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In a non-GLP study of ready biodegradability (Sewell IG et al, 1994), sludge was sampled from a wastewater treatment plant treating predominantly domestic sewage and used at a level of 1%. 2,2 -bis(chloromethyl)trimethylene bis[bis(2 -chloroethyl)phophate was tested at a loading rate equivalent to 20 mg C/l (equivalent to 79.7 mg/l). The test substance was degraded by 5% over the 28-day period according to CO2evolution, and therefore is not readily biodegradable. Sodium benzoate was used as a reference substance, and its degradation met the required validity criteria. Tests were performed in duplicate. The study does not claim compliance with a guideline, although appears to be consistent with standard methods (OECD 301B).

In a non-GLP study of inherent biodegradability (Mead C and Handley JW, 1996), performed according to the OECD 302C Modified MITI (II) procedure, sludge was sampled from 10 sites around the UK and was present in test vessels at a loading equivalent to 100 mg dry weight/l. The test substance was present at a level of 30 mg/l. Aniline was used as a reference substance, present at 100 mg/l. The observed cumulative percentage biodegradation of the test substance was very variable. The substance apparently degraded up to around 10% total, and then reverted to 0% degradation at day 9-10 (the reference substance degraded normally and fulfilled the required criteria). The test report suggests that the variability is “due to variations in the basal respiration rate of the inoculum”. After 14 days a consistent increase in the extent of degradation started, and at the end of the 28-day test period the test substance was degraded by 37%, appearing to have reached a plateau in the final 7-8 days. The substance shows clear evidence of being biodegradable, although cannot be described as inherently biodegradable.

References: European Union Risk Assessment Report "2,2-Bis(chloromethyl)trimethylene bis[bis(2-chloroethyl)phophate]" (V6), CAS 38051-10-4, May 2008