UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
DATE:
May
6,
2003
SUBJECT:
Sulfonated
Oleic
Acid­
Report
of
the
Antimicrobials
Division
Toxicology
Endpoint
Selection
Committee.

FROM:
Timothy
F.
McMahon,
Ph.
D.
Chair,
ADTC
Antimicrobials
Division
(
7510C)

Michelle
Centra,
Pharmacologist
Executive
Secretary,
ADTC
Antimicrobials
Division
(
7510C)

THROUGH:
John
Redden,
Roger
Gardner,
Stephen
Dapson,
Ph.
D.,
Karen
Hamernik,
Ph.
D.,
Melba
Morrow,
D.
V.
M.,
Sanyvette
Williams­
Foy,
D.
V.
M,
Jonathan
Chen,
Ph.
D.,
Timothy
Leighton,
Najm
Shamim,
Ph.
D.,
Deborah
Smegal
PC
Codes:
079604
On
February
25,
2003,
the
Antimicrobials
Division
Toxicology
Endpoint
Selection
Committee
(
ADTC)
reviewed
the
available
Toxicology
data
for
sulfonated
oleic
acid
and
discussed
endpoint
selection
for
use
as
appropriate
in
occupational/
residential
exposure
risk
assessments.
The
potential
for
increased
susceptibility
of
infants
and
children
from
exposure
to
sulfonated
oleic
acid
was
also
evaluated
by
the
committee
in
order
to
meet
the
statutory
requirements
of
the
Food
Quality
Protection
Act
(
FQPA)
of
1996.
The
conclusions
drawn
at
this
meeting
are
presented
in
this
report.
2
Committee
Members
in
Attendance
Members
present
were:
Timothy
F.
McMahon,
Ph.
D.
Stephen
Dapson,
Ph.
D.;
Jonathan
Chen,
Ph.
D.;
Timothy
Leighton;
John
Redden;
Karen
Hamernik,
Ph.
D.,
Michelle
Centra,

Member(
s)
in
absentia:
Roger
Gardner,
Ph.
D.;
Sanyvette
Williams,
D.
V.
M.;
Melba
Morrow,
D.
V.
M.,
Najm
Shamim,
Ph.
D.

Data
Evaluation
/
Report
Presentation
Timothy
F.
McMahon,
Ph.
D.

Toxicologist
3
COMMITTEE
MEMBERS
IN
ATTENDANCE
(
Signature
indicates
concurrence
unless
otherwise
stated)

Stephen
Dapson
Jonathan
Chen
Roger
Gardner
Karen
Hamernik
Tim
Leighton
________________________

Tim
McMahon
(
chair)

Melba
Morrow
John
Redden
Sanyvette
Williams­
Foy
Deborah
Smegal
_______________________

OTHER
ATTENDEES:
4
Introduction
Sulfonated
oleic
acid
(
CAS
Reg.
nos.
68443­
05­
0
and
67998­
94­
1)
is
currently
registered
for
use
on
milking
equipment,
food
processing,
handling,
and
storage
areas,
breweries,
milk
processing
plants,
meat
processing
plants,
and
beverage
processing
plants.
The
active
ingredient
consists
of
two
chemical
constituents,
one
as
the
primary
ingredient
(
9­
octadecenoic
acid,
sulfonated
sodium
salt,
Cas
Reg
no.
68443­
05­
0)
and
the
other
as
a
by­
product
(
octadecanoic
acid,
sulfo,
sodium
salt,
67998­
94­
1).
Only
two
end­
use
products
are
currently
registered:
AFCO
Low
Foam
Tops
and
PER­
VAD.
Both
of
these
end­
use
products
contain
sulfonated
oleic
acid
at
2.6­
5%,
with
higher
percentages
of
phosphoric
acid
in
the
formulation.
There
are
two
registrants
for
sulfonated
oleic
acid,
Alex
C.
Fergusson,
Inc.
and
Diversey
Corp.

Physical/
Chemical
Properties
Table
3.
Physical
and
Chemical
Properties
of
Oleic
Acid
Sulfonates
Physical
and
Chemical
Property
9­
Octadecenoic
acid
(
9Z­),
sulfonated,
sodium
salt
68443­
05­
0
Oleic
acid,
sulfonated,
sodium
salt
(
octadecanoic
acid,
sulfo,
sodium
salt)
67998­
94­
1
9­
Octadecenoic
acid
(
9Z­),
sulfonated
(
sulfonated
oleic
acid)
68988­
76­
1
Molecular
Formula
C18H33NaO5S
C18H35NaO5S
C18H34O5S
Molecular
Weight
384.51
386.52
363
Water
Solubility,
mg/
L
(
dispersible)
608
2
Vapor
Pressure,
mmHg
<
1
x
10­
6
2.29
x
10­
20,
estimated
<
1
x
10­
6
Henry
=

s
Law
Constant,
atmm3
mole
<
1
x
10­
8
8.75
x
10­
12
<
1
x
10­
8
Log
Kow
2.29
2.51,
estimated
4.44
Log
Koc
2.92
2.92
2.92
Log
BCF
1.85,
estimated
1.85,
estimated
1.85,
estimated
Melting
point,
0C
312
311.7
219
Boiling
point,
0C
>
400
712
>
400
5
Table
3.
Physical
and
Chemical
Properties
of
Oleic
Acid
Sulfonates
Physical
and
Chemical
Property
9­
Octadecenoic
acid
(
9Z­),
sulfonated,
sodium
salt
68443­
05­
0
Oleic
acid,
sulfonated,
sodium
salt
(
octadecanoic
acid,
sulfo,
sodium
salt)
67998­
94­
1
9­
Octadecenoic
acid
(
9Z­),
sulfonated
(
sulfonated
oleic
acid)
68988­
76­
1
Structure
O
O
S
O
O­
Na+

Sulfonated
Oleic
acid,
sodium
salt
O
O
O
S
O
O
O
Na
O
O
S
O
O
O
Dietary
Exposure
and
Risk
The
Food
and
Drug
Administration
has
established
several
food
additive
clearances
for
sulfonated
oleic
acid.
Specifically,
the
following
are
noted:

172.860,
21
CFR:
The
food
additive
fatty
acids
may
be
safely
used
in
food
and
in
the
manufacture
of
food
components
...
and
meets
the
following
specifications:
free
of
chick
edema
factor,
unsaponifiable
matter
does
not
exceed
2
percent..

172.862:
The
food
additive
oleic
acid
derived
from
tall
oil
fatty
acids
may
be
safely
used
in
food
and
as
a
component
in
the
manufacture
of
food
grade
additives
in
accordance
with
the
prescribed
conditions,
as
long
as
1)
the
quantity
added
to
food
does
not
exceed
the
amount
reasonably
required
to
accomplish
its
intended
physical,
nutritive,
or
other
technical
effect
in
food,
and
2)
when
intended
for
use
in
or
on
food
it
is
of
appropriate
food
grade
and
is
prepared
and
handled
as
a
food
ingredient.

176.200,
defoaming
agents:
oleic
acid,
sulfonated,
sodium
salt:
without
limitation,
can
be
used
safely
as
components
of
articles
intended
for
use
in
producing,
manufacturing,
packing,
processing,
preparing,
treating,
packaging,
transporting,
or
holding
food.

178.1010(
b)(
12):
A
An
aqueous
solution
containing
the
sodium
salt
of
sulfonated
oleic
acid...
In
addition
to
use
on
food­
processing
equipment
and
utensils,
this
solution
may
be
used
on
glass
bottles
and
other
glass
containers
intended
for
holding
milk.@

In
addition
to
these
clearances,
the
Agency
=

s
Inert
Ingredient
Focus
Group
(
IIFG)
has
also
performed
reassessment
of
tolerance
exemptions
for
several
fatty
acids
(
July,
2002),
including
oleic
acid.
The
conclusion
of
this
assessment
is
that
fatty
acids
as
a
group
are
of
low
toxicity,
are
metabolized
by
the
body
into
compounds
that
serve
as
energy
sources
and
components
of
cells,
6
and
there
is
no
harm
to
the
general
population
including
infants
and
children
when
exposed
to
these
compounds.
The
exposure
levels
encountered
from
the
pesticidal
use
of
sulfonated
oleic
acid
are
insignificant
in
comparison
to
levels
of
fatty
acids
encountered
normally
in
the
human
diet.
Therefore
there
is
no
risk
of
concern
from
dietary
exposure.

Non­
dietary
exposure
The
primary
uses
of
sulfonated
oleic
acid
as
an
antimicrobial
pesticide
are
in
food
processing/
handling/
storage
areas.
As
such,
potential
exposure
is
expected
to
be
primarily
through
the
diet
if
such
exposure
occurs.
Non­
dietary
exposure
through
dermal
and
inhalation
contact
may
be
expected,
but
sulfonated
oleic
acid
has
no
appreciable
vapor
pressure
at
ambient
temperatures,
and
oleic
acid
has
been
found
to
be
only
a
mild
dermal
irritant
at
high
doses.
Therefore,
at
the
exposures
expected
from
the
food
processing
uses,
risk
is
expected
to
be
negligible.

Conclusions
The
ADTC
considered
the
fact
that
the
registered
uses
for
sulfonated
oleic
acid
may
result
in
residues
in
food.
It
was
recognized,
however,
that
clearances
for
use
of
sulfonated
oleic
acid
up
to
200
ppm
are
allowed
by
the
Food
and
Drug
Administration
for
food
processing
equipment
and
glass
bottles
for
milk.
This
level
of
clearance
is
orders
of
magnitude
greater
than
the
Agency
=

s
level
of
concern
for
indirect
food
uses
of
antimicrobial
pesticides
(
i.
e.
>
200
parts
per
billion)
so
it
is
apparent
that
sulfonated
oleic
acid
is
of
a
low
order
of
toxicity.
Further,
the
ADTC
recognized
that
sulfonated
oleic
acid
is
similar
to
oleic
acid
itself.
The
fatty
acids
as
a
group
have
been
assessed
with
respect
to
safety
by
the
Agency
=

s
IIFG
workgroup
(
July
31,
2002
assessment
from
Kathryn
Boyle
and
Kerry
Leifer,
co­
chairs),
and
it
is
concluded
from
that
analysis
that
the
fatty
acids
have
a
safe
history
of
use
as
natural
components
of
many
foods,
as
direct
food
additives,
and
as
cosmetic
ingredients.
Fatty
acids
are
processed
by
known
metabolic
pathways
within
the
body
and
are
necessary
for
normal
cellular
functioning.
Further,
comparison
of
the
chemistry
of
sulfonated
oleic
acid
as
compared
to
the
non­
sulfonated
oleic
does
not
reveal
significant
differences.
As
the
exposures
anticipated
from
the
indirect
food
uses
(
as
well
as
non­
dietary
dermal
and/
or
inhalation
exposure)
are
insignificant
in
comparison
to
levels
encountered
for
fatty
acids
in
the
normal
human
diet,
use
of
these
chemicals
in
pesticide
products
is
unlikely
to
pose
any
significant
hazard
to
the
general
population
or
to
any
subgroup
including
infants
and
children.
Therefore,
there
are
no
toxicity
endpoints
of
concern
for
this
chemical.
