Document 50E2G4KgqGMDv34N0L2KJaay0

jotxrx x. nuut 4iioNti.neiHA CSAJtU* M.KXXBAM WTLLtAK X- XOXOXItAXZ, JR. ROBERT X. TXXRRAJt wxnt* t.xiacx SAVTS XmXXLL KAirrnt w. xsxcovxcx :tr>- j-t *omr a ilico pint e, sjjuui VXCXAXl, r.lCOKBCWS * ujunr . wotJOMom joxxx.snmex . exsismx A.KSASKXK ntni.uesot* sxisur i. rojncoto xjMrxsxex x. xalpaxv sxaosAX vkdxtjumxxji c. dovoul* JAsarrr MSWJJtV i-xomncx ROBERT L.nssxxxs** x^.w orrtcx* Kiixek and Sbczhan VBO IT* STIUEZT, v. srrxiooo WAsmzxoTon, d. c.aooa -January 9, 1981 s- * '.^riiop'* vv*-<^r*roo CABLT AImImS^'ESU^XK' wunsft'r wf>Kcr j>iu wmcsRR <20*; 457-1116 rHCEV2D JAW 1C 1981 j T. AHR To: The SPI-FVC Safety Group To- <r,. Res Oregon Occupational Safety and Health^ Standard for Vinyl chloride ? ladies and Gentlemen: i In April/ 1980/ the state of Oregon approve an occu pational safety and health standard for vinyl chso that the $tete standard would be "as effective* at; r Occupational Safety and Health Administration ("or *< ; dard. Subsequently * OSHA recognised the Oregon Sfeni.* stan dard as part of the approved State Plan. In the r- *-**! Register notice publicising its approval of thu sten- dard/ OSHA incorrectly stated that the Oregon eta;. - ,_c appix*;.' to the "use of fabricated products made of polyvin>; unioride, while the Federal standard does not provide this coverage.* 45 Fed. Reg. 81132 (Dec. 9, I960). Apparently relying on. the Federal Register notice/ the Occupational Safely and HealtjpReporter published by the Bureau of National Affairs (BNA1) also incorrectly reported that the Oregon ff-andard applied to fabricated products. Zn fact/ as explained below, the Oregon standard does not apply to fabricated products. t rjs. AP00051140 January 9, 1981 Page Two Kezxsb . The Oregon standard applies where vinyl chlo may be relased into the Mr during the manufacture o of vinyl chloride or polyvinyl chloride. Polyvinyl c 4 is defined aa polyvinyl chloride homopolymer or copoJ, "before conversion to a fabricated product." Thus, b*caucc the definition of polyvinyl chloride excludes fabrlce^d products, the Oregon standard does not apply to fabricated products made from polyvinyl chloride. Z confirmed this reading with the Oregon occupational safety and health administrators. OSHA's Federal Reo'stor notice was prepared by Region X in Seattle, Washington After I explained the definitional sections, the autlv admitted that the Federri Register notice was incorr Because the requirements of Mis standard have been ported, X am enclosing a copy of the standard for you:, u&,e should you receive inquiries from downstream processo: s. The applicable portions can be found under sections i ';l- 004(4) and 131-005(7). The Oregon standard does differ from the fed,;a.7 * standard in one particular. Both standards require died surveillance of employees exposed to vinyl chloride i of the action level, which is 0.5ppm averaged over an re work day. Under the federal standard, when the requ.; > 0 tests show abnormalities, the tests are required to K i.e peated as soon as practicable and if the tests remair. mal consideration should be given to withdrawal of trio from contact with vinyl chloride pending a more comp:-*..bcnsi-w *. examination. In contrast, under the Oregon standard ,* th* second set of tests remain abnormal the employee roue i-.* removed from contact with vinyl chloride while a moi hensive examination is made. It does not appear tbtdifference between the federal and Oregon standards significant consequence. If you have any further comments, or if I Ccof any further assistance, please feel free to conte. Cordially yours. cc: Thomas J. McGrath (w/o end.) John R. Lawrence AP00051141