Document XOJ2JZ0KgdL8VeK3NgJwzNe7d
m <N t" fO
as
U O P
Hit. Nt. W YVriK l,jrfL5, SllNLtAY, itLCY.Kue.lt a. 1915
i-\ *
How Polyvinyl Chloride Met Health gules
. , ,,___________ . cnlmi-utf from r<-^c J
- of the cc^ji|>-c,r,A<;, led by
- f new Ch&p" di Company,
:mt eperatm
n-it isre-i
srt*en the O-SK . .mount e-
--came on March 22,
rr~\.
C oneentration j-omeum es
r.iz run to 4U.0UQ or 50,OtW
-tr. per million previous'.',;
a-c the iisk v.n` bHiurd
- nated Bu! tht.i i^n ra s
oosed to 50 parts per mil-
___ , <k. Kors iheu Although the rata
died of other cause--, aulop* ,u*c .hmfted the presence of
i2-.j3an.oma ar.d in April* O'-'HA moved to * standard ijf '`no detectable" concentranon as measured in the air.
The chemical companies argued that the "no deiectablr" standard would close the mdusirv and bring on ration' a' economic disaster They ei en offered a study vwrnmf
th.a..t -a -luidowri would put
. . .a* i--T mr I
2.2 million people ou! of
work anti cost the economy
iS5 to sail hiUlf n
Bv October, inev had con
vinced CLHA to ,nange to
a 1 part per million average
with brief exposures to high
er levels perm hied emis
sions could go to 25 parts
per xri'Mmn iJ workers wore
respirator*. but the respira
tor requirement was delayed
by one year lo Apnl l, 1976.
` OSHA officials now say
that the effects of those
changes were minimal and
claims bv the indudrv that
they made all the difference
were "a Uttie face-saving se-
l maritiC'M
v" But by spring. 1974 most
companies had real tied the
final standard would be
lough and that the nme had
come to try to comply.
Thus discovered that In
coiTVerunJ'lilp Hki to poly
vinyl chloride resin. large vi
nyl chloride gas leaks into
the atmosphere were devel
oped. And for the more than
1,000 companies that shape
the resin imo ils final lorm,
the unconverted gas in the
resin was being liberated
during the reshaping*
Reducing emissions in the
plant1; turning Mini chlor ide gas into PVC, a powder, was the major prohletn-
Respirators for workers in polyvinyl chlo ride plants will become mandatory April 1.
Some techniques were frasy: telling woii.ers not to use oped a new process to re
the supercooled gas to re duce the necessity of clean frigerate soft dnnks and not ing reactors -- thought to
to wade ankle-deep in the have been a major exposure
powder inside the i,100-gal- point It then moved ahead
lon reactors. But getting down and developed a new "strip
to 1 part per million means that a single pmiiole bet omes
-ieve the companies say.
ping" process which reduces 3he re?id:ia5 vinyl chloride
''Jt's iust flufgftig leaks.*** in ih resjn to the "no
id Mr Wheeler of UniW* detectable'Mevtl This Mows
rirbl?e There's no magical LltB laBUckluiiS lo avoid tcgii-
way you ran gri there."
Idiwg emission lei el* in. their
Goodrich, though, devel- own plants.
\1though n ost of the at tention hav fneused on the existing 54 PVC plants, Robintech Inc. and Goodrich have designed new plants
wtth-technolngi pxpc-cied to
completely eliminate the emission problem.
OSHA acknowledges that the progress has been re
markable. *T Louldn'i be
more pleased with the ap parent success and pro
fgt.-w.r."airadm CCrr..Jr 1.1 \1jenn. acting il inr of
nilard dexelvp'renis "t hunk irn, fe* people .n mtlussrv had uri rM,males of vbat could be ifti.n "
Most nf ihe PVC prr*] n ers ave leduced em.ss.r*. lo Bljout 2 parts per million ir they can readi 0 5 part per million. OSifA allows thm to relax The nKui'oring recmreinents "but ilia! last mile is preUy difficult" said John L Nelson. mnula'turing vice, president of Good rich j
Gdrbing the 'missions, however, wasn1: theap Goodrich sa\ s the effort was the largest reseann ai,d de velopment program in us hislorv, involving J30 scientists and engineers 425.000 manhuurs ol work and S.14 mil lion in capita) costs The Society of tne Plastics Indus try estimates the industry costs could run up to S3QO
,
7>
' 4 '
'v
'* \ \. ^ ^
Js'7
i*
mmiillklioTMn And jr-duslry spokasmen sav [he regulatiora lourer productivity' and will add Id to 15 percent tn the cost
of manufacturing PVC. Goodrich, however, notes
it ran lea&e its new cleanup (ethnology to others, and that the new equipmenl cuts labor ensts
And the cost increase eompfamts aren't as impressive v.rhen corripared to tne natur al pnee swing' PVC is down to about 21 ecu is a pound today (although [here are sign' that price- are about lo me frcMii 24 cents in 1974 because of the recession-- *ales are down about 1 bii- lion pounds from the record 4 7 billion of 1&74 And the cleanup price pales beside the doubling of PVC raw materia) costs over the past tw o years
Fight now PVC makers be lieve their biggest problem may be public relations. The
PecWaV TVi's Alnrr;"itfa
is pr<'
to ban
Ivpes <ji f VC lwft pavV.^tiig
on the gtOiiridr that res.uat
vinyl thlonde migrates Lnin.
the food
"People m'ghf begin to
think- 'If it a not good
enough fo- food, n rr.ust r,of
be good to base t<<*
wrapped in it," said TVms
B Nan+z, excuutive v.ce
pres .dent of the parent Gcix.-
neb tt>rrpary. who predicts
a PVC growth rate of about
8 percent a vear Thus, t/ie
chemical maker* haie beer,
runnirig arlierliMng mitunuz
in;Ztbe 'y-anii dangers
Certainji* r-ne s:gn of the
prospects for the chemical
was the recent announce
ment by the Diamond Sham
rock Corporation that it
would build a new $100 mil
lion vinyl chloride plant near
Houston, `.V-e lira to be an
nounced since the cancer
scare started.
n
i a i
j.
Jl ; li V fj '
r. ,
i! [
Kctivi)
M ' a^NHoUf)
OCCUPATIONAL SAFETY & HEALTH REPORTER
Compliance Programming, by telephone, 202/961-2884/3971,
If the OSHA National Office determines that the specific working condition is covered by FRA authority, the com plaint will be referred directly to the National Office of the FRA, unless they request direct referral to their Regional Offices. If a complaint is involved, the complainant shall be notified in writing, by either the National Office or Regional Office as directed, of the disposition of the complaint.
h. State Plans. (V, Routine Slate Inspections. States with approved 18(b) plans should be advised of these guidelines for conduc ting routine railroad inspections. The scope of State coverage in the railroad industry is expected to be equivalent to that provided by OSHA, unless it has been determined that under the particular State plan, coverage of the railroad industry is excluded under 29 CFR 1902.2(c). (2) Referral to Operational States. In States that are determined to be operational under 29 CFR 1954.3 and OSHA Program Directive #74-11, all employee complaints and fatality and catastrophe investigations involving working conditions in the railroad industry within OSHA jurisdiction as defined in the preceding paragraph 4(b), will be referred to the State in accordance with the State's operational agree ment. The procedures in the preceding paragraph 4(g) should be followed for complaints or portions thereof not within the defined OSHA jurisdiction. 5. Effectivo Date: This directive is effective immediately and shall be retained until superseded or amended.
Field Memoranda
SHA SAYS DISCHARGED EMPLOYEE OMPLAINTS SHOULD BE DEEMED VALID
Workplace complaints filed by someone who alleges to have been discriminatorily discharged should be deemed valid complaints and promptly investigated, according to Field Information Memorandum 75-1 issued January 3.
The clarification was made by Occupational Safety and Health Administration Associate Assistant Secretary for Regional Programs Barry J. White regarding Section 11(c) and Chapter VI, Section A.2.D.(1) of the Field Operations Manual. The text of the memorandum follows:
"For the purposes of submitting a complaint, an `employee' would normally be a present employee of the employer whose establishment is being complained about. However, in some circumstances, it may be a former employee; for example, where the employee may have been discriminatorily discharged for a complaint about unsafe or unhealthful conditions in the workplace."
Field Memoranda
OSHA INSTRUCTS FIELD TO RESUME INSPECTIONS FOR VINYL CHLORIDE
Inspections for vinyl chloride should be resumed im mediately, Barry J. White, associate assistant secretary for regional programs, Occupational Safety and Health Ad ministration said in Field Information Memorandum 75-4 issued January 8.
The memo reiterates OSHA's position to enforce the provisions of the levels of the temporary emergency stan-
ard, which expired October 4, but which are similar to the
A Health Reporter
CURRENT REPORT
first stage of the permanent standard which has been stayed by the Second Circuit Court of Appeals,
The text of the memorandum follows: "Attached for your information is a copy of the memoran dum to Assistant Secretary John H. Stender from the Solicitor of Labor; dated January 2. "With this memorandum as a basis, I am directing that in spections for exposure to vinyl chloride be resumed effective immediately. ` "Subsection (o)(I) of 29 CFR 1910.93q dated October 4, 1974, page 35898 of the Federal Register [Reference File 31:5343] shall continue in effect although the date is past January 1, 1975. Citations shall be on 1910.93q(o)(1) published October 4, 1974. This means that until further notice all the provisions of the emergency temporary stan dard (ETS) for exposure to vinyl chloride dated April 5, 1974, shall be implemented and enforced. The April 5, 1974, provisions are found on pages 12342 through 12344 of the Federal Register of that date. "The amendments of December 3, 1974, in the Federal Register shall not apply nor shall any of the provisions of the October 4, 1974 pages 35896 through 35898 apply except 1910.93q(o)(l) on page 35898. "OSHA Program Directive 200-29 (Current Report, May 23, p, 1622) of May 22, 1974 remains in effect."
Solicitor's Memo
"The solicitor's memo to Stender referred to in the Field Information Memorandum pointed out the government's request for clarification from the court on its order (Current Report, January 9, p. 925). The memo explains further the Labor Department's position that the stay of the standard refers only to the "second stage of the standard," which re quires respirators and a 1 ppm exposure ceiling.
Field Memoranda
OSHA DISCONTINUES ENFORCEMENT OF MOCA STANDARD, RELATED LABORATORY ACTIVITIES
Occupational Safety and Health Administration com pliance officers were instructed to discontinue enforcement of the standard for 4,4'Methylene bis (2 chloroaniline) (MOCA) in 1910.93e, and laboratory activities for all 14 car cinogens in 1910.93(c)(6) through p(6)(3).
The order was issued in Field Information Memorandum 75-2 on January 7 and was signed by Associate Assistant Secretary for Regional Programs Barry J. White. The text of the memorandum follows:
"The standard, 29 CFR 1910,93 4,4' Methylene bis (2 chloroaniline) MOCA has been vacated and remanded by a court decision. Simultaneously, the 14 laboratory activities subsections of 29 CFR 1910.93c(c)(6) through p(c)(64 were also vacated.
"Therefore, you are directed to immediately discontinue enforcing the MOCA standard and the laboratory activities subsections (c)(6) of 29 CFR 1910.93c through p.
"A new MOCA standard is being prepared by the Office of Standards. New laboratory subsections (c)(6) for the re maining carcinogens standards are being prepared also.
"This memorandum is effective until further notice. Please notify all area offices and agreement states accor dingly.
"Questions concerning the above should be directed to Ray McClure or Flo Ryer, Division of Occupational Health Programming, Room 760, 1726 M Street, N.W., Washington. D.C. 20210."
VCC 093724