Document DvoMkY1oZ0b925zDBDaR2MQo5

TELEPHONE NATIONAL *6* NATIONAL UM Manufacturing Chemists' Association OF THE UNITED STATES ken N. WATSON UCWTAIY (FOUNDED 187*) 608 Woodward Building Washington 5, D. C HENDTES OF MEETING LABELS AND PRECAUTIONARY INFORMATION COMMITTEE Tayloe Room, Cosmos Club, H St# at Uadison Pi# Washington, D, C* February 19-20, 1947 L-148 The meeting of the Labels and Precautionary information Committee was called to order by Chairman W. N# Watson on Wednesday, February 19, 1947, at 10:00 AfM. The following were present: W.NWatson, Chairman TR#Aalto Carl Andersen J. S, Coey A. G. Cranch J. T, Fuess S. J. Hill D.. D, Irish IT#. A#. Khapp R# W, Lahey Frank s. Low R. D, Ilinteer J# A# Noone Guests: Dr. John H, Foulger, duPont Company John B Williamson, American Cyanamid Company Dr* Thomas W. Nale, Carbide & Carbon Chemicals Corp. Wf W Sunderland, The Dow Chemical Co# W# A, Groening, Jr#., The Dow Chemical Co# F# D# Spdrre, duPont Company Fred Bartenstein, Jr#, Merck & Co#, Inc. R F. Kansen, General Chemical Company T. MEMBERSHIP The Chairman welcomed Mr, J. A. Noone as a new member of the committee and assured him of the fullest cooperation# II. LABELS II-l. Phenol Label. The report of Dr# D D. Irish recommending the following revision in the "In case of contact" statement for the phenol label was approved: "In case of contact, remove all contaminated clothing at once; immediately flush skin or eyes with plenty of water for at least 15 minutes; for eyes, get medical attention. Wash clothing before re-use." This revision was also approved for cresylic acid and chlorophenol. PLAINTIFF'S EXHIBIT L-149 Dr, Irish -was requested by the committee to determine whether this revision Should be applied to any other items in "Warning Labels", and to report to the nest ^'meeting of the committee, II-2. Dry Ice Label., The chairman was requested to write to the CGMA advising that, after reconsideration, it was planned to include the LA-PI dry ice label (LA.PI Minutes, L-132) in a supplement to "Warning .labels." It was agreed that such advice should include a suggestion that if the S.CGMA should desire to appoint a spokesman to review the matter the chairman of the (||lAPI committee would be glad to meet with him* II-3. Nitrogen Dioxide. which was unanimously approved: Subcommittee chairman SJHill submitted the following label for cylinders of nitrogen dioxide. DANGERI Extremely Hazardous Liquid and Gas Inhalation May Cause Delayed Fatal Lung Injury READ MANUFACTURERS MANUAL FOR DETAILED HANDLING INSTRUCTIONS Avoid contact with skin or clothing. Do not allow to mix with combustible materials. In case of inhalation or suspicion of inhalation, remove at once to fresh air and call a physician. Keep patient absolutely quiet and give oxygen M continuously through suitable equipment. II-A. Paraformaldehyde. The committee affirmed mail vote approving the r>. following label for paraformaldehyde, submitted Ip members on October 15 and later included in Chemical Safety Data Sheet SD-6: WARNING! causes Irritation of Skin, Eyes, Nose and Throat. Avoid prolonged or repeated contact. Avoid breathing dust or prolonged breathing of vapor* Use with adequate ventilation. POISON fl Call a physician at once First Aid ; * Internally: Give milk freely, or one glassful of water containing one tablespoonful of ammonium acetate. Produce vomiting with a pint or more of warm salt water (1 cupful per quart) or warm soapy water* Repeat three times. Follow with milk and raw eggs* H~5. Paradichlorbenzene. Mr. Coey reported that available medical refer ences on paradichlorbenzene had been submitted to the subcommittee, including reported damage to the eyes and internal injury in case of excessive exposure. The committee recommended that a special study of this subject be made, including medical examination of employees in production plants to determine detailed case histories for a maximum number of persons. It was agreed that such investigations should have the approval of top management. Subject continued on docket. Ir-150 II-6. Dimethyl Sulfate -- Chloral* Mr. Hill submitted the following draft of labels for dimethyl sulfate and chloral. The dimethyl sulfate label is needed for inclusion in a Chemical Safety Data Sheet, and the toxic properties of chloral also call for a caution label* DIMETHH. SULFATE DANGER! Extremely Hazardous liquid and Vapor Causes Severe Burns Avoid contact with skin or clothing. Avoid breathing vapor. Use with adequate ventilation. Wear goggles and rubber gloves when handling. a poison a Antidotes Call physician immediately Eyes: Flush with water for at least 15 minutes. Skin: Immediately remove all contaminated clothing and flush skin with water for at least 15 minutes. Inhalation: If congestion results, start oxygen inhalation through suitable equipment. Spilled on floor: Cover immediately with dry soda ash. CHLORAL DANGERJ Extremely Hazardous Liquid and Vapor Inhalation May Cause Delayed Fatal Lung Injury Avoid contact with skin or clothing. Avoid inhalation of vapors. Use with adequate ventilation. In case of contact, immediately flush eyes or skin with plenty of water for at least 15 minutesj for eyes, get medical attention. In case of inhalation or suspicion of inhalation remove at once to fresh air and call a physician* Keep patient absolutely quiet and give oxygen continuously through suitable equipment. Members agreed to review these'labels and to submit their comments to the chairman and Mr. Hill by April 7, 1947. H-7. Chlorinated Cresols or Xylenols. Reference was made to a query from Hr, Mnteer concerning caution labels for chlorinated cresols or xylenols. It was reported that para-chloro-meta cresols had caused dermatitis but that it appears these items are not very important in this country. II-8* Experimental Labels for Tank Cars. Mr* Noone reported that more durable tags have been prepared and that the Tank Car Committee is reviewing reports on trial tests at each meeting. Progress report accepted. L-151 H-9, Nitric Acid - Label addition. The following amendment to the nitric : acid, warning label (also to be used . * on mixed acids) was unanimously approved: Add as 4th statement under warnings; "Spillage may cause fire or liberate dangerous gas," I-fi-. II--10. Labeling of Household Pa1ckages, In the temporary absence of following recommendations: Mr# Anderson, Mr, Hill reported the 1, That further publicity be given to the publication 1'Warning Labels," 2, That assistance be offered to interested parties concerned with caution labels. 3. That further efforts be made to prepare an appropriate article on the safe handling of household chemicals and chemical products. The committee questioned the advisability of the IAEE Committee attempting to formulate a series of specific labels for the various household products since these cane within the jurisdiction of separate associations dealing with these retail items. 11--11. Labeling of Commercial Shipments of Products Whose Properties are not Fully Known, Following a review of the problem of appropriat caution labels for new products, it was agreed that a letter should be sent to the M.C.A. Executive Committee outlining the problem and the need for determination of preliminary toxioological data before a new product is sold, rather than relying upon a statement to the effect that its properties are not fully known. It was also agreed that this letter should be accompanied by a draft letter to Member Presidents recommending that the principal toxic hazards of a new product be determined and covered by a specific label before being marketed. The text of these letters is to be prepared by Mr. Anderson and Dr, Foulger, 11--12. Labeling of Bulk Chemicals. Under Section 502 (f) of the regulations for the FDC Act, it has been permissible to use the statement "for manufacturing use only" in lieu of adequate directions for use. Section 503 (a)(2) exempts from any labeling requirement any product covering which the seller enters into an agreement with the user (code labeling). These provisions have also applied to a repacker, who has been regarded as a manufacturer. Attention was called to the fact that there are indications that FDC officials are considering a requirement that adequate directions for use must be placed on each bulk package of a drug unless the seller enters into an agreement with the user. It was pointed out that it is not feasible to put adequate directions for use on a bulk package of a medicinal because of the multitude of potential medical uses of the product, and furthermore, that in any seller-user agreement the seller must in practical terns police the labels adopted by his customer, including revis ions thereof. The following committee was appointed to make a further investigation of this problem and to report back to the IAPI Committee: Carl Anderson, chairman; L-153 Thus far labels have been supplied by General Chemical Co., E, I. duPont deKemours & Co., Carbide & Carbon Chemicals Corp,, American Cyanamid Co,, Penna. Salt Mfg. Co., Merck & Co., Monsanto Chemical Co. Other members agreed to submit a set of sample caution labels to committee members, 711. HANDBOOK OF ACCEPTED REMEDIES The chairman reviewed his letter of October 17, 1946, to Dr. P, J. Hanzlik of the Stanford University School of Medicine asking whether it was planned to revise his "Handbook of Accepted Remedies", and calling attention to the recommend ed antidotes sent by the IAPI Committee' to the Board of Pharmacy in California, Dr. Hanzlik* s reply dated October 22 indicated doubt that a revision would be issued, and suggested that any further suggestions for the revision of antidotes be sent to the Board of Pharmacy, Vm. CALIFORNIA ANTIDOTES It was agreed that members of the committee would review the Sept.l, 1946 list of official antidotes of the California State Board of Pharmacy, and submit comments to the chairman on those antidotes found to need revision in order that subsequently recommendations may be prepared by the Medical Advisory Committee for submittal to the California State Board of Pharmacy. - It was.pointed out that most of these antidotes appear to be acceptable and might be advantageously used on packages moving to the various States as they are mandatory in California and are believed to be acceptable in other States. IX. ARTICLE The chairman read a letter from Steven IJ. Spencer of the Saturday Evening Post asking for case history material -- particularly on the newer organic compounds that go to the household -- on the basis of which he might determine whether an article might be prepared. After extended discussion, the committee requested that the chairman advise Hr. Spencer that sufficient information along the lines indicated is nob available now to afford an article on this particular phase of the subject. X. POISON DEFINITION Reference was made to a court decision in the case of Lena v. Standard Oil Company of New York (Supreme Court of N.H. 1936, 88 N.H, 212, 186 A.329) in which the court held that the defendant company was not liable to the plaintiff for "a severe streptococcus infection, as a result of which he was disabled for several weeks and incurred substantial expense for-medical and surgical treatment and hospital care" from external contact with ethyl gasoline. In so holding, the court stated: "The fact that tetra ethyl of lead is an iactive poison* does not involve the conclusion that external contact therewith is injurious to human beings. It is common knowledge that such contact with many materials, known to be poisonous if taken internally, may be entirely harmless. The extensive use of spraying materials to combat insect pests and plant diseases bears witness to this fact." The committee reviewed the suggestion that this decision be referred to L-154 in connection with the footnote on page 2 of 'Warning Labels" relating to a definition of "poison," However, it Teas decided that the present footnote adequately covers the point in question* XI. CALIF.LABELING REGULATIONS The chairman reviewed a letter dated January 21 from A, C. White, San Francis co, in which he advised that galley proofs of the California labeling regulations had been proofread and returned to the printer for final printing. Mr, White also reported an effort by the California State Board of Pharmacy to prepare a separate label for carbon tetrachloride, and stated that at the hearing attention had been called to the fact that the Division of Industrial Safety had already approved a caution label for this product. XU. EXEMPTION CLAUSE FOR EOONCMEC POISONS AND INDUSTRIAL CHEMICALS The committee was advised that the following model exemption clause is being used for economic poisons and industrial chemicals in State pharmacy acts: "Nothing in this act shall be construed to apply to economic poisons used for the control of insects, or animal pests, or weeds, or fungus diseases (provided such economic poisons' are sold in original unbroken packages bearing a label having plainly printed upon it the name of the contents and the word 'poison') or to substances sold for use in agricultural, horticultural, industrial, or related arts and sciences." Members were invited to review this label and to submit their comments to the chairman in the event that any statement in this clause is not satisfactory. XIH. MISCELLANEOUS Definition of Glass B Poisons. Mr. Lahey reported on a proposed revision "' of the ICC definition of class B poisons which is under study by the M.C.A. Technical Committees, as indicated in the correspondence attached to these minutes. The problem has always been a serious one for the industry despite various revisions that have been adopted. The present Class B poison regulation lists certain items by name and in addition there is a basket clause for other products* A liability problem arises for the shipper if a product, which may not be specifically listed in the Class B category, falls within the definition under the basket clause by virtue of its properties. Members of the LAFI Committee were asked to review this subject and to send their comments to Mr, Lahey with a copy to Chairman Watson. Adhesives. Mr. Lowe asked about the most satisfactory adhesives for drum labels. A number of the members reported they were using mica resin 3605 manufactured by the National Adhesives Company, Discussion developed the observations that some adhesives are difficult to handle at low temperatures and others are not sufficiently water repellant, Mr. Lahey agreed to refer this subject to the Metal Packages Committee and to report back to the LAFI Committee on the recommendations of the MPC. L-155 Svthetic Resin Adhesives* Mr, R. IT. Lahey'presented the problem of an appropriate label for resin adhesives including urea formaldehyde. Afier a review, the chairman was authorized to appoint a sub-committee and to contact the EMMA in regard to their desire to have the M.C.A. handle this question, Caution Labels for Reagent Chemicals. The suggestion was made' that reagent chemical producers consider whether a special committee should be created to handle warning labels for reagent chemicals, which, on account of space limitations, would require some abbreviatio of the phrases in ''Warning Labels." Next Meeting. It was decided to hold the next meeting of the committee on Monday and Tuesday, April 21 and 22, at the Hotel New York er, XIV. ADJOURNMENT The meeting adjourned Thursday,'February 20, 1947, at 4:00 P,M W. N. WATSON Chairman Minutes subject to approval,