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Long-term toxicity to aquatic invertebrates

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Reference
Endpoint:
long-term toxicity to aquatic invertebrates
Data waiving:
other justification
Justification for data waiving:
other:

Description of key information

TODI as such is hardly soluble in water (See IUCLID section 4.6., water solubility), therefore Dimethylformamide was used as auxiliary solvent / dispersant in the acute toxicity fish test.
Moreover, TODI showed to be highly unstable in aqueous media, with hydrolysis occurring virtually instantaneously on contact with water and the degradation product was found to be insoluble in organic and aqueous solvents. (See IUCLID section 6.1.3, short-term toxicity to aquatic invertebrate).
That means that the acute toxicity test in fish represents already a worst case as the solubility in water was increased by an auxiliary solvent and a chronic exposure to the TODI, respectively to its degradation product is negligible due to the insolubility of both if no auxiliary solvent is used. Furthermore, the hydrolysis product is not expected to bioaccumulate (experimentally determined BCF value for TODA < 83). Consequently a long-term fish study is not justified.

 

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