Document 6rM89o3Mzw86xLv3YYmmJmX3

*- I received ' John W. WHrrrLcscr COUMSCLLO* AT LA* TO MK AVCHUC NttW TOMA, M. t IOOI7 4 ***-** AUG 19 ISM ft. N. WHEELED i** REGISTERED MAIL JETPHN RECEIPT REQUESTED t** August 16, 1974 $ Hr, Julius Jlmeno Occupational Safety and Health Administration tftiited States Department of Labor 1336 M Street, N.V. Boom 200 Washington, D.C. 20210 Re: Docket - OSH-36 Dear Mr. Jlmeno: I am enclosing three copies of three additional documents which I should like to include In the record of the above docket on vinyl chloride. They are as follows: 1. Paper prepared by Mr. R. N. Wheeler, Jr., ttiion Carbid ' s Vinyl Chloride Monomer - Polyvinyl Chloride Manager, Which sets forth the difficulties which have been found to exist with the control and recovery of vinyl chloride emissions and which`tends to Indicate that proposals made In testimony before you already with respect to the ease of such control may be con siderably over-rated. This in turn Is relevant to your Inquiry on th feasibility of control of vinyl chloride monomer. 2. The second document also prepared under the direction of Mr. Wheeler by Mr. W. R. Mamina which addresses attention to +.h* difficulties of undertaking new engineering products particularly with reference to the time necessary for completion. This is sup ported by recent magazine articles showing the waiting time for quipment delivery which also must be taken Into account on top of the necessary lead time required for undertaking acceptable Improvement projects such as would be required to meet any severely restrictive new vinyl chloride monomer standard. This material, of course, is relevant to the question of engineering feasibility and has not been giv n sufficient emphasis in the testimony submitted to you to date. 3. This document is an alphabetical list of all employees at thl n Carbide's Texas City, Texas plant who have ever been exposed K'Q rkf/e >v l/Cj AsJLsTU-! ^0^1 ucc 036395 Mr. Julias Jlmeno i August 16. 1974 to vinyl chloride monomer. It lists the date of exposure, the length of time of the exposure, and the total as well as the time weighted average exposure to vinyl chloride. It covers a total f 312 Individuals of whom 23 have had over 20 years of exposure, 23 have had 15-20 years of exposure, 34 have had 10-15 years of exposure, 15 have had 5-10 years of exposure end the balance of 182 have had 0-5 years of exposure. The document represents a total of some 2,000 years of exposure at ah average rate of 47.5 parts per million. It is a complete listing of these employees. The significance, of course, for this hearing is that not one of those employees regardless of the length of exposure or the con centration, which Jn some cases average 200 parts per million, have ever had angiosarcoma or any other physical impairment of any sort attributable In any way to exposure to vinyl chloride monomer. The tabulation then supplements the testimony of Dr. Dernehl on behalf of SFI and Mr. R. J. Hughes on behalf of Union Carbide. lhese documents in my Judgment are of great significance In this matter. Indicating as they do the validity of the position urged upon you by Industry generally and Union Carbide in particular that no evidence whatever exists to support adoption of the proposed OSHA standard on vinyl chloride monomer exposure. Biel sures JW:me UL-1- 036396 t 999**9999**99 Mr. JullOfl Jlneno t A. B. Steele D. H. Glenn R. H. Wheeler R# E. Oreebert E. Q. Boll C. U. Dernehl X). E. Deeae R. . Bradley J. B. Leverton R. W. Sealer 0# L. Engle T. W. Carmody R. J. Hughes -3- August 16. 1974 97