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Effects seen in the reliable aquatic (marine) invertebrate test conducted with HEBMP are slightly more severe than for most analogous aminomethylene phosphonates. A reliable existing short-term fish study confirms that fish were less sensitive than invertebrates.

Fish: 96-hour LC50 >300 mg/l - >600 mg active acid/l, Cyprinodon variegatus.

Invertebrates: 48-hour EC50 value of 64 mg active acid/l, Acartia tonsa.

Algae: 72 h EC50 and NOEC of 46 and 10 mg active acid/l, respectively, Pseudokirchneriella subcapitata.

No existing long-term aquatic data are available therefore a 21-day Daphnia reproduction study is currently ongoing. The results are expected to be available in time for the ECHA decision deadline of 13th December 2021 (ECHA decision number:CCH-D-2114493149-38-01/F).

It is known that a structural moiety of the cyclised constituent is analogous to some biologically important chemicals: c-HEBMP has a superficial resemblance to the components of phospholipids phosphoethanolamine, phosphocholine and phosphoserine. These latter materials are vital cell components and it is suggested that if c-HEBMP interferes with steps in their biosynthesis or action that this may lead to toxic effects.

In the REACH chemical safety assessment the assumption is therefore made that the cyclic constituent of the test substance is the cause of the toxic effects seen in aquatic invertebrates. The proportion of cyclic constituent of the salt present in the test is not known but would likely have been approximately 50% w/w of the test material. The PNEC is therefore derived on this basis from the most sensitive result (toxicity to algae). Hazard assessment should be conducted bearing in mind the whole substance as supplied and the available test results used a representative substance.

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