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Toxicity to terrestrial arthropods

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The performance of a test for toxicity to terrestrial arthropods is scientifically unjustified.
REACh Regulation No. 1907/2006, Annex IX, Sect. 9.4, Col. 2, states as follows:
“9.4: Effects on terrestrial organisms: These studies do not need to be conducted if direct and indirect exposure of the soil compartment is unlikely.”
Direct and indirect exposure of the test item to soil is highly unlikely. Due to the unstable nature of organic peroxides, it can be assumed that upon contact with soil and organic matter, the test item undergoes rapid degradation resulting in the formation of respective alcohols and acids. Thus, toxicity to soil macro-organisms was considered scientifically not justified. In addition, BCF calculations (BCF = 32.57 L/kg wwt) with EPIWIN 4.10 and the low log Pow of 3.17 indicates that the substance is not bioaccumulative.

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