Document 2JJE2R024XeJDRjOKdnd7YmLb

JUSTIFICATION FOR VARIANCE FROM THE REQUIREMENTS OF ?9CFR 1910.93Q RE: RESPIRATORY PROTECTION FOR WORK ENVIRONMENTS CONTAMINATED WITH VINYL CHLORIDE Medical Division wishes to address itself to the full fficemssk requirement of the above mentioned standard. Total credence is given to the use of protective respiratory equipment in s VCM contaminated environment. Protection of the individual should be carried out to the fullest extent but to the exclusion of Introducing any other safety or health hazards to that employee, Conoco Medical Division st this point takes issue with the requirement of the full facensssk. We as a corporation have placed employee safety ahead of operating costs long before a law like OSHA was ever enacted. Jn keeping with this line of thought it is appropriate to question t?ie justification for s full face * as opposed to the potential hazard* created by Wien the half faperasule <*n ^ the fitBnd"*rd Points of discussion: 3. Restricted vision - the use of the full face cannistet mask greatly increases the likelihood of Injuries doing tasks which require a maximum amount at peripheral vision such as working at elevated positions and operating industrial powered vehicles. This justification is non-technical, simple, and straightforward ana needs no definitive elaboration. II Impaired visual ecuity - any employee whose vision in impaired whatever reason can not only be o safety hazard to himself but depending on the nature of the specific operation'in question, ht be a hazard to numerous other individuals. a) Fogging of the facepiece can occur for numerous reasons. 1) Hie exhaled breath is quite high in humidity. Variable external climatic conditions and geographic locations c<n result in repetitive fogging* 2> C O-->weat moy cause fogging of the facepiece or actual optical distortion from the sweat droplets running off the inner portion of the fscemask* .. b) Employees' with corrective lensos will demons trate 1c h nT> r - t ban their corrected vision If the vertex distance between the eyes and the lenses is greater than four diopter**. The ver :*x distance must be within two millimeter* feeforn and aft to maintain a correct refraction of any refraction over four diopters. /.vvvv r*.V//yV. -* / -- v f( S' X VAB.0001042304 * Dave Kuhn March 18, 1976 Page Two In addition, any employee with a cylinder refractory correction over one diopter can demonstrate visual distortion if the facez&ask become# tilted on the eoiployee*s face. Not only Is the distortion a problem but systemic systems since as a motion sickness type syndrome may develop if the glasses within the shield are tilted on an individual with more than one diopter correction. Such signs include nausea and/or vomiting, dizziness with or without headache. Reasonably critical tolerances of corrective lenses Ku&t be maintained to avoid refraction distortions. Such tolerances cannot be aaaured with e full face mask. c) Surveys have demonstrated that the incidence of chronic obstructive pulmonary disease in tables over the age of 35 runs approximately 32%. The wearer of respirators suffering from chronic cigarette cough, bronchitis, emphysema, and chronic asthma is a reality which must be given consideration. Although these people may have sufficient early disease that would not prohibit their working in such an area, having to cough quite frequently creates practical problem within a full facemssk. The employee with a cough or frequent sneezing can either temporarily fog his mask during coughing or permanently spray the inner portion with mucoid or purulent exudate which could temporarily limit vision. III. Dermatologic problems -- sweating is a normal physiologic mechanism for the body to dissipate heat, of the anatomical body areas whe t sweat first forms is across the forehead The wearing of the full air^purifying device can reasonably be expected to result in increased dermatological proble? in and around the vicinity of the eyes because of this phenomena The opening of the pores in sweating likewise contributes appreciably to skin sensibility. Numerous Individuals have low grade allergies to toiletries, etc. Many allurgies nrc first manifest around the eyes because of the thinness and sensitivity of the skin, fhusly, the introduction of contact allergy or enhancement of existing allergy will result in periorbital annoyances such as itching and blepharospasm which adds to the general distraction and discomfort of an employee. This is not to include in severe eases the compensable lost time from th% job until such symptoms subside. individuals with oily skin who tend co have comedo, blackheads, or pustular formations will have increased dermatologic problems over this area. Some microabrasion and trauma of the skin over the pressure surfaces of the facemask about the forehead is unavoidable. This too can only perpetuate pustular skin disorders. VAB.000104 Dave Kuhn March 18, 1976 Page Three In conclusion, It is wy fins opinion the many physiological contraindications which have been outlined resulting from the use of the full facc^ssk as opposed to one covering just the south and nose justify the sole use of lb*? half face mask. The exposure to vinyl chloride is not increased whatsoever by using the half fecentosk. Although employees are instructed to leave the exposure area if adjustments need to be made relative to their fresh air equipment, ye must be realistic in realising that when a man is at a critical point of his operation, in all probabillty he will finish the job and then correct whatever problem exists with his fscemask; should this problem be restricted vision, the ha card is quite high and an accidani might result, We consider this use of the full facemaak in thi situation unjustified snd in addition it serves as a potential serious safety hsy-axd. May our zeal for good work practices not be bogged down with regulations that create second level hazards. Charles L, Whetstone, M.D* Assistant Medical Director rift +r -*,F ^ J J- _ ^^vwv##w r J- -i" -r -* v-V J' / / / ^ ^ _r> j- * r r ^/V/V///// -* -* W- -< -* VAB.0001042306