Document GzZ9yamGND8V01EaJ0J2z8q8V

SP9S31683 flH M I_ N U T E S PVC/VCM AD HOC STUDY GROUP SPI COMMITTEE ON DISTRIBUTION Thursday, January 23, 1975 9:30 a.m. - 4:00 p.m. Committee Members: Conference Room Keller & He cjj Washington, D.C. Tom H. Smith, Chairman B. F. Goodrich Chemical Company Edward Bell Union Carbide Corporation " D. V. Bierwert Monsanto Company . (Substituting for Edwin F. Celette) Roy C. Danziger Air Products & Chemicals Inc. Gerry A. Lapointe Tenneco Chemicals, Inc. (Substituting for Sal Cincotta) Richard L. Way Shell Chemical Company Martin Bercovici Keller & Heckman Guests: Grant Arnold George Coffenberg Edwin A. Olsen Ethyl Corporation Stauffer Chemical Company Compressed Gas Association Opening _ Chairman Tom Smith opened the meeting at 9:30 a.m. He expressed that the meeting had been called to undertake contingency plans with respect to the OSHA Standard for Exposure to Vinyl Chloride currently under Court review. Following the November 21st meeting of the full committee of PVC and VCM producers, there had been an expression of interest in developing for transportation purposes a uniform approach to the labeling required under the standard and, to this end, further defining requisite labels. This meeting of the Working Committee would explore those sug gestions and make further recommendations to the full Com mittee at a later date as dictated by the outcome of the pending Court case. ' Martin Bercovici of the SPl's legal staff was asked for his comments. He stated that it is impossible to predict when the Second Circuit Court of Appeals in New York will issue its decision. He stated that the industry has re quested, in the event of an adverse decision, that ninety days be allowed for implementation of the Standard and that it was not unreasonable to expect that the Court would allow H n m m (iha 2- - a reasonable period of time for compliance. A Uniform Approach for Marking and Labeling The Working Committee then addressed itself to the major reason, for the meeting. The benefits of the -uniform ap proach were listed as follows: 1. Uniformity of approach by all producers and shippers will facilitate compliance with the Standard with respect to the marking or labeling of transportation equipment. 2. Uniformity will enable OSHA inspectors to impar tially judge compliance and effect uniform enforce ment of the standards. 3. Transportation companies and carrier employees will become accustomed to seeing the prescribed warnings in the identical form and in identical locations regardless of the company making shipment. The carriers are accustomed to standardization in hazard ous materials regulations and such uniform approach would be welcomed. 4. No unnecessary or unwarranted statements, markings or placardings would appear on transportation equip ment or shipping papers to cause confusion to involved personnel. 5. Uniformity would be more effective in Warning the employees of industry, who are intended beneficiaries of the warning. The OSHA standards are directed to three main groups of employees. The employees of the VCM manufacturers, the PVC manufacturers, and, the 'employees of fabricators. The marking or labeling of transportation equipment required by the OSHA standard is directed to the warning of the aforementioned employees. It is also directed to the employees of carriers who may be involved in loading or - unloading of VCM or PVC where the carrier employees are involved in such operations and, therefore, should be alerted as directed by the standards. ' m900Z000 - 3- Recommended Labels . VCH The Working Committee considered the options of marking tank cars with the required warning U.1 on the DOT "DANGEROUS" placard, (2) at or near the manway housing, or (3) both on the placard and at or near the manway housing. After reviewing a number of inputs, including legal opinions, the thoughts of the Compressed Gas Association and the - viewpoints of the Working Committee members, it was agreed that the Committee would recommend addition of the legend "CANCER-SUSPECT AGENT" to the DOT placard, in 1/2 inch letters inserted under the vinyl chloride identification. The underlying rationale for this decision is, as follows; 1. Several producers and the CGA have held discussions with DOT and OS HA, and DOT strongly favors this approach. Additionally, in the text of the OSHA report adopting the standard for exposure to vinyl chloride, and at the second full paragraph of page 35895 of the October 4, 1974 Federal Register, OSHA states that since the DOT placard already warns of the fire hazard, "only a statement concerning the carcinogenic hazard need be added to the Department of Transportation labels." 2. The alternate wording "EXTREMELY FLAMMABLE GAS UNDER PRESSURE" introduces new nomenclature for describing vinyl chloride which is different from the DOT nomen clature and therefore potentially confusing to persons in the transportation field. 3. The placard serves to give notice of hazard information to all persons handling the tank car. Further, specific notice at or near the manway protective housing for workers loading or unloading VCM tank cars should not be required in that such workers will be trained to handle vinyl chloride and further since the loading and unloading facilities will be subject to regulation pur suant to the standard. 4. Utilizing the placard approach will convey all relevant -4 C*i hazard information warning at a_ single place on the tank car. The recommendation for labeling of VCM tank trucks was left for further development. The Working Committee did not wish to make a recommendation with respect to tank trucks without the benefit of the advice of the limited number of parties affected. Labeling of barge shipments of vinyl chloride will simi larly be left to the development of appropriate guidelines by the limited number of shippers involved. It should be noted, however, that the Coast Guard is in the pro cess of promulgating regulations which may preempt OSHh's jurisdiction. Cylinders of vinyl chloride should be marked with the appropriate label using lettering of a size to be deter mined by the shipper. Bulk Polyvinyl Chloride Products It is recommended that hopper cars, latex cars and latex truck trailers are to be labeled, stenciled or tagged on or in the vicinity of all hatches and all outlets, in 3/Q inch lettering which contrasts in color to the background. Bulk truck trailers should be labeled in 3/8 inch letter ing at or near the outlets. The foregoing labeling with respect to bulk PVC products is intended to warn of the potential risks from exposure to trapped monomer which may escape from open hatches or outlets during unloading. Since bulk trailers are unloaded under pressure without need for opening the hatch, the Working Committee believes that a risk of exposure to monomer vapor is presented only at the outlets and accor dingly that only the outlets should be labeled. Inasmuch as the label is required for "containers" of PVC, the la beling is not intended for the benefit of loading personnel who, in any event, must be trained for that function. With respect to packaged PVC products, after considerable discussion the Working Committee recommends that bags should be stenciled or printed on the sides or ends in 1/4 inch lettering, contrasting to the background. Such lettering would be visible to workers handling both indi vrd v s s n n u i A 5 vidual bags and those observing the bags in a palletised unit. Bulk boxes should be labeled on front and back in 1/4 inch lettering, and drums should be labeled on the front in 1/4 inch lettering. The Working Committee concluded that such labeling will give appropriate notice to personnel handling such containers and that the let tering is appropriate in relation to the size of the con tainer and in relation to the size of warning labels required pursuant to the hazardous materials regulations of the Department of Transportation. In concluding its thoughts on the uniform approach, the Committee recommends that the warnings suggested above are sufficient to meet the regulations for any mode of shipment. The Committee agreed to offer this contingency position for consideration by the entire Committee pending the Court ruling. It will call a meeting after the court ruling to consider whether to send a delegation to OSHA with this uniform approach. In the meantime, it encourages and would appreciate any position or comments from other members of the Ad Hoc Study Group. Ocean Shipments . Tom Smith reported that informal discussions with a ter minal operator indicated that they would refuse to handle bags or units labeled with "CANCER-SUSPECT AGENT". This company said they would feei comfortable handling ocean containers as long as they were not labeled. The Committee suggested an informal visit to the National Maritime Safety Association would be in order. The Coramittee Chairman and the legal counsel for SPI will arrange a meeting with NMSA and report back to the Ad Hoc study Group. Other Subjects . . Several members have been providing test data to the American Trucking Association and the National Tank Truck Carriers. These two organizations are seeking background to determine the extent of the problem created by the regulations and to provide support in their seeking relief is necessary. ' These two organizations would appreciate help from any other BSt90SZ000 QHA 6- - \ V member of the Ad Hoc Study Group should they care to participate. Several of the members have found that they have had no problem in meeting the requirements of the regulations so that their warehousing qualifies as non-regulated areas. -- - Adjournment _ The meeting was adjourned at 4:00 p.m. Respectfully submitted. Thomas H. Smith, Chairman 12-20-74 m90BZBB3 (MA PVC/VCM AD HOC STUDY CROUP SPI COMMITTEE OH DISTRIBUTION *0. F. Coodrich Chemical Co. 6100 Oak Tree Boulevard Cleveland, Ohio 44131 Thomas H. Smith, Chairman Ethyl Corp. P. 0. Box 341 Baton Rouge, La. 70821 J. F. Pollto Air Products fc Chemicals 5 Executive Hall Swedes ford Road Wayne, Penna. 19807 William Brand. Jr. Roy C, panzlger Inc, _ Allied Chemical Corp. Columbia Road Morristown, N. J. 07960 Charles Corle Borden Chemical Company 180 East Broad Street Columbus, Ohio 43215 Henry R. Blain Certain-teed Products Corp. P. 0. Box 860 Valley Forge, Penna. L94S2 ^ Thomas F. McGrath ChcmpLex Company 3100 Golf Road Rolling Meadows, Illinois Jim L. Collins 60008 Conoco Chemicals Continental Oil Company park 80 Plaza East Saddle Brook, N. J. 07662 John F. Pinkman E. Marcus Smith Roger G. Hutchinson Diamond Shamrock Corp. P. O- Box 191 Palnaville, Ohio 44077 Rodney P, Becker Diamond Shamrock Corp. 1100 Superior Avenue Cleveland, Ohio 44114 E, E. Bracken Proctor W. Dodson %iw Chemical Company (The) erationa Services 2020 Dow Center Midland, Michigan 48640 J. A. Farawe11 Ethyl Corp, 451 Florida Boulevard Baton Rouge, La. 70801 E. R. Schutz Firestone Plastics Co. P. O. Box 699 Pottatown, Penna. 19464 Rusaell A. Park Firestone Tire & Rubber Co. 1200 Firestone Parkway Akron, Ohio 44317 T. F. Csrchiaro Cleo Cory General Tire & Rubber Co. One General Street Akron, Ohio 44329 R. W. Laundrle The Goodyear Tire 6c Rubber Co. 5408 Baker Avenue Niagara Falls, R. Y. 14302 Rowland H. LeCain W, R. Grace & Company 62 Whittemore Avenue Cambridge, Maos. Joseph W. Keating Great American Chemical Corp. 650 Water Street Fitchburg, Mass. 01420 O. Paul Cohen John C. Cloros Hooker Chemical Corp. River Road Burlington, N. J. 08016 Ram Abramowitz Alan R. McAllister Monsanto Company 800 North Lindbergh Boulevard St. Louis, Missouri 63166 E. F. Celette Olin Corporation 120 Long Ridge Road Stamford, Conn. 06904 Joseph F. Rubinec 6n s n & $ * aha