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Based on the estimated Koc (EUSES 2.1, organic acids) of 65 L/kg sorption to sewage sludge in a STP is low and transfer of TPSA to agricultural soil is limited. In addition TPSA has a low aquatic ecotoxicity (see IUCLID Chapter 6.1) and a low ecotoxicity is expected for terrestrial organisms as well.Based in the facts mentioned before, terrestrial ecotoxicity tests are not warranted and it is justified ot calculate the PNEC soil from the PNEC freshwater by the Equilibrium Partitoning Method.