Document KG2LXObbB8ZLgxDKLb4Z74QE2

UKIRGY4L w UNIROYAL, Inc. '' 'Oxford Monagement A Research Center . Mr. Julius Jlmeno Hearing Management Officer Occupetlonel Safety & Health Administration 1726 M Street, N.W. Room 200, D.S. Department of Labor Washington, D.C. 20210 RE: DOCKET CSH-36 PUBLIC HEARING - PROPOSED STANDARD FOR OCCUPATIONAL EXPOSURE TO VINYL CHLORIDE - SUBMITTED WRITTEN TESTIMONY OF UNIROYAL. INC. ON JULY 9. 1974 , Dear Mr. Jlmeno: ..''H Following the UhlROYAL testimony on July 9 at the vinyl chloride hearing, one of the attorneys questioned me as to the need of a medical surveillance program in a fabricating plant. One of the Medical Directors in the audience subsequently spoke to me. His understanding of what I said was quite different from what 1 meant to imply. This letter is to correct any error in wording which I may have made. The thought I meant to get across follows: A good medical program la highly desirable in any Industrial operation. However, experience has shown that typical VC exposures in PVC fabricating plants are not more than a very few ppm. It is extremely unlikely that these concentrations would cause an effect which could be detected by medical surveillance. Therefore, liver function or other tests aimed at VC effects would be fruitless and unwise. Very truly yours, CtflTTAArvL* VDH/mab V. D. Harris, Fh. D. Corporate Industrial Toxicologist % c nr" Qcr> 3i --`- .* 3 % *1 4 UNIROYAL CHEMICAL Division of UNIROYAL, Inc. ,_Elm Street ' Nsucstuck, Connecticut 06770 > V" KS-7MM2 July 11, 1974 Mr* Julius Jimeno Hearing Management Officer Occupational Safety and Health Administration 1726 M Street, N.W. Rom 200, U*S, Department of Labor Washington. DC. 20210 Re: Docket OSH-36 Public Hearing - Proposed Standard for Occupational Exposure to Vinyl Chloride Submitted Written Testimony of Uniroyal. Inc, on July 9. 1974 Dear Mr* Jimeno: Would you kindly make the following correction in our written submittal* On the second from last page (the first page of the two-page Conclusion) in the third paragraph delete the phrase "time weighted average" and substitute the word telling Thank you* Very truly yours, MJKslads M, J.sKieinfeld, Director Commercial Planning H < UNIROYAL, INC. Rople 2, Box 32 Frmvill, Virginia 23901 June 18, 1974 The Honorable H. F. Byrd, Jr. United States Senate Washington, D.C. 20510 Bear Sir: Hr. John Stender, Assistant Secretary of Labor, will be conducting an OSHA hearing in Washington, June 25 to June 28, 1974 regarding the exposure of workers to vinyl chloride gas (VC). Vinyl Chloride gas has been identified as a very hazardous naterial in that it can cause cancer of the liver. As a result OSHA. has issued a temporary standard limiting exposure to 50 parts per million in the air being breathed. OSHA has further announced its intention of issuing a permanent standard in October specifying "no detectable level". The June hearings will provide an opportunity for all Interested parties to speak to the proposed standard. Ve want you to be aware of the impact a "no deteotable level" standard could have on our plant. In all probability the Poly Vinyl Chloride (PTC) industry would be shut down by such a stringent standard. Poly Vinyl Chloride is the end product of the polimerization of vinyl chloride. If manufacturers of FTC could no longer supply us with this material our plant would be forced to close. We use FTC to manufacture both waterproof and fabric footwear. Our plant employs two hundred and twenty people in Southside Virginia with an annual payroll of $1,600,000. Purchase of raw materials, fuel, utilities and taxes add another $2,200,000 to the economy. These would be lost to the local, state and national communities. Ve do not advocate any worker be exposed to a working condition that will affect his health or safety. We do advocate however a logical non-emotlonal approach to the problem, leading to solution that will permit our plant* continue to operate and provide our employees with dobs. Ve respectfully ask that your offioe bring these points to the attention of Assistant Secretary Stender. Should you need any further information please do not hesitate to us. :`i . Sincerely, :; :f?Irr.r:7r 7577rr:::- - sz 190 " W j > Hhotoxy Manager t