Page
1
of
7
IUR
Petition
Review
Report
June
13,
2005
CASRN
and
TSCA
Inventory
Chemical
Name:
106­
63­
8
2­
propenoic
acid,
2­
methylpropyl
ester
Alternate
Chemical
Name
Used
in
Petitions:
iso­
Butyl
Acrylate
Petitioners
and
Petition
Docket
Numbers:
The
Basic
Acrylic
Monomer
Manufacturers,
Inc.
(
BAMM)
OPPT­
2004­
0008
BASF
Corporation
OPPT­
2004­
0044
Note:
The
petitions
contained
additional
chemicals.
These
additional
chemicals
are
addressed
in
other
petition
review
reports.

Summary
of
Decision:
The
petition
review
group
recommends
a
denial
for
these
petitions,
as
EPA
has
a
current
interest
in
the
processing
and
use
information
collected
under
the
Inventory
Update
Reporting
(
IUR)
rule
(
see
40
CFR
Part
710)
for
2­
propenoic
acid,
2­
methylpropyl
ester
(
CASRN
106­
63­
8).
This
recommendation
is
based,
in
part,
on
the
determination
by
the
petition
review
group
that
there
is
a
direct
application
of
the
IUR
processing
and
use
information
to
complement
data
collected
by
or
identified
for
use
under
the
HPV
Challenge
Program.
See
Considerations
A,
C,
D,
and
E.

Background:
EPA
received
two
petitions
requesting
that
2­
propenoic
acid,
2­
methylpropyl
ester
(
CASRN
106­
63­
8)
be
added
to
the
40
CFR
710.46(
b)(
2)(
iv)
list
of
specific
chemical
substances
which
are
exempt
from
the
reporting
of
industrial
processing
and
use
and
commercial/
consumer
use
information
required
by
40
CFR
710.52(
c)(
4).
The
chemical
substances
included
on
this
"
partial
exemption"
list
are
substances
for
which
EPA
has
previously
determined
that
there
is
a
low
current
interest
in
the
IUR
processing
and
use
information.
However,
as
stated
in
the
preamble
to
the
amendment
to
the
IUR
rule
promulgated
on
January
7,
2003
(
68
FR
854),
"...
the
need
for
processing
and
use
information
...
changes
over
time.
The
inclusion
of
a
chemical
substance
under
this
partial
exemption
is
not
based
on
the
potential
risks
of
a
chemical.
This
partial
exemption
is
solely
intended
to
provide
a
tool
to
assist
the
Agency
in
better
managing
the
collection
of
processing
and
use
information..."
and
is
also
"
based
on
the
Agency's
current
need
for
collecting
IURA
processing
and
use
information."
(
68
FR
855)
Additionally,
the
preamble
states,
"
In
determining
whether
there
is
low
current
interest
in
IURA
processing
and
use
information
related
to
a
specific
chemical
substance,
EPA
will
look
to
the
specific
circumstances
surrounding
the
chemical
in
question,
and
may
use
one
or
more
of
the
considerations
identified
below,
and/
or
considerations
not
identified
below,
to
make
an
informed
decision."
The
considerations
used
by
EPA
in
reviewing
these
petitions
and
an
analysis
of
how
those
considerations
relate
to
the
chemical
identified
in
these
petitions
are
set
forth
below.
1
See
the
attached
list
of
acronyms
at
the
end
of
this
report.

Page
2
of
7
Discussion:
The
petition
review
group
considered
information
submitted
with
the
two
petitions,
as
well
as
other
information
including
(
but
not
limited
to):
whether
the
petition
substance
is
included
in
TRI,
IRIS,
or
IARC;
OECD
HPV
SIDS
program
status;
HPV
Challenge
Program
status;
and
the
petition
chemical's
inclusion
in
other
regulatory
programs
administered
by
EPA.
1
The
petition
from
the
BASF
Corporation
(
docket
number
OPPT­
2004­
0044)
stated
that
2­
propenoic
acid,
2­
methylpropyl
ester
(
CASRN
106­
63­
8)
is
in
the
OECD
HPV
SIDS
program,
and
referred
EPA
to
the
completed
OECD
HPV
SIDS
program
documents
for
this
chemical.
The
petition
stated
that
the
BASF
Corporation
believes
that
the
information
in
the
OECD
HPV
SIDS
program
documents
demonstrates
that
there
is
little
need
at
this
time
to
collect
processing
and
use
information
for
this
chemical.

The
petition
from
the
BAMM
(
docket
number
OPPT­
2004­
0008)
also
referred
EPA
to
the
OECD
HPV
SIDS
program
documents
for
this
chemical,
and
stated
that
the
information
provided
therein
"
should
be
sufficient
for
EPA
to
make
the
necessary
determination
to
include
this
chemical
on
the
list
for
partial
reporting
exemption
under
IURA."
Additionally,
this
petition
stated
that
"
There
is
a
great
deal
of
information
on
the
basic
acrylates
use
and
exposure."

The
petitions
did
not
link
information
furnished
in
the
petitions
to
specific
considerations
cited
in
40
CFR
710.46(
b)(
2)(
ii),
but
provided
a
general
citation,
as
noted
above,
to
OECD
HPV
SIDS
program
documents
for
2­
propenoic
acid,
2­
methylpropyl
ester
(
CASRN
106­
63­
8).
General
citations
alone
are
of
limited
use
in
establishing
a
rationale
for
adding
a
chemical
to
the
IUR
partial
exemption
list.

Consideration
A:
Production
volume.

The
petition
review
group
found
that
there
was
at
least
one
site
reporting
in
2002
with
a
production
volume
for
this
chemical
of
300,000
pounds
or
greater.

Consideration
B:
The
substance's
chemical
and
physical
properties
or
potential
for
persistence,
bioaccumulation,
health
effects,
or
environmental
effects.

The
petitions
did
not
identify
specific
information
from
the
OECD
HPV
SIDS
review
that
pertained
to
Consideration
B.
The
OECD
HPV
SIDS
program
SIAP
indicated
that
2­
propanoic
acid,
butyl
ester
(
CASRN
141­
32­
2)
was
used
as
an
analog
for
2­
propenoic
acid,
2­
methylpropyl
ester
(
CASRN
106­
63­
8)
based
on
structural
similarities
and
similar
toxicokinetics,
acute
toxicity,
corrosiveness
and
irritation,
and
genetic
toxicity
(
in
vitro
and
in
vivo)
data.
The
SIAP
contained
summary
results
of
a
variety
of
studies
associated
with
human
health
and
the
environment
and
a
conclusion
that
2­
propenoic
acid,
2­
methylpropyl
ester
(
CASRN
106­
63­
8)
"
possesses
properties
indicating
a
hazard
for
human
health
and
the
environment"
(
Ref.
1).
2
Risk
is
composed
of
hazard
and
exposure.
In
order
to
screen
for
potential
risk
in
the
U.
S.,
both
hazard
data
and
exposure­
related
data
relative
to
U.
S.
situations
are
needed.
Exposure
is
based
upon
manufacturing,
processing,
and
use
scenarios,
all
of
which
change
over
time
as
technology
and
other
societal
effects
change.
The
changing
nature
of
exposure
scenarios
means
the
potential
risks
associated
with
a
chemical
can
also
change,
and
therefore
the
collection
of
exposure­
related
information
over
time
is
fundamental
to
identifying
potential
risks.
(
See
68
FR
848,
852
for
further
discussion)

3
For
additional
information
on
uses
of
IUR
processing
and
use
information,
see
IURA
Data
Use
Plan,
located
in
EPA's
electronic
docket
OPPT­
2002­
0054,
item
number
0261.

4
The
OECD
HPV
SIDS
program,
while
it
is
not
United
States
based,
is
a
program
where
different
countries
are
combining
their
resources
to
investigate
at
least
the
hazards
associated
with
different
chemicals.
This
allows
all
of
the
countries
to
benefit
from
this
information.
The
United
States
can
use
information
collected
during
and
generated
by
the
OECD
HPV
SIDS
program
to
address
domestic
issues.

Page
3
of
7
Consideration
C:
The
information
needs
of
EPA,
other
federal
agencies,
tribes,
states,
and
local
governments,
as
well
as
members
of
the
public.

The
petition
review
group
found
that
this
chemical
is
part
of
EPA's
HPV
Challenge
Program.
The
HPV
Challenge
Program
seeks
to
collect
and,
where
necessary,
develop
a
screening­
level
hazard
data
set
for
chemicals
produced
or
imported
in
large
quantities
in
the
United
States.
EPA
plans
to
screen
and,
as
needed,
further
assess
chemicals
included
under
the
HPV
Challenge
Program.
For
this
purpose,
the
IUR
processing
and
use
information
is
needed
by
EPA
to
put
the
hazard
data
into
context,
complementing
the
HPV
Challenge
Program
submission
by
providing
EPA
with
exposure­
related
information.
2
The
reporting
of
IUR
processing
and
use
information
is
needed
at
least
once
and,
potentially,
periodically
thereafter
to
more
accurately
and
realistically
gauge
potential
exposure
and
provide
information
needed
for
screening,
assessing,
and
managing
exposures
and
risk.
Other
important
uses
of
the
reported
information,
even
for
low­
hazard
chemicals,
may
include
comparative
exposure
analyses,
identification
of
safer
substitutes,
or
pollution
prevention
investigations.
3
Consideration
D:
The
availability
of
other
complementary
risk
screening
information.

The
petitions
referred
EPA
to
the
OECD
HPV
SIDS
review
documents
of
2­
propenoic
acid,
2­
methylpropyl
ester
(
CASRN
106­
63­
8),
but
did
not
identify
specific
information
within
those
documents
that
would
address
Consideration
D.
The
results
of
the
OECD
HPV
SIDS
review,
as
documented
in
the
SIAP,
indicate
that
this
chemical
is
currently
a
low
priority
for
further
work
because
exposure
to
humans
and
the
environment
is
anticipated
to
be
low,
but,
as
this
chemical
possesses
properties
indicating
a
hazard
for
human
health
and
the
environment,
countries
"
may
desire
to
investigate
any
exposure
scenarios
that
were
not
presented
by
the
Sponsor
country."
With
the
collection
of
IUR
processing
and
use
data
for
this
chemical,
the
United
States
will
be
able
to
identify
domestic
situations
by
combining
the
OECD
HPV
SIDS
program
hazard
data4
with
the
IUR
exposure­
related
information,
thereby
identifying
new
or
revised
exposure
scenarios.
These
new
or
revised
scenarios
will
likely
have
differing
potential
risk
screening
results
than
the
previous
scenarios
and
will
be
specific
to
situations
in
the
United
States.
See
Consideration
E
below
for
further
discussion
of
the
IUR
exposure­
related
processing
and
use
information.
Page
4
of
7
Consideration
E:
The
availability
of
comparable
processing
and
use
information.

The
petition
referred
EPA
to
the
OECD
HPV
SIDS
review
documents
for
this
chemical,
but
did
not
identify
specific
information
within
those
documents
that
addresses
Consideration
E.
The
SIAP
for
this
chemical
(
dated
October
2002)
contains
some
general
information
on
uses
and
worldwide
annual
production
quantity,
and
states
that
this
chemical
is
used
as
a
co­
monomer
in
the
manufacture
of
polymers.
The
polymers
are
then
used
for
applications
such
as
surface
coatings,
in
films
and
pressure
sensitive
adhesives,
in
dispersions,
and
construction
materials.
The
SIAP
also
indicates
that
exposure
may
occur
during
manufacture,
transportation
and
industrial
use,
but
that
worker
exposure
is
adequately
controlled
at
production
plants
in
the
United
States
and
that
as
a
result
of
polymerization,
end­
use
products
contain
only
trace
amounts
of
2­
propenoic
acid,
2­
methylpropyl
ester
(
CASRN
106­
63­
8).

The
conclusion
expressed
in
the
SIAP
indicated
that
countries
"
may
desire
to
investigate
any
exposure
scenarios
that
were
not
presented
by
the
Sponsor
country."
Although
the
U.
S.
was
one
of
the
sponsors
of
the
OECD
HPV
SIDS
program
evaluation,
the
petition
review
group
recognizes
that
since
exposure
scenarios
change
based
on
uses
and
available
technology,
information
quickly
becomes
outdated
and
of
limited
use.
Because
of
this,
the
relative
importance
of
each
use
may
change
or
new
uses
may
develop.
EPA
believes
tracking
these
changes
is
important,
especially
since
the
SIAP
indicated
that
this
chemical
"
possesses
properties
indicating
a
hazard
for
human
health
and
the
environment."
Since
the
collection
occurs
on
a
regular
basis,
the
IUR
facilitates
tracking
changes
in
use
patterns
and
the
identification
of
new
exposure
scenarios,
which
is
an
important
component
of
risk
screening.

Additionally,
the
IUR
contains
some
exposure­
related
data
elements
not
provided
in
the
OECD
HPV
SIDS
submission,
such
as
data
on
the
function
of
the
chemical
in
the
industrial
processing
and
use
category,
the
NAICS
code
associated
with
the
use,
and
the
number
of
potentially
exposed
workers
and
the
number
of
sites
associated
with
each
use.
For
commercial
and
consumer
uses,
the
IUR
collects
data
on
the
amount
of
the
chemical
in
various
use
categories,
the
concentration
of
the
chemical
in
the
use
category,
and
the
likelihood
of
inclusion
in
products
intended
for
children.
Furthermore,
IUR
information
is
updated
every
four
years,
is
quantitative,
and
is
specific
to
the
United
States.

Consideration
F:
Whether
the
potential
risks
for
the
chemical
substance
are
adequately
managed
by
EPA
or
another
agency
or
authority.

The
petitions
did
not
identify
or
discuss
any
risk
management
actions
taken
by
EPA
or
another
agency
or
authority
with
respect
to
the
petitioned
chemical.
The
petitions
did
not
explain
why
the
downstream
processing
and
use
information
should
be
of
low
current
interest
in
light
of
any
such
risk
management
actions.
Page
5
of
7
Other
Considerations/
Notes:

The
October
2002
SIAP
for
2­
propenoic
acid,
2­
methylpropyl
ester
(
CASRN
106­
63­
8)
noted
a
conclusion
of
"
low
priority
for
further
work"
under
the
OECD
HPV
SIDS
program
since
exposure
to
humans
and
the
environment
is
anticipated
to
be
low,
but
also
noted
that
the
chemical
"
possesses
properties
indicating
a
hazard
for
human
health
and
the
environment."
A
designation
of
low
priority
for
further
work
within
the
OECD
HPV
SIDS
program
means
that
no
further
hazard
testing
is
needed
to
meet
the
purposes
of
the
OECD
HPV
SIDS
program
at
the
time
the
review
was
completed.
These
judgements,
however,
do
not
determine
the
approach
that
an
individual
OECD
member
country
must
take
in
considering
such
a
chemical.
Rather,
the
OECD
HPV
SIDS
program
assessment
is
seen
as
a
starting
point
for
assessment
in
countries.
In
the
U.
S.
case,
it
is
a
starting
point
for
a
screening­
level
risk
assessment,
for
which
IUR
processing
and
use
information
provides
screening­
level
exposure
information.
In
the
past
there
have
been
a
number
of
chemicals
identified
by
the
OECD
HPV
SIDS
program
as
a
"
low
priority
for
further
work,"
but
for
which
EPA
wanted
to
make
a
confirmatory
priority
judgement
based
on
risk
 
i.
e.,
screeninglevel
hazard
information
based
on
the
OECD
HPV
SIDS
program
work
plus
screening­
level
exposure
information
based
on
the
U.
S.
situation.

Cited
Reference:
1)
SIAP
for
2­
propenoic
acid,
2­
methylpropyl
ester
(
CASRN
106­
63­
8).
October
2002.
Available
on
the
web
at
http://
cs­
3­
hq.
oecd.
org/
scripts/
hpv/
NewSIDS.
asp
Sources
Searched:
(
Note:
These
sources
are
typically
searched
or
reviewed
to
gather
information
presented
in
the
petition
review
report.)

American
Conference
of
Governmental
Industrial
Hygienists
(
ACGIH)
Threshold
Limit
Values
(
TLV­
TWA).
2003.
ACGIH,
Cincinnati
OH.
pp.
12­
61.

Agency
for
Toxic
Substances
and
Disease
Registry
(
ATSDR)
ToxFAQsTM
(
Frequently
asked
questions
about
contaminants
found
at
hazardous
waste
sites).
Available
at
http://
www.
atsdr.
cdc.
gov/
toxfaq.
html
California
Air
Resources
Board
List
of
Toxic
Air
Contaminant
Fact
Sheets,
available
at
http://
arbis.
arb.
ca.
gov/
toxics/
tac/
toctbl.
htm
California
EPA,
Safe
Drinking
Water
and
Toxic
Enforcement
Act
of
1986:
List
of
chemicals
known
to
the
State
to
cause
cancer
or
reproductive
toxicity.
Listing
as
of
Nov.
14,
2003.
Available
at
http://
www.
oehha.
ca.
gov/
prop65/
CRNR_
notices/
list_
changes/
111403lsta.
html
International
Agency
of
Research
on
Cancer
(
IARC)
Overall
Evaluations
of
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National
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United
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U.
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U.
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High
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VCCEP)
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ACGIH
American
Conference
of
Governmental
Industrial
Hygienists
AEGL
Acute
Exposure
Guideline
Level
ARB
Air
Resources
Board
ATSDR
Agency
for
Toxic
Substances
and
Disease
Registry
CAA
Clean
Air
Act
CASRN
Chemical
Abstract
Service
Registry
Number
CICAD
Concise
International
Chemical
Assessment
Document
CPSC
Consumer
Product
Safety
Commission
EHC
Environmental
Health
Criteria
EPA
Environmental
Protection
Agency
EU
European
Union
FDA
Food
and
Drug
Administration
FFDCA
Federal
Food,
Drug,
and
Cosmetic
Act
FIFRA
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
GRAS
Generally
Recognized
as
Safe
HAP
Hazardous
Air
Pollutant
HPV
High
Production
Volume
HSDB
Hazardous
Substances
Databank
IARC
International
Agency
of
Research
on
Cancer
ICCA
International
Council
of
Chemical
Associations
IFCS
International
Forum
on
Chemical
Safety
IPCS
International
Programme
on
Chemical
Safety
IRIS
Integrated
Risk
Information
System
IRPTC
International
Register
of
Potentially
Toxic
Chemicals
ITC
Interagency
Testing
Committee
IUCLID
International
Uniform
Chemical
Information
Database
IUR
Inventory
Update
Reporting
Rule
IURA
Inventory
Update
Reporting
Rule
Amendment
NAICS
North
American
Industry
Classification
System
NIOSH
National
Institute
for
Occupational
Safety
and
Health
OECD
Organisation
for
Economic
Cooperation
and
Development
OECD
HPV
SIDS
or
OECD
HPV
SIDS
program
OECD/
SIDS
HPV
Chemicals
Programme
OPP
Office
of
Pesticide
Programs
OPPT
Office
of
Pollution
Prevention
and
Toxics
OSHA
Occupational
Safety
and
Health
Administration
PEL
Permissible
Exposure
Limit
POP
Persistent
Organic
Pollutant
SIAM
SIDS
Initial
Assessment
Meeting
SIAP
SIDS
Initial
Assessment
Profile
SIAR
SIDS
Initial
Assessment
Report
SIDS
Screening
Information
Data
Set
SRS
Substance
Registry
System
TLV­
TWA
Threshold
Limit
Value
Time­
Weighted
Average
TRI
Toxics
Release
Inventory
TSCA
Toxic
Substances
Control
Act
UNEP
United
Nations
Environment
Programme
VCCEP
Voluntary
Children's
Chemical
Evaluation
Program
