Document G61yRNNaq4yb41oLxNvyvv5w4
R&S 029657
March 3, 1984
DOW CHEMICAL U.S.A.
/
TEXAS OPERATIONS FREEPORT. TEXAS 77541
Stan Cole, Plaquemine Carey Brannan, Plaquemine Dave Kiesel , Midi and
VINYL INSTITUTE SAFETY WORKSHOP
Our committee in the Vinyl Institute has organized a safety work shop. We hope to have one at least once per year if it is suc cessful. We hope you can support the effort by sending some of your folks. We plan to move the location each year to make it more convenient for your participation. Besides exchanging ideas on safety, it would be a good opportunity to meet with employees of your competitors and customers.
Regards,
Bob Oubre CEP/TOX Technology Center 0C-1120
web
attachment
AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY
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PVC Resins and Compounds/PVC Fabricated Products Divisions
Armand Hammer Boulevard. Box 699. Pottstown, Pennsylvania 19464 215/327-6400
------ TOMORROW _ _ _ _
EPA'S SECOND THOUGHTS ON CANCER RISKS
TONING DOWN THE ALARM First it was DDT. Then dioxin. For more than a decade, a steady drumbeat of studies proclaimed how exposure to all sorts of common chemicals was hazardous to your health. Now, better understanding of how chemicals cause cancer in humans is prompting the Environmental Protection Agency to rethink health risks. The process is Just getting started, but in the handful of cases reviewed to date, the EPA is finding chemicals less dangerous than previously thought. So far, only lead has been rated more hazardous. The review is certain to have far-reaching impact on EPA monitoring of some 65,000 chemicals. In some cases, it will mean relaxing rules on disposal of toxic wastes and amounts of contaminants permissible in air and water.
A decade ago, researchers determined a chemical's cancer-causing potential by feeding high doses to animals and looking for tumors. Effects on humans were extrapolated, based on weight differences. Now, data are gathered from many more types of studies, and better statistical models are used to translate findings.
Some early results: Estimates of cancer risk from arsenic are a tenth as high as before. Arsenic, a common component of pesticides and mining waste, sometimes seeps into ground water. Methylene chloride, a widely used solvent, long has been known to cause cancer in animals. But recent studies show that in humans it tends to break down into innocuous substances. The EPA calls the cancer risk one fifth what it calculated previously.
Some scientists say that the reviews are an administration move to ease regulations on industry. They note that no health data are available for 78 percent of industrial chemicals. It will take years and millions of dollars to make headway.
A CAMPAIGN-SPENDING SPREE With last week's big Infusion of campaign cash from Uncle Sam, presidential hopefuls of both parties are spending as if there's no tomorrow in Iowa and New Hampshire, where opening rounds of the 1988 campaign are Just weeks away. Federal matching funds added $29 million to coffers of the 13 candidates in early January, boosting total cash raised so far to more than $100 million. Before the White House race is over, some $400 million will be spent.
Biggest fund-raisers so far: George Bush, on the GOP side, with $18.7 million, followed by Bob Dole, $14.2 million, and Pat Robertson. $14 million. Michael Dukakis leads Democrats with $10.6 million, followed by Dick Gephardt. $4.4 million, and Paul Simon, $4.1 million.
For nearly all contenders, a poor finish in Iowa will be lethal, so they're pulling out all stops, doubling staff size and airing expensive TV ads. Some will exceed federal spending limits--about $745,000 in Iowa. But^it will take weeks to detect, and civil fines are seen as a small price for victory. Many will use accounting tricks to bend limits: Renting cars out of state, for example, and sending staffers across state lines every fifth day to avoid being counted as full-time workers.
How important is money at this stage? Important, but not decisive. Remember John Connally? He raised $13 million in the 1980 GOP race and landed one delegate. And Democrat John Glenn was rolling in cash four years ago, before his campaign faded. Now, with federal matching funds, all should have enough to get through Iowa and New Hampshire. And success there will bring a deluge of donations. The biggest advantage of early cash: Being able to field a national staff to slate delegate:
MORE MASS MURDERS? The nation suffered its worst mass-murde: toll ever in 1987. Some 50 persons were killed by relatives in eight incidents, three of them near year's end. And the situation could get worse because of the "copycat factor.* A Massachusetts man suspected of killing his sister in early January was found with news clippings on recent mass murders. Days later, a man in Washington, D.C., was charged with fatally stabbing his two sons, both cerebral-palsy victims. Family members constitute some 40 percent of mass-murder victims. Typical assailant: A middle-aged white male, a loner, set off by such trauma as Job loss or divorce. Experts don't know how to stop the killings. Says one criminologist: "We can't round up everyone who fits the profile, because 99 percent of them will never do it. It's the price we pay for a society that believes in civil liberties."
by Jeffery L Sheler with Kathleen McAuliffe, Andy Plattner, Harrison Rainie and Ted Gest
R&S 029659
38 U.S.NEWS & WORLD REPORT. Jan. 18. 1988
R&S 029660
CLEAN AIR ACT STATIONARY SOURCE CIVIL PENALTY POLICY
March 25, 1987
Table of Concents
R &s 029661
Introduction ......................................................................................... 1
Preliminary Deterrence Amount ................................................ 3
A. Benefit Component ...................................................................... 3
1. Benefit from delayed costs ....................;................ 4 2. Benefit from avoided costs ......................................... 4 3. Settling cases for an amount less than the
economic benefit ................................................................. 5
*
a. Benefit component involves insignificant amount .......................... .................................................... 5
b. Compelling public concerns .................................. 6 c. Litigation practicalities .................................... 7 d. Concurrent SI 20 action ........................................... 7 e. Offset for penalties paid to state or local
agencies ............................................................................... 8
B. Gravity Component ...................................................................... 8
1. Actual or possible harm ..........................................
10
a. Level of violation b. Toxicity of the pollutant c. Sensitivity of environment d. Length of time of violation
2. Importance to regulatory scheme ............................. 11
3. Size of violator ................................................................. 11
Adjusting the Gravity Component ........................................... 12
A. Degree of willfulness ornegligence ............................. 13
B. Degree of cooperation ....................................... ..................... 14
1. Prompt reporting of noncompliance 2. Prompt correction of environmental problems.
C. History of noncorapllance .................................................. 15
D. Ability to pay ............................................................................. 17
E. Other unique factors ........................................
18
Calculating a Penalty in Cases with More than one Violation ................................................................................................ 19
2- -
\ v-
VVT1
Mitigation Projects ...
\VTT1 T1 4
VIII.
OUll^ X U*3 X w li *?
Appendices --- "[30
oor
I. Permit Penalty Policy II. Vinyl Chloride Penalty Policy III. Asbestos Penalty Policy IV. VOC Penalty Policy
V. Air Civil Penalty Worksheet
20
22
R&S 029662
1. Brief Description Dr. Maurice N. Johnson. BFGoodrich Director of Environmental Health and Dr. John Creech, BFGoodrich Louisville Plant Physician were the first in the world to link exposure to vinyl chloride with human cancer.
Late in 1973, Dr. M. N. Johnson attended a meeting where an interim report on Dr. Cesare Maltoni's vinyl chloride health effects study was presented. Dr.Maltoni had observed angiosarcoma of the liver in his rat studies. Dr. Johnson connected these findings with observations Dr. Creech had reported concerning BFGoodich plant employees. Within three weeks. Dr. Johnson and Dr. Creech met and discussed the combined human and animal data and decided to immediately pursue the possibility that the human cases could have been work related to vinyl chloride in the workplace.
In January, 1974, BFGoodrich informed OSHA, NIOSH and the Kentucky Department of Health of the link of vinyl chloride and angiosarcoma of the liver. Value of Contribution
The early discovery and announcement of the link of vinyl chloride and angiosarcoma of the liver allowed the VCM/PVC industry to take early control measures and curb the number of related angiosarcoma cases. As of January, 1988, 138 deaths have been reported worldwide as a result of vinyl chloride caused angiocsarcoma of the liver.
Without the early discovery and announcement of the link by Dr. Johnson and Dr. Creech, the high vinyl chloride exposure activities (primarily reactor cleaners) would have continued indefinately. This discovery and announcement forced the development and use of new technology resulting in greatly reduced worker and community exposures to vinyl chloride. Much pain, suffering and death have thus been avoided.
,1695 j/kp
Vl/88
R&S 029663
agenda
HEALTH. SAFETY & ENVIRONMENT COMMITTEE
The Atlanta Hilton and Towers Courtland and Harris Streets, N.E. Atlanta, Georgia 30043 John Adams Room
Tuesday March 8, 1988 11:00 a.m.-4:00 p.m.
1. Self-introductions.
.2 Safety
Group B. Barton/Group
a. Subcommittee Update. b. Dow Approach to Safety. c. Kev Elements of an Effective Safety Program.
(This is to be a company-by-company discussion. Each committee member should be prepared to dis cuss - What Do You Do? - How Does It Work? Please bring statistics.).
d. Future Vinyl Institute Safety Activities.
VI Safety and Environmental Awards?":
a. Calendar Year 1987 Recipients^ b. Other Uses of Data. c. Recommendations to VI Board on Annual
Safety Award.
M. Scheck
V.
4. EPA Update:
P. de la Cruz
a. NRDC v. EPA . b. SPI v. EPA
5. TCLP Task Force
J. Ledvina
6. SARA Section 110 VCM Toxicological Profile 7.: a''Title III, July 1988 Emission Reporting
A. Gellrier
Group
33 Go
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1
. ' -- " Y? '
Y.,
&. Environment _
71988 in con- -' ' :
Meeting.
.
; 4' The Vinyl Institute, A Division of The Society of the Plastics Industry, Iric. Wayne Interchange Plaza II, 155 Route 46 West, Wayne, New Jersey 07470, (201) 890-9299
Paul J. Uslnowicz, Ph.D., P.E. Manager Environmental Technology
AIR A
products
Chemicals Manufacturing Division Air Products and Chemicals, Inc, Allentown, PA 18195 Telephone (215) 481-4153 Telex: 847416
J3 0 O
to (cOn con
i BORDEN CHEMICALS and PLASTICS oeeoxT'tJGt'V'Teopxbtnirship BCP Minjgemenl. Inc. General Pjrtner
J. C. (CRfS) LUNN. JR, TECHNICAL MANAGER
POST OFFICE BOX 417 GEISMAR. LA. 70734 (504) 6?3*m <304) 307-5101
R&S 029666
COHPAHT
DOES TANK CAR CARRY DOT LABEL?
PPC INDUSTRIES^"
YES
DOW CHEMICAL
YES
BORDEN CHEMICAL
YES
BPGOODRICH
YES
VISTA CHEMICAL
YES
GEORGIA GULP
YES
TABLE I VINYL CHLORIDE LABELING PRACTICES TI MEMBER COMPANIES MAHDPACTURINC TCH
OSHA STD. 1910 12000 SEC.PI LABEL
J*
DOES TANK CAR CARRY "CANCER SOSPECT AGENT" LABEL?
YES
YES ?
YES YES YES
YES (On mat erials shipped from plants.
YES
YES (Welded Inside tank car.)
YES
YES
IS MSDS SENT WITH TANK CAR?
y-*-s *
YES
YES
NO
NO
YES
COMMENTS MSDS sent by mail vLth Initial shipment to customer in calendar year, on a yearly basis. Updates to comply with OSHA 90-day requirement. OSHA label and MSDS inside dome.
Tank cars as received carry OSHA "Cancer Suspect Agent" Label. MSDS with shipping papers.
Prior to or at time of first shipment.
Revised 9/30/87
* Update
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R&S 029667
TABLE II PVC LABELING AMD HSDS PRACTICES (RESIN) VI MEMBER COMPAMIES MANUFACTURING PVC RESIN
COMPANY AIR PRODOCTS
LABEL ON RESIN CONTAINER
DOES LABEL CARRY OSHA "CANCER SUS PECT AGENT" LABEL?
DOES LABEL CAR RY NOTATION RE: DUST?
DOES LABEL CAR RY HOTATIOH REt COMBOS. HAZARD?
YES (On bags bulk cars, A silos)
NO
NO
MATERIAL SAFETY DATA SHEETS
DOES MSDS IN
CLUDE VC "CANCER
NOTATION RE:
NOTATION EE:
SUSPECT AGENT"
DUST AS A
FIRE/COMBUS
STATEMENT?
"NUISANCE"?
TION HAZARD?
YES
YES
YES
COMMENTS
CEKXAINTEED
YES
NO
NO YES
YES
YES
CEORCIA GULF
1
YES 1
NO 1)
OCCIDENTAL BORDEN BFCOODRICH
VISTA
YES if > lppo RVCM NO if < lppm RVCM
NO
All suspension resin SO LABELED. All paste resin <lppm RVCM la not labeled.
If > 8.5ppm RVCM Would be so labeled. Mostly, resins are < 8.5ppm and are not labeled.
YES
NO YES YES
1) To be changed. Revised 9/30/87
NO 1) NO NO YES
YES
YES YES YES YES
YES
YES YES YES YES
YES
YES YES YES
Label sent v/ bill of lading
YES
YES
R&s 029668
TABLE III PVC COMPOUND LABELING AND MSDS PRACTICES VI MEMBER COMPANIES PRODUCING PVC COHPOOWPS
.
COMPANY GEORGIA GULF
DOES LABEL CARRY OSHA "CANCER SUS PECT AGENT" LABEL?
NO
LABEL ON COMPOUND
DOES LABEL CAR RY NOTATION REi DUST?
NO
DOES LABEL CAR RY NOTATION REi COMBDS. HAZARD?
YES
OCCIDENTAL
NO
NO NO
BFCOODRICH
YES If RVCM > 8.5ppm
YES
YES
MATERIAL SAFETY DATA SHEET
DOES MSDS IN
CLUDE VC "CANCER
NOTATION RE:
NOTATION RE:
SUSPECT AGENT"
DUST AS A
FIRE/COMBUS
STATEMENT?
"NUISANCE"?
TION HAZARD?
YES NO YES
NO NO YES
YES
YES
YES
COMMENTS
Label also carries informa tion on sensitivity to stabilizers
MSDS forms list limited haz ard warnings for ingredients (stabilizers, plastiez. etc. )
Labels address fumes from processing.
VISTA
YES
YES
YES
YES
YES
YES
Revised 9/30/87
029669
IS IT YOUR COMPANY'S STANDARD PRACTICE TO APPLY OSHA WARNING LABELS OH THE FOLLOWING: (29 CFR 19X0.1017) Page _1 of 2
COMPANYAir Products & Chemicals
PLANT STORAGE CONTAINERS /HOPPERS
PACKAGES /BAGS OF PVC RESIN
PACKAGES /BAGS OF PVC COMPOUND
CONTAINERS /GAYLORDS OF PVC RESIN
CONTAINERS /GAYLORDS OF PVC COMPOUND
DRY BLEND SHIPMENTS
RAILROAD HOPPER CARS
Yes
Yes N/A
N/A
N/A
N/A
Yes, in plastic envelope in dome with MSDS when loaded.
OTHER SHIPMENT CONTAINER OR IN-PLANT
Trucks - Label hand ed to driver w/ B/L and MSDS.
Vista Chemical Company
No
Yes Yes
Yes
Yes Yes Yes, differs by plant. One No answer has affixed stick-on 5"x7" sign to bottom cone of hop per/both sides. (8 signs per car. Other one has 4"x6" label in envelope to each valve on compartment bot tom/8 per car. Label used contains additional info.
CcrtainTeed Corporation
No
N/A
N/A
Yes
N/A
No
Yes, each hatch cover (8)
No answer.
and unloading port (8) are
labeled with sticker. If
labels not present, warn
ing label applied in center
of hatch cover and/or
unloading port.
BFGoodrich Company
No
Yes, only
No (but is
Yes, only
No, but is
if RVCM
labeled un
if RVCM
labeled un
> 8 ppm.
der HCS ef
>8 ppm.
der HCS ef
fective 1st
fective 1st
quarter '88.
quarter '88.
Yes, only if RVCM >8 ppm.
Waste Containers
Georgia Gulf: Plaquemine
Labeled under HCS
HCS = Hazard Communication Standard
-
-
-
-
-
Yes, cars stencilled
AH in-plant contain
in 1" letters. "Product
ers labeled in
Label" sent w/ B/L of
accordance
resin shipments.
with HCS.
R&S 029670
IS IT YOUR COMPANY'S STANDARD PRACTICE TO APPLY OSHA WARNINC LAPELS OK THE FOLLOWING: (29 CFR 1910.1017) Page^l
COMPANY
Georgia Gulf (continued) Delaware City
PLANT STORACE CONTAINERS /HOPPERS
PACKAGES /BAGS OF PVC RESIN
PACKAGES /BAGS OF PVC COMPOUND
CONTAINERS /GAYLORDS OF PVC RESIN
CONTAINERS /GAYLORDS OF PVC COMPOUND
DRY BLEND SHIPMENTS
RAILROAD HOPPER CARS
Labeled under HCS
Yes
-
Yes
Labeled
Labeled
Yes, cars stencilled in
under
under
1" letters, "Product
HCS
HCS
Label" sent w/ B/L of
resin shipment.
Occidental Chemical Corporation Addis
Pottstown
HMIS HMIS
Yes, if > 1 ppm RVCM N/A
Yes, if
N/A
1 ppm RVCM
No N/A
N/A N/A
N/A N/A
Yes, > 1 ppm RVCM Yes, >1 ppm RVCM
OTHER SHIPMENT CONTAINER OR IN-PLANT
Waste Containers. Scrap shipments labeled under OSHA VC Standard.
Scrap Containers
Scrap Containers
Burlington North Burlington South Pasadena
Borden Chemical Company
HMIS
Use HMIS
Use HMIS
Yes Yes
Use HMIS
No Sold Com pound Plant
N/A
N/A N/A
N/A
No N/A
N/A
-- N o
Resp onse
No N/A
N/A
Yes, >1 ppm RVCM Yes, ->1 ppm RVCM
Yes, >1 ppm RVCM
Scrap Containers Scrap Containers
R&S 029671
COMPANY
DOES TANK CAR CARRY DOT LABEL?
PPC INDUSTRIES ^
YES
DOW CHEMICAL
YES
BORDEN CHEHICAL
YES
BFCOODRICH
YES
VISTA CHEMICAL
YES
GEORGIA GULF
YES
TABU I Tim CHLORIDE LABELING PRACTICES VI MEMBER COMPANIES MANUFACTURING VCH
OSHA STD. 1910 12000 SEC.FI UBEL
?*
DOES TANK CAR CARRY "CANCER SUSPECT AGENT" LABEL?
YES
YES
? YES YES YES
YES (On mat erials shipped from plants.
YES
YES (Welded inside tank car.)
YES
YES
IS MSDS SENT WITH TANK CAR?
Vt
y-ejs *
YES
YES
NO
NO
YES
COMMENTS MSDS sent by mall with initial shipment to customer in calendar year, on a yearly basis. Updates to comply with OSHA 90-day requirement. OSHA label and MSDS inside dome.
Tank cars as received carry OSHA "Cancer Suspect Agent" Label. MSDS with shipping papers.
Prior to or at time of first shipment.
Revised 9/30/87
* Update
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TABLE II PVC LABELING AND HSDS PRACTICES (RESIN) VI MEMBER COMPANIES MANUFACTURING FTC RESIN
R&S 029672
COMPAST AIR PRODOCTS
LABEL OH RESIN CONTAINER
DOES LABEL CARET OSHA "CANCER SUS PECT AGENT" LABEL?
DOES LABEL CAR RY NOTATION REs DUST?
DOES LABEL CAR RY NOTATION REi COHBUS. HAZARD?
YES {On bags bulk cars, & silos)
NO
NO
MATERIAL SAFETY DATA SHEETS
DOES USDS IN
CLUDE VC "CANCER
NOTATION REi
NOTATION RE:
SUSPECT AGENT"
DUST AS A
FIRE/COMBUS
STATEHENT?
"NUISANCE"?
TION HAZARD?
YES
YES
YES
COMMENTS
CERTAIHTEED
YES
NO
NO YES
YES
YES
GEORGIA GULF
YES
NO 1)
NO 1)
YES
YES
YES
* Lab el sent v/ bill of lading
OCCIDENTAL BORDER BFCOODRICH
VISTA
YES if > lppm RVCM NO if < lppm RVCM
NO
All suspension resin SO LABELED. All paste resin <lppm RVCH is not labeled.
If > 8.5ppm RVCH Would be so labeled. Mostly, realns are < 8.5ppm and are not labeled.
YES
NO YES YES
1) To be changed Rjevlaed 9/30/87
NO NO YES
YES
YES YES YES
YES
YES YES YES
YES
YES YES YES
YES
R&S 029673
TABLE III PTC COMPOUND LABELING AND MSDS PRACTICES VI MEMBER COMPANIES PRODUCING PTC COMPOUNDS
COMPANY GEORGIA COL?
OCCIDENTAL
BPCOODRICH
DOES LABEL CARRY OSHA "CANCER SUS PECT AGENT" LABEL?
NO
LABEL ON COMPOUND
DOES LABEL CAR RY NOTATION RE: DUST?
NO
DOES LABEL CAR RY NOTATION REi COMBOS. HAZARD?
YES
NO
*
YES If RVCM > 8.5ppm
NO YES
NO YES
MATERIAL SAFETY DATA SHEET
DOES MSDS IN
CLUDE TC "CANCER
NOTATION REi
ROTATION REj
SUSPECT AGENT"
DUST AS A
FIRE/COMBUS
STATEMENT?
"NUISANCE"?
TION HAZARD?
YES NO YES
NO NO YES
YES
YES
YES
COMMENTS
Label also carries informa tion on sensitivity to stabilizers
MSDS forms list limited haz ard varnings for ingredients (stabilizers, plastlcz. etc.)
Labels address fumes from processing.
VISTA
YES
YES
YES YES
YES
YES
Revised 9/30/87