Document NvprD9xY4m4L26L4RbR4yvQD

2020 DOW CENTER August 28, 1993 The Dow Chemical Company Midland. Michigan IMPORTANT PRODUCT STEWARDSHIP INFORMATION ENCLOSED. PLEASE FORWARD TO YOUR PLANT MANAGER OR APPROPRIATE SAFETY MANAGER. PPG INDUSTRIES INC ATTN BETTY BAILEY'' ONE/PPG PL PITTSBURGH,PA 15272 As a valued customer of The Dow Chemical Company, you probably share our commitment to safety and the environment. To assist you in addressing these issues, we have developed the enclosed literature on the safe handling, use, and disposal of our products. Accompanying your recent sales order(s) of Dow products is the following literature: ORDER LITERATURE DESCRIPTION FORM // PROD CODE 8548673 VINYL CHLORIDE MONOMER SAFE HANDLING 102-00233 91575 Please review this literature before using your Dow products, and forward this information to your plant manager or appropriate safety manager. This literature has been sent to both your company's invoice and receiving locations. Providing customers with high quality health, safety, and environmental information -- such as the enclosed literature -- is the focus of our CHEMAWARE+ Enhanced Product and Environmental Stewardship Program. CHEMAWARE extends our dedication to you, and all those who handle Dow Chemicals and Metals products. For more information on CHEMAWARE or the safe handling, use, and disposal of Dow products, call us at 1-800-447-4DOW (4369). Gregory G. Bond Manager, Environmental, Health & Regulatory Affairs Chemicals and Metals Department ENCLOSURE 930062523 tService mark of The Dow Chemical Company SL 106804 Vinyl Chloride Monomer Safe Handling Guide i SL 106805 Contents Characteristics of Vinyl Chloride Monomer................................................ Name.............................................................................................................. Structural Formula........................................................................................ General Characteristics.................................................................................. Monomer Stability........................................................................................... Available Grades............................................................................................. 1 1 1 1 1 1 PhysicalPropertiesandConstantsofPureVinylChloride..................... 2 Hazards and Their Control............................................................................... Health.............................................................................................................. Fire and Explosion Hazards............................................................................ Polymerization Hazards................................................................................. Spills and Leakage........................................................................................... Special Personal Protective Equipment........................................................... Employee Education and Training................................................................... 4 4 4 5 5 5 5 Transportation.................................................................................................... 6 Preparing Shipments...................................................................................... 6 Tank Cars....................................................................................................... 0 Barges and Ships............................................................................................. 6 Safety Precautions........................................................................................... 7 v Storage .................................................................................................................. 8 Safety Precautions........................................................................................ 8 Tanks and Tank Farms.................................................................................. 8 Operating Equipment.........................................................................................1 Effect of Monomer Upon Materials................................................................ 10 Pressure Control............................................................................................. 10 Pumps, Piping and Reactors.............................................................................10 Instrumentation..............................................................................................10 Vents and Waste Disposal..................................................................................ll Dow and Product Stewardship.........................................................................11 Sources of Further Information......................................................................12 106806 sh Characteristics of Vinyl Chloride Monomer Name Vinyl Chloride Vinyl Chloride Monomer Chloroethylene Chloroethene Structural Formula HH II II -- C = C -- Cl General Characteristics At ambient temperatures and pressures pure vinyl chloride monomer is a colorless gas. It has a faintly sweet odor at high concentrations. A significant health hazard can exist with prolonged contact, even at low concentrations. Because of its toxicity, particularly its carcinogenicity, several Federal agencies have issued regulations for its handling, shipping, venting or use. These agencies include the Occupational Safety and Health Administration (OSHA), Department ofTransportation (DOT), Environmental Protection Agency (EPA), and Consumer Product Safety Commission (CPSC). Their most recent regulations covering vinyl chloride monomer must be adhered to, as well as those of other Federal, state and local agencies. Vinyl chloride monomer is sold, shipped and stored in the form ofa liquefied gas under pressure. It is flammable and, at ambient temperatures, will form explosive mixtures with air. The greatest immediate hazard in handling the monomer is the danger offire and explosion. Monomer Stability Pure vinyl chloride monomer is quite stable and will not free radical homopolymerize at temperatures or pressures encountered in transportation, storing and handling. It does not form peroxides as readily as many other monomers do. Hazardous levels of peroxides will not develop when the monomer is properly handled and stored in the absence ofoxygen, as outlined in this bulletin. Available Grades Vinyl chloride monomer is usually shipped in the uninhibited form. Low levels ofhydroquinone may be added to improve its stability for marine shipment. i SL 106807 1 Physical Properties and Constants of Pure Vinyl Chloride Tables 1 and 2 contain the latest information available on the properties of vinyl chloride. These data are taken from the Dow Physical Property Data Bank, which provides a self-consistent set of properties from published literature, internal Dow measurements, calculations and estimations. Tabic lr Property Molecular Weight Color Odor Melting Point and Heat of Fusion, cal/g Normal Boiling Point and Heat of Vaporization, cal/g Flash Point, open cup Autoignition Temperature Flammability Limits, Vol % in air Refractive Index, D Line Critical Parameters Temp., C -153.71 -13,83 -78 472 25 25 TC=152.6 Heat of Formation, Ideal Gas, keal/mol Heat of Polymerization, g to c, kcal/mol Volumetric Shrinkage upon Polymerization, approx., % Dielectric Constant at 105Hz Solubility ofWaterin VinyJ. Chloride, wt% Solubility ofVinyl Chloride inySVater at Saturation Conditions r* t' . -' (3.9 atm total pressure), wt %;i:, , Henry's Law Const, for Vinyl Chloride in Water, torr/wt ppm Solubility of O2 from Air in Vinyl Chloride at 60 psig, wtppm T., 25 17.2 -21 25 25 25 23.8 7 These properties are typical of the product, but should not be confused with or regarded as specifications. Value 62.50 Colorless Faint Sweet Odor 18.75 84.55 3.6-33 1.3642 Pc= 56.0 atm Vc= 174.8 cc/mol Zc= 0.28 6.81.6 -29.4+2 35 6.26 7.05 0.11 0.86 0.34 21025 SL 106808 2 For the convenience of the user, extrapolated data are included in Table 2. The last line of that tables gives the temperature range of experimental measurement. Table 2 + T,C Vapor Density, Pressure Liq. AHr mm Hg cal/g ^"sat* Liquid caV(g<>C) Cp, Ideal Gas cal/(gr C) Viscosity, cps Liquid Sat. Vapor Thermal Conductivity cal/(sec cm C) Liquid Sat. Vapor Surface Tension dyn/cm -100 2.61 1.105 99.62 0.3272 0.1508 0.607 6.31x10*3 4.78x10*4 1.04x10*3 33.5 -75 24.48 1.068 95.30 0.3265 0.1607 0.471 7.13xl0-3 4.25x10*4 1.28xl0-5 29.9 -50 129.8 1.030 91.06 0.3319 0.1715 0.369 7.99x10*3 3.77x10*4 1.57x10*3 26.4 -25 469.0 0.9899 86.63 0.3419 0.1828 0.292 8.90x10*3 3.34x10^ 1.90x10*3 -13.831 760.0 0.9712 84.55 0.3470 0.1879 0.263 9.32x10*3 3.17X10*4 2.07x10*3 0 1298 0.9473 81.84 0.3537 0.1943 0.232 9.87x10*3 2.96x10*4 2.26x10*3 25 2964 0.9016 76.52 0.3665 0.2057 0.186 1.09xl0-2 2.63x10*4 2.69x10*3 23.0 21.4 19.6 16.2 50 5883 0.8518 70.52 0.3815 0.2169 0.151 1.21x10*2 2.35x10*4 3.18x10*3 12.8 75 10520 0.7960. 63.57 0.4032 0.2277 0.123 1.34x1 O*2 2.12x10*4 3.77x10*3 9.38 100 17402 0.7308 55.02 0.4422 0.2382 0.101 1.49x10*2 1.94x10-* 4.43x10*3 6.04 Measured Tempera- Tm ture to 152 Range, C* Tmm -59 to 60 to 152 Tm,, to-14 TTMrn to 500 -40to30 -10 to 90 estimated 0 to 400 * These properties are typical of the product, but should not be confused with or regarded as specifications. 1 Normal BoilingPoint 2 Tm = -153.71C SL 106809 estimated 3 Hazards and Their Control Health Recommendations for safe handling are necessarily general because detailed recommendations can be made only for the specific exposures and circumstances of each use. When vinyl chloride monomer is present in sufficiently high vapor concentrations (about 10,000 ppm), the vapor has an anesthetic action. Repeated exposure of employees to high levels of the vapor has been shown to cause liver injury, acroosteolysis (a bone disease), and angiosarcoma (a cancer) of the liver. Other injuries, including mutagenic (chromosomal) changes, have also been reported but their relationship to vinyl chloride is not as well established. According to Occupational Safety and Health Administration (OSHA) regulations 29 CFR1910.1017, employees' exposure must be controlled to low levels to prevent carcinogenicity. At the low levels met by conforming to OSHA regulations, anesthesia or any other toxic effect is unlikely. Paragraph (c) of this section in the regulations reads: "Permissible exposure limit. (1) No employee may be exposed to vinyl chloride at concentrations greater than 1 ppm averaged over any 8-hour period and (2) No employee may be exposed to vinyl chloride at concentrations greater than 5 ppm averaged over any period not exceeding 15 minutes. (3) No employee may be exposed to vinyl chloride by direct contact with liquid vinyl chloride." Other parts of this section list the requirements for monitoring, regulated areas, methods of compliance, respiratory protection, hazardous operations, emergency situations, employee training, medical surveillance, signs and labels, records and reports. A copy of the regulation in effect at the time this brochure was published is included inside the back cover. However, readers should consult OSHA to be sure that their operations comply with the latest regulations. Fire and Explosion Hazards Always handle vinyl chloride with full recognition of its volatility and flammability. The vapors can form flammable mixtures with air at ambient temperatures. In general, precautions should be taken both to keep the material enclosed and to eliminate all sources of ignition. In the laboratory, handle samples of vinyl chloride in a well-ventilated hood and away from all ignition sources. Most small fires involving vinyl chloride can be extinguished with carbon dioxide (CO2) or dry chemical agents when these agents are properly applied. Be sure to provide adequate fire extinguishing equipment, either fixed or portable. Adding water to a pool of liquid vinyl chloride will promote vaporization and increase the hazard of a vapor cloud explosion. Gaseous vinyl chloride monomer is heavier than air; therefore, vapors coming off a pool of liquid vinyl chloride monomer will stay on the ground and will not disperse readily. Fires that involve large quantities of liquid are difficult to extinguish because vinyl chloride is not miscible with water and, having a lower specific gravity, will float on top of the water. Equipment that could be exposed to fire should be protected by properly designed and adequately maintained sprinkler systems. For additional protection, use flammable gas detectors to warn of hazardous conditions and to actuate protective devices automatically. Heatactuated devices can provide additional protection. Because explosive mixtures may be formed, do not allow vinyl chloride to enter closed drainage or general sewer systems. Regulations may also prohibit such methods of disposal. The products of combustion of vinyl chloride are hydrogen chloride, carbon dioxide, carbon monoxide and large quantities ofblack smoke. Phosgene has been reported to be a product of vinyl chloride fires; however, tests have shown that only minute amounts are formed. The real danger is in the large quantities of hydrogen chloride produced. 4 SL 106810 In the event of a fire, do not permit unauthorized persons to enter the area until the space has been thoroughly sprayed with water and then ventilated to remove all combustion products. Water spray from fogging nozzles directed into the path of the combustion products is highly effective in removing the hydrogen chloride. Polymerization Hazards Pure vinyl chloride monomer is quite stable (see page 1, "Monomer Stability") and offers essentially no hazard from free radical homopolymerization when it is stored properly. To prevent polymerization, it can be stored safely by meeting two essential requirements: 1) store the monomer so that it does not contact air (oxygen) or moisture, and 2) store it so as to prevent contamination by free radical initiators or other catalytic impurities. Spills and Leakage Because of its toxicity, spills and leaks of vinyl chloride must be prevented by means ofproper equipment design, regular maintenance and good operating procedures. Government standards specifying methods of sampling, loading, and handling that are aimed at minimizing emissions ofvinyl chloride came into effect in May 1980. Standards require the installation of approved area monitoring devices and portable vinyl chloride detectors. Equipment that contains a significant amount of liquid vinyl chloride should have remotely operated shut-off valves to reduce the potential of a large spill or fire. Provide adequate drainage to move liquid vinyl chloride away from equipment and personnel along with diking to retain spills. . When spills or leaks occur, remove all sources ofignition from the area immediately. Only properly protected personnel should remain. Small spills usually evaporate rapidly but ample ventilation must be provided. For large spills the recommended action is to cover the surface with a protein-based foam to retard vaporization. When the spill has been confined within a pit or diked area, transfer the vinyl chloride into closed vessels or dispose ofit as soon as possible in accordance with all applicable regulations. Take precautions to prevent contact with liquid vinyl chloride. In case of accidental contact with the liquid, undertake immediate decontamination. Recognize the potential danger offrostbite. Remove clothing accidentally contaminated with vinyl chloride immediately and wash the body thoroughly with water to remove any material that may have penetrated to the skin. Do not wear clothing again until it is free of vinyl chloride. Dispose of contaminated shoes. Special Personal Protective Equipment Respirators must be available for persons who handle vinyl chloride and must be of a type jointly approved by the National Institute of Occupational Safety and Health (NIOSH) and by the Mining Enforcement and Safety Administration. Current OSHA standards specify the vinyl chloride concentrations at which specific respirators must be used. Adequate eye protection should be worn whenever there is any possibility of chemical contact. Employee Education and Training All persons who work in areas where vinyl chloride liquid or vapor may be present should be thoroughly trained. The training must include several topics that are mandatory under the OSHA standard. Safety with vinyl chloride depends in large part upon the safe handling practices. Only reliable, properly trained personnel should control the flow and handling of the monomer. All personnel who handle vinyl chloride must be fully aware ofthe hazards involved, pertinent government regulations and the necessity for immediately reporting to the proper authorities all suspected leaks, malfunctioning equipment or equipment failures. In addition, each person in a vinyl chloride area should know the location and use of personal protective equipment, fire-fighting equipment, alarms, evacuation signals and procedures, safety showers and first aid measures. SL 106811 5 Transportation Preparing Shipments Vinyl chloride monomer is shipped in tank cars, barges and ships. These vessels must be specially designed and built to prevent the product from contacting copper alloys, aluminum or other materials that could cause the formation of explosive copper acetylides or aluminum chloralkyls. Vinyl chloride monomer is classified for transportation, by the DOT, as a Flammable Gas. Requirements for packaging, marking, labeling, placarding and preparing shipping papers are published in the Hazardous Materials Regulations (49 CFR, parts 100-199 for rail shipments) and the Coast Guard Regulations (46 CFR for barge and ship shipments). Federal, state and local regulations must be followed while loading or unloading the product. Containers ofvinyl chloride must be labeled "CANCERSUSPECT AGENT." Tank Cars Detailed instructions for loading and unloading tank cars ofvinyl chloride monomer are found in DOT Regulations (49 CFR). A diagram of the preferred vinyl chloride tank car unloading station is shown in Figure 1. The preferred type of tank car for vinyl chloride service is a DOT 105 A 300 W equipped with a Midland Manufacturing magnetic gauging device. These 25,000-gal. insulated tank cars have 225 psi pressure relief valves. Other acceptable tank cars are DOT 112J340 W, DOT 114J340 W, DOT 112T340 W, DOT 114T340 W, and DOT 105A200 W. Any tank car that Dow loads must have a magnetic gauging device. No external source ofheat should ever be applied to tank cars that contain vinyl chloride. Vinyl chloride gas should be the pressurizing medium used to empty tank cars. Install a suction line from the storage tank to a compressor that will discharge vinyl chloride gas to the vent connection on the car. The pressurizing gas should be virgin VCM as received and should contain no recycled VCM. Do not use inert gases to pressure vinyl chloride from a tank car; use of an inert gas can cause pressure buildup and problems with vent handling and disposal when the car is returned. A forwarding pump in conjunction with the compressor is recommended to expedite unloading. The pump should be located close to the tank car to minimize pressure drop. Steel centrifugal pumps with tandem or double seals are recommended. The pressure on the car must not exceed its designed service pressure. Positive vinyl chloride gas pressure should be left in the tank car after unloading is complete. In no case should air be allowed to enter the car. Tank cars are equipped with excessflow check valves that close when the discharge rate is too great. Whenever this check valve closes, the outlet valve must also be closed until the pressure is equalized and the excess-flow check valve reopens. Barges and Ships Marine shipments of vinyl chloride monomer must comply with U.S. Coast Guard regulations 46 CFR 151 for barge shipments and 46 CFR 154 for ship movements. Shipments should also comply with regulations of the Intergovernmental Maritime Consultative Organization (IMCO). Refrigeration is normally required on ships or barges that carry liquid vinyl chloride in order to maintain tank pressure at suitable low levels and to prevent the venting of monomer during transit. All air is purged from the tanks with nitrogen before it is loaded. Air should not be allowed to enter the tanks during transit. Dow inspects each ship and barge before it is loaded, and reserves the right to determine the suitability of each vessel and its hardware for transporting vinyl chloride. The method of unloading barges and ships is essentially the same as for tank cars. Because of the large loads involved, pumps are always used to unload ships; barges are sometimes unloaded with the compressor alone. Dow's policy is to work with customers to assure proper unloading facilities. 6 SL 106812 Exercise care when purging tanks on marine vessels after they have been emptied of liquid vinyl chloride. Inert gas must be used to displace the vapors to a non combustible level before any air is introduced into the tanks. Air and inert gas vented from the tanks during purging will contain vinyl chloride and must be disposed of so as not to create a health or fire hazard. Safety Precautions 1. Ground all cars, tanks, piping, pumps and equipment. 2. Eliminate all sources of ignition in the area. 3. Provide check valves in all liquid piping from the unloading operation to storage or reactors. 4. Dow's experience has shown that expansion joints should be avoided unless stringent inspection and testing programs are followed. If flexible metallic hoses are used, a test program should be followed. FIGURE 1 - Vinyl Chloride Tank Car Unloading Station SL 106813 Storage Safety Precautions Vinyl chloride storage areas should be selected in accordance with local codes. Assistance may be obtained from organizations such as the American Insurance Association, Factory Insurance Association or Factory Mutual Engineering Corporation, Factory Mutual System. All electrical equipment, motors, lights and flashlights in areas where vinyl chloride is stored or handled should conform to the National Electrical Code for Hazardous Areas. Areas where the monomer is stored should be clearly posted as hazardous and the burning characteristics of the liquid should be clearly defined for the benefit offire departments. Tanks and Tank Farms Figures 2 and 3 illustrate one type of recommended storage facility for vinyl chloride monomer. Vinyl chloride monomer may be stored at normal atmospheric temperatures in steel pressure vessels. Protect the monomer from contact with moisture, air, sunlight and other initiators to prevent quality degradation during storage. All tanks, piping, instrument leads, relief valves and equipment in contact with the monomer should be of steel and designed to have a working pressure of at least 138 psig. Do not use copper or copper-bearing alloys, or aluminum or aluminum bearing alloys, in storage facilities that put these metals in contact with the monomer or its vapors. Cast iron is not recommended for use in flanges, fittings or equipment. Liquid inlet lines should enter the bottom of tanks, or extend to the bottom, to prevent static charges from accumulating on filling. In addition, all tanks and filling equipment must be grounded. FIGURE 2 - Vinyl Chloride Storage Tank 3-WAY SL 106814 8 EPA regulations specify no leakage from vinyl chloride reliefvalves. This requirement is best achieved by installing a frangible disc under the reliefvalves as shown in Figure 2. In case excess pressure ruptures the frangible disc, the pressure relief valve will prevent the loss of the entire contents ofthe tank after the excess pressure has been relieved. To help prevent excessive pressure buildup, paint exposed tanks with a white or reflecting paint to keep tank skin temperatures below 130F(54C). Tanks should not be filled to more than 90% of volume capacity. Do not allow air to enter a tank. Relief valve specifications should conform to the requirements of the American Society of Mechanical Engineers (ASME) Unfired Pressure Vessel Code and may be sized in accordance with Volume 1, "Flammable Liquids," ofthe National Fire Code published by the National Fire Protection Association (NFPA). Provide drainage of at least 2% slope under the tanks to dispose of the liquid in case of major spills and build adequate diking to confine the liquid. A water-spray system is recommended for keeping the metal tank cool in case of fire. Some means should be provided to handle water which accumulates in the pit. Equipment for generating protein-based foam should be installed at the pit or otherwise be available at the site. All liquid outlet lines from storage tanks should contain check valves to prevent the contamination of tank contents. Before a tank is put into vinyl chloride monomer service, it must be clean, dry and free ofrust and it must be purged with an inert gas until it is free of air. Tanks of50,000-gal or less capacity are ordinarily constructed in the form of horizontal cylinders. Above 50,000gal, a sphere or other special shape should be considered. FIGURE 3 - Vinyl Chloride Tank Farm . SL 106815 9 Operating Equipment Effect of Monomer Upon Materials Dry vinyl chloride is not corrosive to iron and steel at ambient temperatures. Wet monomer, however, will cause the corrosion of iron and steel, particularly at elevated temperatures, and should be processed in corrosion-resistant equipment. Glass, porcelain, baked phenolic, and nickel linings are satisfactory for use with wet vinyl chloride. Copper or copperbearing alloys, and aluminum or aluminum-bearing alloys, should never be in contact with vinyl chloride. The use ofgalvanized steel in contact with vinyl chloride is not recommended. Many elastomers are attacked by vinyl chloride; however, Teflon resin and certain grades ofViton resin may be used. Other materials suitable for gaskets, seals, or packing include lead, asbestos and carbon. Pressure Control Equipment should be designed with due recognition of the high vapor pressure of vinyl chloride, and suitable safety factors must be allowed. Each piece ofequipment, even pipelines, that can be sealed offby means of valves should be protected with a pressure-control device. When relief valves are used, they should be placed in pairs to facilitate inspection, cleaning, and replacement. Figure 2 illustrates a pressure relief mechanism on a storage tank. The same system may be used on other types of equipment. Pumps, Piping and Reactors At ambient temperatures and unless moisture is present, steel is recommended for pipelines, flanges, pumps, tanks and valves. Cast iron is not recommended. Centrifugal, positive displacement and gear pumps are all acceptable for use with vinyl chloride monomer, but must comply with EPA requirements for minimizing leaks and fugitive emissions. They must be equipped with either tandem or double mechanical seals, or "canned" centrifugal pumps may be used. Steel ball valves or plugcocks lined with Teflon resin are recommended in preference to rising-stem valves to minimize leakage. Lubricated valves are not recommended. Instrumentation Conventional process controls and recording instruments of the proper materials of construction are acceptable for use with vinyl chloride. SL 106816 10 Vents and Waste Disposal Disposal of liquid or vapor streams that contain vinyl chloride must be carried out so that fire and health hazards are controlled. The allowable concentration of vinyl chloride in process vents is set by EPA regulations. When the vinyl chloride in a waste vapor stream exceeds this level, the stream must be conducted through a suitable control device to remove vinyl chloride before the stream is released to the atmosphere. Procedures for clearing and venting vinyl chloride-containing equipment prior to entry are also covered in the EPA standard. When liquid vinyl chloride must be disposed of, it should be salvaged, if at all possible, by reprocessing through a vinyl chloride purification system. Otherwise, it must be burned in a suitable incinerator system under conditions that will not release either vinyl chloride or hydrochloric acid to the air and in accordance with all applicable regulations. A copy of the EPA regulation for VCM in effect at the time this brochure was published by Dow is included in the pocket inside the back cover. However, readers should contact the EPA to be sure that their operations comply with the 1 atest regul ati on s. Dow and Product Stewardship Dow encourages its customers to review their applications of Dow products from the standpoint of human health and environmental quality. To help ensure that Dow products are not used in ways other than as intended or tested, Dow personnel are willing to assist customers in dealing with ecological and product-safety considerations. Your Dow sales representative can arrange the proper contacts. SL 106817 11 Sources of Further Information Additional information may be obtained from the following organizations or references: American Insurance Association 85 John Street New York City, New York 10038 (212) 669-0400 Chemical Manufacturers Association 2501 M Street, N.W. Washington D.C. 20009 (202) 887-1100 Factory Mutual Engineering Corporation Factory Mutual System 1151 Boston-Providence Turnpike Norwood, Massachusetts 02062 ' (617) 762-4300 National Fire Protection Association Batterymarch Park Quincy, MA 02269 (617) 770-3000 Research and Special Programs Administration Materials Transportation Bureau U.S. Department of Transportation 400 7th st., aw. Washington D.C. 20590 (202) 426-4486 The Dow Chemical Company Chemicals and Metals Department 2020 W. H. Dow Center Midland, Michigan 48674 (517) 636-1000 The Vinyl Institute Wayne Interchange Plaza II 155 Route 46 West Wayne, New Jersey 07470 (201) 890-9299 Vinyl and Related Polymers by Calvin E. Schildknecht John Wiley & Sons, Inc. (1952) 12 SL 106818 FRIDAY, OCTOBER 4, 1974 WASHINGTON, D.C. Volume 39 Number 194 PART II DEPARTMENT OF LABOR Occupational Safety And Health Administration EXPOSURE TO VINYL CHLORIDE Occupational Safety and Health Standards SL 106819 T3S50 RULES AND REGULATIONS Till 23---Ljoor CHAPTER XVII--OCCUPATIONAL SAFETY ANO HEALTH ADMINISTRATION. DE PARTMENT OF LABOR PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS Standard for Exposure to Vinyl Ohiorid* Pursuant to sections 6(b), 6<c), and 8<c) of the Occupational Safety and Health Act at 1970 <34 Slat. 1393, 1396. 1399; 29 u.s.C. 635. 637> secretary at Labor"* Order Mo. 12-71 <36 FR 8734) and 29 CFR Part 1911. 3 1910.93 of Part 1910 of Title 29. Code of Federal Regu lation* is hereby amended in the manner set forth below. In order to provide an Occupational Safety and Health stand ard dealing with the exposure ot em ployees to vinyl chloride. I. Bac^around--< l) Vinyl chloride. Vmvl chloride <chloroethene>. Chemical Abstracts Service ResL-.irv Mo. 73014 is a vnthctic organic riiemical made licm ethviene or acetylene and chlorine by any of several processes. It is the parent compound o. a senes of thermoplastic ream polymers and copolymers winch are widely used for containers, wrapping film, electrical insulation, pipe, conduit, and a variety of other industrial and consumer products. Vinyl chloride has been made commercially In this country since 1939. and present production is in excess of seven billion pounds per year. The vinyl chloride industry divides into three segments: monomer production, polymer production, and fabrication. Production cf the monomer Is a large* eale continuous process, mvulvmd omy .i few firms. There are comparatively few employees m this segment of the indus try. became the process** lend them selves to automation. Vinyl cnio.-irie <vc< is used primarily in the production of polyvinyl chloride (PVC), a resin which Is produced through batch processing. The conversion of the VC monomer into a polymer or copolymer is an Incomplete procem, Le_ not all of the monomer Is reacted. PVC Is fabricated by a variety of tech nicale*. Including extrusion, injection molding and calendering, to form a fin ished product that needs no further chemical handling. The vast majority of employees involved in the VC industry are employed by fabrication firms. Such firms range in sue from those with few employees and simple equipment to large plants involving many cmploytea and considerable capital Vinyl chloride (VC), a gma at ambient temperature and pnature, la a chlori nated hydrocarbon, which heretofon has been regarded aa having moderate liver toxicity. The Initial standard, contained In Table G-l of 1910.93, establlahed a celling value of 300 parts of VC per mil lion parts of'air. (2) The emergency temporary standant. On January 22. 1974. the Occupa tional Safety and Health Administra tion (OSHA) waa informed by the Na tional Institute for Occupational Safety nd Health <NIOSH> that the B. F. Goodrich Chemical Company had re ported thil laatha of ceteral of Its em ployees from a rare liver cancer (angio sarcoma) may have been occupationally related. As a result of this notification and alter consultation with NIOSH, and a jomt inspection oi the B. F. Goodilch plant by OSHA. NIOSH and the Ken tucky Department of Labor, a lact-fir.dmg hearing was announced on Janu ary 30. 1974 <30 FR 3874) and held on February 15,1974. Information obtained from this hear ing, particularly the preliminary reports of experiments conducted by Professor Cerare Moltoni of the Instituto dl Oncolocla. Bologna. Italy, demonstrated that vinyl chlonde Induced angiosarcoma in rats at levels as low as 250 ppm. and In other species at lucher levels. Experi ments performed at lower levels of ex posure were not completed at that time. Other testimony irom meaicr.l witnesses and NIOSH. and the results of autopsies, led to the conclusion that the Goodrich workers had angiosarcoma ot the fiver and that VC probably was the. causal agent in the angicsareomas observed. In post hearing comments, additional angiosarcoma deaths were reported among workers who had been exposed to vc in plant* operated by Union Carbide Corporation. Firestone Plastics Corpora tion and Goodyear Tire It Ruooer Com pany. Oh the basis of all Information avail able at that time, and Use fact that em ployee* were being exposed at levels around the experimentally observed ef fect level of 230 ppm. aa emergency temporary standard <ETS> waa promul gated otl April 3. 1974 <39 FR 12341) pursuant to section 6<c) of the Act. aa 29CFR 1910.93d. Tills standard reduced the permissible exposure level Irom a ceiling of 530 ppm to a 50 ppm ceiling, and established other requirement*, including, lor example, monitoring and respiratory protection. It waa expressly recognised that this standard limiting exposure* to a 50 ppm celling was a tentative. Interim standard, and that the whole question of exposure to VC would be considered mare fully in the light of additional information especially the results of experiment* which were known to be underway at On April 13.1974. Information and data were presented to representative! of OSHA. NIOSH. and the Environmental Protection Agency by the Industrial BioTest Laboratories, Northbrook. Illinois, concerning results of snlmol exposure studies with VC. These studies were sponsored by the Manufacturing Chem ists Association. Although only pre liminary in nature at that time, these results revealed that 2 out of 200 mice exposed to VC concentrations of 50 ppm for 7 hours a day. five days a week, for approximately 7 months, had developed angiosarcoma of the liver. <3) The proposed permanent stand ard. Based on the demonstrated evidence of VC's carcinogenicity in three smmal species (rats, mice and hamsters), and the substantial probability that VC had been the causal agent in uie cases of liver angiosarcoma found In workers both here and abroad. OSHA pronosed to ! - !91C.D2q and published a eompr~p.c"m-< proposal '39 FR 16896) on May ! D ' 07 ; to protect employees from ha:, rcLv of exposure to VC. The proposal ca'lril for limitation of employee exposure to vc to 'no detectable level." as measured v o. sampling and analytical method sqr-.nive to 1 ppm. with an accuracy of 1 inn *50 percent. The proposal also c-.lled for the establishment of regulated areas and limited acres* to such areas to au thorized persons. A requirement for monitoring of employee exposures was 'imposed, along with engineering and work practice controLs to be implemented when exposures over the detectable hunt were measured. Respiratory protection would - h^ve been required while engineering and ..-nrk practice controls were being implemented or where exposures exceeded me ,.cr- missmle limit even .ater fens.oie en gineering controls were instituted. In addition, the proposed standard included requirements for medical sur veillance. protective clothing, c.-.iriu'.cv procedures, training, specific protection during maintenance and decontamina tion operations, transportation loauing and unloading operations and -ccerd- kevptng. (4) Hearing an the yrovosal. The pro posal. as published on May 10. 1974. allowed 30 days for interested parties to submit written comments and to request an informal rulemaking hearing. In formal contacts with OSHA staff and early responses indicated that the sub- feet wag of great interest and Importance to many persons. Because at the limited time available before expiration of the .lx month period provided in section S'c)<3) of the Act for promulgation of a final standard. It was decided to huid a hearing as soon as possible. Accord ingly, ou May 24,1074, a notice at a hear ing was published (39 FR 18303>. setting a hearing date of June 25. 1974, The hearing was conducted from June 25 through June 23. and again from July 3. through July 11. before Administrative Law Judge Gordon J. Mymtt. All partici pants wen given the opportunity to pre sent testimony and to cross-examine other witnesses. Persons participating in the heftring were given until August 22. 1974, to file additional posthearing com ments. various items of infor mation which were requested during the examination of witnesses. <3> Economic and technical imoact study. During the hearing. OSHA deter mined that additional facts would be needed to determine the practicality of certain aspects of the proposed stand ard. Accordingly, OSHA contacted an in dependent consultant. Foster D. Snell Corporation, to conduct studies of the feasibility of compliance at various ex posure levels, including those proposed by OSHA and others advanced ay in dustry spokesmen. Snell was also com missioned to collect Information regard ing the economic costs of compliance. This action was announced at the close of the hearing, and Judge Myatt lur'.hcr announced that the record would be kept raeiAL uoistta. vol no. it*--mioay. octoaee *, 1*74 SL 106820 RULES AND REGULATIONS 33S91 open for & period of Umc beyond August 23, to allow interested persons to com ment In writing on die study. On Aueust 26, 1974, OSIIA aitaounced Unit the pre- mlnary study was available and that -ommenls were to be submitted no later than September 6. 1374 (39 PVt 3P844). On September 13, 1374. OSHA tamed comment* on both the preliminary and the final study, which was to be received on or before September 25, 1374 139 FR 33009). (6) Environmental impact statements. A notice of Intent to file an environmen tal Impact statement assessing the im pact of a proposed standard on occu pational exposure to VC was published In the Fezcast. Registt* on April 24. 1974 (39 FR 14522). The notice invited any person having taforma'tou or data on the environmental impact to submit It to 03HA by May 17, 13 74. On June 12, 1974. a droit environmental impact statement wm prepared and circulated to all Interested persons. Ten copies were forwarded to the Council of Environ mental quality iCEQ). which published 'a notice of it* filing and availability In the Fromai. Rican* on June 25. 1974 (39 FR 23975). A 45 day period was al lowed for the submission of comments on the draft statement. On September 5, 1974. the flnsl environmental impact statement wag prepared and a copy of it and aU substantive comments were sent to appropriate governmental agencies, private organisations, and other inter ested persons. CEQ published a notice of armliability for the final statement on September 6. 1974 (39 FR 32330). The .submission of comment was Invited un til September 25, 1974. The state ment and all significant comments have been carefully considered in arriving at the final standard on occupational expo sure to VC. (7) The record. Hie record tn this proceeding la one of the moet exhaustive ever relied upon by OSHA. It consists of pre and post-hearing comments and testimony received at both factfinding and rulemaking hearing!, the studies and lnspectlcps conducted by OSHA person nel. the environmental impact state ments, the economic and Impact studies, and all other relevant information. In all. over 80Q written com ments have ben received, with more than 200 separate oral and written sub- mlaolops made with regard to the two hearings- The recced Itself exceeds 4.000 pages. Employer*, employees, labor unions, public health groups, independ ent experts, physicians. research scien tists, and specialists la many fields have been invited to submit informstion and have made their views, knowledge and experience available to OSHA. The en tire record encompassing them submis sions was thoroughly reviewed and evaluated in reaching the determina tions set forth below. ' TL Findings regarding carcinogenicity, exposure levels and feasibility--at Car- dnogenicity ot vinyl chloride. The car cinogenicity of vinyl chloride for three animal species (rat, mouse, hamster) has been documented on tho record by the studios of Maltont and Bio-Test Labora tories. Moreover. Maltonl's investigations have demonstrated a dose-dependent re lationship for induction of tumors (i.c., more tumors occur at higher exposure levels', including angiosarcoma of the liver. In rats. The Investigations of In dustrial Bio-Test Laboratories have dem onstrated a similar relationship lor both rats and mice. These Investigators have induced angiosarcoma of the liver m rats and mice at exposure concentra tions of 50 ppm. and in hamster* at high er concentrations of exposure. Additional tumors involving other organs, including the kidneys, lungs, and skin of exposed animals, were also observed in frequen cies much In excess of control animals. The incidence of tumors m mice in the Industrial Bio-Test Laboratories investi gations is particularly pertinent. Of 200 mice (100 males, 100 females) exposed to 50 ppm of vinyl chloride by inhalation for eleven months. 100 died. Sixty-four ani mals died without gross postmortem pathologic examination being performed. Of the 36 remaining animals lor which a gross postmortem pathologic examina tion was performed. 13 (30 percent) were found with liver tumors (including angiosarcomas). 21 (59 percent) with lung tumor*. 9 (25 percent) with skin tumor*, and one-with a kidney tumor. According to the 1970 report by th* Surgeon General's Ad-Hoe Committee on the Evaluation of Low Levels of En vironmental Chemical Carcinogens, the if* two or znora species may be extrapolated to Indicate a carcinogenic haxard to humans. Here, such a finding was made In three species that were exposed to VC by inhalation-- a route comparable to employee ex posure. in addition, there were at least 13 confirmed coses of angiosarcoma of the liver among employees exposed to VC, a particularly significant number in view of the extreme rarity of this cancer in the U3. adult male population (testi mony of Dr. Marcus Key, Director of NIOSH, et the rulemaking hearing). Tb# Ql a*|4iiMtw4HI4 Qf t&| liver In both ********* i inrf exposed employees Is compelling evi dence that exposure of humane to vinyl chloride induces this turner. Industry spokesmen, at the hearing, conceded that VC is carcinogenic for humane (e.g. testimony ot Dr. McBumey, Rulemaking hearing. 1041). Accordingly, it le con cluded that VC must be regarded as a human' carcinogen, and the probable causal ftgw*fc of andosarcooia of Uio liver, and that exposure of employees to VC must be controlled. Additional evidence of tumor Induction in a variety of other organs, including lung, kidney, brain and skin, ss well ** non-malignant alteration*, such me fi brosis and connective tissue deteriora tion. ta'llfitf additional oncogenic and toxicologic properties of vinyl chloride, which must be considered in establishing control regulations. (See testimony snd results of studies by Bio-Test Labora tories. TOberahaw-Cooper. Maltoni, NIOSH. and Seiikofl.) (2) Exposure limits. Upon finding that exposure of employees to vinyl chloride may create a carcinogenic hazard, the amount of exposure which Is hazardous must be determined. The Surgeon Gen eral's Ad Hoc Committee referred to above concluded that safe exposure levels for carcinogenic substances cannot be scientifically determined. This position is supported by the testimony of NIOSH at the hearing. Its recommendations lor a standard of no detectable level, ana by the testimony of expert witnesses from the National Cancer Institute. Several witnesses and persons who sub mitted comments have taken a contrary view and have suggested that man is less sensitive to biologic aberrations Induced by vinyl chloride exposure than experi mental animals. Proponents of this posi tion have argued that If humans were as sensitive as rodents, on "epidemic" of cancer resulting from VC exposures should have already been discovered among employees. They also argue (ha: the employees in whom tumors have teen observed are those who have consiaeraule employment experience as polymeriza tion reactor cleaners. Because it is gen erally agreed that reactor cleaning in volved high enrosures to vlnjl chloride In year* post. It Is argued that the lower levels currently found m the workplace have not Induced cancer and are there fore safe. We reject this argument. The fact that approximately threequarter* of those employees with the longest exposure to VC (greater than 30 years sine* initial exposure) have not yet been located, mokes it Impossible to determine the actual number of affected employees. The cases of liver tumors ob served to date have on average latency period, since initial exposure, of app1-0x1raatety 20 yean. If it is assumed Unit in duction of angiosarcoma Is a dose-re lated phenomenon, end If employees en gaged in cleaning reacton did. in fact, receive larger doses of vinyl chloride, it would be expected that such tumors would be observed earlier for this em ployee population. For this reason, the significance of presumed lower doses cannot be accurately assessed until a laager period of time has paned. ss a longer induction period would be expected. Initiation of exposure to chemical carcinogens and induction of cancer are not necesasnly synchronous event*. Be cause of the physiologic complexities in volved with carcinogenesis, induction of tumors does not occur tn all employees with similar exposure histories. For ex ample, Dr. Schneiderman of the Na tional Cancer Institute emphasized dur ing his testimony that only about a fifth of longer-term heavy smoker* develop lung cancer. Accordingly, the Industry contention that exposure levels have been dramatically reduced since the 1940's' is not reliable evidence that cur rent levels of exposure are safe. Soma industry spokesmen also sug gested that the apparent nonrandom distribution of observed cancer tn em ployees may indicate an exposure thres hold for tumor induction, based on vena tions In the workplace design or prac tice and resultant employee exposures TIDItAl UOtsm. VOL IV. NO. 1*4--ntOAV, OCTOSI* 4. IVV4 SL 106821 33892 RULES AND REGULATIONS (testimony and questioning by Tenneco Chemicals. Inc.), It has also been em phasized that in only 3 of 8 polymerisa tion plants where employees have been exposed to VC lor more than 23 years have any employees developed angiosar coma of the liver. This argument is very similar to that raised concerning vari ability of past employee exposure. Al though geographic and workpracUce dif ferences may ultimately be demonstrated to be factors la distribution of angiosar coma. sufficient Information la unavail able to exclude from conalderatlon of risk thofh employees la workplaces for which cases of angiosarcoma have not been observed. It has also been suggested that the absence of cancer In a population of 339 Dow Chemical Company polymerization employees monitored over a period of 7 years. Indicates that exposure to vinyl chloride at concentrations of less than 200 ppm is sa;e. `See study by Dr. Cook, submitted at the hearing by Dow Chem ical Company.! However, the grouo sur veyed did not include all workers who had been exposed, and the missing em ployees Included many who had the longer term (over 20 years) exposures. Moreover, the statistically Insignificant size of the sample population decreases thj tbti tiMim-- would bo observed. Dow also presented preliminary data In testimony at the hearing an the pos sible metebode pathways of VC. The hypothesis peesmtid wag that VC may exert tu carcinogenic effect by a metals- ollte, and that the metabolite Is pro duced only whan VC to metabolised by a secondary metabolic pathway operating only when enzymes regulating the pri mary pathway are saturated, at would be the result at higher exposures. Tile preliminary data Uidlcatad the possi bility of an additional pathway for metabolism of VC in rats sxpoeed to con centrations of VC In wTM of 220 ppm. However, the occurrence .of "psarcoma in both rata and mice at VC exposure lumemi tlkam of SO ppm In dicates that if a metabolite of VC to the ultimate eardnoesn. then U must be generated at lower exposure oommnna tions in these tpemaa. AUhotmfc this re search may be helpful to the thorough uodcntiodini of tiu cMdttOUJnkdty of VC. It appears that U does not yet offer evidence which can amtot la determine tlon of safe exposure mmaniriUnns fag employees, or even that suolt safe ex posures exist. A number at witnesses representing employers have stressed that there to no evidence at cancer, either in employtae or experimental animals, at exposure concentration* of VC less than so ppm. (See e-g- testimony of Firestone. Ten neeo Chemicals.) The of these witnesses was that no dsebdoa can bo made TM~-'~"*"g risk of exposure to VC at concantratloxu lass than 90 ppm. On the other hand, the testimony of most expert witnesses. Including soma in dustry biomedical- experts, stated- that quantification of a safe exposure con centration la not possible with the pres ent state of scientific knowledge. (See e g., testimony of Selikoff. Firestone. NCL and NIOSH.) In our view, the demonstration of can cer Induction In humans at a particular level Is not a prerequisite to a determina tion that a substance represents a can cer hazard for humans at that level. It would be Imprudent to assume man to be less sensitive to VC exposure than ex perimental animals in the absence Of conclusive evidence. It would also be un founded to assume that m(mfti will not develop tumors when exposed at concen trations of VC of leas than 10 ppm. Should a sufficiently large number of ex perimental be exposed to VC at concentrations of lews then SO ppm. Sctwetderman said that It would be ex pected that some would develop VC in duced tumors. (3) Feasibility. There 1s virtually no dispute that most. If not all, fabricators are currently capable of reaching ex posure levels of l ppm through engineer ing controls. These employers employ well over 95 percent of all employees ex posed to vc. Indeed, several fabricators are already operating at this level (see SPI testimony). However, Industry spokesmen have universally claimed that It Is infeasible for the VC and the FVC Industries to remain below 1 ppm con sistently. using engineering controls. In addition, the Snell study on technical feasibility concluded that a 1 ppm cell ing to not feasible for the VC and PVC Industries with present technology, but that the VC Industry eould curatly st rain lower exposure levels than the FVC Industry. Labor union spokesmen and the Health Research Oroup. me., however, have suegestad that such a level to at tainable. Since there to no actual evidence that snv of the VC r PVC manufacturers have already attained a 1 ppm level or in fact instituted ail `available engineering and work practice controls, any estimate as to the lowest feasible level attainable must neeenarliy involve subfeetlve judg ment. Likewise, the projections of indus try. labor, and others concerning feasi bility are essentially conjectural. Indeed, as Firestone has suggested, it to not Poe- sible to accurately predict the degree of Improvement to be obtained from en gineering changes until such rhsngss ere Mtmllv ImlcBnttd. We agree that the FVC end VC estab lishments win not be able to attain a 1 ppm TWA level for all job clseiidratlona In the near future. We do believe, how ever. that they will. In time, be able to attain levels of l ppm TWA for most jab classifications most of the time. It to ap parent that reaching such levels may re quire some new technology and work practices. It may also be necessary to utilize technology proandy used in other industries. In any event, the VC and FVC industries have already mode great strides In reducing exposure levels. (See wwMwiy at Vow Chemical Co- TR 973). For example. B. F. Goodrich testified (TR 1120) *nx it hoe reduced avenge exposure levels In several PVC plants from 39--to ppm early this year to 13-12 ppm at rim-- of the hearing. We are confident that Industry will continue to do so. (4) Conclusions. The conclusions be low are based on a thorough review and evaluation of all the evidence tubuutted. Whore decisions can be based on record evidence, this has b'en done. Where, however, factual certainties are lacking or where the facts alone do not provide on answer, policy judgments have been made. There Is little dispute that VC to car cinogenic to man and wo so conclude. However, the precise level of exposure which poses a hazard and the question of whether a "safe" exposure level exists, cannot be definitively answered on the record. Nor is it clear to what extent exposures can be feasibly reduced. We cannot wait until indisputable answers to these questions are available, because lives of employees are at stake. There fore. we nave had to exercise our best judgment on the basis of the oein avail able evidence. These judqmenu n.-vo re quired a balancing prccess. In which t.ie overriding consideration has been the protection of employees, even thO'e who may have regular exposures to vc throughout their working lives. Based on the available evidence end In view of the above considerations, includ ing feasibility, we believe that employee exposures to VC must be reduced to a 1 ppm time-weighted average (TWA). We also boilers that PVC and VC establish ments will, in Urns, be able to attain that level through engineering controls, and that fabricators can do so hi the lm-. mediate future. ___ I In addition ro the TWA requirements we have established a 5 ppm cciiinx (averaged over a 13-mmute period) in order to prevent exposure of employees to unacceptable high excursions. Trim nn operation starn^nmt. this ceiling level is realistic because minor excur sions up to the celling level are likely to occur on a regular bests. IXX. The/Inal standard--<l) Scope and application. Both the ETS and the pro posal would apply the standard to the entire VC Industry. Including manufac turers of VC and PVC and fabricators, bat eeeinoiHf employers handling or using fabricated products mode from VC. There to no dispute that a standard to required tor the monomer end polymer lndustzlm. However, the Society of Plas tics Industry (SPI) and various fabrica tors (saa testimony of Goodyear. Gen eral Cable. etcJ recommended that fabricators be excluded from the stand ard. or that a separate requirement be established for them because- many of them were already at or below the propoeed eelllngieveL The record evidence establishes that at toast same employees in the fabricat ing industry are expwed In excess of the permissible control limits (See NIOSH testimony, TR 106; Robintech TR 642). In these circumstances, we believe that it Is imprudent to grant a blanket exemp tion for all fabrlmtoR. Therefore, the final standard to applicable to the fabri cation industry, ss well se the monomer FtosaAt uotm*. voc j, no. ise--wuoat. ocraam 4. i*re SL 106822 rules and regulations 35S93 and polymer industries. Employers who. temperature as PVC. for further pro below the action level, no further moni in fact. are suOstantlallv below the. ex cessing, indicates that a potential for re toring 1* required Unless the employer posure limit will be subjected to only lease of the residue still exists. It ap has reason to suspect that any employee minimal burdens by virtue of the "action pears that the exemption of fabricated Is exposed In excess of the action level, lever' to be discussed belbw. products should be limited to Just those or unless changes have been made :n Where employers In the fabricating Items winch will not undergo such mass production, process, control, type of resin, industry have exposures approaching the heating. Further, the opportunity to etc. permissible limit, they will appropriately demonstrate that exposures are below Where the exposure level, without re be subject to the standard. Employers the action level, and thus, discontinue gard to respirators, exceeds the permis handling or using fabricated products many duties of the standard, provides a sible levels, monitoring must be conduc made of PVC were not included in the more positive control and an adequate ted at least monthly. Where exposures ET3 or the proposal and are excluded relief. are less than the permissible levels, but from the Anal standard. This conclusion (2) Permissible exposure limit. The greater than the action level, monitoring is based on the absence of actuate evi standard sets on exposure limit ot 1 ppm must occur at least quarterly. dence of expoaure to VC In these opera averaged over any 8 hour period, and a (5) Methods ol compliance. The stand tions. The final standard clarifies the ex ceiling of 5 ppm averaged over any per ard, like the'proposal, requires that em emption by defining a fabricated prod iod not exceeding 15 minutes. ployers immediately institute feasible uct as a product made wholly or partly As more fully discussed above, this engineering and work practice controls from PVC which does not require further limit is based on an evaluation ot the best to reduce exposures to at or below the processing at temperatures, and for available evidence and on a judgment permissible exposure limit. times, sufficient to cause mass melting of that the health and safety of employees Where feasible engineering and work the PVC. SPI and others <cf. TR. 344) must be protected to the fullest extent practice controls will reduce exposures requested that PVC resins with less than feasible, in view of the fact that release below the permissible levels, thev must 0.1 percent residual monomer be ex of VC In the VC and PVC manufacturing be instituted. Where such controls v. :il empted from the regulation now, and processes are- variable, the 1 ppm ceiling not reduce exposures below the permis that the exemption level be reduced to level provided in the proposal would sible level, they must nonetheless be im o.oi percent in three years. SPI suggested require maintenance of an average level plemented to reduce exposures to me that the exemption of materials with less significantly more difficult to attain lowest practicable level, and be supple than 0.1 percent of 14 carcinogens from through feasible engineering controls. mented by the use of respirators to pro 38 CPU 1910.03p (39 PR 3756) was an Therefore, the exposure limit prescribed vide the necessary protection. There appropriate precedent. The cases are not m the proposal has been rejected. upon, a continuing program of engineer comparable, because no attempt had been made to set air concentration limits for the 14 carcinogens. Tha record did not include Information that reliable moni toring and measuring techniques were available. Moreover, the exemption did not exempt airborne traces of carcino gens. The administrative cutoff was pro (3) Action level. The final standard, unlike the ETS and the proposal, pro vides for an "action lever* of 0.5 ppm TWA. one-half of the permissible ex posure limit. Tha purpose of the action level la to minimm the impact of {he standard on the employers who have attained exposure levels well below the ing and work practice controls must be Instituted to reduce exposures to the low est practicable level. When exposures are at or below the permissible exposure limit*, the program may be discontinued. In addition, a plan for achieving con trol by engineering and work practice methods must be drawn up and be made vided to avoid regulation of materials permissible limit. Thus, where the re available, upon request, to represent about which there was no health haz sult* of monitoring under paragraphs atives of OSHA and NIOSH. ard information, and which would have (d)(1) or (d)(3) demonstrate that no We recognize that many employers broadly extended the application of the employee is exposed In excess of 0.5 covered by the standard con not cur regulation beyond the record. Herein, ppm TWA. employers may. in effect, be rently achieve compliance with tlir. per no information was presented to show exempted from some provisions of the missible exposure limit solely by the use safe concentration results from the use standard. For example, fabricators who of feasible engineering and work practice of resins with specific levels. Indeed, the are below the action level are not re controls. The record also reflects broad proposal to change the level later, when quired *o provide medical surveillance or generic distinctions between the compli improved technology would permit such to monitor again, unless the employer ance capabilities of the VC and PVC reduction, would seem to Indicate that has reason to suspect that any employee industries. Some industry spokesmen, SPI has doubts about the safety of 0.1 is exposed in excess of the action level. including SPI (TR. 333-382), recom percent reabtae leveL Diamond Shamrock In our Judgment, exposures below the mended that a schedule of different per- (Exhibit 143) testified that there is no action level do not present a sufficient mistUe exposure limits and compliance direct relation. They Indicate that the hosord to warrant application ol the en dates be established for the VC and PVC airborne concentration is more related tire standard to the many employers who segments of the Industry. to tha physical form of the ream and ore or will bo below that levoL This view summerthat the ability and the ventilation provided. Also, monitor (4) Monitoring. The final standard, the time required to feasibly reach in ing data from industry (ef. Exhibits 131, llks the proposal, raqulros that Individual creasingly lower control levels is similar IBS, 170) and OSHA (Exhibit 131) lndl- employee exposure levels be determined. within each industry, but differs mark cata that levels in mas of 1 ppm may This may be accomplished by personal edly between industries. While the record be found id fabrteetion operation*. In or area monitoring. Some witnesses and does suggest that such differences do view of thee* facta and of tho opportunity persona who submitted comments did exist between industries, as noted above, for employers to discontinue many dutlaa not understand tha meaning ot the term it is clear that intra-industry differences upon a showing of no expaeuree above the "93 percent level" la the also exist. Tius, the ability and time re ration level. It does not appear that any proposal. Essentially It means that the quired by each employer to attain lower residua exemption it either justified or employer is required to take a sufficient control levels may depend upon such neceomry at this time. This course also number of measurements *o that the re factors os the climate In which the plant agrees with a mwwhee of industry pro sults an statistically valid. We Is located, the age of equipment, the size posals (cf. TR #60). have modified the proposal to establish of reactors, or the type of resin manu SPI (TR 343). ament others, asked that compounded PVC pallets be ex empted from the standard on the grounds that tha pellets had too low a residua to cause harmful or measurable emissions. While It appears that PVC pellets would have a lower residua level than virgin PVC, the fact that the pellets must be heated to a molten mas* at the same accuracy range requirements for various measurement levels. These rongee are narrow enough to ensure that a deter mination of compliance can be made, and broad enough to allow the application of a variety of technologies AH covered employers art required to conduct initial monitoring. Where moni toring amt mM*llrtT|g results are at or factured or used. (Snell study. Firestone testimony, etc*) Monitoring data also tends to support such Intra-industry variations. (See. e g. Dow. Firestone. Tenneco.) As noted above, the standard requires ail employers to institute feasible engi neering controls to the fullest extent and to continue to improve and apply engi- FlDOAl UOimt, VOL If, NO. 194--SttOAV, OCIOBt* 4. 1974 SL 106823 33894 RULES AND REGULATIONS ncermg controls until lull compliance Is If the environmental level Is not con trations. In discussions of there findings achieved. trolled to the permissible exposure limit, with NIOSH. It has Indicated that it is We hove not established any deadlines then employees must be afforded respira willing to consider on on expedited basis lor lull compliance through engineering tory protection. the approval of air-purifying respirators control# because we are presently unable while exposures In excess of the per for use against VC. Consequently, we to determine when It will be feasible lor missible level do constitute a hazard, we have included three types of ilr-punfy- most establlslimenLs to reduce exposure believe that It is necessary to mitigate ing respirators In the list of acceptable levels to the permissible level. some of the problems associated with units, subject to the approval of such We also believe that the requirement Implementing a program of respiratory units by NIOSH. The maximum concen that each employer reduce airborne con protection while employees are being tration for which each respirator may centrations to the permissible level, or fitted and trained In respirator use. and be used is based upon our evaluation to the lowest level /risible as soon as while other adjustments which may be of the data submitted by NIOSH and practicable will provide lor Inter-indus required are Implemented. Therefore, Goodrich. Because sir-punfytng respi try and intra-industry technological dif until January 1, 1979, where exposures rators do not indicate sorbent exhaustion ferences which do exist, and will avoid are not in excess of a 23 ppm ceiling, or breakthrough of VC. and because vc the setting of separate Industry stand each employer must provide each em has no inherent warning properties at ards on the basis of the general situation ployee with on appropriate respirator. levels for which these devices ore used, and conditions in each Industry. However, employees whose exposures do strict administrative controls will be re (S) Regulated areas. The proposed not exceed a 23 ppm ceiling, may decline quired for their use. Such controls In standard would have required that regu to use the respirator, in which cose the clude a program to assure timely re lated areas be established, that access be employer is not obligated to require its placement of canisters or cartridges and limited to authorized employees, and use. During this adjustment period, cm- nil alarm system tn alert employees v r.ei; that daily rasters or summaries of those rioyees will be trained r.i the uses, iiur- vinyl chloride concentrations evewd tne entering be kept for at least 20 yean. In poses and limitations ol respirators, and concentrations allowed for the pai,v.c,i- objection to these requirements, it was the hazards of exposure to vinyl chloride. lar type of respirator in use. asserted that such control ol r cress was Moreover, each amployee will be notified 13) Hazardous operations. This is a not necessary from a health standpoint. Secondly, it was claimed that these con trols would interfere with operations by preventing access of needed employees or In writing if he has been exposed tn ex cess of the permissible exposure limit. Where exposures exceed a 23 ppm ceil ing, respiratory protection is mandatory new section within the final standard. It encompasses essentially the proposal's requirements for maintenance and de contamination but has restated them hi non-employees, such as contractors, truck drivers, customers end consultants. The purpose of establishing regulated areas tn the proposal was to limit the In light of our judgment that much -terms of performance language to allow greater risks are twortstert with such greater flexibility for employer* to deal exposures. with such operations. The intent of the The provisions in the final standard new section la to protect employee* en risk of exposure to as few employees as retarding the selection and use of respi gaged tn activities that present a risk of possible, This concern is still paramount, ratory protective dsvtcsa differ from expoeura to vinyl chloride In excem of the sad thus the limited srrem feature re those In the proposal. The descriptions of permissible levels. An example would be mains. The final standard amends the proposal slightly to allow "authorized persons" to enter n-yaiated area*. This change. It Is felt, will allow operations to atmosphere-supplying respirators haws been revised to Indicate more dearly the types of devices intended, and the maxi mum permissible concentration level for the cleaning of a filter when resin con taining high residual monomer is trapped. The propomTi requirement for full- continue without undue interference. The final standard has also increased the length of time daily rosters must be maintained from 20 to 30 rears. This each defied. Moreover, the number of types of atmosphere-supplying devices has been increased. At the hearing Mr. Edwin C. Hyatt, an body, Impervious clothing has been re placed by the direction to use impervious garments suited to the particular .simatica and probable extent ol exposure. change was based largely on epidemio OSHA consultant, made suggestions re Thus, full-body clothing is not always logical considerations. (See NIOSH testi garding the use of particular respiratory necessary, and la therefore not required mony, tr. no.) dsvtcsa. We have concluded that his sug where less protection is adequate. Since <T) Rerptratanr protection. The final gestions arc meritorious. Therefore, the vessel entry- falls within the definition standard, like the proposal requires the ptoviiions for mlcetion of atmoeohem- of a hazardous operation, the vessel entry use of raepUMcra where employee expo supptytnx derleee fellow docsly the roe- action of the proposal has been deleted sures exceed the permissible control level COUbUMd 1ft bit ttttt* fnnttaifl&ilittft(tftfd Industry representatives made e number many of 8FX and B. T. OoodrtchJ <TR <9) emergency situations. The defini of objections to proposed requirements with Hyatt's augnsoeno <8es ex testi tion of emergency haa been recast. in for respiratory protection. They stated mony of SPI and B. T. Goodrich) (TR terms af an unexpected massive release. that the "no detectable level" would af S3 m We had originally omitted alr- The mam abjection to the section on fectively require continnone weerms of purlfytng respirators became none bad emergency situations in the proposal was respirators a pVC sad VC plants, aad been approved by NZOSH far use against *a the term was defined, many that this is not feasible became respira tors are cumbersome, preaant a safety hazard, and luiploysw won!" not use thorn 7C* piindpiily btcsoM they in* dicetorn to signal the expiration of the wrote* life of the sorbent. Hyatt and Atiiv witnesses discussed in Hetait Hie ordinary leaks or operations resulting in a "--n release of vinyl chloride would be considered emergencies. This was not the intent of the proposal. The final We would agree that respirators have many drawbacks: the pennant did not wiptwipld yhyft ee n lltwl TtM record shows that the FVC industry par ticularly may need several years before plant environmental levels can be re duced so that respirators are necessary desirability of being able to use canisters or cartridge air-purifying respirators, provided a sorbait could be shown to affectively absorb vinyl chlnrtdo with an adequate service Ufa Recently, OSHA haa received respiratory data from labo ratories regarding the effaettvanese of standard has been clarified to correct thit ambiguity. It should be noted that the written operational plan required by the standard need not be developed for mini- excursions above the permissible exposure limit, and that such excursions need not be reported. only occusionally. However, we cannot i-wihii--hajiw available canistan and (10) Signs and labels. The thrust of the agree that respiratory protection should cartridges for vinyl chloride. These eval signs and labels section is to apprise not be required simply beetuaa It Is in convenient. may require additional per sonnel. interfere* with production, or may require extensive renaming of em- uations were conducted separately by NIQSH ud by the B. P. Goodrich com pany and submitted to OSHA in post hearing rtmnant*. The results indieste employees of the cjuicer and fire haz ards. No objections have been raised with respect to Informing employees of the fire hazard. However, a number of ob jections were raised at the hearing and aloyees and restructuring of work prac- that certain presently available canis In written submissions to the require -lcts- We have carefully considered all ters and cartridges effectively absorb ment that the word "cancer" appear on the objections, and Have concluded that vinyl chloride at relatively low concen all signs and labels. The principal argu- Hoauo. Momm. vot. jv. no. ive--swbav, ocroam a ivr SL 106824 RULES AND REGULATIONS 35S93 ment advanced against Its use was that Indicated that the medical tests proposed posal Ls the requirement for maintenance the term "cancer" or "cancer-suspect are currently the only ones available of monitoring records and daily roster agent" scares employees and that In which are useful for medical surveillance sheets of authorized persons for 30 years. stead, the message should contain In <TR 121. Exit. 93. TR 589-591). Conse Instead of 20 years. Additionally, the em structions on how to deal with the sub quently, the specific blood tests proposed ployer is required to maintain medical stance iTR. 3471. We believe that a have been retained as a minimum re records for the duration of an employee s diluted form of warning will not suffice. quirement to assist the examining physi employment plus 20 years, or 30 years, We appreciate the concern of employers cian In determining fifties* of potential whichever Is longer. The original pro with the reaction of their employees. But employees for assignment to workplaces posal called for only 20 years. we consider it Imperative that a worker involving VC exposure. In addition, al This change has been implemented be be fully Informed, and that he realize the ternative medical examinations may be cause the latency period for induction of possible risks Involved in his occupation. used where the examining physician de angiosarcoma ranges up to 30 years from Coupled with the training requirement termines that they are at least as good initial exposure. Therefore, as a mini In the standard, we believe that the signs as those specified by the standard. mum. medical records must be main and labels required will adequately in The Tabershaw-Cooper study and the tained for at least that long. It should be form employees of the hazard. In addi various animal experiments suggest that noted that spokesmen for both labor and tion, such signs will warn unauthorized VC may produce a wide spectrum of ma Industry recommended that this change personnel to keep out of regulated areas. lignant and non-mallgnant disorders. be made. Tlie proper application of most protec The general scope of the required medical The reporting requirement* are not tive measures requires an amount of examination has. therefore, been broad significantly different from those in the training and Indoctrination of employees ened to include kidneys, skin, connective original proposal. However, instead of that cannot easily be conveved on a sign tissue, spleen, and pulmonary system, as the requirement for reporting incidents or label. Also, the variety of measures well as the liver. No additional specific which result in the release of VC into that couid be prescribed would result In procedures or tests are required, but rec areas where employees may be exposed, an unwieldly or excessively detailed leg ommendations have been included in the the final standard clarifies our original end. Consequently, the required message Appendix to assist the examining physi intent by stating that only emergencies on signs and labels will not Include in cian. Because of the nonspecific nature must be reported. Also the requirement formation on precautions, relevant of the required medical tests, it Is not for filing a detailed, written report symptoms, etc. The addition of suitable appropriate to prescribe timing, or type within 15 days has been deleted. It has Information by the employer would be of followup tests, or to mandate with been concluded that submission, within permitted, providing it does not detract In any way from the required statement. The requirement in the proposal for labeling containers of vinyl chloride has been amended by deleting the reference to the possible hazard of violent polym drawal from exposure based solely on re sults of the tests. Instead, the employer is required to obtain a statement from the examining physician of the em ployee's suitability for continued expo sure. when the mmintne physician has 24 hours, of an initial report that in cludes facts Immediately available, would ordinarily be sufficient. However, if the OSHA Area Director request! further in formation relevant to the emergency, the employer will be required to furnish such erization. Very little Information wag completed such tests at he consider* ap Information. developed on this hazard during the standard-setting procedure. It does ap pear that this hazard is essentially under control end that the Are and carcino genic hazards at present are the most significant. Since labeling or placarding that Is in compliance with the 0.3. De partment of Transportation regulations <49 CFR Part 173. Subpart H> already warns of the fire hazard, only a state ment concerning the carcinogenic haz ard need be added to the Department of Transportation labels. propriate. The employer Is required to withdraw an employee only when this statement indicates that the employee may be at added risk from continued VC exposure. As with monitoring, there appears to be no basis for complete exemption of the fabrication industry from the require ment for medical examination. The rec ord doe* *bow fabricating establishments with concentrations of VC monitored considerably above the action level, in these iritem-et. medical surveillance of (14) Deleted portion* of the proposal. The proposal contained provisions re quiring that shower facilities end change rooms be provided, and that storage or consumption of food be prohibited in regulated arena. We have deleted these provision* because it ls our conclusion they are no longer necessary. Showenrfadlitle* are not required because pro tective clothing, where required by the final standard, should protect employees from skin absorption by direct contact with VC end became there i* no reliable (U) Medical lurvttUanot. The princi affected tmnloyeee will provide baseline evidence that VC vapor ls absorbed pal questions that have been relied re data for future evaluation of their health, through the akin. In addition, since we garding medical surveillance are the even If both monitoring and medical sur anticipate that most employee* will not nacenlty and efficacy of requiring cer tain specific serum marine determina tions (8MA-13 series) and the applleajwt A mmUmI wtHwdHiW tfiTilrai veillance are discontinued because im proved controls reduce concentration! below the action level. Where expoeuree are below the action level, the medical be wearing protective clothing and that employees who wear protective clothing will cHenge such clothing infrequently, we are not requiring that change rooms menu to the fabrlcetlon segment* of the surveillenca requirements do not general be provided. industry where employee* are izpoeed to ly apply. In eAfitttot we feel that there la In- lower levels of VC. The obleetton has also <131 Trnintno. A separate provision for adaquate evidence showing that hazar been raised that the specification of tests employee training baa bean added to the dous of VC can be absorbed and procedures Interferes with the ap final standard rather than including it through Ingestion. For this reason, the plication of advances In medical knowl edge. A particular difficulty In considering medical surveillance Is that the moat commonly discussed lesion, angiosar coma of the liver, currently cannot be diagnosed until the victim Is terminal and. usually, within months of death. Precursor physiologic alterations, which might be reversible, have not yet been directly sssodated with the lesion. Con sequently. there are no specific diagnos tic tests which can be prescribed whten will determine presence or absence of this tumor at an early stage of develop ment However, meet medical witnesses within the section on emergency situa tions ae in the proposal. The new para graph provide* for training of employees concerning the carcinogenic hazard of VC. emergency procedure!, the need for monitoring and an annual review of the standard. It also provides for training of employees concerning the purpose for, proper use of, end - connected with respiratory protection. (13) Records and report*. The provi sions for recordkeeping contained in the final standard require the preparation and maintenance of essentially the same information required by the proposal. The major change from the original pro requirement prohibiting the storage or consumption of food in regulated areas hM tetQ rifUrtftd. The proposal also contained provisions on malntentence and decontamination, transportation loading and unloading. mnrt polymer handling operations. These requirements are not mentioned in the final standard because attention to these Items ls Implicit In the requirement that each employer reach the permissible ex posure limit or attain the lowest feasible level. (15) ZOtctlv* dot*. In order to ensure that affected employer! and employees will be Informed of the existence of these SL 106825 nMZAl IMISIB. VOC JV, NO. 1V4--RIDAV. OCTOtB *, IV74 35896 RULES AND REGULATIONS provisions and that employers affected of the operation or bcetiuse of an acci opportunity to observe the monitor are given an opportunity to familiarize dent in the operation, which would result ing and measuring required by thy themselves and their employees with the in an employee exposure in excess of the paragraph. existence of the new requirements, the permissible exposure limit. <e) Regulated area. (1) A regulated effective date of the amendment to (81 "OSHA Area Director" means the area shall be established where: I 1910.93q will be January 1.1073. To pro Director for the Occupational Safety (1) Vlnvl chloride or polyvinyl chloride vide continued protection for employees and Health Administration Area Office Is manufactured, reacted, repackaged, until that date, the provisions currently having jurisdiction over the geographic stored, handled or used: and contained in i 1910.93q are hereby urea in which the employer's establish (11) Vinyl chloride concentrations are promulgated, pursuant to section 6(b), ment Is located. in excess of the permissible exposure fife) and (c) at the Occupational Safety (9) "Polyvinyl chloride'* means poly limit. and Health Act, as an occupational vinyl chloride homopolymer or copoly (2) Access to regulated areas shall be safety and health standard effective mer before such Is converted to a fsbri- limited to authorized persons. A dally October 4, 1974. the amendment to cited product. roster shall be made of authorized per 119l0.93q set out below will supersede (10) "Vinyl chloride" means vinyl sons who enter. these provisions as of January 1. 1979. chloride monomer. <f) Methods of compliance. Employee Accordingly, upon consideration of the (C> Permmible exposure limit. (1) No exposures to vinyl chloride shall be con whole record of this preceding. Part 1910 employee may be exposed to vinyl chlo trolled to at or below the permissible ex- of Title 39. Code of Federal Regulations ride at concentrations greater than 1 ppm posure limit provided in paragraph (c> is amended, effective January 1. 1973, by averaged over any 8-hour period, and of this section by engineering, work proc - revision of i I910.93q to read ss follows: (3) No employee may be exposed to tiee, and personal protective controls as 1910.93<t Vui>l tiiloride. vinyl chloride ot concentrations greater follows: than 3 ppm aver?ved over any period not (1) Feasible engineering rui -e- : (a) Scone, and application. '1' This exceeding 15 minutes. " ' ~ 1 practice controls shall immediate!? bo section includes requirements for the T3) Jfo employee may be exposed to used to reduce exposures to at or bclow control of employee exposure to vinyl vinyl chloride by direct contact with the permissible exposure limit. chloride (chloroethene). Chemical Ab liquid vinyl chloride. (2) Wherever feasible engineering and. stracts Service Registry Mo. 73013. <d> Monitoring. (1) A program of work practice controls which can be In (3) This section applies to the manu Initial monitoring and measurement stituted immediately are not sufficient to facture. reaction, packaging, repackag shall be undertaken in each establish reduce exposures to at or below the per ing. storage, handling or use .of vinyl ment to determine if there is any em missible exposure limit, they shall none chloride or polyvinyl chloride, but does ployee exposed, without regard to the use theless be used to reduce exposures to not apply to the handling or um of fabri of respirators, in excess of the action the lowest practicable leveL and shall be cated products made of polyvinyl chlo leveL supplemented by respiratory protection ride. (3) Where a determination conducted in accordance with paragraph < g> of this (3) This section ippllee to the trans under paragraph (d)(1) of this section section. A program shall be established portadon of vinyl chloride or polyvinyl ahowa any employee exposure, without and Implemented to reduce exposures to chloride except to the extent that the regard to the use of respirators, in ex at or below the permissible exposund Department of Transportation may cess of ths action level, a program far de limit, or to the greatest extent feaslblfl regulate the hexards covered by this sec tion. termining exposmm for each such em ployee shall be established, such a pro solely by means of engineering and won? practice controls, os soon as feaaiuie. 0 Definition. <n "Action level" gram: (3) Written plans for such a program means a concentration of vinyl chloride (i) Shall be repeated et least monthly shall bo developed and furnished upon of 0.3 ppm averaged over an t-hour work where any employee is exposed, without request for examination and copying to day. regard to tha use of respirators, in ex authorized representatives ot the Aril. - (3) "Assistant Secretary'" means the cess of the permissible exposure limit. tont Secretary and the Director. Sucn Assistant Secretary of idw for Occupa ill) Shall be repeated not less man plans *hii bs updated at least every six tional Safety and Health. tJJ. Depart quarterly where any employee is exposed, mrtg.tR- ment of Labor, or his designee. without regard to tha um of respirators. (g) Respiratory protection. Where (3) "Authortmd person" means any In excess of the action lereL respiratory protection is required under person specifically sutboritsd by tha em OH) Hoy be discontinued for any em this section: ployer ulnae duUee require him to enter ployee only when at least two consecu (1) The employer shall provide a a regulated area or thy person entering tive monitoring dstarminations. made not respirator which meets the requirements such in eve -- ---*- ripl millle less than 3 wotking day* apart, show ex of this paragraph and shah assure that trve of employees for the puipuae at ex- posures far that employee at or below ths employee usee such respirator, except erehtog an opportunity to nhssra mien the action levsL that until December 31. 1979, wearing of <41 "Director-^mSuna"uis^Dtreetov, (3) Whenever there has ben a pro duction. process or control change which respirators shall be at the discretion of each employee for roasnraa not In ex. National institute for Occupational may result in an Increase in the relemee cess at 23 ppm. mcMfad over any lTf Safety end Health, OH. Department of of vtnyl chloride, or the employer has UnunoagwBPsFTrTirx- Health. Education. and Welfare, or bis any other reason to suspect that any em- each employee who chooses not to wear plOjfM may bf fgpottti IQ HKtti of t&l an appropriate respirator shall be in (3) "Emergeney" -- any occur action leveL a determination of employee formed at least quarterly of the hazards rence such as. but not limited to. equip exposure under paragraph (d) (l) of this of vinyl chloride and the purpose, proper ment failure, or operation of a relief de section shall be performed. use. and limitations of respiratory vice which is likely to, or does, result In (4) The method of monitoring and devices. massive release of vtpyl chloride. measurement shall have an accuracy (2) Respirators shall be selected from (6) "Fabricated product" -- a (with a confidence level of 93 percent) of among thaw Jointly approved by the product mads wholly or partly tram not less than plus or minus 30 percent Mining Enforcement and Safety Admin polyvinyl chloride, and which docs not from 0.23 through 03 ppm. plus or minus istration. Department of the Interior, require further pTM--i..y at tempera 39 percent from over 0-3 ppm through end the National institute for Occupa tures. and for Mt"-- sufficient to cause 1.0 ppm, and plus or minus 23 percent tional Safety and Health under the pro mass malting of the polyvinyl -Rin-M- over 1.0 ppm. (Methods meeting these visions of 30 CFR Part 11. resulting in the release of vinyl chloride. (7) "Hazardous operation" m--m any operation, procedure, or activity where a release of either vinyl chloride liquid or gee might be expected as a consequence accuracy requirements art available In the "NTOSH at Analytical Methods'*). (3) Onnlaram ot thetr designated rep resentatives shall be afforded reasonable (3) A respiratory protection program meeting the requirements of I 1910.134 shall be established end maintained. (4) Selection of raprestore for vinyl chloride shall be as follows: nnmAL iisum vol ov, no. i i i wmsv. ocraan A tare SL 106826 RULES AND REGULATIONS 33807 XlmoipAxrlo eonetntratton of uinfl chloriOo (i) Unknown. or Mon s.eoo ppm- (11) Not ota l.MO ppm_______ ,,,, (id) Notonr 100 ppn_______ (It) Not onr It ppm. (t) Not ota 10 pp Xtquirtd apparatus Opoa-circuiL. nlf-coototood brssthing apparatus, prseura damud typo, with full facaplaos. (A) Combination typo C suppUsd ulr rapottar, pm. out dsmaod typo, witb lull a naif faeaplsew. and auxiliary aalf-contalnae air supply; or (B) Typo C. suppUsd sir respirator continuous flov typo, with lull or bait Iscapiseo. and auxiliary ell-contained air supply. (A) Combination typo C suppUsd air respirator de mand typo. Wlta lull lacopMoo. and auxiliary orsell-contained air supply; <B) Open-circuit sail-contamed breathing apparatua with tun lacepiece, in demand mode: or (0) Type C supplied air respirator, demand type, with lull tacaplooe. (A) A powered alr-purllylnf respirator with hood. helmet, lull or hall taoepleee, aud a canister which prondos a terries Ule at at laast 4 hours lor conesnrationa ol nnyl chiorlda up to 26 ppm. or (B) Qaa maia. rroot- or back-mounted canister which protldea a lemoe lila ol at laast 4 hours for concentrations ol yinyl chloride up to 2$ ppm. (A) Combination type C supplled-alr respirator, da. mand type, with hall facepiece, and auxiliary sell-contalnad air supply; or (B) Type C supplled-alr respirator, demand type, with hall laceptaee; or (O) Any chemical cartridge respirator wtth an organic taper cartridge which prwridaa a semes Ule of at least 1 hoar tor eotmtnaitlnpi ol tlnyl chlottds up to IQ ppm. (5) (1) Entry Into unkown concentra (3) Protective garments thall be pro tions or concenttattane greater than vided clean and dry for each use. 36.000 ppm (lower explosive limit) may (I) Emergency litttationi. A written be made only Tor purpoeee ol liie rescue; operational plan for emergency situa il*4 tions shall be developed for each facility (ID Entry into concentrations of Isas storing, handling, or otherwise using than 30,000 ppm. but greater than 3.800 vinyl chloride es a liquid or compressed ppm may be made only for purpoeee of gas. Appropriate portions of the plan Ufa rescue, firefighting, or securing shall be implemented in the event of an equipment so ax to prevent a greater emergency. The plan shall specifically haxard from release of tlnyl chloride. provide that: (> Where air-purifying respirators (l) Employees engaged in hazardous are used: operations or correcting situations of ex (1) Air-purifying easnlstam or car isting bamrdouo releases shall bo tridges shall be replaced prior to the equipped ae required in paragraph (h) expiration at their eerttee life or the of this section; end ef the shift in which they are first (3) Other employees not to equipped used, whichever ocean first, and shell evacuate the area and not return (11> A continuous monitoring and until conditions are controlled by the alarm system shall be provided where method! required In paragraph (f) of concentrations of vinyl eniamfr could this notion and the nmgluey is sbated, (ration for*thideTtomatn uwo^Buchox^ (J) Tririnfay. Each employe* engaged in vinyl chloride or polyvinyl chloride -rm thall hi iwed to atari employne eliwi operations shall be provided training in vinyl ahmeWto MwmwttoM. Um a program relating to the heard! of allowable nontwntrmtlona for the devicee in am (7) Apparatus preecri'-ad for higher coneentratloos may be used far any lower vinyl chloride and precautions for its safe use. (1) The program thall include: (1) The nature of the health hsxanl from chronic exposure to vinyl chiorlda (h> Hmordows operation*. (1) Em ployees engaged In haxardout operations, including entry of vessels to ci--n poiyvinyl chloride residua from vessel walla, shall be provided end required to wear and use; lncinditif specifically the cardoceanic hazard; (U) The specific nature of operations which could result in exposure to vinyl ehintirfa m excess of the permissible limit end necessary protective steps; (I) Respiratory protection in accord (U) Hie purpose for. proper use. end ance With paragraphs (c) and (g) at llmitetione of respiratory protective this section: end (II) Protective garments to tnevrat skin contact with liquid vinyl or with polyvinyl chloride reridtw from reseat walls. The protective ferments devtea; (lv) The fire hazard and scute toxic ity of vinyl chloride, end the necessary protective steps: shall be selected for the operation and (v) The purpose for and a daartptlan Us* possible exposure conditions. of the monitoring program; (vt) The purpose for. and a descrip tion of. the medical surveillance program: (vil) Emergency procedures: (vtil) Specific information to aid the employee In recognition of conditions which may result in the release of vinyl chloride: and i (lx) A review at this standard at the employee's first training and indoctrina tion program, and annually thcreatter. (3) Ail materials relating to the pro gram shall be provided upon request to the Assistant Secretary and the Director. (k) ATcdteal tvrveillance. A program of medical surveillance shall be Insti tuted lor each employee exposed, with out regard to the use of respirators, to vinyl chloride in excess of the action level. The program shall provide each such employee with an opportunity tar examinations and tests in accordance with this paragraph. All rr.eo.ical ex aminations and procedures snail be per formed bv or under the supervision o: a licensed physician, and shall be provided without cost to the employee. (l) At the Ume of Initial assignment, or upon institution at medical surveil lance; (I) A general physical examination shall be performed, with specific atten tion to detecting enlargement of liver, spleen or kidneys, or dysfunction in these organs, and for abnormaltlss in skin, connective tissues and tne pulmonary system (See Appendix A). (II) a medical history shall be taken, including the following topics: (A) Alcohol intake: (B) Past history of hepatitis: (C) Work history and past exposure to potential hepatotoxic agents, includ ing drugs and chemicals; (D) Past history of blood transfu sions: and (E) Past history of hospitalizations, (lit) a serum specimen shall be ob tained and determinelions made of: (A) Total bilirubin: (B) Alkaline phosphatase: (C) Serum glutamic oxalacetic trans aminase (SOOT); (D> Serum glutamic pyiurie transam inase (SOFT): and (1) Gamma glustamyl transpeptldase. (3) wvw--<vtiTM provided in accord ance with this paragraph shall be per formed atleast: (i) Every 8 months for each employee who haa been employed in vinyl chlo ride or polyvinyl chloride manufacturing for 10 yean or longer; and (U7 Annually for all other employees. (3) Each employee exposed to an emergency shall be afforded appropriate medical surveillance. (4) A statement of each employee's suitability for continued exposure to vinyl chloride including use of protec tive equipment and respirators, shall be obtained from the examining physician promptly after any examination. A copy of the physician's statement shall be pro vided each employee. (g) If any employee's health would be mafriaiiw impaired by continued ex- poeure, such employee bau be witn- SL 106827 IMIStm, VOL 30, NO. 1*4--mOAT, OCTOMt 4, 1*74 33898 RULES AND REGULATIONS drawn from powble contact with vinyl tion which contradicts or detracts from 'll) Tli- number of employees in each chloride. the effect of. any required warning, regulated area during normal opera tions. <S) Laboratory analyse* for all bio information or Instruction. Including maintenance. logical specimens Included in medical 'ml Accords, il) All records main (2) Emergencies, and the facts ob examinations shall be performed In labo tained in accordance with this section tainable at that time, snail be reported ratories licensed under 42 CFR Part 74. shall Include the name and social secu within 24 hours to the OSHA Aren Di (7) If the examining physician deter rity number of each employee where rector. Upon request of the Area Direc mines that alternative medical examina relevant. tor. the employer shall submit additional tions to those required by paragraph (21 Records of required monitoring Information in anting relevant to the (kill) of this section will provide at and measuring, medical records, and au nature and extent of employee exposures least equal assurance of detecting med thorized personnel rosters, shall be made and measures taken to prevent future ical conditions pertinent to the exposure and shall be available upon request for emergencies of similar nature. to vinyl chloride, the employer may ac wmiimtlftB and rftppny to authorized (3) Within 10 working days following cept such alternative anmmntinna as representatives of the Assistant Secre any monitoring and measuring wmch meeting the requirements of psrmgraph tary and the Director. HUrin that any employee nas been (kill) of this section. If the employer U) Monitoring and measuring records exposed, without regard to the use of obtains a statement from the examining physician setting forth the alternative examinations and the rationale for sub stitution. This statement shall be avail shall: (A) State the date of such monitor ing and measuring and the concentra tions determined and Identify the instru respirators in escess of the permissible exposure limit, each such employee shall be notified in anting ot the results of able uuen request ler examination and ments and methods used: the exposure measurement and the steps copying to authorized representatives of a) Include any additional informa being taken to reduce the exposure the Assistant Secretary and the Director. ( Siam and labels. Ui Entrances to regulated areas shall be posted '.nth leg ible signs bearing the legend: CAMoa-SoeracT Aarwv Am acthowb Ptaeuewu. ovtv tion necessary to determine Individual employee exposures where such expo sures are determined by means other then Individual monitoring of employees; and (C> Be maintained for not less than within the permissible exposure limit (o) Effective dates. <u Until Janu ary 1, 1975. the provisions currently set forth in 1 191Q.93q of this Part shall apply. (2) Areas containing hazardous oper ations or where an emergency currently exists shall bo posted with legible signs bearing vhs legend: 30 years. ill) Authorized personnel rosters shall be maintamed for not leu than 30 yean. (ill) Medical records shall be main tained for the duration of the employ ment at each employee plus 20 years, <21 Effective January 1.1275, the pro visions set forth In 1 1910.33q of tins Part shall apply. miimm a sumuinnat itcsica Xavoa*ATBM> or 30 yean, whlcbew Is longer. When require! test* uniter paragraph (3) In the event that the employer (k)(l) at tau aaunnn enow showmanttw. (3) Contslnetx of polyvlnvl chlorido re*tn waste from reaeton or other waste contaminated with vinyl chloride shall be legibly labeled: eeasee to do and there is no suceemor to fwaive and retain his rec- eras far the prescribed renod. these rec ords shall be transmitted by regi'-tcrcd the teat* should be repeated as soon aa prac ticable. preterably within S to 4 TMti U testa remain abnormal, consideration should given to withdrawal of the emplcro lui-n contact with vinyl chloride, while a atom Contaminated with Vistl Cxumc CAOCte-OoaMXl Mon (4) Containers of polyvinyl chloride hall be legibly labeled: Potnisn Cxunsi (oe Tlus Sue) contains mall to the Director, end each cmpicree individually notified In writing of this transfer. U) Employees or their designated representatives shall be provided access to examine and copy records of required met flifftnir*??. eontpreheaeive examination ta r...i- Additional teat* which may be c.ieful- A. Por kidney dyaluncilon: unce . urnuc- flop for albumin, rtd Mood erh- foliauve abnormal etna. h. pulmonary eyttem: Forced tiu. m:,..'. lty. Forced expiratory volume it i nrt cheet roentgenogram iposcerlor-antenor, (3) Former employees shall be pro 14 x 17 losae*>. vided mcecss to exemlne and copy re C. s-Mwwei eemm taete; Lactic add de (5) Container* of vinyl chloride : quired monitoruig and measuring records nialog--. lassie add dahvditigecaae be legibly labeled either: U) vsnt Cae Cism-SMM 1SBR or (ID In accordance with 4* ent Part 173. Subpert H. with the additional legends: reflecting their own exposures. (S) Upon written requmt of any em ployee. a copy of the medical record of that employee shall be furnished to any phytitiaa py the employee. (a) Reports. (1) Not later than 1 month after the ---1'11-*----* of a reg ulated area, the following Information ihftU bt rtnorfd to tbi Am Dl laoenryme. protein aetermiosuom. and protein mul lupine eele D. per e more eomprabenalve examination on iipeeien abnormal unun teste: Hepatitis antigen, and liver wanning. (Sew. and . M Stas. 1394. ISM 129 UA.C. (SI. HT): Secretary of Labors order No. 12-T1.3* TO f7S4) . Signed M Washington, D.C.. this 1st CurczB-smrac* Amort rector. Any changes to such information day of October, 1274. applied near the leber or placard. shall he reported within 13 days. <l) The address and location of each (S) No statement shall appear on or establishment which has one or more John Sixmou. ater--r Secretary of Labor. near any required sign, label or Instruc regulated areae: end [TO Doc.74-22178 Filed 10-l-7t:3;S4 pm| VOL 3V, NO. If iv. octom s, im 106828 Sl> SL 106829 Vinyl Chloride Monomer Safe Handling Guide DOW CHEMICAL U.S.A. AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY CHEMICALS AND METALS DEPARTMENT MIDLAND, MICHIGAN 48674 AREA HEADQUARTERS OF THE DOW CHEMICAL COMPANY DOW CHEMICAL U S A.............................................................................. DOW CHEMICAL LATIN AMERICA...................................................... DOW CHEMICAL EUROPE. S. A ... DOW CHEMICAL PACIFIC LIMITED...................................................... DOW CHEMICAL CANADA INC.............................................................. DOW QUIMICA, S A. . ...................................................... . MIDLAND. Michigan 48674 CORAL GABLES, Florida 33134 . .8810 HORGEN, Switzerland .......... P.O. Box 711, HONG KONG SARNIA, Ontario, Canada N7T 7K7 .........................SAO PAULO, Brazil SALES OFFICES OF DOW CHEMICAL U.S.A. ATLANTA ................................................Suite 2005, 20 Perimeter Center East. Atlanta, GA BATON ROUGE ........................................... Suite 400, 2900 West Fork Drive, Baton Rouge, LA BOSTON ................ Wcstborough Office Park, 1800 West Park Dr , Westborough, MA CHARLOTTE .......................... Suite 200, 5727 Westpark Drive, Charlotte, NC CHICAGO Suite 800, 10 Gould Center, 2850 Golf Road, Rolling Meadows, IL CINCINNATI . Northmark Business Center, 10123 Alliance Road, Cincinnati, OH CLEVELAND ...................................................................... 14955 Sprague Road, Strongsville. OH DALLAS................................ .................... Suite 1025-Lock Box 18, One Galleria Tower, 13355 Noel Road, Dallas, TX DENVER Suite 310, 6025 South Quebec Street, Englewood, CO DETROIT .................... Suite 415, Travelers Tower, 26555 Evergreen Road. Southheld, MI GRAND RAPIDS.................... .................. ... , Suite 301, 2100 Raybrook S E , Grand Rapids, Ml HOUSTON.................................. .... 400 West Belt South, Houston, TX INDIANAPOLIS ,, .................. 9550 N. Zionsville Road, Indianapolis, IN KANSAS CITY Corporate Woods, Suite 160, 10890 Benson Drive, Shawnee Mission, KS LOS ANGELES.......................... ............................................................ Suite 110,17870 Castleton St , City of Industry, CA MEMPHIS. ... .., . . Suite 330, 6055 Primacy Parkway, Memphis, TN MINNEAPOLIS ....................................................11100 Bren Road West, Minnetonka, MN NEW YORK ,, .........................Park 80 Plaza East, Saddle Brook, NJ PHILADELPHIA ...................................................... 505 S, Lenola Road, Moorestown, NJ PITTSBURGH .......................... , , . , . Suite 1313, Four Gateway Center, Pittsburgh, PA RICHMOND ..................................... Suite 415, 8002 Discovery Dr., Richmond, VA ROCHESTER.. ............ ............................................. ................. 400 Perinton Hills Office Park, Fairport, NY ST LOUIS .......................... .................. 450 University Club Tower, 1034 S Brentwood Blvd St Louis, MO SAN FRANCISCO ............................... 2800 Mitchell Drive, Walnut Creek, CA SEATTLE .................................................................. Suite 522, 600-108th N E . Bellevue, WA TAMPA . . . Suite 450, 5100 W. Kennedy Boulevard, Tampa, FL 30346 70827 01581 28210 60008 45242 44136 75240 80111 48076 49506 77042 46268 66210 91748 38119 55343 07662 08057 15222 23288 14450 63117 94598 98004 33609 404-394-4141 504-293-2222 617-898-3720 704-525-9030 312-228-2700 513-793-6200 216-826-6000 214-387-2211 303-740-9300 313-358-1300 616-949-9000 713-978-3700 317-873-7000 913-451-2000 818-810-8050 901-767-5000 612-938-4300 201-845-5000 609-234-0400 412-281-3030 804-288-1601 716-425-1200 314-726-5000 415-944-2000 206-455-7250 813-877-8300 NOTICE: Dow believes the information and recommendations herein to be accurate and reliable as of February 1987, However, since any assistance furnished by Dow with reference to the proper use and disposal of its products is provided without charge, and since use conditions and disposal are not within its control, Dow assumes no obligation or liability for such assistance and does not guarantee results from use of such products or other information herein; no warranty, express or implied, is given nor is freedom from any patent owned by Dow or others to be inferred. Information herein concerning laws and regulations is based on U.S. federal laws and regulations except where specific reference is made to those of other jurisdictions. Since use condi tions and governmental regulations may differ from one location to another and may change with time, it is the Buyer's responsibility to determine whether Dow's products are appropriate for Buyer's use, and to assure Buyer's workplace and disposal practices are in compliance with laws, regulations, ordinances, and other governmental enactments applicable in the jurisdiction(s) having authority over Buyer's operations SL 106830 Printed m U.S.A. Trademark of The Dow Chemical Company Form No. 102-233-87 PILING INSTRUCTIONS: OjUAt V/u^ i KEYWORDS: _J