Document N73w60G22M27LDeXrxaRGOQg

S' GR 10/20/75 PCD EXPOSURE CONTROL 1. PREMISE Current data indicates that PCD type materials may be more hazardous to working personnel than had previously been con sidered. Based on these facts, the control of exposure of workers where pen's are manufactured or used should be re examined and made more restrictive. Currently the American Conference of Governmental Industrial Hygienists (ACGIH) shows threshold limit values for chlorodiphenyl (42% chlorine) (AROCLOR 1254) of 0.5 mg/M3. The two routes of entry of importance in PCB manufacture and use are vapor inhalation and skin absorption. Very limited analysis in the AROCLOR department indicates that the airborne concentrations are below these numbers. Although there is no evidence that skin absorption presents a significant hazard, it is probable that skin exposure does occur. 2. RECOMMENDED METHODS OF CONTROL A. Vapor Inhalation Vapor inhalation is a problem only when AROCLOR is heated above ambient temperature. Where vapor exposure is pos sible, air supplied respiratory protection must be worn. An airborne control limit for all PCB vapor exposure must be set as low as is practicable and certainly below the standard for PCB with the lowest TLV currently listed in 29 CFR 1910.93 which is chlorodiphenyl (54% chlorine) (ARO CLOR 1254). Routine air monitoring must be conducted. 1 B. Skin Any operation, particularly maintenance operations, where liquid PCB's Q,r PCB mists can come in contact with the skin, skin protection including gloves and suitable im pervious clo hing must' be used. Where heated AROCLOR is present resulting in vapor exposure, air supplied respira- tory equipment and impervious clothing both must be used. For example, in maintenance work on a chlorinator that has been drained but is still hot, air supplied respiratory protection and impervious clothing should both be used. " . C. Exposure Registry . An exposure registry must be established on all PCB workers. All air sampling data must be recorded along with all appropriate health information. This registry would be a composite, therefore, of all medical and health data and all airborne exposure data. This registry should be so constructed that each individual employee can have avail able to him all data that pertains to him for examination or transfer to any subsequent employer. MONS 04585** -2D. Environmental Contamination We would recommend that all means be exercised, either through engineering changes or through work practice Changes to minimize environmental releases, either by air water or through solid residues. HONS 045855