Document BRgpk6gq3kLR0YVwNdgOaMwgX

4^0e)uxi g9 HTX a jK U"M4 [ti5*0u _ [6 received Date 27 August 1980 INTEROFFICE MEMORANDUM AUb fc b iS&U Subject Company Medical Audit Audit No. 80-244 To From L. G. TepperR. E. Bennett Corporate Medical (Location. Organization, or Ooartmant) Internal Audit (Location, Organization, or Oapartmant) cc: J. 0. Ballker J. T. Barr A. D. Bizzarro M. R. Chmura D. H. Davies R. E. Jones A. H. Kaplan G. E. Maurer J. F. Posch R. H. Schenck ' Attached Is the report resulting from our Company Medical Audit. In accordance with standard practices, we ask that you respond to the recommendations of this report In writing within thirty days Indicating actions taken, actions planned and expected dates of completion. REB:pmg Attachment f? (320) ] AP00031409 (A l^fo^AcducQ) 6ATU$s0dU+A AUDIT NO. 80-244 AUDIT REPORT TO ____________ L. B. TeDoer FROM R. E. Bennett AUDIT OF Company Medical Audit BY R. R. Brown DATE 27 August 1980 COPIES TO \ * J. Baliker J. T. Barr A. D. Bizzarro M. R. Chmura D. H. Davies R. E. Jones A. H. Kaplan G. E. Maurer J, F. Posch R. H. Schenck I. Introduction and Scope The Internal Audit department recently completed a corporate medical and chemicals manufacturing operational audit dealing with OSHA com pliance to vinyl chloride monomer (VCM) requirements at our polyvinyl chloride (PVC) plants. Our objectives were to: 1. Determine the extent of company compliance to OSHA requirements. 2. Evaluate the administration of the company medical programs relating to VCM. 3. Evaluate the effectiveness of the computerized systems which support our plant and medical staffs. 4. Evaluate the administration of VCM controls at our plant locations (Calvert City and Escambia). II. Summary While our audit revealed no OSHA violations at either plant, it is our opinion that certain existing conditions potentially could lead to Inaccurate record keeping and erroneous management decisions. Specifically, the conditions noted were: 1. The medical procedures for VCM are not being applied uniformly at our PVC locations. FORM 2100 (REV. 9/75) AP00031410 Audit No. Date 27 August 1980 CONTINUATION Page _______z 2. The computerized medical system which tracks medical data, physical scheduling, VCM exposures, etc. is not being fully utilized by PVC field locations. 3. A common interpretation of the OSHA requirements \for VCM does not exist among all areas involved in overseeing PVC operations. III. Detailed Audit Findings and Recommendations As a result of our review of the administration of our medical surveillance program at our PVC plants, we found that: A. Medical procedures are not being applied uniformly at our PVC locations. 1. There are no specific company policies or procedures Indicating when construction physicals are to be given or who should be getting them at our PVC plants. As a result, plant medical personnel are not sure all required physicals are being admin istered. 2. The format of the medical exam given to construction employees Is different at our two plants. Calvert City uses several of the forms that are used for our own employees. Escambia uses a one page physical exam form, specifically designed for con struction employees. 3. Calvert City perforins 5-liver function tests for VCM; Escambia performs 6 (OSHA requires 5). 4. The grounds for medically declaring someone unfit for VCM work are different. At Calvert City, any two abnormalities in the 5-liver tests constitutes unfitness. At Escambia, one abnormality in the 6-llver tests constitutes unfitness for VCM work. 5. The follow-up physicals for liver test abnormalities are different. Calvert City re-tests only the abnormal test(s); Escambia re-tests all of the 6-liver function tests and _ re-tests the person every six months for a period of 18 . ; ; ~ months. 6. Medical record retention is different. Calvert City main tains MIO input forms, lab tests, physician's statements of r fitness, and associated computer output. Escambia discards everything except lab tests and computer output. 7. FORM 2100-1 (REV. 9/75) For terminations, Calvert City retains the medical files. At Escambia, the medical files for terminations are forwarded to the Corporate Medical Department in Trexlertown. - .- AP00031411 Audit No. ________ ftfl-944 CONTINUATION Date 27 August 1980 Page______ l Recommendations Because of the above inconsistencies, we recommend the following: 1. The corporate medical department should establish and communi cate to the field uniform standards for the following areas at all our plants: - Guidelines on which construction employees will be placed under our medical surveillance program and when they will receive abbreviated physicals. - The format of construction physicals including forms to be used, scheduling of exams, and follow-up testing to be conducted. - Guidelines on liver tests to be conducted, criteria for declaring an employee unfit and follow-up testing for company employees. - Retention requirements for medical records by the plant for employees and contractors. Also, disposi tion instructions for files of terminated employees. B. The existing medical information systems are not being efficiently utilized. * ** 1. The medical exam scheduling list (report A3C220) can not be used at either plant because it contains inaccuracies relating to the current listing of persons requiring physicals. The inaccuracies are not the result of any systems failure, but rather are due to incomplete data input and file maintenance. For example: - 33 of 49 current PVC plant employees at Escambia do not appear on this report. -r - 43 of 182 total persons listed on the report for Escambia have terminated. - 8 of 149 total persons listed on the report for Calvert City have terminated. 2. The RAMADS system report (A3C505), which lists persons who entered a restricted area and whether they were/or were not authorized to do so is missing 50% of its total data because Calvert City no longer fills out the input form (regulated FORM 2100-1 (REV. 9/75) AP00031412 Audit No. _________ CONTINUATION Date ^7 August 1980 Page_______4 area access log-form 5583) which provides the data for this report. The remaining 50% of the report is currently being generated for Escambia since they still submit the Input form (5583) to MID. 3. The VCM monitoring/exposure report (A3C130) is incomplete because Calvert City forwards the input forms (form 5576) to Trexlertown before all the required information has been put on the form (i.e. respirator usage and type). 4. The medical system reports do not Include current contractor physicals. The medical exam scheduling list (report A3C220) shows 18 construction people at Calvert City. However, Calvert1s plant medical department has 53 contractors who have received VCM physicals as of May, 1980. Escambia's exam scheduling list shows no contractor physicals. Recommendations Since extensive amounts of data are either missing or incomplete in the medical systems data base, the exposure exists that all the medical system reports are inaccurate, and thus we recommend: 1. With the assistance of MID, all reports from the medical system should be reviewed by the appropriate level of management to determine if their continuance is warranted in their present state. 2. Steps should be taken to upgrade the completeness and accuracy of the medical systems data bases. 3. The medical system users should determine if they need the RAMADS system report (A3C505). ^ > 4. The appropriate level of management should determine if ^ contractor physical information is to be maintained on the medical system. C. Area monitoring controls are not applied uniformly at our PVC locations! 1. The existing PVC area at Calvert City was designed to operate es a non-regulated area, and as a result, people are entering the PVC area without signing a regulated area access log or being monitored for medical clearance to enter the PVC "plant. However, based on personnel monitoring data reviewed, indi cations are that VCM in excess of the permissible exposure FORM 2100-1 (REV. 9/75) AP00031413 Audit No. ________80*244 CONTINUATION Date 27 August 1980 Page____ 5 Unit 0 ppm In 8 hours r time weighted average or 5 ppm In 15 minutes - time weighted average), is being experienced in certain parts of the Calvert City plant and thus those areas should be regulated. At Escambia, the PVC ar?a Is regulated and the access log is still used. Also, a fence surrounds the PVC area at Escambia. Calvert City has no barrier surrounding their PVC area. 2. Area monitoring is required per the OSHA vinyl chloride standard-29 CFR 1910.1017 (g) (6) (ii). At Escambia, area monitoring readings are taken every 15 minutes by gas chromatographs. The readings are recorded on strip charts and are also evaluated and documented immediately by a minicomputer. At Calvert City, the gas chromatographs take readings every 20 minutes. However, the readings that appear on the strip charts are not evaluated until the following day. Calvert City's minicomputer could be used to perform this task with greater speed and effi ciency but Is currently not in use. Recommendations Because of the above Inconsistencies, we recommend the following: 1. Those areas at Calvert City that have exhibited exposure readings in excess of permissable limits should be identified in order that appropriate measures can be taken to restrict access to such areas to authorized personnel only. Also, other appropriate access controls should be reinstituted. 2. The appropriate level of management should determine how area monitoring is to be handled (i.e., manually or com puterized) and develop a plan to accomplish such monitoring. Such a plan should be coordinated between plant and support groups to ensure that it will adequately address OSHA requirements for VCM area monitoring. All of the assistance provided by chemicals manufacturing, corporate medical, legal, and the plant staffs at Escambia and Calvert City was very helpful and greatly appreciated. FORM 2100-1 (REV. 9/75) AP00031414 JL: v i / I \ R. E. Davi s B. 0. Helms J. W. Gentile J. c. Novak H. J. Smith E. K. McIntyre CALVERT CRY PVC PLANT GROUP SAFETY ASSISTANCE ACTIVE PROJECTS STATUS REPORT AS OF 44- MARCH 1960 J*.' PROJECT NUMBER PROJECT TITLE 1* Self-contained Breathing Air for lab use during collection of YCM gas and liquid samples. RESPONSIBILITY W. H. Stermon TARGET DATE 03/28/80 2* Requirement for personal protective equipment by all persons in/around collection of YCM gas and liquid samples. 3* Respiratory Protection Program for laboratory. W. H. Stermon 03/29/80 W. H. Stermon 03/29/80 4 Use of Lab Hood. W. H. Stermon 04/01/60 * These Items (1, 2, 3) were to require temporary suspension (Not done). RECOWENDATIOMS/ACTIONS TAKEN/STATUS 2 Scott Sling-Pak IIA's or equivalent and breathing air tank refil ling station recommended by H. J. Smith on 2/22/80. Not ordered as of 2/28 since air line resp. hook-ups to be installed, jmg recommended purchase anyway since this would give lab flexibility if other areas become identified for additional sampling. CE written by Stermon. Approved through Bob Lomlcky as of 3/11/80. r. a. r>v^ 3V-, r r .17 n ,neSo, . Tfr.-' < Respiratory protection (Project No. 1 above) plus impervious gloves and impervious coat or jacket recommended by H. J. Smith on 2/ZZ/80. Procedures not fully implemented as judged by observation of VCM rec. non. sampling and seal water sampling techniques on 2/26/80. Gloves and coat in use but not respiratory protection. CE written by Stermon and approved through Bob Lomlcky for respiratory protection as of 3/11/80. Ve, < -w ^Tvlrv-. /-.*- - , . Program to satisfy OSHA 29 CFR 1910.134 requirements recommended by H. j. Smith on 2/22/60. Training session conducted on 2/28 by J. U. Gentile. Agreed to purchase 2 Sling-Pak IIA's, establish cleaning, inspection and storage procedures. As of 3/11/80, cleaning, inspection and storage procedures to be implemented upon receipt of the Sling-Pak IIA's. ............ ... 1 *' VCM sample preparation and pH analyses recommended to be performed in side the hood by H. J. Smith on 2/22/80. Sample prep, and pH analyses confined to hood as of 2/27. Liquid sanpling valve for GC on order. Valve to be received and In use by 4/1/80. j, , . -Jr r Z..M ! i i. pf4 /r'~> r~Tr.,y n - jz-ers ">rny /*/ rMr /Vc--r. AP000314I5 AP00031416 Page 2 of 6 CALVERT CITY PVC PLANT GROUP SAFETY ASSISTANCE ACTIVE PROJECTS STATUS REPORT AS OF U MARCH 1980 PROJECT NUMBER PROJECT TITLE RESPONSIBILITY TARGET OATE RECOHHENPATIONS/ACTIONS TAKEH/STATUS 5 Upgrade of Lab Hood. W. H. Sternon A. 03/28/80 A. H. J. Smith recommended the following on 2/22/SO: provide 125 fpm Minimum face velocity with sash fully open via higher capacity fan, air volume to be reduced to 1,000 CFM (approx.) via sash half open; makeup air to be provided. 8. 02/29/80 B. In interim: thoroughly clean/repair; adjust upper and lower plenum slots so that they are 3/4 closed; block off bypass grating above the sash and lower portion of hood (between sill and shelf}, leav ing the space below the sill open; reduce face opening to 2.5 I square feet by reducing width via plexiglass panels. Completed. C. 04/25/80 D. 03/13/80 C. J. W. Gentile recommended replacement of blower motor with an explosion-proof model. W.O. for maintenance or engineering eval uation to be written by R. J. Lomicky on 2/29. As of 3/11/80, engineering evaluation completed. Replacement motor to be purchased and Installed, * * .O.Mr.fv .... . irv,r M-'WWB O. E. --.-ic.'-jC-L' wlT-.e-J' c' er . 0. J. W. Gentile recommended purchase of a Dwyer vaneometer or equiv alent for routine monitoring of lab hood performance on 2/26/80. Purchase requisition written on 2/27/80. P.0, issued on 3/3/80. Dwyer vaneometer received on 3/13/80. Checked out. Functions O.K. Coaipl eted. 6 VCH Gas Sampling P. P. Aqulla 03/14/80 Stainless steel cylinders (one end to sample valve, other end to closed system), tubing connections as short as possible, gas holder sample connected to fugitive emissions system, 4 gas sampling points in mon. rec. system connected to knock-out pot, sampling points to be more ac cessible, all recommended by H. J. Smith on 2/2Z/80. Cylinders received 3/7/80. In use by 3/14/80. 7 Works-Wide Clearance Work Permit Procedure R. E. Davis 03/24/80 Procedure drafted, reviewed and signed off by E. K. McIntyre and J. J. Baiiker on 2/25/30. Training sessions to explain began on 2/26/80. C.C. Safety Dept, to obtain rubber stamps In order to implement. Tar get date is dependent upon receipt and distribution of the stamp. I AP00031417 p Page 3 of 6 PROJECT NUMBER 8 PROJECT TITLE Leak Patrol Program 1 9 YCH Regulated Area 10 Catalyst Freezer Room CALVERT CITY PYC PLANT GROUP SAFETY ASSISTANCE ACTIVE PROJECTS STATUS REPORT AS Of 14 MARCH 1980 RESPONSIBILITY A. F. Cantor TARGET DATE A. 04/11/80 B. 03/24/80 A. F. Cantor 04/21/80 A. F. Cantor 04/07/80 RECOHHEHDATIQHS/ACTIOMS TAKEM/STATUS A. Program reviewed and walk-throughs made with John Powell by HJS week of 2/18 and JUG week of 2/25. S. Brunswick Leak Patrol Pro gram and reporting reviewed with Powell on 2/25 by JUG. Leak patrol area and point measurements recorded during 2/27 patrol. Revised program similar to S.B.'s presented to Lou Toney and Boyce Heims on 3/11/80. Lou Toney and Joe Gentile to revise and reissue by 4/1/80. B. Authority to order resp. prot. use and evacuation or radio conmo. w/supervision and -immediate follow-up recommended to Dick Davis by JUG on 2/29. Based on evaluation of leak patrol data and walk-throughs during leak patrols, JUG conducted a survey on 2/28 with Duane Hawes, Safety Super visor, for the purpose of defining boundaries/control actions. Yellow chain and posts and their positioning outlined for Hawes. A plot plan with the boundary indicated needs to be presented to Cantor/Helms so that agreement can be obtained. Ponds on south side of plant and con struction access road need to be addressed. As of 3/13/80, Works manage ment decided to discontinue the use of the Sagalin (access) roster and enforcement of the "45 minute rule" until area personnel monitoring indicate the need. Evaluation to be made monthly beginning 4/21/80. Door tied open with tube-turn closure 0-rings. Identified by JCN/H0S during week of 2/18. Status the sane as observed by JUG week of 2/25. Recommendation to Cantor from JUG on 2/29 to strictly prohibit and posting of signs on both sides of door to inform employees to "Keep Door Closed". 0-rlng removed by 3/10/80. Temporary sign placed on door by Duane Hawes. Frank Saul to order permanent signs. Page 4 of 6 PROJECT NUMBER 11 PROJECT TITLE Red Warning Lights In Poly. Building 12 Laboratory Sampling fn Remote Areas of Plant 13 Lockouts of Switches in MCC East of the Poly. Bldg. 14 Additional Sampling Points CALVERT CITY PVC PLANT GROUP SAFETY ASSISTANCE ACTIYE PROJECTS STATUS REPORT AS OF 14 MARCH 1980 RESPONSIBILITY A. F. Cantor W. H. Stemon R. E. Davis R. E. Davis TARGET DATE 03/07/80 04/07/60 A. 03/24/80 meetings B. 04/24/80 corrective action 03/21/80 RECOMHENDATIQHS/ACTICNS TAKER/STATUS Plant Inspections made by HJS during week of 2/13 discovered lights (3) blocked by transite siding (installed for freeze protection). JWG recom mended to Cantor on 2/29 to relocate lights or remove siding. Lights visible as of 3/11/80. Completed. Need for portable light source and radio identified at 2/28 resp. prot. safety training session. JWG recommended to Stemon to support his re quest for these items. As of 3/11/80, explosion-proof flashlight in use. CE written by Stersion for radio. CE approved through Bob Lonrfcky. During observations made by JWG week of 2/25 noticed attachments for locks, some of which were bent. Recommended to Davis that he review with operating and maintenance personnel and take corrective action which might Include modifications to attachments so they can't be bent. Also, strong discipline will be needed to demonstrate management's commitment. Laboratory technician sampling of seal water of Kash Compressor from the monomer decanter and from recycle pump for recovered monomer ob served by JWG during week of 2/25. Recommendations to Davis on 2/29 for: closed system loop, lighting and check of electrical bonding/ grounding at recycle pump sampling point; closed system loop at seal water sampling point. Sketches completed 3/3/60. W.O. far Nash Com pressors issued by 3/4/80. Work initiated on recovered monomer sample; however, unsatisfactory as of 3/10/80. JWG reviewed with Bob Hall. Mall agreed to: ensure lighting is provided, ground plastic lines or replace with stainless steel, number valves, draft a valve use procedure. Modifications to the seal water point completed as of 3/14/80. f AP00031418 Page 5 of 6 PROJECT NUMBER PROJECT TITLE 15 Chromatograph/ Computer Use. 16 VCM Canister CALVERT CITY PYC PUNT GROUP SAFETY ASSISTANCE ACTIVE PROJECTS STATUS REPORT AS OF 14 MARCH I960_ RESPONSIBILITY A. F. Cantor TARGET DATE 09/01/80 A. F. Cantor A. 3/21/80 B. 3/23/80 C. 04/13/80 0. 03/21/80 E. 03/24/80 RECOMMENDATIONS/ACTIOHS TAKEN/STATUS During weeks of 2/18 and 2/16/80, It was observed that the chromatograph and alarm system does not function effectively. For example, several (If not all) lights cone on when only one should. Also, no time-weighted average nor peak concentrations per point are being determined. As of 3/7/80 a CE was drafted for a system to alarm (one point at a time) at 1 ppm and 1,000 ppm with computer analysis for calculation of TUA's and peak concentrations. Need verbally confirmed by Dick Fleming during his 2/29-3/1 visit. In interim, woman hired by Boyce Heins to perform manual computations. To begin work week of 3/17/80. C7.C --L-t f--> -jr-llje rrt> i 7 ,->liwc 'H . ir .*'' - ... r-7 . ' '1 On 3/11/80 JUG recommended the following to Bob Kail : A. Strategically locate HJOSH-approved canister gas masks throughout the plant for work in areas above 1 ppm but still on-scale on the chromatograph (10 ppn max.) since the canisters are good for exposures not exceeding 25 ppm. >' " ; 11 ' 8. Require all users to turn In the canisters Immediately after use to their shift foreman who should tnsiedlately replace any used canisters. /- '*>' * * ' '>'' ....................... ' C. Establish periodic inspections to insure the canisters and face pieces and hoses are maintained in a sanitary, serviceable con dition and are located In their designated locations, a.-- t..-, r H . - r ,,, . 0. Conduct training for all potential users in the capabilities, limitations, conditions of use, and maintenance of the canister gas masks, On 3/12/80 JUG recommended the following to Tony Carter: E. Improve housekeeping in the respirator storage shed west of the maintenance shop. Aisleways are not maintained and stock Is very dlffiCUl t tO locate. C Inurrn; / i fcMf ^ fff p rre rr r> t/**- ' r--. a.'<- * ' r-*/ >t a ?/*>: i AP00031419 'Pf*% ' :V` i * Pago 6 of 6 PROJECT NUMBER PROJECT TITLE 17 SHWPS on Vinyl Chloride 18 Process Area Fire Water Deluge System 19 DMF Cleaning (Final Rinse Water Hand!ing) CALVERT CITY PVC PLANT GROUP SAFETY ASSISTANCE ACTIVE PROJECTS STATUS REPORT AS OF 14 MARCH 1980 RESPONSIBILITY TARGET DATE F. 03/25780 A. F. Cantor 06/15/80 A. F. Cantor 03/21/80 A. F. Cantor 03/21/80 RECOMHEMDATIOWS/ACTIONS TAKEN/STATUS F. Determine the expected Mage rate for the VCM gas mask canisters and order/establish a reorder frequency (purchase information can be obtained from plant safety department). 3<r' *r' TM tF-T T>. Group safety drafted and reviewed with B. D. Helms and R. E. Davis on 3/12/80. Format to be revised, procedures more specific, and safety procedures added with reissue, as revised draft, scheduled for 4/1/80. Deluge system selector and alarm switches observed in "off" position at various times during week of 3/10/80. JWG recommended to A. F. Cantor; a) enclose the selector and alarm switches in plexiglass, hinged, lockable enclosures and b) lock the enclosures, keeping the key under Cantor's control. Note: Switches should be in the "auto" and "on" positions always unless authorized otherwise by Cantor. <*t*At*rr 4 m/ ? r |*T\ p i I -i hrr,w(i, r '4* JRG reviewed unnecessary release of DMF and VCM during draining of hot DMF final rinse water to sewer with Cantor and Szulczewski on 3/13/80. W.0. written to install Canlock fittings with flex-hose to sewer on all 6* drain (dump) valves JV-1123 through JY-1423. *!,. Ad c / vc. I". 4 AP00031420 . it, rz ,^4ov-" '-l f P.O. BOX 939 ALLENTOWN, PA. lttOS PHONEl 219*391*4911 from the desk of Joseph W. 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