Document JNoaex1Dg6OjKGNVx9BzR6e7K
DATE: TIME: PLACE:
CHEMICAL MANUFACTURERS ASSOCIATION
Record of Meeting of the
Vinyl Chloride Panel with the
U.S. Department of Transportation
August 12, 1992 10:00 a.m. U.S. Department of Transportation 7th and D Streets, S.W Washington, D.C.
LIST OF ATTENDEES:
John Coburn George Cushmac Charles Ke Vergel Perry Frank Sollman
OxyChem U.S. Dept, of Transportation U.S. Dept, of Transportation Dow Chemical BFGoodrich
Has Shah
CMA
1.0 Mr. Vergel Perry provided background information on the Vinyl Chloride Panel and VCNet. Dr. Has Shah will send copies of the Vinyl Chloride Safety Awareness Training manual to Drs. Charles Ke and George Cushmac.
2.0 Mr. Frank Sollman discussed industry's concerns regarding the shipping label name, "Vinyl Chloride, Inhibited," under 49 CFR 172.102. Mr. Sollman emphasized that most domestic shipments of vinyl chloride and shipments to Canada and Mexico are not chemically inhibited and, therefore, would not be in compliance with shipping label name. Mr. Sollman also described the vinyl chloride loading and shipping practices that would prevent vinyl chloride polymerization over short hauls (less than several weeks). The Panel representatives also mentioned that they do not know of any polymerization incident of uninhibited vinyl chloride commercial shipments in the U.S. The polymerization of vinyl chloride during domestic, Canadian, and Mexican shipments is prevented by keeping vinyl chloride dry, free of caustic impurities, and maintaining low oxygen atmosphere (less than 0.1%) in the tank cars or pipelines.
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ROM Vinyl Chloride August 12, 1992 Page 2
The Panel representatives also described the vinyl chloride storage conditions and practices in plants, which are similar to transportation conditions and practices with respect to impurities, humidity, and oxygen level controls.
3.0 DOT representatives asked questions about vinyl chloride shipment practices in Europe, Asia, and the Pacific Rim. Panel representatives responded that they do not have that information, but they will contact companies in those regions and submit information to DOT. Based on information received, DOT will determine if alternative shipping label name should be considered only for U.S shipments or for all international shipments. In the later case, DOT will work with the U.N. to affect the necessary change.
4.0 The meeting adjourned at 11:45 a.m.
Subject to Approval September 24, 1992
Hasmukh C. Shah, Ph.D. Manager, Vinyl Chloride Panel
CMA111767