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Diss Factsheets

Administrative data

Description of key information

LLNA, skin sensitizer (OECD 429, GLP, K, Rel. 1)

Respiratory sensitisation: The currently identified mechanisms of dermal and respiratory sensitization may be sufficiently different, and exposure levels are significantly lower than the probable minimum threshold

level required for induction and/or elicitation to prevent any risk of respiratory sensitization. This conclusion is based on various elements of scientific evidence that together constitute a robust argument and obviate the need to conduct further specific studies to investigate the potential for respiratory sensitization of this substance. It is noted that, even if it was considered appropriate to conduct further testing, there is currently no available or suitable validated method that could be used.

Key value for chemical safety assessment

Skin sensitisation

Link to relevant study records
Reference
Endpoint:
skin sensitisation: in vivo (LLNA)
Type of information:
experimental study
Adequacy of study:
key study
Study period:
From November 06, 2014 to March 17, 2015
Reliability:
1 (reliable without restriction)
Rationale for reliability incl. deficiencies:
guideline study
Qualifier:
according to guideline
Guideline:
OECD Guideline 429 (Skin Sensitisation: Local Lymph Node Assay)
Deviations:
no
Qualifier:
according to guideline
Guideline:
EU Method B.42 (Skin Sensitisation: Local Lymph Node Assay)
Deviations:
no
Qualifier:
according to guideline
Guideline:
EPA OPPTS 870.2600 (Skin Sensitisation)
Deviations:
no
Principles of method if other than guideline:
Not applicable
GLP compliance:
yes (incl. QA statement)
Remarks:
UK GLP Compliance Programme (inspected on July 01, 2014/ signed on October 10, 2015)
Type of study:
mouse local lymph node assay (LLNA)
Species:
mouse
Strain:
CBA/Ca
Sex:
female
Details on test animals and environmental conditions:
TEST ANIMALS
- Source: Four healthy female mice were obtained from Harlan UK Ltd and a further 27 female mice were obtained from Charles River UK Ltd.
- Age at study initiation: Approximately 8-12 weeks
- Weight at study initiation: 14.9-20.7 g
- Housing: Animals were housed two or three animals per cage, in solid bottomed polycarbonate cages with a stainless steel mesh lid.
- Diet: Standard rodent diet (Harlan Teklad 2014C Diet), ad libitum
- Water: Potable water taken from the public supply, ad libitum
- Acclimation period: 5 days

ENVIRONMENTAL CONDITIONS
- Temperature: 19-23 °C
- Humidity: 40-70 %
- Air changes: Animal room was kept at positive pressure with respect to the outside by its own supply of filtered fresh air, which was passed to atmosphere and not re-circulated.
- Photoperiod: 12 h dark / 12 h light

IN-LIFE DATES: From November 06, 2014 to March 17, 2015
Vehicle:
acetone/olive oil (4:1 v/v)
Concentration:
Main test: 10, 25 and 50 % v/v in acetone/olive oil 4:1
No. of animals per dose:
5
Details on study design:
PRELIMINARY STUDY:
- Compound solubility: A vehicle trial performed showed that the test item formed a clear solution in 4:1 v/v acetone: olive oil (AOO) at 50% v/v which was satisfactory for dose administration.
- Preliminary investigations were performed to ensure the highest concentration to be used on the main study did not result in systemic toxicity or excessive local irritation. Although the material could be dosed as supplied as a precautionary measure the preliminary investigation started at 50% v/v in AOO. As no toxicity was seen at 50% v/v in AOO the preliminary investigation continued with the test material as supplied. Preliminary investigations conducted in Harlan animals proved that 50% v/v in AOO was the suitable high dose level for the main study. However, it became necessary to perform the main study in mice provided by Charles River. As a precautionary measure when changing animal supplier the preliminary phase was repeated at 50% v/v using Charles River animals to ensure there was no difference in outcome before proceeding to the main study in Charles River mice.
- An assessment of local irritation was performed and an erythema score greater or equal to 3 and/or an increase in ear thickness of greater than 25% at Day 3 or 6 compared with predose would be regarded as irritation which precludes the use of that concentration on the main study.
- Two female mice (per concentration) received a daily application of 25 μL of appropriate concentration of the test substance to the dorsal surface of each ear for three consecutive days (Days 1-3).
- Results of the preliminary investigations indicated that 50% v/v was a suitable high concentration for administration in the main phase of the study. The low and intermediate concentrations were selected from the concentration series given in regulatory guidelines and the concentrations administered on the main study were: 10, 25 and 50% v/v in AOO

MAIN STUDY
ANIMAL ASSIGNMENT AND TREATMENT
- Name of test method: Local Lymph Node Assay
- Criteria used to consider a positive response: If the SI is 3 or more, the test substance is regarded as a skin sensitizer with a consideration given to dose response and statistical significance.

TREATMENT PREPARATION AND ADMINISTRATION:
- The test substance was prepared for administration as a series of graded concentrations in the vehicle, by direct dilution. The test substance was used as supplied and all formulations were prepared on the day of dosing at the required concentration(s).
- The mice were treated by daily application of 25 μL of the appropriate concentration of the test substance to the dorsal surface of each ear for three consecutive days (Days 1-3). Five days following the first topical application of test substance (Day 6) all mice were injected via the tail vein with 250 μL of phosphate buffered saline containing 3H-methyl Thymidine (3HTdR: 80 μCi/mL) giving a nominal 20 μCi to each mouse. Five hours following the administration of 3HTdR on Day 6 all mice were humanely killed by carbon dioxide asphyxiation. The draining auricular lymph nodes were excised for each experimental animal and placed in 1.0 mL of PBS. A single cell suspension of lymph node cells (LNC) was prepared by gentle mechanical disaggregation through a stainless steel gauze (200 mesh size). The LNC were then washed by adding 10 mL PBS, pelleted at 190 x g for 10 minutes and resuspended. The cells were washed twice again and resuspended in 3 mL trichloroacetic acid (TCA: 5%) following the final wash. After overnight incubation (minimum of 18 hours) with 5% TCA at 4 °C, the precipitate was recovered by centrifugation and resuspended in 1 mL 5% TCA and transferred to 10 mL Ultima gold scintillation fluid on Day 7. The 3HTdR incorporation was measured by β scintillation counting. The proliferative response of LNC was expressed as radioactive disintegrations per minute per lymph node (dpm/node).
- Stimulation Index: Results for each treatment group were expressed as the Stimulation Index (SI). This was derived by dividing the mean dpm/mouse for each treated group and the positive control group by the mean dpm/mouse in the vehicle control group.
Positive control substance(s):
hexyl cinnamic aldehyde (CAS No 101-86-0)
Statistics:
The individual dpm data was analysed statistically.
Positive control results:
SI for the positive control substance hexyl cinnamic aldehyde (HCA), was 5.5 which demonstrates the validity of this study.
Key result
Parameter:
EC3
Value:
9.5
Cellular proliferation data / Observations:
CELLULAR PROLIFERATION DATA
DPM / node for vehicle, 10, 25 and 50 % v/v were 466.3, 1876.3, 9956.7 and 13740.1, respectively.

DETAILS ON STIMULATION INDEX CALCULATION
Stimulation index for 10, 25 and 50 % v/v were 4.0, 21.4 and 29.5, respectively

EC3 CALCULATION
As a SI of 3 or more was recorded for all of the concentrations tested, test item was considered to have the potential to cause skin sensitization. Based on the results of this study the EC3 value is calculated to be 9.5% v/v.

CLINICAL OBSERVATIONS:
There were no deaths and no signs of ill health or toxicity were observed during this study.
Wet/greasy fur on the head was noted following each dosing occasion, this was related to unoccluded dermal administration of a liquid formulation/vehicle and not an effect of the test substance.
In addition partially closed eye lids were seen pre dose on Day 3 for all positive control animals and from approximately 5.5 hours post dose on Day 3 for two animals receiving 50%v/v (animal numbers A25 and A26). Recovery for all animals was seen by the end of Day on Day 3.
No signs of dermal irritation were seen on the ear during the study. There was no evidence of an effect of treatment on ear thickness.

BODY WEIGHTS
There was no indication of an effect of treatment on body weight gain.
A minor loss in body weight was noted for several mice (Nos. A7, A9, A12, A14, A17, A26 and A27) over the study period, however, there was no evidence of a dose relationship and as a small loss in body weight is not uncommon in young laboratory mice this is considered not to be an effect of treatment.

Preliminary investigation

Mortality and clinical signs: There were no deaths and no signs of ill health or toxicity were observed during this study for any of the mice receiving 50% v/v. Group 2 animals dosed with the test substance as supplied (Nos. A3 and A4) were killed for welfare reasons on Day 2 due to poor condition.

Group 2 animals both exhibited partially closed eyelids (both), hunched posture, underactive behaviour and irregular breathing on Day 2 after dosing. The female animal (No. A3) was also noted to have closed eyelids (both), lachrymation in both eyes and tremors before being killed for welfare reasons.

Wet/greasy fur on the head was noted following each dosing occasion, this was related to unoccluded dermal administration of a liquid formulation/vehicle and not an effect of the test substance.

Dermal reactions: No erythema was observed on the ears for any of the mice receiving 50% v/v on Days 1 to 6.

Measurement of ear thickness: There was no evidence of an effect of treatment on ear thickness.

Body weight:There was no indication of an overt effect of treatment on body weight gain.

A loss in body weight was noted for both mice from Charles River receiving 50% v/v (animal Nos. A5 and A6) over the study period, however, a small loss in body weight is not uncommon in young laboratory mice and this was considered not to be an effect of treatment.

On the basis of the results from the preliminary investigation, 50% v/v was considered a suitable high concentration for administration in the main phase of the study.

Table 7.4.1/1: Group dpm/node and Stimulation Index

Test article

dpm

Number of lymph nodes per animal

dpm/node

Stimulation Index†

Result

+ = positive

- = negative

Vehicle (AOO)

932.5

2.0

466.3

n/a

n/a

10% v/v

3752.5**

2.0

1876.3

4.0

+

25% v/v

19913.3***

2.0

9956.7

21.4

+

50% v/v

27480.2***

2.0

13740.1

29.5

+

HCA 25% v/v

5107.7*

2.0

2553.9

5.5

+

 

         Stimulation Index of 3 or more indicates a positive result

n/a       Not applicable

dpm    Disintegrations per minute (less background count of 35.8 dpm)

AOO    Acetone:olive oil (4:1 v/v) (vehicle control)

HCA    Hexyl cinnamic aldehyde (positive control)

 

Individual approach only:

*p<0.05 for comparisons with Group 4 using t-test.

**p<0.01 p-values for comparisons with Group 4 using Williams’ test

***p<0.001 p-values for comparisons with Group 4 using Williams’ test

Interpretation of results:
Category 1B (indication of skin sensitising potential) based on GHS criteria
Conclusions:
Under the test conditions, test material is classified as a skin sensitizer 1B according to the annex VI of the Regulation EC No. 1272/2008 (CLP) and to the GHS.
Executive summary:

A study was performed to assess the skin sensitisation potential of test material in the CBA/Ca strain mouse following topical application to the dorsal surface of the ear. The method was conducted according to the OECD test guideline No 429 and in compliance with GLP.

 

The study comprised three treated groups, each comprising five female mice receiving test item at concentrations of 10, 25 or 50% v/v. Similarly constituted groups received the vehicle 4:1 v/v acetone: olive oil (AOO) or positive control substance (25% v/v hexyl cinnamic aldehyde). The mice were treated by daily application of 25mL of the appropriate concentration or control (vehicle or positive), to the dorsal surface of both ears for three consecutive days. The proliferative response of the lymph node cells (LNC) from the draining auricular lymph nodes was assessed five days following the initial application, by measurement of the incorporation of 3H-methyl Thymidine (3HTdR) by β-scintillation counting of LNC suspensions. The response was expressed as radioactive disintegrations per minute per lymph node (dpm/node) and as the ratio of 3HTdR incorporation into LNC of test nodes relative to that recorded for control nodes (test/control ratio), termed as Stimulation Index (SI).

The SI obtained for 10, 25 and 50% v/v were 4.0, 21.4 and 29.5 respectively which indicates that test item showed the potential to induce skin sensitization. The EC3 value was calculated to be 9.5% v/v. No sign of systemic toxicity or excessive local skin irritation were noted at the concentrations of 10, 25 and 50 % v/v.

The SI for the positive control substance hexyl cinnamic aldehyde was 5.5, which demonstrates the validity of this study.

 

Under the test conditions, test material is classified as a skin sensitizer 1B in the Local Lymph Node Assay according to the annex VI of the Regulation (EC) No. 1272/2008 (CLP) and to the GHS.

This study is considered as acceptable and satisfies the requirement for sensitisation endpoint.

Endpoint conclusion
Endpoint conclusion:
adverse effect observed (sensitising)
Additional information:

Existing human and animal data concluded that the registered substance has no skin sensitization potential. However, the reliability of those data was not considered adequate to meet the REACH requirements and to make a conclusion on classification and labelling. Moreover, QSAR (Toxtree, v2.6.6) identified skin sensitisation potential (Michael acceptors alert).

Therefore, a new LLNA study was performed according to the OECD test guideline No. 429 and in compliance with GLP (Envigo, 2015, rel.1) [NB: at the time of test performance, i.e. 2015, in vitro testing was not the REACH default requirement].

 

The study comprised three treated groups, each comprising five female mice receiving test item at concentrations of 10, 25 or 50% v/v. Similarly constituted groups received the vehicle 4:1 v/v acetone: olive oil (AOO) or positive control substance (25% v/v hexyl cinnamic aldehyde). Mice were treated by daily application of 25mL of the appropriate concentration or control (vehicle or positive), to the dorsal surface of both ears for three consecutive days.The proliferative response of the lymph node cells (LNC) from the draining auricular lymph nodes was assessed five days following the initial application, by measurement of the incorporation of 3H-methyl Thymidine (3HTdR) by β-scintillation counting of LNC suspensions. The response was expressed as radioactive disintegrations per minute per lymph node (dpm/node) and as the ratio of 3HTdR incorporation into LNC of test nodes relative to that recorded for control nodes (test/control ratio), termed as Stimulation Index (SI).

The SI obtained for 10, 25 and 50% v/v were 4.0, 21.4 and 29.5, respectively, which indicates that test item showed the potential to induce skin sensitization. The EC3 value was calculated to be 9.5% v/v. No sign of systemic toxicity or excessive local skin irritation were noted at the concentrations of 10, 25 and 50 % v/v.

The SI for the positive control substance hexyl cinnamic aldehyde was 5.5, which demonstrates the validity of this study.

 

Under the test conditions, test material is classified as a skin sensitizer.

Respiratory sensitisation

Endpoint conclusion
Endpoint conclusion:
no study available
Additional information:

Under the REACH regulation there is no legal standard information requirement in Annexes VII to X to perform any specific test for respiratory sensitisation. However, guidance document Chapter R.7.a endpoint specific guidance (paragraphs 7.3.5-7.3.9) describes how to use human and non-human data. As regards non-human data there is:

 

  • No definitive guidance on use of QSARs
  • No specific in vitro method
  • The role on LLNA, cytokine fingerprints, total IgE/specific IgE methods are described. However, it is widely appreciated that, in both humans and animals, the accurate evaluation of antibody responses against chemical allergens in the form of hapten–protein conjugates can be technically demanding and highly variable between laboratories.
  • Assessment should be case-by-case

The case-by-case risk assessment for the potential for respiratory sensitization for this substance is addressed as follows.

 

Prevalence.

Compared with contact allergens, of which a few thousand have been identified, far fewer chemicals have been implicated as having the potential to cause sensitisation of the respiratory tract, the number being no more than 80, all are associated with occupational exposures (Kimber and Dearman, 1997; Bakerly et al., 2008; Health and Safety Executive, 2001; Baur, 2013; Baur and Bakehe, 2014).

 

Mechanistic Factors.

Most chemicals are too small in terms of molecular size to induce an adaptive immune response. To acquire immunogenic potential they must form stable associations with protein (hapten–protein conjugates). Mechanistic chemistry studies have revealed that chemical respiratory allergens can be assigned to one of six electrophilic mechanistic domains, with harder (stronger) electrophilic mechanisms such as acylation being more prevalent than softer (weaker) mechanisms, with the hypothesis being that the harder nucleophile lysine is the favoured biological nucleophile for sensitization of the respiratory tract (Enoch et al., 2012). The substance is not-predicted to react with skin proteins directly, but may act as a pro-hapten and no alerts for respiratory sensitisation has been predicted (OECD toolbox v3.4). The substance or its’ metabolites are expected to react via covalent binding with a cysteine peptide under the metabolic conditions of the peroxidase peptide reactivity assay (PPRA) (Gerberick, 2009), which is the first step of the adverse outcome pathway (AOP) of sensitization. The possible importance of lysine reactivity (in comparison to cysteine binding) in sensitization of the respiratory tract by chemical allergens is supported by some in chemico and in vitro studies (Hopkins et al., 2005; Lalko et al., 2011, 2012, 2013b). Hence, as the substance or its’ metabolites preferentially react with cysteine (skin sensitiser) it is unlikely to be a respiratory sensitizer, which seem to be those chemicals that are more likely to react with lysine.

Antigenic Response.

In any in vivo sensitisation test such as LLNA or GPMT, a positive response does not imply that a chemical will cause respiratory sensitisation because the immune responses induced by contact allergens and chemical respiratory allergens begin to diverge in a qualitative sense after the initial activation of T lymphocytes (Cochrane et al., 2015). Chemical respiratory allergens result in the development of a selective Th2-type immune response characterised by the increased expression of type 2 cytokines such as IL-4, IL-5 and IL-13. In contrast, under the same conditions, skin sensitising chemicals elicit Th1-selective immune responses.

 

Threshold Effects.

There is evidence that thresholds of elicitation can be defined for IgE mediated allergies and in the case of human respiratory sensitisation to proteins there is evidence for thresholds even if it is not currently possible to be specific in numerical terms (Basketter et al., 2010, 2012; Peters et al., 2001; Sarlo, 2003).

As an example for chemical respiratory sensitizers, over the past 30 years evidence has accumulated of occupational asthma associated with the use of glutaraldehyde, including the involvement of IgE antibody, and in particular in endoscopy, radiography and pathology suites. The evidence suggests that brief exposures to high levels of glutaraldehyde are required to induce allergic sensitization, this is consistent with the probability that peak exposures to chemicals may drive sensitisation (Arts et al., 2006; Vyas et al., 2000).

 

Experimental Evidence.

A study was conducted with patients with confirmed contact allergy to isoeugenol or hydroxyisohexyl-3-carboxaldehyde (HICC). These patients were exposed to the chemical to which they were sensitized by inhalation using an exposure chamber, with skin contact being shielded by protective clothing. No significant changes in lung function were observed suggesting the absence of respiratory sensitization (Schnuch et al., 2010). This study provides evidence that individuals already sensitised to a substance via the dermal route do not experience symptoms of sensitization when exposed via the inhalation route. Also of relevance is a study of lung function among employees in the fragrance industry (Dix, 2013). A group of workers exposed to fragrance materials during production or similar operations was compared with a non-exposed control group of office workers. There were no significant differences in lung function as determined by measurement of forced expiratory volume, forced vital capacity of peak expiratory flow (Dix, 2013). The relevance of these studies and other work has been recently reviewed (Basketter and Kimber, 2015).

 

Conclusion.

The currently identified mechanisms of dermal and respiratory sensitization may be sufficiently different, and exposure levels are significantly lower than the probable minimum threshold level required for induction and/or elicitation to prevent any risk of respiratory sensitization. This conclusion is based on various elements of scientific evidence that together constitute a robust argument and obviate the need to conduct further specific studies to investigate the potential for respiratory sensitization of this substance.

 

References

Arts, J.H.E., Mommers, C., de Heer, C., 2006. Dose-response relationships and threshold levels in skin and respiratory allergy. Crit. Rev. Toxicol. 36, 219–251.

Bakerly, N.D., Morre, V.C., Vellore, A.D., Jaakkola, M.S., Robertson, A.S., Burge, P.S., 2008. Fifteen-year trends in occupational asthma: data from the shield surveillance scheme. Occup. Med. 58, 69-174.

Baur, X., 2013. A compendium of causative agents of occupational asthma. J. Occup. Med. Toxicol. 8, 1-8.

Baur, X., Bakehe, P., 2014. Allergens causing occupational asthma: an evidence based evaluation of the literature. Int. Arch. Occup. Environ. Health 87, 339-363.

Basketter, D.A., Broekhuizen, C., Fieldsend, M., Kirkwood, S., Mascarenhas, R., Maurer, K., Pedersen, C., Rodriguez, C., Schiff, H.-E., 2010. Defining occupational consumer exposure limits for enzyme protein respiratory allergens under REACH. Toxicology 268, 165–170.

Basketter, D.A., Berg, N., Kruszewski, F.H., Sarlo, K., Concoby, B., 2012. Relevance of sensitization to occupational allergy and asthma in the detergent industry. J. Immunotoxicol. 9, 314–319.

Basketter, D.A. and Kimber, I., 2015. Fragrance sensitisers: Is inhalation an allergy risk? Regul. Toxicol. Pharmacol. 73(3): 897-902.

Cochrane, SA., Arts, J.H.E., Ehnes, C., Hindle, S., Hollnagel, H.M., Poole, A., Suto, H., and Kimber, I., 2015. Thresholds in chemical respiratory sensitisation. Toxicology, 333, 179-194.

Dix, G.R., 2013. Lung function in fragrance industry employees. Occup. Med. (Lond.) 63, 377-379.

Enoch, S.J., Seed, M.J., Roberts, D.W., Cronin, M.T., Stocks, S.J., Agius, R.M., 2012. Development of mechanism-based structural alerts for respiratory sensitization hazard identification. Chem. Res. Toxicol. 25, 2490–2498.

Gerberick GF1, Troutman JA, Foertsch LM, Vassallo JD, Quijano M, Dobson RL, Goebel C, Lepoittevin JP. Investigation of peptide reactivity of pro-hapten skin sensitizers using a peroxidase-peroxide oxidation system. Toxicol Sci. 2009, 112(1):164-74.

Hopkins, J.E., Naisbitt, D.J., Kitteringham, N.R., Dearman, R.J., Kimber, I., Park, B.K., 2005. Selective haptenation of cellular and extracellular protein by chemical allergens: association with cytokine polarization. Chem. Res. Toxicol. 18, 375–381.

HSE (Health and Safety Executive), 2001. Asthmagen? Critical Assessments of the Evidence for Agents Implicated in Occupational Asthma. UK Health and Safety Executive.

Kimber, I., Dearman, R.J., 1997. Chemical respiratory allergy: an introduction. In: Kimber, I., Dearman, R.J. (Eds.), Toxicology of Chemical Respiratory Hypersensitivity. Taylor & Francis, London, UK, pp. 1-6.

Lalko, J.F., Kimber, I., Dearman, R.J., Gerberick, G.F., Sarlo, K., Api, A.M., 2011. Chemical reactivity measurements: potential for characterization of respiratory chemical allergens. Toxicol. In Vitro 25, 433–445.

Lalko, J.F., Kimber, I., Gerberick, G.F., Foertsch, L.M., Api, A.M., Dearman, R.J., 2012. The direct peptide reactivity assay: selectivity of chemical respiratory allergens. Toxicol. Sci. 129, 421–431.

Lalko, J.F., Dearman, R.J., Gerberick, G.F., Troutman, J.A., Api, A.M., Kimber, I., 2013a. Reactivity of chemical respiratory allergens in the peroxidase peptide reactivity assay. Toxicol. In Vitro 27, 651–661.

Lalko, J.F., Kimber, I., Dearman, R.J., Api, A.M., Gerberick, G.F., 2013b. The selective peptide reactivity of chemical respiratory allergens under competitive and noncompetitive conditions. J. Immunotoxicol. 10, 292–301.

Peters, G., Johnson, G.Q., Golembiewski, A., 2001. Safe use of detergent enzymes in the workplace. Appl. Occup. Environ. Hyg. 16, 389–396.

Sarlo, K., 2003. Control of occupational asthma and allergy in the detergent industry. Ann. Allergy Asthma Immunol. 90, 32–34.

Schnuch, A., Oppel, E., Oppel, T., Rommelt, H., Kramer, M., Riu, E., Darsow, U., Przybilla, B., Nowak, D., Jorres, R.A., 2010. Experimental inhalation of fragrance allergen in predisposed subjects: effects on skin and airways. Br. J. Dermatol. 162, 598-606.

Vyas, A., Pickering, S.A.C., Oldham, L.A., Francis, H.C., Fletcher, A.M., Merrett, T., Niven, R.M., 2000. Survey of symptoms respiratory function, and immunology and their relation to glutaraldehyde and other occupational exposures among endoscopy nursing staff. Occup. Environ. Med. 57, 752–759.

Justification for classification or non-classification

Harmonized classification:

The substance has no harmonized classification according to the Regulation (EC) No. 1272/2008.

Self-classification:

Based on the available data, the substance is classified as Skin Sens. 1B, H317 (May cause an allergic skin reaction) according to the Regulation (EC) No. 1272/2008 (CLP) and to the GHS, since EC3 is > 2% (9.5%).

No direct scientific data are available on the substance to address respiratory sensitisation. However, a scientific argument using mechanistic information has been constructed and is detailed in the discussion of the endpoint summary. As a result, the substance does not meet the criteria for classification according to Regulation (EC) No 1272/2008, Annex I section 3.4.