Document DvpK7o8VG6qzeEgGE6xXOgmnd

W. E. Horton FIELD POINT OR DS'T. & BLDG NO. . FROM T. S. Bialke .3JECT FIELD POINT OR DEPT. & BLDG. NO. Akron - D/0020, 5-H Industrial Hygiene Survey, Sept. 22-25, 1981 OATE YOUR LETTER DATE THIS LETTER 11-5-81 During the period Sept. 22-25, 1981 I conducted an industrial hygiene survey of the Avon Lake General Chemical plant. You will note that this survey report uses a table format to present survey results. The table has a column for findings of the survey, a column for responsibility (the plant is to note the person(s) names responsible for taking action on survey recommendations when replying to the survey) , a column for the date which action is expected to be com pleted on each item, and a column in which the findings are discussed and recommendations offered to address each item. The table is followed by a brief discussion of air monitoring results and general comments regarding the survey. This years survey report of the Avon Lake plant identifies a need for the plant to improve implementation of its respirator fitting, cleaning and storage policy. Eye and face protection requirements need to be reviewed in all plant departments. The paint shop paint spray booth is in violation of OSHA standards and needs upgrading. I want .to thank B. Welch, R.Lockemer and J. Gressler for their help and courtesies given to me during my survey. v cc /II.W.&ycLa^D 0030 CLaff' J.Gressler/R.Lockemer/B.Welch H.Waltemate/E.Martinelli/E.Harrington W.C.Becker G.F.Krcmar/R.A.Krueger N.Aquino/W.Lodge R.Kaminski/J.Malone W.Niederst/E.Osborne OS :i/aCMJTHOIN U.S.A. BFG46505 Avon Lake III Survey - Sept. 22-25,1981 Survey Findings Responsibility Exp.Comp. Date Recommendation/Comments 1. Items from Previous Survey 1. Modify eyewash fountains to elimi nate spring loaded valves (previous survey recommendation). 1. Did not see any eyewash fountain with spring loaded valves during this survey. Action on previous recom mendation satisfactorily completed. 2. Estane/Estol B/471 a. Access doors to ventilation system installed (previous survey recommenda tion) . b. On Sept. 22 the extrusion line was being run with the ventilation system down. The foreman said a work order had been issued, but work to correct the problem had not been scheduled until the following day. 2. b. When appraised of the serious ness of running line with no venti lation, the foreman contacted the maintenance department. Maintenance responded and repaired the ventilation system that evening. Processes that have a potential for exposing employee to substances that present an immediat or acute hazard (such as in this case an isocyanate) must not be operated if controls, such as a ventilation system that are necessary to protect worker's health) are not functioning properly. 3, Waterblasting of Estane agitators found to be adequate for routine cleaning (previous recommendation). Acetylene torches occasionally used for "rush" cleaning jobs. 3. Airline respirators are required to be worn by employees engaged in the burning off of Estane agitators. 4. Bldg. 452. The three air pumps south of bagger used to supply trans port air were not muffled or sound proofed (previous survey recommeniation). Sound level in bagging area greater than 95 dBA with pumps running. 4. Reduce noise from air pumps by enclosing pumps with a noise enclosure BFG46506 Z009ZT9Z Avon Lake 111 Survey - Sept. 22-25,1901 Survey Findings Uosponsibility Exp.Comp. Date Recommendation/Comments 2. Items from This Survey 1. Numerous common use found to be improperly clean, or with missing them unserviceable. respirators stored, not parts, making 1. ALGC has a well written respirator program, however the findings of this survey indicate that it is not being thoroughly implemented. My July 1978 survey also resulted in a recommenda tion to improve implementation of the respirator program. Procedures need to be instituted that require a safety and health representative to review that respirators are kept clean and serviceable at least on a monthly basis. BFG46507 2. Many employees in Geon west poly building were observed with full, beards working in job classes that routinely require the wearing of respirators. 2. Currently the area OSHA coordinate are responsible for administering the annual respirator training and fit testing program. The importance of obtaining a good respirator fit for exposure to VCM cannot be over-empha sized when you consider the difficult} in obtaining a good fit on a person with a full beard. For this reason, I recommend that the plant's environ mental/safety personnel ensure that respirator training/fitting and testii especially on employees with beards, is being done correctly and frequent^ To this end, the environmental group at ALGC has made a commitment to try a semi-quantitative fit testing pro cedure developed by duPont. I will work with the plant to plan and initiate the procedure, 3. No current data kept in plant files documenting worker exposure to asbestos during removal of asbestos containing insulation. C009ZT9Z. 3. To satisfy the requirements of the OSHA asbestos standard, the plant needs to obtain 3-5 air samples for asbestos exposure during insulation removal. Proper procedures are being Avon Lake III Survey - Sept* 22-25,1901 Survey Findings Responsibi1ity Exp.Comp Date Recommendation/Comments 3. i followed for handling asbestos, in addition, employees whose jobs put them in contact with asbestos get a yearly physical. Obtaining personnel air samples will document that the procedure ALGC employs is adequate for the exposures encountered. Plant environmental group has been advised of sampling procedures. 4. Plant has conducted area moni toring for MDI in B/433. However, no personnel monitoring for MDI has been conducted to date to evaluate actual worker exposure to MDI. 4, Conduct personnel monitoring for MDI using the Liquid Media Sampling device. The LMS will permit personnel sampling for MDI without the problem of spilling or inconvenience associatf with wearing of impingers. Obtain 15 minute samples during various tasks throughout the workshift on employees in B/433 and 471. The MDI exposure limit is 0.02 ppm ceiling. A ceiling TLV is assigned to substances whose effects on humans are acute and fast acting. The potential for pulmonary sensitization and resulting response of an individual with such sensitivity requires that MDI, i.e. isocyanates, have a ceiling TLV. The only way to ascertain compliance with a substance having a ceiling TLV is to obtain short term (15 minute maximum) samplef throughout the workshift. BFG46508 5, Noise a. Areas with sound levels greater than 85 dBA not posted per BFG Medical Policy 5.05. b. Discontinue the practice of conducting noise dosimeter tests on employees who have demonstrated only threshold shifts, fr009ZT9Z 5, All plant areas greater than 85 dB, are to be surveyed and posted as beim noise hazardous with a requirement fo: wearing of hearing protection. As a minimum, obtain one noise dosimeter reading per employee working in a noi hazardous area per year. Avon Lake IH Survey - Sept. 22-25,1901 Survey Findings-Noise (conft) Responsibility Exp.Comp Pate Recommenda tion/Common ts 4. c. B/461 Geon East, 2nd floor, sound absorbing barriers moved due to construction work. c. Portable sound barriers that had been installed around noise producing equipment need to be repositioned. Their proper placement is marked by lines on the floor around each piece of sound producing equipment. 6. An employee in Geon East was observed not wearing eye/face pro tection while handling a liquid catalyst that had an eye hazard warning label on the container. Investigation of eye/face protection requirements in other process areas, i.e. hydrophyllics and Geon West, where liquid catalyst initiators are handled, revealed that eye/face pro tection is not always required or worn. Eye/face protection requirements should be reviewed plant-wide. Any time an employee is required to trans fer a reactive liquid such as a catal yst or initiator from one container to another, eye and/or face protection must not only be provided, but it must be worn. A full face shield is pre ferred. 7. Paint spray booth in carpenter shop had air flow across face 50-60 fpm less than OSHA requirements. Manometer to indicate restricted air flow inoperable. 7. OSHA 1910.107(B)(5)(i) requires that paint spray booths have an air flow of at least 100 fpm across their open face and have a gauge to indicate when the flow rate drops below require minimum. Increased air flow may be accomplished by increasing fan speed. If that does not work, extensive modi fications may be required. Once air flow meets the requirements of the standard, the manometer must be kept operable 8, No periodic review or follow-up on leak detection programs in Geon East or West. S009Zt9Z 8, Each Geon unit has procedures for detecting and correcting VCM leaks. However, the Environmental/Safety grou; does not routinely review the program. The Environmental/Safety group at ALGC must periodically review the leak detection program to ensure that props: procedures are followed to detect leak: Avon Lake III Survey - Sept. 22-25,1901 Survey Findings Responsibi1ity Exp.Comp, Date Recommendation/Comments 5. \ 8. and once they are detected, they are eliminated to everyone's satis faction. Leaks that require mainten ance should be tagged, with copy of tag sent to the environmental group for review and follow-up if necessary to improve maintenance department's responsiveness. 9. November 10-13, 1980 survey reply not documented. 9. Reply within 60 days of the survey report as to the plant's programs to address each recommendation. Include person or group responsible for taking action? also the expected date of completion. BFG46510 Avon Lake GC IH Survey Sept. 22-25, 1981 6. Discussion; Table I contains the results of personnel sampling conducted for VCL during the survey. The table lists my results along with results of the plant's duplicate sampling efforts. The two methods for sampling and analysis were different. The plant used the Bendix flasher tube for the entire shift. My method employed charcoal tubes with solvent desorption. My results represent the combination of two partial period consecutive samples to get a full shift TWA result. The two results over the TLV were caused by employees conducting strainer cleaning tasks that require wearing of respirators during that time period. The wearing of respirators during performance of hazardous tasks is permitted under OSHA. The result on Mr. Kula is not significantly in excess of the permissible exposure limit. TSB 0092X92 BFG46511 TABLE I. Name/SS # S. Kula 506-36-5426 K. Kocsis 289-40-9461 R.Kowalczyck 289-54-5234 VCM PERSONNEL MONITORING AVON LAKE GC - 9/22-23,1981 Bldq . Job Sample Time (min.) Resp. Worn Geon East H Blowdown Oper. Charge Oper. Blowdown Oper. 410 390 392 Yes it TSB* Results (ppm) 1.06 1.83 1.54 Plant Results (ppm) 0.7 2.05 1.75 Results represent sum of two consecutive samples. 26126008 BFG46512 _R Industrial Hygiejft^SSv.urvey, Sept. 22 to 25, 1981 26127001 Attached is the Avon Lake General Chemical Plant's response to the Industrial Hygiene Survey Report. "Robert C. Lockemer RCL/bp Distribution: W. E. Horton J. W. Gressler D. D. Quester J. C. Meek Fdl. ft nninyTn~ 'Tf~~ W. Deitz/D-0020 Staff -^Twaltenate A. D. Timpano/B. R. Welch/D. M. Daidone C. Bayard D. J. McDonald D. J. Barnicki M. L. McCaslin E. C. Gilbert D. J. Gargas W. E. Kenney D. F. Spink J. R. Shellenberger T. J. Biskupich Survey Findings (Sept. 22-25, 1981) Items from Previous Survey 1. Modify eyewash fountains to elimi nate spring loaded valves (previous survey recommendation). 2. Eatane/Kstol B/471 a. Access doors to ventilation system installed (previous survey recommendation). b. On Sept. 22 the extrusion line was being run with the ventilation system down. The foreman said a work order had been issued, but work to correct the problem had not been scheduled until the following day. 3. Waterblasting of Estanc agitators found to be adequate for routine cleaning (previous recommendation). Acetylene torches occasionally used for "rush" cleaning jobs. 4. Bldg. 452. The three air pumps south of bagger used to supply transport air were not muffled or sound-proofed (previous survey recommendation). Sound level in bagging area greater than 95 dBA with pumps running. Recommendstion/Commenta 1. Did not see any eyewash fountain with spring loaded valves during this survey. Action on previous recommendation satisfactorily com pleted. ALGC Response 1. No response required. 2. b. When appraised of the seriousness of running 2.a. Access doors to the ventilation were installed line with no ventilation, the foreman contacted the 2.b. ALGC has an ongoing program to improve the maintenance department. Maintenance responded and extruder vent system in B/471. Several modifica repaired the ventilation system that evening. Processes tions to the existing vent system were made in 1981 that have a potential for exposing employees to substances that present an immediate or acute hazard (such as in the case of an isocyanate) must not be operated if controls, Buch as a ventilation system to increase its capacity. In addition, an AK to install a new vent system will be prepared by the Estane/Estol Dept, during the 1st Quarter of 1982 and submitted for approval. that is necessary to protect worker's health, is not functioning properly. 3. Airline respirators are required to be worn by employees engaged in the burning off of Estane agitators. 3. The use of airline respirators when burning off Estane equipment is a standard operating procedure. The procedure will be reviewed with Maintenance personnel during safety meetings to ensure compliance. 4. Reduce noise from air pumps by enclosing pumps with a noise enclosure. 4. A GPO to install mufflers on the air pumps will be prepared by Geon West during the 1st Quarter of 1982 and submitted for approval. $ 9 *9 4 3 ZQ01ZX9Z BFG46515 Survey Findings (Sept. 22-25, 1981) Items from This Survey Recommendation/Commenta 1. Numerous cojiunon use respirators found to be improperly stored, not clean, or with missing parts, making them unserviceable. 1. ALGC has a well written respirator program, however, the findings of this survey indicate that it is not being thoroughly implemented. My July, 1978, survey also resulted in a recommendation to improve implementation of the respirator program. Procedures need to bo instituted that require a safety and health representative to review that respirators are kept clean and serviceable at least on a monthly basis. 2. Many employees in Geon West poly building were observed with full beards working in job classes that routinely require the wearing of respirators. 2. Currently, the area OSRA coordinators are responsible for administering the annual res pirator training and fit testing program. The importance of obtaining a good respirator fit for exposure to VCM cannot be over-empha9ized when you consider the difficulty in obtaining a good fit on a person with a full beard. For this reason, 1 recommend that the plant's environ mental/safety personnel ensure that respirator training/fitting and testing especially on employees with beards, is being done correctly and frequently. To this end, the environmental group at ALGC has made a commitment to try a semi-quantitative fit testing procedure developed by DuPont. X will work with the plant to plan and initiate the procedure. 3. No current data kept in plant files documenting worker exposure to asbestos during removal of asbestos containing insulation. 3. To satisfy the requirements of the OSHA asbestos standard, the plant needs to obtain 3-5 air samples for asbestos exposure during insulation removal. Proper procedures are being followed for handling asbestos, in addition, employees whose jobs put them in contact with asbestos get a yearly physical. Obtaining personnel air samples will document that the procedure ALGC employs is adequate for the exposures encountered. Plant environmental group has been advised of sampling procedures. ALGC Response 1. By February, 1982, all production areas will conduct a monthly check of common use respirators to ensure that they are properly cleaned and 9tored with all necessary parts. The Health, Safety, and Environmental Dept, will conduct a quarterly check of common use respirators in the plant. Records of the monthly and quar terly checks will be maintained by the Health, Safety, and Environmental Dept. 2. An action plan to evaluate the quantitative mask fit procedure developed by DuPont has been prepared by ALGC. The evaluation should be completed during the 1st quarter of 1982. 3. Personnel will be monitored for asbestos exposure. Survey Findings {Sept. 22-2S, 1981) Items from This Survey 4. Plant has conducted area monitoring for MDI in B/433. However, no personnel monitoring for MDI has been conducted to date to evaluate actual worker exposure to MDI. 5. Noise a. Areas with sound levels greater than 85 dBA not posted per BFG Medical Policy 5.05. b. Discontinue the practice of con ducting noise dosimeter tests on employees who have demonstrated only threshold shifts. c. B/461 Geon Bast, 2nd floor, sound absorbing barriers moved due to construction work. 3. Recommendstion/Comments ALGC Response 4. Conduct personnel monitoring for MDI using the Liquid Media Sampling device. The U4S will permit personnel sampling for MDI without the problem of spilling or inconvenience associated with wearing of impingers. Obtain 15 minute samples during various task9 throughout the workshift on employees in B/433 and 471. The MDI exposure limit is 0.02 ppm ceiling. A ceiling TLV is assigned to substances whose effects on humans are acute and fast acting. The potential for pulmonary sensitization and resulting response of an individual with such sensitivity requires that MDI, i.e., isocyanates, have a ceiling TLV. The only way to ascertain compliance with a substance having ceiling TLV is to obtain short term (15 minute maximum) samples throughout the workshift. 4. Once data on the LMS device have been supplied to the plant, the Health, Safety, and Environskental Affairs Dept, and the Estane Dept., will develop an action plan to monitor personnel exposure to MDI. Personnel monitoring will be completed by the 3rd Quarter of 1982. 5. All plant areas greater than 85 dBA are to be surveyed and posted as being noise hazardous with a requirement for wearing of hearing protection. As a minimum, obtain one noise dosimeter reading per employee working in a noise hazardous area per year. c. Portable sound barriers that had been installed around noise producing equipment need to be re positioned, Their proper placement is marked by lines on the floor around each piece of sound producing equipment. 5.a. Building noise surveys have been completed and noise hazardous areas defined. All areas with sound levels greater than 85 dBA will be posted in January, 1982. 5.b. Noise dosimeter testing will be conducted once per year on all employees who work in noise hazardous areas. Additional dosimetry testing will be conducted only on those employees who receive a medical referal recommendation on the Audiometry Action Report, c. The sound barriers will be kept in their proper positions. BFG46516 *00ZT9Z Survey Findings (Sept. 22-25, 1981) Items from This Survey 6. An employee in Geon East was observed not wearing eye/face protection while handling a liquid catalyst that had an eye hazard warning label on the con tainer. Investigation of eye/face protection requirements in other process areas, i.e., hydrophilics and Geon West, where liquid catalyst initiators are handled, revealed that eye/face protection is not always required or worn. 1. Paint spray booth in carpenter shop had air flow across face 50-60 fpm less than GSHA requirements. Manometer to indicate restricted air flow inoperable. 8. Mo periodic review or follow up on leak detection programs in Geon East or West. 9. November 10-13, 1980 survey reply not documented. 4. Recommendations/Comments Eye/face protection requirements should be reviewed plant-wide. Any time an employee Is required to transfer a reactive liquid such as catalyst or initiator fora one container to another, eye and/or face protection must not only be provided, but it must be worn. A full face shield is preferred. ALGC Response Pace shields will be worn when weighing or charging catalyst. 7. 0SI1A 1910.107(B) (5) (i) requires that paint spray booths have an air flow of at least 100 fpm across their open face and have a gauge to indicate when the flow rate drops below required minimum. Increased air flow may be accomplished by increasing fan speed. If that does not work, extensive modifi cations may be required. Once air flow meets the requirements of the standard, the manometer must be kept operable. 8. Each Geon unit has procedures for detecting and correcting VCM leaks. However, the Environmental/Safety group does not routinely review the program. The Environmental/Safety group at ALGC must periodically review the leak detection program to ensure that proper procedures are followed to detect leaks. 9. Reply within 60 days of the survey report as to the plant's programs to address each recommendation, include person or group responsible for taking action; also the expected date of completion. 7. The paint spray booth vent system has been modified and the air flow across the open face increased to 100 fpm. The existing manometer haB been repaired. As the filters become clogged the Maintenance Dept, will correlate pressure drop with face velocity to define a maximum acceptable pressure drop. A pressure drop in excess of the maximum will require cleaning or replacing the filters. 8. Leak detection reports will be reviewed by the Health, Safety, and Environmental Dept. BFG46517 S00ZT9Z C. E. Flemi T. S. Bialke Avon Lake C.C. - si.5 ?0>NI uOkR mOce?r" >i ;-s -j`-O Akron - D/0020, 5-H Industrial Hvciene Survey-Avon Lake T.C. DATIEc TV:5 Lt ` * 2-8-82 During the period December 7-1C, 1981 I conducted an industrial hygiene survey at the Avon Lake Technical Center. Attached is my report detailing findings of the survey. This year the format of the I.E. survey has been changed, resulting in a better understanding of how the recommendations relate to each finding and to allow the facility and outside reviewer to fellow actions on recommendations. You will note that the report has four columns headed survey findings, responsibility, expected date of completion and recommendations or comments. The "findings" column describes the situation that needs correcting. In the "responsibility" column, the facility is requested to name the person(s) who will be respon sible for completing the necessary corrective action(s). The "expected date of completion" column should be used to put the timetable or date at which action is expected to be completed. The "recommendations/comments" column contains a discussion of the findings at the time of the survey together with recommen dations which, if implemented, should correct or improve the problem or situation found. The table format should be used when reporting on actions taken to address the survey findings. This years survey of ALTC identified incomplete actions on con verting spring loaded eyewash fountains over to stay open types, laboratory hoods not rated per Chemical Group SA127 and need for hearing protection and controls in the extruder building. ALTC monitoring programs are more than sufficient and recommen dations are offered to reduce some industrial hygiene monitoring. I would like to thank R. Hardesty for his assistance during ray survey. v cc: R. Hardesty H.Waltemate/3. Mar tine Hi W. C. Becker/i?. C. Holbrook E. B .Katzenneyer/H .W. Dietz/R. A. Guyton/D/00 20 Staff T008ZT9Z :<5-i556-E '1/30 LI7H0 IN O.Svi V^57Sf A v n . ,akc TC III Survey - Dec, 1901 Sui vey Findings Responsibility Exp.Date of Comp. I terns from Previous Survey(s) 1. round 21 spring loaded eyewash r''i m tains had not been changed over to stay-open valve type. 2. All laboratory hoods not routinely checked for ventilation rates or rated per BFG Chemical Group SA127. BFG46519 3. Hydrazine exposures associated v. i ( I ADVA process were monitored by i i r Ti'chnlcol ('enter Per Inst years : . < < mmondations . Results for four '..impler* were 0.08 -- 0.18 ppm. ACGIII '! t i or 8 hours is 0,. 1. Exposures__ w< i 1 tasksn9t _p^ntging reactoj: an sampling collection'. Z008ZT9Z Recommendations/Comments 1. In the 1979 and 1980 IH survey reports it was recommended that all spring loaded eyewash fountains be modified with a type that would remain open. In the November 1981 reply to the 1980 III survey, the Technical Center indicated that all foun tains had been changed over. Finding 21 fountains that had not been modified indi cates a need for the Technical Center to pay closer attention to the review and follow-up of recommendations. 2. The BFG Chemical Group SA127 requires quarterly flow checks and rating of labor atory hoods. Due to the large number of hoods at ALTC and manpower limitation, the Center is experiencing, the following compromise was agreed upon. a. The Technical Center will measure al hoods and rate them per SA127 in the 1st quarter 1982. b. The Center will institute quarterly maintenance checks on blowers, belts and duct work on all hoods. c. The Center will check flow rates on an annual basis for the newer compensa ting hoods and measure flow rates on the older single-pass hoods on a quarterly basis. 3. Require wearing of airline respirators for tasks of charging reactor and collection of samples. 59^0^ Avun Laxe TC IH Survey - Dec. 1981 Responsi- Sm vi'.y Findings bility Exp.Date of Comp. [ I . -in:; round during Th i s Survey 1. [Aspirators seen during walk through were clean and serviceable, but approximately 50% not protected I'wbecoming soiled during storage. 2. in Lab #11, the Porosimeter device had much mercury contamination in and around it. 2. Employee engaged in weighing up of pigments in compound room w.r observed smoking. C008ZT9Z too * Recommendations/Comments 2: 1. Place all clean respirators in plastic bags or other suitable protective covering to prevent contamination during storage. 2. Place Porosimeter on a pan/tray to con tain any Hg that may be spilled and dropped on the floor. Clean, then seal floor with polymeric sealer to prevent any Hg already soaked into it from evaporating into the lab's, work environment. A smooth floor would allow for easier clean-up of any spilled Hg. The existing floor is of a tarazzo tile type with many nooks and crannies, making it nearly impossible to completely remove any apilled Hg. Obtain uring Hg level checks on employees working in Lab #11. After clean-up determine airborne Hg levels in Lab #11. 3. Lead, antimony, and a variety of other compounds are handled in the Tech Center's compounding area. Adjacent, through a door, is an area lunchroom. Smoking must be prohibited in the compounding area; if employees are to timokc, It must be restricted to the lunchroom. Employees also must be instructed to wash their hands before smoking. Smoking materials must also be prohibited from being carried or stored in the compounding area. Av oi -ike TC IH Survey - Dec. 1981 Survc-y Findings Responsibility Exp.Date of Comp. * Recommendations/Comments 3 rc * rj 4. Noise levels in excess of 85 dBA jn.' f.ncountered when certain pieces of equipment are used in the xtrucler building such as cubers, icers, air blow-offs. No hearing roiection is being worn. 4. Post the extruder building as "noise hazardous" when running cuber, dicer, bios-offs, etc. immediately require that when such noise producing equipment is being run, hearing protection is mandatory. Investigate the possibility of employing portable noise attenuation/absorbing panels around noise producing equipment. Design ing permanent enclosures around such equip ment is impossible due to the mobility required in the extruder building. However, portable sound absorbing panels, custom designed with windows, slots, etc., would reduce the transmission of noise through out the building. M < tn . IOdg. 414 Hydrin/PVC works. A onli1ation system in all of B/414 as observed with open ducts easing nowhere; flexible ductwork wivh holes in them and accumulation of material on the insides. 5. All ventilation systems in B/414 need to have an engineering review to determine how to better utilize existing capacities and cost out repair to damaged systems. These systems need to have a periodic duct work and fan blade clean-out. An engineering review with the intent of better utilization of existing capacities, plugging of unused ducts, etc., would provide for more effect ive control and have a potential for saving energy. As the system now exists, much heat is exhausted unnecessarily. P\T iosin is stored in the Bower r, iot.ujc cabinet in B/414. No local exhaust is provided. The Bower storage cabinet needs to have local exhaust ventilation provided to it which will create a slight negative pressure inside the cabinet, thus preventing any residual vinyl chloride monomer released from the stored resin from escaping into the work environment. Thr Tyler screen in the Hydrin process i : ic>t enclosed to prevent release of BFG46521 bOOSZTSZ The Tyler screen has a hood over it to capture vapors released from the product. The hood had curtains extending from it ,;c TC IH Survey - Dec. 1981 Survey Findings Responsi bility Exp.Date of Comp. b Recommendatlons/Comments I A. which enclosed the screen, enabling the ventilation system to better capture escaping fumes. This curtain, which had been removed, must be replaced. 6. f'nichlorohydrin, toluene and hrj'i.ine levels in Hydrin well Kclow TI..V. 6. Reduce personnel monitoring for epichlorohydrin, toluene and heptane to twice per year or whenever there is a process or equipment change or modification, , 7. Carboset 7000 process moni tored in past for ^respirable ciiiM. Obtain several samples to !'otter evaluate nose irrii .. t i on problem. lab .8 DOP/test ovens have local exhaust ventilation system inhr .locked with opening of 'if *! to capture DOP fumes ri Unsed from heating test. bC.H' exposures in lab have never been documented. 7. Carboset 7000 has caused nose irritation complaints by workers. Currently the problem is resolved through use of respi rators and by putting vaseline in the nose. : Respirable dust samples were collected on affected employees in the past. However, total dust measurements would be a more meaningful way of quantifying the exposure level associated with nasal irritation as respirable dust sampling does not quantify particulates normally deposited in the upper respiratory tract. A total dust measure ment quantifies' all inhaled and deposited particles. 8. Obtain 3-5 personnel DOP samples to document effectiveness of interlocking controls. i TSB S0082T9Z