Document Z82e22gBpZqG2ZDdaGjgvxQ1V

UNIOX CARBIDE , CORPORATION . COATINGS MATERIALS DEPARTMENT T" 270 PARK AVENUE. NEW YORK. N.Y. 10017 Robert W. Wesson VTC* rFETTSEKT AM : ; ' '' '* RECEIVED, . April 11, 1975 APR 1% 175 ; . ' ' ' & D. LLOYD': \ Union Carbide's solvent vinyl resins and dispersion resins are free from the OSILA standard on vinyl chloride monomer in all coatings and adhesive applications, according to a ruling by the U. S. Department of Labor in the attached letter. The 05HA ruling recognized these resins as "fabricated products" since their use in coatings and adhesives formulations do not involve mass melting sufficient to release vinyl chloride monomer. The use of Union Carbide's solvent vinyl resins and dispersion resins reir."ves you from monitoring for vinyl chloride as a reouirement for compliantwith the CSHA regulations when good operating practices are followed. Furthermore, Union Carbide will not label solvent vinyl resins and dispersion resins containers per this ruling and will sell these resins with less than 1 ?FM retained monomer. You may want to use the attached letter to assure your employees and customers that coatings made with Union Carbide resins are exempt from the OSKA regulations. Please feel free to contact your Union Carbide sales representative if you have'any questions or problems. 1441001 BFG13766 SOUTH CHARLESTON PLANT Ci*r c* zs n UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS P-O- BOX 5004, SOUTH CHARLESTON. W. VA. 25303 f. April 7, 1975 Dr. R. S. Brookman Research Development & Technical Service Firestone Plastics Company P.O.Box 699 Pottstown, Pennsylvania 19464 Dear Boh: Since you were in on the start of these negotiations, thought you might be interested in this interpretation by Mr. Grover C. Wrenn. ft 5. u-. Best regards, ll J R. N. Wheeler, Jr. RNWJr/ra Attachment Copies to: R. A. PARK 4/14/75 C. E. FINKPIK33 C. J. KLEIRERT J. J. CASSIDY, JR. BFG13767 2J00IW 2 m 2 5 T37S US. DEPARTMENT OF LABOR Occupational Safety and Health Administration - WASHINGTON, D.G 20210 Hr. R. N. Wheeler, Jr. Union Carbide Corporation Chemicals and Plastics P.0. Box 8004 South Charleston, West Virginia 25303 HlUiVUi 'HAR 311975 D ty WHPfl FR, JR. Dear Mr. Wheeler: Tour letter dated February 14 suggests that certain of Union Carbide Corporation's vinyl coating resins from its dispersion and solution vinyl resin processes should be considered "fabricated products." In support of that position, you state that the particular resins described -are "fabricated" for use and application via coating technology; and further that the dispersion and solution vinyl resins contain less than one part per million by weight of residual vinyl chloride monomer which effectively precludes the possibility of employee exposures in excess of the action level in the subsequent transportation, handling or use of these resins. The Occupational Safety and Health Administration standard for vinyl chloride defines a fabricated product as a "product made wholly or partly from polyvinyl chloride, which does not require further processing at temperatures, and for times sufficient to cause mass malting of the polyvinyl chlorine resulting in the release of vinyl chloride." In reviewing the materials which you submitted, it is agreed that the term "fabricated products" includes those solution and dispersion polyvinyl chloride resins decribed as having application in the formulation of paints and coatings which do not undergo further processing involving mass melting. It should be noted that the vinyl chloride standard would apply in all respects during the manufacturing of the solution and dispersion resins within Union Carbide Corporation facilities. Additionally, employers Vno used these resins in applications which would require further processing at temperatures sufficient to cause mass melting of the polyvinyl chloride, would be subject to the provisions of the ctandard. Sincerely, eooT W -I? Chief, Division of Health Standards Development