The Code

The “Aerosol Sectoral Code” defines the minimum performance criteria relating to the packaging format aspects for all manufacturers of aerosol products. This sets certain minimum standards to address the issues identified as far as they apply to the performance of an aerosol can (but not the actual product) and defines the manner in which adherence to these standards are to be maintained.

The requirements of this Aerosol Sectoral Code are obligatory on any aerosol product (including imported products), whether or not the supplier is a member of the AMA or not.

The safety and quality of aerosol products in the consumer’s hands will be assured by:

1. making the setting up of a quality management system within any company developing, marketing or filling aerosol products or manufacturing aerosol components following the principles of the AMA Quality Management System obligatory. This quality management system includes provision for Consumer Complaints Handling Procedure will be developed for handling any complaints which may be received by the CGCSA Ombud. This will make provision for:
(a) the submission of any claim-related complaint to the Advertising Standards Authority for adjudication on the validity of the claim.
(b) the submission of any quality-related complaint to XYZ for an audit of the supplier’s adherence to the QMS. This will include assessing whether the fault arose as a result of incorrect handling/storage in the supply chain.
(c) the establishment of a Sanction Regime whereby the use of the “AMA Approved” logo may be denied to any supplier does not adhere to this Aerosol Sectoral Code.
This must, most importantly, include the requirement for a fully traceable batch system for any aerosol product placed on the market. Also there will be specific defined quality parameters for an aerosol, e.g. internal pressure at 25 and 55 °C, discharge rate at 25 °C, spray and cone patterns, crimp diameter, crimp depth.
2. accepting the jurisdiction of the Advertising Standards Authority in assessing whether the claims made for any product has been adequately substantiated.
The ASA effectively claims this right in any case and their rulings would override a decision on the same matter by any other body. Probably, this will require the establishment of a Memorandum of Understanding between the AMA and the ASA to this effect. In terms of the ASA code, it will definitely require that any aerosol marketer will be in possession of appropriate substantiation reports acceptable to the ASA for any claims made for their products before placing such product on the market.
3. proposing the adoption the GHS system of hazard labelling for aerosol products as the de facto labelling standard for such products.
This will be in advance of the mandatory compliance that will in due course be required in terms of appropriate regulations from the Department of Labour. Although compliance with GHS of raw materials in South Africa would not be mandatory until these regulations are promulgated, it is in Europe, Japan and Australia (I think), so any raw material supplier that is supplying their products into these markets will be able to provide GHS compliant safety data sheets for their products.
4. the prescribing of appropriate stability test protocols in order to determine the lifetime of the aerosol product. The inclusion of the expiry date of the aerosol product on the aerosol can together with the batch identification information will also be required.
This will ensure that the supplier has acceptable proof of the stability of the product under his prescribed storage conditions (as on the label and the SDS) in order to determine whether any product failure arises from incorrect storage/handling by either the retailer/wholesaler or the consumer.
5. the establishment of a product recall procedure to ensure that a minimum level of product recall is consistently achieved.
It is proposed that the recall procedure included in the AMA Code of Practice will be adopted in the Sectoral Code.

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