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Justification:Column 2 criteria for bioaccumulation testing of TCPP provide the following adaptations to required testing data:


The study need not be conducted if:

·                   the substance has a low potential for bioaccumulation (for instance a log Kow ≤ 3) and/or a low potential to cross biological membranes, or

·                   direct and indirect exposure of the aquatic compartment is unlikely.

It is generally assumed that non-ionised organic substances with a log Kow below 3 are not significantly bioaccumulative (Section R7c of the ECHA Guidance on information requirements). TCPP has an estimated log Kow of 2.89 (EPI Suite (v.4.00) software).

Generally, a BCF/BAF in fish of ≥ 500 is indicative of the potential to bioconcentrate for classification purposes in accordance with CLP/GHS criteria. The BCF/BAF values estimated for TCPP are well below the cut-off values for bioaccumulation. Therefore, TCPP is not likely to bioaccumulate in aquatic organisms.