Document NGpLvxGaxEGGynb9n7qRNkJ6w

10: Mr. J. I. Kejgeri On January 21, 1972 Koha and Haas seat people to Washington to discuss OSHA standards with OSHA people. The following Is one consent Included la a neaoraadua fron Bohn and Haas regarding the aaetlag that 1 thought you night be laterested la: "Air Cootanlnaat ganpllng - docnnentatloo of our ssapling practices will be required. The use of direct reading Instraaants Is accaptable. However, the saapllng oust be done over an H-hour period of tine to accurately reflect eaployee exposure. Where celling values are Involved, continuous nonItorlag Is rr i ivimili il and la all probability will be required." 8. A. D'Amond 3/21/72 E-02340 J- J- beroin E-02341 ETC 14640 J. J. /3esy'* /s 5ct?/ /rtferesfp/zj /r? /*s/?7z/z^i f/dro/c/ os?s?/f2y^t?/tf S&ff/d^c/ r` f&TT? /(od/7? <2*u/ //&&S C<n?cesr?sszy 0S///I. //dro/c/ J&/s J&/?ys JdCde/r^ a-f rf/j cPc</?(/sA(fy #j/ it yd 7&&S- R. W. MAESER, JR. V^/7_ ^'0234? MEMORANDUM ''^ ~ ROHM AND i; A AS COMPANY Plant Managers Mr. R. R. Van Sickle - Corp. Safety February 7. 1972 COPIES TO (nif * tj Mr. Tctzlaff Mr. Whitesell Dr. Winters Subject REVIEW 0? OSHA STANDARDS l' i 1 .r ` Mur. .Geniesse Mr. Moody Mr. Prizer We attach a copy of Mr. Jorgensen's report of a, meeting held with representatives of the OSKA standards group. The information which is included in this report provides a different slant and a change in interpretation from some of the regulations \ rich have beer, included in the Federal Register. We believe that uhe :..odified interpretations will result in considerable savings based on previous interpretations of the regulations. Although it is not certain that the present interpretations will persist, we should be able to use the sursnary of our dissuasions as a guide in determining whether v/e are able to comply with the regula tions. The items covered during our discussions represent only a partial listing of regulations in question. Please advise us. if, other regulations require additional background information, interpretation and/or clarification. RVS.-mrl Attachment Report of OSHA meeting, Washington, D.C., 1/21/72 -02343 ETC 14642 REPORT 07 MEETING' Reported by John Jorgensen Subject 03HA STANDARDS Date and Place Held: January 21, 1972; VJashington, D. C. Persons Attending: Mr. G. Scannell, Mr. E. Regard, Mr. R. Rank, Mr. R. R. VanSickle, and John Jorgensen The purpose of the meeting with the OSHA officials was to obtain some clarification, interpretations, scopes and intents of the standards promulgated to date. All in all it was a very satisfactory meeting. Key points discussed were: 1. Variances - we learned about 100 applications for variances have been received, with only 3 approved to date. . Obtaining variances as a company does not appear to be a desirable route as OSHA much prefers .industry requests for variances. Recommendation - we use the MCA as the medium for variance requests. 2. Material. Safety Data Sheets - the form and system to be eventually adopted will require much the sane information as the present Maritime Data Sheet. Recommendation - continue our present approach in handling this program. Apparently ve will have adequate lead time. We may possibly wish to have our Data Sheet approved by OSHA. ' 3. Product Identificat* on - apparently. D.O.T. is planning to adopt the Hazard Id ntification system as developed by MCA. Recommendation - we should lie low on labeling ahd identification until we know for sure when OSHA and D.O.T. decide how they are going to resolve who's going to do what. 4* 32 psi Air Pressure - 03KA at the moment is trying to obtain an interpretation from their solicitor on this point. They frown on air nozzles at pressures above 30 psi mounted on hose wheels. However, if the nozzle is permanently mounted on other than hose wheels they will accept pressures higher than 30 psi. Recommendation - where we don't need 30 psi ve reduce the pressure by compressor controls or by safety nozzles. In addition, we should explore how we can permanently mount air nozzles where ' greater than 30 psi air pressure is required. However, we should not go to great expense before we receive further clarification on this issue. e_0234A ETC 14643 4. 5. Sr^cty Color Codo - has been revoked. Recommendation - suggest ve continue oar own color code practices. 6. Floor Losding Si nos - if loads do not change from design loads ? J),s-*sJ on a regular basis, sigUns are not needed. 3/jf/7t 7re.*i'rrs /Z/i,*,,!,? M-J srn-f'Sr*4"-' , Recommendation - review our existing facilities for irregularities in loading practices, to assure whether ve need signs or not. 7 Floor Openings lw or Less - if floor openings p,,ro not over working areas, normal precautions are adequate (sleeves, etc.). Recommendation - ve review our operations for exposure to hazards due to openings larger than 1". * 8. Perfomance Standards regarding Railings -- 203 force pounds .is accented. Recommendation - that ve do not replace existing railings, stairs, etc., that deviate slightly from standard as long as. they can moot the performance standard of 200 force pounds. 9. Emergency Lighting - emergency generators, separate power sources, batteries, are considered adequate. Recommendation - make sure that ve do have emergency lighting back up by batteries, generators, different pover sources, as required. .10 Air will Contaminant Sampling be required. The use - ofddociruemcetnrtaetaiodningofiro.surtrsaamme nptlsingisp.reacccteicpetcsfple.ipT,**r?i' f However, the sampling must be done over an 8-honr .period of til e - to accurately reflect employee exposure. Where colli r~ values are ! involved, continuous .monitoring is recommended and; in all probability will be required. Recommendation - ve continue our present approach of establishing and conducting sampling and analytical procedures for the air contaminants listed in Section .93* 11. Heat Stress Standard - ve have received conflicting statements as to when-this standard -would b'e proposed, but it vill in all probability be this year. 12. Noise Exposure - if our noise levels exceed, the table, ve must have a hearing conservation program. Audiometric testing is still not a requirement, but strongly recommended. Recommendation - ve continue our present programs. 13. Definition of Chemical vs. Process Plant - 05:11 has not arrived at a clear definition of what a chemical plant is. For the present, it is to our advantage to have all our plants clcssificd as chemical plants due to the many exemptions granted. However, in the pur? sense, only Houston can qualify as a chemical plant as it starts fron the natural gas, air and water stages; whereas our other plants process materials made by chemical plants. e~02345 ETC 14644 (13. - cont'd.) :3 Recommendation - wo wait until 03HA has clarified the definition of a chemical plant. Meanwhile we urge MCA to make a pitch for retaining present broad definition. valves. Recoxaer.datior. - check compliance reviews to learn where action required. Recommendation - avalt further clarification o Recommendation - alert plants Recommendation - check to learn if river/process water can be made' potable by inexpensive means. (HKal Weaver, S. Behrend, and H. Spear are working on this project.) examinations are recommended for employees who use respirators routinely in their jobs. Recommendation - advise plants. 20. Change Rooms: Clean vs. Dirty Lockers - one locker sufficient except for special, unusual conditions. Recommendation - none. 21. Control Room as Lunch Room - okay, provided not contaminated. Sampling required before use as lunch room. Recommendation - plants check out eating areas for acceptability by sampling if necessary. P-02346 ETC 14645 22. Carbon Monoxide SaT.pIin': - industrial hygienist is not required, as a trained employee, preferably Safety nan, can sample. Recommendation - notify plants. 23. Limitation on Soinnev Knobs on Fork Lift Trucks - Revoked. Recommendation - notify plants of revocation. 0 nr? 24. Working* Platform for nr-o with Fork Lift If fork lift operator stays with unit, shut-off device r.ot require Recommendation - notify plants of clarification. 25. Fire Pose Longer than 7b fees Located Ins.ld-s Fills^ ~r - can 'c:-. used by fire brigade members. Recommendation - department employees be trained and designated as fire brigade members. 26. Exhaust Ventilation Sir.rie C-rindor - if dust cclov; T1Y, not Recommendation - sample dust exposure to determine needs. /+ cn JJsjla e_023A7 ETC 14646