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COMMENT:

Validity of ecotoxicity studies with solvent in which the test concentrations exceed the limit of solubility by several orders of magnitude.

Several ecotoxicity tests with structural analogue dodecyl methacrylate have been performed at concentrations orders of magnitude above the limit of solubility. In those cases, rapid stirring or solvent or both have been used to disperse the test material. In those studies, no attempt has been made to determine whether the test material was dissolved and only in one study it was acknowledged that the test material was present in the form of an emulsion.

Based on the measured water solubility of dodecyl methacrylate (< 1 µg/L) it can be assumed, that in those cases the test material was present almost entirely as small, undissolved droplets forming an emulsion. That has the consequence that the 'concentration' no longer determines the dose in the test organism but the stochastical, individual contact of the test organism with droplets of the test material and the kinetics of the subsequent absorption of the droplet by the test organism. Test results obtained this way are artefacts and not representative. They cannot be used establishing a concentration-effect relationship.

Therefore, with the exception of some fish studies, test results have only been used when the test was performed without solvent and the nominal test concentration was not higher than approximately ten-fold above the solubility of dodecyl methacrylate in water.

Considering the three trophic levels, fish, aquatic invertebrates and algae, the test results available clearly demonstrate the absence of ecotoxicity within the range of water solubility of the long-chain alkyl methacrylate esters.

There is no evidence for toxicity to microorganisms.