517.
"Features, Questions, and Future Challenges in Layered Silicates Clay Nanocomposites with
Semicrystalline Polymer Matrices" Harrats, C.; Groeninckx, G. Macromol. Rapid
Commun.2008, 29, 14-26.
"From carbon nanotube coatings to high-performance polymer nanocomposites" Bredeau, S.;
Peeterbroeck, S.; Bonduel, D.; Alexandre, M.; Dubois, P. Polym. Intl.2008, 57, 547-553.
"Nanocomposites based on polyolefins and functional thermoplastic materials" Ciardelli, F.;
Coiai, S.; Passaglia, E.; Pucci, A.; Ruggeri, G. Polym. Int.2008, 57, 805-836.
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"Flame retarded polymer layered silicate nanocomposites: a review of commercial and open
literature systems" Morgan, A. B. Polym. Adv. Technol.2006, 17, 206-217.
"Polymer nanotechnology: Nanocomposites" Paul, D. R.; Robeson, L. M. Polymerias, 49,
3187-3204.
"Processing of nanographene platelets (NGPs) and NGP nanocomposites: a review" Jang, B. Z.;
Zhamu, A. J. Mater. ,Sc/.2008, 43, 5092-5101.
"Toxicity Evaluation for Safer Use of Nanomaterials: Recent Achievements and Technical
Challenges" Hussain, S. M.; Braydich-Stolle, L. K.; Schrand, A. M.; Murdock, R. C.; Yu, K. O.;
Mattie, D. M.; Schlager, J. J.; Terrones, M. Adv. Mater.2009, 21, 1549-1559.
"A review and analysis of electrical percolation in carbon nanotube polymer composites"
Bauhofer, W.; Kovacs, J. Z. Composites Science and Technology2009, 69, 1486-1498.
"An assessment of the science and technology of carbon nanotube-based fibers and composites"
Chou, T-W.; Gao, L.; Thostenson, E. T.; Zhang, Z.; Byun, J-H. Composites Science and
TechnologylOlO, 70, 1-19.
"Assessing the strengths and weaknesses of various types of pre-treatments of carbon nanotubes
on the properties of polymer/carbon nanotubes composites: A critical review" Bose, S.; Khare,
R. A; Moldenaers, P. Polymer20l0, 51, 975-993.
"Recent Advances in Research on Carbon Nanotube-Polymer Composites" Byrne, M. T.;
Gun'ko, Y. K. Adv. Mater.lQlQ, 22, 1672-1688.
"Carbon nanotube-based hierarchical composites: a review" Qian, H.; Greenhalgh, E. S.;
Shaffer, M. S. P.; Bismarck, A. J. Mater. Chem.2010, 20, 4751-4762.
"Current issues in research on structure-property relationships in polymer nanocomposites"
Jancar, J.; Douglas, J. F.; Starr, F. W.; Kumar, S. K.; Cassagnau, P.; Lesser, A. J.; Sternstein, S.
S.; Buehler, M. J. Polymeria, 51, 3321-3343.
"Polymer/layered silicate (clay) nanocomposites: An overview of flame retardancy" Kiliaris, P.;
Papaspyrides, C. D. Progress in Polymer SciencelOlO, 35, 902-958.
"Graphene/Polymer Nanocomposites" Kim, H.; Abdala, A. A.; Macosko, C. W.
Macromolecules20l0, 43, 6515-6530.
"Debunking Some Misconceptions about Nanotoxicology" Warheit, D. B. Nano LetterslOlO, 10,
4777-4782.
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Flame Retardant References:
"A review of current flame retardant systems for epoxy resins" Weil, E. D.; Levchik, S. J. Fire.
&7.2004, 22, 25-40.
"Commercial Flame Retardancy of Thermoplastic Polyesters - A Review." Weil, E. D.; Levchik,
S. J. Fire Sci.2004, 22, 339-350.
"Commercial Flame Retardancy of Unsaturated Polyester and Vinyl Resins: Review" Weil, E.
D.; Levchik, S. J. Fire &/.2004, 22, 339-350.
"Thermal decomposition, combustion and fire-retardancy of polyurethanes - a review of the
recent literature" Levchik, S. V.; Weil, E. D. Polym. Int.lWA, 53, 1585-1610.
"Thermal decomposition, combustion and flame-retardancy of epoxy resins - a review of the
recent literature" Levchik, S. V.; Weil, E. D. Polym. Int.2W4, 53, 1901-1929.
"Recent Advances for Intumescent Polymers" Bourbigot, S.; Le Bras, M.; Duquesne, S.;
Rochery, M. Macromol. Mater. Eng.2004, 289, 499-511.
"New developments in flame retardancy of epoxy resins" Levchik, S.; Piotrowski, A.; Weil, E.;
Yao, Q. Polym. Degrad. Slab. 2005, 88, 57-62.
"Developments in flame retardant textiles - a review" Horrocks, A. R.; Kandola, B. K.; Davies,
P. J.; Zhang, S.; Padbury, S. A. Polym. Degrad. Stab.2005, 88, 3-12.
"Flammability" Tewarson, A. Chapter 42 in "Physical Properties of Polymers Handbook, Mark
J. E. ed. AIP Press, NY 1996. pp 577-604.
"Overview of recent developments in the flame retardancy of polycarbonates" Levchik, S. V.;
Weil, E. D. Polym. M.2005, 54, 981-998.
"Flame and Smoke Retardants in Vinyl Chloride Polymers - Commercial Usage and Current
Developments" Weil, E. D.; Levchik, S.; Moy, P. J. Fire Sci.2006, 24, 211-236.
"Thermal decomposition, combustion and fire-retardancy of polyurethanes - a review of the
recent literature" Levchik, S. V.; Weil, E. D. Polym. Int.lWA, 53, 1585-1610.
"A review of flame retardant polypropylene fibres" Zhang, S.; Horrocks, A. R. Prog. Polym.
Sc/,2003, 28, 1517-1438.
"A Review of Recent Progress in Phosphorus-based Flame Retardants" Levchik, S. V.; Weil, E.
D. J. Fire Sc/,2006, 24, 345-364.
"Flame retarded polymer layered silicate nanocomposites: a review of commercial and open
literature systems" Morgan, A. B. Polym. Adv. Technol.2006, 17, 206-217.
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"Flame Retardants for Polystyrenes in Commercial Use or Development" Weil, E. D.; Levchik,
S. V. J. Fire Sci.lWl, 25, 241-264.
"Fire retardant polymers: recent developments and opportunities" Bourbigot, S.; Duquesne, S. J.
Mater. Chem.lWl, 17, 2283-2300.
"Flame Retardants in Commercial Use or Development for Polyolefins" Weil, E. D.; Levchik,
S. V. J. Fire Sc/,2008, 26, 5-42.
"New Developments in flame retardancy of styrene thermoplastics and foams" Levchik, S. V.;
Weil, E. D. Polym. M.2008, 57, 431-448.
"Flame Retardants in Commercial Use or Development for Textiles" Weil, E. D.; Levchik, S. V.
J. Fire Sc/,2008, 26, 243-281.
"Combined Fire Retardant and Wood Preservative Treatments for Outdoor Wood Applications -
A Review of the Literature" Marney, D.C.O.; Russell, L.J. Fire Technology200S, 44, 1-14
"Zinc borates as multifunctional polymer additives" Shen, K. K.; Kochesfahani, S.; Jouffret, F.
Polym. Adv. Technol.lOOS, 19, 469-474.
"Ignition, Combustion, Toxicity, and Fire Retardancy of Polyurethane Foams: A Comprehensive
Review" Singh, H.; Jain, A. K. J. App. Polym. Sci.2009, 111, 1115-1143.
"Fire Properties of Polymer Composite Materials" Eds. Mouritz, A. P.; Gibson, A. G. Springer-
Verlag, TheNetherlands, 2006. ISBN 978-1-4020-5355-9.
"Flame retardancy of silicone-based materials" Hamdani, S.; Longuet, C.; Perrin, D.; Lopez-
cuesta, J-M.; Ganachaud, F. Polym. Degrad. Stab.,2009, 94, 465-495.
"A Review of Transition Metal-Based Flame Retardants: Transition-Metal Oxide/Salts, and
Complexes" Morgan, A. B. ACS Symposium Series 1013 - Fire and Polymers V: Materials and
Concepts for Fire Retardancy2009, Oxford University Press, pp 312-328.
"SFPE Handbook of Fire Protection Engineering" 4th Edition, Eds. DiNenno, P. J.; Drysdale, D.;
Beyler, C. L.; Walton, W. D.; Custer, R. L. P.; Hall, J. R.; Watts, J. M. National Fire Protection
Association, Quincy, MA, 2008. ISBN 978-0-87765-821-4.
"Flame Retardants for Plastics and Textiles: Practical Applications" Weil, E. D.; Levchik, S. V.
Hanser Publishers, Cincinnati, OH 2009, ISBN 978-1-56990-454-1.
"A review on flame retardant technology in China. Part I: development of flame retardants"
Chen, L.; Wang, Y-Z. Polym. Adv. Technol.2010, 21, 1-26.
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Fire Retardancy of Polymeric Materials, 2nd Edition. Eds. Wilkie, C. A.; Morgan A. B.
December 2009 (2010 publishing date), Taylor and Francis. Boca Raton, FL ISBN 978-1-4200-
8399-6.
"Polymer/layered silicate (clay) nanocomposites: An overview of flame retardancy" Kiliaris, P.;
Papaspyrides, C. D. Progress in Polymer SciencelOlO, 35, 902-958.
"The fire retardant behavior of huntite and hydromagnesite - A review" Hollingbery, L. A.; Hull,
T. R. Polym. Degrad. Stab.2010, 95, 2213-2225.
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