Document 71JM6OL3qxkp1byJXr7zdvKQ6
/
R. L. Bourget
SUBJECT
March 1, 1974 STATUS REPORT ON VCM HEALTH ISSUE
reference
to .PVC Personnel
' Since the time we first alerted you of the Goodrich VCM health concern, there have been many developments that will be of inti to you. We shall attempt to cover the key points as.:.w.e know t] in this communication. THE KEY FACTS . 1- B.F. Goodrich has had four known cases of liver cancer (angiosarcoma) in past three years--since the original announcement, two additional cases have "been identified for a total of six--all at their Louisville, Kentucky plant. The estimated B.F. Goodrich work force at Kentucky is 420 people. 2. In a worldwide search since the announcement, two addi tional cases have been reported--both in men who died of other causes (heart attack/auto accident) who previously worked with VCM. The estimated U.S. PVC work force is about 6500 people. 3. ^National Institute of Occupational Safety and Health
(NIOSH) and the Kentucky Board of Public Health have visited the Goodrich facility--preliminary conclusion is that VCM is highly suspect but not definite cause of disease. Over 50 other chemicals used at B. FdeJiC'uk -v*
/
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PSV0025276
A Professor Maltoni from Cologne, Italy, has presented data from experiments conducte d using rats exposed to VCM. He has shown that VCM can cause cancer in rats at high exposures. He reported nothing at 50 ppm exposure or less. Conclusion must be drawn from this w ork that VCM is highly suspect.
NIOSH has initiated a tot al program for investigation of this disease to include: A. 1. Government sponso red medical study.
2. Determination.of extend and use of VCM and PVC. 3. Study on Vinyl U. S. General Population death
causes.
B. 1
Potential occupational exposures to VCM and 50-60 other B.F. Goodrich chemicals. t
C 1. llse of PVC in consumer products. 2. Coordination with National Cancer Institute.
D 1. National surveillance program on angiosarcoma.
As part of this program they will visit several plants to obtain
information. All of this information, plus that obtained in recen
hearings from Industry, Public Health sectors and Labor groups^
will be used to assure satisfactory PVC worker protection. Three
areas for emphasis are:
(1)
Environmental Testing and Personnel monitoring for VCM exposure.'
(2) Work Practices which minimize VCM exposure
(3) Medical testing and evaluation of exposed
workers.
RSV0025277
6. We do not know all the detail of the B.F. Goodrich,
Louisville plant PVC process compared to our own or others
in industry. However, Monsanto has two significant process
advantages for VCM control over most every other plant in the
industry--flare stack system for vent control and THF system
for reactor cleaning.
7. The Occupational Safety and Health Administration (OSHA) has
ruled that regulations for VCM will be developed via a regular
rule making investigation rather than issue an emergency regula
tion. Nevertheless, recommended regulations tightening control
over VCM exposure, analytical surveillance and medical testing
will be immediately implemented by Monsanto.
will be discussed separately.
*
These regulations
In summary, no one knows for certain whether VCM is the specific cause of this problem. Industry, government and private health interest groups are hard at work to answer these difficult question The collective evidence available, however, suggests that VCM must regarded as a definite suspect, particularly at high concentrations for extended periods of time.
Monsanto, as a result intends to cooperate fully in whatever action
are required to insure that our own operation remains a safe and
healthy place to work. We will need your cooperation as we move to
implement some of the required changes in our work practices and
operations to give maximum protection. As information is developed
the changes may be modified--either relaxed or tightened, as the
situation"may warrant. /m
R. L. Bourget
RSV0025278
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Offices
Warehouse Warehouse production styrene
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pump house main gate house and co. store PTC paste resin emulsion process warehousing formerly PYC repair lab styrene operations warehouse PYC suspension warehouse allyl alcohol additive
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west gate house warehouse office Saflex - acetate laminate
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RSV0025279
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Bldgs
82 pump house
87 p- warehouse
81* -- PVC paste resin emulsion process 86 -- styrene operations
81 -- urea melamine
80 -- instrument bldg - electrical substation
85 -- warehousing formerly PVC repair lab 88 - PYC suspension
92 - nothing at present 89 -- warehouse 98 -- office
83 -- main gate house and co. store
93 -- catalyst storage area
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91 -- HCHO 97 -- warehouse
99 -- Saflex - acetate laminate 79 -- water tower 96 -- west gate house
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phenolic resin & research lab warehouse
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69 - pilot plant
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70 -- warehouse-
68 -- pilot plant
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warehouse & garage
23 -- stores & receiving warehouse 38 -- maintenance
52 -- warehouse
20 fire station
19 offices
15 -- offices
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asbestos
noise areas 100 degree heat stress
XR ovens no UV
vinyl chloride ffi.Gnor.ier Beta Gamma radiation no lead
ECHO acrylonitrile urea melamine phenolic sllyl alcohol welding
RSV0025280
RSV0025281
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Bldgs
82 - pump house
87 - warehouse
Sh - PVC paste resin emulsion process 86 - styrene operations
81 -- urea melamine
80 - instrument bldg - electrical substation
85 - warehousing formerly PVC repair lab
88 - PVC suspension
92 - nothing at present
89 -- warehouse
98 -- office
83 - main gate house and co. store
93
9k
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90 -- allyl alcohol additive
91 - ECHO
97 - warehouse
,
99 - Saflex - acetate laminate
79 -- water tower 96 -- west gate house
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39 38 --
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59 -
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1+2 -- out
1*9 - steam generating plant 60 - fork truck repair - charge batteries
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pilot plant
70 -- warehouse-
68 -- pilot plant
1+3 -- research complex
1+3A -
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22 - warehouse & garage
23 -- stores & receiving warehouse
36 -- maintenance
52 -- warehouse
20 -- fire station
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RSV0025282
bldgs
82 pump house
87 warehouse
Sk PVC paste resin emulsion process 86 styrene operations
81 urea melamine
80 instrument bldg - electrical substation
85 warehousing formerly PVC repair lab
88 PVC suspension
92 nothing at present
.
89 warehouse
98 office
83 main gate house and co. store
93 catalyst storage area
9k It If ft
90 allyl alcohol additive .
91 ECHO
97 99 79 96
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warehouse Saflex - acetate laminate water tower west gate house warehouse
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steam generating plant
fork truck repair - charge batteries
phenolic resin & research lab
warehouse
67 -
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69 - pilot plant
70 - warehouse-
68 - pilot plant
43 43A 22 -
23 36
52 20
research complex
warehpuse & garage stores & receiving warehouse maintenance warehouse fire station
19 offices
15 offices
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63
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12 - insulation
30 - pipe shop
29 -styrene production
10 - offices & lab
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8 - production styrene 9 11 ii
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64 - warehouse
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21 steam generation
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asbestos noise areas 100 degree heat stress
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PSV0025283
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RRV0025784
Monsanto
MONSANTO POLYMERS & PETROCHEMICALS CO. 730 Worcester Street Indian Orchard, Massachusetts 01051 Phone: (413) 788-6911
April 22, 1975
Mr. Rudolph Bayerle, Director
Occupational Safety & Health Administration
Room 501
436 Dwight Street
Springfield, Massachusetts
01103
SUBJECT: Regulated Areas. Regulation 1910.93q VCM
Dear Mr. Bayerle:
Per the requirements set forth in Paragraph n of OSHA regulation 1910.93q, Exposure to Vinyl Chloride, please be informed that Monsanto Company has established two regulated areas in accordance with Federal requirements. Both of these regulated areas are at Monsanto's Springfield plant located at 730 Worcester Street, Indian Orchard, Massachusetts and are related to our polyvinyl chloride emulsion resins manufacturing operation. During normal operations there are approximately ten employees, including maintenance personnel, per eight hour period in the man ufacturing area (regulated area No. 1) and approximately six employees in the warehouse area (regulated area No. 2). The manufacturing plant is operated continuously, seven days per week, and the warehouse operation is conducted on a five day, eight hour per day basis.
/th
Plant Manager Monsanto Company
uni* rtf Mnn t snth rnmnflnW
Monsanto
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MONSANTO -POLYMERS & PETROCHEMICALS CO. 730 Worcester Street Indian Orchard, Massachusetts 01051 Phone: (413) 788-6911
April 22, 1975
`ir t 0i>.k l>-** AKir"
Mr. Rudolph Bayerle, Director
Occupational Safety & Health Administration A.M
Room 501
436 Dwight Street
Springfield, Massachusetts
01103
A
SUBJECT: Regulated Areas. Regulation 1910.93q VCM
Dear Mr. Bayerle:
Per the requirements set forth in Paragraph n of OSHA regulation 1910.93q, Exposure to Vinyl Chloride, please be informed that Monsanto Company has established two regulated areas in accordance with Federal requirements. Both of these regulated areas are at Monsanto's Springfield plant located at 730 Worcester Street, Indian Orchard, Massachusetts and are related to our polyvinyl chloride emulsion resins manufacturing operation. During normal operations there are approximately ten employees, including maintenance personnel, per eight hour period in the man ufacturing area (regulated area No. 1) and approximately six employees in the warehouse area (regulated area No. 2). The manufacturing plant is operated continuously, seven days per week, and the warehouse operation is conducted on a five day, eight hour per day basis.
G. M. Ellsworth Plant Manager Monsanto Company
unit of Monsanto Company
Enclc .re
DEVIATION
DETECTED BY
levels high at seed ainer when dumping seed ch (1/2 days)
G. C.
levels high in east er kettle floor trench n dumping kettle sh water
G. C.
CORRECTiIVE 'ACTION
Extend kettle spot exhaust fan system to.remove vapors
Cover trench
'
STATUS
In progressexpected' _compietrtTfri^724/2 7 / 7 5
TPOA/B
Done
escapes from latex k manholes when covers
open, especially durtransfer operations
L
%
G C. ,
1. Close covers, upgrade
Century Meter'
gaskets and dogs, provide
sight glasses, lights and
water washers to allow -
inspection of tank contents
without opening manholes
1. Done
2. Improve flame arrester maintenance.
2. Continuous
3. Provide for mandatory respirator wear when
entering or cleaning tanks
3. PVC work rules in draft stage
I escapes from sewer inch in RVCM building ;n compressor seal :er is being dumped
G C , Century Meter
1, Cover trench 2. Evacuate covered trench by
tieing into existing building exhaust fan
1. Done 2. In progress -
expected completion W/E .4/27/75
\erous minute leaks relop in VCM valve ;ms, kettle gaskets 1 VCM pipeline inge gaskets
Century Meter
Tighten, replace, etc.
Continuous