Understanding Why These Products Require a Different Approach to Classification
Foam aerosols and paste-like products do not always behave the same way traditional spray containers do. That difference can have a meaningful impact on how they must be classified under the Consumer Chemicals and Containers Regulations, 2001 (CCCR, 2001). Many manufacturers are familiar with flame projection testing for typical aerosol sprays, but products such as insulating foams, caulking aerosols, and novelty spray-string items present unique challenges. Their dispensing orientation, how the product settles during storage, and the way consumers use them can all change the flammability hazards they present.
For companies selling these types of products in Canada, the CCCR framework takes a conservative approach. CCCR 2001 also restricts advertising of certain hazardous products, alongside manufacturing, importation, and sale, especially for those classified as very flammable, very toxic, or very corrosive. Depending on how the product behaves, it may need to be evaluated under more than one flammability criterion. In practice, this means a foam or paste aerosol may require flash point testing of the emitted material, flame projection testing of the propellant, and an assessment of flammable gas criteria if pure propellant can be released during use. These requirements help ensure that products are classified based on the most hazardous behaviour a consumer may encounter.
This article explains why these products are treated differently under CCCR 2001, when each flammability test applies, and how Dell Tech supports manufacturers in obtaining an accurate and defensible classification. Dell Tech’s long-standing business experience and trusted expertise ensure comprehensive support for product safety, testing, and compliance services.
Why These Products Are Treated Differently Under CCCR 2001
Foams, mousses, caulks, and spray-string products fall into a special category because of how they are dispensed. Many of these products are intended to be used in an upside-down position so the internal dip tube can draw up the product. When the container is operated upright, the material inside often settles to the bottom of the can. This leaves a layer of pure propellant above the product.
If a consumer presses the nozzle while the container is upright, or clears the nozzle after use, the can may release pure hydrocarbon propellant such as propane, butane, or dimethyl ether. These gases are highly flammable, and the hazard may not be obvious from looking at the foam or paste that normally comes out of the container.
To address this, Health Canada recommends that the manufacturer is responsible for evaluating both the emitted product and the propellant when there is a realistic chance that pure propellant can be released. Testing procedures should be conducted in accordance with the manufacturer’s respecting instructions, such as whether the container should be shaken before use, to ensure compliance and accurate results. This approach ensures that the final category reflects the most hazardous situation a consumer could encounter.
Products intended exclusively for use in the workplace are subject to different regulations, such as the Hazardous Products Act and WHMIS, and are not covered by CCCR, 2001.
The Hazard Challenge: Pure Propellant Release
The central issue is that these containers can produce different types of emissions depending on how they are held. In their intended position, the product dispenses as a foam, paste, string, or similar material. In this form, it may not pose a high flammability hazard. Flash point testing of the emitted material helps determine that.
When the pressurized container is used upright, especially after some of the internal product has been dispensed, pure propellant can be released. This behaviour does not occur in most conventional aerosol sprays. CCCR therefore treats these specialty products differently. When alternative position to intended use (typically upright for products intended to be used inverted) or nozzle clearing can result in the release of pure gas, the product must also be evaluated using the flammable gas criteria.
The flammable gas criteria is listed in CCCR 2001 49 (1), items 5 and 6, stating that a gas is considered flammable in the case that:
- A gas, other than a gas in a spray container, that forms a flammable mixture with air at a concentration of 13% or less by volume at normal atmospheric pressure.
- A gas, other than a gas in a spray container, that forms a flammable mixture with air over a concentration range of 12% or more by volume at normal atmospheric pressure.
The CCCR guidance document emphasizes that if pure propellant can be released, manufacturers should consider both the flash point of the emitted material and the flame projection/flash back of that propellant. The product is then classified into the most flammable sub-category to ensure the safest outcome.
Relevant CCCR 2001 Flammability Requirements
Depending on how the aerosol behaves, several CCCR flammability criteria may apply.
Flash point of the emitted material
If the product dispenses a foam, paste, or string, the flash point of that emitted material must be considered. Some emitted materials behave differently from the bulk formulation inside the container.
Flammable gas criteria for propellant
If pure propellant can be released, the classification must also consider the flammable gas criteria (CCCR 2001, 49 (1) items 5 and 6). This is necessary whenever gas-only emissions may occur during typical consumer behaviour.
Flame projection and flashback
This test applies when the product behaves like a conventional aerosol spray that emits a spray in the horizontal plane. Although this is not usually the case for insulating foams or caulks, it can apply to spray-string products and other specialty aerosols that function like traditional sprays. The flame projection and flashback test is specifically designed to assess the hazards associated with a flammable product enclosed in a spray or aerosol container.
As mentioned in the case above, if the foam product can emit pure propellant in an alternative position, the flame projection and flashback of that propellant release should be evaluated.
In every case, CCCR instructs manufacturers to use the most hazardous applicable result when determining the final classification.
Dell Tech Lab Services Staff and our Product Safety team, work together to ensure the appropriate testing is conducted and suitable for compliance purposes. We make these decisions based on the nature of the product, directions and directed position/orientation for use, and additional considerations like gun attachments, straws, tubes, multiple actuators, or multiple actuator settings.
When Flame Projection and Flashback Testing Apply
Flame projection and flashback testing are standard for traditional aerosol sprays. They do not automatically apply to insulating foam, caulk, or paste aerosols unless the product can emit pure propellant. Many foam sprays cannot emit in the horizontal plane, or do not have a spray length long enough (> 15cm) to pass through the ignition source for evaluation, and so must be tested for flammability by other means.
Spray-string novelty products dispense in a horizontal direction and behave like conventional aerosol sprays, so flame projection is appropriate for those products. Flash point testing of the emitted material must still be considered. Testing should be conducted on containers of the same size to ensure consistent and comparable results.
This combination of tests helps determine an appropriate and safe CCCR sub-category.
When Flash Point Testing Applies
Flash point testing is required when the product emits a substance that is not a mist. This includes foams, pastes, gels, and string materials. The flash point of the emitted product is not always intuitive. Some foams or pastes ignite at lower temperatures than expected. For a chemical product in the form of a solid, paste, or gel, CCCR 2001 requires that the flash point be assessed by standard method ASTM D56, using a Tag Closed Cup Tester. Dell Tech is ISO 17025 accredited to perform ASTM D56.
Dell Tech evaluates each product to identify whether flash point testing of the emitted material is required under CCCR 2001. It is important to test a sample that reflects what a consumer would actually encounter during use.
When Flammable Gas Criteria Apply
The flammable gas criteria apply whenever a product can release its propellant without the foam or paste component. This may happen when:
- the product is used upright
- the internal product has settled
- the nozzle is cleared after use
If the propellant is a flammable gas, such as propane or dimethyl ether, this behaviour needs to be considered in the final classification. The emitted foam or paste and the propellant are evaluated, and the most hazardous result determines the final category.
This evaluation is not a part of our Laboratory Services or testing. It is a consideration that our Product Safety team would take into account if performing a consumer chemical label review for a client product.
How Dell Tech Supports CCCR 2001 Flammability Classification
Dell Tech performs the full range of flammability testing required for CCCR classification on our ISO 17025 accredited scope, including:
- Flash point testing of emitted foams, pastes, or strings
- Flame projection and flashback testing
- Transportation-related testing – UN TDG Foam Flammability
Our laboratory team evaluates each product based on its form, dispensing orientation, and packaging to determine which criteria apply. While Dell Tech does not provide full regulatory consulting outside defined project scopes, our reports provide the data needed for accurate classification. Our Product Safety team also offers CCCR 2001 packaging and labelling consulting to help clients ensure that all required elements and text are included on their packaging and labels, based on the results of hazard classification testing. Please note that is it an additional optional consulting service, and not automatically included with the laboratory test performed.
All testing is conducted under controlled laboratory conditions in the prescribed manner to ensure safety and consistency, following good laboratory practices to ensure consistent and reliable results.
Common Products We Test
Dell Tech regularly tests:
- Shaving foams, cosmetic mousses, and other personal care foams
- Expanding insulating foam aerosols
- Caulking or sealant aerosols
- Spray-string novelty products
- Other foaming, paste-like, or specialty aerosols not classified as conventional sprays
The common feature is that these products often release foam or paste during normal use but can release pure propellant in certain situations.
Testing Limitations for Gun-Attachment Products
While CCCR 2001 flammability testing methods may apply to foam aerosols that dispense in the horizontal plane, certain challenges arise when products are actuated using gun-style attachments:
- Horizontal clearance constraints
- The CCCR Schedule 1 flame projection test requires measurement at 100 cm beyond the ignition flame.
- When gun attachments are excessively long, our fumehood does not provide sufficient horizontal plane clearance beyond the 100 cm mark to safely capture results.
- This limitation prevents accurate evaluation while maintaining the required safety buffer.
- Higher-pressure spray risks
- Gun attachments often deliver product at greater force than standard aerosol valves.
- This can result in a fireball effect, where burning foam impacts the fumehood wall rather than projecting in a controlled stream.
- Such behavior poses a greater safety hazard to laboratory staff compared to typical aerosol sprays.
- Regulatory implications
- Under CCCR 2001, Schedule 1, any product with a flame projection greater than 100 cm is prohibited from sale in Canada.
- For gun-actuated products, the combination of extended attachments and higher spray pressures increases the likelihood of exceeding this threshold, making compliance more difficult to demonstrate.
Preparing Samples for CCCR Flammability Testing
Manufacturers can send samples using the same process as our other hazard classification tests. If the sample requires an adapter or an attachment in order to actuator or release the product from the can, please include this attachment with the samples.
A completed Sample Submission Form should accompany the shipment or be emailed to our team. The product name should be listed exactly as it should appear on the final report. Clients should also include handling instructions for the technician, such as shaking requirements for aerosol containers.
The Safety Data Sheet should be shipped with the sample or emailed to our team. SDS information helps us determine safe handling procedures during ignition-based tests.
International clients should be aware that customs officials have increased their scrutiny of lab sample shipments. Declared values of one dollar or zero dollars are often flagged and can cause delays. Accurate customs details and a reliable courier help prevent this. Dell Tech can provide contact information for our customs broker upon request. Fees apply.
Turnaround time begins once the sample, Sample Submission Form, SDS (if required), and prepayment are all received.
Why Proper Classification Matters
Incorrect classification under CCCR can lead to non-compliant labels, consumer safety concerns, or enforcement action. Because foams, pastes, and novelty aerosols can behave differently depending on how they are used, more than one type of flammability test may apply.
Objective laboratory testing ensures that the classification reflects the most hazardous behaviour. This supports compliance and helps protect consumers.
Conclusion
Foam aerosols, caulking products, and spray-string items require a careful approach to flammability testing under CCCR 2001. Their unique dispensing behaviour means the emitted product and the propellant may both need to be evaluated. Flash point testing, flame projection, and flammable gas assessments can all play a role in determining the safest classification.
Dell Tech provides the laboratory expertise needed to evaluate these products reliably. Our team is ready to assist with CCCR flammability testing and other hazard classification needs.
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