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Long-term toxicity to fish

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Description of key information

The chemical safety assessment carried out according to Annex I of Regulation (EC) No 1907/2006 does not indicate the need to investigate further the long-term toxicity to fish. 

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The chemical safety assessment carried out according to Annex I of Regulation (EC) No 1907/2006 does not indicate the need to investigate further the long-term toxicity to fish.

There is no long-term test on fish available for 1,2,4-Benzenetricarboxylic acid, tri-C9-11-alkyl esters (CAS No. 94279-36-4 The chemical safety assessment according to Annex I of Regulation (EC) No 1907/2006 does not indicate the need to investigate further the long-term toxicity to fish. Thus, in accordance to Annex IX, column 2 no further long-term toxicity test to fish is proposed. Available short-term studies for fish, daphnia and algae conducted with a structurally similar category member (1,2,4-Benzenetricarboxylic acid, mixed decyl and octyl triesters (CAS No. 90218-76-1)), indicate no potential for aquatic toxicity (no effects up to the limit of the water solubility). Moreover, the long-term NOEC values obtained from algal growth and aquatic invertebrates studies performed with the structurally similar category member are clearly above the limit of water solubility (< 0.05 mg/L).  

Based on the short-term values, fish cannot be identified as the most sensitive taxonomic group. According to the “Guidance on information requirements and chemical safety assessment Chapter R.7b: Endpoint specific guidance, R.7.8.5.3” (ECHA, 2012), long-term testing of fish should only be conducted if it represents the most sensitive taxonomic group. The Guidance states that if invertebrates are likely to be more sensitive than fish and algae or the relative sensitivity of invertebrates cannot be predicted, long-term testing on Daphnia sp. should be preferred instead of fish.

Due to its enhanced ultimate biodegradability it is not likely that aquatic organisms will be exposed to 1,2,4-Benzenetricarboxylic acid, tri-C9-11-alkyl esters since it will be ultimately degraded in sewage treatment plants and only low concentrations (if any) will be released into the environment, where further biodegradation can be expected. Based on all the above mentioned information, it is unlikely that the substance will exhibit chronic toxicity to fish up to the limit of water solubility. Hence, based on this information and due to animal welfare reasons, no further long-term test with fish is proposed.