Document O1qDaKxJEY24goorvEmK5K521

'lFotP0tfoa ^ INTEROFFICE DATE OCTOBER 21, 1974 to MR. T. C. WALKER FROM R. S. EROOKMAN REFERRING TO LETTER OF SUBJECT ORC MEETING WASHINGTON. D.C. - OCTOBER 17. 1974 ami*. I attended subject meeting in Washington, D.C. on Octob r'T17, 197^. The intended purpose was to allow industry representatives to question OSHA officials in regard to interpretation of the new permanent standard. Representing OSHA were: Mr. L. Cox - Stender's Industry Liaison Man Mr. F. Kuckenbecker - Office of the Solicitor Mr. Grover Wren - OSHA Office of Standards Mr. R. McClure - OSHA Office of Regional Programs '* Industry was represented by the following companies: Belden Corp. Olin Corp. American Can Co. Union Carbide Diamond Shamrock Western Electric Allied Chemical Dayco Corp. DuPont Armstrong Cork B. F. Goodrich Goodyear Tenneco After participating in 2# hours of questioning of these OSHA people, one can only conclude that they really do not recognize the huge number of problems associated with the permanent standard they have created. Regardless of the acceptable VCM levels, which we were told was not a subject for debate at this meeting, the ambiguity in the language of the standard and its unstated impli cations leave industry at the mercy of the local compliance officer. The OSHA people present acknowledged these facts and offered the following consultation: A. They will publish some corrections shortly (which ones were not stated;. B. They are now writing program directives which give guide lines to compliance officers. These documents will be made available to the general public. received OCT 25 1974 OCC 0512 f. f hoy -2- C. They claim they will he promptly responsive to questions on interpretation in writing directed to: Mr. Barry White Associate Sec. For Regional Programs OSHA Department of Labor Washington, D.C. 20210 Listed below is a sampling of questions asked and the OSHA responses: 1. What is meant by a non-regulated "Fabricated Product?" Response: Any fabrication operation* regardless of temperature employed* is controlled by the standard if it results in the release of VCM above the "action" level. 2. Do containers for fabricated scrap designed to be reworked (such as calender tailings) have to be labelled as a "Cancer Suspect Agent?" Response: Don't know, will investigate. Is continuous monitoring* as required by the standard* the same as continuous* sequential monitoring? Response: Don't know, will investigate. 4. Are other manufacturing facilities and offices within the same industrial complex as the the PVC plant that may on occasion (due, for example* to weather inversions) go above the action level of 0.5 ppm subject to the provisions of the standard? Response: When you get your levels in the PVC plant down to 1 TWA and 5 ceiling, this should not be a problem. In the interim, we don't know, will investigate. 5. Are outside contractors, coke machine service men, etc. who enter a regulated area subject to the provisions of the standard? Response: Don't know, will investigate. 6. Can clockcards be used for the purpose of the roster requirement? Response: Tea. occ 0513 -3- 8. Do the training provisions of the standard apply only to people working in a regulated area? Response: No, they apply to everyone within an industrial complex who may he potentially exposed to levels above the action level. (To me this means all 3500 people in Pottstown are affected.) 9- When will NIOSH approve canister? Response: Hopefully, before November 1, 1974-. 10. How will OSHA respond when they discover that industry cannot possibly get sufficient masks and canisters by January 1, 1975? Response: Use air supplied respirators (they are available) until you can get masks and canisters. 11. How do you explain the incongruity of the table related to types of respiratory protection--particularly with regard to the allowance of half face pieces at high VCM levels and full face pieces at lower levels? Response: It's a difficult job to describe respiratory equipment. The table is incomplete and we f OP.TT h> 'S wi 1 1 ar\Trsafnwo vn ^w - -r-- f*- ,< W4UV V ^ *. `A V UL.V 1 /wivia /* 4- if V ^ VV V ^ V S 12. How do you dispose of VCM saturated canisters? Response: Don't know. 13. Must empty bulk trucks and railcars that contained PVC be labelled as containing a "Cancer Suspect Agent?" Response: Yes. RSB:djs cc: Mr. C. J. Kleinert (2) Mr. R. A. Park Mr. J. J. Cassidy Mr. W. B. Connolly, Jr. Mr. G. D. Lloyd R. S. EROOKMAN OCC 0514