Registration Dossier

Environmental fate & pathways

Endpoint summary

Administrative data

Description of key information

Additional information

Data on stability in the environment are not available. Hydrolysis testing is not considered to be technically feasible or appropriate for this UVCB substance. Currently, no analytical method exists for accurate quantification of this substance. As hydrolysis testing requires analytical methods with high levels of sensitivity and accuracy, it is not feasible to conduct testing for this endpoint.

Fatty acids, tall-oil, reaction products with bisphenol A, epichlorohydrin, glycidyl tolyl ether and triethylenetetramine is considered to be a UVCB reaction product of four starting materials. Testing of the reaction product in ready biodegradation and hydrolysis tests is not scientifically appropriate and therefore QSAR has been prepared to identify and recommend a suitable but conservative DT50 hydrolysis endpoint for use in hazard assessment and risk characterisation.

The percentage biodegradation of TOFA_TETA_PAA_BADGE_CGE_Adduct reached a maximum of 9% over the course of the 28 day incubation and therefore failed to meet the requirements for ready biodegradability. Thus TOFA_TETA_PAA_BADGE_CGE_Adduct cannot be classified as readily biodegradable.

As the substance is not used under conditions with potential exposure to water, sediment or soil and due to its very low vapour pressure, making indirect deposition via air unlikely and negligible, further tests on degradation in sediment or soil are not required. In accordance with column 2 of REACH Annex IX, the aquatic bioaccumulation study (required in section 9.3.2) does not need to be conducted as the substance has a low log Kow (3.38 as weighted average) and due to its molecular weight (average of 755 g/mol) is unlikely to cross biological membranes to bioaccumulate in fish. Based on the physicochemical properties of the substance (log POW of 3.38) a moderate potential for adsorption to sediment and soil is expected. However, based on the LogPOW a KOC value was calculated according to Sbljic and Güsten, 1995, using the model for Amides (logKOC = 0.33 * log KOW + 1.25), resulting in a KOC of 232 (logKOC = 2.37), indicative of moderate absorption to soil.