Steven Charles Hunt President, ShipMate, Inc. from here to there: topics in transportation New Aerosols GHS Working Group Established he deadline for marking and labeling of chemical products to conform to the U.S. Occupational Safety & Health Administration’s (OSHA) Globally Harmonized System for Classification & Labeling of Chemicals (GHS) Hazard Communication Standard (HazCom 2012) is rapidly approaching. Unfortunately, there are many companies that have yet to take these changes into consideration. Perhaps they are hoping for an extension or waiting for others to pave the way so they can benefit from their experience. Maybe they think these new requirements do not apply to them because they primarily manufacture consumer products. Although the reasons why there is such a significant delay are not readily apparent, what is abundantly clear is that there seems to be a lack of direction and understanding of how the GHS will affect these companies and what information is actually required on product labels and safety data sheets for products distributed outside of the U.S.—in Europe, Asia and Canada in particular. Additionally, many companies still do not recognize the differences between the requirements of the U.S., Canada and Europe. To assist the industry, I made an offer to the National Aerosol Association (NAA) to chair an Aerosol Working Group (AWG) that will focus, initially, on three key objectives: 1. A harmonized definition of “aerosols” and “aerosol products” 2. A blanket authorization to permit alternatives to the water bath test 3. Developing useful templates for aerosol product labels that take into account the various regulatory requirements and those of Europe, Asia and Canada, in particular. The proposal was accepted and adopted by the NAA Board of Directors and the initial AWG meeting was held on May 23. 18 Spray August 2014 The objectives of the AWG were laid out and agreed upon and the benefits of this committee were discussed in detail. Ultimately, it was agreed that there is a lot of work to do on each of these objectives and that assistance from the aerosol industry as a whole, and not just the membership of NAA, would be needed. Harmonized Aerosols Definition Few people realize that there is a significant difference between the U.S. and other regulatory requirements with respect to aerosols. For example, the U.S. Dept. of Transportation (DOT) defines an aerosol as “…any non-refillable receptacle containing a gas compressed, liquefied or dissolved under pressure, the sole purpose of which is to expel a nonpoisonous (other than a Division 6.1 Packing Group III material) liquid, paste, or powder and fitted with a self-closing release device allowing the contents to be ejected by the gas.” The UN Model Regulations’ definition of aerosol or aerosol dispenser, however, means a “…non-refillable receptacle meeting the requirements of 6.2.4, made of metal, glass or plastics and containing a gas, compressed, liquefied or dissolved under pressure, with or without a liquid, paste or powder, and fitted with a release device allowing the contents to be ejected as solid or liquid particles in suspension in a gas, as a foam, paste or powder or in a liquid state or in a gaseous state.” This difference in definition allows certain compressed gases to be offered as limited quantities of aerosols when distributed outside of the U.S., but restricted as a fully regulated material and not entitled to any of the regulatory relief for limited quantities when in receptacles that exceed 4 fl oz (120mL). Examples of such products in this group include dusters and refrigerant replacements, some of which are non-flammable in nature. Although the DOT cited evidence of several incidents and accidents in their denial of a petition by another trade organization, there is plenty of empirical and scientific evidence to suggest that the transport of aerosols is quite safe, even when transported T
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