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EOSCA ITT – Comparison of Freshwater and Marine Ecotoxicity

European Oilfield Speciality Chemicals Association

There is an intention to harmonize the assessment factors between HMCS and REACH, a consequence of which may be the requirement to more readily accept freshwater toxicity data for fish, crustacean and algae under the HMCS.  However, uncertainty exist on the representativeness of freshwater data for the marine environment. Although the REACH marine assessment factors partly address this uncertainty, EOSCA feel it would be valuable to quantify this uncertainty by reviewing and collating existing information on the comparison of marine and freshwater toxicity for fish, crustacean and algae to inform on the potential future use of available marine and freshwater toxicity data from e.g. REACH and BPR in HMCS.

Please see the full ITT documetn via the link below:

https://eosca.eu/wp-content/uploads/2024/10/EOSCA-ITT-for-Consultant-Review-Fres-vs-marine-toxicity-data_FINAL.pdf


EOSCA are looking for responses to this ITT by end of November 2024.