Document NepeJvbLGR86bQyJ3EDB47L0E

V* THE SOCIETY OF THE PLASTICS INDUSTRY, INC. 250 PARK AVENUE NEW YORK, NEW YORK 10017 212/573-9400 February 13, 1975 TO: VCM and PVC PRODUCERS GROUP SUBJECT: OSHA LABELING for VCM and PVC In the event that you have not been following the activities of the special committee within our regular SP1 Committee on Distribution, you will be interested in seeing the progress they are making in standardizing the labeling required for conformance with the OSHA Standard on Vinyl Chloride. This Committee responded to the need to develop standardized labeling that will be required when the OSHA Standard goes into effect. I suggest that you contact your company's representative on the SPI Committee on Distribution (list attached) for more information on this activity. Respectfully JRL:jo Attachments John R. Lawrence Technical Director NGC 16325 THE SOCIETY OF THE PLASTICS INDUSTRY, INC. 250 PARK AVENUE NEW YORK. NEW YORK 10017 212/687-2675 February 4, 1975 TO: RE: PVC/VCM Ad Hoc Study Group SPI Committee on Distribution OSHA Required Labeling for PVC and VCM; MEETING NOTICE Gentlemen: As you are aware, the United States Court of Appeals for the Second Circuit has denied the petitions for review of the OSHA Standard for Exposure to Vinyl Chloride. The Court's decision, issued January 31, 1975, allows 60 days lead time for implementation of the Standard. Accordingly, the new effective date is April 1, 1975. The Working Committee of the PVC/VCM Ad Hoc Study Group met on January 23, 1975, to review the results of the November, 1974 meeting of the full Committee and further to determine whether any additional steps may be appropriate. The Working Committee concluded that stan dardization of labeling practices is desirable. Further more, in order to implement a standardized approach and to assure that the recommended approach satisfies the regulation, the Working Committee believes that the indus try should seek to obtain OSHA's concurrence with the recommended approach. The Minutes of the January 23 meeting of the Working Committee are enclosed herewith. In order to further discuss the recommendations of the Working Committee and to discuss other problems of implementation of the OSHA Standard, Chairman Tom Smith has requested a meeting of all members of the PVC/VCM NGC 16326 2 Ad Hoc Study Group to be held: Tuesday, February 18, 1975 Commencing at 9:30 a.m. MARRIOTT TWIN BRIDGES HOTEL 333 Jefferson Davis Highway Arlington, Virginia The Marriott Hotel has set aside a block of rooms for this meeting which will be held until Friday, February 14. Please advise the hotel when you call for reservations (Phone No. - (703)628-4200) that you are attending the SPI Committee on Distribution meeting. We anticipate the meeting will be concluded by 3:30 p.m. There will be a $15.00 registration fee for the meeting and luncheon arrangements. Please complete the enclosed registration form and return it to the above address no later than Wednesday, February 12. Sincerely yours. A. J. Evans, Staff Administrator Committee on Distribution enclosure ngc 16327 Mr. Albert J. Evans Staff Administrator Committee on Distribution THE SOCIETY OF THE PLASTICS INDUSTRY, INC. 250 Park Avenue New York, NY 10017 Re: PVC/VCM Ad Hoc Study Group February 18, 1975 Meeting Dear Al: This is to advise you that I Plan Do Not Plan // // to attend the February 18 meeting of the PVC/VCM Ad Hoc Study Committee. Sincerely yours. (name) (address) (company) ENCLOSURE: Check for registration fee in the amount of $15.00. HOC 16328 MINUTES PVC/VCM AD HOC STUDY GROUP SPI COMMITTEE ON DISTRIBUTION Thursday, January 23, 1975 9:30 a.m. - 4:00 p.m. Conference Room Keller & Heckman Washington, D.C. Committee Members: Tom H. Smith, Chairman B. F. Goodrich Chemical Company Edward Bell Union Carbide Corporation D. V. Bierwert Monsanto Company (Substituting for Edwin F, Celette) Roy C. Danziger Air Products & Chemicals Inc. Gerry A. Lapointe Tenneco Chemicals, Inc. (Substituting for Sal Cincotta) Richard L. Way Shell Chemical Company Martin Bercovici Keller & Heckman Guests: Grant Arnold George Coffenberg Edwin A. Olsen Ethyl Corporation Stauffer Chemical Company Compressed Gas Association Opening Chairman Tom Smith opened the meeting at 9:30 a.m. He expressed that the meeting had been called to undertake contingency plans with respect to the OSHA Standard for Exposure to Vinyl Chloride currently under Court review. Following the November 21st meeting of the full committee of PVC and VCM producers, there had been an expression of interest in developing for transportation purposes a uniform approach to the labeling required under the standard and, to this end, further defining requisite labels. This meeting of the Working Committee would explore those sug gestions and make further recommendations to the full Com mittee at a later date as dictated by the outcome of the pending Court case. Martin Bercovici of the SPI's legal staff was asked for his comments. He stated that it is impossible to predict when the Second Circuit Court of Appeals in New York will issue its decision. He stated that the industry has re quested, in the event of an adverse decision, that ninety days be allowed for implementation of the Standard and that it was not unreasonable to expect that the Court would allow Nc 16329 2 a reasonable period of time for compliance. A Uniform Approach for Marking and Labeling The Working Committee then addressed itself to the major reason for the meeting. The benefits of the uniform ap proach were listed as follows: 1. Uniformity of approach by all producers and shippers will facilitate compliance with the Standard with respect to the marking or labeling of transportation equipment. 2. Uniformity will enable OSHA inspectors to impar tially judge compliance and effect uniform enforce ment of the standards. 3. Transportation companies and carrier employees will become accustomed to seeing the prescribed warnings in the identical form and in identical locations regardless of the company making shipment. The carriers are accustomed to standardization in hazard ous materials regulations and such uniform approach would be welcomed. 4. No unnecessary or unwarranted statementsr markings or placardings would appear on transportation equip ment or shipping papers to cause confusion to involved personnel. 5. Uniformity would be more effective in warning the employees of industry, who are intended beneficiaries of the warning. The OSHA standards are directed to three main groups of employees. The employees of the VCM manufacturers, the PVC manufacturers, and the employees of fabricators. The marking or labeling of transportation equipment required by the OSHA standard is directed to the warning of the aforementioned employees. It is also directed to the employees of carriers who may be involved in loading or unloading of VCM or PVC where the carrier employees are involved in such operations and, therefore, should be alerted as directed by the standards. ngc 16330 3 Recommended Labels VCM The Working Committee considered the options of marking tank cars with the required warning (1) on the DOT "DANGEROUS" placard, (2) at or near the manway housing, or (3) both on the placard and at or near the manway housing. After reviewing a number of inputs, including legal opinions, the thoughts of the Compressed Gas Association and the viewpoints of the Working Committee members, it was agreed that the Committee would recommend addition of the legend "CANCER-SUSPECT AGENT" to the DOT placard, in 1/2 inch letters inserted under the vinyl chloride identification. The underlying rationale for this decision is, as follows: 1. Several producers and the CGA have held discussions with DOT and OSHA, and DOT strongly favors this approach. Additionally, in the text of the OSHA report adopting the standard for exposure to vinyl chloride, and at the second full paragraph of page 35895 of the October 4, 1974 Federal Register, OSHA states that since the DOT placard already warns of the fire hazard, "only a statement concerning the carcinogenic hazard need be added to the Department of Transportation labels." 2. The alternate wording "EXTREMELY FLAMMABLE GAS UNDER PRESSURE" introduces new nomenclature for describing vinyl chloride which is different from the DOT nomen clature and therefore potentially confusing to persons in the transportation field. 3. The placard serves to give notice of hazard information to all persons handling the tank car. Further, specific notice at or near the manway protective housing for workers loading or unloading VCM tank cars should not be required in that such workers will be trained to handle vinyl chloride and further since the loading and unloading facilities will be subject to regulation pur suant to the standard. 4. Utilizing the placard approach will convey all relevant NGC 16331 4 hazard information warning at a single place on the tank car. The recommendation for labeling of VCM tank trucks was left for further development. The Working Committee did not wish to make a recommendation with respect to tank trucks without the benefit of the advice of the limited number of parties affected. Labeling of barge shipments of vinyl chloride will simi larly be left to the development of appropriate guidelines by the limited number of shippers involved. It should be noted, however, that the Coast Guard is in the pro cess of promulgating regulations which may preempt OSHA's jurisdiction. Cylinders of vinyl chloride should be marked with the appropriate label using lettering of a size to be deter mined by the shipper. Bulk Polyvinyl Chloride Products It is recommended that hopper cars, latex cars and latex truck trailers are to be labeled, stenciled or tagged on or in the vicinity of all hatches and all outlets, in 3/8 inch lettering which contrasts in color to the background. Bulk truck trailers should be labeled in 3/8 inch letter ing at or near the outlets. The foregoing labeling with respect to bulk PVC products is intended to warn of the potential risks from exposure to trapped monomer which may escape from open hatches or outlets during unloading. Since bulk trailers are unloaded under pressure without need for opening the hatch, the Working Committee believes that a risk of exposure to monomer vapor is presented only at the outlets and accor dingly that only the outlets should be labeled. Inasmuch as the label is required for "containers" of PVC, the la beling is not intended for the benefit of loading personnel who, in any event, must be trained for that function. With respect to packaged PVC products, after considerable discussion the Working Committee recommends that bags should be stenciled or printed on the sides or ends in 1/4 inch lettering, contrasting to the background. Such lettering would be visible to workers handling both indi NGC 16332 5 vidual bags and those observing the bags in a palletized unit. Bulk boxes should be labeled on front and back in 1/4 inch lettering, and drums should be labeled on the front in 1/4 inch lettering* The Working Committee concluded that such labeling will give appropriate notice to personnel handling such containers and that the let tering is appropriate in relation to the size of the con tainer and in relation to the size of warning labels required pursuant to the hazardous materials regulations of the Department of Transportation. . In concluding its thoughts on the uniform approach, the Committee recommends that the warnings suggested above are sufficient to meet the regulations for any mode of shipment. The Committee agreed to offer this contingency position for consideration by the entire Committee pending the Court ruling. It will call a meeting after the court ruling to consider whether to send a delegation to OSHA with this uniform approach. In the meantime, it encourages and would appreciate any position or comments from other members of the Ad Hoc Study Group. Ocean Shipments Tom Smith reported that informal discussions with a ter minal operator indicated that they would refuse to handle bags or units labeled with "CANCER-SUSPECT AGENT". This company said they would feel comfortable handling ocean containers as long as they were not labeled. The Committee suggested an informal visit to the National Maritime Safety Association would be in order. The Committee Chairman and the legal counsel for SPI will arrange a meeting with NMSA and report back to the Ad Hoc Study Group. Other Subjects Several members have been providing test data to the American Trucking Association and the National Tank Truck Carriers. These two organizations are seeking background to determine the extent of the problem created by the regulations and to provide support in their seeking relief is necessary. These two organizations would appreciate help from any other NGC 16333 member of the Ad Hoc Study Group should they care to participate. Several problem so that areas. of the members have found that in meeting the requirements of their warehousing qualifies as they have had no the regulations non-regulated Adjournment The meeting was adjourned at 4:00 p.m. Respectfully submitted. Thomas H. Smith, Chairman 12-20-74 PVC/VCM AD HOC STUDY GROUP SPI COMMITTEE OK DISTRIBUTION B. F. Goodrich Chemical Co. 6100 Oak Tree Boulevard Cleveland, Ohio 44131 Thomas H. Smith, Chairman Ethyl Corp. P. O. Box 341 Baton Rouge, La. J. F. Polito 70821 Air Products & Chemicals Inc. 5 Executive Mall Swedes lord Road Wayne, Penna. 19807 William Brand, Jr. Roy C. Danzlger Allied Chemical Corp. Columbia Road Morristown, N. J. 07960 Charles Corle Borden Chemical Company 180 East Broad Street Columbus, Ohio 43213 Henry R. Blain Certain-teed Products Corp. P. 0. Box 860 Valley Forge, Penna. 19482 Thomas F. McGrath Cheroplex Company 3100 Golf Road Rolling Meadows, Illinois 60008 Jim L. Collins Conoco Chemicals Continental Oil Company Park 80 Plaxa East Saddle Brook, N. J. 07662 John F. Plnkman E. Marcus Smith Roger G. Hutchinson Diamond Shamrock Corp. P. 0. Box 191 Painsville, Ohio 44077 Rodney P. Becker Diamond Shamrock Corp. L100 Superior Avenue Cleveland, Ohio 44114 E. R. Bracken Proctor W. Dodson Dow Chemical Company (The) Operations Services 2020 Dow Center Midland, Michigan 48640 J:__f'.Faraweil Ethyl Corp. 451 Florida Boulevard Baton Rouge, La. 70801 E. R. Schutz Firestone Plastics Co. P. 0. Box 699 Pottstown, Penna. 19464 Russell A. Park Firestone Tire & Rubber Co. 1200 Firestone Parkway Akron, Ohio 44317 T. F. Cerchiaro Cleo Cory General Tire & Rubber Co. One General Street Akron, Ohio 44329 R. W. Laundrie The Goodyear Tire & Rubber Co. 5408 Baker Avenue Niagara Falls, N. Y. 14302 Rowland H. LeCain W. R. Grace & Company 62 Whlttemore Avenue Cambridge, Mass. Joseph W. Keating Great American Chemical Corp. 650 Water Street Fitchburg, Mass. 01420 0. Paul Cohen John C. Cloros Hooker Chemical Corp. River Road Burlington, N. J. 08016 Ram Abramowitz Alan R, McAllister Monsanto Company 800 North Lindbergh Boulevard St. Louis, Missouri 63166 E, F. Celette Olin Corporation 120 Long Ridge Road Stamford, Conn. 06904 NGC I6335 PVC/VMC AD HOC STUDY GROUP Pantasote Co. 26 Jefferson Street Passaic, N. J. 07055 William Link PPG Industries, Inc. Ona Gateway Center Pittsburgh, Penna. L5222 Charles K. Dilley Robintech, Inc. P. 0. Box 2342 Fort Worth, Texas 76101 John E. Ertel Shell Chemical Co. One Shell Plaza Houston, Texas 77002 Richard L. Way Stauffer Chemical Co. Westport, Conn. 06897 Philip Cupertino Patricia C. Watson Tenneco Chemicals P. 0. Box 2 Turner Place Plscataway, N. J. 08854 S. N. Clncotta Union Carbide Corp. 1 River Road Bound Brook, N.J. 08805 Edward Bell Uniroyal Chemical Spencer Street Naugatuck, Conn. 06770 A. P. Wolff Keller & Heckman 1150 17th Street, N. W. Washington, D. C. 20036 Martin W. Bercovici SPI 250 Park Avenue New York, N. Y. A. J. Evans 10017 -2- v NGC 16336