The test for a surfactant will only be required when there is disagreement between a supplier and Cefas as to whether a substance is a surfactant. If a substance is not declared as a surfactant on the HOCNF, but as a result of literature surveys and expert knowledge Cefas believe that a substance is a surfactant, we will communicate that view and reasoning to the supplier. If the supplier is unwilling to accept our view, and cannot present scientific evidence to convince us to change their evaluation, a surfactant test will be required.
Weight-of-evidence approach for bioaccumulation assessment of surfactants
Any supplier intending to submit a weight-of-evidence-based evaluation of a substance in line with Annex 1 of the guidance to the HOCNF should contact Cefas to discuss the suitability of their approach before starting work. General guidance for the type of approach that may be acceptable are outlined in the following references:
de Wolf, W., Comber, M., Douben, P., Gimeno, S., Holt, M., et al. (2007). Animal Use Replacement, Reduction, and Refinement: Development of an Integrated Testing Strategy for Bioconcentration of Chemicals in Fish. Integrated Environmental Assessment and Management: Vol. 3, No. 1, pp. 3-17.
Millais, A.J., Rycroft, R.J., Tolhurst, M.A., Sheahan, D.A. (2007). Bioconcentration: Comparison of methods for assessing potential hazards of offshore chemicals. Chemistry in the Oil Industry: X, 5-7 November 2007.