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Ecotoxicological information

Short-term toxicity to fish

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Administrative data

Link to relevant study record(s)

short-term toxicity to fish
Type of information:
read-across from supporting substance (structural analogue or surrogate)
Adequacy of study:
key study
Justification for type of information:
See Read-across justification attached
Reason / purpose for cross-reference:
read-across source
Reason / purpose for cross-reference:
read-across source
96 h
Dose descriptor:
Effect conc.:
>= 10 mg/L
Basis for effect:
mortality (fish)
Remarks on result:
The fish is expected to be less sensitive species, this endpoint is not useful for the CLP classification and for the risk assessment.

Description of key information

No short-term study is available for this endpoint. Nevertheless, reliable studies performed according to the OECD Guideline 203 under GLP are available on the analogue, THPC-urea monomer (Tetrakis[hydroxymethyl] phosphonium chloride, oligomeric reaction products with urea) and on one component of the registered reaction mass, THPS (Tetrakis[hydroxymethyl] phosphonium sulphate). The 96h-EC50 for the THPS was found to be 71 mg/L and the 96h-EC50 for the THPC-urea monomer was found to be above 100 mg/L. 

According to the results of the short term studies on fish, invertebrates and algae performed with THPS and with THPC-urea monomer, it appears that the fish is the less sensitive trophic level for these both analogues.

In addition according to the results of short term studies performed on invertebrates and algae with the THPS-urea monomer, it appears that THPS-urea monomer has similar range of toxicity toward invertebrates and algae than both analogues THPS and THPC-urea monomer. Therefore, it could be considered and concluded that the THPS is the most toxic constituent of the registered reaction mass and that the toxicity of the reaction mass towards daphnids is managed by the THPS.

For these reasons, it can be expect that THPS-urea monomer will have the same range of toxicity than both analogues toward fish. Thus the acute toxicity to fish study is considered of low importance in this dossier, since the algae model has been shown to be the most sensitive model for all this chemical family of THP-Urea or THPS. Therefore, it seemed reasonable not to perform such in vivo fish study since this endpoint is not useful for the CLP classification and for the risk assessment and regarding also the limitation use of vertebrae species (3R rules).


In conclusion and according to the section 1.2 of the annex XI, the short term study on fish does not need to be conducted.

Key value for chemical safety assessment

Fresh water fish

Fresh water fish
Effect concentration:
100 mg/L

Additional information