Document LJ4wJ3gDZrd5Jq8RRearxrNg3

TELEPHONE NATIONAL 2458 NATIONAL 2409 Manufacturing Chemists' Association, Inc (POUNDED 1872) 246 Woodward Building N. WATSON jb'c*bxa*v WASHINGTON 5, D. C. I.-206 MINUTES OF MEETING LABELS AND PRECAUTIONARY INFORMATION COMMITTEE- Hotel C arlton, Washington, D . C., November 15-16, 1948 The meeting of the Labels and Precautionary Information Committee was called to order at 10:00 A.M. Monday, November 15, 1948, by Mr. J. T. Fuess, in the absence of Chairman Watson. The following were present: J.T. Fuess, Acting Chairman Fred Bartenstein A. Q. Butler J. S.^Coey A. G. Cranch J. B'. Foulger S. J. H ill (Tuesday only) W. A. Knapp Franks. Low R. D. Minteer J. A. Noone W. W. Sunderland F. D. Sparre R. H. Hansen (Tuesday morning only) J. B. Williamson Guests: James S. Walker, Hooker Electrochemical Co. M. H. Arveson, Standard Oil Company George M. Douthett, J.T. Baker Chemical Co. H. F. Pfann, Koppers Co. lie*********************************************************** * Correction * * ---- * * Attention was called to an error in the minutes of the Septem- * * ber meeting in reporting action taken on a proposal to revise * * the "Causes Severe Burns'' statement on Acetic Acid, Glacial; * * Acetic Acid 80%, and Acetic Anhydride to read "Causes Burn^I* * (Min. HE-11, L-201). This minute is corrected to read as * * follows: * * * * HI-11. Acetic Acid. The committee reviewed a proposal to * revise the `Causes Severe Burns" statement on Acetic Acid, * Glacial; Acetic Acid 80%, and Acetic Anhydride. A motion to * modify the hazard statement on these labels to "Causes * Burns" was defeated. * * * * * I. "WARNING LABELS" Mr. Fuess, chairman of the revision subcommittee, reported that the subcommittee would meet following the LAPI Committee meeting for the purpose of reaching final conclusions on the content of "Warning Labels. ' He indicated L-207 that the manual will be divided into sections, which will replace the schedules comprising the present edition of the manual. It was agreed that in view of the amendments to the act covering trans portation of explosives and other dangerous articles in interstate commerce, in which the term "flammable" is employed, this term should be used consistently in "Warning Labels." (See Min. VL3). Statement of Poison Hazard. Mr. Noone inquired whether, in view of the committee's adoption of a definition of "Poison" to include the hazards of inhalation and skin absorption, LAPI labels bearing the word "Poison" should include a statement of hazard indicating the route of entry by which the product is poisonous, using the language employed in labels prepared under the require ments of the Federal Insecticide Act (i.e. "Poison. Poisonous if Swallowed" -or inhaled or absorbed). Members of the committee were of the opinion that the statements used in "Warning Labels" imply the route of entry although the wording used differs from that incorporated in labels prepared for insecticides. ACTION: On motion made, seconded and carried, it was agreed to retain in "Warning Labels" the hazard statements as now in use for industrial chemicals which will bear the word "Poison." Other action related to the definition and use of the word "Poison" included: Use of Word "Poison" and Skull and Cross Bones. ACTION: Industrial chemicals (as distinguished from insecticides) should in all cases bear the word "Poison" when the characteristics of the compound involved come within the definition of "Poison" approved by the committee for use in "Warning Labels." ACTION: When the word "Poison" is used on a label covered in "Warning Labels" the skull and cross bones shall be included. A negative vote on the latter action was registered by Mr. Low and Mr. Bartenstein. Distinctions Between Labeling for Use and Labeling for Transportation. hi connection with the-above, two viewpoints were expressed: (f) that failure to use the skull and cross bones would be in conflict with I.C.C. requirements forClass B poisons; and (2) the possibility of union demands for premium pay for the handling of chemical shipments which are marked with strong hazard warnings. Committee members stated that the labeling of chemicals intended for manufacturing uses -- as is the case with the recommended labels in "Warning Labels" -- is distinctly different from requirements for transportation. ACTION: It was agreed that this distinction should be emphasized in the introduction to "Warning Labels." Toxicological Tests. In the discussion of whether a hazard statement indicating the route of entry of a poisonous chemical should be included with the word "Poison," reference was made to the fact that in some cases the route cannot be shown because adequate toxicological data on the product have not been developed. .Li-ijUO ACTION: On motion made, seconded and carried, it was agreed that since the committee believes as a matter of principle that LAPI manual labels for poisons should indicate in the statement of hazard the route by which the chemical is poisonous, under the definition of "Poison*' adopted by the LAPI Committee, the appoint ment of a special committee is hereby authorized to report on how pertinent data may be secured to determine this information for use in future manual revisions. 1.1. Rating System for Signal Words. Mr. K napp presented a revised draft of the" rating system under whichTthe signal word for a specific product would be governed by a point rating based on the specific hazards present in the designated product. Li an application of the system to the chemicals covered by labels in Manual L-2, Mr. Knapp stated he had found 34 products in which the rating indicated a signal word different from that used in the manual. A number of these labels were reviwed in the meeting, culminating in the following ACTION: Moved, seconded and carried that Mr. Knapp send to each member of the committee two copies of the revised draft of the rating system, and that each member go over the products manufactured by his company to determine the accuracy of the ratings tentatively listed for such products, sending his comments and recommendations to Mr. Knapp not later than December 15. Changes in Rating System. Review of the ratings in the course of the I;# meeting resulted in the following changes: Category 2. Raising the point rating for flammable materials having a flash point below 80F from 15 to 25. Category 5. Raising the point rating of chemicals highly corrosive to the skin to 40, and adding the subcategory "Corrosive to Skin" with a rating of 25 points. Category 7. Adding a subcategory designated as (k) "Ethers which form explosive peroxides*' with a point rating of 20. Action on Labels in Rating System. Review of labels with respect to application of the rating system to the Hazards indicated resulted in the following conclusions: 1. Acetonylacetone. Moved, seconded and carried, that the label for this product be eliminated from Manual L -2 because it presents no appreciable hazard. 2. Antimony Trichloride. A toxicity rating of 25 was indicated for this product, together with an increase to 40 in the corrosion rating. 3. Barium Oxide. A toxicity rating of 25 points was added, giving a total rating of 30 points. 4. Butyl Alcohol (t). The flammability rating was increased to 25, giving a total rating of 50 points. 5. Butyl Catechol (t). The physical form designation was changed from (a) to (i). L-209 6. Butyl Ether (n). The flammability rating was changed from 15 to 5, giving a total rating of 40. The new subcategory (k) in Category 7 "Ethers which form explosive peroxides" was substituted for (a). Note: It was decided that the caution concerning dry ethers should be placed with the hazard statements on the label rather than at the end of the warning statements. 7. Carbon Tetrachloride and Chloroform. There was discussion concern ing an increase in the absorption rating to 25, giving a total rating which would require the signal word "Danger" but no decision was reached. It was decided that Mr. Sunderland and Mr. Low should give further study to the CTC label and to report their recommendations to a subsequent meeting. Note: Not definitely decided was the question whether two degrees of skin absorption should be given in the rating system rather than the single rating given. 8. Chlorinated Naphthalene. It was decided that the label as used in Manual L-2 covers a group rather than an individual compound, and since certain naphthalenes do require labeling, Dr. Cranch was asked to designate the particular chlorinated naphthalenes to which the label should apply, for incorporation in Manual L-2. 9. In connection with category 7 - Physical form, S pecial Properties, and Conditions of Use - Mr. Knapp suggested it might be desirable to decide on a limitation of the maximum point rating to be given. Vote of Appreciation. On motion of Mr. Douthett, the committee voiced its appreciation to Mr. Knapp for the amount of work and time contributed by him in compiling the rating system, and expressed its recognition of the value of the system in promoting more scientific and accurate designation of chemical hazards. Action on Rating System. A final decision on the inclusion of the rating system in the new '`Warning"Labels" will await the further check of its accuracy by the committee, as requested in the first action under this minute. H. MODEL STATE BILL Mr. R. F. Hansen appeared before the committee on Tuesday morning for the purpose of presenting and reviewing the draft of a proposed uniform state act governing the labeling of hazardous chemicals. This draft was supplemented by an interpretative statement describing the purposes of and need for the act. Following a detailed review, during which suggestions for revision were advanced, Mr. Hansen stated that he would revise the act to meet the objections raised, and would enlarge the interpretative statement to set forth more specifically what the act is intended to accomplish, after which the text will be cleared with the Legal Advisory Committee. The LAPI Committee approved the act, with the revisions recommended by the members, and also the interpretative statement, and concluded with the following L-210 ACTION: Moved, seconded and carried that the model Uniform State Act Governing the Labeling of Hazardous Chemicals, as approved by the LAPI Committee, and after clearance by the Legal Advisory Committee, be presented to the Board of Directors of the M.C.A. with the recommendation that the Legal Advisory Committee, or other appropriate committee, be instructed to present this act, with a view to enactment, to appropriate members or officials of those state legislatures which have shown particular interest in a precautionary labeling program. The motion was opposed by four members of the committee because they were of the view that the proposed act should be used only when state legislation became imminent and not on an indication of interest in precautionary labeling. The majority affirmative action was based on the view that more constructive results can be obtained if the approach made to states is related to a desire to assist in securing sound and workable proposals. In this connection, it was pointed out that while some state regulations have designated the M.C.A. "Warning Labels" as providing labels meeting the requirements for precautionary labeling, such designation is of doubtful constitutionality. Vote of Appreciation. The committee unanimously expressed to Mr. HSrfsen its appreciation and gratitude for his constructive contribution in developing the model act, and congratulated him on the high standard of accomplishment reflected in its compilation. IH. LABELS EH.l. Acetic Acid and Acetic Anhydride, Attention was called to an error in the minutes of the September meeting in reporting action taken on a proposal to revise the "Causes Severe Burns" statement on Acetic Acid, Glacial; Acetic Acid 80%, and Acetic Anhydride. Accordingly this minute is revised to read as follows: "The committee reviewed a proposal to revise the "Causes Severe Burns" statement on Acetic Acid, Glacial; Acetic Acid 80%, and Acetic Anhydride. A motion to modify the hazard statement on these labels to "Causes Burns" was defeated. I.C.C. Requirements. The committee reviewed correspondence dealing with the LC .C. requirement for a corrosive liquid label on shipments of acetic acid 80% and acetic anhydride, together with reports that such regulation should not be prescribed, considered on the basis of plant and shipping experi ence over a period of many years, and on the basis of results of a toxicological study of the effects of these products when in contact with skin. Correspondence presented stated that the I.C.C. requirement stems from the warning statements appearing in Manual L -2, and that the regulatory agencies cannot permit a chemical designated as dangerous and causing severe burns to be shipped so marked without at the same time requiring the I.C.C. corrosive liquids label. ACTION: Moved, seconded and carried, that after further consider ation it is concluded that there is insufficient information at hand to adequately decide whether or not the signal word and statement ' of hazard on labels for glacial acetic, and acetic anhydride should be revised. L-211 1 Mr. Minteer suggested that further,study be made of these labels, and r it was agreed that an effort would be m$de to develop additional information jjf before the next meeting of the committee. Mr. Sunderland said that he would $ forward to the Washington office, for transmittal to the committee, the results '.! of tests on rabbits with Acetic Acid 80% and Acetic Anhydride. 3h discussion of this subject, the distinction between transportation hazards and hazards to humans in contact with a dangerous chemical was again , emphasized. I" Subject continued on docket. IU.2. Hydrogen Sulfide. The following label for Hydrogen S ulfide, as recommended by a subcommittee composed of Messrs. Knapp, Coey, and Pfann, , was unanimously approved: HYDROGEN SULFIDE danger/ POISON> Cl!qu$AND gas under pressure FLAMMABLE Before using, read M.C.A. Chemical Safety Data Sheet No. Do not breathe gas. Keep away from heat and open flame -- May form explosive mixture with air. NOTE: This gas deadens the sense of smell. Do not depend on odor to detect presence of gas. POISON First Aid Treatment Carry patient to fresh air. If patient has stopped breathing, apply artificial respiration immediately. Keep patient warm. Call physician. HE.3. Insecticide Labeling. Mr. N oone reported progress toward completioh of the caution labels tor insecticides, particularly with reference to : clearance by the Committee on Toxicity and Antidotes, Association of Economic -Poisons Control Officials. 1 . The committee agreed that the subcommittee should proceed in developing . : with Mr. Ward its suggestions relating to supplementary statements for especJ- lally hazardous products, and the inclusion of such additional information in idirections for use. Article on Federal Economic Poison Act. Mr. Bartenstein was commend - ji ed for his comprehensive and constructive article on the Federal Act, sent to -fe members of the committee on October 25. iftl '! NAHDM. Reference was made to a letter sent to its members by the ational Association of Insecticide and Disinfectant Manufacturers, in which the L-212 I association submitted a list of caution and warning statements for insecticide ' labels based on preliminary reports of the Committee on Toxicity and Antidotes, Association of Economic Poisons Control Officials. It was considered that such promulgation was premature, in view of the tentative status of this matter, and informally suggested that our views on the subject should be transmitted to the NAIDM. m.4. Paradichlorbenzene. Reference was made to an article appearing in the DRUG TRADE NEWS to the effect that paradichlorbenzene is safe to use as a mothicide, on the basis of studies made by a graduate student and professor of Purdue University. Dr. Coey, who transmitted the inform ation, indicated that he had written for a copy of the report on which the state y. ment is based. Continued on docket. HI. 5. Phosphorus - Container Handling and Storage Sections. It was agreed that container "handling and storage provisions for Phosphorus oxychloride ;> and Phosphorus Pentachloride should be considered in connection with the pro; posed section on container handling to be prepared by M.F. Crass, Jr., Assistant ^ Secretary, M.C.A., for inclusion in "Warning Labels" as a part of the section :';v on "General Principles." Any comments which may result from this draft, '/: when completed, will then be referred to Mr. Crass for coordination. j?;,, m. 6. Phosphorus Trichloride. The committee accepted Mr. vf.Minteer's recommendation that the original label for Phosphorus Trichloride, 21; approved by the committee at its September meeting (LAPI Min. m-lla., L-201) i:;. be reaffirmed. He stated that additional tests did not sustain the statements If hi the alternate label presented to the committee following the meeting. m.7. Volatile Solvent - Deletion from M.C.A. Manual. In accordance -with action taken at the September' meeting7Dr. Cranch presented a report indicating labels from which the words "Volatile Solvent" should be eliminated, and in some instances substituting phrases to take the place of the deleted words. I In considering the status of labels where elimination of the words Volatile Solvent" left only the signal word and precautionary statements, the committee took the following |. ACTION: Moved, seconded and carried that when the elimination I of the words "Volatile Solvent" from a label leaves no statement i of hazard, such label shall carry only the signal word and the t remaining precautionary statements; and further, that the W introduction to "Warning Labels" be revised to provide that where the hazard of a product is not significant the signal word may be used without a hazard statement. ' Four negative votes were recorded against using only the signal word under these circumstances, on the ground that such use is contrary to the requirements of "Warning Labels" and also that recommended label warnings should be eUminated entirely for products where the hazards of use and handling are of a minor or insignificant character. It was agreed that the action of the committee on this subject should % be relayed to Mr. Hansen so that he may take cognizance of it in the re-writing f. of the model state labeling act. Action on Individual Labels. '$ were deleted from ttie following labels: The words "Volatile Solvent' Amyl Acetate (identity to be clarified) Butyl Acetate (normal) Butyl Alcohol (normal and secondary) Carbon Tetrachloride Chloroform Dichloroethylene Dioxane. Hazard statement * 'Vapor Harmful" substituted. Dry ethers statement transposed to hazard statement position. Methyl Isopropyl Ketone Petroleum Naphthas and Solvents (Flash point above 80) Trichloroethylene. "Vapor Harmfull" substituted. Tetrachloroethane. "Volatile Liquid" eliminated. Aromatic Industrial Solvent (Flash point above 80). Butyl Ether (normal). Caution on dry ethers placed in hazard statement position. Dichloroethyl Ether Ethyl Acetate Ethylene Dichloride Ethylene Glycol Monomethyl Ether "Vapor Harmful" substituted. Methyl n-Amyl Ketone Methyl Ethyl Ketone Isopropyl Acetate Tetrachloroethylene. "Vapor Harm ful" substituted. Amendment of Surgeon General's Agreements. In connection with the fact that elimination of the words ,l Volatile solvent" would require amendment of the Surgeon General's agreements, Dr. C ranch suggested that the agreements had outworn their use, and recommended that they be discontinued. He referred specifically to the agreement on Methanol, and asked that a committee be authorize." to confer with Dr. Townsend to secure his reaction to a suggested letter which, upon agreement of the Surgeon General's office, would be sent to manufacturers of Methanol notifying them of discontinuance of that particular agreement. He indicated that similar action to disctoninue agreements covering other products could be taken at a future time. ACTION: Moved, seconded and carried, that Dr. C ranch and Mr. Hill confer with Dr. Townsend on the matter of discontinu ing the Surgeon General's Agreement on Methanol. Dr. Cranch later reported that he and Mr. Hill had conferred with Dr. Townsend on the matter and that while Dr. Townsend was not opposed to jabandonment of the agreement, he was hesitant as to how soon the discontinuance 'should take place. Dr. Cranch stated that it had been concluded he should write a letter to Dr. Townsend stating the circumstances and explaining the reasons for the recommendation, in order that the latter might submit the question formal ly to the Chemical Products Agreements Committee. m. 8. Warning Statement. Mr. Low presented a report in which he recommended: 1. A suitable note should be included in the new "Warning Labels" stating that label admonitions regarding contaminated clothing should be understood to mean shoes if they were contaminated, but that special mention of shoes on the label would be reserved for a few commodities where leather was known to be easily satur ated and very retentive of these special compounds. 2. The use of one of two types of warning statement: (a) a statement emphasizing flushing of skin or eyes; and (b) a statement placing emphasis on removal of contaminated clothing. i'l 3. A specific warning to be attached to individual products. L-214 In discussion with reference to the statement emphasizing removal of contaminated clothing, the view was expressed that in the case of clothing . saturated with a hazardous chemical, a warning concerning flushing of the skin should be given equal value with the warning to remove contaminated clothing. To meet this condition, the committee adopted the following langugage for a warning statement to be used on the labels indicated: "In case of contact, immediately remove all contaminated clothing and flush skin or eyes with plenty of water for at least 15 minutes; for eyes, get medical attention, wash clothing before reuse." Allyl Alcohol Ethylene Chlorhydrin M-Toluidine Antimony Trichloride Perchloric Acid Solution Hexaethyl Tetraphosphate Tetraethyl Pyrophosphate In the case of the following products, the committee agreed that the additional statement "including shoes'" should be inserted after the word "clothing": Aniline Ethylene Dibromide Methyl Bromide Arsenic Trichloride Cresol Phenol Bromine The following warning statement was agreed to for the products inv dicated below: "In case of contact, immediately flush skin or eyes with plenty of water for at least 15 minutes; for eyes get medical attention. Wash clothing before reuse." Ammonium Bichromate Sodium Dichromate Chromic Acid m-Nitroaniline. In the case of Aqueous Hydrofluoric Acid it was decided to retain the contact statement in the recently revised version of this label (LAPI Sept, meeting), and as to the following products it was decided that current warnings fare adequate: o-Anisidine, Benzidine, Benzoyl Chloride, Benzyl Chloride, Coal Tar Creosote, Phosphorus Oxychloride, Sulfur Chloride, and Dichlorophenol. IV. LABEL ADHESIVES Messrs. Sunderland and Low were added to the subcommittee of Mr. Minteer and Mr. Coey for the purpose of drawing up specifications for fadhesives in cooperation with a technical committee on the subject. V. DEFINITION OF CLASS B POISONS It was reported that the proposed definition of Class B poisons had ;been submitted to M.C.A. Technical Committees, and that returns being received ^indicated approval of the definition. This definition will give weight to experience -factors, making it possible to secure exemption from the regulations for products -which on the basis of experience and tests are proved not to create extraordinary hazards in transportation. L-215 Mr. Fuess suggested that some means should be provided whereby the results of tests covering specific products may be publicized and made available to those concerned in order to avoid duplication of effort. It was the opinion, of members of the committee that such results would be made available through the Bureau of Explosives, and through the recommendations of the committee to be appointed under Minute I, Toxicological Tests. Subject continued on docket. VI. MISCELLANEOUS VI.1. Los Angeles Hearings - Oxidizing Materials. Reference was made to the fact tnat the M.C .A." had tiled" a brief October 14 with the Los Angeles Fire Department on proposed regulations for Oxidizing Materials. Copies of the brief were transmitted to members of the committee. VI.2. Reagent Labeling. Mr. Fuess referred to a letter sent by Secretary Watson to the Reagent Labeling Subcommittee in which he reported on I; his conference with Mr. G. R. Kuhn of the Federal Interdepartmental Safety S< Council concerning the chemical properties chart on which the subcommittee was !> asked to prepare recommendations. It was decided to continue this subject on the docket on the basis of information in Mr. Watson's letter to the effect that Mr. Kuhn is to report on the suggestion that the Interagency committee give consideration to the utility of M.C.A. labels for both laboratory and warehouse containers. VL3. N.Y. Fire Dept. Labeling Requirements. Reference was made to i;i, the inflexible requirements of the New York Fire Department for special labels 5 ' on flammable and combustible mixtures, and in particular the use of the word "Inflammable." Members of the committee reported that while they had attempted to secure a more flexible formula, no tangible results had been obtained. In this connection it was felt that the enactment by the 80th Congress .of amendments to the act covering transportation in interstate commerce of exI ' plosives and other dangerous articles might be helpful in securing a change of attitude on the New York ordinance. %' . The enactment referred to concerns amendment of the U.S. Criminal Code, and the law as revised in the closing days of the 80th Congress (Public ;;Law 772) provides, among other things, for continuing recognition of the Bureau | of Explosives as advisory agency to the I.C.C., and employs the word "flammable" | vi.n place of the previously used "inflammable." Background: Explosives and other dangerous articles are transported ffin Interstate Commerce under provisions*of the U.S. Criminal Code. During the j|79th Congress a special committee on revision of the laws was appointed to ^completely revise and modernize the Federal criminal statutes. During revision %pf that portion of the statutes comprising the transportation of explosives act, " the provision which officially recognized the Bureau of Explosives as the advisory agency to the I.C.C. was deleted. The M.C .A., together with other interested organizations made representations to the committee and succeeded in reinserting the provision relating to the Bureau. In company with the American Petroleum Institute, it was decided also to recommend a change in the term "Inflammable" to "Flammable" L-216 inasmuch as the latter term had been previously adopted as standard by recognized agencies such as the National Fire Protection Association, etc. The above recommendations were accepted by the committee and were incorporated in the final copy of the bill which was reintroduced in the 80th Congress and ultimately passed during the session's closing days. H.R.2200 was the original bill, later changed to H.R.3190. VI.4. Calif. Fire Marshals Code. Mr. Noone referred to a provision in the Fire Marshals Code for California which requires that solvents offered for sale at retail, having a flash point below 120F, closed cup test, shall have on the container label words indicating that the solvent is flammable. It was agreed to solicit the-assistance of the California Division of Industrial Safety with a view to securing uniformity between the labeling require ments of the Division and those of the Code. VI.5. Carbon Tetrachloride Labeling - Calif. Board of Pharmacy. Mr. Sparre referred to a resolution of San Francisco officials memorializing the Calif. State Board of Pharmacy to take emergency action requiring that all Carbon Tetrachloride be labeled "Poison." A committee consisting of Messrs. Sparre, Sunderland, and Cranch was appointed to draft a letter to L.M. Walsh of the California Pharmacy Board, for presentation to the city officials, recom mending the CTC label incorporated in "Warning Labels" and adopted by the Calif. Div. of Industrial Safety, as appropriate labeling for this product. It was agreed, after further discussion of questions raised in connec tion with the proper signal word and warning statements for CTC as a result of application of the rating system (Min. 1.1) that the label to be recommended to the Calif. Pharmacy Board should be the current label from which the words "Volatile Solvent" have been deleted. (Letters sent attached as Attachment "A"). VI.6. Alkali Detergents. Mr. H ill raised a question concerning the labeing of Alkali Detergents, and it was agreed that Mr. Hill and Mr. Noone should confer on the matter and report their conclusions. VL7. M.C.A. Labeling Program - Public Education in. Mr. Sparre raised the question whether action could not be taken constructively to combat unreasonable demands in the area of chemical labeling -- both from the stand point of state regulatory bodies and labor unions, whose members have recently demanded premium pay for handling chemicals marked hazardous -- through a program of education of the purposes and objectives of M.C.A. labeling and other safety activities. It was RESOLVED: That the Board of Directors of the M.C.A. be asked to consider the initiation of an educational program to secure wider public understanding of the safety work of the association, particularly in the field of adequate labeling, such program to be directed to private safety organizations, public officials, and labor leaders. Seconded by Mr. Coey and carried. VI. 8. Next Meeting It was agreed that the next meeting of the com mittee should be held at the Hotel New Yorker, N.Y.C., Tuesday and Wednesday, Feb.8 and 9, 1949. L-217 Later: Hotel New Yorker advised of arrangements on November 18, VH. ADJOURNMENT There being no further business, the meeting adjourned on Tuesday, fjovember 16, 1948, at 5 P.M. J. T. Puess Acting Chairman Minutes subject to approval. ATTACHMENT A Letters to Calif. State Board of Pharmacy on labeling of Carbon Tetrachloride: (Covering Letter) November 23, 1948 Mr. L. M. Walsh, Secretary State Board of Pharmacy 313 Joslin Bldg., 507 Polk Street San Francisco, Calif. Dear Mr. Walsh: At a meeting of our M.C.A. Labels and Precautionary Information Committee last week, a review of the carbon tetrachloride labeling problem was given by Dr. A. G. Cranch of Carbide & Carbon Chemicals Corporation, Mr. F. D. Sparre of the duPont Company (both of whom visited you in your office recently), and Mr. W. W. Sunderland of the Dow Chemical Company. 8 As a result of that presentation, the attached recommendation was approved by the LAPI Committee, and affirmed by the M.C.A., for transmittal to the California State Board of Pharmacy. We shall appreciate your views and comments on the recommendation. /s/ M. F. Crass, Jr., Asst. Secy. (Letter of Recommendation) Mr. L. M. Walsh, Secretary (Same address as above letter) November 23, 1948 Dear Mr. Walsh: Newspaper items and verbal reports have brought to our attention recent disabilities and fatalities in California resulting from the misuse of carbon tetrachloride. This naturally prompted a review of the labeling of con tainers of this chemicals it >{ i L-218 Some time ago, the Labels and Precautionary Information Committee of this association, in cooperation with the producers of carbon tetrachloride, developed the following label statement for this chemical: WARNING./ VOLATILE SOLVENT VAPOR HARMFUL Use with adequate ventilation. Avoid prolonged or repeated breathing of vapor. Avoid prolonged or repeated contact with skin. Do not take internally. The name "carbon tetrachloride," with or without a trade name, is stencilled or otherwise separately shown on the package when not included in the warning notice. The Surgeon General of the United States approved this label as an adequate replacement for similar requirements in the original Surgeon General's Agreement. This label appears in the current editions of the "Labeling Orders" of the California Division of Industrial Safety, and the M.C.A. manual "Warning Labels," and it is our understanding that all producers of carbon tetrachloride are using it. I also enclose a copy of M.C.A. Chemical Safety Data Sheet SD-3 on carbon tetrachloride, which gives the properties of this chemical and essential information for safe handling and use. The Surgeon General, the California Division of Industrial Safety, and the M.C.A. all recommend, in addition to the warning notice, that the label on a container of.a-hazardous material include a qualitative statement of chemical identification of those ingredients imparting hazardous characteristics to the material in those cases where the trade name is not sufficiently descriptive of such content. The M.C.A. label committee is currently engaged in preparing a re vision of the label manual for publication in the not too distant future. One of the items under discussion concerns the elimination of the phrase "Volatile Solvent" from the labels for carbon tetrachloride and similar chemicals. This discussion was undertaken because it is believed that the phrase conveys no particular meaning to the ordinary user and serves no useful purpose in a warning statement because volatility and solvent action are not in themselves hazardous characteris tics. In addition, the use of the word "solvent" is considered misleading, as these chemicals are solvents for only a limited number of materials. Therefore, since the phrase "Volatile Solvent" does not describe a health hazard and the label already contains the phrase "Vapor Harmful," which clearly indicates the hazardous nature of this chemical, it is concluded that we are justified in recom mending the following revision to the carbon tetrachloride label. WARNING/ VAPOR HARMFUL Use with adequate ventilation. Avoid prolonged or repeated breathing of vapor. Avoid prolonged or repeated contact with skin. Do not take internally. L-219 iiUHa, vision of Industrial Safety and it is our understanding that this D ivision has jen considering this question for some time. It should be emphasized that the M.C.A. program in regard to precaution--y labeling for hazardous chemicals includes a strong stand against the indiscrimZg,te use of the word "Poison" as a means of warning users against any and all vizards. The actual hazards inherent in a given chemical should be clearly pointed out on the container label through the use of an appropriate signal word, Statement of hazards, precautionary information, and instructions, if necessary, in case of accident. The addition of the word "Poison" to the above labels might serve only to reduce the over-all effectiveness of the word in Its proper field. The word does not accurately describe the hazards connected with the use of carbon tetrachloride and might therefore conceivably lull the user into a flase sense of security. vVe all realize that unfortunately there are those who do not heed posted warnings and will therefore take no steps to protect themselves from danger in spite of the best possible precautionary labeling. However, we must continue our efforts to provide all users of chemicals with adequate information. All the' labeling appears Such labeling is also recommended, in addition to other statements which may he advisable due to. the presence of other hazardous constituents, for products containing this chemical in significant amounts. Copies of representative labels currently used for this chemical are enclosed for your information. As discussed above, future revisio ns are expected to exclude the term "Volatile Solvent." Since we are familiar with the interest of the California Division of Industrial S afety in precautionary labeling, we are taking the liberty of sending a copy of this letter to Mr. Horswill of that Division. We believe this to be particularly important in view of the existence of label #29 "Carbon Tetrachloride" published in Article 85 - "Labeling of Injurious Substances" issued by the Division. /s/ Manufacturing Chemists' Assn., Inc. M.F.Crass, Jr. Assistant Secretary. (Minutes mailed Friday, November 26) ' *<? vaK.- '*s -M