Document J375b0NvyER3mdqpg2pjboRkr

The Vinyl Institute Roy T. Gottesman Executive Director RECEIVED MG 1985 Curtis M. Pontz August 1, 1985 To: Vinyl Institute Legal Committee Subject: Generic PVC Material Safety Data Sheet and Label You will recall that at the last Vinyl Institute Legal Committee Meeting on May 1 in Washington, Bob Luss agreed to undertake the development of a generic PVC Material Safety Data Sheet and Label in an attempt to standardize thse documents within the industry. I have now received the enclosed letter and attachments from Bob and I know that you will agree that he has done an outstanding job in carrying out this assignment. These are being forwarded to you with the request that you have them reviewed by the appropriate person(s) within your own company and return them to me no later than September 10 with any changes, corrections or additions you deem necessary. I would also request that technical data, viz. physical constants, be checked with your technical people. If you have any questions, I'd suggest you discuss them directly with Bob Luss at (215) 327-6425. i When I receive your replies, I will coordinate the finalization of these documents with Bob Luss and obtain final approval from Keller and Heckman. In order to expedite the review process, I am sending a copy of this to Jerry Heckman for any comments that Keller and Heckman may have at this stage. At the same time, I am requesting Jerry Heckman to have his firm provide the Vinyl Institute with a legal opinion on the applicability of the OSHA labeling standard to PVC film material. Once we have final review and approval on the generic Material Safety Data Sheet and Label, we can then discuss the desireability of submitting them to OSHA for their acceptance. RTG:g Enel. cc: Jerome H. Heckman, Esq. Mr. Donald Goodman-- As per your request, the attachments are not being sent to Richard Lorenz as you will handling ADMsionof t*ie review within Tenneco Polymers THE SOCIETY OF THE PLASTICS INDUSTRY. INC. 355 LEXINGTON AVENUE NEW YORK. N.Y. 10017 (212) 503-0652 CTL031907 Occidental Chemical Corporation PVC Products Robert D. Luss Gigud Course. July 17, 1985 RECEIVED 'JUL 2 i 1985 DR. R. T. GOTTESMAN 4i Mr. Roy T. Gottesman, Executive Director The Vinyl Institute Division The Society of the Plastics Industry, Inc. 1025 Connecticut Avenue, N.W. Washington, D. C. 20036 Dear Roy: Enclosed please find a generic:--PVC material Safety Data Sheet and label for your review. The intent of developing these two 'documents is to standardize them for the industry. From . the material you previously sent me, we were able to see differences in the amount of information among the PVC producers. After you have had a chance to review the documents, they should either be forwarded to Keller and Heckman or the legal committee for review. If you have any questions, please feel free to contact me. I believe that our next project should be a review of the Keller and Heckman opinion concerning the applicability of the OSHA labeling standard to PVC film material. I still believe that film is an article and not covered by the standard. Have a good vacation. Sincerely, cc: Donald Goodman - Tenneco encs. DXY A^rr'.^rr: < re ; 5.. - 099 ' P i CTL031908 MATERIAL SAFETY DATA SHEET . GENERIC PVC MATERIAL SAFETY DATA SHEET PRODUCT INFORMATION Product Name The trade name under which the product is marketed. Common Name or Svnonvm: Polyvinyl Chloride: PVC; Poly vinyl Chloride Resin Chemical Name: Ethene. Chloro-homo polymer CAS Registry Number: 9002-86-2 Chemical Family: Homopolymers of Vinyl Chloride Chemical Formula: (CH2CHC1)n Manufacturer's name as cited on product package. Manufacturer's address as cited on product package. Manufacturer's emergency telephone number as cited on product package. Transportation emergency telephone ______________________ _ CHEMTREC: (800) 424-9300 Date of MSDS preparation or date of last change to it. HAZARDOUS INGREDIENTS PVC is not considered a hazardous material under current Department of Labor definitions. PVC may contain any of the materials cited below in residual (trace) concentrations. CAS Number Common Name Chemical Name 75-01-4 79-01-6 PHYSICAL DATA Vinyl Chloride Trich1ore thy 1ene Ethene, Chloro Ethene. Trichloro Boiling Point: (760 mm Hg) Not Applicable Vapor Pressure: (mm Hg 20 Vapor Density: (Air = 1 ) Not Applicable Not Applicable CTL031909  Solubility in Water: (% by Weight) Negligible f Appearance and Color: Powder: White- Specific Gravity: h2o = 1) 1.40 pH : Not Applicable Percent Volatily: (By Volume) Not Applicable Evaporation Point: (Butyl Acetate = 1) Not Applicable Other: Bulk density, depending upon type ranges from 18 to 35 lbs . / ft3 IV. FIRE AND EXPLOSION HAZARD DATA Flash Point: About 391C (735F ) Method: Not Specified ' Auto Ignition Temp. : About 435-5570C (815-1035F) Method: Not Specified x Flammable Limits: (la-Air % by Volume") Lower - Not Applicable Upper - Not Applicable o Extinguishing Media: Water is most effective. ABC dry chemical. AFFF and protein type air foams also work well. PVC resins are "ordinary combustibles" (NEPA defined Class A). Carbon Dioxide is not generally-recom mended for use on Class A fires ns a lack of co.oling capacity may result in reignition. Special Fire Fighting: Wear positive pressure, selfcontained breathing apparatus (SCBA). Personnel not having suitable respiratory protection must leave the area to prevent significant exposure to toxic combustion gases from any source. In enclosed or poorly ventilated areas, wear SCBA during cleanup immediately after a fire as well as during the attack pha'se of firefighting operations. -2CTL031910 'IV.. V. FIRE AND EXPLOSION HAZARD DATA f o Unusual Fire and Explosion Hazards: Combustion or thermal decomposition yields Carbon Dioxide, Carbon Monoxide. -Hydrogen Chloride (gas). Hydrogen chloride has a corrosive effect on many metals. Affected equipment surfaces and unprotected structural elements of buildings should be washed to remove corro sive deposits as soon as possible after depositions have occurred. Vinyi resin is not considered to be a dust explosion risk. The potential hazard has been evalu ated using the Hartmann Vertical Tube Apparatus. Data have also been reported by the National Fire Protection Association (NFPA). In the Hartmann apparatus, vinyl resin representing fine particle size (2 Microns) and large par ticle size (130 Microns) does not ignite or explode in concentra tions up to 2.0 gm/ liter. The NFPA shows "fine" particle size vinyl resin to have a low order of risk.* Explosibility index: Ignition sensitivity: Explosion severity: Ignition temperature dust cloud:- 660C <<().l (weak) <<0.1 (weak) <<0.1 (weak) (1220 F) `Source: NFPA 654-1975. "Proven tion of Dust Explosions in the Plastics Industry." <<0.1 means that ignition of the dust cloud is not obtained by a spark or flame source. As a precaution, it is prudent to employ standard safety measures used in handling finely divided organic powders. HEALTH HAZARD DATA THRESHOLD LIMIT VALUE None Established -3- CTL031911  Dust Exposure: Vinyl resin has little e f f,e c t the lungs and is not known to cause any.dis ase when d,ust exposure is minimized. on While there is no evidence of a stubstantial risk to health, a British study found a small de crease in breathing capacity for workers who smoked and were ex posed to vinyl resin dust. This decrease was about one-seventh of that caused by normal aging and about equal to that expected with one-pack-a-day cigarette.smokers. The American Conference of Govern mental Industrial Hygienists' Threshold Limit Value (1984) for nuisance dust is 10 mg/m3 for total dust and 5 mg/m3 for respirable dust. Respirable dust are those particles in a size range below 10 microns. Typical particle size for suspension and mass vinyl resin is 70-1.5 0 microns: blending resin is 25-130 microns. Dispersion resin has an average particle size below 5 microns. Routine inhalation of dust of any kind should be avoided. Exercise care when dumping bags, sweeping, mixing or doing other tasks which can create dust. Where large amounts of any dust may occur, wear a respirator approved by NI0SH/MSHA to protect against nuisance dust. V. HEALTH HAZARD DATA Effects of Overexposure: There are no significicant health hazards from vinyl resin at ambient temperature (see Dust Exposure) . No adverse health effects are expected from processing vinyl resin when potential exposures minimized by good industrial hygiene practice and adequate ventilation. Nevertheless, at are -4- cTL031912 f' processing temperatures, he sum total of all ingredients un a vinylbased compound (e.g., vinyl resin, stabilizer, lubricant, modifier, etc.) may emit fumes and vapors that are irritating to the respiratory tract, eyes or skin of some sensi tive people. This depends upon processing technique and tempera ture, volume processed and, most importantly, the effectiveness of exhaust ventilation provided to the process area. Inhalation of decomposition or combustion products, especially hydrogen chloride, will cause irritation of the respiratory tract, eyes and skin. Depending on the severity of exposure, physiological response will be coughing, pain and inflammation. Individuals with bronchial asthma and other types of chronic obstructive respiratory diseases may develop bronchspasm if exposure is prolonged. SPECIAL NOTE: Hydrogen chloride is detectable by its sharp, pungent odor in concentrations as low as 1-5 ppm. Low concentractions (below 50 ppm) are not harmful in short-term exposures., but do provide excellent warning properties by causing cough ing or irritation. Because the protective response is so strong, humans rarely submit to damaging con ce ntractions--instead. there is an unmistakable urge to leave the area. Repeated or prolonged expo sure to high concentrations can' cause eye and respiratory damage. In studies sponsored by the Federal Aviation Administration, no incapaci tation, no impairment to escape and no significant post-exposure effects occurred in baboons exposed to hydro gen chloride up to 11.400 ppm (1.14%). OSHA has established a ceiling limit of 5 ppm for workplace exposure to hydrogen chloride". CTL031913 -5- VI. F----i-r--s--t---4As---i-d-----M--e---a--s--u--r--e--s--: Skin : Eyes: Inhalation: Note to Physician : HAZARDOUS REACTIVITY DATA Stability: 0 Conditions to Avoid: Incompatibility: Hazardous Decomposition Products: Below decomposition teipdrnturo the product has no significant toxic hazard. HAZARDOUS FUMES'are produced by combustion or high temperature decomposition. If exposed to fumes: Flush skin thoroughly with cool water for at least five minutes. Immediately flush eyes with a directed stream of water for at least 15 minutes, while forcibly holding eyelids apart to ensure complete irrigation of all eye and lid tissue. GET.MEDICAL ATTENTION. Remove to fresh air. If breathing is difficult, administer oxygen. If respiration stops, give mouthto-mouth resuscitation. GET MEDICAL ATTENTION. Material has no significant toxic hazard. Hazardous fumes (HC1. CO. CO2) are produced by combustyion and may be produced by decomposi tion at processing temperatures. Stable. Hazardous polymerization will not occur. Excessive heat for prolonged periods. Avoid contact with acetal or acetal copolymers and with amine contain ing materials during processing. At processing conditions these materials are mutually destructive and involve rapid degradation. Thoroughly purge and mechanically clean processing equipment to avoid even trace quantities of these materials from coming in contact with each other. Prevent cross contamination of feedstocks. Hydrogen chloride, carbon monoxide, carbon dioxide, and small amounts of benzene and aromatic and ali phatic hydrocarbons. -6CTL031914 VI I . ENVIRONMENTAL PROTECTION Procedure In Case of Spill or Release: Vacuum or sweep into a closed concontainer for reuse or disposal. Waste Disposal Method: Dispose of waste in a licensed landfill or by inceration in accord ance with federal, state and local regulations. For waste disposal purposes. PVC resins are not de fined or designeated as hazardous by current provisions of the Fed eral Resource Conservation and Recovery Act (RCRA - 40CFR261). If incinerated, be aware that hydrogen chloride is generated. Ventilation: Provide effective exhaust ventila tion to draw dust and/or fumes away from workers tro prevent routine inhalation. Compounding, hot melt processing (extruding, molding, etc.), cutting or sawing, machin ing. regrin<yjig, the rmo f o r m i ng . heat welding, and other processing or post-processing operations in volving heat sufficient to result in polymer breakdown should be examined to ensure adequate ventilation. Ventilation guidelines and techniques may be found in the following publications: - NIOSH Recommended Industrial Ventilation Guidelines: GPO #017-033-00136-7. Available from the Superintendent, of Documents. U.S. Government Printing Office, Washington, DO 20042 ($9.00 as of December 1984). - Industrial Ventilation. 18th Edition. Available from the American Conference, of Govern mental Industrial Hygienists. 6500 Glenway Ave.. Bldg. D-5, Cincinnati. Ohio 45211 ($15.00 as of December 1984). II. SPECIAL PROTECTION INFORMATION ------------------------------------------------------------------------ CT^03I915 -7-  Respiratory: (Type) *_ Not normally required. Abnormal conditions such as equipment mal function, use of improper equipment or procedures, or hangup or stagna tion of vinyl-based compound during processing may cause decomposition. Employees involved in removing decom posing material should be provided with suitable air-supplied respi rators, such as NIOSH/MSHA approved positive pressure, se 1 fconta i ned breathing apparatus. Gloves: (Type) None required. Protective gloves are suggested when handling hot material during processing. other Protective None required. Gloves if allergic Equipment :___________ * dermatitis is suspected. Dust masks where exposure to dust takes place. Note: TLV (Threshold Limit Value) for Chemical Substances in Workroom Air Adopted by ACGIH for 1978, page __ 32. "Nuisance Particles: is 30 mppcf or 10 mg/m3 of total dust <1% quartz.-or 5 mg/m3 respirable dust. IX. SPECIAL PRECAUTIONS Precautions to be Taken Store in cool, dry place (for prodin Handling and Storing: uct quality). Normal melt processing. Virtual 1y all thermoplastic-materials will emit fumes and/or vapors when heated to processing temperatures. The concentraction and composition of these vapors will depend upon variables such as the specific compound formulation and processing method and temperature. Always use vinyl compound under well-ventilated conditions and avoid continued or prolonged breathing of process vapors. For personal hygiene, wash thoroughly after handling resin, especially before eating, smoking or using toilet facilities. Do not store or consume food in processing areas. Do not use processing equipment to heat food. Cleanup following normal melt proces sing should be performed under wellventilated conditions. Compound -8- 1 f based i^pon vinyl resin may be held at process temperatures for a short time without significant thermal degradation. However, it should be recognized that exposure to either elevated temperature or excessive heat history (time) will result in decomposition.* Equipment should not be shut down for extended' time periods with vinyl compound in it, or decomposition and possible cor rosion of unprotected metal may result. If dies and screws are not to be cleaned manually, then com pound should be purged from proces sing equipment prior to shutdown using special vinyl purge compound or a compatible thermoplastic such as general purpose ABS (do not use flame-retarded or halogencontaining grades for this purpose). Time and temperature required to initiate degradation will vary depending upon processing tech nique, degree of compound stabil ization and other factors. As a general rule-of-thumb, degradation begins to occur after about one hour at 177C (350F). about ten minutes at 204C (400F) and within five minutes at 2 3 2C (450F). In case of power loss or other mishap, shut off the machine and dismantle the die assembly as soon as possible before degradation or decomposition begins. If denompnsi tion begins (with gassing and "Popping" sounds) before the die can be disassembled, dangerously high pressure may occur in the die system. In this event, shut off the machine, clear the area of personnel and wait until decompo sition stops. Thoroughly ventilate the area. Remove and disassemble the die system. These are guide lines only. Refer to technical service reports and equipment manufacturer's recommendations for specific procedures. CTL031917 -9- X . REGULATORY STATUS Regrinding scrap normal] j( generates substantial heat. Cool regrind before placing it in containers. The excellent insulating quality of vinyl will prevent heat in the center of a container from escap ing, potentially resulting in slow thermal decomposition of the material. This may not only render the product unsatisfactory for further processing but also result in fumes and vapors being released into the workplace atmosphere. Remove vinyl resin from walkways and floors to prevent slippery footing. Sprinklered warehouse areas are recommended. Although vinyl resin by itself will not support combus tion. materials such as wooden pallets, cardboard boxes and other combustibles can provide sufficient fuel to cause vinyl to burn. Compounding vinyl resin. Many of the common compounding ingredients which are mixed with vinyl resin' may require special handling, especially respiratory protection. It is the user's responsibility to obtain and follow the recommend-ed precautions of the individual additive supplier. SPECIAL N-OTE: Vinyl compound at or above normal processing temperature must never be allowed to accumulate in thick masses, or it will begin to thermally decompose and to swell due to internal gassing. Gassing may cause a thick mass to explode if its outside surface is hard ened. Molten waste should be collected as strands or flattened to 2-inches or less, and quenched in a drum of cold water provided for this purpose. Decomposing material should be removed to a we 11-venti1 ated area, preferably outdoors . -10- CTL031918 r m Vinyl Chloride Monomer (VCM): i Employee exposure to vinyl chloride monomer (CAS Registry Number: 75-01-4), a carcinogen, is regulated by OSHA ( 29CF.R1910.1017 ) . The current regulation requires that no employee may be exposed to VCM concentrations greater than 1.0 ppm (parts per million by volume) averaged over any eight-hour period or 5.0 ppm averaged over any period not exceeding 15 minutes. The action level is 0.5 ppm averaged over any eight-hour work day. SPECIAL NOTE--Viny1 Chloride Warning Labels on Resin Containers: The regulation applies to the manufacture, packaging, repackaging, storage, handling or use of vinyl chloride or polyvinyl chloride, but does not apply to the handling or use of fabricated prod ucts made of polyvinyl chloride. Typically, purchasers of vinyl resin to be compounded or further processed must comply with the permissible exposure limits set by OSHA. Moreover, the regulations requires a program of initial monitoring in each facility to determine if there is any employee exposure in excess of the action level without the use of respi rators. If monitoring does not find VCM above 0.5 ppm, no further action is necessary. Refer to OSHA regulations (including 29CFR1910. 1017) for complete details. Monitoring of vinyl processing and fabricating plants and modeling studies show that the action level (0.5 ppm) cannot be exceeded when residual VCM is at or below The OSHA regulation requires that the label says "Polyvinyl chloride contains vinyl chloride. Vinyl chloride is a cancer suspect agent." Polyvinyl chloride resin is not a cancer suspect agent. It is the trace amount of unreacted vinyl chloride monomer that must be controlled, not the vinyl itself. -11- CTL031919  Hazardous Substances: Although some containersfmay be labeled, this does not necessarily mean that employee exposure to VCM will exceed permissible exposure limits. Using "worst case" condi tions of thermal processing, studies show that more than 30 ppm of unreacted monomer in vinyl resin is needed to cause 0.5 ppm to be present in the atmosphere of a hot, poorly ventilated workplace. Good ventilation in those areas where VCM might concentrate--such as where containers are stored and first opened, where materials are mixed and where resin is melted-will further ensure a work environ, ment virtually free of VCM. None of the following materials designated as toxic and hazardous by the U.S. Department of Labor (OSHA) are used to manufacture vinyl resin nor are they anticipated by-products in.our production pro-cess: 29CFR1910. 1001 1002 1003 1004 1006 1007 1008 1009 1010 1011 1012 1013 1014 1015 1016 1018 1029 1043 1044 1045 1047 Asbestos Coal tar pitch volatiles 4-Nitrobipheny1 a 1pha-Naphthy1 am ine Methyl chloromethyl ether 3.3'-nichlorobenzidine (and salts) b i s-Ch1oromethy 1 ether beta-Naphthy1 amine Benz id ine 4-Aminodiphenyl Ethyleneim i ne beta-Propiolactone 2-Acetylaminofluorene 4-DimethylmainoazobonzRno N-Nitrosodimethy1 amine Inorganic arsenic Coke oven emissions Cotton-dust 1.2-Dibromo-3-ch1oropropane Acrylonitrile Ethylene oxide No lead, mercury, other heavy metals or heavy metal compounds and no polychlorinated biphenyls (PCB) -12- CTL031920 XI . ADDITIONAL INFORMATION Transportation: Hazard Codes: . * Special Note: t' r polybrominated biph n,yl s (PBB) are used to manufacture vinyl 'resins. These materials are ubiquitous and trace quantities may be found in the environment. For domestic transportation purposes, vinyl resins are not classified as hazardous by the D.S Department of Transportation under Title 49 of the Code of Federal Regulations , 1983 Edition. DOT Proper Shipping Name : DOT Hazard Class: DOT Label: DN/NA Hazard No.: Not Not Not Not applicable applicable applicable applicable Hazard Code Key 4 - Extreme 3 High 2 - Moderate 1 - Slight 0 - Insignificant NFPA 704(1) Flammability / /1 /V Reactivity \ y< Health \ /----- 0 ' Special (1) National Fire Protection Assoc. Vinyl chloride and polyvinyl chloride (PVC) are not the same material. Vinyl chloride is a flammable gas that is strictly regulated by DOT, EPA and OSHA. Through a chemcial reaction, this gas--known as monomer --is converted to a non-hazardous white granular powder called polyvinyl chloride resin, PVC, or simply, vinyl. Vinyl resin is not a cancer suspect agent. Moreever, the reaction is not reversible. That is, thermal processing or decomposition will -13- CTL031921 not cause polyvinyl chloride to revert back to vinyl chloride monomer. (See Section II and Appendix ,1 . ) HMIS Code: Health Hazard Rating: Flammability Hazard Rating: Reactivity Hazard Rating: Personal Protection Equip.: 0 l o None For PVC Resins With Over 1 PPM of RVCM: In compliance with the Department of Labor. Occupational Safety and Health Administration Standard "29 CFR 1910.1017 Vinyl Chloride (1). (4)" (published in Federal Regis ter. Friday. October 4, 1974, Vol. 39, No. 194, Part II. page 35890), containers of polyvinyl chloride shall be legibly labeled: POLYVINYL CHLORIDE (OR TRADE NAME) CONTAINS VINYL CHLORIBE VINYL CHLORIDE IS A CANCER-SUSPECT AGENT For PVC Resins With 1 PPM and Under of RVCM: ' No additional statements. Disclaim of Liability: IMPORTANT! The information pre sented herein, while not guaranteed, was prepared by competent technical personnel and is true and accurate to the best of our knowledge. NO WARRANTY. OR GUARANTY, EXPRESS OR IMPLIED. IS MADE REGARDING PERFORMANCE. STABILITY OR OTHERWISE- This information is not intended to be all-inclusive as to the manner and conditions of use. handling and storage. Other factors may involve other or additional safety or performance considerations. While our technical personnel will be happy to respond to questions regarding safe handling and use procedures, safe handling.and use remains the responsibility of the customer. No suggestions for use are intended as, and nothing herein shall be construed as. a recom nre n d a tion to infringe any existing patents or to violate any Federal, State or local laws. -14- CTL031922 GENERIC" PVC LABELS Identity of Product: Polyvinyl Chloride Appropriate Hazardous Warning--All Resins: This product may contain any one of the materials shown below: CAS Number -- 73-01-6 Common Name Trichlorothylene Chemical Name Ethene. Trichloro- Resins Above 1 PPM RVCM: POLYVINYL CHLORIDE (OR TRADE NAME) CONTAINS VINYL CHLORIDE VINYL CHLORIDE IS A CANCER-5 U-SPEC-T AGENT Resins Below 1 PPM RVCM: No additional warnings. Manufacturing Data: Name of Manufacturer: As appropriate Address: As appropriate Also Suggest 24 Hour Emergency Telephone Contact Data HMIS Code: Health Hazard Rating: Flammability Hazard Rating: Reactivity Hazard Rating: Personal Protection Equip.: 0 1 0 None RAP/jn 6/85 CTL031923