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Additional information

The toxicity of 1,3,4 -Thiadiazolidine-2,5 -dithione, reaction products with hydrogen peroxide and tert-nonanethiol towards birds was not investigated experimentally. It is not a standard information requirement in REACH Annex IX and in accordance with REACH Annex X, Section 9.6.1, column 2, studies on long-term or reproductive toxicity to birds have not to be conducted due to the existence of a large mammalian dataset for this substance. Furthermore, secondary poisoning to birds is unlikely since the bioaccumulation potential is low.

In addition, the substance is not directly applied to air or any other terrestrial compartment and based on its intended use it will not enter the environment. The indirect exposure of the terrestrial environment to this substance via sewage sludge is also of no concern based on the treatment of the sludge. In accordance with Section 9.4 of REACH Annex IX and X, further tests do not need to be conducted if direct and indirect exposure of the environment is unlikely as in this case. REACH allows that certain tests may be waived based on exposure scenarios or an absent, unlikely, not relevant, or not significant exposure. In addition to the manner of use of this substance in formulated products at relatively low constituent volume, during production, formulation, use and waste stages strict management measures are in place to ensure that the substance or product is not released to the environment. It is therefore considered that there should be no exposure of the substance to air and soil and therefore no exposure to birds.