Document 99Ed6R2J32aNwyXk5VyLKjOjL

y L -vfusLi, B.F. GOODRICH CHEMICAL COMPANY Calvert City, Kentucky DISTRIBUTION D SUBJECT: Vinyl Chloride Standards SPECIAL NOTICE ISSUED: 3-26-74 Last week the Federal Occupational Salety and Health Adalnistratlon announced temporary emergency health standarda for planta Involved In tho manufacture or use of vinyl chloride. Theae standarda will be published In the Federal Register and will be effective on April 8. In general, they will be the same standards adopted by the Kentucky Occupational Safety and Health Adalnistratlon a few weeks ago, which applied primarily to polyvinyl chloride plants. For the most part, we are operating In conformance with what we believe the new standards will specify. The basic parts of the standard call for the use of protective breathing devices when the concentration of VCM exceeds SO ppm, the use of protective clothing In certain Jobs where high exposure might be experienced, and the monitoring of work areas to be sure the exposure Is measured. In addition, some basic rules for personal hygiene, such as eating habits, washing, showering, etc., will be included. We have been monitoring our work areas for soma time now with our new organic vapor analyzer (OVA). It shows that our normal atmosphere la well below the SO ppm. It also shows on certain Jobs such as sampling and opening equipment, that we will have to develop new methods and procedures. In the Interim, we must use protective respiratory equlpomnt where VCM exposure Is possible. It must be remembered that our OVA monitoring shows total hydrocarbon exposure and further laboratory analyses have shown that In most cases, the major portion Is EDC, not vinyl chloride. Our present monitoring system In the EDC Manufacturing and Synthesis area tells us specifically how much of each hydrocarbon Is In the atmos phere--our other monitoring does not. It Is important In complying with the new regulations that we know the VOt concentration In the atmosphere and our monitoring systems will be so designed. It Is Important, also, that our exposure to EDC be minimized as It has in the past; however, the effects of EDC on health are well-known and there has been no evidence that it la as toxic as VCM nay prove to be. It Is known that exposure to excessive amounts will cause liver problems which abate upon the person's removal from the exposure. This is the reason we have had a strict health monitoring program since the first day EDC was brought into the plant. There has been no evidence to link EDC to any cancer problem In any way. Our present health monitoring program for all employees is continuing. Some employees who showed some abnormalities In liver function arc being re-oxamined to seek the cause of the abnormalities. At the present time, the doctors reviewing the test re sults still see no serious Implications for any Individual. Hearings will be held by the Federal OSHA In the next two months to establish permanent standards for the handling of VCM. We believe tho present temporary standard to represent the best balance at this time of exposure level to health risks. This judgment is baaed on available data from animal studies and human exposures to more than SO ppm for extended periods. A standard of "zero cxpo.sure" has been proposed. In our view this standard, If adopted, would shut down the PVC industry. Our Company has made this position known to OSHA- C. L. woods bs 20304001 WGD25TT