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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:
The substance is produced, marketed and used only in solution. As it is not possible to isolate the pure solid substance, the study can not be conducted.
Instead, a flash point study performed with a solution of Benzyltrimethylammonium hydroxide in methanol is available.
Reason / purpose for cross-reference:
data waiving: supporting information
flash point of flammable liquids
Type of information:
experimental study
Adequacy of study:
key study
Study period:
from 13 April 2018 to 09 May 2018
1 (reliable without restriction)
Rationale for reliability incl. deficiencies:
test procedure in accordance with generally accepted scientific standards and described in sufficient detail
Justification for type of information:
The substance can be produced through different process routes, yielding solutions in water or organic solvent (e.g. methanol or ethylene glycol).
It was initially unclear how to register the substance (mono-constituent or multi-constituent substance) and which manufactured substance to test to fulfil the REACH data requirements. After consultation with the ECHA helpdesk, the test program was started with the manufactured substance of the Lead registrant (solvent: methanol) in which the highest amount of solvent could be removed without causing degradation of the substance. This resulted in the selection of a solution of 56-57% BTMAOH in methanol as test substance.
During the course of the test program, and in order to aid meaningful risk assessment, after consultation with ECHA and upon ECHA's recommendation, it was considered to be more appropriate to test the water-based manufactured substance. As a consequence, some testing was performed with a BTMAOH solution in methanol, and some testing was performed with a BTMAOH solution in water.

The current entry reflects a test performed with a methanol-based test solution.
equivalent or similar to guideline
EU Method A.9 (Flash-Point)
Version / remarks:
according to guideline
other: ASTM D7094: “Standard Test Method for Flash Point by Modified Continuously Closed Cup (MCCCFP) Tester”
Version / remarks:
according to guideline
ISO 2719 (Determination of flash point - Pensky-Martens closed cup method)
Version / remarks:
see field below
Principles of method if other than guideline:
remark of reviewer:
Several non-equilibrium methods are mentioned in the EC A.9 guideline. According to the study report the study was performed according to ISO Guide 2719 (Pensky-Martens closed cup). However, from the description of the test performance and the flash-point tester it was concluded that ASTM D7094 (modified continuously closed cup) is more applicable. ASTM D7094 is not mentioned in the EC A.9 guideline but is a commonly used and safer (low sample volume) alternative for the ISO 2719 method.
GLP compliance:
Type of method:
non-equilibrium method closed cup
Flash point apparatus:
other: Eraflash (Eralytics, Austria)
Dynamic viscosity of test material:
Key result
Atm. press.:
1 013 hPa
Remarks on result:
not determinable, other reason:
no flash point up to possible reaction/decomposition at 94°C
Interpretation of results:
other: not classified under CLP or GHS
The tested BTMAOH solution in methanol has no flash point.
Executive summary:

The modified continuously closed cup ASTM D7094 method (GLP study) was performed. A solution of Benzyltrimethylammonium hydroxide in methanol was tested. No flash-point was observed below the temperature at which reaction and/or degradation was observed (i.e at ca 94°C). Thus the tested solution has no flash point. However, this conclusion may not be applicable to test solutions containing a higher percentage of methanol.  

Data source

Materials and methods

Results and discussion

Applicant's summary and conclusion

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