Document RpKX1jLgGj7Y99rzxDGvkzK68

-I ' i * A Division of The Society of The Plastics industry, Inc. RECEIVED JUllS'88 Route: July 12, 1988 Copy: TO: The VI Health, Safety & Environment Committee and pj|e; Additional Attendees of the June 29th Meeting RE: OSHA PEL Revisions/Ethvlene Dichloride BACKGROUND The Occupational Safety and Health Administration proposed June 7th a rule to amend its existing air contaminant standards or set new standards for approximately 400 substances. Relative to EDC, the proposed rule would adopt the NIOSH REL of 1 ppm (with a 2 ppm ceiling) or as an alternative the 10 ppm ACGIH level as a replacement for the current PEL of 50 ppm. The cited bases for this proposed change are two 30-year old studies. VI Meeting A special meeting of VI member company representatives was convened on June 29th. After substantial discussion, it was decided that the Vinyl Institute comments focus on challenging OSHA's health basis for reducing the PEL from current allowed levels. The group after considering the known available health effects information was not aware of any health justification for lowering the PEL. The group concluded that being regulated to 1 ppm or 10 ppm would have a significant economic impact as related to providing engineering controls and have an adverse impact on productivity, primarily associated with plant maintenance and turn-around activities. while there was no disagreement on voluntarily operating within the ACGIH levels, there was concern expressed about such levels being prescribed by OSHA regulation. Review and Comment We are informed that CMA plans to comment on the overall OSHA proposal with specific comments on certain chemicals including EDC. With regard to EDC, it is our understanding at this time that CMA comments will endorse reducing the regulatory level 0000QS556 Wayne Interchange Plaza II 755 Route 46 Wesf Wayne, NJ 07470 (201) 890-9299 L * k. 2- - from the current 50 ppm to ACGIH level of 10 ppm. Attached are the pertinent sections of the comments (Health Issues and Feasibility Issues) for your review. (Note the meeting attendees. Changes on the health section have been prepared by Bob Hinderer). The final comments will, of course, include cover letter describing the VI and a summary of the position taken. We request your support of the approach taken in these comments and ask that you communicate your company's view on this position to your representative on the CMA-EDC panel. Please note that as the comment deadline is July 25th, I would appreciate any comments on the attached by July 20th. HNS/pmb enclosure Distribution: HSE Committee J. Robinson, BFG J. Shepherd, BFG R. Hinderer, BFG R. F. Adams, OxyChem A.L. Sepeda, OxyChem C. Graybill, PPG S. Reynolds, Borden K. Travis, BFG T. Robinson, Vulcan (guest) v i1': i fUJ:ic A C Ut. (U_ Meredith N. Scheck Assistant Director VVV 000005557 ETHYLENE DICHLORIDE H.S. NUMBER 1168 Feasibility Issues A typical U.S. facility manufacturing ethylene dichloride (EDC) is associated with the production of vinyl chloride monomer. A 1500 ton per day vinyl chloride monomer plant will produce approximately 2400 tons per day of EDC. The typical EDC/VCM facility consists of two EDC production steps and a VCM production step. The EDC production steps include direct chlorination and oxychlorination which are followed by EDC purification and storage. VCM is produced by thermal cracking of EDC to VCM and HCl. During VCM purification, uncracked EDC is recycled to EDC purification and HCl is sent to oxychlorination for additional EDC production. In order to comply with the proposed regulation in a typical EDC/VCM plant, it would be necessary to make major capital y investments. Some of the areas where modifications are anticipated include tank farm vent controls, sample gathering f and laboratory techniques, process sewer systems, additional employee exposure monitoring, loading/unloading operations and maintenance expenses. The estimated total initial capital expenses for compliance will be in the order of $10-25l4y- The additional annual expense to maintain this compliance is estimated to be $4-5M. Extrapolating typical plant expenditures to the domestic vinyl industry as a whole, the initial capital expense for the industry to comply with the proposed regulations is $160-400M. In addition to the initial expense, the annual expense to maintain industry compliance would be $60-80M. This level of. expenditures for compliance will place significant economic burdens on the domestic vinyl industry. In addition to initial capital costs and annual expenses, plant capacity will be significantly impacted by the proposed regulations. The regulations will require the cleaning of process equipment sufficiently to meet a severely-reduced EDC exposure limit prior to performing any maintenance. Pure EDC itself requires long purge/evacuation cycles to eliminate it. This will add significantly to the time essential equipment is down for maintenance. However, in almost all cases, EDC is associated with heavier materials, including solids, that make cleanout of closed process equipment extremely difficult. Purging cycles on the order of days will be required in many instances of severe equipment pluggage. It is estimated that additional purging time will reduce EDC (and therefore VCM) VVV 00000555 -2- plant capacity by approximately 10% in the early years of the reduced exposure limit. This will result in an average sales loss of $20-30M for the typical EDC/VCM plant. jEhis represents a sales loss of approximately to $48/6mm^ for the VCM industry. In many instances, there^Is no feasible method to clean severely plugged process equipment prior to opening. This equipment simply must be opened, removed, and the pluggage removed directly by properly protected personnel. 000005559 VVV D RA FT HEALTH ISSUES OSHA is proposing to lower the existing workplace standard for EDC from 50 ppm to 1 ppm without anv valid scientific support and without: a critical review of the literature. In its June 7, 1988 proposal (FR vol. 53, No. 109. pp. 21052) OSHA states that it is necessary to reduce its current limits for EDC to reduce health risk(s) and propos es that the standard be lowered to 1 ppm ,(8 hr TWA) with a 2 ppm STEL. Although the Agency acknowledges a concern about carcinogenicity, the primary basis for the proposed change is two 30-year old reports in the foreign literature of hepatotoxicity, nervous system effects, and blood changes in workers. It is not clear why after 30 years OSHA suddenly believes that two Eastern European articles have gained such weight as to support a change in the OSHA workplace standard. Furthermore, it is particularly puzzling how OSHA can use these references to support its proposal when it has not even obtained translations (no translations were available in the Docket as of 6/27/88; we were told that OSHA was considering efforts to obtain translations). These facts suggest a lack of critical review in developing this proposal for EDC. Without such critical review of these studies and all of the literature it will be impossible for OSHA to demonstrate that this or any proposal has a valid scientific base. In proposing a standard for EDC based on the studies of Kozik (1957) and Brzozowski et al (1954), particularly without critical review, OSHA has failed to note the significant findings and limitations of these studies. The descriptions of the Brzozowski et al (1954) and Kozik (1957) studies by NIOSH (1976) provides some evidence that worker exposures were high. Although the highest area sample in the former study was reported as 60 ppm during the pouring of EDC into a bucket, it is cleairjthaf exposures were gross, _ primarily due to skin aj^sfltfption. The authors report Workers breathing extreme-!^ close to barrels during pouring; spills on clothing and shoes, unchanged-contaminated clothing, and the use of EDC to wash their skin indicating that actual exposures were much VVV 000005560 VWa \ AV\o-^ ViiJp' ' .9 -2- higher than predicted by the limited environmental sam pling. ' The study by Kozik (1957) also indicated that workers were employed in occupations where there was significant potential for dermal exposure. It is unfortunate that the contribution of absorption via the skin was not assessed. Because no information was provided on the nature of the sampling (personal versus area monitoring) or the analytical methods used and because skin exposure may have contributed significantly to total exposure, it is not possible to give much weight to the reported concentrations as an indication of actual expo sure. Furthermore, there is no information regarding other chemicals were used in this operation. \y .jv IT The studies of Kozik and Brzozowski noted above also constitutes the known published exposure studies relative to chronic exposure in humans and the deficiencies of these studies do not provide clear evidence of chronic toxic effects at the reported levels of EDO in air. These studies do not take into consideration the exposures received via dermal absorption and it is most likely that any health effects attributable to chronic exposure are due to the combined inhalation and dermal exposures. Consequently, the reported health effects are the result of much higher exposures than reported by the authors. Accordingly, there is no justification for OSHA to propose PEL of 1 ppm on the basis of chronic toxic effects. More recently, studies of the chronic effects of the inhalation of EDC by rats and mice were reported by Spreafico et al (1980). clinical chemistry, hematology, and urinalysis were conducted on both young and old animals which were exposed to concentrations of EDC up to 150 ppm for as long as 2 6 months. Although an elevation of SGOT levels was noted in mature rats exposed to 50 and 150 ppm for 12 months (age 14 to 26 months) , no evidence of any chronic changes was observed in adolescent animals exposed for most of their life span (from age 3 to 21 months). The significance of the elevation of SGOT levels in animals exposed during the later part of their life span is highly questionable. The absence of evaluations at other time points does not allow one to eliminate the possibility that this is a random response. However, even if this elevation is compound-related, the relevance to workers is not clear. No chronic effects are evident in the younger groups which were exposed to the approximate human equivalent of age 65. WV 00000*5561 Toxicology studies indicate that EDC is a weak carcinogen and that the potential cancer risk to man is low. Early studies of McCann et al (1975) reported that EDC was "an extremely weak mutagen" using the Ames assay. Subse quent studies by Rannug et al (1978) also showed that EDC was mutagenic in bacteria. These studies pointed out that Glutathioni (GSH) was a critical factor necessary for mutagenicity. In the mid 1970's, the National Cancer Institute initiated a study to evaluate the carcinogenic potential of EDC (NCI, 1978) . Rats and mice were force-fed EDC in corn oil at concentrations as high as 150 and 200 mg/lg, respectively. In these studies, evidence of cancer was observed in both rats and mice. The response in these studies strongly suggested that EDC posed a significant risk to man* Shortly after these results became available, Maltoni et al (1980) reported that long-term inhalation studies with rats and mice failed to show any evidence that EDC was carcinogenic. These results suggested that route of exposure could have a significant effect on the actual cancer risk posed by EDC. Furthermore, it indicates that the actual risk posed by EDC is much lower via inhalation than that posed by force-feeding. More recently, Klaunig et al (1986) has also reported that route of exposure is critical in determining the actual risk posed by EDC. In carcinogenicity studies of a number of chlorinated hydrocarbons, the authors found that EDC did not cause cancer in mice via drinking water. This finding was important not only because the dose received via drinking water was higher on a weekly basis, but because the total dose was also higher. The results of Maltoni et al (1980) and Klaunig et al (1986) are important because the absence of carcinogenic responses here are in stark contrast to that by force-feed ing even though the weekly and or total dose are equal to or higher than received in the NCI studies (1). Interest ingly, in vivo studies of genotoxicity via different routes of exposures appear to support these observations. Storer et al (1984) reports that EDC causes hepatic DNA damage in mice by oral exposures, but not when animals were exposed by the inhalation route. The authors conclude that their "results provide additional evidence for the importance of a route o-f exposure effect in the in vivo genotoxicity and carcinogenicity of DCE". VVV 000005562 i -4- There are a jiumber of factors which probably contribute to this dramatic difference in carcinogenic response. One of the most (?>important reasons may be the differences in primary n&tabolic pathways. NAS (1987) reports that metabolism of EDC occurs primarily via cytochrome p 450 by the inhalation route while metabolism following ingestion primarily involves GSH. This difference in metabolic pathways may be a very important determinant in the carcinogenicity of EDC. Rannug et al (1978) reports that GSH is required for mutagenic activity in bacterial systems and Boyd et al (1979) reports that GSH is present in high concentrations in the forestomachs of rodents. Given the potential importance of GSH in gastric metabolism of single massive doses of EDC during forced-feeding and its apparent importance in mutagenicity, such species and route differences are likely to have a major impact, on human cancer risk assessment of EDC. This data provides strong evidence that the results of the NCI cancer bioassay are not good predictors of the response to be expected in man. They indicate that the carcinogenic response is the result of the route of exposure and a species specific difference. Furthermore, the studies by. Condie (1985) which show that the hepatotoxicity of carbon tetrachloride is enhanced by corn oil provides additional evidence that the carcinogenic response in the NCI studies are closely tied to the specific conditions of exposure. (1) 1.2 mg/lg weekly dose was determined for Maltoni et al (1980) assuming an average minute volume of 3'5 ml/min and an average body weight of 35 g. VVV 00G005563 1 k. -5- HEALTH ISSUES SUMMARY 1. The OSHA proposal of 1 ppm for EDC lacks scientific support and critical review of the literature. 2. The studies of Brzozowski and Kozik do not provide evidence of chronic effects from EDC at low levels because of high dermal exposure and inadequate reporting. 3. The absence of a carcinogenic response via drinking water and inhalation and the differences in metabolic pathways between routes of exposure indicate that the NCI results over-predict the potential carcinogenic risk of EDC to man. VVV 000005564 F BIBLIOGRAPHY Spreafico, F. , Zuccato, E., Marcucci, F., Sironi, M., Paglialunga, S., Madonna, M. , and Mussini, E. (1980). Pharmacokinetics of ethylene dichloride in rats treated by different routes and its long-term inhalation toxicity. Banburv Report 5 Ethvlene Dichloride: A Potential Health Risk?, pp. 107-133 . Maltoni, c., Valgimigli, L. , and Scarnato, c. (1980) Long-term carcinogenicity bioassays on ethylene dichloride administered by inhalation to rats and mice. Banbury Report 5 Ethylene Dichloride: A Potential Health Risk? pp. 3-29. Condie, L.W., (1985) Target organ toxicity of halocarbons commonly found contaminating drinking water. Report, EPA/600/D-85/172, pp. 1-14. Critieria For a Recommended Standard. Occupational Exposure to Ethylene Dichloride (1,2-dichloro-ethane). U.S. DHEW, PHS, CDC, HIOSH, pp. 52-57, March 1976. D'Souzea, R.W., Francis, W.R., Bruce, R.D., Anderson, M.E., (1987) Physiology Based Pharmacokinetic Model for Ethylene Dichloride and its Application and Risk Assessment, Pharmacokinetic and Risk Assessment - Drinking Water and Health. Volume 8, National Academy Press, Washington, D.C. pp. 286-301. Ward, J.M. (1980) The Carcinogenicity of ethylene dichloride in Osborne-Mendel rats and BgC-F- mice. Banburv Report 5 Ethvlene Dichloride: A Potential Health Risk?, pp. 35-49. Klaunig, J.E., Ruck, R.J., and Pereira, M.A. (1986) Carcinogenicity of chlorinated methane and ethane compounds administered in drinking water to mice. Environmental Health Perspectives, 69:89-95. Boyd, S.C., Susame, H.A., and Boyd, M.R. (1979) High concentrations of glutathione is glandular stomach: possible implications for carcinogenesis. Science 20:1010-1012. Storer, R.D., Jackson, N.M., and Connolly, R.B. (1984) In vivo genotixicity and acute hepatotoxicity of 1, 2-dichloroethane in mice: comparison of oral, intraperitoneal, and inhalation routes of exposure. Cancer Research, 44(10):4267-4271. Kozik, J.V., (1957) Problems of Industrial Hygiene Arising from the Use of Dichloroethane: The Aircraft Industry. Gigiena Truda I Professionalnye Zabolevaniia (MOSKVA) 1:32. Brzozowski, J., Czajka, J., Dutkiewica, T. et al (1954). Higiena pracy i stan zdrowia zatrudnionych przy zwalczaniu stonki ziemniaczanej heksachlorocykloheksanem, dwuchloroetanem. Medycyna Pracy Dwumiesiecznik 5:89-98. VVV 000005565 minutes HEALTH. SAFETY & ENVIRONMENT COMMITTEE Princess Resort Hotel Scottsdale, Arizona Wednesday May 11, 1988 1:00 p.m. Attendees; W. c. Holbrook, BFGoodrich, chairman C. Lunn, Borden Chemicals & Plastics R. Oubre, Dow Chemical Fisher, Air Products R. Luss, Occidental Chemical P. J. Usinowicz, Air Products C.A. Gellner, CertainTeed B. Gholson, Georgia Gulf P. de la Cruz, Keller and Heckman M.A. Voison, BFGoodrich Canada W.A. McClain, Vista Chemical J.C. Ledvina, Vista Chemical E. Schroeder, Shintech Inc. M. N. Scheck, Vinyl Institute RECEIVED JUNO9 '88 Rnirt.- Copy:--------------File: ,,.^T X-F: _________ Opening, of Meeting Committee Chairman, W.C. Holbrook convened the meeting at 1:00 p.m. and asked for self-introductions. Safety Subcommittee Cris Lunn, who had volunteered at the committee's March 8th meeting to assume the chairmanship of a new Safety Subcommittee, distributed a paper outlining short-term goals, objectives and some suggested activities. In opening comments, Mr. Holbrook noted that he believed the long range goal should be to improve the vinyl industry's safety record and noted that the industry in total has much to gainby supporting program(s) that may improve safety performance. The committee had a brief discussion on the variety of programs that exist within individual companies. Mr. Ledvina stated that he thought the VI programs should not be duplicative of activities of other organizations. Mr. Luss suggested that an appropriate activity for a trade association would be the convening of a safety conference. Mr. Holbrook suggested that a small group of interested individ uals meet prior to the next meeting to develop a mission 111 "" yyy 000005566 The Vinyl Institute, A Division of The Society of the Plastics industry, Inc. Wayne Interchange Piaza II, 155 Route 46 West, Wtiyne, New Jersey 07470, (201) 890-9299 4 ft i t -2- statement and develop some recommendations for short-term activities with a proposal to be received by the full committee. (Mrs. Scheck was asked to arrange for a meeting of this work group on June 29th in Baton Rouge). Mr. Holbrook suggested that a matter of old business, the calculations used in determining the VI Safety Performance Awards, be delegated to this subcom mittee for review. Title III A company-by-company review of activities being undertaken to comply with the reporting provisions of SARA Title III. A question and answer period followed. It was noted that in some geographic areas companies are working alone with the local community, while in areas with a large chemical industry pres ence, joint programs are underway. It was noted that at the committee's next meeting it would be appropriate to have a company-by-company review of experiences since the July 1, 1988 reporting deadline. In order to achieve a total industry figure of amounts reported under this first deadline, Mrs. Scheck was dir&g^ed to send out a notice to the committee requesting ^the nurnbersL.,reported for calendar year 1987. Mr. Holbrook" stated" that this information is to be otherwise available under the FOI Act. SPI v. EPA Mr. de la Cruz stated that the EPA General Counsel's office and the Justice Department had both "signed off" on the settlement language. He stated, however, that the staff of the EPA's Air Office noted that a time limit had applied to this process and that the actions by the OGC had occurred following the expira tion of this time limit. Mr. de la Cruz noted that he is hopeful that this problem can be remedied in the near future. TCLP Mr. Ledvina stated that the TCLP is to be published as a reproposal during June and noted that the numbers may change and further, that it is expected that 48 additional materials may be added. Mr. Usinowicz stated that it is his understanding that a revised analytical procedure is to be published within the next few weeks. HRS Revisions Mr. Holbrook stated that it is his understanding that the revisions to the Hazard Ranking System have been through "redborder review" and are at OMB. Mr. Holbrook asked whether there VVV 000005567 . fc. . -3- was interest among the committee members in reviewing the HRS revisions when published. Hr. Luss suggested that CMA is the appropriate lead and that activity should be coordinated with them. State Federal Enforcement Update The committee had a company-by-company review of recent enforce ment activities. Hr. McClain noted that Covington and Burlington has maintained a library on consent decree informa tion and that this was offered to the ABA Natural Resources Committee. He offered to provide Mr. Holbrook with the appro priate contact for any possible future interest/use. QSHA Labeling Mr. de la Cruz updated the committee on a recent citation received by Occidental for failure to warn under the OSHA Hazard Communication Standard. Mr. Luss noted that as of May 10th the company received a 30 day extension. Mr. Luss also reviewed the discussion at the March 10, 1988 Executive Board Meeting that had resulted in the labeling practices survey. He noted that the Legal Committee had previ ously discussed developing a generic MSDS and noted that the committee would re-examine the labeling issue at its May 12th meeting. Proposition 65 Mr. de la Cruz updated the committee on recent developments related to Proposition 65, including a March 16, 1988 memo to the State Department of Health Services from the California Health and Welfare Agency requesting that DHS review existing state and federal risk assessment for 49 listed chemicals, with a proposed timetable for completion of the review (7/1/89). According to this memo, the first part of the assessment for 9 chemicals is due 7/1/88, with 23 more chemicals (including vinyl chloride) due 10/1/88. Toxicological Profile Mrs. Scheck stated that the VI comments on the ATS DR draft toxicological profile for vinyl chloride issued under SARA 110 (52FR338340) were filed April 18th. She noted that these were previously distributed to the committee members. Wy 0000S56g -4- ORC Emergency Planning Guidelines Mrs. Scheck noted that at the committee's September 30, 1987 meeting, a discussion was held on work underway by ORC (Organ ization Resources Counselors, Inc.) to develop on behalf of the American Industrial Hygiene Association Emergency Response Planning Guidelines. She updated the committee on the status of the project and noted continued interest on behalf of ORC to have vinyl industry involvement. There was consensus among the committee members that this issue be pursued and that a consul tant be hired if staff determined this was necessary. Strategic Plan Mrs. Scheck reviewed for the committee the proposed strategic plan that is to be reviewed by the Executive Board on May 12th. She noted that under this proposal, the HSE committee would remain as currently structured. Proposed Meeting with EPA Mr. Holbrook noted that at the Committee's last meeting, the members discussed whether it would be appropriate to schedule a meeting with EPA staff at RTP to review and discuss any new environmental initiatives. It was agreed that there did not appear to be any specific reason at this time to schedule such a meeting with EPA. However, it was suggested that a possibility may be to schedule a future meeting in North Carolina and to invite the EPA staff to join the committee for a portion of the meeting *. Next Meetina/Adiournment The next full committee meeting was scheduled for September 21, 1988, 1:00 p.m. in San Francisco, to precede the September 22-23 meeting of the Vinyl Chloride Safety Association, unless issues needing the full committee's review developed before that date. There being no other business, the meeting was adjourned at 4:45 p.m. Respectfully submitted, MjuadoUbLufJu^ M. N. Scheck VVV 000005569 HEALTH. SAFETY & ENVIRONMENT COMMITTEE Princess Resort Hotel Salon IX Scottsdale, Arizona Wednesday May 11, 1988 1:00 p.m. SELF-INTRODUCTIONS Group , . ,, APPROVAL OF MINUTES OF LAST MEETING SAFETY SUBCOMMITTEE Group 'V; '' ' . . ,!">: C. Lunn DISCUSSION OF TITLE III, JULY 1988 REPORTING Group LITIGATION UPDATE: - SPI v. EPA Settlement - EPA V. NRDC M. Scheck VI ENVIRONMENTAL & SAFETY AWARDS - Review of Definitions Group TCLP UPDATE J. Ledvina STATE/FEDERAL ENFORCEMENT UPDATE Group OLD BUSINESS - SARA 110 Toxicological Profile - Proposed Meeting With EPA - OSHA Labeling M. Scheck W.C. Holbrook M. Scheck NEW BUSINESS - VI Presentation at VCSA - VI Strategic Plan NEW MEETING DATE/LOCATION M. Scheck M. Scheck Group VVV 000005570 The Vinyl Institute, A Division of The Society of the Plastics Industry, Inc. Wayne Interchange'Plaza'II, 155 Route 46 west, Wayne, New Jersey 07470, (201) 890-9299 IS rr YOUR COMPANY'S STANDARD PRACTICE TO APPLY OSHA WARNING LABELS OH THE FOLLOWING: <29 CFR 1910.1017) Page^of^ COMPANY Air Products & Chemicals PLANT STORAGE CONTAINERS /HOPPERS PACKAGES /BAGS OP PVC RESIN PACKAGES /BAGS OF PVC COMPOUND Yes Yes N/A CONTAINERS /GAYLORDS OF PVC RESIN CONTAINERS /GAYLORDS OP PVC COMPOUND DRY BLEND SHIPMENTS RAILROAD HOPPER CARS N/A N/A N/A Yes, in plastic envelope in dome with MSDS when loaded. OTHER SHIPMENT CONTAINER OR IN-PLANT Trucks - Label hand ed to driver w/ B/L and MSDS. Vista Chemical Company No Yes Yes Yes Yes Yes Yes, differs by plant. One No answer has affixed stick-on 5,,x7w sign to bottom cone of hop per/both sides. (8 signs per car. Other one has 4"x6" label in envelope to each valve on compartment bot tom/8 per car. Label used contains additional info. CertainTeed Corporation No N/A N/A Yes N/A No Yes, each hatch cover (8) No answer. and unloading port (8) are labeled with sticker. If labels not present, warn ing label applied in center of hatch cover and/or unloading port. BFGoodrich Company No Yes, only No (but is Yes, only No, but is if RVCM labeled un if RVCM labeled un > 8 ppm. der HCS ef >8 ppm. der HCS ef fective 1st fective 1st quarter *88. quarter'88. Yes, only if RVCM >-8 ppm. Waste Containers Georgia Gulf: Plaquemine Labeled under HCS HCS = Hazard Communication Standard ' ij/a `tjfi Yes, cars stencilled in 1" letters. "Product Label" sent w/ B/L of resin shipments. All in-plant contain ers labeled in accordance with HCS. VVV 000005572 IS IT YOUR COMPANY'S STANDARD PRACTICE TO APPLY OSHA WARNING LABELS OK THE FOLLOWING; <29 CFR 1910.1017) Page lot 2 COMPANY Georgia Gulf (continued) Delaware City- PLANT STORAGE CONTAINERS /HOPPERS PACKAGES /BAGS OP PVC RESIN PACKAGES /BAGS OP PVC COMPOUND CONTAINERS /GAYLORDS OF PVC RESIN CONTAINERS /GAYLORDS DRY OP PVC BLEND COMPOUND SHIPMENTS RAILROAD HOPPER CARS Labeled under HCS Yes -fijf Yes Labeled under HCS Labeled under HCS Yes, cars stencilled in 1" letters, "Product Label" sent w/ B/L of resin shipment. Occidental Chemical Corporation HMIS Addis Yes, if > 1 ppm RVCM N/A No N/A N/A Yes, > l ppm RVCM Pottstown HMIS Yes, if .> N/A 1 ppm RVCM N/A N/A N/A Yes, >1 ppm RVCM OTHER SHIPMENT CONTAINER OR IN-PLANT Waste Containers. Scrap shipments labeled under OSHA YC Standard. Scrap Containers Scrap Containers Burlington North Burlington South Pasadena Borden Chemicals 4 Plastics Illlopolis Geismar HMIS Use HMIS Use HMIS yes yes Yes Yes Use HMIS No Sold Com pound Plant N/A N/A N/A N/A yes M/A N/A N/A H/A yes No N/A N/A N/A N/A No N/A N/A Yes, > I ppm RVCM Yes, >! ppm RVCM Yes, ppm RVCM Scrap Containers Scrap Containers N/A N/A fes Yes Scrap Containers Scrap Containers VS/V 0 0 0 0 0 5 5 7 2 Update: March 23, 1980 THE VINYL INSTITUTE HEALTH, SAFETY AND ENVIRONMENT COMMITTEE MAY 11, 1988 SAFETY SUBCOMMITTEE THE VINYL INSTITUTE ANNUAL MEETING SCOTTSDALE , ARIZONA VVV 000005573 SHORT TERM SAFETY SUBCOMMITTEE GOALS: 1. FORMALIZE SUBCOMMITTEE OBJECTIVES S. INITIAL PRIORITIES, TASKS AND TARGET DATES FOR SUBCOMMITTEE 3. ESTABLISH MEMBERSHIP IN SUBCOMMITTEE *V\/ 005 S?4 SAFETY SUBCOMMITTEE OBJECTIVES The primary objectives of the safety subcommittee shall be to provide a forum to: A. Share safety related information which can improve the overall vinyl industry safety record. B. Develop and maintain standard safety training programs for the vinyl industry. C. When appropriate, review and prepare comments on governmental/vinyl industry safety issues. D Assist in recognizing and publicizing outstanding safety performance in the vinyl industry. VVV 000005575 Share safety related information which can improve the overall vinyl industry safety record. .vinyl specific or ________general accident/incident reports .safety organizatian/responsibi1ities safety procedures .vinyl handling viny1 loading .emergency response offsite impact .acc i dent invest igat ion engineering standards relief valves/rupture disk tank design loading/unloading testing sample systems viny1/PVC laboratories control system interlocks fire protection special clearing procedures fire fighting personnel protective equipment 1abe1ing/MSDS samp ling Quest speakers/writers topics: company safety CAER programs _ mutual aid programs Clearinghouse/pub1ished document list yVV 000005 B. Develop and maintain standard safety training programs for the vinyl industry. OSHA training requirements Emergency response guidelines video ________slide/tape _________PC based written VVtf 0000G5577 c. When appropriate, review and prepare comments on governmental/ vinyl industry safety issues. D. Assist in recognizing and publicizing outstanding safety performance in the vinyl industry. VVV 000005578