Reaction products of diphosphorus pentaoxide and alcohol C7-9-iso, C8 rich, salted with 2-ethylhexylamine

Endpoint summary

Description of key information

In the key study, conducted with the target substance, the microscopic changes were limited to in α2μ-globulin nephropathy in the males at 500 mg/kg/day (α2μ-globulin nephropathy), which is not relevant for human risk assessment. Therefore, a NOAEL for general toxicity was considered to be 500 mg/kg/day, the highest dose level tested. In the supporting study, conducted with the read across substance, the administration of test material to rats by gavage resulted in toxicologically significant changes at 500 mg/kg bw. The effects at the mid dose level, 150 mg/kg/day, were confined to minimal adaptive morphological changes in the liver of one animal and were considered not to represent an adverse health effect. The findings in kidneys of male rats at this dose level are male species specific findings related to "hydrocarbon nephropathy" (the same as in the key study) and are not relevant to humans. Therefore, NOAEL of 150 mg/kg bw is considered.

Key value for chemical safety assessment

Repeated dose toxicity: via oral route - systemic effects

Link to relevant study records

Reference

Endpoint:

short-term repeated dose toxicity: oral

Type of information:

experimental study

Adequacy of study:

key study

Study period:

2012-11-08 to 2013-01-20

Reliability:

1 (reliable without restriction)

Rationale for reliability incl. deficiencies:

other: GLP guideline study.

Reason / purpose for cross-reference:

reference to same study

Qualifier:

according to guideline

Guideline:

other: OECD Guideline 421, Reproduction/Developmental Toxicity Screening Test

Deviations:

no

GLP compliance:

yes

Limit test:

no

Species:

rat

Strain:

other: CD® [Crl:CD®(SD)]

Sex:

male/female

Details on test animals or test system and environmental conditions:

TEST ANIMALS
- Source: Charles River Laboratories, Raleigh, North Carolina
- Age at study initiation: (P) x 8 wks
- Weight at study initiation: (P) Males: 285 to 316 g; Females: 191 to 222 g
- Fasting period before study: no
- Housing: individually in suspended, stainless steel, wire-mesh type cages except during pairing, near parturition, and during lactation in an environmentally controlled room. During pairing, the animals were randomly cohabitated (one male and one female from the same group) in the cage of the male. On approximately GD 20, P females were individually housed in plastic solid bottom cages containing wood chip bedding. Females were housed in these solid bottom cages with pups during the 4-day lactation period.

- Diet (e.g. ad libitum): Meal Lab Diet (Certified Rodent Diet #5002, PMI Nutrition International, Inc.), ad libitum.
- Water (e.g. ad libitum): Tap water (ad libitum)
- Acclimation period: 8 days. On Days -3 and -2, all animals were administered a sham dose of tap water in the same manner and at the same volume intended for use during the study period.

ENVIRONMENTAL CONDITIONS
- Temperature: 68 to 79 °F
- Humidity (%): 30 to 70
- Air changes (per hr): not reported
- Photoperiod (hrs dark / hrs light): 12/12

Route of administration:

oral: gavage

Vehicle:

peanut oil

Remarks:

FN

Details on oral exposure:

PREPARATION OF DOSING SOLUTIONS:
The test article was used as received from the Sponsor. No adjustment was made for purity when preparing the test article formulations. Formulations of the test article were prepared as needed at nominal concentrations of 50, 75, 150, and 250 mg/mL, and were stored at room temperature.

VEHICLE
Peanut oil (arachis oil NF)
- Justification for use and choice of vehicle (if other than water): test article is well soluble in peanut oil
- Concentration in vehicle: 50, 75, 150, and 250 mg/mL
- Amount of vehicle (if gavage): 1 mL/kg/dose for the 50 mg/kg/day group, or 2 mL/kg/dose for all other groups.
- Lot/batch no. (if required): 2BH0270

Analytical verification of doses or concentrations:

yes

Details on analytical verification of doses or concentrations:

Dosing formulations prepared for the study were evaluated for homogeneity and concentration by GC (on week 1, 5 and 8). Homogeneity analyses have been performed on sampled dose level of 50 and 500 mg/kg bw. Concentration analyses have been performed on formulations of all dose levels.
Stability has been established under Test facility for the concentration range of 20 to 300 mg/mL for at least 5 days under room temperature storage. A total of 102 samples were analyzed for the test material in dosing formulations using a validated method. The analytical data demonstrated acceptable performance of the method for all reported results.

Duration of treatment / exposure:

Dosing began 14 days prior to pairing. Dosing of the males continued through the mating and postmating period to euthanasia (43 days total), while dosing of the females continued through LD 3.

Frequency of treatment:

once daily

Remarks:

Doses / Concentrations:
0, 50, 150, 300 and 500 mg/kg bw
Basis:
actual ingested

No. of animals per sex per dose:

12

Control animals:

yes, concurrent vehicle

Details on study design:

- Dose selection rationale: An Oral Pilot Reproduction/Developmental Toxicity Screening Study in Rats (study No. 1928-009)
The dose levels were selected by the Sponsor on the basis of available data from previous studies (OECD 407 28-day oral gavage toxicity study in the Sprague-Dawley Crl:CD BR rat) with the compound. In this study, dose levels of 15, 150, 300 and 500 mg/kg/day were previously tested at a dose volume of 2 mL/kg in arachis BP oil. Treatment-related changes were observed at 500 mg/kg/day (clinical observations, body weight, food consumption, and organ weight changes) and at 150 mg/kg/day (only organ weight changes), and no such effects were demonstrated in animals treated with 15 mg/kg/day. A maximum dose level of 500 mg/kg/day was selected as the high dose to show some morbidity and for comparison to the previous study, and a low dose level of 50 mg/kg/day was selected as the potential no effect level. The 150 and 300 mg/kg/day dose levels were selected as intermediate doses to provide additional information between the low and high-dose groups.

- Rationale for animal assignment (if not random): randomized.

Positive control:

None.

Observations and examinations performed and frequency:

CAGE SIDE OBSERVATIONS: Yes
- Time schedule: All animals were observed for morbidity, mortality, injury, and the availability of food and water twice daily.


DETAILED CLINICAL OBSERVATIONS: Yes
- Time schedule: All animals were given a detailed clinical examination and body weights were recorded on Days -8 and -1 (the results are not reported but maintained in the study file). Daily during the study (1-2 hours postdose), each P animal was removed from the cage and given a detailed clinical examination. On occasion, clinical observations were recorded at unscheduled intervals. The observations included, but were not limited to, evaluation of the skin, fur, eyes, ears, nose, oral cavity, thorax, abdomen, external genitalia, limbs and feet, as well as evaluation of respiration.

BODY WEIGHT: Yes
- Time schedule for examinations: Individual body weights were recorded for all P animals weekly. Mated females were also weighed on GD 0, 7, 14, and 20, and LD 0 and 4. Body weight change was calculated weekly for the males, and for the females over the following intervals: weekly (premating),
GD 0-7, 7-14, 14-20, and 0-20, and LD 0-4.

FOOD CONSUMPTION AND COMPOUND INTAKE (if feeding study): no
Food consumption for all P animals was recorded weekly prior to pairing for mating. During the first 14 days of the pairing period, food consumption was not recorded for any animals. Food consumption was recorded on the corresponding gestation and lactation body weight days for mated females.

WATER CONSUMPTION AND COMPOUND INTAKE (if drinking water study): No

OTHER:
Dams were housed with their litters for four days after birth (LD 0 to 4). The dams and litters were observed daily for survival and behavioral alterations in nesting and nursing, and the presence of dead pups was recorded.

Sacrifice and pathology:

SACRIFICE
- Male animals: At the termination of the study (Day 44) all P males were observed externally, euthanized, and subjected to a necropsy.
- Maternal animals: On LD 4, all surviving P females were euthanized and subjected to a necropsy, and the number of uterine implantation scars and corpora lutea were recorded.


GROSS NECROPSY
- Gross necropsy consisted of external and internal examinations including the cervical, thoracic, cranial and abdominal viscera.

The animals were examined carefully for external abnormalities including palpable masses. The skin was reflected from a ventral midline incision and any subcutaneous masses were identified and correlated with antemortem findings. The abdominal, thoracic, and cranial cavities were examined for abnormalities. The organs were removed, examined, and, where required, placed in fixative. All designated tissues were fixed in neutral buffered
formalin, except for the testes, which were fixed using a modified Davidson’s fixative. The epididymis, ovary, oviducts, prostate, seminal vesicles, testis, uterus with cervix, vagina, and gross lesions were collected from all animals.

HISTOPATHOLOGY / ORGAN WEIGHTS
Body weights and protocol-designated organ weights were recorded for all parental animals at the scheduled necropsy and appropriate organ weight ratios were calculated (relative to body weights). Paired organs were weighed together.

Microscopic examination of fixed hematoxylin and eosin-stained paraffin sections was performed on protocol-designated sections of tissues. The slides were examined by a board-certified veterinary pathologist. A four-step grading system was utilized to define gradable lesions for comparison between dose groups.

Other examinations:

Mating, fertility and fecundity indices (please refer to section 7.8.1 of the IUCLID file).

Statistics:

Please refer to "Any other information on materials and methods incl. tables".

Clinical signs:

effects observed, treatment-related

Description (incidence and severity):

post-dose salivation

Mortality:

mortality observed, treatment-related

Description (incidence):

post-dose salivation

Body weight and weight changes:

no effects observed

Description (incidence and severity):

no toxicologically meaningful changes

Food efficiency:

no effects observed

Ophthalmological findings:

not examined

Haematological findings:

not examined

Clinical biochemistry findings:

not examined

Urinalysis findings:

not examined

Behaviour (functional findings):

not examined

Organ weight findings including organ / body weight ratios:

no effects observed

Gross pathological findings:

effects observed, treatment-related

Description (incidence and severity):

findings in kidneys (males only) at 500 mg/kg bw

Histopathological findings: non-neoplastic:

effects observed, treatment-related

Description (incidence and severity):

minimal to moderate tubular degeneration/regeneration

Histopathological findings: neoplastic:

no effects observed

Details on results:

CLINICAL SIGNS AND MORTALITY (PARENTAL ANIMALS)

The most remarkable clinical finding included post-dose salivation that was seen in both male and female animals treated with the test article, which is most likely due to the taste of the test article in the vehicle at the concentrations affected. In males, this was noted in 42, 92, and 83 % of the animals at 150, 300, and 500 mg/kg/day, respectively. In females this was noted in 25 and 67 % of the animals at 300 and 500 mg/kg/day, respectively, during the premating period. During gestation, 36 % and 44 % of the females were affected with this finding at 300 and 500 mg/kg/day, respectively. However, during lactation this finding was no longer seen in the treated females at any dose level tested. This finding was considered to be test article related. Some other clinical findings were noted, but no clear dose responsive pattern was identified to indicate a relationship to treatment.

BODY WEIGHT AND FOOD CONSUMPTION (PARENTAL ANIMALS)

No test article-related changes in mean body weight were noted in male or female animals exposed to the test article at the dose levels tested (50, 150, 300, and 500 mg/kg/day) during the study period. Statistically significant decreases in mean body weight gain were limited to animals at 500 mg/kg/day. This was noted in males during Weeks 6-7 and in females during GD 0-7. Based on the lack of statistically significant changes in mean body weight or food consumption during these periods for each gender, these decreases in body weight gain were not considered toxicologically meaningful.

FOOD EFFICIENCY

Mean food consumption was unaffected by treatment with the test article at the dose levels tested. A statistically significant decrease in mean food consumption was noted in males at 150 mg/kg/day during Weeks 5-6. However, as there were no statistically significant changes at the higher dose levels, this finding was considered to be spurious in nature and not toxicologically meaningful.

ORGAN WEIGHTS (PARENTAL ANIMALS)

There were no apparent test article-related organ weight changes in males or females. Any organ weight differences were considered to be incidental and unrelated to treatment due to a low magnitude, the lack of a dose response, and/or the absence of correlative microscopic effects.

GROSS PATHOLOGY (PARENTAL ANIMALS)

500 mg/kg/day, which had mild tan discoloration in four males at 500 mg/kg/day, and of these, one male (animal number 250) also had moderate enlargement of the kidneys. These findings correlated microscopically with tubular degeneration/regeneration. All other macroscopic findings were either common background findings in rats or were considered incidental and unrelated to treatment due to the lack of a dose response, the absence of correlative microscopic effects, and/or the lack of similar findings in both sexes.

HISTOPATHOLOGY (PARENTAL ANIMALS)

Test article-related microscopic findings were present in the kidneys of males at 500 mg/kg/day, which had minimal to moderate tubular degeneration/regeneration. Tubular degeneration/regeneration was most prominent within the outer medulla and inner cortex characterized by tubules lined by swollen, hypereosinophilic epithelial cells (degeneration) associated with tubules lined by increased numbers of small, basophilic epithelial cells (regeneration). With increased severity (mild to moderate), tubular degeneration/ regeneration was also often associated with casts of cellular debris at the junction of proximal tubules and the loop of Henle. These findings are consistent with a well characterized condition described as α2μ-globulin nephropathy, which is limited to the male rat and not relevant for human risk assessment. Tubular degeneration/regeneration was distinct from chronic progressive nephropathy, which is a common background finding in the kidneys of rats at this age, and was present in one female at 500 mg/kg/day (animal number 313). The kidneys of this female also had mild bilateral hydronephrosis and minimal unilateral lymphocytic infiltration which are common background findings in rats and were considered incidental and unrelated to treatment. It should be noted that the kidneys were only examined microscopically in animals which had gross lesions. Because the kidneys were not collected at necropsy in other animals in this study (per the protocol), the kidneys were not examined in all animals. All other microscopic observations were either common background findings in rats or were considered incidental and unrelated to treatment.

OTHER:

Male and female mating, fertility and fecundity indices were unaffected in the treated animals at 50, 150, 300, and 500 mg/kg/day. No statistically significant changes in females with confirmed mating day or copulatory interval were identified in the treated animals as compared to controls.

Dose descriptor:

NOAEL

Remarks:

general toxicity

Effect level:

500 mg/kg bw/day (nominal)

Based on:

test mat.

Sex:

male/female

Basis for effect level:

other: based on microscopic changes noted in the males at 500 mg/kg/day (α2μ-globulin nephropathy), which was limited to the male rat and not relevant for human risk assessment.

Critical effects observed:

not specified

Conclusions:

Oral administration of the test substance to male and female rats at 50, 150, 300, and 500 mg/kg/day during the study period produced test article-related findings that included postdose salivation at 300 and 500 mg/kg/day (males and females), and microscopic changes in the parental males at 500 mg/kg/day (renal tubular degeneration/regeneration). With the exception of the microscopic changes noted in the males at 500 mg/kg/day (α2μ-globulin nephropathy, which was limited to the male rat and not relevant for human risk assessment), a NOAEL for general toxicity was considered to be 500 mg/kg/day.

Executive summary:

The objective of this study was to generate limited information concerning the effects of the test article on male and female reproductive performance such as gonadal function, mating behavior, conception, development of the conceptus, and parturition. This study met or exceeded Guideline 421, Reproduction/Developmental Toxicity Screening Test, the OECD Guideline for Testing of Chemicals, adopted July 1995. Four treatment groups of twelve CD® [Crl:CD®(SD)] rats/sex/group were administered the test article at dose levels of 50, 150, 300, or 500 mg/kg/day. One additional group of twelve animals/sex served as the control and received the vehicle, peanut oil (arachis oil NF). The vehicle or test article was administered to all groups daily via oral gavage at a dose volume of 1 or 2 mL/kg/dose. Dosing began 14 days prior to pairing and continued to euthanasia (43 days total) for the parental (P) males. Dosing of the females began 14 days prior to pairing, through the mating period, up to and including Lactation Day (LD) 3.

Observations of the P animals included clinical signs, body weights and body weight change, and food consumption during the premating/mating, gestation, and lactation periods, and parturition and litter data. Observations of the offspring (F1) included survival at birth and during lactation, individual clinical signs, pup body weights and sex, and gross abnormalities. At study termination, necropsy examinations were performed on all surviving P animals, and organs and tissues were collected, weighed, and examined for select groups. On LD 4, surviving F1 pups were examined externally, euthanized, and discarded.

The formulation analysis verified a lack of test article in the control samples. The results from the analytical evaluation from the Week 1 test article preparations showed lower than expected values at all concentrations, particularly at the lower dose levels, which triggered an investigation and resulted in a change in the mixing procedures. The two higher concentrations (150 and 250 mg/mL) were acceptable for Weeks 2 and forward. By Week 4, all the values were within the acceptance criteria, except for the 50 mg/mL concentration that was just barely outside. Homogeneity evaluation and concentration verification were repeated on Week 5 and all values passed the acceptance criteria established. Therefore, animals at the two higher dose levels received the targeted concentrations of the test article starting on Week 2 for the remainder of the intervals evaluated. The animals receiving the two lower concentrations (50 and 150 mg/mL) had slightly lower exposures during the first three weeks, but by Week 4 the concentrations for all treatment groups approached the nominal concentrations. By Week 5, all treated animals received the targeted concentrations of the test article.

Oral administration of the test article to male and female rats at 50, 150, 300, and 500 mg/kg/day during the study period produced test article-related findings that included postdose salivation at 300 and 500 mg/kg/day (males and females) and microscopic changes in the parental males at 500 mg/kg/day (renal tubular degeneration/regeneration). All paternal animals survived to scheduled necropsy without significant test article-related effects on body weight, food consumption, or remaining uterine or reproductive parameters evaluated, including fertility, mating and fecundity indices. F1 survival was unaffected by treatment.

Based on the results obtained from this oral reproductive/developmental toxicity screening study in rats, a No-Observed-Adverse-Effect-Level (NOAEL) for developmental toxicity was considered to be 500 mg/kg/day, based on a lack of toxicologically meaningful changes in the treated pups at the dose levels tested. As there were no significant changes in fertility, mating, and fecundity indices, a NOAEL for reproductive performance was considered to be 500 mg/kg/day. With the exception of the microscopic changes noted in the males at 500 mg/kg/day (α2μ-globulin nephropathy, which is limited to the male rat and not relevant for human risk assessment), a NOAEL for general toxicity was considered to be 500 mg/kg/day.

Endpoint conclusion

Endpoint conclusion:

no adverse effect observed

Dose descriptor:

NOAEL

500 mg/kg bw/day

Study duration:

subacute

Species:

rat

Quality of whole database:

The key study is GLP compliant and of high quality (Klimisch score = 1).

Additional information

Reproduction/Developmental Screening Test (OECD 421)

The key Reproduction/Developmental Screening Test (OECD 421), which evaluated reproductive parameters such as gonadal function, mating behavior, conception, development of the conceptus, and parturition provide sufficient information about systemic toxicity of the target substance (Reaction products of diphosphorus pentaoxide and alcohol C7-9-iso, C8 rich, salted with 2-ethylhexylamine) (Thorsrud, 2013, Report No. 1928-010). Four treatment groups of twelve CD® [Crl: CD®(SD) ] rats/sex/group were administered the test article at dose levels of 50, 150, 300 or 500 mg/kg/day. One additional group of twelve animals/sex served as the control and received the vehicle, peanut oil (arachis oil NF). The vehicle or test article was administered to all groups daily via oral gavage at a dose volume of 1 or 2 mL/kg/dose. Dosing began 14 days prior to pairing and continued to euthanasia (43 days total) for the parental (P) males. Dosing of the females began 14 days prior to pairing, through the mating period, up to and including Lactation Day (LD) 3.

Observations of the P animals included clinical signs, body weights and body weight change, and food consumption during the premating/mating, gestation, and lactation periods, and parturition and litter data. Observations of the offspring (F1) included survival at birth and during lactation, individual clinical signs, pup body weights and sex, and gross abnormalities. At study termination, necropsy examinations were performed on all surviving P animals, and organs and tissues were collected, weighed, and examined for select groups. On LD 4, surviving F1 pups were examined externally, euthanized, and discarded.

Oral administration of the test article to male and female rats at 50, 150, 300, and 500 mg/kg/day during the study period produced test article-related findings that included postdose salivation at 300 and 500 mg/kg/day (males and females) and microscopic changes in the parental males at 500 mg/kg/day (renal tubular degeneration/regeneration). Test article-related macroscopic findings were present in the kidneys of males at 500 mg/kg/day, which had mild tan discoloration in four males at 500 mg/kg/day, and of these, one male (animal number 250) also had moderate enlargement of the kidneys. These findings correlated microscopically with tubular degeneration/regeneration which was most prominent within the outer medulla and inner cortex characterized by tubules lined by swollen, hypereosinophilic epithelial cells (degeneration) associated with tubules lined by increased numbers of small, basophilic epithelial cells (regeneration). With increased severity (mild to moderate), tubular degeneration/ regeneration was also often associated with casts of cellular debris at the junction of proximal tubules and the loop of Henle. These findings are consistent with a well characterized condition described as α2μ-globulin nephropathy, which is limited to the male rat and not relevant for human risk assessment. Tubular degeneration/regeneration was distinct from chronic progressive nephropathy, which is a common background finding in the kidneys of rats at this age, and was present in one female at 500 mg/kg/day. The kidneys of this female also had mild bilateral hydronephrosis and minimal unilateral lymphocytic infiltration which are common background findings in rats and were considered incidental and unrelated to treatment.

All paternal animals survived to scheduled necropsy without significant test article-related effects on body weight, food consumption, or remaining uterine or reproductive parameters evaluated, including fertility, mating and fecundity indices. F1 survival was unaffected by treatment.

Based on the results obtained from this oral reproductive/developmental toxicity screening study in rats, a NOAEL for general toxicity was considered to be 500 mg/kg bw. Microscopic changes (α2μ-globulin nephropathy) noted in the males at 500 mg/kg bw were limited to the male rat and are not relevant for human risk assessment.

NOAEL for developmental toxicity was considered to be 500 mg/kg/day, based on a lack of toxicologically meaningful changes in the treated pups at the dose levels tested. As there were no significant changes in fertility, mating, and fecundity indices, a NOAEL for reproductive performance was considered to be 500 mg/kg/day.

28 -Day study in rats

In a supporting 28 -day study in rats, the systemic toxicity of the read-across substance was investigated (Jones et al., 1999, Project No. 525/130). The test material was administered by gavage to three groups, each of five male and five female Sprague-Dawley Crl:CD@BR strain rats, for twenty-eight consecutive days, at dose levels of 15, 150 and 500 mg/kg/day. A control group of five males and five females was dosed with vehicle alone (Arachis oil BP). Clinical signs, functional observations, body weight development and food and water consumption were monitored during the study. Haematology and blood chemistry were evaluated for all animals at the end of the study. All animals were subjected to a gross necropsy examination and histopathological evaluation of selected tissues was performed.The administration of the test article by oral gavage for a period of twenty-eight consecutive days resulted in toxicologically significant changes at 500 mg/kg/day. Clinically observable signs at 500 mg/kg/day were confined to commonly reported increased salivation after dosing, together with associated fur wetting and staining, probably associated with an unpalatable or slightly irritant test material. One female from this treatment group however, showed additional observations of hunched posture and noisy respiration from Day 13, supported by the open-field observations over the respective study period. Bodyweight development was adversely affected during Week 1 and bodyweight gain for the adversely affected female remained reduced during the second week of treatment. Food efficiency was also impaired but this was confined to Week 1. Blood chemical investigations revealed an increase in plasma alanine aminotransferase (ALAT) for 500 mg/kg/day females which suggests an adverse effect on the liver. Absolute and relative liver weights were substantially elevated for 500 mg/kg/day animals and microscopic examination of liver sections revealed changes identified as centrilobular hepatocyte enlargement. This morphological change is often seen in the rodent liver following treatment with xenobiotics and, in the absence of any associated degenerative or inflammatory changes, is considered to be adaptive in nature. The increase in levels of ALAT, a plasma enzyme of hepatic origin, however, suggests a change in hepatocellular integrity which could be regarded as toxicologically important. No such effects were noted in animals treated with 150 or 15 mg/kg/day. At 150 mg/kg/day one male only showed hepatocyte enlargement but this was assessed as minimal. Liver weight was slightly elevated but, in the absence of any blood chemical changes, this was considered to be an entirely adaptive response, not representing an adverse effect on the health of the animals treated at this dose level. The remaining treatment-related effects were confined to male rat specific kidney changes. Kidney weights were elevated for both 500 and 150 mg/kg/day males and microscopic examination of kidney sections revealed globular accumulations of eosinophilic material in the renal proximal tubular epithelium for two animals at the highest dose level. This is a well-documented effect peculiar to the male rat and occurs in response to treatment with some hydrocarbons. Female rats and other laboratory animals do not develop "hydrocarbon nephropathy" (Alden, 1986). Such a change would, therefore, not occur in humans and, as such, these renal effects in two animals are considered not to represent a hazard to human health. There were no treatment-related changes detected at 15 mg/kg/day.Oral administration of the test material to rats for a period of twenty eight consecutive days at dose levels of up to 500 mg/kg/day, resulted in treatment-related changes at 500 and 150 mg/kg/day. No such effects were demonstrated in animals treated with 15 mg/kg/day and the "No Observed Effect Level" (NOEL) was, therefore, considered to be 15 mg/kg/day. The effects at 150 mg/kg/day however, were confined to minimal adaptive morphological changes in the liver of one animal and were considered not to represent an adverse health effect as defined in the criteria given in the EC labelling guide of Commission Directive 93/21/EEC. Therefore, NOAEL for both sexes was considered to be 150 mg/kg bw.

Justification for selection of repeated dose toxicity via oral route - systemic effects endpoint:
The OECD 421 study is the study with the longest duration available. Moreover, it is conducted with the target substance.

Justification for classification or non-classification

The target substance (Reaction products of diphosphorus pentaoxide and alcohol C7-9-iso, C8 rich, salted with 2-ethylhexylamine) did not cause relevant significant toxicological effects after repeated oral exposure at the highest dose level tested. Therefore, it does not meet the criteria for classification and will not require labelling, according to the European Regulation (EC) No. 1272/2008.