Document XRK6rZYnNVRkYpZN3pqaD56GJ

P^ TX-^ % A C U TE TOXICITY TO FISH (FATHEAD MINNOW) TEST SUBSTANCE Identity: Perfluorooctanesulfonylamido(ethyl)acetate; may also be referred to as PFOSAA, FC-128 or as the major component of FC-127, FC-129, FC-109, or FC-109-X. (Glycine, N-ethyl-N[(heptadecafluorooctyl)sulfonyl]-, potassium salt, CAS #299151-7) Remarks: The test sample is FC-109-X referred to by the test laboratory as E2566-2. Current information indicates it is a mixture of 1923% test substance, 61% water, 12% 2-methoxymethylethoxypropanol, 2% ethanol, and 2-6% C4-C7 fluoroalkyl carboxylate compounds. Test material was from 3M production lot 2. mDtThhaeixetattufeomrsleltaosoywufnibtnohsgettaastnceuccsmeut.mrsauatberyslytiasrneaclabetbeinretoavxiawictaeittdyebro/eofcrthgaeaunsteeicststhosealvtmeesnpttlessaowmluitphtiloetnhi.astaof METHOD: Methods: O ECD 203 Test type: Static acute GLP: Yes Year Completed: 1988 Species: Pimephales promelas Analytical monitoring: Temperature, pH, DO Statistical analysis: LC50 values were calculated using the program developed by Stephan et al. RESULTS Nominal concentrations: Bk control, 10,18, 32, 56,100,180, 320 mg/L Element values: 96-hour LC50 = 57 (36-93) mg/L 96-hour NO EL = <10 mg/L All element values based on nominal concentrations. Remarks: Testing was conducted on the mixture of the test substance as described in the test substance remarks field. The value reported applies to that mixture and not the test substance. No attempt was made to determine the impact of the presence of the organic solvents or what portion of the toxicity can be contributed to the Perfluorooctanesulfonylamido(ethyl)acetate. 0002C3 C O N C LU S IO N S The FC-109-X 96-hour LC 50 for Pimephales promelas was determined to be 57 mg/L with a 95% confidence interval of 36-93 mg/L. The 96-hour no observed effect level was <10 mg/L. Submitter: 3M Company, Environmental Laboratory, P.O. Box 33331, St. Paul, Minnesota, 55133 DATA QUALITY Reliability: Klimisch ranking 2. Testing meets all criteria for quality testing, but lacks analytical confirmation of test substance concentrations. There is a lack of characterization of the test sample. REFERENCES This study was conducted at Analytical Bio-Chemistry Laboratories, Inc. of Columbia, Missouri at the request of the 3M Company. OTHER Last changed: 5/17/00 000234 SIONSOR 3M Company Aten: Mr. Mohamed Elnabaravy EE 5 PC Environmental Labs Building 21-2W-05, 90 Bush Avenue St. Paul, Minnesota 55106 BEST COPY AVAILABLE STUDY TITLE Acute Toxicity of E2566-2 to Fathead Minnow (Pimeph.iles promelas) DATA REQUIREMENT OECD Guideline 203 AUTHOR Jane H. Bowman Biologist I STUDY COMPLETED ON January 12, 1988 PERFORMING LABORATORY Analytical Bio-Chemistry Laboratories, Inc Aquatic Toxicology Division 7200 East ABC Lane P.O. Box 1097 Columbia, Missouri 65205 ABC LABORATORY PROJECT ID #36617 Page 1 of 63 000235 Submitted By Analytical Bio-Chemistry Laboratories, Inc. 72C0 East ABC Lane ?. 0. Box 1097 Columbia, Missouri 652C5 (314) 74-8579 Prepared By: BEST copy AM flABLE Jane "H. Sovran Biologist IZ;'Study director Laura Muller Biologist 1 Late 'j''?-X V Date Approved By: :dab31 Mi Jarjs P. Svigert , ?b.D. Supervisor, Fish Acute/ Chronic Investigations Date Phillip M. Buckler Quality Assurance Supervisor /' 'v. v Carl M. Thompson *o Aquatic Toxicology Manager ---- & r> T 'DateDate 000236 ABCLABS #36617-2 of 63 1 S T COPY AVAILABLE TA3LE OF CONTESTS Page So. LIST OF ILLUSTRATION'S..........................................36617-4 PROJECT PERSONNEL .............................................. 36617-5 FISH ACUTE TOXICITY COMPENDIUM................................. 36617-6 S U M M A R Y ........................................................ 36617-7 INTRODUCTION.................................................... 36617-8 METHODS AND MATERIALS .......................................... 36tl7-S I. Test F i s h ............................................ 2t517-8 II. Test M a t e r i a l ........................................ 3*61'-S III. Test Water. . . ; .................................... 2t6l7-9 IV. Biological Test Procedure . . . ...................... 3661?-? V. Biological Data Analysis. . . . ...................... 3r6!7-5 REsULTS. . . . . ... ... . . . . . . . . . . . . . . . . . .3661* -- 0 LITERATURE CITED. . . . . . . . ............................... 36617-16 QUALITY ASSURANCE STATEMENT .. . . ............................ 36617-17 STUDY COMPLIANCE STATEMENT. .. . . . . . . . . ................ 36617-18 000237 ABC LASS 36617-3 of 63 LIST OF ILLUSTRATIONS BEST COPY AVAILABL Table So. T<i;e So. 1 Chemical Characterise. ..s cf Veil Vate: '.sei by ABC's Aquatic Toxicology Divis lor.............. ***! T-- 12. 'y Acute Toxicity of E2566-2 to Fathead Mirrov (Picephales p r o n e l a s ) ............................. .-*'*I !1 3 Mortality Rates ard Vater Quality Measurererts Turing the Acute Toxicity Test o: Eli---I to Fathead Minaev (Fitserhales rrore'a v .............. 3 - r i K i c u r e No. i S l o p e o f D o s e - F . e s p o r . s e L i r e a t bt> ' -r E2566-2 t o F a t h e a d M a a c w ( P i r e p f s p r o r e l a s ) ................................................................................................................................................................................................. . - . 000238 ABC LASS of 63 BEST COPY AVAILABLE PROJECT PERSONNEL The study director of the project for Analytical Bio-Chemistry Laboratories, Inc. was Ms. Jane H. Bowman, Biologist II. Supervising the conduct of the study for 3M Company was Mr. Mohamed Elnabaravy. The following ABC personnel assisted with various phases of the study. Name Jane H. Bowman Laura Mullen Chris Brenneke James P. Ewigere, Ph.D. Title Biologist II Biologist I Biological Technician I Supervisor, Fish Acute/ Chronic Investigations Initials ! I" )'1 000239 ABC LABS 436617-5 of 63 REST COPY AVAILABLE FISH ACUTE TOXICITY COMPENDIUM Subject: "Acute Toxicity of E2566-2 to Fathead Minnow (Piaephales promelas) A B C Study Number 36617. Sponsor: 3M Company V Testing Facility: Analytical Bio-Chemistry Laboratories, Inc. Aquatic Toxicology Division P.O. Box 1097 Columbia, Missouri 65205 (314-474-8579) Location o: Original Raw Data and Final Report: 3M Company St. Paul, Minnesota 55106 Test Material: F.2566-2 Test Concentrations: Control, 10, 18, 32, 56, 100, 180 and 320 mg/1 Dilution Water: 42 mg/1 (hardness), 32 mg/1 (alkalinity), 7.4 (pH) Test Dates: Initiation - January 8, 1988 Termination - January 12, 1988 Length of Study: 96-hours Results: 96-hour I.Cj q " 57 mg/1 (95% C.I. " 36-93 mg/1) 96-hour NOEL *'.<10 mg/1 96-hour Slope of the,Dose-Response Line was 16 Test Species: Fathead Minnow (Pimephales promelas) Source of Organisms: ABC Laboratories in-house culture Mean Weight: 0.061 g (i0.037 g) Mean Length: 17 no (2.2 ms) 000240 ABC LABS i''36617-6 of 63 FISH ACUTE TOXICITY COMPENDIUM Subject: "Acute Toxicity cf E2566-2 to Fathead Minnow (Pinephales procelusl.** ABC Study Nuaber 36617. Sponsor: 3M Conpary Testing Facility: Analytical Bio-Cheaistry Laboratories, Icc. Aquatic Toxicology Division P.0. Box 1097 Columbia, Missouri 65205 (314-474-8579) Location e:' Original Raw Data arc Final Report : 3M Ccnpar.v St. Paul, Minnesota 55106 Test Material: E2S66-2 Test Concentratlens: Control, 10, 18, 32, 56, 100, 180 and 320 ng/1 Dilution Water: 42 ragtl (hardness), 32 cg/l (alkalinity), 7.4 (pH) Test Dates: Initiation - January 8, 1SS8 Tenaination - January 12, 1988 Length of Study: 96-hours Results; 96-hour LC^Q - 57 ag/1 (952 C.I. - 36-93 ag/1} 96-hour NOEL - <10 ag/1 96-hour Slope of the Dose-Response Line was 16 Test Species: Fathead Minnow (Piaephales pror.elas) Source of Organisms: ABC Laboratories in-house culture Mean Weight: O.Obl g (10.037 g) Mean Length: 17 res (i2.2 na) 000241 ABC LABS 56617-6 of 63 BEST COPY AVAILABLE SUMMARY The acute toxicity of E2566-2 to fathead minnow (fioephal.es prone las) was assessed using the methods outlined by the Committee on Methods for Toxicity Tests with Aquatic Organisms. Water quality parameters of temperature, dissolved oxygen and pH were measured throughout the test and were within acceptable limits. Culture and acclimation records Indicated the fish were in good condition for testing. The study was conducted at the following nominal concentrations of E2566-2: 10, 18, 32, 56, 100, 180 and 320 mg/1. At 0-hour, the 8, 32. 56, 100, 180 and 320 mg/1 solutions had a white surface film. The amount of surface film increased with the concentration from a very slight amount in the 18 mg/1 solution to a thicker, nearly complete covering over the 320 mg/1 solution. After 24 hours, a slight surface film also appeared over the 10 mg/1 solution while the other solutions had a surface film increasing with the concentration. At the 72- and 96-hour observations the 100, 180 dnd 320 mg/1 solutions were cloudy and all solutions had a surface film that increased in proportion to the concentration. Ten fish, with a mean weight of 0.061 (i0.037) g and a mean standard length of 17 (2.2) mm, were exposed to each test concentration and control. The results of the four day static fish toxicity study using E2566-2 are summarized below. The 24-, 48- and 72-hour LC,Q values were also determined. The 96-hour slope of the dose response line was 16. Compound 96-Hour I-Cj0 (95Z C.I.) E2566-2 57 mg/1 (36-93 mg/1) Also, the results indicated a 96-hour, no-observed effect concen tration could be estimated at <10 mg/1, the lowest concentration tested. Abnormal effects of mortality, surfacing, loss of equilibrium, dark discoloration, fish on the bottom of test chamber, quiescence and/or excitability were observed during the 96-hour exposure period in the 10, 18, 56, 100, 180 and 320 mg/1 test concentrations. One fish in the control c>.amber was quiescent and on the bottom of the test chamber at the 96-hour observation. 000242 ABC LABS 036617-7 of 63 BEST COPY AVAILABLE INTRODUCTION . . This static bioassay was performed by the Aquatic Toxicology Division of Analytical Bio-Chemistry Laboratories, Inc., Columbia, Missouri, for 3M Company, from January 8, 1988 to January 12, 1988. The purpose of this test was to determine the 24-, 48- ami 96-hour I.C., levels for E2566-2 to fathead minnow yPlmephalas promo las). preliminary range-finding study was conducted from December 31, 1987 to January 4, 1988 to determine the concentration range for the definitive bloa&say. The study was conducted following the procedures outlined in ABC Protocol Number 7601 (Raw Data), as approved by Mr. Mohatned .Elnabarawy, 3M Company, on January 7, 1968 METHODS AND MATERIALS The procedures for static bioasaay, as described in Methods of Acute Toxicity Tests with Fish, Macrolnvertehrates amt Amphibians (1) and Standard Methods for Examination ot Water and Wastewater (2), were used in this experiment. I.' Test Fish The fathead minnow (ABC Lot #2287 FUM) used in the test were obtained from an ABC Labs in-house culture. All test fish were held in culture tanks on a 16-hour daylight photoperiod and observed for at least fourteen days prior to testing. Fish culture techniques used were basically those described by Brauhn et al. (3). A daily record of fish observations during the holding period, along with any prophylactic or therapeutic disease treatments, is included in the Paw Data, During this period, the fish received a stan dard commercial fish food occasionally supplemented with brine shrimp nauplii (Artemis sp.) daily until 48-96 hours prior to . testing at which time feeding was discontinued. The fathead minnow used for this experiment had a mean weight of 0.061 (iO.037) g and a mean standard length of 17 (t2.2) mm. This gave a test chamber loading biomass of 0.041 g/1 for the definitive study. Weight and length measurements were made on the control group of fish at the termination of the test and arc Included in the Raw Data, II. Test Material The E2566-2 sample was received on December 29, 1987, in good condition. The sample upon receipt was observed to be a foam; yellow liquid and was stored at room temperature, 'Sample purity was not specified. The definitive test concentrations were obtained by transferring appropriate weights of test compound directly Vo the test chambers. All test concentrations were based on the total compound, i.e. not corrected for sample purity. All standard weights and dilution values are listed in the Raw Data. ABC LABS 036617-6 o f 63 BEST COPY AVAILABLE Test Water The static fish bioassay was conducted in five gallon glass vessels containing 15 liters of soft reconstituted water composed of the following compounds in the amounts stated per liter of deionised water: 48 mg NaHCOj 30 mg CaS04 *2 1^0 30 mg MgSO^ 2 mg KC1 This reconstituted water was prepared to yield a total hardness of 40-48 rag/i as CaCO-, a total alkalinity of 25-35 tng/1 as CaCOj and an initial pH of 7.2 to 7.6. The C-hcur measured control water parameters of this dilution water were dissolved oxygen 9.3 mg/1 and pH 7.4. The well water source from which this dilution water was prepared had the charac teristics shown in Table 1. The test vessels were kept in a water bath at 223C (1.0). The test fish were acclimated to the dilution water and test temperature and held without food for 48-96 hours prior to testing. An acclimation record is included in the Raw Data. Biological Test Procedure A range-finding test of 96-houro duration was conducted to determine the concentration range for the definitive study. The preliminary test concentrations were set at 30, 100 and 320 mg/1. Based on the results of preliminary testing, seven concentrations of the test compound, ranging in a logarithmic series from 10 to 320 mg/1, with ten fish per concentration were selected for the definitive bloassay. Also included was a dilution water control. The fish were added to the test chambers by random assignment within 30 minutes after addition of test material. All test organisms were observed once every 24 hours for mortality and abnormal (sub-lethal) effects. Any dead individuals were removed from the test 'chambers after each 24-hour observation. Biological Data Analysis Statistical analysis of the concentration vs. effect data (generally mortality) was obtained by employing a computerized LC,n program developed by Stephan et al. (4). This program calculated the LC,-. statistic and its 95 percent confidence limits using the binomial, the moving average and the probit tests. However, if no mortality occurred or if a dcse response could not be demonstrated over a reasonable range ('-37 to'^SZ), an I.C^q and/or its 95 percent confidence limits 000244 A3C I.ABS #36617-9 of 63 BEST COPY AVAILABLE could not be calculated. Three different methods of analyzing the data were used since no one method of analysis is appro priate for all possible sets of data that cay be obtained. The method of calculation selected for presentation ir. this report was that which gave the narrowest confidence limits for the ICjq (4, 5) although all three models are valid. The concentration-mortality curve was constructed for the 96-hour mortality data. The slope of the dose-response line was reported as calculated by least squares regression analysis (log of concentration vs. probit transformation of percent mortality). RESULTS The results of the 96-hour static toxicity test with fathead minnow (Pimephales pronelas) exposed to E2566-2 are presented in Table 2. '.he 24-, 46- and 9o-hour LC,._ values for E2566-2 were >320, 160 and 57 cg/1, respectively. The 96-nour slope of the dose-response curve was 16 (Figure l). All results were based or. the nominal concentrations of 10, !8, 32, 56, 100, 180 ar.d 320 cg/1. At 0-hour, the IB, 32, 56, 100, 180 and 320 cg/1 solutions had a white surface film. The amount of surface film increased with the concentration from a very slight amount in the 18 cg/1 solution to a thicker, nearly complete covering over the 320 mg/1 solution. After 24 hours a slight surface film also appeared over the 10 mg/1 solution while the other solutions had a surface film increasing with the concentration. At the 72- and 96-hour observations the 100, 180 and 320 mg/1 solutions were cloudy and all solutions had a surface film chat increased in proportion to the concentration. The 96-hour no-observed effect concentration was estimated to be <10 mg/1, the lowest concentration tested. The abnormal effects of mortality, surfacing, loss of equilibrium, dark discoloration, fish on the bottom of test chamber, quiescence and/or excitability were observed in the 10, 18, 56, 100, 180 and 320 mg/1 test concentrations during the 96-hour exposure period. One fish in the control chamber was quiescent and on the bottom of the test chamber at the 96-hour observation. The 10 mg/1 chamber also had 202 mortality at 96 hours while the 18 and 32 mg/1 chambers had 02 mortality. An examination of the fish culture and acclimation records for this test Indicated that the fish were in good condition for testing (Raw Data). Nominal test concentrations, mortality rates and water quality data are presented in Table 3. The dissolved oxygen concentrations ranged from 6.8 to 9.8 mg/1 during the test. These values represented 81 and 1172 saturation at 22C, respectively, and were considered adequate for testing .1), therefore, the test chambers were rot aerated during testing. The pll values ranged from 7.2 to 7.9. ABC LABS 36617-10 of 63 BEST COPY AVAILABLE The study was conducted following the intent of the Good Laboratory Practice Regulations (6) end the final report was reviewed by Analytical Bio-Chemistry Laboratories' Quality Assurance Unit. All original raw data was provided to 3>! Company, with a copy retained at Analytical Bio-Chemistry Laboratories. 000246 ABC LABS #36617-11 of 63 BEST COPY AVAILABLE TABLE 1 Chenical Characteristics of Veil Water Used by ABC's Aquatic Toxicology Division. Parameter Temperature Dissolved Oxygena pH Hardness (CaCO^) Alkalinity (CaCO^) Conductivity Total Organic Carbon Suspended Solids Aluminum Arsenic Boron Cadmium Chromium Cobalt Copper Iron Lead Mercury Nickel Silver Zinc Measured organophosphorus pesticides Measured organochlorine pesticides plus PCB's Concentration 17 - 22*Cb 7.4 - 9.1 ppmb 7.6 - 8.4b 206 - 275 ppmb 224 - 336 ppmb 500 - 650 -_zhos/c:n 1 . 4 ppnc (0.9 - 2.8 ppm) 0 - 1 . 3 ppab <10 ppb < l ppb 2.25 ppm <3 ppb <7 ppb <3 ppb <3 ppb 14 ppb <30 ppb 0.43 ppb <8 ppb <4 ppb 2 ppb <0.14 ppb <1.0 ppb After aeration "Renresents seasonal variation, difference from one month to the next, will not exceed 102 cAverage of all well water values from January-September, 1987 "Total monthly range of organic carbon Sample dates: Trace elements June 3, 1987, organophosphate and organochlorine analyses May 28, 1987. 000247 ABC LASS -'36617-12 of 63 BEST COPY AVAILABLE TABLE 2 Acute Toxicity of E2566-2 to Fathead Minnow (Plmephales pronelas) Compound E2566-23 LCjq in nilligrans/liter (ppa) 24 hours > 3 2 0 ib) 48 hours 160(3' 96 hours 5-12) (120-2I0)C {36-93)c N = 10 fish per concentration. aBlcassay as conducted at 22C (tl.O), mean fish weight and length, 0.061 (i0.037)g and 17 (t2.7)mm. bLC^0 could not be calculated due to insufficient mortality data. C95S confidence limits. The 96-hour no-observed effect concentration could be estimated at <10 mg/1. The 96-hour slope of the dose-response line was 16 as calculated by least squares regression analysis. i.. All values were rounded to two significant figures following ABC S.O.P. 13.7. LCj q calculated using: ^ B i n o m i a l Method ( 2) Moving Average Method ^ P r o b i t Method 000248 ABC LABS #36617-13 of 63 <10 by K?, ABC LABS *36617-14 of 61 TABLE 3 Mortality Rates and Water Quality Measurements During the Acute Toxicity Teat of F.2566-2 to Fathead Minnow (Plsophales pronelas) Nominal Concentration (mg/1) Control 10 18 32 56 100 180 320 Percent Mortality Hours 24 68 9 6 0 00 0 0 20 0 c0 0 00 0 10 30 0 10 100 0 50 100 10 100 100 Water Quality Temp. cC 22 nn a p/l 9 .3 pHb 7.4 Temp, D .O . *C nj?/l 22 6 . 2 E iL 7.4 Temp. c 22 D .O . mc/1 e .i 22 9 . 2 7.5 4 ** 8 . 2 7.4 22 7.4 22 7.5 9 .3 7.5 22 7.5 7.3 31 6 .8 22 7.0 22 9.5 7.6 22 7.5 7.4 22 7.4 7.3 22 9.8 7.9 pH 7.5 7.4 7.4 7.2 7.3 ^Dissolved oxygen concentrations - Dissolved Oxygen Probe (YS1 Model 54). ^pH - p H Probe (Corning Model 476182) used with a Corning Model 123 pH and mV meter. NOTE: Dissolved oxygen saturation corrected for altitude at the test temperature of 22*C is 8.4 mg/1. t9 3 s t - n m # shvi -Hiv percent mortality Figure 1 Slope of Dose-Response Line at 96 Hours for E2566-2 to Fathead Minnow (Piffephales prooelas) cs> 6.0 6.5 4.0 A .5 5.0 5.5 PROBITS c 3-0 3.5 LITERATURE CITED BEST COPY AVAILABLE (1) Committee on Methods for Toxicity Tests with Aquatic Organisms (C. E. Stephan, Chairman). 1975. Methods for Acute Toxicity Tests with Fish, Macroirtvertebrates and Amphibians. Environmental Protection Agency, Ecological Research Series EPA-660/3-75-0C9, April, 1975. 61 p. (2) American Public Health Association. 1980. Standard Methods for the Examination of Water and Wastewater. 15th ed. Washington, DC. 1134 p. (3) Brauhn, J. L. and R. A. Schoettger. 1975. Acquisition and Culture of Research Fish: Rainbow Trout, Fathead Minnows, Channel Catfish and Bluegills. Environmental Protection. Agency, Ecological Re search Series EPA-660/3-75-011, May, 1975. 45 p. (4) Stephan, C. E., K. A. Busch, R. Smith, J. Burke and R. V. Andrew. 1978. A computer program for calculating an LC-q . T. S. Environ mental Protection Agency, Duluth, Minnesota, pre-publicaticn . .manuscript, August, 1978. (5) Stephan, C. 1977. Methods for calculating an LC.^, p. 65-34. In F. L. Mayer and J. L. Haaelink (eds.). Aquatic Toxicology and Hazard Evaluation. ASTM Special Technical Publication 634. ASTM. Philadelphia. (6) (a) U. S. Food and Drug Administration. 1978. Nonclir.ical Laboratory Studies, Good Laboratory Practice Regulations (21 CFR, Part 58). Federal Register, Vol. 43, No. 247:59986- 60025. (b) U. S. Environmental Protection Agency. 1983. Pesticide Programs; Good Laboratory Practice Standards; Final Rule (40 CFR, Part 160). Federal Register, Vol. 48, No. 230: 53946-53969. (c) U. S. Environmental Protection Agency. 1983. Toxic Sub stances Control; Good Laboratory Practice Standards; Final Rule (40 CFR, Part 792). Federal Register, Vol. 48; No. 230:53922-53944. (d) Organization for Economic Cooperation and Development. 1981. OECD Guidelines for Testing of Chemicals, Principles of Good Laboratory Practice Annex 2, C(81) 30(Final):7-28. 000251 ABC LABS 36617-16 of 63 BEST COPY AVAILABLE QUALITY ASSURANCE STATEMENT Quality Assurance Statement for final report #36617 entitled, "Acute Toxicity of E2566-2 to Fathead Minnow (Pimephales procelas) ," for Mr. Mohamed Elnabaravy, 3M Company, St. Paul, Minnesota. In accordance with ABC Laboratories' intent that all studies con ducted at our facilities are designed and function in conformance with good laboratory practice regulations and the protocols for individual laboratory studies, an inspection of the final report for E2566-2 was conducted and found to be In an acceptable fora by a member of our Quality Assurance Unit. An inspection of the daily mortality rate of the test organisms prior to the initiation of the study Indicated they were in good health and should not bias the observed mortality in the study. A procedure audit was conducted on January 8, 1988. Results were reported to the study director on January 8, 1988. Results were reported to management on January 20, 1988. A final inspection of all data and records on January 20, 1988 indicated that the report submitted to you is an accurate reflection of the study as it was conducted by A3C Laboratories. Should you have any questions relating to the information provided in this statement or the function of our Quality Assurance Unit, please contact the Quality Assurance Unit at your convenience. Us jfj ^Philiip^M. Buckler ~ Quality Assurance Supervisor Date 000252 ABC LABS #36617-17 of 63 BEST COPY AVAILABLE STUDY COMPLIANCE STATEMENT Study Compliance Statement for ABC report #36617 entitled, "Acute Toxicity of E2566-2 to Fathead Minnow (Pimephales promelas) f o r Mr. Mohamed Elr.abaravy, 3M Company, St. Paul, Minnesota. lr. accordance with ABC Laboratories' intent that all aquatic toxi city tests conducted by our facility follow good laboratory practices, ABC's study director for the above test herein confirms that the study was conducted in compliance with the OECD Principles of Good Laboratory Practice Annex 2, C(81), OECD Guidelines for Testing of Chemicals. All original raw data were provided to 3M Company, with a copy retained at Analytical Bio-Chemistry Laboratories. Jane R. Bowman ABC Study Director Date 000253 ABC LABS #36617-18 of 63 COPY AVAILABLE Raw Data Report #36617 Acute Toxicity of E2566-2 to Fathead Minnow (Pimephales pronelas) NOTE: Some of the records which appear in this raw data appendix have been provided as photocopies of original records on file at ABC. This has been done by necessity for certain data which are used commonly in several studies at ABC. Such records include acclimation records, organism culture legs and well water chemical screen results. 000254 ABCLABSftO3bb I 1 pg. 00IQ,of00b3