PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 SEPA December 2023 United States Office of Chemical Safety and Environmental Protection Agency Pollution Prevention Draft Risk Evaluation for Tris(2-chloroethyl) phosphate (TCEP) Systematic Review Supplemental File: Data Quality Evaluation Information for Environmental Hazard CASRN: 115-96-8 December 2023 ------- PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 This supplemental file contains information regarding the data quality evaluation results relevant to the characterization of environmental hazard for the Draft Risk Evaluation for Tris(2-chloroethyl) phosphate (TCEP). EPA conducted data quality evaluation based on author-reported descriptions and results; additional analyses (e.g., statistical analyses performed during data integration into the risk evaluation) potentially conducted by EPA are not contained in this supplemental file. EPA used the TSCA systematic review process described in the Draft Systematic Review Protocol Supporting TSCA Risk Evaluations for Chemical Substances (also referred to as '2021 Draft Systematic Review Protocol'). Any updated steps in the systematic review process since the publication of the 2021 Draft Systematic Review Protocol are described in the Draft Risk Evaluation for Tris(2-chloroethyl) Phosphate (TCEP) - Systematic Review Protocol. Different data quality evaluation forms were used depending on the organism as described in the PECO statement in Ap- pendix H.5.7 of the 2021 Draft Systematic Review Protocol. Each health outcome was evaluated independently within a given reference, therefore each reference may have more than one overall quality determination (OQD) to more appropriately reflect the quality of each health outcome and the respective hazard endpoints as described by the study authors. Some data evalua- tion forms have general additional comments presented adjacent to the OQD to add further context. No OQD is determined for each reference as a whole, if it contains data from more than one evidence stream. The table of contents lists references based on chemical, broad habitat (e.g., aquatic, terrestrial), taxa, taxonomic group, exposure duration, and health outcome (e.g., mortality) categories relevant to the endpoint being evaluated. Page 2 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Table of Contents Table of Contents HERO ID Reference Page Tris(2-chloroethyl) phosphate (TCEP) Habitat: Aquatic (freshwater) Taxa: Vertebrates Danio rerio 5164137 Alzualde, A., Behl, M., Sipes, N. S., Hsieh, J. H., Alday, A., Tice, R. R., Paules, R. S., Muriana, A., Quevedo, C. (2018). Toxicity profiling of flame retardants in zebrafish embryos using a battery of assays for developmental toxicity, neurotoxicity, cardiotoxicity and hepatotoxicity toward human relevance. Neurotoxicology and Teratology 70:40-50. 3014520 Dishaw, L. V., Hunter, D. L., Padnos, B., Padilla, S., Stapleton, H. M. (2014). Developmental Exposure to Organophosphate Flame Retardants Elicits Overt Toxicity and Alters Behavior in Early Life Stage Zebrafish (Danio rerio). Toxicological Sciences 142(2):445-454. 18 4290535 4180931 Du, Z., Wang, G., Gao, S., Wang, Z. (2015). Aryl organophosphate flame retardants induced cardiotoxicity during zebrafish embryogenesis: by disturbing expression of the transcriptional regulators. Aquatic Toxicology 161:25-32. Jarema, K. A., Hunter, D. L., Shaffer, R. M., Behl, M., Padilla, S. (2015). Acute and developmental behavioral effects of flame retardants and related chemicals in zebrafish. Neurotoxicology and Teratology 52(Pt B):194-209. 20 24 7274629 Lee, J. S., Morita, Y., Kawai, Y. K., Covaci, A., Kubota, A. (2020). Developmental circulatory failure caused by metabolites of organophos- phorus flame retardants in zebrafish, Danio rerio. Chemosphere 246:125738. 26 2953504 Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177-195. 32 5166352 Wang, G. W., Chen, H. Y., Du, Z. K., Li, J. H., Wang, Z. Y., Gao, S. X. (2017). In vivo metabolism of organophosphate flame retardants and distribution of their main metabolites in adult zebrafish. Science of the Total Environment 590:50-59. 40 3479540 Behl, M., Hsieh, J. H., Shafer, T. J., Mundy, W. R., Rice, J. R., Boyd, W. A., Freedman, J. H., Hunter, E. S., Jarema, K. A., Padilla, S., Tice, R. R. (2015). Use of alternative assays to identify and prioritize organophosphorus flame retardants for potential developmental and neurotoxicity. Neurotoxicology and Teratology 52(Pt B):181-193. 42 3014520 Dishaw, L. V., Hunter, D. L., Padnos, B., Padilla, S., Stapleton, H. M. (2014). Developmental Exposure to Organophosphate Flame Retardants Elicits Overt Toxicity and Alters Behavior in Early Life Stage Zebrafish (Danio rerio). Toxicological Sciences 142(2):445-454. 46 4180931 Jarema, K. A., Hunter, D. L., Shaffer, R. M., Behl, M., Padilla, S. (2015). Acute and developmental behavioral effects of flame retardants and related chemicals in zebrafish. Neurotoxicology and Teratology 52(Pt B):194-209. 54 5469290 Li, R., Wang, H., Mi, C., Feng, C., Zhang, L., Yang, L., Zhou, B. (2019). The adverse effect of TCIPP and TCEP on neurodevelopment of zebrafish embryos/larvae. Chemosphere 220:811-817. 56 Page 3 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Table of Contents 2953504 Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177-195. 66 5469203 Sun, L., Xu, W., Peng, T.,ao, Chen, H., Ren, L.,in, Tan, H., Xiao, D.,an, Qian, H., Fu, Z. (2016). Developmental exposure of zebrafish larvae to organophosphate flame retardants causes neurotoxicity. Neurotoxicology and Teratology 55:16-22. 75 5469243 Wu, Y., Su, G., Tang, S., Liu, W., Ma, Z., Zheng, X., Liu, H., Yu, H. (2017). The combination of in silico and in vivo approaches for the investigation of disrupting effects of tris (2-chloroethyl) phosphate (TCEP) toward core receptors of zebrafish. Chemosphere 168:122-130. 79 Oryzias latipes 4292102 Sun, L., Tan, H., Peng, T., Wang, S., Xu, W., Qian, H., Jin, Y., Fu, Z. (2016). Developmental neurotoxicity of organophosphate flame retardants in early life stages of Japanese medaka (Oryzias latipes). Environmental Toxicology and Chemistry 35(12):2931-2940. 89 Salmo gairdneri 6310866 Life Sciences Research Ltd, (1990). Fyrol CEF: Acute toxicity to rainbow trout. 99 Salmo salar 5469341 Arukwe, A., Carteny, C. C., Eggen, T. (2016). Lipid peroxidation and oxidative stress responses in juvenile salmon exposed to waterborne levels of the organophosphate compounds tris(2-butoxyethyl)- and tris(2-chloroethyl) phosphates. Journal of Toxicology and Environmen- tal Health, Part A: Current Issues 79(13-15):515-525. 103 Taxa: Invertebrates Daphnia magna 5184752 Kovacevic, V., Simpson, A. J., Simpson, M. J. (2018). Investigation of daphnia magna sub-lethal exposure to organophosphate esters in the presence of dissolved organic matter using "H NMR-based metabolomics. Metabolites 8(2):34. 105 Dugesia japonica 10064285 Zhang, S., Hagstrom, D., Hayes, P., Graham, A., Collins, E. S. (2019). Multi-behavioral endpoint testing of an 87-chemical compound library in freshwater planarians. Toxicological Sciences 167(l):26-44. 107 5469417 Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 73:54-66. 119 Habitat: Terrestrial Taxa: Vertebrates Falco sparverius Page 4 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Table of Contents 5353113 Fernie, K. J., Palace, V., Peters, L. E., Basu, N., Letcher, R. J., Karouna-Renier, N. K., Schultz, S. L., Lazarus, R. S., Rattner, B. A. (2015). Investigating endocrine and physiological parameters of captive American kestrels exposed by diet to selected organophosphate flame retardants. Environmental Science and Technology 49(12):7448-7455. 137 Gallus gallus domesticus 5165206 Stauffer Chem Co, (1981). Toxicology reports on FYROL FR-2 (volume I - II) with attachments and cover letter dated 020381. nan 8100271:#88-8100271. 143 Taxa: Invertebrates Caenorhabditis elegans 3479540 Behl, M., Hsieh, J. H., Shafer, T. J., Mundy, W. R., Rice, J. R., Boyd, W. A., Freedman, J. H., Hunter, E. S., Jarema, K. A., Padilla, S., Tice, R. R. (2015). Use of alternative assays to identify and prioritize organophosphorus flame retardants for potential developmental and neurotoxicity. Neurotoxicology and Teratology 52(Pt B):181-193. 145 3975281 Behl, M., Rice, J. R., Smith, M. V., Co, C. A., Bridge, M. F., Hsieh, J. H., Freedman, J. H., Boyd, W. A. (2016). Editor's highlight: Comparative toxicity of organophosphate flame retardants and polybrominated diphenyl ethers to Caenorhabditis elegans. Toxicological Sciences 154(2):241-252. 147 5469475 Xu, T., Li, P., Wu, S., Lei, L., He, D. (2017). Tris(2-chloroethyl) phosphate (TCEP) and tris(2-chloropropyl) phosphate (TCPP) induce locomotor deficits and dopaminergic degeneration in Caenorhabditis elegans. Toxicology Research 6(l):63-72. 153 Eisenia fetida 5469239 Yang, Y., Xiao, Y., Chang, Y., Cui, Y., Klobucar, G., Li, M. (2018). Intestinal damage, neurotoxicity and biochemical responses caused by tris (2-chloroethyl) phosphate and tricresyl phosphate on earthworm. Ecotoxicology and Environmental Safety 158:78-86. 163 Page 5 of 170 ------- PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Tris(2-chloroethyl) phosphate (TCEP) Environmental Hazard Evaluation HERO ID: 5164137 Table: 1 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Alzualde, A., Behl, M., Sipes, N. S., Hsieh, J. H., Alday, A., Tice, R. R., Paules, R. S., Muriana, A., Quevedo, C. (2018). Toxicity profiling of flame retar- dants in zebrafish embryos using a battery of assays for developmental toxicity neurotoxicity cardiotoxicity and hepatotoxicity toward human relevance. Neurotoxicology and Teratology 7040-50. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 5164137 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Tris(2-chloroethyl) phosphate (TCEP), CASRN 115-96-8 High Supplied by Sigma-Aldrich, Lot number SZBE090XV High Purity = 95.6% Domain 2: Test Design Metric 4: Negative Controls High Vehicle/Solvent control (0.5% DMSO) and positive controls were used. No negative control reported. No mortality was reported in the vehicle control so lack of negative control is expected to have minimal impact on the results. Metric 5: Negative Control Response Low Biological response was difficult to interpret. Figure 1 reported affected embryos, but not for TCEP and based on other examples, "affected embryos" was near 10% with no mortality reported. Metric 6: Randomized Allocation Low Organism allocation was not reported. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Study used well plates for experiments. Covering of well plates were not reported. Ex- Preparation posure solutions were renewed on day two. However, remaining concentration in well plate prior to renewal was not reported. Metric 8: Consistency of Exposure High Exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Medium Exposure solutions were renewed on day two. However, remaining concentration in well Concentration plate prior to renewal, and end of test concentration on day four were not reported. Metric 10: Exposure Duration and Frequency High Duration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Exposure group dosage and spacing were appropriate following a dose-range finding Spacing of Exposure Levels study. Metric 12: Testing at or Below Solubility Limit High No indications were reported that TCEP concentration were above solubility limit. The study reported precipitation of other chemicals tested. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Metric 14: Acclimatization and Pretreatment Low Conditions Embryos and life stages were adequately described. Study did not report an acclimation period. Continued on next page ... Page 6 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5164137 Table: 1 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Alzualde, A., Behl, M., Sipes, N. S., Hsieh, J. H., Alday, A., Tice, R. R., Paules, R. S., Muriana, A., Quevedo, C. (2018). Toxicity profiling of flame retar- dants in zebrafish embryos using a battery of assays for developmental toxicity neurotoxicity cardiotoxicity and hepatotoxicity toward human relevance. Neurotoxicology and Teratology 7040-50. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 5164137 Domain Metric Rating Comments Metric 15: Number of Organisms and Replicates per Group Low Number of replicates were not reported. Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment. High High High Housing and environment were appropriate for the test. Intended outcomes were reported. Assessment were consistent among groups. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High No confounding variable were reported. High Outcomes unrelated to exposure were not reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Percentage of altered and dead embryos wasused for Effective Concentration 50% (EC50) and Lethal Concentration 50% (LC50) calculations applying a nonlinear re- gression test (sigmoidal dose-response curve) using the GraphPad Prism (GraphPad Software). Low Data were not clearly presented or described, but calculated endpoints were presented in the text and discussed. High No unexpected outcomes were reported. Additional Comments: None Overall Quality Determination High Page 7 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5164137 Table: 2 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Alzualde, A., Behl, M., Sipes, N. S., Hsieh, J. H., Alday, A., Tice, R. R., Paules, R. S., Muriana, A., Quevedo, C. (2018). Toxicity profiling of flame retar- dants in zebrafish embryos using a battery of assays for developmental toxicity neurotoxicity cardiotoxicity and hepatotoxicity toward human relevance. Neurotoxicology and Teratology 7040-50. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Larvae Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5164137 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Tris(2-chloroethyl) phosphate (TCEP), CASRN 115-96-8 High Supplied by Sigma-Aldrich, Lot number SZBE090XV High Purity = 95.6% Domain 2: Test Design Metric 4: Negative Controls High Vehicle/Solvent control (0.5% DMSO) and positive controls were used. No negative control reported. No mortality was reported in the vehicle control so lack of negative control is expected to have minimal impact on the results. Metric 5: Negative Control Response Low Biological response was difficult to interpret. Figure 1 reported mortality, but not for TCEP and based on other examples, "affected embryos" was near 10% with no mortality reported. Metric 6: Randomized Allocation Low Organism allocation was not reported. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Study used well plates for experiments. Covering of well plates were not reported. Ex- Preparation posure solutions were renewed on day two. However, remaining concentration in well plate prior to renewal was not reported. Metric 8: Consistency of Exposure High Exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Low Only initial nominal exposure concentrations were reported. Concentration Metric 10: Exposure Duration and Frequency High Duration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Exposure group dosage and spacing were appropriate following a dose-range finding Spacing of Exposure Levels study. Metric 12: Testing at or Below Solubility Limit High No indications were reported that TCEP concentration were above solubility limit. The study reported precipitation of other chemicals tested. Domain 4: Test Organism Metric 13: Metric 14: Metric 15: Test Organism Characteristics High Acclimatization and Pretreatment Low Conditions Number of Organisms and Low Replicates per Group Embryos and life stages were adequately described. 10 min acclimation period was reported prior to behavior assessment (locomotor activ- ity). Number of replicates were not reported. Continued on next page ... Page 8 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5164137 Table: 2 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Alzualde, A., Behl, M., Sipes, N. S., Hsieh, J. H., Alday, A., Tice, R. R., Paules, R. S., Muriana, A., Quevedo, C. (2018). Toxicity profiling of flame retar- dants in zebrafish embryos using a battery of assays for developmental toxicity neurotoxicity cardiotoxicity and hepatotoxicity toward human relevance. Neurotoxicology and Teratology 7040-50. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Larvae Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5164137 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Housing and environment were appropriate for the test. Metric 17: Outcome Assessment Methodology High Intended outcomes were reported. Metric 18: Consistency of Outcome High Assessment were consistent among groups. Assessment. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High Design and Procedures Metric 20: Outcomes Unrelated to Exposure High No confounding variable were reported. Outcomes unrelated to exposure were not reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High The mean of the total distance moved by embryos in each group asmeasured in two- minute time bins and treated versus control groups were compared using unpaired Stu- dent's t-test. Metric 22: Reporting of Data Low Data were not clearly presented or described, but calculated endpoints were presented in the text and discussed. Metric 23: Explanation of Unexpected Outcomes High No unexpected outcomes were reported. Additional Comments: None Overall Quality Determination High Page 9 of 170 ------- PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Tris(2-chloroethyl) phosphate (TCEP) Environmental Hazard Evaluation HERO ID: 5164137 Table: 3 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Alzualde, A., Behl, M., Sipes, N. S., Hsieh, J. H., Alday, A., Tice, R. R., Paules, R. S., Muriana, A., Quevedo, C. (2018). Toxicity profiling of flame retar- dants in zebrafish embryos using a battery of assays for developmental toxicity neurotoxicity cardiotoxicity and hepatotoxicity toward human relevance. Neurotoxicology and Teratology 7040-50. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Hepatic/Liver Tris(2-chloroethyl) phosphate (TCEP) 5164137 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Tris(2-chloroethyl) phosphate (TCEP), CASRN 115-96-8 High Supplied by Sigma-Aldrich, Lot number SZBE090XV High Purity = 95.6% Domain 2: Test Design Metric 4: Negative Controls High Vehicle/Solvent control (0.5% DMSO) and positive controls were used. No negative control reported. No mortality was reported in the vehicle control so lack of negative control is expected to have minimal impact on the results. Metric 5: Negative Control Response High Biological response was difficult to interpret. Figure 1 reported affected embryos, but not for TCEP and based on other examples, "affected embryos" was near 10% with no mortality reported. Metric 6: Randomized Allocation Low Organism allocation was not reported. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Study used well plates for experiments. Covering of well plates were not reported. Ex- Preparation posure solutions were renewed on day two. However, remaining concentration in well plate prior to renewal was not reported. Metric 8: Consistency of Exposure High Exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Medium Exposure solutions were renewed on day two. However, remaining concentration in well Concentration plate prior to renewal, and end of test concentration on day four were not reported. Metric 10: Exposure Duration and Frequency High Duration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Exposure group dosage and spacing were appropriate following a dose-range finding Spacing of Exposure Levels study. Metric 12: Testing at or Below Solubility Limit High No indications were reported that TCEP concentration were above solubility limit. The study reported precipitation of other chemicals tested. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Embryos and life stages were adequately described. Metric 14: Acclimatization and Pretreatment Low Study did not report an acclimation period. Conditions Metric 15: Number of Organisms and Low Number of replicates were not reported. Replicates per Group Continued on next page ... Page 10 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5164137 Table: 3 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Alzualde, A., Behl, M., Sipes, N. S., Hsieh, J. H., Alday, A., Tice, R. R., Paules, R. S., Muriana, A., Quevedo, C. (2018). Toxicity profiling of flame retar- dants in zebrafish embryos using a battery of assays for developmental toxicity neurotoxicity cardiotoxicity and hepatotoxicity toward human relevance. Neurotoxicology and Teratology 7040-50. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Hepatic/Liver Tris(2-chloroethyl) phosphate (TCEP) 5164137 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Housing and environment were appropriate for the test. Metric 17: Outcome Assessment Methodology High Intended outcomes were reported. Metric 18: Consistency of Outcome High Assessment were consistent among groups. Assessment. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High Design and Procedures Metric 20: Outcomes Unrelated to Exposure High No confounding variable were reported. Outcomes unrelated to exposure were not reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes Low Percentage of altered and dead embryos was used for Effective Concentration 50% (EC50) and Lethal Concentration 50% (LC50) calculations applying a nonlinear re- gression test (sigmoidal dose-response curve) using the GraphPad Prism (GraphPad Software). High Data were not clearly presented or described, but calculated endpoints were presented in the text and discussed. High No unexpected outcomes were reported. Additional Comments: None Overall Quality Determination High Page 11 of 170 ------- PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Tris(2-chloroethyl) phosphate (TCEP) Environmental Hazard Evaluation HERO ID: 5164137 Table: 4 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Alzualde, A., Behl, M., Sipes, N. S., Hsieh, J. H., Alday, A., Tice, R. R., Paules, R. S., Muriana, A., Quevedo, C. (2018). Toxicity profiling of flame retar- dants in zebrafish embryos using a battery of assays for developmental toxicity neurotoxicity cardiotoxicity and hepatotoxicity toward human relevance. Neurotoxicology and Teratology 7040-50. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Cardiovascular Tris(2-chloroethyl) phosphate (TCEP) 5164137 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Tris(2-chloroethyl) phosphate (TCEP), CASRN 115-96-8 High Supplied by Sigma-Aldrich, Lot number SZBE090XV High Purity = 95.6% Domain 2: Test Design Metric 4: Negative Controls High Vehicle/Solvent control (0.5% DMSO) and positive controls were used. No negative control reported. No mortality was reported in the vehicle control so lack of negative control is expected to have minimal impact on the results. Metric 5: Negative Control Response High Biological response was difficult to interpret. Figure 1 reported affected embryos, but not for TCEP and based on other examples, "affected embryos" was near 10% with no mortality reported. Metric 6: Randomized Allocation Low Organism allocation was not reported. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Study used well plates for experiments. Covering of well plates were not reported. Ex- Preparation posure solutions were renewed on day two. However, remaining concentration in well plate prior to renewal was not reported. Metric 8: Consistency of Exposure High Exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Medium Exposure solutions were renewed on day two. However, remaining concentration in well Concentration plate prior to renewal, and end of test concentration on day four were not reported. Metric 10: Exposure Duration and Frequency High Duration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Exposure group dosage and spacing were appropriate following a dose-range finding Spacing of Exposure Levels study. Metric 12: Testing at or Below Solubility Limit High No indications were reported that TCEP concentration were above solubility limit. The study reported precipitation of other chemicals tested. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Embryos and life stages were adequately described. Metric 14: Acclimatization and Pretreatment Low Study did not report an acclimation period. Conditions Metric 15: Number of Organisms and Low Number of replicates were not reported. Replicates per Group Continued on next page ... Page 12 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5164137 Table: 4 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Alzualde, A., Behl, M., Sipes, N. S., Hsieh, J. H., Alday, A., Tice, R. R., Paules, R. S., Muriana, A., Quevedo, C. (2018). Toxicity profiling of flame retar- dants in zebrafish embryos using a battery of assays for developmental toxicity neurotoxicity cardiotoxicity and hepatotoxicity toward human relevance. Neurotoxicology and Teratology 7040-50. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Cardiovascular Tris(2-chloroethyl) phosphate (TCEP) 5164137 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Housing and environment were appropriate for the test. Metric 17: Outcome Assessment Methodology High Intended outcomes were reported. Metric 18: Consistency of Outcome High Assessment were consistent among groups. Assessment. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High Design and Procedures Metric 20: Outcomes Unrelated to Exposure High No confounding variable were reported. Outcomes unrelated to exposure were not reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes Low Percentage of altered and dead embryos was used for Effective Concentration 50% (EC50) and Lethal Concentration 50% (LC50) calculations applying a nonlinear re- gression test (sigmoidal dose-response curve) using the GraphPad Prism (GraphPad Software). High Data were not clearly presented or described, but calculated endpoints were presented in the text and discussed. High No unexpected outcomes were reported. Additional Comments: None Overall Quality Determination High Page 13 of 170 ------- PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Tris(2-chloroethyl) phosphate (TCEP) Environmental Hazard Evaluation HERO ID: 5164137 Table: 5 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Alzualde, A., Behl, M., Sipes, N. S., Hsieh, J. H., Alday, A., Tice, R. R., Paules, R. S., Muriana, A., Quevedo, C. (2018). Toxicity profiling of flame retar- dants in zebrafish embryos using a battery of assays for developmental toxicity neurotoxicity cardiotoxicity and hepatotoxicity toward human relevance. Neurotoxicology and Teratology 7040-50. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo ADME (biotransformation) Tris(2-chloroethyl) phosphate (TCEP) 5164137 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Tris(2-chloroethyl) phosphate (TCEP), CASRN 115-96-8 High Supplied by Sigma-Aldrich, Lot number SZBE090XV High Purity = 95.6% Domain 2: Test Design Metric 4: Negative Controls High Vehicle/Solvent control (0.5% DMSO) and positive controls were used. No negative control reported. No mortality was reported in the vehicle control so lack of negative control is expected to have minimal impact on the results. Metric 5: Negative Control Response High Biological response was difficult to interpret. Figure 1 reported affected embryos, but not for TCEP and based on other examples, "affected embryos" was near 10% with no mortality reported. Metric 6: Randomized Allocation Low Organism allocation was not reported. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Study used well plates for experiments. Covering of well plates were not reported. Ex- Preparation posure solutions were renewed on day two. However, remaining concentration in well plate prior to renewal was not reported. Metric 8: Consistency of Exposure High Exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Medium Exposure solutions were renewed on day two. However, remaining concentration in well Concentration plate prior to renewal, and end of test concentration on day four were not reported. Metric 10: Exposure Duration and Frequency High Duration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Exposure group dosage and spacing were appropriate following a dose-range finding Spacing of Exposure Levels study. Metric 12: Testing at or Below Solubility Limit High No indications were reported that TCEP concentration were above solubility limit. The study reported precipitation of other chemicals tested. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Embryos and life stages were adequately described. Metric 14: Acclimatization and Pretreatment Low Study did not report an acclimation period. Conditions Metric 15: Number of Organisms and Low Number of replicates were not reported. Replicates per Group Continued on next page ... Page 14 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5164137 Table: 5 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Alzualde, A., Behl, M., Sipes, N. S., Hsieh, J. H., Alday, A., Tice, R. R., Paules, R. S., Muriana, A., Quevedo, C. (2018). Toxicity profiling of flame retar- dants in zebrafish embryos using a battery of assays for developmental toxicity neurotoxicity cardiotoxicity and hepatotoxicity toward human relevance. Neurotoxicology and Teratology 7040-50. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo ADME (biotransformation) Tris(2-chloroethyl) phosphate (TCEP) 5164137 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions High Outcome Assessment Methodology High Consistency of Outcome High Assessment. Housing and environment were appropriate for the test. Intended outcomes were reported. Assessment were consistent among groups. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High Design and Procedures Metric 20: Outcomes Unrelated to Exposure High No confounding variable were reported. Outcomes unrelated to exposure were not reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes Low Percentage of altered and dead embryos was used for Effective Concentration 50% (EC50) and Lethal Concentration 50% (LC50) calculations applying a nonlinear re- gression test (sigmoidal dose-response curve) using the GraphPad Prism (GraphPad Software). High Data were not clearly presented or described, but calculated endpoints were presented in the text and discussed. High No unexpected outcomes were reported. Additional Comments: None Overall Quality Determination High Page 15 of 170 ------- PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Tris(2-chloroethyl) phosphate (TCEP) Environmental Hazard Evaluation HERO ID: 5164137 Table: 6 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Alzualde, A., Behl, M., Sipes, N. S., Hsieh, J. H., Alday, A., Tice, R. R., Paules, R. S., Muriana, A., Quevedo, C. (2018). Toxicity profiling of flame retar- dants in zebrafish embryos using a battery of assays for developmental toxicity neurotoxicity cardiotoxicity and hepatotoxicity toward human relevance. Neurotoxicology and Teratology 7040-50. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 5164137 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Tris(2-chloroethyl) phosphate (TCEP), CASRN 115-96-8 High Supplied by Sigma-Aldrich, Lot number SZBE090XV High Purity = 95.6% Domain 2: Test Design Metric 4: Negative Controls High Vehicle/Solvent control (0.5% DMSO) and positive controls were used. No negative control reported. No mortality was reported in the vehicle control so lack of negative control is expected to have minimal impact on the results. Metric 5: Negative Control Response High Biological response was difficult to interpret. Figure 1 reported affected embryos, but not for TCEP and based on other examples, "affected embryos" was near 10% with no mortality reported. Metric 6: Randomized Allocation Low Organism allocation was not reported. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Study used well plates for experiments. Covering of well plates were not reported. Ex- Preparation posure solutions were renewed on day two. However, remaining concentration in well plate prior to renewal was not reported. Metric 8: Consistency of Exposure High Exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Medium Exposure solutions were renewed on day two. However, remaining concentration in well Concentration plate prior to renewal, and end of test concentration on day four were not reported. Metric 10: Exposure Duration and Frequency High Duration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Exposure group dosage and spacing were appropriate following a dose-range finding Spacing of Exposure Levels study. Metric 12: Testing at or Below Solubility Limit High No indications were reported that TCEP concentration were above solubility limit. The study reported precipitation of other chemicals tested. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Embryos and life stages were adequately described. Metric 14: Acclimatization and Pretreatment Low Study did not report an acclimation period. Conditions Metric 15: Number of Organisms and Low Number of replicates were not reported. Replicates per Group Continued on next page ... Page 16 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5164137 Table: 6 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Alzualde, A., Behl, M., Sipes, N. S., Hsieh, J. H., Alday, A., Tice, R. R., Paules, R. S., Muriana, A., Quevedo, C. (2018). Toxicity profiling of flame retar- dants in zebrafish embryos using a battery of assays for developmental toxicity neurotoxicity cardiotoxicity and hepatotoxicity toward human relevance. Neurotoxicology and Teratology 7040-50. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 5164137 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Housing and environment were appropriate for the test. Metric 17: Outcome Assessment Methodology High Intended outcomes were reported. Metric 18: Consistency of Outcome High Assessment were consistent among groups. Assessment. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High Design and Procedures Metric 20: Outcomes Unrelated to Exposure High No confounding variable were reported. Outcomes unrelated to exposure were not reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes Low Percentage of altered and dead embryos was used for Effective Concentration 50% (EC50) and Lethal Concentration 50% (LC50) calculations applying a nonlinear re- gression test (sigmoidal dose-response curve) using the GraphPad Prism (GraphPad Software). High Data were not clearly presented or described, but calculated endpoints were presented in the text and discussed. High No unexpected outcomes were reported. Additional Comments: None Overall Quality Determination High Page 17 of 170 ------- PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Tris(2-chloroethyl) phosphate (TCEP) Environmental Hazard Evaluation HERO ID: 3014520 Table: 1 of 1 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Dishaw, L. V., Hunter, D. L., Padnos, B., Padilla, S., Stapleton, H. M. (2014). Developmental Exposure to Organophosphate Flame Retardants Elicits Overt Toxicity and Alters Behavior in Early Life Stage Zebraflsh (Danio rerio). Toxicological Sciences 142(2):445-454. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Nutritional and Metabolic Tris(2-chloroethyl) phosphate (TCEP) 3014520 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High High High The chemical substance was identified as the organophosphate flame retardant, TCEP. The test substance was obtained from a reputable chemical manufacturer. The deuter- ated TCEP internal standards were synthesized in a single lab. The test substance had a 97% purity. Domain 2: Test Design Metric 4: Negative Controls Uninformative The metabolism study compared 1 day post fertilization and 5 day post fertilization parent chemical to metabolites in embryos and larvae. No negative control reported. Metric 5: Negative Control Response Uninformative The study evaluated parent chemical to metabolite at 24 hours in embryos to levels in larvae at 5 days exposure. No negative control was used. Metric 6: Randomized Allocation Low embryos were viewed under a dissecting microscope and only healthy embryos with intact chorions were selected for use in experiments. This is a supplemental metabolite study in zebraflsh embryos. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High The experimental system and methods for preparation of test media were described in Preparation adequate detail. Metric 8: Consistency of Exposure High Details were sufficient to indicate consistency of exposure over 24 hour period for em- Administration bryos. Metric 9: Measurement of Test Substance Medium Embryos were exposed to 1 uM solution of TCEP (in 10% Hanks' balanced salt solu- Concentration tion) in glass petri dishes for 24 hours. Metric 10: Exposure Duration and Frequency High The 24-hour exposure was appropriate for this metabolism study. Metric 11: Number of Exposure Groups/ High Exposures were to a single concentration in embryos to evaluate metabolism, which was Spacing of Exposure Levels later compared with 5-day old larva metabolism. Metric 12: Testing at or Below Solubility Limit High This was a metabolism study with a single concentration (which was below the water solubility limit of TCEP). Domain 4: Test Organism Metric 13: Test Organism Characteristics Metric 14: Acclimatization and Pretreatment Conditions Low Low The test species is an established model for toxicity testing, but the authors did not re- port the the source of the zebraflsh used in the study. Controls were not used for the metabolism study, and the authors referenced Padilla et al., 2011 for details on acclimatization and pretreatment. Continued on next page . Page 18 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3014520 Table: 1 of 1 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Dishaw, L. V., Hunter, D. L., Padnos, B., Padilla, S., Stapleton, H. M. (2014). Developmental Exposure to Organophosphate Flame Retardants Elicits Overt Toxicity and Alters Behavior in Early Life Stage Zebrafish (Danio rerio). Toxicological Sciences 142(2):445-454. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Nutritional and Metabolic Tris(2-chloroethyl) phosphate (TCEP) 3014520 Domain Metric Rating Comments Metric 15: Number of Organisms and Replicates per Group Medium This embryo metabolism test used 75-95 embryos per petri dish with 3 replicates. Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment. High High High The embryos were collected from breeding tanks, washed and bleached, and healthy embryos were maintained in glass petri dishes maintained at 26C. The assessment methodology assessed metabolism after 24 hours of exposure. Outcomes were assessed consistently across exposure groups. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High High The authors did not report any variations in environmental conditions or other factors that could impact results. The authors selected for healthy, viable embryos so that there were no differences among groups that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Tissue concentrations of the parent and primary metabolites were averaged, along with a two-way ANOVA and Sidak multiple comparisons for both the embryo and larval metabolism tests. Metric 22: Reporting of Data High Data for the metabolism study for embryos and larva were presented. Metric 23: Explanation of Unexpected Outcomes High There were no unexpected outcomes for the metabolism study. Additional Comments: Metabolism study for zebrafish embryos accompanied by the larval metabolism study. Overall Quality Determination Uninformative Page 19 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4290535 Table: 1 of 2 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Du, Z., Wang, G., Gao, S., Wang, Z. (2015). Aryl organophosphate flame retardants induced cardiotoxicity during zebrafish embryogenesis: by disturbing expression of the transcriptional regulators. Aquatic Toxicology 16125-32. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB Strain; Embryo Cardiovascular Tris(2-chloroethyl) phosphate (TCEP) 4290535 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Metric 2: Metric 3: Test Substance Identity Test Substance Source Test Substance Purity High Low High toxicant identified by acronym and CAS number Sigma"Aldrich was the supplier, not analytically verified purity reported as 97% Domain 2: Test Design Metric 4: Metric 5: Metric 6: Negative Controls Negative Control Response Randomized Allocation High Medium Low suitable solvent control was used author reported strictly following OECD guidelines which, if valid, indicates that control survival was >=90% no mention of randomization reported Domain 3: Exposure Characterization Metric 7: Metric 8: Metric 9: Metric 10: Metric 11: Metric 12: Experimental System/Test Media Preparation Consistency of Exposure Administration Measurement of Test Substance Concentration Exposure Duration and Frequency Number of Exposure Groups/ Spacing of Exposure Levels Testing at or Below Solubility Limit High Medium Low High Uninformative High daily renewal is adequate not enough details provided to warrant a high rating chemical concentrations were not measured followed oecd guidelines for acute tests It was just stated that seven concentrations were used per chemical. There was no infor- mation on the test concentration used. EC50 was well below solubility limit Domain 4: Test Organism Metric 13: Metric 14: Metric 15: Test Organism Characteristics Acclimatization and Pretreatment Conditions Number of Organisms and Replicates per Group High High Medium well documented and met OEECD guidelines reasonably well documented, seemed adequate followed OECD guidelines for organism number Domain 5: Outcome Assessment Metric 16: Metric 17: Adequacy of Test Conditions Outcome Assessment Methodology High High enough documentation to verify adequacy simple and consistent methods used Continued on next page ... Page 20 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4290535 Table: 1 of 2 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Du, Z., Wang, G., Gao, S., Wang, Z. (2015). Aryl organophosphate flame retardants induced cardiotoxicity during zebrafish embryogenesis: by disturbing expression of the transcriptional regulators. Aquatic Toxicology 16125-32. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB Strain; Embryo Cardiovascular Tris(2-chloroethyl) phosphate (TCEP) 4290535 Domain Metric Rating Comments Metric 18: Consistency of Outcome Assessment Medium methods used to quantify pericardial edema were not well documented Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High High no variables were reported in the study no unexpected outcomes were reported Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High methods of calculating EC50s were reported clear reporting of EC50s no unexpected outcomes reported Additional Comments: None Overall Quality Determination Uninformative Page 21 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4290535 Table: 2 of 2 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Du, Z., Wang, G., Gao, S., Wang, Z. (2015). Aryl organophosphate flame retardants induced cardiotoxicity during zebrafish embryogenesis: by disturbing expression of the transcriptional regulators. Aquatic Toxicology 16125-32. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB Strain; Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 4290535 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Metric 2: Metric 3: Test Substance Identity Test Substance Source Test Substance Purity High Low High toxicant identified by acronym and CAS number Sigma"Aldrich was the supplier, not analytically verified purity reported as 97% Domain 2: Test Design Metric 4: Metric 5: Metric 6: Negative Controls Negative Control Response Randomized Allocation High Medium Low suitable solvent control was used author reported strictly following OECD guidelines which, if valid, indicates that control survival was >=90% no mention of randomization reported Domain 3: Exposure Characterization Metric 7: Metric 8: Metric 9: Metric 10: Metric 11: Metric 12: Experimental System/Test Media Preparation Consistency of Exposure Administration Measurement of Test Substance Concentration Exposure Duration and Frequency Number of Exposure Groups/ Spacing of Exposure Levels Testing at or Below Solubility Limit High Medium Low High Uninformative High daily renewal is adequate not enough details provided to warrant a high rating chemical concentrations were not measured followed oecd guidelines for acute tests It was just stated that seven concentrations were used per chemical. There was no infor- mation on the test concentration used LC50 was well below solubility limit Domain 4: Test Organism Metric 13: Metric 14: Metric 15: Test Organism Characteristics Acclimatization and Pretreatment Conditions Number of Organisms and Replicates per Group High High Medium well documented and met OEECD guidelines reasonably well documented, seemed adequate followed OECD guidelines for organism number Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment. High High High enough documentation to verify adequacy simple and consistent methods used simple and consistent methods used Continued on next page ... Page 22 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4290535 Table: 2 of 2 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Du, Z., Wang, G., Gao, S., Wang, Z. (2015). Aryl organophosphate flame retardants induced cardiotoxicity during zebrafish embryogenesis: by disturbing expression of the transcriptional regulators. Aquatic Toxicology 16125-32. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB Strain; Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 4290535 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High High no variables were reported in the study no unexpected outcomes were reported Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High methods of calculating LC50s were reported clear reporting of LC50s no unexpected outcomes reported Additional Comments: None Overall Quality Determination Uninformative Page 23 of 170 ------- PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Tris(2-chloroethyl) phosphate (TCEP) Environmental Hazard Evaluation HERO ID: 4180931 Table: 1 of 1 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Jarema, K. A., Hunter, D. L., Shaffer, R. M., Behl, M., Padilla, S. (2015). Acute and developmental behavioral effects of flame retardants and related chemicals in zebrafish. Neurotoxicology and Teratology 52(Pt B):194-209. Overall Duration: 4-10 days; Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type; Larvae Behavioral Tris(2-chloroethyl) phosphate (TCEP) 4180931 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Well documented in supplemental data and table 1. IUPAC name and structure provided. Low NTP is listed as supplier, Sigma-Aldrich as the manufacturer but no analytical verifica- tion was reported High Information is in supplemental data Table 1, purity of 99% reported. Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High DMSO vehicle control was used as negative control, and chlorpyrifos or heptachlor were used as positive controls. Low No report on survival or malformation rate for controls, no comparison between clean and solvent controls were reported. Medium Dose groups were randomized. "The location of each chemical concentration was ran- domized on the stock plate (96 well glass plate which mirrored the dosing on the ex- perimental plate containing the embryos/larvae), and therefore the dose groups on the experimental plate were also randomized." Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High Experimental system was explained in detail. Preparation Metric 8: Consistency of Exposure High Method for administering the test substance was reported in detail, and was consistent Administration across study groups. Metric 9: Measurement of Test Substance Low Test substance concentrations were not analytically verified. Wells were covered and Concentration sealed with Parafilm to minimize evaporation. Metric 10: Exposure Duration and Frequency High durations were based on other studies Metric 11: Number of Exposure Groups/ High Five concentrations were tested, covering an adequate range for a response. A range Spacing of Exposure Levels finding study was conducted to set the highest dose that would not cause any acute ef- fects or lethality that would confound the behavioral assessment. Metric 12: Testing at or Below Solubility Limit Medium No indication given for how solvent concentrations were chosen. Domain 4: Test Organism Metric 13: Test Organism Characteristics High "Wild type adult zebrafish (Danio rerio), undefined, outbred stock originally obtained from Aquatic Research Organisms, Hampton, NH, 03842 and EkkWill Waterlife Re- sources, Ruskin, FL 33575 were" used for egg collection. Housing conditions for adult zebrafish and procedure for collecting eggs was described in detail. Continued on next page ... Page 24 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4180931 Table: 1 of 1 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Jarema, K. A., Hunter, D. L., Shaffer, R. M., Behl, M., Padilla, S. (2015). Acute and developmental behavioral effects of flame retardants and related chemicals in zebrafish. Neurotoxicology and Teratology 52(Pt B):194-209. Overall Duration: 4-10 days; Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type; Larvae Behavioral Tris(2-chloroethyl) phosphate (TCEP) 4180931 Domain Metric Rating Comments Metric 14: Metric 15: Acclimatization and Pretreatment Conditions Number of Organisms and Replicates per Group High Medium Testing paradigm began with a 20 minute acclimation phase; all control and test organ- isms were subjected to the same pretreatment conditions. The number tested at each concentration were reported - 24 larvae per dose. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Metric 17: Outcome Assessment Methodology Metric 18: Consistency of Outcome Assessment. Medium Conditions seemed adequate for embryo development, small quantities are difficult to assess. High Well documented assessment procedure. High No deviations in assessment procedures were reported. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High No confounding variables were reported. Medium No unrelated outcomes reported downgraded because only normal larvae were assessed. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Metric 22: Reporting of Data High Metric 23: Explanation of Unexpected Outcomes Medium Well documented analysis methods. All behavioral data was presented in a reasonable manner. Downgraded because they only assessed normal larvae and none during the acclimation phase. Additional Comments: None Overall Quality Determination High Page 25 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 7274629 Table: 1 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Lee, J. S., Morita, Y., Kawai, Y. K., Covaci, A., Kubota, A. (2020). Developmental circulatory failure caused by metabolites of organophosphorus flame retardants in zebrafish, Danio rerio. Chemosphere 246125738. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Cardiovascular Tris(2-chloroethyl) phosphate (TCEP) 7274629 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Chemical was identified by name and structure presented in Figure 1. High Test substance source was identified and test substance purity was measured by MS and NMR techniques. High Purity was measured at >98% Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High DMSO controls were run concurrently. High The biological response of the negative control group was reported and reasonable for assessed outcomes Low Researchers did not report how organisms were allocated to study groups Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High The experimental system and methods for preparation of test media were described in Preparation adequate detail Metric 8: Consistency of Exposure High Details of exposure administration were reported and exposures were administered Administration consistently across study groups. Metric 9: Measurement of Test Substance Low Exposure concentrations were not measured or measurements were not reported. Concentration Metric 10: Exposure Duration and Frequency High The duration of exposure was reported and suitable for the study type Metric 11: Number of Exposure Groups/ High Concentration spacing was adequate for the developmental experiment. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High Exposure concentrations were below reported water solubility limits and a solvent was employed to further aid solubility Domain 4: Test Organism Metric 13: Test Organism Characteristics Medium Metric 14: Acclimatization and Pretreatment Low Conditions Metric 15: Number of Organisms and Medium Replicates per Group Test organism source was not stated, otherwise the organisms were described ade- quately. The study did not report whether test organisms were acclimatized and/or whether pre- treatment conditions were the same for control and exposed groups The numbers of test organisms and replicates were reported and sufficient to character- ize toxicological effects. 10 organisms per dish with 3 replicates per treatment level. Domain 5: Outcome Assessment Continued on next page ... Page 26 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 7274629 Table: 1 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Lee, J. S., Morita, Y., Kawai, Y. K., Covaci, A., Kubota, A. (2020). Developmental circulatory failure caused by metabolites of organophosphorus flame retardants in zebrafish, Danio rerio. Chemosphere 246125738. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Cardiovascular Tris(2-chloroethyl) phosphate (TCEP) 7274629 Domain Metric Rating Comments Metric 16: Adequacy of Test Conditions Medium Metric 17: Outcome Assessment Methodology High Metric 18: Consistency of Outcome High Assessment They state the embryos were reared in breeding water. There are uncertainties on whether this is the same water the adults were bred in (the assumption would be yes) and if the temperature is the same in the static test dishes as it is in the flow through tanks. The outcome assessment methodology addressed or reported the intended outcome of interest. Reduction in blood flow was measured by degree of circulation of red blood cells through a certain region of a trunk vessel. Embryos were exposed at 72 hpf and assessed for reduction in blood flow at 96h using a 0-2 grading system under an inverted microscope. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High Design and Procedures Metric 20: Outcomes Unrelated to Exposure Medium There were no reported differences among the study groups in environmental conditions or other factors that could influence the outcome assessment There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Metric 22: Reporting of Data High Metric 23: Explanation of Unexpected Outcomes High Statistical methods were adequately described Results on Blood Flow are presented in Supplemental Data Figure S2 There were no unexpected outcomes. Additional Comments: The cardiovascular outcome was chosen for this because it pertains to circulation of red blood cells and cardiac function.Data for this form are contained in Supplemental Figure S2. TCEP metabolite BCEP was also studied in this test. Overall Quality Determination High Page 27 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 7274629 Table: 2 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Lee, J. S., Morita, Y., Kawai, Y. K., Covaci, A., Kubota, A. (2020). Developmental circulatory failure caused by metabolites of organophosphorus flame retardants in zebrafish, Danio rerio. Chemosphere 246125738. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 7274629 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Chemical Structure was presented in Figure 1. Metric 2: Test Substance Source High Test substance source was identified and test substance purity was measured by MS and NMR techniques. Metric 3: Test Substance Purity High Purity was measured at >98% Domain 2: Test Design Metric 4: Negative Controls High DMSO controls were run concurrently. Metric 5: Negative Control Response High The biological response of the negative control group was reported and reasonable for assessed outcomes Metric 6: Randomized Allocation Low Random allocation was not detailed. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High The experimental system and methods for preparation of test media were described in Preparation adequate detail Metric 8: Consistency of Exposure High Details of exposure administration were reported and exposures were administered Administration consistently across study groups. Metric 9: Measurement of Test Substance Low Exposure concentrations were not measured or measurements were not reported. Concentration Metric 10: Exposure Duration and Frequency High The duration of exposure was reported and suitable for the study type Metric 11: Number of Exposure Groups/ High concentration spacing was adequate for the developmental experiment. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High Exposure concentrations were below reported water solubility limits and a solvent was employed to further aid solubility. Domain 4: Test Organism Metric 13: Test Organism Characteristics Medium Test organism source was not stated, otherwise the organisms were described ade- quately. Metric 14: Acclimatization and Pretreatment Low The study did not report whether test organisms were acclimatized and/or whether pre- Conditions treatment conditions were the same for control and exposed groups Metric 15: Number of Organisms and Medium The numbers of test organisms and replicates were reported and sufficient to character- Replicates per Group ize toxicological effects. 10 organisms per dish with 3 replicates per treatment level. Domain 5: Outcome Assessment Continued on next page ... Page 28 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 7274629 Table: 2 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Lee, J. S., Morita, Y., Kawai, Y. K., Covaci, A., Kubota, A. (2020). Developmental circulatory failure caused by metabolites of organophosphorus flame retardants in zebrafish, Danio rerio. Chemosphere 246125738. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 7274629 Domain Metric Rating Comments Metric 16: Adequacy of Test Conditions Medium Metric 17: Outcome Assessment Methodology High Metric 18: Consistency of Outcome High Assessment They state the embryos were reared in breeding water. There are uncertainties on whether this is the same water the adults were bred in (the assumption would be yes) and if the temperature is the same in the static test dishes as it is in the flow through tanks. The outcome assessment methodology addressed or reported the intended outcome of interest. Pericardial edema was assessed at different treatment levels. Embryos were exposed at 72 hpf and assessed for pericardial edema at 96h using a 0-2 grading system under an inverted microscope. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High Design and Procedures Metric 20: Outcomes Unrelated to Exposure Medium There were no reported differences among the study groups in environmental conditions or other factors that could influence the outcome assessment There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Statistical methods were adequately described High Data for exposure-related findings were presented for each treatment and control group and were adequate to determine values for the endpoint of interest High There were no unexpected outcomes. Additional Comments: Development/growth was selected because pericardial edema was being assessed as a morphological abnormality seen during an early life stagePE data are presented in Figure 4, Page 4/7. TCEP metabolite BCEP was also tested in this study. Overall Quality Determination High Page 29 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 7274629 Table: 3 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Lee, J. S., Morita, Y., Kawai, Y. K., Covaci, A., Kubota, A. (2020). Developmental circulatory failure caused by metabolites of organophosphorus flame retardants in zebrafish, Danio rerio. Chemosphere 246125738. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 7274629 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Chemical Structure was presented in Figure 1. Metric 2: Test Substance Source High Test substance source was identified and test substance purity was measured by MS and NMR techniques. Metric 3: Test Substance Purity High Purity was measured at >98% Domain 2: Test Design Metric 4: Negative Controls High DMSO controls were run concurrently. Metric 5: Negative Control Response High The biological response (mortality) of the negative control group was reported and rea- sonable for assessed outcomes Metric 6: Randomized Allocation Low Random allocation was not detailed. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High The experimental system and methods for preparation of test media were described in Preparation adequate detail Metric 8: Consistency of Exposure High Details of exposure administration were reported and exposures were administered Administration consistently across study groups. Metric 9: Measurement of Test Substance Low Exposure concentrations were not measured or measurements were not reported. Concentration Metric 10: Exposure Duration and Frequency High The duration of exposure was reported and suitable for the study type Metric 11: Number of Exposure Groups/ High concentration spacing was adequate for the developmental experiment. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High Exposure concentrations were below reported water solubility limits and a solvent was employed to further aid solubility. Domain 4: Test Organism Metric 13: Test Organism Characteristics Medium Test organism source was not stated, otherwise the organisms were described ade- quately. Metric 14: Acclimatization and Pretreatment Low The study did not report whether test organisms were acclimatized and/or whether pre- Conditions treatment conditions were the same for control and exposed groups Metric 15: Number of Organisms and Medium The numbers of test organisms and replicates were reported and sufficient to character- Replicates per Group ize toxicological effects. 10 organisms per dish with 3 replicates per treatment level. Domain 5: Outcome Assessment Continued on next page ... Page 30 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 7274629 Table: 3 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Lee, J. S., Morita, Y., Kawai, Y. K., Covaci, A., Kubota, A. (2020). Developmental circulatory failure caused by metabolites of organophosphorus flame retardants in zebrafish, Danio rerio. Chemosphere 246125738. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 7274629 Domain Metric Rating Comments Metric 16: Adequacy of Test Conditions Medium Metric 17: Outcome Assessment Methodology High Metric 18: Consistency of Outcome Medium Assessment They state the embryos were reared in breeding water. There are uncertainties on whether this is the same water the adults were bred in (the assumption would be yes) and if the temperature is the same in the static test dishes as it is in the flow through tanks. The outcome assessment methodology addressed or reported the intended outcome of interest. Pericardial edema was assessed at different treatment levels. Embryos were exposed at 72 hpf and assessed Mortality at 96h. Specific criteria for mortality (ie, heart beat, response to stimuli, etc) was not reported. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High Design and Procedures Metric 20: Outcomes Unrelated to Exposure Medium There were no reported differences among the study groups in environmental conditions or other factors that could influence the outcome assessment There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Statistical methods were adequately described High Data for exposure-related findings were presented for each treatment and control group and were adequate to determine values for the endpoint of interest High There were no unexpected outcomes. Additional Comments: This form represents the mortality observations reported in Fig 4 and Fig S2. TCEP exposures resulted in no mortality observations in the recorded data, however, mortality was reported as being recorded for all compounds in this study within the materials and methods. Overall Quality Determination High Page 31 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 1 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High The chemical is referred to by name, structure, and CASRN. Metric 2: Test Substance Source Low Source was reported but the authors did not perform analytical verification. Metric 3: Test Substance Purity High Purity is >98% and reported in Table 3. Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High A solvent control (DMSO at 0.64% ) was used. High All control responses are reported in the supplemental data PDF. Medium Although not specifically reported as "random" the process of chorion removal and distribution into well plates was automated and is detailed in: "Mandrell, David, Lisa Truong, Caleb Jephson, Mushfiqur R. Sarker, Aaron Moore, Christopher Lang, Michael T. Simonich, and Robert L. Tanguay. "Automated zebrafish chorion removal and single embryo placement: optimizing throughput of zebrafish developmental toxicity screens." Journal of laboratory automation 17, no. 1 (2012): 66-74." Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Preparation Metric 8: Consistency of Exposure High Administration Metric 9: Measurement of Test Substance Low Concentration Metric 10: Exposure Duration and Frequency High Metric 11: Number of Exposure Groups/ High Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium The exposures were static non-renewal from 6 to 120 hpf. Renewal of compounds would have been preferred. Exposures were conducted consistently among treatments and control. No verification was performed, concentrations are reported as nominal. Exposure was initiated at 6 hpf and continued till 120 hpf. The assessments at 24 and 120 hpf are appropriate to capture embryo and larval periods. Concentrations were: 64, 6.4, 0.64, 0.064, 0.0064, and 0 uM and represent a broad range of exposure concentrations. The highest concentration (64 uM) is above the solubility limit. The remaining four con- centrations are below solubility for TBBPA and TCEP. The highest two concentrations (6.4 and 64 uM) are above TPP solubility limit (solubility from final scopes for TBBPA, TPP, and TCEP are 4.1, 1.9 and 7.8 mg/L) Domain 4: Test Organism Metric 13: Test Organism Characteristics High The strain and source for broodfish was reported. Continued on next page ... Page 32 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 1 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Metric 14: Metric 15: Acclimatization and Pretreatment Conditions Number of Organisms and Replicates per Group High Medium Water quality parameters were well described and accordance with protocols under Oregon State University"s Institutional Animal Care and Use Committee. All sample size numbers for treatment and control groups are listed in the first two pages of the supplemental data PDF for this work. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium Photoperiod and temperature were reported, while other water quality conditions were not. Mortality assessment was described in the section titled "Developmental malformation evaluations" but authors did not report specific criteria for death (ie, movement, heart- beat, color, etc.). Assessment was consistent among treatments and control. Metric 17: Metric 18: Outcome Assessment Methodology Consistency of Outcome Assessment Medium High Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High Medium Nothing was reported to indicate differences in study groups based on environmental factors. No information in the study to indicate that differences were from animal attrition or Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High "Data collection was undertaken using a custom barcoding and tracking system (Ze- brafish Acquisition and Analysis Program) to facilitate reliable management of the large amounts of data collected. Statistical analyses were performed using R code with test- ing methodologies used by Truong et al. (2014) to evaluate developmental toxicity of chemicals under the ToxCast program(RCoreTeam, 2014; Truong et al., 2014). Briefly, a binomial testwas performed that calculated lowest effect levels (LELs) foreach end- point to identify incidences that exceeded a significantthreshold above controls. This test was preferable to a logisticregression as it accounted for the observed nonmonotonicity offlame retardant toxicity." High All counts of data per treatment and control group are represented in the supplemental data for each compound and time point (24 and 120 hpf). High No unexpected outcomes were reported by the authors. Additional Comments: This form is for Mortality assessment at 24 hpf for TCEP. The specific data and statistical significance for each compound are located within the supple- mental PDF. Continued on next page ... Page 33 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 1 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Overall Quality Determination High Page 34 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 2 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Behavioral Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High The chemical is referred to by name, structure, and CASRN. Metric 2: Test Substance Source Low Source was reported but the authors did not perform analytical verification. Metric 3: Test Substance Purity High Purity is >98% and reported in Table 3. Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High A solvent control (DMSO at 0.64% ) was used. High All control responses are reported in the supplemental data PDF. Medium Although not specifically reported as "random" the process of chorion removal and distribution into well plates was automated and is detailed in: "Mandrell, David, Lisa Truong, Caleb Jephson, Mushfiqur R. Sarker, Aaron Moore, Christopher Lang, Michael T. Simonich, and Robert L. Tanguay. "Automated zebrafish chorion removal and single embryo placement: optimizing throughput of zebrafish developmental toxicity screens." Journal of laboratory automation 17, no. 1 (2012): 66-74." Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Preparation Metric 8: Consistency of Exposure High Administration Metric 9: Measurement of Test Substance Low Concentration Metric 10: Exposure Duration and Frequency High Metric 11: Number of Exposure Groups/ High Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium would have been preferred. Exposures were conducted consistently among treatments and control. No verification was performed, concentrations are reported as nominal. Exposure was initiated at 6 hpf and continued till 120 hpf. The assessments at 24 and 120 hpf are appropriate to capture embryo and larval periods. Concentrations were: 64, 6.4, 0.64, 0.064, 0.0064, and 0 uM and represent a broad range of exposure concentrations. The highest concentration (64 uM) is above the solubility limit. The remaining four con- centrations are below solubility for TBBPA and TCEP. The highest two concentrations (6.4 and 64 uM) are above TPP solubility limit (solubility from final scopes for TBBPA, TPP, and TCEP are 4.1, 1.9 and 7.8 mg/L) Domain 4: Test Organism Metric 13: Test Organism Characteristics High Metric 14: Acclimatization and Pretreatment High Conditions The strain and source for broodfish was reported. Water quality parameters were well described and accordance with protocols under Oregon State University"s Institutional Animal Care and Use Committee. Continued on next page ... Page 35 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 2 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Behavioral Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Metric 15: Number of Organisms and Replicates per Group Medium All sample size numbers for treatment and control groups are listed in the first two pages of the supplemental data PDF for this work. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium Photoperiod and temperature were reported, while other water quality conditions were not. Movement assays for embryos (24 hpf) and larvae (120 hpf) were described in detail on page 7 of 19. Assessment was consistent among treatments and control. Metric 17: Metric 18: Outcome Assessment Methodology Consistency of Outcome Assessment. Medium High Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High Nothing was reported to indicate differences in study groups based on environmental factors. Medium No information in the study to indicate that differences were from animal attrition or health outcomes. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Embryo movement: "Specifically, overall patterns of activity within each cycle inter- val (ie, baseline, excitation, refractory) were compared with those in vehicle controls by (1) estimating the 50% peak difference from controls in either direction and (2) performing a Kolmogorov"Smirnov test that compared the empirical cumulative dis- tribution function between chemical treatments and controls. A Bonferroni-corrected p-value threshold of .01 (0.05/5 treatments".01) was used to determine statistical signif- icance. "Larval Movement: "As larval activity did not meet parametric assumptions of normality, Kruskal"Wallis analyses of variance and Dunn"s multiple comparison post tests were used to compare median locomotor activity per minute in treatment versus controls in each of the 5-min light/dark phases." High All raw data across time for embryo and larval movement is reported in the supplemen- tal notes (24 and 120 hpf). High No unexpected outcomes were reported by the authors. Additional Comments: This form is for embryo movement assessment at 24 hpf for TCEP. Overall Quality Determination High Page 36 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 3 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High The chemical is referred to by name, structure, and CASRN. Metric 2: Test Substance Source Low Source was reported but the authors did not perform analytical verification. Metric 3: Test Substance Purity High Purity is >98% and reported in Table 3. Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High A solvent control (DMSO at 0.64% ) was used. High All control responses are reported in the supplemental data PDF. Medium Although not specifically reported as "random" the process of chorion removal and distribution into well plates was automated and is detailed in: "Mandrell, David, Lisa Truong, Caleb Jephson, Mushfiqur R. Sarker, Aaron Moore, Christopher Lang, Michael T. Simonich, and Robert L. Tanguay. "Automated zebrafish chorion removal and single embryo placement: optimizing throughput of zebrafish developmental toxicity screens." Journal of laboratory automation 17, no. 1 (2012): 66-74." Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Preparation Metric 8: Consistency of Exposure High Administration Metric 9: Measurement of Test Substance Low Concentration Metric 10: Exposure Duration and Frequency High Metric 11: Number of Exposure Groups/ Spacing of Exposure Levels High would have been preferred. Exposures were conducted consistently among treatments and control. No verification was performed, concentrations are reported as nominal. Exposure was initiated at 6 hpf and continued till 120 hpf. The assessments at 24 and 120 hpf are appropriate to capture embryo and larval periods. 24 hour developmental assessments included: delays in developmental progression, notochord deformities, and altered spontaneous movements. 120 hour developmental assessments included: 17 de- velopmental malformations, including yolk sac edema (YSE) and pericardial edema (PE); body axis (AXIS), trunk length (TRUN), caudal fin (CFIN), pectoral fin (PFIN), pigmentation (PIG), and somite (SOMI) deformities; eye (EYE), snout (SNOU), jaw (JAW), and otolith (OTIC) malformations; gross brain development (BRAIN); noto- chord (NC) and circulatory (CIRC) deformities; swim bladder presence and inflation (SWIM); and touch responses (TR). Concentrations were: 64, 6.4, 0.64, 0.064, 0.0064, and 0 uM and represent a broad range of exposure concentrations. Continued on next page ... Page 37 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 3 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Metric 12: Testing at or Below Solubility Limit Medium The highest concentration (64 uM) is above the solubility limit. The remaining four con- centrations are below solubility for TBBPA and TCEP. The highest two concentrations (6.4 and 64 uM) are above TPP solubility limit (solubility from final scopes for TBBPA, TPP, and TCEP are 4.1, 1.9 and 7.8 mg/L) Domain 4: Test Organism Metric 13: Metric 14: Metric 15: Test Organism Characteristics Acclimatization and Pretreatment Conditions Number of Organisms and Replicates per Group High High Medium The strain and source for broodfish was reported. Water quality parameters were well described and accordance with protocols under Oregon State University"s Institutional Animal Care and Use Committee. All sample size numbers for treatment and control groups are listed in the first two pages of the supplemental data PDF for this work. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium Photoperiod and temperature were reported, while other water quality conditions were not. Developmental assessment was described in the section titled "Developmental malfor- mation evaluations". The specifc analysis is detailed in another publication that authors referenced as HERO ID 8591199 Assessment was consistent among treatments and control. Metric 17: Metric 18: Outcome Assessment Methodology Consistency of Outcome Assessment Medium High Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High Medium Nothing was reported to indicate differences in study groups based on environmental factors. No information in the study to indicate that differences were from animal attrition or health outcomes. Domain 7: Data Presentation and Analysis Continued on next page . Page 38 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 3 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Metric 21: Statistical Methods High "Data collection was undertaken using a custom barcoding and tracking system (Ze- brafish Acquisition and Analysis Program) to facilitate reliable management of the large amounts of data collected. Statistical analyses were performed using R code with test- ing methodologies used by Truong et al. (2014) to evaluate developmental toxicity of chemicals under the ToxCast program(RCoreTeam, 2014; Truong et al., 2014). Briefly, a binomial testwas performed that calculated lowest effect levels (LELs) foreach end- point to identify incidences that exceeded a significantthreshold above controls. This test was preferable to a logisticregression as it accounted for the observed nonmonotonicity offlame retardant toxicity."This reference is HERO ID 8591199 Metric 22: Reporting of Data High All counts of data per treatment and control group are represented in the supplemental data for each compound and time point (24 and 120 hpf). Metric 23: Explanation of Unexpected Outcomes High No unexpected outcomes were reported by the authors. Additional Comments: This form is for developmental assessment at 24 hpf for TCEP. The specific data and statistical significance for each compound are located within the supplemental PDF. Overall Quality Determination High Page 39 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5166352 Table: 1 of 1 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Wang, G. W., Chen, H. Y., Du, Z. K., Li, J. H., Wang, Z. Y., Gao, S. X. (2017). In vivo metabolism of organophosphate flame retardants and distribution of their main metabolites in adult zebraflsh. Science of the Total Environment 590:50-59. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 5166352 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Low High Chemical was identified by name, CAS# and structure. Details provided in Table SI. The test substance identity was not analytically verified by the performing laboratory. Chemical purity reported as >97% . Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation Low Low Low The use of a control is implied in order to calculate 96h LC 50 according to OECD 203 protocol. The biological response of the negative control groups was not reported. Researchers did not report how organisms were allocated to study groups. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Low The study provided no details on exposure media preparation for the mortality experi- Preparation ment. Metric 8: Consistency of Exposure Low The study provided no details on exposure administration for the mortality experiment. Administration Metric 9: Measurement of Test Substance Low Exposure concentrations were not measured or measurements were not reported. Concentration Metric 10: Exposure Duration and Frequency High The duration of exposure was reported (96 h) and appropriate for the study type. Metric 11: Number of Exposure Groups/ Uninformative No information is provided on the number of exposure groups and spacing of exposure Spacing of Exposure Levels levels used to determine 96h LC 50. Metric 12: Testing at or Below Solubility Limit Low Reporting omissions prevented determination of whether exposure concentrations ex- ceeded the water solubility limit. Domain 4: Test Organism Metric 13: Test Organism Characteristics Metric 14: Acclimatization and Pretreatment Conditions Metric 15: Number of Organisms and Replicates per Group Medium The test organisms were obtained from a reliable source but specifics such as average weight were not reported. Low The study did not report whether test organisms were acclimatized. Low The number of test organisms and/or replicates was not reported. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Low Environmental conditions were not sufficiently reported to evaluate if adequate and whether differences occurred between control and exposed populations. Continued on next page . Page 40 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5166352 Table: 1 of 1 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Wang, G. W., Chen, H. Y., Du, Z. K., Li, J. H., Wang, Z. Y., Gao, S. X. (2017). In vivo metabolism of organophosphate flame retardants and distribution of their main metabolites in adult zebrafish. Science of the Total Environment 590:50-59. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 5166352 Domain Metric Rating Comments Metric 17: Metric 18: Outcome Assessment Methodology Consistency of Outcome Assessment Low Low The outcome assessment methodology was not clearly reported. It was stated that the experiment was conducted according to OECD 203 but no other details were provided. Details regarding the execution of the study protocol for outcome assessment were not reported. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low Medium The study did not provide enough information to allow a comparison of environmental conditions. There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes Low Low Low Statistical analysis was performed but not described adequately. Data for exposure-related findings were not shown for each treatment and control group, but results were summarized in the text as an LC50 value. The study did not report any measures of variability. Additional Comments: LC 50 values were determined according to OECD 203 but no details (regarding test media preparation, number of exposure groups, control response, number of organisms and replicates, mortality data for each treatment group, environmental conditions, etc.) were provided. The main focus of the paper was to study in vivo metabolism of TCEP and the LC50 values were used to set up the exposure groups for the main experiment. Overall Quality Determination Uninformative Page 41 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3479540 Table: 1 of 2 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Behl, M., Hsieh, J. H., Shafer, T. J., Mundy, W. R., Rice, J. R., Boyd, W. A., Freedman, J. H., Hunter, E. S., Jarema, K. A., Padilla, S., Tice, R. R. (2015). Use of alternative assays to identify and prioritize organophosphorus flame retardants for potential developmental and neurotoxicity. Neurotoxicology and Teratology 52(PtB):181-193. Overall Duration: 4 - 10 days; Exposure Duration: 4 -10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 3479540 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Test substance was identified by name and CAS # Low Test substance source was reported as Sigma-Aldrich, but it did not appear to be ana- lyzed by the performing laboratory High Test substance purity was 98.95% Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High All treated groups were compared to a DMSO vehicle controls. Low The biological response of the negative control groups was not reported. The biological response of the positive TOCP control was reported though. Low Researchers did not report how organisms were allocated to study groups. Domain 3: Exposure Characterization Metric 7: Metric 8: Metric 9: Metric 10: Metric 11: Metric 12: Experimental System/Test Media Preparation Consistency of Exposure Administration Measurement of Test Substance Concentration Exposure Duration and Frequency Number of Exposure Groups/ Spacing of Exposure Levels Testing at or Below Solubility Limit Low DMSO solvent was used in the preparation of the test media stock solutions, but little other information was provided on preparation. The experimental system was 96 well plates with one egg per plate. High Details of exposure administration were reported and exposures were administered consistently across study groups. 5 day exposure with one day in Hanks' buffer before assessment. Low Exposure concentrations were not measured or measurements were not reported. High The duration of exposure was reported and suitable for the study type-5 day exposure with 1 day in Hanks' buffer only. Medium A concentration range of 2.12uM to 120uM was reported with a concentration interval of about 0.251ogl0 units. The exact number of exposure groups was not reported. High DMSO solvent concentration was appropriate at 0.1% (v/v) Domain 4: Test Organism Metric 13: Test Organism Characteristics Metric 14: Acclimatization and Pretreatment Conditions High The test organisms were adequately described and were obtained from a reliable source Low The study did not report whether test organisms were acclimatized Continued on next page ... Page 42 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3479540 Table: 1 of 2 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Behl, M., Hsieh, J. H., Shafer, T. J., Mundy, W. R., Rice, J. R., Boyd, W. A., Freedman, J. H., Hunter, E. S., Jarema, K. A., Padilla, S., Tice, R. R. (2015). Use of alternative assays to identify and prioritize organophosphorus flame retardants for potential developmental and neurotoxicity. Neurotoxicology and Teratology 52(PtB):181-193. Overall Duration: 4 - 10 days; Exposure Duration: 4 -10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 3479540 Domain Metric Rating Comments Metric 15: Number of Organisms and Replicates per Group Medium The numbers of test organisms and replicates were reported and sufficient to character- ize toxicological effect. 1 embryo per well/test concentration with at least 4 replicates of each concentration. Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment Low High High Environmental conditions were not sufficiently reported to evaluate if adequate. Envi- ronmental conditions of breeding adults was reported, but conditions were not reported for embryos. The outcome assessment methodology reported the intended outcome of interest Details of the outcome assessment protocol were reported, and outcomes were assessed consistently across study groups-assessment was performed 6dpf after 1 day in Hanks' buffer without test substance Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low Medium The study did not provide enough information to allow a comparison of environmental conditions or other non-treatment-related factors across study groups. There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Medium High Statistical methods were adequately described Data for exposure-related findings were presented for each treatment was reported, but no data regarding control performance was recorded. There were no unexpected outcomes Additional Comments: None Overall Quality Determination Medium Page 43 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3479540 Table: 2 of 2 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Behl, M., Hsieh, J. H., Shafer, T. J., Mundy, W. R., Rice, J. R., Boyd, W. A., Freedman, J. H., Hunter, E. S., Jarema, K. A., Padilla, S., Tice, R. R. (2015). Use of alternative assays to identify and prioritize organophosphorus flame retardants for potential developmental and neurotoxicity. Neurotoxicology and Teratology 5 2(Pt B): 181 -193. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 3479540 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Test substance was identified by name and CAS # Metric 2: Test Substance Source Low Test substance source was reported as Sigma-Aldrich, but it did not appear to be ana- lyzed by the performing laboratory Metric 3: Test Substance Purity High Test substance purity was 98.95% Domain 2: Test Design Metric 4: Negative Controls High All treated groups were compared to DMSO vehicle controls. Metric 5: Negative Control Response Low The biological response of the negative control groups was not reported. The biological response of the positive TOCP control was reported though. Metric 6: Randomized Allocation Low Researchers did not report how organisms were allocated to study groups. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Low DMSO solvent was used in the preparation of the test media stock solutions, but little Preparation other information was provided on preparation. The experimental system was 96 well plates with one egg per plate. Metric 8: Consistency of Exposure High Details of exposure administration were reported and exposures were administered Administration consistently across study groups. 5 day exposure with one day in Hanks' buffer before assessment. Metric 9: Measurement of Test Substance Low Exposure concentrations were not measured or measurements were not reported. Concentration Metric 10: Exposure Duration and Frequency High The duration of exposure was reported and suitable for the study type-5 day exposure with 1 day in Hanks' buffer only. Metric 11: Number of Exposure Groups/ Medium A concentration range of 2.12uM to 120uM was reported with a concentration interval Spacing of Exposure Levels of about 0.251ogl0 units. The exact number of exposure groups was not reported. Metric 12: Testing at or Below Solubility Limit High DMSO solvent concentration was appropriate at 0.1% (v/v) Domain 4: Test Organism Metric 13: Test Organism Characteristics High The test organisms were adequately described and were obtained from a reliable source Metric 14: Acclimatization and Pretreatment Low The study did not report whether test organisms were acclimatized Conditions Metric 15: Number of Organisms and Medium The numbers of test organisms and replicates were reported and sufficient to character- Replicates per Group ize toxicological effect. 1 embryo per well/test concentration with at least 4 replicates of each concentration. Continued on next page ... Page 44 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3479540 Table: 2 of 2 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Behl, M., Hsieh, J. H., Shafer, T. J., Mundy, W. R., Rice, J. R., Boyd, W. A., Freedman, J. H., Hunter, E. S., Jarema, K. A., Padilla, S., Tice, R. R. (2015). Use of alternative assays to identify and prioritize organophosphorus flame retardants for potential developmental and neurotoxicity. Neurotoxicology and Teratology 5 2(Pt B): 181 -193. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 3479540 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment Low High High Environmental conditions were not sufficiently reported to evaluate if adequate. Envi- ronmental conditions of breeding adults was reported, but conditions were not reported for embryos. The outcome assessment methodology reported the intended outcome of interest Details of the outcome assessment protocol were reported, and outcomes were assessed consistently across study groups-assessment was performed 6dpf after 1 day in Hanks' buffer without test substance Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low The study did not provide enough information to allow a comparison of environmental conditions or other non-treatment-related factors across study groups. Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes Uninformative Statistical analysis did not appear to be performed on mortality alone. Just percent mor- tality was reported. Furthermore, death and non-hatching were grouped together with developmental toxicity. Medium Data for exposure-related findings were presented for each treatment was reported, but no data regarding control performance was recorded. Low Variability in mortality was not provided. Additional Comments: None Overall Quality Determination Uninformative Page 45 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3014520 Table: 1 of 4 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Dishaw, L. V., Hunter, D. L., Padnos, B., Padilla, S., Stapleton, H. M. (2014). Developmental Exposure to Organophosphate Flame Retardants Elicits Overt Toxicity and Alters Behavior in Early Life Stage Zebraflsh (Danio rerio). Toxicological Sciences 142(2):445-454. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Larvae Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 3014520 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High The chemical substance was identified as the organophosphate flame retardant, TCEP. Metric 2: Test Substance Source High The test substance was obtained from a reputable chemical manufacturer. Metric 3: Test Substance Purity High The test substance had a 97% purity. Domain 2: Test Design Metric 4: Negative Controls High Study authors reported using a negative control with 10% HBSS and 0.4% DMSO. Metric 5: Negative Control Response High There were no developmental abnormalities among control fish. Metric 6: Randomized Allocation Medium Embryos were collected from multiple breeding tanks and pooled, then 1 embryo/well in 96-well plates used for exposures. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High The experimental system and methods for preparation of test media were described in Preparation adequate detail. Metric 8: Consistency of Exposure High Details were sufficient to indicate consistency of exposure over 6 days post-fertilization. Administration Metric 9: Measurement of Test Substance Medium The researchers did not measure exposure concentrations, but renewed the non-volatile Concentration test substance daily. Metric 10: Exposure Duration and Frequency Low The 6-day exposures, while informative, do not qualify for early-life stage testing, which require 30-day post hatch exposures. Metric 11: Number of Exposure Groups/ Medium The test organisms were exposed to 1/2 log increments of TCEP concentrations ranging Spacing of Exposure Levels from 0.033-100uM. Metric 12: Testing at or Below Solubility Limit High Testing was below the water solubility for TCEP. Domain 4: Test Organism Metric 13: Test Organism Characteristics Medium The test species is an established model for toxicity testing, so although the authors did not report the the source of the zebrafish used in the study, results for controls indicate that this will not have a substantial impact on results. Metric 14: Acclimatization and Pretreatment N/A The authors referenced Padilla et al., 2011 for details on acclimatization and pretreat- Conditions ment of the test organisms. Metric 15: Number of Organisms and Low The study used 8 fish/concentration in two replicates. While not adequate for OPPT Replicates per Group TG 850.1400 for fish early life-stage testing, concentration-response relationships were observed and the number was sufficient for statistical analysis. Continued on next page ... Page 46 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3014520 Table: 1 of 4 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Dishaw, L. V., Hunter, D. L., Padnos, B., Padilla, S., Stapleton, H. M. (2014). Developmental Exposure to Organophosphate Flame Retardants Elicits Overt Toxicity and Alters Behavior in Early Life Stage Zebrafish (Danio rerio). Toxicological Sciences 142(2):445-454. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Larvae Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 3014520 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High The larvae were maintained in glass petri dishes maintained at 26C. Metric 17: Outcome Assessment Methodology High The assessment methodology assessed developmental abnormalities after 6 days of exposure. Metric 18: Consistency of Outcome High Outcomes were assessed consistently across exposure groups. Assessment. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High Design and Procedures Metric 20: Outcomes Unrelated to Exposure High The authors did not report any variations in environmental conditions or other factors that could impact results. The authors did not indicate differences among groups that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Metric 22: Reporting of Data High Metric 23: Explanation of Unexpected Outcomes High Statistical analyses were adequately described for the study. Data for exposure-related findings were presented for each treatment and control group. There were no unexpected outcomes for the development study. Additional Comments: None Overall Quality Determination High Page 47 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3014520 Table: 2 of 4 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Dishaw, L. V., Hunter, D. L., Padnos, B., Padilla, S., Stapleton, H. M. (2014). Developmental Exposure to Organophosphate Flame Retardants Elicits Overt Toxicity and Alters Behavior in Early Life Stage Zebraflsh (Danio rerio). Toxicological Sciences 142(2):445-454. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Larvae Mortality Tris(2-chloroethyl) phosphate (TCEP) 3014520 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High The chemical substance was identified as the organophosphate flame retardant, TCEP. Metric 2: Test Substance Source High The test substance was obtained from a reputable chemical manufacturer. Metric 3: Test Substance Purity High The test substance had a 97% purity. Domain 2: Test Design Metric 4: Negative Controls High Study authors reported using a negative control with 10% HBSS and 0.4% DMSO. Metric 5: Negative Control Response High There was no mortality among control fish. Metric 6: Randomized Allocation Medium Embryos were collected from multiple breeding tanks and pooled, then 1 embryo/well in 96-well plates used for exposures. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High The experimental system and methods for preparation of test media were described in Preparation adequate detail. Metric 8: Consistency of Exposure High Details were sufficient to indicate consistency of exposure over 6 days post-fertilization. Administration Metric 9: Measurement of Test Substance Medium The researchers did not measure exposure concentrations, but renewed the non-volatile Concentration test substance daily. Metric 10: Exposure Duration and Frequency Low The 6-day exposures, while informative, do not qualify for early-life stage testing, which require 30-day post hatch exposures. Metric 11: Number of Exposure Groups/ Medium The test organisms were exposed to 1/2 log increments of TCEP concentrations ranging Spacing of Exposure Levels from 0.033-100uM. Metric 12: Testing at or Below Solubility Limit High Testing was below the water solubility for TCEP. Domain 4: Test Organism Metric 13: Test Organism Characteristics Medium The test species is an established model for toxicity testing, so although the authors did not report the the source of the zebrafish used in the study, results for controls indicate that this will not have a substantial impact on results. Metric 14: Acclimatization and Pretreatment Low The authors referenced Padilla et al., 2011 for details on acclimatization and pretreat- Conditions ment of the test organisms. Metric 15: Number of Organisms and Low The study used 8 fish/concentration in two replicates. While not adequate for OPPT Replicates per Group TG 850.1400 for fish early life-stage testing, concentration-response relationships were observed and the number was sufficient for statistical analysis. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High The larvae were maintained in glass petri dishes maintained at 26C. Continued on next page ... Page 48 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3014520 Table: 2 of 4 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Dishaw, L. V., Hunter, D. L., Padnos, B., Padilla, S., Stapleton, H. M. (2014). Developmental Exposure to Organophosphate Flame Retardants Elicits Overt Toxicity and Alters Behavior in Early Life Stage Zebrafish (Danio rerio). Toxicological Sciences 142(2):445-454. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Larvae Mortality Tris(2-chloroethyl) phosphate (TCEP) 3014520 Domain Metric Rating Comments Metric 17: Metric 18: Outcome Assessment Methodology Consistency of Outcome Assessment. High High The assessment methodology assessed mortality after 6 days of exposure. Outcomes were assessed consistently across exposure groups. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High Design and Procedures Metric 20: Outcomes Unrelated to Exposure High The authors did not report any variations in environmental conditions or other factors that could impact results. The authors did not indicate differences among groups that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Metric 22: Reporting of Data High Metric 23: Explanation of Unexpected Outcomes High Statistical analyses were adequately described for the study. Data for exposure-related findings were presented for each treatment and control group. There were no unexpected outcomes for the mortality study. Additional Comments: None Overall Quality Determination High Page 49 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3014520 Table: 3 of 4 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Dishaw, L. V., Hunter, D. L., Padnos, B., Padilla, S., Stapleton, H. M. (2014). Developmental Exposure to Organophosphate Flame Retardants Elicits Overt Toxicity and Alters Behavior in Early Life Stage Zebraflsh (Danio rerio). Toxicological Sciences 142(2):445-454. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Larvae Nutritional and Metabolic Tris(2-chloroethyl) phosphate (TCEP) 3014520 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High High High The chemical substance was identified as the organophosphate flame retardant, TCEP. The test substance was obtained from a reputable chemical manufacturer. The deuter- ated TCEP internal standards were synthesized in a single lab. The test substance had a 97% purity. Domain 2: Test Design Metric 4: Negative Controls Uninformative The metabolism study compared 1 day post fertilization and 5 day post fertilization parent chemical to metabolites in embryos and larvae. No negative control reported. Metric 5: Negative Control Response Uninformative The study evaluated parent chemical to metabolite at 24 hours in embryos to levels in larvae at 5 days exposure. No negative control was used. Metric 6: Randomized Allocation Low embryos were viewed under a dissecting microscope and only healthy embryos with intact chorions were selected for use in experiments. This is a supplemental metabolite study in zebraflsh embryos. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High The experimental system and methods for preparation of test media were described in Preparation adequate detail. Metric 8: Consistency of Exposure High Details were sufficient to indicate consistency of exposure over 5 days. Administration Metric 9: Measurement of Test Substance Low Larvae were exposed to 1 uM solution of TCEP in glass petri dishes for 5 days, without Concentration renewal or analytical monitoring. Metric 10: Exposure Duration and Frequency High The 5-day exposure was appropriate for this metabolism study. Metric 11: Number of Exposure Groups/ High Exposures were to a single concentration in larvae to evaluate metabolism, which was Spacing of Exposure Levels later compared with 1-day exposure in embryos. Metric 12: Testing at or Below Solubility Limit High This was a metabolism study with a single concentration (which was below the water solubility limit of TCEP). Domain 4: Test Organism Metric 13: Test Organism Characteristics Low The test species is an established model for toxicity testing, but the authors did not re- port the the source of the zebraflsh used in the study. Metric 14: Acclimatization and Pretreatment Conditions Low Controls were not used for the metabolism study, and the authors referenced Padilla et al., 2011 for details on acclimatization and pretreatment. Metric 15: Number of Organisms and Replicates per Group Medium The larval metabolism test had 3 replicates of 3 samples (20 fish per sample). Continued on next page ... Page 50 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3014520 Table: 3 of 4 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Dishaw, L. V., Hunter, D. L., Padnos, B., Padilla, S., Stapleton, H. M. (2014). Developmental Exposure to Organophosphate Flame Retardants Elicits Overt Toxicity and Alters Behavior in Early Life Stage Zebrafish (Danio rerio). Toxicological Sciences 142(2):445-454. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Larvae Nutritional and Metabolic Tris(2-chloroethyl) phosphate (TCEP) 3014520 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High The larvae were maintained in glass petri dishes maintained at 26C. Metric 17: Outcome Assessment Methodology High The assessment methodology assessed metabolism after 5 days of exposure. Metric 18: Consistency of Outcome High Outcomes were assessed consistently across exposure groups. Assessment Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High High The authors did not report any variations in environmental conditions or other factors that could impact results. The authors did not indicate differences among groups that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Tissue concentrations of the parent and primary metabolites were averaged, along with a two-way ANOVA and Sidak multiple comparisons for both the embryo and larval metabolism tests. Metric 22: Reporting of Data High Data for the metabolism study for embryos and larva were presented. Metric 23: Explanation of Unexpected Outcomes High There were no unexpected outcomes for the metabolism study. Additional Comments: Metabolism study for zebrafish embryos accompanied by the larval metabolism study. Overall Quality Determination Uninformative Page 51 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3014520 Table: 4 of 4 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Dishaw, L. V., Hunter, D. L., Padnos, B., Padilla, S., Stapleton, H. M. (2014). Developmental Exposure to Organophosphate Flame Retardants Elicits Overt Toxicity and Alters Behavior in Early Life Stage Zebraflsh (Danio rerio). Toxicological Sciences 142(2):445-454. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Larvae Behavioral Tris(2-chloroethyl) phosphate (TCEP) 3014520 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High The chemical substance was identified as the organophosphate flame retardant, TCEP. Metric 2: Test Substance Source High The test substance was obtained from a reputable chemical manufacturer. Metric 3: Test Substance Purity High The test substance had a 97% purity. Domain 2: Test Design Metric 4: Negative Controls High Study authors reported using a negative control with 10% HBSS and 0.4% DMSO. Metric 5: Negative Control Response High The control larval swimming behavior appears acceptable. Metric 6: Randomized Allocation Medium Embryos were extracted from multiple breeding tanks and pooled before cleaning and inspection for viability. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High The experimental system and methods for preparation of test media were described in Preparation adequate detail. Metric 8: Consistency of Exposure High Details were sufficient to indicate consistency of exposure over 6 days post-fertilization. Administration Metric 9: Measurement of Test Substance Medium The researchers did not measure exposure concentrations, but renewed the non-volatile Concentration test substance daily. Metric 10: Exposure Duration and Frequency Low The 6-day exposures, while informative, do not qualify for early-life stage testing, which require 30-day post hatch exposures. Metric 11: Number of Exposure Groups/ Medium The test organisms were exposed to 5 concentrations of 1/4 log increments of TCEP Spacing of Exposure Levels concentrations set below concentrations that resulted in mortality or developmental abnormalities. Metric 12: Testing at or Below Solubility Limit High Testing was below the water solubility for TCEP. Domain 4: Test Organism Metric 13: Test Organism Characteristics Medium The test species is an established model for toxicity testing, so although the authors did not report the the source of the zebrafish used in the study, results for controls indicate that this will not have a substantial impact on results. Metric 14: Acclimatization and Pretreatment Low The authors referenced Padilla et al., 2011 for details on acclimatization and pretreat- Conditions ment of the test organisms. Metric 15: Number of Organisms and Low The study used 6-12 fish/concentration with 2-4 replicates. While not adequate for Replicates per Group OPPT TG 850.1400 for fish early life-stage testing, concentration-response relationships were observed and the number was sufficient for statistical analysis. Domain 5: Outcome Assessment Continued on next page ... Page 52 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3014520 Table: 4 of 4 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Dishaw, L. V., Hunter, D. L., Padnos, B., Padilla, S., Stapleton, H. M. (2014). Developmental Exposure to Organophosphate Flame Retardants Elicits Overt Toxicity and Alters Behavior in Early Life Stage Zebrafish (Danio rerio). Toxicological Sciences 142(2):445-454. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Larvae Behavioral Tris(2-chloroethyl) phosphate (TCEP) 3014520 Domain Metric Rating Comments Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment High High High The larvae were maintained in glass petri dishes maintained at 26C. The assessment methodology assessed changes in larval swimming behavior after 6 days of exposure. Outcomes were assessed consistently across exposure groups. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High High The authors did not report any variations in environmental conditions or other factors that could impact results. The authors did not indicate differences among groups that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Metric 22: Reporting of Data High Metric 23: Explanation of Unexpected Outcomes High Statistical analyses were adequately described for the study. Data for exposure-related findings were presented for each treatment and control group. There were no unexpected outcomes for the behavioral study. Additional Comments: None Overall Quality Determination High Page 53 of 170 ------- PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Tris(2-chloroethyl) phosphate (TCEP) Environmental Hazard Evaluation HERO ID: 4180931 Table: 1 of 1 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Jarema, K. A., Hunter, D. L., Shaffer, R. M., Behl, M., Padilla, S. (2015). Acute and developmental behavioral effects of flame retardants and related chemicals in zebrafish. Neurotoxicology and Teratology 52(Pt B):194-209. Overall Duration: 4-10 days; Exposure Duration: 4 - 10 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type; Larvae Behavioral Tris(2-chloroethyl) phosphate (TCEP) 4180931 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Well documented in supplemental data and table 1. IUPAC name and structure provided. Low NTP is listed as supplier, Sigma-Aldrich as the manufacturer, purity was not analytically verified. High Information is in supplemental data, listed as 99% pure. Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High DMSO vehicle control was used as negative control, and chlorpyrifos or heptachlor were used as positive controls. Low No report on survival or malformation rate for controls, no comparison between clean and solvent controls were reported. Medium Dose groups were randomized. "The location of each chemical concentration was ran- domized on the stock plate (96 well glass plate which mirrored the dosing on the ex- perimental plate containing the embryos/larvae), and therefore the dose groups on the experimental plate were also randomized." Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High Experimental system was explained in detail. Preparation Metric 8: Consistency of Exposure High Method for administering the test substance was reported in detail, and was consistent Administration across study groups. Metric 9: Measurement of Test Substance Low Test substance concentrations were not analytically verified. Wells were covered and Concentration sealed with Parafilm to minimize evaporation. Metric 10: Exposure Duration and Frequency High durations were based on other studies Metric 11: Number of Exposure Groups/ High Five concentrations were tested, covering an adequate range for a response. A range Spacing of Exposure Levels finding study was conducted to set the highest dose that would not cause any acute ef- fects or lethality that would confound the behavioral assessment. Metric 12: Testing at or Below Solubility Limit Medium No indication given for how solvent concentrations were chosen. Domain 4: Test Organism Metric 13: Test Organism Characteristics High "Wild type adult zebrafish (Danio rerio), undefined, outbred stock originally obtained from Aquatic Research Organisms, Hampton, NH, 03842 and EkkWill Waterlife Re- sources, Ruskin, FL 33575 were" used for egg collection. Housing conditions for adult zebrafish and procedure for collecting eggs was described in detail. Continued on next page ... Page 54 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4180931 Table: 1 of 1 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Jarema, K. A., Hunter, D. L., Shaffer, R. M., Behl, M., Padilla, S. (2015). Acute and developmental behavioral effects of flame retardants and related chemicals in zebrafish. Neurotoxicology and Teratology 52(Pt B):194-209. Overall Duration: 4-10 days; Exposure Duration: 4 - 10 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type; Larvae Behavioral Tris(2-chloroethyl) phosphate (TCEP) 4180931 Domain Metric Rating Comments Metric 14: Metric 15: Acclimatization and Pretreatment Conditions Number of Organisms and Replicates per Group High Medium Treatments were reported as similar across all treatments. The number tested at each concentration were reported - 24 larvae per dose. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Metric 17: Outcome Assessment Methodology Metric 18: Consistency of Outcome Assessment. Medium Conditions seemed adequate for embryo development, small quantities are difficult to assess. High Well documented assessment procedure. High No deviations in assessment procedures were reported. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High No confounding variables were reported. Medium No unrelated outcomes reported downgraded because only normal larvae were assessed. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Well documented analysis methods High All behavioral data was presented in a reasonable manner. Medium Downgraded because they only assessed normal larvae and none during the acclimation phase. Additional Comments: None Overall Quality Determination High Page 55 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469290 Table: 1 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Li, R., Wang, H., Mi, C., Feng, C., Zhang, L., Yang, L., Zhou, B. (2019). The adverse effect of TCIPP and TCEP on neurodevelopment of zebrafish embryos/larvae. Chemosphere 220811-817. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Reproductive/Teratogenic Tris(2-chloroethyl) phosphate (TCEP) 5469290 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High TCEP identified by CAS number and name Metric 2: Test Substance Source Low TCEP was not analytically verified Metric 3: Test Substance Purity Medium 97% purity reported Domain 2: Test Design Metric 4: Negative Controls Low the solvent concentration of treatments wasn't reported Metric 5: Negative Control Response High good survival (>90% ) in controls Metric 6: Randomized Allocation Low did not report random allocation Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High adequate test system and description Preparation Metric 8: Consistency of Exposure High no inconsistencies reported between treatments Administration Metric 9: Measurement of Test Substance High test concentrations were measured Concentration Metric 10: Exposure Duration and Frequency High adequate duration to observe desired effects Metric 11: Number of Exposure Groups/ High adequate number of exposure groups to assess outcome Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High well within solubility of TCEP Domain 4: Test Organism Metric 13: Test Organism Characteristics High organisms were adequately characterized Metric 14: Acclimatization and Pretreatment High consistent pre treatment across all concentrations Conditions Metric 15: Number of Organisms and Medium four replicates were used Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium test water parameters except temperature were not reported Metric 17: Outcome Assessment Methodology Medium adequate to determine percent hatch and survival Metric 18: Consistency of Outcome High no inconsistencies were reported Assessment. Continued on next page ... Page 56 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469290 Table: 1 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: ... continued from previous page Li, R., Wang, H., Mi, C., Feng, C., Zhang, L., Yang, L., Zhou, B. (2019). The adverse effect of TCIPP and TCEP on neurodevelopment of zebrafish embryos/larvae. Chemosphere 220811-817. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Reproductive/Teratogenic Tris(2-chloroethyl) phosphate (TCEP) 5469290 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High no confounding variables were reported Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High statistical methodology was adequate for this outcome Metric 22: Reporting of Data High data reporting was reasonably clear Metric 23: Explanation of Unexpected Outcomes High no unexpected outcomes were reported Additional Comments: This evaluation form pertains to hatching rate of embryos following exposure to 0, 100, 500 or 2500 mg/L of TCEP. Overall Quality Determination High Page 57 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469290 Table: 2 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Li, R., Wang, H., Mi, C., Feng, C., Zhang, L., Yang, L., Zhou, B. (2019). The adverse effect of TCIPP and TCEP on neurodevelopment of zebrafish embryos/larvae. Chemosphere 220811-817. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Mechanistic-Biomarkers (exposure and effect)-Cell signaling/function-Neurotoxicology Tris(2-chloroethyl) phosphate (TCEP) 5469290 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High TCEP identified by CAS number and name Metric 2: Test Substance Source Low TCEP was not analytically verified Metric 3: Test Substance Purity Medium 97% purity reported Domain 2: Test Design Metric 4: Negative Controls Low the solvent concentration of treatments wasn't reported Metric 5: Negative Control Response High good survival (>90% ) in controls Metric 6: Randomized Allocation Low did not report random allocation Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High adequate test system and description Preparation Metric 8: Consistency of Exposure High no inconsistencies reported between treatments Administration Metric 9: Measurement of Test Substance High test concentrations were measured Concentration Metric 10: Exposure Duration and Frequency Medium adequate duration to observe desired effects Metric 11: Number of Exposure Groups/ High the number of exposure groups were adequate to assess this outcome Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High well within solubility of TCEP Domain 4: Test Organism Metric 13: Test Organism Characteristics High organisms were adequately characterized Metric 14: Acclimatization and Pretreatment High consistent pre treatment across all concentrations Conditions Metric 15: Number of Organisms and Medium four replicates were used Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium test water parameters except temperature were not reported Metric 17: Outcome Assessment Methodology Medium enzyme and protein determination and gene transcription methods seemed sound Metric 18: Consistency of Outcome High no inconsistencies were reported Assessment Domain 6: Confounding / Variable Control Continued on next page . Page 58 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469290 Table: 2 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: ... continued from previous page Li, R., Wang, H., Mi, C., Feng, C., Zhang, L., Yang, L., Zhou, B. (2019). The adverse effect of TCIPP and TCEP on neurodevelopment of zebrafish embryos/larvae. Chemosphere 220811-817. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Mechanistic-Biomarkers (exposure and effect)-Cell signaling/function-Neurotoxicology Tris(2-chloroethyl) phosphate (TCEP) 5469290 Domain Metric Rating Comments Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High no confounding variables were reported Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High statistical methodology was adequate for this outcome Metric 22: Reporting of Data High determinations of levels of significance seemed sound Metric 23: Explanation of Unexpected Outcomes High no unexpected outcomes were reported Additional Comments: This evaluation form pertains to mechanistic endpoints (neurotransmitter contents, AchE activity, gene transcription and protein expression) evaluated in zebrafish larvae after exposure to TCEP. Overall Quality Determination High Page 59 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469290 Table: 3 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Li, R., Wang, H., Mi, C., Feng, C., Zhang, L., Yang, L., Zhou, B. (2019). The adverse effect of TCIPP and TCEP on neurodevelopment of zebrafish embryos/larvae. Chemosphere 220811-817. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5469290 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High TCEP identified by CAS number and name Metric 2: Test Substance Source Low TCEP was not analytically verified Metric 3: Test Substance Purity Medium 97% purity reported for TCEP Domain 2: Test Design Metric 4: Negative Controls Low the solvent concentration of treatments wasn't reported Metric 5: Negative Control Response High good survival (>90% ) in controls Metric 6: Randomized Allocation Low did not report random allocation Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High adequate test system and description Preparation Metric 8: Consistency of Exposure High no inconsistencies reported between treatments Administration Metric 9: Measurement of Test Substance High test concentrations were measured Concentration Metric 10: Exposure Duration and Frequency High adequate duration to observe desired effects Metric 11: Number of Exposure Groups/ High adequate number of organisms to observe desired effects Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High well within solubility of TCEP Domain 4: Test Organism Metric 13: Test Organism Characteristics High adequately documented organism characteristics Metric 14: Acclimatization and Pretreatment High consistent pre treatment across all concentrations Conditions Metric 15: Number of Organisms and Medium four replicates were used Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium test water parameters except temperature were not reported Metric 17: Outcome Assessment Methodology Medium adequate measurements but excluding malformed organisms is concerning Metric 18: Consistency of Outcome High no inconsistencies were reported Assessment Domain 6: Confounding / Variable Control Continued on next page . Page 60 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469290 Table: 3 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Li, R., Wang, H., Mi, C., Feng, C., Zhang, L., Yang, L., Zhou, B. (2019). The adverse effect of TCIPP and TCEP on neurodevelopment of zebrafish embryos/larvae. Chemosphere 220811-817. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5469290 Domain Metric Rating Comments Metric 19: Metric 20: Confounding Variables in Test Design and Procedures Outcomes Unrelated to Exposure High Medium no confounding variables were reported There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High statistical methodology seemed sound data reporting was reasonably clear adequate explanation of difference between light and dark response Additional Comments: This evaluation form pertains to locomotor behavior measurement of zebrafish larvae. Overall Quality Determination High Page 61 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469290 Table: 4 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Li, R., Wang, H., Mi, C., Feng, C., Zhang, L., Yang, L., Zhou, B. (2019). The adverse effect of TCIPP and TCEP on neurodevelopment of zebrafish embryos/larvae. Chemosphere 220811-817. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 5469290 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High TCEP identified by CAS number and name Metric 2: Test Substance Source Low TCEP was not analytically verified Metric 3: Test Substance Purity Medium 97% purity reported for TCEP Domain 2: Test Design Metric 4: Negative Controls Low the solvent concentration of treatments wasn't reported Metric 5: Negative Control Response High good survival (>90% ) in controls Metric 6: Randomized Allocation Low did not report random allocation Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High adequate test system and description Preparation Metric 8: Consistency of Exposure High no inconsistencies reported between treatments Administration Metric 9: Measurement of Test Substance High test concentrations were reported Concentration Metric 10: Exposure Duration and Frequency Medium adequate duration to observe desired effects, not primary purpose of study Metric 11: Number of Exposure Groups/ High adequate number of exposure groups to assess outcomes Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High well within solubility of TCEP Domain 4: Test Organism Metric 13: Test Organism Characteristics High adequate documentation of organism characteristics Metric 14: Acclimatization and Pretreatment High consistent pre treatment across all concentrations Conditions Metric 15: Number of Organisms and Medium four replicates were used Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium test water parameters except temperature were not reported Metric 17: Outcome Assessment Methodology Medium type of malformations not reported Metric 18: Consistency of Outcome High no inconsistencies were noted Assessment Domain 6: Confounding / Variable Control Continued on next page . Page 62 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469290 Table: 4 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: ... continued from previous page Li, R., Wang, H., Mi, C., Feng, C., Zhang, L., Yang, L., Zhou, B. (2019). The adverse effect of TCIPP and TCEP on neurodevelopment of zebrafish embryos/larvae. Chemosphere 220811-817. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 5469290 Domain Metric Rating Comments Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High no unexpected variables were reported Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High statistical methods were adequately explained Metric 22: Reporting of Data High documentation of data reporting as adequate Metric 23: Explanation of Unexpected Outcomes High no unexplained outcomes were reported Additional Comments: This evaluation form pertains to malformation rate of embryos following exposure to 0, 100, 500 or 2500 mg/L of TCEP. Overall Quality Determination High Page 63 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469290 Table: 5 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Li, R., Wang, H., Mi, C., Feng, C., Zhang, L., Yang, L., Zhou, B. (2019). The adverse effect of TCIPP and TCEP on neurodevelopment of zebrafish embryos/larvae. Chemosphere 220811-817. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469290 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High TCEP identified by CAS number and name Metric 2: Test Substance Source Low TCEP was not analytically verified Metric 3: Test Substance Purity Medium 97% purity reported Domain 2: Test Design Metric 4: Negative Controls Low the solvent concentration of treatments wasn't reported Metric 5: Negative Control Response High good survival (>90% ) in controls Metric 6: Randomized Allocation Low did not report random allocation Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High adequate test system and description Preparation Metric 8: Consistency of Exposure High no inconsistencies reported between treatments Administration Metric 9: Measurement of Test Substance High test concentrations were measured Concentration Metric 10: Exposure Duration and Frequency High adequate duration to observe desired effects Metric 11: Number of Exposure Groups/ High adequate number of exposure groups to assess outcome Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High well within solubility of TCEP Domain 4: Test Organism Metric 13: Test Organism Characteristics High organisms were adequately characterized Metric 14: Acclimatization and Pretreatment High consistent pre treatment across all concentrations Conditions Metric 15: Number of Organisms and Medium four replicates were used Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium test water parameters except temperature were not reported Metric 17: Outcome Assessment Methodology Medium adequate to determine percent hatch and survival Metric 18: Consistency of Outcome High no inconsistencies were reported Assessment Domain 6: Confounding / Variable Control Continued on next page . Page 64 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469290 Table: 5 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Li, R., Wang, H., Mi, C., Feng, C., Zhang, L., Yang, L., Zhou, B. (2019). The adverse effect of TCIPP and TCEP on neurodevelopment of zebrafish embryos/larvae. Chemosphere 220811-817. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469290 Domain Metric Rating Comments Metric 19: Confounding Variables in Test High no confounding variables were reported Design and Procedures Metric 20: Outcomes Unrelated to Exposure High no unrelated outcomes reported Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High statistical methodology was adequate for this outcome High data reporting was reasonably clear High no unexpected outcomes were reported Additional Comments: None Overall Quality Determination High Page 65 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 1 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Behavioral Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High The chemical is referred to by name, structure, and CASRN. Metric 2: Test Substance Source Low Source was reported but the authors did not perform analytical verification. Metric 3: Test Substance Purity High Purity is >98% and reported in Table 3. Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High A solvent control (DMSO at 0.64% ) was used. High All control responses are reported in the supplemental data PDF. Medium Although not specifically reported as "random" the process of chorion removal and distribution into well plates was automated and is detailed in: "Mandrell, David, Lisa Truong, Caleb Jephson, Mushfiqur R. Sarker, Aaron Moore, Christopher Lang, Michael T. Simonich, and Robert L. Tanguay. "Automated zebrafish chorion removal and single embryo placement: optimizing throughput of zebrafish developmental toxicity screens." Journal of laboratory automation 17, no. 1 (2012): 66-74." Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Preparation Metric 8: Consistency of Exposure High Administration Metric 9: Measurement of Test Substance Low Concentration Metric 10: Exposure Duration and Frequency High Metric 11: Number of Exposure Groups/ High Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium The exposures were static non-renewal from 6 to 120 hpf. Renewal of compounds would have been preferred. Exposures were conducted consistently among treatments and control. No verification was performed, concentrations are reported as nominal. Exposure was initiated at 6 hpf and continued till 120 hpf. The assessments at 24 and 120 hpf are appropriate to capture embryo and larval periods. Concentrations were: 64, 6.4, 0.64, 0.064, 0.0064, and 0 uM and represent a broad range of exposure concentrations. The highest concentration (64 uM) is above the solubility limit. The remaining four con- centrations are below solubility for TBBPA and TCEP. The highest two concentrations (6.4 and 64 uM) are above TPP solubility limit (solubility from final scopes for TBBPA, TPP, and TCEP are 4.1, 1.9 and 7.8 mg/L) Domain 4: Test Organism Metric 13: Test Organism Characteristics High The strain and source for broodfish was reported. Continued on next page ... Page 66 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 1 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Behavioral Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Metric 14: Metric 15: Acclimatization and Pretreatment Conditions Number of Organisms and Replicates per Group High Medium Water quality parameters were well described and accordance with protocols under Oregon State University"s Institutional Animal Care and Use Committee. All sample size numbers for treatment and control groups are listed in the first two pages of the supplemental data PDF for this work. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium Photoperiod and temperature were reported, while other water quality conditions were not. Movement assays for embryos (24 hpf) and larvae (120 hpf) were described in detail on page 7 of 19. Assessment was consistent among treatments and control. Metric 17: Metric 18: Outcome Assessment Methodology Consistency of Outcome Assessment. Medium High Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High Nothing was reported to indicate differences in study groups based on environmental factors. Medium No information in the study to indicate that differences were from animal attrition or health outcomes. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Embryo movement: "Specifically, overall patterns of activity within each cycle inter- val (ie, baseline, excitation, refractory) were compared with those in vehicle controls by (1) estimating the 50% peak difference from controls in either direction and (2) performing a Kolmogorov"Smirnov test that compared the empirical cumulative dis- tribution function between chemical treatments and controls. A Bonferroni-corrected p-value threshold of .01 (0.05/5 treatments".01) was used to determine statistical signif- icance. "Larval Movement: "As larval activity did not meet parametric assumptions of normality, Kruskal"Wallis analyses of variance and Dunn"s multiple comparison post tests were used to compare median locomotor activity per minute in treatment versus controls in each of the 5-min light/dark phases." High All raw data across time for embryo and larval movement is reported in the supplemen- tal notes (24 and 120 hpf). High No unexpected outcomes were reported by the authors. Additional Comments: This form is for embryo movement assessment at 120 hpf for TCEP. Continued on next page ... Page 67 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 1 of 3 ... continued from previous page Study Citation: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Behavioral Tris(2-chloroethyl) phosphate (TCEP) 2953504 Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Domain Metric Rating Comments Overall Quality Determination High Page 68 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 2 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High The chemical is referred to by name, structure, and CASRN. Metric 2: Test Substance Source Low Source was reported but the authors did not perform analytical verification. Metric 3: Test Substance Purity High Purity is >98% and reported in Table 3. Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High A solvent control (DMSO at 0.64% ) was used. High All control responses are reported in the supplemental data PDF. Medium Although not specifically reported as "random" the process of chorion removal and distribution into well plates was automated and is detailed in: "Mandrell, David, Lisa Truong, Caleb Jephson, Mushfiqur R. Sarker, Aaron Moore, Christopher Lang, Michael T. Simonich, and Robert L. Tanguay. "Automated zebrafish chorion removal and single embryo placement: optimizing throughput of zebrafish developmental toxicity screens." Journal of laboratory automation 17, no. 1 (2012): 66-74." Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Preparation Metric 8: Consistency of Exposure High Administration Metric 9: Measurement of Test Substance Low Concentration Metric 10: Exposure Duration and Frequency High Metric 11: Number of Exposure Groups/ High Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium would have been preferred. Exposures were conducted consistently among treatments and control. No verification was performed, concentrations are reported as nominal. Exposure was initiated at 6 hpf and continued till 120 hpf. The assessments at 24 and 120 hpf are appropriate to capture embryo and larval periods. Concentrations were: 64, 6.4, 0.64, 0.064, 0.0064, and 0 uM and represent a broad range of exposure concentrations. The highest concentration (64 uM) is above the solubility limit. The remaining four con- centrations are below solubility for TBBPA and TCEP. The highest two concentrations (6.4 and 64 uM) are above TPP solubility limit (solubility from final scopes for TBBPA, TPP, and TCEP are 4.1, 1.9 and 7.8 mg/L) Domain 4: Test Organism Metric 13: Test Organism Characteristics High Metric 14: Acclimatization and Pretreatment High Conditions The strain and source for broodfish was reported. Water quality parameters were well described and accordance with protocols under Oregon State University"s Institutional Animal Care and Use Committee. Continued on next page ... Page 69 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 2 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Metric 15: Number of Organisms and Replicates per Group Medium All sample size numbers for treatment and control groups are listed in the first two pages of the supplemental data PDF for this work. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium Photoperiod and temperature were reported, while other water quality conditions were not. Mortality assessment was described in the section titled "Developmental malformation evaluations" but authors did not report specific criteria for death (ie, movement, heart- beat, color, etc.). Assessment was consistent among treatments and control. Metric 17: Metric 18: Outcome Assessment Methodology Consistency of Outcome Assessment. Medium High Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High Nothing was reported to indicate differences in study groups based on environmental factors. Medium No information in the study to indicate that differences were from animal attrition or health outcomes. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High "Data collection was undertaken using a custom barcoding and tracking system (Ze- brafish Acquisition and Analysis Program) to facilitate reliable management of the large amounts of data collected. Statistical analyses were performed using R code with test- ing methodologies used by Truong et al. (2014) to evaluate developmental toxicity of chemicals under the ToxCast program(RCoreTeam, 2014; Truong et al., 2014). Briefly, a binomial testwas performed that calculated lowest effect levels (LELs) foreach end- point to identify incidences that exceeded a significantthreshold above controls. This test was preferable to a logisticregression as it accounted for the observed nonmonotonicity offlame retardant toxicity." High All counts of data per treatment and control group are represented in the supplemental data for each compound and time point (24 and 120 hpf). High No unexpected outcomes were reported by the authors. Additional Comments: This form is for Mortality assessment at 120 hpf for TCEP. The specific data and statistical significance for each compound are located within the supplemental PDF. Continued on next page ... Page 70 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 2 of 3 ... continued from previous page Study Citation: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 2953504 Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Domain Metric Rating Comments Overall Quality Determination High Page 71 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 3 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High The chemical is referred to by name, structure, and CASRN. Metric 2: Test Substance Source Low Source was reported but the authors did not perform analytical verification. Metric 3: Test Substance Purity High Purity is >98% and reported in Table 3. Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High A solvent control (DMSO at 0.64% ) was used. High All control responses are reported in the supplemental data PDF. Medium Although not specifically reported as "random" the process of chorion removal and distribution into well plates was automated and is detailed in: "Mandrell, David, Lisa Truong, Caleb Jephson, Mushfiqur R. Sarker, Aaron Moore, Christopher Lang, Michael T. Simonich, and Robert L. Tanguay. "Automated zebrafish chorion removal and single embryo placement: optimizing throughput of zebrafish developmental toxicity screens." Journal of laboratory automation 17, no. 1 (2012): 66-74." Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Preparation Metric 8: Consistency of Exposure High Administration Metric 9: Measurement of Test Substance Low Concentration Metric 10: Exposure Duration and Frequency High Metric 11: Number of Exposure Groups/ Spacing of Exposure Levels High would have been preferred. Exposures were conducted consistently among treatments and control. No verification was performed, concentrations are reported as nominal. Exposure was initiated at 6 hpf and continued till 120 hpf. The assessments at 24 and 120 hpf are appropriate to capture embryo and larval periods. 24 hour developmental assessments included: delays in developmental progression, notochord deformities, and altered spontaneous movements. 120 hour developmental assessments included: 17 de- velopmental malformations, including yolk sac edema (YSE) and pericardial edema (PE); body axis (AXIS), trunk length (TRUN), caudal fin (CFIN), pectoral fin (PFIN), pigmentation (PIG), and somite (SOMI) deformities; eye (EYE), snout (SNOU), jaw (JAW), and otolith (OTIC) malformations; gross brain development (BRAIN); noto- chord (NC) and circulatory (CIRC) deformities; swim bladder presence and inflation (SWIM); and touch responses (TR). Concentrations were: 64, 6.4, 0.64, 0.064, 0.0064, and 0 uM and represent a broad range of exposure concentrations. Continued on next page ... Page 72 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 3 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Metric 12: Testing at or Below Solubility Limit Medium The highest concentration (64 uM) is above the solubility limit. The remaining four con- centrations are below solubility for TBBPA and TCEP. The highest two concentrations (6.4 and 64 uM) are above TPP solubility limit (solubility from final scopes for TBBPA, TPP, and TCEP are 4.1, 1.9 and 7.8 mg/L) Domain 4: Test Organism Metric 13: Metric 14: Metric 15: Test Organism Characteristics Acclimatization and Pretreatment Conditions Number of Organisms and Replicates per Group High High Medium The strain and source for broodfish was reported. Water quality parameters were well described and accordance with protocols under Oregon State University"s Institutional Animal Care and Use Committee. All sample size numbers for treatment and control groups are listed in the first two pages of the supplemental data PDF for this work. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium Photoperiod and temperature were reported, while other water quality conditions were not. Developmental assessment was described in the section titled "Developmental malfor- mation evaluations". The specifc analysis is detailed in another publication that authors referenced as HERO ID 8591199 Assessment was consistent among treatments and control. Metric 17: Metric 18: Outcome Assessment Methodology Consistency of Outcome Assessment Medium High Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High Medium Nothing was reported to indicate differences in study groups based on environmental factors. No information in the study to indicate that differences were from animal attrition or health outcomes. Domain 7: Data Presentation and Analysis Continued on next page . Page 73 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 2953504 Table: 3 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Noyes, P. D., Haggard, D. E., Gonnerman, G. D., Tanguay, R. L. (2015). Advanced morphological - behavioral test platform reveals neurodevelopmental defects in embryonic zebrafish exposed to comprehensive suite of halogenated and organophosphate flame retardants. Toxicological Sciences 145(1):177- 195. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ wild type (Tropical 5D); Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 2953504 Domain Metric Rating Comments Metric 21: Statistical Methods High "Data collection was undertaken using a custom barcoding and tracking system (Ze- brafish Acquisition and Analysis Program) to facilitate reliable management of the large amounts of data collected. Statistical analyses were performed using R code with test- ing methodologies used by Truong et al. (2014) to evaluate developmental toxicity of chemicals under the ToxCast program(RCoreTeam, 2014; Truong et al., 2014). Briefly, a binomial testwas performed that calculated lowest effect levels (LELs) foreach end- point to identify incidences that exceeded a significantthreshold above controls. This test was preferable to a logisticregression as it accounted for the observed nonmonotonicity offlame retardant toxicity."This reference is HERO ID 8591199 Metric 22: Reporting of Data High All counts of data per treatment and control group are represented in the supplemental data for each compound and time point (24 and 120 hpf). Metric 23: Explanation of Unexpected Outcomes High No unexpected outcomes were reported by the authors. Additional Comments: This form is for developmental assessment at 120 hpf for TCEP. The specific data and statistical significance for each compound are located within the supplemental PDF. Overall Quality Determination High Page 74 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469203 Table: 1 of 2 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Sun, L., Xu, W., Peng, T.,ao, Chen, H., Ren, L.,in, Tan, H., Xiao, D.,an, Qian, H., Fu, Z. (2016). Developmental exposure of zebrafish larvae to organophosphate flame retardants causes neurotoxicity. Neurotoxicology and Teratology 5516-22. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5469203 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High TCEP (CAS: 115-96-8; purity: 97% ). Metric 2: Test Substance Source Low Purchased from Sigma-Aldrich. The test substance identity was not analytically verified by the performing laboratory. Metric 3: Test Substance Purity High 97% purity reported. Domain 2: Test Design Metric 4: Negative Controls High Solvent controls were used but solvent concentration in treatments was not reported. Metric 5: Negative Control Response Low Survival response of controls not reported. "No treatment-related effects were found in the numbers of dead or malformed larvae for any chemical tested." Metric 6: Randomized Allocation Medium "The embryos (b2 h post fertilization (hpf)) were randomly transferred into individual wells of 96-well plates (Corning, NY, USA) containing 100 "L of chemical solution." Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Test vessels were not covered. Preparation Metric 8: Consistency of Exposure High Exposures were administered consistently. Administration Metric 9: Measurement of Test Substance Medium Concentrations were not measured, but no reason to believe actual concentrations dis- Concentration similar from nominal. Metric 10: Exposure Duration and Frequency High Duration and frequency were appropriate. Metric 11: Number of Exposure Groups/ High Number and spacing of groups was sufficient. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High Concentrations were below solubility values. Domain 4: Test Organism Metric 13: Test Organism Characteristics High "The zebrafish (Danio rerio) originated from the Institute of Hydrobiology of the Chi- nese Academy of Science (Wuhan, China). The fish maintenances were conducted ac- cording to the method of Westerfield (2000) with minor modification (Sun et al., 2010)" Metric 14: Acclimatization and Pretreatment High Control and treatment organisms treated similarly. Conditions Metric 15: Number of Organisms and Medium "Twenty embryos in one plate were used for one replicate, with triplicate plates for each Replicates per Group treatment." Continued on next page ... Page 75 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469203 Table: 1 of 2 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Sun, L., Xu, W., Peng, T.,ao, Chen, H., Ren, L.,in, Tan, H., Xiao, D.,an, Qian, H., Fu, Z. (2016). Developmental exposure of zebrafish larvae to organophosphate flame retardants causes neurotoxicity. Neurotoxicology and Teratology 5516-22. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5469203 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Metric 17: Outcome Assessment Methodology Metric 18: Consistency of Outcome Assessment. Medium No details of test conditions were reported, but followed procedures from published peer-reviewed studies. "The fishmaintenances were conducted according to the method of Westerfield (2000) with minor modification (Sun et al., 2010)." High Methods were reported for the outcomes of interest, "...the locomotor activity was mea- sured by the Zebralab Video-track system..." High No inconsistencies were noted. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low Environmental conditions and attrition were not reported. Medium No information to suggest differences among groups Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High Statistical methods clearly described. "Data were checked for normality and homo- geneity of variance before conducting statistical comparison. As the assumptions were met,the data were subjected to one-way analysis of variance (ANOVA)followed by Dun- nett's post hoc test" Data was reported in a reasonably clear manner. No unexpected outcomes were reported Additional Comments: This evaluation is for the behavioral outcome measured in zebrafish larvae following exposure to TCEP. Overall Quality Determination High Page 76 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469203 Table: 2 of 2 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Sun, L., Xu, W., Peng, T.,ao, Chen, H., Ren, L.,in, Tan, H., Xiao, D.,an, Qian, H., Fu, Z. (2016). Developmental exposure of zebrafish larvae to organophosphate flame retardants causes neurotoxicity. Neurotoxicology and Teratology 5516-22. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Mechanistic-Biomarkers (exposure and effect)-Cell signaling/function-Neurotoxicology Tris(2-chloroethyl) phosphate (TCEP) 5469203 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High TCEP (CAS: 115-96-8; purity: 97% ). Metric 2: Test Substance Source Low Purchased from Sigma-Aldrich but the test substance identity was NOT analytically verified by the performing laboratory. Metric 3: Test Substance Purity High 97% purity reported. Domain 2: Test Design Metric 4: Negative Controls High Solvent controls were used but solvent concentration in treatments was not reported. Metric 5: Negative Control Response Low Survival response of controls not reported. "No treatment-related effects were found in the numbers of dead or malformed larvae for any chemical tested." Metric 6: Randomized Allocation Medium "The embryos (b2 h post fertilization (hpf)) were randomly transferred into individual wells of 96-well plates (Corning, NY, USA) containing 100 "L of chemical solution." Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Test vessels were not covered. Preparation Metric 8: Consistency of Exposure High Exposures were administered consistently. Administration Metric 9: Measurement of Test Substance Medium Concentrations were not measured, but no reason to believe actual concentrations dis- Concentration similar from nominal. Metric 10: Exposure Duration and Frequency High Duration and frequency were appropriate. Metric 11: Number of Exposure Groups/ High Number and spacing of groups was sufficient. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High Concentrations were below solubility values. Domain 4: Test Organism Metric 13: Test Organism Characteristics High "The zebrafish (Danio rerio) originated from the Institute of Hydrobiology of the Chi- nese Academy of Science (Wuhan, China). The fish maintenances were conducted ac- cording to the method of Westerfield (2000) with minor modification (Sun et al., 2010)" Metric 14: Acclimatization and Pretreatment High Control and treatment organisms treated similarly. Conditions Metric 15: Number of Organisms and Medium "Twenty embryos in one plate were used for one replicate, with triplicate plates for each Replicates per Group treatment." Domain 5: Outcome Assessment Continued on next page ... Page 77 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469203 Table: 2 of 2 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Sun, L., Xu, W., Peng, T.,ao, Chen, H., Ren, L.,in, Tan, H., Xiao, D.,an, Qian, H., Fu, Z. (2016). Developmental exposure of zebrafish larvae to organophosphate flame retardants causes neurotoxicity. Neurotoxicology and Teratology 5516-22. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ Embryo Mechanistic-Biomarkers (exposure and effect)-Cell signaling/function-Neurotoxicology Tris(2-chloroethyl) phosphate (TCEP) 5469203 Domain Metric Rating Comments Metric 16: Adequacy of Test Conditions Medium No details of test conditions were reported, but followed procedures from published peer-reviewed studies. "The fishmaintenances were conducted according to the method of Westerfield (2000) with minor modification (Sun et al., 2010)." Metric 17: Outcome Assessment Methodology High Outcome assessment methodologies for AChE activity measurements and gene tran- scription were provided in detail. Metric 18: Consistency of Outcome High No inconsistencies were noted. Assessment Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Low Environmental conditions and attrition were not reported. Design and Procedures Metric 20: Outcomes Unrelated to Exposure Medium No information to suggest differences among groups Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Statistical methods clearly described. "Data were checked for normality and homo- geneity of variance before conducting statistical comparison. As the assumptions were met,the data were subjected to one-way analysis of variance (ANOVA)followed by Dun- nett's post hoc test" Metric 22: Reporting of Data High Data was reported in a reasonably clear manner. Metric 23: Explanation of Unexpected Outcomes High No unexpected outcomes were reported Additional Comments: This evaluation form is for the mechanistic data (AChE activity and gene transcription) in the reference. Overall Quality Determination High Page 78 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469243 Table: 1 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Wu, Y., Su, G., Tang, S., Liu, W., Ma, Z., Zheng, X., Liu, H., Yu, H. (2017). The combination of in silico and in vivo approaches for the investigation of disrupting effects of tris (2-chloroethyl) phosphate (TCEP) toward core receptors of zebraflsh. Chemosphere 168:122-130. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 5469243 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High TCEP was purchased from AccuStandard (100% , AccuStandardlnc., CT, USA). Metric 2: Test Substance Source Low percent purity was not analytically verified Metric 3: Test Substance Purity High reported as 100% purity Domain 2: Test Design Metric 4: Negative Controls High vehicle control reported with 0.1% DMSO Metric 5: Negative Control Response High control mortality was <= 8.3% Metric 6: Randomized Allocation Medium embryos were randomly distributed Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High documentation was adequate for this test system Preparation Metric 8: Consistency of Exposure High no inconsistencies were noted Administration Metric 9: Measurement of Test Substance Medium concentrations were measured but results were reported as log concentrations. "Based Concentration on the preliminary test, a gradient of nominal concentrationswas chosen (2.85, 28.5, 285, 14,250 and 28,500 mg/L, equalto 0.01, 0.1, 1, 50 and 100 mM, respectively)." Metric 10: Exposure Duration and Frequency High 3 to 120-h post fertilization Metric 11: Number of Exposure Groups/ High a wide range of concentrations was reported Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High the use of DMSO should be adequate to ensure the highest concentrations were fully dissolved Domain 4: Test Organism Metric 13: Test Organism Characteristics High age and source of organisms seemed satisfactory, although genus species was not spec- ified by study authorsage and source of organisms seemed satisfactory"Adult zebrafish (4 months old, AB wild-type) were obtainedfrom the Institute of Hydrobiology, Chinese Academy of Sciences" Metric 14: Acclimatization and Pretreatment Medium pretreatment was not well documented but it was adequate Conditions Metric 15: Number of Organisms and Medium three replicates were used Replicates per Group Continued on next page ... Page 79 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469243 Table: 1 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Wu, Y., Su, G., Tang, S., Liu, W., Ma, Z., Zheng, X., Liu, H., Yu, H. (2017). The combination of in silico and in vivo approaches for the investigation of disrupting effects of tris (2-chloroethyl) phosphate (TCEP) toward core receptors of zebrafish. Chemosphere 168:122-130. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 5469243 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment Medium Low High minimal documentation of exposure water conditions malformations were not well quantified observations were made at multiple durations for all concentrations Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High High no variables were reported no unrelated outcomes reported Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes Low Low High malformations were not statistically analyzed data was reported in the form of typical images and in text but not quantified no unexpected outcomes reported Additional Comments: None Overall Quality Determination High Page 80 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469243 Table: 2 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Wu, Y., Su, G., Tang, S., Liu, W., Ma, Z., Zheng, X., Liu, H., Yu, H. (2017). The combination of in silico and in vivo approaches for the investigation of disrupting effects of tris (2-chloroethyl) phosphate (TCEP) toward core receptors of zebraflsh. Chemosphere 168:122-130. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Mechanistic-Biomarkers (exposure and effect)-Cell signaling/function Tris(2-chloroethyl) phosphate (TCEP) 5469243 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Metric 2: Metric 3: Test Substance Identity Test Substance Source Test Substance Purity High Low High TCEP was purchased from AccuStandard (100% , AccuStandardlnc., CT, USA), percent purity was not analytically verified reported as 100% purity'TCEP was purchased from AccuStandard (100% , AccuStan- dardlnc., CT, USA)." Domain 2: Test Design Metric 4: Metric 5: Metric 6: Negative Controls Negative Control Response Randomized Allocation High High Medium vehicle control reported with 0.1% DMSO control mortality was <= 8.3% embryos were randomly distributed Domain 3: Exposure Characterization Metric 7: Metric 8: Metric 9: Metric 10: Metric 11: Experimental System/Test Media Preparation Consistency of Exposure Administration Measurement of Test Substance Concentration Exposure Duration and Frequency Number of Exposure Groups/ Spacing of Exposure Levels High High Medium High High documentation was adequate for this test system no inconsistencies were noted concentrations were measured but results were reported as log concentrations 3 to 120-h post fertilization a wide range of concentrations was reported "Expression of genes associated with es- trogen receptor in zebraflsh larvae (120hpf) exposure to 2.85, 28.5 and 285 mg TCEP/ L " Metric 12: Testing at or Below Solubility Limit High the use of DMSO should be adequate to ensure the highest concentrations were fully dissolved Domain 4: Test Organism Metric 13: Metric 14: Metric 15: Test Organism Characteristics Acclimatization and Pretreatment Conditions Number of Organisms and Replicates per Group High Medium Medium age and source of organisms seemed satisfactory pretreatment was not well documented but it was adequate three replicates were used Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium minimal documentation of exposure water conditions Continued on next page ... Page 81 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469243 Table: 2 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: ... continued from previous page Wu, Y., Su, G., Tang, S., Liu, W., Ma, Z., Zheng, X., Liu, H., Yu, H. (2017). The combination of in silico and in vivo approaches for the investigation of disrupting effects of tris (2-chloroethyl) phosphate (TCEP) toward core receptors of zebrafish. Chemosphere 168:122-130. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Mechanistic-Biomarkers (exposure and effect)-Cell signaling/function Tris(2-chloroethyl) phosphate (TCEP) 5469243 Domain Metric Rating Comments Metric 17: Outcome Assessment Methodology High assessment of endocrine gene expression was adequateThere were some concerns, how- ever, regarding the different responses among exposure concentrations. Three concentra- tions of TCEP/L were asssessed, 2.85, 28.5, and 285 ug TCEP/L. Results for the vtg2, pgr, ncoal, ncoa3, er2b, vtgl, and erl indicated a greater response for 2.85 and 285 ug TCEP/L than the middle 28.5 concentration. The authors did not provide a rationale as to why this may have occurred. Metric 18: Consistency of Outcome Assessment. High no inconsistencies were reported Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High no confounding variables were reported High no unrelated outcomes reported Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High "Key receptor pathway analysis was conducted according to a previous study (Liu et al., 2015). The resulting network genes (nodes) were colored by the Enhanced Graphics application within Cytoscape v3.1.1 (Cytoscape consortium, San Diego, CA, USA) according to the significant changes in gene expression in the respective treatments." data was clearly reported graphically and in text no unexpected outcomes reported Additional Comments: Due higher responses seen at the highest 285 ug TCEP/L and lowest 2.85 ug TCEP/L concentrations compared to the middle 28.5 ug TCEP/L concentra- tions, it is not clear which concentration is responsible for the effect seen. Overall Quality Determination High Page 82 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469243 Table: 3 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Wu, Y., Su, G., Tang, S., Liu, W., Ma, Z., Zheng, X., Liu, H., Yu, H. (2017). The combination of in silico and in vivo approaches for the investigation of disrupting effects of tris (2-chloroethyl) phosphate (TCEP) toward core receptors of zebraflsh. Chemosphere 168:122-130. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Endocrine Tris(2-chloroethyl) phosphate (TCEP) 5469243 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Metric 2: Metric 3: Test Substance Identity Test Substance Source Test Substance Purity High Low High TCEP was purchased from AccuStandard (100% , AccuStandardlnc., CT, USA), percent purity was not analytically verified reported as 100% purity'TCEP was purchased from AccuStandard (100% , AccuStan- dardlnc., CT, USA)." Domain 2: Test Design Metric 4: Metric 5: Metric 6: Negative Controls Negative Control Response Randomized Allocation High High Medium vehicle control reported with 0.1% DMSO control mortality was <= 8.3% embryos were randomly distributed Domain 3: Exposure Characterization Metric 7: Metric 8: Metric 9: Metric 10: Metric 11: Experimental System/Test Media Preparation Consistency of Exposure Administration Measurement of Test Substance Concentration Exposure Duration and Frequency Number of Exposure Groups/ Spacing of Exposure Levels High High Medium High High documentation was adequate for this test system no inconsistencies were noted concentrations were measured but results were reported as log concentrations 3 to 120-h post fertilization a wide range of concentrations was reported "Expression of genes associated with es- trogen receptor in zebraflsh larvae (120hpf) exposure to 2.85, 28.5 and 285 mg TCEP/ L " Metric 12: Testing at or Below Solubility Limit High the use of DMSO should be adequate to ensure the highest concentrations were fully dissolved Domain 4: Test Organism Metric 13: Metric 14: Metric 15: Test Organism Characteristics Acclimatization and Pretreatment Conditions Number of Organisms and Replicates per Group High Medium Medium age and source of organisms seemed satisfactory pretreatment was not well documented but it was adequate three replicates were used Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium minimal documentation of exposure water conditions Continued on next page ... Page 83 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469243 Table: 3 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Wu, Y., Su, G., Tang, S., Liu, W., Ma, Z., Zheng, X., Liu, H., Yu, H. (2017). The combination of in silico and in vivo approaches for the investigation of disrupting effects of tris (2-chloroethyl) phosphate (TCEP) toward core receptors of zebrafish. Chemosphere 168:122-130. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Endocrine Tris(2-chloroethyl) phosphate (TCEP) 5469243 Domain Metric Rating Comments Metric 17: Outcome Assessment Methodology High assessment of endocrine gene expression was adequateThere were some concerns, how- ever, regarding the different responses among exposure concentrations. Three concentra- tions of TCEP/L were asssessed, 2.85, 28.5, and 285 ug TCEP/L. Results for the vtg2, pgr, ncoal, ncoa3, er2b, vtgl, and erl indicated a greater response for 2.85 and 285 ug TCEP/L than the middle 28.5 concentration. The authors did not provide a rationale as to why this may have occurred. Metric 18: Consistency of Outcome High no inconsistencies were reported Assessment Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High no confounding variables were reported Design and Procedures Metric 20: Outcomes Unrelated to Exposure High no unrelated outcomes reported Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High "Key receptor pathway analysis was conducted according to a previous study (Liu et al., 2015). The resulting network genes (nodes) were colored by the Enhanced Graphics application within Cytoscape v3.1.1 (Cytoscape consortium, San Diego, CA, USA) according to the significant changes in gene expression in the respective treatments." Metric 22: Reporting of Data High data was clearly reported graphically and in text Metric 23: Explanation of Unexpected Outcomes High no unexpected outcomes reported Additional Comments: Due higher responses seen at the highest 285 ug TCEP/L and lowest 2.85 ug TCEP/L concentrations compared to the middle 28.5 ug TCEP/L concentra- tions, it is not clear which concentration is responsible for the effect seen. Overall Quality Determination High Page 84 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469243 Table: 4 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Wu, Y., Su, G., Tang, S., Liu, W., Ma, Z., Zheng, X., Liu, H., Yu, H. (2017). The combination of in silico and in vivo approaches for the investigation of disrupting effects of tris (2-chloroethyl) phosphate (TCEP) toward core receptors of zebraflsh. Chemosphere 168:122-130. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469243 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High TCEP was purchased from AccuStandard (100% , AccuStandardlnc., CT, USA). Metric 2: Test Substance Source Low percent purity was not analytically verified Metric 3: Test Substance Purity High reported as 100% purity Domain 2: Test Design Metric 4: Negative Controls High vehicle control reported with 0.1% DMSO Metric 5: Negative Control Response High control mortality was <= 8.3% "The morality rate of each concentration (2.85, 28.5and 28,500 mg TCEP/L) did not change rapidly (the change ofmortality rate was no more than 12.5% ) from 24 to 120 hpf" Metric 6: Randomized Allocation Medium embryos were randomly distributed Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High documentation was adequate for this test system Preparation Metric 8: Consistency of Exposure High no inconsistencies were noted Administration Metric 9: Measurement of Test Substance Medium concentrations were measured but results were reported as log concentrations Concentration Metric 10: Exposure Duration and Frequency High 3 to 120-h post fertilization Metric 11: Number of Exposure Groups/ High a wide range of concentrations was reported Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High the use of DMSO should be adequate to ensure the highest concentrations were fully dissolved Domain 4: Test Organism Metric 13: Test Organism Characteristics High age and source of organisms seemed satisfactory"Adult zebraflsh (4 months old, AB wild-type) were obtainedfrom the Institute of Hydrobiology, Chinese Academy of Sci- ences" Metric 14: Acclimatization and Pretreatment Medium pretreatment was not well documented but it was adequate Conditions Metric 15: Number of Organisms and Medium three replicates were used Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium minimal documentation of exposure water conditions Continued on next page ... Page 85 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469243 Table: 4 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Wu, Y., Su, G., Tang, S., Liu, W., Ma, Z., Zheng, X., Liu, H., Yu, H. (2017). The combination of in silico and in vivo approaches for the investigation of disrupting effects of tris (2-chloroethyl) phosphate (TCEP) toward core receptors of zebrafish. Chemosphere 168:122-130. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469243 Domain Metric Rating Comments Metric 17: Metric 18: Outcome Assessment Methodology Consistency of Outcome Assessment High High both percent mortality and log LC50 values were reported at multiple durations observations were made at multiple durations for all concentrations Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High High no variables were reported no unrelated outcomes reported Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High both percent mortality and Log LC50 values reported at various durations data was reported graphically and in text no unexpected outcomes reported Additional Comments: None Overall Quality Determination High Page 86 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469243 Table: 5 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Wu, Y., Su, G., Tang, S., Liu, W., Ma, Z., Zheng, X., Liu, H., Yu, H. (2017). The combination of in silico and in vivo approaches for the investigation of disrupting effects of tris (2-chloroethyl) phosphate (TCEP) toward core receptors of zebraflsh. Chemosphere 168:122-130. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo ADME (biotransformation) Tris(2-chloroethyl) phosphate (TCEP) 5469243 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High TCEP was purchased from AccuStandard (100% , AccuStandardlnc., CT, USA). Metric 2: Test Substance Source Low percent purity was not analytically verified Metric 3: Test Substance Purity High reported as 100% purity Domain 2: Test Design Metric 4: Negative Controls High vehicle control reported with 0.1% DMSO Metric 5: Negative Control Response Low control response was not reported Metric 6: Randomized Allocation Medium embryos were randomly distributed Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High documentation was adequate for this test system Preparation Metric 8: Consistency of Exposure High no inconsistencies were noted by the study authors Administration Metric 9: Measurement of Test Substance High concentrations were measured but actual values were not reported except as the Log Concentration value of the mean-measured concentrations Metric 10: Exposure Duration and Frequency High 3 to 120-h post fertilization Metric 11: Number of Exposure Groups/ High a wide range of concentrations was reported Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High the use of DMSO should be adequate to ensure the highest concentrations were fully dissolved Domain 4: Test Organism Metric 13: Test Organism Characteristics High age and source of organisms seemed satisfactory, although genus species was not spec- ified by study authorsage and source of organisms seemed satisfactory"Adult zebrafish (4 months old, AB wild-type) were obtainedfrom the Institute of Hydrobiology, Chinese Academy of Sciences" Metric 14: Acclimatization and Pretreatment Low pretreatment was not well documented but it was adequate Conditions Metric 15: Number of Organisms and Medium number of organisms and replicates (3) were adequate Replicates per Group Domain 5: Outcome Assessment Continued on next page ... Page 87 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469243 Table: 5 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Wu, Y., Su, G., Tang, S., Liu, W., Ma, Z., Zheng, X., Liu, H., Yu, H. (2017). The combination of in silico and in vivo approaches for the investigation of disrupting effects of tris (2-chloroethyl) phosphate (TCEP) toward core receptors of zebrafish. Chemosphere 168:122-130. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Danio rerio\ AB strain; Embryo ADME (biotransformation) Tris(2-chloroethyl) phosphate (TCEP) 5469243 Domain Metric Rating Comments Metric 16: Adequacy of Test Conditions Low minimal documentation of exposure water conditions "Moreover, the morality rate of each concentration (2.85, 28.5and 28,500 mg TCEP/L) did not change rapidly (the change ofmortality rate was no more than 12.5% ) from 24 to 120 hpf (seeSupplemen- tary Table S2), indicating the amount of chemicalentering the zebrafish did not change greatly with increasing ofexposure concentrations, consistent with the relatively low log Kow(1.44)." The second half of that statement seems to indicate that, contrary to what the study authors have concluded (a relationship between bioaccumulation and TCEP exposure), increasing the TCEP concentrations had no effect on bioaccumulation by zebrafish. Metric 17: Outcome Assessment Methodology Medium The bioaccumulation potency of TCEP was calculated based on the ratios of concentra- tions between zebrafish larvae and exposure solutions. Metric 18: Consistency of Outcome Medium control measurements were not well documented, other sources were cited and were Assessment reviewed to determine assessment methods Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High no variables were reported Design and Procedures Metric 20: Outcomes Unrelated to Exposure High no unexpected outcomes reported Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High a linear regression equation was established and there was little statistical difference between nominal and measured test concentrations Metric 22: Reporting of Data Medium actual measured test concentrations that accumulation was based on, was only available in log values Metric 23: Explanation of Unexpected Outcomes High no unexpected outcomes reported, expected outcomes had explanations provided Additional Comments: None Overall Quality Determination High Page 88 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4292102 Table: 1 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Sun, L., Tan, H., Peng, T., Wang, S., Xu, W., Qian, H., Jin, Y., Fu, Z. (2016). Developmental neurotoxicity of organophosphate flame retardants in early life stages of Japanese medaka (Oryzias latipes). Environmental Toxicology and Chemistry 35(12):2931-2940. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Oryzias latipes\ d-rR strain; Larvae Behavioral Tris(2-chloroethyl) phosphate (TCEP) 4292102 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High The test substance was identified as tris (2-chloroethyl) phosphate (TCEP; CAS no. 115-96-8). Chemical structure was given in table 1. Low Purchased from Sigma-Aldrich. The test substance identity was not analytically verified by the performing laboratory. High Percent purity was reported as 97% . Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High A control group containing 0.01% DMSO was included. High Control group response for behavior assay were reported in the text and in figures 1 and 2. Low Researchers did not report how organisms were allocated to study groups. Non- deformed larvae were selected for behavior assay Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High Preparation Metric 8: Consistency of Exposure High Administration Metric 9: Measurement of Test Substance Low Concentration Metric 10: Exposure Duration and Frequency High Metric 11: Number of Exposure Groups/ High Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High Static system, test solution renewed every 24 hrs. Exposures were consistent among all test groups. Exposure concentrations were not measured. Exposure duration of 96 hours was appropriate for test. The number of exposure groups and spacing of exposure levels were adequate to address the purpose of the study. 4 concentrations and a control (5 mg/L, 25 mg/L, 125 mg/L, 625 mg/L) w were used. Exposure concentrations were at or below the solubility limit. The solvent concentration was appropriate. Domain 4: Test Organism Metric 13: Test Organism Characteristics Metric 14: Acclimatization and Pretreatment Conditions High Japanese medaka (d-rR strain) originated from the Laboratory of Freshwater Fish at the Bioscience Center of Nagoya University. Low The study did not report whether test organisms were acclimatized and/or whether pre- treatment conditions were the same for control and exposed groups. Continued on next page ... Page 89 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4292102 Table: 1 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Sun, L., Tan, H., Peng, T., Wang, S., Xu, W., Qian, H., Jin, Y., Fu, Z. (2016). Developmental neurotoxicity of organophosphate flame retardants in early life stages of Japanese medaka (Oryzias latipes). Environmental Toxicology and Chemistry 35(12):2931-2940. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Oryzias latipes\ d-rR strain; Larvae Behavioral Tris(2-chloroethyl) phosphate (TCEP) 4292102 Domain Metric Rating Comments Metric 15: Number of Organisms and Replicates per Group Medium 20 test organisms with 3 replicates per treatment. Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment Low High High Housing and environmental conditions were adequate during incubation period. How- ever, environmental conditions were not reported for test conditions. Outcome assessment methodology (locomotor behavior assay) was appropriate and re- ported the intended outcomes of interest. End points were changes in the relative swim- ming speed during 30 min of visible light and during the dark-light-dark photoperiod stimulation test Outcome assessments were consistent across study groups. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low Medium Environmental conditions during test were not reported. There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Appropriate statistics were used after data met assumptions of the tests. Metric 22: Reporting of Data High Data for exposure-related findings (changes in the relative swimming speed during 30 min of visible light and during the dark-light-dark photoperiod stimulation test; figures 1 and 2) were presented for each treatment and control group Metric 23: Explanation of Unexpected Outcomes High No unexpected outcomes were reported. Additional Comments: This evaluation form is relevant to the behavioral outcome (changes in the relative swimming speed during 30 min of visible light and during the dark- light-dark photoperiod stimulation test) in medaka larvae following exposure to TCEP. Overall Quality Determination High Page 90 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4292102 Table: 2 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Sun, L., Tan, H., Peng, T., Wang, S., Xu, W., Qian, H., Jin, Y., Fu, Z. (2016). Developmental neurotoxicity of organophosphate flame retardants in early life stages of Japanese medaka (Oryzias latipes). Environmental Toxicology and Chemistry 35(12):2931-2940. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Oryzias latipes\ d-rR strain; Larvae Mechanistic-Biomarkers (exposure and effect)-Cell signaling/function Tris(2-chloroethyl) phosphate (TCEP) 4292102 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High The test substance was identified as tris (2-chloroethyl) phosphate (TCEP; CAS no. 115-96-8). Chemical structure was given in table 1. Metric 2: Test Substance Source Low Purchased from Sigma-Aldrich. The test substance identity was not analytically verified by the performing laboratory. Metric 3: Test Substance Purity High Percent purity was reported as 97% Domain 2: Test Design Metric 4: Negative Controls High A control group containing 0.01% DMSO was included. Metric 5: Negative Control Response High Control group response for AChE and mRNA expression were reported in the text and in Figures 3 and 4. Control responses were adequate. Metric 6: Randomized Allocation Low Researchers did not report how organisms were allocated to study groups. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High Static system, test solution renewed every 24 hrs. Preparation Metric 8: Consistency of Exposure High Exposures were consistent among all test groups. Administration Metric 9: Measurement of Test Substance Low Exposure concentrations were not measured. Concentration Metric 10: Exposure Duration and Frequency High Exposure duration (96 hours) appropriate for test. Metric 11: Number of Exposure Groups/ High The number of exposure groups and spacing of exposure levels were adequate to address Spacing of Exposure Levels the purpose of the study. 4 concentrations and a control (5 mg/L, 25 mg/L, 125 mg/L, and 625 mg/L). Metric 12: Testing at or Below Solubility Limit High Exposure concentrations were at or below the solubility limit. The solvent concentration was appropriate. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Japanese medaka (d-rR strain) originated from the Laboratory of Freshwater Fish at the Bioscience Center of Nagoya University. Metric 14: Acclimatization and Pretreatment Low The study did not report whether test organisms were acclimatized and/or whether pre- Conditions treatment conditions were the same for control and exposed groups. Metric 15: Number of Organisms and Medium For gene transcription analysis, 15 larvae from each replicate (from the behavior assay) Replicates per Group were pooled into 1 sample. For AChE activity measurements, 30 larvae/beaker were sampled and homogenized after the exposure period, and 3 replicates of each concentra- tion were used. Continued on next page ... Page 91 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4292102 Table: 2 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: ... continued from previous page Sun, L., Tan, H., Peng, T., Wang, S., Xu, W., Qian, H., Jin, Y., Fu, Z. (2016). Developmental neurotoxicity of organophosphate flame retardants in early life stages of Japanese medaka (Oryzias latipes). Environmental Toxicology and Chemistry 35(12):2931-2940. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Oryzias latipes\ d-rR strain; Larvae Mechanistic-Biomarkers (exposure and effect)-Cell signaling/function Tris(2-chloroethyl) phosphate (TCEP) 4292102 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment. Low Housing and environmental conditions were adequate during incubation period. How- ever, environmental conditions were not reported for test conditions. High Outcome assessment methodologies (for acetylcholinesterase activity and gene tran- scription analysis) was appropriate and reported the intended outcomes of interest. High Outcome assessments were consistent across study groups. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low Environmental conditions during test were not reported. Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Appropriate statistics were used after data met assumptions of the tests. Metric 22: Reporting of Data High Data for exposure-related findings for AChE activity and mRNA level (Figures 3 and 4) were presented for each treatment and control group and were adequate to determine values for the endpoints of interest. Metric 23: Explanation of Unexpected Outcomes High No unexpected outcomes were reported. Additional Comments: This evaluation form is relevant to the mechanistic endpoints (AChE activity and changes in the transcription of genes related to the nervous system) in medaka larvae following exposure to TPP Overall Quality Determination High Page 92 of 170 ------- PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Tris(2-chloroethyl) phosphate (TCEP) Environmental Hazard Evaluation HERO ID: 4292102 Table: 3 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Sun, L., Tan, H., Peng, T., Wang, S., Xu, W., Qian, H., Jin, Y., Fu, Z. (2016). Developmental neurotoxicity of organophosphate flame retardants in early life stages of Japanese medaka (Oryzias latipes). Environmental Toxicology and Chemistry 35(12):2931-2940. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Oryzias latipes\ d-rR strain; Embryo Cardiovascular Tris(2-chloroethyl) phosphate (TCEP) 4292102 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High The test substance was identified as tris (2-chloroethyl) phosphate (TCEP; CAS no. 115-96-8). Chemical structure was given in table 1. Low Purchased from Sigma-Aldrich. The test substance identity was not analytically verified by the performing laboratory. High Percent purity reported as 97% . Domain 2: Test Design Metric 4: Negative Controls High A control group containing 0.01% DMSO was included. Metric 5: Negative Control Response High Control group response (table 2) was adequate. Metric 6: Randomized Allocation Medium Organisms were randomly allocated for treatments. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Preparation High Static system, test solution renewed every 24 hrs. Metric 8: Consistency of Exposure Administration High Exposures were consistent among all test groups. Metric 9: Measurement of Test Substance Concentration Low Exposure concentrations were not measured. Metric 10: Exposure Duration and Frequency High Exposure duration (14 days) appropriate for test. "During the exposure period, embryos went through the major embryonic stages (blastula, gastrula, neurula, and organogene- sis), hatching and proceeding into the larval stage." Metric 11: Number of Exposure Groups/ High Number of exposure groups and dose spacing were appropriate for test. 4 concentra- Spacing of Exposure Levels tions and a control (5 mg/L, 25 mg/L, 125 mg/L, and 625 mg/L). Concentrations were determined via a prior range finding test (data not shown). Metric 12: Testing at or Below Solubility Limit High Exposure concentrations were at or below the solubility limit. The solvent concentration was appropriate. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Japanese medaka (d-rR strain) originated from the Laboratory of Freshwater Fish at the Bioscience Center of Nagoya University. Metric 14: Acclimatization and Pretreatment Conditions Low The study did not report whether test organisms were acclimatized and/or whether pre- treatment conditions were the same for control and exposed groups. Metric 15: Number of Organisms and Replicates per Group Medium 20 test organisms with 3 replicates per treatment. Continued on next page ... Page 93 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4292102 Table: 3 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Sun, L., Tan, H., Peng, T., Wang, S., Xu, W., Qian, H., Jin, Y., Fu, Z. (2016). Developmental neurotoxicity of organophosphate flame retardants in early life stages of Japanese medaka (Oryzias latipes). Environmental Toxicology and Chemistry 35(12):2931-2940. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Oryzias latipes\ d-rR strain; Embryo Cardiovascular Tris(2-chloroethyl) phosphate (TCEP) 4292102 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment. Low Housing and environmental conditions were adequate during incubation period. How- ever, environmental conditions were not reported for test conditions. High Assessment methods for body length, hatch % , incubation time, deformity % and heart rate were reported. High Outcome assessments were consistent across study groups. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low The study did not provide enough information to allow a comparison of environmental conditions or other non-treatment-related factors across study groups. Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High Appropriate statistics were used after data met assumptions of the tests. Data for exposure-related findings were presented for each treatment and control group and were adequate to determine values for hatchability, time to hatching, gross abnor- mality rate, heart rate and body length. No unexpected outcomes were reported. Additional Comments: This evaluation form is relevant to cardiovascular outcome (heart rate) determined in medaka embryos following exposure to TCEP. Overall Quality Determination High Page 94 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4292102 Table: 4 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Sun, L., Tan, H., Peng, T., Wang, S., Xu, W., Qian, H., Jin, Y., Fu, Z. (2016). Developmental neurotoxicity of organophosphate flame retardants in early life stages of Japanese medaka (Oryzias latipes). Environmental Toxicology and Chemistry 35(12):2931-2940. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Oryzias latipes\ d-rR strain; Embryo Reproductive/Teratogenic Tris(2-chloroethyl) phosphate (TCEP) 4292102 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High The test substance was identified as tris (2-chloroethyl) phosphate (TCEP; CAS no. 115-96-8). Chemical structure was given in table 1. Metric 2: Test Substance Source Low Purchased from Sigma-Aldrich. The test substance identity was not analytically verified by the performing laboratory. Metric 3: Test Substance Purity High Percent purity reported as 97% . Domain 2: Test Design Metric 4: Negative Controls High A control group containing 0.01% DMSO was included. Metric 5: Negative Control Response High Control group response (table 2) was adequate. Metric 6: Randomized Allocation Medium Organisms were randomly allocated for treatments. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High Static system, test solution renewed every 24 hrs. Preparation Metric 8: Consistency of Exposure High Exposures were consistent among all test groups. Administration Metric 9: Measurement of Test Substance Low Exposure concentrations were not measured. Concentration Metric 10: Exposure Duration and Frequency High Exposure duration (14 days) appropriate for test. "During the exposure period, embryos went through the major embryonic stages (blastula, gastrula, neurula, and organogene- sis), hatching and proceeding into the larval stage." Metric 11: Number of Exposure Groups/ High The number of exposure groups and spacing of exposure levels were adequate to address Spacing of Exposure Levels the purpose of the study. 4 concentrations and a control (5 mg/L, 25 mg/L, 125 mg/L, and 625 mg/L). Concentrations were determined via a prior range finding test (data not shown). Metric 12: Testing at or Below Solubility Limit High Exposure concentrations were at or below the solubility limit. The solvent concentration was appropriate. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Japanese medaka (d-rR strain) originated from the Laboratory of Freshwater Fish at the Bioscience Center of Nagoya University. Metric 14: Acclimatization and Pretreatment Low The study did not report whether test organisms were acclimatized and/or whether pre- Conditions treatment conditions were the same for control and exposed groups. Metric 15: Number of Organisms and Medium 20 test organisms with 3 replicates per treatment. Replicates per Group Continued on next page ... Page 95 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4292102 Table: 4 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Sun, L., Tan, H., Peng, T., Wang, S., Xu, W., Qian, H., Jin, Y., Fu, Z. (2016). Developmental neurotoxicity of organophosphate flame retardants in early life stages of Japanese medaka (Oryzias latipes). Environmental Toxicology and Chemistry 35(12):2931-2940. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Oryzias latipes\ d-rR strain; Embryo Reproductive/Teratogenic Tris(2-chloroethyl) phosphate (TCEP) 4292102 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment. Low Housing and environmental conditions were adequate during incubation period. How- ever, environmental conditions were not reported for test conditions. High Outcome assessment methods for body length, hatch % , incubation time, deformity % and heart rate were reported. High Outcome assessments were consistent across study groups. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low Environmental conditions during test were not reported. Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High Appropriate statistics were used after data met assumptions of the tests. Data for exposure-related findings were presented for each treatment and control group and were adequate to determine values for hatchability, time to hatching, gross abnor- mality rate, heart rate and body length. No unexpected outcomes were reported. Additional Comments: This evaluation form is relevant to reproductive outcomes (percent hatchability and time to hatch) determined in medaka embryos following exposure to TCEP Overall Quality Determination High Page 96 of 170 ------- PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Tris(2-chloroethyl) phosphate (TCEP) Environmental Hazard Evaluation HERO ID: 4292102 Table: 5 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Sun, L., Tan, H., Peng, T., Wang, S., Xu, W., Qian, H., Jin, Y., Fu, Z. (2016). Developmental neurotoxicity of organophosphate flame retardants in early life stages of Japanese medaka (Oryzias latipes). Environmental Toxicology and Chemistry 35(12):2931-2940. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Oryzias latipes\ d-rR strain; Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 4292102 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High The test substance was identified as tris (2-chloroethyl) phosphate (TCEP; CAS no. 115-96-8). Chemical structure was given in table 1. Low Purchased from Sigma-Aldrich. The test substance identity was not analytically verified by the performing laboratory. High Percent purity reported as 97% . Domain 2: Test Design Metric 4: Negative Controls High A control group containing 0.01% DMSO was included. Metric 5: Negative Control Response High Control group response (table 2) was adequate. Metric 6: Randomized Allocation Medium Organisms were randomly allocated for treatments. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Preparation High Static system, test solution renewed every 24 hrs. Metric 8: Consistency of Exposure Administration High Exposures were consistent among all test groups. Metric 9: Measurement of Test Substance Concentration Low Exposure concentrations were not measured. Metric 10: Exposure Duration and Frequency High Exposure duration (14 days) appropriate for test. "During the exposure period, embryos went through the major embryonic stages (blastula, gastrula, neurula, and organogene- sis), hatching and proceeding into the larval stage." Metric 11: Number of Exposure Groups/ High Number of exposure groups and dose spacing were appropriate for test. 4 concentra- Spacing of Exposure Levels tions and a control (5 mg/L, 25 mg/L, 125 mg/L, and 625 mg/L). Concentrations were determined via a prior range finding test (data not shown). Metric 12: Testing at or Below Solubility Limit High Exposure concentrations were at or below the solubility limit. The solvent concentration was appropriate. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Japanese medaka (d-rR strain) originated from the Laboratory of Freshwater Fish at the Bioscience Center of Nagoya University. Metric 14: Acclimatization and Pretreatment Conditions Low The study did not report whether test organisms were acclimatized and/or whether pre- treatment conditions were the same for control and exposed groups. Metric 15: Number of Organisms and Replicates per Group Medium 20 test organisms with 3 replicates per treatment. Continued on next page ... Page 97 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 4292102 Table: 5 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Sun, L., Tan, H., Peng, T., Wang, S., Xu, W., Qian, H., Jin, Y., Fu, Z. (2016). Developmental neurotoxicity of organophosphate flame retardants in early life stages of Japanese medaka (Oryzias latipes). Environmental Toxicology and Chemistry 35(12):2931-2940. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Oryzias latipes\ d-rR strain; Embryo Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 4292102 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment. Low Housing and environmental conditions were adequate during incubation period. How- ever, environmental conditions were not reported for test conditions. High Assessment methods for body length, hatch % , incubation time, deformity % and heart rate were reported. High Outcome assessments were consistent across study groups. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low The study did not provide enough information to allow a comparison of environmental conditions or other non-treatment-related factors across study groups. Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Appropriate statistics were used after data met assumptions of the tests. Metric 22: Reporting of Data High Data for exposure-related findings were presented for each treatment and control group and were adequate to determine values for hatchability, time to hatching, gross abnor- mality rate, heart rate and body length. Metric 23: Explanation of Unexpected Outcomes High No unexpected outcomes were reported. Additional Comments: This evaluation form is relevant to development/growth outcomes (body length and percentage of gross abnormality rate) determined in medaka embryos following exposure to TCEP. Overall Quality Determination High Page 98 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 6310866 Table: 1 of 2 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Life Sciences Research Ltd, (1990). Fyrol CEF: Acute toxicity to rainbow trout. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Salmo gairdnerr, Juvenile Mortality Tris(2-chloroethyl) phosphate (TCEP) 6310866 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Name, CASNR, and structure provided High Supplied by AKZO Chemical Inc., Batch no. 8101 K-l-4 Low Contrary to narrative, purity was not reported in appendix 2. Domain 2: Test Design Metric 4: Negative Controls High Negative controls used. Metric 5: Negative Control Response High Zero mortality reported for controls Metric 6: Randomized Allocation Medium Random allocation was reported. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Low Only nominal concentrations used. Measures taken to account for volatility (e.g., head Preparation space, closed system etc.) not reported. Metric 8: Consistency of Exposure High exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Medium Nominal concentrations were used. Concentration Metric 10: Exposure Duration and Frequency High Exposure duration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Number of exposure groups and spacing appropriate for the test. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High Concentrations were below water solubility. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Fish and source were well described with the exception of sex. Metric 14: Acclimatization and Pretreatment High Acclimation was appropriate for test. Conditions Metric 15: Number of Organisms and Medium Number of organisms and replicates were acceptable. Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Environmental conditions were adequate. Metric 17: Outcome Assessment Methodology High Intended outcomes were reported. Metric 18: Consistency of Outcome High Outcome assessments were consistent across groups. Assessment. Continued on next page ... Page 99 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 6310866 Table: 1 of 2 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: ... continued from previous page Life Sciences Research Ltd, (1990). Fyrol CEF: Acute toxicity to rainbow trout. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Salmo gairdnerr, Juvenile Mortality Tris(2-chloroethyl) phosphate (TCEP) 6310866 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High No confounding variables reported. Medium No differences among groups reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes Low Statistical analyses were performed. However, statistics used were reported as not valid for the data. Therefore approximate values were reported. High Data reported for all outcomes. High No unexpected outcomes reported. Additional Comments: None Overall Quality Determination High Page 100 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 6310866 Table: 2 of 2 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Life Sciences Research Ltd, (1990). Fyrol CEF: Acute toxicity to rainbow trout. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Salmo gairdnerr, Juvenile Mortality Tris(2-chloroethyl) phosphate (TCEP) 6310866 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Name, CASNR, and structure provided Metric 2: Test Substance Source High Supplied by AKZO Chemical Inc., Batch no. 8101 K-l-4 Metric 3: Test Substance Purity Low Contrary to narrative, purity was not reported in appendix 2. Domain 2: Test Design Metric 4: Negative Controls High Negative controls used. Metric 5: Negative Control Response Low No data on control conditions related to the outcome for this form (loss of coordination, pigmentation, and edema) are reported or quantified. Metric 6: Randomized Allocation Medium Random allocation was reported. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Low Only nominal concentrations used. Measures taken to account for volatility (e.g., head Preparation space, closed system etc.) not reported. Metric 8: Consistency of Exposure High Exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Medium Nominal concentrations were used. Concentration Metric 10: Exposure Duration and Frequency High Exposure duration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Number of exposure groups and spacing appropriate for the test. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High Concentrations were below water solubility. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Fish and source were well described with the exception of sex. Metric 14: Acclimatization and Pretreatment High Acclimation was appropriate for test. Conditions Metric 15: Number of Organisms and Medium Number of organisms and replicates were acceptable. Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Environmental conditions were adequate. Metric 17: Outcome Assessment Methodology Low This form is for observations reported in the results on loss of equilibrium, pigmenta- tion, and edema (Page 18/24). This report has no data sheets to quantify these observa- tions past report in the results. Responses for control individuals are not reported. Metric 18: Consistency of Outcome Low The methods do not report the frequency of when this outcome was recorded. Assessment. Continued on next page ... Page 101 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 6310866 Table: 2 of 2 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Life Sciences Research Ltd, (1990). Fyrol CEF: Acute toxicity to rainbow trout. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Salmo gairdnerr, Juvenile Mortality Tris(2-chloroethyl) phosphate (TCEP) 6310866 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High No confounding variables reported. Medium No differences among groups reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Low Metric 22: Reporting of Data Low Metric 23: Explanation of Unexpected Outcomes High No Statistics for these observations were reported. The data for the observations for this form are not presented. No unexpected outcomes reported. Additional Comments: This form is for observations reported in the results on loss of equilibrium, pigmentation, and edema (Page 18/24). This report has no data sheets to quantify these observations past report in the results. Responses for control individuals are not reported. Overall Quality Determination Medium Page 102 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469341 Table: 1 of 1 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Arukwe, A., Carteny, C. C., Eggen, T. (2016). Lipid peroxidation and oxidative stress responses in juvenile salmon exposed to waterborne levels of the organophosphate compounds tris(2-butoxyethyl)- and tris(2-chloroethyl) phosphates. Journal of Toxicology and Environmental Health, Part A: Current Issues 79(13-15):515-525. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Vertebrate; Fish; Salmo solar; Juvenile Mechanistic-Cell signaling/function-Oxidative stress (including redox biology) Tris(2-chloroethyl) phosphate (TCEP) 5469341 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Th tests substance was identified by chemical name and molecular formula. Low The test substance was obtained from obtained from Sigma-Aldrich Chemie GmbH but its was not analytically verified by the performing laboratory. High Percent purity of TCEP was reported as 97% . Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High Study authors reported using an appropriate concurrent negative control group. High The biological responses of the negative control group were adequate. Low Researchers did not report how organisms were allocated to study groups. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium The experimental system and test media preparation methods were reported. A Preparation semistatic experimental protocol was used. Test solution were prepared in Milli-Q water. Test solutions were renewed every 3 days. Metric 8: Consistency of Exposure High Details of exposure administration were reported and exposures were administered Administration consistently across study groups. Metric 9: Measurement of Test Substance Low Exposure concentrations were not measured. Concentration Metric 10: Exposure Duration and Frequency High 7-d exposure duration is appropriate for the study type. Metric 11: Number of Exposure Groups/ High Three exposure groups (0.04, 0.2, or 1 mg/L) and a control were used and adequate to Spacing of Exposure Levels address the purpose of the study. Metric 12: Testing at or Below Solubility Limit High Exposure concentrations were below the water solubility limit. Domain 4: Test Organism Metric 13: Test Organism Characteristics Metric 14: Acclimatization and Pretreatment Conditions Metric 15: Number of Organisms and Replicates per Group High The test organisms were adequately described. Average length and weight measure- ments were provided. Test organisms were obtained from Settefiskanlegget Lundamo AS (Lundamo, Norway). High The test organisms were acclimatized to test conditions for 9 days and all pretreatment conditions were the same for control and exposed organisms Low The numbers of test organisms was reported. "Fish were divided into 6 treatments and 1 control where each group constitutes 16 individuals." The use of replicates was not reported. Continued on next page ... Page 103 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469341 Table: 1 of 1 ... continued from previous page Arukwe, A., Carteny, C. C., Eggen, T. (2016). Lipid peroxidation and oxidative stress responses in juvenile salmon exposed to waterborne levels of the organophosphate compounds tris(2-butoxyethyl)- and tris(2-chloroethyl) phosphates. Journal of Toxicology and Environmental Health, Part A: Current Issues 79(13-15):515-525. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Vertebrate; Fish; Salmo solar; Juvenile Mechanistic-Cell signaling/function-Oxidative stress (including redox biology) Tris(2-chloroethyl) phosphate (TCEP) 5469341 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Metric 17: Outcome Assessment Methodology Metric 18: Consistency of Outcome Assessment High Organism housing and environmental conditions at which the tanks were maintained were appropriate. "The tanks were kept at a constant temperature of 8°C and a 12:12-h photoperiod." However, water quality parameters were (pH, DO, etc.) were not moni- tored. High The outcome assessment methodology addressed or reported the intended outcome(s) of interest. Methodologies to determine gene expression of GPx, GR, GST, peroxisome proliferator-activated receptors (PPAR) were described well. The immunochemical method to determine presence of PPAR proteins was also described well. High Details of the outcome assessment protocol were reported, and outcomes were assessed consistently across study groups. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Low The study did not provide enough information to allow a comparison of environmental Design and Procedures conditions or other non-treatment-related factors across study groups. Metric 20: Outcomes Unrelated to Exposure Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Statistical methods were adequately described. "One-way analysis of variance (ANOVA) was performed, followed by post hoc analysis (Duncan"s test) between sub- groups." Metric 22: Reporting of Data Medium Data for exposure-related findings were presented for each treatment and control group for gene expression data. The immunoblot analysis results (Figure ID) is missing in the manuscript. Metric 23: Explanation of Unexpected Outcomes High There were no unexpected outcomes Additional Comments: This form includes all mechanistic data- gene expression of glutathione peroxidase (GPx), glutathione reductase (GR), glutathione S-transferase (GST), peroxisome proliferator-activated receptors (PPAR), and presence of PPAR proteins using immunochemical methods. Overall Quality Determination High Page 104 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5184752 Table: 1 of 1 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Kovacevic, V., Simpson, A. J., Simpson, M. J. (2018). Investigation of daphnia magna sub-lethal exposure to organophosphate esters in the presence of dissolved organic matter using "H NMR-based metabolomics. Metabolites 8(2):34. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Arthropods; Daphnia magna; Adult Mechanistic-Biomarkers (exposure and effect)-Cell signaling/function-Nutritional and Metabolic Tris(2-chloroethyl) phosphate (TCEP) 5184752 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Chemical was identified by name and chemical structure (Table 1). Metric 2: Test Substance Source Low The test substance identity was not analytically verified by the performing laboratory. Metric 3: Test Substance Purity High Chemical purity reported as 97% . Domain 2: Test Design Metric 4: Negative Controls High Study authors reported using an appropriate concurrent negative control group, both DOM and clean controls were used. Metric 5: Negative Control Response Medium The biological response of the negative control groups was reported for analyzed metabolites but not for survival. Metric 6: Randomized Allocation Low Researchers did not report how organisms were allocated to study groups. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High The experimental system and methods for preparation of test media were described in Preparation adequate detail. Stock solution was prepared in dechlorinated water and beakers with test solution "were sealed with parafilm and equilibrated on a magnetic stirrer at room temperature in the dark for 48 h." Metric 8: Consistency of Exposure High Exposures were administered consistently across study groups. Administration Metric 9: Measurement of Test Substance High Exposure concentrations were measured using appropriate analytical technologies and Concentration methods, and were similar to nominals. Metric 10: Exposure Duration and Frequency High The duration of exposure was reported (48 hours) and appropriate for the study type. Metric 11: Number of Exposure Groups/ N/A Only one concentration was tested. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High Exposure concentration was below the water solubility limit. Domain 4: Test Organism Metric 13: Test Organism Characteristics High The test organisms were adequately described and were obtained from a reliable source. Laboratory cultured adult daphnids (16 days old) were used. Metric 14: Acclimatization and Pretreatment High All pretreatment conditions were the same for control and exposed organisms. Conditions Metric 15: Number of Organisms and Medium The numbers of test organisms and replicates were reported, 10 replicates with 10 daph- Replicates per Group nids each. Continued on next page ... Page 105 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5184752 Table: 1 of 1 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Kovacevic, V., Simpson, A. J., Simpson, M. J. (2018). Investigation of daphnia magna sub-lethal exposure to organophosphate esters in the presence of dissolved organic matter using "H NMR-based metabolomics. Metabolites 8(2):34. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Arthropods; Daphnia magna; Adult Mechanistic-Biomarkers (exposure and effect)-Cell signaling/function-Nutritional and Metabolic Tris(2-chloroethyl) phosphate (TCEP) 5184752 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Metric 17: Outcome Assessment Methodology Metric 18: Consistency of Outcome Assessment. Medium Daphnia culture conditions were reported. Organism housing and feeding during expo- sure period were reported. Biomass loading (1 daphnid/30 ml) was appropriate. It was stated that temperature and light conditions were the same as the culture conditions but specifics during the exposure period were not reported. High The outcome assessment methodology reported the intended outcome of interest. Metabolomics methods were described well. High Outcomes were assessed consistently across study groups. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Medium Design and Procedures Metric 20: Outcomes Unrelated to Exposure Medium There were no reported differences among the study groups in environmental conditions although specifics were not reported. There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Statistical methods were adequately described. "The statistical significance of the in- dividual metabolite percent changes was determined with a t-test (two-tailed, equal variances, p < 0.05) and the results of this statistical analysis is given in Table S3 in the Supplementary Materials." Metric 22: Reporting of Data High Table S3 has statistical results for all treatments. Metric 23: Explanation of Unexpected Outcomes High Unexpected outcomes were satisfactorily explained Additional Comments: The study examined the effect of dissolved organic matter (DOM) on the sub-lethal toxicity of TCEP to D. magna using 1H NMR-based metabolomics. TCEP was tested alone and in the presence of DOM. Overall Quality Determination High Page 106 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 10064285 Table: 1 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Hagstrom, D., Hayes, P., Graham, A., Collins, E. S. (2019). Multi-behavioral endpoint testing of an 87-chemical compound library in freshwater planarians. Toxicological Sciences 167(1 ):26-44. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 10064285 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Identified by name and CASRN in supplemental notes. Metric 2: Test Substance Source Low Source of stock solutions were identified. Analytical verification not reported. Metric 3: Test Substance Purity Low Purity or grade was not reported. Domain 2: Test Design Metric 4: Negative Controls High Solvent controls were reported. Metric 5: Negative Control Response High Negative control response acceptable and presented within the supplemental excel file. Metric 6: Randomized Allocation Low Worms were selected by specified size. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High Experimental system well described. Preparation Metric 8: Consistency of Exposure High Exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Low Stock solutions of different concentrations were purchased. No analytical measurements Concentration were reported. Metric 10: Exposure Duration and Frequency High Exposure concentration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Number of exposure groups and spacing were appropriate for the tests. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High The highest concentration (100 uM) is 28 mg/L which is over the solubility listed in the final scope (7.9 mg/L). Domain 4: Test Organism Metric 13: Test Organism Characteristics High Test organisms were well described. Metric 14: Acclimatization and Pretreatment High Acclimation and pretreatments were appropriate for tests. Conditions Metric 15: Number of Organisms and Medium Number of organisms and replicates were acceptable. Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Test conditions were adequate. Metric 17: Outcome Assessment Methodology High Intended outcomes reported in supplemental excel file. Continued on next page ... Page 107 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 10064285 Table: 1 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Hagstrom, D., Hayes, P., Graham, A., Collins, E. S. (2019). Multi-behavioral endpoint testing of an 87-chemical compound library in freshwater planarians. Toxicological Sciences 167(1 ):26-44. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 10064285 Domain Metric Rating Comments Metric 18: Consistency of Outcome Assessment High Outcome methodology was consistent. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High No confounding variables reported. Medium No unrelated outcomes were reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Statistics well described. High Data reported in supplemental excel file. High There were no unexpected outcomes reported. Additional Comments: supplementary data (table 2) provides LC50 values for 12 day worms but TCEP is not listed in this data. Specific data on mortality for TCEP is within the excel file (no mortality for worms at concentrations in this work). Overall Quality Determination High Page 108 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 10064285 Table: 2 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Hagstrom, D., Hayes, P., Graham, A., Collins, E. S. (2019). Multi-behavioral endpoint testing of an 87-chemical compound library in freshwater planarians. Toxicological Sciences 167(1 ):26-44. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 10064285 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Identified by name and CASRN Metric 2: Test Substance Source Low Source of stock solutions were identified. Analytical verification not reported. Metric 3: Test Substance Purity Low Purity or grade was not reported. Domain 2: Test Design Metric 4: Negative Controls High Solvent controls were reported. Metric 5: Negative Control Response High Negative control response acceptable. Metric 6: Randomized Allocation Low Worms were selected by specified size. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High Experimental system well described. Preparation Metric 8: Consistency of Exposure High Exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Low Stock solutions of different concentrations were purchased. No analytical measurements Concentration were reported. Metric 10: Exposure Duration and Frequency High Exposure concentration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Number of exposure groups and spacing were appropriate for the tests. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium The highest concentration (100 uM) is 28 mg/L which is over the solubility listed in the final scope (7.9 mg/L). Domain 4: Test Organism Metric 13: Test Organism Characteristics High Test organisms were well described. Metric 14: Acclimatization and Pretreatment High Acclimation and pretreatments were appropriate for tests. Conditions Metric 15: Number of Organisms and Medium Number of organisms and replicates were acceptable. Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Test conditions were adequate. Metric 17: Outcome Assessment Methodology High Intended outcomes were reported. Metric 18: Consistency of Outcome High Outcome methodology was consistent. Assessment. Continued on next page ... Page 109 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 10064285 Table: 2 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Hagstrom, D., Hayes, P., Graham, A., Collins, E. S. (2019). Multi-behavioral endpoint testing of an 87-chemical compound library in freshwater planarians. Toxicological Sciences 167(1 ):26-44. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 10064285 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High Medium No confounding variables reported. No unrelated outcomes were reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Low High Statistics well described. Data were reported in supplemental, however reporting of data was not clear. There were no unexpected outcomes reported. Additional Comments: This form represents measures of growth, specifically eye regeneration on day 7. Data is located in the supplementary excel file. Overall Quality Determination High Page 110 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 10064285 Table: 3 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Hagstrom, D., Hayes, P., Graham, A., Collins, E. S. (2019). Multi-behavioral endpoint testing of an 87-chemical compound library in freshwater planarians. Toxicological Sciences 167(1 ):26-44. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Behavioral Tris(2-chloroethyl) phosphate (TCEP) 10064285 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Identified by name and CASRN Metric 2: Test Substance Source Low Source of stock solutions were identified. Analytical verification not reported. Metric 3: Test Substance Purity Low Purity or grade was not reported. Domain 2: Test Design Metric 4: Negative Controls High Solvent controls were reported. Metric 5: Negative Control Response High Negative control response acceptable. Metric 6: Randomized Allocation Low Worms were selected by specified size. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High Experimental system well described. Preparation Metric 8: Consistency of Exposure High Exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Low Stock solutions of different concentrations were purchased. No analytical measurements Concentration were reported. Metric 10: Exposure Duration and Frequency High Exposure concentration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Number of exposure groups and spacing were appropriate for the tests. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium The highest concentration (100 uM) is 28 mg/L which is over the solubility listed in the final scope (7.9 mg/L). Domain 4: Test Organism Metric 13: Test Organism Characteristics High Test organisms were well described. Metric 14: Acclimatization and Pretreatment High Acclimation and pretreatments were appropriate for tests. Conditions Metric 15: Number of Organisms and Medium Number of organisms and replicates were acceptable. Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Test conditions were adequate. Metric 17: Outcome Assessment Methodology High Intended outcomes were reported. Metric 18: Consistency of Outcome High Outcome methodology was consistent. Assessment. Continued on next page ... Page 111 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 10064285 Table: 3 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Hagstrom, D., Hayes, P., Graham, A., Collins, E. S. (2019). Multi-behavioral endpoint testing of an 87-chemical compound library in freshwater planarians. Toxicological Sciences 167(1 ):26-44. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Behavioral Tris(2-chloroethyl) phosphate (TCEP) 10064285 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High Medium No confounding variables reported. No unrelated outcomes were reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High Statistics well described. Data were reported in supplemental excel file. There were no unexpected outcomes reported. Additional Comments: This form is for the behavior metrics which on day 7 mentary Excel file. are unstimulated behavior and phototaxsis. The TCEP data for this metric is located in the supple- Overall Quality Determination High Page 112 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 10064285 Table: 4 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Hagstrom, D., Hayes, P., Graham, A., Collins, E. S. (2019). Multi-behavioral endpoint testing of an 87-chemical compound library in freshwater planarians. Toxicological Sciences 167(1 ):26-44. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 10064285 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Identified by name and CASRN Metric 2: Test Substance Source Low Source of stock solutions were identified. Analytical verification not reported. Metric 3: Test Substance Purity Low Purity or grade was not reported. Domain 2: Test Design Metric 4: Negative Controls High Solvent controls were reported. Metric 5: Negative Control Response High Negative control response acceptable. Metric 6: Randomized Allocation Low Worms were selected by specified size. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High Experimental system well described. Preparation Metric 8: Consistency of Exposure High Exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Low Stock solutions of different concentrations were purchased. No analytical measurements Concentration were reported. Metric 10: Exposure Duration and Frequency High Exposure concentration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Number of exposure groups and spacing were appropriate for the tests. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium The highest concentration (100 uM) is 28 mg/L which is over the solubility listed in the final scope (7.9 mg/L). Domain 4: Test Organism Metric 13: Test Organism Characteristics High Test organisms were well described. Metric 14: Acclimatization and Pretreatment High Acclimation and pretreatments were appropriate for tests. Conditions Metric 15: Number of Organisms and Medium Number of organisms and replicates were acceptable. Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Test conditions were adequate. Metric 17: Outcome Assessment Methodology High Intended outcomes reported in supplemental excel file. Metric 18: Consistency of Outcome High Outcome methodology was consistent. Assessment. Continued on next page ... Page 113 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 10064285 Table: 4 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Hagstrom, D., Hayes, P., Graham, A., Collins, E. S. (2019). Multi-behavioral endpoint testing of an 87-chemical compound library in freshwater planarians. Toxicological Sciences 167(1 ):26-44. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 10064285 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High Medium No confounding variables reported. No unrelated outcomes were reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High Statistics well described. Data reported in supplemental excel file. There were no unexpected outcomes reported. Additional Comments: supplementary data (table 2) provides LC50 values for 12 day worms but TCEP is not listed in this data. Specific data on mortality for TCEP is within the excel file (no mortality for worms at concentrations in this work). Overall Quality Determination High Page 114 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 10064285 Table: 5 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Hagstrom, D., Hayes, P., Graham, A., Collins, E. S. (2019). Multi-behavioral endpoint testing of an 87-chemical compound library in freshwater planarians. Toxicological Sciences 167(1 ):26-44. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 10064285 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Identified by name and CASRN Metric 2: Test Substance Source Low Source of stock solutions were identified. Analytical verification not reported. Metric 3: Test Substance Purity Low Purity or grade was not reported. Domain 2: Test Design Metric 4: Negative Controls High Solvent controls were reported. Metric 5: Negative Control Response High Negative control response acceptable. Metric 6: Randomized Allocation Low Worms were selected by specified size. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High Experimental system well described. Preparation Metric 8: Consistency of Exposure High Exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Low Stock solutions of different concentrations were purchased. No analytical measurements Concentration were reported. Metric 10: Exposure Duration and Frequency High Exposure concentration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Number of exposure groups and spacing were appropriate for the tests. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium The highest concentration (100 uM) is 28 mg/L which is over the solubility listed in the final scope (7.9 mg/L). Domain 4: Test Organism Metric 13: Test Organism Characteristics High Test organisms were well described. Metric 14: Acclimatization and Pretreatment High Acclimation and pretreatments were appropriate for tests. Conditions Metric 15: Number of Organisms and Medium Number of organisms and replicates were acceptable. Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Test conditions were adequate. Metric 17: Outcome Assessment Methodology High Intended outcomes were reported. Metric 18: Consistency of Outcome High Outcome methodology was consistent. Assessment. Continued on next page ... Page 115 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 10064285 Table: 5 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Hagstrom, D., Hayes, P., Graham, A., Collins, E. S. (2019). Multi-behavioral endpoint testing of an 87-chemical compound library in freshwater planarians. Toxicological Sciences 167(1 ):26-44. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 10064285 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High Medium No confounding variables reported. No unrelated outcomes were reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Low High Statistics well described. Data were reported in supplemental, however reporting of data was not clear. There were no unexpected outcomes reported. Additional Comments: This form identifies morphology assessments at day 12 of exposure. This is identified in Figure one of the paper. Results are located on page 9/18, TCEP was not. detailed for these data. Overall Quality Determination High Page 116 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 10064285 Table: 6 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Hagstrom, D., Hayes, P., Graham, A., Collins, E. S. (2019). Multi-behavioral endpoint testing of an 87-chemical compound library in freshwater planarians. Toxicological Sciences 167(1 ):26-44. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Behavioral Tris(2-chloroethyl) phosphate (TCEP) 10064285 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Identified by name and CASRN Metric 2: Test Substance Source Low Source of stock solutions were identified. Analytical verification not reported. Metric 3: Test Substance Purity Low Purity or grade was not reported. Domain 2: Test Design Metric 4: Negative Controls High Solvent controls were reported. Metric 5: Negative Control Response High Negative control response acceptable. Metric 6: Randomized Allocation Low Worms were selected by specified size. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High Experimental system well described. Preparation Metric 8: Consistency of Exposure High Exposures were consistent across groups. Administration Metric 9: Measurement of Test Substance Low Stock solutions of different concentrations were purchased. No analytical measurements Concentration were reported. Metric 10: Exposure Duration and Frequency High Exposure concentration and frequency were appropriate for the test. Metric 11: Number of Exposure Groups/ High Number of exposure groups and spacing were appropriate for the tests. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium The highest concentration (100 uM) is 28 mg/L which is over the solubility listed in the final scope (7.9 mg/L). Domain 4: Test Organism Metric 13: Test Organism Characteristics High Test organisms were well described. Metric 14: Acclimatization and Pretreatment High Acclimation and pretreatments were appropriate for tests. Conditions Metric 15: Number of Organisms and Medium Number of organisms and replicates were acceptable. Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Test conditions were adequate. Metric 17: Outcome Assessment Methodology High Intended outcomes were reported. Metric 18: Consistency of Outcome High Outcome methodology was consistent. Assessment. Continued on next page ... Page 117 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 10064285 Table: 6 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Hagstrom, D., Hayes, P., Graham, A., Collins, E. S. (2019). Multi-behavioral endpoint testing of an 87-chemical compound library in freshwater planarians. Toxicological Sciences 167(1 ):26-44. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Behavioral Tris(2-chloroethyl) phosphate (TCEP) 10064285 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High Medium No confounding variables reported. No unrelated outcomes were reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High Statistics well described. Data were reported in supplemental excel file. There were no unexpected outcomes reported. Additional Comments: This form represents behavior metrics in the paper that include: unstimulated behavior, thermotaxsis, phototaxis, and scrunching. These data for TCEP are located in the supplementary excel file. Overall Quality Determination High Page 118 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 1 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ regenerative; Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High clearly identified with name and CAS # Low Sourced from Sigma Aldrich, but chemical was not analytically verified by the labora- tory. High reported as 99.07% pure Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation Low Authors did not use a true negative control. "Negative" controls contained either ac- etaminophen or L-ascorbic acid. A positive solvent control (0.5% DMSO) was also used. The authors presented information from previous studies to verify that ac- etaminophen or L-ascorbic acid did not affect the test organisms. High 100% survival in solvent control (0.5% DMSO), no mortality observed in "negative" controls Low No mention of randomization in this paper. Author did cite another paper which may have described randomization. Domain 3: Exposure Characterization Metric 7: Metric 8: Metric 9: Metric 10: Metric 11: Experimental System/Test Media Preparation Consistency of Exposure Administration Measurement of Test Substance Concentration Exposure Duration and Frequency Number of Exposure Groups/ Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Low The experimental system and methods for preparation of test media were described in adequate detail and appropriately accounted for the physical-chemical properties of the test substance (solvent used due to the low solubility of the test material). Measured test concentrations were not provided. High No inconsistencies were noticed or reported Low Exposure concentrations were not measured, highest concentration listed as 99.5 uM in supplemental data instead of a nominal value of 100 uM as stated in text High Exposure duration (12 days) was adequate to cause mortality for some of the chemicals in this study (but not TCEP). High Exposure concentrations seemed adequate to illicit a response (mortality) for most chemicals tested in this study. This was below the NOAEL for TCEP, but the purpose of the study was to compare the mortality between chemicals within a specific group, so this was not determined to affect the rating of this study. High Solvent (0.5% DMSO) was used to facilitate the dissolution of the test material into the test medium. Domain 4: Test Organism Continued on next page . Page 119 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 1 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ regenerative; Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Metric 13: Test Organism Characteristics High Supplemental methods description describes the test organism in more detail (Zhang et al., 2019). Test organisms were described as adults and "Test worms were manually selected to fall within a certain range of sizes and we found full worm length, after au- tomated size measurement, to be 7.3 6 2.3 mm (mean 6 SD), and tail worm length to be 7.3 mm 2.7 mm (mean 6 SD). Metric 14: Acclimatization and Pretreatment Conditions High In supplemental materials, pretreatment procedure was described as: "Animals were starved for at least 5 days before beingused for experiments and their containers were cleaned immediately prior to worm selection for experiments." This was adequate for gut-clearance. Metric 15: Number of Organisms and Replicates per Group Medium 8 individuals were used for each replicate. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Low Test conditions were fully described in supplemental methods paper (Zhang et al., 2019): "Wells of a 48- well plate with 200 ml of IO water." The authors noted that in the present study, they updated the feeding procedure, but this was not described clearly, "we fed planarians used in FR screen 2 commercial freeze-dried organic chicken liver (Amazon, Seattle, WA) to better control food quality and thus minimize animal fitness variability." It was unclear when this supplemental feeding occurred during the exposure period or if the lack of feeding could have contributed to additional mortality in some chemicals in the screen (No mortality was observed for TCEP, so this was not an issue for this chemcial). Metric 17: Outcome Assessment Methodology High Outcome assessment was adequate to describe the comparative mortality of several flame retardants following exposure to the test material. Metric 18: Consistency of Outcome High assessment methods seemed consistent across groups Assessment. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low The study did not provide enough information to allow a comparison of environmental conditions or other non-treatment-related factors across study groups. Besides the feed- ing procedure, which did not contribute to mortality for TCEP, there were no reported differences among the study groups in environmental conditions or other factors that could influence the outcome assessment. Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Continued on next page ... Page 120 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 1 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ regenerative; Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Metric 21: Statistical Methods Low The authors describe the statistical procedure as: "Statistical significance was deter- mined using either a one-tailed Fisher's exact test for lethality, eye regeneration, photo- taxis, and scrunching endpoints; Mann Whitney U test for thermotaxis and unstimulated behavior; or two-tailed t-test for unstimulated behavior (depending on normality of the sample) using a significance level of 0.05. This was adequate to determine if mortality was significant." This analysis and the raw data describing mortality were not presented in this study. Metric 22: Reporting of Data Low A large amount of data was presented in the supplemental file (Zhang et al., 2019): https://doi.Org/10.1016/j.ntt.2019.03.003. Data were not clear and interpretation was difficult. It appeared that no mortality was observed in the adults following exposure to TCEP for 7-12 days, but this was not clearly discussed. Metric 23: Explanation of Unexpected Outcomes High no mortalities for entire test duration in any treatment. The lack of bioactivity observed in this study for TCEP was not consistent with previous studies showing bioactivity in Zebrafish. This was explained in the discussion (4.6) Additional Comments: None Overall Quality Determination Medium Page 121 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 2 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ regenerative; Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High clearly identified with name and CAS # Low Sourced from Sigma Aldrich, but chemical was not analytically verified by the labora- tory. High reported as 99.07% pure Domain 2: Test Design Metric 4: Negative Controls Low Authors did not use a true negative control. "Negative" controls contained either ac- etaminophen or L-ascorbic acid. A positive solvent control (0.5% DMSO) was also used. The authors presented information from previous studies to verify that ac- etaminophen or L-ascorbic acid did not affect the test organisms. Metric 5: Negative Control Response High 100% survival in solvent control (0.5% DMSO), no mortality observed in "negative" controls. Metric 6: Randomized Allocation Low no mention of randomization in this paper. Author did cite another paper which may have described randomization Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Preparation Low minimal details provided making acceptability difficult to determine Metric 8: Consistency of Exposure Administration High no inconsistencies were noticed or reported Metric 9: Measurement of Test Substance Concentration Low exposure concentrations were not measured, high concentration listed as 99.5 uM in supplemental data instead of a nominal value of 100 uM as stated in text Metric 10: Exposure Duration and Frequency High Exposure duration (12 days) was adequate to cause mortality for some of the chemicals in this study (but not TCEP). Metric 11: Number of Exposure Groups/ High Exposure concentrations seemed adequate to illicit a response (mortality) for most Spacing of Exposure Levels chemicals tested in this study. This was below the NOAEL for TCEP, but the purpose of the study was to compare the mortality between chemicals within a specific group, so this was not determined to affect the rating of this study. Metric 12: Testing at or Below Solubility Limit High Solvent (0.5% DMSO) was used to facilitate the dissolution of the test material into the test medium. Domain 4: Test Organism Continued on next page . Page 122 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 2 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ regenerative; Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Metric 13: Test Organism Characteristics High Supplemental methods description describes the test organism in more detail (Zhang et al., 2019). Test organisms were described as adults and "Test worms were manually selected to fall within a certain range of sizes and we found full worm length, after au- tomated size measurement, to be 7.3 6 2.3 mm (mean 6 SD), and tail worm length to be 7.3 mm 2.7 mm (mean 6 SD). Metric 14: Acclimatization and Pretreatment Conditions High In supplemental materials, pretreatment procedure was described as: "Animals were starved for at least 5 days before beingused for experiments and their containers were cleaned immediately prior to worm selection for experiments." This was adequate for gut-clearance. Metric 15: Number of Organisms and Replicates per Group Medium 8 individuals were used for each replicate. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Low Test conditions were fully described in supplemental methods paper (Zhang et al., 2019): "Wells of a 48- well plate with 200 ml of IO water." The authors noted that in the present study, they updated the feeding procedure, but this was not described clearly, "we fed planarians used in FR screen 2 commercial freeze-dried organic chicken liver (Amazon, Seattle, WA) to better control food quality and thus minimize animal fitness variability." It was unclear when this supplemental feeding occurred during the exposure period or if the lack of feeding could have contributed to additional mortality in some chemicals in the screen (No mortality was observed for TCEP, so this was not an issue for this chemcial). Metric 17: Outcome Assessment Methodology High Outcome assessment was adequate to describe the comparative mortality of several flame retardants following exposure to the test material. Metric 18: Consistency of Outcome High assessment methods seemed consistent across groups Assessment. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low The study did not provide enough information to allow a comparison of environmental conditions or other non-treatment-related factors across study groups. Besides the feed- ing procedure, which did not contribute to mortality for TCEP, there were no reported differences among the study groups in environmental conditions or other factors that could influence the outcome assessment. Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Continued on next page ... Page 123 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 2 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ regenerative; Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Metric 21: Statistical Methods Low The authors describe the statistical procedure as: "Statistical significance was deter- mined using either a one-tailed Fisher's exact test for lethality, eye regeneration, photo- taxis, and scrunching endpoints; Mann Whitney U test for thermotaxis and unstimulated behavior; or two-tailed t-test for unstimulated behavior (depending on normality of the sample) using a significance level of 0.05. This was adequate to determine if mortality was significant." This analysis and the raw data describing mortality were not presented in this study. Metric 22: Reporting of Data Low A large amount of data was presented in the supplemental file (Zhang et al., 2019): https://doi.Org/10.1016/j.ntt.2019.03.003. Data were not clear and interpretation was difficult. It appeared that no mortality was observed in the regenerating adults following exposure to TCEP for 7-12 days, but this was not clearly discussed. Metric 23: Explanation of Unexpected Outcomes High no mortalities for entire test duration in any treatment. The lack of bioactivity observed in this study for TCEP was not consistent with previous studies showing bioactivity in Zebrafish. This was explained in the discussion (4.6) Additional Comments: None Overall Quality Determination Medium Page 124 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 3 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ regenerative; Adult Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High clearly identified with name and CAS # Low Sourced from Sigma Aldrich, but chemical was not analytically verified by the labora- tory. High reported as 99.07% pure Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation Low Authors did not use a true negative control. "Negative" controls contained either ac- etaminophen or L-ascorbic acid. A positive solvent control (0.5% DMSO) was also used. The authors presented information from previous studies to verify that ac- etaminophen or L-ascorbic acid did not affect the test organisms. High 100% survival in solvent control (0.5% DMSO), no mortality observed in "negative" controls Low no mention of randomization in this paper. Author did cite another paper which may have described randomization Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Preparation Metric 8: Consistency of Exposure Administration Metric 9: Measurement of Test Substance Concentration Metric 10: Exposure Duration and Frequency Metric 11: Number of Exposure Groups/ Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Low The experimental system and methods for preparation of test media were described in adequate detail and appropriately accounted for the physical-chemical properties of the test substance (solvent used due to the low solubility of the test material). Measured test concentrations were not provided. High no inconsistencies were noticed or reported Low Exposure concentrations were not measured, highest concentration listed as 99.5 uM in supplemental data instead of a nominal value of 100 uM as stated in text High Exposure duration (12 days) was adequate to elicit a response for the chemicals in this study (but not TCEP). High Exposure concentrations seemed adequate to illicit a response (development) for most chemicals tested in this study. This was below the NOAEL for TCEP, but the purpose of the study was to compare the mortality between chemicals within a specific group, so this was not determined to affect the rating of this study. High Solvent (0.5% DMSO) was used to facilitate the dissolution of the test material into the test medium. Domain 4: Test Organism Continued on next page . Page 125 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 3 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ regenerative; Adult Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Metric 13: Test Organism Characteristics High Supplemental methods description describes the test organism in more detail (Zhang et al., 2019). Test organisms were described as adults and "Test worms were manually selected to fall within a certain range of sizes and we found full worm length, after au- tomated size measurement, to be 7.3 6 2.3 mm (mean 6 SD), and tail worm length to be 7.3 mm 2.7 mm (mean 6 SD). Metric 14: Acclimatization and Pretreatment Conditions High In supplemental materials, pretreatment procedure was described as: "Animals were starved for at least 5 days before beingused for experiments and their containers were cleaned immediately prior to worm selection for experiments." This was adequate for gut-clearance. Metric 15: Number of Organisms and Replicates per Group Medium 8 individuals were used for each replicate. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium Test conditions were fully described in supplemental methods paper (Zhang et al., 2019): "Wells of a 48- well plate with 200 ml of IO water." The authors noted that in the present study, they updated the feeding procedure, but this was not described clearly, "we fed planarians used in FR screen 2 commercial freeze-dried organic chicken liver (Amazon, Seattle, WA) to better control food quality and thus minimize animal fitness variability." It was unclear when this supplemental feeding occurred during the exposure period or if the lack of feeding could have contributed to additional mortality in some chemicals in the screen (No effects on development were observed for TCEP, so this was not an issue for this chemcial). Metric 17: Outcome Assessment Methodology High outcome assessment was adequate, TCEP was essentially inactive for this test Metric 18: Consistency of Outcome Assessment High assessment methods seemed consistent across groups Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Low The study did not provide enough information to allow a comparison of environmental Design and Procedures conditions or other non-treatment-related factors across study groups. Besides the feed- ing procedure, which did not contribute to mortality for TCEP, there were no reported differences among the study groups in environmental conditions or other factors that could influence the outcome assessment. Metric 20: Outcomes Unrelated to Exposure High There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Continued on next page . Page 126 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 3 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ regenerative; Adult Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Metric 21: Statistical Methods Low The authors describe the statistical procedure as: "Statistical significance was deter- mined using either a one-tailed Fisher's exact test for lethality, eye regeneration, photo- taxis, and scrunching endpoints; Mann Whitney U test for thermotaxis and unstimulated behavior; or two-tailed t-test for unstimulated behavior (depending on normality of the sample) using a significance level of 0.05. This was adequate to determine if mortality was significant." This analysis and the raw data describing mortality were not presented in this study. Metric 22: Reporting of Data Low A large amount of data was presented in the supplemental file (Zhang et al., 2019): https://doi.Org/10.1016/j.ntt.2019.03.003. Data were not clear and interpretation was dif- ficult. It appeared that no effect on development were observed in the adults following exposure to TCEP for 7-12 days, but this was not clearly discussed. Metric 23: Explanation of Unexpected Outcomes High No effects on development were observed for entire test duration in any treatment for TCEP. The lack of bioactivity observed in this study for TCEP was apparently not con- sistent with previous studies showing bioactivity in Zebrafish. This was explained in the discussion (4.6) Additional Comments: None Overall Quality Determination Medium Page 127 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 4 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ regenerative; Adult Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High clearly identified with name and CAS # Low Sourced from Sigma Aldrich, but chemical was not analytically verified by the labora- tory. High reported as 99.07% pure Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation Low High Low Authors did not use a true negative control. "Negative" controls contained either ac- etaminophen or L-ascorbic acid. A positive solvent control (0.5% DMSO) was also used. The authors presented information from previous studies to verify that ac- etaminophen or L-ascorbic acid did not affect the test organisms. No effects observed in "negative" or solvent controls No mention of randomization in this paper. Author did cite another paper which may have described randomization. Domain 3: Exposure Characterization Metric 7: Metric 8: Metric 9: Metric 10: Metric 11: Experimental System/Test Media Preparation Consistency of Exposure Administration Measurement of Test Substance Concentration Exposure Duration and Frequency Number of Exposure Groups/ Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Low The experimental system and methods for preparation of test media were described in adequate detail and appropriately accounted for the physical-chemical properties of the test substance (solvent used due to the low solubility of the test material). Measured test concentrations were not provided. High no inconsistencies were noticed or reported Low exposure concentrations were not measured, high concentration listed as 99.5 uM in supplemental data instead of a nominal value of 100 uM as stated in text High Exposure duration (12 days) was adequate to to illicit a response for some of the chemi- cals in this study (but not TCEP). High Exposure concentrations seemed adequate to illicit a response (behavior) for most chem- icals tested in this study. This was below the NOAEL for TCEP, but the purpose of the study was to compare the effects on behavior between chemicals within a specific group, so this was not determined to affect the rating of this study. High Solvent (0.5% DMSO) was used to facilitate the dissolution of the test material into the test medium. Domain 4: Test Organism Continued on next page . Page 128 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 4 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ regenerative; Adult Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Metric 13: Test Organism Characteristics High Supplemental methods description describes the test organism in more detail (Zhang et al., 2019). Test organisms were described as adults and "Test worms were manually selected to fall within a certain range of sizes and we found full worm length, after au- tomated size measurement, to be 7.3 6 2.3 mm (mean 6 SD), and tail worm length to be 7.3 mm 2.7 mm (mean 6 SD). Metric 14: Acclimatization and Pretreatment Conditions High In supplemental materials, pretreatment procedure was described as: "Animals were starved for at least 5 days before beingused for experiments and their containers were cleaned immediately prior to worm selection for experiments." This was adequate for gut-clearance. Metric 15: Number of Organisms and Replicates per Group Medium 8 individuals were used for each replicate. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Low Test conditions were fully described in supplemental methods paper (Zhang et al., 2019): "Wells of a 48- well plate with 200 ml of IO water." The authors noted that in the present study, they updated the feeding procedure, but this was not described clearly, "we fed planarians used in FR screen 2 commercial freeze-dried organic chicken liver (Amazon, Seattle, WA) to better control food quality and thus minimize animal fitness variability." It was unclear when this supplemental feeding occurred during the exposure period or if the lack of feeding could have contributed to additional mortality in some chemicals in the screen (No mortality was observed for TCEP, so this was not an issue for this Chemical). Metric 17: Outcome Assessment Methodology High Outcome assessment was adequate to describe the comparative mortality of several flame retardants following exposure to the test material. Metric 18: Consistency of Outcome High assessment methods seemed consistent across groups Assessment. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low The study did not provide enough information to allow a comparison of environmental conditions or other non-treatment-related factors across study groups. Besides the feed- ing procedure, which did not contribute to mortality for TCEP, there were no reported differences among the study groups in environmental conditions or other factors that could influence the outcome assessment. Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Continued on next page ... Page 129 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 4 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ regenerative; Adult Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Metric 21: Statistical Methods Low The authors describe the statistical procedure as: "Statistical significance was deter- mined using either a one-tailed Fisher's exact test for lethality, eye regeneration, photo- taxis, and scrunching endpoints; Mann Whitney U test for thermotaxis and unstimulated behavior; or two-tailed t-test for unstimulated behavior (depending on normality of the sample) using a significance level of 0.05. This was adequate to determine if mortality was significant." This analysis and the raw data describing behavioral effects were not presented in this study. Metric 22: Reporting of Data Low A large amount of data was presented in the supplemental file (Zhang et al., 2019): https://doi.Org/10.1016/j.ntt.2019.03.003. Data were not clear and interpretation was difficult. It appeared that no behavioral effects were observed in the regenerating worms following exposure to TCEP for 7-12 days, but this was not clearly discussed or ade- quate to characterize a dose response. Metric 23: Explanation of Unexpected Outcomes High no unexpected outcomes for entire test duration in any treatment Additional Comments: None Overall Quality Determination Medium Page 130 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 5 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Other (please specify below) (AChE) Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High clearly identified with name and CAS # Low Sourced from Sigma Aldrich, but chemical was not analytically verified by the labora- tory. High reported as 99.07% pure Domain 2: Test Design Metric 4: Negative Controls Low Authors did not use a true negative control. A positive solvent control (0.5% DMSO) was used. Metric 5: Negative Control Response High No effects on ACHE activity was reported in the solvent control Metric 6: Randomized Allocation Low No mention of randomization in this paper. Author did cite another paper which may have described randomization. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Low The experimental system and methods for preparation of test media were described in Preparation adequate detail and appropriately accounted for the physical-chemical properties of the test substance (solvent used due to the low solubility of the test material). Measured test concentrations were not provided. Metric 8: Consistency of Exposure High no inconsistencies were noticed or reported Administration Metric 9: Measurement of Test Substance Low Exposure concentrations were not measured, as this was conducted as a limit test, only Concentration one test concentration with a nominal value of 100 uM was used. Metric 10: Exposure Duration and Frequency High Exposure duration (12 days) was adequate to elicit significant loss of cholinesterase activity for the other chemical in this study, EHDP, but not TCEP. Metric 11: Number of Exposure Groups/ N/A As this was conducted as a limit test, only one concentration was used and no effects Spacing of Exposure Levels were observed. Metric 12: Testing at or Below Solubility Limit High Solvent (0.5% DMSO) was used to facilitate the dissolution of the test material into the test medium. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Supplemental methods description describes the test organism in more detail (Zhang et al., 2019). Test organisms were described as adults and "Test worms were manually selected to fall within a certain range of sizes and we found full worm length, after au- tomated size measurement, to be 7.3 6 2.3 mm (mean 6 SD), and tail worm length to be 7.3 mm 7- 2.7 mm (mean 6 SD). Continued on next page... Page 131 of 170 ------- PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Tris(2-chloroethyl) phosphate (TCEP) Environmental Hazard Evaluation HERO ID: 5469417 Table: 5 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Other (please specify below) (AChE) Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Metric 14: Acclimatization and Pretreatment Conditions High In supplemental materials, pretreatment procedure was described as: "Animals were starved for at least 5 days before beingused for experiments and their containers were cleaned immediately prior to worm selection for experiments." This was adequate for gut-clearance. Metric 15: Number of Organisms and Replicates per Group Low 8 individuals were used for each replicate. Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Medium Test conditions were fully described in supplemental methods paper (Zhang et al., 2019): "Wells of a 48- well plate with 200 ml of IO water." The authors noted that in the present study, they updated the feeding procedure, but this was not described clearly, "we fed planarians used in FR screen 2 commercial freeze-dried organic chicken liver (Amazon, Seattle, WA) to better control food quality and thus minimize animal fitness variability." It was unclear when this supplemental feeding occurred during the exposure period or if the lack of feeding could have contributed to additional effects in the screen (No effects were observed following exposure to TCEP, so this was not an issue for this chemical). Metric 17: Outcome Assessment Methodology High Outcome assessment was adequate to describe the comparative loss of cholinesterase activity following exposure to two flame retardants, TCEP and EHDP. Metric 18: Consistency of Outcome High assessment methods seemed consistent across groups Assessment. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low The study did not provide enough information to allow a comparison of environmental conditions or other non-treatment-related factors across study groups. Besides the feed- ing procedure, which did not contribute to mortality for TCEP, there were no reported differences among the study groups in environmental conditions or other factors that could influence the outcome assessment. Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data N/A statistical analysis not applied as this was a limit test Low Data were not clear and interpretation was difficult. It appeared that no loss of cholinesterase activity in the adults following exposure to TCEP for 7-12 days, but this was not clearly discussed and raw data were not available. Continued on next page ... Page 132 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 5 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Other (please specify below) (AChE) Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Metric 23: Explanation of Unexpected Outcomes High No mortalities for entire test duration in any treatment. The lack of bioactivity observed in this study for TCEP was not consistent with previous studies showing bioactivity in Zebrafish. This was explained in the discussion (4.6) as being related to the loss of cholinesterase activity. Additional Comments: None Overall Quality Determination Medium Page 133 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 6 of 6 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High clearly identified with name and CAS # Low Sourced from Sigma Aldrich, but chemical was not analytically verified by the labora- tory. High reported as 99.07% pure Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation Low High Low Authors did not use a true negative control. "Negative" controls contained either ac- etaminophen or L-ascorbic acid. A positive solvent control (0.5% DMSO) was also used. The authors presented information from previous studies to verify that ac- etaminophen or L-ascorbic acid did not affect the test organisms. No effects observed in "negative" or solvent controls no mention of randomization in this paper. Author did cite another paper which may have described randomization Domain 3: Exposure Characterization Metric 7: Metric 8: Metric 9: Metric 10: Experimental System/Test Media Preparation Consistency of Exposure Administration Measurement of Test Substance Concentration Exposure Duration and Frequency Metric 11: Number of Exposure Groups/ Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Low The experimental system and methods for preparation of test media were described in adequate detail and appropriately accounted for the physical-chemical properties of the test substance (solvent used due to the low solubility of the test material). Measured test concentrations were not provided. High no inconsistencies were noticed or reported Low Exposure concentrations were not measured, high concentration listed as 99.5 uM in supplemental data instead of a nominal value of 100 uM as stated in text High Exposure duration (12 days) was adequate to to illicit a response for some of the chem- icals in this study (but not TCEP, as no activity was observed up to the highest test con- centration). High Exposure concentrations seemed adequate to illicit a response (behavior) for most chem- icals tested in this study. This was below the NOAEL for TCEP, but the purpose of the study was to compare the effects on behavior between chemicals within a specific group, so this was not determined to affect the rating of this study. High Solvent (0.5% DMSO) was used to facilitate the dissolution of the test material into the test medium. Domain 4: Test Organism Continued on next page . Page 134 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 6 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S„ Ireland, D„ Sipes, N, S„ Behl, M„ Collins, E, S, (2019), Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66, Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g.. Annelids, Nematodes); Dugesia japonica; Adult Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Metric 13; Test Organism Characteristics High Supplemental methods description describes the test organism in more detail (Zhang et al., 2019). Test organisms were described as adults and "Test worms were manually selected to fall within a certain range of sizes and we found full worm length, after au- tomated size measurement, to be 7.3 6 2.3 mm (mean 6 SD), and tail worm length to be 7.3 mm 2.7 mm (mean 6 SD). Metric 14; Acclimatization and Pretreatment Conditions High In supplemental materials, pretreatment procedure was described as: "Animals were starved for at least 5 days before beingused for experiments and their containers were cleaned immediately prior to worm selection for experiments." This was adequate for gut-clearance. Metric 15; Number of Organisms and Replicates per Group Medium 8 individuals were used for each replicate. Domain 5; Outcome Assessment Metric 16; Adequacy of Test Conditions Low Test conditions were fully described in supplemental methods paper (Zhang et al., 2019): "Wells of a 48- well plate with 200 ml of IO water." The authors noted that in the present study, they updated the feeding procedure, but this was not described clearly, "we fed planarians used in FR screen 2 commercial freeze-dried organic chicken liver (Amazon, Seattle, WA) to better control food quality and thus minimize animal fitness variability." It was unclear when this supplemental feeding occurred during the exposure period or if the lack of feeding could have contributed to additional mortality in some chemicals in the screen (No mortality was observed for TCEP, so this was not an issue for this Chemical). Metric 17; Outcome Assessment Methodology Medium Outcome assessment was adequate to describe the comparative behavioral changes following exposure to the test material and other flame retardants. Metric 18; Consistency of Outcome High assessment methods seemed consistent across groups Assessment. Domain 6; Confounding / Variable Control Metric 19; Confounding Variables in Test Design and Procedures Metric 20; Outcomes Unrelated to Exposure High The study did not provide enough information to allow a comparison of environmental conditions or other non-treatment-related factors across study groups. Besides the feed- ing procedure, which did not contribute to mortality for TCEP, there were no reported differences among the study groups in environmental conditions or other factors that could influence the outcome assessment. Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure (e.g., infection) that could influence the outcome assessment. Domain 7; Data Presentation and Analysis Continued on next page ... Page 135 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469417 Table: 6 of 6 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Zhang, S., Ireland, D., Sipes, N. S., Behl, M., Collins, E. S. (2019). Screening for neurotoxic potential of 15 flame retardants using freshwater planarians. Neurotoxicology and Teratology 7354-66. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Aquatic (freshwater); Water; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Dugesia japonica\ Adult Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5469417 Domain Metric Rating Comments Metric 21: Statistical Methods High The authors describe the statistical procedure as: "Statistical significance was deter- mined using either a one-tailed Fisher's exact test for lethality, eye regeneration, photo- taxis, and scrunching endpoints; Mann Whitney U test for thermotaxis and unstimulated behavior; or two-tailed t-test for unstimulated behavior (depending on normality of the sample) using a significance level of 0.05. This was adequate to determine if mortality was significant." This analysis and the raw data describing behavioral effects were not presented in this study. Metric 22: Reporting of Data High A large amount of data was presented in the supplemental file (Zhang et al., 2019): https://doi.Org/10.1016/j.ntt.2019.03.003. Data were not clear and interpretation was difficult. It appeared that no behavioral effects were observed in the regenerating worms following exposure to TCEP for 7-12 days, but this was not clearly discussed or ade- quate to characterize a dose response.v Metric 23: Explanation of Unexpected Outcomes High no unexpected outcomes for entire test duration in any treatment Additional Comments: None Overall Quality Determination Medium Page 136 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5353113 Table: 1 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Fernie, K. J., Palace, V., Peters, L. E., Basu, N., Letcher, R. J., Karouna-Renier, N. K., Schultz, S. L., Lazarus, R. S., Rattner, B. A. (2015). Investigating endocrine and physiological parameters of captive American kestrels exposed by diet to selected organophosphate flame retardants. Environmental Science and Technology 49(12):7448-7455. Overall Duration: > 21 days; Exposure Duration: 11-21 days Terrestrial; Food/Diet; Dietary Vertebrate; Avian; Falco sparverius\ Adult Hepatic/Liver Tris(2-chloroethyl) phosphate (TCEP) 5353113 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High identified in text and abstract Metric 2: Test Substance Source Low TCEP was purchased from Sigma-Aldrich but not analytically verified Metric 3: Test Substance Purity High purity reported as >97% Domain 2: Test Design Metric 4: Negative Controls High Negative control of safflower oil (the delivery medium) was used. Metric 5: Negative Control Response High No reported mortalities in the negative controls and significant differences in the effects were observed between the controls and exposure groups. Metric 6: Randomized Allocation Low random dosing was not reported Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High Exposure preparation was well documented. Each kestrel ate one cockerel per day that Preparation had been injected with 50 "L of a safflower oil solution containing TCEP. Dosage was calculated by weight to ensure consistent weight between the flame retardants used int he study. Metric 8: Consistency of Exposure High No inconsistencies were reported Administration Metric 9: Measurement of Test Substance High actual measured concentrations were reported Concentration Metric 10: Exposure Duration and Frequency High exposure duration (21 days) was long enough to assess outcomes Metric 11: Number of Exposure Groups/ N/A Authors used only one test concentration, normalized by body weight, across multiple Spacing of Exposure Levels chemicals so dosage spacing is not relevant in this case Metric 12: Testing at or Below Solubility Limit N/A dietary dose was administered via vegetable oil carrier, therefore the solubility was not relevant Domain 4: Test Organism Metric 13: Test Organism Characteristics High organisms were adequately described and appropriate Metric 14: Acclimatization and Pretreatment Conditions Low no description of acclimatization process was provided Metric 15: Number of Organisms and Replicates per Group Low 7 individuals for each chemical with no replication. Given that the intention was to char- acterize the comparative effects of the test material and not to calculate a dose response, this is sufficient for statistical analysis Continued on next page ... Page 137 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5353113 Table: 1 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Fernie, K. J., Palace, V., Peters, L. E., Basu, N., Letcher, R. J., Karouna-Renier, N. K., Schultz, S. L., Lazarus, R. S., Rattner, B. A. (2015). Investigating endocrine and physiological parameters of captive American kestrels exposed by diet to selected organophosphate flame retardants. Environmental Science and Technology 49(12):7448-7455. Overall Duration: > 21 days; Exposure Duration: 11-21 days Terrestrial; Food/Diet; Dietary Vertebrate; Avian; Falco sparverius\ Adult Hepatic/Liver Tris(2-chloroethyl) phosphate (TCEP) 5353113 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment. High test conditions were adequate and reasonably well documented High methods were adequate to assess hepatic and thyroid hormone levels High no inconsistencies were reported Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High no confounding variables were reported High no unrelated outcomes were reported Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes Low End points were compared for each treatment to vehicle-treated controls by parametric analysis of variance (ANOVA). Calculations were not provided High data was reported adequately and clearly High no unexpected outcomes were reported Additional Comments: None Overall Quality Determination High Page 138 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5353113 Table: 2 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Fernie, K. J., Palace, V., Peters, L. E., Basu, N., Letcher, R. J., Karouna-Renier, N. K., Schultz, S. L., Lazarus, R. S., Rattner, B. A. (2015). Investigating endocrine and physiological parameters of captive American kestrels exposed by diet to selected organophosphate flame retardants. Environmental Science and Technology 49(12):7448-7455. Overall Duration: > 21 days; Exposure Duration: 11-21 days Terrestrial; Food/Diet; Dietary Vertebrate; Avian; Falco sparverius\ Adult Other (please specify below) (Thyroid Function) Tris(2-chloroethyl) phosphate (TCEP) 5353113 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High identified in text and abstract Metric 2: Test Substance Source Low TCEP was purchased from Sigma-Aldrich but not analytically verified Metric 3: Test Substance Purity High purity reported as >97% Domain 2: Test Design Metric 4: Negative Controls High negative control of safflower oil (the delivery medium) was used Metric 5: Negative Control Response High No reported mortalities in the negative controls and significant differences in the ef- fects were observed between the concentrations of FT3 and FT4 thyroid hormones and thyroid gland histology between the control and exposure group of TCEP Metric 6: Randomized Allocation Low random dosing was not reported Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High exposure preparation was well documented. Each kestrel ate one cockerel per day that Preparation had been injected with 50 "L of a safflower oil solution containing TCEP. Dosage was calculated by weight to ensure consistent weight between the flame retardants used int he study Metric 8: Consistency of Exposure High no inconsistencies were reported Administration Metric 9: Measurement of Test Substance High actual measured concentrations were reported Concentration Metric 10: Exposure Duration and Frequency High exposure duration (21 days) was long enough to assess outcomes Metric 11: Number of Exposure Groups/ N/A authors used only one test concentration, normalized by body weight, across multiple Spacing of Exposure Levels chemicals so dosage spacing is not relevant in this case Metric 12: Testing at or Below Solubility Limit N/A dietary dose was administered via vegetable oil carrier, therefore the solubility was not relevant. Domain 4: Test Organism Metric 13: Test Organism Characteristics High organisms were adequately described and appropriate Metric 14: Acclimatization and Pretreatment Low no description of acclimatization process was provided Conditions Metric 15: Number of Organisms and Low 7 individuals for each chemical with no replication. Given that the intention was to char- Replicates per Group acterize the comparative effects of the test material and not to calculate a dose response, this is sufficient for statistical analysis Continued on next page ... Page 139 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5353113 Table: 2 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Fernie, K. J., Palace, V., Peters, L. E., Basu, N., Letcher, R. J., Karouna-Renier, N. K., Schultz, S. L., Lazarus, R. S., Rattner, B. A. (2015). Investigating endocrine and physiological parameters of captive American kestrels exposed by diet to selected organophosphate flame retardants. Environmental Science and Technology 49(12):7448-7455. Overall Duration: > 21 days; Exposure Duration: 11-21 days Terrestrial; Food/Diet; Dietary Vertebrate; Avian; Falco sparverius\ Adult Other (please specify below) (Thyroid Function) Tris(2-chloroethyl) phosphate (TCEP) 5353113 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment. High test conditions were adequate and reasonably well documented High methods were adequate to characterize the comparative toxicity of several related chemi- cals at the same exposure concentration High no inconsistencies were reported Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High no confounding variables were reported High no unrelated outcomes were reported Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes Low High High differences between the chemicals were compared for each treatment to vehicle-treated controls by repeated measures (RM) analysis of variance (ANOVA). Calculations were not provided. data was reported adequately no effects were not unexpected, explanation was adequate Additional Comments: None Overall Quality Determination High Page 140 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5353113 Table: 3 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Fernie, K. J., Palace, V., Peters, L. E., Basu, N., Letcher, R. J., Karouna-Renier, N. K., Schultz, S. L., Lazarus, R. S., Rattner, B. A. (2015). Investigating endocrine and physiological parameters of captive American kestrels exposed by diet to selected organophosphate flame retardants. Environmental Science and Technology 49(12):7448-7455. Overall Duration: > 21 days; Exposure Duration: 11-21 days Terrestrial; Food/Diet; Dietary Vertebrate; Avian; Falco sparverius\ Adult ADME (biotransformation) Tris(2-chloroethyl) phosphate (TCEP) 5353113 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High identified in text and abstract Metric 2: Test Substance Source Low TCEP was purchased from Sigma-Aldrich but not analytically verified Metric 3: Test Substance Purity High purity reported as >97% Domain 2: Test Design Metric 4: Negative Controls High negative control of safflower oil (the delivery medium) was used Metric 5: Negative Control Response High No reported mortalities in the negative controls Metric 6: Randomized Allocation Low Random dosing was not reported Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High exposure preparation was well documented. Each kestrel ate one cockerel per day that Preparation had been injected with 50 "L of a safflower oil solution containing TCEP. Dosage was calculated by weight to ensure consistent weight between the flame retardants used int he study. Metric 8: Consistency of Exposure High no inconsistencies were reported Administration Metric 9: Measurement of Test Substance High actual measured concentrations were reported Concentration Metric 10: Exposure Duration and Frequency High exposure duration (21 days) was long enough to assess outcomes Metric 11: Number of Exposure Groups/ N/A authors used only one test concentration, normalized by body weight, across multiple Spacing of Exposure Levels chemicals so dosage spacing is not relevant in this case Metric 12: Testing at or Below Solubility Limit N/A Dietary dose was administered via vegetable oil carrier, therefore the solubility was not relevant. Domain 4: Test Organism Metric 13: Test Organism Characteristics High organisms were adequately described and appropriate Metric 14: Acclimatization and Pretreatment Low no description of acclimatization process was provided Conditions Metric 15: Number of Organisms and Low 7 individuals for each chemical with no replication. Given that the intention was to char- Replicates per Group acterize the comparative effects of the test material and not to calculate a dose response, this is sufficient for statistical analysis Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High test conditions were adequate and reasonably well documented Continued on next page ... Page 141 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5353113 Table: 3 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Fernie, K. J., Palace, V., Peters, L. E., Basu, N., Letcher, R. J., Karouna-Renier, N. K., Schultz, S. L., Lazarus, R. S., Rattner, B. A. (2015). Investigating endocrine and physiological parameters of captive American kestrels exposed by diet to selected organophosphate flame retardants. Environmental Science and Technology 49(12):7448-7455. Overall Duration: > 21 days; Exposure Duration: 11-21 days Terrestrial; Food/Diet; Dietary Vertebrate; Avian; Falco sparverius\ Adult ADME (biotransformation) Tris(2-chloroethyl) phosphate (TCEP) 5353113 Domain Metric Rating Comments Metric 17: Metric 18: Outcome Assessment Methodology Consistency of Outcome Assessment High High methods were adequate to characterize the comparative toxicity of several related chemi- cals at the same exposure concentration no inconsistencies were reported Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High High no confounding variables were reported no unrelated outcomes were reported Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes Low High High effects were compared for each treatment to vehicle-treated controls by nonparametric analysis of variance (ANOVA) and Repeated Measures ANOVA on ranked data using SAS 9.3. Calculations were not provided, data was reported adequately low TCEP levels in organisms was given possible explanations Additional Comments: None Overall Quality Determination High Page 142 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5165206 Table: 1 of 1 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Stauffer Chem Co, (1981). Toxicology reports on FYROL FR-2 (volume I - II) with attachments and cover letter dated 020381. 8100271#88-8100271. Overall Duration: > 21 days; Exposure Duration: 4 - 10 days Terrestrial; Food/Diet; Dietary Vertebrate; Avian; Gallus gallus domesticus\ Adult Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5165206 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity Uninformative High Low Fyrol CEF. Lot f 3587-2-1, was identified as the test chemical with no other identifiers (e.g., CASRN, structure, formula). Online search shows FYROL CEF as a synonym for Tris(2-chloroethyl) phosphate CAS 119-96-8. However, Fyrol CEF is also listed as a synonym for at least one other CASRN. Source reported as Specialty Chemical Division Purity not reported. Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High High Low negative and positive controls used. Negative response for positive and negative controls. Allocation method not reported. Domain 3: Exposure Characterization Metric 7: Metric 8: Metric 9: Metric 10: Metric 11: Metric 12: Experimental System/Test Media Low Preparation Consistency of Exposure High Administration Measurement of Test Substance Medium Concentration Exposure Duration and Frequency High Number of Exposure Groups/ Uninformative Spacing of Exposure Levels Testing at or Below Solubility Limit N/A Reported details were limited Exposure administration consistent across groups. Method of measuring exposure concentration not reported. Exposure duration was adequate for the test. Only a single exposure level for test with no response. Dosage administered orally. Domain 4: Test Organism Metric 13: Metric 14: Metric 15: Test Organism Characteristics Acclimatization and Pretreatment Conditions Number of Organisms and Replicates per Group Low Only age of chickens reported. Low Acclimation or pretreatment not reported. Medium Number of organism per group and replicates were appropriate for test. Domain 5: Outcome Assessment Metric 16: Metric 17: Adequacy of Test Conditions Outcome Assessment Methodology High Low Environmental conditions not reported. Response to treatment was zero. Continued on next page . Page 143 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5165206 Table: 1 of 1 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Stauffer Chem Co, (1981). Toxicology reports on FYROL FR-2 (volume I - II) with attachments and cover letter dated 020381. 8100271#88-8100271. Overall Duration: > 21 days; Exposure Duration: 4 - 10 days Terrestrial; Food/Diet; Dietary Vertebrate; Avian; Gallus gallus domesticus\ Adult Behavioral Tris(2-chloroethyl) phosphate (TCEP) 5165206 Domain Metric Rating Comments Metric 18: Consistency of Outcome Assessment High Outcome assessments were consistent. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High Medium No confounding variables were reported, no differences were reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes Low High High Qualitative score for behavior were summed. All outcomes reported, no unexpected outcomes reported. Additional Comments: None Overall Quality Determination Uninformative Page 144 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3479540 Table: 1 of 1 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Behl, M., Hsieh, J. H., Shafer, T. J., Mundy, W. R., Rice, J. R., Boyd, W. A., Freedman, J. H., Hunter, E. S., Jarema, K. A., Padilla, S., Tice, R. R. (2015). Use of alternative assays to identify and prioritize organophosphorus flame retardants for potential developmental and neurotoxicity. Neurotoxicology and Teratology 52(PtB):181-193. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Food/Diet; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans\ Bristol N2; Larvae Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 3479540 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity Metric 2: Test Substance Source Metric 3: Test Substance Purity High Test substance was identified by name and CAS # Low Test substance source was reported as Sigma-Aldrich, but it did not appear to be ana- lyzed by the performing laboratory High Test substance purity was 98.95% Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High All treated groups were compared to a DMSO vehicle controls. High The biological response of the negative control was reported and adequate. Untreated nematodes reached L4 stage in growth. Low Researchers did not report how organisms were allocated to study groups. Domain 3: Exposure Characterization Metric 7: Metric 8: Metric 9: Metric 10: Metric 11: Metric 12: Experimental System/Test Media Preparation Consistency of Exposure Administration Measurement of Test Substance Concentration Exposure Duration and Frequency Number of Exposure Groups/ Spacing of Exposure Levels Testing at or Below Solubility Limit Low DMSO solvent was used in the preparation of the test media stock solutions, but little other information was provided on preparation. The experimental system was 96 well plates. High Details of exposure administration were reported and exposures were administered consistently across study groups. 48h exposure in 96 well plates with 50 nematodes per well. Low Exposure concentrations were not measured or measurements were not reported. High The duration of exposure was reported and suitable for the study type-48h exposure. High 12 exposure groups were reported with a concentration range from luM to 200uM. Found in the supplementary material. High DMSO solvent concentration was appropriate at 0.1% (v/v) Domain 4: Test Organism Metric 13: Test Organism Characteristics Metric 14: Acclimatization and Pretreatment Conditions Metric 15: Number of Organisms and Replicates per Group High The test organisms were adequately described and were obtained from a reliable source Low The study did not report whether test organisms were acclimatized Medium The numbers of test organisms and replicates were reported and sufficient to character- ize toxicological effect. 50 nematodes per well with at least 3 replicates of each concen- tration according to the supplementary material. Continued on next page ... Page 145 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3479540 Table: 1 of 1 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Behl, M., Hsieh, J. H., Shafer, T. J., Mundy, W. R., Rice, J. R., Boyd, W. A., Freedman, J. H., Hunter, E. S., Jarema, K. A., Padilla, S., Tice, R. R. (2015). Use of alternative assays to identify and prioritize organophosphorus flame retardants for potential developmental and neurotoxicity. Neurotoxicology and Teratology 52(PtB):181-193. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Food/Diet; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans\ Bristol N2; Larvae Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 3479540 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions Metric 17: Outcome Assessment Methodology Metric 18: Consistency of Outcome Assessment Low Boyd et al 2009 was cited for organism maintenance. Kept at 20 C and fed E.coli, other- wise little other housing information was provided. Medium Rice et al 2014 was cited for assessment methodology. Some details were provided in the paper- organisms' gross morphology and developmental stage were assessed as well as size High Organisms were assessed 48h after exposure using gross morphology and developmental stage. Biosort was used to assess size and number of organisms Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure Low The study did not provide enough information to allow a comparison of environmental conditions or other non-treatment-related factors across study groups. Medium There was no information in the study to suggest differences among groups in animal attrition or health outcomes unrelated to exposure Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High Statistical methods were adequately described Data for exposure-related findings were presented for each treatment and control group and were adequate to determine values for the endpoint of interest. Data was provided in the supplementary material. Control response was described in the text. There were no unexpected outcomes Additional Comments: None Overall Quality Determination Medium Page 146 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3975281 Table: 1 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Behl, M., Rice, J. R., Smith, M. V., Co, C. A., Bridge, M. F., Hsieh, J. H., Freedman, J. H., Boyd, W. A. (2016). Editor's highlight: Comparative toxicity of organophosphate flame retardants and polybrominated diphenyl ethers to Caenorhabditis elegans. Toxicological Sciences 154(2):241-252. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans\ Bristol N2 (wild-type); Larvae Reproductive/Teratogenic Tris(2-chloroethyl) phosphate (TCEP) 3975281 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High TCEP (tris(2-chloroethyl) Metric 2: Test Substance Source High Purchased from Sigma Aldrich Chemical Co Metric 3: Test Substance Purity High 98.95% Purity Domain 2: Test Design Metric 4: Negative Controls High Authors only reported two positive control groups used, containing chlorpyrifos and "aromatic OPFR TOCP". Metric 5: Negative Control Response High No toxicity response from the positive control groups used. Metric 6: Randomized Allocation Low How organisms were allocation was not reported. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Study did not comment on whether agar plates or well-plates were sealed. Preparation Metric 8: Consistency of Exposure High Exposure administration was consistent for all groups. Administration Metric 9: Measurement of Test Substance Medium Exposure concentrations were measured at beginning of exposure, but not at the end of Concentration the exposure period. Metric 10: Exposure Duration and Frequency High Exposure duration and frequency appropriate for test. Metric 11: Number of Exposure Groups/ Low Number exposure groups and frequency were appropriate for other tested chemicals, Spacing of Exposure Levels however no adverse effects were reported for TCEP. Metric 12: Testing at or Below Solubility Limit Low Reporting were insufficient to determine if solubility limits were exceeded. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Test organisms were adequately described and source provided. Metric 14: Acclimatization and Pretreatment High pretreatments and acclimation periods were adequately described. Conditions Metric 15: Number of Organisms and Medium Number of test organisms and replicates were adequate. Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Test organism environmental conditions were acceptable. Metric 17: Outcome Assessment Methodology High Intended outcomes reported. Continued on next page ... Page 147 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3975281 Table: 1 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Behl, M., Rice, J. R., Smith, M. V., Co, C. A., Bridge, M. F., Hsieh, J. H., Freedman, J. H., Boyd, W. A. (2016). Editor's highlight: Comparative toxicity of organophosphate flame retardants and polybrominated diphenyl ethers to Caenorhabditis elegans. Toxicological Sciences 154(2):241-252. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans\ Bristol N2 (wild-type); Larvae Reproductive/Teratogenic Tris(2-chloroethyl) phosphate (TCEP) 3975281 Domain Metric Rating Comments Metric 18: Consistency of Outcome Assessment High Assessments were consistent across groups Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High Medium No reported differences among groups. No reported differences among groups. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Low Low Statistical methods were clearly described. Test results for exposure groups were reported in poorly rendered, graphs and only sum- marized cursorily in the text. No adverse outcomes were reported. No explanations was provided why TCEP was the only flame retardant that was inactive across all of the C.elegans endpoints. Additional Comments: None Overall Quality Determination High Page 148 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3975281 Table: 2 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Behl, M., Rice, J. R., Smith, M. V., Co, C. A., Bridge, M. F., Hsieh, J. H., Freedman, J. H., Boyd, W. A. (2016). Editor's highlight: Comparative toxicity of organophosphate flame retardants and polybrominated diphenyl ethers to Caenorhabditis elegans. Toxicological Sciences 154(2):241-252. Overall Duration: 4-10 days; Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans\ Bristol N2 (wild-type); Larvae Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 3975281 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High TCEP (tris(2-chloroethyl) Metric 2: Test Substance Source High Purchased from Sigma Aldrich Chemical Co Metric 3: Test Substance Purity High 98.95% Purity Domain 2: Test Design Metric 4: Negative Controls High Authors only reported two positive control groups used, containing chlorpyrifos and "aromatic OPFR TOCP". Metric 5: Negative Control Response High No toxicity response from the positive control groups used. Metric 6: Randomized Allocation Low How organisms were allocation was not reported. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Study did not comment on whether agar plates or well-plates were sealed. Preparation Metric 8: Consistency of Exposure High Exposure administration was consistent for all groups. Administration Metric 9: Measurement of Test Substance Medium Exposure concentrations were measured at beginning of exposure, but not at the end of Concentration the exposure period. Metric 10: Exposure Duration and Frequency High Exposure duration and frequency appropriate for test. Metric 11: Number of Exposure Groups/ Low Number exposure groups and frequency were appropriate for other tested chemicals, Spacing of Exposure Levels however no adverse effects were reported for TCEP. Metric 12: Testing at or Below Solubility Limit Low Reporting were insufficient to determine if solubility limits were exceeded. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Test organisms were adequately described and source provided. Metric 14: Acclimatization and Pretreatment High pretreatments and acclimation periods were adequately described. Conditions Metric 15: Number of Organisms and Medium Number of test organisms and replicates were adequate. Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Test organism environmental conditions were acceptable. Metric 17: Outcome Assessment Methodology High Intended outcomes reported. Metric 18: Consistency of Outcome High Assessments were consistent across groups Assessment. Continued on next page ... Page 149 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3975281 Table: 2 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Behl, M., Rice, J. R., Smith, M. V., Co, C. A., Bridge, M. F., Hsieh, J. H., Freedman, J. H., Boyd, W. A. (2016). Editor's highlight: Comparative toxicity of organophosphate flame retardants and polybrominated diphenyl ethers to Caenorhabditis elegans. Toxicological Sciences 154(2):241-252. Overall Duration: 4-10 days; Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans\ Bristol N2 (wild-type); Larvae Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 3975281 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High No reported differences among groups. Design and Procedures Metric 20: Outcomes Unrelated to Exposure Medium No reported differences among groups. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Statistical methods were clearly described. Low Test results for exposure groups were reported in poorly rendered, graphs and only sum- marized cursorily in the text. No adverse outcomes were reported. Low No explanations was provided why TCEP was the only flame retardant that was inactive across all of the C.elegans endpoints. Additional Comments: None Overall Quality Determination High Page 150 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3975281 Table: 3 of 3 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Behl, M., Rice, J. R., Smith, M. V., Co, C. A., Bridge, M. F., Hsieh, J. H., Freedman, J. H., Boyd, W. A. (2016). Editor's highlight: Comparative toxicity of organophosphate flame retardants and polybrominated diphenyl ethers to Caenorhabditis elegans. Toxicological Sciences 154(2):241-252. Overall Duration: 4-10 days; Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans\ Bristol N2 (wild-type); Larvae Behavioral Tris(2-chloroethyl) phosphate (TCEP) 3975281 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High TCEP (tris(2-chloroethyl) Metric 2: Test Substance Source High Purchased from Sigma Aldrich Chemical Co Metric 3: Test Substance Purity High 98.95% Purity Domain 2: Test Design Metric 4: Negative Controls High Authors only reported two positive control groups used, containing chlorpyrifos and "aromatic OPFR TOCP". Metric 5: Negative Control Response High No toxicity response from the positive control groups used. Metric 6: Randomized Allocation Low How organisms were allocation was not reported. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media Medium Study did not comment on whether agar plates or well-plates were sealed. Preparation Metric 8: Consistency of Exposure High Exposure administration was consistent for all groups. Administration Metric 9: Measurement of Test Substance Medium Exposure concentrations were measured at beginning of exposure, but not at the end of Concentration the exposure period. Metric 10: Exposure Duration and Frequency High Exposure duration and frequency appropriate for test. Metric 11: Number of Exposure Groups/ Low Number exposure groups and frequency were appropriate for other tested chemicals, Spacing of Exposure Levels however no adverse effects were reported for TCEP. Metric 12: Testing at or Below Solubility Limit Low Reporting were insufficient to determine if solubility limits were exceeded. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Test organisms were adequately described and source provided. Metric 14: Acclimatization and Pretreatment High pretreatments and acclimation periods were adequately described. Conditions Metric 15: Number of Organisms and Medium Number of test organisms and replicates were adequate. Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High Test organism environmental conditions were acceptable. Metric 17: Outcome Assessment Methodology High Intended outcomes reported. Metric 18: Consistency of Outcome High Assessments were consistent across groups Assessment. Continued on next page ... Page 151 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 3975281 Table: 3 of 3 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Behl, M., Rice, J. R., Smith, M. V., Co, C. A., Bridge, M. F., Hsieh, J. H., Freedman, J. H., Boyd, W. A. (2016). Editor's highlight: Comparative toxicity of organophosphate flame retardants and polybrominated diphenyl ethers to Caenorhabditis elegans. Toxicological Sciences 154(2):241-252. Overall Duration: 4-10 days; Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans\ Bristol N2 (wild-type); Larvae Behavioral Tris(2-chloroethyl) phosphate (TCEP) 3975281 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High No reported differences among groups. Design and Procedures Metric 20: Outcomes Unrelated to Exposure Medium No reported differences among groups. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Statistical methods were clearly described. Low Test results for exposure groups were reported in poorly rendered, graphs and only sum- marized cursorily in the text. No adverse outcomes were reported. Low No explanations was provided why TCEP was the only flame retardant that was inactive across all of the C.elegans endpoints. Additional Comments: None Overall Quality Determination High Page 152 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469475 Table: 1 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Xu, T., Li, P., Wu, S., Lei, L., He, D. (2017). Tris(2-chloroethyl) phosphate (TCEP) and tris(2-chloropropyl) phosphate (TCPP) induce locomotor deficits and dopaminergic degeneration in Caenorhabditis elegans. Toxicology Research 6(l):63-72. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans; Wild Type (Bristol, N2); Larvae Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 5469475 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Name and CASRN were reported. Metric 2: Test Substance Source High Sourced from Sigma Aldrich. Metric 3: Test Substance Purity High All chemicals were Analytical Grade. Domain 2: Test Design Metric 4: Negative Controls High Control was K Medium as were the rest of the treatments. Metric 5: Negative Control Response High Body length of control reported in Figure 2, Al; seems appropriate for baseline as low concentration TCEP treatments had similar body lengths. Metric 6: Randomized Allocation Low No mention of how organisms were allocated. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High "TCEP solutions were prepared in K-medium and the control groupis K-medium. Preparation Worms were exposed to a series of concentrations of TCEP (50, 250, 500, 750, 1000 mg in 24-well plates." Post exposure set up adequately described. Metric 8: Consistency of Exposure Medium Test organisms exposed for 3 days in 24-well plates. Lighting and other incubation Administration conditions not described. Metric 9: Measurement of Test Substance Medium Exposure concentrations were not measured but based on professional judgment of Concentration experimental design and nature of test substance, actual concentrations are likely to be similar to nominal concentrations. These minor uncertainties or limitations are unlikely to have a substantial impact on results. Metric 10: Exposure Duration and Frequency Medium Unclear if 3 day exposure duration with endpoints taken immediately post-exposure is sufficient for determining impact on body length. Metric 11: Number of Exposure Groups/ High Exposure covered a wide range with good spacing, 0-1000 mg/L. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium Sigma Aldrich states TCEP solubility in water is 50 mg/mL (50 g/L); 1000 mg/L (1 g/ L), the high dose, would be far under the solubility limit. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Good description of C. elegans and how test organisms were obtained. "All strains of C. elegans were obtained from the Caenorhabditis Genetics Center (University of Min- nesota, Minneapolis, MN, USA), and maintained in terms of standard protocols as previ- ously described." Metric 14: Acclimatization and Pretreatment Low Authors did not state if organisms were acclimated to 24-well plates prior to chemical Conditions exposure. Continued on next page... Page 153 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469475 Table: 1 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Xu, T., Li, P., Wu, S., Lei, L., He, D. (2017). Tris(2-chloroethyl) phosphate (TCEP) and tris(2-chloropropyl) phosphate (TCPP) induce locomotor deficits and dopaminergic degeneration in Caenorhabditis elegans. Toxicology Research 6(l):63-72. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans\ Wild Type (Bristol, N2); Larvae Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 5469475 Domain Metric Rating Comments Metric 15: Number of Organisms and Replicates per Group Medium Sufficient to establish an adequate response. 50-100 worms per exposure concentration, experiments performed in quadruplet. Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment Medium High High Details on total volume per well (assuming 500 uL) as well as temperature and lighting during exposure in 24-well plates lacking. Authors reported how lengths were assessed: "After being exposed to TCEP (0, 50, 250, 500, 750, 1000 mg/L)...for 3 d, worms were washed three times with M9 buffer, and then transferred to agar-padded slides and sealed with a coverslip which were immobi- lized with 100 mM sodium azide. Then body lengths of nematodes were measured using an imaging system." No mention of any inconsistencies. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High High No reported differences of any variables that would alter the outcome. No unrelated issues were reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High "All data were expressed as mean ± Standard Deviation (SD). Mean differences be- tween treated groups and controls were determined by one-way analysis of variance (ANOVA), followed by Dunnett"s test. A p-value of less than 0.05 was considered sig- nificant." Data for control and treatment groups were reported graphically with standard deviation (Figure 2, Al) and in text form. No unexpected outcomes, deviations were reasonable. Additional Comments: The form 3 for biomarker endpoint applies to GFP expression in BZ555 and YFP expression in NL5901 strains. The form 3 for neurological endpoint applies to both local movement and locomotor assays. Well reported study. Overall Quality Determination High Page 154 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469475 Table: 2 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Xu, T., Li, P., Wu, S., Lei, L., He, D. (2017). Tris(2-chloroethyl) phosphate (TCEP) and tris(2-chloropropyl) phosphate (TCPP) induce locomotor deficits and dopaminergic degeneration in Caenorhabditis elegans. Toxicology Research 6(1 ):63-72. Overall Duration: > 21 days; Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans; Wild Type (Bristol, N2); Larvae Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469475 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Name and CASRN were reported. Metric 2: Test Substance Source High Sourced from Sigma Aldrich. Metric 3: Test Substance Purity High Percent purity not reported however chemicals stated to be Analytical Grade. Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High Control was K Medium as were the rest of the treatments. Medium Control response of near 100% survival, from graph. However, it was unclear if this response was scaled to 100% of control survival. Low No mention of how organisms were allocated. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High "TCEP solutions were prepared in K-medium and the control groupis K-medium. Preparation Worms were exposed to a series of concentrations of TCEP (50, 250, 500, 750, 1000 mg in 24-well plates." Post exposure set up adequately described. Metric 8: Consistency of Exposure Medium Nothing to suggest exposure was inconsistent across groups. Administration Metric 9: Measurement of Test Substance Medium Concentrations not measured but no indication that measured concentrations should Concentration deviate from nominal concentrations. Metric 10: Exposure Duration and Frequency High Sufficient duration (3 days) to obtain mortality over time post-exposure. Metric 11: Number of Exposure Groups/ High Exposure covered a wide range with good spacing, 0-1000 mg/L. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High Sigma Aldrich states TCEP solubility in water is 50 mg/mL (50 g/L); 1000 mg/L (1 g/ L), the high dose, would be far under the solubility limit. Domain 4: Test Organism Metric 13: Test Organism Characteristics Metric 14: Acclimatization and Pretreatment Conditions Metric 15: Number of Organisms and Replicates per Group High Good description of C. elegans and how test organisms were obtained. "All strains of C. elegans were obtained from the Caenorhabditis Genetics Center (University of Min- nesota, Minneapolis, MN, USA), and maintained in terms of standard protocols as previ- ously described." Low Authors did not state if test organisms were acclimated to 24-well plates prior to chemi- cal exposure. Medium Sufficient to establish an adequate response. 50-100 worms per exposure concentration, experiments performed in quadruplet. Domain 5: Outcome Assessment Continued on next page ... Page 155 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469475 Table: 2 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Xu, T., Li, P., Wu, S., Lei, L., He, D. (2017). Tris(2-chloroethyl) phosphate (TCEP) and tris(2-chloropropyl) phosphate (TCPP) induce locomotor deficits and dopaminergic degeneration in Caenorhabditis elegans. Toxicology Research 6(1 ):63-72. Overall Duration: > 21 days; Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans\ Wild Type (Bristol, N2); Larvae Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469475 Domain Metric Rating Comments Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment Low High High No details on physical conditions of test organisms Reported how mortalities were assessed (every 2 days) over time post exposure. No mention of any inconsistencies. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High High No mention of any variables that would alter the outcome. No unrelated issues were reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High Percentages were reported as well as a mention of significant difference. Statistics for lifespan assay sufficiently described in cited methods Xu et al 2016 as well as under 'Statistical Analysis' section. Data for control and treatment groups were reported graphically (Figure 2, CI) and in text form. No unexpected outcomes, deviations were reasonable. Additional Comments: The form 3 for biomarker endpoint applies to GFP expression in BZ555 and YFP expression in NL5901 strains. The form 3 for neurological endpoint applies to both local movement and locomotor assays. Well reported study. Overall Quality Determination Medium Page 156 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469475 Table: 3 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Xu, T., Li, P., Wu, S., Lei, L., He, D. (2017). Tris(2-chloroethyl) phosphate (TCEP) and tris(2-chloropropyl) phosphate (TCPP) induce locomotor deficits and dopaminergic degeneration in Caenorhabditis elegans. Toxicology Research 6(l):63-72. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans; BZ555; Larvae Mechanistic-Biomarkers (exposure and effect) Tris(2-chloroethyl) phosphate (TCEP) 5469475 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Metric 2: Metric 3: Test Substance Identity Test Substance Source Test Substance Purity High High High Name and CASRN were reported. Sourced from Sigma Aldrich. All chemicals were Analytical Grade. Domain 2: Test Design Metric 4: Metric 5: Metric 6: Negative Controls Negative Control Response Randomized Allocation High High Low Control was K Medium as were the rest of the treatments. Control responses shown in Figure 6G and 7F and seem reasonable. No mention of how organisms were allocated. Domain 3: Exposure Characterization Metric 7: Metric 8: Metric 9: Metric 10: Experimental System/Test Media Preparation Consistency of Exposure Administration Measurement of Test Substance Concentration Exposure Duration and Frequency High Medium Medium High "TCEP solutions were prepared in K-medium and the control groupis K-medium. Worms were exposed to a series of concentrations of TCEP (50, 250, 500, 750, 1000 mg in 24-well plates." Post exposure set up adequately described. Test organisms exposed for 3 days in 24-well plates. Lighting and other incubation conditions not described. Exposure concentrations were not measured but based on professional judgment of experimental design and nature of test substance, actual concentrations are likely to be similar to nominal concentrations. These minor uncertainties or limitations are unlikely to have a substantial impact on results. 3 day exposure period should be sufficient for GFP and YFP expression in the transgenic strains. Exposure covered a wide range with good spacing, 0-1000 mg/L. Sigma Aldrich states TCEP solubility in water is 50 mg/mL (50 g/L); 1000 mg/L (1 g/ L), the high dose, would be far under the solubility limit. Metric 11: Metric 12: Number of Exposure Groups/ Spacing of Exposure Levels Testing at or Below Solubility Limit High High Domain 4: Test Organism Metric 13: Metric 14: Metric 15: Test Organism Characteristics Acclimatization and Pretreatment Conditions Number of Organisms and Replicates per Group High Medium Medium Good description of C. elegans and how test organisms were obtained. "All strains of C. elegans were obtained from the Caenorhabditis Genetics Center (University of Min- nesota, Minneapolis, MN, USA), and maintained in terms of standard protocols as previ- ously described." Authors did not state whether organisms acclimated to 24-well plates prior to exposure. At least 30 nematodes per group analyzed for GFP expression or YFP expression. Continued on next page... Page 157 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469475 Table: 3 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Xu, T., Li, P., Wu, S., Lei, L., He, D. (2017). Tris(2-chloroethyl) phosphate (TCEP) and tris(2-chloropropyl) phosphate (TCPP) induce locomotor deficits and dopaminergic degeneration in Caenorhabditis elegans. Toxicology Research 6(l):63-72. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans\ BZ555; Larvae Mechanistic-Biomarkers (exposure and effect) Tris(2-chloroethyl) phosphate (TCEP) 5469475 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Metric 17: Adequacy of Test Conditions Outcome Assessment Methodology Metric 18: Consistency of Outcome Assessment Medium Details on total volume per well (assuming 500 uL) as well as temperature and lighting during exposure in 24-well plates lacking. High Analysis of PDat-1 in dopamine neurons via GFP tagging and alpha-synuclein in mus- cles via YFP tagging adequately described. Established transgenic strains utilized for these experiments. High Outcome assessment methodology adequately described by authors as well as cited references. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test High Design and Procedures Metric 20: Outcomes Unrelated to Exposure High No mention of any variables that would alter the outcome. No outcomes unrelated to exposure were reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High "All data were expressed as mean ± Standard Deviation (SD).Mean differences between treated groups and controls weredetermined by one-way analysis of variance (ANOVA), followedby Dunnett"s test. A p-value of less than 0.05 was consideredsignificant." High Data for GFP expression in dopamine neurons (in BZ555 strain) shown in Figure 6 and data for YFP expression in muscles (in NL5901 strain) shown in Figure 7 as well as described in the text. High No unexpected outcomes, deviations were reasonable. Additional Comments: The form 3 for biomarker endpoint applies to GFP expression in BZ555 and YFP expression in NL5901 strains. The form 3 for neurological endpoint applies to both local movement and locomotor assays. Well reported study. Overall Quality Determination High Page 158 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469475 Table: 4 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Xu, T., Li, P., Wu, S., Lei, L., He, D. (2017). Tris(2-chloroethyl) phosphate (TCEP) and tris(2-chloropropyl) phosphate (TCPP) induce locomotor deficits and dopaminergic degeneration in Caenorhabditis elegans. Toxicology Research 6(l):63-72. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans; Wild Type (Bristol, N2); Larvae Neurological Tris(2-chloroethyl) phosphate (TCEP) 5469475 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Name and CASRN were reported. Metric 2: Test Substance Source High Sourced from Sigma Aldrich. Metric 3: Test Substance Purity High All chemicals were Analytical Grade. Domain 2: Test Design Metric 4: Negative Controls High Control was K Medium as were the rest of the treatments. Metric 5: Negative Control Response High Control responses in local movement and locomotor assays shown in Figures 3, 4, and 5 seem reasonable (i.e. similar to responses shown in low TCEP concentration treat- ments). Metric 6: Randomized Allocation Low No mention of how organisms were allocated. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High Test set up described in 24-well plates as well as in cited references for NGM plates Preparation (Tsalik and Hobert 2003; Donnelly et al 2013; Gallagher et al 2013) Metric 8: Consistency of Exposure High Test organisms exposed to TCEP 3 days prior to local movement and locomotor assays Administration as stated in Figure 3 and Figure 4. Metric 9: Measurement of Test Substance Medium Exposure concentrations were not measured but based on professional judgment of Concentration experimental design and nature of test substance, actual concentrations are likely to be similar to nominal concentrations. These minor uncertainties or limitations are unlikely to have a substantial impact on results. Metric 10: Exposure Duration and Frequency High Exposure duration was 3 days which should be sufficient for establishing effects on local movement and locomotion. Metric 11: Number of Exposure Groups/ High Exposure covered a wide range with good spacing, 0-1000 mg/L Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High Sigma Aldrich states TCEP solubility in water is 50 mg/mL (50 g/L); 1000 mg/L (1 g/ L), the high dose, would be far under the solubility limit. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Good description of C. elegans and how test organisms were obtained. "All strains of C. elegans were obtained from the Caenorhabditis Genetics Center (University of Min- nesota, Minneapolis, MN, USA), and maintained in terms of standard protocols as previ- ously described." Metric 14: Acclimatization and Pretreatment Medium Test organisms acclimated briefly before local movement and locomotor assays in NGM Conditions plates. Authors did not state whether test organisms were acclimated to 24-well plate prior to chemical exposure. Continued on next page ... Page 159 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469475 Table: 4 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Xu, T., Li, P., Wu, S., Lei, L., He, D. (2017). Tris(2-chloroethyl) phosphate (TCEP) and tris(2-chloropropyl) phosphate (TCPP) induce locomotor deficits and dopaminergic degeneration in Caenorhabditis elegans. Toxicology Research 6(l):63-72. Overall Duration: 0 - 4 days (0-96h); Exposure Duration: 0 - 4 days (0-96h) Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans\ Wild Type (Bristol, N2); Larvae Neurological Tris(2-chloroethyl) phosphate (TCEP) 5469475 Domain Metric Rating Comments Metric 15: Number of Organisms and Replicates per Group Medium Sufficient to establish an adequate response. 50-100 worms per exposure concentration in 24-well plates, experiments performed in quadruplet. Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment Medium High High Details on total volume per well (assuming 500 uL) as well as temperature and light- ing during exposure in 24-well plates lacking. Conditions in NGM plates adequately described by authors as well as cited references. Authors adequately described how local movement and locomotion was assessed via text and cited references. No mention of any inconsistencies in any of the assessments. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High High No mention of any variables that would alter the outcome. No outcomes unrelated to exposure were reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High "All data were expressed as mean ± Standard Deviation (SD).Mean differences between treated groups and controls weredetermined by one-way analysis of variance (ANOVA), followedby Dunnett"s test. A p-value of less than 0.05 was consideredsignificant." Data for local movement shown in Figure 3 and data for locomotion shown in Figures 4 and 5 as well as described in text. No unexpected outcomes, deviations were reasonable. Additional Comments: The form 3 for biomarker endpoint applies to GFP expression in BZ555 and YFP expression in NL5901 strains. The form 3 for neurological endpoint applies to both local movement and locomotor assays. Well reported study. Overall Quality Determination High Page 160 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469475 Table: 5 of 5 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Xu, T., Li, P., Wu, S., Lei, L., He, D. (2017). Tris(2-chloroethyl) phosphate (TCEP) and tris(2-chloropropyl) phosphate (TCPP) induce locomotor deficits and dopaminergic degeneration in Caenorhabditis elegans. Toxicology Research 6(l):63-72. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans; Wild Type (Bristol, N2); Larvae Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469475 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High Name and CASRN were reported. Metric 2: Test Substance Source High Sourced from Sigma Aldrich. Metric 3: Test Substance Purity High Percent purity not reported but all chemicals were Analytical Grade. Domain 2: Test Design Metric 4: Negative Controls High Control was K Medium as were the rest of the treatments. Metric 5: Negative Control Response Medium Control response of near 100% survival, from graph; however, not clear if control sur- vival was scaled to 100% for the purposes of the graph. Metric 6: Randomized Allocation Low No mention of how organisms were allocated. Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High TCEP prepared in K medium, 24-well plate set up adequately described. Preparation Metric 8: Consistency of Exposure Medium Nothing to suggest exposure was inconsistent across groups. Administration Metric 9: Measurement of Test Substance Medium Exposure concentrations were not measured but based on professional judgment of Concentration experimental design and nature of test substance, actual concentrations are likely to be similar to nominal concentrations. These minor uncertainties or limitations are unlikely to have a substantial impact on results. Metric 10: Exposure Duration and Frequency High Sufficient duration to obtain a good dose response; 1,3,6 days. Metric 11: Number of Exposure Groups/ High Exposure covered a wide range with good spacing, almost two orders of magnitude. Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit High Sigma Aldrich states TCEP solubility in water is 50 mg/mL (50 g/L); 1000 mg/L (1 g/ L), the high dose, would be far under the solubility limit. Domain 4: Test Organism Metric 13: Test Organism Characteristics High Good description of C. elegans and how test organisms were obtained. "All strains of C. elegans were obtained from the Caenorhabditis Genetics Center (University of Min- nesota, Minneapolis, MN, USA), and maintained in terms of standard protocols as previ- ously described." Metric 14: Acclimatization and Pretreatment Medium Unclear if organisms were acclimated to 24-well plates prior to treatment. Conditions Metric 15: Number of Organisms and Medium Adequate for endpoint determinations. Replicates per Group Continued on next page ... Page 161 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469475 Table: 5 of 5 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Xu, T., Li, P., Wu, S., Lei, L., He, D. (2017). Tris(2-chloroethyl) phosphate (TCEP) and tris(2-chloropropyl) phosphate (TCPP) induce locomotor deficits and dopaminergic degeneration in Caenorhabditis elegans. Toxicology Research 6(l):63-72. Overall Duration: 4-10 days; Exposure Duration: 4-10 days Terrestrial; Cell Culture Media; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Caenorhabditis elegans\ Wild Type (Bristol, N2); Larvae Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469475 Domain Metric Rating Comments Domain 5: Outcome Assessment Metric 16: Metric 17: Metric 18: Adequacy of Test Conditions Outcome Assessment Methodology Consistency of Outcome Assessment Medium High High Details on total volume per well (assuming 500 uL) as well as temperature and lighting during exposure in 24-well plates lacking. Reported how mortalities were assessed-unresponsive to gentle needle probe. No mention of any inconsistencies. Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High High No mention of any variables that would alter the outcome. No unrelated issues were reported. Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High High High Confidence intervals were included with LC50 values. "The median lethal concentra- tions (LC50) of TCEP and TCPP were determined bylinear regression analysis with Graphpad Prism." LC50 values for 1, 3, and 6 day lethality tests were reported in text and dose responses were shown in graphically. Well documented. No unexpected outcomes, deviations were reasonable. Additional Comments: The form 3 for biomarker endpoint applies to GFP expression in BZ555 and YFP expression in NL5901 strains. The form 3 for neurological endpoint applies to both local movement and locomotor assays. Well reported study. Overall Quality Determination High Page 162 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469239 Table: 1 of 4 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Yang, Y., Xiao, Y., Chang, Y., Cui, Y., Klobucar, G., Li, M. (2018). Intestinal damage, neurotoxicity and biochemical responses caused by tris (2- chloroethyl) phosphate and tricresyl phosphate on earthworm. Ecotoxicology and Environmental Safety 15878-86. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Terrestrial; Soil; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Eiseniafetida\ Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469239 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High positively identified in abstract and main body Metric 2: Test Substance Source Low Obtained from TCI development Company, not analytically verified Metric 3: Test Substance Purity High percent purity reported as >97% Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High Control group was used, no chemical control was used High Mortality was less than 5% across treatments. Treatments were significantly different than controls. Low no mention of random allocation Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High well documented experimental set up Preparation Metric 8: Consistency of Exposure High no inconsistencies were noted Administration Metric 9: Measurement of Test Substance Low chemical treatment levels were not measured Concentration Metric 10: Exposure Duration and Frequency High exposure duration followed guidelines and was sufficient to assess outcomes Metric 11: Number of Exposure Groups/ High exposure concentration range was sufficient to assess outcomes Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium no mention of how chemical dispersion occurred, this is a terrestrial study not sure if solubility is an issue for this Domain 4: Test Organism Metric 13: Metric 14: Metric 15: Test Organism Characteristics Acclimatization and Pretreatment Conditions Number of Organisms and Replicates per Group High well documented organism characteristics High well documented organism acclimatization and pretreatment procedure Medium organism numbers sufficient to assess outcome Domain 5: Outcome Assessment Metric 16: Metric 17: Adequacy of Test Conditions High Outcome Assessment Methodology Medium well documented and adequate test conditions subsampling periodically for mortality is not the recommended method Continued on next page ... Page 163 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469239 Table: 1 of 4 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Yang, Y., Xiao, Y., Chang, Y., Cui, Y., Klobucar, G., Li, M. (2018). Intestinal damage, neurotoxicity and biochemical responses caused by tris (2- chloroethyl) phosphate and tricresyl phosphate on earthworm. Ecotoxicology and Environmental Safety 15878-86. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Terrestrial; Soil; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Eiseniafetida\ Adult Mortality Tris(2-chloroethyl) phosphate (TCEP) 5469239 Domain Metric Rating Comments Metric 18: Consistency of Outcome Assessment High no inconsistencies in the assessment were noted Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High High no confounding variables in the assessment were noted no unrelated outcomes were noted in the assessment Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High Low High Statistical methods were adequate and reported in section 2.8 no actual values for mortality were reported no unexpected outcomes were reported Additional Comments: None Overall Quality Determination High Page 164 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469239 Table: 2 of 4 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Yang, Y., Xiao, Y., Chang, Y., Cui, Y., Klobucar, G., Li, M. (2018). Intestinal damage, neurotoxicity and biochemical responses caused by tris (2- chloroethyl) phosphate and tricresyl phosphate on earthworm. Ecotoxicology and Environmental Safety 15878-86. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Terrestrial; Soil; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Eiseniafetida\ Adult Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 5469239 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High positively identified in abstract and main body Metric 2: Test Substance Source Low Obtained from TCI development Company, not analytically verified Metric 3: Test Substance Purity High percent purity reported as >97% Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High Control group was used. No chemical control was used High Mortality was less than 5% across treatments. Treatments were significantly different than controls. Low no mention of random allocation Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High well documented experimental set up Preparation Metric 8: Consistency of Exposure High no inconsistencies were noted Administration Metric 9: Measurement of Test Substance Low chemical treatment levels were not measured Concentration Metric 10: Exposure Duration and Frequency High exposure duration followed guidelines and was sufficient to assess outcomes Metric 11: Number of Exposure Groups/ High exposure concentration range was sufficient to assess outcomes Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium no mention of how chemical dispersion occurred, this is a terrestrial study not sure if solubility is an issue for this Domain 4: Test Organism Metric 13: Test Organism Characteristics High well documented organism characteristics Metric 14: Acclimatization and Pretreatment High well documented organism acclimatization and pretreatment procedure Conditions Metric 15: Number of Organisms and Medium organism numbers sufficient to assess outcome Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High well documented and adequate test conditions Metric 17: Outcome Assessment Methodology High assessment methods were straightforward Metric 18: Consistency of Outcome High no inconsistencies in the assessment were noted Assessment. Continued on next page ... Page 165 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469239 Table: 2 of 4 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Yang, Y., Xiao, Y., Chang, Y., Cui, Y., Klobucar, G., Li, M. (2018). Intestinal damage, neurotoxicity and biochemical responses caused by tris (2- chloroethyl) phosphate and tricresyl phosphate on earthworm. Ecotoxicology and Environmental Safety 15878-86. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Terrestrial; Soil; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Eiseniafetida\ Adult Development/Growth Tris(2-chloroethyl) phosphate (TCEP) 5469239 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High no confounding variables in the assessment were noted High no unrelated outcomes were noted in the assessment Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods High Statistical significance compared to control reported in Figure 1. Metric 22: Reporting of Data High growth rate values were reported reasonably well Metric 23: Explanation of Unexpected Outcomes Medium a trend was reported but no explanation for a mid treatment level relative decrease Additional Comments: None Overall Quality Determination High Page 166 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469239 Table: 3 of 4 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Yang, Y., Xiao, Y., Chang, Y., Cui, Y., Klobucar, G., Li, M. (2018). Intestinal damage, neurotoxicity and biochemical responses caused by tris (2- chloroethyl) phosphate and tricresyl phosphate on earthworm. Ecotoxicology and Environmental Safety 15878-86. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Terrestrial; Soil; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Eiseniafetida\ Adult Neurological Tris(2-chloroethyl) phosphate (TCEP) 5469239 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High positively identified in abstract and main body Metric 2: Test Substance Source Low Obtained from TCI development Company, not analytically verified Metric 3: Test Substance Purity High percent purity reported as >97% Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High Control group was used. No chemical control was used High Mortality was less than 5% across treatments. Treatments were significantly different than controls. Low no mention of random allocation Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High well documented experimental set up Preparation Metric 8: Consistency of Exposure High no inconsistencies were noted Administration Metric 9: Measurement of Test Substance Low chemical treatment levels were not measured Concentration Metric 10: Exposure Duration and Frequency High exposure duration followed guidelines and was sufficient to assess outcomes Metric 11: Number of Exposure Groups/ High exposure concentration range was sufficient to assess outcomes Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium no mention of how chemical dispersion occurred, this is a terrestrial study not sure if solubility is an issue for this Domain 4: Test Organism Metric 13: Test Organism Characteristics High well documented organism characteristics Metric 14: Acclimatization and Pretreatment High well documented organism acclimatization and pretreatment procedure Conditions Metric 15: Number of Organisms and Medium organism numbers sufficient to assess outcome Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High well documented and adequate test conditions Metric 17: Outcome Assessment Methodology High assessment methods were straightforward Metric 18: Consistency of Outcome High no inconsistencies in the assessment were noted Assessment. Continued on next page ... Page 167 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469239 Table: 3 of 4 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Yang, Y., Xiao, Y., Chang, Y., Cui, Y., Klobucar, G., Li, M. (2018). Intestinal damage, neurotoxicity and biochemical responses caused by tris (2- chloroethyl) phosphate and tricresyl phosphate on earthworm. Ecotoxicology and Environmental Safety 15878-86. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Terrestrial; Soil; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Eiseniafetida\ Adult Neurological Tris(2-chloroethyl) phosphate (TCEP) 5469239 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High no confounding variables in the assessment were noted High no unrelated outcomes were noted in the assessment Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High author noted what statistics were applied, gene transcription, GSH and AChE did not follow a clear dose response High Transcriptions, GSH levels and AChE levels rate values were reported reasonably well High trends were reported ando explanations were provided for results not following trends Additional Comments: None Overall Quality Determination High Page 168 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469239 Table: 4 of 4 Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Yang, Y., Xiao, Y., Chang, Y., Cui, Y., Klobucar, G., Li, M. (2018). Intestinal damage, neurotoxicity and biochemical responses caused by tris (2- chloroethyl) phosphate and tricresyl phosphate on earthworm. Ecotoxicology and Environmental Safety 15878-86. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Terrestrial; Soil; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Eiseniafetida\ Adult Gastrointestinal Tris(2-chloroethyl) phosphate (TCEP) 5469239 Domain Metric Rating Comments Domain 1: Test Substance Metric 1: Test Substance Identity High positively identified in abstract and main body Metric 2: Test Substance Source Low Obtained from TCI development Company, not analytically verified Metric 3: Test Substance Purity High percent purity reported as >97% Domain 2: Test Design Metric 4: Negative Controls Metric 5: Negative Control Response Metric 6: Randomized Allocation High Control group was used. No chemical control was used High Mortality was less than 5% across treatments. Treatments were significantly different than controls. Low no mention of random allocation Domain 3: Exposure Characterization Metric 7: Experimental System/Test Media High well documented experimental set up Preparation Metric 8: Consistency of Exposure High no inconsistencies were noted Administration Metric 9: Measurement of Test Substance Low chemical treatment levels were not measured Concentration Metric 10: Exposure Duration and Frequency High exposure duration followed guidelines and was sufficient to assess outcomes Metric 11: Number of Exposure Groups/ High exposure concentration range was sufficient to assess outcomes Spacing of Exposure Levels Metric 12: Testing at or Below Solubility Limit Medium no mention of how chemical dispersion occurred, this is a terrestrial study not sure if solubility is an issue for this Domain 4: Test Organism Metric 13: Test Organism Characteristics High well documented organism characteristics Metric 14: Acclimatization and Pretreatment High well documented organism acclimatization and pretreatment procedure Conditions Metric 15: Number of Organisms and Medium organism numbers sufficient to assess outcome Replicates per Group Domain 5: Outcome Assessment Metric 16: Adequacy of Test Conditions High well documented and adequate test conditions Metric 17: Outcome Assessment Methodology High assessment methods were straightforward Metric 18: Consistency of Outcome High no inconsistencies in the assessment were noted Assessment. Continued on next page ... Page 169 of 170 ------- Tris(2-chloroethyl) phosphate (TCEP) PUBLIC RELEASE DRAFT - DO NOT CITE OR QUOTE December 2023 Environmental Hazard Evaluation HERO ID: 5469239 Table: 4 of 4 ... continued from previous page Study Citation: Duration: Exposure Route, Media, Path: Taxa, Species, Age: Health Outcome: Chemical: HERO ID: Yang, Y., Xiao, Y., Chang, Y., Cui, Y., Klobucar, G., Li, M. (2018). Intestinal damage, neurotoxicity and biochemical responses caused by tris (2- chloroethyl) phosphate and tricresyl phosphate on earthworm. Ecotoxicology and Environmental Safety 15878-86. Overall Duration: 11-21 days; Exposure Duration: 11-21 days Terrestrial; Soil; Not determined by study authors (i.e., chemical of interest in exposure water, but unable to determine exact uptake route) Invertebrate; Worms (e.g., Annelids, Nematodes); Eiseniafetida\ Adult Gastrointestinal Tris(2-chloroethyl) phosphate (TCEP) 5469239 Domain Metric Rating Comments Domain 6: Confounding / Variable Control Metric 19: Confounding Variables in Test Design and Procedures Metric 20: Outcomes Unrelated to Exposure High no confounding variables in the assessment were noted High no unrelated outcomes were noted in the assessment Domain 7: Data Presentation and Analysis Metric 21: Statistical Methods Metric 22: Reporting of Data Metric 23: Explanation of Unexpected Outcomes High author noted what statistics were applied, intestinal damage and DNA breaks followed a reasonable dose response biochemical changes did not follow a clear dose response High intestinal damage, DNA breaks and biochemical changes were reported reasonably well High trends were reported and explanations were provided for results not following trends Additional Comments: None Overall Quality Determination High Page 170 of 170 ------- |