Benzenesulfonic acid, 4-C10-13-sec-alkyl derivs., ammonium salts

Flammability

Link to relevant study record(s)

Reference

Reference 1

Endpoint:

flammable solids

Data waiving:

study technically not feasible

Justification for data waiving:

the study does not need to be conducted because the substance is a liquid

Justification for type of information:

JUSTIFICATION FOR DATA WAIVING
A flammability study does not need to be conducted because the test item is a liquid.

Reference 2

Endpoint:

substances / mixtures which in contact with water emit flammable gases

Data waiving:

study scientifically not necessary / other information available

Justification for data waiving:

the study does not need to be conducted because the experience in production or handling shows that the substance does not react with water, e.g. the substance is manufactured with water or washed with water

the study does not need to be conducted because the substance is known to be soluble in water to form a stable mixture

Justification for type of information:

JUSTIFICATION FOR DATA WAIVING
On the basis of both production and handling, the substance does not react with water. The test item has been placed in the market in aqueous solution.

Further it has been possible to determine a water solubility value for the test item of 1.207 g/l using critical micelle concentration (ISO 4311:1979) as a surrogate value (test item is surface active). This water solubility value is in excess of ECHA's position that substances with a water solubility of < 1 mg/l are regarded as poorly water soluble. This position is outlined in ECHA's Guidance on Information Requirements and Chemical Safety Assessment section R.7.8.5 (Endpoint Specific Guidance R.7.b - Version 4.0, June 2017). As such the test item can be regarded as soluble in water.

Reference 3

Endpoint:

pyrophoric liquids

Data waiving:

study scientifically not necessary / other information available

Justification for data waiving:

the study does not need to be conducted because the substance is known to be stable in contact with air at room temperature for prolonged periods of time (days) and hence, the classification procedure does not need to be applied

Justification for type of information:

JUSTIFICATION FOR DATA WAIVING
The prescribed storage conditions of the test item are room temperature and (non-inert) air. When subject to these conditions the test item is stable for in excess of 12 months from the date of manufacture. During this period the test item does not demonstrate any pyrophoric properties when subject to the described storage conditions.

Description of key information

Flammability: Manual handling experience demonstrates that the test item is not flammable when in contact with water, nor is it pyrophoric.

Key value for chemical safety assessment

Flammability:

not classified

Additional information

Waiver – In accordance with Regulation (EC) 1272/2008 the flammability of liquids are determined based on flash point and boiling point.  Flammability in contact with water and pyrophoric properties of liquids must also be assessed under this Regulation.

No flash point was determined when the test item was subject to testing using a procedure designed to be compatible Method A.9., Flash Point, of Commission Regulation (EC) No 440/2008 of 30 May 2008.  The test item foamed prior to a flash point being determined.

The hazard classification pyrophoric properties of liquids is not applicable based on additional classification criteria (CLP, Annex I, 2.10.4).  Practical handling experience shows that the substance does not ignite spontaneously on coming into contact with air at normal temperatures and is stable at room temperature for in excess of twelve months from the date of manufacture.

The hazard classification flammability (contact with water) is not applicable based on screening procedures and waiving of testing (CLP, Annex I, 2.12.4.1).  No constituents contain metal or (commonly recognised) metalloids.  Available handling information indicates that the test item does not react with water.   A critical micelle concentration (ISO 4311:1979) study (water solubility surrogate) determined that the test item has a water solubility of 1.207 g/l, in excess of the < 1 mg/l cut-off point for poorly water soluble substances adopted by ECHA in section R.7.8.5 of Endpoint Specific Guidance R.7.b.

The test item cannot be categorised in accordance with Commission Regulation (EC) No 1272/2008 (Classification Labelling and Packaging) of 16 December 2008.

Justification for classification or non-classification

In accordance with Regulation (EC) 1272/2008 the flammability of liquids are determined based on flash point and boiling point. Flammability in contact with water and pyrophoric properties of liquids must also be assessed.

A flash point was not determined during the relevant study due to foaming of the test item (> 60^oC) (Bär. C, EU Method A.9. (2017)).

Pyrophoric properties of liquids is not applicable based on additional classification criteria (CLP, Annex I, 2.10.4). Practical handling experience shows that the substance does not ignite spontaneously on coming into contact with air at normal temperatures and is stable at room temperature for in excess of twelve months from the date of manufacture.

Flammability in contact with water is not applicable based on additional classification criteria (CLP, Annex I, 2.12.4.1). The test item complies with all three criteria and as such does not meet the classification criteria.