Document 6bO5mxjyg4ve8BBaJew3aX679

UNinOYAL CHEMICAL Division ol U N1 ROYAL, Inc. Naunetuck,Connecticut 06770 203-729-5241 March 21 , 1974 URL 07792 The Honorable John H. Stender Assistant Secretary of Labor U. S. Department of Labor Washington, D. C. 20210 Subject : RECOMMENDED OCCUFA i IONAL HEALTH STANDARD FOR THE MANUFACTURE OF SYNTHETIC POLYMER FROM VJNYL CHLORIDE - MARCH 11, 1974 ____ My dear Mr. Stender: Once again i feel compelled to write to you with regard to an action which we under stand OSHA may soon promulgate based upon a NIOSH recommended exposure level which we believe to be unwarranted. In the last instance, relative to the suspected carcinogen list, NIOSH's recommenda tions involved the untenable guideline of zero exposure. However, your Department did ultimately issue an order establishing reasonable levels, which, while they did create some new costs and problems for us, we felt were proper and justified. I hope that this precedent of reasonableness will be applied to this newly discovered problem associated with vinyl chloride. If the standards are adopted as recommended by NIOSH, there would be no question that we would have to shut down our vinyl chloride plant at Geismar, Louisiana and our polyvinyl chloride resin plant in Painesvilie, Ohio, i am fairly certain that the entire industry wouid be similarly affected. In our own instance we would have to lay off about 550 employees and about 1700 in other Divisions of Uniroyal which are dependent upon polyvinyl chloride. Approximately 100 customers employing many thousands would likewise be shut down. Considering that we produce only about 3% of the domestic consumption of polyvinyl chloride, it is easy to visualize the concurrent effect upon the entire industry and consequent Linen-.hoyment and loss of revenue. jtt.To the best of our knowledge (we ourselves have had no-known or suspected cases of H angiosarcoma in 25 years of operation) the several occurrences have been related j to lengthy exposures at high concentrations. The only comprehensive animal data released to date ("Maltoni Report,f - OSHA Hearing - 2/15/74) showed evidence of | toxicity at 250 ppm and higher, but no effect at 50 ppm. .p . 2 The >mbined toxicological evidence suggests no need to set a "less than detectable level" for vinyl chloride in the workplace. Some fixed guideline limit is desirable to assure reasonably safe working conditions. A level of 50 ppm (time-weighted average) appears to be both reasonable and attainable. In addition, all appropriate engineering and design changes should be encouraged to reduce all vinyl chloride exposure to the minimal practical level in all PVC manufacturing facilities. With such steps we believe that our employees will be properly protected and with minimum economic disruption in a major industry. Again, I would respectfully urge you to insist upon a really objective analysis of the evidence before accepting the NIOSH recommendation. Sincere! y, URL 07793 bcc: GRV DS AJF: LJH GAA CDMc MJK BRL DD JDR, M.D. WDH RJD