Document V32B8kMyRaQRKqDeBe8aEavwo

& Manufacturing Chemists Association OSH 6-1 Minutes of Meeting OCCUPATIONAL SAFETY AND HEALTH COMMITTEE Stouffer's National Center Hotel Arlington, Virginia March 15, 1979 Mr. De Martino convened the meeting at 9 a.m. The record of attendance follows: MEMBERS PRESENT Carl De Martino, Chairman Richard L. O'Connell, Vice Chairman Linda M. Casey Emil E. Christofano Robert M. dyne R. D. Fulwiler Benjamin B. Holder Phil C. Holladay (for Howard L. Kusnetz) John M. Pardee Robert E. Rutherford W. Mayo Smith Jack S. Snyder Arlin G. Voress Milton Freifeld, Secretary E. I. du Pont de Nemours & Company Olin Corporation Ashland Oil, Inc. Hercules Incorporated American Cyanamid Company The Procter & Gamble Company Dow Chemical U.S.A. Shell Oil Company Eastman Kodak Company Gulf Science and Technology Company Air Products and Chemicals, Inc. Merck & Co., Inc. Union Carbide Corporation MCA Staff PRESENT BY INVITATION Geraldine V. Cox H. Christopher Nolde John G. Tritsch Jay A. Young MCA Staff MCA Staff MCA Staff MCA Staff At this open meeting 38 representatives from 31 companies were present. MEMBERS ABSENT Richard 0. Howard Frank A. Ubel Virginia Chemicals Inc. Minnesota Mining and Manufacturing Co. CMA 060487 OSH 6-2 1.0 Minutes of Meeting January 18, 1979 The last phrase in Paragraph 2 of Minute 8.0 should read "...was referred to the Engineering Advisory Committee." with this change, the captioned Minutes were approved as distributed. 2.0 Federal Cancer Policy Dr. Holder noted the issuance of two documents recently which represent an attempt by the government to give substance to a federal cancer policy. The first is a risk assessment paper by the Interagency Regulatory Liaison Group (IRLG). It is intended to provide a common scientific basis for assessing carcinogenicity of materials for the four leading concerned agencies. Each agency is then expected to apply the results in accord with its enabling legislation. Notice of the availability of this document and request for comment are expected in the Federal Register shortly. Also mentioned by Dr. Holder was the February 1, 1979 report, "Identification, Characterization and Control of Potential Human Carcinogens: A Framework for Federal Decision-making", of the Office of Science and Technology Policy, Executive Office of the President. A final generic regulation on carcinogens is expected from OSHA in May of this year. An MCA statement of February 26, 1979 on cancer policy to the Con sumer Products Safety Commission stressed the need for uniformity among agencies on this matter. ACTION: The Task Group on Federal Cancer Policy (Dr. M. N. Johnson) will draft a response to the IRLG paper. 3.0 Publication Program 3.1 Chemical Safety Data Sheets (SDS's) Three SDS's (Chromic Acid, SD-44; Acetaldehyde SD-43; and Dimethyl Sulfate SD-19) have been through two rounds of review, said Dr. Young. They served as test cases for the preparation of sample labels according to the guidelines on chronic hazard labeling. Sixty-eight responses regarding these drafts were received, plus one stimulated by the notice about them in MCA News. Following Executive Committee approval of the Chronic Hazard Guidelines and completion of the final review process for the drafts, these three SDS's will be published. The next subjects for revision or reaffirmation, according to Dr. Young, are SD-16 Phosphorus; SD-101 Sulfur Trioxide and a film on Sulfur Trioxide Spill Control. * \ i s j | 'j | | i ^ $ f i i 4 CMa 060488 OSH 6-3 3.2 Chem-cards and Cargo Information Cards Dr. Young believes that current procedures for approval of revised captioned cards are appropriate. At present drafts are reviewed and ultimately approved by industrial experts from member companies familiar with the chemicals treated in the cards. The OSH Committee, however, may wish to suggest a different procedure. ACTION: Freifeld - discuss with OSH Committee officers alternatives such as designating a task group to evaluate the current practice and suggest modifica tions . 3.3 Federal Trade Commission (FTC) Proposal on Standards Dr. Young reported that the Engineering Advisory Committee (EAC) is addressing an FTC proposed regulation under which certain MCA publications may be defined as standards. This could include SDS's and safety guides. This FTC proposal appeared in the Federal Register, December 7, 1978. The deadline for written comments as testimony is April 30, 1979. ACTION: matter. Freifeld - arrange for OSH Committee coordination with EAC on this 3.4 Chronic Hazard Labeling The task group on this subject met on March 6, said the Secretary, and revised the draft of October 15, 1978. The earlier draft placed warnings about carcinogenicity or embryotoxicity before any Statements of Hazard required by Section 4.1 of ANSI Z129.1 and before warnings pertaining to other significant chronic effects. The revised draft places all chronic hazard warnings between Statements of Hazard requiring the signal word "DANGER" and those requiring the signal word "WARNING" according to the ANSI Standard. In addition, some minor editorial changes were made. The task group also discussed alternative statements for two sections of the guidelines. These dealt with warnings regarding suspect carcinogens based on animal data and embryotoxins. The task group left the final choice in these two cases to the parent body. It also recommended acceptance of the guidelines by the OSH Committee. A suggestion was made to conduct a letter ballot on the wording alternatives and adoption of the guidelines. Following discussion, however, the Committee adopted A motion to vote during this meeting on wording choices where appropriate and whether to recommend the guidelines. The motion was carried by a margin of 8 affirmative to 4 negative votes. CMA 060489 OSH 6-4 The results of voting on the choices of phraseology and adoption of the guidelines were as follows; Question #1 Question #2 Question #3 Section 2.2.2 Cancer-Suspect Agent _2 Causes Cancer in Laboratory Animals _1 Use either one, as appropriate _9 Section 2.3 Can Cause Damage to Pregnancy __1 Can Cause Damage to Unborn Child __4 Use either one, as appropriate _7 That guidelines for chronic hazard labeling revised March 6, 1979, with Questions #1 and #2 as decided above, be recommended for adoption by MCA for internal use; Yes No 2 (one member abstained from voting on #1 and #2) ACTION; Freifeld/Young - revise guidelines as indicated above. Forward revised guidelines for Executive Committee consideration at their April 10, 1979 meeting. 4.0 Epidemiology Dr. O'Connell indicated a number of comments had been received following distribution of the draft document, "Model Modules and Suggested Guidelines for Gathering Epidemiologic Data." He therefore plans to re convene the task group to revise the draft in light of suggestions made and questions raised. A discussion ensued about informing the association membership generally concerning progress on this type of project. It was felt an opportunity for their input should also be provided. As part of the discussion on involving a wider segment of the association's membership, Mr. Pardee suggested creation of three standing subcommittees on safety, health and labeling respectively. They could act as resource groups and advisory bodies. ACTION: 1) Freifeld - combine comments received and distribute them to task group in preparation for revision of draft document. 2) Freifeld - arrange for wide distribution of the revised draft document. Notice of its availability in MCA News may be a good means for accomplishing this in addition to direct mailings. 3) Freifeld - pursue wittr Committee officers and MCA management possible implementation of Mr. Pardee's suggestion regarding standing sub committees . CMA 060490 OSH 6-5 5.0 Embryotoxins Draft guidelines on this subject are being final typed and should be available for Committee comment shortly, said Dr. Clyne. 6.0 Liaison Dr. Fulwiler reported that responses to survey letters indicated that nearly all posts for desired liaison with professional and trade organi zations are filled. Retirements will make some changes necessary. Mr. Pardee suggested that new members of the Committee, starting June 1, be substituted for Committee members leaving on that date who have liaison functions with other associations. This would provide a more direct linkage of the Committee with the outside groups. ACTION: Freifeld - work with Fulwiler and Kolodner to complete the roster of liaison contacts. 6.1 American Industrial Health Council (AIHC) The continuing activities of AIHC regarding the cancer policy of various government agencies were described by Dr. O'Connell. That group plans to become incorporated in the State of New York very soon. No decision has yet been reached regarding how long this organization should continue. 7.0 OSHA Proposal on Access to Employee Exposure and Medical Records 7.1 Post-hearing Brief The task group on Chemical Substances Identification, led by Roger Batchelor, expects to have this brief ready, with the aid of outside counsel, by the due date of March 30. 7.2 Final (Interim) Rule of July 19, 1978 No cases, which might serve as a basis for legal action, have been brought to our attention regarding an attempt by OSHA or the National Institute of Occupational Safety and Health (NIOSH) to gain unconsented access to the records in question, 7.3 NIOSH Letter to Former Employees Exposed to Carcinogens Mr. Christofano discussed such a letter received by Hercules and distributed copies. It related to ethyleneimine, one of the original fourteen carcinogens regulated by OSHA, January 29, 1974. The regulation requires that when workers exposed to carcinogens retire or leave their employer, or the company goes out of business without a successor, the medical records of those affected should be sent to NIOSH. The NIOSH letter lists a number of biomedical CMA 060491 OSH 6-6 tests, apparently referred to in their criteria document on the subject. However, the OSHA regulation does not specifically mention these tests. Hence, the former employee is left with the erroneous impression that the company was required to perform the tests. The letter also includes a form which the ex-worker may com plete to allow NIOSH to send pertinent information to the recipient's physician as well as to his union and employee representative. Mr. De Martino said Du Pont had a similar experience with another chemical. ACTION: Messrs. Snyder and Freifeld will refer this matter to the Batchelor task group which will be asked to draft an appropriate letter to NIOSH after in vestigating the cases cited. 8.0 Symposium - 1979 The program is being arranged by Mr. Christofano with the assistance of Tim Hubbard of Chevron in San Francisco. ACTION: Mr. Christofano will aim to complete the program by April 30, thus allowing time for advance publicity. 9.0 Future Issues Mr. Phil Holladay, new leader of this task group, noted that Grover Wrenn has been reassigned within OSHA and a new director of Health Standards Development is being sought. This change may affect our interaction with the agency. Mr. Holladay also described the overlapping interests in labeling at EPA and OSHA. EPA is particularly concerned about what happens to labels as materials move from supplier to customer. The Committee was also reminded of a past MCA statement to the Office of Management and Budget urging that labeling requirements of various agencies be made compatible with each other. This may require the removal of some legislative impediments. ACTION: Freifeld - arrange coordination of OSH Committee with other MCA committees in dealing with various government agencies on labeling, 10.0 President's Task Force on Workplace Safety and Health (Bergman) Mr. Voress reviewed the recently submitted MCA comments on the draft Bergman report. ACTION: Voress and Freifeld - follow up at OSHA and other government bodies to encourage implementation of recommended actions we endorse, 11.0 Confined Work Spaces and Turnarounds (Maintenance) This task group has been working closely with OSHA and Organization Resource Counselors (ORC), said Mr, Pardee. Task group leader, Al Rover, CMA 060492 OSH 6-7 reported on how favorably impressed OSHA personnel were when they visited several locations in the Gulf Coast area on this matter. Additional visits are being arranged for Dr. Purswell and his staff in Safety Standards Development to observe actual turnarounds and work being performed in confined spaces. ACTION: Kover and Freifeld - continue coordination with ORC for input to OSHA standards development. Prepare formal MCA responses to OSHA initiatives in this area, as appropriate. 12.0 New Jersey Cancer Study The report "Cancer Mortality in the New Jersey Region, 1950-1969" by Dr. M. R. Greenberg of Rutgers University, was released at the end of January, 1979. Copies of the summary were sent to the Committee. 13.0 Council on Economic Priorities Proposal (CEP) The Secretary described a letter of March 5 from CEP inviting MCA participation in a study in which they plan to compare the safety performance of the eight largest chemical companies. In the ensuing discussion, it was brought out that this organization is largely financed and controlled by unions and environmental activists with only token support from industry. It was felt their motivation was not constructive but to embarrass industry. The Committee then approved without dissent A Motion for MCA to advise CEP that industry has cooperated fully, at considerable expense and effort, with the President's Task Force on Work place Safety and Health, Richard Bergman, Executive Director. The Bergman draft report on the subject is current and thorough, hence there is no need for additional studies in this area. ACTION: Freifeld - respond to CEP declining invitation to participate in study described giving reasons noted above. 14.0 Lammot Du Pont Safety Award Winners The Secretary announced that the winners of this year's captioned awards are Allied Chemical Corporation in the over 2,000,000 exposure hours category and SunOlin Chemical Company in the smaller company grouping. ACTION: Freifeld - make arrangements for the presentation of these awards at the Annual Meeting. CMA 060493 15.0 Next Meeting This is to be held May 15 in Washington, D. C. The meeting was adjourned at 3 p.m. OSH 6-8 MF:hec Minutes Subject to Approval March 30, 1979 Milton Freifeld Secretary Occupational Safety and Health Committee CMA 060494 it-* Manufacturing Chemists Association OCCUPATIONAL SAFETY AND HEALTH COMMITTEE Open Meeting Stouffer's National Center Hotel Arlington, Virginia March 15, 1979 Attendance of non-Committee Members E. A. Agostini Suzie G. Altenburg Donald V. Anderson J. H. Blacker J. J. Bonin Richard Burack L. W. Burnette Andrew G. Chasar Dennie L. Dowell William E. Driscoll Warren S. Ferguson R. L. Finocchio Charles W. Flickinger L. J. Gilbert R. F. Gold James J. Hall Anna Marie Herodes Robert W. Hill John D. Kern Albert Kover Leonard A. Krause Charles S. Laubly Jeremiah Lynch Patrick J. McNulty Myrl E. Miller Stuart R. Mirowitz R. P. Mo line Hi H. L. Northrop J. K. Robison George F. Rotter Walter L. Schleyer Sanford Schreiber Philip Sonneborn A. T. Talcott Don Taylor John Varadi William H. Westendorf Ray E. Witter Pfizer Inc. Ashland Chemical Company Amoco Chemicals Corporation SCM Corporation Shell Oil Company Allied Chemical Corporation GAF Corporation Mobil Oil Corporation Borg-Warner Chemicals USA ARCO Chemical Company Allied Chemical Corporation PPG Industries, Inc. Kopper Company, Inc, Witco Chemical Corporation Stauffer Chemical Company Conoco Chemicals Company Nalco Chemical Company Diamond Shamrock Corporation Basic Incorporated Diamond Shamrock Corporation Olin Corporation Celanese Corporation Exxon Chemical Company Rohm and Haas Company IMC Chemical Group, Inc. M&T Chemicals Inc. Stauffer Chemical Company Stauffer Chemical Company Oxirane Corporation Armak Company PQ Corporation Allied Chemical Corporation Fisher Scientific Company The Dow Chemical Company Fisher Scientific Company CIBA-GEIGY Corporation Monsanto Company Monsanto Company i1 f i ;: * ,) ,i i j I, !i . 1! CMA 060495