Document KqnEyOkoVao6OeVVN4aMbneX

.cVj. *_^ y/. , ^ K *S T *">, T*\ ? J tS L I)i;?MiOMi.\T O) IJLM/ni. ZVVCATiOW AXI> . i". \;.tm.kvh.j. Mir. tt>r. i>.m .vi. u*\ i koj. TO : Assistant Secrt iz\r/ of Lubor ijaik- KPA\ l j 13/4 Otcupationai nrid Health Administration Department of J^huf JTtGM Director* National Institute for Occupational Safety and Health suiter: P.ecojsaeoded Occupational Health Standard for the Hanutacturc of Synthetic Poly:;,or from Vinyl Chloride On January 22 > 1974* representatives from the Si Y* Goodrich Chemical Company informed KIOSK that the deaths of several employees of their louisviile, Kentucky, plant eight have he.c-.n related to occupational exposures* An iar-rdiete industrial hygiene walk-through survey or the facility tos conducted by K103K and resulted in developing and transreit tiug to affected cer-pani.es recommendations, for precautioncry ronitorirsj and control procedures for rciymerisation processes involving vinyl chloride. On February 1, 1574, KVOSr2/CEC conducted a briefing for other Federal agencies with health research responsibilities at which it was disclosed that four employees of the plant in question had died of angiosarcoma of the liver, because of the cxtresrely low incidence of this disease, estimated to be en the order of 20 to 30 deaths per year in the boatc-z i:atcs, the Liscc :>.n a iVc-vear period in one plant vss considered of`great importance. It \*na .concluded at the briefing that a rev occupation*.! cancer had bean discovered: enuiosarcoma cf the liver. It vas further concluded that this disease vss associated with the manufacture of polyvinyl chloride end that vinyl chloride was the prime etiological candidate in producing the disease. KIOSK, with the assistance cf expert consultants Sros* both industry and organized labor, began development of a recomcndcd occupational health standard. These and other activities wore discussed in move detail at the 031IA Informal Fact-Finding Hearing on Possible Kacards of Vinyl Chloride Manufacture sad Use on February IS, 1974, It was also during this Hearing that Professor Cesare Maltcni or Dologna, Italy, presented the preliminary results of his research which showed Induction of nnsiosarcom of the liver and ocher organs, as veil as .the production of other cancers in rats exposed to vinyl chloride-.* The results of chess studies identify vinyl chloride as a carcinogen and further confirm its role in inducing the cancers observed in the . V* Goodrich workers- <* VVC 000006448 ,;c 2 - Ausiufant Secretary of L,jor, OSHA Since the QSUA Hearing, NIOSH has learned of nt least five additional cjjjcj; of ;!n;;ioaareoT.ia of the liver. Two of theue cases were diepnonud in the current working population cl the samu Louisville facility, while the other three involved 'jeeoased workers, one each from the Louisville facility, Union Carbide's South Charlestown plant, end Goodyear's lUagara plant. Although vinyl chloride rjust bo considered as a carcinogenic agent, the irincdiate proWen appeared to be concentrated in polymerization facilities. Consequently, the attached 'JIQSJJ recommended standard only applies to such operations. This is not to say, however, that appropriate standards should not be developed for other exposures to the basic chemical. "lCS;i is implementing further evaluation of the data, coupled vith field observations, to determine exposure potentials in pre~<and post-polyncrizsticm operations. You will be informed as further data and plans arc developed. As previously indicated. J:10SH considers this to be a most serious problem and strongly urges that expedited -rulemaking be implemented by OS11A to insure that the health of exposed workers is promptly and adequately safeguarded. Ke feel that, except where employers experience problems in obtaining air supplied respirators or environmental raonitorinr; equipment,' the attached rc'ccnxreridatiGns can be implemented a? soon os a standard is promulgated. The medical surveillance requirements 'which -will be supplied in one to two weeks could also be implemented immediately with the possibility that some employers would need a short period of titre for their medical stall or consultants to make arrangenent.s for any special laboratory tests. You should be aware that the consultants fron industry who worked with us proposed that the rccorxrcr.ued standard contain the concept of an allowable "working level" for- vinyl chloride gas in the atmosphere* which they identified as a time weighted average of 50 ppm. They, recommended that where workers were exposed to concentrations in excess of this level they should wear aiz--supplied respirators. TIUs concept cf an allowable ''working level" might seen justifiable in that Vrofessor Maltcmi found no liver fcutaors at 50 ppm, but there is the possibility that turners night have been produced if a larger cumber of animals had been exposed nr. that concentration. Based on theoretical considerations, there is probably no threshold for carcinogenesis although it is possible that vith very lev Concentrations the latency period might be extended beyond the life expectancy. view of these considerations and our inability to describe a safe exposure level as required in section 20(a)(3) of the Occupational Safety and Health Act, ve rejected the concept of s threshold limit for vinyl chloride gas in the atmosphere. *. VVC 000006449 * Rage 3 - Assistant Secretary of Labor, OSJl/i Consequently, our reccnrsendaticns as contained in the attached document arc such that vhcre any employee is exposed to measurable concentrations c vir.yl chiori: itertjinod by the r-ecrr.randcd campling and analytical <" "Hi"* ^ A C ' 'l' " year an air supplied respirator * Tb :cnr.crjc< >n i: based on cone pteliiunarv information that the standard chemical cartridge respirators arc? inefficient in protecting a&cinst vinyl chloride. KIG5U is inpltravnti-np, a study to evaluate the degree cz protection afforded by different, types ol respirators using vinyl chloride as the test gas. As information becomes available, it v-i.ll be .forwarded to CSHA as reccm- jrendetiors for alternative respirator usage. The cry}.oyer is also icqMixtd to develop a Control Tien to reduce airborne concentrations ex vinyl chloride to levels not detectable by the recoupended method. As you vill note in reviewing, the recortr.atvded standard, there axe referenccs to the ``stripling and analytical cethcd recommended by the Virector,'* This method, in the fora of a compliance sampling data, sheet* vili be forvnrded r.o DS'HA vrithin n week. Va. now escintte that the level of. sensitivity of our recommenced method vill be around one part per jaitlios, specifically for vinyl chloride. The Office of Research and Standards development, vhich is directed by Mr. Vernon ,, Rose, has had lead responsibility in developing this recommended standard. As your professional staff review and evaluate our document, questions or requests for additional information should be directed to Hr. Kosc. & /- / cA A-->/---------- -Harctis fr-J# Key, K,B/ /assistant Surgeon General Attachment; t we 000006450