Document 1yYEdbOO15zjBLxKxVkrJj5X

Yj fcXHIBM 1 GF-757 (i&rfuntal l&rmt, tfitniisl] aiu) Carquci* ^ssonatum I o^mrntm MIJIDIKT--(MUT t. TIOS. (ne RP R AT * D 2201 NEW YORK AVE. N.W.. WASHINGTON, D. C. iuicmc jiUUIOHCNf--*. fCnA*rHv>I cL. .Hrlilti4urgv*lvli.* Caiua* OFFICE OF THS PRESIDENT tuic W. CLTOrn. WatMatTC* 0. MACP9NAID. WliRlRataj July 18, 1939 TO CL.4SS A l.'LM-TRS: CONFIDENTIAL Not for publication icickal vi:i >=[: rtvri c t ( v ii;q. :*>;i rh. umm ( ? I9WTM(|*-- fLl. CCC luv( <j*av--.vf4* a| c- ;,(9 --4 9 ! <; i: 2t*IIf0h M. MCE f 9 fl : :>T aiv:i'R--| : ic Toxic mtsrials with their ever-present problems require our conscientious c:r~ iiderotion of the fundwoental principles involved. The N'ticr.sl Paint, Vsruish end Lacquer Association is keenly interested in providing Class A nsnbc-rs -..itn ns much infor.r.ation on this subject as is practicable at this tire. Tiu.s ir.fumetion being confidential is not intended for general publication, - it is. being sent only to tfca Class A group, pluas* rGspoct this confidence. The vital factor concerning toxic ..latsrials is to intelligently safeguard the public. People ray feal safer in buying materials whose danger they know rather than materials unknown to them. ffe trust the Several phases presented herein ivill bo of some benefit to cambers in applying every precautionary erasure in manufacturing, in selling end in use- where toxic materials are likely to or ao enter a product. Toxics end their effects is a subject very brood ir. scope end can only briefly be treated in this message. Children's toys, equipment, furniture, etc. are not tne only consideration. Toxics - ,.ui'.y compounds used in puints or lacquers may hove harmful effects if cr.rclessly handled. Toxic isctcrials any enter the body through the lungs in the foru of dust, r.ust, vapors, or gases, through the skin, or through the mouth end stomach, n.ctcnai inhaled into the nose and mouth can dissolve in the saliva one be sv/clloi.sd. Irritant .materials u*y clso nova a direct action upon tno skin end the mucous membranes of the.4ys*nose, mouth,and threat. It must be remenbored that all people do not react in the sane way when exposed to chemicals, Som* may be quite seriously affected by quantities which ere harmless to cithers. Hcnc*, it follows that any one using print and allied prod uct* should ;irovide adequate ventilation and should observe ordinary sanitary ncesurcs such as the washing of the hands and face before eating end keeping the clothes clean. Dirty work clothes, including sho^s, can bo an important source of skin obsorption. Soma of the ingredients of pr.int3 end allied products might receive opocial mention because of their specific effects, rather than because they neraly displace pert of the air or causa slight discomfort if token into the stomach or system. ollov-'ing pigments .may be considered ns toxic if they find their toe. ;ch. The ..mount tolerated by the body varies with the pige, into t :ti:,cny. Antimony oxide, fIopls yyccJilroov, or other untieo:o' .ntinony is supposed to be considerably loss toxic than lead N C A 0 0 2901 / -2- there. is ouch evidence tu l^dicato that it is a toxic .ietorixl.) I'-cjr-y cases of suspected untmony poisoning have been tr.-ced to the Acco-;v_Ln.yin<_; Iced. irsenic Ccr.pounds. Paris groan or other coupounds cent.lining arsenic. C:-.'Ca.-'jciuri sulfides *rid seleriJns ore toxic, but btiong to the icoy uifed pi^nents. Chr;*^1-:-- Chrorrt^s of nil types are oncerstood tc be rei^ti-cly toxic w Cl.r0ri.a7. oxides ore relatively :ion-toxic. Lc:c Cociounas. I7uite lerd, red lead, iitnarge, lead chror.ctos (chrcr.e yelled, chrone green), or other lend pigments. Herrurv. Rert and yellow oxides of osreury or other products err.tcir.ir.s ccr.ury. - Liquids - Alcohols. The toxicity of ntthyl alcohol is very eeil *ro*n. as used in li-ccuirs, the other alcohols are relatively h-.rrdess. l-i-r.zol. This is probably th>* uost dangerous of ell curriercial solvents, but it,s use* ir. our industry is probably restricted to certain paint Lnd v-c.-.nish recovers. Chlorinated Hydrocarbons. Curbon tc trichloride, tricklor ethylene, t_-trr.c!ilorethnne, uthyle.ie uiciiloride, end similar chlorinated riiphntic. hydrocarbons are said to be very u ji.'joroju tones. Chbcrui^ted r-'/uU-tic hyuroc .rbor.a .'.*0 enri to be iucr- toxic th t;.o corvcn^onaL-.g 'yurociirbon itcoif, but some chlorinated area tics are frequently t.ne sour of rkin troubles. Lccr.uer Solvents. There is scae evidence that the acotntcs--ethyl, butyl and catyl--cro more or less toxic. Acetone and thi ether ketones arc rvir.tively hcroleas. Mojt other solvents used to a lesser extent ore either hornless in thexselves; ere used in such relatively snail anour.ts, or arc sc sicsiy evaporating that they present no he sard. MethyliAlcohol. The use of this product should be avoided. It is Ocfir.itc-ly poisonous. Solvent Nr.phthA. This is tlso relatively nor-toxic as compared tc benzol; ana probably less toxic than toluol ^nd xylol. Toluol end Xylol. In equal concentrations, those arc said be acre toxic than bonxol, but because they are loss volatile tho actual huzord is usually less. NC A 0 02902 / -3- Trtcresvl Phosphates. The para- and cets-tricresyl phosphates which are used as plasticizers are nor.-toxic. Orths-tricrasyl phosphate, on the other hand, ie> & violent poison. 'Turoentlne and f.'.lr.erel Spirits. These products ara relatively non-tcr.ic cut are still listed in works on toxicology as causing eczena and irri tation of'the skin and mucous membrsinos. Sosa people exposed to the funas are; subject to internal disorders when breathing substantial ar.eur.ts of turpentine. Minarcl spirits is less toxic than turpentine. Other rZ?.3tlcigors. Very little is known regarding the toxicity of other c.-naon so-called chemical plasticizers, but the hazard from volatility or dust is, of course, small. The sain consideration, whenever paint produets ore used, Is constant repetition to the paint consumer of the necessity of employing edequata ventilation and maintaining personal hygiene. Printed Vatter - Color cards and advertising literature should not in clude any;reference by the use of words or sketches to indicate or racemnend a product for children's toys, equipment, furniture, etc., unless it is absolutely free from toxic materials. Nan-Poisonous Colors - It is generally concoded there is relatively little danger of toxic effect from paints on toys and nursery furniture, as both the paint isanufaeturer and the toy manufacturer arc familiar with the types of non-poisonous pigments to use. Nevertheless, the individual company should constantly guard against using any toxio material, especially lead compounds, in products for finishing children's toys, etc. Nota: (See page #7 of "Odds and Ends", a special circular of the Scientific Section Notional Paint, Varnish and Lacquer Association, issued August 1938.) Grcwn-ups arc exposed to some hazards as in tha case, of children. There fore products for finishing pencils, and other articles that may be placed in tha mouth, through habit, require the uso of toxic-free oateriels. Labeling No definite proceduro is recocoended for labeling. Labeling is serious since it becomes a public matter with the question as to what would result if this were done. Each manufacturer can sbiy cope with tho toxic material situation fay constantly safeguarding the public through the prod ucts he manufactures and by the repetition of instructions to salesman, service men and others who eon intelligently instruct the consumer of the edvanteges of providing adequate ventilation and of maintaining personal hygiene. ; General - The statement of legal principles listed below was prepared for i.nd distributed by the Manufacturing Chemists1 Association for the guidance of its locmbcrs concerned with labeling problems, and is supported by decisions of tha courts. Although the principles set forth are not entirely the result of litigation involving material used by members of our industry they are nevertheless generally applicable to situations arising from the use of harmful substances. N C A 0 02902 Manufacturing Chemists' Association Legal Principles 1. A .manufacturer who puts out c dangerous cirticlu or substance without uccor.jsanyinfr*lt with u warning at to its dangerous prupertias is erdinsrily liable for any das-jge which results from such failure tc warn. 2. A ^manufacturer or dealer who erroneously labels a dangerous drug with the name of a harmless substance is liable for any injury which nay be; caused thereby. 3. Failure to comply v.ith c statute, e.g., with respect tc lubtlirg pcisen?, is usually held tc be negligence per sc or ct Least evidence of negligence. L. Thu nine of the product alone nay be sufficient turning, if its na ture i3 very widely knct>n or its sale is restricted to those who ore pras'.vced tc know its nature, but even in such cases the advisability of t-specific warning is indicated. 5. Technical accuracy may not bo sufficient protection for the manufac turer if he uses words which nay give the purchaser the impression that his product is not whet It octu;u.ly is. 6. A nonwnmnty of results is net a warning against possible dangerous results. 7. The ecnsx-ar is entitled to roly on positive representations or di rections appearing on the label vmless ha knows then tc be incorrect. 8. The manufacturer is ordinarily net liable if his product is put tc a use for which it is not intended and an injury results which eculd net reasonably have been foreseen, t-t is often difficult, however, to V^vcw whether a particular result should hava buen foreseen, and thu courts are apt to differ on this point. 9. The manufacturer or one who holds himself out to be the manufacturer must know the qualities of his product and ho cannot escape liability on the ground that he did not know it to be dangerous. 10. The general nil* that a manufacturer is not liable to those not in privity of contract with him does not apply when hi a product is immi nently or inherently aangarous. Conclusion r tfe grant that this is a very broad subjact, and doubt if a conclf:*et cf rules can be established. Nevertheless, it may be sola that our centers can meet their individual problems in safeguarding the public, including of course our o|wn factory employees, by their sincere effort in taking advantage of every possible proccution in the use of toxic materials In manufacturing, selling and in use. Q. Q2?Q4