First aid statements

What form is the exposure likely to take and what degree of severity can be expected A number of factors must be taken into consideration in order to answer these questions. The form of the product is of critical importance. Liquids are more likely to be ingested or to cause skin or eye exposures than are solids. The converse is usually true of sprays or aerosol products. Inhalation problems may occur regardless of the form of the product. The amount of volume of the product is an equally important consideration. Manufacturers tend to utilize the same first aid statements across a product line. This is an acceptable practice only if, indeed, the exposure problems and their severity do not change as the amount of available product changes. Products that are to be diluted or mixed with other components deserve special attention. 

The label writer must clearly indicate what conditions are being addressed by the first aid statements. Finally, packaging is a critically important area that is too often overlooked. Package designs that enhance the likelihood of a particular type of exposure should be avoided. If this is not possible then the first aid advice given must adequately reflect and address those types of exposures that are likely to be caused by the packaging. 

Once the nature and severity of the problems that can occur with an acute exposure to the product have been determined, the label writer is now in a position to develop appropriate first aid statements. 

Fortunately, relatively few products produce life-threatening situations following acute exposures. Such situations include  

Cardiac arrest can be defined generally as a cessation of the contractions of the heart. Such a situation is obviously life-threatening, and if it persists for more than several minutes it can cause moderate to severe brain damage or death. 

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What are the known acute toxic effects of the product based on human exposures Initially, one might say that such information usually does not exist since our society does not condone human experimentation involving products other than drugs. Conversely, it could be argued that such information could be obtained from unplanned human exposures but that these would only occur after the product had been placed on the market. Thus, the information would not be available to the label writer at the time that it was needed. While the former statement is usually true the latter is usually not. It is the unusual product that does not have several close relatives if not a twin already in the market place. Thus, such human exposure information probably exists. One source of such information is the National Poison Center Network whose resources will be described later in this chapter. Obviously, such exposure information is undeniably superior to all others since humans form the principal audience that is to be addressed by the first aid statements. Manufacturers should make every effort to obtain such information. As previously mentioned, the sole dependency on animal studies may lead to erroneous conclusions. 

If toxicity studies in animals or previous human exposure experience indicates that a product is or may be capable of producing any of these situations, that fact must be clearly stated on the label. At times such information may appear in the Warning Section of the label. Since that section may be located on another part of the label some distance from the first aid statement or that section may be obscured for a variety of reasons, it is prudent to repeat such information at the beginning of the first aid statements. 

Ingestions constitute the most common route of exposure in acute situations. In developing first aid statements to provide management information for such exposures, the label writer must first determine if the ingestion of a small amount of the product (more than 5 to 10 cc or more than 5 to 10 g) of the product will produce potentially harmful results. 

If, based upon animal studies or human experience, the judgement is made that the best way to manage an acute ingestion of a given product is to induce vomiting then in this writer s opinion the first aid statements should clearly state this and should also provide the specific recommendation that Syrup of Ipecac be used along with specific instructions for its use. The argument that... 

There appears to be consensus regarding the order in which first aid statements are presented on the product s label. As previously mentioned, those products that are capable of causing a life-threatening situation following an... 

III Harmful if swallowed (inhaled or absorbed through the skin.) Avoid contact with skin (eyes or clothing). (Appropriate first aid statement required.)... 

You should consult your employees (through safety representatives, if you have any) about the policy statement. Everyone should be able to see from the policy statement exactly who is responsible for different things, such as advice, reporting an accident, and first aid. 

Legal Controls. These include a labeling law requiring all economic poisons to be clearly labeled according to content and amount of each ingredient, with appropriate statements on first aid measures and precautions and an adequate system of inspection for the presence of poisonous residues on the surface of, or within, the foods placed on the market. It is recommended also that the states adopt legislation consistent with the federal laws. 

Dean BL, Peterson R, Garrettson LK, Picchioni AL. American Association of Poison Control Centers Policy Statement gastrointestinal dilution with water as a first aid procedure for poisoning. J Toxicol Clin Toxicol 1982 19 (5) 531-2. 

Statement of Practical Treatment (162.10(h)(l)(iii))—EPA prefers the term practical treatment to first aid and generally does not permit the use of the word antidote , since few pesticides have specific antidotes. The agency also prefers that all practical treatment statements appear on the front panel of the label, but only requires front panel placement for pesticides falling into Toxicity Category I on the basis of oral, dermal, or inhalation toxicity. With EPA s permission users may place this statement elsewhere on the label if a reference... 

However, NIOSH has provided, based primarily upon the CMA label guide, recommended label statements for health, fire, reactivity, disposal, and first aid. The NIOSH system proposes a label that includes a numeric NFPA-type... 

NOTE 3 See FHSA Regulations (16 CFR 1500.83(a)(1)] for an exemption to this requirement. NOTE 4 This information (Other Cautions) supplements the Statement of Principal Hazard(s) on the Front (or Main) Panel. It includes minor hazards and other precautionary measures. NOTE 5. This statement provides immediate First Aid measures for the victim (or the parents of the victim), and should be stated as simply as possible. It is not specific antidotal information for the Physician,... 

One or more indices describing incident performance according to various units of measurement (e.g., disabling injury frequency rate, number of lost-time accidents, disabling injury severity rate, number of first-aid cases, or dollar loss). It may also refer to a summary statement describing incident performance. 

C.2.4.7 In most cases, the precautionary statements are independent (e.g., the phrases for explosive hazards do not modify those related to certain health hazards, and products that are classified for both hazard classes shall bear appropriate precautionary statements for both). Where a chemical is classified for a number of hazards, and the precautionary statements are similar, the most stringent shall be included on the label (this will be applicable mainly to preventive measures). An order of precedence may be imposed by the chemical manufacturer, importer or responsible party in situations where phrases concern Response. Rapid action may be crucial. For example, if a chemical is carcinogenic and acutely toxic, rapid action may be crucial, and first aid measures for acute toxicity will take precedence over those for long-term effects. In addition, medical attention to delayed health effects may be required in cases of incidental exposure, even if not associated with immediate symptoms of intoxication. 

The method statement should also contain the information about the necessary emergency arrangements should an incident occur, unless they are already detailed in the health and safety plan. Details regarding any site-based personnel trained to administer first aid, and the location of the nearest hospital with accident and emergency facilities, should be included. A method for swift communication should be identified and, if there is no telephone available on site, details given on the location of a public telephone close by otherwise a mobile telephone should be provided. Thought should be given to the actions to be taken if a person were to be injured within a trench or if any gas monitors in use... 

The flaws in the FDA s systems have been twofold. First, the cosmetic secrets system has not given adequate consideration to private statements showing confidential status. Second, the central agency staff must know how many exceptions have been allowed, to whom and for what. If the procedure is unfair or if exceptions cannot be catalogued, then the agency cannot manage its workload and the submitter cannot be adequately listened to. But these problems can be worked out within the EEC structure, and chemists familiar with the EEC inventory process should aid in the letter exceptions process. 

The first step is to derive the variational statement of the problem. This can be done with the aid of the Lagrange-Euler equation... 

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