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Environmental fate & pathways

Biodegradation in soil

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The performance of simulation tests covering the soil compartement is scientifically not justified due to the fact that the biodegradation of a representative substance for " Hydrochloric acid, reaction products with aniline and nitrobenzene, sulfonated, sodium salts" was modeled with the EAWAG-BBD Pathway prediction system (PPS) and did not reveal a significant potential for biodegradation. In line with these results the substance is neither inherently nor rapidly biodegradable in water (Kanne, 1987). As a consequence the substance can be regarded as not biodegrable in soil as well. Both arguments are laid out in further detail in the attached waiver justification document.  In addition, the performance of simulation tests would not provide additional information for the hazard, risk and persistency assessment. As the substance neither fulfills the B, nor the T criterion, no further information is required for the PBT assessment (Guidance Document R.7b, ECHA, 2012).

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