[nitrilotris(methylene)]trisphosphonic acid, ammonium salt

Toxicity to soil microorganisms

Link to relevant study record(s)

Reference

Endpoint:

toxicity to soil microorganisms

Data waiving:

other justification

Justification for data waiving:

other:

Additional information

ATMP-xNH4 will dissociate into ATMP and ammonia when it is released into soils where water is present. ATMP and ammonia will therefore be treated separately for the purposes of deriving PNECs for soils.

ATMP: In accordance with Column 2 of REACH Annex IX, there is no need to further investigate the effects of this substance in a toxicity to terrestrial microorganisms study because, as indicated in REACH guidance R7c Section R.7.11.6 (ECHA 2017), the quantitative chemical safety assessment (conducted according to Annex I of REACH) indicates that the Risk Characterisation Ratio is below 1, therefore the risk is already adequately controlled and further testing is not justifiable. The substance is involatile and highly adsorbing and low toxicity was observed in short-term terrestrial tests and short- and long-term aquatic tests; therefore, there is no reason to expect effects in the terrestrial compartment that were not expressed in the aquatic compartment. While aquatic microorganisms effect data are not taken into account in deriving the freshwater PNEC value, it is notable that the data on microorganisms indicate a lack of effects up to 200 mg/l, which is 8.7 times higher than the long-term fish NOEC of 23 mg active acid/L. Based on the short-term aquatic data set, the most sensitive trophic level is algae and according long-term aquatic data set, the most sensitive trophic level is fish.  The soil hazard category 3 (ECHA 2017, guidance part R7(c) table R.7.11-2) has been derived for the category. According to the screening assessment for soil hazard category 3, the PNECsoil has been calculated measured long-term toxicity to soil macroorganism data. The risk characterisation ratio (RCR) based on PNECsoil derived from the measured data is <1 and hence no further toxicity testing of soil organisms is currently considered to be necessary. The phosphonate ligand binds strongly and irreversibly to various minerals present in soil and so bioavailability to soil organisms is extremely limited. Details on how the PNEC and the risk characterisation ratio have been derived can be found in IUCLID Section 6.0 and Chapters 9 and 10 of the Chemical Safety Report, respectively. See also the endpoint summary for additional considerations on the toxicity to micro-organisms from aquatic data.

Ammonia:

As an inorganic ion, ammonium is ubiquitous in the environment, is not bioaccumulative and is highly water soluble. It is therefore not necessary to obtain test data for setting a PNECsoil for ammonia. Therefore the RCR has been based on ATMP.