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Biodegradation in water and sediment: simulation tests

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The performance of simulation tests for biodegradation in water and sediment is scientifically unjustified.
REACH Regulation No. 1907/2006, Annex IX, Sect., Col. 2, states as follows:
“ The study need not to be conducted:
- if the substance is readily biodegradable, or
- if direct and indirect exposure of sediment is unlikely. ”
Direct and indirect exposure of the test item to water and sediment is highly unlikely. Due to the unstable nature of organic peroxides, it can be assumed that upon contact with water and organic matter, the test item undergoes rapid degradation resulting in the formation of respective alcohols and acids. Furthermore, tert-butyl peroxypivalate was considered to be inherently biodegradable, therefore simulation testing for biodegradation in water or sediment was considered to be scientifically not justified.

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