File No: NA/458
Date: December 1996
NATIONAL INDUSTRIAL CHEMICALS NOTIFICATION
AND ASSESSMENT SCHEME
FULL PUBLIC REPORT
Polymer in NALMET 8702
This Assessment has been compiled in accordance with the provisions of the
Industrial Chemicals (Notification and Assessment) Act 1989 (the Act), and
Regulations. This legislation is an Act of the Commonwealth of Australia. The
National Industrial Chemicals Notification and Assessment Scheme (NICNAS) is
administered by Worksafe Australia which also conducts the occupational health &
safety assessment. The assessment of environmental hazard is conducted by the
Department of the Environment, Sport, and Territories and the assessment of
public health is conducted by the Department of Health and Family Services.
For the purposes of subsection 78(1) of the Act, copies of this full public report may
be inspected by the public at the Library, Worksafe Australia, 92-94 Parramatta
Road, Camperdown NSW 2050, between the following hours:
Monday - Wednesday 8.30 am - 5.00 pm
Thursday 8.30 am - 8.00 pm
Friday 8.30 am - 5.00 pm
For Enquiries please contact the Administration Coordinator at:
Street Address: 92 Parramatta Rd Camperdown, NSW 2050, AUSTRALIA
Postal Address: GPO Box 58, Sydney 2001, AUSTRALIA
Telephone: (61) (02) 9577-9466 FAX (61) (02) 9577-9465
Director
Chemicals Notification and Assessment
NA/458
FULL PUBLIC REPORT
Polymer in NALMET 8702
1. APPLICANT
Nalco Australia Pty Ltd of 2 Anderson Street BOTANY NSW 2109 has submitted a
limited notification statement in support of their application for an assessment
certificate for Polymer in NALMET 8702.
2. IDENTITY OF THE CHEMICAL
Polymer in NALMET 8702 has been classified as hazardous by Worksafe
Australia due to its irritant potential, this is due to the impurity sodium hydroxide
which is at the threshold value for classification as a hazardous material of 1%.
However for commercial reasons, the chemical identity, chemical composition
and spectral data relating to the polymer have been granted exemption from
publication in the Full Public Report and Summary Report.
Other Names: none
Trade Name: NALMET 8702 (contains notified polymer)
Number-Average > 1 000
Molecular Weight:
Maximum Percentage of Low
Molecular Weight Species
Molecular Weight < 500: < 1%
Molecular Weight < 1 000: < 15%
3. PHYSICAL AND CHEMICAL PROPERTIES
Appearance at 20癈 hazy, light yellow liquid with a sulphurous odour
and 101.3 kPa:
Boiling Point: 100癈 (at 760 mm Hg)
Density: 1.1-1.3 g/cm (polymer in water solution)
FULL PUBLIC REPORT 2
Vapour Pressure: 2.40 kPa at 25癈
Water Solubility: stated as completely miscible
Partition Co-efficient
(n-octanol/water): see comments
Hydrolysis as a Function < 10% hydrolysis after 5 days
of pH: at pH 4, 7 & 9
Adsorption/Desorption: see comments
Dissociation Constant: see comments
Flash Point: > 61癈
Flammability Limits: not flammable
Autoignition Temperature: not determined
Explosive Properties: not explosive
Reactivity/Stability: not reactive, stable
Comments on Physico-Chemical Properties
The company has stated that NALMET 8702 (which contains 44% of the notified
product) is water miscible in all proportions. This is based on bench experiments,
a laboratory report is not available. The notified polymer contains a group which is
expected to hydrolyse under acidic conditions. The polymer would be expected to
remain stable under the normal environmental pH range. No test for partition co-
efficient has been conducted. The notifier expects this to be low due to the high
water solubility of the polymer. Due to the expected low partition coefficient and
high water solubility, the notified polymer would not be expected to adsorb to
organic matter in soils or water. However, because of the anionic form in solution,
it may be expected to adsorb to cations in clays and silicates. The polymer would
be expected to fully dissociate in water in the environmental pH range.
4. PURITY OF THE CHEMICAL
Degree of Purity: high
Toxic or Hazardous
Impurities: contains a chemical that is an eye and skin
irritant, is harmful by inhalation and is a teratogen
(1); however, the concentration of this chemical is
well below the threshold for classification as a
hazardous substance (harmful) according to
Worksafe Australia's List of Designated
Hazardous Substances
FULL PUBLIC REPORT 3
Chemical name: sodium hydroxide
Synonyms: caustic soda
sodium hydrate
CAS No.: 1310-73-2
Weight percentage: 1.0%
irritant and corrosive, threshold for classification
Toxic properties:
as a hazardous substance (irritant) is 1.0%
according to Worksafe Australia's List of
Designated Hazardous Substances, on this
basis polymer is classified as hazardous; NaOH
is a Type III ingredient according to Worksafe
Australia's Control of Workplace Hazardous
Substances (2)
Non-hazardous Impurities
(> 1% by weight):
Chemical name: sodium chloride
Synonyms: salt
Weight percentage: < 3%
CAS No.: 7647-14-5
Maximum Content see hazardous impurities
of Residual Monomers:
Additives/Adjuvants: Formulation, NALMET 8702, consists of water
and other ingredients determined not to be
hazardous, refer to Material Safety Data Sheet
(MSDS)
5. USE, VOLUME AND FORMULATION
An annual importation volume of between 1 and 5 tonnes of the notified polymer is
expected over the first five years. It will be imported in 200 L steel drums by sea,
and transported to the notifier's site at Botany, New South Wales.
The notified chemical contains metal chelating groups attached to a polymer
backbone, making it effective in precipitating heavy metal ions from solution. The
product (containing the notified chemical) is expected to be used in industrial
waste water treatment, for reduction of heavy metals in wastewater which will then
be disposed or to sewer, or reused.
FULL PUBLIC REPORT 4
6. OCCUPATIONAL EXPOSURE
The notified polymer will be imported in a formulation, NALMET 8702, containing
the polymer, in 200 L steel drums. These drums will be transported to the
notifier's warehouse for decanting, repackaging and quality assurance testing.
Occupational exposure during transport and warehousing is unlikely and will only
occur in the event of accidental release. The formulation is classified under the
Australian Dangerous Goods Code (3) as a corrosive liquid with the Hazchem
code 2R.
Decanting into smaller containers will be undertaken with automatic pumping
equipment in well ventilated areas. This task and sampling for quality control will
be performed by four operators for periods of 2-5 hours/day for 30 days/year.
Three quality control chemists will analyse the formulation, the chemists will
potentially be exposed to the notified chemical for 4-8 hours/day for 30 days/year.
The group with the highest level of exposure to the notified chemical will be those
associated with the end use of the product as a water treatment chemical. Many
sales staff will be involved in distribution and implementation of the treatment
system. The latter involves setting up the feed equipment and verifying the required
dosage levels. These staff will potentially be exposed for periods of 4-8 hours/day
for 200 days/year. The water treatment plant operators will maintain the feed
systems by setting and testing the dosage levels. The notified chemical will be
diluted to 10-40 ppm in the dosed wastewater. The treatment plant operators will
potentially be exposed for periods of 1-2 hours/day for 340 days/year.
The treatment dosage equipment is automated however, there will be potential for
occupational exposure during maintenance and filling of the equipment. The low
volatility of the formulation will limit inhalational exposure. The main routes of
exposure will be dermal and ocular. The caustic nature of the formulation
indicates that exposure via these routes should be minimised, the most
appropriate methods include the use of appropriate personnel protective
equipment.
7. PUBLIC EXPOSURE
No public exposure is expected to occur during storage, decanting or distribution of
the notified polymer.
Only industrial use of the notified polymer is anticipated as the product, NALMET
8702, will not be sold to the public. Although, some operator exposure is expected
to occur, it is unlikely that the public would be exposed to the notified polymer
during its industrial use.
It has been estimated that approximately 95 to 99% of the notified polymer will
absorb onto metal/solids during treatment of the wastewater. Such metals/solids
will be removed from wastewater and then disposed of to landfill. In addition, it
has been estimated that wastewater released to sewer may contain approximately
FULL PUBLIC REPORT 5
0.1 to 2 ppm of the notified polymer. Overall, public exposure to the notified
polymer will be minimal.
8. ENVIRONMENTAL EXPOSURE
Release
Upon arrival at the notifier's Botany site, the product will, in most cases, be
repackaged into other containers. Generally, it will be transferred to the notifiers
purpose designed containers, or smaller pails. This repackaging will be carried
out either by automatic pumping or gravity feed. Any residue remaining in empty
drums will be washed with water and disposed of to a liquid waste treatment
facility. Generally, the purpose designed containers will not require washing
before re-filling as they are product dedicated. The notifier has estimated release
from repacking operations to be 1% (up to 50 kg annually) of the product.
Repacking is expected to occur on 30 days of the year, giving a daily release of
around 1.7 kg.
Dilution of the imported product occurs when waste water treatment facilities are
dosed. Typically, the concentration of NALMET 8702 in the dose system is less
than 0.1%
The major release of the notified product will occur on discharge from treatment
plants. Discharge from treatment plants will depend on the size of the operation,
and is estimated to be between 3 and 30 KL a day. A typical treatment plant will
have a `balance tank' to maintain a constant discharge rate to sewer.
In the presence of water containing heavy metals or suspended solids, the notifier
has indicated that between 95 to 99% of the polymer is expected to absorb onto
the metals/solids and be removed from the water phase. Based on the
assumption that 95% of the polymer is released in this manner through end use,
and that release from industry occurs over 200 days of the year, the following
release figures are derived:
Operation Volume % Release/yea Days/ year Release/day
releas r
e
Repack 5000 kg 1 50 kg 30 1.67 kg
END USE
Removal from 4950 kg 95 4702 kg 200 23.5 kg
water phase
(landfill)
Release to sewer 4950 kg 5 248 kg 200 1.24 kg
The estimated releases due to end use will be spread over a number of sites
around Australia.
FULL PUBLIC REPORT 6
Fate
The notified chemical is to be used in wastewater treatment plants to scavenge
heavy metals generated in the electroplating and metal finishing industry. As such,
the majority of the polymer will be removed from the water phase through
absorption onto the metals/solids, and the sludge disposed of to landfill where it
would be expected to remain associated with the metals or clay particles due to
ionic bonding, or sent to have the metals reclaimed.
A proportion of the chemical will not be bound to metals/solids within the
wastewater treatment plant, but will be released to sewer. The notifier estimates
that water released to sewer will contain the polymer at less than 2 ppm. This
polymer could be expected to further bind to cations within the sewage treatment
plant, and be landfilled. A small proportion may be discharged to receiving waters
where it could be expected to remain associated with clay or silicates.
No ready biodegradation test was provided. Biochemical Oxygen Demand (BOD)
values were provided as BOD (20 days) = 100 mg/L; and BOD (5 days) greater
than 50 mg/L. While this indicates some degradation, it is not certain whether the
notified polymer itself is degrading, or other structures within the test system, such
as low molecular weight material.
Bioaccumulation of the polymer is not expected because of its high water solubility
and high molecular weight which is likely to inhibit membrane permeability and
prevent uptake during exposure.
The company has submitted a label and an MSDS for the notified polymer which
has adequate recommendations for disposal and handling accidental spillage.
9. EVALUATION OF TOXICOLOGICAL DATA
No toxicological data are required for polymers of NAMW greater than 1 000
according to the Act and none are available for either the polymer in isolation or as
a component of the formulation NALMET 8702.
10. ASSESSMENT OF ENVIRONMENTAL EFFECTS
No ecotoxicological data are required for polymers of NAMW greater than 1 000
according to the Act. However, several ecotoxicity test results were provided by the
notifier and are summarised as follows: (S = static; NC = nominal concentration).
FULL PUBLIC REPORT 7
Species Test (Conditions) Result (mg/L)
Fathead minnow (Pimephales promelas) 96 hour (S; NC) LC 50 > 1 000
Sheepshead minnow (Cyprinodon 96 hour (S; NC) LC 50 > 1 000
variegatus)
Silverside (Menidia beryllina) 96 hour (S; NC) LC 50 > 1 000
Rainbow trout (Oncorhynchus mykiss) 96 hour (S; NC) LC 50 = 20
Mysid shrimp (Mysidopsis bahia) 96 hour (S; NC) LC 50 = 140
Water flea (Daphnia magna) 48 hour (S; NC) LC 50 = 11
LC 50 values for Fathead minnow can be considered questionable. Like Rainbow
trout, this is a freshwater fish, and was tested in carbon filtered, dechlorinated tap
water. The definitive test was carried out at one concentration only, 1 000 mg/L
(ppm), and no deaths were recorded. This is despite two screening tests where
all test fish had died between 10 mg/L and 100 mg/L. Why the definitive test was
conducted at such a high concentration is unclear given the results of the
screening tests. An explanation for the lack of toxicity at higher concentrations may
be due to the nature of the polymer. It is an anionic polymer which would be
expected to exhibit flocculant characteristics. At 1000 ppm, high turbidity of the test
solution was observed, which could be due to flocculation of the chemical, thereby
reducing its content in solution and thus its bioavailability. Turbidity of water was
not observed at lower concentrations (< 30 ppm) in other tests, meaning more
chemical could be in solution, and therefore exhibit increased toxicity.
A further anomaly is found in the Sheepshead minnow toxicity test. Again, the
definitive test was only conducted at 1 000 ppm, even though the screening test
showed 0% survival at 10 ppm (and 100% survival at 100 ppm).
Both Sheepshead minnow and Silverside are saltwater species, and were tested
in natural seawater. This may provide an explanation for the increased tolerance
of these species to the polymer. Being natural seawater, as opposed to clean
laboratory water, there would be present a number of impurities such as dissolved
organic carbon (DOC) which has been shown by a number of authors to reduce
the apparent toxicity of polyelectrolyte flocculants (4). Although no fish deaths were
reported during testing of silverside, a LOEC = 1 000 mg/L was found, as almost
half the fish in the treated groups were surfacing at 24 hours.
Turbidity of the test water was a common observation for all tests. With the
exception of water fleas and rainbow trout, this turbidity was observed at higher
concentrations, around 1000 ppm. During preliminary testing of Rainbow trout and
Daphnia, cloudiness was observed at 30 to 300 ppm concentration in test waters.
Rainbow trout effected during testing were lethargic and darker in colour than
control fish. No other sub-lethal effects were observed.
The definitive test was conducted at five concentrations: 13, 22, 36, 60 and 100
mg/L. After 96 hours, 100% survival was observed in the 13 mg/L concentration,
with 20% survival in the 22 mg/L concentration. No survival was observed in the
other test concentrations.
FULL PUBLIC REPORT 8
The 96 hour NOEC for mysid shrimp was found to be 100 mg/L as one of the ten
mysids was swimming erratically at 72 hours.
Screen testing of water fleas showed no sub-lethal effects. All ten animals were
dead at 48 hours in both the 100 and 1000 mg/L solutions, with 80% dead at 10
mg/L.
The results indicate that the notified substance is slightly to moderately toxic to
water fleas, moderately to practically non-toxic to fish depending on test conditions,
and practically non-toxic to shrimp.
No tests were carried out on algae. Polyanionic polymers (the notified polymer is
in this class) which are water soluble, and have a MW greater than 1 000 are of
concern for aquatic toxicity (5). Algae could be of concern because of anionic
polymer's ability to chelate nutrient elements needed by algae for growth. No
results appear to be available for this class of anionic polymer in the literature.
11. ASSESSMENT OF ENVIRONMENTAL HAZARD
The notifier has estimated discharge from treatment plants to be between 3 000
and 30 000 litres per day, depending on the size of the operation. As a worst case
scenario, we have assumed in the following calculations, that the largest
estimated daily discharge occurs to a country sewer, and 3 of the largest
estimated daily discharges occur to a city sewer.
A predicted environmental concentration (PEC) has been derived as follows:
City Country
Daily discharge from treatment plant (L) 90 000 30 000
Dosing rate 40 ppm 40 ppm
% removed through chelation with metal ions Nil Nil
Total quantity released to sewer 3.6 kg 1.2 kg
Daily output from Sewage Treatment Plant (STP) 200 ML5 ML
Concentration in STP 18 ppb 0.24 ppm
The PEC has been derived assuming none of the notified chemical is removed
through association with heavy metals/solids in wastewater treatment plants, the
total treatment plant volume is released to the sewer each day.
Australian and New Zealand Environment and Conservation Council (ANZECC) (6)
water quality guidelines recommend, that to obtain `safe' levels in water when only
acute toxicity data are available, the application factor for a persistent chemical is
derived by 0.01 x LC 50. The lowest observed LC 50 = 11 ppm for daphnia.
Therefore, according to these guidelines, the `safe' level of this polymer in water is
0.11 ppm.
FULL PUBLIC REPORT 9
It can be seen that the PEC in a country sewer is 0.24 ppm. Assuming dilution of 2
to 1 in receiving waters, the PEC is 0.12, which is very similar to that derived using
the ANZECC guidelines.
These figures do indicate caution is required when discharging the notified
polymer to sewer. However, it should be remembered that the PEC's were
obtained assuming no removal in the water treatment plant through association
with metal and solids and no removal in the sewage treatment plant through
association with cations and suspended solids. Additionally, when released to
receiving waters, this chemical would be expected to further bind to clays and
silicates, and toxicity would be further mitigated due to dissolved organic carbon
available in receiving waters.
12. ASSESSMENT OF PUBLIC AND OCCUPATIONAL HEALTH AND SAFETY
EFFECTS
The notified polymer has a NAMW of greater than 1 000 and is therefore not
expected to traverse biological membranes and constitute a toxicological hazard.
The notified polymer contains low levels of residual monomers/hazardous
impurities including a proprietary ingredient, sodium hydroxide (1.0%) and low
molecular weight species (< 15% with NAMW < 1 000). The sodium hydroxide
concentration is equivalent to the threshold for classification as hazardous
according to the List of Designated Hazardous Substances (1), on this basis the
polymer is classified as hazardous. However, the hazardous impurities will be
present at extremely low levels in treated wastewater and therefore are not
expected to present a toxicological threat during use in water treatment systems.
The imported formulation NALMET 8702 is caustic/corrosive (pH 11.5-13) and is
classified as hazardous according to the Australian Code for the Transport of
Dangerous Goods by Road and Rail (3). On this basis the formulation would also
be classified as hazardous according to the Worksafe Australia criteria (7) even
though the levels of hazardous impurities in the formulation are below the
threshold values requiring hazardous classification according to Worksafe
Australia's, List of Designated Hazardous Substances (1).
Occupational exposure to the notified polymer is unlikely to occur during transport
and warehousing. Exposure may occur during repackaging when the imported
formulation is decanted into smaller containers. Exposure may also occur during
sampling and analysis for quality assurance. These processes will occur in well
ventilated situations and the procedures involved will limit occupational exposure.
Occupational exposure will be greatest during end use of the formulation where it
will be dosed into water treatment systems. The groups with greatest potential for
exposure are the sales representatives and water treatment plant operators.
Exposure will potentially be dermal or ocular. The caustic nature of the formulation
indicates that this should be avoided. When handling the formulation the
appropriate personnel protective equipment should be used.
It is not anticipated that the public would be exposed to the notified polymer. If
public contact with the notified polymer were to occur, the high NAMW for the
FULL PUBLIC REPORT 10
polymer suggests that absorption is unlikely, and therefore there is negligible risk
to public safety. Public exposure to the formulation, NALMET 8702 is also unlikely.
13. RECOMMENDATIONS
To minimise occupational exposure to Polymer in NALMET 8702 the following
guidelines and precautions should be observed:
Safety goggles should be selected and fitted in accordance with Australian
?br>
Standard (AS) 1336 (8) to comply with Australian/New Zealand Standard
(AS/NZS) 1337 (9);
Industrial clothing should conform to the specifications detailed in AS 2919
?br>
(10) and AS 3765.1 (11);
Impermeable gloves or mittens should conform to AS 2161 (12);
?br>
All occupational footwear should conform to AS/NZS 2210 (13);
?br>
Spillage of the notified chemical should be avoided, spillages should be
?br>
cleaned up promptly with absorbents which should then be put into
containers for disposal;
Good personal hygiene should be practised to minimise the potential for
?br>
ingestion;
A copy of the MSDS should be easily accessible to employees.
?br>
14. MATERIAL SAFETY DATA SHEET
The MSDS for the formulation containing the notified chemical was provided in
accordance with the National Code of Practice for the Preparation of Material Safety
Data Sheets (14 ).
This MSDS was provided by the applicant as part of the notification statement. It is
reproduced here as a matter of public record. The accuracy of this information
remains the responsibility of the applicant.
15. REQUIREMENTS FOR SECONDARY NOTIFICATION
Under the Act, secondary notification of the notified chemical shall be required if
any of the circumstances stipulated under subsection 64(2) of the Act arise. A
secondary notification will be required if the annual import volume exceeds 10
tonnes per annum, or if the use of this product leads to an increased exposure to
the aquatic compartment than the uses in this assessment.
FULL PUBLIC REPORT 11
16. REFERENCES
1. National Occupational Health and Safety Commission 1994, List of
Designated Hazardous Substances [NOHSC:10005(1994)], Australian
Government Publishing Service Publ., Canberra.
2. National Occupational Health and Safety Commission 1994, Control of
Workplace Hazardous Substances [NOHSC:1005(1994), 2007(1994)],
Australian Government Publishing Service, Canberra, Australia.
3. Federal Office for Road Safety 1992, Australian Code for the Transport of
Dangerous Goods by Road and Rail, 5th Edition, Australian Government
Publishing Service Publ., Canberra.
4. Lamberton C. J. 1995, Acute Toxicity and Management of Polyelectrolyte
Flocculants in Australian Aquatic Ecosystems. Master of Applied Science
(Environmental Toxicology) Thesis, University of Technology, Sydney, 1995.
5. Nabholz J.V., Miller P., Zeeman M. 1993, Environmental Risk Assessment of
New Chemicals Under the Toxic Substances Control Act (TSCA) Section
Five. In "Environmental Toxicology and Risk Assessment." ASTM STP
1179. G. Landis, J.S. Hughes, M.A. Lewis (eds). American Society for
Testing and Materials, Philadelphia. pp 40-45.
6. ANZECC (Australian and New Zealand Environment and Conservation
Council), November 1992, National Water Quality Management Strategy.
Australian Water Quality Guidelines for Fresh and Marine Waters.
7. National Occupational Health and Safety Commission 1994, Approved
Criteria for Classifying Hazardous Substances [NOHSC:1008(1994)],
Australian Government Publishing Service, Canberra.
8. Standards Australia 1994, Australian Standard 1336-1994, Eye protection in
the Industrial Environment, Standards Association of Australia Publ.,
Sydney.
9. Standards Australia/Standards New Zealand 1992, Australian/New Zealand
Standard 1337-1992, Eye Protectors for Industrial Applications, Standards
Association of Australia Publ., Sydney, Standards Association of New
Zealand Publ, Wellington.
10. Standards Australia 1987, Australian Standard 2919-1987, Industrial
Clothing, Standards Association of Australian Publ., Sydney.
11. Standards Australia 1990, Australian Standard 3765.1-1990, Clothing for
Protection against Hazardous Chemicals Part 1 Protection against General
or Specific Chemicals, Standards Association of Australia Publ., Sydney.
FULL PUBLIC REPORT 12
12. Standards Australia 1978, Australian Standard 2161-1978, Industrial Safety
Gloves and Mittens (excluding electrical and medical gloves), Standards
Association of Australia Publ., Sydney.
13. National Occupational Health and Safety Commission 1994, National Code
of Practice for the Preparation of Material Safety Data Sheets
[NOHSC:2011(1994)], Australian Government Publishing Service, Canberra.
FULL PUBLIC REPORT 13
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