Document BRLvG50OLj8X9Z9777X1VLQv4

*? Hukill Chemical Corporation TOO nic Iioo Bcoroso. Ohio <-11*6 July 8, 1971 it* >* Mr. Frank S. Dllton, Director of Purchase* FOSCCO, Inc. P.0. Hox 8723 Cleveland, Ohio 44133 Dear Hr. ISilcon: In the interest of supplying the information requested in your letter of June 23th, 1971 vc have ehcched with the United States Depnx'tscnt of' Labor and have been advised that the labcllinr r<-quircr.cncr. as required by The V.'illiams-Steip.er Occcyntianal Ssloty and health Act of 1970 have not been published as vert. This Is to advise you chat as soon as this information is available vc will change our labels to eonply vith this lav and advise you accordingly. Cordially, LUVolf/pa Fos-ea-eeaeae 1 at* 3 0958 m It'M E. !. ou Pont oc Nn.-.ouns & Company Wilmington. Dclaware u>G9fl hcmiimts ncr*MTMCwr July 9, 1971 Mr: Prank S. Btlton Director of Purchases Koscco, Incomornted1\ 0. 13ox 8726 Cleveland, Ohio 44135 Dear Mr. Bilton: This is in answer to your letter of Juno 25 requesting our confirmation that all materials sold to you will, by August 27, 1971, be labeled so as to conform with the YJilliar.sSteiger Occupational Safety and Health Act of 1570. You stated that said Act requires that all chenicals and materials be labeled to indicate the precautions and safety equipment re quired, symptoms of possible illness, and composition. I presume you refer to Section 6 of the Act, codified as 29 U.S.C. 655, which empowers the Secretary of Labor to pro mulgate occupational safety and health standards. Subsection (b) (7) of Section 6 provides that: "Any standard promulgated under this subsection shall prescribe the use of labels or othsr appro priate* forms of warning as are r.ecessar;* to ensure that employees are apprised of all hazards to which they are exposed, relevant symptoms and appropriate emergency treatment, and proper conditions and pre cautions of safe use or exposure." r As the subsection makes clear, special labeling is not required for a product unless the Secretary of Labor promulgates i a standard imposing such labeling. To date, no standard has been issued which requires such labeling for the several pigments which *;c sell to you. We are pleased to include a list of the general practices and precautions that v.c follou-in our manufacturing units when handling the pigment colors you purchase. We trust that this will answer your questions on handling pigments. Cordially yours, pm: 1 fs \y ?. D'er.n Graham, Jrv Technical Manager-Figment Color m -.it 11 Tiiiiinr, ro nr.Tfrtn . .viuC . . . uittf'u(in enr.^tisiiir POS-aa-oaeaooiebA 0959 \ Company Pom Muic". M-ci'-oi". <JC10 TelpAw-c M3 Teletype 310-731 -ZJiS Ol'ii'O'i o! Aclietse indjtir-ci. Iac. is July 1971 Foscco Incorporated P.0. Box 8720 Cleveland, Ohio 44135 Attn: Mr. Frank S. Bilton Director of Purchases Gentlemen: The Williams-Steiger Occupational Safety Act of 1970 requires the Secretary of Labor to promulgate standards dealing with toxic materials or harmful physical agents so that no employee will suffer material impairment of health or functional capacity even if such employee has regular exposure to the hazard dealt with by such standard for the period of his working life. The Act further stipulates that any standard so promulgated shall prescribe the use of labels or other appropriate forms of warn ing as are necessary to ensure that employees are appraised of all hazards to which they are exposed, relevant symptoms and appropriate emergency treatment, and proper conditions and pre cautions of safe use or exposure, where appropriate, such standards shall also prescribe suitable protective equipment and control or technological procedures to be used in connection' with such hazards, and shall provide for monitoring or measuring employee exposure at such locations intervals, and in such manne: as be necessary for the protection of employees. At the present time, standards exist for a limited number of chemicals only. At the current moment you purchase from us c.-tc proprietary product with the trade name of Prodag. Konc of the ingredients in Prodag are currently covered under any known standard thus far promulgated by the Secretary of Labor. AIm. i w. (;*#? naif a**4*k FOS-00-000qqq106! 0960 . Cwa* <il* Compo.iy 1'oseco Incorporated Pngs 2. 15 July 1971 The only chemical contained in Prodag which has been subject to study by the American Conference of Govcrnr-.cntal Industrial Hygienists and for which a threshold limit value has been re commended is ammonia, which is used in the -product in small amounts. According to the recommendations of this conference, a threshold limit value for ammonia has been established at 50 parts per million. This represents the conce:itrr.tion in air which is believed nearly all workers may be repeatedly exposed, day after day, without adverse affect. Good .practice is to control exposures below the TLV. At the concentrations of ammonia present in Prodag, we do not believe you will encounter any difficulties with air concentrations of ar.^nonia exceeding the threshold limit values under any normal or sensible working conditions. Consequently, we believe we will be in compliance with the Occupational safety Act with our current label. Very truly yours HAH:bfh H.A. Hoover General Manager Fos-0-aceai0fefe 0961 CAfjut 'SUCIUAIV 1201 I 301.6100 >000 coouocc stncET SOUTH lLAINFICLO. N J. 07060 July no, 1971 Mr. Prank S. Hilton Director of Purchases Poseco, Inc. F. O. Eox C728 Cleveland, Ohio 44135 Dear Mr. Bilton: .. . ... This will acknowledge receipt of your letter to us of July 7, 1971, concerning the: Occupational Safety and Health Act, we have reviewed this with our Washington attorney and he advises as follows. There,,is nn n'-oyir:.O.S.H.A~px<r i t. s, i i--'leincnf j.nn.r'-oui'ati ons TvilieiV'reciuj.::cs' labels such as you*'descriocdV The O.S.H.A. was passed December 29, 1970 and became effective April 20, 1971. It impowers the Secretary of Labor to promul gate safety and health standards for-all industries in the United States. These standards, when promulgated, arg applicable to every employer in the industry, if his output "affects commerce." V.'a are advised this is aimed mainly at, what we call, "hazardous materials. " There are ,no_L at _this_ timespecific._standarcls. _fo", the chemical mlunuVcturersT' "' __ i.:---r.-- In that our products do not come under the general heading of "hazardous materials", we feel this regulation docs not apply to our area of commerce. We arc in touch with these things as they develop and should there be any significant changes, we will certainly advise you of same. Sincerely yours, JCW:jr cc: PP, almer Supplies Company Cleveland, Ohio FQS.Qe-eeeeaQ1067 0962