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Vista Chemical Compony 15990 N. Barker's Landing Rd. Post Office Box 19029 HoustonJexos 77224 Phone |7I3) 53V3200 &S: SS^TS: 3t- December 27, 1985 VIS1A Wanda Macisaac Molecular Biotech 139 Main Street Cambridge, MA 02142 Dear Wanda: Per our discussion, enclosed is a Material Safety Data Sheet for Vista ALFOL 12 Alcohol. The toxicity data is listed in Section 5. Also, the NIOSH Registry of Toxic Effects of Chemical Substances 1983 Supplement has do-decyl alcohol listed on pages 678 and 679. The registry number for do-decyl alcohol is JR 5775000. I have also enclosed a technical data sheet on VistaTs alcohols. Please call me at 713-531-3445 if you have questions on the information enclosed. Sincerely, Thomas G. Grumbles, CIH Environmental Quality Manager bh Enc. VVV 000017480 Thomas G. Grumbles VIS1A VVV 00G017481 CHARTER VISTA CHEMICAL TOXICOLOGY ASSESSMENT COMMITTEE Functions 1. Review toxicological testing needs for Vista products and recommend appropriate testing. 2. Select, au<4it and monitor contract testing laboratories to assure testing is done in a cost effective, timely manner according toapplicable regulatory procedures and professional standards. 3. Review new or modified products to pre-manufacturenotification is required Substance Control Act. determine under the if a Toxic 4. Review customer requests for test data and formulate appropriate responses. 5. Monitor scientific literature and communicate new toxicity or health effect information for products produced or used by Vista. Membership T. G. Grumbles - Environmental Quality Manager - Chairman 0. C. Kerfoot - Director, Chemicals Technical Service Alan Nielsen - Senior Research Micro-Biologist Bill McClain - Attorney, Environmental and Biomedical Affairs Department Additional members, such as the Vista Medical Manager or toxicology consultants will be included on an ad-hoc basis. Meeting Dates The committee shall meet quarterly. scheduled when necessary. Other meetings will be Records A written record of all proceedings will be kept. This record will include, but not be limited to agendas, meeting minutes and support documents. A summary report of all testing done by Vista will be kept at the R&D facility and in the Biomedical and Environmental Affairs Department. yy/y >Oi 7482 'Pou \ V; <j v-w ^ 4Ni D.V., V V, \ *V\ V sjM'J 0HEMNET extends transport safety CHEMNET -- the industry's mutual aid system for transportation emergencies -- got on track Novem ber 1. It is the third element of the new National Chemical Response and In formation Center (NCRIC) to go into place. Expanded programs for CHEMTREC and first responder training recently went into service. A final initiative, a Chemical Referral Center (CRC) is scheduled to start in December to provide the public with basic information about chemicals. CHEMNET is an outgrowth of CHEMTREC's service that provides information to emergency crews re sponding to a transportation incident involving chemicals. Going one step further, CHEM NET is a mutual aid network between ers that will speed emergency nders to the scene of serious chemical distribution accidents. They will act as advisors and offer hands-on aid only if requested by the official in charge. The network will be activated when a member shipper cannot respond promptly to a problem involving his chemical that requires the presence of a chemical expert. The shipper would then activate CHEMNET, which would contact a nearby chemical company response team to go to the scene. At startup, 55 companies were members of CHEMNET and another 10 companies are expected to join shortly. Network members have com mitted 100 emergency response teams to the system. In areas where the chemical indus try can't respond quickly, CHEM NET will rely on for-hire emergency response contractors. Two such com panies with 20 teams have already agreed to help, and several more are expected to join the system soon. Mayhew, director of the Nationmical Response and Information Center, said that overall, the response teams "are distributed geographically where the industry is concentrated, This map shows where CHEMNET is presently operating. Dots denote the locations of member company response teams. Stars signify where for-hire cleanup contractors are stationed. Circled numbers are the number of emergency response teams in the general area. and that's where most accidents occur. " The Rocky Mountain and upper plains states are "the only real areas where we need more teams," Mr. Mayhew said, predicting that "we'll pick up more teams quickly." The startup date for CRC may come around Christmas, Mr. Mayhew said. Chemical companies presently are busy complying with the federal hazard communication standard that goes into effect November 25. After that deadline has passed, the 97 companies that have joined CRC should be able to provide the center the index of their products needed for reference files. "Only a few companies have sent this information to CRC so far," Mr. Mayhew noted. He expects an "information crunch" to hit the center around the first week in December. Some companies are providing data tapes that are com patible with CMA's IBM 36 comput er. "That will speed things consider ably," he said. The only sticky point he sees in operating the new center is in refer ring callers to companies. The initial call to the center is toll free. "And many companies have set up toll-free lines to get referral calls," Noting that some members have not taken that step, he emphasized that it needs to be done "to complete the loop." Otherwise, he said, "the public -will be turned off." Enrollment is still open for both CRC and CHEMNET, and Mr. Mayhew urged members to join "for the benefit of the entire industry. VVV 000017484 S8*i.TQ000 AAA j?->y n uU ~\\ U VLorv Co^-V^C5\ )}6/85 SPECIAL REPORT How To Deal With The Media Neither wind, rain, sleet, nor snow can keep the news media's interest from your wastewater treat* ment plant door in the event of an "unfortunate" incident. Public knowledge and awareness of the world we live in has increased and now, a crisis means instant media attention. According to Christine C. Bott and Thomas E. Decker, authors of a paper presented at the Water Pollution Control Federation's annual conference, treatment plant managers must know how to deal with the media. Crisis communications has come of age and the public's heightened awareness and inter est has extended into the environmental and pollution control area. A derailed train spilling acid into a stream or a chemical plant accident that spews a toxic cloud into the air become prime time and front-page national news, the authors warn. Whatever Can Go Wrong, Will If you think that it's the other guy's problems that come under the scrutiny of the news media-think twice. It doesn't take a major disaster to get the attention of your local media. Just see what happens with a sewer collapse, a plant bypass, or a treatment chemical leak or spill aj your facility. Bott and Deck er say that the media will be probing for answers and insisting on the facts before you can say "biochemical oxygen demand." Crises have a way of happening, even in the best operated and maintained wastewater collection and treatment systems. You must be ready to deal with such an occurrence by planning for it and reacting properly. Crisis communication planning and response may seem like a huge waste of time if you never have to use the plan. But just think how nice it would be if you already had a written, workable plan in place in case you did need it. What does the plan provide? It provides you with a framework and a set of proce dures for helping you and your treatment plant staff deal with every conceivable and sudden stroke of ill fortune. The big question is how to develop a plan for catastrophe. The first step is to develop the base for successful planning. This means developing a policy. You will have to emphasize communications ail year round-not wait until a crisis occurs. You should keep the public informed, including the media, in order to develop and enforce- your credibility. During a crisis, communicate. Silence breeds suspi cion, or encourages indifference, the authors say. It seldom wins understanding, sympathy, or support. Be prepared for every conceivable disaster. In other words, have a communications plan. The plan should be specific, updated regularly, practiced, and commu nicated to everyone in your facility. Where To Start Initial development of the plan must begin at the top of your organization. As the person in charge of the entire utility, you should appoint a committee to prepare the plan. Bott and Decker suggest that this committee be composed of individuals who are thor oughly knowledgeable about all aspects of the charac teristics and operations of the various facilities be cause they will be best equipped to ensure that all possible eventualities and ramifications have been covered. You should designate a spokesperson for your facil- ity. This person should be someone in upper management who is cool under fire, thinks quickly, and is a good speaker. The authors suggest the director or the general manager as two good choices. On the other hand, some larger utilities choose their professional communicator or public relations officer. It all de pends on the size of your facility. In larger facilities, this person usually is kept free for speech writing, fact findings, and news release preparation. ; j Crisis Response Your plan is set, you've covered everything, and, with any luck, you'll never have to use it. But just for a moment, let's pretend that all's not well with your wastewater treatment plant, and a crisis occurs. Quickly, you spring into action. When a disaster situation develops, the best advice to take may be that of Bott and Decker: Reduce confusion, panic, and misunderstandings; Present a united front; Eliminate hearsay and rumors; Increase potential for balanced news media coverage; Establish credibility and honesty. There are several simultaneous activities that you must deal with the instant a crisis occurs: Assemble the response team and the spokesperson that you have already identified in your plan; Attend to the health and safety of employees as well as the community as a whole. Inform the families of any affected staff members; Notify top utility management; Notify the media of the occurrence; Obtain all pertinent facts about the situation and determine the positive aspects; Prepare a formal statement; Start a log of responses and actions related to the crisis. Remember, it's hard enough to gather information under ordinary circumstances, let alone in a crisis. Obtain the correct information and disseminate it. Be prepared to answer questions about the mone tary estimate of damages, time frames for when you will resume normal operations, and the possibility of threats to life or safety-information that will in all probability have been given to the emergency re sponse officials to help them in their duties. Discuss with these officials in advance how, when, and by whom this information will be released to the media. u Page 4 VVV 000017486 0194-0147/85/$0+.50 Thomas G. Grumbl. XF: To ^ *rtN Mo 11 \ ff' ^CAcxv n ~Torr> MuV^r frcxr 'Z'lTr- ~\) <3 VVA. r li t? t X. v"c.i >2.O VIS1A Date 1 /c 1 TV, 3)0- jcV \-W 1.of 3 j)o. T ^ r-Aiir.-v Co of^-V- vjh'.Of Vvj ^ ; JtA `i+S 10. /'-r 1 a cce-t. s VVV 000017487 Occupational Health & Safety Letter, December 22, 1985 3 That is not entirely new, of course, but the Office of Technology Assessment (OTA), a branch of Congress, has issued a report emphasizing the importance of doing more to protect both women and men as well as the fetus. OTA found that evidence linking specific agents with reproductive or developmen tal effects in humans is, for the most part, inconclusive. However, four hazards are now regulated in part because of their known effects on adult reproductive capacity or embryo development. They are ionizing radiation, lead, ethylene oxide and dibromochloropropane (DBCP). - Among the factors complicating the study of reproductive health hazards, according to OTA, are individual variations in susceptibility to suspected agents, difficulties in extrapolating information from animal studies, incomplete data on the agents, their possible toxic effects and the number of workers'exposed. - Many of the studies have been evaluated only in men, women or offspring, but not in all three. UNIONSTfflfT^^ AS MONITOR:- The U.S. Court of Appeals in Boston has upheld the right of a union to have its own.industrial hygienist measure noise levels in a workplace. The National Labor Relations Board last January ruled that a union's request for access to a workplace in order to carry out its representation function should not be considered the same as a request for information needed for bargaining. Instead, NLRB adopted a more restrictive policy favoring the employer's interest in excluding "outsiders" from company property. Even so, NLRB found that the Holyoke <Mass.) Water Power Co. had violated federal labor law by denying Electrical Workers Local 455 the right to have an industrial hygienist of its choice measure the noise levels in a fan room where the company had provided personal protective devices to workers who maintained and repaired the equipment. The company challenged the NLRB order in-the 1st U.S. Circuit Court of Appeals in Boston. The AFL-CIO filed a brief to argue the union's right to relevant data. A three-judge panel of the court agreed that the company was required to grant the union hygienist access to the fan room and noted that the information sought was clearly relevant to collective bargaining. At the same time, the judges said NLRB had "reached the same result by a different route." The court also noted that OSHA's issuance of a noise standard did not make the requested information irrelevant, adding: "The union is entitled to bargain for a standard that exceeds the one established by OSHA." CORPORATE SAFETY DIRECTOR JAILED FOR LYING TO OSHA: Carl MacPetrie, safety director for GTE-Valeron Corp., has been sentenced to three months in jail and fined $10,000 for lying to an OSHA inspector during a September 1981 visit to the company's tungsten carbide tool manufacturing facility in Syracuse, NY. He pleaded guilty in his appearance before the U.S. District Court for the Northern District of New York. In addition to the three-month jail term, he was fined $10,000. He may appeal the sentence. OSHA said it was believed to be the first jail term and fine for this type of offense. Under the Occupational Safety & Health Act of 1970, anyone who "knowingly makes a false statement, representation or certification" to OSHA is liable for a fine of up to six months in jail and/or a fine of up to $10,000. According to the charges filed against him, MacPetrie informed an OSHA inspector that a "rough cut saw" used to grind tools was down for repairs. In fact, the saw Jiad been disabled at his direction to prevent the OSHA compliance officer from Obtaining an accurate reading on worker exposure to cobalt and other dust emitted during machine operation. "We expect good faith on the part of employers in preventing occupational injury VVV 000017488 Thomas G. Grumbled" ---------------------------- XF:__ T>i^Aoes V l t>r molI DiEecAdfc.3 IS1A - ------------------- Date c,t.c^\(?5-o a^-v-vcAe. \)qrc>oos ^ieuViuf. ae.Vio/'s o^HA 0*aiJ . Occupational Health & Safety Letter, December 22, 1985 3 That is not entirely new, of course, but the Office of Technology Assessment (OTA), a branch of Congress, has issued a report emphasizing the importance of doing J more to protect both women and men as well as the fetus. OTA found that evidence linking specific agents with reproductive or developmen tal effects in humans is, for the most part, inconclusive. However, four hazards are now regulated in part because of their known effects on adult reproductive capacity or embryo development. They are ionizing radiation, lead, ethylene oxide and dlbromochloropropane (DBCP). Among the factors complicating the study of reproductive health hazards, according to OTA, are individual variations in susceptibility to suspected agents, difficulties in extrapolating information from animal studies, incomplete data on the agents, their possible toxic effects and the number of workers exposed. Many of the studies have been evaluated only in men, women or offspring, but not in all three. UNIONS WIN RIGHT TO HAVE OWN HYGIENIST AS MONITOR: The U.S. Court of Appeals in Boston has upheld the right of a union to have its own industrial hygienist measure noise levels in a workplace. The National Labor Relations Board last January ruled that a union's request for access to a workplace in order to carry out its representation function should not be considered the same as a request for information needed for bargaining. Instead, NLRB adopted a more restrictive policy favoring the employer's interest in excluding "outsiders" from company property. Even so, NLRB found that the Holyoke (Mass.) Water Power Co. had violated federal labor law by denying Electrical Workers Local 455 the right to have an industrial hygienist of its choice measure the noise levels in a fan room where the company had provided personal protective devices to workers who maintained and repaired the equipment. ^ The company challenged the NLRB order in the 1st U.S. Circuit Court of Appeals in Boston. The AFL-CIO filed a brief to argue the union's right to relevant data. A three-judge panel of the court agreed that the company was required to grant the union hygienist access to the fan room and noted that the information sought was clearly relevant to collective bargaining. At the same time, the judges said NLRB had "reached the same result by a different route." The court also noted that OSHA's issuance of a noise standard aid not make the requested information irrelevant, adding: "The union is entitled to bargain for a standard that exceeds the one established by OSHA." CORPORATE SAFETY DIRECTOR JAILED FOR LYING TO OSHA: Carl MacPetrie, safety director for GTE-Valeron Corp., has been sentenced to three months in jail and fined $10,000 for lying to an OSHA inspector during a September 1981 visit to the company's tungsten carbide tool manufacturing facility in Syracuse, NY. He pleaded guilty in his appearance before the U.S. District Court for the Northern District of New York. In addition to the three-month jail term, he was fined $10,000. He may appeal the sentence. OSHA said it was believed to be the first jail term and fine for this type of offense. Under the Occupational Safety & Health Act of 1970, anyone who "knowingly makes a false statement, representation or certification" to OSHA is liable for a fine of up to six months in jail and/or a fine of up to $10,000. According to the charges filed against him, MacPetrie informed an OSHA inspector that a "rough cut saw" used to grind tools was down for repairs. In fact, the saw had been disabled at his direction to prevent the OSHA compliance officer from obtaining an accurate reading on worker exposure to cobalt and other dust emitted during machine operation. "We expect good faith on the part of employers in preventing occupational injury VVV 000017490 ,4 Occupational Health & Safety Letter, December 22 1985 and illness, and we're willing to work with those who demonstrate that good faith to correct any problems in their workplaces," said Acting Assistant Secretary of Labor Patrick R. Tyson. "But those few employers who callously assume that OSHA will ignore deception and lies and blatant disregard for the welfare of workers would do well to reconsider their approach." More evidence that a crackdown against violators of occupational and environmen tal laws came in an indictment of the owner of four chemical waste disposal firms on charges of criminal mishandling of toxic waste, including three counts of placing employees in danger of serious injury "through conduct showing an extreme indif ference for human life." It was the first major case in which the government has brought criminal charges under the "knowing endangerraent section" of the Resource Conservation and Recovery Act of 1980. The indictment was returned against Arthur J. Greer, 48, of Orlando, FL. His companies are City Industries, Inc., City Chemicals Company, Inc., City Environmental Services, Inc., and Recovery of America Corp., all of Orlando. Greer caused employees "to become ill by having them sniff samples from drums of various wastes to determine the content of the drums, rather than performing the chemical analyses required for this purpose," said the indictment. In addition, Greer caused employees "to determine the ignitability of various . wastes by placing samples thereof in soft drink cans and placing lighted matches in these cans," the indictment said. Moreover, it added that clothing was burned off an employee when he used a forklift to pick up a deteriorated drum containing waste. That's not all. He was charged with mail fraud for allegedly cheating customers who contracted with his firms for waste disposal, operating without a federal permit and, finally, submitting fraudulent claims against the federal government for cleanup and disposal of chemicals. If convicted on all counts, he faces a maximum penalty of 12 years in prison and a $310,000 fine. Note: A little-known Criminal Fine Enforcement Act of 1984 greatly increases the monetary penalties which can be imposed on companies willfully violating environ mental and occupational laws. For example, an employer who willfully caused a worker's death by violating a standard enforced by OSHA could be fined $500,000 and interest. Under the old law, the limit for a criminal fine would have been $10,000 with no interest. U OF MASS. GETS OCCUPATIONAL HEALTH GRANT FROM KELLOGG: The University of Massachusetts Medical Center in Worcester has received a three-year $396,138 grant from the W.K. Kellogg Foundation of Battle Creek, MI, to develop an educational program to improve health and safety in the workplace. The grant will enable the university's occupational health program, a division of the Department of Family and Community Medicine, to establish three projects aimed at increasing the knowledge and skills of health professionals from varied disci plines to improve recognition and prevention of work-related injuries and illnesses and to improve workplace health and safety. The three projects are: a one-year, clinically oriented residency training program in occupational medicine; a three-week intensive institute in occupational health and safety; and a two-month student training and placement program in occupational health and safety. The residency program will train eight physicians in various aspects of occupa tional medicine over the next three years. The institute, to be called the New England Occupational Health and Safety Institute, will be held annually starting next June, when a series of six courses will be presented. The student training and placement program will begin next July, with 14 medical, nursing, public health and other students participating over the next two VVtf 000Q1T491 Vista Chemical Company 15990 N. Barker's Landing Rd. Post Office Bo* 19029 Houston,Texas 77224 Phone (713) 53V3200 December 27, 1985 XF: nQO*?- VIST/ Dean Hill, Chief Pesticides and Toxic Substances Branch EPA, NEIC Bldg. 53, Box 25227 Denver Federal Center Denver, CO 80225 Dear Mr. Hill: I spoke with Bill Palmer, of your staff, today regarding your request for a copy of Vista's surface active agents catalogue. Currently, Vista does not have a single document describing our products that fall in that category. As I understand your needs, your group is trying to build a data base to better understand trade names and chemical constituents of end-use products you encounter during TSCA investigations. I have enclosed 5 technical data sheets describing our products that could be used as surface active agents in some applications. Please feel free to call me if you have questions regarding this information. ' inc.cure lv. Thomas G. Grumbles, CXH Environmental Quality Manager bh Enc. Thomas G. Grumbles .~ _____________ yfQ5Hl ir rf VISTA * \uYs\^ WA^. Com \|W oooo 587 Current Report Right-to-Know SMALL OIL REFINERIES SUE OSHA CLAIMING AMBIGUITIES IN STANDARD Three small independent oil refineries asked a federal court in Washington. D.C., Dec. 6 to stop the Occupational Safety and Health Administration from enforcing the hazard communication standard as it pertains to lubricating oil because of ambiguities concerning which oils are carcinogens. OSHA violated the Administrative Procedure Act by fail ing to 'clarify, interpret or modify the standard." which became effective Nov. 25. "to provide a definition of the distinction between mild and severe hydrotreating in the refining and processing of lubricating oil." according to the suit. Calumet Industries, Inc., et al. v. William Brock, et at. (No. 85-3889), filed in the U.S. District Court for the District of Columbia. In addition to Calumet, a Chicago. 111., oil company with a refinery in Princeton, La., the suit was filed on behalf of Macmillan Ring-Free Oil Co.. Inc., New York. N.Y.: and Seaview Petroleum. Inc., a company located in Blue Bell. Pa., with a refinery in Paulsboro, N.J. The three were characterized in their request for preliminary injunction as "relatively small in size." Joseph Woodward, counsel for appellate litigation at OSHA, told BNA Dec. 10 that he had received a copy of the suit the day before, and had just assigned it to an attorney. The oil companies asked U.S. District Judge Charles R. Richey to order OSHA to respond to their request for documents and to answer their first set of questions by Dec. 16. although a defendant normally would be given 45 days to respond. The expedited request is being pursued by the companies in order to "alleviate the irreparable injury they are suffering from OSHA's arbitrary and capricious action." according to the suit. The small companies are "losing substantial sales" be cause some oil purchasers, such as General Motors, will only buy oils that do not require a label. Calumet wrote to OSHA prior to filing the suit. To change its process. Calumet would have to spend $22 million to $25 million, and still would not be certain that the new procedures for treatment would produce non-carcinogenic products, the company continued. Raymond Wright, executive vice president, Seaview, also wrote to OSHA stating that his company is reluctant to spend money on further processing techniques "because of the likelihood of animal testing establishing the fact that all naphthenic lubricants are potentially carcinogenic." No Undue Burden OSHA will "not be unduly burdened" by the expedited request since officials have recently held meetings on the standard, the suit related. The companies noted that a chemical is considered to be a carcinogen under the standard if it "has been evaluated by the International Agency for Research on Cancer and found to be a carcinogen or potential carcinogen." IARC concluded that mildly hydrotreated oils are carcinogenic to animals, but for those that are severely treated the data are inad equate to permit an evaluation of their carcinogenicity (Current Report. Nov. 21, p. 509). Consequently, only those oils which have undergone mild hydrotreating need to be labeled as carcinogenic. IARC does not "provide a clear definitional distinction between mild and severe hydrotreating." the plaintiffs con tended. Because of this, some of the major oil companies, such as Exxon and Shell, have "taken unfair advantage of the ambiguities" by relying on their own "proprietary" test results to characterize their "processes as severe hydrotreating," when in fact the processes are mild hydrotreating, they continued. Thus, the firms are being allowed to engage in " private rulemaking' in order to avoid the Standard s labeling requirements," they added. In addition, the suit alleged, employees of those firms "avoiding the labeling requirements, will be adversely affected." Although OSHA is aware of the problems, it has not issued a notice in the Federal Register distinguishing between the two forms of treatment, "so as to determine whether other manufacturers purporting to be exempt from the standard must in fact comply," the suit declared. OSHA "may, in fact, be conducting itself in accordance with a policy that, absent a specific budget allocation to support an interpretative rulemaking process, it will refrain from conducting rulemaking to clarify the standard until ordered to do so by a court," the companies contended. Following a Nov. 7 meeting with the oil companies, agency officials had predicted that a notice would be pub lished before the Nov. 25 effective date of the standard. An OSHA health standards official told BNA Dec. 10 that the agency held an internal meeting on the issue Dec. 6, and is still considering a Federal Register notice. OSHA will make a final decision concerning its course of action within a week, and will then make an announcement, he said. Cotton Dust REVISED COTTON DUST STANDARD ANNOUNCED; MEDICAL SURVEILLANCE REQUIREMENTS RELAXED The Occupational Safety and Health Administration Dec. 5 announced final revisions to its cotton dust standard which relax the medical surveillance and exposure monitoring requirements of the rule, but restore wage retention protec tion for workers who must be removed from cotton dust exposure. The revised rule is tentatively scheduled for publication in the Federal Register Dec. 13. The standard reflects joint recommendations made by the Amalgamated Clothing and Textile Workers Union and the American Textile Manufacturers Institute, the agency re ported. "A commitment to worker safety and real coopera tion between labor, industry and government made these revisions possible." Secretary of Labor William E. Brock stated in announcing the regulatory action. The new standard, Brock said, will be more cost effective, more performance-oriented, and will "guarantee the neces sary protections for more than 170,000 workers in the textile and non-textile industries." 12-12--85 Occupational Safety 4 Health Reporter 0095-3237)85/50 - .50 VVV 0000174^4 'nteroffice Communication TO: Don Wharry FROM: DATE: Tom Grumbles December 20,1985 SUBJECT: ST&S MANUAL - LABELING SECTION fY"\ CsAwc* VBIA I would propose the following format for the labeling sections of the manual. I) Introduction (draft attached) II) List of products needing labels (attached) III) Actual copies of some typical labels: this would include drum labels for typical products; i.e., several alcohols, ethoxylates, industrials, etc., and the same for sample and bulk labels. IV) As part of III above, basic labeling instructions. Below is the proposed introduction. This section contains a list of VISTA products that must be labeled according to the OSHA Hazard Communica tion Standard, 29 CFR 19L0.1200, and samples of those labels. These labeling requirements should not be confused with DOT labeling and placarding requirements found in 49 CFR. The OSHA standard requires labeling of all chemicals which present physical or health hazards. The OSHA health hazard definition is very broad. Therefore, many Vista products that are not hazardous by DOT definition are OSHA defined hazardous materials and must be labeled accordingly. OSHA labels must be applied to all containers, regardless of size. Labels have been developed for drums, samples, and bulk containers (i.e., railcars and tank trucks). Samples of these lables are included in this section. All questions regarding labeling content should be directed to Environmental Affairs in Houston. requirements or Biomedical and As part of each label sample section we should put a brief description of the label application procedure. For example: Drum labels are x 11, self-adhesive peel-off back. Two lables per drum should be applied, one on each side. Instructions used. VVV 000017495 Don Wharry December 20, 1985 Page 2 Please call when you have reviewed this so we can discuss development of the labeling section. T. G. Grumbles bh Att. cc: 0. C. Kerfoot oooox-^6 OSHA DEFINED HAZARDOUS MATERIALS PLANT AND HAZARDOUS MATERIAL ABERDEEN None BALTIMORE Aqueous Aluminum Chloride Anhydrous Aluminum Chloride Muriatic Acid Spent Caustic Spent Sulfuric Acid HAMMOND SA-597 Sulfonic Acid SA-697 Sulfonic Acid C-550 Slurry C-560 Slurry C-640 Slurry VMC-100 ALFONIC 1412-A Ether Sulfate ALFONIC 1412-S Ether Sulfate LAKE CHARLES LAB Cion Normal Paraffins Cl 113 Normal Paraffins C1416 Normal Paraffins C1214 Normal Paraffins C1216 Normal Paraffins Benzene 41 41 Oooo -4 PRODUCT YES NO X X X X X X X X X X X X X X X X X X X LABEL AVAILABLE? BULK SAMPLE DRUM HAZARD(S) XX X XX X X XX XX XX XX XX XX XXX XXX XX XX XX X X X Corrosive Corrosive Corrosive Corrosive Corrosive Corrosive Corrosive Irritant Irritant Combustible,Irritant Irritant Combustible,Irritant Combustible,Irritant Combustible.Irritant Combustible.Irritant Irritant Irritant Irritant Flammable, Irritant, Human Carcinogen c4) X0Oe0 c340O)0 UCJ X0 33 In cj CJ c 5 g3B3 c c c c c c cX X X x 4J 4-1 4-1 4-> 4-1 4-4 44 ** cs 33 Xc Xc to to X cx to CO to to CO 4_l 4-1 X x 4-1 co W H H X X Ih Vl u Cl to (0 x 4-1 XX Vl l-i CO to 4-4 4-4 H t. M CO to 44 44 X H Vl M 44 44 44 44 44 44 44 44 44 44 X H In H Vi u Cl M u 14 X X Hr I--1 l-l Vi V- Vl X X X I-H V Vi 1-4 4-4 3 3 3 3 888 3 3 3333333 33 3 33 3 Vl U Vl 4J 4J 44 44 44 44 44 44 44 44 44 Vi X X X *H X H H *H X H H X X (--( 01 41 01 a 41 41 01 3 01 OJ 01 Vl Vl Vi Vl Vl Vl Vl Vl 14 14 Vl * L * r-i rH -H rH pH rH rH U V4 Vl u Vi u U 14 V* 14 u A A A4) 4) 3 41 01 X x 01 42 42 43 43 43 1--i M X hi X X 1--1 1--1 1-4 1-4 44 > H rH pH X Tt H H H r*1 X X hH H 44 H *H 4J 44 44 44 4J 44 44 44 44 44 A A A c cX X LJ X 4-1 X 4-> 44 4-4 4-4 44 44 e e 3 44 44 44 44 44 44 44 44 8 8 3 3 3 44 44 44 8 ato a m CO tn (A m to (0 cn CO 01 to 01 0} CO 0} 01 CO CO CO 3 CJ a U U U CJ CJ 3 3 3 3 3 CJ O 8 3 a gggX * 553 5R 3 3 3 4-4 3 3 44 44 44 44 3 3 3 3 3 3 3 3 44 44 44 44 44 3 3 3 44 B fc Au g XXx X R 4=1 42 43 XI H 43 43 H 1-4 1-i H 44 44 44 44 44 44 44 *H H H H H 44 XJ X H fe E Eu to to to to H Fs b e CO E R b Vl R Vl VI Vi Vl 3 3 3 8 3 3 8 3 M Vi 14 Vi V 8 3 8 Vi r> a Mo pH pH rH rH O O o O O pH O n O O l-l O CJ Vl V Vl Vi n o O O OO l4 14 14 Vl O O O Vi o l-l ( UCb Cb lb CJ CJ CJ CJ CJ Cb CJ CJ CJ CJ X CJ CJ 44 X 1-- CJ CJ CJ CJ CJ CJ CJ 1-4 1-4 1-4 X X CJ CJ CJ X w-e<Ja 44 <>< as o to -0J4 cn hhbG<JOJ] vs X=033I XXX XXXXXXXXXXX X X X X X XX XX XXX XXXX XXXXXXXXXX XXXXXX xxxxxx xxxxx xxxxxxxx xxxxxxxxxxxxxxxxx xxxxxx H c5ao=j zO co aClS, W>- xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx vvv 00001749a 3 X K o 3 < 3 H i-- X 3 X 33 33 >*, 3 3 3 3 X X X X ao 3 ,-H XXXXX 3 3 3 3 w X Cb o 3 3 3 3XX X X 4C X 33 rH i4 X X X fH X X X >> >> >1 >4 X 5b X 5b 5b XX h-2 X3 i4 oo XXXXXo0 o o < 8 3 U o X o o o oXX X X 4400 CJ H Vi * 8 s CJ X 0) O 01 X o XX X X X "o X 0 X X X X X X X A X X u X X o o 0 tJ 0 u o c o 0 CJ X X X X w X X X o Z < * 8 8 CJ X X o o i4 X X X X f4 X i-H X AX 3X wwu aw 333 3 *--i i4 X f-4 o o X o o o o o < Q < o o o o 33 o m o CM as = U a CJ CJ CO O o o o a X o o X X u u CJ u CJ CJ (J u o o o o o -a- NO CM < CJ H hH 8 H X A X X X o CJ u o o X X X CJ X o X X X X u m NO gr NO Vi Vi O O. x to o o o o < CJ X X CJ o < < < CJ c CJ < < <J < 04 CM CM CM NO < X CO CJ 3 oO o 3 X i-H XE X8 3X X CJ a CJ 8 X<<XX X X X p-4 Ph < < < CM 1 t o o o o --4 --4 _H --4 -T -S' LO L0 CO eg NO oo >4 --4 fH --4 o o o CM X H A 3 Oh O 3 F--1 3 << < < oo --I b F-H xM -H F-4 03 NO Nf> CO CO -4 FH f-4 o as 3 CJ 8 * X 3 > X 3 o CM <T o o CM CM CM CM CM *T -c *cr cz < CO 3 3 < 3 t--1 X > CM <r A 00 co --H A CO <X 4H X 3 01 X X in xX pH fH F-4 fH -- 1 CJ CJ o o o o CJ CJ CJ XXX XX XX w X u 44 T3 3 X 3 CO a o X X X X X X X X X X X X X X X X X X X X z z z z z z z z Z c6-< z a. ^ c< CJ vs < 3 A 3 CV X O CO i c o o c o o o o o o o o CD o o o o o a o o cooo c o 01 44 3 CO z X o 00 X < CJ CJ Cb Ex Cb Cb Cb Cb Cb Cb Cb Cb 3X 3 Ph c OS G X X i ; X X X X 3d X 04 X US X c Z C < < < < < < < <3 Cb X Cb X Cb l-H Cb X Cb X Cb% Cb X Cb X fb X Cb X Cb X Cb X Cb X Cb X Cb X Cb X Cb X <<<< << <<<< < << <<< X X < Cb X<2 Oh X PLANT AND HAZARDOUS MATERIAL LAKE CHARLES CHEMICAL (cont.) PRODUCT YES NO ALFONIC I2L6-25 Ethoxylate ALFONIC 1216-30 Ethoxylate ALFONIC 1214GC-30 Ethoxylate ALFONIC 1214HA-30 Ethoxylate ALFONIC 1214GC-40 Ethoxylate ALFONIC 1412-40 Ethoxylate ALFONIC 1412-60 Ethoxylate NOVEL 1412-70 Ethoxylate C1012 Normal Paraffins C1216 Normal Paraffins C1016 Normal Paraffins LAKE CHARLES VCM X X X X X X X X X X X Ethylene Dichloride* Heavy Ends EDC/VCM* Vinyl Chloride Light Ends* Vinyl Chloride Monomer* Muriatic Acid X X X X X PONCA CITY Alcohol Sulfates Alkylbenzene Sodium Sulfates Alkylbenzene Sulfonic Acids Dialkylbenzene Sodium Sulfates Diphenylalkane Sodium Sulfates Alcohol Ether Sulfates Alcohol Ethoxylates Alcohol Ethoxylates LPA-140 LPA-180 LPA-190 LPA-210 < < < o o oQ * -si * sO 'Q X X X X X X X X X X X X LABEL AVAILABLE? BULK SAMPLE DRUM XX XX XX XX XX XXX XX X XX XX XX XX X X X X X X X X X X X X HAZARD(S) Irritant Irritant Irritant Irritant Irritant Contact Irritant Irritant Irritant CombustibleIrritant Contact Irritant Combustible,Irritant Flammbale, Irritant* Animal Carcinogen Combustible,Irritant Flammable,Irritant Flammable* Human Carcinogen Corrosive Contact Irritant Irritant Corrosive Irritant Irritant Irritant Irritant Contact Irritant Combustible,Irritant Combustible,Irritant Combustible,Irritant Irritant * Railcars containing these materials are in dedicated fleets and may hav permanently affixed vinyl stickers on the inside of the rail car dome lid. OSHA DEFINED HAZARDOUS MATERIALS PLANT AND HAZARDOUS MATERIAL ABERDEEN None BALTIMORE Aqueous Aluminum Chloride Anhydrous Aluminum Chloride Muriatic Acid Spent Caustic Spent Sulfuric Acid HAMMOND SA-597 Sulfonic Acid SA-697 Sulfonic Acid C-550 Slurry C-560 Slurry C-640 Slurry VMC-100 ALFONIC 1412-A Ether Sulfate ALFONIC 1412-S Ether Sulfate LAKE CHARLES LAB C1011 Normal Paraffins Cl 113 Normal Paraffins C1416 Normal Paraffins C1214 Normal Paraffins Cl216 Normal Paraffins Benzene < < o o o o -J ui o o PRODUCT YES NO x x x x x x x x x x x x x X X X X X X LABEL AVAILABLE? BULK SAMPLE DRUM HAZARD(S) --- -- xX X XX x X Corrosive Corrosive Corrosive Corrosive Corrosive XX XX XX XX XX XX XX X XXX Corrosive Corrosive Irritant Irritant Combustible,Irritant Irritant Combustible,Irritant Combustible,Irritant XX XX XX X X X ' Combustible,Irritant Combustible,Irritant Irritant Irritant Irritant Flammable, Irritant, Human Carcinogen WV 000017501 UCV^CL <1,3 BUTADIENE> DANGER! EXTREMELY FLAMMABLE tinenruL if indued. has caused cakcer iu lab Animus, overexposure hay CREATE CAhCER RISK. KEEP AUAY FROM MEAT# SPARKS ADD FLAHE. AVOID BtEflTHItiG UAPQRS. USE UITH ADEQUATE UEhTILATIOh. CHEMTREC 1-800-424-9308 OR UISIA 1-318-494-5142 <1,3 BUTADIENE > DANGER! EXTREMELY FLAMMABLE HARMFUL IF IhHALED. HAS CAUSED CAhCER Ih LAB fthIHALS. OVEREXPOSURE KAY CREATE CAhCER RISK. KEEP AUAY FROM MEAT, SPARKS MiD FLAUE. AVOID BREATHIhG UAPORS. USE UITH ADEQUATE UEhTILATIOh. FOR EMERGENCY ASSISTANCE; CALL CHEMTREC 1-800-424-9388 OR VISTA 1-318-494-5142