Safety Assessment of Polyurethanes as Used in Cosmetics

Transcription

1 Safety Assessment of Polyurethanes as Used in Cosmetics Status: Draft Report for Panel Review Release Date: March 17, 2017 Panel Meeting Date: April 10-11, 2017 The 2017 Cosmetic Ingredient Review Expert Panel members are: Chair, Wilma F. Bergfeld, M.D., F.A.C.P.; Donald V. Belsito, M.D.; Ronald A. Hill, Ph.D.; Curtis D. Klaassen, Ph.D.; Daniel C. Liebler, Ph.D.; James G. Marks, Jr., M.D.; Ronald C. Shank, Ph.D.; Thomas J. Slaga, Ph.D.; and Paul W. Snyder, D.V.M., Ph.D. The CIR Director is Lillian J. Gill, D.P.A. This report was prepared by Lillian C. Becker, Scientific Analyst/Writer. Cosmetic Ingredient Review 1620 L Street, NW, Suite 1200 Washington, DC ph fax cirinfo@cir-safety.org

2 Commitment & Credibility since 1976 MEMORANDUM To: From: CIR Expert Panel and Liaisons Lillian C. Becker, M.S. Scientific Analyst and Writer Date: March 17, 2017 Subject: Polyurethanes As Used In Cosmetics Attached is the Draft Report of Polyurethanes as used in cosmetics. [polyur_042017_rep] The 66 polyurethane ingredients in this report are copolymers comprised, in part, of carbamate (i.e., urethane) linkages. Several of these polyurethane ingredients, as defined, are the polymers dispersed in water or another solvent. The presence of residual diicocyanante monomers will be important in the evaluation of the safety of the polyurethanes. Exposure to diisocyanates in the work place is one of the leading causes of occupational asthma and other related issues; diisocyanates have also been associated with irritant and allergic contact dermatitis, as well as skin and conjunctival irritation. The SLR was posted in January 2017 requesting additional data, including impurity data, especially on the monomers. Concentration of use data [polyur_042017_data_1-2] and unpublished data have been submitted and summarized in the report. This data includes technical information for Polyurethane-36, -60, and -61 [polyur_042017_data3]; HRIPT and in vitro ocular irritation for Polyurethane-14 [polyur_042017_data_4]; physical properties, in vitro eye and skin irritation data, and mutagenicity data for Polyurethane-62 [polyur_042017_data_5]; inhalation, sensitization, HRIPT, and cumulative irritation data for Polyurethane-14 [polyur_042017_data_6]; and physical properties and toxicity data for Polyurethane-28, -42, and -69 [polyur_042017_data_7-8] Data on polyurethanes that may be similar to the polyurethanes in this safety assessment (e.g. have a similar method of manufacture and starting materials) that are not listed in the Dictionary as cosmetic ingredients have been included as potential supporting information. Council comments have been addressed. [polyur_042017_pcpc] If no further data are needed, the Panel should develop the basis for the Discussion and issue a Tentative Report. If more data are required, the Panel should identify the data that are needed for a conclusion of safety, and issue an Insufficient Data Announcement L Street, NW Suite 1200, Washington, DC (Main) (Fax) ( ) cirinfo@cir-safety.org (Website)

3 SAFETY ASSESSMENT FLOW CHART INGREDIENT/FAMILY Polyurethanes MEETING April 2017 Public Comment CIR Expert Panel Report Status Priority List INGREDIENT PRIORITY LIST 60 day public comment period SLR January 11, 2017 Draft Report Table DRAFT REPORT Apr 2017 Table IDA TR IDA Notice Draft TR IDA DRAFT TENTATIVE REPORT Table Table Tentative Report Issue TR 60 day Public comment period Draft FR DRAFT FINAL REPORT Table Table Different Conclusion PUBLISH Final Report Issue FR

4 History Polyurethanes June, 2016 Polyurethanes added to Priority List due to reported VCRP usage of Polyurethane-11 (300 uses). January, 2017 SLR posted with a list of data needs: Chemical and physical properties, including molecular weight Method of manufacture Impurity data, especially on the monomers Dermal penetration Chronic dermal toxicity Inhalation toxicity Carcinogenicity Dermal irritation and sensitization June, 2017 Panel examines Draft Report. Concentration of use data and unpublished data (including chemical and physical properties, method of manufacture, impurity data, ocular and dermal irritation, sensitization, and mutagenicity) have been submitted and inserted into the report. All of the available data are only on a few of the ingredients in this report: Polyurethane-14, -28, -35, - 42, and -62. A concern for evaluating the safety of these ingredients, as it was for the HDI Polymers, is the presence of residual monomers.

5 Polyurethanes Data Profile for April, Writer Lillian Becker ADME Acute toxicity Repeated dose toxicity Irritation Sensitization Phototoxicity Carcinogenicity Genotoxicity Repro/Devel In Vitro Human Animal Dermal In Vitro Dermal Human Dermal Animal Ocular In Vitro Ocular Animal Inhale Dermal Oral Inhale Dermal Oral Use Log K ow Dermal Penetration Polyurethane-1 X Polyurethane-2 X Polyurethane-4 Polyurethane-5 Polyurethane-6 X Polyurethane-7 X Polyurethane-8 X Polyurethane-9 X Polyurethane-10 X Polyurethane-11 X Polyurethane-12 Polyurethane-13 Polyurethane-14 X X X X X X X Polyurethane-15 X Polyurethane-16 X Polyurethane-17 Polyurethane-18 X Polyurethane-19 Polyurethane-20 Polyurethane-21 Polyurethane-23 Polyurethane-24 X Polyurethane-25 Polyurethane-26 Polyurethane-27 Polyurethane-28 X Polyurethane-29 Polyurethane-32 Polyurethane-33 X Polyurethane-34 X Polyurethane-35 X X X X X X X Polyurethane-36 Polyurethane-39 X Polyurethane-40 X Polyurethane-41 Polyurethane-42 X X Polyurethane-43 Polyurethane-44 Polyurethane-45 Polyurethane-46 X Polyurethane-47 Polyurethane-48 Polyurethane-49 Polyurethane-50 Polyurethane-51 Polyurethane-52 Polyurethane-53 Polyurethane-54 Polyurethane-55 Polyurethane-56 Polyurethane-57 Polyurethane-58 Polyurethane-59

6 Polyurethanes Data Profile for April, Writer Lillian Becker ADME Acute toxicity Repeated dose toxicity Irritation Sensitization Phototoxicity Carcinogenicity Genotoxicity Repro/Devel In Vitro Human Animal Dermal In Vitro Dermal Human Dermal Animal Ocular In Vitro Ocular Animal Inhale Dermal Oral Inhale Dermal Oral Use Log K ow Dermal Penetration Polyurethane-60 Polyurethane-61 Polyurethane-62 X X X X Polyurethane-63 Polyurethane-64 Polyurethane-65 Polyurethane-66 Polyurethane-67 Polyurethane-68 Polyurethane-69 Polyurethane-70 Polyurethane-71 Polyurethane-72 Polyurethane X X

7 Polyurethanes Ingredient CAS # InfoBase SciFinder PubMed TOXNET FDA EU ECHA IUCLID SIDS HPVIS NICNAS NTIS NTP WHO FAO FEMA Web Polyurethane-1 N N N N N N N N N N N N N N N N N Polyurethane-2 N N N N N N N N N N N N N N N N N Polyurethane-4 N N N N N N N N N N N N N N N N N Polyurethane-5 N N N N N N N N N N N N N N N N N Polyurethane-6 N N N N N N N N N N N N N N N N N Polyurethane-7 N N N N N N N N N N N N N N N N N Polyurethane-8 N N N N N N N N N N N N N N N N N Polyurethane N N N N N N N N N N N N N N N N N Polyurethane-10 N N N N N N N N N N N N N N N N N Polyurethane N N N N N N N N N N N N N N N N N Polyurethane-12 N N N N N N N N N N N N N N N N N Polyurethane-13 N N N N N N N N N N N N N N N N N Polyurethane-14 Y N N N N N N N N N Y N N N N N N Polyurethane-15 N N N N N N N N N N N N N N N N N Polyurethane-16 N N N N N N N N N N N N N N N N N Polyurethane N N N N N N N N N N N N N N N N N Polyurethane-18 N N N N N N N N N N N N N N N N N Polyurethane-19 N N N N N N N N N N N N N N N N N Polyurethane-20 N N N N N N N N N N N N N N N N N Polyurethane-21 N N N N N N N N N N N N N N N N N Polyurethane-23 N N N N N N N N N N N N N N N N N Polyurethane-24 N N N N N N N N N N N N N N N N N Polyurethane-25 N N N N N N N N N N N N N N N N N Polyurethane N N N N N N N N N N N N N N N N N Polyurethane N N N N N N N N N N N N N N N N N Polyurethane-28 N N N N N N N N N N N N N N N N N Polyurethane-29 N N N N N N N N N N N N N N N N N Polyurethane-32 N N N N N N N N N N N N N N N N N Polyurethane-33 N N N N N N N N N N N N N N N N N Polyurethane-34 N N N N N N N N N N N N N N N N N Polyurethane-35 Y N N N N N N N N N Y N N N N N N Polyurethane-36 N N N N N N N N N N N N N N N N N Polyurethane-39 N N N N N N N N N N N N N N N N N Polyurethane-40 N N N N N N N N N N N N N N N N N Polyurethane-41 N N N N N N N N N N N N N N N N N Polyurethane N N N N N N N N N N N N N N N N N Polyurethane-43 N N N N N N N N N N N N N N N N N Polyurethane-44 N N N N N N N N N N N N N N N N N Polyurethane-45 N N N N N N N N N N N N N N N N N

8 Ingredient CAS # InfoBase SciFinder PubMed TOXNET FDA EU ECHA IUCLID SIDS HPVIS NICNAS NTIS NTP WHO FAO FEMA Web Polyurethane-46 N N N N N N N N N N N N N N N N N Polyurethane-47 N N N N N N N N N N N N N N N N N Polyurethane-48 N N N N N N N N N N N N N N N N N Polyurethane-49 N N N N N N N N N N N N N N N N N Polyurethane-50 N N N N N N N N N N N N N N N N N Polyurethane-51 N N N N N N N N N N N N N N N N N Polyurethane-52 N N N N N N N N N N N N N N N N N Polyurethane-53 N N N N N N N N N N N N N N N N N Polyurethane-54 N N N N N N N N N N N N N N N N N Polyurethane-55 N N N N N N N N N N N N N N N N N Polyurethane N N N N N N N N N N N N N N N N N Polyurethane N N N N N N N N N N N N N N N N N Polyurethane-58 N N N N N N N N N N N N N N N N N Polyurethane-59 N N N N N N N N N N N N N N N N N Polyurethane-60 N N N N N N N N N N N N N N N N N Polyurethane-61 N N N N N N N N N N N N N N N N N Polyurethane-62 Y N N N N N N N N N Y N N N N N N Polyurethane-63 N N N N N N N N N N N N N N N N N Polyurethane-64 N N N N N N N N N N N N N N N N N Polyurethane-65 N N N N N N N N N N N N N N N N N Polyurethane-66 N N N N N N N N N N N N N N N N N Polyurethane N N N N N N N N N N N N N N N N N Polyurethane N N N N N N N N N N N N N N N N N Polyurethane N N N N N N N N N N N N N N N N N Polyurethane-70 N N N N N N N N N N N N N N N N N Polyurethane-71 N N N N N N N N N N N N N N N N N Polyurethane N N N N N N N N N N N N N N N N N Polyurethane N N N N Y N N N N N N N N N N N N ECHA Data Base there is a Pre-Registration entry for Polyurethane with the CAS No (which does not match any ingredient listed in the On-line DB) and Polyurethane-9. Polyurethane Manufacturers Association (PMA) no useful information.

9 Safety Assessment of Polyurethanes as Used in Cosmetics Status: Draft Report for Panel Review Release Date: March 17, 2017 Panel Meeting Date: April 10-11, 2017 The 2017 Cosmetic Ingredient Review Expert Panel members are: Chair, Wilma F. Bergfeld, M.D., F.A.C.P.; Donald V. Belsito, M.D.; Ronald A. Hill, Ph.D.; Curtis D. Klaassen, Ph.D.; Daniel C. Liebler, Ph.D.; James G. Marks, Jr., M.D.; Ronald C. Shank, Ph.D.; Thomas J. Slaga, Ph.D.; and Paul W. Snyder, D.V.M., Ph.D. The CIR Director is Lillian J. Gill, D.P.A. This report was prepared by Lillian C. Becker, Scientific Analyst/Writer. Cosmetic Ingredient Review 1620 L Street, NW, Suite 1200 Washington, DC ph fax cirinfo@cir-safety.org

10 INTRODUCTION This is a review of the available scientific literature and unpublished data relevant to assessing the safety of polyurethanes as used in cosmetics. According to the International Cosmetic Dictionary and Handbook (Dictionary), the functions of these 66 ingredients include artificial nail builders, binders, film formers, hair fixatives, plasticizers, and surface modifiers (Table 1). 1 The ingredients in this group are: Polyurethane-1 Polyurethane-2 Polyurethane-4 Polyurethane-5 Polyurethane-6 Polyurethane-7 Polyurethane-8 Polyurethane-9 Polyurethane-10 Polyurethane-11 Polyurethane-12 Polyurethane-13 Polyurethane-14 Polyurethane-15 Polyurethane-16 Polyurethane-17 Polyurethane-18 Polyurethane-19 Polyurethane-20 Polyurethane-21 Polyurethane-23 Polyurethane-24 Polyurethane-25 Polyurethane-26 Polyurethane-27 Polyurethane-28 Polyurethane-29 Polyurethane-32 Polyurethane-33 Polyurethane-34 Polyurethane-35 Polyurethane-36 Polyurethane-39 Polyurethane-40 Polyurethane-41 Polyurethane-42 Polyurethane-43 Polyurethane-44 Polyurethane-45 Polyurethane-46 Polyurethane-47 Polyurethane-48 Polyurethane-49 Polyurethane-50 Polyurethane-51 Polyurethane-52 Polyurethane-53 Polyurethane-54 Polyurethane-55 Polyurethane-56 Polyurethane-57 Polyurethane-58 Polyurethane-59 Polyurethane-60 Polyurethane-61 Polyurethane-62 Polyurethane-63 Polyurethane-64 Polyurethane-65 Polyurethane-66 Polyurethane-67 Polyurethane-68 Polyurethane-69 Polyurethane-70 Polyurethane-71 Polyurethane-72 The polyurethane ingredients in this report are copolymers comprised, in part, of carbamate (i.e., urethane) linkages. Some of these polyurethane ingredients, as defined, are the polymers dispersed in water (e.g., Polyurethane-17, -35, -36, -58, -60, -61, -70, -71, and -72). 1 Several precursors and moieties of these polymers have been reviewed by the Cosmetic Ingredient Review (CIR) Expert Panel (Panel) Table 2 lists the previously reviewed ingredients and connects them to the relevant polyurethanes in this report. Chemicals, including cosmetic ingredients, which have not been reviewed by the Panel and are precursors or moieties of the polyurethanes in this safety assessment, are listed in Table 3. Quantification of residual diisocyanate monomers in the cosmetic ingredients addressed in this report is important for determining safety (Table 4). These ingredients are copolymers, each of which is synthesized, in part, from isocyanate analogs. 28,29 Exposure to diisocyanates in the work place is one of the leading causes of occupational asthma and related issues; diisocyanates have also been associated with irritant and allergic contact dermatitis, as well as skin and conjunctival irritation. The CIR Panel has reviewed hexamethylene diisocyanate (HDI) polymers, which are polymers (polyurethanes) also derived from isocyanates, and found that 17 of these ingredients are safe in cosmetics in the present practices of use and concentration, and that the available data are insufficient to make a determination that 2 of these ingredients are safe (Table 2). 30 The data needed for these two ingredients are their molecular weights; if the molecular weights are <1000 Da, then dermal penetration absorption, and/or 28-day dermal toxicity. If these ingredients are soluble or dermally absorbed, then systemic toxicity, including genotoxicity, carcinogenicity, and reproduction/developmental toxicity, may be needed. Data on polyurethanes that are not listed in the Dictionary as cosmetic ingredients have been included for potential supporting information. CHEMISTRY Definition and Structure The structures, definitions, and functions of the polyurethanes in this safety assessment are provided in Table 1. Some of the definitions may give insight into the method of manufacture. Several of these polyurethane ingredients, as defined, are the polymers dispersed in water (e.g., Polyurethane-17, -35, -36, -58, -60, -61, -70, -71, and -72). 1 Other polyurethanes may be supplied as dispersions (in water or other solvents), as indicated in ingredient specifications (e.g. Polyurethane-14, -28, -42, and -69). 31,32 The polyurethane ingredients in this report are copolymers comprising, in part, carbamate (i.e., urethane) linkages (Figure 1). Polyurethanes are formed by reacting a polyol (e.g., a glycol) with a diisocyanate or polyisocyanate.

11 Figure 1. Urethane residue Physical and Chemical Properties Chemical and physical properties are provided in Table 5. Some of these polymers are linear, but when multi-functional monomers (e.g., glycerin) are used as reactants, branched or cross-linked structures are probable. The degree of polymerization of these ingredients can be controlled to obtain a product having a desired functionality, such as rheology modifier. Accordingly, the molecular weights and molecular volumes of these ingredients could vary widely, unless otherwise noted in specifications. These polymers, by virtue of their monomers, contain both hydrophilic and hydrophobic groups. The ratio of hydrophilic and hydrophobic groups may vary within one ingredient name. Estimating some of the chemical and physical properties of these ingredients is challenging in the absence of ingredient-explicit specifications. These ingredients potentially can range from liquid to solid, soluble to insoluble, and non-penetrating to readily penetrating the skin. Aside from the potential presence of a diisocyanate or end-capping agent residue, these ingredients are likely to be similar to unmodified polyurethane-type polymers. Based on the monomer composition and general hydrophobic properties of Polyurethane-14, it is not expected to be significantly soluble in water. 31 It is not expected to undergo significant hydrolysis within a ph range of 4-9. Polyurethane-14 partitions primarily in the organic phase in octanol-water separation systems. The particle size of Polyurethane-14 was reported to be 1.9 ± 3.21 µm by one supplier. 33 Polyurethane-28 is reported to have a mean molecular weight >30,000 daltons (Da) with no molecules <1000 Da. 32 Polyurethane-42 is reported to have a mean molecular weight of >36,000 with no molecules <1000 Da. These polymers are reported to be stable at 5-50 C for 3 years under storage conditions. Based on the high mean molecular weight (>1000 Da) and predominantly hydrophobic structure, Polyurethane-35 is expected to have low solubility in water. 34 This polymer is stable under normal environmental conditions and will not degrade in cosmetic products at 5%-15%. The mean molecular weight of Polyurethane-36 is >50,000 Da. 35 The same supplier reported that Polyurethane-60 is supplied as an aqueous, low viscosity, anionic dispersion polycarbonate-polyurethane. 36 The mean molecular weight of Polyurethane-60 is >50,000 Da. Additionally, the same supplier reported that Polyurethane-61 is supplied as an aqueous, low viscosity dispersion of an aliphatic polyester-polyurethane. 37 The mean molecular weight of Polyurethane-61 is >50,000 Da. A supplier reported that the particle size of Polyurethane-62 was µm and the mean molecular weight is >70,000 Da. 38 Polyurethane-62 is stable under normal environmental conditions and yields no degradation products under normal conditions of use. Another supplier reports that the average molecular weight of Polyurethane-62 is approximately 100,000 Da. 39 The average total molecular weight of Polyurethane-69 is >3400 Da. 32 Low molecular weight fractions (<1000 Da) were detected at 4%. Method of Manufacture In general, polyurethanes are formed by reacting a polyol (e.g., a glycol) with a diisocyanate or polyisocyanate. Table 6 cites the methods of manufacture of individual polyurethanes. Impurities/Constituents Table 7 cites the polyurethanes that are reported to be suspensions. Suspensions include water and cyclopentasiloxane. Preservatives may also be included in the suspension. 31,32,34-37 A supplier reports that Polyurethane-36, -60, and -61, which are supplied as dispersions in water, are reported to be free from other solvents and isocyanate groups; residual isocyanates are expected to react with water in the dispersion and form polyureas Polyurethane-28, -42, and -69 are reported to contain no detectable residual isophorone diisocyanate (IPDI; a monomer used in their synthesis) by high-performance liquid chromatography-mass spectrometry (HPLC-MS; detection limit 5 ppm). 32 Polyurethane-62 is reported to contain no detectable residual unreacted isocyanate (HDI; a monomer used in their synthesis). 39 4,4 -Diaminodiphenylmethane (MDA) is classified as a carcinogen and is used in the production of methylene diphenyldiisocyanate (MDI). 40 MDI, or an analog thereof, is a component of some of the polyurethanes in this safety assessment (e.g., Polyurethane-2, -17, -29, -33, -40, -60, and -61). 1 In a study to determine the safety profile of MDI in

12 consumer products, no residual MDA was detected in the resultant production of MDI. 40 Furthermore, any remaining MDI would be expected to be further reduced when MDI is further processed in the manufacture of polyurethanes. USE Cosmetic The safety of the cosmetic ingredients addressed in this assessment is evaluated based on data received from the FDA and the cosmetics industry on the expected use of these ingredients in cosmetics. Use frequencies of individual ingredients in cosmetics are collected from manufacturers and reported by cosmetic product category in FDA s Voluntary Cosmetic Registration Program (VCRP) database. Use concentration data are submitted by the cosmetic industry in response to a survey, conducted by the Personal Care Products Council (Council), of maximum reported use concentrations by product category. According to VCRP survey data received in 2017, Polyurethane-11 was reported to be used in 315 formulations, 303 in leave-on formulations and 12 in rinse-off formulations (Table 8). 41 The additional ingredients with reported uses in the VCRP were reported to have uses in 33 or fewer formulations. The VCRP has an entry for polyurethane with 17 uses in a pattern similar to the polyurethanes in this safety assessment. It is unknown to what extent, if any, polyurethane is the same as or similar to, one or more of the polyurethane ingredients in this safety assessment. The results of the concentration of use survey conducted by the Council in 2016 indicate that Polyurethane-1 has the highest reported maximum concentration of use; it is used at up to 15% in nail products. 42 The highest maximum concentration of use reported for products resulting in leave-on dermal exposure is 7.5% Polyurethane-33 in the category of other skin care preparations. The other reported concentrations of use were at up to 9% (in nail, hair, or rinse-off dermal preparations) or less. In some cases, uses were reported to the VCRP, but concentration of use data were not provided. For example, Polyurethane-7 was reported to be used in 14 cosmetic formulations, but no use concentration data were reported. In other cases, no uses were reported to the VCRP, but concentration of use data were received from industry; for example, Polyurethane-10 had no reported uses in the VCRP, but use concentrations in the categories of mascara; tonics, dressings, and other hair grooming aids; and foundations were provided in the industry survey. Therefore, it should be presumed there is at least one use in every category for which a concentration is reported. The ingredients not in use according to the VCRP and industry survey are listed in Table 9. Polyurethane-1, -2, -10, -11, -14, -33, -34, -35, and -40 were reported to be used in products that are applied around the eye; the highest reported concentration of use was 7%, which was for Polyurethane-35 in mascara. Polyurethane-11, -15, and -34 were reported to be used in products that may be ingested and come in contact with mucous membranes; the highest reported concentration of use was 2.9%, which was for Polyurethane-34 in lipsticks. Several of the polyurethanes are used in cosmetic sprays and could possibly be inhaled. Polyurethane-1, -6, -11, -14, -24, and -33 were reported to be used in spray products; the maximum reported concentration for a spray product was 6% Polyurethane-6 in pump hair sprays. In practice, 95% to 99% of the droplets/particles released from cosmetic sprays have aerodynamic equivalent diameters >10 µm Therefore, most droplets/particles incidentally inhaled from cosmetic sprays would be deposited in the nasopharyngeal and bronchial regions and would not be respirable (i.e., they would not enter the lungs) to any appreciable amount. 43,45 Polyurethane-2, -7, -11, -14, -35, and -40 were reported to be used in face powders; the highest maximum reported concentration was at up to 3.2% Polyurethane-11. Conservative estimates of inhalation exposures to respirable particles during the use of loose-powder cosmetic products are 400-fold to 1000-fold less than protective regulatory and guidance limits for inert airborne respirable particles in the workplace Polyurethane-17 and -21 are restricted in Europe: the amount of residual trialkyalmines is limited to 2.5% in readyfor-use preparations in the category of leave-on products. 50,51 Also, trialkylamines are further limited in that they are not to be used with nitrosating systems, have a maximum secondary amine content of 0.5%, have a maximum nitrosamine content of 50 µg/kg, have a minimum purity of 99%, and must be kept in nitrite-free containers. The National Industrial Chemical Notification and Assessment Scheme (NICNAS) of Australia determined that there is negligible concern to public health when Polyurethane-14 is used as a hair fixative agent in hair care products such as pump sprays and hair gel formulations at concentrations up to 6%. 31 NICNAS also determined that Polyurethane-35 and -62 were not considered to pose an unreasonable risk to the health of workers and the public. 34,38 Non-Cosmetic In the United States, polyurethanes may come in contact with food as direct and indirect food additives, and in single use and repeated use food containers. [21 CFR 174.5; 21 CFR ; 21 CFR ; 21 CFR ; 21 CFR ; 21 CFR ; 21 CRF ; 21 CFR ] Polyurethanes used in food packaging adhesives and polyurethane resins may not contain 4,4'-Methylenebis (2-chloroanaline). [21 CFR ] Polyurethanes may be used in ear, nose and throat medical devices and in general and plastic surgery devices (e.g., silicone gel-filled breast prosthesis and occlusive wound dressing). [21 CFR ; 21 CFR ; 21 CFR ] Polyurethane-36, -60, and -61 are not in compliance for use in food contact adhesives according to FDA regulations

13 The U.S. Food and Drug Administration (FDA) stipulates that polyurethane resins that are used in adhesives that may come in contact with food must be produced by: (1) reacting diisocyanates with one or more of the listed polyols or polyesters [this is a large list and is not provided here; an abbreviated list of monomers and precursors are provided in Table 10], or (2) reacting the chloroformate derivatives of one or more of the listed polyols or polyesters with one or more of the listed polyamines [not listed here; Table 10], or (3) reacting toluene diisocyanate or 4,4'-methylenebis(cyclohexylisocyanate) with: (i) one or more of the listed polyols or polyesters [not listed here; Table 10] and with either N-methyldiethanolamine and dimethyl sulfate or dimethylolpropionic acid and triethylamine, or (ii) a fumaric acid-modified polypropylene glycol or fumaric acid-modified tripropylene glycol, triethylamine, and ethylenediamine, or (4) reacting meta-tetramethylxylene diisocyanate with one or more of the listed polyols and polyesters [not listed here; Table 10] and with dimethylolpropionic acid and triethylamine, N-methyldiethanolamine, 2-dimethylaminoethanol, 2-dimethylamino-2-methyl-1-propanol, and/or 2-amino-2-methyl-1-propanol. [21CFR ] Polyurethane-36 is exempt from the Toxic Substances Control Act (TSCA) Inventory listing requirements under the provisions of the TSCA Polymer Exemption. [40CFR ] Polyurethane foam or porous polyurethane films are used to make wound dressings Polyurethane prostheses are being developed for soft tissue scaffolds of blood vessels and tissues of the cardiovascular system; some of these are impregnated with drugs to control smooth muscle cell proliferation. 55 Polyurethanes are used to coat medical implants, including percutaneous leads, catheters, tubing, and intra-aortic balloons. 56,57 Polyurethane has been used as a coating on breast implants. 58 Sprayed polyurethane foam is used for roofing material and other protective applications such as truck bed liners. 59 TOXICOKINETIC STUDIES Toxicokinetic studies were not found in the published literature and no unpublished data were submitted. TOXICOLOGICAL STUDIES Acute Dose Toxicity Acute dermal toxicological studies were not found in the published literature and no unpublished data were submitted. Oral The oral LD 50 of Polyurethane-35 in rats was reported to be 4890 mg/kg. 34 The test was conducted in accordance with the Organisation for Economic Co-operation and Development test guideline (OECD TG) 423. No further details were provided. Inhalation Sprague Dawley rats (n=5/sex) were exposed to Polyurethane-14 (9.6% in 55% ethanol) for 4 h in a whole body inhalation chamber at 110 mg/m 3 Polyurethane-14 and 964,000 mg/m 3 ethanol as a liquid droplet aerosol. 33 The mean aerodynamic diameter of the particles was 1.9 ± 3.21 µm. There were no mortalities during the experiment or during the 14- day observation period. Clear nasal discharge was observed in one male following exposure. No toxicologically significant clinical findings were observed. There were no remarkable body weight changes or observations at necropsy. The LC 50 of Polyurethane-14 was reported to be >110 mg/m 3. Short-Term Toxicity Studies Short-term dermal toxicity studies were not found in the published literature and no unpublished data were submitted. Oral Male Swiss albino mice (n=6) received a polyurethane nanoparticle solution (0, 2, 5, or 10 mg/kg in saline) by gavage daily for 10 days. 60 The polyurethane tested was manufactured with a natural triol, diisocyanate, and olive oil that were added to a solution of tween 80 while stirring at room temperature. The polyurethane particles had a diameter of 249 ± 5.7 nm and a polydispersity index (PDI) of 0.3 ± All mice survived the study and there were no behavioral changes observed. At necropsy, there were no differences in body weights or organ weights among the groups. There was increased visceral fat accumulation in the mice in all treatment groups compared to controls. The lungs of mice in the 5 and 10 mg/kg/day groups (4 and 6 mice, respectively) showed inflammation, and inflammatory infiltrate was observed in all treatment groups. The kidneys of mice in the 5 and 10 mg/kg/day groups (5 and 6 mice, respectively) showed glomerular necrosis and glomerular atrophy. Histological examination of the adipose tissue did not reveal any alterations in morphology in any group. Oral polyurethane administration induced an increase in alanine aminotransferase (ALT) levels (58 ± 7.7, 69 ± 15, and 78 ± 4.5 IU/L in the 2, 5, and 10 mg/kg groups, respectively, versus control mice 34 ± 3.5 IU/L). Mice in the 5 and

14 10 mg/kg groups also showed an increase in alkaline phosphatase activities (ALP) (20 ± 4 and 24 ± 2 IU/L, respectively, versus controls, 8.5 ± 1.7 IU/L). Hematological evaluation revealed no changes in any parameter. There was an increase in TNF-α level (approximately 80-fold) in mice in the 10 mg/kg group. The authors concluded that oral administration of polyurethane nanoparticles generates an inflammatory response in mice. Inhalation Sprague Dawley rats (n=5/sex) were exposed to Polyurethane-14 (9.6% in 55% ethanol) 6 h/day for 14 days in a whole body inhalation chamber at 10, 30, and 100 mg/m 3 Polyurethane-14 and 964 ppm ethanol as a liquid droplet aerosol. 61 There were no mortalities during the exposure period. At necropsy, pallor was observed in the lungs of one male and one female in the 30 mg/m 3 group; this finding was consistent with histopathologic observations of alveolar histiocytosis and was considered an effect of exposure to the test material. The mean absolute lung weights were increased in both sexes of the 100 mg/m 3 group and the females of the 30 mg/m 3 group; mean relative lung weights were increased in both sexes in the 30 and 100 mg/m 3 groups. The increased lung weights were considered an effect of exposure to the test material and correlated with the increased incidence and severity of alveolar histiocytosis. The diffuse alveolar histiocytosis, observed in the lungs of the rats in the 30 and 100 mg/m 3 groups, increased in severity with increased exposure. Multifocal, minimal alveolar histiocytosis was observed in the lungs of some of the rats in the control and 10 mg/m 3 groups and was not considered to be an effect of exposure to the test material. Subchronic Toxicity Studies Subchronic oral and dermal toxicity studies were not found in the published literature and no unpublished data were submitted. Inhalation Sprague Dawley rats (n=15/sex) were exposed to Polyurethane-14 (9.6% in 54.9% ethanol neutralized with adenosine monophosphate) 6 h/day, 5 days/week, for 90 days (66 doses) in a nose-only inhalation chamber at 1.17 ± 0.3, 5.3 ± 1.1, and 40.6 ± 4.8 mg/m 3 (50, 147, 320 ppm, respectively) Polyurethane-14 and 964 ppm ethanol as a liquid droplet aerosol. 62 The particle aerodynamic diameters were 1.5 ± 2.7, 1.4 ± 2.1, and 1.9 ± 2.2 µm (±geometric standard deviation), which resulted in a respirable percentage of 97.2%, 99.6%, and 98.3%, respectively. After exposure, 5 rats/sex were allowed to recover for 13 weeks. There were no test material-related deaths or clinical observations. There were no toxicologically significant effects on mean body weights, body weight gains, feed consumption, microscopic organ evaluations (except the lung and lymph nodes), or on hematology or serum chemistry parameters. In the air and ethanol controls and the low dose group, a background syndrome was present, which was described as concurrent mild perivascular inflammatory cell infiltrate and/or subacute inflammation (mixed cell type) with interstitial pneumonia. This pattern was distinguishable from test-article induced responses. Exposure to Polyurethane-14 in the 5.3 and 40.6 mg/m 3 groups resulted in a low incidence of macroscopic findings, such as white areas in the lungs and enlarged lymph nodes, a dose-dependent increase in lung weights, accumulation of foamy alveolar macrophages, interstitial pneumonia, and acute inflammation (alveolar neutrophils) in the lung. The incidence and severity of the above findings generally decreased in the recovery animals, indicating partial recovery. A few 1.2 mg/m 3 and greater numbers of 5.3 and 40.6 mg/m 3 exposed rats had foamy macrophage accumulations in the mediastinal and/or tracheobronchial lymph nodes. Accumulation of foamy macrophages in the lung or lymph node is considered a normal physiological response necessary to remove particles from the lung, and was not considered to be an adverse health effect. Based on the results of this study, the no observed adverse effect level (NOAEL) was 1.2 mg solids/m 3. The lack of primary parenchymal toxicity and progressive lesions demonstrated that Polyurethane-14 is a polymer of low toxicity. 62 Chronic Toxicity Studies Chronic toxicity studies were not found in the published literature and no unpublished data were submitted. DEVELOPMENTAL AND REPRODUCTIVE TOXICITY (DART) STUDIES DART studies were not found in the published literature and no unpublished data were submitted. GENOTOXICITY STUDIES In Vitro Polyurethane-28 Polyurethane-28 was not mutagenic in a bacterial reverse mutation assay conducted in accordance with OECD TG 471 (Bacterial Reverse Mutation Test) using Salmonella typhimurium and Escherichia coli. 32 No further information was provided.

15 Polyurethane-35 Polyurethane-35 was not mutagenic in a bacterial reverse mutation assay conducted in accordance with OECD TG No further information was provided. Polyurethane-42 Polyurethane-42 was not mutagenic in a bacterial reverse mutation assay conducted in accordance with OECD TG 471 using S. typhimurium and E. coli. 32 No further information was provided. Polyurethane-62 In an Ames mutagenicity test of Polyurethane-62 (up to 5000 µg/plate) using S. typhimurium (strains TA98, TA100, TA1535, and TA1537) and E. coli (WPluvrA), no cytotoxicity or precipitation was observed with or without metabolic activation. There were no significant increases in the frequency of revertant colonies. In Vivo In vivo genotoxicity studies were not found in the published literature and no unpublished data were submitted. CARCINOGENICITY STUDIES Carcinogenicity studies were not found in the published literature and no unpublished data were submitted. DERMAL IRRITATION AND SENSITIZATION STUDIES Irritation In Vitro Polyurethane-35 In an in vitro dermal corrosion assay conducted in accordance with OECD TG 431 (In Vitro Skin Corrosion: Human Skin Model Test), Polyurethane-35 was not corrosive. 34 No further information was provided. Polyruethane-62 An EpiSkin assay using the reconstructed human epidermis (RhE) model conducted in accordance with OECD TG 439 (In Vitro Skin Irritation: Reconstructed Human Epidermis Test Method) was conducted on Polyurethane-62 (neat). 63 Polyrurethane-62-treated cells had a 95% survival rate. Survival greater than 50% is considered negative for dermal irritation. The control had the expected result. Animal In a skin irritation study conducted in accordance with OECD TG 404 (Acute Dermal Irritation/Corrosion), Polyurethane-35 (40% in water) was slightly irritating to the skin of rabbits (n=3). 34 The author noted that the removal of the patch was not possible without altering the response or the integrity of the epidermis in one rabbit. All irritation effects were reversible within 7 days. The irritant effects were not sufficient to warrant classification as a skin irritant. No further information was provided. Human In a cumulative irritation assay, subjects (n=29) were topically exposed to Polyurethane-14 (9.6% in 55% ethanol; 0.2 ml), 55% ethanol, distilled water, or sodium lauryl sulfate (0.075%) for 21 days. 64 Exposure was under semi-occlusive conditions for days 1-9; exposure was changed to semi-open due to irritation observed in the polyurethane and ethanol control groups. Scoring for cumulative irritation was performed every 24 h immediately prior to reapplication or until excessive irritation was noted. Polyurethane-14 produced erythema and papules in three subjects by the fourth application. After changing to semi-open patches, an additional subject was observed with erythema and papules on day 19. Under identical conditions, the ethanol control produced erythema and papules in three subjects by the third application. No to very slight erythema was observed at the majority of sites treated with Polyurethane-14 or ethanol. Sites treated with distilled water elicited a very low response. Distilled water and 0.1% sodium lauryl sulfate produced the expected results. The cumulative scores were 232 (Polyurethane solution), 208 (ethanol solution), 13 (water), and 338 (sodium lauryl sulfate) out of a possible Under the conditions of the study, both 9.6% Polyurethane-14 and the ethanol control produced mild to moderate irritation in a few subjects, with no differences in the responses to these two test articles. Sensitization In Vitro Polyurethane-62 A Direct Peptide Reactivity Assay (DPRA) measuring reactivity (percent depletion) of cysteine and lysine peptides by liquid chromatography with UV detector (LC-UV) was conducted on Polyrurethane-62 (neat). 63 This assay was conducting in accordance with the OECD Draft Proposal for Guideline, In Chemico Skin Sensitization (Direct Peptide

16 Reactivity Assay). The mean depletion rates were 0.02% for Polyrurethane-62 and 78.04% for the positive control. Depletion less than 6.38% is considered to have no or minimal reactivity and is predicted to be negative for dermal irritation. The control had the expected result. Animal Polyurethane-14 A guinea pig maximization test was conducted in accordance with OECD 406 (Skin Sensitization) on Polyurethane-14 (23.4% solids in 27% ethanol). 65 The guinea pigs (n=10/sex; control=5/sex) were injected with 0.1 ml of a 1% solution of Polyurethane-14 with and without Freund's Complete Adjuvant. After pretreatment with 10% sodium lauryl sulfate, an 8 cm 2 -patch of filter paper saturated with the test article was applied topically for 48 h. The challenge was applied to virgin sites. A 4-cm 2 -patch of filter paper saturated with the test material was applied topically for 24 h. The application sites were evaluated for erythema 48 and 72 h after application. Moderate to intense redness was observed after the intradermal injection, which was reduced to scabbing for the remainder of the induction period. No erythema was observed after challenge with the test material or the control. Under the described test conditions, the test material did not cause a sensitization reaction in guinea pigs. Polyurethane-35 In Buehler and maximization tests conducted in accordance with OECD TG 406 (Skin Sensitization), Polyurethane-35 showed no evidence of causing sensitization. 34 No further information was provided. Human In a human repeated insult patch test (HRIPT; n=50), a product containing Polyurethane-14 (10%) was diluted in distilled water to 10% (final concentration of Polyurethane-14 was 1%) and administered in open patch applications to the backs of the subjects nine times over three weeks. 66 The challenge was administered at the same concentration. No adverse reactions of any kind were observed at any time during this study. Under the conditions of this experiment, Polyurethane-14 was not a primary irritant or a primary sensitizer. In an HRIPT (n=104), Polyurethane-14 (9.61% solids in 54.9% ethanol) was administered under semi-occlusion to the upper arms of subjects three times per week for 3 weeks. 67 The challenge was administered at the same concentration. The test material was applied to the patch pad min before application to the subjects. The control was 55% ethanol. Mild erythema was observed in both the treatment and control groups in a few subjects at various evaluation periods during induction. No reaction was observed in any subject during the challenge phase. Under the test conditions described, the test material did not yield evidence of delayed contact hypersensitivity response in human subjects. OCULAR IRRITATION STUDIES In Vitro Polyurethane-14 In an EpiOcular assay, a product containing Polyurethane-14 (10%) was tested at 20% (final concentration of Polyurethane-14 was 2%). 68 The time at which the percent viability would be 50% (ET 50 ) was > 256 min. Therefore, under the conditions of this assay, the estimated Draize ocular irritation score of the test material at 100% was 0 and Polyurethane-14 can be predicted to be a non-irritant. Polyurethane-42 Polyurethane-42 was found to be a moderate irritant in a chorioallantoic membrane of the embryonic hen s egg (HET-CAM) assay and a non-irritant in a bovine corneal opacity and permeability (BCOP) assay. 32 No further details were provided. Polyurethane-62 An EpiOcular assay using the reconstructed human cell epithelial (RhCE) model (conducted in accordance with the OECD Draft Guideline titled Reconstructed Human Cornea-Like Epithelium (RhCE) Test Method for Identifying Chemicals Not Requiring Classification and Labelling for Eye Irritation or Serious Eye Damage) was conducted on Polyurethane-62 (neat). 63 Cell treated with Polyrurethane-62 had 63% survival. Survival greater than 60% is considered negative for ocular irritation. The control had the expected result. Animal In an eye irritation study conducted in accordance with OECD TG 405 (Acute Eye Irritation/Corrosion), two of the rabbits (n=3) exhibited redness in the conjunctivae in the treated eye of one rabbit 1 h after instillation of Polyurethane-35, and the remaining rabbit exhibited these effects in 1 treated eye 24 h after instillation. 34 All irritation responses were reversible within 48 h and were not sufficient to warrant classification of the polymer as an eye irritant.

17 SUMMARY This is a review of the available scientific literature and unpublished data relevant for assessing the safety of polyurethanes as used in cosmetics. According to the Dictionary, the functions of these 66 ingredients include artificial nail builders, binders, film formers, hair fixatives, plasticizers, and surface modifiers. The polyurethane ingredients in this report are copolymers, which comprise carbamate (i.e., urethane) linkages within the respective polymer backbone. Several of these polyurethane ingredients, as defined, are the polymers dispersed in water (e.g., Polyurethane-17, -35, -36, -58, -60, -61, -70, -71, and -72). The reported molecular weights of these polyurethanes are 1000 Da (Polyurethane-35) or greater. Quantification of residual monomers or precursors of concern in the final cosmetic ingredient is important for determining safety. The ingredients in this report are copolymers, each of which is synthesized, in part, from isocyanate analogs. Exposure to diisocyanates in the work place is one of the leading causes of occupational asthma. Polyurethane-36 and -60 are reported to be free of solvents and isocyanate groups; residual isocyanates are expected to react with water in the dispersion and form polyureas. As supplied, Polyurethane-36 contains approximately 1.0%-1.5% phenoxyethanol as a preservative and approximately 1.0%-1.5% trimethylamine as a neutralizing agent. Polyruethane-60 and -61 contain approximately 75 ppm methylisothiazolinone and 75 ppm benzisothiazolinone as preservatives, and approximately 1.3% and 1.5% by weight, respectively, dimethylethanolamine as a neutralizing agent. Polyurethane-62 is reported to contain no detectable residual unreacted isocyanate (HDI). According to VCRP survey data received in 2017, Polyurethane-11 was reported to be used in 315 formulations, including 303 in leave-on formulations and 12 in rinse-off formulations. The other ingredients that had reported uses were reported to be used in 33 or fewer formulations. The results of the concentration of use survey conducted by the Council in 2016 indicate that Polyurethane-1 has the highest reported maximum concentration of use; it is used at up to 15% in nail products. The highest maximum concentration of use reported for products resulting in leave-on dermal exposure is 7.5% Polyurethane-33 in the category of other skin care preparations. The rest of the ingredients that had reported concentrations of use are used at up to 9% (in nail, hair, or rinse-off dermal preparations) or less. The oral LD 50 of Polyurethane-35 in rats was reported to be 4890 mg/kg. The inhalation LC 50 of Polyurethane-14 for 4 h was 110 mg/m 3 in a whole body chamber. The oral administration of polyurethane particles at 5 and 10 mg/kg/day for 10 days generated inflammation in mice. The polyurethane particles had a diameter of 249 ± 5.7 nm and a PDI of 0.3 ± There was increased visceral fat accumulation in the treated mice in all groups (2, 5, 10 mg/kg/d) compared to controls. The lungs of mice in the 5 and 10 mg/kg/day groups showed inflammation, and inflammatory infiltrate was observed in all treatment groups. Polyurethane-14 caused alveolar histiocytosis in rats exposed for 6 h/day for 14 days in a whole body inhalation chamber at 30 and 100 mg/m 3 in a dose-dependent manner. Polyurethane-35 (concentration not specified) and Polyurethane-62 (neat) were not mutagenic in bacterial reverse mutation assays. Polyurethane-28 and -42 were not mutagenic in bacterial reverse mutation assays. Polyurethane-35 and -62 were not corrosive to human skin cells in in vitro dermal corrosion assays. In a skin irritation study, Polyurethane-35 (40% in water) had a slight irritating effect to the skin of rabbits. All irritation effects were reversible within 7 days. Polyurethane-62 (neat) was predicted to be sensitizing in a DPRA. In Buehler and maximization tests, Polyurethane-35 (concentration not specified) showed no evidence of sensitization. In a guinea pig maximization test, Polyurethane-14 (23.4% solids) was not sensitizing. In a cumulative irritation test, Polyurethane-14 (9.6%) was mildly to moderately irritating to human subjects and had similar results as ethanol (55%). In an HRIPT, Polyurethane-14 (10%) was not sensitizing and there were no adverse reactions observed at any time during the study. In another HRIPT, Polyurethane-14 (9.61% solids) was not sensitizing. In EpiOcular assays, a product containing Polyurethane-14 (10%) and Polyurethane-62 (neat) were not predicted to be ocular irritants. Polyurethane-42 was found to be a moderately irritant in a HET-CAM assay and a non-irritant in a BCOP assay. In an eye irritation study conducted with rabbits, the irritant effects were not sufficient to warrant classification of Poluyrethane-35 as an eye irritant. [To be developed.] [To be developed.] DISCUSSION CONCLUSION

18 TABLES Ingredient CAS No. Polyurethane-1 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-1 is a copolymer of isophthalic acid, adipic acid, hexylene glycol, neopentyl glycol, dimethylolpropanoic acid, and isophorone diisocyanate monomers. [Monomers:] Function(s) Binder; film former; hair fixative Polyurethane-2 Polyurethane-2 is a copolymer of hexylene glycol, neopentyl glycol, adipic acid, saturated methylene diphenyldiisocyanate (SMDI), and dimethylolpropanoic acid monomers. [Monomers:] Film former Polyurethane-4 Polyurethane-4 is a copolymer of PPG-17, PPG-34, isophorone diisocyanate and dimethylolpropanoic acid monomers. [Monomers:] Film former

19 Ingredient CAS No. Polyurethane-5 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-5 is a copolymer of hexylene glycol, neopentyl glycol, adipic acid and isophorone diisocyanate monomers. [Monomers:] Function(s) Film former Polyurethane-6 Polyurethane-6 is a copolymer of isophthalic acid, adipic acid, hexylene glycol, neopentyl glycol, dimethylolpropanoic acid, isophorone diisocyanate and bis-ethylaminoisobutyl-dimethicone monomers. [Monomers:] Binder; film former; hair fixative Polyurethane-7 Polyurethane-7 is a copolymer of hexylene glycol, neopentyl glycol, adipic acid, isophorone diisocyanate and dimethylolpropanoic acid monomers. [Monomers:] Film former

20 Ingredient CAS No. Polyurethane-8 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-8 is a copolymer of polyethylene, poly(1,4-butanediol), propanoic anhydride, isophorone diisocyanate, and isophorone diamine. [Monomers:] Function(s) Binder; film former; plasticizer Polyurethane Polyurethane-9 is the copolymer of adipic acid, toluene diisocyanate, propylene glycol, ethylene glycol and hydroxyethyl acrylate monomers. [Monomers:] Artificial nail builder Polyurethane-10 Polyurethane-10 is a copolymer of isophorone diisocyanate, cyclohexanedimethanol, dimethylolbutanoic acid, polyalkylene glycol and N-methyl diethanolamine monomers. [Monomers:] Film former; hair fixative

21 Ingredient CAS No. Polyurethane , CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-11 is a copolymer of adipic acid, 1,4-butanediol, isophthalic acid, methylene bis-(4-cyclohexylisocyanate), neopentyl glycol and trimethylolpropane monomers. [Monomers:] Function(s) Film former Polyurethane-12 Polyurethane-12 is a copolymer of trimethylolpropane, neopentyl glycol, dimethylolpropanoic acid, polytetramethylene ether glycol and isocyanato methylethylbenzene monomers. [Monomers:] Binder; film former Polyurethane-13 Polyurethane-13 is a copolymer of trimethylolpropane, dimethylol propionic acid, hexanediol, adipic acid, polyester diol, and isocyanato methylethylbenzene monomers. [Monomers:] Binder; film former

22 Ingredient CAS No. Polyurethane-14 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-14 is a copolymer of isophorone diisocyanate, dimethylol propionic acid, and 4,4'-isopropylidenediphenol reacted with propylene oxide, ethylene oxide and PEG/PPG-17/3. [Monomers:] Function(s) Film former; hair conditioning agent Polyurethane-15 Polyurethane-15 is a copolymer of isophorone diisocyanate, adipic acid, triethylene glycol, and dimethylolpropanoic acid. [Monomers:] Film former Polyurethane-16 Polyurethane-16 is a cross-linked condensation polymer formed from the addition polymerization of 2 [stoichiometric equivalents] of hexamethylene diisocyanate with 1 [stoichiometric equivalent] of polycaprolactonetriol terminated with 3 hydroxyl groups. [Members:] Anticaking agent; emulsion stabilizer; film former; slip modifier; surface modifier

23 Ingredient CAS No. Polyurethane , CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-17 is a complex polymer made by neutralizing Hexylene Glycol/Neopentyl Glycol/Adipic Acid/SMDI/DMPA Copolymer with triethylamine in the presence of water. Further chain extension is achieved by reacting the polymer with ethylenediamine. [Monomers/reactants:] Function(s) Film former Polyurethane-18 Polyurethane-18 is a complex polymer formed by the reaction of m-tetramethylene diisocyanate, polybutylene glycol and dimethylol propionic acid. The pre-polymer is neutralized with triethylamine and condensed with a combination of hydrazine and C1-8 diamines to achieve chain extension. [Monomers/reactants:] Binder; hair fixative Polyurethane-19 Polyurethane-19 is a complex polymer formed by the reaction of m-tetramethylene diisocyanate, neopentyl glycol, trimethylol propane, dimethylol propionic acid and a polyester formed by condensing neopentyl glycol and adipic acid. The pre-polymer is neutralized with triethylamine and condensed with a combination of hydrazine and C1-8 diamines to achieve chain extension. [Monomers/reactants:] Binder; hair fixative

24 Ingredient CAS No. Polyurethane-20 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-20 is a complex polymer formed by the reaction of isophorone diisocyanate (IPDI), and two polyols: The first polyol is polybutylene glycol containing approximately 12 butylene glycol units. The second polyol is formed by the reaction of approximately 10 [stoichiometric equivalents] of caprolactone [with 1 stoichiometric equivalent of] neopentyl glycol. The urethane polymer is then reacted with isophorone diamine to build molecular weight and the resulting polymer is capped with ethanol to eliminate residual isocyanate groups. [Monomers/reactants:] Function(s) Binder; film former; plasticizer Polyurethane-21 Polyurethane-21 is a urethane copolymer prepared by reacting isophorone diisocyanate (IPDI) with dimethylol propionic acid (DMPA), a polyester of hexanedioic acid, isophthalic acid and 1,6-hexanediol, and ethylene diamine, neutralized with triethylamine. [Monomers/reactants:] Film former Polyurethane-23 Polyurethane-23 is a copolymer of adipic acid, 1,4 butanediol, diphenylmethane diisocyanate, and trimethylolpropane. [Monomers:] Film former

25 Ingredient CAS No. Polyurethane-24 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-24 is a complex polymer prepared via the following multi-step synthesis. First, isophorone diisocyanate (IPDI) is reacted with three different polyols: poly(1,4-butanediol)-30, 1,4-butanediol, and dimethylol butanoic acid. This pre-polymer is then reacted with a reagent formed by the reaction between aminpropyl triethoxysilane and lauryl acrylate. The resulting polymer is subsequently chain extended by reaction with isophorone diamine in aqueous solution to produce Polyurethane-24. [Monomers/reactants:] Function(s) Hair conditioning agent; hair fixative Polyurethane-25 Polyurethane-25 is a complex polymer formed by the reaction of dihydroxypolyoxobutylene (degree of polymerization 12-30), dimethylol propionic acid, meta-tetramethylenexylenediisocyanate, isophoronediisocyanate and trimethoylpropane. The prepolymer is neutralized with triethylamine and chain extended with C1-8 alkyl diamine. [Monomers/reactants:] Binder; hairwaving/ straightening agent; skinconditioning agent-occlusive

26 Ingredient CAS No. Polyurethane , CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-26 is a complex polymer that is formed by the reaction of polyperfluoroethoxymethoxy difluorohydroxyethyl ether and isophorone diisocyanate (IPDI) to form a prepolymer. The prepolymer is further reacted with 3-diethylamino-1,2-propanediol followed by the capping of any residual isocyanate groups with 2-ethyl-1-hexanol. The resulting polymer is neutralized with acetic acid. [Monomers/reactants:] Function(s) Film former; hair conditioning agent; skin protectant Polyurethane Polyurethane-27 is a complex polymer that is formed by the reaction of polyperfluoroethoxymethoxy difluorohydroxyethyl ether and isophorone diisocyanate (IPDI) to form a prepolymer. The prepolymer is further reacted with the triethylamine salt of 3-hydroxy-2-(hydroxymethyl)-2-methyl-1-propionic acid. [Monomers/reactants:] Film former; hair conditioning agent; skin protectant Polyurethane-28 Polyurethane-28 is a complex polymer formed by the reaction of bis-hydroxyethoxypropyl dimethicone with isophorone diisocyanate (IPDI) and Sorbitan Isostearate. [Monomers/reactants:] Surfactantemulsifying agent

27 Ingredient CAS No. Polyurethane-29 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-29 is a copolymer of methyl diethanolamine (MDEA), polytetramethylene ether glycol (PTMEG), hexamethylene diisocyanate (HDI), and saturated methylene diphenyldiisocyanate (SMDI). [Monomers:] Function(s) Emulsion stabilizer; film former; hair conditioning agents; hair fixative Polyurethane-32 Polyurethane-32 is a copolymer of 1,4-butanediol, ethylenediamine, hexamethylene diisocyanate, isophorone diisocyanate, and sodium N-(2-aminoethyl)-3-aminoethane sulfonate monomers. [Monomers:] Binder Polyurethane-33 Polyurethane-33 is a complex polymer formed by reacting dimethylolpropionic acid and a polyester composed of adipic acid, hexylene glycol, neopentyl glycol with methylene dicyclohexyldiisocyanate (SMDI) to form a prepolymer. The prepolymer is neutralized with triethylamine and then chain-extended with hydrazine. [Monomers/reactants:] Binder

28 Ingredient CAS No. Polyurethane-34 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-34 is a complex polymer that is formed in a multi-step reaction. A copolymer of hexanediol, neopentyl glycol, and adipic acid is reacted with hexamethylene diisocyanate. The resulting polymer is further reacted with N-(2-aminoethyl)-3-aminoethanesulfonic acid and ethylenediamine. [Monomers:] Binder Function(s) Polyurethane-35 Polyurethane-35 is a complex urethane polymer that is made by reacting a polyester pre-polymer consisting of adipic acid, hexanediol, and neopentyl glycol with dicyclohexylmethane diisocyanate. The resulting urethane polymer is further reacted with sodium N-(2-aminoethyl)-3-aminoethanesulfonate and ethylenediamine and then dispersed into water. [Monomers:] Binder Polyurethane-36 Polyurethane-36 is a copolymer of isophorone diisocyanate (IPDI), PPG-15-20, and dimethylol propionic acid, neutralized in the presence of water with triethylamine. Further chain extension is achieved by reacting the polymer with hydrazine. [Monomers/reactants:] Film former

29 Ingredient CAS No. 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-39 Polyurethane-39 is a copolymer of PEG-140 and hexamethylene diisocyanate end-capped with C12-14 Pareth-10, C16-18 Pareth-11, and C18-20 Pareth-11. [Monomers:] Function(s) Hair conditioner Polyurethane-40 Polyurethane-40 is a copolymer of Adipic Acid, dimethylolpropanoic acid (DMPA), isophthalic acid and saturated methylene diphenyldiisocyanate (SMDI) monomers. [Monomers:] Film former; surface modifier Polyurethane-41 Polyurethane-41 is a copolymer of 1,4-Butanediol, polytetramethylene glycol and isophorone diisocyanate (IPDI) monomers. [Monomers:] Film former; hair conditioning agent; skin protectant Polyurethane Polyurethane-42 is a copolymer of Di-C12-13 Alkyl Tartrate, Hydrogenated Dilinoleyl Alcohol and isophorone diisocyanate. [Monomers:] Film former Polyurethane-43 Polyurethane-43 is the polymer that conforms generally to the formula: Film former

30 Ingredient CAS No. Polyurethane-44 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-44 is a copolymer of hexanedioic acid, hexamethylene diisocyanate (HDI), trimethylolpropane, 3-methyl-1,5-pentanediol (MPD), and caprolactone monomers. [Monomers:] Function(s) Anticaking agent; bulking agent Polyurethane-45 Polyurethane-45 is a polymer made by the reaction of epsilon caprolactone and Trimethylolpropane with the cyclic trimer of hexamethylene diisocyanate. [Monomers:] Film former Polyurethane-46 Polyurethane-46 is a complex urethane-based polymer. Initially, a pre-polymer is made by the reaction of isophorone diisocyanate (IPDI) with three different polyols. The polyols are poly(1,4-butanediol)-30, methoxy PEG-20 terminated with a 2,2 dimethyol butoxy group, and Methyl Diethanolamine. The pre-polymer is capped with the product formed by the reaction of lauryl acrylate and aminopropyl triethoxysilane (via Michael addition), and finally the amine groups from the methyl diethanolamine are quaternized with dimethylsulfate. [Monomers/reactants:] Hair conditioning agent

31 Ingredient CAS No. Polyurethane-47 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-47 is a copolymer made by reacting a polyester polyol with isophorone diisocyanate (IPDI) and then bis-hydroxypropyl dimethicone. The polyester polyol is made by reacting Epoxidized Soybean Oil with a polyol. [Soybean oil consists essentially of triglycerides of oleic, linoleic, linolenic and saturated acids. Monomers:] Function(s) Binder; film former; hair fixative; skinconditioning agent-occlusive Polyurethane-48 Polyurethane-48 is a copolymer of hexanediol, neopentyl glycol, adipic acid, isophorone diisocyanate, isophorone diamine and sodium N-(2-aminoethyl)-3-aminoethanesulfonic acid monomers. [Monomers:] Film former Polyurethane-49 Polyurethane-49 is a copolymer of poly(1,4-butanediol), 1,3-bis(isocyanatomethyl)benzene, ethoxylated 4,4'-isopropylidenediphenol and 4-hydroxybutyl acrylate. [Monomers:] Artificial nail builder

32 Ingredient CAS No. Polyurethane-50 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-50 is a copolymer of poly(1,4-butanediol), 1,3-bis(isocyanatomethyl)benzene, ethoxylated 4,4'-isopropylidenediphenol and 2-hydroxyethyl acrylate. [Monomers:] Function(s) Artificial nail builder Polyurethane-51 Polyurethane-51 is a copolymer made by reacting 2-hydroxyethyl acrylate, 2-hydroxyethyl methacrylate (HEMA), 1,2-Butanediol, poly(1,4-butanediol) and 1,3-bis(isocyanatomethyl)cyclohexane. [Monomers:] Artificial nail builder Polyurethane-52 Polyurethane-52 is a copolymer of poly(1,4-butanediol), isophorone diisocyanate, PEG-6, 2-hydroxyethyl acrylate and hydroxypropyl methacrylate. [Monomers:] Artificial nail builder

33 Ingredient CAS No. Polyurethane-53 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-53 is a copolymer of poly(1,4-butanediol), isophorone diisocyanate and 2-hydroxypropyl acrylate. [Monomers:] Function(s) Artificial nail builder Polyurethane-54 Polyurethane-54 is a copolymer of poly(1,4-butanediol)-4, 1,2-butanediol, 3-(acryloyloxy)-2-hydroxypropyl methacrylate and isophorone diisocyanate. [Monomers:] Artificial nail builder Polyurethane-55 Polyurethane-55 is the polymer formed by the reaction of Poly(1,4-Butanediol)-28, Poly(1,4-Butanediol)-14, and 1,3-bis(isocyanatomethy[l])cyclohexane. The polymer is capped with 4-hydroxybutyl acrylate. [Monomers:] Artificial nail builder Polyurethane Polyurethane-56 is a copolymer of 4,4'-Isopropylidenediphenol, poly(1,4-butanediol)-3, Hydroxypropyl Methacrylate, and isophoronediisocyanate (IPDI). [Monomers:] Binder

34 Ingredient CAS No. Polyurethane , CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-57 is a copolymer of Ethylene Carbonate, Hexanediol, isophorone diisocyanate (IPDI), 1,5-pentanediol and hydroxyethyl acrylate. [Monomers:] Binder Function(s) Polyurethane-58 Polyurethane-58 is a complex polymer made by reacting polytetramethylene ether glycol, 2,2-dimethylolpropionic acid and meta-tetramethylenexylenediisocyanate to form a prepolymer. The prepolymer is dispersed in water with 2-dimethylamino-2-methylpropanol as neutralizer and chain-extended with ethylenediamine. [Monomers/reactants:] Film former; hair fixative; plasticizer; skin protectant; skinconditioning agent-occlusive Polyurethane-59 Polyurethane-59 is a copolymer of Ethylhexylglycerin, PEG-240, tetradecyloctadeceth-100, and hexamethylenediisocyanate. [Monomers:] Dispersing agentnonsurfactant; emulsion stabilizer; viscosity increasing agentaqueous

35 Ingredient CAS No. Polyurethane-60 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-60 is the complex polymer made by first reacting saturated methylene diphenyldiisocyanate (SMDI), dimethyl aminopropylamine (DMAPA), isopropylidenediphenoxypropanol, and dimethylcarbonate-1,6-hexanediol to form a prepolymer, followed by dispersion in water with dimethylethanolamine and subsequent chain extension with ethylenediamine. [Monomers/reactants:] Function(s) Nail conditioning agent Polyurethane-61 Polyurethane-61 is the complex polymer made by first reacting saturated methylene diphenyldiisocyanate (SMDI), dimethyl aminopropylamine (DMAPA), isopropylidenediphenoxypropanol and the polyester polyol derived from isophthalic acid/1,6-hexanediol/adipic acid to form a prepolymer, followed by dispersion in water with triethylamine and subsequent chain extension with ethylenediamine. [Monomers:] Nail conditioning agent Polyurethane-62 Polyurethane-62 is a copolymer of hexamethylene diisocyanate, PEG-200, Methyl Gluceth-10 and Trideceth-6 monomers, end-capped with a fatty alcohol containing 16 to 20 carbons. [Monomers:] Binder; viscosity increasing agentaqueous

36 Ingredient CAS No. Polyurethane-63 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-63 is a complex polymer formed by first reacting dimethylolpropionic acid (DMPA) and isophorone diisocyanate (IPDI) with a polyester diol made with Adipic Acid, isophthalic acid, and Hexanediol. The resulting prepolymer is then neutralized with triethylamine and finally, chain-extended with ethylenediamine. [Monomers/reactants:] Function(s) Film former Polyurethane-64 Polyurethane-64 is a urethane copolymer formed by a multi-step reaction. First, isophorone diisocyanate (IDPI) is reacted with a mixture of polytetrahydrofurans (PTHFs), also known as polybutylene glycols or polytetramethylene glycols. One of the PTHFs contains an average of 14 mols and the other an average of 28 mols of butylene glycol. The resulting polyurethane is reacted with 4,4'-methylenebis(cyclohexylamine) and finally the residual isocyanate groups are reacted with ethanol. [Monomers/reactants:] Film former Polyurethane-65 Polyurethane-65 is a complex urethane copolymer made by reacting Isophorone Diisocyanate (IPDI) with a combination of dimethylolpropionic acid (DMPA) and a copolymer composed of Neopentyl Glycol and Adipic Acid. The resulting polymer is chain extended with ethylene diamine and neutralized with trimethylamine. [Monomers:] Artificial nail builders Polyurethane-66 Polyurethane-66 is a urethane polymer formed by reacting a polymer of 1,4-butanediol that contains an average of 28 moles of butylene oxide with a combination of isophorone diisocyanate (IPDI) and 1,3-bis(isocyanomethyl)cyclohexane. The polymer is end-blocked with hydroxybutyl acrylate. [Monomers:] Binder

37 Ingredient CAS No. Polyurethane , CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-67 is a complex polymer made by reacting the trimer of hexamethylene diisocyanate (HDI isocyanurate trimer) with a copolymer that is made by reacting PPG-3 Butyl Ether with a mixture of epsilon-caprolactone and valerolactone. Some of the remaining isocyanate groups from the first reaction are reacted with Decyl Alcohol and in a third step, the remaining isocyanate groups are reacted with N-(3-aminopropyl)imidazole. [Monomers:] Function(s) Surface modifier Polyurethane Polyurethane-68 is a complex polymer that is made by reacting the trimer of hexamethylene diisocyanate (HDI isocyanurate trimer) with PPG-30 Butyl Ether. Some of the remaining isocyanate groups from the first reaction are reacted with 2-pyridylethanol and in a third step, the remaining isocyanate groups are reacted with 1-isobutanol. [Monomers:] Surface modifier Polyurethane Polyurethane-69 is a copolymer of Isopropylidenediphenyl Bisoxyhydroxypropyl Methacrylate, Isophorone Diisocyanate (IPDI), and Di-C12-13 Alkyl Tartrate, end-capped with hydroxyethyl methacrylate (HEMA). [Monomers:] Skin-conditioning agentmiscellaneous

38 Ingredient CAS No. Polyurethane-70 1, CIR Staff Table 1. Definitions, idealized structures, and functions of the ingredients in this safety assessment. Definition & Monomers Structures Polyurethane-70 is a complex polymer that is formed by a multi-step synthesis. First, a mixture of polyester diols (a copolymer of Adipic Acid and 1,4-Butanediol; and a copolymer of Adipic Acid and Hexanediol; and Neopentyl Glycol and 1,4-Butanediol are reacted with Isophorone Diisocyanate and hexamethylene diisocyanate (HDI). The resulting urethane polymer is reacted with the sodium salt of N-(2-aminoethyl)-3-aminoethanesulfonic acid, ethylene diamine, and Diethanolamine. The final polymer is dispersed in water. [Monomers/reactants:] Function(s) Film former Polyurethane-71 Polyurethane-71 is a complex polymer that is formed by a multi-step synthesis. First, a polyester diol made by condensing Hexanediol, Adipic Acid, and isophthalic acid is reacted with isophorone diisocyanate and dimethylolpropionic acid. The resulting pre-polymer is neutralized with Triethylamine. The neutralized polymer is dispersed in water with Isopropanolamine and ethylene diamine. [Monomers/reactants:] Binder; film former Polyurethane Polyurethane-72 is a urethane polymer made by reacting Hydrogenated Acetophenone/Oxymethylene Copolymer with Isophorone Diisocyanate (IPDI), dimethylolpropanoic acid, and Dimethyl MEA. The resulting polymer is dispersed in water. [Monomers/reactants:] Binder; film former; nail conditioning agent

39 Table 2. Previous reports on precursors, monomers, moieties, and related ingredients of polyurethanes in this safety assessment. Moiety Conclusion; year Highest concentrations of use 1 Relevant to Reference Acetic Acid Safe as used; 2012 Acetic Acid-0.3% in nail products Polyurethane Isopropyl Alcohol-100% Methyl Acetate-60% Adipic Acid; Hexanedioic Acid Safe as used; Alkyl PEG Ethers Butylene Glycol, Hexylene Glycol 1,4-Butanediol; 1,5- Pentadiol; Hexanediol Safe when formulated to be non-irritating; 2012 Safe as used; 1985, 2006 Insufficient Data Announcement; 2016 Adipic Acid-18% in rinse-off, % in leave-on products Succinic Acid-26% in rinse-off; Disodium Succinate- 0.4% in leave-on products C12-13 Pareth 3-32% in products diluted for the bath, 25% in leave-on products Hexylene Glycol-4% in rinse-off; 6% in leave-on products Butylene Glycol-12% in rinse-off; 89% in leave-on products 1,4-Butanediol and 1,5-Pentadiol-none reported Hexanediol-0.5% in leave-on; 0.45% in rinse-off products Propanediol-39.9% in leave-on products 1,2-Butanediol Safe as used; ,2-Butanediol-none reported 1,2-Hexanediol-10% in leave-on products Diethanolamine Safe when Diethanolamine-0.3% in rinse-off; 0.06% in leave-on formulated to be products non-irritating; 2011 Ethylhexylglycerin Safe as used; 2013 Ethylhexylglycerin-2% in leave-on; 8% in rinse-off products Batyl Alcohol-3% in leave-on products Glycine Soja (Soybean) Oil HDI Polymers Bis- Hydroxyethoxypropyl Dimethicone Hydroxyethyl Acrylate/Sodium Acryloyldimethyl Taurate Copolymer Hydroxypropyl Methacrylate; Isopropylidenediphenyl Bisoxyhydroxypropyl Methacrylate; HEMA (Hydroxyethyl Methacrylate) Isopropanolamine Isostearic Acid (Sorbitan Isostearate) Polyurethane-1, -2, -5, -6, -7, -9, -11, -13, -15, -17, -19, -21, -23, -33, -34, -35, -40, -48, -61, -63, -65, -70, -71 Polyurethane-39, -62 Polyurethane-1, -2, -5, -6, -7, -17, -33 Polyurethane-8, -11, -13, -21, -23, -24, -32, -34, -35, -41, -46, -48, -49, -50, -51, -52, -53, -55, -56, -57, -60, -61, -63, -66, -70, -71 Polyurethane-51, -54 Polyurethane-10, -29, -46, -70 Polyurethane-59 Safe as used; 2011 Glycine Soja (Soybean) Oil-95% in leave-on products Polyurethane are safe as used, 2 insufficient data; 2016 Safe as used; 2014 Safe as used; 2016 Safe in nail enhancement products when skin contact is avoided Safe as used if not used in products containing N- nitrosating agents;1987, 2006 Safe as used; 2014 HDI/Trimethylol Hexyllactone Crosspolymer-31% in leave-on products Highest reported residual HDI < 100 ppm Bis-Hydroxyethoxypropyl Dimethicone-12% in leaveon products Stearoxy Dimethicone-22% in rinse-off products Cetyl PEG/PPG-10/1 Dimethicone-15% in leave-on products Hydroxyethyl Acrylate/ Sodium Acryloyldimethyl Taurate Copolymer-4.3% in rinse-off, 3.6% in leave-on products Hydroxypropyl Methacrylate-25% in nail products Isopropylidenediphenyl Bisoxyhydroxypropyl Methacrylate-none reported Methoxydiglocol Methacrylate and Ethoxyethyl Methacryalte-85% in nail products HEMA-30% in nail products Isopropanolamine-1% in leave-on hair products Sorbitan Isostearate-6.5% in leave-on; 1% in rinse-off products Sorbitan Triisostearate-9.1% in leave-on products Methyl Gluceth-10 Safe as used; 2013 Methyl Gluceth-10-15% in leave-on and rinse-off products PEGs; Triethylene Glycol Triethylene Glycol PEG-200-none reported-85% in leave-on hair products; and PEGs 4 are 45% in other personal care products safe as used, 2010 Polyethylene Safe as used; 2007, 2015 Polyethylene-67.6% in leave-on products Hydrogenated Polyisobutene 95% in leave-on products All Polyurethane-28 Polyurethane-9 Polyurethane-51, -52, -54, -56, -69 Polyurethane-71 Polyurethane-28 Polyurethane-62 Polyurethane-14, -39, -46, -52, -59, -62 Polyurethane ,4 17, , ,

40 Table 2. Previous reports on precursors, monomers, moieties, and related ingredients of polyurethanes in this safety assessment. Moiety Conclusion; year Highest concentrations of use 1 Relevant to Reference PPG-3 Butyl Ether; PPG- 30 Butyl Ether Propylene Glycol; PPGs Toluene Safe when formulated to avoid irritation; 2001 Insufficient Data Announcement; 2016 Propylene Glycol and PPGs 3 are safe when formulated to be non-irritating, 2012 Safe in the present practices of use; 1987, 2006 PPG-3 Butyl Ether and PPG-30 Butyl Ether none reported PPG-40 Butyl Ether -60.5% in leave-on hair products PPG-14 Butyl Ether-17.5% leave-on dermal products Propylene Glycol-73% in leave-on products; 99% in products diluted for the bath Toluene-26% in nail products 1 Highest concentration of ingredient of interest and the highest concentration among the ingredients in the report. Polyurethane-67, -68 Polyurethane-4, -9, -14, -36, -67, -68 Polyurethane-9 16, ,21 Table 3. Precursors, monomers, moieties, and related ingredients of polyurethanes in this safety assessment that are either cosmetic ingredients that have not been reviewed or chemicals that are not cosmetic ingredients. 1 Acetophenone* N-(3-Aminopropyl)imidazole Aminpropyl triethoxysilane bis-ethylaminoisobutyl-dimethicone Butylene oxide Caprolactone* monomers Cyclohexanedimethanol* Decyl Alcohol* Di-C12-13 Alkyl Tartrate* 3-Diethylamino-1,2-propanediol Dihydroxypolyoxobutylene Dilinoleyl Alcohol* 2-Dimethylamino-2-methylpropanol Dimethyl aminopropylamine (DMAPA) Dimethylcarbonate-1,6-hexanediol Dimethyl MEA* Dimethylolbutanoic acid Dimethylolpropanoic acid Dimethylolpropionic acid (DMPA) Dimethylsulfate Ethoxylated 4,4'-isopropylidenediphenol 2-Ethyl-1-hexanol Ethylene Carbonate* Ethylene diamine Ethylene glycol* Ethylene oxide Ethylenediamine Hydrazine 4-Hydroxybutyl acrylate 3-Hydroxy-2-(hydroxymethyl)-2-methyl-1- propionic acid Hydroxypropyl dimethicone* Hydroxybutyl acrylate Hydroxyethyl acrylate 1-Isobutanol Isophthalic acid Isophorone diamine 4,4'-Isopropylidenediphenol* Isopropylidenediphenoxypropanol Lauryl Acrylate* 4,4'-Methylenebis(cyclohexylamine) N-(2-Aminoethyl)-3-aminoethanesulfonic Neopentyl glycol* acid Oxymethylene Polyalkylene glycol Polybutylene glycol Polycaprolactonetriol Polyester diol Polyperfluoroethoxymethoxy Difluorohydroxyethyl Ether* Polytetrahydrofurans (PTHFs) Polytetramethylene ether glycol Polytetramethylene glycol Propanoic anhydride Propylene oxide 2-Pyridylethanol Sodium N-(2-aminoethyl)-3-aminoethane Tetradecyloctadeceth Trimethylamine* sulfonate Trimethylolpropane* Valerolactone* *Cosmetic ingredient or closely related to a cosmetic ingredient listed in the Dictionary that has not been reviewed. Table 4. Diisocyanates used in manufacturing polyurethanes in this safety assessment. 1 bis(isocyanatomethyl)benzene Diphenylmethane diisocyanate Hexamethylenediisocyanate Isophorone diisocyanate (IPDI) m-tetramethylene diisocyanate Saturated methylene diphenyldiisocyanate (SMDI) 1,3-bis(Isocyanatomethyl)cyclohexane Cyclic trimer of hexamethylene diisocyanate Isocyanato methylethylbenzene Methylene bis-(4-cyclohexylisocyanate) meta-tetramethylenexylenediisocyanate Toluene diisocyanate

41 Table 5. Chemical and physical properties of polyurethanes. Property Value Reference Polyurethane-14 Molecular Weight g/mol > ,000-35,000 Water Solubility o C & ph Miscible Polyruethane-28 Molecular Weight g/mol >30,000 Polyurethane-35 Molecular Weight g/mol >1000 Disassociation constants (pka, o C pka est. Polyurethane-36 a Physical Form Liquid Color Whitish Molecular Weight g/mol >50, o C ~1.04 Viscosity kg/(s m)@ o C Vapor pressure 20 o C Melting Point o C ~0 Boiling Point o C 100 Water Solubility o C & ph Completely miscible Polyurethene-42 Molecular Weight g/mol >36,000 Polyurethane-60 b Physical Form Liquid Color Light yellow Molecular Weight g/mol >50, o C ~1.06 Viscosity kg/(s m) Vapor pressure 20 o C Melting Point o C ~0 Boiling Point o C 100 Water Solubility Completely miscible Polyurethane-61 c Physical Form Liquid Color Light yellow Molecular Weight g/mol >50,000 Density/Specific 20 o C ~1.05 Viscosity kg/(s m) Vapor pressure 20 o C Melting Point o C ~0 Boiling Point o C 100 Water Solubility o C & ph Completely miscible Polyurethane ,61 31 Physical Form Powder Color White to off white 38 Molecular Weight g/mol >70, ~100, Density kg/m 23 o C Water Solubility Dispersible 38 est.=estimated a Polyurethane-36 in an aqueous dispersion with approximately 1.0%-1.5% phenoxyethanol and triethylamine. b Polyurethane-60 in an aqueous dispersion with approximately 75 ppm methylisothiazolinone and benzisothiazolinone and 1.5% triethylamine. c Polyurethane-61 in an aqueous dispersion with approximately 75 ppm methylisothiazolinone and benzisothiazolinone and 1.5% triethylamine

42 Table 6. Methods of manufacture for polyurethanes. Ingredient Method of manufacture/monomers Termination Notes Reference Polyurethane-28 Condensation of an isocyanate component and Addition of ethyl alcohol 32 molecules containing hydroxyl groups (sorbitan isostearate) Polyurethane-42 Condensation of an isocyanate component and Addition of ethyl alcohol 32 molecules containing hydroxyl groups (di C12 13 alkyl dilinoleyl alcohol) Polyurethane-62 A proprietary anhydrous reaction The resulting solid is then ground to the desired particle size. 39 Polyurethane-69 Condensation of an isocyanate component with 2 H 32 di C12 13 alkyl tartr added to react with terminal isopropylidenediphenyl bisoxyhydroxypropyl methacrylate. isocyanate groups. The reaction is carried on until free isocyanate groups are not detected. Table 7. Polyurethanes that are reported to be supplied as dispersions. Ingredient Percentage Solids Solvent/medium Reference Polyurethane-14 20% Water 31 Polyruethane-28 25% Cyclopentasiloxane 32 Polyurethane-35 40% Water 34 Polyurethane %-41.0% Water, approximately 1.0%-1.5% (by weight) phenoxyethanol as a preservative 35 and approximately 1.0%-1.5% triethylamine as a neutralizing agent Polyurethane % Isododecane and ethanol 32 Polyurethane %-39.0% Water, approximately 75 ppm methylisothiazolinone and benzisothiazolinone 36 as preservatives, and approximately 1.3% (by weight) dimethylethanolamine as a neutralizing agent Polyurethane %-40.0% Water, approximately 75 ppm methylisothiazolinone and 75 ppm 37 benzisothiazolinone as preservatives, and approximately 1.3% and 1.5% by weight, respectively, dimethylethanolamine as a neutralizing agent Polyurethane-69 66% Butyl acetate and ethanol 32 Use type Table 8. Frequency of use according to duration and exposure of polyurethanes. 41,42 Uses Maximum Concentration (%) Uses Maximum Concentration (%) Uses Maximum Concentration (%) Uses Maximum Concentration (%) Polyurethane-1 Polyurethane-2 Polyurethane-6 Polyurethane-7 Total/range NR Duration of use a Leave-on NR Rinse-off NR 3 NR NR NR Diluted for (bath) use NR NR NR NR NR NR NR NR Exposure type Eye area NR NR NR NR NR Incidental ingestion NR NR NR NR NR NR NR NR Incidental Inhalation-sprays 4;2 b b ; 3 c NR NR NR Incidental inhalation-powders NR NR 3 c 0.63; 1.1 c NR NR 6 NR Dermal contact NR NR 14 NR Deodorant (underarm) NR NR NR NR NR NR NR NR Hair-noncoloring NR NR NR NR Hair-coloring NR 0.15 NR NR NR NR NR NR Nail NR 15 NR 9 NR NR NR NR Mucous Membrane NR NR NR NR NR NR NR NR Baby NR NR NR NR NR NR NR NR

43 Table 8. Frequency of use according to duration and exposure of polyurethanes. 41,42 Maximum Concentration (%) Uses Maximum Concentration (%) Uses Maximum Concentration (%) Uses Maximum Concentration (%) Use type Uses Polyurethane-8 Polyurethane-9 Polyurethane-10 Polyurethane-11 Total/range 1 NR 1 NR NR Duration of use Leave-on 1 NR 1 NR NR Rinse-off NR NR NR NR NR NR Diluted for (bath) NR NR NR NR NR NR NR use Exposure type Eye area NR NR NR NR NR Incidental ingestion NR NR NR NR NR NR Incidental Inhalation-sprays NR NR NR NR NR 3 c 2; 1 b ; 2 c Incidental inhalation-powders NR NR NR NR NR NR 2; 2 c 3-3.2; c Dermal contact 1 NR 1 NR NR Deodorant (underarm) NR NR NR NR NR NR NR NR Hair-noncoloring NR NR NR NR NR 3 NR NR Hair-coloring NR NR NR NR NR NR NR Nail NR NR NR NR NR NR Mucous Membrane NR NR NR NR NR NR Baby NR NR NR NR NR NR NR NR Polyurethane-14 Polyurethane-15 Polyurethane-16 Polyurethane-18 Total/range Duration of use Leave-on Rinse-off NR NR NR NR NR NR Diluted for (bath) use NR NR NR NR NR NR NR NR Exposure type Eye area NR 0.62 NR NR NR NR NR NR Incidental NR NR NR NR NR NR NR ingestion Incidental 10; 15 b ; Inhalation-sprays c NR NR NR NR 3; 7 b NR Incidental inhalation-powders NR NR NR NR NR NR Dermal contact NR Deodorant (underarm) NR NR NR NR NR NR NR NR Hair-noncoloring NR NR NR NR Hair-coloring NR 0.63 NR NR NR NR NR NR Nail NR NR NR NR NR NR NR NR Mucous Membrane NR NR NR NR NR NR NR Baby NR NR NR NR NR NR NR NR

44 Table 8. Frequency of use according to duration and exposure of polyurethanes. 41,42 Maximum Concentration (%) Uses Maximum Concentration (%) Uses Maximum Concentration (%) Uses Maximum Concentration (%) Use type Uses Polyurethane-24 Polyurethane-33 Polyurethane-34 Polyurethane-35 Total/range NR Duration of use Leave-on NR Rinse-off NR NR NR NR 1 NR NR NR Diluted for (bath) NR NR NR NR NR NR NR NR use Exposure type Eye area NR NR Incidental ingestion NR NR NR NS NR 2.9 NR NR Incidental ; NR NR 0.04 NR c Inhalation-sprays 0.5 NR NR Incidental inhalation-powders NR NR NR NR NR NR NR 0.84 d Dermal contact NR NR NR Deodorant (underarm) NR NR NR NR NR NR NR NR Hair-noncoloring NR NR 0.04 NR NR NR Hair-coloring NR NR NR NR NR NR NR NR Nail NR NR NR NR 1 NR Mucous Membrane NR NR NR NR NR 2.9 NR NR Baby NR NR NR NR NR NR NR NR Polyurethane-39 Polyurethane-40 Polyurethane-46 Polyurethane e Total/range 8 NR 9 NR NR NS Duration of use Leave-on 5 NR 9 NR NR NR 16 NS Rinse-off 3 NR NR NR NR NS Diluted for (bath) use NR NR NR NR NR NR NR NS Exposure type Eye area NR NR 3 NR NR NR 2 NS Incidental ingestion NR NR NR NR NR NR 1 NS Incidental Inhalation-sprays 3 b NR 2 b NR NR NR 3; 1 b ; 2 c NS Incidental inhalation-powders NR NR 1 NR NR NR 2 c NS Dermal contact 1 NR 9 NR NR NR 5 NS Deodorant (underarm) NR NR NR NR NR NR NR NS Hair-noncoloring 7 NR NR NR NR NS Hair-coloring NR NR NR NR NR NR NR NS Nail NR NR NR NR NR NR 3 NS Mucous Membrane NR NR NR NR NR NR 1 NS Baby NR NR NR NR NR NR NR NS NR = Not Reported; NS = Not surveyed; Totals = Rinse-off + Leave-on + Diluted for Bath Product Uses. Note: Because each ingredient may be used in cosmetics with multiple exposure types, the sum of all exposure type uses may not equal the sum total uses. a Because each ingredient may be used in cosmetics with multiple exposure types, the sum of all exposure types may not equal the sum of total uses. b It is possible these products may be sprays, but it is not specified whether the reported uses are sprays. c Not specified whether a powder or a spray, so this information is captured for both categories of incidental inhalation. d It is possible these products may be powders, but it is not specified whether the reported uses are powders. e Not a cosmetic ingredient in the Dictionary but reported in the VCRP.

45 Table 9. Polyurethanes that have no reported uses in the VCRP or from an Industry survey. 41,42 Polyurethane-4 Polyurethane-5 Polyurethane-12 Polyurethane-13 Polyurethane-17 Polyurethane-19 Polyurethane-20 Polyurethane-21 Polyurethane-23 Polyurethane-25 Polyurethane-26 Polyurethane-27 Polyurethane-28 Polyurethane-29 Polyurethane-32 Polyurethane-36 Polyurethane-41 Polyurethane-42 Polyurethane-43 Polyurethane-44 Polyurethane-45 Polyurethane-47 Polyurethane-48 Polyurethane-49 Polyurethane-50 Polyurethane-51 Polyurethane-52 Polyurethane-53 Polyurethane-54 Polyurethane-55 Polyurethane-56 Polyurethane-57 Polyurethane-58 Polyurethane-59 Polyurethane-60 Polyurethane-61 Polyurethane-62 Polyurethane-63 Polyurethane-64 Polyurethane-65 Polyurethane-66 Polyurethane-67 Polyurethane-68 Polyurethane-69 Polyurethane-70 Polyurethane-71 Polyurethane-72 Table 10. Precursors and monomers of the polyurethanes in this safety assessment that may be used in polyurethane resins that are used in adhesives that may come in contact with food in accordance with the FDA. [21CFR ] 1,4-Butanediol 1,4-Cyclohexanedimethanol [part of a polyester resin] 2-Hydroxypropyl methacrylate Dehydroacetic acid Diethylene glycol adipic acid copolymer Dipropylene glycol copolymer of adipic acid and phthalic anhydride Ethylenediamine Fats and oils derived from animal or vegetable sources, and the hydrogenated, sulfated, or sulfonated forms of such fats and oils Isobutyl alcohol (isobutanol) Isopropanolamine (mono-, di-, tri-) Octylphenoxypolyethoxy-polypropoxyethanol (13 moles of ethylene oxide and propylene oxide) Polyester of adipic acid, phthalic acid, and propylene glycol, terminated with butyl alcohol Polyethyleneadipate modified with ethanolamine with the molar ratio of the amine to the adipic acid less than 0.1 to 1 Tetramethyl decynediol plus 1-30 moles of ethylene oxide Tridecyl alcohol 1,4-Butanediol modified with adipic acid 1,6-Hexanediol (CAS Reg. No ) [part of a polyester resin] 4,4'-Isopropylidenediphenol Diethanolamine Diethylene glycol copolymer of adipic acid and phthalic anhydride Ethylene glycol Ethylenediaminetetra-acetic acid, calcium, ferric, potassium, or sodium salts, single or mixed Hydroxyacetic acid Isophthalic acid Monochloracetic acid Polybutylene glycol (molecular weight 1,000) Polyethylene glycol (molecular weight 200-6,000) Propylene Glycol and p-p -isopropylidenediphenol diether Toluene Triethylene Glycol

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47 20. Bergfeld, WF, Belsito, DV, Hill, RA, Klaassen, CD, Liebler, D, Marks Jr, JG, Shank, RC, Slaga, TJ, Snyder, PW, Gill, LJ, Burnett, C, and Heldreth, B. Safety assessment of polyene group as used in cosmetics. Washington, DC, Cosmetic Ingredient Review pp Elder, RL. Final report on the safety assessment of Toluene. Journal of the American College of Toxicology. 1987;6(1): Bergfeld, WF, Belsito, DV, Hill, RA, Klaassen, CD, Liebler, D, Marks Jr, JG, Shank, RC, Slaga, TJ, Snyder, PW, Gill, LJ, and Becker, LC. Safety assessment of acryloyldimethyltaurate polymers as used in cosmetics; Tentative report for public comment. Washington, DC, Cosmetic Ingredient Review pp Heldreth, B, Bergfeld, W, Belsito, D, Hill, R, Klaassen, C, Liebler, D, Marks Jr, J, Shank, R, Slaga, T, Snyder, P, and Andersen, F. Final report of the Cosmetic Ingredient Review Expert Panel on the safety assessment of Methyl Acetate. International Journal of Toxicology. 2012;31(Suppl. 1):112S-136S. 24. Fiume, MM, Heldreth, B, Bergfeld, W, Belsito, D, Hill, R, Klaassen, C, Liebler, D, Marks Jr, J, Shank, R, Slaga, T, Snyder, P, and Andersen, F. Safety assessment of alkyl PEG ethers as used in cosmetics. International Journal of Toxicology. 2012;31(Suppl. 2):169S-244S. 25. Bergfeld, WF, Belsito, DV, Hill, RA, Klaassen, CD, Liebler, D, Marks Jr, JG, Shank, RC, Slaga, TJ, Snyder, PW, Andersen, FA, Burnett, C, and Fiume, MM. Final report: plant-derived fatty acid oils as used in cosmetics. Washington, DC, Cosmetic Ingredient Review pp Bergfeld, WF, Belsito, DV, Klaassen, CD, Liebler, D, Hill, RA, Marks Jr, JG, Shank, RC, Slaga, TJ, Snyder, PW, Gill, LJ, Johnson Jr, W, and Heldreth, B. Safety assessment of methyl glucose polyethers and esters as used in cosmetics. Washington, DC, Cosmetic Ingredient Review pp Bergfeld, WF, Belsito, DV, Hill, RA, Klaassen, CD, Liebler, D, Marks Jr, JG, Shank, RC, Slaga, TJ, Snyder, PW, Gill, LJ, and Fiume, MM. Amended safety assessment of Butyl Polyoxyalkylene Ethers as used in cosmetics. Washington, DE, Cosmetic Ingredient Review Date Accessed pp Bello, D, Herrick, C, Smith, T, Woskie, S, Streicher, R, Cullen, M, Liu, Y, and Redlich, C. Skin exposure to isocyanates: Reason for concern. Environmental Health Perspectives. 2006;115(3): Silva, A, Nunes, C, Martins, J, Dinis, T, Lopes, C, Neves, B, and Cruz, T. Respiratory sensitizer hexamethylene diisocyanate ihibits SOD 1 and induces ERK-dependent detoxifying and maturation pathways in dendritic-like cells. Free Radical Biology and Medicine. 2014;72: Bergfeld, WF, Belsito, DV, Hill, RA, Klaassen, CD, Liebler, D, Marks Jr, JG, Shank, RC, Slaga, TJ, Snyder, PW, Gill, LJ, and Becker, LC. Safety Assessment of hexamethylene diisocyanate (HDI) polymers as used in cosmetics. Washington, DC, Cosmetic Ingredient Review pp National Industrial Chemical Notification and Assessment Scheme (NICNAS). Full Public Report: Polyurethane in DynamX. Sydney, Australia, Australian Government; Department of Health data/assets/pdf_file/0009/9756/plc371fr.pdf. Date Accessed Report No. PLC/371. pp Intercos CIR review of Polyurethane: Intercos supplementary data (Polyurethane-28, -42 and - 69). Unpublished data submitted by Personal Care Products Council. 33. WIL Research Laboratories Inc Summary of acute inhalation toxicity study (Polyurethane- 14). Unpublished data submitted by Personal Care Products Council. 34. National Industrial Chemical Notification and Assessment Scheme (NICNAS). Polymer of low concern public report: Polymer in Baycusan C Sydney, Australia, Australian Government; Department of Health AA&url=https%3A%2F%2Fwww.nicnas.gov.au%2F data%2fassets%2fword_doc%2f0015%2f14334%2fplc FR.DOCX&usg=AFQjCNE27i_SktC8BYktMdh8vn9pU-ifjQ&sig2=hbvoZRhg9MxDmoCZuadgrg. Date Accessed Report No. PLC/1228. pp Anonymous Technical information Polyurethane-36. Unpublished data submitted by Personal Care Products Council. 36. Anonymous Technical information Polyurethane-60. Unpublished data submitted by Personal Care Products Council. 37. Anonymous Technical information Polyurethane-61. Unpublished data submitted by Personal Care Products Council. 38. National Industrial Chemical Notification and Assessment Scheme (NICNAS). Polymer of low concern public report: Z-155 (INCI name: polyurethane-62). Sydney, Australia, Australian Government: Department of Health emaa&url=https%3a%2f%2fwww.nicnas.gov.au%2f data%2fassets%2fword_doc%2f0007%2f18754%2fplc1260-fr- FINAL.DOCX&usg=AFQjCNG86sWoTX0FE5OogUCn6otTJb6NkQ&sig2=cNMlqvIzfnabM4pa-pcoVQ. Report No. PLC/1260. pp. 1-6.

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49 62. WIL Research Laboratories Inc Summary of 90-day inhalation toxicity range-finding study (Polyurethane-14). Unpublished data submitted by Personal Care Products Council. 63. Lubrizol Advanced Materials Inc Toxicology Studies: Avalure TM Flex-6 Polymer. Unpublished data submitted by Personal Care Products Council. 64. Hill-Top Research Inc Summary of 21-day cumulative irritation study in humans (Polyurethane-14). Unpublished data submitted by Personal Care Products Council. 65. Covance Laboratories Inc Summary of dermal sensitization study in guinea pigs - maximization test (Polyurethane-14). Unpublished data submitted by Personal Care Products Council. 66. AMA Laboratories Human subject repeat insult patch test skin irritation/sensitization evaluation (open patch) of a pomade containing 10% Polyurethane-14. Unpublished data submitted by Personal Care Products Council. 67. Hill-Top Research Inc Summary of human repeated insult patch test (Polyurethane-14). Unpublished data submitted by Personal Care Products Council. 68. Consumer Product Testing Co The MatTek Corporation EpiOcular tissue model in vilro toxicity testing system (test article: pomade containing 10% Polyurethane-14). Unpublished data submitted by Personal Care Products Council. 69. Bergfeld, WF, Belsito, DV, Hill, RA, Klaassen, CD, Liebler, D, Marks Jr, JG, Shank, RC, Slaga, TJ, Snyder, PW, Gill, LJ, Fiume, MM, and Heldreth, B. Amended safety assessment of butyl polyoxyalkylene ethers as used in cosmetics - tentative amended report for public comment. Washington, DC, Cosmetic Ingredient Review pp

50 2017 VCRP Data for Polyurethanes 03B - Eyeliner POLYURETHANE C - Eye Shadow POLYURETHANE F - Mascara POLYURETHANE B - Hair Spray (aerosol fixatives) POLYURETHANE G - Tonics, Dressings, and Other Hair Grooming Aids POLYURETHANE H - Wave Sets POLYURETHANE I - Other Hair Preparations POLYURETHANE D - Eye Lotion POLYURETHANE E - Eye Makeup Remover POLYURETHANE F - Mascara POLYURETHANE C - Foundations POLYURETHANE C - Face and Neck (exc shave) POLYURETHANE F - Moisturizing POLYURETHANE B - Hair Spray (aerosol fixatives) POLYURETHANE H - Wave Sets POLYURETHANE I - Other Hair Preparations POLYURETHANE B - Face Powders POLYURETHANE C - Foundations POLYURETHANE F - Makeup Bases POLYURETHANE C - Foundations POLYURETHANE J - Other Skin Care Preps POLYURETHANE-9 1

51 03B - Eyeliner POLYURETHANE C - Eye Shadow POLYURETHANE G - Other Eye Makeup Preparations POLYURETHANE E - Other Fragrance Preparation POLYURETHANE A - Blushers (all types) POLYURETHANE B - Face Powders POLYURETHANE E - Lipstick POLYURETHANE I - Other Makeup Preparations POLYURETHANE E - Nail Polish and Enamel POLYURETHANE G - Other Manicuring Preparations POLYURETHANE A - Bath Soaps and Detergents POLYURETHANE E - Other Personal Cleanliness Products POLYURETHANE D - Body and Hand (exc shave) POLYURETHANE F - Moisturizing POLYURETHANE J - Other Skin Care Preps POLYURETHANE B - Hair Spray (aerosol fixatives) POLYURETHANE F - Shampoos (non-coloring) POLYURETHANE G - Tonics, Dressings, and Other Hair Grooming Aids POLYURETHANE H - Wave Sets POLYURETHANE I - Other Hair Preparations POLYURETHANE I - Other Makeup Preparations POLYURETHANE A - Blushers (all types) POLYURETHANE B - Face Powders POLYURETHANE C - Foundations POLYURETHANE B - Hair Spray (aerosol fixatives) POLYURETHANE G - Tonics, Dressings, and Other Hair Grooming Aids POLYURETHANE H - Makeup Fixatives POLYURETHANE

52 03B - Eyeliner POLYURETHANE F - Mascara POLYURETHANE E - Nail Polish and Enamel POLYURETHANE G - Other Manicuring Preparations POLYURETHANE F - Mascara POLYURETHANE H - Paste Masks (mud packs) POLYURETHANE B - Eyeliner POLYURETHANE F - Mascara POLYURETHANE G - Other Eye Makeup Preparations POLYURETHANE E - Nail Polish and Enamel POLYURETHANE A - Hair Conditioner POLYURETHANE G - Tonics, Dressings, and Other Hair Grooming Aids POLYURETHANE I - Other Hair Preparations POLYURETHANE I - Other Makeup Preparations POLYURETHANE D - Eye Lotion POLYURETHANE G - Other Eye Makeup Preparations POLYURETHANE A - Blushers (all types) POLYURETHANE B - Face Powders POLYURETHANE C - Face and Neck (exc shave) POLYURETHANE F - Moisturizing POLYURETHANE G - Night POLYURETHANE

53 03C - Eye Shadow POLYURETHANE 1 03F - Mascara POLYURETHANE 1 05B - Hair Spray (aerosol fixatives) POLYURETHANE 3 05G - Tonics, Dressings, and Other Hair Grooming Aids POLYURETHANE 1 05I - Other Hair Preparations POLYURETHANE 3 07E - Lipstick POLYURETHANE 1 07I - Other Makeup Preparations POLYURETHANE 1 08A - Basecoats and Undercoats POLYURETHANE 1 08E - Nail Polish and Enamel POLYURETHANE 1 08G - Other Manicuring Preparations POLYURETHANE 1 12A - Cleansing POLYURETHANE 1 12C - Face and Neck (exc shave) POLYURETHANE 2 17 There were no reported uses in the 2017 VCRP for: Polyurethane-4 Polyurethane-5 Polyurethane-10 Polyurethane-12 Polyurethane-13 Polyurethane-17 Polyurethane-19 Polyurethane-20 Polyurethane-21 Polyurethane-23 Polyurethane-24 Polyurethane-25 Polyurethane-26 Polyurethane-27 Polyurethane-28 Polyurethane-29 Polyurethane-32 Polyurethane-36 Polyurethane-41 Polyurethane-42 Polyurethane-43 Polyurethane-44 Polyurethane-45 Polyurethane-46 Polyurethane-47 Polyurethane-48 Polyurethane-49 Polyurethane-50 Polyurethane-51 Polyurethane-52 Polyurethane-53 Polyurethane-54 Polyurethane-55 Polyurethane-56 Polyurethane-57 Polyurethane-58 Polyurethane-59 Polyurethane-60 Polyurethane-61 Polyurethane-62 Polyurethane-63 Polyurethane-64 Polyurethane-65 Polyurethane-66 Polyurethane-67 Polyurethane-68 Polyurethane-69 Polyurethane-70 Polyurethane-71 Polyurethane-72

54 Memorandum TO: FROM: Lillian Gill, D.P.A. Director - COSMETIC INGREDIENT REVIEW (CIR) Beth A. Jonas, Ph.D. Industry Liaison to the CIR Expert Panel DATE: December 14, 2016 SUBJECT: Concentration of Use by FDA Product Category: Polyurethanes

55 Concentration of Use by FDA Product Category Polyurethanes* Polyurethane-11 Polyurethane-1 Polyurethane-2 Polyurethane-3 Polyurethane-5 Polyurethane-6 Polyurethane-7 Polyurethane-8 Polyurethane-9 Polyurethane-10 Polyurethane-12 Polyurethane-13 Polyurethane-14 Polyurethane-15 Polyurethane-16 Polyurethane-17 Polyurethane-18 Polyurethane-19 Polyurethane-20 Polyurethane-21 Polyurethane-23 Polyurethane-24 Polyurethane-25 Polyurethane-26 Polyurethane-27 Polyurethane-28 Polyurethane-29 Polyurethane-32 Polyurethane-33 Polyurethane-34 Polyurethane-35 Polyurethane-36 Polyurethane-39 Polyurethane-40 Polyurethane-41 Polyurethane-42 Polyurethane-43 Polyurethane-44 Polyurethane-45 Polyurethane-46 Polyurethane-47 Polyurethane-48 Polyurethane-49 Polyurethane-50 Polyurethane-51 Polyurethane-52 Polyurethane-53 Polyurethane-54 Polyurethane-55 Polyurethane-56 Polyurethane-57 Polyurethane-58 Polyurethane-59 Polyurethane-60 Polyurethane-61 Polyurethane-62 Polyurethane-63 Polyurethane-64 Polyurethane-65 Polyurethane-66 Polyurethane-67 Polyurethane-68 Polyurethane-69 Polyurethane-70 Polyurethane-71 Polyurethane-72 Ingredient Product Category Maximum Concentration of Use Polyurethane-11 Bubble baths % Polyurethane-11 Eyebrow pencils % Polyurethane-11 Eyeliners % Polyurethane-11 Eye shadows % Polyurethane-11 Other fragrance preparations Not spray % Polyurethane-11 Hair color sprays 0.086% Polyurethane-11 Blushers 0.29% Polyurethane-11 Face powders 3-3.2% Polyurethane-11 Foundations 0.01% Polyurethane-11 Lipstick 0.058% Polyurethane-11 Nail polish and enamel % Polyurethane-11 Other personal cleanliness products 0.016% Polyurethane-11 Body and hand products Not spray Spray 0.024% %

56 Polyurethane-1 Eyeliners 2.3% Polyurethane-1 Mascara % Polyurethane-1 Hair sprays Aerosol 4.5-5% 0.5% Pump spray Polyurethane-1 Other hair coloring preparations 0.15% Polyurethane-1 Cuticle softeners 15% Polyurethane-1 Other manicuring preparations 15% Polyurethane-2 Face powders 0.63% Polyurethane-2 Nail polish and enamel 9% Polyurethane-2 Polyurethane-6 Face and neck products Not spray 1.1% Hair sprays Aerosol Pump spray Polyurethane-10 Mascara 0.098% Polyurethane-10 Tonics, dressings and other hair grooming aids 3% Polyurethane-10 Foundations 2% Polyurethane-14 Other eye makeup preparations 0.62% Polyurethane-14 Hair sprays Aerosol 3% 6% % 0.6% Pump spray Polyurethane-14 Shampoos (noncoloring) 0.18% Polyurethane-14 Tonics, dressings and other hair grooming aids % Not spray 0.28% Polyurethane-14 Hair color sprays 0.63% Polyurethane-14 Foundations 1.5% Polyurethane-15 Blushers 0.024% Polyurethane-15 Face powders 0.2% Polyurethane-15 Foundations 0.01% Polyurethane-15 Lipstick 0.036% Polyurethane-16 Foundations 0.98% Polyurethane-18 Tonics, dressings and other hair grooming aids Not spray 0.8% Polyurethane-24 Hair sprays Pump spray % Polyurethane-24 Tonics, dressings and other hair grooming aids Not spray 2% Polyurethane-33 Eyeliners 0.5% Polyurethane-33 Eye shadows 1.8% Polyurethane-33 Hair sprays Aerosol 0.04% Polyurethane-33 Leg and body paints 2.3% Polyurethane-33 Other makeup preparations 4.5% Polyurethane-33 Nail polish and enamel % Polyurethane-33 Other manicuring preparations %

57 Polyurethane-33 Other skin care preparations 7.5% Polyurethane-34 Mascara 3.2% Polyurethane-34 Hair sprays Aerosol 0.36% 0.75% Pump spray Polyurethane-34 Tonics, dressings and other hair grooming aids 0.5% Polyurethane-34 Lipstick 2.9% Polyurethane-35 Eyebrow pencils 2.9% Polyurethane-35 Mascara 4.1-7% Polyurethane-35 Other eye makeup preparations 2% Polyurethane-35 Blushers 2% Polyurethane-35 Polyurethane-35 Body and hand products Not spray 0.84% Suntan products Not spray 1.1% Polyurethane-46 Shampoos (noncoloring) 0.2% *Ingredients included in the title of the table but not found in the table were included in the concentration of use survey, but no uses were reported. Information collected in 2016 Table prepared: December 14, 2016

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82 Personal Care Products Council Committed to Safety, Quality & Innovation Memorandum TO: FROM: Lillian Gill, D.P.A. Director- COSMETIC INGREDIENT REVIEW (CIR) Beth A. Jonas, Ph.D. Industry Liaison to the CIR Expert Panel DATE: February 23,2017 SUBJECT: Polyurethane-14 WIL Research Laboratories, Inc Summary of acute inhalation toxicity study (Polyurethane-I 4 ). WIL Research Laboratories, Inc.. Summary of I 4-day inhalation toxicity range-finding study (Polyurethane-14 ). WIL Research Laboratories, Inc Summary of90-day nose-only inhalation toxicity study (Polyurethane-14). Covance Laboratories, Inc Summary of dermal sensitization study in guinea pigsmaximization test (Polyurethane-14). Hill Top Research, Inc Summary of human repeated insult patch test (Polyurethane-14). Hill Top Research, Inc Summary of 21-day cumulative irritation study in humans (Polyurethane-! 4) L Street, N.W., Suite 1200 I Washington, D.C I (fax) I

83 PRODUCT NAME Polyurethane - I L{ M~IPcJfa,.. Wt' ;,~ (}a C) oo - I~O o OTHER NUMBERS BATCH# PC DATE Jan.3,2002 STUDY NAME Acute Inhalation Toxicity Study GUIDELINES OECD 403 LAB WIL Research Laboratories, Inc. STUDY# WIL SPECIES Rats STRAIN Sprague Dawley (Charles River) # OF ANIMALS USED 10 # OF ANIMALS/GROUP 5 Male and 5 female CONCENTRATION 11 0 mg/m 3 -polymer 964 ppm-ethanol # OF EXPOSURE Single exposure EXPOSURE PERIOD 4 hours ROUTE OF EXPOSURE Inhalation VEHICLE none %SOLIDS 9.61% polymer 54.9% ethanol ph=9.11 %AMP EXPOSURE CHAMBER Whole Body PARTICLE SIZE (MMAD) 1.9~m ± 3.21 (GDS) RESULTS No mortality was observed during any point in the study. Clear nasal discharge was observed for one male immediately following exposure. During the 14-day observation period, there were no toxicologically significant clinical findings, remarkable body weight changes or gross findings at the scheduled necropsy. CONCLUSION The LC 50 of Polyurethane :_ 1 '1 was found to be greater than II 0 mglm 3 when male and female rats were exposed to the test article as a liquid droplet aerosol for four hours. I I Acute Inhalation Toxicity Study in Albino Rats (OECD 403) Ten Sprague Dawley (Charles River) rats (5 male and 5 female) were placed in whole body chambers and exposed for 4 hours to an aerosol of a Polyurethane ; 9.6% polymer; 55% ethanol). The exposure concentration of the polymer and ethanol were I I 0 mglm3 and 964 ppm, respectively. The particle, mean aerodynamic diameter was 1.9 J.lm :t No mortality was observed during any point in the study. Clear nasal discharge was observed for one male immediately following exposure. During the 14-day observation period, there were no toxicologically significant clinical findings, remarkable body weight changes or gross findings at the scheduled necropsy. The LC 50 ofpolyurethane A was found to be greater than 110 mglm 3 when male and female rats were exposed to the test article as a liquid droplet aerosol for four hours.

84 PRODUCT NAME Polyurethane.. I '-1 Mdlt'C'Jia..- Wf"/<;,h~ ;)<J "0 0 ' 3 ') Otl 0 f. ~ OTHER NUMBERS BATCH# PC DATE STUDY NAME 14-Day Inhalation Toxicity Range-Finding Study GUIDELINES Range-Finding LAB WIL Research Laboratories, Inc. STUDY# WIL SPECIES Rats STRAIN Sprague Dawley (Charles River) # OF ANIMALS USED 50 # OF ANIMALS/GROUP 5 Male and 5 female CONCENTRATION polymer Filtered air, ethanol, 10, 30, 100 mg/m 3 -polymer #OF EXPOSURE 14 EXPOSURE PERIOD 6 hours ROUTE OF EXPOSURE Inhalation VEHICLE Filtered air, ethanol %SOLIDS 9.61% polymer 54.9% ethanol ph=9.11 %AMP EXPOSURE CHAMBER Whole Body PARTICLE SIZE (MMAD) XX ).lm ±XX (GDS) RESULTS CONCLUSION 14-dav Inhalation Toxicity Range-Finding Study Ten Sprague Dawley (Charles River) rats (5 male and 5 female) per group were placed in whole body chambers and exposed for six hours to an aerosol of a Polyurethane ~ ~ '-/, 9.6% polymer; 55% ethanol). The exposure concentrations used were air control, ethanol control, 10, 30 and 100 mglm 3 polymer. I I Morbidity and mortality: There were no unscheduled deaths. Gross necropsy observations: Pallor of the lungs was noted in one male and one female in the 30 mg/m 3 dose group and in one male in the I 00 mg/m 3 dose group. This gross finding is consistent with the histopathologic observations of alveolar histiocytosis in the lungs ofthese animals which was considered an effect of exposure to the test article. Organ weights: Mean absolute lung weight was increased in I 00 mg/m 3 males and females and in 30 mg/m 3 females. Mean relative to final body weight lung weights were increased in males and females in both the I 00 mg/m 3 and 30 mg/m 3 dose groups. The increased lung weights are considered an effect of exposure to test article and correlated with increased incidence and severity of alveolar histiocytosis in the lungs. Histopathology: An exposure-related condition, diffuse alveolar histiocytosis, was noted in the lungs of all animals in both the I 00 mg/m 3 and 30 mg/m 3 exposure groups and it increased in severity with exposure level. Alveolar histiocytes are macrophages, typically with abundant foamy cytoplasm, in alveolar spaces. Animals in 100 mg/m 3 and 30 mg/m 3 exposure groups had increased alveolar macrophages diffusely throughout their lungs. Alveolar histiocytosis noted in the lungs of occasional animals in groups 1 and 2 (without exposure to test material) was focal or multi focal and minimal in severity in contrast with that of

85 mid- and high-level exposure groups where the condition was minimal to mild and was diffuse throughout the lung. Alveolar histiocytosis in the lungs of2 ofs animals of either sex in the 10 mg/m 3 exposure group was multi focal and minimal and was not considered related to exposure to test material.

86 PRODUCT NAME OTHER NUMBERS DATE BATCH# STUDY NAME GUIDELINE LAB STUDY# SPECIES STRAIN # OF ANIMALS USED # OF ANIMALS/GROUP CONCENTRATION Polymer (ethanol) #OF DOSES EXPOSURE PERIOD ROUTE OF EXPOSURE VEHICLE %SOLIDS EXPOSURE CHAMBER PARTICLE SIZE RECOVERY PERIOD RESULTS PolYurethane - I '"I 1\1\dl ~ c-jl Q-" r~~. ~ ""~ ~() ooov March 31, , PC Day Nose-Only Inhalation Toxicity Study OECD 413 WIL Research Laboratories, Inc. WIL Cri:CD (SD)IGS BR Rats!50 30 ( 15 females and 15 males) air, 394 ppm ethanol, 1.17 ± 0.3 (50), 5.3 ± 1.1 (147) and 40.6 ± 4.8 (320 ppm) mg oolvmer /m hours/day, 5days/week, 90-day Inhalation Air, ethanol 9.6I% solids neutralized with AMP, 54.9% ethanol Nose-only 1.5 ± 2. 7, 1.4 ± 2.1, 1.9 ± 2.2 (± GSD) 13 weeks There were no test article-related deaths or clinical observations. There were no toxicologically significant effects on mean body weights, body weight gains, food consumption, microscopic organ evaluations (except the lung and lymph nodes) or on hematology or serum chemistry parameters. In the air and ethanol controls and the low dose group, a background syndrome was present which was described as concurrent mild perivascular inflammatory cell infiltrate and/or subacute inflammation (mixed cell type) with interstitial pneumonia. This pattern was distinguishable from test article induced responses. Exposure to 5.3 and 40.6 mglm 3 groups resulted in a low incidence of macroscopic findings such as white areas in the lungs and enlarged lymph nodes, a dose dependent increase in lung weights, accumulation of foamy alveolar macrophages, interstitial pneumonia and acute inflammation (alveolar neutrophils) in the lung that increased in incidence and severity with dose. The incidence and severity of the above findings generally decreased in the 90 day recovery animals indicating partial recovery. A few 1.2 mglm 3 and greater numbers of 5.3 and 40.6 mglm 3 exposed animals had foamy macrophage accumulation in the mediastinal and/or tracheobronchial lymph nodes. Accumulation of foamy macrophages in the lung or lymph node is considered a tr :5 (}00 hi\ II I I I

87 normal physiological response necessary to remove particles from the lung and is not adverse. CONCLUSION Based on the results of this study, the No Observed Adverse Effect Level was 1.2 mg solids/m 3 The lack of primary parenchymal toxicity or progressive lesions demonstrate that is a polymer oflow toxicity. P<ll-t&JI'' t-l'ic\n<"- I '-f Thirteen Week Inhalation Toxicity Study In Rats (OECD " 413) Thirty Sprague Dawley (Charles River) rats (fifteen male and fifteen female) per group were exposed nose-only to air, 394 ppm ethanol, or increasing concentrations of a neutralized polyurethane ~ t'"'{ for six hours per day, five days per week for 13 weeks. The aqueous solution containing 9.61 % solids and 55 % ethanol was diluted with air to result in an exposure concentration of 1.2 ± 0.3 (50 ppm ethanol), 5.3 ± 1.1(147 ppm ethanol) and 40.6 ± 4.8 (320 ppm ethanol) mg polymer /m 3 The particle mean aerodynamic diameter was 1.5 ± 2.7, 1.4 ± 2.1, 1.9 ± 2.2J.!m (±geometric standard deviation) which resulted in an inhalable percentage of97.2, 99.6, and 98.3 %, respectively for the 1.2, 5.3 and 40.6 mglm 3 groups. After thirteen weeks of exposures, five males and five females per group entered a thirteenweek recovery period. All animals were observed routinely for clinical signs, food consumption, and body weight changes. There were no test article-related deaths or clinical observations. There were no toxicologically significant effects on mean body weights, body weight gains, food consumption, microscopic organ evaluations (except the lung and lymph nodes) or on hematology or serum chemistry parameters. In the air and ethanol controls and the low dose group, a background syndrome was present which was described as concurrent mild perivascular inflammatory cell infiltrate and/or subacute inflammation (mixed cell type) with interstitial pneumonia. This pattern was distinguishable from test article induced responses. Polyurethane exposure to 5.3 and 40.6 mg/m 3 groups resulted in a low incidence of macroscopic findings such as white areas in the lungs and enlarged lymph nodes, a dose dependent increase in lung weights, accumulation of foamy alveolar macrophages, interstitial pneumonia and acute inflammation (alveolar neutrophils) in the lung that increased in incidence and severity with dose. The incidence and severity of the above findings generally decreased in the 90 day recovery animals indicating partial recovery. A few 1.2 mg/m 3 and greater numbers of 5.3 and 40.6 mglm 3 exposed animals had foamy macrophage accumulation in the mediastinal and/or tracheobronchial lymph nodes. Accumulation of foamy macrophages in the lung or lymph node is considered a normal physiological response necessary to remove particles from the lung and is not adverse. Based on the results of this study, the No Observed Adverse Effect Level was 1.2 mg solids/m 3 The lack of primary parenchymal toxicity or progressive lesions demonstrate that A \ is a polymer of low toxicity. p.,jl'vr e- t'vlct.,<- IL.(

88 TEST ARTICLE ~ OTHER NAMES Polyurethane, c.j/q..- w~:,j.d ao 00 o- 35' STUDY NAME Dennal Sensitization Study in Guinea Pigs-Maximization Test GUIDELINES OECD 406 OPPTS EPA DATE 01/29/01 LAB Covance Laboratories, Inc. STUDY# BATCH# SPECIES Guinea Pig STRAIN Cri:(HA)BR %SOLIDS 23.4% # OF ANIMALS USED Test Group-20 animals (10 females and 10 males) Irritation Control Group-I 0 animals (5 females and 5 males) DOSE- INDUCTION INJECTION: 0.1 ml 1% solids (1.2% ethanol), TOPICAL: saturated 8 cm 2 patch of23.4% solids (27% ethanol), 48 hours DOSE-CHALLENGE saturated 4 cm 2 patch of 23.4% solids (27% ethanol), 24 hours POSITIVE CONTROL Alpha-hexylcinnamaldehyde - amended to report, performed October 9,2000 SLS 10% SLS on day 7 PATCH TYPE Occluded EVALUATION- 48 and 72 hours after challenge application CHALLENGE VEHICLE 27% ethanol RESULTS Moderate to intense redness was observed after the intradermal injection, which was reduced to scabbing for the remainder of the induction period. The application sites were evaluated for erythema 48 and 72 hours after application. No erythema was present after challenl',e with test article or control treatment. l't CONCLUSION Under the described test conditions, : (Polyurethane} did not cause a sensitization reaction in guinea pigs..., Md)P I ::,1 Guinea Pig Maximization Test (Magnusson-Kligman) (OECD 406) ~~ Twenty guinea pigs ( 10 females and 10 males) were dosed with _ (Polyurethane'} and ten (5 females and 5 males) were dosed with 27% ethanol during the induction phase and the test article at challenge (control). The induction phase consisted of two appl~ations. First, animals were injected with 0.1 ml of a I% solution of Polyurethan~ 1 *ith and without Freund's Complete Adjuvant. Second, after pretreatment with I 0% sodium Iaury! sulfate, an 8 cm 2 patch of filter paper saturated with a 23.4% solids solution of28-006a (Polyurethane) in 27% ethanol was applied topically for 48 hours. Moderate to intense redness was observed after the intradermal injection, which was reduced to scabbing for the remainder of the induction period. The challenge to virgin sites consisted of a 4 cm 2 patch of filter paper saturated with a 23.4% solids solution of A (Polyurethane) in 27% ethanol which was applied topically for 24 hours. The application sites were evaluated for erythema 48 and 72 hours after application. No erythema was present after challenge ~ith test article or control treatment. Under the described test conditions, (Polyurethan~ d\d not cause a sensitization reaction in guinea pigs.

89 TEST ARTICLE Polyurethane -IY MOIPcJit.~..- rle: :' "l-jo OTHER NUMBERS PC STUDY NAME Human Repeated Insult Patch Test LAB Hilltop Research STUDY# DATE August 28, 2001 BATCH# %SOLIDS 9.61%; 54.9% ethanol SPECIES Humans PANEL Non-exclusive # OF SUBJECTS USED 104 DOSE 0.2 ml polyurethane CONTROL 0.2 ml 54.9% ethanol # OF EXPOSURES 9 induction and I challenge PATCH TYPE Semi-occlusive SITE upper arm PATCH APPLICATION Test article was applied to patch pad at least 15 minutes before application, but no longer than 30 minutes before application. LENGTH OF EXPOSURE 24 hours ROUTE OF EXPOSURE Dermal OBSERVATION PERIOD 48 to 72 hours after induction patch application 48 and 72 hours after challenge patch application VEHICLE 55% ethanol RESULTS With both the treatment and ethanol control sites, mild erythema was noted in a few different subjects at various evaluation periods during induction. No reaction was observed in any subject during the challenge phase. CONCLUSION Under the described test conditions, Polyurethane "": t '1 I did not exhibit evidence of a delayed contact hypersensitivity response in human beings. ' Human Repeated Insult Patch Test Approximately 0.2 ml of a Polyurethane - I~ \)solution (9.6% polymer; 55% ethanol), or a 55 %ethanol control was applied to the upper arm of a non-exclusive panel of I 04 subjects for nine induction and one challenge exposures. The semi-occluded patch was in contact with the skin for 24 hours and the site was evaluated 48 or 72 hours after the induction application and 48 and 72 hours after the challenge application. With both the treatment and ethanol control sites, mild erythema was noted in a few different subjects at various evaluation periods during induction. No reaction was observed in any subject during the challenge phase. Under the described test conditions, Polyurethane - I "f. did not exhibit evidence of a delayed contact hypersensitivity response in human beings.

90 - TEST ARTICLE Polyurethane - I Y Molr~ via.,.. ~...,""i (} ", ~ OTHER NAMES/#S STUDY NAME 21-Day Cumulative Irritation Study in Humans GUIDELINES - DATE Jan. 7, 2002 LAB Hill Top Research, Inc. STUDY# BATCH# CHEMISTRY SPECIES Human #OF SUBJECTS USED 29 <v,, SOLIDS 9.61% polymer; 54.9% ethanol- Test Article B VEHICLE CONTROL 55% Ethanol - Test Article B NEGATIVE CONTROL Distilled water - Test Article C POSITIVE CONTROL 0.075% sodium lnuryl sulfate (semi-occluded, day 1-15)- 0.1% SLS (occluded; day 16-21) Test Article D DOSE 0.2 ml, 2cm X 2cm non woven cotton pad #OF EXPOSURES 21 Exposures PATCH TYPE Semi-occluded, day 1-9 Semi-open, day I 0-2 I LENGTH OF EXPOSURE 24 Hours ROUTE OF EXPOSURE Skin OBSERVATION PERIOD 24 hours after patch application RESULTS Under repetitive semi-occluded conditions, Polyurethane - 1'1 produced erythema and papules (Score 3) in a total of three subjects by the fourth application. After changing to semi-open conditions, an additional subject was observed with erythema and papules on day I 9. Under identical conditions, ethanol control produced erythema and papules in a total of three subjects by the third application. None to very slight erythema was observed at the majority of sites treated with Polyurethane or ethanol. Patch sites treated with distilled water elicited a very low response. Distilled water and 0.1% Sodium Laury! Sulfate (occluded conditions after day 16) produced the expected responses. The cumulative score was 232, 208, I 3, and 338, respectively. CONCLUSION Under the conditions of the study, both the 9.6% Polyurethane 1-1'1 polymer in 54.9% ethanol and the 55% ethanol control produced mild to moderate irritation only in a few subjects, with no differences between these two test articles. 21-Dnv Cumulative Irritation Study in Humans Twenty-nine subjects were exposed topically under semi-occluded conditions to 0.2 ml of a : (Polyurethane) solution (9.6% polymer; 55% ethanol), 55 %ethanol control, distilled water and 0.075% sodium lauryl sulfate (0.1% and occluded from day 16-21) for 21 days. Scoring for cumulative irritation was performed every 24 hours immediately prior to reapplication or until excessive irritation was noted (Score ~3). Due to irritation observed in the polyurethane and ethanol control groups, the patch type was changed in these two groups to semi-open on day I 0 of study. Under repetitive semi-occluded conditions, Polyurethane produced erythema and papules (Score 3) in a total of three subjects by the fourth application. After changing to semi-open conditions, an additional subject was observed with erythema and papules on day 19. Under identical conditions, ethanol control produced erythema and papules in a total of three subjects by the third application. None to very slight erythema was observed at the majority of sites treated with A (Polyurethane) or ethanol. Patch sites treated with distilled water elicited a very low response. Distilled water and 0.1% Sodium Lauryl Sulfate (SLS; occluded conditions after day 16) produced the expected responses. The cumulative scores were 232

91 (Polyurethane solution), 208 (ethanol solution), 13 (water), and 338 (SLS). Under the conditions of the study, both the 9.6 % A (Polyurethane) in 54.9% ethanol and the 55% ethanol control produced mild to moderate irritation only in a few subjects, with no differences between these two test articles.

92 Memorandum TO: FROM: Lillian Gill, D.P.A. Director - COSMETIC INGREDIENT REVIEW (CIR) Beth A. Jonas, Ph.D. Industry Liaison to the CIR Expert Panel DATE: February 24, 2017 SUBJECT: Polyurethane-28, -42 and -69 Intercos CIR review of Polyurethane: Intercos supplementary data (Polyurethane-28, -42 and - 69).

93 CIR REVIEW OF POLYURETHANE INTERCOS SUPPLEMENTARY DATA POLYURETHANE 28 Polyurethane 28 (Icaflex Pusiosorb ST) is manufactured as a 25% dispersion in cyclopentasiloxane and it is intended as film forming ingredient for make up cosmetics. The use concentration of the dispersion (solvent + copolymer) is up to 32%, that results in a maximum concentration of the polymer up to 8% in the final formulations. Method of Manufacture The polymer is obtained by condensation of an isocyanate component and molecules containing hydroxyl groups (sorbitan isostearate). The polimerization is terminated by the addition of ethyl alcohol. Molecular weight The molecular weight distribution is above g/mol and no low molecular weight fractions (<1000 g/mol) were detected by SEC MALS Stability Data The polymer is stable over time at different temperatures (5, 25, 50 C for 3 years (storage conditions)). Purity data The absence of the sensitising monomer IPDI has been shown analytically. HPLC MS ANALYSIS (IPDI < 5 ppm at different check times) In Vitro Genotoxicity Studies Polurethane 28 does not induce reverse mutation in Salmonella typhimurium or Escherichia coli. The assay was conducted according to OECD Guideline for the testing of chemicals No POLYURETHANE 42 Polyurethane 42 (Intercoshine) is manufactured as a 47.50% dispersion in isododecane and ethanol. Its intended use is as film forming ingredient for make up cosmetics. The use concentration of the dispersion is up to 70% (33.25% of polymer) in the final products Method of Manufacture The polymer is obtained by condensation of an isocyanate component and molecules containing hydroxyl groups (Di C12 13 Alkyl Tartrate and Hydrogenated Dilinoleyl Alcohol). The polimerization is terminated by the addition of ethyl alcohol. Molecular weight The average total molecular weight is above g/mol and no low molecular weight fractions (<1000 g/mol) were detected by SEC MALS. INTERCOS New Raw Material Laboratory 1

94 Stability Data The polymer is stable over time at different temperatures (5, 25, 50 C for 3 years (storage conditions)). Purity data The absence of the sensitising monomer IPDI has been shown analytically. HPLC MS ANALYSIS (IPDI < 0.5 ppm at different check times). In Vitro Genotoxicity Studies The absence of mutagenic potential (gene mutation) was confirmed by a bacterial reverse mutation test (Ames test on Salmonella typhimurium / Escherichia coli). The assay was conducted according to OECD Guideline for the testing of chemicals No Ocular Irritation Studies Two alternative assays for the in vitro evaluation of the eye irritation potential (HET CAM test, BCOP assay) were performed. The dispersion was classified as moderately irritant against the chorioallantoic membrane of the embryonic hen s egg; the same polymer showed an in vitro score of 0.67, and was hence classified as NOT IRRITANT for the eye, in the BCOP assay. POLYURETHANE 69 Polyurethane 69 (VinylSunshine) is manufactured as a 66% dispersion in ButylAcetate and ethanol. Its intended use is film former and builder for nail polish. Method of Manufacture The polymer is obtained by condensation of an isocyanate component with Di C12 13 Alkyl Tartrate and Isopropylidenediphenyl Bisoxyhydroxypropyl Methacrylate. After the NCO terminated prepolymers is obtained, 2 Hydroxyethyl Methacrylate is added to react with NCO terminal groups. The reaction is carried on until the absence of free NCO groups. Molecular weight The average total molecular weight is above 3400 g/mol. A little amount (4%) of low molecular weight fractions (<1000 g/mol) were detected by SEC MALS. Stability Data The complete stability of the VinylSunShine is observed over time at different temperatures (5, 25, 50 C for 16 weeks years (storage conditions)). There is no formation of high molecular weight crosslinked fractions and, at the same time, no depolimerization is detected. Purity data The absence of the sensitising monomer IPDI has been shown analytically. HPLC MS ANALYSIS (IPDI < 0.5 ppm at different check times). Toxicological studies No data available. Issued 02/2017 INTERCOS New Raw Material Laboratory 2

95 Personal Care Products Council Committed to Safety, Quality & Innovation Memorandum TO: FROM: Lillian Gill, D.P.A. Director- COSMETIC INGREDIENT REVIEW (CIR) Beth A. Jonas, Ph.D. ~~ 0... (\.~ Industry Liaison to the CIR Expert Panel...J» Q DATE: January 25, 2017 SUBJECT: Comments on the Scientific Literature Review: Safety Assessment of Polyurethanes as Used in Cosmetics (release date: January II, 20 17) The Council has no suppliers listed for the following ingredients: Polyurethane-4 Polyurethane-50 Polyurethane-S Polyurethane-51 Polyurethane-6 Polyurethane-54 Polyurethane-7 Polyurethane-55 Polyurethane-25 Polyurethane-56 Polyurethane-29 Polyurethane-63 Polyurethane-49 Polyurethane-66 Polyurethane-67 Polyurethane-68 Polyurethane-70 Polyurethane-71 Polyurethane-72 Key Issues Cosmetic Use- Please review the EU limit for trialkylamines. The product type row has two categories (a) leave-on products; (b) rinse-off products. The maximum concentration of 2.5% applies only to (a) leave-on products. The other limitations apply to both (a) leaveon products and (b) rinse-off products. Acute, Summary- The NICNAS summary for Polyurethane-35 reported that the rat oral LD 50 was >4890 mg/kg (not =to 4890 mglkg as stated in the SLR). The summary table in the NICNAS report also noted that no effects were observed in the acute oral rat study. Additional Considerations Introduction - In the Introduction, it would be helpful to state which ingredients have a NICNAS assessment and meet their criteria for Polymers of Low Concern (PLC). It is not correct to state that the report including PPG-30 Butyl Ether is an insufficient data announcement. At the December 2016 meeting, the report on Butyl Polyoxyalkylene Ethers moved to a tentative report with a conclusion of safe when formulated to be non L Street, N.W., Suite 1200 I Washington, D.C I (fax) I

96 irritating. Definition and Structure- Rather than saying "Some of these polymers are linear" it would be helpful to state which ones are linear, or at least provide an example of one that is linear. As glycerin is not a frequent component of the polymers in this report, is there another example of a "multi-functional monomer" that could be stated? Physical and Chemical Properties - Please provide a reference for the information on Polyurethane-35. Method of Manufacture - Although it is not necessary to list the components of polyurethanes permitted in food contact adhesives, it would be helpful to know if the components found in cosmetic ingredients are found in polyurethanes permitted for food contact. Cosmetic Use - Please indicate the highest concentration and the product category in which Polyurethane-! 0 was reported to be used. The Cosmetic Use section currently implies that a number of ingredients were reported to be used in spray products at a maximum concentration of 6%. This is misleading, only Polyurethane-6 was reported to be used in hair sprays at a concentration of 6%. No use concentrations for spray products were reported for Polyurethane-IS. The text should be specific, e.g., "The VCRP and the industry survey reported Polyurethane-I, -6, -11, -14, -24, and -33 to be used in spray or potential spray products. The maximum concentration reported for a spray product was 6% Polyurethane-6 in hair sprays." The use information on face powders is also misleading. Only Polyurethane-11 was reported to be used at a concentration of 3.2% in face powders (not Polyurethane-2, -7, -14, -35 and -40 as implied by the text). Summary - In the Summary, please state the particle size of the polyurethane used in the 1 0 day mouse study. Table 2 - Please add a footnote to explain the information presented in the column with the heading "Highest concentration of use" (e.g., highest concentration of ingredient of interest and the highest concentration among the ingredients in the report). Please correct: "Methyl Acitate"; "1,4-Butanediole". It should also be stated that no uses were reported for 1,5-Pentanediol. In the HDI Polymers row, it would be helpful to state that the highest residual HDI level reported in the polymers was <1 00 ppm. Table 3 - It is not clear why both Dimethyl ethanolamine and Dimethyl MEA need to be in Table 3 as these appear to be two names for the same material. As triethylamine is used as a neutralizer for a number of the polymers in this report, it is not clear why it is not included in Table 3. Table 6 - The use information from the Council did not have a spray product containing % Polyurethane-11 (the only product with this concentration was an "other fragrance preparation" that is not a spray product. There is a body and hand spray containing % Polyurethane-11. 2