Document Dv63x9o5DpVKjgQQa8rnG35NB

INCORPORATED tnct Mtiieiirr--u k o t t . t iim. w a mt m 2201 NEW YORK AVE. N.W.. WASHINGTON. D. C. viCt rauiSMT--IUM L NUinia CmciH TAtASUIt*--(. I. NATLACI. PaUMiriM OPTICS or THE PRESIDENT itrurrtiiT--a iu c l *. ((.t o n . w u iiu im CSk'MICL--N. a. MACDONALD. tUIKIIH July 18, 1939 TO CLASS A r/LSSaS: CONFIDENTIAL Not for Publication HC6I0N41 VICt^C'r\T| n i. aitt. :i;i lilTItl--t. *. IITTKB. If Till Mktui--unt tncu. t. ien:tT(uc mt ibr --t. r ffRTTi s*R Mt* : d iv is io n a l v ic c .w j s c s :::n t DHOLItAit IYI*0-^. . |U * *.S CtTf Tcxic r.%trials with their ever-present problems require our cor.scienticus c'.r.iiderution of the fundamental principles involved. The National Faint, Varnish arid Lacquer Association is keenly interested in providing Class A renders v.ith .is mucn information on this subject as is practicable at this tire. This in formation being confidential is not intended for general publication, - it is being sent only to the Class A group. Please respect this confidence. The vital factor concerning toxic ..aterials is to intelligently safeguard the public. People cay feel safer in buying materials whose danger they know rath-r than materials unknown to them. We trust the several phases presented herein will be of some benefit to members in applying every precautionary erasure in manufacturing, in selling and in use where toxic materials are likely to or do enter a product. Toxics ana their effects is e subject very broad in scope and can- only briefly bu treated in this message. Children's toys, equipment, furniture, etc. are not the only consideration. Toxics - ..Lay compounds used in * pa int s or lacquers may have harmful effects if carelessly handled. Toxic inatcrials may enter the body through the lungs in the form of dust, mist, vapors, or gases, through the skin, or through the mouth and stomach, acttrial inhaled into the nose and mouth can dissolve in the saliva end be swallowed. Irritant materials may also hove a direct action upon tno skin end the mucous membranes of the. eyas,nose, mouth, and threat. It must be remembered that ell people do not react in the same way when exposed to chemicals. Some may be quite seriously affected by quantities which are harmless to others. Hones, it follows that any one using paint and allied prod ucts should provide adequate ventilation and should observe ordinary sanitary measures such as the washing of the bonds and face before eating and keeping the clothes clean. Dirty work clothes, including sho.s, can be an important source of skin absorption. Some of the ingredients of paints and allied products eight receive special mention because of their specific effects, rather than because they merely displace part of the air or cause slight discomfort if taken into the stomach or system. The following pigments muy be considered as toxic if they find their way into s stomach. The ;mount tolerated by the body varies with the pigment. Antimony. Antimony oxide, Naples yellow, or other antimony cem^f (Antinony is supposed to be considerably less toxic than lead / -2 there is much evidence to iiidicata that it is a toxic material.) ifeny cases of suspected antimony poisoning have been trr.ced to the accompanying lc.-.d. Arsenic Ccr,pounds. Paris green or other compounds containing arsenic. C/'Vi'U;.. C-dtium sulfides rsid selenides ore toxic, but belong to the ls ;cor u;ed pigments. Chr-cu."js. Chromates of nil typos are understood tc be rti-ti.'ciy toxic. CI.rori.id oxides are relatively ::or.-toxic. Lo~".c Coo, mounds, Wnite terd, red lead, litnrxge, lead chromates (chrome yeilevr, chrome green), or other lend pigments. Herourv. Red ur.d yellow oxides of cercury or other products contriving ."c" W ur^r' e - Liquids - Alcohols. The toxicity of methyl alcohol is very veil *crown. As used in lacquers, the other alcohols are relatively harries*. jjenoPL.- Trie is probably tnr. uost dangerous of all commercial solvents, but its use ir. our industry is probably restricted to certain paint end varnish removers. Chlorinated Hydrocarbons. Carbon tctrichloride, trichlor ethylene, tctrr.ciilorethane, uthyle.ie uicliloride, and siailar chlorinated rlipn.-.tic hydrocarbons are said to be very C jijerous toxics. Chlori:u.ted 1-ouu.tic liyuroc .rbor.a ; ra o-i'i to be iucr tcxic ti n tbc cori ch^onuu-.g '.'.ydrccurbon itj o if, but some chlorinated area tics are frequently tne source of rkm troubles. Lcccuer Solvents. There is sciae evidence that the acetates--ethyl, butyl and cayl--ere more cr less toxic. Acetone "j.d thi ether ketones are relatively hrrmless, Mc->t other solvents used to a lessor extent are either harmless in thenselves, are used in such relatively small amounts, or arc so slowly evaporating that they present no hazard. Methyl Alcohol. The use of this product should be avoided. It is aefinitely poisonous. Solvent Naphtha. This is elso relatively nos-toxic as compared tc benzol, and probably less toxic then toluol end xylol. Toluol and Xylol. In equal concentrations, those ore saiu tv be more tcxic than benzol, but because they are loss volatile the actual hazard is usually less. MCA 0 029Q2 t/ -y- Trleresvl Phosphates. The para- and meta-tricresyl phosphates which are used as plasticizers are non-toxic. Ortho-tricresyl phosphate, on the other hand, i a violent poison. Turpentine and "ineral Spirits. These products are relatively non-toxic but are still listed in works on toxicology as causing eczema and irri tation of the skin and nucous nenbrunos. Some people exposed to the fumes are subject to internal disorders when breathing substantial anour.ts of turpentine, itir.sral spirits is less toxic than turpentine. Other plasticizers. Very little is known regarding the toxicity of other c.-nmon so-called chemical plasticizers, but the hazerd frea volatility or dust is, of course, small. The main ccnsidsration, whenever paint products are used, is constant repetition to the paint consumer of the necessity of employing adequate ventilation and maintaining personal hygiene. Printed Matter - Color cards and advertising literature should not in clude any reference by the use of words or sketches to indicate or recemnc-nd a product for children's toys, equipment, furniture, etc., unless' it is absolutely free from toxic materials. Nor.-Foiscnous Colors - It is generally conceded there is relatively little danger of toxic effect from paints on toys and nursery furniture, as both the paint manufacturer and the toy manufacturer are familiar with the types of non-poisenous pigments to use. Nevertheless, the individual company should constantly guard against using any toxic material, especially lead compounds, in products for finishing children's toys, etc. Note: (See page #7 of "Odds and Ends", a special circular of the Scientific Section National Paint, Varnish and Lacquer Association, issued August 1938.) Grown-ups are exposed to some hazards as in the case of children. There fore products for finishing pencils, and other articles that may be placod in the mouth, through habit, require the use of toxic-free materials. Labeling - No definite procedure is recommended for labeling. Labeling is serious since it becomes a public matter with the question as to what would result if this were done. Each manufacturer can sbly cope with the toxic material situation by constantly safeguarding the public through the prod ucts he manufactures and by the repetition of Instructions to salesmen, service men and others who can intelligently instruct the consumer of the advantages of providing adequate ventilation and of maintaining personal hygiene. General - The statement of legal principles listed below was prepared for und distributed by the Manufacturing Chemists' Association for the guidance of its members concerned with labeling problems, and is supported by decisions of the courts. Although the principles set forth are not entirely the result of litigation involving material used by members of our industry they are nevertheless generally applicable to situations arising from the use of harmful substances. NCA 0 0250i L- / Alanuf&eturing Chc-mists' Association Legal Principles 1. A manufacturer who puts out c dtngcrous article or substance without accompanying- it with u warning ea to its dangerous properties is crcir.srily liable for any damage which results from such failure tc warn. 2. A manufacturer or dealer who erroneously libels e dangerous drug with the name of a harmless substance is liable for any injury which cay be caused thereby. 3. Failure tc comply with c statute, e.g., with respect tc labeling poisons, is usually held tc be negligence par se or ct least eviijuce of negligence. A. The name of the product alone nay be sufficient warning, if its na ture is very widely known or its sale is restricted to those who arc . pr*s-.zed tc know its nature, but even in such cases the advisability of a specific warning is indicated. 5. Technical accuracy nay not be sufficient protection for the manufac turer if he uss words which cay give the purchaser the impression that his product is not -.het it actually is. 6. A nonwarrcnty of results is not a warning against possible ocnci*ous ra suits__ 7. The consumer is cntitlca to rely on positive representations or di rections appearing on the label unless he knows them to be incorrect. 8. The manufacturer is ordinarily not liable if his product is put tc a use for which it is not intended and an injury results which cculd net reasonably have been foreseen. It is often difficult, however, to knew whether a particular result should have been foreseen, and the courts are apt to differ on this pcint. 9. The manufacturer or one who holds himself out tc be the manufacturer must know the qualities of his product and he cannot escape liability on the ground that he did not know it to be dangerous. 10. The general rule that a manufacturer is not liable to these not in privity of Contract with him does not apply when his product is immi nently or'inherently aangerous. Ccnclusion - Re grant that this is a very broad subject, and doubt if a ccncif: set of rules can be established. Kc-vorthsless, it may be saia that our members can meet their individual problems in safeguarding the public, including of course our own factory employees, by their sincere effort in taking advantage of every possible preccution in the use of toxic materials in manufacturing, selling and in use. Such precautions plus constant repetition of intelligent instructions will, it is HIE* Q Q22Q4