Document DpDNE8aBon82K33e79MnwnJB

THE CHLORINE INSTITUTE, INC. 342 MADISON AVE., NEW YORK, N.Y. 10017 ~,T: 212-682-4324 Melvin E. Clark, President J. Roger Hirl, Wee President Robert L MitcheK, Jr.. Executive Director Edmund J. Lautysch, Technical Manager September 21, 1973 Mr. Thomas E. Levenhagen Area Director, OSHA U.S. Department-of Labor Federal Office Building, Room 6j4 200 North High Street Columbus, OH A3215 ^ Chtorin* , and Suboan Dear Mr. Levenhagen: ' We appreciate the materials on the subject file whlch you haver us, most recently on September 5th. - As you know, the mission of ourlnstitute is. to promote _ __ ,,,, manufacture, transfer, packaging and use of chlorine; - While our membersl does not encompass chlorine consumers such as the Head Corpoir^tiV ^'producers whose output Is for captiveuse), our servlces-exte -^-concerned with chlorine safety.::? It Is, therefore, in such matters truly reflects arr industry. J. ___ _ ______ understanding of statutes and regulations derived therefrcto 6 We have read the contents of M4463~513 and the.assoclatednoticeofcontest; as related to 29CFR1926.103(a) [Regulations for Constructlonl -^Our^Inter^ pretatlon of Table 4, anent contaminants- immadlately dangeroueflto^Ilf^lor?? health. Is that it provides for mouthpiece re&pf'iritei*s`as protection means for escape purposes. We do not interpret' that In such - - cl rcumstances^jLjpvis lon_ for full facepiece respiratorsis mandated?^Jn- fact. It Is tfi&runlveraal position of thechIorineindustry;base<f years of experience and: evaluation, that the mouthpiece superior to the full facepiece respirator:in- protection in the event of an emission during the course of nonndl" wol*k operations.. Our reasons include: _. ^ * Facial features. In addition to hair and spectacles, make aitliT:.' : adequately tight fit of facepiece respirators essentially impossible. * Donning time for full facepiece respirators, particularly for the untrained and inexperienced, is too long for workers exposedta___ _ high chlorine concentrations; . C 003462 -5 vV: Continued... MON-2565 LAM023136