Esters and salts in April 2024

[Mike Dewhirst]

Esters and salts which have components (parents) on the High Hazard list are themselves considered to be High Hazard.

Each of the health properties now have specifically listed esters which have specific exceptions due to certain properties which now need to be considered during categorisation.

These sections in the Guidelines for health properties are:

6.3.2 Carcinogenicity
6.4.2 Reproductive toxicity
6.5.2 Developmental toxicity
6.6.2 Adverse effects mediated by an endocrine mode of action
6.7.2 Genetic toxicity

and environment properties ...

6.25.2 Adverse effects mediated by an endocrine mode of action
6.26.2 PBT (reference to esters and salts removed - no listed ones)
6.27.2 Very toxic to any aquatic life (ditto PBT)
6.28.2 Persistent and bioaccumulative (ditto PBT)

These chemicals probably need their own ester/salt table entries. It would be preferable to centralise them in the main Index. Some more research is required.

This ticket

See Interim solution - amending/enhancing an existing note - in the first comment below.

[Mike Dewhirst]

Overview

The main game is to detect a chemical's particular hazards and categorise accordingly.

However, for each class of hazard a chemical may have, AICIS requires proof the chemical does not have the next level of hazard in each class worse than claimed by the introducer. AICIS actually specifies the OECD tests (and equivalent tests of other respected organisations) required to be passed successfully and also requires the documented results for that proof on demand.

"Otherwise", they say in their guidelines, two things are required:

1. The chemical is not on the high hazard list for the particular hazard in question; and

2. confirmation that the chemical is not an ester or salt of the specified chemicals (shown in the below table) and which are on the high hazard list

Interim solution

So the interim solution is to detect if the chemical being categorised appears in the "below table" and if so append/insert an appropriate statement to the above effect into the existing note being created for the above OECD test requirements.

History

This scenario has history. Previously, it was looked at from the reverse direction.

Ticket #2
If you were introducing a salt or ester it was necessary to detect the "parents" of that chemical and consider their hazards to also be hazards of the salt or ester. We had an algorithm which looked for the hazards of acids and alcohols (typical parents) and added their hazards but allowing the (expert) user to defeat the software provided a note including "Not applicable" in the title was created to contain their reasons.

Ticket #24
Subsequently we decided our algorithm was not entirely chemically adequate and stopped automatically adding parental hazards and instead simply created a note to be acknowledged by the user that they need to know what they are doing regarding salts and esters.

Next

The next solution (future ticket) will be to algorithmically detect if the chemical being introduced is a salt or ester of tabled chemicals in order for that confirmation (2 above) to be given.