Document G6jvaBxpwVGLYnQbz5gVYEmGv

BFGoodrich Tha BFGoodrteh Company ( Chamtaal Group 0100 Oak Tim Boulevard Cleveland. Ohio 44131 216-624-0200 /30C, PLEASE REFIR THIS LETTER ID THE PERSON IN TOUR ORGANIZATION W3D IS RESPCNSIBIEFCR EWIRCMEMrAL AFFSIIS: March 25, 1960 Dear Custoner: In recent years, polished reports have suggested that adverse health effects may be associated with PVC dust, though no specific risk to health had been established. Presently, all PVC dust is classfied as a nuisance dust, one that is not thought to produce any irreversible change in living tissue when properly controlled. The Occupational Safety and Health Administra tion (CORA) and the American Conference of Governmental Industrial Ifygienists (AGGIE) have established a threshold limit value (TLV) for nuisance dust of 15 and 10 mg/m3, respectively, for a total particu lates and 5 rngfnP for respirable dust, These values are based on an eight hour time weighted average (TEA). Concentrations at and ap proaching this level are easily recognized since visibility in such an envlroonent is significantly restricted. Respirable dust, that is, dust which is able to reach the lungs, is recognized by health authorities to consist of particles that are 10 micrcns or snailer in size. Typical particle size for suspension and mass FVC resins is 140 - 150 microns. These represent about 90% of all FVC resin production. Generally, no more than 0.1 percent of these resins will be belew io microns in size. Dispersion IVC resins, however, typically have an average particle size of less than 10 microns. To determine the significance of these reports, Imperial Chemical Indus tries LTD, (a major British IVC manufacturer) sponsored a study of the workers at one of their large FVC plants which has been operating for about 40 years. The study was conducted by a well respected, indepen dent health institute and the results have been made available. While there is no evidence of a substantial risk to health, the findings do indicate that it is prudent to minimize exposure as much as possible. There was no significant increase in lung damage from the inhalation of IVC dust by non-srokers, but there was a small decrease in breathing capacity due to the ccnfoinaticc of IVC dust exposure and cigarette smoking. This decrease was about one seventh of that caused by normal aging and about equal to the loss expected with a one-pack-a-day cigarette smoker. It is generally felt that this effect is the result of relatively higher exposures to dust in past years in contrast to lower exposures in the IVC industry today. BFG06442 20779001 1 Me bellow that the WC chat levels Is our current operations do not irosent a significant health hazard. Nevertheless, we are expanding the frequency of our WC dust monitoring to determine whether there are areas where further exposure controls nay be prudent. It Is reoasnended that those engaged Is handling and processing PVC raelns, particularly rasing of respirable Bias, monitor pertinent areas so as to assure themselves that their plants axe responsibly operated. Sincerely IBB BOOCraiCH OCMPANY canficAL qaoap , /vb ( G. L. Hjber General Shies Manager 20779002