Benzene-1,3,5-tricarbonyl trichloride

Flammability

Link to relevant study record(s)

Reference

Reference 1

Endpoint:

pyrophoric solids

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

other:

Justification for type of information:

JUSTIFICATION FOR DATA WAIVING
In accordance with section 1 of REACH Regulation (EC) No. 1907/2006 Annex XI, the study does not need to be performed as based on assessment of the chemical structure pyrophoric properties are not to be expected and this is supported by experience in handling and use for the substance. According to ECHA Guidance on Information Requirements and Chemical Safety Assessment (Chapter R.7a: Endpoint Specific Guidance, R.7.1.10.5, July 2017), pyrophoricity testing is scientifically unjustified.

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 organic substance does not contain metals or metalloids and hence, the classification procedure does not need to be applied

other:

Justification for type of information:

JUSTIFICATION FOR DATA WAIVING
In accordance with section 1 of REACH Regulation (EC) No. 1907/2006 Annex XI, the does not need to be performed as based on assessment of the chemical structure flammability on contact with water properties are not to be expected and this is supported by experience in handling and use for the substance. According to ECHA Guidance on Information Requirements and Chemical Safety Assessment (Chapter R.7a: Endpoint Specific Guidance, R.7.1.10.8, July 2017), flammability on contact with water testing is scientifically unjustified.

Reference 3

Endpoint:

flammable solids

Type of information:

experimental study

Adequacy of study:

key study

Study period:

15-03-2022 to 28-04-2022

Reliability:

1 (reliable without restriction)

Rationale for reliability incl. deficiencies:

guideline study

Remarks:

Guideline study performed under GLP. All relevant validity criteria were met.

Qualifier:

according to guideline

Guideline:

UN Manual of Tests and Criteria: Test N.1 (Test method for readily combustible solids)

Version / remarks:

UN (2019). Recommendations on the Transport of Dangerous Goods Manual of Tests and Criteria (7th ed.), Geneva, United Nations

Deviations:

no

Qualifier:

equivalent or similar to guideline

Guideline:

EU Method A.10 (Flammability (Solids))

Deviations:

no

GLP compliance:

yes (incl. QA statement)

Remarks:

inspected: February 2022 ; signed: April 2022

Key result

Test procedure:

burning rate test: preliminary screening test

Burning time:

> 2 min

Remarks on result:

substance does not ignite and propagate combustion either by burning with flame or smouldering along 200 mm of the powder train within the 2 minutes test period

Interpretation of results:

not classified based on GHS criteria

Conclusions:

The flammable solid properties of the test item was determined in a burning rate test consistent with UN Transport MTC Test N.1. Based upon the results of the preliminary screening test, no propagation of combustion of the test item was observed within a 2 minute test period.

Executive summary:

The flammability of the solid test item was examined using a method consistent with the UN Transport of Dangerous Goods: Manual of Tests and Criteria: Test N.1 (7th ed.) (2019) by measuring the burning rate of the test item. In a preliminary test, the test item was loosely filled into an aluminium mould of 250 mm long with a triangular cross-section of inner height of 10 mm and width of 20 mm. On both sides of the mould in a longitudinal direction two metal plates were mounted as lateral limitations that project 2 mm beyond the upper edge of the triangular cross section. The mould was dropped three times from a height of 2 cm onto a solid surface. If necessary, the mould was filled up again. The lateral limitations were removed and the excess substance was scraped off. A non-combustible and non-porous plate was placed on top of the mould. The complete assembly was inverted and the mould removed. A flame of a gas burner was applied to one end of the test item pile for 2 minutes. The pile was visually interpreted for propagation of combustion either by burning with a flame or smouldering. If applicable, the time of burning over a distance of 200 mm was measured after the pile had burned a distance of 50 mm. If the test item does not propagate combustion along 200 mm of the pile within the 2 minutes test period the test item is considered ‘not flammable’. Any other result requires further examination within a definitive test. In contact with the flame of the gas burner the test item melted into a clear liquid and partly reduced into a blackened residue. Grey smoke was observed. After removal of the ignition source, no propagation of combustion of the test item was observed. No propagation of combustion of the test item along 200 mm length of the pile within a 2 minutes test period was observed. According to the guidelines, performance of the burning rate test is not required. Based on the results obtained, the test item is considered ‘not flammable’.

Description of key information

Flammability: Not flammable
(1) No pyrophoric properties based on absence of pyrophoric chemical groups
(2) Not flammable on contact with water based on absence of relevant chemical groups
(3) Flammability solids: non-flammable solid : preliminary screening test: no propagation of combustion of the test item was observed within a 2 minute test period, UN Transport MTC: Test N.1, 2022

Key value for chemical safety assessment

Flammability:

not classified

Additional information

Flammability:
In accordance with section 1.2 of REACH Regulation (EC) No. 1907/2006 Annex XI further study of flammability does not need to be completed based on weight of available evidence and structural assessment along with experience of handling and use. 

The flammability of the solid test item was examined using a method consistent with the UN Transport of Dangerous Goods: Manual of Tests and Criteria: Test N.1 (7th ed.) (2019) by measuring the burning rate of the test item. In a preliminary test, the test item was loosely filled into an aluminium mould of 250 mm long with a triangular cross-section of inner height of 10 mm and width of 20 mm. On both sides of the mould in a longitudinal direction two metal plates were mounted as lateral limitations that project 2 mm beyond the upper edge of the triangular cross section. The mould was dropped three times from a height of 2 cm onto a solid surface. If necessary, the mould was filled up again. The lateral limitations were removed and the excess substance was scraped off. A non-combustible and non-porous plate was placed on top of the mould. The complete assembly was inverted and the mould removed. A flame of a gas burner was applied to one end of the test item pile for 2 minutes. The pile was visually interpreted for propagation of combustion either by burning with a flame or smouldering. If applicable, the time of burning over a distance of 200 mm was measured after the pile had burned a distance of 50 mm. If the test item does not propagate combustion along 200 mm of the pile within the 2 minutes test period the test item is considered ‘not flammable’. Any other result requires further examination within a definitive test. In contact with the flame of the gas burner the test item melted into a clear liquid and partly reduced into a blackened residue. Grey smoke was observed. After removal of the ignition source, no propagation of combustion of the test item was observed. No propagation of combustion of the test item along 200 mm length of the pile within a 2 minutes test period was observed. According to the guidelines, performance of the burning rate test is not required. Based on the results obtained, the test item is considered ‘not flammable’.

Other measures of flammability include pyrophoricity and flammability on contact with water. These can be considered not a concern for the substance and testing waived if consideration of the structure and experience in handling and use show that no effects are envisaged. Such a screening procedure represents an intelligent testing strategy for flammability. If applied correctly then only liquid substances for which it is suspected will give a positive result in either the pyrophoric properties or flammability on contact with water tests need to be tested.

A review of the structure suggests that there are no chemical groups present that would imply pyrophoric properties or flammability on contact with water. A review of handling and used implies no pyrophoric properties or flammability on contact with water. Based on the absence of structural alerts and experience in handling and use negative results are predicted for pyrophoric properties and flammability of contact with water. Based on the preliminary screening tests for solids flammability, the substance is not considered to be flammable.

References:
1. UN Transport of Dangerous Goods Manual of Tests and Criteria, Seventh Edition (2019)
2. Bretherick (1999) Bretherick’s Handbook of Chemical Reactive Hazards: An Indexed Guide to Published Data, 6th Edition (2 volume set).
3. ECHA Guidance on Information Requirements and Chemical Safety Assessment (Chapter R.7a: Endpoint Specific Guidance, R.7.1.10, July 2017)
4. REACH Regulation (EC) 1907/2006, Annex XI, section 1
5. CLP Regulation (EC) 1272/2008, Annex I, section 2.6 and 2.7
6. ECHA Guidance on Application on the CLP Criteria, section 2.6 and 2.7 (v5.0, July 2017)

Justification for classification or non-classification

The substance does not meet classification criteria under Regulation (EC) No 1272/2008 for flammable solids