Document 2jz2GX3OoEMXnOnXBwZvv0wRL

Volume 1, Number 5 December 1995 Intld Nows Feature 3 Spotlight 4 News Brief 5 People 6 People to Watch 6 Recent Releases 7 Upcoming Events 7 ACGIH + CHEMSTAR = Success Panels focus on Key Player in Worker Health and Safety ACGIH Technical Committees Agricultural Health and Safety Air Sampling Instruments Air Sampling Procedures Bioaerosols Biological Exposure Indices Computers in Safety and Health Construction Hazardous Waste Industrial Ventilation Infectious Disease ' Mining Safety and Health Research Needs in Industrial Hygiene Small Business Threshold Limit Values for Chemical Substances Threshold Limit Values for Physical Agents Since its founding in 1938, the of TLVs for chemical substances. The American Conference of Governmen Committee's recommendations and tal Industrial Hygienists (ACGIH) has notice of intended changes are subject been committed to the devel to review for a mini opment and dissemination of technical information that can be used to create a healthful and safe environment forwork ers and the surrounding com munity. ACGIH addresses both the administrative and technical aspects of worker . . TLVs m e helpful m establishing workplace regula tions . . [and] are frequently adopted by the OSHA. mum of one year, after which they are referred to the ACGIH general membership for ap proval. TLVs are limits of airborne concen health and safety while providing a trations of substances which are in forum for the exchange of ideas, expe tended for use in industrial hygiene riences, techniques and the promotion practice. ACGIH emphasizes that the of standards. TLVs are guidelines or recommenda Technical committees, which are tions in the control of occupational established by and report directly to health hazards; they are not intended the Board of Directors, are the building for other uses. Nevertheless, because blocks of ACGIH. (See left side.) TLVs are helpful in establishing work These groups conduct reviews of place regulations, the TLVs recom issues specific to each committee, make mended by ACGIH are frequently recommendations and distribute infor adopted by theOccupational Safety and mation through reports, symposia, con Health Administration (OSHA) and ferences and peer-reviewed publica state regulators. tions. A TLV is neither a fine line between CHEMSTAR Panels and Councils safe and dangerous workplace exposure that have contact with ACGIH most nor a relative index of toxicity. TLVs are frequently interact with the Threshold simply estimates, based on the best avail Limit Values for Chemical Substances able information from industrial experi Committee, commonly referred to as ence, and of human and animal studies. the "TLV Committee". This Commit The TLV Documentation contains the tee is responsible for the development data upon which the TLV is based. The CMA 030963 amount of information available willvary from substance to substance, thus some TLVs are more firmly rooted than others. Because of these potential uncertainties, Panels and Councils often assist ACGIH reviews by providing crucial data. In October 1995, the TLV Committee met in San Antonio, TX. When the TLV of Ethylene Glycol Monobutyl Ether (EGBE)wasconsidered, the EGBE Panel's EGBE Task Group shared hematology studies and their PB/PK model as justifi cation for keeping the current TLV. Next, the Panel will co-sponsor a symposium with ACGIH on Pharmacokinetics/ Pharmacodynamics in Developing Sys tems and Impact on Risk Assessment on April 21-22, 1996, in Arkansas. Panel members are optimistic that data and dialog will lead to their goal of retaining the TLV. The optimism is based on experi ence: given the opportunity, CHEMSTAR panels can contribute an impor tant service to ACGIH by initiating a scientific dialog and providing the most updated information on the particular chemicals under consideration. For example, in February 1995, the Acetone Panel sent technical experts, who had completed critical studies on acetone, to an ACGIH meeting. At that meeting, the experts provided additionalinsights into their work, discussed the relevance of their data with other studies, and suggested how their research should be considered in determining an ac etone TLV value. The Panel believes that this opportunity for scientific ex change was instrumental in addressing the concerns of the ACGIH Subcom mittee, and will lead to a proper TLV assignment for acetone. Additionally, the Oxo Process Panel had a similar experience when ACGIH proposed the lowering of the TLV on nbutyl acetate. The Panel sponsored a study to assess exposure to butyl ac etate sprays at furniture manufactur ing operations. In January 1995, the Panel presented the study results to the ACGIH TLV subcommittee. Although the committee has not yet voted on the proposed reduction, the Oxo Process Panel believes that the study provided sufficient evidence that the current TLV is adequately protective, and that ACGIH will act accordingly. The Inorganic Add Mists Panel cur rently is addressing the recommended ACGIH notation for sulfuric add as a human carcinogen. The Panel feels that the notation is not justified since it is based on IARC's classification of occupa tional exposure to inorganic add mists containing sulfuric add as carcinogenic. IARC did not classify sulfuric add, per se, as carcinogenic. The Panel currently is bringing this disparity to ACGIH's atten tion with the objective of a similar clarifi cation by ACGIH. The Panel feels that the potential for success is high. And finally, the successful ap proach the Alkanolamines Panel took in 1992 is a model for all the foregoing examples. A proposed A-2 carcinogen designation for triethanolamine was removed by ACGIH after the Panel submitted data that had not previously been considered, and presented the in formation at an ACGIH meeting. Based on their successful experience, the Panel recommends the following strategy to other groups that have issues with ACGIH: Q Watch ACGIH's "Notice of In tended Changes" for early warn ing; Interact with ACGIH at an early stage; and Q Develop a well prepared written counter-proposal. For the future, it is important to remember ACGIH and CHEMSTAR's successful past There is frequently commonality in the issues both groups address and the establishment of a good working relationship early in the pro cess can benefit alL For more informa tion on ACGIH and it's processes, call (513) 742-2020. NEWS FLASH ITC Revised PriorityTesting List The Interagency Testing Commit tee (ITC) delivered its 37th Report to the EPA Administrator on November 22,1995. The Report revises the TSCA 4(e) PriorityTestingListby recommend ing 28 alkyphenols and alkylphenol ethoxylates and removing 43 previously recommended silicone chemicals and five isocyanates. The ITC removed the silicone chemicals after reviewing submitted production and exposure data. The five isocyanates were removed upon consideration of production and im portation volume data, TSCA-related uses and data needs. Ten isocyanates remain on the Priority Testing List be cause ITC is soliciting consumer use and exposure data. The alkyphenols and alkylphenol ethoxylates in the "recommended" cat egory are subject to information gath ering. EPA will add them to the TSCA 8(d) Health and Safety rule. Manufacturers and importers of these materials will be required to submit unpublished studies to the EPA within 60 days ofthe effective date of the rule. The ITC will review the submitted studies before designat ing any of the compounds for testing under TSCA section 4. Data of interest are: 1) chemical composition data (major components and impurities); 2) environmental fate data; 3) health and ecological effects data, including data on toxicokinetics and endocrine-modu lating effects. To obtain a copy of the report, contact John Walker, (202) 2601825. i in \isi \i: December 1995 CMA 030964 in M moriam: Th D mis of CFCs On December 31 of this year let's pause a moment to consider the loss of what were once thought to be the world's "perfect chemicals" -- chlorofluorocarbons (CFCs). Invented in the 1930s as safe, eco nomical alternatives to the potentially hazardous refrigerants then in use [am monia (flammable and toxic), sulfur dioxide (even more toxic)], CFCs sub sequently found many industrial and commercial uses as aerosol propellants, foam-blowing agents, and coolants in home, commercial and auto air condi tioners. Over time, CFCs became major con tributors to a higher standard of living and to the global economy. In 1987, at the peak of production, almost 1.1 mil lion metric tons were produced world wide, generating revenues in the bil lions of dollars, CFCs are non-flam mable, non-corrosive, not explosive, very low in toxicity, and extremely stable. Stability and consequent atmo spheric lifetime are some of the very properties that led to their demise. A respect for science and product stewardship motivated chemical indus try leaders. In 1970, Dr. James Lovelock of Britain detected CFC-11 in the atmo sphere. By 1972, DuPont was calling on fluorocarbon manufacturers from around the world to meet under the auspices of CMA (then MCA) to dis cuss the environmental fate of CFCs. As a result of this meeting, the in ternational Fluorocarbon Panel was formed. Approximately twenty CFC producers from around the globe launched a program to determine the atmospheric fate of CFCs. Over its lifetime (1972-1990) the Panel spent more than $23 million to support re search in areas as diverse as: gas phase and heterogeneous chemistry; atmo spheric measurements (including ground-based,balloon and aircraftmea surements and their analysis, and more work by Lovelock); atmospheric mod eling; ultraviolet measurement; ozone trend detection; and biological effects of increased UV radiation. This fo cused program, that began with sci ence, eventually played a major role in the development of public policy on CFCs. In 1974, two U.S. scientists postu lated the potential for CFCs to contrib ute to the destruction of the earth's ozone layer. The ozone layer is essen tial to life on earth, acting as a filter for ultraviolet radiation from the sun. Its destruction could occur through release of chlorine radicals following the break down of CFCs when exposed to intense solar radiation in the stratosphere. Then in 1985, a British scientist reported that, using ground-based measuring devices, he had detected a decrease in totalozone over Antarctica. NASA confirmed these ground-based measurements after the extremely low values were retrieved from raw satellite data. Eventually, these and other inves tigations led the international commu nity to conclude that the science sup ported taking action globally. They instituted an international process to periodically assess our knowledge of important atmospheric processes. The Fluorocarbon Panel played a pivotal role in supporting international coop eration in these efforts. The results of these assessments increasingly sup ported action to curb the release of CFCs and other ozone-destroyingcom pounds. Under the auspices of the United Nations Environment Programme, in tense public, industrial and academic focus resulted in assessments not only of atmospheric science and other tech nical issues, but of the impacts of CFCs and ozone depletion on society and the global economy. In 1987, these consid erations led to the adoption of the Montreal Protocol by international gov ernment policy makers. This Protocol, now ratified by 40 nations, called for a reduction of CFC consumption, stepwise over a ten year period, to 50% of 1986 levels. In 1989 the Fluorocarbon Panel publicized their conclusion that scientific evidence justified speeding up the phase-out on a global basis. Continued scien tific research and the contin ued growth of the Antarctic "ozone hole" led in 1990 to a strengthening of the Montreal Proto col, and a total phase out of CFC pro duction by the year 2000. Subse quently, the U.S. Congress decided even stronger measures were war ranted and, as part of the Clean Air Act Amendments of 1990, passed a law halting CFC production by the end of 1995. The development of suitable sub stitutes for CFCs has not been easy for the chemical industry. Some hydrofluorocarbons (HFCs) and hydrochlorofluorocarbons (HCFCs) have received approval from EPA, but HCFCs also have some ozonedepleting potential (though less than CFCs). In addition, some of the re placements may have decomposition products that may not be as biologi cally benign as CFCs. Other chemical products and alternative processes are being explored. The members of the former CHEMSTAR Fluorocarbon Panel are proud to have played a role in facili tating international cooperation by industry, academia and government in establishing the solid scientific foun dation. This effort prepared their com panies to participate constructively in the process that led to unified action on such an important global environ mental policy issue. This effort can also be recognized as an early model for product stewardship by the chemi cal industry. Let's have a moment of silence..... For additional information on the CMA Fluorocarbon Panel, contact Elizabeth Festa Watson at (202) 8871194. December 199S CMA 030965 ID( 11! MM U This is the Latest article in a series which highlights the activities ofthe various CHEMSTAR Panels and Councils. HieVinylChloride Panelwas formed long ago -- in 1971 -- to develop and analyze health and safety concerns on the vinyl chloride monomer. Today, the health issues are addressed by the Vinyl Chloride Health Committee, one of two subsets of the Panel, and safety issues are addressed by the Vinyl Chloride Trans portation Committee, the other subset Each Committee's membership is listed below. Health JonathanRamlow ofthe DowChemi cal Company is the current chair of the Health Committee. In 1993, the Ameri can Journal of Industrial Medicine pub lished the Panel's concerns about a 1991 publication entided, "An Industry-Wide Epidemiologic StudyofVinyl Chloride Work ers," by Wong et.al. The concerns in cluded the reporting of excess mortality due tobraincancerand emphysema with out a discussion of other factors that may affect the evaluation of these findings. Dr. Wong agreed with the Panel's con cerns. He subsequently published an article subsequently in the same journal indicating that the concerns raised by the Panel were important not only for the vinyl chloride epidemiology study, but also foroccupationalepidemiologicstud ies in general. The Panel has worked with Richard Reitz, a consultant, to predict cancer risk fromvinylchlorideexposurewitha physi ologically-based pharmacokinetic (PBPK) model. The risk assessmentbased on the PB-PK model predicted considerably fewer risks than would be calculated by non-pharmacokinetic procedures. The HEALTH Borden, Inc. The Dow Chemical Company Formosa Plastics The Geon Company Georgia Gulf Corporation Occidental Chemical Corporation PPG Industries, Inc. Westlake Polymers Vista Chemical Company Committee presented this model to EPA personnel to ensure that the Agency's vinyl chloride risk estimates are based on sound scientific data and methodologies. In 1994, the Committee began nego tiating with EPA and ATSDR on their data needs for vinyl chloride for risk assessment at Superfund sites. EPA pro posed requiring reproduction, teratol ogy, and neurotoxicity testing under TSCA, if a negotiated testing program between the Agency and industry was not reached. The Committee has reached tentative agreement on a testing pro gram with ATSDR for developmental and reproductive effects testing, but has not yet been convinced of the scientific need for conducting neurotoxicity test ing. This year, the Committee con tracted with Applied Epidemiology Inc. to update the Vinyl Chloride Epidemi ology Study (1942-82), that was con ducted by Environmental Health Asso ciates in 1986. The update will analyze mortality among vinyl chloride work ers through 1992. TRANSPORTATION Borden, Inc. The Dow Chemical Company Formosa Plastics The Geon Company Georgia Gulf Corporation Occidental Chemical Corporation PPG Industries, Inc. Shintech, Inc. Vista Chemical Company JTS Enterprises, Inc. Transportation Vergel Perry of the Dow Chemical Company is the current chair of the Transportation Committee. In 1991, the Panel expanded its scope to address safety issues in the transportation of the vinyl chloride monomer. In 1992, the Committee formed a Vinyl Chlo ride Mutual Aid Network (VCNet) that provides technical expertise and assis tance by the industry and contractors to emergency responders at vinyl chlo ride transportation incidents. VCNet plans to coordinate its activities with railroad and community response teams. The Committee has prepared a map that includes information on rail road transportation routes and indus try, contractor, railroad, and selected community emergency response teams. The map enables CHEMTREC to acti vate VCNet in cases of incidents. The Committee conducts periodic mock emergency response exercises to en sure the CHEMTREC, contractor and company response teams are aligned and can act quickly in case of an emer gency. < III MSI \U December 1995 CMA 030966 The Committee has developed an Emergency Response Operation manual to facilitate the operation of the mutual aid network among CHEMTREC, vinyl chloride manufac turers and users, emergency response contractors, and railroad emergency response teams, The manual also con tains information on public communi cation in emergency situations. The Committee is in the process of prepar ing a video on use of a capping kit in the transfer of vinyl chloride at an incident site and on the use of personal protec tive equipment. The Committee also has developed a Vinyl Chloride Safety Awareness Training Workshop. The workshop is directed at industry, contractor, and community emergency response per sonnel to provide them with a better understanding of the principles and techniques involved in responding to a vinyl chloride incident. The workshop provides a detailed view of health and safety risks that may be encountered in responding to vinyl chloride incidents. As part of the training, workshop at tendees sometimes participate in a simu lated vinyl chloride incident. In early 1992, the Committee met with US Department of Transportation (DOT) representatives to discuss the industry's concerns about the DOT re quired shipping label name, "Vinyl Chlo ride, Inhibited," under 49 CFR 172.102. Most domestic shipments on vinyl chlo rideand shipments toCanadaandMexico are not chemically inhibited and there fore, would not be in compliance with the shipping label name. The Committee provided scientific support that uninhib ited vinyl chloride does not undergo a violent polymerization reaction over a short period of time. DOT agreed with the Committee and revised its Hazard ous Materials Regulations througha Fed eral Register notice in October 1992. The Committee has commented on the DOT'S proposed implementation of the UN recommendation to align the US Hazardous Materials Regulations with corresponding provisions of in ternational standards. The Panel ex pressed concern that the proposed changes to the shipping name for vinyl chloride would effectively prevent vi nyl chloride from being shipped do mestically in its current state. TheCom mittee recommended that "Provision 21" be added to the proposed listing that would permit shipping of vinyl chloride in its current state and still maintain the alignmentofthe DOTregu lations with corresponding interna tional standards. In December, DOT published a final rule (HM-215A) that included "Provision 21." TheCommittee worked with OSHA to receive clarification of the applicabil ity of the Vinyl Chloride Standard or the Hazardous Waste Operations and Emergency Response Standard when responding to vinyl chloride leaks. The clarification supported the Committee position that entry by properly trained personnel into unknown concentration or concentration greater than 36,000 ppm for non-life rescue operation is necessary to prevent catastrophic fail ure or explosion. The Committee has requested the Association of American Railroads to docket a proposal to consider standard izing manways for newly constructed rail tank cars in vinyl chloride service. Adoption of such a standard would help to ensure that allnewly constructed rail tank cars in VCM service are ca pable of accepting a transfer capping kit. The Committee will comment on DOT'S anticipated Tank Vessel and Fa cility Response Plan, and Response Equipment for Hazardous Substances mandated by the Oil Pollution Act of 1990. For more information, contact Has Shah at (202) 887-1192. Metal Catalysts Plan Ahead (September 19-20, Houston, TX) At the Metal Catalyst Panel's Fall meeting, they emerged with a clearer focus of what issues take priority for the coming year. The Panel was able to formulate an advocacy strategy for 1996 which will reflect the emerging impor tance of the Resource Conservation and Recovery Act and the Clean Air Act issues. For further information, contact Leah Porter at (202) 887-1364. Safety Seminar Success (August 29-September 1, Hilton Head, SC) The Hydrogen Fluoride Panel held their annual Safety Seminar. The semi nar provided a forum for education and information exchange covering manufacturing, transportationand han dling of hydrogen fluoride. The semi nar is an annual event and open to all interested in attending. For additional information, contactElizabeth Watson at (202) 887-1194. (H20)3 Drinking Water, Process Water and HwaI--s---t-e- IHw-a.t.er (September 14 -15, New Orleans, LA) The Chlorine Dioxide Panel in conjunction with EPA, the American Water Works Asso ciation Research Foundation, and the World Health Organi zation held an International Symposium entitled, "Chlorine Dioxide: Drinking Water, Pro- December 1995 i II! MM \\< CMA 030967 cess Water and Wastewater Issues." The objectives of the symposium were to provide information to Industry in volved in operations and management of water treatment facilities, water chemistry, health effects, application technologies and regulatory issues of chlorine dioxide. The two-day seminar also focused on generation, test meth ods and current research and health issues relating to chlorine dioxide, in cluding cryptosporidum. For more in formation, contact Dr. Robert Romano at (202) 887-1198. Petroleum Additives Presents ~ (Toronto, October 18) Members of the Petroleum Addi tives Technical Advisory Group gave a panel presentation on the CMA Code of Practice for engine oil testing at the Society of Automotive Engineers meet ing in Toronto. The three part presen tation, "CMA Code of Practice -- A Catalyst for Change" addressed the state of engine oil testing prior to intro duction of the Code, the changes brought about by the Code when it was implemented in March 1992, and how recent changes to the Code can lead to improved engine test precision and partnering with other industry stake holders in the development of new en gine oil categories. The presenters were: Bill Mahoney (Ethyl), Rick Tittel (Castrol NAA), and A1 Ross (Lubrizol). For more information, or copies of the presentation, contact Carol Stack at (202) 887-1196. TEA Tim The Alkanolamines Panel released a Panel-sponsored subchronic dermal toxicity study on triethanalomine (TEA). The study, conducted in mice, indicated that TEA did not cause sys temic toxicity. Results will be pub lished in Food and Chemicals Toxicology (Vol. 33, No. 8. pp 675-680,1995). For more information, dontact the Akanolamines Panel manager, fon Busch at (202) 887-1189. Chair it again, Wayne H. Wayne Ellice, Crosfield Catalysts, was confirmed for a second term as Chair of the Metal Catalysts Panel for 1996. Wayne has particular interest in TLVs (Threshold Limit Val ues) and PELs (Permissable Ex posure Limits). These are ar eas of major concern to the metal cata lysts industry, because OSHA is ex pected to propose new guidelines very soon. The Panel looks forward to an eventful year under Wayne's leader ship. Chair of the Hydrocarbon Solvents Panel and Vice-Chair of the Solvents Council. Thanks for meeting the chal lenge, Bob! Baby Makes Grandma Elizabeth (Bette) Moran, Ph.D., DABT, CHEMSTAR Director, and man ager of the Carbon Disulfide, Ethylben zene, Olefins and Terephthalates Pan els, can add one more title to her name...GRANDMA. The CHEMSTAR Department would like to extend a hardy congratulations to Bette on the birth ofher first grandchild,Maria Irene. and began operation--List Expansion, Technical, Membership, and User In terest A proposal on the next lists to be included in the database will be sub mitted to the Steering Committee by the List Expansion Task Group shortly. For more information on the Regula tory Data Council, contact Marian Stanley at (202) 887-1207. Cody Takes the Reign Patricia Cody, UnionCarbide Cor poration, has taken the reign from Neil Hawkins, The Dow Chemical Company, as the new Chair of the Alkanolamines Panel. This active Panel welcomes Patricia and bids a fond farewell to Neil for his superb job. Bob Makes a Double Impact Bob Chouffot, Shell Chemical Company, has been elected as the new A Half Dozen Welcomes (September 6, Washington, DC) The Regulatory Data Council wel comed six new members at its second meeting. Henkel, Eastman Kodak, Safety-Kleen, Mobil Oil, Lubrizol, and National Starch and Chemical will join the Council's Steering Committee, in creasing its ranks to twelve. The Council's mission is to compile core compliance list information on indi vidual chemicals in a standard format that all members can use, at an afford able cost. Four task groups were formed Richard Sutherland Sterling Chemicals. TheChlorine Dioxide Panel wants to thank you for the memorable signs that you created for the Third Inter national Symposium in New Orleans on Septem ber 14-15,1995. i ill mm \i: CMA 030968 December 1995 Ca nts Comments to the House Commit* teeonScience,Subcommittee nTech nology on Maintaining Our Interna CommentstoEPAontheProposed Ethylbenzene TSCA Section 4 Test tional Competitiveness: the Impor Rule, (filed by the Ef/iyllmizene Panel, tance of Standards and Conformity Assessment on Industry, (filed by the July 25,1995). Comments to EPA in Re sponse to EPA's Request for Total Quality Council, July 7,1995). Testing Proposals forthe Ne- ^ Comments ** lev:-- gotiation ofa TSCASecti n4 Enforcement Consent Agree ment, filed by the Hexamethylene Dusocyanafe Panel, August 11,1995). ^mbtr 199s TQC Does PSM... Again! The Total Quality Council and the CMA Envi ronment, Health, Safety and Operations Com mittee released the second product of their collaboration on demonstrating the connections between Responsible Care* and Total Quality Management. The new publication. Questions of Quality -- Integrating Process Safety and Total Quality: A Roadmap, Toolguide and Toolbox, is designed to assist plant managers with the creation of management systems for process safety in a total quality framework. Copies are available for $20.00 each for CMA members and $30.00 each for non-members, including third class postage. Prepaid orders should be sent to CMA, attention Trish Messenger. Payment can be made by check, or by using American Ex press, Visa or Mastercard. Iff$ _ Miration ofStote Chemical Associations Annual Report Now Available The Federation of State Chemical Associa tions members have achieved great successes over the past year. CMA, the 19 state chemical associations, and their members passed volun tary remediation legislation, advocated risk as sessment and risk management standards, lob bied for voluntary audit privilege laws, and enacted the most comprehensive civil justice legislation in this country. To leam about these issues and many more, order your free copy of the "1995 FederationofStateChemical Associa tions Annual Report" today. Please fax your request to 202/887-6926. If you need more information, contact Ann-Margaret Belke at 202/887-1322. t -* CHEMSTAR Annual Report Fax your requestto CandiJohnnson-Bityeki at ` (202) 887-5427. After January 8, fax to (703) 741-6091. CMA 9 EXTRA CMA IS MOVING Through January 1996 2501 M Street, NW Washington, DC 20037 (202) 887-1100 Effective January 8,1996 1300 Wilson Boulevard Arlington, Virginia 22209 (703) 741-5000 CHEMSTAR NEWS a published quarterly os a senxe of Chemxal Manufacturers Association, Chemical SelfFunded Technical Advocacy and Research Department No special permission is required to quote or reproduce from this publication, Credit is appreciated when reproducing articles. Correspondence may be sent to CHEMSTAR NEWS, 2S0I M Street. N.W,, Washington, DC 20037: Telephone (202) 887-1191; Fax (202) 887-5427. Dellcia Ballard, and Sarah Loftus, Editors; Marlene Johnson-BIryeki, Layout i Ml MM \K CMA 030970 December 1995