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Sediment toxicity

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Waiver:
The performance of long-term toxicity testing to sediment dwellers is scientifically unjustified.
REACh Regulation No. 1907/2006, Annex IX, Sect. 9.2.1.4, Col. 2, states as follows:
“9.2.1.4: The study need not to be conducted:
- if the substance is readily biodegradable, or
- if direct and indirect exposure of sediment is unlikely.”
Direct and indirect exposure of sediment is highly unlikely, as: 4,4-sulphonyldiphenol is manufactured and used in completely closed systems. Furthermore, 4,4-sulphonyldiphenol is not coming into contact with final consumers, because substance is chemical bounding completely during industrial polymerisation process.
Therefore, the direct and indirect release of 4,4-sulphonyldiphenol into sediment is practically negligible.
In summary, direct and indirect exposure of soil compartment to 4,4-sulphonyldiphenol is unlikely and thus, toxicity testing on sediment dwellers is scientifically unjustified.

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