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Please be aware that this old REACH registration data factsheet is no longer maintained; it remains frozen as of 19th May 2023.

The new ECHA CHEM database has been released by ECHA, and it now contains all REACH registration data. There are more details on the transition of ECHA's published data to ECHA CHEM here.

Diss Factsheets

Ecotoxicological information

Toxicity to birds

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Administrative data

Link to relevant study record(s)

Reference
Endpoint:
long-term toxicity to birds
Data waiving:
other justification
Justification for data waiving:
other:

Description of key information

Waiver: Studies on effects on birds do not need to be conducted secondary poisoning is not of concern. PACM (4,4’-methylenebis(cyclohexylamine) has a log Kow of 2.03 and a BCF of 10.15; each value is below the threshold of concern for secondary poisoning. 

Key value for chemical safety assessment

Additional information

Evaluation of upper trophic level exposures (secondary poisoning) is not of concern for PACM (4,4'-methylenebis(cyclohexylamine)). "Secondary poisoning" refers to the toxic effects in the higher members of a food chain that result from ingestion of organisms from lower trophic levels that contain accumulated substances (and/or related metabolites).  To be evaluated for secondary poisoning, the chemical must have a log Kow ≥ 3 or a BCF ≥ 100; and no mitigating property such as biodegradability or hydrolysis (half-life less than 12 hours).  Since the log Kow for PACM is 2.03 (based on the measured value from the OECD Guideline 107 shake flask method test by BASF, 1988), and the BCF for PACM is : BCF < 60 (read across to the source substance DMDC CAS: 6864-37-5)supported by a calculated BCF of  3.72 (Catalogic v.5.14.1.5, BCF base-line model v.04.11) then neither of the first two screening criteria are satisfied for PACM (Section R.16.4.3.5, Chapter R.16, Environmental exposure estimation, Guidance on information requirements and chemical safety assessment, ECHA, May 2008).


Therefore, PACM may be waived with respect to the evaluation of secondary poisoning and the derivation of a PNECoral for wildlife exposures, including the food chain exposures of birds (Section R.10.8.1, Chapter R.10, Characterisation of dose[concentration]-response for environment, of Guidance on information requirements and chemical safety assessment, ECHA, May 2008).