Document nJX2QLzgK55jVMNZMdaa7xBa
Vista Chemical Company
15990 N. barker's Lancing Rd. Post Office Bex 19029
HoustQDjpus 77224^7
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November 22, 1985
Mr. Ron Bland Huges Drilling Fluids 10777 Northwest Freeway Houston, XX 77092
Dear Ron:
This letter is to confirm our discussion regarding the labeling of
Vista*s ODC Drilling
Oil and our hazard determination.
You are aware of the jDSHA^CarcInogenic warning labeling requiremi
which applies to materials which have^ heen 'Vvaluated";under vaj
testing conditions and .shown;^lgnlficant-positive.results or for
those which have not been tested
contain greates^Q^lj!
or volume of a known' carcinogen. ^l^owi^cagc^Qeem^^are^1 def:
chose chemicals listed by the" National Toxicoloi
International Agency for Research on Cancer
Croups I and lI,
and those which OSHA regulates as a Carcinogen'. In some cases
evaluation of IARC listed categories is required to determine
specific chemicals.
Vista ODC contains no OSHA defined carcinogens, for purposes of the Hazard Communication Standard, at levels greater than 0.12.
As for the broad categories of "mineral oils", petroleum oils, or ocher generic classifications of oils which have been, indicated to have a carcinogenic potential by various studies we believe the following to be true in respect to Vista ODC. IARC Monograph, Volume 33 (portions attached) classifies petroleum derived oils
based on the increasing severity of processing or refinement.
This monograph deals with oils that are predominately lubricant base
oils with initial boiling points exceeding 750F and carbon number
distributions of 15 or greater. Vista*s ODC has an I3P of 370 F and
has a
carbon number distribution.
Of chose oils discussed in the monograph Vista ODC is closest to the white oil (class 5) classification, for which the only evidence for carcinogenicity is of questionable significance to human exposures.
Sincerely,
Thomas G. Grumbles, CXH Environmental Quality Manager
ajo/8 Attachment cc Dan Plummer, John Nelson, Pat Quinlan
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