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The acute aquatic EC50/LC50 toxicity of 2,3 -epoxypropyl neodecanoate as determined by GLP O.E.C.D. Testing Guidelines conducted in rainbow trout, the water flea Daphnia magna and green algae ranged from 1.2 mg/L to 5.0 mg/L. An O.E.C.D. test guideline no. 201 acute algal study was conducted with the test substance. The EC50 value from this study conducted for 96 hr was approximately 3.5 mg/L. A second O.E.C.D. test guideline no. 201 acute algal study was conducted with the test substance and included test substance concentration verification. The EC50 value from this study conducted for 72 hr ranged from 1.2 -2.9 mg/L supporting the findings from the first study and is

the most appropriate study result for establishing an aquatic PNEC. Based on E.C.H.A. RIP Guidance 3.2. Chapter R.10: Characterisation of dose [concentration]-response for environment, Table R.10 -4, page 19, an Assessment Factor of 1000 x is applied to the algal EC50 value of 1.2 mg/L. This results in a PNEC aquatic of 1.2 ug/L. The PNEC saltwater was derived in a similar manner by applying a 10,000 x Assessment Factor as per E.C.H.A. RIP Guidance 3.2. Chapter R.10, Table R.10 -5, page 27. Therefore, 1.2 mg per L/ 10,000 = 0.12 ug/L. The PNEC for microorganisms in a sewage treatment plant (STP) is based on the results from the O.E.C.D. 209 Testing Guideline study with activated sewage sludge. The NOEC value from this study was 500 mg/L for a three hr contact time. Following E.C.H.A. RIP 3.2 Guidance, Chapter R.10, page 30, an Assessment Factor of 10 x is applied resulting in PNEC microorganisms STP of > 50 mg/L.