Document 1QnpgmDaL7gmg66yyyV9oe89E

NOUSTRILS INTEROFFICE / LAKE CHARLES TO FROM P. J. Snyder p* s- Trew DATE December 8, 1978 SUBJECT VDC Workpractice Guideline Status Phil, here is the update of the progress made on achieving compliance with the VDC Work Practice Guidelines. If you have any questions, please feel free to cal I. Point 1; Authorized Person -- Dr. H. B. Lovejoy maintains a Iist of personnel, both PPG and contract workers, who are authorized to work in chlor inated organics plant. Point 2; Project Status -- The VDC Emission Control Project (P-746) is in the study and estimate stage. ACT preparation and approval will be in the first quarter of 1979. The VDC closed loop samplers are in service. The Laboratory ventilation system is in working order. Point 3: Methods of Control -- The VDCM Respiratory Policy is posted on the bulletin boards in Area B. PPG and contract workers are following this respiratory policy. Point 4: Emergency Procedures -- A written operational plan for emergency situations has been written. This plan has been reviewed with the MCVDCM unit operating personnel. This plan is also found in the MCVDCM Operating Manuals. Point 5: Medical Surveillance and Training -- Medical Surveillance is provided to all employees, PPG and contractors. Initial training/orientation programs are given to PPG and contractor personnel. Further contractapersonnel are given specific training when working in either the VCM or VDCM units. A roster is maintained of those people who attend the training programs. Point 6: Former PPG Employee Follow-up -- All PPG and contract personnel are provided an exit physical at the time of termination of employment. PPG, at this time, does not require a death certificate at the time of death of an employee or former employee. Follow-up physicals are not provided on a routine schedule to former employees. SL 073&7 P. J. Snyder December 8, 1978 Page 2 Point 7: Monitoring Schedule -- The present monitoring schedule for VDCM and other chlorinated compounds is monthly monitoring of all operators. /as cc: W. J. Peard R. Corley/M, Davis SL 073&08 INDUSTRIES '*W To: Z. G. Bell INTER-OFFICE CORRESPONDENCE Date: July 25, 1978 From: P. J. Snyder Location: 10 West Subject: VDC Workpractice Guideline Status A review was made of the current status of the Vinylidene Chloride Workpractice Guideline at Lake Charles on July 18 and 19, 1978. Attached for your information is a summary of those items which require additional attention. Two major problem areas which warrant further discussion between plant management, Environmental Affairs, and the Industrial Relations De partment are: What involvement is PPG to have with respect to contractor workers in plant areas affected by workpractice guidelines and internal standards, e.g. , VDC, EDC, Hg. What medical surveillance is to be afforded to former PPG employees who are covered by workpractice guidelines. The VDC Workpractice requires/recommends a periodic follow-up of former PPG employees who have had five or more years potential exposure to VDC. In general, Lake Charles is making progress in identifying potential VDC problem areas and implementing corrective/preventive control measures. While employee exposures in excess of the internal standard have been found on certain job categories, a reduction on actual VDC exposure levels should be noticed with the implementation of an enforced respiratory protection policy and the use of a closed sampling system as proposed. A periodic review of the progress made in implementing the VDC Workpractice will be made in order to keep you up to date. If you have any questions or comments on this review please let me know. VDC Workpractice Guideline "Noncompliance Items" Section Recommended Program Requirements B.3. De fi n i t i on s "AUTHORIZED PERSON" means any person specifically author ized by PPG to enter a VDCM regulated area. A complete roster of the persons who are authorized to enter the plant's VDCM regulated area must be developed and maintained. _ A complete roster of PPG employees who are medically authorized by Dr. Lovejoy to work in the organics area is presently maintained. While this authorization also applies FORM 503 A RiV 6-1-76 SL 073609 1. G. Bell July 25, 1978 Page 2 C.l. , C.2. Permissible Exposure Limits F.d. Methods of Control to contra$:or workers who are working in the vinyl chloride areas, it does not at the present time apply to contractor employees potentially exposed to vinylidene chloride. A determination of the medical surveillance that is to be required of contractor employees potentially exposed to other organic chemicals including vinylidene chloride is requi red. No employee may be exposed to a VDCM air concentration greater than 2.5 ppm (TWA) as determined by personnel monitoring conducted for a period not less than four (4) but not greater than ten (10) hours and averaged over the time period of actual sampling; and. No employee may be exposed to VDCM to concentrations greater than 10 ppm (ceiling) as determined by any personnel moni toring conducted for 15 minutes. There presently are plant operations which can result in employee exposures in excess of the prescribed limits. Three job categories with the greatest exposure potential are: (1) EDC Operator, (2) Me Operator, and (3) Me Aux. Operator. Other workers with exposure potential in excess of 1.0 ppm TWA include the Me Lead Operator, P/T Still Operator, and loading personnel. The VDC Emission Control Project (Res 613.0 P746) as planned will minimize this exposure potential by 1981. Interim control measures are being taken to eliminate or minimize known sources of exposure, e.g., the installation of closed loop and a review of the adequacy of present laboratory ventilation systems. In order to minimize both releases of and exposures to VDCM, all the applicable operating manuals shall be reviewed and revised so as to include precautionary information and pre ventive steps that must be followed when working with VDCM. If two consecutive personnel monitoring determinations con ducted on a single job category reveal an actual overexposure to VDCM, the written work procedures followed by the employees assigned to that job category shall be reviewed in order to ascertain the need for additional methods of control. Based on past experience and the information generated by the monitoring program, those jobs which require respiratory protection have been identified. An announcement outlining when respiratory protection is to be worn is to be posted in the unit control room (proposed requirements provided as Attachment 1). This procedure is to be substituted for the required manual revision. SL 073610 Z. G. Bell July 25, 1978 Page 3 1.1 . Emergency Procedures J.l . Training and K.l. Medical Surveillance K.l-(G) Former PPG Employee Fol low-up TWritte^^operational plan for emergency situations shall be developed.* The plan shall specifically provide for: A. Evacuation procedures. B. Fire fighting procedures. C. The use of appropriate protective equipment and clothing, including the use of a self-contained breathing apparatus. _D. Containment and cleanup procedures. _ At the present time a "written operational plan for emer gency situations" is not available. B. Lynch is to prepare this procedure. TTach employee engaged in VDCM operations shall be provided training in a program relating to the hazards of VDCM and the necessary protective measures for its safe use. Such a program shall be provided at the employee's initial training and annually thereafter; and. Any employee assigned work in an area where a potential ex posure to VDCM may occur shall be placed on a medical sur veillance program. The program shall provide each such employee with an opportunity for examinations and tests in _accordance with this paragraph. Presently, employee training and medical surveillance applies to PPG employees only and not contractor personnel. Again, this area of involvement needs to be resolved. It is further suggested that the Employee Training Program provide for a documentation that each employee affected by this workpractice was in fact informed of those items listed under Section J of the guideline. "All employees who have had five or more years employment at PPG in a job where there has been VDCM exposures above those specified in Section C of this workpractice guideline will be followed-up as described below. 1. At the time of departure from PPG's employment, they will be advised that they are entitled to an exit physical examination and a follow-up examination is advised every three years to include the five tests specified in (K)(1)(c) of this workpractice guideline. 2. PPG will request death certificates when an employee or former employee dies. sb 0736H 1. G. Bell July 25, 1978 Page 4 * An exit physical is performed on a 1 newly retired/ terininateff"employees. No plans have been made to address this requirement of the workpractice /tea Attachment cc: F. C. Dehn "P fr. P. J. Snyder SL 073612