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Short-term toxicity to fish

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A study to determine the acute toxicity of tetrairon tris(pyrophosphate) to fish is not submitted for the following reasons:
In accordance with Regulation (EC) No. 1907/2006 (REACH) Annex XI, section 2 testing for a specific endpoint may be omitted if it is technically not possible to conduct the study as a consequence of the properties of the substance. Tetrairon tris(pyrophosphate) is an insoluble inorganic material and is not considered to be bioavailable in aquatic environments. This is demonstrated by the fact that iron is often added to effluents containing soluble phosphates in order to remove phosphorus (via making the phosphate insoluble) and prevent eutrophication in water bodies.
As a result of the physicochemical properties, administration of precise and consistent dose levels is not considered to be possible and as such aquatic toxicity testing is not considered to be technically possible.

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