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Classification & Labelling & PBT assessment

PBT assessment

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Administrative data

PBT assessment: overall result

PBT status:
the substance is not PBT / vPvB

Classification of 7-[[2-[(aminocarbonyl)amino]-4-[(4-amino-6-chloro-1,3,5-triazin-2-yl)amino]phenyl]azo]naphthalene-1,3,6-trisulphonic acid for effects in the environment:


The chemical 7-[[2-[(aminocarbonyl)amino]-4-[(4-amino-6-chloro-1,3,5-triazin-2-yl)amino]phenyl]azo]naphthalene-1,3,6-trisulphonic acid (CAS no. 35642-4-9) is used in as a dye for plastics and inks. The aim was to assess whether the PBT criterion within Annex XIII was fulfilled for 7-[[2-[(aminocarbonyl)amino]-4-[(4-amino-6-chloro-1,3,5-triazin-2-yl)amino]phenyl]azo]naphthalene-1,3,6-trisulphonic acid. The PBT criterion was herein assessed based on experimental data in conjunction with standardized environmental fate models. Here follows a description of the PBT assessment.



Persistence assessment

The tested substance fulfils the P criterion within Annex XIII based on the assessment that here follows:


Biotic degradation

Biodegradability of test chemical 7-[(E)-2-{4-[(4-amino-6-chloro-1,3,5-triazin-2-yl)amino]-2-(carbamoylamino)phenyl}diazen-1-yl]naphthalene-1,3,6-trisulfonic acid (CAS no. 35642 -64 -9) is predicted using OECD QSAR tool box v.3.3 using log Kow as primary descriptor. The test chemical 7-[(E)-2-{4-[(4-amino-6-chloro-1,3,5-triazin-2-yl)amino]-2-(carbamoylamino)phenyl}diazen-1-yl]naphthalene-1,3,6-trisulfonic acid undergoes 0.8571 % biodegradation by considering BOD as parameter and Microorganisms as inoculum in 28 days. On the basis value of percent biodegradability this chemical is considered as not readily biodegradable.


Another prediction done by using Estimation Programs Interface Suite (EPI suite, 2017) to estimate the biodegradation potential of the test compound 7-[(E)-2-{4-[(4-amino-6-chloro-1,3,5-triazin-2-yl)amino]-2-(carbamoylamino)phenyl}diazen-1-yl]naphthalene-1,3,6-trisulfonic acid (CAS no. 35642-64-9) in the presence of mixed populations of environmental microorganisms. The biodegradability of the substance was calculated using seven different models such as Linear Model, Non-Linear Model, Ultimate Biodegradation Timeframe, Primary Biodegradation Timeframe, MITI Linear Model, MITI Non-Linear Model and Anaerobic Model (called as Biowin 1-7, respectively) of the BIOWIN v4.10 software. The results indicate that chemical 7-[(E)-2-{4-[(4-amino-6-chloro-1,3,5-triazin-2-yl)amino]-2-(carbamoylamino)phenyl}diazen-1-yl]naphthalene-1,3,6-trisulfonic acid is expected to be not readily biodegradable.


Experimental results from the similar substances (CAS: 2611-82-7 and 6459-94-5) also indicate that they are not readily biodegradable


Environmental fate

According to the fugacity model levels III, the most likely environmental fate for this test chemical is soil (i.e.estimated to 55.9%). In soil, 7-[[2-[(aminocarbonyl)amino]-4-[(4-amino-6-chloro-1,3,5-triazin-2-yl)amino]phenyl]azo]naphthalene-1,3,6-trisulphonic acid was expected to have rapid mobility based upon a LogKOC of 0 (Koc = 1). Thehalf-life in soil (360 days estimated by EPI suite) indicates that the chemical is persistent in soil and the exposure risk to soil dwelling animals is moderate to high.


If released in to the environment, 43.3% and 0.083% of the chemical will partition into sediment and water according to the Mackay fugacity model level III in EPI suite version 4.1 (2017). However, the half-life (180 days in water and 1620.83 days in sediment as estimated by EPI suite) indicates that the substance is persistent in both the compartments.


Although the half-life values indicate the chemical to be Very persistent (vP), since only predicted data is available for the substance, it has been concluded that 7-[[2-[(aminocarbonyl)amino]-4-[(4-amino-6-chloro-1,3,5-triazin-2-yl)amino]phenyl]azo]naphthalene-1,3,6-trisulphonic acid is likely to be persistent in nature.



Bioaccumulation assessment

The tested substance does not fulfil the B criterion within Annex XIII based on the assessment that here follows:


Theestimated BCF value from authoritative database was determined to be in the range 1.0 – 3.162 and theoctanol water partition coefficient of the test chemical is -0.66 which is less than the threshold of 4.5. If this chemical is released into the aquatic environment, there should be a moderate to low risk for the chemical to bioaccumulate in fish and food chains.


Toxicity assessment

The tested substance does not fulfil the T criterion within Annex XIII based on the assessment that here follows:



The tested chemical is regarded to be not classified for carcinogenicity, mutagenicity and reprotoxicity, Further, there is no evidence of chronic toxicity, as identified by the classifications STOT (repeated exposure), category 1(oral, dermal, inhalation of gases/vapours, inhalation of dust/mist/fume) or category 2 (oral, dermal, inhalation of gases/vapours, inhalation of dust/mist/fume).


Aquatic organisms

All of the available short-term eco-toxicity estimations for fish, invertebrates and algae for the substance indicates the LC50/EC50 value to be in the range 113.58– 165.307 mg/L. These value suggest that the substance is not likely to be hazardous to Aquatic organisms at environmentally relevant concentrations and can be considered to be ‘not classified’ as per the CLP regulation.


There are no available long-term toxicity evaluations for7-[[2-[(aminocarbonyl)amino]-4-[(4-amino-6-chloro-1,3,5-triazin-2-yl)amino]phenyl]azo]naphthalene-1,3,6-trisulphonic acid. By speculation, long-term NOEC for aquatic organisms were not expected for the substance at concentration below 0.01 mg/L based on the data mentioned above.


The chemical was therefore not considered as hazardous to aquatic environments as per the criteria set out in Annex XIII.




Based on critical, independent and collective evaluation of information summarized herein, the tested compound fulfil the P criterion but does not fulfil the B and T criterion and has therefore not been classified as a PBT compound within Annex XIII.