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In the aquatic environment the effects of HCl are clearly related to the pH effect, as HCl will dissociate fully in H3O+ & Cl- ions, of which the latter is not a harmful substance. The substance itself thus will not reach the sediment/terrestrial environment. Exposure via air is limited since the use of HCl as a gas is not supported by the LC. According to column II of annex iV/X the test can thus be waived