Risk Evaluation Determining Whether Environmental Emergency Planning is Required Under the Environmental Emergency Regulations set under the Canadian Environmental Protection Act, 1999 (CEPA 1999)

Tributyl Tetradecyl Phosphonium Chloride (CAS #: 81741-28-8) (TTPC) (CEPA, 1999 – Schedule 1, #46)

Summary of Risk Evaluation Analysis

Summary of Risk Evaluation Analysis

The Risk Evaluation Framework (REF), developed by Environment Canada, is applied to chemical substances in order to determine whether or not an environmental emergency (E2) plan should be required. For those substances that are evaluated as requiring an E2 plan, the next step is to determine a threshold quantity for the total quantity of the substance and the maximum storage container size on site. Within the REF, three categories are used to evaluate chemicals and assign threshold quantities. Shown below are the details within the three categories for tributyl tetradecyl phosphonium chloride:

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1. Environment Hazard

(Persistence, Bioaccumulation and Aquatic Toxicity Analysis)

No data are available to determine persistence.
No data are available to determine the bioaccumulative potential.
For aquatic toxicity, it was determined that tributyl tetradecyl phosphonium chloride is extremely toxic (LC₅₀ at 96 hrs less than 0.1 mg/L) based on the most sensitive species, bluegill sunfish (Making Water Work, 2006).

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2. Human Hazard

(Inhalation Toxicity and Carcinogenicity Analysis)

No vapour pressure is available to determine if tributyl tetradecyl phosphonium chloride could cause an inhalation problem.
Tributyl tetradecyl phosphonium chloride has currently not been evaluated for carcinogenicity.

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3. Physical Hazard

(Flammability and Combustibility Analysis)

Tributyl tetradecyl phosphonium chloride is a substance normally stable, even under fire exposure conditions, and is not reactive to water (BioLab Water Additives, 2006).

Flammability and Combustibility Analysis Table
	Value	Vapour Cloud Explosion (Yes/No)	Combustible (Yes/No)	References
Boiling point (°C)	100	No	No	(BioLab Water Additives, 2000)
Flash Point (°C)	--	No	No

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Threshold

The data from the above mentioned categories were used to determine the various environmental/human thresholds. The threshold quantities relate to: carcinogenicity, aquatic toxicity, inhalation toxicity, vapour cloud explosion, combustibility, and reactivity.

The threshold quantity for carcinogenicity is defaulted to 0.22 tonnes, if it meets the following criteria:

1) have an IARC rating of 1, 2A or 2B, or have a US EPA rating of A, B1, or B2;

2) be persistent in any media for greater than 5 years.

Threshold quantities assigned as a result of aquatic toxicity are based on the following table:

Threshold Quantities Assigned as a Result of Aquatic Toxicity
Criteria	Extremely Toxic	Highly Toxic	Moderately Toxic	Slightly Toxic
Persistence (water)	≥ 6 months	≥ 2 months to < 6 months	N/A	N/A
Bioaccumulation	BCF ≥ 5000 or Log Kow ≥ 5	BCF ≥ 500 to < 5000 or Log Kow ≥ 4 to < 5 (unless BCF < 500)	N/A	N/A
Acute Aquatic Toxicity (96 hrs LC₅₀ – mg/L)	≤ 0.1	> 0.1 to ≤ 1	> 1 to ≤ 10	> 10 to ≤ 100
Threshold Quantity Tonnes (lbs)	0.22 (500 lbs)	1.13 (2 500 lbs)	4.50 (10 000 lbs)	9.10 (20 000 lbs)

A substance is a candidate for a vapour cloud explosion if its flash point is < 23°C and its boiling point is < 35°C. A substance is considered combustible if its flash point is < 23°C or its boiling point is < 35°C. In accordance with the precautionary principle, the category with the lowest threshold will be used. For further explanation, please refer to the Implementation Guidelines for Part 8 of the Canadian Environmental Protection Act, 1999 – Environmental Emergency Plans. (http://www.ec.gc.ca/ee-ue/)

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Conclusion

For tributyl tetradecyl phosphonium chloride # 46, the E2 hazard threshold was triggered by:

1) Aquatic toxicity at 0.22 tonnes.

Therefore, tributyl tetradecyl phosphonium chloride # 46 is recommended for addition to Schedule 1 of the Environmental Emergency Regulations under Part 3 with a threshold quantity of 0.22 tonnes.

References

BioLab Water Additives. Product information sheet for Bellacide 350. 2006. World Wide Web accessed November 2011.
http://www.wateradditives.com/Repository/Files/BWA_Bellacide_350_GP_WF_AP.pdf

Cat. No.: En14-55/33-2011E-PDF

ISBN: 978-1-100-19723-4

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