CHEMICAL AND ENGINEERING WALTER J. MURPHY, Editor
"WarningLabels99—A
Noteuporthy
A H E revised Manufacturing Chemists' Association manual "Warning Labels," soon to be released, will appear in a completely new format, its contents broadened in scope by the addition of new information, its original material screened through the critical sieve of experience and technical analysis. The result—after more than a year of intensive preparation—is an achievement that crowns five years' work by the MCA Labels and Precautionary Information Committee, whose members, drawn from the staffs of a wide segment of member companies, have contributed their diverse knowledge and experience, and a considerable amount of their time, to this accomplishment. It also reflects the evolution of association activity in this field for more than a decade. A significantly major addition to the brochure is the section containing principles and illustrative labels (58 in number) for economic poisons. The development of this section entailed discussion and consultation with other industry groups, and primarily with the Insecticide Division of the Department of Agriculture, which is the administrative agency for the Federal Insecticide, Fungicide, and Rodenticide Act of 1947. The economic poisons section of "Warning Labels," is particularly opportune in view of the recently announced hearings to be conducted by the Food and Drug Administration beginning in January of next year to determine if it is necessary to regulate, by limitation, permissible amounts of insecticidal residues remaining on agricultural products when marketed. Notice of the FDA hearing also suggests that the inquiry will attempt to develop evidence as to the possibility t h a t toxic substances are absorbed by the product itself—an attempt which appears to be a reflection of the charge made earlier this year with respect to D D T residues in milk. Although the end result of the Food and Drug Administration's investigation will be directed to farmers and other growers, the agency's determination must of necessity rest on reliable information. The latest revision of the MCA manual on "Warning Labels" and especially the section on economic poisons, should furnish a focal point for all interested parties, since it provides very comprehensive and reliable data on the subject. California was the first state to promulgate detailed labels, based on MCA recommendations, in its regulation of hazardous chemicals; Oregon and Hawaii designate "Warning Labels" as the standard which will meet their chemical labeling requirements. I t is our understanding that other states currently are studying the actions taken by California, Oregon, and Hawaii. The program is gaining increased recognition and it is generally expected t h a t this pattern will be adopted ultimately on a nationwide basis. Uniformity in state laws would simplify matters for manufacturers who generally distribute and sell nationally. Multiplicity of diverse regulations can only lead to confusion and will defeat the primary purpose, namely, safety to the user.
Contribution
to
Safety
Rounding out other phases of the MCA's technical work, under way for almost a half century, notably in the development of safe containers, the association's program in labeling provides a sane and reasonable groundwork for the formulation of safeguards, uniformly patterned, adequate to the states concerned, and with least disruption to normal channels of interstate trade. The association's labeling activities go back to the middle thirties at which time a booklet entitled "Adequate Labeling" was prepared summarizing the chemical manufacturer's responsibility as interpreted by the courts for the care and safety of those using and handling his products. I n 1936, container labels for specific products, such as nitric and sulfuric acids and ammonia, were available. In 1934, the association cooperated with the U. S. Public Health Service and producers for the labeling of benzol, carbon tetrachloride, aniline, methanol, carbon disulfide, and certain chlorinated hydrocarbons. Noting the trend which state legislation was taking, the association in 1944 set u p the Labels and Precautionary Information Committee. The first edition of "Warning Labels" was issued in 1945. The manual found ready acceptance because it was the only publication in existence which outlined a definite system for the design of a precautionary label based upon the physical characteristics and hazards of particular products. The latest edition is intended as a guide for the preparation of warning labels for hazardous chemicals, and is divided into three parts: (1) general principles involved in the design and preparation of warning labels for hazardous chemicals; (2) ISO illustrative warning labels for industrial chemicals; (3) 58 illustrative warning labels for economic poisons. Included are principles for labeling small commercial packages and products intended for investigational use; container handling and storage instruction; definitions of pertinent terms, including a quantitative definition of the term "poison," related to exposure by contact, inhalation or oral intake; and a table outlining statements of hazard, precautionary measures and instructions in case of contact or exposure, based on the class of hazard encountered. Many chemicals are by nature hazardous but frequently the very properties that make them dangerous unless labeled, handled, and applied properly, make them invaluable. The chemical industry it fully cognizant of its responsibilities in this problem. The recently revised and enlarged edition of "Warning Labels" will serve a very useful purpose. Safety in the handling and use of hazardous chemicals must be achieved through a long range educational program. Superimposing additional regulatory agencies upon those already in existence may only add further confusion to the situation. Copies of this important brochure may be obtained from the Manufacturing Chemists , Association, 246 Woodward Building, Washington 5, D . C., at SI.00 per copy. Remittances should accompany orders.
