Document B8yYR94O911zOzm2KJ9gqbL7J

ONION CARBIDE CORPORATION________________________________________________________________________________ Chemicals & Plastics 270 Park Avenue, New York, New York 10017 RECEIVED Prom: A. B. Steele cc: See Attached List APR 26 1974 R. N. WHEELER. JR. Date: Subject: April 19, 1974 Formation of the VCM/PVC Industry Management Cctonictee Within the Society of the Plastics Industry PURPOSE: 1 The recent increase in concern that vinyl chloride monomer exposure may induce liver cancer in wortanen has given rise to a proposal that the monomer and PVC resin producers form a single, unified action group to deal with the various phases of the problems that now con front the industry. In the recent past, coordinated effort to cope with the special problems relating to regulations by 0S11A, NIOSH, EBY, and FDA have been handled by the management representatives of the group of vinyl chloride and polyvinylchloride resin producers Involved In the Vinyl Chloride Research Program administered by the Manufacturing Chemists Association. Because the charter of the MCA makes It awkward to have specialized segments of the industry opera ting under its sponsorship, the VCM/PVC Industry Management Connietee held an Ad Hoc meeting In Washington, D.C, on April 16, 1974, and decided to form a permanent action group within the Society of Che Plastics Industry where Bylaws of SET are compatible with present Industry needs. SPX COORDINATION: Mr, Ralph L. Harding, Jr. will coordinate the activities of the VCM/PVC Industry Management Committee; Jerome H. Heckman of Keller and Heckman, 1150 17th Street N.W., Washington, D.C. will pro vide legal advice. .For the present, the MCA-administered projects (animal exposure studies at Industrial Bio-Test Laboratories, Inc. and the study of the health of vinyl chloride workers by Tabershaw-Cooper Associates) remain within the administrative control of the MCA, Further addi tional studies that may be authorized by Che Management Committee from time to time will he administered by the SPI. INDUSTRY MANAGEMENT COMMITTEE ACTIONS: In recognition of the substantial amount of effort that will be needed to represent properly the Interest of the VCM/PVC producers in actions relating to vinyl chloride exposure of workmen in monomer, polynar, and fabrication plants, the following decisions were reached: 1. VCM/PVC producers form a single, unified group to deal with all of the phases; actions to be taken with OSHA, NIOSH, PA, FDA, and other agencies will be on a groups basis rather than each producer acting as an independent agent. Each producer reserves Che right to withdraw support and endorsement if che producer is unable to accept the proposals or representations of the Industry Management Consnittee. ucc 005022 -2- April 19, 1974 2. The SFI co provide administrative guidance, scaff support, and legal direction; costs to be covered by assessment of each Industry member, using a sliding scale relating to production of vinyl chloride monomer and/or FVC resins, within the general pattern now used by MCA. in raising monies for the several research projects relating to vinyl chloride. 3. A Steering Committee elected; Messrs. Vittone (Goodrich), Connors (Diamond Shamrock), Adams (Air Products), Williams (Dow) and Harding (SFI) are to act for the Industry when timing of action makes im practical bringing together of total Industry Management Committee. 4. A Public Relations Committee appointed; chaired by Ross Adams (Air Products) and authorized to contract with Arthur D. Little for an econotalc impact analysis defining the impact to the United States economy from a shutdown of the PVC resin industry--a condition that would result from the Imposition by OSHA of a standard of nondetectable levels of vinyl chloride within regulated operating areas. 5. A Task Group headed by Harry Connors (Diamond Shamrock) assigned Che responsibility to define the strategy and to initiate actions that will place the Industry in an advantageous position in nego tiating with OSHA a permanent Work Standard that can be accom plished in operating plants and not impose additional burdens on the safety and operating capabilities of employees, yet not com prise the health of workmen. The scope of this strategy includes concern for the Work Standard applied to monomer production, PVC polymerization operations, and forward through fabrication, inclu ding the monomer content of the workplace atmosphere, of the air exhausted Co the external environment, and of the resin product shipped and then fabricated to plastic materials. Union Carbide Is assigned an active role in this Task Group, since it is the present view that the Industry must present actual ex perience (health history) of a large population of employees in the production of PVC resins over an extended period of time if substantial relief from the likely standard that the vinyl chloride content of the workplace atmosphere be maintained at non-detectable levels. Union Carbide is recognized by the Industry as unique In having accumulated experience with VCM and FVC manufacture and em ployee health monitoring and records over extended time periods. 6. The Task Group identified in Item 5 additionally takes responsi bility for collecting information on the magnitude of VCM venti lated to the workplace atmosphere in various PVC plastic fabrica tion activities; almost without exception each PVC producer has at least one type of fabrication operation; has methods and in struments for making measurements that are reliable; will measure UCC 005023 -3- April 19, 1974 VCM concents o FVC resin, of fabricated plastic, and of work place atmosphere in an attempt to construct a profile that would inter-relate VOi concentrations. All members of the Industry Committee agreed to pool information In this area as 3uch data are accumulated, COMMENTS AMD MISCELLANEOUS INFORMATION REIATIVE TO THE VCM STANDARDS : A, MCA to prepare and distribute by April 17th a press release on preliminary findings of animal exposure studies at Industrial Bio-Test Laboratories, Findings of liver angiosarcoma at all three levels of vinyl chloride exposure confirmed by histopathology. These recent findings will likely influence OSHA to: 1) decrease ceiling exposure level in temporary standard below the 50 ppm level or 2) press for early publication of the permanent Standard which will approximate the NXOSH limit of non-detectable levels of VCM la the regulated operating areas. An early perma nent standard is the more likely action. , 3. Survey of members producers showed none that could operate if the HIOSH Work Standard were Imposed on the industry, Two major monomer producers agreed that the best in engineering, design, and operation of a monomer plant will likely reduce emissions of vinyl chloride to a level of 5 ppm IWA over eight hours equiva lent to a ceiling of 10 ppm. as now defined by the Temporary Stan dard. The 3ame survey showed that FVC suspension producers new believe Chat a realistic present goal for plant operations Is 25 ppm VCM using a TWA over eight hours or a 30 - 40 ppm ceiling; - achievement of this goal is certain to take both time and signi ficant added investment. C. The producers need a basis on which to standardise monitoring and sampling procedures to permit comparisons on a sound basis. Eighteen companies are using presently the carbon absorption tube 'technique while Six report using the air-bag approach to obtaining air samples measuring employee exposures. Much of the data are TWA based and the Temporary Work Standard leaves opent the possi bility for substantial variance in methodology, making It unlikely that the data now being compiled in individual plants can be com pared across the industry. D. Firestone will likely confirm the finding of a case of liver angio sarcoma in a workman with an estimated seventeen years of service in PVC operations. E. There is a growing recognition that emission levels and the steps needed to abate VCM passing to the environment are substantially different for plants manufacturing re3in by the solvent, emulsion, dispersion, suspension and bulk polymerization processes; that the Industry Management Committee should press for VCM tolerances that ' will permit continuation of the FVC process exhibiting the highest levels of emission when properly designed and operated to minimize escape of monomer to the atmosphere; emulsion and dispersion plants ucc 005024 -4- Aprll 19, 1974 re likely the processes which will be most difficult to bring into line, particularly if the work standard is designed primarily on Che experience in PVC suspension resin operations. F. The revised Work Standards as prepared last week by Mr. K, N. Wheeler and his associates have broad acceptance by Che Industry Management Committee, The proposed level of 0.1% maximum monomer in PVC resins will remain difficult for certain producers, parti cularly in manufacturing certain low molecular weight hamopoiymers and copolymers by the suspension process and certain grades of homopolymer by the bulk process. There is a feeling that a toxicsubstance warning label may be required for all resin having a monomer content above some ceiling level; no label for resins having less than the celling level; the dividing concentration may be 0,1% monomer based on wt. of resin. G. Organization Resource Counselors (DRC) will likely present a pro posal for a survey of employee health in fabrication plants con verting PVC resins; a cause-of-death review is to be included in the proposal now expected from the School of Biblic Health, George town University. H. FDA is expected to issue a temporary standard on vinyl plastics used on critical applications including food, feed, drug, cosmetic and medical apparatus. The likely levels of VCM will be 1 ppm in the surface in contact for flexible packaging; 10 ppw in the surpackaging; 4P PPb extracted into the test fluid for both flexible and rigid packaging. I. CBS has approached Vittone (Goodrich) and Harding (SPI) relative to Industry cooperation in the preparation by CBS of a TV docu mentary on the VCM problem. Certain agencies of Government have identified for CBS industry people who are thought by the agencies to be particularly knowledgeable and, thus, good candidates for participation in preparing the documentary. Our Dr. C. U, Dernahl is reported on the list of knowledgeable persona. The Industry ^ Management Committee urges industry-wide discussion before anv member company agrees to participation. J. My feeling now is that the Department of Labor (OSHA) is unlikely ' to set Work Standards that will shut down the PVC resin industry; that no revised temporary standard or final permanent standard will be pushed that would force an immediate cessation of PVC resins nationwide. Rather I anticipate that OSHA. will impose on the in dustry the toughest standard that the industry can tolerate in 1974, with the provision that the exposure limit be progressively reduced stepwise year-by-year until the absolute minimum level is achieved. Concurrently, I would expect the requirement for a continuing re view of employee health to assure Chat the improved operating condi tions within the workplace atmosphere reflect in lessening health problems among FVC workers. Yet to achieve even this type of regu lation court action may well required. ABS:ml A, B. Steele ucc 005025 DISTRIBUTION list E. BELL G. P. BIGELOW T. W. CARMODY . J. L. CARVAJAL C. E. COLWELL R. A. DECOUDRES D. E. DEESE C. U. DERNAHL, M.D, M. S. EISENHOUR D* L. ENGLE R. L. FRANTZ J. E. GIFFIN R. E. GRAEBERT G. J. HANKS R. J. HANNA R. J. HUGHES E. Q. HULL V. L- LARSON J. B. LEVERTON A. W. LUTZ W. R. MANNING Q, T. SCOTT R. W. WESSON R. N. WHEELER J. W. WHITTLESELY D. L. WILEY UCC 005026