CTA Report, Draft 1, ISP Review - US Chemical Safety and Hazard ...

A 1998 internal Borden Chemical memo from a staff member to the Director of Regulatory
Compliance—the person responsible for developing Borden Chemical MSDSs—recommended that
wording be added to the firefighting section of the MSDSs for phenolic resins to state that explosive
mixtures can be formed in air. The suggested changes recommended in this memo were not adopted.
Information listed in other sections of the MSDSs was inconsistent with information contained in NFPA
654 and warnings listed by other phenolic resin manufacturers. For example, in the firefighting measures
section of the Borden Chemical MSDSs, the LELs are marked as “not applicable.” Appendix A.1.5.20 of
NFPA 654 explains that the LEL is also known as the MEC. MEC values for phenolic resins have been
published by the Bureau of Mines (Section 8.1) and are reported on MSDSs by several other phenolic
resin manufacturers (Table 4). The 1998 Borden Chemical internal memo also recommended that the
actual MEC for the phenolic resins be listed if test results for these products could be located.
Other sections of the Borden Chemical phenolic resin MSDSs lacked information or listed inappropriate
measures for handling combustible dusts. There are no warnings to avoid ignition sources or to avoid
cleaning up spills using dry sweeping.
Also, Borden Chemical could have included, in its MSDSs, dust explosibility data found in safety and
health textbooks (Section 8.1) as some phenolic resin manufacturers have done.
8.2.2 HMIS Flammability Rating
The Borden Chemical Durite phenolic resin MSDSs contain a Hazardous Materials Identification System
(HMIS) rating. The National Paint and Coatings Association (NPCA) developed HMIS as a quick way of
identifying the hazards of chemicals (Appendix E). Chemicals are rated in the areas of health,
flammability, and reactivity using a numerical scale of “0” to “4,” with “4” being the most hazardous
(NPCA, 1976).
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