Document VJZ55X4j9Xw4ykOGEK4MGqJLq

t T. L. Carey Vice President, Manufacturing bec t J. T. Barr 1 J. C. Novak cd&l t''ioc/uc& am/ &en \H\ J. D. Ktnr.. : J. T. Scba.;tianclli H. L. Watson CHEMICALS GROUP ` A. J . Dig!1o J. F, Healy f:iv Executive Mail, Swedesford Road. Wjync. Pa. 19037 RECEIVED m ^1974 LAW DEPArWB^ 1974 Ti: (215) 6S7-c:e.: CERTIFIED MAIL RETURN RECEIPT REQUESTED Deparir.mt of Labor Commonwealth of Kentucky Frankfort, Kentucky 40601 Gentlemen: In accordance with Section 4 of OSH Regulation 119, we hereby register with the Department of Labor, Com monwealth of Kentucky the use of vinyl chloride monomer in*our plant located on Highway 95, Calvert City, Kentucky. The information required by Section 4 (b) is submitted as follows: i) The intended use of vinyl chloTide monomer is in storage1, transfer and polmerization operations for the manufacture of: -7 A. Polyvinyl chloride (PVC) resin homo polymers and copolymers. B. Emulsion copoLymers using vinyl chloride monomer. The two processes involve: With respect to PVC: 1. Polymerization of vinyl chloride monomer to homopolymer or with copolymers of pro pylene or vinyl acetate in a water suspension under controlled temperature and pressure. 2. Recovery of unreacted vinyl chloride and comonomer. 3. Filtration and drying of the resulting product, PVC resin, which contains less than 0.51 vinyl chloride monomer. AP00047634 Department o Labor Page 2 24 June 1974 With respect ts emulsions: 1. Copolymerization of vinyl chloride with vinyl acetate and oti. irnc in an emulsion polymerization system under controlled temperature and pressure. 2. After the completion of the polymerization the resulting emulsion polymer is filtered and pumped to storage. The vinyl chloride content of this product is less than 0.14. ii) Both of these processes are batch operations carried out in closed systems. They are very closely moni tored and maintained to minimize exposure to em ployees. The amount of average exposure to the employ::* is below 50 ppm 8 hr. TWA of vinyl chloride in their breathing air. iii) A. Retained the services of medical consultants to administer and evaluate a series of tests to determine any deficiencies in the employees* liver functions. The series of tests consisted of the following: Chest V-rays Hand X-rays (previously done) BUN Uric Acid Phosphrous Calcium Alkaline Phosphatase Total Protein Albumin Bilirubin Cholesterol Carbon DioXide Chloride SGOT LDH CSC with Platlets if necessary SGPT We will adopt in the future any additional recommended tests that will define the effects of vinyl chloride on the employees' health and these will be administered to the employees as a routine medical control. AP00047635 t, Department of ! iror Page 3 24 June 1974 B. The industrial 1 ;?ne control measures include the folio;.-*:;..: 1. Sequential area monitoring to give a recj-i.'.ja profile of vinyl chloride con centration in the general work area, with an alarm for any excursions. 2. Personnel monitoring program on a rotating basis for all employees to monitor their exposure. 3. Thorough ventilation is provided throughout the process area, backed up by automatically controlled emergency ventilation in the event of an unexpected excursion. 4. Lunch area is provided separate from the process area and n food or drink is allowed in the working area. * 5. Shower and locker facilities are available to the employees. 6. Employees are provided with both air-line respirators and self-contained breathing apparatus for emergency use. 7. Employees have been trained in the proper operation of the process, and in possible hazardous effects of exposure to vinyl chloride monomer. 8. Emergency procedures are established and the employees are trained in their use. We at Air Products and Chemicals have a meaningful and effec tive program to protect our employees. This program is a dynamic effort, continually seeking ways for improvements We trust that this information meets your requirements, and we shall be glad to furnish any further information that you may require. Very truly yours, TLC/izr AP00047636