Registration Dossier

Administrative data

Description of key information

The skin irritation profile of benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts (registered/target substance) was determined in an in vitro corrosivity (OECD 435) and skin irritation (OECD 439) assays. An in vivo rabbit study (OECD 404) on a read across source substance confirmed these non-skin irritation results. The eye irritation profile of the registered/target substance was determined by eye in vitro toxicity studies following OECD guidelines 437 (Bovine Corneal Opacity and Permeability Test) and 492 (Reconstructed Human Cornea-like Epithelium Test). Several in vivo rabbit studies on read across source substance confirmed these eye non-irritation results.

Key value for chemical safety assessment

Skin irritation / corrosion

Link to relevant study records

Referenceopen allclose all

Endpoint:
skin corrosion: in vitro / ex vivo
Remarks:
in vitro
Type of information:
experimental study
Adequacy of study:
key study
Study period:
29 Sep 2017 to 06 Oct 2017
Reliability:
1 (reliable without restriction)
Rationale for reliability incl. deficiencies:
guideline study
Remarks:
Study completed according to OECD 435 Guidelines, and under GLP.
Qualifier:
according to
Guideline:
OECD Guideline 435 (In Vitro Membrane Barrier Test Method for Skin Corrosion)
GLP compliance:
yes (incl. certificate)
Test system:
other: Corrositex Kit Biobarriers
Source species:
other:
Cell type:
other:
Cell source:
other:
Vehicle:
water
Control samples:
yes, concurrent negative control
yes, concurrent positive control
Species:
other: N/A - Macromolecular Barrier
Type of coverage:
other: In vitro
Vehicle:
water
Remarks:
Tissue culture water
Controls:
yes, concurrent vehicle
yes, concurrent positive control
yes, concurrent negative control
Amount / concentration applied:
500 μl of the test article to each of four test vials containing biobarriers
Duration of treatment / exposure:
Single Exposure
Observation period:
Theamount of time required for the test article to penetrate or destroy each biobarrier was recorded and themean time of the four replic ates is used to designate the United Nations (U.N.) Packing Group classification and GHS Sub-category
Details on study design:
Background
The Corrositex® test is a standardized and reproducible method that can be employed to determine the potential corrosivity and the Packing Group classification of specified categories of chemical compounds under the hazardous materials transportation regulations administered by the U.S. Department of Transportation (DOT) and international dangerous goods codes. The Corrositex® test predicts the in vivo corrosive potential of a chemical compound or mixture by using as an endpoint the amount of time it takes for a chemical to destroy a synthetic biobarrier. A color change in a proprietary liquid Chemical Detection System (CDS) is used to indicate that the chemical has passed through the biobarrier.

Procedure
The Corrositex® test is a three-step procedure. First, the test article was qualified to ensure that it was compatible with the Corrositex® system, and then it was categorized according to pH to determine cut-off times. Finally, it was classified based on the mean time the test article took to penetrate the biobarriers.

Qualification
150 μl of the test article were added to the CDS reagent in a Qualify vial, and the vial was observed for any notable color change. An observable color change indicates that the test article is compatible with the Corrositex® system.

Categorization
Next, the test article was categorized, which determined cut-off times for the Packing Group designations. A 10% formulation of the test article was prepared and its pH was measured. If the pH of the 10% formulation was <7.0, 150 μl of the neat test article were added to Vial A. The pH of Vial A was then measured, and if it was lower or equal to 5.0, the test article was assigned to Category 1, and if it was >5.0, the test article was assigned to Category 2. If the pH of the 10% formulation was >7.0, 150 μl of the neat test article were added to Vial B. The pH of Vial B was measured, and if the final pH was 9.0, the test article was Category 1, and if it was greater or equal than 9.0, the test article was Category 2.

Classification
Finally, the test article was classified to determine the Packing Group by adding 500 μl of the test article to each of four test vials containing biobarriers. If the test article destroys the biobarrier, it will come in contact with the CDS reagent in the vial and induce a color change similar to that observed in the Qualify vial. The amount of time required for the test article to penetrate or destroy each biobarrier was recorded and the mean time of the four replicates is used to designate the United Nations (U.N.) Packing Group classification and GHS Sub-category as described below. A positive control was performed using 1.0 N sodium hydroxide. The result for the positive control is considered valid if it falls within the range of the MB Research historical mean ± 2 standard deviations. A negative control was performed using 1% citric acid; the result is considered valid if the breakthrough time is greater than 60 minutes.
Irritation / corrosion parameter:
penetration time (in minutes)
Run / experiment:
1
Value:
> 61.19
Vehicle controls validity:
valid
Negative controls validity:
valid
Remarks:
Citric acid
Positive controls validity:
valid
Remarks:
1.0 N Sodium hydroxide
Remarks on result:
no indication of irritation
Remarks:
Non Corrosive

The 1.0 N sodium hydroxide" positive control had a breakthrough time of 17.75 minutes, which fell within the range allowed (>13.7 and <22.2 minutes). The 1% citric acid negative control had a breakthrough time of >67.27 minutes, which met the acceptance criterion of >60 minutes.

Interpretation of results:
GHS criteria not met
Remarks:
The material was considered non-corrosive.
Conclusions:
The material was considered non-corrosive.
Executive summary:

Benzene sulfonic acid, di-C10-14-alkyl derivs., sodium salt was analyzed using the Corrositex® test method to determine its dermal corrosivity potential and U.N. Packing Group classification and GHS Sub-category. The 1.0 N sodium hydroxide" positive control had a breakthrough time of 17.75 minutes, which fell within the range allowed (>13.7 and <22.2 minutes). The 1% citric acid negative control had a breakthrough time of >67.27 minutes, which met the acceptance criterion of >60 minutes. The results of this study indicated that the test article was compatible with the Corrositex® system. Based on the pH of the test article, it was assigned as a Category 2 test article. The results obtained from the evaluation of four replicate tests demonstrated that a mean time of >61.19 minutes was required to penetrate the synthetic biobarriers. These findings lead to the classification of this test article as a Non-Corrosive material.

Endpoint:
skin irritation: in vitro / ex vivo
Type of information:
experimental study
Adequacy of study:
key study
Study period:
21 Nov 2017 to 01 Dec 2017
Reliability:
1 (reliable without restriction)
Rationale for reliability incl. deficiencies:
guideline study
Remarks:
Study completed according to OECD 439 Guidelines, and under GLP.
Qualifier:
according to
Guideline:
OECD Guideline 439 (In Vitro Skin Irritation: Reconstructed Human Epidermis Test Method)
Version / remarks:
OECD Guideline 439 (In Vitro Skin Irritation)
Deviations:
no
Principles of method if other than guideline:
OECD Guideline 439 (In Vitro Skin Irritation)
GLP compliance:
yes (incl. certificate)
Species:
human
Vehicle:
other: vehicle
Controls:
yes, concurrent vehicle
Amount / concentration applied:
30 μl of the test article were applied to the EpiDerm™ tissue.
Duration of treatment / exposure:
MatTek EpiDerm™ tissue samples were treated in triplicate with the test article, negative control and positive control for 60 minutes
Observation period:
EpiDerm™ tissues were returned to the incubator for 24±2 hours. Medium was changed at 24±2 hours. Tissues were returned to the incubator for an additional 18±2 hours
Number of animals:
Not applicable
Details on study design:
EpiDerm™ Tissue Samples
EpiDerm™ tissues, Lot No. 27631, Kit F, were received from MatTek on 28 Nov 2017 and refrigerated at 2-8°C. Before use, the tissues were incubated (37±1°C, 5±1% CO2) with assay medium (MatTek) for a one-hour equilibration. The tissues were then moved to new wells with fresh medium for an additional overnight equilibrium, for 18±3 hours. Equilibration medium was replaced with fresh medium before
dosing.

Test Article Reduction of MTT
100 μl of the test article were mixed with 1 ml of MTT solution (1 mg/ml methyl thiazole tetrazolium diluted in Dulbecco's Modified Eagle's Medium [DMEM]). A negative control (100 μl tissue culture water) was tested concurrently. The solution was incubated at room temperature in the dark for 60 minutes. After incubation, the solution was visually inspected for purple coloration, which indicates that the test article reduced MTT. Since tissue viability is based on MTT reduction, direct reduction by a test article can
exaggerate viability, making a test article seem less irritating than its actual irritation potential. The test article did not reduce MTT and the assay continued as per the protocol.

Mesh Compatibility
Pre-cut nylon mesh supplied with the tissues was placed on a slide and 30 μl of the test article or tissue
culture water (negative control) were applied. After 60 minutes of exposure, the mesh was checked
microscopically. No interaction between the test article or phosphate-buffered saline and the mesh was
observed so the test article was dosed using the mesh as a spreading aid.

Dosing
30 μl of the test article were applied to the EpiDerm™ tissue. A nylon mesh was then placed on top to facilitate even distribution of the test article. A negative control (30 μl of PBS) and a positive control (30 μl of 5% SDS solution) were each tested concurrently, with a nylon mesh placed on top to facilitate even distribution of the material. Each treatment with test article or control was conducted in triplicate. The exposure period for the test article and controls was 60 minutes. The dosed tissues were placed in an incubator at 37±1°C, 5±1% CO2 for 35±1 minute, and then returned to the sterile hood for the remainder of the 60-minute exposure period. After dosing and incubation, the tissues were rinsed with PBS, blotted to remove the test substance and dry the tissue, and transferred to fresh medium. The rinsed EpiDerm™ tissues were returned to the incubator for 24±2 hours. Medium was changed at 24±2 hours. Tissues were returned to the incubator for an additional 18±2 hours.

Tissue Viability (MTT Reduction)
At the end of the incubation period, each EpiDerm™ tissue was rinsed with PBS and transferred to a 24-well plate containing 300 μl of MTT solution (1 mg/ml MTT in DMEM). The tissues were then returned to the incubator for a three-hour MTT incubation period. Following the MTT incubation period, each EpiDerm™ tissue was rinsed with PBS and then treated with 2.0 ml of extractant solution (isopropanol) per well for at least two hours, with shaking, at room temperature. Two aliquots of the extracted MTT formazan were measured at 540 nm using a plate reader (μQuant Plate Reader, Bio-Tek Instruments, Winooski, VT).

Analysis of Data
The mean absorbance value for each time point was calculated from the optical density (OD) of the duplicate samples and expressed as percent viability for each sample using the following formula: % viability = 100 X (OD sample/OD negative control)

Quality Controls
The assay meets the acceptance criteria if the mean OD540 of the negative control tissues is between 1.0 and 2.5, inclusive, and the mean viability of positive control tissues, expressed as percentage of the negative control tissues, is at least 20%. In addition, the standard deviation (SD) calculated from individual percent tissue viabilities of the three identically-treated replicates must be less than 18%.

Skin Irritation Prediction
According to the EU and GHS3 classification (R38 / Category 2 or no label), an irritant is predicted if the mean relative tissue viability of three individual tissues exposed to the test substance is 50% or less of the mean viability of the negative controls.

Irritation / corrosion parameter:
% tissue viability
Run / experiment:
1
Value:
ca. 109.6
Negative controls validity:
valid
Remarks:
97.2%
Positive controls validity:
valid
Remarks:
3.3%
Remarks on result:
no indication of irritation
Irritation / corrosion parameter:
% tissue viability
Run / experiment:
2
Value:
ca. 61.2
Negative controls validity:
valid
Remarks:
102.5%
Positive controls validity:
valid
Remarks:
3.5%
Remarks on result:
no indication of irritation
Irritation / corrosion parameter:
% tissue viability
Run / experiment:
3
Value:
ca. 101.8
Negative controls validity:
valid
Remarks:
100.3%
Positive controls validity:
valid
Remarks:
3.2%
Remarks on result:
no indication of irritation
Other effects / acceptance of results:
The standard deviation of the three test article-treated tissues was over 18%, which is higher than the protocol acceptance criterion. However, all three tissues had viabilities above the classification cut-off of 50%, which is classified as a Non-Irritant. The Study Director judged that the test article material was classified as a Non-Irritant.

Of the three test-article treated tissues, the individual viabilities were 109.0%, 61.2% and 101.8%, with a mean tissue viability of 90.6%. The protocol states that the standard deviation of the three treated tissues be <18%. The standard deviation of the three treated tissues was 25.7%. Although the standard deviation did not meet the acceptance criterion, 2 of the 3 tissues had similar viability and the mean was 90.6%. Also, all three tissues had viability above the classification cut-off of 50% (Non-Irritant). Therefore, the material was classified as a Non-Irritant
Interpretation of results:
GHS criteria not met
Remarks:
Criteria used for interpretation of results: OECD GHS
Conclusions:
Of the three test-article treated tissues, the individual viabilities were 109.0%, 61.2% and 101.8%, with a mean tissue viability of 90.6%. The protocol states that the standard deviation of the three treated tissues be <18%. The standard deviation of the three treated tissues was 25.7%. Although the standard deviation did not meet the acceptance criterion, 2 of the 3 tissues had similar viability and the mean was 90.6%. Also, all three tissues had viability above the classification cut-off of 50% (Non-Irritant). Therefore, the material was classified as a Non-Irritant
Executive summary:

To predict dermal irritation potential, MatTek EpiDerm tissue samples were treated with 30 μl of benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts, 30 μl of phosphate buffered saline [PBS] (negative control), or 5% sodium dodecyl sulfate [SDS] solution (positive control). The samples were then incubated in 300 μl Methyl thiazole tetrazolium (MTT) solution (1 mg/ml MTT in DMEM) followed by 2.0 mL extractant solution (isopropanol). Mean tissue viability was determined to be 90.6% for the test material, 3.3% for the positive control, and 100% for the negative control. The material was concluded to be a non-irritant.

Endpoint conclusion
Endpoint conclusion:
no adverse effect observed (not irritating)

Eye irritation

Link to relevant study records

Referenceopen allclose all

Endpoint:
eye irritation: in vitro / ex vivo
Remarks:
in vitro
Type of information:
experimental study
Adequacy of study:
key study
Study period:
27 Sep 2017 to 28 Sep 2017
Reliability:
1 (reliable without restriction)
Rationale for reliability incl. deficiencies:
guideline study
Qualifier:
according to
Guideline:
OECD Guideline 437 (Bovine Corneal Opacity and Permeability Test Method for Identifying Ocular Corrosives and Severe Irritants)
GLP compliance:
yes (incl. certificate)
Species:
cattle
Strain:
not specified
Remarks:
bovine cornea
Details on test animals or tissues and environmental conditions:
Test System
The bovine eyes, in a Hanks’ Balance Salt Solution (HBSS) with penicillin-streptomycin, were received from Spear Products on 28 Sep 2017 and transported to MB Research in a refrigerated container.

Pretest Procedures
Fresh assay solutions were prepared prior to use. MEM solution was prepared by stirring together one jar of MEM powder (sufficient to make one liter of solution), 2.2 g of sodium bicarbonate, 0.292 g L-glutamine, 10 ml of fetal bovine serum (FBS) and brought to a final volume of 1000 ml with distilled water. The MEM solution was kept in a 32 (±1)°C incubator for the duration of testing. HBSS was prepared by stirring together HBSS powder (sufficient to make one liter) and 0.35 g of sodium bicarbonate and brought to a final volume of 1000 ml with distilled water. HBSS was maintained at room temperature. In addition, MEM solution with phenol red was prepared by stirring together 9.3 g of MEM with phenol red (sufficient to make one liter), 2.2 g of sodium bicarbonate, 0.292 g L-glutamine, 10 ml of fetal bovine serum (FBS) and brought to a final volume of 1000 ml with distilled water. The MEM solution with phenol red was kept in a 32 (±1)°C incubator for the duration of testing. The eyes were examined prior to use on the day of dosing. Any eye with a cornea exhibiting evidence of vascularization, pigmentation, opacity or scratches was discarded. Corneas from eyes that were free of defects were dissected from the surrounding tissues. A 2-3 mm rim
of sclera was left attached to each cornea. The corneas were then placed in a container of fresh HBSS. The dissected corneas were mounted in specially designed holders that were separated into anterior and posterior chambers and filled separately. Each cornea was mounted allowing the epithelium of the cornea to project into the anterior chamber. The posterior chamber was filled with MEM solution ensuring contact with the endothelium. The anterior chamber was filled with MEM solution, ensuring contact with the epithelium. Each cornea was visually inspected again to ensure there were no defects. The entire holder was incubated at 32 (±1)°C and allowed to equilibrate for at least one hour, but not longer than two hours. A pre-exposure determination of opacity was made for each cornea by measuring each against the blank supplied by the opacitometer. Any cornea with a value greater than 7 units was discarded.
Vehicle:
unchanged (no vehicle)
Controls:
yes, concurrent positive control
yes, concurrent negative control
Amount / concentration applied:
0.75 ml of test article, Minimal Essential Media (MEM, negative control), or 100% ethanol (positive control)
Duration of treatment / exposure:
10-minute exposure for each group
Duration of post- treatment incubation (in vitro):
All corneas were incubated at 32 (±1)°C for an additional two hours at which time the MEM solution in the anterior and posterior chambers was removed and the holders refilled with fresh MEM solution. After 10 (±1) minutes), the test article, ethanol or MEM was removed from the epithelium of the cornea and anterior chamber of the holder by washing with MEM solution containing phenol red. A final rinse was made with MEM without phenol red. The anterior and posterior chambers of the holders were then refilled with fresh MEM solution. Opacity measurements were made following the 10-minute exposure and MEM solution refill.
Number of animals or in vitro replicates:
Thre replicates per sample
Details on study design:
Study Procedure
Following the pretest observations, the MEM solution was removed from the anterior chamber. A volume of 0.75 ml of test article, ethanol, or MEM solution was applied to the epithelium of each of the three test article corneas, three positive control corneas and three negative control corneas in a manner which ensured that the entire cornea was covered. Test article corneas were dosed via the open-chamber method. The negative and positive controls were dosed via the closed-chamber method. All holders and corneas were placed in a horizontal position (anterior side up) in the 32 (±1)°C incubator. After 10 (±1) minutes), the test article, ethanol or MEM was removed from the epithelium of the cornea and anterior chamber of the holder by washing with MEM solution containing phenol red. A final rinse was made with MEM without phenol red. The anterior and posterior chambers of the holders were then refilled with fresh MEM solution. Opacity measurements were made following the 10-minute exposure and MEM solution refill.

All corneas were incubated at 32 (±1)°C for an additional two hours at which time the MEM solution in the anterior and posterior chambers was removed and the holders refilled with fresh MEM solution. A measurement of opacity was taken with each treated cornea compared to the blank supplied with the OP-KIT. This reading was used in the final IVIS calculations. Immediately following the two-hour opacity measurement, the MEM solution was removed from the anterior chamber and replaced with 1.0 ml of 0.4% sodium fluorescein solution in Dulbecco's phosphatebuffered saline (PBS). Each holder was then returned to the 32 (±1)°C incubator in a horizontal position (anterior side up) ensuring contact of the fluorescein with the cornea. After 90 (±5) minutes, the fluid from the posterior chamber was removed and the amount of dye that passed through the cornea (permeability) was measured as the optical density at 490 nm by a spectrophotometer. A 1:1000 dilution of the fluorescein was prepared and measured in the spectrophotometer as a measure of consistency.
Irritation parameter:
cornea opacity score
Value:
4.67
Vehicle controls validity:
not applicable
Negative controls validity:
valid
Remarks:
Minimal Essential Media; value= 0.021
Positive controls validity:
valid
Remarks:
100% Ethanol; value 25.34
Remarks on result:
no indication of irritation
Remarks:
Non-Corrosive
Irritation parameter:
in vitro irritation score
Remarks:
IVIS
Value:
4.87
Vehicle controls validity:
not applicable
Negative controls validity:
valid
Remarks:
IVIS=32.84
Positive controls validity:
valid
Remarks:
IVIS=-0.36
Remarks on result:
no indication of irritation
Remarks:
Non-Corrosive

The ethanol positive control IVIS was 32.84, which fell within the acceptance range of 16.96 - 37.00 (± 2 standard deviations of the historical mean).

Interpretation of results:
GHS criteria not met
Remarks:
The test material is not considered an ocular corrosive or severe irritant (Category 1).
Conclusions:
The test material is not consider an ocular corrosive or severe irritant (Category 1).
Executive summary:

To determine the potential for ocular irritation using an alternative to the Draize methodology, a study based on the methodology described in the current OECD Guideline for the Testing of Chemicals No. 437 was conducted. Three bovine corneas per group were dosed with 0.75 ml of Benzene sulfonic acid, di-C10-14-alkyl derivs., sodium salts, Minimal Essential Media (MEM, negative control), or 100% ethanol (positive control). Following a 10-minute exposure for each group of dosed corneas, opacity measurements and sodium fluorescein permeability were determined. The MEM solution is then removed from the anterior chamber and replaced with 1.0 ml of 0.4% sodium fluorescein solution. After 90 min the fluid from the posterior chamber is removed and the amount of dye that passed through the cornea is measured as the optical density at 490 nm by a plate reader. For the test substance, the in vitro irritancy score (IVIS) is 4.87, with a corneal opacity score of 4.67. Based on these results, benzene sulfonic acid, di-C10-14-alkyl derivs., sodium salts cannot be consider an ocular corrosive or severe irritant.

Endpoint:
eye irritation: in vitro / ex vivo
Type of information:
experimental study
Adequacy of study:
key study
Study period:
06 Nov 2017 to 10 Nov 2017
Reliability:
1 (reliable without restriction)
Rationale for reliability incl. deficiencies:
guideline study
Qualifier:
according to
Guideline:
OECD Guideline 492 (Reconstructed Human Cornea-like Epithelium (RhCE) Test Method for Identifying Chemicals Not Requiring Classification and Labelling for Eye Irritation or Serious Eye Damage)
Deviations:
no
GLP compliance:
yes
Species:
other: Reconstructed Human Cornea-like Epithelium
Details on test animals or tissues and environmental conditions:
EpiOcular™ Tissue Samples
EpiOcular™ tissues, Lot No. 27405 Kit B, were received from MatTek on 07 Nov 2017 and refrigerated at 2-8°C. Before use, the tissues were incubated (37±1°C, 5±1% CO2) with assay medium (MatTek) for a one-hour equilibration. Equilibration medium was replaced with fresh medium for an additional overnight equilibration of 16 to 24 hours. After the overnight incubation, the tissues were moistened with 20 μl of phosphate-buffered saline (PBS) and incubated at 37±1°C, 5±1% CO2 for 30±2 minutes.
Vehicle:
unchanged (no vehicle)
Controls:
yes, concurrent positive control
yes, concurrent negative control
Amount / concentration applied:
All procedures were conducted under yellow light. 50 μl of the test article were mixed with 1 ml of MTT solution (1 mg/ml methyl thiazole tetrazolium diluted in Dulbecco's Modified Eagle's Medium [DMEM]). A negative control (50 μl of tissue culture water) was tested concurrently. The plate was then covered in foil.
Duration of treatment / exposure:
Two test tissues per test article will be exposed for 30 +/- minutes.
Observation period (in vivo):
The solutions were incubated in the dark at 37±1°C, 5±1% CO2 for 3 hours in a six-well plate microplate. After incubation, the solutions were visually inspected for purple coloration, which indicates that the test article reduced MTT. Since tissue viability is based on MTT reduction, direct reduction by a test article can exaggerate viability, making a test article seem less irritating than its actual irritation potential. The test article did not reduce MTT and the assay continued as per the protocol.
Duration of post- treatment incubation (in vitro):
Incubated for 120 +/- 15 minutes
Number of animals or in vitro replicates:
50 μl of the test article were applied to duplicate EpiOcular™ tissues. negative control (50 μl of TCH2O) and a positive control (50 μl of methyl acetate) were each tested concurrently. Each treatment with test article or control was conducted in duplicate.
Details on study design:
EpiOcular™ Tissue Samples
EpiOcular™ tissues, Lot No. 27405 Kit B, were received from MatTek on 07 Nov 2017 and refrigerated at 2-8°C. Before use, the tissues were incubated (37±1°C, 5±1% CO2) with assay medium (MatTek) for a one-hour equilibration. Equilibration medium was replaced with fresh medium for an additional overnight equilibration of 16 to 24 hours. After the overnight incubation, the tissues were moistened with 20 μl of phosphate-buffered saline (PBS) and incubated at 37±1°C, 5±1% CO2 for 30±2 minutes.

Plate Reader Linearity Check
The linearity of the plate reader used for optical density (OD) determination was verified prior to its use the same week the EIT assay was performed. A dilution series of trypan blue or thiazolyl blue tetrazolium bromide (MTT) formazan was prepared and 200 μl aliquots were pipetted into a 96-well plate. The optical density of the plate wells was measured at a wavelength of 570 nm (OD570), with no reference wavelength. A regression line and an R-squared value were generated using Microsoft Excel® .
Verification is considered acceptable if the R-squared value is greater than 0.999.

Test Article Reduction of MTT
All procedures were conducted under yellow light. 50 μl of the test article were mixed with 1 ml of MTT solution (1 mg/ml methyl thiazole tetrazolium diluted in Dulbecco's Modified Eagle's Medium [DMEM]). A negative control (50 μl of tissue culture water) was tested concurrently. The plate was then covered in foil. The solutions were incubated in the dark at 37±1°C, 5±1% CO2 for 3 hours in a six-well plate microplate. After incubation, the solutions were visually inspected for purple coloration, which indicates that the test article reduced MTT. Since tissue viability is based on MTT reduction, direct reduction by a test article can exaggerate viability, making a test article seem less irritating than its actual irritation potential. The test article did not reduce MTT and the assay continued as per the protocol.

Assessment of Coloring or Staining Materials
Since the test article was colored, it was assessed for its ability to absorb light at the wavelength used for MTT determination (570 nm). 50 μl of the test article were added to 2 ml of extractant (isopropanol) and incubated for 2 to 3 hours in a six-well plate, at room temperature with shaking. Two 200 μl aliquots of the test article plus extractant from each well were measured at 570 nm using a plate reader (μQuant Plate Reader, Bio-Tek Instruments, Winooski, VT). The mean OD570 value of the test article plus extractant was greater than 0.08 after subtraction of blank (undosed isopropanol). This indicates that background absorption of light could augment the OD570 values measured for the test article-treated tissues, increasing viability. Therefore, colorant controls (live tissues) were added to the assay.

Dosing
50 μl of the test article were applied to duplicate EpiOcular™ tissues. A negative control (50 μl of TCH2O) and a positive control (50 μl of methyl acetate) were each tested concurrently. Each treatment with test article or control was conducted in duplicate. The tissues were incubated at 37±1°C, 5±1% CO2 for 30±2 minutes. After dosing and incubation, the tissues were rinsed with phosphate-buffered saline (PBS) and soaked in 5 ml of room-temperature assay medium in a 12-well plate for 12 minutes. The soaked tissues were then incubated in fresh assay medium at 37±1°C, 5±1% CO2 for 120 minutes. As colorant controls, two additional live tissues were treated with the test article, but incubated in assay media instead of MTT during the MTT incubation period.

Tissue Viability (MTT Reduction)
At the end of the incubation period, each EpiOcular™ tissue was transferred to a 24-well plate containing 300 μl of MTT solution (1 mg/ml MTT in Dulbecco's Modified Eagle's Medium). Tissues for the colorant controls were transferred to wells containing assay media instead of MTT solution. The tissues were then returned to the incubator for a three-hour MTT incubation period. Following the MTT incubation period, each EpiOcular™ tissue was rinsed with PBS and then treated with 2.0 ml of extractant solution (isopropanol) per well overnight at room temperature in the dark. Two aliquots of the extracted MTT formazan from each well were measured at 570 nm using a plate reader (μQuant Plate Reader, Bio-
Tek Instruments, Winooski, VT).

Analysis of Data
Viability:
The mean absorbance value for each time point was calculated from the optical density (OD) of the duplicate samples and expressed as percent viability for each sample using the following formula: % viability = 100 X (ODsample/ODnegative control)

Corrected Viability:
The colorant controls included in the assay showed that the viability measurement attributable to background was 0.8%. Consequently, the test article viability was corrected for the background by the following formula: Corrected Viability = % Viability – VB
Where: VB = Mean apparent viability of the test article-treated colorant (live) controls
Irritancy classifications were based on the corrected viability values.
Irritation parameter:
other: % viability measured by Thiazolyl blue tetrazolium bromide (MMT) reduction
Run / experiment:
Mean
Value:
ca. 99.1
Negative controls validity:
valid
Remarks:
100%±0.01% viability
Positive controls validity:
valid
Remarks:
38.7%±4.97% viability
Remarks on result:
no indication of irritation
Other effects / acceptance of results:
Quality Controls
The assay meets the acceptance criterion if the mean OD570 of the negative control tissues is greater than 0.8 and less than 2.5, and the mean relative viability of positive control tissues, expressed as percentage of the negative control tissues, is less than 50%. In addition, the difference in viability between identically treated tissues must be less than 20%.
Irritant / corrosive response data:
The test article provided by Advanced Testing Laboratory was tested using the MatTek EpiOcular™ Eye Irritation Test (EIT). The R-squared value calculated for the plate reader linearity check was 1.0000, which met the acceptance criterion of greater than 0.999. All other quality controls passed the acceptance criteria. Since the test article was found to be a colorant, color controls were added to the assay, the test article viability was corrected for the background, and irritancy classifications were based on the corrected viability values.
Interpretation of results:
GHS criteria not met
Remarks:
The material was concluded to be a non-irritant.
Conclusions:
The material was concluded to be a non-irritant.
Executive summary:

The test article benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts was tested using MatTek EpiOcular Eye Irritation Test (EIT). MatTek EpiOcular™ tissue samples were treated in duplicate with the test article, negative control and positive control for 30 minutes. Following treatment and subsequent incubation time, the viability of the tissues was determined using thiazolyl blue tetrazolium bromide (MTT) uptake and reduction. The absorbance of each sample was measured at 570 nm. The viability was then expressed as a percent of negative control values. If the mean tissue viability was less than or equal to 60%, the test material was classified as an ocular irritant (UN GHS Category 1 or 2); if the mean tissue viability was greater than 60%, the test material was classified as UN GHS No Category, and was therefore interpreted to be non-irritating. The test article was found to be a colorant. Therefore, color controls were added to the assay, the test article viability was corrected for the background, and irritancy classification was based on the corrected viability values.

Endpoint conclusion
Endpoint conclusion:
no adverse effect observed (not irritating)

Respiratory irritation

Endpoint conclusion
Endpoint conclusion:
no study available

Additional information

SKIN CORROSION/IRRITATION:

The benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts (registered/target substance) were analyzed using the Corrositex® test method to determine its dermal corrosivity potential. Five hundred microliters of the test article were added to each of four Corrositex® test vials containing biobarriers and the times required for the test article to destroy the biobarriers were recorded. A positive control (1.0 N sodium hydroxide) and a negative control (1% citric acid) were tested concurrently. The 1.0 N sodium hydroxide positive control had a breakthrough time of 17.75 minutes, which fell within the range allowed (>13.7 and<22.2 minutes). The 1% citric acid negative control had a breakthrough time of >67.27 minutes, which met the acceptance criterion of >60 minutes. The results obtained from the evaluation of four replicate test article samples demonstrated that a mean time of >61.19 minutes was required to penetrate the synthetic biobarriers. These findings lead to the classification of benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts as a Non-Corrosive to the skin material.

To predict dermal irritation potential, MatTek EpiDerm tissue samples were treated with 30 μl of benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts, phosphate buffered saline [PBS] (negative control), or 5% sodium dodecyl sulfate [SDS] solution (positive control) according to OECD 439. The samples were then incubated in 300 μl methyl thiazole tetrazolium (MTT) solution (1 mg/ml MTT in DMEM) followed by 2.0 mL extractant solution (isopropanol). Mean tissue viability was determined to be 90.6% for the test material, 3.3% for the positive control, and 100% for the negative control. Based on this, benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salt was concluded to be a non-skin irritant.

Justification for selection of skin irritation / corrosion endpoint: 

An in vitro skin corrosion study (OECD 435) on benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts showed that the average breakthrough time for benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts was >61.19 minutes. The results obtained from the evaluation of four replicate test article samples demonstrated that a mean time of >61.19 minutes was required to penetrate the synthetic biobarriers. These findings lead to the classification of benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts as a Non-Corrosive material.

To predict dermal irritation potential, MatTek EpiDerm tissue samples were treated with 30 μl of benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts

, 30 μl of phosphate buffered saline [PBS] (negative control), or 5% sodium dodecyl sulfate [SDS] solution (positive control). The samples were then incubated in 300 μl Methyl thiazole tetrazolium (MTT) solution (1 mg/ml MTT in DMEM) followed by 2.0 mL extractant solution (isopropanol). Mean tissue viability was determined to be 90.6% for the test material, 3.3% for the positive control, and 100% for the negative control. The material was concluded to be a non-skin irritant.

Effects on skin irritation/corrosion: Not Irritating

EYE IRRITATION:

In vitro eye irritation studies following OECD guidelines 437 (BCOP-Bovine Corneal Opacity and Permeability Test) and 492 (Reconstructed Human Cornea-like Epithelium Test) were conducted on benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts.

To determine the potential for ocular irritation using an alternative to the Draize methodology, a study based on the methodology described in the current OECD Guideline for the Testing of Chemicals No. 437 was conducted. Three bovine corneas per group were dosed with 0.75 ml of benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts, Minimal Essential Media (MEM, negative control), or 100% ethanol (positive control). Following a 10-minute exposure for each group of dosed corneas, opacity measurements and sodium fluorescein permeability were determined. The MEM solution is then removed from the anterior chamber and replaced with 1.0 ml of 0.4% sodium fluorescein solution. After 90 min the fluid from the posterior chamber is removed and the amount of dye that passed through the cornea is measured as the optical density at 490 nm by a plate reader. For the test substance, the in vitro irritancy score (IVIS) is 4.87, corneal opacity score is 4.67, and the permeability score is 0.013. Based on an IVIS between 3 and 55 and as defined in OECD Guideline No. 437, the benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts cannot be considered an ocular corrosive or severe irritant.

Tissue samples were treated according to EpiOcular Irritation Test (OECD 492) guidelines to determine its irritation potential. Duplicate tissue samples were treated with benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts, negative and positive control samples for 30 minutes. Following treatment and subsequent incubation time, the viability of the tissues was determined using thiazolyl blue tetrazolium bromide (MTT) uptake and reduction. The absorbance of each sample was measured at 570 nm. The viability was then expressed as a percent of negative control values. Mean viability results for benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts, negative and positive controls were 99.1, 100, and 38.7%, respectively. These findings lead to the classification of benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts as a Non-Irritating to the eye.

This in vitro eye non-irritation potential was corroborated with in vivo studies on the read across source substance calcium sulfonate (CAS 70024-69-0), evaluated in accordance with EPA OPPTS 870.2400 (Kern, 1999). A group of six albino rabbits (3 per sex) was used for the study. Each animal received a single, unwashed exposure of 0.1 mL of the test article instilled into the lower conjunctival sac of the right eye. The eyelid was held closed for approximately one second and released. The left eye was manipulated in a similar manner as the right eye and served as a contralateral control. Observations for eye irritation were made at 1, 24, 48 and 72 hours following dosing and on day 4 in accordance with the method of Draize. One animal had clear discharge from the eye, one-hour post dosing. There were no deaths or changes in bodyweight throughout the study. Mean 24, 48, and 72 hour corneal and iris scores were 0 for all animals tested. The conjunctival erythema scores were 1.3, 1, and 1, respectively and were all reversible within 7 days. The chemosis scores were 0.3, 1.3, 0.3, 0, and 1, respectively. In this study, the test substance is not considered an eye irritant.

A second eye irritation study on the read across source substance calcium sulfonate (CAS 70024-69-0) (Swan, 1972) administered 0.1 mL of test substance into one eye (the other eye served as a control) of adult New Zealand white rabbits (3/sex). The test material was not washed from the eyes. Eyes were scored for corneal, iritis and conjunctival effects 24, 48 and 72 hours following exposure in accordance with the method of Draize. Mean scores at 24, 48 and 72 hours for each animal for corneal opacity and iritis was 0 for all animals. Mean scores for conjunctival redness were 2, 2, 1.3, 1.3, 1 and 1, respectively. Mean scores for chemosis were 2, 1.7, 0.7, 1, 0.3 and 1, respectively. As the scores for conjunctival redness and oedema were less than 2 in 4 animals, this substance is not irritating to rabbit eyes.

In a supporting eye irritation screening study (Buehler, 1990) on the read across source substance calcium sulfonate (CAS 70024-69-0) administered to rabbits (1 male and 1 female) a single, exposure of 0.1 mL of the test article instilled into one eye. The other eye served as a control. The test material was not washed from the eyes. Animals were observed at 1, 24, 48, 72 hours in accordance with the method of Draize. Mean scores at 24, 48 and 72 hours for each animal for corneal opacity and iritis were 0 for all animals. Mean scores for conjunctival redness was 2 in both animals. Conjunctival oedema scores were 2.0 in one animal and 2.33 for the other. In the latter animal the conjunctival oedema decreased from a score of 3 at 24 hours to a score of 2 at 72 hours indicating the effects being reversible. However, because only 2 animals were used, and observations were terminated at 72 hours rather than the normal 21 days, this study cannot be used to determine classification and labelling.

In a definitive supporting study on the read across source substance calcium sulfonate (CAS 70024 -69 -0), that was conducted following the screening study of Buehler (1990), six animals (3 male and 3 female animals) were used to more fully evaluate the eye irritation potential of the calcium sulfonate read across substance, CAS 70024-69-0 (Buehler, 1991). Each animal received a single, exposure of 0.1 mL of the test article instilled into one eye. The other eye served as a control. The test material was not washed from the eyes. Animals were observed at 1, 24, 48, 72 hours in accordance with the method of Draize. Mean scores at 24, 48 and 72 hours for each animal for corneal opacity and iritis was 0 for all animals. Mean scores for conjunctival redness were 1, 0.7, 0.7, 0.3, 0.3 and 1, respectively. Mean scores for chemosis were 1.3, 0.7, 0, 0.7, 0.7 and 1.7, respectively. With the exception of the 1.7 value for chemosis in animal 6, all other signs were fully reversible within 72 hours. The mean scores for all animals for conjunctival redness and oedema were less than 2. Therefore, this read across source substance is not irritating to rabbit eyes.

 Justification for selection of eye irritation endpoint: 

In vitro eye corrosion and irritation studies following testing guidelines OECD 437 (BCOP-Bovine Corneal Opacity and Permeability Test) and OECD 492 (Reconstructed Human Cornea-like Epithelium Test) conducted on benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts showed that benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts was not corrosive or irritating to the eyes. These in vitro study results were confirmed on a primary eye in vivo irritation study which instilled 0.1 ml of calcium 4-icosan-3-ylbenzenesulfonate into the conjunctival sac of young adult white rabbits (3/sex).  Animals then were observed for 7 days. Irritation was scored by the method of Draize. No eye irritation was observed. Based on the weight of evidence, benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts are not an eye irritant.

Effects on eye irritation/corrosion: Non-Irritating

Justification for classification or non-classification

SKIN IRRITATION:

In vitroskin corrosion and irritation studies of sufficient quality and tested in accordance with standard methodology (OECD 435 and 439) showed that benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts were not corrosive and neither irritating to the skin. This non-irritation classification was confirmed by an in vivo skin irritation studies on several read across source substances.

 

EYE IRRITATION:

The eye non-irritation profile of the registered/target substance was determined by in vitro toxicity studies following OECD guidelines 437 (Bovine Corneal Opacity and Permeability Test) and 492 (Reconstructed Human Cornea-like Epithelium Test). This in vitro non-irritation potential was corroborated by several eye irritationin vivostudies of sufficient quality on the read across source substance calcium sulfonate (CAS 70024-69-0) and conducted in accordance with standard methodology. The mean scores in these studies were zero for the cornea and iris. The average scores for conjunctival redness over 24, 48, and 72 hours ranged from 1.0 to 2.0. Overall, mean scores for chemosis and conjunctival redness ranged from 0.3 to 2.0. All adverse effects were fully reversible between 72 hours to 7 days. The cutoff value for eye irritation classification is a positive response of corneal opacity ≥ 3 and/or iritis > 1.5 calculated as the mean scores following grading at 24, 48, and 72 hours after instillation of the test material. Therefore, no classification for eye irritation is proposed for benzenesulfonic acid, di-C10-14-alkyl derivs., sodium salts.