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The use of the substance on workplaces is controlled and widespread exposure to the environment is not expected. In service life, the substance is embedded in polymer matrices from which there is no release of substance "reaction mass of calcium hydrogen phosphonate and dialuminium tricalcium hexaoxide". Soil exposure to the substance is unlikely. In addition, substance "reaction mass of calcium hydrogen phosphonate and dialuminium tricalcium hexaoxide" is an inorganic, sparingly soluble crystalline solid of lamellar clay mineral (hydrocalumite) -like substance. Although, if released to the environment, the substance most probably will end up in the sediment or soil compartment by sedimentation comparable to natural clay minerals, this fate is not expected to result in any negative environmental impact (c. f. G. E. Batley and M. J. McLaughlin CSIRO Niche Manufacturing Flagship Report, Fate of Manufactured Nanomaterials in the Australian Environment, prepared for the Australian Department of the Environment, Water, Heritage and the Arts (March 2010), available via Internet https://www.environment.gov.au/system/files/pages/371475a0-2195-496d-91b2-0a33f9342a6d/files/manufactured-nanomaterials.pdf).

In accordance with REACH Regulation, Annex IXff., 9.4, column 2 as well as Annex XI, 1., the performance of terrestrial toxicity studies is not justified due to exposure as well as toxicological considerations.

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