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Environmental fate & pathways

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According to Regulation (EC) No.1907/2006, Annex IX, Section 9.3.2, Column 2, studies to determine bioaccumulation in aquatic speciesneed not be conducted if the substance has a low potential for bioaccumulation (for instance a log Kow < 3) and/or a low potential to cross biological membranes. PACM (4,4'-methylenebis(cyclohexylamine)) has a log Kow of 2.03 as determined by the shake flask method, and therefore testing to determine aquatic bioaccumulation is not indicated. 

The low potential for bioaccumulation is supported by the experimental results for the structurally similar substance DMDC (CAS 6864 -37 -5; MITI, 2003, OECD 305): BCF < 60.

In addition QSAR models used to determine the BCF indicate that significant bioaccumulation is not to be expected:

- BCFBAF v3.01 (EPI Suite v4.10): BCF = 10.1

- Catalogic v5.11.6TB - BCF baseline model v02.05: BCF = 21.7 (effective mitigating factors like molecular size and water solubility)

- US EPA T.E.S.T. (v4.1): Consensus method: 49.7 (range: 23 to 155).

Using a weight-of-evidence approach on the available data, significant accumulation of the substance is not expected regarding the majority of data indicating a BCF < 100. There is only one model with a higher BCF of 2436, while all other models as well as the experimental data have lower BCFs.