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Toxicity to soil macroorganisms except arthropods

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Indirect exposure of 2,2'-[propane-2,2-diylbis(4,1-phenyleneoxy)]diethanol (BPA-2OE) to soil cannot be excluded. Therefore, according to column 2 of annex IX of Reach regulation, "in the absence of toxicity data for soil organisms, the equilibrium partitioning method may be applied to assess the hazard to soil organisms". ECHA's guidance on information requirements and chemical safety assessment, chapter R.7c (v4.0 ; June 2017 ; pp.158 -159) explains how EPM should be used. In the absence of any soil toxicity data, a soil hazard category must be assigned to the substance. BPA-2OE is not readily biodegradable but not H400/H410. It falls therefore within the scope of soil hazard category 3. In this category, it is demanded to conduct one confirmatory long-term soil testing. It is our understanding that invertebrate testing is preferred to plant testing in a first approach (ECHA's guidance R.7c; v4.0 ; June 2017 ; p. 149, fourth paragraph). Therefore a study according to OECD 222 guideline is proposed.

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