AEROSOL AND TRANSPORT (Classification)In transport regulations concerningdangerous goods aerosols have always beenclassified in Class 2 (gases).Transport regulations cover both matters(substances and mixtures) and articles
UN CLASSIFICATIONIn the UN Recommendations on theTransport of Dangerous Goodsaerosols are assigned to Division 2.1(flammable) or 2.2 (non flammable,non toxic)Gases of division 2.3 shall not be usedas propellantIf contents other than propellants areclassified as Division 6.1 or Class 8(packing group II or III) the aerosolswill have a subsidiary risk 6.1 or 8
EUROPEAN CLASSIFICATION (transport)In European land transport regulations (ADR/RID/ADN) a morearticulated 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
QUESTIONA question for industry:It is necessary,it is useful,it is possible, to harmonize European approach andinternational (UN Recommendations, IMDG Code,ICAO Technical Instructions) one ?
FLAMMABLE AEROSOLSIn the 80’s aerosol industries shifted fromCFC propellants which depleted the ozonelayers.Liquefied flammable gases were then usedas propellants.
OLD CLASSIFICATION CRITERIA (TRANSPORT)Division 2.1 (flammable gases) applies if the contentsinclude:more than 45% by mass ormore than 250 gof flammable components.Flammable components are gases which areflammable in air at normal pressure or substances orpreparations in liquid form which have a flash pointless than or equal to 100 °C
OLD CLASSIFICATION CRITERIA (EUROPEAN DIRECTIVE ) Based on the content of : - extremely flammable - higly flammable - flammable components
HARMONIZATION (1)UNCED Rio de Janeiro 1992Agenda 21Section 2 chapter 1919.27. A globally harmonized hazardclassification and compatible labelling system,including material safety data sheets andeasily understandable symbols, should beavailable, if feasible, by the year 2000
HARMONIZATION (2)The Inter-Organization programme for thesound Management of Chemicals (IOMC),created by WHO, ILO, UNEP, FAO, OECD andUNIDO,with his Coordinating Group for theHarmonization of Chemical ClassificationSystems (CG/HCCS),was charged to develop the GHS (GloballyHarmonized System of Classification andLabelling of Chemicals).
HARMONIZATION (3)In that framework an ILO/UNCETDG WorkingGroup was then charged to develop harmonizedcriteria for physical hazards (including aerosol)Note: UNCETDG (United Nations Committee ofExperts on the Transport of Dangerous Goods)was recognized as the global expert group onphysical 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 UN SubCommittee ofon the Transport of Dangerous Experts on the GHS Goods
HARMONIZATION (5)The new SubCommitte on GHS was thenresponsible for the development of GHSand for the future amendment (every twoyears)
HARMONIZED CRITERIA (1)Criteria for classification of flammable aerosols were lenghty discussed inseveral meetings of theworking group.The main contribution to this discussion came from FEA(Federation of European Aerosol Associations) andCSMA (Chemical Specialities ManufacturersAssociation), representing the European and the UnitedStates aerosol industry respectively.
HARMONIZED CRITERIA (2)Final agreement was reached in 2000 and criteriawere 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 followingyears.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 combustionand flammable aerosols can be classified as:- Category 1 (extremely flammable)- Category 2 (flammable)
HARMONIZED CRITERIA (4)Decision logic is different for spray and foam aerosolFor spray, it is based on ignition distance test andenclosed space ignition testFor foam, it is based on foam flammabiliy testThe detailed test procedures can be found in the Manual ofTests and Criteria, annexed (as a separate publication) to theUN Recommendations on the Transport of Dangerous Goods
BACK TO PAST (1)The enclosed space ignition test require the use of acandle .Not a gas burner or other source of ignition, but just acandle !
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 aerosolsdispensers such as: