Document a4BQonq9Rv8LO7DOzaNZ9MJmN

the so cjlETY OF THE PLASTICS INDUSTRY, INC. 250 PARK AjVENUE NEW YORK, NEW YORK 10017 . 212573-9400 HOW THE NEW OSHA STANDARD AFFECT POLYVINYL CHLORIDE RESIN FABRICATORS At the out set,, all recipients of this memorandum are urged to recognize that each individual fabricator must evaluate his own operations with respect to compliance with the OSHA Standard for occupational exposjure to vinyl chloride since operations can vary significantly froir company to company. Each plant has its own problems and no g efneral statements can be applicable to all. For this reason, the comments which follow must be considered as nothing more than guidelines and not a set of directions or instructions. Anotbe:r point to be borne in mind is that OSHA's action in adoptinc the Standard is now before the u.S. Court of Appeals for the S eicond Circuit for formal review. Thus, the effective date of the Standard could eventually be stayed, or the entire matter rem,4nded to OSHA for reconsideration. For the immediate future, h< wever, we hope that the following comments will be useful to you : n indicating steps that should be taken by fabricators to br: ng themselves and their plants into compliance with OSHA Standard S1910.93q Vinyl Chloride, assuming it remains as is and becomes effective on January 1, 1975. The first ]>oint to be noted is that the Standard applies (S1910.93q(a)(2)) to the manufacture, reaction, packaging, re packaging, storage handling or use of vinyl chloride or poly vinyl chloride, but does not apply to the handling or use of fabricated produc s made of polyvinyl chloride. Still further, fabricated product is defined to mean ((b) (6)) a product made wholly or partly rom polyvinyl chloride and which does not re quire further processing at temperatures, and for times, sufficient to cause maps inelting of the polyvinyl chloride, resulting in the release of vinyl chloride. In other words, those who use polyvinyl chlorid^ either in the form of powder for subsequent formulating, dry >lend, or pellets and who melt the polyvinyl chloride so as to form it into useful shapes, must comply with the Standard. We believe, however, that those who only heatseal polyvinyl ch .oride film and sheet or thermoform sheet such that mass melting does not occur need not be concerned with the Standard. SPI-01782 3 These may include chfe:.nges such as improving ventilation in storage areas, or enclosing ind ventilating mixing areas. In any event, if the controls whic 1 can be immediately instituted are not effective in reducing axposure levels, without regard to the use of respirators, to the permissible exposure limit or below, written plans for a program to reduce exposures to the greatest extent feasible must be dev sloped. These plans will have to be furnished to OSHA if a writ ben request is made. Still further, these plans must be updated every six months. If exposures ibove the "action level" are found, a program for determining the sxposure of every employee should be established. The program shojild be repeated at least monthly where an employee is exposed ibove the permissible exposure limit, and should be repeated qi arterlywhere employees are exposed above the "action level" but w: Lthin the permissible exposure limit. Finally, if two consecutive m<mnitoring determinations made not less than five working days ap irt show exposures for an employee at or below the "action level", monitoring for that employee may be discontinued. In other words if on the initial monitoring "go around" you find some employfees exposed above the "action level" and you institute engineering controls or changes in work practices that reduce employee expo{sure to vinyl chloride so that the employees1 exposure goes below ind remains below the "action level", these employees then fall .n the same class as those found below the "action level" on thfe first monitoring. In addition to setting up Regulated Areas where exposures are above the permis sible level and providing the required respiratory protectij}n, fabricators must also institute a program of medical surv sillance for employees exposed above the "action level". Emp oyees exposed above the "action level" initially, but whose exposure level is reduced below the "action level" as a result of engineering changes, need not be subjected to medical follow-up^ according to the current thinking most widely held; this is an ambiguous point, however, which may need further clarificatioh The section o the Standard that deals with signs and labels requires careful attention. Many of the requirements set forth in this Standa d may not be applicable to most fabricators but this will depend in part on the results found by monitoring and the nature of thfe operations being conducted. More specifically, SPI-01784 ENFORCEMENT CONSIDERATIONS RE EPA STANDARD FOR VINYL CHLORIDE A. What i.9 a Leak? X ppm above background level? Where measured? Fence Line, areas, rooms, et . Suggest 200 ppm above background for starters. B. 61.62 (b) Oxychlorinat. on Reactor - How should production of Ethylene Dichloride to be deter i:lined ? C. 61.64 (a) (2) - Reacto Opening Losses - How should polyvinylchloride production be determine,d-? Material balance? History for each grade and type? Over what p iriod of time? Past year, quarter, month, running averages, etc. D. 61.64 (a) (3) - Manual vent valve discharge - How should the Vinyl Chloride emitted be estimated? Duration of discharge, state of reaction (time, conversion, pressure, rate of rise of temperature, pressure, etc? Material balance on individual jatch if segregatable? E. 61.64 (e) (2) (i) - No s trippers technology - How should production be determined for dispers Lon resins? Separation of weights by grades? F. 61.64 (e)(2)(i) - No s trippers technology - How should production be determined for suspens Lon resins? Separation of weights by grades? G. 61.65 (a) Relief valve discharge - How should vinyl chloride discharge be estimated? H. 61.67 (g) (1) (iii) Emission tests in terms of mass - How should production be determined? See e qiation, Z term. I. 61.67 (g)(3) (iii) be determined? Production for each stripper - How should prdiction J. 61.67 (g) (4) (ii) In process water - How should production be determined? See equation, Z term. K. 61.67 (g) (5) (1) - Re|actor opening loss - How should production be determined? See equation, Z term. L 61.70 (c) (2) (i) - How should production be determined? M. '61.70 (c)(2)(ii) - " N. 61.70 (c)(2)(iii)- " RWL/mls 10/8/76 R. W. Laundrle SPf-01786