Document 8295w20erz950ZJQKJXD8ewre
1 IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A7001
Page 2
INTRODUCTION
The following programs are included in your current Occupational Health Program. The programs are scheduled to be reviewed annually and updated on a two year basis.
Industrial Hygiene Monitoring Program Hearing Conservation Asbestos Ventilation Ergonomics Heat Stress Medical Surveillance Hazard Communication Industrial Hygiene Education Program Respiratory Protection Protective Equipment Department Activities Roster and Job Descriptions (updated on a yearly basis) Chemical and Physical Agent Inventory (updated on a yearly basis)
These programs should be placed behind the appropriate tab in the Department Industrial Hygiene Manual.
C O N F ID E N T IA L
DOW CONFIDENTIAL
3fCio3O CJ1 00o00o
IHS File #A70-3926-91
<
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA. A7001
Page 3
OCCUPATIONAL HEALTH GOALS AND PLANS 1991-93
Industrial Hygiene Monitoring: Comprehensive Chemical (8-hr TWA & Excursion) Noise (Area & Personal)
Hearing Conservation Training (every 2 years):
Asbestos Awareness Training:
Ventilation: Ventilation Survey Manometer Check
Ergonomics: Initial Training Evaluation of Manual Lifting Activities
Heat Stress Training:
Hazard Communication: Review written Hazcom program Review Industrial Hygiene Manual/Protocol Update CPAI Review MSDS's compared to CPAI Health hazards training (annually) New chemicals training
Respiratory Protection: ' Fit Testing for SCBA, airline, half face air purifying Inspections- Mouthbit, half face air purifying SCBA, airline
Training-
Mouthbit SCBA, airline, half face air purifying
Protective Equipment Training (every 2 years)
DATE LAST COMPLETED
DATE DUE
1989 1991
1991
----
1992/93 1994
1993
1992
1989 quarterly
1992
V* --
--
1992 1992
1992
1991 1991 1991 1991 1 991 as needed
1993 1993 1992/93 1992/93 1992/93
1991
1993
before each use and annually
before each use, monthly, and
annually by fire department
1991
1993
1991
1 992/93
-..._
1992
C O N F ID E N T IA L
DOW CONFIDENTIAL
3eD
03
OU)i
CD
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 1
MONITORING PROGRAM
1 . RATIONALE
Personnel monitoring was conducted during 1988-1989 to evaluate employee exposures to ethylene dichloride (EDC), methylene chloride, 1,1,1,2-tetrachloroethane, 1,1,2,2-tetrachloroethane, 1,1,2-trichloroethane, vinyl chloride, vinylidene chloride, 1,1-dichloroethane, and ethyl chloride. Both 8-hour time-weighted average (TWA) and short-term exposures were evaluated. Average exposures (8-hour TWA) for each monitored job classification were significantly less than the acceptable guidelines for each respective chemical with the exception of ethylene dichloride. Monitoring in 1988 and 1989 indicated that average 8 hour TWA exposures for Control C Operators exceeded the OSHAPELforEDCofl ppm.
Closed loop process sampling was installed in 1991 at the EDC plant. Followup 8-hour TWA and short-term personnel monitoring will be conducted as part of the 1991-93 Occupational Health Program to evaluate the effectiveness of the controls in reducing exposures to EDC.
Additional 8-hour TWA and short-term monitoring will also be conducted during the 1992 plant shut-down. The monitoring will be conducted to evaluate exposures to EDC during line clearing activities.
Wipe testing was conducted in 1991 to evaluate hexachlorobenzene (HCB) levels in selected office and process areas (IHS File A70-3688). Areas identified with higher levels of HCB were cleaned and follow-up monitoring was conducted. HCB wipe testing will be conducted following the 1992 shut-down to insure the HCB remains at acceptable levels.
2. SAMPLING STRATEGY
A. 8-Hour TWA Chemical Monitoring
Job glassification
Number of ~ employees
Chemical
Number of Samples
Control C Operator Sr. I&E Technician
3 2
H3C BDC
6 4
B. Job Task Monitoring
Job Task
Chemical
Number of Samples
Process Sampling Line clearing
BXJ BX
3 3
Hexachlorobenzene wipe testing will be performed following the 1992 shut-down in areas to be selected at the time of the shut-down.
DOW CONFIDENTIAL
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA. A-7001
Page 2
MONITORING PROGRAM (CONT.)
3. SAMPLING METHODS
Sampling for ethylene dichloride will be conducted using 1 gram charcoal tubes and air sampling pumps. Pumps will be calibrated both before and after use at 50 cc/min for 8-hour TWA samples and-200 cc/min for excursion samples (as outlined in DLI-IHM-81-3). Analysis will be performed by the Industrial Hygiene Laboratory.
Wipe testing for HCB will be conducted with Whatman #2 filter paper, 5.5 cm diameter.
Approximately 100 cm2 of surface area will be wiped in a cross-hatched format with as much pressure as can be applied without tearing the paper. The filter will be placed In a clean labeled glass vial and sealed immediately after sampling. Gloves will be worn while sampling and changed frequently between samples to avoid cross contamination. Filters will be analyzed by the Industrial Hygiene Laboratory.
4. QUALITY CONTROL AND EQUIPMENT
Routine quality control procedures shall be an integral part of the sampling and analysis procedures and functions. These shall include:
a Routinely introduced sampling of blanks and spikes (known content) along with other samples for analysis
b. Routine checking, calibrating, and maintaining in good working order all equipment and instruments. Air sampling pumps will be calibrated both before and after use.
c Routine checking of procedures and results. d. Participation in Dow's Analytical Proficiency Testing (APT) Program.
5. EVALUATION CRITERIA
Exposure
MaterialGuideline
Ethylene Dichloride (EDC)
1 ppm
Excursion
____________ GuideSource*
2 ppm
OSHA-PEL
* OSHA-PEL = Occupational Safety and Health Administration Permissible Exposure Level
C O N F ID E N T IA L
r & S I53839
DOW CONFIDENTIAL
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 3
REVIEW OF PAST MONITORING DATA A. CHEMICAL REPORTS:
TABLE I SUMMARY QF 8-HOUR TIME WEIGHTED AVERAGE EXPOSURES, 1088-90
JOB CLASS
1088:1 Control C Operator
# OF SAMPLES
EDC
CONCENTRATION (PPM)4'5
MECL2 1112 1122
112
VI
5
3.6 0.03 0.01 <0.01 0.01
--
V2
--
1089:2 Control A Operator
Control C Operator
1990 Shutdown:3 Control C Operator
Control A Operator/SRO
Foreman
Prod. Mtc. Foreman
Process Engineer
6 6
3 1 2 1 1
0.18 1.3
4.2 3.8 3.9 1.3 0.24
.... 0.01 .... -- -- 0.01 --
0.03 0.03
-- < 0.02 < 0.02 <0.03 -- < 0.02 < 0.02 < 0.03 -- < 0.02 < 0.02 < 0.03 -- < 0.02 < 0.02 < 0.03 -- < 0.02 <0.02 < 0.03
**-- -- .... -- --
0.05 0.11
---- -- .... -- --
EXPOSURE GUIDELINE {8 HOUR TWA)
1 SO NE 0.1, S 10, S 1
1
1- Reference: Sorrells. M.J.. 1988 Evaluation of Chemical Exposures to Ethvlene Dlchloride: Methylene Chloride:
1.1.2-Trichloroethane: 1.1.1.2-Tetrachloroethane: and 1.1.2.2-Tetrachloroethane at EDC/NPA. A-7001. IHS File A70-3212C 2- Reference: Sorrells, M.J., 1989 Evaluation of Potential Personal Exposures to Ethvl Chloride: Fthvlene Dlchloride:
1.1-Dlchloroethane: 1.1.2.2-Tetrachloroethane: Vinyl Chloride: .and Vtnvlidene Chloride at Ethylene Dichloride/North Process Area. A-7001. IHS File A70-3390C-89. 3. Reference: Blue, M.A. Evaluation of Employee Exposures to Chemicals During Plant Shut-down at EDC/NPA. A-7000. 1990. IHS File A70-3581-89C.
4- EDC = ethylene dichloride: MECL2 = methylene dichloride; 1112 = 1,1,1,2-tetrachloroethane; 1122 = 1.1.2.2-tetrachloroethane; 1,1,2 = 1,1,2-trichloroethane; VI = vinyl chloride; V2 = vinylidene chloride.
5. Ethyl chloride and 1,1-dichloroethane were also evaluated however all results were less than 10% of their respective IHGTs.
DOW CONFIDENTIAL
JO
CO
Cw00Jl
o
TVT TW'TfTTIM fO
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 4
REVIEW OF PAST MONITORING (CONT.)
Short-term personal monitoring was conducted in February, 1990 to evaluate employee exposures to ethylene dichloride during process sampling. The monitoring was conducted after one of the sampling points was modified to determine if additional controls were warranted. Three samples were collected ranging from 58 ppm to 237 ppm. Exposures were potential as respiratory protection was used during the survey.
Hexachlorobenzene (HCB) wipe testing was conducted in October, 1990 in select process and nonprocess areas of the EDC plant to determine the need for personal protective equipment or controls (IHS File A70-3688). Areas of the plant identified with higher levels of HCB included pump P-200A, P-200B and the lab hood. These areas were cleaned and follow-up monitoring was conducted in May, 1991. HCB levels were determined to be within acceptable levels for process areas.
DOW CONFIDENTIAL
33 P
cn
C0J31
CD -P*
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA. A-7001
Page 5
B. NOISE REPORTS:
REVIEW OF PAST MONITORING (CONT.)
TABLE 3 SUMMARY OF 8-HOUR TWA NOISE EXPOSURES, 19911
JOB CLASS/ JOB CODE
# OF SAMPES
% OF OSHA ALLOWABLE
RANGE
AVE.
Control C Operator/ 16026790
Sr. 1 & E Technician/ 12704034
Utility Man/Contractor 18113140C
4 16 - 25 20 4 16 - 48 26 6 16 - 37 29
OSHA PEL OSHA Action Level
100 50
1- Reference: Blue, M.A. , Personal and Area Noise Levels al EDC/NPA.. A-7001. 1991-92. IHS File A70-3581-89N.
C O N F ID E N T IA L
DOW CONFIDENTIAL
3pJa
C/3
<0J3\ 04IS0O*
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 1
HEARING CONSERVATION PROGRAM
1 . JOB CLASSIFICATIONS IN A HEARING CONSERVATION PROGRAM
The date of the last noise survey was May, 1991 - January, 1992. The survey included both area noise levels and personal job exposure evaluations. Personal noise dosimetry data for the monitored job classifications indicated that all average noise exposures were below 50% of the OSHA-PEL Therefore, participation of employees at EDC/NPA in the Hearing Conservation Program is not required.
2. TRAINING
Training is recommended every 2 years.
3 . HEARING PROTECTION AREAS
The entire process area is designated as a hearing protection area.
Temporary jobs that have equipment with noise levels at or above 90 dBA require temporary signs and mandatory use of hearing protection any time the equipment is in operation. This includes such areas as sandblasting, hydroblasting, use of portable air compressors and hand tools.
4 . HEARING PROTECTION TYPES
Hearing protection devices utilized at this department need to have a NRR rating over 19 dBA. Some of the devices available in the plant are:
DEVICE
E-A-R. foam plugs Bilsom Universal Ear Muffs UF-1 Bilsom Viking Ear Muffs #2318 Willson Sound Ban # 20 E-A-R Ultrafit with cord
NOISE REDUCTION RATING <NRR>
29 dB 23-25 dB 28 19-22 dB 27 dB
Other devices are available through plant supervision or the Occupational Health Department.
5 . NOISE ABATEMENT PLAN
There are no noise control plans at this time.
Any new equipment or changes to the process, will be evaluated for noise and when feasible, engineered to keep noise levels below 85 dBA. Contact your Industrial Hygienist.
6. NEXT REVIEW DATE: December, 1993
JJ
C/)
cn CO CO
6
DOW CONFIDENTIAL
C O N F ID E N T IA L
IHSFie#A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Pagel
ASBESTOS PROGRAM
1. INVENTORY
Asbestos is contained in this block in the following forms :
Gaskets
Transite
Fireproofing
V
An inventory of all asbestos containing materials and their respective locations is attached. The inventory must be maintained until the materials have been removed. Labeling of asbestos is by block signs located at entrances to the block.
2. INSPECTION SCHEDULE
Asbestos containing materials will be inspected every 6 months by
' for signs of
deterioration. If deterioration is found the material will be repaired or removed. In the event
removal is required insulation services will be contacted for assistance. Removal and disposal
will be according to appropriate procedures as outlined in the Texas Operations Asbestos Handbook
(TOAH).
Questions may arise at the time of removal of insulation or at the time of the 6 month inspection as to whether a particular piece of equipment contains asbestos or not. If this situation arises, the material will be sampled and sent to analytical sen/ices to be analyzed.
3 . TRAINING
The following job classifications are identified as having potential to handle asbestos containing materials and should be trained according to Section III of the TOAH.
Utility Man/Contractor
0
S
All individuals in the above job classification will be trained before initial assignment and annually thereafter. Training will be documented and forwarded to Industrial Hygiene Services for inclusion in the plant's Industrial Hygiene files.
4 . RESPIRATOR CERTIFICATION
For those jobs that require a respirator, an approved respirator will be chosen and mandatory medical certification and fit tests completed before initiation of the job. If exposure exceeds the Action Level (0.1 f/cc), the employee must be fit tested semi-annually and have annual medical examinations. Currently there are no employees at EDC/NPA that require medical surveillance.
5. PROCEDURES
n
oz
n D W
Z
>r
Written procedures have been developed for the handling of asbestos materials during the performance of maintenance, demolition, and renovation activities to be conducted at the facility The procedures are located in the Industrial Hygiene Manual.
3J
(J1
03 03
t*
DOW CONFIDENTIAL
IHS Fie #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
ASBESTOS PROGRAM (CONT.)
6 . ASBESTOS ABATEMENT PLANS Asbestos on column skirts will be removed in 1992.
7. NEXT REVIEW DATE: December, 1993
>)
Page2
CONFIDENTIAL
DOW CONFIDENTIAL
33 9 03
CWJ1 G4COJ*i
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 1
VENTILATION PROGRAM
1 . PROGRAM DESCRIPTION
The EDC/NPA ventilation system includes as follows:
ID
Last
Next
Average
NumberLocationSurveySurveyVelocity
A700101
A-1001
04/08/91 04/08/94
150
2. OPERATING CRITERIA
A. Periodic Performance Evaluation and Maintenance Programs -Administered by Industrial Hygiene Services and lab personnel at EDC/NPA.
B. Laboratory Fume Hood Performance Criteria -Utilize marked static pressure manometers to provide direct readouts and fall under the quarterly inspection guidelines.
3. DOCUMENTATION
The Industrial Hygiene Contact for EDC/NPA is responsible for maintaining documentation on hood surveys and inspections.
5. NEXT REVIEW DATE: December, 1993
CONFIDENTIAL
DOW CONFIDENTIAL
ID
0*
04a0>*
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 1
ERGONOMICS PROGRAM
1 . INTRODUCTION
The plant ergonomics program is dependent on the work situation and other specific factors which contribute to musculoskeletal injuries. Physical stressors and other activities which can contribute to musculoskeletal injuries include manual lifting, repetitive motion/forceful exertions, or excessivevibration. Identification of these factors is the basic responsibility of the assigned plant ergonomics contact with assistance from the plant Industrial Hygienist.
2. MANUAL LIFTING ACTIVITIES
job Activity Moving Drums/Bottles using a dolly
Frequency 2-3/week
3. REPETITIVE MOTION/FORCEFUL EXERTIONS
Weight
100 - 500 lb
Computer personnel (keyboard entry)
4 . POWER TOOL USE
Tvoe of Tool Disc grinder Impact
Frequency of use daily weekly
Duration 30 min 30 min
5. TRAINING
Basic training on the identification of ergonomics factors is recommended for all block employees on a periodic basis.
6. NEXT REVIEW DATE: December, 1993
CONFIDENTIAL
DOW CONFIDENTIAL
31
0
CO
cn
00
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 1
HEAT STRESS PROGRAM
1 . HEAT STRESS INVENTORY
The plant heat stress program is dependent upon the work situation and other specific factors which would generate excessive heat for the employee. The two factors to be considered are environmental temperatures and heat build-up due to the activity level of the employee. Based on previous heat stress studies, work/task evaluations, hot process operations and/or use of personal protective equipment such as impermeable suits, the following are identified as potential heat stress problems:
Outside manual labor with or without chemical protective clothing (PPE for HCL spill)
2. TRAINING
The following job classifications are identified as having potential for heat stress ahd should be trained in the recognition, prevention and treatment of heat stress:
Control C Operator
Heat stress training is conducted every 2 years.
3 . HEAT STRESS ABATEMENT
The following drinking fluids are available for fluid replacement:
Water
Gatorade
The following checked personal protective equipment for the prevention of heat stress is available at this plant:
none
Recommended work practices for reduction of heat stress include:
1. Fluid replacement
2. Self-paced work
3. Scheduling
4. Acclimation
4 . WORK REST SCHEDULE
The heat stress prevention work/rest schedule for jobs requiring impermeable clothing is as follows:
Temperature (F)
72 - 79 80 - 87 88 - ?
Maximum Stay Time (min.)
40 30 20
5 . NEXT REVIEW DATE: December, 1993
Minimum Rest Time (min.i
20 30 40
CONFIDENTIAL
R&S153848
DOW CONFIDENTIAL
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 1
HEALTH SURVEILLANCE PLAN
1 . HEALTH SURVEILLANCE All employees are offered core examinations every two years.
2. MEDICAL SURVEILLANCE REQUIREMENTS
The following job classifications are included in the MSR programs as identified below:
Job Classification
MSR
Tests
Test Frequency
Control C Operator DOCUMENTATION
BX Same as periodic core exam Every 2 years
Results are reported individually and in group format to area supervision.
CONFIDENTIAL
r &S 153849
DOW CONFIDENTIAL
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 1
INDUSTRIAL HYGIENE EDUCATION PROGRAM
1 . INTRODUCTION
Training will be documented using the forms located in the 'Hazard Communication" section of the facility's Industrial Hygiene Manual. Copies of the training records will be stored in the Industrial Hygiene Manual until the time of the next regularly scheduled Occupational Health Plant Program review. The original documentation will be sent to Industrial Hygiene Services at B-101 for filing in the plant compliance files.
2. TRAINING PLANS - CHEMICALS
The Industrial Hygiene Education Program will focus on the following key agents for 1992/1993:
1992
Chlorine Ethylene Dichloride Vinyl Chloride Polychlorinated Biphenyl Methylene Chloride
1992
1,1,2,2-tetrachloroethane 1,1,1,2-tetrachloroethane Phosgene Caloria HT-43 Noise
3. RESPIRATORY PROTECTION TRAINING
EDC/NPA will follow the guidelines defined in the Plant's written respirator program (located in the Industrial Hygiene Manual). Annual training is required.
4 . CHEMICAL SURVEY RESULTS
A report of the results of sampling conducted in accordance with this protocol will be written and communicated individually and in a group session.
5. HAZARD COMMUNICATION TRAINING
All new employees shall review and document with signatures:
a. hazard communication videos (2) b. the facility's hazard communication program c. health hazard information for all materials with Priority Rating of 1, 2, or 3 (see CPAI) d. health hazard information for OSHA regulated chemicals with Priority Rating of 1, 2, 3, or 4 e. health hazard information for the key agents listed above
See the Plant's written Hazard Communication program in the Hazard Communication section of the facility's Industrial Hygiene Manual for other training requirements.
Any temporary employees shall review and document: b,c,d,e.
CONFIDENTIAL
DOW CONFIDENTIAL
9C/3
U05l CcDn
o
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 2
INDUSTRIAL HYGIENE EDUCATION PROGRAM (CONT.)
6. ASBESTOS TRAINING
All personnel who work in EDC/NPA must receive initial training. Personnel who handle asbestos must receive annual training. Consult the Texas Operations Asbestos Handbook for training requirements.
7. NOISE TRAINING
Employees at EDC/NPA are not required to participate in the Texas Operation Hearing Conservation Program as all average personnel exposures were less than the OSHA Action Level of 50%. As there are noise levels greater than 90 dBA in the plant, training should be performed on a periodic basis (ie. every 2 years). Refer to Safety Standard 0-46 and the Hearing Conservation Manual for training requirements.
8. NEW CHEMICAL TRAINING
Per HAZCOM all employees to be potentially exposed to a new chemical must be trained on the hazards of that chemical and the approved protective equipment. Signatured documentation is required at the time of this training, to include MSDS, TIME sheet, or hazard data used.
9 . HEAT STRESS TRAINING
Personnel performing jobs (eg. chemical suit in the summer) that may lead to heat stress are to be trained on heat stress avoidance procedures. This training is recommended for new employees and on a periodic basis for experienced employees. Training should be documented.
10. PROTECTIVE EQUIPMENT TRAINING
Per 29 CFR 1910.132 protective equipment shall be provided, used and maintained for employees with potential of exposure to environmental or process hazards. Personnel are to be trained on the proper use or applicable protective equipment upon initial assignment, after major job changes, and periodically. Consult the Texas Operations Personal Protective Equipment Program Manual for training guidelines.
CONFIDENTIAL
DOW CONFIDENTIAL
ZD
0 a>
V}
CO
UCDl
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 3
INDUSTRIAL HYGIENE EDUCATION PROGRAM (CONT.)
1 2. VENTILATION SYSTEM TRAINING
Personnel that use ventilation systems (incl. hoods, dust and chemical ventilators) are to be trained in the use, maintenance and documentation requirements. Hood requirements are covered in Safety Ref. 7.
1 3. HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE
Per HAZWOPER personnel involved in operations in RCRA Treatment, Storage, and Disposal facilities must be trained. Training must enable the employees to perform their job in a safe and healthful manner so as not to endanger themselves or others. Training topics include respiratory protection, hazard communication, health hazards training, protective equipment, safety standards/references, job procedures, RCRA, hearing conservation, eye protection, emergency procedures and unit specific rules.
All new employees must receive at least 24 hours of initial training. Current employees do not need the 24 hours of initial training if equivalency can be proved. Certificates of training must be issued to all employees. Eight hours of refresher training is required on an annual basis.
Personnel in facilities where RCRA wastes are stored less than 90 days are only affected by the emergency response portion of the HAZWOPER RCRA section. Training for those employees who must respond must occur prior to ER assignment and annually thereafter and must include:
1. elements of the ER plan 2. ER procedures 3. personal protective equipment 4. job procedures
Non-responding employees should be trained to recognize an incident and activate the ER system. The method used to demonstrate competency must be documented.
CONFIDENTIAL
R&si 53852
DOW CONFIDENTIAL
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 1
RESPIRATORY PROTECTION PROGRAM
1 . INTRODUCTION
Information regarding Dow respiratory protection programs is located in Safety Standard 0-45 and the Texas Operations Respiratory Protection Manual (RPM). The RPM addresses selection, use, fit testing, medical approval, training, maintenance, records, administration and recommended respirators. Responsibilities for employees, supervisors, industrial hygiene, fire departments and Occupational Health are detailed in the RPM.
2 . TYPES OF RESPIRATORS USED
Respirator Type
AOR9722 Mouthbit AO 5 Star Scott Air Pack 2.2 SCBA with Scottoramic full face mask Scottovista full face airline Scottoramic full face airline 3M 8710 Dust Mask
Cartridges Filter. Canisters OVAG (R722) CVA3
NA NA ISA NA
Sources of Breathing Air NA NA
20 min. air tank Cylinder Cylinder NA
OVAG NIOSH approved for Organic Vapors and Add Gases
Industrial Hygiene is contacted whenever a new respirator is selected.
3 . RESPIRATORY USE CATEGORIES
Job Classification
User category
Beso. Types Used
Individually Issued
Office personnel Operators
Maintenance
Escape Routine/Escape Emergency Routine/Escape Emergency
MP
MP; Half-face SCBA
MP; Half-face; airline SCBA
MP MP; AO 5 star
MP; AO 5 star
MP = AOR9722 Mouthbit
Routine/Emergency users are fit tested and medically approved biennially.
Respirator trainingis conducted by:
Respirator Type
Escape Routine/emergency
Trainer
Plant Representative Plant Representative
Frequency
Every 2 years Annually
Visitors, contractors and employees are required to carry an escape respirator on their person while in block process areas.
C O N F ID E N T IA L
DOW CONFIDENTIAL
IHS File #A70-392fi-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
RESPIRATORY PROTECTION PROGRAM (CONT.)
Page 2
4. USE SITUATIONS
Respirator Tvpe/Filter
Mouthbit
Chemical of Concern
"v
CI2, Acid Gases
Use Situation
Escape
Half face/OVAG
RCL's, CI2
Process sampling; equipment opening
Full face airline SCBA
RCL's, CL2 All chemicals
Equipment opening Emergency response
3M 8710
Dust/silica
Cleaning and/or charging silica drums
Filter cartridges for the mouthpiece respirator or half face respirators carried for escape purposes only should be replaced after each use or at least every six months. Filter cartridges for half face respirators used for routine work should be replaced when breathing becomes difficult, breakthrough is detected, or at least every 2 weeks.
5 . RESPIRATOR CLEANING STATIONS
The cleaning station is a sink located in the change room. Half face masks are cleaned with alcohol towlettes. Airline equipment and SCBA are sent to the fire department for cleaning after each use. Contaminated respirators and cartridges which cannot be decontaminated must be disposed of as chemical waste in accordance with applicable environmental standards.
6. RESPIRATOR STORAGE
Respirator
MP Half face air purifying SCBA (30 min.) Airline masks Dust masks
Storage Location
A-7001 lockers A-7001 lockers A-7001 Control room and day Foreman's office A-7001 cabinet behind control panel A-7001 cabinet behind control panel
Except for the mouthpiece respirator, all respirators must be stored in secondary containers such as respirator pouches, plastic bags or storage boxes.
CONFIDENTIAL
DOW CONFIDENTIAL
ID
CO
Oi C0C4O70*1
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA. A-7001
Page 3
RESPIRATORY PROTECTION PROGRAM (CONT.)
7. INSPECTION SCHEDULE
Respirator
Freauencv
E*
Documentation
Retained By
Half Face Airline SCBA
MP Dust Mask 8. BREATHING AIR
Monthly " Before each use
Before each use Monthly Annually 5 year hydro Quarterly Before each use
User User EDC/NPA SRO
EDC/NPA SRO Fire Dept. Fire Dept. User User
Plant Rep. none none Plant Rep Fire Dept. Fire Dept. User none
The breathing air source is from bottles which have been pre-checked for oxygen content and markings.
9. DOCUMENTATION
Documentation of inspections, fit testing, and training are maintained by the plant safety contact. Original signatures on training are sent to the plant industrial hygienist at B-101 for placement in the plant's 75 year compliance file. The plant superintendent and the Occupational Health Department maintain the medical approval list on file.
10. NEXT REVIEW DATE: December, 1993
CONFIDENTIAL
B&S153855
DOW CONFIDENTIAL
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 1
PERSONAL PROTECTIVE EQUIPMENT PROGRAM
1 . INTRODUCTION:
Information regarding the Texas Operations personal protective equipment (PPE) program is located in the Texas Operations PPE Program Manual. The manual addresses program administration, approval procedures, testing requirements, selection, use and maintenance, decontamination, laundering, training, records, and program evaluation. Responsibilities for employees, supervisors, industrial hygiene, safety, purchasing, the Texas Operations Protective Equipment Team, and the Texas Operations Protective Equipment Supplier Partnership Team are detailed in the manual.
2. SELECTION:
See Table 1 for a listing of approved PPE for the EDC/NPA plant. PPE selection was based upon the health and safety hazards associated with the site or job tasks. All PPE has been reviewed by the EDC/NPA Industrial Hygienist and Safety Director and has been approved for use by the Texas Operations Protective Equipment Team.
3. TRAINING:
Training on user responsibilities, PPE inspection, use, donning, doffing, decontamination, limitations and the location of theEDC/NPA PPE program is conducted for Dow employees and long term contractors upon initial assignment and biennally thereafter. This training is documented. Visitors are informed of and provided the minimum PPE required in the EDC/NPA plant.
4. INSPECTION:
All PPE items must be inspected visually before, during and after use for signs of deterioration, defects, damage, etc. However, the PPE items listed below shall be inspected according to the following minimum frequency and specific test protocol:
PPE Item Chemical Protective suits
Test Method Visual Inspection
Ecsquency Biannually
Ey Dept Rep
Chemical protective gloves Visual Inspection
Each use
User
Electrical rubber gloves
High voltage test Air test method
Biannually Each use
Elec Shop User
Electrical rubber blankets High voltage test
Biannually
Elec Shop
CONFIDENTIAL
R&s153856
DOW CONFIDENTIAL
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 2
PERSONAL PROTECTIVE EQUIPMENT PROGRAM (CONT.)
5. DECONTAMINATION AND DISPOSAL:
The EDC/NPA decontamination stations are located in the following locations:
safety showers throughout the process area.
After each use where PPE has been contaminated by hazardous substances, users of the contaminated PPE shall use one of the above listed decontamination stations and clean their PPE by rinsing with copious quantities of potable water. Before storage, the PPE is air dried . Contaminated PPE which cannot be decontaminated must be disposed of as chemical waste in accordance with applicable environmental standards.
6. MAINTENANCE:
No clothing or chemical protective suits are repaired in this department. Defective or damaged equipment is discarded.
7. LAUNDERING:
General purpose clothing is laundered in a standard type washer and dryer located in A-7001. No personal clothing may be washed in block washers. Half face and mouthbit respirators are cleaned by the individual owner. Full face respirators are sent to the fire department for cleaning.
8 . STORAGE:
The following lists where PPE is stored when not in use:
a Cotton gloves in glove bin in men's change room, glove bin b. North Silver Shield gloves are in laboratory drawer in A-7001 c. Low voltage gloves and flash suits in switchroom locker d. Individually issued equipment is stored in personal lockers e. Respiratory equipment is stored as follows:
Full face airline in the respirator cabinet in A-7001 Half face respirators in personal lockers and the day foreman's office in A-7001 Mouthbit in personal lockers and the safety cabinet in A-7001 f. SCBA's are located in the following locations: A-7001 control room A-7001 day foreman's office g. New PPE is stored in the Safety cabinet in A-7001 h. Full body harness in production/maintenance foreman's office
9. PROGRAM EVALUATION:
This program shall be evaluated biennally or whenever there are major job or process changes *u"` require a re-evaluation of the PPE currently in use.
NEXT REVIEW DATE: December, 1993
g cn
CONFIDENTIAL
DOW CONFIDENTIAL
IHS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 3
TABLE 1 EDC/NPA PPE INVENTORY, 1991
The following lists the approved PPE for the EDC/NPA plant. EDC/NPA written job procedures indicate when and which PPE items must be worn for specific job tasks.
A. HAND PROTECTION 1. Edmont Solvex (Vallen # 37-155) gloves 2. Edmont PVA (Vallen # 15-552) 3. North Silver Shield (Vallen # SS504S) 4. Scooba #JPS 10B Cotton Gloves 5. Low Voltage Gloves (the electric shop)
B. FOOT AND LEG PROTECTION 1. Steel Toe Servus 21714, 22114, 2. Boot, steel toe dielectrid & chemical neoprene, DCS-1010ST 3. Servus Rainfair 9043 4. Boot, steel toe pak rubber 15 in. top Servus 21629 5. Lehigh #1149 dielectric natural rubber boots
C. EYE, FACE AND HEAD PROTECTION 1. Face Shields - Wilson # V-10-86 - Encon # SD-115A 2. Hard Hats - Vallen 302 - Fibremetal E2W851 3. Sideshields - Variety (anything that is on approved list) 4. Chemical goggles - Allsafe #G211-10R - American Optical #484B - Encon 500 series - Encon 160 series
D. BODY PROTECTION 1. Neese 45
E. RESPIRATORY PROTECTION 1. Self-Contained Breathing Apparatus - Scott Air Pack 2. Airline Respirators Scottoramic Full Face #801548-00 (MSMS #4871) 3. Half-Mask Respirator - AO 5-Star 4. Dust Mask - 3M 8710 (MSMS #4869) 5. Escape Respirator - AO Mouthpiece R9722 with organic vapor/acid gas cartridge (MSMS #106840)
C/)
C O N F ID E N T IA L
DOW CONFIDENTIAL
IHS FUe #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
TABLE 1 (CONT.)
F. HEARING PROTECTION 1. Willson Sound Ban #20 (NRR=19-22) 2. E-A-R Foam Ear Plugs (NRR-29) 3. Bilsom Universal I Ear Muffs (NRR=23-25) 4. Bilsom Viking Ear Muffs #2318 (NRR=28) 5. E-A-R Ultra Fit Plugs with cord (NRR-27)
"
G. FALL/RESCUE PROTECTION 1. RTC 7435-PT1 Body Harness 2. RTC 8250-P6HH Unyard
Page 4
C O N F ID E N T IA L
DOW CONFIDENTIAL
33
CO
c0CUO3jil
CO
IHS FSe #A7D-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-70O1
DEPARTMENT ACTIVITIES
C O N F ID E N T IA L
DOW CONFIDENTIAL
g
o>
n -H
u
901 tw00n01
o
IHS File #A70-3926-91
EDC/NPA Process Flow, A-7000
t MB/12*91
I
iviiNaauMOD
Ffgur^ 1
aaiovaaa
IHS Re #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
JOB DESCRIPTIONS
Pagel
Plant Superintendent: The job Is primarily administrative with the individual spending 80% to 90% of the time in offices or control rooms. Remaining time is spent in production areas as an observer or supervisor. Non routine situations require close inspection of damaged or leaking equipment and operation of process equipment.
Maintenance/Production Foreman and Foreman: Approximately 40% of work time is spent office areas. Maintenance job supervision in production areas and dealing with open process systems requires 40% of work time. The remaining 20% of the time involves direct supervision of outside operations including spill cleanup, clearing of process equipment and operation of process equipment.
Control A Operator: Almost 100% of time is spent in the control room.
Control C Operator: About 85% of the time is spent in the process area. Work includes sampling, draining equipment, piping line-up, starting/stopping process pumps and plant clean-up. The remaining time is spent in the laboratory area performing analysis on process samples. Lab area includes approved fume hoods.
Senior Instrument Technician: Repairs and troubleshoots process analytical equipment and other instruments. Approximately 6070% of the time is spent in the plant process areas and the remaining time is spent in the instrument shop.
Utility Man/Contractor: These personnel are called upon to perform and support maintenance activities in the A-7000 block. Activities may include pipe fitting, welding, and grinding. 90% of the time is spent in the plant process areas with the remainder of the time in the maintenance shop.
CONFIDENTIAL
DOW CONFIDENTIAL
3Bo
U)
C03n C0roD3
IMS File #A70-3926-91
1991-93 OCCUPATIONAL HEALTH PROGRAM EDC/NPA, A-7001
Page 1
OSHA SPECIAL REGULATIONS
The EDC/NPA plant is directly affected by OSHA special regulations 29 CFR 1910.1001: Asbestos, 29 CFR 1910.1028: Vinyl Chloride, and 20 CFR 1910.95: Occupational Noise Exposure. A copy of each of these standards is located in the plant's Industrial Hygiene Manual. Key elements of the standards includes:
A Asbestos and Vinyl Chloride
1. exposure monitoring requirements 2. respiratory protection and personal protective equipment 3. medical surveillance 4. information and training
A review of the past monitoring data, the plant's respiratory protection and protective equipment policies, and Hazard Communication and training program, has confirmed the EDC/NPA plant to be in compliance with the requirements outlined in the Asbestos and Vinyl Chloride standards.
B. Noise
1. exposure monitoring requirements 2. audiometric testing requirements 3. hearing protection requirements 4. training requirements
A review of the hearing conservation program at the EDC/NPA plant has confirmed the plant to be in compliance with the requirements outlined in the Noise standard.
CONFIDENTIAL
r&SI 53863
DOW CONFIDENTIAL
IHS File #00-4961
1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT 5/VINYL CHLORIDE, OC-501
Page 1
OSHA SPECIAL REGULATIONS
Unit 5 is directly affected by OSHA special regulations 29 CFR 1910.1017: Vinyl Chloride, 29 CFR 1910.1028: Benzene, and 20 CFR 1910.95: Occupation Noise Exposure. A copy of each of these standards Is located in the plant's Industrial Hygiene Manual. Key elements of the standards include:
A. Vinyl Chloride and Benzene
1. exposure monitoring requirements 2. respiratory protection and personal protective equipment 3. medical surveillance 4. information and training
Initial monitoring as required by both standards will be completed upon start-up of the plant. Respiratory protection, protective equipment and medical surveillance policies will be developed and all Unit 5 employees will be trained on the requirements of both the vinyl chloride and benzene standard before plant startup.
B. Noise
1. exposure monitoring requirements 2. audiometric testing requirements 3. hearing protection requirements 4. training requirements
Area noise level monitoring will be conducted as new equipment is installed to determine areas where hearing protection will be required. Additional area monitoring and personnel monitoring will be conducted after plant startup. All employees of Unit 5 will be trained on the requirements of the noise standard before plant startup.
C O N F ID E N T IA L
IHS Rla #004961
1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT 5/VINYL CHLORIDE, OC-501
Page 1
INDUSTRIAL HYGIENE EDUCATION PROGRAM
1. INTRODUCTION
Training will be documented using the forms located In the Training Guidelines* section of the facility's
Industrial Hygiene Manual. The original documentation will be sent to Industrial Hygiene Services at B-101 for filing in the plant compliance files.
2. TRAINING PLANS - CHEMICALS
The Industrial Hygiene Education Program for Unit 5 will focus on the following key agents for 1993/94:
1993
Vinyl Chloride
Benzene Ethylene Dichloride Methylene Chloride Carbon Tetrachloride Chlorine Refractory Ceramic Fiber
1994
Vinyl Chloride 1,1,2,2-Tetrachloroethane Benzene HCL Welding fumes
3. RESPIRATORY PROTECTION TRAINING
Unit 5 will follow the guidelines defined in the Plant's written respirator program (located in the Industrial Hygiene Manual). Annual training is required. 4. CHEMICAL SURVEY RESULTS
A report of the results of sampling conducted in accordance with this protocol will be written and communicated individually and in a group session.
>
O H
5. HAZARD COMMUNICATION TRAINING
-O
All new employees shall review and document with signatures:
_
a. hazard communication videos (2)
b. the facility's hazard communication program
c. health hazard information for all materials with Priority Rating of 1,2, or 3 (see CPAI) d. health hazard information for OSHA regulated chemicalswith a Priority Rating of 1.2,3, or 4 e. health hazard information for the key agents listed above
See the plant's written Hazard Communication program in the Hazard Communication section (Section 10) of the facility's Industrial Hygiene manual for other training requirements.
Any temporary employees shall review and document: b, c, d, e.
6. ASBESTOS TRAINING
There is no asbestos in this plant. However employees will be given asbestos awareness training on initial assignment.
IODf
W cn
CO CO
tfl
C O N F ID E N T IA L
IHS File #00-4961
1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT S/VINYL CHLORIDE, OC-501
Page 1
HEALTH SURVEILLANCE PLAN
1. HEALTH SURVEILLANCE All employees are offered core examinations every two years.
2. MEDICAL SURVEILLANCE REQUIREMENTS Initial exams are conducted as is required by the OSHA vinyl chloride, benzene, and noise standards. Inclusion in a medical surveillance program will be determined based on monitoring data collected as soon as possible after plant startup.
3. DOCUMENTATION Results are reported individually and in group format to area supervision.
CO NFIDENTIAL
B&S153866
IHS File #004961
1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT 5/VINYL CHLORIDE, OC-501
Page 1
MONITORING PROGRAM
1. RATIONALE
To fulfill OSHA requirements of the vinyl chloride and benzene standards, establish a monitoring base and to evaluate the need for any additional engineering controls, initial monitoring will be conducted immediately after plant startup. Chemicals evaluated will include vinyl chloride, benzene, ethylene dichloride, and methylene chloride. Respiratory protection will be used for any job tasks with a significant potential for exposure to concentrations above the acceptable guidelines. Respiratory protection will be continued until monitoring data has proven levels to be below acceptable exposure standards.
Area noise level monitoring will be conducted as new equipment is installed to determine the need for hearing protection, additional engineering controls and identify any job classifications that may need to be included in the hearing conservation program. Personnel monitoring will be conducted for job classifications where 8-hour TWA exposures may exceed 85 dBA. Afterplant startup, a comprehensive area and personnel noise survey will be conducted to identify ail areas with noise levels greater than 85 dBA and determine if any job classifications need to be included in the hearing conservation program.
2. SAMPLING STRATEGY
When Unit 5 reaches the final stages of construction, job classifications will be evaluated periodically to determine the need for chemical and/or noise monitoring. Monitoring will be conducted on an as needed basis until startup. As soon as possible after startup a comprehensive noise and chemical survey will be conducted. The sampling strategy (number of samples and job classifications) will be determined at that time.
3. SAMPLING METHODS
Sampling for vinyl chloride, ethylene dichloride, methylene chloride, and benzene will be conducted using 1 gram charcoal tubes and air sampling pumps. Pumps will be calibrated both before and after use at 50 cc/min for 8-hour TWA samples and 200 cc/min for excursion samples (as outlined in DLI-IHM-83-25A). Analysis will be performed by the Industrial Hygiene Laboratory.
Personal noise levels will be measured using Quest noise dosimeters (Model M-7B) and area noise levels will be measured using a Quest noise level meter (Model 215). All dosimeters and meters will be calibrated both before and after use.
4. QUALITY CONTROL AND EQUIPMENT
Routine quality control procedures shall be an integral part of the sampling and analysis procedures and functions. These shall include:
a. Routinely introduced sampling of blanks and spikes (known content) along with other samples for analysis
b. Routine checking, calibrating, and maintaining in good working order all equipment and instruments. Air sampling pumps will be calibrated both before and after use.
c. Routine checking of procedures and results. d. Participation in Dow's Analytical Proficiency Testing (APT) Program.
a
CO
CO0Q0l
^1
C O N F ID E N T IA L
IHS File #00-4961
1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT 5/VINYL CHLORIDE. OC-501
Page 2
MONITORING PROGRAM (CONT.)
5. EVALUATION CRITERIA
Aaent
Vinyl Chloride Ethylene Dichloride
Benzene Methylene Chloride Noise
Exposure Guideline
1 ppm 10 ppm 1 ppm 1 ppm 50 ppm
90 dBA (8-hr TWA) 85 dBA (8-hr TWA
Excursion Guide
5 ppm-STEL
2 ppm 5 ppm-STEL
90 dBA-Ceiling
Source*
OSHA-PEL ACGIH-TLV Proposed OSHA PEL OSHA-PEL ACGIH-TLV Dow IHG OSHA-PEL OSHA-Action Level
OSHA-PEL Occupational Safety and Health Administration - Permissible Exposure Limit
ACGIH-TLV American Conference of Governmental Hygienists-Threshold Limit Value Dow-IHG = Dow Industrial Hygiene Guideline
C O N F ID E N T IA L
r&S153868
\
IHS File #004961
1993-95 OCCUPATIONAL HEALTH PROGRAM UNIT 5/VINYL CHLORIDE, 00501
REVIEW OF PAST MONITORING DATA
Page 3
Since this Is a new plant there is no historical monitoring data. Previous routine monitoring conducted for
the Unit 1/Vinyl Chloride plant has shown vinyl chloride, ethylene dichloride, and benzene personal exposures to be within acceptable levels.
on
as 3 tr1
33
cn Codr
00 ay