Document 6nbVrpmr279RbNxJ1p5wrqqm

OFFICE _~O-(TU*>)'P"oL^>\&*7.->..:..- .vx-a* Co^toii -U - ,,TELEPHONE NATIONAL 2458 ris O-J A NATIONAL 3409 uy-i.v?,` Manufacturing Chemists' Association ^ OF THE UNITED STATES (FOUNDED 1378) 608 Woodward Building Washington, D. C. MINUTES OF MEETING LABELS AND PRECAUTIONARY INFORMATION COMMITTEE Room $171 Chemists1 Club, $2 E. Ulst Street, New York,NY. 10 s00 A.M., V/ednesday, May 17, 19Wi L-l The meeting was called to order by Acting Chairman W. N. Watson, at 10:00 A.M. The following members were presents R.W, Lahey D. D. Irish J D. Gunther Lynn Watt L. L. Hedgepeth W. N. Watson A.G.Cranch S* J. Hill T# Aalto Carl Anderson Frank Low- Absent s Richard Hansen I. REFERENCE MATERIAL ON LABELS AND PRECAUTIONARY INFORMATION The Chairman advised members that the following reference material had been submitted to each committee members 1. Proceedings of the M.C.A. Conference on Liability Suits, April 12, 19hh (Confidential)* 2. Set of Agreements with the USHIS and manufacturers, including re production of each label in black and white. 3. Set of MCA-sponsored labels. U. Memorandum on "Labelling of Toxic Materials" by II, J, Horswill, Safety Engineer, Industrial Accident Commission, California, $. Memorandum dated May 16, 19UU, from MCA Technical Committees. 6. Special memorandum presented to each person attending the confer ence on April 12 coverings a. Manufacturer's Duty as Interpreted by the Courts; Recanraendations (Confidential) b. Federal Labelling regulations. e. State Laws covering caustic acid poisons, insecticides and related products. The chairman, suggested that these exhibits be retained for future reference. II. REPORT OF AMERICAN HYGIENE ASSOCIATION An informal report was given of the meeting of the American Hygiene Association at St.Louis during tl week of May 8, at which time a resolution was passed to -: l-2 appoint a committee to select a representative to meet with the Chemical Products Agreements Committee in regard to labelling and legislation therefor. It appears that Dr. Drinker and some of the insurance companies favor no "unknown" labels; i! that is, each label must bear the complete chemical composition of all ingredients. i Federal and State legislation involves: (1) conflicts between the State and Federal Acts as the States do not go along identically with requirements of the Federal Act, as is exemplified in the agricultural insecticide acts; (2) the diffi- ' culty of differing interpretations of scope by various officials -- some requiring a statement of composition, and others limiting or even prohibiting certain uses -- because of a lack of understanding of the product and the problem of'the producer and consumer. III. EFFECTIVE USE OF LABELS AND PRECAUTIONARY INFORMATION Discussion pointed out the importance of producer and consumer education as a continuing program. In regard to the method of presentation, for certain users the printing of M.C.A. manuals on posters has been, effective for plant use. Referi ence was made to the fact that the label in many cases allows insufficient space for directions on use and handling, and must be supplemented by a manual or a special i pamphlet. The advantage of a leaflet with each drum to supplement the label was | pointed out. The necessity of permanent adhesives for attaching labels to drums, |l:j%.(;.Stc., was stressed. The M.C.A. has a list of pastes for drum labels. It was also brought out that technical salesmen have been very helpful in the '.if,education of customers- on essential precautions-,- with -emphasis on the label as a ^service to the customer and in his direct interest. This approach should be oapital- j:;.v Ized, and later it should be advantageous to conduct a general campaign on "Read l^iy^^gthe Label." Sales by jobbers and repackers present one of the major problems of ip A?'^contacting customers with precautionary information and labels. It was agreed that <&T 4':. .special bulletins to M.C.A. members should be sent out from time to time, including specific recommendations from the LAPI Committee, in order to advise the presidents j; and vice-presidents. !' ; IV. CLASSIFICATION PATTERN Dr. Irish Stressed the importance of a pattern of classification for chemical li /^products in order to give a scale of relative hazard, thus permitting a product to | "be grouped in the classification. He mentioned, the psychological emphasis placed p.-jfliSupon accidents occurring from time to time, and that a patchwork attack by products, -without a general classification, lacked perspective and might lead to conflict. If" Probably also the USHIS would welcome such a classification and would be glad to give 'if-, f;-us the benefit of their suggestions. Dr. Cranch stated that he had given considerable study to the relative hazard of products according to physiological properties, toxicity, method of handling and use, and type of exposure. It was also pointed out that terminology had not been standardized and that hazards varied; i.e., in terms of skin, stomach, eye, inhal ation, etc. The word "poison" originally serving a useful purpose for the few . products generally sold a generation ago, is not a satisfactory word to cover special '-precautions. Such words as "caution" or "warning" were believed to be more effect ive. On motion duly made and seconded, it was unanimously voted that the committee go on record as supporting a classification of hazardous products; that the follow- _ ing initial draft be carefully reviewed by members at the earliest possible date and their comments sent directly to W.N.A'atson, for preparation of a redraft to be returned to the members for review before action at the next meeting of the commit tees Schedule I. Plan for Classification of Chemical Products ior precautionary Labelling. 1, Flammable vapors or liquids - (Covered by I.C.C.) ?. Simple asphyxiants: (Acting only by exclusion of oxygen# e.g., carbon dioxide, nitrogen, acetylene, methane, propane, etc.) Label: CAUTION: VAPORS ASPHYXIANT AVOID CONCENTRATED VAPORS, OR USE AIR SUPPLY OR OXYGEN MASK Chemical asphyxiants: (Acting through physiological changes more direct than simple exclusion of oxygen from air breathed, e.g., carbon monoxide, or cyanogen compounds) Label: CAUTION: CHEMICAL ASPHYXIANT AVOID ANY BREATHING OF VAPORS. USE AIR SUPPLY OR SPECIAL GAS MASK k. Irritant gases: (Materials in this classification would vary in need for cautionary labels so that subdivisions are indicated). A. Immediately irritating, even in very low concentration. (Largelyirrespirable. Damage more to upper respiratory tract or through systemic action, e.g., ammonia, formaldehyde, various anhydrides, sulphur dioxide, br&nine, chlorine,etc. Label: CAUTION: DANGEROUS VAPORS AVOID EXPOSURE TO VAPORS OR CONTACT 'illTH EYES OR SKIN. USE CANISTER GAS MASK AND GOGGLES . g.~.Dangerous- after-effects- -(Concentrations not-causing serious immediate effects may show serious lung or systemic effects later, e.g., hydrochloric acid, hydro fluoric acid, nitrogen dioxide, phosgene, acrolein, and some halogenated organic compounds, etc. Label: CAUTION: DANGEROUS VAPORS AVOID EXPOSURE TO VAPORS. USE CANISTER GAS MASK. IF VAPORS INHALED GET MEDICAL CARE AT ONCE. 5. Anesthetic and Toxic Vapors: A. Acting rapidly: (Usually no serious after-effects. Causing second stage anes thesia"after few minutes inhaling of saturated vapors. e.g, some acetates as methyl, ethers as ethyl and isopropyl, ethylene oxide, seme hydrocarbons of olefin series and perhaps some of the ketones). Label: CAUTION: VAPORS ANESTHETIC AVOID INHALING CONCENTRATED VAPORS. USE CANISTER GAS MASK. B. Producing serious tissue changes. (Dangerous in repeated exposure to low concentrations as great or greater than acute exposures, e.g., chlorinated hydro carbon solvents, aromatic hydrocarbons, aliphatic alcohols, nitrogen compounds, and some other groups include a considerable number of materials in this class). Label: CAUTION: VAPORS TOXIC PROVIDE GOOD VENTILATION. AVOID ANY PROLONGED OR RELATED 3REATHING OF VAPORS. 6* Corrosive or irritant to skins and mucous membranes; (This would apply usually to fluids but might to some vapors and even solids, e.g., most of the stronger acids, and alkalis, some amines, anhydrides, and other organic compounds.) Label: CAUTION: CONTACT >7ITH SKIN OR BODY TISSUES MAY CAUSE SERIOUS HARM. DO NOT SPLASH OR ALLOT/ CONCENTRATED MATERIAL TO COME IN CONTACT 'AITH SKIN OR EYES. L-U 7 Toxic through skin absorption: (Some materials having little or no direct irritant action on the skin may be rapidly absorbed through the skin with systemic effects, e.g,, ethylene chlorhydrin, aniline, crotonaldehyde. To some extent such substances as benzol, methanol and the chlorinated hydrocarbons). Label: CAUTION: MAY BS TOXIC BY SKIM ABSORPTION AVOID CONTACT WITH SKIN, OR SPLASHING ON CLOTHING. REMOVE WET CLOTHING AT ONCE. WASH SKIN PROMPTLY WITH SOAP AND WATER IF HAS BEEN WET. Schedule II. Plant for Classification of Chemical Products for Precautionary Labelling Special precautionary Label Suggested Label now Label required Vapor Contact Oral Special Indi- Material : and authority:None:Acute:Chronic:AcuterChronic:Acute:Chronic: Eyes,etcseated Acetone None x Benzol U5FHS agree- ment State laws (Mass.); Ethanol F&DAx _________________ Ethylene IB HIS agree- chlorhydrin ment (Chlor. x hydrocarbon solvent label Methanol USPHS agree ment State laws Oxalic Federal Caustic acid Act Sodium Federal Caustic hydroxide Act X _____ X x X x XX XX XX Letter of Dr. A. G. Cranch transmitting Schedules I and II "I am enclosing herewith a revision of the plan for classification which was re ferred to at our meeting in New York on the 17th. This plan was originally drawn up with a view to deciding on precautionary labels for a rather wide group of synthetic organic chemicals. It furnishes a basis for a similar plan applicable to all chemical substances. There can, of course, be no hard and fast dividing line definitely placing substances in one or another of tne classifications, a large number of chemicals have properties which would place them in two or more classifications with reference to precautionary labels. In such cases possibly two or more labels might be used or a single label combining the precautions required for the particular product in question. "This plan for classification does not incorporate labels currently required by Btatute or otherwise for certain materials such as the labelling called for by the I.C.C. regulations, by the Federal Caustic Lav/, the agreements with the Surgeon Gen eral s office, the public Health Service or various provisions under federal law, such as the Food, Drug and Cosmetic Act, or various state lav/s. This classification deals primarily with the cautionary labels often not called for by any present regulation out indicated in the interests of the safety of the consumer or the interests of the manufacturer. -!fWfUpfflftLM nt- Ir-5 "The general classifications in Schedule I may require amplification to include certain types of chemicals which might require a separate heading or may re quire additional subdivisions -under some of the given classifications. The suggested wording of caution labels may well be subject to further consideration and revision but as given is a suggestion as to the type of label which might be required. An effort has been made to avoid the term "Poison" because this as commonly used refers to single dose oral toxicity. If used in some states it might call for more or less elaborate details as to antidotes or first aid treatment. It has been suggested rather that the wording "Caution" be used followed by the most obvious reason for caution. Following this is the direction to avoid such forms of exposure as would be dangerous with the material in question. You may refer to breathing of fumes, vapors or dusts or to contact with the skin, etc. "Schedule II indicates the way a producer can list his materials in order to determine wnat labeling any one of them might require. A few examples are inserted in this schedule. After the column listing the name of the material is a column referring to labeling now required for which a code might easily be substituted for the entries given in the space. The next column indicates that in the opinion of the producer considering the nature of the distribution of, the material no special precautionary label is required. The following columns list -toe types of exposure in which a hazard mi^it be present calling for cautionary label. By use of this schedule a determination could be made as to what precautionary label is indicated for the specific material. If standard precautionary labels are adopted the number or other designation for standard labels indicated could be put in the last column. "This plan of classification is presented as a basis for discussion of this subject inasmuch as it seems out of it might be evolved a practical method of class ification and. use of precautionary labels which would lead to very much more protec tion for both customer and producer than the haphazard way in which such labels are now often selected and the absence of such labels from some materials where it certainly would appear in the interests of all that some precautionary label should be used. "F.S. Of course most of the chemical materials are 'Not for Internal Use' but the question is whether to leave some such label for those of important toxicity, rather than to put it on all chemical materials." It was agreed by the committee that after this classification is completed, it should be sent to each member with the request that they classify their products within the classification and return to the Washington office for summarization and submittal to the LAPI committee for final recommendation. It- was also agreed that preparation of the classification of hazardous products should be expedited in order to avoid a delay in the necessary consideration of labels for individual products. The subject of appointing product subcommittees will be handled after the classification is complete, except for those items which call for immediate action. V. DDT H Mr. Gunther mentioned the problem of labelling DDT and it was unanimously i recommended that a meeting of the producers be called promptly to consider a prei cautionary label for DDT. Laters Meeting called for Wednesday, May 2U, 10 A.M., duPont Hotel, Wilmington, Delaware VI. SCOPE OF COMMITTEE It was agreed that tne scope of the committee should be primarily confined to industrial chemicals but including those chemicals used in the manufacture of drugs* It was felt that the problem of drug labelling under the Food, Drugs and Costmetics Acts was not within the scope of this committee. VII. MEMORANDUM FROM MCA TECHNICAL COMMITTEES MCA Technical Committees submitted a memorandum dated May 16 presenting the following items: 1. The question of a Class B poisonous liquid label to supplement the Class B label under the I.C.C. regulations. It was agreed to postpone this until the classification of products has been completed. 2. Warning label for cylinders containing anhydrous hydrofluoric acid, the MCA HF Committee having submitted a label for cylinders of HP. . This label was approved with one change and with the understanding that the necessity for listing the maximum temperature of 165 degrees F. will be removed as soon as a safety device has been perfected. The original wording, indicating the revision proposed by the LAPI Committee follows: ' " ANHYDROUS" HYDROFLUORIC ACID CAUTION Keep Out of Sun and Away from Direct Heat Never Allow Temperature to Reach 165 F. Avoid Exposure to Liquid or Fumes In-Case of-Centaet-Ceneult-a-Phyeieian- (revision) In case of Contact Obtain Medical Treatment Immediately / Mr. Hedgepeth is to notify the AHF committee members. 3. Empty Drum Hazard. Accidents arise from children inserting lighted matches into discarded empty drums previously used for inflammables, Mr. Lahey reported that the Drums Committee had approved a revision of cer tain M.C.A. manuals pertaining to metal drums to include warnings on the disposition of .such drums by advocating scraping of the drum to release any vapor or inflammable gas. it was unanimously agreed that the matter should be .handled by the Drums Canmittee. VIII. PRECAUTIONARY LABELS The Chairman submitted and read labels drafted by the Victor Chemical Works since the meeting of April 12. These precautionary labels cover phosphorus; thosphoric acids; phosphorus tri and penta chloride, and also oxides, formic and oxalic acids.