New Petition to Harmonize HMR and International Aerosol Definitions

摘要

Clearly a careful reevaluation of the requirements is needed when considering the industry petition. The HMR and international regulations currently evidence that a higher degree of risk is posed by aerosols that contain only a gas, particularly those that contain a flammable gas. Both the HMR and international regulations inconsistently address the risk posed. The biggest concern arises in the case of air safety. Should aerosols that contain only flammable gas be allowed on passenger aircraft when an aerosol of comparable hazard is currently forbidden? We find that the regulatory approach is inconsistent considering that other aerosols charged with highly flammable liquids are authorized on passenger aircraft under both international and domestic regulations. Better consistency of approach is needed in both the HMR and international regulations when it comes to aerosols and related products. Aerosols encompass a wide range of articles with widely different degrees of hazard. The UN Manual already defines a group of aerosols considered "extremely flammable." But this distinction is not currently used in transport regulations. Rather than simply accepting or rejecting the petition, more consideration could be given to rank ordering aerosols based on the risk that they pose, particularly those with high flammable liquid and gas content. If shown to be necessary, any need for further rank ordering the hazards of aerosols could be worked into the HMR and international regulations in the future to provide a harmonized approach worldwide. A similar approach is already in process with lithium batteries. Perhaps this is another area where some further differentiation is appropriate. As for the overall impact of the petition should it be implemented, no actual cost data is provided; but one has to wonder what portion of the aerosol industry is placed in "precarious disadvantage" by the current difference?