Document RJze49eoQ65oO7Z7wRVB9BLjX

FILE NAME: Reichhold (REI) DATE: 1939 July 18 DOC#: REI044 DOCUMENT DESCRIPTION: Unpublished Internal Report ^kfimud J&miislj iuu) JHanjuer Association ot/ncuts M iiiu x r -- u m r t. r m c u u m t h I 2201 TVIKCAI-I'HVUI IIDO--K KIT.--I.FNDAATLACLI..HrUatIuIiMiuIaI u, C H IU "M u t i n u i - m u i L . iit o n . w *n n tw C S C N K L -- N . a MACDONALD, f u . i . t l u NCORPORATED N EW YO R K AVE. N.W.. W ASHINGTON . OPPICE OP TH E PRESID EN T July 18, 1939 D. C. M I0 N A L 1 i. nit u iilM 'n . i, iiftia . i ; ii n u t . r i i - 1 a tu t ieo:iitLi :rt.'l TO CLASS A VL'^ERS CONFIDENTIAL Not for Publication Tcxic r.*tjrials with their ever-present problens require our conscientious ccr.iiderttion of the fundamental principles involved. The National Faint, Varnish and Lacquer Association is keenly interested in providing Class A rrinhers with .is mucn information on this subject as is practicable at this t ir e . This in fo mat i or. being confidential is not intended for general publication, - i t is being sent only to the Class A group. Please respect th is confidence. The v ita l factor concerning toxic ..ateriols is to in te llig e n tly safeguard the public. People nay fe c i safer in buying materials whose danger they know rather than materials unknown to them. Ke trust the several phases presented herein w ill be of some benefit to members in applying every precautionary erasure in r-jiufacturing, in selling and in use where toxic materials are lik e ly to or do enter a product. Toxics and their effects is e subject very broad ir. scope und can- only b rie fly be treated in this message. Children's toys, equipment, furniture, e tc. are not the only consideration. Toxics - compounds used in points or lacquers may have harmful effects i f carelessly handled. Toxic tutorials 003- enter tho body through the lungs in the form of dust, mist, vtpors, or gases, through the skin, or through the mouth and stomach, materiel inhaled into the nose and mouth can dissolve in the saliva and be swallowed. Irritan t materials may also have a direct action upon tno skin and the mucous nimbranes of the. eyes,nose, mouth,and threat. It must be remembered that a l l people do not react in the some way when exposed to chemicals. Some may be quite seriously affected by quantities which are harmless to others. Hence, i t follows that any one using point and A llied prod ucts should provide adequate ventilation and should observe ordinary sanitary measures such as the washing o f the hands and face before eating and keeping the clothes clean. Dirty work clothes, including shOt.s, can ba- an important source of skin absorption. Some of the- ingredients o f points and a llie d products night receive apodal mention because of thoir sp ecific e ffe c ts , rather than because they uerely displace part of the a ir or cause slig h t discomfort i f taken into the stomach or system. NCA D 02901 N 68 / - 2- thre i s much evidence tv. in d icate t'.i&t i t is a to x ic m etarial.) Any cases o f suspected antimony poisoning have been traced to the Accosjvmyixjjj l u .d , Arsenic Compounds. Paris green or other compounds containing arsen ic. C:vv.i-a.. C..;'xiuK su lfid e s raid splenides ore t o x ic , but belong to the i i icon u:ed pigments. Chr-j.v.t;. Chro.-ates o f n i l typos are understood tc be rv -iati.-cly t c x ic . Chromium oxides _re r e la tiv e ly nor.-toxic.' U-.c: "ocoounas, Waite le rd , red le a d , iitn r x g c , load chior.itos (chror.c yeilew , chrome green), or other lead pigments. fer:u n '. r.er .ury. Rad ur.d y e llo v oxides o f tarcury or other products containing - Liquids - Alcohols. The t o x ic it y o f nethyl alco h o l i s vtry w ell xtooti. a s used in lacquers, the other alcohols are re la tiv ely harmless. b5Rio'L.~ T rie i s prcbabl/ tnr. yost dangerous c f a l l cu cn trcia l so lven ts, but i t s use ir. our industry i s r-rohably re s tricte d to ce rtain paint tnd v.-.nish recovers. C lo rlr.atod Hydrocarbons. Carbon t it r ic h lo r id e , trich lor ethylene, CtlT.chlorcthnnc, uthyl7.ve u ic iilo rid e , usd s ia ila r chlorinated a l i phatic hydrocarbons ere said to ce very d otjoroas t o n e s . Chloricu-ted i-n a-tic hyui oc .rbor.a ru "id to be -ter- to x ic t.'i a tuc corror^onnu-.g `'.yurociurtSon l t - o i f , but suae chlorinated area t ic s are frequently tne source of ;`kin tro u b les. Lsccuer So lven ts. There is some evidence that the a ce ta te s-- d th y l, butyl und cmyl--a rc nioro cr le s s t o x ic . Acetone ar.d t in ct'ner ketones are re la tiv ely hrrmless. Hc-t other solvents used to a lts a v r extent are e ith e r harmless in thens e lv e s , are used in such re la tiv e ly small amounts, or arc ss slowly evaporating that they present no hazard. Methyl A lco ho l. The use o f th is product should be avoided. I t is d e fin ite ly poisonous. Solvent Naphtha. T his i s also r e la t iv e ly non-toxic as compared to ben zol, end probably le s s to x ic then to lu o l end x y l o l . T u lu ci end X y lo l. In equal concentrations, those aro said tw be more toxic than benzol, but because they ere le s s v o la tile the actu al hazard is usually le s s . MCA 0 02902 / - 3- Trteresvl Phosohataa. The pira- and zeta-tricresyl phosphates which are used as plasticisers are non-toxic* Ortho-tricresyl phosphate, on the other hand, i*. a violent poison. Turpentine and "ineral Sp irits. These products are relatively non-toxic but are s t i l l listed in works on toxicology as causing ecseaa and ir r i tation of the skin end mucous mezbrunos. Some people exposed to the : _~ei .re subject to intelaiai disorders when breathing substantial enour.ts of turpentine. Kir.srsl spirits is less toxic then turpentine. C^her rlf.stlcizers. Very l i t t l e is known regarding the toxicity of other c.-ruoon so-called chemical plasticizers, but the hazard from v o la tility or dust is , of course, snail. ?ne main ccncidsration, whenever paint products ore used, is constant repetition to the paint consumer of the necessity of employing adequate ventilation and maintaining personal hygiene. Printed V.atter - Color cards and advertising literature should not in c lu d e any reference by the use of words or sketches to indicate or recom mend a product for children's toys, equipment, furniture, e t c ., unlessit is absolutely free from toxic mntcrials. Ncr.-Foiscnous Colors - I t is generally conceded there is relatively l i t t l e danger of toxic effect from paints on toys and nursery furniture, as both the paint manufacturer and the toy manufacturer are fam iliar with the types of non-poiscnous pigments to use. Nevertheless, the individual company should constantly guard .gainst using any to)d.c material, especially lead compounds, in products for finishing children's toys, etc. Note: (See pzge #7 of "Odds and Ends" , a special circular of the S cien tific Section Notional Paint, Varnish and Lacquer Association, issued August 1938.) Grcwn-ups are exposed to some hazards cs in the case of children. There fore products for finishing pencils, and other article s that may be placod in -the mouth, through habit, require the use of toxic-free o aterials. Labeling - No d efinite procedure is recommended for labeling. Labeling is serious since i t becomes a public matter with the question as to what would result IX th is were done. Each manufacturer on ably cope with the toxic material situation by constantly safeguarding the public through the prod ucts he manufactures end by the repetition of instructions to salesmen, service men and others who con in telligen tly instruct the consumer of the advantages of providing adequate ventilation and of n&intiining personal hygicna. General - The statenant of legal principles listed below was prepared for wnd distributed by the Manufacturing Chemists' Association for the guidance of its iradbsrs concerned with labeling problems, and ia supported by decisions of the courts. Although the principles set forth ere not entirely the result of litig a tio n Involving material used by members of our industry they are nevertheless generally applicable to situations arising freo the use of harmful substances. NCA 0 025DJ / -L - ilanufacturing Chemists' Association Legal Principles X. A manufacturer who puts out a dtngcrdus urtielu or substance without uccofipunying-it with u warning at to it s dangerous properties is crcir.arily lia b le for any damage which results from such failu re tc warn. 2. A manufacturer or dealer who erroneously labels a dangerous drug with the name of a harmless substance is lia b le for any injury which nay be caused thereby. 3. Failure to comply with c statute, e .g ., with rasyect tc labeling ptisens, is usually held tc be negligence per sc or ct least evidence of negligence. C. The name of the product alone may be su fficien t wurning, i f its na ture is vary widely known or it s sf:le is restricted to those who arc pr4S'used tc know it s nature, but even In such cases the advisability of a sp ecific warning is indicated. 5. Technical accuracy nay not be su fficie n t protection for the nanufecVsrer i f he uses words which nay give the purchaser the impression that his product is not -.het i t actually i s . 6 . A nonwarranty of results is net a warning against possible dengerous r e s u lts ._ 7. The consumer is entitled to rely on positive representations or d i rections appearing on the label unless ho knows them te be incorrect. 8 . The manufacturer is ordinarily not lia b le i f his product is put tc a use for which it is not intended and an injury re su lt: which could net reasonably have been foreseen. I t is often d iff ic u lt , however, to knew whether o particular result should have been foreseen, and the courts are apt to d iffe r on this point. 9. The manufacturer or one who holds himself out tc be the manufacturer must know tho qualities of his product ana he cannot escape lia b ilit y on the ground that ho did not know i t to bo dangerous. 10. The general rule that a manufacturer is net lia b le to these not in privity of Contract with him does not apply when his product is Immi nently or'inherently aangerous. Ccnclusion - Re grant that this is a very broad subject, and doubt i f a conci:; set of rules can be established. Kovortheless, i t say be saia that our members can meet their individual problems in safeguarding the public, including of course our own factory employees, by their sincere effo rt in taking advantage of every possible proccution in the use of toxic materials in manufacturing, selling and in use* Such precautions plus constent repetition of in te llig e n t instructions w ill, i t is believed, secure the best resulfrsr1 ETT:mt) HIE A 0 0 2 2 0 4