Document 4JxX78JgB4Ra1KL4KqD3LL7jR

doooQl? sSoqqs mood] (^/squoijdcsqo^ MEDICAL AND HEALTH RESOURCES DIVISION R T Chang. Ph, O . P 6 REGIONAL INDUSTRIAL HVQIENE DIRECTOR WESTERN REGION industrial hyCi(n{ and radiation health phvSiCS Department p 0 Bo, ai0oa SH Diego, CA 92l5a April 11, ,1978 RTC: 78-48 Mr, Bryan H. Gambrill I China Gulf Plastics Corporation P. 0. Box 22144 Taipei, Taiwan 105 Republic of China f-iL^6-0^j \ j /\ / CfJUr ' ^ J L~c - , Dear Bryan: Enclosed are two copies of my rep.er^oaAfivaluation-^of Industrial hygiene programs ,,at C|iina Gulf-Plastics-Corporation conducted during^November .1977. I apologize for the delay. A bizarre event occurred during shipping that caused desorption of every bit of vinyl chloride from all the charcoal tube air samples we wrought back from CGPC. However, I believe the observations and the survey results based on organic vapor analyzer were mostly adequate in assessing occupational vinyl chloride and sol vents exposures at Toufen factory. All findings and recommendatons in this report were discussed with you In Taipei and with the factory management in Toufen. Please let me know if you have any questions or need further information. Warm regards, ,,/f? Robert T. Cheng:- j RTC/aln Enclosure I cc: Dr. F. D. Gassaway i Dr. R. L. Gibson (3) Mr. C. P.. Grimes Dr. W. A. McClellan rHr^Hr- E-. Run-ion-- a- Division or uulf oil Corporation toiSWf ooaiSW CUSAROSS 00674 EVALUATION OF INDUSTRIAL HYGIENE PROGRAM AT CHINA GULF PLASTICS CORPORATION November 1977 Robert T, Cheng, Ph.D,, P.E. Gulf Regional Industrial Hygiene Director (C005) 0058. 0002 CUSAROSS 00675 - ', I TABLE OF CONTENTS I. SUMMARY....................................... ........................................................ Eaa. 1 II. VINYL CHLORIDE EXPOSURES ................................................... A. PolymerPlant .................................................................. B. MonomerPlant .................................................................. C. "Search and Secure" Program ................................ D. Vinyl Chloride Sampling by Charcoal Tube . . 3 3 6 7 13 III. SOLVENT VAPOR EXPOSURES .......................................................... A. Printing Shop............................................................... B. LeatherPlant.................................................................. C. Polyurethane Plant ................................................... 14 14 16 17 IV. MERCURY EXPOSURES . ................................................................ 20 V. LEAD, BARIUM, CADMIUM and CHROMIUM ....................................... A. Chromium ...................................................................... B. Lead............................................ C. Barium and cadmium................................................... 23 23 27 28 VI. PLATING SHOP.................................................................................... 29 APPENDIX 1. Laboratory Analytical Results .......................... 2. Mercury Vapor Respirator ....................................... 3. Guideline for Chromium (VI)Exposure ... 4. Guideline for Lead Exposure................................. 30 39 42 50 (0005) 0058. 0003 k CUSAROSS 00676 I. SUMMARY China Gulf Plastic Corporation's Industrial hygiene program was re-evaluated In November 1977 following its Initial set-up in February 1974, and a comprehensive review conducted in August 1976. Impressive progress has been achieved by CGPC in reducing workers' occupational exposures to vinyl chloride, solvent vapors, mercury, and dusts of lead, barium, cadmium and chromium. At this moment, CGPC's industrial hygiene program is by far the most advanced and comprehensive among all industries in Taiwan. The time-weighted average exposure to vinyl chloride for workers at the Toufen polymer plant was over 200 ppm prior to 1974, reduced to about 50 ppm by August 1976, and further reduced to approximately 10 ppm as surveyed in November 1977. This is indeed an extraordinary achievement, considering that the Government of the Republic of China Is still abiding by the old and obsolete 500 ppm permissible vinyl chloride exposure limit; and most of CGPC's local competitors have done very little to reduce occupational VC exposures in their factories. CGPC has implemented a vinyl chloride leakage "search and secure" pro gram. Successful identifying and controlling of leaks have resulted in significant reduction of VC emissions and occupational exposures In the Toufen monomer plant and polymer plant. Nevertheless, reactor cleaners' VC exposures still exceeded CGPC's own exposure limit of 10 ppm. It appears that the only way to reduce their over-exposure is to eliminate routine manual cleaning of the reactors by adopting one of the several automatic reactor cleaning processes currently used by PVC manufacturers in the U. S. and some European countries. In fact, CGPC could meet the U.S. 1 ppm vinyl chloride exposure standard If manual reactor cleaning is eliminated and fugi tive emissions reduced. 1 (0005) 0058. ooo^ CUSAROSS 00677 Occupational exposures to solvent vapors have been reduced over the years. However, there were still excessive airborne solvent vapor concentrations in the Printing Shop and in the new Polyurethane Plant. Additional exhaust ventilation is required to lower exposures to safe levels. Mercury vapor exposures in the Chior-Alkali Plant have been reduced to acceptable levels through measures of dilution ventilation and local exhaust ventilation. Exposures to dusts of lead, barium and chromium in the Extrusion Plant were mostly at safe levels, but occasionally over the permissible limits. It is recomnended that a strong effort should be made to replace dyes and pigment containing lead chromate; otherwise, stringent control measures should be implemented to mini mize employees' chromate exposures. CGPC's industrial hygiene laboratory should acquire field and laboratory equipment for measuring airborne concentrations of lead, chromium, barium and cadmium dusts. Hygiene conditions in the plating Shop were below expectations. Local exhaust ventilation systems should be installed to control high con centrations of chromic acid and sulfuric acid fumes. Preliminary results of this survey have been reported to Mr. B. H. Gambrill, CGPC President. Mr. K. Yu and other senior management per sonnel at Toufen Plant have also been appraised of the findings and recommendations during a debriefing session. The author wishes to thank Messrs. B. H, Gambrill, L. S. Ting, S. K. Yeh, K. Yu and other members of CGPC management for their courtesies and help during his stay in Taiwan. Special thanks to Ed Lu and 0. H. Huang for their assistance in carrying out the survey work. 2 (0005) 0058. 0005 CUSAROSS 00678 II. VINYL CHLORIDE EXPOSURES A. POLYMER PLANT In the November 1977 industrial hygiene survey, monitoring of workplace vinyl chloride concentrations was accomplished with a portable organic vapor analyzer which can give instantaneous display of parts per million concentration of total combustible hydrocarbon gases and vapors present in the air. Because vlnly chloride gas was the only combustible gas present in significant quantities in the air inside the polymer plant, readings obtained with the organic vapor analyzer, after adjustment for the Instrument's sensitivity factor for vinyl chloride, should give a fair indication of workplace vinly chloride concentrations. The highest vinyl chloride concentration was encountered when the top manhole of the reactor vessel was opened to facilitate flushing down PVC resins from reactor walls with a large water hose. Airborne vinyl chlor ide concentrations easily exceeded 1,000 ppm (upper detection limit of the instrument) at places near the manhole. Vinyl chloride can also be sensed readily by its characteristic sweet odor at a few feet distance downwind fromihe manhole opening. (VC odor can be detected by a sensi tive nose at 2000 ppm concentration.) This "flush-down" operation lasted only a couple of minutes. Then the manhole opening was covered up again, and the slurry of reacted PVC resin was withdrown completely from the reactor vessel. Workers who are Involved in the "flush-down" operation, and any other employees who are on the main floor of the polymer plant during that time period, shall be required to wear supplied-air respirators. No one should be exposed to vinyl chloride at concentrations above odor thresh old for even a very brief time. This rule should be enfored with vigor. The most hazardous job in terms of high workplace VC concentrations and lengthy exposure durations was the manual cleaning of the reactor vessel. After PVC resins and the un-reacted monomer were recovered and the reac tor vessel air purged, three reactor cleaners were sent into the vessel through the bottom manhole to scrape PVC scales off the reactor walls with (0005) 0058. 0006 CUSAROSS 00679 hand tools consisting of hammer, knife and chisel. Although air purging was continued during the reactor cleaning time, permeation of monomer from PVC scales on the reactor walls created 50 ppm to 200 ppm VC con centrations within the reactor. It takes 30 to 40 minutes for the three cleaners to clean one reactor. They clean four reactors per shift. Therefore, it is estimated that a reactor cleaner's typical eight-hour time-weighted average exposure should be somewhere between 15 ppm to 50 ppm. Other workers at the polymer plant were exposed to considerably less vinyl chloride than those experienced by the reactor cleaners. VC con centrations were found to vary between 5 to 20 ppm on the main floor (third floor) of the polymer plant during reactor "loading time. Con centrations within the enclosed control room and office area were 0 to 2 ppm. When all reactor top and bottom manholes were closed, VC concen trations varied from 0 to 4 ppm on the first floor, 0 to 15 ppm on the second floor, and 0 to 15 ppm on the third floor of the Polymer Plant. Overall, the average vinyl chloride exposure for all jobs at the Polymer Plant was estimated at 10 ppm. Although occupational VC exposures for polymer plant workers still exceed the 1 ppm U. S. standard, nevertheless, great advances have been made by CGPC in controlling occupational vinyl chloride exposures ever since the first industrial hygiene survey of February 1974. Prior to 1974, the time-weighted average VC exposure for polymer plant workers was put at 200 ppm, but could be well above 500 ppm. During the indus trial hygiene survey of 1976, the time-weighted average VC exposure for polymer plant workers was reduced to 50 ppm. Now, we found that the average exposure was further reduced to about 10 ppm. This is indeed an extraordinary achievement considering that the government of the Republic of China is still abiding by the old and obsolete 500 ppm per missible VC exposure limit; and most of CGPC's local competitors have done very little to reduce occupational VC exposures in their factories. 4 (0005) 0058. 0007 CUSAROSS 00680 It appears that the next step for CGPC to advance in VC exposure, control is to adopt one of the several automatic reactor cleaning pro cesses currently used by PVC manufacturers in thel). S. and several European countries. As of now. It is unlikely that the 10 ppm CGPC self-imposed vinyl chloride exposure standard can be achieved for reactor cleaners. On the other hand, if routine reactor cleaning is eliminated by adopting an automatic reactor cleaning process, CGPC should be able to meet the current U. S. 1 ppm vinyl chloride standard through extra efforts in maintaining good hygiene practices and control ling fugitive vinyl chloride emissions. 5 (0005) 0058 0008 CUSAROSS 00681 B. MONOMER PLANT Total airborne organic vapor concentrations varied from 0 to 20 ppm at the low pressure distillation tower of the Monomer Plant. Measurements at other locations at the Monomer Plant showed 10 to 20 ppm at high boiling point material storage (#340B), approximately 10 ppm at the VCM transfer pumps, 5 to 15 ppm at Section #300, and 0 to 5 ppm at the methanol distillation area. No vinyl chloride was detected at the laboratory and office rooms, mainly because they are situated on north side (upwind side) of the Monomer Plant's process area. Also, no vinyl chloride was found at workers' resting booth after it was moved wisely to its present upwind location. During the industrial hygiene survey of August 1976, three long-term air samples collected along the walkway near the high-boiling-point materials unloading station showed VC concentrations at 60, 87, and 14 ppm. This time, we found much lower VC concentrations at those loca tions. It is estimated that the average VC exposure for CGPC monomer plant workers might be around 2 ppm, considering that workers do spend a substantial amount of time within office, laboratory and other areas where VC concentrations were very low. Further reduction of occupa tional VC exposures can be achieved through vigorous implementation of the recommended "search and secure" program. 6 (0OO5) 0058. 0009 CUSAROSS 00682 C. "SEARCH AND SECURE" PROGRAM e CGPC has Implemented with success a vinyl chloride "Search and Secure" program as recommended in the 1976 Industrial Hygiene Survey Report. With the cooperation and assistance of process area workers, personnel from CGPC's Industrial Safety and Hygiene Department were able to search and locate VC leakage points and suggest maintenance and repair measures to secure those leaks. For example, in a VCM leakage search survey con ducted between June 29 and July 1, 1977, a total of 64 leakage points were Identified in the polymeratization plant. The #401 VCM measuring tank alone was found to contain 17 leakage points at various places such as pipe flanges, valves and level gauges. After the leakage points were identified, the survey results were sub mitted to the Production Department and Engineering Department. Mainten ance and repair measures were initiated to control and secure the vinyl chloride leaks. Subsequently, a re-survey of the leakage points was con ducted to determine the success of the control measures. For example, a re-survey of the Polymer Plant leakage points was conducted during August 31 and September 1, 1978. Results of this second survey showed that 14 out of the original 17 leakage points on #401 VCM measuring tank were under control and the remaining three points needed further treat ment. Table 1 summarizes activities and results of the "Search and Secure" effort for the #401 VCM measuring tank. Experience at CGPC indicate that to search and locate the leakage points was relatively easy, but to repair and secure the leaks was sometimes rather difficult. What occurred at the fourth floor of the Low Pressure Distillation Tower of the Monomer Plant is summarized in Table 2. There one can see that among the 15 leakage points detected during the initial search survey, only six leaks had been repaired and sfecured by the re-survey time. The remaining nine leaks were either unable to be repaired, or not fully under control after repair. It should.be recognized that successful, implementation of a "search and secure" program will not only result in great reduction of occupational I and environmental vinyl chloride hazards, but produce savings through 7 (0005) 0053. 0010 i i CUSAROSS 00683 feedstock and energy conservation. Therefore, it is recomnended that this program be Implemented with strong support from CGPC management. As of September 1, 1977, there were 86 leakage points at Monomer Plant and 43 leakage points at Polymer Plant waiting to be fixed. ,V; 1 (0005) 0058. 0011 CUSAROSS 00684 TABLE 1 "SEARCH AND SECURE" OF VC LEAKS FOR #401 MEASURING TANK, CGPC POLYMER PLANT Initial Search Survey Conducted: June 29 - July 1, 1977 Re-survey conducted: August 31 - September 1, 1977 Leakage Points Detected Initial Survey VC Cone, (ppm) at Leak Point 1. Front flange of reflux pipe at tank bottom 2. Back flange of reflux pipe and tank bottom 50 90 3. Valve gland of reflux Pipe 4. Discharging valve gland 1000 > 1000 5. Bottom flange of level pipe 670 6. Upper valve gland of second level gauge 740 7. Bottom valve gland of second level gauge 50 8. Bottom valve gland of third level gauge > 1000 9. Upper valve gland of third level gauge 70 10. Sampling nozzle of third level gauge > 1000 11. Upper valve gland of fourth level gauge 60 12. Safety valve gland at at tank top > 1000 13. Valve gland of charging1 pipe at tank'top > 1000 Maintenance and Repair Measures Taken Packing replaced Packing replaced Screws tightened Packing replaced Packing replaced Screws tightened Screws tightened Screws tightened Screws tightened Nut sealed Screws tightened Screws tightened Packing replaced Re-survey VC Cone, (ppm) at Leak Point 20 20 30 22 0 12 0 320 * 10 14 0 140 * "25` continued next page 9 (0005) 0058. 0012 CUSAROSS 00685 Leakage Points Detected TABLE 1 (continued) Initial Survey VC Cone, (ppm) at Leak Point Maintanance and Repair Measures Taken 14. Valve gland of balance pipe con nected to monomer plant 15. Valve gland of main balance pipe 16. Flange joint before automatic controller 17. Valve gland of heat ing pipe > 1000 740 320 70 Screws tightened Screws tightened Packing replaced Screws tightened Re-survey VC Cone, (ppm) at Leak Point 30 0 80 * 12 * indicates further treatment is needed to secure the leak. NOTE: Measurements were made with Century Organic Vapor Analyzer Model 11 SB 10 (0005) 0058. 0013 CUSAROSS 00686 TABLE 2 UNSUCCESSFUL LEAKAGE CONTROL EFFORTS AT FOURTH FLOOR OF LOW PRESSURE DISTILLATION TOWER, CGPC MONOMER PLANT ---------------------------------------------------------------- Initial Search Survey conducted: June 22 - June 28, 1977 Re-survey conducted: August 18 - August 20, 1977 . --------- - . ........" .................................... -- Leakage Points Detected Initial Survey VC Cone, (ppm) at Leak Point Maintenance and Repair Measures Taken Re-survey VC Cone, (ppm) at Leak Point '-'-Joo * 1. Valve gland for exhaust gases discharge at #329 separator 2. Defreezing valve at #326 inlet 3. Pressure gauge cock at #326 freezer inlet 4. Safety valve gland of #325B freezer 5. Gland & upper flange of nozzle valve at #325B freezer outlet 6. Pressure gauge gland at 325B freezer 7. Gland & bottom flange of inlet valve at #325B freezer 8. Nozzle valve at #328 separator 9. Pressure gauge adaptor at #325A freezer 10. Cock gland of pressure gauge at #325A freezer 11. Nozzle valve at #325B freezer inlet 12. Nozzle valve at 325A freezer outlet >1000 700 >1000 >1000 450 >1000 >1000 >1000 800 850 >1000 >1000 Unable to control Unable to control Cock tightened Screws tightened Screws tightened Screws tightened Screws tightened Valve tightened Valve tightened Screws tightened Valve tightened Valve tightened > 1000 * > 1000 * 0 650 * 100 * 30 0 > 1000 * 300 * 0 0 contined next page 11 (0005) 0058. 0011 CUSAROSS 00687 Leakage Points Detected Table 2 (continued) Initial Survey VC Cone, (ppm) at Leak Point Maintenance and Repair Measures Taken Re-survey VC Cone, (ppm) at Leak Point 13. Nozzle valve at #319 freezer inlet 14. Valve gland of level gauge duct at #319 distillation tower 15. Valve gland of level gauge duct at #320 distillation tower >1000 400 250 Unable to control Packing replaced >1000 * 0 Had not treated >1000 * * Indicates further treatment is needed to secure the leak } NOTE: Measurements were made with Century Organic Vapor Analyzer model 118B 12 (0005) 0058. 0015 CUSAROSS 00688 D. VINYL CHLORIDE SAMPLING BY CHARCOAL TUBE Besides vinyl chloride measurement with portable organic vapor analyzer, extensive air sampling effort was made during this survey to evaluate workers' vinyl chloride exposures. A total of 56 long-term air samples were collected with charcoal adsorption tubes from various locations and from many workers (personal samples). We expected to see high VC con centrations (10 to 50 ppm) for a few selected air samples such as those collected from reactor cleaners. However, laboratory analysis showed that all 56 samples had virtually no vinyl chloride. There does not appear to be a good answer to the absence of vinyl chlor ide on the charcoal tubes. Dr. James 0. Jackson, Director of Industrial Hygiene Laboratory, suggested that aircraft partial depressurization in the.cargo chamber could have caused desorption of the collected vinyl chloride from the charcoal tube during sample shipment. Had depressuri zation occurred, the reported organic solvent vapor concentrations could also be lower than the true concentrations. However, vinyl chloride, being a gas at standard temperature and pressure, would have desorbed faster and more completely than solvents such as MEK and toluene. A copy of Dr. Jackson's letter and raw data of laboratory analytical results are Included in this report as Appendix 1. We are very sorry that this bizarre event has occurred. It is recommended that CGPC's Industrial Safety and Hygiene Department should periodically send parallel charcoal tube air samples of vinyl chloride and solvent vapors to Gulf's Industrial Hygiene Laboratory for comparative analysis. 13 (0005) 0058. 0016 CUSAROSS 00689 III. SOLVENT VAPOR EXPOSURES A. PRINTING SHOP The third printing machine, a five-color printer, has been added to the Printing Shop since the last survey of August 1976. Solvent vapors, mainly those of toluene and MEK evaporated from printing ink troughs and the PVC fabrics, were readily detectable by odor. Total organic vapor concentrations, as measured with an organic vapor analyzer, ranged from 50 ppm inside the enclosed office to over 1000 ppm at several work places beneath the six-color printer. Occupational solvent vapor exposures were also evaluated with charcoal adsorption tubes and portable personal air samplers. Twenty-four air samples were collected from workers in the Printing Shop and Leather Shop. However, because of contamination and desorption that occurred during sample shipment, the laboratory analytical results are simply presented in Appendix 1 without interpretation. Five-Color Printer. Slotted local exhausters have been installed below every ink trough of the new five-color printer. The exhausters are of the proper type and are cleverly designed for the tight space. However, they all have very inadequate air-moving capacities. As measured with Century Organic Vapor Analyzer, the total organic vapor concentrations often exceeded 500 ppm at spaces between ink troughs. The maximum allow able airborne concentrations for MEK and toluene are 200 ppm and 100 ppm, respectively, according to the Chinese Standards, The Chinese Governmental regulation on industrial ventilation mentioned that ventilation hoods should have 0.5 meters per second ('vlOO ft/min) capture velocity. This is a simple, yet adequate, rule of thumb, but the catch word is "capture velocity." Capture velocity may not be equivalent to the hood face velocity. Capture velocity is the air-moving velocity at a point in front of the hood where one wishes to catch and control the air contaminants. Thus, for an ordinary laboratory hood, 14 (0005) 0058. 0017 CUSAROSS 00690 the capture velocity Is equivalent to the face velocity; for an over head canopy hood, the capture velocity may be roughtly the same as the face velocity; but for a slotted exhausting hood, the capture velocity Is not the face velocity at the slot opening. Judging by the distance between the slotted exhauster and the top of the ink trough, it is believed that the desired slot velocity (face velocity at the slot) should be at least 5 meters per second. Therefore, try to increase the present exhausting capacity by about ten times. Many slot openings of the slotted exhausters were plugged up by glue and ink. Routinely scheduled maintenance is needed to keep the slots clean. Four-Color Printer. The airborne concentration of solvent vapors around and under the four-color printer varied between 100 ppm to 300 ppm as total organic vapors. But it should be noted that anywhere in.the Printing Shop, the total organic vapor concentration may be 100 ppm and above. One reading in the center aisle between the four-color printer and the six-color printer showed 500 ppm. The five wall-mounted exhaust fans were fairly effective in reducing solvent vapor concentrations at the four-color printer. In fact, it is believed that those five wall fans were mainly responsible for moving contaminated air out of the Printing Shop and providing needed dilution ventilation to this large room. Six-Color Printer. The local exhaust ventilation system for the sixcolor printer was partially disassembled during the survey time. Con centrations of total organic vapors exceeded 500 ppm at spaces between Ink troughs. Again, when slotted exhausters are installed here for controlling solvent vapors emitting fromthe ink troughs, the slot air velocity should be at least 5 meters per second. Huge quantities of solvent vapors are emitted fromthe travelling PVC fabric, coated with wet Ink on both sides of the cloth. It is physi cally Impossible to design a local exhaust system to catch all solvent vapors before they disperse into the work-place air. The slotted hood 15 (0005) 0058. 0018 CUSAROSS 00691 j !o * exhuasters, which are good for controlling solvent vapors emitting from the ink troughs can not effectively control solvent vapors evaporated from the travelling fabric. Additional fresh air should be supplied to the Printing Shop to dilute the solvent vapor concentrations. Dilution ventilation in the form of roof exhausters, as suggested in the 1976 Industrial Hygiene Report, should be re-evaluated. Other venti lation design ideas, e.g., wall-mounted exhausters with ductwork extend ing to the adjacent Leather Shop, or fresh air supplied to the working zone through a blower and ductwork system, should also be considered. Ink Preparation Room. The ventilation system for the ink mixers in the Ink Preparation Room was well designed. The system consisted of four ink mixer side-exhaust hoods connected by ductwork to a single blower. A damper was installed on each of the four branch ducts so that each hood can be controlled separately. The operator of the mixers has been Instructed to shut a damper when its hood was not in use, thus increasing the exhaust capacity at the remaining ink mixer hoods. There was almost no solvent odors in the Ink Preparation Room. The operator, Mr. Lin, was very health-and-safety conscious, and the room was in good housekeeping order. All ink and solvent containers were neatly stored. Containers were capped when not in use, thus avoiding unnecessary evaporation of the solvents. B. LEATHER PLANT Housekeeping conditions around the five surface treating machines in the leather plant were exactly the opposite of those in the ink prepar ation room. The worst was observed at #3 and #5 surface treating machines where dozens of ink and solvent containers were randomly placed, most of them with caps fully open. The floor around each of ' the machines was wet with ink, glue, and solvent spills. 16 (0005) 0058 0019 CUSAROSS 006o: Installation of local exhaust hoods at the surface treating machines have mostly been completed. Typical solvent vapor concentrations around a machine operator's breathing zone, measured as total organic vapors, have been reduced roughly five times from the old (prior to 1974) 200 ppm 500 ppm level to the present 40 ppm - 150 ppm level. Better solvent vapor control can be accomplished if the downdraft slotted hood on #3 surface treating machine could be moved closer to the ink trough. Vapor concentrations at #4 surface treating machine can be fur ther reduced if a side-draft hood could be installed on this machine in addition to the existing downdraft hood. C. POLYURETHANE PLANT The Polyurethane Plant was not in operation during the time of this industrial hygiene survey. However, measurement of solvent vapor con centrations were conducted by CGPC's Industrial Safety and Hygiene Depart ment on July 12, 1977. Results of that survey, presented in Table 3, clearly indicate excessive solvent vapor exposure. Besides MEK and toluene, large quantities of dimethylformamide (DMF) were also consumed in the production of polyurethane leather. The maxi mum allowable concentration for DMF is 10 ppm, compared to 200 ppm for MEK and 100 ppm for toluene. DMF at excessive concentrations can cause gastric irritation and pain, nausea and headache, and liver and kidney damage. Prolonged skin contact will cause dermatitis. The Polyurethane Plant is located upstairs of the Fabrication Plant. During summer time, the temperature inside the PU Plant is unbearably hot. Ventilation system for the PU plant, therefore, should be designed for heat relief as well as for solvent vapor reduction. High capacity roof fans may be used for heat reduction and general dilution ventilation, while local exhausters should be installed near the major solvent vapor emission points to reduce workers* solvent exposures. 17 (0005) 0058. 0020 CUSAROSS 00693 TABLE 3 TOTAL ORGANIC VAPOR CONCENTRATIONS AT CGPC POLYURETHANE PLANT Survey Date: July 12, 1977 Instrumentation: Century Organic Vapor Analyzer 118B Surveyor: Mr. 0. H. Huang, CGPC Location of Measurement Office desk Ink preparation area No. 1 coater, ink trough No. 1 coater, South side No. 1 coater. North side No. 2 coater, paste trough No. 2 coater, South side No. 2 coater, North side Floating knife coater, paste trough Laminator, South side Laminator, North side Total Organic Vapor Concentration (ppm) 2.6 30 - 42 22 - 26 100 - 160 220 - 400 20 - 28 >1000 >1000 300 - 600 >1000 >1000 18 (0005) 0058. 0021 CUSAROSS 00694 Isocyanates are often used to manufacture polyurethane foams. Two compounds have been incriminated as causes of occupational asthma. These are toluene diisocyanate (TDI) and diisocyanatodiphenyl methane (MDI). The permissible exposure limit for both is 0.02 ppm as ceiling value. Although CGPC reported none of the above isocyanates was used in its PU Plant, it is possible that they might be contained in one of the many types of additives purchased under trade names. Anyway, please keep alert. 19 (0005) 0058. 0022 CUSAROSS 00695 IV. MERCURY EXPOSURES Chlorine is manufactured by the electrolysis of salt brine in 36 mer cury cells in the Chlor-Alkali Plant. Work-place mercury vapor concen trations have been in the decrease since the first industrial hygiene survey of 1974. Opening up of all windows on both sides of the mercury cell building and installation of local exhaust ventilation systems were effective in reducing occupational mercury exposures. An air sampling survey of airborne mercury concentration was conducted on November 2, 1977 at CGPC's Chlor-Alkali Plant. The samples were col lected by drawing air through an impinger containing a potassium perman ganate (KMn04) solution acidified with H2SO4. Mercury vapor and inorganic mercury compounds were absorbed, and the quantity of mercury later de termined by atomic absorption method in the laboratory. Table 4 summarizes results of the mercury survey. All three air samples showed less than 0.002 mg/m^ of mercury concentration. The permissible 3 occupational mercury exposure limit is 0.05 mg/m for eight-hour con tinuous exposure. (Chinese and U. S. have the same standard). There fore, as sampled on November 2, 1977, the occupational mercury exposures at Chlor-Alkali Plant were well withinthe permissible level. It should be noted that all windows on both sides of the Chlor-Alkali Plant's main floor were opened, and the wind speed was fairly strong (4 meters/second) during the air sampling time. The flake-caustic soda machines in the basement of the Chlor-Alkali Plant were out of service for many months and may not resume operation due to lack of market demand for flake soda. Previous hygiene surveys have shown that mercury vapor concentrations were excessively high around the flake soda machines. It is believed that occupational mer cury exposures at CGPC will remain at safe levels as long as the two flake-soda machines remain inactive. Should the flake soda machines resume production in the future, however, it is recommended that the manufacturing operation be moved out of the basement. The mercury vapor concentrations are simply too high in the 20 (0005) 0058. 0023 CVSAROSS 006Uf TABLE 4 AIRBORNE MERCURY CONCENTRATIONS AT CGPC's CHLOR-ALKALI PLANT FIELD SAMPLE NUMBER 6 7 8 9 BLANK SAMPLE DESCRIPTION Type / Location N. of #21 Mercury Cell N. of #5 Mercury Cell S. of #5 Mercury Cell S. of #21 Mercury Cell SAMPLE VOLUME Liters MERCURY CONCENTRATION mg/m3 660 666 defective sample 670 0 <0.002 <0.002 <0.002 .Sampling Method: Wet absorption in KMn04 - H2SO4 solution with Midget Impinger Analytical Method: Atomic Absorption Detection Limit: One microgram of mercury Results: All samples showed below detection limit mercury concentration Occupational Exposure Standard = 0.05 mg/m3 21 (0005) 0058. 0024 CUSAROSS 00697 basement for effective ventilation control. In addition, the workers are exposed to excessive heat, humidity, and dusts of caustic soda. For temporary, short-duration exposures to high mercury vapor concentra tions such as during maintenance and clean-up of the mercury cells, it is suggested that proper types of respiratory protective equipment be worn by the workers. Substantial protection can be provided by dis posable 3M brand Mercury Vapor Respirator #8707. A manufacturer's des criptive bulletin for this respirator is enclosed as Appendix 2 of this report. 3M has sales representatives in Taipei. 22 (0005) 0058. 0025 CUSAROSS 00698 V. LEAD, BARIUM, CADMIUM AND CHROMIUM Lead, barium and cadmium stearates are added to the PVC resin as stabilizers to avoid disintegration of PVC in later fabrication processes. Compounds of chromium, iron, titanium, lead, etc. are added to the PVC resin as dyes and pigments. Weighing and mixing of these compounding materials are handled in the Compounding Ingreadients Mixing Room located on the second floor of the Extrusion Plant. Airborne suspended particulates samples were collected with Millipore- type AA membrane filters and analyzed for chromium, lead, barium, and cadmium. Table 5 presents results of the airborne concentrations of these toxic metals. The current OSHA permissible occupational exposure 3 limits in the United States are 0.05 mg/m for chromate compounds, 0.15 33 3 mg/m for lead, 0.5 mg/m for barium, and 0.05 mg/m for cadmium. .Except for lead, the airborne concentrations of chromium, barium and cadmium were, in general, within their respective permissible occupa tional exposure standards. A. CHROMIUM Air sample #808, collected at the master batch mixer, showed 0.39 mg/m^ of chromium and 2.2 mg/m^ of lead. It appears that the excessively high concentrations of both lead and chromium was due to the use of lead chromate pigments. According to information supplied by manufacturers, the following pigments in CGPC contain chromates: CGPC Catalog Number 6-21A 6-81C 6-83D Product Trade Name Molybdate Orange P-380 Chrome Yellow GL Chrome Yellow 10G Chemical Components PbCrOd, PbS04 PbMo04 CGPC Annual Consumption 25 short ton PbCr04 (87^ min) 34 short ton PbCrO. (50% min) 15 short ton PbS04 (43% min) 23 (0005) 0058. 0026 CUSAROSS 00699 Table 5 OCCUPATIONAL EXPOSURES TO OUSTS OF CHROMIUM, LEAD, BARIUM ANO CADMIUM at CGPC EXTRUSION PLANT AND TAOYUAN PLANT FIELD SAMPLE HUMBER 796 797 798 799 801 802 803 804 805 808 810 811 812 813 815 816 SAMPLE DESCRIPTION Type/Location Blender ?Z calendar of film plant Blender ?4 calendar of leather Blender #6 calendar of tile floor Blender cl calendar of film Blender #3 calendar of film Blender ?8 calendar of leather Blender *7 calendar of film Blender f5 calendar of film Blender of P'/C ccmoound machine Mixers of Master Batch Stabllizer preparino room.extrusion plant Middle between 31C2 ABC mixers Middle fcetv/een 31C2 DEF mixers Middle between 3103 ABC blenders Middle between 3103 DEF blenders Operator of 3102A mixer, 3103A blender CHROMIUM m9/m3 LEAD i^/m3 BARIUM m9/m3 CADMIUM rcg/n3 <0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 " 0.01 0.39* 0.03 < 0.01 < 0.01 * 0.01 < 0.01 < 0.01 < 0.01 < 0.01 0.68* < 0.01 < 0.01 < 0.01 0.07 < 0.01 * 0.01 2.2* 5.5* 0.22* < 0.01 0.23* 0.93* 0.73* o o V < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 3.1* < 0.01 < 0.01 < 0.01 < 0.01 2.6 * < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 0.03 < 0.01 < 0.01 0.01 < 0.01 < 0.01 24 (0005) 0058. 0027 CUSAROSS 00700 FIELD SAMPLE NUMBER 317 319 820 821 307 809 814 818 822 805 SAMPLE DESCRIPTION Type /Location TABLE S (continued) CHROMIUM mg/m^ LEAD mg/mJ Worker of Stabilizer com pounding room Operator of RC 100 extruder Operator of 310G Mixer Worker of PVC vaste pipe crushing of reborn room `15 5C0L Ribbon Slender operator employee 66973 Taoyuan Plant =11 300L Super Mixer operator employee 66949 Taoyuan Plant N.W. of *11 Suoer Mixer Taoyuan Plant 10GOL Ribbon Slender operator employee 629C3 Taoyuan Plant BLANK BLANK <0.01 <0.01 ,0.01 <0,01 <0.01 <0.01 <0.01 <0.01 - _ 0.50* 0.C8 0.33* <0.01 0.05 0.05 0.11 C.05 - _ Simple Matrix: 0.8 y Type AA filter Analytical Method; Atomic absorption BARIUM CADMIUM <0.01 <0.01 <0.01 <0.01 0.05 0.05 , <0.01 <0.01 - * 0.03 <0.01 <0.01 <0.01 <0.01 0.03 0 02 Q.C4 - _ * Concentration exceeds threshold limit value 25 (0005) 0058. 0028 CUSAROSS 00701 In December 1975, the U. S. National Institute for Occupational Safety and Health (NIOSH) declared that certain forms of hexavalent chromium, including lead chromate, have been found to cause increased respiratory cancer mortality among workers. NIOSH recommends that exposure to those carcinogenic hexavalent chromium be not greater than one microgram per cubic meter of air (1 yg/nv^). In the United States, the Dry Color Manufacturers Association has formed a Lead Chromate Task Force which has advised their employees and cus tomers to prudently reduce chromate pigment exposure to the lowest prac tical level. In dealing with a proven human carcinogen such as lead chromate, an airborne concentration of 0.39 mg/^ (as Cr) is totally unacceptable. It is recommended that CGPC should make a strong effort to replace dyes and pigments that contain lead and zinc chromate. If that is not feasible, then stringent control measures should be implemented to reduce occupational exposures to a minimum. Attached to the report as Appendix 3 is the NIOSH Recoirmended Standard for Occupational Exposure to Hexavalent chromium. Until a new OSHA chromate exposure standard is published, please use this NIOSH criteria document as a guideline for control. 26 (0005) 0058. 0029 CUSAROSS 00702 B. LEAD Results in Table 5 indicate approximately one-third of the air samples showed airborne lead concentrations exceeded U.S. OSHA's 0.15 mg/m^ lead exposure standard. (It is believed that Chinese have the same lead standard.) Among personal air samples, the highest lead concentration was 0.73 mg/m3 for sample #816, which was collected at the stabilizer preparation room of the Extrusion Plant. The following comments and suggestions are based on observations at the Extrusion Plant and the air sampling results: 1. Employees in the Compounding Ingredients Mixing Room and other potential dust exposure areas wore dust respir ators. Therefore, actual dust inhalations by employees in those areas were significantly below the exposures indicated by air sampling results. 2. Floors, walls, and other surfaces in the Extrusion Plant, especially inside the Compounding Ingredients Mixing Room, were covered with a coat of powdery material. No doubt, most of the powders were dusts of PVC resin. But there could be significant amounts of lead dust mixed with the PVC resin dusts. Re-entrainment of the settled lead dusts by foot traffic and air currents could have created high air borne lead concentrations. 3. Effective local exhaust hoods have been installed for all compounding ingredient mixers following suggestions made in the 1974 industrial hygiene survey report. These sidedraft slotted hoods have reduced the work-place concentra tions of dusts of toxic metals. 4. Weighing of compounding ingredients, including dyes and pigments, were conducted within a walk-in booth which was exhausted with a wall fan. This is a correct ventilation arrangement, although the position of the wall fan could be lowered and the capacity of the fan increased for even better dust control. 27 (0005) 0058. 0030 CUSAROSS 00703 5. CGPC's industrial hygiene laboratory should have field and laboratory equipment for measuring airborne particulates concentrations of lead, cadmium, barium and chromium. High flow rate personal air sampling pumps and filters should be acquired for capturing the suspended particulates, and proper analytical instruments (e.g., atomic absorption) for deter mining trace metal concentrations, 6. Enclosed as Appendix 4 is U.S. NIOSH recommended standard for occupational exposure to inorganic lead. Please use this document as a guideline for control of lead exposures. C. BARIUM AND CADMIUM Review of results in Table 5 indicate that only two air samples showed airborne barium concentration exceeded threshold limit value of 0.5 mg/m3. All air samples showed airborne cadmium concentrations within its thresh old limit value of 0.05 mg/m^. Barium and cadmium exposures would be further reduced when measures were taken to lower occupational lead exposure. 28 (0005) 0058. 0031 CUSAROSS 00704 VI PLATING SHOP Hygiene conditions in the Plating Shop were worse in November 1977 than August 1976. The side draft ventilation hood and the blower for the chrome plating tank were taken down for two months without replacement. A wall fan on the farther end of the room was broken down but not replaced either. Airborne concentration of acid fumes (chromic and sulfuric) were so strong thatworkers complained about eye, nose, and throat irritation. A few persons, including this author, coughed and chocked during the short time this walk-through survey was made. Acid corrosion might be the main cause for the breaking down of the exhausting fans in the Plating Shop. The replacement blower and wall fan should have-plastic fan blades or blades coated with inert material such as epoxy resin. It was noticed that there were more activities and more workers (both men and women) inside the Plating Shop. A few of them were without proper eye and body protection. It is believed that the wearing of eye goggles, acid-proof gloves, boots, aprons or other appropriate pro tective clothing shall be made mandatory for Plating Room workers. Next to the Plating Shop are the darkroom and the art design and engraving room. A solvent dipping tank (for washing the rollers) should be equipped with a slotted exhauster along the length of the tank to control solvent emissions. This has been discussed with the Plating Room supervisor. 29 (0005) 0058. 0032 CUSAROSS 00705 APPENDIX 1 LABORATORY ANALYTICAL RESULTS OF CHARCOAL TUBE SAMPLES OF VINYL CHLORIDE AND SOLVENT VAPORS 30 (0005) 0058. 0033 CUSAROSS 00706 internal correspondence L-3UO from 0 cl 1710 S 0. Jackson to R. T. Cheng, Ph.D. AT San Diego subject China Gulf Plastics Corporation Visit of November, 1977 date January 23, 1978 reference F//-2b 1 IHL-77-270 & IHL-77-268 The Industrial Hygiene Laboratory has reviewed the data generated from samples submitted by you from your November, 1977 visit to China Gulf Plastics Corporation. The absence of vinyl chloride on the charcoal tubes leads to the conclusion that an anomaly has occurred and unfortunately no good explanation is available. . At your request, the Industrial Hygiene Laboratory has reviewed the data from Sample No. F77-251. The following observations can be made: 1. Samples were received in a single wooden box. This wooden container contained both the bulk material and the charcoal tubes, although they were each packed in separate cardboard boxes. As we have discussed, the Shipping Department at General Atomic probably repacked your two cardboard boxes into the one wooden box. 2. Both bulk samples of toluene were empty when received and both polyethylene bottles were collapsed. The other bulk liquid materials were intact in their containers. 3. Both field blanks submitted by you had substantial amounts of toluene on both the front and the back layers. Laboratory blanks, which were added to the samples submitted upon arrival, contained no toluene or any other chemicals. 4. Toluene was observed to be contaminated on all submitted charcoal tubes. There appears to be a consistent contamination level on all tubes of 100-200 ug of toluene. The above statements lead us to believe that toluene escaped from the containers and was deposited on the charcoal tubes. Because you stated that all bulk material bottles were intact when you packed them for delivery to the Industrial Hygiene Laboratory, and because the toluene bulk material bottles were collapsed when they arrived at the Industrial Hygiene Laboratory, it seems that an unexplained event occurred between shipment from San Diego and arrival in Harmarville. One probable cause of this could have been aircraft depressuriza tion, although we have no way of evaluating this phenomenon. Had depressurization occurred, it is quite probable that vinyl chloride would have desorbed preferentially because it is a gas at STP. 31 (0005) 0058. 0034 CUSAROSS 00707 date 1/23/78 prom James 0. Jackson to R, T. Cheng, Ph.D. sheet no 2 As a further evaluation of this problem, the pumps you used in Taiwan were re-calibrated. The calibrations were unchanged and the sample volumes were confirmed. The vinyl chloride methodology was analytically confirmed by gas chromatography and mass spectrometry by the Harmarville Research Laboratory. The lot of charcoal which you used in Taiwan was also re-evaluated and good recovery was again found. Unfortunately, there does not appear to be a good answer to the absence of vinyl chloride on these charcoal tubes. The amount of toluene that was found on the charcoal, added to the other solvent amounts discovered, is probably not sufficient to have caused the displacement of vinyl chloride. Please feel free to contact us any time and we would be most interested in your comments on this matter. JOJ/gb cc: R. L. Gibson, M.D. ^ TWiJame a SuGStO'AR* or CiULf Oil COBCQfliTiON (0005) 32 0058. 0035 TElEPmO*S 4i2 / CUSAROSS 00708 " ^0 0 5 8 . :1 ^ 0 0 3 6 SPONSOR: * T* Chens UNIT/LOCATION: Personal/Area FACILITY: Culf China Plastics Corporation SAMPLING DATE(S) : November 2,3,4,5,7,8,9,10 r (000%`r IH LAB SAMPLE NUMBER FIELD SAMPLE SAMPLE DESCRIPTION NUMBER TYPE/LOCATION SAMPLE VOLUME LITERS IF 77-27QA Blank Submitted NA IHL-77-270B IHL^ZItIZAC,, IHL-77-27QD IHl.-77r27QE IHL-77-270F IHL-77-27QC IHL-77-2 70H IHI-77-2701 l IHL-77-270J IHL-77-270K IHL-77-270L Blanh 10 II 12 Submitted NA Lab Blank NA 0. C. Tube NA Instrument Control Operator 59110_____28 Operator of VCM rharclng 58116 I'VC slurrv dis charging bperatcr tJorller, PVC seale 24 25 Cleaning 66124 28 Worker, PVC sea lie Cleaning 59113 28 Operator, VCM Charging, 58116 46 Onerator, PVC slurry dlschargi ng 45 Operator, Instn me n Control 59110 45 SAMPLE MATRIX: Charcoal tubes ; ANALYTICAL METHOD: .ANALYST: fL ^3^LAB PIR/SUPVR: {l- ^cc: HTM/fllc NIOSH P&CAM 127 VINYL CHLORIDE PPM .HSIHIL. ETHYL KETONE PPM BENZENE PPM METHYL ISOBUTYL KETONE PPM TOLUENE PPH CYCLO HEXANONE PPM TR 0.001 mg TR 0.001-mg 0.091 mg TR TR 0.165;mg TR 0.059 mg TR BDL BDL TR BDL BDL TR BDL BDL TR BDL BDL TR' TR BDL TR BDL BDL TR BDL BDL TR BDL BDL TR TR 1.0^ TR 1.1- TR 1.3TR 1.4 TR l.r TR 0.60 TR 0.82' TR 0.82 BDL BDL BDL BDL BDL BDL BDL BDL BDL=Below Detection Limit; NA*Not Applicable; . TR=Trace COMMENTS: There appears to be a Toluene contaminant on the front and backup sections of all submitted charcoal tubes ranging from 0.025-0.2 mg. The values reported include this contaminant. 2 Breakthrough occurred. CUSAROSS 00709 SPONSOR: R* T* Cheng o UNIT/LOCATION: Personal/Area ^J 0037 0058. (0005) --rirr/vu imn-- SSHFIE------SAMPLE SAMPLE DESCRIPTION NUMBER NUMBER TYPE/LOCATIOf Sample VOLUME LITERS PVC Scale IHL-77-270M 133 Cleaning 66124 IKL-77-270N IP 77-270# 14 15 PVC Scale Cleaning 59113 VCM charging operator 61276 . 43 26 IHL-77-270P 16 PVC Scale Cleaning 64348 24 IHL-77-2700 17 PVC Scale Cleaning 58109 26 IHL-77-270R >. PVC Slurry dis charging 65297 23 IHL-77-270S 19 Laboratory of General Plant 870 Ink stirring 02 IHL-77-270T 20 s urface TM.56160 25 IHL-77-270U 21 ' Ink stirring 03 s uVface TM.61270 24 1HL-77-270V 22 Ink stirring 04 STM 60222 24 IH' 77-270W 23 Ink stirring 15 STM 58213 23 IHL-77-270X IHL-77-270Y Ink stirring 05 24 STM 58260 22 Ink stirring of 4 26 col or printer.6422 11 IKL-77-270Z IHL-77-270A? I lk stirring of 5 27 col >r or Inter.6412. 11 Foreman of 6,4, 28 col jr printers. 27. 132 7.9 TOT CHLORIDE PPM BDL kPTHYT. ETHYL KETONE PPM BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 2.2 BDL 0.01 BDL 98 BDL 18 TR BDL BDL 5.0 BDL 5.7 BDL 23 ___BUI______ _JL5__________ CQMnENTS: ^ Field data sheet reports this as a"defectlve sample." BENZENE PPM ... METEYT___ ISOBUTYL KETONE PPM TOLUENE PPM CYCLO HEXANONE PPM TR TR 0.152 2rs> BDL TR TR 0.962 BDL _ t TR TR _ 1,12 BDL TR TR 0.342 Q.90 . TR TR 1.42 BD1. TR TR -; 0.962 ____ BDL_____ TR 0.05 0.21 0.07 0.61_____ 0-03___ _ _ 5.12_____ ____ Bill........ 0.12 0.05 TR 17 -13 .. -- 0.74 4.2 f ___ LA______ ____L22___ TR ...I,a2_____ BDL 0.03 ___ l.s -- 2.1_____ 0.09 0.03 0.12 0.07____ 1.1 22 3-9 ...,62 . .. 3.8_____ 63 BDL_____ , ____ QJ12____ 0.05 T. Cheng QUNIT/L^fT ION: Personal/Area llf'LAU ~iTi:nr* SAM FIX SAMPLE SAMPLE SAMPLE DESCRIPTION VOLUME NUMBER NUMBER TYPE/LOCATIOIf LITERS 'Tinted Ware Park.Inf IHL-77-270B2 29 Workman 65360 8.8 Laboratory of IHL-77-270C2 30 Monomer Plant 610 7."ol uuh uistnrati on IH1 77-270D, 31 tower. Monomer Plant 610 S', of iTjuu K dlvls on IHL-77-270E2 32 of Monomer Plant 610 1HI.-77-770F2 IHL-77-270C? IHL-77-270H2 1HL-77-270I, 1HL-77-270J-, IHL-77-270K? IF 77-270L? IHL-77-270M2 IHL-77-270N, 1HL-77-27O0? IHL-77-270P2 33 34 35 36 37 38 39 40 41 42 43 Ink stirring #2 STM 56160 Ink stirring It3 STM 61270 Ink stirring #4 STM 60222 Ink stirring 05' STM 53213 Ink stirring 05 STM 58260 Ink 6tlrring of 6 'olor printer, 57133 Ink stirring of 4 rolor printer, 64211 Ink stirring of 5 rolor printer, 64125 foreman of 6,4,5 olor printer, 57132 'rinted film ware packing 65360 Guarding Booth, be side Main Office 45 45 45 45 45 23 13 22 16 22 850 VINYL CHLORIDE PPM BDL BDL BDL BDL BDL BDL BDL TR BDL b6l BDL BDL BDL BDL BDL COrL'iLNTSt METHYL ETHYL KETONE PPM 2.2 BDL BDL BDL 142 782 1602 BDL 8.2 682 67 502 80 2.1 BDL BENZENE PPM METHYL IS0BURYL KETONE PPM TR 0.72 TR TR TR TR TR 0.05 0.07 TR TR 2 32 4.4 13 0.01 0.01 0.03 0.14 1.8 7.3 0.19 0.14 0.16 0.01 TR 6.1 4.3 3.3 0.51 TR CtnO. * TOLUENE PPM 17 o.io2 0.292 Q.U2 1302 CYCLO HEXANONE PPM BDL BDL BDL BDL 1.3 1.6 36 0.952 1.0 2.0 BDL 4.4 99 100 85 0.25 0.15 ' 0.12 0.08 50 . 13 0.082 0.10 BDL BDL (0005) 0058. 0038 S CUSAROSS 00711 SPONSORt R. T. Cheng o UNIT/LOCATION; Personal/Area V 0058. "^0039 (0005) nr cab SAMPLE NUMBER IHL-77-270Q2 IHL-77-270P-2 IH 77-270S2 "HELD --------- sahpee------------- SAMPLE DESCRIPTION NUMBER TYPE/LOCATION SE 1ST. 44 Class Dormitory 1 NW 4th. 45 Class Dormitory iTI tence .46 Carpenter Shop SAMPLE VOLUME LITERS 830 800 810 METHYL ' --Tim-- --ethyt-- CHLORIDE KETONE . PPM PPM BENZENE PPM BDL BDL TR BDL 0.01 TR BDL BDL TR METHYL ~ rsturcTYL-"" KETONE PPM TR TR TR IHL-77-270T2 47 ' IHL-77-2701'2 48 IHL-77-270V2 49 IHL-77-270W? 50 Il!!.-77-270Xi 51 IHL-77-.270Y? 52 IHL-77-270Z2 53 IH' 77-270A-1 54 IHL-77-270B-, 55 IIIL-77-270C-) 56 II1L-77-270D3 57 IHL-77-270E3 58 VCM Tank Cars Instrument Control Operator 59110 PVC Slurry dis charge 59019 PVC Scale Cleaning 66124 PVC Scale ' Cleaning 59113 Office of Polymerization 3rd. Floor Poly merization Bldg. Polymerizer 2nd. floor pf P.P. 1st. floor of Polymerizer Plant Workmen rest area of PP instrument Control 59110 Operator, PVC discharging 59019 840 13 12 9 12 58 50 50 50 49 23 22 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL TR TR 0.03 TR TR 0.01 ' TR TR TR 0.01 TR TR TR TR TR TR TR TR TR TR TR TR 0.01 0.01 TOLUENE PPM 0.082 0.142 f TR2 0.072 4.72 5.82 5.42 5.92 0.582 0,77^ 0.812 0.942 0.84 2 - 2.62 2.72 COMMENTS l '' / Co cr> LiLU)HEXANOSf PPM BDL BDL "1 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL ^ SPONSOR* R' T* ^ UNIT/LOCATION: ; AreaPersonal/ f ^ * 0058. '-.-0040 III L/\I3' SAMPLE NUMBER IHL-77-270F-, IHL-77-270Ca IH '7-2 70111 1HL-77-270I1 IHL-77-2 70Ji IHL-77-2 70Ki IHL-77-2 70Li IHL-77-270M-, ' IHL-77-r270Nt IHL-77-27O0i IH1 77-270Pi , IHL-77-270Q3 IHL-77-270R3 IHL-77-270S-1 IHL-77-270T3 eTEld ---------SAM PCS--------- --- SAMPLE SAMPLE DESCRIPTION VOLUME NUMBER TYi'E/LOCATIO.f LITERS PVC Scale 59 Clennine 66124 16 PVC Scale 60 Cleaning 59113 21 Office of 61 Monomer Plant 330 Booth of 62 Monomer Plant 330 CH3OII distillation 63 area, Monomer Plant 330 2500 T 64 VCM Sphere 310 500 l 65 VCM Sphere 310 4th floor, low P 66 distillation tower 13 Jrd, floor, low P 67 distillation tower 13 2nd. floor, low P 68 distillation tower 9 1st. floor, low P 69 distillation tower 12 VCM transfer 70 pumps 21 -Control Room 71 refriteration Plant 20 S, fence by Poly 72 merization pilot pl< nt 480 S. fence beside 73 Sprpenter Shop 520 VINYL CHLORIDE PPM BDL 'BDL BDL BDL BDL BDL BDL BDL BDL BbL 0.01 BDL BDL BDL BDL CO*H.nLNTS I METHYL PPMETHYL KETONE BDL BDL BDL TP BDL BDL BDL BDL BDL BDL BDL BDL BDL TR BDL MFTHYT * ^ BENZENE PPM ISOBUTYL KETONE PPM -__ PPM TOLUENE CYCLO HEXANONE PPV TR TR 7.92 R1!. ... TR TR 2-12 - RDI___ TR TR on2 APT- TR TR . TR TR 0.02 TR TR TR TR 0.142 - TR___ TR -Q.122 D TR -0.152__ ___ jam______ TR _ 0.192 ____ aai-------- TR .,.j,:l-- TR Z.72 - BDL TR 3->2 BDL TR 2.52 *___ P2I______ TR 0.01 1.52 BDL TR TR 2.22 BDL TR TR 0.082 BDL TR TR 0.092 BDL (0005) [ l ' ff 11 1 Co ' mil CUSAROSS 00713 j|j| t up jj|g ` X . v|g! i r 1U  O u SPONSOR* R. T. Chena ' - ii! LAD E i ELD SAMPLE SAMPLE NUMBER SAMPLE DESCRIPTION NUMBER TYPE/LOCAT XOfJ SW guard booth by IKL-77-270U3 74 ink prep. m. ^.. lence by IHL-77-270V3 75 wastewater res. "SAMPLE VOLUME LITERS 480 490 IH 77-270W3 IHL-77-270X3 IHL-77-270Yi IHL-77-270Z-, IHL-77-270A/, IHL-77-270Bi, IHL-77-270C4 IHL-77-270Di IHT 77-270E4 76 77 78 79 80 81 82 83 84 Polymerization Plar t Control Room Bottom VCM measuring tank Center aisle, 3rd. floor polv. plant 2nd. floor. Poly-, merizatlon Plant 0421 VCM gas holder polv. PI N. doorway, printing plant Office, printing plant Center aisle, printing plant S. Doorway, printing plant 22 22 *22 22 22 11 11 7.8 9.8 UNIT/LOCATION: Personal/Area Tim CHLORIDE PPM BDL TR METHYL ETHYL. KETONE PPM 0.04 . 0.03 BDL BDL BDL BDL BDL BDL TR BDL BDL BDL BDL 8.5 BDL 0.09 i!dl 4502 BDL BDL BENZENE PPM TR TR TR TR TR TR TR 0.03 TR 0.492 TR METHYL 1 ISOBUTYL KETONE PPM TOLUENE PPM 0.01 0.33 0.01 * .TR 0.24 1.9? . TR 2.42 -TR 1.62 TR _ 1.62 TR 1.7? 1.1 0.04 " 20 3.82 1.8 0.05 730 4.22 CYCLO HEXANONE PPM TR BDL RDT. BDL _ t> nr H g i | .. , fji * 0i,n0 1 ,. ; j) in. 1 0 0O BDL BDL _ o.m ! 1 BDL 0.11 BDL COMMENTS I CCOO CUSAROSS 00714 V.y'i 1|| r v m . Sc'. tm APPENDIX 2 3M BRAND MERCURY VAPOR RESPIRATOR ,* 39 (0005) 0058. 0042 CUSAROSS 00715 3IH Brand BteituryUnpar,Respirator Substantial protection. The 3M Brand Mer cury Vapor Respirator protects workers up to eight hours against five times the threshold limit value. A worker can depend on effective protec tion for the length of a normal work shift. Low cost for this vital protection. You can fur nish the 3M Brand Mercury Vapor Respirator for about 95 cents.* A low price to pay for protection against potentially damaging mercury vapor. At such reasonable cost, the respirator becomes a disposable item. So you can issue a fresh respi rator for proper protection every day. Protects against particulate matter. Because the 3M Brand Mercury Vapor Respirator is com posed of two layers of filtration material, it per forms two important protection functions. It protects against mercury vapor, of course. But it also filters 98 percent of particulate matter with a mean particle diameter of 0.4 to 0.6 microns. Comfortable--workers will wear it. Naturally, any respirator must be worn to be effective. The 3M Brand Mercury Vapor Respirator encourages regular use because it is unusually comfortable. It's lightweight at just 0.3 ounces. The straps keep it snug without excessive pressure on the face or head. Doesn't interfere with normal functions. A worker can breathe easily with the 3M Brand Mercury Vapor Respirator on. And he feels practically no interference with speech or vision. So he can conduct his normal work activities, almost for getting that the respirator is there protect- , ing him while he works. Weight: 8.4 grams, (very lightweight.) Vision: Respirators were fitted to test subjects, heads were held straight, and subjects were asked to point out all areas of a numbered grid on the floor which were not obscured from view. Results are shown below. Units Indicate distance in feet which was obscured from view. Respirator Anglo front center lino 0 (straight ahead) 30 None 2.0 2.0 3M#8707 3.0 2.5 GO0 2.5 3.0 90 3.5 3.5 For more information about the 3M Brand Mer cury Vapor Respirator and other 3M Brand Occu pational Health and Safety Products, write: 3M Company, 3M Center, Bldg. 527-110, St. Paul, Minnesota 55101. In Canada contact Box 5757, London, Ont., phone (519) 451*2500. VvA vV tV- `j'VvV' \ j "r. )tj//Z mm-"' / y Manufacturer's suggested list price. 1 R-MVR (94 21. (0005.)r":'>r4W- 0058. 0043 4Q odClliitsLiCnlai hdcuul > llcutiilj t*HO bilCIS Utho In U SJL with 3M GRAND Photo 0h4i fm Film sod CUSAROSS 00716 3m Brand mercufv^Unpor Respirator m ra Lfl IfflenoDry inpir priMai at a prlta pu live asitSi. .41 (0005) 0058. 0044 CUSAROSS 00717 APPENDIX 3 GUIDELINE FOR CHROMIUM (VI) EXPOSURE - Vs<- 42 (0005) 0058. 0045" CUSAROSS 00718 v Recommended Standard------------ ^ -for Occupational Exposure To -- Chromium (VI) A complete criteria document for occupational exposure to chromium (VI), also called hexavalent chromium or Cr(VI), has been prepared by the National Institute for Occupational Safety and Health (NIOSH). Certain forms of chromium(VI) have been found to cause increased respiratory cancer mor tality among workers. NIOSH has found that certain other forms of chromium (VI) are noncarcinogenic; they are the monochromates and bichromates (dichromates) of hydrogen, lithium, sodium, potassium, rubidium, cesium, and ammonium and chromium(VI) oxide (chromic acid anhydride). The recommended standard is part of a continuing series of criteria documents developed by NIOSH in accordance with the Occupational Safety and Health Act of 1970. The document was transmitted to the Occupational Safety and Health Administration in the Department of Labor on Dec. 1, 1975, for review and consideration in the standard setting process. NIOSH recommends that chromium(VI) in the workplace be considered to be carcinogenic unless an employer can demonstrate that only the non carcinogenic chromium(VI) compounds mentioned above are present. If this can be demonstrated, NIOSH has less restrictive recommendations appro priate for noncarcinogenic materials. In those instances where the recommendations for carcinogenic chromium(VI) apply, NIOSH recommends that exposure to chromium(VI) be not greater than 1 Mg Cr(VI)/cu m. If only the noncarcinogenic chromium(VI) ma terials described above are present in the workplace, NIOSH recommends workplace environmental limits of 50/ig chromium(VI)/cu m as a 15-minute ceiling and a TWA of 25 Mg chromium(VI)/cu m for up to a 10-hour workday, 40-hour workweek. The present Federal workplace environmental limit for chromium(VI) materials is a ceiling of 52 chromium(VI)/cu m or 100 m6 chromium(VI) oxide/cu m. In 1973, NIOSH provided recommendations for occupational exposure to chromic acid. These 1975 recommendations for chromium(VI) supersede the recommendations for chromic acid in several instances. Exposure to any form of chromium(VI) may result in disorders of the skin, and liver and kidney damage. Compliance with all sections of the NIOSH recommended standard should prevent noncarcinogenic adverse effects of exposure to chromium(VI) in the workplace air and by skin exposure. NIOSH estimates that 175,000 workers are potentially exposed to chromium(VI) which is produced principally from chromite ore. It is used in such diverse operations as pigment production, plating and anodizing, match manu facturing, battery manufacturing, and as an antioxidant. The proposed stan dard would apply to the processing, manufacturing, and use of chromium(VI) products and byproducts covered by the Occupational Safety and Health Act The following is the first chapter of the criteria document. It contains the NIOSH recommendations for controlling worker exposure to chromium(Vl), U.S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE Public Health Service Center for Disease Control National Institute for Occupational Safety and Health Single copies ot complete criteria document are available from: Office of Technical Publications National Institute (or Occupational Safety 4nd Health Post Office Building Cincinnati, Ohio 45202 Please Include a self-addressed mail ing label to assist In answering your request* 43 0058. - 0046 _- CUSAROSS 00719 Recommended Standard I. RECOMMENDATIONS FOR A CHROMIUM(Vi) STANDARD The National Institute for Occupational Safety and the workplace so that the airborne workplace concen Health (NIOSH) recommends that worker exposure to tration of chromiumfVI), sampled and analyzed accord chromiumfVI), ie, hexavalent chromium or CrfVI), in the ing to the procedures in Appendices I and II, is not workplace be controlled by adherence to the following greater than 1 ^g Cr(VI)/cu m of breathing zone air. sections. The standard is designed to protect the health and safety of workers for up to a 10-hour work (b) Concentration of Noncarcinogenic ChromiumfVI) day, 40-hour workweek over a working lifetime. Com Noncarcinogenic chromium(VI) shall be controlled pliance with all sections of the standard should prevent in the workplace so that the airborne workplace con all noncarcinogenic adverse effects of exposure to centration is not greater than 25 /j Cr(VI)/cu m of chromium(VI) in the workplace air and through skin breathing zone air determined as a time-weighted exposure and should reduce materially the risk of lung average (TWA) exposure for up to a 10-hour workday, cancer from occupational exposure to carcinogenic 40-hour workweek, and is not greater than 50 ^g CrfVI)/ chromium(VI). The standard is measurable by tech cu m of breathing zone air as determined by any 15- niques that are valid, reproducible, and available. Suffi minute sample. cient technology exists to permit compliance with the recommended standard. The standard will be subject to review and revision as necessary. Procedures for sampling and analysis of chromium (VI) in air shall be as provided in Appendices I and II, or by any method shown to be equivalent in precision, For the purpose of this standard, "chromium(VI)" accuracy, and sensitivity to the methods specified. is defined as the chromium in all materials in the + 6 (hexavalent) state. Section 2 -- Medical There are 2 recommended standards for chromium (VI). One addresses occupational exposure to a group Medical surveillance shall be made available as outlined below for all workers with occupational expo c of noncarcinogenic, but otherwise hazardous materials, while the other pertains to occupations and workplaces where there is exposure to other chromium(VI) ma terials associated with an increased incidence of lung cancer. sure to carcinogenic or noncarcinogenic chromiumfVI), including maintenance personnel periodically exposed during routine maintenance or emergency repair oper ations. On the basis of the chemical analysis of airborne chromium(VI) materials, there is no practical means (a) Preplacement and annual medical examinations shall include: of distinguishing between these 2 groups of chromium (1) A comprehensive or interim work history. (VI) materials. Until the airborne chromium(VI) in a particular workplace is demonstrated by the employer to be of the type considered to be noncarcinogenic, all airborne chromium(VI) shall be considered to com prise carcinogenic materials. (2) A detailed medical history including infor mation on conditions indicating the inadvisability of further exposure to chromium(VI), eg. potential skin or pulmonary sensitization, a skin or mucous membrane condition that may be exacerbated by chromium(VI), Based on current evidence, "noncarcinogenic chro- smoking habits, and history of liver or kidney disease. mium(VI)" is the chromium(VI) in monochromates and bichromates (dichromates) of hydrogen, lithium, sodium, potassium, rubidium, cesium, and ammonium, and chromium(VI) oxide (chromic acid anhydride). "Carcino genic chromium(VI)" comprises any and all chromium (VI) materials not included in the noncarcinogenic (3) Examination of the skin for evidence of der matitis or chrome ulcers, and of the membranes of the upper respiratory tract for irritation, bleeding, ulcera tions, or perforations, (4) An evaluation of the worker's ability to use group above, "Occupational exposure to carcinogenic negative or positive pressure respirators. chromium(VD" is defined as exposure to airborne (5) Urinalysis. chromium(VI) at concentrations greater than one-half of the workplace environmental limit for carcinogenic (b) For workers with occupational exposure to car '.,1 ChromiumfVI), "Occupational exposure to noncarcino genic chromium(VD" is defined as exposure to airborne cinogenic chromiumfVI), preplacement and annual med ical examinations shall include 14" X 17" chest X-rays. chromiumfVI) at concentrations greater than one-half Other tests, including sputum cytology and liver func of the workplace environmental limit for noncarcino tion studies, shall be considered by the responsible genic ChromiumfVI). Exposure to chromiumfVI) at con physician. centrations less than one-half of the workplace environ (c) For workers with occupational exposure to non mental limit will not require adherence to the following carcinogenic chromium(VI) and not to carcinogenic sections, except for 3(a,b,c,d), 4a, 5, 6(b,c,e,f), and 7. chromium(VI), preplacement medical examinations Ah shall include 14" x 17" chest X-rays. Thereafter, X-ray Section 1 -- Environmental (Workplace Air) (a) Concentration of Carcinogenic Chromium(VI) examinations shall be offered at 5-year intervals and annually after age 40. Other tests, such as liver function studies, may be considered by the responsible physi Carcinogenic chromium(VI) shall be controlled in cian. (0005) .*1*30058. " OO-fY?5^ CUSAROSS 00720 Recommended Standard (d) Medical examinations shall be made available to all workers with signs or symptoms of skin or upper respiratory tract irritation likely to have been the result of exposure to chromium(VI). (e) If clinical evidence of adverse effects due to chromium(VI) is developed from these medical exami nations, the worker shall be kept under a physician's care until the worker has completely recovered or maximal improvement has occurred. (f) Initial annual examinations for presently em ployed workers shall be offered within 6 months of the promulgation of a standard incorporating these recom mendations. (g) The medical representatives of the Secretary of Health, Education, and Welfare, of the Secretary of Labor, and of the employer shall have access to all medical records. Physicians designated and authorized by any employee or former employee shall have access to that worker's medical records. (h) Medical records shall be maintained for all employees with occupational exposure to carcinogenic or noncarcinogenic chromium(VI) and for maintenance personnel with periodic exposure. Preplacement X-rays an8 X-rays for the 5 years preceding termination of employment and all medical records with pertinent supporting documents shall be retained at least 30 years after the individual's employment is terminated. Section 3 -- Labeling (Posting) (a) Except for shipping and storage containers for lithium chromate, lithium bichromate, sodium chro mate, sodium bichromate, potassium chromate, potas sium bichromate, rubidium chromate, rubidium bichro mate, cesium chromate, cesium bichromate, ammonium chromate, ammonium bichromate, and chromium(VI) oxide (chromic acid anhydride), as dry solids or con centrated solutions, all shipping and storage containers for chromium(VI) shall bear the following label in addition to, or in combination with, labels required by other statutes, regulations, or ordinances: (Chemical name) (Synonyms) DANGER! EXTREME HEALTH HAZARD MAY CAUSE IRRITATION, RASH, OR EXTERNAL ULCERS INHALATION MAY CAUSE CANCER Keep container closed. Avoid contact with skin and eyes. Avoid breathing dust or solution spray. In case of contact, immediately flush eyes with plenty of water for at least 15 minutes. Call a physi cian. Flush skin with water. Wash clothing before reuse. (b) All shipping and storage containers for lithium chromate, lithium bichromate, sodium chromate, so dium bichromate, potassium chromate, potassium bi chromate. rubidium chromate, rubidium bichromate, cesium chromate, cesium bichromate, and ammonium chromate, the hydrates of these compounds, high purity aqueous solutions of these compounds, and dry mixtures containing only these materials shall bear the same label except that "Inhalation may cause cancer" shall be deleted and "Extreme Health Hazard" shall be replaced by "Moderate Health Hazard." (c) Because of the flammable characteristics of ammonium bichromate (dichromate), shipping and storage containers for dry forms of this compound shall bear the following label in addition to, or in combination with, labels required by other statutes, reg ulations, or ordinances: AMMONIUM BICHROMATE DANGER! HIGHLY FLAMMABLE MODERATE HEALTH HAZARD MAY CAUSE IRRITATION, RASH, OR EXTERNAL ULCERS. Keep away from heat, sparks, and open flame. Keep container closed. Avoid contact with skin and eyes. Avoid breathing dust or solution spray. In case of contact, immediately flush eyes with plenty of water for at least 15 minutes. Call a physician. Flush skin with water. Wash clothing before reuse. (d) All storage containers of chromic acid, or chromium(VI) oxide (chromic acid anhydride) shall bear the following label in addition to, or in combination.with, labels required by other statutes, regulations, or ordi nances. CHROMIUM TRIOXIDE (CHROMIC ACID) DANGER! POWERFUL OXIDIZER CONTACT WITH OTHER MATERIAL MAY CAUSE FIRE MAY CAUSE DELAYED BURNS OR EXTERNAL ULCERS Keep container closed. Do not get in eyes, on skin, on clothing. Do not breathe dust or mist from solutions. In case of contact, immediately flush skin or eyes with plenty of water for at least 15 minutes. For eyes, get medical attention immediately. Wash clothing before reuse. Use fresh clothing daily. Take showers after work, using plenty of soap. (e) In areas where there is occupational exposure to carcinogenic chromium(VI), the following warning sign shall be posted in readily visible locations, par ticularly at the entrances to the area. WARNING CANCER-SUSPECT AGENT USED IN THIS AREA UNAUTHORIZED PERSONS KEEP OUT (0005) 0058. .0048 45 CUSAROSS 00721 Recommended Standard .. V 1 The sign shall be printed both in English and in the predominant language of non-English-speaking workers, if any, unless they are otherwise trained and informed of the hazardous areas. All illiterate workers shall receive such training. (f) In areas where airborne chromium(VI) comprises only lithium chromate, lithium bichromate, sodium chromate, sodium bichromate, potassium chromate, potassium bichromate, rubidium chromate, rubidium bichromate, cesium chromate, cesium bichromate, ammonium chromate, or chromium(VI) oxide (chromic acid anhydride), their hydrates, or mixtures containing only these chromium(VI) materials, the warning sign shall read as follows; WARNING CHROMATES, BICHROMATES OR CHROMIC ACID ANHYDRIDE USED IN THIS AREA UNAUTHORIZED PERSONS KEEP OUT The sign shall be posted in readily visible locations, particularly at the entrances to the area. The sign shall be printed both in English and in the predominant language of non-English-speaking workers, if any, unless they are otherwise trained and informed of the hazard ous areas. All illiterate workers shall receive such training. (g) In areas where airborne chromium(VI) contains ammonium bichromate, or where ammonium bichro mate is stored, manufactured, or used, the following shall be added to the warning sign in (e) or (f) above; FLAMMABLE SUBSTANCE .Section 4 -- Personal Protective Equipment and Protective Clothing (a) Protective Clothing (1) Coveralls or other full-body protective clothing shall be worn in areas where there is occupational exposure to chromium(VI). Protective clothing shall be changed at least daily at the end of the shift and more frequently if it should become grossly con taminated. (2) Impervious gloves, aprons, and footwear shall be worn at operations where solutions of chromium(VI) may contact the skin. Protective gloves shall be worn at operations where dry compounds of chromium(VI) are handled and may contact the skin. (3) Eye protection -shall be provided by the employer and used by the employees where eye con tact with chromium(VI) is likely. Selection, use, and maintenance of eye protective equipment shall be in accordance with the provisions of the American Na tional Standard Practice for Occupational and Educa tional Eye and Face Protection, ANSI Z87.1-1968. Unless eye protection is afforded by a respirator hood or face piece, protective goggles or a face shield shall be worn at operations where there is danger of contact of the eye with dry or wet compounds of chromium(VI) be cause of spills, splashes, or excessive dust, or mists in the air. (4) The employer shall ensure that all personal protective devices are inspected regularly and main tained in clean and satisfactory working condition. (5) Work clothing shall not be taken home by employees. The employer shall provide for maintenance and'laundering of protective clothing. (6) The employer shall ensure that precautions necessary to protect laundry personnel are taken when soiled protective clothing is laundered. (b) Respiratory Protection from Carcinogenic Chromium(VI) Engineering controls shall be used wherever feasible to maintain airborne carcinogenic and noncarcinogenic chromium(VI) concentrations below those recommended in Section 1 above. Compliance with the permissible exposure limits by the use of respirators is only allowed when airborne chromium(Vl) concentrations are in ex cess of the workplace environmental limit because required engineering controls are being installed or tested, when nonroutine maintenance or repair is being accomplished, or during emergencies. When a respirator is thus permitted, it shall be selected and used in accordance with the following requirements: (1) For the purpose of determining the type of respirator to be used, the employer shall measure the airborne concentration of chromium(VI) in the work place initially and thereafter whenever process, work site, climate, or control changes occur which are likely to increase the airborne concentration of chromium(VI); this requirement does not apply when carcinogenic chromium(VI) is present. (2) The employer shall ensure that no worker is occupationally exposed to chromium(VI) because of improper respirator selection, fit, use, or maintenance. (3) A respiratory protection program meeting the requirements of 29 CFR 1910.134 and 30 CFR 11 which incorporates the American National Standard Practices for Respiratory Protection Z88.2-1969 shall be estab lished and enforced by the employer. (4) The employer shall provide respirators in accordance with Table 1-1, or Table 1-2 when appropri ate, and shall ensure that the employee uses the respirator provided. (5) Respirators described in Tables 1-1 and 1-2 shall be those approved under the provisions of 29 CFR 1910.134 and 30 CFR 11. (6) The employer shall ensure that respirators are adequately cleaned, and that employees are in structed on the use of respirators assigned to them and on how to test for leakage. (7) Respirators specified for use in higher con centrations of airborne chromium(VI) may be used in workplaces with lower concentrations of airborne chromium(VI). (8) When an emergency may develop which could result in employee injury from chromium(VI), the em ployer shall provide an escape device as listed in Table 1-1, or in Table 1-2 where appropriate. 46 -(0005) 0058. ' ^*=0049 CUSAROSS 00722 Recommended Standard A TABLE 1-1 RESPIRATOR SELECTION GUIDE FOR PROTECTION AGAINST CARCINOGENIC CHROMIUM(VI) Self-contained breathing apparatus with positive pressure in full facepiece Combination supplied air respirator, pressure-de mand type, with auxiliary self-contained air supply. Section 5-- Informing Employees of Hazards from Chromium(VI) At the beginning of employment or assignment for work in a chromium(VI) area, employees with occupa tional exposure to chromium(VI) shall be informed of the hazards, relevant signs and symptoms of over exposure, appropriate emergency procedures, and proper conditions and precautions for the safe use of chromiumtVI). Instruction shall include, as a minimum, all infor mation in Appendix III which is applicable to the specific chromiumCVI) product or material to which there is exposure. This information shall be posted in the work area and kept on file, readily accessible to the worker at all places of employment where chromiumlVI) is involved in unit processes and operations. A continuing educational program shall be instituted to ensure that all workers have current knowledge of job hazards, proper maintenance procedures, and clean up methods, and that they know how to use respiratory protective equipment and protective clothing correctly. Information as specified in Appendix III shall be recorded on US Department of Labor Form OSHA-20 "Material Safety Data Sheet" or a similar form ap proved by the Occupational Safety and Health Admin istration, US Department of Labor. TABLE 1-2 RESPIRATOR SELECTION GUIDE FOR PROTECTION AGAINST NONCARCINOGENIC CHROMIUM(VI) Multiples of TWA Limit Less than or equal to 10X Less than or equal to 10QX Less than or equal to 200X Greater than 200X Emergency (no con centration limit) Evacuation or Escape (no concentration limit) Respirator Type Half-mask respirator with replaceable high efficiency filter(s). or Type C supplied-air- respirator, demand type (negative pressure), with half-mask facepiece. Full facepiece respirator with replaceable high effi ciency filter(s). or Type C supplied-air respirator, demand type (negative pressure), with full facepiece, or Self-contained breathing apparatus in demand mode (negative pressure), with full facepiece. Powered air-purifying (positive pressure) respirator with high efficiency filter(s). Self-contained breathing apparatus with positive pres sure in full facepiece, or Combination supplied-air respirator, pressure-demand type, with auxiliary self-contained air supply. Self-contained breathing apparatus with positive pres sure in full facepiece, or Combination supplied-air respirator, pressure-demand type, with auxiliary self-contained air supply. Self-contained breathing apparatus in demand or pres sure-demand mode (negative or positive pressure), or Gas mask, Type N, with high efficiency filter, and mouth piece respirator with high efficiency filter(s). Note: A high efficiency filter is defined as a filter having an efficiency of at least 99.97% against 0.3 ^m DOP (Dioctyl Phthalate) 47 (ooo^T' 0058. 0050 CUSAROSS 00723 Recommended Standard Section 6 -- Work Practices (a) Control of Airborne Contamination: Emission of airborne particulates (dust, mist, spray, etc) of chromium(VI) shall be controlled at the sources of dispersion by means of effective and properly main tained methods such as fully enclosed operations and local exhaust ventilation. Other methods may be used if they are shown to effectively contiol airborne con centrations of chromium(VI) within the limits of the recommended standard. (b) Control of Contact with Skin and Eye; (1) Employees working in areas of possible con tact of skin or eyes with chromium(VI), dry or wet, shall wear full-body protective clothing, including neck and head coverings, and gloves, in accord with Sec tion 4(a). (2) Clean protective clothing shall be put on before each work shift. (3) If, during the shift, the clothing becomes wetted with a solution, slurry, or paste of a chromium (VI) material, or grossly contaminated with a dry form of such material, it shall be removed promptly and placed in a special container for garments for decon tamination or disposal. The employee shall wash the contaminated skin area thoroughly with soap and a copious amount of water. A complete shower is pre ferred after anything but limited, minor contact. Then, clean, protective clothing shall be put on before resuming work. When working directly with chromium (VI) oxide, with unsealed containers of chromium(VI) oxide, Or with chromium(VI) oxide in other than fully enclosed operations, protective devices and clothing shall be removed and the arms, hands, and face thoroughTy washed after working with chromium(VI) oxide, and at 30-minute intervals when working with chromiumfVI) oxide for extended periods of time. (4) Minor areas of skin (principally the hands) contaminated by contact with chromium(VI) shall be washed immediately and thoroughly with an abundance of water. Water shall be easily accessible in the work areas as low-pressure, free-running hose lines or showers. (5) If chromium(VI) comes into contact with the eyes, the eyes should be flushed with a large volume of low-pressure flowing water for at least 15 minutes. Medical attention shall be obtained without delay but not at the expense of thoroughly flushing the eyes. (c) Procedure for emergencies, including firefight ing, shall be established to meet foreseeable events. Necessary emergency equipment, including appropriate respiratory protective devices, Shall be kept in readily accessible locations. 'Only self-contained breathing apparatus with positive pressure in the facepiece shall be used in firefighting. Appropriate respirators shall be available for use during evacuation. (d) Special supervision and care shall be exercised to ensure that the exposures of repair and maintenance personnel to chromium(VI) shall be within the limits prescribed by this standard. (e) Prompt cleaning of spills of chromium(VI): (1) No dry sweeping shall be performed. Wet methods or dry vacuuming shali be used as appropriate. (2) Wet spills and flushing of wet or dry spills shall be channeled for appropriate treatment or collec tion for disposal. They shall not be channeled directly into the sanitary sewer system. (f) General requirements: (1) Good practices of housekeeping shall be ob served to prevent or minimize contamination of areas and equipment and to prevent build-up of such con tamination. (2) Good personal hygiene practices shall be en couraged. (3) Equipment shall be kept in good repair and free of leaks. (4) Containers of dry chromium(VI) shall be kept covered insofar as is practical. -- Section 7 -- Sanitation (a) Washing Facilities Emergency showers and eye-flushing fountains with adequate pressure of cool water shall be provided and be quickly accessible in areas where there is potential of skin or eye contact with chromium(VI), This equip ment shall be frequently inspected and maintained in good working condition. Showers and washbasins shall be provided in the employees' locker areas. Employees exposed to chromium(VI) shall wash before eating or smoking during the work shift. (b) Food Facilities Food storage, preparation, and eating shall be pro hibited in areas where chromium(VI) is handled, proc essed, or stored. Eating facilities provided for employees shall be located in nonexposure areas. Washing facilities should be accessible nearby. (c) Employees shall not smoke in areas where chromium(VI) is handled, processed, or stored. (d) Clothing and Locker Room Facilities Locker room facilities shall be provided in a nonexposure area for employees required to change cloth ing before and after work. The facilities shall provide for the separate storage of street clothing and clean work clothing from soiled work clothing. Showers and wash basins should be located in the locker area to encourage good personal hygiene. Covered containers should be provided for work clothing discarded at the end of the shift or after a contamination incident. The clothing will be held in these containers until removed for decontamination or disposal. Section 8 -- Monitoring and Recordkeeping Requirements Workers are not considered to have occupational 48 (0005) 0058. 0051 . CUSAROSS 00724 Recommended Standard exposure to chromium(VI) if, on the basis of a profes sional industrial hygiene survey, (a) the airborne con centration of carcinogenic chromium(VI) is sufficiently low that a sampling volume greater than IjO cu m is necessary in order to collect 0.5 pg of carcinogenic chromium(VI) and (b) the airborne concentration of noncarcinogenic chromium(VI) is not greater than half the recommended limit of 25 flg Cr(VI)/cu m. All sam ples of airborne chromium(VI) shall be analyzed by the chemical analytical method in Appendix II; if samples can be demonstrated to contain only noncarcinogenic chromium(VI), other methods of chemical analysis equivalent to the method in Appendix II may be used. Records of these surveys, including the basis for con cluding that there is no occupational exposure to chromium(VI) shall be maintained until a new survey is conducted. In workplaces where chromium(VI) is handled or processed, surveys shall be repeated annually and when any process change indicates a freed for reeval uation. Requirements set forth below apply to areas in which there is occupational exposure to chromium (VI). Employers shall maintain records of workplace en vironmental exposures to chromium(VI) based upon the following sampling,-analytical, and recording schedules; (a) In all monitoring, samples representative of the exposure in the breathing zone of employees shall be collected by personal samplers. (b) An adequate number of samples shall be taken in order to permit construction of TWA exposures for every operation or process. Except as otherwise de termined by a professional industrial hygienist, the minimum number of representative TWA determinations for an operation or process shall be based on the number of workers exposed as provided in Table 1-3. (c) The first determination of the workers' exposures to airborne chromium(VI) shall be completed within 6 months after the promulgation of a standard incor porating these recommendations. (d) A reevaluation of the exposures of workers to airborne chromium(VI) shall be made within 30 days after installation of a new process or process changes. (e) Samples of airborne chromium(VI) shall be col lected and analyzed at least every 2 months for those work areas with occupational exposure to carcinogenic chromium(VI) and at least every 3 months if the air borne chromium(VI) is noncarcinogenic. (f) A reevaluation of the workers' exposures to air borne chromium(VI) shall be repeated at 1-week inter vals when the airborne concentration has been found to exceed the recommended workplace environmental limit. In such cases, suitable controls shall be insti tuted and monitoring shall continue at 1-week intervals until 3 consecutive surveys indicate the adequacy of controls. 1 (g) Records of all sampling and analysis of airborne chromium(VI) and of medical examinations shall be maintained for at least 30 years after the individual's employment is terminated. Records shall indicate the details of (1) type of personal protective devices, if any, in use at the time of sampling, and (2) methods of sampling and analysis used. Each employee shall be able to obtain information on his own exposure. In the event that the employer who has employees with occupational exposure to carcinogenic chromiumtVI) ceases business without a successor, records shall be forwarded by registered mail to the Director, National Institute for Occupational Safety and Health. TABLE 1-3 SAMPLING SCHEDULE Number of Employees Exposed 1-20 21-100 over 100 Minimum Number of Employees Whose Individual Exposures Shall Be Determined 50% of the total number of exposed employees 10 plus 25% of the excess over 20 exposed employees 30 plus 5% of the excess over 100 exposed employees (h) A regulated area shall be established and main tained where: (1) Carcinogenic chromiumtVI) is manufactured, reacted, repackaged, stored, handled, or used; and (2) Airborne concentrations of carcinogenic chromium(VI) are in excess of the permissible exposure limit in Section 1. (i) Access to the regulated areas designated by Section 8h shall be limited to authorized persons. A daily roster shall be made of authorized persons who enter; these rosters shall be maintained for 30 years. (0005) 0058. 0052 1....... -................ . 49 w ivj conjKMtfawi*(Tioftct 15/t- orj 7-1,4 0/227 ^>2 CUSAROSS 00725 HI o APPENDIX 4 GUIDELINE FOR LEAD EXPOSURE 0053 CUSAROSS 00726 A Recommended Standard for Occupational Exposure to Inorganic Lead A criteria document for protection against ex posure to inorganic lead has been prepared in ac cordance with- sections 6(b)(7) and 20(a)(3) of the Occupational Safety and Health Act and was transmitted to the Occupational Safety and Health Administration, U.S. Department of Labor, for review and consideration in the stan dard setting process. The standard is based upon criteria developed from the results of numerous investigations of the effects of inorganic lead on the worker. The environmental limit proposed is lower chan the present standard established by the Occupational Safety and Health Administration (published in Part 1910.93 of the Federal Register,Volume 35, Number 157, pages 15101-15107, dated August 13,1971) of 0.2 mg/m1 and based upon American National Standards Institute recommendations that provided no basis for their conclusions. In addition to recommending a lower environmen tal level, provisions for biological monitoring and medical examinations were recommended to be made available to certain workers. .Biological monitoring will allow for a more precise evalua tion of exposures to inorganic lead, which come from many sources. The diversity of occupations where lead exposure occurs is referenced in the document, where over 100 different occupations are listed. Primary exposure to inorganic lead oc curs in the manufacture of batteries and electronic devices, foundry operations, lead burn ing, automotive manufacture, galvanizing, manufacture of paint, and in the printing indus try. It is estimated that approximately 783,000 industrial workers are potentially exposed to lead products. The recommendations for an occupational ex posure standard for inorganic lead take into con sideration available information on health effects and limited data on the technical feasibility of achieving various levels of exposure. The criteria document was reviewed by six knowledgeable consultants, a professional society, and government agencies with interest and responsibility in occupational safety and health. Eight responses were received from the solicitation in the Federal Register, It was the feeling of the reviewers that the in organic lead standard as proposed in this docu ment is appropriate and that no additional infor mation that would affect the standard is available at this time. Substantial changes in the criteria document were made in the program for environmental and biological monitoring as a result of the reviewers comments. The following is the first chapter of the cri teria document. It contains the NIOSH recom mendations for controlling worker exposure to Inorganic Lead. U. S. DEPARTMENT OF HEALTH. EDUCATION, AND WELFARE F*ublic Health Service Center for Disease Control National Institute for Occupational Safety and Health 51 (0005)-'.. 0058. ~*V*"00 54 CUSAROSS 00727 I. RECOMMENDATIONS FOR AN INORGANIC LEAD STANDARD The National Institute for Occupational Safety and Health (NIOSH) recommends that employee exposure to inorganic lead in the workplace be controlled by adherence to the following sections. The standard is designed to protect the health and safety of workers for an 8hour day, 40-hour week over a working lifetime; compliance with the standard should therefore prevent adverse effects of lead on the health and safety of workers. The standard is measurable by techniques that are valid, reproducible, and available to industry and government agencies. Sufficient technology exists to permit com pliance with the recommended standard. The cri teria and standard will be subject to review and revision as necessary. "Inorganic lead" means lead oxides, metallic lead, and lead salts (including organic salts such as lead soaps but excluding lead arsenate). "Ex posure to inorganic lead" is defined as exposure above half the recommended workroom environ mental standard. Exposures at lower environ mental concentrations will not require adherence to the following sections, except for Section 7(a). Section 1 --Environmental (workplace air) (a) Concentration Occupational exposure to inorganic lead shall be controlled so that workers shall not be exposed to inorganic lead at a concentration greater than 0.15 mg Pb/m5 determined as a time-weighted average (TWA) exposure for an 8-h'our workday. (b) Sampling, Collection, and Analysis Procedures for collection of environmental samples shall be as provided in Appendix I, or by an equivalent method. Analysis of samples shall be as provided in Appendix II, or by any method shown to be equivalent in precision and accuracy to the method specified in Appendix II. Section 2--Medical Medical monitoring (biologic monitoring and medical examinations) shall be made available to workers as outlined below. (a) Biologic monitoring Biologic monitoring shall be made available to all workers subject' to "exposure to inorganic lead." It consists of sampling and analysis of whole blood, or alternatively, of urine for lead content. Such monitoring shall be performed to ensure that no worker absorbs an unacceptable amount of lead Unacceptable absorption ot lead posing a risk of lead poisoning is demonstrated at levels of 0 080 mg Pb/l(X) g of whoie blood or greater, or at levels of 0.20 mg Pb/liter of urine (with urine specific gravity corrected to 1.024) or greater. Procedures for sampling and analysis of blood or urine for lead shall be as described in Appen dix II, or by any mechod shown to be equivalent in precision and accuracy. In the case of urine, "spot" urine specimens of about 100 ml shall be collected during a workday, and urine specimens with a specific gravity less than 1.010 shall be dis carded and another sample obtained. Half of all workers subject to "exposure to in organic lead" shall be offered biologic monitoring every 6 months, so that each worker shall have blood sampling and analysis made available to him yearly. If urine sampling and analysis are chosen instead of blood lead sampling and analysis to satisfy the biologic monitoring re quirement, every worker shall have urine sam pling and analysis made available to him at 6 month intervals. The schedule of biologic monitoring, above, may be altered if indicated by a professional industrial hygiene survey. If en vironmental sampling and analysis show that en vironmental levels are at or greater than the en vironmental limit, the interval of biologic monitoring shall be halved, i.e. blood analysis shall be conducted quarterly, with each worker sampled semi-annually, or urinalysis shall be con ducted quarterly on every worker. This increased frequency shall be continued for at least 6 months after the high environmental level has been shown. If a worker's urine lead level is found to be 0.20 mg/liter or greater, calculated to a Specific gravity of 1.024, a blood sample shall be obtained and analyzed within two weeks. If a blood lead level of 0.080 mg Pb/100 g or greater is found, and confirmed by a second sample to be taken within two weeks, steps to reduce his absorption of lead shall be taken as soon as the high levels are con firmed. Steps to be considered should include im provement of environmental controls, of per sonal protection or personal hygiene, and use of administrative controls. A medical examination for possible lead poisoning shall be made availa ble, and the OSHA area industrial hygienist shall be informed of the results of the biologic sam pling of those workers with confirmed, high biologic levels of lead. Biologic monitoring shall also be made availa ble where the OSHA area industrial hvgienist has reason to believe operations produce unusual ex posure excursions or that environmental samples do not adequately describe worker exposure. 52 1 (0005) 0058.,- 0055 Im. CUSAROSS 00728 (b) Medical examination Medical examinations shall be available when a variance has been granted permitting administra tive controls or use of respiratory protection, for workers with unacceptable absorption of lead as judged by biologic monitoring, or when environ mental levels are at or above the environmental standard. These examinations should be made available prior to employee placement and annually thereafter. They should include a physical ex amination, complete blood counts, blood lead determinations, routine urinalysis (specific gra vity, sugar and protein determinations, and microscopic examination), and should record any signs or symptoms of plumbism, if present. Where urine is selected instead of blood for biologic monitoring, the preplacement examina tion should also include a urinary lead determina tion. Each employee who absorbs unacceptable amounts of lead as indicated by biologic monitor ing shall be examined as soon as practicable after such absorption is demonstrated and confirmed, and at least every 3 months thereafter until his blood or urine lead levels have returned to nor mal, i.e. below 0.080 mg/100 g of blood or 0.20 mg/liter of urine. If clinical evidence of plumb ism is developed from these medical examina tions, the worker shall be kept under a physician's care, in accordance with applicable Workman's Compensation provisions, until the worker has completely recovered or maximal improvement has occurred. Medical records shall include information on all biologic determinations and on all required medical examinations. These records shall be available to the medical representatives of the employer, of the Secretary of Labor, of the Secre tary of Health, Education, and Welfare, and, at the employee's request, to the employee's physi cian. These records shall be kept for at least five years after the last occupational exposure to in organic lead. Section 3 -- Labeling (Posting) Areas where exposure to lead at levels over one-half the workroom air standard is likely to occur shall be posted with a sign reading: LEAD (Pb) DANGER! High concentrations of fume or dust may be hazardous to health. Provide adequate ventilation. If environmental levels are at or greater than the environmental limit, or if a variance permit ting use of respiratory controls has been granted, add information to the label or placard describing the location of the respirators. ; Section 4 -- Personal Protective Equipment and Work Clothing Subsection (a) shall apply whenever a variance from the standard recommended in Section 1 is granted under provisions of the Occupational Safety and Health Act, or in the interim period during the application for a variance. When the limits of exposure to lead prescribed in paragraph (a) of Section 1 cannot be met by limiting the concentration of lead in the work environment, an employer must utilize, as provided in subsec tion (a) of this Section, a program of respiratory protection to effect the required protection of ev ery worker exposed. (a) Respiratory Protection Engineering controls shall be used wherever feasible to maintain lead dust and fume con centrations below the prescribed limits. Appropriate respirators shall be provided and used when a variance has been granted to allow respirators as a means of control of exposure to routine operations and while the application is pending. Administrative controls should also be used to reduce exposure. Respirators shall also be provided and used for nonroutine operations (oc casional brief exposures above the TWA of 0.15 mg/m3 and for emergencies); however, for these instances a variance is not required but the re quirements set forth below continue to apply. Appropriate respirators as described in Table 1-1 shall only be used pursuant to the following re quirements: (1) For the purpose of determining the class of respirator to be used, the employer shall measure the atmospheric concentration of in organic lead in the workplace when the initial ap plication for variance is made and thereafter whenever process, worksite, climate or control changes occur which are likely to affect the lead concentration. The employer shall test for respirator fit and/or make iead measurements within the respiratory inlet covering to ensure that no worker is being exposed to inorganic lead in excess of the standard either because of im proper respirator selection or fit. (2) Employees experiencing breathing difficulty while using respirators shall be referred to a physician for evaluation. This evaluation should investigate if the employee has adequate ventilatory capacity and any evidence of obstruc tive lung disease. Employees with inadequate ventilatory capacity or evidence of obstructive lung disease shall not wear types A, B, and F, respirators. 53 \ (0005) .^ 0058*jfl1^00-S6T CIJSAROSS 007 0) A respiratory protective program meet ing the general requirements outlined in section 3.5 of American National Standard for Respiratory Protection Z88.2-1969 shall be estab lished and enforced by the employer. (4) The employer shall provide respiracors in accordance with the Table below and shall assure that the employee uses the respirator pro vided. (5) If both fume and dust are present, the recommended usage is that for fume. (6) Respiratory protective devices de scribed in the following Table 1-1 shall be either those approved under the following listed regula tion or those approved under 30 CFR 11, published March 25, 1972. The termination date of currently approved respirators described in 30 CFR 11 shall apply. (i) Reusable or replaceable filter-type air-purifying respirator -- 30 CFR 14 (Bureau of Mines Schedule 21B) (ii) Powered air-purifying positive- pressure respirator -- 30 CFR 14 (Bureau of Mines Schedule 21 B) (iii) Type C positive-pressure supplied air respirator -- 30 CFR 12 (Bureau of Mines Schedule 19 B) (7) Usage of a respirator specified for use in higher concentrations of lead is permitted in at mospheres of lower concentrations. (8) Employees shall be given instruction on the use of respirators assigned to them, cleaning of the respirators, and how to test for leakage. (b) Work Clothing (1) Each employee subject to exposure above the environmental standard of Section 1 should wear coveralls or similar full body work clothing and har, which should be worn during the working hours in areas where there is ex posure to lead. Workers subject to "exposure to inorganic lead" at or below the recommended standard should change into work clothing before starting work, and should remove work clothing before leaving work. This work clothing need not afford full body coverage. (2) Work clothing should be vacuumed before removal. Clothes shall not be cleaned by blowing or shaking. (3) Work clothing should be changed at least twice a week and more ftequenc changes, especially in high exposure areas, are suggested. (4) Adequate shower facilities should be available and used. (5) When in the judgment of the OSHA area industrial hygienist contamination of clothing or exposed body surfaces can produce significant secondary exposures, items (1), (2), (3), and (4) above shall be mandatory. Section 5 -- Apprisal of Employees of Hazards from Lead (a) Each employee exposed to lead shall be ap prised at the beginning of his employment or assignment to a lead area of all hazards, relevant symptoms, appropriate emergency procedures, TABLE 1-1 Requirements for Respirator Usage at Concentrations Above the Standard Exposure 8 Hr TWA mg/m1 `Respirator type Inorganic lead dust less than less than greater than 1.5 15.0 15.0 A,B C D Inorganic lead fume less than less than greater than 1.5 15.0 15.0 E F D A - Reusable or replaceable filter-type air-purifying dust respirator B - Single-use dust respirator C - Powered air-purifving positive-pressure dust respirator D- Type C positive-pressure supplied air respirator E - Replaceable filter-type air-purifying fume respirator F - Powered air-purifying positive-pressure fume respirator 54 (0005)- 0058. 0057 TV CUSAROSS 00730 and proper conditions and precautions for safe use or exposure and shall be instructed as to availability of such information which shall be kept on file including that prescribed in (b) below and shall be accessible to the worker at each place of employment where lead is involved in unit processes and operations. (b) Information as specified in Appendix III shall be recorded on U. S. Department of Labor Form OSHA-20, ``Material Safety Data Sheet", (see page IX-4 and IX-5), or on a similar form ap proved by the Occupational Safety and Health Administration, U. S. Department of Labor. Section 6 -- Work Practices (a) Emergency Procedures (1) Procedures including fire fighting pro cedures shall be established and implemented to meet foreseeable emergency events. (2) Respirators shall be available for wear ing during evacuation procedures if long dis tances need to be traversed; supplied air respira tors shall be available for employee use where equipment or operations cannot be abandoned. (b) Exhaust Systems Where a local exhaust ventilation and collec tion system is used, it shall be designed and main tained to prevent the accumulation of lead dust and fume. (1) Hazardous types of exposure should not be scattered throughout a plant but, rather, con centrated in a single area where special control procedures can be utilized. (2) Air from the exhaust ventilation systems shall not be recirculated into the workroom, and should not be discharged outside the plant so as to create an air pollution problem. (c) General Housekeeping (1) Vacuuming shall be us.ed wherever practicable and no dry sweeping or blowing shall be performed. (2) Emphasis shall be placed upon cleanup of spills, periodic repair of equipment and leaks, proper storage of materials, and collection of lead-containing dust. Section 7 -- Sanitation Practices (a) Food Facilities Food preparation, dispensing (including vend ing machines), and eating shall be prohibited in lead work areas. (b) Locker Facilities Work and street clothing should not be stored in the same locker. Section 8 -- Monitoring, Recordkeeping, and Reporting Requirements Workroom areas where it has been determined, on the basis of an industrial hygiene survey or the ludgment of a compliance officer, that environ mental levels do not exceed half the environmen tal standard shall not be considered to have in organic lead exposure. Records of these surveys, including the basis for concluding that air levels are below half the environmental standard, shall be kept. Requirements set forth below apply to in organic lead exposures. (a) Employers shall monitor environmental levels of lead at least every 6 months, except as otherwise indicated by a professional industrial hygiene survey. If environmental levels are at or above the standard, environmental levels shall be monitored every 3 months. This increased fre quency of monitoring shall be continued at least 6 months (i.e. two more quarterly monitoring periods) after the last sampling that demon strated levels at or above the environmental limit. Periodic environmental sampling shall be per formed to coincide with periodic biologic sam pling, i.e. shall be performed within 2 weeks of biologic sampling. Breathing zone samples shall be collected to permit construction of a time-weighted average exposure for every operation. The following number of samples shall be collected and analyzed, as a minimum, based on the number of workers exposed in any given work area; Number of Employees Exposed 1-20 20-100 over 100 Number of Samples 50% of the number of workers 10 samples plus 25% of the excess over 20 workers 25 samples plus 5% of the excess over 100 workers 55 (0005) 0058. 0058 CUSAROSS 00731 * (b) When any time-weighted average exposure is at or above the environmental standard, the OSHA area industrial hygienist shall be notified. (c) Records shall be maintained for all sam pling schedules to include the sampling methods, analytical methods, type of respiratory protection in use (if applicable), and the concentrations of lead in each work area. Records shall be main tained so that they can be classified by employee. Each employee shall be able to obtain informa tion on his own environmental exposure. (d) Medical records shall include information on all biologic determinations and of all required medical examinations. These records shall be kept for at least five years following the last oc cupational exposure to inorganic lead. n i (0005) 0058. 0059 56 CUSAROSS 0073J INTERNAL correspondence GA 1078 FROM R. T. Cheng TO J. 0. Jackson, Ph.D. SUBJECT Laboratory Reagents for China Gulf Plastics Corp., Ed Lu IN REPLY REFER TO RTC: 78-15 oate February 14, 1978 Attached is a list of laboratory reagents that Mr. Ed Lu of China Gulf Plastics Corporation needed for his laboratory (GC Analysis). Please arrange to have these chemical reagents shipped to CGPC's Taipei Head quarters. For easy clearing of the Chinese customs, the invoice for the items should be written as less than $150 per shipment. We may want to ship the materials in two shipments at different times. The actual costs of these chemical reagents can be billed to CGPC in a separate invoice. RTC/aln attachment cc: H. 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