Document Z3ZnYZxQw124Vm232NbKqE3V

i i The new NIOSH factor: How to prepare for a crisis i' Plan for speed-up in recommended OSHA materials standards ii { includes active participation by affected industries, bypassing TLV route in favor of better workplace practice l t ? The book says you cannot anticipate a calamity. But you icals, additives, and fillers that hadn't heretofore been on can identify the potential high-risk areas, and marshal up the toxic-investigations list--is the sudden eruption of the what's needed to take the sizzle out of the lightning if and vcm crisis. As recently as a year ago, vcm had occupied a when it strikes. That pretty well sums up the philosophy low-priority position on the agency's iist of potentially now being applied by the National Institute for Occupa toxic substances (June 1973 mp, p. 55). At the time, vcm in tional Safety & Health (niosh) in researching the worker vestigation had a priority rating of 9, on a descending scale health hazards of hundreds of chemicals and other toxic from 1. Its potential health hazard was characterized as ity-suspect materials, many of them critical to plastics. "irritant; central nervous system depressant." As niosh The idea is to move a lot faster in identifying materials points out. these were the only deleterious-to-health po with an imminent workplace health hazard, and in devel tentials of vcm that could then be documented. oping recommended remedial standards for inclusion in It would be wrong to surmise that it was the widely pub i 1 the federal Occupational Safety & Health Act. Although licized (and spreading) vcm flap that has galvanized niosh this law has been in effect for four years, only a handful of and osha into streamlining and accelerating their investi materials standards has been published; fewer stil! for gative and rule-making procedures, as they are doing. But plastics-related substances (see table at right). it is precisely the sort of spotlighted occurrence that can Meantime, there is a several-years-old list of some 400 persuade federal budget directors to pump more operating potentially toxic substances for which standards investi money into these agencies for the additional manpower gation is pending, and more to come. and external assistance they say will be needed to carry out Crisis In VCM a cooperative new plan for fast action in developing health standards for materials. Under the law, niosh has the responsibility of identifying niosh, for example, reports that it has about 100 fewer materials with significant potential for adverse effect on staffers than it had a year ago, despite an increased work workers' health. It then develops proposals for corrective load. Its current employee force is only about 60% of the standards for submission to the Occupational Safety & strength that had originally been targeted for 1974 by the Health Administration (better known, like the law itself, as Dept, of Health, Education, and Welfare. OSHA), which then promulgates a standard. That, at least, is the way it is supposed to work. But the Shifting the sights trouble with this arrangement so far is that niosh is labo Equally to the point--if not more so--the vcm situation ring under a low budget and a high workload. It is a prob and its aftermath represent a vivid affirmation of the new lem compounded by the fact that, particularly for a great NtOSH/OSHA philosophy: If you can't actually prepare for a many substances daily used by the relatively young plastics crisis situation, the next best thing is to restructure the pri industry, there is little documented historic evidence of orities and try to head off the problem before it can hurt. toxic effects from which value judgements can be made. Therefore, current and future materiais-related stan This weak link in the OSHA/NIOSH chain jingled loose dards activities of these allied agencies will be heavily earlier in the year with the finding that a statistically sig weighted toward improving their preventive thrust. A nificant number of workers involved in the polymerization great deal of emphasis will be placed on mandating tightly of vinyl chloride monomer had contracted angiosarcoma controlled workplace practices that minimize the opportu of the liver, a rare and particularly deadly type of cancer. nity for physical exposure of workers to toxic areas. Since the revelation, of course, there has been consider And there will be far less concern about fiddling with able uproar and a lot of fast scrambling by niosh ar.d TLV numbers (threshold limit values, which essentially are OSHA. An emergency temporary standard was written into the p.p.m. dispersions in ambient atmosphere that are the law in April. Among other things, it reduced the VCM rated as innocuous to workers throughout a daily shift). worker-exposure level to 50 p.p.m.. down from the previ For one thing, says NIOSH. the validity of many existing ously allowable 500. A permanent and presumably tlvs is suspect. For another, previous NIOSH efforts to tougher standard will be issued soon, (see box, p. 60). check TLV numbers and recommend "safer" levels of ex What bothers NiOSH-and what is certain to result in in posure has involved a complex and time-consuming proce tensive early scrutiny of a number of monomers, chem dure, including analysis by a panel of outside advisors. 23433001 - 4 & 58 * BFG25563 Modern Plastics, June 1974 . 4 n**'.J -* * - ~r~""v d .taitea ' Monitoring chemical leaks is critical to OSHA materials-standard compliance. Instruments like this organic vapor analyzer help to minimize VCM exposure levels at B.F. Goodrich facility. Sorting out constituents of complex emissions aids NIOSH work on recommended OSHA standards. Here, computer takes inputs from gas chromatograph and mass spectrometer, analyzes level of each component. j j | j The new approach was spelled out recently by osha in announcing a new program, to be run by a joint osha/niosh committee, for faster issuance of health stan dards on materials. By eliminating the deliberation over TLVs, and keying in on physical preventive specifications, OSHa's hope is to develop a one-a-day rate of action on such standards. But that pace is questionable. First up for this type of appraisal is a list of 40 chemical substances that osha describes as affecting a cross section of American industry. Included among them are several that are important plastic building blocks, such as benzene and methyl methacrylate. At presstime, in fact, a Criteria Document on benzene was already circulating through niosh's upper-echelons for final approval before being submitted to osha for action. Delivery is anticipated before the end of this month. Since the contents of Criteria Documents (the data bases from which osha standards are developed) are classified until NIOSH release, the document's recommendations regarding worker exposure at production and processing levels are not yet known. However, benzene had a first-priority rat ing on last year's niosh activities list, for the reason that it is a suspected carcinogen. Processor's stake Because osha regulations on the health safety of tnaterials-as in the safety of equipment--reach into the pro cessing plant, conveners and users have a vested inteiest. economic and otherwise, in the plastics-related outfall cf forthcoming standards. For example, if the final version of the permanent Vcm standard were to. require installation of expensive low-emission-lcvel detection equipment, and/or adoption of "space-suit" protective garb, many processors might not be able to afford the investment. However, there's a chance that processors could be taken off the vcm hook by the already effective work being Material NIOSH action OSHA disposition Asbestos MOCA Vinyl chloride Toluene Toluene diisocyanate Benzene Glass fibers. Chlorine Ethylene dichloride Phenol Xylene Criteria Document, 1972* b b Criteria Document, 1973 Criteria Document, 1973 Criteria Document. 1974 Under review for Criteria Document 1975 priority 1975 priority 1975 priority 1975 priority Emergency standard, 1972 Emergency standard, 1973 Emergency standard, 1974 Under review Under review None None None None None None Source: National Institute tor Occupational Safety & Health, a--Criteria Documents are data bases tor proposed CSHA standards. b--NIOSH research bypassed lor reason cf critical detected health hazard, c--Materials tor which priority actions ara listed may or may not result in OSHA standards; dates are subject to change; new materials may be added. done by resin producers to minimize residual monomer levels at the polymerization stage (see Oct. 1973 MP, p. 73). niosh is cognizant of these efforts. Its current thinking is that if minimal free vcm is carried over to the user's plant, the standard could be limited to monomer/polymer pro duction operations. Air-sample testing is being done for niosh to check vcm exposure levels in such routine processor operations as bag opening, hopper loading, extru sion. and molding. Such speculation aside, it is Nnstl that does the tough, nasic spadework from which materials standards are evolved. Although the agency's charter does not require it i i i 1 j i ' 23433002 Modern Plastics, June 19/4 BFG25564 59 j OSHA's permanent standard for VCM will set tower levels on worker exposure At presstime for this issue, the Occupational Safety & Health Administration was preparing to publish in the Federal Register its proposal for a permanent standard on worker exposure to vinyl chloride monomer. Review and comment will follow. By law, osha is required to come up with its final, permanent standard by not later than Oct. 5. This would be six months after April issuance of its emergency temporary standard for VCM, which among other things mandated immediate reduction of worker exposure to 50 p.p.m., down from a previously allowable 500 (see May MP, p. 10). How low a level? The proposed permanent vcm standard reportedly includes many recommendations made by niosh last spring, before the current temporary standard was issued. Included is reduction of vcm exposure "below detectable levels." By strict interpretation, this means a limit of 1 p.p.m., since that is as fine a measurement as can be made by gas chromatography--the method being considered for specification in the standard. Industry obviously cannot survive an enforced upper limit of 1 p.p.m. without major disruption and new technology. A survey of monomer and polymer producers reveals that a standard specifying levels in the i to 20 p.p.m. range would force some pianrs to shut down for rebuilding. It had, of course, been foreseen that a "no detectable level" standard would be proposed by osha, despite the real difficulties in compliance that industry can document. Both OSHA and niosh have stated that existing experimental and epidemiological data do not support the view that occupational exposure of employees to 50 p.p.m. concentrations of vcm throughout their working lives has no measurable detrimental impact on human health. Signs of relief. Administrators of the law are aware of the impact a near-zero level would have, particularly at the polymerization and processing stages. That's why it is likely that a workable compromise will be reached. Outlook is that the permanent standard will stress regulations for work- practice and monitoring procedures that minimize the potential for worker exposure to monomer. But even this won't be an easy way out. The hardware of "protective technology" doesn't come cheap. A relatively unsophisticated gas chromatograph costs in the neighborhood of $50,000. Air respirators and other protective worker gear, combined with other attendant health-safety controls, add up to a considerable investment, as well. Still unavailable are the data from ongoing experiments and surveys here and abroad aimed at determining statistically safe levels of human exposure to VCM. These will have a direct bearing on the final standard. Worth noting, in this context, is that Dow Chemical Co. (a major vcm producer) identified chlorinated hydrocarbons as a cause of liver damage as long ago as 1933. Since then, tight workpractice controls, including minima! physical exposure of plant employees, has been standard operating procedure. Dow's records show no cases of angiosarcoma of the liver among any of its vcm workers. ( ! j < i ! i j ! i ; i j ; ; i i 1 | , .I \ 1 < j j ; .i to factor economic impact into its evaluations and recom mendations, niosh executives are aware that the estab lishment of zero or near-zero exposure levels is fraught with economic hazard. That's one reason for the shift in emphasis from numerical values to applicable "protective technology" methods for reducing exposure. Aid from Industry As part of the new' fast-action approach to evaluating haz ards and developing proposed standards, niosh has inaugurated an important departure from previous practice. It is soliciting active industry participation in its preliminary data-gathering and direction-pointing sessions, This participation will take the form of open-exchange seminars. Representatives of companies that produce or use a given material on the priority list of potentially hazardous materials will be invited to present pertinent infor mation and to make suggestions. The prototype of niosh's new seminar approach will in volve glass fibers. These reinforcement materials have a Priority-5 status on the current list of materials to be in vestigated (potential hazard: dermatitis). The glass fibers seminar will be held in Washington, June 26-27. According to Dr. H.E. Christensen, NIOSH deputy direc tor for research and standards development, the basic purpose of the seminars is to insure that as much valid infor mation as possible is fed in as early as possible. "No matter how careful we are," he says, "important informa tion sometimes doesn't get into the mill. Sc rather than taking a dogmatic and structured approach to a material, we want to get to the people who know what's what, and come out with usable data on-research analysis, work practice, and other factors that help cut the time lag." Such public discussions won't be necessary for some materials (such as benzene), where sufficient prior documen tation had already existed. But it will become more important, says Dr. Christensen, as NIOSH proceeds into the investigation of newer materials, or those for which available research data are scanty. A look into the future In another procedural change, NIOSH is experimenting with contracting research assignments locally in the VV'ashington, D.C. area. Formerly, all contracts were let in various parts of the country. Simple as it sounds, niosh believes that continuously monitored local research will contribute to speedier production of Criteria Documents. It also is likely that Criteria Documents issued over the next few years will include a number of materials used in the plastic industry that were not on the original list for investigation. And there is sure to be a reshuffling in the order of priorities. Reasons: First, field engineers in niosh's Office of Occupational Health Surveillance and Biometrics are winding down a three-year, investigation of industrial exposure to tlvrated chemicals. Second, niosh has added two new equa tions to the formula it uses to develop priority ratings: trends in use, and production volume. A new priorities list will be issued in 1975. And, as niosh observes, if the re vised formula had been applied in drawing up the original priority list, an osha standard for vcs< would have been issued long ago.--roland r. macbkioe 23433003 BFG2556560 Modern Plastics, June 1974