AEROSOLTRANSPORT

GHS

sergio benassai

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

UN CLASSIFICATIONIn 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

EUROPEAN CLASSIFICATION (transport)In European land transport regulations (ADR/RID/ADN) a more articulated subdivision is in place: A asphyxiantO oxidizingF flammableT toxicC corrosive CO corrosive, oxidizing FC flammable, corrosive TF toxic, flammable; TC toxic, corrosive; TO toxic, oxidizing; TFC toxic, flammable, corrosive; TOC toxic, oxidizing, corrosive

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 ?

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.

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

OLD CLASSIFICATION CRITERIA (EUROPEAN DIRECTIVE )

Based on the content of :- extremely flammable - higly flammable - flammablecomponents

HARMONIZATION (1)

UNCED Rio de Janeiro 1992Agenda 21Section 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

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).

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

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 on the Transport of Dangerous

Goods

UN SubCommittee of Experts on the GHS

HARMONIZATION (5)

The new SubCommitte on GHS was then responsible for the development of GHS and for the future amendment (every two years)

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.

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.

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)

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

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 !

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: