U.S. Environmental Protection Agency
Hazard Characterization Document

December, 2012

SCREENING-LEVEL HAZARD CHARACTERIZATION

SPONSORED CHEMICAL

Benzoyl Chloride
(CASRN 98-88-4)

SUPPORTING CHEMICALS

Benzoic Acid (CASRN 65-85-0)

Hydrochloric Acid (CASRN 7647-01-0)

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

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

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

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

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

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

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

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


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Merck, etc.) and Science Direct and ECHA4. OPPT's focus on these specific sources is based on
their being of high quality, highly relevant to hazard characterization, and publicly available.

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

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

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Sponsored Chemical
CASRN 98-88-4

Supporting Chemicals
CASRN 65-85-0
CASRN 7647-01-0
Chemical Abstract Index	Sponsored Chemical

Name	Benzoyl chloride

Supporting Chemicals
Benzoic acid

	Hydrochloric acid

Structural Formula	Sponsored Chemical

	SMILES: Q=C(c(cccc 1 )c 1 )C1	

Summary

Benzoyl chloride is a colorless liquid with moderate vapor pressure that reacts immediately with
water to produce hydrochloric acid and benzoic acid. It would be expected to have high mobility
in soil and volatilization would be high based on its Henry's Law constant; however, the rapid
rate of hydrolysis suggests that these and other environmental fate pathways are not applicable
for this substance. The rate of atmospheric photooxidation is slow. Benzoyl chloride is expected
to have low persistence (PI) and low bioaccumulation potential (Bl).

Human Health Hazard Summary

The acute oral and dermal toxicity of benzoyl chloride (CASRN 98-88-4) is low in rats and
rabbits, respectively. The acute inhalation toxicity of benzoyl chloride (CASRN 98-88-4) in rats
is high. A 28-day repeated-dose toxicity study showed microscopic lesions in the lung of rats
administered 0.025 mg/L/day of the supporting chemical benzoic acid (CASRN 65-85-0) via
aerosol. Three 90-day inhalation repeated-dose toxicity studies were submitted for the
supporting chemical hydrochloric acid (CASRN 7647-01-0). In the study with mice, mortality
was observed in males at 0.0149 mg/L/day (NOAEC not established) and moribundity in females
at 0.07496 mg/L/day. The NOAEC for systemic toxicity in female mice was 0.0298 mg/L/day.
In another study, mortality was observed in female rats at 0.0746 mg/L/day. The NOAEC for
systemic toxicity in female rats was 0.0298. In the same study histopathological inflammatory
changes of the nasal cavity was observed at > 0.0149 and 0.0298 in female and male rats
respectively. The NOAEC for local toxicity in female rats is not established and the NOAEC in
male rats is 0.0149 mg/L/day. In another study with rats rhinitis was observed in both sexes at
all concentrations. The LOAEC for local toxicity is 0.0149 mg/L/day; the NOAEC for local
toxicity is not established. In the 90-day inhalation repeated-dose toxicity studies previously
mentioned with supporting chemical hydrochloric acid (CASRN 7647-01-0), no treatment-
related effects on reproductive tissues and organs in mice and rats were observed during	

Chemical Abstract Service
Registry Number
(CASRN)

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histopathological examinations. No treatment-related effects were observed in dams, growth and
development of offsprings, in a four-generation developmental toxicity study with supporting
chemical benzoic acid (CASRN 65-85-0) administered via the diet. The NOAEL for maternal
and developmental toxicity is 750 mg/kg-bw/day. The Benzoyl chloride (CASRN 98-88-4)
induced gene mutations in bacteria in vitro; but did not induce chromosomal aberrations in mice
in vivo. Benzoyl chloride (CASRN 98-88-4) is corrosive to the rabbit eye and irritating and
corrosive to the rabbit skin. Benzoyl chloride has the potential to induce tumors in female mice.

No data gaps were identified under the HPV Challenge Program.

Environmental Hazard Summary

For benzoyl chloride, the 96-hour LC50 for fish is 34.1 mg/L. Based on the supporting chemical,
benzoic acid, the 48-h EC50 for aquatic invertebrates is > 100 mg/L. The72-h EC50 of benzoyl
chloride for aquatic plants is 96 and 45 mg/L for growth rate and biomass, respectively.

No data gaps were identified under the HPV Challenge Program.

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The sponsor, American Chemistry Council (ACC) Benzoates Panel, submitted a Test Plan and
Robust Summaries to EPA for benzoyl chloride (CASRN 99-88-4; 9th CI name: benzoyl
chloride) on December 24, 2003. EPA posted the submission on the ChemRTK HPV Challenge
website on February 18, 2004

(http://www.epa.gov/oppt/chemrtk/pubs/summaries/benzchlr/cl4969tc.htm). EPA comments on
the original submission were posted to the website on June 22, 2004. Public comments were also
received and posted to the website. The sponsor submitted updated/revised documents on
August 15, 2005, which were posted to the ChemRTK website on September 16, 2005.

Justification for Supporting Chemicals

Benzoyl chloride undergoes rapid hydrolysis to benzoic acid (CASRN 65-85-0) and hydrochloric
acid (CASRN 7647-01-0). EPA comments state that "given the rapid hydrolysis of benzoyl
chloride at low pH, the submitter should consider using data on the hydrolysis products, benzoic
acid and hydrogen chloride, to address the repeated-dose, reproductive and developmental
toxicity endpoints instead of the proposed OECD TG 422" and that data on benzoic acid can be
used to address the algal toxicity endpoint. As recommended by the EPA, the sponsor provided
data for benzoic acid and hydrochloric acid to satisfy both aquatic and human health toxicity
endpoints. Upon further review, hydrochloric acid is not considered an adequate supporting
chemical for benzoyl chloride to satisfy aquatic toxicity endpoints. Aquatic toxicity test
guidelines require neutralization of the test media before test initiation and since tests with
hydrochloric acid are not neutralized the resulting toxicity is overly conservative due to
deviations in pH. Additional information on hydrogen chloride can be found at the following
website: http://www.chem.unep.ch/irptc/sids/oecdsids/7647010

1. Chemical Identity

1.1	Identification and Purity

Benzoyl chloride also known as benzenecarbonyl chloride is an organochlorine compound with
the formula C6H5COCI. It is a colorless very pungent liquid mainly used for the production of
peroxides but is generally useful in other area such as in the production of dyes, perfumes,
pharmaceuticals, and resins. It reacts with water to produce hydrochloric acid and benzoic acid.

1.2	Physical-Chemical Properties

The physical-chemical properties of benzoyl chloride are summarized in Table 1, while the
environmental fate properties are provided in Table 2.

Physical-Chemical Properties Characterization

Benzoyl chloride is a colorless liquid with moderate vapor pressure. It reacts rapidly with water
and therefore, the water solubility of this substance cannot be measured or estimated.

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Table 1. Physical-Chemical Properties of Benzoyl Chloride1

Property

Benzoyl chloride

CASRN

98-88-4

Molecular Weight

140.47

Physical State

Transparent, colorless liquid

Melting Point

-1°C (measured);
-0.6°C (measured)

Boiling Point

197.2°C (measured);
198.3°C (measured);

Vapor Pressure

0.38-1.0 mm Hg at 20°C (measured);
1.0 mm Hg at 32°C (measured);
2.8 mm Hg at 50°C (measured)

Dissociation Constant (pKa)

Not applicable

Henry's Law Constant

Not applicable due to hydrolysis

Water Solubility

Not applicable due to hydrolysis

Log K0w

Not applicable due to hydrolysis

'American Chemistry Council Benzoates Panel. 2005. Revised Test Plan and Robust Summary for Benzoyl Chloride.
Available online at http://www.epa.gov/chemrtk/pubs/summaries/benzchlr/cl4969tc.htm as of March 7, 2012.

2. General Information on Exposure

2.1	Production Volume and Use Pattern

Benzoyl chloride had an aggregated production and/or import volume in the United States
between 10 to 50 million pounds during calendar year 2005.

Non-confidential information in the IUR indicated that the industrial processing and uses of the
chemical include other basic organic chemical manufacturing as intermediates. Commercial and
consumer uses for the chemical were claimed confidential.

2.2	Environmental Exposure and Fate

Benzoyl chloride is expected to have high mobility in soil, and volatilization is expected to be
high; however, the rapid rate of hydrolysis indicates that volatilization, mobility in soil, and
biodegradation will not be important environmental fate processes. The hydrolysis half-life of
benzoyl chloride was reported as 16 seconds at 2°C. Benzoyl chloride was reported to achieve
92% of its theoretical biological oxygen demand (BOD) after 20 days using the closed bottle
(OECD 301D) test; however, due to the rapid rate of hydrolysis these results likely pertain to the
hydrolysis product (benzoic acid), not the parent substance. The rate of atmospheric
photooxidation is slow. Benzoyl chloride is expected to have low persistence (PI) and low
bioaccumulation potential (Bl).

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Table 2. Environmental Fate Characteristics of Benzoyl Chloride1

Property

Benzoyl chloride

CASRN

98-88-4

Photodegradation Half-life

6.0 days (estimated)2

Hydrolysis Half-life

16 seconds5

Biodegradation

Not applicable due to hydrolysis

Bioaccumulation Factor

Not applicable due to hydrolysis

Log Koc

Not applicable due to hydrolysis

Fugacity

(Level III Model)2'3

Air (%)
Water (%)
Soil (%)
Sediment (%)

100
<0.1
<0.1
<0.1

Persistence4

PI (low)

Bioaccumulation4

Bl (low)

'American Chemistry Council Benzoates Panel. 2005. Revised Test Plan and Robust Summary for Benzoyl Chloride.

Available online at http://www.epa. go v/chemrtk/pubs/ summaries/benzchlr/c 14969tc .htm as of March 7,2012.

2U.S. EPA. 2012. Estimation Programs Interface Suite™ for Microsoft® Windows, v4.10. U.S. Environmental Protection
Agency, Washington, DC, USA. Available online at http://www.epa.gov/opptintr/exposure/pubs/episuitedl.htm as of March 7,
2012.

3Half-lives of 0.004 hours were used for the water, soil, and sediment compartments while a half-life of 144 hours was used for
the atmosphere compartment.

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

5Benzoyl Chloride hydrolyzes rapidly to produce hydrochloric acid and benzoic acid.

Conclusion: Benzoyl chloride is a colorless liquid with moderate to high vapor pressure that
reacts immediately with water to produce hydrochloric acid and benzoic acid. It would be
expected to have high mobility in soil and volatilization would be high based on its Henry's Law
constant; however, the rapid rate of hydrolysis suggests that these and other environmental fate
pathways are not applicable for this substance. The rate of atmospheric photooxidation is slow.
Benzoyl chloride is expected to have low persistence (PI) and low bioaccumulation potential
(Bl).

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3. Human Health Hazard

A summary of the human health toxicity data submitted for SIDS endpoint is provided in
Table 3. The table is also noted were read across (RA) from supporting chemicals are utilized
for the sponsored chemical.

Acute Oral Toxicity

Benzoyl chloride (CASRN 98-88-4)

(1)	Male Wistar rats (10/dose) were administered undiluted benzoyl chloride (>99.5% purity) via
gavage at 1.0, 1.5, 2.0, 2.5, 3.1 or 5.0 mL/kg (~ 1210, 1820, 2420, 3030, 3750 or 6040 mg/kg)
and observed for 14 days following dosing. Mortality was observed at 1820(2), 2420(5),
3030(6), 3750(9) and 6040(10) mg/kg.

LD50 = 2528 mg/kg

(2)	Spartan rats (5/sex/dose, except for highest dose where only males were exposed) were orally
administered 10 mL/kg of benzoyl chloride (purity not indicated) in corn oil at 500, 1250, 1984,
3150, 5000 or 7940 mg/kg and observed for 14 days following dosing. Mortality was observed
in males at 3150(1), 5000(5), and 7940(5) mg/kg; mortality in females was observed at 1984(3),
3150(5), and 5000(5) mg/kg.

LD50 (males) = 3619 mg/kg
LD50 (females) = 1900 mg/kg
LD50 (combined) = 2618 mg/kg

(3)	Rats (number, sex and strain unspecified) were orally administered benzoyl chloride in two
separate studies. Further details or reliability scores were not provided in the robust summary for
this study.

LD50 = 2460 mg/kg
LD50 = 1900 mg/kg

Acute Dermal Toxicity
Benzoyl chloride (CASRN 98-88-4)

(1)	New Zealand White rabbits (2/sex) were administered benzoyl chloride (purity not indicated)
via the dermal route at 2000 mg/kg to unabraded or abraded skin under occluded conditions for
24 hours and observed for 14 days. No mortality was observed.

LD50 > 2000 mg/kg

(2)	Rabbits (number, sex and strain unspecified) were administered benzoyl chloride (purity not
indicated) via the dermal route. Further details or reliability scores were not provided in the
robust summary.

LD50 = 790 mg/kg

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Acute Inhalation Toxicity
Benzoyl chloride (CASRN 98-88-4)

(1)	Male Wistar rats (10/concentration) were exposed to benzoyl chloride (> 99.5% purity) via
nose-only inhalation at 0.190, 0.504, 0.708, 1.453 and 1.980 mg/L for 4 hours and observed for
21 days. Mortality occurred at 1.453(5) mg/L (within 1-19 days) and at 1.980(6) mg/L (within
4-48 hours).

4-h LC50 ~ 1.45 mg/L

(2)	Female Wistar rats (10/concentration) were exposed to benzoyl chloride (> 99.5% purity) via
nose-only inhalation at 0.190, 0.504, 0.708, 1.453 and 1.980 mg/L for 4 hours and observed for
21 days. Mortality occurred at 1.453(1) mg/L (within 10 days) and at 1.980(3) mg/L (within 4 -
24 hours).

4-h LC50 ~ 1.98 mg/L

(3)	Wistar rats (10/sex/concentration) were exposed to benzoyl chloride (purity not indicated) via
nose-only inhalation at 2.343 mg/L for 1 hour and observed for 21 days. Two females died 8 -

11 days after exposure.

1-h	LC50 > 2.34 mg/L

4-h LC50 (estimated) ~ 9.37 mg/L

(4)	Spartan rats (5/sex/concentration) were exposed via inhalation to an aerosol of benzoyl
chloride (purity not indicated) at 2.0 and 200 mg/L for 4 hours and observed for 14 days.
Mortality occurred on observation day six at 2.0(1) mg/L and all animals died within 4 hours of
exposure at 200 (5) mg/L.

4-h LC50 > 2 and < 200 mg/L

(5)	Rats (number, sex and strain unspecified) were exposed to benzoyl chloride (purity not
indicated) via inhalation for 2 hours. Further details and reliability scores were not provided in
the robust summary.

2-h	LC50 = 1.87 mg/L

Repeated-Dose Toxicity

Benzoic acid (CASRN 65-85-0, supporting chemical)

Sprague-Dawley rats (10/sex/concentration) were exposed to technical-grade benzoic acid as a
dust aerosol at 0, 25, 250 or 1200 mg/m3 (~ 0, 0.025, 0.25, 1.2 mg/L) for 6 hours/day, 5
days/week for 28 days. Average particle size was 4.7 [j,m. Microscopic lesions in the lungs with
an increase in inflammatory cell infiltrate and interstitial fibrosis was observed in all test
animals. Animals exposed to > 0.25 mg/L exhibited upper respiratory tract irritation and
decreased absolute and relative kidney weights.

LOAEC (systemic toxicity) = 0.025 mg/L/day (based on microscopic lesions in the lungs)
NOAEC (systemic toxicity) = Not Established

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Hydrochloric acid (CASRN 7647-01-0, supporting chemical)

(1)	B6C3F1 mice (10/sex/concentration) were exposed to hydrochloric acid (99.99% purity) at
nominal concentrations of 0, 10, 20 or 50 ppm (~ 0 [air], 0.0149, 0.0298 and 0.0746 mg/L) for 6
hours/day, 5 days/week for 90 days. Time-weighted average concentrations were 0, 9.8, 19.1
and 46.7 ppm (~ 0, 0.0146, 0.0285 and 0.0696 mg/L). Animals were observed for an additional
day following completion of exposure. Mortality was observed in male rats at 0.0149 mg/L
(1/10) and 0.0746 mg/L treatment groups (1/10); and a single female was killed in extremis
following treatment at 0.0746 mg/L. Statistically significant (p < 0.05) reductions in body
weight and food consumption (> 10% decrease, compared with controls) were observed in males
and females at 0.0746 mg/L. At 0.0746 mg/L, inflammation of the lips (cheilitis) with
accumulation of iron-storing protein macrophages, white blood cell globules in the epithelium of
the nasal passage and decreased liver weight was observed but not statistically significant.

White blood cell globules in the nasal passage epithelium were also observed at 0.0149 and
0.0298 mg/L. http://www.chem.unep.ch/irptc/sids/oecdsids/7647010

LOAEC (systemic toxicity) = 0.0149 mg/L/day (based on mortality in males)

NOAEC (systemic toxicity) = Not Established

LOAEC (systemic toxicity) = 0.0746 mg/L/day (based on moribund female)

NOAEC (systemic toxicity) = 0.0298 mg/L/day

(2)	Crl:CD(SD)Br rats (10/sex/concentration) were exposed to hydrochloric acid (99.99% purity)
at nominal concentrations of 0, 10, 20 or 50 ppm (~ 0 [air], 0.0149, 0.0298 and 0.0746 mg/L) for
6 hours/day, 5 days/week for 90 days. Time-weighted average concentrations were 0, 9.8, 19.0
and 46.7 ppm (~ 0, 0.0146, 0.0283 and 0.0696 mg/L). Animals were observed for an additional
day following completion of exposure. Mortality was observed in a single female at 0.0746
mg/L. A slight reduction in food consumption was observed in one female at 0.0149 mg/L and
one male at 0.0746 mg/L. Minimal to mild rhinitis in the anterior portion of the nasal cavity was
observed at the following incidences in treatment groups as follows: males (0/10, 3/10 and 5/10)
and females (1/10, 1/10 and 4/10) respectively. No treatment-related effects were observed on
urinalysis, hematology and serum chemistry.

http ://www. chem .unep. ch/irptc/sids/oecdsids/7647010

LOAEC (systemic toxicity) = 0.0746 mg/L/day (based on mortality in females) highest dose

tested

NOAEC (systemic toxicity) = 0.0298mg/L/day

LOAEC (local toxicity) = 0.0149 mg/L/day (histopathological inflammatory changes in the
nasal cavity in females)

LOAEC (local toxicity) = 0.0298 mg/L/day (histopathological inflammatory changes in the
nasal cavity in males)

NOAEC (local toxicity) = 0.0149 mg/L/day

(3)	Fischer 344 rats (10/sex/concentration) were exposed to hydrochloric acid (99.99% purity) at
nominal concentrations of 0, 10, 20 or 50 ppm (~ 0 [air], 0.0149, 0.0298 and 0.0746 mg/L) for 6
hours/day, 5 days/week for 90 days. Time-weighted average concentrations were 0, 9.8, 19.1
and 46.8 ppm (~ 0, 0.0146, 0.0285 and 0.0698 mg/L). Animals were observed for an additional
day following completion of exposure. No mortality was observed. Decreases in food
consumption at 0.0298 and 0.0746 mg/L, and body weight (0.0746 mg/L) were observed in
males. Minimal to mild rhinitis in the anterior portion of the nasal cavity was observed in all

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treated animals at the following incidences: males (3/10, 7/10 and 9/10) and females (3/10, 5/10
and 6/10), respectively, http://www.chem.unep.ch/irptc/sids/oecdsids/7647010
LOAEC (local toxicity) = 0.0149 mg/L/day (based on rhinitis in both sexes)

NOAEC (local toxicity) = Not Established

Reproductive Toxicity

Hydrochloric acid (CASRN 7647-01-0, supporting chemical)

In the 90-day repeated-dose inhalation toxicity studies with B6C3F1 mice, Crl:CD(SD)Br rats
and Fischer 344 rats exposed to vapors of hydrochloric acid described previously, reproductive
tissues from animals in all dose groups were evaluated histopathologically after being weighed
and examined macroscopically. No treatment-related effects on the histopathology of
reproductive tissues or organs were found. No weight-related changes or lesions were reported.
http ://www. chem .unep. ch/irptc/sids/oecdsids/7647010

Developmental Toxicity

Benzoic acid (CASRN 65-85-0, supporting chemical)

In a four-generation study, rats of an unspecified strain (20/sex/dose) were exposed to diets
containing 0.5 or 1% benzoic acid (~ 375 and 750 mg/kg-bw/day). The exposure periods were:
generation 1 and 2-lifelong, generation 3-16 weeks and generation 4-until breeding. In all four
generations, no treatment-related effects on body weight, body weight gain, food efficiency and
organ weight was observed. No treatment-related effects on fertility and lactation were
observed. The animals of the third generation were sacrificed and examined histopathologically
after lactation of pups (-16 weeks). No treatment-related histopathological findings were
specified. However, information in the original report was inadequate to determine the organs
and tissues examined. Robust summary informations assumes that as a minimum the brains,
heart, liver, kidney, testis and were examined (sic)." No treatment-related effects on the dams,
growth and development of the offsprings were observed.

NOAEL (maternal toxicity) ~ 750 mg/kg-bw/day (highest dose tested)

NOAEL (developmental toxicity) -750 mg/kg-bw/day (highest dose tested)

Genetic Toxicity — Gene Mutation
In vitro

Benzoyl chloride (CASRN 98-88-4)

(1) Salmonella typhimurium strains TA98, TA100, TA1535 and TA1537 were exposed to
benzoyl chloride (purity not indicated) in acetone at concentrations of 0, 15, 30, 60, 120, 240 or
480 |ig/tube; 0, 75, 150, 300, 600 or 1200 |ig/tube; 225, 450, 900, 1800 or 3600 |ig/tube and 0,
225, 450, 900, 1800 or 3600 |ig/tube in the presence and absence of metabolic activation. The
responses of the controls were not specified. The test substance precipitated at 450|ig/tube and
was cytotoxic starting at 1200 |ig/tube. No evidence of mutagenicity was observed in any of the
strains.

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Benzoyl chloride was not mutagenic in this assay.

(2)	S. typhimurium strains TA98, TA100, TA1535, TA1537 and TA1538 and Saccharomyces
cerevisiae D4 were exposed to benzoyl chloride (purity not indicated) in DMSO at
concentrations ranging from 0.0001 to 1 |iL/plate in the presence and absence of metabolic
activation. Benzoyl chloride was cytotoxic at 1 |iL/plate. Positive control substances were
tested concurrently, but responses were not provided. No evidence of mutagenicity was
observed in any of the strains.

Benzoyl chloride was not mutagenic in this assay.

(3)	S. typhimurium strains TA98 and TA100 were exposed to benzoyl chloride (purity not
indicated) at concentrations of 0.1, 1 and 10 |imole/plate in the absence of metabolic activation.
There was a positive mutagenic response for TA98. No further details or reliability score was
provided in the robust summary.

Benzoyl chloride was mutagenic in this assay.

(4)	Escherichia coli strains H/r30R and Hs30R were exposed to benzoyl chloride (purity not
indicated). Further details were not provided. A reliability scored was not provided in the robust
summary.

Benzoyl chloride was not mutagenic in this assay.

(5)	S. typhimurium strains G46, TA98, TA100, TA1535, TA1537, C3076 and D3052 and is. coli
strains WP2 and WP2 uvrA- were exposed to benzoyl chloride (purity not provided) in the
presence and absence of metabolic activation. The gradient plate technique was used, which
results in a range of concentrations over which chemically-induced mutant colonies are present.
Benzoyl chloride was not mutagenic in any strains of S. typhimurium or E. coli in the presence
and absence of metabolic activation. A reliability score was not provided in the robust summary.
Benzoyl chloride was not mutagenic in this assay.

(6)	E. coli strains WP2 B/r try and WP2 try her and Bacillus subtillis H17(Rec+), M45 (Rec-)
were exposed to benzoyl chloride (purity not indicated) in the presence and absence of metabolic
activation. Further details were not provided. A reliability score was not provided in the robust
summary.

Benzoyl chloride was not mutagenic in this assay.

(7)	S. typhimurium strains TA98, TA100 and TA104 and is. coli strains WP2uvrA/pKM101 were
exposed to benzoyl chloride (purity not indicated) at concentrations up to 1000 |ig/plate in the
presence and absence of metabolic activation. Benzoyl chloride was mutagenic in E. coli strains
WP2uvrA/pKM101 and unspecified strains of S. typhimurium. A reliability score was not
provided in the robust summary.

Benzoyl chloride was mutagenic in this assay.

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Genetic Toxicity - Chromosomal Aberrations
In vivo

Benzoyl chloride (CASRN 98-88-4)

In a micronucleus assay, male and female mice (number and species not specified) were
administered benzoyl chloride (99.97% purity) in corn oil via oral gavage at 0 or 1750 mg/kg-
bw/day. No further details were provided. There were no indications of clastogenic effects on
the chromosomes of the bone marrow erythroblasts.

Benzoyl chloride was not clastogenic in this test.

Additional Information
Carcinogenicity

Benzoyl chloride (CASRN 98-88-4)

1)	Female Specific-Pathogen-Free (SPF) ICR mice (10/dose) were exposed via the dermal
route at 5 |iL (diluted 1:1 with benzene) or 10 |iL benzoyl chloride (purity not provided) 3
times/week for 4 weeks and 2 times/week for 39 weeks (total exposure period was 43 weeks)
and examined at necropsy for skin papillomas, skin carcinomas or lung tumors. The 5 and 10
|iL treatment groups, 2/10 and 3/10 mice had skin papillomas, skin carcinomas or lung tumors.
No details were provided on the control group that was included.

Benzoyl chloride has the potential to induce tumors in female mice in this study.

2)	Female mice Specific-Pathogen-Free (SPF) ICR mice (10/dose) were administered 10 |iL
(neat) or 5 |iL benzoyl chloride to the skin dorsal of 3-week old weanling mice with a
micropipette 3 times/week for 4 weeks, then 2 times/week for 9.8 months, after which they were
necropsied and examined for skin or lung tumors. A vehicle control group (of 30 female mice)
was treated similarly with benzene. Another group of 20 female (7-week old) mice was exposed
dermally to 2.3 |iL benzoyl chloride 2 times/week for 50 weeks (11.7 months), followed by an
observation period that ended at 18.7 months with necropsy of surviving mice. Organs and
tissues were prepared for histological examination, but the tissues examined were not specified.
There were 2/20 skin-tumors and 5/20 lung-tumors in the 7-week old treated mice. Among the
treated 3-week old mice, a skin tumor was observed in one rat in the 5|iL dose groups and
incidence of lung tumors was 0/10 and 3/10 for the 5|iL and 10 |iL doses, respectively. The
tumor incidence in the control group was 0/30 skin tumors and 2/30 lung tumors.

Benzoyl chloride has the potential to induce lung tumors in female mice in this study.

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Eye Irritation

Benzoyl chloride (CASRN 98-88-4)

(1)	Undiluted benzoyl chloride (0.1 mL, purity not indicated) was instilled into the conjunctival
sac of the right eye of five rabbits (sex and strain unspecified) for 5 minutes with the left eye
serving as the untreated controls. Eyes were rinsed after exposure. Irritation was scored up to 21
days using fluorescein. Benzoyl chloride was considered corrosive. No irritation score was
stated.

Benzoyl chloride was corrosive to rabbit eyes in this study.

(2)	Undiluted benzoyl chloride (0.1 mL, purity not indicated) was instilled into the conjunctival
sac of the right eye of three or five (not clear in the robust summary) rabbits (sex and strain
unspecified) and observed for up to 21 days. No irritation score was stated.

Benzoyl chloride was corrosive to rabbit eyes in this study.

(3)	Undiluted benzoyl chloride (100 |iL, purity not indicated) was instilled into the conjunctival
sac of one eye of two rabbits (sex and strain unspecified) and observed for up to 7 days. Severe
redness and moderate to severe chemosis were observed in the conjunctiva up to the end of the
observation period. Slight to moderate swollen and hyperemic irises and slight diffuse cornea
opacity were also observed. No irritation score was stated.

Benzoyl chloride was corrosive to rabbit eyes in this study.

Skin Irritation

Benzoyl chloride (CASRN 98-88-4)

(1)	Undiluted benzoyl chloride (0.5 mL, purity not indicated) was applied to the clipped, abraded
skin of New Zealand White rabbits (3/sex) under semi-occluded conditions for 4 hours and
assessed immediately and at 24 and 72 hours after exposure. The primary irritation index was
3.8.

Benzoyl chloride was irritating to rabbit skin in this study.

(2)	Undiluted benzoyl chloride (0.5 mL, 99.5% purity) was applied to the ears of two rabbits (sex
and strain unspecified) under occluded conditions for 24 hours. Rabbits were observed for 7
days after exposure. Severe erythema and edema were observed throughout the observation
period. Necrosis was apparent at the end of the observation period.

Benzoyl chloride was corrosive to rabbit skin in this study.

Conclusion: The acute oral and dermal toxicity of benzoyl chloride (CASRN 98-88-4) is low in
rats and rabbits, respectively. The acute inhalation toxicity of benzoyl chloride (CASRN 98-88-
4) in rats is high. A 28-day repeated-dose toxicity study showed microscopic lesions in the lung
of rats administered 0.025 mg/L/day of the supporting chemical benzoic acid (CASRN 65-85-0)
via aerosol. Three 90-day inhalation repeated-dose toxicity studies were submitted for the
supporting chemical hydrochloric acid (CASRN 7647-01-0). In the study with mice, mortality
was observed in males at 0.0149 (NOAEC not established) and moribundity in females at

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0.07496 mg/L/day. The NOAEC for systemic toxicity in female mice was 0.0298 mg/L/day. In
another study, mortality was observed in female rats at 0.0746 mg/L/day. The NOAEC for
systemic toxicity in female rats was 0.0298. In the same study histopathological inflammatory
changes of the nasal cavity was observed at > 0.0149 and 0.0298 in female and male rats
respectively. The NOAEC for local toxicity in female rats is not established and the NOAEC in
male rats is 0.0149 mg/L/day. In another study with rats rhinitis was observed in both sexes at
all concentrations. The LOAEC for local toxicity is 0.0149 mg/L/day; the NOAEC for local
toxicity is not established. In the 90-day inhalation repeated-dose toxicity studies previously
mentioned with supporting chemical hydrochloric acid (CASRN 7647-01-0), no treatment-
related effects on reproductive tissues and organs in mice and rats were observed during
histopathological examinations. No treatment-related effects were observed in dams, growth and
development of offsprings, in a four-generation developmental toxicity study with supporting
chemical benzoic acid (CASRN 65-85-0) administered via the diet. The NOAEL for maternal
and developmental toxicity is 750 mg/kg-bw/day. The Benzoyl chloride (CASRN 98-88-4)
induced gene mutations in bacteria in vitro; but did not induce chromosomal aberrations in mice
in vivo. Benzoyl chloride (CASRN 98-88-4) is corrosive to the rabbit eye and irritating and
corrosive to the rabbit skin. Benzoyl chloride has the potential to induce tumors in female mice.

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Tabic 3. Summarv Tabic of the Screening Information Data Set
as Submitted under the U.S. HPV Challenge Program -
Human Health Data

Endpoints

SPONSORED CHEMICAL
Benzoyl Chloride (CASRN 98-88-4)

SUPPORTING CHEMICAL
Hydrochloric Acid (CASRN 7647-01-0)

SUPPORTING CHEMICAL
Benzoic Acid (CASRN 65-85-0)

Acute Oral Toxicity

LDS0 (mg/kg)

= 2528
(rat)





Acute Dermal Toxicity
LDS0 (mg/kg)

> 2000
(rabbit)





Acute Inhalation Toxicity
LCS0 (mg/L)

-1.45
(rat)





Repeated-Dose Toxicity
NOAEC/LOAEC
90-Day Inhalation (mg/L)

LOAEC = 0.0149
NOAEC m;ik. = Not Established
LOAEC female = 0.0746
NOAEC io,iii,io = Not Established (mice)

LOAEC ie„,aie = 0.0746 (hdt)
NOAEC female = 0.0298 (rat)
LOAEC females a,„l,„al,s > 0.0149 a lid 0.0298
(local toxicity, rat)

LOAEC = 0.0149
NOAEC = Established (local loxicilv. rat)
(RA)

LOAEC maie = 0.0149
NOAEC maie = Not Established
LOAEC fenlale = 0.0746
NOAEC female = Not Established (mice)

LOAEC female = 0.0746 (hdt)
NOAEC female = 0.0298 (rat)

LOAEC females and males — 0.0149 and
0.0298 (local toxicity, rat)

LOAEC = 0.0149
NOAEC = Established (local toxicity,
rat)

LOAEC = 0.025
NOAEC = Not Established (rat)

Reproductive Toxicity
NOAEC/LOAEC
90-Day Inhalation (mg/L)

Reproductive Toxicity

In the 90-Dav repeated-dose toxicity
studies, no Ircalmcni-rclatcd effects on
reproductive tissues and organs in mice and
rats were observed during lvislopalhological
examinations.

(RA)

In the 90-Day repeated-dose toxicity
studies, no treatment-related effects on
reproductive tissues and organs in mice
and rats were observed during
histopathological examinations.



Developmental Toxicity
NOAEL/LOAEL
Diet (mg/kg-bw/day)

Maternal Toxicity
Developmental Toxicity

NOAEL ~ 750
NOAEL ~ 750
(rat)

(RA)



NOAEL ~ 750
NOAEL ~ 750
(rat)

Genetic Toxicity -
Gene Mutation
In vitro

Positive





Genetic Toxicity -
Chromosomal Aberrations
In vivo

Negative






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U.S. Environmental Protection Agency

Hazard Characterization Document	

Additional Information

Eye Irritation	Positive

Skin Irritation	Positive

Respiratory Tract Irritation	Positive

	Carcinogenicity Has the potential to induce tumors.

Bold = experimental data (i.e., derived from testing); (RA) = Read Across

December, 2012

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4. Hazard to the Environment

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

Acute Toxicity to Fish

Benzoyl chloride (CASRN 98-88-4)

(1)	Fathead minnow (Pimephalespromelas) were exposed to benzoyl chloride at unspecified,
measured concentrations under static conditions for 96 hours.

96-h LC50 = 34.1 mg/L

(2)	Fathead minnow (.Pimephales promelas) were exposed to benzoyl chloride at unspecified
concentrations under static conditions for 96 hours. Benzoyl chloride reacted with water in
aquatic tests producing benzoic acid and hydrochloric acid, causing an average decrease in pH to
5.2 in freshwater and detrimental effects to the biological oxygen demand.

96-h LC50 = 34.7 mg/L

Benzoic acid (CASRN 65-85-0, supporting chemical)

(1)	Bluegill (Lepomis macrochirus) were exposed to benzoic acid at nominal, unspecified
concentrations under unspecified conditions for 96 hours.

http ://www. chem .unep. ch/irptc/ sids/OECD SID S/BENZO ATES. pdf
96-h LC50 = 44.6 mg/L

(2)	Rainbow trout (Salmo gairdneri) were exposed to benzoic acid at nominal, unspecified
concentrations under unspecified conditions for 96 hours.

http ://www. chem .unep. ch/irptc/ sids/OECD SID S/BENZO ATES .pdf
96-h LC50 = 47.3 mg/L

Acute Toxicity to Aquatic Invertebrates

Benzoic acid (CASRN 65-85-0, supporting chemical)

Water fleas (Daphnia magna) were exposed to benzoic acid at unspecified concentrations under
unspecified conditions. The water was vigorously aerated and determined to have a pH of 8.45.
http ://www. chem .unep. ch/irptc/ sids/OECD SID S/BENZO ATES .pdf
48-h EC50 > 100 mg/L

Toxicity to Aquatic Plants
Benzoyl chloride (CASRN 98-88-4)

Green algae (Pseudokirchnerella subcapitata) were exposed to benzoyl chloride at nominal
concentrations of 21.3, 47.0, 103, 227, or 500 mg/L and were tested in triplicate. The test
substance was found to hydrolyze to HC1 and benzoic acid after 10 minutes in the test solution,
thus only nominal concentrations were used. The pH was not adjusted and no abnormal
development of the cells was observed. Further details of the test conditions were not provided.
http://echa.europa.eu/web/guest/information-on-chemicals/registered-substances
72-h EC50 = 96 mg/L (growth rate)


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72-h EC50 = 45 mg/L (biomass)

NOEC = 21.3 mg/L

Conclusion: For benzoyl chloride, the 96-hour LC50 for fish is 34.1 mg/L. Based on the
supporting chemical, benzoic acid, the 48-h EC50 for aquatic invertebrates is > 100 mg/L.
The72-h EC50 of benzoyl chloride for aquatic plants is 96 and 45 mg/L for growth rate and
biomass, respectively.

Table 4. Summary of Environmental Effects - Aquatic Toxicity Data

Endpoints

SPONSORED
CHEMICAL
Benzoyl Chloride
(98-88-4)

SUPPORTING
CHEMICAL
Benzoic Acid
(65-85-0)

Fish

96-h LC50 (mg/L)

34.1

46.0

Aquatic Invertebrates
48-h EC50 (mg/L)

No Data
> 100
(RA)

> 100

Aquatic Plants
72-h EC50 (mg/L)
(Growth Rate)
(Biomass)

96
45

No Adequate Data

Bold = experimental data (i.e., derived from testing); (RA) = Read Across

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