Pressure Points
Behind the Scenes
of Aerosol Fire Codes
According to John LeBlanc, Staff VP, Principal Standards
Engineer, FM Global, the aerosol industry is the only
industry that conducts fire testing before the product goes
out to market. For readers in the aerosol community, be proud
that we, as an industry, have the forward-thinking ability to protect
consumers and workers through thoughtful development and
preventative testing.
Since the 1980s, the Household
& Commercial Products Association
(HCPA) (formerly the Consumer Specialty
Products Association CSPA), has
helped develop and maintain National
Fire Protection Association (NFPA) and
international fire and building codes
that allow aerosols to be manufactured,
stored in warehouses and placed on store
shelves. HCPA has always used sound
science to assure that its positions are credible and compelling to
the fire officials, insurers and fire engineering professionals who
manage the nation’s complex system of fire and building codes.
More recently, HCPA has introduced new codes for both the
2019 edition of NFPA 30B, Code for the Manufacture & Storage of
Aerosol Products, and the 2021 edition International Fire Code (IFC).
These code change proposals expand on the allowance of aerosol
For readers in the aerosol community,
be proud that we, as an industry,
have the forward-thinking ability to
protect consumers and workers
through thoughtful development
and preventative testing.
products in plastic containers. Currently, aerosols in plastic
containers that meet the code definition of Plastic Aerosol One
are allowed to be manufactured and stored. The code changes
introduce a new category—Plastic Aerosol Three.
If the code changes are accepted, Plastic Aerosol Three would
be defined as those that meet one of the following criteria:
1. The base product has no fire point when tested in accordance
with ASTM D92, Standard Test Method for Flash
and Fire Points by Cleveland Open Cup Tester and there is not
more than 10% by weight flammable propellant
2. The base product does not exhibit sustained combustion
when tested in accordance with 49 CFR 173, Appendix H,
“Method of Testing for Sustained Combustibility,” on the UN
Recommendation of the Transport of Dangerous Goods, and there is
not more than 10% by weight flammable propellant.
3. The base product contains no more than 50% by volume
of flammable and/or combustible, water-miscible alcohols in
an aqueous mix, and there is not more than 10% by weight
flammable propellant.
Plastic aerosol containers open aerosols to new product lines
never seen before because plastics can handle certain chemicals
that would corrode metal containers. They are an additional option
in the toolbox for manufacturers, formulators and marketers
to use and extend current product portfolios.
These code changes are possible thanks to the collaborative
work of Plastic Aerosol Research Group, LLC (PARG) and FM
Global. They constructed and executed a testing plan, utilizing
sound science, which developed the necessary data to support
these codes. If you have interest in plastic aerosol containers and
in becoming involved with this development work, joining PARG
grants you access to the data that has already been developed, in
addition to an influential role in designing test protocols and the
development of new methods and standards for any future work.
Please contact Hannah Alleman (halleman@TheHCPA.org) if
interested.
Hopefully, both NFPA and the International Code Council
(ICC) accept these code changes; however, that doesn’t mean that
manufactures can jump right on in.
Currently under the 49 CFR § 173.306(a)(5):
For limited quantities of Division 2.2 gases with no subsidiary risk, when
in a non-DOT specification or a specification DOT 2S (§178.33b of this
subchapter) plastic aerosol container (see §171.8 of this subchapter for the
definition of aerosol) provided all of the following conditions are met.
Under the limited quantities of compressed gases, The U.S.
Dept. of Transportation (DOT) does not currently allow flammable
propellants to be used in plastic aerosols when utilizing the
limited quantity exemption. This means aerosol manufacturers
will have to request and utilize special permits to formulate using
flammable propellants and ship under the limited quantity until
this section is modified. HCPA is currently working on petitioning
DOT to allow the use of 2.1 gases in plastic aerosol containers.
If you would like to be a part of this effort, contact Nicholas
Georges (ngeorges@TheHCPA.org). Spray
10 Spray March 2018
NICHOLAS GEORGES
Director, Scientific Affairs, CSPA