Document mJdJZ6kZBr7ER9pNKRkB5J1B

c W. C. Becker J. L. Nelson E, W. Harrington A. Vittone, Jr* Plant Managers (12) T. H. Smith October 9, 1974 VC1 - LABELING The October 4, 1974 VCM regulation by OSHA states: (1) Signs and labels (1) Areas Entrances to regulated areas shall be posted with legible signs bearing the legend CANCER SUSPECT AGENT AREA AUTHORIZED PERSONNEL ONLY Further, (2) Areas containing hazardous operations, or \rtiere an emergency currently exists, shall be posted with legible signs bearing the legend CANCER-SUSPECT AGENT IN THIS AREA PROTECTIVE EQUIPMENT REQUIRED AUTHORIZED PERSONNEL ONLY Although the October 4, 1974 OSHA Regulation did not address itself to the details of this subject for vinyl chloride, it is reconmended that the wording used in the regulations issued early in 1973 on the "14 carcinogens" be followed in the case of vinyl chloride regulated areas. This states that letters on such signs be at least 2" high* 20226001 BFG02476 Labeling VC1 and PVC Containers The specified wordings in the VCM regulation of October 4, 1974 are: (3) Containers of polyvinyl chloride resin waste from reactors or other waste contaminated with vinyl chloride should be legibly labled CONTAMINATED WITH VINYL CHLORIDE CANCER-SUSPECT AGENT (4) Containers of polyvinyl chloride shall be legibly labeled POLYVINYL CHLORIDE (or trade name) CONTAINS VINYL CHLORIDE VINYL CHLORIDE IS A CANCER-SUSPECT AGENT Again, there are no details as to location and size, but the regulations on other carcinogens generally include the language (a) under or beside the primary label (b) lettering to be not less than 1/2 the size of the primary label, but not less than 8 point type nor more than 1 inch height The Transportation and Warehousing Department is in the process of redesigning our "universal11 Geon vinyl bags, Gaylords and latex drums, and these will be placed on order in due course, so that you may begin using them for production starting January 1, 1975 for all Geon vinyl products* They will also provide labels which can be attached to shipping containers not so imprinted (off grade, scrap, etc.) Our Corporate Legal Counsel has also suggested other additions to our labels, product literature and sales documents, to increase the level of customer notifi cation and provide some guidance as to what should be done, e.g. NOTICE OPEN, HANDLE AND USE UNDER WELL VENTILATED CONDITIONS. FOR DETAILS REFER TO OCCUPATIONAL SAFETY AND HEALTH STANDARDS CHAPTER XVII Part 9QWT /<?/0 OF THE DEPT. OF LABOR, U.S. GOV'T DATED OCT. 4, 1974 A letter will be sent to you and our customer list summarizing these changes in package labeling and business materials. Special consideration of the appropriate labeling of hopper cars and trucks is in progress. Special stickers or placards will be required. Tom Smith will see that you are provided with appropriate material before January 1, 1975. 20226002 BFG02477 Finally, the labeling of vinyl chloride tank cars has been prescribed: (i) VINYL CHLORIDE EXTREMELY FLAMMABLE GAS UNDER PRESSURE CANCER- SUSPECT AGENT or, (ii) in accordance with CFR Part 173, Subpart II, with the additional legends CANCER-SUSPECT AGENT applied near the label or placard Our Transportation Department will have appropriate labels and recommendations in the hands of Calvert City before January 1, 1975 In accordance OSHA and ICC regulations /ksc 10/9/14 P. J. Weaver B. M. G. Zwicker 20226003 BFG02478