Fatty acids, C18 (even numbered) and C18 unsatd., reaction products with triethanolamine, di-Me sulfate quaternized

Endpoint summary

Description of key information

Overall, the most sensitive organism in all available studies was fish. Thus, the lowest acute toxicity value is the 96 h LC50 of 1.91 mg/L obtained with Oncorhynchus mykiss. This value obtained with the source substance partially unsaturated TEA-Esterquat is also protective for the target substance C18 and C18 unsatd. TEA-Esterquat and will be used for the derivation of PNECs.

Additional information

A fish embryo test conducted with the target substance C18 and C18 unsatd. TEA-Esterquat is available. No experimental data on the short-term toxicity aquatic invertebrates and algae are available for the target substance C18 and C18 unsatd. TEA-Esterquat. However, reliable relevant data are available for the closely related source substances partially unsaturated TEA-Esterquat and fully saturated TEA-Esterquat. Long-term toxicity studies in fish and Daphnia are ongoing with the source substance partially unsaturated TEA-Esterquat. When the data become available, the dossier will be updated accordingly. A justification for read-across is given below.

 

Toxicity to fish

In a 96-h acute toxicity study according to OECD Guideline 236, adopted July 26, 2013, embryonic stages of zebrafish (Danio rerio) were exposed to C18 and C18 unsatd. TEA-Esterquat at nominal concentrations of 0 (control) and 100 mg a.i./L under static conditions.

The test embryos were observed at test start and after approximately 24, 48, 72 and 96 hours test duration for hatching and apical observations (coagulation, somite formation, detachment of tail bud), whereas hatching and heart beat were only observed after 48, 72 and 96 hours.

4 days prior to the test all wells were preconditioned with the test water. Each well was filled with at least 2 mL freshly prepared test water with the respective concentration of the test item, reference item or negative control.

After 96 hours, all fish embryos survived in the control. In the only test item concentration of nominal 100 mg test item/L one embryo died after 96 hours. The death of one embryo in the only test item concentration is most probably not substance related since it is within the mortality range allowed to occur in the control (<10%).

Hatching success in the control was 100% and in the only test item concentration 95%. In the only test item concentration of nominal 100 mg test item/L all surviving embryos hatched. In the internal plate control of nominal 100 mg test item/L all embryos survived and 100% hatched after 96 hours.

The 96-h LC50 was >100 mg a.i./L based on analytically verified nominal concentrations.

 

In a 96-h acute toxicity study conducted according to OECD Guideline 203 (Fish, Acute Toxicity Test), rainbow trouts (Oncorhynchus mykiss) were exposed to partially unsaturated TEA-Esterquat at nominal concentrations of 0 (control), 1.0, 1.6, 2.56, 4.1, 6.55, 10.55 mg/l under semi static conditions. The mean measured concentrations were determined to be 59 % of nominal concentrations. The 96-h LC50 was 1.91 mg/L (based on mean measured concentrations). Sublethal effects such as difficulties with maintenance of balance and unusual behaviour (reduced activity and or orientation to bottom or surface of the test vessels) were observed within the first three hours in the highest test concentration.

Several supporting studies conducted with the source substance partially unsaturated TEA-Esterquat are available, which are described in section “Short-term toxicity to fish”.

 

In accordance with REACH Regulation, Annex IX, 9.1.6, column 2, long-term toxicity testing on fish does not need to be conducted. A test for long-term toxicity on fish is only required if the chemical safety assessment, according to Annex I, indicates the need to investigate further the effects on aquatic organisms. The choice of the appropriate test(s) depends on the results of the chemical safety assessment. As the registered substance does not need to be classified with regard to environmental effects, an exposure assessment is not required. The long-term exposure of aquatic organisms is unlikely as the substance is readily biodegradable. The ready biodegradability of the substance is proved in a number of tests conducted under different conditions (aerobic, anaerobic).

 

Toxicity to aquatic invertebrates

The 48 hr acute toxicity of partially unsaturated TEA-Esterquat to Daphnia magna according to EU Method C.2 (Acute Toxicity for Daphnia) was studied under static conditions.  Daphnids were exposed to control, and partially unsaturated TEA-Esterquat at nominal concentration of 1, 2.2, 4.84, 10.6, 23.4, 51.5, 113 mg test mat./L for 48 hr.  Mortality/immobilization was observed daily. The 48 hour EC50 was 2.23 mg a.i./L. The effect concentration was corrected for the analytical recovery of 93%

 

In accordance with REACH Regulation, Annex IX, 9.1.5 column 2, long-term toxicity testing on aquatic invertebrates does not need to be conducted. A test for long-term toxicity on aquatic invertebrates is only required if the chemical safety assessment, according to Annex I, indicates the need to investigate further the effects on aquatic organisms. The choice of the appropriate test(s) depends on the results of the chemical safety assessment. As the registration substance does not need to be classified with regard to environmental effects, an exposure assessment is not required. The long-term exposure of aquatic organisms is unlikely as the substance is readily biodegradable. The ready biodegradability of the substance is proven in a number of tests conducted under different conditions (aerobic, anaerobic).

 

Toxicity to algae

Acute value 72 h ErC50:

The lowest effect concentration of all valid tests is used. The test was made with fully saturated TEA-Esterquat which inhibited significantly the increase of biomass of the alga   Scenedesmus subspicatus in a study conducted according to OECD Guideline 201 (Alga, Growth Inhibition Test). The 72h-ErC50 was 1.52 mg/L.

 

Long-term value 72 h EC10:

As long-term effect value, instead of the NOEC, the EC10 is used. The current OECD guideline 201 as well as ECHA Guidance R.10, 2008 (Table R.10-1) as well as ECHA CLP Guidance, Nov. 2012 (4.1.3.1.1) recommend the use of the ErC10 instead of NOEC for classification as well as starting point for PNEC derivation.

For the long-term effect value 72 h ErC10, relevant studies are considered in a Weight of Evidence (WoE) approach: For the endpoint “Toxicity to aquatic algae and cyanobacteria”, there are five valid and comparable studies for the same taxonomic group available. For each study there is a full endpoint study record (EPR) in the dossier.

The 72 h ErC10 values for these studies are:

(a): 0.68 mg/L

(b): 1.53 mg/L

(c): 5.09 mg/L

(d): 1.26 mg/L

(e): 1.26 mg/L

The assessment of these comparable studies showed no study inherent reason for differences in results. All five studies were conducted following guidance OECD Guideline 201. All five EPR consider for effect calculation a concentration reduction factor to map the decrease of nominal concentration during the test duration. The values for the 72 h ErC10 range from 0.68 - 5.09 mg/L. For the WoE approach, the geometric mean of the five 72 h ErC10 values was calculated. According to this WoE approach, for this endpoint the 72 h ErC10 = 1.48 mg/L.

 

Toxicity to aquatic microorganisms

In a study with fully saturated TEA-Esterquat the acute bacterial toxicity towards Pseudomonas putida was determined under static conditions according to DIN 38412, part 27 (Inhibition of oxygen demand (Sauerstoffzehrungshemmtest) at test material concentrations of 10, 30, 100 mg test mat./L. The calculated effect concentrations after 30 minutes were as follows: EC0: 24.0 mg a.i./L, EC10: 29.6 mg a.i./L, EC50: 60 mg a.i./L.

Supporting data are available for partially unsaturated TEA-Esterquat, which are described in section “Toxicity to microorganisms”.

 

Sediment toxicity

In accordance with column 2 of REACH Regulation, Annex X, section 9.5.1, long-term toxicity testing with sediment organisms does not need to be conducted. Testing shall be proposed if the results of the environmental exposure assessment indicate the need. As the registration substance needs not to be classified, an environmental exposure assessment is not required.

 

Conclusion 

Overall, the most sensitive organism in all available studies was fish. Thus, the lowest acute toxicity value is the 96 h LC50 of 1.91 mg/L obtained withOncorhynchus mykiss. This value obtained with the source substance partially unsaturated TEA-Esterquat is also protective for the target substanceC18 and C18 unsatd. TEA-Esterquat and will beused for the derivation of PNECs.

 

JUSTIFICATION FOR READ-ACROSS

For details on substance identity and detailed toxicological profiles, please refer also to the general justification for read-across given at the beginning of the CSR and attached as pdf document to IUCLID section 13.

This read-across approach is justified based on structural similarities. The target and source substances contain the same functional groups. Thus a common mode of action can be assumed. The only variation is a slight difference in carbon chain length distribution and the degree of unsaturation.

 

a. Structural similarity and functional groups

The target substance C18 and C18 unsatd. TEA-Esterquat is a UVCB substance manufactured from fatty acids (C18 and C18 unsatd) and triethanolamine. Subsequently the product is reacted with dimethyl sulphate for quaternisation. 

 

The source substance partially unsaturated TEA-Esterquat is a UVCB substance manufactured from fatty acids (C16-18 (even numbered) and C18 unsatd.) and triethanolamine. Subsequently the product is reacted with dimethyl sulphate for quaternisation. 

 

The source substance fully saturated TEA-Esterquat is a UVCB substance manufactured fromfatty acids (C16-18 (even numbered)) and triethanolamine. Subsequently the product is reacted with dimethyl sulphate for quaternisation. 

 

 

b. Differences

Differences in chemical and other intrinsic properties of the target and source substances could potentially arise from the following facts:

 

Degree of esterification: The lipophilic properties increase with the degree of esterification. As the distribution of mono-, di and tri-esters of the target and source substances is similar, no significant differences in properties are expected.

 

Chain-length distribution: Lipophilic properties of molecules also increase with increasing fatty acid chain-length. The amounts of chain-lengths lower than C16 and higher than C18 are comparably low in both the target and the source substance. In contrast to the target substanceC18 and C18 unsatd. TEA-Esterquat, the source substances partially unsaturated TEA-Esterquat and fully saturated TEA-Esterquat contain considerable amounts of C16. This may be considered as a worst case as the bioavailability of shorter chain lengths is in general higher.

 

Amount of unsaturated fatty ester moieties: The amount of unsaturated fatty acid moieties is slightly higher in the source substancepartially unsaturated TEA-Esterquat compared to the target substanceC18 and C18 unsatd. TEA-Esterquat.As fatty acids independently from their degree of unsaturation are generally considered to be non-toxic, a variability in the fatty acid moiety is not expected to have any influence on the aquatic toxicity of the substances.

 

Comparison of aquatic toxicity data

Endpoints	Target substance C18 and C18 unsatd. TEA-Esterquat	Source substance Partially unsaturated TEA-Esterquat	Source substance Fully saturated TEA-Esterquat
Short-term toxicity to fish	key_Short-term toxicity to fish: 9.1.3._Stepan_2016_OECD236   OECD TG 236, embryonic stages of Danio rerio, static, freshwater   96 h LC50 > 100 mg/L   Reliability: 1 (reliable without restriction), GLP	key_RA_Short-term toxicity to fish: 157905-74-3_9.1.3_EBRC 2005_OECD 203   OECD TG 203, Oncorhynchus mykiss, semi-static, freshwater 96 h NOEC = 1.51 mg/L 96 h LC50 = 1.91 mg/L 96 h LC100 = 2.42 mg/L 72 h LC50 = 1.91 mg/L 48 h LC50 = 1.91 mg/L 24 h LC50 = 2 mg/L   Reliability: 1 (reliable without restriction), GLP	No data
		sup_RA_Short-term toxicity to fish: 91995-81-2_Study_9-1-3_Fish_Cognis_R0100273_2001_OECD 203   OECD TG 203, Danio rerio (reported as Brachydanio rerio), semi-static, freshwater 96 h LC0 = 0.66 mg/L 96 h LC50 = 2.1 mg/L 96 h LC50 = 2.6 mg/L 96 h LC100 = 3.2 mg/L   Reliability: 1 (reliable without restriction), GLP
		sup_RA_Short-term toxicity to fish: 91995-81-2_Study_9-1-3_Fish_KaoST000971_1991_OECD 203   OECD TG 203, Danio rerio (reported as Brachydanio rerio), semi-static, freshwater 96 h LC50 = 11.23 mg/L 96 h NOEC ca. 8.64 mg/L   Reliability: 2 (reliable with restriction), GLP
		sup_RA_Short-term toxicity to fish: 91995-81-2_Study_9-1-3_Fish_Stepan_89-017A_1989_OECD 203   OECD TG 203, Leuciscus idus, semi-static, freshwater 96 h LC50 = 5.1 mg/L   Reliability: 2 (reliable with restrictions), GLP
		sup_RA_Short-term toxicity to fish: 91995-81-2_Study_9-1-3_Fish_Stepan_90-011C_1990_OECD 204   OECD TG 204, Danio rerio (reported as Brachydanio rerio), flow-through, freshwater 96 h LC50 = 4.9 mg/L 14 d LC50 = 4.9 mg/L   Reliability: 2 (reliable with restrictions), GLP
Short-term toxicity to aquatic invertebrates	No data, read-across	Key_RA_Short-term toxicity to aquatic invertebrates: 91995-81-2_Study_9-1-1_Daphnia_Cognis_R9800797_1998_EU Method C.2   EUM method C.2, Daphnia magna, static, freshwater 48 h EC50 = 2.23 mg/L 48 h EC0 ca. 0.93 mg/L 48 h EC100 ca. 4.46 mg/L   Reliability: 1 (reliable without restriction), GLP
		sup_RA_Short-term toxicity to aquatic invertebrates.157905-74-3_9.1.1_EBRC 2005_OECD 202   OECD TG 202, Daphnia magna, static, freshwater 24 h EC50 = 7.08 mg/L 48 h EC50 = 6.05 mg/L 48 h NOEC = 0.948 mg/L   Reliability: 2 (reliable with restrictions), GLP
Toxicity to aquatic algae and cyanobacteria	No data, read-across	WoE_RA_Toxicity to aquatic algae and cyanobacteria: 91995-81-2_study_9-1-2_Algae_Evonik_WE-20_83-5pc_1994_OECD 201   OECD TG 201, Desmodesmus subspicatus, freshwater 72 h ErC50 = 3.78 mg/L 72 h ErC10 = 1.53 mg/L   Reliability: 2 (reliable with restrictions), GLP	WoE_RA_Toxicity to aquatic algae and cyanobacteria: 91032-11-0_Study_9-1-2_Algae_Cognis_C0302312-1_2004_OECD 201   OECD TG 201, Desmodesmus subspicatus, freshwater 72 h ErC50 = 2.14 mg/L 72 h NOEC = 0.65 mg/L 72 h ErC10 = 0.68 mg/L   Reliability: 2 (reliable with restrictions), GLP
		WoE_RA_Toxicity to aquatic algae and cyanobacteria.157905-74-3_9.1.2_EBRC 2005_OECD 201   OECD TG 201, Desmodesmus subspicatus, freshwater 72 h ErC50 = 22.3 mg/L (geom. mean meas.) 72 h LOEC = 18.5 mg/L (geom. mean meas.) 72 h NOEC = 9.25 mg/L (geom. mean meas.) 72 h ErC10 = 5.09 mg/L (geom. mean meas.) 72 h ErC10 = 25.77 mg/L (nominal)   Reliability: 2 (reliable with restrictions), GLP
		WoE_RA_Toxicity to aquatic algae and cyanobacteria: 91995-81-2_Study_9-1-2_Algae_KaoST000969_1993a OECD 201   OECD TG 201, Desmodesmus subspicatus, freshwater 72 h NOEC = 1.125 mg/L 72 h ErC10 = 1.26 mg/L   Reliability: 2 (reliable with restrictions), GLP
		WoE_RA_Toxicity to aquatic algae and cyanobacteria: 91995-81-2_Study_9-1-2_Algae_KaoST000970_1993b OECD 201   OECD TG 201, Desmodesmus subspicatus, freshwater 72 h NOEC = 1.125 mg/L 72 h ErC10 = 1.05 mg/L   Reliability: 2 (reliable with restrictions), GLP
Toxicity to microorganisms	No data, read-across	Sup_RA_Toxicity to microorganisms.157905-74-3_9.1.4_EBRC 2005_OECD 209   OECD TG 209, activated sludge of a predominantly domestic sewage freshwater 3 h EC50 > 243 mg/L   Reliability: 1 (reliable without restriction), GLP	Key_RA_Toxicity to microorganisms: 91032_11_0_Study_9-1-4_RespInh_Cognis_R9800416_1998_DIN 38412 part 27   DIN 38412 part 27, Pseudomonas putida, freshwater 30 min EC50 = 60 mg/L 30 min EC0 = 24 mg/L 30 min EC10 = 29.6 mg/L   Reliability: 2 (reliable with restrictions), GLP
		sup_RA_Toxicity to microorganisms: 91995-81-2_Study_9-1-4_RespInh_Cognis_R9800830_1998 DIN 38412 part 27   DIN 38412 part 27, Pseudomonas putida, freshwater 30 min EC50 = 110 mg/L 30 min EC0 = 30 mg/L 30 min EC10 = 35 mg/L   Reliability: 2 (reliable with restrictions), GLP
		sup_RA_Toxicity to microorganisms: 91995-81-2_9-1-4_RespInh_Evonik_WE-20_83-5pc_1993_OECD 209   OECD TG 209, activated sludge, freshwater 3 h EC50 > 250 mg/L   Reliability: 2 (reliable with restrictions), GLP
		sup_RA_Toxicity to microorganisms: 91955_81-2_Study_9-1-4_RespInh_Cognis_R9400293_EQ-C16-18_1994 DIN 38412 part 27   DIN 38412 part 27, Pseudomonas putida, freshwater, 30 min EC0 = 10 mg/L 30 min EC10 = 24 mg/L   Reliability: 2 (reliable with restrictions), GLP

 

 

Toxicity to fish

In a fish embryo test conducted with C18 and C18 unsatd. TEA-Esterquat, the 96 h LC50 to embryonic stages of zebrafish (Danio rerio) was >100 mg a.i./L based on analytically verified nominal concentrations.

 

In a 96-h acute toxicity study conducted according to OECD Guideline 203 (Fish, Acute Toxicity Test), rainbow trouts (Oncorhynchus mykiss) were exposed to partially unsaturated TEA-Esterquat at nominal concentrations of 0 (control), 1.0, 1.6, 2.56, 4.1, 6.55, 10.55 mg/L under semi static conditions. The mean measured concentrations were determined to be 59 % of nominal concentrations. The 96-h LC50 was 1.91 mg/L (based on mean measured concentrations). Sublethal effects such as difficulties with maintenance of balance and unusual behaviour (reduced activity and or orientation to bottom or surface of the test vessels) were observed within the first three hours in the highest test concentration.

 

Toxicity to aquatic invertebrates

In a study conducted according to EU Method C.2 (Acute Toxicity for Daphnia) the 48h-EC50 of the test substance partially unsaturated TEA-Esterquat forDaphnia magnawas determined to be 2.23 mg/L based on estimated concentration (corrected for recovery of 93%).

 

Toxicity to algae

For the long-term effect value 72h-ErC10, relevant studies are considered in a Weight of Evidence (WoE) approach: five valid and comparable studies for the same taxonomic group are available. For the WoE approach, the geometric mean of the five 72h-ErC10 values was calculated to be 1.48 mg/L.

As acute value the lowest effect concentration of all valid tests is used. The test was made with Fully saturated TEA-Esterquat which inhibited significantly the increase of biomass of the algaScenedesmus subspicatusin a study conducted according to OECD Guideline 201 (Alga, Growth Inhibition Test). The 72h-ErC50 is 2.14 mg/L.

 

 

Quality of the experimental data of the analogues:

The available data are adequate and sufficiently reliable to justify the read-across approach.

The aquatic toxicity ofpartially unsaturated TEA-Esterquatwas assessed in reliable (RL1-2) and GLP-compliant studies according to OECD TG 203, 202 and 201. The source substance fully saturated TEA-Esterquat was tested in a reliable (RL2) and GLP compliant study according to OECD TG 201. The toxicity to microorganisms was assessed in reliable (RL1-2) studies according to DIN 38412 part 27 and OECD TG 209.

The test materials used in the respective studies represent the source substance as described in the hypothesis in terms of substance identity and minor constituents.

Overall, the study results are adequate for the purpose of classification and labelling and risk assessment.

 

Conclusion

Based on structural similarities of the target and source substanceas presented above and in more detail in the general justification for read across, it can be concluded that the available data from the source substancespartially unsaturated TEA-Esterquat and fully saturated TEA-Esterquatare also valid for the target substance C18 and C18 unsatd. TEA-Esterquat.

The toxicity to aquatic organisms of the target substance is expected to be in the same range as the source substances as a variability in the fatty acid moiety is not expected to be relevant to the ecotoxicity of the compounds. The substance does not need to be classified for aquatic toxicity.