Document KRL9Ex8oEk8RMZmjVVdvoOeNK

HILL AND KNOWLTON, Inc. FROM KING FEATURES SYNDICATE, 235 EAST 45TH ST., NEW YORK, N.Y. 10017 FOR RELEASE MONDAY, JULY 29, 1974 CHAMBERLAIN: Clear thinking can keep us from throwing the baby out with the vinyl chloride. THESE DAYS BY JOHN CHAMBERLAIN CONFRONTATION IN THE PLASTICS INDUSTRY We live in the midst of many fears. The trouble is that we have no means of knowing in advance just how many of these fears are misplaced. Yesterday it was cyclamates that were going to do us in. But today cyclamates have been given a reasonably clean bill of health. So it has been with cranberries. But other presumed perils arise. The sudden publication by the B.F. Goodrich Co. of news that four workers at its Louisville, Ky., vinyl chloride conversion plant had died from a rare form of liver cancer called angiosarcoma now has workers in other chemical plants around the country lining up for diagnostic tests. The question is, will the new fear pass with the assurance that the chemical industry will accept a standard of 50 parts per million exposure level to the gas that is used to make solid polyvinyl chloride? (Such is the standard accepted in Britain.) Or will the Naderites, who don't believe that the industry ever has a case, insist on killing the entire polyvinyl chloride business by demanding a "zero exposure" safety standard, which cannot in the nature of things be guaranteed? r- 7 TOL zssz Open Concern Whatever one may say, the industry itself cannot be accused of cover-up practices. The B.F. Goodrich Chemical Company has led the way in making investigations designed to establish tolerable exposure limits. In the early days of vinyl chloride conversion to the polyvinyl plastic solid that is used in a myriad of industrial products, nobody worried about the sweet-smelling gas that lingered in the plants. Since it takes 15 years and more for an angiosarcoma tumor to develop, it is important to know whether the 20 or so cases of liver cancer that have been identified as orginating from vinyl chloride exposure date back to a dark age of the plastics industry that has already passed away. The trouble is that adversary proceedings in which'the advocates of extreme positions face each other in Washington will not necessarily lead to a scientific settlement. In Europe, accredited technicians set standards without indulging in passionate arguments and incriminations. But in the U.S., opposing value systems clash, and the scare headlines make it seem that heroes are contending with villains, with industry invariably getting the worst of it. Marginal Notes Despite the Naderites, however, the general public has a special interest in a scientific determination of tolerable safety margins. Some 6,500 U.S. workers now work in plants that turn vinyl chloride gas into a solid plastic. Economically speaking, if 6,500 workers were forced to seek other employment it would cause no great crisis. But 700,000 workers are needed to make finished plastic products out of the raw polyvinyl material. And a grand total of 2.2 million workers throughout the U.S. economy have jobs that can be traced to the use of polyvinyl products. Ticking these products off is an almost endless job. The pipe now in most frequent use for plumbing is a polyvinyl pipe. The tile in your shower bath, the cover on your automobile seat, the tubing used for electric milking machines that give you relatively cheap dairy products, the clear wrapping in which bacon and other meats are sold, the phonograph records that bring you music, and the safe insulation around copper wiring that enables you to electrify your house at a minimum of expense, are all fashioned out of polyvinyl chloride. Even the respiratory equipment used by doctors comes from polyvinyl plastic; the medical supplies made out of the stuff have surely saved more lives than have been lost by exposure to the raw vinyl chloride gas. If polyvinyl plastic were to be replaced by a natural product, the whole of continental Europe would have to be turned over to sheep raising for industrial fabrics. The paper industry, even now suffering from shortages, would be unable to cope with the demands for wrapping derived from forest products. Nevertheless, even though 2.2 million jobs are dependent on polyvinyl plastic, it is crass to use economics to make a case for the industry. The safe limit of vinyl gas control must be found. August 25 is the cut-off date for the submission of evidence in Washington. October 5 is the date set for the final decision about the safety margin. What we need is a lot of light and no heat when the ultimate judgment is made. Distributed by King Features Syndicate (AH) 23527012. HILL and KNOWLTON, Inc. FOLLOWING DON OAKLEY EDITORIAL DISTRIBUTED BY NEWSPAPER ENTERPRISE ASSOCIATION (NEA) TO APPROXIMATELY 800 NEWSPAPERS NATIONALLY. CLIPPING SERVICE RETURNS INDICATE KNOWN USAGE OF THIS WIDELY CIRCULATED COLUMN . . . . 23527013 HILL AND KNOWLTON, Inc. Don Oakley A matter of life and speed limits P i \ T U.i , .V By Don Oakley There are few simple choices in this complex technologi cal world. Often the question of what will bring the greatest good to the greatest number comes dow.n to trying to decide what will cause the least harm to the least number. Congress, for example, is considering making permanent the emergency 55-mile-per-hour speed limit on highways. A flood of data shows that not only has it saved fuel but it has brought about a significant reduction in deaths and injuries from traffic accidents. Obviously, a lowering of the limit to 45 or 35 would save even more resources, both material and human. The ideal situation would be no traffic deaths a! all. But long before we achieved that goal, which would require the banning of motor vehicles entirely, we would reach a point where the benefits would begin to be offset by other undesirable effects, such as the serious disruption of the economy. Another example is the current controversy over polyvinyl chloride -- PVC -- a chemical used in an extremely wide Variety of modern products, from food packaging to automo-' bile parts to plastic heart valves to phonograph records. ' Last January it was discovered that angiosarcoma, a rare form of liver cancer, had been the cause of death among some 19 workers in the United States and Europe involved in processing vinyl chloride, a gas, into PVC. The workers had been exposed to the gas for anywhere from 14 to 27 years before the cancers appeared, raising the possibility that more cases would begin turning up. Because of this, the Occupational Safety and Health Ad ministration of the Department of Labor proposed an emergency standard, effective April s setting a maximum exposure level of 50 parts per million of vinyl chloride in the air. The previous level had been 500 parts per million. Then in May, theOSHA proposed a permanent standard to reduce the exposure of vinyl chloride workers to a "no de tectable level. The Society of the Plastics Industry, claimed that there was no possible way to meet such a standard and that it would threaten the very existence of the industry. The OSH A. as is customary, held hearings in Washington at the end of June. On one side, a number of PVC manufacturers or users of PVC, both large and small, testified that they would be forced out of business if the "no detectable level" were1 adopted. One maker of plastic tubing for medical uses warned that desperately needed equipment in kidney, dialysis and heart surgery might become unavailable. On the other side,organized labor strongly backed the pro-1 posed standard. "This country survived for nearly 20(1 years without polyvinyl chloride and we can survive in the future without it," said Peter Bommarilo, president of the United Rubber Workers and chairman of the health and safety com mittee of the AEL-CIO. Labor Department spokesmen disputed industry claims that the proposed regulation would stop vinyl chloride pro duction and throw out of work as many as two million people in the plastics and other industries. The department did acknowledge the existence of some marginal firms might be jeopardized if they were forced to raise prices to pay for safety measures. The upshot of the hearings was a decision to delay the standard until October 5 while a study of its technological and economic feasibility was made by the OS11A. "What we in OS1IA have to do," said its director Daniel P. Boyd, "is to arrive at a practical solution based on a subjec tive, but detailed, analysis of all the factors under considera tion." In other words, just what is (he balancing point between the health threat of vinyl chloride and PVC to workers and the public and the economic threat to the industry? In stili other words, what should this particular "speed limit" be? . . frlO L Z S S Z HILL AND KNOWLTON, Inc. Oakley Editorial Carried By: News Tribune Tacoma, Washington The News Springfield, Mo. The News Sidney, Ohio The Press Ashland, Wise. The Nevada Times Ely, Nev. The Texas Tribune Terrell, Texas Tribune-Herald Waco, Texas The Times Salisbury, Md. The Sentinel Scottsboro, Ala. The Leaf-Chronicle Clarksville, Term. The News-Herald Panama City, Fla. The Reporter Fond Du Lac, Wis. The Ledger Antioch, Calif. The Tribune Mesa, Ariz. The News Athens, Ga. The Ledger Enterprise, Ala. Foster S. Democrat Dover, N. H. The Banner-News St. Charles, Mo. The Advance Lynchburg, Va. 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The Herald Austin, Minn. The Press Sheridan, Wyo. Jackson Daily News Jackson, Miss. Desert Dispatch Barstow, Calif. Daily Record Long Branch, N. J. Tribune, Monitor Fort Scott, Kans. Jeffersonian Cambridge, Ohio The Post Frederick, Md. The Banner Logan, W. Va. South Dade News Leader Homestead, Fla. Argus-Courier Petaluma, Calif. Wyoming Eagle Cheyenne, Wyo. Courier-Express Dubois, Pa. The News Holla, Mo. The Journal-Herald Waycross, Ga. The News - Welch, W. Va. The Star Meridian, Miss. The News Rogers, Ark. The Times Kerrville, Texas The Democrat Carrollton, Mo. Democrat News Marshall, Mo. Journal-Advocate Sterling, Color. The Standard Celina, Ohio The Bee Danville, Va. The Globe Joplin, Mo. The Star Niles, Mich. The Tribune Hibbing, Minn. The Evening Tribune Albert Lea, Minn. The Times Portsmouth, Minn. The Bulletin Anderson, Ind. The News Tribune Woodbridge, N. J. The News Frederick, Md. The News-Herald Suffolk, Va. The Advocate Victoria, Texas The Boomerang Laramie, Wyo. 9T0L2SS2 HILL and KNOWLTON, Inc. The Bulletin Brownwood, Texas The News-Press Fort Myers, Fla. The Enterprise Pecos, Texas The Times-Record Valley City, N. D. The Times News Lehighton, Pa. The News Brunswick, Ga. Inter-Mountain Elkins, W. Va. Millville Daily Millville, N. J. The Reporter Coldwater, Mich. The Democrat Natchez, Mass. Dispatch Oneida, N. Y. Mesabi News Virginia, Minn. Times-News Mt. Pleasant, Mich. Record Gazette Banning, Calif. News-Tribune Keyser, W. Va. Leader Telegram Eau Claire, Wise. News Journal Radford, Va. Gazette Bellevue, Ohio Gazette McCook, Nebr. Times-Journal Selma, Ala. Freeman-J ournal Webster City, Iowa Home Talladega, Ala. 235270X7 HILL and KNOWLTON, Inc. OCCUPATION/.!. HAZARDS CLEVELAND, OHIO MONTHLY 24,200 SEP 1974 , /Lr2tJfJtwr- The VC standard: The arguments are m, OSHA's decision is imminent by Carl P. Musacchio Is there a safe exposure limit for vinyl chloride? On that question could hang the fate of an entire in dustry, thousands of jobs, and bil lions of dollars in sales and profits. OSHA's proposed standard for exposure to vinyl chloride (VC) holds that there is no safe limit. It calls for no measurable concentra tion of VC in the workplace--in other words a threshold limit value of zero. Spokesman from industry prophesy that adoption of this stand ard would end production of VC and, in so doing, have devastating effects on the plastics industry. The drama began last January when B. F. Goodrich Chemical Co. announced that several deaths from angiosarcoma of the liver, an ex tremely rare cancer, had occurred among workers in vinyl chloride op erations at the company's Louisville plant. Goodrich Chemical called in Ken tucky public health officials and the National Institute for Occupational Safety and Health. After an initial investigation Dr. Marcus Key, direc tor of NIOSH, made a momentous announcement: "On the basis of the medical, epidemiologic, and tox icologic findings thus far, it would appear that a new occupational can cer has been discovered: angiosar coma of the liver. It is associated with the polymerization of vinyl chloride in the manufacture of poly vinyl chloride. Vinyl chloride is the chief suspect among the more than SO chemicals used in the plant." That announcement hit the indus try like an iceberg scraping the hull of a luxury liner. Without question an emergency was at hand, but as long as the watertight Compartments held, there was no cause for panic. The deaths were, after all, in one plant, and they involved only the polymerization process which con verts vinyl chloride monomer, a gas, into solid granules of polyvinyl chloride resin. Synthesis of VC monomer and the polymerization process involved only a small seg ment of the industry. Fabrication of PVC resins into myriad products, ranging from auto seat covers to insulated electrical wire, involved far more workers a-'d was the eco nomic mainspring of the industry. As the Manufacturing Chemists Association pointed out: "It is esti mated that about 1,500 workers are employed in monomer synthesis, and an additional 5,000 in polymeriza tion operations. It is difficult to estimate the number of workers en gaged in converting, molding, and fabricating these polymers, but they arc numbered in the tens of thou sands, working in thousands of plants. It has been estimated the wholesale value of the annual out put of fabricated products is over $3 billion." Cancer spreads Within weeks of the first an nouncement it became clear that the cancer was not confined to one operation in one plant. Cases of an giosarcoma were discovered among workers in synthesis and polymer ization plants in several States and in Europe. In early May, the vast vinyl fab ricating industry was implicated. A group of German scientists reported to a conference on vinyl chloride hazards sponsored by the New York Academy of Sciences, the American Cancer Society, and NIOSH that six cases of serious liver disease had been discovered in a German plant manufacturing vinyl floor tiles. None of the afflicted employees had cancer, but the scientists believed the symptoms might have been those of incipient cancer. Again, VC monomer was suspect. The inves tigators guessed some VC monomer had eluded the polymerization proc ess, and had become trapped in the PVC resins. Over the years then, the workers had been exposed to VC monomer escaping from the resins. A month later, the Connecticut Department of Health reported two deaths from angiosarcoma. Both victims had worked in plants making finished products from PVC. One had worked at coating electrical wire with vinyl. The second was an ac countant for a firm that fabricated products of PVC. An investigation was launched to learn if he had ever worked in the plant. Most ominous of all was a report from Connecticut that two cases of angiosarcoma might have resulted from environmental, not occupation- 5plmb*r 19/4/OCCUfATIONAl HAlAtOS 101 *0 o & "There isn't any ,-:cL Of Hi likelihood . :. that we .vd'jS :-are going to put;. i -v - -j Vthe industry out of ^business.' >r, Danie .-Director, . . .-' OSHA Office of * miStandards Development Jf* j$"The; effect' Cofithe^tgri pqproposed standard] ontfifif F,the .nation's: economy % would, be catastrophic." r*& is&.>.:RalphL. Harding<8 L-#Lf> ' : President, ?.! -.Society for the I S"f*' ' ' Plastics industry* ">! .C--z- .____ L.!. al exposure. One victim was a man who lived about a mile from a PVC product fabricating plant. The other, a housewife, lived even farther from a similar facility. Now every phase of the industry had been involved, and some were calling to abandon ship. In April, Peter Bommarito, president of the United Rubber Workers, had warned: "I feel this is a figurative and literal life-and-death struggle for the polyvinyl chloride resin in dustry in the world." In June, after the dimensions of the outbreak had become clearer, Bommarito added: "If PVC cannot be made and usedsafely, then the proposed OSH A standard must be replaced by an or derly procedure to phase out VC production and find substitutes for its products, or to phase out the products themselves." Out of business? Little wonder that some spokes men for the plastics industry be lieve that phaseout of VC and PVC is a real, though unjustified, possi bility. They see the proposed OSHA standard for worker exposure to VC as the specific threat. Through their major trade associations, es pecially the Society for the Plastics Industry (SPI) and Manufacturing Chemists Association (MCA), man ufacturers and users hammered across their message in 9 days of OSHA hearings on the proposed standard. Apparently with some effect. No final standard was announced by presstime, but OSHA's top stand ards officials were talking of a com promise the industry could live with. The issue in the VC standard is one that's been fought over before: Should the TLV for a carcinogen, proved or suspect, be set at zero, or is there an acceptable maximum dose, a threshold limit value, below which no adverse reactions can be expddted? Before the cancer scare, the TLV for VC was set at 500 parts per mil lion (ppm), though as early as 1970 European researchers were report ing some disquieting data about the effects of that concentration on lab oratory animals. Dr. P. L. Viola, of the Regina Elena Institute for Cancer Research, Rome, reported rats exposed to vinyl chloride at 30,000 ppm developed cancers of the skin, lungs, and bones. Later, tests by Dr. Cesare Maltoni, of the Institute of Oncology (the study of tumors), Bologna, Italy, had pro duced tumors of the kidney and liver at concentrations of 500 and 250 ppm. The MCA knew of the work of Drs. Viola and Maltoni. MCA's Chemical Safety Data Sheet on VC referred to the Italian carcinogeni city studies in its 1972 edition. Meanwhile, MCA had arranged for 17 U.S. companies to sponsor re search and animal studies based on the findings of Maltoni and Viola. Zero exposure In the furor that followed the VC disclosures, OSHA felt pressure, notably from the United Rubber Workers, Oil Chemical and Atomic Workers Union, and the AFL/CIO to issue a temporary emergency standard on VC. On April 5, OSHA issued an emergency standard that limited ex posure to VC to 50 ppm and that established monitoring and record keeping requirements. The OSH Act limits the life of temporary emergency standards to 6 months. This one, then expires on October 5. When the emergency standard was promulgated, the only generally known experiments on the carcino genicity of VC were those of Dr. Maltoni and Dr. Viola. Neither had observed cancers in laboratory an imals exposed to 50 ppm. But shortly after announcement of the 50-ppm emergency standard, pre liminary test results became avail able from one of the research proj ects MCA had sponsored as a result of the Italian studies. Industrial BioTest Laboratories of Northbrook, III., the MCA contractor on the proj ect, revealed that mice exposed to 50 ppm for 7 hours a day, 5 days a week, for 7 months, had developed angiosarcomas. The industry knew then, that OSHA's proposed permanent stand ard, unlike the temporary emergency standard, would come in below 50 ppm, but most PVC manufacturers and users were stunned when the proposed permanent standard was issued. It called for limiting occupa tional exposure to vinyl chloride to "no detectable level," as determined by sampling and analytical methods 670LZSFZ 102 OCCUPATIONAL HAZARDS/Sepltmbtr 1974 capable of detecting VC in concen- lined up to testify that: single case of angiosarcoma," Dern ') trations of 1 ppm, with an accuracy There is no scientific evidence ehl said. of 1 ppm plus-or-minus 50 percent. establishing the need for a zero TLV. Enforcement of the standard : i t The proposal applies to any area or operation in which vinyl chloride is manufactured, reacted, released, repackaged, stored, or used. Thus, the standard would cover PVC fabricating operations if the PVC resin Enforcement of the standard would destroy the industry. Current control technology cannot achieve the concentration levels ordered by the standard. could mean a loss of production and sales of between $65 and $90 billion according to a study by A. D. Little, Inc. contracted by SPI. Not only the plastics industry, but autos, construction, communica being used is releasing detectable Questioning the need for the no- tions, toys, shoes, luggage, and many '1 amounts of VC monomer. The detectable-level standard, Dr. Carl others would be hit hard, the study's standard specifies monitoring to as U. Dernehl, associate medical direc authors concluded. sure that any exposure for any em tor for Union Carbide, offered re SPI president Ralph L. Harding ployee can be determined. It or- sults of a'survey of employees in 36 said, "The effect [of the proposed J ders feasible engineering controls to VC producing plants. permanent standard] on the nation's ' hold concentrations below the de "The tests have failed to show economy and on the social order tectable level. Self-contained respi the existence of abnormal liver func in terms of human hardship it would rators are to be used where concen tion in greater proportion than cause would be catastrophic. We ex trations can't be kept down. would be found in a control popula pect the final results from A. D. Challenge and response tion," he said. The test involved 1,402 men, all of whom had been exposed to concentrations of 50 ppm or higher, and all of whom had been Little will show a potential loss in excess of 2 million jobs. This is all the more regrettable in light of the fact that the industry is taking every Gj wUi In their response to the proposed standard, industry representatives exposed long enough to develop the disease. "Yet, there was not a possible step to reduce worker ex posure to VC monomer." o N) G September I974/OCCUPATIONAL HAZARDS 103 1 0^4 a standard of no-detectable concen tration, Walker concluded that Fire stone would have to cease VCM op erations. Studies made by engineer ing consultants indicate Firestone would have to spend from S50 to $55 million to meet the proposed OSHA standard. Even a 50 ppm level would require about $10 mil lion in engineering controls alone. Dow Chemical Co.'s testimony at hearings on the proposed standard caused a stir that may have under cut other industry testimony. Dow announced it has achieved a nodctectable level of VC monomer on some operations. On the average, the company has held levels down to 10 ppm on an 8-hour timeweighted average. This level has been achieved for most operations, though occasional malfunctions or emergencies cause briefly higher concentrations. Dow's medical records show workers exposed to VC had a ma lignancy rate no different from what would be expected in a comparable group which had never been ex posed. Records show no deaths due to angiosarcoma or any other type of liver cancer. Common ground? "There isn't any likelihood in my mind that we're going to put the in dustry out of business," remarked Daniel P. Boyd, director of OSHA's Office of Standards Development after hearing testimony on the pro` posed standard. Boyd doesn't ex pect the final standard to require industry to achieve a no-detectable level of VC monomer in the work place. "Evidence at the hearings in dicates a standard of 25 parts per million can be met across the indus try. The final standard will prob ably be somewhere between zero and 25 ppm," he said. In any event, the final standard won't be issued until OSHA has completed a study of the technolog ical and economic feasibility of vari ous levels of exposure. "Now that we have the drift of the hearings of VC, we are able to focus on the cost-benefit elements which must be part of our decision making proc ess," Boyd said. One argument the Department of Labor has apparently not bought is that compliance with the proposed standard would shut down the in "Goodyear fails to see how OSHA can scientifically conclude that exposure to VC at concentrations of 50 ppm can constitute a serious health hazard to humans / dustry. The Department of Labor's draft environmental impact state ment on the standard acknowledges that some marginal firms might be hurt, but adds that demand for PVC is so strong, it would probably re main relatively unresponsive to price increases made necessary by the cost of compliance with the standard. In any case the standard is being reconsidered, and, as far as the De partment of Labor is concerned, the zero concentration requirement seems to be out of the running. Most insiders think a limit of 10 ppm, however, is a distinct possi bility for the permanent standard. Labor views "It will be a tragedy if OSHA adopts a common denominator standard that everybody cqn meet so that those plants that can go further are under no incentive to do anything more. For those plants which cannot meet a no-detectablelevel standard, the variance pro cedures of the OSH Act should be utilized," said Anthony Mazzocchi, citizenship and legislative director of the Oil, Chemical, and Atomic Workers Union. Mazzocchi, like many other union officials in the petrochemical and plastics industries, believes industry's claims that the proposed standard will bankrupt them requires much closer scrutiny than it is getting. He pointed to the Dow Chemicql Co. testimony that some plants had achieved the zero TLV in monomer operations. "It is our hope that the proposed permanent standard would force the industry into a proper pre ventive maintenance program which will reduce exposure to VC to the nondetectable level," he said. Peter Bommarito, president of the United Rubber Workers, maintained the industry threats were nothing but blackmail. "This country survived for nearly 200 years without poly vinyl chloride and we can survive in the future without it," Bommarito told the press. With labor leaders playing the role of immovable object, it's clear that any proposal to back away from the no-detectable-level standard will be in for trouble. And the trouble will come not only from the leader ship, but from the rank-and-file membership as well. Angelo Cefalo, special assistant to the president of the International Association of Machinists and Aero space Workers, pointed to growing fears of his union's members who work with PVC. Cefalo said one member told him that he was be ginning to feel that breathing in VC had caused something to grow in his body that eventually would make him die of cancer. Whoever sets the final standard, then, is going to have to reckon not only with technological and eco nomic feasibility, but with a very normal ailment that many people, including much of the industrial workforce, suffers. It's called carcinophobia and it means a fear of cancer. "ft will be a tragedy if OSHA adopts a common denominator standard because those plants that can go further will have no incentive to do so.'" (JO NJ o, September 1974/OCCUPATIONAl HAZARDS 10S Rather than the controversial pro posed standard which lumps to gether both producers and users, Anton Vittone, president of B. F. Goodrich Chemical, speaking for SPI, asked for separate standards for PVC resin producers and VC synthesizers. The standard for resin producers should require: Effective October 5, 1974, a ceiling of 40 ppm with a maximum daily time-weighted average (expos ure averaged out for an 8-hour workday) of 25 ppm. Levels above 40 ppm would require use of prac tical and effective respiratory pro tection. Effective October 5, 1975, a ceiling of 25 ppm with no timeweighted average. Levels above 25 ppm would require use of practical and effective respiratory protection. For plants that synthesize vinyl chloride monomer, Vittone's sug gested standard would require: Effective October 5, 1974, a ceiling of 25 ppm and a maximum time-weighted average of 10 ppm. Levels above 25 ppm would require the use of practical and effective respiratory protection. Effective October 5, 1975, a ceiling of 10 ppm and a maximum time-weighted average of 5 ppm. Levels above 10 ppm would require the use of practical and effective respiratory protection. Vittone noted, "It is the position of industry that it will commit itself to lowering exposure of its workers by a combination of lower levels of vinyl chloride in the work atmos phere and work practices. [This] proposal makes projections for im provement which are not in hand but depend on new developments and additions to facilities." " The SPI proposal, according to Vittone, would require substantial outlays and could take more time than estimated. The standard should, Vittone maintains, permit companies to apply for variances. Vittone also maintains that the no-detectable-level standard being considered by OSHA would require full-time use of self-contained breathing apparatus during the workday for many employees. "This would impose a severe and unneces sary physical burden on workers and create potential health and safe *. v:< President,^ f United Rubber.Workers is ty problems as well," he said. William Miller, manager of cor porate safety and workmen's com pensation, Goodyear Tire and Rub ber Co., recommended not two but three standards, one each for the producers of VC monomer, the pro ducers of PVC resin, and the fabri cators and processors of PVC resins. "Goodyear fails to sec how OSHA can scientifically conclude that ex posure to VC at concentrations of 50 ppm can constitute a serious health hazard to humans," Miller told OSHA. What's possible? J6hn L. Nelson, vice president of manufacturing for B. F. Goodrich Chemical Co., offered evidence on the level of contamination his firm has been able to meet. "Hundreds of readings per day taken at several plants show considerable progress in reducing levels of exposure," he said. "The average reading was re duced from about 35 to 40 ppm early this year, to about 12 to 14 ppm at present. Readings range 104 OCCUPATIONAL HAZARDS/S.plember 1974 from 1 to 2 ppm as a general level with occasional excursions over 50 ppm. A summary of time-weighted average exposures by job classifica tion showed considerable variation in time-weighted measurements, ranging from below 5 ppm to 31 ppm on polymerizer charging opera tions." Nelson also noted that re duction of leaks had done the most for reducing general levels of VC in Goodrich Chemical plants. Firestone Plastics Co., about the only major producer to disagree with the SPI proposal of a step-by-step reduction in the TLV, called for a standard that would limit exposure to 40 ppm with a time-weighted av erage of 25 ppm. T. C. Walker, president of Fire stone Plastics, said, "Clearly, the human deaths caused by admittedly high levels of VCM exposure not now permitted in Firestone's plants or industry generally, suggest Wr nothing with respect to the effects Ui on humans of the low levels of U\ VCM presently permitted in Fire N stone's plants and industry gener -si ally." If compelled to comply with O HILL AND KNOWLTON, Inc. Mastics magazine editors tell of PVC decision coming from OSHA By Dave Kaiser FORT LAUDERDALE, Fla. Sept 5 is the deadline for a deci sion from the Occupational Safety and Health Administration (OSHA) on the dangers involved in the production of polyvinyl chloride resin and the possible formation of industry standards. SPW/A Exclusive The controversy arose on April 15 when the results of animal exposure studies were submitted to OSHA by Industrial Bio-Test Laboratories, Northbrook, 111. The tests indicated that vapor released in the manufacture of PVC resin could cause cancer. Since that time numerous articles have ap peared in the consumer press on the subject. SPW/A contacted the leading t authorities within the plastics ' industry in an effort to find out actly what effects might result .he pool industry. Included in our exclusive interviews were manufacturers of PVC resin, the Society of the Plastics Industry, and editors of trade publications within the plastics industry. Pub lications polled in our survey in cluded: Modern Plastics, Plastics Design and Processing, Plastics Engineering, Plastics Machinery and Equipment, Plastics Tech nology, Plastics World, and Plas tics World News. A three-week hearing on the topic of the vinyl chloride mono mer and proposed standards was held starting June 25 in Washing ton, D.C., and closed in mid-July. Results have to be presented in the Federal Register no later than Sept. 5. The hearing was called by OSHA and attended by repre sentatives from involved groups, including trade unions and the Society of the Plastics Industry. OSHA, in calling the hearings, contended that its own temporary emergency standard, adopted on April 5,1974, should be replaced with a more stringent permanent standard. _________ The Society of the Plastics Industry, which presented key witnesses during the hearings for the opposition, appealed to OSHA on the basis that OSHA s proposed standards were unreason able and could put the industry out of business. "The OSHA standard proposed in April called for no more than 50 parts per million of vinyl chlo ride monomer," expIainedThomas McGrath, general manager of the Society, in an exclusive inter view with SPW/A. "Wegave OSHA conclusive evidence to show that there should be no concern at 200 parts per million. "This was demonstrated through checks on workers * throughout the years." he said. "We have to take the situation in perspective. There have been 13 deaths in over 40 years. "Based on this record, if you had an impaiijal toxicologist or health officigUisten to the tes timony he would come away unconcerned." 1 Delving directly into the effect of such standards on the pool industry, McGrath said that "there could be devastating ef fects if stringent standards were set because PVC production would come to a halt." He indicated that the April restrictions have already caused some problems and slowed production. As far as the standards them selves are concerned, McGrath said pool industry manufacturers would be involved only if they take PVC resin and extrude their own products. "In this case they would be involved from the standpoint that 'a small amount of vinyl chloride monomer is emitted," he explained "We demonstrated to OSHA that in such cases the level is inconsequential and only amounts to one part per million." The susceptibility of the pool industry was further clarified by Bcrnic M illcr, editor of Plastics World in Boston. According to Miller, the hearings will mainly affect resin manufacturers who work with vinyl chloride vapors. "At this level they are usually working with 100 parts per mil lion of the monomer said to cause cancer,"explained Miller. "At each successive stage of the pro cess the amount of monomer is reduced considerably and it is practically non-existent when it gets to the consumer." According to Miller, the mono mer is decreased to one part per million when poolmen become in volved with producing products from the material. It is even less when the material-reaches the pool. "The key question here is with the vapor," said Miller. "If vapor is not involved and it is not in haled, then there is no problem." A.A. Schoengood, editor of Plastics Engineering, the official publication of the Society of Plastics Engineers went one step further. He said to SPW/A in a letter: There is no alleged connection whatsoever between users of PVC and their contraction of liver cancer. There appears, however, to be a connection between vinyl chlo ride monomer and liver cancer, as well as other diseases to unpro tected workers engaged in the manufacture of vinyl chloride and in its polymerization to polyvinyl chloride. There is at least one case of a worker handling polyvinylchloride in the manufacture of insulation who contracted liver cancer. 11 must be remembered that in this case, the PVC resin was exposed to high temperatures and there fore capable of liberating en trapped vinyl chloride monomer. SV/iim.liNG POOL WEEKLY & SWIMMING POOL AGE FT. LAUDERDALE, FLA. 3 Tl. A MONTH 3,500 AUG 5 1974 235^7023 HILL and KNOWLTON, Inc. perspective By Lloyd Stouffer Executive Editor/New York The fate of PVC hangs in balance, but there's hope FIGHTING HARD against a proposed safety standard which, they said, could result in a complete shutdown of the polyvinyl chloride industry, with a loss of 2.2 million jobs and S65 billion in . sales and production, members of the Society of the Plastics Industry apparently scored some points in week-long hearings before the Occu pational Safety & Health Administra tion late in June. Industry's dire prediction was based on OSliA's proposed imposition of a "no detectable level" of vinyl chloride emission in the manufacture and fabrication of PVC. Arguing that such a zero level was literally impossible, the SPI spokesmen suggested instead a stepped reduction from the presently permitted 30 parts per million to 10 ppm for VC monomer plants and 25 ppm for PVC resin plants. Both levels, they said, could be attained by October 5, 1975, and with the use of effective respiratory protection should be sufficient to protect workers. The controversy, of course, stems from the recent finding that 19 cases of a fatal liver cancer have occurred in workers exposed to vinyl chloride fumes over a period of years. While these cases have primarily occurred in plants converting VC monomer to PVC, the scare has recently extended to plants dealing only with PVC. on the theory that the heat of sealing or molding the plastic might release (he suspect monomer gas. The hearings will continue, and no decision is likely before September or October. But industry representatives came away from the first session with the feeling that OSHA. despite rigorous cross examination, W3S trying to be open and fair, and that the Administration probably recognized that a zero level was untenable. One hope is that the fabricating companies, of which there are hundreds, will be given a workable standard, apart from the processors An entirely different problem is the possible ingestion of VC monomer through migration into foods and drugs packaged in PVC. As reported here earlier, the Food & Drug Admin istration -- having already banned PVC bottles for liquor -- is giving intensive study to food applications, but it probably will take no action pending the completion of the OSHA hearings. An FDA source reports that migration levels into foods may be lower than previously suspected. Industry data suggests that migration from tigid PVC runs abour 20 parts per billion, which is lower than the limit FDA has been considering. The F.nvironmental Protection Agency also will come into this complicated picture, with its responsi bility to protect the atmosphere outside of plants. However, it is reported that an PA sampling, conducted at varying distances from a dozen vinyl chloride and polyvinyl chloride plants around the country, lurried up safe atmospheric levels of less than one part per million in 957o of the readings. No lost year for PEF CONTINUED SUPPORT for the Packaging Education Foundation has been pledged by the Packaging Machinery Manufacturers Institute, despite the fact that PMMl's money making packaging show after this year will go on an every-other-year schedule. PMMl's executive director, Claude Breeden, told the Foundation's recent annual meeting that the SI-perregistration contribution will continue to be effective with this year's October 7- 10 show in Chicago, and that when the next show is held in the full of 1976 it is planned to increase the contribution to S2 per paid U.S. visitor, up tn a maximum of S40.000. Thus. PMM1 will make up for the -lost" year. Thanks in part to PMMl's support. PEF's annual report shows that contributions in the last year mounted to a record of over Si50,000. Grants have gone to 10 colleges who have or are establishing degree-granting packaging courses. Requests from three additional schools are under consideration. Selection of a Packaging Man of the Year and live nominees for Packaging's Hall of Fame will be revealed at the annual awards dinner at McCormick PACKAGING DIGEST CLEVELAND, OHIO MONTHLY - CIRC. H. AVAIL. AUS 1974 Place on October 9. A decision was made by the board to streamline the ceremonies. There will be only one featured speaker, and adjournment is planned by 9: IS p.m. It was also decided that there will be a PEF Awards Dinner tn New York in the fall of 1975. In the absence of a packaging show next year, it is expected that this will be coordinated with a National Packaging Week in which the American Management Association, the Packaging Institute and the Society of Packaging and Handling Engineers will participate. \rZ0LZ%Z HILL and KNOWLTON, Inc. INSULATION-CIRCUITS .libertyville, ILL. MONTHLY 27.000 AUG 1974 Government Regulations Threaten Vinyl Chloride Industry; SPE Meets to Discuss Problems A minimum of 1.6 million jobs would be lost if the pro ducers of vinyl chloride, an industrial chemical, and polyvinyl chloride (PVC), a widely used plastic resin, were forced to shut down because of a pending OSHA regula tion. That's the latest from the Society of_The Plastics . Industry whose economic consulting firm recently un veiled the aforementioned staggering figures. The reason for this crisis is that the technology just does not exist to achieve a "no detectable level" of exposure as proposed by OSHA. Vinyl chloride monomer (VCM) has been linked in recent months with higher than normal incidence of angiosarcoma of the liver, a rare type of cancer, among previously highly exposed workers. Vinyl chloride is used primarily to produce PVC resin, which in turn is fabricated into a variety of products including telephone equipment, insulated wire, and various electrical components. With this impending OSHA crisis in mind, the Society of Plastics Engineers plans to sponsor a conference which will look at the problem from a processing perspective. The Regional Technical Conference (RETEC) scheduled for late October is going to be a special educational sym posium which will present the latest information on the means of dealing with the VCM problem. The proposed eight-part program will include an historical summary; an update on the current situation; a summary of OSHA, FDA, and EPA regulations; discussion of what the regulations mean to producers, processors, and users of vinyl plastics products; analytical methods of detection and monitor ing; protective equipment; processing techniques to minimize VCM contact; and an analysis of future needs. Further details of the symposium are available from Kenneth A. Galione, SPE, 656 W. Putnam Ave., Greenwich, Conn. 06830. 23527025 HILL AND KNOWLTON, Inc. M-G FINANCIAL WEEKLY RICHMOND, VA. w. 8,132 SEP 3 0 1974 ^ PVC Ruling: Real Shuke-Out Seen in Industry NEW YORK, (Reuters) -- The Department of Labor early next month is expected to hand down a work safety standard that could ultimately result in the loss of as many as 2.5 million jobs and $1 billion in annual revenues to the plastic and chemical industry in the uumcu jtaico. And according to the Society of Plastics, theordersetting the maximum TifitI'llUCihip level nf vinyl rhlnrirte In which workers can be exposed at best will cause temporary plant shutdowns and could halt production of polyvinyl chloride. in any event, the decision is expected to be a controversial one, since thequestion has been raised over a cancer threat in polyvinyl chloride. Presently there are about 22 com panies, operating 50 plants in the United States, that produce the gaseous vinyl chloride, which since its commercializa tion in 19.40, has been a key element in making polyvinyl chloride (PVC), a resin used in thousands of products. The largest producer of PVC is B. F. Goodrich Co., tut other companies -- Firestone Tire and Rubber Co., Tenneco, Inc.; Goodyear Tire and Ruber Co.; and Dow Chemical Co. -- could be seriously affected by the ruling which will be set by the Occupational Safety and Health Ad ministration (OSHA). Until the definitive standard is set by OSHA, the industry is operating under an average interim level of 50 parts per million allowable in the air. But OSH A last yenr tried tocomedown hard on the industry, according to the Society of Plastics, with a "completely unrealistic and unattainable" proposal, w'hich amounted to "zero-parts-permillion." The industry countered with a range of 25 to 40 parts per million, and warned of widespread plant closings as a result of costs involved in meeting such s*andards. With some 5.0. million pounds of PVC produced each year in the United States -- about IS to 20 percent of total p`?s'ir output in tne country -- the scope of the ruling is ominously clear, the industry said. Those in the industry seem less than optimistic as to the outcome of the con troversy and the alternatives to what they would consider "an unrealistic" OSHA standard. PAPER FILM AND FOIL CONVERTER PARK RIDGE, ILL. MONTHLY 14,000 SEP 1974 I Controls On Vinyl Choride are being opposed by | manufacturers who use it on the grounds that the proI posed reduction of exposure to a "no detectable" lev el or ranges of %-I% ppm, would drive many facets of tire plastics industry out of business, resulting in die ! loss of thousands of jobs. Hearings on the cancerlinked chemical began in the last week of June. It is hoped that consideration will be given to industry's letters to the Labor Department, most of which urged ! delay in the imposition of harsh restrictions. This dej lay would allow scientists more time to discover suit able substitutes and give businesses tune to phase m new controls. According to Society of Plastics Indus try, I.(j MM jobs and at least >65 billion in sales and production could be lost. To date, vinyl chloride has been correlated to 19 cases of rare liver cancer among workers handling it hi the U.S. and odier countries, 16 of wliich ended in fatalities. OSHA recently issued guidelines for inspections of PVC manufacturers. N Co CM N> "-4 O PO HILL AND KNOWLTON, Inc. D. 448,314 SUN. 474,253 ^SEP 231974. Vinyl chloride issue Health ruling seen as threat to plastics f NEW YORK (Reuters) -- The Department of Labor next month is expected to hand down a work safety standard that ultimately could result in the loss of as many as 2.5 mil i Goodyear Tire-Rubber Co. and Dow'fchemical Co. -- could be seriously affected by the rul ing which will be set by the Occupational Safety and Health Administration (OSHA). . lion jobs and $1 billion in an nual revenues to the plastic and chemical industry in Uie 'United States. y Until the definitive standard is set by OSHA, the industry is operating under an average in terim level of 50 pans per mil 1 According to the Society of lion allowable in the air. Plastics Industry, the'Tfider But OSHA last year tried to sett!ng~**Ifie"'"maximum per ' come down hard on the in missible level of vinyl-chloride- dustry according lo the ; to which workers can be ex Society of Plastics Industry, posed at best will cause tern- with a "completely unrealistic ' porary plant shutdowns and and unattainable" proposal, could halt production of polyvi- which amounted to `'zero- 1 nyl chloride. parts-per-million." In any event, the decision is expected to be a controversial one, since question has been raised over a cancer threat in polyvinyl chloride. PRESENTLY there are ' THE INDUSTRY countered with a range of 25 to 40 parts per million, although warning of widespread plant'closings as a result of costs involved in .meeting such standards. about 22 companies operating 50 plants in the United Staes that produce the gaseous vinyl' chloride. Since its com- With 5 billion pounds of PVC produced each year in the United States -- about 18-to-20 per cent of total plastic output ;-mercialism in 1930, the cherni- , cal has been a key element in ' making polyvinyl chloride ! (PVC), a resin used in thou sands of products. j The largest producer of PVC .j i is B. F. Goodrich Co., but"; | other companies -- Firestone I Tire and Rubber Co., Tenneco, in the country -- the scope of the ruling is.ominously clear, the industry said. ' Those in the industry seem less than optimistic as to the outcome of the controversy and the alternatives to what they would consider "an \uty realistic"|OSHA standard. In a recent interview, Uni royal president David Beretta said the decision, if lower than the current interim standard, will inevitably cause "a real s h a k e-out, especially with marginal companies," in the field. Moreover, according to the Society of Plastics Industry, there is no substance that could effectively replace PVC. \ JC 23527027 Top of the news Showdown on vinyl plant rule presages shutdowns Newly issued advisory reports hint at compromise in fight to curb vinyl chloride fumes, but battle may continue in court. Industry insists OSHA's proposal would be ruinous The bitter controversy over worker ex fects of the proposed standard. This re els: and there are no technology transfer posure to vinyl chloride gas may climax port does not discount the possibility of a opportunities to permit development of on Oct. 5 when the U.S. Dept, of Labor is level higher than the 1 ppm. implicit in design for no detectable levels in new expected to set permanent standards for "no detectable level." But it concludes plants. Moreover. Snell says that because the 17 U.S. plants that produce the mono that anything higher is a risk to workers. PVC manufacture is a batch operation, mer, the 37 that polymerize it to make "Despite significant cost increases that emissions couldn't be completely elimi polyvinyl chloride resins, and the thou may occur, the high demand for PVC nated. sands of plants that mold, extrude and resins is likely to continue," the report Something to Live With: Those conclu otherwise shape those PVC resins into states. sions would seem to support a compro plastic pipe, vinyl flooring, house siding The Environmental Protection mise regulation that the vinyl makers and phonograph records. Agency's notification that within nine could live with-perhaps not too happily. The controversy has raged since last months it will-set VCM plant emission But probably because of the imminence January, when medical data apparently standards that could add 4% to the cost of of the Labor Dept.'s new regulations, in established a link between workers' expo PVC. This would seem to preclude the dustry representatives were reluctant to sure to vinyl chloride monomer (VCM) engineering possibility of venting all the discuss Snell's final report, noting that and angiosarcoma, a rare liver cancer. in-plant VCM leaks to the atmosphere. they haven't had time to examine it. And last week the scores of chemical Double Negative: OSHA's proposed Nor did they have much time to react and plastic companies that have a stake goal of operating monomer and polymer to Snell's preliminary report, which con in this $3-billion/year business were plants at no detectable level of vinyl chlo tained pretty much the same data used in given some inkling of whether the gov ride exposure is "not feasible," according the final report but did not contain any ernment will stay with the 50-ppm. emer to Snell. Moreover, the firm's analysis in conclusions. OSHA issued the prelimi gency standard, adopt the proposed "no dicates that the U.S. industry would com nary report Aug. 28. called for response detectable level" by Sept. 6. Never limit or move to theless, industry some compromise osition. Whatever OSHA's vinyl standards impact: higher costs, fewer plants leaders submitted comments, and these standards are set could determine the profitability of pro ducing and process ing vinyl compounds Proposed VCM exposure standard* (ppm.) Time- weighted Maximum average Increase in average unit costs (cents/lb.) Loss of Direct productivitv Total1 Time needed to comply (months) Proportion of industry endangered3 were generally nega tive and caustic. One point of con tention in the prelim inary report was the in the U.S. for many years and are likely to be attacked in the federal courts, either by the companies or the labor unions in Monomer plants 50 15 25 15 10 2-5 "No detectable amount" 0.04 0.09 0.17 - 0.03 0.03 0.15 - 0.07 10% 0.12 40% 0.32 40% 0 24 36 Not feasible 0% 0% 0% 100% use of Firestone data for bringing a PVC plant into com pliance with a no-de tectable-level stan dard. Firestone, Snell volved. Polymer plants reported, was the Conflict: As to exactly what stan dards will be promul gated next week, various indications-- 50 25-40 15-25 15-25 10-15 "No detectable amount" 0.19 0.3G 0.90 4.013 0.35 0.49 0.70 3.073 0.54 20% 0.85 35% 1.60 t 50% 7.08 75%3 0-6 30 30 30-483 Negligible 4% 26% 100% only company that said it could me"' such a standard. ` Firestone replied that studies of its poly sometimes contra dictory-can be found in three newly issued reports: Vinyl chloride monomer (VCM) content, expressed as parts per million, in the air to which employees are exposed. `With estimated range of variance for individual plants, based on partial statistical analysissof data. Percentage of capacity that management would seriously consider shutting down. 3 Based on Firestone's estimates; actual compliance is no t considered feasible. Source: Foster D, Snell, Inc. merization plants in Pottstown, Pa., and Perryvillc, Md., ac tually indicated a Foster D. Snell's contrary judgment. final report to the Occupational Safety pletely collapse under that restrictive Declares a Firestone executive: "Inde and Health Administration on the eco standard, with all producers indicating pendent of economic considerations and nomic impact of the agency's proposed they would have to close their plants. despite enormous equipment, engineer VCM exposure standards. A principal The study offers several reasons for ing and process changes at both facilities, '>nclusion: "achieving no detectable lev- reaching these conclusions: technology to costing in excess of $50 million, it is not ... is judged not feasible, both in eliminate VCM leaks and fugitive losses possible to achieve the drastic exposure PVC and VCM sectors." is not available; existing plants have not levels required by the proposed standard, The Occupational Health and Safety been designed for total VCM contain based on engineering controls and tech Administration's final environmental im ment; there has been no operating expe nology that now exist." pact statement on the physiological ef rience in maintaining very low VCM lev Firestone, No. 5 in PVC output, has September 25. 1974 CHEMICAL WEEK 15 23527C28 1- rr> h t i op ot the news some differences with the rest of industry PVC plants. Examples: major ventilation loadings. The batch operation of PVC on the exposure level standards that system improvement, 18 months; replace plants involves continuous emptying and would be manageable. Industry generally ment or reconditioning of reactors, 18-24 recharging of autoclaves and frequent in supports the Society of the Plastics Indus months. spections and cleaning out of these reac try's proposal: that the present temporary Overly Optimistic? Some companies tors. Chance of VCM exposure in these , emergency standard of 50 ppm. be low contend that these estimates are overly plants is high even in the packing areas. ered in several stages to 25 ppm. for PVC optimistic in light of today's materials While separate standards would seem r plants by Oct. 5, 1975, with further impo shortages and delivery delays. Observes a reasonable to manufacturers, the prac- ^ sition of a time-weighted average limit of Firestone executive: "Individual com ticality of this approach is limited. It's un 10 ppm. Standards for VCM production, pany confidence in being able to attain likely that labor groups, strongly in favor says SP1, could be more restrictive--10 compliance with even the SPI recommen of the no-detectable level and opposed to ppm. by October 1975, and a time- dations has been eroding as lead times the concept of a threshold level for any weighted average (twa.) of 5 ppm. for obtaining equipment expand, as capi carcinogen, could accept different expo T.C. Walker, president of Firestone tal costs rise rapidly, and as the prospect sures for workers in various plants. Plastics, says that a "safe and medically for financing these projects becomes dim Outside Plant: If the vinyl producers sound--as well as technologically and ec mer." solve their in-plant exposure problems, onomically feasible--standard" is 40 they will still have to deal with monomer i. ppm. maximum exposure and 25-ppm. gas escaping from the plant. EPA Admin- ' twa. istrator Russell Train said last week that i_ Snell's analysis offers data on several his agency will set standards for vinyl alternatives, maintaining the SP1 distinc chloride plant emissions by next June. tion between VCM and PVC plants And without firm data on health effects (table, p. 15). Cost data indicate that of VCM at various levels in the atmo VCM makers can manage with a 10-ppm. sphere, Train is proposing that the stan limit and a 2-5-ppm. twa. without closing dards be based on "best available tech any plants. Meeting such a standard nology." 1 would increase their average unit manu EPA's survey of air and water around facturing cost by an estimated 0.32C/lb., 10 PVC plants indicated VCM air levels | which is about 4-5% of the present range of 1 to 2 ppm. Through those emissions, ' (7-10c/lb.) of list prices for various the agency estimates, PVC plants are los grades of VCM. ing monomer at the rate of 200 million For polymer producers, however, some Ibs./year. plant closings may be necessary when the With controls, EPA says emissions present emergency standard is tightened. from PVC and VCM plants could be cut According to the Snell study, at an expo 75% and 90%, respectively. Capital out sure limit of 25-40 ppm. and a 15-25 twa., lays for these controls are put at S80 mil 4% of the existing PVC plants may have lion for the industry as a whole, with op- '' to.be shut down. This might not be too erating expenses estimated at some $40 : disastrous, considering that 58% of the in million/ycar. dustry's plants are more than 10 years John Nelson, vice-president for manu old, and only 8% are less than five years VINYL SIDING costs will rise as makers facturing at B.F. Goodrich Chemical, ap- j old. meet new in-plant and emission standards. proves of Train's analysis, especially the But for an exposure limit of 15-25 statement that there is "no imminent haz- \ ppm. and a twa. of 10-15 ppm., 26% of Industry criticism has also centered on ard" from VCM exposure in the atmo- \ the PVC plants could face the axe. Snell's Snell's projection of cost data to meet sphere. survey indicates that with this standard, projected standards. The figures are said But if OSHA's no-detectable-level pro- ( unit costs of PVC would increase to be heavily weighted in favor of newer posal becomes the law, the vinyl ..loride 1.6e/lb., or about 4-8%, at those plants plants and suspension homopolymeriza industry might have to re-evaluate its do that can take the needed engineering tion units in warmer climates. Such plants mestic production. Although industry changes. At some older, smaller batch op could probably be most readily adapted spokesmen have warned of extensive erations, the companies say it would be to meet a more stringent exposure stan shutdowns if such a standard is adopted, impossible to. reach such a low exposure dard. OSHA's environmental impact statement i level without building a new plant. At Separate Standards: The proposed no- merely suggests that the costs will be high certain plants, Snell believes, the addi detectablc-level standards would be ap but will be passed on to the consumer, tional cost might be 50% more or less plicable to VCM and PVC plants as well and that the time needed to reach the than the 1.6C/lb. average. as fabricators. But the Snell study follows standards would be long. Schedule Makers: Snell estimates it the SPI proposal of separate standards But this report also suggests that "in' will take VCM plants up to three years to for VCM and PVC plants. the long run U.S. companies might find it achieve what it considers the lowest Reasoning is based on relative ease of profitable to build plants abroad." achievable level. For PVC plants, the es controlling emissions at VCM plants, Clearly, this will depend not only on tra timate is two and a half years. which are generally closed systems, oper ditional market and raw-material logis This is based on engineering estimates ating in the open air. Leaks may occur tics but also on whatever in-plant and of installation time for various kinds of around pump packings, during samplings emission standards are put in force in the apparatus to reduce exposure levels at or maintenance operation, or at tank-car U.S. and other nations. 23527029 16 CHEMICAL WEEK September 25, 1974 r