Document J5ENYwMe6600pkzrKry0qONK

1 CRITIQUE OF PROPOSED OSHA PERMANENT STANDARD CM VINYL CHLORIDE 1910.93q Vinyl Chloride 1010.03*1 Vinyl Chloride. (a> Scope and application. This i sect ion applies to any area or operation in which vinyl chloride (chloroethenet, Chemical Abstracts Service Registiy No.' 75015, is manufactured, reacted, re-) leased, repackaged, stored, or used, in cluding areas and operations involving polyvinyl chloride where detectable levels of vinyl clrloride are released. (i This section does not apply to the j handling or use of fabricated products, made entirely or In part of polyvinyl j chloride. (a) (b) Definitions. <1) ``Assistant 3ecrc- , taiy" means the Assistant Secretary of I Labor for Occupational Safety and j .Health, U S. Department of Labor or his designee.___________ _____ ____ "Authorized employee'* means an ' employee whose duties require him to be in Die'regulated area and who has been speriiically assigned by the employer: and any employee who enters such nn area as a designated representative of employees to exercise an opportunity to observe monitoring and measuring of vinyl ehlonde. 1 )* "Closed container" means any container wtilch prevents'the release of vinyl chloride to the environment. (b) Scope and application. (1) We feel that the scope and application of this pro posed standard should be divided into three parts: that associated with the manufacture of vinyl chloride monomer, the practices associated with the manufacture of FVC resin or copolymers and the third part would be the fabricators of this resin into vinyl products. Definitions. (1) No carment. (2) No comment. (3) "Closed container" means any portable waste container which prevents the release of vinyl chloride to the work place in excess of the permissible level. i+i "ConLamilisted" means capable of releasing a detectable level of vinyl ehlonde. (4) "Contaminated" means capable of releasing vinyl chloride into the work place atmosphere at levels which are in (5i `Decontamination" means reduc tion of vinyl chloride concentrations to less than detectable levels. I excess of the permissible level. (5) "Decontamination" means reducing vinyl chloride concen tratians* in the work place atmosphere to levels which are in excess of the- permissible level. 6) "Detectable level" means an air borne concentration of vinyl chloride measurable by a sampling and analytical method capable of measuring concentra tions of l ppm, with an accuracy of 1 ppm ei50 percent. i <71-"Director" means the Director. Na tional Institute for Occupational Safety ana Health, or any person directed by him or the Secretary of Health, Edura-|tlon. and Welfare to act for the Director. 1 <8) "Emergency" means an unforseen circumstance or set of circumstances, re sulting in the release of vinyl chloride into areas occupied by employees. (6) "Permissible level" ireans work place airborne concentra- tions of vinyl chloride with a time weighted average value and ceiling concentrations as defined in the following schedule. ` (7) No carment. v (8) "Emergency" means'an unforeseen circumstance or set of circumstances resulting in the release of vinyl chloride into areas which results jn .erplpyee expc^ure to-VOi in..- 1 (O' "Exposure" means actual contact with'vinyl chloride when unprotected by Required personal protective equipment fid clothing. . -2- (9) "Exposure" rreans inhalation of vinyl chloride in-, excess of the permissible level. . . (10) "Fabricated product" means a finished product or part of such product, made of polyvinyl chloride, entirely or in part, including semifinished products such as film, sheet, block, bar, or extru sion stock. (10) No content., (111- "OSSK>kTei Director" means the Directqj/OTlhe Occupational Safety and Health Administration Area Office hav ing jurisdiction over the geographic area in which the establishment is located. ' (11) No content. (I2\,"gplyvinyl chloride" means poly vinyl jfuloride homopolymer or copol ymer before such is converted to a fab ricated product. (12) No comment. U3> "Protective clothing" means clothing protective against vinyl chlo ride. . ... - - (13) "Protective clothing" means clothing required for protection of personnel when exposure to vinyl chloride contaminated liquid is. possible. There is no evidence to indicate that exposure to vinyl chloride vapors is (14) "Vinyl chloride" means vinyl chloride monomer. (15) "Waste resin" means any resin or other reaction products removed in the cleaning of equipment, such as ves sels and piping. harmful. (14) No coiment (15) NO comment. (c> Re/erence. College of American \ (c) Pathologists. 230 N. Michigan Ave., Chi- \ ca.To, li^fiois 60601. Reference. No content. Ctih# Regulated areas. (1) A regulated area shall be established where (1) vinyl i chloride is manufactured, reacted, re-; leased, repackaged, stored, or used; or| <ii) polyvinyl chloride capable of re-1 leasing detectable levels of vinyl chlo- ` ride is manufactured, reacted, released. I repackaged, stored, or used. _ i (d) Regulated areas. . (1) A regulated area in a monomer plant shall be established where vinyl chloride concentrations in excess of the ... '2* J$&fefeulated areas shall bo I limited t^-ifBthorlid employees. ,| permissible level. (2) No coiment. ' .t r . .= - ,* jjT<3' A 3aUy~ro5ter of employees enter- ! regulated areas shall be made and j liintained. The rosters, or summaries t thereof, shall bc^ kept, for at least 20 (3) We reoormend that a record, not a daily roster be kept can enployees entering regulated areas and that this roster be kept only -3- ) Monilorina. >1) Every regulated shall be monitored lor detectable j <>.' vinyl chloride. i (e) Monitoring. (1) Every regulated area shall be monitored for compliance within the permissible levels. O Tifft.' moniioilnii shall assure that iany exposttre may be determined for j each authorized employee witli a confl- I dcure leveljjf 95 percent. (2) We are critical of the 95 percent confidence level because we feel statistically this is not attainable and we will have an argument to this affect attached in our critique. We would suggest that the monitoring shall be adequate to insure reasonable definition of enplcyee exposure. < 3 * Employees'or their designated rep- ' rc.scnintives shall be ouorded an oppor- I tunily to observe monitoring and mcasur-.l ing required by this paragraph, i li( Where exeirise of an opportunity! requires entry to an area where the use! of protective clothing, equipment, fa cilities, or procedures is required, such clothing, equipment, facilities, and pro- ures shall be provided to all persons .itled to exercise the opportunity, at no to any of them. - *iiij Persons exercising the opportu- y shall be instructed regarding: A) The toxicity and tire hn/.md of! iyl chloride; and , iD) The protective steps and measures necessary for their protection. iii) Observers shall be permitted,! without interference to the persons per-, forming the monitoring and measuring,! to: ' (A) Observe all steps and proceduresrelated to the collecting, processing, and evaluation of particular monitoring and measurement samples; * fB> Record quantities and results obtained; > . <C) Observe the condition of monitor- ' In g and measuring equipment; J (D) Receive a demonstration of the s calibration and function tests of the l monitoring and measuring equipment performed onsite; and . (E) Examine instructions and docu- | ments related to the procedures and} equipment lor monitoring and mcasur- I mg. |! jT Accurate and complete records of] all required monitoring shall be made j, f and maintained for not less than 20 `f-years. Such a record shall" (i) stale the L V date of such monitoring and the levels t ^^ermined; and <il) identify the instru- >' and methods used. (3) Employee representatives must be qualified; that is, they must be either part of the bargaining unit or a federal representative of a federal agency. We also feel it is important for us to instruct all employees in regulated areas as to the monitoring procedures which will be used. (4) We recormend that only sumnary records or facimilies be retained, not individual data sheets for the 20 year period specified. Enoinccring controls and toorK-, practice methods. (1) Where detectable ) oX vinyl chloride ,are measured,: ^Mediate protection shall be provided)' tWnnst exposure to vinyl chloride by the). o( engineering controls, workpractlce |i hods, and respirators as lollows: j (1) Feasible engineering controls and! v.orkpractiee methods shall immediatelv! be used to reduce airborne concentra tions of vinyl chloride below the detect-! able level; (tit Wherever feasible engineering, controls' and workpractiee methods which can be instituted immediately are| not sufficient to reduce concentrations of! vinyl chloride below the detectable level.! they shall nonetheless be used to reduce the concentrations to the lowest prac ticable level, and shall be supplemented by means of respirators*in accordance v.ith paragraph <g> of this section; j uii) wherever no feasible engineering wol or workpractiee method can be Jtutcd immediately, immediate res-, atory protection shall bo provided ln| fordance with paragraph 'K> of this; hon;and i <iv) Jn any ease covered u.v paragrapn 1X1) ill) or * iii) ol this section, the, employer shall also undertake as soon as) practicable a program to reduce airborne loiuentrations of vinyl chloride below! Ihe detectable level, or to V.-.c greatest extent Icasiiije, solely pv means of cngl- ntcrlnr; controls and workpractlce meth ods and as soon as 2) There shall be tests made for process or cqulpmcr L leaks and for emis sion of vinyl chloride which may result from workpractjcc-;. The frequency of , these tests shall be such as to Insure the integrity of equipment and adherence to proper wovkpraclicrs. -4(f) Engineering consols and work practice methods. (1) Where work place levels of vinyl chloride in excess of the permissible level are Treasured, immediate protection shall be provided against exposure to vinyl chloride by the use of engi neering controls on existing equipment, work practice methods and suitable respiratory pro tection as follows: (i) Add "engineering controls shall be . installed" in work practices methods. (ii) Should be consistent with the permissible level. (iii) Should be consistent with the permissible level. (iv) Should be consistent with permissible level (2) No cemment. iV.V.r'j. .... =i.-v. "e: *>., t, g^ 074314 - 5- Hcspiratorp protection. in a res* ,, Tnratory protection program In accord- | ^ore with i 1010.134 shall be established 11 implemented where respirators are i ^^Huired to be used by this section. I Respirators shall be used only in || C.U.CS of emergency and where required by any other provision of this section, i! Respirators may not be used in lieu of "i feasible engineering controls or work* :! practice methods. j (3) Respirators or combinations of 1 respirators for protection against vinyl | chloride shall be selected from among . the following: j 'i> A positive pressure full facepiece self-contained breathing apparatus; (iii A pressure-demand full facepiece self-contained breathing apparatus op erating in the pressure-demand mode; (iii) A combination type "C" pressuredemand full facepiece respirator oper ating in the pressure-demand mode and a pressure-demand self-contained breathing apparatus operating in the pressure-demand mode; or (iv> A combination type "C" continu ous flow respirator and a pressure- j demand self-contained breathing ap- ; paratus operating in the pressurc-de- 1 mand mode. | (Uh) Protective clothing. (1) Employees mite:drinfugll-rbeogduylapterdoteacrteivaes shall be clothing, profoot- .;r or shoe covers, and gloves, at no !cosstt to them, and required to wear It ~ ` lie m the regulated area. ' _..i\ti2' a>lnWinhgeredeptoeclytavibnleyl chloride .powder levels of vinyl chloride is handled, employees shall also be: 'i) Provided and required to wear headcoverlngs; iii) Required to remove all protective clothing at each exit from the regulated area; and iii) Required to shower after the last , exit of the day. (3> Clean protective clothing shall be provided whenever contaminated or soiled, but not less frequently than., weekly. Contaminated clothing shall be i deror.:ami noted before reuse by removal ! for laundering or disposal. 1 (g) Respiratory protection. Respiratory protection for vinyl chloride moncmer production shall be provided according to the following schedule: Below Permissible Level - Approved chemical cartridge respirators will be available but not required. Up to 50 ppm - Approved chemical cartridge respirators will be used. 50 ppm or greater - airline half-masks or suitable selfcontained breathing appratus will be required. \ (h) Protective clothing. 0 It is our opinion that protective clothing is required only when liquid VCM or liquid contaminated with vinyl chloride is in danger of ' caning in ccntact with the worker's skin. There is no special protective clothing required for VCM vapor exposure. ii) Uyoicnc facilities end practices.: 11) Where employees arc required by > tins section to wear protective clothing 1 and equipment, change rooms shall be provided in accordance with 5 1910-141 (e>. (2) When) employees are required by this section to shower, shower facilities shall be provided in accoidance will) 1 lbl0.HHd)i3). (3) Storage or consumption of food beverage*, storage or use of smoking ^^Knon-food chewing products, and llio or application of cosmetics are ' prohibited tn regulated areas. j (i) Hygiene facilities and practices. Because of the physical properties of vinyl chloride (a gas at ambient conditions), the need for shower is only required when clothing is contaminated and retains liquid contaminated with vinyl chloride. Showering may be required for employees involved in emergency situations where gross vinyl chloride *J) Emergency situations, (1) A writ- j ten operational plan lor emergency .situations shall be developed lor .each regulated area. i2> In the event of an emergency, bp* propriate portions of the plan shall be put into operation. clothes or special clothing for operators in regulated areas during normal working conditions. Comments oonjseming storage and consumption of food and beverages is agreeable and con sistent with PPG present plant practices. (j) Emergency situations. (1) No cement. (2) No cement. (i> Hazardous conditions created by die emergency shall be eliminated and the allccied area shall be decontami* aated prior to the resumption of normal ipr rations. Ui> Special medical surveillance by a physician shall be Instituted within 24aours for employees present in the aficcted area at the time of the emergency. Where an employee has a known *t with liquid vinyl chloride such employee shall bo required to shower as soon as possible, unless contraindicated by physical injuries. Uv) Air Incident report on the emer gency shall be reported as required in paragraph <q) (2) of this section. (i) Eliminate decontamination phrase - has no meaning. (ii) The need for special medical survaillance is not required due to the fact that there is no medical 1 * treatment for acute exposure to vinyl chloride (iii) unless the exposure manifests itself in uncon sciousness or frostbite. Would be consistent with our statement on showering which was covered in (h) concerning retained liquid contaminated with vinyl chloride.. (iv) Rewrite to an incident record on the emergency shall be reported. 074316|tfi . W-}-: (3) Each authored employee shall ;-- bo trained In a program relating to the _ haam-da ot vinyl chloride and the pre^^^LUtions for safe use. (1) The program shall include: (A) The nature of the fire hazard, and the necessary protective steps: (B> The nature of the toxic hazard, Including local and' systemic effects, acute and chronic effects including specifically the carcinogenic hazard: (C) The specific nature of operations which could result in exposure to vinyl chloride, and necessary protective steps; (D) The purpose for and application' i of the medical surveillance program; (E) The purpose for and application of decontamination practices; i IE) The purpose for and significance . of emergency practices and procedures; <G> The employee's specific role under normal operating or emergency condi tions: . i <H> Specific information to aid the employee In recognition and evaluation \ of conditions and situations which may result in the release of vinyl chloride: (I) The purpose for and application of specific first aid procedures and prac tices; rj> A review of this standard at the' employee's first training and Indoctri nation program and annually thereafter. _ <ii) All materials relating "to the"pro- i gram shall be provided upon request to authorized representatives of the Assist ant Secretary and the Director. (3) No contents on the various sub-parts of this group. 0\ <k> Signs and labels. (1) Entrances to [gulateii areas shall be posted with signs larine the legend: CAN'CEP-SXJSPFCX AGENT AREA AUTHORIZED PERSONNEL ONLY (k) Signs and labels. (1) No ccnment. i2) Areas containing operations covcrcd in paragraph tk> (1) <4> of this seclion shall be posted with signs bearing the legend: - CANCER-SUSPECT AGENT IN Tin3 AREA FULL IMPERVIOUS AIR-SUPPLIED EQUIP- MENT REQUIRED AUTHORIZED PERSONNEL ONLY , j j 1 l j' , (3) Containers of waste or other ma- totals contaminated With vinyl chloride shall bo labeled: * vinyl CHLORIDE CONTAMINATED material ! CANCER-SUSPECT AGENT ' DISPOSE OP OR DECONTAMINATE USINO ! AUTHORIZED pkecedures i. t! { (4) Containers of polyvinyl chloride containing detectable levels of vinyl cldoride shall be labeled: polyvinyl chloride CONTAINS VINYL CHIORIDK VINYL CHLORIDE 13 A CANCER-SUSPECT AGENT ABSORBED BY BREATHING AND ' THROUGH SKIN (2) Change wording in second statement to "full impervious air-supplied equipment may be required" (3) No comment, (4) No comment - PVC practice. SL 074317 - - !> '"'-/' _ 8'_ ' \ j............... ' bi Containers of vinyl chloride -shall labeled: VINYL CHLORIDE DANGER EXTREMELY FLAMMADLE OAS UNDER PRESSURE MAY POLYMERIZE WITH EXPLOSIVE FORCE POISON CANCER'SUSPECT AGENT AND ANESTHETIC ABSORBED BY BREATHING AND THROUGH SKIN . (6) No statement shall appear on or near any required sign, label or instruc tion, which contradicts or detracts from the effect of any required warning, in formation or instruction. i* (1) Maintenance and dccontamina- i tion. <l) Emphasis shall be placed upon immediate clean up of spills, periodic in spection, prompt repair of equipment and leaks, and proper handling, storage and disposal or decontamination of materials to prevent airborne contamination and accidental skin contact with vinyl chlo ride. Waste materials, equipment, and other sources of vinyl, chloride in closed containers, may not be placed in areas of i ^^Usive temperature or sunlight since ^l-up of internal pressure may result R^upturc of tile container, rue or 1 iplosion. (5) Eliminate "may polymerize with explosive force", since this has not been substantiated. Eliminate the word ""poison" since by definition, vinyl chloride is not a: ^ . poison. Eliminate the last statement "absorbed by breathing and through skin" and replace it with "do not . breathe vapors". (6) No coiment. (1) Maintenance and decontamination. (1) It should be emphasized that irrcnediate clean up of spills, refers to liquid which may be contaminated with vinyl chloride. Pure vinyl chloride would not remain as a liquid for any extended period of time. We also recommerw that instead of the wards "prevent airborne contamination' we change to "minimize airborne contamination" with vinyl chloride In second sentence should be noted parenthetically that under the strict definition of the sentence, it would be impossible to ship vinyl chloride in containers, tank cars or barges, or tank trucks. We don't believe this is the intent of that statement. i2> Waste resins or other materials j contaminated with vinyl chloride shall be 1 placed in closed containers pending dis- posal or decontamination. <3 > Appropriate procedures shall lie developed and implemented for the de contamination or disposal of all such waste material. (2) No content. (3) Rewrite - Appropriate procedures shall be developed and implemented for the protection of the worker during de contamination and disposal of waste material. SL 074318 *4' In maintenance or repair opera* on contaminated--systems or c^^Bient, including vessel entry, rmengaged in such operations shall bo ij) provided with and required to I wear and use a whole-body air-supplied i suit Impervious to vinyl chloride, and a 1 respirator in accordance with' paragraph ! ig' of'this section; and (ii> required to shower after removing protective equip ment. .. *r>> Protective clothing and equipment be clean and dry for cai Ft use. id When vessels or piping systems arc opened local exhaust ventilation shall be provided to n-move the escaping vapor from uil occupied arcus. i7> hi Vessels to be entered slmll first bu vcuLilatrd and monitored so that the concentration of vinyl chloride is reduced to a level within the protection factor capability of the protective equipment. ' 'ii> When vessels are to be entered, all; piping to such vessel shall be: , iA> Opened, b! inked and tagged; or :" (B> Where welded piping is in use. not, i less than 2 valves in scries, which isolate- . tlie vessel from ony other connection to ' such line, must bo closed and secured. ^(iili No employee shall enter a vessel,; cpt when another employee properly j %cd and equipped for entry is pres-' , i* observing the employee in the t vessel. The observer shall have means ^H^ignalhng for help in the event the ^^oyefcexperlerteeiiprbbiemii'Vnder' It*! f^r help(......,,,v.fcMci im theeinplbybeyqntllybiiother'j^-^h? is p PrestoA v> C -9- (4) (x) Where employees are engaged in cleaning and maintenance operations inside vessels with VCM. concentrations below 50 ppm. approved cartridge respiratory protection shall be used. In maintenance operations where the 'VCM concentration cannot be reduced below 50 ppm, approved air supplied breathing apparatus will be used. Protective clothing will be required only when contaminated liquid is present. (ii) Shower facilities will be available to employees after use of protective clothing. (5) Inpervious special protective clothing and equipment shall be clean and dry for each use. . (6) When vessels or piping systems are opened, adequate ventilation shall be provided to maintain VCM concentration within permissible levels. (7) (i) No comment. (ll) No CCfITnent. (iii) Eliminate the last sentence vdiich says "Under such conditions, the observer shall signal Transportation loadinp and an- ' loaning, (1) Facilities for the loading an^mloadlng of vinyl chloride to and: f^^Kontalners shall have each transfer j lfl^Bid vapor-equalizing line equipped wi^rvent connections, and shall have an Inert gas purging system. Vent and purge effluent shall be returned to a proc ess stream or flared In a safe location. <21 Procedures shall be developed ana Implemented for the transfer of vinyl chloride. Written copies of sueh proce dures shall be provided employees en gaged hi such operations, and sueh em ployees sliall be fully trained and re hearsed inall procedures. t3) Employees engaged in tran xtev op erations shall be provided with and required to wear respirators in accord ance with paragraph (g) ol tills section. Polymer handling operations. (1) liners ol polyvinyl chloride releasu^Hctectablc levels ol vinyl chloride shlro be opened and transferred only under local exhaust ventilation which reduces the concentration of vinyl chlo ride below the detectable level. '2) Hot operations, such as but not limited to milling, calendering and ex truding, which release detectable levels jf vinyl chloride, sliall be earned on only ir.der local exhaust ventilation which reduces the concentration of vinyl chlo ride below the detectable level. ini Medical surveillance. Not Inter ban _______ _____ 1974. a program >f medical surveillance shall be instiutud. and shall provide each authorized mployce with an opportunity for c.\.mmailons in accordance with this paraTuph. All medical examinations mid iroccdnrcs shall be performed by or aider the supervision of a licensed locior of Medicine tMD) or Doctor of Xxteopathy (DO). All medical esainiimions and tests shall be provided without ost to the employee. < 1 * At the time of Inlilnl employment, r upon institution of screening a phy.sl at examination shall be performed with attention to detecting entargeHii liver or spleen by abdominal ulTOIoii. M the time of Initial employment Si. Institution of screening, nnd utherealler. ,,n ,, nje^lcM . history - 10 - (m) Transportation loading and unloading. (1) This statement should be modified to indicate that vent and purge lines associated with the process shall be returned to the process system where possible or vented to suitable areas to prevent the exposure of workers to hazardous concentrations of vinyl chloride. (2) No cormant. (3) ' Should be consistent with the provisions in (g) ,c e and should refer to loading and unloading :^ C operations, Tiot "transfers">r' (n) Polymer handling operations. No contents are made since this is not part of a monomer plant operation; however, the recommendation^ under this heading should be consistent with the rest of our proposed recormendatians. (o) Medical surveillance. Basically, the comments concerned in the medical surveillance section are acceptable except for the following items. `/ i a -r is* ^sl 074320'tmm -Z .V1 .- ' -1 'it Alcohol lnlakc: Mu Past history of hepatitis; #uin Past exposure to potential hcpaoxic agents,' Including drugs and micals; <ivi Past history of blood transfu sions; and < v Past history of hospitalizations. *3' At Uic time of initial employment, or ui>on institution of screening, a scrum ! specimen shall be obtained for screening with respect to the following bio-cliemi- cal determinations of liver function: Total bilirubin; <u) Alkaline phosphatase; i hi * Scrum glutamic oxalacetic trans aminase (SGOT); <iv) Serum glutamic pyruvic trans aminase <SGPT); and ,iv> Gamma glustamyl transpeptidase (GGTP). (4) Additional tests that may option ally be considered for use in screening , include: j Lactic dehydrogenase: <ii) Serum protein determinations; (iii> Serum protein electrophoresis; and uv> Platelet count, < 5) Laboratory analyses for all blologi- cal specimens included In medical examillations shall be performed in laborn- ; tories. accredited by the College of | American Pathologists or licensed under l . 43 CFP. Part 74, . _ ' 1 Cj If the results of Screening required paragraph <o><3> ol this section are irmal, screening shall be repeated: _*h\\o have been employed in vinyl chlo- mkdreer: ealnadted operations for 10'years or in Annually for all other employees ^rnte: ;ng regulated areas. <7> If one or more liver function tests performed are abnormal, serum testing .shall be repeated as soon as possible, preferably within two to four weeks. If no aonormalitics are present upon re scree: iing. scrum testing shall be re peated in three months. <8* If abnormalities persist upon re- | screening, the employee shall be with- j diawn from areas where contact with j vinyl chloride is possible, and an indivld- [ . unkzec! medical workshop shall be in- : stituted. Suggested as initial steps arc a , coinple'.c physical examination and vari- j ous special procedures such ns hepatitis II anr:ecn determination and liver scan- ( mile. If liver function abnoi malities are rbhernuned to be unrelated to liver dis ease. the employee may be permitted to re'ar.i to vinyl chloride-related employ-' j ment, subject to Individual medical ev.duition. ii)> A complete and accurate record of i e.'uh.s of medical examinations siinll made and maintamed for the dura* Tlooin of employment plat five years, or dr 30 years, whichever is longer. > (6) (i) Rather than have the screening repeated every six months, we would recommend that this be an annual screening which is- what. we do at the present time at our plants. (7) JVbdify the definition of liver abnormalities t state that one abnormality in employees with over ten years exposure should be sufficient to warrant repeating the serum testing and for workers with less than ten years, two abnormal liver tests are required before repeats are necessary. (8) Employees shall be withdrawn from areas where contact with vinyl chloride is probable. SL 074321 - 12 - <l>> Krmnli. (l> Records of monitor-" Land measuring, mcdlcalrecords. and Voted area entry rosters and sum_ nc*. shall be made available for examlnatlon and copying upon request to authorised representatives of the Assist ant Secretary and the Director i ; ial Xu the event that the employer] ceases to do business and there is no sue-; cessor to receive and retain his records for the prescribed period, these records -hall be transmitted by registered mail to the Director, and each employee indi vidually notified in writing of this transfer. <3> Employees and their designated, representatives shall be provided access, to examine and copy records ol monitor ing and measuring. (p) Records (X) Msdical records can be reviewed only by medical personnel and not by the Department of Labor representati Records should be of surrmary in nature rather than having each detail log sheet. (2) No carment. '0- L 1w * (3) Each employee-or his designated -representative shall have access to his own records on occupational exposure. 4 Former employees shall be pro vided acces to examine and copy records reflecting their own exposures. (4) Insert ... own "individual" exposures. 7 t5> Upon written request of any em ployee, a copy of the medical record of such employee shall be furnished to a physician designated by the employee in . such request. (5) Should be rewritten more specifically and state "Upon j written request of any enployee, a copy of his own nedica record shall be furnished to a physician designated by hii] it in such a request Tq> Reports. (1) Not later than 1---------the following Information shall sported to the OSHA Area Director, change in such Information shall be ted to the OSHA Area Dlicctor ; within IS days of such change. | (1) The address and location of each establishment which has one or more regulated areas; and I (ii) The number of employees in each ! regulated area during normal operations, l including maintenance. ! (2) Incidents which result In' the re- > lease of vinyl chloride Into any area j where employees may be exposed shall oe reported in accordance with this para- j graph. , ! A report of the occurrence of the I incident and the facts obtainable at that! time including a report on any medical | treatment of affected employees shall be made within 24 hours to the OSHA Area ' Director. .. fill A written report shall be filed with the OSHA' Area Director within 15 calendar days, thereafter and shall in-, ' elude: 1 '. \ - ~ - (A) A specification of the amount of . - material released: A description of the area involved ` Jhb the extent of known and potential1. - 13 - (q) Reports. (1) No oanment. (ii)s. The total number of employees in regulated areas during normal operations. .. (2) Change the word "incident" to "emergencies" and specify that the anergency is a case in which anployees were exposed to vinyl chloride in con- centraticns greater than defined by the permissit level. (i) Recommend that OSHA be consistent with their , own practices in the Act which requires noti fication in case of fatality or injury to five or more people within 48 hours. We see \ no reason for notification of the Area i Director within 24 hours of any vinyl chlorid mishap, for an exposure that everyone believes requires long laden periods to re suit in any harmful effects. The 24 tour notice seems rather quick and unnecessary and ' should be deleted. (ii) Instead of 15 days, the report shall be , ** ; - . filed with OSHA within 30 calendar days. '1 (A) ; An estimate of the amount of vinyl . ! chloride released should be.made. We nee ; ' to be specific here that we want to reporj vinyl chloride, not inert material. '? No eminent. ' ' \ ' ii A report on any medical treat-. lent of affected employees and any j logical surveillance program iniplcwS: and ' <D) An analysis o1 the circumstances i f the incident, and measures taken or I j be taken, with specific completion j ates. to avoid further similar releases. I <3> Upon completion of any monitoring ! ud measuring which discloses that any niployee has actually been exposed to Ictcctable levels of vinyl chloride, each ueh employee shall be individually notiied in writing. Tlic notice shall: <i) Be delivered r.ot later than 10 .-orking days after completion of the aonitoring and measuring; fii) State the actual exposure in terms >f concentration and time: and <iii) State the steps which have been aken, arc being taken, and will he taken, j ;ith specific completion datoiCto terml-; iate the exposure and prevent u recur-1 vnee. -a - 14 - / (C) Medical treatment is not warranted because of vinyl physical properties. (D) An analysis of the emergency and measures taken with specific dates should be made. V,:vri (3) Monitoring results shall be posted for : review by all ertplqyees. (Note: This is , . similar to what we do with the lead health ' status at Beaumont.) ; ii Vs . A.WJ ._'''`7j>T,r^' >'.Vie."c1s ,, NOTE: Only the Appendix Table of Contents is attached * since most of the items in the Appendix have been reviewed. '1 s APPENDIX TABLE OF CONTENTS I II III IV February 8 Statement April 30 Statement Internal Work Practice Document for Vinyl Chloride Monomer Tabershaw-Cooper Associates Epidemiological Study 0 \,