  SEQ CHAPTER \h \r 1 Testing of Certain High Production Volume
Chemicals; Second Group of Chemicals

(Exposure Findings Supporting Information)

U.S. Environmental Protection Agency 

Office of Pollution Prevention and Toxics 

Economics, Exposure and Technology Division 

July 2008Table of Contents

PREFACE

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc175984749"  1.0	Data Source
Descriptions	  PAGEREF _Toc175984749 \h  3  

  HYPERLINK \l "_Toc175984750"  2.0	Summary of HPV2 Chemicals and
Findings	  PAGEREF _Toc175984750 \h  4  

  HYPERLINK \l "_Toc175984751"  Attachment A - NLM Printouts	A-1 

  HYPERLINK \l "_Toc175984753"  Attachment B – NOES Printouts	B-2 

  HYPERLINK \l "_Toc175984755"  Attachment C – TRI Printout	C-3 

 Preface

	This findings document was prepared to support EPA’s Proposed TSCA
Section 4 Test Rule for Certain High Production Volume Chemicals; Second
Group of Chemicals.  Prior to promulgating a test rule under section 4
of the Toxic Substances Control Act (TSCA), 15 U.S.C. §§2601 et seq,
EPA is required to make certain findings identified in section 4(a) of
TSCA relating to the chemical’s risk and potential exposure, the
sufficiency of data to allow EPA to determine the human health or
environmental effects of the chemical, and the need to conduct testing.

 

	Under TSCA section 4(a)(1)(B), EPA must make the following findings to
support a test rule based on concerns for exposure: (1) that a chemical
substance is or will be produced in substantial quantities and that it
enters or may reasonably be anticipated to enter the environment in
substantial quantities and/or that there is or may be substantial and/or
significant human exposure to such substance; (2) that there are
insufficient data and experience upon which the effects of the
manufacture, distribution in commerce, processing, use or disposal of
such substance or mixture or of any combination of such activities on
health or the environment can reasonably be determined or predicted; and
(3) that testing of the substance or mixture with respect to such
effects is necessary to develop such data.  The criteria and standards
used by EPA for evaluating the terms “substantial production,”
“substantial release,” and “substantial or significant human
exposure” as used in TSCA section 4(a)(1)(B)(i) are explained in
EPA’s Final Statement of Policy; Criteria for Evaluating Substantial
Production, Substantial Release, and Substantial or Significant Human
Exposure set forth at 58 FR 28736 (May 14, 1993) (hereinafter referred
to as the “B Policy”).

	This document provides a detailed discussion of EPA’s evaluation of
each of the chemical substances identified in the proposed test rule to
determine that preliminary TSCA section 4(a)(1)(B) findings concerning
“substantial production,” “substantial release,” and
“substantial or significant human exposure” can be made. Data
Source Descriptions

TSCA Inventory Update Reporting Rule: In 1986, EPA promulgated the
Inventory Update Reporting (IUR) regulations, under TSCA section 8(a),
to facilitate the periodic updating of the TSCA Inventory database and
to otherwise support activities associated with implementing TSCA. As
originally promulgated, the IUR required chemical manufacturers
(including importers) to report to EPA every 4 years the identity of
chemical substances manufactured (including imported) annually in
quantities of 10,000 pounds or more at each plant site they owned or
controlled. In 2003 EPA adjusted the universe of chemicals and plant
sites that are required to report, and the type of information reported.
In 2005, EPA changed the reporting frequency to once every 5 years,
revised the manner in which amounts of a chemical substance manufactured
or imported must be reported, and changed the submission period for
reporting after 2006.

To protect the claims of confidential business information (CBI)
asserted by some IUR submitters on the amount of the chemical substance
manufactured (including imported) at a specific site, all production
volumes reported by IUR submitters (i.e., CBI and non-CBI) for each
chemical are combined by EPA for an aggregate total.  Confidential
business information claims are further protected by using eight ranges
to identify the total for any specific chemical and then making
available to the public the range that corresponds to the aggregate
production volume. Publicly-available information from the 1986, 1990,
1994, 1998, and 2002 (and 2006) IUR reporting cycles are available
on-line at:   HYPERLINK http://www.epa.gov/oppt/iur/index.htm
http://www.epa.gov/oppt/iur/index.htm 

The Toxics Release Inventory (TRI) contains information about releases
of certain chemicals and management of wastes at a wide variety of
sources, including manufacturing operations, certain service businesses,
and federal facilities.  Publicly-available information from the 2005
TRI reporting cycle is available on-line at:   HYPERLINK
http://www.epa.gov/triexplorer/ http://www.epa.gov/triexplorer/ 

The National Institute for Occupational Safety and Health (NIOSH)
conducted the National Occupational Exposure Survey (NOES) that
collected data on potential occupational exposures to chemical,
physical, and biological agents from 1981 to 1983.  The survey involved
on-site visits to 4,490 establishments in 522 industry types employing
approximately 1,800,000 workers in 377 occupational categories. 
Publicly-available information from the NOES is available on-line at:  
HYPERLINK http://www.cdc.gov/noes/default.html
http://www.cdc.gov/noes/default.html 

The National Library of Medicine Household Products Database provides
information on the chemical ingredients and their percentage in specific
brands of household products.  Information in the database is from a
variety of publicly available sources including brand-specific labels
and Material Safety Data Sheets when available from manufacturers and
manufacturers' web sites.  Publicly-available information from the
database is available on-line at:   HYPERLINK
http://householdproducts.nlm.nih.gov/
http://householdproducts.nlm.nih.gov/ 

Summary of HPV2 Chemicals and Findings

	Table 2-1 below presents a summary of the high production volume (HPV)
chemicals and data collected to support an exposure-based finding. Table
2-2 presents a chemical-by-chemical explanation of the supporting
findings information.

Table 2-1

Summary of Data Searched for Exposure Based Findings

CAS#	Chemical Name	

IUR Number of Workers Information 	NOES	NLM Household Chemicals Database
2005 TRI Data(Total On- and Off-site Disposal or Other Releases, lbs)
2006 IUR Production Volume

[Million lbs]	

Meet Exposure Based Criteria

For Workers	Meet Exposure Based Criteria for Consumers	

Meet Exposure Based Criteria for Release	Non-CBI Commercial/ Consumer
Code Description

75-07-0	

Acetaldehyde	

> 1,000	

216,533	

3 hobby/craft glues; 1 home maintenance product	

13,567,452	

> 100 - 500	

Yes	

Yes	

Yes

	78-11-5	1,3-Propanediol, 2,2-bis[(nitrooxy)methyl]-, dinitrate (ester)	

> 1,000	2,650	no	 	

> 1   - 10	Yes	Yes

C20 - Other

84-65-1	9,10-Anthracenedione	

> 1,000	6,187	no	 	> 10 - 50	Yes	Yes

C13-Paper Products

89-32-7	1H,3H-Benzo[1,2-c:4,5-c']difuran-1,3,5,7-tetrone	

> 1,000	1,926	no	 	

> 1   - 10	Yes



	110-44-1	2,4-Hexadienoic acid, (E,E)-	

> 1,000	69,243	yes, 13 personal care products	 	

> 1   - 10	Yes	Yes

C16-Rubber & Plastic Products, C20-Other

118-82-1	Phenol, 4,4'-methylenebis[2,6-bis(1,1-dimethylethyl)-	

> 1,000	120,009	no	 	

> 1   - 10	Yes	Yes

C10-Lubricants, Greases & Fuel Additives

119-61-9	Methanone, diphenyl-	

> 1,000	41,516	5 personal care products; 1 auto product	 	

> 1   - 10	Yes	Yes

C05-Electtrical & Electronic Products, C12-Paints & Coatings,C13-Paper
Products, C20 - Other

144-62-7	Ethanedioic acid	

> 1,000	142,000	4 auto products; 1 brass polish; 1 cleanser; 2 wood
brighteners; 1 bathroom cleanser	 	

> 1   - 10	Yes	Yes	

     Yes	C06-Fabrics, Textiles, & Apparel, C07-Glass & Ceramic
Products,C13-Paper Products, C15-Polishes & Sanitation Goods, C17-Soaps
& Detergents, C20-Other

149-44-0	Methanesulfunic acid, hydroxyl-, monosodium salt	

> 1,000	239,465	no



> 1   - 10	Yes	Yes

C01-Adhesives & Sealants, C16-Rubber & Plastics Goods

2524-04-1	Phosphorochloridothioic acid, O,O-diethyl ester	

> 1,000	1,088	no	 	

> 10 - 50	Yes



	4719-04-4	1,3,5-Triazine-1,3,5(2H,4H,6H)-triethanol	

> 1,000	225,251	yes, 7 reported uses of Grotan BK (a disinfectant) in 4
laundry detergents, 1 dishwashing detergent, 1 all purpose cleaner, and
1 glass & surface cleaner	 	> 10 - 50	Yes	Yes	

Yes	C20-Other

6381-77-7	D-erythro-Hex-2-enonic acid, .gamma.-lactone, monosodium salt	

> 1,000	19,468	no	 	

> 1   - 10	Yes



	31138-65-5	D-gluco-Heptonic acid, monosodium salt, (2.xi.)-	

> 1,000	74,165	no	 	

> 1   - 10	Yes	Yes

CBI

66241-11-0	C.I. Leuco Sulphur Black 1	

> 1,000	38,555	no	 	> 1   - 10	Yes	Yes

C06-Fabrics, Textiles & Apparel

68187-76-8	Castor oil, sulfated, sodium salt	

> 1,000	11,164	no	 	

> 1   - 10	Yes	Yes

C17-Soaps & Detergents

68187-84-8	Castor oil, oxidized	

> 1,000	36,381	1 auto product; 1 oil-based primer/sealer; 14 personal
care products; 1 insect repellent	 	> 1   - 10	Yes	Yes

C20-Other

68479-98-1	Benzenediamine, ar,ar-diethyl-ar-methyl-	

> 1,000	4,121	no	 	

> 10 - 50	Yes



	68527-02-6	Alkenes, C12-24, chloro	

> 1,000	84,192	no	 	> 1   - 10	Yes



	68647-60-9	Hydrocarbons, C>4	

> 1,000	1,257	no	 	> 1Billion lbs	Yes



	Table 2-2

Chemical-by-Chemical Explanation of Findings 

CAS#	Chemical Name	Summary of Findings

75-07-0	Acetaldehyde

	This chemical reports >1 million lb release to TRI.  The total number
of potentially exposed workers exceeds 1,000 based on reported IUR data.
This chemical exceeds 1,000 workers based on NOES data.   Additionally,
the number of potentially exposed consumers is estimated to be very
large based on the uses (hobby/craft glues; home maintenance product)
cited in the NLM Household Chemicals Database.  It is expected that
hobby or craft glues and home maintenance products will be widely used
by consumers (including children) and hence, may likely exceed 10,000
people.  Based on this information, this chemical would meet the
exposure based findings criteria of "substantial or significant human
exposure.”  The production volume data for the 2006 IUR data
collection was compared to the production volume data for the 1986 IUR
data collection for this chemical to see if the production volume stayed
the same or increased, thereby indicating that the usage of these
chemicals is no less than when NOES data were gathered. The 1986
reported IUR production volume range was 500 million -1 billion lbs. The
2006 IUR production volume range is 100 million – 500 million lbs.

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (100 million -500 million lb)

- Substantial Release (Greater than 13.5  million lb reported to TRI)

- Total workers exceeding 1,000 based on IUR data

- Total workers exceeding 1,000 based on NOES data (217,000 workers) 

- Consumers potentially exceeding 10,000 people.

78-11-5	1,3-Propanediol,2,2-bis[(nitrooxy)methyl],dinitrate (ester)

	The total number of potentially exposed workers exceeds 1,000 workers
based on NOES data. Additionally, the IUR commercial/consumer product
category C20-Other (chemicals contained in commercial and consumer
products not elsewhere classified) was reported for this chemical. This
indicates that this chemical is present in an unknown number of
commercial and consumer products that may potentially have a high number
of exposures. Based on this information, this chemical would meet the
exposure based findings criteria of "substantial or significant human
exposure.” The production volume data for the 2006 IUR data collection
was compared to the production volume data for the 1986 IUR data
collection for this chemical to see if the production volume stayed the
same or increased, thereby indicating that the usage of these chemicals
is no less than when NOES data were gathered.  The 1986 reported IUR
production volume range was 1 million -10 million lbs. The 2006 IUR
production volume range is 1 million -10 million lbs. (All stated IUR 
commercial/consumer product categories are non-CBI)

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (1 million -10 million lb)

- Total workers exceeding 1,000 based NOES data 

  (2,650 workers)



84-65-1	9,10-Anthracenedione

	The total number of potentially exposed workers is likely to exceed
1,000 based on reported IUR data.   The number of potentially exposed
total workers exceeds 1,000 based on NOES data.  Additionally, the
number of potentially exposed consumers is estimated to be very large
based on the reported IUR commercial/consumer product category for this
chemical (C13 – paper products). Chemicals reporting in this category
are contained in commercial and consumer paper products. It is expected
that paper products will be widely used by commercial workers and
consumers (including children) and hence, may likely exceed 1,000
commercial workers and 10,000 consumers.  Based on this information,
this chemical would meet the exposure based findings criteria of
"substantial or significant human exposure.”  The production volume
data for the 2006 IUR data collection was compared to the production
volume data for the 1986 IUR data collection for this chemical to see if
the production volume stayed the same or increased, thereby indicating
that the usage of these chemicals is no less than when NOES data were
gathered.  The 1986 reported IUR production volume range was 500
thousand – 1 million lbs. The 2006 IUR production volume range is 10
million – 50 million lbs. (All stated IUR  commercial/consumer product
categories are non-CBI)

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (10 million -50 million lb)

- Total workers exceeding 1,000 based NOES data  (6,187 workers)

 - Total workers potentially exceeding 1,000 based on  IUR
commercial/consumer product category (C13) 

- Consumers potentially exceeding 10,000 people.

89-32-7	1H,3H-Benzo[1,2-c:4,5-c']difuran-1,3,5,7-tetrone

	The total number of potentially exposed workers exceeds 1,000 based on
NOES data.  Based on this information, this chemical would meet the
exposure based findings criteria of "substantial or significant human
exposure.” The production volume data for the 2006 IUR data collection
was compared to the production volume data for the 1986 IUR data
collection for this chemical to see if the production volume stayed the
same or increased, thereby indicating that the usage of these chemicals
is no less than when NOES data were gathered. The 1986 reported IUR
production volume range was 1 million – 10 million lbs. The 2006 IUR
production volume range is 1 million – 10 million lbs.

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (1 million -10 million lb) 

- Total workers exceeding 1,000 based NOES data (1,926 workers).

110-44-1	2,4-Hexadienoic acid, (E,E)-

	The total number of potentially exposed workers exceeds 1,000 based on
NOES data.  Additionally, the number of potentially exposed consumers is
estimated to be very large based on the uses cited in the NLM Household
Chemicals Database (personal care products) and the reported IUR
commercial/consumer product categories for this chemical (C16 – rubber
and plastic products and C20 - other). Chemicals reporting in these
categories are contained in such products as tires, footwear, flooring,
bottles, sporting equipment, games, and toys. It is expected that these
products will be widely used by consumers (including children) and
hence, may likely exceed 10,000 people.  Additionally, products such as
tires and flooring are also used in a commercial setting, which may lead
to exposures of >1,000 commercial workers.  Based on this information,
this chemical would meet the exposure based findings criteria of
"substantial or significant human exposure.”  The production volume
data for the 2006 IUR data collection was compared to the production
volume data for the 1986 IUR data collection for this chemical to see if
the production volume stayed the same or increased, thereby indicating
that the usage of these chemicals is no less than when NOES data were
gathered.  The 1986 reported IUR production volume range was 1 million
– 10 million lbs. The 2006 IUR production volume range is 1 million
– 10 million lbs. (All stated IUR  commercial/consumer product
categories are non-CBI)

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (1 million -10 million lb)

- Total workers exceeding 1,000 based on NOES data  (69,243 workers)

- Total  workers potentially exceeding 1,000 based on the IUR
commercial/consumer product categories (C16 ) 

- Consumers potentially exceeding 10,000 people.

118-82-1	Phenol,4,4'-methylenebis[2,6-bis(1,1-dimethylethyl)

	The total number of potentially exposed workers exceeds1,000 based on
NOES data. Additionally, the number of potentially exposed consumers is
estimated to be very large based on the reported IUR commercial/consumer
product category for this chemical (C10 – lubricants, greases, & fuel
additives).  Chemicals reporting in this category are contained in
gasoline, kerosene, and distillate fuel oil after refining.  These are
generally commercial or consumer additives to enhance performance or
clean components of combustion devices.  It is expected that these
products will be widely used by commercial workers and consumers and
hence, may likely exceed 1,000 commercial workers and 10,000 consumers. 
Based on this information, this chemical would meet the exposure based
findings criteria of "substantial or significant human exposure.” The
production volume data for the 2006 IUR data collection was compared to
the production volume data for the 1986 IUR data collection for this
chemical to see if the production volume stayed the same or increased,
thereby indicating that the usage of these chemicals is no less than
when NOES data were gathered.  The 1986 reported IUR production volume
range was 1 million – 10 million lbs. The 2006 IUR production volume
range is 1 million – 10 million lbs. (All stated IUR
commercial/consumer product categories are non-CBI)

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (1 million -10 million lb)

- Total workers exceeding 1,000 based on NOES data  (120,009 workers)

- Total workers potentially exceeding 1,000 based on  and the IUR
commercial/consumer product category (C10)

- Consumers potentially exceeding 10,000 people.

119-61-9	Methanone, diphenyl-

	The total number of potentially exposed workers exceeds 1,000 based on
NOES data.  Additionally, the number of potentially exposed consumers is
estimated to be very large based on the uses cited in the NLM Household
Chemicals Database (personal care products and auto products) and the
reported IUR commercial/consumer product categories for this chemical
(C05 – electrical and electronic products, C12 – paints and
coatings, C13 – paper products, and C20 - other). Chemicals reporting
in these IUR product categories are contained in computers, office
equipment, household appliances, electric lighting and wiring, video and
audio recording and communication equipment; commercial and consumer
paints (paste or ready-mix) including artists’ paints, varnishes,
lacquers, enamels and shellac, paint and varnish removers and cleaners
and commercial and consumer paper products.  It is expected that these
products will be widely used by commercial workers and consumers
(including children) and hence, may likely exceed 1,000 commercial
workers and 10,000 consumers.  Based on this information, this chemical
would meet the exposure based findings criteria of "substantial or
significant human exposure.”  The production volume data for the 2006
IUR data collection was compared to the production volume data for the
1986 IUR data collection for this chemical to see if the production
volume stayed the same or increased, thereby indicating that the usage
of these chemicals is no less than when NOES data were gathered.  The
1986 reported IUR production volume range was 1 million – 10 million
lbs. The 2006 IUR production volume range is 1 million – 10 million
lbs. (All stated IUR  commercial/consumer product categories are
non-CBI)

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (1 million -10 million lb)

- Total workers exceeding 1,000 based on NOES data  (41,516 workers)

- Total workers potentially exceeding 1,000  based on the IUR
commercial/consumer product categories (C05, C12, C13 )

- Consumers potentially exceeding 10,000 people.

144-62-7	Ethanedioic acid

	The total number of potentially exposed workers is likely to exceed
1,000 based on reported IUR data.  The total number of potentially
exposed workers exceeds 1,000 based on NOES data. The number of
potentially exposed consumers is estimated to be very large based on the
uses cited in the NLM Household Chemicals Database (auto products,
cleansers, wood brighteners, and polishes) and the reported IUR
commercial/consumer product categories for this chemical (C06 –
fabrics, textiles, & apparel, C07 – glass & ceramic products, C13 –
paper products, C15 – polishes & sanitation goods, C17 – soaps &
detergents).  Additionally, the IUR commercial/consumer product category
C20-Other (chemicals contained in commercial and consumer products not
elsewhere classified) was reported for this chemical. This indicates
that this chemical is present in an unknown number of commercial and
consumer products that may potentially have a high number of exposures.
Chemicals reporting in these IUR product categories are contained in
commercial and consumer products made of cotton, silk, wool, or manmade
fibers; commercial and consumer glass and ceramic products; commercial
and consumer paper products; furniture, metal, glass, and other polishes
and cleaners; waxes and dressings for leather and other materials;
household and industrial disinfectants and bleaches; liquid, granulated,
caked, and flaked washing detergents and personal soaps; dishwashing
compounds; presoaks and scouring compounds for commercial and consumer
use; and sporting equipment, games and toys. It is expected that these
products will be widely used by commercial workers and consumers
(including children) and hence, may likely exceed 1,000 commercial
workers and 10,000 consumers.   It is also expected that based on the
nature of the C17 use that over 90 % of the soaps & detergent products
that contain this chemical will be released into the environment
(exceeding the significant release threshold of 10% of the production
volume).  Based on this information, this chemical would likely meet the
exposure based findings criteria of "substantial or significant human
exposure" and “substantial or significant release.”  The production
volume data for the 2006 IUR data collection was compared to the
production volume data for the 1986 IUR data collection for this
chemical to see if the production volume stayed the same or increased,
thereby indicating that the usage of these chemicals is no less than
when NOES data were gathered. The 1986 reported IUR production volume
range was 1 million – 10 million lbs. The 2006 IUR production volume
range is 1 million – 10 million lbs. (All stated IUR 
commercial/consumer product categories are non-CBI)

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (1 million -10 million lb)

- Substantial Release based on IUR commercial/consumer product category
(C17 – soaps & detergents)

- Total workers potentially exceeding 1,000 based on IUR data 

- Total workers exceeding 1,000 based on NOES data (142,000 workers) 

- Consumers potentially exceeding 10,000 people.

149-44-0	Methanesulfunic acid, hydroxyl-monosodium salt

	The total number of potentially exposed workers exceeds 1,000 based on
NOES data.  Additionally, the number of potentially exposed consumers is
estimated to be very large based on the reported IUR commercial/consumer
product categories for this chemical (C01 – adhesives & sealants and
C16 – rubber and plastics goods).  Chemicals reporting in these
product categories are contained in industrial and household adhesives;
glues; caulking compounds; sealants; linoleum, tile, and rubber cements;
tires; footwear; flooring; and bottles.  It is expected that these
products will be widely used by commercial workers and consumers and
hence, may likely exceed 1,000 commercial workers and 10,000 consumers. 
Based on this information, this chemical would meet the exposure based
findings criteria of "substantial or significant human exposure.”  The
production volume data for the 2006 IUR data collection was compared to
the production volume data for the 1986 IUR data collection for this
chemical to see if the production volume stayed the same or increased,
thereby indicating that the usage of these chemicals is no less than
when NOES data were gathered.  The 1986 reported IUR production volume
range was 1 million – 10 million lbs. The 2006 IUR production volume
range is 1 million – 10 million lbs. (All stated IUR 
commercial/consumer product categories are non-CBI)

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (1 million -10 million lb)

- Total workers exceeding 1,000 based on NOES data (239,465 workers) 

- Total workers potentially exceeding 1,000 based on  and the IUR
commercial/consumer product categories (C01 and C16)

- Consumers potentially exceeding 10,000 people.

2524-04-1	Phosphorochloridthioic acid, O,O-diethyl ester

	The total number of potentially exposed workers exceeds 1,000 based on
NOES data.  Based on this information, this chemical would meet the
exposure based findings criteria of "substantial or significant human
exposure.”  The production volume data for the 2006 IUR data
collection was compared to the production volume data for the 1986 IUR
data collection for this chemical to see if the production volume stayed
the same or increased, thereby indicating that the usage of these
chemicals is no less than when NOES data were gathered. The 1986
reported IUR production volume range was 10 million – 50 million lbs.
The 2006 IUR production volume range is 10 million – 50 million lbs.

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (10 million -50 million lb) 

- Total workers exceeding 1,000 based NOES data (1,088 workers).

4719-04-4	1,3,5-Triazine-1,3,5(2H,4H,6H)-triethanol

	The total number of potentially exposed workers is likely to exceed
1,000 based on reported IUR data. The number of workers exceeds 1,000
based on NOES data. Additionally, the number of potentially exposed
consumers is estimated to be very large based on the uses cited in the
NLM Household Chemicals Database (laundry and dishwashing detergents;
and all-purpose and surface cleaners). Additionally, the IUR
commercial/consumer product category C20-Other (chemicals contained in
commercial and consumer products not elsewhere classified) was reported
for this chemical. This indicates that this chemical is present in an
unknown number of commercial and consumer products that may potentially
have a high number of exposures. It is expected that these products will
be widely used by consumers (including children) and hence, may likely
exceed 10,000 people.  Additionally, products such as laundry detergents
and all-purpose surface cleaners may be used by commercial enterprises
that may lead to exposures of >1,000 commercial workers.   It is also
expected that based on the nature of the laundry and dishwashing
detergents use described in the NLM   Household Chemicals Database that
over 90 % of the production volume of the soaps & detergent products
that contain this chemical will be released into the environment
(exceeding the significant release threshold of 10% of the production
volume). Based on this information, this chemical would meet the
exposure based findings criteria of "substantial or significant human
exposure" and “significant or substantial release.”  The production
volume data for the 2006 IUR data collection was compared to the
production volume data for the 1986 IUR data collection for this
chemical to see if the production volume stayed the same or increased,
thereby indicating that the usage of these chemicals is no less than
when NOES data were gathered. The 1986 reported IUR production volume
range was 1 million – 10 million lbs. The 2006 IUR production volume
range is 10 million – 50 million lbs. (All stated IUR 
commercial/consumer product categories are non-CBI)

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (10 million -50 million lb)

- Substantial Release (Greater than 10% of production volume released)

- Total  workers potentially exceeding 1,000 based on  NLM Household
Chemicals Database information

 - Total workers exceeds 1,000 based on  NOES data (225,251 workers)

- Consumers potentially exceeding 10,000 people.

6381-77-7	D-erythro-Hex-2-enonic acid,.gamma.-lactone, monosodium salt

	The total number of potentially exposed workers exceeds 1,000 based on
NOES data.  Based on this information, this chemical would meet the
exposure based findings criteria of "substantial or significant human
exposure.” The production volume data for the 2006 IUR data collection
was compared to the production volume data for the 1986 IUR data
collection for this chemical to see if the production volume stayed the
same or increased, thereby indicating that the usage of these chemicals
is no less than when NOES data were gathered.  The 1986 reported IUR
production volume range was 10 thousand – 500 thousand lbs. The 2006
IUR production volume range is 1 million – 10 million lbs.

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (1 million -10 million lb) 

- Total workers exceeds 1,000 based NOES data (19,468 workers).

31138-65-5	D-gluco-Heptonic acid, monosodium salt, (2.xi.)-

	The total number of potentially exposed workers exceeds 1,000 based on
NOES data.  Based on this information, this chemical would meet the
exposure based findings criteria of "substantial or significant human
exposure.”  The production volume data for the 2006 IUR data
collection was compared to the production volume data for the 1986 IUR
data collection for this chemical to see if the production volume stayed
the same or increased, thereby indicating that the usage of these
chemicals is no less than when NOES data were gathered. The 1986
reported IUR production volume range was 1 million – 10 million lbs.
The 2006 IUR production volume range is 1 million – 10 million lbs.

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (1 million -10 million lb) 

- Total workers exceeding 1,000 based NOES data (74,165 workers).

66241-11-0	C.I. Leuco Sulphur Black 1

	The total number of potentially exposed workers exceeds 1,000 based on
NOES data.  Additionally, the number of potentially exposed consumers is
estimated to be very large based on the reported IUR commercial/consumer
product category for this chemical (C06 – fabrics, textiles &apparel).
 Chemicals reporting in this category are contained in commercial and
consumer products made of cotton, silk, wool, or manmade fibers. It is
expected that these products will be widely used by commercial workers
and consumers (including children) and hence, may likely exceed 1,000
commercial workers and 10,000 consumers.  Based on this information,
this chemical would meet the exposure based findings criteria of
"substantial or significant human exposure.”  The production volume
data for the 2006 IUR data collection was compared to the production
volume data for the 1986 IUR data collection for this chemical to see if
the production volume stayed the same or increased, thereby indicating
that the usage of these chemicals is no less than when NOES data were
gathered. The 1986 reported IUR production volume range was 1 million
– 10 million lbs. The 2006 IUR production volume range is 1 million
– 10 million lbs. (All stated IUR  commercial/consumer product
categories are non-CBI)

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (1 million -10 million lb)

- Total  workers exceeding 1,000 based on NOES data (38,555 workers) 

- Total workers potentially exceeding 1,000 based on  reported IUR
commercial/consumer product category (C06 – fabrics & textiles)  

- Consumers potentially exceeding 10,000 people.

68187-76-8	Castor oil, sulfated, sodium salt

	The total number of potentially exposed workers exceeds 1,000 based on
NOES data. Additionally, the number of potentially exposed consumers is
estimated to be very large based on the reported IUR commercial/consumer
product category for this chemical (C17 – soaps & detergents). 
Chemicals reporting in this category are contained in liquid,
granulated, caked, and flaked washing detergents and personal soaps;
dishwashing compounds; and presoaks and scouring compounds for
commercial and consumer use.  It is expected that these products will be
widely used by commercial workers and consumers and hence, may likely
exceed 1,000 commercial workers and 10,000 consumers.  The production
volume data for the 2006 IUR data collection was compared to the
production volume data for the 1986 IUR data collection for this
chemical to see if the production volume stayed the same or increased,
thereby indicating that the usage of these chemicals is no less than
when NOES data were gathered.  The 1986 reported IUR production volume
range was 1 million – 10 million lbs. The 2006 IUR production volume
range is 1 million – 10 million lbs. (All stated IUR 
commercial/consumer product categories are non-CBI)

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (1 million -10 million lb)

- Total workers exceeding 1,000 based on NOES data (11164 workers) 

- Total workers potentially exceeding 1,000 based on  IUR
commercial/consumer product category (C17 -  soaps & detergents) 

 - Consumers potentially exceeding 10,000 people.

68187-84-8	Castor oil, oxidized

	The total number of potentially exposed workers exceeds 1,000 based on
NOES data.  Additionally, the number of potentially exposed consumers is
estimated to be very large based on the uses cited in the NLM Household
Chemicals Database (auto care products and personal care products). 
Additionally, the IUR commercial/consumer product category C20-Other
(chemicals contained in commercial and consumer products not elsewhere
classified) was reported for this chemical. This indicates that this
chemical is present in an unknown number of commercial and consumer
products that may potentially have a high number of exposures. It is
expected that these products will be widely used by consumers (including
children) and hence, may likely exceed 10,000 people.  Additionally,
products such as auto care products may be used by commercial
enterprises that may lead to exposures of >1,000 commercial workers. 
Based on this information, this chemical would meet the exposure based
findings criteria of "substantial or significant human exposure.” The
production volume data for the 2006 IUR data collection was compared to
the production volume data for the 1986 IUR data collection for this
chemical to see if the production volume stayed the same or increased,
thereby indicating that the usage of these chemicals is no less than
when NOES data were gathered. There were no reports for this chemical
for the 1986 IUR data collection. The 2006 IUR production volume range
is 1 million – 10 million lbs. (All stated IUR  commercial/consumer
product categories are non-CBI)

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (1 million -10 million lb)

-  Total workers exceeds 1,000 based on NOES data (36,381workers)

- Total workers potentially exceeds 1,000 based on NLM Household
Chemicals Database information 

- Consumers potentially exceeding 10,000 people.

68479-98-1	Benzenediamine, ar,ar-diethyl-ar-methyl-

	The total number of potentially exposed workers exceeds1,000 based on
NOES data.  Based on this information, this chemical would meet the
exposure based findings criteria of "substantial or significant human
exposure.”  The production volume data for the 2006 IUR data
collection was compared to the production volume data for the 1986 IUR
data collection for this chemical to see if the production volume stayed
the same or increased, thereby indicating that the usage of these
chemicals is no less than when NOES data were gathered. The 1986
reported IUR production volume range was 10 million – 50 million lbs.
The 2006 IUR production volume range is 10 million – 50 million lbs.

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (10 million -50 million lb) 

- Total workers exceeds 1,000 based NOES data (4,121 workers).

68527-02-6	Alkenes, C12-24, chloro

	The total number of potentially exposed workers exceeds 1,000 workers
based on NOES data.  Based on this information, this chemical would meet
the exposure based findings criteria of "substantial or significant
human exposure.”   The production volume data for the 2006 IUR data
collection was compared to the production volume data for the 1986 IUR
data collection for this chemical to see if the production volume stayed
the same or increased, thereby indicating that the usage of these
chemicals is no less than when NOES data were gathered.  There were no
IUR reports for this chemical in 1986. The 2006 IUR production volume
range for this chemical is 1 million -10 million lbs.

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (1 million -10 million lb) 

- Total workers exceeds 1,000 based NOES data (84,192 workers).

68647-60-9	Hydrocarbons, C>4

	The total number of potentially exposed workers exceeds 1,000 based on
NOES data.  Based on this information, this chemical would meet the
exposure based findings criteria of "substantial or significant human
exposure.”  The production volume data for the 2006 IUR data
collection was compared to the production volume data for the 1986 IUR
data collection for this chemical to see if the production volume stayed
the same or increased, thereby indicating that the usage of these
chemicals is no less than when NOES data were gathered.  The 1986
reported IUR production volume range was 100 million -500 million lbs.
The 2006 IUR production volume range is > 1 billion lb.

This chemical met exposure based findings criteria based on:

- 2006 IUR Production Volume Range (>1billion lb)

- Total workers exceeds 1,000 based NOES data (1,257 workers).

Attachment AAttachment B

Attachment C

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Table 2-1 (Continued)

	                        

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			Table 2-1 (Continued)

			Table 2-2 (Continued)

