by Eleanor Grimes, PhD
After extensive review this year, CARACAL (Competent Authorities for REACH and CLP) has recommended changes to the section of CLP regarding classification of aerosols (Annex I, 2.3), to clarify whether the propellant should or should not be considered when determining health and environmental hazard classifications.
This discussion was prompted due to ECHA’s FAQ response to the question: “When deciding on the classification of aerosol mixtures concerning health and environmental effects, does the propellant have to be excluded?”. The response to this FAQ concluded that the propellant should not be included as it produced a diluent effect which has prompted concerns around CMR effects. As a product classified as a CMR when in the liquid or solid form, could easily be reduced to non-hazardous in the aerosol form once the propellant has been taken into account.
The discussion around the classification of aerosols was split into two sections; the first covering classification using bridging principles, and the second covering all other methods of classification. The former section was addressed and implemented into the 12th ATP for CLP in September 2018, whilst the second section has been under several rounds of review.
Scenario 2 in particular focuses on the classification of aerosols based on the components within the mixture, and whilst initially discussed in 2018, this scenario has recently undergone further scrutiny in both the June/July and November CARACAL meetings during 2020. These recent meetings have identified three different cases where the impact of the propellant can have different effects.
Case A: The propellant or other gas is not released from the can upon spraying, and in this instance, the propellant should have no impact on the classification on the product. However, as the propellant remains in the aerosol container, in order to ensure adequate risk management measures at the waste stage, in particular in the case of recycling, the classification of the propellant should be reflected on the label of the aerosol container.
Cases B and C: Both the propellant, or other gas, and the product are released upon spraying. In this instance, whether the propellant should be included or not depends on whether or not they remain suitably mixed after spraying.
In the June/July CARACAL meeting, the determination of whether the propellant and product remain suitably mixed after spraying was recommended to be based on “the expected time of impact on the sprayed surface” but this was updated by the November meeting. In this recent addition, the definition is based by default on the vapour pressure of the propellant. If the vapour pressure of the propellant is ≥ 10 kPa at 20°C, then Case B stands, and it is assumed that the propellant will separate from the product and it should not be taken into account for classification of the mixture from which it is separated. However, if the propellant or other gas itself is classified as hazardous for health or the environment, then the classification of the propellant should also be reflected on the label of the aerosol.
If there is proof that even with a vapour pressure of ≥ 10 kPa at 20°C that separation is not taking place, or the vapour pressure of the propellant is < 10 kPa at 20°C then Case C takes over and the amount of propellant released is to be taken into account with the classification of the product.
At the moment these are still draft recommendations from CARACAL, but once an agreement has been released they will enter into EU law via an ATP to CLP.
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