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Toxicity to terrestrial arthropods

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Key value for chemical safety assessment

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No experimental data evaluating the toxicity to soil organisms is available fordisulfiram (CAS No. 97-77-8).

The test substance is characterized by an estimated log Koc range of 3.9 – 4.2 indicating a potential for adsorption to soil particles. However, the substance shows a low persistency behaviour in soil based on DT50s below 120 days in soil achieved inseveral simulation studies under aerobic and anaerobic conditions with the analogue substance tetramethylthiuram disulfide (CAS No. 137-26-8). More information in regard of the used read-across approach can be found in the attached analogue justification document in section 13.2 of the IUCLID. 

According to Regulation (EC) No 1272/2008 (CLP) terrestrial toxicity data are not required for Classification & Labelling of substances. Terrestrial data are only required for PNEC soil derivation in the Chemical Safety Assessment for the identification of potential hazards of the substance to the terrestrial environment. As outlined in the Guidance on information requirements and chemical safety assessment, Chapter R.7c, (ECHA, 2017) it is normally not possible to derive a robust PNEC soil from acute aquatic toxicity testing except if clear effects are reported and that is the case fordisulfiram.Therefore, a PNEC soil was calculated based on the equilibrium partitioning method (ECHA, 2017) and further soil toxicity data are not deemed necessary to confirm the PNEC for the soil compartment. 

In conclusion, due to the following reasons no study for terrestrial organisms need to be conducted:

-         Moderate adsorption behaviour expected

-         Not persist in the soil compartment

-         The substance is toxic to aquatic organisms in the same range in all species, therefore it is not expected that an additional study on terrestrial organism will add more relevant information.