Amines, N-(C18-unsatd. alkyl)trimethylenedi-, ethoxylated

Ecotoxicological Summary

Hazard for aquatic organisms

Freshwater

Hazard assessment conclusion:

PNEC aqua (freshwater)

PNEC value:

1.726 µg/L

Assessment factor:

50

Extrapolation method:

assessment factor

PNEC freshwater (intermittent releases):

1.3 µg/L

Marine water

Hazard assessment conclusion:

PNEC aqua (marine water)

PNEC value:

0.173 µg/L

Assessment factor:

500

Extrapolation method:

assessment factor

STP

Hazard assessment conclusion:

PNEC STP

PNEC value:

1.4 mg/L

Assessment factor:

10

Extrapolation method:

assessment factor

Sediment (freshwater)

Hazard assessment conclusion:

PNEC sediment (freshwater)

PNEC value:

6.5 mg/kg sediment dw

Assessment factor:

1

Extrapolation method:

equilibrium partitioning method

Sediment (marine water)

Hazard assessment conclusion:

PNEC sediment (marine water)

PNEC value:

0.65 mg/kg sediment dw

Assessment factor:

1

Extrapolation method:

equilibrium partitioning method

Hazard for air

Air

Hazard assessment conclusion:

no hazard identified

Hazard for terrestrial organisms

Soil

Hazard assessment conclusion:

PNEC soil

PNEC value:

5 mg/kg soil dw

Assessment factor:

100

Extrapolation method:

assessment factor

Hazard for predators

Secondary poisoning

Hazard assessment conclusion:

PNEC oral

PNEC value:

0.089 mg/kg food

Assessment factor:

90

Additional information

The new tests for oleyl and tallow based ethoxylated diamine have been performed for algae according to OECD TG 201, for daphnia according to OECD TG 211 and for Micro-organisms according to OECD TG 209. Old data have been used for the fish and acute daphnia endpoints. The new data for algae and daphnia were generated using natural river water as test medium and the old data were generated using the standard OECD test media.

The results as observed for algae according to OECD TG 201, for daphnia according to OECD TG 211 and for Micro-organisms according to OECD TG 209 for both the oleyl and tallow based ethoxylated diamine are used to support the read across of fish, acute daphnia, long-term earthworm and ready biodegradability results from the source chemical tallow based ethoxylated diamine to the target chemical oleyl based ethoxylated diamine. The two ethoxylated diamines under consideration consist of carbon, hydrogen, oxygen and nitrogen only. The basic structure includes a hydrocarbon chain with an 3EO ethoxylated 1,3 -propanediamine group at the end of the chain. The main difference consists of differing chain lengths (C_{12 -18}) and slight variations in the degree of saturation in the alkyl chain. The available ecotox data reveal a comparable toxicity independent of the alkyl chain length. Therefore a read-across approach is considered justified. An overview of the most relevant results for both the oleyl and tallow based ethoxylated diamine is presented in the table below.

	Oleyl based ethoxylated diamine  CAS number: 1268344-02-0	Tallow based ethoxylated diamine CAS number: 1290049-56-7
Fish OECD TG 201		96h-LC50 = 0.13 mg/L, OECD water 96h-LC50 = 0.17 mg/L, OECD water
Daphnia magna OECD TG 202	21d-EC50 = 421 µg/L, river water	48h-EC50 = 0.31 mg/L, OECD water  21d-EC50 = 421 µg/L, river water
Daphnia magna OECD TG 211	21d-EC50 = 421 µg/L, river water 21d-ErC10 = 91.3 µg/L, river water 21d NOEC = 270 µg/L, river water	21d-EC50 = 240 µg/L, river water 21d-ErC10 = 200 µg/L, river water 21d NOEC = 270 µg/L, river water
Pseudokirchneriella subcapitata OECD TG 201	72h-ErC50 = 256 µg/L, river water 72h-ErC10 = 86.3 µg/L, river water	72h-ErC50 = 160 µg/L, river water 72h-ErC10 = 100 µg/L, river water
Microorganisms OECD TG 209	3h-EC50 = 56 mg/L 3h-EC10 = 14 mg/L	3h-EC50 = 56 mg/L 3h-EC10 = 16 mg/L
Earthworm OECD TG 222		56d-NOEC = 500 mg/kg dw
Ready biodegradability OECD 301		Readily biodegradable

 

All endpoints are based on measured data or on read across from structurally related substances, applying assessment factors.

Based on the results observed for the algae, long-term daphnia and sludge inhibition tests, no additional assessment factors are considered necessary for the read-across from the acute fish, daphnia and earthworm tests from the source chemical tallow based ethoxylated diamine to the target chemical oleyl based ethoxylated diamine.

The PNEC_{aquatic bulk} is calculated using the assessment factor proposed by the TGD. As long-term NOECs from species representing two trophic levels are available (algae and daphnia) an assessment factor of 50 may be used. Based on the observed comparable or lower toxicity to fish for diamine ethoxylates it is considered unlikely that fish toxicity will be critical for diamine ethoxylates. Hence any additional toxicity testing with fish will not add scientific value to the ecotoxicity profile of the diamine ethoxylates other than for obtaining a lower assessment factor. It is therefore concluded that for scientific reasons and in accordance to REACH legislation further testing on fish has to be avoided for reasons of animal welfare. This means that it is proposed to waive the long term fish test unless a further refinement of the effect assessment is considered necessary based on the outcome of the chemical safety assessment.For diamine ethoxylates a safety factor of 50 is applied for the derivation of the PNEC_{aquatic, bulk}

Conclusion on classification

General discusssion

For classification purposes Ecotoxicity, Biodegradability and Bioconcentration have to be considered

Ecotoxicity

Due to intrinsic properties of amine containing cationic surfactants river water ecotoxicity tests deliver reproducible test results with limited uncertainty. As river water has a mitigating effect on ecotoxicity due to sorption of the amines to DOC and suspended matter a factor of 10 should be applied to the L(E)C_xto correct for the lower ecotoxicity observed. Algae are in general the most sensitive species and are therefore for most of the ethoxylated alkyl-1,3-diaminopropanes basis for classification. It should be noted that the 21 day daphnia EC₅₀(parental mortality) is included in the table below for classification purposes as a worst-case instead of the acute EC₅₀values. The lowest chronic NOEC/EC₁₀for oleyl/tallow based ethoxylated diamine is 86.3 µg/L (72h algae test with the oleyl based ethoxylated diamine (CAS no:1268344-02-0) in riverwater). Correcting this value for mitigation with the realistic worst-case correction factor of 10 leads to NOEC/EC10 for classification of 8.6 µg/L.

 

Available river water EC50 data algae and chronic daphnia used for classification

Ethoxylated alkyl-1,3-diaminopropanes	CAS number	72 h algae ERC50(µg/L)	21 d daphnia EC50 (µg/L)	EC50corr(µg/L) (corrected for Classification with Factor 10)
Amines, N-(C18 unsaturated, alkyl) trimethylenedi-, ethoxylated (NLP)	1268344-02-0	256	421	25.6
Amines, N-(C16-18 (even numbered) and C18-unsatd. alkyl) trimethylenedi-, ethoxylated(NLP)	1290049-56-7	160	240	16

 

 

Available river water EC10/NOEC data algae and chronic daphnia used for classification

Ethoxylated alkyl-1,3-diaminopropanes	CAS number	72 h algae ERC10(µg/L)	21 d daphnia EC10 (µg/L)	EC10corr(µg/L) (corrected for Classification with Factor 10)
Amines, N-(C18 unsaturated, alkyl) trimethylenedi-, ethoxylated (NLP)	1268344-02-0	86.3	91.3	8.6
Amines, N-(C16-18 (even numbered) and C18-unsatd. alkyl) trimethylenedi-, ethoxylated(NLP)	1290049-56-7	100	200	10

  

Biodegradability

Based on the available studies on biodegradation, the substances are classified to be readily biodegradable. The 10-days-window criteriondoes not need to be evaluated for the cationic surfactants under consideration as they are UVCB substances.

 

Bioconcentration factor

No measured BCF for fish is available. Standard OECD 305 tests are technically not feasible with the strongly sorbing easily biodegradable substances. The log Kow values provided in the dossier are however acceptable. The BCF was therefore calculated using the BCFBAF v3.0 estimation program as included in EPIweb v4.0. In addition based on information of kinetics in mammals and for n-hexadecyl amine in fish and the general properties of surfactants, a high bioaccumulation potential is not expected.

 

Measured log Kow values for ethoxylated alkyl-1,3,diaminopropane technical products and the calculated log BCF based on the measured log Kow.

Alkyl-1,3-diaminopropanes	CAS number	Slow stirring  log Kow	Calculated Log Kow (EPIsuite)	Calculated Log BCF (EPIsuite)
Amines, N-(C18 unsaturated, alkyl) trimethylenedi-, ethoxylated (NLP)	1268344-02-0	2.8	5.85	2.15
Amines, N-(C16-18 (even numbered) and C18-unsatd. alkyl) trimethylenedi-, ethoxylated(NLP)	1290049-56-7	2.8	6.06	2.29

  Figures presented in Bold are based on read across.

 

The observed log Kow of 2.8 determined at a pH between 5 and 6 indicates that this substance has a low bioaccumulation potential.Despite the fact that the log Kow is measured applying the most appropriate method according to the REACH guidance i.e. the slow stirring method (OECD 123) there is no reliable relationship between the measured log Kow and BCF for this type of substances. The predicted low bioaccumulation potential is however supported by the low acute to chronic ratio observed in the long-term daphnia test.

The daphnia reproduction test result for the Oleyl based ethoxylated diamine (1268344-02-0) shows that at 810 μg/L all parental daphnids were immobile within two days, without reproduction, while at the next concentration of 270 µg/L not only is there no immobilization till day 20, but there is no detrimental effect on reproduction when compared to the control. These observations results in the derivation of a NOEC of 270 µg/L for reproduction, resulting in a low acute-to-chronic ratio. A low acute-to-chronic ratio is indicative of a non-specific mode of action and is often associated with not systemic effects. This observation is consistent with the known effects of cationic surfactants on aquatic organisms, where toxicity is associated with physical binding to respiratory membranes. This explains the steep concentration curves seen and the lack of intermediate chronic effects on reproduction.

Finally is the substance readily biodegradable and will sorb strongly to soil, sediment and dissolved organic carbon. The substance will therefore either be sorbed or degraded and there will be no long-term aquatic exposure. 

 

 

        Classification according to DSD (Dangerous Substance Directive 67/548/)

As all acute ecotoxicity values are below 1 mg/L it is proposed to classify asR50.

Ethoxylated alkyl-1,3-diaminopropanes are readily biodegradable. The measured log Kow <3 and calculated BCF <100 L/kg which means that anR53does not need to be assigned.

This leads to the following environmental classification according DSD for both Oleyl and tallow based ethoxylated diamine.

 N, R50

 

Classification according to CLP (Classification, Labeling & Packaging Directive 1272/2008/EC)

As all acute ecotoxicity values are below 1 mg/L, the ethoxylated diamines are ‘readily biodegradable’ and have a low bioaccumulation potential based on the measured log Kow values and low acute to chronic ratio, the environmental classification both Oleyl and tallow based ethoxylated diamine is:

 

Acute (short-term) aquatic hazard Acute Category 1

 

The corresponding M-factor is 10 based on the EC50 of 16 µg/L (72h algae riverwater test for the tallow based ethoxylated diamine (1290049-56-7) of 160 µg/L corrected with factor of 10)

 

When chronic toxicity data are available these should be used for classification for chronic aquatic hazard. Considering the comparable sensitivity of fish, the ready biodegradability and low bioaccumulation potential of the substance it is considered justified to use the long-term daphnia and algae test results for the chronic classification. Tallow based ethoxylated diamine (1290049-56-7) is readily biodegradable and the lowest NOEC/EC10 is 86.3 µg/L (72h algae test in riverwater). Correcting this value for mitigation with the realistic worst-case correction factor of 10 leads to NOEC/EC10 for classification of 8.6 µg/L. The substance should be classified with:

Chronic(Long-term) aquatic hazard Chronic Category 1

 

The corresponding M-factor is 1 based on the NOEC/EC₁₀of 8.6 ug/L (72h algae riverwater test of 86.3 µg/L corrected with factor of 10)