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Due to the rapid hydrolysis of the substance, the chemical safely assessment is based on the silanol hydrolysis product 3-chloropropyl(methyl)silanediol.

 

Testing for toxicity to terrestrial organisms is not considered necessary because:

In accordance with Column 2 of REACH Annex IX, there is no need to further investigate the effects of this substance in a long or short-term terrestrial toxicity to invertebrates or higher plants study because, as indicated in guidance R.7.11.6 (ECHA 2016), the quantitative chemical safety assessment (conducted according to Annex I of REACH) indicates that the Risk Characterisation Ratio is below 1, and therefore the risk is already adequately controlled and further testing is not justifiable.

 

The silanol hydrolysis product is not readily biodegradable but has low potential for bioaccumulation and low bioavailability (based on log Kow <3 (0.8); partitioning to the terrestrial compartment is expected to be minimal. No toxicity was observed in aquatic tests conducted at high concentrations, and there is no reason to expect any specific mechanism of toxicity beyond narcosis. Therefore, the occurrence of more severe toxic effects in the terrestrial compartment that were not expressed in the aquatic studies would be considered unlikely.

 

The soil hazard category 1 (ECHA 2014, guidance part R7(c) Table R.7.11—2) has been derived for the substance. In accordance with the screening assessment for soil hazard category 1 substances, a PNECsoil has been calculated from the aquatic data on the basis of the equilibrium partitioning method. The PNEC calculated by Equilibrium Partitioning has been derived for the purpose of chemical safety assessment and the risk characterisation ratios are below 1.

 

Overall it is concluded that the risk characterisation conclusion is sufficiently conservative in respect of any uncertainties and therefore further in vivo testing is not considered necessary.

 

Details on how the PNEC and the risk characterisation ratio have been derived can be found in IUCLID Section 6.0 and Chapters 9 and 10 of the Chemical Safety Report, respectively.