Page
1
of
6
IUR
Petition
Review
Report
April
25,
2005
CASRNs
and
TSCA
Inventory
Chemical
Names:
96­
10­
6
aluminum,
chlorodiethyl­
97­
93­
8
aluminum,
triethyl­
100­
99­
2
aluminum,
tris(
2­
methylpropyl)­
563­
43­
9
aluminum,
dichloroethyl­
1070­
00­
4
aluminum,
trioctyl­
1116­
70­
7
aluminum,
tributyl­
1116­
73­
0
aluminum,
trihexyl­
1191­
15­
7
aluminum,
hydrobis(
2­
methylpropyl)­
12075­
68­
2
aluminum,
di­.
mu.­
chlorochlorotriethyldi­
12542­
85­
7
aluminum,
trichlorotrimethyldi­

Petitioner
and
Petition
Docket
Number:
Albemarle
Corporation
OPPT­
2004­
0048
Note:
This
petition
contained
additional
chemicals.
These
additional
chemicals
are
addressed
in
other
petition
review
reports.

Summary
of
Decision:
The
petition
review
group
recommends
a
grant
for
this
petition
as
EPA
has,
at
this
time,
a
low
current
interest
in
the
processing
and
use
information
collected
under
the
Inventory
Update
Reporting
(
IUR)
rule
(
see
40
CFR
Part
710)
for
the
ten
substances
listed
above.
This
recommendation
is
based
primarily
on
Considerations
B,
C,
and
E.
The
reporting
of
manufacturing
information
will
continue
to
be
required
for
these
substances.

A
Federal
Register
(
FR)
direct
final
rulemaking
to
add
these
chemicals
to
the
partial
exemption
will
be
published.
The
final
listing
decision
is
pending,
based
on
responses
to
the
FR
notice.
Additionally,
if
the
level
of
interest
changes,
EPA
will
reevaluate
the
IUR
reporting
status
of
these
chemicals.

Please
note
that
IUR
submitters
can
still
report
processing
and
use
information
even
if
a
chemical
is
partially
exempt,
so
their
chemicals
can
be
considered
for
safer
substitute
analyses.

Background:
EPA
received
a
petition
requesting
that
the
ten
chemicals
listed
above
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
Page
2
of
6
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
this
petition
and
an
analysis
of
how
those
considerations
relate
to
the
chemicals
identified
in
this
petition
are
set
forth
below.

Discussion:
The
petition
review
group
considered
information
submitted
with
the
petition,
as
well
as
other
information
including
(
but
not
limited
to):
whether
the
petition
substances
are
included
in
TRI,
IRIS,
or
IARC;
OECD
HPV
SIDS
program
status;
HPV
Challenge
Program
status;
and
their
inclusion
in
other
regulatory
programs
administered
by
EPA.
1
The
petition
stated
that
all
of
these
substances
are
pyrophoric
when
shipped
neat
or
in
high
concentration
solutions
and
that
when
solutions
are
dilute
enough
that
the
mixture
is
no
longer
pyrophoric,
the
aluminum
alkyl
solutions
are
still
air­
and
water­
reactive.
For
these
reasons,
the
petition
states,
aluminum
alkyls
and
solutions
containing
aluminum
alkyls
are
shipped
in
airtight
pressure
vessels
where
there
is
no
possibility
of
exposure
or
release.
Furthermore,
the
petition
indicated
that
during
or
after
use
the
original
aluminum
alkyl
no
longer
exists
as
itself
and,
therefore,
EPA
would
obtain
no
additional
information
from
the
reporting
of
processing
and
use
information
for
these
chemicals.
The
highly
reactive
nature
of
these
substances
was
further
described
in
a
subsequent
letter
from
the
petitioner.

Consideration
A:
Production
volume.

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

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

The
petition
indicated
that
these
aluminum
alkyl
substances
are
pyrophoric
as
well
as
highly
water­
and
air­
reactive,
and
that
during
or
after
use,
the
original
aluminum
alkyl
substance
no
longer
exists
as
itself.
The
petition
review
group
reviewed
the
HPV
Challenge
Program
submission
for
aluminum
alkyls,
which
contains
eight
of
these
ten
aluminum
alkyl
substances.
This
HPV
Challenge
Program
submission
stated
the
following:

"
Reactions
of
these
substances
are
explosive...
the
trialkyl
aluminums
are
highly
reactive
towards
oxidizing
agents
including
molecular
oxygen,
thus,
the
fast
reactions
in
air....
Reactions
with
oxygen
(
air)
are
vigorous
and
will
generally
cause
the
material
to
ignite
resulting
in
a
fire
that
is
difficult
to
extinguish.
Often,
the
recommended
fire
fighting
practice
is
simply
to
let
the
material
burn
itself
to
extinction.
Reactions
with
water
are
even
more
violent
than
those
with
oxygen.
The
reaction
with
water
creates
flammable
1
See
the
attached
list
of
acronyms
at
the
end
of
this
report.
Page
3
of
6
gases
that
are
easily
ignited
by
the
fire
already
created
by
the
organoaluminum
compound
with
water.
For
this
reason,
water
is
generally
not
recommended
for
use
in
fighting
aluminum
alkyl
fires....
Because
of
the
strong
reactivity
of
the
aluminum
alkyls,
these
compounds
are
expected
to
cause
thermal
burns
to
eye
and
skin
and
inhalation
may
cause
metal
fume
fever .
These
chemicals
are
required
to
be
labeled
as
spontaneously
combustible,
water
reactive
and
flammable."
(
Ref.
1)

The
petition
review
group
has
determined
that,
at
this
time,
the
reporting
of
IUR
processing
and
use
information
is
not
needed
for
these
substances,
based
on
the
following:
the
reaction
of
these
pyrophoric
substances
upon
contact
with
air
or
water
is
very
fast;
the
nature
of
the
reaction
is
readily
observable
(
i.
e.,
flames);
and
the
reaction
results
in
a
transformation
of
the
aluminum
alkyl
into
another
chemical
substance
once
exposed
to
water
or
air.
Due
to
the
highly
reactive
and
pyrophoric
nature
of
these
substances,
strict
precautions
that
minimize
the
potential
for
exposure
and
release
need
to
be
taken
during
their
manufacture
and
processing.

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

The
petition
did
not
provide
specific
information
that
pertained
to
Consideration
C.
However,
eight
of
these
chemicals
are
part
of
the
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.
Typically,
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.
However,
for
these
aluminum
alkyls,
the
petition
review
group
has
determined
that
there
is
currently
a
low
need
for
the
reporting
of
IUR
processing
and
use
information
because
exposure
to
these
substances
is
not
expected
to
occur
based
on
their
high
and
apparent
reactivities,
and
based
on
the
fact
that
these
aluminum
alkyls
are
shipped
in
air­
tight
containers
to
eliminate
the
possibility
of
exposure
or
release
(
indicated
in
the
petition).
Additionally,
EPA's
response
to
the
sponsor
of
the
aluminum
alkyls
HPV
Challenge
Program
category
submission
stated
that
"
owing
to
the
highly
reactive
nature
of
these
chemicals
when
in
contact
with
air
or
water,
it
is
not
feasible
to
perform
environmental
fate,
mammalian
or
ecotoxicological
tests
on
such
a
reactive
category
of
chemicals"
(
Ref.
2).

Consideration
D:
The
availability
of
other
complementary
risk
screening
information.

The
petition
did
not
provide
specific
information
that
pertained
to
Consideration
D.
Some
hazard
data
are
available
for
the
eight
aluminum
alkyl
substances
that
are
included
in
the
HPV
Challenge
Program;
however,
for
reasons
discussed
under
Considerations
B
and
C
(
i.
e.,
the
highly
reactive
nature
of
these
substances
and
the
limited
exposure
potential),
the
petition
review
group
has
determined
that
the
availability
of
other
risk
screening
information
on
these
substances
has
little
bearing
on
a
decision
to
grant
or
deny
this
petition.
Page
4
of
6
Consideration
E:
The
availability
of
comparable
processing
and
use
information.

The
petition
indicated
that
aluminum
alkyls
are
used
as
catalysts
in
the
production
of
polymers
and
that
during
or
after
use,
the
original
aluminum
alkyl
no
longer
exists
as
itself.
For
these
reasons,
the
petition
states,
EPA
would
obtain
no
additional
information
from
reporting
of
processing
and
use
information
on
these
chemicals.
Furthermore,
the
petition
review
group
found
that
the
HPV
Challenge
Program
submission
for
the
aluminum
alkyls
category
stated
that
"
Aluminum
alkyls
are
highly
reactive
materials
that
are
used
in
a
variety
of
industrial
chemical
processes
such
as
polymerization,
oligomerization,
alkylation,
and
stereochemical
synthesis."
Because
of
the
limited
use
of
these
substances
as
intermediates
in
chemical
synthesis
and
because
of
their
highly
reactive
nature
(
described
in
Considerations
B
and
C
above),
EPA
believes
that,
at
this
time,
collecting
additional
IUR
processing
and
use
information
on
these
chemicals
would
not
likely
further
our
understanding
of
potential
risks
of
this
chemical.
Additionally,
the
IUR
information
does
not
provide
geographic
locations
for
the
uses
of
this
chemical,
which
is
information
that
may
be
useful
in
accidental
exposures.

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

The
petition
did
not
identify
or
discuss
any
risk
management
actions
taken
by
EPA
or
another
agency
or
authority
with
respect
to
the
petitioned
chemicals.

Cited
References:
1)
HPV
Challenge
Program
submission
for
the
aluminum
alkyls
category.
Dated
2001.
Available
at
http://
www.
epa.
gov/
chemrtk/
alalkyls/
c12977tc.
htm
2)
EPA's
comments
on
the
aluminum
alkyls
category
HPV
Challenge
submission.
Dated
Feb
2002.
Available
at
http://
www.
epa.
gov/
chemrtk/
alalkyls/
c12977ct.
htm
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
Carcinogenicity
to
Humans.
Available
at
http://
monographs.
iarc.
fr/
monoeval/
crthall.
html
Interagency
Testing
Committee
(
ITC)
Priority
Testing
List.
Available
at
http://
tsca­
itc.
syrres.
com/
Chemicals/

National
Advisory
Committee
Acute
Exposure
Guideline
Levels
(
AEGLs).
Available
at
http://
www.
epa.
gov/
oppt/
aegl/
index.
htm
Page
5
of
6
Organisation
for
Economic
Cooperation
and
Development
(
OECD)
Integrated
HPV
Database,
http://
cs3­
hq.
oecd.
org/
scripts/
hpv/
index.
asp
United
Nations
Environment
Programme
(
UNEP)
persistent
organic
pollutants
(
POPs),
available
at
http://
www.
chem.
unep.
ch/
pops/
default.
html
United
Nations
Environment
Programme
(
UNEP)
Ozone
Secretariat,
Summary
Control
Measures,
available
at
http://
www.
unep.
org/
ozone/
Treaties_
and_
Ratification/
2B_
montreal_
protocol.
asp
U.
S.
EPA
Clean
Air
Act
(
CAA)
Hazardous
Air
Pollutants
(
HAPs).
Available
in
the
Clean
Air
Act,
section
112(
b),
available
at
http://
www.
epa.
gov/
air/
caa/
caa112.
txt
U.
S.
EPA.
Emergency
Planning
and
Community
Right­
to­
Know
Act
Section
313,
List
of
Toxic
Chemicals.
2001.
Office
of
Environmental
Information,
EPA
260­
B­
01­
001,
available
at
http://
www.
epa.
gov/
tri/
chemical/
chemlist2001.
pdf
U.
S.
EPA
HPV
(
High
Production
Volume)
Challenge
Program
and
Voluntary
Children's
Chemical
Evaluation
Program
(
VCCEP)
Web
sites
under
the
EPA
Chemical
Right­
to­
Know
Initiative,
http://
www.
epa.
gov/
chemrtk
U.
S.
EPA
Integrated
Risk
Information
System
(
IRIS)
Substance
List.
Available
at
http://
www.
epa.
gov/
iris/
subst/
index.
html
U.
S.
EPA.
National
Recommended
Water
Quality
Criteria:
2002.
Office
of
Water.
EPA­
822­
R­
02­
047.
Available
at
http://
www.
epa.
gov/
waterscience/
pc/
revcom.
pdf
U.
S.
EPA.
2004
Edition
of
the
Drinking
Water
Standards
and
Health
Advisories.
Office
of
Water.
EPA­
822­
R­
04­
005.
Available
at
http://
www.
epa.
gov/
waterscience/
drinking/
standards/
dwstandards.
pdf
U.
S.
EPA
Substance
Registry
System
(
SRS).
Available
at
http://
www.
epa.
gov/
srs/

U.
S.
Occupational
Safety
and
Health
Administration
(
OSHA)
Permissible
Exposure
Limits
(
PELs),
available
at
http://
www.
osha.
gov/
SLTC/
pel/
index.
html
Page
6
of
6
List
of
Acronyms
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
