Document Qg1q6vvxDnQ3dJgDD8Ew4L7K5

L-740 Manufacturing Chemists Association MINUTES OF MEETING LABELS AND PRECAUTIONARY INFORMATION COMMITTEE February 21-22, 1973 MCA Conference Room Washington, D. C. * * ** * * Members Present G. R. Sido, Chairman Monsanto Company A. W. Sheldon, Vice Chairman M&T Chemicals, Inc. r. C. Andrews Diamond Shamrock Chemical Company S. W. Beckstead Kerr-McGee Chemical corporation H. A. Birnbaum 3 M Company D. E. Brown Mallinckrodt Chemical Works C. P. Brush Koppers Company L. W. Burnette GAF Corporation C. U. Dernehl Union Carbide Corporation R. H. Dewey Commercial Solvents Corporation E. M. Dixon (2/21) Celanese Corporation R. H. Dunlap (for J. T. Gormally) Pennwalt Corporation ! Joseph Finley FMC Corporation (for D. G. MacKellar) J. W. Hammond Exxon Company, U.S.A. E. L. Hobson Shell Chemical Company M. B. Lore E. I. du Pont de Nemours & Company H. H. McIntyre The Dow Chemical Company L. N. Ortkiese Amoco Chemicals Corporation R. F. Philpitt 01in Corporation C. B. Shaffer American Cyanamid Company C. J. Stroemple PPG Industries, Inc. R. G. Troup J. T. Baker Chemical Company A. G. Wheeler ICI America, Inc. M. M. Hoover, Secretary MCA Staff Guests Present P. R. Arvidson G. S. Batchelor F. W. Mackison (2/21 AM) Inmont Corporation Virginia Chemicals Inc. National Institute for Occupation Safety and Health "r 53CS present! I A\ J. S. Mackay p. E. Neiman Loretta Petrauskas J. J. Robinson J. M. Sigmund J. R. Taylor Judy Tims Members Absent J. T. Gormally W. H. Jones Clarence Lowery D. G. MacKellar C. J. O'Connor R. E. Rutherford L-741 USS Chemicals Exxon Chemical Co., U.S.A. GAF Corporation Mobil Chemical Company Harshaw Chemical Company Allied Chemical Corporation Celanese Corporation Pennwalt Corporation Eastman Kodak Company MC&B Manufacturing Chemists FMC Corporation Stauffer Chemical Company Gulf Oil Corporation 1. MEETINGS a. Minutes of Last Meeting - The minutes of the September 13-14, 1972 meeting were approved as distributed. b. Next Meetinq - It was decided to hold the next meeting June 14-15, 1973 in Washington. 2. PERSONNEL a. Membership - The committee voted unanimously to recommend to the MCA Board of Directors that L. N. Ortkiese of Amoco Chemicals Corporation and A. G. Wheeler of ICI America, Inc. be appointed members of the committee. Action on a third nomination was tabled pending receipt of further information. The secretary read letters of thanks received from two former members: E. J. Masek and N. G. White. Each had received a gift from the committee in appreciation of their services. b. Officers - The committee, in accepting the report of the nominating task group, voted unanimously to recommend to the' MCA Board of Directors that A. W. Sheldon and R. G. Troup be appoin L-742 chairman and vice chairman, respectively, for the cwo-year term starting June 1, 1973. The nominating task group consisted of R. F. Philpirt (chairman), H. H. McIntyre, and C. B. Shaffer. 3. LIAISON ACTIVITIES a. American Congress of Governmental Industrial Hygienists Mr. Hammond reported that he had nothing additional to add to his report distributed August 25. This report concerned the threshold limits adopted by ACGIH for 1972. b. American National Standards Committee Z35 (Symbols) The secretary referred to his report concerning Z35.3 and related matters which was sent to the committee February 14, and Mr. Troup discussed briefly the two attachments to this report concerning meetings he attended. c. American Petroleum Institute - Mr. Hammond reviewed his report which was distributed at the meeting. d. American Society for Testing and Materials - Mr. Lore reported that the ASTM E-34 Committee (Occupational Health and Safety Aspects of Materials, Physical and Biological Agents) has been formed, that several LAPIC members are participating (Messrs. Dernehl, Dixon, Hammond, Jones, Lore, and Sido), that Messrs. Sido and Lore have applied for membership on the Labeling Task Force under the Safety Subcommittee, and that he is tentatively the head of this task force. He reported further that the operating scope of the E-34 committee is at least as broad as the Occupational Safety and Health Act, and that consensus documents are to be written for individual chemicals (according to a priority schedule, and not to conflict: with the work of other standards organizations) for adoption as standards under this act. He urged LAPIC members to join the E-34 Committee to provide labeling expertise. e. Association of American Pesticide Control Officials Mr. Lore reported that he commented on AAPCO1s draft document "Proposed Classification Plan for Restricted Pesticide Uses and Precautionary Labeling," specifically with regard to the proposed change to the LD^q for "highly toxic, oral" from its long established value of 50 mg/kg to 100 mg/kg. He suggested that this term and its equivalents should mean just one thing for all kinds of products and all kinds of regulations, and requested that it not be changed unilaterally for pesticides without contact ing FDA, DOL, DOT, etc. L-743 f. Chemical Industries Association Ltd. - Mr. Sido reDort that A. E. Meadowcroft of Monsanto Chemicals Ltd. has been made f new chairman of the CIAL Hazard Warning Committee, and that he m be in this country at the time of the next LAPIC meeting so as to^ be able to attend. g. Chemical Specialties Manufacturers Association - Mr. l0c reported that CSMA appeared at a hearing on the DOL (and DOT HM' 102) proposals relating to definitions for combustible and flammable liquids, and that the chairman of CSMA's Labeling and Regulatory Advisory Committee is attempting to establish an inter-industry roster of labeling specialists to be available from time to time to consider broad labeling matters (such as when it appears that a new labeling proposal for one class of products might ultimately apply to, or be useful with, other classes). He said the next meetings of the LARA Committee are scheduled for March 4-7 and Mav 13-16. Y h. Foreign Governments - Dr. Birnbaum reported that Sweden hasa new labeling law, and that Switzerland has new labeling regulations. He said he would send a translation of the Swedish law to the secretary for distribution to the committee. Mr. sido said he would supply a description of the new Swiss requirements, also for distribution to the committee. i. Inter-Industry Advisory Committee on Product Information. The committee voted to recommend that MCA appoint a representative from LAPIC to this inter-industry committee, now being reactivated for the purpose of developing an inter-industry recommendation for a symbolic labeling system suitable for adoption as a national standard. There was one comment from the committee to the effect that even the inter-industry committee would not be broad enough to do the job. The secretary mentioned that it will be necessary to specify that MCA needs to approve any action taken by the inter industry committee which claims to represent the position of all, and that the right to make an independent expression needs to be reserved. Mr. Lore said that CSMA will serve as the secretariat, and Mr. McIntyre said that the first meeting will be held at CSMA headquarters in New York on March 20. j. MCA Board of Directors - Mr. Sido stated that he reported on LAPIC activities at the January 9 meeting of the MCA Board, and that copies of his report have been sent to the com mittee. Compliments on this report were made from the floor. k. MCA Ad Hoc Committee on Chemicals Regulation - Dr. Shaffet reported that, since Congress failed to pass toxic substances legis' lation in the last session there is renewed activity, that S. 426 L-744 (Toxic Substances Control Act of 1973) appears to be quite similar to the former Senate Commerce Committee bill, and that hearings are underway. 1. MCA Occupational Health Committee - Dr. Birnbaum reported that OHC has discussed industry assistance to NIOSH in response to the recent Federal Register notices requesting information on various chemicals. m. National Agricultural Chemicals Association - Mr. Sido reported that he had nothing to add concerning labeling of pesticides beyond that reported under Minute 3e. n. National Fire Protection Association - Mr. McIntyre reported that NFPA at its annual meeting in May will vote on withdrawal of NFPA 326, and on changing from 140F to 100F as the flash point cut off for classifying liquids as flammable. o. National Paint and Coatings Association - Mr. Lore reported that NPCA's revised guide for the labeling of household paints is about to be released, that their labeling committee's next major project is to add an industrial finishes section to this guide, and that the next meeting of the labeling committee is to be held March 14-15. p. State of Michigan - Mr. Sheldon said there was nothing new to add to the information sent to the committee October 27 concerning Michigan labeling standards. q. State of Arizona - The secretary reported that Arizona is apparently considering introducing labeling requirements based on correspondence with the industrial hygiene chief. r. State of Indiana - Mr. McIntyre reported that a bill has been introduced to update this state's labeling act. s. U. S. Department of HEW (NIOSH) - The secretary reported on his January 17 exploratory visit with Frank W. Mackison of the NIOSH Office of Research and Standards Development. Following this, Mr. Mackison joined the meeting to further discuss NIOSH's labeling activity. Mr. Mackison said their objective is to develop a general labeling scheme that will be the best devisable from the standpoint of the worker, that their scheme will be referred to the OSHA Advisory Committee on the Labeling of Hazardous Materials, that the scheme will embrace physical and biological hazards as well as chemical, that they will concentrate on normal conditions of use L-745 (not fire or other emergency situations), that placards and material safety data sheets as well as labels will be involved and that a field test of the scheme will be made (using perhaps 10 compounds). He explained further that plans call for the field test to go to individuals (medical people, toxicologists, industrial hygienists) in various fields (academic, industry, and labor) and to state and local health departments. Comments from the floor were largely to the effect that many disciplines would be required to evaluate the proposed scheme rather than one, and that MCA could contribute effectively to its development. Mr. Mackison replied to these comments by indicating that general labeling specialists could be included among the indi viduals to be asked to participate in the field trial, that he will take back the committee's concerns about lack of multiple categories of expertise and about not being involved in the development of their scheme, and that Drs. Powell and Key will have to decide about working with MCA as an association. Following Mr. Mackison's visit, the secretary reported that he had sent to NIOSH MCA labels, in response to the November 10 and December 27 Federal Register notices requesting information on various chemicals, and that he planned to do the same in response to the January 30 Federal Register notice. Later the committee reviewed Dr. Shaffer's letter of October 13 co Mr. Sido (copies to the committee) on the subject of "Material Safety Data Sheet". The committee voted (one negative) to approve the draft MSDS attached to this letter with the follow ing changes: (1) change the base in Section 2.8 front 1 to 100, and (2) delete Section 2.9 as it is and replace it with pH (aqueous solutions), retaining the same section designation. This approval also included the recommendation that the revised sheet be approved by MCA and forwarded to NIOSH with the suggestion that NIOSH reconune: it to OSHA. The committee then voted unanimously to recommend that MCA approve confining the use of this revised sheet to the followin: categories of products: (1) products classified as "hazardous" (including NOS products) under DOT regulations, (2) products con sisting essentially of a single chemical substance for which a standard (TLV or other) has been set, and (3) products which are mixtures and which include 10 percent or more of a component for which a standard has been set. Dr. Shaffer agreed to provide a new sheet containing the above indicated changes. t. U. S. Department of Labor - The committee noted that Dr Shaffer was nominated by MCA as a member of the OSHA Advisory cc P: 4. U t; S' o: bi s< cl f. tl tl P< F o3) 1 1; f< o nu f o T s ro mr L-746 I committee on the Labeling of Hazardous Materials. This nomination I was made October 26. (Note also Minute 3s which refers to OSHA A in two places.) u. U. S, Department of Transportation - The secretary reported that MCA replies to HM-102 and HM-103 were sent to the committee, and the committee noted that the HM-8 notice involving pictorial symbols was to appear in the Federal Register momentarily. 4. COMMITTEE PROJECTS \ a. Manual Revision - With regard to pictorial symbols for labels, the committee voted (two negatives) to have recorded in the minutes that there is little purpose in the use of these ' symbols on product labels at this time due to insufficient degree | of public recognition of them and lack of uniformity in their use, I but that the committee should not stop its effort to develop them so as to have them when needed. The Manual Revision Subcommittee was requested to investigate changes to the hazard statements and precautionary measures for s flammable and extremely flammable products, and to investigate \ the matter of an ingredient statement on labels in the light of ' the recent NIOSH proposal regarding disclosures of mixture com* position. Copies of the February 6 memo to the MCA Safety and Fire Protection Committee regarding this proposal, along with two other related documents, were distributed at the meeting. Dr. Shaffer suggested that ingredients for which there are regulations limiting worker exposure might well be identified on product labels by name as such. Mr. Sido requested that Dr. Dernehl's task group on Labeling 5 for Genetic and Tumorigenetic Effects report at the next meeting of the full committee. 3 jnd There was no discussion of the minutes of the November 30 : meeting of the Manual Revision Subcommittee per se. ig b. Label Preparation (General) - The chairman stated that the objective of the committee should be to complete the update of all chemical safety data sheet labels by the end of this year. The secretary indicated that this would involve acting on sub stantially more labels at the next two meetings than at previous meetings,and that he will schedule to meet the objective. c. Label for SD-1 (Formaldehyde) - Action on this label was I tabled pending receipt of more data. ___________ L-747 d. Label for SD-6 (Paraformaldehyde) - Action on this was tabled to provide adequate time to study the latest draft A The secretary was requested to send this draft to the committee e. Label for SD-17 (Aniline) - The committee voted (one negative) to accept the draft label as revised at the meeting. f. Label for SD-19 (Dimethyl Sulfate) - Action on this ig^ was tabled pending revision of the data sheet to be requested. g. Label for SD-21 (Nitrobenzene) - The committee voted (0n negative) to accept the draft as revised at the meeting to corres6 pond with the label for SD-17 (Aniline). h. Label for SD-26 (Phosphorus Oxychloride) - The committee tabled action on the draft label sent to the committee January 3 i. Label for SD-28 (Phosphoric Anhydride) - The committee voted unanimously to accept the draft label as revised at the meet-, ing. j Label for SD-31 (Acrylonitrile) - The committee tabled action pending a.-draft label to go to the committee. k. Label for SD-34 (Tetrachloroethane) - The committee voted unanimously to accept the draft label as revised at the meeting. l. Label for SD-52 (Sulfur Dioxide) - The committee tabled action on the draft label distributed at the meeting to permit time for consideration. m. Label for SD-54 (o-Dichlorobenzene) - The committee tabled action on the draft label distributed at the meeting to permit time for consideration. n. Label for SD-55 (Butadiene) - The committee tabled action on the draft label distributed at the meeting to permit time for consideration. o. Labels for SD-57 (Methylamines) - The committee voted unanimously to accept the draft labels for Anhydrous and Aqueous Methylamines as revised at the meeting. p. Label for SD-58 (Naphthalene) - The committee tabled actio: on the draft label pending rework by the task group in view of &eW data distributed at the meeting and furnished by Mr. Brush. bei (ne :es:e 3. 'Qet1 r. =d .bled L-748 q. Label for SD-59 (Propylene) - The committee voted unani mously to accept the draft label as revised at the meeting. r. Label for SD-60 (Arsenic Trioxide) - The committee tabled action on the draft label distributed at the meeting to permit time for consideration. s. Label for SD-100 (Ethylene) - The committee tabled action on the draft label which had been circulated among the task group to permit its distribution to the full committee prior to the next meeting. t. Label for Antimony Oxide - Mr. Sheldon reported that the task group has agreed to obtain data to determine whether or not the substance is a sensitizer. The task group met-February 20 in the MCA offices.. This meeting was attended by Messrs.. Sheldon (chairman), Halbadel, Hurley, Nixon, Vamos, and Hoover. M. M. Hoover, Secretary MMH:gr February 27, 1973 Distribution "A" Copies to: Board Liaison Committee-Environment ion r s ctio'