Document By8bMKXNjeLm5m2nVd915RN28

I7 INTERNAL CORRESPONDENCE CHEMICALS AND PLASTICS TO (NAME) Ml*. J. B. Leverton COMPANy LOCATION Texas City Plant COPY TO Mr. D. E. Deese Mr. M. E. Eisenhour Mr. W. A. Mazzolini Mr. F. S. Provenzano Mr. R. N. Wheeler, 514 subject 3 M Brand Vinyl Chloride Respirator No. 8716 Dear John: This letter with its attachments from the 3 M Company follows up on my letter to Mr. D. E. Deese of November 24, 1976, on the same subject. As you can see, 3 M has obtained OSHA approval (of sorts) for use of their half-mask respirator in VCM concentrations up to 10 ppm for two hours. As I indicated in my earlier letter, these masks would be useful for us in light VCM exposure situations. However, before ordering any for use in the Suspension PVC Unit, I'd like U/A from your department. As I understand the directive, OSHA states that the respirator is acceptable for two hour use in atmospheres up to 10 ppm VCM, but they also state on Page 2 that use of the respirator shall be cited de minimus, which I interpret to mean a non-serious, no fine citation. Would you get something from our legal people on this. I do know that other PVC producers, notely B. F. Goodrich, have been using for a year or more half-face respirators in atmospheres up to 10 ppm VCM on the basis of a letter written to B. F. Goodrich by an OSHA official. A prompt reply is requested. Very truly yours, RLF/st Attachments \ R. L. Frantz UCC 091999 GENERAL OFFICES 3M CENTER SAINT PAUL, MINNESOTA 55101 TEL. (619) 733-1110 January 19, 1977 Union Carbide Corporation Mr. R. L. Frantz Production Department Head P.O. Box 471 Texas City, Texas 77590 Dear Mr. Frantz: On Monday, January 17, 1977, the Assistant Secretary of Labor for OSHA signed a field directive to all inspectors instructing them not to site any company using the 3M Brand Vinyl Chloride Respirator No. 8716 to protect employees from vinyl chloride monomer at concentrations up to 10 ppm. The 3M Respirator is a half-mask, valveless, self-indicating respirator designed specifically for vinyl chloride workers. Completely disposable, it will eliminate costly respirator inspection and maintenance programs. Attached you will find a copy of the program directive covering the 3M Vinyl Chloride Respirator. For more information, contact your closest Occupational Health and Safety Products sales representative listed on the attach ment or call (612) 733-8465. Sincerely, WPH: 1 Attachment W. P. Herris Market Manager Occupational Health & Safety Products Department miNNESOTA miNING AND MANUFACTURING COMPANY UCC 092000  2- In addition, the employer should maintain a written record of employees using the respirator and the amount of time that each respirator is worn. 4. Action. Citations should be Issued under Section 1910.134 as necessary. However, until final certification by NIOSH, the use of the 3M respirator (Model 8716) in 'nyl chloride atmospheres of 10 ppm or less for periods not exceeding two hours per respirator shall be cited as de minimus. 5. Effective date. This directive will become effective immediately and will remain In effect until NIOSH tests the respirator and issues its conclusions, or until revised or modified by OSHA. UCC 092001 i = 11/ the Atiutaot Seiretary U.S. DEPARTMENT OF LABOR Occufunorul Safety and Health'Administration ' WASHINGTON, OC 10210 l 9 JAN WJ MEMORANDUM FOR REGIONAL ADMINISTRATORS AND AREA DIRECTORS Thru : Donald E. Mackenzie, Acting Director, Field Coordination From : Morton Corn, Assistant Secretary of Labor Horton Cc. Subject: Use of the 3M Cartridge Respirator (Model 8716) in Vinyl Chloride Atmospheres 1. Purpose. To provide guidance concerning the enforcement of Section TgToTTOl7(g)(4) as it relates to use of the 3M cartridge respirator, 2. Directives Affected. None 3- Background. Section 1910.1017(g)(4) requires that respirators used in vinyl chloride atmospheres be approved by NIOSH. To date no respirators for 10 ppm vinyl chloride or less have been approved. The 3M Company has developed a disposable cartridge respirator with a service life indicator for use in atmospheres of 10 ppm vinyl chloride or less. Because this respirator is not equipped with an exhalation valve, it cannot be tested by NIOSH, which requires an exhalation valve, until NIOSH's procedures are revised. In the interim, test data collected by the 3M Company concerning this respirator has been studied and 05HA h * conducted its own fit tests at the Los Alamos Scientific Laboratory. Based on the information from the tests which have been conducted, It has been determined that the 3M disposable cartridge respirator is acceptable for two hour use in atmospheres of up to 10 ppm vinyl chloride. As with any respirator, the degree of protection provided depends heavily on the adequacy of the respirator program, including the fit of the respirator and enforcement of the service life requirements. Therefore, the requirements of Section 1910.134, which contains the OSHA standards for a respiratory protection program shall be adhered to. Particular attention should be paid to the applicable requirements jf Sections 1910.134(e) and (f). * N V' r\ r UCC 092002 SALES REPRESENTATIVE BRANCH PHONE Jay C. Hickel James H,. Morgan Roger M.. Schmidt Paul E. Bryant Gary A. Huffman Richard J. Woods Paul G. Rogerson Charles D. Hough Lou G. Zeller Douglas F. Alley Leila M. Frogh Douglas D. Swenson William B. Maclndoe Jack N. Monarek Russell J. Loomis Carl W. Rogan Karl L. Moll Jerry H. Brennan Trent A. Niemeyer Atlanta Atlanta Boston Chicago Cincinnati Cleveland Dallas Detroit High Point Los Angeles Los Angeles Milwaukee Philadelphia Philadelphia St. Louis San Francisco Seattle Twin Cities West Caldwell (404) 449-6666 (404) 449-6666 (617) 449-0300 (312) 496-6500 (513) 242-2313 (216) 267-1800 (214) 327-7311 (313) 477-5000 (919) 886-7181 (213) 726-1511 (213) 726-1511 (414) 276-7377 (215) 742-0200 (215) 742-0200 (314) 991-1320 (415) 589-2663 (206) 224-7200 (612) 733-3300 (201) 227-9100 UCC 092003 8X00C2 SC002S 50Q0 D'2/23/77 [042/1045 TO WHOM; IT MAY CONCERN W- frbf /{y/n 4>?ho THE FOLLOWING STATEMENT IS BEING RELEASED.TO THE NEWS MEDIA AT 10;OQ A.M. -23-77 BY THE SOUTH CHARLESTON PLANT: WE HAVE JUST RECEIVED A REPORT THAT AUTOPSY STUDIES FOLLOWING THE DEATH EARLIER THIS YEAR OF A RETIRED FORMER EMPLOYEE OF THE UNION CARBIDE SOUTH CHARLESTON PLANT, ATTRIBUTE CAUSE OF DEATH TO ANGIOSARCOMA, A RARE FORM OF LIVER CANCER BELIEVED TO BE LINKED WITH LONG-TERM EXPOSURE TO VINYL CHLORIDE. THE RETIREE WAS 67 YEARS OF AGE AT THE TIME OF DEATH. HE HAD WORKED 28 YEARS AT THE SOUTH CHARLESTON PLANT22 OF THESE AS A VINYL CHLORIDE WORKER. THREE EARLIER ANGIOSARCOMA DEATHS HAVE BEEN DISCOVERED SINCE 1968. ALL THREE EMPLOYEES HAD LONG-TERM EXPOSURES TO VINYL CHLORIDE AT THc. SOUTH CHARLESTON PLANT. SINCE THE DISCOVERY IN THE EARLY 1970 "S THAT EXPOSURE TO VINYL CHLORIDE MIGHT HAVE AN ADVERSE EFFECT ON HEALTH, UNION CARBIDE HAS ACHIEVED SIGNIFICANT REDUCTIONS OF EMISSIONS OF THIS CHEMICAL TO THE AIR AND THE WORK ENVIRONMENT, AND IS COMPLYING WITH OCCUPATIONAL SAFETY AND HEALTH AND ENVIRONMENTAL PROTECTION AGENCY. REGULATIONS COVERING VINYL CHLORIDE. IN ADDITION, UNION CARBIDE CONTINUES TO CONDUCT PRIVATE STUDIES ON THE EFFECTS OF VINYL CHLORIDE EXPOSURE ON HEALTH, AND IS ALSO PARTICIPATING IN SIMILAR STUDIES CONDUCTED BY THE MANUFACTURING CHEMISTS ASSOCIATION. C. A. XEIL CHEWS SC Jt UCC 092004 l V