By: Darren Dunn – Chemical Regulatory Consultant
The world of chemical regulation is full of many rules that differ from jurisdiction to jurisdiction, and in certain instances, a lack of guidance means regulations are left up to interpretation.
We recently had a client ask the Nexreg team if the ‘Compressed Gas’ pictogram:
was required to be placed on Aerosol products/SDSs because they noticed other companies were not including it. The answer to this question differs depending on which jurisdiction is being discussed.
EU regulations state: “If GHS02 (Flammable Pictogram)
or GHS06 (Toxic Pictogram) applies,
then GHS04 (Compressed Gas Pictogram) for gases under pressure not required.”
Also, under the new 4th ATP, the regulations state that Aerosols are not to be classified as Gases under Pressure. So, under EU GHS regulations, the ‘Compressed Gas’ pictogram is not required.
The OSHA-GHS regulations, in general, are not very detailed and are often left up to interpretation. With regards to aerosols, the only note to be found states:
“Flammable aerosols do not fall additionally within the scope of flammable gases, flammable liquids, or flammable solids.”
Following this, OSHA only has three rules where symbols can be removed. These include:
There is no rule about removing the gases under pressure pictogram. This means that under US regulations, Aerosols need to be classified as gases under pressure, and must include the Compressed Gas Pictogram.
To conclude, the Compressed Gas pictogram is NOT required to be placed on EU aerosols, but IS required on US aerosols.
If you have any questions, concerns, or need help interpreting any chemical regulations please feel free to ask the Nexreg team at firstname.lastname@example.org. We will be happy to give you guidance and supply you with a detailed answer.