Document KR4XLnmw12d4gBex0dnq9NyBx

(conoco) Conoco Chemicals Company A Division of Conoco Inc. 5 Greenway Plaza East R.O. Box 2197 Houston. TX 77001 November 5, 1981 Newell Bolton Union Carbide Corporation 270 Park Avenue New York, New York 10017 Subject: E0IC Industrial Hygiene Questionaire Dear Newell: Following are comments and recommendations on the Industrial Hygiene Questionaire content. As indicated in the minutes of the IH task force the items 5.1 thru 5.5 were "items" to be included In the questionaire. I trust it is correct to assume that the actual questions will be formulated based on our responses to you. Section 5.1, Standards, combines the issues of exposure standards used in individual companies and exposure level measured. I feel the exposure levels measured and currently known by industry are important enough to warrant a seperate and more detailed section of the questionaire. This has always been a large part of any OSHA ANPRM. Section 5.2 on Personal Monitoring should be expanded to include questions con cerning.the limitations and problems with the sampling techniques used. This includes such items as lower detection limits, sampling time and flow rate limit ations, and storage time or transportation problems. Section 5.4 on Respitory Protection should be expanded to distinguish between routine and non-routine use of respitory protection for exposure control. In general if the questionaire is to be complete for gaining information to respond to an ANPRM it should include questions on employee educations programs and practices, and Medical surveillance. The Medical Task force has indicated that they.would probably have questions to be included and should be contacted for their input. These comments are fairly general in nature and I will be happy to lend specifics when needed. Thomas G. Grumbles, Director Industrial Hygiene sef cc: Wes Jordan Becton Dickinson CCR 0000017