Document V2jqzzpy45rz2Km4M51Jpp2q

2030 DOW CENTER January 8,1997 The Dow Chmlel Company Midland. Michigan 48674 D. L. Albert, B-101, Freeport R. A. Dommer, 1803 Building J. P. Jurgiel, B-101, Freeport W. E. Ledford, 1803 Building M. R. Marchant, 3502W, Plaquemine cc: S. E. Taylor, 2030 Dow Center V. L. Rupp, 2020 Dow Center OSHA METHYLENE CHLORIDE STANDARD Enclosed is a copy of the OSHA standard on MC. This is a copy that OSHA gave to Congress and it was obtained from Congress. This will only become "official" once it is published in the Federal Register and some changes might happen before that occurs, however my guess is that any will be minor. Because of this, please do not pass the documents too far afield. I'm also enclosing a simple summary of the standard with some interpretive highlights based on the document we have. Since we don't have the preamble, some of this is speculative at this time. I think it is proper to begin to talk to the plants that will be affected by this standard and begin preparation for initial monitoring, etc. Note that there is no written program required by this standard. Please let me know if there are any questions and there is anything more I can help with. If there are questions of interpretation. I'll try to pass them and the answers on to everyone. R. D. Olson Env. &c Health Reg. Affairs (517) 636-8295 Enc. p.S. I just heard that the MC standard is at the Federal Register and will be published Friday or early next week. Supposedly the language we have is identical to the standard. CONFIDENTIAL DO 007947 METHYLENE CHLORIDE JANUARY 7,1997 These comments are based on a pre-released copy of the methylene chloride (MC) standard. Because this has not appeared in the Federal Register it is not official. Dates: Standard is effective 90 days after publication in the Federal Register Initial monitoring will have to be done within 120 days after the effective date Engineering corrections will have to be made within 1 year of the effective date Based on Federal Register publication date Levels: Time-Weighted Average PEL; 25 ppm. Short Term Exposure Limit PEL: 125 ppm/15 minutes Action Level: 12.5 ppm Emergency: Means an "uncontrolled" release. If an incidental release can be controlled by employees, it is not an emergency Initial Monitoring: Remonitor if present data is older than 12 months Can use objective data in place of initial data Remonitoring: If exposures are above the AL but below the TWA, monitor each 6 months If exposures are above either the TWA or STEL, monitor each 3 months Monitor if exposures have increased, e.g. spill (can use direct-reading instruments) Employee Notification: 15 days after monitoring results are reported to the plant, must inform employees by letter or by posting in workplace Regulated Areas: Set up if over the TWA or the STEL Must have signs and demarcation Method of Compliance: Set up procedures to detect leaks of MC, contain spills and dispose of MC- contaminated wastes 1 CONFIDENTIAL DO 007948 T Written Plan: None is required at this time OSHA METHYLENE CHLORIDE STANDARD Respiratory Protection: Can use air-purifying respirators only when escaping from an emergency with a gas mask with organic vapor canister Employees, including those who might use the gas mask, shall have a health care professional ascertain their ability to use respiratory protection. The health care professional shall provide its findings to the employee and employer in writing. Up to 625 ppm, employees can use continuous flow (CF), supplied-'air (SA) respirator, hood or helmet Up to 1250 ppm, employees can use full facepiece (FF) SA respirator in negative pressure (NP) mode Up to 5000 ppm, employees can use CF, FF, SA respirators or pressure demand (PD), SA, FF respirators or positive pressure (PP), FF SCBA At unknown concentrations or above 5000 ppm, employees must use PP, FF SCBA or FF, PD, SA respirator with escape bottle For fire fighting employees must use a PP, FF SCBA For emergency escape employees can use any continuous flow or PD SCBA or a gas mask with organic vapor canister Must replace the OV canister after every use t Respirator Fit Testing: Qualitative or quantitative ^t initial fit test ' Fit test annually if using negative pressure respirators Don't have to fit test if supplied air respirator is in positive pressure mode Personal Protective Clothing: Must furnish clothing to protect from skin or eye irritation from MC Dow must take care of clothing Medical Surveillance: If exposed above the AL for 30 or more days each year If exposed above the TWA or STEL for more than 10 days each year If exposed above the TWA or STEL for anytime limit and at risk from cardiac disease or other serious MC related problem and employee requests inclusion If exposed in an emergency At termination Initial medical surveillance unless done within 12 months of standard Update medical and work history annually Physical exams, including lab work: If employee is 45 years old or older, every year 2 CONFIDENTIAL DO 007949 If employee is under 45 years old, every 3 years Content of surveillance is in the standard OSHA METHYLENE CHLORIDE STANDARD Written medical opinion to employee and employer within 15 days after medical and physical evaluation but not later than 30 days after the exam Written opinion must carry certain items of information Employer must provide certain information to health professional ^ Information and Trainine: / All employees with potential exposure must be informed and trained at initial assignment Certain information must be given \ Retraining of employees must be done as necessary Recordkeeping: Monitoring data must include PPE wom and names of all employees the data represents together which person was monitored Exposure monitoring data must be kept for 30 years Medical records must be kept for employee's employment plus 30 years urn- CONFIDENTIAL 3 DO 007950