Technical Basis
A review of available sources did not identify exposure limits or acute toxicity data for phosphonoacetic acid. A low-reported GHS health hazard rating (H314, Category 1) indicates a high-level health hazard, approximately equivalent to an HHR=3. Analysts also evaluated structurally similar chemicals, 2-Phosphonopropionic acid (CASRN: 5962-41-4) and phosphorous acid (CASRN: 31669-80-4); these reported similar GHS ratings as the chemical of interest. Considering this, analysts assumed an HHR=3 as the TEEL-3 basis (Section 3.4.5). TEEL-2 and TEEL-1 values were derived according to Table 3.5.
• PAC-1 = TEEL-1 = TEEL-2/11
• PAC-2 = TEEL-2 = TEEL-3/6
• PAC-3 = TEEL-3 = HHR=3
This review generated PAC values inconsistent with Rev. 29A. The Rev. 29A TEEL-1 basis was a TLV-TWA for particles not otherwise specified (Section 3.5.2), from which the TEEL-2 and TEEL-3 were derived (Table 3.5). The current TEEL-3 basis is an assumed HHR=3, from analysis of GHS health hazard statements, from which TEEL-2 and TEEL-1 were derived (Table 3.5).