Document 74zpNJ2Mex4vZ2913zdQNpgR
May 18, 1992
TO:
Jim Schonaerts cc: R. J. Grahek
M. M. Marshall
E. c. Martinelli/W.F.
C. Mattia G. Higby M. Schulz H. Waltemate
S. Williams
Patient
FROM: Dan Gleghorn
LAPORTE INDUSTRIAL HEALTH AUDIT
l<7 * Enclosed is the final report of the Industrial Health Audit conducted in your facility by Herm Waltemate and myself during the
period of May 4 through 8, 1992.
I would like to thank you for the hospitality afforded us during our visit to your facility.
Your people being prepared and John Sanders and Tim Lancelin's assistance helped me complete the audit in a timely manner.
The Industrial Health Audit was directed toward programs and records as well as a facility inspection.
You are fortunate to have Steve Williams, Tim Lancelin and John Sanders who are eager to put a complete Industrial Health Strategy into place. They have worked very diligently to coordinate the implementation of your program.
During our audit, we pointed out conditions that violated BFGoodrich or OSHA standards or were inconsistent with good health practices.
The facility was rated with 102
"Satisfactory11, 16 "Needs
Attention" and 46 "Does Not Apply" items.
NGC 12258
2-
Items To Be Corrected were developed from the Audit Checklist and
the Inspection Tour notes. Not all Comments on the Inspection Tour
require action by the plant.
These documents can serve as
references as you develop your abatement plan. The report format
is laid out for you to write in your abatement program and indicate
the status as complete, in-oomplete or no action. A progress
report giving the status of the items requiring attention is due 60
days after receipt of the report and on a quarterly basis
thereafter until completion.
A computer disk in Word Perfect format is included for your use in complying with this request.
The report includes the following:
I II III IV
Favorable Observations 1992 Items to be Corrected Industrial Health Program Rating Hearing Conservation Audit Checklist
Dan Gleghorn
deg 05/18/92
AUDITLAP.92
LAPORTE INDUSTRIAL HEALTH AUDIT
May 4-8, 1992
I Favorable Observations
1. As mentioned before you are fortunate to have Steve Williams, Tim Lancelin and John Sanders to develop your Industrial Health strategy,
2. There appears to be very good support for the Industrial Health strategies by both the plant management and employees.
3. John Sanders has developed one of the best medical programs in GVD.
4. You have completed your Job Exposure Surveys and are conducting Personnel Monitoring based on a qualitative assessment of the Surveys.
5. Your Instrument Calibration Programs are very good with outstanding recordkeeping.
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NGC
II 1992 Items To Be Corrected
IH--1992-1
Hazard Labeling
a. The sample cylinders used for quality control by the Laboratory need the labeling upgraded. Proper hazard labeling is a requirement of both OSHA 29 CFR 1910.1200 (f) (5) and the Chemical Hygiene Plan.
b. Storage tanks and vessels must be clearly marked with their contents and should have the NFPA Diamond to advise emergency responders of the hazards they face. A large number of vessels, i.e. the tanks in the EDC Tank Farm, do not have the proper Labeling since they have been painted.
Please advise me of your program to comply with this item.
Response
Status
Complete In-Complete No Action
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NGC 12261
IH--1992--2
over Exposure Follow-up
You are monitoring to determine if exposures to hazardous chemicals exist above the PEL. You have a specific written plan to deal with the over exposures to VCM. You need a written plan or standard practice to deal with over exposures to other chemical or physical agent,i.e. EDO.
Please advise when this item has been completed. Include a copy of your plan of action.
Response
Status
_____ Complete _____ In-Complete _____ No Action
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IH--1992--3
Noise Control
Although you have a Corrective Action Team in place to deal with noise problems in the facility, a serious problem has been created by the removal of fire proofing from process equipment. I have a concern that single device hearing protection, i.e. Ear-Plugs or Muffs alone, can adequately reduce the noise exposure to BFG or OSHA permissible limits. This is especially true if the sound level exceeds 100 dBA. As a minimum 7 dB must be deducted from the manufactures NRR rating, of the hearing protector, to determine its effective NRR (Noise Reduction Rating). A program must be implemented to lower noise levels in your facility including the areas where fire proofing removal has increased the noise levels.
Please submit a time table which indicates when this item will be completed and advise when the item is complete.
Response
Status
Complete In-Complete No Action
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IH--1992--4
USDS The MSDS Book in the Control Room did not have a Chemical List in the VCM Section. Please advise when this item has been corrected.
Response
Status
_____ Complete _____ In-Complete _____ No Action
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NGC 12264
IH--1992--5
Sound Level Meter
I reviewed numerous calibration records for equipment
in your facility and find them some of the best in
GVD.
A review of your monitoring equipment
calibration records, however, indicated a need to have
the Sound Level Meter factory calibrated. IH-101
"Equipment Calibration" requires Factory Calibration
every three years.
Please advise that this item has been completed.
Response
Status
Complete In-Complete No Action
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NGC 12265
IH--1992--6
Job Survey Follow-up
Although you have completed your Job Exposure Surveys a procedure must be implemented to update the survey as new materials are introduced to the plant. This is a requirement of IH-101 "Exposure Inventory".
Please advise when this item has been completed. Include a copy of your plan of action.
Response
Status
_____ Complete _____ In-Complete _____ No Action
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NGC 12266
IXX
6EON VINYL DIVISION SPECIALTY POLYMERS fc CHEMICALS DIVISION
INDUSTRIAL HEALTH AUDIT CHECKLIST
LOCATION LaPorte
DATE 05/04-08/92
S = Satisfactory NA - Needs Attention DNA = Does Not Apply
A. INDUSTRIAL HEALTH PROGRAM ADMINISTRATION
l* industrial Health Coordinator
a. Named b. Knowledgeable c. walk-throughs
S_____ S S_
2 Periodic industrial Health Program Reports
a. Timely b. Content c. Quarterly Reports d. Year-end Report e. Goals for Next Year
S_____ S ____ S ___ S S
3. Medical services
a. Physical Examination b. Medical Equipment Certification/
Calibration c. Professional Training d. Illness and ComplaintInvestigation
S
S ___ S_ S
4. Job Exposure Surveys
a. Complete b. New Exposure Review b. Annual Review andUpdate
S___ NA_ DNA
5. Chemical Hazard Review and Use
a. Committee Established b. MSDS
S_
1. Available 2. Employees Trained in Use
S S
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NGC 12267
IH-2Q1A Revised 08/23/91
6. Reply to Industrial Health Audits
a. Initial b. Final Report
s
7 PEL'S and Fetal Toxicity Written Program
a. Hazard communication b. Acrylonitrile c. Benzene d. Carbon Tetrachloride
.e. Chromium VI
f Chloroform g. Dimethyl Acetamide h. Ethylene Thiourea i. Lead
j* Mercury (Vapors)
.k. Methyl Ethyl Ketone
l Vinyl Chloride m. Ethylene Dichloride n. Perchloroethylene
S DNA DNA DNA DNA DNA DNA DNA DNA DNA
S NA DNA
Medical
Training
Surveillance
DNA
m m DNA DNA S___
___
A
5____ m
m
J2KA-
m
m
urn
A A A
DNA
___
_S___
A
8. Monitoring for OSHA PEL'S and Reproduetive/Devalopmental Toxicity
by Area From (month/year) 1/1/91
to Present
Number of
ftawplag
% Over PEL
% over PEL Without
a. Benzene OSHA PEL 1.0 ppm, BFG PEL 1.0 ppm
Department Number & Name
.1.
2
__5_0___ __4_____
3. _______________________________
4. _____________ _____________
* Written Plan to Address Over Exposures DNA______
b. Chloroform OSHA PEL 2.0 ppm, BFG PEL 2.0 ppm
Department Number & Name
1,
__50
_4______________________0
2. ___________________ ________
3. ____________________________________
* Written Plan to Address Over Exposures
DNA
NGC 12268
IH-201A Revised 08/23/91
Number of
% over
pel
% over PEL without
Protection
c. Ethylene Dichloride OSHA PEL 1.0 ppm (contested)
Department-. Number & Name
.1- 155
2 3. _____________
4. ______________
_9__6___
_____________
______________
_____________1_TL_____
_____________
______________
* Written Plan to Address Over Exposures
d. Perchloroethylene OSHA PEL 25.0 ppmr
Department Number & Name
21.. _--__n__a__ __ ______im__
3. _____________ ________ 4. __________________________
DNA
* Written Plan to Address Over Exposures
m
e. Vinyl Chloride PEL 1 ppm
Department Number & Name
. ______1. _____________
2 3. _____________ 4. _____________
_________
______
______
* Written Plan to Address Over Exposures
MA
f. Carbon Tetrachloride 2 ppm
Department Number & Name
.1.
2
___d_n_a_
3. _____________
4. _____________
__p_m_
________
________
m
* Written Plan to Address Over Exposures
DNA
DBG 04/10/91
ihch.aud/12
IH-201A Revised 08/23/91
9 Monitoring for OSHA Noise PEI*
by Area Prom (month/year) 1/1/91
to Present
Number of
Samples
% Over 50% Without Hearing
Protection
% Over 100%
Hearing Protection Action Level 50% Engineering Control PEL 100%
Department Number & Name
.1.
2
__1_0_5__
3. _____________
4. _____________
___0___
_____________
_____________
________0
______
______
* Written Plan to Address Over exposures
S _ __
B. INDUSTRIAL HEALTH PROCEDURES
1. Respiratory Procedure
a. Written
b. Selected per Hazard
c. Training d. Fit Testing e. Medical Examination
f. Cleaning
g- Storage h. Inspection i. Approvals
j- Usage
Asbestos Handling and Disposal
a. Sources Identified
b. Monitoring
c. Medical Examination d. demolition and Removal e. Protective Clothing f. Written
S S
s_ s s s____ s s____ s s
DNA DNA-- PNA DNA _ DNA DNA
DBG 04/10/91
ihch.aud/13
NGC 12270
IH-20IA Revised 08/23/91
3. industrial Health Exposure Evaluation and Monitoring
a. Strategies
1. OSHA Compliance 2. Exposure Evaluation 3. Special Requests
s__ S
S__
b. Sample Procedures
____
c. Analytical Procedures/Cross Check Program
S
d. Employee Notification,Interview &Documentation S
4. Hearing Conservation and Noise Control
(0se Hearing Conservation Audit Checklist)
Total Satisfactory Total NeedsAttention Total DoesNot Apply
24_ Z 0
5. Radiation
a. Hazards Identified and Labeled b. License Requirements c. Records d. Dosimetry Program e. Periodic Leak Checks f. Radiation Protection Officer
6. Ventilation for Health Hazard Control
a. Periodic Plow or MaintenanceChecks b. Laboratory Hoods
1. Yearly Flow Checked (Every 6 Months) 2. Rating or Flow-Rate Posted
c. Modifications Reviewed d. New Systems Reviewed
7 Leak Detection
a. Written b. Area Monitoring Response c. Leak Repair Control
S S S __ S S
NA _________
S S
S S
S S S_
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NGC 12271
IH-201A Revised 08/23/91
8. I.H. Equipment Calibration
a. Audiodosimeters
1. Daily Field Calibration 2. Laboratory Calibration
b. Sound Level Meters
1. Daily Field Calibration 2. Laboratory Calibration/Three Years
c. Acoustic Field Calibrators Every Three Years d. Radiation Detection Device - Annually e. Area Monitoring Devices f. Personnel Monitoring Pumps
S S
NA NA
NA S S DNA
9 Laboratory safety
a. Chemical Hygiene Plan (in use) b. Chemical Hygiene Officer Named c. Lab Hoods Adequate for Hazard d. Personnel Protective Clothing and Equipment
10. Totals
Satisfactory Needs Attention Does Not Apply
S S S S
102 ______16
46
DEG 04/10/91
ihch,aud/15
NGC 12272
IV.
TH-2Q1A Revised 08/23/91
GEON VINYL DIVISION SPECIALTY POLYMERS & CHEMICALS DIVISION
HEARING CONSERVATION AUDIT CHECKLIST
LOCATION Laorote DATE 05/04-08/92
S - Satisfactory NA - Needs Attention DNA - Does Not Apply
1. All jobs with an eight hour TWA exposure of 85 dBA (50% dose), have been identified.
S
2. Noise hazardous (BFG > 85dBA) areas have been posted.
___2--
3. A formal list is available at the plant
specifically designating hazardous and
non-hazardous noise exposure jobs.
___HA--
4. Records are available showing monitoring results for those jobs that were monitored. NOTES A copy of monitoring result must be entered into the Medical Surveillance System in Bath. The plant must retain its records for at least two years (OSHA)
___S--
5. When employees working on noise hazardous
jobs are monitored, they are informed of
the monitoring results (OSHA).
___S__
6. Engineering and/or maintenance efforts are being directed at reducing noise in
those areas/jobs with an eight hour TWA of 90 dBA or greater (100% dose) (OSHA) . NOTE; Details of this effort must be documented.
HA
7. Hearing protection worn in all noise hazardous areas.
S--
8. Hearing protectors in use are capable of reducing employee noise exposures to below 85 dBA (NOTE; MNRRM or attenuation factor on hearing protector package. Consult with Industrial Health in Cleveland if more information is needed).
8
DEG 04/10/91 ihch.aud/16
NGC 12273
IH-201A Revised 08/23/91
9. Employees are provided a choice of two or more different types/varieties of hearing protection (OSHA).
10.
Personnel working at noise hazardous jobs receive annual training which includes at least the following information (OSHA).
a. The effect of noise on hearing.
b. The purpose of hearing protectors, the advantage and attenuation of various types, and instructions on selection, fitting, use, and care.
c. The purpose of audiometric testing and an explanation of the test procedures.
11.
Care is exercised to insure a proper initial fit and correct use of all hearing protectors (OSHA). NOTE: With inset-type hearing protectors (ear plugs), it is important that the ear canal be clear and free of impacted wax. The ears should be examined for impacted wax before plugs are fitted. If impacted wax is found, it should be removed by a nurse or physician. Any employees complaining of an ear problem should be referred to medical personnel for examination.
12. Audiometric examinations are provided for:
a. All new hires (pre-employment) . b. Transfers to noise hazardous jobs. c. Employees working on noise hazardous
jobs (annually).
NOTE: Details for conducting proper audiometric exams are provided in BFG1s OHP Manual, Section 5.05.
13. Audiograms are permanently retained for each employee.
14.
Employees with audiograms showing a standard threshold shift (STS) are notified of this fact in writing within 21 days (OSHA) . NOTE: Employees showing a STS are to be retested within 30 days.
DEG 04/10/91 ihch.aud/17
IH-201A Revised 08/23/91
5.
Employees exhibiting a STS are refitted with
hearing protection and retrained in its use (OSHA) .
NOTE: Hearing protectors with greater attenuation
may
needed.
16.
Employees showing shifts in their hearing are provided follow-up counseling based on the BFG quarterly Audio Action Report and Section 5.0-5 of the OHP manual.
17.
Cases with a confirmed average 25dB shift from the original baseline in the frequencies 2000, 3000, and 4000 Hz, either ear, are recorded on the OSHA 200 Log.
18. * The audiometer in use satisfies requirements of the ANSI standard 3.6-1969.
19. * An acoustical or biological calibration is performed daily on the audiometer before use. NOTE: Results of these tests must be kept on record for at least one year.
20. * An acoustic check is performed on the audiometer annually, NOTE: Audiometer must meet requirements of ANSI S3.6-1969.
21. * An exhaustive calibration of the audiometer is performed at least every two years by the manufacturer or his approved agent. NOTE: (#18, #19, #20) Results of all checks and calibrations must be kept on record.
22.
A copy of the OSHA noise standard is posted in the workplace or is available to employees.
23. Questionnaire answered by:
Name:
John Sanders
Title: Medical/Safetv Technician
Plants LaPorte
S_ S S S S___ S S___
s
*KninhftrR is, 19, 20, 21 - Where an outside audiometric testing service is employed, it must be established that these requirements are satisfied.
DBG 04/10/91
ihch.aud/18