Document XBGp6w8nZ4BVeVbyOgd3K4RK

Paragraph 1910.93q (a) (1) (b) (2) (b) (4) < <n ooo oo -J O' O' 22 Objection Scope.' This paragraph in dicates that it applies to all areas where detectable levels of vinyl chloride are released. Definition of authorized employees. Definition of contam inated . Grounds This requirement is infeasible and unneces sarily stringent for the reasons set forth in Section II, preceding. The definition of authorized employees should make explicit provision to include people such as contractors, truck drivers, service person nel and others whose legitimate roles require their occasional presence in operating areas.' The definition is objected to for two reasons. Firstly, defining contaminated in terms of a `'detectable level" of vinyl chloride is inap propriate in that it should be replaced by a finite number. This number should be the average exposure limit to be permitted in the work place air or, with respect to polyvinyl chloride products , should be set at a residual monomer level of 0.1% in conformity with standards set in 1910.93k, 4-aminodipheny1. It will be noted that 4-aminodipheny1 has been considered by the Occupational Safety and Health Administration as possibly "the most hazardous aromatic amine regarding carcinogenic poten tial." Nevertheless, Paragraph 1910.93k exempts mixtures containing less than 0.1% by weight of the substance. Secondly, the definition as currently for mulated uses the phraseology "capable of re leasing." This is ambiguous and ill-defined; either the material releases a specific amount of vinyl chloride or it does not. The cuestion of capability has no place in an operative definition. VVC 0 0 0 0 0 4 7 6 7 Paragraph 1910.93a (b) (5) (b) (8) (h)(13) 23 Objection Definition of decontamina tion. Definition of emergency. Definition of protective clothing. Grounds Decontamination should be defined to mean reduction of vinyl chloride concentrations to less than the permitted ambient level in the work place, or to less than 0.1% of residual vinyl chloride in polyvinyl chloride. This definition is unduly restrictive in that accidental small spills or leaks resulting in the release of vinyl chloride into areas occupied by employees should not be considered emergencies unless extraordinarily large quantities of vinyl chloride are-*involved. Although conditions that result in an eleva- , tion of vinyl chloride levels above whatever j safe limit is set should properly trigger I responsive safety action, these responses should not be considered to be "emergency" responses but rather standard operation pro cedures . This term is ill-defined. If it means pro viding protection against polyvinyl chloride, ordinary cover-alls or the like should be sufficient. If it means a barrier to the passage of vinyl chloride vapor, we are un aware of any readily available clothing that men could wear without undue and unacceptable discomfort for an eight hour day, and that would permit their performing their necessary duties. Ill o Paraarapn 191CK93q 3/ (d: (K (ID (a) (2) id) (3) (e) (2) < < o o o o o * O' 24 Objection Definition of regulated area. Definition of access' to regulated areas. Definition of daily roster. Definition of monitoring. Grounds For the reasons discussed more fully in Section II above, we believe that a regulated area should not be set where polyvinyl chloride is repackaged, stored, or used. Still further for the reasons discussed in connection with Paragraph 1910.93q(b)(4), we believe that the phrase "capable of releasing detectable levels" should be eliminated and replaced by a finite limit as previously described. In other words, we believe that regulated areas should be set where experience has taught us a poten tial hazard exists and should no^be set where experience and carefully gathered evidence shows that there is no hazard. To the extent that access is extended by en larging the definition of authorized employees as previously discussed, no objection is taken. The. maintenance of this roster should be re stricted to those employees whose duties regularly require their entiry into regulated areas. The occasional transient (such as truck drivers, vendors, contractors and the like) who may enter such areas on only a very few oc casions should be exempt from this requirement. Further, the regular time records should be an adequate record. We are not sure how monitoring with a con fidence. level of 95% can be assured. Sample collection and preparation procedures will require extensive testing as will the actual " 3/ The original document uses the designation (4) instead of (d) but this is an obvious `-vrrocrraohical error. VVC QGQ004-769 Paragraph 1910.93g' (e) (2) (e) (3) 25 Objection Definition of monitoring Definition of employee observation. Grounds analytical procedure. We are not aware of existing instrumentation that will permit immediate compliance with this requirement. Furthermore, monitoring in Paragraph (e)(1) is directed toward area monitoring but Para graph (e) (2) indicates that the monitoring shall permit the determination of exposure for each employee. This discrepency should be resolved. We take no objection to employee observation of monitoring and measuring, in principal. We do take exception to unrestricted observa tion by employees' designated representatives. As it stands, each employee could designate a different representative and such an unmanagable group of observers would pose unacceptable levels of confusion and interference with the actual monitoring program. Still further, feasible and perhaps preferred monitoring systems may involve the installation of per manent equipment that will continuously monitor the workplace atmosphere. The problem of observation of "monitoring and measuring" under such circumstances is hard to visualize. Rather than permitting unrestricted access of "designated representatives," we recommend that observation of monitoring and measuring be afforded to employees, or one union repre sentative whose employees are represented by a union, or a representative of the Occupa tional Safety and Health Administration. \ o JU racraph 1C.93q (e) (3) (iii) (f)(1) <c o o oo oo -4 o 26 Objection Definition of observers' opportunities. Engineering controls and work practice methods. Grounds We find it impossible to see how observers can record quantities and results "without interference to the persons performing the monitoring and measuring" especially if a significant number of quantities and results are being obtained and a large number of observers are present. While we recognize the legitimate right of employees to know what the monitoring is revealing, we believe that this can more appropriately be accom plished by requiring that the results of the monitoring be promptly and conspicuously posted. j This entire paragraph is predicated on the ^ assumption that no detectable level of vinyl chloride should be permitted in the workplace. Since this is infeasible as discussed an detail under Section II above, we believe this entire Section should be reworded. The new paragraph should reflect the need to maintain the workplace atmosphere . below the ma.xinum set by the standard as previously proposed. With specific reference to Subparagraph (ii) and (iii), it should be noted that it is completely impractical and unsafe for employees to regularly and routinely work with respira tors such as are required by the present standard. The use of respirators should be considered only as a temrorary practice ;hen atmospheric levels rise above the permittee maximum and should be rewired only until corrective measures have been taker, to bring * the level of vinyl chloride down below the permitted maximum. Paragraph 1910.93a (g) (3) (h) (1) < <o oo oo o F* 27 Objection Respirators Protective clothing Grounds The respirators required by this paragraph are premised on the report by NIOSK that "leakage through chemical cartridge respira tors at high concentrations of VC" have been observed. The use of the specified respira tors imposes severe safety and operational hazards on the workers. It is anticipated that most operations and occasions that will require the use of respirators will be in atmospheres that contain levels of VC above the permitted maximum but by no g^ans "high." In these cases, cartridge type respirators should provide full protection and provide for far greater safety to the workers. Only in cases of true emergencies where very large quantities of vinyl chloride have been re leased should the type of respirator specified in this paragraph be required since this would tax the capabilities of the cartridge type respirator. Still further, v7e believe that full-faced respirators restrict vision and make working more hazardous, and there appear to be mouth and nose masks that provide the , same respiratory protection as the full-faced respirators. The purpose and significance of this Section is difficult to understand. As previously discussed, if protective clothing is intended to provide an impermeable barrier to liquid or gaseous vinyl chloride, we know of no practical clothing that can be vrern by employees and. which will still permit them to perform their necessary duties. If pro tective clothing means closely woven work VVC 0 0 0 0 0 4 7 7 2 Paragraph 1910.93a (h) (1) (h) (2) (h) (2) (i) (i) (i) 28 Objection Protective clothing. Polyvinyl Chloride powder. Head coverings. Removal of protective clothing. Grounds clothing which can be laundered, we fore see no problem. We have previously indicated that we believe that polyvinyl chloride should be subject to this standard only when it contains 0.1% or more of residual vinyl chloride. If this paragraph is amended to reflect this change, no objections are raised. To the.extent that it is applicable where polyvinyl chloride powder containing detectable levels of vinyl chloride is handled, we believe Tfc poses an unnecessary and undesirable burden upon both the workers and the plant management. Workers in polyvinyl chloride'polymerization plants generally wear "hard hats." We assume that these hats fulfill the requirement of this paragraph. Here again, we believe the requirement is excessively restrictive. Personnel who enter and leave a polyvinyl chloride containing area will at most be carrying dust on their clothing Provision for removing this dust by, perhaps, a vacuum apparatus or the like should be suf ficient to prevent the dispersing of polyvinyl chloride into other areas. The present pro vision would be particularly irksome to those who are required to enter and leave such areas many times during the day. 000004773 Paragraph 1910.9 3g (i)(3) (j) <j)(2)(ii) 29 Objection Storage of food, etc. Emergency situations. Special medical surveillance Grounds The use of non-food chewing products should not be prohibited in regulated areas. Since no harmful levels of vinyl chloride will be in areas where employees are at work, we see no reason to deny employees their use of non-food chev7ing products should they desire them. In the event that the levels of vinyl chloride should rise above the maximum per mitted, the mandatory use of respirators will automatically preclude the use of chewing products. Likewise, we see no reason why the application of cosmetics in regulated areas should be prohibited and we believe j that, therefore, it should be permitted. J We believe that our major objections to this Section will be answered if the term emergency is properly defined so as to refer to a true emergency and not to an occasional accidental small-scale excursion above the permitted maximum. Certainly, in the event of any in crease in vinyl chloride above the permitted maximum, employees in the area will be re quired to don respirators and appropriate action will be taken to reduce the level of vinyl chloride. This term is not properly defined and we find it difficult to understand what is meant by it and what it is intended to accomplish. Acute poisoning by vinyl chloride would be treated as such more promptly than "within 24 hours." 00000477 Paragraph 1910.93q (j)(2)(ill) (j)(3) (k) (2) (k) (4) c n< Objection Contact with liquid vinyl chloride. 30 Training programs. Signs and labels. Labels for containers for polyvinyl chloride. Grounds We find it difficult to see what is intended to be accomplished by this requirement. The liquid vinyl chloride will have completely vaporized long before an employee contacting small amounts of liquid vinyl chloride can reach a shower. In the event of a massive exposure to liquid vinyl chloride, the employees 1 clothes will have to be removed and again, the remaining liquid on his body will evaporate almost instantaneously. Furthermore, exposure to massive quantities of liquid vinyl chloride will proBably pro duce physical injuries which will contra indicate this requirement. The need for this training program should be limited to those employees who regularly and routinely work in the area. Transient "authorized employees" such as truck drivers, vendors and the like, as well as those "designated representatives of employees observing monitoring" should be excluded from this program. The sign required by this paragraph should be amended to reflect permission to use cannister type respirators. Application of the requirements of this para graph should be restricted to containers of polyvinyl chloride containing 0.1$ or more of residual vinyl chloride. VVC 0 0 0 0 0 4 7 7 5 Paragraph 1910.93q (1) (1) (4) Cl) (7) (ii) (a) 31 Objection Maintenance and decon tamination. Maintenance or repair operations. Opened, blanked and tagged. Grounds This paragraph generally refers to decontamina tion of -materials. However, no generally applicable procedures for decontamination are available. Maintenance and repair operations will often not subject the employees to excessive ex posures to vinyl chloride. Requiring this paragraph for all maintenance and repair operations, therefore, is unduly restrictive.' The application of this paragraph should be restricted to maintenance and repair opera tions that require or result in exposure to high levels of vinyl chloride such as could not be adequately and safely controlled by the use of cannister type respirators. The use of whole-body air-supplied suits impervious to vinyl chloride should only be required when feasible engineering controls do not permit the lowering of the vinyl chloride levels in the contaminated equipment to an acceptably low level. The requirement set forth in paragraph (1)(7)(i) should be applicable here to define the required protective equipment. We believe that this requirement is very time consuming and unnecessarily restrictive of production. We believe the same level of safety could be achieved by requiring that the piping can be closed by a double block and bleed valve as an alternative. WC 000004776 Paragraph 1910.93q (1)(7)(iii) (m) (1) (m) (3) (n) (1) Obj ection Employee entering vessels. 32 Loading and unloading facilities. The respirator require ment . Polymer containers. Grounds This requirement should not be mandatory. Instead, a work practice requirement in cluding frequent- and regular checking by the personnel in a vessel combined with a reliable monitoring system equipped with an alarm will provide a satisfactory substitute for the "buddy system." h mechanical "standby" system requiring acknowledgement from the man inside on a periodic basis (every 2 1/2 minutes) has been found to be useful. The specification of a particular means for loading and unloading including inert gas j purging is unnecessarily restrictive. If thej maximum limits of vinyl chloride in the working areas are not exceeded, we see no reason why this paragraph should be required. The requirement that employees engaged in transfer operations wear respirators will pose an undesirable and unnecessary safety hazard' for these employees. If reliable and adequate monitoring assures that the maximum limits of vinyl chloride exposure are not exceeded, we believe it would be in the in terest of employee safety not to require the wearing of respirators. 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