As the provider of a hazardous product, the manufacturer/importer of aerosol products has a responsibility to provide understandable, adequate, instructions for the safe handling and use of their product.
This section deals with the specific measures which should be taken to ensure that the physical risks of the packaging format are minimised. These measures cover actions to be taken in the following areas:
- Product Development
- In Factory
- In Store/Warehouse
- In Transit
- In the Home
As a result of the Consumer Protection Act, Act No. 68 of 2008, a new and explicit obligation is placed on the person responsible for marketing the aerosol dispenser to analyse and identify the hazards which could arise from the use of the aerosol dispenser in order to ensure the safety of the consumer. This analysis must include the risks from inhalation of the spray under normal and reasonably foreseeable conditions of use. The marketer must then design, construct and test the product and, if applicable, draft special statements concerning its safe use if necessary.
It is important to note that it is the person responsible for marketing the aerosol dispenser, which may not be the filler, who bears the legal responsibility for ensuring that all the necessary testing has been carried out and product labelling is correct. In many cases it may be more convenient for a supplier to conduct the analysis, tests, and design any necessary special warning s on the marketer’s behalf, but this should be made explicit in any supply contract.
The primary hazards pertaining to aerosol filling are related to the flammability of gases and vapours and the pressure of some of these products, e.g. the propellant. The design of the production facility must provide for a sufficient level of safety even in the event of operating malfunctions or dangerous operating conditions.
This section deals with the requirements for the safe warehousing of aerosol products in order to prevent damage to aerosols which may result in the product being more dangerous in the hands of the consumer.
Aerosols must be separated from other products in compliance with the separation/segregation requirements of SANS 10263. Aerosols should ideally be packed in racks in the warehouse in order to avoid possible damage to the aerosol valve and the slow release of product and propellant from the aerosols. If racking is not available, the cases of aerosols shall not be stacked higher than the level recommended by the manufacturer/importer
Any aerosol product is pressurised and classed as a ‘Dangerous Good’ in terms of SANS 10228. The transport of dangerous goods in South Africa is subject to the Road Traffic Act, which regulates the transport of dangerous goods via SANS 10228 and SANS 10229-1 and 10229-2.
Aerosols can only be moved under carefully controlled and properly and fully documented conditions by a trained and licensed dangerous goods haulier. The Road Traffic Act Regulations require that all shipments of aerosols (dangerous goods) are accompanied by a Dangerous Goods Declaration, as defined in SANS 10231, issued by the consignor when it is moved between any premises.
Aerosols transported as ‘dangerous goods in limited quantities’ shall comply with the requirements of the appropriate section of the Code of Practice.
The Road Traffic Act Regulations require that a Dangerous Goods Declaration be completed and accompany all shipments of Dangerous Goods moved from any premises. It is now the responsibility of the consignor to compile three copies of the Note, one to be retained for records, one for the carrier and one for the consignee.
Information on how the aerosol product will be used in normal and reasonably foreseeable use is needed as part of any safety assessment. For example, how and where it will be used, how frequently, how long will it be sprayed and at what spray rate. Certain products present special risks by virtue of their formulations, e.g. oven cleaners and water-proofing sprays. For these Special Products awareness of labelling requirements is necessary.
The aerosol product shall be formulated and designed to reduce the potential for cold burns to the user during application. If, during use, liquid propellant is allowed to come into contact with the skin (or eyes) then a cold burn could occur. This is due to the rapid cooling as the liquefied propellant evaporates. This effect should be considered when choosing a propellant and hardware.
An assessment of safety under conditions of accidental misuse shall be made. An assessment of safety when products are accidentally sprayed into eyes by adults and/or children should also be carried out where relevant. Misuse, resulting in liquid propellant coming in contact with the skin (or eyes), could cause a cold burn to occur. For aerosol oven cleaners containing alkalis or solvents, additional precautions should be taken to minimise the possibility of accidental misuse. Specifically, actuators should clearly indicate the direction of discharge and aerosols should carry adequate warnings. For these products awareness of special labelling requirements is necessary.