Document 6w63kjV9argdYwwgmZbKeq85g

Interoffice Communication Leon Vernon To J. F. Alix Frm Flynt Kennedy^" C. H. Klunick Date June 18, 1974 Subject Occupational Safety & Health Reporter, Volume 4, Number 2 CHEMICALS RESEAR^C JUN2JVg4 Attached for your information are excerpts from the'Occupational Safety and Health Reporter',11 Volume 4, Number 2, June 13, 1974. You will note the proposed vinyl chloride standard proposed by OSHA generated substantial critical comment from industry. The Reporter also in a later article mentions the Manufacturing Chemists Association has announced four new projects to research the carcinogenicity of vinyl chloride as it relates to humans. C. H. Klunick rt CURRENT REPORT Legislation HOUSE SCHEDULES OSHA OVERSIGHT HEARINGS; 80 BILLS ARE PENDING The House Select Subcommittee on Labor scheduled oversight hearings on the Occupational Safety and Health Act on June 25*26. Over 80 bills are pending in the House and Senate to amend the Occupational Safety and Health Act. A chart of the bills appears in the Full Text section of this report. Lead witness for the scheduled hearings tills month will be Richard B. Berman, labor law director, U.S. Chamber of Commerce. Other witnesses include Leonard Dodson, safety committee chairman, Associated General Contrac tors of America; Gyde Roberts, National Association of Manufacturers; Congressman David Towell (R-Nev); Robert H. Doyle, National Society of Professional En gineers; Robert M. Gyne, American Cyanamid Company; and William E. McCormick, American Industrial Hygiene Association. A number of the bills pending before the House deal with differentiating between light and heavy construction standards and others would provide for an on-site consulta tion. The latter topic is given the best chance of serious attention by the House. In the Senate, Senator Peter H. Dominick's (R-Colo) bill, S 1147, which he attached as an amendment to the non-profit hospital bill and which was subsequently de feated (Current Report, May 9, p. 1539), would have significantly changed the law. The Senate Labor and Public Welfare Committee is expected to hold hearings on OSHA sometime this summer. Health Hazards MAJORITY OF COMMENTS PROTEST PROPOSED VINYL CHLORIDE STANDARD A majority of comments on the standard for vinyl chloride proposed by the Occupational Safety and Health Administration (Current Report, May 9, p. 1539) were in opposition, stating that if the standard were adopted numerous businesses would be forced to shut down. Deadline for comments was June 10 on the OSHA proposal which calls for "no detectable level" of expo sure. A public hearing will be held June 25 in Washing ton, D.C. (Current Report, May 30, p. 1672). G. Frederick Hanna, regulatory agency liaison, BorgWarner Chemicals, Washington, W. Va.. said in order to evaluate the impact of the proposal, it is essential that details of the approved monitoring, air sampling, and analytical procedures be made available to all involved. If there are preferred techniques and specific items of equipment required to assure the necessary accuracy and sensitivity, these should be identified, he added. Allan J. Topol, Covington and Burling, Washington, D.C., representing Tenneco Chemicals, Inc.. Saddle Brook, N.J., objected to the proposal stating that it lacks ade quate scientific support, is not justified in view of the Jong safety record of the industry, cannot be feasibly achieved in view of the current technological capability, 5*5 * C3 csj 3 rs> and will, if put into effect, require either complet^' shutdown or drastic reduction of production in the vinyb' chloride industry with attendant severe consequences iij^ numerous other sectors of the economy. p-a PVC Production H. M. Walker, Dickinson, Tex., said polyvinyl chloride (PVC) is probably the most important industrial polymer and the least replaceable. The automobile industry and the wire and cable industry could scarcely survive without PVC, he said. The entire concept of dosage was forgotten in the proposal, he said. "The interaction of living matter with foreign materials is controlled always by the param eters of concentration and duration." he added. Walker said he is not aware of any reports where cancer was produced by a single short-duration applica tion of a carcinogenic material. In general, repeated applications are necessary until a significant threshold has been exceeded. "There is no reason to believe that vinyl chloride is any different in this respect," Walker said. Referring to personal experimentation, Walker said evi dence indicated to him that the "level of susceptibility in humans is of the order of seven to ten parts per million-hours dosage. This is the data to use in standards setting," he said. Instrumentation Donald H. Strodel, director, engineering, Environmental Systems Development Corporation, Charleston, S.C.. urged that instrument experts be consulted as to what can be reliably expected in the way of detectable levels of measurement. Control measures could then be stated in terms of measurement by certain instruments or their equivalents, he noted. Edward J. Malek, executive vice president, Joanna Western Mills Co., Chicago, 111., said the investigations to date by no means support the National Institute for Occupational Safety and Health recommendations calling for "no detectable level," of vinyl chloride as determined by a sampling and analytical method capable of detecting concentrations of one ppm plus or minus 50 percent. Emory G. Cook, president, Cook Laboratories, Nor walk, Conn., said 1910.93 (q) (a) (1) is in conflict with 1910.93 (q) (c) (4) in that the term "capable" is not defined regarding meaning and intent. Cook pointed out that PVC in powder form is capable always of releasing detectable levels. He said also that 1910.93 (q) (b) (2) does not ade quately define PVC. that 1910.93 (q) (b) (4) does not adequately define "contaminated," and 1910.93 (q) (b) (6) does not adequately define "detectable level." Possible Shutdowns Many manufacturers and processors said the proposed standard would put them or their suppliers out of busi ness. Among them were; Jo-Gal Shoe, Inc., Lawrence, Mass; Sportsmen's Hastics, Inc., Leominster. Mass.; Montrose Products Co., Auburn, Mass.; Spherex, Inc., Seabrook, N.H.; Multicolor Co., Hatfield, Mass,v a manu facturer of vinyl wall covering; American Universal, Inc., New York, N.Y., a manufacturer of vinyl tablecloths and accessories; Hubbard Apiaries, Onsted, Mich., a honey packager; Extrudyne, Inc., Amityville, N.Y.; J. F. 1Q74 hy The Bureau of Nationol Affairs, Inc. Midobile a Tool rown and nets, and pipe, hers, : his for i, as nrihe 'trie >ws 0) a red ictddel >il, rn- dy ce in d. ill n d it s i- .1 OC. ATIONAL SAFETY & HEALTH REPORTtn OSHA on February 26 (Current Report, February 28, p. 1225). The OSHA proposal appears in the Full Text of this report. Comments are invited until August 9. Health Hazards MCA ANNOUNCES FOUR NEW RESEARCH PROJECTS INTO VINYL CHLORIOE EFFECT Four new projects to research the carcinogenicity of vinyl chloride as it relates to humans were announced by the Manufacturing Chemists Association on June 6. The studies will be funded by producers involved in synthesis and polymerization of vinyl chloride. The proj ects were approved unanimously by the NAM's board of directors during its annual meeting in White Sulphur Springs, W.Va. The research program includes the following: (1) A study of animal metabolism. (2) A study of teratogenesis (animal fetus). (3) Animal chronic inhalation studies at concentrations below 50 parts per million, in an effort to identify a "no-effects" level. (4) An acute inhalation experiment in which animals will be subjected to a massive exposure simulating condi tions which might be experienced by a community ex posed to a tank car rupture in a transportation accident. The animals would be observed over their lifespan. The funding companies and MCA consider it essential that the program be expanded to determine the condi tions necessary to assure the safety of workers involved in the manufacture and use of the products and of the plant neighborhoods in which they are made. The scientific information developed from the research program will be disclosed publicly without restriction, MCA said. Further, as determined appropriate to the advancement of the program, technical reports will be developed and made publicly available on work practices, industrial hygiene monitoring and analysis, and the medi cal surveillance of exposed workers. Two of the research projects will be conducted by The Dow Chemical Company. The other projects will be conducted by Industrial BIO-TEST Laboratories, Inc. BIO-TEST has been conducting'vinyl chloride animal exposure studies, under contract to MCA for administra tion, since February I, 1973- Results of the study have been announced on a continuing basis (Current Report, April 25, p. 1478). Results of another study, documenting the health ex perience of present and former employees who have worked with vinyl chloride, were released on May 7 of this year (Current Report. May 16, p. 1589). TabershawCooper Associates, Inc., conducted the study. All findings have been reported immediately to govern ment agencies concerned with the vinyl chloride problem, MCA said. This practice will be followed in respect to the new studies. MCA estimated the four projects would cost a mini mum of $400,000 to $500,000. Because of the fluid status of scientific knowledge and reeulatorv climate in Ith Reporter J ; -I * 5*5 C3 c CURRENT REPORT 2 --.-- ---------- ---------------------------------- - - -eg;-------- respect to vinyl chloride, an upw^d n estimate might be necessary to acGBmo< protocols, MCA said. V-*- Enforcement SCRAP METAL FIRM GETS $1,000 RECORDKEEPING PENALTY FROM C A judge's order became final order ol Safety and Health Review Commission penalty for violation of a recordkee under the Occupational Safety and Healt Betten Processing Corporation, Green to maintain monthly, written, dated, a tion records and reports for its electri cranes. Originally the Occupational Safety am tration cited the firm and the employer penalties. A follow-up inspection was tion of failure to abate was. issued. The fi $1,500 proposed additional penalty. At an OSAHRC hearing, company re; they requested but were refused advice fr as to how to abate the situation. The j the firm had not started to keep the untO after the reinspection. In affirming failure to abate, the judge noted OSHA to provide forms nor to recommend n recordkeeping at issue. He also found that this case did have a direct relationship t< A $1,000 penalty was deemed appropria who found the violation "moderately grav The judge's decision became the fin.i commission on May 30 when no comr directed its review. Recordkeeping WESTERN ELECTRIC RECEIVES SECON EXCEPTION FROM RECORDKEEPING R The second exception from the recordk ments under the Occupational Safety and . granted to the Western Electric Company of Labor Statistics. The exception was the second granted the requirements went into effect on Jul\ exception will enable Western Electric to k< job injury and illness records in a manner that provided in the regulations. The Western Electric recordkeeping exD ply only to field installation activities am activities such as headquarters, manufacturi It will allow Western Electric to maintain re installation activities in district offices rathe establishment. In order to supply information to comp and others who have a right of access to i the records, personnel must be available c Copyright