Document 2JvgLxxbYL8DBVqY43XgjX225

J T0 DR. R. S. BRQOKMAN SUBJECT INTEROFFICE DATE FROM November 4, 1974 R. A. PARK REFERRING TO LETTER OF "VCM - THE PROCESSOR'S PERSPECTIVE" SIS RETEC October 31* 1974 November 1, 1974 X attended subject conference In New fork City, As preparation for this meeting, I collected questions to be asked government representatives from the chemical plants in fbttsto'.m, ftsrryville, your QRC Meeting letter dated 10/21/74* plus my own questions raised during my examination of the standard. Unfortunately, the large attendance at this RETEC (over 96o, un official count from 3ET3C Chairman) prevented me from directing these questions to appropriate speakers. The RSE3C Chairman promised to submit them in writing to the speakers and have their answers printed in the "Post Print4 book, which will be mailed out at a later date to those attending the RETEC. A copy of the original program is attached (Attachment A). We were told that the program was changed as per Attachment B due to the "press of business" preventing the OSHA representatives from attending. As a substitute, a conference call vas set up between the 0-SHA office and the RETSC meeting hall with both Cvnvsrsatioos carried on the FA system. Attachment C cites the exhibitors who displayed quipnont. Note that only two companies are cited as supplying "respiratory equipment", i.e., 3M and MSA. MSA was tlie only company displaying masks. I collected literature from xhlbitors which furnished product data. These brochures are available for perusal. Using the program as an outline, X will cite what X felt were the highlights of this meeting. I. Keynote address by Richard Fleming (V.P. Chemicals Group, Air Products & Chemicals, Inc.) - "What is the ^inyi Chloride Monomer (VCM) Problem?" Mr, Fleming's talk was a review, familiar to us all, with respect to the history of the VCM problem. He quoted the IDS report as recommending: 1. No detectable VCM level as impracticable. 2. Ten to fifteen (10-15) ppm lower limit for polymer industry. 3. Area monitoring. 4. Phased requirements to lower levels. He then stated that OSHA even ignored IDS with their final standard. This new standard has the following discrepancies with respect to respiratory equipment: 1. NIOSH has granted approval only for the "over 3600 ppm" apparatus. 2. NIOSH has not approved cannister masks. 3. NIOSH has not approved portable bottl masks, 4. At least six months will be required by mask suppliers to go into production after approval is given. 5. Not everyone can wear a mask. OCC 0997 Dr. Fleming stated that OSHA can give waivers, if they want to] 1 -2II. Or. Paul Lobo (Tenneco ) ~ "VCM & PVC Re3in Manufacture" Dr. Lobo cited various techniques for VCM and PVC production. He stated odor detectable levl for VCM was 1200-2000 ppm. Low molecular weight resins have about 200 ppm. Pilot Plant work at Tenneco was able to achieve o> detectable levels, but production capacity and product quality suffered, thus cost would go up. He closed with the statement that "PVC manufacturers will reduce VCM levels to the no detectable levels, thus save the fabricators from the VCM problem". III. Frederick Sacks (Diamond Shamrock) - "VCM Prom Resin Shipment Through Fabrication" Mr. Sacks related lab studies with respect to resins and pellets. He said they range in VCM levels from 1 to 1500 ppa. In the lab it takes seventy-tv (72) hours storage for an equilibria level to be reached for resin; over thirty (30) days for pellets. The pellets are ten to twenty times lower in VCM than resin however. Hie showad curves of these relationships as follows: OCC 0998 ia majdjmm figures ha oited 73 ppa VCM in pell t bon; 9 pjm in warehouse. I -3- IV. Gerald L. MeCoWin (IDA) - "VCM - The IDA Viewpoint" Mr, McCovin related that VCM must became a food additive before IDA can become involved. He cited the 20 ppm VCM recently found in liquor from FVC bottles. Although VCM is a known carcinogen from inhalation, its behavior when ingested is unknown. IDA has five courses of action it could follow: 1, Maintain status quo. 2, Place limitations on VCM in articles by end tests, 3, Place limitations on VCM in food contact alone. 4, Place limitations on VCM that can be extracted into food, 5, Ban PVC. Courses & and #5 have been rejected. Numbers 2, 3, and 4 are still being re~ considered. Date and form of proposal are currently unknown. An interim regulation is being proposed. Animal feeding studies will be required. Drug and cosuetic area will also be affected. Twenty (20) pp billj on accuracy can be obtained in VCM measurements. Since water is food, potable water pipe may be involved. He stated that thin coatings were not of concern. Water pipe being much thicker could present more VCM contact. Low temperatures and short contact time are factors in favor of a higher VC level. V. den E. Schweitzer (Director, Office of Toxic Substances, EPA) - "VCM - The EPA Viewpo*int" "Health problems will continue to be evident in the next five to fifteen years due to incubation or latent periods... Other probloa chemicals will cone up." Note: Copies of his paper were available, but only given out to members of the press* Mr. Schweitzer reviewed the VCM-EPA position. He related how he made a statement that the VC pestiside sprays were of no danger. live days later the agency did an "about face" because tumors were possible in mice at 50 ppm; VCM remained in the air for a significant period of "time; FDA recalled VCM food sprays. He cited sene of their problems such as: May, 1974: VCM monitoring data collected in New Jersey indicated that levels at the plant fence line were one half the level of the site 25 miles distant. June, 1974: Clean Air Act required action, yet MaltoxxL data showed 50 ppm V(M caused AGS In 3 rats. These rats, however, lived longer than the controls. July, 1974: Economic impart surfaced. He stated that for the 90 seconds he was on CBS VCM shows, eleven CBS personnel were in his offioe for 2 hours (with cameras, lights, etc.). He did not have a say in how they edited his cements. With respect to the fabricators, they will have to consider 1. VCM in effluent waste. 2. Breathing dust. r\r^^ '-''-C 0999 I -4~ They have data to indicate few people exposed to high levels are equal to many people exposed to low levels. At this time, EPA has no basis to establish a VCM level standard for fabricators. Disposal of FVC products by burning and incineration is being studied, EPA is establishing VGM standards for VC and PVC plants. It will call for the best available control technology. Whan controls are in place, 90 dp billion highest levels anticipated for VC and PVC plants. Monitoring data will be obtained by EPA. He reviewed the recent EPA paper issued in September (?). Medical surveillance outside of the plant may be an industry requirement. More aggressive monitoring outside of the fence line may be required. He complained that industry has not started very low ppm VGM level studies (toxicity) to date. We will also need studies requiring VCM reactivity by products. According to Mr, Schweitzer. VCM levels in resin should be a part of the buyers spec. In August, 1974, at finehurst, N. C, many chemicals were discussed by government agencies. The World Health Organization is discussing flame retardants and plasticizers. A Toxic Substanoes Act is currently being considered by Congress. "Industry must recognize health risks before government gets involved, i.e., "Head them off at the pass"." A few questions were asked frcn the floor. Question: What is a safe level of VGM? Answer: We don't know. Any at all is some risk. Bisk must be balanced against vnat we are doing. Question: OSHA tells us to vent VCM out of the plant. What does EPA say about this? Answer: I doubt that OSHA recommends this. EPA talks to OSHA frequently about this. (Why do they talk about it if OSHA does not recommend it?) Question: What is the cost of reducing levels at FVC plants? Answer: $2,000,000 for 100-200,000,000 lbs./year plant; $80,000,000 for the Industry as a whole. September, 1975 is the target for EPA Standard. Question: Does SPA intend to regulate air emusaion regarding cigarette smoking. Answer: A special law covers tobacco; therefore, SPA does not become involved. VI. Dr, B. H. mn (NIOSH) - "Determination of Vinyl Chloride in Workplace Air" Dr. wm explained that NIOSH is a research organization, i.e., it has no enforcement powers. OSHA is a regulating agency and has enforcement powers. occ 1000 I -5- He described work dene vith solid sorbants (charcoal, silica gel, porous polymers). He recommended charcoal tube type using activated coconut charcoal. Precision @ 1 ppm was 7.54$. & 50 ppm was 7.45$. A copy of this test method can be obtained by writing for Test Method P & CA 17S, Office of Technical Publications, NIOSH, 1014 Broadway, Cincinnati, Ohio 45202, VXL. OSHA Conference Ca^l At New York City end of phone was Joe Darby of Monsanto. At 03HA*s end were Dr. Grover Wrenn, Chief of Health Standards Division, Dr. Don Lassiter, Special Assistant for Health, and Ms. Ho Ryer, Industrial Hygienist, Offioe of Compliance Program. Dr. Wrenn started by saying that "because of litigation, they won*t discuss the rational of the standard or decision making process. The following questions and ansuers were noted: Question: What is new from OSHA? Answer: More medical surveillance data are available. Vinylidene chiarid is now a suspect. There are 26 AGS deaths recorded worldwide. Answer: OSHA admits that the standard is a poor instructional tool. They recommend that the SPE get Involved in this area, (Implied - No help from OSHA.) Question: Will data collected in 1974 under TPS be acceptable for regulated area of permanent standard? Answer: Yes, if methods are accurate enough (sensitivity of 1 ppm). Question: What advice would you give with respect to a 5+ ppm area where no people are involved with respect to monitoring? Answer: No people, no problem. If people may be involved, it would be prudent to monitor. Warning signs are mandatory. Question: Our overseas plants are allowed higher VCM levels. Your eomnents? Answer: USA leads the field except for animal experimentation. Through labor attaches in other nations, they will probably follow. Question: Will processors'monitoring data taken by OSHA be published? inswer: No. It will not be made public except in stmmaxy form. Question: What technique ean be used to calibrate and measure 0.5 ppm as required for "Action Level* in the standard? insuer: N restriction regarding method is mad in the standard. It is left to the employer to M it right". OCC 1001 -6- Question: When charcoal air samples are used, what is the mininnjn volume of air that must be used for 8 hours? Answer: Not specified. It depends upon the technique, OSQA will soon publish smpling data sheets for their employees. There is no duty to use NIOSH or OSEA techniques, i,e., it is up to the employer. Question: Is continuous monitoring sufficient to replace all other monitoring (TWA, ceiling, etc.)? Answer: Procedure preferred is personal sampling, although other systems are acceptable if it tells the employee exposure. In effect, OSHA is saying (again) it is up to the employer. Question: Is there a residual VCM level where labelling can be discontinued? Answer: No. Question: Regulated Area: Is it based on TWA? What if area above extruder is over 1 ppm? Answer: Two conditions (both) must be met: (l.) VO or FTC is manufactured, reacted, repackaged, stored, handled, or used, and (2.) VG concentrations are in excess of the F2L. Question: If VGM level is over 1 ppm in the warehouse, what precautions must ATMr*r,*r**^ --Lf* 1 4****m/*?*^ *- ^ v ** VY--- * W Answer: This question should be submitted in writing; they will answer in writing. They won't answer hypothetical questions. The audience in New Sort: City was very unhappy with this response* Question: In post operations on FVC (themoforming), is a "Regulated Area" required? Answer: Same as above. But under further questioning they stated that heat sealing and thennofoxming does not come under "mass melting". Question: How do you determine accidental exposures over 15 minutes limit? s Answer: It is up to the employer to pick an adequate method. NIOSH manual, due to be published next year, might help. Question: Do medical records of a person changing employers In the industry follow him? Answer: lea, the medical reoords follow if the employee requests. Question: If the employee goes from a regulated area to an exempt one, does the new employer have to continue medical surveillance? Answer: bility. A new employer in an xempt industry has no medical record responsi OCC 1002 7- lt this point, time ran out. Sixty additional questions will be sent to the OSHA personnel, and hopefully, their answers will appear in the post prints. The OSHA people gave the REIEC audience a very poor opinion of themselves by refusing to give over the phone the address where additional questions could be sent. It was announced at this time that the SHS is conducting a VGM low level analysis Round Robin. Companies interested should contact Ron Richard through the SPE's Analytical Division. VII. Dr. F. M, Zado, Dr. J. 0. Rosmuson ( Western Electric Research Center) "Monitoring Methods for VGM at Western Electric" Work regarding monitoring studies were centered around 1. Raw material shipping areas. 2. Raw material storage areas. 3. FVC processing areas. 4. FVC finished products area. Comments; Direct outside monitoring by automatic Gas Chromatograph with Flame Ionization Detector (AGC/FED). Reliable; sensitivity meets standard; can he modified to measure other gases* Their unit uses a stainless steal tube with Carlosieve B. VC encapsulation tube gave 1 ppb reading. Very expensive equipment. Good to 1 ppb levels, 10055 recovery. VHI. R. Lancaster (American Can Co.) - "VGM in FVC Resins, Compounds, and Extractants A Can Makers View" . GC/F3D used food simulating extractants. In can coatings, no detectable levels. II. P. A. Wilks (Wilks Scientific Corp.) - "tordtorlng Anbient VC With Infrared IK analysis is sensitive to 0.2 ppm when using a 20 meter cell. I. B. A* Denebberg (MDA Scientific Inc.) - "A Continuous Monitor for Vinyl Chloride Monomer, Baaed Upon An Impregnated Paper Tape" Mr, Deneberg described a device manufactured by MDA that is sensitive to 0.01 ppm of VCM. It has a running time of 168 hrs, per cassette* It is Influenced by TCiE and other halogenated compounds* OCC 1003 I -- Otto-White (Q3HA) - "What Happens During in OSHA Visit" At the request of OSHA, no mention was made of VCM in the title of the paper given by Mr. White, Note: OSIIA has no jurisdiction in industries protected by other agencies, i.e,, atomic energy, coal mining, etc. Several emergency standards have been promulgated by OSHA. These include standards regarding asbestos, pesticides, carcinogens, and VCM. iTiorities are given to: 1. Imminent danger. 2. Catastrophe (defined as 1 fatality and 5 injuries). 3. Complaints, 4. Target industries (where industry injury rate is twice the national average). 5. Higher risk target industries, i.e., asbestos, lead exposures. No advance notice is given: 1. Visit by Industrial Hygienist or Ccmplianoe Officer, 2. Visitor will meet with top management to relate purpose of visit, 3. OSHA will not tell who made the complaint, 4* Union representative will accompany OSHA visitor on a plant inspection, 5. Visitor will review acoident records, 6. Alleged violations will be recorded, 7. Exit interview with employer will be held for the purpose of explaining alleged violations and abatement program, 8. Abatement date will be determined at this time, 9* Notice of violation (and possible penalties) will be stated in wilting, 10, Jjurcfion (1*5) days are available tor appeal or vioLardons to area diracr.or, 11. After fifteen (15) days, violation goes before the Review Commission, i.e,, the courts, Mr, White stated that there is no relationship between a call or letter to OSHA for information and an OSHA visit. Questions to OSHA can be addressed to Dr. Daniel P. Boyd, Room 610, 1726 M St. NW, Washington, D, C, 20210. III., Paul A. Ketterer (Tesneco Chemicals, Inc.) - "Vinyl Chloride Analysis In JVC Processing Plants" Based on Mr. Ketterer*s work, teflon bags were superior to charcoal tribe _ techniques. XUI. Mr. David D&rviek (ICI) - "VCM - Current European Status" Mr, Darvick related the following: 3*500,000 tons of FVC/year are produced in Western Europe by 35 polymer producers. Before 1955, 1,000 ppm VCM levels were normal. Nov, they axe below 50 ppm. Limits now in nee are V, Germany Holland Italy Sweden Great Britain Norway 50 ppm maxima plus as low as possible target, 50 ppm maximum. 50 ppa majdLmua. 20 ppm, but expected to go to OSHA standard, 50 ppm + 25 TWA. Suspended production until a government committe filed, Ii I report is OCC 1004 9- Ha doubts if OSHA levels will be used by Europe, except the levels stabli3bad for processing plants, VCM currently found in Europe will be reduced 25 percent soon, European studies indicated that hot powders release VC more readily than hot melts. Highest figure found in tbs United Kingdom was 4 ppa in the processing plant; the average was 2 ppm. The warehouse was in excess of 2 ppm. Dry blend ciixBr3 are high VC level areas, A 50 ppb level of VC will be established next year in Sweden, XIV. R, Voisard (Scott Aviation, Div, of A-T-0, Ine.) - "Respiratory Protection for Vinyl Chloride Monomer" Hr, Voisard started his talk by saying, "I am not here to sell you respiratory protection equipment, the government has already done this for me". He gave an outline of protective masks, similar to that which I have seen in the literature. Therefore, I will not repeat it here. He did mention that respirators such as listed in 1910.93q (g) (4) (ii) Type C did not exist. He commented that it takes an average of 9 months to get NIOSH's approval for masks; therefore, it is doubtful If additional types will be approved before the new standard goes into effect. XV. Karl Oelfke (Dow Chaaical Co.) - "Respiratory Protective Devices and Protective Clothing Used in VCH Manufacture" Mr, Oelfke stated that the latest VC plants, even in the north, are open. Tank oar gauging and disconnecting hoses were main problem areas. Dow is using air supmy respira'Gors, He aoes not know if any carmister type mooei a ha-we bean approved, XVI.Dr, Maurice Oberg (LIE Environmental Systems) - "Protective Techniques for VGM In Mixing and Extruding Operations" This paper was the most naive paper I have ever heard. It is doubtful if he attended any of the other papers presented. His simple solution to the problem was to "order resin with low VCM content". If you do have a VCM problem, then ventilate (EPA ?). His abides were illegible. In my opinion, he is IDS material.' XVII. Dr. Mark (Weraen-Fflelder Corp.) "Controlling and Reducing VCM Content In FVC Formulations Through Advanced Compounding Techniques" "Resin3 for dry blending purposes are currently supplied in the 20 to sev ral hundred ppn VCM range." If the VGM is removed in the dry blend mixer, it will diminish VC problems in the process plant. He described Wemer-Pfleider' s air intake-exhaust vent system. Air can be blown in through roto shaft and mixer blades. He showed curves of VCM vapor pressures that Indicated that it is more difficult to remove Vdl from the hot melt than from the dry blend (Flory-Huggins) vapor pressure considerations). Heating cycles were increased 10 percent due to the addition of 25 cfln of cold air to the extruder, XVIII. Dr, Daniel S. DixLer (Keller & Heckman) Dr, DixLer susmarized the meeting as follows: OCC 1005 10- 1. Stay below "action level" and you will gat out from under additional controls, 2. Available respiratory equipment is uncomfortable and bulky. Much better equipment is not approved, 3. lubricators should not have a problem, i.e., if FVC can be manufactured at a cost we can afford. Miscellaneous: X asked the Century Systems Corporation personnel if a model 98 can be adapted or converted to a model 118. The answer was no. Model 98 is a log readout type while model 118 is linear. RAP: sip R* A, PARK OCC 1006