Document J34rkxJdezDOnQOBab91GxKvv

( TO: John Friend K XF; -A WjKeOg^.^____ Interoffice Communication FROM: DATE: SUB J * Tom Grumbles October 8, 1985 ABERDEEN PLANT INDUSTRIAL HYGIENE PROGRAM ASSESSMENT VISTA The program assessment was conducted on September 24 - 25. The team consisted of myself, Keith Fogg, Safety Director LAB plant. Dr. Drumwright; Medical Manager, and Michele Goodreau, Environmental and Health Specialist. Action taken on the recommendations from the 1983 audit report were reviewed and discussed. Interviews were held with personnel in the safety department, various hourly operations and laboratory employees, and operations and mechanical supervision. interviews vie.' start mounted a gccc awareness or ar.c <'<*>... ~~ to the industrial hygiene program. In particular, the supervisory follow-up on measured overexposures to find exposure sources is good. Employee interviews did not reveal any overt health or safety concerns. The mechanical department does safety audits on a random basis and uses a form to assure consistency in this effort. This type of encourage/. t,~'.ggtL-v.is...t_a,,yery.gr.go,sitive .idea and certainly ' Below are the assessment team's recommendations. Items noted on the walk-through inspection and discussed with you are not included below. 1. A large amount of time was scent reviewing and__discussing the respiratory protection, program. Specific^ recommendations are beiow. a. The respiratory .protection program should contain specific y *'selecrioinP'criteria^ror respirator use. The program Aacks "specificity-ras*'to the selection criteria for specific jobs, or classes of jobs with known exposure potential. There appears to be some gqpfcuajjorr as to what equipment should be considered in VCM service and subsequently what respiratory equipment is needed for jobs on chat equipment. b. Reference was made in conversations to various letters chat had been issued addressing specific uses of respirators. These '"guidance" letters should be consolidated into the program. V John Friend Page 2 i* October 8, 1985 2. In Blending and Compounding several recommendations regarding lead exposures are made below. \ ******* m, .*** tka. Maintenance personnel work in the ead areas and are included in the^fe&me^^MMI program. ffConsideratiooun^f*4llhpuld-* be given tytfonitoriiy maintenance jobs In this, area to determine aTPTOWB lead exposures. This could be area monitoring if done carefully. \ : `` b. A review of personnel clean-up procedures at the ! end of shift should be done to assure proper disposal of contaminated work clothing, and that personal hygiene guidelines are followed. V&\ C. To obtain a total dust measurement approximately one-third^? of the lead air samples are handled at; the plant]-. shipment to the analytical laboratory. This practice should be stopped as there is potential to disturb tha integrity of the lead analysis. Total dust numberscould be obtained by the laboratory being used for lead analysis* 3. To determine the effectiveness of exhaust ventilation systems and quantify exposures^Lja^^^ayalTiagBfldk-welding operations in T' the maintenance shQt^fflSVT^Deeonsldere< 4, Further sampling of short-term should to, determine respiratory protection newde* and workplace procedures. For recognized high potential exposure jobs where air-supplied equipment Is used, a review of "job-sice" preparation should be done to preclude casual exposures Co Chose noc directly involved in Che job. |ig Interviews regarding Several instances of vinyl auwon the day of sampling were mentioned. The quality control program chat I was Co assist the plane in developing has noc been developed. I still plan on proposing a mechanism co independently verify Che sampling and analytical methods Che plane is using. Please let me know if you wish to discuss any of the above. ; We are available to assist in accomplishing the above recommendations. ' I want to thank-you and your staff for their time and cooperation during the plant visit* \ : i "fcf-'JP,/ KSr K \- -i s G. Grumbles ajo/7 cc RDG, JRD, ELF, ALS VVV 000017763 ,, ! . U,5}.5SS, / / i General Offices: 2850 Wusu Grand Boulevard * Detroit, iVlichtgnn 43202 Y E L F. r 11 O N E 3 I 3/C 7S- 7000 November 8, 1971 Mr. Edward Largent OSHA * Dept, of Labor Technical 300 South Wacker Room 12 01 Chicago, Illinois 6 0606 Services G. :r-:: C '> / '... . .^ ^ Dear Mr. Largent: After reading the standard on in the Federal Register (Vol, 1974), one area needs further tation . Exposure to Vinyl Chloride, printed 39, No. 194 - Friday, October 4, clarification as to its interpre Section (c)(4) p.35896 of the standard states: "The method of monitoring and measurement shalljhave an accuracy (with a confidence level cf 95 percent) of not less than plus or minus 50 percent from 0.25 through 0.5 ppm, plus or minus 35 percent from over 0.5 ppm through 1.0 ppm and plus or minus 25% over '1.0 ppm." " ' The preamble to the Vinyl Chloride Standard begins toi define a 95 percent confidence level as (p.35893 , III (4}) "that the employer is required to take a sufficient number of measurements so that the results obtained are statistically valid." Unfor tunately the reader is left without Knowing what a "sufficient number" is, no formula or minimum number given. Secondly, I do not understand the accuracy range requirement completely (p. 35896 (c) (4))-. I assume it pertains to the analytical procedure and not to the sampling procedure. Please clarify this position of the standard by explaining what is meant by "plus or minus 50 percent from 0,25 through 0.5ppm . and if it pertains to both analytical and sampling procedures or just toi the analytical portion, Your help in this matter will be greatly appreciated for I have been unable to obtain a satisfactory explanation thus far. n\ JA }. / is?r-; . S lr v: ' O-Fipr Very truly yours, // n 7- Sarunas 3. M i. ngcla Industrial Hygienist vVV 000017765 C <7 < . , ,