Document xzNmY3zoNd1dqdkZ4pay0V0n6

Labels and Precautionary Information Committee STATLER HOTEL -- WASHINGTON, D. C. -- XTOBER 13-Hi, 19$3 The meeting was called to order at 10:00 A. M. on October 13, 1953- iffMBERS PRESENT: B. D- Minteer (Chairman)------------------ --- ------T- R Aalto---------------------------------------------------------A> Q* Butler---------------------------------------- -------------A- G. Cranch, M. D.--------------------------------- ---------J< W. Foulger, M. D.--------------- ------------------------J. T. Fuess--------- ---------- ----------------------------------S. J* Hill---------------------------------------------------------fl. A. Knapp---------------------------------------------------------- F. S. Low- ---------------------------------------- ---------- ------- If. J Quinn--------------------------------- -----------------------,, ^ 1. W. Sunderland--------------------------------- -------------- J. s Walker ------------------------------------------------------3. A. Walker - ------------------ ----------------- - ------W. W. Yeager (for G. E. Brewer)------------ ---------U. F. Crass, Jr. (Lunch Only-October lU) ----3. H. Mayhood (Lunch and FM Only-October lit) J. D. Kittelton (Secretary)------------------- ---------- -----Monsanto Chemical Company -----Heyden Chemical Corporation - -Mallinckrodt Chemical Works -----Union Carbide and Carbon Corporation -----E. I. du Pont de Nemours and Company, Inc. ---- Distillation Products Industries - -E. I. du Pont de Nemours and Company, Inc. - -Allied Chemical and Dye Corporation General Chemical Division -----Food Machinery and Chemical Corporation Westvaco Chemical Division -----Merck and Company, Inc. - -The Dow Chemical Company -----Hooker Electrochemical Company -----Pennsylvania Salt Manufacturing Company -----Shell Chemical Corporation --Manufacturing Chemists' Association, Inc. - -Manufacturing Chemists' Association, Inc. --Manufacturing Chemists' Association, Inc. GUESTS: J. E. Flanagan, Jr. (October 13, Only)--------------- -U. S. Public Health Service T. W. Nale, M. D.- ------------------ ---------- ------- ---------- -Union Carbide and Carbon Corporation F. D. Sparre------------------- ---------------------------------------------- E. I. du Pont de Nemours and Company, Inc. W. A. Stewart------------------- -----------------------------------------Monsanto Chemical Company Ralphel Troup----------------------------------------------------------------- J.T. Baker Chemical Company J. B. Tuttle - -------------------------------- --- ------------------------ Esso Standard Oil Company ABSENT: i ----- f J. B. Williamson---------------------------------------------------------------------- American Cyanamid Compary I 1. MINUTES It was moved, seconded and adopted that the minutes of the meeting of June 18, *953 be approved. i REGULATIONS 2.0 International i j j L-55 2.0.1 I. L. 0. Dr. Cranch reported that the members of the Committee had been sent a copy of the minutes of his subcommittee meeting and a copy of the state ment which the subcommittee drafted. Dr. Cranch briefly reviewed the meet ing of the subcommittee. In discussing international labeling, it was brought out that the ILO had prepared a survey of international labeling regulations and that an attempt should be made to secure this for the Committee. The Secretary of the Committee will pursue this further. Mr. Flanagan read letters which had been sent by Dr. Mancuso, as Chairman of the ACGIH Committee on Standard Labeling Procedures, and also a letter prepared by the Public Health Service Chemical Products Labeling Committee, concerning the ILO labeling proposal. Ur. Flanagan indicated that he did not believe that there was any real conflict between the statement prepared by the LAPI subcommittee and the statement sub mitted by Dr. Mancuso and the Public Health Service Committee. There was considerable discussion regarding the individuals to whom copies of the statement on ILO labeling should be sent. The Committee indicated that Ur. Crass should use his discretion regarding distribution of the statement. The Committee in discussing the first paragraph of the statement decided that it would be best to have the phrase "if properly developed111 at the end of the first sentence rather than at the beginning of the second. There was considerable discussion as to whether the statement should be limited to transporation or should also include "handling and use". It was agreed by a show of hands that the phrase in the first paragraph "trans portation, handling and use" would be retained, but that Ur. Fuess would draft a sentence stating that the Committee believes that for the present, the study should be limited to the use of symbols for transportation purposes. Mr. Fuess drafted this sentence and it reads as follows: "Because of the many problems involved in such a complex program, some of which are indicated above, and the time re quired to resolve them, it is suggested that the study be limited for the present to the use of symbols for transportation purposes and that the study of this phase be made in cooperation with various other agencies which are now working on such a program." The Committee went on to discuss the wording of Item 1 and It was moved, seconded and adopted THAT, the following sentence be added as the first sentence of Item 1: 1. "Such a program of international symbols will be successful only after development of a complete, accepted international pro gram of labeling which may be translated into symbols." It was moved, seconded and adopted THAT, the second point of the ILO subcommittee draft be approved. L-56 It was moved, seconded, and adopted THAT, Point 3 be approved with the deletion of the last sentence. The vote on this motion was 9-3* After discussing Point U of the subcommittee's report, It was moved, seconded, and adopted THAT, Point li be approved. The vote on this motion was 7-6. It was moved, seconded and adopted THAT, Point 5, as prepared by the subcommittee be approved. The vote on this motion was 9-3* It was moved, seconded, and adopted THAT, Point 6 be accepted after amendment in the following manner: 6. "Consideration should be given to the development of symbols for other hazards, as in the case of oxidizing materials, because they require protective measures different from those required for flammable or explosive materials." After some discussion, Mr. Knapp and Dr. Foulger were asked to rearrange the points in the draft, so that they would be in better form for translation purposes. This was done. The Secretary of the Committee had the agreed changes made and distributed copies of the amended state ment to the members of the Committee. 2.0.2 I.A.G.L.O The Chairman briefly reviewed the developments which had taken place. Mr. Hill stated that a meeting had been talked about for the first of October with the IAGL0 officials, but that this had not developed. There was a discussion regarding the need for a Model Act and it was pointed out that a draft of a Model Act had been submitted to the IAGL0 and that this draft follows closely the draft of the New York labeling regulations. A draft of this Act has been sent to the members of the Committee by Bill Quinn. It was pointed out that the Committee is not primarily interested in seeing that states adopt a model act, as such, but is interested in seeing that states use LAPI principles and that they per mit the use of labels which the LAPI Committee has developed. i Mr. Tuttle read a letter which his company had received from i New Jersey officials asking his company's opinion whether labeling regu / lations should be handled by the Public Health Department or otherwise. There was considerable discussion in the Committee regarding whether the State Public Health Services or the State labor Departments were better equipped to handle a labeling program. It was pointed out, however, that the LAPI Committee could not go on record as favoring either the State Public Health Services or the State Labor Departments. 2.2 STATE REGULATIONS 2.2.5 Massachusetts Mr. Sanford Hill briefly reviewed the developments in re gard to Massachusetts, stating that Dr. Hervey Elkins had talked to L-57 him and that Dr. Elkins was gradually coming around to accept our point of view. Mr. Hill said that he thought that it would be desirable for the Secretary of the Association, Mr. Crass, to arrange a meeting with Dr. Elkins and Commissioner Johnson. It was thought that our immediate objective should be to obtain a revision of the Massachusetts labels on Carbon Tetrachloride and Benzol. 2.2.8 New York The latest draft of the New York State Labeling Regulations was gone over, point by point, with a view to making necessary corrections which would satisfy the New York lawyer's objections. In doing this, the Committee consulted the suggestions which were made by Mr. George Scriba and the suggestions of the CSMA Committee on Precautionary Labeling. The Chairman stated that he would supply each member of the Committee with a corrected copy of the New York regulation contain ing the changes agreed to by the Committee. In going over the definitions, the Committee indicated that the standing Committee on Revision of Manual L-l should consider all definitions for the next revision. Regulation 1 The Committee agreed to amend the definition for "corrosive1' by deleting the term "physiological" which follows the definition and by putting parantheses around the second sentence in the definition. The Committee also agreed to delete "physiological" from the definition of "irritant". In discussing the definition in the regulations for "dust", It was moved, seconded, and adopted THAT, The Committee follow Mr. Scriba's suggestions for join ing the two sentences of the definitions so that the definitia reads as follows: (i) "Dust" - Solid particles generated by handling, crushing, grinding, rapid impact, detonation and decrepitation of organic or inorganic materials such as rock, ore, metal, coal, wood, grain, etc., not tending to flocculate except under ! electrostatic forces and not diffusing in air, but settling under the influence of gravity. , In discussing the definitions for "fume", "gas", and "vapor", 1 It was moved, seconded, and adopted ; i I L-58 THAT, the sentence "A fume flocculates" be deleted from the definition of "fume", that the sentence "A gas diffuses" be deleted from the definition of "gas", and that the sentence "A vapor diffuses" to be deleted from the definition of "vapor". Regulations 2 and 3 After discussion by the Committee, It was moved, seconded and adopted THAT, the word "significant" be eliminated from Regulation 2, from the heading of Regulation 3-A, and from Regulation 3-A itself. After discussion by the Committee It was moved, seconded, and adopted THAT, Regulation 3-B be revised to accord with the recommen dations of the CSMA Committee on Precautionary Labeling with the exception that the word "should" is to be changed to "shall". In accordance with the above motion. Regulation 3-B now reads as follows! "Subject matter to appear where applicable on containers of substances intended for use in hemes or on farms or for other small scale consumer uses, when size of container makes it impractical to include all subject matter required i in Regulation 3-A. The following matter shall appear where applicable, on containers of substances intended for use in homes or on m farms or for other small scale consumer uses, when the size t of the container makes it impractical to include all of the subject matter required in Regulation 3-A. t Regulation $ ir After discussion by the Committee, ! It was moved, seconded and adopted THAT, the CSMA recommendations for the second paragraph of Regulation 3 be adopted with the exception that the word "since" be omitted and the word "and" be inserted between "fully investigated" and "its handling". The Committee later decided that there should also be a phrase indicating that the practical equivalent will be acceptable. In line with this, the Committee decided to put in the phrase "or its practical equivalent" after the phrase "by the following supplementary statement". The second paragraph of Regulation 5 now reads as follows: Products in the experimental stage of development shall bear a label advising the user of the precautions to take against ary known hazards and shall warn him that other hazards may exist, by the following supplementary statement, or its practical equivalent: "IMPORTANT! The properties of this product have not been fully investigated and its handling or use may be hazardous. Exercise due care." The Committee also agreed to designate the first paragraph as (a') and the second paragraph as (b). Regulation 6 It was moved, seconded and adopted THAT, the wording of Mr. Barker and the CSMA in regard to Regulation 6 be accepted, and is as follows: Regulation 6 Practical Equivalents "Use of language on labels such as is suggested in the follow ing table or which is the practical equivalent of this wording shall constitute compliance with these regulations, except that no words shall be regarded as the practical equivalent of the words 'Poison' or 'Poisonous'." 2.2.15 Pennsylvania It was stated that Pennsylvania is willing to work with the LAPI Committee on development of a labeling law, but that the legislature is now out of session and will be for two years. 2.3 CITY REGULATIONS 2.3.2 Buffalo Mr. Fuess briefly described the proposed Buffalo Flammable Liquids Ordinance and stated that he and Mr. Walker had attended a number of meetings with Buffalo officials. Mr. Fuess said that a special subcommittee had been set up to consider the objections of the Chemical Industry to the Proposed Flammable Liquids Ordin ance and that a meeting had been held at which certain changes were agreed to by those attending. Mr. Fuess pointed out that the labeling section of the Ordin ance as originally drafted was especially bad, but that the secti# L-60 has now been revised to follow the NFFA labeling recommendations which are in substantial agreement with LAPI principles. Mr. Fuess stated that as a result of the subcommittee's meeting, a-number of other changes had been made in the Proposed Ordinance to enable the Chemical Industry to more easily comply with the Ordinance. The Chairman thanked Mr. Fuess and Mr. Walker on behalf of the Committee on the excellent job they did in handling this matter. 3- LABELS - SAFETY-DATA SHEETS 3.6.1 Benzene The subcommittee which had been appointed to consider lihe label for this chemical recommended that the label be left unchanged. It was moved, seconded and adopted THAT, the subcommittee report be approved. At this point in the meeting there was a brief discussion regarding the California labeling situation. It was believed that California will follow the LAPI labels entirely in their new revision wnich will be issued in January of 195k It was believed that this would also be true for the label for Benzene, although at the present time, the California label contains the word "Poison" and the skull and crossbones. The Committee recommended that the Association keep the members of the Committee informed regarding industrial chemicals which go into the NF and into the USP. 1 3.6.U Naphthalene After discussion. It was moved, seconded and adopted 1 THAT, the LAPI Committee recommend that a Safety-Data sheet on Naphthalene be omitted and that the Safety Committee be informed that the LAPI Committee will take no action regarding a label for this chemical. i 3.6.5 Pyridine l It was moved, seconded and adopted THAT, the Pyridine label as it now appears in Manual L-l be approved for the forthcoming Safety-Data Sheet. 3.38 Malathion The Chairman reported that he had"received a letter from Mr. Williamson requesting that the subject of a label for Malathion be removed'from the agenda pending the gathering of additional data on this chemical. L-61 It was moved, seconded and adopted THAT, Malathion be removed from the agenda. j 3.1*5 Perchloric Acid It was moved, seconded and adopted THAT, the label as it now appear in Manual L-l be approved for the forthcoming Safety-Data Sheet. 3.1*8 Arsenic Trioxide Dr. Cranch reported that the subcommittee* which had been appoint had drafted a label. This label was discussed by the Committee and j; was felt that it would be desirable to omit the antidote from the lab It was moved, seconded and adopted THAT, the subcommittee's label be approved with the exception that the antidote section be deleted. The vote on this motion was 9-3* The label as approved reads as follows: ARSENIC TRIOXIDE nANGERi MAY BE FATAL IF SWALLOWED I Avoid breathing dust or spray mist. Avoid contact with skin, eyes and clothing. Wash thoroughly after handling. gg POISON 3.1*9 Cyclopropane It was moved, seconded and adopted THAT, because the medical section has not been prepared for this chemical, and because this is not an industrial chemical, the LAPI Committee is referring the subject of a label for this chem ical back to the Safety Committee and will take no action regard ing a label for Cyclopropane. 3.50 Methylamines A subcommittee consisting of F. D. Sparre and Dr. A. G. Cranch was appointed to draft a label for Methylamines. 3.51 Sodium Fluoride It was moved, seconded and adopted THAT, the label as it now appears in Manual L-l be approved as label to appear in the forthcoming Safety-Data Sheet. L-62 3.5 Sodium Chlorate A subcommittee headed by Nicholas U. Walker was appointed to draft a label for this chemical. Mr* Walker will appoint other members to the subcommittee. 19. FEDERAL SPECIFICATION LABELING Tricresyl Phosphate The Chairman reported that he has had correspondence with the National Bureau of Standards in regard to a proper label for Tricresyl Phosphate. The Chairman stated that apparently what the National Bureau of Standards desired was a recommendation by the LAPI Committee that the term "poison" is not needed on the label. Mr. Minteer went on to further describe the results which had been obtained by Monsanto's Consulting Laboratories. He, however, felt that these tests were inadequate and that the members of the Committee would not be able to definitely recommend a label until additional tests have been run. The Chairman stated that after additional data is available he will take care of this matter by letter ballot. Mr. Minteer believed that the Committee should take a stand that ''poison" . is not necessary if the data warrants such a conclusion. MISCELLANEOUS ITEMS A. COMMENTS ON THE BRITISH REPORT AND MANUAL The Chairman announced that the British representatives of the Association of British Manufacturers who visited this country have pre pared a report of their visit and that this report will be distributed to the members of the Committee. The new British manual "Marking Containers" was briefly discussed by the Committee. The Secretary of the Committee was instructed to write the British representatives congratulating them on the fine job they did in preparing the manual. The Committee also suggested that consideration be given in the future to the appointment of a subcommittee from the U. C. A. LAPI Committee to go over to Britain and to talk over ways of coordinating the labeling programs of both countries. B. TANK CAR LABELING Mr. Charles Mayhood, attending the meeting at the invitation of the Chairman, Mr. Minteer, briefly reviewed for the members the minutes of the Technical Committees wnich have already discussed the subject of tank car labeling. Mr. Mayhood discussed this subject as it relates to regulated and unregulated articles, and read the conclusion of the Legal Advisory Committee, stressing that this conclusion related only to regulated pro ducts . The Legal Advisory Committee in 1950 reached the following con clusion t Precautionary Labeling of Tank Cars "It was the unanimous opinion of the Committee that although some manufacturers have seen fit to put precautionary labeling on tank cars.