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Long-term toxicity to aquatic invertebrates

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For hydrochloric acid, it is not relevant to determine toxicity in terms of mg/L due to the varying buffering capacity of different test systems and different aquatic ecosystems. Aquatic studies are carried out using buffered media and therefore as discussed for the acute aquatic studies, standard aquatic chronic test methods would lead to differing results based on the different buffering capacity of the specific test systems. Additionally, maintaining exact pH values over time in chronic studies could be problematic.  
It is accepted that the aquatic toxicity of hydrochloric acid results if sufficient acid is present to produce a very low pH (i.e. pH 3-5 – see Doc IIA, Section 4.2). Given that the environmental exposure assessment (Doc IIB, Section 3.3) shows insignificant perturbation of aquatic pH levels from the formulation of the product and its proposed use, it is considered that there is no long-term risk to aquatic organisms and therefore chronic invertebrate effects data are not required.

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