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The registration substance Tetrapropenyl succinimido caproic acid (Tetra-PSCA), CAS No. 1424148-99-1 is a structural homologue of Pentapropenyl succinimido caproic acid (Penta-PSCA), CAS No. 1424148-94-6. Both substance are not only structurally very similar they also have a similar Octanol-water partitioning coefficient: Tetra-PSCA Log Kow=3.7 and Penta-PSCA Log Kow=3.6. Assuming a narcotic mode of action the ecotoxicity of both substances should be comparable based on their comparable Log Kow. Both substances have also comparable vapour pressures and Critical Micelle Concentrations. Therefore it is justified to use substance data from Penta-PSCA for read-across to Tetra-PSCA.


Based on the estimated Koc (EUSES 2.1, organic acids) of 162 L/kg sorption to sewage sludge in a STP is low and transfer of the registration substance to agricultural soil is limited. In addition the registration substance has a low aquatic ecotoxicity (see IUCLID Chapter 6.1) and a low ecotoxicity is expected for terrestrial organisms as well.Based in the facts mentioned before, terrestrial ecotoxicity tests are not warranted and it is justified ot calculate the PNEC soil from the PNEC freshwater by the Equilibrium Partitioning Method.