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Long-term toxicity to fish

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Endpoint:
adult fish: sub(lethal) effects
Type of information:
(Q)SAR
Adequacy of study:
supporting study
Study period:
2017
Reliability:
2 (reliable with restrictions)
Rationale for reliability incl. deficiencies:
results derived from a valid (Q)SAR model and falling into its applicability domain, with adequate and reliable documentation / justification
Justification for type of information:
Please refer to attached QMRF and QPRF Documents.
Qualifier:
according to guideline
Guideline:
other:
Version / remarks:
REACH guidance on QSAR R.6
Principles of method if other than guideline:
Calculation of Long-Term toxicity in fish. Software used: ECOSAR 1.11 (EPISUITE) for chemical class "Peroxyester" and "Neutral Organic SAR (Baseline Toxicity)"
GLP compliance:
no
Specific details on test material used for the study:
SMILES: CC(C)(C)OOC(=O)CC(C)CC(C)(C)C
Analytical monitoring:
not required
Test organisms (species):
other: fish
Water media type:
freshwater
Total exposure duration:
30 d
Remarks on exposure duration:
chronic exposure
Key result
Effect conc.:
0.117 mg/L
Remarks on result:
ChV (chronic value, QSAR)
Remarks:
The substance is within the applicability domain of the model. ECOSAR class "Peroxyester".
Key result
Effect conc.:
0.168 mg/L
Remarks on result:
ChV (chronic value, QSAR)
Remarks:
The substance is within the applicability domain of the model. ECOSAR class "Neutral Organic SAR (Baseline Toxicity)".

ECOSAR v1.11 Class-specific Estimations

ECOSAR Class

Organism

Duration

End Pt

Predicted mg/L (ppm)

 

 

 

 

 

Peroxy Esters

Fish

96-hr

LC50

1.181

Peroxy Esters

Daphnid

48-hr

LC50

1.669

Peroxy Esters

Green Algae

96-hr

EC50

0.134

Peroxy Esters

Fish

 

ChV

0.117 !

Peroxy Esters

Daphnid

 

ChV

0.236

Peroxy Esters

Green Algae

 

ChV

0.039

 

 

! = exclamation designates: The toxicity value was estimated through application of acute-to-chronic ratios per methods outlined in the ECOSAR Methodology Document provided in the ECOSAR Help Menu.

Validity criteria fulfilled:
yes
Conclusions:
Using ECOSAR v1.11 the long-term toxicity ChV value for fish was calculated to be 0.117 mg/L. The substance is within the applicability domain of the model.
Executive summary:

The long-term toxicity in fish was calculated using ECOSARv 1.11 as part of EPISuite v4.11 from US Environmental Protection Agency.

The adequacy of a prediction depends on the following conditions:

a) the (Q)SAR model is scientifically valid: the scientific validity is established according to the OECD principles for (Q)SAR validation;

b) the (Q)SAR model is applicable to the query chemical: a (Q)SAR is applicable if the query chemical falls within the defined applicability domain of the model;

c) the (Q)SAR result is reliable: a valid (Q)SAR that is applied to a chemical falling within its applicability domain provides a reliable result;

d) the (Q)SAR model is relevant for the regulatory purpose.

 

For assessment and justification of these 4 requirements the QMRF and QPRF files were developed and attached to this study record.

 

Description of the prediction Model

The prediction model was descriped using the harmonised template for summarising and reporting key information on (Q)SAR models. For more details please refer to the attached QSAR Model Reporting Format (QMRF) file. 

 

Assessment of estimation domain

The assessment of the estimation domain was documented in the QSAR Prediction Reporting Format file (QPRF). Please refer to the attached document for the details of the prediction and the assessment of the estimation domain.

Endpoint:
fish early-life stage toxicity
Data waiving:
study scientifically not necessary / other information available
Justification for data waiving:
other:
Justification for type of information:
The performance of a test for long-term toxicity to fish was considered not scientifically justified. REACH Regulation No. 1907/2006, Annex IX, Sect. 9.1., Col. 2, states as follows: “9.1.: Long-term toxicity testing shall be proposed by the registrant if the chemical safety assessment according to Annex I indicates the need to investigate further the effects on aquatic organisms.”

The chemical safety assessment does not indicate the need to further investigate the effects on aquatic organisms for the following reasons:

Exposure and stability considerations:
TBPIN is not stable in the aquatic environment. Due to the unstable nature of organic peroxides, it can be assumed that upon contact with water and organic matter, the test item undergoes rapid degradation resulting in the formation of respective alcohols and acids. Hydrolysis half-life of TBPIN was determined to be 213.2 hrs (ca. 9 days) at 12 °C, reflecting the worst case half-life determined with TBPIN in this study. Therefore, an abiotic degradation of the test item in the environment is expected.
In addition, the test item was found to be readily biodegradable.

Based on the points outline above, long-term toxicity testing is considered scientifically not justified since the test item is not stable in the aquatic environment.

Further, Environmental Risk Assessment revealed safe use of the substance throughout its whole life cycle due to very low exposure of the water compartment which is especially based on the following facts:
Organic peroxides, when released into the sewage of a plant production or a downstream user’s plant, are treated with other substances in dedicated sewage treatment plants. The activated sludge stemmed from these sewage treatment plants are then extracted and treated as chemical waste. From the production plant, the release of organic peroxide into the sewage is very limited, not to say completely negligible. The waste water from production plant can be treated on site (at least a physical/chemical treatment, which will neutralize potential residual organic peroxide), which is usually followed by a biological treatment. Regarding the rest of the lifecycle, organic peroxides are mainly used as cross-linking agent/polymerization initiator for the production of resins/rubbers/polymers. Based upon the fact that organic peroxides are totally consumed during the process (>99%, which is confirmed by the release factor to sewage for curing agents from ESD n°3), the surface water is not exposed to organic peroxides via the waste water system. As a consequence, the surface water and with this aquatic organisms are not considered to be significantly exposed by the test item.

Furthermore, based on available data on toxicity to aquatic organisms, algae was considered to be the most sensitive species with the test item. Therefore, and for animal welfare reasons, long-term toxicity testing with fish is considered to not improve the chemical safety assessment. This assumption is further supported by QSAR calculations. Chronic toxicity effect concentrations were estimated with ECOSAR v1.11 for algae, daphnia and fish (For more details please refer to IUCLID Section 6.1.2). The test item was within the applicability domain of the model thus reliability of the results is not affected. ChV values were estimated to be 0.117, 0.236 and 0.039 mg/L for fish, daphnia, and algae, respectively, being in well accordance with experimental data for long-term toxicity in algae and daphnia. Based on calculated values, again algae was predicted to be the most sensitive species.

In summary, long-term toxicity testing in a vertebrate species is considered not scientifically justified according to REACH Regulation No. 1907/2006, Annex IX, Sect. 9.1., Col. 2 and not in line with animal welfare.

Description of key information

The performance of a test for long-term toxicity to fish was considered not scientifically justified. REACH Regulation No. 1907/2006, Annex IX, Sect. 9.1., Col. 2, states as follows: “9.1.: Long-term toxicity testing shall be proposed by the registrant if the chemical safety assessment according to Annex I indicates the need to investigate further the effects on aquatic organisms.”  The chemical safety assessment does not indicate the need to further investigate the toxicity to aquatic organisms. This is based on exposure and stability considerations of the test item and considering that algae is the most sensitive species and further testing in a vertebrate species would not improve the chemical safety assessment.

Key value for chemical safety assessment

Additional information