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August 2014 19 under certain relaxed requirements. However, in order to demonstrate the level of safety, the industry must be able to demonstrate an equivalency of safety. This can be accomplished through testing, and by providing statistical evidence that shows the number of incidents and accidents is extremely low when considering the number of shipments made. Therefore, one of the major tasks of the AWG would be to collect this data. It was suggested that a survey be drafted and distributed to the industry as a whole, whereby the AWG could collect useful data, such as number of cans shipped, number of shipments made, and by certain modes of transport, as well as accident data, such as the number of transportation-related incidents and the circumstances surrounding each accident. It was also suggested that a public forum be created whereby scientific data could be shared. It was agreed that the AWG should work with its European and Asian counterparts to collect similar data for those regions. Armed with volumes of useful data, the AWG will draft a Petition for Rulemaking to the DOT’s Pipeline & Hazardous Materials Safety Administration (PHMSA) that urges the DOT to adopt the international definition of aerosols, or at least provide for fewer restrictions on certain types and sizes of aerosols if the measure is not adopted as written. Alternative Testing Requirements Another key objective of the AWG would be to petition PHMSA to adopt alternatives to the water bath testing required by 49 CFR. Although this would not have a significant impact on U.S. manufacturers and fillers (who already have the apparatus), it would have significant benefits for those companies that were upgrading their facilities or looking at increasing production or reducing their environmental or safety exposures. There are many widely recognized, safe alternatives to water bath testing currently used throughout Europe that would significantly boost U.S. production if employed in the U.S. Available literature on this equipment suggests that they are much more accurate in detecting releases, whereas water bath testing relies heavily upon the visual acuity and attention of the operator. The AWG agreed to investigate available alternatives and to reach out to its European and Asian counterparts to obtain copies of the standards required by the competent authorities in those regions. It was further agreed that the AWG could draft responsible legislation that takes into account the risks and safety assessments of using such equipment and build into the code a methodology whereby additional destructive and non-destructive testing methods could be employed. Again, it would be necessary to gather as much scientific and empirical evidence as necessary to demonstrate that alternative methods are as safe and effective as traditional ones, or even more so. This data would be gathered by interviewing our European and Asian counterparts who use these methods heavily. GHS Product Label Templates Perhaps the most beneficial objective of the AWG is the development of a series of templates for aerosol product labels that can be downloaded for use by aerosol manufacturers, distributors and fillers. It is envisioned that the templates will include downloadable files in various formats and in various multiple languages that contain and outline the minimum regulatory requirements for Signal Words, Pictograms, Hazard and Precautionary Statements as well as other regulatory requirements such as the EU Chemical Labeling & Packaging (CLP), Consumer Product Safety Commission (CPSC), Health Canada Workplace Hazardous Materials Identification System (WHMIS) and Canada’s Consumer Chemical and Container Regulations (CCCR 2001), among others. Templates would be available in a variety of useful formats such as Word (.doc), Adobe Acrobat (.pdf), Adobe Illustrator (.ai), Adobe Photoshop (.psd), Visio (.vsd) and other formats. Links would also be provided to high resolution GHS, WHMIS, CCCR and CLP pictograms, warning signs and other industry-related or recognized logos, such as the “OK to Spray” logo, Restriction on Hazardous Substances (ROHS), Humane Cosmetics & Household Products Standards (cruelty-free leaping bunny), Steel Recycling Institute recycling logo and others. It is also envisioned that the templates would be set up by common can sizes (e.g., 112 x 312, 211 x 604, etc.) and include scaled drawings that conform to the minimum font sizes (dimensions and points), and properly sized pictograms, which are based on the primary labels’ surface area. Additionally, links to scaled drawings of the transportation cartons and other useful resources would be provided. It is envisioned that users would download an editable file that can be used to draft properly prepared, compliant product labels. The group plans to work with its European, Canadian and Asian counterparts to develop templates that are also compliant with other international standards as well, such as the European Cosmetics & Chemical Labeling and Packaging Directives. The Aerosol Working Group will be meeting monthly. Anyone interested in participating in the AWG should contact either Mary Metzner, National Aerosol Association at (714) 525-1518 or naa@nationalaerosol.com; or the author, Steve Hunt, Aerosol Working Group Chairman at (310) 370-3600 or steve@shipmate.com. Spray


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