Are Aerosols Considered ‘Gases Under Pressure’?

Nexreg

10 years ago

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.

European Union:

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 4^th 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.

US regulations:

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:

C.2.1.2 If the skull and crossbones pictogram is included, the exclamation mark pictogram shall not appear where it is used for acute toxicity;

C.2.1.3 If the corrosive pictogram is included, the exclamation mark pictogram shall not appear where it is used for skin or eye irritation

C.2.1.4 If the health hazard pictogram is included for respiratory sensitization, the exclamation mark pictogram shall not appear where it is used for skin sensitization or for skin or eye irritation.

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 info@nexreg.com. We will be happy to give you guidance and supply you with a detailed answer.