Document Znvz047o8wZBk8kdKnLzQOKpp

TO: Ben Decker -F6S: jet: XF: ^___ FROM: DATE: Interoffice Communication gygj. T. G. Grumbles August 8, 1986 OWENS-ILLINOIS ALUMINA HEALTH CLAIMS VISIA 0-1 is correct in informing their customers that an alumina based product does not have the health hazard potential of a silica based product. However, I share your concern if 0-1 is indicating, by implication or actual verbage, that no further hazard exists. Nuisance dusts in the respirable range still present an inhalation hazard. The effect, or "disease" potential is different. Nuisance particulates create simple obstructive lung problems versus actual fibrogenic disease as is caused by certain silicas. Both should be avoided. We would recommend appropriate protective measures be taken, i.e. ventilation and respiratory protection, to prevent excessive exposures to the alumina. We don't have specific data on Alumina particles in the nanometer range. I would suggest we share our concern with O-I to assure they aren't representing the new alumina based product as hazard free. Let me know if you want help with the correspondence. Thomas G. Grumbles ajo/9 cc OCK, MMV VVV 000015402 DXon PLANT ABD BALT LCCP VCM OKC LAB TOTAL 1980 974 ( 198)* HEALTH AND SAFETY 1981 J.982 855 (203) 581 (300) J.983 313 J.986 290 (381) 1,920 (670) 489 (0) 1,039 (750) 1,025 155 (590) 631 (0) 99 (0) 118 (118) 193 2150 (490) 893 (273) 103 (65) 56 0 2193 (74) 355 (0) 1,498 (268) 55 80 205 (50) 118 (373) 4,773 (1,141) 3,044 (536) 1,849 (1, 168) 1,611 (0) 5,111 (1,958) * NUMBERS IN ( ) ARE FOR HEALTH VVV 000015403 ASSURE COMPLIANCE WITH APPLICABLE REGULATIONS IN THE AREAS OF 1. HEALTH AND SAFETY REGULATIONS 2. HAZARDOUS WASTE HANDLING AND DISPOSAL 3. AIR POLLUTION - EMISSIONS AND MONITORING 4. WATER POLLUTION - EMISSIONS AND MONITORING 5. HAZARDOUS MATERIALS TRANSPORTATION o CLASSIFICATION, MANIFESTING, PLACARDING 6. FOOD AND DRUG ADMINISTRATION o DIRECT AND INDIRECT FOOD USES 000I5404 PRODUCT LIABILITY PROGRAMS 1. TOXICOLOGICAL TESTING OF PRODUCTS 2. DISTRIBUTION OF SAFE HANDLING AND WARNING INFORMATION TO CUSTOMERS 3. TRANSPORTATION EMERGENCY RESPONSE SYSTEM 4. CUSTOMER ASSISTANCE WITH PROBLEMS IN THEIR WORKPLACES - TECH ASSISTANCE WAIVER 5. RECORDKEEPING WV 000015405 ENVIRONMENTAL PROTECTION AGENCY (EPA) 1. CLEAN AIR ACT 2. CLEAN WATER ACT 3. SAFE DRINKING WATER ACT 4. TOXIC SUBSTANCE CONTROL ACT 5 COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT (SUPERFUND) 6. FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT (FIFRA) 7. RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) Oi5*6 000 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) 1. GENERAL STANDARDS A. FIRE PROTECTION B. HARD HATS, ETC. C. PROTECTIVE EQUIPMENT 2. SUBSTANCE SPECIFIC STANDARDS FOR HAZARDOUS CHEMICALS A. ETHYLENE OXIDE B. ASBESTOS C. NOISE D. LEAD VVV 0000X5407 FOOD AND DRUG ADMINISTRATION (FDA) 1. CERTIFICATION FOR DIRECT AND INDIRECT FOOD USES 2. PESTICIDE USES vvv 00001540a DEPARTMENT OF TRANSPORTATION (DOT) 1. CLASSIFICATION OF HAZARDOUS MATERIAL 2. PLACARDING REQUIREMENTS 3. MANIFEST/BILL OF LADING CONTENT 4. SHIPPING CONTAINER SPECIFICATIONS 0015409 REGULATORY CONTROLS REQUIRE: 1. PROPER EVALUATION OF CHEMICALS BEFORE MARKETING A. IF MATERIAL IS NOT ON TSCA INVENTORY, THEN PMN REQUIRED B. HAZARD EVALUATION FOR LABELING AND TRANSPORTATION CLASSIFICATION C. PREPARATION OF MATERIAL SAFETY DATA SHEETS 2. MANUFACTURE CHEMICALS WITHOUT EXCESSIVE EMISSIONS TO AIR, WATER, OR GROUND A. MINIMIZATION OF WASTE NOW REQUIRED B. WASTE DISPOSAL, STORAGE, TREATMENT HIGHLY REGULATED 3. SELF REPORTING OF NEW INFORMATION A. TSCA SECTION 8 - ENVIRONMENTAL OR HUMAN B. TSCA SECTION C 4. PROPER SAFETY AND HEALTH IN-PLANT 5. PRODUCT LABELING INFORMATION DICTATED vvV 000015*1 6. CONTAINER/EQUIPMENT SPECIFICATIONS FOR TRANSPORT TO: D. A. Kuhn : mQ XF: Interoffice Communication FROM: DATE: gjjQj. T. G. Grumbles August 14, 1986 PROGRESS REPORT FOR THE WEEK ENDING AUGUST 14, 1986 VISP 1. Developed comments for the Vinyl Institute on EPA's proposal to modify the method of determining what a hazardous waste is. As proposed, all Vista's wastewater would be hazardous which would require considerable expenditures to up grade our wastewater treatment facilities. 2. Assisted Public Relations in developing "if asked" statements for Hammond and LCCP. 3. Completed first draft of an Environmental Audit Manual. 4. Worked with LCCC to place a value on the LCVCM hydrocarbon bank. Identified a contractor, which LCCC hired, to provide an appraisal. 5. Conferred with Du Pont regarding Baltimore groundwater assessment. Will meet with Du Pont on Monday, August 18. 6. Met with Engineer on revisions to standards incorporating additional environmental considerations. 7. Made a presentation to the Ponca City overview class regarding environmental and health regulations and product liability concerns. 8. Presented two training sessions to R&D on the requirements of the Toxic Substances Control Act. 9. Met with R&D to discuss completion of the Premanufacture Notification for Alumina XD. The first draft is estimated to be complete the week of August 25. 10. Met with S&T to discuss the development of a DOT Audit Program. Thomas G. Grumbles ajo/9 VVV 000015411