Document OExdz1JXj4b8zrJ4Ra1ymB2VX

Eo ,_^. sznv; I '*1 !.sn f) - , ALLIED CHEMICAL CORPORATION / tLL&iz: WFS_ / "GK ` MEMORANDUM received by NOV 7 1374 J. M. QUINN / WCK. V X ;V i ,L_ "stT _ *rjn" i 'J LLS To; works '"product' I TICKLE SuLHL To N c j vombor 1 , 197 4 If'' r\Lw T'-H'fVs 1 r i a 1. Chemicals Division riivisnm JV/ - F4.*e liminnry Guidelines lor Compliance with Vinyl, Chloride Occupational Health Standard Subject to modification as we develop experience, we will observe the following guidelines lor compliance with OSHA standard 1910.93q which becomes effective January 1, 1975: \i. 1 Action Level - "Action Level" moans a concentration of vinyl chloride of 0.5 ppm averaged over an 8-hour work day. The standard does not make it clear whether the action level means any one 8-hour day, or a typical 8-hour day. With respect to operating areas, we will consider it to mean any 8-hour day. B.5 Emergency - "Emergency" means any occurrence such as, but not Tu7t limited to, equipment failure, or operation of a relief device which is likely to, or does, result in massive release of vinyl chloride. We will interpret this literally as meaning equipment failure or o per:;. I ion of a relief device' by extending the definition of equipment failure to include vessel or pipeline failure. AST 00023938 B.6 Fabricated Product - - "Fabricated. Product" means a product made wholly"or parily from polyvinyl chloride, and which does not. require further processing at temperatures, and for times, sufficient to cause mass me I t .i ng of the poly vinyl chloride resulting; in the release of vinyl chloride. This exclusion hypothetically does not cover such acti vities as maintenance or construction welding of PVC. Until we receive further guidance, we will assume that PVC welding when done occasionally under field conditions does not .in toma 11 ca 1 1 v brim; the operation under t ho standard . However, shop welding, it conducted ovoi` a po i' i od ot lour hours or more, will cither require moni -- tori nr, ol t lie individual's work atmosphere, or the wen rim; oi air-snppi ird respirators. Fi. 7 Ha/.ardous Operation - "lla/.ardous Operation" means any opera tion, procedure, or activity where a release oi' either vinyl chloride liquid or pis might be expected as a consequence o1 the operation or lu ;ause oi an accident in the operation, which would resu ' t m an employee exposure in excess oi t4ie permissible exposin' : limit. In the monomer and film plants we believe that this defi nition should be limited to activities involving tank or vesscL entry and to loading and unloading liquid vinyl chloride. C.l and 1. 2. C. 2 Permissible Exposure Limit No employee may be exposed to vinyl chloride at concen trations greater than 1 ppm averaged over any 8-hour period, and No employee may be exposed to vinyl chloride at concen trations greater than 3 ppm averaged over any period not exceeding lb minutes. It has been pointed out that, in the absence of con tinuous monitoring, it is impossible to establish with certainty whether or not a given individual has been exposed to concentrations in excess ol C> ppm over a brio! time period such as l;i minutes. Bearing in mind that this is a problem tor both ourselves and the Com pliance people, we will assume for the time being- that, il the individual's exposure over 8 hours is 1 ppm or less, the eeiIing is also being complied with. Oitr inability to comply with the coiling would then become a matter lor the ("ompltanee Ollicer to. demonstrate with iiis monitoring equi pir.cnt. D. Monitoring *- Because of the lengLh oi the text, we refer you to the standard. It will he our procedure to apply this section literally. Please note Hat this reference is to exposure of speci fic employees, hence persona. 1 monitoring is the preferred method. Area or grid monitoring may be used once it has been established that the results are consistent wii.h personal monitoring data. AS I 00023939 E. Regulated Area 17 A' regu i a ta ai area shall be e.s t a b ! l s bed where: (i) Vinyl chloride or polyvinyl chloride is manufactured. reacted, repackaged, stored, handled or used; and ( ii ) Vinyl chloride co neon f ra t ions are m excess of the permissible exposure limit. 2. Access to repula fep areas shall be limited to authorized poisons. A daily roster shall be made of authori/.ed persons who enter. Monitoring studies may establish that either or both plants are generally below the action, level, except when certain activities are being performed, or alternately that exposures in excess ol the permissible level arc1 con fined to a specific portion of the plant: e.g. exposures at Pottsv.il Je may exist only while trucks are being unloaded. If is also conceivable that exposures at Baton Rouge can, now or in the future, be Limited to Loading and unloading operations involving liquid vinyl, chloride. In such cases, and relying on the precedents established in the carcinogen standard, regulated areas may be tem porary in nature and confined to certain small geographic boundaries. Under these conditions there should bo an appropriate signal to indicate that the area is operating under regulated conditions, the outlines of the regulated area should bo clearly marked, and unauthorized persons should be excluded. E. 2 Daily Roster - Access to regulated areas shall bo limited to aut lioiv iTTAd^pc rso ns . A daily roster shall be made of author ized persons who enter. Altho'.vgb we have been informally advised that OSIIA had in mind ^procedure involving emplovees' signing in or out of the area, practice has shown this to be unwieldy and unduly cumbersome in the case of regularly assigned employees. We believe that ike intent of the regulation will be served equally well by procedures which derive such rosters from payroll or time distribution sources, and are prepared to defend this position. F. 3 Written Plans - Written plans for such a program shall bo deV7iV,ped nVid furnished upon request for examination and copying to authorized representatives o! the Assistant Secretary and the Director. Such plans shall be updated at least every six months. Particular attention is directed to this item. Wo have no desire to defend complaints of aL1eged non-compliance with other sections of the regulation if we are not in strict compliance' with all recordkeeping requirements. AS I 00023940 4- G.l Ri'-'P i rr. torv Protect inn - The employer .411011 provide a res pirator which mewls tin' requirements ot this paragraph and shall assure tint the employee uses such respirator, except t ha t unt. i. 1 December hi. lD7b, wearing ol respirators shall he at thee dice ret lou oi teach employee lor e p >sures not in (exeess ol it ppm. measured over any lb-minute period. Until December 4 1. !h/b. each employee' who chooses not. to wear an appropriate respirator shall he informed at least quarterly of the hazards ol vinyl chloride and the purpose, proper use, and limitations of respiratory devices. Please note that over the first year the standard pcihnits the wearing if respirators on a voluntary basis unLcss a ceil in;; value cf 2b ppm is exceeded, and except during hazardous opera tions. G.4 (Please see standard) Wc have informal information that the Table contained in G.4 will be revised in light of information which has more recently come to the attention of OSHA. Wc also have information that NIOSII lias not yet certified any specific type of cartridge or cannistcr for vinyl chloride service. Ponding- clarification of this issue, we believe it appropriate that all personnel in the monomer plant, and those personnel in the film plant who have potential exposure to vinyl chloride, should be provided with personal hnLf-mnsk respirators equipped with cartridges certified for organic vapors and acid gases. In addition, a reasonable number of lull-face gas masks, with cannistcr mooting the above specifica tion, should also be provided for emergency use at those points at which significant excursions may be anticipated. G.G Ai r-Pr.r i f v i ng IU'sp i ra tors - Where air-pur if;. ing respirators TTrc used: (i) Air-purifying cannisters or cartridges shall bo replaced prior to the expiration of their service Life or the end of the shiit in which they arc first used, whichever occurs first; and (ii) A continuous monitoring and alarm system shall be pro vided where concentrations of vinyl chloride could reasonably excis'd the allowable concentrations for the devices in use. Such system shall bo used to alert employees when vinyl chloride concentrations exceed the allowable' concentrations for the devices in use. AS I 00023941 Please note Unit ro n l i nuous mmiilor 111^ and alarm systems arc requ i rod only il Ur,' company elects to use airpurifying res p 1 rn t ors or gas masks. It. is not required L i; protection is provided by air-supplied units. Neither should it 011 contused with reporting r eq , 1 rciuo n t s implied by Section 1) of the standard. (See below) Kmergencv Situations - A written operational plan tor omori^o'iTcV _s~i t~u a t i "(Tits' "sTia 1 1 be developed tor each facility storing, hand tin;;, or otherwise using vinyl chloride ns a liquid or compressed gas. Appropriate portions of the plan shall lye implemented in the event of an emergency. The plan shall specifically provide that: (1) Employees engaged in hazardous operations or correcting situations ol existing hazardous releases shall be equipped as required in paragraph (h) of this section; (2) Other employees not so equipped shall evacuate the area and not return until conditions are controlled by the methods required in paragraph (f) of this section and the emergency is abated. Note that a written emergency plan is required. This should be developed and on file before January 1, 1975. Training- - Each employee engaged in vinyl chloride or poly vinyl ~chlori do operations shall be provided training in a pro gram relating to the hazards of vinyl chloride and precautions for its safe use. IVc have been informally advised that it is not OSlIA's intent that irrelevant items be included in a given employee's training program. However, if the employee's job indicates, omission of relevant material would becomo a violation. Please note again that training aids and written materia 1.must be maintained in a fashion suit able for compliance inspection and transmission to the Labor Department. Medical burvoi11 a nee - A program of medical surveillance si in" 1 TinT: 1 s t! Ui t e d~" for each employee exposed, without regard to the use of respirators, to vinyl chloride in excess of the action level. '1 he program shall provide each such employee with an opportunity for examinations and tests .in accordance with this paragraph. All medical examinations and procedures shall be perlormed by or under the supervision of a licensed physician, and shall be provided without cost to the employee ASI 00023942 o We uihI(']'s La nd that. most plants liavr elected to include in the ),!c;| urn 1 Mu u v e i i j a ;u:o program nil employees direc tly e np aged :n net ivi ties involving vmyl chloride wile t'ner or not the exposure is in excess nl the notion limit. Vie tx'liev' it prudent to emit mm this policy tor the toroseeable Luture; howiiuii', demo ns t. i'n t io n that a given ('uiployee exposure has been consistently below the notion lovel wtui I d make' i, t possibLe to avoid some oi the reoordkeep i tip requirements. With respect to Section K. 1, questions have been raised as to the willingness, or even the Legal authority, Lei1 exami in ng; physic'inns to make unqualified statements regarding suitability tor employment. In response to these questions, we have prepared sample physician's statements to be used where appropriate, which we believe meet the intent of the standard, without unduly jeopardi zing the examininp physician. PLcase note that these arc1 sample statements only, and the wording may be modified by the examinin'; physician to suit his needs. Sample Alternate Physician's Statements for CompTT a nc e w Pt h V TTPP1 C~hT7Pr-i de St a nda rd 1. "Based on diagnostic information available to me, I see no evidence of impairment of your health which might be aggravated by occupational expo sure to permissible levels of vinyl chloride." 2. "Based on diagnostic information available to me, I do not believe that your continued exposure to vinyl chloride is advisable until we have arranged for further medical test inn; and evaluation." (Add physician's instructions for ioLlow-up examination.) 3. Statement (1) plus: "However. I have noted other medical conditions which lead me to recommend that your perse-.-.;. i_ physician. Please call me back so that we -can discuss the results of your examination." 5 Signs and Labels - Containers of polyvinyl, chloride resin waste I roiti reactors or other waste contaminated with vinyl chloride shall be legibly labeled: Contaminated with VINYL CHLORIDE CANCER-SUSPECT AGENT. Section E.3 could include scrap film destined to be romo1 tod. A similar concern has been expressed by Armstrong cork regarding scrap iloor tile. We under stand that OSHA intends t.o issue a clarifying1 statement regarding materials oi this nature. Pending clarifica tion wo wil 1 assume that tin.: labeling, requirement as staled docs not apply. AS I 00023943 M . Hi;cm'(is l. T,mpl oyees or t Ikm ' u- signated representatives shall Ik; pm- vided across to examine and copy records of required moni tor i nr. a nd moasu i-1 nr; . 5. Former employees shall be provided access to examine and copy required monitoring ami measuring record-, reflecting their own expose, vs. Please note that Section M.d and f> give employees or their representatives t: lie rip lit to examine a nd copy monitoring and measurin': information. N.1 (1) Reports >nrt~TaTer than 1 month after the establishment of a regulated area, the folLowing information shall be reported to the OSHA Area Director. Any changes to such information shall be re ported within 1 f> d a y s ; (i) the address and location of each establishment which has one or more imprinted areas; and (ii)The number of employees in each regulated area during normal operations, including maintenance. It is mandatory that, on or before February 1, 1975, the OSHA Area Director be advised as to what regulated arenas exist, and the number of employees who normally work in such areas. It is sufficient to state that we have established a regulated area at a given street address, and that a given number of employees arc involved. It is unnecessary to further describe the area itself. N.2 Emergencies - Emergencies, and the facts obtainable at that time",' shaTl be reported within 2d hours to the OSHA Area Director. Upon request of the Area Director, the employer shall submit additional information in writing relevant to the nature and extent of employee exposures and measures taken to prevent future emergencies of similar nature. We believe that telephone notification, supported by a memorandum to file, constitutes an adequate report unless further information is later, requested by OSHA. N.3 Written Notice to Employees - Within 10 working days following any monTioritig and measuring which discloses that any employee has been exposed, without regal'd to the use of respirators in excess of the permissible exposure limit, each such employee shall be notified in writing of the results of the exposure measurement and the steps being taken to reduce the exposure to within the permissible exposure limit. ASl 0023944 This section states that omp J oyuc^ sha! i be1 notiiicd in w n L in1'- u[ i, h" '.`(-suits of Llii- exposure measurement and the sU'pM bo i an, taken to reduce the exposure to within the permissible exposure limit. Unless we receive a contrary interpretation, we will interpret tliLS as relleetine, toe results of the monitorin'1, conducted under Section I). rather than continuous monitoring con ducted under Section G. W. S. Ferpuson WSF : nm Addressees: Industrial Chemicals Division Mr. J. M. Quinn Mr. II. Nclcpovitz Mr. P- B. Cornell Fibers Di vision Mr. W. L. Su11ivan Mr. R. J. O'Leary Mr. H. Rosenblatt ASI 00023945