Document GmrDmrNanLBX6NVEybejdm3Gq

(conoco) Conoco Chemicals Company A Division of Conoco Inc. 15990 North Barker's Landing Road P.O. Box 19029 Houston. TX 77224 September 30, 1982 Mr. Pat Menulty Rohm and Haas Company P.O. Box 584 Bristol, PA 19007 Dear Pat: Sorry for the delay. Enclosed is the second draft of the preamble. I think I have included most of the suggestions from our last meeting. Please feel free to make further changes, editorial or otherwise. Sincerely, Thomas G. Grumbles, Director Industrial Hygiene ajo Enclosure CCR 000000979 DRAFT PREAMBLE THE CHEMICAL INDUSTRY IS NO NEWCOMER TO EMPLOYEE TRAINING. EXAMPLES OF THE INDUSTRIES CONCERN FOR EMPLOYEE TRAINING CAN BE FOUND DATING BACK TO THE TURN OF THE CENTURY. THIS TRAINING COMMITMENT IS BASED ON THE SIMPLE FACT THAT PROTECTION OF WORKER HEALTH AND SAFETY IS THE RIGHT THING TO DO. IT'S GOOD BUSINESS. NEVER BEFORE HAS THE NEED FOR TRAINING OF OCCUPATIONAL POPULA TIONS IN THE SAFETY AND HEALTH ASPECTS OF THEIR JOBS AND WORKPLACE HAZARDS BEEN MORE EVIDENT. THE WORKING POPULATION HAS CHANGED IN CHARACTER, BECOMING MORE INDEPENDENT. THUS IT IS INCREASINGLY NECESSARY TO TELL WORKERS "WHY IT MUST BE DONE THIS WAY" RATHER THAN "DO IT THIS WAY BECAUSE I'M THE BOSS". AS WE RAPIDLY LEARN MORE INFORMATION ON THE HEALTH HAZARDS OF CHEMICALS THE AMOUNT AND COMPLEXITY OF INFORMATION TO BE CONVEYED TO EMPLOYEES IS INCREASING. KNOWLEDGE AND USE OF NEW TRAINING TECHNIQUES AND MEDIA AND HOW TO MEASURE THE EFFECTIVENESS OF THESE PROGRAMS HAS ALLOWED FOR IMPROVEMENT AND INCREASED EMPLOYEE ACCEPTANCE OF THE TRAINING PRESENTED. TRAINING AND EDUCATION HAVE EXPANDED UNDER OSHA FROM INTERPRETING THE GENERAL DUTY CLAUSE REQUIREMENT TO INFORM EMPLOYEES OF WORKPLACE HAZARDS TO VERY SPECIFIC TRAINING REQUIREMENTS AS SEEN IN THE VINYL CHLORIDE AND LEAD STANDARDSOTHER FEDERAL AGENCIES AND ACTS CDOT, RCRA, TSCA) NOW INCLUDE EDUCATION TRAINING REQUIREMENTS. MANAGEMENT OFTEN CHALLENGES THE DIRECT COSTS OF WORKER EDUCATION VERSUS THE BENEFITS. HOWEVER, THE BENEFITS OF EFFECTIVE WORKER EDUCATION, DIRECT AND INDIRECT, ARE NUMEROUS. WITH AN CCR 000000930 PAGE 2 UNDERSTANDING OF WORKPLACE HAZARDS THE WORKER CAN BETTER UNDERSTAND WHY HE MUST DO THE JOB A CERTAIN WAY AND DO IT WITH LESS ANXIETY, INCREASING PRODUCTIVITY. EDUCATION CAN BE LOOKED AT AS AN INTREGAL PART OF EXPOSURE CONTROL PROGRAMS. EDUCATION IS A PREVENTATIVE DEVICE. IN THE CURRENT LEGAL ATMOSPHERE, THE SIMPLE FACT, YOU DIDN'T TELL US, IS ENOUGH TO CONDEMN YOU IN COURT. SAFETY TRAINING RESULTS HAVE SHOWN WORKMAN COMPENSATION CLAIMS AND OTHER MEDICAL AND RELATED INSURANCE COSTS CAN BE REDUCED BY MAINTAINING A WELL TRAINED WORK FORCE. THIS CONCEPT CAN NOW BE EXPANDED TO HEALTH TRAINING. THE CHALLENGE FOR SAFETY AND HEALTH PROFESSIONALS SHOULD BE TO MINIMIZE THE DIRECT COSTS OF TRAINING WITH EFFECTIVE, WELL ADMINISTERED TRAINING PROGRAMS THAT CAN MAXIMIZE THE BENEFITS REALIZED. THE GOAL OF THIS COMMITTEE IS TO DETERMINE WHAT CURRENT INDUSTRY PRACTICES ARE, DETERMINE THE NEEDS OF MEMBER COMPANIES, AND MAKE RECOMMENDATIONS FOR ACTIONS TO MEET THOSE NEEDS. CCR 00000981