Annex XV 2,4 - Dinitrotoluene EC Number: 204-450-0 CAS Number: 121-14-2 Proposal for identification of a substance as a CMR cat 1 or 2, PBT, vpvb or a substance of an equivalent level of concern It is proposed to identify the substance as a CMR according to Article 57 (a). Submitted by: Spain (Ministerio de Sanidad y Política Social) Version: July 2009 1
CONTENTS ABBREVIATIONS... 3 PROPOSAL FOR IDENTIFICATION OF A SUBSTANCE AS A CMR CAT 1 OR 2, PBT, VPVB OR A SUBSTANCE OF AN EQUIVALENT LEVEL OF CONCERN... 4 JUSTIFICATION... 5 1 IDENTITY OF THE SUBSTANCE AND PHYSICAL AND CHEMICAL PROPERTIES... 5 1.1 NAME AND OTHER IDENTIFIER OF THE SUBSTANCE... 5 1.2 COMPOSITION OF THE SUBSTANCE... 5 1.3 PHYSICO-CHEMICAL PROPERTIES... 6 2 MANUFACTURE AND USES... 6 3 CLASSIFICATION AND LABELLING... 6 3.1 CLASSIFICATION IN ANNEX VI OF REGULATION (EC) NO 1272/2008... 6 4 ENVIRONMENTAL FATE PROPERTIES... 7 5 HUMAN HEALTH HAZARD ASSESSMENT... 7 6 HUMAN HEALTH HAZARD ASSESSMENT OF PHYSICOCHEMICAL PROPERTIES... 7 7 ENVIRONMENTAL HAZARD ASSESSMENT... 7 8 PBT, VPVB AND EQUIVALENT LEVEL OF CONCERN ASSESSMENT... 7 INFORMATION ON USE, EXPOSURE, ALTERNATIVES AND RISKS... 8 1 INFORMATION ON EXPOSURE... 8 2 INFORMATION ON ALTERNATIVES... 10 3 RISK-RELATED INFORMATION... 10 OTHER INFORMATION... 12 REFERENCES... 12 TABLES TABLE 1: SUMMARY OF PHYSICO-CHEMICAL PROPERTIES... 6 TABLE 2: SUMMARY OF THE OCCUPATIONAL EXPOSURE LEVELS... 9 TABLE 3: DAILY HUMAN DOSES (MG/KG/D)... 10 2
ABBREVIATIONS ATP CAS CMR DNT EASE EC ECB EEC EU EUSES IUPAC RAR RRS SPIN TDA TDI vpvb Adaptation to Technical Progress Chemical Abstract Services Carcinogenic, Mutagenic and toxic to Reproduction Dinitrotoluene Estimation and Assessment of Substance Exposure Physico-chemical properties [Model] European Communities European Chemicals Bureau European Economic Communities European Union European Union System for the Evaluation of Substances [software tool in support of the Technical Guidance Document on risk assessment] International Union for Pure and Applied Chemistry Risk Assessment Report Risk Reduction Strategy Substances in Preparations in Nordic Countries [Database] Toluene-2,4-diamine (4-methyl-m-phenylenediamine) Toluene-2,4-diisocyanate (4-methyl-m-phenylenediisocyanate) very Persistent and very Bioaccumulative 3
PROPOSAL FOR IDENTIFICATION OF A SUBSTANCE AS A CMR CAT 1 OR 2, PBT, VPVB OR A SUBSTANCE OF AN EQUIVALENT LEVEL OF CONCERN Substance name: 2,4-Dinitrotoluene EC number: 204-450-0 CAS number: 121-14-2 It is proposed to identify the substance as a CMR according to Article 57 (a). Summary of how the substance meets the CMR (Cat 1 or 2), PBT or vpvb criteria, or is considered to be a substance of an equivalent level of concern The substance is listed as carcinogen Category 2; R45 in Annex VI, part 3, Table 3.2 (the list of harmonised classification and labelling of hazardous substances from Annex I to Directive 67/548/EEC) of Regulation (EC) Nº 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006 (Index Number: 609-007-00-9). This corresponds to a classification as carcinogen (1B) in Annex VI, part 3, Table 3.1 of Regulation (EC) No 1272/2008 (list of harmonised classification and labelling of hazardous substances). The classification of 2,4-dinitrotoluene as carcinogen Category 2; R45 in Annex I of the Directive 67/548/EEC was included in the 25 th ATP, revised in the 29 th and 31 st ATP (Index Number: 609-007-00-9). Registration number(s) of the substance or of substances containing the substance: Not relevant 4
JUSTIFICATION 1 IDENTITY OF THE SUBSTANCE AND PHYSICAL AND CHEMICAL PROPERTIES 1.1 Name and other identifier of the substance Chemical Name: 2,4-Dinitrotoluene EC Number: 204-450-0 CAS Number: 121-14-2 IUPAC Name: 1-methyl-2,4-dinitrobenzene 1.2 Composition of the substance Chemical Name: 2,4-Dinitrotoluene EC Number: 204-450-0 CAS Number: 121-14-2 IUPAC Name: 1-methyl-2,4-dinitrobenzene Molecular Formula: C 7 H 6 N 2 O 4 Structural Formula: CH 3 NO 2 NO 2 Molecular Weight: 182.14 Typical proportion % 99% Impurity There are no data available Real proportion (range) in % 5
1.3 Physico-Chemical properties Table 1: Summary of physico-chemical properties REACH ref Annex, VII, 7.1 Property Value Reference Physical state at 20 C and 101.3 kpa Solid EU RAR (2008) VII, 7.2 Melting / freezing point 69.9ºC EU RAR (2008) VII, 7.3 Boiling point 319.5ºC EU RAR (2008) VII, 7.5 Vapour pressure 7.9 10-3 Pa at 20ºC EU RAR (2008) VII, 7.7 Water solubility 166 mg/l at room temperature EU RAR (2008) VII, 7.8 Partition coefficient n- octanol/water (log value) IX, 7.16 Dissociation constant Not available 1.98 EU RAR (2008) 2 MANUFACTURE AND USES Not relevant for this type of dossier. However, see section about information on use, exposure, alternatives and risks. 3 CLASSIFICATION AND LABELLING 3.1 Classification in Annex VI of Regulation (EC) No 1272/2008 2,4-Dinitrotoluene is classified as follows (with Index Number: 609-007-00-9) according to part 3 of Annex VI, Table 3.2 (the list of harmonised classification and labelling of hazardous substances from Annex I to Directive 67/548/EEC) of Regulation (EC) No 1272/2008: Carc.Cat. 2; R45: May cause cancer Muta. Cat. 3; R68: Possible risk of irreversible effects. Repr. Cat. 3; R62: Possible risk of impaired fertility T; R23/24/25: Toxic by inhalation, in contact with skin and if swallowed. Xn; R48/22: Harmful, danger of serious damage to health by prolonged exposure if swallowed. N; R50-53: Dangerous for the environment. Very toxic to aquatic organisms/may cause long-term adverse effects in the aquatic environment. Safety Phrases: S53: Avoid exposure - obtain special instructions before use S45: In case of accident or if you feel unwell, seek medical advice immediately (show the label where possible) S60: This material and its container must be disposed of as hazardous waste 6
S61: Avoid release to the environment. Refer to special instructions/safety data sheets Its harmonised classification and labelling as a hazardous substance according to Regulation (EC) No 1272/2008 (Annex VI, part 3, Table 3.1) is as follows (Index Number: 609-007-00-9): Carc. 1B; H350 Muta. 2; H341 Repr. 2; H361f *** Acute Tox. 3 *; H331 Acute Tox. 3 *; H311 Acute Tox. 3 *; H301 STOT RE 2 *; H373 ** Aquatic Acute 1; H400 Aquatic Chronic 1; H410 4 ENVIRONMENTAL FATE PROPERTIES Not relevant for this type of dossier 5 HUMAN HEALTH HAZARD ASSESSMENT Not relevant for this type of dossier 6 HUMAN HEALTH HAZARD ASSESSMENT OF PHYSICOCHEMICAL PROPERTIES Not relevant for this type of dossier. 7 ENVIRONMENTAL HAZARD ASSESSMENT Not relevant for this type of dossier 8 PBT, VPVB AND EQUIVALENT LEVEL OF CONCERN ASSESSMENT Not relevant for this type of dossier 7
INFORMATION ON USE, EXPOSURE, ALTERNATIVES AND RISKS This section is based on information for 2,4-Dinitrotoluene taken from the EU Risk Assessment Report and the Risk Reduction Strategy. Additional information from the New Member States reported in 2005 has been added since it was uncovered in the quoted reports. 1 INFORMATION ON EXPOSURE 2,4-Dinitrotoluene is commercially available as a purified isomer or as a component of DNT mixtures. This substance can be produced by a two-step nitration of toluene in a closed system process producing a mixture, the commercial or technical grade, of approximately 80% ratios of 2,4-dinitrotoluene and 20% of 2,6-dinitrotoluene. If the single 2,4-isomer is required, the nitration can be stopped at the mono-stage and pure p-nitrotoluene is obtained by crystallization. Subsequent nitration of the p-nitrotoluene yields only 2,4-dinitrotoluene. Following EU RAR (2008), 2,4-dinitrotoluene is primarily used as a chemical intermediate in the production of toluene diisocyanate (4-methyl-m-phenylenediisocyanate). 2,4-Dinitrotoluene is hydrogenated to yield TDA and this diamine is reacted with phosgene to yield TDI, which is used to make flexible polyurethane foams. According to bibliography, 2,4-dinitrotoluene has several other minor uses. It is used as gelatinizing-plasticizing agent in both commercial and military explosive compositions. Its use in automotive airbags has been cited. Uses as intermediates in the synthesis of azodyes have been described as former uses in the literature. At the time data were collected for the purpose of risk assessment, the substance was produced in Europe by three companies in three European countries. All manufacturers had reported manufacture of DNT as a non-isolated intermediate in the synthesis of TDA. A minor use of the pure substance as an additive in the production of explosives was also reported, though information had only been obtained by one European company that imported the substance. In the RAR, the total EU production volume of dinitrotoluene as a mixture of isomers (80:20) was estimated as 629,949 tons in 2004. Then, a production volume of 503,959 tons of 2,4-dinitrotoluene could be estimated in that year. In addition, an amount of 11 to 50 tons/year of the pure product was imported by one company for use in explosives. These estimations were not related to the situation in the New Member States. Information voluntary collected by these countries in 2005 (Poland, Latvia, Estonia, Lithuania, Hungary, Czech Republic, Slovakia, Cyprus) showed that in one of these countries, one company had reported an imported volume of 10,000-100,000 tonnage in 2003 and another company had reported a production volume of 100-1000 tonnage in 2003. In another of them, one company had reported an imported quantity of 100-200 tonnes in year 2002 of the pure substance for use in explosives. In addition, data from Nordic Database SPIN shows that 84 tonnes were used in 2007 for explosives in one Nordic country. According to this information, the amount of the substance used in this country steadily augmented during the 2005-2007 period. The envisaged registration deadline for this substance is 30/11/2010. 111 preregistrations have been reported. Human exposure to 2,4-dinitrotoluene occurs primarily through occupational sources. It has not been identified in consumer products. Directive 2003/34 EC, amending for the 23 rd time Directive 8
76/769/EEC, bans the placing on the market of this substance for use by the general public (this provision is now specified in Entry 28 of Commission Regulation (EC) No 552/2009, amending Annex XVII of REACH Regulation, which repealed Directive 76/769/EEC with effect from 01.June 2009). Occupational exposure According to EU RAR (2008), occupational exposure to 2,4-dinitrotoluene is possible during its use as a chemical intermediate essentially in TDI production in closed installations. Most TDI producers use toluene as the starting material, generating 2,4-dinitrotoluene as a captive intermediate in the process. The only identified end-use of 2,4-dinitrotoluene not involving chemical conversion is its use as a minor component of gunpowder. Therefore, the following scenarios are considered: Scenario 1: Production and further processing of 2,4 DNT: Exposure is expected in those activities where the system is breached such as collection of samples for quality control and maintenance. Scenario 2: Explosives Manufacture: Pure 2,4 dinitrotoluene is used as an additive in the production of explosives (less than 1%, solid gunpowder formulations). Workers exposure would mainly occur during tasks such as weighing and charging. Scenario 3: Use of explosives: The recipients of the explosive formulation are companies dedicated to the manufacture of cartridges and munitions. Potential for exposure could be possible during charging of the system. External exposure by inhalation and dermal routes is assessed in all scenarios. The exposure assessment is based on measured data obtained from industry or from the literature and modelled data derived from EASE model (EASE for Windows Version 2.0) and RISKOFDERM potential dermal exposure model (EXCEL version 2.0, October 2005). Table 2: Summary of the occupational exposure levels Exposure Scenario (Relevant Tasks) Inhalation exposure RWC Typical Short- term mg/m 3 Method mg/m 3 Method mg/m 3 Method Dermal exposure RWC (mg/day) Method Manufacture (Sampling and maintenance) Explosives Manufacture (Weighing and charging) Use of explosives (Charging) 0.009 Measured 0.0007 Measured 0.018 Calculated 0-2.1 EASE (90% protection by suitable gloves) 0.15 EASE 0.075 Calculated 0.3 Calculated 3 RISKOFDERM (unprotected workers) 0.006 EASE 0.003 Calculated 0.012 Calculated 0.42-4.2 EASE (unprotected workers) 9
Consumer exposure There is no information about 2,4-dinitrotoluene in consumer products in the EU RAR (2008). According to Directive 2003/34/EC, since 15 January 2005, the use of this substance and preparations containing it should not be placed on the market for use by the general public. Humans exposed via the environment Indirect exposure of humans to 2,4-dinitrotoluene via the environment may occur by consumption of food (fish, crops, meat and milk), drinking water and inhalation of air. In the EU RAR (2008), exposure estimates were performed according to EUSES. The resultant daily doses for the uptake of 2,4-dinitrotoluene are in the table below: Table 3: Daily Human Doses (mg/kg/d) Intake route Local site A Local site B Local site D Local site E Regional Drinking water 8.62 10-6 1.24 10-4 6.46 10-7 3.43 10-6 5.1 10-7 Fish 4.77 10-6 6.87 10-5 3.57 10-7 2 10-6 2.8 10-7 Leaf crops 1.24 10-7 7.71 10-8 2.12 10-7 8.15 10-8 6.4 10-8 Root crops 1.8 10-8 1.8 10-8 1.81 10-8 1.8 10-8 1.2 10-8 Meat 1.76 10-10 2.47 10-9 2.15 10-11 7.15 10-11 1.3 10-11 Milk 1.09 10-9 1.52 10-8 1.33 10-10 4.41 10-10 7.9 10-11 Air 1.76 10-9 5.89 10-10 3.61 10-9 8.76 10-10 5.9 10-10 Total 1.35 10-5 1.93 10-4 1.24 10-6 5.53 10-6 8.7 10-7 Combined exposure Exposure to 2,4-dinitrotoluene may reasonably be predicted to arise as a result of combined exposure from workplace and environmental sources. 2 INFORMATION ON ALTERNATIVES There is no information on alternatives. 3 RISK-RELATED INFORMATION Risk related information is summarized from the European Union Risk Assessment Report for 2,4- Dinitrotoluene (EU RAR, 2008) 10
Human Health The EU RAR (2008) identified carcinogenicity and mutagenicity as the key areas of concern because it is not possible to identify a clear threshold below which there would be no risk of cancer for the development of these effects in humans. Workers A quantitative risk characterisation according to the T25 approach was performed in order to estimate the level of concern for the assessed scenarios. Data for calculating T25 were obtained from the life-time oral carcinogenicity studies performed in rats. A T25 value of 14.39 mg/kg/day calculated for the incidence of hepatocellular carcinomas in male rats was considered the critical value to be used for carcinogenicity risk characterization. Then, a human equivalent of the animal dose-descriptor, i.e. the HT25 (4.13 mg/kg/day) was calculated. This value was subsequently used for calculating lifetime cancer risks associated with actual exposure scenarios by linear extrapolation. According to it, the exposure scenario life-time cancer risk for workers for the three scenarios, by both inhalation and dermal routes, are relatively greater to the established default cancer risk value of 10-5 (values for life cancer risk specific for scenarios 1, 2 and 3 are 9.27 10-5, 5.56 10-4, 1.48 10-4, respectively). In addition, 2,4-dinitrotoluene is classified as mutagenic category 3. Overall, it is considered that risk reduction measures are required and conclusion (iii) applies. Conclusion iii): There is a need for limiting the risks; risk reduction measures which are already being applied shall be taken into account. Carcinogenicity is the critical effect. Controls aimed at reducing cancer should also reduce the risk of other effects. Due to the genotoxicity of 2,4-dinitrotoluene, it is not possible to identify a clear threshold below which there would be no increased risk of cancer. In such a situation, it is important that exposures be controlled to as low as technically feasible. Consumers Exposure of consumers is not assumed to exist. Therefore, the conclusion (ii) is reached. Conclusion ii): There is at present no need for further information and/or testing and for risk reduction measures beyond those which are being applied already. Humans exposed via the environment Conclusion ii) was obtained in the EU RAR (2008) for all effects except for mutagenicity and carcinogenicity. These effects do not allow the identification of a threshold level of exposure below which there would be no risk for the development of these effects. However, based on the calculated life time cancer risk, the risk is judged to be tolerable for the regional scale and for local scenarios (A, D and E). The calculated life-time cancer risk for the local scenario B 1.7 10-5 is slightly higher than the established default cancer risk value of 10-5. Overall, conclusion (iii) can be derived for inhalation and oral exposure for the local scenario B. However, exposure modelling of exposure via the environment indicates very low daily intakes, suggesting low concern. Conclusion iii): There is a need for limiting the risks; risk reduction measures which are already being applied shall be taken into account. 11
Combined exposure Exposure to 2,4-dinitrotoluene may reasonably be predicted to arise as a result of combined exposure from workplace and environmental sources. The risk to human health under conditions of combined exposure is dominated by occupational exposure. Thus, the conclusions of the risk characterisation for combined exposure reflect those reached for workers. In relation to mutagenicity and carcinogenicity, the available data for 2,4-dinitrotoluene do not allow the identification of a threshold level of exposure below which there would be no risk for the development of these effects. Therefore, the conclusion (iii) is reached. Conclusion iii): There is a need for limiting the risks; risk reduction measures which are already being applied shall be taken into account. OTHER INFORMATION 2,4-Dinitrotoluene is on the 4 th priority list under Council Regulation (EEC) Nº 793/93 on the Control and Evaluation of the Risks of Existing Substances with Spain as Rapporteur. The final Risk Assessment Report was published by the ECB in 2008. The last literature research for the RAR was carried out in 2005. In the framework of the development of a Risk Reduction Strategy for 2,4-dinitrotoluene, industry manufacturers were consulted again. The resulting RRS was endorsed at the 14 th RRS Meeting and published in the Official Journal in 2008 (OJ 2008/L141/20). All the information showed in this Annex XV dossier is mainly based on these reports. Full references for this information can be found in the EU Risk Assessment Report on 2,4- Dinitrotoluene. European Commission (2008); Risk Assessment of 2,4-Dinitrotoluene. http://ecb.jrc.ec.europa.eu/documents/existing-chemicals/risk_assessment/report/24dinitrotoluenereport411.pdf REFERENCES EU RAR, 2008: European Union Risk Assessment Report, 2,4-Dinitrotoluene. CAS No: 121-14-2. EINECS No: 204-450-0. OJ 2008/L141/20 Commission Recommendation on risk reduction measures for the substance 2,4- dinitrotoluene. CAS No: 121-14-2. EINECS No: 204-450-0. Substances in Preparations in Nordic Countries database. SPIN (2007) 12