‘Alternative Methods’ of Aerosol Testing
In the UK, the Department for Transport (DfT), which is the UK competent authority for ADR 2017, has indicated that to provide a smooth transition, any company that can demonstrate that it has in place an ‘alternative method’ complying with the requirements of ADR2017 may apply to use it prior to implementation into UK Regulations, expected in January 2017.
To take advantage of this derogation, the company will need to verify that their ‘alternative method’ provides an equivalent level of safety to the hot water bath test
The ‘alternative method’ is prescribed in ADR 2017 18.104.22.168.2 (Annex A), it has three key elements:
- A Quality System that ensures all aerosols that leak or are deformed are rejected and not offered for sale.
- Pressure testing of all empty aerosols to ensure that they do not deform when filled and leak at a rate less than 3.3 x 10-2mbar.l.s-1.
- Leak testing of all filled aerosols so that they do not leak at a rate greater than 2.0 x 10-3mbar.l.s-1 at 20°C.
Currently the only ‘alternative method’ that has been demonstrated to comply with the requirements set out in ADR2017 is the one developed by FEA.