Document YrOKK3LbOyJdyVr5rk6JxQ0Lk

SOUTH CHARLESTON PLANT UNION CARBIDE CORPORATION CHEMICALS AND RUSTICS P. O. BOX *004, SOUTH CHARLESTON. W. VA. 25303 July 5, 1974 Mr. Julius Jixneno Hearing Management Officer Docket OSH-36 Room 200 Occupational Safety and Health Administration United States Department of Labor 1226 M Street, N.W. Washington, D. C. 20210 tT/f * //A ^ Dear Mr. Jimeno: Attached are three copies of an additional appendix to be attached to the TESTIMONY OF RICHARD J. HUGHES Vice President of Union Carbide Corporation Before Department of Labor Occupational Safety and Health Administration Vinyl Chloride Occupational Exposure Standard Very truly yours, RNWJr/ra Attachments R. N. Wheeler jr. 001850 APPENDIX TO TESTIMONY TO RICHARD J. HUGHES VICE PRESIDENT. UNION CARBIDE CORPORATION < PROPOSED STANDARD 1910. 93q VINYL CHLORIDE LEVEL OF EXPOSURE - METHOD OF ANALYSIS PROPOSED STANDARD 1910. 93q VINYL CHLORIDE (m) TRANSPORTATION LOADING AND UNLOADING VINYL CHLORIDE MONOMER THRESHOLD ODOR CONCENTRATION IN AIR VINYL CHLORIDE RESIN OPERATIONS UNION CARBIDE CORPORATION JOB CLASSIFICATIONS AND EXPOSURE MONITORING PROPOSED STANDARD 1910. 93q VINYL CHLORIDE LEVEL OF EXPOSURE - METHOD OF ANALYSIS The proposed standard for employee exposure is set at no-detectable level, as determined by a sampling and analytical method capable of detecting vinyl chloride at concentrations of 1 ppm with an accuracy of 1 ppm t 50%. This specification has been loosely interpreted as permitting exposure levels up to 1 ppm. The specification on the method of analysis and the interpretation of the permissible level of exposure resulting therefrom are imprecise. Incorporation of this specification into the permanent standard would result in confusion and ultimately endless litigation on the meaning of the results. A more precise specification of the method of analysis would be as follows: The proposed standard for employee exposure is set at nodetectable level as determined by a method capable of detecting 1 ppm with a reproducibility of t 0. 5 ppm at the 95% confidence level as defined by ASTM Standard, E 180-67. Even with tie more precise specification of the method of analysis proposed, the results of single samples could vary considerably from the desired results. Assuming no errors in sampling, the employer would have to control the absolute concentration of vinyl chloride in the work space air at less than 001852 0. 3 ppm to run no risk of an OSHA citation for non-compliance. From the enforcement standpoint, the work space air could have as much as 3 ppm or more before there would be no risk of not getting a non-compliance citation. To reduce the 0.3 to 3. 0 ppm range of questionable compliance, the only alternatives are to specify a more precise method of analysis or to analyze more than one sample for each determination. For more details concerning the variability of the method of analysis and its specification, see the attached letters. TmM^BQftQ^jtfiTtffllr<vt"wbs|ttlagkMKintendato^nfoBQ,at>heirnoL- hiad**?5TTghdy*iippJIH* Similarly, if they intend to limit employee vinyl chloride exposure to 1 ppm, then this should be made plain and the method of analysis chosen to suit the situation. RNWheeler Jr/ra July 5, 1974 001853