Document MKZ8N0g97bQq44zZJDDL3eKa

JOUTH CHASLZSTON SLANT UNION CARBIDE CORPORATION ,CHEMICALS AND PLASTICS 0 SOX MP4, SOUTH CmAHUSTON, W. VA. IUU December 2, 1974 Mr. John Stender Assistant Secretary of Labor fr>r Occupational Safety and Health U. S. Department of Labor 14th Street and Constitution Avenue Washington, D. C, 20004 Re: Dear Mr. Stender: Occupational Safety and Health Standard for Exposure to Vinvl Chloride The Occupational Safety and Health Standard for Exposure to Vinyl Chloride promulgated on October 4, 1974 applies to the transportation of vinyl ounce sample of polyvinyl chloride shipped by parcel post in a sealed can would require monitoring, training, and records for a mass of postal employees despite the fact t^atno significant exposure to vinyl chloride monomer could occur. A single, fiftypound, paper bag of resin is essentially treated the earn as a rail car containing fifty tens. In the case of the large bulk container be it ship, rail car, or truck, adherence to the letter of the standard regarding monitoring, training, and record keeping is relatively easy and the trans porta tion company has an economic incentive to transport the product. In the case of the single bag shipment, the multi-bag shipment, or the sample shipment, the logical move on the part of the transportation company is simply to refuse shipment to spare themselves the obvious expense involved in monitoring, train ing. and record keeping. The same applies to the public warehouse man and the terminal operator. Many of these distributive companies have indicated that they plan to handle direct truck load or rail car load shipments only of poly vinyl chloride. Union Carbide Corporation.owns and operates major polyvinyl chloride resin production facilities at South Charleston, West Virginia and at Texas City, Texas. Production facilities at these locations produce a variety of polyvinyl chloride resins by four different processes - Suspension p lymerisation, bulk polymerisation, emulsion polymerisation, and solution polymerisa tion. Only one of these polyvinyl chloride resin products, suspension resins, ucc 060418 Mr. John Stender 2 - December 2, 1974 contains significant amount* of vinyl chloride monomer; thia material ia generally ahipped by bulk and repreaenta no conaiderable problem in diatribution. Product* from the other three proceaaea are diatributed worldwide via a network of warebouaea and tranaportation companies. Of theae reaina, approximately one half or 100, 000, 000 pound* per year are ultimately d live red to about 1,500 customers in lea* -than-truck-load quantitiea. The average shipment ia eatimated to be H, 000 pound*. Theae leas-than-truck-load shipm nt* (9, 500 per year) involve 41 public warehouses and up to 200 different common carrier trucking companies in the United States alone. The value of these sales to Union Carbide Corporation is approximately $22,000, 000 per year. A sub stantial number of trucking and warehouse companies have indicated they d n t wish to handle these shipments in the future. Union Carbide Corporation thus finds itself with having to meet a very difficult standard in its production facilities and with being unable to supply many of its smaller customers. Other companies are faced with similar problems. Union Carbide Corporation is also concerned about the distribution problem as it is related to its customers. Many of Union Carbide's customers are formulators of lacquers, plastisols, and organosols for coating and molding applications. These liquids are normally shipped in closed steel drums by common carrier truck. As required by the Standard, monitoring, training, and record keeping are needed. It is very hard to conceive how a vinyl resin con taining no detectable vinyl chloride monomer, formulated into a coating material, and shipped in a sealed steel drum can be a hazard to a trucker or anyone Is*. This problem was discussed with Mr, Grover Wren, Chief of Health Standards Development, by Dr. R. S. Brookman of Firestone Plastics C mpany, Mr. Wayne T. Brooks of Organisation Resources Counselors, and me on November 26, 1974. The consensus of the discussion was that good monit ring studies of shipments correlated with type of PVC, weight of the shipment, vinyl chloride content of the PVC. the mod* of shipment, and the resin c ntainer could be used to develop shipping rules, freight classifications, and resin containers to fulfill the spirit of the vinyl chloride standard without requiring all of the monitoring, et cetera burdens of the transportation company. With adoquate guidelines for the shipper and the transportation company owners, application of the Standard's requirements for monitoring, training, and rec rd keeping can be avoided without any sacrifice of employe* safety. t Du* to the diversity of the industry interests and the broad sweep f the vinyl chloride Standard in its safety, objective, 1 think the Department of Labor should take the initiative in providing clear-cut rules and procedures f r vinyl resin transportation and distribution. Certainly, a trucking company in I < ucc 060419 Mr. John Stand# r AO. December 2, 1974 Dea Moines, Iowa, hauling 2, 000 pounds f solution p lymerised VYHH rosin containing no datactabla vinyl chlorida monomer, should not have to monitor its employee vinyl chloride exposure, train them in its hacard, and keep such records thirty years. A task force or committee, under the direction of the Assistant Secretary of Labor, should certainly be able to arrive at performance standards and rules for the distribution industry that achieve the objectives of the Standard. Union Carbide Corporation, Firestone Plastics Company, and many others would be willing to contribute data and alternative distribution technics to such a group. The formation of such a group could do much t clear up other questions regarding this Standard and to demonstrate that the Department of Inbor considers employee safety a cooperative effort by all concerned. Very truly yours RNWJr/ra R. K. Wheeler, Jr. ucc 060420