Document 4vXYKa0rVMgdz91B9rymZmB3V

CHEMICAL SPECIALTIES MANUFACTURERS ASSOCIATION 202/872-6440 August 25, 1981 TO: CSMA Membership FROM: Ralph Engel President RE: Hazardous Materials Identification System This past January, the Occupational Safety and Health Administration (OSHA) published an extremely important proposal addressing chemical hazard identification. CSMA strongly opposed the drastic approach taken, and in February the Reagan administration rescinded the proposed rule. In response to pressure from labor unions and some members of the chemical industry, OSHA created a task force to develop a substitute rule. OSHA plans to publish a proposed regulation in the near future. We have established a task force to help formulate a CSMA position as the issue develops, and member companies should be prepared to advise us of their views on this highly significant matter. In the meantime, there have been discussions between chemical suppliers and downstream users as to how the chemical industry as a whole should communicate hazard information. Many suppliers are concerned that an OSHA performance standard would lead to a variety of responses from suppliers, frustrating any uniform system of rating hazards. These ratings would appear on the material safety data sheet or equivalent document, and would be most helpful to suppliers if they are universally accepted. There have also been discussions among processors, who appreciate the suppliers1 concern and see the advantage of having a uniform system. The National Paint & Coatings Association (NPCA) has developed a Hazardous Materials Identification System (HMIS), which includes the enclosed rating scales for hazards related to health, flammability, and reactivity. The central concept of HMIS is to create labels for these three hazards, using a five-tiered scale for each hazard, and designating the proper personal protective equipment, so that an CCR 000001B70 2- - employee will be able to handle the chemical substances he deals with safely. The system is color-coded to communicate the relative degree of hazard, so that a label will show the health hazard rating on a blue background, the flammability hazard rating on a red background, and the reactivity hazard rating on a yellow background. Symbols or letter designations oh a white background will show what protective equipment the worker should use. Since NPCA has asked other groups of processors to endorse HMIS, this memorandum seeks to solicit opinions from CSMA member companies with regard to the HMIS system in particular, and the idea of a uniform rating system for hazard communication in general. Please fill out the enclosed survey and return to CSMA as soon as possible. RE/kms Enclosures CC R 000001 871 Survey on HMIS My company's position with regard to NPCA's HMIS system can best be described as follows: Supports the HMIS hazard rating scales /\ Supports the concept of a uniform hazard rating system for the chemical industry, but not necessarily HMIS Opposes the HMIS hazard rating scales Opposes the concept of a uniform rating system for the chemical industry No established position Other (Please explain) Please submit any other comments you have on HMIS Upon completion, please send this survey to CSMA at 1001 Connecticut Avenue, N.W*, Suite 1120, Washington, D.C. 20036 Attention: HMIS Survey Individual Completing the Form Company TABLE 1 HEALTH HAZARD RATING CHART 0 MINIMAL HAZARD no significant risk to health i SLIGHT HAZARD irritation or minor reversible injury possible 2 MODERATE HAZARD temporary or minor injury may occur 3 SERIOUS HAZARD major injury likely unless promot action is taken and medical treatment is given 4 SEVERE HAZARD lile threatening major or permanent damage may result trom single or repeated exposures FLAMMABILITY HAZARD RATING CHART 0 MINIMAL HAZARD 1 SLIGHT HAZARD materials whieh are normally stable and will not bum unless heated materials that must be preheated before ignition wiU occur. Flammable liquids in this category will have flash points (the lowest temperature at which ignition wtii occur) at or above 200F (NFPA) Class II and Oats lit A) 2 MODERATE HAZARD material which must be moderately heated before ignition will occur, includ ing flammable liaulds with flash points at or above 100F and pelow 200*F. (NFPA) Class ill B) 3 SERIOUS HAZARD msteriels capable ol ignition under almost all normal temperature condi tions, including flammable liquids with flesh points below 73F and bolting points above 10QF as welt as liquids with flash points between 73 F (NFPA Classes IB and 1C) 4 SEVERE HAZARD very flammable gases or very volatile flammable liquids with flash points below 73F and boiling points below 100F (NFPA Class IA) REACTIVITYJHAZARDJIATINGlCHARTo3 0 MINIMAL HAZARD materials which are normally stable, even under (ire conditions, and which will not react with water. 1 SLIGHT HAZARD materials which are normally stable, bu> csn baeoFne unstable al high lemperatures and pressures. These materials may react with water, but will not release energy violently. 2 MODERATE HAZARD materials which in themselves are normally stable and will readily undergo violent chemical change, but wilt not detonate. These msterials may also react violently with water. 3 SERIOUS HAZARD materials which are capable of detonation or explosive reaction, but reoulre a strong initiating source, or must be heated under confinement before initiation, or materials whieh react explosively with water. 4 SEVERE HAZARD these materials are readily capable of detonation or explosive decomposition at normal temperatures and pressures. CCR 000001873