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/ /f r U.S. Department of Labor July 8, W87 Occupational Safety and Health Administration 344 Smoke Tree Business Park North Aurora, Illinois 60542 (312) 896-8700 Borden Chemical Division Borden, tnc. 130 E. Broad Street Columbus, OH 43215 Attn; Mark Grenwald Dear Mr. Grenwald: Representatives of the Occupational Safety and Health Administration (OSHA) recently visited the following company: The above mentioned company purchases the following chemlcal(s) from you: PVC Homopolymer At the time of the visit, labels on shipped containers of hazardous chemical(s) supplied by your company were found to be deficient in the following areas: The label did not give a proper hazard warning to Include the following: Respiratory Irritation, Eye Irritatioa which is target organ and effect. You are required under OSHA* s Hazard Comninication Standard (29 CFR 1910.1200) or your State's right-to-know law to perform hazard determiatlons, label outgoing containers properly and provide copies of MSDS for all hazardous chemicals which you produce or import. A copy of the standard is provided for your reference. Please Immediately send proper labels for the containers of hazardous chemical(s) listed above to your customer. Thank you for your assistance. If you have any questions regarding this matter, please feel free to contact me at (312) 896-3700. Sincere! v. Kenneth Yotz Area Director recess0 f TABLE I VINYL CHLORIDE LABELING PRACTICES VI MEMBER COMPARIES MANUFACTURING VCH O <\i rV O o o o o ,5k COMPANT PPG INDUSTRIES DOCS TANK CAR CARRY DOT LABEL? YES DOW CHEMICAL BORDEN CHEMICAL BFGOODRICH VISTA CHEMICAL YES YES YES YES DOCS TAHE CAR CARRY AN OSHA "CANCER SUSPECT AGENT" LABEL? YES YES (On materials shipped out of plants. YES YES (Welded In side of tank car.) YES IS MSDS SENT WITH TANK CAR? NO YES YES NO NO COMMENTS MSDS sent by mail with initial shipment to customer in calendar year, on a yearly basis. Updates to comply with OSHA 90-day requirement. OSHA label and MSDS inside dome. Tank cars as received carry OSHA "Cancer Suspect Agent" Label. MSDS with shipping papers. GEORGIA GULF YES YES YES Prior to or at time of first shipment. T 2Z V 00000 AAA TABLE II PVC LABELING AHD USDS PHACTICES (BESIB) VI MEMBER COMPANIES MANUFACTURING PTC RESIN COMPANT AIR PRODUCTS DOES LABEL CARRY OSHA "CANCER SUS PECT AGENT" LABEL? YES (On bags bulk cars, & silos) I-A1MI. (NT RESIN DOBS LABEL CAR RY NOTATION RE: DUST? NO DOES LABEL CAR RY NOTATION RE: COMBOS. HAZARD? NO MATERIAL SAFETY DATA SHEETS DOES HSDS IN CLUDE VC "CANCER NOTATION RE: NOTATION RE: SUSPECT AGENT" DUST AS A FIRE/COMBUS STATEMENT? "NUISANCE"? TION BAZARS? YES YES YES COMMENTS CBRTAIBTEED YES NO NO YES YES YES GEORGIA GULF yy.s f^T \ sill B'V~ OCCIDENTAL YES if > lppm RVCM NO if < lppm RVCM BORDEN BFGOODRICH VISTA All suspension resin SO LABELED. A1 pasCe resin <lppn RVCM is not labeled. If > S.Sppm RVCM Would be so labeled. Mostly, resins are < S.Sppm and are not labeled. YES -AiuH uwn~ h NO NO YES YES YES , . ' 1:) tXzf . . ) NO NO YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES Label sent w/ bill of lading. YES VVV G 00004222 TABLE III PTC COMPOUND LABELING AND MSDS PRACTICES VI MEMBER COMPANTES PRODUCING PVC COMPOUNDS COMPANY CBORGZA GOLF DOES LABEL CARET OSHA "CANCER SUS PECT AGENT" LABEL? NO LABEL ON COMPOUND DOES LABEL CAR RY NOTATION RE: DUST? DOES LABEL CAR RY NOTATION RE: COMBOS. HAZARD? NO YES OCCIDENTAL NO NO NO BFGOOORICH YES If RVCM > 8.Sppm YES YES MATERIAL SAFETY DATA SHEET DOES MSDS IN CLUDE VC "CANCER NOTATION RE: NOTATION RE: SUSPECT AGENT" DUST AS A PIRK/COMBUS STATEMENT? "NUISANCE"? TION HAZARD? YES NO YES NO NO YES YES YES YES COMMENTS Label also carries Informa tion on sensitivity to stabilizers. MSDS forms list limited haz ard warnings for ingredients (stabilizers, plasticz. etc.) Labels address fumes from processing. VISTA YES YES YES YES YES YES  Gabriel lias lead modcwnacompli- birth."Fontenot explained, cated path from the Department of He said he had fold DHHR i iniiiMinii tifl tTiuBfr a rtrnnrn rf about -- this, - and continued the fimronoicBtal ' Protection . saying,"Georgiar Golf and BJP. Ageagft to the ISO Lkary; in Goodrich have had numerous leaks . search of the answers they re* ' and releases through the peari.of quested. iWortuaiately, my expo- vinyl chloride." rise b not fo Qieirical Engineering <v. scientific analysis. Therefore, it Dr. Robinson pi DHHR said that she -didn't have the manpower is notary positioo to ofier the Col* to initiate an mwesrigation as exten- lowing information as a conclusive sive as this one, at this rime, butthat answer to .those questions'being she did however, have sone of her raised in`the community-of' St sfaff trying to compile birth recards GsbrieL The ihfbnnatioa compiled and herem actnaDy is a continuation of N area. from the St'Gabriel :; - frdr original questions, Is'It pos- When'I Grst began this invesr rible that the emissions of Hazar- ligation I spoke with Kay jGaudet a dons Air PoDutants from the chcim- pharmacist In S& GabrkL She sup* cal r1--** in the St .Gabriel area, {died me with .names of some could have,. in some way, -con- women who she knew had suffered tributed to the priscamages, and miscarriages and tfiffidot pregnaa- other medical and health related ties. She also toldme ofthe group problems that residents ofthe com- ofwomen in the area, (he tta ladies nranity suffer from7 - .who were aD pregnant id the same. It has been said that rising con- rinie, and hine'had ,miscarriages, icern in the St Gabriel area over,the . that 'Fontenot* had spoke of.She past few months in relation to the * added^though, that these ladies jdl allegedly lrigh rate of miscarriage suffered thtir^miscairi^ges. in the and stiD births, has prompted hives- same six to . eight month time to be iniriated in various period, between late 1984 and early agnatic* and whh a con* 1985. Gaudet went on tocxplain gfomeration of savironincBtaliit that the average for mis- groups. carried pregnancies as &9 for tvmy Congressman Charles Ttaddy" 1000 livctolhs.Sbe eaplaioed that Roemer rnrtacfftd the .Attorney it would take' St Gabriel 15 .1/2 General's office asking for mi mves- yearstohavclOOOBvebirths,thererigarion after he was made aware of fore St Gabrfcl exceeded the Na- the suspicions ofsome women m St rional Average injust six months. Gabriel who had suffered iwtscar- \ The fonaen 1 spoke with riages and still births. Willie Fon- labeled Vinyl, Chloride a "fetal ' tenotof the Attorney GeneraTs Of- taxinV One woman said, /Vinyl free confirmed that he had sent a Chloride rentes spontaneous aborletter to Dr. Sandra Robinson of tion in pregnant women." the Dcpartmesft of Health and Vinyl chloride is a human carcin- Human Resources asking them to ogen. k labeled as an EPA hazardi--oos waste and a priority <oxic "Basically, in 1984, out oT 10 (See VTNYL CHLORIDE, page sA) Wv 00000^223 VINYL CHLORIDE. tfmwffwmri from pngs lA) - poVntutt. The compound is tnatlly 1 went to the LSU Library la la search Of facts tn to how !; encountered a* a cooled liquid, jet earth of support for what these much of this tone chemical has ac : is actually a flammable gas at room , temperature. Vinly chloride is s j. colorless gas and is basically odor- , less. Yet at it's threshold of human ; detection lias a pleasant ethereal odor, similar to that of gasoline | fumes. 'women bad told me. In a book - catted "Mutation, Cancer, and Mik formation*, written by Ernest RY. Qui and Walderico-M/ Gcheroao, under the nhhHwig "vinyl chloride*, I found support for their tually escaped to tire atmosphere in recent yean, 1 went to the main of fice of DEQ to Baton Rouge. Iwas Bowed to examine file* which con tained information concerning the , amounlsofvinylchloridewhich had p I called upon Mr. Bill Davis of DEQ, head of the LESHAP surF veillance, (Louisiana Emissions Standards for Hazardous Air Pol- been released. Under the direction ,, sr.k`sa:.4-. .-K*-. -- . i' 9An Increasedfetal mortality,was observed for the wives ofMothers \ of Bill Davis, I was Georgia Gfd Dow B. F.Goodrich.1''l given foes for Chemical and L lutants), this division of the who had been exposed to the com- Some ofthe filet were incomplete Jr EPA/ DEQ is the office which . pound, and other studies hove /m/i- and others ritoply listed a date that assesses whether or not a particular K -voted mn-increased risk-of .birth an emission occurred without list (emission of vinyl chloride was pie.venuble. Once ah emission is defects in children ofparentsrepd- ing the amount involved. The entire int in the veebtity ofvinyl chloride year of 1984 of the Georgia Gulf as either preventable or - . production' and polymerization surveillance file was nowhere to be aoa-preveotabie they begin the pro- ; plants * the passage read'. found. Therefore, only limited cess of determining if any action .information concerning that partic should he taken against the viola ular time period was madeavailable . tor. Once the Environmental Qual- Georgia GoH, Dow Chemical to me. . , ./ - tty Act has been violated, the DEQ : and -Bf. Goodrich use vinyl Diavis was successful in . then decides what action, if any, [ chloride mthetr production proces- some information from another should be taken against the plant. r set. Dow prodnees the chemical it- source concerning this year.- Davis could not confirm the settand sells vinyl to B.F. Goodridi statement by the women I spoke by pipeline, and ships the chemical with concerning vinyl chloride ' fay ratt also. When shipped by rail, From the awaflaMc rornrdt, the approximate aumber af total being a fetal toxin or causing spon taneous abortion in pregnant women, he could only tell me in I regard to the subject that the t>EQ r inspectors, those who go to -the plants to do annual inspections and periodical inspections to determine the preventability of a particular emission, cmmiot be woasen of ` childbearing age. In search ofproofthatwhst these ; women had told me was in fact , scientifically tested and proven 1 somewhere, I called Dr. James , Freeman, Iberville Parish Coroner. Freeman also could not confirm this. He did, however, agree with Davis saying that vinly chloride has ; been proven to cause angiosar coma, cancer of the liver. Davis had told me that this was.discovered st 1 B F Goodrich plants in Kentucky, - the chemical is a liquid under pres sure. .Georgia Gulf also produces vinyl chloride and sells the chemi cal. They also are a polymerization . plant, producing Polyvinyl chloride from the vinyl chloride monomer, or creating PVC from VCM. B. F. Goodrich, as mentioned .before redeves its vinyl chloride from Dow Chemical by pipeline, and they produce PVC resin and adme PVC compound. ' Their polymerization plant produces the granular type resin to be shipped out `for -tire creation of such products as pipe fitting, construc tion industry electrical fittings, mapping products, such as plastic ; -wap. That part of the PVC resin j pounds of vinyl chloride release! from these three plants froir 1961 until the begining of 1987 added uj to 153,097.89 lbs. Sources of these release varied but most were safety vahn releases, pumps and . other tnal functioning equipment However eveiytime a plant starts op or drau - down ususwally Urge omission! occur, this is also true' of shutting down the boilers for inspection and other operations. * On some oc- caiiuons of boiler shut down, in which the EPA had given their per mission to the plant to conduct the shut down fully aware that chemi cals would be released, a*ery large amount of hydrocarbons were .emitted. made into -compound is sold for rfcMigK neh |JmA-hnftW (V VVV 0000Q4224 ~s ~ pkte Oeotpi Mf flu tmiM 9645U9 h 4* vfagt dMe g F Goodrich, which receives it's teleased,*Dow Mbl reported . i vinyl chloride Item Dow Chemical 15,2S3jO fci, mod B. F.Goodrich i- by pipeline, emitted i3,429. lbs, wf totaled 41,677.30**. cadged o?er I1' VCM -to-'the atmosphere in tbe pt51/2 yean. , } 1983. These entitstons included-a ' The years of the most cobcernto - those' residents in Sl Gabriel involved in this issue in those of , 1984 nod 1985, According to those. DEQ record* available, .^Dow. 7J00 lb. release on October 18 of ! 1983 and 5,000 lbs.'on December 14, 1983. 1 In the years 1980 and 1981, B F : Goodrich released 11 50 lbs. of Chemacafs total emissions from J984 and 1985 were 288.00 lbs. From 1984 to .1985 BFGoodrich emitted 24,61235 lb*, of Vinyl chlo ride according to DEQ records. -Georgia Gulf, between 1984 and 1985 according to the incomplete . records at DEQ, had a total of ^ 29,635.48 lbs. of VCM released io the atmosphere. Georgia Gulfs releases for, that. time period included a 17,760 lb. release .of vinyl chloride tin November 13,1985 front their PVC pant and 9,142 lbs. that same day' from their VCM`pitot These releases also included a 1,900 lb. emission on April 23, ,1985 from ` vinyl chloride to the atmosphere. In 1983 the U.S. filed suit against . BF Goodrich in relation to it's vinyl . chloride emissions. The .company ; had to pay approximately ; 8100,000.00 to the state as a result - of thefe.soppisiiik; .... . *. ,V .. Georgia Gulfs emissions ml986 and pan of .1987 total to 5,796 lbs. . . of vinyl emitmd. i . From 1980-1982 the company r released 5297 Jbs. according to - DEQ records which went only as l far back as 1980. ; On September 20, J985 a pro- ' posed concent decree .in United :. States vs. Georgia Pactfic Corpora! tion was 'lodged with the United '' States District Court, Middle Dis- tbeir VCM plant. B F Goodrich's releases .during this time period included n 5,400lb. f `trict of Louisians. The.complaint filed by the US; alleged that the : Georgia Pacific Corporation vio- release ofvinyl chloride onJanuary * lated the 'Clean Air Act and the 19,1984; and a 3400 lb. discharge Vjiiyt Chloride National Emissions oilJanuary 29,1984. - On June 22, J 1984, they rekased 2fi00 lbs: of vinyl chloride to the atmosphere * and on August 15,-19846.8lbs. with '*- n 7.905 1b. rtkaston August 21 -of f thai'year.'-In *1985. -they 'emitted 1 '4*00 lbs'. 6f VCM dh'May 6. According to the DEQ records, Dow's .total reported emissions from 1986 up to date total45.50 lbs. ,of VCM emitted to the atmosphere. j ' However, in 1983 Dow Chemical rckased 4,425JI lbs. of VCM to t the atmosphere according-to the [ records. These emissions inchided a : 300 lb. release on December 4, 1983. 750 lbs, on April 15, and the same week on April 18, 3,080 lbs. , were released from the plant. In 1981 and 1982 Dow released ` Standard for Hazardous Air Pollu- 1 tants, by discharging vinyl chloride' from its ethylene dichloride/ vinyl chloride and -potyvinly chloride ; facilities. Georgia Gulf now is the | - owner of the plant .and * conse quently intervened in the action to effectuate the injunctive relief .sought by the U.S. under Concent Decree. The ' Concent Decree required the plant to adhere to a Remedial Action Plan and ensure , cbmpliance.- Tbe company bad to- ; pay 8562,300.00 in civil peaaities-to i. the U.S. and an additional penalty: of -.862,500.00 to *the State . of ( Louisiana. . * Vinly chloride is used as a'vinyl monomer in the manufacture of ] 10,495 lbs. according to ihe'fiks, . These releases included an 8,925 lb, i release on October 22oH982 anda 770 lb. discharge on August II, 1982. pphrrinyi chloride and other teams.. . According `to .hiutatkm,*. Cancer ^ and by Enint H.Y. Chu and WaldericO'M. Gencroso, 1 over 90 percent of vinyl chloride monomer is uafed in the production of vinyl chloride horaopolymer and . copolymer resins Used in the build ing * and construction' 'Industries. 7k compound is used in the crea tion of auch things as plastics, varatshes, silk and paper coatings and , refrigerants. 'According to ihie 'Handbook of Toxic and. Hazardous Chemicals, byMarshall Sittig, the hazards of vinyl chloridfc was .'originally believed to girimarily. concern workers'employed in* the conver sion of VCM to PVC, (vinyl xWo-; ride 'niodomer to .polyvinyl chloride) who may.receive a partic ularly high exposure of VCM iq certain operations, or long term exposure to relatively low concen trations of VCM in the air at differ ent factory the*. Muchiarger populations axe now believed to be . potentially at risk, including: pro ducers ofVCM, people livingin the dost proximity to VCM or PVC producing industries, users ofVCM as propellant in aerosol sprays, per, sons in contact with resins made from VCM, consumers offood and beverage products containing teachable amounts of unreacted VCM from PVC packaged .mate-.' rials (plastics, etc.), and ingestion of water containing .unreacted VCM leached from PVC pipes. In 1976 it was. bstimiied that almost one 'million"`persons .were, associated with manufacturing goods derived frain 'PVC.'. i'.`" - -This same publicationbays, 'Incinerators maybe an additional : source of &inyl chloride emissions since the entrapped monomer, escapesfollowing incomplete4?pfn~ bustion of PVC products-f-- According to the: ^filial'rule* of the DEQ Regulations and Proce' dUres for Unauthorized Dis charges, ' which became effective November 19, 1985,'the reportable quantity level for vinyl chloride is one pound- This level is applicable regardless of \ the environmental .. medium, (land, air, water, ground water) into which the pollutant is discharged.-This is the limit the tJEQ basset forthe plants to tgpprt An emission. 0000*225 vvv o exposure fcsha fa air IftfM ta the ]Atoofom+*a*mHBmiords zjfshe Workplan, *OverJOcescfof L Handbockcf.TdJdc ottd Hazard- magiiwarrwmanfthe } oau CV*tfaais.*lbe federal MMtt*' : ratpormd -among `44njii.-Rlieride i ird for nponn t. viRjl tlM arts* fonhofl partpersaUUopever iothMr period.audecettggdf* rpolymerization workers p tha Deited States and nine other nations. Because this tumor is extremely t bpm averaged over a period mot exceeding K minutes. The Chemical is absorbed both through InhiUtioa , add 'akin absorption. * 1 4 rare, the occurrence* of these cases under similar occupational condi r tions strongly suggests a casual relationship to some phase of vinyl chloride production^ Clinical fea \ According to the Handbook of tures of seven patients with the car Toxit+nd Hpurdem hpmlcnls cinoma varied from no signs or edblHlaonlen associated with - symptoms to weakness,. pleuritic vinyl chloride include: ecfOOsteofcr* pain,abdominal pain, weight loss, s, Raynaud's phenomenon, and sclerodermatous skin changes. Chronic exposure mayaho cause hepatic damage.- * ; Vinyl chloride a tt|ardai as a human carcinogen ; > af>da cause ofangoomreoma ofthe fiver. Excess cancer of tbe fung and lymphatic . and nervoassystearihasahobeen reported.Experimental evideheefcf tumof induction in aVarietyof organa, including fiver, lung, brain and kidneys, as well as nonmalig- nant alterations such as fibrosis and connective ''tissue deterioration indicate the mntUsystem oncogenic nad .toxicologic-effects of vinly chloride. . In agreement a book, called Chemical Hazard* of the Work place by Nick H. Proctor. PHD, toxicologitt and James P. Hughs, MD explains that there is an increased incidence of malignant tumors, weroosseotyu, Raynauds . syndrome, acerodenna,' thrombo cytopenia,* circulatory -dhtnrban- . ces, and unpaired liver function; very high concentrations causecen tral nervous system depression, - v associated with theintake ofvar ied amounts of vinyl cMoridd., Radiologic findings in patients with acroosteofysis iodtidak lytic lesions in the distal phalange! ofthe hands. In the styloid processes of the ulna and. radius, aod'in the 'gastrointestinal bleeding, and hepatosplenomegaly; liver function abnormalities were: present in all subjects but without a consistent pattern. In addition to. the malig nant tumors,, four-cases of nonmaligoant hepatic disease character ized by portal fibrosis and poifal hypertension have been attributed * to vinyl chloride exposure." Continuing inthis publication. - the authorJists symptoms end signs 'of exposure as> "weakness pleuritic `pain, abdominal pain, anorexia, r* weight loss, gastrointestinal bleed ing; hepatomegaly, .splenomegaly; . Raynaud's syndrome, lesions in the distal phalanges of the hands; cen tral nervous system depression." 'Numerous publications sop ported this fact, that vinyl chloride exposure causes cancer of the liver or angiosarcoma, including a pas sage in Mutations. : Cancer and Malformation which listed a key brent in which workers in numer ous countries showed an increased incidence ofangiosarcoma. . . Angiosarcoma is a very rare dis order ofthe liver. I have also found evidence that vinyl chloride exposure'clearly produces gene muta tions and.primary DNA dahtage. Reference was made to problems in .genetics and chromosomal defects in relation to exposure. sacroiliac joints. -Of 20 autoclaive DHHR has not yet compiled any workers with exposure lo vinyl Statistics that they would release on chloride, 16 bad thrombocytope the birth rate in the St. GabriaJ nia, aeven had splenomegaly, six area, l am presently awaiting those had hepatomegaly, 14 had Hbrosis statistics along with statistics on of the liver capsule and Tour had incidences of cancers "and other signs of acroosteolysb in one study related material . from an area : in this same publication : . ' The passages made reference to numerous other disorders found in workerswfVCM plants. Including -ear ainUf fkidi MTfktKMT . ncroeateolyaa, {degeneration rdf , tirimmal phalanges)..,V : t VVV 000004226 \ According to .Ton SaDe^cr, Director 4f th* StataCeaU* far Heafcfc Statistics, fc 1962 IbervOe . Mh averaged afightly over dm stale overage for atilt bktlx fan ` the yean 190-1966 Iberville w aligWy Rader the state average far stfil births, and in ,1966 aooe of . those cases reported came from St. |V GabricL . ' According to those -women 1 . spoke within St Gabriel, fristincc* | of miscarriage and stiD births we -- Shaw BilUmgef*! wA i . cate. One of these wosnea said that ' - from 1963 to 1985 out of 17 preg- i. nancies there were 15 miscani^s , and one five birth. ' Several of the women went on to have childreo later but had to hare progesterone (a female hormone) supplements during their pregnan: cies following their miscarriages. > None of these women had any instances ofthis type of complica* lions with childbearing in their famr ily histories. If this is indeed fact, we may find . reasoning behind. these occurren ces, -and-'that reasoning may not , necessarily be those chemical emis sions between the. years of 1983-45. . The evidence 1 mentioned briefly , before , concerning genetic - and ! chromosonal damage after expo sure has opened up another field of - investigation. The-question of'the '. generation before this one's expo; sure ntiw arises. Their parents. many of which lived ;in the -area 1 , years ago-when limits set on vinyl chloride and other hydrocarbon emissions were not as strict as they I ` are now; could possibly be the ones who's intake was too great. This theory 1. will try to support | with more research, but to begin 1 | quote from Mination. Cancer and f Malformations, "Only dominant j -mutations and certain chromoj soma! defects will have clinical effects in the first generation. The 1 persistence of mutations depends upon the biologic fitness of the phenotype. If-.carriers of a given mutation have no offspring because of lethality or infertility^ the muta tion will only persist for one genera tion. Mutations of the heterozygote type will.be similar to that of nor mals.' Such mutations will persist for many generations." [' in addition to the information I presented in this article,! have docamented evidence of releases of Chlorine and other hydrocarbons , and theireffects on the human hody ~--and the-enVfronmetit -which i will :.. present with further research at 1 laierdate. . *Z?*OGOGO AAA mma <n Xmp x* ^ mpjog 9q> n IP*' S| Oad P9mm ag. Tpapo opp^ .*puTO IS TM PWpW: TO* *q psau wopwab item ap 09 uimr 00 fcpw* Q99q a| . oau m9N}aii|bimpipoo^ ^ . 1 ./'V--: pw tsojnof jajvjLSsHuupjoqnx * .-. - `^jaafaucqnio* p kpm aimpwojp . 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