Document MD4MeoJLBm8QYkRZrv41GjaV

i ( B.F. Goodrich Chemical Company A DIVISION OF THE B. F GOOORICH COMPANT 6100 OAK TREE BOULEVARD CLEVELAND, OHIO 44131 PHONE: 2T6-524-0200 June 7, 1974 Gentlemen: The Occupational Safety and Health Administration (OSHA) announced on April 5, 1974, an Emergency Temporary Health Standard for exposure to vinyl chloride. (Federal Register, Volume 39, Humber 67, April 5, 1974, pages 12342-44). This emergency standard established an exposure ceiling of 50 parts per million (ppm) in air for vinyl chloride (VC). OSHA, in paragraph 1910.93q of the subject standard, has set down temporary in-plant monitoring requirements for ambient air for employee protection. On May 10, 1974, OSHA published a Proposed Permanent Standard for Exposure to Vinyl Chloride Monomer with allowable exposure to vinyl chloride limited to "non-detectable" level. Please refer to Federal Register, Volume 39, Number 92, pages 16896-16900 dated May 10, 1974. This proposed standard covers vinyl chloride manufacturing, polyvinyl chloride resin manufacturing and we believe that vinyl material processors, such as your company, are intended to be included. As PVC latex is manufactured in the industry today, detectable quantities of vinyl chloride monomer remain in the product. While this may not result in detectable quantities in the general atmosphere in your plant, there are conditions under which residual monomer may accumulate to measurable amounts. It is the intent of this letter to indicate the order of magnitude of the trace amounts of residual vinyl chloride monomer presently in our products at the time of manufacture and to point out potential areas of accumulation. Geon latexes contain a maximum of .08% (800 ppm) of vinyl chloride, with an average level of .04% (400 ppm). We are working diligently to reduce these trace amounts and progress is constantly being made, but time will be required to implement improved technology and equipment to reach the desired goal. Since the monomer is volatile, it is released from the latex gradually in storage and more rapidly under the heat of drying and further processing. are: Analysis has shown that areas where vinyl monomer might concentrate (1) In enclosed containers such as bulk railcars, bulk trucks, storage tanks, and drums. The air space above the latex should be purged and monitored for vinyl monomer or adequate protection provided prior to exposure of personnel. 23357001 BFG25251 -2 (2) In processing areas such as compound preparation, spraying, or coating. Suitable ventilation should be provided. (3) In drying and curing areas. Normal good operating practice in exhausting volatiles may be sufficient. The concentration of vinyl chloride at the currently mandated exposure limits cannot be detected by odor so that suitable test equipment and methods must be used as indicated. Intense technical efforts by us and others in the industry are resulting in a rapidly changing situation. As additional information becomes available, we will certainly be in touch with you. Cordially yours R. L. Steller, Director Latex and Specialty Chemicals crw BFG25252 23357002