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SRP: The most favorable course of action is to use an alternative chemical product with less inherent propensity for occupational exposure or environmental contamination. Recycle any unused portion of the material for its approved use or return it to the manufacturer or supplier. Ultimate disposal of the chemical must consider: the material's impact on air quality; potential migration in soil or water; effects on animal, aquatic, and plant life; and conformance with environmental and public health regulations.

Disposal of Fyrol 6 at the manufacturing site is done in a closed wastewater treatment system.

TERRESTRIAL FATE: Based on a classification scheme(1), an estimated Koc value of 9.7(SRC), determined from a log Kow of -0.72(2) and a regression-derived equation(3), indicates that diethyl ((diethanolamino)methyl) phosphonate is expected to have very high mobility in soil(SRC). The estimated pKa of diethyl ((diethanolamino)methyl) phosphonate is 5.6(4), indicating that this compound is expected to partially exist in the protonated form in the environment, and cations generally adsorb to organic carbon and clay more strongly than their neutral counterparts(5). Volatilization of diethyl ((diethanolamino)methyl) phosphonate from moist soil surfaces is not expected(SRC) given an estimated Henry's Law constant of 1.6X10-7 atm-cu m/mole(SRC), derived from its vapor pressure, 0.43 mm Hg(2), and water solubility, 900 g/L(2). Diethyl ((diethanolamino)methyl) phosphonate is not expected to volatilize from dry soil surfaces(SRC) based upon its vapor pressure(2). Diethyl ((diethanolamino)methyl) phosphaonte was found to biodegrade 15-19% after 28 days in a modified Sturm test(2). Based on this screening test, diethyl ((diethanolamino)methyl) phosphonate would be expected to biodegrade slowly in soil(SRC).[(1) Swann RL et al; Res Rev 85: 17-28 (1983) (2) US EPA; High Production Volume (HPV) Challenge Program. The HPV Voluntary Challenge Chemical List. Robust Summaries and Test Plans. Phosphonic Acid, [

AQUATIC FATE: Based on a classification scheme(1), an estimated Koc value of 9.7(SRC), determined from a log Kow of -0.72(2) and a regression-derived equation(3), indicates that diethyl ((diethanolamino)methyl) phosphonate is not expected to adsorb to suspended solids and sediment(SRC). Volatilization from water surfaces is not expected(3) based upon an estimated Henry's Law constant of 1.6X10-7 atm-cu m/mole(SRC), derived from its vapor pressure, 0.43 mm Hg(2), and water solubility, 900 g/L(2). The estimated pKa of diethyl ((diethanolamino)methyl) phosphonate is 5.6(4), indicating that this compound is expected to partially exist in the protonated form in the environment, and cations generally adsorb to organic carbon and clay more strongly than their neutral counterparts(5). In general, hydrolysis may be an important fate for phosphonic acid esters at basic pH's(3). According to a classification scheme(6), an estimated BCF of 3.2(SRC), determined from its log Kow of -0.72(2) and a regression-derived equation(7), suggests the potential for bioconcentration in aquatic organisms is low(SRC). Diethyl ((diethanolamino)methyl) phosphonate was found to biodegrade 15-19% after 28 days in a modified Sturm test(2). Based on this screening test, diethyl ((diethanolamino)methyl) phosphonate would be expected to biodegrade slowly in water(SRC).[(1) Swann RL et al; Res Rev 85: 17-28 (1983) (2) US EPA; High Production Volume (HPV) Challenge Program. The HPV Voluntary Challenge Chemical List. Robust Summaries and Test Plans. Phosphonic Acid, [

ATMOSPHERIC FATE: According to a model of gas/particle partitioning of semivolatile organic compounds in the atmosphere(1), diethyl ((diethanolamino)methyl) phosphonate, which has a vapor pressure of 0.43 mm Hg at 20 °C(2), is expected to exist solely as a vapor in the ambient atmosphere. Vapor-phase diethyl ((diethanolamino)methyl) phosphonate is degraded in the atmosphere by reaction with photochemically-produced hydroxyl radicals(SRC); the half-life for this reaction in air is estimated to be 2.7 hours(SRC), calculated from its rate constant of 1.4X10-10 cu cm/molecule-sec at 25 °C(SRC) that was derived using a structure estimation method(3). Diethyl ((diethanolamino)methyl) phosphonate is not expected to be susceptible to direct photolysis by sunlight, since it does not contain functional groups that are expected to absorb light with wavelengths >290 nm(SRC).[(1) Bidleman TF; Environ Sci Technol 22: 361-367 (1988) (2) US EPA; High Production Volume (HPV) Challenge Program. The HPV Voluntary Challenge Chemical List. Robust Summaries and Test Plans. Phosphonic Acid, [

The Koc of diethyl ((diethanolamino)methyl) phosphonate is estimated as 9.7(SRC), using a log Kow of -0.72(1) and a regression-derived equation(2). According to a classification scheme(3), this estimated Koc value suggests that diethyl ((diethanolamino)methyl) phosphonate is expected to have very high mobility in soil. However, the estimated pKa of diethyl ((diethanolamino)methyl) phosphonate is 5.6(4), indicating that this compound is expected to partially exist in the protonated form in the environment, and cations generally adsorb to organic carbon and clay more strongly than their neutral counterparts(5).[(1) US EPA; High Production Volume (HPV) Challenge Program. The HPV Voluntary Challenge Chemical List. Robust Summaries and Test Plans. Phosphonic Acid, [

Diethyl ((diethanolamino)methyl) phosphonate's production and use as a flame retardant in rigid polyurethane foams(1,2) may result in its release to the environment through various waste streams(SRC).[(1) US EPA; High Production Volume (HPV) Challenge Program. The HPV Voluntary Challenge Chemical List. Robust Summaries and Test Plans. Phosphonic Acid, [

AEROBIC: Diethyl ((diethanolamino)methyl) phosphonate at concentrations of 10 and 20 mg/L was found to biodegrade 15 and 19%, respectively, after 28 days in a modified Sturm test using activated sludge from a municipal sewage treatment plant(1).[(1) US EPA; High Production Volume (HPV) Challenge Program. The HPV Voluntary Challenge Chemical List. Robust Summaries and Test Plans. Phosphonic Acid, [

An estimated BCF of 3.2 was calculated for diethyl ((diethanolamino)methyl) phosphonate(SRC), using a log Kow of -0.72(1) and a regression-derived equation(2). According to a classification scheme(3), this BCF suggests the potential for bioconcentration in aquatic organisms is low(SRC).[(1) US EPA; High Production Volume (HPV) Challenge Program. The HPV Voluntary Challenge Chemical List. Robust Summaries and Test Plans. Phosphonic Acid, [

The Henry's Law constant for diethyl ((diethanolamino)methyl) phosphonate is estimated as 1.6X10-7 atm-cu m/mole(SRC) derived from its vapor pressure, 0.43 mm Hg(1), and water solubility, 900 g/L(1). This Henry's Law constant indicates that diethyl ((diethanolamino)methyl) phosphonate is not expected to volatilize from water surfaces(2). Diethyl ((diethanolamino)methyl) phosphonate's estimated Henry's Law constant indicates that volatilization from moist soil surfaces is not expected(SRC). Diethyl ((diethanolamino)methyl) phosphonate is not expected to volatilize from dry soil surfaces(SRC) based upon its vapor pressure(1).[(1) US EPA; High Production Volume (HPV) Challenge Program. The HPV Voluntary Challenge Chemical List. Robust Summaries and Test Plans. Phosphonic Acid, [

/LABORATORY ANIMALS: Acute Exposure/ Clinical signs of toxicity /in Sprague-Dawley rats after an oral dose of 5000 mg/kg/ were mild depression, piloerection, alopecia and red facial stains. All animals appeared normal by day 2 /of observation/. The only effect seen at necropsy was reddened intestines.

/LABORATORY ANIMALS: Acute Exposure/ There was no mortality /in Stauffland albino rabbits after dermal administration of 2000 mg/kg Fyrol 6 for 24 hr/. Clinical signs of toxicity were mild depression. All animals appeared normal by day 1 /of observation/. Local dermal effects included mild erythema and edema. There were no adverse effects at necropsy.

/LABORATORY ANIMALS: Acute Exposure/ /In a test for eye irritation, 9 Stauffland albino rabbits were exposed to 0.1 mL of Fyrol 6./ Eyes of 3 animals /were/ washed after 20-30 seconds of exposure. Eyes of the other 6 animals were not washed. There was mild conjunctival irritation in 6 rabbits with unwashed eyes and no effects in the 3 rabbits with washed eyes. The irritation cleared by the 72 hour observation period. ...Fyrol 6 was mildly irritating to rabbits.

/LABORATORY ANIMALS: Subchronic or Prechronic Exposure/ /Sprague-Dawley rats, 22/sex/dose, were administered 20, 100, 500 mg/kg/day Fyrol 6 by gavage once daily for 13 weeks, 7 days/wk. Control: Mortality -3 females (dosing accident) and 3 males (dosing accident); Macroscopic examination- enlarged liver in 8 animals. 500 mg/kg/day: Mortality- 1 male (dosing accident) and 6 females (dosing accident); Clinical signs- alopecia, darker coloration of eyes, chromorhinorrhea; Clinical chemistry- increase in white blood cells; lower hemoglobin and hematocrit; Macroscopic exam- discoloration of lungs, thymus, liver and kidney and enlarged liver; Organ weights- significant increase in mean absolute and relative liver weight and an increase in mean absolute and relative kidney weight; Microscopic exam- very slight hepatocellular hypertrophy, cytoplasmic eosinophilia of centrilobular hepatocytes. 100 mg/kg/day- Mortality- 5 males (dosing accident) and 2 females (dosing accident); Clinical signs- alopecia; Clinical chemistry- decrease in red blood cells; Macroscopic examination- discoloration of lungs, liver and kidney and enlarged liver; Organ weights- increase in mean relative liver and absolute and relative kidney weight; Microscopic examination- very slight hepatocellular hypertrophy, cytoplasmic eosinophilia of centrilobular hepatocytes. 20 mg/kg/day- Mortality- One male (dosing accident) and 3 females (dosing accident); Clinical signs- alopecia; Clinical chemistry- decrease in red blood cells; Macroscopic examination- discoloration of lungs and kidney and enlarged liver; Organ weights- no changes; Microscopic examination- no changes. There were no signs of functional changes in the kidney and liver of animals in any dose groups. Fyrol 6 administered daily by oral gavage to rats for 13 weeks resulted in minor histopathological changes in the liver at doses of 100 and 500 mg/kg/day. These results were considered an adaptive rather than a toxic response to Fyrol 6. The NOAEL was 500 mg/kg/day.

The rate constant for the vapor-phase reaction of diethyl ((diethanolamino)methyl) phosphonate with photochemically-produced hydroxyl radicals has been estimated to be 1.4X10-10 cu cm/molecule-sec at 25 °C(SRC) using a structure estimation method(1). This corresponds to an atmospheric half-life of about 2.7 hours at an atmospheric concentration of 5X10+5 hydroxyl radicals per cu cm(1). Diethyl ((diethanolamino)methyl) phosphonate is not expected to be susceptible to direct photolysis by sunlight, since it does not contain functional groups that are expected to absorb light with wavelengths >290 nm (SRC). In general, hydrolysis may be an important fate for phosphonic acid esters at basic pH's(2).

NIOSH (NOES Survey 1974) has statistically estimated that 441 workers are potentially exposed to diethyl ((diethanolamino)methyl) phosphonate in the US(1). Occupational exposure to diethyl ((diethanolamino)methyl) phosphonate may occur through inhalation and dermal contact with this compound at workplaces where diethyl ((diethanolamino)methyl) phosphonate is produced or used(SRC). Exposure to the general population would not be expected(SRC), since diethyl ((diethanolamino)methyl) phosphonate reacts and becomes an integral part of the foam structure when it is added to polyurethane foams as flame retardants(2,3).[(1) NIOSH; National Occupational Exposure Survey (NOES) (1974) (2) US EPA; High Production Volume (HPV) Challenge Program. The HPV Voluntary Challenge Chemical List. Robust Summaries and Test Plans. Phosphonic Acid, [

Diethyl ((diethanolamino)methyl) phosphonate's production and use as a flame retardant in rigid polyurethane foams may result in its release to the environment through various waste streams. If released to air, a vapor pressure of 0.43 mm Hg at 20 °C indicates diethyl ((diethanolamino)methyl) phosphonate will exist solely as a vapor in the ambient atmosphere. Vapor-phase diethyl ((diethanolamino)methyl) phosphonate will be degraded in the atmosphere by reaction with photochemically-produced hydroxyl radicals; the half-life for this reaction in air is estimated to be 2.7 hours. Diethyl ((diethanolamino)methyl) phosphonate is not expected to be susceptible to direct photolysis by sunlight, since it does not contain functional groups that are expected to absorb light with wavelengths >290 nm. If released to soil, diethyl ((diethanolamino)methyl) phosphonate is expected to have very high mobility based upon an estimated Koc of 9.7. Volatilization from moist soil surfaces is not expected to be an important fate process based upon an estimated Henry's Law constant of 1.6X10-7 atm-cu m/mole. The estimated pKa of diethyl ((diethanolamino)methyl) phosphonate is 5.6, indicating that this compound is expected to exist partially in the protonated form in the environment, and cations generally adsorb to organic carbon and clay more strongly than their neutral counterparts. Diethyl ((diethanolamino)methyl) phosphonate is not expected to volatilize from dry soil surfaces based upon its vapor pressure. If released into water, diethyl ((diethanolamino)methyl) phosphonate is not expected to adsorb to suspended solids and sediment based upon the estimated Koc. Diethyl ((diethanolamino)methyl) phosphonate was found to biodegrade 15-19% after 28 days in a modified Sturm test. Based on this screening test, diethyl ((diethanolamino)methyl) phosphonate would be expected to biodegrade slowly in the environment. Volatilization from water surfaces is not expected to be an important fate process based upon this compound's estimated Henry's Law constant. An estimated BCF of 3.2 suggests the potential for bioconcentration in aquatic organisms is low. In general, hydrolysis may be an important fate for phosphonic acid esters at basic pH's. Occupational exposure to diethyl ((diethanolamino)methyl) phosphonate may occur through inhalation and dermal contact with this compound at workplaces where diethyl ((diethanolamino)methyl) phosphonate is produced or used. Exposure to the general population would not be expected, since diethyl ((diethanolamino)methyl) phosphonate reacts and becomes an integral part of the foam structure when it is added to polyurethane foams as a flame retardant. (SRC)

Basic treatment: Establish a patent airway. Suction if necessary. Watch for signs of respiratory insufficiency and assist ventilations if needed. Administer oxygen by nonrebreather mask at 10 to 15 L/min. Monitor for pulmonary edema and treat if necessary ... . Monitor for shock and treat if necessary ... . Anticipate seizures and treat if necessary ... . For eye contamination, flush eyes immediately with water. Irrigate each eye continuously with normal saline during transport ... . Do not use emetics. For ingestion, rinse mouth and administer 5 ml/kg up to 200 ml of water for dilution if the patient can swallow, has a strong gag reflex, and does not drool ... . Cover skin burns with dry sterile dressings after decontamination ... . /Poison A and B/

Advanced treatment: Consider orotracheal or nasotracheal intubation for airway control in the patient who is unconscious, has severe pulmonary edema, or is in respiratory arrest. Positive pressure ventilation techniques with a bag valve mask device may be beneficial. Monitor cardiac rhythm and treat arrhythmias as necessary ... . Start an IV with D5W /SRP: "To keep open", minimal flow rate/. Use lactated Ringer's if signs of hypovolemia are present. Watch for signs of fluid overload. Consider drug therapy for pulmonary edema ... . For hypotension with signs of hypovolemia, administer fluid cautiously. Watch for signs of fluid overload ... . Treat seizures with diazepam (Valium) ... . Use proparacaine hydrochloride to assist eye irrigation ... . /Poison A and B/