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Long-term toxicity to fish

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Toxicity to fish of a structural analogue of the registered substance has been investigated in 14 day test according to OECD Test Guideline No. 204. It is recognised that the duration of the OECD TG 204 test is shorter than that currently accepted for investigating long-term toxicity in fish. Waiving of repeat or additional testing is proposed based both on the lack of effects seen in the 14 -day fish study and chronic Daphnia reproduction studies together with considerations regarding adequate justification for the use of vertebrate species for experimental purposes.

In contrast with the experimental value from the tested structural analogue, QSAR estimates for the registered substance predict no effect concentrations to be very low. However, similarly low values are obtained from QSAR estimates of the structural analogue and it is considered that modelling may not be a reasonable predictor for these substances.