Document JJ6Y4RyRYnea7MR2DxKjr3XBr

TO: Distribution TGG: JjGT: XF: _ RF FROM: DATE: Interoffice Communication SUBJ: T. G. Grumbles November 28, 1988 INDUSTRIAL HYGIENE MEETING ACTION ITEMS Below are the action items from the industrial hygiene meeting held November 15-16 at Lake Conroe. There will be detailed follow-up on several of the items. Correspondence regarding these itfems will follow in the near future. 1. Copies of the overheads used during the meeting will be sent to all attendees - TGG (these are attached) 2. By December 9 anyone interested in commenting to OSHA on the generic exposure monitoring ANPR should contact TGG. 3. Determine how the Houston office number can go on the Vista MSDS's to avoid Safety Directors getting calls for additional copies - MMG/AJO * 4. Form a team to improve the industrial hygiene audit process(TGG will initiate action with Manufacturing Management). 5. Any Safety Director having written audit systems on file will send a copy to TGG. 6. Houston will consider copying Plant Managers on specified information such as new regulations and necessary actions to be taken. 7. Jim Harris will send information on the in-plant labelling system used at LCCC, Aberdeen and OKC to Campanella, Martin, and Lipps. 8. TGG will specifically review the TSCA training needs and explore developing a VISTA "corporate" program. 9. Jim Harris will send copies of his sampling forms to the Safety Directors. 10. TGG will summarize the results of the IH needs brainstorming session in a memo with suggested actions. 11. MMG/DLC will send a HAZWOPER data needs form to the Safety Directors for completion and return to DLC. 12. TGG will prepare a memo regarding IH data security and long term i storage options. Wy 0000Q0B98 Distribution Memo November 28, 1988 Page 2 13. Attendees will send their equipment lists to George Shirley for preparation of a "master" list. 14. Dr. Drumwright will prepare a memo summarizing issues raised in the generic medical testing ANPRM. Thank you for your efforts and participation at the meeting. As always we've got a lot of work to do in the near future. You'll be hearing from me soon regarding Items 4, 8, 10 and 12. T. G. Grumbles dlj .536 Distribution: Safety Directors, D. L. Morgan cc: Plant Managers, JAD, THH, JRD, WLM,' DLC, MMG, AJO, CDM VVV 000000899 Aberdeen VCM LAB LCCP OKC R&D Ham Balt Blane pp VCM * Lead Bz (done) MeCl* EO * Noise Asbestos k HF Resp. Protection Noise Haz Com TSCA* Hazwoper X X X X X - X XX X X XX XX X XXX XX X X X X X XXXX XX XXX --- XXX XX X ---- XX XX XX XX -- New Emp. Contrax. X XXX XX X XX X Instrumentation X Confined Space * Indicated need for updating WV 000000900 INDUSTRIAL HYGIENE AUDITING GOALS 1. Affirm Committment to Process 2. Concensus on Purpose 3. Review Existing System/Method 4. Discuss Alternate Systems VVV OOCOOG90I MY PERCEIVED NEEDS 1) Written objectives of industrial HYGIENE AND OCCUPATIONAL HEALTH PROGRAMS 2) Definition of company standards OUTSIDE OF REGULATIONS 3) Requirement for written follow-up or MEASUREMENT OF AUDIT ITEM WORK 4) Training/preparation of audit team MEMBERS IN PROCESS AND TECHNIQUES General concern on resource needs to IMPROVE AND RUN THE PROGRAM vvv 000000902 PROPOSED GOAL Audits are a management tool to measure COMPLIANCE WITH APPLICABLE REGULATORY REQUIREMENTS AND COMPANY GOALS OR POLICIES IN THE AREA OF INDUSTRIAL HYGIENE AND OCCUPATIONAL HEALTH AUDIT PURPOSE - Audits should provide a measure of REGULATORY COMPLIANCE AND PROGRESS IN PROGRAMS - Audits should identify areas of DEFICIENCIES, PROGRAM NEEDS, AND PROGRAM SUCCESSES Audits should help develop goals and OBJECTIVES OF PLANT IH PROGRAMS Audits do not - assure compliance! - solve problems 000000903 WHO DOES THEM Currently done with a team Options 1) Continue with team 2) Contractor 3) Plant only 4) Corporate only J 5) ? Basic goal to achieve consistency & QUALITY Use same standards at each location VVV 000000904 SCOPE OF AUDITS Currently D 0 ALL PROGRAMS AND REGULATIONS IN A BRIEF TIME-FRAME WITH PLANT VISIT Options 1) More detailed single or multiple REGULATORY AUDIT 2) More detailed total program audit via survey/questionnaire that is FOLLOWED-UP WITH A PLANT VISIT 3) Site visit with detailed check-list SENT PRIOR TO VISIT 4) ? VVV 000000905 REGULATORY OVERVIEW PROMULGATED SINCE VE MET Benzene Standard Asbestos Excursion Limit Ethylene Oxide Excursion Limit Revisions to Medical and Exposure Records Access PROPOSED FINAL RULES SINCE WE NET Generic Medical Surveillance Generic Exposure Monitoring PEL Revisions Hazard Co-munication Revisions VVV 000000906 ANTICIPATED TO BE PROPOSED (BASED ON PUBLISHED REGULATORY AGENDA) 12/88 11/88 1/89 12/88 12/88 10/88 Respiratory Protection Confined Spaces 1-3 Butadiene Final Hazwoper. Hazwoper Training Course Certification Occupational Exposures to Chemicals Laboratories YVV 000000907 ACCESS TO EMPLOYEE EXPOSURE AM) MEDICAL RECORDS Final Rule Promulgated: Effective Date: Proposal mas in 1982 Septb-ber 29, 1988 November 28, 1988 Revised Rule is essentially unchanged from 5/23/80 FINAL RULE WITH THE FOLLOWING EXCEPTIONS: D First aid and nedical records of short-term EMPLOYEES ARE EXEMPTED. 2) Microfilm of X-Rays is allowed 3) Employer trade secret provisions now consistent with Haz Com 4) Union Reps are required to show an OCCUPATIONAL HEALTH NEED FOR REQUESTED RECORDS WHEN SEEKING UNCONSENTED ACCESS TO EXPOSURE RECORDS 5) NO IMXJSTRIES TREATED SEPARATE WITH RESPECT TO TRADE SECRET DISCLOSURE ACTION REQUIRED - 1) Assure revised copy REPLACES OLD ONE 2) Communicate revision to UNION REPRESENTATIVE VVV 000000908 HAZARD COMMUNICATION STANDARD REVISIONS Proposed: August 8, 1988 Comment Period Ended: October 8, 1988 Public Hearing Held 11/15/88 o Originally expanded scope to all WORKPLACES IN OCTOBER OF 1987 o Comments received resulted in other MODIFICATIONS BEING PROPOSED o Also provided some clarifications in PREAMBLE o Some 0MB objections in expansion o Stay of effective date construction INDUSTRY ETC .... ETC .... ETC .... o Significant issues to Vista - Labeling exemptions (articles) Applicability of HCS to SUBSTANCES THAT ARE RELEASED IN VERY SMALL QUANTITIES Nuisance dust Appropriate hazard warning (target organ) Hazard determination percentages VVV 000000909 NUISANCE DUST OSHA HAS A GENERIC STANDARD FOR NUISANCE DUSTS ACGIH HAS SOME SPECIFIC NUISANCE DUSTS LISTED WITH TLV'S AND SOME LISTED IN "Appendix D" This makes nuisance dusts on floor list OF HAZARDOUS MATERIALS All dusts could potentially be a nuisance OSHA is limiting application of HCS to nuisance dusts listed in "Appendix D" VVV 000000910 SUBSTANCES RELEASED IN SHALL AMOUNTS If under normal conditions of use a HAZARDOUS CHEMICAL IS RELEASED, THE HCS MOULD APPLY UNLESS THE RELEASE MAS OF MINUTE OR TRACE QUANTITIES... AND DID POSE A HEALTH HAZARD Exposures exceeding TLV or PEL not only CRITERIA - MUST CONSIDER "HEALTH RlSK" ASPECT Carcinogens are health risk Purpose of HCS is INFORMATION ABOUT OR HEALTH RISK to ensure disclosure of HAZARDS BEFORE EXPOSURE Providing info only if CONFLICTS MITH THIS PURPOSE PEL exceeded If A HAZARDOUS CHEMICAL IS RELEASED EMPLOYEES SHOULD BE INFORMED vvv oooooo^n ASBESTOS "EL" RULEMAKING Published: September 14, 1988 Effective date: October 14, 1988 o Amended 1986 asbestos rule by adding an excursion limit (EL) of 1 fiber/cc averaged over 30 MINUTES o Also amended standard to require certain ANCILLARY PROTECTIVE ACTIONS ARE TAKEN WHEN EL IS EXCEEDED o For example Regulated areas established Decontamination facilities o Requirements - Monitoring MUST SPECIFICALLY EVALUATE 30-MINUTE EXPOSURES IN OPERATIONS MOST LIKELY TO CREATE HIGH EXPOSURES Must do initial monitoring - any done since March 14 mould count Representative job sampling allowed Periodic monitoring required if exposure above EL (not specified) VVV 000000912 APPROPRIATE HAZARD WARNING Many labels found to contain only PRECAUTIONARY WARNINGS (DON'T INHALE) VS. SPECIFIC HAZARDS Cl.E. KIDNEY DAMAGE) Not providing information on type or SEVERITY The term "including target organ WAS ADDED TO HEALTH HAZARD DEFINITION effects" WARNING Selection of hazards to be highlighted THE LABEL WILL INVOLVE SOME ASSESSMENT THE WEIGHT OF THE HAZARDS on OF This does not mean only acute hazards SHOULD BE INCLUDED May be appropriate to provide ON IN-PLANT LABELS DUE TO TRAINING PROGRAMS less MSDS info AND VVV 000000913 REGULATED AREAS Must now be established where EL is EXCEEDED For construction (maintenance) NEGATIVE PRESSURE ENCLOSURE "SHORT-DURATION" JOB AS DEFINED this is UNLESS Protective Clothing, Facilities. Training Surveillance. Respirators Hygiene Medical Now REQUIRED WHEN EL IS EXCEEDED Actions Required 1) Assess monitoring need 2) Revise existing programs 3) Notify contractors to ASSURE awareness 4) Replace old copies OF THE standard WV QOOOOO914 GENERIC EXPOSURE MONITORING - ANPRM Proposed: September 27, 1988 Comments: December 27, 1988 Purpose: Agency is trying to determine if generic EXPOSURE MONITORING REQUIREMENTS COULD BE USED TO SD'PLIFY FUTURE RULEMAKINGS WHERE EXPOSURE MONITORING WOULD BE REQUIRED. Backgroumd: 1) No monitoring requirements for Z- TABLE PEL'S ) 2) Standard would establish broad PERFORMANCE CRITERIA FOR ACCEPTABLE MONITORING PRACTICES 3) Could include provisions for a) frequency b) personal vs. area monitoring c) FULL SHIFT OR GRAB D) NOTIFICATION REQUIREMENTS E) ACCURACY LIMITS F) PROVISIONS FOR OBSERVATION G) APPLICABILITY ACTION REQUIRED: 1) Review questions in ANPRM 2) Decide if we should comment VVV 000000915