Document Lp3LQ7w47GXEkjgR1X2EG9xxw

c, C. Lee FROM T. S. Bialke subject FIELD POINT OR DEPT & &LDG. NO Niagara Falls___________ FIELD POINT OR DEPT. & BLDG. NO. Akron - D/QQ2Q. 5-H Industrial Hygiene Survey; August 13-16, 1984 date this letter .q=lZ=fl4- . An industrial hygiene survey of the Niagara Falls plant was conducted during the period August 13-16, 1984. All previous survey recommendations have been satisfactorily completed. Efforts to control noise levels in the Niro bagging area have been successful. Audiodosimeter readings taken on the Niro bagger show reduction from 200% to 85-87%. All plant employees who must wear respi rators are being annually fit-tested. New laboratory hoods have been installed. Few items were found that need attention. The first and second floors of Geon North are to be posted as noise hazardous, as they exceed 85 dBA. My compliments to Messrs. Lee and Reid for their interest and support of the plant's industrial hygiene program. Their interest is demonstrated by the plant's enthusiasm in attacking the Niro bagger noise problem and improving the laboratory hood ventilation. Their cooperation in making the survey run smoothly made the visit an enjoyable one. Please respond to the status of the recommendations within 120 days and upon completion of all items on the anniversary of the survey, whichever comes first. cc: C. Reid, Niagara Falls F. Hovey/D. Brooks, Shawinigan G. Lefebvre/H. Waltemate, Cleveland H. Botelho, Cleveland T. S. BialWe 25892001 BFG-495&-E 11/80 LITHO IN U.S.A. BFG45103 Niagara Falls IH Survey; Aug. 1984 J. Status of Previous Survey Recommendations: 1. All Niagara Falls employees required to wear respirators have been fit-tested with irritant smoke. 2. N-hexane is flo longer used as a catalyst; solvent monitoring not required. 3. Sampling procedure for personnel monitoring of VCM is following published requirements. 4. Personnel monitoring for vinyl acetate shows exposures to be less than 1 ppm. 5. No. 2 Niro bagger noise exposures reduced by muffling air exhaust of bag compactor and installation of noise barriers (see Discussion). 6. Maintenance shop parts cleaning tank has been provided with a fusible linked lid. 7. All portable eyewash fountains are being noted with date of last water change. All water in fountains being changed every two months. Recommendations (1984) 1. Post Geon first and second floor areas as noise hazardous; require that hearing protection be worn when working in these areas. 2. Add to goals for 1985 and upcoming years the requirement of evaluating employee exposures to three agents not previously monitored. Suggest employee exposures to isotar, TCE and parts cleaning solvent in machine shop be evaluated. Initially, obtain one sample per exposed employee. If results suggest that exposures near the TLV exist, further monitoring will be necessary. 3. Ensure that employees working on the VGA during activities requiring them to open up the system wear airline respirators. See Discussion and sample result No. 5, attachment II. Industrial Hygiene Audit Checklist: Attachment I is the completed checklist for the 1984 Niagara Falls IH survey. The checklist is a guide used during the survey to ensure that all areas of a plant's IH program are being addressed. The checklist is based on the BFG Chemical Group industrial hygiene program, standard IH-101. Z00Z68SZ The Niagara Falls IH program is in very good shape with 61 items satisfactory and only one item needing attention. You will note that items that do not apply to the Niagara Falls plant pertain to the USA OSHA law. Discussion: All previous survey recommendations have been satisfactorily addressed. The plant's respirator program has been improved and all employees who require a respirator have been properly fit-tested. Records of the fit testing are complete. Noise exposures at the Niro bagger have been substantially reduced through control of noise sources. Last year's noise dosimeter results indicated bagger exposures to be as high as 214%. This year's dosimetry results showed the bagger's exposure to be 86-87%. (See Attachment II, Samples 1 and 2). BFG45104 Niagara Falls IH Survey 2. Discussion (con't) The plant is to be congratulated on doing an excellent job of reducing noise exposure. The wearing of hearing protection by employees in noise hazardous areas is much im proved over previous years; I did not observe any employee in a posted area without hearing protection. Employees with shifts in their audiograms are being counseled and instructed in proper fitting of hearing protection. The Geon North building, first and second floor noise levels were measured in the 90-92 dBA range. These areas were not posted as noise hazardous. As indicated in the Recommendations, these areas need to be posted. Noise dosimeter monitoring on Geon N employees obtained by the plant show that employee exposures above 50% are occurring. No readings over 100% have been documented. The Niagara Falls- plant issues a year-end summary of its personnel monitoring results and monitoring goals for the next year. * To anticipate future health or regulatory concerns, a data base of current employee exposures to heretofore not monitored agents is needed. The recommendation to collect personal sampling data on previously unchecked chemicals in the workplace is directed at initiating this data base. Personnel monitoring was conducted on Geon South employees to document exposures to vinyl acetate, vinyl chloride and trichloroethylene. All results were well below published exposure limits (see results 3-4, Attachment II). A maintenance man working on the VGA system was also monitored for VCM (see result 5, Attachment II). The maintenance man did not wear a respirator. The result of 5.6 ppm suggests that there were times during his work on the VGA when levels of VCM in or around the area were much higher. Therefore, the recommendation to wear a respirator is aimed at protecting the worker against short-term high VCM exposures encountered from VCM task work. Two new fume hoods were installed in the plant laboratory. The average flow rates through the hoods were found to be 150-200 fpm. These flow rates are good, too good in fact. Research by the Brecksville environmental health lab has shown that a hood with an average of 85-100 fpm is adequate. Reducing the flow rates in both hoods to 85-100 fpm would result in conserving heat in the winter and airconditioning in the summer months. TSB 25892003 BFG45105 LOCATION CHEMICAL GROUP INDUSTRIAL HYGIENE AUDIT CHECKLIST IH-1Q1A Revised: 8/8/84 H>/L , Cfj] ft-f ftft, ft A___________ DATE %fj 3 " %// C^/ ? /V S = Satisfactory NA = Needs Attention DNA s Does Not Apply A. INDUSTRIAL HYGIENE PROGRAM ADMINISTRATION 1. Industrial Hygiene Coordinator a. Named b. Knowledgeable c. Walk-throughs S _r 2. Periodic Industrial Hygiene Program Reports a. Timely b. Content c. Year-end Summary d. Goals for Next Year 777f 3. Medical Services a. Physical Examination b. Medical Equipment Certification/ Calibration c. Training d. Illness and Complaint Investigation Jr 4. Hazard Inventory a. Complete b. Annual Review and Update 5. Chemical Hazard Review and Use a. Committee Established b. MSDS 1. Available 2. Employees Trained in Use s *O O Z68Z 6. Reply to Corporate Surveys a. Initial b. Final Report s 7. Training a. Hazard Communication b. Vinyl Chloride c. Lead d. Acrylonitrile wp6/3560q-4 bFG45106 J.7/v ft )h! ft pti A IH-101A . Revised: 8/8/8 ^ S = Satisfactory NA = Needs Attention DNA = Does Not Apply INDUSTRIAL HYGIENE PROCEDURES 1* Respiratory Procedure a. Written b. Selected per Hazard c. Training d. Fit Testing e, Medical Examination f. Cleaning g. Storage h* Inspection i- Approvals J, Usage 2. Asbestos Handling and Disposal a. Sources Identified b. Monitoring c. Medical Examination d. Demolition and Removal e. Protective Clothing g. Written 3. Industrial Hygiene Sampling j S -s j ___ (- s ^s J s a. Strategies t. 2. . 3. OSHA compliance Hazard Evaluation Special Requests b. Sample Procedures c. Analytical Procedures/Cross Check Program d. Employee Interview j: j j j j 4. Hearing Conservation and Noise Control (Use Hearing Conservation Audit Checklist") Total Satisfactory Total Needs Attention $/Y ft A C A A ^O C ^ 5. Radiation a. Hazards Identified and Labeled b. License Requirements c. Records d. Dosimetry Program e. Periodic Leak Checks f. Radiation ProtectionOfficer wp6/3560q-7 bFG45107 J J ON* S ~ IH-101A Revised: 8/8/84 S = Satisfactory NA = Needs Attention DNA = Does Not Apply 6. Ventilation for Health Hazard Control a. Periodic Flow or Maintenance Checks b. Laboratory Hoods S. 1. Yearly Flow Checked 2. Rating or Flow-Rate Posted 0. Modifications Reviewed d. New Systems Reviewed wr 7. Leak Detection ~ a. Written b. Area Monitoring Response c. Leak Repair Control W 8* i.H. Equipment Calibration a. Audiodocimeters -- 1. Daily Field Calibration 2. Laboratory Calibration S wf b. Sound Level Meters 1. Daily Field Calibration 2. Laboratory Calibration/Three Years j: c.* Acoustic Field Calibrators Every Three Years d. Radiation Detection Device - Annually e. Area Monitoring Devices f. Personnel Monitoring Pumps j JaA j 9. Laboratory Safety a. Lab Hoods Adequate for Hazard b. Lab Procedures Reviewed c. * Personnel Protective Clothing and Equipment 10. Totals Satisfactory Needs Attention *f / 900Z68SZ p6/3560q-8 BpG45l08 Sample No. Date 1. 8/14 2. 8/15 ATTACHMENT II. PERSONNEL MONITORING RESULTS Employee Job 1. NOISE Hearing Protection Sample Time % 12 Hr. TWA dBA Equivalent N. Lynsden #2 Niro Bagger Yes 401 min. 62.8 85.6 R. Arnold #2 Niro Bagger Yes 480 min. 99.1 87 .0 3. 8/14 T. Morris ORGANIC VAPORS #1 Oper., Geon S No resp. 383 min. 4. 8/14 R. Dekker #2 Oper., Geon S No resp. 380 min. 5. 8/15 6. 8/15 T. Canham G. Johnson Maint. Mechanic #1 Lab Operator No resp 375 min. No resp. 380 min. PPm VCM VAC TCE <0.1 -r0.4 <0.2 VCM <0.1 VAC <0.4 TCE < 0.2 VCM 5.6 EDC <0.7 "Sjoise data collected with a duPont audiodosimeter with a threshold of 80 dBA, criteria of 90 dBA and an exchange rate of 5 dBA. Organic vapor results collected with Sipin pumps operating at a flow rate between 17-42 cc/min. Collection media used was 100/50 mg charcoal tube; GC analysis by the Brecksville H & E laboratory. VCM - vinyl chloride VAC - vinyl acetate TCE - trichloroethylene EDC - ethylene dichloride * TLV = 2.0 ppm (OMH) TLV =10.0 ppm (ACGIH) TLV = 50.0 ppm (ACGIH) TLV = 10.0 ppm (ACGIH) A O O Z68S Z BFG45109 ro rPOM C. C. Lee X~.S. Blalke SUBJECT FIELD POINT OR DEPT & BLDG NO Niagara Falls__________ FIELD POINT OR DEPT. & BLDG. NO Akron D/Q0-20. 5-H Industrial Hygiene Survey; May 10-13, 1983 DATE YOUR LETTER DATE THIS LETTER 6-10-83 An industrial hygiene survey was conducted at the Niagara Falls chemical plant during the period May 10-13, 1983. Nine recommendations from the 1981-82 surveys have been satisfactorily completed. Three recommendations need minor refinements before they can be considered complete, i.e. recording results of employee respirator exams in medical file, fit testing of employees with different types of respirators that they may have to wear, and increasing sampling rates for VCM monitoring. Items that need attention as a result of the 1983 survey include control of noise at the PVC bagging stations, n-hexane and vinyl acetate exposure assessments. An inventory of chemical and physical hazards by job class was completed to ful fill requirements of the medical information system. I found housekeeping in the plant to be very good. Also, the wearing of hearing protection in posted noise hazardous areas was being observed. I want to thank C. Reid, B. Hawkins and the Niagara Falls management for their , cooperation and assistance in making this survey profitable. Please respond to the status of recommendations in this survey within 60 days and quarterly there after until all items have been acted upon. v cc: F.Houey/D.A.Brooks, Shawinigan G.Lefebvre/H.Waltemate, Cleveland H.C.Bothelo, Cleveland \ i: 25893001 BFG45110 Niagara Falls IH Survey; May 1983 Items from Previous Survey Recommendation 1. (1981) Replace eyewash fountain* third floor, Geon south. 2. (1981) Provide employees who are required to wear respirators with a respirator approval exam per BFG OHP 1.17. 3. (1981) No formal reply to IH survey. 4. (1982) Document respirator usage by adopting a written respirator procedure. 3. (1982) Incorporate SPCC procedure into the plant's protective clothing and equipment requirements. 6. (1982) Establish VCM monitoring require ments through a written procedure. 7. (1982) a. Post areas greater than 85 dBA as noise hazardous and require hearing protection to be worn. b. Provide nurse and doctor with audiodosimeter results. c. Calibrate noise dosimeter annually. 8. Note respirator and hearing protection usage when employees are being/'monitored. 9. Install GC line particulate filters in Geon S. 10. Tighten Bolton filters on GC lines, Geon N. i. Action taken 1. Completed. 2. Partially complete. Respirator approval exam being given, but results not being recorded in employees' medical exam files. 3. Reply to 1981 survey received and is satisfactory. 4. Respirator procedure written; action complete; see current findings. 5. Action complete. 6. Procedure written; see current findings. a. All areas except PVC bagging posted. hearing protection requirements good. Compliance with b. Results being provided on an "as needed" basis. c. Complete; dosimeters being calibrated annually. 8. Monthly environmental report being noted. Action complete. 9. Action complete; filters installed. 10. Action complete; filters tightened. BFG45111 Z00C68SZ BFG45112 Niagara Falls IH Survey; May 1983 Current Survey Findings Recommendations Responsibility 2. Exp. Date of Comp. 1. Respirator procedure does not require fit testing of all types of respirators used at Niagara Falls. 1. Conduct fit testing of employees with employee wearing each type of respirator he will be required to wear. Does not apply to wearing of disposable-type particulate respi rators. 2. a. Pigment room, 3rd fir. Geon S., face shield found to be unserviceable. b. N-hexane used as solvent for catalyst make-up. Catalyst make-up tank is refrigerated and local exhaust provided to tank opening and to catalyst container filling station. 3. VCM monitoring procedure requires flowrate of 10 cc/min. for sample duration of 4-7 hours. a. Replace face shield and ensure that the operator uses it whenever he handles catalyst. b. Obtain 3 personnel task monitorings for n-hexane during catalyst make-up operation and during filling of n-hexane holding tank. Procedure has been pro vided. 3. Increase VCM sample flowrate to 25-30 cc/min. with minimum time for a long-term sample of 6 hours. 4. Plant has obtained one sample for vinyl acetate. Four samples were collected during this survey. Results are listed in Table I. See Discussion. 4. More personnel monitoring for vinyl acetate needs to be done to properly evalu ate employee exposure. Obtain at least 3 samples per exposed job class per request dated 3-11-83. 5. Noise. Four employees were monitored for noise using a duPontMK-1 dosimeter set with a threshold o^80 dBA) and a criteria of 90 dBA. Table II contains these results. All employees monitored worked 12 hour shifts: process helper Geon S., noise exposure 121.4%; No. 2 dryer operator had noise exposure of 132.1%; No. 2 Niro bagger's noise exposure was 214%. 5. The Ontario Ministry of Health has pro posed a noise standard of 90 dBA for a 40 hour work week measured with dosimeters having 85 dBA thresholds. This is equivalent to having 5 eight hour day exposures to 100% noise dosimeter readings or three and one- / ' third days exposure to 100% noise dosimeter readings. The process helper and dryer operator noise exposures, if maintained over a 3-day period, would result in the worker being exposed at the 0MH standard. The #2 Niro bagger's exposure, however, is clearly excessive. C00C68SZ s Niagara Falls IH Survey; May 1983 Current Survey Findings (con't) 5. Noise (con't) 6. Maintenance shop parts cleaner solvent observed without a lid. 7. Portable eyewash fountains not posted with date of last water change or maintenance check. Recommendations Responsibility 3. Exp.Date. Compl. Both the //2 dryer operator and #2 Niro bagger received their noise exposure from the bagging operation. Compressed air from the bagger needs to be muffled. The plant has an ER in process to isolate bagging station from the silo. The bagging area needs to be posted as noise hazardous and hearing protection made mandatory. 6. Install a lid on parts cleaning tank and keep lid closed when not in use. 7. To ensure that the water in the portable eyewash fountains has been periodically changed and is kept filled to the proper level, each portable eyewash fountain must be labeled with the date it was last in spected and water changed. A punch-out tag system, such as that used to record inspection of fire extinguishers should be adequate. BFG45113 *00C68SZ Niagara Falls 1H Survey; May 1983 Discussion: 4. Table I contains results of personnel monitoring for vinyl acetate (VA) at Niagara Falls. Sample #1 is a task sample taken in the tank farm during a VA unloading operation. No detectable level of VA was found. Four other samples collected indicated VA exposures to be below 1 ppm; the current ACGIH TLV is 10 ppm. While these results are encouraging, more monitoring needs to be done so that we can properly evaluate worker exposures to vinyl acetate. This year's survey afforded the opportunity for me to complete a hazard inventory of the plant. Carl Reid and all Niagara Falls production managers were most help ful in assisting with this inventory. The inventory lists by plant job class all physical and chemical agents an employee working in that particular job class may be exposed to. It also attempts to estimate the degree of exposure. Once the inventory is computerized, it will allow the medical department to run epidemio logical studies and track potential health problems that may be associated with plant exposures. This year's survey also provided an opportunity to discuss industrial hygiene con cerns regarding the possible relocation of the Kitchener PVC compounding line to Niagara Falls. The discussion included control of noise from cubers, mills, and mill drives, pallet transfer and strip blow-off. Control of noise is best achieved through isolation of the noise source by appropriate sound barriers. Toxic stabilizers and pigment dust control measures were discussed. Booths for pigment weighing need proper design and flowrates of 150-200 fpm at weigh point. Empty bags need proper handling to prevent dust release. Henschel loading needs ventilation. Automatic scales fed by hoppers through an air pallet system reduces manual handling of pigments and worker exposures. Plasticizers should be pumped from bulk storage to eliminate open buckets. Henschel, extruders, mills, and strip conveyors need ventilation to remove stabilizer and plasticizer fumes from hot PVC. A central vacuum system is a must to facilitate clean-up. Much experience has been gained by U.S. plants toward addressing exposures from PVC compounding. It would be very beneficial for individuals involved in the relocation project to visit the Louisville, Avon Lake, and Pedricktown PVC operations to view the controls implemen ted at each of these chemical facilities. I will be available to review proposals, offer suggestions, or refer you to other people within the company who are "in-theknow" to ensure that all necessary precautions are engineered into the line before installation. This is an excellent opportunity for "doing it right the first time". TSB 25893005 BFG45114 TABLE I. VINYL ACETATE RESULTS Niagara Falls; May 1983 CORRECTED COPY 6/14/83 Sampl e No. Name Job Date Sample Time (min.) Vinyl Acetate Cone (ppm) 1. Willard Arseneault Tank Farm operator 5/11 10 LDL* 2. B. Burley #1 Charge oper. 5/11 378 0.27 3. P. Marshall 4. P. Marshall Recovery oper. If 11 5/11 5/12 377 390 0.8 0.21 5. E. Ryan Charge oper. & foreman 5/12 389 0.11 *LDL = less than detectable limit. * ** **** ** TABLE II. NOISE DOSIMETRY RESULTS* ___________May 11, 1983 Name K. McArdle N. Lunsden D. Potter W. Fisher Job Title Stationary Engr. Process helper //2 dryer oper. //2 Niro bagger * Instrument characteristics: threshold = 80 dBA criteria = 90 dBA exchange rate = 5 dBA Location Boiler house Geon S. poly bldg. Dryer bldg. Dryer bldg. H.P. Worn Yes ir M - 12 Hr. TV 86% 121.4% 132.1% 214% BFG45U5 25893006