Document XRw1ga4BKjdxJDy4vDdoeZYQy

Monsanto Memante Company 800 N. LmObargn Soulavard St. Louia, MitsouM 03166 Phona: :3U) S94.I000 February 7, 1972 Mr. George E. Best Secretary Board Liaison Committee for Environmental Quality and Control Manufacturing Chemists Association Dear Mr. Best: PROGRESS OF LABELS AND' PRECAUTIONARY INFORMATION COMMITTEE Labeling Regulations - OSHA The Department of Labor has not published labeling requirements. The act requires the Secretary to issue regulations before April 13, 1973 and to use a National Consensus Standard or a Federal Standard, unless he determines such a standard would not result in improved safety and health for specifically designated employees. Federal gfrawdayfl 313 la new and the only qualified labeling standard. It endorses MCA Manual L-l Hazard and Safeguard Text on Packages, but adds use of NFPA's controversial numerical health, fire and reactivity rating symbol. LAPIC wants to establish a more acceptable option than NFPA 704M for OSHA regulation. LAPIC is dedicated to establishment of one coordinated labeling program which provides for unrestricted distribution of industrial chemicals. International pictorial hazard symbols, MCA1 s Transportation Emergency Guide numbers and DOT'S emerging Hazard Information numerical guides and pictorial hazard symbols are also competing and complicating labeling. Alternate to Federal Standard 313 To provide a more acceptable labeling standard we have tried but failed to establish the MCA Manual L-l "Guide to Precautionary Labeling of Hazardous Chemicals" as an ANSI ^ standard by canvass vote of interested and affected organizations. Insurance and Fire Protection groups oppose on > p* i**; p BFG54239 ASI 00003154 R"ort o: Activities of Occupational Health Committee Manufacturing Chemists Association N. V. Hendricks, Chairman Government Liaison K` Contacts have been developed with OSHA program personnel. Repre sentatives from the National.Institute of Occupational Safety and Health have approached us to discuss information on the more important industrial chemicals in terms of production, use, tosdcity and extent of potential ex posure. This group is responsible for suverillance of occupational hazards, control measures, occupational illnesses and the statistical analysis of these factors. Arrangements will be made for them to discuss their interest at the next meeting of the Occupational Health Committee. New Orleans Workshop The committee cooperated with the Safety and Fire Protection C ommittee in a Workshop held in September where the subject material dealt with the impact of the Occupational Safety and Health Act on the chemical industry. The Workshop was highly successful with over 400 in attendance p?rticip?.ti'-,n. Polyvinyl Chloride Program As a second phase of the Acroosteolysis study in the PVC industry, a follow.up program has been established at the University of Michigan. Participating companies will provide information to be used in the evaluation of the coarse of these diseases, especially trends after cessation of exposure. This program is being continues and the University of Michigan feels it is beginning to provide valuable information. Vinyl Chloride Studies With a background of studies done in Italy where animals exposed to vinyl chloride developed a high incidence of both skin and lung cancer, dis cussions have been held with the Italian investigators. Details of these studies whichhave been published were presented to the industry group in November along with recommendations from the Occupational Health Committee for studies of this problem. iA :^ ? * o BFG54241 ASI 00003156 SAFETY AND FIRE PROTECTION COMMITTEE REPORT OF ACTIVITIES BOARD LIAISON COMMITTEE - 2/6/72 Following Is a brief summary of some of the major activities of our Committee since our last meeting* We have had two meetings with the technical staff of the Department of Labor for the pur pose of reviewing changes made to concensus standards that are neither feasible nor sound from a Loss Prevention standpoint, accom panied by recommendations to change the standards back to their original intent. These meetings were coordinated with other MCA committees for their Input and Included representation from the Occupational Health and Labels Committees* A summarization of the agreements reached at these meetings was circulated to all Interested MCA committees. At a meeting with the Department of Labor, we also discussed the possibility of MCA issuing, for the Industry, stereo-type Material Safety Data Sheets and have not pursued this matter any further than our original exploratory meeting with the Department of Labor* There apparently is still a conflict between the Department of Labor and other governmental agencies concerning the content of those forms* In addition, it appears that due to these conflicts, this will not become a requirement under the law until at least 1973. We have Just recently persuaded Mr. Driver to circulate letters to all executive contacts advising them of the status of the Material Safety Data Sheets and a second letter to Mr. Guenther, Assistant Secretary of Labor, to publicize the fact that this is still not required by law and to advise as to the status and timetable for publication in the Federal Register. A task force has now been formed in our Committee with a rather ambitious undertaking to totally review all of the standards that exist as well as the ones that will be published in the near future by the Department of Labor for the purpose of reviewing any and all changes made by the Department of Labor to concensus standards and to submit to the Department of Labor with MCA endorsement, recommen dations and language to either clarify or change the standards back to original context. Our Committee agreed that where existing consensus standards appear to be impractical or incorrect, that we would submit those requests for changes hack to the consensus-making bod:'. It is my understanding that Just recently an Inter-committee tack force has been formed with Mr. Dtephen3on acting as Secretary so that all interested committees can provide Innut to evaluations of all OSHA standards* It is vitally important that the mechanics C/f o f') o ASI 00003158 ^ BFG54243 r fib. 7, 1972 Raport of SOLID WASTE MANAGEMENT COMMITTEE to the MCA BOARD LIAISON COMMITTEE FOR ENVIRONMENTAL QUALITY The SWMC has been most active in developing guidelines end recom mended practices for disposing of solid wastes of the chemical industry. Significant developments are in the following areas. 1. Landfill The first draft of Initiating and maintaining a chemieal landfill has been produced. Expertise from member firms end the EPA Office of Solid Waste Management Programs is being blended into guidelines for proper operation of landfills. Parallel to this endeavor Is a continuing survey of state regulations relating to solid waste disposal, particularly by landfill. Each committee member is assigned to follow appropriate legislation in 2 states and report to the secretary. States with particularly comprehensive regulations will be discussed es possible model regulations for ocher states. 2. Disposal by private contractors Guidelines are being developed In conjunction with the National Solid Waste Management Association (a trade organi zation similar to MCA). Exploratory meetings are being set up between MCA-SWMC members and the association to discuss needs, capabilities and requirements. It is envisioned that this would lead to mutually conducted workshops to study most effective technologies, particularly related to landfill. 3. Industrial pollution ratings A special 3-man cosmittee has been appointed to wrestle with this problem as it relates to solid wastes handling. A rather extensive discussion by the entire comnlttee indicated that while they agree chat such a rating system may be desirable, the chances of agreeing upon one are remote. However, three criteria were discussed chst may be developed further, namely, ASI 00003160 ro C7I O xoX V\ BFG54245 February 1, 1972 REPORT OF THE WATER RESOURCES COMMITTEE OF THE MANUFACTURING CHEMISTS ASSOC. Presented to the Manufacturing Chemists Association Board Liaison Committee for Environmental Quality and Control at Meeting of February 8, 1972. During the period since the last report was made to you (November 24, 1971) the Water Resources Committee held their winter meeting at Dallas, Texas on January 18-19, 1972, Mr, Arthur Busch, newly Installed administrator of the Dallas Regional Office of EFA was a luncheon guest and speaker on January 18, and Mr* Hugh C* Yantis, Executive Director of the Texas Water Quality Board was luncheon guest and speaker on January 19* Some of the items of most Import, discussed at Dallas WRC meeting, are summarized below: e Research Budget - The committee voted to request research funds in the amount of $45,000 for FY72-73* A maximum of $15,000 of these funds would be used to conclude the fish avoidance studies conducted by Ichthyological Associates and for preparation of a plant operator's manual detailing the necessary equipment and techniques to perform the avoidance tests* The remainder of the $45,000 would be utilized by Dr. John Calms of Virginia Polytechnic Institute and State University to continue his research in simplified biological monitoring techniques. Environmental Rating Index - This matter referred to the 'WRC by Mr* Gerstacker was discussed and an ad hoc committee appointed by Chairman Byrd to consider the opinions voiced andvto prepare a recommendation. The majority of the opinion, expressed was pessimistic in regard to devising a meaningful index. ASX 00003162 o v'J O> . BFG54247