Document 0qaXLw2ye57n6yB2QQkXwykQV

A X" THE GENERAL TIRE & RUBBER COMPANY Corporate Safety Policy Directive Section: FIRE Effective Date: MARCH 7. 1977 Number: 002 Applicable To: ALL PLANTS Date Issued: 3-8-77 Execution Responsibility Of: PLANT MANAGER Supercedes No.: NONE Distribution: ALL PLANTS Subject: LOCKING OF FIRE SYSTEM VALVES PURPOSE To ensure that water supplies are always available to fire protection systems, General Tire shall now require that fire protection valves at all plants and facilities are locked in the open position. The only times these valves may be closed are during emergencies,systems repairs, tests, and then only as delineated under "Procedures" below. BACKGROUND Fire losses attributable to closed fire protection system valves have been increas ing in recent years. These valves have been closed, in a large number of cases, by unauthorized persons for reasons unknown. As this kind of loss has continued, all fire insurance carriers have established a policy of insisting that their policy holders lock in the open position all valves controlling water supplies to fire protection systems. PROCEDURES The following procedures shall be adhered to in administering the valve-locking policy: A. Types of Locks To Be Used Locks shall be of padlock variety (not combination locks) with case-hardened steel shackles. Locks should be capable of being cut with heavy bolt cutters, however, in case the key holder cannot be found in an unusual emergency. B. Key Holders The locks shall be keyed to the Corporate great grand master and the plant master system. All locks shall be keyed alike and only the following per sonnel shall be issued keys for these locks: 1. Plant Safety Engineer 2. Fire Safety Control man or equivalent 3. Plant Superintendent (senior man in plant during night shifts). 4. Plant Guard - key to be kept in guard house and controlled by log with spaces for time out, time in, reason for logging out, and signature of person logging it out. Only the following shall be authorized to log out this key: a. General Manager b. Engineering Manager c. Industrial Relations Manager d. Manufacturing Manager e. Maintenance Superintendent f. Maintenance Supervisor in charge of off-shift. UENC 011130 Page 2 LOCKING OF FIRE SYSTEM VALVES PROCEDURES - continued B. Key Holders - continued This locking system is of value only when an absolute minimum number of people are authorized access to the keys and positive key control is maintained. C. Valves To Be Locked Open All valves, regardless of configuration, the closing of which would cut off water flow to sprinkler heads in any area, shall be locked open. This includes, but is not limited to, sprinkler riser valves, supply valves between the riser and the main, sectional control valves, public water supply connections, and valves controlling the flow to and from the fire pumps. The following valve configurations are included: 1. Post Indicator Valves (PIV) 2. Wall Post Indicator Valves 3. Outside Screw and Yoke Valves (OS&Y) A, Post Indicator Valve Assemblies (PIVA) 5, Indicating Butterfly Valves (IBV) 6. Inside-screw Gate Valves D. Methods of Locking Valves Valves shall be locked utilizing existing loops or eye bolts, or, as in the case of OS&Y valves, a chain passed through the handwheel and yoke and secured with a lock. When it is necessary to install loops or eyes, these should be welded on rather than bolted. Curb box valve handles and other handles which are stored or hung in a location removed from the valve shall be locked into their hangers. Multiple valves should not be locked together so that unlocking of one valve for an authorized opera tion will leave an adjacent valve improperly locked. E. Initial Locking' Procedure Before a valve is locked open for the first time, a drain test shall be run on the sprinkler system controlled by the valve. A rapid rise in pressure in the riser after closing the drain valve will indicate that the supply valve is fully open. After the drain test has been run the valve must again be manually tried to make sure it is still open before being locked. F. Inspections 1. Until a valve has been locked open it must be inspected weekly with results recorded on the facility's regular fire equipment self-inspection sheet. Once valves have been locked open they must be inspected monthly, again with results recorded. GENC OU 131 Page 3 LOCKING Of FIRE SYSTEM VALVES PROCEDURES - continued F. Inspections - continued 2. Once valves have been locked the regular monthly inspection shall consist of visually checking indicator position, screw position, and handle position or location, as appropriate. In addition, the inspector shall actually physically try all valves except the PIVA, (This type cannot be closed if it indicates open). It is important to turn the handle force fully open, and then close it down a quarter turn to prevent jamming. G. Curtailment for Repairs or Testing When it is necessary to shut a valve which is normally locked open, a valve shut "2 Part" card shall be used. The first portion is filled out and displayed on the valve while it is shut. When the valve is re opened and locked, this portion should then be saved by the plant for review upon the next visiting insurance inspector. The second portion of the valve can be displayed in the office of the person responsible for plant loss prevention while the valve is shut as a reminder of a shut valve. When the valve is reopened and locked, this portion is then filled out and mailed to the Corporate Safety Office. If it becomes necessary to shut a valve for more than 8 hours or beyond the present work shift, whichever is shorter, it must be reported to the Corporate Safety Department immediately by telephone and followed with a written report. If it becomes necessary to keep the valve shut for more than 24 hours or during a plant shut-down period (such as a weekend), the Corporate Safety Office should receive prior notification by telephone. Drain tests shall be performed after the system is back in service to en sure that the closed valve(s) is again fully opened. H. Valve Closings in Emergencies or after Fires Valves may, of course, be closed during emergencies at the discretion of the safety engineer, the fire safety control man, and management such as in the case of a fire main break which would have to be isolated by the closure of sectional control valves. Valves must also be shut fol lowing extinguishment of a fire which has set off and been controlled by sprinkler heads so that the flow valves may be reset and sprinkler heads replaced. But, management must exercise caution by making sure the fire is completely extinguished before closing off the water supply. GENC 011132 Page 4 LOCKING OF FIRE SYSTEM VALVES PROCEDURES - continued I. If a situation should arise during which it appears to be necessary to deviate from these procedures, the Corporate Safety Department shall be notified immediately. J. Maintenance Routine maintenance of fiTe protection control valves such as lubrica tion, adjustments and other minor service work will not require valve closing notification or valve shut tags. However, if during the course of routine maintenance it becomes necessary to close a valve and keep it closed, then valve closing procedures as outlined in Section G should be followed. In any event, if during the course of routine maintenance a valve is closed, even momentarily, a drain test should be performed after work is completed and the valve re-locked in the open position. GENC 011133 THE GENERAL TIRE & RUBBER COMPANY Corporate Safety Policy Directive Section: FIRE Effective Date: MARCH 1, 1977 Number: 001 Applicable To: ALL PLANTS Date Issued: 3-8-77 Execution Responsibility Of: PLANT SAFETY ENGINEER Supercedes No.: NONE Distribution: ALL PLANTS_____________________________________ Subject: WELDING. BRAZING. CUTTING. OR OTHER "HOT WORK" PROCEDURES PURPOSE The purpose of this Standard Practice Bulletin is to establish general procedures to be followed at all company facilities during welding, brazing, cutting, or other "hot work" operations performed in manufacturing areas, as distinguished from permanent welding shops or booths. SCOPE This practice is intended to supplement and reinforce written procedures covering the same subject which are currently in force at some company locations, and, therefore, will not in all cases necessitate a change in local practices. Outside contractors, as well as General Tire employees, must adhere to these procedures in order to guard against fire and other hazards normally presented by welding and cutting operations. In addition, conformance with this practice will ensure Occu pational Safety and Health Act compliance. PROCEDURES Each "hot work" job must be covered by a permit, in the form of a card or eraseable plastic tag, which must be filled out before the job can start and which should re main at the site throughout the job. The permit must be signed by the immediate supervisor of the man doing the work, and by the supervisor in whose area the job is to take place. The permit should be renewed before each shift change, after an extended break in operations or as necessary due to changing conditions at the work site. The above supervisory personnel should sign the permit only after completion of the following: 1. Personal inspection of the immediate area involved. 2. A check as to training and qualifications of the welder or other employee who is to operate the equipment and the equipment is in good repair. 3. Assignment of a fire watch trained in the operation of first aid fire equipment at the scene. (Necessary for inside jobs; recom mended for all jobs.) 4. A test, through use of a combustible gas indicator, for explosive vapors which may be present in hazardous areas. 5. A check to ensure that there is no impairment of fire protection equipment. (Such as work in progress on sprinkler system in area). 6. A check to ensure adequate ventilation, using an oxygen analyzer or gas detector tubes as appropriate, in vessels or confined areas. 7. Removal of combustible materials from an area at least 35 feet from the job. GENC 011134 Page 2 WELDING, BRAZING, CUTTING, OR OTHER "HOT WORK" PROCEDURES 8. Shut-down of nearby equipment or processes which could produce flam mable vapors, liquid spills, or other conditions likely to affect the safety of the welders or other employees in the area. 9, A check to ensure that sparks produced by the operation will not be carried through ventilation ducts (floor openings, or wall open ings) to hazardous areas. 10. Placement of signs, ropes, or warning devices as necessary to pro tect other employees in the area. Supervisors should ensure that no welding or cutting is ever done on any closed container or pipeline until it has been thoroughly -cleaned and subsequently tested for flammable vapors. Fire watches should remain at the site for a half-hour after completion of the job to make sure no slow-burning fires have been ignited. Other action may be required in specific cases, but the above points should be con sidered prior to every job. The permit itself is designed so that these require ments are listed and can be checked off as completed. OSHA and other regulations specify maintenance, handling, and storage requirements for welding equipment (gas bottles, etc.) which should be adhered to on a continu ing basis and are not within the scope of this practice. GENC 011125 fl WEEKLY FIRE-PREVENTION INSPECTION c.ikpi p ONI V NO ONE BLANK CAN BE DESIGNED TO FIT ALL CONDITIONS. USE THIS BLANK AS A BASIC Cl'll't IN 01 VI l ill'INO. YOUM U L ' OWN FOFM. ITEMS THAT DO NOT APPLY CAN BE OMITTED. OTHER ITEMS CAN BE EXPANDED AS DESIRED. AND NEW ITEMS CAN BE ADDED. INSTRUCTIONS TO INSPECTOR PLANT fill OUT FORM WHILE MAKING INSPECTION. SEND COMPLETED FORM TO YOUR SUPERVISOR FOR NECESSARY ACTION REPORT SHOULD BE HELD FOR REVIEW BY THE NEXT ARM ENGINEER. LOCATION AutoMatic Sprinklers ANY HEADS DISCONNECTED OR NEEDED Yes No Q HEAT ADEQUATE TO PREVENT FREEZING (NOTE BROKEN WINDOWS, ETC.) Y No OBSTRUCTED BY HIGH PILING Water Pressure lb, at yard level Sprinkler Alarms ' OPERATION SATISFACTORY (IF "NO" * COMMENT BELOW) Yes Q No Q DRY PIPF VALVES VALVE ROOM PROPERLY HEATED AIR PRESSURE No. 1 No. 2 QYes NoQ YesQ NoQ No. 3 No. 4 No. 5 No. 6 No. 7 No. 8 YesQ NOQ YQ NOQ YesQ NoQ YesQ NoQ YetQ NoQ YesQ NoQ No. 9 No. 10 No. 1 1 No. 'i, ,, No. 13 No, 14 No. IS No. Yes Q NoQ Yes Q No Q YesQ NoQ YetQ NoQ YesQ NoQ YesQ NoQ Yes NoQ YesQ NoQ No. 1 No. 9 No. 2 Lb* No, 10 No. 3 Lb*. No. 11 No. 4 Lb*. No, 12 No. 5 Lbs. No. 13 No. 6 Lbs. No. 14 No. 7 Lbs. No. 15 No. 8 Lbs. No. 16 ^ Lbs. Lb*. TURNED OVER Lb* yd Lb* Lbs. Lbs. NoQ GOOD CONDITION Lbs. Lbs. NoQ Lbs. WS AU TP EP RL I E S FIRE PUMP auto. CONTROL TESTED VesF~l PUMP ROOM PROPERLY HEATED AND VENTILATED YesQ NoQ_ = TANK OR RESERVOIR FULL TEMPERATURE AT COLD WATER RETURN (SHOULD BE 42F MINIMUM) FUEL TANK FULL PRIMING TANK FULL YD Yes HEATING SYSTEM IN USE Yes CIRCULATION GOOD * noD NoD EXTIN* GUISHERS charged yQ NoQ INSIDE HOSE IN GOOD CONDITION Yes^^ No| | CONDITION NO 1 YARD HYDRANTS, NO. 2 & HYDRANTS DRAINED HOSE YesQ NoQ ANY MISSING ACCESSIBLE ACCESSIBLE Nd NO. 3 NO. 4 REMARKS: ATTENTION NEEDED (Give Location) y*Q NO. 5 NO. 6 NoQ GENERAL ORDER & NEATNESS GOOD NoQ elect, EQUIP FLAM. LIQUIDS DEFECTS NOTED SAFETY CANS USED EXCESSIVE IN MFG AREAS YetQ y**d YesQ noq NoQ SMOKING REGULA TIONS LOCATIONS WHERE VIOLATIONS NOTED CUTTING & WELDING PERMITS ISSUED FOR ALL CAW OPERATIONS Ye*Q Non STORAGE WELL ARRANGED Ye*Q NoQ ADEQUATE SPACE BELOW SPRINKLERS Ye*Q No I 1 COMBUSTIBLE WASTE REMOVEO ON SCHEDULE (PROMPTLY) VesD COMBUSTIBLE DUST. LINT OR OIL DEPOSITS ON CEILINGS, BEAMS OR MACHINES Yesn LJ DESCRIBE AREAS NEEDING ATTENTION INCLUDING YARD: NoQ Non LJ DRAINAGE OBSTRUCTED VENT FANS ON Yes NoQ NoQ LISTED PRECAUTIONS TAKEN AISLES CLEAR CLEAR OF LAMPS. HEATERS Ye* Q Ye* Q YesQ NoQ NoQ NoQ FIRE DOORS CONDITION obstructed Ye*Q NoQ BLOCKED open Ye*0 Non ANY ACCUMULATIONS OF SNOW. DIRT, ETC. WHICH CAUSE ROOF OR FLOOR CONSTRUCTION OVERLOADING AND COULD LEAD TO COLLAPSE YeSQ ANY LEAKS IN ROOF AREAS NEEDING REPAIR YeQ NoQ NoQ f"tlm X-5069 3- 77 GENC 011136 VALVE INSPECTIONS INSPECT LOCKED VALVES AT LEAST MONTHLY, INSPECT ALL UNLOCKED VALVES AT LEAST IVEEKL Y. ALL INSIDE AND OUTSIDE VALVES CONTROLLING SPRINKLERS OR FIRE-PROTECTION WATER SUPPLIES ARE LISTED BELOW. CHECK CONDITION OF VALVE AS FOUND. PHYSICALLY "TRY" GATE VALVES INCLUDING NONINDICATING AND INDICATOR POST GATE VALVES. DO NOT REPORT A VALVE OPEN UNLESS YOU PERSONALLY HAVE TRIED IT. FM APPROVED PIVA'S (POST-INDICATOR-VALVE ASSEMBLIES), IBVS (INDICATING BUTTERFLY VALVES) AND STANDARD OUTSIDE SCREW & YOKE VALVES DO NOT HAVE TO BE TRIED BUT SHOULD BE VISUALLY CHECKED AT CLOSE RANGE. NO. 1 2 3 4 5 C6 0 7 N T8 B9 O 10 L 11 12 V A 13 L 14 V 15 E 16 S 17 18 19 20 valve location AREA CONTROLLED OPEN SHUT locked sealed THE "VALVE SHUT" TAG METHOD IS USED TO GUARD AGAINST DELAYED REOPENING OF VALVES. GENERAL TIRE VALVE SHUT TAGS SHOULD BE USED EVERY TIME A SPRINKLER CONTROL VALVE IS CLOSED. WHEN THE VALVE IS REOPENED THE 2 INCH DRAIN SHOULD BE FLOWED WIDE OPEN TO BE SURE THERE IS NO OBSTRUCTION IN THE PIPING THE VALVE SHOULD THEN BE RELOCKED. WERE ANY VALVES OPERATED SINCE THE LAST INSPECTION Y0 2c WERE VALVE SHUTTAGS USED 2 o WAS THE VALVE REOPENED FULLY ANO A FULL FLOW 2 IN. DRAIN TEST MADE BEFORE THE VALVE WAS RELOCKED OR RESEALED yd COMMENTS NoD INSPECTED BY SUPERVISOR 6ENC 011137 WEEKLY FiRE-PREVENTION INSPECTION SAMPLE ONL Y NO 0NE BLANK CAN 8E DESIGNED TO FIT ALL CONDITIONS. USE THIS BLANk. AS A BASIC OUU'f IN ni Vi l iH'tNl* YOUM OWN FORM. ITEMS THAT DO NOT APPLY CAN BE OMITTED. OTHER ITEMS CAN BE EXPANDED AS DESIRED. AND NEW ITEMS CAN BE ADDED. INSTRUCTIONS TO INSPECTOR Plant FILL OUT FORM WHILE MAKING INSPECTION, SEND COMPLETED FORM TO YOUR SUPERVISOR FOR NECESSARY ACTION REPORT SHOULD BE HELD FOR REVIEW BY THE NEXT ARM ENGINEER. LOCATION DATE 2o xi s p R Auto* ANY HEADS DISCONNECTED OR NEEDED Ye* No OBSTRUCTED BY HIGH PILING Ye. 1 N K MatiC Sprinkler* HEAT ADEQUATE TO PREVENT FREEZING (NOTE broken windows, etc.i i~n Yes |__ | .n No LJ Water Pressure LB. AT YARD LEVEL L E R S Sprinkler Alarm* TESTED Ves NoQ OPERATION SATISFACTORY (IF "NO" . COMMENT BELOW) Yes Q No Q DRY PIPE VALVES VALVE ROOM PROPERLY HEATED No 1 No. 2 Yes q Nog Yes g Nog No. 3 No. 4 No. 5 No. 6 No. 7 No. 8 Yes Q Nog YesQ NoQ V**D ND Yes g Nog Yes g NoQ YesQ NoQ No. 9 No 10 No. 11 No 12 No. 13 No. 1 4 No. 15 Ye* g Nog Ye* g Nog YesQ NoQ YesQ Nog YesQ NoQ YesQ NoQ YesQ NoQ YesQ NoQ NO 1 No. 2 NO. 3 No. 4 No, 5 No, 6 2 o No. 8 AIR PRESSURE No. 9 Lbs No. 10 Lb*. No. 1 1 Lbs. No, 12 Lbs. NO, 13 Lbs. No. 14 Lbs. No. 15 Lbs, No. 16 Lbs. Lbs. TURNED OVER Lbs. YesQ Lbs. noQ Lbs. Lbs. GOOD CONDITION Lbs. Yes Q Lbs, NoQ Lbs, ws AU TP EP RL 1 E S FIRE PUMP AUTO CONTROL TESTED YesO PUMP ROOM PROPERLY HEATED AND VENTILATED y,,Q NoO NoQ TANK OR RESERVOIR FULL YesQ NoQ TEMPERATURE AT COLD WATER RETURN (SHOULD BE 42F MINIMUM) FLELTANK FULL PRIMING TANK FULL YesQ YesQ] HEATING SYSTEM IN USE YesO CIRCULATION GOOD YesQ NoQ NoO Nod NoQ EXTIN. guishers CHARGED INSIDE HOSE IN GOOD CONDITION nD YARD hydrants & HOSE CONDITION NO, 1 NO. 2 HYDRANTS DRAINED YesQ NoQ ANY MISSING ACCESSIBLE VQ ACCESSIBLE NoQ NO, 3 NO. 4 REMARKS: ATTENTION NEEDED (Give Location) Yei f~| NO, 5 NO. 6 GENERAL ORDER & NEATNESS GOOD Yes Q Nog elect, EQUIP, flam. LIQUIDS DEFECTS NOTED SAFETY CANS USED EXCESSIVE IN MFG. AREAS YesD YesQ YesQ NoQ Nog NoQ SMOKING REGULA* TIONS LOCATIONS WHERE VIOLATIONS NOTED CUTTING PERMITS ISSUED FOR ALL C6.W OPERATIONS YesQ Non & WELDING STORAGE WELL ARRANGED YesQ No (""1 ADEQUATE SPACE BE LOW SPRl NKLE RS YesQ NoQ COMBUSTIBLE WASTE REMOVED ON SCHEDULE (PROMPTLY) YesQ COMBUSTIBLE DUST. LINT OR OIL DEPOSITS ON CEILINGS. BEAMS OR MACHINES Yesn LJ DESCRIBE AREAS NEEDING ATTENTION INCLUDING YARD: NoQ Non u DRAINAGE OBSTRUCTED VENT FANS ON YesQ YQ NoQ NoQ L1STEO PRECAUTIONS TAKEN AISLES CLEAR CLEAR OF LAMPS. HEATERS Yes YesQ Yes Q NoQ Non Nog fire DOORS CONDITION obstructed YesQ Non BLOCKED OPEN YesQ NoQ CONSTRUCTION ANY ACCUMULATIONS OF SNOW. DIRT, ETC, WHICH CAUSE ROOF OR FLOOR OVERLOADING AND COULD LEAD TO COLLAPSE YejQ ANY LEAKS IN ROOF AREAS NEEDING REPAIR Y*.Q NoQ Non X-5869 3-77 GENC 011133 VALVE INSPECTIONS INSPECT LOCKED VALVES AT LEAST MONTHL Y, |NSPECT ALL UNLOCKED VALVES AT LEAST WEEKL Y. ALL INSIDE AND OUTSIDE VALVES CONTROLLING SPRINKLERS OR FIRE-PROTECTION WATER SUPPLIES ARE LISTED BELOW. CHECK CONDITION OF VALVE AS FOUND. PHYSICALLY "TRY" GATE VALVES INCLUDING NONINDICATING AND INDICATOR POST GATE VALVES. DO NOT REPORT A VALVE OPEN UNLESS YOU PERSONALLY HAVE TRIED IT. FM APPROVED PlVA'S (POST-INDICATOR-VALVE ASSEMBLIES). IBV$ (INDICATING BUTTERFLY VALVES) AND STANDARD OUTSIDE SCREW & YOKE VALVES DO NOT HAVE TO BE TRIED BUT SHOULD BE VISUALLY CHECKED AT CLOSE RANGE. \ N NO. K L 2 E R3 4 VALVE LOCATION AREA CONTROLLED OPEN SHUT LOCKED sealed 5 C6 0 7 N T8 R9 0 10 L 11 12 V A 13 L 14 V 15 E 16 S 17 IS 19 20 THE "VALVE SHUT" TAG METHOD IS USED TO GUARD AGAINST DELAYED REOPENING OF VALVES. GENERAL TIRE VALVE SHUT TAGS SHOULD SE USED EVERY TIME A SPRINKLER CONTROL VALVE IS CLOSED. WHEN THE VALVE IS REOPENED THE 2 INCH DRAIN SHOULD BE FLOWED WIDE OPEN TO BE SURE THERE IS NO OBSTRUCTION IN THE PIPING. THE VALVE SHOULD THEN BE RELOCKED. were any valves operated since the last inspection *o WRE VALVE SHUT TAGS USED Y.Sp WAS THE VALVE REOPENED FULLY AND A FULL FLOW 2 IN. DRA N TEST MADE BEFORE THE VALVE WAS RELOCKED OR RESEALED COMMENTS. M0n INSPECTED 0 V. SUPERVISOR DATE OATS GENC 01113? VCM-PVC MANAGEMENT SUMMARY necetvcD FEB J 13Tf &&Uiun4fia Vol. II, No. 1 ON THE REGULATORY FHONT Court Grants SPI Intervention In EPF Suit, On December 9, SPI filed a motion with the U.S. Court of Appeals for tbe District of Columbia asking to intervene in the November 19 petition of the Environmental Defense Fund (EDF) for review of EPA's national emission standard for vinyl chloride ... SPI said any modification of the standard could disrupt and render moot efforts underway * to meet strict statutory compliance deadlines set by EPA. On December 20, the U.S. Department of Justice, which is representing the EPA in the EDF case, filed an Opposition to the SPI Motion to Intervene... Justice alleged that SPI clearly could have filed a petition for review of the regulations if it had done so within 30 days after the regulations were promulgated, and did not do so... hence, Justice said , SPI may not participate as a party to the review proceedings... further, Justice claimed that to the extent the Court of Appeals feels some form of Intervention is permissable, SPI's Intervention should be strictly limited to those raised by EDF. On December 29, SPI filed a "Reply of the Society of the Plastics Industry, Inc, to Bespondent's Opposition.to Motion for Leave to Intervene'1... it is expected that the Circuit Court's Motlona. Panel will meet early in January to rule on SPI's motion... in its reply, SPI emphasised thaitt has not filed a petition for review and does not intend to challenge the Standard... further that SPI sought to Intervene because it was concerned that efforts to modify the Standard could "disrupt and render moot efforts already underway to meet the existing Standard within the strict statutory deadlines imposed by Section 112 of the Clean Air Act"... SPI pointed out it seeks to Intervene only to ensure that "this Court will have before It all relevant arguments in support of the Standard and will be appraised of tbe consequences of any proposed modifications... SPI's Reply also pointed out that the interests of SPI members cannot be adequately protected by participating In the review process as Amicus Curiae ( as the Department of Justice suggested in its Opposition Motion). On December 30, the Court of Appeals granted Motion to Intervene In the case of The Goodyear Tire & Rubber Company and Air Products and Chemicals. Inc... however, the government filed opposition to these Motions, and the Court vacated it's previous Order granting the Motions ... on January 18, the Court decided to grant all the pending Motions fer Leave to Intervene. i \ |j GENC 0111 AO -3 - -<"V TOSCA Problems Analyzed December 15, 1976, Chemical Week article "Toxic Control Law Needs Helping Hand" notes "Chemical Industry will have key role in developing regulations that will determine the direction of control effort and how well it will halt spread of hazardous materials"... notes three things have become clear from current debate over Implementation of the TOSCA... (1) Control of toxic substances will become EPA's biggest task within 10 years; (2) Rapid developments in toxicology and epidemiology are needed to come to grips with the law's requirements; (3) The chemical Industry is going to play a major role In development of the regulations... quotes Dr. Samuel Epstein, head of the University of Illinois' Department of Occupational and Environmental Medicine (School of Public Health at Chicago) as saying the TOSCA is "one of the most critical measures in the history of preventive medicine in the U. S, " NIOSH Expands Workplace Cancer Program December 6, 1976, Chemical & Engineering News reported that NIOSH has developed an ambitious three-part program involving surveillance, industry-wide studies and laboratory research to identify and control carcinogens in the workplace... program has been greatly expanded at the prompting of Congress which upped allocation from $1.8 million in fiscal 1975 to $6.9 million In fiscal 1976. ON THE LEGISLATIVE FRONT In Congress... Several bills that expired In the last session of the 94th Congress will return early in the first session of the 95th Congress... The Clean Air Act of 1970 actually expired on June 30, 1975 and amendments were killed by a Senate filibuster... funds for the original law are provided through September 1977 so pressure will be heavy to get revision of the act passed quickly... same kind of Congressional thinking applies to Water Pollution Control Act of 1972 which expired June 30, 1975 although Its funds are provided through September 1977... since this law gives EPA power to control water pollution there will be a rush to get it extended. In The States... More than 40 of the 49 legislatures scheduled to have regular session in 1977 will convene in January .. .in New Jersey, according to the December 31^,1976_New York Times, a Senate committee recommended on December 30 that the State Legislature ban 16 cancer-causing chemicals from the State as part of a far-reaching program to cut the high rate of cancer In the State... the committee also suggested that the Governors and Legislatures of New Jersey, New York, Pennsylvania and Delaware form a four-state cancer-control commission to attack environmental canoers on a regional basis... according to the Times, asbestos and vinyl chloride head the list of 16 chemicals the committee recommended be banned In New Jersey. GENC 011141 -4- " ON THE TECHNICAL FRONT New Mammary Tumor Results Reported According to December 29 Pesticide & Toxic Chemical News, vinyl chloride inhalation tests on rats conducted under contract for HEW's National Institute for Envlronmenal Health Sciences (NIEHS) reportedly have shown induction of malignant mammary tumors at levels down to 50 parts per million... further that none of the tumors appear in control groups which inhaled no vinyl chloride... preliminary results "revealed to Pesticide & Toxic Chemical News by one of the nine Environmental Protection Agency officials" asked to comment on the new Maltoni findings, lend credence, the source revealed, to allegations by EPF that EPA's air emission standard for VCM does not offer adequate margin of safety to people living near plants which emit the chemical. NEWS BRIEFS VCM Discovered in Long Island Wells * Tiny amounts of vinyl chloride and other toxic chemicals have been found In water from some public and private wells on Long Island, just east of New York City... VCM was found in only two of 50 wells tested thus far but has received most of the publicity... source of pollution said to be Hooker Chemical Company PVC plant (now closed) but this theory being questioned... New York State legislators up in arms... local health officials have been blamed for alleged failure to act decisively on problem... story has attracted wide press attention in Long Island with some national coverage. Labor Says Existing Channels Best For Information on Carcinogens On December 3, Sheldon Samuels, AFL-CIO's director of health safety and environment, said agencies wishing to inform workers about workplace carcinogens and other occupational health hazards should use existing channels of communication rather than inveht totally new systems... addressing a symposium in Washington, D. C. on role of public Information in prevention of occupational cancer sponsored by National Research Council of National Academy of Sciences, Samuels noted "We need to look at existing structures and develop information tools for peer group leaders in those structures"... stated examples of channels that can be used to disseminate information to workers are voluntary health associations, county health services, community and church programs, and the mass media. PVC Involved in White House Fire PVC fumes were labeled the main hazard resulting from a small fire in an auxiliary power transformer room at the White House on December 17.. .a spokesman for the D. C. Fire Department said PVC fumes are a "continuing problem" In Washington fires... one White House employee required hospital treatment for smoke inhalation... the story received heavy coverage in the Washington press and local radio and television. 6ENC 011142 ---w^i -5 - -jfasdr' ON THE MEDIA FRONT Massive Cancer Series Buns to Long Island Newspaper The vinyl chloride industry was given high marks for its clean up effort in the third installment of a massive 14 part series on cancer running in Newsday, a major Long Island newspaper... 'In 1974, when the link between vinyl chloride and a rare liver cancer was established, the plastics industry set in motion a huge clean up campaign," the article said... SPI Technical Director John Lawrence was quoted extensively as to the industry's commitment and control programs... "that kind of thinking, that kind of effort, is necessary for the health of the nation and, in the long run, the health of their businesses, " the article concluded. Industry Critic Praises PVC Control Program Dr. Jeanne M. Stellman, a frequent critic of health conditions in U. S. industry, used the PVC industry as a prime example of "a job well done" in an article in the * November/December issue of Occupational Safety & Health... some of her quotes: "The best example (of successful process control) Is vinyl chloride"... "Today, residue (of VCM in PVC resin) is controlled to less than 10 ppm. This virtually eliminates VC monomer exposure among PVC product processors" . "Profits continue to rise ( in the resin industry) and future cancers have probably been eliminated. '' #### GENC 011143