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fish early-life stage toxicity
Data waiving:
other justification
Justification for data waiving:
Justification for type of information:
A full set of short-term aquatic toxicity data is available for TGA and MeaTG. In addition, singe data points are available for ATG (short-term toxicity to fish) and KTG (toxicity to algae). A Daphnia reproduction test was conducted with TGA.
A long-term toxicity study in fish is not required for this category, since neither of the substances showed any effects to fish in the available short-term toxicity studies (96 h LC50 >100 mg/L in the studies conducted with TGA, ATG, and MeaTG).
Instead, an acute to chronic ratio is provided. The acute to chronic ratio is calculated by dividing the LC50 by the Maximum Acceptable Toxicant Concentration (MATC) which is s determined by taking the square root of the NOEC multiplied by the LOEC ( MATC = sqrt ( NOEC x LOEC )).

Acute to chronic ratio for TGA:
Daphnia Algae
EC50 (geom. mean if applicable) 32.4 3.47
NOEC (geom. mean if applicable) 2.7 0.37
LOEC (geom. mean if applicable) 6.5 0.53
MATC 4.19 0.44
ACR 7.73 7.84

This ACR is applied to estimate the MATC for fish, which is > approx. 12.8 mg/L based on the 96 h LC50(fish)>100 mg/L. For animal welfare reasons and fish being not the most sensitive species, the conduct of a long-term toxicity test to fish is not acceptable. In addition, conservative assessment factors are applied to derive the PNECs. Therefore, no higher safety level would be reached by providing this study.

Data source

Materials and methods

Results and discussion

Applicant's summary and conclusion