Document 6Vyz0BnMxxMJE7JO6b1Zwez4

INTERNAL CORRESPONDENCE UC 149- 2 P. O. BOX 471, TEXAS CITY, TEXAS 77S90 TO: C. V. Taormina USV Shift Prod. Supervs. USV Staff cc: N. J. Alford M. E. Eisenhour R. A. Mendez Date: August 26, 1985 Subject: Safety Training The following safety topics and assignments have been made: 1. General Safety/Startup Safety M. L. White - Chairman M. G. Sellen R. A. Mendez T. T. Do 2. Unit Hazards Review (including Evacuation Training, Vapor Cloud Releases, Hazardous Chemicals, VCM Training): D. R. Hall - Chairman S. M. Norwood J. R. Rex R. J. Bocek 3. Reaction/Processing Technology: R. M. Arnold - Chairman M. E. Eisenhour J. A. Gordy 4. Eye, Hearing and Hand Protection: R. W. Brandt - Chairman E. D. Sheely J. D. Washington 5. Vessel and Confined Space Entry, Elevated Work Procedure and Master Card/Hazardous Work Permits: K. R. Behnke - Chairman D. B. Rygaard C. V. Taormina UCC 093680 Safety Training 2. Each of the five general safety topics should be presented to all USV Personnel in training sessions of 1-1/2 - 2 hours maximum. It is anticipated that each topic will be presented in two sessions, i.e., Startup Safety on Monday, Unit Hazard Review on Tuesday, etc. Each group should be prepared to present their training by October 1. The training sessions and time have not been established but most likely will occur during the weeks of October 14 and 21. Vinyls Application Training is scheduled for October 10. Each group will also have an SPS assigned in the next few days. Please feel free to use any resources, material, film, etc. Consideration should be given to involving as many people as possible in these sessions - perhaps designating a specific topic to a select group of Operators (such as Hazardous Chemicals). Input from all Operations and Maintenance Personnel is encouraged. Let me know if you have any questions. R. M. Arnold RMA/st 10#: RMA8853 UCC 093681 Jc. J&.&- (ktZi d! M. Cjf'?\Jbr>--' -Q'C. ^zuLO Cl A ~yk<//c<j&r^ c. i db&S A&yJ*,'?*' hjUj 4M ^ 6C & A/ J. /C<*<-Cyt^ZtuZZ 6j/J4 &p*j*dZ**> /f/o. /<//7^} ytyf**<su<s ZdJJLUeZ >. - t*,<?Zs '~l&~Z0t^ZCs t yU ?-ysZ'Z<xys L/J^CcAc/ <3Zc^^ZCZ^t^ zZ^ZZ 3t.'ZX- **.s& 4- AL /J w ^ r;/^ 225 ZzZo --3- ~ s $ *4 (1/JCLu/jls #ti.J{ puc&uZZttss*.x.***jUjW--' ^cCCc^ , 'y^^l,Z/^^JC1^.-1.scyZr^jr&.w-vv-v/y/tZZ*J^Z--ZZZCsC ' yZj Ttt a*Jo*i<XX/ . A'' yi'rc ^ jUyes**tc /2^XyktctiJM.X. %6xx . - <?V- ZXdJLX^^ ~H-4\s /&A. C* Z-d^X-ZC J&tZi&vO PTl*** ZxZ <ZLc> *4 ,, UCC 093682 INFERENCE FILE (U ON (HI) Rot OtaMinun, Mtt- m r r typa. wtta full fa (A) OwMlulMi ypP O supplied Mr tsTOWees*. NN 4mMM >TM wUA full or IM auxiliary Ml-nal (i)Cwliuti<T|)> C. upelieS alt leepiratot twmwM flaw type, lull at kail laeaplera. and i amilitary Type C. suppUad If respirator, continuous flow type. with full or half faos- ptooo, helmet or ehtasM* to erases of tho halt MR necessary protective mm; (Ui) TO* puipow for, pfopci use, and leeiishops of lemwsimy protaclm Mai; ISectira l910.93q(i)(IHiii) imeeded it 39 FR 41041, December 1, I974.ind ledcsuMteO u 1910.1017 at 40 FR 23072. May 28, 19751 (hr) The fire hoard tad acute toxic ity Of vinyl eWorld* end tho protmolvo atooo: () Tho purpoao for and a < of tho monttortag purm: (vl) Tho purpose for. and o of, tho medicpi rarruillanca 0v) Not <v> 25 typa o mi typa, wlto ful aalf aaolalwaO aw aappiy; w Opest-eWcult aalf-eontalaaO ___ fun faeapsaae. La (0) TIP* O aippMW i^imw, (A) A*'poe"55o*13f*punfy!no full or ball fi (fO NMi (V) Oaa miSS^ront- ar baex-aaounMO aaolatar itHfe ' pee*Mas a asrvm Ufa of at leeet a bourn for _ aotratlaaa of vinyl chloride up to *4 ppm. aMoattoa typo C auppllaa-air raapmur. eetype, wlto half faaaplaaa, aod auaUlary aalfMontalnaO aw aupply: or O) Typo C supplied-eW roapwator. half faoaptaaa; or (O) Aoy aWomlaal eartruge rapInto* with oo aapor oorttidpa whMh praaMaa a aervloa Ufa af a* leeet l hour nr oooaonwatlaaa of *layl ISectioa |9l0.93q (41 amended at 39 FR 41348, December 3. 1974 and nAufiulcf at 1910.1017 at 40 IR 23072. May 28, 1975) (vtl) fvttt) Specific information to eld tho employee to recognition of oondltlora which may result In lbs release of vtayl chloride: end (lx) A review of this standsid at the employee* first training and todoctrtnathm program, and annually thereafter. (3) All materials relating to the pro gram shell be provided upon request to the Assistant Secretary and the Director. (k> Medical sroctdeace. A program of medical surveillance shell be insti tuted for each emptoyao exposed, with out regard to the use of respirators, to vinyl chloride to excess of the action level. The program shall provide each such employee with an opportunity for examinations and tests to accordance with this paragraph. Alt medical ex aminations and procedures shall be per formed by or under the supervision of a Hrsnssfl Physician, and shall bo provided without cost to the employe* ((1) Entry Into unkown concentra tions or concentration* creater than 30,000 ppm (lower explosive limit) may ho made only for purpoooo of life rescue; and (U> Entry Into concentration! of lead thou 30,000 ppm. but treater than 3,000 ppm stay be made only for purpoom of Ufa reecu* flrcflghUng. or eecurlnt equipment ao a* to prevent a traitor taaoard from relaaee at vinyl chlorida (> Where elr-purtfytog iwplntm (I) Air-purifying cannlateri or tridges ataall be replaced prior to the expiration of their aenrteo life or tho and of tho shift in which they are lint used. whichever occurs first, and (II) A continuous monitoring and alarm system shall bo provided where occcentretlon* of vinyl chloride could reasonably exceed tho allowable concen trations for the devices in use. Buch sys tem shall ha used to alert employees when vhiyl eblorlda eonesntraUona exceed the allowable concentrations for tho devices to wo* (7) Apparatus prescribed for hither oenoontrationo may bo used for any lower concentration. (h) MaaordOM operations. (1) tonplaysaa enseged to hasardous operations, tocludtog cdtry of vessels to clean poly vinyl chlorida residua from vessel walls, s provided and required to (1) Respiratory protection In aneo with paragraphs (c) and <> of this section; (11) Protective garments to prevail (1) At the time of miuai assignment, skta contact with liquid vinyl chloride or or upon Institution of medical surveU- with polyvinyl chloride residue from eemel walla. The protective garmnits baU be selected for the operation and its possible exposure condition* (3) Protective garments shall be ptw- vtded dean and dry for each ua* (1) Cmeroeecv sitactions. A written operational plan for emergency aituatiom shall be developed for each faculty storing, handling, or otherwise using vinyl chloride aa a liquid or compressed gea. Appropriate portions of tho plan shaU be Implemented to the event of an emergency, lbs plan shall specifically provide that: (l) tonnlnem encaged to heserdoue taoct? (V> A general physical examination shall bo performed, with specific atten tion to detecting enlargement pf liver. spleen or kidney* or dysfunction to these organ* and for abnormalUse in skin, connective tissues and tbs wilunnsiy system (See Appendix A). (U> A medical history shall be i Inetudlng the following toptce: (A) Alcohol Intake; (B> Past history of hepatitis; (C> Work history and to potential hopatotoxlc tog drugs and chemicals: ID) Past history of operations or correcting situations of ex isting hasardous ralease shall be equipped as required to paragraph (h> of this section: (t> Past htoocy of hoapttaUaatlaas. (Ill) A serum spochnon shall bo ob tained end doterminations made of: (A) TotalbUlrupto; (3) Other employees not oo equipped <B) Alkaline phosphatase; hell evacuate the area end not return (C> Serum glutamic oxalaeetic trails- untU oondltlora an controlled by the (BOOT): methods required to paragraph <f> of this section end the emergency Is abated. <J> Training. Each employee engaged to vinyl chloride or polyvinyl chloride operations shall be provided training In e program relating to the haxarde of vinyl chlorida and precautions for Us (D) Seram glutamic pyruvic transam inase (SOFT); and (E) Gamma glustamyl tranepeptldaee. (3) Examinations provided In accord ance with this paragraph shall ha per formed at Mast: safe ua* (I) Every 0 months for saeh employee <i) The program shall toelnds: who has been employed to vinyl chlo (1) The nature of the health hasard ride or polyvinyl chloride manufacturing from chronic exposure to vinyl chloride for 10 years or longor: and tocludtog specifically the carcinogenic (II) Annually for all other employees. <3> Each employes exposed to an (U) TTto specific nature of operations emergency shall be afforded appropriate which oould result to exposure to vinyl medical surveillance Occueetienpl Safety A Health Repettet Itee. Iff UCC 093683 VIMYLS AREA S.O.P. TEXAS CITY PLANT . OCAR SOLUTION VINYLS COMPLEX TOTAL Am MO. 2 (Revised) PAGE: Cover ShMt EF7ECTIVE: May 15, 1981 SUBJECT: Vinyl Chloride Exposure Protaction This S.O.P. i* a Revision of two S.O.P.'s combined: S.O.P. No. 2 three pages issued August-2f3, 1976 and S.O.P. No.~26 issued January 16, 1979, eight pages for Bldgs. 115 and 117. ' Please take those two S.O.P.'s fro* your Manual and insert this new Revised S.O.P. No. 2 for TOTAL AREA, effective May 13, 191. Xt contains the followingi A. POLICY B. MONITORING EQUIPMENT C. LEAR DETECTION D. RESPIRATORY EQUIPMENT X. EMERGENCY UCC 093684 VINYLS AREA 3.O.P. TEXAS CITY PLANT UCAR SOLUTION VINYLS COMPLEX TOTAL AREA_________________ NO. 2 (Revis'd) PACK: 1 Of 14 PTECTIVE: Nay 15, 1981 SUBJECT: Vinyl Chloride Expomrt Protection A. POLICY 1. UCC Policy- is to fully comply with the OSHA Regulation for Ex posure to VC1 (1910.1017) reference letter by D.L. Engle dated 3/1/76 to all employees, Texas City Plant. 2. The OSHA standard for VC1 requires that no employee may be ex posed to VC1 in concentrations greater than 1) 1 ppm averaged over any 8-hr period, 2) 5 ppm averaged over any period exceeding 15 minutes, 6 3) may not be exposed by direct contact with liquid VC1 (1910.1017c). 3. At any time the allowable levels are exceeded in an area, personnel working in the area must wear respiratory protection and rain suits if required. 4. All Visitors to the Regulated Area will register at Bldg. 114 or Bldg. 119 Control Roan. The Regulated Aroa is shown on on attadiod plot. 5. All Operations k Maintenance personnel regularly assigned to the Regulated Area will be registered on Rosters kept by the Chief Operators A Leadmen. The Contract Division will keep Rosters n contract personnel entering the area. The UCAR Vinyls Staff Roster will be maintained by the Vinyls Secretary. These Rosters (Logsheets) must be forwarded to Bldg. 197 on a regular basis for filing. 6. The Regulated Area will be monitored by three continuous vapor fraction analyzers (VFA's) with sample points scattered through out the area. B. MONITORING EQUIPMENT 1. Continuous Vapor Fraction Analyzer (VFA) Two continuous vapor fraction analyzers are currently in service in the Unit and located in Bldg. 115. A third unit will be added during 1981. Each analyzer consecutively analyzes sample points requiring 40 minutes to complete a scan (2 minutes/point). The analyzer is designed to analyze for VC1 only. Results are r UCC 093685 VINYLS AREA S.O.P. TEXAS CITY PLANT UCAR SOLUTION VINYLS COMPLEX TOTAL AREA NO. 2 (Revised) PAGE:3 of 14 EFFECTIVE: Mav 15. 1981 : SUBJECT: Vinyl Chloride Exposure Protection C. LEAK DETECTION 1. Vinyl Chloride Leak (Defined) A leak, other than one that can be detected by sight, sound, or smell, is defined as a single reading of 10 ppm or greater, or two consecutive readings of 5 ppm or greater on the VFA. 2. Leak D1 1 etection Prol cedure (North Area) a. The Bldg. 115 Operator is responsible for monitoring the continuous analyzer (VFA) printouts and determine if ther is a leak as previously defined. b. The North Area Chief Operator must be notified immediately when a leak is indicated. Other personnel in the affected area must also be notified immediately over the public address (PA) system. The Chief Operator will notify the Shift Production Supervisor. c. The Chief Operator, or the Operator if delegated, will determine the source of the leak using the portable organic analyzer (OVA) or the Drager Detector. The Operator search ing for the leak must wear respiratory protection (MSA Pack). It roust be assumed that he will be exposed to levels higher than the permissible exposure limits when the source of th leak is discovered. 4 d. When the source has been determine, corrective action must begin immediately to stop the leak. If Maintenance is re quired to repair the leak, the request should have a high priority, normally 2A unless the leak is very large or a vapor cloud release, then 1A. See Emergency Section. Maintenance personnel repairing the leak must also wear respiratory protection and rain suits if danger of exposure to liquid. r UCC 093686 VINYLS AREA S.O.P. TEXAS CITY PLANT UCAR SOLUTION VINYI.S COMPLEX ____total,AZA______________ NO. 2 (Revised) PACE: 4 of 14 EFFECTIVE: May IS. 1981 SUBJECT: Vinyl Chloride Exposure Protection e. Non-essential personnel shall be withdrawn from the area of the leak. Personnel required to remain in an affected area are required to wear respiratory protection when spending 154 minutes in an area where the latest reading is 5 ppm, or anytime the individuals 8-hr TWA is forecast to be over 1 ppm. f. If. for any reason, repairs cannot be made immediately, the area must be isolated until the leak is fixed and VFA ' monitor indicates a return to normal conditions (< 1 ppm). g. The Chief Operator will notify personnel in the area ov r the PA system when the VC1 level is back to normal. h. All leaks, as defined, oust be recorded on the forms pro vided (copy attached) with a description of the action tr1-- to eliminate the leak. The completed form should be rout to the SPS, DPS, and Vinyls Dept. heed. 3* Leak Investigation Procedure (Bldq^ 112 Areal a. The Bldg. 112 Operator is responsible for monitoring the VFA printout# and determine if there is a leak as previoa__. defined. '& *1. ... . . if b. The Sldg. 112 Chief Operator must be notified immediately, as well as any other personnel in the affected area, wham e leak is indicated. I d. Other steps of procedure same as procedure for North Area and as listed above. 4. Procedure For High Levels At Bldg. 121 - a. The Bldg. 115 OperatorfHk responsible for monitoring the VFA for the Bldg. 121 area. When^Vnigh level fpt ppm or greater for a single point, or two consecutive readings of 5 ppm or greater) is detected in Bldg. 121, he will notify the North Chief Operator. UCC 093687 VINYLS AREA S.O.P. TEXAS CITY PLANT UCAR SOLUTION VINYLS COMPLEX TOTAL JUtSA NO. 2 (Revised) PASS: 5 of 14 EFFECTIVE: Nay 15, 1981 SUBJECT: Vinyl Chloride Exposure Protection 3* b. The North Chief Operator will notify the South Chief Operator and the Shift Prod. Supervisor. ' -4? c. If the Control Room (Point 5) is indicated by the VFA to be high, the South Chief Operator will use the Drager Detector to confirm the level in the Control Room and make the decision on proper respiratory protection (canister respirators or MSA Air Packs) for the Operators. d. The South Chief Operator, or the Operator if delegated, will use the Drager to determine the source of the VC1. He must wear respiratory protection while searching for the source. The most likely source is the varnish and a check of each impregnator must be made to determine the specific varnish involved. e. The South Chief Operator will cosmmnicate the results of his search to the North Chief Operator who will take corrective action in the Stripping Area, if required. * ^ <{ j | l f. The Bldg. US Operator will continue to aonitor the VFA and report areas of Bldg. 121 affected. \ g. The North Chief Operator will cosnunicate areas affected to the South Chief Operator who will decide on areas to be cleared of personnel and notify Staff. 4 h. The North Chief Operator will notify personnel in the area over the PA system when the VC1 level is back to normal. 1 i 1 1 i. The North Chief Operator will fill out the Leak Detection Log Report. .j UCC 093688 VINYLS AREA S.O.P. TEXAS CUT PLANT UCAR SOLUTION VINYLS COMPLEX TOTAL AREA______________ NO. PAGI: EFFECTIVE: 2 (Revised) 6 of 14 May 15. 1981 SUBJECT: Vinyl Chloride Exposure Protection 5. Routine Check For Leak* A weekly check will be conducted to find small leaks in the area. The Bldg. 116 Operator and the Bldg. 113 Chief Operator will be responsible for conducting the checks for their areas each Saturday on Day shift. Areas to be checked using the OVA include: North Area (Bldg. 116 Operator) a. Autoclave steam pumps b. Autoclave safety relief devices and manual vents c. Centrifugal pumps in the Stripping Unit d. Reciprocating (steam) pumps in the Stripping Unit e. The second and third levels of the Stripping Unit f. Safety relief devices in the Stripping Unit g. The compressors (unloaders and packing) h. Centrifugal pusps in Tank Area 1 i. Reciprocating pumps in Tank Area 1 j. The second level of Tank Area 1 k. Safety relief devices in Tank Area 1 l. Scrubber vent to atmosphere in Stripping Unite. VCl Tank Car Rack (Bldg. 113 Chief Operator a. First level - transfer pump b. Second level - four hookup spots. Building 119 (Bldg. 113 Chief Operator) a. First level - compressor, reflux pump, cycle tank, knockout pot b. Second level - condenser c. Third level - stripper feed motor valve f UCC 093689 VINYLS AREA S.O.P. TEXAS CTTT PUUTT PCAR SOLUTIOM YIICTL3 COMPLEX TflffiTi >ltt____________ 0. 2 (Bevised) PACK: 2 of 14 EFFECTIVE: >Uy 15, 1991 SUBJECT: Vinyl Chloride Exposure Protection recorded on a strip chart and stored in a Micro-Computer f r further processing. After each 20-point cycle* the stored in formation is printed out showing VC1 concentrations for each f 19 saaplo points. Tho 20th point is a 10 ppm calibration point. The first analyser covers Tank Area 1* Bldgs. 115 t 117. The second analyser covers Bldgs. 121* 122* & 114. The location f the sanple points are shown in the attached lists. The third analyser will be located at Bldg. 112 and cover Bldg. 119 and the VCl Tank Car Unloading Rack. ] Calibration samples are taken every 40 minutes. NheneVer the calibration samples read out of the specified range (10 ppm t 1 ppm) * the analyser must be reported to Maintenance for repair. The Bldg. 115 Operator ft Bldg. 113 Operator when VFA is installed* are responsible for monitoring the VTA* requesting Maintenance* for repairs if required* ordering replacing the printout sheets* and removal of completed sheets each Monday Day Shift. The com pleted sheets should be placed in the DPS`a box with other charts* `` filing the VFA printout 2 Portable OVA Units (Century) are currently available at Bldg. 115 for pin-pointing leaks in the unit. One unit will also be located at Bldg. 113. The analysers can be used to measure total organic vapors* or specifically for VCl. The analyser is accurate to 1 ppm. 3. Draqer Gas Detector 9|| The Drager Unit consists of a hand operated bellows pomp and a detector tube. The tubes come in three detection sisess 0.5 3ppn* 1-50 ppm* 100 - 300 ppm. The tubes are speeifife for e --vaini yel --ch* lo- r- >id* e- Three units will be available - erne each at Bldgs. 115* 121 A 197. UCC 093690 TEXAS CITY PLANT UCAR SOLUTION VINYLS COMPLEX VINYLS AREA S.O.P. NO. PACK: EFFECTIVE: 2 (Revised) 7 of 14 May 15, 1981 SUBJECT: Vinyl Chloride Exposure Protection Tank Area 4 (Bldg. 113 Chief Operator) a. Transfer pump b. Acetone purge pump All leaks discovered should be recorded on the forms provided at the Chief Operator's desk at Bldg. 115 and Bldg. 113. Action should be taken to eliminate any leaks as soon as possible. D. RESPIRATORY EQUIPMENT 1. The approved respiratory equipment in the Unit for protection from exposure to VC1 are (1) the MSA self-contained 30-minute Air Pack, (2) the Breathing Air Systems and (3) Canister Masks. 2. One or more MSA Air Packs are located at each building in the . Vinyls Area. A list is attached showing the number and location. Each Operator should know the location of the respiratory equip ment in his/her working area. The MSA Air Pack contains a clean MSA Mask and a full air bottle. Anytime an Air Pack is used, it must be reported to the Safety Dept. Ext. 6027 or 5199, for refilling the bottle and cleaning the Mask. 3. The Breathing Air System consists of a Mask and Hose connected t a cylinder of "breathing" air. Some buildings have cylinders connected to a manifold with several take-off points for hose use. Clean Masks should be stored conveniently located to each Breath ing Air Station or in the Control Rooms. ^ When a Mask has been used, it should be cleaned or the Safety Dept, should be called(Ext. 6827 or 5199) and they will pick up the Mask f&r cleaning. Breathing Air Systems are located at Bldgs. 113, 115, 116, 117, 122 and the VC1 Tank Car Rack. UCC 093691 VINYLS AREA S.O.P. TEXAS CITY PLANT UCAR SOLUTION VINYLS COMPLEX TOTAL AREA______________ NO. 2 (Revised) PAGE: 8 of 14 EFFECTIVE: May 15, 1981 SUBJECT: vinyl Chloride Exposure Protection 4. Canister type respirators are available from a storage container located on the west side of Fifth Street about midway between Bldgs. 115 and 121. The container is painted green and marked "Vinyl Chloride Canister Respirators" These respirators can be worn only in areas where the VC1 level is less than 25 ppm. The canister is good for four hours use. E. EMERGENCY A vinyl chloride emergency occurs when there is a massive VC1 release threatening a vapor cloud hazard* In this case, the . Flammable Vapor Cloud Release S.O.P. (Vinyls Area S.O.P. No. 1) should be followed. The main steps of that procedure are as follows* 1. Actuate the deluge system for the affected area. 2. Evacuate the endangered area (upwind or crosswind of the leak). 3. Activate the Plant Fire Alarm and/or the Toxic Gas Alarm. Locations of Toxic Gas Alarm boxes* Box 412 - Pipe rack east of Bldg. 117 Box 423 - Pipe rack east of Bldg. 113 Box 432 - Pipe rack northeast of Bldg. 120 4 4. Isolate the affected area, roping it off if possible. Do not allow ignition source near area. 5. Do not re-enter the area. Only Fire and Rescue Squad wearing proper protective equipment are allowed in the area. 6. Isolate the leak by remote valve or pumping arrangements, if possible. 7. All available water should be used to disperse the cloud and ucc 093692 VINYLS AREA S.O.P. TEXAS CITY PLANT UCAR SOLUTION VINYLS COMPLEX TOTAL AREA NO. 2 (Revised) PAGE: 14 of 14 EFFECTIVE: May 15, 1981 SUBJECT: Vinyl Chloride Exposure Protection LOCATION OF RESPIRATORY EQUIPMENT Bid?* No. Tank Car Rack Bldg. 113 Bldg. 114 Bldg. 115 Bldg. 116 Bldg. 117 Bldg. 119 Bldg. 121 Bldg. 122 5th Street Storage Box MSA Air Packs (30 Minute) 4 2 2 1 2 1 4 Breathing Air Systems Yes Yes Yes Yes Yes Canister Typo Respirators *t 1 1 2 2 1 20 UCC 093693 VINYLS AREA S.O.P. TEXAS CITY PLANT UCAR SOLUTION VINYLS COMPLEX TOTAL AREA.________________ NO. 2 (Revised) PAGE: 9 of 14 EFFECTIVE: Mav 15. 1981 SUBJECT: Vinyl Chloride Exposure Protection form a water curtain to prevent vapors from reaching an ignition source. Deluge, spray systems, monitor nozzles, and fire hoses should be used. 8. As a last resort, entry to the area shall be made from upwind by Fire/Rescue Squad especially trained to cope with vapor releases, wearing protective clothing and respiratory protect! n and under a protective water spray. An ignition should be anticipated at any time. 9. If a fire occurs, do not extinguish until the source of the fuel is shut off. A re-ignition could be more hazardous than the fire. * UCC 093694 VINYLS AREA S.O.P. TEXAS CITY PLANT UCAR SOLUTION VINYLS COMPLEX TOTAL AREA_________________ NO. 2 (Revised) PAGE: 12 of 14 EFFECTIVE: May 15, 1981. SUBJECT: Vinyl Chloride Exposure Protection * Date: Time: Operator: VINYL CHLORIDE LEAK DETECTION LOG Please list below the sources or leaks of VCl found in the Solutions Unit* Please list how the source was discovered and the action taken to 1 eliminate theleak. | Source .3 * How Discovered i 1 i J \ Action Taken UCC 093696 # VINYLS AREA 8.O.P. TEXAS CItT PLANT UCAR SOLUTION VINYLS COMPLEX TOTAL ARIA ___________ 0. 2 (Mriiad) PAGE: 10 of 14 EFFECTIVE: May 15, H1 SUBJECT: Vinyl Chloride Exposure Protection . Vr4 Point Bo, .* 1 ,F41'*.* 2 - *3 1 4 5 4 ^* ., * 7 1 v* 9 10 11 12 *,/ 13 14 15 14 17 * IS 5 19 20 -- > LOCATION OF VINYL CHLORIDE CONTINUOUS SAMPLE POINTS - NORTH END k% . . . * Buildiiui Loyal ' Location Tank Atm 1 Tank Aron 1 Tank Aroa 1 Tank Aroa 1 Bids. 117 Bldg. 117 Bldg. 117 Bldg. 117 Bldg. 117 Bldg. 115 Bldg. 115 Bldg. 115 Bldg. 115 Bldg. 115 Bldg. 115 Bldg. 115 Bldg. 115 Bldg. 115 Bldg. 115 Calibration Point 1 1 2 1 1: i i i l l . Berth of 02 4 412 tanka Berth of 74 tank South of 415 tank South of 475 tank Middle of compressor too* Control Boon Middle of dock Middle of dock North of 12 Dilution- tank North of B-4, 9 autoclavee South of B-7, autoclaves South of B-9, 10 autoclaves Office 4 Control Boon . Lab North of B-4, 5 autoclaves North of B-2, 3 autoclaves North of B-3, 4 autoclaves B-4 autoclave punp Calibration point UCC 093697 TEXAS CITY PLANT OCAR SOLUTION VIMTL8 COMPLEX VINYLS. AREA S.O.P. *0. 2 (Mriiad) PASS: 11 of 14 rriVE: Hay 15, 1541 SUBJECT: Vinyl Chloride Exposure Protection ' Point No. 1 .2 3 4 S 4 '7 9 io 11 12 13 14 15 14 17 14 19 29 LOCATION Of VINYL CHLORIDE CONTINUOUS SAMPLE POINTS - SOUTH END ' 4* Buildina Lml 121 121 121 121 121 121 121 121 121 Tank ATM 2 122 122 122 122 * 122 122 121 114 114 115 1 1 1 2 .2 2 3 3 3` 1 1 2 1` 1 2 3 2 1 1 1 Location ** Offica - Bldg. 121 Hast and of building Bast and of building Naat and of No. 3 Bird chuta Control Noon Boat, and by No. 4 wash tank Niddla of atoadser roon Cantar north wall of Bird roan Niddla of cyclone roan Northaaat of 13004 tank North of structure Between 013 and 031 North wall of gal tank roon North wall of ionexer roon Niddla of floor Niddla of floor Outside northaaat corner of bldg. Offica Control Roon Calibration point - 10 ppn UCC 093698 UCC 093699 mmCOURS E i XU l * I^SOURSl DESCRIPTION Ml ** -*w IV 11 w 1? n i \ t t# V _ 2* 2 7 i^f'7 PAYROLL NUMBER IJL i. 1. 3 0 a_ _a -I 0 !E 9 7 MM JL JL J SL A. o 10 F ) [r [Z 12 i. 13 D_ 14 G 16 JLH LJ1 0 10(19 20]0 12 ! ] "7 1 -'I __ " jt_ 1 1-----i_--: _ 23 3 23 1 _----_Hj 26 11 23 JV BATE aaere *0 VR row j'|<a |eo mm B J (SAMPLE 11 (Sampi-:: :? - `S;vr*\ mmmm mmfmn mmfflMm \o\?\o\?n annan ani '&mms mmmm mmmmmmMmmn cX&w\o\ I ftriifBraiBMBMi JOB AX TRAIN RETURN FORM TO: BLDG. EMPLOYEE TRAINING ATTENDANCE RECORD ^ S f S>Kt, TRAINER F / PAYROLL * ____LJ :S V SUPERVISOR ^ A? i - - -.i UCC 093700 CT 27^7 TRAINING COURSE ft TRAINING COURSE DESCRIPTION 3 4 5F / ae *3 31 f < 5 16 I t 6 1 ; ?o|:m 77 i 3 M L (9 \r\r\ vw\A/m> U4? PAYROLL NUMBER LAST NAMES n7 i. tm: 9_ 10 a12 13 14 15 16 i a 19 20 21 22 23 ii 25 27 28 mZ O m J5L a 2j j9_ _Q7 aoj?a m A_ E E3 o omm _EN JL E SI IL. I_ S ?s I JL E J aaan mnmmwm B af fm m mm m r JQ K 2mj1. P[ 2 i uan n -Q 4 m4k Buin JZ mwMmi 2 Fiaarauaar* a a a 1 2e. id QP-i e. _ L S o t mmmmmm mmm i Lr TA I L UJ "Tj" T3 n T a a i 3m mL n c z 2 XP / Z^Fij qWE3 7 t2 2J 7 _ ti 2 0 'M & A/ J/ d. --L r "T" J A r 1 u) *: (i a 2 JL 3 Kl x F X 3 H 0 A $ lu 2. / 5 /V It L. LL 2 1 V 2 1 IE^Z. ^HZ jjv n 9. 4 sK^z12 / X I JL L s / ray |T^fZ r L & A JL Z L S2r il iE- A" 2 r z 47 & d A/ X l / u K I i. 4n w L mm mm H 1 L -rr- mm I fi 1 is- d. ? 2 I c c M@ DATE OELKTt [MO vr coot: mm (SAMPLE I) (SAMPLE 2) r j >r> Kh'TI'J. uldl. c:t EMPLOYEE TRAINING ATTENDANCE RECORD t*sT T RAIN ER_ r.L.^OM+JXrtJ PAYROLL # SUPERVTSORTS', J/?. A/cJMCnA TRAINING COURSE # TRAINING COURSE DESCRIPTION DATE DELETE 1 1 1 2 1 j|k 1 5 16 i t 9 H 20 ^ 1 77 * ] M as u 22 QL L a7 34 T a Ln u n u 33 ~ 35 3fl 21 36 )9 i/ PAYROLL NUMBER LAST NAMES 11CODE 1 4j <3 44 45^117 *0 St) 1* -2_JLl_Ui JL...CL 3, j..Q| 0 59 S.X.10 J_12 13Lii5 16 17 1 819 20 2122 23 24 25 26 128_ ILiL JO Q (SAMPLE 1) {SAMPLE 2) a aa 4( : 9 K1 3 `j. 9 3 SI J~lL*JJ1 la. tl aj H FI z __1 nJL /?> ra z 3. 4. J. Cl Flit* K ri 51aa Z fJ m * aO _ -- - i *L\ F P P 3 A r f, wRKl. vJLLLiano9/ mjj\aej mFT Iwmsm? X ri & n o_ M __j ~1 L_141 K 1 & fa 7G a L7 a Ta 2= jL a 4c L$ ja 2*L il R M o. _ <v X cL 4 jC r JC ft. H fL XiJAL A ie M p Ji _ 'ft IZ 2 "r',r ** L . -t ' , Mm a O -. P:, ^ jl & H o JL -r a Mpi MM* |- XLi. iLa 5 4 K/ Y1 fi 0 ml L i,s 4. i5 CJ otfsi-' yM V7;v : UCC 093701 U C C 093702 JOB AX TRAIN iETUHN FORM TO: }LDG. _ J?7. TRAINING COURSE a EMPLOYEE TRAINING ATTENDANCE RECORD TRAINING COURSE DESCRIPTION List MJI M , F . I . , M . C . TRAINER JT' Jb/ttrJMyyy PAYROLL # 3SZSy SUPERVISOR 7>, _ 111 3 A 5 e 7 B 9 1 0 11 1 2 1 3 u IS 16 j; 1 8 1 S 20 21 22 23 74 25 21 J 7 26 ?9 3C 31 32 33 3' IS 3t 37 3 B 19 4( 4 1 42 43 44 / Vo\? 0 % o . k w L /C M L o & * /2 T. <2 N t N4 PAYROLL NUMBER 2 _3_ 4_ _5 H 7 _Q_ JL. _a n 059 1 BB m 8 jL i 3 a if? ? 2- / n % r / fn J/ rainn s; * XSi 1 JZ X _ X X X El ra _SL i_ X L * X j2 a X 13 --LAST NAMES 1 8 9 10 Ll_ 12 13 14 15 16 v_ 1 8 19 20 21 22 5SL A_ R _B_ D E_ r r tttJ 0 N fE i_ L_ _ _ _ t i r|2n4 25 i i . - r" m\ m m >f' *:' j'.J /L,' r%f IL J er - __ 14. & Q. AL 0 . 2.' o Z> r_ m. 21 _ C_ 1 4 X ML D it bL f=- >i X X mimmm 0 w_ /V / V z. g~~ a_ /_ X EL lT y n \P_ _ ]_ S_ *"*"1 X x a X L x it._ V X 0 nn L1 fr J (SAMPLE 1) (SAMPLE 2) __ '1 _J n r 27-788 3 L__ ITU ~j 1 MU JQOHI INTERNAL CORRESPONDENCE UC 1*3- I TO: SVR Staff SVR SPS cc: M. E. Eisenhour F. S. Provenzano D. G. Reese P. O. BOX 471, TEXAS ClTY, TEXAS 77590 Date: January 5, 1982 Subject: Revised Training Schedule January 1982 The new schedule of the SVR Unit Startup has necessarily changed the Startup Training Schedule. Also, we have obtained permission to have all operators back in the unit on days for one week (except for the minimum shift coverage) which will allow an unusual majority of all SVR operators to meet together. The amount of overtime necessary will also be minimized. The attached revised schedule has all operators except the day minimum coverage attending one big session. The midnight and evening minimum coverage personnel will be the only overtime necessary. The day minimum coverage personnel will have a makeup session as shown. Please see me if there is any confusion concerning this schedule, or if there are necessary changes to be made. Sincerely, SMN/gh Attachment S. M. Norwood UCC 093703 SVR TRAINING SESSIONS January, 1982 Subject 1. State of Union and Vinyl Chloride Trainer Trainees - D. G. Reese F. L. Johnson All SVR Operators and Staff Time Date Shift Place 7 am - 1-18-82 10 am All No. 3 CR Shifts 2. Bldg. 115 Ins trumentation and General Autoclave Operation Regular Distillation Control J. A. Gordy and T. T. Do J. R. Rex All Qualified B-115 Operators, Chiefs and Vacation Relief All Qualified B-114 Operators, SVR Staff 12-4 1-18-82 pm All No. 3 CR Shifts 3. Carbon Bed Operation Bldg. 121 Misc D. J. Tassin M. T. Rissky All 121, 122 Outside Operators S. Chiefs and Vacation Relief 1-4 pm 1-19-82 All No. 3 CR Shifts MAKE-UP SESSIONS FOR THOSE COVERING UNIT DURING ABOVE SESSIONS Same Same Same Same Same Same Same Same Same 12 - 3 1-20-82 A 197 CR pm 12 - 4 1-21-82 A 197 CR pm 12 - 3 1-22-81 A 197 CR pm UCC 093704 JOB AX TRAIN RETURN FORM TO: BLDG . EMPLOYEE TRAINING ATTENDANCE RECORD LAST NAME.F.I..M.1. TRAINER PAYROLL # _ SUPERVISOR. UCC 093705 JOB AX TRAIN RETURN FORM TO: BLDG. _____ EMPLOYEE TRAINING ATTENDANCE RECORD LAST N*E,f.I.,K.r. TRAINER p. iku- PAYROLL # _ SUPERVISOR. TRAINING COURSE # TRAINING COURSE DESCRIPTION 12 ft3 i 6 1 6 9 1 0 \ 1 S 2 \ 3 1 4 1 5 1 6 i i i ft 1 E 20 2 1 2? 23 24 2 ft I! IT 2ft T9 3 ( 3 r 35 33 \ U N L T ft A l 4 /> * C K ( 13 5 3 6 33 3ft >9 *( 41 DATE DELETE IMO. 42 4 sj 44 4ft^|47 4ft YR 49 5 CODE UCC 093706 m JOB AX TRAIN RE TUB N I'ORM TO: BLDG. EMPLOYEE TRAINING ATTENDANCE RECORD t*S T TRAINER } ) ( DO PAYROLL # 71^\ supervisor U&'lPJ u c c 093707 JOB AX TPAIN RETURN FORM TO: BLDG . EMPLOYEE TRAINING ATTENDANCE RECORD LIST NDME.F.I..M.I. TRAINER rJT> PAYROLL # 3 > 7r'Jrl .qriPERVTROR MCrSef/CM' M joU TRAINING COURSE ft TRAINING COURSE DESCRIPTION 1 2 3 4 5 6 7 8 9 I 0 11 E 7 1 3 1 4 1 5 \ 6 i: \ B 1 20 21 22 2: 24 25 2 ( 27 28 ?9 3 ( 3 1 32 33 3' 35 36 37 36 19 4 ( 4 1 42 43 44 4 7 b L / F / / 310 5 0 V Ll L zti < L 0 /> R Rr A' i PAYROLL * NUMBER LAST NAMES K DATE DELETE I HMO. VR CODE 47 4 B 49 50 00 ro o u u D 3 8 9 10 Ll 12 13 14 15 16 17 1 8 19 20 21 22 23 24 25 26 2 7 28 50 ch J0 RBIDE NES 3 Q (SAMPLE 1) K 2W/Ay/ U& l L> 4 I H \1 R ft r f u e 1 0 4 fr- ft T? ft- YR fR N A0 A L_ r ? 0 X D 2. t-- I rfl, l s /u Jp (j /u -------- i; Ml . mi ri i 1! |. ... -- | 1 1 ; mi ..-- ... -7- -- -- i-- INTERNAL CORRESPONDENCE UC 149-- Z TO: cc: D. L. Berringer G. W. Crody W. W. Johnson J. C. Kiri C. P. Milligan E. E. Simpson H. J. Augustus J. T. Floyd F. S. Provenzano D. G. Reese A. 0. Ross V. O. BOX 471P TEXAS ClTY. TEXAS 77590 Date: November 20, 1981 Subject; Vinyl Chloride Training -For Operators & Maintenance OSHA Regulation 1910.1017 (j) requires that "each employee engaged in vinyl chloride or polyvinyl chloride operations shall be provided training in a program relating to the hazards of vinyl chloride and precautions for its safe use". It further requires that this training be done annually. If your personnel have not received this training in the last year, you should arrange to do so. The Safety Department (Ext. 5153) has the Vinyl Chloride Training Film in both video tape and 35-minute slide module. FLJ/st ucc 093709 VINYL'S PROBLEMS CONTINUE TO MOUNT. It's difficult- to put this one into perspective at this time. Solet'sjustquickly review where the industry stands. The problem currently concerns the manufacturing of polyvinyl chloride and the exposure levels of vinyl chloride monomer that' : -^ will be permitted during manufacturing. Last month, the CSHA standards were"set at 50 parts per- . . % million (in air)--a level that industry could meet and was, in fact,, above the exposure levels that Y many plants were already operating at. This month, however, CSHA changed its mind and came <_ " ' ; out with a new standard that called for "no detectable levels" of monomer as determined by devices' ^ y capable of detecting concentrations of 1 ppm with an accuracy of 1 ppm, plus or minus 50%, 7 Without going into technical aspects, it's-a tough one.5 And most producers of PVCfeel it's not *> ^ only impractical, but unachievable; If if stands up--*ahd theoretically,' it's due for adoption by .- v * / ,, October--the vinyl industry is in for some really serious problems. The industry's efforts right now are going towards proving to CSHA that it's possible to insure the safety of workers wirhout * ,,* resorting to the extremes called for in the CSHA standard; while both CSHA and the SPI are un- - dertaking separate studies on the economic impact that the standard ecu Id have. ^ ^_______ " " ; ^/t'm sure most of you dori't need the studies to know what the impact would be--especially ; ' i - in key markets like automotive and construction. A disaster. Sb there)s a goad chance -/ - , .` that the industry may get some relief on the standards before October that will make them ; " possible to live with. I still feel strongly, however, about the need for educating the mold- /yers,. fabricators, and end-users who work with polyvinyl chloride bn the.subject, Jusr /judging by some of the talks I've had with these people, few are making the distinction , between vinyl chloride and polyvinylchloride.^ Their anxiety"is showing and if could ,: .*-. -s-^v*":hurf in the'Hays aheaHT^ - \ 7* " ` v v _- :' --' "TTT CrJ." -* - -r . '* * / * . -`-ft r" '* ^,3;>, , . r ^. '' S 's . , . J-i ' ' ** ., Fibrous glass-reinforced plastics keep pace with Detroit's: interest in new finish- ;; * ]NG TECHNIQUES--LIKf POWDER COATING; Everyone's.well aware or the advantages that , , -- powder coating offers: the automotive industry as a competitive technique for conventional- wet phinf--. ' * ingr lower cost, less waste, less pollution. But up to now, not many people-considered reinforced r ,, 4 plastics as a candidate to be powder coated1 by the electrostatic process (sinceRP is non-conduct-,,. - ive, the charged powderparticles would not be attracted tb it). Well; the situation's changed. _ ;( '3 Owens-Coming now has in development a special primer mixture which provides conductivity to f r. ;v. 7 the glass-plastic part" and allows it tb be sent through paint curing ovens without loss or surface ' - integrity. The hew one-pass system is a big step over the two-coaHsystem previously used'{one coat- / ;% ' to-serve as aprimer; the other ta add conductivity) and. if could-be ready-1for'productrbrr-by4W#hd- of the year. Conventional spray equipment can be used. And although'C-C has worked mostly so . far with actylic-metallic and epoxy-type powders, it looks like other powder paints would.be equal-. , ;ly as'0ppl.icable, ' /.> - C- ' ( - ' ' ' -y- ) -- "r7~- -V; ; v r jFLAME-RETARbANT POLYOLEFINS IN SHEET FORM, - Mbit of the publicity so far has ' V " ] " gone to flame-jetardant molding compounds. But the same'formulations are aIso^appIicable ; 1 umtfojTnoDi iY; "hlgh^ensity polyethylene and cross-linkable polyethylene).* The sheeV.meets A^ - '< U' L Subject 94'ratmg 94 V-l, is non-dripping, and low sifmke.generating-- Pofenfial, " ,, j ;bf course. Is. hythermoformed products for aircraft, mass-transit,'automotive, con'sffuction; ..industrial, anct electrical products--in fact, any application that might TnvolveContact' ' with- large numbers of people or proximity to expensive industrial equipment. *- s _j ;* i v V ^/ .air; UCC 093711 vii- Z.I THE WALL STREET JOURNAL _______ Monday, Oct. 7. 1974 Health Hazards Vinyl-Chloride Scare Points Up Dangers J OfOtHerChemicals - < , - --* ---------Substances - Long' Believed ; * ' "<t, . Safe NowAre Regarded . . With Greater Skepticism A Hospital's Hidden Perils ' ' . By^BARRY Kramer ttnff krptlTtrr Of THt WaI.L ftTRFKT JOUtNAL - It's a simple moleciiletwo atoms ot car bon. three atompof hydrogen and a single atom of chlorine, 'M room temperature ttis a gas. The molecule U hailed chloroethylene by. chemists, ,, but ; It Us - more commonly known-as Vinyl chlqride. The chemical structure of vinyl chloride has been known since the 1830s. Since a dec ade-after the Civil )Var, scientists have known how to link, or polymerize, the vinylchloride molecules like, beads on a chain to , form a plastic called polyvinyl chloride, or PVC. Since the late 1930s, When B.F. Good- ' rich perfected a commercial process for po lymerizing vinyl' chloride, the plastic has , come to be a staple in thousands of house hold ; products ranging Irom kitchen food . wraps to construction materials. .. , ` Last January, the world learned some- thing else about vinyl chloride: It can cause This is the second of two stories con >peniinp implications of the discovery that vinyl chloride can cause cancer. cancer in humans. v Twenty-six cases of a rare liver cancer have been -discovered among workers in polyvinyl-chloride plants. All of the workers were exposed over many years to large quantities of vinyl-chloride gas. In recent months, further evidence has come to light indicating that the gas is also responsible for an increase of other cancers among the workers in the PVC plants. As a result, there now are standards regulating vinyl-chloride emissions in factories Vinyl- chloride gas has also been banned for use as an aerosol propellant, and the Food and Drug Administration Is toughening restric tion of the amount of vinyl-chloride,in PVC food wraps. , ; Vinyl chloride, of course, is far from thej only man-made chemical known to cause cancer or, for that matter; other human ail ments. Industry regularly works with toxic1 substances of all types known to cause ill ef fects ranging from'skin disorders to dam aged lungs, kidneys and livers. ri'HuiTUTftTilnfOKZtf chloride. TMnlatn The , chlorinated hydrocarbons, as the chemicals are collectively called, are used in a broad range of products to which every human being has multiple exposures It would be difficulttSUnd Jt'pArSoifjfhjrwhere who hasn't come lnto.contact with products such as plastics, anesthetics, insec ticides and herbicides,, solvents and pharmaceuticals. all of .which, can be madeifrom chlorinated 'hydrocarbons, -(As a^result of their widespread manufacture'and qse, mol ecules from these'products cnn.be found ev erywhere on earth and in the upper atmo sphere. Such molecules are also commonly ., found in human tissues. " V'*" ' ; i ' What is particularly concerning some scientists is the fact that the compounds are rarely found in natural system^ unless those systems have been exposed to man-made pollution. "Although all living things contain considerable amounts of chloride ion very few chlorinated organic compounds ac tually occur in living things," eaya Dr. Barry Commoner, director of'the Center tor the Biology of Natural Systems ApyFashihg- ton University in .St, Louis. , - 1//`J-,V Trial and Error ... ,, ,,- . , : Dr. Commoner further notes,that' biol ogic evolution isa-process of trial-and ferror over millions of years;-therefore, hesays, the asayjgj)|jflUia^lWBRds 'that since the chlonnatedhydrocarbons are virtually ab sent from''all living things,; the- compounds are likely to.be "evolutionary rejects.'^ And that means, he' says, that if such compounds Invade a natural system like that of man, they are likely,to he toxic.*.' 7 "TWs means that Industrial operations that synthesize or make. use pf suph sub stances. and agricultural- and other opera tions-that disseminate them into the envi ronment, ought to be governed by the level of prudence that is demanded -by the inher ently dangerous situation,".,Dr. Commons'1 says. "That we now are discovering, with increasing frequency, health hazards due to dissemination Of synthetic .^organic sub stances, both In the workplace and the gen-. eral environment, is evidence .that we'have' thus far failed to appreciate the need for such care." .. , " ' '* ... It is interesting to consider that vinyl chloride, in the early days followingiits dis covery. was actively considered as an anes thetic for surgery. But animal tests showed that the gas caused heart irritation; and it was abandoned for that use in- favor of other substances. However, many anesthetics In use today are chemically related to vinyl chloride--and there is growing evidence that they aren't without harmful ..sidp ef fects. - For the past several years, for example, there have been scattered reports of HI ef fects suffered by those who administer anes thesia and among others continually ex posed to anesthetic gases while working in hospital operating rooms. It has also been known for some time that there is greater- ' than-expected incidences of spontaneous abortion among female anesthesiologists and nurse-anesthetists and, more tellingly, a, greater than expected rate of certain types of fatal cancer among anesthesiologists of both sexes. (There is no evidence that such anesthetics pose long-term dangers to surgi cal patients. One recent survey -of nurse-anesthetists in Michigan showed that of those' who worked in the operating room during preg nancy. more than 16r/r delivered Infants with birth defects, compared with a birthdefect rate of under 6r/( among nurse-anes thetists who stopped working during their pregnancy Other surveys have found higher-than-oxpected rates of miscarriage and Please Turn to Page 25. Column ,i s <7iWk'> 1(`s nil*-1.^" c*@0 <<$ 0*' ealth Hazards:, Scientists Look Aanielsw,: \o\ >`k . Based on 'previous, leas-conclusive evi the possibility that' pome chemicals in the At`Safe'Chemicals it' t-f - Continued From First Page v. ,,', stillbirths among.the wives of.anesthesiolo gists, even though these wives presumably didn't enter, an.-operating room until the dence linking arsenic with cancer, the Na tional Institute for Occupational Safety and Health last January recommended reducing maximum levels of arsenic in the air of, fac tories from the present 4.6 milligrams per, * cubic meter of air to 0.05 milligrams.,Iiidus- t JT try has opposed that reduction, btj^jerois workplace cause cancer onl/in combination with other chemicala.;And, the fxpqsure of most workers to' many chemicals at thC same; time would make tt difficult to pin point the offending-Chemibah > _ . ,, it., r, . The cancer ganger of vinyl Chloride was spotted only/ because-it caused an exceed ingly rare tumor, -liver -angiosarcoma,; of time of their deliveries One explanation ad vanced by observers Is that the anethesloio- $ gtsts somehow * carried home. , sufficient ^ y amounts of anesthetic gas in their breath or ." i ^ t on their clothes to affect their spousbg. - i ^ v V aaiaittuiimJAitmm O "no detectahle - limit on ersenlc ; | UBviously, it isn't enough to learn that workers exposed decades before to vinyl chloride, arsenic and asbestos--to name a - which there,are only slightly-jnorethan 100' cases ln medical; literature. If'vinyl chloride ] were to. cause a more common malignancy, i such as-longjcaneer;, it wouldn't-have been so readily detected as a carcinogen. ' /: 1 Studies are currently under way to deter- mlije whether or not the wives', of vinylchloride workers have been affected by min- mte amounts of (he gas unwittingly carried home by their husbands from the plants. Of particular. Interest Is the rate .of stillbirths and miscarriages among these women. The studies are by no. means simple,, since the true rate of fetal- wastage throughoutihe na tion isn't, exactly known- and therefore a basis of comparison is 'difficult. Further more, the women's husbands are also ordi narily exposed to a`wide variety of-, chemi cals other than Vinyl chlorides, hampering direct correlations. ~; : V - , - , . There are, of jcoqrse,' other carcinogens, or cancer-causing agents, and' toxic chemi- I cals in,widespread Industry-use that are 1 even more dangerous than vinyl 'chloride. M^hfore the Labor. Department began setting ^^Hidards for vinyl-chloride emissions in ^Wctories-by an emergency decree in May and then by a "permanent" standard effec tive next Jan; J--it had issued standards last January for H other carcinogens. - < ^ V" Vs *e'V carcinogensr-are dying today of. cancer { or of other toxic effects of those substances. ^ J But the question of how to go about deter- cfy,mining whether chemicals are indeed lethal in the long term1 is the subject of some dis But testing la'oniy one part-of the orob-i . left)* lll(j MKIHhftN being what" do do about ( toxic substances once their dangers-are ek> rwrffryn:gfNrfffffi7.-. pute.. ; ^ . One - suggested solution is > to --test rail '`chemicals already in the. workplace' and to i- test other chemicals before they are used. However, .Dr. Irving J. Selikoff,' an expert on environmental carcinogens ah 'Mount Sinai School' bf Medicine in New.' York,! claims that this;would be "unrealistic and1 scientifically Impossible. , ; ) ^(Resources are limited," lie says,' "so we can't go charging off in'all directions at once." Instead, Dr. Selikoff says that he and. Dr. E. Cuyler Hammond, the chief health! statistician of the American Cancer Society; have worked out some tentative .testing -guidelines. First, he says; chemicals to be tested should be those to which large num bers'of workers are exposed- If many con sumers are exposed to the chemical as well, he adds, the substance is an even likelier target for study. An example of one such chemical is car CAflmiJnMfaoratory^mmaisjtyet no*ohe is buggestimnBanuftaHisffljeorasHcaiiy cur tailed among- humans lof that reason; ) r , l'i arri/ve/at a,balancepetween fljks and benefits, the risks must be JUlly understood. But very little l|i known about the dangers posed to workers-by' the- thousands of sub stances they .work' wlth. ^and there is little optimism thatsuCh-fiubstanoea-will be fully! tested in the near future..Government agen** cies are understaffed and working with lim ited funds. A Toxic Substances Control Act, which the Labor (Department" says It needsJ to strengthen its .hand In'controlling, Indus?' [trial chemicals,Js stuck in a1 House-Senate / conference committee, u ' Of course, teven If su<Sh ah'act weye to. be 1 passed,'even'the most sanguine, aren't aug-'| itatfildut&filfiiliis Industry will be able to ns^jne-blithely that lntn^worJ! environment are safe mjSI^SBWw^Rey've never demonstrated any overt harm. Like vinyi chloride, which took years to take its toll on worker health, many chemicals thought to be' harmless may be equally insidious. This may well mean that there will have" to be extensive animal testing of new chemicals before they are introduced and that workers' health will have to be continually monitored to detect clusters of disease. '' >* . - The task of such testing and monitoring would be mammoth Indeed. There are cur rently 23,000 industrial chemicals. More than 500 new ones are Introduced every year. With an array like this, it's llkelythat other vinyl chlorides are lurking In the background. Allied Chemical Corp. and Dow Chemical Co., for example, recently reported to the Labor Department's Occupational Safety and Health Administration that they had found excess cancer mortality among work ers. at two planta that made pesticides with bon black, an ingredient in rubber Urea and, I consequently, a widespread'air. pollutant. I "We ought to be taking a look at what's hap pening to carbon-black workers," the doctor says. (Scientists currently know that mas sive doses of carbon black painted on. the skin of mice has caused - tumors.) - Other prime study targets, he says, ' are sub stances whose chemical structure is "suspi cious" (or not unlike the structures of known carcinogens). , The testing envisioned by Dr.' Selikoff would be a combination of animal trials, in which hundreds of animals would be ex posed for long periods to the chemicals being studied, and statistical surveys ' of working populations that have handled the chemicals. "There are agents to which mil lions of people have been exposed which now can be evaluated in terms of long-term human experience," he says. "The' human data is there waiting for us to evaluate it." (Because animal studies don't always pre dict what will happen in humans exposed to the same substances, he says,, the human , gesting-thatthe workplaces of American in dustry will be cleared of-danger.; Neverthe less, it is becoming more and more !evident that-, there Is less willingness to; accept chemical dangerB-as simply,.an Inescapable part of working life/' ^ .1* 1 - [ "Whatever happens," editorializes Lan cet, the British medical journal; "the vinyl- chloride episode will have provided a salu tary lesson. It will not be quite so easy, in the future as It has been In the past for any chemical manufacturer to assume, until proved otherwise, that a-chemical to which workers are exposed is carcinogenically safe. There must surely !be more systematic evaluation of industrially used chemicals for carcinogenic risk to workers." inorganic arsenic. One study, conducted by monitoring is essential, i Johns Hopkins University's School of Hy All this testing would be complicated by giene and Public Health, found that of the 22 retired male workers from Allied's Balti more pesticide plant who died between 1862 i4Hkl972, 17 had died of cancer. At Dow's Mich., arsenical pesticide plant, 1^TMTM was closed down 20 years ago, Dow researchers found that of 173 workers who died between 1940 and 1972, 57 died of can cer. Both studies show higher-than-expected 1 rates of cancer death. I UCC 093713 352 reduce further the hazard and inconvenience of excess noise. Also, high noise levels can prevent the transmission of warnings, both verbal and machine, and speech interfer ence by noise can lead to errors, including safety-related errors. Wilson described the speech interference level for the normal male voice as approximately 69 dBA when the distance to the listener is two feet, although "truly reliable or error-free conversation" would require much lower background noise. A reasonable estimate for errorfree communication, he said, would be levels 12 dBA lower, about 57 dBA for a normal male voice two feet from the listener. Subjective judgments may be unreliable in assessing a noise problem, Wilson said, because most workers become accustomed to high noise levels after an initial period of adjustment. Hearing damage continues, however, de pendent on noise level and time of exposure, even if discomfort is no longer experienced. Noise Surveys ' A manufacturing plant noise safety program should begin with a plant noise survey, Wilson said, A noise contour map should be plotted over a floor plan, showing locations of steady noise sources, and amount of exposure. Wilson described a type 1 precision sound level meter, costing about $1,500, as a good investment if it can be expected that the noise surveys will lead to. other noise measurements. For most noise 'surveys, a type 2 general purpose meter, costing about $400, would probably be adequate, he said. Useful access ories would include a windscreen, and sound level cali brator about $150. As a company grows, noise problems may increase to where more sophisticated equipment may be purchased, and personnel may be trained in their use. The supervisor given responsibility for noise safety in a manufacturing operation, should be given the time and the authority necessary to do'the job, according to Wilson. He should have a background in mechanical, safety, or industrial engineering, A small manufacturer may find it practical to contract for noise engineering services with an outside firm. Wilson pointed out that, if the noise survey indicates levels above 90 dBA, the manufacturer will have to use both engineering and administrative controls. Access to high-noise areas should be limited. Noise monitoring and hearing conservation programs should be instituted im mediately. Engineering solutions, such as reduction of noise at its source and elimination of noise transmission paths, are most effective attenuation measures, Wilson said. Health. Hazards -SNELL STUDY REPORTS ECONOMIC IMPACT OF PROPOSED OSHA VINYL CHLORIDE RULE The estimated economic impact of standards for the vinyl chloride monomer industry ranges from 0.073 cents per pound to meet a 50 ppm ceiling VCM level, to 0.42 cents per pound to meet a less than 10 ppm ceiling VCM level, both with a one to five ppm time-weighted average OCCUPATIONAL SAFETY & HEALTH REPORTER (TWA), if the 1974 capacity is to be sustained, according to the first results of study by Foster D. Shell, Inc. Florham Park, N.J. . ; The Snell study, commissioned by the Occupational Safety and Health Administration to assess the economic impact of proposed vinyl chloride standards1 on industry, divided the industry costs of reducing VCM levels "in VCM plants into five categories: engineering COst&, `personal protective equipment costs, monitoring costs, productivity loss, and expensed items. ': Information for assessing the economic impa'ct under various VCM regulatory levels was collected through an industry survey conducted by Snell. Figures -were based on Snell audits of industry assessments of required engi neering, personal protective, and monitoring equipment. Within the five categories, engineering cdsts-included ventilation, vapor recovery, stripping, loading for shipping, and "other (pumps, piping, etc.)." Personal protective equipment costs included shower and eating, facilities, breathing equipment (respirators, air lines and bottled air), and clothing (uniforms, and protective?-, clothing). Monitoring costs included personal monitoring equipment, area and leak monitoring equipment, medical testing, and recordkeeping. Productivity `loss included The cost of keeping at the levels unimpacted by OSHAcapacity otherwise derated as a result of regulation,, the cost of equipment, personnel, etc. The expense*! items .included consultant costs, management time, (out-of-pocket expenses of 0.01 cents per pound are not included in the cost summaries). ; v r- , v.i.-- The study included tables of. summarized;estimates of VCM industry cost impacts and- timing tq .meet .selected VCM compliance levels. .. , PolyvinylChloride ' The results showed the estimated economic impact on the polyvinyl chloride industry ranged from (f.72 cents per pound to meet a 50 ppm VCM ceiling tb?2.73 cents per pound to meet a 25 ppm VCM ceiling with a 10 to 15 ppm TWA and sustain 1974 production capacity. These figures were computed from similar category deter minations. Price Escalation " The study noted increasingly strict VCM compliance requirements are expected to result in significantly greater price escalations for PVC than for VCM. VCM prices are estimated to be reasonable through a 15 ppnt ceiling and 5 to 10 ppm TWA since supplies are not expected to'be affected. The eight cent per pound price af the less than 10 ppm VCM ceiling and one to five ppm'TWA is viewed as being on the low side since the effect of the claimed 42 percent of industry capacity possibly lost as a result of this standard should cause additional price increases due to supply and demand factors, the report said. Also, PVC prices are estimated to be reasonable through a 25 ppm ceiling with a 15 to 25 ppnrTWA since only 9 percent of supplies may be affected. Snell said a 9 percent expected reduction in supply was claimed in the industry sample. The 22.9 cents per pound through 30.5 cents per pound prices at less than a 25 ppm ceiling and less than a 10 to 15 ppm TWA are viewed as being on the low side, since the effect of the Occupational Safety & Health Reporter UCC 093714 CURRENT REPQRT claimed 31 percent to 100 percent of industry capacity possibly lost as a result of the lower standards should cause additional price increases due to supply and demand factors. Protective Equipment Two of the four types of respirators listed under the proposed permanent standard are available readily from at least one equipment manufacturer, Snell said. These are the pressure demand full-facepiece self-contained breath ing apparatus, and combination pressure demand fullfacepiece respirator and pressure demand self-contained breathing apparatus. The other two types in the proposal "are not currently produced," according to Snell inter views with manufacturers who indicated these devices are considered wasteful of compressed air. These types are: positive pressure full-facepicce self-contained breathing apparatus, and combination continuous flow respirators and a pressure demand self-contained breathing apparatus. The results showed the required types of respirators purchased under the 50 ppm .temporary standard may be used under low VCM ceiling concentrations. Industry and employees piefer half-mask air lines, canister, or cartridge type respirators over those required under the OSHA proposal, Snell said. Also, the number of covered workers needing respiratory protection increases with a decrease in permissible VCM concentration levels or require higher respiratory wearing times, the report in dicated. Most types of protective clothing are available within four weeks from order placement, according to the report. Disposable clothing, hoods, shoe covers, gloves and overalls are available within one week from the manu facturers including one piece pressurized suits. Permanent (reusable) work clothing is available also within one month of order. Full impervious pressurized suits, how ever, have a procurement lead time of at least two months. The report indicated also that costs for protective clothing vary with type, with a low of $3.50 for dis posable clothing, to a high of $178 for a permanent, impervious full pressurized suit. Monitoring The results indicated the following points with respect to monitoring equipment: (1) The three major classes of VCM monitoring devices, personal, data, and leak, are all available to the VCM and PVC producing industries. (2) The costs of monitoring equipment range widely depending on type; however, most equipment purchased under the temporary 50 ppm standard may be used at levels down to, and below, one ppm VCM. (3) Expenditures for monitoring equipment for a typi cal VCM or PVC plant average $100,000 in capital with annual operating expenses of $80,000. (4) The industry as a whole, shows no preference for particular types of monitoring equipment, although the concept of area monitoring appears well accepted. (5) Automatic sequential monitoring systems can serve as a long term data collection system for an entire plant. 353 (6) The automatic sequential .monitoring , system can protect workers and alert maintenance., personnel when excessive VCM concentrations occur,,,. 'yj, Medical Surveillance ^ t v' The report found that with regard'to, medical surveil lance costs, the average time required per employee for the required medical examination is four hours wh4n performed outside the plant. The Snell,estimate for total, examination cost per employee is $160. Industry4'jest!-' mates of present medical ` surveillance'',costs average. $140 per worker per year. j v 2. * ,' An OSHA spokesman said the report received flrdm Snell fulfills the information requested bythe OSHA contract and constitutes another ecoribmijj input into final deliberations. Snell will submit tnore recommenda tions, but the study, at this point, is)what was'needed in the OSHA Office of Standards. " ,, ' **', ' r.,ur,..' Industry Comments ' ` 1 Joseph R. Shaw, president, Associated Industries1 tif , New York State; Inc., 'protested the'- length of time allotted for comment on the economic impact statement in a telegram sent to Assistant Labor' Secretary Johft H. Stender on August 27. * ` 4 -y- Tire telegram is as follows: ' , r-v, "Associated Industries of New York,1 Inc.,' protests' the overly short time permitted 'for comment on the hew" impact statement for vinyl chloride as`published iri the- Federal Register on August 26. The'notice'was not issued until after the hearing record closed,'and the 'new irripaCl statement has not been sent to the 'hearing' participants,' unlike the environmental impact statement in June', lire opportunity to comment fs effectively foreclosed. We recommend a time extension to September 26 and 4 mailing to all participants in the hearing; in accordance with normal procedures." ' ' ' ' Notice of the availability of the study was published by^ OSHA on August 26. The study, is available for examina tion and copying in Room "230, , 1726. "M ,"St., NW,; Occupational Safety and Health Administration; Washing ton, D.C. 20210. Alt comments regarding the study should be mailed to the Docket Officer, Docket OSH-36, at the above address, and,roust be postmarked no, later, than September 6, 1974. / Health Hazards i'1 SELIKOFF SUGGESTS VC IS "MUTAGEN," - i- INDUSTRY CONTINUES BATTLE ON STANDARD . -I , Possible mutagenic effects from exposure to'.vinyl' chloride were seen in examination of 11 workers, Dr'. Irving J. Sclikoff, Mount Sinai School of Iviedicme, New, York City, N.Y., told the Senate environmental subcom mittee on August 21. 1 '' Selikoff described work'by a graduate student which showed VC may cause both genetic damage and birth defects. The white blood cells of the 11 men were examined and abnormal chiomosomes in move of the sample than would have been expected were found, when the findings Copyright 1974 by The Bureau of National Affairs, Inc, UCC 093715 * Sr >'-ZJ - :? ?... i . <'*Bk ` *. r c-..' J: f, H - ' * * i SEPTEMBER 30, 1974, ''" -l v . : : -i'; ; ; .; v> 'i '*; .,> ^ * . I' t. v ^ ' vi' ```V' -A1-* f- < ' A', * *. ..............'**''vV v f ' - '' ; : . 1 ' v A i i ST* ?i J-* ^ *'V/V*'' * >i\-4' j"/ - *r . ** . up. smoothly for developer B, F. Goodrich Chemical Co. at its Vinyl chloride mono- \ / mer plant in Calvert City, Kyr \ Dubbed the Caloxid process, it operates at lower temperatures; than conventional., . incineration, improving operating safety and allowing low^cost'materials of con . i .. . struction without excessive maintenance. The process generates a substantial amount"" , V of steam, from the svastes during treatment, and can handle liquid feedstocks carry- , - t: ing suspended solids. In oxychlorination VCM plants such as Goodrich's, further- more, chlorine values (as hydrogen chloride)can be recycled for making precursor , - ethylene dichloride. The process is offered for license. ;; , J,, L It's official now: Dow will build a'petroleum refinery, on the U.Si, Gulf Coast, to supply feed- }; stock and fuel to its operations inTexas and'Louisiana. The 200,000-bbl/d, more- . 'v.;,i',1 ,.- than-$20(I-miUion'facility at Brazosport, Tex., will produce naphtha, distillate fuel., , r til *lr i..vs' */ ' ' oil uu*d residual fuel, oil, _pliis byproduct sulfur that .will go to outside customers., ,; , -.V-1 Ip ** * , 1 y- ' - ^ ; -r^ ' .1,,J'" I? airin' Parcrttie 7 tine 4lir pumtiptifinn'1 /'nnf-i-ts/'t 1' T7trc+ tV,a fnmlitti I? <ri. r ft- *f a * A 4*- v .1 ^ 7| *W` h ; . 'some will be importedl. ./>r?i, , f,' t .' . .. 1 . ; . r -* !'* v`w^C^IC^^QIN^INe/?EPT|EMpW> 197^ ; V* Si OCC 093716 -{;3J?> r. ; C^ ' 0*^ TTi <- GrFT / The Society f the Plastics Industry. Inc. 355 Lexington Avenue, Nev; >orx Ne.\ > (212) 573-9400 10017 VCM-PVC MANAGEMENT SUMMARY received J'.JIM t '[ ^7r> M. E. ElSIifa^O1** No- 2 ON THE REGULATORY FRONT Requests denied for variances from OSHA standard requiring wearing of respirators by workers exposed to more than 1 ppm of vinyl chloride ... OSHA says three companies -- Air Products, Union Carbide and Borden --failed to meet test showing an unavailability of materials or personnel needed to comply with standards ... FDA now states it is committed to finalizing long-awaited regulatory package for PVC food contact applications to June 30. 1976 ... likelihood of timely pnblication of EPA emission standard for VCM in Federal Register diminishing due to volume of comments filed and Agency's heavy workload. BRIEFS: FDA discussing cosmetics regulation that may include banning of baby oil in PVC containers ... proposed regulation nowhere near promulgation and highly likely will not be promulgated until decision reached on food additive status of PVC ... EPA Administrator Train announced new risk/benefit guidelines for future actions on chemicals, pesticides etc ... provides for expanded and independent evaluation of health risks and economic impact before Administrator decides whether or not to take action against chemicals suspected of causing cancer . EPA action noteworthy because it constitutes step forward In properly assessing health risk decisions. ON THE LEGISLATIVE FRONT In California, an SPI legislative team has reported that author of bill re regulation of carcinogenic substances (see Management Summary #1) has agreed to accommodate almost completely PVC industry's demand that nothing be required of industry beyond that now mandated by federal OSHA standard ... Some 20 other states still in legislative session -- no VCM-PVC bills of threatening nature detected. Published by VCM-PVC Steering Committee of VCM-PVC Producers Group of SPI UCC 093717 -2 - in U.S. Congress, House Commerce Committee began mark-up sessions on H, R. 10318, toxic substances control bill approved by subcommittee in October 1975 .., Senate passed similar bill this past March .. .Manpower and Housing Subcommittee of House Government Operations Committee expected to hold three-day hearing in June on worker exposure to toxic substances ... subcommittee Chairman Floyd W. Hicks (D-Wash.) concerned over "shocking examples of workers being poisoned on the job" ... cites specifically asbestos, vinyl chloride, lead and Kepone incidents. On May 13 both Senate and House approved S. 510 that will materially strengthen FDA power over medical devices, particularly life-supporting devices implanted in body (i.e. pacemaker) or used outside body (i.e. kidney dialysis machine) ... this is land-mark legislation which has been pending last ten years and is supposed to cover regulatory gaps existing for 38 years ... could increase FDA regulatory authority over plastic materials used in any of these devices ... Senate floor action on clean air amendments bill begins last week in May or first week in June ... House bill on same issue may come up on floor early in June. ON THE MEDIA FRONT Contact with producer of "CBS Reports" program in the making "Politics of Cancer" elicited comment she is taking a balanced perspective ... no "bad guvs" will be portrayed ... she added "some are gray, however" and industry "not on the hot seat", program now scheduled for July or August to examine process of federal regulation looking at industry and government interaction. Dr. Elizabeth Whelan, author of book, "Panic in the Pantry" interviewed a group of industry representatives .,. Whelan working on sequel in which she'll examine VCM/PVC-FDA situation among other related case histories ... her credentials and book establish she is clear-thinking in pursuit of establishing rational regulation of food and food additives. Ralph Harding's response to editor of the Sierra Club Bulletin finally published in Bulletin's April issue ... as expected, Bulletin used considerable space to respond to SPI and tends to skirt many of points raised by Harding ... no plans to respond to their response to industry's response ... could go on ad infinitum. ON THE TECHNICAL FRONT EPA's report on vinyl chloride in natural water systems -- "Dynamic Behavior of Vinyl Chloride in Aquatic Ecosystems" -- summarized in April 23 Environment Reporter ... makes main point that "unrealistically high levels" of vinyl chloride would have to accumulate in aquatic ecosystems before significant damage to systems could occur. According to April 1 Internal Medicine News, high rates of airway impairment found among 369 current and former employees of PVC polymerization plant in West Virginia ... prevalence of obstructive airway changes higher among workers who smoked cigarettes when duration of exposure to VCM and PVC less than ten years .,. study conducted by Dr, Irving Sellkoff's team at New York's Mount Sinai School of Medicine. UCC 093718 -3 - April 17 British Medical Journal contained paper on syndrome sometimes called \ invl chloride disease" ... titled 'Immunological Mechanisms in the Pathogenesis of Vinvl Chloride Disease", paper reports results of examining 58 patients from a single polymerization plant in Great Britain .., investigations showed presence of circulating immune complexes in id out of 28 patients with the disease, and in a further two out of 30 workers exposed to YCM. April Radiology News Digest carried short summary of paper on the use of liver scans for detection and diagnosis of angiosarcoma among vinyl chloride workers .., full paper appeared in March Radiology. NEWS BRIEFS Final TV and Radio Training Session in June Fourth -- and final -- television and radio training session to be held sometime in June ... will add successful trained people to existing teams or make up new teams for face-to-face briefings with leading media reps in major cities ... training challenging and valuable ... if your company wants to send representative contact Bob Ferrante at Hill and Knowlton (212) 697-5600 .,, future visits planned for Boston, Pittsburgh, Denver, Minneapolis, Salt Lake City and Detroit ... and subsequently San Francisco, Los Angeles, Houston, Dallas, Chicago, New York and Washington ... appearances also planned on major television and radio shows. Q&A Booklet on "PVC and Health" Being Prepared In preparation for all members of VCM-PVC Producers Group is question and answer booklet on PVC and Health, a handy, concise, easy-to-understand document for use by member company marketing and management personnel in answering questions from customers and the general public ... questions based on those most commonly asked. Each member company will be provided with 750 copies ... additional booklets can be ordered for nomln il fee to cover printing and mailing. ACS Symposium on VCM August 29-September 3 American Chemical Society will hold symposium on VCM in conjunction with its annual meeting in San Francisco August 29-September 3 ... Dr. Dan Dixler of Keller & Heckman, SPI legal counsel, co-chairman with Dr. Seymour Gilbert of Rutgers University ... format will be overview of genesis of problem, government activity, and industry's response ... Dr. Dixler looking for speakers, participants etc ... Member companies can contribute ... contact Dr. Dixler (202) 296-2700 if you are interested. *** UCC 093719