Document RoE46Xy8ddgKJLNdYzqVrxK8

/ BORDEN, INC. 960 KINGSMILL PARKWAY. COLUMBUS. OHIO 43229 MARK A. GRUENWALD, C.I.H. MANAGER PRODUCT SAFETY & TECHNICAL SERVICES August 3, 1987 Mr. Peter L. de la Cruz, Keller & Heckman 1150 Seventeenth Street, Washington, D.C. 20036 Esquire N.W. RE: OSHA LABELING Dear Peter: Dr. Gottesman suggested I send to your attention the attached letter we received from OSHA concerning target organ effect labeling for PVC. In light of your ongoing discussions with OSHA concerning a clarification on the labeling of PVC as a carcinogen under the Vinyl Chloride Standard and the Hazard Communication Standard, I believe you might also want to address the issue raised in the attached letter at your August 24 meeting with Frank White at OSHA. This appears to be a generic issue for the PVC industry as a whole to address. In the interim, we plan to contact the OSHA area office in Illinois to determine the basis for their "suggestion". We would appreciate any comments that you might have on this subject. Sincerely, Mark A. Gruenwald MAG:sis:attachment cc: Dr. Gottesman VVV 000015063 TELEPHONE: (614) 431-6610 TELEX: 246*692 / /t U.S. Department of Labor July 8, 1987 Occupational Safety and Health Administration 344 Smoke Tree Business Park North Aurora, Illinois 60542 (312) 896-8700 Borden Chemical Division Borden, Inc. 180 E. Broad Street Columbus, OH 43215 Attn: Mark Grenwald Dear Mr. Grenwald: Representatives of the Occupational Safety and Health Administration (OSHA) recently visited the following company: The above mentioned company purchases the following chemical(s) from you: PVC Homopolymer At the time of the visit, labels on shipped containers of hazardous cheraical(s) supplied by your company were found to be deficient in the following areas: The label did not give a proper hazard warning to include the following: Respiratory Irritation, Eye Irritation which is target organ and effect. You are required under OSHA's Hazard Communication Standard (29 CFR 1910.1200) or your State's right-to-know law to perform hazard determiations, label outgoing containers properly and provide copies of MSDS for all hazardous chemicals which you produce or import. A copy of the standard is provided for your reference. Please immediately send proper labels for the containers of hazardous cheraical(s) listed above to your customer. Thank you for your assistance. If you have any questions regarding this matter, please feel free to contact me at (312) 896-3700. S1 nrprpl v . VVV 000015064 Kenneth Yotz Area Director RCE^E0 Thomas G. Grumbles VISTA To D S<2_ Date P\ \ \"0A-i_ Cl- lO ~*VL etc . lo <3^50 Q_e_- o A ^LG^> tea V3 .0 ba^CGlU^ OOQ\tiA^ tctZ_ LJ <Y\ -aor*\ \joa of*- (YVitsor\ as to LoV\at cxOt^^l ^pEd^ocit "to test, NXa-fcso^ Vacls c^wvtO tVQ-- -te>> 4\ ^ , L^Wo./\ cQe,avtV\e Scv^<pl<o rr\o.\^^ ft o-ill a|co. (<. Idj to C^-4 R-^'dnJ Its , Q.CS CLq.cl\ V^^ooTT VVV 000015065