Document dYnKKz8menwdvzK7b60pOgXGq

PRESIDENT-ELECT 1, J. BLOOMFIELD N.*iiu-nal Institute of Health Pethesda. Maryland PAST PRESIDENT p h :l :p d r in k e r Ss.-h.-ci cl Pubhc Hea B<-,5cr M assac h u se11 s SECRETARY KLV.AR 0 BARNES .--Jf ;i-u:-e F ~: i SM.in .In' Fsi: F'M \ '.rcTpi'-vy ,r TREASURER I. B 1JTTLZF1ELD A' eru-an Shoe Cun.pu: :BOI BUh :,.jr.d Avenue ok j j . INDUSTRIAL HYGIENE ASSOCIATION Zu:..:h Insurance Companies j. V/. FEHNEL Me': >coLdr. Life Insurance Coinpmv G. C. HARROLD. PH. D. Chrysler Corporator. LT. COLONEL T. F. HATCH A. F. Medical Research Laboratory D. D. IRISH, PH. D. Dow Chemical Company E. G. MEITER, PH. D. Employers Mutual L^.cm-y Insurance Company ot W isconsin C. W. ML'EHLBERGER. PH. D. M'.ch'7an State Department of Health J. H. STERNER. M. D. Eastman Kodak Company MAJOR R. C STRATTON. C W. S. '..are ef Travelers insurance Company J. J. Bloomfield Philip Drinker Kehpe E. C. Barnes J. B. Littlefield M. Bowditch J. W. Fehnel G, C. Harrold T. F. Hatch E. C. Meiter J. H. Sterner W. R. Bradley T. C. L. Hemeon M. Witheridge In accordance with instructions received at the Annual Meeting of the American Industrial Hygiene Association, I ob tained permission from Doctor Townsend to transmit to you a copy of the letter which Doctor Townsend received from Mr Warren N. Watson dated February 2k, 19Ui, dealing with labeling of hazardous chemicals* Sincerely yours. H. H. Schrenk hhs/rd Enel* N 2492 c 0,/ p r Tarroc 5f<, Uatsan Secretary 7ZXEP8QH HSim 2153 HATIOSiL 21*0? MSOTtCTMlSQ CTHSKLSTS' iSSOCim OP TH5 JHITSD STJLTIS (POOKSD 18?2) 606 HOGDRASO BUILD2JD WuteLnctoii; Do 0* February 2U, l?i& rr. J- 0-> f-wnseed, Chairtsaa lyrical ?rr iuc~3 igreaaants Cosedtiee Jo So Public Health Same* >fitional Institute of Health Bsthssda, Maryland rear 3rs Trwnsaad: SCBJBCTi Labeling of Hazardous Chenicala In-response to t o o t rt^tast, th&re follows a aanorandsai on the labeling haaardoua chewicals, which way bs grouped under two heads, (1) ravrt-ary requiresrob*, Federal and State, and (2) labels and jarecaaticsary inforaatioa adopted by the aanufaoturer* this saencrsnchai gives priwazy aphasis to ths statutory requiremente, the effect of which is to cover prolusts for both inter stats and intrastate ooaaeree.* is no state Is self supportleg in chesical*, but mat purchase ucy products fros Other states> the manufacturer mat label hi a products so -let they rest requiraaants of all State and Fsdaral lass# Cheadcaia: -can be- dassifi'aa under the following headings'? (1) Industrial Chead ;ala? Tbs bulk of cheat cals are sold to and -jtei by chewicaX and oifaaar industrial plants, such as paper^ Steel, leather, utci textiles-, (2) Icoaoadc Pod sene, Xccncsdc pci sons, better teens aa aptultural inaectidldea and fungicides, are used in agriculture*? (3) Medicinal Chsalc&la# These go to the censssasr through the rug ntcre and also to lha pharmaceutical sanufacturar0 Somewhat relatad is ~ -group b-.own as reagent chssicals constated by research and analytical labora-oricso Ui) Household Preparations.# Household preparations includa such preparations as vaaBcig powders, bleaching solutions, household insecticides ind iry rleaning preparations# The last three groups are sold to a large extant through whole salers? ill four groups are handled to sone extent by rep&ctarsa * * tt Mi 01 7 0 -c. N 24926.01 .CoT3r Cnder rogulallcna c1 -,he Interstate C-rrra; Serous articles arid -;q)lo sires ~ust be 'ibelad vi'h of labels and auipp-i in a cort/uner author! ?v urd also include the spr.t.fi -.aMcns fvr .tach rortair.sr, *o carboys and ir.cilucdrtf .ixs, boxes, otco tzri.ixi -n> a:' Zr u.art.'. x- ra Shipsenta of industrial chaadcals, occnccds pel sons; drugs and household preparations, either by rail, truck or water rast corf cm vi oh ':!-: labeling and container regulations listed ceiss? Rafarsncesi 1.* *Refalations for Transport-andan of Xxpleadvsa and Other Dangerous Articles by Water, Rail, Freight, Sxpreas and Baggage Seer-vises" * 213 pagasj Superintendezrt of Bccucamts# Gcverraaant Printing Office, Washington, D* C; Price, UO cants* (Sots* A&endsteuts sines -January ?, l?Ui are svaiiabla in sineograph fora, or a cosplat* print is available from the Bureau of Sxplogivss, 30 Tewsy Street, See Icrk City* 2. "Motor Carrier Safety Regulations", Superintendent of Docuassnts, Gonrsrnasat Printing Cffics, Washington.. D* 0* Pries, 15 esntso 3 "Explosives and Other Dangerous Articles on Board Tassels", issued by ths Department of Caaaaeros, But'aaa of Mart.no Inspection and Isvigaiion, 3S3 pages* Superintendent of Documents, CScrsmaent Printing Office. Washington, 0. Price, |l*00o (Sote: Sinca Mardv lu2 the w&t-r .r-til lations have been under the jnrisdicticn of the rJ* 3, Coast Ouardo) There follows a list of the eleven I*CcC* labels? Class B Poisons Corrosive Liquids Class S Poisons (War gas) Wcn-inflsaoEabls Oasss Pirswcrfcs Poison Gases Explosives (Saapls) Inflasnabls Gases Explosives InflsasEable Solids and Cxliialig Materials Rail, trick 3.-d water regulations iamcnina with respect j tal-sl aid. container requirementsj -T-h - rwise :02cer-:a would be prohibited * Att-ached hereto are the slavan label* above referred to* n 7 "? 7 u000 scowacc poisons Agricultural insecticides and fungicides are under the Jurisdic tion of the federal Insecticide Act and 32 State laws Toxic products, such as calcium ax senate, without exception carry a red poison label with skull and cross bones, and word "POISO**, and also the antidote o This latter label is in addition to the loCeCo Class B Poison Label, mandatory under the I?CoCo regulationso iEDICIHAL CHEMICALS The labeling of Medicinal aheadcals falls under the Federal Food, Drug and Co acestic Act and the State laws, which harmonise with the require ments of the Federal Act* Tbs requirements cover components,, dosage and pre cautions far use, with special labels for narcotic drugs? BDpagjflTfP FKBPittATIcaB The Federal Caustic Poison Act specifically enumanitea the fol lowing 12 chemicals* Hydrochloric Acid Sulfuric Add Hitrio Acid Carbolic Add Oxalic Add 3alt of Oxalio Add Acstic Add Hypochlorous Add Sodium Hydroxide Potassium Hydroxide Ammonium Hydroxide Silver Xitrato The labeling requirements for these twelve chemicals include the word POISO!*, name of product, antidote, sod seller or makero Many states have identical or similar acts Household insecticides and fungicides are covered by the Federal Insecticide Act or most of the State insecticide acts Every state has a pharmacy law and most states have in addition a poison lawa In some oases, these are combined in a single acta Under these acts, poisew labels, with antidotes, are required for an extensive list of products, which vary frow state to states *** , Supplementing the statutory requirements, the chemical menufao-- turer has adopted special labels for particular products and has prepared and distributed to users special information on handling and uslngo This coverage is vary extensive and comprehensive* 0j oo4 i The VoCo&o has issued 30 nar.uala in regard v:> the handling of different kinds of containers filled with different kinds or groups of hazardous chemicals** These are primarily designed i'T tha ;rotection of the consumer. These include several special labels which ssrve to warn the transportation employee as well as the consumer. A list of the aanuals is attached hereto, and. also copies of the seven labels theraundaro SURgBQg GSXBULL AGRSS2SSBTS Agreements between the air goon General of the 0. S. Public Health Service and the producers have been concluded on the following; products* Methanol* Methyl Alcohol, or Wood Alcohol Carbon Tetrachloride and/or Similar Volatile Chlorinated Liquid Hydrocarbons Carbon Bisulphide Aniline Oil Industrial Bensol (Benxene) Chlorinated Haphthalenes, Chlorinated Biphenyls and Chlorinated Diphenyl Oxides Attachsd hereto is a complete set cf the agreements and the labels thereunder. GSLABEUBD HAZARDOUS PRODUCTS The problem of additional labeling resolves itself in the datr adnation of chemical products of a hasardous character not now labeled under (1) Federal and State lass, (2) agreements with ths U S. Public Health Ser vice^ and (3) by the manufacturer or sellero It is suggested that coasti.ttee members submit to you as Chairman a list of unlabeled products of a hasardous character. This list might in clude products on which a precautionary warning for adequate ventilation is required, or a warning to avoid skin contact or inhalation of fuses or duet, Experience has riicrnn that simple, clear warnings are sore effective than long paragraphs* Many products already carry two labels, as explained in this memorandum, and it may be questioned whether an excessive number of labels or excessive use of the word "F0IS0H* would be effective, or in fact have the reverse effect. Plsnt facilities for adequate ventilation, etc., are of primary importance in the protection of the users Two examples, perhaps unusual in character, illustrate some as- . pacts of,the label problem, According to newspaper reports on poisonings, drinking of kerosene oil ranks high In -he cause*'of child deaths and poisonings in spite of its strong odor and flavorQ la this case the solution appear* to involve parental responsibility to keep the child ssray froa the kerosene oil can On the other hand, tincture of iodine ranks high in poison ings through mistaken identity* Tincture of iodine without exception carries a red warning label narked "POISCJP with skull and cross bones* It has a strong warning od.br, a deep color, and a burning -taste, and is always sold in rrall bottles which should prevent its being mistaken for a beverage* It is difficult to see why iodine poisoning cases are 30 coasnon despite warning labels^ odor, color and taste, and one rust conclude that there is no com plete answer to prevention of accidents due to carelessnesso There is no question, however, that adequate labeling plays a vital and Important part as a safety device and that the use of precautionary labels and literature should be extended for hazardous products* In conclusion, I want to offer our fullest cooperation on the adoption of labels and precautionary inforaaticn for products suggested by your a n--d ttee* t Very truly yours, (Signed) Warren W* Watson Secretary