Document 82GpmxBV1y9rKLEjNNw9Rdz7a

O. S. H. A. INSPECTION - BROWNSVILLE PLANT SEPTEMBER 18, 1974 Mr. Bert Lindquist, District Supervisor, and Mr. Ray Skinner, Industrial Hygienist, representing the U, S. Department of Labor, in spected sections of the Brownsville Plant. The officers were from the Corpus Christi, Texas office. The inspection was triggered by the opinion that we manufactured or stored vinyl chloride based on our SIC number. After discovering that we did not manufacture or store vinyl chloride, one of the inspecting officers, Mr. Skinner, decided that he would perform an abbreviated inspection concentrating in the area of industrial hygiene. The following areas were inspected: 1. Plant Laboratory 2. Respiratory equipment specifications and inspection records. 3. Noise Surveys. 4. Asbestos Exposure Data. 5. Sandblasting equipment and respiratory equipment. 6. O. S.H.A. forms 100 - 101 - 102. 7. Bulletin Board for display of Department of Labor Notification to the Employee. Inspection Discussion: Laboratory Area Checked storeroom and storage areas carefully for carcinogens and target health hazards. Talked to two laboratory analysts privately. Checked exposure of analyst washing glassware. Checked for flammable vapors while drying glassware with acetone in open sink. The inspector was impressed with laboratory equipment, indus trial hygiene equipment and general laboratory capability. Medical Area O; S. H. A. Forms 100, 101, 102 checked. Very impressed with low O. S. H. A. recordables. Asked about audiometer calibration and certifi cation of plant nurse. Inspector mentioned the regulations to be proposed soon related to a hearing conservation program. The plant nurse in formed him that she was to attend a meeting soon to set up a plant audio metric program. He said he had no legal basis for looking at our audio- BRE 0003 2- - metric data but felt we were far ahead of most companies. Respiratory Equipment Records and Procedures Respiratory equipment records and procedures were checked and found to be in order. The sandblasting area was checked for the following: a. Sandblasting hood certification b. Air Compressor. We could find no Bureau of Mines certification stickers on the blasting hoods. He seemed concerned about this and felt that our permanent records should reflect this certificate number. (See general comments section). The inspector checked the air compressor for high temperature cut-off capabilities. We were also asked if we had silica exposure data. These data had not been collected. The inspector indicated that the Contractor should be responsible for monitoring for silica. We pointed out use of Maintenance RM-1 computer program for safety equipment checks. Industrial Hygiene Records Review Exposure data was reviewed in the following areas: ,a. Organic vapors in the operating area and personnel exposures. Records were reviewed briefly. The discussion centered around methods more than data. b. Asbestos exposure records were reviewed. Maintenance procedures for removing and disposing of asbestos were reviewed. c. Audio dosimeter data was reviewed. He checked data and pointed out error of duPont dosimeter in various frequency ranges. Impressed with our efforts in regard to noise maps. BRE 0004 -3 - Laboratory Hoods . We asked the inspector if a laboratory ventilation hood had to meet ANSI standards. He felt that from an industrial hygiene standpoint he would monitor personnel exposure and not be con cerned about design. If exposure was below eight hour time weighted average he would have no concern. General Comments Mr. Lindquist asked if we had a Plant Safety Committee, Safety Meetings, policies and procedures. We explained our formal safety program for him. We also showed him a list of records which the plant maintains for O. S. H. A. purposes. The cafeteria bulletin board was checked for the O. S. H. A. Employee Notification Form. The inspector noticed our Plant Safety Committee Meeting notes and the UCC Disabling Injury Frequency Rate through August, 1974 which were also on the bulletin board. Mr. Lindquist telephoned Friday, September 20th and thanked us for our cooperation. He had checked with the manufacturers of our sandblast hoods to determine if ours were Bureau of Mines approved. .The hoods were approved and he provided the number for our plant records. Documents Furnished Inspectors 1. "Union Carbide in Texas" Bulletin. 2. "SHARE UPDATE" No. 3, August 1974. .3. Receiving report for valve assembly from Fairmont, W. Va. 4. O. S. H. A. checklist of fourteen carcinogens and target hazards. (Attached) 5. O. S. H. A. questionnaire regarding'number of personnel, products, location and management. (Attached) BRE 0005 JOB SITE QUESTIOXAIRI --PLEASE PRINT- CSHO NO. AREA F/'lR | OSR-.-I No.' REGION 7AME OF COMPANY / ./ /. TYPE CF BUSINESS ESCRIPTION OF WORK IN PROCESS , , JOB SITE ADDRESS (- / ' ... < \ l r' `i - r. , CITY ( I STATE ZIP ."L ' J03 SITE TELEPHONE NO.- L ' ' > PERSON IN CHARGE OF JOB ' '' TITLE r". - H. 7- /vV HAILING ADDRESS SUPERVISING OFFICE 'l A-;- _P. 0. BOX_ CITY ________ STATE ZIP OFFICE PHONE NO. & AC NAME OF TOP SUPERVISOR & TITLE A IF CORPORATION, GIVE NAME OF PRESIDENT AND HIS MAILING ADDRESS_ ( V,, t r i *--- . S. 1 /VF>r;Vf IF PARTNERSHIP, GIVE THEIR NAME AND THEIR MAILING ADDRESS IF SOLE OWNER, GIVE HIS NAME AND HOME MAILING ADDRESS IF ASSOCIATION OR OTHER LEGAL ENTITY, GIVE NAME AND MAILING ADDRESS NUMBER OF YOUR EMPLOYEES AT THIS SITE: MALEI ? CFEMALE ' ? LARGEST SHIFT: MALE:"-" FEMALE i 7 TOTAL EMPLOYED AT ALL LOCATIONS . / L 14 DO YOU HAVE A FEDERAL GOVERNMENT CONTRACT: YES___ NO '/ , CONTRACT NO.AMOUNT ARE YOU UNION: YES____NO' X IF SO, NAMELOCAL NO.' BRE 0006 Ehi-lbvor -(ITC v*' t* A *5 Ccunr,v C)* O M, U V" K SIC .-? At ( . 1 t. tj V" :* >-r J03 SITE CHECKLIST C'.i CAECIHGGEHS AMD TARGET HEALTH HAZARDS CSHO !io. 6090 Area 0SHA-1 :Io. 06 ^ ca Do you have or store any of the following: (This information should be supplied by chemist, industrial hygienist, purchasing agent or other competent oerson). . Yes ]lo__ i. cly vinyl chloride, vinyl chloride or vinyl chloride resins ----------Li------------------ 2. 4 - Hitrobi nhenyl ...... ^_____________ 3. Alpha-naphthylam.iue 4. 4, 41 - Methylene bis(2-chlcro aniline) 5. Me thy1 chior one tLylether 6. 3,3' n:CHLQ?.03Ei-:ZIDi:!S (add its salts) ______________ X 7. bis-Chloro methyl ether 8. beta - Haphthylamine A' 9. Penaiciir.e 10. 4 - Anir.o-d ipher.yl 11. ET HITE: ; S L'iIDE * * 12. be ta-rr cpic-lactone 13. 2 - Acetylaninofluorene 14. L - Dic.ethlaminoazobenzene 15. ' Kitrossdisiethylamir.e 16. Targe (o') h y r.,- r ---1-- i S! ": (c) biirca :tarards ~ U'-/ uou.cn ..st ^ e; oarnon . .onoxj.<:e ______________ . THE ABOVE ILEOrt-'JiTIX!^ TfdJE AIJ^qpRRFXT Fh m. oyrs Si mature & 4. X. * Ji A* *sr ----- :--------Jf * f\ Title # *1 .-<? H * Date ^ * } S'" * / ____ t j- . ^,2r wj5f% .S^rv- - (At>a ai, fees'?*> $>,<w*t o 6 fe 5 ft- f 'iT.V- t<j BRE 0007 u. s. DEPARTMENT OF LABOR OCCl'P.vnONAI. SAKKTY AND UDAI.Til ADMf.N 1ST!'ATION Suite 1322, Tlie 600 HuiMin 6C0 Leopard Street Corpus Christi, Texas 73 REQUEST FOR AS ITOUSTRIAL HYGIENE INSPECTION To: __________ ____________________________ {Name of Establishment) (street) (City) DATS OF REQUEST? REFERRAL DATA CSKO SIGNATURE 1, What is produced? 2. 'What raw material is used? 3. What materials are added in the process? 4. What operational procedures are U3ed? 5. How many employees are exposed and for how long? ADDITIONAL IN'FOPO'ATIOU: BRE 0008 #i llWSSlliSfsISl INTERNAL CORRESPONDENCE UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS p. o. box 3370, brownsville, texas 78520 To (Namei Company Location Mr. W. W. McManus Copy to * Mr, B. F. Brown, 526 Mr. D. E. Deese, 515 Department Heads, 526 Mr. W. A. Gay, 312 Dr. D. H. Glenn, 515 Mr. R. C. Glock, 526 Mr. R. E. Graebert, 511 Mr. C. A. Keil, 526 Mr. R. E. Peele, 511 Mr. K. G. Townsend, 526 Date September 23, 1974 Originating Dept. Answering letter date Subject o. S. H. A. Inspection, Brownsville Plant September 18, 1974 Attached is a summary of the O. S. H. A. inspection conducted by Department of Labor representatives on September 18, 1974. The inspection began at 9:00 A. M. and was completed by 1:15 P. M. No citations were issued or violations noted. Very truly yours, LTW :gr Attachments - V. L. T. Windel BRE 0002