Document NemJM3vyEdLnm10dzKvg8eq5w

telephone national 4sa NATIONAL *<09 Manufacturing Chemists' Association OF THE UNITED STATES (FOUNDED 181*) yPrN*C*N*T. AW*VATSON 608 Woodwabd Building Washington 6, D. C. L-184 MINUTES OF MEETING LABELS AND PRECAUTIONARY INFORMATION COMMITTEE Hotel Carter, Cleveland, Ohio, April 22 and 23, 1948 The meeting of the Labels and Precautionary Information Committee was ealled to order by Chairman W. N. Watson on Thursday, April 22, 1948, at 10:00 A.M. The following were present: W. N. Watson, Chairman D. D. Irish T. R. Aalto W. A. Knapp Carl Anderson R. D. Minteer A. Q. Butler J. A. Noone J. S. Coey F. D. Sparre A. G. Cranch W. W. Sunderland J. T. Fuess J. B. Williamson (Alt. for R. W. Lahey) S. J. Hill Dr .John Zapp (Alt. for J.HJFoulger) Guests: R. F. Hansen, General Chemical Division G. E. Hinds, Sharpies Chemicals, Inc. I> MODEL STATE BILL The second draft of the model state bill (Proposed Uniform State Act Govern ing the Labeling of Hazardous Chemicals), revised in accordance with comments / received since review of the first draft, was read and discussed paragraph by \X/ paragraph. Suggestions were noted by Mr. Hansen for incorporation in the ^^ f-1 third revision, which will be referred to the legal advisory committee for treat ment prior to submittal to the Executive Committee for approval. 3 r * IL LABELS 1. Warning .Statement. Tfte committee deferred until the next meeting con'' . ^ration of a report on LAPI labels which should contain, in addition to a warning statement concerning removal of contaminated clothing, a statement on the removal of contaminated shoes; also a recommends ation as to labels from which the clothing warning should be deleted. 2. Volatile Solvent. A report on the scope and limits of application of the phrase "volatile solvent"-was deferred for consideration at the next meeting. L-185 3. Reagent Chemicals. The committee, after review of proposed labels for reagent chemicals submitted at the February meeting a test of general principles governing reagent chemicals, approved the condensfjjj labels listed below. A label for ammonium bichromate was omitted so that i'froducers may be rechecfc^ |n regard to the question of its flammable properties. In approving these labels emphasis was laid upon space restrictions of small bottles which would limit the number of words feasible in legible type, and on the fact that labels on larger bottles could contain more information. (See General principles for Reagent Chemical Labeling, LAPI Minute 1-5, L-164). Acetic Anhydride Acetone DANGER./ Causes Severe Burns Vapor Harmful DANGER,/ Extremely Flammable Oxalic Acid *.1 POISON "Antidote" Phenol DANGER./ Rapidly Absorbed Through Skin Causes Severe Burns \ Sodium Hydroxide VARNINg/ Burns Skin and Eyes POISON "Antidote" \ | POISON "Antidote" ;.W . . : t/ ' 'A* A. ? C T,. ;5: ar- Article on Reagent Chemicals. Reference was made to copy of a letter dated March 31 from J.T. Fuess on behalf Jbfthe Reagent Chemicals Subcommittee to W. J. Murphy of "Chemical and I Engineering News" protesting publication of the article "Health Hazards of " Common Laboratory Reagents" on grounds of inaccuracies and misleading state ments. This letter was attached to the docket for the April meeting. 4. Rubber Chemicals. Mr. Hill agreed to report on the conclusions reached at the second meeting of the Rubber Chemicals. Subcommittee, and on labels adopted to date. It was agreed that these labels should not be included in the reprint of "Warning Labels." 5. Nitrocellulose. The committee deferred until the next meeting consideration of a revised label for wet nitrocellulose in drums (contain- less than 12.4% nitr.ogeh)... s 6. Anhydrous Hydrofluoric Acid. The following label, submitted to the "j ' : " committee on a mail ballot dated March 22, ?ag referred back to the AHF Committee for reconsideration of the phrase :<$tore sway from direct heat and below 105F. Hydrofluoric Acid, Anhydrous DANGER./ EXTREMELY HAZARDOUS LIQUID AND VAPOR M. CAUSES SEVERE BURNS WHICH MAY NOT BE IMMEDIATELY PAINFUL OR VISIBLE Do not get in eyes, on skin, on' clothing. Do not breathe vapor. Store away from direct heat and below 1Q5F. UNLOAD ONLY IN ACCORDANCE WITH PRACTICE RECOMMENDED IN MANUFACTURING CHEMISTS' ASSOCLATION MANUAL H-2. Read also M,C,Aa Safety Data Sheet Number SD-22. Copies furnished on request. First Aid hi case of contact or suspicion of contact, remove all contaminated clothing at once; immediately flush skin or eyes with plenty of water for at least 15 minutes; pay particular attention to skin under nails. Apply magnesia-glycerin paste to skin after washing. ' Get medical attention. Wash clothing before reuse. 7. Aqueous Hydrofluoric Acid. A proposed revision of the label for Aqueous Hydrofluoric Acid was deferred for consider- Nation at the next meeting. 8. Labeling of Repackaged Products. At the last meeting of the LAPI Committee nearly one hour was devoted ito proposals of the Safety Research Institute for revision of the carbon tetrachlorV^, JlMe label for use on household packages. The Chairman reported that Mr. Low, V v |J|in a letter dated February 25, suggested that the matter be dropped by the LAPI ' 1-Committee. 9. Methanol Label. Members were advised that the Chemical Products Jf;, Agreements Committee, U. S. Public Health Service,. \X||ad approved for use under the agreements with the Surgeon General the revised Iplethanol label adopted by the LAPI Committee in February (LAPI Minute 1-13, ;fL-180). A copy of the letter of the USPHS, dated March 25, was attached to the f^docket for the April meeting. I? 10. Insecticide Labeling The committee reviewed the preface of Supplement I Sfr to Manual L-2, entitled "Illustrative Warning / ^Labfels for Economic Poisons," and approved the preface following incorporation \ aJ r certain revisions. A copy of the approved text is attached to these minutes as v IfAttachment A. Tfye committee also approved, after review, the revised draft of caution ls for economic poisons. The chairman was requested, in accordance with committee's desire to cooperate with the Department of Agriculture, to submit spies of the Supplement and of the caution labels to Dr. W. G. Reed, Chief, Insecside Division, Department of Agriculture, and to ask for a conference with the 'secticide Subcommittee wit|$i a week. 11. Standardization of Signal Words. The committee deferred until the next meeting consideration of the report of )?, J. H. Foulger dated March 17 on standardization of signal words used on LAPI sis. A copy of the report was attached to the docket for the April, meeting. 11-a. Rating System for Choice of Signal Words. The report of Dr. W. A.Knapp on a "Rating System for |Cj|oice of Signal Words" also was deferred until the next meeting. A copy of the ^report was sent to members by Dr. Knapp on April 16. 12. Extension of Toxicological Tests. In the absence of Dr. Foulger no action was taken on the suggestion made at February meeting with reference to extension of his toxicological tests. 13. Color Code for Mineral Acids. No action taken. 14. Cyanide. - First Aid Treatment. Representatives of the three producers of cyanides submitted the following ;r4(Wsed first aid treatment for Cyanide, which was unanimously approved. It was ~ ip agreed that the revised first aid treatment should be used in the recommended Pi for Acrylonitrile. m Cyanide POISON ANTIDOTE AND FIRST AID Carry patient to fresh air. Have him lie down. Remove contaminated clothing but keep patient warm. Start the following first aid treatment immediately and call a physician. IF PATIENT IS BREATHING Break an amyl nitrite pearl in a cloth and hold lightly over nose for not more than 20 secop$$ repeating every 5 minutes for 25 minutes', if recovery is not forthcoming. Give oxygen inhalation between amyl nitrite administrations. (Label continued on next page) L-188 IP PATIENT HAS STOPPED DREATHJNG Give artificial respiration until breathing starts. During artificial respiration have assistant administer amyl nitrite pearl as above. IF PRODUCT HAS BEEN SWALLOWED AND PATIENT IS CONSCIOUS OR WHEN CONSCIOUSNESS RETURNS Give one pint of 1% sodium thiosulfate solution (or soapy water or mustard water) by mouth every 15 minutes until vomiting occurs. Administer amyl nitrite as above. NEVER GIVE ANYTHING BY MOUTH TO AN'UNC0NSfc UNCONSCIOUS PERSON. In all cases keep patient quiet and warm until a physician arrives. m. LABEL ADHESIVES Mr. Minteer and Dr. Irish showed samples of labels on metal that had been submitted for 139 hours to the exposure meter test. Mr. Minteer advised that he hoped to supplement this progress report with a final report at the next meeting of the committee. IV. DEFINITION OF CLASS B POISONS The chairman advised that the proposed new definition of Class B Poisons is under careful review by the technical container committees. V. "WARNING LABELS" Report of Subcommittee. The report of the subcommittee on a revision and reprint of "Warning Labels" was approved as follows: 1. The Manuals should be reprinted. This will require some time and since we understand that the stock of the present manual is very limited it would be desirable to proceed at once with this work, setting January 1949 as the final deadline. 2. It is recommended that the revised Manual be printed on a page size 6|- x 9-| and be plastic bound. 3. It Is considered desirable, if at all possible, to include in the manual four center pages of sample labels in color. 4. The revised Manual should include the report on insecticides and labels therefor. This should preferably be a separate section. The committee decided that action on this recommendation should be deferred until clearance of the report with the Department of Agriculture. 5j The Subcommittee feels that the definition of "poison" should be revised. The present definition has not been too generally accepted and is seriously lacking in that it does not provide methods of test. A new definition similar to that in the Economic Poison Act which includes methods of test would be preferable. A subcommittee consisting of Drs. Foulger, Cranch and Zapp was appointed to prepare a new definition of "poison." 6* The discussion of the treatment of mixtures under General Principles should be expanded. This might be done somewhat along theL ines of the proposed introduction for the insecticide section. 7. The Manual should include a notice of approval by the Surgeon General's Office of each label so approved. 8. It should also include with each appropriate label reference to the availability of a safety data sheet when such is available. a 9. When the word "poison" is included on a label it is recommended that a footnote be added to indicate the reason for the use of that . word. This, seemsjrather important since-the Committee has recommended against the use of this word generally but has specified it in a number of cases and the reasons for this are not generally clear* 10. The Editorial Board will require time for revision and preparation oi the Manual, hi order to meet the deadline set, it is important that 9,11 proposed revisions be presented and acted upon, at least in principle, this meeting. A letter was therefore sent to each member of the Committee requesting that all proposals for changes be presented at this meeting. Other recommendations. Other recommendations approved by the committee are: 1. The preface should contain a paragraph on container handling, with specific examples, such as "Completely drain carboy before returning." 2. There should be a reference to M.C.A. publications on containers, such as paper bags, fiber containers, steel drums, and tank cars. 3. The chairman should Request the chairmen of container committees to submit specific suggestions in regard to material for the paragraph indicated in (2) above. Warning Statements "Avoid" and "Do not". A member of the legal advisory committee raised the question that if a label contains statements to "avoid" or "do not" do certain things, there is an implication that all important hazards are covered; consequently a producer might be liable If he overlooked some hazard. This suggestion was discussed at length and it was concluded, after careful review, that a little more emphasis should be placed upon the statement of hazards and a little less on the "avoid" and "Do not" statements; however, it was agreed that it would seriously detract from the utility of a caution label to simply state the hazard and discontinue the "Avoid" and "Do not" statements. Furthermore, it was felt that it would be inconsistent to omit these statements at this time. Deadline date for changes. Members of the committee agreed to have their suggestions for any changes in "Warning Labels" in the hands of Chairman Fuess not later than June 1, in order that his subcommit tee may proceed with preparation of the revisionTand have it ready for final action at the next meeting of the committee. Addition to subcommittee. Mr. F. Bartenstein of Merck & Co. was added to the membership of the subcommittee on revision of "Warning Labels," which also includes J. T. Fuess, chairman, S.J. Hill) and J. B. Williamson. State Regulations. The chairman was requested to advise the California and Oregon State authorities concerned with the administration of their respective caution label regulations of the contemplated revision of "Warning Labels." VI. MISCELLANEOUS 1. Classification of Fluorides under ICC Regs. No action taken. . ^2, Ammonium Nitrate Caution Label. It was reported that the M.C.A. Ammonium Nitrate Technical Committee has approved the following caution label, which was reviewed by thle LAPI Committee at the October 1947 meeting and suggestions made (LAPI Minute 1-24, L-170): Ammonium Nitrate Fertilizer Keep away from heat and open flame -- DO NOT SMOKE Store away from materials which will burn. In case of fire, flood with water. Burn empty bags promptly in open - a few at a time. Place broken or torn bags and contents in overslip bags. Sweep up and dispose of all spilled material immediately. The M,C.A. Ammonium Nitrate Technical Committee includes all U.S. producers of the fertilizer grade, and all producers except one have indicated that they are ready to adopt the uniform label". "The single exception is delaying until Part HE of the report of the Interagency Committee has been completed. L-191 3. National Chemical Exposition. The chairman referred to a letter from the Industrial Conference Committee for the Fifth National Chemical Exposition to he held in Chicago next October, and to the request that a member of the LAPI Committee address a forum on "Control of Hazardous Chemicals anc| Materials." A canvass of the members indicated that none of them is in a position to give a talk on the work of the committee at that particular meeting. 4. Army-Navy Medical Procurement. It was reported that there has been a relaxation of the Army-Navy Medical Procurement requirement for LAPI labels on small containers, and it was suggested that a member or members of the Reagent Chemical subcommittee make direct contact with the proper officials at the Brooklyn office. 5. New Member. It was agreed to invite Mr. W. W.- Sunderland to become a member of the LAPI Committee. 6. Next Meeting. It was agreed that the next meeting should be held at Rochester, N, Y. on Monday and Tuesday, September 20 and 21, 1948, with headquarters probably at the Rochester Hotel. vn.$ adjournment si, 1*7. The meeting adjourned on Friday, April 23, 1948, at 5:45 PJM. l W. N. WATSON Chairman Minutes subject to approval tti i: ' I^tpl Committee April 22-23, 1948 Attachment A SUPPLEMENT I To Manual L-2 Illustrative Warning Labels For Economic Poisons Adopted 1948 Preface The Manufacturing Chemists' Association has issued this Supplement as a guide to its members in preparing label warnings for economic poisons. It is intended to fill a timely need in view of the enactment in 1947 of the Federal Insecticide, Fungicide, and Rodenticide Act and of recent revisions in State Laws affecting economic poisons. The Supplement contains suggested label- warnings for a selected group of chemical products commonly used as or in the formulation of insecticides, ftittgioides, rodenticides, and herbicides, and presenting hazard to man, useful animals or useful vegetation. The warnings are based on the principles setforthin Part I of Manual L-l, "A Guide for the Preparation of Warning Labels for Hazardous Chemicals". The Reader should first carefully study these principles before attempting to adapt any suggested wording to his economio poison product. The principles apply primarily to the labeling of hazardous chemicals intended for industrial consumption, many of which are also used for processing into 'consumer`forms of economio poisons. Labels for consumer packages of economio pois ons- require consideration of additional factors since they will be handled, stored, and used differently than those intended for industrial consumption. Also, consumer labels should include warnings not only for hazards to man, but to domestic animals, useful invertebrates, and useful vegetation. A producer or distributor of an economic poison should acquaint him self with all laws governing eoonpmic poisons, including those of the Federal Government, states, territories, and other political subdivisions, and with any ir applicable statutes, ordinances, or regulations affecting labeling in general. Statements suggested in this Supplement should be used In addition to or in combi nation with, any other wording required by jawjj IIs' Because of the large variety of economio poison formulations in which the ingredients may be contained in various concentrations or combinations it has been impossible to suggest wordings in this Supplement applicable to all cases. In geperal, the range of concentrations to which the suggested wording applies is stat ed'. Where other concentrations or combinations are involved, the statements may be suggestive of the hazards to be considered. Products formulated from two or more constituents may have properties that vary in kind or degree from those of the" "** constituents; any warning statement should be based on the properties of the fin ished formulation. "' Furthermore, it has not been practical to propose statements for all special packages, extraordinary uses or other unusual circumstances surrounding in dividual products. Each statement is designed for the normal and customary use of a particular economic poison. Each labeler of an; economic poison should recognize that his product must be treated individually, in the light' of its own characteri stics, , including among others, quality, package sizes and types, channels of -2 iatribution, normal storage and transportation conditions, intended, consumers, and tended'uses. The Federal Act requires the word "Poison" and the skull and cross hones on all products deemed "highly toxio to man". Regulations under the Act provide that a product may be highly toxic to man by oral intake, inhalation or ikin absorption. In Manual L*-l poison is defined to include only products capable of causing acute effects by oral intake or inhalation. Mot only do the regulations add a third mode of entry into the body, namely, skin contact, but they also change the iiinits within whioh a "Poison" may jeopardize life. The word "Poison", when used pn eoonomio poisons under the Federal Regulations, thus has a broader meaning than that given in Manual L-l for ordinary industrial chemicals'! >ri To the ultimate consumer the word "Poison" on a label, even when associated with other warning statements, may not indicate the modes of entry by which the product is poisonous* The term "Poison" is commonly understood by the lay man to mean toxic by oral intake only. To avoid personal injuries that may arise by misinterpretation of the term, labels on consumer packages of economic poisons highly toxio to man should specify the modes of entry into the body by which the product is poisonous. Examples s Warning* Manger * Caution* Danger* Poisonous If Swallowed. Poisonous by skin contact. May be poisonous if inhaled. Poisonous if swallowed or by skin contact. .It is to be noted that the word "Poison" never takes the place of a signal word and that ary one of the signal words "Danger", "Warning" or "Caution" may be applicable even when a product is poisonous. The selection of the appropri ate word will depend not only on the degree of toxicity of the product, but more particularly on the risk of injury normally presented. The word "Poison" (or its derivatives) should be reserved exclusively for those products coming within the definitions of the Federal Act as "highly toxic to man" except where it may be required by other laws or regulations suoh as the Federal Caustic Poison Act, Surgeon Generals Agreements, eto. For products that are less toxic statements like the following are preferredi May be fatal JLf swallowed Harmful if inhaled or swallowed The label examples in this Supplement are confined mainly to measures necessary to prevent injuryto man and domestic animals arising out of the ordinary handling, storage or use of a product. Additional warnings may be indicated by the particular form or manner in which a product is sold or the circumstances surround ing its use. There also may be other hazards to man or animals which' can arise only from specific uses for which directions are given in the labeling. Frequently an economic poison may alsobe fiazardous to useful invertebrates or useful vegetation or from residues remaining on edible vegetation* The omission of reference to these hazards from any statement in this Supplement does not imply that they may be dis regarded. As a rule such warnings are properly incorporated in directions for use. Even though they may be separated from the principal warnings they should, never theless, be prominently displayed. Examples: Do not use this powder on drainboards, shelves or other places where contact with food is likelj'1. -3Avoid use during flowering and pollination periods. Do not allow spray to come in oontaot with garden plants. Do not consume fruits or vegetables until residue is removed. An important principle of good labeling is to avoid the promiscuous |':us0 of precautionary statements since they tend to detract from the prominence and Ijfmportance which should be given to the vital warnings. Common sense indicates >rtain fundamental precautions in the handling of nearly all household and farm figupplies and a label statement cannot substitute for it* Phrases such as "Keep ii'*wy from children and domestic animals" and "Avoid contamination of food" should f'lje necessary only where the inherent high toxicity of the product, special use of the material, the size of the package, likelihood of mistaken identity; or actual use experience strongly Indicate their need. Where the inherent hazard is of minor significance it may be adequate to include on the label a simple statement such as: v CAUTION* Avoid prolonged Inhalation. The absense from this Manual of a label recommendation for a specific if. economic poison should not be interpreted as meaning that the product requires no precautionary information* i . !>; if i Rating System Insecticide Labeling ii ..Basic toxicity ' Flammability Point Rating 25 ' Highly toxic to man via Federal Insecticide Act regulations. 50 Flash point below 20F 15 - n i* n gQOp 5 - 1409F Vapor Hazard 25 - Equil. cone at rm. temp. highly toxic 15 - Vapor pressure at rm. temp, over 10 mm. (13,000 ppm) 5 " " " " 1 mm. { 1,300 ppm) Absorption Hazard 25 - If readily absorbed thru skin Corrosion to Skin or Mucous Membranes 25 - If highly corrosive to skin 15 - If markedly irritating to skin 5 - If only minor skin irritation Oxidizing Agent 25 If oxidizing agent Physical form and Conditions of use (a) 10 - If liquid, or formulated for dusting purposes, or directions for use are such as will result in marked exposure to skin (b) 10 If attractive nuisance (clear liquid, likelihood of mistaken identity, used in baits etc.) (c) 10 If used as fumigant Note: Although the above categories include all hazards which may reasonably be encountered in the use of a product it is realized that special and peculiar properties of a material may dictate a greater or less hazard than is indicated by the scoring system. Thus allergic responses, sensitization, cumulative effects from more than a single chemical in a mixture and particularly insidious physiological responses may require a stronger signal word than would appear to be necessary by strict adherence to the system. Similarly, rapid detoxification in the body or conclusive evidence, for example, that absorption thru the skin produces no serious toxic effects may justify a milder signal word. Cases of this type are expected to be very few in number and should be decided only on a broad basis of fact and not upon an individual experience. Tentative Limits for .Signal Words 20-40 Caution! 45-70 Warning! 75 up Danger! laaion of ifetingSvgtem It is evident from long experience that the hazards of handling a material md basically upon toxicity, physical and chemical properties and conditions of These factors may be subdivided and a greater or less importance placed upon In the above outline point ratings have been placed on each hazard of known in stance. Maximum point ratings (25 pts) on each hazard are equal with the exception ;t extremely flammable materials are given a 50 pt rating. This is justified by the it that normal precautions may be ineffective and the damage resulting from accident tyr\y extend far beyond the individual working with the material. I It is visualized that in some cases it may be impossible to assign ratings Tor a given hazard because information is lacking. In this event it is suggested that t'the score be prorated on the basis of the first six hazards as follows: Hazard Possible Score Actual Score 25 50 25 25 25 25 30 no 0 15 25 data 0 0 10 .. teXval Sgpre. ,1-6, ...4Q = JL Posslble Score, 1-6 150 175 X - 47 Signal Word Rating * 47 * 10 = 57 (Warning) ;A8aaisj2z&i& In the absence of complete toxicological data on most compounds now in use md with the certain knowledge that this deficiency cannot be made up in the very near liture one level of toxicity only has been assigned. Of three routes of ingestion it reasoned that oral intake is in the great predominance of cases a voluntary action the amount ingested is frequently far in excess of the toxic limit regardless of the .ficity level of the material. Any toxicity which might result from the involuntary If)*'^4tes of ingestion, namely skin absorption and inhalation are taken care of under items and (4) wherein the point system is applied based on opportunity for ingestion ir- fspective of the basic toxicity of the chemical. Hammabi] itv The ratings under this heading are quantitative and there should be no disJi4lgreement except as to the absolute values applied to flash points. w-j&uor Hazard ** V-` ff f1 This category is in effect a slight extension of the regulations and may re- 12345 67 Total Signal 25 15 25 0 15 0 20 (a-c) 110 Danger 25 0 0 0 5? 0 20 (a-b) 50 Warning 0? 0 0 0 5? 0 0 5 Caution 25 0 0 0 15 0 10 (a) 50 Warning 0 0 0 25? 15 0 10 (a) 50 Warning 25 0 25? 25? 5 0 10 (c) 90 Danger 25 25 25 0 15 0 20 (a-c) 110 Danger 0? 0 25 0 5 0 30?(a-b-c) 60 Warning 0 0? 0 25 0 5 0 30? 60 Warning opierin 25 0 25 0 15 0 20 (a-c) 85 Danger jsar creosote 0 0 0 0 5 0 20 (a-b) 25 Caution 5?*!' is t 0? 0 25? 25 25 0 0 0 25? 5 0 10 (a) 0 10 (a) 85 Danger 40 Caution i Dsjifchloroethyl Ether 0? 0 25 0 5 0 30 (a-b-c) 60 Warning Djfeblorophenol 6? 0 0 25? 25 0 0? 50 Warning 0 0 0 0 15 0 0? 15 Caution fjTOjylene dibromide 0? 0 25 0 15 0 20 (a-c) 60 Warning Ethylene dichloride 0? 15 25 0 15 0 10 (a) 65 Warning Ethyl Mercury Chloride 25 0 25 25 15 0 0 90 Danger ocyanic Acid 25 0 0? 0 15 0 20 (a-c) 60 Warning 25 0 25 25 15 0 10 (a) 100 Danger 25 0 25 0 15 0 10 (c) 75 Danger :d Arsenate 25 0 0 0 5 0 10 (a) 40 Caution Note: Letters in column indicate use conditions for which points ratings were applied. Letter signed J.T*Fuess, as Ch. of Reagent Chemicals Subcommittee of LAPI of MCA copy March 31, 1948 Mr* Walter J. Murphy Chemical and Engineering News 1155 16th Street N.W, Washington 6, D. C. . Dear Sir: The publication in the February 2, 1948 issue of "Chemical and Engineering News" of the article "Health Hazards of Common Laboratory Reagents" by Prudence M. Van Arsdell Is most disturbing to our Committee which has concerned Itself for the last three years with the problem of safety In the use and handling of chemicals. It is felt that this article, instead of serving its Intended purpose, Is more likely to be harmful and dangerous. Criticism should perhaps be directed primarily against the editors of the magazine for the publication of an article on such an important subject without definite approval by competent authorities in the field, and in fact in direct opposition to strong recommendations by such experts against its publication, 3$ is indeed unfortunate that the harm done by the publication of this article cannot be entirely counteracted by any subsequent publication or explanation. , The criticism of an article in general terms only is perhaps unfair to the author* but detailed criticism of tMs article would require the writing of a thesiSv We would like, however, to .present some general comments (some of which I understand were presented in 1946 in opposition to the publication). 1. The article is evidently simply a literature review of an essenti ally medical subject by an obviously incompletely informed layman. The presentation of such an article in a magazine having the reput ation and circulation of "Chemical and Engineering News" provides the article with prestige greater than would normally accrue to it by-virtue of the professional standing of the author. Since this subject deals with a field of knowledge differing from that usually appearing in the magazine, particular care should be exercized by the editors in assuring themselves of the professional standing of the author and hi abiding by the opinions of recognized authorities in that field. These points appear to have been completely overlooked or disregarded. 2. As is often the case of a "collected" article on a professional subject by a non-professiOnal person, serious mistakes which have entered the literature have been repeated and obsolete methods recommended. 3. Description of signs and symptoms of injury as included in the table are inaccurate in fact, and very often misleading in termin ology. -2- 4. Too much emphasis has been placed on oral ingestion, with little on inhalation, an equally important and often lesser known hazard. 5. The first aid procedures recommended are a peculiar mixture of actual first aid and suggested medical treatmat.- They are so vague in their detail that in many cases they could actually cause more , injury to the patient than no first aid at all. They include procedures which have long ago been discarded by those having knowledge in the field of toxicology and the treatment of poison cases. They are in fact quite often dangerous recommendations. 6. Compounds are classified by groups, which for action and treatment is not considered safe by recognized authorities. 7. Statements in the article indicate a serious lack of toxicological orientation on the part of the author. 8. There are obvious inaccuracies in the article. 9. The article fails to distinguish clearly between acute and chronic effects. 10. The article deals with inorganic chemicals primarily, with little attention to the-organic-reagents which are of extreme importance. 11. The article attempts to cover in 3-| pages of text and 2 of table, a subject on which a whole encyclopedia could be written. Our work as the Labels and Precautionary Information Committee, one of the technical committees of the Manufacturing Chemists' Association, is concerned with the presentation of accurate information principally by means of labeling, on the hazards, protective measures, and in many instances first aid measures for specific chemicals. (If you have not seen our Manual, I shall be glad to send you a copy.) In our work we have had the assistance and expert advice of the best authorities in the field of industrial medicine and toxicology, ha spite of this, difficulty is continually encountered in preparing in brief form accurate information on immediate treatment of injury. It was realized early that general statements based on groups of compounds' could not be used, but that each chemical had to be treated individually. In all cases, accuracy has been .considered the major objective. These efforts will be of little avail and the. user will certainly become more confused and possibly seriously injured if reputable journals published by societies such as the American Chemical Society with their reputation sponsor articles by laymen with no professional standing on such complex subjects as this. On these grounds we feel that a very strong protest must be registered against the action of the editors of "Chemical and Engineering News" in publish ing this article, particularly in the face of recommendations against its public ation by those who are authorities in the field discussed.-.This protest is not that of the writer alone, but constitutes a-summary of opinions presented to me as subcommittee chairman with the request that they be incorporated into a single comment from the Committee, (signed) J.^Chem.Subcommittee >1 committee Meeting April 22-23, 1948 HYDROFLUORIC ACID, AQUEOUS DANGER./ Hazardous Liquid and Vapor Causes Severe Burns Which May Not Be Immediately Painful or Visible Do not get in eyes, on skin, on clothing. Do not breathe vapor. READ MANUFACTURING CHEMISTS* ASSOCIATION SAFETY DATA SHEET NO.____ . COPIES FURNISHED ON REQUEST FIRST AID In case of contact or suspicion of contact, remove all contaminated clothing at once. Immediately flush skin or eyes with plenty of water for at least 15 minutes. Pay particular attention to skin under nails. Apply magnesia-glycerin paste to skin after washing. Get medical attention. Wash cjothing before re-use. m m. i, c ji-4 ft ? r tV . B 0 p Y FEDERAL SECURITY AGENCf U.S,, PUBLIC HEALTH SERVICE WASHINGTON 25, D.C. MARCH 25, 1948 Mr, Warren N* Watson, SecretaryManufacturing Chemists' Association 608 Woodward Building Washington, D.C. Dear Mr. Watson: I have contacted the members of the Chemical Products Agreements Com mittee relative to the advisability of revising the label on methanol as set forth in the agreement revised in 1935, The members approve the follow ing revision of the label, however the remainder of the agreement of 1935 remains unchanged. METHANOL DANGER: FLAMMABLE VAPOR HARMFUL MAY BE FATAL IF SWALLOWED . CANNOT BE J.IADE HONPOISONOUS fi POISON a ANTIDOTES IF swallowed: Give a tablespoonful of salt in a glass of warm water and repeat until vomit fluid is clear. Give two ijeaspoonfuls of baking soda in a glass of water. Have patient lie down and keep warm. Cover eyes to exclude light, CALL A PHYSICIAN. If splashed in the eyes: Immediately flush with water for at least 15 minutes. Get medioal attention. The word "flammable" may be omitted from the label if the methanol mixture has a flash point above 80oF* This new label will be obligatory one year after date of notice, but it would be optional within the year. In other words, the old label could be used for at least one year. It is anticipated that you will contact the signers of the old agree ment and also submit the new agreement to new companies that will be in operation. Sincerely yours. JGT:DLH /s/ JG. Townsend, Medical Director Chief, Industrial Hygiene Division March 17, 1948 To: Members of the 1API Committee From: John H. Foulger, M. D. Subject: Standardization of Signal Words used on LAPI Labels, The LAPI Committee, through its Sub-Committee on Economic Poisons, has been asked by Dr, W. G. Reed-of the Insecticide Division, U. S. Department of Agriculture, to present, if possible, at least semi-quantitative criteria for use of the signal words, "Danger, Warning, Caution," Since this request is virtually a challenge to the LAPI Committee to demonstrate its consistency In allocation of signal words, it seemed important to analyze existing LAPI labels at once, in order to disclose any existing pattern which might be used as a basis for standardization. The attached pages show the result of this analysis in the form of a Code, and Its application to 139 labels approved by the LAPI Committee in its published Manual L-2 and Supplement A, dated June 1947, It is found that the Committee has been surprisingly consistent. Of the 139 labels considered, the Code gives signal words differing from the approved labels in only 18 cases. Of these, the changes from Manual to Code are: Manual Code No, of Labels Warning increased to Danger Caution increased to Warning signal word Increased to Caution 4) ) Total increased 2) ) 1) 7 ) Warning decreased to Caution ) Total decreased 11 ) ) 11 Thus,-in the majority of cases in which the Committee's decisions depart from the Code, the Committee has leaned toward greater protection of the user of the labelled chemicals JHF:AMcB ffl (--t 45 is d 0 o ' (1) (U 3 .CD 0} p -e p 3 Oo ft 3 ca w o t*> 3 ft a0) f<*t-* p xi o co ft ft 3 X .3 0 3*0 0 lft P 0, 3O O 3H 3 60 43 !> P O 43 3 43 PP ft O & < S3 * 01 60 0 P TJ ft ft PP O 3 ft 3 ft P O PO O 3O a p cn oo 3 cd p 3 0 p 44 p 0 3 p 44 * 43 P Q cd S3 am 3 44 p pp ft 0 0 3B a *3 ft a - 44 ftp p ftO 3 p rft p0 p p0 3 > 44 3 >3 p 60 0 rH rH * a} H 3 p ft PO 3 3 P 3 ft P 3 PO 3 3O a 60 6043 P r**i OJ > 3 Xi o3 * w 3-=r 33 3 P 44 e 433 A! M P O ra 60 3 43 PP 01 ft 0 CO 3 _ 3 l-c 3 O 3P OP 01 3 O 0 <a PP P 0 424 P p 3P 3 P 0 3 P30 3 3 44 ap 0p X3 0 3P 44 -d p X0 3 3 OP p 44 44 > 3 3 O P 43 ft 3 P r" 44 3 P 0p p ft ra 3 44 <d O 60 3 P 3> ft N P <D p T3 O U 3 44 cd p Xi 0 3 P >P P 3 44 pPP OP 3 0 44 ri a OP t<\ =* OO "*"" 3 b frt Ct) a3 3 P P 0 >d 1 O ft 3 3 0) ftP 0) O 0P 3 P o 68 > ft P 3 O Js X O PP 0P 0 3 p ftO P p. 3 o 3P ft 44 3 3 !* P p O 3 P P 4J O CSflti *H >>----- ft P d H >0 P. !?s * 3 P cn 0) ^PTS f>> >3 ft P ft 0) xi 600 O p p 3 3 , o 3 ft O P P p CD O 3 ft ft w P O 0 W P ft P 0 -d cd p 44 o o 3 44 a s cd 01 P T> O OO -- 0 d 3 cd CQ TJ C3 H *H 0p 3 > * p CQ 0 p 3p 3p^ 0 p 0 3 p 44 0> p O 3P ^ ^ iP OOP 3P g S0 > 0 GO fH p t> pp P cd 333 P P 44 O a 0P r<A ^t- tn > t>* p 0 O > 3 CM ft Pw xp o W 3 ft P ft ox 3 (3. P P W .3. O PP .;g*--nfoc I--Ml I--1--^ P o p3 0p EP P P 3 a ft o l t=*> P 3 ft p P P. 3 6 ; ft p p p 3 po > 3 3 (3 O 60 O P CO P P P --- 3 < O <C 3 o ,3 0 Q CM *3 P -*o ,3 ft ^ ^ O 3 p ap 0 3 p ft^-d 3 S3 p 44 p p > p 3 ft ft 3 p ft ra cd 0 0 ft PH 3 O 3 0 ft p 0 0 p 0 2;--- 0 0 r*\ 3 X! t>sP 3 ft ft P3 3 3P Xi 33 33 60 60 3 P 3 P O 3 f3t p x} H Q -S 3 a0 to 0 rldfi . *3 P P ft ft 3 ft ft P0 3 0 3 a t<\ t t>> p <d Pp 0 3 P P p p 3 tJ 3 3 3 3 > 3 P P 33 pi P P P O 3 O30 60 3 0 p 0 3-d 3 > 3 60 O O 0 ft P t>3 60P P P P 3 d 3 0 3-d fH M 3 P 3 n O P 44 O > 3\ ft O O 60 CQ 3 44 ^ 0 3 3p P 3a . CM P 3 Pfl S *3 p O 44 ft 3 P P ft 60 O 3 ft 44 3 3 3 ft > O O 3 P P 0 OP 3 > O 0 OOpPP p a k'c > p P 0 > _ ,PP P,, 60P 3 t4 OP p PP 0 P>3 > 3PP 3 p O mP O P 60 * O 3 fe PP 3 3 3 OP 3 O O OP > 3 P 60 O iP 3 ?>P 3 a 0 ^4 fi O p cd 0 0 X GQ p 0 P t3 3 3 p pP O P X _ 60 >5 3 O P 3P P 0 OP P X <D *H 60 O 3p 3P a +> ^ O p i--I CM PO t<A AP LO P page in Manual L-2 12 Acetaldehyde 12 Acetic acid - Glacial 13 Acetic acid - 80$ 13 Acetic acid - 56$ and 70$ 13 Acetic acid - 28$ 14 Acetic anhydride 14 Acetone 14 Acetonyl acetone 14 Acetyl chloride 15 Acrylonitrile 16 Allyl alcohol 16 Allyl chloride 16 Ammonia aqua 17 Ammonia anhydrous 18 Ammonium bichromate 18 Amyl acetate 18 Aniline 19 . o-Anisidine 19 p-Anisidine 19 Antimony trichloride 19 Aromatic industrial solvent 20 Aromatic industrial solvent 20 Arsenic trichloride 20 Barium nitrate 21 Barium oxide 21 Barium peroxide 21 Benzol 21 Benzidine 22 Benzoyl chloride 22 Benzyl chloride Code D1 D4 D4 W4 C3 D4 D1 C4 D2 D2 V> 2 D2 W4 W4 W4 C2 D4 W3 W3 D4 W1 C4 D4 C1 C3 C1 D1 C4 D4 W2 Manual D D D W c D D C D D D D w. W W C D W w D W c D C C C D W 7/ W page in Manual - L-2 23 Bromine 23 Butyl acetate (N) 23 Butyl alcohol (H or Sec.) 23 Butyl alcohol (?ert.) 24 Butylamine 24 p-tert. Butyl catechol 24 Butyl chloride (N) 24 Butyl ether (N) 25 Calcium cyanide 25 Carbon bisulfide 25 Carbon tetrachloride 25 Chlorinated naphthalene 26 Caustic soda 26 Chlorobenzene, mono 27 Chloroform 27 Chlorotoluene, mono 27 Chromic acid 27 Creosote oil 28 Cyanides, inorganic 29 Cresol 29 Cyclohexane 29 Cyclohexanol 29 Dichloroe thylene 30 Dichloroethyl ether 30 Dichlorophenol 30 Diethylamine 31 Dioxane 31 Ethyl acetate 31 Ethyl bromide Code D4 C2 C4 W1 W1 C3 D1 C4 D5 D1 W2 C3 W4 W2 W2 W2 W4 C3 D5 D5 D1 W2 W1 D5 W3 D1 W1 W1 C4 Manual D C C w w w D w D D W None W W V/ c w C D D D C W w W D W w w Ethyl chloride Ethylene chlorhydrin Ethylene dibromide Ethylene dichloride Ethylene glycol monoethyl ether Ethyl ether Ethyl formate Ethyl methacrylate monomer Formaldehyde Formic acid Hydrochloric acid Hydrocyanic acid Hydrogen peroxide (above 25 not above 130) Hydrogen peroxide (25) Hydrofluoric acid, Aq Lead acetate Maleic anhydride Mercury bichloride Methyl n-Amyl ketone Methyl bromide Methylene chloride Methyl ethyl ketone Methyl methacrylate monomer Methyl isopropyl ketone Mixed acid Morpholine b-Naphthylamine Nitric acid Code D1 D5 C4 W1 C4 D1 D1 W1 D4 W1 W4 D5 C1 Manual L-2 D D `W W c D D W w w w D C C1 C D5 D W5 w C3 w D 5 t> I C4 c D4 D C4 C W1 w W1 w W1 w D 4 D C4 w C4 c D 4 I> . page in \ Manual f L-2 43 m-Nitroaniline 43 Nitrophenol, mono 44 Oleum 44 Oxalic acid 44 Paraldehyde 45 Pentaehlorophenol 45 Pentaehlorophenol - oil solns* 45 Petroleum naphthas 46 Petroleum naphthas 46 Petroleum naphthas 46 p-Phenetidine 47 Phenol 47 p-Phenylene diamine 47 phosphoric acid 48 Phosphoric anhydride 48 Phosphorus 48 Phosphorus pentachloride 49 Phosphorus oxychloride 49 iso-propyl acetate 49 Pyridine 50 Silver nitrate 50 Sodium chlorate 51 Sodium bichromate 51 Sodium fluoride 51 Sodium hydrosulfite 52 Sodium sulfide (granular) 52 Styrene monomer 52 Sulfur chloride Code Manual L-2 W3 W W3 W D5 D W5 W C4 C W5 W C3 C D1 D W1 C4 W c C4 C D5 D C4 C C3 C W2 W D1 D W2 W D4 D W1 W W1 w W4 W W1 W V/ 4 W W5 W Cl C D5 D C2 W D4 D Manual L-2 53 54 54 54 54 55 55 55 55 56 56 Supple ment A 11 " ,f " " " " n " " ,r n " " Sulfuric acid Sulfur dioxide Te trachloroe thane Tetrachloroethylene Toluene m-Toluidine Trichlo re thylene Trichlorophenol Vinyl chloride Xylene Zinc chloride Barium fluosilicate Sodium fluosilicate Calcium arsenate Chloral Chlorine Dimethyl sulfate Dry ice Hexaethyl tetraphosphate Magnesium arsenite Nitrogen dioxide Paraformaldehyde Paris green Perchloric acid solution Zinc arsenite Zinc arsenate JHF:AMcB 3-17-48 40* Code D5 D3 D4 C2 W1 W3 C2 C3 D1 W1 C3 Manual L-2 D W D W W W W C D W C W5 W5 W2 D4 D5 D4 C5 D5 W2 D5 W2 W5 D1 W5 W5 w w w D D D W D W D W W D W w