Document 65dBbwLjG9zQBr11mbLOzZ9Od

FILE NAME: Union Carbide (UC) DATE: 1981 Dec 4 DOC#: UC315 DOCUMENT DESCRIPTION: Memo RE Carcinogen Labeling Policy 4 H S S 2 ;^ 5 -, > ' J.W A 'C: -> JNT2JSMAU c c s ^ S 5 p c ^:c 3A;c s VNIC! fi-,.,. UNION CARBIDE CORPORATICN oia RKjgecuryRoad,"a^cury.C~ 33S i 7 v^=TAl_S DIVISION Tz :\ a rre ; Dv<s L.3C3C'Cr A-ea Mr. W. C. Thurber Metals J1398 Ccc.- ".c Mr. J. Myers - King City Oaza O^girat-^o Oeot December 4, 1981 R W Rebholz Area SwOiect Carcinogen Labeling Policy Attached are draft policies coveringr o Chronic Health Hazard Labeling - Carcinogens o Distributor Policy (Re:Product Safety) These drafts will be reviewed on December 9th at a Product Safety Communications Committee meeting here in Danbury. I will attend the meeting and would appreciate your comments regarding the attached. Copies of the drafts have been sent to John Myers via the telecopier machine and he has agreed to call here December 7th with his comments. RWR:sf Attachment UCC 023947 PURPOSB/BACKGROUND One element of an effective precautionary labeling program is inclusion of warnings for chronic health hazards that potentially might arise from improper use and/or exposure to the involved hazardous chemical substance. This policy concerns the hazard warnings that should be used for those hazardous chemical substances that have demonstrated carcinogenic potential. Some state governments and the Federal Government have exercised authority in mandating hazard warnings for hazardous chemical substances demonstrating carcinogenic activity. This policy will supplement and not supplant such authority. * Precautionary labeling is a part of our product safety program furnishing customers with information about the potential hazard and the safe handling of our products and this policy is merely an ( extension of our Precautionary Labeling Policy. The labeling of carcinogens are treated as a special class for several important reasons) they have a long latency period before the adverse effects are observable and the determination of material possessing carcinogen potential is complex and requires the judgement of trained professional toxicologists and/or doctors. Proper product labeling is essential for the safe use of hazardous chemical substances including carcinogens and products demonstrating potential to cause other chronic health hazards. The purpose of this policy is to provide a basis for management programs to identify potential carcinogen materials and provide for their uniform labeling. The Corporate Product Safety Policy states: "Union Carbide will: "Regularly review product safety Information and in the light of new experience of tfnlon Carbide and others#- - - and# if appropriate, - - -- , modify the product safety communications.M & 18 5 6 I It further states: C "Comply with all applicable governmental laws and regulations relating to product safety." UCC 023948 suwsct caSuSSe I CORPORATE PRODUCT SAFETY MANUALI E ^ # /? f l i l L<u - / j I~ MOTION Poli cies/Communications CHROMIC HEALTH HAZARD LABELING CARCINOGENS PATS 11/30/81 Amiss TO UNITEDSTATSS RAOC 2 of 3 C INTERNATIONAL POLICY 1. The component Product Safety Director in conjunction with his component Medical Director and Industrial Hygienist, shall be responsible for submitting candidate chemical substances and mixtures to the Medical Departments Toxicology Assessments and Advisory Committee (TAAC)for review of their carcinogenic potential. 2. Such candidate lists shall also be forwarded to the Product Safety Communications Committee to ensure that all components are aware of the pending TAAC review. 3. Recommendations as to the classification of a particular chemical substance or mixture developed by the TAAC shall be communi cated to the HS&EA Health Effects Review Branch (HERB) for their consideration and action. 4. HERB shall develop action plans to implement decisions ( regarding a particular chemical substance or mixture including ^ classification for precautionary labeling and/or exemption from label ing for a particular mixture if a carcinogenic substance is present as an ingredient or impurity at such low concentrations that it does not present a significant chronic hazard. 5. The action plans by the Health Effects Review Board shall be communicated to all interested Union Carbide Corporation groups including the affected component Product Safety Managers and the Product Safety Communications Committee. 6. All government mandated carcinogen labeling requirements will be compiled with and in the event that the Union Carbide Corporation labeling requirements is different, the affected operat ing component may meet either requirement at its option. 7. Products which have been evaluated by TAAC and HERB and found to have a carcinogenic potential shall be placed in one of the following categories and the precautionary labeling shall contain the appropriate hazard warning statements UCC 023949 *18562 CORPORATE PRODUCT SAFETY MANUAL i SUBJECT CHRONIC HEALTH HAZARDS LABELING CARCINOGENS / SECTION Policies/Communications SATE PACE 11/30/81 amiBSTo S UNITEDSTATES 3 of 3 2 INTERNATIONAL. CATEGORY Known Human Carcinogen Suspect Human Carcinogen Animal Carcinogen WARMING STATEMENTS Human Cancer Agent Suspect Cancer Agent Has caused cancer in laboratory animals 8. The elements of the precautionary label of carcinogens. , shall be placed as followst . : (a) Signal Word? Label will have Signal Word appropriate*to most significant hazard. If cancer is the major risk WARMING is the appropriate Signal Word. (b) Placement: Directly following Hazard Statement for the most immediate and serious risks (such as flammability, poison ing and serious b u m s ) ; or directly under product name if no more serious product hazards are involved. (c) Marne: Known or Suspect Human Carcinogens or Animal Carcinogens must be designated by their common or usual chemical name which may be in addition to trade or code names. (d) Precautionary Measures: Appropriate list of precautions depending on whether risk is from skin absorption, inhalation and/or ingestion. SCOPE This policy applies to all parts of DCC except to products and services of the Nuclear Division regulated by the Department of Defense, Department of Energy or Nuclear Regulatory Committee and to all affiliates worldwide in which UCC has a greater than fifty percent equity interest and is recommended for application in affiliates of fifty percent or less equity interest. UCC 023950 &18563