Document 3dNOJkwXQ4mmkQ9EXLBDGKvn

tl r* rt V. ii \ * H ' V iii li Vli ^ u'jUj iix_v^. jf JunUi do e.s iu r^k iOlV'oJ b Almost everything you rtlwc.r v untod to know about OSHA's vinyl chloride standard but were afraid to a k JOB SAFETY AND HEALTH MAGAZINE APRIL 1973 "In the average year approximately 130 people are shuck by lightning. Last year 32 cases of vinyl chl'Midc-related cancer were discovcied. In view of these numbers, should not workers be required to carry a lightning rod?'' Not every question osiia gets asked about its vinyl chloride (vc) standard is as fiivolous as this one from an anonymous user of polyvin)! chloride (pvc) resin. In fact, now that -an appeals court has ruled the standard is effective April 1, 1975, hundreds of legitimate questions--the ones that get down to the nitty-gritty of how to comply in each plant --arc rolling in. Here we offer osha's replies to some of the most frequently asked questions. For more general information on the vc standc.J, check Job Safety <? Health, January 19"7'. !l y ,, : further questions, write to: OSH A \ Regional Programs, Division of Occupa tional Health Programming, Room 760, ''v 1726 M St., NW, ^Washington, D.C. 20210. Q. We know that the standard requires an initial monitoring program to tell if an em ployee is exposed above the action level of 0 5 ppm. Do we have to monitor vr exposures for every single employee? A. Each employee need not he pci sonally monitored, but your moni tormg must take into account all employees -- whether they wear / respirators or not -- and must give a valid determination of employee exposures. You might select re presentative employees for personal monitoring according to these ci iteria: ' the rumibci of employees per shift, their duties, work areas and operations, and work pi notices in force. Each employee's vc exposure must he represented even though he may not be personalis monitored. Q. How \iion after the stumbii't! com into i licet must the initial monitoring he done? A. Where a process is already in operation, monitor ing must be accomplished and regulated areas estab lished by April 1, 1975. We recommend that new processes be monitored within one week after start up and regulated areas established as soon as possible after the monitoring results are available. Q. We use pvc, but extensive monitoring has shown that vc concentrations are txclow the permissible limit--one ppm as a time-weighted a. crave and five ppm as a ceiling. Do we have to establish a "regulated areal1'' V/hat if concentrations are below the "action level" of 0.5 ppm1' A. The standard sets two conditions, both of which must be met before a regulated area is required: 1) vc or pvc is manufactured, reacted, pack aged, repackaged, stored, handled, or used. - 2) vc concentrations are in excess of the \ permissible exposure limit. 4 If concer.trcticr.:'., then, arc below either the permissible limit or the action level, you do not have to set up a regulated area Q, Docs every employee in our plant who with vc have to be given training? What about the employees exposed below the action level? A. There are no exceptions to the training requirement. Regaidlesx of how low the monitoring results arc, each employee "engaged in \r or Pvc operations" must be given training in the hazard* related to vc and the proper precau tions for usine it This mult include maintenance, lab oratory, and supers Aon personnel as well as pro duction workers. Q. Occasionally oarcompany uses what we consider temporarv eniplovees 7 hese peo[th would be exposed above the action level for no more than two weeks a year. Must we prosaic them with medical exams req'tiral by the standatd' A. If the workers are exposed above the aeti'n level and if they are your employees, you are respon- 19 BOR 014990 sible for furnishing medical exams and holding the records !or 30 yeais or ihc duration of employment plus 20 years, whichever is longer. Thcie are no exceptions to the medical surveillance requirements, no matter how short trio period of exposure, Q. Our company fabricates various packaging ma terials, some of which use pvc. Since one of our plants is pretty much like another, are we allowed to monitor typical operations rather than every single plant? We believe we can show that VC concentra tions are nowhere near 0.5 ppm in our operations. A. Your program of initial monitoring must deter mine if any employee is expos. 1 ; ess of the action level--0.5 ppin. If the program you propose gives a true determination of your workers' expo sures, it is satisfactot y. If what you p'oposc, how ever, gives a false reading of worker exposures and, as a icsulr, you disregard requirements of the stan- datd that are triggered by the action level, then your program is unsatisfactory and you will be in violation of the standard. .< Q. Our company has many plants throughout the country and few industrial hygienists, but we do have an excellent technical center. Can we monitor by taking grab samples of air in bags, end sending them to the technical center for analysis? A. You may use any monitoring method that mea sures the exposures of employees to within the ac curacy requirements given ;n the standard. For eighthour exposures, the method must be accurate within pius nr minus 50 percent from 0.25 ppm through 0.5 ppm. within plus or minus 35 percent from 0.5 ppm through one ppm, and within plus or minus 25 percent over one ppm. It must measure 15minure exposures within plus or minus 25 percent from one ppm on up. Q. How do you figure out an eight-hour time-weight ed average (twa)? A. The basic formula is: 1 TWA = CaTa + CbTb................CnTn 8 where C - VC concentration during any given period time T - duration in houri of the exposure at contration C. For example, the twa for an employee who was exposed to 0.2 ppm for two hours, 3.0 ppm for four hours, and 1 0 ppm for two hours would be as follows: 8-hour TWA = 2 x 0.2 + A x 3.0 + 2 x 1.0 ~ 1.8 ppm Q. What procedure will an osha compliance officer use io determine ceiling-limit vc exposures? A. The ceiling limit for vc. is five ppm for any 20 sampling period under 1 5 minutes. A ceiling samp'., should be taken when you have anv ictooti to belli ve --from the context of your operation--that some exposures are higher than the eight-hour time-weight ed average. osha industrial hygienists will measure ceiling exposures as 15-minute samples. At present, we will be taking air samples with charcoal-filled tubes that absorb the vc. In the laboratory the tube can be desorbed with carbon disulfide and the vc detected through gas chromotography. For a detailed ac count of this method, write niosji, Office of Tech nical Publications, 1014 Broadway, Cincinnati, Ohio 45202, and ask for a copy of "P&CAM No. 178." Q. The standard says that within 10 days after monitoring discloses that an employee has been over exposed, we must notify him of the results and tell him what steps we're taking to control exposures. Our company, though, is using a continuous monitor ing system for vc. How often do we have to notify our employees about overexposures if vc levels arc constantly above one ppm? How many times do we have to tell them about our control measures? A. You should report the monitoring results each month when employees are exposed above the "action level" of 0.5 ppm. All monitoring results must be included, but they may be reported in a summary form that indicates the total extent of ex posure. You must notify each individual employee in writing. If you've started to implement a regular program to control exposures, you need tell the employee about this in detail only once and mav cite your original announcement thereafter. Q. We understand that certain processes involving PVC are not regulated by the osha standard. Our company manufactures a pvc part by extrusion. Our customers then mitre-cut the part and heat seal or heat weld it to form a gasket. The part is heated to approximately 450 `F for 30 seconds to form a seal. Is any part of this operation covered by the standard89 A. The standard excludes the handling and use of fabricated pvc products that don't require mass melting as part of their further processing. "Mass melting" occurs when the entire structure is heated so that the physical integrity and form of the input material is lost. Obviously, the melting or plasticiza tion of pvc molding pellets in your extmsion process is covered by the standard. However, such operations as heat sealing (like that done by your customers), thermoforming, blister packaging, lamination, vacu um forming, and heat shrinking, do not destroy the essential form of the fabricated product and so are exempt from the standard. Q. I've been a meat wrapper for the last 15 years, and lately I've been hearing a lot about the dangers of vc. Every day I work with pvc meat packaging BOR 014991 film, sometimes tutting it with a hot wire. Ai cord ing to the osha simulant, what should our company he doing to protect me? A. Meal packaging films arc considered a "fabri cated product" mulct the ostiv standard since mass inciting does not occm when they are cut with the hot wire. Consequently, the packaging opeiation you describe is not covered by the vr standaid. niosh has conducted research into the possible release of vr during pvc packaging operations and, using instruments sensitive to approximately one ppm, has not detected any vc . However, NIOSH has determined that when heated, pvc film decomposes into hydrogen chloride and carbonaceous gases. The hydrogen chloride gas, which becomes hydrochloric acid on contact with the mu ;us mem ranes of the eyes, throat, and nasal passages, can be irritating at concentrations above the osha standard of five ppm for hydrogen chloride. So far niosh lias found no health hazards from exposure to other pvc decom position products, though the investigation is con tinuing, Q. The standard says that it applies to the trans portation of vc or pvc "except to the extent that the Department of Transportation fDOTj may regulate the hazards." Arc the placards DOT requires for tank trucks carrying vr monomer enough to fufill the labeling requirements of the standard0 If not. what is meant by the requirement that labeling h ' "legible?" Is a tank truck on the road considered a "regulated area0" If the dnver docs not help in loading or unloading, is he covered by any of the provisions of the standard? \. There need not be duplication of dot markings that cover such hazards a* flammability. However, niatkings not requited by not, oieh as "cancersuspect agent," must be part of the container label. In other words, when placarding specified In POT is not sullicient to meet requu einentx outlined in the osn\ standard, additional labeling will he required. For working puiposes, we define "legd'le" as the same si/c fctteimg as o.her emeigenes or warning in structions on the side of the container or vehicle. A tank truck cans mg vc warn Id be considered a regulated area onl\ il it were expe ted (based on measurements or other known face i that \c con centrations would exceed one ppm i, an eight-hour time-weighted aveiaec or (he ppm as a ceiling It appears unlikely that a truck on the road would be in this situation. Whether the tiuck drivet is covered depends on the amount of vc lie is exposed to, It the exposuie is below the action level of (I 5 ppm---as seems likelv --only the training : nd labeling piovisions of the standard would apple Q. ITc me expecting \htpments of pvc resin after the standard goes into effect The resin m shigr.-q sealed < ontamers 20 and to feet long flaw > , standard affect oar operatum? A. The osha standard does not prohibit importing vc or pvc, but each employer is rcponsihle for know ing the working conditions of his employees and con trolling conditions to meet the standard's require ments. Our information on vr exposure levels in handling packaged resins is limited Concentrations above the exposure limit have been measured in warehouses where pvc resin is stored. Freshly opened containers, particularly air-tight ones, may release significant amounts of vc to the air. For instance, concentra tions in tracks loaded with bagged pvc resin have been measured at 200 to 600 ppm. It appears that, at the vety least, you must do initial monitoring of employee exposures. If the eight-hour time-weighted average is below 0,5 ppm and I5-minutc exposures below' five ppm, then your duties arc reduced basically to labeling containers and training employees. Q. The standard says that no employee can he ex posed to VC concentrations above five ppm over a 15-minute period. What about those emphnees who decide not to wear respirator for the stan dard's first year? A. Before April ), 1976, the ceiling exposure limit of five ppnt over 15 minutes does not applv to the employees who have elected not to wear respnn'orThey may be exposed to as much as 25 ppm ovci ,mv 15-minute period. Q. The emergency provisums of the standard go into effect when you have a "massive icleuse" o< vc Exactly how much vc docs it take to tugger these provisions? A. We define a "massive release" as any operation or place where the vc concentration is giente: than 100 ppm. For example, a broken pipe in a rvc plant might cause a massive release 0- The standard says that no emplovves mav haw direct contact with vc. If hat ilo you mean by "Ji'c:: contact?" A. Skin contact with liquid vc Q. The standaid requires us to keep a dailv kmc of authorized persons who entei a regulated area. What information should nr include on the tiis'er'' A. The daily roster should consist of legible sig natures--or piintcd or typed names--and social se curity numbeis of authorized persons. 1 "cubic mimes oi numlvis on the mstei sheet will K eonsideted as failing io keep a bomilide log I he- c lus ters must be kept for 30 years. 21 BOR 014992