March
29,
2006
1
RISK
SCREEN
ON
SUBSTITUTES
FOR
HALON
1301
TOTAL
FLOODING
FIRE
EXTINGUISHERS
OCCUPIED
SPACES
SUBSTITUTE:
Uni­
Light
This
risk
screen
does
not
contain
Clean
Air
Act
(
CAA)
Confidential
Business
Information
(
CBI)
and,
therefore,
can
be
disclosed
to
the
public.

1.
INTRODUCTION
Ozone­
depleting
substances
(
ODS)
are
being
phased
out
of
production
in
response
to
a
series
of
diplomatic
and
legislative
efforts
that
have
taken
place
over
the
past
few
years,
including
the
Montreal
Protocol
and
the
Clean
Air
Act
Amendments
of
1990
(
CAAA).
The
U.
S.
Environmental
Protection
Agency
(
EPA),
as
authorized
by
Section
612
of
the
CAAA,
is
developing
a
program
to
evaluate
human
health
and
environmental
risks
posed
by
alternatives
to
ODS.
The
main
purpose
of
EPA's
program,
called
the
Significant
New
Alternatives
Policy
(
SNAP)
program,
is
to
identify
acceptable
and
unacceptable
substitutes
for
ODS
in
specific
end
uses.

EPA's
decision
on
the
acceptability
of
a
substitute
is
based
largely
on
the
findings
of
a
screening
assessment
of
potential
human
health
and
environmental
risks
posed
by
the
substitute
in
specific
applications.
EPA
has
already
screened
a
large
number
of
substitutes
in
many
end
uses
within
all
of
the
major
ODS­
using
sectors,
including
refrigeration
and
air
conditioning,
solvent
cleaning,
foam
blowing,
aerosols,
fire
suppression,
adhesives,
coatings
and
inks,
and
sterilization.
The
results
of
these
risk
screens
are
presented
in
a
series
of
Background
Documents
that
are
available
in
EPA's
docket.

The
purpose
of
this
report
is
to
supplement
EPA's
Background
Document
on
the
fire
suppression
and
explosion
protection
sector
(
hereinafter
referred
to
as
the
Background
Document).
1
This
risk
screen
discusses
potential
human
health
and
environmental
risks
posed
by
Uni­
Light,
a
water
mist
fire
extinguishing
system,
which
could
replace
Halon
1301
for
use
as
a
total
flooding
agent
in
occupied
areas.
According
to
the
submitter,
the
typical
application
of
Uni­
Light
will
be
in
machinery
spaces
onboard
ships
and
off­
shore
installations.
The
use
of
Uni­
Light
in
streaming
applications
is
not
addressed
in
this
risk
screen.

On
July
28,
1995,
EPA
listed
"
Water
Mist
Systems
using
Potable
Water
or
Natural
Sea
Water 
as
acceptable
as
a
Halon
1301
substitute."
(
60
FR
38731)
That
determination
was
based
on
the
recommendations
of
a
Health
Panel
convened
to
consider
the
potential
physiological
effects
of
inhaling
very
small
droplets
in
fire
and
non­
fire
scenarios.
The
Panel
concluded
that
"
water
mist
systems
using
pure
water
do
not
represent
a
toxicological
or
physiological
hazard
and
are
safe
for
use
in
occupied
areas."
The
Panel
recommended
"
that
additives
be
evaluated
on
1U.
S.
EPA,
1994.
Risk
Screen
on
the
Use
of
Substitutes
for
Class
I
Ozone­
Depleting
Substances:
Fire
Suppression
and
Explosion
Protection
(
Halon
Substitutes).
Stratospheric
Protection
Division.
March
1994.
March
29,
2006
2
a
case­
by­
case
basis
depending
on
the
properties
of
the
additive
and
the
concentration
at
which
it
is
used."
EPA
adopted
the
recommendations
of
the
Panel
by
listing
water
mist
systems
composed
of
potable
water
and
natural
sea
water
as
acceptable
without
restriction
and
requiring
that
"
water
mist
systems
containing
additives
different
than
those
of
potable
water,
and
water
mist
systems
comprised
of
mixtures
in
solution,
must
be
submitted
to
EPA
for
SNAP
review
on
a
case­
by­
case
basis."

The
fire
extinguishing
product
submitted
under
the
name
Uni­
Light
contains
a
[]
percent
(
by
mass)
foam
enhancement
mixed
with
water.
The
foam
consists
of
[].
The
composition
of
the
foam
enhancement
is
listed
below
in
Table
1.

Table
1:
Composition
of
the
[]
Foam
Component
of
Uni­
Light
Constituent
Chemical
Formula
CAS
#
Percent
of
Total
by
Mass
Section
2
of
this
report
summarizes
the
results
of
the
risk
screen
for
Uni­
Light,
Section
3
presents
atmospheric
modeling
and
potential
environmental
risks;
Section
4
discusses
occupational
exposure
during
manufacture,
installation
and
maintenance;
Section
5
discusses
exposure
at
end
use;
Section
6
assesses
risks
associated
with
general
population
exposure;
and
Section
7
assesses
the
emissions
of
volatile
organic
compounds.
March
29,
2006
3
2.
SUMMARY
OF
RESULTS
Uni­
Light
is
recommended
for
SNAP
approval
as
a
total
flooding
agent
for
extinguishing
fires
in
occupied
spaces.
Approval
is
specific
to
the
water
mist
system
with
the
foam
formulation
submitted
with
the
application
and
evaluated
in
this
risk
screen.
Any
change
to
the
either
the
individual
constituents
or
composition
of
the
foam
blend
may
be
considered
a
new
formulation
requiring
SNAP
review.
Appropriate
personal
protective
equipment
(
PPE)
should
be
worn
during
end­
use
or,
in
the
event
of
an
accidental
release,
should
be
made
available
in
a
normally
occupied
space.
PPE
should
include
safety
goggles,
protective
gloves,
and
a
self
contained
breathing
apparatus
(
SCBA).
Additionally,
the
risk
screen
indicates
that
the
use
of
the
proposed
substitute
will
be
less
harmful
to
the
atmosphere
than
the
continued
use
of
Halon
1301.
Risk
to
the
general
population
is
expected
to
be
negligible,
and
occupational
exposure
should
not
pose
a
problem
if
personal
protective
equipment
is
used.
For
applications
of
this
and
all
other
fire
suppression
equipment,
ICF
recommends
that
the
applicable
National
Fire
Protection
Agency
(
NFPA)
standards
be
followed,
including
NFPA
750
Standard
on
Water
Mist
Fire
Protection
Systems
and
NFPA
16
Standard
for
Installation
of
Foam
Water
Sprinkler
and
Foam
Water
Spray
Systems.

3.
ATMOSPHERIC
MODELING
This
section
presents
an
assessment
of
the
potential
risks
to
atmospheric
integrity
posed
by
the
use
of
Uni­
Light
as
a
total
flooding
agent
in
occupied
areas.
According
to
the
applicant,
the
active
ingredients
released
are
liquids
at
standard
temperature
and
pressure
and
have
no
ozonedepleting
potential
(
ODP)
and
a
negligible
atmospheric
lifetime
(
ALT).
Therefore,
the
use
of
Uni­
Light
will
be
less
damaging
to
the
atmosphere
than
continued
use
of
Halon
1301.

4.
OCCUPATIONAL
EXPOSURE
AT
MANUFACTURE
The
Uni­
Light
foam
enhancement
is
manufactured
using
an
automated
production
process.
This
prevents
manufacturing
personnel
from
direct
exposure
to
any
of
the
Uni­
Light
chemical
constituents.
Although
contact
is
typically
avoided,
workers
may
be
exposed
to
chemicals
during
a
manufacturing
accident.
In
case
of
an
accidental
release,
the
applicant
claims
that
both
audible
and
visual
alarms
will
be
activated
to
warn
workers.
Workers
that
may
be
exposed
to
any
chemicals
during
an
accidental
release
or
spill
are
recommended
to
take
precautionary
measures
to
minimize
risk.
Protective
gloves
and
goggles
should
be
worn
to
protect
the
skin
and
eyes
and
a
SCBA
should
be
worn
to
avoid
breathing
vapor.
After
an
accidental
spill,
the
area
should
be
well
ventilated
and
any
material
should
be
collected
with
an
inert
absorbent
and
disposed
of
as
hazardous
waste.

5.
EXPOSURE
AT
END
USE
In
order
to
evaluate
exposure
at
end
use,
ICF
has
evaluated
the
compounds
contained
in
the
Uni­
Light
foam
additive.
The
information
for
these
compounds
is
presented
below:
March
29,
2006
4
5a.
[]
Exposure
at
End
Use
[]
has
a
low
toxicity
during
acute
oral
exposure
or
single
inhalation
(
Bingham
et
al.
2001).
It
has
also
been
demonstrated
that
exposure
does
not
result
in
any
adverse
developmental
effects
(
Bingham
et
al
2001,
HSDS
2004),
which
is
a
concern
with
other
structurally
similar
chemicals.
Even
though
the
health
concerns
associated
with
exposure
to
[]
appear
to
be
low,
exposure
to
humans
was
modeled
because
[]
is
considered
the
most
toxic
constituent
of
the
Uni­
Light
foam
additive
and
composes
[]%
of
Uni­
Light,
the
highest
concentration
of
all
of
the
constituents.

A
reasonable
release
scenario
was
constructed
to
model
a
release
of
Uni­
Light
into
an
occupied
space
where
the
system
would
typically
be
installed.
The
typical
application
of
Uni­
Light
will
be
in
machinery
spaces
onboard
ships
and
off­
shore
installations
(
Submitter).
The
following
information
was
provided
by
the
Submitter
and
was
used
to
model
potential
exposure
of
an
individual
to
Uni
Light
at
the
time
of
release:

 
Water
mixed
with
Uni­
Light
is
discharged
for
300
seconds
(
s)
from
the
Uni­
Light
System;
 
The
rate
of
discharge
is
[]
g/
m3/
s
or
[]
mg/
m3/
s;
 
The
material
released
is
[]%
(
by
mass);
 
The
average
size
room
(
ship
machine
room)
where
Uni­
Light
would
be
released
is
14
m3
 
Uni­
Light
particles
will
completely
settle
in
60s;
and
 
The
Uni­
Light
System
discharges
pure
water
after
release
of
foam
for
a
minimum
of
10
minutes.
This
water
discharge
will
help
"
scrub"
the
air
(
submitter)
and
flush
the
foam
into
the
bilge
system
(
a
waste
pump
system
located
on
board
a
ship
or
in
an
off­
shore
location).
The
table
below
summarizes
the
concentrations
of
[]
by
time
interval
during
a
release
based
on
information
provided
by
the
applicant.

Table
2:
Concentration
of
[]
in
typical
During
Release
at
End­
Use
Time
Interval
(
s)
Concentration
0­
60
Concentration
increases
in
the
room.
It
is
assumed
that
this
is
a
constant
rate
of
[]
mg/
m3/
s
60­
300
Concentration
in
the
room
reaches
a
steady
state
concentration
of
[]
mg/
m3
300­
360
The
system
begins
to
discharge
pure
water.
The
concentration
is
assumed
to
decreases
at
a
constant
rate
of
[]
mg/
m3/
s
as
particles
settle.
At
360s,
the
concentration
returns
to
0
mg/
m3.

Exposure
Modeling
Exposure
to
[]
was
modeled
to
determine
the
safety
of
the
Uni­
Light
system
during
a
release.
In
order
to
model
human
exposure
the
following
assumptions
were
made:

 
All
aqueous
particles
of
[]
inhaled
are
available
for
dissolution
and
uptake
in
the
pulmonary
region
of
the
lungs;
and
March
29,
2006
5
 
The
average
ventilation
rate
of
a
70­
kg,
18­
30
year­
old
male
in
moderate
activity
is
1.74
m3/
hr
(
US
EPA
1997).

It
was
assumed
that
all
aqueous
particles
containing
[]
inhaled
will
enter
the
bloodstream.
The
amount
of
[]
that
enters
the
body
was
estimated
using
the
following
information
and
calculation
below:

C
=
[]
concentration
=
[]
mg/
m3
T1
=
0­
60s
time
interval
=
0.017hr
T2
=
60­
300s
time
interval
=
0.067hr
T3
=
300­
360s
time
interval
=
0.017
hr
I
=
Inhalation
rate
=
1.74m3/
hr
0.5
=
Target
concentration
scaling
factor
Maximum
Exposure
=
(
0.5
*
C
*
T1
*
I)
+
(
C
*
T2*
I)
+
(
0.5
*
C
*
T3*
I)
=
(
0.5
*
[]
mg/
m3
*
0.017hr*
1.74m3/
hr)
+
([]
mg/
m3
*
0.067h
*
1.74m3/
hr)
+
(
0.5*
[]
mg/
m3
*
0.017h
*
1.74m3/
hr)

=
[]
mg
Using
this
equation,
it
is
estimated
that
the
maximum
amount
of
[]
that
a
70
kg,
18­
30
­
year­
old
male
could
be
exposed
to
during
a
standard
release
of
Uni­
Light
would
be
[]
mg.

US
standard
setting
organizations
(
OSHA,
NIOSH,
and
ACGIH)
have
not
established
a
standard
for
[].
Therefore
a
German
occupational
TWA
of
100
mg/
m3
set
by
the
Federal
Republic
of
Germany
Maximum
Concentration
Values
in
the
Workplace
(
MAK)
has
been
chosen
(
ACGIH
2000).
Using
this
value,
ICF
estimated
the
maximum
amount
assumed
to
be
safe
when
inhaled
by
a
worker
on
a
daily
basis
(
8
hour
day,
5
days/
week).
The
value
was
estimated
using
the
following
information
and
calculation:

CTWA=
maximum
occupational
exposure
concentration=
100
mg/
m3
T8hr=
8
hour
exposure=
8
hr
I=
inhalation
rate=
1.74mg/
m3
Maximum
ExposureTWA
=
(
CTWA*
T8hr*
I)
=
(
100
mg/
m3*
8hr*
1.74
m3/
hr)

=
1392mg/
day
Using
this
equation,
the
maximum
amount
of
[]
that
an
individual
should
be
exposed
to
is
1392
mg/
day.
The
maximum
amount
of
[]
that
a
70­
kg,
18­
30­
year­
old
male
would
be
exposed
to
during
a
300s
discharge
of
Uni­
Light
is
well
below
this
estimated
amount.
The
above
value
is
used
to
estimate
a
safe
daily
dose
and
is
a
value
deemed
to
be
protective
of
chronic
occupational
exposure
to
this
compound.
Because
the
exposure
scenario
of
concern
for
Uni­
Light
in
this
risk
screen
is
an
accidental
release
which
is
an
acute
or
one­
time
exposure,
there
is
a
sufficient
margin
of
safety
above
the
factor
of
[]
calculated
using
the
chronic
exposure
TWA
value.
March
29,
2006
6
5b.
[]
Exposure
at
End
Use
Exposure
to
the
[]
in
Uni­
Light
is
not
expected
to
pose
a
significant
risk
to
workers
or
bystanders.
As
with
the
above
constituent,
US
standard
setting
organizations
have
not
set
standards
for
these
agents
because
they
have
been
assumed
`
safe.'
The
German
MAK
has
set
a
standard
for
[]
which
is
a
TWA
of
1000
mg/
m3
(
ACGIH
2000).
This
value
is
10
fold
greater
than
the
MAK
standard
for
[].
[]
is
only
[]%
of
the
total
mass
of
Uni­
Light
and
therefore
the
potential
exposure
is
estimated
to
be
considerably
(
two
orders
of
magnitude)
less
than
the
TWA
of
1000
mg/
m3
and
therefore
exposure
should
not
be
a
health
concern.

5c.
[],
[],
Exposure
at
End
Use
ICF
believes
that
exposure
to
[]
and
[],
are
not
expected
to
pose
a
significant
risk
to
workers
or
bystanders.
US
standard
setting
organizations
have
not
set
standards
for
these
agents
because
they
have
been
assumed
`
safe.'
Both
[]
and
[]
are
surfactants
that
may
cause
skin
and
eye
irritation
in
high
concentrations,
but
are
not
expected
to
cause
any
systemic
effects
at
the
concentration
individuals
may
be
exposed
to
during
a
release.
These
surfactants
are
most
commonly
used
in
shampoos
and
soaps
and
are
classified
as
"
generally
recognized
as
safe"
by
the
Food
and
Drug
Administration.
When
exposure
to
a
surfactant
occurs
it
is
recommended
that
individuals
remove
contaminated
clothing,
rinse
their
eyes
and
skin
after
an
exposure.

6.
GENERAL
POPULATION
EXPOSURE
Uni­
Light
is
not
expected
to
cause
a
significant
threat
to
human
health
in
the
general
population
when
used
as
a
flooding
agent
in
occupied
areas.
The
only
possible
general
population
exposure
to
Uni­
Light
will
be
during
discharge
of
fire
extinguishers
in
machine
rooms
onboard
ships
and
in
off­
shore
installations.
Uni­
Light
could
be
used
on
cruise
ships
where
the
general
population
will
be
effected.
However,
Uni­
Light
will
primarily
be
used
in
offshore
facilities
and
commercial
ships
only
populated
with
workers
where
the
general
public
will
not
be
exposed.

Fire
fighters
and
those
exposed
to
Uni­
Light
during
release
should
wear
full
protective
clothing,
including
self­
contained
breathing
apparatus
(
SCBA).
Individuals
should
follow
the
precautionary
measures
describes
in
Section
5c
and
equipment
should
be
thoroughly
decontaminated
after
use.
When
the
recommended
safety
precautions
are
followed,
no
significant
adverse
health
effects
should
result.

6a.
AMBIENT
AIR
Uni­
Light
is
not
expected
to
pose
a
significant
threat
to
human
health
in
the
general
population
in
the
ambient
air
concentrations.
All
chemical
constituents
of
the
Uni­
Light
foam
are
liquids
at
standard
temperature
and
pressure
and
therefore
will
not
volatilize
into
air
contaminants.
As
was
mentioned
earlier,
the
Uni­
Light
System
discharges
pure
water
after
release
of
foam
for
a
minimum
of
10
minutes.
This
water
discharge
will
help
"
scrub"
the
air
(
submitter)
and
flush
the
foam
into
the
bilge
system
(
a
waste
pump
system
located
on
board
a
ship
or
in
an
off­
shore
March
29,
2006
7
location).
Therefore,
Uni­
Light
is
not
expected
to
be
a
safety
concern
for
ambient
air
contamination.

6b.
SURFACE
WATER
Systems
containing
Uni­
light
will
be
used
in
machinery
spaces
onboard
ships
and
off­
shore
installations.
After
a
discharge,
the
foam
is
collected
by
an
automatic
bilge
system
and
only
discharged
from
the
vessel
off­
shore.
The
Material
Safety
Data
Sheets
(
MSDS)
submitted
by
the
applicant
indicates
that
[]
and
[]
should
not
be
allowed
to
enter
drains
or
be
released
into
the
environment.
US
federal
maritime
regulations
designate
three
types
of
discharge
"
zones"
in
U.
S.
waters.
Over
three
miles
offshore,
one
may
discharge
waste
directly
overboard.
Inside
the
threemile
limit,
it
is
illegal
to
dump
bilge
water
or
other
sewage.
This
waste
must
be
contained
onboard
and
treated
or
discharged
at
a
pump­
out
station.
Furthermore,
the
applicant
claims
that
discharge
of
these
chemicals
at
the
concentrations
released
during
end­
use
should
not
be
a
concern.
As
long
the
Uni­
light
is
used
on
ships
and
off­
shore
installations,
it
is
not
expected
that
drinking
water
supplies
will
be
contaminated
because
the
Uni­
Light
waste
product
will
not
be
released
in
coastal
areas.
In
addition,
[]
is
listed
as
having
a
low
ecologic
toxicity
and
environmental
persistence
as
an
aqueous
solvent
by
the
EPA
(
U.
S.
EPA
2004).

6c.
SOLID
WASTE
All
constituents
of
the
Uni­
Light
system
are
liquids,
so
the
only
solid
waste
generated
is
from
absorbent
materials
used
to
clean
spaces
after
release.
[]
is
regulated
as
a
controlled
substance
by
the
Toxic
Substance
Control
Act
(
TSCA).
Therefore,
all
materials
used
to
clean
spaces
after
an
accidental
should
be
handled
and
disposed
of
as
hazardous
waste
in
accordance
with
federal,
state,
or
local
requirements.

7.
VOLATILE
ORGANIC
COMPOUND
ANALYSIS
In
Chapter
7
of
the
Background
Document,
EPA
estimated
the
impact
of
potential
increases
in
volatile
organic
compound
(
VOC)
emissions
from
the
use
of
substitutes
for
ozone­
depleting
substances
(
U.
S.
EPA
1994).
It
was
shown
that
VOC
emissions
from
substitutes
for
Halon
1301
in
fire
extinguishing
systems
are
likely
to
be
insignificant
compared
to
VOC
emissions
from
all
other
sources
(
i.
e.,
both
anthropogenic
and
biogenic).
The
constituents
of
Uni­
Light
all
have
very
low
volatility
and
therefore
are
also
not
expected
to
contribute
significantly
to
VOC
emissions.

REFERENCES
ACGIH.
2000.
Guide
to
Occupational
Exposure
Values:
2000.
ACGIH,
Inc.,
Cincinnati.
p.
42.

Bingham,
E;
Cohrssen,
B.;
Powell,
CH.
(
eds.).
2001.
Patty's
Toxicology,
5th
Edition.
John
Wiley
and
Sons,
Inc.,
New
York.

HSDB.
2004.
Hazardous
Substances
Data
Bank,
TOXNET.
National
Library
of
Medicine.
Specialized
Information
Services.
<
http:///
toxnet.
nlm.
nih.
gov
TOXNET>
March
29,
2006
8
NFPA.
2000.
Standard
on
Clean
Fire
Extinguishing
Systems.

Uni­
Light
SNAP
Submission.
2005.
Significant
New
Alternatives
Policy
Program
Submission
to
the
United
States
Environmental
Protection
Agency,
February
17,
2005.

U.
S.
EPA.
2004.
Aqueous
and
Semi­
Aqueous
Solvent
Chemicals:
Environmentally
Preferable
Choices.
<
http://
www.
epa.
gov/
oppt/
solvents/
finlchr4.
htm>.
U.
S.
EPA.
1997.
Exposure
Factors
Handbook.
EPA/
600/
P­
95/
002Fa.
Office
of
Research
and
Development,
Washington,
DC.
August
1997.

U.
S.
EPA.
1994b
Risk
Screen
on
the
Use
of
Substitutes
for
Class
I
Ozone­
Depleting
Substances:
Fire
Suppression
and
Explosion
Protection
(
Halon
Substitutes).
Stratospheric
Protection
Division.
March
1994.
March
29,
2006
9
Appendix
A:
Toxicity
of
Uni­
Light
through
Dermal
Exposure
Dermal
exposure
and
skin
absorption
to
Uni­
light
should
not
be
a
safety
concern
for
workers
handling
the
substance
or
individuals
exposed
at
end­
use.
Two
of
the
constituents,
[]
and
[]
are
surfactants
that
are
commonly
used
in
shampoos
and
soaps.
They
are
also
classified
by
the
Food
and
Drug
administration
as
"
generally
recognized
as
safe
(
GRAS)."

Dermal
exposure
to
[]
is
discussed
in
Patty's
Toxicology
5th
Edition,
which
states,
"[]
present
practically
no
health
hazards
in
industrial
handling
and
use.
They
are
not
significantly
irritating
to
the
eyes,
skin,
or
mucous
membranes "
It
discusses
a
study
on
[]
that
found
that
the
dermal
LD50
of
[]
could
not
be
established
because
the
lethal
dose
would
have
been
extremely
high
(
Bingham
et
al.
2001)
and
an
unpublished
study
by
Dow
Chemical
Company,
which
found
that
a
single
dermal
dose
of
20g/
kg
had
no
adverse
effects.
Other
studies
mentioned
examined
the
subchronic
effects
of
dermal
exposure.
Most
of
these
found
that
subchronic
dermal
exposure
had
no
adverse
effects
(
Bingham
et
al.
2001).
One
study
did
raise
health
concerns,
but
was
difficult
to
evaluate
because
it
also
studied
diet
deficiency
and
lacked
a
control
group
(
Bingham
et
al.
2001).

Dermal
exposure
to
[]
is
also
discussed
in
Patty's
Toxicology
5th
Edition,
which
states
that,
"[]
has
low
acute
toxicity
by
the
oral,
dermal,
and
inhalation
routes."
[]
is
commonly
used
in
cleaning
products
and
coatings,
so
dermal
exposure
is
typically
the
most
common
route
of
exposure
in
the
US.
The
EPA
issued
a
TSCA
ruling
in
[],
which
required
dermal
subchronic
and
dermal
neurotoxicity
studies
(
U.
S.
EPA
[]).
Patty's
Toxicology
reports
that,
"
The
results
of
these
studies
confirmed
that
[]
presents
little
risk
of
systemic
toxicity "
One
dermal
acute
toxicity
study
on
rabbits
and
guinea
pigs
found
that
exposure
to
pure
[]
caused
slight
skin
irritation
(
Bingham
et
al.
2001).
A
rabbit
study
found
that
exposure
to
0.1mL
of
pure
[]
can
cause
eye
irritation
and
temporary
tissue
damage
(
Bingham
et
al.
2001).
The
study
also
found
that
irritation
decreased
as
[]
was
diluted
and
no
irritation
was
detected
when
rabbits
were
exposed
to
a
5%
solution.

References
Bingham,
E;
Cohrssen,
B.;
Powell,
CH.
(
eds.).
2001.
Patty's
Toxicology,
5th
Edition.
John
Wiley
and
Sons,
Inc.,
New
York.

U.
S.
EPA.
[],
Final
test
rule
on
[]
and
[].
Fed.
Reg.
[].
