Document VGdQBw3kndjqB2anV9L5Lp3k8
PROPOSED TRAINING PROGRAM FOR VINYL CMLORIDE (VC) STANDARD 1910.93Q,
"Each employee engaged in VC or polyvinyl chloride (PVC) operations shall he provided training in a program relating to the hazards of VC and precautions for its safe use." The program shall include:
I. "The nature of the health hazard from chronic exposure to VC including specifically the carcinogenic hazara11;
A. Chronic cynosure and carcinogenic hazard:-
1* Read paragraph II "Findings regarding carcinogenicity, exposure levels and feasibility -(*1) carcinogenicity of vinyl chloride" (Preamble to 1910.93Q) See attachment ,^1.
II. 1'The specific nature of operations which could result in exposure to VC in excess of the permissible limit and necessary protective steps";
A. Specific operations v:hich could result in excess exposure:
1. Cover plant layout diagrams and specific jobs as they relate to monitoring data results.
2. Utilize monitoring s\immaries and letters from Hr. R. Arnold on "mask areas," etc.
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1. Good operating procedures to prevent* occurance 2. Preventative maintenance 5* Monitoring 4-o Respiratory protection
III., "The purpose for, proper use, and limitations of respiratory protective devices":
A. Purpose for:.
Read section III, paragraph (7), Respiratory Protection. See attachment #2o
B. Proper use and limitations:
1. Reviev; chart from 1910.93Q, (g), (A), Selection of Respirators for VC. Explain types listed. See attachment #3-
2o- Cover "Quarterly Information Form" for those employees who elect not to wear respirators below 25 ppm VC. (Distributed to all employees quarterly) To be written.
3* (Jover limitations as listed in ANSI 258.2-1969, Practices for Respiratory Protection. See attachment
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4. Distribute SOP's for all respirators. Example - see attachment 0-5.
5. Demonstrate proper use of each type to be provided*
6. Have each'employee practice using each type of respirator which will be provided.
7. Cover maintenance required by 1910.134 and A1TSI Z88.21969. See attachment #6*
IV. 'The fire hazard and acute toxicity of VC, and the necessary protective steps:
A. Eire hazard:
1. Cover flash point and explosive limits.
B. Acute toxicity:
1. Cover physiological response and acute vapor exposure as
listed in F. A. Patty's Industrial Hygiene and Toxicology, Vol. II, Pgs. 1305-4. See attachment if}.
C. Protective steps:
1t Emergency gas leaks procedure.
2. Cover respiratory protection equipment requirements.
V. The purpose for and a description of the monitoring program:
A. Purpose for:
1. Cover section III, (4), monitoring, in the preamble to
19^0.93Q and paragraph (d), monitoring in 19"10.93Q* See attachment #8.
B. Description of program:.
1. Personnel monitoring. See attachment #9
2. Miran monitoring. (Ncu attachment - To be completed)
VI. The purpose for, and a description of, the medical surveillance program:.
A. Purpose for: TT " r J
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1. Only tests available which are useful for medical surveillance - Ho positive tests, etc.
2. ijevelopment of medical history and data which aids in suggesting problems of a general nature - Search for possible early warning signals of a specific nature.
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B. Description of program:
1. Read section (K), Medical Surveillance of 1910.93^ and appendix A. See attachment #10.
2. Make chart comparison of requirements under law and Firestone program.
3- Necessity of continuing our program and need for employee cooperation.
VII. Emergency procedures:
* A. Hazardous operations:
1o Cover as defined by 1910.93Q and as it relates to our operations.
2. Cover as it relates to respirators.
3- Cover as it relates to protective clothing. (Show sample garmet) Specify who will wear.
B. Emergency situations:
1. Present written operational plan, (to "be written) Includes hazardous operations and evaluation plan*
VTU. Specific information to aid the employee in recognition of conditions which may result in the release of VC;
A. High pressure in reactors.
B. Frost on seals, valves^, joints, etc.
C. Leaking slurry pipes.
D. Etc.
IX. A review of this standard at the employee's first training and indoctrination program and annually thereafter: A. Initial program:
1* Cover all parts of 1910.93Q not covered in items I thru VIII above. See attachment #11.
B,, Annual review:
1. Reduce to slide and tape program and present to employees on individual basis thru the Singer Caramate units.
X. All materials will b organized for easy submittal to OSHA if reqt^ested by OSHA.
G. D. Lloyd