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Ecotoxicological information

Toxicity to birds

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Description of key information

Waiver: Studies on effects on birds do not need to be conducted secondary poisoning is not of concern. PACM (4,4’-methylenebis(cyclohexylamine) has a log Kow of 2.03 and a BCF of 10.15; each value is below the threshold of concern for secondary poisoning. 

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Additional information

Evaluation of upper trophic level exposures (secondary poisoning) is not of concern for PACM (4,4'-methylenebis(cyclohexylamine)). "Secondary poisoning" refers to the toxic effects in the higher members of a food chain that result from ingestion of organisms from lower trophic levels that contain accumulated substances (and/or related metabolites). To be evaluated for secondary poisoning, the chemical must have a log Kow≥ 3 or a BCF ≥ 100; and no mitigating property such as biodegradability or hydrolysis (half life less than 12 hours).  Since the log Kowfor PACM is 2.03 (based on the measured value from the OECD Guideline 107 shake flask method test by BASF, 1988), and the BCF for PACM is 10.15 (as predicted by the BCFBAF v3.00 model in EPI-Suite, based on a log Kowof 2.03), then neither of the first two screening criteria are satisfied for PACM (Section R., Chapter R.16, Environmental exposure estimation, Guidance on information requirements and chemical safety assessment,ECHA, May 2008). Therefore, PACM may be waived with respect to the evaluation of secondary poisoning and the derivation of a PNECoral for wildlife exposures, including the food chain exposures of birds (Section R.10.8.1, Chapter R.10, Characterisation of dose[concentration]-response for environment, of Guidance on information requirements and chemical safety assessment,ECHA, May 2008).