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Toxicity to soil microorganisms

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The performance of a test for toxicity to soil microorganisms 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 long-chain 2-Propenoic acid, octadecyl ester to soil is highly unlikely. The acrylate ester is readily biodegradable (but failing the 10 - day window) and therefore will not persist in soil. Furthermore, an indirect exposure to soil via sewage sludge transfer is unlikely. In addition, no direct releases to soil from point sources are known. Thus, toxicity to soil microorganisms was considered scientifically not justified.

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