 Okay, welcome back to the Thursday session The seventh meeting of the chap committee. I'd like to continue this morning with our recommendations and yesterday we left at five o'clock discussing diethyl phthalate and I'd like to Take up that discussion today, and I think as I understand it Andreas you have some Verbiage that you'd like to propose is that correct for Yes, this verb it is is forthcoming in Five minutes and five minutes. Okay, and I wanted to indicate that What I will do when I get back Home is will I will try to convert all of these recommendations and into a one-page document But for now we have what we have in front of us, which is good because we have virtually all of the information that we need before us to Make a recommendation, but I will try to condense it into a one-page document Yes, I Think based upon where we've been heading we do have to add a sentence or two about whether it's in toys or products that are Under the purview of CPSC In there because we don't say that clue. We don't say that we talk about exposure from the vantage point of Biomonitoring which again is that integrated and unresolved issue about where it comes from So I think we should have to take a little bit a sentence from from the Binal CPSC memo which Changes a little bit the boot intake portion and And add that to it because I'll use that's the issue of the source It's about sense or so Hey, well again, let's bring that up in the discussion today because we did bring it up twice already You know in terms of discussion about recommendations, so I think we need to pay statement before we reach that point as to why one thing we said yesterday was I think to and the word recommendation to Recommend something I suggested to see regarding Ever whatever remember the focusing on toys and All care products and personal care products. Yeah, they're products But make it not just general recommendation recommendation to CPSC Specifically for toys and childcare articles right arts to toys and childcare This what we're talking about it's on the label in five on the label recommendation number five Recommendation to CPSC on products of concern Fine that resolves a lot of issues Okay, I have no problem with that Andreas are you rephrasing six? Oh? Okay for the recommendation, but I have no problem with the way six is phrased. I think that's good I'm very comfortable with that. I think a cup we I looked up this Oishi in Haraga paper and as far as I can tell it was DEH P was the study Assuming I have the right paper, you know unless there's another another Oishi Paper references here. Yes. Yes. Oh wait a minute. Here we go. There is another paper It's decreased serum testosterone You can find it That's in in burns, okay, I don't see it, but it's in burns. Yeah on page 22 of his So it is a decrease and he also says So Report it significantly decrease serum testosterone serum di Hydro testosterone and testicular testosterone in JCL with star rats following dietary exposure And then he adds these results are questionable however when taken in context of other results of the study where increases in Testosterone levels were seen after exposure to dbp di bp and DH P another paper Lou at all where they looked at gene expression. I think a In this study DEP did not look like the other like the active phthalates and it says that dimethyl diethyl in diactyl terephthalate were Not active the draft recommendation for diethyl This is really just to get us going. That's the intention. I'm I don't regard it as final It needs what smithing probably editing The last paragraph But perhaps perhaps instead of calling it a recommendation It's it's really the the sort of summary of the value. It's you know under section for risk assessment considerations There's an exposure section and a hazard section, but we don't ever put them together And so I'm I would propose that we think about maybe a 4c that could be summary summary or something where we actually do Make statements like what Andres has done It's not not the recommendation, but it's the sort of our evaluation of where it sits I think that would be a good idea because it's under risk assessment risk assessment is typically Three steps exposure hazard and then risk That's me. I think I think that would be logical and then the way is free To get to the point straight to the point under number five recommendation Could you could you do that? Yeah, what so the first two paragraphs would go under 4c, okay What would you want to title 4c risk? You can call it risk sure what I did I did not lose it last one would be oh Since the paragraph before that is also a recommendation. We could just swap it around I would suggest That would be fine. Yeah start with the last paragraph then the second and the first one goes under 4c. It did You wished it away and it disappeared. Do any documents open? Take away that last move down. Okay, get rid of Yeah, put that under five now, that's not the main one There I would go Just have two paragraphs that you know in that order and we just can consistently do that Now as far as the statement goes There are consumer products where there's exposure to DEP, but they're not toys and child care articles They make a try to express by saying since Exposes from articles under the remit of CPSC from articles not in the year not specifying what they are precisely And instead of non-existent. How about negligible and in the second paragraph you maybe should Replace of the late with DEP catch I Does that capture what we discussed yesterday? I sort of I think so. Yeah Good job Just a minor you you don't need the human in front of epidemiologic by definition. They're all human So we're not worried about the snail daughter this morning. The what the snail daughter this morning. We're not worrying about Although although the Institute at work Now that eco toxic colleges and that's something like eco epidemiology, but we don't need to spit We have the same issue There are people do eco Yep populations of animals and Russ this is also is it's reproductive outcomes Can can you confirm that from the episteles? reproductive well for DEP There's this the swan and Suzuki study with AGD, which is really a developmental reproductive Yeah, so it yeah would fit within both and then there's a neurodevelopmental and Then which is not really talked a lot about on the report But it's in the appendix or the associations with semen quality and adult men for instance Or yeah, so I think reproductive and developmental would be fair, but that's a style we can use Okay Can we cycle back to DMP then and Add a 4c to the 4c Risk again What would be the content I meant this case we have say no human studies I mean it outcome data in toxicological studies. Yeah I would say that I guess what reproductive and developmental can we simply say risks to To humans are currently not discernible Risks to humans are currently not discernible Or indeterminate or whatever From human studies and or animal toxicology Yeah, but that's why I suggest a phrase it risk to risks to humans that they're normally also extrapolated from animals Okay, so we don't need to go as long as it covers it we're fine. Yeah, would you want to add a becaus? because of lack of data because of Because it you know not specific to this it could be lack of data inconsistent data it could be data showing no Effect this really would be because of a lack of data like a relevant data All right, I'd be the sentence starting with therefore could be moved to number five. Yeah, it's already there. Yeah So Mike, I know we're gonna edit some of the other text in these pieces, but that margin of exposure I think is not a correct That was based on old assumptions that we moved away from at the bottom of part a It just needs to be cut that whole sentence But it just cut it When you when you said you were gonna that these were gonna be they're gonna be one page each for each chemical If I can do that. Yes. Okay, not one page for okay And I mean we can talk more about it, but I assume that the human part you would want me to Write that which I'm fine doing. Yes. You were gonna provide that. Yeah, and it was We were gonna move away from the bullets for each study and have more of a synthesis You know almost like the way exposure is written here, you know, there were X number of studies and these Associations they saw etc. Okay. Yeah, I can do that. Okay everyone happy with I will I will help to update the exposure part based on the most recent Calculations, okay. Yes, if if if all of you could Provide updates relevant to your expertise, that would be great. Mm-hmm. That would be helpful to me Okay, I'll incorporate that and I'll do the development reproductive toxicity parts and And the human yep, great great And when I finish I'll I'll email that to everyone Get your comments Okay, so everyone happy with DMP and DEP Okay Then let us move on to DVP Well, isn't it important at this stage to start with the observation that DVPs already under current law And from occurring in in the articles and that CSC's remit Do not make it very short and then say the we we see no reason to to alter this practice That's it. I think we could do that under under 4c again under risk that Essentially the data still support the the current And then under 4c risk would you say both the the animal and the human? Data in you to support the the current CPSC ban Do we want to add a statement to that fact that this ban is operating because we found no exposure kids toys and products under CPSC This is probably a result of the current regulation. That's what I'm just saying is that you know and Consistent with that we found in our analysis. There is no No Those are current exposure boys or other products are under the purview That's it shows that things working. Hey, yeah, you know Think that's good Somebody might ask, well, is it there or is it not there? it's not any Comments about the the wording here for five or four C and Five I guess my only comment. I mean, I'm fine with what's there but I and I was trying to make a distinction and for C is being more of a evaluation of Where things were and then recommend it, you know in terms of the science and then the recommendation part Part five and we're kind of blending that now, but You know, I think there's not much more to say here so But in general, I think the idea in for C was to make it sort of the What does it mean, you know, how we're evaluating the conditions that are described in parts A and B Already banned, you know, there's no need to go and repeat that from before We're just continuing the band. Well, don't you don't you think that the statement that both animal and human data support maintained Band is enough is a fair summary of A and B Yes, although strictly speaking Chris is of course, right. It's not a it's a it's a recommendation not a risk Statement, but did he say of course Chris was right? Of course, I mean we could yeah, we could have a few sentences that that Summarize the animal data the human data. That's what you want to have Yeah, I think because I would like to add something else and the recommendation along the lines of what we said about DEP yeah, and to do that it needs a bit of a Cotanga and that cotanga is here among C. So we could say something that we believe risk assessment of Exposers from other Sources needs to be carried out by the other competent Authorities in the USA. It could be under number five recommendations. Oh, yeah For example In order to make the go back to number C for C If you scroll up a little more There's there's a statement at the end of a for a about margins of exposure. There we are last sentence Yeah, I'm not suggesting to copy it But but under C this risk we could simply refer to that and Make a statement to the effect that you know in view of the Inversibility and you know the lasting damage that may be caused This margin of exposure is deemed too small and So that that would then build a bridge to the recommendation in number five that to the other US agencies So say something like that under for C, but the margin of exposure Yeah, okay Yeah, sure Persistent How do we want to describe it? It's a It's a it's an irreversible effect. I think those numbers aren't we need to verify those numbers, right? That's not what's in our tables at this point It's in the same ballpark, but the numbers aren't quite right. It needs to be a therefore after effect. I think Otherwise that sentence doesn't really Therefore oh Okay, maybe that needs to be the first sentence the margins of exposure needs to be the first That be the therefore Therefore both animal and human data support maintaining the ban Or however, I would suggest to change the term irreversible effects into too small for the Severeity of the effects described above. Yeah, I agree. I I think that's better And I would suggest to slightly modify the second sentence is in sentence in C Current it dbp is not found in these articles in relevant amounts Because dbp is omnipresent. So I just would like to add not in relevant amounts What does relevant mean? That means that it is there. It means more than point one percent. Yes It means it can be found everywhere Here it means biologically relevant amounts Violent no no in relevant in the sense of the text of the law IE more than point one percent That's fine That would be fine. Is this us legislation 0.1 percent. Yes, it's the same. Yeah Same here. Yeah We haven't seen Dibutal in a long time that mean we need to if we're saying it's not really there You haven't seen it in a long time, but we're now saying margins of exposure is small. That's based on data Back in that's well. These are five years ago, but they're also total Exposed this is total human exposure Oh, you're saying it's not available you're saying in toys Not in toys. Yes. Yes keeping focused You can put a paragraph Make this a new paragraph Do we need that extra? However, I don't know about the however In the margins of safety maybe just take out the deemed I don't know that's It makes it I think it would be a stronger statement are too small considering the severity are small Any other comments see or also on five well on five or Or six well For five should the recommendation it says no further. I think this was just carried forward, but should it be recommends Maintaining the permanent ban on DPP. Well, I think the permanent You can say it, but I think it's not necessary because it's permanent, but it's okay to say it Should I say because it's permanently banned for the reaction required? Yes, and writing these we have to think sometimes someone may just read Number five. Yeah, yeah the rest and yeah, yeah, okay You changed the last paragraph but you took out you just focused on food Yeah, I took a comma out food food supplements Where the paragraph starts with however chap, you know, baby basically use the same language that we use before where we said I think personal care products food. Yeah pharmaceuticals. I took out the drugs because it is I would leave them I would leave it in okay. Yeah. Why why take it out? Well, I was that it's in food Diabutal in I do. Yeah in food supplements. Yes. Yeah The competent agencies Okay Hearing no further comment. We will go on to the next the I B P Okay, so here we have Valate that has Fairly robust developmental toxicity data set no reproductive toxicity Data set no human Measured in human studies my BP Exposureed yeah by being in terms of toxicity Yes, it's measured in some of the epidemiologic studies. Oh because it doesn't say that here Does no published human studies. I didn't write correct. Yeah, it's not correct. Oh, okay. I Think they need some update because so that's right now. There's no real quantifiable number in products under the purview of CPSC Lee and indoor dust and Supposedly an indoor dust. What does it get there? That? means to be Understood I'm gonna go back and check a little bit further What do you what do you say about? Exposure hoger. Well, there is omnipresent and quantifiable exposure the I think the margins of exposure are in the Relevant region that that we currently see I've got DPS. Oh Didi D. P. Yeah, BP Yeah, I BP. Yeah What I have As it's mostly diet in indoor air. Yeah, but I think it's You know that could be a lack of data All right, indoor air. It's not indoor dust. I apologize. I meant indoor air. Well, no, I didn't I'm wrong. It's in it says indoors here. So if I go break it down Direct ingestion Which is house dust? But it's not that that would be I think it's indoor. I mean, there's a you do get it from indoor air indoor air In house dust inhalation Rate for house dust in but diet is the the primary driver Mostly diet it's indoor air from dust But it's not from the toys and the products that are used by CPSC Ross, what do you have on on human toxicity? Can you associations were found in the swan? AGD study and then in some of I mean My response to your question will be more general rather than going through each one. Yeah, and then Also some associations found with the neuro developmental outcomes Neural neuro. Yeah Started to kind of prepare Text that'll be relevant, you know relatively short for each one and be kind of worded similarly I don't think we want to get into the specific Neurotests et cetera because that's all in another part of the report. Yeah So this become similar to EP No So this is somewhat similar to DBP. Pardon me DEP. Yeah Talks wise and exposure wise similar to which DEP DEP Dibutal debut DBP DB The IPP definitely is in the same ballpark with the active whether it is not covered by any band right now And it's not present in any But it's a possible substitute for But we don't know we should say What no further in action unless they decide to use it Or CPSC related project products. We don't know it's It goes back to the you know give other agencies the opportunity to deal with this most directly and for diet and whatever You would clearly have the indication Active delayed. Yes So I think it's different compared to DEP How should we handle Active delayed I think we need to indicate that in risk first. Yes. Well for we have to say it's mean that I'm not sure Look at the hazard statements as an incomplete data set is that Accurate well, I think that may be based on the fact that in in this write-up It says there are no No published human studies and that's not correct Well that hazard Statement needs to be I think changed I think it would have to be Exposure the IPP can cause development and reproductive effects Reproductive there apparently isn't Similar to the DBP wording you want to go to that mic and cut paste it and then We can modify it if needed Well, the question I have is how do we make how do we ensure it is not put in kids? products, it's an if it's not there now at the appreciable quantities, but Could be used as a substitute. We're not just talking about children's products when we're talking about number C No, no, I understand that part. I understand totally. I'm thinking a little farther ahead Because it's a little more complicated than DB data and animals suggest that it don't turn that last part because we don't know that Target organ well, there may be right maybe Most likely Most likely like just add the eye. No, but what is most likely about that in the IVP they just cut out Want to say And cause developmental effects Do do we want to say is it animal studies because I don't know What's animal and human? both cause developmental Even as repro developmental Yeah, that's fine Dr. Slash development Around there's also the neuro development. Would you give it a developmental effects? Do we have to precise be more precise with you? Do we need to include neurological? But did I don't did we for DBP here? So I would try to And it's just it'll be described above anyway in humans I think Well, I okay, I mean I think the Should say can cause reproductive and developmental Why do we want to lose the inhumans in the end? Sort of redundant. Yeah And I'm on human studies. I'm gonna copy the risk for BP That's on human data. We want to say here, you know, what are the Moe's our table for the MOE's for the 95th percentile for DI BP are from like 5,800 to Much bigger Values before the 95th percentiles What was it 5,800 or 5,900 to 147,000? That's the 95th percentile So 5,800's the median That's the lower so we gave a range on the 95th percentile based on the Reference dose cases Okay, so one of the cases had the lower value there So it's 5,800 to So, I mean, I'm not sure if we're gonna Consistently talk about the 95th percentile or the median Okay, I think I've been asked to have a break so let's Save that mic and we'll come back to it in 20 minutes Okay, we are back in session so we're working on DI BP and we need to Complete the risk statement. I think the hazard statement is is complete. Is that correct? We have to delete the first sentence You have to modify that obviously and both animal and human data that that can that can stay So what do the animal and human data support? The DBP should be DI BP port Currently not banned right support initiating This is the band discussion. This is based on what we want to say our evaluation of the risk is right. Yeah this the MOE statement is correct for DI BP And what was there was basically pasted from DBP So pasted from the risk. Yes, what would the numbers in the brackets mean 780,000 From DBP. Oh, oh, so is the rest of that sentence that that's actually based on the in Haines Exposure data the margin of exposure in our table, but if we look at the hazard quotient from the different studies the infants have I don't know if you want to say that but the infants have One of the cases have a hazard index of 0.1 at the at the 99th percentile And I would suggest that since we're thinking of this in cumulative risk assessment where that's in the Area where we might be concerned I'm not saying we need to say that though Mike. I'm saying I'm just pointing that out no discussion point Well, we're talking about risk. So I think we need to say that that's going to be what we're going to base our recommendation on Hopefully I don't want to confuse this question. You have a quite frankly don't understand the last statement How can the hazard quotient be? 0.1 when the margin of exposure is from 5,000 different data There has it a quotient there was from the infant study the SSS FF data But the margin of exposure we calculated only was based on the in Haines data We didn't use the exposure in the children in the in that calculation. I'm just I'm just reading off of the tables But isn't this rather confusing to say here Should we leave it out Leave it out. It makes it very confusing They has a quotient or the M. Oh, yes, does that make it confusing? It's two different data sets. Why does that race? I think we should we should for the margins of exposure look at all data sets and Therein we should include We should update the margins of exposure including both and Haines and the SFF data set Well, the in Haines is for this is for women pregnant women and and also the general population or just Pregnant women for the same case that pregnant women was point oh four Why however? However, it doesn't make any sense as a connector, right? Yeah, but it's not however It's something else I think we should stick with the margin of exposure and the margin of exposure should include should be over all populations I think that's the way it should be We wouldn't specify the pregnant women here So if we did this on multiple populations, how would you express that then would you just give the range of The most sensitive one would you give the range of you wouldn't specify what it was based on? Pregnant women versus infants, etc. I think our populations are clear. We investigated pregnant women in the Haines and as of F people is that I'm only for All of them, you know, basically Or just for the infants One that I gave the 5800 That's for the in Haines pregnant women and the range comes from the different cases we considered for the reference doses So do we know what the hazard quotient was for women? I haven't calculated it, but we can But are you waiting for me to calculate it? Well, no, no What do we want to else Want to say well, I think that I mean the fact that the infants We can switch away from the hazard index and change that to margin of exposure, but it's going to be with a point one value It's going to be you know around a thousand which So I I would think we're in the place where we need to Where we would say that's too low of a margin Can you do a split screen? So we can have the Dbp on there as well. I like to see how that see that risk statement again that we did for the Well up to the risk statement for dbp No, that's the wrong one. Yeah, we just did that. I want to say something about the ibp the ibp and toys and Childcare articles and they're right now. It's not found in it It levels that are yep, you want that sort of statement in there. Don't you Mike? Oh, yeah But maybe not in the risk section do we well, that's where we have it here Yeah, I think we need in the risk section Why currently d ibp is not found in no exposure and no risk Lee or Founder detected auger Don't want to debate you Founder detected. I think it's probably more precise. I think it is later And so I think what we need is an evaluation of what we think those values look like Not sure that that includes describing what's in toys and not So after the second sentence don't we need to evaluate if we think well, that could go in our recommendation I mean, these are the these risks are for the general or for total exposure But the exposure from The toys and childcare articles is as far as we know negligible We haven't said what we think that general risk is that's what I would think about before we start talking about the toys Now these these MOE's are based on the 99th so I mean I need to verify The exposure numbers that I've gotten from a table. I mean again, this is a problem of pulling up tables I'm not quite sure If it's accurate now, I think those are correct in Haynes, but for the infants Right what I'm calculating now for the infants Based on a 99th percentile exposure estimate for infants Right, wait a minute typo We can fill that in Goes from a thousand of 25,000. That's the 90 99th percentile Chris do you want to say then that have the same statement the margins of exposure for DIBP? parentheses 1,000 and 25,000 are small considering the severity of Yes, I mean that's those are the kinds of statements. I think we need to have an evaluation of what we mean how we Evaluate those numbers. That is what I would suggest After the first paragraph at the end of the first paragraph under C. I think your suggestion Phil is a good one Mike copy the Margins of exposure sentence up there and paste it me Be happy with that. I don't like that. It's really nearest to what we said with DBP You don't like that. Yeah, because just All The exposure is lower than than I believe delayed so I Would simply not state this last sentence What would you substitute? We have to evaluate all we've done is stated a number Don't we have to interpret what we mean? How you know we have a margin of exposure in infants from a thousand to twenty five thousand So do we consider that too small? Is that an acceptable? And how is that going to drive our recommendation? Pardon? I'm gonna do anything to our recommendation because it's not in children's products. I mean I this is Getting off track again. We're going back to public health and it's good. We're gonna be here for 10 years Based upon how we're going we have to this isn't the recommendation. We have to make I'm sorry. We have to make our arguments based upon What our charges? You will need to explain this for Again, you're talking a total exposure, which is not where our charges and I'm we're just gonna be here all day And we're not gonna get anywhere. I have to rein in what we think Not that these things are not public health issues, but I don't see where this is heading Quite if I go down the number some direction Then let me know let me go on to number six, which is the most important Point of all go down to number six. We have to make a statement With this recommendation if implemented expected to reduce exposure to children No, it wouldn't but the case is equivalent to dbp So clearly I think the cut the risk assessment based on current exposures as these margins of exposure would Suggest there indicate There's nothing There's no case to answer or it's not sort of within the critical zone. However What we've said before about the toxicological effects of di BP Shows that they're very similar to dbp so Therefore it can be concluded that Although currently not present or not widely used in children's toy The ibp is not the kind of substance you want to see in children's toys Ever which is fine. I I think so we could be this should be reflected in the recommendations Well current exposure to the ibp Alone yeah, I do not do not indicate Yeah a high level of concern. Yeah The substance is currently not widely used in articles under the remit of CPSC However, the toxicological profile of the ibp Is very similar to that of dbp and something like you know, this is not therefore the Someone helped me. I'm not even a native speaker Recommended to be banned. Yeah from any consideration for future use in children's toys period. Yeah, that's all I mean, I don't want to spend the day just Dealing with Details we have to make recommendations. We know pretty much where we're going if we have the wordsmith fine But I think we're pretty clear as to where we're going with this particular chemical and These are a lot of things to deal with and we just can't you know We spent over an hour and a half on this one compound and I think that's inappropriate Okay back to five so Would you to be clear because you're saying we recommend should not be used in toys and childcare articles The terms that we should be using our ban in turn ban, you know, etc. No action Recommend should be banned and not using toys and childcare articles just so we're using the same. That's what I said But it's not written there Just from use or to prevent the ban from use Get rid of in the future Yeah, now the question I have is that number six at the present time? No Because it's not used in it, but we I want us to materialize as being part of children's toys in the future We're wording it from these products and it's chemical talking about such products Let's move on to By a pencil phthalate. There's one with a very clear Developmental toxicity profile Correct. There's no human Think B is correct as written. What do we say about risk? Don't find it in biomonitoring. I don't find it in toys. I don't find it anywhere. There's no data Minimal minimal trivial I mean, whatever's there is not very quantifiable. I think we have in for sufficient information to take any action at this time I think in terms of hazard we have to be aware that Thypentyl phthalate is clear in the heart of activity of the phthalates So I would propose a similar wording as for the IPP with some more emphasis on on the Severity of the toxicity I don't remember the authors, but there was a recent Paper that we were given on die on the Pentel right as being very biologically active in talk studies All right, so so can we put an interim ban until somebody gives us more data to find out whether this is is or is not a real issue There's no exposure data found in human urine though in the silver paper 2011 Not found in and Haynes it's is it whole girl because there's not a biomarker for it Or you would it's or it's been looked for and not found or it hasn't properly been looked for I Think the don't social is low because it is not used because those who would use it know how would how critical it would be probably Well, it's not used for good reasons and I think based on the Toxicity I think there is no grounds for an interim but the permanent ban Was this substance you clearly would not want to see in any children's products a Collection from the toxic data. It's it's it's more toxic. It's the most in the heart of toxicity. Yeah, yeah Maybe even DHP as well It's a factor of three to five more potent than that beautiful delayed DHP Probably Limited talk studies just because it's not one of the phthalates for which there's a lot of interest. So Is there no interest because it's not used because people are worried about the toxicity from the get-go That's true. I think Paul you're saying that because of its Right, it hasn't really been used in products. Is that Consensus Andreas, I don't hear you. That's because I didn't say anything. Yes. I think it is consensus. Okay great, do we want to lift any of the Statements from the DI or DBP or DI BP. I think we have to modify the hazard section because We have to state here is clearly among the most potent stellates so they As such the stewardess to stewardship for this compound Such that we cannot find it detected in biomonitoring studies and not find any Estimated exposures in children's products Not sure we're measuring it in in Haines. Is it Holger? I mean, I don't we didn't try to model it Yeah, I Think in Haines yet. I do measure it, but I I really don't have any positive detects I don't just say the stewardship of this company that we don't find it In our estimates of exposure from children's products and at your stewardship is the right word Well, I'm trying to figure out a word for it too, but stewardship is the best thing It's a potent chemical, but the exposure isn't high, but the risk there. I think we don't Because it's a potent chemical and people don't use it. That's why the risk is low. It's not because the hazards low No risk, but I has it. It's but the exposure is low That statement in there and also the fact it's not used currently and yeah, that's that's the issue of toys and That's the issue of stewardship because it is such a highly potent compound And you've got this it's not in the products. It's not In the environment However, it's highly highly toxic like what I think those standing next to a vial of weapon grade Anthrax which I have it's highly toxic, but it's not touching me I think I think that needs to go in the risks Part to be consistent with our other I would I would not have that first statement Yeah, I would start out that way and just say however, it's not found in Children's toys and personal care products and it's Not Teenly found in biomonaturing, right? Yeah murder what we said before for BP that's it's the kind of chemical we don't want to find in children's toys, so Let's scream. Maybe you could go to the DI BP part. I am a bit reluctant to name a highly toxic compound Shouldn't we just say it's I would say it's a developmental toxic. It's a yeah Highly toxic My ears It's strange A potent elemental toxic and somebody told me you've mentioned it's the most pot Delates, but does it sound of the delights? We're talking about that And you could hear you said that way Mike is the most potent Developmental and we're dealing with people who are gonna look Not be scientists Valley based upon your experiences that is a reason Back to its developmental toxicity move the toxic after developmental You need the however Currently not found in children's toys and A third sentence tying those together. I mean because you're basically Almost repeating what the exposure and hazard Sections are saying you're saying it's a hazard. There's no exposure. Therefore risk is Low minimal net negligible, you know because of the exposure not being Right risk right right low exposure. It's it's low six want Intermediate statement, you know something below exposure, you know Right to the ban, I mean should this Raise be precede the recommendation have to give the recommendation first How would how would you word it? Everybody happy with that move on to butyl benzel right So can can I suggest we do a cut-and-paste job from DBP because it's a totally analogous case I Recycled Margin of exposure if I'm if this needs to be verified but the 95th from the SFF study the 95th percentile 7,000 250,000 Infants the 99th percentile for BVP 27 to 3,000 you say that again 90 in infants. This is from the SFF study. The numbers 99th is from 227 Thousand Or I guess if we're rounding 200 to 3,000 what a habit we're gonna round but let's not start that again a little higher and in ranging from About 3500 to 47,000 range anything here Not an issue in pharmaceuticals isn't and you delete the last sentence in 4c and This the sentence. No, you delete it the one from from diabetes delayed Crawl up to the diabetes delayed have to make the same statement here because we are in the range of 200 100 Got six, but okay, let's move on to the next one see if we can do one more before lunch die Hexel phthalate I don't think there are any human studies this time What would be the metabolite that they would measure if there are I don't know if ensign and Haynes has it It says here Frequently the urine of and Haynes The simple mono estates used the monocyclohexyl of the late mchp And I Rarely see it actually I don't see it Estimates and toys are negligible We don't even report it. Oh, it's very infrequently What can we can we make statements? It's not used in Currently used in children's toys and Childcare products correct you make that statement. It's not a case fairly analogous to The yeah, Pentel, which we discussed until the Dp and P We do a cut and paste Except the I don't think the toxicity developmental toxicity is the same. No, no, I agree, but I'll be it is one of the more potent Phthalates as far as I can see Yeah, yeah That they're right But I agree it's it's analogous to Bosure and risk, you know in terms of them. It's not very it's not really you about the recommendation We should do it all before lunch Okay moving on to by Hexhol phthalate now here's Similar to the last one. However, there's only one developmental talk study it produced That similar to other phthalates active phthalates well up Noel of 250 no human Toxic no current use Children's products Right. I was some so I don't but there's no information on exposures biomonitoring What was written for cyclohexyl? Yeah, I think this is a good time to break for lunch. Okay start Session that roughly one o'clock Okay, one o'clock