Document b5eX94gkrRzxO4EmDzM8ebq40

PARAGRAPH OBJECTION GROUNDS (b) (9) "Exposure" means actual contact with vinyl chloride when unprotected by required personal protective equipment and clothing. Limits of time and amount of vinyl chloride necessary to constitute an "exposure" are not Included in the definition. Also there is no mention of vinyl chloride gas versus vinyl It is obviously not feasible to determine actual contact with an infinitely small amount of vinyl chloride for an infinitely short time with a confid ence limit of 95 percent. Either the definition f chloride liquid "exposures". "exposure" or the requirements in regard to monltori or both should be changed. { The definition of "exposure" could be accepted if ! 1910.93q (e) (2) did not require "any exposure" ! to be determined with a confindence level of 95 i percent. j } The definition of "exposure" also relates to 1910.93 (g) (2) pertaining to reporting of Incidents involvl i "potential employee exposure." Everything that is dc in a polyvinyl chloride polymerisation plant has the t 1 "potential" for actual contact with vinyl chloride. ii i It is suggested that the term "Exposure" could be dc fined as follows: | "Exposure" means actual contact with vinyl chlori i gas in a concentration exceeding the allowable limit in the work environment, or actual contact of the si with sufficient vinyl chloride liquid to result in m to vinly chloride gas concentrations exceeding the alii o 00 able limit in the air adjacent to the employee havi such contact. i A MBER PARAGRAPH OBJECTION GROUNDS 2 (h) Protective clothing (1) amployees entering re The specification "protective against vinyl An ordinary loosely fitting coverall will stop drc gulated areas shall be provided full-body protective j chloride", as defined in (b) (13) is not suf clothing footwear or shoe covers, and gloves, at no cost to them, and required to wear it'while in | ficient for an employer to provide to a supplier j of clothing to be sure of meeting the require lets of vinyl chloride liquid from contacting the skin: the droplet will vaporize from such clothln into the surrounding air since the boiling point o the regulated area. ments of the proposed regulation. vinyl chloride is -13.8*C (+7#F). OLI 5209 3 (h) (2) Where polyvinyl chloride powder containing j detectable levels of vinyl chloride is handled, employee shall also be: j t Would clothing that would prevent contact of vinyl chloride liquid in amounts reasonably likely t be encountered in normal operations be, normally suffl lent, and a different type of protective clothing i case of accidents? Does protective clothing have t protect against exposure (actual contact at any cor centratlon) or only keep the vinyl chloride gas concentration between the clothing and the skin bel I the approved limit of vinyl chloride? 4 (i) Provided and required to wear head coverings; "head covering" in non-descriptive. Generally, hard hats are worn by employees, and th are not always compatable with the use of resplrat. I Specifically, what typle of "head covering" may be i used to satisfy this requirement? 5 (ii) Required to remove all protective clothing at Vinyl chloride has a very bow boiling point Since vinyl chlorde has a low boiling point (-'3.8 3ER PARAGRAPH OBJECTIVE GROUNDS each exit from the regulated area; and will readilly vaporize, therefore, flow will sufficient ly decontaminate any contaminated areas, making it unnecesi sarjr to remove all protective clothing at each exit from the \ regulated area. (+7F), clothing that has been contaminated by one or a few drops of vinyl chloride liquid will be decontaminated by normal evaporation. and (iii) Required to shower after the last exit of the day. Unnecessary - vinyl chloride vaporizes rapidly, therefore, a shower would not help to protect against exposure. The objective of the proposed regulation is primari! to protect against excessive exposure to vinyl chloride. Since there would be no vinyl chloride present by the time an employee reached the shower room, a shower would serve no useful purpose. (3) Clean protective clothing shall be Laundering for the purpose of decontaminating clothing is provided whenever contaminated or soiled, unnecessary as vinyl chloride vaporize before laundering but not less frequently than weekly. can be accomplished. Contaminated clothing shall be decontam inated before reuse by removal for laund ering or disposal. A 8hover may be desirable for personal hygiene rea sons, but not for the regulation of exposure to viny chloride. Physical characteristics of vinyl chloride are such that decontamination can be accomplished by natural evaporation. (h) (3) Storage or consumption of food or beverages, storage or use of smoking Unnecessarily restrictive. The rapid rate of evaporation of vinyl chloride precludes any likely hood of exposure by ingest' n i* OLI 5210 NUMBER PARAGRAPH or non-food chewing products, and the storage or application of cosmetics are prohibited in regulated areas. OBJECTIVE GROUNDS or by skin absorption. Therefore, it seenis imne ssrily restrictive to deny the use of such sister in areas where the atmosphere is normally below allowable limit of vinyl chloride. I OLI 5211