Document 443BG9mgKeMZRKVnYGyz3ED1N
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Interoffice Communication
To Jerald Uptaln
From
Oven Tubb
Date December 8, 1975
Subject Aberdeen Chemical Exposure Abatement Program
On June 11, 1975, Leon Vernon issued a letter which was to be used as a guideline in establishing a plant chemical exposure abatement program. On July 10, 1975, an Aberdeen chemical exposure abatement program was initi ated. Outlined below is the status of that program and also the program plan for 1976.
X, Initial Abatement Program
A. Identifying In the Aberdeen chemical exposure abatement program, ten chemicals were identified as the most dangerous chemicals used in the plant. They were as follows:
Vinyl Chloride Lead - hM,
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Phthalic Anhydride - fol*
Nitrobenzene - l ft*>. Trichlorethylene --
Alphamet hy1s tyrene Antimony
Barium Cadmium
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The plan was to take the top four chemicals, excluding vinyl chloride^
and run a quick-check analysis on each of the four chemicals. These chemicals are as follows:
1. Lead 2. Phthalic Anhydride 3. Nitrobenzene ,, 4. TrichloroethrTSne'
B, Status of Existing Program
1. Since the start of the chemical exposure abatement program the following chemicals have been monitored:
a. Lead
b. Trichloroethylene c. Tin
d. Barium
e. Other metals as per attached table
f. Cadmium (Not detected on monitoring result s)
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2. The monitoring results to date are listed on the attached table.
, 3. Monitoring of the other chemicals listed in (Section IA) will be completed by;March 31, 1976.^
4. After monitoring is completed the plant safety department will decide what course of action to take. This action will Include:
(a) Quarterly monitoring of each chemical as listed in (Section ia) if none of the chemicals monitored in the initial program exceed the action level of each chemical.
(b) Personnel dosimetry, weekly, for a two month period if any of the chemicals exceed the action level. If needed, this will be completed by May 31, 1976.
(c) If the personnel monitoring results Indicate that a chemical exceeds the action level, the safety de partment will take the following action:
1. Propose to the affected operating department changes in work practices.
2. Propose the use of personnel protective equipment. 3. Propose the use of "substitute" less toxic chemicals.
(d) After the personnel dosimetry program is completed, the engineering department will be asked to make a study of the problem and develop a plan to reduce employee exposure.
II. 1976 Chemical Exposure Abatement Program
A. The 1976 program is essentially the same as the program initiated in 1975. This program includes the following:
1. Identifying toxic chemicals
a. The safety department is responsible for determining which chemicals are to be monitored. Those chemicals listed on the "Suspected Carcinogen List" and those chemicals in plant use that are suspected of exceeding the permissable limit will be given higher priority.
b. It is the purchasing department's responsibility, when purchasing chemicals, to insure that material safety data sheets are sent to the plant prior to the purchase of the chemicals.
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c. The safety department is responsible for keeping an up* dated file of material safety data sheets that are available for review to all employees.
2. Monitoring toxic chemicals
a. The safety department is responsible for monitoring toxic chemicals. There responsibilities include:
(1) Purchase of monitoring equipment (2) Scheduling and conducting monitoring (3) Determining what action to take toward further
monitoring (4) Review and filing of monitoring results
b. The monitoring schedule is as follows:
(1) Area dosimetry or quick check analysis for a two month period for each chemical.
(2) If monitoring results exceed the action level, a two month period of personnel dosimetry will be initiated on a weekly basis to determine if employees are exposed above the action level.
(3) If it determined at the end of the personnel dosimetry tests that employees are being exposed in excess of the action level, the safety department will tdte the following action:
(a) Propose to operating department a program for better employee work practices.
(b) Propose the use of personnel protective equipment.
(c) Survey the possibility of using a "substitute" less toxic material.
(d) Continue personnel monitoring on a monthly basis to assure that the plant remains below the action level.
c. This monitoring program will begin in April of 1976, immediately after the completion of the initial program.
d. The plant laboratory is responsible for:
(1) Aiding the safety department in determining what monitoring methods to use.
(2) Determining what type analytical methods to use.
(3) Analyze monitoring tests and send results to the safety department.
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g. plant operating departments are responsible for g8istng, as needed, in conducting monitoring tests.
3. ontfpl of toxic chemical?.
g, The safety department has the following responsibilities fn hp control of toxic materials:
(1) knowledge of the toxicity of materials before they pgtgr the plant. Monitor the toxic materials on a scheduled basis %9 assure that employees are not overexposed.
(3) Propose to operating departments proposals for |>g|tgr employee work practices.
(6) the engineering department for assistance in engineering controls.
fer laboratory is responsible for:
(I) AaalysiBg monitoring tests (1/ the safety department in the search for
,fP^s|ituten less toxic materials.
gf Tfop plant engineering department is responsible for being ppgpgped to make a study and design plans that will pg^cp employee exposure to toxic chemicals. The safety (jepgrtment will ask engineering for assistance immediately gflpf the completion of the personnel dosimetry program, If tbe gfreraical being monitored exceeds the action level.
6, Repp?ts
f ^sulfs from gH Baonitoring will bp included in the monthly repeat'
fer ffeftftopfng results will bp filgd in the safety department.
f U!ary
g, completion of monitoring the ten "most dangerous" listed in (Section IA) on March 31, 1976, the
ggfp|y department will take the following action:
lr pick two chemicals as per priorities given in (gpgtlon II A lt) and run a quick check analysis on pgph chemical.
2, If either chemical exceeds the action level, a personnel dosimetry program will commence.
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3. If, at the completion of the personnel dosimetry program, the chemicals exceed the action level, the safety department will prepare a program as listed in (Section IB4c).
4. Ask assistance from the engineering department to develop a program to reduce employee exposure.
5. Continue personnel dosimetry on a monthly basis to insure that the plant remains below the action level.
QtoJ&ns IvJak___
Owen TUbb Industrial Hygienist OT/sm