Document DM9ZMje4qq6OKMkkrO661qe9d

TO: Tom Huffman ER.OM: DATE: Interoffice Communication SUBJ: T. G. Grumbles February 17, 1988 LABELING OF IN-PLANT PVC AND VCM CONTAINERS: REGULATORY APPLICABILITY iV; k: . . ", VISTA There have been multiple activities and actions regarding OSHA regulatory requirements impacting the labeling of PVC and VCM 'containers". Specifically, questions regarding in-plant container requirements have recently been raised. The following memo is to clarify the requirements for in-plant containers. There are two regulations affecting the labeling of in-plant PVC and VCM con tainers. The OSHA Vinyl Chloride Standard (1910.1017) requires the following: A. Containers of vinyl chloride shall be legibly labeled: Vinyl Chloride Extremely Flammable Gas Under Pressure Cancer Suspect Agent B. Containers of polyvinyl chloride shall be legibly labeled: Polyvinyl Chloride (or Trade Name) Contains Vinyl Chloride Vinyl Chloride is a Cancer Suspect Agent There are also requirements for PVC Waste containers. applicable sections of the regulation is attached. definition does not include pipes. Items A. and applicable to all in-plant containers. A copy of the The container B. above are The OSHA Hazard Communication Standard (1910.1200) requires con tainers of chemicals determined to be hazardous to be labeled with the appropriate chemical identity and appropriate hazard warning. Specific to VCM, if a container contains a substance with greater than 0.1% of a recognized carcinogen or is known to present a health hazard at levels below 0.1% it must be labeled. Vista has determined that VCM is covered by 1910.1200. It is Vista's determination that PVC product is not hazardous under 1910.1200 and any ` additional labeling requirements do not apply to PVC product containers. It should be noted that containers of off-spec, etc. PVC that are known to contain high RVCM must be evaluated for 1910.1200 labeling requirements. vvv 0 00QG031-1 H -**' Tom Huffman February 17, Page Two __ _ 198S^"'' I have also attached several memos regarding the recent labeling activity for "shipped" PVC containers. T. G. Grumbles cek .301 cc: WLM *VV 000000312