CFA supports the CPSC proposed rule to ban any aerosol duster product containing more than 18 mg of either of two hydrofluorocarbon propellants—1,1-difluoroethane (HFC-152a, CAS # 75-37-6) and 1,1,1,2-tetrafluoroethane (HFC-134a, CAS # 811-97-2)—or of a combination of these propellants. These two toxic substances are common aerosol duster propellants and both hydrofluorocarbons are intentionally inhaled to experience a euphoric high, resulting in numerous deaths. CFA also supports CPSC’s proposal to prohibit the stockpiling of aerosol duster products that are subject to the proposed ban.

While the identified number of deaths and injuries related to the inhalation of aerosol duster products is large and alarming, it is an underestimate of the problem’s scope. CPSC’s CPSRMS database contains reports for 1,039 unique fatal incidents involving inhalation hazards from aerosol duster products that occurred between January 1, 2012, and December 31, 2021. CPSC staff also identified a large number of toxicity deaths from unspecified aerosol products or deaths without sufficient information to determine whether the product was an aerosol duster product. Further, CPSC staff estimate 21,700 ED-treated injuries in the United States resulting from inhalation of aerosol duster products between 2012-2021.

While there are two existing voluntary standards related to this consumer product, neither standard addresses the hazard of intentional inhalant abuse. Further, there is no reasonable way to make current products safe from the hazard because many aerosol duster products already include bitterants and carry FHSA required labeling and statements identifying the hazards of inhalant abuse. Finally, there are alternative products, not subject to the proposed ban, that consumers can use for the same purposes, including vacuums, aerosol duster products with HFO-1234ze, compressed air dusters which use corded or cordless electric pumps, or CO2 cartridge dusters which use disposable CO2 cartridges to blow CO2 through a nozzle.