Written on: May 1, 2025 by Nicholas Georges
The Household & Commercial Products Association’s (HCPA) Aerosol Products Division recently created a task force to explore developing a new voluntary industry standard; this is in order to avoid proposed amendments to aerosol fire and building codes that could create unsafe storage conditions and cause confusion in distribution channels.
Last year, fire officials proposed to amend a number of codes for a variety of products within the International Fire Code to align with the Globally Harmonized System of Classification & Labeling of Chemicals (GHS), arguing that the Safety Data Sheet (SDS) is typically the only available information they have about flammability to verify the proper design of buildings and warehouses. HCPA strongly opposed these efforts for aerosol fire and building codes. While fire officials changed many sections of the codes to align with GHS, aerosol fire and building codes were not among them.
Since the 1980s, the aerosol products industry has been collecting data to support the development and maintenance of these codes. Based on this data, HCPA’s fire code experts know that using GHS codes for certain aerosol products could result in unsafe storage conditions.
For example, metal and plastic aerosols have different codes because the same fire protection schemes cannot adequately protect both containers in the same manner. If these codes were to change to align with GHS, this difference would not exist and could result in a warehouse fire.
Alignment with GHS could also cause confusion among stakeholders across distribution channels. Under the current fire codes, aerosol products are assigned a “level” based on either the chemical heat of combustion or the formulation, which are both dependent on the type of container used for the product. A “level 1” aerosol product contributes a minimal amount of energy to the fire and requires the least amount of protection for an aerosol product, whereas a “level 3” aerosol product contributes a significant amount of energy to the fire and requires a more enhanced fire protection scheme to provide sufficient protection. Under the GHS, levels are assigned based on tests related to how the product sprays, in addition to the contents within the container. In these instances, a “level 3” aerosol product has minimal flammability, while a “level 1” aerosol product is the most flammable. Changing the fire codes to align with GHS would reverse the meaning of the levels printed on the outside of the container and result in confusion among the distribution channels attempting to manage both systems at the same time.
While HCPA has been able to protect aerosol fire and building codes from alignment with GHS in this cycle, there is no guarantee that we will be successful in the future—even with data on our side. For this reason, HCPA has established a task force within the Aerosol Products Division to explore a potential voluntary industry standard that would provide fire officials with additional information related to aerosol fire and building codes in the SDS.
Some aerosol companies are already providing the aerosol storage level and/or chemical heat of combustion on the SDS; agreeing on the section for this information will be critical so that fire officials know where to find it.
Should the task force develop and agree on a voluntary industry standard, HCPA will be following its standard-setting procedures, which include a period for public comment before finalization. While HPCA represents many companies in the aerosol space, it is critically important that every aerosol company has the opportunity to review and contribute to the standard in order maximize its effectiveness.
Modifying SDS templates is not ideal, but it is certainly better than changing the current aerosol fire and building codes so significantly that:
1. Storage conditions are not sufficient in the event of a fire; and
2. They cause confusion in distribution channels.
If you would like to get involved in the HCPA task force working on this issue, please contact me at ngeorges@thehcpa.org. SPRAY
