USE OF BENZENE IN SDA PRODUCTS
Proprietors of Distilled Spirits Plants,
Users of Specially Denatured Alcohol,
Reprocessors of Specially Denatured Alcohol
Articles, and Others Concerned:
Purpose. This circular is issued to inform industry
members that the Occupational Safety and Health Admin-
istration, Department of Labor, has established a perma-
nent standard for protection of workers exposed to benzene.
The standard limits employee exposure to one part benzene
per million parts of air as an 8-hour time-weighted, average
concentration, with a ceiling level of 5 PPM for any 15-minute
period during the 8-hour day. However, the standard has
been challenged in the U. S. Court of Appeals for the Fifth
Circuit. An injunction has been granted against enforcement
of the new standard pending appeal.
Effect. If the standard is upheld, the immediate practical
effect may force many users of benzene denatured alcohol to
shift to formulas produced with other authorized denaturants,
and other users of benzene, such as producers of anhydrous
alcohol, to use other compounds or processes.
SDA formulas. Benzene is an authorized denaturant for
production of SDA formulas 2-B, 27 CFR 212.17; 2-C, 27
CFR 212.18; and 12-A, 27 CFR 212.23. However, in lieu of
benzene, sections 212.17 and 212.18 authorize the use of 1/2
gallon of rubber hydrocarbon solvent; and Revenue Ruling
72-145, 1972-1 C. B. 418 (Internal Revenue), authorizes the
use of toluene in formulas 2-B and 12-A in the same
amounts specified for benzene; i.e., 1/2 gallon in 2-B and 5
gallons in 12-A.
Compliance. Manufacturers holding approved ATF
forms 1479-A for formulas 2-B, 2-C, and 12-A may con-
tinue to use these formulas produced with the above alternate denaturants without having to file new ATF forms 1479-A.
However, the manufacturers must, by letter, notify their
respective regional regulatory administrators of the new
formulations which will be used. Distillers of anhydrous
alcohol intending to use other compounds or processes in
lieu of benzene should file ATF form 2607 to amend the state-
ment of process where necessary.
Inquiries and Request for Comments. Inquiries con-
cerning this circular or comments regarding proposals
for other possible substitutes for benzene should be
addressed to the Assistant Director, Technical and
Scientific Services, 1200 Pennsylvania Avenue, NW.,
Washington, DC 20226.