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According to chapter R16 of the “Guidance on information requirements and chemical safety assessment” (ECHA, 2008), substances that may pose a risk on birds may be assessed on the basis of mammalian toxicity data. The bioaccumulation potential is low and thus the test substance is considered to cause little or no hazard to predators. Therefore, and due to animal welfare reasons, a long term toxicity study on birds is scientifically unjustified.