Document DvQKojreO7OXRoVg59R4114bM

MARKET STUDY PERSONAL MONITORING DEVICES AND THE #3500 ORGANIC VAPOR MONITOR Prepared for: Occupational Health & Safety Products Division 3M COMPANY St. Paul, Minnesota Prepared by: Marketing Service Associates, Inc. Pittsburgh, Pennsylvania January - May, 1980 CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3M 105S34 TABLE OF CONTENTS BACKGROUND ...................................................................................................... OBJECTIVE ...................................................................................................... PROCEDURE ...................................................................................................... CCMPLETED INTERVIEWS................................................................................. RESULTS OF USER INTERVIEWS.................................................................... Marketplace Awareness of 3M and the #3500 OVM..................... Extent of Involvement in Personal Monitoring .......................... Organic Vapors Being Monitored ....................................................... Organic Concentrations Being Monitored ...................................... Monitoring Expenditures .................................................................... Distribution of Resources Between Prevention and Monitoring ................................................................ Purchase Influencers............................................................... Personal Monitoring Equipment Encountered .............................. Perceived Advantages/Disadvantages: Pump Versus Dosimeter........................................................................ Analytical Service ................................................................................. User Preference for Distribution Route...................................... Personal Monitoring Versus Area Monitoring .............................. Personal Monitor Selection Factors ............................................... Factors of Product Quality ................................................................ Users' Attitudes Regarding NI0SH/0SHA Approval ...................... PAGE 1 3 5 9 10 11 11 12 14 15 17 19 21 24 28 30 31 33 35 38 CONFIDENTIAL MATERIAL SUBJECT 5q PROTECTIVE ORDER ii 3M 105S35 Technical Literature Considerations ........................................... Time Frame for Decisions to Use a Passive Monitor .... RESULTS OF DISTRIBUTOR INTERVIEWS ................................................... RESULTS OF GOVERNMENTAL AND CONSULTANT INTERVIEWS .................. Current NIOSH/OSHA Stance Regarding "Approval" ................. Summary.................................................................................................. Details.................................................................................................. Organic Compounds on Which Monitoring Activity Should be Expected to Increase ................................................... CONCLUSIONS AND RECOMMENDATIONS ....................................................... Recommendations ..................................................................................... PAGE 40 41 42 50 51 51 51 55 57 60 CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER iii 3H 105836 A MARKET STUDY OF PERSONAL MONITORING DEVICES AND THE MARKET POSITION AND OPPORTUNITIES FOR THE #3500 OVM Background The air breathed by today's worker is subject to contam ination by the products, byproducts, and raw materials which the worker is using and producing. These contaminates may be only a nuisance to the worker, but are increasingly being found to be ha zardous to the worker's health. Historically, the danger of the con taminate was first monitored directly by the nuisance level . . . and then, later, by the acute effect upon the worker (eye, skin, mucus membrane irritations). Then, various instruments were developed to detect the level of contamination and alert workers when a hazar dous level was reached. (Perhaps the first "instrument" was the live canary taken into mines . . . the "alarm" was the canary's death!) In the modern industrial age, acute effects were first recognized, and area monitoring systems were developed to sample, analyze, and report (alarm) the level of the hazardous substance in the ambient workplace atmosphere. Within the past two or three decades, very low concentrations (down to even a few parts per bil lion) of some materials have been found to cause health or reproduc tive problems 20, 30, 40 years later. Area monitoring was found to be insufficient to measure the exposure of an individual worker to these low levels, and methods of sampling the air breathed by the individual worker were developed. The system of personal monitoring gaining widest acceptance was the personal air pump and, for many -- but not all -- contaminants, activated charcoal to trap the contam inant for later analysis. The majority of the known or suspected hazardous materials are organics with sufficient vapor pressure to yield levels of concern in the air; and for most of these organics, activated carbon is a suitable "trap". But for other organics, silica gel or other absorbants are required. For particulate con taminates, seme means of filtration or impingement is used to trap the particles for analysis. And for various other contaminants, specific physical and/or chemical "traps" were developed. These various personal sampling pump systems have served well, but have required much personal attention of specifically trained personnel to maintain and use, and have been cumbersome to the individual worker wearing them. CONFIDENTIAL MATERIAL SUB] EOT TO PROTECTIVE ORDER 3M 105837 * 3M`s OH&SP Division entered the personal monitor market with a passive dosimeter for mercury. Unlike the positive, active pump which transferred and measured the amount of air being sampled, the passive dosimeter is based on the transfer of the contaminant . . . in this case, mercury vapor . . . across a diffusion membrane from the ambient atmosphere bearing some discrete level of contami nant into a chamber of "zero" concentration wherein the contaminant was immediately "trapped" by, in this case, a gold film and held for future analysis. Having successfully gained acceptance and use of the mercury monitor, the OH&SP Division introduced a similar passive dosimeter -- the #3500 OVM -- for organic vapors absorbable by activated charcoal. The principal target market was substitution of the #3500 OVM for the sampling pump and charcoal absorption tubes used in monitoring most of tne hazardous organic vapors found in the industrial workplace. The new business volume for the #3500 OVM has fallen short of the projected market growth curve. The present study was con tracted as part of a broader OH&SP Division examination of the rea sons for the slower-than-expected growth, and re-assessment of the market potential. CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER -2- 3M 10583S Objective The overall objective of this study was to profile the personal monitor market -- both pump and passive -- to detail an understanding of the marketplace perception of 3M's #3500 OVM, and to project the market potential for the #3500 OVM. Specifically, this study provides answers to the follow ing questions: 1. What is the marketplace awareness of 3M in the occu pational health and safety field . . . and what is the extent of familiarity with the #3500 OVM? 2. What percent of industry firms are doing personal monitoring? 3. What are the organic vapors being monitored? And, at what concentrations? 4. How much money is being spent for monitoring activi ties? How are financial resources distributed between monitoring and prevention? 5. Who are the "purchase influencers"? Are these the same people that influence the purchase of safety equipment such as protective masks, etc.? 6. What monitoring equipment is currently being used? 7. What are the perceived advantages/disadvantages of the pump-tube methods ... and of the passive dosimeter? CONFTDENTlALMATEBmL S'JBjCiC 1 TO PROTECTIVE ORDER -3- 3M 105839 8. What are the preferences for/against, and perceptions of, a central analytical service for personal monitor ing . . . such as that offered by 3M? 9. Do end-users prefer to purchase direct from manufac turers or through distributors? 10. What trends are anticipated in the "mix" of personal versus area sampling? 11. What factors are most important to end-users in their selection of the specific passive dosimeter to be pur chased . . . and how do they rate 3M on these factors? 12. What is the time-frame within which company decisions to use a particular passive dosimeter are made? 13. How do 3M's distributors see the '#3500 OVM market? . . . see 3M's development of the market? . . . and perceive the users' selection factors? 14. What are the regulatory factors affecting the #3500 market? ... and what trends or changes are expected? 15. What is the present and potential competitive activity? 16. What is the potential market for passive dosimeters and, specifically, for the #3500 OVM. CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER _4_ 3H 105840 Procedure This study was based on primary source interviews with known and potential #3500 OVM user-companies, with 3M distributors, competitors, and with others as will be described more fully at the end of this section. Secondary sources such as governmental documents and industry publications were consulted as the market potential was developed. A training meeting for the Marketing Service Associates, Inc. project team was conducted in Pittsburgh by Terry McClusky and Mimi Merino of 3M to familiarize the MSA project team with the pro duct, its competition, the market, and the requirements of the study. Subsequent to the training meeting, an interview guide was prepared by MSA and sent to 3M for suggested clarifications and changes. The overall guide was then partitioned into two guides: one for use in interviewing known and potential passive dosimeter users, and the other for use in interviewing distributors. These guides were "tested" in some preliminary interviews to assure that the questions and terminology would be understandable to the inter viewees. Interviewing was done entirely by Marketing Service Asso ciates, Inc. personnel ... no work was sublet to others. Those of us involved in this study were: CONFIDENTIAL MATERIAL SUBjECt TO PROTECTIVE ORDER -5- 3H 105841 Richard C. Andres: A.B. Economics -- Allegheny College; MBA -- Indiana University; 6 years -- General Motors in sales and marketing; 6 years -- Koppers Company in marketing research; 1 year as Manager of Marketing Research -- Rockwell Stan dard Corp. Formed Marketing Service Associates in 1961. James E. Thompson: B.S. Chemical Engineering -- Texas Tech University; 4 years -- New Product Development and Test Market Management -- Procter and Gamble; 7 years -- Environmental Research Management, Procter & Gamble. R. Dale Colby: A.B. Economics -- Allegheny College; 12 years in marketing research with Blue Cross of Pennsylvania; former President and current board member, Pittsburgh Chapter of American Marketing Association. William A. Pardee: B.S. Chemistry -- Emory University; PhD Chenical Engineering -- Yale University; former R&D Gulf Oil Corp. M. Whitney Greene; A.B. Economics -- Cornell University; MBA -- Harvard University.- Retired as Manager of Economics Research and Chief Econ omist for Koppers Company. Interviews were all voice-to-voice with the person(s) in each company most responsible for atmospheric monitoring in the work place. These persons were generally in the Industrial Hygiene or Safety Departments. Reception to our calls was excellent. In only six instances were interviews refused, and in most of these, the prospective respondent stated that they would answer a printed ques tionnaire should we send one (we didn't since sufficient other con tacts were available). The excellent reception was a result of two factors: First, interest in personal monitoring ... and particularly new CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3H 105842 -6- technology to simplify the process ... is quite high, and the re spondents were generally eager to talk. Secondly, 3M was identified as the project sponsor at the beginning of interviews with distri butors, with insurance companies, and with known and potential users (not with governmental agencies, consultants, nor competitors). This "open identification" cleared the air of any suspicion that the caller was from one of the respondent company's competition or from a regulatory agency. A positive future fall-out from "open identi fication" can be expected as a result of the respondent knowing the identified sponsor is actively concerned with the marketplace's needs and evaluation of the sponsor's products and services. A table of completed interviews is on the next page. The sample of end users was selected from a list of current accounts sup plied by 3M (25% of the end user interviews) and from manufacturing SIC lists (75%). While all manufacturing segments were sampled, 80% of the calls were concentrated in SIC's 28, 29 and 30 wherein the concern for organic vapors is concentrated. The distributor sample was drawn from a supplied list of 3M distributors carrying the #3500 OVM. Convergence of the results from the various responding cells was good. With consideration given to the number of comple tions in each cell, the market picture derived from one cell did not differ significantly from that derived from another cell. Of CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER -7- 3W 105843 particular note is the fact that no significant differences were found between the two subsets of the end user cell. Interviews of the known purchasers of #3500 QVM led to conclusions consistent with those reached from interviews of potential end users selected ran domly from SIC lists. CONFIDENTIAL MATERIAL LULjEUT TO PROTECTIVE ORDER -8- 3H 105844 COMPLETED INTERVIEWS RESPONDING CELLS NUMBER OF COMPLETIONS END USERS ...................................... I62W DISTRIBUTORS .............................. 37 COMPETITORS .................................. 8 INSURANCE COMPANIES ................. 4 REGULATORY .................................. 27 CONSULTANTS .................................. 4 SECONDARY ....................................... 16 258 (^SAMPLED FROM 20 TWO-DIGIT MANUFACTURING SIC'S; CONCENTRATED IN THOSE THAT SHOWED HIGHEST CURRENT AND EXPECTED FUTURE USAGE: SIC 28 -- CHEMICALS & ALLIED PRODUCTS SIC 29 -- PETROLEUM & COAL PRODUCTS SIC 30 -- RUBBER & PLASTICS PRODUCTS CONFIDENTIAL S4AT8RW- du TO PROTECTIVE OBDEH -9- 3M 105845 RESULTS OF USER INTERVIEWS CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3M 105846 Marketplace Awareness of 3M and the #3500 OVM Almost all of the user company respondents -- 97% -- stated that they were aware of 3M as being a company offering pro ducts in the industrial employee safety/health area. Only in five companies did we find no recognition of 3M being in this business. When asked concerning their awareness of the #3500 OVM, 78% gave a positive response. Not all, but most are aware of the product by "3500" . . . some required prompting by the interviewer's description of the purpose of the product. But those requiring prompting did then have a prior awareness of the 3M product as differentiated from competitive or just a generic awareness. Extent of Involvement in Personal Monitoring Of all the user firms contacted, 78% were found to be actively involved in personal monitoring for organic vapors. These companies had purchased same equipment and had at least a minimal monitoring effort. It is coincidental that this number -- 78% -- is the same as the percent given in the preceding section as the percent of com panies aware of the #3500 OVM. While the agreement of positive responses was very large, seme companies were involved in personal monitoring and not aware of the #3500, and others aware of the #3500 did not have any monitoring program in effect. CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3M 105847 -li- Organic Vapors Being Monitored Each user interviewee was asked to identify those organic vapors for which his company was concerned in its personal monitor ing program. Response in seme cases was rather guarded, but we were able to get at least a generic identification of the organics being monitored. Specific organics were identified in the majority of interviews. Those frequently mentioned are tabulated below, and, on the next page, have been added to the generic mentions from the interviews for an overall ranking of those generic groups most fre quently encountered. MOST FREQUENTLY MENTIONED SPECIFIC ORGANIC COMPOUNDS Benzene Toluene Methyl Ethyl Ketone Acetone Vinyl Chloride Styrene Formaldehyde Acrylonitrile 1,1,1-Trichloroethane Trichloroethylene Ethyl Alcohol 24% of User Cos. Monitor 24% 11% 11% 9% 9% 8% 8% 7% 7% 7% CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3M 105848 MOST FREQUENTLY MONITORED ORGANICS BY GENERIC GROUP Benzene and Derivatives 87% of User Cos. Chlorinated Hydrocarbons 57% Ketones 36% Hydrocarbons 28% Solvents 27% Alcohols 25% Acid and Low MW Organic Gases 23% Nitrogenous Hydrocarbons Ethers 20% 5% Aldehydes 4% -13- CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3M 105849 Organic Concentrations Being Monitored Respondents, for the most part, did not feel free to men tion or discuss the specific concentrations of organics being found in their personal monitoring programs. Most would say only that their levels were "at, or below, the allowable levels" established by OSHA. Of particular interest would be benzene levels . . . both because benzene and its derivatives were found to be the most fre quently monitored, and because of the soon to be handed-down decision of the U.S. Supreme Court (this case will be discussed in a later section). It was found that benzene levels are generally below the 10 ppm level (8-hour Time Weighted Average) adopted in 1970, but in many cases exceed the 1 ppm 8-hour TWA promulgated in the 1976 OSHA regulation that was set aside by a lower court and on which the Suprone Court is soon to rule. Should the decision be in favor of OSHA, therefore re-esta blishing the 1 ppm benzene level, the monitoring activity for benzene will increase ... at least for several months ... by several fold as companies that currently are doing very little monitoring pending the court's decision scramble to position themselves relative to the re-established regulation. -14- CONFIDENTIAL MATERIAL SLiijLCT TO PROTECTIVE ORDER 3H 105850 Monitoring Expenditures Each user respondent was asked to estimate the total expenditures for monitoring workplace atmospheres within his plant. From the responses received, it was obvious that expenditures for this activity are very infrequently identified and segregated within the overall industrial hygiene or safety departmental budgets. This lack of fiscal segregation suggests that costs are not a primary control of monitoring activities. Never-the-less, we pushed for the respondent's best estimate and did get a figure from almost all respondents. User expenditures, per plant location, run . . . Low $ 200 per year High 1,200,000 per year Median 20,000 per year. Based upon the discussion that normally accompanied these estimates, we have distributed the median expenditure as follows: Sampling pumps and other equipment $5,000 per year Non-analytical personnel costs allocated to monitoring 8,000 Tubes and other supplies 2,000 Analytical 8,000 TOTAL $20,000 CONnDBlTUU.MA1EHM.SUfi]tCT TO PROTECTIVE ORDER -15- 3M 105851 Respondents were asked how they saw the expenditure for monitoring moving within the next few years . . . Will be "up" . . . 83% of respondents Will be "down" 7% of respondents Will be "about the same" .... 10% of respondents. The reasons most frequently given for an upward trend were: 1. Expectation that governmental regulations will cover additional organic compounds (particularly chlorin ated hydrocarbons and ketones). 2. Increasing internal corporate "concern" for worker safety and/or for long-term corporate liability for occupational disease. 3. Expectation that the U.S. Supreme Court will rule in OSHA's favor on the benzene case. Those 17% of respondents that projected a downward trend or no change in expenditures had, in most cases, recently made sig nificant expenditures for sampling pumps or other monitoring equip ment and did not anticipate having to make that expenditure again during the next several years. -16- 3M 105852 Distribution of Resources Between "Prevention" and "Monitoring Respondents were asked to describe how the available funds were allocated between the functions or activities of: 1) preventing organic vapors from entering the workplace atmosphere; and 2) monitor ing the concentration of organics that were in the atmosphere. We found that this was seen as an "apples and oranges" type of comparison. At the present stage of evolving control of worker exposure to atmospheric organics, there is not a practical trade-off between the two areas. The desired end result is that workers not be exposed to more than the known "safe" or "regulated" levels. Money must be spent to determine, by initial monitoring, the exposure level under current engineering and housekeeping prac tices. If this level is higher than the "safe" or "regulated" levels, then funds must be allocated for engineering and housekeeping changes to reduce the levels. And, then monitoring is necessary to evaluate tha effect of the changes and to demonstrate that the new, reduced levels are satisfactory. While the respondents tell us that there is not a prac tical trade-off, as outlined in the paragraph above, there is a theoretical trade-off that in seme situations might be operative and would thus influence the expenditure of funds for personal monitors. The theoretical situation can occur when organic levels are found to be between the regulated permissible level and one-half that n,TAL material SUBIEC1 CO^TTl^ECTIVE ORDER TO PR'T -17- 3M 105853 level. OSHA regulations generally state that if the level (deter mined through monitoring) falls between the permissible level and one-half that level, then monitoring must be continued. If, how ever, the actual level is less than one-half the permissible level, monitoring may be discontinued until such time that there is reason to suspect that the atmospheric levels would have increased. Thus,-should a company find in a given situation that the monitored levels were within this range of 50 to 100% of the per mitted level, consideration should be given to the costs of further engineering or other "prevention" changes in comparison to the costs of continued monitoring. We believe that this "theoretical" situation trade-off will have an insignificant effect upon the personal monitor market. In the first place, the concentration range over which this situa tion occurs is a small portion of the practical range, over which actual concentrations may be found. Secondly, "reasons" to suspect that the atmospheric levels may have increased occur frequently. And thirdly, if a company finds that its organic concentrations are even close to the 50% of permissible level, good management practice would direct it to continue monitoring to develop the historical data needed to defend itself against potential regulatory agency or employee charges. -18- CONFIDENTIAL MATERIAL SL5/ECT TO PROTECTIVE ORDER 3* 105854 Purchase Influencers From both pre-interview screening, to arrive at the best person to interview in each user company, and from direct questioning during the interview, the department having the greatest influence on the type and source of personal monitoring equipment was deter mined : Department % of Plants IndustrialHygiene 50% Safety 30% Environmental Health 15% Medical 5% Frequently these departments are combined or closely linked. Just how closely is important to 3M's marketing strategy in light of the sales contacts and distributors used for protective devices (masks, etc.). Respondents were asked if the department responsible for personal monitoring was also responsible for worker protective devices: % Plants Yes,-Same Department...................................... 35% No, Different Departments.......................... 65% In those plants wherein the responsibility is not in the same department, the "Safety Department" has the responsibility for protective devices, and the Industrial Hygiene or other departments have responsibility for monitoring. In the few "snail" companies -19- CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3H 105855 interviewed, monitoring responsibility may reside with the plant manager even though other "safety" items are delegated. These data on purchase influencers suggest caution in relying, for #3500 OVM marketing strategy, upon distribution patterns that have been developed by 3M for the marketing of per sonal protective equipment. This potential problem has obviously not been overlooked by 3M, as evidenced by the 78% #3500 OVM "awareness" reported earlier in this report. CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER -20- 3M 105S56 Personal Monitoring Equipment Encountered Each interviewee was asked to identify the type and the man ufacturer of personal monitoring equipment in use in their plant. Of those plants doing personal monitoring (78% of the total contacted), 62% reported some brand of personal monitoring pump and n passive dosimeters in use. Thirty-eight percent reported using both pumps and passive dosimeters, but no company was found to be using only the passive dosimeter for monitoring. It was found that all the companies "using" passive dosi meters were doing so in only a test mode. In other words, passive dosimeters are in various stages of evaluation, but nowhere did we find them currently accepted for routine use. In most companies "using" dosimeters, the testing is still at the very earliest stage of evaluation ... but in a few companies, evaluation has progressed to "acceptance" but the usage is in parallel monitoring with the pump and carbon tube methods. In some cases, initial company evaluation has yielded a preliminary "OK", but any use is pending OSHA acceptance (to be dis cussed later). The manufacturers identified for both pumps and the pas sive dosimeters are listed on the next page, with the percent of plants using that brand based on the total number of plants having a monitoring program. The manufacturer categories are not mutually -21- CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3W W5857 exclusive since most plants had purchased products made by two or more manufacturers. The high ratio of "3M" to "DuPont" should be viewed as transitory since DuPont's entry into this market is fairly recent; this ratio will probably decrease with time. The "3M" to "Abcor" ratio will probably increase as Abcor is generally seen as a sub siding brand. -22- CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3M 105S5S MANUFACTURERS ENCOUNTERED Used by This Percent of Those Plants Monitoring PUMPS: MSA.................................................................... 58% DUPONT............................................................ 55% BENDIX............................................................ 37% SIPIN................................................................ 35% SKC.................................................................... 27% DRAEGER............................................................ MDA.................................................................... ` 12% 9% PASSIVE DOSIMETERS: 3M.................................................................... ABCOR................................................................ DUPONT............................................................ 38% 12% 4% -23- CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3M 105859 Perceived Advantages/Disadvantages: Pump Versus Dosimeter ADVANTAGES OF PUMP: 1. Users perceive the personal sampling pump and carbon or other "traps" as NIOSH/OSHA approved. As OSHA is the primary regula tory agency whose standards the user company must meet, use of an "approved" methodology and equipment is seen as very impor tant. While neither OSHA nor NIOSH actually have approved any such sampling equipment (as is the case of NIOSH certification of respirators), the NIOSH "Manual of Sampling Data Sheets" does specify personal air sampling pumps as the means of collecting workplace atmosphere samples for monitoring of organics. (Only in the method for mercury utilizing 3M's mercury monitor does NIOSH depart from the pump sampling specification.) 2. OSHA uses the pump in its field investigations. This actual use of the pump by OSHA is probably of greater importance to many ccmpanies than is their belief that the pump is NIOSH/OSHA ap proved. Several respondents stated that as soon as the OSHA inspector began to use a passive dosimeter, their company would quickly follow. 3. The historical records of organic vapor levels is based upon the pump/tube method. There is seme fear that if the passive dosi meter should give higher results, the record would then indicate an overall increase in the hazard to which the company allowed workers to be exposed. CONFIDENTIAL MATERIAL SUBIECi TO PROTECTIVE ORDER 3M 105860 -24- 4. There is greater confidence in the pump actually sampling a stated volume of air because of its positive flow rather than the passive "flow" of the dosimeter. This feeling exists more among the less sophisticated personnel rather than the technically trained industrial hygienist. 5. The pump and tube method is seen as a proven method. DISADVANTAGES OF PUMP: 1. The pump/tube is seen as costly in two areas: initial cost of the pumps and analysis costs. One respondent stated that in his laboratory, analytical effort was only half as much for the anal ysis of the passive dosimeter carbon disc as for the carbon tubes used with the pump. (The perceived initial cost of the pumps also works as an advantage of continued use of the pump method once the initial capital purchase has been made . . . "get our money's worth out of the pumps before switching to the passive dosimeters".) 2. As expected, users find the pump cumbersome for workers to wear. This is reflected in both worker resistance to wear the pump and in the pump's interfering with the worker's movement . . . which in itself could be an unsafe practice. 3. The pumps are difficult and time-consuming to keep in calibration. 4. In addition to calibration problems, overall maintenance is seen as a problem. One respondent said that only one-half of his pumps were operable at any one time. confidential MATERIAL SUBJECT TO PROTECTIVE ORDER 3M 105861 -25- 5. While the pumps method was generally seen as a "proven method", performance failures are apparently frequent. There just isn't any assurance that the pump does in fact keep pumping during the time that the worker is wearing it. Some companies have the industrial hygienist or an IH technician stay with the worker wearing the pump to see that the pump does continue to work. ADVANTAGES OF THE PASSIVE DOSIMETER: 1. It is lightweight, and thus ccmfortable to wear. No worker resistance is encountered . . . as is sometimes the case with the pump. 2. The use of the passive dosimeter is seen as less expensive over all than the pump/tube method. No initial pump cost, no main tenance costs, frequently less analytical costs, and signifi cantly lower personnel costs in conducting a monitoring program. 3. No continuing calibration is required. This advantage is per ceived as outweighing the costs of the initial "calibration" required to qualify the passive dosimeter for a particular application. 4. Less skilled technician effort is required. The passive dosi meter is seen as a device that can even be mailed to a workplace location to be monitored . . . with very simple, easy-to-follow instructions yielding acceptable and dependable monitoring re sults. This is in contrast to the need for an experienced ,,nTMTlM.MATEBIM>SUB1ECT -26- 3M 105862 technician to maintain, set-up, calibrate, put on and take off the pump for each use. DISADVANTAGES OF THE PASSIVE DOSIMETER: 1. The passive dosimeter is yet quite controversial among the pro fessional people. Moreover, there is yet sufficient assurance that it will come to be accepted by OSHA. 2. Many people just do not understand diffusion as a means of col lecting a sample . . . "Where is the flow of air?" 3. There is a lack of published laboratory and field test data. Each potential user wants to be able to refer any challenger of his data to published reports by third parties demonstrating acceptable results. -27- CONFIDENTIAL MATERIAL SUBjECT TO PROTECTIVE ORDER 3M 105863 Analytical Service Various practices and attitudes of the respondents were obtained concerning the analytical aspects of monitoring organics that are "trapable" by activated charcoal. First . . . current practice (almost entirely related to analysis of charcoal tubes from the pump and tube method): Analysis is done b.y . . . In-Plant Laboratory Only . . Outside Laboratory, including Company Headquarters Laboratory . . Both In-Plant and Outside ..................... % of Plants 4855 3255 2055 Turn-around time for analyses . . . Median (all plants) .......................... Range (all plants) .......................... 11 Days 2-35 Days Is your present turn-around time adequate? Yes, it is generally "OK" .......................... No, generally need sooner .......................... 8755 13% What tum-around time would you like to have? Median (all plants) ............................................... 7 Days Turn-around time was defined.as the time lapsed from sample submission to receipt of result . . . either via written report or by telephone if quicker response was needed. 3H -28- The respondents' attitudes toward using the services of a nationwide, independent laboratory . . . such as 3M's . . . were ob tained. Care was taken to frame this question so as to focus on samples from the passive dosimeter as well as from the pump and tube method. The result was almost a toss-up . . . 442 of the persons interviewed had a positive attitude toward sending samples to a cen tral, independent laboratory, and 56% were not inclined to use any outside analytical service. Reasons given for the positive attitudes were: 1. No internal G.C. capability; 2. Internal G.C. capacity filled; 3. Independent, "unbiased" result desired; 4. Parallel analysis to check internal results; 5. less expensive than internal analysis; 6. Less turn-around time required; 7. Better technical capabilities. Reasons given for the negative attitudes were; 1. Samples could be lost in mail; 2. Samples could be confused with others; 3. Uncertainty of outside lab capabilities; 4. More expensive than internal analyses; 5. Loss of confidentiality (competition and regulatory). -29- CONFIDENTIAL MATERIAL SUBjECT TO PROTECTIVE ORDER 3H 105865 User Preference for Distribution Route User respondents were polled for their preference for buy ing personal monitoring equipment and supplies direct from manufac turers versus buying from their local distributor. The following data show that the great majority prefer dealing with distributors or have no preference: Prefer Direct from Producer ................. 14% Prefer Through Distributor...................... 40% Have No Preference....................................... 46% The persons interviewed reported that DuPont and MSA sell only direct and that Bendix, Si pin, SKC, and Abcor sell through dis tributors. A distributive consideration arises when one considers the data previously reported on purchase influencers. With 65% of the companies reporting that responsibility for personal monitoring rests with a department other than that department responsible for per sonal protective devices, it may be that distribution of the #3500 OVM should not be restricted to the traditional "safety equipment" distributors. Other types of distributors . . . such as laboratory supply houses . . . might be added to the distributor system to reach a broader range of those professionals involved in personal monitoring. CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER -30- 3M 105866 Personal Monitoring Versus Area Monitoring Workplace atmospheres may be sampled either from a fixed position or from a mobile position . . . usually as close as possi ble to the face of a worker. The former is generally referred to as "area sampling" and the latter "personal sampling". (The "samp ling" plus analysis plus record-keeping is the "monitoring" program.) Area sampling is a necessary approach in situations where immediate analysis is needed to alert workers to the presence of hazardous concentrations of materials that pose an immediate, acute health or safety hazard. Area sampling is necessary because the re quired analytical equipment is not usually attachable to a worker. Most hazardous organics are not ones that present an immediate, acute hazard, and thus area sampling is not a required approach in monitoring programs for these substances. Area sampling might be used for convenience or cost or other reasons in organic vapor monitoring programs even though this approach to sampling might not be "required". One consultant we talked with reported that at least one company is exploring the possibility of combining area sampling (and subsequent analysis) with computer assisted descriptions of worker movements within the workspace to yield Time Weighted Averages of worker exposure. The uncertainty that this approach would give sufficient correlation with the actual exposure of a given worker, and the high cost of CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER -31- 3M 105867 developing the system, would both suggest that this approach will find little if any acceptance among user companies . . . much less by regulatory agencies. Another factor that affects the choice between area and personal sampling is the position taken by regulatory agencies, most notably OSHA. All promulgated regulations to date that ac tually prescribe a sampling procedure require personal monitoring . . . not area monitoring. While we did not attempt to get a direct measure of the usage of area monitoring, we can conclude from our interviews in general that the great preponderance of sampling for organic vapors is by personal sampling. We did ask directly concerning the respondents' expecta tion of any changes in the "mix'1 of personal versus area sampling. The results give no reason to expect that personal monitoring will decrease in favor of area monitoring: "See no change from current mix"................. 22% "Trend is definitely toward personal" . . 71% "Trend is toward area" ...................................... 7% -32- CONFIDENTIAL o util EOT TO PROTECTIVE ORDER 3M 105868 Personal Monitor Selection Factors What factors are most important to the key purchase in fluences in making decisions as to which passive dosimeter to pur chase and use? To answer this most important question, we evaluate the unaided corrments made by the respondent and directly query the respondent concerning a number of generally found selection factors. We use a 1-10 numerical rating scale that is rooted to some gener ally accepted evaluatory terms. A similar scale is then used to obtain the respondents evaluation of the performance of the manu facturer on the same factors, RATING SCALE Scale _________ Importance_______ Performance 0.0 - 1.9 2.0 - 3.9 "Not at all important" "Not too important" "Lousy "Poor" 4.0 - 5.9 "Somewhat important" "Fair" 6.0 - 7.9 8.0 - 10.0 " Important" "Very Important" "Good" "Super On the following page are the factors and importance rat ings for passive organic vapor monitors, and the ratings for 3M's #3500 OVM. The most important three factors will be discussed indivi dually in sections that follow. On the other six factors, 3M rates quite favorably compared to the importance that the respondents place on the various factors. The one "yellow light" is in the area of "Knowledgeable Sales Reps" which should be interpreted as being both -33 confidential TO PROTECTIVE ORDER 3M 105S69 3M's representatives that are in contact with potential users and 3M`s distributors. Somewhat more technical and application know ledge is desired from these people. PERSONAL MONITOR SELECTION FACTORS RANK FACTOR IMPORTANCE RATING 1-10 SCALE 3M PERFORMANCE Mi DIFF, VERY IMPORTANT 1 PRODUCT QUALITY 2 NIOSH APPROVAL 3 TECHNICAL LITERATURE 9.6 8.2 -1.4 8.1 ,,(1) -- 8.0 6.8 -1.2 IMPORTANT 4 SIMPLICITY OF USE 5 KNOWLEDGEABLE SALES REPS 6 COMPANY REPUTATION 7 WORKER ACCEPTANCE 8 DELIVERY TIME 7.9 9.3 +1.4 7.7 7.2 -0.5 7.3 9.1 +1.8 7,2 9.5 +2.3 7.0 9.0 +2.0 9 PRICE 6.5 7.8 +1.3 10 ANALYSIS TIME 6.2 8.3 +2.1 numerical rating here would be meaningless since most respondents either said that "approval" was being awaited, or didn't know if the #3500 was "approved" or not. Many asked if it was approved. -34- CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3M t05870 Factors of Product Quality v w "nA >><1 The selection factor given the highest rating by users was "product quality". This is a very broad term, but it can be boiled down to the basic question: "Will the passive dosimeter do the job it is intended to do?" And more specifically, the concern of each individual is will it work on the organics that are potentially pre sent in his plant. In the earliest stages of consideration, the user looks to see if the manufacturer claims that his product will work on the specific organics of concern. In other words, the first test of product quality are the manufacturer's claims in the promotional literature. The importance of literature will be discussed more fully in a later section of this report. Because of the incumbant position held by the pump and carbon tube method, the user wants to see that the passive dosimeter gives results that agree with those that his company, or regulatory agencies, have obtained previously using the pump and tube method. This is important both from the standpoint of not disrupting the historical data line, and of being able to use the two methods inter changeably. If no pump-and-tube data are available for comparison, the user is concerned with "accuracy" . . . generally determined by sampling a known concentration of the organic vapor in a vapor chamber. Closely related to "accuracy", which is a measure of the CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER -35- 3M 105871 correctness of the result, is "precision" ... a measure of the sensitivity of the method. In other words, will the passive dosi meter distinguish between important differences in vapor levels. Other related analytical concerns relate to the consis tency of the results. Are they reproducible? Badge to badge . . . day to day . . . analysis to analysis. All of these analysis related factors must be lumped to gether to determine if the passive dosimeter gives results that will meet the "accuracy" section of those OSHA regulations that speci fically require personal monitoring. Another concern related to product quality is for the effect of other organic vapors upon the dosimeter's ability to mea sure the organic of specific concern. Will the dosimeter accurately measure one organic in the presence of other, often less critical and higher concentrations, organics. Other product quality questions relate to the susceptibi lity to high temperature, high humidity, and low ambient air speeds. And finally, is the capacity of the passive dosimeter ex ceeded in the user's specific application? How do you know if over loading has occurred? These questions arise primarily from the practice of using and analyzing a "back-up" section of activated carbon in the pump and tube method. As may be seen in the Selection Factor table, 3M's #3500 QVM performance falls short in its "Product Quality" rating when CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3M 105872 -36- compared to the importance that potential users attach to product quality. While we found very few opportunities to evaluate users' perceptions of the #3500 in comparison to competition, those few situations strongly suggest that 3M is perceived as being better than any competition in "product quality" . . . particularly in the analytical areas of accuracy, precision, and reproducibility. The product quality shortfall comes primarily as a result of lack of information. Where data is available, it should be effec tively communicated to potential users. And where the data is lack ing, laboratory and field testing that will address these product quality concerns should be conducted and reported. Test data should be developed by third parties . . . not by 3M. Preferably the third party should be under NIOSH, or the testing done under NIOSH or OSHA auspices. -37- COWTOBrnALMMEKW. SUBjBCT TO PROTECTIVE ORDER 3M 105873 Users' Attitudes Regarding NIOSH/OSHA Approval The significance of the second-ranked selection factor -- NIOSH Approval -- is much greater than its importance rating indi cates. While the first-ranked "Product Quality" is in many ways a vague term, and satisfaction in 3M's performance on this factor can be achieved by effective communication of present or future data, meeting potential users expressed needs for "NIOSH Approval" will be much more difficult. We find that the expression "NIOSH Approved" covers a range of official endorsements: 1) Many respondents are familiar with the NIOSH certification program for respirators, and a similar cer tification for the Bendix-type, colormetric gas analysis tubes. They would like the same assurance of acceptability with the passive dosimeters. 2) The NIOSH Manual of Sampling Data Sheets details the type of sample collection with each method. For mercury, there is a method detailing 3M's Mercury Monitor passive dosimeter. Users want to see NIOSH published methods that detail the dosimeter as the means of sample collection. 3) OSHA at least implicitly "approves" the pump and tube methodologies, even though the promulgated regula tions state that any method is acceptable if it meets the prescribed "accuracy" requirements, 4) And perhaps most importantly, OSHA inspectors sample workplace atmospheres . . . and whatever method used by the inspector is assumed to be the most acceptable method -38- CONFIDENTIAL MATERIAL TO protective: order , i -OT 3M 105874 for the company to use in meeting OSHA requirements. Gaining any one of the above four "endorsements" would satisfy users' demands for "NIOSH Approval". The individual importance ratings given to the selection factor "NIOSH Approval" were not spread over the 1-10 scale continuum. Rather, they fell into one of four distinct classes: 11% of Users -- Little, if any, regard for "NIOSH Approval", NIOSH approval not needed before they would use passive dosimeters routinely. 20% of Users -- Approval desired, but they would use passive dosi meters if their evaluation showed that the dosimeter was satisfactory in their application. Sufficient data would be generated to meet the OSHA regulation requirements for accuracy, and to otherwise demon strate to regulatory people the acceptability of the dosimeter. 25% of Users -- Approval is very important, but they might use for some internal control monitoring even if approval was not expected. "Official" monitoring would con tinue to be with the pump and tube method. 44% of Users -- Approval is absolutely necessary, will not use pas sive dosimeter unless "NIOSH Approved". CONFIDENTIAL MATER Tu, TO PROTECTIVE ORDER -39- 3M 105875 Technical Literature Considerations The potential user is looking for extensive literature coverage on the attributes and applications of the passive dosimeter. This attitude is directed toward both sales and promotional litera ture, as well as technical reports of laboratory and field testing. To most potential users, the passive dosimeter is still a new concept. He needs to be sold on the diffusion sampling approach. The potential user looks for answers to all the questions raised in the previous section on "Product Quality"; and when he doesn't find the answer, a negative is assumed. He looks particularly for "NIOSH APPROVED" or "MEETS ALL OSHA REQUIREMENTS" or some similar statement. And he expects to see his particular application mentioned among the applications discussed in the promotional literature. If the potential user does not find his organic listed as a "Recommended Compound" in the 3M Compound Guide he assumes that the #3500 OVM is not applicable to his situation. He would like to have reprints of articles in technical journals presenting data fran laboratory and field tests involving the specific organic compound and possible interferences that he would encounter in his potential application. In short, the potential user is looking for literature that will allay his every concern about the acceptability of using the #3500 in his plant. rONHDENTIAL TO PROTECTIVE ORDER ,OT -40- 3M 105S76 Time Frame for Decisions to Use a Passive Monitor ORDER FOR INITIAL EVALUATION...............................................* - 1*5 Months The advantages of the passive dosimeter over the pump and tube method are sufficient to elicit a sample order from most people engaged in personal monitoring. But "I'd like to try a few" quan tities do very little to increase sales once the distributor pipeline is filled. ORDER FOR ROUTINE USE, ASSUMING "NIOSH APPROVAL"*. .2-24 Months Average Time ... 13^ Months Respondents were asked "If NIOSH approved, how long would it take for your company to evaluate and make a decision to use a passive dosimeter?" Some said they would begin using quickly . . . if NIOSH approved, then they would assume satisfaction in their application. Others said that they would still have to do extensive evaluatory testing before any decision for routine use and/or replace ment of the pump and tube method was made. ORDER FOR ROUTINE USE, ASSUMING "NIOSH APPROVAL" . . 44% of canpanies WAS NOT FORTHCOMING ................................................................ would not consi der for use the other......................... 56%: 2-36 Months Average Time: ................. 18 Months Those companies that would use in the absence of "NIOSH Approval" would require additional time for more complete testing and consideration than if approval were forthcoming. *"NIQSH APPROVAL" is used here to mean any of the four "official endorsements" discussed earlier. -41- CONFIDENTIAL MATERIAL SUBJECT ^ TO PROTECTIVE ORDER 105877 RESULTS OF DISTRIBUTOR INTERVIEWS ftlFTOENTIAL MATERIAL SUbjfaC i protective: order 3H 105878 Results of the distributor interviews are presented in a question and response format followed by ratings of business selec tion factors as ranked by the distributor respondents. 1. To what industries do you sell personal organic monitoring devices (passive or pump)? % of Distributors* Chemical............................................................... ^Metals Finishing............................................... 4035 "20%~~"~^) Petroleum........................................................... Petrochemical................................................... Glass, Paper, Textiles, Electronics, Gas......................................... 15% 10% 5% each The high ranking of the metals finishing industry was un expected, but explainable in hindsight: Solvents -- most of them considered by NIOSH/OSHA as hazardous -- are used exten sively as cleaning agents. Also, safety equipment distributors have an "in" with this industry through supplying protective clothing and eyewear. 2. With what department do you mostly deal in selling personal monitoring devices? Safety.................................................................... 75% Purchasing........................................................... 45% Industrial Hygiene......................................... 45% *The responses to most of the questions are not mutually exclu sive categories; thus, the percentages do not total 100%. -43 - 3MCONFIDENTIAL MATERIAL SUBJECT 105879 TO PROTECTIVE ORDER This mix should be carefully considered in light of the previously discussed mix of "purchase influencers" in which we found that persons other than in the safety department comprise 7035 of the influence. Converting the above data to mutually ex clusive categories of "Safety" and "Industrial Hygiene", it would appear that only about 40% of the distributor effort is being applied to potential purchasers outside the safety depart ment. 3. Is there a "call for" passive dosimeters or do you have to "sell"? "Call For"................................................................ 5% "Sell"..............................................................................65% Both................................................................................. 30% Obviously, "pull through" marketing on the part of the manufacturer is currently required. 4. What approaches do you find effective in selling? Personal Sales Calls ........................................... 100% Direct Mail............................................................ 50% Advertising............................................................ 50% Telephone Calls ................................................... 10% Trade Show Promotion........................................... 5% iWLMKnI-5UB1ECT -44- 3H 105880 Most respondents said that only the personal sales call would actually produce a sale . . . the other approaches were useful only in creating interest. 5. How does 3M help in selling the #3500 OVM? 3M Reps Make Calls with Distributor .... 65% Advertising..................................................................... 45% Provides Literature ............................................... 25% Provides Leads............................................................ 20% Does Direct Mailings.......................................... 5% Runs Field Testing............................................... 5% 6. How could 3M improve its sales support? Nothing More is Needed................................................55% (Two distributors said that 3M is the best of their OEM's!) Better 3M Sales Representation .......................... 30% Not Have so Many Competing Distributors , . 15% Provide More Leads....................................................... 5% 7. Are you satisfied with the frequency of 3M representative contact with you? What frequency is desired? Current Frequency is Satisfactory . . ......................80% Median: 52 times per year Range: 4-120 times per year Current Frequency is Not Satisfactory ..................... 20% Current Range: 1-12 times per year Desired Range: 4-36 times per year CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3H 105SS1 -45- While the responses to this question show a moderate need for increased rep contacts, consideration of the responses to Questions 5 and 6, and other data frcm this study, point out rather strongly the need for 3M's reps to be better qualified technically and to be able to transmit either verbally or with literature the technical information that is needed by potential users. 8. What other personal monitoring devices do you offer? Bendix.............................................................................. 10% National Draeger ................................................... 10% Gas Tech........................................................................ 5% Abcor.............................................. 5% "Color Chromatograph Badge" - Mfg. Not Known................................................................ 5% The most important aspect of these data is that threefourths of the distributors have no experience in selling organic vapor monitoring equipment other than the #3500 QVM (unless they used to carry a "pump and tube" line and have dropped it). They may have very little knowledge of carbon absorption technology, and may not appreciate the advantages that the passive monitor offers compared to the pump and tube. -46- CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER 3H 105882 9. How does your profit margin on 3M's #3500 OVM compare to that on competitive devices? Same............................................................... 15% 3M is Better..............................................15% 3M is Poorer................................................ 0% 10. What percent of your total sales of industrial safety products is in 3M's 3500 OVM? Mean response...................................... 2.6% Median................................................... 2.0% Range....................................................... Nil to less than 10% 11. What trend do you see in the sales of personal organic vapor monitors? Increasing.................................................... 75% Decreasing............................................... 0% No Change............................................... Don't Know............................................... 5% 5% No Response................................................ 15% Distributor's Comments: . . . If benzene decision is in favor of 0SHA, denand for #3500 will be very large. . . . #3500 sales will grow faster than the overall personal monitor market. CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER -47- 3M 105883 . 3M will be the leader in a "sky rocketing" market. . Abcor will go "down the drain". . #3500 market will "fly" ... but will take much longer to develop than 3M has projected. your #3500 customers have their G.C. analyses done . . .? In House.................................................... 35% Outside,Local ..................................... 25% By 3M.........................................................50% Don't Know................................................ 10% -48- CONFIDENTIAL MATERIAL SUdJll, 1 TO PROTECTIVE ORDER 3H 105884 DISTRIBUTOR'S SELECTION FACTORS IMPORTANCE AND 3M PERFORMANCE RATINSS RANK FACTOR VERY IMPORTANT 1 COMPANY REPUTATION 2 ACCURACY OF RESULTS 3 EASE OF ANALYSIS 4-5 ACCESSIBILITY OF LOCAL DISTRIBUTOR 4-5 KNOWLEDGEABLE MFG. SALES REPS 6 DELIVERY 7 NIOSH APPROVAL IMPORTANT 8 PRICE 9 LIGHT WEIGHT/EASE OF USE 10 TECHNICAL LITERATURE 11-12 ANALYTICAL TIME 11-12 WORKER'S ACCEPTANCE 13 ONE-TIME-USE ITEM 14 QUANTITY DISCOUNTS IMPORTANCE 3M PERFORMANCE RATING RATING DIFFERENCE 9.3 9.4 +0.1 9.1 9.1 -- 8.9 8.9 -- 8.8 9.1 +0.2 8.8 8.6 -0.2 8.7 9.0 +0.3 8.5 9.1* +0.6 7.8 9.1 7.7 9.0 7.6 8.9 7.3 8.8 7.3 8.9 6.9 8.9 6.5 8.6 +1.3 +1.3 +1.2 +1.5 +1.6 +2.0 +2.1 *3M`s distributors appear to believe that NIOSH approval, or at least some form of official endorsement, has been received. If this claim is being made to knowledgeable prospects, it presents either or both a lack of know ledge of the field or a "credibility gap". CONFIDENTIAL MATERIAL SULJtCl TO PROTECTIVE ORDER -49- 3M 105885