Document OVRqvgmKBY6nb7K7eeqpRbB1

TO: Mike Abadi FROM: DATE: Interoffice Communication SUBJ: Tom Grumbles June 25, 1985 MURIATIC ACID FOOD GRADE STATUS VISTA Enclosed is the letter we discussed regarding the Food Chemicals Codex specification for by-product., acid organic contaminants. As we discussed, at this point in time we can only say that our acid meets the total organic and benzene specification levels as defined in the new edition of Food Chemicals Codex. Hopefully, FDA will accept this specification when making their final determination on the GRAS status of by-product acid. Thomas G. Grumbles ajo/007 Enclosure WV 000016862 FROM: BATE: Interoffice Communication SUBJ: Tom Grumbles June 24, 1985 SDA AD HOC COMMITTEE: CLASSIFICATION ALCOHOL ETHOXYSULFATEHAZARD VIST/ The subject meeting was held on...June 21 at SDA. Representatives from Shell, Proctor 5c Gamble, Texize, Monsanto, GAF and SDA attended. The basic issue was the DOT exemption for aqueous solutions containing less than 24% alcohol. These solutions have measured flash points below 100F which puts them in the flammable liquid classification. However, DOT allows them to be classed as combustible liquids for classification purposes. Shell had raised the issue of whether this exemption was appropriate based on the actual hazard of the materials. The collective experience of those attending was that the combustible classification appropriately describes the hazards of affected materials. In our case 1412-A and 1412-S. To reclass these materials as flammable would have impact on the following areas: 1. Container labeling: combustible liquids in containers less than 110 gallons are exempt from DOT hazardous materials regulations. 2. Transportation logistics: for example flammable liquids are prohibited on some bridges and in some tunnels. Most quantities of flammables are prohibited from some air shipments. 3. Transportation costs: in some cases it is more expensive to ship flammables. 4. Other: building codes, fire codes, insurance rates, etc., may be affected by the more hazardous flammable classification. Based on the above, those attending were confident combustible classification appropriately described the alcohol ethoxysulfates and other similar alcohol containing less than 24% alcohol. that the hazard of solutions yyy 000016863 However, a complicating factor is the 0SHA Hazard Communication Standard labeling requirements which are effective November 25. 0SHA requires all "containers" of hazardous materials to be labeled. 0SHA has the same classification scheme for physical hazards. Materials with flash points less than 100F are classed as W. J. B. Vogel Page 2 June 24, 1985 flammable, OSHA has no exemptions for aqueous solutions. In other words, a 55 gallon drum of 1412-S must be labeled as a flammable liquid. This regulatory conflict will be pursued by SDA. Please let me know if you'd like to discuss the above. CTV^------ ----------Thomas G. Grumbles ajo/007 cc Paul Gowan Carl Kerfoot Gary Draper Wayne Hilgers vvv 000016864