By: Kirsten Alcock, Manager of Product Safety, email
Before you determine which country you want to sell your product to, there are a couple of questions you must ask yourself: “Where is my intended market?”, “Who will be using my product?”, and “Which regulation is applicable to my product?”.
There are differences between country requirements for selling your products. Aerosols in particular have some very large differences between these requirements. Before you market your product, you need to answer all of these questions.
In addition to the country requirements, what realm is your product sold in? Is it a consumer, workplace, cosmetic, or food product? Is your intention to sell to homes, the workplace, or both? These all must be answered as the testing requirements are completely different.
The answers will determine which test methods you will require for hazard classification and labeling. Today I’d like to focus on Canada and the requirements for the Consumer Chemicals and Containers Regulations (CCCR, 2001).
Canadian consumer products require aerosol testing per the CCCR 2001 Schedule 1 -Test for Determining the Flashback and the Length of the Flame Projection of a Flammable Product Enclosed in a Spray Container.
There are differences between aerosol flammability test methods for the workplace, consumer, and between countries. Let’s delve into the consumer requirements for Canada as that is our focus today.
1. Ignition Source Temperature
The Canadian methods use a propane burner with a 5 cm (2”) yellow flame while the United States uses a candle flame. Depending on the aerosol, it may blow out the candle and therefore have no ignition observed in the US method, but ignite in the Canadian method that uses a Bunsen burner.
2. Ignition Source Position
For Canada, the CCCR Schedule 1 indicates that the propane burner candle is situated at a fixed position at 15 cm from the actuator of the aerosol.
3. The Aerosol Can Position
The Aerosol can position is different for Canada. CCCR Schedule 1 – The instruction of use shall be strictly followed, including whether the dispenser is intended to be used in the upright or inverted position. When shaking is required, shake immediately before testing. When there are no instructions by the manufacturer respecting the shaking of the spray container, test the product with and without shaking. It is important to note that if you have a straw attachment to use with your product, you must also test with and without the straw!
4. Interpretation of Results
A product is considered Very Flammable if it has a flashback (part of a flame projection that extends from the point of ignition back towards the spray container) or a flame projection 100 cm or more. The manufacturing, importation, advertising, or sale of a spray product that has a flame projection of 100 cm or more is prohibited. This is something that must be known BEFORE IMPORTATION.
A product is considered Flammable if it has a flame projection greater than 15 cm but less than 100 cm.
In conclusion, the classification of an aerosol product can differ drastically depending on the method used.
If you would like more information about your label requirements in Canada or the USA or help to choose the appropriate test method, please contact Dell Tech Laboratories for further details. Dell Tech Laboratories is equipped and the staff is trained to perform all the test methods mentioned above. Our lab is ISO accredited. We can help you test and classify your product for GHS, CCCR, or CPSC. Not many companies can make that claim. We test and consult in-house. Let us be your one-stop shop!
Dell Tech has provided professional, confidential consulting and testing services to the chemical specialty industry in Canada, the USA, Europe, and Asia for more than 40 years! We have been in the business longer than most consulting companies for a reason! We are your trusted source for consulting and testing.
Contact for CCCR Consulting:
Dell Tech
Kirsten Alcock, B.Sc. (Hons)
Manager, Product Safety Group
519-858-5074
kirsten@delltech.com
Contact for Lab Testing:
Dell Tech
Joe McCarthy, Lab Services Manager
jmccarthy@delltech.com
519-858-5024
Dell Tech has provided professional, confidential consulting services to the chemical specialty
industry in Canada, the USA, Europe, and Asia for the last 40 years.
Contact us today for more information.
