Document MJ7EKEX72vL6MqDr1M1vjGMzx

FILE NAME: DuPont (DUP) DATE: 1939 July 18 DOC#: DUP188 DOCUMENT DESCRIPTION: NPVLA Confidential Memo to Class A Members RE Toxic Materials ^famtal p i m t , Jfitnttslf mift JCarq u c r Vssnriatiuii oinctM .UIBCWT--It f t U T 1, T il . * u n t T N INCOWWOWATKQ 2201 NEW YORK AV N.W.. WASMINOTON, O.C. v ie iM u iB X ir t -- ** V. H U t m n , c .t u . I I U V i l l I M . . IU T U C S . T n u t n m u o m e t or THt ructicNT u: n m -- tutu. h.to*.w>nntM iim-. g Maeooftait.*u<iMt July 18, 1939 TO CLASP A :.T.g35: confidential Not for Publication ttC io N a i v ic t -a a t'tNT r frak-- ai l ut.*4-, i iittti, via t: h , t lu ,, Mu;-- un i >i.i,,., a M taTit li t m i; t*i divisional vitt.:i-::sr Him utii'ii^. g,iian tuf To:ic r.itjrlals with their ever-present problems require our conscientious con sideration of the fundamental principles involved. The National Faint, Vsrr.ssh Lacquer Association is keenly interested in providing Class A .msnberc with .'.a muon inforr^ition on this subject as is practicable at this tire. This information being confidential is not intended for general publication, - it is being sent only to the Class A group. Please respect this confidence. The vital factor concerning toxic ..ateriols is to intelligently safaguaro the public. People ray feel safer in buying materials whose danger they know rnth.-r than r.cterials unknown to thea. We trust the several phases presented herein will be of some benefit to centers in applying every precautioriary erasure in .manufacturing, in selling and in use *htru toxic materials are likely to or ao enter a prod-ict. Toxics end their effects is a subject very broad in scope and can-only briefly be trented in this message. Children's toys, equipment, furniture, etc. are not the only consideration. Toxics - ..i.ny compounds used in 'paints or lacquers nay have harmful effects if carelessly handled. Toxic materials may enter the body through the lungs in the foru of dust, mist, vepors, or gases, through the skin, or through the nouth c-nd stomach, oatcrial inhaled into the nose and couth can dissolve in the saliva and be swallowed. irritant materials uay clso tuve a direct action upon tno skin end the mucous membranes of the. eyes,nose, mouth,and threat. It must be reseabered that all people do not react in the suae way when exposed to chemicals. Some may ha quite seriously affected by quantities which are harmless to others. Hcncc, it follows that any one using point and allied prod ucts should provide adequate ventilation and should observe ordinary sanitary mcesuros such as the washing of the hands and face before eating and keeping the clothes clean. Dirty work clothes, including shout, can bo an important source of skin absorption. Some of the ingredients of paints and allied products night receive special mention because of their specific effects, rathor than because they merely displace part of the air or ccuae slight discomfort If taken into the stomach or system. The ^,-v*tts *v-.'-W Mfeowa% w* following pigments may be considered ns toxic if thsy find their way stomach. The .'.mount tolerated by the body varies with the pigfasnt. Ar.tiuony. Anticony cxido, Hcplcs yellow, or other ontlooiiy ccag (Antimony is supposed to be considerably loss toxic than lead into NCA 0 02901 N 68 / - 2- thre is touch evidence tv indicata that it it a toxic actarial.) any cases of suspected antimony poiiorur.'g have been trr.ced to the Accompanying Ic/.d. Arsenic .Ccrapounda. Paris green or other coupounds cont-ciring arsenic. C : - v C..-.UK sulfidss raid sdeniJcs ore toxic, but belong to tns iz >zer u;ec pigments. Chr-j.'-.z , Chro.-.it*s of all types aro oncerstood te be re-iat.'cly texic. Chromium oxides -re rel:.tively r.or.-toxic.' U-.ti Con.-'Qunag. Wuite lerd, red iead, iitnrxge, load chromates (chrome ycilcw, chrome green), or other leed pigments. r*er:ury. Red or.d yellow oxides of esreury or other producto ccntciaar.g r.ers.urys - Liquids - Alcohols. The toxicity of ntthyl alcohol is very well rom. as used in~li*cquers, tha other alcohols are relatively hr.raless. on p i Tris is probably tnr. aost dangerous of all cusnwsial solvents, but its use ir. our industry is ,-rohably restricted to curtain paint end vemish recovers. Chlorinated Hydrocarbons. Carbon titrichloride, trichlor ethylene, tcUvxhlorotlv.me, uthylc.ie uicid.oride, mnd similar chlorlnnted rliph .tic hydrocarbons are said to be very d ai^urouc tones. Chlornu-ted roi_tic liyu.-oc .rbor.a -ro rid to oc -err tcxic t i n t;.c coricr.J.onuj-.g ''yurocarbon it coif, but some chlorinited cxoa.tics are frequently tne source of rkin troubles, Lccc.uer Solvents. There is some evidence that the acotntos-- vthjrl, butyl and cayl-- arc more cr less tcxic. Acetone pjr.d tho ether ketones /.re relatively hcralesa, Hcrft other solvunts used to a l*.ssr extent are either harmless in themselves, ere used in such relatively smell amounts, or arc sc slowly evaporating that they present no hazard. ?ethyl Alcohol. The use of this product should be avoided. It is Definitely poisonous. Solvent B,aphtha. This is also relatively ncc-toxic as compared to benacl, cad probably less toxic than toluol fend xylol. Tuluci and Xylol. In equal concentrations, these aru s&iu tv be oore tcxic than benzol, but because they <u*e less volatile tie actual hazard is usuclly less. NCA 0 02902 / TricresYL Phosphates. The para- and seta-tr-icreayl phosphates which are used as plasticizers are non-toxic. Ortho-trieresyl phosphate, on the other hand, ie* a violent poison. Turpentine and i*Inara! Spirits. These products are relatively non-toxic but are still listed ia works on toxicology ks causing eczema and irri tation of the skin and mucous membranes. Some people exposed to the fazes are subject to internal disorders when breathing substantial cr.-z-^r.ts of turpentine. Mir.srnl spirits is less tcxic than turpentine. her rlhstlcizcrs. Very little is known regarding the toxicity of other c.-znon so-called chemical plasticizers, but the hazard frca volatility or dust ia, of course, snail. ?ne main ccnc-LJa-ration, whenever paint products ore used, is constant repetition to the paint consumer of the necessity of employing adequate ventilation and maintaining personal hygiene. Printed "atter - Color cards and advertising literature should not in clude any reference by the use of words or sketches to Indicate or rcccanend a product for children's toys, equipment, furniture, etc., unlessit is absolutely free frca toxic anterials. Non-Foiscnous Colors - It is generally cancoded there is relatively little danger of toxic effect from paints on toys and nursery furniture, as bath the paint manufacturer ani the toy manufacturer arc familiar with the types of non-poisenous pigments to use. Nevertheless, the individual coapany 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 end Ends", a special circular of the Scientific Section Notional Paint, Varnish and Lacquer Association, issued August 1938.) Grcwn-ups arc exposed to some hazards as in the case of children. There fore products for finishing pencils, and other articles that aay be placod in the mouth, through habit, require the use of toxic-free naterials. 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 ware done, Each manufacturer can ably cope with the toxic material situation by constantly safeguarding the public through the prod ucts he manufactures end by the repetition of Instructions to salesmen, service men and others ho can intelligently instruct the consumer of the advantages of providing adequate ventilation end of maintaining personal hygiene. Conerol - The stotenant of legal principles listed below was prepared for and distributed by the Manufacturing Chemist!' Association for the guidance of its (.-.sobers concerned with labeling problems, and is supported by decisions of the courts. Although the principles set forth are not entirely the result of litigation involving notarial used by aembers of our industry they are nevertheless generally applicable to situations arising frca the use of harmful substances. NCA 0 025DI Manufacturing Chc-alsts' Association Legal Principles 1. A manufacturer who puts out c dangerous article or substance without ucconpanying-it with u warning at- to its dangerous properties is crci- r.arily liable for any ducuge which results from such failure tc warn. 2. A manufacturer ur aeeler who erroneously labels a dangerous drug with the name of a hornless substance is liable for any injury which may la caused thereby. 3. Failure to comply with c statute, e.g., with raspect tc l.bdirg pcisens, is usually held tc be nsgiigoncs per sc or ct l^ust avii.u-.ce of negligence. 1. The name of the product alone nay be sufficient warning, if its na ture is very widely knewn or its sale is restricted to those who are . presumea to know its nature, but even in such cases the cdviscoility of a specific warning is indicated. 5. Technical accuracy may not bo sufficient protection for the auiufecVjrer if he uss r.crcs v.-hich say give the purchaser the impression that his product is not -.net it actually is. 6. A nonwnrrcnty of results is net a warning against possible Cicn^^rous results. 7. The consumer is entitled to rely on positive representations or di rections t.ppe&ring on the label unless ha knows then to oe incorrect. 8. The manufacturer is ordinarily not liable if his product is put tc a use fer which it is not intended ana tn injury results which could net reasonably have been foreseen. It 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 to be the manufacturer must know tha qualities of his product and ha cannot uscape liability on the ground that ho did not know it to be dangerous. 10. The general rule that a manufacturer is not liable to these not in privity of Contract with him doos not apply when his product is immi nently or'inherently dangerous. Ccncluslon - He grant that this is a very broad subject, and doubt if a conclfn set cf rules can be established. Nevertheless, it say be saia 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 prcccutlon in the use of toxic materials in manufacturing, selling and in use. Such precautions plus constent repetition of intelligent instructions will, it is believed, secure the best resul}<*r Tours vary truly# ETTima Q 02204