Document 2RnwxrnvEoQ9LrBVO0Bb53Y2N

OxyChem Vinyls Division Safety and Industrial Hygiene Program Status March 1991 * OCC 10315 Vinyls Division Industrial Hygiene Program Status March 1991 Table of Contents Tab 1: Tab 2: Tab 3: Tab 4: Tab 5: Tab 6: Tab 7: Safety and Industrial Hygiene Summary VCM Health Effects Statement OSHA Compliance Status Plant Summaries Questionnaire Executive Summary Pasadena Plant IH Survey OSHA STAR Recommendation VCM Task Force Hazard Potentials by Plant Plant Summaries Worksheet Example Corporate IH Database Example 1991 Industrial Hygiene Plans Plant Status Memo Requesting IH Plans Major Issues Divisional Summary Plant Summaries OCC 10316 # OCC 10317 IT OCC 10318 Statement on Health Effects of VCM Kenneth A. Mundt, Ph.D. September 10, 1990 Vinyl chloride monomer, or VCM, is used in the production of polyvinyl chloride (PVC) polymers. Several OxyChem facilities produce VCM and/or use it to produce PVC. Before 1960, VCM was thought to be safe, even at moderately high levels, as reflected by an exposure limit of 500 ppm. In fact, VCM was evaluated for possible use an an anesthetic for surgery. By the early 1970's, however, evidence was gathered which suggested that VCM might be hazardous at high levels. For example, it was discovered that some of the employees involved in cleaning the polymerization vats used in the production of PVC developed a condition in which the bones in their hands degenerated (acroosteolysis). In 1972, evidence of liver damage among exposed employees was observed with VCM levels over 300 ppm, and in 1974, studies demonstrated an association between high levels of exposure to VCM and the occurrence of a very rare liver cancer, called angiosarcoma. Most cases of these conditions were observed among those who had worked for 10 years or more in the most highly exposed jobs, especially the polymerization vat cleaners. As of January 1, 1981, the Occupational Safety and Health Administration (OSHA) standard for exposure to VCM was changed to 1 ppm. Numerous studies have been conducted to better understand the possible health effects of VCM. To date, the only clear association between VCM and cancer is that of liver cancer, including angiosarcoma, and the OCC 10319 Statement on Health Effects of VCM Page 2 excess risk appears to be limited to individuals sustaining prolonged exposures to VCM levels of 100 ppm or higher. A worldwide registry of occupationally-related cases of angiosarcoma has identified 157 cases, occurring between 1955 and 1990, out of an estimated workforce of 2.2 million potentially exposed to VCM. Among these cases, the average duration of exposure was over 15 years, and the detection of angiosarcoma occurred, on average, 20 to 25 years after the first occupational exposures. The United States has identified 39 of the cases to date, and 29 of these were associated with employment during the 1940's and 1950's in one of three plants. New cases are becoming fewer worldwide, indicating the effectiveness of the low exposure limits in preventing this disease. At present, there is no evidence, despite several toxicological studies (in animals), that VCM can cause birth defects. To date, there have been no human studies of reproductive effects. I believe that employees in OxyChem's VCM and PVC plants and the members of the surrounding communities are protected from the possibl. adverse health effects of VCM, primarily because of the lower exposure limits. OCC 10320  OCC 10321 Plant Summaries OCC 10322 Facility Addis* Burlington North* Burlington South* Pasadena Pottstown Salisbury Total OSHA COMPLIANCE MINIMUM PROGRAM REQUIREMENTS P & P Vinyls (% Completion) Haz Com 92 92 92 100 85 100 94 Respiratory Protection 74 62 91 100 88 96 85 Noise 86 87 100 100 93 93 93 Chem PEL 85 75 92 100 75 83 85 Substance Specific 100 100 100 100 75 0 79 Medical Notification 86 100 71 100 100 100 93 Total 87 86 91 100 86 79 88 occ 10323 * Self-assessment Questionnaire INDUSTRIAL HYGIENE QUESTIONNAIRE Facility: Prepared By: Date: OCC 10325 Industrial Hygiene Questionnaire Facility: ______________________ Page 1 I. HAZARD COMMUNICATION All plants must have a written HazCom program in place which addresses container labeling, material safety data sheets (MSDSs), and training. All new employees must be given training within 30 days of hire and before being assigned to work with hazardous chemicals. The written program should be reviewed annually and signed by the facility manager. The following items are designed to insure that your facility is in compliance with the HazCom standard. YES a. Do you have an up-to-date chemical inventory? b. Do you have a written hazard communications program? c. Has there been a hazard determination made on all hazardous chemicals? d. Has everyone been trained in the hazards and properties of the chemicals he/she works with within 30 days of the introduction of the chemicals? e. Does this training include target organs? f. Are all appropriate containers, tanks, etc. labeled? g. Is the H M IS labeling system used? h. Are these labels in good condition and legible? i. Do you have an MSDS file that is up-to-date and readily accessible? j. Is there a designated individual responsible for assuring that workers are informed of MSDS changes/additions that results in a new hazard being introduced into the workplace? NO OCC 10326 Industrial Hygiene Questionnaire Facility: ______________________ Page 2 I. HAZARD COMMUNICATION (Con't) k. Is there a procedure in place that requires the Purchasing Department to request and receive a MSDS on all new chemical purchases? l. Is there a tracking system for new chemicals to assure that they do not leave the receiving dock until a MSDS has been received, reviewed and distributed to the appropriate departments? m. Do you have a procedure for informing contractors about the chemicals on site? YES _____ _____ _____ NO OCC 10327 Industrial Hygiene Questionnaire Facility: Page 3 II. RESPIRATORY PROTECTION If the facility uses or provides employees with respirators of any kind (even nuisance dust disposables) or emergency SCBAs (such as Scott Air Paks), the facility must have a respiratory protection program which contains, as a minimum, the following elements: YES NO a. Do you have a written respirator program? Is the program reviewed annually? b. Have the respirators been selected for the type of contaminant protected against? c. Have workers been trained in the use and limitations of their respirators? Does their training include: 1. an opportunity to handle the respirator? 2. having it fitted properly? Qualitative Quantitative 3. is the fit test current (annual)? 4. if asbestos is handled at your facility, is fit testing conducted semi-annually? 5. testing its facepiece-to-face seal (beard, glasses, etc.)? 6. wearing it in normal air for a long familiarity period? 7. wearing it in a test atmosphere? 8. is the training documented? d. Have respirators been individually assigned, where appropriate? e. Are respirators regularly cleaned? (This requirement does not apply to disposables.) Are they disinfected? f. Are respirators stored in a clean, convenient and sanitary location? OCC 10328 Industrial Hygiene Questionnaire Facility: ______________________ Page 4 II. RESPIRATORY PROTECTION (Con't) YES g. Have workers been instructed to inspect respirators for wear or damage including a leak check, before and after each use? h. Are monthly inspections of SCBA equipment conducted and records maintained? i. Is Grade D breathing air utilized for all supplied-air respirators? Is oxygen content checked? j. Do supervisors maintain awareness of possible changes in workplace exposure conditions and respirator effectiveness through frequent random inspections? k. Has each worker in the respiratory protection program been medically certified for ability to wear? l. Is his/her status reviewed periodically? NO OCC 10329 Industrial Hygiene Questionnaire Facility: ______________________ Page 5 III. NOISE - HEARING CONSERVATION There is no OSHA requirement for a written noise program. The regulation does require that we determine whether our employees are exposed at or above the "action level" of 85 dBA as an eight-hour time-weighted average (TWA). If they are, the affected employees must be given training, access to hearing protection and audiometric testing. Our practice has been to include all plant employees in the program if there are any sources of noise above 90 dBA in the plant. You should have an up-to-date noise survey on file to show the compliance officer. Noise surveys should be updated whenever new noise sources are added, or at least every two years. If indicated by the survey, dosimetry should be performed on employees in high noise environments. a. Has a sound level survey of the facility been performed to identify areas above 85 dBA within the past two years? YES ______ b. Are areas above 90 dBA posted with signs? ______ c. Are workers offered an annual audiometric exam? ______ d. Has representative 8-hour dosimetry been conducted on those individuals identified by the sound level survey? ______ e. Are employees given annual training? ______ f. Does this training include effects of noise on the ear, and the principles of noise generation? ______ g. Is a copy of the OSHA Noise Standard 1910.95 readily available for employees to examine? ______ h. Is proper hearing protection provided for identified employees? ______ Are employees trained in care and use? ______ i. In areas over 90 dBA, is hearing protection usage enforced? ______ NO ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ OCC 10330 Industrial Hygiene Questionnaire Facility: ______________________ Page 6 III. NOISE - HEARING CONSERVATION (Con't) j. Does the program include documentation of: 1. Area and personal sampling? 2. Audiometric testing? 3. Annual training? k. Is the documentation readily available? l. Is special training given to employees who have experienced a standard threshold shift? YES _____ _____ _____ _____ _____ NO OCC 10331 Industrial Hygiene Questionnaire Facility: ______________________ Page 7 IV. CHEMICAL EXPOSURE For all chemicals in your facility for which there are OSHA Permissible Exposure Limits (PELs) or Threshold Limit Values (TLVs), employee exposure should be determined or estimated. A listing of these limits & values may be obtained from Corporate Industrial Hygiene. Sometimes, a careful review of the exposure potential will result in the conclusion that exposure is minimal or non existent. In other cases, it will be necessary to actually sample to determine the extent of exposure. If exposure (without regard to the use of personal protective equipment) is above the action level (1/2 of the limit), then a program of routine sampling must be established, and an engineering solution investigated. Chemicals for which there are substance-specific standards (asbestos, formaldehyde, vinyl chloride, etc.) should be sampled routinely to generate sufficient data to allow exposure to be estimated with more confidence. (See section V.) YES a. If as a result of sampling an overexposure is believed to exist, have the individual employees who were monitored been provided with proper personal protective equipment? ______ Is its use enforced? ______ b. Is there an action plan to engineer out the source of overexposure? ______ c. Is ventilation checked regularly and results documented? ______ d. Have representative exposure samples been taken for all chemicals with OSHA-PELs or ACGIH-TLVs at your facility? ______ e. Are samples taken on a scheduled basis? ______ f. Are they representative of an 8-hour TWA? ______ g. Are area STEL and Ceiling samples taken? ______ h. Are employees notified of monitoring results? ______ i. Is there prompt follow-up on high exposures? ______ j. Is there proper documentation of: 1. Monitoring data? ______ 2. Sampling/Analytical procedures? ______ 3. Results ______ NO ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ OCC 10332 Industrial Hygiene Questionnaire Facility: ______________________ Page 8 V. SUBSTANCE SPECIFIC STANDARDS If your facility handles chemicals which have been specifically regulated by OSHA as listed below, the requirements of that standard(s) must be met. If there are any questions in this area, please call Corporate Industrial Hygiene. Substance Specific Standards have been promulgated by OSHA for the followin 1. Asbestos 2. Coal tar pitch volatiles 3. 4-Nitrobiphenyl 4. a-Naphthylamine 5. Methyl chloromethyl ether 6. 3,3'-Dichlorobenzidine and salts 7. bis-Chloromethylether 8. b-Naphthylamine 9. Benzidine 10. 4-Aminodiphenyl 11. Ethyleneimine 12. b-Propiolactone 13. 2-Acetylaminofluorene 14. Dimethylaminoazobenzene 15. N-Nitrosodimethylamine 16. Vinyl chloride 17. Inorganic arsenic 18. Lead 19. Coke oven emissions 20. Cotton dust 21. l,2-Dibromo-3-chloropropane 22. Acrylonitrile 23. Benzene 24. Formaldehyde 25. Ethylene oxide Have the specific requirements of these standards been addressed as to... YES a. Sampling to measure action level? ______ b. PEL, ceiling and STEL concentration? ______ c. Change rooms & shower facilities? ______ d. Medical monitoring? ______ e. Medical removal from workplace exposure? ______ f. Recordkeeping & training? ______ g. Is there a written program where required? ______ h. Have regulated areas been established and demarcated as required? ______ NO ____ ____ ____ ____ ____ ____ ____ ____ occ 10333 Industrial Hygiene Questionnaire Facility: ______________________ Page 9 VI. ACCESS TO EXPOSURE AND MEDICAL RECORDS OS HA regulations require that employees be informed annually that they have a right to see and/or obtain a copy of their exposure and medical records. Should an employee ask to see his/her data, we have fifteen days to comply. Requests for exposure data will likely be minimized if you discuss the results of any sampling with employees as they are obtained. The notification of right of access can be done by posting an appropriate announcement on the bulletin board, or by discussion during a safety or communications meeting. If you use the latter method, you must document that fact. Records are required by the standard to be preserved and maintained for the duration of employment, plus thirty years. a. Are employees informed annually of their right to exposure data and medical records, both past and present? b. Are employees notified of their personal exposure data as collected? c. Can you meet the 15-day time frame to supply requested records? d. Do the employees know of the existence, the location and availability of records? e. Do employees know the designated person who maintains these records? f. Do employees know of their right of access? g. Is a copy of the standard (OSHA 1910.20 ) readily available for employee examination? YES ______ ______ ______ ______ ______ ______ ______ NO ____ ____ ____ ____ ____ ____ ____ OCC 10334 Industrial Hygiene Questionnaire Facility: Page 10 VI. ACCESS TO EXPOSURE AND MEDICAL RECORDS OS HA regulations require that employees be informed annually that they have a right to see and/or obtain a copy of their exposure and medical records. Should an employee ask to see his/her data, we have fifteen days to comply. Requests for exposure data will likely be minimized if you discuss the results of any sampling with employees as they are obtained. The notification of right of access can be done by posting an appropriate announcement on the bulletin board, or by discussion during a safety or communications meeting. If you use the latter method, you must document that fact. Records are required by the standard to be preserved and maintained for the duration of employment, plus thirty years. a. Are employees informed annually of their right to exposure data and medical records, both past and present? b. Are employees notified of their personal exposure data as collected? c. Can you meet the 15-day time frame to supply requested records? d. Do the employees know of the existence, the location and availability of records? e. Do employees know the designated person who maintains these records? f. Do employees know of their right of access? g. Is a copy of the standard (OSHA 1910.20 ) readily available for employee examination? YES ______ ______ ______ ______ ______ ______ ______ NO ____ ____ _____ ____ _____ _____ _____ occ 10335 Executive Summary Pasadena Plant Industrial Hygiene Survey OSHA STAR Recommendation OCC 10336 Employee Exposure Monitoring at the Occidental Chemical Corporation PVC Resins Plant Pasadena, Texas I. Executive Summary Employee occupational exposures to certain chemical substances and noise at the Occidental Chemical Corporation PVC Resins Plant in Pasadena, Texas, were studied. Activities to accomplish this project included the following; * Physical inspection of the plant prior to the formal industrial hygiene (IH) survey, * Development of a comprehensive monitoring plan; and * Conducting an formal IH survey that included: Identification of employee exposure potentials to dusts, fumes, organic chemicals, and noise; 1 OCC 10337 Collection of air samples for chemicals, noise dosimetry, and measurement of area noise levels; Analysis of the air samples and noise data; and Evaluation of the sample results in relation to established criteria. Exposure monitoring representative of employee exposures in the plant was conducted for chemical substances including FVC dusts, welding and zinc oxide fumes, and organic chemicals used in the laboratories and solution preparation area. Air sampling was accomplished using OSHA, NIOSH, or equivalent methodology. Noise monitoring was conducted using noise dosimeters. An area noise survey of the plant was also conducted to provide data that could be useful in developing recommendations to reduce noise levels. Time weighted average airborne FVC dust levels exceeding the OSHA PEL were measured in the Dryer area. While dust levels in the FVC Loading area did not exceed the PEL, dusty conditions were observed for short periods of time. The high dust levels in both areas were caused by the use of compressed air to clean screens and magnets (Dryers) and the tops of rail cars (Loading area). Airborne dust can irritate or injure the eyes and obscure vision, and cause slipping on walking surfaces where dusts accumulate. The Dryer operator was using a single-use disposable respirator ("paper mask") for protection against the airborne FVC dusts. These respirators, although certified by NIOSH, cannot be fit tested with a challenge agent. As a result, the quality of protection is unknown. RiskFocus recommended that Dryer operators be fit-tested and issued a NIOSH approved dust cartridge respirator, and that alternate cleaning methods be investigated to reduce the dust levels. 2 OCC 10338 The results of the noise dosimetry revealed average noise levels that exceeded PELs in the Dryer, PVC Loading (including the rail car cleaners), Liquid Loading, the Bagging machine, and Recovery areas. These areas have been designated and posted as hazardous noise areas where hearing protection is required. Consistent wear of hearing protection was observed. The Dryer blower noise was remarkable in that the noise was 108 dBA and was a pure tone at 600 Hz. While past efforts to reduce the noise emission have not been successful, efforts are continuing. Continued use of hearing protection with the highest Noise Reduction Rating (NRR) in this area was recommended. The area noise survey confirmed where noise levels exceeding 85 dBA were possible and validated the posting of the hazardous noise warning signs. No additional recommendations resulted from these measurements. 3 OCC 10339 m OCC 10340 . VCM TASK FORCE Purpose The purpose of the VCM Task Force is to review current industrial hygiene procedures and work practices at each OxyChem facility where VCM is handled, and to recommend an effective, consistent industrial hygiene policy for those facilities. Scope The group consists of a representative from each plant, appointed by the plant manager, and Bob Adams, corporate industrial hygiene, who will act as team leader. The task group will use utilize written and telephone communications to accomplish their initial objectives, which are: 1. Review current procedures and practices at each facility. 2. Identify, prioritize and develop solutions to Industrial hygiene issues. 3. Recommend necessary modifications to existing VCM procedures and practices. At this time, the recognized major issues at the VCM facilities include: 1. Respiratory protection practices 2. Industrial hygiene monitoring a Monitoring methods h Frequency c. Area vs. Personal d. Task specific sampling e. Survey instruments f. Analytical methods 3. Personal protective equipment Status Only initial contacts have been made with the task group members. Currently, the project is in the information collecting phase. OCC 10341 OCC 10342 Plant Summaries Vinyl Division Hazard Potentials ^brlteatloi^ OT?#- iSM; IPottstown \wm rionoiitoo ,:-in imiiiii mumm itiiV 4 4|iJiU44 A - ]: ' i i; -l V Lv;!:: 4V mmmit itoMiiv i i : = -E'S - j ' 4 4 fV/;; : ; . 4-i : -M4" f ' 44 litiitfi! iilllflliMi Mid I L it '.5.VVX, Ars nlc mmmmMm rnmimm 1.1 i 11 <t aUiM-lLL V /: :> JV -iX $ , ;:4 ft4L. ift'Vi 4- i y 144 ! 1 i-iZH&zUi . - IHiMUm jV 4,4 dam; ' ? if 1 Lli'L J',.v '>. y. Vli \ 1.9]^ - } ' 1; : 1, . \dzM Li;; : `i ; ; ; . li Nl- umMnau :-x> j L -v'J : ;::4- :- V diMMMim U:-4::/4..44: 4l:4.4;4li:; 4 >i V iifititiifi MlllilMjl 444 L:L-:. sH ':'nM Vj : x . >;! ? i tiiillilS 1 mimum 4 4 -H'-'V' ;i;5is:yv 2-Mercaptoathanol M tats > X'.;- ; 4.:-: v- tumm. iiUUilm - >:*..-*:. :V*>i-.':, K>-;:`>; y: .^j;, : - ; : . 4 9N : i - - . : 44 -Li. 4 `kf<% <-' 4 V :: .< i:-.-": Li fe'-J' * -i..i i jV ;4L 44- = thyl Alcohol gWnyi ct|>l,1 IvftOftft ;4 V >J , :f ;: 4. -; \h* -: - V OCC 10344 Vinyl Division Hazard Potentials Chemicals ftift' f xi'-ft. t:X:- -::1 I: 5 V: Addis Burlington ?N4 Btirl)ngtb| &; Pasadena | Pottstown**; 2 Pottstown 2 Sslisburv 2 <Febtfcitiori i 1#8brtCa1foh 2 : jyj, ft fj :> -X.,-x- 2 Pabrlcatloni : Resins : Molybdenum IllHixiilntl ify Iflf II ft-fy`ft. Xx `;-|.--x_ v;- ftx- -X.;*: j :ftftvft :;ft- l'L'xi y- Xftfti -Xft ?: :M: V ' ;f ftlf. If II If 2HI 2 V. iji- X: V ;i ly X: ::| > i-i: : 1 - ' "Ai mmt 2 :22'f -i ,;y| ; N is* Nuisance Dust V XX;:: ftftfftt .fVXt-Xft. X:: .:HXfftt:',;-X.:x::f::t:: .: V isl; 2 \ ijf-. yi : V * iujmMi vsls ^ yy-c Organotlns Pltioisiim Ibiatiiiatj^i: f1 ttlii III iciii-- ^ ^- t kf:: ::-,2l!:. i: - : i 2 2? . ^ I* V x. i'i :: ' Phosphoric xA-" xcid Phthsist# ';:;5 2ft 1- ft ft X. vfHiiiftl -xi V i-i--.ftfti; V lAA'mAm x .: j x :X t ` .' x -: I; \:V `i;: :'i -x iVt s- ' * - ` : ; J .i: j Plgm nts Plasticizers HTH; X-'ft;!? ft;...,ft- ->;:v ,y>- :S.- : : vV t; >; v; J ^ -:- 2: :? 2 l-l-::-. 1` :V V / ;: i| | ; V V - V 2 - i. 2 4 Pyradin ftlljrfrsbj:;bistl ft ; |V;v ^ ^ \ V Silica Dust Sodlutrt 2H*droxlde21 ?.2 i?- nu^y:<{ri V l|:? f'l-I V ri t ;i; Il-ift ft? It VJi||i: rf i ;V - :<i |.p- 11 fit =1;/:lm y: i f 11 r; i 2 ^ 1: \t v: X -x ,,ft>.,,y,,,,ft. : : ; p SS i; *i , V x'X ft' 2 i 2 '_. -: Solvents V Stabtlliers fy 2:1 iftll 11 Iv 4 fftttU ?V . :x - : ft. : X O' : .yyiix;X: .X?; X. >1 ^clx : j iV;- :--5 2-1: : i ;p A'4}4- 2-2 :2 : Sulfamic Acid ftji 2ft 2ftft'i 1; :i-:. 5 ft: 9i 2 \ x :X.:>. XxVyi -x, :X .X /:,. > ;> : : y " :> x : ills :di:Wm I'lllMl ill . >; >: : x:<V ;i>y- '* :y x *-T rt Butylphenol ^Mlfldllbfliiftfii HI 11 ;f 1 i. 2 ? IfilllS :: :X?;- i ? i A V :: 2 2 < ,|y :2:| i Titanium Di xide till'! :1 I- - BI I11 Vi; % |>.x \% 5 f.- } V; V x-; I; 1V-i}yJ: x ^ Xx xj. -x y; X;1 x X:-X:; V - x; I ft :-;i .x Vi ft : ; i; 2 2 2->-;2 2/::2 f:;; 2 .i 2 2 H Trld c ;V y! V n);-2l:; V V* Y: ^2 I 1 > V ?iiV 2 iii -M- VCM ijip'iyeiStsi V! V V * '! V i V i;: ;i; i K : ' ; ;; ' ; V - .i;x yv ' i x ` -< > i 'y " Vinyl Chloride ftiitWt^ :iymeii2 2 ;2 2 tlft ; " 2 ' . ft : V-H-ifxi-C; Burlington North VCM resins plant is not in operation. The calendering department is currently not in operation. 2? ; V V OCC 10345 Worksheet Example OCC 10346 ELECTROCHEMICALS/ VINYL INDUSTRIAL HYG6NE PUN -1991 PLANTS PLANT NUMBER OF NUMBER RATING EMPLOYEES PLANT 111 POTENTIALS HAZARDS LIST VINYL BaHtittot North Ratal B *17 0J3 AMMONIA HEAT STRESS LEAD MERCURY NITRIC ACID NOISE HAZARD TOTAL BMP'S RATING EXPOSED JOB CLASSES EMPLOYEES BEG SAMPLES SAMPLES SAMPLES SAMPUNG BY JOB CL TWA CEIL STEL FREQUENCY 31 Reactor Crewleader Reactor Cleaner Catalyst Cutter *9 Reactor Crewleader Reactor doner Median!cs Blearidana Boorman Utility Crewleader Catalyst Cutter * Utility Crewleader 3 Electrician! 31 Reactor Crewleader Reactor Cleaner Ciulyrt Cutter 60 SupcrviHsr/Foreman Reactor Crewleader Reactor Qeaner Mechanics Electricians Floanaan Utility Crewleader Catalyst Cutter 12 IS I 11 IS B j 1 4 1 4 5 11 18 1 11 12 IB 8 S ! 4 1 Pag* 1 ELECTROCHtMlCALS/ VHYL INDUSTRIAL HYQENE PLAN 1981 PLANTS PLANT NUMSER OP NUMBER POTENTIALS RATING EMPLOYEES PLANT IH HAZARDS LIST VINYL Barifemoi North Rotaa B 427 0.33 VCM WELDING FUMES RESPIRABLE DUST pEROxroe METHYL ALCOHOL PVC HAZARD TOTAL BMP'S RATING EXPOSED JOB CLASSES 69 Supcrmor/Foreman Roaaor Crcwleadrr Reactor Cleaner Mcchanica Electrician Operator Fteldman Floornuo Utility Crewleader B Mrrhanira 60 Superviaor^ereoun Reactor Qewlcadcr Reactor Cleaner Mechanics Blectricuna Roonman Uiility Crewloader Catalyit Cutter 13 Reactor Crewleadcr Ceulya Cubs 13 Reactor Crewieader Caulyat Cutter 6 Fieldman EMPLOYEES HEG SAMPLES SAMPLES SAMPLES SAM RUNG BY JOB CL 1 TWA CEIL STEL FREQUENCY 11 12 IB S 5 4 6 1 4 B 11 12 IB B J 1 4 1 12 1 12 1 6 OCC 10348 Ps0 2 CLECTBOCHEMCALS/ VMYL WOUSTFWAL HYQENE PLAN -1Ml PLANTS VINYL PLANT NUMBER OF NUMBER SATING EMPLOYEES PLANT 111 POTENTIALS HAZARDS LIST HAZARD TOTAL BMP'S RATING EXPOSED JOB CLASSES EMPLOYEES HEG SAMPLES SAMPLES SAMPLES SAMPUNG BY JOB CL TWA CEIL STEL FREQUENCY B 417 033 BISPHENOL-A t C*alva Cutter l occ 10349 P9* 3 Corporate Industrial Hygiene Database Example OCC 10350 Vims DIVISION 03/07/DI P*ge 1 FACILITY DATS ASSESSED Add it Burlington North Burt inston South Pttadant Pottttoun Stlitbury // // // 12/31/91 11/16/09 12/06/09 i.H. RATING SAFETY RATING 24 33 44 55 22 23 UARR CAER 33 43 43 42 33 33 HA2 CON 92 92 92 100 OS 100 RESP. PHOT. NOISE 74 06 62 07 91 100 100 100 00 93 96 93 CHEN PEL 05 75 92 100 75 03 SUBSTANCE SPECIFIC HEDICAL NOTIFICATION TOTAL COMPLIANCE 100 06 100 100 100 71 100 100 75 100 0 100 07 06 91 100 06 79 OCC 10351 occ 10352 Plant Status OCC 10353 1991 INDUSTRIAL HYGIENE PLANS Background On February 4, 1991, a request was made to all OxyChem facilities to submit their 1991 industrial hygiene plan by February 25th to corporate industrial hygiene (memo included in this tab section). While each facility was given the freedom to use their own style to develop the plan according their individual plant's health issues, they were asked to summarize the details of their plan to facilitate computer data entry at the corporate level. Status As of March 7, 1991, none of the plants in the Vinyls division have submitted their 1991 industrial plan to corporate. OCC 10354 Memo Requesting 1991 Industrial Hygiene Plans OCC 10355 OxyChem To: Distribution From: David Manning Subject: 1991 Industrial Hygiene Plan February 4, 1991 Please send a copy of your 1991 Industrial hygiene plan to my attention in Niagara Palls by February 25, 1991. As a minimum, your plan for this year should include: 1. the chemicals and/or physical agents which will be monitored, and type of sampling (area, personal). 2. the frequency (monthly, quarterly, annually, etc.), and scheduled quarter (1st, 2nd. etc.) the monitoring will be conducted. 3. the number of employees by job classes for each substance which will be monitored. 4. the sampling methods (passive badge, charcoal tube, impinger, etc.), and equipment (air pump, noise dosimeter, etc.) that will be used for each monitoring strategy. 5. the laboratory (NATLSCO, in-house, etc.) used to analyze your samples. Attached is an example of an industrial hygiene plan which was developed by the Ingleside plant in Corpus Christi for 1990. The outline used by Ingleside is not standard, and your plan does not have to follow their format. It is solely included to generate ideas for the development of your facilities' industrial hygiene plan. Please send any information you have already developed. But, in order to standardize everyone's information to make data entry into the computer more efficient, please summarize the details of your 1991 plan on the attached worksheet (last page). An example of a worksheet filled out is included for your review. DJM/hs cc: R F. Adams M. A. Buczynski W. E. Driscoll T. M. Jones S. B. Kemp D. W. Scullion J. D. Snell EXJM/Correspondencc/Plants/IH Plan -1991 Occidental Chemical Corporation ^ Corporate Industrial Hygiene Occidental Chemical Center 360 Rainbow Boulevard South, PO, Box 728, Niagara Falls, NY 14302-0728 716/286-3000 occ 10356 INDUSTRIAL HYGIENE SAMPLING PROGRAM CORPUS CHRISTI PLANT 1990 CHLORINE 1. Process - Nos. 1, 2, & 3 Chlorine Cell Circuits - Chlorine Liquefaction Area - Chlorine Recovery Area - Chlorine Railcar Loading Area - Chlorine Barge Loading Area 2. Employees - Chlorine Technicians - Cell Technicians - Lab Technicians - Bulk Storage Technicians - Cell Renewal Technicians - Chlorine Recovery Technicians 3. Sample Type - Employee Monitoring/Area Monitoring a. 8-hour Time Weighted Average (TWA) b. 15-minute STEL 4. Sampling Equipment - Metrosonics Model dl-3310 Chlorine Monitor 5. Frequency - Conducted Annually - Approximately 20 samples 6. Analysis - NATLSCO - Long Grove, Illinois 7. Completion Date - 12/90 ASBESTOS 1. Process - Cell Renewal (Asbestos Handling Area) 2. Employees - Cell Renewal Technicians 3. Sample Type - Employee Monitoring/Area Monitoring a. 8-hour Time Weighted Average (TWA) b. 15-minute STEL 4. Sampling Equipment - DuPont Alpha-I Air Sampler - 25 mm Methyl Cellulose Ester Filter & Cassette CC 10357 INDUSTRIAL HYGIENE SAMPLING PROGRAM - 1990 PAGE 2 5. Frequency - Semiannually - Approximately 16 Samples 6. Analysis - NATLSCO - Long Grove, Illinois 7. Completion Date - 6/90 and 12/90 III. VENTILATION 1. Area - Asbestos Handling Room - Cell Renewal Lab - Works Lab 2. Sample Type - Air Flow Measurement 3. Sampling Equipment - Alnor 8565 Thermo Anemometer 4. Frequency - Conducted in each area once/quarter. 5. Analysis - Direct reading instrument 6. Completion Dates - 3/90, 6/90, 9/90, 12/90 IV. NOISE 1. Process - Plant Wide las required) 2. Employees - Boiler Technicians - Caustic Technicians 3. Sample Type - Employee Monitoring - 12-hour and 8-hour Time Weighted Average (TWA) - Area Monitoring - Noise survey 4. Sampling Equipment - Metrosonics Noise Dosimeters - Quest 227 Integrating Sound Level Meter with CA 12 calibrator 5. Frequency - Employee Monitoring - Annually - Area Monitoring - (as required) 6. Analysis - Direct Reading Instruments 7. Completion Date - 12/90 OCC 10358 INDUSTRIAL HYGIENE SAMPLING PROGRAM - 1990 PAGE 3 V. HEAT STRESS 1. process - #1, #2, & #3 Cell Circuits 2. Sample Type - Measurement of the Environment 3. sampling Equipment - Metrosonics - Heat Stress Monitor 4. Frequency - Monitor during summer months 5. Analysis - Direct Reading Instrument 6. Completion Dates - 06/90, 07/90, 08/90 VI. PERCHLOROETHYLENE 1. Process - Miscellaneous Barge Dock - EDC Finished Product Tank Farm (South Area) 2. Employees - Bulk Storage Technicians 3. Sample Type - Employee Monitoring a. 8-hour Time Weighted Average (TWA) 4. Sampling Equipment - 3M 3520 Organic Vapor Diffusion Badges (all samples) - Dupont Alpha-I Air Sampling Pumps with Charcoal Media (10% of samples) 5. Frequency - Conducted Quarterly Approximately 1-2 samples per quarter 6. Analysis - NATLSCO - Long Grove, IL 7. Completion Date - 3/90, 6/90, 9/90, 12/90 8. Sample Type - Area Monitoring - Bulk Storage Area (2 points) a) Frequency - Once each shift b) Sampling Equipment - Foxboro OVA-128GC Organic Vapor Monitors for Detection of Volatile Organic Compounds OCC 10359 INDUSTRIAL HYGIENE SAMPLING PROGRAM - 1990 PAGE 4 VII. ETHYLENE DICHLORIDE 1. Process - EDC Unit - Bulk Storage Area 2. Employees - EDC Technicians - Loading Technicians - All Fluor-Daniel Contract Maintenance Employees in EDC Production Area - EDC Process,Supervisor 3. Sample Type - Employee Monitoring a. 8-hour Time Weighted Average (TWA) b. 15-minute STEL 4. Sampling Equipment - Dupont Alpha-I Air Sampling Pumps with Charcoal Tube Media (10% of Samples) - 3M 3520 Organic Vapor Diffusion Badges (all samples) 5. Frequency - Conducted quarterly Approximately 32 Samples per Quarter 6. Analysis - NATLSCO - Long Grove, IL 7. Completion Date - 3/90, 6/90, 9/90, 12/90 8. Sample Type - Area Monitoring - EDC Process Area (15 points) - Bulk Storage Area (7 points) a) Frequency - once each shift b) Sampling Equipment - HNU Organic Vapor Monitors for Detection of Volatile Organic Compounds VIII. CARBON TETRACHLORIDE 1. Process - Chlorine Recovery - Chlorine Liquefaction 2. Employees - Chlorine Recovery Technicians Chlorine Technicians 3. Sample Type - Employee Monitoring a. 8-hour Time weighted Average (TWA) OCC 10360 INDUSTRIAL HYGIENE SAMPLING PROGRAM - 1990 PAGE 5 4. sampling Equipment - 3M 3520 Organic Vapor Diffusion Badges (all samples) - Dupont Alpha-1 Air Sampling Pumps with Charcoal Tube Media (10% of Samples) 5. Frequency - Conducted Quarterly Approximately 2 Samples per Quarter 6. Analysis - NATLSCO - Long Grove, IL 7. Completion Date - 3/90, 6/90, 9/90, 12/90 8. Sample Type - Area Monitoring - Chlorine Recovery Area (3 points) a) Frequency - Once each shift b) Sampling Equipment - Foxboro OVA-128GC Organic Vapor Monitors for Detection of Volatile Organic Compounds IX. SODIUM HYDROXIDE 1. Process - Caustic Unit 2. Sample Type - Employee Monitoring a. 8-hour time weighted average 3. Sampling Equipment - Dupont Alpha-I Air Sampler Impinger 4. Frequency - Conducted Quarterly - Approximately 1-2 samples per quarter 5. Analysis - NATLSCO, Long Grove, Illinois 6. Completion Date - 03/90, 06/90, 09/90, 12/90 JSmla JS-508 OCC 10361 PLANT NUMBER OP EMPLOYEES DEPT TOTAL EMPLOYEES EXPOSED POTENTIAL HAZARDS LIST (CHEMICAL / AGENT) {Plant Name) 166 EVAP 13 AMMONIA JOB CLASSES EMPLOYEES SAM PLE SAMPLE SAMPLE BY JOB CL TY PE FREQ'CY QUARTER Area Pen SAMPLING METHOD LABORATORY ANALYSIS Operator Hud Operator Retie/ Operator 10 4 1 X Annually lit Pump / Cassette X X NATLSCO CELL REP 9 ASBESTOS Operator Heed Operator Operator Trainee 4 1 4 X Semi-Annually 2nd/4th X X Pump / Cassette NATLSCO CELL REP 9 UOUEFAC IS ASBESTOS Opqilioci CARBON TETRACHLORIDE Operator Head Operator Relief Operator 9X Annually lit Pump / Cassette NATLSCO 10 X Quarterly All Pump / Charcoal Tube NATLSCO 4X 1X CELL REP 9 CHLORINE Operator 4 X Semi-Annually lct/3rd Pump / Impinfter DATACHEM Heed Operator , X :> Operator Trainee 4 X > i UOUEFAC 1J CHLORINE Operator 10 X Semi-Annually 2nd / 4th pm-7700 Monitor METROSONICS \ Head Operator 4 X 1991 INDUSTRIAL HYGIENE PLAN WORKSHEET EXAMPLE Pa^e 1 PLANT NUMBER OF EMPLOYEES DEPT TOTAL EMPLOYEES EXPOSED POTENTIAL HAZARDS LIST (CHEMICAL/AGENT) CELL ROOM 13 CHLORINE JOB CLASSES EMPLOYEES SAM PLE SAMPLE SAMPLE BY JOB CL TY PE FREQ'CY QUARTER Area Pen SAMPLING METHOD LABORATORY ANALYSIS Relief Operator Operator Head Operator Operator Trainee Semi-Annually 1st / 3rd Pump t Impinger NATLSCO EVAP IS CHLORINE Operator Head Operator Relief Operator 10 Semi-Annually 2nd /4lh Pump / Tnupinj^er NATLSCO UQUEFAC IS NOISE Operator Head Operator Relief Operator 10 Annually 2nd dt>-3100 Monitor METROSON1CS CO-GEN 20 NOISE Operator Head Operator Relief Operator 14 Annually 3rd db-3]00 Monitor METROSONICS VCM 20 VINYL CHLORIDE MONOMER Operator Head Operator Relief Operator 14 Quarterly All Renner Badge IN-HOUSE LAB OCC 10363 1991 INDUSTRIAL HYGIENE PLAN WORKSHEET EXAMPLE Page 2 PLANT NUMBER OP EMPLOYEES DEPT TOTAL EMPLOYEES EXPOSED POTENTIAL HAZARDS LIST (CHEMICAL t AGENT) SOLVENTS 20 ETHYLENE DICHLORIDE JOB CLASSES EMPLOYEES SAM PLE SAMPLE SAMPLE BY JOB CL TY PE FREQ*CY QUARTER Area Pen SAMPLING METHOD LABORATORY ANALYSIS Operator Head Opentoc Relief Operator 14 4 2 X Quarterly X X All Pump / Charcoal Tube NATLSCO SHIPPINO 20 DUST Operation 20 X Annually 3rd Pump / Cassette NATLSCQ CAUSTIC 31 NOISE Operation 35 X Annually 2nd db-3100 Monitor METROSONiCS OCC 10364 1991 INDUSTRIAL HYGIENE PLAN WORKSHEET EXAMPLE Rage 3 PLANT NUMBER OF EMPLOYEES DEPT TOTAL EMPLOYEES EXPOSED POTENTIAL HAZARDS LIST (CHEMICAL/AGENT) JOB CLASSES EMPLOYEES SAM PLE SAMPLE SAMPLE BY JOB CL TY PE FREQ'CY QUARTER Area Pen SAMPLING METHOD LABORATORY ANALYSIS OCC 10365 ) i 1991 INOUSTfi IAL HYGIEN E PLAN WORKSHEET Pa^e OCC 10366 Divisional Summary OCC 10367 Vinyls Division Industrial Hygiene - Major Issues Divisional Summary Respiratory protection practices IH exposure monitoring methods Frequency of monitoring Type of monitoring (area vs. personal) Task specific sampling requirements Standardized instrumentation for area survey Standardized PPM alarm settings for fixed monitors Analytical methods of IH samples Personal protective equipment practices HAZCOM labeling inspection programs Work practices for similar exposure hazards Employee notification procedure for VCM over-exposure OCC 10368 Plant Summaries OCC 10369 Vinyls Division Industrial Hygiene - Major Issues Plflfit-hv-Plant Summary Addis Training of additional person in Basic Fundamentals ofIndustrial Hygiene course scheduled in March 1991. Sound level survey conducted by corporate IH. Comprehensive monitoring for personal exposure to air contaminants and noise needs to be conducted. IH program needs to be assessed by corporate IH. Burlington North IH program needs to be assessed by corporate IH. Open position needs to be filled (person may need IH Fundamentals course training. Resins department is currently not in operation. IH exposures for that area are not presently applicable. Burlington South No individual plant issues. Pasadena No individual plant issues. OCC 10370 Vinyls Division Industrial Hygiene - Major Issues Plant Summary March 1991 Page Two Pottstown Open positions need to be filled (persons may need IH Fundamentals course training). Establish action plan to accomplish recommendations of corporate environmental, health and safety assessment. Calendering department is currently not in operation. IH exposures for that area are not presently applicable. Salisbury Solvent storage and usage. UV-cured resin coatings procedures. Comprehensive monitoring for personal exposure to air contaminants needs to be conducted. OCC 10371