Document a4R35LYN1pzd9dqp8N0X7yEXY

1 BFGoodrich The BFGoodrich Company Geon Vinyl Division 6100 Oak Tree Boulevard Cleveland, Ohio 44131 216:447-6000 October 8, 1992 Director. Health, Toxicology' and Product Safety Jim Lowrie Safety Manager Sola Optical 1500 Cader Lane Petaluma, Ca. 94953 Dear Mr. Lowrie: t This letter is in response to your request for comments on the letter from Dr. Patricia Bailey regarding the hazards of exposure to Geon 86416. The hazards of Geon 86416 are described in the Material Safety Data Sheet (MSDS) for this product. Although you indicated that you have a copy of this MSDS, a second copy is enclosed for your convenience. As you know, Geon 86416 is a mixture of polyvinyl chloride (PVC) and a number of other ingredients which are added to impart specific functional characteristics. PVC, which is the prime ingredient in this compound, is known to release hydrogen chloride (HC1) when excessive temperatures occur during processing. Under these conditions HC1 can cause irritation to the eyes, nose and upper respiratory tract. Studies in nonhuman primates have shown that as the result of its high solubility in water and scrubbing action of the upper respiratory tract (moisture) no significant penetration to the lower lung or lung function effects are expected. Furthermore, Geon 86416 does not contain any ingredients which can generate hydrogen cyanide. All of the hazardous ingredients are listed under Section II of the MSDS. PVC contains a small residual amount of vinyl chloride, the basic building block, which is a known human carcinogen. However, the residual levels of VCM have been reduced to the point where they are not expected to pose any significant risk. DEHP, also called DOP or bis(2ethylhexyl)phthalate, has not been shown to be carcinogenic in man. Long-term studies have shown that DEHP is carcinogenic in rodents and have led some organizations to list this chemical as a possible human carcinogen. However, further studies of this carcinogenic response in rodents have indicated that this response is an artifact specific to the animal species tested and not a true indication of human hazard. This has led bodies like the Specialized Experts Working Group of the European Community to conclude that there is no evidence to warrant classification of DEHP as a carcinogen. The U.S. FDA also has not regulated DEHP as a 15S7001 BFG15603 Jim Lowrie October 8, 1992 Page 2 carcinogen not only because of questions about the relevance of the rodent response, but because of the long history of use in medical devices and as an indirect food additive. More over, senior officials for the Environmental Protection Agency have taken the position that the process of tumor formation in the rodent may not be relevant to man. Please call me at (216) 447-7978 if you have any further questions. Sincerely, THE BFGOODRICH COMPANY Robert K. Hinderer, Ph.D. Director of Health, Toxicology, and Product Safety 1008--2/jp Attachment cc: John Dresch Don Knechtges Mike Marshall (w/attachment) Charlie Ragland Z00Z6ST BFG15604 HFGoodrieh Geon Vinyl Division MATERIAL SAFETY DATA SHEET Geon 86416 TRANSPARENT PELLETS 0027 Product No.: 86416 00D 0027 Issue: 005 Issued: July 1992 Supersedes: New Issue Written by: M. Hross SECTION I The B.F.Goodrich Company Geon Vinyl Division 6100 Oak Tree Blvd. Cleveland, Ohio 44131 The B. F.Goodrich Company 195 Columbia Street West Waterloo, Ontario N2J4N9 Telephone No.: 1-(800) 438-4366 ' Transportation Emergency No.: CHEMTREC: 1-(800) 424-9300 Medical Emergency No.: POISON CENTER: (216) 379-8562 Telephone No.: (519)888-4318 Transportation Emergency No.: CANUTEC: (613)996-6666 Chemical Family: Alloy Chemical Name/Synonyms: Poly(vinyl chloride), PVC, vinyl Trade Mark: Geon Vinyl Formula: Vinyl Resin* plus functional additives *(CH2CHCl)n C.A.S. Registry No.: Not Applicable (Mixture) TSCA Inventory Status: All ingredients comply with the USEPA's TSCA regulations Canadian Domestic Substances List Status: All ingredients have been nominated or are elgible for inclusion Workplace Hazardous Materials Information System (WHMIS) Classification: DIB Product Use: Various Applications SECTION II - Hazardous Ingredients Hazard Summary Statement: CAUTION! Processing fumes may cause irritation of the eyes and respiratory tract. Use with adequate ventilation. Avoid breathing process emissions. Read entire Material Safety Data Sheet (MSDS). n 1597003 BFG15605 Geon 86416 TRANSPARENT PELLETS 0027 Page 2 Material B is(2-ethylhexyl) Phthalate1,2,3,4,5,6 C.A.S. Number 117-81-7 Amount in Product 15-20% ACGIH TLV-TWA 5.0 mg/m3 10 mg/m3 short term exposure limit (STEL) Bis(2-ethylhexyl) Phthalate LDSq (rat, oral) - 3000 mg/kg Bis(2-ethylhexyl) Phthalate LCS0 - N.E. OSHA PEL-TWA 5.0 mg/m3 10 mg/m3 short term exposure limit (STEL) Bis(2-ethylhexyl) Adipate1,2,4,5,6 103-23-1 5-10% N.E. Bis(2-ethyUiexyl) Adipate LD50 (rat, oral) - 9,110 mglkg Bis(2-ethylhexyl) Adipate LCS0 - N.E. N.E. Vinyl Chloride Monomer1,2,3,4,5,6 75-01-4 <8.5 ppm 5 ppm Vinyl Chloride Monomer LDS0 (rat, inhalation) -18 pphllSM Vinyl Chloride Monomer LCS0 - N.E. 1 ppm (5 ppm TWA for any 15 minute period) N.A. - Not Applicable N.E. - Not Established Bis(2-ethvlhexvl) phthalate is a National Toxicology Program (NTP) anticipated human car cinogen and an International Agency for Research on Cancer (IARC) possible human carcino gen. Vinvl chloride monomer is shown as an OSHA cancer suspect agent (29 CFR 1910.1017), an American Conference of Governmental Industrial Hygienists (ACGIH) confirmed human car cinogen, and a National Toxicology Program (NTP) and an International Agency for Research on Cancer (IARC) human carcinogen. Legislative Footnotes 1 Ingredient listed on SARA Section 313 List of Toxic Chemicals 2 Ingredient listed on the Pennsylvania Hazardous Substances List 3 Ingredient listed on the California listing of Chemicals Known to the State to Cause Cancer or Reproductive Toxicity BFG15606 ! Geon 86416 TRANSPARENT PELLETS 0027 Page 3 4 Ingredient listed on the Massachusetts Substance List 5 Workplace Hazardous Materials Information System ingredient found on the Ingredient Dis closure List - Canada ^ Ingredient listed on the New Jersey Right to Know Hazardous Substance List Notes: TLV-TWA -- Threshold Limit Value - Time Weighted Average for concentration of the chemical substance in the ambient workplace air. American Conference of Governmental Industrial Hygienists (ACGIH). OSHA PEL -- OSHA Permissible Exposure Limit, 8-hour TWA. 29 CFR1910.1000 1989. SECTION m - Physical Data Appearance: Tramsparent Pellets Odor Slight Characteristic Percent Volatiles: N.E. Solubility in Water: N.E. Physical State: Solid Specific Gravity: 1.23 0.02 Melting Point: N.E. Glass Transition Temperature: N.E. Bulk Density: N.E. SECTION IV - Fire and Explosion Hazard Data Flash Point: Not established for the product; the vinyl resin portion of the product has a flashignition temperature of approximately 391C (735F) and a self-ignition temperature of approximately 454C (850F). ASTM D-1929. Notes: Flash-Ignition Temperature - The lowest initial temperature of air passing around the specimen at which sufficient combustible gas is evolved to be ignited by a small external pilot flame. Self-Ignition Temperature -- The lowest initial temperature of air passing around the specimen at which, in absence of an ignition source, ignition occurs of itself, as indicated by an explosion, flame or sustained glow. Extinguishing Media: Water, ABC dry chemical, protein type air foams. (Carbon dioxide may be ineffective on larger fires due to lack of cooling capacity which may result in reignition.) Special Firefighting Procedures: Wear self-contained breathing apparatus (SCBA) in positive pressure mode. Personnel not having suitable respiratory protection must leave the area to pre vent significant exposure to toxic combustion gases from any source. In enclosed or poorly ventilated areas, wear SCBA during cleanup immediately after a fire as well as during the at tack phase of firefighting operations. Unusual Fire and Explosion Hazards: None known. 21597005 BFG>5607 Geon 86416 TRANSPARENT PELLETS 0027 Page 4 SECTION V - Reactivity Stability: Stable Hazardous Polymerization: Will not occur. Hazardous Decomposition Products: Hydrogen chloride, carbon monoxide, carbon dioxide and small amounts of benzene and aromatic and aliphatic hydrocarbons and aliphatic olefins. CAUTION! Prolonged heating (approximately 30 minutes or more) of the product above 200C (392F) or short term heating at 250C (482F) may result in rapid evolution of hydro gen chloride. Incompatibility (Materials to Avoid-): Avoid contact with strong oxidizers. Also, avoid contact with acetal or acetal copolymers and with amine containing materials during processing. At processing conditions, these materials are mutually destructive and involve rapid degradation. Thoroughly purge and mechanically clean processing equipment to avoid even trace quantities of these materials from coming in contact with each other. Prevent cross contamination of feedstocks. SECTION VI > Health Hazard Data Threshold Limit Value: Not Established Primary Routes of Exposure: Inhalation of process emissions Effects of Overexposure: No adverse health effects arc anticipated from the product at ambient temperatures. However, at process temperatures, the product can emit fumes and vapors which may cause irritation of die eyes and respiratory tract. Any effects will depend upon processing technique and temperature, volume processed and the effectiveness of exhaust ventilation provided for the process. Effects of chronic exposure to off-gases at processing temperatures have not been fully evaluated. Hazardous ingredient specific medical data (if ingredient found in "pure" form'): Bis(2-ethylhexyl) phthalate causes gastrointestinal effects in man. It is a mild eye and skin irritant Although it causes liver cancer in rodents, the significance of this response to humans is not known. Reproductive and developmental effects have been observed in rodents fed high doses. However, experts from the EEC Commission have concluded that it could not be clas sified as a carcinogen or as a teratogenic substance. Bis(2-ethyhexyl) phthalate is an NTP an ticipated human carcinogen and an IARC possible human carcinogen. BFG15608 21597006 Geon 86416 TRANSPARENT PELLETS 0027 Page 5 Bis(2-ethylhexyl) adipate vapors or mists from heated material may irritate the respiratory tract. Repeated or prolonged contact may irritate the skin. Ingestion causes abdominal cramps and diarrhea. (Liver tumors seen in mice fed bis(2-ethylhexyl) adipate appear to be unique to the species.) Vinyl chloride monomer in high concentrations can cause eye, nose and throat irritation, dizzi ness, euphoria, drowsiness, incoordination, nausea, headache, blunred vision, disorientation, persistent irregular heart beat, unconsciousness and death. Direct contact with the liquid causes freeze bums of the skin, eyes and mucous membranes with possible permanent damage Repeated exposure causes angiosarcoma of the liver, a rare form of liver cancer. Repeated exposure to high concentrations can cause degeneration of the tips of the finger bones. Transplacental carcinogenicity has been observed in some long term studies with animals. Other organ system effects also have been observed in animal studies but have not been con firmed in humans. Vinyl chloride is an OSHA cancer suspect agent (29 CFR 1910.1017), an ACGEH confirmed human carcinogen and an NTP and IARC human carcinogen. Emergency and First Aid Procedures: Inhalation (of process emissions): Remove affected individual to fresh air. Contact a physician. Eve Contact: Flush eyes with water for at least 15 minutes while lifting upper and lower eyelids. Seek medical attention if irritation persists. Skin Contact: Not an anticipated hazard, however, good personal hygiene practices are always recommended for material handling. Ingestion: Not an anticipated hazard. SECTION VII - Spill and Leak Procedure Steps to be taken in case material is released or spilled: Vacuum or sweep material into a clean, properly labeled container for reuse or disposal. Waste disposal method: Dispose of waste in accordance with all federal, state/provincial and local regulations. TCLP: This product or others of similar composition, in the as-shipped condition, have been tested and found to be not hazardous using the USEPA's Toxicity Characteristic Leaching Pro cedure (TCLP - 40 CFR 261, Appendix II). Any physical or chemical modification of this product may change the TCLP test results. SECTION VIII - Special Protection Information Ventilation: Effective exhaust ventilation should always be provided to draw fumes or vapors away from workers to prevent routine inhalation. Ventilation should be adequate to maintain the ambient workplace atmosphere below the legislated levels listed in Section II. Hot melt BFG15609 -1 2159700 Geon 86416 TRANSPARENT PELLETS 0027 Page 6 processing (e.g., extruding and molding), cutting or sawing, machining, regrinding, thermoforming, heat welding and other processing or post-processing operations involving heat sufficient to result in polymer breakdown should be examined to insure adequate ventilation. Respiratory Protection: Wear a NIOSH/MSHA-approved respirator specific for chemicals listed in Section II and VI, as applicable, when concentrations exceed those limits listed. Com ply with OSHA 1910.134 (29 CFR). Protective Equipment: Wear protective gloves when handling hot material during processing. Safety glasses are recommended for all industrial activities. SECTION IX - Special Precautions Material Handling: As with any product, should dusting occur from material handling, sources of ignition, such as static discharge, should be addressed by the user to prevent the ignition and sudden release of energy from suspended, finely divided particulates. Remove product from walkways and floors to prevent slipping hazards. Normal Melt Processing; Virtually all thermoplastic materials will emit fumes and/or vapors when heated to processing temperatures. The concentration of these emissions in the workplace air will depend upon variables such as the specific compound formulation, amount processed, processing method and temperature and the effectiveness of exhaust ventilation. Always use Geon vinyl compound under well ventilated conditions and avoid continued or prolonged breathing of process vapors. For personal hygiene, wash thoroughly after processing com pound, especially before eating, smoking or using toilet facilities. Do not store or consume food in processing areas. Do not use processing equipment to heat food. Cleanup: Cleanup following normal melt processing should be performed under well ventilated conditions. Geon vinyl compound may be held at process temperatures for a short time with out significant thermal degradation. However, it should be recognized that exposure to either elevated temperature or excessive heat history (time) will result in decomposition. The time and temperature required to initiate degradation will vary depending upon processing technique, degree of compound stabilization and other factors. As a general rule-of-thumb, degradation begins to occur after about one hour at 177C (350F), about 10 minutes at 204C (400F) and within five minutes at 232C (450F). Equipment should not be shut down for extended time periods with compound in it, or decomposition and possible corrosion of unprotected metal may result. If dies and screws are not to be cleaned manually, then purge equipment prior to shut down using special vinyl purge compound or a compatible thermoplastic such as general pur pose ABS (do not use flame-retarded or halogen-containing grades for this purpose). Processine Fume Condensates: Processing fume condensates, which may include toxic con taminants, may be combustible and should be periodically removed from exhaust hoods, ductwork and other surfaces. Protective clothing, including impervious gloves, should be worn during cleanup operations to prevent skin contact. Storage: Sprinklered warehouse areas are recommended The product by itself will not support combustion, however, materials such as wooden pallets, paper bags, cardboard boxes and other combustibles can provide sufficient fuel to cause the product to bum. BFG15610 O r\r\> C C T 'y Geon 86416 TRANSPARENT PELLETS 0027 Page 7 Material Not Used Within One Year: Material not used within one year should be tested to determine if degradation has occurred. Abnormal Conditions: Abnormal conditions such as equipment malfunction or using improper equipment or procedures, or hang-up or stagnation of material during processing may cause de composition. Employees involved in removing decomposing material should be provided suit able air-supplied respirators and other appropriate protection. Housekeeping: Remove any dust generated as a result of material handling from areas such as rafters, roofs, building columns and ductwork to eliminate any secondary potential dust explo sion or fire hazards. SECTION X - Hazard Codes NFPA 704 (1980) (National Fire Protection Association) Health: Flammability: Reactivity: Special: 2 1 0 Kev: 0 = Insignificant 1 = Slight 2 = Moderate 3 = High 4 = Extreme HMIS (Hazardous Materials Identification System National Paint and Coatings Association) Health: Flammability: Reactivity: Personal Protection: 0 1 0 B User's Responsibility This bulletin cannot cover all possible situations which the user may experience during process ing. Each aspect of the user's operation should be examined to determine if, or where, addi tional precautions may be necessary. All health and safety information contained within this bulletin should be provided to the user's employees or customers. We must rely upon the user to utilize this information to develop appropriate work practice guidelines and employee in structional programs for his or her operation. Disclaimer of Liability As the conditions or methods of use are beyond the control of B.F. Goodrich, B.F. Goodrich does not assume any responsibility and expressly disclaims any liability for any use of this ma terial. Information contained herein is believed to be true and accurate but all statements or e006ST2 BFG15611 Geon 86416 TRANSPARENT PELLETS 0027 Page 8 suggestions are made without warranty, expressed or implied, regarding the accuracy of the in formation, the hazards connected with the use of the material or the results to be obtained from the use thereof. Compliance with all applicable federal, state and local laws and regulations remains the responsibility of the user. BFG15612 21597010 PRODUCT LABELING INFORMATION Product: Geon 86416 TRANSPARENT PELLETS 0027 The B.F.Goodrich Company Geon Vinyl Division 6100 Oak Tree Blvd. Cleveland, Ohio 44131 Telephone No.: l-(800) 438-4366 Transportation Emergency No.: CHEMTREC: 1-(800) 424-9300 Medical Emergency No.: POISON CENTER: (216) 379-8562 The B.F.Goodrich Company 195 Columbia Street West Waterloo, Ontario N2J 4N9 Telephone No.: (519) 888-4318 Transportation Emergency No.: CANUTEC: (613)996-6666 READ MATERIAL SAFETY DATA SHEET (MSDS) BEFORE USE NFPA HMIS CAUTION! Processing fumes may cause irritation of the eyes and respiratory tract. Use with adequate ventilation. Avoid breathing process emissions. Health Flammability Reactivity Personal Protection 0 1 0 B First Aid: Inhalation of process emissions: Remove affected individual to fresh air. Contact a physician Eve contact: Flush eyes with water for at least 15 minutes while lifting upper and lower eyelids. Seek medical attention if irritation persists. Contains: Bis(2-ethylhexyl) Phthalate (CAS No. 117-81-7 15-20% Bis(2-ethylhexyl) Adipate (CAS No. 103-23-1) 5-10% Vinyl Chloride Monomer (CAS No. 75-01-4) <8.5 ppm rto iS G T BFG15613 1 Ingredients List Required by the New Jersey Right-To-Know: Polyvinyl Chloride CAS No. 9002-86-2 Ethyl Acrylate Methyl Methacrylate Polymer CAS No. 9010-88-2 Epoxidized Soybean Oil CAS No. 8013-07-8 Bis(2-ethylhexyl) Phthalate CAS No. 117-81-7 Bis(2-ethylhexyl) Adipate CAS No. 103-23-1 LABEL INFORMATION FOR CANADIAN WHMIS Product: GEON VINYL COMPOUND Product No.: 86416 00D 0027 rj! ProduiU COMPOSE VINYLIQUE GEON"1' 'du produit: 86416 00D 0027 CAUTION! ATTENTION! Processing fumes may cause irritation of the eyes and respiratory tract. Under certain conditions and without proper ventilation and/or personal protection, exposure to carcinogens could occur. PRECAUTIONS: Use with adequate ventilation and avoid breathing process emissions. FIRST AID MEASURES: INHALATION OF PROCESS EMISSIONS: Remove affected individual to fresh air. Contact a physician. EYE CONTACT: Contact medical personnel for removal of foreign bodies. Les fumdes ddgagdes lors de la mise en oeuvre peuvent provoquer une irritation dea yeux et del voies respiratoires. Dans certaines conditions et sans ventilation appropride et/ou protection personelle une exposition 4 des dldments cancdrigdnes est possible. PRECAUTIONS: A utiliser avec une ventilation appropride et dviter d'inhaler les vapeun Imises par la mise en oeuvre. PREMIERS SOINS: INHALATION DES EMISSIONS LORS DE LA MISE EN OEUVRE: Emmenerla victime k Pair frais. Appeler un mddedn. CONTACT OCULAIR: Appeler un personnel mddical pour extraire les corps dtrangers. See MATERIAL SAFETY DATA SHEET Voir la FICHE SIGNALEtIQUE The BFGoodrich Company The BFGoodrich Company Geon Vinyl Division, 6100 Oak Tree Blvd., Cleveland. OH 44131 Division Vinyle Geon, 6100 Osk Tree Blvd., Cleveland, Telephone: l-(800) 438-4366 OH 44131 Wa LCtHliUEMTREC: 1-(800) 424-9300 Poiseon Center: (216) 379-8562 Tdldphonc: l-(800) 438-4366 CHEMTREC: 1-(800) 424-9300 Centre anti-poison: (216) 379-8562 J BFG15614 JO & tc n N Shipping Information IDENTIFICATION - DOMESTIC TRANSPORTATION Proper Shipping Name (172.101(c)): N.A. (Technical Names(s)) (172.203(k)): N.A. Hazard Class (172.101(d)): N.A. UN/NA# (172.101(e)): N.A. Haz. Substance (171.8): N.A. Inhalation Hazard (172.2a(b)): N.A. Reportable Quantity: N.A. PACKAGING fPart 173) Packaging Sections (172.101(g)) - Col. 5(a): N.A. General Packaging Sections - General 173.24 Col.5(b): N.A. Hazard Class: N.A. DANGEROUS GOODS DETERMINATION (2.1) - INTERNATIONAL TRANSPORT Proper Shipping Name (Col. B): N.A. Class/Division (Col. C): N.A. Subsidiary Risk (Co. D): N.A. UN/ID# (Col. A): N.A. U.S. Haz. Substance (US 1): N.A. Other/Inhalation Haz. (US 34): N.A. Variations (1.8): States (Governments): N.A. Carrier (Table 1.8B): N.A. PACKAGING Max. Qty. Per PKg.(Cols. H/J) - Passenger: N.A. Packaging Instructions (Cols. G/I) - Passenger N.A. Cargo: N.A. Cargo: N.A. MARKING A. Proper Shipping Name (172.301(a)) (Technical Name(s))(172.301(c)) B. UN/NA Number (172.301(a)) C. Name and Address (172.306(a)) D. THIS END UP 9(172.312(a)) E. Haz. Substance RQ (Name)(172.324) - ORM Designation (172.316(a)) - Inhalation Hazard (172.301(a)) DOMESTIC LABELING 1. HMT LABELS (172.400) 2. Additional Hazard (172.402(a)) INTERNATIONAL LABELING 1. Primary Hazard 2. Subsidiary Risk (If Appropriate) 3. Cargo Aircraft (If Appropriate) {C A. Proper Shipping Name (T scl nical Na ne) B. UN/NA Number E. (Haz. Substance) RQ BFG15615