The document discusses the evolution of flammable aerosol testing under HCS regulations from 1994 to 2012, highlighting changes in criteria for categorizing aerosols based on flammability. It details testing methods, including the ignition distance test for spray and foam aerosols, and emphasizes safety considerations. Additionally, it compares the testing equipment and procedures of the past with current standards, providing a comprehensive overview of the necessary steps for compliance and safety evaluation.

1. Flammable Aerosol Testing for
HCS 2012 (GHS)
Joe McCarthy, Lab Services Manager/Regulatory Affairs Specialist

2. 1. THEN vs. NOW
- And why a product that was not flammable
THEN may very well be flammable NOW.
2. Performing the tests
- Catching Fire, what is sustained combustion?
3. Safety considerations
- Fire is not the only way to get burned.

3. HCS 1994 (THEN) vs. HCS 2012 (NOW)
HCS 1994 (THEN)
means an aerosol that, when
tested by the method described in
16 CFR 1500.45, yields a flame
projection exceeding 18 inches at
full valve opening, or a flashback
(a flame extending back to the
valve) at any degree of valve
opening;
HCS 2012 (NOW)
Category 1
Contains ≥ 85% flammable components and the chemical heat of
combustion is ≥ 30 kJ/g; or
a) For spray aerosols, in the ignition distance test, ignition occurs
at a distance ≥ 75 cm (29.5 in),
or
b) For foam aerosols, in the aerosol foam flammability test
(i) the flame height is ≥ 20 cm (7.87 in) and the flame duration ≥ 2
s; or
(ii) the flame height is ≥ 4 cm (1.57 in) and the flame duration ≥ 7 s
Category 2
Contains > 1% flammable components, or the heat of combustion
is ≥ 20 kJ/g; and
a) For spray aerosols, in the ignition distance test, ignition occurs
at a distance ≤ 15 cm (5.9 in),
or
in the enclosed space ignition test, the
(i) time equivalent is ≤ 300 s/m3; or
(ii) Deflagration density is ≤ 300 g/m3
b) For foam aerosols, in the aerosol foam flammability test, the
flame height is ≥ 4 cm and the flame duration is ≥ 2 s and it does
not meet the criteria for Category 1

4. 1. Can be tested using ASTM D240-02, ISO 13943, NFPA 30B
2. Calculated as a weighted sum of the individual components.
n
ΔHc (product) = ∑ [wi% × ΔHc(i)]
i
Literature data available from: NFPA 30B, NIST, CRC, Perry’s Chemical
Engineers Handbook, etc.
Heat of Combustion (ΔHc)

5. THEN
1500.45 Method for determining extremely flammable and flammable contents of self-pressurized
containers.
(a) Equipment required. The test equipment consists of a base 8 inches wide, 2 feet long, marked in 6-
inch intervals. A rule 2 feet long and marked in inches is supported horizontally on the side of the
base and about 6 inches above it. A paraffin candle 1 inch or more in diameter, and of such height
that the top third of the flame is at the height of the horizontal rule, is placed at the zero point in the
base.
(b) Procedure. The test is conducted in a draft-free area that can be ventilated and cleared after each test.
Place the self-pressurized container at a distance of 6 inches from the flame source. Spray for periods
of 15 seconds to 20 seconds (one observer noting the extension of the flame and the other operating
the container) through the top third of the flame and at a right angle to the flame. The height of the
flame should be approximately 2 inches. Take three readings for each test, and average. As a
precaution do not spray large quantities in a small, confined space. Free space of previously
discharged material
Flame Projection/Flashback (THEN) vs. Ignition Distance Test (NOW)
NOW

6. 16CFR1500.45 (THEN) vs. Ignition Distance Test (NOW)
THEN
Fixed Ignition point (6”), Is the flame projection > 18”? Is there a flashback?
NOW
Increasing ignition point in 15 cm (6”) intervals. Is there sustained combustion?

7. 16CFR1500.45 (THEN) vs. Ignition Distance Test (NOW)
THEN
1 inch candle, flame height 2”
1400°C (2550°F)
NOW
Gas burner w/ blue non-luminous
flame 4-5 cm (1-1.5”) height
Methane – 1917°C (3484°F)
Propane – 1972°C (3583°F)
Butane – 1967°C (3573°F)

8. Same Product: Candle vs. Gas Flame
Click on image to play

9. 16CFR1500.45 (THEN) vs. Ignition Distance Test (NOW)
Discharge
Time
Orientation Fill # Tests
THEN
NOW

10. Same product: No Shaking vs. Shaking before use.
Click on image to play

11. 16CFR1500.45 (THEN) vs. Ignition Distance Test (NOW)
6” 12” 18” 24” 30” 36”
15cm 30cm 45cm 60cm 75 cm 90cm
Flammable
Flammable
Category 2
Category 1Do ESIT
THEN
NOW

12. Enclosed Space Ignition Test (ESIT)

13. Enclosed Space Ignition Test
2 calculations, only one needs to be met for inclusion in Category 2
Time equivalent (teq, in seconds) needed to achieve ignition
teq = 1000 x discharge time (s) .
Actual volume of drum (dm3)
Confirm the volume of your drum!
Deflagration density (Ddef, in g/m3) needed to achieve
Ddef = 1000 x Amount of product dispensed (g)
Actual volume of drum (dm3)

14. Foam Flammability Test


“foam aerosol” means the content that is dispensed from an aerosol dispenser
having a spray distance of less than 15 cm and that is in the form of a foam, mousse,
gel or paste.
“spray aerosol” means the content that is dispensed from an aerosol dispenser
and that is not a foam aerosol.

15. Foam Flammability Test
≥ 20 cm & ≥ 2 s ≥ 4 cm & ≥ 7 s ≥ 4 cm & ≥ 2 s
00:00:02 00:00:07 00:00:02
Category 1 Category 2

16. Foam Flammability Test – How to measure
Align ruler with base of watch glass Rim of the watch glass should line up at 20 mm
 
~ 5 g of product no more than 25 mm (~1”) high

17. Foam Flammability Test – How to Measure
31.6.3.2(h)(i) “The maximum height of the flame in cm above the base of the watchglass”
31.6.4.1(b) “Maximum flame height in cm”

Click on image to play
Measure from base of the watchglass, not top of the foam

18. Foam Flammability Test
30s
1 min
2 min
4 min

19. The aerosol is sprayed in the direction of an ignition source at intervals of 15 cm to
observe if ignition and sustained combustion of the spray takes place. Ignition and
sustained combustion is defined as when a stable flame is maintained for at least 5 s.
Ignition Distance Test – Sustained Combustion
Lubricant / Water Dispersant
Click on image to play

20. Lubricant / Water Dispersant with extension tube
Click on image to play

21. Click on image to play
Solvent Degreaser

22. Roller Chain Lubricant
Click on image to play

23. Enclosed Space Ignition Test (ESIT)
Click on image to play
Air Freshener

24. Enclosed Space Ignition Test (ESIT)
Air Freshener
Click on image to play

25. Enclosed Space Ignition Test (ESIT)
Air Freshener
Click on image to play

27. Enclosed Space Ignition Test (ESIT)
Electronics Duster
Click on image to play

28. 31.5.1.1 “If an observable ignition occurs, the elapsed time &
amount discharged is noted”

29. Enclosed Space Ignition Test (ESIT)
Click on image to play
Glass Cleaner

30. Enclosed Space Ignition Test (ESIT)
Glass Cleaner

31. Enclosed Space Ignition Test (ESIT)
Foaming Hard Surface Cleaner
Click on image to play

32. Substance TWA STEL IDLH
Odour
detection
threshold
Odour description Sources
Phosgene
(Carbonyl Chloride)
(COCl2, 75-44-5)
0.1 0.5 2 0.4
Fresh cut grass, hay,
corn
Combustion/pyrolysis Perchloroethylene,
chlorinated solvents
Hydrogen Fluoride
(HF, 7664-39-3)
0.5 2 30 0.04
Sharp, pungent,
irritating
Combustion/pyrolysis Fluorinated
compounds
Carbonyl Fluoride
(COF2, 353-50-4)
2 5 ? ?
Sharp, pungent,
irritating
Combustion/pyrolysis Fluorinated
compounds
Chlorine
(Cl2, 7782-50-5)
0.5 1 10 0.5 Chlorine bleach
Combustion/pyrolysis Perchloroethylene,
chlorinated solvents
Hydrogen Chloride
(HCl, 7647-01-0)
5 2 50 0.7 Sharp pungent
Combustion/pyrolysis Perchloroethylene,
chlorinated solvents
Hydrogen Cyanide
(HCN, 74-90-8)
5 4.7 50 5 Almond Combustion of polyurethanes
Perchloroethylene
(C2Cl4, 127-18-4)
25 100 1500 50
Sweet like
chloroform
Used in brake cleaners
TWA
“TWA” or “time-weighted average limit” is the time-weighted average airborne concentration to which a worker may be exposed in a work day or
work week.
STEL STEL = “Short-term exposure limit” means the maximum airborne concentration to which a worker may be exposed in any 15-minute period.
IDLH Immediately Dangerous to Life or Health
EXPOSURE LIMITS OF SELECTED TOXIC GASES