flammable aerosol testing for hcs 2012 (ghs)

dell tech laboratories ltd. 1

FLAMMABLE AEROSOL TESTING FOR HCS 2012 (GHS)

JOE MCCARTHY, LAB SERVICES MANAGER/REGULATORY AFFAIRS SPECIALIST


1. THEN vs. NOW - And why a product that was not flammable THEN

may very well be flammable NOW.

2. Performing the tests- Catching Fire, what is sustained combustion?

3. Safety considerations - Fire is not the only way to get burned.


HCS 1994 (THEN) vs. HCS 2012 (NOW)HCS 1994 (THEN)

means an aerosol that, when tested by the method described in 16 CFR 1500.45, yields a flame projection exceeding 18 inches at full valve opening, or a flashback (a flame extending back to the valve) at any degree of valve opening;

HCS 2012 (NOW)

Category 1

Contains ≥ 85% flammable components and the chemical heat of combustion is ≥ 30 kJ/g; or

a) For spray aerosols, in the ignition distance test, ignition occurs at a distance ≥ 75 cm (29.5 in),

or

b) For foam aerosols, in the aerosol foam flammability test

(i) the flame height is ≥ 20 cm (7.87 in) and the flame duration ≥ 2 s; or

(ii) the flame height is ≥ 4 cm (1.57 in) and the flame duration ≥ 7 s

Category 2

Contains > 1% flammable components, or the heat of combustion is ≥ 20 kJ/g; and

a) For spray aerosols, in the ignition distance test, ignition occurs at a distance ≤ 15 cm (5.9 in), orin the enclosed space ignition test, the (i) time equivalent is ≤ 300 s/m3; or (ii) Deflagration density is ≤ 300 g/m3

b) For foam aerosols, in the aerosol foam flammability test, the flame height is ≥ 4 cm and the flame duration is ≥ 2 s and it does not meet the criteria for Category 1


1. Can be tested using ASTM D240-02, ISO 13943, NFPA 30B

2. Calculated as a weighted sum of the individual components. n

ΔHc (product) = ∑ [wi% × ΔHc(i)] i

Literature data available from: NFPA 30B, NIST, CRC, Perry’s Chemical Engineers Handbook, etc.

Heat of Combustion (ΔHc)


THEN

1500.45 Method for determining extremely flammable and flammable contents of self-pressurized containers.(a) Equipment required. The test equipment consists of a base 8 inches wide, 2 feet long, marked in 6-

inch intervals. A rule 2 feet long and marked in inches is supported horizontally on the side of the base and about 6 inches above it. A paraffin candle 1 inch or more in diameter, and of such height that the top third of the flame is at the height of the horizontal rule, is placed at the zero point in the base.

(b) Procedure. The test is conducted in a draft-free area that can be ventilated and cleared after each test. Place the self-pressurized container at a distance of 6 inches from the flame source. Spray for periods of 15 seconds to 20 seconds (one observer noting the extension of the flame and the other operating the container) through the top third of the flame and at a right angle to the flame. The height of the flame should be approximately 2 inches. Take three readings for each test, and average. As a precaution do not spray large quantities in a small, confined space. Free space of previously discharged material

Flame Projection/Flashback (THEN) vs. Ignition Distance Test (NOW)

NOW


16CFR1500.45 (THEN) vs. Ignition Distance Test (NOW)

THEN

Fixed Ignition point (6”), Is the flame projection > 18”? Is there a flashback?

NOW

Increasing ignition point in 15 cm (6”) intervals. Is there sustained combustion?



THEN

1 inch candle, flame height 2”

1400°C (2550°F)

NOW

Gas burner w/ blue non-luminous flame 4-5 cm (1-

1.5”) height

Methane – 1917°C (3484°F)Propane – 1972°C (3583°F)Butane – 1967°C (3573°F)


Same Product: Candle vs. Gas Flame

Click on image to play



Discharge Time Orientation Fill # Tests

THEN

NOW


Same product: No Shaking vs. Shaking before use.




6” 12” 18” 24” 30” 36”

15cm 30cm 45cm 60cm 75 cm 90cm

Flammable

Flammable

Category 2Category 1Do ESIT

THEN

NOW


Enclosed Space Ignition Test (ESIT)


Enclosed Space Ignition Test

2 calculations, only one needs to be met for inclusion in Category 2

Time equivalent (teq, in seconds) needed to achieve ignition

teq = 1000 x discharge time (s) . Actual volume of drum (dm3)

Confirm the volume of your drum!

Deflagration density (Ddef, in g/m3) needed to achieve

Ddef = 1000 x Amount of product dispensed (g) Actual volume of drum (dm3)


Foam Flammability Test

“foam aerosol” means the content that is dispensed from an aerosol dispenser having a spray distance of less than 15 cm and that is in the form of a foam, mousse, gel or paste.

“spray aerosol” means the content that is dispensed from an aerosol dispenser and that is not a foam aerosol.

Foam Aerosols

Not Foam Aerosols



≥ 20 cm & ≥ 2 s ≥ 4 cm & ≥ 7 s ≥ 4 cm & ≥ 2 s

00:00:02 00:00:07 00:00:02

Category 1 Category 2


Foam Flammability Test – How to measureAlign ruler with base of watch glass Rim of the watch glass should line up at 20 mm

~ 5 g of product no more than 25 mm (~1”) high


Foam Flammability Test – How to Measure

31.6.3.2(h)(i) “The maximum height of the flame in cm above the base of the watchglass”31.6.4.1(b) “Maximum flame height in cm”


Measure from base of the watchglass, not top of the foam



30s

1 min

2 min

4 min


The aerosol is sprayed in the direction of an ignition source at intervals of 15 cm to observe if ignition and sustained combustion of the spray takes place. Ignition and sustained combustion is defined as when a stable flame is maintained for at least 5 s.

Ignition Distance Test – Sustained Combustion

Lubricant / Water Dispersant



Lubricant / Water Dispersant with extension tube




Solvent Degreaser


Roller Chain Lubricant





Air Freshener



Electronics Duster



31.5.1.1 “If an observable ignition occurs, the elapsed time & amount discharged is noted”




Glass Cleaner



Foaming Hard Surface Cleaner



Substance TWA STEL IDLH Odour detection threshold Odour description Sources

Phosgene(Carbonyl Chloride)

(COCl2, 75-44-5)0.1 0.5 2 0.4 Fresh cut grass, hay,

cornCombustion/pyrolysis Perchloroethylene,

chlorinated solvents

Hydrogen Fluoride(HF, 7664-39-3) 0.5 2 30 0.04 Sharp, pungent,

irritatingCombustion/pyrolysis Fluorinated

compounds

Carbonyl Fluoride(COF2, 353-50-4) 2 5 ? ? Sharp, pungent,

irritatingCombustion/pyrolysis Fluorinated

compounds

Chlorine(Cl2, 7782-50-5) 0.5 1 10 0.5 Chlorine bleach Combustion/pyrolysis Perchloroethylene,


Hydrogen Chloride(HCl, 7647-01-0) 5 2 50 0.7 Sharp pungent Combustion/pyrolysis Perchloroethylene,


Hydrogen Cyanide(HCN, 74-90-8) 5 4.7 50 5 Almond Combustion of polyurethanes

Perchloroethylene(C2Cl4, 127-18-4) 25 100 1500 50 Sweet like chloroform Used in brake cleaners

TWA “TWA” or “time-weighted average limit” is the time-weighted average airborne concentration to which a worker may be exposed in a work day or work week.

STEL STEL = “Short-term exposure limit” means the maximum airborne concentration to which a worker may be exposed in any 15-minute period.

IDLH Immediately Dangerous to Life or Health

EXPOSURE LIMITS OF SELECTED TOXIC GASES


Questions/Comments?

Joe McCarthyLab Services Manager/Regulatory Affairs Specialist

[email protected]

Product Safety - Regulatory Affairs – Lab Services

www.delltech.com

mailto:[email protected]

http://www.delltech.com/

flammable aerosol testing for hcs 2012 (ghs)

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