In April, the British Aerosol Manufacturers’ Association (BAMA) completed its filling statistics survey for 2023; the volume filled was roughly at the same level in 2023 as it was in 2022—just over 1.4 billion cans. Aerosol filling in the UK has been bouncing around the 1.3 to 1.5 billion mark for about 10 years now. In those years, we have lost some filling companies, some products have migrated overseas and other products have moved to the UK.
Elsewhere across Europe, filling figures have also remained fairly consistent, with single-digit growth in many markets and small reductions in others. This raises the question as to whether the use of aerosol dispensers in most Western economies has reached its peak—or, perhaps, we have passed the peak?
Some markets, such as Southeast Asia, China and Latin America, are still seeing positive growth. In Europe and the U.S., often in spite of legislative efforts, aerosol usage has barely changed.
The product mix has certainly evolved. The growth of powder-based antiperspirants filled in the UK continues to grow year on year, as does alcohol-based deodorants. Much of this growth can be put down to a few major brands who, through the combination of high-quality products and performance accompanied by canny advertising and marketing, find new users and new markets every year. However, much of the growth seen in UK aerosol fillings goes to export. The use of aerosols by UK consumers has only grown in relation to the increase in population over the last 20 years.
This brings us back to my question: Have we reached “peak aerosol” with Western consumers? Certainly, in my years in the industry, there haven’t been any major new products launched in aerosol dispensers. As innovative as the development of barrier pack systems were, all they really did was move consumers from shave foam to shave gel. A better consumer experience undoubtedly, but not a move to grow a significant new market.
Can we break new ground?
There have been some novel ideas, such as silicone sealants and builders’ caulk in pressurized packs. Any amateur DIYers (like me) who have struggled with a caulk gun will know how much simpler the aerosol version is to use. There have been a variety of foods put into aerosol cans across Europe. My favorite was a short-lived product that put churro batter into an aerosol can. A fabulous idea, but food in aerosols is something consumers in Europe, particularly, just don’t seem to get—unless it’s whipped cream,
of course.
Anyone who has formulated an aerosol, or played around with the enormous range of valve and actuator systems that are available, knows the scope of products that the humble aerosol can is able to dispense. As the pallet of ingredients, especially preservatives, becomes smaller, one has to wonder if there is a bigger market for a dispensing system that keeps the product hermetically sealed throughout its life, even while the consumer is using it. I’m sure we all have seen the growth in ranges of airless pumps over recent years. Shouldn’t these products be being filled into an off-the-shelf, already available, airless dispenser with a proven capability?
Here’s the challenge for the aerosol industry: We have a trusted, proven, versatile, recyclable package. How do we find new markets, new designs and new styles to take the aerosol dispenser beyond its current markets and break new ground? SPRAY
Hello everyone. In previous editions of Corrosion Corner, I’ve discussed the cost of in-market corrosion failures. These are package corrosion failures that occur with an existing or derivative commercial product.
In this issue’s column, I’m going to refine the prior discussions on in-market failures and add in-development failures from package corrosion observed during new/derivative product development.
The parameters for calculating failure-costs are summarized in Table 1.
These types of failures have costs that include internal budget costs, out-of-pocket costs, and loss of revenue when a fraction of a firm’s consumers/customers switch to a competitor’s brand when a failure occurs.
The numbers in Table 1 are from discussions with multiple attorneys, our current research on package-failure cost and experience. The actual numbers for each company could be different from those used here.
Table 2 lists the typical number of full-time employees (FTE) on a team investigating both in-development and in-market package failures. The last row of Table 2 summarizes all the yearly FTE costs for in-development and in-market failures.
These examples of calculations for both types of failure costs assume:
• Annual expected sales of $15 million
• A one-year manufacturing delay
• A 20% brand-loyalty revenue loss for five years for an in-market failure with personal injury litigation
• A 50% brand-loyalty revenue loss for five years for in-market failure with wrongful death litigation
Let’s begin with in-development failures caused by package corrosion that occurs during development of a new or a derivative product.
Solving In-development failures for new and derivative products typically involve the FTE personnel listed in the first three rows of Table 2. In-development failure costs are typically resolved within 1–2 years; manufacturing begins shortly thereafter. The costs for 1–2 years are:
• $15,573,948 for a 1-year resolution
• $31,147,896 for a 2-year resolution
In-market failures of commercial products are significantly more costly than in-development failures. Indeed, during my more than five decades of corrosion research and experience, I’ve witnessed examples where a single in-market failure negated decades of profits for a given brand.
In-market failures are more complex, involve more people and have escalating costs as the consequences of the failure become more severe, such as litigation, product recall and revenue loss from reduced brand loyalty.
Table 3 summarizes several scenarios for in-market failure costs that are resolved after one year, using the same assumptions as those for the in-development cost examples. Each row in Table 3 provides a different failure-cost scenario with the estimated cost for each scenario in the last column of each row.
Table 3 illustrates that, as the consequences of a failure become more severe, the costs increase significantly from only paused manufacturing to scenarios involving an in-pantry recall, lost brand-loyalty revenue and litigation. Indeed, a failure resulting in only lost revenue from a manufacturing pause ($15,940,637) is significantly less expensive than a failure where revenue is lost from all consequences of the most expensive litigation ($183,440,637).
How do you minimize the probability of financial losses from in-development and in-market failures? A comprehensive, corrosion control program is needed to minimize the occurrence of both in-development and in-market failures.
A corrosion control program includes corrosion testing and is typically inside a company’s R&D program. The costs of an internal corrosion control program with 2–4 FTE would range from approximately $573,948 to $1,147,896 per year.
Thus, the cost for a corrosion control program is significantly less than the costs for both in-development failures and in-market failures, particularly when an in-market failure involves product recall, litigation and loss of brand loyalty!
Therefore, why doesn’t/wouldn’t your company have a comprehensive internal corrosion control program?
Thanks for your interest and I’ll see you in August. Contact me at 608-831-2076; rustdr@pairodocspro.com or from our two websites: aristartec.com and pairodocspro.com. SPRAY
SCAQMD
In May, the South Coast Air Quality Management District (SCAQMD) held two workgroup meetings.
May 21
SCAQMD staff held its second workgroup meeting concerning Rule 1151 Automotive Refinish Coatings. SCAQMD is attempting to prohibit parachlorobenzotrifluoride (PCBTF) and tertiary butyl acetate (tBAc) from Automotive Refinish Coatings. SCAQMD amended its rule 1168 on Adhesives last year to accomplish the same task.
For Rule 1151, SCAQMD is considering raising the volatile organic compound (VOC) limits higher in certain categories to make it easier for manufacturers to reformulate without PCBTF and tBAc. This is a significant move for SCAQMD, as raising VOC limits is not something that it usually does. The higher limits for these coating categories would be either the current European VOC limit or the current U.S. Environmental Protection Agency (EPA) VOC limit for Refinish Coatings. By raising the category limits, SCAQMD staff will be able to phase out these compounds at a much faster pace; staff is currently considering a two-year phase-out schedule to eliminate PCBTF and tBAc.
SCAQMD will initially raise the VOC limits for certain categories that have PCBTF and tBAc so that formulators can remove these compounds with VOCs. SCAQMD will then set another schedule to once again lower these certain categories where the VOC is being raised. It is a two-step process. Ultimately, SCAQMD wants VOC limits to return to where they are now.
May 29
This workgroup meeting pertained to Rule 1171 Solvent Cleaning, which is similar to Rule 1151 and Rule 1168, and was developed to phase out the use of PCBTF and tBAc. However, SCAQMD staff found little use of these two compounds in Solvent Cleaning products. Thus, the focus has changed.
SCAQMD staff is now focused on the 160 fluid ounce/per day exemption for Aerosol Products, which has been in the Rule since 1996. Staff has found aerosol product that exceeds its 25g/l limit but meets current California Air Resources Board (CARB) limits for the Aerosol Products category. It is worth noting that some of the products found may exceed CARB limits for Aerosol Products; if true, the products could then be subject to enforcement actions.
Currently, staff believes removing the exemption could have an effect on small cleaning operations, as well as dealerships and auto repair/collision repair shops.
Staff has stated that its next meeting is set for the third quarter and the Board hearing to finalize the rule is set for the fourth quarter. Thus, we need to review this exemption quickly and get comments back to SCAQMD.
AIM Act
For months now, we have shared information on the EPA American Innovation & Manufacturing (AIM) Act. As a reminder, as of Jan. 1, 2025, EPA is restricting the use of all hydrofluorocarbons (HFCs) with a Global Warming Potential (GWP) greater than 150 in aerosol products (some categories are an exception, and will have until Jan. 1, 2028, to utilize HFCs higher than 150 GWP).
Therefore, as of Jan. 1, 2028, all aerosols can only use HFCs with a GWP of 150 or less. This includes an extension for the use of HFC-43-10mee and HFC-245fa in aerosols until Jan. 1, 2028. Remember, HFC-152a has a less-than 150 GWP and therefore is not restricted under this rule.
First labeling reminder
Companies need to be aware that the use of any HFC, including HFC-152a, for any aerosol product—other than technical aerosol products listed in the rule, metered dose inhalers and defense sprays—the label must disclose the HFC[s] that are in the product, starting Jan. 1, 2025. For the technical products listed in the rule, the label must disclose the HFC[s] that are in the product starting Jan. 1, 2028.
It is important to note that the deadlines—including label disclosure—are for products manufactured on those dates and beyond. There are no restrictions on products manufactured before those dates under the AIM Act (although please be aware of the restrictions/requirements that individual States may have on certain HFCs). SPRAY
On May 20, the U.S. Occupational Safety & Health Administration (OSHA) published a final rule 1 to update the Hazard Communication Standard (HCS) from the Globally Harmonized System of Classification & Labeling of Chemicals (GHS) Revision 3 to GHS Revision 7 with elements of Revision 8. OSHA made these amendments to not only enhance worker protections, but to also align with Health Canada’s Workplace Hazardous Materials Information System (WHMIS).
The scope and framework of the HCS have not changed. Chemical manufacturers and importers are still responsible for providing information about the hazards of chemicals they produce or import, and not every safety data sheet (SDS) and label is impacted. Even so, it’s important to be aware of the various changes.
OSHA has created materials to help highlight the various areas that have been amended, including a Questions & Answers document 2 for the update and a side-by-side comparison document.3 I have also called out some of the changes that I think are relevant for SPRAY readers:
• Label and SDS updates align primarily with GHS Revision 7.
• OSHA had originally proposed to require that a label include the date a chemical is released for shipment; however, OSHA did not implement this change after reviewing comments from stakeholders. Chemicals that have been released for shipment, and are awaiting future distribution, do not need to be relabeled with an update; however, companies must provide an updated label for each individual container with each shipment.
• The existing Flammable Aerosols hazard class (Appendix B.3) has been expanded to include non-flammable aerosols. OSHA is also revising a note (now B.3.1.2.1) to explain that aerosols do not fall within the scope of gases under pressure, but may fall within the scope of other hazard classes.
o OSHA will not allow the optional use of the compressed gas pictogram for aerosol products because it would introduce inconsistency between labels of similar products, cause confusion for downstream users and lead to “over warning.”
• OSHA has included special labeling provisions for 3mL and 100mL small containers, similar to Health Canada’s WHMIS requirements.
• While OSHA still allows the use of concentration ranges when the exact percentage is claimed as a trade secret, OSHA has aligned with the prescribed concentration ranges used by Health Canada’s WHMIS.
• OSHA is allowing the use of non-animal test methods from GHS Revision 8 for skin corrosion/irritation.
OSHA developed a tiered approach for companies and employers to comply with the amended HCS. The final rule takes effect July 19, 2024, and companies should be aware of the following compliance dates:
• Substances
o Manufacturers, importers and distributors that evaluate substances shall be in compliance with all modified provisions no later than Jan. 19, 2026.
o All employers shall, as necessary, update any alternative workplace labeling used by July 20, 2026.
• Mixtures
o Chemical manufactures, importers and distributors that evaluate mixtures shall be in compliance no later than July 19, 2027.
o All employers shall update any alternative workplace labeling for mixtures by Jan. 19, 2028.
Beginning July 19, 2024, companies may comply with either the 2012 HCS (previous standard) or the new amended standard until the compliance dates noted above.
It should be noted that Health Canada’s compliance dates are before OSHA’s and previous attempts at delaying those dates have been for naught, as Health Canada was not willing to extend without knowing when OSHA’s compliance dates will be. Hopefully, with OSHA’s final rule published, we will be able to work with the Canadian Consumer Specialty Products Association (CCSPA) and other allied Canadian trade associations to align the compliance dates between Canada and the U.S.
For further information, please contact me at ngeorges@thehcpa.org. SPRAY
The New York Society of Cosmetic Chemists (NYSCC) will host its annual golf outing on Monday, July 29, at the Crystal Springs Resort in Hamburg, NJ.
The event will begin at 9 a.m. ET, and includes a box lunch, 18-hole scramble golf, dinner, cocktail hour and prize. Tickets are priced at $220 for SCC members and $235 for non-members. There is also a Beginner’s Clinic (which includes the box lunch, dinner, cocktail hour and prize) for $150, and tickets for just the gala dinner can be purchased for $75.
Participants can also take advantage of a special rate if booking a hotel room at the resort by mentioning NYSCC when making a reservation. For full details and to purchase tickets, click here.
Your proprietary formula is worth its weight in gold. It is prudent to protect this invaluable information and avoid disclosing specific details on a safety documentation.
In the U.S., it is not uncommon for suppliers to hide chemical information on the safety data sheet (SDS) for a hazardous product as “trade secret.” This is permitted without any registration or administrative fee required, as long the claim can be supported and given that it provides an advantage over competitors who do not know or do not use it. In contrast, it is challenging to obtain approval to withhold chemical information for a mixture in Europe. Under the European Union Classification, Labeling & Packaging (EU CLP) regulation, an approval to use an alternative chemical name can only be obtained for chemicals that do not have any community workplace exposure limits, and that are classified into specified, less severe, hazard categories.
Canada is a middle ground between the relaxed U.S. and the stricter EU confidentiality provisions. In Canada, a registration must be completed to withhold chemical details from the SDS. If you are thinking about hiding confidential chemical information on your Canadian Workplace Hazardous Materials Information System (WHMIS) SDS, you will want to continue reading!
HMIRA background
The Hazardous Materials Information Review Act (HMIRA) and Hazardous Materials Information Review Regulations (HMIRR) set out the requirements for suppliers that wish to claim an exemption from the obligation to disclose confidential business information (CBI) with respect to SDS and labeling requirements under the Hazardous Products Act (HPA) in Canada.
Amendments to HMIRA and HMIRR came into force in 2020 and, since then, Health Canada has been working to modernize the administration of the program to improve efficiencies. There is a new searchable webpage that consolidates claim information, such as exemption status and expiry date, in one location in a user-friendly format.
Health Canada has also updated the online application form to provide an easier, more streamlined claim application process. Once filled out, the application can be submitted, downloaded, and saved as an .hcxs file, which can be uploaded again at a future time if modifications are required.
To withhold the name of a hazardous chemical from the SDS, a generic chemical name (GCN) must be chosen to take its place. Selecting any generic replacement for the chemical name—such as “proprietary chemical 1”—is not allowed. The GCN should be less specific than the true chemical name but no more general than necessary to protect the CBI. It must not convey false or misleading information about the nature of the chemical. Health Canada released a helpful guidance document that explains strategies for developing a GCN along with some specific examples and commonly encountered errors.
New service standards
In the past, registration has been a slow process, sometimes taking Health Canada several years before a HMIRA claim is fully reviewed and accepted. This used to result in large backlogs of mixtures with claims in limbo waiting for approval. In 2023, Health Canada introduced a new multi-staged review process wherein claims are assessed separately from SDS and label compliance. This allows for a more streamlined process for claimants to have up-to-date information on their submissions in a more predictable and timely manner.
Under the new process, once all information needed to complete an evaluation is provided, the registry number (RN) and date of filing are issued together with a claim validity decision or consultation document at the time of registration. The RN must be displayed on the SDS of a hazardous mixture to import or sell the product in Canada without disclosing the CBI. This method results in faster and more predictable responses about the claim status and helps ensure that the three-year exemption period is followed more closely. For the issuance of an RN on up to 15 HMIRA exemption claims, Health Canada has now committed to a service delivery standard of just 10 business days from the date of the receipt of a complete application. The standard for 16–25 claims is 15 business days, and for 26 or more claims, the standard is 20 business days. Health Canada confirmed that it processed 100% of claims for exemption applications within the service standards for fiscal year 2022–2023. The new service standards officially took effect on April 1, 2024.
In our anecdotal experience at Nexreg, we have also found that the response from Health Canada for HMIRA claims has improved substantially. Recently, we have assisted clients with HMIRA submissions and received responses from Government of Canada agents in fewer than two business days.
The fees associated with submitting a HMIRA claim are adjusted on April 1 of each year. The cost is updated in the April Consumer Price Index for Canada, as published by Statistics Canada for the previous fiscal year. Fees can now be paid online via credit card.
2024–2025 work plan & multi-stakeholder workshop
In terms of the next steps for regulatory activities, Health Canada’s Workplace Hazardous Products Program (WHPP) will focus on the following priorities during the 2024–2025 fiscal year:
• Increasing transparency of inspection information
• Publication of additional hazardous substance assessments
• Implementation of the amended Hazardous Products Regulations (HPR)
• Ongoing international leadership
With these priorities in mind, Health Canada aims to strengthen compliance promotion and advance work on key policy files. Additionally, Health Canada is actively participating in United Nations Sub-Committee of Experts on the GHS (UNSCEGHS), and in the Canada–U.S. Regulatory Cooperation Council, to advance global health and safety and facilitate regulatory alignment throughout North America.
Initially planned for this Spring, the 2024 WHPP multi-stakeholder workshop has been rescheduled to Fall 2024. The multi-stakeholder workshop is an opportunity for interested parties to engage with those affected by WHMIS and provide regulators with valuable ideas and feedback. The Government of Canada would like to maximize the usefulness of the workshop by leveraging the availability of more substantive updates coming later this year. As we go to press, there had been no word yet on the update to the U.S. Hazard Communication Standard, which is anticipated to be released soon. The specific timing of the multi-stakeholder workshop has not yet been confirmed. Industry stakeholders and other interested groups are encouraged to lead discussion topics. The deadline to submit topic proposals is July 2, 2024.
Health Canada plans to continue to issue general program updates via the quarterly WHPP newsletter. If you have any questions about Canadian regulatory compliance or trade secret registrations, don’t hesitate to reach out to us at Nexreg Compliance. SPRAY
Over the last few years, the conversation around Perfluoroalkyl & Polyfluoroalkyl Substances (PFAS) has focused on the manufacturing process and intentionally added ingredients in a product. However, product packaging could also be a source of PFAS and must be reviewed.
Some products utilize fluorinated packaging to protect and maintain the contents throughout their lifespan. Manufacturers will use fluorinated packaging when the average plastic container is not sufficient to hold the product and other packaging materials are either not compatible or have drawbacks. Through various processes, fluorinated packaging undergoes treatment to form a barrier that ensures there isn’t an unintended reaction or permeation that could degrade the integrity of the packaging.
In 2020, the U.S. Environmental Protection Agency (EPA) learned of potential PFAS contamination in an insecticide. After studying the product, the EPA determined1 that the PFAS was likely formed during the fluorination process of high-density polyethylene (HDPE) containers by Inhance Technologies, which bled into the pesticide formulation.
Following this, the EPA contacted a variety of pesticide stakeholders that may have used fluorinated packaging. Under the Federal Insecticide, Fungicide & Rodenticide Act (FIFRA) Section 6(a)(2), companies are required to report certain information about their products, such as unreasonable adverse effects, including metabolites, degradates and impurities, including PFAS. The EPA studied the potential leaching of PFAS over time in various test solutions and found that even water-based products could leak certain PFAS into the formulation from the container.
Under the Toxic Substances Control Act (TSCA), the EPA also requires manufacturers to notify it at least 90 days before commencing the manufacture (including import) or processing of long-chain perfluoroalkyl carboxylate (LCPFAC) substances. Inhance Technologies, who had been producing fluorinated packaging for 40 years, did not view their process as new, even though the EPA was learning new information about its processes and what could happen to products in the marketplace.
This led the EPA to issue2,3 content orders on Dec. 1, 2023, to Inhance Technologies to stop producing certain PFAS incidentally and unintentionally by Feb. 28, 2024, under Section 5 of TSCA. The orders required Inhance to stop the manufacture, sale and distribution in commerce of any fluorinated packaging within the scope of the order, which would have profound impacts on industries that rely on fluorinated packaging. At the time of issuing the consent orders, the EPA could measure PFAS in plastic packaging down to 20 parts per trillion (ppt) (although, recently, the EPA published4 a newer methodology that can measure as low as 2ppt). Inhance petitioned a review by the 5th District Circuit Court of Appeals to stop the consent orders and quickly had its motion to stay granted while the Court considered the appeal.
Due to the significant impact these consent orders could have on Household & Commercial Products Association (HCPA) members that rely on fluorinated packaging for some of their products, HPCA joined and contributed to an amicus brief5 filed by the American Chemistry Council, CropLife America, Outdoor Power Equipment Institute and U.S. Chamber of Commerce in support of Inhance Technologies’ petition. The brief’s key arguments stated that the EPA’s orders are premised on EPA’s incorrect conclusion that Inhance engaged in a “significantly new use” of a substance and highlighted the scale of market disruptions. For example, any replacement packaging would need to undergo compatibility and stability testing along with market considerations.
On March 21, 2024, the 5th District Circuit Court determined6 that the EPA exceeded its authority. The Court’s opinion made it clear that the EPA cannot contort the plain language of TSCA’s Section 5 to deem a 40-year-old manufacturing process a “significant new use” that is subject to the accelerated regulatory process provided by that part of the statute.
This decision does not impede the EPA’s ability to regulate Inhance’s (or other companies’) fluorination processes. In fact, the EPA can utilize the authority7 under Section 6 of TSCA, which nongovernmental organizations (NGOs) have already petitioned8 the EPA to do, as well as other authorities, such as those under FIFRA.
It is critical that companies continue to evaluate their packaging, both to ensure stability throughout the life of the product and adjust to the ever-changing regulatory environment. While the Court’s decision provides companies more time to examine their fluorination processes, it is likely that activity in this space will continue.
For more information about the fluorination process or PFAS specifically, please contact me at ngeorges@thehcpa.org. SPRAY
1 link
2 link
3 link
4 link
5 link
6 link
7 Unlike Section 5 under TSCA, which requires a company to submit a significant new use notice at least 90 days before manufacturing or import, Section 6 gives EPA the authority to conduct risk evaluations of existing chemicals and their manufacture, processing, or distribution in commerce.
8 link
OTC Meeting
On April 22, the Ozone Transport Commission (OTC) held its Spring virtual meeting, during which it was mentioned that the Consumer Model Rules were edited. Changes included administrative and formatting updates, such as modified dates and rules. As well, it was reported that the Consumer Products Phase I, II, III and IV were reposted.
Next on the agenda is the Annual Public Meeting in Portland, ME, on June 13, 2024.
Oregon
Oregon is considering a Consumer Products volatile organic compound (VOC) regulation. Our first pre-meeting was in January. Oregon has informed Industry that it is moving forward with Consumer Products and Architectural Coating rulemakings. The State was planning a Rule Advisory Committee (RAC) meeting in mid- to late May.
It is likely that Oregon will put in the OTC Model Rule IV rule. There will be more to come on this issue.
CARB
The California Air Resources Board (CARB) Consumer Products survey is likely to to be further delayed. Industry has expected the survey’s release for more than seven months now; however, CARB staffing and other issues have delayed this release. It is doubtful that we will see the survey any time before July 2024 at the earliest.
Remember, this survey will be the beginning of CARB’s next rulemaking, which is expected to be presented to its executive board in 2027. CARB is targeting 20 tons of VOC emissions reductions per day or equivalent, which is two-and-a-half times the VOC emission reductions in the last rulemaking.
Other States
Clark County, NV, showed interest in developing a rulemaking on Consumer Products VOC regulations. To date, the County has not acted on this rulemaking but has moved ahead with other VOC regulations.
Similarly, New Jersey has stated that it plans to have a rulemaking on Consumer Products to update its OTC Model Rule II to OTC Model Rule IV. However, the Garden State has not yet released a timeline for this rulemaking. SPRAY
Hello, everyone. Which chemical most often contributes to or causes spray package material corrosion? Water! Water can be in a formula, either as an ingredient or as a contaminant. There are four reasons why I am so quick to implicate water as the most frequent contributor to or cause of spray package corrosion.
First: Water and metals are thermodynamically unstable when in contact with each other. The simple chemical equations for corrosion of the steel and aluminum used in spray packages by water are:
These two equations show that iron (steel) and aluminum corrosion by water is possible, but do not tell us the corrosion reaction rates of aluminum and iron with water. Corrosion rates are important because they are directly proportional to the spray package service lifetime. Thus, corrosion reaction rates should be measured.
Second: A variety of corrosive ions and molecules dissolve in water. Consequently, water is also a carrier that delivers corrosive ions and molecules to spray package metals and metal foils.
Third: Water easily diffuses through materials, such as polymer coatings and laminate polymer films. Water diffusion degrades and disables coatings and film barrier properties, causing them to lose the ability to protect the underlying metal from corrosion. Water diffusion through polymer coatings/films brings corrosive water, molecules and ions to the metal under the polymer coating/film.
Fourth: Metals and metal-polymer interfaces have a molecular cloud of negative electrons on the surface and at the interface, respectively. Thus, water molecules are drawn to uncoated metal surfaces, and through polymer coatings and films, to these negative clouds. Water molecules cause corrosion when they adsorb onto metals and subsequently remove electrons from the water atoms:
What about anhydrous formulas?
It is extremely difficult to keep anhydrous formulas from being contaminated by small amounts of water. Thus, anhydrous formulas are not immune to corrosion by water.
Water is corrosive as a liquid and a cluster of only 90 water molecules is needed to form liquid water that initiates corrosion (based on thermodynamic calculations). Of course, additional water is needed to sustain corrosion after it initiates. The amount of additional water needed depends on the treatment of the metal or metal-foil surface (such as uncoated or coated/type of coating/etc.) plus the chemical composition of the formula inside the spray package.
Consequently, corrosion testing is needed to determine if an anhydrous formula is corrosive and what is the safe concentration of contaminant water. Corrosion testing can be either an electrochemical corrosion test with the appropriate measurement parameters or a minimum one-year constant temperature storage-stability test.
Please note that raising the storage temperature does not accelerate corrosion of spray package materials, such as aluminum, steel, polymer coatings and films. In other words, raising storage temperature does not shorten the length of the test.
Controlling & preventing corrosion
Spray package corrosion by both formula water and contaminant water can be controlled or prevented. For anhydrous formulas, there often is a non-corrosive concentration range for contaminant water. In other words, corrosion of anhydrous formulas might be controlled or prevented by keeping the concentration of contaminant water inside the non-corrosive range.
Corrosion by formula water can often be prevented with corrosion inhibitors. Indeed, in my almost five decades of corrosion research, testing and consulting, I’ve not found a corrosive formula that could not be inhibited! In some instances, slowing down the corrosion is required; in other instances, corrosion prevention is needed.
A corrosion inhibitor is often only effective for a very specific environment or formula. There are literally thousands of chemicals that might inhibit corrosion, hence finding the most effective corrosion inhibitor often takes time.
Ironically, corrosion inhibitors can actually cause corrosion when their concentration is above or below the effective concentration range. Hence, the effective corrosion inhibitor concentration range should also be determined when developing an inhibitor for a corrosive formula.
Storage testing can be used to screen potential corrosion inhibitors; however, a storage test requires at least one year to complete. Electrochemical corrosion testing is more precise and the quickest way to screen a large number of potential corrosion inhibitors—assuming the appropriate measurement parameters and data analysis protocols are used.
Changing package materials also can, in some situations, control and prevent corrosion. However, the options for changing package materials are more limited than the options for corrosion inhibitors.
In summary, water contributes to, or causes, spray package corrosive because water is:
• Thermodynamically unstable when in contact with metals
• Electrochemically active and causes corrosion
• Moves (diffuses) easily in solutions towards metal surfaces
• Attracted to charged surfaces—indeed the electrical field on charged surfaces often pull water towards the surface, as well as through polymer coatings and polymer films
• A carrier of corrosive ions and molecules
• Degrades polymers so they are not barriers between a formula and the package metal under the polymer coatings and films
Anhydrous formulas are not immune to corrosion. However, in some instances, there is a non-corrosive concentration range for contaminant water.
Corrosion inhibitors are an effective way to control or prevent spray package corrosion by formula water and anhydrous formulas. However, finding an inhibitor that works for individual formula-package systems takes time and the effective concentration for the inhibitor must also be determined.
Corrosion testing is needed to determine:
• If corrosion will occur
• Where in the package corrosion will occur
• The spay package service life with a specific formula
• The non-corrosive concentration range for contaminant water—if one exists
• An effective corrosion inhibitor and its effective concentration range
Thanks for your interest and I’ll see you in July. Contact me at 608-831-2076; rustdr@pairodocspro.com or from our two websites: pairodocspro.com and aristartec.com. SPRAY
The New York Society of Cosmetic Chemists (NYSCC) 45th Annual Suppliers’ Day came to a successful conclusion on May 1 and 2 at the Jacob K. Javits Convention Center in New York City. Showcasing thousands of ingredients and raw materials on a sold-out exhibit floor that housed in excess 103,000 net square feet of exhibits while attracting 11,085 registrants representing 72 countries, Suppliers’ Day 2024 enjoyed nearly an 8% increase in overall attendance—more than 35% increase since its move to NYC in 2017.
“The beauty community truly showed up for Suppliers’ Day with our theme, ‘INSPIRE. INNOVATE. CELEBRATE,’ evident end-to-end at the Javits Center,” said Amber Evans, Chair of NYSCC.
“Every element of product development was on display and optimism and excitement for growth and innovation in all product categories was high.”
In addition to an exhibit floor that featured 567 exhibiting companies including 139 new exhibitors, Suppliers’ Day had unique in-classroom technical and marketing education programs that attracted 523 conference delegates, its largest audience to date. Popular programs included the Scientific Advisory Committee’s curated courses on hair, biotechnology and nutricosmetics; as well as sessions on opportunities and challenges in the cosmetic industry, Chinese innovations, mircobiome and fragrance. Essential Suppliers’ Day programming on World of Chemistry, Digital Age of Beauty and Discover Sustainability were also well received as well as the innovations from exhibitors and special sessions on current beauty innovations, Latina and California product development updates, sustainable developments in the cosmetic sector, influencer panel and more.
A special Keynote Presentation with L’Oreal’s Dr. Qian Zheng, Senior VP Head of Advanced Research North America & Global Regenerative Beauty Discovery Domain, in conversation with Kathryn Hopkins, Senior Beauty Editor of WWD, on L’Oreal’s Green Sciences Revolution took place on May 2.
The highest number of students also participated in the Future Chemists Workshop with more than 100 students, from 32 colleges and universities across the country, formulating an antioxidant primer. The NYSCC Mentorship Mixer and Career Development Program connected members with mentees looking to enhance their professional development and career in cosmetic chemistry.
New this year was the INSPIRATION ZONE where attendees were able to touch and feel the ingredients of tomorrow. These ingredients were selected by BEAUTYSTREAMS senior trend analysts and forecasters.
The NYSCC Awards Night event took place on May 1 at LAVAN Midtown and revealed the eight finalists of the CEW Beauty Award for Supplier’s Ingredients and Formulation: Bakuchiol Ester BCR by Bio Component Research; CycloRetin by Clariant; ETERWELL YOUTH by DSM Firmenich; Vecollage Fortify L by Evonik Corporation; Illuminyl 388 by Givaudan; Corneopeptyl by Lucas Meyer Cosmetics; EstoGel Green by Presperse Corporation; and SRHC Type XVII by Trautec. The winner will be announced at the CEW Beauty Awards Luncheon on November 21, 2024.
The INDIE 360 Pavilion was again a popular destination for attendees with 16 brands participating and featuring a Latina beauty capsule. Ziba Beauty, founded by Sumita Batra, was this year’s INDIE 360 People’s Choice Award, for its modern signature brow collection.
Four sci-comm influencers also walked the exhibit floor to select their top three ingredients worthy of the new Suppliers’ Day Ingredient Maverick Award. The influencer awards went to:
Erica Douglas
Solobia + Applechem, Ingredient: Serenibiome
Mibelle AG Biochemistry, Ingredient: RejuveNAD,
iOi OLEOCHEMICAL, Ingredient: DYNASAN CrystalCONTROL L
Ginger King
dsm-firmenich, Ingredient: ETERWELL YOUTH
Corum Inc., Ingredient: Epi-On
Provital LLC, Ingredient: SHILOXOME
Ramon Pagan
Rahn USA Corp, Ingredient: ILLUMISCIN-GLOW
P2 Science, Ingredient: Citripol F
Arcaea, Ingredient:ScentARC Prebiotic
Jane Tsui
Barnet Products, Ingredient: IntenCfy
Disruptive Materials USA Inc., Ingredient: UPSALITE
Grant Industries, Ingredient: Granactive Retinoid Pro+
Plans are underway for the 2025 NYSCC Suppliers’ Day taking place June 3-4, 2025, again at the Javits Center, with 87% of the exhibitor floor already resigned. The event will be moving to the expansive third level of the convention center and will include new activations and strengthened industry partnerships to create the best global ingredients event for the industry.
For more information about NYSCC visit www.nyscc.org. For 2025 Suppliers’ Day exhibitor and sponsorship information email: suppliersday@nyscc.org.
