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Environmental fate & pathways

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According to the guidance given in Annex VII if REACH legislation and Chapter R.7B (Endpoint Specific Guidance) of the ECHA REACH Guidance Document, (2008), the requirements for “Ready biodegradability” can be waived if the substance is inorganic (e.g., Pb-salt).

For inorganic substances like lead salts for which the chemical assessment is based on the elemental concentration (i.e., pooling all inorganic speciation forms together), biotic degradation is an irrelevant process, regardless of the environmental compartment that is under consideration: biotic processes may alter the speciation form of an element, but will not eliminate the element from the aquatic compartment by degradation of transformation. This elemental-based assessment (pooling all speciation forms together) can be considered as a worst-case assumption for the chemical assessment.