Document vV2eD5zd8gv4VpNr3KGL05JR

L-614 Manufacturing Chemists' Association, Inc. 4 MINUTES OF MEETING LABELS AND PRECAUTIONARY INFORMATION COMMITTEE May 9-10, 1967 The Homestead Hot Springs, Virginia ************** ggbers, Present Shaffer, Chairman C- B# Hasek, Vice Chairman b J* Burnette b C. w* Dernehl Dixon C. b ! * French Hammond J. J- Hogan H. McIntyre F. philpitt W. Sheldon S. Sido D. Sparre G. Troup E. Wendt G. White H. Hoover, Secretary American Cyanamid Company Diamond Alkali Company General Aniline & Film Corporation Union Carbide Corporation Celanese Corporation Mallinckrodt Chemical Works Enjay Chemical Company Allied Chemical Corporation The Dow Chemical Company Olin Mathieson Chemical Corporation M & T Chemicals Inc. Monsanto Company E. I. du Pont de Nemours & Company J. T. Baker Chemical Company American Potash & Chemical Corp. Shell Chemical Company MCA Staff Members Absent I. H. Dewey k. C. Diliberto h T. Fuess ^ b T. Gormally Commercial Solvents Corporation Stauffer Chemical Company Distillation Products Industries Pennsalt Chemicals Corporation Saeats Prasan^ 3avid Brown I Brush I * <3- MacKellar A** H. Maxwell w * C. Stevens L Mallinckrodt Chemical Works Koppers Company FMC Corporation USS Chemicals Imperial Chemical Industries Ltd. ************** L 1. Introduction of Guests The committee welcomed Messrs. Brown, Brush, MacKellar, and Maxwell to the meeting, and extended a special welcome to Mr. Charie Stevens of imperial Chemical Industries Ltd., who attended the meet/ as a representative of the Marking of Containers Committee of the ^ Chemical Industries Association Ltd. 2. Minutes of the Last Meeting The minutes of the January 17-18, 1967 meeting in Houston, Texas were approved as distributed. 3. Membership sF oi M3 9* of li ha St The committee voted unanimously tc recommend to the MCA Board of Directors that Donald G. MacKellar of PMC Corporation be appointed a member of the committee. a<i ^ er 4. Election of Officers - - Following the- recommendations of the nominating subcommittee (H. H. McIntyre - chairman, C. L. French, and F. D. Sparre), the committee unanimously elected E. J. Masek as chairman, and R. F. phifpj} as vice chairman, for the two-year term beginning June 1, 1967 subject'- to confirmation by the MCA Board of Directors. | The outgoing chairman, C. B. Shaffer, thanked the committee and especially the subcommittee chairmen for their assistance during his term. , A motion of appreciation for the outstanding leadership rendered by the chairman was carried by acclamation. ec b ti P< 7. Mi Lf th 5. Rules of Organization and Procedure The chairman announced that the subcommittee appointed following the Houston meeting for the purpose of preparing a draft of LAPI Committee Rules of Organization and Procedure had not had sufficient time to meet since its appointment, and that it therefore had nothing to report. 6. Manual Revision rac St ar si pc Di oi The committee voted unanimously to accept in principle the April 1967 draft of Part I of the next edition of the "Guide to Pre* cautionary Labeling of Hazardous Chemicals" as prepared by the Manual L-616 sion Subcommittee, with the understanding that comments on any *e^ific points be submitted in writing to the secretary for consideration ^t-he Manual Revision Subcommittee. So as to have drafts of labels for Part IX ready for consideration full committee at the September meeting, the chairman of the uai Revision Subcommittee announced that he will schedule small oup3 to meet periodically to determine the hazards from examination & the assembled data, and to mark these hazards on the computer check for each substance. Mr. Philpitt urged all committee members who list not yet sent in their data and who have been sent Warning Label liav study Sheets to do so as soon as possible. in response to a request by Mr. Sido, the chairman said he would .ja fourth precautionary statement for spill clean-up to the check list. This statement is to read "Keep upwind of leak. Evacuate etlcl<>3ed sPaces until gas has dispersed." Consideration of references on labels to specific protective ^uipment resulted in general agreement that such references should ^ nade only in special cases where the label language does not suggest die proper protective equipment to use. There was also general agreement that statements concerning dis posal of containers should not be included routinely. 7. internal Liaison a. Environmental Health Advisory Committee - The secretary read Hr. Gormally's report, which included mention of his hope that the LAPI committee will have one or more projects for submission to EHAC this fall. b. Safety and Fire Protection Committee - The chairman recomended that drafts of label texts to appear in Chemical Safety Data Sheets for Nitrobenzene, Sodium Cyanide, Caustic Soda, Methyl Bromide, and Calcium Chloride be submitted to the committee for letter ballot simultaneously, so as to have them acted upon sooner than would be possible by waiting for the next meeting of the committee. c. Inter-Committee Task Group on Transportation Hazard Information 3r* White reported that the task group has not yet proposed anything ofa specific nature other than its report of January 30, 1967. J On the subject of flash points. Dr. White illustrated graphically *Be of the points made in his recently-distributed brief supporting Jl the retention of 80 degrees P. as the dividing point for the classic cation of a flammable liquid as determined by the Tagliabue Open Cyp ' Method, Mr. Sido distributed copies of his memo outlining the disadvantages of extending the flammable liquid classification above 80 degrees F. and the advantages of establishing a "Combustible Liq^., category, Mr. McIntyre distributed copies of his Memorandum No. 2 which argues against revision of the present ICC definition, Mr. Hamurv reported that API has decided in favor of the closed cup method foj determining flash points and 100 degrees F. as the cut-off between classifications, and the secretary reported that the survey of moa member companies regarding the proposed change in classification is still in progress. 8. External Liaison pep tot gen 196 a. Chemical Industries Association Ltd. - Mr. Stevens reported ^ j the implications for the U.S. chemical industry of draft Directives Nos. 179 and 180 of the Economic and Social Committee of the European Economic Community. He also listed a number of specific points in these directives which are regarded as objectionable by the Chemical Industries Association, Ltd. ; 1 Mr. Stevens then proposed (on the instructions of the CIA Marking of Containers Committee): to inc th< of an< of 1. That MCA send a small delegation of LAPI Committee members to i Europe to assess at first hand the possible effect of the directives on the U.S; chemical industry, and to influence their development in cooperation with representatives of the CIA Marking of Containers Committee. This is to be done in a series of meetings scheduled for s June 28, 29, and 30, 1967. f Another important reason for the June visit was advanced by Mr. Stevens. This concerns eight or ten directives (in addition to those for labeling) which are yet to be prepared and which will in- j volve food additives, colors, and occupational safety among others. j The Chemical Industry Association has already formed a committee to follow them. Mr. Stevens felt that it would be most advisable for MCA representatives to make an initial contact at this time with the trade association people, the appropriate attaches, and the EEC so as j to be better able to deal effectively with succeeding directives as j they develop. i Mr. Stevens also felt that the visit would afford a valuable : opportunity for MCA representatives to exchange views on matters of flj common interest outside the sphere of the EEC, and advised that CIA | has authorized himself, Mr. Denny, and one or two others to be at the | disposal of the MCA representatives at the time of the proposed visit* I th fi wo in be Mr di cc cc re u] r Ac 2 That MCA establish contact with the U.S. diplomatic attache EEC in Brussels for the purpose of determining what might be to `"Jthrough h....i.s......o....f..f..i.ce to f-urt.h....e....r.....o...u...r.....o...b....j.e....c...t.i..v...e...s......w.....i.t..h.......r..e...s...p...e...c...t.....to J^irectives, 2. That MCA establish contact with the person attached to the ^tment of Commerce who represents the U.So abroad in the Organization Economic Cooperation and Development to accomplish the same purpose. toi Mr . Stevens advised that Directives 179 and 180 will likely be the European High Parliament for ratification around the end of nt :967 following Mr. Stevens' presentation, the committee voted unanimously recommend acceptance of the CIA invitation to send a small delegation, Eluding a representative of the MCA staff, to Europe. The chairman then referred to the Subcommittee on the EEC Directives $e proposals regarding contacts with attaches, as well as the suggestion 0f the international Trade Committee regarding contact with GATT. b.- Chemical Specialties Manufacturers Association - Messrs. Hogan ^ gparre reported briefly on CSMA activities, but there was nothing of particular concern to MCA as such. c. National Fire Protection Association - Mr. McIntyre reported that NFPA has a group working on fumigation standards for adoption in fire codes, and that he plans to oppose that part of the standard which nould require use of the 704M symbol. d. American Petroleum Institute - Mr. Hammond reported no changes in Bulletin 2511, and that API Toxigrams on gasoline and kerosene have ieen published. e. Inter-Industry Advisory Committee on Product Information hr. Hogan reported that the committee (which met April 25) is evenly divided on the proposed change in flash point classification, and that moments requested from the various associations represented on the :onmittee relative to the EEC Directives have not so far been received. f. Association of American Pesticide Control Officials - Mr. Sparre reported briefly on AAPCO activities, but there was nothing of particJlar concern to MCA. g. industry Committee on Weights and Measures - Mr. Sparre ^Ported that positions with respect to the Pair Packaging and Labeling regulations are being taken, and that these will be sent to the FDA. 9. Other Items a. Labeling for Carcinogenic chemicals - The chairman referred a letter to MCA from Northeastern Products Company which included a suggestion that "some unique system of labeling should be uniformly effect, similar to the requirements for radiation hazards," and to reply by the chairman of the Occupational Health Committee, both of 8 which were brought to the attention of the LAPI Committee because of the labeling suggestion. The chairman commented that the number of chemicals known to.fcg carcinogenic are well-known and small in number. Dr. Demehl reported that his company's approach is to warn that prolonged and repeated sv contact may produce delayed and serious injury if such is indicated bv * animal tests, although there is no assurance that humans would be s0 affected. Mr. Hammond said that the API Labeling Committee faced thi8 problem, and approached it in the same way. b. National Status for LAPI Manual - As the result of a vote by the Safety Standards Board of the USA Standards Institute at its February 28, 1967 meeting to "look into the broad subject of utilizing some existing standard on the subject of labeling and to explore the problem of emergency procedures as a result of spills of these chemical^ the chairman requested Dr. Dernehl to prepare a report on this subject for the May 9-10 meeting, and requested the secretary to attend the May 5 meeting of the ad hoc committee of the Safety Standards Board which is exploring this subject and to report on it at the May 9-10 meeting. Dr. Demehl said that, in the absence of an acceptable labeling standard which has been accorded national status by one means or another, the Department of Labor may be forced to write its own regu lations, that certain "fringe" laws may already give it the necessary authority, that H.R. 1323 if passed will direct the department to cow up with regulations, and that as soon as the department sets forth regulations, or as soon as the USA Standards Institute comes up with a standard, the LAPI Manual will take second place. He said further that MCA could request USASI to initiate a stand ardization project, or that such a request might be made from within USASI,resulting in the formation of a sectional committee comprised of representatives from all interested organizations. c it a a r He felt that if the LAPI Manual were submitted to USASI as a working tool to start with it might become unrecognizable, and further that quantitative values would be emphasized regardless of whether USASI or the Department of Labor enters the picture. L-620 The secretary reported that at the May 5 meeting of the ad hoc ittee of the Safety Standards Board, R. D. Gidel (subcommittee C<^itfl>an and Director, Office of Occupational Safety, Bureau of Labor c113 .ards, U.S. Department of Labor) said that nationally recognized St3ndards will be considered by the department for regulations under st3en public laws (Maritime, Walsh-Healey, Arts and Humanities, Service csonftoraycetrs' Vocational Rehabilitation, Pair Compensation). The department Labor wants Standards, and Federal one labeling standard poprefer to in preparing regulations under all these laws. to The meeting was attended by representatives of MCA, API, NPVLA, cgat3t Guard, an insurance group, as well as the Department of Labor. The LAPI Manual, the NFPA marking system, Chem-Cards, the Coast Guard regulations, the IMCO system, the NAS report dealing with flammability and others were all brought into the discussion, so it jjecame even more evident that what was being sought was an omnibus national standard for labeling that would encompass transportation, dock handling, shipyard handling, storage within the holds of ships, etc. as well as what the LAPI Manual is intended to cover. It was suggested by the industry people at this meeting that it would probably be impractical to tackle the problem in this fashion, end that it should be done piecemeal. The thought was advanced that it might be possible to bridge the pieces later to afford some degree of unity at least. Mr. Gidel said he would send a memo summarizing the discussion to all members of the ad hoc committee and request their comments, the memo to include a suggested proposal to the Safety Standards Board for consideration at its June meeting. c. Model Regulations - Mr. McIntyre reported on his recommendation 1 of April 4 "that the LAPI Committee review and update the present i model regulations for labeling of hazardous industrial products." It I appeared to be the feeling of the committee that other committee activities demanded more priority, so no action was taken on this recommendation at the May 9-10 meeting. d. Labeling re Air Pollution Regulations - Mr. Sparre reported that the Los Angeles regulations have no provision for labeling, that the San Francisco regulations provide for labeling but do not specify the content, that it is hoped that industry will come up with stand ardized wording or a identification mark to avoid possible difficulties ^tween suppliers and purchasers with respect to products shipped into these areas, that information concerning this problem has been sent to CSMA, NPVLA, and the Inter-Industry Advisory Committee on Product ^formation, and that NPVLA Labeling Committee has formed a subcommittee to develop the wording or identifying mark which will be sent out to the other industry groups after approval by the full committee. 10. Next Meeting It was decided to hold the next meeting of the LAPI Committee in New York during the week of September 18, 1967. MMHssjg May 23, 1967 M. M. Hoover, Secretary M< S R L C R E J J J B D H c: c A G P R N N C M Gj H T C M 8