2. AEROSOL AND TRANSPORT
(Classification)
In transport regulations concerning
dangerous goods aerosols have always been
classified in Class 2 (gases).
Transport regulations cover both matters
(substances and mixtures) and articles
3. UN CLASSIFICATION
In the UN Recommendations on the
Transport of Dangerous Goods
aerosols are assigned to Division 2.1
(flammable) or 2.2 (non flammable,
non toxic)
Gases of division 2.3 shall not be used
as propellant
If contents other than propellants are
classified as Division 6.1 or Class 8
(packing group II or III) the aerosols
will have a subsidiary risk 6.1 or 8
4. EUROPEAN CLASSIFICATION (transport)
In European land transport regulations (ADR/RID/ADN) a more
articulated subdivision is in place:
A asphyxiant
O oxidizing
F flammable
T toxic
C corrosive
CO corrosive, oxidizing
FC flammable, corrosive
TF toxic, flammable;
TC toxic, corrosive;
TO toxic, oxidizing;
TFC toxic, flammable, corrosive;
TOC toxic, oxidizing, corrosive
5. QUESTION
A question for industry:
It is necessary,
it is useful,
it is possible,
to harmonize European approach and
international (UN Recommendations, IMDG Code,
ICAO Technical Instructions) one ?
6. FLAMMABLE AEROSOLS
In the 80’s aerosol industries shifted from
CFC propellants which depleted the ozone
layers.
Liquefied flammable gases were then used
as propellants.
7. OLD CLASSIFICATION CRITERIA
(TRANSPORT)
Division 2.1 (flammable gases) applies if the contents
include:
more than 45% by mass
or
more than 250 g
of flammable components.
Flammable components are gases which are
flammable in air at normal pressure or substances or
preparations in liquid form which have a flash point
less than or equal to 100 °C
8. OLD CLASSIFICATION CRITERIA
(EUROPEAN DIRECTIVE )
Based on the content of :
- extremely flammable
- higly flammable
- flammable
components
9. HARMONIZATION (1)
UNCED Rio de Janeiro 1992
Agenda 21
Section 2 chapter 19
19.27. A globally harmonized hazard
classification and compatible labelling system,
including material safety data sheets and
easily understandable symbols, should be
available, if feasible, by the year 2000
10. HARMONIZATION (2)
The Inter-Organization programme for the
sound Management of Chemicals (IOMC),
created by WHO, ILO, UNEP, FAO, OECD and
UNIDO,
with his Coordinating Group for the
Harmonization of Chemical Classification
Systems (CG/HCCS),
was charged to develop the GHS (Globally
Harmonized System of Classification and
Labelling of Chemicals).
11. HARMONIZATION (3)
In that framework an ILO/UNCETDG Working
Group was then charged to develop harmonized
criteria for physical hazards (including aerosol)
Note: UNCETDG (United Nations Committee of
Experts on the Transport of Dangerous Goods)
was recognized as the global expert group on
physical hazards
12. HARMONIZATION (4)
In 1999 UN/ECOSOC established a new structure
UN Committee of Experts on the
Transport of Dangerous Goods and GHS
UN SubCommittee of Experts
UN SubCommittee of
on the Transport of Dangerous
Experts on the GHS
Goods
13. HARMONIZATION (5)
The new SubCommitte on GHS was then
responsible for the development of GHS
and for the future amendment (every two
years)
14. HARMONIZED CRITERIA (1)
Criteria for classification of
flammable aerosols were
lenghty discussed in
several meetings of the
working group.
The main contribution to this discussion came from FEA
(Federation of European Aerosol Associations) and
CSMA (Chemical Specialities Manufacturers
Association), representing the European and the United
States aerosol industry respectively.
15. HARMONIZED CRITERIA (2)
Final agreement was reached in 2000 and criteria
were adopted by UNSCEGHS.
Transport regulations , i.e. UN Recommendations ,
and then ADR/RID/ADN, T.I. Technical Instructions,
IMDG Code, included the new criteria in the following
years.
The same criteria were included in EU legislation
(concerning aerosols) in 2008.
16. HARMONIZED CRITERIA (3)
Basic criteria are based on:
- content of flammable components (gas, liquid, solid)
- chemical heat of combustion
and flammable aerosols can be classified as:
- Category 1 (extremely flammable)
- Category 2 (flammable)
17. HARMONIZED CRITERIA (4)
Decision logic is different for spray and foam aerosol
For spray, it is based on ignition distance test and
enclosed space ignition test
For foam, it is based on foam flammabiliy test
The detailed test procedures can be found in the Manual of
Tests and Criteria, annexed (as a separate publication) to the
UN Recommendations on the Transport of Dangerous Goods
18. BACK TO PAST (1)
The enclosed space ignition test require the use of a
candle .
Not a gas burner or other source of ignition, but just a
candle !
19. BACK TO PAST (2)
If I need to come back to the old candles for testing,
perhaps I can think also to come back to old aerosols
dispensers such as:
