3-[3-(pentanoyloxy)-2,2-bis[(pantanoyloxy)methyl]propoxyl]-2,2-bis[(pentanoyloxy)methyl]propyl pentanoate 3-{3-[(3,5,5-trimethylhexanoyl)oxy]-2,2-bis({[(3,5,5-trimethylhexanoyl)oxy]methyl}propoxy)-2,2-bis({[(3,5,5-trimethylhexanoyl)oxy]methyl}propyl 3,5,5-trimethylhexanoate

Endpoint summary

Additional information

No chronic data are available on the aquatic toxicity of dipentaerythritol ester of nC5/iC9 acids (CAS 647028-25-9) towards fish and invertebrates. In accordance with Article 13 (1) of Regulation (EC) No 1907/2006, "information on intrinsic properties of substances may be generated by means other than tests, provided that the conditions set out in Annex XI are met”. In particular for human toxicity, information shall be generated whenever possible by means other than vertebrate animal tests, which includes the use of information from structurally related substances (grouping or read-across). In order to fulfil the standard information requirements set out in Annex VII - IX, in accordance with Annex XI, 1.5, of Regulation (EC) No 1907/2006, whereby substances may be predicted as similar provided that their physicochemical, toxicological and ecotoxicological properties are likely to be similar or follow a regular pattern as a result of structural similarity, read-across from one structurally related substance was conducted to cover chronic toxicity to aquatic invertebrates.

According to the “Guidance on information requirements and chemical safety assessment Chapter R.7b: Endpoint specific guidance, R.7.8.5.3” (ECHA, 2012), long-term testing of fish should only be conducted if it represents the most sensitive taxonomic group. The Guidance states that if invertebrates are likely to be more sensitive than fish and algae or the relative sensitivity of invertebrates cannot be predicted, long-term testing on Daphnia sp. should be preferred instead of fish. Therefore, no long-term testing on fish was conducted.

Ecotoxicological parameters for the aquatic toxicity of the target substance dipentaerythritol ester of nC5/iC9 acids (CAS647028-25-9) and the source substance dipentaeryhtritol hexa esters of pentanoic, heptanoic and trimethylhexanoic acid (67762-52-1) are presented in the following table:

ID	CAS	Short term toxicity to fish	Long term toxicity to fish	Short term toxicity to aquatic invertebrates	Long term toxicity to aquatic invertebrates	Toxicity to aquatic algae	Toxicity to microorganisms
Target	647028-25-9	Experimental result: LL50 >100 mg/L (96 h)	Data waiving	Experimental result: EL50 >100 mg/L (48 h)	RA: CAS 67762-52-1	Experimental result: EL50 >100 mg/L, NOELR ≥ 100 mg/L (72 h)	Experimental result: EC50 >1000 mg/L (3 h)
Source 7	67762-52-1	--	--	--	Experimental result: EL50 >100 mg/L, NOELR ≥ 100 mg/L (21 d)	--	--

The above mentioned substances are considered to be similar on the basis of structural similarity, physico-chemical properties, and toxicological and ecotoxicological profiles resulting in similar behaviour/activities. The available information is used to predict the same endpoints for both substances.

A detailed analogue approach justification is provided in the technical dossier (see IUCLID section 13).

In accordance with Regulation (EC) No. 1907/2006, Annex XI, 1.5, grouping and read-across, the target substance dipentaerythritol ester of nC5/iC9 acids (CAS 647028-25-9) and the source substance dipentaerythritol hexa esters of pentanoic, heptanoic and trimethylhexanoic acid (CAS 67762-52-1) are not considered to be harmful to aquatic organisms based on the results from short-term and long-term studies with fish, aquatic invertebrates and algae.

Both substances are structurally similar, characterized by the same alcohol component (dipentaerythritol) and similar fatty acid chain lengths, respectively. Based on the structural, physico-chemical, and ecotoxicological similarities, reading across between target and source substance is justified.

Acute toxicity of dipentaerythritol ester of nC5/iC9 acids to aquatic organisms was investigated for different trophic levels (fish, invertebrates, algae and bacteria). No acute toxic or sublethal effects of the substance on the test organisms were observed up to the limit of the water solubility. In the toxicity tests with rainbow trout andDaphnia magna, water solubility was determined to be < 0.00613 mg/L, and in the test with Scenedesmus subspicatus, the water solubility was measured to be < 0.18 mg/L. Also in the toxicity test with activated sludge where the test substance was applied at a nominal concentration of 1000 mg/L, no effects were observed.

Furthermore, the low water solubility of the substance and the high molecular weight and large size of its components (> 800 g/mol) result in a low bioavailability of the substance to aquatic organisms, if at all.

These findings are corroborated by a long-term study on Daphnia magna conducted according to OECD guideline 211 with the source substance dipentaerythritol hexa esters of pentanoic, heptanoic and trimethylhexanoic acid (CAS 67762-52-1), resulting in no toxic or sublethal effects up to the limit of the water solubility.

In conclusion, no effects on aquatic organisms were observed in any of the available short- and long-term studies for the three trophic levels (fish, Daphnia, algae) up to the limit of water solubility.

The available data on the target substance itself and from the suitable source substance allow for an accurate assessment of the ecotoxicity profile of the target substance dipentaerythritol ester of nC5/iC9 acids (CAS647028-25-9).