Reaction mass of Amines, N-tallow alkyltrimethylenedi-, mono(2-ethylhexanoates), Amines, N-tallow alkyltrimethylenedi-, acetates and n-tallow-1,3-diaminopropane ditallate

Ecotoxicological Summary

Hazard for aquatic organisms

Freshwater

Hazard assessment conclusion:

PNEC aqua (freshwater)

PNEC value:

3.84 µg/L

Assessment factor:

50

Extrapolation method:

assessment factor

PNEC freshwater (intermittent releases):

2.87 µg/L

Marine water

Hazard assessment conclusion:

PNEC aqua (marine water)

PNEC value:

0.384 µg/L

Assessment factor:

500

Extrapolation method:

assessment factor

PNEC marine water (intermittent releases):

0.287 µg/L

STP

Hazard assessment conclusion:

PNEC STP

PNEC value:

1.26 mg/L

Assessment factor:

100

Extrapolation method:

assessment factor

Sediment (freshwater)

Hazard assessment conclusion:

PNEC sediment (freshwater)

PNEC value:

3.3 mg/kg sediment dw

Assessment factor:

50

Extrapolation method:

assessment factor

Sediment (marine water)

Hazard assessment conclusion:

PNEC sediment (marine water)

PNEC value:

0.33 mg/kg sediment dw

Assessment factor:

500

Extrapolation method:

assessment factor

Hazard for air

Air

Hazard assessment conclusion:

no hazard identified

Hazard for terrestrial organisms

Soil

Hazard assessment conclusion:

PNEC soil

PNEC value:

19.2 mg/kg soil dw

Assessment factor:

100

Extrapolation method:

assessment factor

Hazard for predators

Secondary poisoning

Hazard assessment conclusion:

PNEC oral

PNEC value:

170.5 µg/kg food

Assessment factor:

90

Additional information

General discusssion

As long-term NOECs from species representing two trophic levels are available (algae and daphnia) and these results cover the level showing the lowest EC50 in short term tests, an assessment factor of 50 may be used. However based on the observed lower toxicity to fish not only for the alkyl-1,3 -diaminopropanes but also for primary fatty amines and mono and dialkyl quats it is considered unlikely that fish toxicity will be critical for alkyl-1,3 -diaminopropanes. Hence any additional toxicity testing with fish will not add scientific value to the ecotoxicity profile of the alkyl-1,3-diaminopropanes other than for obtaining a lower assessment factor. It is therefore concluded that for scientific reasons and in accordance to REACH legislation further testing on fish has to be avoided for reasons of animal welfare and that based on the weight of evidence available on ecotoxicity data for several cationic surfactants the use of safety factor of 10 is justified for the derivation of the PNEC_aquatic,bulk. Despite of that an assessment factor of 50 is used for the calculation of the PNEC

The PNECsediment and the PNECsoil are derived on the basis of experimental data and the application of the appropriate assessment factor according to REACH guidance.

For classification purposes Ecotoxicity, Biodegradability and Bioconcentration have to be considered

Ecotoxicity

Due to intrinsic properties of amine containing cationic surfactants river water ecotoxicity tests deliver reproducible test results with limited uncertainty. As river water has a mitigating effect on ecotoxicity due to sorption of the amines to DOC and suspended matter a factor of 10 is applied to the L(E)C_xto correct for the lower ecotoxicity observed for the alkyl-1,3 -diaminopropanes. Algae are in general the most sensitive species and are therefore for most of the alkyl-1,3-diaminopropanes basis for classification. It should be noted that similar as for the alkyl-1,3 -diaminopropanes, the 21 day daphnia EC₅₀(parental mortality) is included in the table below at the acute EC50 for daphnia. For classification purposes the acute daphnia result as observed for R814M is used. The lowest chronic NOEC for (Z)-N-9 -octdecenyl-1,3 -diamopropane is 192 µg R814M/L (21d daphnia test in riverwater). Correcting this value for mitigation with the realistic worst-case correction factor of 10 leads to NOEC/EC10 for classification of 19.2 µg/L.

Available ecotoxicity data for R814M used for classification

	72 h algae ERC50(µg/L)	48h daphnia EC50 (µg/L)	96 h fish LC50 (µg/L)	Value used for classification (µg/L)
R814M	55.4	48.2	287 (RA)	48.2

 For chronic classification the long term ecotoxicity data as read across from oleyl and tallow-1,3 -diaminopropanes are used. Because these studies were performed in natural river water the value used for Classification is as a worst-case devided by a factor 10 to compensate for possible mitigation by river water constituents.

Available river water EC10/NOEC data algae and chronic daphnia used for classification

R814M read across from Alkyl-1,3-diaminopropanes	CAS number	72 h algae ERC10(µg/L)	21 d daphnia NOEC (µg/L)	EC10corr(µg/L) (corrected for Classification with Factor 10)
(Z)-N-9 -octdecenyl-1,3 -diaminopropane	7173 -62 -8	360	192	19.2

  

Biodegradability

Based on the available studies on biodegradation, R814M is considered to be readily biodegradable. The 10-days-window criterion does not need to be evaluated for the cationic surfactants under consideration as they are UVCB substances.

 

Bioconcentration factor

No measured BCF for fish is available. Standard OECD 305 tests are technically not feasible* with the strongly sorbing easily biodegradable substances and also not needed in the framework of PBT/vPvB assessment because the substance is readily biodegradable and therefore not P. REACh guidance chapter R.11 on PBT/vPvB assessment (v3.0, June 2017, p. 26).

Measured log Kow values for Oleyl-1,3,diaminopropane and R814M.

Alkyl-1,3 -diaminopropanes	CAS number	Slow stirring  log Kow	Ratio octanol solubility and CMC logKow
(Z)-N-9 -octdecenyl-1,3 -diaminopropane	7173 -62 -8	-0.0
R814M	-		4.21

* Considering the limited solubility of the test substance an OECD 305 -I (water exposure) is considered as not technically feasible. Because of the strong sorbing properties of the several constituents of the substance, maintaining steady concentrations of these constituents in water is technically not feasible. OECD 305-I and OECD 305-II is therefore waived according to annex XI, section 2 of REACh regulation EC 1907/2006.

In relation to OECD 305 -III (dietary) testing it should be noted that annex XIII of REACh requires a fish BCF to be derived to allow comparison with B/vB criteria. It is however known that OECD 305 -III only provides a fish BMF and that BMF cannot be directly compared to B/vB criteria. In order to be used in the framework of the PBT/vPvB assessment of REACh, BMF must be converted into BCF. Several equations are available to do so. However, all these equations use log Kow as a key parameter (i.e. they are based on the lipophilicity of the substance). Since log Kow is not considered to representatively predict the fate of surfactants, the available equations cannot be used to convert a BMF into a BCF for the registered substance. As a result, it is not feasible to derive a reliable BCF from an OECD 305-III test with the registered substance. This is due to the cationic surface-active property of the substance (i.e. one of its intrinsic properties). Performance of an OECD 305 -III study cannot reach its purpose (i.e. cannot be used to assess B/vB of the substance).

In conclusion OECD 305 -III testing is in general for cationic surfactants not technically feasible and should be waived according to annex XI (section 2) of REACh regulation EC 1907/2006.

Conclusion on classification

The available aquatic ecotoxicity data used for the dossier of "Reaction mass of Amines, N-tallow alkyltrimethylenedi-, (2-ethylhexanoates), Amines, N-tallow alkyltrimethylenedi-, acetates and n-tallow-1,3 -diaminopropane ditallate" (R814M) are presented in the table below

Aquatic ecotoxicity data used for R814M

Endpoint	Value*	Corrected value for C&L*	Value for R814M**	Value used for C&L
Fish acute (96h) LC50 (mg/L)	0.287	0.287		0.287
Daphnia acute (48h) EC50 (mg/L)	0.556	0.0556	0.0482	0.0482
Daphnia Chronic (21d) EC10/NOEC (mg/L)	0.192	0.0192		0.0192
Algae acute (72h) ErC50 (mg/L)	0.97	0.097	0.0554	0.0554
Algae Chronic (72h) ErC10/NOEC (mg/L)	0.36	0.036	0.0188	0.0188

* read across from alkyl-1,3-diaminopropanes and recalculated to R814M

Figures in bold are Bulk approach data obtained in tests with river water.

** Observed for R814M in acute daphnia and algae study.

The results presented in the table show that all acute ecotoxicity values (corrected and uncorrected) are below 1 mg/L. From the fate paragraph it can be read that all alkyl-1,3 -diaminopropanes are ‘readily biodegradable’ and have a low predicted bioaccumulation potential based on the measured log Kow values and observed biotransformation in in-vitro biotransformation tests.

Based on this information the environmental classification for R814M according to CLP (Classification, Labeling & Packaging Directive 1272/2008/EC) is:

Acute (short-term) aquatic hazard Acute Category 1

The corresponding M-factor is 10 based on the EC50 of 0.0482 mg/L.

When chronic toxicity data are available these should be used for classification for chronic aquatic hazard. Considering the lower sensitivity of fish it is considered justified to use the long-term daphnia and algae test results for the chronic classification.

R814M is readily biodegradable and the lowest EC10/NOEC is 0.0188 mg/L (72h ErC10 algae test with R814M). This leads to a classification of:

Chronic (Long-term) aquatic hazard Chronic Category 1

No M-factor is needed for chronic classification based on the EC10/NOEC of 0.0188 mg/L and R814M being readily biodegradable.

 

 

ot need to be assigned.

This leads to the following environmental classification according DSD for (Z)-N-9 -octadecenyl-1,3-diaminopropane and N-C16-18-alkyl-(evennumbered) C18 unsaturated-1,3-diaminopropane is:

.

 N, R50