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* / f/ic* * 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 Bites 1 nC - 4_ 6-- 8- 8b _ 8D -- 9-- 10 -- li 12 -- 14 -- 1$ -- 19 -- 20 -- 21 - 22 -- 23 2k -- 26 - 29 30 " 31 -- 36 -- 38 -- 39 -- ho -- 42 43 -- 43A -- hh -- k9 - 52 -- 59 -- 60 -- 61 -- 62 -- 63 -- 67 -- 68 -- 69 70 -- 79 -- 80 -- 81 -- 82 -- 83 -- 84 -- ^85 86 -- 87 -- 88 -- 89 -- 90 -- 91 -- 92 93 -- 94 -- '96 :t - 97 -- 98 99 - Offices Warehouse Warehouse production styrene ?i 11 * ti ti ft i 1 1 Offices & Lab 11 11 Insulation Offices It Offices fire station steam generation Warehouse & Garage Stores & Receiving Warehouse Warehouse Storage styrene production pipe shop Warehouse Maintenance Warehouse II 1! out Research Complex If It phenolic resin & research lab steam generating plant Warehouse II fork truck repair - charge batteries Warehouse II Offices Warehouse 11 pilot plant ti it Warehouse water tower instrument bldg - electrical substation urea melamine 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 HCHO nothing at present catalyst storage area It It II west gate house warehouse office Saflex - acetate laminate Li asbestos noise areas 100 degree heat stress IR ovens no TJY vinyl chloride monomer Beta Gamma radiation no lead HCHO acrylonitrile urea melamine phenolic allyl alcohol welding $. RSV0025279 (t / 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 9U - If tf If 90 -- ally! alcohol additive . 91 -- HCHO 97 -- warehouse 99 -- Saflex - acetate laminate 79 -- water tower 96 -- west gate house 1*0 - warehouse 39 -- M 38 -- H 59 - ft 1*2 ** out 1*9 -- steam generating plant 60 -- fork truck repair - charge batteries 1*1* ' 61 -- 62 - 67 -- phenolic resin & research lab warehouse 11 If 69 - pilot plant , 70 -- warehouse- 68 -- pilot plant i 1*3 -- 1*3A 22 -- research complex If ft warehouse & garage 23 -- stores & receiving warehouse 38 -- maintenance 52 -- warehouse 20 fire station 19 offices 15 -- offices 11* -- 1-- If . fl 63 -- fl 21* -- warehouse 31 -- It 12 -- insulation 30 - pipe shop 29 -styrene production 10 -- offices & lab 11 -- fl If If 8 - production styrene 9-- SB -- It tt ft It 8B -- ft It 61* warehouse 6-- It 1* -- tt 26 - storage 21 - steam generation 2-- 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 N, / 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 -- - catalyst storage area It It 11 90 -- allyl alcohol additive 91 - ECHO 97 - warehouse , 99 - Saflex - acetate laminate 79 -- water tower 96 -- west gate house 1 Uo -- warehouse 39 38 -- II If 59 - II 1+2 -- out 1*9 - steam generating plant 60 - fork truck repair - charge batteries 14* ' -- 61 -- 62 67 -- 69 - phenolic resin & research lab warehouse II 11 * pilot plant 70 -- warehouse- 68 -- pilot plant 1+3 -- research complex 1+3A - tl It 22 - warehouse & garage 23 -- stores & receiving warehouse 36 -- maintenance 52 -- warehouse 20 -- fire station 19 W offices 15 -- offices 111 -- II 1-- p II 63 It 2l| -- warehouse 31 -- It 12 -- insulation 30 -- pipe shop 29 -styrene production 10 -- offices & lab 11 <- It 11 11 8 -- production styrene 9-- 8h It 11 11 If 83 -- II If 6k -- warehouse 6_ ft U-- fl 26 - storage 21 - steam generation 2-- { asbestos noise areas 100 degree heat stress IE ovens no trv vinyl chloride monomer Beta ++c"i-uiiiici* i'**'. t j "i cxOii no lead ECHO acrylonitrile urea melamine phenolic allyl alcohol welding- . 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 ko 39 38 59 h2 k9 60 hh ' 61 62 - warehouse Saflex - acetate laminate water tower west gate house warehouse out ' ' steam generating plant fork truck repair - charge batteries phenolic resin & research lab warehouse 67 - " 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 1U 1 63 2k - warehouse 31 _ If 12 - insulation 30 - pipe shop 29 -styrene production 10 - offices & lab 11 TM ft n n 8 - production styrene 9 11 ii 8b 8B 64 - warehouse 6 4 26 storage 21 steam generation 2 asbestos noise areas 100 degree heat stress IE ovens no TJV vinyl chloride monomer beta Gamma radiauron no lead ECHO acrylonitrile urea melamine phenolic allyl alcohol welding . PSV0025283 (ZvSk? r Nf\ al^rs 7 p/--/ 9//, 'x J-/) j , a , fa* . .. A 3-^7/... 4^^ &/j%y ./was; r- yi-w-mi' . ....................... ,>.r^ . (^K. fa fafa' cfa/cfa^ ; . 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 ?' 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