Propanol, iminobis-, N-(C16-18 and C18-unsatd. alkyl) derivs.

Ecotoxicological Summary

Hazard for aquatic organisms

Freshwater

Hazard assessment conclusion:

PNEC aqua (freshwater)

PNEC value:

0.425 µg/L

Assessment factor:

10

Extrapolation method:

assessment factor

PNEC freshwater (intermittent releases):

0.163 µg/L

Marine water

Hazard assessment conclusion:

PNEC aqua (marine water)

PNEC value:

0.043 µg/L

Assessment factor:

100

Extrapolation method:

assessment factor

STP

Hazard assessment conclusion:

PNEC STP

PNEC value:

3.1 mg/L

Assessment factor:

10

Extrapolation method:

assessment factor

Sediment (freshwater)

Hazard assessment conclusion:

PNEC sediment (freshwater)

PNEC value:

1.692 mg/kg sediment dw

Assessment factor:

50

Extrapolation method:

assessment factor

Sediment (marine water)

Hazard assessment conclusion:

PNEC sediment (marine water)

PNEC value:

0.169 mg/kg sediment dw

Assessment factor:

500

Extrapolation method:

assessment factor

Hazard for air

Air

Hazard assessment conclusion:

no hazard identified

Hazard for terrestrial organisms

Soil

Hazard assessment conclusion:

PNEC soil

PNEC value:

5 mg/kg soil dw

Assessment factor:

100

Extrapolation method:

assessment factor

Hazard for predators

Secondary poisoning

Hazard assessment conclusion:

PNEC oral

PNEC value:

2 mg/kg food

Assessment factor:

300

Additional information

All endpoints are based on measured data for di (2 -hydroxypropyl)tallow amine or read-across from di (2 -hydroxyethyl)oleyl amine applying the appropriate assessment factors. The PNEC sediment is both calculated using the equilibrium partition coefficient method and based on the sediment test result available for di (2 -hydroxyethyl)oleyl amine. The test result is used for risk assessment purposes. Also for earthworms the toxicity data is read-across from primary fatty amine ethoxylate di (2 -hydroxyethyl) oleylamine (CAS 25307-17-9). A justification for read-across is included in IUCLID Chapter 13.

All endpoints are based on measured data applying assessment factors.

Conclusion on classification

Ecotoxicity

Aquatic ecotoxicity tests have been performed in standard test media to quantify the intrinsic toxicity for C&L purposes and in natural riverwater to derive the PNEC_aquatic-bulk to be used for environmental risk assessment purposes. The reasoning why this PNEC_aquatic-bulk is derived is explained in the next paragraph and in the endpoint summaries of the algae and long term daphnia tests. 

Due to intrinsic properties of amine containing cationic surfactants river water ecotoxicity tests deliver more reproducible test results with limited uncertainty. River water has a mitigating effect on ecotoxicity due to sorption of the amines to DOC and suspended matter. For this reason, data obtained under standard test conditions is prefered for classification and labeling purposes. If no data obtained under standard conditions is available the results of tests performed in natural river water can be corrected for the mitigation using a worst-case factor of 10 to the L(E)C₅₀ .

 

More details on the use of the bulk approach are described in a document attached to IUCLID chapter 13.

Table Available algae, daphnia and fish test results (Klimisch 1 and 2)

PFAPO-T (2-[(2-hydroxypropyl)(C16-18 sat. C18 unsat. alkyl)amino]propan-1-ol, (EC 695-977-9, CAS 1309955-79-0, old CAS 68951-72-4))
	nominal		TWA
	EC(L)50/L(L)C50	EC(L)10/NOEC(L)	EC50	EC10/NOEC
	(µg/L)	(µg/L)	(µg/L)	(µg/L)
Algae test (2010)	273**	137**
Bulk-approach static
Akzo Nobel
(CAS 68951-72-4, old CAS)
Algae test (2022)	361	5.87	2.02	0.284
WAF-approach static
Noack
New CAS no.: 1309955-79-0
Short term daphnia test (2022)	waived		waived
Acute fish test (2022)	waived		waived
Long-term fish (2022)	19.5	5.0	16.3	4.25
Flow-through	overall survival		overall survival	overall survival
Noack
New CAS no.: 1309955-79-0
Long-term daphnia test (2012)	480**	140**
Bulk-approach semi-static
Akzo Nobel
(CAS 68951-72-4, old CAS)
Long-term daphnia test (2022)	1874	150	48.1	7.45
WAF approach semi-static
Noack
New CAS no.: 1309955-79-0
Toxicity to microorganisms (2010)	169000	31550
Geerts (2010)
3h-ECx
(CAS 90367-28-5, old CAS)

** figures in bold are based on tests in natural river water. The endpoint value is divided by a factor of 10 as worst-case to correct for the mitigation which might be due to the use of natural river water.

Biodegradability

Di (2 -hydroxypropyl) tallowamine is readily biodegrable.

 

Bioaccumulation potential

No measured BCF fish is available for the primary fatty amine propoxylates. Standard OECD 305 tests are technically very complicated with substances which are sorbing and easily biodegradable. For two pH conditions valid measured log Kow values are however available as presented in the table below. For allow comparison the by EPIsuite (V4.0) calculated Log Kow for the protonated structures is included in the table.

 

primary fatty amines propoxylates	Measured Log Kow (at pH 7)	Measured Log Kow (at pH 3 - 4)	Calculated Log Kow (EPIsuite)
Di (2-hydroxypropyl)hexadecylamine	5.7	3.3	3.93
Di (2-hydroxypropyl)octadecenylamine	6.1	3.6	4.7
Di (2-hydroxypropyl)octadecylamine	6.9	4.4	4.9
Di (2-hydroxypropyl)tallow amine	6.2	3.7	4.5

 

The highest log Kow is observed for di (2 -hydroxypropyl)octadecyl amine. For this product a pKa was calculated of 5.73. For di (2 -hydroxypropyl) octadecyl amine also the lowest water solubility of 0.15 mg/L was observed. The measured log Kow value of 6.2 indicates a bioaccumulation potential if this substance would have been a narcotic substance. For polar narcotics like the primary fatty amine propoxylates however there is only limited information on the relationship between log Kow and BCF.

For hexadecyl amine rapid metabilisation in fish is anticipated based on in vitro metabolism test results with this substance (K_met= 0.152 1/d; Bernard et al., 2006). Based on the structural similarity and ready biodegradability of the primary fatty amine propoxylates also similar metabolisation rates are expected. According to the REACH PBT guidance R.11, evidence of high biotransformation/metabolisation rate in fish may be used to support for arguing for a limited bioaccumulation potential but quantitative thresholds have not been established. The use of QSAR- and mechanistically-based bioaccumulation models is also considered valuable in the overall bioaccumulation assessment process. The BCFBAF model (v3.0) as included in EPIsuite (v4.0) allows the inclusion of metabolism into the BCF calculation but the results of this model should be considered with care as the training set holds only a limited number of substances which can reliably be used to predict the fate of cationic surfactants. With a log Kow of 6.2 the BCFBAF model predicts a BCF of 20880 L/kg wwt without metabolism and 148.6 L/kg wwt with metabolism.

 

Classification according (Classification, Labeling & Packaging Directive286/2011/EC)

 

 

Acute toxicity			Hazard	M-factor
EC50 = 16.3 µg/L (TWA, long term fish)			H400	10
readily biodegradable
Chronic toxicity			Hazard	M-factor
EC10 = 4.25 µg/L (TWA, long term fish)			H410	1