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Toxicity to soil macroorganisms except arthropods

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The performance of a test for toxicity to soil macroorganisms is scientifically not justified.
REACh Regulation No. 1907/2006, Annex IX, Sect. 9.4, Col. 2, states as follows:
“9.4: These studies need not to be conducted if direct and indirect exposure of the soil compartment is unlikely.”
Direct and indirect exposure of the soil compartment 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 soil compartment is practically negligible.
In summary, direct and indirect exposure of soil compartment to 4,4-sulphonyldiphenol is unlikely and thus, toxicity testing on terrestrial organisms is scientifically unjustified.

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