Comment on "Policies for Chemical Hazard and Risk Priority Setting: Can Persistence, Bioaccumulation, Toxicity, and Quantity Information be Combined?"

Authors: Sierra Rayne

In their article, Arnot and Mackay [Environ. Sci. Technol., 2008, 42, 4648-4654] use 200 chemicals from the Canadian Domestic Substances List (DSL) to illustrate a model that integrates persistence, bioaccumulation, toxicity, and quantity information for a specific substance to assess chemical exposure, hazard, and risk. The authors claim that the DSL chemicals used in their study are not expected to appreciably ionize at environmental pH. In contrast, a number of the compounds in this study have ionizable functional groups with environmentally relevant pKa values, meaning the corresponding partitioning properties are highly pH dependent, thereby rendering the modeling approach applied by these authors subject to a fatal conceptual and practical flaw. In addition, several compounds in the authors' dataset are expected to hydrolyze rapidly in aquatic systems, resulting in negligible environmental persistence.

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[v1] 2013-03-26 11:45:33

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