Reaction mass of Pentaerythritol bis (2-ethylhexanoate) bis (3,5,5-trimethylhexanoate) and Pentaerythritol tris (2-ethylhexanoate) 3,5,5-trimethylhexanoate and Pentaerythritol 2-ethylhexanoate tris (3,5,5-trimethylhexanoate) and Pentaeryhthritol tetrakis(2-ethylhexanoate) and Pentaerythritol tetrakis (3,5,5-trimethylhexanoate)

Ecotoxicological Summary

Hazard for aquatic organisms

Freshwater

Hazard assessment conclusion:

no hazard identified

Marine water

Hazard assessment conclusion:

no hazard identified

STP

Hazard assessment conclusion:

no hazard identified

Sediment (freshwater)

Hazard assessment conclusion:

no hazard identified

Sediment (marine water)

Hazard assessment conclusion:

no hazard identified

Hazard for air

Air

Hazard assessment conclusion:

no hazard identified

Hazard for terrestrial organisms

Soil

Hazard assessment conclusion:

no hazard identified

Hazard for predators

Secondary poisoning

Hazard assessment conclusion:

no potential to cause toxic effects if accumulated (in higher organisms) via the food chain

Conclusion on classification

Aquatic toxicity data are available for all three thopic levels (fish, daphnia and algae). No effects were observed in any of the studies at or above the maximum solubility limit of the substance in test medium. Based on these results, the substance does not need to be classified for acute aquatic hazard nor for long-term aquatic hazard categories 1 to 3; it only needs to be assessed whether the 'safety net' classification of long-term aquatic hazard category 4 apllies.

According to the CLP Regulation, poorly soluble substances for which no acute toxicity is recorded at levels up to the water solubility (as for this substance), will be classified in this category when they are not rapidly degradable AND have a potential to bioaccumulate (to some extent). The CLP Regulation mentions a log Pow of >=4 as criterium for the potential to bioaccumulate, when the BCF is not experimentally determined. An experimentally determined BCF should be >=500 to meet the criterium for the potential to bioaccumulate. Although this substance is not rapidly degradable, it is not considered justified to classify it as a category 4 substance, as its bioaccumulating potential is not justifying such classification.

As explained in the PBT/vPvB assessment, the log Pow values of the constituents (12.34 - 13.86) are far above 10 and their calculated BCF values (0.9 - 32.1) are far below 500. It can therefore be expected that the constituents of this substance will not pass through the cell membranes (to a significant extent). Therefore the argument that the exposure duration in short term tests may be too short for a steady state concentration to be reached in the test organisms, justifying therefore classification as a bioaccumulative substance which may still exert effects in long-term tests, is not considered appropriate for this substance (based on the current available information).