Document Lp4857a7Q99rBDQ3azOzB6RJQ

^Caiimutl jjfcrhii, JJaniisIf auir JCarquci* (Association OFFICER* PRESIDENT--ERNEST T. TRIGG. Wasnihctor INCORPORATED 220t NEW YORK AVE. N.W., WASHINGTON, D. C. VICE-MCSfOCNT--FRANK L. SUL2RERGER. Cmicar# TREASURER--*. t. NATLACK. PHMURtLFWIA OFFICE OF THE PRESIDENT SEIRETART--RCUEL W. ELTON. Waihirctor CCLNSCL--M. 0. MACOONAlO. WiSMiftCTOR July 18, 1939 TO CLASS A !.'LM5ER5i CONFIDENTIAL Not for Publication REGIONAL VICE PS r f Tl STS mcv cc,_ajm*--waft l. Rite. rr*ci tASTCIR--~0. M LITTER. "CW r:m lOUTRttR----- c. P K ( LLT LCL'JV.LLt ci*tr*l--aiLtoa c p:ic. c-i:*co f hk Mi.; DIVISIONAL V I c F : : TINT MMOLtfALC OIV'I'OA--L. I. *C*U ' IC Toxic matsrials with their ever-present problems require our conscientious con sideration of the fundamental principles involved. Tine Nsticr.al Faint, Varnish and Lacquer Association is keenly interested in providing Class A members with a much information on this subject as is practicable at this time. This in formation being confidential is not intended for general publication, - it is. being sent only to the Class A group. Please respect this confidence. The vitnl factor concerning toxic ..materials is to intelligently safeguard the public. People may feel safer in buying materials whose danger they know rather than materials unknown to them. We trust the several phases presented herein will bo of some benefit to members in applying every precautionary measure in .manufacturing, in selling and in use where toxic materials are likely to or ao enter a product. . Toxics and their effects is a subject very broad in scope and can only briefly bt* treated in this message. ' Children's toys, equipment, furniture, etc. are not tne only consideration. Toxics - ,.u:ny compounds used in paints or lacquers may have harmful effects if carelessly handled. . Toxic materials may enter the body through the lungs in the fora of dust, vapors, or gases, through the skin, or through the mouth and stomach. I'.r.tcrial inhaled into the nose and mouth can dissolve in the saliva and be sv/allovsd. Irritant materials may also hove a direct action upon tno skin and the mucous membranes of the. eyes,nose, mouth, and threat. It must be remembered that all people do not react in the same way when exposed to chemicals. Some may be quite seriously affected by quantities which are harmless to others. Hence, it follows that any one using print and allied prod ucts should provide adequate ventilation and should observe ordinary sanitary measures such as the washing of the hands and face before eating and keeping the clothes clean. Dirty ?/ork clothes, including sho.s, can be an important source of skin absorption. Some of the ingredients of prints end allied products might receive special mention because of their specific effects, rather than because they merely displace part of the air or cause slight discomfort if taken into the stomach or system. /\ The following pigments muy be considered ns toxic if they find their way into ^ stomich. Thu :mount tolerated by the body varies with the pigment. ^ Antimony. Antimony oxide, Naples yellow, or other untioo-.jy oi (Antimony is supposed to be considerably lc-ss toxic than lead. N C A 0 02 9 01 2/ - - there is much evidence to indicate t'.iat it is a toxic material.) ,'.any cases of suspected antimony poisoning have been traced to the accompanying lead. /.raenic Cor,pounds. Paris groan or other compounds containing arsenic. C;yv.oriL:. C-diciuni sulfides and selcriJos ore toxic, but belong to the i: '.cor used pigments. Car '"u-rn:. Chro.~o.tas of all tyros ora understood to be rc-iati .-c ly toxic. Cl.rorj.ur. oxides ore relatively non-toxic. Lc-.d Compounds, Wnite teed, red iead, iitnc.rge, lead chromates (ch.rcc.e yeilc'A', chrome green), or other lend pigments. F'errury. Red and yellow oxides of mercury or other products containing r.ers.ury. - Liquids - Alcohols. The toxicity of methyl alcohol is very r;eil xrown. As used in lacquers, the other alcohols are relatively harmless. jc-ncol. This is probably tnr. most dangerous cf all commercial solve;.ts, but its use in our industry is probably restricted to certain paint and vernish recovers. Chlorinated Hydrocarbons. Carbon tc. trichloride, trichlor ethylene, twtrr.ciilorethane, uthyle.ie uicliloride, und similar chlorinated ali phatic hydrocarbons are said to be very C iigerous tones. Chlcrjuioted rnui.tic hyuroc .rbor.a ; ro s~id to be icsr toxic th n the corrcr.t.onei..g 'yurocurbon it so If, but some chlorinated area tics are frequently tne sour of ckin troubles. Lmccuer Solvents. There is seme evidence that the acetates--ethyl, butyl und amyl--ere more cr less toxic. Acetone and tai ether ketones are relatively hrrmless. Me at other solvents used to a lessor extent are either harmless in them selves, are used in such relatively sacli amounts, or arc sc slowly' evaporating that they present no hazard. Methyl Alcohol. The use of this product should be avoided. It is cefinitc-ly poisonous. Solvent Naphtha. This is also relatively non-texic as compared to benzol, ana probably less toxic than toluol and xylol. Tuiucl end Xylol. In equal concentrations, these arc said to be mere f toxic than benzol, but because they are less volatile the actual V hazard is usually less. 1 NC 0 02902 3/ -- Tricresvl Phosphates. The para- and netc-tricresyl phosphates which are used as plasticizers are non-toxic. Orthc-tricresyl phosphate, on the other hand, ie. a violent poison. Turnentina and Mineral Spirits. These products are relatively non-toxic but are still listed in works on toxicology as causing eczema and irri tation of the skin and raucous membranes. Some people exposed to the fumes are subject to internal disorders when breathing substantial amounts of turpentine. Mineral spirits is less toxic than turpentine. Other rissticisers. Very little is known regarding the toxicity of other c.-mmon so-called chemical plasticizers, but the hazard from volatility or dust is, of course, small. The nain consideration, whenever paint products are used, is constant repetition to the paint consumer of the necessity of employing adequate ventilation and maintaining personal hygiene. Printed Matter - Color cards and advertising literature should not in clude any reference by the use of words or sketches to indicate or, receranend a product for children's toys, equipment, furniture, etc., unless it is absolutely free from toxic materials. Non-Foiscnous Colors - It is generally conceded there is relatively little danger of toxic effect from paints on toys and nursery furniture, as both the paint manufacturer and the toy manufacturer are familiar with the types of non-poisenous pigments to use. Nevertheless, the individual company should constantly guard against using any toxic material, especially lead compounds, in products for finishing children's toys, etc. Note: (See page #7 of "Odds and Ends", a special circular of the Scientific Section National Paint, Varnish and Lacquer Association, issued August 1938.) Grown-ups are exposed to some hazards as in the case of children. There fore products for finishing pencils, and other articles that may be placed in the mouth, through habit, require the use of toxic-free materials. Labeling - No definite procedure is recommended for labeling. Labeling is serious since it becomes a public matter with the question as to what would result if this were done. Each manufacturer can ably cope with the toxic material situation by constantly safeguarding the public through the prod ucts he manufactures and by the repetition of Instructions to salesmen, service men and others who can intelligently instruct the consumer of the advantages of providing adequate ventilation and of maintaining personal hygiene. General - The statement of legal principles listed below was prepared for and distributed by the Manufacturing Chemists' Association for the guidance of its members concerned nith labeling problems, and is supported by decisions of the courts. Although the principles set forth are not entirely the result of litigation involving material used by members of our industry they are nevertheless generally applicable to situations arising from the us5 of harmful substances. N C A 0 02903 / -4- Manufacturing Chemists* Association Legal Principles 1. A manufacturer who puts out c dangerous article or substance without accompanying- it with u warning aa to its dangerous properties is ordi narily liable for any damage which results free: such failure tc warn. 2. A manufacturer or dealer who erroneously labels a dangerous drug with the name of a harmless substance is liable for any injury which nay be caused thereby. 3. Failure to comply with e statute, e.g., with respect tc labeling poisons, is usually held tc be negligence par se or ct least evidence of negligence. 4. The name of the product alone may be stifficient warning, if its na ture is very widely knewn or its sale is restricted to those who arc prusvjoed tc know its nature, but even in such cases the advisability of a specific warning is indicated. 5. Technical accuracy may not be sufficient protection for the manufac turer if ha uss words which may give the purchaser the impression that his product is not .vhat it actually is. 6. A nonwarranty of results is not a warning against possible dangerous results. 7. The consumer is entitled to rely on positive representations or di rections appearing on the label unless he knows them to be incorrect. 8. The manufacturer is ordinarily not liable if his product is put tc a use for which it is not intended ana an injury results which cculd net reasonably have been foreseen. I-t is often difficult, however, to knew whether a particular result should have been foreseen, and the courts are apt to differ on this point. 9. The manufacturer or one who holds himself out tc be the manufacturer must know the qualities of his product and he cannot escape liability on the ground that he did not know it to be dangerous. 10. The general rule that a. manufacturer is not liable to those not in privity of contract with him doas not apply when his product is immi nently or inherently dangerous. Ccnclusion - Ke grant that this is a very broad subject, and doubt if a ccncis: set cf rales can be established, nevertheless, it may be salct that our members can meet their individual problems in safeguarding the public, including of course our own factory employees, by their sincere effort in taking advantage of every possible precaution in the use of toxic materials in manufacturing, selling and in use* Such precautions plus constant repetition of intelligent instructions will, it is $1 1 Q G 2 9- Q 4