Registration Dossier

Diss Factsheets

Administrative data

Hazard for aquatic organisms

Freshwater

Hazard assessment conclusion:
PNEC aqua (freshwater)
PNEC value:
0.011 mg/L
Assessment factor:
100
Extrapolation method:
assessment factor
PNEC freshwater (intermittent releases):
0.009 mg/L

Marine water

Hazard assessment conclusion:
no data available: testing technically not feasible

STP

Hazard assessment conclusion:
no data available: testing technically not feasible

Sediment (freshwater)

Hazard assessment conclusion:
no exposure of sediment expected

Sediment (marine water)

Hazard assessment conclusion:
no exposure of sediment expected

Hazard for air

Air

Hazard assessment conclusion:
no hazard identified

Hazard for terrestrial organisms

Soil

Hazard assessment conclusion:
no hazard identified

Hazard for predators

Secondary poisoning

Hazard assessment conclusion:
no potential for bioaccumulation

Additional information

The reference substance, CAS No. 20566 -35 -2, and structural analogs were used to model the ecotoxicology of the UVCB substance. See attachment for structures and substances modeled. Predicted hydrolysis products are tetrabromophthalic acid and alcohols. IUCLID Data Sets and/or OECD SIDS profiles are available on the structural analogs modeled. See attachment for data and references.

Conclusion on classification

Based on modeling, the PNEC-aqua for the reference substance is 0.009 mg/L for intermittent releases. This is based upon the lowest of 3 short-term L(E)C estimated values (0.9 mg/L) with an assessment factor of 100. This effect level is clearly above the water solubility, estimated by WSKOW v1.41 as 0.057 mg/L. The reference substance is not expected to bioconcentration/bioaccumulate.

TBPA Diol is a UVCB substance, and because of that performing aquatic studies with analytical confirmation of dose levels is not possible. The molecule used to estimate the toxicity of the product is a worst case for aquatic toxicity since the remaining molecules in the product are monomers and polymers. Therefore, and in line with the Guidance on the application of the CLP criteria, Part 4 -4.1.3.3.2 an environmental classification would not be justified.