Document NGbK7Yre5yYnN2jzzj8D4aD9D

KtUtULw 9 mMAY 27 R.H.WHFFIEJ<<. Barring future court action, OSHA regulation 1910.93q pertaining to vinyl chloride will take effect on April 1, 1975. Goodyear's plans for continued production of general purpose resins, dispersion resins, and compounds have not been contingent on a favorable ruling by the court on the petitions for review of the OSHA standard. We intend to maintain production under the new standard at our P7C plants with the use of respiratory equipment. * The company has already made numerous improvements in equipment, processes, and work practices, including the use of respirators as required. In addition, we are continuing intensive research and develop ment programs on new and improved technology. These programs already are providing promising results which are now undergoing further evalua tion and in-plant testing. In further compliance with the standard, we have in-place alarm systems which signal any leak above 10 ppm, and are installing alarms for even lower levels. Hie company's current product line includes mass polymerized general purpose resin from our Plaquemine, Louisiana plant and dispersion resin and compounds produced at Niagara Falls, New York. Long term plans include further expansion of the Plaquemine plant and replacement of that portion of our Niagara Falls production facility previously closed down because of the OSHA regulation. The regulations require precautionary labeling of containers of resins and compounds shipped after or in transit on April 1,. 1975* The regulation states: "Containers of polyvinyl chloride shall be loglbly labeled: Polyvinyl Chloride (or Trnde Nans) Contains Vinyl Chloride Vinyl Chloride is a Cancer Suspect Agent" In tho case of Pliovic PVC resins and compounds, the labol will np|H*.ur: (over) UCC 010187 A precautionary statement on pre-printed 3" x 5" vara tags with the above type will be used at the entries to bulk hopper trucks^ box cars, and truck trailers. Bulk rail cars used for transporting Pliovic polyvinyl chloride will be stenciled at both ends close to the access ladders with the OSHA pre cautionary statement above in 3/4" letters. All top hatches will be stenciled in l/2" letters with the following: Enter with Adequate Ventilation Respiratory Protection Recommended Goodyear has continuing and on-going programs for reducing the residualviryl chloride monomer levels in its products, Current levels measured in the resins being manufactured in our Niagara Falls plant are as follows: "AQ/fyOn rosins: "M" resins: Compounds: 10 ppm maximum with typical levels being nen detectable 50 ppm maximum with typical levels<30 ppm 5 ppm maximum with typical lovels being nondetectahlo The above values were determined jusit prior to movement of the finished resins into our warehouse for storage. These values should be con sidered maximum since vinyl chloride is migratory. At the Plaqueaine plant, resin being produced In our recent expansion is generally measured under 100 ppm with typical levels of 60 ppm. New equipment being delivered and Installed during the second quarter of this year will assist us in reducing VCM levels in resin produced in the older section of this plant, and will help us In reaching a goal of. less than 10 ppm residual monomer in all Plaquemine produced materials. The company is hopeful that these continuing programs will permit still further reductions of monomer levels in its products. As further progress is made or significant developments occur., va will continue to keep you informed. H D Alliefc 8 Karkoting Jianager Plastics Department ucc 010188