Fall Forum of the Industrie-Gemeinschaft Aerosole e.V.

On November 22, 2018 in Frankfurt

Numerous representatives of the association’s member companies came to the the fall forum of the Industrie-Gemeinschaft Aerosole e.V. in Frankfurt to talk about current topics in the aerosol industry in Germany and learn about the association’s work in the last year, to exchange ideas, and to network. After greeting the participants, the Chair of the IGA, Volker Krampe, briefly explained the program, which was very well-organized and reflected current topics extremely well. The association is particularly proud of its two new members (KPIT Technologies and Ball Aerocan CZ), who introduced themselves briefly. After Krampe’s introduction, Matthias Ibel, Managing Director of the IGA, presented the report of the Chemical-Technical Committee about the current state of discussion of the following topics:  

- Planned new regulations for plastic aerosol cans

- 12th ATP for the CLP regulation

- Implementation of the UN specifications for flexibility with respect to the precise wording of identification according to GHS

- CARACAL guidance for health-related classification of aerosols

- Guidance from member states about tactile warning labels on aerosols

- UN-GHS: Revision of section 2.3. “Aerosols”

- Recipe reporting according to the CLP regulation

- New packaging law

- Basic ingredients of explosive materials

Ibel emphasized that the consultations in Brussels about the safety requirements for plastic aerosol cans have been concluded. Currently there is a delay because new questions have been raised about the recycling of plastic aerosol cans. Therefore, negotiations of the FEA with the Directorate General-Environment are planned. The Directorate would have presented a comprehensive plastic strategy at the beginning of the year with the goal of significantly reducing consumption of one-way plastics. In particular, all plastic packaging on the EU market should be recyclable starting in 2030, according to Ibel.

For the 12th planned adjustment of the CLP regulation, there should be a new draft that includes a rule for flexibility with regard to the identification of P-phrases, said Ibel. On the question of the health-related classification of aerosols according to the CLP regulation based on computational methods, the European Commission and the majority of member states have adopted the view of the FEA in the meantime. 

Furthermore, the FEA has inquired with the European Blind Union about “tactile warning signs for aerosol products with danger of aspiration.” The EBU also recommends identification with tactile warning signs for aerosol products which, despite the general exception from the duty of identification in No. 1.3.3. of Annex 1 of the CPL regulation, would be marked accordingly in individual cases if there is a danger of aspiration. And there was a reminder that warning signs according to the applicable DIN ISO standard should be - if technically possible - placed on the spray head. 

The consultations of a UN working group on draft regulations for “chemicals under pressure” have not yet been concluded. 

Matthias Ibel then explained the reasons that VCI and IKW are currently advocating a shift of the deadlines for recipe reporting according to Annex VIII of the CLP regulation. 

The definition of “fill goods containing hazardous materials” in Annex 2 No. 4 of the packaging regulation was also discussed in the CTA, according to Ibel. According to this, “oils, liquid fuels, and other products made from oil” fall under the waste codes named there. In the opinion of the CTA, these waste codes do not apply to spray cans that contain oil, for which in practice the waste codes 150104 (metal packaging) and 150110* (packaging that contains residues of hazardous materials and is contaminated with hazardous materials) are used. 

Based on the new waste guideline, currently an ECHA database is being prepared, in which “especially worrisome materials“ (SVHC) in products will have to be reported starting on January 5, 2021. This regulation will supplement the existing duties of information according to Art. 33 of the REACH regulation. 

There was a report at the last IGA forum on the draft of the EU Commission to revise the directive EC No. 98/2013 about the marketing and use of initial materials for explosive materials. Matthias Ibel reported on the latest state of consultations in Brussels. 

The topic “FEA and CEN standards” was the focus of the remarks of Dr. Heidi Lukasch (Precision Dispensing Solutions Europe GmbH). In particular:

• CEN Standard 15006:2006: Metal aerosol containers – Aluminium containers – Dimensions of the 25.4 mm aperture 

EN was confirmed. According to an agreement, the national associations have declined another revision according to which the EN was updated. 

• CEN Standard‚ EN 15007:2017 (ex-FEA 214): Aerosol packaging – Tinplate containers – Dimensions of two- and three-part containers 

A BAMA representative has declared his willingness to draft a briefing paper in which the most relevant dimensions of an aerosol can are determined as the basis for further discussions. 

• CEN Standard 14854:2005: Aerosol containers - Glass containers - Dimensions of the neck finish 

In this standard, details from the “International Technical Center for Bottling and Related Packaging - Cetie” were adopted since no more comments were received, according to Lukasch. The standard was confirmed and now continues on the CEN level. 

Volker Krampe concluded the lecture program, among other things with the application presented by the FEA at the joint meeting to adjust hazardous goods regulations to the “15 bar”-rule of the EC aerosol directive. He indicated that the changes of the ADR 2019 have already been adopted into German law. These apply as of January 1, 2019. There is a transitional period until June 30, 2019. The IGA submitted a change proposal for the chapter on safety data sheets to the “FEA Guide on the Transport of Aerosols” formulated by the FEA, in which the hazardous goods regulations for all modes of transport for aerosols are explained in detail. In the original version of the guideline, there was an incorrect impression that safety data sheets should also be provided for the purpose of the safe transport of cosmetic aerosols. 

Several films that depicted the safety requirements for the storage and transport of aerosols ended the official lecture program.

Dr. Michael Lulei of VCI, an outstanding expert, was the guest speaker on the topic “Chemical safety: Future challenges.” In particular, Dr. Lulei discussed the topics REACH, classification and identification, and initiatives for non-toxic environment, which have resulted in discussions within the industry. 

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