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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 soil compartment is highly unlikely, as: 4,4-sulphonyldiphenol is manufactured and used in completely closed systems. Furthermore, 4,4-sulphonyldiphenol is not coming into contact with final consumers, because substance is chemical bounding completely during industrial polymerisation process.
Therefore, the direct and indirect release of 4,4-sulphonyldiphenol into soil compartment is practically negligible.
In summary, direct and indirect exposure of 4,4-sulphonyldiphenol to soil compartment, is unlikely and thus, toxicity testing on terrestrial organisms is scientifically unjustified.

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