Document 93ODEmya4mRv3k3X2mGwxpya3

Technical Task Group on Vinyl Chloride Research Manufacturing Chemists Association 1825 Connecticut Avenue, N. W. Washington, D. C. 20009 April 8, 1974 P. O. Box 8004 South Charleston, W. Va. 25303 SUBJECT: Proposed Occupational Safety and Health Work Practice Standard for the Manufacture of Synthetic Polymer Containing Vinyl Chloride Gentlemen: The attached Occupational Safety and Health Work Practice Standard for the Manufacture of Synthetic Polymer Containing Vinyl Chloride is submitted for your consideration and approval. J- In preparing this Work Practice, the Subcommittee set the following objectives for itself: 1. Workers in the industry must be protected from hazards related to vinyl chloride exposure. 2. The Work Practice Standard should be practical and clearly understandable. Performance standards were not to be rigid routines. 3. The hazards related to vinyl chloride exposure should be controlled within the monomer and polymer industry. Resin converters and com* pounders should be protected. 4. The Work Practice should not impose impossible or uneconomic limits on the monomer or resin industry, but should eliminate many of the past practices which may have caused or contributed to the health hazards attributed to vinyl chloride inhalation. ftS V 0002760 2. In light of the foregoing objectives, the Subcommittee chose a working level concentration of 50 ppm TWA based upon work reported by Torkelson, Oyen, and Rowe (Am, Ind. Hyg. Assoc. Journal, Volume 22, page 354, 1961) and the work currently underway by Dr. Cesare Maltoni. Since there is no data indicating that polyvinyl chloride resin is harmful, the Subcommittee does not feel that protection from this material is required other than that needed for nuisance dusts. Similarly, no identified hazard exists for absorption of vinyl chloride through the skin from low concentra tions in air, thus, no impervious clothing and other protective devices are required. .k ;.. . ... Based upon the Work Practice Standards already established for human carcinogens, a concentration limit of 0. 1% by weight or less was set on process and product streams to be exempt from the standard. The Sub committee believed that with proper ventilation no hazazard would exist for workers in waste treatment plants, in transportation operations, and in sub sequent compounding and fabrication of the resin. The desire of everyone in government, labor, and industry to minimize the hazards to workers in the resin and monomer industry has .led to requests for goals such as no detectable level of vinyl chloride monomer in the air or levels of 5 or 10 ppm ceiling. The subcommittee believes that these limit? are uneconomic and all but impossible to meet, based upon present technology. The chosen limit of 50 ppm TWA in this standard represents a serious constraint on the industry but it is one that industry is prepared to accept in the interest of worker safety. An arbitrary reduction in the acceptable ceiling concentration to 0, 5, or 10 ppm at this time is simply a requirement for liquidation of a major industry. The Subcommittee on Work Practices recommends approval of the attached Work Practice Standard for the Manufacture of Synthetic Polymer Containing Vinyl Chloride and that it be transmitted to the Department of Labor as an industry proposal. Very truly yours. RNWJr/ra Attachment Subcommittee on Work Practices Rsv 0002761