Fatty acids, C14-18 and C16-18-unsatd., zinc salts

Ecotoxicological Summary

Hazard for aquatic organisms

Freshwater

Hazard assessment conclusion:

PNEC aqua (freshwater)

PNEC value:

183.9 µg/L

Assessment factor:

1

Extrapolation method:

sensitivity distribution

Marine water

Hazard assessment conclusion:

PNEC aqua (marine water)

PNEC value:

54.5 µg/L

Assessment factor:

1

Extrapolation method:

sensitivity distribution

STP

Hazard assessment conclusion:

PNEC STP

PNEC value:

892.9 µg/L

Assessment factor:

100

Extrapolation method:

assessment factor

Sediment (freshwater)

Hazard assessment conclusion:

PNEC sediment (freshwater)

PNEC value:

1 051.8 mg/kg sediment dw

Assessment factor:

1

Extrapolation method:

sensitivity distribution

Sediment (marine water)

Hazard assessment conclusion:

PNEC sediment (marine water)

PNEC value:

504.5 mg/kg sediment dw

Assessment factor:

1

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:

317.9 mg/kg soil dw

Assessment factor:

1

Extrapolation method:

sensitivity distribution

Hazard for predators

Secondary poisoning

Hazard assessment conclusion:

no potential for bioaccumulation

Additional information

Fatty acids, C14-18 and C16-18-unsatd., zinc salts consist of fatty acid anions (C14-18-satd. and C16-18-unsatd.) and zinc cations. In the assessment of environmental fate and toxicity of Fatty acids, C14-18 and C16-18-unsatd., zinc salts, a read-across to the assessment entities soluble zinc substances and C14-18 fatty acids is applied since the ions of fatty acids, C14-18 and C16-18-unsatd., zinc salts determine its environmental fate and toxicity. Since zinc cations and fatty acid anions behave differently in the environment, including processes such as stability, degradation, transport and distribution, a separate assessment of the environmental fate and toxicity of each assessment entity is performed. Please refer to the data as submitted for each individual assessment entity. For a documentation and justification of that approach, please refer to the separate document attached to section 13, namely Read Across Assessment Report for Fatty acids, C14-18 and C16-18-unsatd., zinc salts.

Fatty acids are generally not considered to represent a risk to the environment, which is reflected in their exclusion from REACH registration requirements (c. f. REACH Annex V (Regulation (EC) No 987/2008)). Zinc compounds, however, may have an impact to the environment. For PNEC derivation and the decision on C&L requirements, data of the analogue substances Fatty acids, C16-18, zinc salts and zinc dilaurate (C12) and data for soluble zinc substances are considered.

Fatty acids, C14-18-satd. and C16-18-unsatd., zinc salts is poorly soluble in water (< 2 mg/L), and thus the respective bioavailability in environmental compartments is very low. The ecotoxicity data available for structural analogues, i.e. fatty acids, C16-18, zinc salts and zinc dilaurate (C12), although limited, indicate that the acute aquatic toxicity of the substance Fatty acids, C14-18 and C16-18-unsatd., zinc salts to algae, daphnia and fish is orders of magnitude above the respective water solubility limit:

- The acute toxicity of the structural analogue Fatty acids, C16-18, zinc salts to Daphnia magna was determined according to OECD 202 in M7 medium at pH 6 and 8 (Bouwman et al., 2003). The EC50 was not reached up to a loading rate of 100 mg fatty acids, C16-18, zinc salts/L. At this loading, the zinc concentration at the beginning of the test was 1170 μg Zn/L at pH 8 and 800 μg Zn/L at pH 6. The test report concludes: “No daphnids became immobilised during the test period. Although all daphnids exposed to the undiluted water fraction had test substance on their bodies at the end of the test, this did not hinder them”. The low potential for toxicity is further supported by studies performed with the structural analogues zinc bis[12-hydroxyoctadecanoate], a zinc salt of a C18 fatty acid of similar zinc content, and zinc dilaurate, a zinc salt of a shorter-chained fatty acid (C12) but with a higher zinc content. In the case of zinc bis[12-hydroxyoctadecanoate] an EC50 could not be derived up to a nominal loading of 1000 mg/L (Rudolf, 2002). The toxicity of zinc dilaurate to Daphnia magna is also above the water solubility limitof approx. 5 mg/Land an EC50 could also not be derived up to a loading of 10 mg zinc dilaurate/L at pH 7.8 (Muckle, 2009). Thus, acute toxicity data of structural analogues, i.e. zinc salts of fatty acids with shorter and similar chain length, support the conclusion that Fatty acids, C14-18 and C16-18-unsatd., zinc salts is not acutely toxic to invertebrates.

- Information on fish toxicity of the structural analogue fatty acids, C16-18, zinc salts are available from a study performed according to EU Method C.1 (Acute Toxicity for Fish) in the former version of 1992 (Henkel KGaA, 1995), from a study performed according to OECD Guideline 203 (Fish, Acute Toxicity Test) but reported only in a short study report (TÜV Bayern Sachsen E.V., 1992) and from an older publication (Dowden and Bennett, 1965). In the most reliable study (Henkel KGaA, 1995), fish (Danio rerio) were exposed for 96 hours to nominal concentrations of 0 (control), 1000, 3000 and 10000 mg/L under semi-static conditions. The nominal concentrations far exceed the water solubility of fatty acids, C16-18, zinc salts by 3 to 4 orders of magnitude. Measures to disperse the test substance in the test water were used. At all tested concentrations, including the highest nominal test concentration, behavioural abnormalities or mortality were not observed. Effects were also not observed at nominal concentrations of fatty acids, C16-18, zinc salts up to the water solubility limit in two further studies. These findings are further supported by acute aquatic toxicity data of a zinc salt of fatty acids with a shorter alkyl chain length and a relatively higher zinc content, i.e. zinc dilaurate, with a 96-h NOEC of 10 mg/L for fish that is above the respective water solubility limit of 5 mg/L (Muckle 2009). In accordance with the EU Risk assessment on the structural analogue zinc distearate (Final report R074_0805_env, May 2008) and taken into account results of tests with the structural analogues fatty acids, C16-18, zinc salts and zinc dilaurate (C12), it is assumed that the toxicity of Fatty acids, C14-18 and C16-18-unsatd., zinc salts to fish is (far) above the water solubility limit of around 2 mg/L.

These daphnia and fish toxicity data have already been assessed within the EU risk assessment on zinc stearate, a structural analogue of Fatty acids, C14-18 and C16-18-unsatd., zinc salts. In the meantime, since finalisation of the EU risk assessment additional data on the algal toxicity of structural analogue fatty acids, C16-18, zinc salts were generated:

- The toxic effects of the dissolved fraction of structural analogue fatty acids, C16-18, zinc salts on the growth rate of algae (Pseudokirchneriella subcapitata) were studied in three tests according to OECD Guideline 201 (Wenzel, 2010a, b and 2013). While in the first test, the dissolved fraction of a loading of 100 mg/L in a non-standard test medium was diluted in series to allow the calculation of toxicity parameters (EL10, EL50) (Wenzel, 2010a), the dissolved fraction of several loadings (1, 10, and 100 mg/L) in non-standard medium were applied in the second test according to OECD Series No. 23 (Wenzel, 2010b). In the third test by Wenzel (2013), lower concentrations were applied (i.e. 0.01, 0.1, 1.0, 10.0 and 100.0 mg/L) in the standard test medium to enable the classification for a potential aquatic hazard based on dissolved fractions. The EL10 and EL50 values for the 72-h inhibition of growth rate of P. subcapitata in the standard test medium are 3.31 mg/L and > 100 mg/L, respectively. Thus, algae appear to be the most sensitive trophic level with regard to acute toxicity of structural analogue fatty acids, C16-18, zinc salts. In addition, a growth inhibition test with P. subcapitata exposed to the dissolved fractions of the shorter-chained fatty acid (C12) zinc salt zinc dilaurate at loadings of 0.01, 0.1, 1 and 10 mg/L in standard test medium over a test period of 72 hours revealed calculated EL50 values for growth rate of 12.87 mg/L (extrapolated) while the EL10 was 3.73 mg/L, based on loadings of the applied dissolved fraction (Wenzel, 2013b). In growth inhibition tests of the alga Desmodesmus subspicatus performed with the structural analogue zinc bis[12-hydroxyoctadecanoate] and the shorter-chained zinc dilaurate (C12), 72h-EC50 and 72h-NOEC values far above the maximum water solubility were reported (Rudolph, 2002 and Muckle, 2009, respectively). In sum, structural analogues, i.e. zinc salts of fatty acids with a similar or shorter chain length, similar water solubility and similar or higher zinc content are not toxic to algae at concentrations ≤ relevant acute and chronic aquatic classification criteria; and the potential of Fatty acids, C14-18 and C16-18-unsatd., zinc salts for toxicity to freshwater algae and cyanobacteria is considered similarly low.

- The data indicate that structural analogue substances, such as Fatty acids, C16-18, zinc salts, have a significantly lower aquatic toxicity than soluble zinc salts, including zinc chloride or zinc sulphate. Therefore, it is assumed that a high portion of zinc from fatty acid zinc salts in general and also of Fatty acids, C14-18 and C16-18-unsatd., zinc salts is not bioavailable, likely because the substances only partly dissociate into zinc cations and fatty acid anions (poorly soluble in water, < 2 mg/L).

 

Taking into account measured dissolved zinc concentrations at 1 mg/L loading of the structural analogue fatty acids, C16-18, zinc salts after 7 days and the acute ecotoxicity reference values of zinc, it is expected that the substance Fatty acids, C14-18 and C16-18-unsatd, zinc salts does not meet classification of Acute Category 1 according to Figure IV.1 "Classification strategy for determining acute aquatic hazard for metals" (ECHA Guidance on the application of CLP criteria, 2017).

 

Based on the ecotoxicity reference values of zinc, algae appear to be the most sensitive trophic level with regard to long-term toxicity. However, effect levels of structural analogues, i.e. fatty acids, C16 -18, zinc salts and zinc dilaurate (C12) for algae are above long-term CLP classification criteria.

Considering measured dissolved zinc concentrations at 1 mg/L loading of structural analogue fatty acids, C16 -18, zinc salts after 28 days in the transformation/dissolution test and the chronic ecotoxicity reference values of zinc for the other trophic levels with invertebrates being the 2nd most sensitive, it is expected, that Fatty acids, C14-18 and C16-18-unsatd, zinc salts would not meet chronic classification according to Figure IV.2 "Classification strategy for determining long-term aquatic hazard for metals" (ECHA Guidance on the application of CLP criteria, 2017). The zinc level after 28 d of transformation/dissolution of 1 mg/L of structural analogue fatty acids, C16 -18, zinc salts is not above chronic ecotoxicity reference values available for the other trophic levels (i.e. invertebrates and fish). Based on the data of structural analogues, it is concluded that, Fatty acids, C14-18 and C16-18-unsatd, zinc salts does not meet long-term aquatic hazard classification criteria of Regulation (EC) No 1907/2006.

 

Transformation/dissolution of the structural analogue fatty acids, C16 -18, zinc salts according to OECD Series # 29:

Loading 1 mg/L OECD medium:           -after 7 days:         19 µg Zn/L

                                                            -after 28 days:       29 µg Zn/L

Loading 10 mg/L OECD medium:        -after 7 days:         90 µg Zn/L

Loading 100 mg/L OECD medium:      -after 7 days:         369 µg Zn/L

 

Based on the hazard assessment of "Zinc" within the framework of Regulation (EC) No 1907/2006, reference values for the Zn2+- ion are:

Acute:

For low pH:                      0.413 mg Zn/L (based on single lowest value for Ceriodaphnia dubia)

for neutral/high pH:      0.136 mg Zn/L (based on single lowest value for Pseudokirchneriella subcapitata

 

Chronic:

-for low pH:                     0.082 mg Zn/L (Daphnia magna)

-for neutral/high pH:     0.019 mg Zn/L (Pseudokirchneriella subcapitata).

 

The solubility of fatty acids, C14-18-satd. and C16-18-unsatd., zinc salts may not correspond to the actual bioavailability and subsequent ecotoxicity of zinc, possibly due to the formation of micelles in the medium rendering dissolved zinc unavailable. Indeed, the absence of toxicity of the structural analogues to daphnia and fish in acute aquatic tests indicate that the actual toxicity is substantially lower than the predicted toxicity by use of the transformation/dissolution data and the aquatic toxicity data on Zn2+ toxicity.

Confirmatory transformation/dissolution testing of Fatty acids, C14-18 and C16-18 unsatd., zinc salts (i.e., finest material as put on the market) in environmental media according to OECD Series #29 (2001) is planned by the of Zinc Metallic Soaps Consortium. The hazard assessment of Fatty acids, C14-18 and C16-18 unsatd., zinc salts will be updated accordingly upon finalisation of the study.

 

In sum, toxicity scores of the most sensitive trophic level, i.e. EL10 value (3.31 mg/L and 3.73 mg/L) and EL50 value (> 100 mg/L and 12.87 mg/L) derived for growth rate of the alga P. subcapitata in a standard test medium, for the structural analogues fatty acids, C16-18, zinc salts and zinc dilaurate (C12), respectively, indicate that zinc salts of fatty acids with similar or shorter chain length, similar water solubility and similar or higher zinc content do not meet classification criteria for acute and chronic aquatic hazard. Therefore, Fatty acids, C14-18 and C16-18-unsatd., zinc salts do also not require classification for acute and chronic aquatic hazard. In addition, the structural analogues, i.e. fatty acids, C16-18, zinc salts (93 % degradation within 28 days in an OECD 301D study by TÜV, 1992) and Octanoic acid, zinc salt, basic (C8) (> 80 % in an OECD 301F study by Simon, 2012) are readily biodegradable which indicates that fatty acids, C14-18 and C16-18-unsatd., zinc salts is also readily biodegradable. Bioaccumulation is not expected, knowing that fatty acids degrade by the ß-oxidation pathway.

The classification and labelling decision for Fatty acids, C14-18 and C16-18-unsatd., zinc salts is based on evidence of the lack of a potential for toxicity to aquatic organisms below relevant criteria for classification and for bioaccumulation. It is therefore concluded that the substance Fatty acids, C14-18 and C16-18-unsatd., zinc salts does not need to be classified for the environment according to Regulation (EC) No 1272/2008. This conclusion on non-classification is consist with the conclusion drawn in the EU risk assessment on the structural analogue zinc stearate (i.e. Fatty acids, C16-18, zinc salts) carried out within the framework of EU Existing Chemicals Regulation (EEC) No 793/93 (Final report R074_0805_env, May 2008): “Based on the stoichiometrical content of zinc (10 % by weight) in a saturated solution of zinc distearate and the lowest acute EC50 value for soluble zinc, being 70 μg Zn/L for crustacean Daphnia magna (based on accepted tests with soluble zinc, see the environmental classification and labelling section in the RAR Zinc metal), zinc distearate should be classified for the aquatic environment with R50-R53, according to the transformation/dissolution protocol. However, since there were doubts whether the stoichiometrical calculation corresponds to the true content in Zn2+free cations concentration, different approaches have been used to measure the water solubility of zinc from zinc distearate. The measurements were carried out in different media, a/o ISO 6341 medium and Elendt M7, using different detection methods, a/o photometric detection and Differential Pulse Anodic Stripping Voltammetry (DPASV). At a loading rate of 100 mg zinc distearate/L, the detection techniques reveal different zinc concentrations: ranging from 30-60 μg Zn/L using photometric detection and 250-500 μg Zn/L using DPASV. No explanation can be given to clarify this difference (Mayer et al., 2001; Bowmer, 2002).

 

In order to come to a final conclusion, the acute toxicity of zinc distearate to Daphnia magna was determined according to OECD 202 in M7 medium at pH 6 and 8 (Bouwman et al., 2003). Up to a loading rate of 100 mg zinc distearate/L the EC50 was not reached. The zinc concentration (detected using ICP-MS) at the beginning of the test was 1170 μg Zn/L at pH 8 and 800 μg Zn/L at pH 6, at a loading rate of 100 mg zinc distearate/L. In ISO medium at pH 6 the same concentration was measured, whereas at pH 8 the concentration was much lower: 550 μg Zn/L. The absence of toxicity cannot be explained by the presence of EDTA in the Elendt medium, since the EDTA concentration present could bind at maximum 11% of the zinc being analysed (based on one to one ratio). It is therefore assumed that a high portion of zinc in solution is not bioavailable, likely because zinc distearate is only partly dissociated into the zinc cation and the fatty acid anions. It is assumed that this low bioavailability not only applies for daphnids, but for algae and fish as well. For fish this is confirmed by the limited information available on acute toxicity in three tests: no effects on the fish were observed in these tests at concentrations at or far above the maximum water solubility limit of zinc distearate (see section 3.3).

According to the transformation/dissolution protocol, a chronic toxicity test had to be performed with a solution stirred for 28 days at a loading rate of 1000 μg zinc stearate/L. Since in the above-mentioned acute toxicity test with D. magna no effect was found at a concentration of approximately 900 μg Zn/L, measured by ICP-MS (Bouwman et al., 2003), it can be argued that the free Zn2+ion concentration has to be lower than the lowest acute EC50 of 70 μg Zn/L for soluble zinc (from a test with D. magna, see earlier in this section). Assuming that 1000 μg zinc distearate/L will be completely dissolved, giving a total Zn concentration of 100 μg Zn/L, the equilibrium between stearate and Zn ions has to shift strongly to the right in order to reach the lowest reported NOEC (34 μg Zn/L) included in the RAR Zinc metal. This is considered unlikely and therefore R53 is not applicable. Although distearate cannot be considered as readily biodegradable (based on an OECD 301D study), distearate is not expected to bioaccumulate, knowing that fatty acids will degrade by the β-oxidation pathway.

(In the final version of the RAR Zinc metal, which was finalised after the decision on the classification of zinc distearate (see below), the lowest chronic NOEC is 17 μg Zn/L, being the ‘species mean’ value for alga Pseudokirchneriella subcapitata. For Daphnia magna, the aquatic species with the lowest acute L(E)C50(70 μg Zn/L), the ‘species mean’ chronic NOEC is 88 μg Zn/L).

Conclusion: “Zinc distearate is not classified for the environment.”

 

In the meantime, since finalisation of the EU RAR Zinc stearate, a further transformation/dissolution test and algal toxicity tests (see above and IUCLID sections 4.8 and 6.1.5) have been performed. The measured zinc concentrations in the now available transformation/dissolution test, which was performed in accordance with ECHA guidance following the method described in OECD Series on Testing and Assessment. Draft Guidance Document on Transformation/Dissolution Metals and Metal Compounds in Aqueous Media. Number 29 (2001) were below the values measured in the tests evaluated in the EU Risk Assessment (see above). The result of the algal toxicity tests with structural analogues, i.e. zinc salts of fatty acid with similar or shorter chain length, confirm the assumed low toxicity of the substance Fatty acids, C14-18 and C16-18-unsatd., zinc salts to aquatic organisms, as consistently observed in tests performed with fish, aquatic invertebrates and micro-organisms. The now additional available transformation/dissolution and toxicity data for structural analogue fatty acids, C16-18, zinc salts support the conclusion made in the EU Risk assessment. Accordingly, it is expected, that Fatty acids, C14-18-satd. and C16-18-unsatd., zinc salts also does not pose a hazard to the environment and there is no reason to classify this substance for environmental hazards.

Nevertheless, as only limited environmental toxicity data are available for Fatty acids, C14-18-satd. and C16-18-unsatd., zinc salts and its structural analogues, a read-across to soluble zinc substances is applied, and the PNECs as derived in the Chemical Safety Assessment of "Zinc" within the framework of Regulation (EC) No 1907/2006 are read-across to Fatty acids, C14-18-satd. and C16-18-unsatd., zinc salts taking into account the maximum zinc content of 11.2%.

Conclusion on classification

Based on reliable, adequate and relevant studies on structural analogues, the substance Fatty acids, C14-18 and C16-18-unsatd., zinc salts does not require classification as short-term and long-term aquatic hazard according to Regulation (EC) No 1272/2008.

This conclusion is consistent with the conclusions of the EU risk assessment on the structural analogue Zinc distearate (i.e. Fatty acids, C16-18, zinc salts) carried out within the framework of EU Existing Chemicals Regulation (EEC) No 793/93 (Final report R074_0805_env, May 2008): Zinc distearate is not classified for the environment."