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Ecotoxicological information

Toxicity to terrestrial plants

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Reference
Endpoint:
toxicity to terrestrial plants: short-term
Data waiving:
exposure considerations
Justification for data waiving:
the study does not need to be conducted because direct and indirect exposure of the soil compartment is unlikely
Justification for type of information:
The performance of a test for toxicity to terrestrial plants was considered not scientifically justified. REACH Regulation No. 1907/2006, Annex IX, Sect. 9.4, Col. 2, states as follows: “9.4: These studies need not to be conducted if direct and indirect exposure of the soil compartment is unlikely.”
Direct and indirect exposure of the test item to soil is highly unlikely. Due to the unstable nature of organic peroxides, it can be assumed that upon contact with soil and organic matter, the test item undergoes rapid degradation resulting in the formation of respective alcohols and acids. Thus, toxicity to soil macro-organisms was considered not scientifically justified. This is confirmed by the following argumentation: Chemicals can reach the soil via several routes:

1. Application of sewage sludge in agriculture.
Organic peroxides, when released into the sewage of a plant production or a downstream user’s plant, are treated with other substances in dedicated sewage treatment plants. The activated sludge stemmed from these sewage treatment plants are then extracted and treated as chemical waste. From the production plant, the release of organic peroxide into the sewage is very limited, not to say completely negligible. The waste water from production plant can be treated on site (at least a physical/chemical treatment, which will neutralize potential residual organic peroxide), which is usually followed by a biological treatment. So it is expected that organic peroxides are not present in sludge. Furthermore, application of sludge to soil is excluded for industrial uses.
Regarding the rest of the lifecycle, organic peroxides are mainly used as cross-linking agent/polymerization initiator for the production of resins/rubbers/polymers. Based upon the fact that organic peroxides are totally consumed during the process (>99%, which is confirmed by the release factor to sewage for curing agents from ESD n°3), the soil is not exposed to organic peroxides via use of sludge.
As a consequence, soil is not exposed to organic peroxides via the application of sewage sludge in agriculture.

2. Direct application of chemicals. Based on the uses inventoried for organic peroxides there is no direct application of these substances on the soil compartment. Indeed, all uses are within industrial settings.

3. Deposition from the atmosphere.
Deposition from the atmospheric compartment involves volatilization, vaporization or direct release of a considered substance into the atmosphere. Due to their dangerous intrinsic physico-chemical properties, organic peroxides are carefully handled in (semi-)closed systems and their transport, production and use are ruled by several regulations. This is also in line with the release factor to atmosphere for curing agents from ESD n°3. Based on organic peroxides uses, deposition on soil from the atmosphere is also not expected.

Based on these arguments no test is proposed for the soil compartment.

Description of key information

The performance of a test for toxicity to terrestrial plants was considered not scientifically justified. REACH Regulation (EC) No 1907/2006, Annex IX, Sect. 9.4, Col. 2, states as follows: “9.4: These studies need not to be conducted if direct and indirect exposure of the soil compartment is unlikely.” Direct and indirect exposure of the test item ditetradecyl peroxydicarbonate to soil is highly unlikely. The test substance is practically insoluble in water and readily biodegradable.  In addition, low exposure is guaranteed, as no sludge application from STP on soil will be done and aerial deposition is negligible. Thus, toxicity to terrestrial plants was considered not scientifically justified.

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