Document QkYa27zj8ZREqBLr1JKneM6Z5

ICI Americas Inc. fi d C t I V c U 3 JUL 1 o lyo^ Legal DR. R. T. GGTTP.'vViAfy Department July 10, 1984 Roy Gottesman The Vinyl Institute Division of SPI 355 Lexington Avenue New York, NY 10017 Dear Hr. Gottesman: Per our telephone conversation, I am enclosing a copy of the U.S. Department of ilabor Memorandum dated October 23, 1975. Although the letter appears incomplete, Mark Duvall was advised that this was the entire letter. Very truly yours, Melford F. Tietze Environmental Counsel 071084KDR01 Enclosure Wilmington, Delaware 19897 Phone (302) 575-3000 SPI-00849 Subjects Enforcement of \finyl Chloride Standard With Respect to Low Residual Monomer Resins. QSBR has received nuzaarous inquiries from suppliers* of "* -certain resins which conta In a very low amount of residual \ - vinyl chloride monomer, re^uestlng an exemption from the labeling requirements of tie vinyl chloride standard, ----- 29 CFR 1910.1017. Some of these suppliers have asked that th*ir products be regarded es "fabricated.products" under 29 CFR 1910.1017(b)(6) vhidh would exempt'them from the requirements of the standard Although such resins are i -- not "fabricated products" v ithin the meaning of tho standard, some degree of discretion njust be used in -.enforcing the standard with respect to tfa|e labeling of such resins. | A fabricated product is a product in its final, useable and recogniteable fora vhici does not require further processing at temperatures and for times, sufficient to cause mass melting of polyv nyl chloride resulting in the release of vinyl chloride, These resins are not e product} in their final useable fora and therefore may not be in- | eluded in the fabricated prcduct exemption. However, when there is no realistic possii lity that employees handling or using these rosins will t|e exposed to concentrations of vinyl chloride in excess of 25 ppa in the absence of engineering controls, we wil not cite their employer for failure to comply with the libeling requirement* of the standard because there is no direct and immediate relation-- ship to the health of the em; iloycos. SP1-00850 T The federal standard is a rigc rous program which applies to all manufacturing employees in every state and provices uniform, nationwide right-to-know coverage. Its adoption and enforcement by states eliminates the patchwork inconsistencies among states which have adopted their own laws without close adherence to this federal framework. The federal standard provides >rovisions for the following: * written hazard conunication program * labels and other ] onus of warning * material safety d; ta sheets (MSDS) * employee informatio n and training * trade secret prote ction In summary, The Society of the lastics Industry believes the Federal Standard is a comprehensive hazard communicat on and right-to-know program for manufacturing ~p 1 o yees and encourages its adoption by all states. SPI-00851 T