Registration Dossier

Administrative data

Workers - Hazard via inhalation route

Systemic effects

Long term exposure
Hazard assessment conclusion:
no hazard identified
Acute/short term exposure
Hazard assessment conclusion:
no hazard identified
DNEL related information

Local effects

Long term exposure
Hazard assessment conclusion:
DNEL (Derived No Effect Level)
Value:
0.824 mg/m³
Most sensitive endpoint:
repeated dose toxicity
DNEL related information
DNEL derivation method:
ECHA REACH Guidance
Overall assessment factor (AF):
12.5
Dose descriptor:
NOAEC
Value:
10.3 mg/m³
AF for dose response relationship:
1
Justification:
The dose response relationship is considered unremarkable, therefore no additional factor is used.
AF for differences in duration of exposure:
1
Justification:
Local effects are independent from time.
AF for interspecies differences (allometric scaling):
1
Justification:
Local effects are independent from metabolic rate.
AF for other interspecies differences:
2.5
Justification:
Recommended AF for other interspecies differences.
AF for intraspecies differences:
5
Justification:
The default value for the relatively homogenous group "worker" is used.
AF for the quality of the whole database:
1
Justification:
The approach used for DNEL derivation is conservative. No further assessment factors are required.
AF for remaining uncertainties:
1
Justification:
The approach used for DNEL derivation is conservative. No further assessment factors are required.
Acute/short term exposure
Hazard assessment conclusion:
no hazard identified
DNEL related information

Workers - Hazard via dermal route

Systemic effects

Long term exposure
Hazard assessment conclusion:
DNEL (Derived No Effect Level)
Value:
10.3 mg/kg bw/day
Most sensitive endpoint:
repeated dose toxicity
Route of original study:
Oral
DNEL related information
DNEL derivation method:
ECHA REACH Guidance
Overall assessment factor (AF):
5
Dose descriptor starting point:
NOAEL
Value:
103.31 mg/kg bw/day
Modified dose descriptor starting point:
NOAEL
Value:
1 033.1 mg/kg bw/day
Explanation for the modification of the dose descriptor starting point:

There are no relevant experimental data on repeated dermal exposure. A low dermal vs oral absorption value can be expected due to the physico- chemical properties. Therefore, dermal absorption is anticipated to be 10 % of oral absorption.

AF for dose response relationship:
1
Justification:
The dose response relationship is considered unremarkable, therefore no additional factor is used.
AF for differences in duration of exposure:
2
Justification:
The default extrapolation factor for exposure duration is used: subchronic (starting point) to chronic (end point).
AF for interspecies differences (allometric scaling):
4
Justification:
The default allometric scaling factor for the differences between rats and humans is used.
AF for other interspecies differences:
2.5
Justification:
Recommended AF for other interspecies differences.
AF for intraspecies differences:
5
Justification:
The default value for the relatively homogenous group "worker" is used.
AF for the quality of the whole database:
1
Justification:
The quality of the whole data base is considered to be sufficient and uncritical.
AF for remaining uncertainties:
1
Justification:
The approach used for DNEL derivation is conservative. No further assessment factors are required.
Acute/short term exposure
Hazard assessment conclusion:
no hazard identified
DNEL related information

Local effects

Long term exposure
Hazard assessment conclusion:
high hazard (no threshold derived)
Acute/short term exposure
Hazard assessment conclusion:
high hazard (no threshold derived)

Workers - Hazard for the eyes

Local effects

Hazard assessment conclusion:
low hazard (no threshold derived)

Additional information - workers

General

DNEL derivation for the substance is performed under consideration of the recommendations of ECHA REACH Guidance (2010). In view of the data used for evaluation, the "quality of whole database factors" and the “factor for remaining uncertainties“ is considered to amount to a value of 1.

Short-term, local DNEL

The skin and eye irritation and sensitization potential of the test item was assessed in several in vivo studies. The test item demonstrated to be irritating to the eyes and skin and sensiting to the skin. Thus a qualitative risk assessment was performed. It is further classified as irritating and sensitising to the respiratory tract. The short-term local inhalation DNEL is however sufficiently covered by the calculated long-term local inhalation DNEL (please see below).

Short-term, systemic DNEL

The guidance on dose/concentration response regarding human health (section R.8.1.2.5 of chapter R.8 of the Guidance on Information Requirements and Chemical Safety Assessment) indicates that short-term DNELs do not need to be calculated for substances that are not classified for a short-term toxicity hazard according to Regulation (EC) No 1272/2008 (CLP). As this substance is not classified for short-term systemic effects, no short-term systemic DNELs need to be calculated.

Long-term, local DNEL

Inhalation exposure

A sub chronic inhalation toxicity study revealed that the test substance has irritating properties in the respiratory tract. Based on these findings a long-term inhalation DNEL for local effects is derived. The NOAEC of 10.3 mg/m³ is identified as the relevant dose descriptor and starting point.

Assessment factors:

Dose response differences: 1

Differences in exposure duration: 1

Interspecies differences (allometric scaling): 1

Other interspecies differences: 2.5

Intraspecies differences (worker): 5

Taking the above mentioned assessment factors into account, the following worker long-term inhalation DNEL for local effects is:

10.3 mg/m³ / (1 x 1 x 2.5 x 5)

= 0.824 mg/m³

Dermal exposure

The skin and eye irritation and sensitization potential of the test item was assessed in several in vivo studies. The test item demonstrated to be irritating to the eyes, skin and the respiratory tract. It is further classified as respiratory and skin sensitiser. Thus, a qualitative risk assessment was performed.

Long-term, systemic DNEL

Inhalation exposure

In the subchronic repeated dose toxicity study, APS caused primary local toxicity effects. A similar effect is also anticipated for KPS. All observed systemic effects were of secondary nature. Therefore no DNEL, systemic, long-term was derived for inhalation. The systemic exposure is sufficiently covered by the long-term local DNEL.

Dermal exposure

In order to derive the worker DNEL (long-term dermal exposure), the NOAEL assessed in the key repeated dose oral toxicity study (103.31 mg/kg bw/d) is identified as the relevant dose descriptor.

Modification into a correct starting point:

Correction for dermal absorption rates of the test substance (based on Guidance on information requirements and chemical safety assessment, Chapter R 7.12): Dermal absorption is supposed to be low for several reasons: 1. Very high water solubility (52.77 g/L). 2. A log Kow of -1. With a low log Pow (below 0) and a water solubility above 10 g/L the substance is to hydrophilic to cross the lipid rich environment of the stratum corneum. Thus, dermal uptake is anticipated to be low. In addition, the results of the acute dermal toxicity support a low absorption via dermal route. Therefore, dermal absorption can be reasonably estimated to be lower than 10%.

In conclusion, dermal NOAEL = oral NOAEL x 100/10 =

103.31 x (100/10) = 1033.1 mg/kg bw/d.

Assessment factors:

Dose response differences: 1

Differences in exposure duration: 2

Interspecies differences (allometric scaling): 4

Remaining interspecies differences: 2.5

Intraspecies differences (worker): 5

Taking the above mentioned assessment factors into account, the following worker long- term dermal DNEL for systemic effects is:

1033.1 mg/kg bw/d / (1 x 2 x 4 x 2.5 x 5) = 1033.1 mg/kg bw/day / 100

= 10.3 mg/kg bw/day

 

References

- ECHA (2010). Guidance on information requirements and chemical safety assessment. Chapter R.8: Characterisation of dose [concentration]-response for human health. Version 2. ECHA-2010 -G-19 –EN.

- ECHA (2016). Guidance on Information Requirements and Chemical Safety Assessment Part E: Risk Characterisation. Version 3. ECHA-2016-G-04-EN

 

General Population - Hazard via inhalation route

Systemic effects

Long term exposure
Hazard assessment conclusion:
no hazard identified
Acute/short term exposure
Hazard assessment conclusion:
no hazard identified
DNEL related information

Local effects

Long term exposure
Hazard assessment conclusion:
DNEL (Derived No Effect Level)
Value:
0.421 mg/m³
Most sensitive endpoint:
repeated dose toxicity
DNEL related information
DNEL derivation method:
ECHA REACH Guidance
Overall assessment factor (AF):
25
Dose descriptor:
NOAEC
Value:
10.3 mg/m³
AF for dose response relationship:
1
Justification:
The dose response relationship is considered unremarkable, therefore no additional factor is used.
AF for differences in duration of exposure:
1
Justification:
Local effects are independent from time.
AF for interspecies differences (allometric scaling):
1
Justification:
Recommended AF for other interspecies differences.
AF for other interspecies differences:
10
Justification:
The default value for the more heterogenous group "general population" is used.
AF for intraspecies differences:
1
Justification:
The quality of the whole data base is considered to be sufficient and uncritical.
AF for the quality of the whole database:
1
Justification:
The approach used for DNEL derivation is conservative. No further assessment factors are required.
AF for remaining uncertainties:
1
Justification:
The approach used for DNEL derivation is conservative. No further assessment factors are required.
Acute/short term exposure
Hazard assessment conclusion:
no hazard identified
DNEL related information

General Population - Hazard via dermal route

Systemic effects

Long term exposure
Hazard assessment conclusion:
DNEL (Derived No Effect Level)
Value:
5.2 mg/kg bw/day
Most sensitive endpoint:
repeated dose toxicity
Route of original study:
Oral
DNEL related information
DNEL derivation method:
ECHA REACH Guidance
Overall assessment factor (AF):
200
Dose descriptor starting point:
NOAEL
Value:
103.31 mg/kg bw/day
Modified dose descriptor starting point:
NOAEL
Value:
1 033.1 mg/kg bw/day
Explanation for the modification of the dose descriptor starting point:

There are no relevant experimental data on repeated dermal exposure. A low dermal vs oral absorption value can be expected due to the physico- chemical properties. Therefore, dermal absorption is anticipated to be 10 % of oral absorption.

AF for dose response relationship:
1
Justification:
The dose response relationship is considered unremarkable, therefore no additional factor is used.
AF for differences in duration of exposure:
2
Justification:
The default extrapolation factor for exposure duration is used: subchronic (starting point) to chronic (end point).
AF for interspecies differences (allometric scaling):
4
Justification:
The default allometric scaling factor for the differences between rats and humans is used.
AF for other interspecies differences:
2.5
Justification:
Recommended AF for other interspecies differences.
AF for intraspecies differences:
10
Justification:
The default value for the more heterogenous group "general population" is used.
AF for the quality of the whole database:
1
Justification:
The quality of the whole data base is considered to be sufficient and uncritical.
AF for remaining uncertainties:
1
Justification:
The approach used for DNEL derivation is conservative. No further assessment factors are required.
Acute/short term exposure
Hazard assessment conclusion:
no hazard identified
DNEL related information

Local effects

Long term exposure
Hazard assessment conclusion:
high hazard (no threshold derived)
Acute/short term exposure
Hazard assessment conclusion:
high hazard (no threshold derived)

General Population - Hazard via oral route

Systemic effects

Long term exposure
Hazard assessment conclusion:
DNEL (Derived No Effect Level)
Value:
0.52 mg/kg bw/day
Most sensitive endpoint:
repeated dose toxicity
Route of original study:
Oral
DNEL related information
DNEL derivation method:
ECHA REACH Guidance
Overall assessment factor (AF):
200
Dose descriptor starting point:
NOAEL
Value:
103.31 mg/kg bw/day
AF for dose response relationship:
1
Justification:
The dose response relationship is considered unremarkable, therefore no additional factor is used.
AF for differences in duration of exposure:
2
Justification:
The default extrapolation factor for exposure duration is used: subchronic (starting point) to chronic (end point).
AF for interspecies differences (allometric scaling):
4
Justification:
The default allometric scaling factor for the differences between rats and humans is used.
AF for other interspecies differences:
2.5
Justification:
Recommended AF for other interspecies differences.
AF for intraspecies differences:
10
Justification:
The default value for the more heterogenous group "general population" is used.
AF for the quality of the whole database:
1
Justification:
The quality of the whole data base is considered to be sufficient and uncritical.
AF for remaining uncertainties:
1
Justification:
The approach used for DNEL derivation is conservative. No further assessment factors are required.
Acute/short term exposure
Hazard assessment conclusion:
DNEL (Derived No Effect Level)
Value:
1.55 mg/kg bw/day
Most sensitive endpoint:
repeated dose toxicity
DNEL related information
DNEL derivation method:
ECHA REACH Guidance
Overall assessment factor (AF):
0.33
DNEL extrapolated from long term DNEL

General Population - Hazard for the eyes

Local effects

Hazard assessment conclusion:
low hazard (no threshold derived)

Additional information - General Population

General

DNEL derivation for the substance is performed under consideration of the recommendations of ECHA REACH Guidance (2010). In view of the data used for evaluation, the "quality of whole database factors" and the “factor for remaining uncertainties“ is considered to amount to a value of 1.

Short-term, local DNEL

The skin and eye irritation and sensitization potential of the test item was assessed in several in vivo studies. The test item demonstrated to be irritating to the eyes and skin and sensiting to the skin. Thus a qualitative risk assessment was performed. It is further classified as irritating and sensitising to the respiratory tract. The short-term local inhalation DNEL is however sufficiently covered by the calculated long-term local inhalation DNEL (please see below).

Short-term, systemic DNEL

The guidance on dose/concentration response regarding human health (section R.8.1.2.5 of chapter R.8 of the Guidance on Information Requirements and Chemical Safety Assessment) indicates that acute DNELs do not need to be calculated for substances that are not classified for an acute toxicity hazard according to Regulation (EC) No 1272/2008 (CLP). As this substance is not classified for short-term inhalative or dermal systemic effects, no acute systemic DNELs need to be calculated for those exposure routes.

The substance is classified as harmful if swallowed (H302). Thus, short term DNEL is derived for the general population taking the long-term DNEL as basis. A long-term oral DNEL of 0.52 mg/kg bw/d was determined (please see below). Thus, a short-term DNEL of 1.55 mg/kg bw/d was determined.

Long-term, local DNEL

Inhalation exposure

A sub chronic inhalation toxicity study revealed that the test substance has irritating properties in the respiratory tract. Based on these findings a long-term inhalation DNEL for local effects is derived. The NOAEC of 10.3 mg/m³ is identified as the relevant dose descriptor and starting point.

Assessment factors:

Dose response differences: 1

Differences in exposure duration: 1

Interspecies differences (allometric scaling): 1

Other interspecies differences: 2.5

Intraspecies differences (general population): 10

Taking the above mentioned assessment factors into account, the following worker long-term inhalation DNEL for local effects is:

10.3 mg/m³ / (1 x 1 x 2.5 x 10) =10.3 mg/m³ / 25

= 0.421 mg/m³

Dermal exposure

The skin irritation and sensitization potential of the test item was assessed in several in vivo studies. The test item demonstrated to be irritating to skin. It is further classified as skin sensitiser. Thus, a qualitative risk assessment was performed.

Long-term, systemic DNEL

Inhalation exposure

In the subchronic repeated dose toxicity study, APS caused primary local toxicity effects. All observed systemic effects were of secondary nature. A similar effect is also anticipated for KPS. Therefore no DNEL, systemic, long-term was derived for inhalation. The systemic exposure is sufficiently covered by the long-term local DNEL.

Dermal exposure

In order to derive the general population DNEL (long-term dermal exposure), the NOAEL assessed in the 90 d repeated dose oral toxicity study (103.31 mg/kg bw/d) is identified as the relevant dose descriptor.

Modification into a correct starting point:

Correction for dermal absorption rates of the test substance (based on Guidance on information requirements and chemical safety assessment, Chapter R 7.12): Dermal absorption is supposed to be low for several reasons: 1. Very high water solubility (55.77 g/L). 2. A log Kow of -1. With a low log Pow (below 0) and a water solubility above 10 g/L the substance is to hydrophilic to cross the lipid rich environment of the stratum corneum. Thus, dermal uptake is anticipated to be low. In addition, the results of the acute dermal toxicity support a low absorption via dermal route. Therefore, dermal absorption can be reasonably estimated to be lower than 10%.

In conclusion, dermal NOAEL = oral NOAEL x 100/10 =

103.31 x (100/10) = 1033.1 mg/kg bw/d.

Assessment factors:

Dose response differences: 1

Differences in exposure duration: 2

Interspecies differences (allometric scaling): 4

Remaining interspecies differences: 2.5

Intraspecies differences (general population): 10

Taking the above mentioned assessment factors into account, the following worker long- term dermal DNEL for systemic effects is:

1033.1 mg/kg bw/d / (1 x 2 x 4 x 2.5 x 10) = 1033.1 mg/kg bw/day / 200

= 5.2 mg/kg bw/day

Oral exposure

In order to derive the general population DNEL (long-term oral exposure), the NOAEL assessed in the 90 d repeated dose oral toxicity study (103.31 mg/kg bw/d) is identified as the relevant dose descriptor. No modification of the starting point is necessary.

Assessment factors:

Dose response differences: 1

Differences in exposure duration: 2

Interspecies differences (allometric scaling): 4

Remaining interspecies differences: 2.5

Intraspecies differences (general population): 10

Taking the above mentioned assessment factors into account, the following worker long- term dermal DNEL for systemic effects is:

103.31 mg/kg bw/d / (1 x 2 x 4 x 2.5 x 10) = 103.31 mg/kg bw/day / 200

= 0.52 mg/kg bw/day

References

- ECHA (2010). Guidance on information requirements and chemical safety assessment. Chapter R.8: Characterisation of dose [concentration]-response for human health. Version 2. ECHA-2010 -G-19 –EN.

- ECHA (2016). Guidance on Information Requirements and Chemical Safety Assessment Part E: Risk Characterisation. Version 3. ECHA-2016-G-04-EN