Document 6w37QbdZa7gRam7dLVDr0BvyE
CPR 25 'S3 13:34 -8046228964
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PLAINTIFF'S EXHIBIT
P.ml u, o'
Manual L-1
rA RT I
MANUAL L-l--A GUIDE FOR THE PREPARATION OF WARNING LABELS FOR HAZARDOUS CHEMICALS
Adopted 10-40 * Revised April 1940
The development of new chemical products and the1 introduction of chemical processes into mr-wklenirtg fields has accentuated the need for furnishing: appropriate information in those cases where special precautions are necessary* Many chemicals present no hazard# in normal handling
and storage and for these products no precautionary 'labels are necessary.
The education of employees regarding chemical hazards is, and must remain, the direct respon sibility of their employers. However, such hazards are not confined to employees alone, and Infor
mation concerning them should, so far as practicable, reach every person using, transporting, or storing ehemiciUs. The most practical means for the seller to disseminate this information appears
to be by labels affixed to containers of hazardous chemicals; bearing appropriate precautionary statements and Instructions stated as simply and briefly as rirduinstances permit.
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In the interest of uniformity and more adequate labeling of chemical products, the Manufac
turing Chemists' Association has prepared this Manual for the benefit and guidance of its members,
A series of definitions is included in Schedule 1 in order that the terms used may be clearly under-
steod. In addition to the general recommendations contained herein, the MCA has prepared sug
gested labels for specific products. .These have been printed as Manual L-2, which will be supple
mented fprom time to time as additional recommended litbe*ls are developed.
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A precautionary label does not take the place of safety equipment such as -suitable goggles,
airline respirators, gas masks, clothing, shoes, etc. 1 * *,
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Individual statutes, regulations* or ordinances may iwjnlre that particular information be
included on a label or that a specific label be affixed`to a container. In each ease, the requirements
of these laws should also be studied. Th tvarniiig labels siiffysHed in this Manual should bo med
ht addition, to, or in combination- with, a.ny label reqitine# by lam*
* federal statutes include;
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Interstate Commerce Coinmission SoealftHonB for Transportation of Explosives and Other B- 'pus Aviidriss _ Supt. m Documents. Cove, Printing Office, 'Washington, i>- C,
Federal Caustic Poison Aei and regulations; Food and Drug Administration, FcsUsvui Washington, D, C.
-... Agency,
Federal Insecticide Act of iSiO and regulations! Agricultural 2Kni*etiif Administration. U. S. Department
of AgricuUuva, Washington, D. C.
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Federal Food, Drug and Cosmetic Act and ragulntionas Food' nd Drug Administration, Federal Security
Agency, Washington, B- C.
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Belated statutes of the 48 States and the District of Columbia include Caustic Acid. Pharmacy, Poison, and
Insecticide Acta.
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GENERAL PRINCIPLES
In the preparation of any precautionary label the following principles should first be con-
sidfcireu:
.
I) Each chemical product (including mixtures) presents a distinct problem and must be treated individually, in the light of it's own characteristics.
3) Extreme care should be exercised in the choice of terminology. Statements should ba
bri*ef and simple.
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3) On labels for different products, uniformity in language to indicate the same hazards is most desirable in order to gain greater understanding through standardization.
4) Precautionary statements must'be accurate, selectively chosen, and expressed in
dearly defined terms. Te be effective they should be used only when mid to the extent
neuttsaury. Labeling of a relatively harmless product so as to indicate that it is hazard
ous, as well as the failure to give adequate notice of a hazard, will develop a disregard
far labels and defeat their purpose. _
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For example, if the word "POISON" Is to retain its usefulness on a label, it should be applied exclusively to those products (I) which are poisons according to a definite toxicity standard*, ur (2) with which it is associated through common usage, or (Si for which its use is prescribed by law. In all other cases the relative degree of the hazard can be better indicated by the use of signal words such as: "DANCES'* to cover extremely serious hazards; "WARNING" to cover less serious hazards; and "CAUTION" to cover minor hazards, together with a descriptive statement of the hazurd, ,
5) Chemical names should be those recommended by the American Chemical Society.
8) The use of a nun-descriptive code designation or trade name as the only identification of a hazardous chemical should be avoided. If for any reason, it is undesirable to show the chemical name, or if the chemical name ia so complex us to ba meaningless except to the trained chemist, the lube] should state the type of chemical, e.g,, "eoryo-
sive acid," "lead compound.'*
7) The following subject matter should be considered for inclusion on a precautionary label:
1. Chemical mime
2. "Signal word" {DANGER-WARNING..UTION) designating degree of hazard (Column A, Schedule 3)
3. Affirmative statement of "hazard" (Coiuwn B, Schedule 3)
4. "Precautionary measures" covering actuals to be followed or avoided
(Column C, Schedule 3)
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5. "Instructions in case of accident,*' where advisable (Column D, Schudule 3)
S) Warning label# should be printed in easily legible type, which is in contrast by typog
raphy, layout, or color with any ether printed matter on the label and should be placed
conspicuously on containers. Legibility m&y be preserved with a suitable protective
coating.
'To provide a practical working standard for labeling purposes ``POISON" is.downed In Schedule L cf this Manual
io i:ieidu ,,niy chemicals capable A causing scat,; effects by ingestion nnd inhalation, the principal modes of noisy
into the body. This definition exclude* chemicals capable of causing injuries us a result of skin absorption or of
chronic exposure by inhalation, because the 'variable actions and effects of chemicals with thesP fihaiacteriatscB
preclude a practical moans of measuring tUair hazards.
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Manufacturing ChfttvitfV A^ncUtinn ot fhe Vn\t<d
PREPARATION OF PRECAUTIONARY LABELS
. .Manual
L*1
. The basic considerations in the preparation of a precautionary label for any chemical product (including mixtures) are:
1) Determination at the hazards present in the particular chemical-product.
2> Selection of appropriate statements for each significant hazard inherent in the product.
3) Arrangement of statements in the order of emphasis desired.
The moat frequently ettemmtered hazards have been classified by the MCA into 10 types "hs'
listed in Schedule 2. Set opposite each class are statements illustrating characteristic precautions
usually required for that type of hazard,
Many chemical product?, will have more than one type of hazard, in which case appropriate statements for each significant type should he included on the label. Most chemical products con tain impurities. When these are present in harmful quantifies, appropriate warnings and precau
tionary measures .should be included on the labels.
' As each chemical product must be treated individually, there will be many instances in which the illustrative statements will not be applicable cither because they do not accurately express the degree of hazard or'because they fail to cover the particular characteristics. In such cases, suitable statements should be selected from Schedule 3. This Schedule presents a more comprehensive list
of statements arranged in columnar form, and grouped as follows:
.A Signal Word
B Hazards
C Precautionary , Measures
D Instructions in Case of Accident
Column A--The degree of hazard can be expressed only in relative terms, The purpose is two-fold: to indicate to the reader the comparative seriousness of the danger involved
Example: WARNING!
ii Column B--From this column ^should be selected the phrase (or phrases) that most accu rately describe? the principal hazard. This is placed on the same line as the "signal word."
Example: WARNING! FLAMMABLE
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i If other significant hazards are present, they should be tabulated under the principal
hazard.
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Column C--The appropriate statement, of "precautionary measures" should he chosen
I from Column C and should follow on subsequent lines.',
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' Example: WARNING! FLAMMABLE - , `
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Keep away from boat and open fin mo, Keep container closed.
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Use with adequate ventilation.
Avoid prolonged breathing of vapor.
Avoid prolonged or repeated contact with skin.
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Mnnu/jny(!iij! CUtrttiJH' Antuciutiun of the United Stttvt
Column D--When it is advisable to include instructions in case of accident, the appropriate statements may be selected from this column. Instructions in case of accident to indi viduals are valuable but should be limited to recognized first aid procedures based upon simple methods ami eummuiiiy available materials. Instructions for strictly medical treat ment should be omitted except when rpedfically required by law. Because of the serious ami lasting effects that may .result from eye injuries, a recommendation to obtain medical
attention should accompany any specific instruction directed to the treatment of the eyes,
li' the statements from Schedule $ fail to meet the exact needs, they should be modified to
suit.' In' the example shown, toluene, mo phrase from this column appears to be necessary.
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While every compound curries some hazard, if improperly uaed',7Tirirnpructical to cover every possible contingency on a label. Efforts should be directed toward naming' the serious hazards, anil warning against such abuses ami accidents as are likely to be encountered under normal con ditions, There are scarcely any means of-measuring in absolute terms the relative seriousness of hazards!, and the recommendations in Schedule*.3 only contemplate their division into two or three degrees of intensity. It follows that of two compounds one may be less hazardous than the other and yet may carry the same warnings and cautions.
Instructions for handling and storage of containers should be included where conditions Indi cate their need. These instructions should take Into consideration both the characteristics of the chemical product and the limitations of the type or types of container in which it is packed.
Schedule 4 presents suggested labels for samples of experimental products for which full data regarding hazards are not yet known.
Schedule r> illustrates the application of caution statements to three specific products. In the case of toluene, the statements used are similar ro those given In Schedule 2 for a compound or mixture having hazards in classifications f-B and IV. The second example, aqueous hydrofluoric acid, represents u very special cose where the particular hazards require modification of the stand ard statements. The third example is that of a label for a proprietary compound or mixture.
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MMinfaiturinK Clirmiiis' Aanciiitloft of thr UnitftJ Stum
Schedule 1 DEFINITIONS
Manual U-l
t'lamnnbie. Liquid '---An inflammable1 liquid is any liquid which givesnTTFihfiamrnable vapors (ns
determined by flash point from Taffliabue's open-cup tester, as used for test of burning
oils) at or below a temperature of SO" F.
.
Extrcmlu Fhmypabfo ^
An exhtyrefmlaeslhy pfloaimntmfarobmle lTiqausrildiabisuea'a lioqpueind-cwuphictehstgeirv,eass oufsfefdlafmor-
test of burning oils) at or below n temperature of 20* F.
Confmrr '*--(Physiological)--A corrosive is an agent which in contact with living tissue will cause more or less severe destruction of tissue by chemical action.
In-itant1--(Physiological)--An irritant is an agent which in contact with living tissue will induce
either immediately or after prolonged or repented contact a more or less severe local tissue reaction not leading directly to destruction of .tissue:
Scii.tih'zrv ---(Physiological)--A sensitizer is a material which as ordinarily handled does not necessarily cause any discernible reaction in living tissue but which after initial or repeatod contact with the tissue of some individuals may, at a later date, produce a prompt
inflammatory reaction on contact, even in minute amounts, with the tissue of the same
individuals.
DvutitSolid partides generated by handling, crushing, grinding, rapid impact, detonation and
decrepitation of organic or inorganic materials such ns rock, ore, metal, coal, wood,
grain, etc. Dusts do not tend to flocculate except under electrostatic forces; they do not
. diffuse in air but settle under the influence of gravity.
`
Ftnarx "Solid particles generated by condensation from the gaseous state, generally after volatili sation from molten metals, etc., and often accompanied by a chemical reaction such as oxidation. Fumes flocculate and sometimes coalesce.
Mtet-x 8--Suspended liquid droplets generated by condensation from the gaseous to the liquid state or by breaking up a liquid into a dispersed state, such as by splashing, foaming, and atomizing.
Gus(t$ --Normally formless fluids which occupy the space of enclosure and which can be changed
to the liquid or solid state only by the combined effect of increased pressure and decreased
temperature. Gases diffuse,
.
YnimmThe gaseous form of substances which are normally in the solid or liquid state ami
which can be changed to these states either by increasing the pressure or decreasing the
the temperature alone. Vapors diffuse, . '
Patton ---Poison means a substance, which, when' taken by mouth in amounts of 60 grains (4
grams) or lass, or when inhaled In concentrations of less than 200 parts per million by
volume in the air, rapidly (within f or 10 minutes) jeopardizes life by other than mechani
cal or physical action,
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Mote: This definition of -`Poison" is 'eased an practical eohidderations only,
a* nn sift in dw.mir.i'nR, generally, when the word "Pniron*' should bo
included on n wanning laS-e}. Sro (tenoral Principles 4.
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Niyturr---A physical commingling of two or more substances which may or may not bear ft fixed proportion to one another and which have not reacted chemically with one another.
* ICV definition. While the term "mflai'iiinftMo" <n this Manual.
d hy the ?<"!(!, the preferred form "flnmniahle" is used in
Chapter It "Enirinefirte* Control ^
J" ^ifl5,lin f thc WopWnB v,nn,ent" fAl,Cn
p. Urnndi, D.Se.) oasc i98. Manual of fwUisti.al H.jpcno. uSfc US.
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` Schedule 2
CLASSIFICATION OF HAZARDS
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Cla&s
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Tjpit'al Label
I. Flammable Liquids und Oxidizing Agents
which Support Combustion. (Flash points
' for liquids are determined by Tagliabus'a
Opey-Cup Method),
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A. Flush point SO" F, or below,
B, Flush point above 2U" to dOu F. in clusive.
DANGER! EXTREMELY FLAMMABLE Keep away from host and open llama. ` Keep container closed.
WARNINGI FLAMMABLE. Keep away from heat and open flume.Keep container closed.
H. Flammable Solids and Oxidizing Agents as Classified by the ICC.
CAUTION J EXPOSURE MAY CAUSE FIRE
OR CREATE FIRE HAZARD
Keep away from heat und open Hume,
Keep container dosed,
In case of contact, immediately Hush with plenty of water; remove and wash clothing
before re-use.
III. Vapors Immediately Toxic or Extremely
Irritating Sven oh Exposure for a'Short
Time or to Low Concentrations. ,
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DANGER! VAPOR EXTREMELY
HAZARDOUS
Do not breathe vapor.
Do not get on skin.
Do not get in eyes.
Keep container dosed and away from heat.
Keep away from feed or food products.
Have air line respirator or gas mask ap
proved by U. S. Bureau of Mines specifi
cally for (name of chemical) available for
emergency.
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iy. Vapors Hazardous from Prolonged or
Repeated Exposures, or Exposure to
Higher Concentrations.
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WARNING! VAPOR HARMFUL
Use only with adequate ventilation.
Avoid prolonged or repeated breathing of
vapor.
Keep container dosed and away from heat.
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V. Gases and Vapors Physiologically Inert.
CAUTION! VAPOR REDUCES OXYGEN . AVAILABLE FOR BREATH
, , ING Use- with adequate ventilation. Keep container dosed.
VI. Harmful Dusts.
CAUTION! HARMFUL DUST Avoid repeated breathing or skin contact. Wash thoroughly before eating or smoking. Keep away from feed or food products.
VII. Skin Irritants--Corrosive,
DANGER!CAUSES SEVERE BURNS
Do not-get in eyes.
Do not get on skin.
Do not get on clothing.
In case of contact, immediately flush skin or eyes with plenty of water; for eyes, get medical attention. Remove and wash cloth ing before re-uso.
VIII. Materials Causing Skin Irritations after Repeated or Continued Contact.
CAUTION! MAY CAUSE SKIN IRRITA TION
Avoid prolonged or repeated contact.
IX. Materials Toxic through Vapor inhala tions or Skin Absorption,
WARNING! ABSORBED THROUGH SKIN
VAPOR HAZARDOUS
Avoid contact with akin or clothing.
Avoid breathing vapor.
.
In case of exposure, r< iove to fi-jjsh air,
Immediately wash with soap.and plenty of
water. Remove and wash clothing before
re-use.
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X, Toxic if Taken Internally. Applies to ma terials covered by statutory definition of poison "liable to be destructive of human adults in doses of (50 grains or less (4 gms.)" or to any materia! toxic jn amounts likely to bo taken infernally through easily anticipated errors.
POISON If ot rwcreii i>,v rtftrulaHfln <r definition (two t!en*
end I'riitpiph'* () h lyjilottl ialx-1 mie;t)t road: DANGER! MAY BIO FATAL IF
SWALLOWER Do not take internally,
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Ouwissh* AjMivUu'ofi jrf the Uniffd State*
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Moheduli! it UHOOMMUN 1)151) hAlllCL UAUTIONH
aA. a
c.
Signal Witnisi
JIimardH
,. i'recuutio/iai'y iUtubim1* .
* ,
Flammability
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a. Extremely Flummuldedriash
point 201' F. oi' bufew.) b. Flnmnitthle (Hush point
ubuvu lib" to SO' F. inclu sive). e. Exposure May Fuusc Five of ('ivitU File Hui-nib.
ti. Keep away from heat (upiifks) and spun ilamu.
h. Keep souluinc-r closed (ami awy from ham.;.
Volatility
..Jiwtructioiis in fuse tf Accident
a. Highly Volatile. b. Volatile (riyivciit Of
f.iijuid;.
.
a. Keep iiul of 'sun ami away from hunt.
b. Heap container closed (ami . uwa.V fromJmtL___________
Miufation
u,, lUKt'.HitJ :}. WAitNlNGi . CAUTION!
a. Vapor Extremely HiiBaftloiu.
b. May tie Fatal if inhaled. c. Vapor Harmful. d. Vapor itfiiuuca 0 :c y 1{ u
Available for Breath inj{, 0. Huimfni Dust. 1. Causes Irritation to Eyes,
Norn ami Throat.
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, Do not breathe vapor (or) Avoid breathing vapor,
li. Avoid prolonged ur rcpentod branthiiw of vapor,
c. Use (only; witii udunuate ventilation.
tl. Avoid prolimr'i'd bfontiiinpf of dust.
Contact
u. tn case of exposure remove
to fresh air.
b. Have air-lino respirator or
gas mask approved hy V.
S. liurmui of Mines sporiti-
caliy for ('mime of chemi
cal) available for timer.
Iteimy.
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u, C<msdvu Liquid. b. Cause* {.Severe) Burns. c. Duuueriiuu Uocuuse {Rap
idly; Absorbed Through
<i. (.'uukph -Skin Jn-ituiiohi o. May Guise Skin imtatius.-,
S
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a, Do nut get H) in ayes. (U) on skin, ill) on clothing,
h. Avoid contact with <1) ayes, (ID skin, <31 clothing.
C, Wiish tborouiiidy before eating or smoking. e*
Ingestion
a. In case of contact!
(1) lmmediutciy UunlJ (skin
or oyesi with plenty of
wuter {for at loitat IS min
utes). {For eyes, gut med
ical tittunticmj.
(H) Immediately wash with
soap and plenty of water.
<H) Hiuuovc mid v/iisli
cimliintf befart* re-use.
.
a. t'rdMm (skull t& cross- ,
femes).
h. Mnv ho FuUl If Swallowed
.
u, Du nut take internally. General
a. Strung Oxidant.
,,,
, IVdsmcv with CoMibUKti>Ic
Alumial May Cause Finj,
. Keep away from food or fom! products,
li. Keep dry. c, store iu cool niece. d, Keep a'.vuy from eombus-
lihle iiUilork'.lpi.
a. Get medical attention, b. In vase of sniibiKV, !ivu.h
with plenty of water. v. In case of splliape. absorb
with sand, aahes or earth.
Th.j sisu ui' any wumi!^ other .sUiU-menc listed above is mu necessarily limited !i> ttu> Imzurii under which it is xroupvn. Thu sroupihf; meru-iy indicates the ty'iJU of hazard tv which {fivua ainimnvuts mu-it fi-vqiicmly apply.
The .-miml fetters me not intruded t indicate u comduumi butwoen nitnilurly feUeied Btsiuiinenia in adjacent columns btit ui't! iof iiivuviiicacoit only.
The jwi'cjitlwtiuu' wvrii> iniiicuic apU'msi etui-omenta.
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Miifiufarruriruc Chtmiw' .Wftiiatinn t'f th* I'nmO StittM
Schedule 4
Mtuutnl
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The labeling of experimental samples of new product presents unusual problems. Ail of the
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recommended:
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3, Samples of a product already on.the market should carry the same warning label as a commercial shipment.
_ 2. The following labs! is suggested for samples of any material that has never been in commer cial production unless U) the materia! is known to bo wholly innocuous, or (2) the dangers are limited to known hazards and appropriate cautions are submitted.
)
CAPTION? The chemical, physical and toxicological properties of this product have not been fully investigated and jis handling or use may ns hazardous Kxercise due care.
2. The Identity of the sample, indicated in parentheses above, should be as clear m possible, Wherever feasible.'it should be the name of the compound or mixture, and in any case it should be
5, The above label may be used in the case of old products being considered for now uses.
Schedule 5
Product Combining Hazards f
Class f-b and IV (Schedule 2) Chemicals.
TOLUENE
WARNING FCAMMAlHXb
Keep away from heat and open flame.
Use with adequate ventilation.
Avoid prolonged breathing of vapor.
Avoid prolo.
v repeated contact with skip.
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Manufictumts ChtmiKi* Aitctiuisn ill ilu Unil Sum
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HVDllOFLUOHI ACID, AQUEOUS
Pjv Requiring,
Cautious
t
and First Aid ' '
Do mu biValho vapor.
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Do not get in ey.e, on skin, on clothing'.
in ciiwsi of contact or suspicion of contact;
Immediately Hush-skin with plenty of water until whiteness dia-
uppears, paying particular attention to skin under nmla, Soak
idfodotl areas with crushed Ice in 70', a ethyl alcohol until physician
wnflrt fiitattfj* s\ tvnf An
^fr Kwtuf 1ft ri\l 111 J> Aj
Jn all cases get medical attention. Remove and wash clothing
before re-use. Avoid use of greasy ointments.
Proprietary Prod act (e.g,, 000.tauiing fluorine units;
(PHUPIUETARY NAME)
' Contains Fluorine Compounds. WARNING 1 POISONOUS IF TAKEN
INTERNALLY Avoid breathing du3t. Flush spillage is sewer with water.