0ba0c9c5_t_Red_104___Environment_Canada_Summary_table_Response
[Topic] Persistence and bioaccumulation [Comment] Government assessors should develop an appropriate testing protocol to determine the bioaccumulation factor for these substances. [Response] 
At the moment, the current state of scientific understanding on bioaccumulation potential for metal-containing inorganic substances is limited. Interpretation of the significance of various measures of bioaccumulation (e.g., BCFs, BAFs) for metal-containing inorganic substances is complicated (e.g. presence as micronutrients, or detoxified forms). Research is ongoing to develop methodologies for BCF and BAF measurements and unambiguous interpretation for non-essential and sparingly essential metals. Additionally, to be bioaccumulated or to cause ecotoxicity, the substance and/or an ion released from the substance must be taken up by the organism – that is, they are to be bioavailable. However, the pigments have a low bioavailability (mainly because of a very low solubility), and therefore would also be unlikely to bioaccumulate significantly.
Public comments for C.I. Pigment Red 104 - Environment Canada