Document YGBEYOgMyZzQ7487bj4y9ndx8

Interoffice Communication To Distribution Gabbett 0atc May 28, 1974 Subject FVC Safety Association Meeting - Cleveland, 5/24/74 CHEMldSLSf research mru vj r-- FX \rm-- " r* *. " --4 --* "OB H* " A ! i Ltf The morning session was devoted to a general discussion on the VCM level acceptable to the attending polymer and monomer companies. Most ocher companies like Conoco have reached agreement internally on a monomer level which they intend to use in OSHA presentations. All companies intend to seek a TWA. The levels were stated, in Some cases vaguely, as follows: COMPANY American Chem. TWA - Air Products 20-25 Borden - Certain-Teed - 25 Diamond Shamrock Dela. City 25 Diamond Shamrock Deer Park - Ethyl . __ 25 Firestone Georgia Pacific " B. F. Goodrich 10-20 5 CEILING 40 - cannot meet 50 30 10 COMMENTS (intends to follow Stauffer) (exceedable for short periods) (no comment--still under study) (ceiling impossible) (no comment) (not represented) (Ethyl has requested assistance from a European company.) (still studying the situation but feels it cannot meet a 50ppm ceiling.) (not in a position yet to comment - is working wicl Wacker.) (three years) izumzM&vaiM 5/28/74 Page Two COMPANY Goodyear TWA 25 CEILING 50 COMMENTS (based c limited datawill st gest ceiling overru .) Great American 40-50 . - (present 50ppm ceiling crnmc: be met) Hooker 25-30 (SOppm ceiling cannot now be met because of excursions.) Imp. Oil (Exxon) Keysor 5-15 - - (unknown) - (no data, but possibly . a 25-30 TWA.) Dlin Pantaso te 25 .40 (no representation) (TWA to be based on Tenneco lOOOppm/week plan) Robintech 20-25 - (unknown) Stauffer 25 50 Tenneco ' . . -- _" (lOOOppm for 40 hrs, or 25 TWA weekly 40ppm celling) UCC Uniroyal 25-30 25-30 50 - (with overrun relief) (still studying) The following miscellaneous comments were also made in the morning session: Air Products feels, based on discussions with Stender, that the proposed standard is not necessary and that it tan be overturned if Call) companies make submittals stating objections, including converters. They intend to base their objections on precedent (asbestos case and QSHA handling of the existing 14 carcinogens) and feasibility ( a large proportion of the proposed QSHA requirements are not - -- technologically based). Xt may be presumptive to assume that the proposed standard can be overturned,but the 14 carcinogen precedent could be of value (Federal Register 1/29) as well as asbestos (Industrial Union Dept., AFL/CIO vs. Hodgson. l-OSHC-1631 (1974). File no. 72-1713, 4/15/74). Several companies stated that they will argue for occasional excursions above an acceptable ceiling providing the TWA maximum is not exceeded. The idea obviously is attractive assuming that a TWA is allowed. At this time, however, nobody has a precise concept of possibly acceptable magnitude. Three companies (Air Products, Union Carbide and Tenneca) plan to argue for a residual 0.13! VCM in product. They do not feel optimistic however. 19892000 B 5/23/74 Page Three Monomer producers generally were comfortable about a 25 TWA with the ex ption of Ethyl Corp. who doubts if they can meet the requirement,. Ceilings were uncertain because of excursions which occur unexpectedly. Dow outlined for comm it the following monomer plant improvement schedule: 25 TWA 10 TWA 5 TWA 2 TWA 7/75 7/76 7/77 7/78 ^ The general opinion of PVC producers was that 5 TWA may be possible1for them some distance down the road when a new radical plant could be constructed. 2 TWA would be impossible. : The afternoon session was devoted to a general discussion of the objectionable parts of. the proposed permanent standard. The following outline covers the pertinent obj ectionable areas. In general it was very similar.to the Conoco meeting at Aberdeen indicating similarity of opinion. ' A. Discussion of Possible Objections to Proposed Permanent Standard 1. Objections to Definitions end Clarification a. Contaminated b. Regulated Areas i. - daily roster of entry into regulated area c. 20-year record keeping 2. Objections to Engineering Controls and Work Practices a. Respiratory Protection - Selection from exceptable type based on OSHA recommendations b. Protective Clothing Requirements (1) Operators (2) Vessel Cleaners (3) Maintenance (4) Supervision & Others (5) Employees in Regulated Areas vs. PVC/VCM Exposure (Appears to require further clarification) c. Special Medical Surveillance following Emergency Situation w/i 24 hours. d. Signs and Labels (1) Substitute "Hazardous to Health" for words "CancerSuspect Agent" 5/28/?'. Page Four e. Maintenance & Decontamination X, Maintenance in full bodysuit and respiratory protection . Transportation Loading & Unloading ! Question need for respirators g. Medical Surveillance It Implementation for removal of suspect employees .from VCM exposure. h. Records __ It Reports to O.S.H.A. _ . i. Filing Procedure for Individual Company Objections \jf, Jo. J. F, Gabbett mj DISTRIBUTION: K. L- Schurter, G. J. Koch, L. N. Vernon, J. S* Chew, E. M* Smith, / Ft Kennedy, W. R. Sorenson VRif IT) =9 O' --j -fc*