Aerosols: Is Further Harmonization Needed?

With so much focus over the years on harmonizing the dangerous goods regulations, one commodity that can definitely benefit from a focused review is the entry for aerosols.  This is particularly a concern relative to U.S. regulations, where the definition for aerosols is not aligned with the international definition.  In §171.8 of the Hazardous Materials Regulations (HMR) the term “Aerosol” is defined as

“Any non-refillable receptacle containing a gas compressed, liquefied or dissolved under pressure, the sole purpose of which is to expel a nonpoisonous (other than a Division 6.1 Packing Group III material) liquid, paste, or powder and fitted with a self-closing release device allowing the contents to be ejected by the gas.”

This definition is inconsistent with the definition of an aerosol found in the United Nations Regulations on the Transport of Dangerous Goods (UN Model Regulations), the International Maritime Dangerous Goods Code (IMDG Code), the International…