2,2-bis(chloromethyl)trimethylene bis(bis(2-chloroethyl)phosphate)

Ecotoxicological Summary

Hazard for aquatic organisms

Freshwater

Hazard assessment conclusion:

PNEC aqua (freshwater)

PNEC value:

0.074 mg/L

Assessment factor:

50

Extrapolation method:

assessment factor

PNEC freshwater (intermittent releases):

0.35 mg/L

Marine water

Hazard assessment conclusion:

PNEC aqua (marine water)

PNEC value:

0.007 mg/L

Assessment factor:

500

Extrapolation method:

assessment factor

PNEC marine water (intermittent releases):

0.35 mg/L

STP

Hazard assessment conclusion:

PNEC STP

PNEC value:

10 mg/L

Assessment factor:

100

Extrapolation method:

assessment factor

Sediment (freshwater)

Hazard assessment conclusion:

PNEC sediment (freshwater)

PNEC value:

0.45 mg/kg sediment dw

Extrapolation method:

equilibrium partitioning method

Sediment (marine water)

Hazard assessment conclusion:

PNEC sediment (marine water)

PNEC value:

0.045 mg/kg sediment dw

Extrapolation method:

equilibrium partitioning method

Hazard for air

Air

Hazard assessment conclusion:

no hazard identified

Hazard for terrestrial organisms

Soil

Hazard assessment conclusion:

PNEC soil

PNEC value:

0.37 mg/kg soil dw

Extrapolation method:

equilibrium partitioning method

Hazard for predators

Secondary poisoning

Hazard assessment conclusion:

PNEC oral

PNEC value:

1 mg/kg food

Assessment factor:

300

Conclusion on classification

Data presented are consistent with no classification for the environment.

The fish, Daphnia and algae acute E(L)C₅₀values all fall in the range 10 to 100 mg/l, and there is no evidence of ready degradability in standard tests. However, R52-53 is not applicable for 2,2-Bis(chloromethyl)trimethylene bis[bis(2-chloroethyl)phophate] for the reasons outlined below:

• The measured acute data show a similar level of sensitivity across the three taxonomic groups
• Reliable chronic NOECs are available for invertebrates and algae and both are above 1 mg/l (>3.7 and 10 mg/l respectively). The tests have been conducted well below the water solubility limit (232 mg/l), and the low log K_ow(2.83) does not suggest that the substance will accumulate over long periods (in line with measured BCF data for analogous substances). The acute toxicity therefore probably reflects the effect of uptake at steady state (i.e. not just partial uptake).
• There is reasonable agreement between the measured acute fish LC₅₀(52 mg/l) and QSAR predictions (17-32 mg/l, using SRC ECOSAR with measured physicochemical data entered). The substance therefore appears to be behaving in a predictable way.
• There is no indication of neurotoxicity in this chemical class from mammalian and avian studies.
• There is therefore no reason to suppose that there will be a significant difference in chronic effects in fish compared to the other taxa.
• Applying the worst-case acute-to-chronic ratio for Daphnia to fish would give a NOEC of approximately 4.5 mg/l. This is very similar to the QSAR estimate of 7.0 mg/l (using SRC ECOSAR with measured physicochemical data entered).
• The acute-to-chronic ratio would be above 50 if the fish NOEC were below 1 mg/l, which is clearly out of line with the observations for Daphnia and algae.

Given these considerations it is unlikely that 2,2-Bis(chloromethyl)trimethylene bis[bis(2-chloroethyl)phophate] would be chronically toxic to fish at <1 mg/l and testing to confirm this assertion could not be justified on animal welfare grounds. The substance should not therefore be classified.

Classification as not dangerous for the environment (not classified) was agreed at EU level in 2005.

Reference:

- Commission Working Group on the Classification and Labelling of Dangerous Substances Meeting on Environmental Effects of Existing Chemicals, Pesticides and New Chemicals, September 28 -30, 2005

- European Union Risk Assessment Report "2,2-Bis(chloromethyl)trimethylene bis[bis(2-chloroethyl)phophate]" (V6), CAS 38051-10-4, May 2008