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EC number: 202-112-7
CAS number: 91-97-4
EU regulation No 1272/2008 (CLP; amending
and repealing Directives 67/548/EEC and 1999/45/EC, and amending
Regulation (EC) No 1907/2006):
CLP classification as "Acute (short-term)
aquatic hazard", Acute Category 1 as 96 hr EC50 (for fish) is 0.25 mg/L
(i.e. lower than 1 mg/L).
CLP classification as "Chronic (long-term)
aquatic hazard", Chronic Category 1 (Note 1) as 96 hr LC50 (for fish) is
0.25 mg/L (i.e. lower than 1 mg/L) and the log Kow is 6.05 at 25°C (i.e.
higher than 4). (M factor=1)
Remark: The classification is based upon a
worst case scenario and not the general exposure scenario.
The LC50 (96h, fish) is derived at
concentrations exceeding the water solubility of TODI.***
TODI reacts very fast with water
(hydrolysis). The log Pow of the postulated product of hydrolysis of
TODI (TODA, substance name: 4,4'-bi-o-toluidine; alternative name:
3,3'-Dimethyl-4,4'-diamino-biphenyl, CAS no. 119 -93 -7, EC no. 204 -358
-0) at 25 °C was estimated to be equal or lower than 3.
*** TODI as such is hardly soluble in water
(See IUCLID section 4.6., water solubility), therefore Dimethylformamide
was used as auxiliary solvent / dispersant in the acute toxicity test to
fish, to aquatic invertebrate and to aquatic algae, respectively.
Moreover, TODI showed to be highly unstable in aqueous media, with
hydrolysis occurring virtually instantaneously on contact with water and
the degradation product was found to be insoluble in organic and aqueous
solvents. (See IUCLID sections 6.1.1, short-term toxicity to fish and
6.1.3, short-term toxicity to aquatic invertebrate). That means that
(1.) the acute toxicity tests represent the worst case as the solubility
in water was increased by an auxiliary solvent and (2.) a chronic
exposure to the TODI, respectively to its degradation product is
negligible due to the insolubility of both if no auxiliary solvent is
On the other hand, the insolubility in water
or aqueous solvents and the missing ready biodegradability of TODI (not
so relevant because of rapid hydrolysis) and its degradation product and
the calculated log Kow of 6.05 for TODI may indicate and trigger H413
classification for precautionary reasons.
However, the estimated log Kow of the
hydrolysis product TODA (log Kow= 2.34 - 3 .02), as well as the
experimentally BCF of TODA (BCF < 83) does not indicate long-lasting
effects in the aquatic compartment.
Information on Registered Substances comes from registration dossiers which have been assigned a registration number. The assignment of a registration number does however not guarantee that the information in the dossier is correct or that the dossier is compliant with Regulation (EC) No 1907/2006 (the REACH Regulation). This information has not been reviewed or verified by the Agency or any other authority. The content is subject to change without prior notice.Reproduction or further distribution of this information may be subject to copyright protection. Use of the information without obtaining the permission from the owner(s) of the respective information might violate the rights of the owner.
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