Document X86BKDBROrXkJkqjnVB6BkMgy

TO FROM ,3JECT Mary E. Long H.W, Dietz , M.D FIELD POWT 0SG&-fc 6U3G. NQ/ un : Avoh Lake G.C. FIELD POINT OR DEPT. * BtDG. NO. ____________Akron - D/0020, 5-H DATE YOUR LETTER DATE THIS LETTER 4-16-81 Fertile Female Policy The medical department is unable to establish a safe level of exposure to vinyl chloride for the developing fetus. Areas where monitoring for vinyl chloride is required are known to result in exposure of the potential mother and therefore, the fetus, to vinyl chloride. For this reason, regular employ ment in such areas is prohibited for fertile females. While it is recognized that vinyl chloride can probably be detected in all areas within the plant boundary and possibly for some distance beyond, the levels outside areas where moni toring is required are considered to be comparable to the routine everyday areas to which the general population is exposed. Your interpretation of the corporate policy is incorrect. A fertile female shall not be assigned to work in an area where her exposure to vinyl chloride is required to be monitored and regular exposure to levels as high as 1 ppm is not acceptable. Your list of hazardous chemicals is not current, so I am attaching a copy of the latest list. v cc:. S. Henning R. Montgomery 26137001 1/30 LJTHO IN U.S.A. BG*6556 Acrylonitrile Benzene Carbon Tetrachloride Chloroform Chromium (VI) Dimethyl acetamide Lead Methyl Ethyl Ketone Vinyl chloride Ethylene thiourea Mercury Employment not permitted in areas where the OSHA regulation (1910.1045) applies and where that regulation requires quarterly or more frequent monitoring of employee exposures. 8-hour TWA not to exceed 0.5 ppm. No regular daily exposure. Exposure may be permitted in laboratory situations if exposure is to less than 10 ppm and no more than 150 minutes/week in increments no greater than 15 minutes with a minimum of two hours between exposures. As for carbon tetrachloride. 8-hour TWA not to exceed 0.025 mg/M*^. As for carbon tetrachloride. 8-hour TWA not to exceed 0.05 mg/M^ provided blood leads do not exceed 30 ug/100 gm. 8-hour TWA not to exceed 100 ppm. Employment not permitted in areas where monitoring is required. 8-hour TWA no greater than 0.1 ppm 8-hour TWA no greater than 0.05 mg/M^ provided urine mercury levels do not exceed 75 ug/1. 26137002 BF046SS7 w* t5 mi April 13, 1981 Dr. Harold W. Dietz Director of Health & Environmental Services Dear Dr. Dietz: Avon Lake General Chemical is attempting to obtain a clarification or working policy on the topic of fertile females. We are in need of a clarification to aid us in answering those females we are recruiting who want to work in the restricted area as well as our more senior female engineers who also desire experience in regulated areas. Enclosed is our suggested fertile female policy for your approval, job breakdowns of times in regulated and non-regulated areas and our list of hazardous chemicals and their restrictions. Questions and comments will be appreciated. Please contact me at extension 1832 in Avon Lake. MEL/ecw Enclosures/ Niarjr c. i_uny Personnel Assistant Avon Lake General Chemical Plant 26137003 BbU4b55 Avon Lake General Chemical FERTILE FEMALE POLICY A female employee with childbearing capability may be assigned to work in vinyl chloride regulated areas under the following conditions: a. The employee must wear an airline respirator when a yellow warning light is flashing indicating exposure over one part per million (ppm) but less than three ppm. b. The employee must leave the regulated area when a red warning light is flashing indicating exposure in excess of three ppm. c. The employee must not be exposed to vinyl chloride in excess of one ppm Time Weighted Average (TWA) for an eight hour period as shown by monthly personal monitoring. The employee will not be assigned in areas where she would be exposed to hazardous chemicals other than vinyl chloride in excess of exposure limitations specified by BFGoodrich. MEL/ecw 4/1/81 CT 05 "vi O 6 BFG46559 STRICTLY PRIVATE March 27, 1979 Mr. P. C. Zellers The following chemicals and corresponding exposure limitations have been identified by the Medical Department as requiring restriction from employment/removal from the area for fertile females: Benzene 954 H34 8 hour TWA not to exceed 0.5 ppm. Carbon Tetrachloride 954 H80 Byproduct of Chloroform No regular daily exposure. Exposure may be permitted in laboratory situations if exposure is to less than 1 ppm and no more than 150 minutes/wk in increments no greater than 15 minutes with a minimum of two hours between exposures. Chloroform 954 H40 1,4H lbs. Chromium (VI) Lead _ 913 2.2M lbs. As for carbon tetrachloride. 8 hour TWA not to exceed 0.025 mg/M3 8 hour TWA not to exceed 0.05 mg/m^ provided blood leads do not exceed 30 mg/100 gm Methyl Ethyl Ketone 953 G23 8 hour TWA not to exceed 100 ppm Vinyl Chloride Employment not permitted in areas where monitoring is required (or levels greater than 0.5 ppm) Ethylene Thiourea 8 hour TWA no greater than 0.1 ppm Mercury 951 C48 8 hour TWA no greater than 0.05 mg/M provided urine mercury levels do not exceed 75 ug/L MEL/ecw 3/30/81 Richard A. Guyton, M.D. BFG46560 JOB BREAKDOWNS Position: Technical Staff Regulated Non-Regulated Polymerization: - 1 to 3 hours (maximum) - Monitoring run through building; check charts. - Monitor charging times. - Twice a day monitoring of process. - Catch shifts, operator interface. - Experimental work, e.g., modifying charge process. - Total: 30% of time or 12 hrs./week Dryer: - Quality control on final product. - Interface between production line and laboratory. - Routine paper work. - Customer work with production and Lab. - Handle customer complaints. - Handle returned goods. - Inspect and sample goods. - Interpret data on sample; generate answer. - Interaction with production in Dryer Bldg. 50% (more mech. 1st floor). - Total: 50% or 20 hrs./week. Concentrator Building: - Monitoring. - Operator interface. - Check out equipment. - Trouble shooting. - Startup and training. - Maintenance. - Experimental work, i.e., process modification. - Total: 5% or 10% 2 or 4 hrs./week MEL/ecw 4/13/81 >* (3 o BFG46561 Position: Process Engineer Regulated Area Polymeriizzaattiioonn:: JOB BREAKDOWNS Non-Regulated Area Dryer: - Monitoring - Control room. - Trouble shooting. - Some mofification and experimentation. - Vinyl samples. - Maximum of 3 hours in area at a time. Office work. - Check over instruments. - Projects. - Visual observations. - Meetings, etc. Total: 20% of his time or 8 hrs./week. - Instrumental percent development in control room. 3 hrs. or 4. Total: 80% or 32 hrs./week. Instrumentation: - Process Control. - Process overseeing. - Working w/p.c.'s 26137007 MEL/ecw 4/13/81 .7-13-81 26138001 1. The results of personnel and area monitoring conducted during the month are presented in the attached table. 2. A maintenance mechanic was restricted from working in Estane for 6 months because of possible MDI sensitization. The individual evidenced symptoms of MDI exposure for the second time in as many months while working in B/433. 3. Geon West has stopped using DOA, a suspect carcinogen, and switched to Sanicizer 97. 4. We met with representatives of Robert Ross and Sons, BFI, and Norton Construction to obtain their approval to stop monitoring their employees for VCM and acrylonitrile. With the exception of a few VCM readings at Robert Ross,exposure to VCM and AN has been below the OSHA action levels. Robert Ross has agreed to cessation of our AN monitoring. We will continue VCM monitoring until the exposure levels remain below the action level. BFI and Norton Construction are reviewing our proposal. 5.' Four employees in Hydrophilics, including a supervisor, experienced nausea ^ and diarrhea while working in B/437. The only common denominator we could find was their work on a plugged extruder line. The men were working around the extruder for several hours in the presence of acrylate fumes. This is the first time anyone in Hydrophilics has reported these effects, even though similar situations have occurred in the past. Neither Cleveland nor Akron were able to provide much help in identifying the cause of the nausea and diarrhea. Hydrophilics has modified their extruder line to prevent plugging in the future. 6. Personnel monitoring of weighman in B/4^8 indicates that lead exposures are above the OSHA allowable of 50 mg/m , In the past, weighman exposure to lead has been very low. Similarly, lead levels in the blood have also been low. The exact cause of the recent high readings is unknown. Compound West has begun routine cleaning of the screens at the weigh station and has closed off unused sections of the evacuation system to increase suction in the immediate vicinity of the scales. Hopefully, these measures will alleviate the problem. If not, additional employee protection, such as the ventilated helmets used at Pedricktown, 'may be needed. Distribution: B. R. Welch W. E. Horton C. Bayard J. R. Shellenberger D. D. Quester J. C. Meek E. C. Gilbert D. J. McDonald K. J. Kaminski T. S. Bialke H. Waltemate J. A. Kiel - Ped. D. J. Gargas b?G46563 To: J. W. Gressler 2 7-13-81 7. Noise levels in excess of 90 dBA exist in B/465A. Signs have been posted at all entrances requiring hearing protection when working in the building. 8. Our lab and ALTC are working to resolve discrepancies between their respective MDI analytical techniques. Our lab's method has been modified and a series of experiments are being conducted to verify its accuracy. RCL/bp R. C. Lockemer 26138002 BFG46564 SUMMARY OF PERSONNEL MONITORING MAY_________, 1981 Parameter Allowable Cone. 8 hr. TWA VCM* Plant 1 ppm J B/432 t B/438 B/449 V451 B/4S2 { B/4S4 B/4S5 B/4S7 B/4S8 B/459 3/461 i B/463 l B/464 B/465 3/466 NO. Of Samples Month Avg. Cone. 186 - 1 26 31 3 8 3 - 7 29 15 28 2 33 1.00 - - 0.50 1.38 0.25 0.14 0.16 0.13 - 0.62 1.64 0.27 2.89 0.08 0.09 Year-To-Date No. Above i No. of Allowable j Samples Avg. Cone. No. Above Allowable 1 i j hi -- i i J 27 761 0.63 80 j -- i - 1 0.44 - 5 0.82 8 114 0.75 2 ' 130 0.20 ! 22 - 0.29 - 39 0.22 21 0.16 - 7 0.02 - 1 iI i 21 ! | 21 i ?! <T*\ 1 Si ! o p - CJ 1 19 0.42 i i i 9 110 1.45 ; 29 ; 1 73 0.30 ; 1 196 146 1.00 - 3 0.20 - 69 0.09 - B/468 -- - 1 0.05 - 3/471 -- -- Includes all long term monitoring with and without tasks. - BFG46565 1 Envir. - 4-a 3-1-31 SUMMARY OF PERSONNEL MONITORING May 198 Parameter Allowable Cone. 8 hr. TWA No. of Samples Month Avg. Cone. No. Above Allowable Year-To-Date No. of Avg. No. Above Samples Cone. Allowable Dust Total 10 mg/m3 Respirable 5 mg/m3 Noise 90 dA 0 12 9 Metals Sb Cd Cr Pb 500 /fg/m3 j 200 jag/m3 i 500 /ug/m3 50 jag/m3 0 O 0 1 Other HPA DOP AN 0.5 ppm 5. mg/m^ 1 ppm 0 0 0 0 2.43 81 0 0 0 999.0 0 0 0 0 0 00 2 27 1.85 2 t 0 40 69 1 | i 0 36 46.2 2 0 36 0.34 0 0& 0 15 1.22 H" 1 38 63.55 4 05 3 C3 0 6 0.03 0 0 2 0.01 0 1 1 00 7 <2. j $O G 8X9 Envir. - 4-b 5-1-31 PERSONNEL M O NITO RING - % < 1 PPM A c tu a l O U a o 0 jj u (TJ --. 0 > z0 *9 * -3 3 4J 4J CJ 0 < --* o w pH m T* n* CD r- <T> co O lO pH pH r- rH P *> * 5T> <7\ CD vO lO <JN r- ID <yi m CO <N (N pH <N H o -- 3 00 C C < CD CO m r-- r~ C\ CO u JJ <y ~ a# JS -- -T CO in 1$ r- r- a M U o-- 00 "0 w U ro 0) pH <c 3 U jJ ex -- P T3 CS <N CD CO in <? r* p Cjl <ii CO CO in CD r- p- 01 r- u xJ 0 -- dP OJ --' W CD CO m in r- r- eh r- ( m m <0 ID iD r 3* TT s CO a CD CD 3 xj a Q S2 j Ui >1 h m vo rC0 CO <Ti 03 X C- a* V IP- JJ -- <*> c* m r- r- r 0 03 > Ji J zo M X I pH i CJ ID .pH 3 < <0 3 <*0 0 C-- OOO D S' O' u -c i~H --4 m 'T in \3 vD ID *9* ffi V \ a CD CD BFG46567 a: GC O o err