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i'nrfliirirnirri i Aifi MANUFACTURING CHEMISTS' ASSOCIATION, INC. MINUTES OF MEETING LAPELS AND PRECAUTIONARY INFORMATION COMMITTEE La Salle Hotel, Chicago, 111., May 7-8, 1952 L-lii The meeting was called to order at 10:00 A.M., May 7, and 9:30 A.M., May 8. Members Present: Messrs. F. S. Low, Chairman .... Westvaco Chemical Division, Food Machinery & Chemical Corporation T. R. Aalto .......................... Heyden Chemical Corporation A. G. Cranch, M. D................ Union Carbide & Carbon Corporation J. H. Foulger, M.D...............E. I. du Pont de Nemours & Company, Inc. J. T. Fuess ........................... Eastman Organic Chemicals Dept., Distil lation Products Industries S. J. Hill.......................... E. I. du Pont de Nemours & Company, Inc. W. A. Knapp .......................... General Chemical Division, Allied Chemical & Dye Corporation M. D. Madsen (for A. Q. Butler ) . Mallinckrodt Chemical Works R. D. Minteer ...................... Monsanto Chemical Company W. J. Quinn.......................... Merck & Co., Inc. W. W. Sunderland ................. Dow Chemical Company J. S. Walker ....... Hooker Electrochemical Company J. B. Williamson ................. American Cyanamid Company W. W, Yeager (for G. E. Brewer) . Shell Chemical Corporation J. A. Gosnell* ...... Manufacturing Chemists' Association D. E. Campbell (Secretary). Manufacturing Chemists' Association Guests: J. E. Flanagan, Jr W. S. Jessop* . . F. Dallas Sparre R. G. Troup . . . W. J. Zick* . . . U. S. Public Health Service U. S. Sanitary Specialties Co. E. I. du Pont de Nemours & Company, Lnc. J. T. Baker Chemical Company B. Heller & Company Absent: N. M. Walker . Pennsylvania Salt Manufacturing Co. * May 7 only Minutes of the meeting of February 5-6, 1952, are corrected as follows: P. L-ll - 3.1k delete (30;?) after Sodium Peroxide. P. L-12 - 9.1 Sentence (2) should read, "Does every such liquid ..." After sentence (li) insert "Committee on Combustible Liquid*, y.Lor, Chairman; Fuess, Williamson.** L-l5 1. ELECTION OF OFFICERS AND NEST MEMBERS 1.1 The report of the subcommittee on Nominations was presented and accepted by the Committee. The nominations suggested were made and seconded and voted unanimously. The officers for the fiscal year June 1, 1952, to May 31, 1953, are: Chairman - R. D. Minteer Vice Chairman - J. S. Walker The Committee and the Association express their thanks and appre ciation to Frank Low, as Chairman, and John Williamson, as Vice Chairman, for their excellent services apd valuable contribution to the Associa tion and the chemical industry. 2. REGULATIONS 2.1 State Regulations (a) MCA Policy on Uniform State labeling Laws? Mr. Quinn inquired as to whether it was the policy of the Committee to encourage the enactment of uniform labeling legis lation throughout the various states. It wa3 the view of the majority of the Committee that the MCA policy does not contem plate "the encouragement of such-legislation. However, wherever an effort is being made by others to have laws or regulations enacted which would affect the labeling of hazardous chemicals, it is'our policy to promote uniformity in such laws and regula tions, particularly by urging the adoption of LAPI principles. (b) Conference of Governmental Hygienists - Resolution: The-American Conference of Governmental Hygienists, at their meeting in,Cincinnati, on April 22, 1952, adopted the following resolution referring to warning labels: 'WHEREAS the content, dangers and protective mea sures necessary for the handling of potentially danger ous substances is not limited by geographic areas; and "WHEREAS the appropriate label on such substances can help to preserve and protect the public health; and "WHEREAS the storage, transportation and use of these.substances may need specific precautions for the protection of the public; arui "WHEREAS in the past the Public Health Service and the Manufacturing Chemists* Association have cooperated toward this end: Therefore be it "RESOLVED, That the American Conference of Govern mental Industrial Hygienists approve the following principles: L-l6 I. That adequate labels for warning and identi I fication of harmful substances are necessary i for the prevention and control of a public health problem, II. That requirements for adequate warning labels should be as uniform as possible, III. That the American, Conference of Governmental Industrial Hygienists work together with other official and non-official groups as well as with the Manufacturing Chemists' Asso*ciation toward the development of an adequate uniform guide for the labeling of potentially harmful substances; and be it further I "RESOLVED, That the Executive Committee assign to the Chairman of one or more appropriate standing commit tees the responsibility fbr immediate action to implement these principles; and furthermore "BE IT RESOLVED, That the Secretary of the Confer ence be instructed to distribute copies of this resolu tion to the members of the Conference and other interested parties."- Ur. Flanagan, a guest at the LAPI meeting, who is Secretary of the Conference of Governmental Hygienists, announced the formation of a subcommittee of the Hygienists group to deal with standard labeling pro cedure. The composition of that group includes; ) Dr. Thomas F. Uancuso, Chairman Dr. Herbert K. Stokinger Mri J. B. Flanagan, Jr. Dr. Leonard Greenburg Uri Hugh L. Parker Dr. H. B. Elkins 2.2.1 New York City - Carbon Tetrachloride The Committee discussed the "Notice to Industry," dated Kerch 20, which was circulated by Mr. H. Raybin, of the New York City Department of Health. This was circulated to members of the LAPI Committee on March 21st, and proposed specific labeling for pradructs containing carbon tetrachloride. The proposed label did con form in general to principles set forth, but certain suggested phrases were objected to by this Committee. Mr. Low has been in contact with Mr. Raybin and feels that major items, of .difference have been cleared up, with the remaining items to be handled in the ( future. The latest information from Mr. Low indicates that L-17 Mr. Raybin thinks all the corrments and suggestions have been received and filed with the New York City Committee for further consideration. The next meeting of that Committee will be the fore part of June, but it is not indicated whether this matter will come up at that meeting. We have been assured that before any formal action is taken we will be advised, as well as members of the CSMA, through Dr. Hamilton, and we will be permitted to present further written or oral arguments. The Committee discussed labeling of small packages with representatives of CSMA, and adopted the following minimum label for containers of a pint or less. CARBON TETRACHLORIDE DANGER' HAZARDOUS VAPOR AND LIQUID MAY BE FATAL IF BREATHED OR SWALLOWED Use only with adequate ventilation. The Committee further took the position that, if the city of -- New York was very deeply.concerned with the additional line "Keep away from children," we would not seriously oppose this addition to household package labels, although the Committee feels that this is unnecessary and will not produce any appreciable reduction in the num ber of accidents. 2.2.6 Michigan Mr. Feuss discussed Michigan Senate Bill No. 136, which would limit sale of economic poisons and various chemicals to registered pharmacists. A letter has been written to the Chairman of the Michigan Senate Committee on Health and Welfare referring to this Bill, requesting that, if the Bill be acted upon, it should include an exception for such items Then used in science or the arts. At the present time the Michigan Legislature is in recess, scheduled to resume during the month of May. Mem bers of the Committee may want to take action on this Bill through their contacts in Michigan. 3. LABELS - SAFETY DATA SHEETS 3.9 Ortho-Dichlorobenzene No change is made in this label from that found on page ?h, Manual - L-18 3.10 Sulfur Dioxide The following label was adopted, subject to approval by the Compressed Gas Association: WARNING'. EXTREMELY IRRITATING GAS AND LIQUID UNDER PRESSURE LIQUID CAUSES BURNS Avoid breathing gas. 3.11 Naphthalene No precautionary label is necessary for this chemical. 3.12 Pyridine The following label was adopted by the Committee: WARNING' FLAMMABLE VAPOR HARMFUL Keep away from heat and open flame. Keep container closed. Use only with adequate ventilation. Avoid prolonged or repeated breathing of vapor. Avoid prolonged or repeated contact with skin. 3.13 Zinc Chloride The following label was adopted by the Committee: WARNING! MAY CAUSE SEVERE SKIN IRRITATION Avoid contact with skin or eyes. In case of contact, flush skin or eyes with plenty of water for at least IS minutesj for eyes, get medical attention. 3-lii Sodium Peroxide The following label was adopted by the Committee for use in the Safety Data Sheet: WARNING! STRONG OXIDANT CAUSES SEVERE BURNS TO SKIN AND EYES Wear goggles or face shield when handling. Avoid spillage. Avoid any contact with skin or clothing. Sweep up spilled material with dry sand and flood with water in the open. L-19 3.lii (cont.) Keep container tightly closed at all times. Store in a cool, dry location away from acids or com bustible material. Dissolve carefully; always ADD the Sodium Peroxide TO the liquid. Avoid contact with any combustible matter. In case of fire, smother with dry sand. Never use a chemical fire extinguisher. Do not use water unless fire continues. THen flood with large quantities from a hose. S POISON B FIRST AID TREATMENT Contact - Clothing; Remove contaminated clothing and shoes at once. Wash thoroughly before reuse. Eyes - Skint Immediately flush with plenty of water'for 1f> minutes. For eyes, get medical attention. Internally - % Give large quantities of water, followed by citrus fruit juices, diluted with water. Than give milk, olive oil, or other cooking oil, in liberal amounts. 3.15> Potassium Permanganate The following label was adopted by the Committee: WARNING! STRONG OXIDANT CONTACT WITH COMBUSTIBLE MATERIAL MAY CAUSE FIRE OR EXPLOSION Store away from'acids, alkalies and combusti ble materials. Keep container closed and away from heat. Avoid prolonged contact with skin. In case of contact, remove and wash clothing immediately; for eyes, flush with plenty of water for at least 15 minutes; get medical attention. Flush spillage with plenty of water. 3.16 Hydrogen Peroxide Consideration of this label was continued for the next meeting of the Committee. L-20 3.17 Butadiene The following label was adopted by the Committee: DANGER! EXTREMELY FLAMMABLE MAY FORM EXPLOSIVE PEROXIDES ON EXPOSURE TO AIR Keep away from heat, sparks and open flame. Keep container closed. Use with adequate ventilation. Various labels were presented to the Committee in Safety Data Sheets, which will be reprinted in the next six months. These are con sidered and reported under Item Revision of Manual L-l. The following motion was made, and seconded, and was defeated by vote, of the Committee: "All labels adopted by the LAPI Committee for use in the Safety Data Sheets shall also appear in Manual L-l.n This motion was defeated for several reasons, including the fact that the Manual is set up, not as a complete compilation but, as a guide for the preparation of warning gabels. It is also felt that some of the labels prepared for Safety Data Sheets have extremely limited usefulness in the industry, being relegated primarily to the use of one or two manufacturers. U. NEW LABELS U.3 Aniline and Derivatives An extensive report was submitted by Mr. Sparre in behalf of the subcommittee. The Committee reviewed this in detail, and the labels noted will be included in the revised Manual. The report and committee review covered a number of other compounds not derived from aniline but associated with such products in the dyestuffs intermediate business, as well as aniline and derivatives. iuli Fluorides At the request of Mr. N. Walker, the Committee reviewed suggestions submitted by Penn Salt, and it was moved, seconded and voted that the words "inhaled or" be deleted from the Sodium Fluoride and Sodium Fluosilicate labels. .The revised label will read: SODIUM FLUORIDE WARNING! MAY BE FATAL IF SWALLOWED Avoid breathing dust. Wash thoroughly after handling. Clean up spillage. fc-21 5. REVISION OF MANUAL L-l 3 (a) Review of Labels for Safety Data Sheets: The Committee took the following action on labels for Safety Data Sheets which are due to be reprinted within the next six months. Sulfuric Acid label in manual - No change. Benzene - Minor variations between manual and SD-2 No change in the label in manual. Perchloric Acid - New Label in manual to be used. Formaldehyde - No change. Carbon Tetrachloride - New label in manual to be used. Phenol - Change to correspond to L-I. Methyl Bromide - No change. SD-3f> sjme as L-l. Ethylene Dichloride - Change to correspond with label in L-l. Acetic Anhydride - Change to correspond to label in L-l. Page 13, heading "Definitions" will be changed to "Terms as Deed." It was voted to accept the Revision Committee's recommendation to add the line "Keep away from Heat and Open Flame, to all labels of items having a flash point between 80 F. and 15>0o ?. Anhydrous Ammonia - Change vapor to gas. Benzyl Chloride - Revise label to be submitted by T. R. Aalto. Carbon Tetrachloride - It was voted to revise this label, but after a serious objection by'Dr. Craneh, a new vote was taken which was 7 to in favor of no change. Label to remain as shown in L-l. Diacetone Alcohol - Voted to remove from manual. 2-Ehtylhexylacetate - Voted to remove from manual. Glycol Diacetate, Glycol Diformate, Heptanol-2, Hexanol, voted to remove from manual. Hydrochloric Acid - Add (Muriatic Acid). Hydrogen Peroxide $0% - Add "Remove and wash clothing at once," after "in case of contact ..." statement. On Table 1 rtheevisfoiollnowoifngMawnouardl inLg-lieitsewtauspm: oved, seconded and voted that in *1.-- Liquids Flash point 150 or below ... C. Flash point above 80 to l0 F., inclusive." L-22 Methanol - Voted to leave unchanged. Nitric Acid - Voted to add statement "Spillage may cause fire or liberate dangerous gas," as the Uth statement of hazard. iso-Propyl Acetate - Remove the label and add "Refer to Ethyl Acetate." Tetrachloroethylene - Refer to Trichloroethylene and remove label. Xylene - This label should now be the same as the old Toluene label, which will, therefore, require printing of the old Toluene label below this heading. The Sodium Metal label is to be reviewed in regard to first aid treatment. Hold the data sheet until this has been cleared by Sanford Hill. Page $ of Dr. Knapp's report was accepted by vote of the Committee. It was agreed that Dr. Knapp would try and mimeograph all the revisions and circulate it to the Committee within the next 30 days for approval by letter ballot. 6. LABELING OF SMALL PACKAGES AND HOUSEHOLD PRODUCTS The Committee met with two representatives of the Chemical Specialties Manufacturers' Association in an effort to promote liason on the labeling of small packages. It was suggested that CSMA be recognized as the source in small household package labels. In view of the discussion, labeling of retail packages will be the work of a committee of representatives of CSMA and LAPI. For the purpose of the revision of Manual L-l, the present com mittee recommends no changes in the statement appearing on page 11. At the present time liason will be continued through Sanford Hill, who is on com mittees of CSMA and MCA. 7. REUSE OF CXANIDE CONTAINERS The memo of March lUth from Fowler; Leva, was circulated with the Com mittee. prior to the meeting. It was moved, seconded and voted that the LAPI Committee thanks the counsel for the opinion; the Committee feels that any action to bat-taken in the future should be by the individual companies. Notice of the Committee's action should be circulated, inclu ding the notation that the firms having this problem may obtain a copy of the aforementioned letter from counsel. 8. SURGEON GENERAL'S AGREEMENTS Mr. Flanagan reported on a discussion he had had with Dr. Paul Neal, who is the last remaining member of the Committee set up under the agree ments. It is his feeling that to abrogate the agreements would serve to ] twt L-23 indicate that the Public Health Service is not interested in the present situation, -which is not the case. Various alternatives were discussed by the Committee as a'means to overcome this objection and to expedite the abrogation of the agreements. It is thought possible to work out some means of revising *r abrogating the agreements without embarrassment to either the Public Health Service or to Industry. One suggestion was that consideration could well be given to the ex pansion of activities by the IAPI Committee to include representatives from groups outside the MCA. Such joint meetings might be used in place of the agreements and would also serve a useful purpose in future regula tions . A subcommittee was appointed to draft a paragraph to be included in Revised Manual L-l. This will be under the direction of Dr. Cranch and Mr. Flanagan, working in conjunction with the MCA Washington representstivefl. 9. INDEX OF MINUTES Mr. N. M. Walker has finished an index of the minutes of the LAPI meet ings from 19UU through 1951. This is being checked and he is planning to have the index mimeographed and distributed to the various members of the LAPI. On motion duly made and seconded, it was voted that the Committee wishes to extend a vote of thanks to Mr. N. M. Walker for his excellent work. 9.1 Combustible Liquids The subcommittee recommended that the top limit for the "C classifi cation of so-called combustible liquids' be set at 1^0 F., inclusive. The subcommittee is discharged. - 10. MIDYEAR MEETING OF MCA - NOVEMBER 25, 1952 A subcommittee was appointed, with F. S. Low, Chairman, W. J. Quinn and Sanford Hill, to handle the IAPI Committee section of the midyear meet ing, which is scheduled for November 25, 1952, at the Hotel Statler, New York city. Members of this subcommittee will meet as soon as possible to draw up plans for the presentation, since this material must be available at least by September 1st. 11. MISCELLANEOUS 11.1 Book by Sax Mr. Frank Low reported on his contacts With the . Reinhold Publishing Company, which he will continue in an effort to obtain a satisfactory solu tion to the problem. L-2h 12. FEDERAL SPECIFICATIONS - LABELING T.T.R 2j?l Paint and Lacquer Solvents The Committee discussed the proposed Federal Specifications on paint and lacquer solvents, and it was decided to prepare a formal reply to the General Services Administration. This reply has been sent, and Mr, Sparre and Mr, Campbell have had a personal interview with representatives of GSA. It is reported that they are favorably inclined to the principles of the LAPI Committee, as contained in Manual L-l. A copy' of the Is tter sent to GSA will be attached to these minutes. 13. NEXT MEETING The Committee voted to hold the next meeting on October 2, 1952, in Washington. Following the indicated wishes of the Committee, arrangements have been ma$e as follows: The Committee meeting will be held in the Potomac Room of the Statler Hotel in Washington beginning the morning of October 2. Members desiring sleeping rooms should write the Hotel Statler, Washington, D. C., Atten tion - Mr. John Whitlock, Sales Department, referring to this meeting. -Members who may wish to stay at the Shoreham Hotel may write to -the atten tion of Mr. Moore, the Manager, where some room arrangements have also been made. Members are asked to write for room reservations as early as possible, since the supply of hotel rooms in Washington is exceedingly short at all times, and particularly at this period of the fall. Minutes subject to approval Attachments DEC:be Douglas S. Campbell Secretary COPY numeral national issa Manufacturing Chemists' Association, Inc I Sbcmtakv's Ofpicb (FOUNDED 1172) 246 Woodipaid Building Washington 3, D. C May lh, 1952 Mr. <1. R. Stewart Room 2813, Alcott Hall Federal Supply Service, G. S. A. West Potomac Park Washington, D. C. Dear Mr. Stewart: \ In accordance with our previous conversations, the interim Federal Specifications on paint and Varnish Removers, TT-R-25lb, were considered by the Labels and Precautionary Information Committee at their meeting in Chicago, on May 7 and 8. The Committee prepared a formal statement of policy, a copy of which I am sending you herewith, and which we would be most happy to discuss with you at your convenience. The committee report follows:* We are anxious to cooperate withyou to the fullest extent in your attempt to provide for adequate precautionary labeling of materials covered by Federal specifications. We have examined the subject specifications with particular attention to the proposed labeling requirements. There is an apparent attempt to base the precautionary labeling of the products on the end uses to which these items will be put. This has not proven practicable. Ex perience has shown that each chemical product presents a distinct problem. In the case of a mixture the properties will vary with the composition. Therefore, e ach specific mixture must be considered by itself. It is probable that many different mixtures not necessarily presenting identical hazards will meet the performance requirements of each type, class and form in the specifications. In view of this, we feel that it is impossi ble to specify two labels to cover all the mixtures in types I and II. Further, we feel that the requirement that the precautionary label be printed in red is not necessary or desirable. It is suggested that Section 5.3.3 be revised to read as follows: "Each shipping container, each can packed therein, and each pail or drum requiring no overpacking shall bear, in addition to any label prescribed in the regulations of the Interstate Commerce Commission, a label bearing the follow ing information: J IL. Mr. J. R. Stewart 2- - May 1U, 1952 (a) Name of product; (b) Name and address of manufacturer or distributor; (c) An adequate label warning of the hazards of the product, listing precautionary measures which should be observed. A warning label prepared in accordance with the labeling principles of the Manu facturing Chemists' Association, as set forth in Manual L-l, 'WARNING LABELS,' will be satisfactory." We believe adoption of this suggestion will have two advantages: (a) The responsibility for providing an adequate label for each specific mixture is placed upon the supplier; (b) The same phraseology can be used in GSA specifications for other hazardous materials when, from time to time, a labeling requirement may seem desirable. Seption 6.U may be revised to call merely for those instructions. Precautionary labeling requirements are covered by the Revised Section 5.3.3. Use of the word "poison" should be limited to materials which are -poisonous-according to a generally accepted-definition of that term. Indis criminate use of the word destroys its effectiveness and should be avoided. This will be handled by the proposed revision of Section 5.3.3. Likewise, the term "volatile solvent" is almost never a satisfactory statement of hazard. As I stated above, these are the formal suggestions of the Com mittee, and it is our earnest hope that we may be able to discuss these suggestions and other general labeling policies with you at an early time. Yours truly, i Enclosure DEC:bc Douglas E. Campbell Assistant to the Secretary f