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Based on the use pattern for this substance, direct and indirect exposure of soil is unlikely. Level 3 fugacity modelling with realistic mass flow inputs indicate that soil concentrations would be approximately 30 -70% of those found in water. In reality, less than this would partition as the substance is readily biodegradable. In addition the equilibrium partitioning method is sufficient to estimate the toxicity to soil micro-organisms based using the existing aquatic toxicity hazard data as a starting point. On the basis that exposure is lower than in water, toxicity can be estimated from existing aquatic toxicity data and good mammalian toxicity information when available. No testing for terrestrial toxicity is therefore justified.