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Biodegradation in water and sediment: simulation tests

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The performance of simulation tests for biodegradation in water and sediment is scientifically unjustified.
Regulation (EC) No 1907/2006 (REACH), Annex IX, Sect. and Sect., Col. 2, states as follows:
“ The study need not to be conducted:
– the substances is highly insoluble in water; or
– the substance is readily biodegradable.
- if the substance is readily biodegradable; or
– if direct and indirect exposure of sediment is unlikely."
The test substance is practically insoluble in water. In addition, low exposure is guaranteed, as no sludge application from STP on soil will be done and aerial deposition is negligible. Thus, simulation testing for biodegradation in water and sediment was considered not scientifically justified.

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