Document MJ9M9Rxq4mez8BpyEmKa8we3x

A *c&- ant/ &6*ntcai- INTEROFFICE MEMORANDUM To From_ Distribution J. T. Barr_________ Distribution: A. R. Adams C. E. Blades W. R. Byrnes T. L. Carey J. D. Evers R. Fleming H. L. Jaffe J. D. Kramer ' Subject Date 10 December 1974 Action Steps to Meet QSHA Standard on Vinyl Chloride {Location, Organisation, or Department) Valley Forge (Cac*Uon, Or?nl*tian, or Department) A. K. McMillan J. B. Maerker G. J. Mantell B. S. Melnick J. Novak E. A. Primeau F. J. Ryan J. T. Sebastianelli W. M. Smith R. R. Spiegelhalter G. B. H. Speed E. M. Spurlock E. Steck M. H. Sternum J. Tinnon H. L. lVatson The 9 October memo from A. R, Adams to Distribution detailed certain assignments on preparing for the 1 January effective date of the pennanent OSHA standard on vinyl chloride. Recommendations for some of the action points assigned to me are given below. These have been discussed with the other persons concerned. In many cases final decisions cannot be made until the program. ' directive is available. This is expected to be published by next week. There is also a possibility that the courts may act on a part or all of the standard before 1 January. I. Respirators 1. Until cartridge and/or canister types are approved, we will rely on the half-face, continuous air supplied respirators on hand. They are to be carried by all persons entering the regulated areas and worn (a) whenever in the polymerization building, or (6) when working on monomer-containing equipment, such as filters, etc., or connecting or disconnecting tank cars. (0 They must tenporarily be disconnected before going up or down stairs or crossing the area. 2. Scott Air Paks or equal will be worn for re-entry in case of a release that shows above 195 LEL (3,600 ppm) on the Bacharach, or where concentrations above 1,000 ppm can be expected. They should be available in an area remote from the potential release points. 3. Provisions of 1910.134' must be met as to air quality and mask maintenance. <320} AP00034642 Action Steps/OSIIA. Standard 10 December 1974 Page TWo 4, These procedures will be revised as soon as additional types of equipment have been approved. II. Protective Clothing 1. All workers assigned to the polymer building, or to other potential hazardous areas will be issued daily clean cotton or cotton/synthetic blend work uniform; pants and long sleeve shirts, or coveralls. 2. Spare clothing will be available in case o worker's becoming wet or unusually dirty. 3. We will continue to supply foul weather gear for jobs that anticipate the need for protection against splashing, etc. 4. Thus, the minimum clothing to be worn in the regulated aTea includes: (a) clean outer garments (b) hard hat (c) eye protection (d) respirator 5. Inside vessels, waterproof gloves will also be worn, plus boots or overshoes. 6. A change area will be available outside the regulated area. III. Monitoring 1. Non-regulated areas (a) Personal monitoring on an 8-hour TWA basis must be completed in time for the decision as to the need for regulation to be made and the regulated areas reported before 30 January. (b) If tiro measurements more than five days apart show below 0.5 ppm, it is not necessary to test for the 5 ppm ceiling. (c) It is recommended that monitoring be repeated quarterly or whenever there is reason to suspect that any change requires further testing. AP00034643 Action Steps/OSHA Standard 10 December 1974 Page Three 2. Regulated Areas (a) We understand that both area and personal monitoring will be required, Cb) Monitoring results will be processed in the manner developed by the medical consultants* (c) It is recommended that, until we receive further information, all persons be monitored at least monthly for 8-hour exposures if they enter the regulated area. This would seem to include even the infrequent visitor. The 15-minute ceiling tests must be run in addition. (d) Area monitor alarms should be set below 25 ppm, say 20, to give those electing not to wear respirators time to put them on before the 25 ppm concentration is reached. /dw AP00034644 ' PVC Workers in Britain j Want Stringent Standard: `No Detectable' Amount Britain's General & Municipal Workers' Union has proposed that ex posure levels in polyvinyl chloride plants be limited to ` the least detecta ble amount," claiming that vinyl chlo ride manufacture has been responsible for twenty-three deaths through liver cancer and an increase in other indus trial diseases. The union it a powerful one, having tome 2,000 members involved in vinyl chlo ride plants in the UK. A spokesman points out that "the over whelming weight of medical opinion, to gether with evidence that the monitoring techniques in the US and Europe are simi lar to our own. brings us to the conclusion that the present Interim UK standard is not acceptable to the union. We now require that manufacturers agree to set a standard of the least detectable amount of exposure," He says that it is "no longer sufficient" for UK makers to relate their monitoring to exposures of even one part per million when equipment is now available to meas ure one part per billion. He adds that the new US standard of one ppm, which appar ently worries UK manufacturers, is "not acceptable to either the US or the UK unloos." and he asserts "neither are we pre pared to negotiate or to bargain on expo sure levels." The union will convene a conference of ahop stewards and union officials at which findings by medical scientists will be pres- W ** AP00034645 1 Plastics GroupSe Stay on VGM Sta i-. *' r'i*. 1\ ,--W RECE'^g DEC5'U3ft Society of the Plasty petitioned the US Court stay an order of the Oc ty & Health Administra the decision of that coi of a recently promulgate for Occupational Exposure Chloride. -a TheOSHA standard, whic! respiratory protective equipm into effect January 1,1975. Ori on the case are schedule/ of Appeals on December The stay has been reqi of the ora}'arguments, SPl pr* ii-o potslblejBay" rid numbers 9f Yespintio uipment by the eod of tKg*: 'This would have the prae requiring many plants in the' producing vinyl chloride poly-vinyl chloride resin t' December SI, 1974, SPl. >: In itsrpbtition SH a much of the equipment spec use has not yet been appro tlonal Institute of Occupi Health (NIOSH). nor is it January 1. v According to SPl, res today, "is only' 26 percent raand with optimum supplypercent of current deman AP00034646