Flammable Aerosol Testing for HCS 2012 (GHS)

dell tech laboratories ltd. 1
FLAMMABLE AEROSOL TESTING FOR
HCS 2012 (GHS)
JOE MCCARTHY, LAB SERVICES MANAGER/REGULATORY AFFAIRS SPECIALIST

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.

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

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)

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

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?

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)

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

Discharge
Time
Orientation Fill # Tests
THEN
NOW

Same product: No Shaking vs. Shaking before use.

6” 12” 18” 24” 30” 36”
15cm 30cm 45cm 60cm 75 cm 90cm
Flammable
Flammable
Category 2
Category 1Do ESIT
THEN
NOW

Enclosed Space Ignition Test (ESIT)

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)

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.
Foam
Aerosols
Not Foam
Aerosols

≥ 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

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

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”

Measure from base of the watchglass, not top of the foam

30s
1 min
2 min
4 min

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

Lubricant / Water Dispersant with extension tube

Solvent Degreaser

Roller Chain Lubricant

Air Freshener

Electronics Duster

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

Glass Cleaner

Foaming Hard Surface Cleaner

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
Hydrogen Chloride
(HCl, 7647-01-0)
5 2 50 0.7 Sharp pungent
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

Questions/Comments?
Joe McCarthy
Lab Services Manager/Regulatory Affairs Specialist
jmccarthy@delltech.com
519-858-5024
Product Safety - Regulatory Affairs – Lab
Services
www.delltech.com

Flammable Aerosol Testing for HCS 2012 (GHS)

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