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03/08/2017 81933364 DICHLOFLUANID 1 CHEMICAL IDENTITY Common name Dichlofluanid Chemical name (IUPAC) N-dichlorofluoromethylthio-N',N'-dimethyl-N-phenylsulfamide Synonym(s) Chemical class (when available/relevant) CAS number 1085-98-9 EU number 214-118-7 Molecular formula C9H11Cl2FN2O2S2 SO2 N(CH3)2 N Molecular structure S Molecular weight (g.mol-1) 333.2 1 CCl2F 03/08/2017 2 81933364 EXISTING EVALUATIONS AND REGULATORY INFORMATION Annex III EQS Dir. (2008/105/EC) Not Included Existing Substances Reg. (793/93/EC) Not listed Pesticides(91/414/EEC) Not included in Annex I Biocides (98/8/EC) Included in Annex I (wood preservative) Not included in Annex I (Masonry preservative), because this product type was not supported by submission of a dossier. Pending (film preservative, antifouling) PBT substances No Substances of Very High Concern (1907/2006/EC) No POPs (Stockholm convention) No Other relevant chemical regulation (veterinary products, medicament, ...) No Endocrine disrupter Available information / Not investigated Dichlofluanid is used as a wood preservative in biocidal products (E.C., 2006). The review report for the active substance Dichlofluanid (E.C., 2006) has concluded that: “It may be expected that wood preservatives containing dichlofluanid will fulfill the requirements laid down in Article 10(1) and (2) of Directive 98/8/EC. This conclusion is however subject to: i. compliance with the particular requirements in the following sections of this assessment report, ii. the implementation of the provisions of Article 5(1), and iii. the common principles laid down in Annex VI to Directive 98/8/EC, for each wood preservative containing dichlofluanid. Furthermore, these conclusions were reached within the framework of the uses that were proposed and supported by the applicant (see Appendix III). Extension of the use pattern beyond those described will require an evaluation at Member State level in order to establish whether the proposed extensions of use will satisfy the requirements of Article 5(1) and of the common principles laid down in Annex VI of Directive 98/8/EC.” Dichlofluanid is also under assessment for the product types 07 (Film preservatives) and 21 (antifouling). The substance has been subjected to a non-inclusion directive for product type 10 (Masonry preservatives), because the applicant did not support this use by submission of a dossier. 2 03/08/2017 3 81933364 PROPOSED QUALITY STANDARDS (QS) to be defined later –on hold 3.1 ENVIRONMENTAL QUALITY STANDARD (EQS) QS for -- is the “critical QS” for derivation of an Environmental Quality Standard Value Comments Proposed AA-EQS for [matrix] [unit] Corresponding AA-EQS in [water] [µg.L-1] Critical QS is QS--. See section 7 Proposed MAC-EQS for [freshwater] [µg.L-1] Proposed MAC-EQS for [marine waters] [µg.L-1] See section 7.1 Stakeholder’s comment (Lanxess): As dichlofluanid rapidly degrades in the environment to other, compounds which are less toxic to the environment, the derivation of an environmental Quality standard (EQS) and consequent proposal of dichlofluanid to the list of priority substances under the WFD is regarded as not appropriate. 3.2 SPECIFIC QUALITY STANDARD (QS) Protection objective* Unit Value Pelagic community (freshwater) [µg.l-1] Pelagic community (marine waters) [µg.l-1] Benthic community (freshwater) [µg.kg-1 dw] Benthic community (marine) [µg.kg-1 Comments See section 7.1 e.g. EqP, see section 7.1 dw] [µg.kg-1biota ww] Predators (secondary poisoning) [µg.l-1] (freshwaters) (marine waters) See section 7.2 [µg.kg-1biota ww] Human health via consumption of fishery products [µg.l-1] Human health via consumption of water [µg.l-1] (freshwaters) (marine waters) See section 7.3 Please note that as recommended in the Technical Guidance for deriving EQS (drat version), “EQSs […] are not reported for ‘transitional and marine waters’, but either for freshwater or marine waters”. If justified by substance properties or data available, QS for the different protection objectives are given independently for transitional waters or coastal and territorial waters. * 3 03/08/2017 4 81933364 MAJOR USES AND ENVIRONMENTAL EMISSIONS 4.1 USES AND QUANTITIES Dichlofluanid is used as an active substance included in biocidal products. Dichlofluanid has been evaluated for its use in wood preservation (product-type 8) up to Hazard Class 3 (i.e. wood which is not covered and not in contact with ground, but exposed to weather or frequent wetting). It is applied in solvent-based product formulations either in primers or incorporated in low binder-containing paints (e.g. glazes). Products can be used for: - the pre-treatment of timber (dipping and automated enclosed spraying by industrial/professional users); - the protective treatment of wood in situ by brush application (both professional and amateur users). Dichlofluanid is not recommended for treatment of wood inside housing areas (with the exception of window frames and external doors, which will usually be treated on or before installation) or for spraying manually in open systems (E.C., 2006). Dichlofluanid is also under assessment for the product types 07 (Film preservatives) and 21 (antifouling). The substance has been subjected to a non-inclusion directive for product type 10 (Masonry preservatives), because the applicant did not support this use by submission of a dossier. No information available on quantities produced or used. 4.2 ESTIMATED ENVIRONMENTAL EMISSIONS No information available on environmental emissions. 5 ENVIRONMENTAL BEHAVIOUR 5.1 ENVIRONMENTAL DISTRIBUTION Dichlofluanid Master reference Water solubility (mg.l-1) 1.58 at 20 °C at pH 4. Solubility in water is dependent of pH in the range of pH 4 to pH 9. Volatilisation Given the vapour pressure and Henry constant reported below, dichlofluanid is not likely to volatilise. E.C., 2006 Vapour pressure (Pa) 2.15 10-5 at 20 °C ; 5.37 10-5 at 25 °C E.C., 2006 Henry's Law constant (Pa.m3.mol-1) 4.5 10-3 E.C., 2006 Adsorption The value of 1344 is used for derivation of quality standards. Organic carbon – water partition coefficient (KOC) KOC = 1344 Log KOC = 3.13 Sediment – water partition coefficient(Ksusp-water) 169 Bioaccumulation E.C., 2006 Calculated from KOC The BCF value 72 on fish is used for derivation of quality standards. Octanol-water partition coefficient (Log Kow) log KOW = 3.5. Coefficient independent of temperature (10 to 30 °C), respectively pH (range 4 to 9). E.C., 2006 BCF (measured) Dichlofluanid is unlikely to bioaccumulate. BCF for Lepomis macrochirus is 72 +/- 14 E.C., 2006 4 03/08/2017 81933364 Relevant metabolite of dichlofluanid : DMSA Master reference -1 E.C., 2006 Water solubility (mg.l ) 1300 at 20 °C Volatilisation DMSA is not likely to volatilise. Vapour pressure (Pa) 2.5 10-4 at 20 °C 4.9 10-4 at 25 °C E.C., 2006 Henry's Law constant (Pa.m3.mol3.8 10-5 1 ) Adsorption E.C., 2006 DMSA is not likely to adsorb onto solid particles Organic carbon – water partition coefficient (KOC) KOC = 53 Log KOC = 1.72 Suspended matter – water partition coefficient(Ksusp-water) 2.2 E.C., 2006 Calculated from KOC DMSA is not likely to bioaccumulate given the low log K OW Bioaccumulation Octanol-water partition coefficient (Log Kow) At 20 °C: KOW = 39; log KOW = 1.59 E.C., 2006 BCF (measured) DMSA is unlikely to bioaccumulate. E.C., 2006 5.2 ABIOTIC AND BIOTIC DEGRADATIONS Dichlofluanid Master reference Hydrolysis Dichlofluanid hydrolyses rapidly to DMSA (N,N-dimethyl-N’phenylsulfamide) at neutral pH. DT50 dichlofluanid (20°C) = 25.6 h (1) E.C., 2006 Photolysis Due to its lack of UV absorbance at the wavelengths present in sunlight, dichlofluanid is not degradable by direct photodegradation in aqueous solution. E.C., 2006 Biodegradation In water, dichlofluanid is not readily biodegradable (9% after 28 days, 41% after 140 days). In water/sediment systems, dichlofluanid was rapidly degraded in two aerobic aquatic systems with DT50 values of 1.2 and 3 h. Dichlofluanid does not constitute a lasting potential to contaminate surface water or sediment. E.C., 2006 (1) At pH 9, the hydrolytic degradation was so rapid that at room temperature, even when the analysis was conducted immediately, no dichlofluanid could be detected. At pH 7: DT50 (20°C) = 25.6 h, DT50 (30°C) = 5.4 h and DT50 (22°C, extrapolated) = 18.8 h. At pH 4: DT50 (30°C) = 6.9 d, DT50 (40°C) = 2.8 d and DT50 (22°C, extrapolated) = 15.3 d. Half lifess for DMSA in water/sediment are longer than for Dichlofluanid, however, it is not likely to be found in soil, groundwater and surface water above acceptable values as it degrades further to the metabolite N,N-dimethylsulfamide. N,N-dimethylsulfamide does not cause itself concerns. It can however react with ozone during a standard drinking water preparation process (ozonisation) forming nitrosamine (NDMA), which is harmful to health. Stakeholder’s comment (Lanxess): This reaction between N,N-dimethylsulfamide and ozone came into discussion in the framework of plant protection uses of Tolylfluanid. Dichlofluanid was however not on the market for plant protection purposes, solely for the limited biocidal uses (PT8, PT 7 and PT 21). These uses are not comparable to plant protection uses. Dichlofluanid is still under evaluation in PT 7 and PT 21. The stakeholder would like to refer also to information on Tolylfluanid prepared by Finland. Finland proposed to evaluate the need for deriving an EQS for the main degradation product of tolylfluanid, N,N-DMS, at a later stage, after evaluation of PT 7 and PT 21, e.g. within the Chemical Monitoring and Emerging Pollutants Sub Group or as part of priority setting schemes within MS. 5 03/08/2017 81933364 Relevant metabolite of dichlofluanid : DMSA Hydrolysis Photolysis Biodegradation 6 Master reference No hydrolysis of DMSA is detectable at pH 4, 7 and 9 at 22°C. DT50 DMSA (20°C) > 1 year E.C., 2006 No information available In aerobic water/sediment systems, dichlofluanid was very rapidly degraded to DMSA which stayed mainly in the water phase. No further metabolite approaching or exceeding the 10 % mark within the incubation time. E.C., 2006 E.C., 2006 AQUATIC ENVIRONMENTAL CONCENTRATIONS 6.1 ESTIMATED CONCENTRATIONS Compartment Predicted environmental concentration (PEC) Master reference 0.39 Daginnus et al., 2009(1) Freshwater Marine waters (coastal and/or transitional) No data available Sediment No data available Biota (freshwater) No data available Biota (marine) No data available Biota (marine predators) No data available (1) data originated from EU modelling-based prioritisation results. 6.2 MEASURED CONCENTRATIONS Stakeholder’s comment (Lanxess): It is expected that all measured concentrations of dichlofluanid in the environment will be below Limit of Detection, because the substance hydrolyses rapidly under environmentally relevant pH values in the aquatic compartment and also in soil. 6 03/08/2017 81933364 Compartment Measured environmental concentration (MEC) Master reference cf. table above James et al., 2009(1) Freshwater Marine waters (coastal and/or transitional) WWTP effluent No data available cf. table above Sediment No data (0) James et al., 2009(1) No data (0) No data (0) Biota James et al., 2009(1) No data (0) Biota (marine predators) (1) No data available data originated from EU monitoring data collection. 7 03/08/2017 7 81933364 EFFECTS AND QUALITY STANDARDS Dichlofluanid is extremely toxic to aquatic organisms, although it metabolises rapidly in DMSA, which is a low toxicity molecule. Stakeholder’s comment (Lanxess): The metabolite DMSA is less toxic than Dichlofluanid and degrades further to N,N-dimethylsulfamide, a substance which does not fulfil the PBT criteria and does itself not present an unacceptable risk to the environment. N,N-dimethylsulfamide came into discussion through plant protection uses of tolylfluanid, which is chemically related to dichlofluanid. Only in the limited situations, when surface water containing N,NDimethylsulfamide is extracted for production of drinking water and during processing ozone is applied Nnitrosodimethylamine (NDMA) can occur. 7.1 ACUTE AND CHRONIC AQUATIC ECOTOXICITY All (eco)toxicological data reported below are extracted from EU Draft Assessment Report (E.C., 2006) and were therefore considered reliable at an EU level. ACUTE EFFECTS Algae & aquatic plants (mg.l-1) Freshwater Master reference Dichlofluanid Scenedesmus subspicatus / 72 h ErC50 = 15 No data available Marine Dichlofluanid Daphnia magna / 48h EC50 = 0.42 E.C., 2006 DMSA Daphnia magna / 48h EC0 ≥ 95.6 E.C., 2006 Freshwater Invertebrates (mg.l-1) No data available Marine No data available Sediment Freshwater Fish (mg.l-1) E.C., 2006 Dichlofluanid Oncorhynchus mykiss / 96 h LC50 = 0.01 Marine No data available Sediment No data available No data available Other taxonomic groups 8 E.C., 2006 03/08/2017 81933364 CHRONIC EFFECTS Algae & aquatic plants (mg.l-1) Master reference Dichlofluanid Freshwater DMSA Marine Dichlofluanid Freshwater Invertebrates (mg.l-1) Scenedesmus subspicatus / 96 h NOErC = 1 Scenedesmus subspicatus / 72 h NOErC > 97.7 No data available Daphnia magna / 21d NOEC repro, weight, length = 2.65 10-3 E.C., 2006 E.C., 2006 E.C., 2006 No data available No data available Marine DMSA Sediment Dichlofluanid Freshwater Fish (mg.l-1) DMSA Chironomus riparius / 28d EC5 development = 9.7 Oncorhynchus mykiss / 21d NOEC = 4.55 10-3 Pimephales promelas / 33d NOEC weight, length = 4.07 10-3 Oncorhynchus mykiss / 21d NOEC weight, length = 10 Marine No data available Sediment No data available E.C., 2006 E.C., 2006 E.C., 2006 E.C., 2006 No data available Other taxonomic groups Assessment factor Tentative QS Oncorhynchus mykiss / 96 h LC50 = 0.01 mg/l 100 0.1 µg/l 1 000 0.01 µg/l 10 0.26 µg/l AA-QSmarine water, eco Daphnia magna / 21d NOEC = 2.6 10-3 mg/l 100 0.026 µg/l AA-QSfreshwater, sed. - To be defined To be defined AA-QSmarine water, sed. - To be defined To be defined Tentative QSwater Relevant study for derivation of QS MACfreshwater, eco MACmarine water, eco AA-QSfreshwater, eco 9 03/08/2017 81933364 7.2 SECONDARY POISONING Secondary poisoning of top predators Master reference Mammalian oral toxicity Dog / Oral route carcinogenicity / 2 y / no effect reported NOAEL : 25 mg.kg-1bw.d-1 NOEC : 100 mg.kg-1feed ww (CF= 40) E.C., 2006 Avian oral toxicity Colinus virginianus & Anas platyrhynchos / Oral / Subacute / 5 d LC 50 : > 5000 mg.kg-1feed ww E.C., 2006 Tentative QSbiota Relevant study for derivation of QS Biota NOEC : 100 mg.kg-1feed ww Assessment factor Tentative QS 90(1) 11 111 µg.kg-1biota ww corresponding to 154 µg.L-1 (freshw.) 154 µg.L-1 (saltw.) (1) proposal made for the purpose of this dossier, according to REACH guidance on information requirements and chemical safety assessment (ECHA, 2008) 7.3 HUMAN HEALTH Stakeholder’s comment (Lanxess): The rapid hydrolysis of dichlofluanid in the aquatic environment leads to the conclusion that human health via consumption of fishery products is not at risk. Further more BCF is low. Depuration time (DT50) is 0.25 days (edible) and 0.24 d for the whole fish. DMSA and N,N-dimetyhlsulfamide are also expected to not bioaccumulate. Human health via consumption of fishery products Master reference Mammalian oral toxicity Dog / Oral route carcinogenicity / 2 y / no effect reported NOAEL = 25 mg.kg-1bw.d-1 CMR Dichlofluanid is not classified for any carcinogenic, mutagenic or reprotoxic properties Tentative QSbiota, hh Relevant study for derivation of QSbiota, hh Human health NOAEL= 25 mg.kg-1bw.d-1 AF 100(1) unknown in WHO, 1983 E.C., 2008 Threshold level Tentative QSbiota, hh 0.3(1) mg.kg-1bw.d-1 18.3 µg.kg-1biota ww corresponding to 0.142µg.L-1 (freshw.) 0.142µg.L-1 (saltw.) (1) No information is available concerning the study. The source of information is WHO (WHO, 1983) but there is no information on administered doses and endpoints for the derivation of this ADI. Confidence in this study is therefore very low. Human health via consumption of drinking water Master reference Existing drinking water standard(s) Directive 98/83/EC 0.1 µg.L-1 (preferred regulatory standard) Any guideline 10 03/08/2017 8 81933364 BIBLIOGRAPHY, SOURCES AND SUPPORTIVE INFORMATION Daginnus K., Gottardo S., Mostrag-Szlichtyng A., Wilkinson H., Whitehouse P., Paya-Pérez a. and Zaldívar J.-M. (2009). A modelling approach for the prioritisation of chemicals under the Water Framework Directive. Ispra, Italy, European Commission, Joint Research Centre, Institute for Health and Consumer Protection.: 48. E.C. (2006). Assessment Report - Dichlofluanid, PT 8. Directive 98/8/EC concerning the placing of biocidal products on the market. Inclusion of active substances in Annex I to Directive 98/8/EC. E.C. (2008). Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006 (Text with EEA relevance). Official Journal of the European Union. L353: 1355. ECHA (2008). Guidance on information requirements and chemical safety assessment Chapter R.10: Characterisation of dose [concentration]-response for environment. Guidance for the implementation of REACH. Helsinki, European Chemicals Agency. James A., Bonnomet V., Morin A. and Fribourg-Blanc B. (2009). Implementation of requirements on Priority substances within the Context of the Water Framework Directive. Contract N° 07010401/2008/508122/ADA/D2. Prioritisation process: Monitoring-based ranking., INERIS / IOW: 58. WHO (1983). Pesticide Residues In Food. Sponsored jointly by FAO and WHO. Evaluations 1983. Data and recommendations of the joint meeting of the FAO Panel of Experts on Pesticide Residues in Food and the Environment and the WHO Expert Group on Pesticide Residues, Geneva, 5 - 14 December 1983., World Health Organisation. 11