Document DK1gxD79jgdnvjEzepD5ae2n

L-871 Manufacturing Chemists Association Minutes of Meeting LABELS AND PRECAUTIONARY INFORMATION COMMITTEE Twin Bridges Marriott January 17 t 18, 1978 Washington, D.C. Chairman Jones convened the meeting at 10:30 a.m. on January 17. The record of attendance is: MEMBERS PRESENT W. H. Jones, Chairman R. H. Dewey, Vice Chairman R. C. Andrews* S. W. Beckstead J. J. Bonin L. W. Burnette A. G. Chasar C. U. Dernehl* P. G. Elsey J. F. Lemen* K. S. Logan* M. B. Lore J. K. Peterson (for J. S. Mackay) D. G. MacKellar R. F. Philpitt* R. E. Rutherford* W. L. Schleyer A. C. Wasser (for A. W. Sheldon) G. R. Sido P. Sonnebom A. T. Talcott R. G- Troup A. G. Wheeler M. Freifeld Eastman Kodak Company IMC Chemical Group, Inc. Diamond shamrock Corporation Kerr-McGee Chemical Corporation Shell Chemical Company GAF Corporation Mobil Chemical Company Union Carbide Corporation Ethyl Corporation Hooker Chemicals & Plastic Corporation Pennwalt Corporation E.I. du Pont de Nemours & Company USS Chemicals Div. of U.S. Steel FMC Corporation Olin Corporation Gulf Oil Corporation Philadelphia Quartz Company M & T Chemicals, Inc. Monsanto Company Fisher Scientific Company The Dow Chemical Company J. T. Baker Chemical Company IC1 Americas, Inc. MCA *(Attended January 17 Only) CMA 039756 L-872 MEMBERS ABSENT D. V. Anderson E. M. Dixon j,. W. Hammond R. Jelus C. J. O'Connor C. B. Shaffer J. V. Urenovitch T. R. Madden GUESTS T. R. Aalto D. Billings J. B1umberg J. M. Capriccioso R. M. Egan C. M. Firestone E. M. Flint R. Gold D. G. Hall W. G. Kahler R. Lages E. L. Lewis R. L. Malason C. A. Malone B. J. McNamee P. J. McNulty O. Overman R. Raymond P. M. Reed J. B. Redd J. J. Trexel F. Yanno ** Amoco Chemicals Corporation Celanese Corporation Exxon Chemical Company MC/B Manufacturing Chemists Stauffer Chemical Company American Cvanamid Company Air Products and Chemicals, Inc. Reichhold Chemicals, Inc. Tenneco Chemicals MC/B Manufacturing Chemists Philadelphia Quartz Company Dow Chemical Company Ashland Chemical Company WITCO Chemical Corporation CIBA-GEIGY Corporation Stauffer Chemical Company Virginia Chemicals, Inc. Union Carbide Corporation Dart Industries Inc. ARCO/Polymers, Inc. Rohm & Haas Company Mobil Oil Corporation Hooker Chemicals & Plastics Rohm and Haas Company Stauffer Chemical Company Hooker Chemicals & plastics Tenneco Chemicals, Inc. Koppers Company, Inc. E. I. du Pont de Nemours A Company Eastman Kodak Company * * 1.0 Minutes -^Meeting September 27-28, 1977 changes: The captioned minutes were approved with the following (1.0) The meeting was held at Kodak office, Rochester, New York. (3.0) Proposal to Publish Recommended Labels Replace the second paragraph with the following: $ i s CMA 039757 L-873 A task group headed by Mr. Trexel and including Mrs. Redd and Mr. Yanno was formed to review 77 labels for presentation to the full Committee at the next LAPIC meeting in January. (6.0) OSHA Proposal on Labeling (Ref. Ltr. Wrenn to Freifeld, 9/20/77) The following replaces 6.0 in total: An MCA delegation including Dr. Jones, Messrs. Sheldon, Trexel and Freifeld met with OSHA's Grover Wrenn, Director - Health Standards Programs, and Barbara Cohrssen, Project Officer, on September 23rd to discuss the above subject. The delegation reviewed for the Committee some of the details of the meeting. The LAPI Committee was told that a great deal of time at OSHA was spent in discussing the pros and cons of chemical listing and asking for clarification on the other points. The. delegation emphasized that ANSI Standard Z129.1 contains adequate procedures to identify a product or its hazardous component(s) if identifying a mixture. OSHA was unaware of the existence of this section in the ANSI standard. There was no discussion at OSHA on the labeling portion of the proposed standard except that we strongly suggested the use of the definitions in ANSI Z129.1 to identify hazardous chemicals in the workplace and for labeling containers of hazardous chemicals to be shipped. The comments from OSHA were very general in nature. The full Committee agreed that we should keep in close contact with OSHA and act promptly on any further information supplied by them. 2.0 Membership The Committee acted favorably on the nominations of Messrs. R. L. Finocchio, R. Gordon and Mrs. J. B. Redd. 3.0 Proposal to Publish Recommended Labels Mr. Trexel reported for this task group, which includes Mrs. Redd and Mr. Yanno, that thirty-one labels prepared according to ANSI Z129.1 format were recently turned over to the Secretary. When these are dis tributed and added to the seventy-seven sent recently, the Committee will have in hand a complete set of labels drafted in the ANSI format for chemicals in MCA Chemical Safety Data Sheets. It was noted that some SDS's require more than one label. Full Committee action is now required. CMA 039758 L-874 Since the Committee can only consider a relatively few labels at any given meeting, Dr. Young supplied the following list for which he recommends first priority: SD# 2 Benzene 3 Carbon tetrachloride 4 Phenol 8 Ammonia, anhydrous 12 Carbon disulfide 13 Ammonia, aqua 14 Trichloroethylene 15 Acetic anhydride SD# 18 Ethylene dichloride 19 DimethylsuIfate 24 Perchloroethylene 31 Acrylonitrile 37 Styrene monomer 40 Methyl chloride 42 Sodium chlorate 46 Sodium and potassium dichromates and chromates SD# 58 Naphthalene 63 Toluene 74 Sulfur 81 Benzoyl peroxide 85 Acrolein ( 89 Chloroform 90 1,1,1-Trichlor- oethane } j i ? | i 1 I The Committee was commended for its work. Labels in SDS's are changed only when the SDS is revised. 4.0 Technical publications 4.1 Procedures These were reviewed by Dr. Young and it was noted that there is no formal mechanism for adding subjects for SDS's other than via the Safety and Fire Protection Committee. Five SDS's previously named are in the final stages. About two dozen other SDS's are now scheduled for revision and subsequent issue at the rate of about one every two weeks. 4.2 Statement for Addition to each Label Upon review of the general procedure for publication of labels, Dr. Young reported that he has been directed by MCA Counsel to add the following statement to labels which appear in SDS's: "Notice: Space on label limited, Before Using or Handling , read MCA Safety Data Sheet SD-. Precautionary information should be provided to all persons using, handling or otherwise exposed to ____ Committee members felt that such a statement could incur even more liability for member companies than they now have, since CMA 039759 L-875 it implies that the information on the label is not sufficient. Accordingly, Dr. Jones appointed a task group headed by Mr. Rutherford, and including Messrs. Dewey, Lore and Raymond to draft a position reflecting the Committee's views on this matter. Subsequently, the task group submitted the following which was endorsed by the full Committee: "LAPIC views this statement, as presently constituted, as being directed to MCA's potential liability as an Association. LAPIC specifically requests that similar consideration be given to the interests of manufacturers by an appropriate standing or ad hoc committee of this Association, with LAPIC either being that Committee or having an opportunity to participate." 4.3 Proposed MSDS Guidelines Dr. Jones read a letter dated September 22 that he had received from'Dr. Suresch Damly, of Chematron Chemical Products, which proposed that MCA take the leadership in providing guidelines for the preparation of suitable OSHA type Material Safety Data Sheets. In the discussion it was brought out that LAPIC had previously agreed not to recommend changes in MSDS's and Dr. Jones will respond in that vein. 5.0 Task Group on Chronic Hazard Labeling Mr. Sido's task group will review its previous report when relevant OSHA regulations are finalized or substantive information develops. 6.0 OSHA Proposal on Chemical Substances Identification Following a historical review of this matter, Dr. Jones read portions of the implementation action steps given to Eastman Kodak Company in conjunction with a request for a cost analysis of the proposed regulation. These were provided and subsequently cleared for release by OSHA and its contractor, Foster D. Snell Division of Booz, Allen and Hamilton who are attempting to assess the economic impact on chemical manufacturers and U.S. industry at large. These action steps brought home the vast amount of effort and additional paper work that would be required by the OSHA rule. The MCA response of January 16 to OSHA's invitation of December 30 for comments on the draft proposal were read to the Committee. Difficulties perceived with the proposal were outlined in the MCA letter. CMA 039760 L-876 While LAPIC efforts in this area are continuing, it is recognized that a broad program will have to be developed requiring expertise from such areas as industrial relations, legal,public relations, economics and others. This is expected to involve a large segment of MCA member companies. Mr. Max Minnig, a member of the MCA Board of Directors has accepted a leadership role in this pro ject. It is planned to prepare an expanded version of MCA's position in anticipation of a possible meeting with Dr. Eula Bingham and Secretary of Labor, Ray Marshall, k task group headed by Dr. Jones was appointed and will include Messrs. Lore, Trexel and Talcott, with legal assistance as needed. 7.0 Liaison with Legal Advisory Conniittee Mr. McNamee, who is assigned as the Legal Advisory Committee (LAC) liaison with LAPIC, described his function in this capacity as keeping LAC informed of LAPIC activities, providing contact in case particular legal- problems arise and providing actual legal assistance, in certain instances. 8.0 Participation in Annual MCA Health and Safety Symposium The Secretary described preliminary preparations of the co-sponsors of this event, the Occupational Health Committee and the Safety and Fire Protection Committee. This year's symposium is scheduled for September 14 at the Cherry Hill Inn, New Jersey with the theme of "OSHA Update." These Committees have asked for LAPIC participation and plan to set aside a place on the program for the discussion of the proposed labeling standard. Mr. Dewey agreed to coordinate this activity with the other Committees. 9.0 Report on MCA Special Projects The Secretary made available to the Committee status summaries listing reports released on special projects administered by MCA. 10.0 Report on ACGIH Labels Symposium *- (November 21 & 22, 1977, Washington. D.C.) Dr. Jones, a speaker at this symposium, commented on how few industry spokesmen were invited to share the podium and how anti industry some of the other speakers were. cMA 039761 n.o OSHA Cancer Policy The preparation of MCA's written statement, now in its final stages, and the intent of MCA to testify at the hearings, were described by Messrs. Dewey and Sido. Also discussed were MCA's participation in and support of the activities of the American Industrial Health Council. Assistance from AIHC available to com panies in preparing their own responses to OSHA was also described. 12.0 Attempt to Achieve International Acceptance of ANSI Z129.1___________________ Mr. Overman said efforts in this direction are continuing but progress is extremely slow. He brought to the Committee's attention Mr. O'Connors particular interest in the international standardization of regulations for shipping. To pursue this, a task group including Messrs. MacKellar and Talcott, chaired by Mr. O'Connor was appointed. 13.0 Revision of ANSI Z129.1 Mr. Trexel reported for his task group that following conversations with Mr. de Tarnowsky (ANSI) four alternative courses of action were open: 1. Reprint the standard with changes and resubmit for letter ballot to essentially all the organizations that originally participated in its approval. This approach opens the whole standard to review, not just the proposed changes. 2. Resubmit for letter ballot the proposed changes as a supplement to the standard as outlined above. In this procedure, only the proposed changes would be open for review, not the whole standard. 3. Try to get ANSI to agree to a very few changes, corrective or editorial in nature, which would be reviewed only by the ANSI Board. 4. Do nothing for the present. CMA 039762 i""nnH mi i mnwW'HWPWPU........... .. L-878 LAPIC was initially hesitant about going through the consensus procedure since it might put this very useful standard in jeopardy. Mr. de Tarnowsky recommended against the supplemental approach. The third option of attempting only minor changes via the ANSI Board appeared inadequate and the approach of inaction unacceptable. After discussion, the following motion duly seconded was carried without dissent: "A subcommittee should draft proposed amendments to ANSI Z129.1. LAPIC will then be prepared to con sider these suggested revisions when reaffirmation of the standard is called for." A related item brought to the Committee's attention by Dr. Burnette is that the January 3 issue of the Federal Register carries a proposal by the Office of Management and Budget that the government seriously re-evaluate the possible use of consensus standards. 14.0 Next Meeting May 10 and 11 were tentatively set as the dates for the next meeting to be held in the Washington, D.C. area. The meeting was adjourned at noon on January 18. t. Milton Freifeld V Secretary Labels and Precautionary Information Committee MF:jgm Minutes Subject to Approval February 13, 1$78 CMA 039763^