Document 0J8VKv921Lk4q1Vx21jjXmDQJ

R-TSA U.5. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION REGION V 300 SOUTH WACK6R DRIVE. ROOM 1301 CHICAGO. ILL. 60006 313 - 3S3-47I0 reived nr ca November 7 197L SOV12 74 Mr* B* R. Leach Factory Manager Uniroyal Chemical Division of Uniroyal, Inc Painesville, Ohio l|li077 Dear Mr* Leach: ^RDC* . noun TO IC0 v.r'B JMC pm f.LEASD *H VM CHK UM r ;ml : XX Your letter of inquiry of October 21*, 197L, sent to our Cleveland Office has come to us for reply* Your question concerning limitations on concentrations of vinyl chloride r exceeding five parts per million must be tied for the interpretation at this time to our OSHA sampling method used by our compliance officers* The longest sampling they are to use is never to exceed fifteen minutes* 2his does not exclude some shorter sampling periods such es ten minutes. A ten minute period of sampling which revealed the concentration as hi^i as 8 ppm of vinyl chloride would be considered to be a violation of 1910*93q(c)(2). Your other question concerns a roster of employees who enter regulated areas. Whatever method you use to develop this roster would be acceptable so long as the information alluded to in 1910*93q()(2) is readily available for inspection when a compliance officer may be in your plant. If there is any other information that may be supplied, please let us know. Very truly yours, h EDWARD J. LARCENY Associate Assistant Regional Director for Technical Support URL 02621 / UNIROYAL CHEMICAL Division of UNIROYAL, Inc. Painc&ville, Ohio 44077 *16-357-767* October 24, 1974 Mr. Kenneth Bowman, Area Director Occupational Safety and Health Administration 1240 Cast 9th Street, Room 847 Cleveland, Ohio 44199 Dear Mr. Bowman: Re: CFR Paragraph 1910.93q - Vinyl Chloride Dated 10/4/74 As v/e have studied the new vinyl chloride standard several questions as to the intent of the regulation have cone up. There are two of these on which I would like to ask your advice. 1. Section (g)(4)(1 thru v) relates the type of respirators required for certain concentrations of vinyl chloride. He cannot determine whether the concentrations referred to are celling values or values "averaged." over any period not ex ceeding fifteen minutes. It would be convenient for us to assume'that the Intent is for values averaged over a fifteen minute period but we are not certain that this is what is Intended. 2. Section (e)(2) required that a daily roster be made of author ized persons who enter "regulated areas". We propose to use employee time records, which keep an accurate accounting of job assignment and hours worked, for those people assianed * each day to a regulated area. For those who intermittently visit a regulated area a sign-in roster will be maintained. Vie would hope that it is not necessary to maintain the paper work represented by a dally roster when the majority of the names on the roster will be repeated day after day. Our long range plan Is to combine the VCM monitoring results with the employees work history and maintain a computerized record of each employees weekly and annual exposure as interpreted by the computer. Thus we would expect to comply with what we assume the intent of record keeping to be. Is such a procedure satisfactory? Any guidance which you can provide us regarding the above paragraphs would be very much appreciated as we try to prepare to comply with this regulation. URL 02622 BRL/nak Factory Manaaer Uniroyal Chemical Division of Urriroyal, Inc. U. S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION CLEVELAND AREA OFFICE - REGION V 1240 EAST 9TH STREET, ROOM 847 CLEVELAND, OHIO 44199 1 RlCEVED BY Eitt OCT 3 0 74 Mr. B. R* Leach Factory Manager TJniroyal Chemical Division of Uniroyal, Inc Fainesville, Ohio 1+1*077 ORDER ROUT TO f LEO evri'i ; htr. V<AI C1K -- Dear Mr. Leach: LFM FMRL 11 XX I received your letter of October 2i+ pertaining to a request for an in-f terpretation of Section 1910.93q on vinyl chloride of the standards pro mulgated under the provisions of the Williams-Steiger Occupational Safety and Health Act of 1970." Since your request is of a technical nature, I have referred your let ter to our Technical Support Staff, Regional Office, Chicago, Illinois, for an official interpretation. They will reply directly to you. Sincerely yours, KB/jsb KENNETH BOWMAN Area Director Occupational Safety and Health Administration URL 02623 r