Document 1gN7gQ3NzqmQOX7MaBR15kO9o

To: ' 3 - 5>o - C MANUFACTURING CHEMISTS ASSOC^^J2J^ 1925 CONNECTICUT AVENUE, N. W. WASHINGTON, D.C, 20008 (202) 483.12 n- ---------k November 2, 197 7 WO'/ 0 7 1977 ^AVV npBfi Members of the intercomnu.ttee Group on chemical Safety publications Mr. Jack S. Snyder, Merck and Company, Inc. Dr. Warren H. Jones, Eastman Kodak Company Dr. I. A. Rosenthal, Rohm and Haas company Mr. John A. stichnoth, union Carbide Corporation Gentlemen: At this time I would like to institute procedures for the preparation of drafts of the Safety Data Sheets that are listed as "First Priority" in Appendix A enclosed with this letter. (These SD's correspond to those listed in categories II and V, with some minor changes, from my March 25, 1977 letter addressed to the members of the s&FPC, OHC, LAPIC, and LAC.) As we work, our way through the SD's in the first priority list, workable procedures for the preparation of future drafts will evolve. These latter drafts are listed as second priority and third priority in Appendix A. Most of the SD's not listed in Appendix A Were identified in my March 25 letter as up to date except fox minor matters. Altho ugh some will be addressed by minor amendment at reprinting, others may be subject to temporary withdrawal. Meanwhile their distribu tion will continue until we finish new drafts for the SD's listed in Appendix A. Other SD's not listed in Appendix A are either now ready for revision-or-reaffirmation within the planned three year cycle or soon will be ready. These are: SD-16,- phosphorous, SD-43, Acet aldehyde, SD-44, chromic Acid, SD-57, Methyl Amines, SD-95, Phos gene, SD-101, Sulfur Trioxide, and SD-102, Chlorosilanes. To assure us of authoritative and unbiased review, we have instituted a continuous current awareness search of the published literature to be carried out by the Franklin Institute Research Laboratories (FIRL) for all the chemicals included in our SD's. When pertinent information is received from FIRL, it will be con veyed to the appropriate working group assigned to the SD in ques tion. Additionally the information will be useful in deciding 0whether a published SD need be withdrawn promptly from distri*UCaolV E NOV 4 1977 L. r* HO'T. JS. AP00027299 2 I propose the following procedure for trial on the first pri ority SD's and invite your suggestions before we actually initiate action, please refer to Appendix B, which is the Table of Contents for the current draft of the Guide for the Preparation of Chemical Safety Data Sheets. 1. For each SD, the Safety and Fire protection committee assumes overall responsibility and designates a person or group of persons to prepare the initial draft of most SD sections. 2. Other MCA standing committees have an interest in parti cular sections and should designate those individuals to review or prepare such sections, as may be appropri ate: Section 4 - the Occupational Health Committee Labeling - the Labels and precautionary informa tion Committee Section 8.3 - the Chemical Packaging committee Sections 8.4 and 8.5 - the Transporation Equipment committee Section 9 - the Water Resources, Air Quality, and Solid waste Management Committees In carrying out the above, the following steps are suggested: X A. working with the intercommittee Group on chemical Safety publications and with MCA Technical staff members, I will establish deadline dates for the completion of the first drafts of the SD's. B. I will advise the chairmen and vice-chairmen of each of the eight committees of these dates, requesting the assignment of individuals to "Working Groups" for each SD. Each chairman subsequently will advise me of the names of the individuals assigned. c. I will send copies of the Guide for the preparation of Chemical Safety Data Sheets to the members of the "Working Groups", along with copies of the most re cent pertinent SD. AP00027300 3 For each Safety Data Sheet: D. As necessary, I will coordinate the work and its sched uling among the members of the Working Group. E. Once a draft is prepared, I will edit it for consistency and compliance with the Guide for the Preparation of Chemical Safety Data Sheets. P. This edited version will be separated into parts corre sponding to the committee responsibilities described in paragraphs 1 and 2, above, and the appropriate parts sent to each of the members of those committees, for comment. (A sample of the form to be used is enclosed.) G. This edited version also will be sent for comment to outside reviewers not associated with the chemical ind ustry directly but expert in the fields of toxicology, occupational health, industrial hygiene, and materials handling. To this end we have made a contractual ar rangement with FIRL. H. Editorial comments received will be incorporated as practical into a "Final Draft". Substantive comments will be reviewed by the working Group and may be in corporated into the "Final Draft". X. x will send the Final Draft to members of the S&FPC, OHC, and LAPIC for a letter ballot vote, with only limited opportunity for further comments. (A sample of the form to be used is enclosed.) J. After the letter ballot vote and incorporation of any final comments, the Final Draft will be reviewed by Counsel. Following Counsel's approval,, it will be printed for public distribution. Thank you for your attention to this long letter? I await your comments. Sincerely Manager 4 Enclosures: Appendix A, SD Priority List Technical Publications Appendix B, Contents, SD Preparation Guide Request for Comments, sample Letter Ballot, Sample JAY/sa1 cc: Chairmen and vice-chairmen of S&FPC? OHC? LAPIC? LAC? AQC? CPC? SWMC? TEC? & WRC. B. M. Barackman, MCA and MCA Technical Staff members. AP00027301 Appendix A Page 1 First priority Either temporarily withdrawn from distribution or out of print and needing substantial changes. SD# Title 2 Benzene 3 Carbon tetrachloride 4 Phenol 8 Ammonia, anhydrous 12 Carbon disulfide 13 Ammonia, aqua 14 Trichloroethylene 15 Acetic anhydride 18 Ethylene dichloride 19 Dimethylsulfate 24 Perchloroethylene 31 Acrylonitrile 37 Styrene monomer 40 Methyl chloride 42 Sodium chlorate 46 Sodium and potassium dichromates and chromates 56 Vinyl chloride 58 Naphthalene 63 Toluene 74 Sulfur 81 Benzyl peroxide 85 Acrolein 89 Chloroform 90 1,1,1-Trichloroethane AP00027302 Appendix A rage 2 Second priority Need substantial changes, but now in print. SD# Title 9 Caustic Soda 26 _ Phosphorous oxychloride 45 Ammonium dichromate 43 Cresol 52 Sulfur dioxide `70 phosphoric acid 72 `isopropyl amine 73 Toluene diisocyanata 76 Diethylenetriamine 83 Methyl ethyl ketone 87 Acetone 88 Maleic Anhydride 93 Oinitrotoluenes AP00027303 Appendix A INiyo 3 Third priority Need moderate changes. SB# 17 23 28 28 38 49 50 53 54 61 65 66 67 69 71 77 78 79 82 86 97 99 100 Title Aniline Calcium carbide Phosphoric anhydride Ethyl ether Ethylene oxide Bromine Ethyl chloride Hydrogen peroxide ortho-Dichlorobenzene Phthalic anhydride Mixed acid Antimony trichloride Hydrocyanic acid Benzyl chloride phosphorous pentasulfide Sulfur chlorides Butyraldehydes Methyl and ethyl acrylate Toluidine Methylene chloride Diethylamine Allyl chloride Ethylene AP00027304 Appendix B Page 1 TABLE OF CONTENTS Guide for the Preparation of Chemical Safety Data sheets Front Matter (Introduction or Preface) Section 1 NAMES 1.1 1.2 1.3 Chemical Name Common Names Formula Section 2 PHYSICAL AND CHEMICAL PROPERTIES 2.1 2.2 Grades and Strengths Physical Properties and Critical values Section 3 TRAINING AND JOB SAFETY 3.1 3.2 Employee Education and Training Safety Review Section 4 HEALTH FACTORS 4.1 4.2 4.3 4.4 4.5 Toxicity industrial Hygiene Medical Management First Aid Personal Protective Equipment Section 5 FIRE HAZARDS AND FIRE FIGHTING 5.1 5.2 General Special Hazards Section 6 INSTABILITY, REACTIVITY HAZARDS AND CONTROL 6.1 6.2 instability Hazards Reactivity Hazards Section 7 ENGINEERING CONTROL OF HAZARDS 7.1 7.2 7.3 7.4 7.5 Building Design Equipment Design ventilation Electrical Equipment Static Electricity AP00027305 Appendix D Page 2 TABLE OF CONTENTS Guide for the Preparation of Chemical Safety Data Sheets (continued) Section 8 STORAGE, LABELING AND PLACARDING, SHIPPING, HANDLING 8.1 8.2 8.3 8.4 8.5 Storage Precautionary Labeling, Identification, DOT Labeling and Placarding Non-Bulk Containers Bulk Transport 8.4.1 General 8.4.2 Tank Trucks 8.4.3 Tank Cars Shipping and section 9 Section 10 WASTE DISPOSAL GUIDELINES AND SPILL CONTROL 9.1 9.2 9.3 Waste Disposal Regulations Spill and Leak Control . Disposal of wastes TANK, EQUIPMENT CLEANING AND REPAIRS 10.1 0.2 10.3 10.4 10.5 Preparation for the Job Preparation of the Tank or Equipment Tank Entry Emergency Rescue Cleaning and Repairs to Tanks or Equipment AP00027306