Reaction mass of Amines, N-tallow alkyltrimethylenedi-, mono(2-ethylhexanoates), Amines, N-tallow alkyltrimethylenedi-, acetates and n-tallow-1,3-diaminopropane ditallate

Bioaccumulation: aquatic / sediment

Link to relevant study record(s)

Reference

Endpoint:

bioaccumulation: aquatic / sediment

Type of information:

(Q)SAR

Adequacy of study:

key study

Study period:

2018

Reliability:

2 (reliable with restrictions)

Rationale for reliability incl. deficiencies:

other: BCF estimated using a measured Log Kow (slow stirring at pH 7).

Justification for type of information:

QSAR prediction:

Qualifier:

no guideline followed

Principles of method if other than guideline:

QSAR calculation

GLP compliance:

no

Radiolabelling:

no

Test type:

other: QSAR

Type:

other: Log BCF

Value:

0.66 dimensionless

Basis:

other: QSAR based on measured Log Kow

Type:

other: Log BCF

Value:

3.19 dimensionless

Basis:

other: Worst-case BCF based on calculated log Kow

Conclusions:

QSAR calculation of the BCF using a measured log Kow (Slow stirring at pH 7) for an ionic surface active substance.

Executive summary:

The registrant considers an OECD 305 -I (water exposure) as not technically feasible because the substance is readily biodegradable and because of the strong sorbing properties of the several constituents of the substance, maintaining steady concentrations of these constituents in water is technically not feasible. OECD 305-I and OECD 305-II are therefore waived according to annex XI, section 2 of REACh regulation EC 1907/2006.

In relation to OECD 305 -III (dietary) testing it should be noted that annex XIII of REACh requires the derivation of a fish BCF for comparison with B/vB criteria. It is however known that OECD 305 -III only provide a fish BMF and that BMF cannot directly be compared to B/vB criteria. In order to be used in the framework of the PBT/vPvB assessment of REACh, the BMF must be converted into BCF. Several equations are available to do so. However, all these equations use log Kow as a key parameter (i.e. they are based on the lipophilicity of the substance). But since log Kow is a poor predicter of the bioaccumulation potential of these substances the registrant considers that the available equations cannot be used to convert a BMF into a BCF for R814M. As a result, it is not feasible to derive a reliable BCF from an OECD 305-III test with the registered substance. The performance of an OECD 305 -III study can considering the arguments given not reach its purpose and is therefore waived according to annex XI, section 2 of REACh regulation EC 1907/2006.

Despite the fact that the log Kow is based on the current knowledge a poor predicter of the bioaccumulation potential for cationic surfactants, the BCF has been calculated using EPIsuite.

EPI suite calculations based on a measured log Kow of 1.5 (pH 7: protonated) predict a log BCF of 0.66 with a normalized (to 10 g fish) biotransformation half-life of 0.46.

EPI suite calculations based on a calculated log Kow of 7.69 (unprotonated) predict a log BCF of 3.19 with a normalized (to 10 g fish) biotransformation half-life of 36.7.

Finally, for primary alkyl amines and also for alkyl-1,3 -diamino propanes biotransformation has been observed in an in-vitro biotransformation test using rainbow trout hepatic S9 subcellular fraction. e.g t½ = 2.7h for 0.7 µM dodecyl-1,3 -diaminopropane.

It is therefore not expected that these substances will accumulate in the food chain.

Description of key information

The alkyl-1,3-diaminopropanes are readily biodegradable and biotransformation has been observed in in-vitro biotransformation tests and it is therefore unlikely that they will accumulate in the food chain.

The registrant considers an OECD 305 -I (water exposure) as not technically feasible because the substance is readily biodegradable and because of the strong sorbing properties of the several constituents of the substance which will make maintaining steady concentrations of these constituents in water is technically not feasible. OECD 305-I and OECD 305-II are therefore waived according to annex XI, section 2 of REACh regulation EC 1907/2006.

In relation to OECD 305 -III (dietary) testing it should be noted that annex XIII of REACh requires the derivation of a fish BCF for comparison with B/vB criteria. It is however known that OECD 305 -III only provide a fish BMF and that BMF cannot directly be compared to B/vB criteria. In order to be used in the framework of the PBT/vPvB assessment of REACh, the BMF must be converted into BCF. Several equations are available to do so. However, all these equations use log Kow as a key parameter (i.e. they are based on the lipophilicity of the substance). But since log Kow is a poor predicter of the bioaccumulation potential of these substances the registrant considers that the available equations cannot be used to convert a BMF into a BCF for R814M. As a result, it is not feasible to derive a reliable BCF from an OECD 305-III test with the registered substance. The performance of an OECD 305 -III study can considering the arguments given not reach its purpose and is therefore waived according to annex XI, section 2 of REACh regulation EC 1907/2006.

Since there is a measured log Kow value, this is used to predict the bioaccumulation potential. Based on the measured log Kow value of 1.5 the calculated log BCF is 0.66 (BCF = 4.6; EpiSuite v4.0).

Key value for chemical safety assessment

BCF (aquatic species):

4.6 dimensionless

Additional information

The alkyl-1,3-diaminopropanes are readily biodegradable and it is therefore unlikely that they will accumulate in the food chain. The predicted BCF value could even be lower, as the calculation of the BCF is not taking into account metabolism of the compound, e.g. by fish and other aquatic organisms.