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Long-term toxicity to fish

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Long-term toxicity testing in fish is not necessary since there are sufficient read-across chronic toxicity data in invertebrates (e.g., Daphnia magna) to indicate that the test substance is unlikely to cause long-term aquatic toxicity at its maximum water solubility limits.  Other supporting data indicate that the test substance is not acutely toxic to fish, invertebrates and algae at its maximum water solubility limits. 
Furthermore, the test substance is not persistent or bioaccumulative (see Section 4). As pointed out on page 54 of the 2008 ECHA-REACH Guidance on Information Requirement and Chemical Safety Assessment, Chapter R.7b : “PBT assessment: chronic fish toxicity testing is generally only necessary, when the P and B criteria are fulfilled.” Since the test substance does not fulfill the P and B criteria, chronic fish toxicity testing is not necessary.

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