Reaction mass of benzyldodecylbis(2-hydroxypropyl)ammonium chloride and benzylbis(2-hydroxypropyl)tetradecylammonium chloride

Viscosity

Description of key information

The viscosity of a substance might gain importance in the view of environmental and human health hazard assessment. 
With respect to human health, certain liquid substances may present an aspiration hazard because of their low viscosity possibly resulting in an entry of the liquid into the trachea and lower respiratory tract. 
As the substance is classified as carcinogenic category 2, any exposure (dermal, inhalation, oral) to the substance has to strictly be avoided. The substance is exclusively used in closed systems applying strictly controlled conditions and using dedicated filling lines at dedicated sites. Therefore, exposure is unlikely. Strict application of Risk Management Measures and defined Operational Conditions is, furthermore, expected to minimize exposure to a negligible extent.
The viscosity of fluids is environmentally relevant owing to the penetration of fluids into the soil and the harmful effect on the groundwater which may thus possibly be caused. The substance is not directly applied on soil. No waste water occurs during manufacture and use. Waste gases are transferred to an incineration plant. The liquid waste from manufacture and use is disposed of via a hazardous waste combustion unit. Furthermore, all relevant surfaces are sealed to prevent any soil contamination. In summary, any releases in the environment, especially on soil, can be excluded based on the applied process conditions, waste management measures and in the absence of a direct application on soil. 
Concluding, based on the applied process conditions and waste treatment processes, the substance will neither enter the soil compartment, nor pose an aspiration hazard to the workers. Therefore, according to REACH Annex XI, Section 3 a study to determine the viscosity of the substance does not need to be conducted, as exposure is unlikely to occur. The substance is contained throughout its whole life cycle.