11097/ECCO/BBA/00 Addendum 1 to draft assessment report (6613/ECCO/PSD/99) Monograph Addendum 1 26 May 2000 Ferric phosphate Ecotoxicology Rapporteur Member State: Germany
2/3 Addendum B.09.06 Effects on earthworms (Annex IIIA, point 10.6) For determination of the long term PEC the short term PEC is used, because the ferricphosphate is strongly adsorbed to soil and is not washed out. The NOEC derived from the reproduction test is 0.05 g/m² (for one-fold application rate 0.5 kg as/ha). This amounts to 0.7 mg as/kg substrate, and accordingly the long term TER amounts to 1 (0.7/0.67) for the onefold rate and to 0.25 for the four-fold field rate (0.7/2.7). The long term TERs are below the relevant trigger of 5 as laid down in Annex VI of Directive 91/414/EEC. According to Annex III of Directive 91/414/EEC a field test would be necessary. However, in this special case of exposure, where surface active species might be at risk, an additional laboratory study might be more relevant. In this study the surface feeding Lumbricus terrestris should be used and the study design should follow the guideline on reproduction with Eisenia fetida and Daniel Funnel Test (Bieri et al. 1989). A corresponding study has been submitted to the RMS on March 21 st which is reported below: Title: Assessment of sublethal effects of NEU 1165 M on Lubricus terrestris L. in soil. Purpose: This study was performed to determine the subacute effects of NEU 1165 M on earthworm Lumbricus terrestris L. in soil under laboratory conditions based on the ISO- Guideline 11268-2. Treatments: untreated (control) 1 x max. recommended field rate (5 g/m²) 5 x max. recommended field rate (25 g/m²) 10 x max. recommended field rate (50 g/m²) Mode of application: The test substance was spread on the soil surface according to the agricultural practice of using this product. The recommended test organisms were field catches of Lumbricus terrestris L. (the common species in soil). Results are summarized in Tab.1.
3/3 Results: Tab. B.09.06.01.: Effects of formulation NEU 1165 M (ferric phosphate 1 %) on growth of Lumbricus terrestris L. in the laboratory (duration 8 weeks, original soil, silty sand (Su), org. C 2.5 %, 4 rep. x 4 sub-adults per treatment). Application Rate Mortality [%] Food consumption: Salix leaves per box Mean weight of surviving adults [% of initial weight] Control 0 47 105.6 5 g/m² 0 38 105.4 25 g/m² 0 31 96.4 50 g/m² 1 31 98.2 Risk evaluation: No significant difference of body weight was calculated in the tested concentrations of NEU 1165 M (multiple test procedure according to Dunnett, α = 0.05). The difference to control was < 10 % (reproduction was not analysed due to low numbers of juvenils/cocoons). A long term risk on natural earthworm fauna after application of NEU 1165 M is unlikely to occur.
11114/ECCO/BBA/00 Addendum 2 to draft assessment report (6613/ECCO/PSD/99) Monograph Addendum 2 29 May 2000 Ferric phosphate Mammalian Toxicology Rapporteur Member State: Germany
- i Addendum on Ferric phosphate Contents 2000-05-29 Contents Volume 1:... 1 LEVEL 2: 2.3 Impact on human and animal health... 1 VOLUME 3:... 2 B.6 Toxicology and Metabolism... 2 B.6.2 Acute toxicity including irritancy and skin sensitization... 2 B.6.2 Oral... 2 B.6.2.4 Skin irritation... 3 B.6.2.5 Eye irritation... 4
- 1 - Addendum on Ferric phosphate 2000-05-29 2.3 Impact on human and animal health 2.3.1 Effects having relevance to human and animal health arising from exposure to the active substance or to impurities contained in the active substance or to their transformation products Acute toxicity The oral LD 50 of Ferric phosphate in Wistar rats was established to exceed 5000 mg/kg bw. Ferric phosphate was not skin irritating in a rabbit study. Installation of ferric phosphate into the eye of rabbits resulted in effects on the iris and conjunctivae. Iridal irritation (grade 1) was observed in all animals after 1 hour. Irritation of the conjunctivae was seen as redness, chemosis and discharge, which had completely resolved within 48 hours in two animals and within 72 hours in the other animal. No corneal opacity was observed, and treatment of the eyes with 2 % flourescein, 24 hours after test substance installation revealed no corneal epithelial damage in any of the animals. There was no evidence of ocular corrosion. Based on these results and according to the EC criteria for classification and labelling 93/21/EEC), Ferric phosphate does not have to be classified and has no obligatory labelling requirements for acute oral toxicity and for skin or eye irritation. The further knowledge of acute toxic effects of iron salts is based mainly on extensive experiences, resulting from use of iron salts as food additives and from accidental intoxication after ingestion of tablets containing iron salts. Especially children often ingested high doses of ferrous sulfate tablets because of their candy-like coatings. Iron is a corrosive agent and, on direct contact, may produce lesions similar to those caused by acids. The toxicity of iron salts depends mainly from the amount of elemental iron. Therefore, when estimating toxicity of an acute ingestion of iron, the amount of elemental iron should be used in the calculation rather than the milligrams of a particular iron preparation. Doses of < 20 mg/kg body weight (computed as elemental iron in iron salts) are considered non-toxic. Because ferric phosphate contains only approximately 28 % iron, a dose of at least 70 mg/kg bw could be ingested without any toxic effect. But the nontoxic dose of ferric phosphate could be even higher because ferric phosphate is much less bioavailable than ferrous salts. Ferric phosphate is practically insoluble in water and lipids. Therefore a significant skin and eye irritation is not expected. Exposure by the inhalation route would be non-existent because ferric phosphate is not volatile and the formation of the product is a solid matrix of non-respirable size. Ferric phosphate is a natural constituent of human diet and is also added to food for nutritional fortification. Based on these long and extensive experiences it can be concluded that there is no indication of a sensitizing potential of ferric phosphate.
- 2 - Addendum on Ferric phosphate 2000-05-29 VOLUME 3: B.6 Toxicologicy and Metabolism B.6.2. Acute toxicity including irritancy and skin sensitization B.6.2.1 Oral Van Huygevoort (2000): Assessment of acute oral toxicity with ferric phosphate in the rat (acute toxic class method); Report Number: 272982; Laboratory: NOTOX B.V., DD`s Hertogenbosch, The Netherlands; Date: April 06, 2000. GLP: Yes Guidelines: OECD No. 423; 96/54/EEC B.1 tris Acute toxicity oral, acute toxic class method Material and methods: Animal strain: Rat, Wistar strain Crl: (Wi) BR (outbred, SPF-Quality), Source: Charles River Deutschland Dose: 5000 mg/kg bw; The dose level was reached by administration of two times 2500 mg/kg bw within 24 hours Batch, Purity: 105668, Min. 24.8 % Fe Group size: 3 male and 3 female animals Treatment: oral gavage of the test substance using a stainless steel stomach tube. The results were evaluated according to the EC criteria for classification and labelling 93/21/EEC). Date of treatment: female: 14 September 1999, male: 16 September 1999 Results: No mortality occured. Clinical signs: Lethargy, uncoordinated movements, staining of the eye on day 1. Conclusion: The oral LD 50 value of Ferric phosphate in Wistar rats was established to exceed 5000 mg/kg bw. Based on the results and according to the EC criteria for classification and labelling 93/21/EEC), Ferric phosphate does not have to be classified and has no obligatory labelling requirements for acute oral toxicity.
- 3 - Addendum on Ferric phosphate 2000-05-29 B.6.2.4 Skin irritation Van Otterdijk (2000): Primary skin irritation/corrosion study with Ferric phosphate in the rabbit; Report Number: 287426; Laboratory: NOTOX B.V., DD`s Hertogenbosch, The Netherlands; Date: April 06, 2000. GLP: Yes Guidelines: OECD No. 404, 92/69/EEC B.4. Material and methods: Animal strain: Albino rabbit, New Zealand White (SPF-Quality), Source: Charles River UK Dose: 0.5 gram test substance per animal Batch, Purity: 105668, Min. 24.8 % Fe Group size: 3 animals of one sex (sex not indicated) Treatment: The test substance was moistened with 0.6 ml of the vehicle and applied to the skin of one flank, using a metalline patch of 2x3 cm. The patch was mounted on Micropore tape, which was wrapped around the abdomen and secured with Coban elastic bandage. Experimental period:. start February 29, 2000, end March 03, 2000 Observations: The skin reactions were assessed at approximately 1, 24, 48 and 72 hours after removal of the dressings and test substance. The irritation scores and a description of all other (local) effects were recorded. Adjacent areas of the untreated skin of each animal served as controls. The results were evaluated according to the EC criteria for classification and labelling requirements for dangerous substances and preparations (Guidelines in Commission Directive 93/21/EEC). Results: No skin irritation was caused by 4 hours exposure to Ferric phosphate. There was no evidence of a corrosive effect on the skin. No symptoms of systemic toxicity were observed in the animals during the test period and no mortality occured. Conclusion: Based on the results and according to the EC criteria for classification and labelling 93/21/EEC), Ferric phosphate does not have to be classified and has no obligatory labelling requirements for skin irritation.
- 4 - Addendum on Ferric phosphate 2000-05-29 B.6.2.5 Eye irritation Van Otterdijk (2000): Acute eye irritation/corrosion study with Ferric phosphate in the rabbit; Report Number: 287437; Laboratory: NOTOX B.V., DD`s Hertogenbosch, The Netherlands; Date: April 06, 2000. GLP: Yes Guidelines: OECD No. 405, 92/69/EEC B.5. Material and methods: Animal strain: Albino rabbit, New Zealand White (SPF-Quality), Source: Charles River UK Batch, Purity: 105668, Min. 24.8 % Fe Group size: 3 animals of one sex (sex not indicated) Treatment: Each animal was treated by installation of 43.2 ±1.0 mg of the test substance (a volume of approximately 0.1 ml) in the conjunctival sac of one of the eyes after gently pulling the lower lid away from the eyeball. The lids were then gently held together for about one second to prevent loss of the test substance. The other eye remained untreated and served as the reference control. Immediately after the 24 hour observation, a solution of 2 % flourescein in water (adjusted to ph 7.0) was instilled into both eyes of each animal to quantitatively determine corneal epithelial damage. Any bright green stained area, indicating epithelial damage, was estimated as a percentage of the total corneal area. Experimental period:. start March 06, 2000, end March 09, 2000 Observations: The eyes of each animal were examined at approximately 1, 24, 48 and 72 hours after installation of the test substance. The irritation scores and a description of all other (local) effects were recorded. The results were evaluated according to the EC criteria for classification and labelling 93/21/EEC). Results: Installation of approximately 43 mg of the test substance (a volume of approximately 0.1 ml) into one eye of each of three rabbits resulted in effects on the iris and conjunctivae. Iridial irritation (grade 1 ) was observed in all animals after 1 hour. Irritation of the conjunctivae was seen as redness, chemosis and discharge, which had completely resolved within 48 hours in two animals and within 72 hours in the other animal. No corneal opacity was observed, and treatment of the eyes with 2 % flourescein, 24 hours after test substance installation revealed no corneal epithelial damage in any of the animals. There was no evidence of ocular corrosion. No symptoms of systemic toxicity were observed in the animals during the test period and no mortality occured. Conclusion: Based on the results and according to the EC criteria for classification and labelling 93/21/EEC), Ferric phosphate does not have to be classified and has no obligatory labelling requirements for eye irritation.
Monograph 31 August 2000 Ferric phosphate Addendum (Final; including Addendum 1 and 2) Rapporteur Member State: Germany
Addendum on Ferric phospate 1 September 2000 Contents Volume 1:... 1 2.3 Impact on human and animal health... 1 2.3.1 Effects having relevance to human and animal health arising from exposure to the active substance or to impurities contained in the active substance or to their transformation products... 1 Volume 3:... 2 B.6 Toxicologicy and Metabolism... 2 B.6.2. Acute toxicity including irritancy and skin sensitization... 2 B.6.2.1 Oral... 2 B.6.2.4 Skin irritation... 3 B.6.2.5 Eye irritation... 4 B.8 Ecotoxicology... 5 B.8.1 Effects on birds (Annex II 8.1.3)... 5 B.9.6 Effects on earthworms (Annex IIIA, point 10.6)... 5
- 1 - Addendum on Ferric phospate 1 September 2000 Volume 1: 2.3 Impact on human and animal health 2.3.1 Effects having relevance to human and animal health arising from exposure to the active substance or to impurities contained in the active substance or to their transformation products Acute toxicity The oral LD 50 of Ferric phosphate in Wistar rats was established to exceed 5000 mg/kg bw. Ferric phosphate was not skin irritating in a rabbit study. Installation of ferric phosphate into the eye of rabbits resulted in effects on the iris and conjunctivae. Iridal irritation (grade 1) was observed in all animals after 1 hour. Irritation of the conjunctivae was seen as redness, chemosis and discharge, which had completely resolved within 48 hours in two animals and within 72 hours in the other animal. No corneal opacity was observed, and treatment of the eyes with 2 % flourescein, 24 hours after test substance installation revealed no corneal epithelial damage in any of the animals. There was no evidence of ocular corrosion. Based on these results and according to the EC criteria for classification and labelling 93/21/EEC), Ferric phosphate does not have to be classified and has no obligatory labelling requirements for acute oral toxicity and for skin or eye irritation. The further knowledge of acute toxic effects of iron salts is based mainly on extensive experiences, resulting from use of iron salts as food additives and from accidental intoxication after ingestion of tablets containing iron salts. Especially children often ingested high doses of ferrous sulfate tablets because of their candy-like coatings. Iron is a corrosive agent and, on direct contact, may produce lesions similar to those caused by acids. The toxicity of iron salts depends mainly from the amount of elemental iron. Therefore, when estimating toxicity of an acute ingestion of iron, the amount of elemental iron should be used in the calculation rather than the milligrams of a particular iron preparation. Doses of < 20 mg/kg body weight (computed as elemental iron in iron salts) are considered non-toxic. Because ferric phosphate contains only approximately 28 % iron, a dose of at least 70 mg/kg bw could be ingested without any toxic effect. But the nontoxic dose of ferric phosphate could be even higher because ferric phosphate is much less bioavailable than ferrous salts. Ferric phosphate is practically insoluble in water and lipids. Therefore a significant skin and eye irritation is not expected. Exposure by the inhalation route would be non-existent because ferric phosphate is not volatile and the formation of the product is a solid matrix of non-respirable size. Ferric phosphate is a natural constituent of human diet and is also added to food for nutritional fortification. Based on these long and extensive experiences it can be concluded that there is no indication of a sensitizing potential of ferric phosphate.
- 2 - Addendum on Ferric phospate 1 September 2000 Volume 3: B.6 Toxicologicy and Metabolism B.6.2. Acute toxicity including irritancy and skin sensitization B.6.2.1 Oral Van Huygevoort (1999): Assessment of acute oral toxicity with ferric phosphate in the rat (acute toxic class method); Report Number: 272982; Laboratory: NOTOX B.V., DD`s Hertogenbosch, The Netherlands; Date: April 06, 2000. GLP: Yes Guidelines: OECD No. 423; 96/54/EEC B.1 tris Acute toxicity oral, acute toxic class method Material and methods: Animal strain: Rat, Wistar strain Crl: (Wi) BR (outbred, SPF-Quality), Source: Charles River Deutschland Dose: 5000 mg/kg bw; The dose level was reached by administration of two times 2500 mg/kg bw within 24 hours Batch, Purity: 105668, Min. 24.8 % Fe Group size: 3 male and 3 female animals Treatment: oral gavage of the test substance using a stainless steel stomach tube. The results were evaluated according to the EC criteria for classification and labelling 93/21/EEC). Date of treatment: female: 14 September 1999, male: 16 September 1999 Results: No mortality occured. Clinical signs: Lethargy, uncoordinated movements, staining of the eye on day 1. Conclusion: The oral LD 50 value of Ferric phosphate in Wistar rats was established to exceed 5000 mg/kg bw. Based on the results and according to the EC criteria for classification and labelling 93/21/EEC), Ferric phosphate does not have to be classified and has no obligatory labelling requirements for acute oral toxicity.
- 3 - Addendum on Ferric phospate 1 September 2000 B.6.2.4 Skin irritation Van Otterdijk (2000): Primary skin irritation/corrosion study with Ferric phosphate in the rabbit; Report Number: 287426; Laboratory: NOTOX B.V., DD`s Hertogenbosch, The Netherlands; Date: April 06, 2000. GLP: Yes Guidelines: OECD No. 404, 92/69/EEC B.4. Material and methods: Animal strain: Albino rabbit, New Zealand White (SPF-Quality), Source: Charles River UK Dose: 0.5 gram test substance per animal Batch, Purity: 105668, Min. 24.8 % Fe Group size: 3 animals of one sex (sex not indicated) Treatment: The test substance was moistened with 0.6 ml of the vehicle and applied to the skin of one flank, using a metalline patch of 2x3 cm. The patch was mounted on Micropore tape, which was wrapped around the abdomen and secured with Coban elastic bandage. Experimental period:. start February 29, 2000, end March 03, 2000 Observations: The skin reactions were assessed at approximately 1, 24, 48 and 72 hours after removal of the dressings and test substance. The irritation scores and a description of all other (local) effects were recorded. Adjacent areas of the untreated skin of each animal served as controls. The results were evaluated according to the EC criteria for classification and labelling requirements for dangerous substances and preparations (Guidelines in Commission Directive 93/21/EEC). Results: No skin irritation was caused by 4 hours exposure to Ferric phosphate. There was no evidence of a corrosive effect on the skin. No symptoms of systemic toxicity were observed in the animals during the test period and no mortality occured. Conclusion: Based on the results and according to the EC criteria for classification and labelling 93/21/EEC), Ferric phosphate does not have to be classified and has no obligatory labelling requirements for skin irritation.
- 4 - Addendum on Ferric phospate 1 September 2000 B.6.2.5 Eye irritation Van Otterdijk (2000): Acute eye irritation/corrosion study with Ferric phosphate in the rabbit; Report Number: 287437; Laboratory: NOTOX B.V., DD`s Hertogenbosch, The Netherlands; Date: April 06, 2000. GLP: Yes Guidelines: OECD No. 405, 92/69/EEC B.5. Material and methods: Animal strain: Albino rabbit, New Zealand White (SPF-Quality), Source: Charles River UK Batch, Purity: 105668, Min. 24.8 % Fe Group size: 3 animals of one sex (sex not indicated) Treatment: Each animal was treated by installation of 43.2 ±1.0 mg of the test substance (a volume of approximately 0.1 ml) in the conjunctival sac of one of the eyes after gently pulling the lower lid away from the eyeball. The lids were then gently held together for about one second to prevent loss of the test substance. The other eye remained untreated and served as the reference control. Immediately after the 24 hour observation, a solution of 2 % flourescein in water (adjusted to ph 7.0) was instilled into both eyes of each animal to quantitatively determine corneal epithelial damage. Any bright green stained area, indicating epithelial damage, was estimated as a percentage of the total corneal area. Experimental period:. start March 06, 2000, end March 09, 2000 Observations: The eyes of each animal were examined at approximately 1, 24, 48 and 72 hours after installation of the test substance. The irritation scores and a description of all other (local) effects were recorded. The results were evaluated according to the EC criteria for classification and labelling 93/21/EEC). Results: Installation of approximately 43 mg of the test substance (a volume of approximately 0.1 ml) into one eye of each of three rabbits resulted in effects on the iris and conjunctivae. Iridial irritation (grade 1 ) was observed in all animals after 1 hour. Irritation of the conjunctivae was seen as redness, chemosis and discharge, which had completely resolved within 48 hours in two animals and within 72 hours in the other animal. No corneal opacity was observed, and treatment of the eyes with 2 % flourescein, 24 hours after test substance installation revealed no corneal epithelial damage in any of the animals. There was no evidence of ocular corrosion. No symptoms of systemic toxicity were observed in the animals during the test period and no mortality occured. Conclusion: Based on the results and according to the EC criteria for classification and labelling 93/21/EEC), Ferric phosphate does not have to be classified and has no obligatory labelling requirements for eye irritation.
- 5 - Addendum on Ferric phospate 1 September 2000 B.9 Ecotoxicology B.9.1 Effects on birds (Annex II 8.1.3) The company presented additional data and information in order to show that the reproductive risk for birds is low: Publications by Ramsey et al. (1954) and Planas et al. (1961) on certain aspects of iron metabolism in birds compared to mammals: The authors show that birds and mammals obviously have the same basic serum transport mechanism; however, female birds were observed to elevate the serum iron level during egg laying. This is regarded as a response to compensate for iron loss that is due to transfer of iron to the eggs. A publication by Firman (1993): The author reports on the feed requirements in chicken turkey breeding; the table states a concentration of 50 mg/kg as recommended iron content in the diet (that would be equivalent to 1.8 % "Ferramol" in the diet). A publication by Taylor et al. (1965) on avian physiology concluding that there are no indications that iron interferes with the calcium metabolism and egg shell formation, but iron deficiency may affect egg laying. A paper by Gemmeke (1999) who reports that colouring of a material generally reduces the attractivity to birds. Conclusion of the RMS: The notifier maintains there is no risk to birds. Therefore, he sees no necessity for further studies. These arguments of the notifier should be accepted. B.9.6 Effects on earthworms (Annex IIIA, point 10.6) For determination of the long term PEC the short term PEC is used, as ferric-phosphate is strongly adsorbed to the soil and is not washed out. The NOEC derived from the reproduction test is 0.05 g/m² (for one-fold application rate 0.5 kg as/ha). This amounts to 0.7 mg as/kg substrate, and accordingly the long term TER amounts to 1 (0.7/0.67) for the one-fold rate and to 0.25 for the four-fold field rate (0.7/2.7). The long term TERs are below the relevant trigger of 5 as laid down in Annex VI of Directive 91/414/EEC. According to Annex III of Directive 91/414/EEC a field test would be necessary. However, in this special case of exposure, where surface active species might be at risk, an additional laboratory study might be more relevant. In this study the surface feeding Lumbricus terrestris should be used and the study design should follow the guideline on reproduction with Eisenia fetida and Daniel Funnel Test (Bieri et al. 1989). A corresponding study has been submitted to the RMS on 21 March 2000 which is reported below: Title: Assessment of sublethal effects of NEU 1165 M on Lumbricus terrestris L. in soil.
- 6 - Addendum on Ferric phospate 1 September 2000 Purpose: This study was performed to determine the subacute effects of NEU 1165 M on the earthworm species Lumbricus terrestris L. in soil under laboratory conditions based on the ISO-Guideline 11268-2. Treatments: untreated (control) 1 x max. recommended field rate (5 g/m²) 5 x max. recommended field rate (25 g/m²) 10 x max. recommended field rate (50 g/m²) Mode of application: The test substance was spread on the soil surface according to the agricultural practice of using this product. The recommended test organisms were field captured Lumbricus terrestris L. (a common species in soil). Results are summarized in Table B.9.6-1. Results: Table B.9.6-1: Effects of formulation NEU 1165 M (ferric phosphate, 1 %) on growth of Lumbricus terrestris L. in the laboratory (duration 8 weeks, original soil, silty sand (Su), 2.5 % organic C, 4 rep. x 4 sub-adults per treatment). Application Rate Mortality [%] Food consumption: Salix leaves per box Mean weight of surviving adults [% of initial weight] Control 0 47 105.6 5 g/m² 0 38 105.4 25 g/m² 0 31 96.4 50 g/m² 1 31 98.2 Risk evaluation: No significant difference of body weight was calculated in the tested concentrations of NEU 1165 M (multiple test procedure according to Dunnett, α = 0.05). The difference to control was < 10 % (reproduction was not analysed due to low numbers of juveniles/cocoons). A long term risk on natural earthworm fauna after application of NEU 1165 M is unlikely to occur.