Copper(2+), bis[N-[amino(imino-.kappa.N)methyl]urea-.kappa.O]-, nitrate (1:2)

Long-term toxicity to fish

Link to relevant study record(s)

Reference

Endpoint:

fish early-life stage toxicity

Data waiving:

exposure considerations

Justification for data waiving:

other:

Description of key information

According to REACH Annex Section 3 and ECHA R.5 guidance, to avoid unnecessary animal testing, testing in accordance Annex IX may be omitted if exposure is absent or not significant throughout the whole life cycle of the substance, based on the exposure scenario(s) developed in the Chemical Safety Report. As described in the CSR, no environmental exposure has been demonstrated during the different steps of lifecycle of CuGUN. The CuGUN is imported from United States of America in tight depressurized container by AUTOLIV. In the production line of gas generator, air and dust are aspired by a cyclonic system and then passes through a dust containment system by the water. During cleaning, pellets are removed by a specific vacuum cleaner for pyrotechnic products which contains a tank filled with water. Finally, the water that contains CuGUN is sent to a specialized company for incineration together with personal protection equipment Therefore, no release to environment is expected. When included in article, gas generator is sealed. At the outbreak of the airbag in the event of collision, all the products in the generator are burned. If some of the components should not burn, they remain confined within the generator. At waste life stage, gas generator is incinerated. Concerning classification and labelling needs, CuGUN is already classified as hazardous to aquatic environment: aquatic acute (category 1, with a M factor of 10) and aquatic chronic (category 1). Additional testing will not provide useful data for this purpose (except for chronic M factor). For PBT/VPvB assessment, persistence and bioaccumulation criteria are not met, CuGUN is not considered as PBT/VPvB. Furthermore, T criteria is already an evidence in regard to acute toxicity testing on invertebrates, mutagenicity results and repeated exposure toxicity by oral route. Additionnal testing will then not provide useful data for PBT/VPvB assessment.