Document G6LrJBG6ZgYX4DwJ3E06K4zEY

7 CV r/cLLU't^.7 DEPARTMENT OF HEALTH, EDUCATION. AND WELFARE PUfiLlC HCALTH SERVICE CENTER FOR DISEASE CONTROL NATIONAL INSTITUTE FOP. OCCUPATION A SAFETY And health 5soo Fi>irns lanc ROCKVILLE, MARYLAND 7CS53 *UW*CTt/Ja Ch Asswuno.-s, r ^\ --^ Hr. George E. Best Manufacturing Chemists Association 1825 Connecticut Avenue, N.W. Washington, D.C. 20009 UlJlEEflElj'U Dear to. Best: On January 22, 1974, representatives from the B. F. Goodrich Chemical Company, set with myself and other staff of the National Institute for Occupations! Safety end Health (KIOSH) to present their concerns that recent deaths of several of their employees at their Louisville, Kentucky plant might be related to occupational conditions. Had not the Company taken the initiative it did in following up on suspicions aroused by the occurrence of the rare type of liver cancer (i.e. angiosarcoma} discovered in several of its employees at autopsy, it is entirely possible that the significance presently attached to the appearance of those tutors would not have been realized for several more years. As a result of Chie information, a walk-through survey \ras conducted on January 24 in the Company's facility in Louisville by NI0S11. Also participating in the survey at the specific request of KIOSH were representatives from the Department of Labor of the State of Kentucky, the Occupational Safety and Health Administration of the U.S. Department of Labor and the Epidemic Intelligence Service (EIS) of the Center for Disease Control (CDC). Ve were moat pleased with the Company's excellent cooperation with the survey teas in providing access to Company employees, union representatives and Company records of medics] find employment history significance. The agreement of officials of the Louisville facility to provide continuing cooperation with the organizations participating in the survey demonstrates the nincerity and concern of the S. F. Goodrich Chemical Company in determining the significance of past and present conditions of employment which may hove either precipitated or initiated the induction of tumors in certain of its employees. On February 1, KIOSH will brief representatives of the National ^ Cancer Institute (NCI), the Food and Drug Administration (FDA), ^ -I o BFG26806 Page 2 - Kr. Ceorgs'E. rest and the National Institute for Environmental Health Sciences (NIE1IS), as to the results of the initial survey of the Louisville plant and also review the results of the investigation thus far. Subsequent to this Electing, NIGSN trill develop a protocol for further field studies as veil as recommendations for medical diagnosis and follow up. At this time the ctiologic role of vinyl chloride in the induction of the observed liver tumors is not certain. The occupational exposure of the deceased workers to over 50 other chemicals at the Louisville facility precludes a clear definitive role for this substance as a carcinogenic agent until the degree of exposure to other chemical substances and work histories of deceased employees can be evaluated. However, the implication of vitij'l chloride as the possible ctiologic agent is not readily dismissable and, unless sn association with another of the chemical substances is revealed, vinyl chloride must remain as the principal etiologic agent of suspicion. Until vell-docuraentcd recommendations to OSHA can be developed, ve are recommending that the preliminary work practices and monitoring and control procedures for the polymerization of vinyl chlorides (Enclosure 1) be instituted as interim measures. These preliminary procedures are based, in part, on the information on hand concerning the operation of the Louisville facility and on the results of the walk-through survey conducted by members of the Institute's staff. These recommendations in core specific detail have been transmitted to the J3. F. Goodrich Chemical Company for implementation at their Louisville facility. Mr. Vernon E. Rose, Acting Assistant Institute Director for Research and Standards Development will provide KIOSK coordination in develop ment of controls and/or standards to be recommended to OSHA. Mr. Hose or members of his staff may be reached by telephone at (301) 443-3660. They will insure that all requests for technical information or assistance concerning this situation are directed to appropriate NIOSH staff or members of the other Federal agencies involved with the ongoing study. The possible significance of vinyl chloride as a carcinogenic substance requires close cooperation between the vinyl chloride industry and State and Federal agencies. Consequently, it is my hope that through your organization the above information and BFG26807 23670002 Page 3 - Mr. George E. Best enclosed recccrr.cndations can receive the videst distribution to other companies using these processes. Sincerely yours, T'CldV'U'-t 7 M-r.'O tee. -A___c-t'i Marcus M. Key, K.D. / JAssistant Surgeon General / Director f Enclosure 'i <! 1 23670003 BFG26808 Enclosure 1 KIOSH Recommended Precautionary Monitoring and Control Procedures for Polymerization Processes Involving Vinyl Chloride I. General Housekeeping Procedures A. The spillage of Vinyl Chloride, and Polyvinyl Chloride in and around the production facilities should be controlled 33 fellows: 1. Housekeeping procedures should be implemented to assure immediate removal of VC and PVC material around polymerization operations including drying, packaging and loading operations, 2. Recovered PVC material which is to be packaged should be stored in closed containers. 3. Waste PVC material should be stored in closed containers and consideration should be given to the adequacy of its disposal and/or destruction. Care should be taken in the storage of closed containers to insure that unsafe conditions do not result from an internal build-up of pressure in the container. B. Inventories of beginning and recovered quantities of VC and quantities of PVC produced, packaged and recovered should be nade to determine losses and probable areas affected, C. PVC material should be removed from overhead structures and conduits where it tends to collect. D. Consumption of food Should be permitted only in separate facilities provided for this purpose, and no foodproducts should be permitted elsewhere in thepolymerization facility. . II. Protective Clothing I : ; > < [ A. A daily change or protective clothing including full coveralls, or the cquiIvaicnt, should be provided each employee in areas where possible exposure to VC PVC could occur. Clocking contaminated by accidental spills should be changed as soon as feasible. B. Protective gloves and footwear, or footcovers, should be worn as appropriate In those PVC operations where exposure to PVC material is possible. C. Protective head covers should be worn during PVC operations ss appropriate (e.gi hard hats in those areas where physical protection of the head is necessary and hair coverings, or the equilvnlent, in fyj Cl cn o &- BFG26809 .operations such as cleaning of polymerisation reactor tanks and packaging operations) D. Where employees arc engaged in maintenance or cleaning operations of polymerization reactors tanks they should wear full impervious suits to guard against skin contact of FVC material and VC vapors. Procedures fer safe entry to confined spaces should be observed. III. Showers Showers at the termination of an eight-hour vork shift should be mandatory for all workers vith possible contact with VC-FVC. IV. Monitoring A. Environmental Monitoring 1. 7n-plant environmental monitoring programs should be implemented; and where workers are required to enter polymerizetion tanks, a survey of the VC concentrations should be made in the reactors immediately after opening, immediately prior to entry of maintenance personnel and during the tank cleaning operation. 2. Data obtained from the environmental monitoring program should he used to indicate those areas where efforts should be directed to reduce airborne levels of VC. 2. Positive programs to initially control VC levels well below the present Federal Standard of 500 ppm should he developed (some ebapenies are targeting at 50 ppm) and efforts to further reduce levels bponld be given consideration concomitantly with the necessary modif i cations in engineering and design controls, A. The concentration of vC in exhaust ventilation should be determined to estimate the amount of VC lost curing operations and the possible exposure of personnel temediately outside the facility'. 5. Monitoring for ?VC particulate material should be accomplished to estimate the degree of exposure to this substan.ee throughout the facility. : |S. Personal Monitoring 1, Integrated, eight-hour personal monitoring samples should be obtained from-those employees considered to receive the greatest exposure to VC or PVC. BFG26810 23S70005 2. Breathing rone samples should be obtained to complement environmental monitoring program for VC, and similar samples should be obtained for PVC. V, Respiratory Protection Because VC is a gas under ambient conditions and PVC is a solid under these conditions, it is recommended that respiratory protection for employees take these circumstances into consideration. A. Where employees are engaged in cleaning and maintenance operations inside polymerization reactors they should bn equipped with an atmosphere-supplied respirator in order to protect against both VC vapor and i'VC particulates. B. Ihirirtg housekeeping procedures and packaging operations where the possibility of PVC dust inhalation is a factor, it is recommended that on air-purifying respirator equipped with 3 mechanical filter designed to remove particulate material be worn. Respiratory protective devices which meet this requirement, as veil as protect against VC vapors in concentrations less than 0.1% have been approved bjr the NIOSH Testing and Certification Laboratory and bear the numbers; TC-23C-4Q, TC-23C-47, TC-23C-48. C. Where employees are engaged in transfer operations of YC from railway tenkcars to storage facilities or at any similar transfer point which requires .manual operations, they should wear a selfcontained breathing apparatus fSCBA) during such operations to guard against unexpected release of VC during such operations, D. Other operations involving possible exposure to TC or VVC should be evaluated as the individual situation exists and respiratory protection provided as appropriate. BFG26811 OJ a W w* 05