Document EVLw7pGY5bLV33DRn4Z59E7L

Snell Foster D. Snell, Inc. General Laboratories Hanover Road Florham Park New Jersey 07932 (201)377-6700 August 23, 1974 Mr. James Kallenborn Acting Director of Planning, Evaluation and Research OSHA MNWA Building Room 110 1726 M Street, N'.W. Washington, D. C. 20036 Re: Contract No. L/A 74-167 Dear Mr. Kallenborn: The following is the preliminary report being submitted by August 23, 1974, for insertion into the Vinyl Chloride Hearing Transcripts. As agreed, the report presents the findings gathered by the study team during the seven weeks begun on July 1, 1974. The conclusions developed and presented in this report are preliminary, in that they will be subjected to farther analyses in the remaining period of the contract. Please do not hesitate to call should you have any questions about this report. Sincerely, / Joseph Nemec, Jr., Ph.D. Vice President mjs A Subsidiary of BOOZ* ALLEN & HAMILTON Inc. 1 4 S A* PRELIMINARY REPORT ECONOMIC IMPACT STUDIES OF THE EFFECTS OF PROPOSED OSHA STANDARDS FOR VINYL CHLORIDE Contract No. L/A 74-167 Mr. James Kallenborn Acting Director of Planning, Evaluation and Research OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION U. S. DEPARTMENT OF LABOR MNWA Building Room 110 1726 M Street N.W. Washington, D. C. 20036 FOSTER D. SNELL, Inc. Hanover Road Florham Park, New Jersey 07932 G 7N< August 23, 1974 CC' atta a J! L tr TABLE OF CONTENTS * INTRODUCTION II. METHODOLOGY Page III. INDUSTRY STRUCTURE IIIA. VINYL CHLORIDE MONOMER IIIB. POLYVINYL CHLORIDE PRODUCTION IIIC. KEY POLYVINYL CHLORIDE MARKETS IV. TECHNOLOGY OVERVIEW III - 2 III - 5 III - 9 IVA. VINYL CHLORIDE IVB. POLYVINYLCHLORIDE V. FINDINGS AND CONCLUSIONS IV - 2 IV - 9 VA. PRELIMINARY ECONOMIC IMPACT ASSESSMENT ', PERSONAL PROTECTIVE EQUIPMENT AND HYGIENE RELATED FINDINGS AND CONCLUSIONS VC. MONITORING EQUIPMENT RELATED FINDINGS AND CONCLUSIONS VD. MEDICAL SURVEILLANCE COSTS RELATED FINDINGS AND CONCLUSIONS V-2 V-9 V - 13 V - 18 cJ VI. NEXT STEPS S: iPa* CD APPENDICES A - DETAILED PROCESS DESCRIPTIONS AND PROCEDURES B - EXPOSURE DATA FOR POLYVINYL CHLORIDE (PVC) AND VINYL CHLORIDE MONOMER (VCM) PLANTS C - ECONOMIC DETAILS D - PERSONAL PROTECTIVE EQUIPMENT AND HYGIENE E - MONITORING EQUIPMENT F - MEDICAL SURVEILLANCE OF EMPLOYEES CO c? I- 1 II- 1 II-2 II- 3 III- l HI-2 III-3 III--4 III-5 III-6 III--7 INDEX OF EXHIBITS Following Page THE SCOPE OF THE SNELL STUDY 1-1 VINYL CHLOniDE/POLYVINYL CHLORIDE PRODUCERS VISITED AND INTERVIEWED BY II-6 TELEPHONE BY SNELL STAFF FOR DATA COLLECTION GOVERNMENT AGENCIES, INDUSTRY ORGANISATIONS, AND EQUIPMENT MANUFACTURERS VISITED BY SNELL STAFF FOR DATA COLLECTION H-6 FIRMS CONTACTED DURING THE SNELL TELEPHONE SURVEY OF EQUIPMENT MANUFACTURERS JJ-G PROFILE OF VINYL CHLORIDE PRODUCERS UI-3 VINYL CHLORIDE MARKET TRENDS HI-3 ' VINYL CHLORIDE PRODUCTION WORKERS - 1974 ni-4 PROFILE OF POLYVINYL CHLORIDE PRODUCERS HI-8 . COMPANY CAPACITY AS PERCENT OF TOTAL POLYVINYL CHLORIDE PRODUCTION CAPACITY III-8 GEOGRAPHIC DISTRIBUTION OF POLYVINYLCHLORIDE PLANTS III-8 U. S. POLYVINYL CHLORIDE PLANT AGE III-8 Pi CO C2 O' I-* CO -si i HI-8 III-9 III-10 III-ll III-12 III--13 III-14 III-15 III- 16 HI-17 IV- 1 IV-2 Following Page PVC HOMOPOLYMER PRODUCTION IN VARIOUS SIZE REACTORS - 1972, 1975 III-8 POLYVINYL CHLORIDE PRODUCTION BY RESIN TYPE HI-8 POLYVINYL CHLORIDE PRODUCTION WORKERS - 1974 HI-8 POLYVINYL CHLORIDE AND COPOLYMER RESINS, RESIN EQUIVALENT BASIS III-13 POLYVINYL CHLORIDE OUTPUT AND PRICE FORECASTS HI-13 SUPPLY SITUATION OF POLYVINYL CHLORIDE AND VINYL CHLORIDE HI-13 POLYVINYL CHLORIDE MAJOR MARKETS - 1970 - 1973 (MILLION POUNDS) HI-13 END USE FORECASTS OF POLYVINYL CHLORIDE MARKET, 1974 and 1978 - 1980 HI-13 POLYVINYL CHLORIDE CONSUMPTION BY MAJOR FABRICATION PROCESS - 1970TO 1973 HI-13 (000 LBS. DRY WEIGHT) MAJOR RESIN TYPES AND THEIR TYPICAL FREE MONOMER LEVELS RELATED TO FABRICATION CATEGORY HI-13 THE STAUFFER PROCESS FOR VINYL CHLORIDE JV-8 THE B.F. GOODRICH PROCESS FOR VINYL CHLORIDE IV-8 IV-3 IV-4 IV-5 IV-6 IV-7 IV-8 IV-9 IV-10 - IV-11 IV-12 IV-13 VINYL CHLORIDE PROCESS DESCRIPTION ESTIMATED VINYL CHLORIDE MONOMER ECONOMICS - 1974 EXAMPLE OF A STANDARD OPERATING PROCEDURE FOR MAINTENANCE AT DOW CHEMICAL CO. VINYL CHLORIDE WORKS CAPSULE OVERVIEW OF POLYVINYL CHLORIDE PROCESSES REPRESENTATIVE POLYVINYL CHLORIDE SUSPENSION RESIN MANUFACTURE FLOW DIAGRAM TECHNOLOGICAL OVERVIEWS OF SUSPENSION (S) EMULSION (E) AND COPOLYMERIZATION (S AND E TYPES) ' THE POLYMERIZATION CYCLE IN THE SUSPENSION AND EMULSION PROCESSES POTENTIAL EXPOSURE CHECKLIST BASED ON SUSPENSION POLYVINYL CHLORIDE MANUFACTURE TYPICAL FLOW DIAGRAM FOR THE BULK PROCESS TYPICAL TIME REQUIREMENTS FOR IMPLEMENTING VARIOUS ENGINEERING CONTROL METHODS POLYVINYL CHLORIDE ECONOMICS - 1974 Following Page IV-8 IV-8 IV- IV-13 IV-13 IV-13 IV-13 IV-13 IV-13 IV-13 IV-13 u> co ^ \ ^ CO CD fl V-l V-2 V-3 V-4 V-5 V-6 V-7 V-8 Following Page ESTIMATED INDUSTRY COSTS OF ACHIEVING A 50 PPM VCM CEILING LEVEL IN VCM PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL V-4 ESTIMATED INDUSTRY COSTS OF ACHIEVING A 25 PPM VCM CEILING LEVEL IN VCM PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL V-4 ESTIMATED INDUSTRY COSTS OF ACHIEVING A 15 PPM VCM CEILING AND 5-10 PPM TWA LEVELS IN VCM PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL V-4 ESTIMATED INDUSTRY COSTS OF ACHIEVING A LESS THAN 10 PPM VCM CEILING . AND 1-5 PPM TWA LEVELS IN VCM PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL V-4 U.S. INDUSTRY CLAIMED TIME TO REACH SELECTED VCM LEVELS IN VCM PLANTS V-4 THROUGH ENGINEERED CONTROLS SUMMARY OF THE COST IMPACTS AND TIME COMPLIANCE CLAIMED BY VCM INDUSTRY V-4 ESTIMATED INDUSTRY COSTS OF ACHIEVING A 50 PPM VCM CEILING LEVEL IN PVC PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL V-8 ESTIMATED INDUSTRY COSTS OF ACHIEVING A 25-40 PPM VCM CEILING AND 15-25 PPM TWA LEVEL IN PVC PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL V-8 EES X V-9 V-10 V-ll V-12 V-13 V-14 Following Page ESTIMATED INDUSTRY COSTS OF ACHIEVING A 25 PPM VCM CEILING AND 10-15 ' PPM TWA LEVEL IN PVC PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL V-8 ESTIMATED COST.FOR THE FIRESTONE TIRE AND RUBBER COMPANY TO ACHIEVE A "NO DETECTABLE" VCM LEVEL V-8 U.S. INDUSTRY CLAIMED TIME TO REACH SELECTED VCM LEVELS IN PVC PLANTS THROUGH ENGINEERED CONTROLS V-8 SUMMARY OF THE COST IMPACTS AND DELAYS TO COMPLIANCE EXPECTED BY ' PVC INDUSTRY BY VCM TARGET LEVEL V-8 ESTIMATED VINYL CHLORIDE ECONOMICS IMPACTED BY SELECTED VCM LEVEL STANDARDS (1874 Dollars) V-8 POLYVINYL CHLORIDE ECONOMICS IMPACTED BY SELECTED VCM LEVEL STANDARDS V-8 (1974 Dollars) C 1 it* O I. INTRODUCTION 'Oc\\/ i i49 CO TO 9 5SP I. INTRODUCTION This chapter presents the background of the economic impact study of the proposed OSHA standards for vinyl chloride, the study methodology, and the organization of the report. 1. SNELL'S ASSIGNMENT WAS TO ASSESS THE ECONOMIC IMPACTS RESULTING FROM THE COST TO INDUSTRY FOR MEETING ALTERNATE STANDARDS FOR WORKER EXPOSURE TO VINYL CHLORIDE MONOMER (VCM) IN THE VCM AND POLYVINYL CHLORIDE (PVC) MANUFACTURING INDUSTRIES On January 22, 1974 the Occupational Safety and Health Administration (OSHA) was informed by the National Institute for Occupational Safety and Health (NIOSH) that the B.F, Goodrich Chemical Company reported that deaths of several of its employees from a rare liver cancer (angiosarcoma) may have been occupationally related. As a result of this information, subsequent epidemiological studies and a fact finding hearing, an Emergency Temporary Standard (ETS) was promulgated by OSHA on April 5, 1974 detailing preliminary regulations on worker exposure to VCM (50 ppm ceiling exposure limit) . As required by law, six months after the issuance of an ETS a permanent standard must be formulated and approved. Therefore, on May 10, 1974 OSHA published a proposed permanent standard which included "no-detectable limit". To aid OSHA in carrying out its standard setting mandate Snell was assigned to prepare this report dealing with assessing the economic impacts of alternate standards for worker exposure to VCM in the VCM and PVC manufacturing industries. The alternate standards investigated are: . 50 ppm ceiling . 25 ppm ceiling 25 ppm 8-hour time weighted average (TWA) with a 40 ppm ceiling . lower TWA (s) with a ceiling . "no-detectable"proposed permanent standard The study is limited to U.S. production of VCM and PVC. Exhibit 1-1, on the following page, is a self-explanatory summary of the scope of the Snell study. 1-1 EXHIBIT 1-1 U. S. Department of I abor/Occupat'.onal Safety . and Health Administration THE SCOPE OF THE SNELL STUDY Primary Emphasis Secondary Requirements Deliverables Assess the economic impact of VCM regulation on VCM and PVC manufacturing Concentrate on PVC manufacture (approximately SO'frof level of effort) Investigate the following alternate standards - 50 ppm ceiling - 25 pprn ceiling - 25 ppm TWa( ^with 40 ppm ceiling - lower TWA(s) with ceiling - "no detectable ' level Emphasize key regulator)' considerations - engineering and work practices - use ot personal protective equipment - environmental and personal monitoring assembling of exposure data * residual monomer levels in PVC Include a study of VCM manufacture (apnroximately 20% of level of effort) Include secondary regulatory constderations^ - medical surveillance costs - record keeping costs - covered workers - regulated areas Deliver preliminary report on the 50 ppm. 25 ppm and "no detectable" cases in 7 weeks starting on July 11, 1974 on 23 August 1974 Present draft final report in 11 weeks (13 September 1974) Key deliverables are - estimates of the time table required In each of these evaluations for ''ffectivo implementatJ .. In the near-term, 6 months to one year in the longer-term, 2 years or more - estimates of the costs of achieving the various levels of VCM controls evaluated - assessment o' economic impact on the basis of technical feasibility, timing and costs (1) Other regulatory considerations include, for example, emergency situations and signs and labels, but were not Included in the scope oi Snell's work. All the regulatory considerations assigned for study are listed In the Exhibit, 2) TW; = Time weighted average .2 THE REPORT IS ORGANIZED INTO TWO PARTS The report conclusions and recommendations are presented first supported by detailed appendices. (1) The First Part Of The Report Presents The Findings Of Economic Impact Together With Recommendations Part One includes the following outputs: . Chapter I - Introduction. This chapter summarizes the problem, the scope of the study and the organization of the study. . Chapter II - Methodology. This chapter presents the Snell study methodology. . Chapter III - Industry Structure. This chapter presents data on members of the VCM and PVC producing industries location of plants marketing and base-line economic data. Chapter IV - The Technology of the Industry. This chapter describes the processes of VCM and PVC and includes process description and flow diagrams for each major process representative operating procedures . Chapter V - Findings. This chapter details the major findings related to economic impact emphasizing technical feasibility, timing and costs based on aggregating individual company data to the Industry level. i0 1-2 Chapter VI - Conclusions. The conclusions are presented as a function of various VCM levels and include technical feasibility particularly in relation to the emphasized regulatory considerations studied, including .. engineering controls work practice personal protective equipment .. monitoring timing costs . Chapter VH - Recommendations. The recommendations presented in this chapter give heavy emphasis to technical feasibility and timing. (2) The Second Part Of The Report Presents Detailed Study Documentation (Appendices) This part of the report is comprised of seven self-explanatory appendices and supports the material in Part One . Appendix A - Detailed Process Description and Procedures . Appendix B - Exposure Data . Appendix C - Cost Details . Appendix D - Personal Protective Equipment and Hygiene . Appendix E - Monitoring Equipment Appendix F - Medical Surveillance Appendix G - NIOSH Recommendations to OSHA l ***** K-* This chapter presented the scope of the study and the organization of this report. The following CO chapter details the methodology used by Snell to carry out the study. 1-3 II. METHODOLOGY This project was carried out as a rapid response study. The timing of the Report was such that on August 23, 1974, seven weeks from the start of the study, this preliminary report was submitted-to USDOL/OSHA for inclusion into the public record. The preliminary report features . Fact finding, such as field visits and telephone interviews including recontacting of parties for data clarification. . Preliminary analysis of regulatory scenarios including "no-detectable" vinyl chloride monomer (VCM) levels 25 ppm levels A final report draft is to be submitted by the end of the 11th week of the study (September 13 , 197.4). The methodology used by Snell in fulfilling the work requirement was to perform .the study in several major tasks described below. All exhibits are presented at the conclusion of the text of this chapter. 1. PLANT AND INDUSTRY VISITS WERE A PRINCIPAL MEANS OF INFORMATION GATHERING During the course of the investigation, Snell team members made 29 industry visits. The vinyl chloride and polyvinyl chloride industries consist of 30 producers and 53 plants. These visits involved either day long technical dis cussions in their engineering and production offices or detailed plant tours. Exhibit II-l presents the plants, location and purposes of these trips. These trips were comprised of 22 plant visits er 8 visits to corporate engineering offices. *vi II-l wait! 2. INDUSTRY RELATED ORGANIZATIONS, GOVERNMENTAL AGENCIES, EQUIPMENT MANUFACTURERS, AND SPECIALISTS WERE VISITED TO SUPPLEMENT INFORMATION OBTAINED FROM PLANT VISITS In order to gain a broader view of the technical feasibility and necessary, costs., personal visits were made to recognized experts in the areas covered by the' study. Exhibit II-2 details the organizations, governmental agencies, and equipment manufacturers visited and the types of information obtained. These visits included 4 visits to government agencies 3 visits to industry organizations 4 visits to equipment manufacturers or technical specialists 3. A TELEPHONE SURVEY WAS CONDUCTED OF MANUFACTURERS OF MONITORING EQUIPMENT, RESPIRATORY DEVICES, PERSONAL PROTECTIVE EQUIPMENT AND PROCESS EQUIPMENT The purpose of this task was to obtain detailed information covering costs, availability, and technology. Information was obtained both directly through the telephone survey and the brochures and catalogues sent to Snell as a result of the conversations. Exhibit JI-3 details the manufacturers interviewed during the telephone survey. Calls were made to 13 monitoring equipment manufacturers - 7 manufacturers of respiratory equipment 6 producers of protective clothing - 8 processing equipment manufacturers or designers CO CO n-2 /^ory 4. THE SNELL INFORMATION CENTER STAFF CONDUCTED A LITERATURE SURVEY. TO IDENTITY AND OBTAIN BACKGROUND INFORMATION ON AREAS RELEVANT TO THIS STUDY To obtain an overview of manufacturing processes, pollution problems, marketing, end-use products, and possible protective devices, etc., a survey of the following journals was performed: Hydrocarbon Processing - 15 years Modern Plastics - 5 years Chemical Marketing Reporter - 3 years Chemical and Engineering News - 3 years Chemical Engineering - 5 years European Chemical News - 3 years ; Standard chemical reference texts such as the Encyclopedia of Polymer Science and Technology and the Kirk-Othmer Encyclopedia of Chemical Technology were also researched to obtain more general iniormation. Chemical Marketing Abstracts and Chemical Economics Handbook were used for basic industrial facts. 5. THE STUDY METHODOLOGY EMPHASIZED THE PARAMETERS DEFINED IN EXHIBIT 1-1, IN THE INTRODUCTION CHAPTER The methodology described in the above points was employed to determine and define the scope of the following parameters: Profiling of industry structuia and processes OO ' CD II--3 CO Definition of the number of workers potentially exposed to VCM considering job description unit operation potential exposure to VCM levels Determination of costs and means of controlling exposure levels through engineering controls and improved work practices with particular attenti n to: "buttoning-up" of plants ventilation operation maintenance monomer levels in the polymer Investigation of further methods and costs of protection through the use of personal protective equipment beyond controlling exposure through engin- ' eering and work practices. Development of a technical and economic information base for personal, and area monitoring and leak determination equipment. Isolation of information regarding: medical surveillance costs record keeping costs covered workers regulated areas l M cr II-4 Detailed methodology is presented as footnotes to exhibits, textual reference or material in the appendices. 6. AS DIRECTED BY OSHA THE STUDY DEALT PRIMARILY WITH PVC PRODUCTION Approximately 80% of the level of effort was devoted to PVC production. Discussion emphasis in subsequent chapters reflects this. 7. FURTHER WORK AFTER THE PRELIMINARY REPORT WILL ADDRESS THE EVALUATION OF EXPOSURE LIMITATIONS BETWEEN THE "NO DETECTABLE" AND 25 PPM CASES, GENERAL DATA REFINEMENT AND FURTHER EVALUATION OF DEVELOPMENTAL TECHNOLOGY This section indicates the topics to be further expanded on in the final report. These topics include: An analysis of case(s) representing potential exposure limit (s) between "no detectable" and 25 ppm. (The preliminary report deals with the 50 ppm, 25 ppm and "no detectable" cases). Data refinement where indicated in the body of the preliminary report The 35,000 gal. reactor technology Polymerization cycles and reactor cleaning Monomer stripping Carbon absorption General R6D o> II-5 150 8. WHERE THERE WAS A QUESTION AS TO THE POSSIBLE PROPRIETARY NATURE OF INFORMATION, DATA SOURCES WERE CODED The elements of each coded plant designation are as follows . Random leading number only for VCM plants . Random leading number - PVC plant capacity - PVC plant age - PVC plant siting for PVC plant S = small, less than 100 New = to 10 yrs.. .C = cold climate million lbs. M = medium, 100 to 200 Int. = 11 to 20 yrs. W = warm climate million lbs. Old = over 20 yrs. L = large, over 200 million lbs. Exhibits featuring the code refer back to this page for meaning of the elements of the code. ***** This chapter detailed study methodology. The chapter that follows presents the preliminary findings and conclusions. o O f'J m n-6 Firm or Organization Visited Air Products, Inc. Valley Forge, Pennsylvania Allied Chemicals, Inc. Corporate H. Q, Morristown, New Jersey American Chemical Co, Long Beach. California Conoco . Corporate H. Q. Saddlebrook, New Jersey . Oklahoma City, Oklahoma Diamond Shamrock . Corporate H.Q. Cleveland, Ohio . Delaware City. Delaware . Deer Park, Texas Dow Chemicals, Inc, , Oyster Creek, Louisiana . Freeport, Texas Ethyl Cotporation Baton Rouge, Louisiana Firestone Tire & Rubber Co. Akron, Ohio General Tire & Rubber Co. Ashtabula, Ohio Exhibit ii-W .usdol/osha VINYL CHLORIDE/POLYVINYL CHLORIDE PRODUCERS VISITED' AND INTERVIEWED BY PHONE BY SNELL STAFF FOR DATA COLLECTION Purpose of Visit Technical and engineering data collection on PVC Technical and engineering data collection on VCM Plant visit on VCM and PVC Technical and engineering data collection Plant visit on PVC Technical and engineering data collection on PVC Plant visit Plant visit Plant visit on VCM Plant visit on VCM Plant visit on VCM Phone interview on PVC Plant visit on PVC Firm or Organization Visited B. F, Goodrich Co. . Corporate H. Q. Cleveland, Ohio . Calvert City, Kentucky . Long Beach, California . Louisville, Kentucky . Pedricktown, New Jersey Goodyear Tire & Rubber Co. Niagara Falls. New York Great American Chemical Co. Fitchburg, Massachusetts Hooker Chemical Corp, Florence, New Jersey Monsanto Springfield, Massachusetts National Starch & Chemical Co. Corporate H. Q. Plainfield, New Jersey Olin-Thompson Plastics Assonet, Massachusetts Pantasote Passaic, New Jersey Robintech, Inc. Painesville, Ohio Shell Oil Co. , Corporate H. Q. Houston, Texas , Deer Park, Texas Stauffer Chemicals h-* Delaware City, Del, CJ1 o Tenneco Burlington, New Jersey Purpose of Visit EXHIBIT 11-1(2) ' USDOL/OSHA Technical and engineering data collection Plant visit on VCM Plant visit on PVC Plant visit dn PVC Plant visit on PVC Plant visit on PVC Plant visit on PVC Plant visit on PVC Phone interview on PVC Technical and engineering data collection on PVC Plant visit on PVC Plant visit on PVC Plant visit on PVC Technical and engineering data collection on VCM Plant visit on VCM Plant visit on PVC Plant visit on PVC Vfc % i- - >Y Firm or Organization Visited Union Carbide, Inc. So, Charleston, West Virginia Uniroyal Chemical Co, Akron, Ohio Source: Snell Purpose of Visit EXHIBIT 11-1(3) ,USDOt/OSHA Technical and engineering data collection .on 'PVC Plant visit on PVC GX O C' 1 Government Agencies U, S. Department of labor Washington, D. C, National Institute for Occupational Safety and Health Cincinnati, Ohio Environmental Protection Agency Washington, D. C. and Research Triangle Park, N.C, U, S. Department of Commerce Washington, D C, Industry Organizations Manufacturing Chemists Association New York, New York Organizational Resources Council, Inc, Washington, D.C, Society of the Plastics Industry New York, New York Equipment Manufacturers, Medical Laboratories, Industrial Consultants, The Pfaudler Co. - Div. Sybrou Corp, Rochester, New York Diagnostic Sciences, Inc. - Ivan K. Smith Morris Plains, New Jersey Tec-Air, Inc. - David Metal East Northport, New York Human Motivation Resources - Joel D. Schaffer Morris Plains, New Jersey Source: Snell EXHIBIT II-2 USDOL/OSHA GOVERNMENT AGENCIES, INDUSTRY ORGANIZATIONS, AND EQUIPMENT MANUFACTURERS VISITED BY SNELL STAFF FOR DATA COLLECTION General data collection and attend heatings Discussion on medical, monitoring,' and protective equipment General data collection Industry marketing data collection Discussions on technical feasibility and marketing data General discussion Discussions on technical feasibility Discussions on polymerizers and other technical questions (sole U, S. suppliers of glass lined equipment) Medical surveillance data collection Protective equipment data collection Safety program data collection -Ml I YiO.iJ I S O I. Monitoring Equipment Manufacturers AID West Chester, Pennsylvania Bacharach Instrument Co, Pittsburgh, Pennsylvania Bechmann Instrument Fullerton, California Bendtx Corporation Environmental Science Division Baltimore, Maryland Byron Instruments, Inc. Raleigh, N. C. Carle Instruments Fullerton, California Century Systems Corp, Arkansas City, Kansas H. Respiratory Equipment Manufacturers Bausch & Lomb Rochester, New York Mine Safety Appliances Pittsburgh, Pennsylvania Minnesota Miring & Manufacturing, Inc, Minneapolis, Minnesota Scott Aviatian South Haven, Michigan EXHIBIT 11-3(1) USDOL/OSHA FIRMS CONTACTED DURING THE SNELL TELEPHONE SURVEY OF EQUIPMENT MANUFACTURERS Hewlett-Packard Co, Avondale, Pennsylvania Microchemical Specialties Co, Berkeley, California Perkin-Elmer. Norwalk, Connecticut Anatole J. Sipin Co, 386 Park Avenue, S. New York, New York Vartan Association Palo Alto, California Wilks Scientific Norwalk, Connecticut Survive-Air Santa Ana, California Welsh Scientific, Inc. Providence, Phode Island Willson Products Pennsylvania m ^n V- < Cl o c* III. Protective Clothing Manufacturers Arrow Disposables, Inc. Cincinnati, Ohio E. I. Dupont de Nemours Wilmington, Delaware Dura fab Cleburne, Tejas IV. Processing Equipment Manufacturers Crawford and Russel, Inc. (Design Engineers) Stamford, Connecticut Dresser Industries (Compressors and Vacuum Pumps) Connersville, Indiana Durion Company, Inc. (Valves and Pumps) New York, New York Fluid Handling System (Viking Pumps) Secaucus, New Jetsev' Source; Snell EXHIBIT II-3 (2) USDOl/OSHA Edmont-Wilson Coshocton, Ohio Mars, Inc. Ashville, North Carolina Uniroyal, Inc. New York, New York GAF (Cleaning Systems) New York, New York Nash Engineering Co. (Compressors and Vacuum Pumps)' Norwalk, Connecticut Process Pumps. Inc, (Pumps) Kenilworth, New Jersey Stauffer Inc. (Cleaning Systems) Westport, Connecticut cy 0V o o III. INDUSTRY STRUCTURE III. INDUSTRY STRUCTURE This chapter presents an overview of the structure of the U.S . vinyl chloride monomer (VCM) and poly vinyl chloride (PVC) industries. Key elements of production, prices and markets are delineated to provide a background and comparative criteria to judge the economic impact of proposed regulations on VCM and PVC manufacturing. The chapter is divided into three sections: . . Section IIIA - Vinyl Chloride Monomer Production . Section IIIB - Polyvinyl Chloride Production Section IIIC - Key Polyvinyl Chloride Markets $0 HIA. VINYL CHLORmE MONOMER This section defines the structure of the vinyl chloride monomer (VCM) manufacturing industry. 1. NINE COMPANIES OPERATE 14 VCM PLANTS Exhibit III--1, on the following page, presents a profile of the VCM producers in terms of plant locations, capacities and manufacturing process. Process related factors are discussed in Chapter IV. Shell, Dow and Goodrich are the leading 1974-1975 producers, accounting for approximately 58% of nameplate capacity. Approximately 5,225 million pounds VCM are estimated to be available for conversion into PVC in 1974-1975, assuming no major economic impact from OSHA regulations. With the exception of the Goodrich plant in Calvert City, Kentucky, the U .S. VCM plants are located in warm climate areas -- Texas, Louisiana, Puerto Rico, and California. In general, the plants are open except for weather screening. VCM plants are generally located in or near petroleum rich areas to minimizethe cost of feedstock (ethylene) transfer. CH m-a 2. U.S. VCM PRODUCTION HAS INCREASED APPROXIMATELY 370% TO 6,000 MILLION FOUNDS IN 1974 SINCE 1964, WHILE THE MID-1974 PRICE IS 7 TO 10 CENTS PER POUND OR ALMOST DOUBLE THE 1972 PRICE . Exhibit III-2, on the following page, presents production, sales and price data for the years 1962 throujh 1978-1980 (estimated). Sales and unit cost information are also presented. ' .. Since 1964 production of VCM has increased from 1,615 million pounds to an estimated 6,025 million pounds in 1974, for an increase of 373%. For the years 1962 to 1972, production of VCM increased from 1,311 million pounds to 5,089 million pounds or 388%, while merchant sales increased from 516 million pounds to 3,343 million pounds or 647%. Merchant uses were 39% of production in 1962 and 66% of production in 1972. This indicates a decreased forward integration in the industry with growth. . The doubling of price from 1972 to mid-1974 is attributed to the great escalation in feedstock costs due to the "energy crisis". 3. THE VCM MANUFACTURING INDUSTRY HAS APPROXIMATELY 940 PRODUCTION WORKERS . Based on a Snell survey of VCM producers, representing approximately 65% of 1974-1975 nameplate capacity (see Exhibit III-l), estimates were developed of the numbor of production and related personnel in the industry. Ol t'O m-3 Major Producer/Location Allied, Geismar, La, American Chemical, Watson, Calif, Conoco, Lake Charles, La. Dow, Freeport, Tex. Dow, Oyster Creek, Tex. Dow, Plaquemine, La. Ethyl, Baton Rouge, La. Ethyl, Houston, Tex, Goodrich, Calvert City, Ky, Monochem, Geismar, La. PPG, Guayanilla, P. R. PPG, Lake Charles, La, Shell, Deer Park, Tex. Shell, Norco, La, Total Correcting for 90% operating level Subtotal 5% lost in polymerization Subtotal Estimated 1974 exports Estimated 1974 imports Subtotal Other uses of VCM Total available for PVC conversion Order of magnitude values 1974-1975 Nameplate Capacity* * (Million Lbs.) 1,400 4o0 900 1,500 300 170 625 f * 180 r 700 T450 (*270 (150 1,000 350 (500 (*300 (*800 (700 6.695 670 6,025 ' 300 5, 725 300 Negligible 5,425 200 5,225 EXHIBIT HI-1 USDOL/OSHA PROFILE OF VINYL CHLORIDE PRODUCERS Process^) Oxychlorl nation Stauffer Oxychlcrinadon Stauffer Oxychlorinadon Dow Oxychlorination Dow Oxychlorination Dow Direct Chlorination Direct Chlorination Direct Chlorination Goodrich Oxychlorination Acetylene Oxychlorination Oxychlorination Stauffer Oxychlorination Stauffer Oxychlorination Sources.- (1) Company and industry totals based on Modern Plastics, May, 1974 and plant site estimates based on Chemical Marketing Reporter, 17 September, 1973, and industry interviews, (2) Industry interviews. (3) Snell assessment Tgj kkO- Cl JrTM* Year 1962 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1978-- 1980 (Unimpacted by OSHA Standards) Production^ (MM Lbs.) 1,311 1,435 1,615 2,000 2,500 2,424 2,969 3,736 4,040 4.336 5,089 5,348 6.025(3) 6, 80q(4) Sales(1> (MM Lbs.) 516 501 597 688 836 952 1,463 2,359 2,720 3,003 3,343 NA NA NA EXHIBIT III-2 USDOL/OSHA VINYL CHLORIDE MARKET TRENDS Unit Value (d/I.b,) 7.5 7.0 6.4 6.1 5.9 5.3 4.6 4.4 3.9 4.2 4.0 5(2) 7-lo(?) NA Sources.- (1) "Synthetic Organic Chemicals", U. S, Tariff Commission, Annual Reports 1960-1973. (2) Posted price in tanks (works, freight equalized), Chemical Marketing Reporter, December 31, 1973 and June 24, 1974. (3) Estimate based on 1974 capacity 6,695 MM Lbs, in Exhibit III-X at 90% utilization, (4) 7,500 MM Lbs. capacity at 90% utilization per Hydrocarbon Processing, May, 1974, p. 83. NANot Available w Exhibit III-3, on the following page, summarizes employment data for 1974 production, maintenance and laboratory personnel have responsibilities with likelihood of VCM exposure: these represent 720 workers or 77% of manufacturing employment - there are approximately 220 management and support personnel ****# This section defined the structure of the VCM industry. The section that follows similarly profiles PVC manufacture. < CJ1 Cl m-4 ' `'fJfe IV. TECHNOLOGY OVERVIEW IV. TECHNOLOGY OVERVIEW The previous chapter defined the economic infrastructure of the vinyl chloride (VCM) and polyvinyl chloride (PVC) industries. This chapter presents a technological overview of VCM and PVC manufacture to provide broad engineering and operational perspective to the information of Section V, which presents findings and conclusions. This chapter is divided into two sections: . Section IVA , Vinyl Chloride Section IVB, Polyvinyl Chloride PVC is given significantly greater discussion emphasis than VCM since the study is of PVC. 1V-1 IVA. VINYL CHLORIDE This section discusses the technology of vinyl chloride (VCM) manufacture. Exhibits appear sequentially at the end of the text. 1- THE OXYCHLORINATION PROCESS ACCOUNTS FOR APPROXIMATELY 80% OF VCM CAPACITY The table below summarizes estimated U.S. VCM capacity in 1974 as a function of the manufacturing process. VCM Process Estimated 1974 Nameplate Capacity (Million Lbs.) Percent of Total Oxychlorlnation 5,450 81% Direct Chlorination Only Acetylene 900 350 14 _5' Total 6,700 100% source: Exhibit III - 1 ,\vn( v Hf 01 H*- The balanced oxychlorination process is described by the following equations: Direct Chlorination: (1) CH2, = CH2,, + Cl2,--------- C1CH 2CH 2Cl Oxychlorination (2) CH, = CH, + 2HC1 + K>? CuC12 C1CH,CH,C1 + H,0 11 L 250 C 22 2 EDC Cracking (3) 2C1CH2CH2CI q - 2CH2 = CHC1 + 2HC1 Net 2 CH2 = CH2 + Cl2 + i02-------- 2CH2 = CHC1 + HjO Source: Brownstein, A.M., U. S. Petrochemicals. Tulsa, Oklahoma; The Petroleum Publishing Co., 1971. p. 250. Exhibits IV-1 and IV-2 provide representative flow diagrams for the balanced oxychlorination process based on the Stauffer Chemical and B. F. Goodrich Chemical designs, respectively. Unit operations are similar in balanced oxy chlorination plants, although design details can vary appreciably regarding mass and heat balances, particularly in fractionation steps. Exhibit IV-3 provides a general process description related to the Stauffer design. The Exhibit also provides a more detailed description of unit opera tions involving VCM. CD JV-9 V K CJt o o The American Chemical plant is believed to feature unbalanced oxychlorination. using only reactions (2) and (3) in the preceding table. The Ethyl plants and Dow's Plaquamine plant are believed to feature direct chlorination and cracking only, using reactions (1) and (3) in the preceding table. The Monomchem plant, the only substantial acetylene-based process still op erating , is believed to be balanced type employing both ethylene and acetylene. The HC1 produced by pyrolysis of ethylene dichloride is added to acetylene for further VCM production, instead of oxychlorination. The newest process is the Transcat process (Lummus Co., and Armstrong Cork Co.) with the potential to compete strongly with the ethylene process. It is one step synthesis of VCM by oxychlorination of ethane. VCM is produced by passing ethane, HC1 and air (1 to 1 to 2,5 vol) through a molten catalyst of KC1 and CuCl/CuCl2 at 875F. Exhibit IV-4 summarizes estimated 1974 VCM economics. 2. GENERALLY, VCM PRODUCTION CAN PRESENT RELATIVELY LIMITED CHANGES OF EXPOSURE TO THE OPERATING PERSONNEL DUE TO AUTOMATION AND REMOTE CONTROL AND OUTDOOR CONSTRUCTION SIMILAR TO REFINERIES However, localized hazard areas are associated on a routine basis with the loading of tank cars, the cleaning of tank cars and of other equipment. Maintenance operations may be also a source of personnel exposure. (1) The VCM Production Plants Are Highly Automated . A typical VCM production plant consists of an island of process units, principally fractionation and similar towers, cracking ftirnaces, and sometimes compressors. Day tanks, providing storage space during testing, are also Included. Long-term storage is provided by Hortonspheres which are located in tank farms and connected to the. loading racks where the tank cars are filled. The flow of material through the production train (or trains) is controlled from control rooms, which, especially in newer installations, are fairly removed from the actual production units. The operators spend much of '.heir time in the control room, mostly monitoring the operation of automatic controllers and from time to time making necessary set point adjustments. Normally there is little need for the operating personnel ^ to be physically present in the production area. J.'* 13 IV-5 \ O ov u \j . However, inspection trips may be necessary from time to time and are usually motivated by some abnormality in the operation. While most of the abnormal ities are usually traceable to instruments or control malfunction, significant leaks could be occurring and result in appreciable exposure risk. (2) The VCM Plants Are Usually Completely Outdoor Operations All production equipment is generally installed out-of-doors. There is limited chance of VCM accumulation and area concentrations may remain low even in the presence of significant leaks, particularly when atmos pheric conditions are not stagnant. . However, significant exposure may be encountered by the greaser. Since his function is to fill up the lubricating devices of pumps and compressors, which in some instances may have to be done daily, he comes into close proximity of seals which may be leaking, and his own personal exposure may be in considerable excess to what would be surmised from the general background. (3) Tank Car Loading And Tank Car Cleaning Present The Most Critical Areas Of Exposure In Monomer Plants . While there are some "over-the-fence" pipeline deliveries and some marine shipments, the bulk of the VCM is moved in railroad tank cars. Significant VCM exposure risk can result from disconnecting transfer lines and from the historical practice to use "dip tubes" to determine the level in the tank car. iv-e . The "dip tube" method consists in allowing a minute amount of VCM gas continuously to escape through an adjustable tube dipping into the tank. When the level of the liquid in the car reaches the bottom of the tube liquid VCM is discharged resulting in a visible "plume" from the tube. Usual practice has been to raise further the dip tube at this point and to complete the filling carefully at a lower rate until the permissible level was reached. Under certain atmospheric conditions this method is known to have given significant VCM concentrations even at some distance from the tank car dome. A solution to this problem has been to re-equip larger fleets of tank cars with more elaborate, non-emitting gauging devices. Tank car cleaning operation put men in close contact with cars which may contain residual amounts of monomer. But thorough venting and incin eration can be installed and personal protection used. Thus, exposure hazard to personnel can be minimized. (4) Maintenance Operations, While Serious Potential Sources Of Personnel Exposure, Can Be Controlled By Appropriate Depressurization And Ventinff Procedures Catastrophic failures involving rupture of large volume containers or massive leaks upstream of the main control device are rare. 0^' o CJf u CO IV-7 Other situations requiring maintenance action (such as pulling a unit off the line for repair) divide into two categories: scheduled and unscheduled, with the former more easily accomplished using proper procedures to minimize VCM exposure risks. Appropriate operating procedures and additional venting equipment can be used to reduce or to virtually eliminate the risk of exposure. Exhibit IV-5 shows an example of current operating procedure for maintenance action of the Dow Chemical Company ***** Section IVB, following, provides a similar overview of polyvinyl chloride technology. Of IV"0 EXHIBIT IV-1 USDOL/OSHA THE STAUFFER PROCESS FOR VINYL CHLORIDE QXYCHLQRtNATIOtf PRIMARY SECONDARY , PYROLYSIS , ' 1 reactor;' recovery ` recovery FURNACE QUENCH - HC_I SEPARATION . i -.vtNVl , * ' CNLOFHPE 1 'V* fj SEPARATION ( Source: 1 f,nl" ..Vi- [ . vJ (_____ 3 CRUDE EDC rAVAVA pi PURE EDO' LIGHT ENDS - > 'CRUDE EOC C - useful, p HEAVY ends' W -< ' h' -Anon ion *''t HL OR IN A I I UN ' REACT OR,/, * . ' , `-l Stauffer Chemical Co.: idiMi i in 'H Iji I ic mi i, n [)'. heavy I mu1,; i aji ''' 1 NEUTRALISATION yj^OVAL A- ' ' REMOVAL SEPARATION ' *' , "~i , , ..'VV' 'l; " I Vinyl Chloride. Hydrocarbon Processing 52: 194, November 1973, EXHIBIT IV-2 USDOL/OSHA THE B. F. GOODRICH PROCESS FOR VINYL CHLORIDE o Source: B. F. Goodrich Chemical Co.: Vinyl Chloride. Hydrocarbon Processing 52: Ot 191, November 1973. *0 a t CJt 10 _"t General Description^ Ethylene dichloridc (EDC) Is produced In both addition (direct) chlorination and oxychlorination units. In the addition chlorina tion unit ethylene and chlorine are combined to produce EDC In a liquid phase reactor. In the oxychlorination unit ethylene, air and byproduct HC1 from the EDC cracking unit are reacted to pro duce EDC. An efficient catalyst in the vapor phase oxychlorina tion reactor Is used to promote high yields. High pressure steam generated in the oxy reactor removes reaction heat and is used as heat medium In other points in the process, EDC Is seperated from vent gas by condensation in two recovery units. There are no moving parts in the entire oxy process except in the air com pressor and refrigeration units. Crude EDC from the addition and the oxychlorination units is combined with recycle EDC from the cracking unit and puri fied by removal of small quantities of light and heavy materials. Aqueous effluents seperated from the crude EDC are steam strip ped and are suitable for biological treatment. Both light and heavy ends may be treated for further use as feed to other chlor ination processes, Vinyl chloride monomer (VCM) is produced by cracking purified EDC in the pyrolysis furnace. EXHIBIT IV-3 (1) USDOL/OSHA VINYL CHLORIDE PROCESS DESCRIPTION Description of Unit Operations Involving VCM^ Dry EDC is dehydrochlorlnated to vinyl chloride as it passes through the packed tubes of a cracking furnace. The tubes are normally packed with pumice, charcoal or some other "contact" type catalyst. At 900 to 950 F and 50 PSIG, EDC conversion is about 50% and yield to vinyl chloride is 94 to 97 mole%. The hot effluent gases are then quenched, and partially condensed, by direct contact with cold EDC in a quench tower. Effluent fractionation and product purification are generally accom plished in three additional towers, where each producer of VCM has its own modification of this process. Hydrogen chloride and light chlorinated hydrocarbons are rejected over head in the "HCL" and "Light Ends" towers. The hydrogen chloride is normally recovered by water scrubbing and recycled to the EDC plant. Trichloroethane, chlorinated C 's and other heavy ends are rejected from the bottom of either the "quench tower" or the "vinyl tower". Contained EDC is recovered by fractionation and recycled to both the quench tower and the feed storage tank. The light and heavy ends are either further processed or disposed of by, for example, incineration. Vinyl chloride monomer is taken overhead in the "vinyl" column, generally caustic washed, and then sent to the product storage facilities. General Description^ After quenching, the furnace product; are seperated into HC1, which is recycled to the oxy unit, and high purity VCM. Unreacted EDC is recycled through the EDC purification system. The overall process is balanced so that only VCM is produced without byproduct HC1. Design is easily adapted to produce HCl for other uses, to use HCl from other sources, or to make EDC as a seperate product. The process is highly automated for stable, fail-safe operation at high yields over a wide turn-down range. Startup is easy and rapid. Units combine simplicity of operation with low manpower, capital, operating and maintenance costs. EXHIBIT IV-3 (2) USDOL/OSHA VINYL CHLORIDE PROCESS DESCRIPTION Notes: Sources: (1) Related to the Stauffer process, Exhibit IV-1 (2) Reflects generalized practice (1) Stauffer Chemical Co,: Vinyl Chloride. Hydrocarbon Processing 52: 194, November 1973, (2) Air Products & Chemicals, Inc. Houdry Division, Survey Report on Vinyl Chloride Monomer Production Via Dlchlorethane Pyrolysis, Prepared for Environmental Protection Agency: Durham, North Carolina-, 1972. EXHIBIT IV - 4 (1) USDOL/OSHA ESTIMATED VINYL CHLORIDE MONOMER ECONOMICS - 1974 Unit Production Costs For A 500 Million Lb, Ethylene Oxychlorination Plant of 1974 Construction With Total Fixed Capital of $20,4 Million (0/lb.) Plant investment 4.08 Cost of Manufacture Raw Materials Ethylene (0.49 lb/lb <S>6.00/Ib) Chlorine (0.67 lb /lb (2>3.00/lb) 2.94 2,01 Subtotal 4,95 Labor Utilities Maintenance Overhead Taxes & Insurance Depreciation 0,12 0,25 0,20 0,15 0.06 0,40 Total cost of manufacture 6,13 jy* Ojk -`- *M EXHIBIT IV - 4(2) USDOL/OSHA ESTIMATED VINYL CHLORIDE MONOMER ECONOMICS - 1974 Unit Production Costs For A 500 Million Lb. Ethylene Oxychlorinadon Plant of 1974 Construction With Total Fixed Capital of $20.4 Million (d/lb.) Profitability Net selling price (FOG plant) 7.41 Cost of manufacture (6.13) Selling, general and administrative expenses ' ** (0.30) Pretax profit 0,98 . Pretax return on total investment (@1.2 plant investment) 2Ofy Sources: (1) Snell estimates based on Brownsteln, A, M., U, S. Petrochemicals, Tulsa, Oklahoma, The Petroleum Publishing Co., 1971, p. 25 (2) Snell estimates based on mid-1974 Chemical Marketing Reporter posted prices E Ol CO EXHIBIT IV-5 (1) USDOt/OSHA EXAMPLE OF A STANDARD OPERATING PROCEDURE FOR MAINTENANCE AT DOW CHEMICAL CO. VINYL CHLORIDE WORKS SAFETY PROCEDURE Subject; BLEED-DOWN OF VINYL CHLORIDE CONTAINING EQUIPMENT Problem,- At present, pumps, sections of piping, and some equipment is partially or otherwise bled down to atmosphere. This exposes personnel to vinyl vapors If care Is not taken. Situation; Obviously, there are numerous situations that occur in the plant, where exposure to vinyl vapors Is possible when preparing equipment for repair or entry. Most equipment is either already tied Into the vent recovery system for bleed-down, or can be, with limited temporary piping. Almost all bleed-downs can be done through the vent recovery system and all personnel exposures to vinyl vapors must be eliminated. Elimination of exposure to the vapors should extend to any final low pressure bleed-down of equipment that has already been relieved through the vent recovery system.. Also, preventative measures should be taken when opening equipment with stagnated vapors in It. In these two cases, proper respirators should be used to prevent exposures due to change of wind direction or otherwise. Solution: 1. All seal repair work done on vinyl furnace pumps should utilize the vent recovery system for the primary bleed-down. Any small final bleeddown should Involve personal respirator protection. In some cases, it may be necessary to use a full face mask, rather than a mouth-bite respirator. 2. Temporary piping to the vent recovery system should be run when necessary to vent an isolated piece of equipment, or run of piping. 3. When breaking into a vessel or piping system containing vinyl that has been depressured, use a respirator. (Hose-Line Mask). In the case of breaking vinyl containing system, the use of respirators should parallel the policy of using monogoggles. ' EXHIBIT IV- S (2) USDOL/OSHA EXAMPLES OF A STANDARD OPERATING PROCEDURE FOR MAINTENANCE AT DOW CHEMICAL CO. VINYL CHLORIDE WORKS 4. All vessels will be purged to D-234 vent recovery system before opening. Considerable exposure to vinyl vapprs is possible working around these openings due to trapped liquid vaporization inside the vessel. Therefore, fresh air-suppllcd masks should be used around such openings for exposures of any length. 5. When breaking Into vinyl containing equipment, the Immediate supervisor of that area should advise the type of respiratory equipment to be used, and issue a safe work permit in some cases. Source; Dow Chemical Corporation Cl V. FINDINGS AND CONCLUSIONS This chapter of the preliminary report presents the findings and conclusions drawn from the detailed data appearing in Chapters II and III, dealing with industry structure and technology respectively, as well as from the appendices. Information is presented in individual sections topically addressing each of the key regulatory consid erations of primary concern to the study. See Exhibit II--1. Secondary considerations are discussed in a general category. Then, an overview is provided in a preliminary economic impact assessment. Sections follow as shown , VA - Preliminary Economic Impact Assessment, Including Timing of Engineered VCM Controls VB - P. rsonal Protective Equipment VC - Monitoring Equipment . VD - Medical Surveillance Costs I Each of these sections will indicate the analysis, refinements, or new information to be developed during the remaining three weeks of the study between this preliminary report and the draft final report. < tn ta v-i CJ VA. PRELIMINARY ECONOMIC IMPAC1 ASSESSMENT This section presents the preliminary estimated economic impact of various regulatory standards on the vinyl chloride monomer (VCM) and polyvinyl chloride (PVC) industries. For this study, economic impact is defined only as the direct cost impact on the VCM and PVC industries resulting from compliance with proposed OSHA levels of VCM exposure. Economic impacts in other .sectors were not included in the scope of work. The timing required to achieve engineered controls of VCM at various comnliance levels is also discussed. 1 THE METHODOLOGY FOR ASSESSING THE ECONOMIC IMPACT IS BASED ON SNELL AUDITS OF INDUSTRY ASSESSMENTS OF REQUIRED ENGINEERING, PERSONAL PROTECTIVE AND MONITORING EQUIPMENT Information for assessing the economic impact under various VCM regulatory levels was collected through an industry survey conducted by Snell. The cost estimates are developed for various compliance levels. plant-by-plant costs reported by industry for various VCM exposure levels provided the data base individual plant information was aggregated to provide the estimated economic impact per pound of VCM or PVC produced for the industry. Cost estimates of specified equipment were checked by Snell for order of magnitude validity. monitoring and personal protective equipment information were compared with equipment supplier quotations specific items such as compressors, pumps, etc. were validated with supplier quotations or o V-2 <37 ^37 in addition, process designers were contacted selected extraneous industry claimed improvements, such as water treatment systems, were not included in the cost summary 2. THE ESTIMATED ECONOMIC IMPACT OF STANDARDS ON THE VINYL CHLORIDE MONOMER INDUSTRY RANGES FROM 0.073$ PEI1 POUND TO MEET A 50 PPM CEILING VCM LEVEL TO 0.42$ PER POUND TO MEET A LESS THAN 10 PPM CEILING VCM LEVEL AND 1 TO 5 TPM TWA AND SUSTAIN 1 97^ CAPACITY Snell assessed industry costs of reducing VCM levels in VCM plants wore separated into five categories which include: engineering costs, including: ventilation vapor recovery stripping loading for shipping other (pumps, piping, etc.) personal protective equipment costs, including: .. shower and eating facilities .. breathing equipment (respirators, air lines and bottled air) .. clothing (uniforms and protective clothing) monitoring costs, including: .. personal monitoring equipment <O: .. area and leak monitoring equipment medical tosting -* recordkeeping Cl CO Cl V-3 productivity loss the cost of keeping at the levels unimpacted by OSHA capacity otherwise derated as a result of regulation . . the cost includes equipment, personnel, etc. expensed items these include consultant costs, management time, etc. out-of-pocket expenses of 0.01<t/Ib are not included in the cost summaries Summarized estimates of VCM industry cost impacts and timing to meet selected VCM compliance levels follow in Exhibits V-l through V-5. Exhibit V-l presents the case of the50 ppm VCM ceiling Exhibit V-2 presents the case of the25 ppm ceiling Exhibit V-3 presents the case of the15 ppm ceiling and 5 to 10 ppm TWA (time weighted average) Exhibit V-4 presents the case of the 10 ppm ceiling and 1 to 5 ppm TWA Exhibit V-5 presents the industry claimed time requirements for compliance Exhibit V-0, following Exhibit V-5, servos as n summary discussion of findings. EXHIBIT V-I USDOL/CSHA Snell assessment of VCM level potentially achieved*L> Total plant* In sample: 9 Processes represented^ O STO, DO, DC; G location of plana In sample!3); 8W, 1C ESTIMATED INDUSTRY COSTS OF ACHIEVING A 50 PPM VCM CEtUNG LEVEL IN VCM PLANTS AS CLAIMED BY INDUSTRY AND ASSESSU> BY SNELL Capacity In Sample - Million* lb*, pet yeat (Percent 1974 U. d, nameplate capacity): Percent Industry claimed capacity from lample subject to ihutdown at a 50 ppm celling VCM level; 0% Snell ettlmate of percent capacity from tample tubject to shutdown at a 50 ppm celling VCM level: i% 1 Direct Costs Capitol (J/1.000 lb.) Annual ($/1.000 1b,) 5,125 {ITk) fercent of Total Annual Engineering costs!4) $1.14 $0.4.<8) 56% Personal Equipment Costs! 8) Monitoring 0,05 0.11(8) 0.03 CO 0.190.. 8) 4 28 .Total Direct Costs!1) ftoductlvlty Loss $1.30 $0.18 $0.63 $0.10 88% 14% Total Costs $1.48 $0.73 100% ,'S S T ^ q. Note: Soun* (1) Snell ettlmate of VCM levels achieved In plana Incorporating the level of control effort represented In the Exhibit. Monitoring data is detailed In Appendix B. (2) 0 Oxychlorination, STO = Stauffer Oxychiorinadon, DO = Dow Oxycholot[nation, DC 3 Direct Chlorination, G Goodrich Oxychlorination. (3) W Sited in worm climate, C Sited In odd climate. (4) Includes ventilation, vapor recovery, stripping, loading and o*er(piping, general pumps, maintenance, etc.) (5) Includes capital amortized @ 12% - 10 yti. and OAM charges. (6) Includes breathing equipment and clodih g. (7) Includes capital amort-jed ..2*, - 5 yr*. and OAM charges. (8) Includes area and y; sonal moni'orlng equipment. (9) It 'udes medical jnd recordkeeping costs, (10) ftodu ;tlvlt) Joit ' the Industry average cost of additional capacity, personnel, etc. to maintain Industry capacity level" tinimpacted Ly OSHA regulations. Industry inter.'lews and Snell estimates. -- t ity ) ) s' |hmi4 at co c* I EXHIBIT V-2 USDOI/OSHA Snell uwmnent of VCM level potentially achteved(l) Total plants in samples 9 Recesses representedf2); O, STO, DO, DC, G Location of plana Inamplest 8W, 1C ESTIMATED INDUSTRY COSTS IN ACHIEVING A 25 PPM VCM CHUNG LEVEL IN VCM PUNTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL CapacityIn Sample - MUllcot lbs. per year (Percent 1974 U.S. nameplate capacity)! Percent Induttry claimed capacity from rample subject to thutdovra at a 25 ppm ceiling VCM levelt 0% Snell estimate of percent capacity from sample subject to tfiutdown at a 25 ppm ceiling VCM levelt 0% Direct Costs Capital (8/1.000 lb.) Annual (3/UOOO lb.) 5,125 (77%) fttreent of Total Annual L Engineering costs*4) 1L Personal Rpripment Coms(6) QL Monitoring 82.15 0.07 0.17(8) 80.71(6) 0.04(7) 0.25H. M) 59% 3 21 Total Direct Cost(10) >2.37 81.00 gf> Productivity Lon $0.36 80.21 Vfr Total Costs 82.73 81.21 100% Notest (1) Snell ertimate of VCM levels achievable in plants Incorporating die level of control effort represented In the Exhibit. Monitoring data U detailed In Appendix o. (2) O Oxychlorlnatlon, STO Stauffer Oxychlotlnatlon, DO Dow Oxychlorlnatlon, DC - Direct Chlotlnstfrm, G * Goodrich Oxychlorlnatlon. (3) w sited in warn oilman, C Sited In cold climate. (4) Includes ventllatloa, vapor recovery, stripping, loading and odier (piping, general pumps, maintenance, etc.). (5) Includes capital amortized 12% - 10 yrs. and O&M charges. (d) includes breatlilng equipment and olodilng, (7) Include! capital amortized 0 12% - 5 yts, and OAM charges, (8) Include! area and pertonal monitoring equipment, (9) Includes medical and recordkeeping orwts, (10) Productivity lots la the Induttry average oost of additional capacity, personnel, etc. to maintain Industry capacity levels unimpeded by 06HA regulations, Soutcei Induttry interviews and Snell estimates. lUAr 0 O EXHIBIT V-S USDOL/OSHA Snell asseament of VCM level potentially achleved(f) Tout plena In sample!: 9 Recesses represented^): O, STO, DO, DC, G Location of plana In sample^3); 8W, 1C ESTIMATED INDUSTRY COSTS OF ACHIEVING A 15 PPM VCM CEILING AND 5-10 PPM TWA LEVELS IN VCM PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL Capacity In Sample-Millions lbs. per year (Percent 1974 U. S. nameplate capacity): Percent Industry claimed capacity from sample subject to shutdown at a 10 ppm celling and 5-10 ppm TWA VCM level: 0% Snell estimate of percent capacity from sample subject to shutdown at a 10 ppm ceiling and 5-10 ppm TWA VCM level: 0<J1> 5,125 (77%) Direct Costs Capital (J/1.000 lb.) Annual (S/1.000 lb.) hreent of Total Annual Cost L Engineering Costst4) 1L Personal Equipment Co*t(6) nt Monitoring $3.59 o.n 0.24(8) S1.2I?6) 0.08(7) 0.29(7,8,9) 61% 4 Total Dltect Costs Productivity Lossf 12) Total Costs $3.94 SO, 64 $4.58 $1.58 $0.41 $1.99 79% 21% 100% Notes: (1) Snell estimate of VCM levels achievable In plants Incorporating the level of control effort represented In the Exhibit, Monitoring data la detailed In Appendix B, (2) O s Oxychlorination, STO Stauffer Oxychlorination, DO 3 Dow Oxycholorlnatlon, DC Direct chlorination, G Goodrich Oxychlorination. (3) W a Sited In warm climate, C - Sited In cold climate. (4) Includes ventilation, vapor recovery, stripping, loading and other (piping, general pumps, maintenance, etc.). (0) Includes capital amortised 19% 10 yts, and OAM charges. (6) Includes breathing equipment and clothing. (7) Includes capital amortized $ 12% 5 yn, and 0AM charges. (8) Includes area and personal monitoring equipment, (9) Includes medical snd recordkeeping costs, UU) Roduetlvlty 1ms Is the Industry average annual cost of additional capacity, personnel, etc, to maintain capacity levels unimpacted by OSHA regulation!. ftareif Gtfw&y (nrervfewi ind Snell eHlirmei, EXHIBIT V-4 USDOL/OSHA Snell assessment of VCM level potentially achieved^1' Total plants In sample; S Processes tepresentedCO: 0, DO, STO Location of plants in sample!3); 5W ESTIMATED INDUSTRY COSTS OF ACHIEVING A LESS THAN 10 PPM VCM CEIUNG AND 1-5 TWA LEVELS IN VCM PLANTS AS CLAIMED BY INDUSTRY AND ASSESSED BY SNELL Capacity of sample: Millions lbs. pet yeat (percent 1914 U.S. nameplate capacity) 2,950 (44$) Percent Industry claimed capacity from sample subject to shutdown at a 10 ppm celling and 1-5 ppm TWA VCM level 42$ Snell estimate at percent capacity from sample subject to shutdown at a 10 ppm celling and 1-5 ppm TWA VCM level Capital Annual Direct Costs ($/1,000 Lb.) (*/1,000 lb.) Percent of Total Annual Cost I. Engineering Costs!4) *4.56 *2.18^) 51$ II. Personal Equipment Costs!6) 0.63 0.24<7) 6 III. Monitoring 0.24<8> 0.3lP..) 7 Total Direct Costs Productivity Loss'*0) Total Costs *5.43 *1.88 *7.31 *2.73 *1.51 *4.24 -5tt 3S$ 100$ ^otes- f1) 3ne^ estimate of VCM levels achievable in plants incorporating the level of control effort represented In the Exhibit. Monitoring data is detailed in Appendix B. (2) 0 = Oxychlorination, STO = Stauffer Oxychlorination, DO = DOW Oxychlorination, DG = Direct Chlorination, G = Goodrich Oxychlorination. (3) w = Sited in warns climate, C Sited in cold climate, (4) Includes ventilation, vapor recovery, stripping, loading and other (piping, general pumps, maintenance, etc.) (5) Includes capital amortized @ 12$ - 10 yrs, and O&M charges. (6) Includes breathing equipment and clothing. (7) includes capital amortized $ 12# - 8 ya, and O&M charges. (8) Includes area and personal monitoring equipment, (B) Includes medical and recordkeeping costs, (10) Productivity loss is the industry average annual cost of additional capacity, personnel, etc, to maintain industry capacity levels unimpacted by OSHA regulations. This Is bawd on dioic plants that expected ability to meet the claimed levels shown In the Exhibit, Source; Induihy Interviews and Snell estimates. u- O < 01 EXHIBIT V - 5 USDOL/OSHA U.S. INDUSTRY CLAIMED TIMET TO REACH SELECTED VCM LEVELS IN VCM'PLANTS THROUGH ENGINEERED CONTROLS VCM Standard SO ppm ceiling 25 ppm ceiling 15 ppm celling & 5-10 ppm TWA <10 ppm ceiling & 1-5 ppm TWA Sampl? Total Number of Capacity Plants (million lbs) 1974 Number of Percent'x' Plants Capacity 1975 Number of Percent Plants Capacity 9 5125 9 10 0^ 9 5125 1 5% End of Year 1970 Number of Percent Plants Capacity 1977 1978 'Number of Percent . Number of Percent Plants Capacity Plants Capacity 8 95% 9 5125 3 49% 5 40% 1 5% 5 2950 2 51% 3 49% Notes: Source: (1) Percent of sample 1974 capacity Industry Interviews by Snell ", 'i,.1 J^ -1 ^? VCM Level Claimed By Industry Direct Costs of Compliance 50 ppm ceiling 25 ppm celling 15 ppm ceiling with 5-10 ppm TWA <10 ppm celling with 1-5 ppm TWA (2) 0.06 0,10 0.16 0.27 EXHIBIT V - 6 USDOL/OSHA SUMMARY OF THE COST IMPACTS AND TIME COMPLIANCE CLAIMED BY VCM INDUSTRY Unit Costs, d/ib. Costs to Make Up for loss of Productivity Total Costs^ Compliance Period Percent of Industry . Required For "Endangered'^ Engineered Controls Based On Sample 0.01 0.02 0.07 1 10% 0.12 - 20% In compliance now 2 years 0% 0% 0.04 0.20 35% 2.5 years 0% 0,15 0.42 50% 3 years 42% Notes: Source: (1) The percentage ranges of total costs represent Snell's estimates based on partial statistical analysis of data (2) Two of the plants in the sample representing 1150 million pounds per year (22% of the 9 plant sample) estimated the ability to reach a 1 ppm VCK1 celling and 1 ppm TWA (3) Endangered = management will seriously consider plant shutdown Exhibits V - 1 through V - 5 iO a 3. THE ESTIMATED ECONOMIC IMPACT OF STANDARDS ON THE POLYVINYL CHLORIDE INDUSTRY RANGE FROM 0.72$ PER POUND TO MEET A 50 TPM VCM CEILING TO 2,73$ PER POUND TO MEET A 25 PPM VCM CEILING AND 10 TO 3 5 PPM TWA AND SUSTAIN 1974 CAPACITY Snell assessed industry costs of reducing VCM levels in PVC plants were separated into five categories which include: engineering costs, including: VCM unloading ventilation reactor cleaning stripping and VCM recovery other (pumps, piping, etc.) '' personal protective equipment costs, including; showers and eating facilities breathing equipment (respirators, air lines and bottled air) clothing (uniforms and protective clothing) monitoring costs, including: .. personnel monitoring equipment .. area and leak monitoring equipment .. medical testing .. recordkeeping 0 productivity loss .. the cost of keeping at the levels unimpacted by OSHA capacity otherwise derated as a result of regulation cn .. the cost includes equipment, personnel, etc. co V- 5 C$NV SBUSBR expensed items .. these include consultant costs, management time, etc. out-of-pocket expenses of 0.033$/lb are not included in the cost summaries Summarized estimates of PVC industry cost impacts and timing to meet selectedVCM concentration levels are presented in Exhibits V-7 through V-l' after page V-81 Exhibit V-7 presents the case of the 50 ppm VCM ceiling Exhibit V-8 presents the case of the 25 to 40 ppm ceiling and 15 to 25 ppm TWA Exhibit V-9 presents the case of the 25 ppm ceiling and 10 to 15 ppm TWA Exhibit V-10 presents the case of the "no detectable" VCM level based on data provided by the Firestone Tire and Rubber Company . . Firestone was the only PVC producer reporting the ability to meet a "no detectable" VCM standard primarily using engineering controls. Exhibit V-10 presents the Firestone information for the two Firestone plants. These plants were not included in the indus try summaries since the Firestone recommended measures to meet the 50 ppm standard were not estimated to be complete for two years. In addition, the Firestone estimates were inconsistently high with estimates provided by the.remainder of the industry at higher VCM levels, for example 50 ppm, and Included environmental protection measures, such as incineration and water pollution control, not directly determining OSHA compliance at the higher levels. V-0 v^tsV 1514 "y C pajk CJf Cl .. Exhibit V-10 also presents the Firestone economic impact data as a weighted average over the Firestone capacity of 507 million lbs. per year. Exhibit V-ll presents the PVC industry claimed time requirements for compliance. Exhibit V-12, following Exhibit V-ll, serves as a summary discussion . of findings. 4. INCREASINGLY STRICT VCM COMPLIANCE REQUIREMENTS ARE EXPECTED TO RESULT IN SIGNIFICANTLY GREATER PRICE ESCALATIONS FOR PVC THAN FOR VCM Exhibit V-13, following Exhibit V-12, presents the estimated impact of selected VCM standards on VCM prices. VCM prices are estimated to be reasonable through a 15 ppm ceiling and 5 to 10 ppm TWA since supplies are not expected to be affected. The 8.0C/lb price at the less than 10 ppm VCM ceiling and 1 to 5 ppm TWA is viewed as being on the low side since the effect of the claimed 42% of industry capacity possibly lost as a result of this standard should cause additional P'-jce increases due to supply and demand factors. Exhibit V-14, following Exhibit V-13, presents the estimated impact of selected VCM standards on PVC prices, . PVC prices are estimated to be reasonable through a 25 ppm ceiling and 15 to 25 ppm TWA, since only 9% of supplies may be affected. * That is, a 9% expected reduction in supply was claimed in the indus- try sample. V-7 *H7 The 22.9C/lb through 30.5<t/lb prices at less than a 25 ppm ceiling and less than a 10 to 15 ppm TWA arc viewed as being on the low side, since the effect of the claimed 31% to 100% of industry capacity possibly lost as a result of the lower standards should cause addi tional price increases due to supply and demand factors. ***** This section presented economic impact details. The next section discusses personal protective equipment. 1516 % V-8 "T'* o* "vE I VB. PERSONAL PROTECTIVE EQUIPMENT AND HYGIENE RELATED FINDINGS AND CONCLUSIONS Preliminary discussion follows. 1. TWO OF THE FOUR TYPES OF RESPIRATORS LISTED UNDER THE PROPOSED PERMANENT STANDARD (PPS) ARE READILY AVAILABLE FROM AT LEAST ONE EQUIPMENT MANUFACTURER . As presented in Appendix Exhibit D-8, two of the typos of OSHA listed respirators are available from the manufacturer in approximately two to four weeks from the placement of the order. These types are: pressure demand full-facepiece self-contained breathing apparatus (PD) combination pressure demand full-facepiece respirator and pressure demand self-contained breathing apparatus (CPD) The two other types of breathing apparatus listed in the PPS are not currently produced. Interviews with manufacturers indicate that these devices are considered wasteful of compressed air. These types are: - positive pressure full-facepiece self-contained breathing apparatus combination continuous flow respirators and a pressure demand self-contained breathing apparatus. 2. THE REQUIRED TYPES OF RESPIRATORS PURCHASED UNDER THE 50 PPM TEMPORARY STANDARD MAY BE USED UNDER LOW VCM CEILING CONCENTRATIONS . The purchase costs for types PD and CPD from Exhibit D-8 are $515 and $615, respectively. V-0 4.>. `d'vv 'rti'.'i-' The operating and maintanance costs from Exhibit D-10 range between $500 to $1,000 per man per year, with an average of data estimated at $900. The cost of grade D or better breathable air is $15 per 310 SCF cylinders. With an air flow of 4 CFM, this amounts to a cost of $0.20/minnte. 3 INDUSTRY AND THE EMPLOYEES PREFER HALF-MASK AIR LINES CANISTER OR CARTRIDGE TYPE RESPIRATORS OVER THOSE REQUIRED BY OSHA IN THE PPS Industry and worker preferences and human factors are detailed in Exhibits D-l through D-4. Self-contained devices are heavy, bulky, and require highly trained individuals. Air line respirators are much lighter than self-contained, but they require a long hose for the air supply and a complicated air distribution system. Cartridge and canister types are the lightest and least expensive of the three, but lifetime has not yet been fully established for atmospheres containing VCM. Users of cartridge or canister type masks have no way of knowing when their air purifier is no lenger effective. Half-face mask types are more comfortable to wear than those with full-facepieces, however, they do not provide complete facial protection. 4. THE NUMBER OF COVERED WORKERS NEEDING RESPIRATORY PROTECTION INCREASES WITH A DECREASE IN PERMISSIBLE VCM CONCENTRATION LEVELS OR REQUIRE HIGHER RESPIRATORY WEARING TIMES The following table summarizes case studies of the percentage of workers needing respiratory pro tection as a function of VCM permissible levels, climate of plant location, and plant type (VCM or PVC). Further data will be provided in the final report. v-io 154$ Plant Type Climate of Plant I.ocation Ceiling VCM level fppni) Percent Of Workers Weeding Respiratory Protection VCM Warm 50 25 10 . 10 1 15"/, 15 30 Id 100 PVC Warm Cold 50 25 10 ppm TWA 4 25 ppm ceiling 1 50 25 1 75 100 100 NA 100 100 100 Source: Exhibit D-ll and Snell Assessment Percent Of Time Respiratory Protection Weeded SO1/, 50 75 50 100 1 3 25 NA 10 25 100 Comments With engineering Controls With Engineering Controls Without Engineering Controls With Engineering Controls With Engineering Controls With Engineering Controls With Engineering Controls With Engineering Controls With Engineering Controls Without Engineering Ccatrols Without Engineering Controls Without Engineering Controls 5. MOST OF THE TYPES OF PROTECTIVE CLOTHING ARE AVAILABLE WITHIN FOUR WEEKS FROM ORDER PLACEMENT '! Disposable clothing, hoods,shoe covers, gloves and overalls are available within one week from the manufacturers including one piece pressurized suits, as shown in Exhibit D-9. G ^ Permanent (reusable) work clothing is also available within one month of order. Full impervious pressurized suits however, have a procurement lead time of at CJt least two months. BBsssnsm T51 V-ll m i... 6. COSTS FOR PROTECTIVE CLOTHING VARY WITH TYPE, WITH A LOW OF $3,50 FOR DISPOSABLE CI.OTHING TO A HIGH OF $178 FOR A PERMANENT, IMPERVIOUS FULL PRESSURIZED SUIT A full suit of disposable clothing including coveralls, hoods, shoe covering, and gloves costs approximately $3.50. . Permanent work clothing costs in the neighborhood of $40.00 per worker for a full suit of clothing including coveralls, gloves and boots. A permanent impervious full pressurized work suit which can be worn with an air mask costs $178. Industry believes that routine use of these is not feasible on grounds of human factors, indicated in Exhibit D-5 and concluded from the Snell industry interviews. The cost of cleaning a suit of permanent work clothes is in the range of $1.00 to $1.50 per suit, per worker, per day. ***** The next section deals with monitoring equipment. Cl C" C' fl V-12 VC. MONITORING EQUIPMENT, RELATED FINDINGS AND CONCLUSIONS Preliminary discussion follows. 1. THE THREE MAJOR CLASSES OF VCM MONITORING DEVICES: PERSONAL , AREA, AND LEAK, ARE ALL AVAILABLE TO THE VCM AND PVC PRODUCING INDUSTRIES Personal monitoring, which is the technique recommended to OSHA by NIOSH (see Exhibit E-3), is available to industry from the manufacturer within two months from time of order. The gas chromatograph needed for the analysis of their samp'cs can be received from the manufacturer in two to three months time. . Area monitoring systems of the automatic sequential or continuous type can be obtained for installation within six months from time of order. Installation could take upwards of two months. . Manual area monitoring systems comprising a gas chromatograph with a flame , ionization detector (FID) and Mylar or Tedlar bags for sample collection can be obtained from the manufacturer within three months. These devices require little or no set-up time. Leak detection devices such as portable gas chromatographs or infrared spectro photometers can be received from suppliers within two months. CJ1 U* v-ia w , l/ p I--* cn C.R t'J 4 2. THE COSTS OF MONITORING EQUIPMENT RANGE WIDELY DEPENDING ON TYPE, HOWEVER, MOST EQUIPMENT PURCHASED UNDER THE TEMPORARY 50 PPM STANDARD MAY BE USED AT LEVELS DOWN TO'AND BELOW ONE PPM VCM Personnel monitoring equipment vary in cost from $300 for automated charcoal tube/pump system to $70 for colorimetric tube devices. For the automated system, a back-up gas chromatograph is required at a cost upwards of $7,000 including basic chromatograph, columns, recorder, and mechanical integrator as shown in Appendix Exhibit D-5. Area monitoring systems of the sequential gas chromatograph type cost in the neighborhood of $12,000 per 10 point instrument system without installation. Those operating under the FID total hydrocarbon principle can be purchased for $8,000, again without installation charges. Leak detection equipment, which are either of the portable gas chromatograph, total hydrocarbon FID, and infrared types cost from $3,000 to $5,000. No installation is required for these devices. 3. EXPENDITURES FOR MONITORING EQUIPMENT FOR A TYPICAL VCM OR PVC PLANT AVERAGE $100,000 IN CAPITAL WITH ANNUAL OPERATING EXPENSES OF $80,000 . Personal monitoring equipment of the colorimetric types do not require a chemist for back-up due to their instantaneous reading capability. The charcoal tube types, however, require a trained chemical technologist for analysis of samples due to the necessity of using a gas chromatograph. At least one chemist per plant is needed at an annual cost of $15,000 to $20,000. V-3 4 AUTOMATIC SEQUENTIAL MONITORING SYSTEMS (ASMS) CAN SERVE AS A LONG TERM DATA COLLECTION SYSTEM FOR AN ENT1 HR PLANT The ASMS can analyze an air sample from a particular point in the plant in 1 to 3 minutes with potential for at least 10 point monitoring. A system installed in the polymerization building can provide warning to work personnel in that area if VCM levels have gone above ceiling levels. Personal monitoring data can provide the statisitieal basis for locating sampling points for the ASMS . TWAs can be determined by the personnel monitors for critical areas those values can provide a calibration for the ASMS and determine the points within an area where the greatest VCM exposures are most likely to occur. The ASMS can be used to provide correlation witli personnel monitoring d; ' i of actual worker exposure. In addition, it can bo used to provide a permanent record of VCM levels, provide alarms in case of exceeding ceiling values, serve as a means to initially identify the general sources of VCM releases, and to monitor progress in complying with OSHA requirements. THE AUTOMATIC SEQUENTIAL MONITORING SYSTEM CAN PROTECT WORKERS AND ALERT MAINTENANCE PERSONNEL WHEN EXCESSIVE VCM CONCENTRATIONS OCCUR VCM emissions can occur from two sources: slowly developing minor continuous leakage, such as a worn pump seal V-1G The cost of installation for automated sequential or continuous area monitoring systems is approximately $15,000 per 10 point unit with operating and maintenance costs of about $30,000 per year with an operator. A mini-computer can bo interfaced with the system for alarming and recordkeeping for an additional $10,000 to $15,000 and OOM costs of $4,000 per year. Leak detection devices cost in the area of $2,000 to $3,000 for OfiM including a part-time operator for each instrument. THE INDUSTRY AS A WHOLE SHOWS NO PREFERENCE FOR PARTICULAR TYPES OF MONITORING EQUIPMENT, ALTHOUGH THE CONCEPT OF AREA MONITORING APPEARS WEIL ACCEPTED. The VCM and PVC producing industries employ a variety of different types of monitoring equipment in each classification. , In personal monitoring, both the colorimetric and charcoal tube system are employed. However, the charcoal tube type are sensitive to lower VCM con centrations than colorimetric devices. . For area monitoring, both gas chromatographs (GC) and total hydrocarbon analyzers arc used. gas chromatographs provide concentration values which are specific for vinyl chloride monomer total hydrocarbon analyzers, as their name suggests, arc not specific for VCM but givo the total hydrocarbon concentration in the sample air, V-16 * AEsa serious leakage, such as resulting from an operating error (e.g. valve left iully or partially open) or a serious sudden leak (e.g. blown gasket, sight glass breakage, ete.) In both eases, the system can prove useful in alarming the potentially affected people. In the case of a minor leak however, (with localized effects) the sample point nearest the leak will register the localized concentration and alarm on the next sampling indicating localized concentration above the limit. . Response to either type of alarm can be standardized. These steps could include donning of personal protective equipment, investigation using leak detectors, isolating the point of VCM release and corrective maintenance. , t * **** The next section deals with medical surveillance costs. CJ1 V-17 VD. MEDICAL SURVEILLANCE COSTS, RELATED FINDINGS AND CONCLUSIONS Preliminary discussion follows: 1. THE AVERAGE TIME REQUIRED PER EMPLOYEE FOR THE REQUIRED MEDICAL EXAMINATION IS FOUR HOURS WHEN PERFORMED OUTSIDE THE PLANT " From the information presented in the Appendix Exhibit F-2, the time allowance per employee is itemized as follows: . Travel to and from examination facility -- 2.5 hours . Examination and laboratory tests - 1.5 hours Maximum time required - 4 hours or 1/2 working day 2 THE SNELL ESTIMATE FOR TOTAL EXAMINATION COST PER EMPLOYEE IS $160 The cost estimate developed by Snell is based primarily on thetests and examination procedures recommended to OSHA by NIOSH as detailed in Exhibit F-3. The costs were estimated for examination and tests completed out side the plant for a manufacturing facility with 500 covered workers. The total cost for such a plant would bo approximately $B2,000/year. CJ1 CN Ci v-ia 3. INDUSTRY ESTIMATES OF THEIR PRESENT MEDICAL SURVEILLANCE COSTS AVERAGE $3 <10 PER WORKER PER YEAR. ' - -- -- - ~~ " It was assumed by Snell that the examinations performed by the reporting plants were based on the NIOSH recommendations Vo OSI1A. This will be confirmed prior to the submission of the final report. ****$ The chapter that follows presents next steps in the study. O' h' !-* CJ ................'! .................................. ............ V-19 APPENDIX D PERSONAL PROTECTIVE EQUIPMENT AND HYGIENE Ol Ol c APPENDIX D PERSONAL PROTECTIVE EQUIPMENT AND HYGIENE This appendix presents the elements of personal protective equipment and hygiene as related to their purpose, costs, and availabilities. The appendix summarizes the relevant portions of the testimony at the public hearings and details which types of equipment have been purchased by the industry. All exhibits follow the text of the appendix sequentially. 1. REVIEW OF THE REGULATORY REQUIREMENTS PRESENTED BY THE QSHA VINYL CHLORIDE TEMPORARY AND PROPOSED PERMANENT EXPOSURE STANDARDS IN RELATION TO PERSONAL PROTECTIVE EQUIPMENT AND HYGIENE ARE SUMMARIZED BELOW This section summarizes the requirements of employers in the vinyl chloride monomer (VCM) and polyvinyl chloride (PVC) producing industries concerning breathing equipment, protective clothing and personal hygiene as they relate to both the temporary and proposed permanent exposure standards. (1) The Emergency Temporary Standard (ETS) For Exposure To VCM^ * The ETS applies to any area or operation in which VCM is: manufactured reacted handled processed released repacked stored (1) 29 CFR 1910, Occupational Safety and Health Standards Emergency Temporary Standard for Exposure to VCM D-l Wherever any monitoring sample reveals VCM at a concentration in excess of 50 ppm, or whenever any accident, such as rupture of equipment or spillage, indicates the likelihood of a greater than usual release of VCM into the ambient air all employees exposed to such concentrations should be withdrawn to a safe area the employees should not be permitted to re-enter the work area unless they wear either ,. type C continuous flow or pressure demand air-supplied respirators ,. self-contained breathing apparatus . Work which may reasonably be expected to release VCM in concentrations in excess of 50 ppm, such as the repair maintenance cleaning of a reactor or other equipment containing VCM, should be accomplished only by employees wearing type C continuous How or pressure demand air-supplied respirators or self-contained breathing apparatus. (2) The Proposed Permanent Standard (PPS) For Exposure To VCM^ . The PPS "states that engineering controls are favcreu 'othods of compliance C-' because they tend to avoid contamination of the ambient air in the workplace. However, until these controls are instituted it requires the use of respirators of the continuous flow or pressure demano *ypes oJy. Ti e PPS requires CJ1 CD (1) 29 CFR 1910 Occupational Safety and Health Standards, Proposed Standard. O D-2 CJ1 cn Cfl a respiratory protection program in accord with CFR 1910.134 should be established and implemented where respirators are required to be used by the PPS respirators should be used only in cases of emergency and where engineering controls or change in work practices have not as yet been instituted respirators or combinations of respirators for protection from VCM should be selected from among the following types: .. positive pressure full facepiece self-contained breathing apparatus pressure demand full facepiece self-contained breathing apparatus operating in the pressure demand mode combination type C pressure demand full facepiece respirator operating in the pressure demand mode and a pressure demand self-contained breathing apparatus operating in the pressure demand mode .. combination type C continuous flow respirator and a pressure demand self-contained breathing apparatus operating in the pressure demand mode ' Employee entering regulated areas should be provided with full-body protective' clothing, footwear or shoe cover, at no cost to the employee. The employee should be required to wear this clothing. Where PVC powder contains detectable levels of VCM in handling, employee should also be provided and required to wear head covering required to remove all protective clothing at each exit from the regulated area D-3 : W>. required to shower after the last exit of the day clean protective clothing should be provided whenever contaminated or soiled, but not less frequently than weekly contaminated clothing should be decontaminated before re-use by removal for laundering or disposal Where employees are required by the PPS to wear protective clothing and equip ment, change rooms should be provided in accordance with 1910.141 (e). Where employees are required by this section to shower, shower facilities should be provided in accordance with 1910.141(d) (3) . The PPS prohibits in regulated areas the storage or consumption of food or beverages the storage or use of smoking or non-food chewing products the storage or application of cosmetics 2 A SUMMARY WAS DEVELOPED OF THE STATEMENTS OF INDUSTRY AND GOVERNMENT REPRESENTATIVES PRESENTING COMPARISONS OF PROTECTIVE EQUIPMENT TYPES AT THE OSHA HEARINGS ON THE PPS This section presents summaries of selected statements of witnesses at the OSHA public hearings who gave test results on detailed comparisons of respiratory protective devices and protective clothing. These are presented in five exhibits. Exhibit D-l presents the statement of Karl Oelfke, Dow Chemical Company comparing the types of respiratory devices. Exhibit D-2 details the presentation of Dr. Joseph F. Tomashefski of the CT1 Cleveland Clinic also comparing various types of respiratory equipment. cn fj D-4 4. A SUMMARY WAS PREPARED OF SNELL INTERVIEWS WITH VCM AND PVC PRODUCERS TO DETERMINE THE COST OF RESPIRATORY EQUIPMENT AND PROTECTIVE CLOTHING UNDER THE ETS AND THE PROJECTED EXPENDITURES FOR VCM LEVELS BELOW THE ETS In this section of Appendix D the results of Snell's interviews with the VCM and PVC producing industry in relation to present and projected costs of respiratory equipment and protective clothing are presented. The exhibits detail: . Purchased equipment and clothing types . Capital costs . Operating and maintenance costs(OSM) . Procurement lead times . Relevant industry comments regarding topics such as human factors The information is arranged in the following manner: . Exhibit D-10 summarizes the costs to the industry for protective equipment under the ETS. ' . Exhibit D-ll presents case studies of cost profiles for respiratory equipment as a function of VCM levels and projected covered workers, including expected wearing time. > o (? Cl CJ D-B s') Q, at to Exhibit D-3 is another contribution of Dr. Tomashefski. This exhibit is an in-depth discussion of human factors relating to the use of respirators. Exhibit D-4 is a summary of the statement of Dr. Marcus Key, NIOSH, Cincinnati discussing breakthrough times of VCM in air purifying respiratory equipment. Exhibit D-5 is a general composite statement of several individuals relating to the human factors involved in wearing protective clothing. 3. RASED ON A SURVEY, SNELL COMPILED RESPIRATORY DEVICE^ AND PROTECTIVE CLOTHING TYPES INCLUDING DESCRIPTIONS , COMPARISONS , THEIR COST AND AVAILABILITY This portion of the appendix gives detailed description and comparison of the various types of respiratory devices and protective clothing. Also included are their costs and availability to the industries studied by type and manufacturer. As in the previous section, an exhibit format is used for the presentation of the information. Exhibit D-6 is a general presentation detailing the procedure for the selection of the proper type of respiratory protective devices as a function of use. Exhibit D-7 is an in-depth of matrix presentation listing respiratory devices and detailing by type important topics including: function advantage disadvantage comparisons with other types Bureau of Mines approval Exhibit D-8 presents the costs and availability of typical respiratory devices by type and manufacturer. Exhibit D-9 is a comparison to Exhibit D-8 as it describes typical protective clothing types and their cost and availability by manufacturers. D-G W* : i: : ?\ Cl EXHIBIT D - 1 umoi/osHA STATEMENT OF KARL OELFKE COMPARING TYPES OF RESHRATDRY DEVICES AT OSIA hEARINGS fiapltatory Device______ Now-mouth cartridge or ctnliter re*pirator(N-hfi Phil face earthier typo roplrator (FF) w/fice mounted canltter Full race caniitc* type w/chett mimtad cenlater Coothmoiia flow air applied hood (Acid Hood) Condnuoui flow alt applied food (Add Hood) Continuous flow Air supplied full mask Self-contained breathing apparatus Portable breathing air cylinder* ___________ Advantage*____________ . Easy to don . Small vise * Lightweight . Easy to wear and carry rias larger canister tMn N-M type last longer Eye protection Is an integral part of mask t Longer breahdtrough time than above . Good head iptll protection a Good protection , Beat of air supplied breeding apparatus . Mobility # Mobility , Long respiratory protection. Two hours at a demand of 59 L/min. ___________ Dliadvantagc*_________ . Interfere! with cettalo typci of eye protection tuch u goggle! , Can't fit ell facet . Wearing of hard hit become) difficult . Can't fit all face* . BulkIt*** . Can't fit all faaaa . Poor mobility fot waker due to air bote . Bulkina* . Vliloa ratrlcdon . Lack of head movement . Poor mobility for worker , vUlon tetttletlon . Poor mobility for worker due to air hoee . Wearing of hard hat beccxnei difficult , Poor mobility for worker due to air h-ie . Air apply li normally limited to 1S-S0 minute* in the proure demand mode Breakthrough Time 100 cc canister hat breakthrough time of 16 min. at 1 ppm VCM and flow rate of 900 l^mln. Acme canltter of 300 cc line, hid breakthrough time to l ppm of. 23 min, at 1000 ppm VCM. 1 ppm tmaktteough after 1B7 min. Same condition* a* above. (NA) # <NA) (NA) (NA) (NA) Source; KarlOelfke. Production Manager for Vinyl Otlorkle, Teiat Die,, Dow Chemical Co., SUtement preiented to USDOL/OSHA Hearing* on Vinyl Chloride} Occupational Exposure Standard, June 2f\ 1074 and Snell eiicument* 9 K cn CT; EXHWT P3 US DOL/OSHA STATIMCNT OF DU JOSEPH F. TOJ4ASHCr(C( COMPARING TrFES OF RESPIRATORY KJUtFbBNT AJ OCHA HEA04G& jwgcawt^Dajka^ 1. Ail taifylng Type PurWH Uw.d to romovo wowminim* fanm il ainrn^KKc that cnttla it iihrpmi fomirtiarlott of 0* OlDt by wtamo). Method Of Operation Wock by ckhei flltiatkm. adrtpion. or a dwnlcil nidlaa to mmove ceumlnaoti. Advaanfte^ DUadvOiXiga Canine* maaki hato tdicbaf to them a Mt,lnlii| u alwilxui, Such madt am td nine la pme* itoo again*: , Of|Mk TOpota * Acid Ammoda , Cuban dioxide Aaa^mon Intendod to film paniculate* offer no protection *gil gaaoa or vapos, Air pwffyUg mp4itOwl podia Ugh wHitca to bwaiMag. Ado<tiiato fit to dw taco Ham bicaat of dtfhcua ta hi* and ihip and oNdaopoleglul fhaiuotoffetaa la c/taq a pnblom. Maoy amu maaki man bo molded to ladlriduak--m mult tankage Comniaiily aem, They on very offoatv* tad dey can The reelannua to bod taaptatteft aod oxpmttao aim mod provide effective and taiiablo poK^tloo. worker* to dbcaid filter type maaki crpociitty if day oaa*i too da dum yt dk time. no<i-vMbie <M may bo >nmt harmful. Chemical cnittWge .ype maaki ato umelly of do half mad* wiCy, do rbornlnil aitantmnr (efceiooal, aoSa lime, or atlloa gal) hive Yoty limited application aod an of value when oaad apian vapor* and gam of low toxicity. ow*l congncML To prtmg cloggbg of do cantata aad v ducmaae tin rndwmre ta hmethiag tt li pwmivablo w tomow do flkM within Inch dla wlan pntoetloQ agiiMt fnittoulatot b not rooulaod. 2. AltdepplUil Uauaily employe for epoclfk taakt ei for huatdoua enviiwncntt. Thii type he* a how oooaeotad to ao uBBoWaminatod air ihh, They may bo oipippvd w/wo bfewen <x day may bavo an aliUao attachmcia tar HdJlv* 0m or demand flow. They may bt uaod with full faeo matin, hood*, ot wld full body ailn* Many air^nppllad ra*(dmton omploy a ilight Jkjiitive potfurc la octal to (Rvdi lawaid kam. They am good fm baxaidow BtvUuuintmi not immodiauly dtagoiuui to Ufa. Whan biowan ato employed with tuch roaptatoo, It la aocoaiary to bar* an individual attending da btoww or a tund<by. Sock roapiiaioii podece ao inctoned mlnaia to bmadtag. They frequently have a long how wtachod. which, in ftietf, may be a nirtianra or a aataty baa^rd. Than am limltitim on da maxianm laigth of how dal eafi bo wadi Uw w/attblowot: <M ft. . UM t /UmrOh 110 ft. to SOO ft. Oh mwt ho mo that lomptnoJ air auppllod It fiu of CO aod COj* 3. to-Contained PiDTido comptato mtpratMy pro* wcttaei for any ootwominion of toxic gM or oxygon defkleocy. ftenuiu^tatnuvd type. The alight HfiUn pnuuffl initiated by do individual at the bagimiiic of Ingntkia trlggcn tba valve ao that the gar will flow at it it needed tt an eppnyelate rate. Thoy caa ba wmI with an air toum or an oxygatt hum. Tba utf-rowalnm* appacam it heavy, bulky and requlrm highly tralaod iod|vi<kula tar uae. It it nectttaiy wb*n ooe nniployi talf< cowainod nigMtcn to han warning devtaoi Indicating that tin ptenauo tuppiy la gening low. Soqice; Jooaph F. Tomadeftld. Xl, n,, IK-ad of Pulmonary niaeaac IkpaRirwn ot The Ctexulaihl Clinic. Catement prcuitad to WDOL/DSHA burlnga on vinyl chicridei OecopdcQal Expoama Standard. June 3$, 1974 and SoeU atommwn. M- cn C5 EXHIBIT D-3 (1) USDOL/OSHA STATEMENT OF DR. JOSEPH F. TOMASHEFSKI DISCUSSING HUMAN FACTORS IN RESPIRATOR USE AT THE OSHA HEARINGS - PROPOSED PERMANENT STANDARD GENERAL PROBLEMS ASSOCIATED WITH RESPIRATOR USE Problem Areas 1. Safety in Term* of Fit and Improper Sealing of Mask 2. Perspiration 3. Psychological 4. Respirator and Mask Dead Space Problems, If a leak occurs at the mask, especially an inward leak, the toxic materials may be inhaled and a false security will be provided. There is a marked variability in the contour of faces-therefore it is very important that any mask fit comfortably, otherwise an individual using it over a long period of time may find a mask to be intolerable. When effort is expended and work is performed requiring increased oxygen demand, petsplrarion is not adequately evaporated--it remains within the mask and produces an unpleasant effect. Toxic substance may become trapped between the skin and the mask causing local irritation. ___ Allergic reactions have been known to occur, ' Many people find the confinement and sense of Isolation distressing. Others are uneasy about the need to work In an . environment that requires the use of such equipment. It Is very important that the individual not rebreathe exhaled air, and that the dead space in the mask be kept to <150 cc or that the mask be adequately ventilated to flush out the dead space. Otherwise th_te would be rebreathing of exhaled C02 and a deficiency in inspired 02. . Q tJl CJ5 GENERAL PROBLEMS ASSOCIATED WITH RESPIRATOR USE fCont'd.) EXHIBIT D-3 (2) Problem Areas 5. Design Problems Associated With the Eyepiece on Full- Face Masks 6. Speech Transmission 7. People With Respiratory Diseases 8. Personnel Training In the Use of Respirators Problems . They should not distort the vision* . They do decrease the field of vision. . If an Individual wears glasses, the glasses can become fogged or the eyepiece itself may become fogged. . The individual with bifocal vision may have difficulty in performing his task. . It may be necessary .to construct the eyepieces by means of special grinding With built-in lenses , Anti-fogging compounds may have to be employed or a nose clip worn to prevent fogging of the eyepiede. . All of these can decrease efficiency and be uncom fortable and unpleasant for the individual. I. : . Upon movement,of the jaws, die mask may become j distorted and leaks occur, i . It may be necessary to equip the masks with special \ diaphragms, microphones, amplifiers, and radios to provide ability for communication. . People who have bronchitis, emphysema or chronic asthma should not be employed in work using respirarois. . This limitation knocks out a large segment of the working population (approx. 3?7o of all males and females over the age of 35), . Personnel must be trained in respirator use, workings and care. CJ1 CD EXHIBIT D-3 (3) GENERAL PROBLEMS ASSOCIATED WITH RESPIRATOR USE (Cont'd.) Problem Areas 9. Maintenance of Respirators 10. Storage Problems . Masks must be Inspected monthly. . They have to be cleaned and examined after each use. The washing should be done with soap and water or with detergent and allowed to be air or force dried. . Occasionally it may be necessary to sterilize the mask, because it may become a source for bacterial contamination and disease transmission. , Cleaning and repair stations have to be set up where masks or respirators are being used. . Storage is another factor that must be considered. Proper facilities must be provided to keep the respirators and their component parts in good condition. Source: Joseph F, Tomasheftkl, Head of Pulmonary Disease Department, The Cleveland Clinic, Statement presented to USDOL/OSHA Hearings on Vinyl Chloride; Occupational Exposure Hazard, June 25, 1974 and Snell assessment. 2 CJt O i EXHIBIT D-4 USDOL/OSHA SUMMARY OF THE STATEMENT OF DR MARCUS M. KEY AT OSHA HEARINGS - AIR PURIFYING EQUIPMENT TO VINYL CHLORIDE MONOMER BREAKTHROUGH TIMES Respiratory Device Organic Vapor Cartridges Canister Gas Masks Gas Mask Facepieces Teat Conditions VCM concentration* 50 ppm 50$ R. H. Flow rate cotslstent with a moderately heavy work rate VCM conoentratloa* 100 ppm 50$R. H, Flow rate consistent with a moderately heavy work rate VCM concentration* 100 ppm 50$ R. H. Flow rate consistent with a moderately heavy work rate Breakthrough 10$ breakthrough in 40 to 75 minutes Service life decreases as R. H. increases 10$ breakthrough in 200-350 minutes . Service life decreases as R. H. increases 1$ leakage Comments Because the odor threshold of VCM Is considerably higher than the breakthrough concentration, it is the position of NIOSH that the only suitable respiratoty protective devices for VCM are supplied respirators or positive mask selfcontained breathing I apparatuses^ Source: Marcus M. Key, M.D., Director, NIOSH Center for Disease Control, Statement presented to USDOL/OSHA Hearings on Vinyl Chloride; Occupational Exposure Standard, June 25*, 1974 and Snell assessment."" ' I Maury RjfpreaemiHvt K. H. OellW11 r r. hoj< DCHH1T D-6(X) USDOiyOfflA STATEMENTOF INDUSTRY REPRESENTATIVES CN HUMAN FACTOJB RELATING TO PROTECTIVE CLOTH WO AT THE 031A HEARTS Clothing Tvp* Pull Impervious pressurised wit Ad ventages ftoreerlv* against vinyl chloride Full body Impervious air supplied wit fctvtntt vinyl chloride ges from Wmtscitng body impervious v>tOb Prevents vinyl chloride from compering hindi ________ Piniwiim flicci worker In situation of unacceptable heat stress Prevents body heat ind moisture Irom putlog 10 ft* atmosphere Garment would guarantee k>ngternt exposure to VCM II. by chance, tome of ft* gis entered the nerment Gloves will dlmlnlth employee's dexterity ftiyiloiogjcxl Considerations A vrotker, while veering such * suit Id a son efter & minute* sitting At 85 F ambient tempeteove, had a skill KmpeiAtw of lQO, 9 t. After live AddttlonAl minntci of iIoj walking ftc skin temperature wet H>1. $ P end she body tempera ture which had botnPM* F At ftc beginning of ftc ten, we* to 10*.* F. Human Factors Suit tend* to be safety haexird because of la bulkinet* and limited visibility Hearing is difficult Comnwileation-wtih others l* almost Impossible . Comments The use of this type wit should be limited to emergency situations The hcAt And dlscomrors produced vtlt produce fatigue reducing employee ale/mes* fatplrarlon generated by the tula will cause severe discomfort Reduction of employte efficiency due to cumulative erects of fatigue, Ukiurc footing fttactbr cleantit, requited by thrlr Job to be sure footed, will be greatly Impaired by bulk of suit Employee efficiency will drop as much as ?Sft when sudt suits ate wem Operators will find Ir difficult to operate controls and keep records, and maintenance men, particularly instrument and electrical repair men, will not be able to perform fttir Jobs safely and properly hemiura wipes will be required to Induce employees wear suits ttecognlxlng the fact that the wilt represent a safety hazard, ftc Secretary of Labor did not requite their use in the carcinogen iiandiitii Because reaetor cleaners are identi fied at a group of maximum dsk they ftouid be supplied with'protective" mrher than impervious clothing and gloves in order so protect them from skip contact ci -a I !v..v 11 . <) ',f**>f* 'it tftdamy KcPe*em--Ivg ll. H. Favtori'M Uothilltf Type Air milled ft'ln lfc*l>ped (or etactly the kind of Haitian 14 meter cltBlo| PhjdTiftfgci _ Wiyttokglcal Ccntlderariont BCHtSTT D-#<1) Hutton Ftcton People could work Tor long period* of rim* wearing tit wipplted min 1/ die lr ware directed throughout (he ait. Comment! People don't want thl* type of equipment because it it trouble and eo*tt money Equipment can be ooed If people are educated *0 ute ft and know die advantage* and neceeriry for utjng lr Souraa; fit "wknm mbmiulon by K, H. OelfVn, Producth* Manager at the Teiu DlvUion of Dow, Chemical I'.S A. pie*enred at rite USD0U/05HA Hairing on the propoted permanent itandard for occupational expaure to vinyl chloride. June 2S. 1974 (D Statement of F, P Hoy. plant manatft. Flreimoa nattkiCompany, FeoyvOIe, McryUnd prewnted at USD0I/05HA Hearing on die prapoeed permifeor rtanda/d for occupational ertpoture to vinyl chloride. July Id. W74 (3) statement of H,H. Fawcett, Chairman of the Committee on chcniicat Safety of the American chemical Society at the USD01705HA Hearing* on the propoted permanent standard for occupational eapmura to vinyl dilorldc, Jety 9, 1974. (4) Snell aaaesment, I ^J H* CJI VT EXHIBIT D-6 CI <s cn --.3 cc Note? ouri-e: K'jmheri 1* pireiiil*:!*! refer t j ll'iresu of Mlnti KrlioJulei *ml Pcvliioiu rlwn af. After 'tnicin of MIikj lnform..tJoti circular 77C>2 c; a 4 CJ1 .v AetOiWtCtV Device 1. Atr Furifirtw Dcvicei (I) Mectnuloct Film ^f*ton 9) Onwtical CenrtJgjn tottMon Application Air Purifying PeWCct itTOt contaminant! tom the etmeipheic. Mechanical Filter htiplreion provide Mfitiuty iwteetoo agalOM particulate miner tucA a* noo-yoUtile dun* mud, or mciat feme*. Selection or the Jjpioprtitc respirator it hated on tht type, toafclty, ad particle site of die particulate matter. Chemical rlartridge Rctptawm afford preteetjoo aKlimt light coo> CcOUStioa (,0B* to ,1-Vhy volume, depending epee the contaminant) of cuitli acid gem. illeliM garni. Hfidt vipM, and monety v*pot by vtiUsing vtritwa rhemieal ftlten to purify the inhaled air. Method of Optnrtofl Umltnt|onj_ vadm chemicals remove ipedfU gases Hit vapon and mechanical Alien remove partieulitc wiitii. Can be iued only in atnwtphcrei containing lufflcienr oxygen to surein life (at lent ld> hy volume at tea level) and withIn tptcifiad concentration limitatloni of ih tpeclfle device. Tiny eomlft tuermilly of a soft tviiUertt fkeepicce of clibv half-mask or (uil-faee dedyn. to which U directly attached one of revual type* of mochatdeal Alien made up of mmc fthmei material wMeh temovc* dre harmful particle* by phyrical topping at ait li Inhaled through th material, caretmi miner such a> air inelf will pare duougfc die Alter, but solid ru Uuuid particles am topped in much the Mme manner n tncto and pcbbiei ' are wpanied tom send in a tnetniflg procore. The filter mure be MJily efficient however to ttop the imall harmful partkki. Mechanical filter t*quieten do not provide against gates, vapon or oxygen deficiency, They differ fiW mechanical filter lelpireum only in that they me renal! cartridges comainlng chemicals to remove harmful gate* and vapon. Chemical Camidge feapinten are non* emergency mptremry protective devlcn and mould never be uaed in imrnadiaiely dangerous atm^btMi, except foe escape Ucfr1 Life The treefal ala of an air purifying device ii dependent upon ft# eencenaadon of Aw MmamureoQt tba breathing volume of die wearer, and the capacity of the air purifying medium ' However, to clarify tirfi generel itarement. it will be well to Hit four odire major negative relei which apply to Cbemlc." Cartridge Ifesptretorti . IVi not u Chemical Cartridge Hoptoton for protection againit gaaooos material which ti extremely tale in vrty onaU concertiretioru (carcinogen! wch at VCM), , Chemical Cartridge hrspiiuton dwuld net be ured for exposures m harmfol caseous marerr which ranore rloariy be detected hyrelnr t VCM in concentrelliMW < |M> ppin. EXH1HT 0*1 (1) usdol/osha compawsom or resnitATOmr FncncM devices BuMJnee ApBrOiml Commrnti Schedule 21 Other than the dlffercrew between a belf-theik ftcopdece and a foil fleepiece, witch U uacd when the particular axpoaure It harmful o* irritating to the eyre ai well as the reiplretory tract, the filter it the more essential distinction among claws of Htpireton, Tha mou desirable compromise mure be worM out fot cicj cUu with reipeci to breathing area (ds), rcainance to breathing, affideicy In filtering particulates of specific tide rengtt and time required to clog the filter. Schedule 39 Mouthpiece type chemical cartridge rexpiaton offer prelection againit lnwonlnatu eaposuaa 10 llgTil concentration* of |>KI and vapon Of may he ured for nlf`KiCW in dtnaa of cm<' UDphe. The mouthpiece ti sign ysocuoM* eompaetoowtuch a respirator can be cenvenlanily carried by tha workman during all working hom or itored convetdenily near tin work location tor immeduic availability. CamMnatfog mechanical flltgr-dumicil filter retpinmn uiIUh durt, min, or fume filtui with a chemical cartridge for dual or multiple expohoc, Rciptrtum vwlih ladapudoniJy replaceable mechanical fiucri are preferred for ddi type bneauw the dun filter normally plugs before the chemical cartridge ii uhewted. On* eomtdfiatlon mechanical-Chemical filter reiptotor employ* beck mounted filter element and l ripeciniy all wiled for tprey palMitig and welding uyvnilore, wlrere ibe Ur contaminam li concentrated in tom of the wiitkff, 1575 b'' i 01 Cj ^E7 A--toawy Perl-- 1, SuppBod Air Periods (1) Hr U--fiatntinw Cu--anr flow typ-- Appltoafipp fn|4t tit km Qtilrfd* Mint tot long periods of do*. Method of Operation Uminnows deliver breathing Hr through a nipply Shill be need only in dtmnaphetCJ iwt hste connected la rite WcCnn bespit**, Immediately harmful to fife. Alt touts mutt be touted i clean tie And ttiotdwud frequently. Attorn all U cotnfettihlb The Air-IlM lespliaior la connected an * Mltable compressed lit UKc b7 a beta of mil inner diameter end air to delivered *e the ter cooritetototy er leaerndnently in sufficient volume w meet the wearer's breathing require Air-Urn AetptiaMti dull be used only in atmospheres not immediately hapnful h Ufe or bom vUeh the wearer Ua escape without the we of the i--(dt. This llndiadon it wesaaiy bcciioe the air* line miptreior it entirely dependent upon >n air mpply which la not carried by the wearer of the reqdintof. if the air supply bill* the wearer la without respiratory prelection and might --t eaupe both the inuitedUtoly hanttdoua >rniTI[dian Another limitation of ali-line ipitaton It that tha air supply beta bmln ifc* wearer to a Bacd distance km the air supply source. The bureau of Mims apposvet air-linn Kipimon under Sehadnte 19 which bti tha (allowing significant requirement, TOe maximum hoae tongA lor which approval to fidMi4 to 9W bti. and tire maximum pcfmlatibto inlet paatnia to 12S {tog. Approval la sought be specific boaa lengths and inlet pressures with the longest horn lengthi be vdtlch approval la sought aaembud to Um respirator, and rim towut inlet pre-ire Intnwleced to an air ipp)y ttoto, comtaqr flow units nwat deliver at Uan lout cubic feet per minute (CfXI) meiauwd at the boapiece. Tba a--aladon realstance at M Man per minute dial! not exceed oiu (1) Inch of water-column height. Constant ftow udti am wosmally uaad where bam U ample ait supply web at provided by an aii campitem. When helmet) or bonds am u4a the rama requirements mutt bn mat aaeapt that bn flow rata mart be at toast da (9) cubic feet per tninutn. for both type! of Ateemhlted with the highest inlet pie-- and shorten hose length, tha manimom flow dull not exceed fifteen (IS) cubic feet per minute. GonriBet-nev Air-u-- firepiretoi* with faeeplacai alone tired wham ratpiraiory twiMiton only is neeskd, A hood can be added n* tha bcapiecr let protection against adiwi or tint btafl and frequently a hairnet li used fur tliii application with a hood or cap* fined to it. Such units toe used also for toad grinding MMlauAwonl Schedule 19 rotorr 0*7 (9) Accnwy eqtfpmacc ml aa (miaou KfidiKO. fana rebel wins a-- air filters may be --c--17 to eotnee (bat Ac nir is attbe preper p--re aad quality far tombing. Aii-lln# eetpiatJa in ftwtiibed in many types, hit there are Amo haic claaaaa. Them am cogwaoi ftow. demand flow aryl prepare demand-flow, with tha mqdtMon --nipped with half masks or fail baftecea. If eye pwiactton la required, a full Icee- Tha air Apply ti the responsibility of the oath tad In air-Una implzator li approved br UH only whoa It nppUea teipiiAbl* Mr at tha comet preen-- and ftow. The eoraj--d air dull ran* be moat recent icqiimnsaiits of Cofflpmamd <UI AMOCirtion SpndfkatioA CT.l fin Type I. Clam D gaseous alx. This cttnently retiuUes that An carbon nxnrelde level not ucwl 20 pant per million (ppm), Ac carbon dtoxtiU content tax exceed 1000 ppm, and eeodemed hydrocarbooi not exceed 9 rtiUligmmi per cubic WlA lmemafly lubbcatsd piaee-typn compres* tort, overheating suy pcobiee catbon moxlde, uwlliu testing far carbon raononlde or Ac inHallalloe of a comUBt tmmimiing iialyic! to dednble. Some air contptcbeti arc maMbetumd ptdf. leauy m inovtde resptoabto au. They uia oompwlon rut liquids n*h as water or diaphragms for dallvetlng Ac air. mam x: Q tardmtaty Device , Demand typ*s demand typ*s Application Demand type an gettetany wl wheat only tiwifnw J air cylinders am available. Mefaod of foowioa Demand type air-linn icfbtkn witfi half inaslu or fall httpleni dbttvtr air flow only fairing inhalation with exhalation 10 faa atmosphere. For facet conditions when fa* posdbk lowud leafage rtiiwd by tfci M|illn ptaaqi fairim IfanletiotilllWiyi pmil In demand system u wecctpWble nut faera cen't te An wlalively hlgi Alj eomimptioe or die eCMMB flow UfiltL. It pamddo* a positive petunia during both lrfialedon and uhalaAoiw UmUettoos A nilUblc puun Kgulatof Is required iv ciMtt faa i tie all to 4i fac prop*r pressure far breathing, Tba uma mpUrementt far approval apply to die demand typo li Odwanitat flow snlti, upt |be mintnum flow at a niadniVR) inditaneo of two <*) Inchas of water-column height meatuied at tha far*plana faaU fa at least four 14) cubic fact a minute awl not twee than fifteen (if) blf fee* a miane wish all bofa lengtfa tritbdn lb* inlet pa-- tinge far wWfa appeowl li sm#l the exhalation ndtuec at lib Utcn pat mtmilE diall not cxeaad one (1) loch of water. It mutt mew the tame wqidremena far demand lyiUmj except that fae Hade prereure te die far*|dena faell aet exceed 1.0 lnehot of wet**. fae tifaeUtiee udaunee at tb Uten/fniMie 4UQ exceed fae Hade pie mm in the laeejdeee by mom thin 3. o inches of nhrlid fan faeu bn at ls*st 4 O'M air Qow during Inhalation bofau a negative pressure Is developed In the facepiece. . With ktown , Wlfaewt Mown Ikm muk with blowers may bt ippnwl by Ittmlna fat sc^tretasy puofcctloo In any moaffan regardless of the degree of wo undnadon or Nyml 4ctdcACf, providing clean. teeefaabt* air can he reached within ilia iHiUnra sf tha pwrnlsribl* heat length. blower faces air in mask. Ilow masks wlfaoul blower* aw umd tfaan irtetuanilneted air can bo method wlibln a Aiumo of II Ini. Wearer facets air Into mask through hli on breathing. lk*e rnstki with Mowers cm be toed wifa up in 8v0 ft of hole. The blower faould ehrayt be used with this type of equipment. Italy bawl driven blown aim curicntly SppcOvad, The air how mutt haw Urge leafdc dumtter. approximately one l.uh, so, In H Of blower failure, tho wearer can faeafac tiirouifa fae Inna wblU eKSping bom the comamlnawd inii and it tout fa highly fesbuat to pcUelsunt WpWi a* Well ai fa *Wc to wltbiUed eniahing weight. Hut accounts fae fa* heavy wtf* lult#>tcud PnMMcUu* of lwre*nt*sk Inn*. Can tally te uni up to a ttnunw of 76 fan!. Ihow until, hnwvtvr, cany vnly limited nppmval ini iimM fa uwd In 6imuip|i ininiadiiicty harmful to life, bureau of Mints Approval. Uicful Life nnMlnw Apgovel KXHMT D-7 (4) Tba entire hau merit anemldy, including facepieces, harms, air bou, and blower. Is usually packaged In a portable trunk, the blowci opentor serves also as a itaiulby or guard, ready to aid tha workmao |a case of mishap. EOtrttT 0-7 <8> *. jitf-CiHliiJ NnXn Am*tam 0> ftyiCfiiiiWlMlIt is* and w-GewamdM 2ffi" Application Vlf-cowained faufalng appermt provide complete M^Bhiy protectee la wait aiwvd Abas fame tieKygnadaflclaftcy ft* Warn* to ladlfdlte 1 fae tatteuedlng nmijiiw ktHM V tt %tfa nfatetilag m anrid* eit TVo*ytn or M Stffly of fan *|fMH waif uhn CBN ^mpfaemry mCtejeminte. Method of Operation limtatiwa Sett-eooalaad bathin* apperoten divided tow dim baric type*--oxygen cylinder Mbrcafauig, demand, and tetf-gcatiating. Mijn problem or Urnfudoe !r Valbifiw* of ippmn**. Umfuf Lite Dependent on die of air eyUndeu and, la A* cm f ii wtctdln tyfd, a fag CO| oumi) ctvlMt, taMtoae Awoml Setmdalois TV oxygen oyllsJer ktewthing type 1* s* rodey li dm TV oxygen cylinder matt be rotated and fa* caibon dtaUda-maovUg ehamleal roplaced type nfetth antrnnetteeiiy ewt^eamtet after eaVeee. At U turn of all w|<awy far dm varying bttifalsg demand at dm prouedot efattpnroM, oalteof i proper um ex* (toonriitiofi (nledveiy imaii and metagenanoe U wenrial fa* dm n*w effl* cyiiAdv of oonfatomed Myp*B, mdacing deni sfHittUMk ead tcgularing film, a bu>ttiing b^, facepiece er monfapitoe pka m* cup, The one boor teniae Ufa for to >alfg*netaring ad a dmadeal eHulwrviwnm type affwiuna 1* baaed on ten pcocedum of eeibea dkwlda from the idtld breath, Vue* of Mine* Approval icVfaua is and la a* a tenet or Min fnwrtM period nnf until Tim telfg*umqng type mt dm bend an dm mar and hit level ofnxcfdoo. principle of mtenadriagi bill it be* no mechaami epnring oorapenen*. V will be faremend *o*edmr. TV klgh'pnmea Mygw Vnv the Cylinder U ladnend la pen we to a breathing level by mown ef e mduelag and rognlaring valve, in rome wdn Am la a comma Dav pin a tongooonollnd valve oMdi add* any noulml eddittonai flow, abet eppemroi have only as admlirioo valve tddeb dellwn dm oxygen bow dm breathing bag u dm mw1! lace. TV typer of cylinder mteoithlng ida aow manafremmd am appmed by dm kiMi of Mlm far tw. fame ot fan* bow dmntfuh IV Mif-fMMitiif iyp* appntero* it tppwved by V tontine* V one bow. tnio dm oontabni VldMig dm eatbon dioxide rmnovtug chemical uni Men dump a owteo Finally, the ptufVd ftdutedon fan into fan bfMfatgg bag wVtn It mlm* vffa Um 1nwwring oeypn front the oyHnder. TV mbfeBdiUig principle peimlh IV itmmi efSeUni twiluaiboo of dn oxyjfnt wpply. TV eabated Writ contnim both oxygen end carton 4oaMe a* the hameti Vdy axnecr* i`rvly a mall pen of rin .ixygun itdulod. TV mtf-gtocmtlAg bmadtfng pparotu differ* boa ooaveatitmal cyllufar mbteafalsg appnmnu In that U mlUse* a cbemleat catdnar With evolve* oxygen and renew* dm trifled tattoo dioxide in aaaobUnaa with bieaddog tnmitetnem. it eh* ruinate* Mgb penwe cyltndcn. rogutetlng veins, and other mtrriiaflical compemon. TV miner. vUcb contain* pomtricnr Mpnceld*. evoteea oxygen Mmn toow.ni! sy Me motiOM and wlsn dlflclV In ite exVted beeatt. and ictaisi dm eatbos diatkte and tnoutmn, bataimng moumm ti Impcvtaca ai It eiM In peveatiog leu fagging. in w, dn acdf-poamdng nedt opentet at otbu mbuaiblnt apfnmnn tncept that dn weanr. ering ibeceaennr. make* bit own terygea tuned of dcewing bun a compund pi eyftndu, TV ouw--ting bitiuii of tbit type am !n ttmpUciiy of ooeemcdion and kw. aqd tenet naed far malmeotnee vtea com pand with high pcenum apyaieeia. TVtn are mvtml ucdmdi for nlUusg or ncVigtng blgb penmn air ot oxygen cyhndeM, Cemptetua am eomadoM* end. but tbe Ample* and mo wo* voidsnt medtod te m eaicada front large wpply * tnrnll appafttut cylinder*. ^7 8CMAT P-1 {) KaretatBry Peutee Application MctlioJnf Operation A* the u*er cxhtlci into 'he container, the carbon dioxide ll removed by Ufo chemical and the oxygen which la left I* reured. That method of operation applies hi all oxygen cylinder mbufo Ifig type appexllui at well II to tbc wlfpciHiating type. Umltattoni Ureful life ff) Dn*Ml Type Demand-type apparatus tn available In different models (or ipcciflc applications. Of pnniftilif appliestion to reme Industries U e rfion durttton unit kmn at an 'tniti wi* itli normally worn by a worker ai l}me when he li in an Ata tfocie a poten tially tonic atmosphere, above the capacity el a gaa math exkiu, Altai to which high ptwute garei ait piped fall Into chla category. Another type of short duration uitft U pul on at the time creapa U necessary, A work math wipe of apparatus li ured hi plenretd main*nance work. The apparent* la actually a two-fold unit . A self-contained apparetua with which the wearer cat move finely ebott by Mug unafl cyllndar re enter or leave An mde atimspherewlfoar mutloely or In the feline of the main breadttng wppiy. , The)* la a jmreuen for wonaettflf a (at* re th* demand regulator mi that the wtaw can breafoa iMaclfm tha work paged Item a Utpa vyttsdu which hat a prawnae reducing valvc.ituehed to provide low pceunre for the cenoectlng boat. Manifold ataemhUct can ba pvidad to pawdi noie than one worker to work front a coirmee breading Mote, it la impedlive (bat foe retail emergency cylinder be uacd with chla type of appaterwt otherwlae. a fellow of the supply bom the large cylinder would capnfe tha wearet in tha tunic atrtwtphcre. A It condA of a high Pterwre cylinder, a demand regulator connected either directly or by hlgh'pnfiure tube to the eylimkr. a Tacvpiece anl tube aieembiy with an achelation valve or viWct, and a method of nwundrt the complete ppamtut Ou tlie body. Muae, the wearer turn on the cylinder valve after putting on the facepiac*. inhalet at breathing preiure through ihe demand regulator to tha foe*piece and then exhale! through a valve In tha felcpieu* to tha umHuvUng aimo^bcre. All demand appexttre an reUtlvtly inaffietcre when compared with the rebreathing Type, became the exhakd oxygan li released to the atmosphere innead of being ra-uied. Work matk typei are limited by tha connecting hou which limits tha free movement of dw wearer to the length of tha here, tl U not tn emci^ncy type luitt at, for me. It require* setting up Mime auxiliary equipment. The duration of the demand type apparetui dependi on n*eh fectON aw . The degree of phyueal activity of foa . The degree id which the user*! hraatblog U increased by excitement, fore or other cnwtionel faeuw. typical demand type ppreiu mt at tha MIA "AU Cub* am certified by Bumintt fong tnimitM. Others nreh at the msa "Air Math* are Minified for so minutes under ichcduia 13 for entry Into and escape bun Inetpitable atmosphere*. there service Ufo ratings are bated on tern tfr foe Bureau of Minn on men per* forming modarere re heavy work lit each of the different type* of work teat or breathing machine teati at a tare of 40 Uteri par minute. The rereduser should nor expect re obtain tha exact service Ufa on each u. the week being performed may be more or ten sueouou*. . The degree or training or apedenea which foe urea hai had with foil or dnttiar equip ment; whether or not the cylinder it foity charged at foe tun of foe work period; . The porthi* preaanae In foe compreHd air of carbon dioxide concentrations gnarer than foe t0d5. normally found tn atmospheric atn . the atmotfherfe pressure . The eonditlmi of the appatatut i ruler tire current Schedule l?, all demand type uppareuu iniat satisfy rent wndueud at -aahp, although low temperature rerntponentt such at aoee* cupt u reduce fogging may h avkM If ireedud. Sourct; Bade dementi of Respiratory Protection, Mine Mfcty Appliances ami *nclt leltphone Purvey of .la^pittatry pquipment Indvlliry, BuMlw Aotnoval _Cwnnrerrt*. The term, demand regulator, nreare that foe air flow 1* on inhalation demaod. automatically regultdeg iticlf fo foe detixad level to compen sate for YaitatioiB (e broafotnf needa. Demand appamiu depend upon watching piebur gauge re learn when the bjqjfoJty supply kn dropped to e point where foe user ruw reresn to fresh an, a relf-actuailng warning device u required for Bureau Of Milka Approval. The wanting dxvice can ba either audihre or -m incmared bnefolog resitiencc to alert foe wearer to return to fresh air. l CJt C' c EXHIBIT D-8(l) USDOL/OSHA COSTS AND AVAILABILfTY OF TYPICAL RESPIRATORY DEVICES ftesidntoxY Device/Miniifactufer 1. All Purifying Device* (I) Mechanical filter icafdraton . Bunch end Lomb (B&L) . Mine tafety ipptratui (MSA) . Scott . Webb (2) Chemlcel cartridge teiplinoa . BAL . MSA ' Catalog Number RIO R20 5-15-10 90000 90106 79983 79984 0201-R 8004-ft 8101-R 502-ft .7680 7600-0 7400 7500-68 R21 5-15-21 85556 44135 76853 7BM Component* Description Lot Size Coat Per Unit (1974 Dollar*) Availability (Weeks To Receive After Order) Piovldei protection egelint dtuti (tingle ctittldge). Seme at above but with dual camldge. Replacement filtto. Duactoe 77 provide* protection from Aim and mint having a TLV of tt len than 2.4 million (aiddea/cu. ft. Fllten Dunfbe provide! protection agalnit finely divided aerorola up to 0.3 mlcioni diameter (99.90*5) effective). Type "H" cartridge. Duo-teal dual cartridge high efficiency durt filter (0.3 micron pttdclei). Replacement cartridge. Same at above re!pitator but ringle cartridge. Replacement cartridge. Pmtex dual cartridge rciplrator for duttt with TLV mom toxic than 0.1 mg/m3 full face maik. Replacement cenridge. Protest tingle cartridge half face trunk. Static wool filter replacement, Up to SO unit* Pack of 50 24-71 Pack of 5n 72-145 144 and up 50-99 50-99 50-99 1 4 72-143 72*143 package* of 100 sa. 4 7,35 . 8,90 0.28 7.25 0,13 8.35 2.55 9.00 8.99 2.80 45.75 1.34 5.50 0.13 Ptovldet protection agalmt tow conoeutarioni of organic vapoti. Otganic vapor catridge teplacement for R 21. MSA chemical cartridge retpirator for protection gaiiw organic vapen (0,171). Replacement cartridge for 86556. MSA tame at 85556 but with tingle cartridge fut organic Vpoi, Rtplactmom cartridge for 70803. 50-99 50-99 boxe* of 6 72-143 100*140 72-143^ 100-140 10.70 1.51 0,70 1.45 9.30 2.05 ' Stock item Stock item Stock Item stock item Stock item Stock Item Stock Item Stock Item stock Item Stock item stock Item Stock Item Stock Item Stock Item Block Item EXHIBIT D-8 (2) ttespintoiy Devlcc/Manufacturex . Scott . Welth (3) Gaft muks . MSA . Scott Catalog Numbfct 8301-OV 82004-OV 8101-OV 502* OV 7601 7500-1 Components Description Div>*teal respirator for organic vapors. Dual cartridge Replacement cartridge for 8201-OV Same as 8201-OV but with single cartridge Iteplucement clitridge for 8101-OV Full-foci teipliitor for otgenic report. Duel certddge Replecemcnt ceraidge fot 7601 457081 71705 457112 88339 679-1 184-OV 661-1 282-OV-L MSA Industrial size for up to by volume organic vapocs and toxic dusts with full lace mask and body mounted canister Replecemcnt centner for 457081 MSA chin type raetk for up m 0.5% by volume orgetdc ripon Aeplacemei* canister for 457112 Chert style gas mask for up to 2% by volume organic vapor protection wllb full facepiece Replecemcnt emitter for 679-1 (lOOOcc) CMn style gas mask for organic vapor protection (foil face) 600cc replecemcnt emitter fot 658-1 Lot Size 50-99 100-499 pr. 100-499 10r-499 1 73-143 pedtt with 6 piecet/peck 6-11 12-71 6-11 loo end up 18 end up 12-71 18 end up 50-99 Con Per Unit (1974 Dolleri) Availability (Weehi To Receive t 9,00 2,50 8,30 2,30 45,95 1.28 Stock item Stock item Stock item 78,05 7.45 53.90 5.85 ' 75.43 6,50 42,16 5,10 Stock item Stock item , Stock item stock item 3 veefct Stock itemt Stock item Stock item Supplied Ait Dericet (1) Alt line ntpiratote . Content flow - MSA 457162 Ultra-Vue fteepiece end low pmsue control 1 82.30 Stock item velve (10-15 ptlg with 50 foot hoee) % 487161 8mc ei 457103 box with hypu-flo eontml 1 82,30 Stock Item velvt (40-100 ptlg trtth up to 350 foet of tlr- . hote) - Scott s 4633-10 Zepbytalr-compLete full vision mask with belt mounted filter body and manual control valve. Adjutt ill ptetturet u follow! with 3/8" ID boM 18 and up 60.94 2 weeks Hok Length 1$' to 50' Pteuuro it Hate inlet 8 to 17 Mi i, 158 9>. <-. tn o ^37 Respiratory Device/Manufacturer Caulog Humber Demand types - MSA 7600A 457157 457165 - Scott 4637-1 Hose maikiAiSA 457140 457142 Accessories for air-line systems Compnssionsyttems/MSA 32057 81857 46727 79030 66716 - Pressure regulatoti/MSA ` 66709 68265 68853 - Air-lines and manlfolds/MSA 455020 455021 455022 93931 Component* Description bow-pressure (10-25 pd) full facepiece. Mask-mounted demand air-line respirator w/ultra-vue facepiece 30-125 pl/15-250 ft. hose lengths. Belt mounted demand flow air-line respirator w/ukravue facepiece 30-125 psi/15-250 ft. hose lengths. Demand type respirator w/full vision mask 50-125 pel/ 15-250 ft. of hose length. One man combination hose mask, with hand operated blower (cesitrifugal) and 50 it, of hose. Same si 457140 but is a two man unit. 'Clear sir' blower that washes, cools, snd humidifies sit for 12 masks (Nash Co. cotnpcejaor) Alr-Une filter for removal of dusts, mists, fumes as a final. Replacement chemical cartridge for 81857 filter (2 required). Particulate element replacement for 81857 filter. MSA pressure regulator reduces plant-compressor air pressure to the rated valve for the equipment. . Plenum relief valve-16 p%. Pressure relief valve-25 pi Required accessory when sir-line respirators are operating from a high pressure cylinder 0*4000 pel hi-pressure gauge 0-200 pel low -pressure gauge. Air hose - 15 ft. long Air hose - 25 ft. long AD hose - 50 ft. long Msnlfold-4 man (saip-iite) Lot Size 1 1. 1 18 and up 1 1 1 1 1-71 1 1 1 1 1 1 1 1 1 EXHIBIT D-8 (3) Com Per UnU (ian Douni Availability (Weein To Receive After Order1) * 57.85 95.90 95.90 75.43 868.00 972,00 Stock item Stock Item 3 weeks 60-90 days 60-00 days 2,586.00 44.55 2.40 4.80 34.90 9.80 14.65 94.35 16-18 weeks Stock Item Stock item Stock Item Stock item Stock item Stock item stock item 18.65 23:85 43.20 59.20 Stock item Slock Item Stock item 30 days %&?& 'U:i'V V:5'1-^':9,9"9'#IS^Sii^5' *?SST 9. Self Gocualned Respirators (1) Pimm dnuad^bU-fiaplaH lfcomiaed breathing apparatus l. 2 USA Catalog Number 05069 Comconetti Description With tingle kas elatr-vue facepiece end audible alenn (3) ConblflAikn psettart demand foil huffed mpltator ud damd KtfuuuliBd bfuddag i^inlo 1.2 kBA (3) furtive pawn fall facepiece selfcwmlMd bn.tbU| ipp.mii. 1.3 (4) CmnblpuimcooUBmiftev icqdiuM ud 3 pnum duiud teX-nmiaul breathing tppttuai 1, 2 (8) Demand wodi mark w/qulctaome*/ taaaual Mwnbiy which eon b* ~*J B pdtHAlj III Wlj USA 4* Cylinder Rnehirgcv Systems MIA 26396 Complete Is canylng cik Would be eery wasteful of compressed air Would be very wasteful of compressed air 4671SB 48660 C8BS1 46146 77263 MSA mb complete with uMra^ua facepiece assembly, speaking dlapteagirit demand leguUtOr* hatnets, and 12 cu. ft* capacity air cylinder in carrying case CiHidlm Syitom far Gvllndii tochinlng Air coupler tee AU pigtail All Hdu cowietlaa, compliH with |.U|. High pressure alriilling hose. 6 ft* long* Nam; (1) Pumltud typu radix thi lamponty SO ppm tunduil. (3) Pgrmitud typit under ih< ppcd pmmiHiu no dnicubl* uindud. (n| Itwk Inn* in diUvind 1* mi nwn tins m* li. Xouic liuKh Lomb Sifdiy Fiaduct* MtIHsh Ciutt|, 1014. Mbs bihty Appllurti laiplnloty PMictlm CiuIcr, 1014. Icttt/Aemo hsdMtt RM|4nloiy froncilos KqulpmeM Md AvrMwrloi C.ilo||, 1011, WiWiCimIorIM, 1014. Itewtu ef Snell twtf ot lb? Miptntuty nwlpmtM mihuheWKn. Lee Sine 1 1 1 1 1 1 l eXHBIT P-e (4) Cotta Unix am Dollars! Availability (WulB To nncclTe After Order; ISIS.00 Two week* 699.00 Two weeks Not available Not available 496.00 2 weeks . 17.60 22.20 34*23 94.30 Stock item Stock item Stock Item 9K>eh Item X7 Protective Clodduff/Manufectutv* DiqnsaUe Qoddqg 1. CGolovveera*lls* Hoo* and Shoe Cs*crtagi. TwftK . Arw DiqxmhlM . UMVlDC. , nonet Rublw a. Om-TUet Ewumlmil Buln . MSA Catalog No. CoraeonemsDevolution Lot Sise EXHIBIT B-9 (1) USDOL/OSHA COST ABB AVAILABUJTY Cf FROTIcriVE CIOTHIHO Pcs U19n7i4t (CCooslltars) Note; Sortolecsksi.tem* are delivered in one week - Coverall made of Dupont Tyvek(R) with ela*tic wris and aside for tight fit. * 2.25 Stock item 700205 dSrhaowesdtrijnwg famtatdigehotffDttnpcviz Tyvek(R) Kightop with 100 0.S1 Stock item 520805 fHoorotdigmhtadite ca4roDunudpoCnuteT.yvek 09 with djawtrlng 300 0,40 Stock item - Coverall made of Dupont Tyvek (*9 with elastic wrist and ankle ft* tight fit. - 2.00 Iinn qdueavenltoitpym. em 2-3 months before available - wCodvftearanldl manakdleeofaftDtuigphotntfiTt.yrekW with elastic - 2.00 Stock item V-5 Di^xeebte liquid poof glove*. 144 0.21 30 weeks SITES Allied padtfre Internal pcatne itft made cfvinyl* Cpioemcep.letReowomithfoArttaMch{eddrahmoroydpwroittehcctilveearevquirlyptlrfoaocLe- 1 47.00 Stock item Dedgned fee one tae only. 1L Pddibvk n"fn 1. Foil Impervious foasurixed Suits , American Optical cm Vbarepaodricnhgeem^iicijaalnseunitt.prtnuriicd with self-contained 1 290.45 G-6 weeks . MSA ui 75090 Cbempref^1) tidt complete wife oaae, hood end air sduepvpelylotpytptawmit.lvcUsinetdewrniathl pmreasnsuifroel.d and airline >dt 1 393,45 15-17 weeM CO ifa- ` 33400 Raiur' mSeasdkasnn! oPtrtoiqteipcUtioendSwuitithcuannitlie ween with MSA 1 170.12 fi-fl weeks ;v.W lu&i-'jyA*;-* m33*fS /*C C Pnxectlv, CMliis/Minuficttuu Add Resistant Suit . MSA , Uniioyil American Optical Cloth Woth Clothtt . MSA EXHIBIT D-9 (2) Catalog No. Components Description lot Slxe 37108 31934 MHI-A27 MHO-957 9011 503*1' 512 524 Son Ra/R) suit, vinyl coated nylon made to be decon* tamlaated after eaeh use. Jacket ha* safety cuff* ar-d 1* fastened with ball and socket fasteners. Pants have bib front and no fly. Rubber utility mlt jacket hat stand-up collar with storm fly front. Pants have btb from with no fly. All scams pressure welded. Neoprene coated on nylon jacket with attached hood with dawstring for right face fit, Closed with itoiro fly fiont. Neoprene coated on nylon bib type penis with map ny. Acid resistant coveralls made of neoprene coated on nylon. Add resistant jacket made of heavy duty vinyl with norm fly front. Acid resistant bib type pants made of heavy duty vinyl. Hood made of heavy duty vinyl with clear vinyl facepiece covering shoulders and upper chest. 1 12 1 1 1 1 1 1 1974 Cost Per Unit (Dollars) S 47.50 21.50 11.65 9,45 25.00 25, SO 22,00 45.70 2*3 week* Stock item ` Not less than 2 months No lea than 2 months 6*3 week* 6-8 week, 8-8 wwkj 6*8 weeks 39134 Coveralls made ci ithetlc fiber fabric Dynel^ made to cover or replace the worker's street clathe*. 12 13,60 3*4 weeks CJ1 oo Qj Protective Clorhiofl/Minufacturer 4. Glove. , MSA 4 Pioneer Rubber 5. Boon * Unltoyal Catalog No. Components Description Lot Size 3GGe8 31643 N-31 Heavy duty acid reslsunt rubber designed with curved fingers and using high quality latex for pliability and chemical resistance over a vide temperature range. Flexible, completely coated with vinyl 12* gauntlet type. Lightweight designed to give liquid tight protection. Clove is not particularly durable. 12 72 12 1274 Cost Per Unit (Dollars) S 4,02 1.T1 0.91 MBS01 MB09O MB 031 Knee length acid resistant rubber with steel safety toe. Knee length medium weight acid resistant rubber with safety toe. Knee length imported acid military rubber with safety toe. 12 12 12 16.00 19.65 12.70 EXHIBIT D-9 (3) Availability 2*3 weeks Stock (tern 6*8 weeks Stock Item Stock item Stock item Smum: Dunfib 1914 silei brochtue, Mine Sifeiy Appliincei 1974 emlogue. Unlreyal 1914 catalogue, Piontet Rubber 1914 Citalogue and Snell Survey of Protective Clothing Minuficttiieij. Z CJ1 CO EXHIBIT D-10 (1) USDOL/OSHA SUMMARY OF SNELL INTERVIEWS WITH VINYL CHIDRIDE/POLYVINYL C. 'LORIDE MANUFACTURERS RELATING TO PROTECTIVE HJUl MINT PURCHASED VC or PVC Producer^ llM-Int. -C end ns-int.-w 27 20 and 21M-Int.-W CIn of Protective Equipment Number of Worker* Requiring Protective Equipment Respirators, half face air supplied Reiplraton Respirator*. half face air supplied 16-20 16-20 57 N.A. Colt of Equipment (1974 Dollan) $200,000 200,0Oi> 16, 000 N.A. Operating and Maintenance Coin (1974 Dollar*) S 25.000 25,000 N.A, N.A. Comments Several tripping accidents have been attributed to reiplraton and some of the workers are reluctant to wear them. Mlnute-byminute supervision required to enture use. 6 weeks procurement lead * 40L-New'W 15 191-New-W 41L-OU-W 54M-New-C 1. Respirators, airline 2. Protective clothing Disposable coveralls Rubber gloves Reiplraton Reiplraton, airline Reiplraton, alrllie 88 20 12 16 16 60,ooo 30 30 4,750 14.000 13,000 8,000 5, 000 300 300 6,300 6.500 5,000 5,000 MSA type. One incident of face and scalp rash from use of air mask. 34 Reiplraton, ptenure 6.5 10,000 6, 000 demand or continuous flow 38 Same 3 4,000 2, bOO H*cn (JO C3 EXHIBIT D-10 (2) VC ot PVC Producer lOM-New-W M-Int. C EL-Old-C 13 SL-New-C 14M>Int. -W rln of Protective Equipment Respirators, half face mask Resplritott. Pratective clothing Coveralls Shoe coven Hud coven Gloves Number of Wotken Requiring Protective Equipment 26 Con of Equipment (1974 Dollan) $ 25,000 8 N.A. 40,000 Operating and Maintenance Com (1974 Dollan) $ 5,000 Comment) Workets complain ot diy throat ind impaired movement. 12,000 1. Respirator Airline matin Self-contained respirators Cartridge reapiraton 2. Piacactlve clothing Waterpeoof attltt Head coven, dust shields, gloves Respirators Airline Cartridge 1. Respiteton R. Protective clothing 1, Rasplrason, self-contained cartridge 3. Protective clothing coveralls Disposable suitt 112 N.A. N.A. 81 f 50 2 40 N.A, 23,500 7,025 2,312 Disposable clothing lined as operating cost N.A. N.A. 72.000 2,400 1,600 67,000 15,000 5,000 18.000 3,000 4,503 N.A. N.A. N.A. 34,000 4,800 Scott type * MSA type. . Welsh and Scott type. Them hive been complaints by workers on wearing tespirston Seen type. ............ . mu mint w>f ^37 EXHIBIT D-10 (3) VC Of PVC Producer 48M-OU-C 44M-New-C 22M-01d*C 8S-Int.-C 30M-Ncw-C 353-Int, -C 31M-NOW-C 423-H.-C end 383-Now-C 8IL-NW"C Cleat of Protective Equipment 1. Roplrircn, alt supplied Cartridge 2. Protective clotting Hard hat* Coveralls Waterproof aula 1. Respirators 2. Protective Clotting Reapiraton, oomlnuoui flow airline Reipintat Number of Worked Requiring Protective Equipment N.A. N.A. N.A, N.A, N. A. 31 25 N.A. Coat of Equipment a924 Dolled) 3 2,500 3.300 1,250 21,188 20.000 500 Operating and . Maintenance Cotta (1974 Dollatt) Comments t 4,800 120,000 People with hetrt or lung jroblems hive been Advised not to went respirators r have been reassigned to Areas not requiring their use. N.A. 72,000 14,400 30.800 58,000 12.000 One worker with htauiy of aattma became 111 wMlo wearing air line maik. N.A. Scott type. Individual cases of wotkers refusing to wear reapiraton. Reapiraton, full face matk type C contlnuoua flow Protective clothing Reapiraton Reapiraton hiptraton, bold* roppUed air maakt detf-ronMinad 16 N.A. N.A. N.A. DO 45,000 5,000 25,000 15.000 10,300 1,100 3. 000 26.000 N.A. NeA. 80,000 N.A. 2-5 weeka procurement lead time. 1-8 montha procurement lead time. Problems in fining matk! on personnel with beards and mustaches. Increased abaenteelim and refusal of overtime haa been attributable to uae of teapltttory equipment. On* complaint el tu probUmi caused by respirator use. UW^Ui OSS I EXHIBIT D-10 (4) VC or PVC Producer 36M-Im. -C 46M-OW-C Clan of Protective Equipment Number of Workers Requiring Protective Equipment Cost of Equipment (1974 Dollars) Protective Clothing Rain lulls Respirator! - N.A. 200-300 $ 13,000 41,000 Operating and Maintenance Com (1974 Dollars) N.A. Comments * 18,000 3 months procurement lead time. Wodrsn have complained of nasal and throat dehydration. Note; (1) For meaning of producer code, see page II-6. Source: Results of Snell Interview with the VCM/PVC manufacturing industry. NA Not applicable. V CJ1 0 /T--~* o ***** ^7 EXHWf 0*11 (l) USDOI/00HA XaMPLE CTT* VS, HJMBtt CT COVtUH* WOWUB MOD1NO W5POATOKT KJJtPMTNT AS A FUNCTION Of VtNtt CHLUUDC MONOMER tfVIlS ST PRODUCT* Waxlnc TUB* f* ofI Hr. D*V) iSsO* 100 SO 7J M 100 so IS 100 110000 100 100 IS 10 10 10 SO sIoI 17 Ctptal QMti tu.ase b4 MtldtOBiaeo com QT4 DcU*a) It MO Comwww Tettl f so ppui to?t 111,100 NA 1,100 KA with DO cDglDUrioi Lmp*rtnI*l. WUb lmjwrcmeiDn. u.000 t MolDOMt* 1591 EXKBIT D-ll (3) VCM/TVC tn*e*i 4N.'Nw'W Tol Tot>! M Total Total Total Total VQ4 Ural 50 SO 10 1 Ho. oftmpkyai Weaitac Benanten so 4 4 t 20 4 4 12 4 >0 30 4 4 0 20 4 4 U ^4 IS 11 it 13 20 12 0 N 110 180 lob ClattincaHoo Ftaattot eloaatog U*j manor openmxi Laigo nvtot load opcntra Small raactar load opexaton Small inctor opuaaos Roacmr doputmaoa atiift wptrrfmf Diyv lot* Diytr o)oimii> Dtyn odlttloa Diyt* Hdh aupaMaor tKM tkaalag Laigo macto* optiaton Uiga matter toad opttatnt Small maoiM load opomton SnuU iuch opoiaaoii Iteaetm (04ft anpanrlaor Diyorloodi Diyor opoiauu Dtyor wlihlm Drytfduft rapendaor Sampling Loadts MaluttMoao Sampling Lotdon MaiDtcnanct Sampling MatolaaatKO Oihtn All *ba Woaitng Tima (*off Hr. Day) * Capfe*] Cotfa (DoJUn) *80,000 tod Mtimagau-a Coot <1*74 Dalian) IS. 000 3 M U HolDCroaaa 30 4 S 3 IS s <1 10,000 8,400 3 7 No lanoaM for 7,000 IS SO ppm Loral 12 7 NA HA 7 100 3*0,000 HA \^csV 159 ""Wf? EXHBIT D-ll <*) CJ1 CD CO VCM/PVCPB^WCM M Toni Toni Tool Toni Toni 14M*LH.*W Toni VCMUvol (P*V) so 2ft 10 1 SO 2ft 10 TWA od 2S (Catling) SO 2ft 10 No. of Inployeei WuriM AmAnton 12 4 12 I 4 !& na 272 272 50 70 70 70 70 12 1 * 2 2 1 l ml 43 "* load* fob dud/lcadm LOfelU MHnctrnnra iMifa* Other AH Poly betiding pcoomcl Poly faeUdng pmawl lililmiirt i ncfaalcal Same above NOT F1AS9U Onjgtag palyi haeovti/ potyi Helper uOi lending verfne lagjtl mini Maintenance, pipelining MiUawdra. mechanic! wuifltwHK*, electronic* Maintenance, latuuiruuKi Feinting, lagging Same at above bn move me of tlj NOT rEASDLE Wearing Time {% Of 8 Hr. Dot) is* 10 02 100 7 100 CtfJul coat* (DoUui) t 4,004 No tnnr*r KA Hi Malotemttoo Com 11974 DoQasl *2,800 Noimroeae , NA NA NA 1 2,000 <80,000 s 10,004 NA IS10 T.OM 10 - :.. i-..* -i. . y - v;:-fir i,;' . '* ft Vfft-Jj'vH' > >. BXKBIT D-ll (4) VCM^VC twodtem 4M<IK Total T*Ml VCM Uni o(Cffla() SB (C*lSnO No. ofEmptoyni 4 4 4 4 80 SO 34 4 t* IS 18 4 180 18 f * S 1 888 4 4 4 4 30 SO S4 4 98 IS 18 4 180 18 t S lob C1*wlflC4flW Lata* obiip (piiwr rMcinttopbiM Uni (Horsy opaaatn Ufa lialf m Chaiga opantos Iboovoiy opoBMon WC l'l|>MM Udltay opaia*** HaJpa* Diytf opataton U||M Tmfw npaiifnn yilmgilff mgcha&tO Took turn optmtno Fotanea Pay mpawiaia Ownlfcama Dtpnuii mangat Ufa cbnja opsaaat Flask Inn oyaaaaat Un wuwy opaaaw uni katyat Ctaatga opecMMi kata nay opotion HWCofiaamn IMUry opanOoti Halpoa Diyar opatatoti l(j|-- Tmffaiam UatOMAftM maebartc Tank farm opantco Foaosae Pay wyMpaai Fatfftaan rwllMiia-- Dapanmoat manger WMdof T1b f^ofgHr. pof) s s 20 8 <118 U 90 <1 <1 <1 18 'SO 10 <1 <1 <1 <1 10 I10 SB 10 8 to 88 SO8 <1 <1 so 88 188 a 8 <1 Caftul Co* (Pollau) n,sso tJ MftlitMttet Co qtl4 Dottm) $4,800 Ccwoentt Htlftp tua bodi alrfad m^w tad cattmga type rcqtatoa. Tt alr-fod wfjfcum ttt i--d fm opo^Bj wW rl--mog pol/mmrlw n mi tfw canridj* Mptauft in owl < adm )pt whu t)n `f jgo^t few tbOf* 2fi pp(D bA bm 80 ppm. KA MA WttfeaSSppaeaUbgAaaaaoffiafltidf* wntoom ytaaM ba oiladmire*. Tba wot alt- fad tmrjtmtm voU W'ImM *>0 eaataar luta vaakt ba 0*4, Inrifnmnflly bottiao of * dutr teagot Ilia aad bocur icoMliiy. T?GSI IIU EXHBtT D*ll (8) VCM/rvc Fites-- 4M*OW< Total 1* VCM L4V1 IW W (CoiBuf) 10 TWA SO it 10 (C*ttUl|) 0 TWA 1 WaaHfM OairtlMoia 4 4 4 4 80 to 34 4 u IS is 4 uo 11 a s l 933 11 l "* II Tob CllBlfleitloa Latex chuya op--tor Flaadc iaux spaas-- Utex mcoraiy mourn* hotpot Chat|* op--toa Asoevaty op--w HOC op--is* Utility opu*tn Diysr opccstsB Ttautir opctam fi8i fffiii ops-- FoMmss Day nifnlsw rngtnmin Ganaral fflton Dapajmcu ff NOT ttMtoll Sampltaf ffamnt ouipmatf Aten, plm uklaf isadlo* u |oto| (ns i wUk any lulu axt* oa VCM *qttipnMl Sams u abovs NOT FtAtlBLt (1) Ctfttnf Itfslim--o*--tMiutd. W In maanlin af |>sftesr cate ns pajs tM, g""* Ipsa --am-- si tte waste at tgtwiw with VC/PVC pteacm. see Wsa4a| Tim* 10 16 0180 to 10 it s 6 80 40 620 6 <1 CapftalGan (Pollan) _ NA OpmUn ate ml--ira Cana (1014 DoPaa) NA 7CP n*ra For tUa lsval tb* w*iis| of m|tetn would te Issa^Msd aa ttelaate. s mtoo tio.000 IS Note--aas NA SO No la-- NA APPENDIX F MEDICAL SURVEILLANCE OF EMPLOYEES x 1596 W 1 !'H!g^UW!lap>^-w1IWW"T'V '-riWmwjlfWWi| |l. HI 11 , IJLwuw^pWftipipjiJJ ^ Jiifl .JPIHI c) 9 -1 T3F APPENDIX F MEDICAL SURVEILLANCE OF EMPLOYEES This appendix details the elements of routine medical surveillance and their attendant costs. All exhibits appear sequentially at the end of the appendix. 1. A REVIEW FOLLOWS OF THE TEMPORARY AND PROPOSED REQUIREMENTS FOR THE MEDICAL SURVEILLANCE OF EMPLOYEES IN VINYL CHLORIDE (VCM) AND POLYVINYL CHLORIDE (PVC) PLANTS This section summarizes the medical surveillance required under the emergency temporary standard for exposure to VCM (50 ppm) and the medical surveillance required under the proposed permanent standard (no detectable limit). (1) 50 ppm Emergency Temporary Standard (ETS) ^ The ETS does not recommend or require any medical surveillance of employees in VCM and PVC plants. It is concerned only with the fixing of exposure levels to 50 ppm value (127.0 ms/cm). 12) (2) Proposed Permanent "No-detectable" VCM Standard (PPS) Comprehensive requirements for employee medical examination are proposed, in cluding necessary tests. Some additional guidance is included for the convenience of physicians. The proposed requirements have been recommended to OSHA by NIOSH (see below) as reasonable and appropriate to detect liver dysfunction which may be indicative of, or predisposing to, the development of liver angiosarcomas. (1) 29 CFR 1910, Occupational Safety and Health Standards, Emergency Temporary Standard ' for Exposure to VCM. (2) 29 CFR 1910, Occupational Safety and Health Standards, Proposed Standard. F-l Records of medical examination are to be kept with provision for access by appro priate OSHA and NIOSH officials. Specific requirements are made to furnish a copy of a medical record to an employee's physician on the employee request. In the event of an "emergency", that is. an unforeseen circumstance or set of circumstances resulting in the release of VCM into areas occupied by employees, a special medical surveillance by a physician shall be instituted within 24 hours for employees present in the affected area at the time of the emergency. (3) NIOSH Recommendations For Medical Surveillance Referred To By The Proposed Permanent Standard The following recommendations are directed primarily at medical screening to ddtect liver disease and/or hepatic tumor. They should be considered in the context of routine health screening for any general employee health problem, including non-hepatic health condition potentially related to VCM exposure. Routine health screening should include at the time of initial employment: . the recording of past medical history the performance of v a general physical examination certain basic laboratory procedures including: .. complete blood count .. urinalysis .. chest x-ray Provisions should also be made for routine periodic health follow-up examinations; (1) NIOSH, Recommended Occupational Health Standard For the Manufacture of Synthetic Polymer From VCM, March 11, 1974. vMV 1598 F-2 Employees covered by the following specific recommendations shall encompass all persons engaged in VCM production and polymerization including personnel peripherally involved such as in clerical and management assignments. The recommendations shall be applied both as a pre-employment requirement and as a part of periodic health follow-up. Screening priority should be given to current employees with prolonged and close potential exposure to VCM, whether in present or past work settings. The recommended examination protocol is: At the time of initial employment, or upon institution of screening, a physical examination shall be performed with specific attention to detecting enlargement of liver or spleen by abdominal palpation. . At the time of initial employment, or upon institution of screening and annually thereafter, a medical history check-list shall be completed by the employee. This list shall include questions concerning: alcohol intake past history of hepatitis - past exposure to potential hepatotoxic agents including drugs and chemicals past history of blood transfusion past history of hospitalization The completed medical check-list shall be reviewed by a physician and should be acted upon as medically indicated for each individual employee.. Q OK CD CD F-3 At the time of initial employment, or upon institution of screening, a serum specimen shall be obtained for screening with respect to the following five bio-chemical determinations of liver function: - total bilirubin alkaline phosphatase serum glutamine oxalacetic transaminase (SGOT) serum glutamine pyruvic transaminase (SGPT) gama glutamyl transpeptidase (GGTP) Additional tests that optionally may be considered for use in screening include lactic dehydrogenase (LDH) serum protein determinations serum protein electrophoresis platelet count Laboratory analyses shall be performed in laboratories accredited by the College of American Pathologists, licensed in accordance with the provision of the Clinical Laboratories Improvement Act of 1967. If results or laboratory screening are normal, screening shall be repeated on an annual basis. If the person being screened has been employed directly in vinyl chloride monomer production or polymerization for 10 years or longer, screening shall be repeated every six (6) months. If one or more liver function tests are abnormal, serum testing shall be repeated as soon as possible, preferably within two (2) to four (4) weeks. If no abnormalities are present upon rescreenlng, testing should be re U' 0; peated in three (3) months. O F-4 If abnormalities persist on rescreening, the employee shall be removed from contact with VCM operations and an individualized workup shall be ' instituted. Suggested as initial steps in medical workup are a complete physical examination various special procedures such as .. hepatitis B antigen determination .. liver scanning If liver function abnormalities are determined to be unrelated to liver disease (e.g. elevated hlkaline phosphatase in a young, physically active man or elevated bilirubin in Gilbert's syndrome) or to be transient (e.g. due to recent hepatitis or recent alcohol intake), the employee may be permitted to return to VCM related employment, subject to individual medical evaluation. In view of the preliminary results of animal toxicology studies, it is recom mended that no woman who is pregnant or who expects to become pregnant should be employed directly in VCM operations. F-5 2. SNELL ASSESSMENT OF THE COST OF MEDICAL SURVEILLANCE UNDER THE PROPOSED PERMANENT7 STANDARD d) This section details the cost of medical surveillance needed by the VCM and. PVC industries to comply with the requirements of the Proposed Permanent Standard (PPS). Costs are essentially based on the physical examinations and laboratory tests recommended to OSHA by NIOSH. Exhibit F-l presents a screening flow sheet for the physical examination and laboratory tests which may be performed. It details the screening steps which are given by the PPS. . Exhibit F-2 presents the time required for an average worker to spend on obtaining the needed physical examination and laboratory tests by a physician under contract to the VCM and PVC manufacture. . Exhibit F-3 details the types of laboratory tests which may be required as well as their normal values. It is from these tests that a portion of the total cost is based. t . Exhibit F-4 summarizes the itemized costs for the various elements of the medical surveillance program from Snell estimates based on the detailed study. The Snell estimate is $160 per worker. . Exhibit F-5 shows the costs which were reported by the VCM and PVC industryTor their medical surveillance program. Their costs average out to $143 per worker based on sixteen reporting firms. (1) 29 CFR, 1910, Occupational Safety and Health Standards, Proposed Standard For Exposure to VCM (2) NIOSH Recommended Occupational Health Standard For the Manufacture of Synthetic Polymer From VCM, March 11, 1974 0 3 1 /^ F-B 3. REVIEW WAS COMPLETED OF THE INFORMATION BY NORMAN B. JAVITT. M.D., PH.D. HEAD, DIVISION OF GASTROENTEROLOGY, DEPARTMENT OF MEDICINE, NEW YORK HOSPITAL-CORNELL MEDICAL CENTER According to Dr. Javitt in his letter to Snell, shown in Exhibit F-6, he reviewed the appendix and in his judgment, "the proposed protocol adequately reflects both the recommendations of the appropriate governmental agencies, and considering the constraints of time.and expense, is carefully constructed to obtain a sensitive estimate of the existence of liver dysfunction as well as other ancillary data on health status." Dr. Javitt in his letter also suggests modifications or clarifications to the NIOSH recommended protocol as is seen in the Exhibit. C! j F-7 160  03 O EXHIBIT F-l USDOL/OSHA SCREENING FLOW SHEET BASED ON NIOSH RECOM MENDATIONS TO OSHA FOR THE PROPOSED PERMANENT STANDARD Screening tp.sts Normal est every B months if employed over 10 years Test annually if employed under 10 years Normal results epeat tests in 3 months Abnormal liver function tests Repeat'tests in 2-4 weeks Return to VCM area if medically approved Nte: (1) Source: Abnormal Results 1. Remove from VCM area 2. Medical workup EXHIBIT F-3 provides listing of Screening tests elated to liver disease Additional medical Based on NIOSH Recommended Occupational Health Standard evaluation necessary for the Manufacture of SynthetlcPolymer from Vinyl Chloride, Marqh 11, 1974 TT!W EXHIBIT F-2 USDOL/OSHA TIME REQUIRED FOR TRAVEL, PHYSICAL EXAMINATION AND LABORATORY TESTS OUTSIDE OF PLANT Worker Completes Medical History Checklist While Waiting 30 minutes ' Blood iSamples !Taken 5 minutes Urine Sample Provided 5 minutes Chest X-ray Taken 10 minutes EKG Taken 10 minutes Total Time Required Examination and laboratory tests Travel to and from examination facility Maximum time required * 1^5 hours 2.5 hours 4 hours Source: Snell estimates Physical Examination 30 minutes 9G9T Laboratory Test Blood Chemistry Cholesterol ^ Calcium ^ Inorganic Phosphorus Total Bilirubin Total Protein Albumin Uric Acid BUN^ Glucose LUH l1-21 Alkaline Phosphatase d>2) SCOT Creatinine (3) '' GGTPf2^ SGPTf1-2^ NPN Purpose Cholesterol metabolism Calcium metabolism Phosphorus absorption Liver function Liver function Kidney and liver function Purine metabolism Kidney function Carbohydrate metabolism Organ damage Liver function Organ damage Kidney function Liver function Organ (part, liver) damage Kidney function EXHIBIT F-3 (1) USDOL/OSHA NORMAL VALUES IN LABORATORY TESTS Normal Values 150 to 300 mg/100 ml 9 to 11.5 mg/100 ml 2.5 to 4.5 mg/100 ml 0.2 to 1.0 mg/100 ml 6.0 to 8.0 gm/100 ml 3.5 to 5.0 gm/100 ml 2.5 to 7.5 mg/100 ml 10 to 20 mg/100 ml 65 to 100 mg/100 ml 67 to 122 technicon units 4 to 17 KA units 15 to 45 units ff.9 to 1.7 mg/100 ml 6-28 mu /ml 15 to 56 units 25 to 38 mg/100 ml EXHIBIT F-3 (2) USDOL/OSHA NORMAL VALUES IN LABORATORY TESTS Laboratory Test Hematology RBC (2) WBC W) Hgb<2> Hot Differential (2) Purpose Standard screening for all diseases <i It ft Normal Values 4.6 to 6.2 x 106 4.8 to 10.8 x 103 15 to 18 gm 42 - 52% Polys Stabs Eosinophils Basophils Lymphocytes Atypical Lymphocytes Monocytes Platelets c" MCV < MCH MCHC - cn o " " ' 60 - 70% 0-1% 1-3% 0.25 - 0.5% 25 - 33% 0-1% 2-6% 2 - 4 x 105 80 - 94 y 3 273 y yg 32 - 36% EXHIBIT F-3 (3) Laboratory Test Urinalysis ^ Purpose , Normal Values Color Appearance Specific Gravity PH Albumin Glucose Acetone Bile Urobilinogen Standard screening for all diseases Pale straw to amber Clear to slight hazy 1.905 to 1.002 5.5-7 Negative Negative Negative Negative Up to 2.1 Ehrlich units Notes: (1) included in automated SMA12 analysis (2) recommended for determination within first screening or initial examination by NIOSH to OSHA specifically for liver function. (3) included to obtain a total laboratory profile of the worker (4) Recommend as a special test by NIOSH to OSHA. Sources: IvanK. Smith. Diagnostic Services, Inc., 520 Speedwell Ave., Morris Plains, NJ 07950; NIOSH. Recommended Occupational Health Standard for the Manufacture of Synthetic Polymer From Vinyl Chloride, March 11, 1974; 1 Snell assessment of the NIOSH recommendations to OSHA C3 o or EXHIBIT F-4 (1) USDOL/QSHA APPROXIMATE COSTS OF T i i,<ICAL EXAMINATIONS AND LAb ' LORY TESTS COMPLETED OUTSD L PLANT BASED ON A MANUFACTURING FACILITY WITH 500 COVERED WORKER Element Full-time clerical person for typing, filing, coordinating visits to labs and physicians, etc. ($9,000 x 1.25 in fringe) Records, stationary, postage, etc. Overhead(U 500 examinations by physician (general practioner).@ $20 per examination 500 reviews of physical and laboratory examination results by physician $15/review 500 chest x-rays $20 per worker 500 laboratory test series @ $24 per seriest2) 500 EKG's $25 per worker 125 repeat laboratory test series (25% of workers) $24 per series^ . 125 repeat medical reviews by physicians @ $15 per review 25 special laboratory tests 5% of the workers @ $25 per worker (3) 25 reviews by physician at special laboratory tests @ $15 per worker Cost (Dollars) $ 11,225 7,500 5,000 10,000 7,500 10,000 12,000 12,500 3,000 1,875 625 375 Total expenditures per annum for 500 covered workers $ 81,500 Approximate cost of medical screening per worker 160 & ?L m o CD EXHIBIT F-4 (2) USDOL/OSHA Notes: Sources: (1) overhead includes electricity, telephone, heating, space.allocations for clerical activities, etc, (2) initial laboratory screening tests include SMA12, SGPT, GGTP, CBC with platelets and urinalysis (3) special laboratory tests may include: serum hepatitis B determination, serum protein electrophoresis Ivan K. Smith, Diagnostic Sciences, Inc., Morris Plains, NJ 1)7950; Snell assessment 2. 03 !<** * O -low** i w iwi mfrrwimiwiir WU'lfl | II |ll u 9, 03 Number of Workers 97 173 (NA) 57 222 1,137 50 325 128 420 fNA) 81 150 3,204 68 74 135 EXHIBIT F-5 (1) USDOL/OSHA RESULTS OF SNELL INTERVIEWS TO DETERMINE THE COSTS OF MEDICAL SURVEILLANCE COST PER WORKER PER YEAR Total Cost (Dollars) 16,000 34.000 (NA) 3,000 (NA) (NA) (NA) (NA) 12.000 12,900 (NA) 10,000 22,000 224,280 (NA) (NA) (NA) Cost per Worker per Year (Dollars) 165 200 (NA) 52 (NA) 200 (NA) 150 - 200 94 40 (NA) 125 146 70 200 200 (NA) EXHIBIT F-5 (2) USDOL/OSHA Number of Workers Total Cost (Dollars) Cost per Worker (Dollars) 338 45,000 200 (NA) 693 110,600 111 (NA) 150 20,000 700 (NA) 133 (NA) 160 (NA) 133 200 Average annual cost per employee $ 143(1) Notes: Sources: (1) Cost for examinations assumes tests are based on NIOSH recommendations. Snell review and assessment of interviews with VCM and PVC manufacturers. NA = not available vjG'^ 1612 EXHIBIT F - 6(1) USDOL/OSHA LETTER OF DR. NORMAN B. JAVITT TO SNELL REVIEWING THE DATA IN APPENDIX F 52S EAST Stth STREET. NEW YORK, N.Y. 10021 THE NEW YOHK IIOS1MTAL-CORNELL MEDICAL CENTER DEPARTMENT OF MEDICINE DIVISION OF GASTROENTEROLOGY August 16, 1974 TO: John W. Keating, Ph. D. Director, Biological Sciences Foster D. Snell, Inc. FROM: Norman B. Javitt, M.D., Ph. D. Professor of Medicine and Head, Division of Gastroenterology ^ New York Hospital-Cornell Medical Center C; ^ SUBJECT: Review of Appendix F (first draft) Technical Feasibility and Economic Impact Study 05 CO EXHIBIT F - 6(2) USDOL/OSHA I have'reviewed the above appendix with special emphasis on Exhibits F-2 through F-5 and have the following comments: 1. In my judgement the proposed protocol adequately reflects both the recommendations of the appropriate governmental agencies, and considering tl.-j constraints of time and expense, is carefully con structed to obtain a sensitive estimate of the existence of liver dysfunction as well as other ancillary data on health status. 2. I would suggest consideration of the following modifications: A. Routine tests: 1) Hepatitis B antigenemia (by RIA). A positive test should be an automatic exclusion from working with vinyl chloride because of the possibility of the person being a high risk for developing toxicity. Final judgement would require complete medical evaluation. Expense for this test is probably minimal since now, by state lav/, every unit of blood obtained for the purpose of transfusion mut be tested for the presence of Hepatitis B antigen. B. Special tests in the event of abnormal screening tests: In the event of persistent abnormal test of liver function, the following further studies should be done: *1. Alpha^ Fetoprotein (correlateswith hepatoma) *2. Alpha i Anti-trypsin deficiency (at special risk to develop chronic lung and/or liver disease). 1614 EXHIBIT F - 6(3) USDOL/OSHA *3. 2-hour post-prandial serum bile acid. (The most specific sensitive test for hepatobiliary disease - not as yet activated-cost per test on contract basis, $20 test). * Probably can be cost-accounted through Bio-Science Laboratories and other similar laboratories. NBJ/bq C3