Document JNJjJX1aaJYzJGJjZkjoeQKqa

INTER-OFFICE CORRESPONDENCE n nr. c. . Coleman Los Angeles August 25, 1977 **" J. C. Schmitt - Rochelle Park *uu*rr pioneer Product Labels I. We have reviewed all of the labels which you submitted in accordance with your June 29 letter and find a varying practice of showing warnings and safety precautions. For your guidance, we offer the following general remarks concerning warning statements on the labels and some of the practices to be observed. Following our general remarks, we will make some specific eonraents on groups of labels, and this will be followed by detailed recomendatxor.s on certain of the labels. In general, the following should be observed: 1. Directions for installation and application must be separated from safety precautions and state ments of product hazards. Precautions needed for proper performance of the product must be a part of this section on directions. 2. Safety precautions must be preceded by the appropriate signal word such as CAUTION, WARNING or DANGER, printed in a type size larger than any other type in the same panel. Hazardous ingredients must be identified, precautions to . be observed must be described and instructions on medical treatment should be included. All of this is to be in clear print in a prominent location on the label. 3. The above two types of statements can be indicated on most labels under the headings of: 1. SAFETY PRECAUTIONS 2. APPLICATION PRECAUTIONS These should suffice unless the nature of the product hazard is more severe than usual due to low flash . point, toxic ingredients, etc. Page 2 Mr. G. E Colaman August 25, 1977 4. Containers of five gallon capacity or greater should carry an additional label concerning the hazard of emptied containers. On cutback products, this label should read as follows: attention: THIS CONTAINER HAZARDOUS WHEN EMPTIED Since Emptied Containers Retain produet Residues (Vapor, Liquid or Solid), All Labeled Hazard Precautions Must be Observed. ' . . Do not expose to open flame. For'vater based emulsion and latex products, the label should read as follows: ' ATTENTIONi THIS CONTAINER HAZARDOUS WHEN EMPTIED Since Emptied Containers Retain product Residues (Vapor, Liquid or Solid), All Labeled Hazard precautions Must be Observed. Dried, water-free residues may be combustible. * Do not expose to open flame. * 5.. For most cutback products represented by your labels, the following general wording is the minimum warning recommended: * DANGER CONTAINS PETROLEUM DISTILLATES SAFETY PRECAUTIONS Avoid prolonged breathing of vapor or contact with skin. Use only in well ventilated area. If swallowed, do not induce vomiting. Call physician immediately. KEEP OUT OF THE REACH OF CHILDREN. KEEP AWAY FROM FIRE OR OPEN FLAME. DANCER - HARMFUL OR FATAL IF SWALLOWED Page 3 Mr. C. . Coleman August 25, 197? 6. For most vater based emulsion ar.d latex products, the minimum varying statenent should be as follows: ^ WARNING SAFETY PRECAUTIONS ' HARMFUL IF SWALLO^D. KEEP OUT OF THE REACH OF CHILDRid. 7. We note several product labels carry the warning paragraph concerning the corcsnt of asbestos fiber. In this paragraph, we prefer the wording that OSHA "has stated" that repeated inhalation of asbestos fiber is a health hazard, rather than OSHA "believes" that it is a hazard. This warning statement should appear in the sane panel and adjacent to all other health and safety warnings. We also prefer the use of petroleum distillates as a description of the solvents instead of mineral spirits and other terms. 8. Any other warning statements required by local regulations should be in the same panel and adjacent to the safety precautions and warnings. This would apply to the California Prohibition of spraying asbestos containing products. 9. Labels should not contain such terms as "non toxic", if another portion of the label states that ingestion can be harmful. Avoid the use of "non-toxic" altogether. 10. There is some inconsistency in the use of the signal words "CAUTION, WARNING AND DANGER". As a general term to call attention to warning statements, the words SAFETY PRECAUTIONS is recommended. The word CAUTION is a signal word for minimum hazards such as avoiding ingestion or of combustibility, etc. The word warning r . Page 4 Mr. G. Coler.ar. August 25 1977 is a stronger word, which will aptly to irritants or harmful vapors, flzrmables ' and similar hazards. The word DANGER is a still stronger term which will apply . to toxic materials, petrolcra distillates, . and higher flascnability characteristics. t 11. All product use and performance claims and statements should be substantiated by factual records. 12. Flintkote has full liability for the contents of customer labels applied by Flintkote, even though the labels may be furnished by the customer. The requirements for Flintkote labels extend to private account labels. For more on liability for private labeled products see the enclosed letter of October 8, 1975 frcm 5. Weiss to C. T. Derry. The Pioneer Division should be governed by the statements in this letter. . gf-s cs:s:r? . One large group of labels are those used on Flintkote GF-8 Tile Cement and the various private labels for this same product. Included arc the labels to be applied to the carton for one gallon cans. We suggest that all earton labels for GF-8 Cement, and other cutback products carry the following statement: WARMING Contents Flarranable Do not store near heat sources. Read precautions on containers before using. Referring to the GF-8 label for five gallon containers, application instructions and safety instructions arc intermingled. We would suggest that the safety precaution information be consolidated in one panel as follows: ) Page 5 Mr. G. 5* Coleman August 25, 1977 . Cr.-c * DANGER - FLAM-ABLE .MIXTURE DO NOT USE NEAR FIRS OR FLAME ^ . FLASH POINT IS 25* F T.C.C CONTAINS PETROLEUM DISTIIIATE. HARMFUL OR FATAL if swallowed. Do not induee vomiting. CALL PHYSICIAN IMMEDIATELY Avoid prolonged contact with skin and breathing of vapor. t USE WITS ADEQUATE VENTILATION ' DO NOT use in same room with open flame. Extinguish all pilot lights. Turn off stoves, heaters, electric motors and other sources of ignition - and do not smoke - during use and until all vapors are gone. KEEP CAN CLOSED WHEN NOT IN USE. YS.I2 OUT OF REACH OF CHILDREN. This particular label has the DOT red flammable liquid diamond. Is this red diamond required on five gallon pails? If so, why is it not included on the cutback cement labels for ROBERTS and KELDWOOD? We note that some of the private label cutback labels have a small insert on the front panel reading in essence "Warning, Flammable Mixture, Do not use near fire or flame, F.D. C of A number, see precautions elsewhere on the label.* This practice is highly recommended on all labels since the front panel attracts the first attention of the buyer or user. Some private labels for the GF-8 cutback tile cement contain the information as listed in the above recoirenendation, but these state ments need to be separated from the application instructions, and they require larger type for the signal words. This applies to labels for GAF and TCP. Some of the private labels are totally deficient, for example, American TILE-TITE, Webtex, and Kentilc. The label for Roberts Adhesive 41-5014 contains all of the essential warning information in the proper style, therefore, needs no' revision. The Weldwood label does not display the warning statements properly, therefore, this must be revised. * Pago C Hr. G. S. Coleman August 25, 197 exuieto^ *T>TT~ cements The next group of labels is for FAST-SET and other emulsion tile cements. Labels for produets in this category should have the following warning statement. WARNING SAFETY PRECAUTIONS Harmful if swallowed JSEP OUT OF THE REACH OF CHILDREN On the FAST-SET label* we object to the statement "non-toxic" under" the description which is inconsistent with the warning that the product is harmful if swallowed. Zt is suggested that the words "non-toxic" be eliminated entirely. . We question another statement which appears on the FAST-SET label and on other Flintkote labels to the effect that Flintkote is the "world's largest manufacturer of flooring adhesives". Is it possible to support or substantiate this claim? The same recommenced warning statement should be added to the Roberts Brush-On adhesive label and the Weldvood Brush-On label. On both of these labels the warning statement should stand cut very clearly with large type for the word WARNING. Similar comments apply to the BONDCOTE label and the private labels for emulsion adhesive. There is no objection to the statement that the contents consist of asphalt dispersed in water. LATEX U?7PRLAY?!EXT The labels for Latex underlayment liquid should carry this same warning* repeated as follows: WARtfTNG _ SAFETY PRECAUTIONS Harmful if swallowed KEEP OUT OF THE REACH OF CHILDREN This applies as well to the Roberts and the Wcldwood labels in which the warning statement should be separated and preceded with the word warning in a larger type site than used elsewhere. Page 7 Mr* C. 2. Coleman August 25, 197 The labels supplied with your June 29 latter did net include those used cn the Latex Undarlayment powder peonages. Latex Uf.derlaymer.t powder contains dry portland cement, therefore, the bag or container should carry the following caution statement: I ' % ' exmoy Contains Portland Cement. Freshly mixed cement, mortar, grout or concrete r.ay cause skin irritation. Avoid direct contact where possible and wash exposed skin areas promptly with water. Portland cement dust ray be an eye irritant. If any cementitious material gets into the eye, rinse immediately and repeatedly with water for 15 minutes. Get prompt medical attention. ,, Avoid ingesting or inhaling. KEEP OUT OF TK5 REACH OF CHXLCRZM ASPHALT CUTBACK PRODUCTS The next large group of labels is for cutback asphalt products for roofing, damp proofing and water proofing, etc. Most of the labels for these cutback products can use the minimus warning statement included uner general recomendation Mo. 5 above. This warning statement should be more prominent than on the label for Flirtkote Plastic Cement 810-22. The labels for the cartons of one gallon cans should have the same warning as recommended for the GF-8 earton. The Cclotex Elaatigum roof coating label would be more effective if the warning on asbestos fiber content were placed adjacent to the remainder of the warning statement. These same comments apply to the labels for the other cutback produc both Flintkote and private label. Pag 9 Mr. G. E. Coleman August 25 1977 ALUMtyJM 70OF COATINGS ' Another large group of labels is for the series of aluminum rear coatings both fibered and non-fiberea. All of these are cutback products, therefore, should carry as a minimvsa the statement appearing under general recommendation No. S. Again, we note thak the five gallon labels do not carry the SOT red flarsable liquid, diamond. is it necessary that this be applied to all cutback products in five gallon containers?' Is this red diamond required on 55 gallon drums? - is it required on cases and careens? The Fibre* label contains the statement that the product is an extremely flammable mixture. What property puts fibre* in this higher category of flammability. If Fiferex Cement is more hazardous than the other cutback products due to a lower flash point or due to the nature of the solvent, some mention of this should be made in the warning statement to identify this increased hazard. In the case of the ribrex label, we note that the five gallon label carries the DOT red flaznable liquid diamond. ASPHALT EMULSION PRODUCTS The next major group of labels is for asphalt emulsion products. These should carry the minim.cn statement given under general recommendation No. 6 above. Again, this warning statement should be separated from, all other instructions, and the word "warning" should be in a type size larger than any other type in the same panel. The same recorrr.endations pertain to Dura Shield Driveway Coating, Deco-Color "MP" and DecoTurf, all of which appear to be emulsions or latices. If these products contain other ingredients that may be toxic or hazardous, appropriate warnings should be afied. Is there a slipping hazard when these products are wet, either directly after application, or during use after drying? If so, seme caution statement should call attention to this. The Rexkote-Spectra labels carry the statement that the product contains phenyl mercuric acetate. This chemical is listed in the Registry of Toxic Substances. Ve would suggest that you obtain some information from the supplier of this material relating to the expected toxicity in the actual concentration in the RcxcoteSpectra products. You mig*t ask the supplier to make any reccm.~er.dati on the warning statements needed on a product with this concentration of phenyl mercuric acetate. Page 9 Mr. G Coleman August 25, 1977 D5C0S0ND EPO:c? The .Deeo3ond product is a two component epoxy compound.. Epoxy materials are considered toxic and the label must identify the tox$.c materials by name, list the hazards, give precautionary instructions, advise on clean up of spillage and first aid measures. The extent of these warning statements will depend upon the particular ingredients used in your produet, and we suggest that you contact your suppliers and obtain their recommendations. The Flooring Division supplies an epe::y flooring compound, the reeormendations for which are attached hereto. These recommendations cover both the wording and the nininxa type size. * This warning, or a similar statement should be added to the DecoScr.d labels. ?tcyc~o?.M EMULSION - Flinfete Monoform emulsion is presumably similar to other asphalt emulsions, therefore, would carry the minimum warning statement suggested in general rcecmendation No. 6. If Monoform contains any other ingredients, their hazards should be evaluated and included in the warning statement, if necessary. The Monoform labels show only S5 gallon capacity. Presumably, it is not supplied in smaller containers. These drums as veil as all other containers of five gallon capacity or greater should carry the emptied container warning label. If Monoform emulsion is sold only to eonenercial applicators, and if the product or its containers does not generally enter the retail trade or be brought into a household, it might be advisable to include in the label some statement such as the following: FOR PROFESSIONAL AND INDUSTRIAL USE ONLY Even with this statement, it is still reecranended that the minimxs warning given in geeral recommendation No. 6 be added to the label. Returned herewith is one copy of each of the labels on which vs have indicated some of these changes. We did not taVe the time to indicate the required changes on all of the labels since these arc covered in a general way in this letter. , Page 10 Hr. G. E. C August 25, 1977 These remarks also apply to the lithographed cans. The taikial can printing contains the essential warning statement. The Plastie Cement and GP-8 can printing must be revised torake the warning statement more prominent* I ' The same procedures will apply to stencilled drvts. In response to your question of timing on the revisions, we suggest a program of priorities, giving greatest emphasis to the Epoxy product, the ilamable cutback products, and products that have a greater liklihood of being U3ed in the home such as tile cements. High priority should be given to labels completely lacking m warning statements, or lacking essentials in part. Lowest priorities ' go to labels with most of the esantials but requiring more prcm.inenc An immediately change over is not only costly, but will no doubt -e physically overwhelming. If existing stocks are so extensive that t change will not occur in the foreseeable future, then the cost of disposed stock may ba low in comparison to a potential claim. Naturally, all reorders will include necessary revisions. Our review did not extend to other features of the label such ' as descriptive matter or application instructions. These should be cheeked for accuracy before printing, Many labels lack the proper limited warranty statement, which should conform to the wording on the Flintkote Plastic Cement 810-22 label. If you have any questions concerning the above, or if we can assist you further in bringing the labels into conformance, please advise. JCS/plb Enclosures eet Mr.W. Harvey Hr. J. Askins Hr. J* Hay Hr. J. Kent Hr. w. R. Ingram Hr. T. H. Parke Mr. S. Weiss HEAVYEMPHASIS ON hTntKotI HELP Lnes PREVENTION component a I Contains Epoxy resin, diethylene triamine and toluol. 4 VARYING: '* ' .The ingredients in parts A 4 B are toxie. In addition, the contents of part B are flasaaable, the vapor is harmful and if allowed to contaet the skin nay eause sensitization or other allergic reactions or serious dermatitis. The same hazards exist in the mixture until cured. - Keep away from heat, sparks and open flame. Use only with adequate ventilation. Avoid contact with eyes and skin. Avoid breathing of vapor - Keep closures tight and upright to prevent leakage. Keep container closed whan not in use. In case of spillage, absorb and flush with large volumes of water immediately. FinST AID: In case of skin contact wash thoroughly * with soap and water; for eyes, flush imediately with plenty of water for IS minutes and call a physician. If affected by inhalation of vapors, remove to fresh air. If swallowed, call a physician immediately. Do not induce vomiting. Remove and wash contaminated clothing immediately and wash thoroughly before reuse. Minimum Tvce Size 12 pt. CAPS 13 pt. CA?S 10 pt. CAPS 10 pt. CAPS > lasel for pzst ck: COMPOSES? S } Minimum Type Size Contains Diet'nylene triamine and toluol 12 pt. CAPS DAUGER: The contents are toxic, and fleasable, the vapor is harmful d if allowed to contact the shin say cause skin sensi tisation or other allergic reactions or serious dermatitis. 18 pt. CAPS Keep away fren heat, sparks and open flame, Use only with adequate ventilation. Avoid contact with eyes and skin. Avoid breathing of vapor. Keep closures tight and upright to prevent leakage. Keep container closed when not in use. In ease of spillage exposure, absoro and flush with large volumes of water immediately.. 10 pt. CAPS FIRST AID: In ease of skin contact wash thoroughly ' with soap and water; for eyes, flush immediately with plenty of water for 15 minutes and call a physician. X . affeeted by inhalation of vapors, remove to fresh air. If swallowed, call a physician inenediately. Do not induce vomiting. Remove and wash con . taminated elothing immediately and wash thoroughly before reuse. 10 pt. CAPS