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User Guide to Thresholds and Classification - Environmental ...

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43<strong>User</strong> <strong>Guide</strong> for <strong>Thresholds</strong> <strong>and</strong> <strong>Classification</strong>sRegulations 2001 <strong>to</strong> avoid any overlap with the Gas Act controls. This follows the previous practice asdefined in the Dangerous Goods (Class 2 – Gases) Regulations 1980, which stated in regulation 4:Nothing in these regulations shall apply <strong>to</strong>—(a) coal gas or natural gas except when packed, s<strong>to</strong>red, conveyed or h<strong>and</strong>led in cylinders ortransportable tanks.4.2. Flammable aerosols – subclass 2.1.24.2.1. Threshold criteria for flammable aerosolsAn aerosol is a flammable aerosol if it is a pressurised mixture containing a gas, compressed, liquefied, ordissolved under pressure, with or without a liquid, paste, or powder; comprising at least 45% by mass offlammable ingredients. The substance also must be packed under pressure in a way that is designed <strong>to</strong> bereleased as solid or liquid particles in suspension in a gas; or as a foam, paste, or powder; or in a liquidstate; or in a gaseous state.In this context, ‗flammable ingredient‘ means any substance that meets the threshold for a ‗flammable gas‘, a‗flammable liquid‘, a ‗flammable solid‘, or any combination of these.4.2.2. <strong>Classification</strong> of flammable aerosolsThe one classification category for flammable aerosols (2.1.2A) has the same threshold criteria as above.4.2.3. DiscussionThe UN Model Regulations definition of ‗aerosols‘ (chapter 3.3: notes 63 <strong>and</strong> 190) combines a description ofthe substance <strong>and</strong> a description of the package, as follows.A flammable aerosol is a substance that includes more than 45% by mass or more than 250 g of flammablecomponents, which are defined as ‗gases that are flammable in air at normal pressure, or are substances orpreparations that are in liquid form that have a flashpoint ≤ 100°C‘ (note 63).Aerosols, meaning the aerosol dispensers, are any non-refillable receptacles made of metal, glass, or plasticthat contain a gas compressed, liquefied, or dissolved under pressure, with or without a liquid, paste, orpowder, <strong>and</strong> fitted with a release device allowing the contents <strong>to</strong> be ejected as solid or liquid particles insuspension in a gas, as a foam, paste, or powder, in a liquid state, or in a gaseous state (note 190).Aerosols are classified under the UN Model Regulations as division 2.1 when the criteria of note 63 are met.The definitions of aerosol in European Commission Directive 75/324/EEC (EC, 1975) <strong>and</strong> the InternationalCivil Aviation Organization‘s Technical Instructions for Safe Transport of Dangerous Goods by Air (ICAO,2006) are virtually identical <strong>to</strong> the definition in the UN Model Regulations. The EC directive sets a maximumcapacity of metal aerosol dispensers of 1,000 ml. A recent amendment <strong>to</strong> the directive requires all aerosolswith any flammable contents <strong>to</strong> be considered flammable unless tests indicate that they are not.January 2012 EPA0109

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