Document O1vBw0gLwde8VROrpZ3X1L7LL

G*l. 14 INTERNAL. CORR88PONDENCB i CHEMICALS AND PLASTICS 0M3M (see Distribution List) Cori* RIVER ROAD, BOUND BROOK, NEW JERSEY 08305 tMjmwtot Pt*. May 8/ 1974 Research & Development RECEIVED MAY 13 1974 A N. WHEF' *> JR. The attached letter dated May 8, 1974 was sent to the following customers with reference to the indicated resins: CUSTOMER Dr. Stewart w. Gloyer Technical Division# Coatings & Resins PPG Industries# Inc. 1 Goleway Center Pittsburgh# Pa. 15222 Mr. Robert P. Carter Aluminum Company of America 1501 Alcoa Building Pittsburgh# Pa. 15219 Mr. James Stillwagon Alcoa Laboratories Alcoa Tech. Center Alcoa Center# Pa. 15069 Mr, J, D, Gibbs Aluminum Company of America P. 0. Box 488 Richmond# Indiana 47374 Mr. George White Packaging Research Division Reynolds Aluminum 10th and Byrd Streets Richmond# Virginia 23219 RESINS Solution vinyl resins VAGIT, VMCH# VYHH# VYLF, VAGD# and dispersion resin QYNV Solution vinyl resins VMCH# VMCA# VMCC# VAGH, VAGD, VYHH, VYHD, VYDS# VYLF, VYNS and dispersion resins QYKV-A and QYOH-2A Solution vinyl resins VMCH, VMCA# VMCC, VAGH, VAGD, VYDS, VYHH# VYHD, VYLF, VYNS and dispersion resins QYKV and QYOH UCC 029546 -2- CUSTOMER Mr. L. P. Turner Kaiser Aluminum and Chemical Corporation 177 South Airport Blvd. South San Francisco, Calif. 94080 Mr. A. Bradley Inmont Corporation L-5 Factory Lane Bound Brook, New Jersey 08805 Mr. James M. Drubel International Paint Company Morris and Elmwood Avenues Union, New Jersey 07083 Mr. R. Wilkinson International Paint Company Morris and Elmwood Avenues Union, New Jersey 07083 Mr. P. K. Wolper Manager, Packaging Research Rexham Corporation Flemington, New Jersey 08822 RESINS Solution vinyl resins VMCH and VYHH. Solution vinyl resins VYHH, VAGH, VYNS-3, and dispersion resin QYNV-1 Solution vinyl resins VMCH, VYHH and VAGH Solution vinyl resins VAGH, VMCH, VYHH WBAtdeb att. W. B. Ackart UCC 029547 UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS RIVER ROAD, BOUND BROOK, N. 4, 0AB05 TELEPHONE (201) 350*9000 Dear Sir: Your request for information regarding the food additive status of "BAKELITE" brand vinyl resins when used in contact with foods has been referred to me. We have been informed that the Food and Drug Administration is considering the revocation of the prior sanctioned status of vinyl resins for use in food contact applications pending the completion of a two year animal feeding study. Our information is that an interim food additive regulation will be issued that will permit the continued use of vinyl resins in contact with foods provided the residual vinyl chloride monomer content of the food contact material is less them 10 ppm and there is no detectable monomer migration to food from the fabri cated item using on analytical method capable of showing 50 ppb in the food. . The residual vinyl chloride monomer content of the various Bakelite brand vinyl resins will vary depending upon the polymerization process used. Vinyl resins made by the solvent polymerization process and the dispersion (emulsion) process as supplied by Union Carbide Corporation involve processing operations not conducive to the retention of significant vinyl chloride monomer residues in the resin. Such resins are recovered in an extremely fine form thereby providing a surface-to-volume ratio highly favorable to efficient removal of residual monomer. The retained vinyl chloride monomer content of these PVC resins is not and has not been a specification parameter and is not therefore a measured value we can furnish from accumulated historical data. We can, however, advise you that on the basis of our UCC 029548 2 ongoing surveillance program BAKELITE solvent polymerized resins to date have been found to contain no detectable free vinyl chloride monomer when analyzed by a gas chroma tographic method sensitive to 1.5 ppm VCM. On the same basis the vinyl chloride monomer con tents of our dispersion resins have been found to vary from undectable levels to about 5 ppm. This information applies to the following BAKELITE brand vinyl resins that we supply you: we believe that these resins when used in contact with foods under conditions of good manufacturing practice will conform to the expected interim requirements of the food additive regulations CIO ppm maximum in the food con tact article and no detectable migration to food]. Very truly yours. W. B. Ackart Manager, FDA Liaison WBAtdeb UCC 029549 BOUND BROOK Gorham, W. F, Peacock, G, S. Reinking, N. H DISTRIBUTION SOUTH CHARLESTON Brezinski, J. J. #anna, R, J. Wheeler, R. N / NEW YORK Annonio, R, W. Bigelow, G. P. Dernehl, C. U, Gulick, R. E. Hardman, D, E. Steele, A, B. Whittlesey, J. Wood, W. X,, Zutty, N, L. - 33 - 33 "4 '32 - 33 *28 W."46 *-47 "32 TARRYTOWN Colwell, C. E, Niehaus, W. R. ucc 029550 * TECHNICAL SERVICE BULLETIN RESEARCH AND DEVELOPMENT DEPARTMENT OSHA CONSIDERATIONS IN THE USE OF BAKE LITE POLYVINYLCHLORIDE DISPERSION AND SOLVENT TYPE RESINS On April 5, 1974, the Occupational Safety and Health Administration, Department of Labor, published an "Emergency Temporary Standard for Exposure to Vinyl Chloride" in the FEDERAL REGISTER, pages 12342-12344. A copy of this reference is attached. The scope and application of this temporary standard is defined in 1910. 93q. (a) and we advise that you determine die applicability of this standard to your manufacturing operation. You will note that initial monitoring operations were to begin no later than April 22, 1974. The retained vinyl chloride monomer (VCM) content of our FVC resins is not and has not been a specification parameter and accordingly is not a measured value we can furnish from accumulated historical data. We have initiated a surveillance program which is intended to provide range guidelines applicable to the retained VCM content of our various resin types. On the basis of program results to date we can inform you that the BAKEUTE dispersion and/or solvent types of polyvinyl chloride resins of interest to you have generally been found to contain no detectable free vinyl chloride monomer when analyzed by a gas chromatographic method sensitive to 1.5ppm VCM. This result is not cited as a specification or as a guarantee of any sort for our products but as a range guideline to assist you in your appraisal of possible source contributors of VCM to your occupational environment. Please direct inquiries with respect to C5HA considerations to: W. R. Niehaus Chemicals and Plastics Tarrytown Technical Center Tarrytown, New York /slm TT-TL- 976 ucc 029551 UNION CARBIDE CORPORATION chemicals and plastics tarrytown technical center, tarrytown, new york THIS INFORMATION 13 NOT TO BE TAKEN AS A WARRANTY OK REPRESENTATION FOR WHICH WE ASSUME LEGAL RESPONSIBILITY NOP A3 PERMISSION OR RECOMMENOaTiON PRACTICE Any PATENTED INVENTION WITHOUT A LICENSE IT 1$ OFFERED SOLELY FOR YOUR CONSIDERATION, INVESTIGATION AND VERIFICATION,