Document XOo73kQRGobvVa17nYEkw8Mn4

t - STATEMENT bF VINYL CHLORI DE RESEARCH r HQ GRAY AY 'iIM1 ST ERE l> 3Y THE MANUFACTURING CKEM ISIS ASSOCIATION D R A _T Z ^NAGEMEMT REP HIES ENT AT IVES OF THE GROUP OF VINYL CHLORIDE AND POLYVINYL CHLORIDE PRODUCERS INVOLVED IN THE VINYL CHLORIDE RESEARCH PROGRAM ADMINISTERED BY THE MANUFaCTURING CHEMISTS ASSOCIATION HAVE REVIEW'ED THE PROPOSAL BY NIOSH DATED MARCH Uj 1914* TITLED "RECOMMENDED OCCUPATIONAL HEALTH STANDARD FOR THE MANUFACTJRE OF SYNTHETIC POLYMERS FROM VINYL CHLORIDE" ADOPTION AND I IMPLEMENTATION OF THESE STAN CARDS AS PROPOSED COULD FORCE AN IMMEDIATE CESSATION OF PUC PRODUCTION NATION WIDE* wS FEEL THAT BOTH THE REQUIREMENT TO COMPLETELY DECON TAMINATE AIR EXHAUSTED TO THE EXTERNAL ENVIRONMENT AND THE REQUIRED MAINTENANCE OF NON-DETECTABLE LEVELS OF VINYL CHLO RIDE WITHIN REGULATED OPERATING AREAS ARE GROSSLY UNREASONABLE AND CANNOT BE ACCOMPLISHED. NEITHER TECHNOLOGY NOR ENGINEER ING OR CONTROL METHODS TO ACHIEVE THESE RESULTS ARE KNOWN. OTHER ASPECTS OF THE PROPOSAL ARE SIMILARLY RESTRICTIVE AND IMPOSE ADDITIONAL SURDENS ON THE SAFETY AND OPERATING CAPA BILITIES OF EMPLOYEES. IN VIEW OF THE RECENT SERIOUS CONCERN REGARDING CANCER CAUS ATION THE INDUSTRY IS* AND HAS BEEN* CARRYING OUT PROGRAMS THAT ARE SIGNIFICANTLY REDUCING EMPLOYEE EXPOSURE AND* MORE SPECIFICALLY* ASSESSING EMPLOYEE HEALTH STATUS AND EXPERIENCE. IT IS BELIEVED THAT A STANDARD OF 50 PPM TWA INDIVIDUAL EXPOSURE CAN BE ACHIEVED*' MAINTAINED* AND PERHAPS BETTERED WITH AVAILABLE TECHNOLOGY IN EXISTING PLANTS BY MEANS OF : l <A> IMPROVED LEAK DETECTION AND CORRECTION (B) VENTILATION IMPROVEMENT CC) WORK PRACTICE IMPROVEMENT CD) EQUIPMENT MODIFICATION CE> PROCESS IMPROVEMENT REALIZATION OF THIS LEVEL SHOULD PRECLUDE THE NECESSITY Ft)R CONTINUOUS USE OF ALR SUPALIEB RESPIRATORY EQUIPMENT PROPOSED 1 BY NIOSH. ' IMPOSITION OF 'A "SPACE SUIT" TYPE APPROACH ON LARGE1 POPULATIONS OF EMPLOYEES fN THE PRODUCTION OF VINYL CHLORIDE PVC* AND PVC FABRICATED PRODUCTS INTRODUCES NEW SAFETY AND OPERATIONAL. RISKS ; WHIGH^HAVE NOT BEEN ASSESSED AND SHOULD NOT BE REQUIRED. ' ..... UE BELIEVE THAT-. THERE ;IS,.NO NECESSITY TO IMPOSE EXPOSURE RE GULATIONS' OF, TIIE SEVERITY PROPOSED BY NIOSH. THE MEDICAL AND TOXICOLOGIC EVIDENCE AVAILABLE TO DATE SUGGUST THAT 50 PPM EIGHT HOUR TIME WEIGHED AVERAGE EXPOSURE LEVEL TO VCM IS A PRU DENT WORKING LEVEL. THIS IS BASED ON SUBSTANTIAL ANIMAL TOXI-' COLOGICAL WORK AND HUMAN EXPERIENCE. THE ANIMAL EXPOSURE STUD IES OF MALTONI AND TORKELSGN SHOWED NO EFFECT AT 50 PPM LEVEL.' DOW CHEMICAL COMPANY HAS PRESENTED STUDIES OF ITS WORKERS OVER A SEVENTEEN YEAR PERIOD DURING WHICH TIME VINY*. CHLORIDE EXPO SURE WERE REDUCED FROM WELL ABOVE TO BELOW S0*PPM. IN SPITE OF DILIGENT SEARCH* NO CASES OF DISEASE OF OVERT CONDITION WERE FOUND IN THIS STUDY. UE BELIEVE THAT EVERY CASE OF SUSPECTED OR DETERMINED ILL EFFECT FROM VINYL CHLORIDE IN LABORATORY ANIMALS OR NAN HAS BEEN RELATED TO MUCH HIGHER LEVELS OF EXPO SURE ON A PROLONGED BASIS. OCC 0441 1 THE VINYL CHLURI OS MONOMER - PDLYVIXYL GHLOP.l DC FES IN 'PVCO INDUSTRY IMPACTS S J 3STANTI ^.LLY ON THE ECONOMIC LIFE OF THE NATION* APPROXIMATELY 50 MONOMER ANDr% RES IN PLANTS THROUGHOUT THS COUNTRY EMPLOY APPROXIMATELY i 4* SmC WORKERS. HUNDREDS OF PLANTS AROUWG THE COUNTRY* EMPLOYING AN ESTIMATED 50ji000 workers * PROCESS PVC INTO A MULTITUDE OF PRODUCTS WHICH* IN TURN* aR USED SY AN ESTIMATED 600*000 TO 903*000 MORE WORKERS TO PRODUCE GOODS FOR INDUSTRY AND INDIVIDUAL CON SUMERS. THE Value added by these operations is measured in BILLIONS OF DOLLARS. INDUSTRIES HEAVILY DEPENDENT ON PVC PRODUCTS INCLUDE BUILDING AND CONSTRUCTION* AUTOMOTIVE* MEDICAL PRODUCTS* ELECTRICAL WIRE AND CABLE* HOUSEHOLD FURNISHINGS* INDUSTRIAL AND HOUSEHOLD EQUIP MENT* AND PACKAGING PRODUCTS. OTHER POLYMERS CONTAINING VINYL CHLORIDE ARE USED IN FIBERS AMD SURFACE COATINGS. IN MOST CASES* A WITHDRAWAL OF PVC PRODUCTS FROM THESE INDUSTRIES WOULD RESULT IN; SUBSTANTIAL SHUTDOWNS OF PRODUCTION BECAUSE SUBSTITUTE MATERIALS EITHER DON NOT EXIST OR COULD NOT -BE MADE AVAILABLE IN ADEQUATE QUANTITIES FOR MONTHS OR EVEN YEARS. VINYL CHLORIDE MONOMER IS THE SINGLE MOST IMPORTANT MARKET FOR THE CHLORIDE-CAUSTIC `INDUSTRY* ANOTHER BASIC PART OF OUR ECONOMY. A REDUCTION IN THE PRODUCTION OF CHLORIDE FOR VINYL CHLORIDE WOULD RESULT IN A SUBSTANTIAL WORSENING OF THE PRESENT SHORTAGE OF INDUSTRIAL ALKALI INCLUDING.THAT NEEDED FOR ENVIRONMENTAL CONTROL PROCESSES. WE BELIEVE THAT THE ADOPTION OF THE PROPOSED STANDARDS WOULD' RESULT IN A VIRTUAL 100 0/0 SHUTDOWN OF PVC PRODUCING PLANTS*MM2DIATE UNEMPLOYMENT OF A SUBSTANTIAL NUMBER OF THE WORKERS WHOLLY OR PARTLY DEPENDENT ON PVC PROCESSING FOR PVC PRODUCTS WOULD RESULT. COMPLETELY NEW PLANTS* USING TECHNOLOGY MOT NOW EXISTING* WOULD .HAVE TO BE DEVISED* THEN BUILT TO REPLACE PRESENT PRODUCTION .FACILITIES OF THIS INDUSTRY. ECONOMIC FEASIBILITY OF J5UCH RE BUILDING IS HIGHLY QUESTIONABLE IN THE FACE OF THE PROPOSED RE FLATIONS AMD* IN ANYJSVEMT* A PERIOD OF AT LEAST FIVE YSAJJS WOULD BE REQUIRED EVEN IF'FEASI BI LITY WERE ASSURED. 1 IN VI.EW OF THE ABOVE OSHA SHOULD CAREFULLY DEVELOP STANDARDS FOR EXPOSURE.TO VINYL CHLORIDE USING THE REGULAR RULE-MAKING PROCEDURE.^-WITH SUCH A PROCEDURE* IT WILL BE POSSIBLE TO MOVE FORWARD^I|JAN ORDERLY FASHION WITH NEEDED OPPORTUNITY TO REVIEW IN DE'pfH^CLvOF rTHV FINDINGS OF SCIENCE* LABOR* AND INDUSTRY AND THE^REGlfLTAXORYfciMEASURES THEMSELVES. SUCH A DETERMINATION WILL' NOT.CBliLARBITRARY OR CAPRICIOUS* NOR WILL IT OPERATE TO THE SUSS TAN TI Al*?r DETRIMENT OF CONSUMER* LABOR AND IMDUS"RY AS SEEMS INEVITABLE WITH THE HASTILY-C0NC2IVED. PROPOSED STANDARD OF NIOSH. THE REGULAR RULE-MAKING PROCEDURE SHOULD BE USED TO ESTABLISH REGULATION OF THIS INDUSTRY WHICH TOUCHES IN A SIGNIFICANT WAY UPON A SUBSTANTIAL SEGMENT OF THE AMERICAN ECONOMYM RICHARD FLEMING/APCI END/KM A + MJA USH VF % OCC 0442