Document Gz1Nq8pynj2aO9D5wB1XVQ4YN
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DISTRIBUTION LIST
RHM-2572-79 November 15, 1979
J. D. Underwood - New York G. A. Rodenhausen - New York
Hayden w. Head, Jr.*
C. J. Schaefer* E. L. Tejml I. 0. Coleman, Bishop W. H. Brough * J. Garza * P. E. Hime R. G. Brandt C. W. Harrison Clear Lake G. A. Dorgant * J. J. Fritsch J. W. Dunn * CCCTC Central Files R. D. Damron W. E. Heinz . G. J. Fisher W. T. McNair J. L. Ragan * W. J. Humphrey Dallas
Dawson J. K. Stafford* R. Seawright * E. Radziewicz * C. D. Barrett
Pampa J. M. Mullins* C. E. Steel
Newark Terminal W. D. Coble
Chatham G. W. Halek
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Interoffice totwfnmhm
i o (Name and Location)
DR. F..V. UHRFT.ER
MOM (Naina and Location)
JAMES M. RAMEY
SEN 55 (ReV./74)
.................
DATE
SeptMnhpr 26 r 1977
REFERENCE NO.
JMR/557/77
SUBJECT: ADMINISTRATIVE PROCEDURE - HAZARD REVIEW FOR PURCHASED CHEMICALS
A proposed Administrative Procedure requring hazard review of purchased chemicals was presented to the August 18th meeting of the Product Safety Committee. You will recall that the extensiveness of the list of support chemicals was questioned. R.D. Damron and C.D. Barrett were asked to develop a more definitive list which excludes many maintenance and construction materials that should not be covered.
I have revised the Administrative Procedure to reflect their reconmendation. If this meets with your approval 1 suggest that Mr. Trebellaa mail copies of the revised Administrative Procedure (attached) to all members of the Product Safety Comlttee for final approval.
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JMR/to enc.
CC: Dr. J. Trebellas J.A. Bousquet C.D. Barrett R.D.- Damron
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CELANESE CHEMICAL COMPANY HAZARD REVIEW OP ALL PURCHASED CHEMICALS
PROPOSED POLICY STATEMENT
The operation of Celanese Chemical Company encompasses a broad range of production processes and chemical substances which present potential hazards to employee safety and health and the environment. It is the policy of the company to mini mize these risks by establishing and enforcing rigid standards in the field of safety and occupational health. A key element of these standards requires that certain basic information be developed on a chemical before it is purchased for use in order to identify and evaluate potential hazards and to establish approved procedures for the safe handling, use and disposal of the chemical.
A program called Hazard Review for Purchased Chemicals will be implemented immediately under the direction of the Manager, Product Standards. The administration of the program is detailed in the attached Administrative Procedures. The con trol for the program must be the shared responsibility of the purchasing organization and the product standards group with consultation from the Medical and Safety Departments. The following basic policies are established:
1 For the purpose of control, all chemical sub
stances must be considered potentially hazardous
until they are evaluated and determined to be
otherwise.
*
2 No chemical substance will be approved for
purchase until its physical, chemical and
toxicological properties have been reviewed
and a guideline developed for its safe use.
No chemical will be introduced into the plants unless it can be handled, used, and disposed
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of without undue risk to employee safety,
health, or the environment.
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3. A chemical which has demonstrated a carcinogenic, mutagenic, or teratogenic response in humans will not be approved for purchase if there is any technically feasible substitute. The chemical may be purchased only with written approval of the Chairman, Product Safety Committee and the Corporate Medical Director.
4. A chemical which has demonstrated a carcinogenic, mutagenic or teratogenic response in animals and is thus a suspect human carcinogen, mutagen, or teratogen will require approval of the Manager, Product Standards prior to purchase.
5. No Purchase Order for a chemical will be approved unless it is listed in the Inventory List authorized under the Toxic Substances Control Act of 1976.
6. The chemical composition of new trade name chemicals should be defined before approval for purchase.
* - Chemicals purchased in small quantities for research and laboratory use will be excluded from the control procedures. A facility manager or his designee can grant temporary approval of a chemical or material in an emergency to avoid a critical process outage. Written notification of such exceptions must be sent to the Division Industrial Hygienist within 5 days. The approving authority in the two exceptions listed above is responsible for developing enough information on the material to ensure its safe use.
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CELANESE CHEMICAL COMPANY ADMINISTRATIVE PROCEDURES HAZARD REVIEW FOR PURCHASED CHEMICALS REVISED LISTING OF SUPPORT CHEMICALS
1. Objective - To provide a positive control of the purchase of hazardous chemicals to ensure that adequate health and safety information is developed and evaluated prior to use.
2. Purpose - To identify and evaluate potential hazards associated with use of a chemical and establish approved procedures for its safe handling, use and disposal.
3. Scope - For the purpose of control, all chemical substances must be considered to be potentially hazardous until they have been evaluated and determined to be otherwise. Chemicals to be evaluated prior to purchase should include raw materials, catalysts, and support chemicals. Support chemicals include mainten ance, construction, aqd other related compounds such as:
a) Solid "asbestos containing" materials such as transite, building Danels (such as Galbestos), etc.;
b) Liquid materials such as asphalt emulsions, plastic water-proofing compounds, polyurethanes, plastics, resin-type compounds (such as epoxy resins), pipe coat ings, adhesives, sealants, joints compounds, caulking compound, rust proofing compounds;
c) Powdered or granular compounds such as abrasives, cements, etc.;
d) Welding rods, welding flux, soldering flux. etc. ;
e) Asbestos insulating materials;
f) Cutting oils, lubricants, vacuum pump oils;
g) Solvent based paints, varnishes, lacquers, thinners, shellacs, degreasing (or cleaning) solvents , Freons, etc.
h) Water treatment compounds;
i) Pesticides, herbicides and fungicides; j) Compressed gases including aerosols;
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k) Acids, and other corrosive chemicals; and
1) Other supportive type chemical compounds such as copying machine (Xerox) compounds and printing chemicals.
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Chemicals purchased in small quantities for research and laboratory use will be excluded from the control procedures. Also, chemicals and maintenance materials needed in an emergency or to avoid a critical process outage can be approved by the facility manager or his designee. Written documentation of such exceptions must be sent to the Division Industrial Hygienist with in 5 days who will develop the same safety and health information required forthe routine purchase of a new chemical or material. The approving authority is charged with the responsibility of developing enough information on the material to ensure its safe use.
4. Procedures
a. To implement the Hazard Review for Purchased
Chemicals, the Division Industrial Hygienist,
with guidance from the Corporate Medical and
Division Safety Departments, will develop an
approved list of all chemical substances
currently in use in the company. A Material
Safety Data Sheet (OSHA Form 20) will be developed
and reviewed for each chemical to ensure that
adequate safety guidelines have been developed
on the chemical prior to approval. If this is
not possible, the following minimum information
is required before a chemical can be included
in the "approved" list:
-Composition
-Modified NFPA Code (Health, Fire, Reactivity)
-DOT classification
-Special Hazard Code (C-Carcinogen; SC-Suspected
Carcinogen; SENSensitizer; CHR-Chronic Hazard;
_ SKIN=Skin Hazard)
-Storage Code (to be developed)
-Disposal Code (to be developed)
-Chemical Abstract Registry Number received by
the Plant Purchasing Department
-TOSCA Candidate List Code -First Aid Information
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- Special Fire Fighting Procedures
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The "control point" for the programs must be the shared responsibility of the purchasing organization and the product standards group. An up-to-date list of chemicals approved for purchasing will be provided by the Division Industrial Hygienist for the Division Purchasing Groups (within Supply and Distribution) and each facility Purchasing Department, Safety Supervisor, Laboratory Superintendent and Health Chemist. Purchase Orders for chemicals on the Approved List will be honored immediately.
All Purchase Orders for chemicals which are not included in the Approved List will be handled as follows: 1. ) Central Purchasing will submit Purchase
Orders to the Division Industrial Hygienist for approval. 2. ) Facility purchasing departments will send Purchase Orders to the Laboratory Superin tendent for approval. The Division Industrial Hygienist or the Labora tory Superintendent will take the following action: 1. ) Request from supplier a completed Material Safety Data Sheet (MSDS) and other information needed to complete Chemical Data Form. (The assistance of purchasing groups should be en listed to facilitate and expedite this step. In cases of urgency, the data can be taken from the supplier by phone and the MSDS developed prior to receipt of official form. 2. ) Complete the Chemical Data Form (Attachment A). 3. ) Evaluate the data. 4. ) Consult as required with safety, medical and technical functions.
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5. ) Materials adjudged "non-hazardous" will be approved immediately with no further action required.
6. ) If the material is a generic chemical and presents no unusual safety or health hazard (such as a contact allergen or a suspect carcinogen), a MSDS will be requested or pre pared; the Chemical Data Form completed and entered in the data system, and the name of the chemical entered on the Approved List by the Division Industrial Hygienist.
7. ) If the material is a new trade name chemical, the supplier must be contacted to ascertain its chemical composition and hazard potential. Copies of all appro*ved Purchase Orders for new chemicals and materials will be submitted to the Division Industrial Hygienist to be included on the Approved List and to facilitate follow-up with the ordering facility to assure that the chemical will be handled safely. An informational copy will be submitted to the Safety Supervisor of the ordering facility. Copies of the completed MSDS must be submitted to the Division Industrial Hygienist, Facility Laboratory Superintendent, Facility Safety Super visor, and the ordering department.
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ATTACHMENT A
CHEMICAL DATA FILE*
1. Chemical Name 2. Chemical File No. 3. Supplier(s) 4. Using Location(s) and Planned End Use 5. Generic Composition 6. Modified NFPA Code (Health, Fire, Reactivity) 7. Special Fire Fighting Procedures 8. Special Hazard Code (i.e., C = Carcinogen;
SC - Suspected Carcinogen; SEN = Sensitizer; CHR = Chronic Hazard; SKIN = Skin Hazard) 9. First Aid Treatment 10. Storage Code, Disposal Code 11. TOSCA Information
a. Chemical Abstracts Registry Number b. Candidate List Code Number c. Estimated Consumption in Current Calendar Year if Known
* Information stored on magnetic tape and entered by Health Chemists and Division Industrial Hygienist.
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