1
of
15
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
DC
20460
OFFICE
OF
PREVENTION,
PESTICIDES,
AND
TOXIC
SUBSTANCES
January
30,
2006
MEMORANDUM:

Subject:
Ecological
Hazard
and
Environmental
Risk
Assessment
of
alkylbenzene
sulfonates
for
the
Registration
Eligibility
Document
(
RED).
PC
Codes:
190116;
079010;
098002
To:
Jennifer
Slotnick,
Chemical
Review
Manager
Antimicrobials
Division
From:
Richard
C.
Petrie,
Agronomist,
Team
Leader
Risk
Assessment
and
Science
Support
Branch
(
RASSB)
Antimicrobials
Division
(
7510C)

Thru:
Norm
Cook,
Branch
Chief
Risk
Assessment
and
Science
Support
Branch
(
RASSB)
Antimicrobials
Division
(
7510C)

DP
Barcode:
323970
Decision
No.:
362579
Case
No.:
4006
Chemical
Name
(
s)
CAS
#
Sodium
Dodecylbenzene
Sulfonate
25155­
30­
0
Benzenesulfonic
acid,
C10­
16­
alkyl
derivatives
(
DDBSA)
68584­
22­
5
Dodecylbenzene
sulfonic
acid
(
DDBSA)
27176­
87­
0/
68584­
22­
5
2
of
15
ECOLOGICAL
HAZARD
AND
ENVIRONMENTAL
RISK
ASSESSMENT
ALKYLBENZENE
SULFONATES
CASE
4006
PC
CODE:
190116
01/
24/
2006
Richard
C.
Petrie
Antimicrobials
Division
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
3
of
15
Table
of
Contents
1.
Ecological
Toxicity
Data
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4
A.
Toxicity
to
Terrestrial
Animals
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5
1.
Birds,
Acute
and
Subacute
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5
2.
Mammals,
Acute
and
Chronic
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5
B.
Toxicity
to
Aquatic
Animals
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5
1.
Freshwater
Fish,
Acute
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6
2.
Freshwater
Invertebrates,
Acute
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6
3.
Estuarine
and
Marine
Organisms,
Acute
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7
4.
Aquatic
Organisms,
Chronic
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7
C.
Toxicity
to
Plants
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7
II.
Risk
Assessment
and
Risk
Characterization
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.9
A.
Environmental
Fate
Assessment
Summary
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11
B.
Environmental
Exposure
Assessment
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11
C.
Environmental
Risk
Assessment
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12
D.
Endangered
Species
Considerations
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III.
Confirmatory
Data
Required.
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14
IV.
Label
Hazard
Statements
for
Terrestrial
and
Aquatic
Organisms.
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.14
V.
References
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.
15
4
of
15
Ecological
Effects
Hazard
and
Environmental
Risk
Assessment
alkylbenzene
sulfonates
Alkylbenzene
sulfonates
are
used
for
a
variety
of
indoor
antimicrobial
uses.
Alkylbenzene
sulfonates
include
sodium
dodecylbenzene
sulfonate,
dodecylbenzene
sulfonic
acid,
and
benzenesulfonic
acid,
and
are
collectively
called
DDBSA
by
the
DDBSA
Joint
Venture
Task
Force.
All
alkylbenzene
sulfonates
as
pesticides
are
formulated
with
phosphoric
acid
(
CAS#
s
27276­
87­
0
and
68584­
22­
5;
mineral
acid
RED
­
EPA­
738­
93­
025,
December
1993).
Alkylbenzene
sulfonates
through
sulfonation
and
neutralization
becomes
linear
alkylbenzyl
sulfonate
(
LAS).

Currently
registered
use
categories
include
spray
application
to
agricultural
premises
and
equipment,
food
handling/
storage
establishment
premises
and
equipment,
commercial­
institutionalindustrial
premises
and
equipment,
medical
premises
and
equipment.
Sites
include:
milking
equipment,
dairy
farms,
teat
liners,
farm
utensils,
milk
claws
and
inflations,
bars,
restaurants,
dairy
equipment,
dairy
premises,
dairy
utensils,
milk
processing
plant
surfaces­
equipment­
premises,
milk
storage,
fruit
and
vegetable
wash
water,
food/
milk
transport
vehicles,
food
processing
plant
equipment­
handling­
storage
premises
and
surfaces,
bakery
processing
equipment,
brewery
process
plant
equipment
and
surfaces,
cannery
processing
equipment,
potato
washing
machines,
winery
processing
equipment,
egg
processing
equipment,
beverage
processing
equipment­
premises
and
surfaces,
meat
and
poultry
processing
equipment­
premises
and
surfaces,
food
vending
and
dispensing
machines,
soft
custard
equipment,
food
stores/
markets,
seed
houses,
food
service
industry
pots
and
pans,
research
animal
facilities,
zoo
premises,
airports,
campgrounds,
commercial
transportation
facilities,
aircraft,
buses,
ships,
automobiles,
railroad
trains,
shower
stalls,
urinals,
toilet
bowls,
sickroom
premises,
and
healthcare
facilities.
There
are
no
home­
owner
or
residential
uses
currently
registered.
The
only
outdoor
use,
mine
acid
control,
was
voluntarily
withdrawn
by
the
registrant.

Of
the
approximate
30
million
pounds
of
alkylbenzene
sulfonates
produced
per
year,
0.1%
or
300,000
pounds
are
used
in
EPA
registered
antimicrobial
products.
The
rest
is
primarily
used
in
household
laundry
and
dish
detergents
annually.

I.
Ecological
Toxicity
Data
The
toxicity
endpoints
presented
below
are
based
on
the
results
of
ecotoxicity
studies
submitted
to
EPA
to
meet
the
Agency=
s
data
requirements
for
the
uses
of
the
alkylbenzene
sulfonates.
The
linear
chained
alkylbenzene
sulfonates
(
LAS)
replaced
the
highly
persistent
branched
alkylbenzene
sulfonates
(
ABS)
in
the
mid
1960'
s
in
laundry
detergents.
The
environmental
fate
and
effects
or
LAS
detergent
formulations
on
aquatic/
terrestrial
organisms
are
well
studied
(
see
5
of
15
www.
inchem.
org
and
www.
cler.
com
for
detailed
information).
Ecotoxicity
data
available
for
LAS
is
assumed
to
be
representative
of
DDBSA
based
on
available
literature.

A.
Toxicity
to
Terrestrial
Animals
(
1)
Birds,
Acute
and
Subacute
In
order
to
establish
the
toxicity
of
alkylbenzene
sulfonates
to
avian
species
for
environmental
hazard
labeling,
the
Agency
requires
an
acute
oral
toxicity
study
using
the
TGAI
for
outdoor
uses
having
no
environmental
exposure
of
concern.
One
avian
acute
test
species
is
required
for
indoor
uses
for
label
hazard
purposes.
Preferred
test
species
can
be
either
the
mallard
duck
(
a
waterfowl)
or
the
Northern
bobwhite
quail
(
an
upland
game
bird).
See
Table
1
below
for
test
results.

Table
1.
Acute
Oral
Toxicity
of
sodium
dodecylbenzene
sulfonate
to
Birds
Species
chemical,
%
Active
Ingredient
(
ai)
Endpoint
(
mg/
kg)
Toxicity
Category
(
TGAI)
Satisfies
Guidelines/
Comments
Reference
Northern
bobwhite
(
Colinus
virginianus)
87.6%
Carbon
chain
not
identified.
(
Nacconal
90G
used)
LD50
>
1382
NOEL
=
279
Slightly
toxic
Yes.
Acceptable.

14
day
test
MRID:

41143901
The
results
indicate
that
LAS
is
slightly
toxic
to
the
Northern
bobwhite
quail
on
an
acute
oral
basis.
The
sodium
dodecylbenzene
sulfonate
study
MRID
41143901
fulfills
guideline
requirement
850.2100.
The
avian
acute
oral
LD50
is
>
500
ppm,
therefore,
an
avian
environmental
hazard
statement
for
birds
is
not
required
on
manufacturing
use
product
labels.

A
subacute
dietary
study
using
the
TGAI
may
be
required
on
a
case­
by­
case
basis
depending
on
the
results
of
lower­
tier
ecological
studies
and
pertinent
environmental
fate
characteristics
in
order
to
establish
the
toxicity
of
a
chemical
to
avian
species,
however,
this
testing
is
not
required
unless
outdoor
uses
are
added
to
alkylbenzene
sulfonate
labels.

(
2)
Mammals,
Acute
and
Chronic
Toxicity
In
most
cases,
rat
toxicity
studies
for
human
health
risk
assessments
are
used
as
surrogates
for
wild
mammal
testing.
Wild
mammal
tests
are
not
required
for
alkylbenzene
sulfonates
at
this
time
because
the
currently
registered
uses
are
indoor
spray
applications.
Refer
to
the
toxicology
section
of
this
RED
for
mammalian
toxicity
data.
6
of
15
B.
Toxicity
to
Aquatic
Animals
(
1)
Freshwater
Fish,
Acute
In
order
to
establish
the
acute
toxicity
of
pesticides
to
freshwater
fish
for
environmental
hazard
labeling,
the
Agency
requires
a
TGAI
study
for
indoor
uses
having
no
environmental
exposure
of
concern.
The
preferred
test
species
are
rainbow
trout
(
a
coldwater
fish)
or
bluegill
sunfish
(
a
warm
water
fish).
Results
of
freshwater
fish
acute
testing
for
LAS
are
presented
in
Table
2.
Table
2.
Acute
Toxicity
of
LAS
to
Freshwater
Fish
Species
%
Active
Ingredient
(
ai)
Endpoints
(
ppm)
Toxicity
Category
Satisfies
Guidelines/
Comments
Reference
Fathead
Minnow
(
Pimephales
promelas)
14.0%*
96hr
LC50
=

3.4
mg/
L
Moderately
toxic
No.
Supplemental
study.
44260002
Rainbow
trout
(
Oncorhynchus
mykiss)
65.0%
C11,
C12
96
hr
LC50
=
1.68
mg/
L
Moderately
toxic
No.
Supplemental
study.
44260009
*
Carbon
chain
not
identified.

The
guideline
requirement
for
a
freshwater
fish
acute
test
has
not
been
fulfilled.
Guideline
850.1075
is
outstanding
for
DDBSA.
One
acute
freshwater
fish
toxicity
test
using
technical
grade
DDBSA
must
be
submitted
in
order
to
support
the
current
indoor
uses.
Available
data
for
aquatic
organisms
indicate
that
DDBSA's
may
be
more
toxic
to
aquatic
organisms
as
the
number
of
carbons
in
the
chain
increase.
No
acute
fish
toxicity
data
are
available
for
carbon
chains
above
12.
DDBSA
may
contain
chains
up
to
or
greater
than
14.
Therefore,
a
fish
environmental
hazard
label
statement
is
required
on
manufacturing
use
product
labels
at
this
time.

(
2)
Freshwater
Invertebrates,
Acute
In
order
to
establish
the
acute
toxicity
of
pesticides
to
freshwater
aquatic
invertebrates
for
environmental
hazard
labeling,
the
Agency
requires
a
TGAI
study
for
indoor
uses
having
no
environmental
exposure
of
concern.
The
preferred
test
species
is
Daphnia
magna.
See
Table
3
below
for
results
of
available
studies
for
LAS.

Table
3.
Acute
Toxicity
of
LAS
to
Freshwater
Invertebrates
7
of
15
Species
%
Active
Ingredient
(
ai)
Endpoints
(
ppm)
Toxicity
Category
Satisfies
Guidelines/
Comments
Reference
Waterflea
(
Daphnia
magna)
Not
reported.
48­
hr.
EC50
=
LAS­
C10
=
29.5
mg/
L,
LAS­
C12
=
6.84
mg/
L,
LAS­
C14
=
0.80
mg/
L,
LAS­
C16
=
0.20
mg/
L.
C­
10
=
Slightly
toxic,
C14
=
highly
toxic.
No.
Supplemental
study.
47025025
The
results
of
this
study
indicate
that
LAS
toxicity
to
Daphnia
magna
is
variable,
dependent
on
the
length
of
the
carbon
chain.
LAS
antimicrobial
formulations
are
comprised
primarily
of
C10
to
C14
chains
(
DDBSA
Task
Force),
and
therefore
LAS
formulations
are
slightly
to
highly
toxic
to
freshwater
invertebrates.
Guideline
850.1010
is
outstanding
for
DDBSA.
One
acute
freshwater
invertebrate
study
using
technical
grade
DDBSA
must
be
submitted
in
order
to
support
the
current
indoor
use.
Based
on
study
results
above
(
MRID
47025025)
an
environmental
hazard
statement
for
aquatic
invertebrates
is
required
on
manufacturing
use
products
because
the
EC50
is
<
1.0
ppm
(
C14,
C16).

(
3)
Estuarine
and
Marine
Organisms,
Acute
Acute
toxicity
testing
with
estuarine
and
marine
organisms
using
the
TGAI
is
required
when
the
end­
use
product
is
intended
for
direct
application
to
the
marine/
estuarine
environment
or
effluent
containing
the
active
ingredient
is
expected
to
reach
this
environment.
Acute
estuarine/
marine
tests
are
not
required
for
alkylbenzene
sulfonates
because
the
currently
registered
uses
are
indoor
applications.

(
4)
Aquatic
Organisms,
Chronic
Chronic
toxicity
testing
(
Fish
early
life
stage,
850.1300/
72­
4a
and
aquatic
invertebrate
life
cycle,
850.1400/
72­
4b)
is
required
for
pesticides
when
certain
conditions
of
use
and
environmental
fate
apply.
Chronic
aquatic
organism
tests
are
not
required
for
alkylbenzene
sulfonates
because
the
currently
registered
uses
are
indoor
applications.

C.
Toxicity
to
Plants
Non­
target
plant
phytotoxicity
tests
are
required
for
pesticides
when
uses
result
in
exposure
to
the
environment.
This
testing
is
not
required
for
alkylbenzene
sulfonates
because
the
currently
registered
uses
are
indoor
applications.
Refer
to
Table
4
below
for
the
summary
of
a
non­
target
plant
phytotoxicity
study
using
green
algae.
8
of
15
Table
4.
Acute
Toxicity
of
LAS
to
Green
Algae
Species
%
active
ingredient
(
ai)
Endpoints
(
ppm)
Toxicity
Category
Satisfies
Guidelines/
Comments
Reference
MRID:

Selenastrum
capricornutum
Not
Reported.
Carbon
chain
not
identified.
96
hr.
EC50
=
70.27
Slightly
toxic
No.
Supplemental.
42439803
9
of
15
II.
Risk
Assessment
and
Characterization
Risk
assessment
integrates
the
results
of
the
exposure
and
ecotoxicity
data
to
evaluate
the
likelihood
of
adverse
ecological
effects.
One
method
of
integrating
the
results
of
exposure
and
ecotoxicity
data
is
called
the
quotient
method.
For
this
method,
risk
quotients
(
RQs)
are
calculated
by
dividing
exposure
estimates
by
ecotoxicity
values,
both
acute
and
chronic:

RQ
=
EXPOSURE/
TOXICITY
RQs
are
then
compared
to
OPP's
levels
of
concern
(
LOCs).
These
LOCs
are
criteria
used
by
OPP
to
indicate
potential
risk
to
nontarget
organisms
and
the
need
to
consider
regulatory
action.
The
criteria
indicate
that
a
pesticide
used
as
directed
has
the
potential
to
cause
adverse
effects
on
nontarget
organisms.
LOCs
currently
address
the
following
risk
presumption
categories:
(
1)
acute
high
­
potential
for
acute
risk
is
high,
and
regulatory
action
may
be
warranted
in
addition
to
restricted
use
classification;
(
2)
acute
restricted
use
­
the
potential
for
acute
risk
is
high,
but
this
may
be
mitigated
through
restricted
use
classification;
(
3)
acute
endangered
species
­
the
potential
for
acute
risk
to
endangered
species
is
high,
and
regulatory
action
may
be
warranted;
and
(
4)
chronic
risk
­
the
potential
for
chronic
risk
is
high,
and
regulatory
action
may
be
warranted.
Currently,
AD
does
not
perform
assessments
for
chronic
risk
to
plants,
acute
or
chronic
risks
to
nontarget
insects,
or
chronic
risk
from
granular/
bait
formulations
to
mammalian
or
avian
species.

The
ecotoxicity
test
values
(
i.
e.,
measurement
endpoints)
used
in
the
acute
and
chronic
risk
quotients
are
derived
from
the
results
of
required
studies.
Examples
of
ecotoxicity
values
derived
from
the
results
of
short­
term
laboratory
studies
that
assess
acute
effects
are:
(
1)
LC50
(
fish
and
birds)
(
2)
LD50
(
birds
and
mammals)
(
3)
EC50
(
aquatic
plants
and
aquatic
invertebrates)
and
(
4)
EC25
(
terrestrial
plants).
Examples
of
toxicity
test
effect
levels
derived
from
the
results
of
long­
term
laboratory
studies
that
assess
chronic
effects
are:
(
1)
LOEC
(
birds,
fish,
and
aquatic
invertebrates)
(
2)
NOEC
(
birds,
fish
and
aquatic
invertebrates)
and
(
3)
MATC
(
Maximum
Allowable
Toxic
Concentration)
(
fish
and
aquatic
invertebrates).
For
birds
and
mammals,
the
NOEC
value
is
used
as
the
ecotoxicity
test
value
in
assessing
chronic
effects.
Other
values
may
be
used
when
justified.
Generally,
the
MATC
(
defined
as
the
geometric
mean
of
the
NOEC
and
LOEC)
is
used
as
the
ecotoxicity
test
value
in
assessing
chronic
effects
to
fish
and
aquatic
invertebrates.
However,
the
NOEC
is
used
if
the
measurement
endpoint
is
production
of
offspring
or
survival.

Risk
presumptions,
along
with
the
corresponding
RQs
and
LOCs
are
tabulated
below.

Risk
Presumptions
for
Terrestrial
Animals
Risk
Presumption
RQ
LOC
Birds
and
Wild
Mammals
Acute
High
Risk
EEC1/
LC50
or
LD50/
sqft2
or
LD50/
day3
0.5
Acute
Restricted
Use
EEC/
LC50
or
LD50/
sqft
or
LD50/
day
(
or
LD50
<
50
mg/
kg)
0.2
10
of
15
Acute
Endangered
Species
EEC/
LC50
or
LD50/
sqft
or
LD50/
day
0.1
Chronic
Risk
EEC/
NOEC
1
1
abbreviation
for
Estimated
Environmental
Concentration
(
ppm)
on
avian/
mammalian
food
items
2
mg/
ft2
3
mg
of
toxicant
consumed/
day
LD50
*
wt.
of
bird
LD50
*
wt.
of
bird
Risk
Presumptions
for
Aquatic
Animals
Risk
Presumption
RQ
LOC
Acute
High
Risk
EEC1/
LC50
or
EC50
0.5
Acute
Restricted
Use
EEC/
LC50
or
EC50
0.1
Acute
Endangered
Species
EEC/
LC50
or
EC50
0.05
Chronic
Risk
EEC/
MATC
or
NOEC
1
1
EEC
=
(
ppm
or
ppb)
in
water
Risk
Presumptions
for
Plants
Risk
Presumption
RQ
LOC
Terrestrial
and
Semi­
Aquatic
Plants
Acute
High
Risk
EEC1/
EC25
1
Acute
Endangered
Species
EEC/
EC05
or
NOEC
1
Aquatic
Plants
Acute
High
Risk
EEC2/
EC50
1
Acute
Endangered
Species
EEC/
EC05
or
NOEC
1
1
EEC
=
lbs
ai/
A
2
EEC
=
(
ppb/
ppm)
in
water
A.
Environmental
Fate
Assessment
Summary
(
excerpted
from
the
Environmental
Fate
Science
Chapter
of
this
RED
document)
11
of
15
No
fate
studies
for
DDBSA
are
available
in
US
EPA's
files.
It
was
decided
by
the
agency
during
Phase
IV
or
reregistration
that
data
in
the
open
literature
would
be
utilized
in
the
DDBSA
environmental
fate
assessment.
The
EPI
Suite
model
was
run
to
obtain
different
environmental
properties
for
DDBSA's.
These
values
are
provided
in
Section
3.0,
"
Model
Results."
The
output
parameters
model
support
that
any
potential
impacts
are
expected
to
be
very
short­
lived.
This
is
because
the
chemical
is
not
likely
to
persist
in
water
or
microbial
soils
and
sediments.
The
Agency
also
conducted
a
literature
search
to
further
support
the
output
parameters
that
were
provided
by
the
EPI
Suite
model.
The
results
of
the
literature
search
are
presented
in
Section
4.0,
"
Additional
Data
from
Literature
Search."

Sodium
dodecylbenzene
sulfonate
is
highly
unlikely
to
bioaccumulate
in
the
environment
or
aquatic
organisms
(
i.
e.
fish)
because
the
low
value
for
the
log
Kow
(
3).
The
chemical
is
also
expected
to
be
soluble
in
water
such
that
it
will
exhibit
mobility
through
the
soil.
In
addition,
the
low
log
Koc
(
4.2261)
further
supports
the
expected
soil
mobility.
The
model­
calculated
linear
and
nonlinear
biodegradation
probabilities
suggest
that
the
linear
carbon
chain
will
biodegrade
rapidly,
whereas
the
benzene
ring
is
not
expected
to
biodegrade
as
rapidly.
The
short
half
life
of
approximately
7.914
hours
indicates
that
if
this
chemical
is
present
in
the
soil,
it
is
likely
to
vaporize
easily
and
degrade
rapidly.

DDBSA
is
expected
to
behave
very
similarly
as
what
is
projected
for
sodium
dodecylbenzene
sulfonate.
Based
on
the
low
Kow
value
(
3.80),
DDBSA
is
highly
unlikely
to
bioaccumulate
in
the
environment
or
aquatic
organisms
(
i.
e.
fish).
The
chemical
is
also
expected
to
be
soluble
in
water
such
that
it
will
exhibit
mobility
through
the
soil.
In
addition,
the
log
Koc
(
3.6944)
is
low,
and
this
further
supports
the
expected
soil
mobility.
The
model­
calculated
linear
and
non­
linear
biodegradation
probabilities
suggest
that
the
chemical
will
most
likely
biodegrade
rapidly.
The
short
half
life
of
approximately
9.485
hours
indicates
that
this
chemical
is
likely
to
vaporize
easily
from
soils
and
degrade
rapidly.

As
a
result
of
the
modular
output
along
with
the
information
gathered
from
the
literature
search,
the
environmental
fate
of
alkylbenzene
sulfonates
is
not
likely
to
be
of
a
concern.
Likewise,
minimal
or
no
environmental
exposure
is
expected
to
occur
from
the
majority
of
alkylbenzene
sulfonate
antimicrobial
pesticide
uses
because
it
is
unlikely
that
any
appreciable
exposure
to
terrestrial
or
aquatic
organisms
would
occur.
This
is
assumed
based
on
the
information
that
a
very
small
number
of
pounds
of
this
chemical
are
sold
for
commercial
down­
the­
drain
use.

B.
Environmental
Exposure
Assessment
Environmental
exposure
modeling
was
not
conducted
for
alkylbenzene
sulfonic
acids
and
sulfonates
because
the
currently
registered
uses
are
indoor
spray
applications.
Uses
such
as
urinals
and
toilet
bowls
could
result
in
minimal
exposure
to
the
environment
when
flushed.
However,
significant
environmental
exposure
is
not
expected
for
the
following
reasons:
1.)
total
LAS
usage
for
these
industrial
applications
is
very
minor
­
a
very
small
percentage
of
the
total
pounds
used
in
antimicrobials;
and
commercial
only
use
precludes
broad
environmental
exposures
that
might
occur
12
of
15
with
residential
use,
applications
are
mostly
sprayed
on
and
allowed
to
air
dry
2.)
LAS
breakdown
and
degradation
in
the
environment
is
very
rapid,
3.)
LAS
is
significantly
reduced
by
sewage
treatment.
Industrial
water
treatment
requires
a
NPDES
permit
in
order
to
discharge
effluents.

C.
Environmental
Risk
Assessment
Linear
alkyl
benzene
sulfonates
(
LAS)
have
been
the
principal
ingredient
in
laundry
detergent
for
30+
years.
Volume
12
(
10)
of
the
1993
issue
of
Environmental
Toxicology
and
Chemistry
featured
a
series
of
papers
on
environmental
impacts
of
LAS
in
a
special
symposium:
Surfactants
and
Their
Environmental
Safety
­
convened
by
R.
A.
Kimerle,
N.
T.
De
Oude
and
T.
W.
La
Point.
Two
papers
provide
excellent
summaries
of
ecotoxicity
endpoints
from
literature,
and
feature
laboratory
vs
field
analysis
of
detergent
generated
LAS
impacts
on
aquatic
organisms.
An
assessment
of
short
and
long­
term
impacts
of
LAS
detergents
on
the
environment
was
conducted.
Monitoring
indicates
that
concentrations
of
0.230
mg/
L
(
continuous
criterion
concentration)
and
0.625
mg/
L
(
criterion
maximum
concentration)
are
rarely
exceeded
in
aquatic
systems
protected
by
activated
sludge
treatment
systems.
Ecotoxicity
studies
indicate
that
a
laboratory
derived
NOAEC
value
of
0.40
mg/
L
LAS
is
protective
of
structure
and
function
of
experimental
streams.
Mortality
was
determined
more
sensitive
than
growth
as
a
chronic
endpoint
in
chronic
fathead
minnow
(
Pimephales
promelas)
studies.
The
chronic
NOAEC
toxicity
value
from
the
28
day
study
for
fathead
minnow
using
carbon
chain
C11.7
was
0.7
mg/
L
(
Fairchild
et
al,
1993).
In
a
second
symposia
study,
the
in
situ
toxicity
of
LAS
to
natural
periphyton
communities
before
and
after
wastewater
treatment
was
assessed.
Upstream
and
downstream
algal
communities
were
evaluated
before
and
after
the
introduction
of
LAS
into
the
stream.
LAS
inhibitory
effect
levels
were
higher
(
3.3
mg/
L)
than
average
levels
recorded
in
wastewater
treatment
plant
outflows
in
the
U.
S.
(
0.115
average).
Increases
and
decreases
in
periphyton
community
abundance
were
observed,
but
determined
not
to
be
significant
for
the
three
major
species
evaluated:
Amphora
perpusilla,
Navicula
minima,
and
Schizothrix
calcicola
(
Lewis
et
al,
1993).

No
environmental
exposure
is
expected
to
occur
from
the
majority
of
linear
alkylbenzene
sulfonate
uses
and
it
is
unlikely
that
any
appreciable
exposure
to
terrestrial
or
aquatic
organisms
would
occur
from
limited
commercial
down­
the­
drain
use
because
of
the
very
small
number
of
pounds
sold
for
these
uses
as
compared
to
the
detergent
market
and
rapid
degradation.

D.
Endangered
Species
Considerations
Section
7
of
the
Endangered
Species
Act,
16
U.
S.
C.
Section
1536(
a)(
2),
requires
all
federal
agencies
to
consult
with
the
National
Marine
Fisheries
Service
(
NMFS)
for
marine
and
andronomus
listed
species,
or
the
United
States
Fish
and
Wildlife
Services
(
FWS)
for
listed
wildlife
and
freshwater
organisms,
if
they
are
proposing
an
"
action"
that
may
affect
listed
species
or
their
designated
habitat.
Each
federal
agency
is
required
under
the
Act
to
insure
that
any
action
they
authorize,
fund,
or
carry
out
is
not
likely
to
jeopardize
the
continued
existence
of
a
listed
species
or
result
in
the
destruction
or
adverse
modification
of
designated
critical
habitat.
To
jeopardize
the
continued
existence
of
a
listed
13
of
15
species
means
"
to
engage
in
an
action
that
reasonably
would
be
expected,
directly
or
indirectly,
to
reduce
appreciably
the
likelihood
of
both
the
survival
and
recovery
of
a
listed
species
in
the
wild
by
reducing
the
reproduction,
numbers,
or
distribution
of
the
species."
50
C.
F.
R.
'
402.02.

To
facilitate
compliance
with
the
requirements
of
the
Endangered
Species
Act
subsection
(
a)(
2)
the
Environmental
Protection
Agency,
Office
of
Pesticide
Programs
has
established
procedures
to
evaluate
whether
a
proposed
registration
action
may
directly
or
indirectly
reduce
appreciably
the
likelihood
of
both
the
survival
and
recovery
of
a
listed
species
in
the
wild
by
reducing
the
reproduction,
numbers,
or
distribution
of
any
listed
species
(
U.
S.
EPA
2004).
After
the
Agency=
s
screening­
level
risk
assessment
is
performed,
if
any
of
the
Agency=
s
Listed
Species
LOC
Criteria
are
exceeded
for
either
direct
or
indirect
effects,
a
determination
is
made
to
identify
if
any
listed
or
candidate
species
may
co­
occur
in
the
area
of
the
proposed
pesticide
use.
If
determined
that
listed
or
candidate
species
may
be
present
in
the
proposed
use
areas,
further
biological
assessment
is
undertaken.
The
extent
to
which
listed
species
may
be
at
risk
then
determines
the
need
for
the
development
of
a
more
comprehensive
consultation
package
as
required
by
the
Endangered
Species
Act.

For
certain
use
categories,
the
Agency
assumes
there
will
be
minimal
environmental
exposure,
and
only
a
minimal
toxicity
data
set
is
required
(
Overview
of
the
Ecological
Risk
Assessment
Process
in
the
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
­
Endangered
and
Threatened
Species
Effects
Determinations,
1/
23/
04,
Appendix
A,
Section
IIB,
pg.
81).
Chemicals
in
these
categories
therefore
do
not
undergo
a
full
screening­
level
risk
assessment,
and
are
considered
to
fall
under
a
Ano
effect@
determination.
The
active
ingredient
uses
of
alkylbenzene
sulfonic
acids
and
sulfonates
fall
into
this
category
for
the
following
reasons:

1.
The
amount
that
will
actually
reach
the
environment
is
very
small
based
on
usage
data
for
down­
the­
drain
uses.
2.
Use
for
toilets
and
urinals
is
limited
(
no
home­
owner
or
residential
uses
are
registered).
3.
Breakdown
of
LAS
in
the
environment
and
via
sewage
treatment
is
rapid
and
well
documented
in
the
literature.

The
labeled
antimicrobial
uses
of
alkylbenzene
sulfonic
acids
and
sulfonates
are
not
expected
to
result
in
significant
environmental
exposure.
Therefore,
no
adverse
effects
(
NE)
to
listed
species
are
anticipated.

III.
Confirmatory
Data
Required
Valid
acute
aquatic
toxicity
studies
for
fish
and
invertebrates
must
be
submitted
to
support
indoor
use
patterns.
These
studies
are:
14
of
15
850.1075
­
Acute
Freshwater
Fish
using
TGAI
DDBSA
on
Rainbow
trout
or
Bluegill
sunfish
850.1010
­
Acute
Freshwater
Invertebrate
using
TGAI
DDBSA
on
Daphnia
magna
Based
on
DDBSA
task
force
data
provided,
DDBSA
typically
contains
a
range
of
carbon
chain
lengths
from
10
to
16.
Study
MRID
47025025
indicates
that
the
greater
the
number
of
carbons,
the
greater
the
toxicity
to
Daphnia
magna.
For
example,
C10
was
slightly
toxic
and
C14
was
highly
toxic.
DDBSA
TGAI
with
the
highest
carbon
length
must
be
used
in
aquatic
toxicity
tests.

IV.
Label
Hazard
Statements
for
Terrestrial
and
Aquatic
Organisms
Manufacturing
use
products
must
state:

"
This
pesticide
is
toxic
to
fish
and
aquatic
invertebrates".

"
Do
not
discharge
effluent
containing
this
product
into
lakes,
streams,
ponds,
estuaries,
oceans,
or
other
waters
unless
in
accordance
with
the
requirements
of
a
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
and
the
permitting
authorities
are
notified
in
writing
prior
to
discharge.
Do
not
discharge
effluent
containing
this
product
to
sewer
systems
without
previously
notifying
the
local
sewage
treatment
plant
authority.
For
guidance
contact
your
State
Water
Board
or
Regional
Office
of
the
EPA."
15
of
15
V.
REFERENCES
MRID
41143901
­
Lloyd,
D.;
Grimes,
J.;
Jaber,
M.
(
1989)
Nacconol
90G:
An
Acute
Oral
Toxicity
Study
with
the
Bobwhite:
Final
Report:
Wildlife
International
Ltd.
Project
No.
257­
101.
Unpublished
study
prepared
by
Wildlife
International
Ltd.
26p.

MRID
42439803
­
Bollman,
M.
A.
et.
al.
(
1990)
Report
on
the
Algal
Toxicity
Tests
of
Selected
Office
of
Toxic
Substances
(
OTS)
Chemicals.
US
EPA
Environmental
Research
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179p.

MRID
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­
McKim,
J.
M.;
Arthur,
J.
W.;
Thorslund,
T.
W.
(
1975)
Toxicity
of
Linear
Alkylate
Sulfonate
Detergent
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Larvae
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USEPA,
Nat.
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Qual.
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Duluth,
MN.
Bulletin
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Vol
14
(
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pg.
1­
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MRID
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­
Calamari,
D.;
Marchetti,
R.
(
1973)
The
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of
Mixtures
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Metals
and
Surfactants
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1453­
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47025025
­
Maki,
A.
W.;
Bishop,
W.
E.
(
1979)
Acute
Toxicity
Studies
of
Surfactants
to
Daphnia
magna
and
Daphnia
pulex.
Archives
of
Environmental
Contamination
and
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Vol.
8,
p.
599­
612.
Sponsored
by
The
Proctor
and
Gamble
Company
USA,
Ivorydale
Technical
Ctr.,
Cincinnati,
OH.

Fairchild,
J.
F.,
F.
J.
Dwyer,
T.
W.
La
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S.
A.
Burch,
and
C.
G.
Ingersoll.
1993.
Evaluation
of
a
Laboratory­
Generated
NOEC
For
Linear
Alkylbenzene
Sulfonate
In
Outdoor
Experimental
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Environmental
Toxicology
and
Chemistry.
Vol.
12(
10):
1763­
1775.
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Their
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Arlington,
VA,
Nov.
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15,
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Lewis,
M.
A.,
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A.
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