July 2012

GHS finally arrives in the U.S: Part 2

The new Hazcom 2012 rule brings significant changes to the classification, labeling and Safety Data Sheets (SDSs) for aerosol products. The criteria for whether or not an aerosol product is considered flammable has changed dramatically. The following are the new classification criteria under Hazcom 2012 for compressed gases and flammable aerosols and the implications they will have on your product label. Note that these label changes only apply to industrial/institutional labels. There have been no changes to the existing U.S. Consumer Product Safety Commission (CPSC) regulations.

Products with compressed gases will require the gas cylinder pictogram with a border printed in red and the signal word “WARNING.” Compressed gases (which under pressure is entirely gaseous at -50ºC/-58ºF, including all gases with a critical temperature of less than -50ºC/-58ºF), liquefied gases (which under pressure is partially liquid at temperatures above -50ºC/-58ºF) and dissolved gases (which when under pressure is dissolved in a liquid phase solvent) require the signal word of “WARNING,” the hazard statement of “Contains gas under pressure; may explode if heated” and the storage
statement “Protect from sunlight. Store in a well-ventilated place.”

Refrigerated liquefied gases (which are made partially liquid due to their low temperature) also require the gas cylinder pictogram with the signal word “WARNING,” but have different associated statements. They require the prevention statement “Wear cold insulating gloves/face shield/eye protection,” the response statements “Thaw frosted parts with lukewarm water. Do not rub affected area” and “Get immediate medical advice/attention” as well as the storage statement “Store in a well ventilated place.”

There are two categories of Flammable Aerosol: Category 1 (Extremely Flammable) and Category 2 (Flammable). The only difference for labeling purposes is that Category 1
requires the signal word “DANGER” and the hazard statement “Extremely flammable aerosol” while Category 2 requires the weaker “WARNING” and the hazard statement
“Flammable Aerosol.” Note that only one signal word is required per label; a product with a signal word of “WARNING” (because it is a Gas Under Pressure) and a signal word of “DANGER” (because it is a Category 1 Flammable Aerosol) would use the more stringent “DANGER” signal word.

For both categories of Flammable Aerosols, there are three required prevention statements: “Keep away from heat/sparks/open flames/hot surfaces—No smoking,”
“Do not spray on an open flame or other ignition source” and “Pressurized container: Do not pierce or burn, even after use,” as well as the storage statement “Protect from sunlight. Do not expose to temperatures exceeding 50°C/122°F.” The flame pictogram with the red border needs to appear on the label as well for both categories (with the border printed in red).

There are three possible criteria for a Category 1 Flammable Aerosol (Extremely Flammable) classification; falling into any of these three triggers a Category 1 classification.
The first is that product contains ≥85% flammable components and the chemical heat of combustion is ≥30 kJ/g. The second is a spray aerosol where ignition occurs at a distance ≥75 cm (29.5 inches). The final is a foam aerosol where the flame height is ≥20 cm (7.87
inches) and the flame duration ≥2 seconds or the flame height is ≥4 cm (1.57 inches) and the flame duration ≥7 seconds.

For a Category 2 Flammable Aerosol (Flammable), there are two possible criteria—one for spray aerosols and one for foam aerosols. Both of the criteria require that the product have > 1% flammable components, or the heat of combustion is ≥20 kJ/g. For spray aerosols, the additional requirements are that the ignition occurs at a distance ≥15 cm (5.9 inches) or in the enclosed ignition the time equivalent is less than 300 s/m3 or the deflgration
density is less than 300 g/m3. For foam aerosols that do not meet the criteria for Category 1, the flame height is ≥4 cm (1.57 inches) and the flame duration ≥2 seconds.

While the new labeling requirements for gases under pressure are relatively straight-forward, we expect many companies to be surprised by the flammability criteria,
particularly the 15 cm/6 inch ignition distance rule for spray aerosols. Part 1 appeared in the June 2012 issue of ST&M.