Document DmewB3vzwZ7aQ6Dkq0dqONrd

\ /,' r' * / i . rr".} .,`^1 A TTy^T T\A 'w KKbAhTdbXV OK l.'KAJ/nS, hbh'CATJOX, AN'i) \ run k rvw.i i: vj.kVit.i. f.Ta;-, tor. f/jsij-.ui. TO i Ar.53st.int At-Cl'. tar/ oC bebor fwn> YiAK lj 13'/4 Occupational V>A oty and Health Adoirnmiration bepart-(v_ni: of. .mhof IT', CM : birccfor, Knf-5 ; nal Institute for Occupational hoiciv and Health V snorter-. He omen endof! Occupational Health Standard for the Manufacture of Synthetic Holy:;,or from Vinyl Chloride On January 22, 1974, representatives from the Th F. Goodrich Chemical Company informed KIOSK that the deaths of several employees of their Louisville, Kentucky, plant night have been related to oceupaticn.nl exposures* An immediate" industrial hygiene ualk-Uirough survey of the. facility cos conducted by KIOSK one resulted in developing end trensritting to affected ccnpsnics recover,erberd oss for precautionary Eonitoring end control procedures for polymerisation processes involving vinyl chloride. On February 1, 1S7A, K1.0SK/CHC conducted a briefing for other Federal agencies vith health research tcspnnsibilitiea at which it vns disclosed that four employees of the plant in Question had died of angiosarcoma of the liver, because of the extremely Ion* incidence of this disease, estimated to he cn the order of 20 to 30 deaths per year in the United Seal os, the history of four cases in a five-vent1 period in one plant van considered of`great importance. It vac .concluded at the briefing that a rev occupational cancer bad been discovered: angiosarcoma of the liver. It v.y.s further concluded that tills disease kss associated vith the ranufaeturc of polyvinyl chloride and that vinyl chloride was the prime etiological cecdidate in producing the disease, KIOSK, vith the assistance of export consultant;; from both industry l t . and organised labor, began development o a re comeneed occupational hc-nlih standard. These end other activities mere discussed in r.erc detail at the OlKA Informal Feet-Finddug bearing on Forcible Hatarus of Vinyl Chloride HenuractuTc sr.d Use on Fahrunry IS, 1974. It v'os also during this bearing that Professor Keanre Mslsroni of KoXopna, Italy, prc.-r.cn ted the preliminary results of his research v?hich honed induction of anrAm-nrrcn/i of the .liver and other organs, as veil os .the -product, i on of other cancers in rots caponed to vinyl e3;loride. The results o there studies identify vinyl chloride os a carcinogen and further confirm its role in inducing the cancers observed in the 33. F. Goodrich corkers. < AS I 00023529 huge 2 ~ Assistant Secretary of Lsbur, OCHA Since the. 05! 1A bearnn;, biogg ]\ar> learned of r.t least five; additional Cases of cngioxnrcnc.u of the liver. Two of there cases were diagnos ed in t.);o current working o*pu 1 at:ion cl the cant* Louisville facility, while Cite oi-htT three; involved si etc used vcrh'VS, one each irore the Lou i ;'v i 1o facility, Union Car bine's Sooth Charlestown plant, and Goodyear's Niagara plant. Although vinyl chloride must bo considered an a carcinogenic agent > the ii-nediote problem appeared to be concentrated in polymerisation facilities. Consequently, the attached 'i'lOSU recommended standard only applies to turn operations. This is not to soy, however, that appropriate standards SlfO\ 1 A not be developed for other exposures to the basic chemical, h'lOSh is ie.pl erven tins; further evaluation of the data, coupled vr.lth field observations, to determine exoosure potentials in pro-, and post-polymerisation operations, You will be informed as further data and plans are developed. As previously indicated, };103k considers this to be a most serious problem and strongly urges that expedited rulemaking be implemented by OS31A to insure that the health of exposed workers is promptly and adequately safeguarded. Ke feel that, except where employers experience problems in obtaining riir supplied respirators or environmental monitoring equipmentthe attached recommendations can be implemented as soon os a standard in promulgated. The medical surveillance requirements which `."ill be supplied in one to two weeks could also be imp 1 cm on ted immediately with the possibility that sons employers would 'need a short period of time for their medical staff or consultants to irP.c arrangements for any special laboratory tests. You should he aware that the consultants from industry who worked with us proposed that the recommended standard contain the concept of an allowable "working level" for- vinyl chloride gas in the atmosphere, which they identified as a tins weighted overage of 50 ppm. They, recommended that where workers were exposed to concentrations in excess of this level they should wear air-supplied respirators. This concept of an allowable "working level" reignt seen justifiable in that iTofcssor Milt on i found no liver tenors at 50 ppra, but there in tho possibility that turners might have been produced if a larger number of animals had been exposed ox that concentration) Based on theoretical considerations, there is probably no threshold for cai'ciuogcnchis although it is possible that with very lev; Concentrations, the lafancy period aignt he extended beyond the life expectancy. "In view of these, considerations and our inability to describe a safe exposure level as required in portion 20(a)(3) of'the Occupational Safety ar.u Vrslth Act. we rejected the. concept of a threshold limit for vinyl Cniori.de gas. in the atmosphere, . AS i 0023S30 Co asequontly, our recces: on doticns as contained In the attached document each that vhere any employee ic; c7.00001} to rancurable concentrations cf: vinyl chloriiddes,, as deter;-jir.au by the roco; re the.;'., he r, 11 veer on ni r supplied renpir based on sor: pc cl shun ary 3 r.f erratic;! that t a inefficient in protecting eg is ir.pl cm eating a study to evaluate the decree ox protection afforded by cliff arena types of respirators us in 3 vinyl chloride as the rest gas. As infcroation becomes available, it vrill be foruarded to OSHA as rcco3rcandatior.s Ter alternative respirator usage. The employer is also requeued! to develop a Control Plan to reduce airborne concentrations c vinyl chloride to levels not detectable by the rocotrt-cndcd n&thod. As you mill note in rcvxc"-ring the recorrr ended standard, there arc references to the '''sampling and analytical netted re carat ended by the Director,1' This ticthod, in the fern ox a compliance sampling data sheet, vri11 be fonrerd' ' to 0S11A vithin a week, lie nov estimate that the level of sensitivity ' our recommended method viil be around one part per million, specifically for vinyl chloride. The Office of Research and Standards Development, vhich is directed by Ur. Vernon E, Pose, has had lead responsibility in developing this recommended standard. As your professional staff review "Md evaluate our document, questions or requests for additional information, should, be directed to Hr. Dose, V" /S /- / 'll&vcvs li* Key, Vi,Cif7 /assistant Surgeon General Attachment AS I 00023531