Document XRwgE485eOG15bvyGb4GMVYgx

(conoco) Interoffice Communication To Gary Draper From Tom Grumbles Goto December 8, 1981 Sub^act INDUSTRIAL HYGIENE AUDIT OF LAKE CHARLES CHEMICAL PLANT I would like to do an industrial hygiene audit of the Chemical Plant on January 20, 21, and 22. The emphasis of the audit is an overall review of the Plant's industrial hygiene activities, and the extent and adminis tration of policies relating to those activities. Although a walk-through survey of the plant will be conducted, this is not an "inspectionoriented" audit. On the first morning of the audit an opening conference will be held with you and other staff personnel involved in the audit. During this time we will further explain the audit and arrange times to see other plant per sonnel as necessary. These would include engineers involved in health and safety projects, the laboratory director, and others involved in the industrial hygiene activities. A closing conference will be held on the last day to discuss audit findings and report content. The audit criteria is enclosed for your review. Let me know if you have any questions on the content or audit process in general. Also please let me know if the above dates are acceptable. Further details will be supplied at that time. Thomas G. Grumbles aj o Enclosures cc Sid Pitts Ralph Ferrell OCR 000001668 f\o<bt n . L Union Carbide Says Byproduct Causes Skin Cancer in Mice ** Tests by Firm Disclose Effect Of Pyrolysis Fuel Oil; 50 Workers Directly Exposed }9 By a WillStrkctJock.'ial Staff Reporter NEW YORK--Union Carbide Cora, said it found in laboratory testa that certain tarry residues, whirh art*^a-hv-proriuet of its-olefin operations, cause ski" rrinr-pr in mire The- residues, known as pyrolysiafiuX-oU, come from the company's operations that make olefins, a <rroup of haste chemicals used to make other rh.-miml* and plastics. Pyrolysis fuel oil produced by Union Car* bide is used as a supplementary fuel at ole* fin-operation sites, including Tail, La.; Texas-City-and Seadrift, Texas: Torrance. Calif., and Ponce, Puerto FJco. Union Car bide said about SO workers are directly ex posed to the fuel oil. The company made these tests during a two-year program at Carnegie-Mellon Insti tute of Research to monitor the potential health hazards of its products and opera tions. Union Carbide aaid it has submitted its findings to the National Institute of Occu pational Safety and Health and to the indus trial processors who buy a small amount of the oil from Union Carbide. Union Carbide said the mice were painted with the oil three times a week on the skin of their backs. Nearly all the mice developed skin cancer over 19 months. A few of the animals also developed other types of cancer. fm iJ of human exposure to the oiL " Union Carbide said the workers involved in handling equipment that may expose them to the oil wear protective clothing and where there is a chance of exposure to liq uid mists, a filtered air respirator. The com pany added that a task force will reexamine olefin operations and work practices and de termine if epidemiological studies may be appropriate. i CCR 0000016&7 CONOCO CHEMICALS: INDUSTRIAL HYGIENE AUDIT SYSTEM Basic Goals: Procedure: Audit Team: 1. To assure chat all feasible steps are being taken to adequately protect the health of Conoco Chemicals employees. 2. To assure compliance vlth federal and local regulations. 3. Assess adherence to company policies and good proactlce. 4. Identify areas of need based on the above and make recommenda tions to aid in meeting those needs. Each plant will be audited at least every two years with actual frequency determined by need. The audit will be conducted in three phases as outlined below. 1. Pre-Audit - prior Co the audit the plant will be contacted to arrange a time of visit agreeable to all. The time spent in the plant will vary dependent on size of the plant and extent of the existing program. The plant to be audited will be notified of the audit criteria to enable preparation of necessary materials for review and assure the availability of key personnel to be interviewed. 2. Site Visit - the on site audit will consist of two basic parts. a. The majority of the audit will be performed "in-office". An opening conference will be held with management and other affected staff personnel to describe the purpose and process of the audit. The major activity will involve review of written programs, air sampling data, recordkeeping, and overall administration of the program. The specific aspects of this review are attached as Appendix I. b. The second phase of the audit will involve a walk-through inspection of the plant. This walkthrough will be done in OSHA style to identify obvious areas of non-compliance as well as allow for an assessment of administration and success of written programs. c. A closing conference will be held with appropriate plant management before the audit team leaves the plant. Audit findings, preliminary recommendations, and report format and distribution will be discussed. 3. Post-Audit - A written report of the audit findings will be addressed to the plant manager, with a copy to the Vice President of Operations, General Manager of Manufacturing, and Medical Director. The audit will be conducted by the Director of Industrial Hygiene, a Corporate Medical Department Hygienist, and a Person involved in hygiene activities from another Conoco Chemicals Plant. 00000166? CCR INDUSTRIAL HYGIENE AUDIT ON-SITE CRITERIA The following items will be considered where applicable to the given facility or operation under review. This list is a guideline and not intended to be all inclusive or totally limiting. A) Program Administrati on TJ 'Definition of Responsibilities (Departments, People) 2) Structure of the program 3) Administration of the program 4) Communications (in-plant, external) B) Review of Written Programs TJ Chemical Exposure^batement Programs 2) Written determinations 3) Portions of Safety Procedures with reference to industrial hygiene procedures (if applicable) 4) Other specific programs (i.e. Respiratory protection, education pro grams) will be reviewed at other times during the audit. C) Plant Recognition of Hazards TJ Chemical^i :resent in the plant 2) Current list of chemicals 3) Availability of MSDS's or similar information on chemicals in the plant 4) Communication with the purchasing group 5) Review of new chemicals.or new uses of chemicals in the plant 6) Periodic review/updating of material 7) Inventory of radiation devices D) Hazard Evaluation Programs TJ Sampling program review a) what agents/chemicals are sampled b) sampling frequency c) criteria for sampling frequency 2) Program Administration a) placement of sampling devices b)' observation of sampling c) job/task information for overexposure determinations d) sample retrieval and labeling e) sample storage 3) Sample Analysis 4) Reporting of Results a) format b) distribution 5) Input to Industrial Hygiene Computer Storage and Retrieval System 6) Sampling Records 7) Sampling Equipment and Methods a) what's available ccr oooooia b) Calibration of equipment (frequency, records, methods) Page 2 E) Hazard Control TJ Review of specific control procedures 2) Input and review of proposed process or equipment changes 3) Evaluation of newly installed controls 4) Ventilation systems review a) needs and use b) testing of devices (hoods, exhausters, etc.) c) maintenance of systems d) records of inspections 5) Respiratory Protection Program a) review of program for compliance with OSHA regs b) administration of program c) record keeping 6) Other personal protective equipment a) need b) selection c) availability and use 7) Radiation a) surveys by qualified person b) test of on/off mechanisms for sealed sources c) permits F) Review Of Exposure Records TJ Regulatory compliance 2) Compliance with company policies 3) Record keeping G. Education Programs TJ Present program review 2) Frequency of training 3) Administration of programs H) Medical Surveillance Programs TJ Administration of program 2) Results of review of program previously done by Dr Massad will be discussed I) Storage and Handling of Hazardous Materials TJ Facilities 2) Equipment used 3) Methods used 4) Labeling/identification in plant J) __ General Sanitation TJ Eating faci1ities 2) Restrooms 3) Change rooms 4) Potable water supply 5) General housekeeping K) Employee Awareness of Hazards 1) Personnel interviews to be conducted 2) Work practices observed nooooi&7i L. Miscellaneous TJ Sign-posting in plant ?y 1 *rht levels in work areas