a mixture shall be classified in the same hazard category as the tested, non-aerosolized form of the mixture, provided the added propellant does not affect the toxicity of the mixture when spraying. This refers to non-flammable aerosols. Therefore, non-flammable aerosols should be evaluated against the criteria and bridging principles for the hazard applicable to the liquid or solid concentrate, not the non-flammable propellant. 6. The final rule continues to further discuss aerosols being evaluated against the many different criteria, including potential for aspiration where the liquid concentrate can be pooled in the mouth (e.g., spray lubes). I will refer you to p. 17,817 of the final rule for example. This is further evidence of OSHA’s intent to evaluate the hazards of the concentrate. 7. Perhaps most convincing is the statement made by OSHA on page 17,818 which very clearly states that “Note: Aerosols should not be classified as flammable gases. See B.3.” How do you take this into consideration by classifying a flammable aerosol as a gas under pressure under Appendix B.5 (as many in industry or government often do) when OSHA very clearly states that you should follow Appendix B.3? 8. Additionally, OSHA states on the same page “Note 2: Flammable aerosols do not fall additionally within the scope of flammable gases, flammable liquids, or flammable solids.” Again, OSHA does not intend to require the pictograms for cylinders on flammable or non-flammable aerosols. 9. Per page 17,818, “Flammable aerosols shall be classified in one of the two categories for this class in accordance with Table B.3.1.” 10. Now, assuming that a product is classified as a “flammable aerosol,” the guidance in Appendix C, C.4.16 Flammable Aerosols (Classified in Accordance with Appendix B.3), shown on page 17,860 of the OSHA Final Rule, the pictogram would be the flame (GHS02), and NOT the cylinder (GHS04) and flame (GHS02). Hazard and Precautionary statements are also identified on that page. Additional Considerations 1. Consider also that GHS Revisions 5 and 6 are consistent with GHS Revision 3 with respect to flammable aerosols. A cylinder pictogram is not required for flammable aerosols. 2. GHS Revisions 5 and 6 have included provisions for non-flammable aerosols (Category 3) which do not require any pictograms for physical hazards. 3. The bridging principles discussed in the OSHA Final Rule and GHS Revisions 3, 5 and 6 are consistent with one another. Each refers to the evaluation of the liquid or solid concentrate in terms of their health hazards. Outer Packaging Marking & Labeling Although the OSHA Final Rule stated, in effect, that GHS pictograms and DOT hazard warning labels should not be on the package at the same time, OSHA later reversed itself in a written Letter of Interpretation, stating that it may be appropriate (and in some cases suggested) to apply both the GHS pictograms and DOT hazard warning labels on the transportation case (or outer packaging). For example, if I were to ship a fully regulated flammable liquid, I would apply the Class 3 flammable liquid label, 100 mm x 100 mm, placed on the package in a diamond (square on point) configuration. By applying the hazard warning labels, I need not apply the GHS pictogram, which has minimum dimensions of 10 mm x 10 mm on each side. However, what do you do in the case where you have a limited quantity and have applied the LTD QTY hollow diamond in lieu of the hazard warning label? For transportation purposes, this is fine, but what about storage and handling after transportation has been concluded? How would you effectively communicate the physical and health hazards associated with the product within the master carton? In these instances, it would be appropriate and, indeed, even recommended to apply the appropriate GHS pictogram, Signal Word and Hazard Statements on a different panel, away from the hazard warning label(s). Although it is recommended to size the pictogram as large as possible, I would exercise caution and advise against making the pictogram 100 mm x 100 mm so as not to be confused with the required hazard warning labels. Perhaps 25 mm x 25 mm or 50 mm x 50 mm would be appropriate and effective at communicating the risks. To conclude I trust that you will find this information is helpful and offers some guidance on the marking and labeling to satisfy the GHS and transportation labeling requirements for flammable and non-flammable aerosols. Perhaps some aerosol “fog” has been lifted? For additional information on product and transportation case marking and labeling, you may contact the U.S. Department of Transportation Pipeline & Hazardous Materials Administration (PHMSA) website at http://phmsa. dot.gov/hazmat, OSHA’s hazard Communication webpage at https://www.osha.gov/dsg/ hazcom/index.html, or call ShipMate, Inc. at (310) 370-3600. Spray 24 Spray February 2016 GHS Creates Aerosol “Fog”
Spray February 2016
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