Document YDGn9Kxaryw3qpoJ06aL9kMOV

'j'fflaVftrfiC , '-'r J >, i-f, Ji i- 't ';: i^sigteWSS 1 ^Cp-<' '___ ,ot RAL COMMODITIES 7^v'' ,. ` . FOR COMPLIANCE WITH OSHA STANDARD ON VINYL CHLORIDE AND POLYVINYL CHLORIDE (Published by Safety Department, American Trucking Assns, Inc. 6-1-75) y.'r Motor carriers are now subject to OSHA standard . Shippers should then be contacted to determine the ; 719,10.93q which sets forth requirements for protecting general nature of materials being shipped, the general :: employees safety and health when shipments of vinyl levels of hazard and the assistance that they will give the ^"chloride and polyvinyl chloride are handled. - carrier to monitor shipments of VC and PVC. j General information about the. hazards, monitoring In its contact with the shipper the carrier should as t % procedures and employee training is set forth in Appen- certain:-'^ .. , ... , = C'drx I..In response to the requirement for training carriers 1. The various .types of PVC being shipped, fre- may want to issue a bulletin of a type similar to Appendix " quehcy and size of VC and PVC shipments, gen- - >wl,-to their employees. The information is based upon a ... , eral exposure levels for PVC. "premise that the exposure level for vinyl chlonde will be 2. If the1 shipper will provide special identification on v- very low in motor carrier.operations and thus only a ... . ..Ci- /.shipping papers so that PVC shipment# can be 7 ^'minimum, compliance program ,is required. If,j after _ - ^easily identified and not confused with oner ship- . a".Imonitoririg.-acarrier,determinesthat exposure levels are ? . v . merits of plastics. ' - ........- ^-?7higher. than expected it 'will be necessary to establish a ; .. -3. lf the shipper can assist with monitoring by provid- - - ^^^more"detailedvp"rbgVam'?hanithe^rninimum. j -sV-S: .- v_ ,7;>%'n9 technical people to do the monitoring. by pro- : ; PVC sKould obtain a -U. 'C . viding personal monitoring units,'by analyzing r, - .-^i^^isc^Bf.'tji^^a^te^tanBarcl^which.iis contained ^IliEe&efciiRfegister^bTbme^^^ ' *samples. ^ wilUssujilhat^fXJsure level^are^belw^ ^r^^^S^ritibb^5^iieffi^iibup^first^reacJ.^Appendix,-|. _for5^.^;thet"a$i^^ shipper will ' ^ 7 4-T^^ge^ral iihfofriiatbh abd shduldithen read the following notify the carrier of any 7 .r^rti iron rtf ar'tirtn i " nhsnriP thflt "Aa/III ^dditiofidl ^ ^ FAGTIOKBl^di............... ... ..., . ... _. .............. IMt^^^^^^^-^v^^-^^MONITORING 4 ^'^i^Manufactarers^ofvinyl"cl. Mnd&andpolyvinyfChloride . "V . ' - -. j',t?". '-I , ' ~y- i-^^ave indicated -they will (C&riers in carrying out the : VThe .second step of a motor carrier prbgramjn 7sgipip ffrst.step toward com- ^imonitbring. "Some., information,about monitoring, is pro- ^ ftsyaw--* *" videdin'theAppendixfor'employees but is presented c a)" Review,past, .-V- ::^:|;Sf|t=tarr| fments to determine bMocuments VC will be blonde" and classed as jafgas'V -Documents for herein in greater detail for management. When monitoring exposure levels, air samples must be taken at the level of an employee's mouth and nose -- his breathing area. Personal monitoring units clipped to ?describe :the shipment as his shirt serve this purpose.-Samples of air at floor levels .^ some documents :AV7,.,-Athe words 'polyvinyl chloridet will be shown in ad- dition to'the shipping name. :7.7; ' b) Check freight containers to determine who the -7 -. shippers.are. Vinyl .chloride will be in cylinders vi-V^vA Tjbearing the label "Flammable compressed gas" fv C. and a label "Cancer:suspect agent". ,i Polyvinyl should not be used because vinyl chlorides are heavier than air-and tend to settle at floor level -- well below the employee's breathing area. . ..- There should be monitoring for each shipper and for each of his products that may have a different exposure level, as the exposure varies according to manufacturing' ' processes. If a shipper changes his processes and ex- -r ; chloride may be in bags, boxes and drums and posurSWevels are increased there must be additional ' .will bear a label reading ", . contains vinyl monitoring. .chloride. Vinyl chloride is a cancer-suspect The exposure level also varies by time and tempera- ' - .agent". ? i'y,i - ture- Thus the monitoring should be after a vehicle has SL 098159 had time to venti" ure levels, if any; will be higher immed |pr<|pors are opened but the process of id backing the trailer to the unloading pi -wilt reduce levels. The carrier should monitor immediately after the trailer is moved to the platform, and again after it has been at the platform - medical surveillance records mbst- be kejptPSr^ci if regu- s lated areas are established there mlist be' records of / persons authorized in the regulated areas. Itdoes not ' appear likely that motor carriers will have an exposure level above the "action level" of .5 ppm and, if such is the case, regulated areas and medical surveillance will not for 10 to 20 minutes to determine if the additional time lag be required.. > " ' - reduces exposure levels significantly. If such is the case, Monitoring and measuring records must be kept for the carrier should issue instructions to employees that VC 30 years and state: date of monitoring, concentrations and PVC shipments should not be handled until the trailer determined, identification of instruments and methods .has been open for a specified period of time. used. They must also include any additional information . The exposure level varies by size of shipment. necessary to determine individual employee exposures , Truckloads will probably be handled by shipper and where such exposures are determined by means other : consignee and there is no responsibility on the carrier if than individual monitoring. his employees are not exposed. Monitoring of LTL should Monitoring and measuring records must be open for '-/.be for.the largest shipments usually loaded and un loaded by carrier employees. Monitoring of dock operations must be carried out if examination and copying by employees or their desig nated representatives. Former employees may examine and copy records of their own exposure. . '. ... - VC and RVC are to be kept on the freight platform. A written report must be made to an employee within ,,; ; Results of the monitoring are obtained through use of ten days after his exposure to levels above the permissi an analyzer. The samples taken are processed through ble limit,'without regard to use of~a respirator. Such a /the analyzer and the results are averaged over a time / report must tell the exposure level and steps being taken - *;; / period to determine the exposure level for a 15 minute to reduce exposure to allowable limits. / If; ; S'-period, and for an eight hour period. If the exposure level Reports are required concerning estarashment of /is at or below the "action level" of .5 parts per million for 1 . regulated areas but this does not appear tojje applica- .' ///eight hours thejcarrier is allowed to conduct a minimum > ble to motor carriers because of tow exposiire levels,. i Lt the/ievel is at or below one part; per million - `.City*"' TM i. ,* * y ; v/pi^rthe.(evelisLaboveione partIper million,br: 5 parts per /;-/ ADDITIONAL REQUIREiiiiNTS inHnT 5.mintrtes;/theicarriermust;establish admmis- ^tratiye^nd/engineenhg*-dontrols^to* reddce/exposure f.Iflievqls'carmbt be reduced sufficiently through quarter.Monthly'monitoringis.'r^iredrT^p|te\Lr-. -.^ T-^admihistrative^d engineering controlsfthe carrier must /^respirators, if exposfa're'tlevels are above /permissible`ll K:--` ---------- -i--'*.------------ 110 limits. / \a- -.Regulated areas are/required/if concentrations/are^s 1 above permissibie jirhits^and; only-authorized persons'^ ; //.can have access to such'areas. Daily rosters mustfbe^ ji * r^^InfbririatiOTS^^i^in.iridVKtre mlijryc: entsffs?provided in kept of persons who enter such areas.' L ?}.*$ ;p.endix^_ if,jt. wants to T?^ssueemploye$ iirpilaf'To that in Ap- If such controls do not bring levels to permissible limits ; -.vivpendix.frbi3ik' * 'sive trajning .''.X :e levels'qpqeSsitate rnore exten- . they must be used and. supplemented by use of pre- T SyS* * -i.<v' v ,- t'* '' ' \ '_ ./scribed respiratory equipment. Written plans for such /- controls must be developed.and available to OSHA rep- -'fTf.7 yj.. RTS ff:; ; resentatives. / > -' \ " OSHA has provisions for "hazardous operations".and T, ' - r. / a .The fourth step/for a motor carrier, program is to "emergencies" but these are designed for manufacturing ' / establish a system of records and reports.. In addition to operations and do not seem applicable to truck opera- i / required items the motor carrier should keep a record of tions, except possibly 'for bulk transportation of vinyl // .. / every effort it. has made toward compliance with OSHA chloride. These provisions do not contemplate the hand/ vv- .requirements.;Thus'.documents, relating to shipper qon- ing "of PVC in powder, pellet or liquid form. tacts, fevjew bf shipping records, etc. will indicate to an ' t "Hazardous operations" are those where a release of T . . TOSHA inspector that, the carrier is*making a good faith ' vinyrtSworide liquid or gas might be expected as a con- . ' ' effort to comply, even though its compliance program sequence of the operation or of accident which would might not be in full force. result in exposure in excess of limits. , ? . The basic record keeping requirement is that there An "emergency" is defined as an occurrence which is / ' must be a record of monitoring and measuring. If there is likely to, or does result iryarnassive release of VC. It does // v SL 098160 ;S "jr - - - V.'/- 7' v:;t -T''^'v^vVS' *- T , ' - -*. j" not seempossible that a g rieral freight barrier can haye such a release because of thesmafl quantities of VC ; handled and the integrity of the VC containers. Carriers should obtain copies of the complete stan dard for a full understanding of, what is required, and so that they can determine its applicability to their opera tions. ' \ . `y, s ' ... / D.O.T. JURISDICTION The Department of Transportation exercises jurisdic tion over vinyl chloride gas and thus it does not appear to ATA.that OSHA has jurisdiction. Informally. OSHA has claimed that D.O.T. is exercising jurisdiction only over the W&X :r.= . . / flammaBility and comjaf^^icljgas hazards (OSHA) has jurisdiction ov rjhe carcinogenic (cancer) T hazard. The ATA position Is that D.O.T. is exercising 1 ' jurisdiction over the commodity and protects employees from hazards of flammability, compressed gas and car cinogens because of its rules, including those governing type and strength of containers. Until this difference is resolved by the agencies themselves or in a test case, the motor earner handling vinyl chloride must determine for himself what course to follow. D.O.T. does not regulate polyvinyl chloride and thus it appears that OSHA has jurisdiction to promulgate these rules. ` _ ` ,, fV V-.'H' -'k ' - '.r'' l * 3 . ; i- ;jSi v' . ffr-rzska - i, x: "`.^T ~ -i. *- -J--Tr~d~* ` * 'J'fi r^T , ' ' . - _ jW-- * 1 rP -,>? ' .v * ... , . v' , V S SjPv SL 098161 ;f^XSKy 'V, ;r 4 appendix i OSHA RULES COVER TRANSPORTATION POLYVINYL CHLORIDE OF VINYL CHLORIDE AND POLYVINYL CHLORIDE Polyvinyl chloride represents approximately 40 per cent of all plastic materials moving by truck. Estimates ' To help assure the safety and health of employees, are that more than 2 billion pounds move annually by the Occupational Safety and Health Administration has motor carrier. PVC may be in the form of powder, pellets .. established rules that govern the handling, including or liquid, thereby moving in bags, boxes and drums transportation, of vinyl chloride (VC) and polyvinyl when it moves in van type vehicles. - chloride (PVC). Shipping papers will read "Plastic Materials, NOI", The rules were designed primarily for workers in . but not all plastics are PVC, and not all PVC shipments plants and factories where VC and PVC are made and - are subject to the OSHA regulations. Those that are sub where employees may have exposure to high levels of ject to the regulations will have a label on containers . VC gas or liquid. Thousands of workers had contact with which reads "Polyvinyl chloride (or trade name) contains . the vinyl chloride gases during processing since the vinyl chloride. Vinyl chloride is a cancer-suspect agent". 1940's. It was found that a few workers having worked in Exposure hazards for PVC are usually very low. .. processing for an average of 19 years developed a rare Employees should be aware that PVC itsel| is not ` form of liver cancer. , ' . , hazardous and thus there is no danger from accidentally Exposure of transportation workers is not comparable coming in contact with the material. The exposure hazard to that of manufacturing employees because of differ- is due to the possibility that some of the vinyl chloride gas r: - ences in the nature,of their work. Transportation workers ; may be trapped ir : have low .exposure. because they^don't handle VC and - the atmosphere: pVC in the same form as-manufacturing employees and :- . because they handle it infrequently and for short periods SUMMARY OF THEIOSHAlREQUIREMENTS^i^ T^f time.^Theirexpqsure is^also lower because of protec: -- " T??fion^bffefed by^acj^irig/and because new-iproduction1^ ; v(rthe basic' rule ,i^;ff^^^emplpyeeKca4r-ii'(no5^^-be1T ex-*^^ '#methbds-for PVC have-reduced the presence of sub- . posed to a ratio of .mdre(th^-;bneVparf;of 'vihyirchlbfideli^Aik; .stances that might cause cancer after longtime and high .(level expbsure^The danger to trucking company ( ;employees is - believed to - be very low arid almost nil. (continuous 15 minute period. The exposure .is on-aTime 7g|p Nonetheless,-iOSHA has ;made the; rulesrapplicable to r- (Weighted basis, and so, for example,^an employeerex- .i^>" ;' -_, ' t? truck operations:just ;as they didfor the companies that - ^manufacture thesefmaterials. ^ Sv ^jr .(...v" C 7 ' ,'.V~ posed to 4 parts per million for a one hbur period is not.in . `(.`(y excess of the limit of one part per million for an eight hour(fei ^ 7 ..Ai. .7 '> r*. * |VINYLCHLORIDE( `day. The time weighted-average (twa) for such-an employee.Tor eight hours,:would be (5 parts per million! .'(('f' ..Shipments of vinyls i are classed as flammable compressed gasesar^ we primarily in tank trucks and OSHA provides that employers can establish a ' / minimum program of activity if employees are not ex- ' >. posed above an "action level" of .5 parts per million (twa) tank cars. They hardly ^er- move by van type vehicles for an eight hour day.. The minimum program require- - but when they a^he/are;in fcylinders. V : ^ " Vinyl chloricle wiil^belisted on shipping papers as ments for a trucking company are: 1. Monitor exposure levels to determine if there is any '"Vinyl Chloride"-:and classed on shipping papers as " exposure above the action level of .5 ppm. "Flammable Compressed Gas", in accordance with , 2. Provide training for employees engaged in the . D.O.T. regulations. Cylinders will bear a "Flammable handling of vinyl chlorides and polyvinyl chlorides. : - Compressed Gas" label required by D.O.T., and a labelrequired by OSHA which reads "Cancer-Suspect ,, '3. Maintain records. '- Agent." , - ; . ., *7: Exposure hazards for VC are nil in transportation be MONITORING cause the cylinders must meet requirements of D O T. to prevent escape of gases and to protect against the main Employers are required to monitor and measure ex hazard of flammability. posure levels for shipments of vinyl chloride and 098X62 '' *cr -, " -'- '* .* ^ ./,*- - ' polyvinyl ^chloride, and employees or their designated representatives are to be afforded a reasonable oppor tunity to observe thq process of monitoring and measur- . ing. " ; J'. v'1 * Monitoring will be for the various types of shipments < handled by the employer, as the exposure level varies according to differences in manufacturing processes. If a ' shipper changes his processes and exposure levels are increased there must be additional monitoring. The monitoring procedure consists of taking air sam ples at the level of an employee's mouth and nose -- his breathing area. Personal monitoring units are clipped to a person's shirt for this purpose. Samples of air at floor levels are not used because vinyl chlorides are heavier than air and tend to settle at floor level -- well below the employee's breathing area. Monitoring should be of loca tions where there may be exposure such as vehicle in teriors and on freight platforms. Truckloads, loaded by shipper and unloaded by con signee, need not be monitored because there is no ex posure to trucking company employees. Monitoring of LTL should be for the larger shipments usually loaded and unloaded by carrier employees as exposure level varies according to size of shipment. Exposure level, if any, also varies by time and temp erature. Additionally, air flow is a factor in reducing levels ' ; as the vehicle moves down streets and highways and as : the vehicle isbacked to the loading platform. Monitoring aftertheVehicle is'at the platform will determine levels, if ' . any, tpwhicfr.employees will be exposed. As a result of "monitoring ^employers may determine that shipments J , ; should not b'eh'ancHed until the vehicle has been allowed to ventilate for a period of .time. . i ; .: . v .. ;;After air samples have been taken they.will be pro-. ; cessed through an analyzer,to determine exposure leveisrif-the levels are at or below the "action level" of .5 V ,, -vparts per million for eight hours the carrier (sallowed to . .A conduct a minimum program. If the level is at or below - ' one part per million (twa) but above .5, the carrier must .'conduct "an extensive program which includes medical ' surveillance of employees. If the level is above one part ' per million, or 5 parts'per million in 15 minutes; the carrier \ must establish administrative and engineering controls to reduce exposure levels.1. If levels cannot be sufficiently >- reduced through-administrative and engineering con- T' trols, the carrier musbprovide respirators to employees that are exposed to tiigher levels. 1'OSHA REQUIRES: Explain nature of tHe^heaTthf^ . hazard for chronic exposure to vinyl chloride includ ing specifically the carcinogenic hazard. Explanation for employees: Vinyl chloride in com pressed gas cylinders is extremely flammable and is under pressure. It also presents a risk of cancer to employees who inhale the gas. Trucking industry employees do not handle vinyl chloride frequently and so they do not have the risk of chronic exposure. (The few workers in processing who suffered cancer had a daily exposure for an average of 19 years) In fact, there is no exposure to transportation workers unless a cylinder leaks. Polyvinyl chloride shipments may release a very low amount of vinyl chloride gas. Again, trucking industry employees do not have the risk of chronic exposure, nor are they exposed to high levels of gas and so the nature of health hazard is almost non-existent. 2. OSHA REQUIRES: explain the specific nature of op erations which could result in exposure^ to vinyl , chloride in excess of permissible limit and n cessary protective steps. ^ y, " : ' - '* Explanation for employees: In routine operations it is _ not expected that there will be a possibility of expo sure in excess of permissible limits. However, in case " of a leak from cylinders the exposure may reach the ~ J_- permissible limit or slightly above jn a confined area.; Employees should leave an area if There is a leaking ; cylinder. The exposure levels of polyvinyl chloride are not likely to reach the permissible limit under routine conditions or if a container is leaking. V - ,, V 3. OSHA REQUIRES: explain the purpose for, proper . use and limitations of protective devices. Explanation for employees: Protective devices are - designed to protect the employee from breathing air mixed with vinyl chloride above the permissible limit. !n general, protective devices will not be provided to trucking employees because exposure levels do not exceed the permissible limit. If an employee is issued a protective device, or required to use such a device there will be explanation of proper use and limitations. r TRAINING OSHA requires that each employee engaged in VC or PVC operations be provided training in a program relat 4. OSHA REQUIRES: explain the fire hazard and acute toxicity of vinyl chloride and necessary protective steps. ing hazards and precautions for safe use of vinyl chloride. Training is necessary for those who load and unload and for their supervisors. The items of training required by OSHA are listed below and are followed by employee information de signed to meet the training requirements. Explanation for employees: Vinyl chloride gas may act n anesthetic when the exposure level is very high -- at about 3,600 parts per million or higher The vapor is harmful so employees should evacuate an area if they determine that a vinyl chloride cylinder is leaking. The gas is more dangerous because of its 5 SL 098163 ''O' ... . ^ - flammafeij^t^aractehstics. It is extremely flammable . and may bignitec$||y heat, sparks or open flame, if a cylinder is leaking employees should shut off leaking valves if it can be done quickly and with a minimum of exposure. Otherwise they should notify supervisors and evacuate the area. 5. OSHA REQUIRES: explain the purpose for and a de scription of the monitoring program. ' Explanation for employees: The purpose of the monitoring program is to determine the level of 'employee exposure to vinyl chlorides so that a prog- ram to protect the employee safety and health can be :instituted as needed. A description of the monitoring program is included in the monitoring section of this : information bulletin. 6. OSHA REQUIRES: explain the purpose for and de- ' scription of the medical surveillance program . f Explanation for employees: The purpose of the medical surveillance program is to determine if there are _ . any adverse effects developing in employees ex.-posed to levels above the action level. The medical ;-i surveillance program will be described to employees exposure levels for motor carriers employees is V^^lyet5fparts , per million in which case a medical ^surveillance program will be instituted. -W4 ^REQUIRES: explain, emergency procedures. ^Explanation for employees: It is not anticipated that . ;i : there wilf be any opportunity for the type of massive - rel ase:that wilt result in a need for emergency action. , - 3^However,jjri:ithe event of a- leaking cylinder of vinyl - -r %'. V f \ sT? chloride the employee should evacuate the area to protect himself. If he feels that he can shut off a leaking valve or source of ignition without exposure to danger he should do so quickly. 8. OSHA REQUIRES: provide specific information to aid employees in recognition of conditions which may result in release of vinyl chloride. Explanation to employees: The condition which will result in release of vinyl chloride is a leaking con tainer. Employees should not handle containers which appear defective -- they should notify their supervisor for instructions. Employees should use care in handl ing containers. Avoid use of equipment which is likely to damage containers, do not handle containers roughly or drop them, do not store cylinders near heat or open flame. In general, follow good freight handling practices. 9. OSHA REQUIRES: a review of this standard at the employee's first training and indoctrination program and annually thereafter. Explanation for employees: Your employer will pro vide a review to comply with the OSHA requirement. RECORDS The employer is required to maintain records of monitoring, and if a medical surveillance program is necessary appropriate records must be maintained. Employees or their representatives must be granted ac cess to examine and copy records of required monitoring and measuring. -: .. . 'i.. ; 6 SL 98l64 mi