COMMITTEE OF EXPERTS ON THE TRANSPORT OF
DANGEROUS GOODS AND ON THE GLOBALLY
HARMONIZED SYSTEM OF CLASSIFICATION
AND LABELLING OF CHEMICALS
Sub-Committee of Experts on the Globally Harmonized
System of Classification and Labelling of Chemicals
Geneva, 9 – 11 December 2009
Item 3 of the provisional agenda
HAZARD COMMUNICATION ISSUES
Hazard communication for supply and use of aerosols
Transmitted by the experts from United Kingdom and FEA
1. At the last session of the Sub-Committee, United Kingdom submitted an informal document UN/SCEGHS/17/INF.4 (also submitted to the SCETDG as UN/SCETDG/35/INF.11) proposing that aerosols should not fall within the scope of Chapter 2.5 of the GHS, Gases Under Pressure.
2. The Sub-Committee of Experts on the Transport of Dangerous Goods was of the view that aerosols should not fall within the scope of chapter 2.5 of the GHS (gases under pressure), although the proposal was not agreed by the UNSCEGHS. However most experts did agree that the pictogram for gases under pressure should not be required for aerosols falling within the scope of the definition of gases under pressure, and that further work on the development and harmonization of hazard and precautionary statements applicable to these aerosols was needed. Some experts proposed that the precautionary phrases which are currently being used by different regulatory regimes all over the world be also taken into account. 3. Germany, United Kingdom and EIGA have jointly submitted the working document ST/SG/AC.10/C.4/2009/9 ‗Pictogram for gases under pressure‘ and propose to remove the
pictogram "gas cylinder" for the purposes of supply and use from the GHS.
4. The category ‗Flammable Aerosols‘ was agreed in December 2002 and added to the
fourth edition of the Manual of Tests and Criteria and into Chapter 2.3 of the ‗Purple Book‘ in 2003. That work included consideration of ‗non flammable‘ aerosols which are not required to
be classified. The subcommittee now, however, is returning to the subject in the context of another ‗new‘ GHS category, ‗gases under pressure‘ which was discussed and developed in parallel with the work on aerosols. As a result the experts from UK and FEA believe there remains a lack of clarity in proposed labelling requirements for non-flammable and flammable aerosols.
5. The experts from United Kingdom and FEA suggest that the discussion should centre on the following points:
- The agreed labelling provisions for flammable aerosols already include phrases
which are specific to all aerosols (not only to flammable ones). For consistency,
the phrases could be applied to all aerosols. If the Sub-Committee considers that
those phrases need adaptation, consistency must be maintained for flammable
- To ensure that statutory warnings remain easy to read, understand and apply, all
labelling requirements related to aerosols (flammable and non-flammable aerosols)
should be kept together in Chapter 2.3 (flammable aerosols). Aerosols would then
be exempted from the scope of Chapter 2.5 (gases under pressure).
- The agreed labelling provisions for flammable aerosols in Chapter 2.3 (flammable
aerosols) have proven to be effective within Europe for more than a decade
(corresponding to around 70 billion units). There is no justification or need for
additional labelling requirements on flammable aerosols.
- For non-flammable aerosols sets of warning phrases have been in place
worldwide e.g. in Europe for 35 years. There is no indication that any additional
consumer information is necessary for non-flammable aerosols.
6. The warnings in use in Europe are similar to those used elsewhere around the world. These include warnings which apply to all aerosols, flammable or not. Please find below some findings on different regulatory regimes all over the world for non-flammable aerosol consumer products. The labelling provisions related to flammability are generally simply added onto these standard warnings. Please note that several countries have not yet implemented the GHS (i.e. the UN classification scheme for flammable aerosols) in their national consumer products legislation.
1Total Aerosol Country Statements GHS Scope / remarks Source Production equivalence 2007 (in units) Argentina Do not expose to temperature exceeding P412 ‗Class D‘ aerosols (no flame). Standard IRAM 3793 736 millions
Do not burn. Do not pierce.
Prohibited to refill.
Australia PRESSURISED DISPENSER. DO NOT P251 All aerosol dispensers. Australian 235 millions
PIERCE OR BURN, EVEN AFTER USE. P410 + P412 Similar or equivalent words may Dangerous Goods thPROTECT FROM SUNLIGHT AND DO be used to stress the hazard of the Code (7 ed).
NOT EXPOSE TO TEMPERATURES product. Australian Standard
EXCEEDING 50?C. AS2278.1-2008 Canada (1) Consumer ‗pressurised containers‘ Consumer Chemicals 190 millions
(aerosols), except cosmetics and and Containers
disinfectants. Regulations, 2001. Products which have a flame CAUTION Warning projection of less than 15 cm. CONTENTS UNDER PRESSURE. H280
Container may explode if heated. P411
Do not puncture. Do not burn. Store away
1 Statements in bold italic have no GHS equivalence.
UN/SCEGHS/18/INF.16 1Total Aerosol Country Statements GHS Scope / remarks Source page 4 Production equivalence 2007 (in units)
Canada (2) Cosmetics and disinfectants in Cosmetic
‗pressurised containers‘. Regulations, 2009
Products with a flame projection of less than 15cm. CAUTION Warning
CONTAINER MAY EXPLODE IF H280
Contents under pressure. Do not place in hot
water or near radiators, stoves or other
sources of heat. Do not puncture or incinerate container or store at temperatures over 50?C.
China Classification criteria for GB20758-2006 1031 millions
flammable aerosols are fully in ―Safety rules for
line with the GHS. classification ,
Non-flammable aerosols are then precautionary
‗not classified‘. labelling and
Flammable and non-flammable precautionary
aerosols do not additionally statements of
belong to the physical hazard chemicals –
category ‗gases under pressure‘. flammable aerosols
EU-27 Pressurized container: protect from sunlight P410 + P412 All aerosol dispensers. Aerosol Dispensers 5414 millions and do not expose to temperatures exceeding P251 Last phrase to use only for non-Directive 50?C. flammable aerosols containing 75/324/EEC Do not pierce or burn, even after use. flammable components.
X% by mass of the contents are flammable.
1Total Aerosol Country Statements GHS Scope / remarks Source Production equivalence 2007 (in units)
Japan (1) P410 + P412 Non-flammable aerosols using High Pressure Gas 565 millions Attention to High Temperature.
P251 (part.) non-flammable liquefied gas Regulation
propellant HFC-134a. Comply with following cautions since it is
dangerous due to high pressurised gas:
Do not expose to the place like direct sun shine comes, close to fire, where the
temperature goes up to 40?C over, since it may be exploded if heated.
Do not put into fire.
Do not throw away before use up.
High pressured gas: HFC 134a.
Japan (2) P251 (part.) Non-flammable aerosols using Voluntary industry Attention to High Temperature.
P412 non-flammable compressed gas practice (AIAJ)
propellant CO, N. Comply with following cautions due to 22
Do not expose to temperature exceeding
Do not put into fire.
Do not throw away before use up.
New Keep in cool place away from heat. P235 Equivalent approved wording may Dangerous Goods < 50 millions
Zealand Do not puncture can or throw in fire even P251 be used. Labelling when empty. P412. Regulations 1978.
Hazardous A warning that the contents are under Substances pressure; and a warning not to expose the (Compressed Gases) UN/SCEGHS/18/INF.16 aerosol dispenser to heat and not to pierce or Regulations 2004.
page 5 burn it, even after use.
UN/SCEGHS/18/INF.16 1Total Aerosol Country Statements GHS Scope / remarks Source page 6 Production equivalence 2007 (in units)
South Pressurized container- (protect from sunlight P410 + P412 Non-flammable aerosols. Industry guidance: 216 millions
Africa and) do not expose to temperatures exceeding P251 AMA Code of 50?C. P102 Practice. AMA Do not pierce (puncture) or burn (incinerate), P211 labelling guidelines even when empty. P210 SANS 10265 Keep out of reach of children (even when P271
Do not spray near naked flame (or
Keep away from source of ignition - no
smoking. Use in a well-ventilated
Use only as directed.
USA WARNING--CONTENTS UNDER Warning Phrases to use when the only CFR Title 16—3655 millions PRESSURE H280 (part.) hazard associated with a self-Commercial Do not puncture or incinerate container. P251 (part.) pressurized container is that the Practices, Chapter Do not expose to heat or store at P412 contents are under pressure II--Consumer temperatures above 120 [deg]F. P102 (consumer uses). Product Safety Keep out of the reach of children. The word ―CAUTION‖ may be Commission, Part
substituted for the word 1500 Hazardous
―WARNING‖. substances and
7. Based on the above elements, the experts from UK and FEA suggest the following
consistent labelling provisions for both flammable and non-flammable aerosols:
Label elements for aerosols
(i.e. for extremely flammable, flammable and non-flammable aerosols)
new ‗Category 3‘ non-CLASSIFICATION Category 1 Category 2 flammable aerosols GHS Pictograms --
Signal word Danger Warning --
Extremely flammable Flammable aerosol
aerosol (H222) (H223) HXXX Pressurized Hazard statement container (new hazard HXXX Pressurized HXXX Pressurized
statement) container (new hazard container (new hazard
‗Keep away from ‗Keep away from
heat/sparks/open heat/sparks/open ‗Keep away from flames/hot surfaces. No flames/hot surfaces. No heat/sparks/open smoking‘ (P210) smoking‘ (P210) flames/hot surfaces. No ‗Do not spray on an ‗Do not spray on an smoking‘ (P210) Precautionary Statement open flame or other open flame or other Prevention ‗Pressurized container: ignition source.‘ (P211) ignition source.‘ (P211) Do not pierce or burn, ‗Pressurized container: ‗Pressurized container: even after use.‘ (revised Do not pierce or burn, Do not pierce or burn, P251) even after use.‘ (revised even after use.‘ (revised
Precautionary Statement Response
‗Protect from sunlight.
Do not expose to ‗Protect from sunlight. ‗Protect from sunlight. temperatures exceeding Do not expose to Do not expose to 50?C/122?F‘ (P410 + Precautionary Statement temperatures exceeding temperatures exceeding P412) Storage 50?C/122?F‘ (P410 + 50?C/122?F‘ (P410 + X% by mass of the P412) P412) contents are 2flammable. (new Pxxx) Precautionary Statement Disposal
2 Only when the aerosol contains flammable components.
8. Aerosols for the general public will additionally be labelled with P102 ‗Keep out of
reach of children‘.
9. This would be in line with the intention of the various legislations around the world which clearly have a similar purpose.
10. If agreed by the Sub-Committee, the experts UK and FEA will be pleased to convert this informal proposal into a working document including all necessary editorial changes for approval at the next Sub-Committee session.