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Environmental fate & pathways

Biodegradation in soil

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The performance of tests for biodegradation in soil is scientifically unjustified.
REACH Regulation No. 1907/2006, Annex IX, Sect. 9.2.1.3, Col. 2, states as follows:
“9.2.1.3: The study need not to be conducted:
- if the substance is readily biodegradable, or
- if direct and indirect exposure of soil 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. Furthermore, tert-butyl peroxypivalate was considered to be inherently biodegradable, therefore simulation testing for biodegradation in soil was considered not scientifically justified.

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