Document O38ewk79Br9VgRG2M6qN3XB0j

L-820 MANUFACTURING CHEMISTS ASSOCIATION MINUTES OF MEETING LABELS AND PRECAUTIONARY. INFORMATION COMMITTEE Stouffer's National Hotel Arlington, Virginia May 26, 1976 Mr. Charles J. O'Connor presided and convened the meeting at 10:00 AM. The following attended: MEMBERS PRESENT C. J. O'Connor, Chairman W. H. Jones, Vice Chairman Stauffer Chemical Company Eastman Kodak Company G. S. Batchelor H. A. Birnbaum L. W. Burnette C. U. Dernehl R. H. Dewey Fred Holler (a) Robert Jelus M. B. Lore J. S. Mackay D. G. MacKellai R. F. Philpitt R. E. Rutherford W. L. Schleyer C. Boyd Shaffer A. W. Sheldon G. Robert Sido Phillip Sonneborn C. J. Stroemple R. G. Troup J. V. Urenovitch A. G. Wheeler H. B. Woolfalk (b) J. T. Seawell, Secretary Virginia Chemicals Inc. 3 M Company GAF Corporation Union Carbide Corporation IMC Chemical Group, Inc. Allied Chemical Corporation MC/B Manufacturing Chemists E. I. du Pont de Nemours & Co. USS Chemicals - U. S. Steel FMC Corporation Olin Corporation Gulf Oil Corporation Philadelphia Quartz Company American Cyanamid Company M&T Chemicals Inc. Monsanto Company Fisher Scientific Company PPG Industries, Inc. J. T. Baker Chemical Company Air Products & Chemicals Inc. ICI United States Inc. Diamond Shamrock Corporation MCA Staff (a) For J. R. Taylor (b) For R. Craig Andrews Members Absent S. W. Beckstead C. P. Brush E. M. Dixon J. W. Hammond R. P. Ingham T. R. Madden Guests Present D. V. Anderson Delmar Billings Rita Bogoroch J. J. Bonin A. G. Chasar J. G. Contino Howard Cunningham P. G. Elsey R. L. Finocchio R. F. Gold E. L. Lewis J. F. Lemen J. P. Rakus J. J. Trexel Jack Turer Anne Waggoner R. A. Williams Frank Yanno * * L-821 Kerr-McGee Chemical Corporat Hoppers Company Inc. Celanese Corporation Exxon Chemical U.S.A. Mallinckrodt Inc. Reichhold Chemicals Inc. Amoco Chemicals Corporation MC/B Manufacturing Chemists Environmental Health Centre National Health & Welfare Shell Chemical Company Mobil Chemical Company Dow Chemical U.S.A. Witco Chemical Company Ethyl Corporation PPG Industries, Inc. Stauffer Chemical Company ARCO Polymers Inc. Hooker Chemicals. & Plastics Corp, Dart industries, Inc. E. I. du Pont de Nemours & Co. Witco Chemical Company MCA Government Relations Dept, IMC Chemical Group, Inc. Eastman Kodak Company it * * * * * 1.0 Introduction of Guests 2.0 Approval of the Minutes of the January 28, 1976 Meeting The minutes of the January 28, 1976 meeting were approved after making the following revisions: 2.1 Manual Revision Subcommittee Mr. Thomas R. Madden, Reichhold Chemicals is to be added to the roster of the Manual Revision Subcommittee. L-822 I 2.2 Phraseology on Labels Regarding Medical Assistance (Section 8.2, pages L-813, L-814 of January 28, 1976 Meeting) The phrase "Call a Physician at Once" is to be changed to read, "Call a Physician." 2.3 Explorations into the International Implications of the ANSI Standard Z129.1 - Formation of Sub committee The missions of this Subcommittee have been modified to read as follows: Section 4.0 The Chairman requested that Mr. G. Robert Sido submit the new ANSI Standard Z129.1 to key Monsanto representatives and their associates in Europe for their consideration of the document as a possible international standard on precautionary labeling. Following initial assessment of European reactions, the Subcommittee is requested to make recommendations for LAPI action. Section 4.1 International Transportation Hazard Classification. Mr. Sido was asked to form a Subcommittee to determine whether or not a comparison is available on U. S. and International Transport Hazard Classification of Industrial Chemical Products. If none exists, the group should make recommendations on ways to develop it as a tool to promote uniformity in labeling and marking. 3.0 Manual Revision Subcommittee Report The overall objective of this Subcommittee was the develop ment of recommendations for the future course of Manual L-l, Guide to Precautionary Labeling of Hazardous Chemicals for the con sideration of the full Committee. t 1 ! L-823 One of the Subcommittee's principal objectives was to outline a scope for Manual L-l which would recognize the existence of ANSI Standard Z129.1 as a valuable asset to those concerned with precautionary labeling. During the Subcommittee's deliberations, due consideration was given to the ongoing needs of the chemical industry under present and proposed regulations. Using the foregoing objectives, the Subcommittee prepared a five-point program which is proposed as a core of a Manual L-l work program. An outline of the five-point program developed is as follows: General Outline of Manual L-l (Proposed) A. ANSI Standard Z129.1 B. How to Develop a Label Text C. Government Requirements and Proposals D. Other Standards of Care E. Customer/User Literature Section A - ANSI Standard Z129.1 A copy of Z129.1 in loose-leaf form would appear as the first section in the proposed Manual. Section B - How to Develop a Label Text This section of the new Manual would contain text similar to that in Manual L-l describing the individual steps to be taken in writing a label. Section C - Government Requirements and Proposals This section of the Manual would provide a general scope of each of the acts and regulations which are known to be applicable to labeling and container markings. It would also include a list of sources of the regulations (Federal Register, Code of Federal Regulations, etc., etc.,). Pages 9 and 10 of the 1970 Edition provide an introduction to this section. L-824 This section could include references to the Department of Transportation requirements and any marking system it might adopt, IMCO Labeling, EEC and other foreign requirements. Section D - Other Standards of Care This section would contain broad-based considerations of additional standards of care and related subject matters such as container disposal, pictorial (photographic) symbols, and additional toxicological properties such as chronic health hazards. This area could also advise the reader of related hazard information systems found in the CHEMTREC system (ChemCards) and signs and placards for specific and general chemical hazards. Section E - Customer/User Literature This section will advise the Manual user that literature can become labeling under various regulations. All forms of such literature should be consistent among themselves and with package labeling. Examples include Material Safety Data Sheets, Chemical Safety Data Sheets, Proprietary Data Sheets, Product Information, and Technical Data Sheets. The motion was-made, seconded, and passed to accept the report and recommendations of the Subcommittee as presented. 3.1 Items for Consideration During Possible Subsequent Revisions in Manual L-l and the ANSI Standard Z129.1 Discussions regarding this subject centered about the following: (1) A revised Manual L-l must be kept under continuing review. A recommendation was made that this might be accomplished by means of a standing Manual Revision Sub committee together with standing Task Groups for each of the sections described under the five-point Manual Revision . Program. (2) Those sections of either a revised Manual L-l or Z129.1 which treat Government regulations will require constant surveillance and updating. L i L-825 (3) Further considerations should be given to "referencing test methods" when developing a label, i.e., on what test are label recommendations being based. (4) It appears as though general definitions will not be sufficient in the future. For example, a more definite definition should be written for the term "corrosive." Apropos of the subject of definitions is Append^ I containing definitions and recommendations present for the consideration of the LAPI Committee by dc ed C. B. Shaffer. Dr. Shaffer's recommendations, whil intended primarily for a subsequent revision of the ANSI Standard 2129,1, can apply also to future revisions in Manual L-l. 4.0 Status of the Work of the Inter-Committee Task Group on Hazard Information System_______________________________________ Dr. Warren Jones reported that the Task Group had com pleted its action and a letter report was submitted to the Department of Transportation on March 16, 1976. 5.0 Report on Section 2 for the ANSI Standard Z129.1 to be Prepared by the Compressed Gas Association Dr. Warren Jones was appointed by the Chairman to conduct appropriate liaison with Mr. Robert E. Lenhard, Managing Director of the Compressed Gas Association (CGA). During a telephone call to Mr. Lenhard which was placed immediately prior to the LAPI meeting. Dr. Jones was informed of the action taken to date by CGA, He was further advised that a letter would be sent to him summarizing Mr. Lenhard's "verbal progress report." Immediately following the LAPI meeting. Dr. Jones received from Mr. Lenhard a letter dated June 4, 1976, subject: Precautionary Labeling of Compressed Gas Containers, CGA Docket C-7-1971 in which answers to outstanding questions were confirmed in writing. Mr. Lenhard's letter of June 4th is made a part of these minutes and is presented as Appendix II. 6. i i I 6.0 t I j J ] L-8 26 Subconunittee Progress Reports and Committee Decisions and Actions on the following: 61 Hydrogen Peroxide The Subcommittee on Hydrogen Peroxide has been restructured and currently consists of the following: Mr. D. J. MacKellar Mr. J. J. Bonin Mr. J. J. Trexel Mr. R. L. Finocchio FMC Corporation Shell Chemical Company E. I. du Pont de Nemours PPG Industries, Inc. Test data are not as yet in report form. These data will be made available to the Subcommittee at the earliest possible time. 6.2 Vinyl Chloride After lengthy deliberation, the motion was made seconded, and passed that the phrase "CancerSuspect-Agent" appear in the label immediately after the leading statement "Extremely Flammable Liquid and Gas Under Pressure." 6.3 Salt as an Emetic A thoroughgoing review was presented on the reasons why further implementation of the Occupational Health Committee decision be suspended and why recommendations concerning salt as an emetic need not be discontinued immediately. Mr. Lore presented for the consideration of the LAPI Committee the following wording which may be used as a modification of existing documents wherein reference is made to salt as an emetic: "The information in First Aid and/or Precautionary Labeling for using salt solution to induce vomiting is hereby modified as follows: 'Salt solution to induce vomiting should be administered only with medical approval1." U r I i ii i < i< i 6.4 6.5 L-827 Phosgene The label for Chemical Safety Data Sheet SD-95, Phosgene as submitted to the members of the Subcommittee is acceptable. The following observation was presented in con nection with the deliberations of this Subcommittee: The question of corrosivity of phosgene is difficult to answer quantitatively, sd95, 4.2 notes "It is unlikely that there will be eye or skin irritation without involvement also of the lungs." / The draft label of 4/19/76 is based on the premise that corrosivity is a secondary hazard but that it is present. The in struction for skin and eye contact is given in SD-95 4.2.3 which reads "Contact of the skin or eyes with phosgene should be followed immediately with a minimum of 15 minutes washing with water," The Inter-Governmental Maritime Con sultative Organization (IMCO) also recommends that phosgene be labeled with the United Nations "Corrosive" label, in addition to the United Nations "Poison Gas" label. This document lends support to the SD-95 concern with potential skin and eye injury. Action on Safety Data Sheet SD-57, Methylamines The labels for both anhydrous and aqueous methylamines were approved after the acceptance of Sub committee recommendations that the word "open" be deleted from the phrase "open flame." The Subcommittee recommends that the first aid section of the label for aqueous methylamines be changed to read as follows: L-828 "In case of contact, immediately flush eyes or skin with plenty of water for at least 15 minutes while removing contaminated clothing and shoes. Call a Physician. Wash clothing before reuse." 6.6 Action on Safety Data Sheet SD-44, Chromic Acid The Subcommittee on Chromic Acid has been ex panded to include: Dr. C. U. Dernehl Dr. Warren H. Jones Union Carbide Corporation Eastman Kodak Company Action on Chromic Acid will not be completed until the Subcommittee has had an opportunity to review in its entirety the final draft of this Safety Data Sheet. 6.7 Action on Safety Data Sheet SD-46, Sodium and Potassium Dichromates The Subcommittee has been expanded to include: 1 Mr. J. J. Trexel E. I. du Pont de Nemours Toxicological data secured by PPG Industries supports classification of these products as poisons via skin absorption rather than by ingestion or inhalation. The final draft of SD-46 does not reflect these findings and appropriate revision of the SD-46 text is necessary. As soon as PPG toxicological data are made available, they will be reviewed by the Sub committee and appropriate members of LAPIC preparatory to the drafting of a label. 6.8 Action on Safety Data Sheet SD-36, Hydrogen Sulfide A Subcommittee on Hydrogen Sulfide has been appointed and consists of: .J L-829 Mr. Orton Overman Mr. A. G. Chasar Dr. C. B, Shaffer Mr, C. J, Stroemple Mr. A. Thayer Talcott Mr, J. V. Urenovitch Stauffer Chemical Company Mobil Oil Corporation American Cyanamid Company PPG Industries, Inc. Dow Chemical Company Air Products and Chemical 7.0 Proposed Federal Standard FED-STD-Hazardous Materials: Marking and Labeling Interior Containers of (Project PAK 0546) , Dated April 8, 1976__________________________________ Mr. G. Robert Sido is to be added to the roster of the Subcommittee on this proposed standard. After due deliberation on this subject, it was the decision of the Committee that those companies having an interest in and concern with this document would comment directly to the Naval Supply System Command (SUP 0321). Representatives of those companies expressing an intent to file comments emphasized the potentially productive exchange which could evolve from a meeting with Cmdr. R,, E. Plante. The Secretary will contact Cmdr. Plante in an effort to arrange such a meeting. 8.0 Recommendation of the LAPIC Concerning "Guide to Precautionary Labeling of Hazardous Chemicals, Seventh Edition,-1970" The following unanimous decision and/or recommendation was made with respect to questions presented by MCA Management: 1) Orders or requests for copies of this subject document from the current printing are to be filled under the condition that. 2) In each copy there will be inserted (or attached thereto) a letter or notification calling attention to the availability of ANSI Standard Z129.1 and that, of the two, the Standard is the preferred document. Details are to be given in the letter as to how copies of Z129.1 may be obtained, and ! L-830 3) When the current supply of the 1970 edition is depleted, no more will be reprinted. 9.0 Future Meetings The majority vote during the May 26, 1976 meeting showed that the LAPIC still prefers one-day meetings. Plans have been made and confirmed for meetings and luncheons on the following dates. October 27, 1976 January 6, 1977 May 5, 1977 JTS:er Attachments Minutes subject to approval July 16, 1976 ii j I T. Seawell T APPENDIX I PROPOSED REVISIONS IN THE ANSI STANDARD Z129.1 TO ACCOMPLISH TTTR NAMING OF HAZARDOUS INGREDIENTS IN A LABEL----------------------------- Step 1. Change definition of "hazardous chemical" to read as follows: hazardous chemical. A substance falling within either of the following categories: (1) A chemical or mixture of chemicals that is toxic, highly toxic, irritant, corrosive, a strong oxidizer, a strong sensitizer, combustible, flammable, extremely flam mable, dangerously reactive, or pressure-generating, or which otherwise may cause substantial personal injury or substantial illness during or as a direct result of any customary or reasonably foreseeable handling or use. (2) A material consisting in whole or in part of a material that is listed in Tables G-l, G-2 or G-3 qf 29 CFR 1910.93, provided that such listed material is present in such an amount that under any reasonably foreseeable condi tions of use, handling, storage, processing, or disposal, an airborne concentration in excess of the exposure limits prescribed in tables G-l, G-2 or G-3 of 29 CFR 1910.93 is likely to be released. Step 2. Change subparagraph 3.3 to read as follows: 3.3 Identification of the product shall not be limited to a nond&scriptive code designation or trade name. Regardless of the use of proprietary identification, the label shall include the following: ' (a) The common or usual name or the chemical name (if there be no. common or usual name) of the hazardous material of of each component which contributes substantially to its hazard; except that, when the sole hazard of a pressurized material is that it generates pressure, or when the sole haz ard of a material is that it is flammable or combustible, the name of the material or of the component which contributes the hazard need not be stated. "(b) The name, as used in the table, of any material listed in tables G-l, G-2, or G-3 of 29-CFR 1910.93, pro vided that such listed material is present in such an amount that under any reasonably foreseeable conditions of use, hand ling, storage, processing, or disposal, an airborne concen tration in excess of the exposure limits prescribed in the table is likely to be released. f I Step 3. Insert a new subparagraph 3.12 in paragraph 3, 3.12 The label shall include the signal word WARNING!, the statement of hazard HARMFUL IF INHALED, and the pre cautionary measure "Avoid breathing (dust, fume, gas, mist vapor)1 for a material which hazardous as defined in sub- ' paragraph.............. and which is not highly toxic by inhala tion or toxic by inhalation. 1 Select the applicable word or words in parentheses. Prepared by C. B. Shaffer LAPI Committee Meeting May 26, 1976 Copied by MCA for distribution to LAPIC - 7/19/76 - JTS:er APPENDIX II o s s t: o GAS ASSOCIATION, INC. 500 FIFTH AVENUE- NEW YORK. N.Y. 1 0036 -(212) 354-1 1 30 1 I June 4, 1976 Dr. Warren H. Jones Eastman Kodak Company 1669 Lake Ave. Rochester, N.Y. 14650 SUBJECT: PRECAUTIONARY LABELING OF COMPRESSED GAS CONTAINERS CGA DOCKET C-7-1971 Dear Dr. Jones: Please excuse my long delay in answering your letter of March 30, 1976, dealing with ANSI Standard Z129.1 and CGA plans (for developing precautionary labeling for compressed gas containers. I know that our telephone conversation prior to the MCA LAPI , Committee meeting on May 26th served to answer your questions : orally, and now I am in a position to confirm those answers in writing. We now have a reorganized task force made up of member company representatives charged with developing a revised and substantially expanded version of our present CGA Pamphlet C-7 entitled, "Guide ; to the Precautionary Labeling of Compressed Gas Containers". The ; task force held its first meeting here on April 30th, primarily to : get organized on what will be a fairly substantial task. In the ; case of compressed gases, it appears as though we will probably go i the individual product route as far as precautionary labeling text j is concerned, at least for the more commonly used gases and mixtures, j We have three broad product areas to cover, industrial, medical and specialty gases. In some of the mixture areas, we may go the generic route that MCA has tended to follow in the LAPI manual that is now ANSI Z129.1. As you probably know, we have done a good deal of work in J developing standard cylinder valve outlet configurations assigned to different gases, and have a proposed revision of ANSI B57.1 out for consideration, at the present time. It is expected that revised Pamphlet C-7 will cover as a very minimum all of the gases that are . listed in the valve standardization pamphlet. I ( COMPRESSED CAS ASSOCIATION. INC. Dr. Warren H. Jones 2- - June 4, 1976 Several years back, there was reluctance on the part of sotne gas producing companies to consider the use of standardized nrervT' ary labeling either in total or as a minimum. We think this atfi- Qn' has changed because of developments in the last year or so, but to^e on the safe side we have written the top managements of most of J? gas companies in the country asking them a specific question as tQS whether or not they would use standardized precautionary language if it was developed. We also pointed out that as far as medical are concerned, in all probability there will be an FDA regulatory^36 requirement to use certain standardized language. Our response to this letter is not yet complete, but the responses received to date urge us to develop such language and clearly indicate that it be used if available. The specialty gas part of the industry has been actively workin on this project for well over a year, and they now are in a position to be close to agreement on many of the specialty gas products that will carry precautionary labeling information. The medical gas group has also been working actively, but they are somewhat curtailed because of lack of response to date from the FDA. However, it now appears as though the FDA is going to issue good manufacturing practices for medical gases as an individual product line, and this proposed gmp will undoubtedly include references to labeling. It is the industrial gas group that is really the laggard in the total area, and by means of this newly reorganized task force we are hoping to spur them into some real constructive activity starting as of now. We hope this brings you up to date as to our activity and we will certainly continue to keep you informed regarding progress in developing a revision of C-7. When we get a proposed draft together we will see that copies are sent to the MCA DAPI Committee so that we can solicit your comments and suggestions. Once the project is complete, it is our intent to submit it to ANSI for consideration as a standard either as a Dart of Z129.1 or as a companion piece to it. Sincerely j?ours,'- f .ft y."' e.- /mf Copied by MCA for distribution to LAPIC - 7/19/76 - JTS:er Robert E. Lenhard Managing Director i