Environmental hazard and risk assessment of thiochemicals. Application of integrated testing and intelligent assessment strategies (ITS) to fulfil the REACH requirements for aquatic toxicity

REACH requires information on hazardous properties of substances to be generated avoiding animal testing where possible. It is the objective of the present case study with thiochemicals to extract as much information as possible from available experimental data with fish, daphnia and algae and to fill data gaps for analogues to be registered under REACH in 2018. Based on considerations of chemical similarity and common mode of action (MOA) the data gaps regarding the aquatic toxicity of the thiochemicals were largely closed by trend analysis ("category approach") and read-across within the same group, for example, thioglycolates or mercaptopropionates. Among 16 thiochemicals to be registered by 2018 there are only 2 substances with sufficient data. 36 data gaps for 14 thiochemicals were identified. Most of the required data (>60%) could be estimated by in silico methods. Only 14 tests (6 algae, 6 daphnia, 1 limit fish test and 1 acute fish test) were proposed. When the results of these tests are available it has to be discussed whether 2 further fish (limit) tests are required. For two substances (exposure-based) waiving was suggested. The relatively high toxicity of the thiochemicals is manifested in low predicted no-effect concentrations (PNECs). Only preliminary predicted environmental concentrations (PECs) could be derived for the thiochemicals for which a risk assessment has to be performed (production rate >10 t/y). The preliminary PEC/PNEC ratios indicate no risk for the aquatic compartment at the production site. PECs due to down-stream use must not exceed the estimated PNECs.