Document by0gdabeXd3YLX49G64wwmj50
internal CORRESPONDENCE
uc us-
CHEMICALS AND PLASTICS
to (name) COMPANY LOCATION
r. e. Kirkland, Jr.
O. BOX 471, TEXAS CITY, TEXAS 77590
date May 7, 1981
COPY TO
SUBJECT
Attached are the suggested revisions in the Medical portion of the Vinyl Chloride Training Program to be inserted wherever they fit best.
TV*f
David H. G/tenn, M.D.
UCC 093638
On October 4, 1974 OSHA issued a standard regulating worker exposure to Vinyl Chloride* This training program was developed to acquaint you with requirements of the standard which will protect your health and safety.
Medical and scientific studies have demonstrated an increased risk of angio sarcoma, an extremely rare form of liver cancer with exposures to long term, high levels of vinyl chloride.
As a part of the standard, every employee will be offered an examination prior to being assigned work in the regulated areas. The examination may be repeated annually for the first 10 years. Following this, it will be offered every 6 months. The examination will consist of a medical history with special attention directed toward drug and chemical exposures, hepatitis or other liver disease, blood transfusions, alcoholic intake and smoking. A blood sample will be drawn for an analysis of five special liver function tests, and finally a clinical examination will be performed with special attention being directed toward detecting enlargement of the liver or spleen. This examination is net for diagnosing cancer but is intended only as a screening to determine whether or not the employee is at any risk in con tinuing to work in the regulated area. Each employee will be furnished a statement advising him of the physicianjs opinion as to the suitability of continuing to work in the regulated area and the ability to wear a respirator. The examination is purely voluntary. If you do not choose to take it, we request you sign a statement to this effect. You will again be offered the examination at the appropriate intervals. The results of the examination are available to you and your personal physician on request. By law, they may also be inspected by an OSHA complaince officer. They will be kept by the medical division indefinitely. The Medical Division will welcome any questions concerning acute or chronic toxicity of vinyl chloride and will be happy to provide you or your physician with any information we have.
UCC 093639
2- Union Carbide is concerned about the health of its employees and has participated actively in the investigation of the vinyl chloride health hazard. There is little dispute that vinyl chloride is carcinogenic to man, but the level of exposure which is hazardous, cannot be definitely established with present evidence. Workers who have developed angiosarcoma have all had many years of high level exposures. Exposure levels in this plant have been dramatically reduced. We urge that you protect your health by learning and following the work procedures and practices that have been set forth. We ask that you cooperate with the Industrial Hygiene Monitoring and Medical Surveillance Programs that have been outlined.
UCC 093640
vtmyi rmPRIDE TRAINING PROGRAM
Following the discovery in 1974 that a number of workers engaged in the manufacture of vinyls resins had died of a rare form of liver cancer called angiosarcoma, OSHA issued a standard .on October 4, 1974 covering workers exposed to vinyl chloride. Certain facts of this standard that will be covered in detail in this training program require sig nificant changes from past practices.
A medical surveillance program will establish each employees health and
his suitability to continue in an area where exposure to vinyl chloride
is a possibility. t
^ Monitoring of exposure w41T-be required.
OaJU' Two techniques will be employed,
individual personnel monitoring and area monitoring by on-site gas ana
lyzers that +*444 provide continuous reading of the level of vinyl chloride
in the work place. Regulated areas .wi-W--be-established where vinyl resin
is manufactured or packaged and where vinyl chloride monomer is stored or
handled whenever the permissible exposure 1 imit 4<-exceeded-. Access to
regulated areas shall be limited to authorized persons, and a daily log
of persons who enter smri-1 be maintained. These regulated areas v444
-be appropriately marked by barricades and signs. The wearing of resp-
irators will be required where work -or exposure may exceed permissable
limits. Protective clothing that f-itr tha c-itnatinn w-m-fr* required
.for variouG levels of potential exposure. Training programs, such as /MJU A
the one being presented here, w.fllt be provided. A copy of the full standard as issued by OSHA will IxTfflade available to any employetf'upon
request to his supervisor.
UCC 093641
a)
Vinyl Chloride is a gas with a sweet, pleasant odor. It is used to make a solid material called Poly Vinyl Chloride. As PVC, it has a multiple uses in the plastics industry such as pipe, records, in-
A sulation, upholstery, kitchen food wraps, shower curtains, floor tiles and many more everyday plastic products. The vinyl /fchlnrida~gs-has hpan lieoH ac an anASthPtfF--Pljftnt find AS a pApoHyVrf in cpvay r-aru?-- Vinyl Chloride is a flanmable gas at normal apn/spheric conditions with a high vapor pressure. It boils at -13 degra& Centrigade. It is more dense than air and tends to concentraj'e iq low lying pockets. The lower explosive limit is 3.6" by volumeair\ The upper explosive limit is 33% by volume. It readily ignites by common sources such as , sparks, flame, or electrical Strks./It has long bqen recognized that the gas in high concentrations of 6^000 to 80,000 parts per million may cause light headiness or woozfness, symptoms resembling drunkiness and even death. On removal/fron exposure to fresh ai\ the symptoms usually clear up quickly.
In January 1974 three deaths due to a rare cancer of the liver, angio^ sarcoma, were discovered in workers who had44 a long-term high level
exposure to vinyl chloride. Subsequently, an intensive search of all r 1 ' former vinyl chloride workers and -medical testing of active workers
uncovered 17 cases out of 6,000 workers since 1961. This is statistically significant since only about 20 cases of this cancer, affectw^-the walls of the blood vessels of the liveware reported each year. Angiosarcoma has also been caused by arsenic and by an X-ray dye called thoriumdioxide. Animal experimentation has also produced this condition in mice by long term exposures of 50 parts per million of vinyl chloride.
UCC 093642
As a result of these findings, the government, through OSHA has enacted a standard regulating the exposure of workers to vinyl chloride. As a part of the standard, every employee will be offered an ex amination prior to being assigned to work in the regulated areas. The examination may be repeated annually for the first 10 years. Following this, it will be offered every 6 months. The examination wiW-consists of a medical history with special attention directed toward drug and chemical exposures, hepatitis or other liver disease, blood trans fusions, alcoholic intake and smoking. A blood sample vwl'f^c drawn
for an analysis of five special liver function tests, and finally a clinical examination wfH-bo performed with special attention being directed toward detecting enlargement of the liver or spleen. These tests are not for diagnosing a cancer but are intended only as a screening to determine whether or not the employee is at any risk in continuing to work in the regulated area and whether he may safely use a respirator. Each employee will be furnished a statement advising him of the physician's opinion as to a suitability in continuing to work in the regulated area and to wear a respirator. The examination is purely voluntary on your part. If you do not choose to take it, we request you sign a statement to this effect. You will again be offered the examination at the appropriate intervals. As of now, thorough investigation of all past and present vinyl chloride workers in the Texas City Plant has failed to find any cases of angiosarcoma of the liver. The results of the examination are available to you and your personal physician on request. By law, they may also be inspected by an OSHA compliance officer. They will be kept by the medical division indefinitely. Medical divisions will welcome any questions concerning acute or chronic toxicity of vinyl chloride and will be happy to provide you or your physician with any information we have.
UCC 093643
fas The vinyl chloride regulation also requires monitoring ar"vinyl chloride
monomer. The purpose is to determine the exposure level of each em
ployee without regard to the use of respirators. Personal monitoring
is performed by attaching an activated carbon tube to the collar of
the employee. Air is drawn through the tube at a metered rate by a
battery-powered pump attached to his belt. Vinyl chloride is absorbed
on the carbon and retained for laboratory analysis. The level of ex
posure is calculated for the total volume of air sampled. Individual
exposure records are available to each employee and will be maintained
for a period of 30 years. | Inf production area*, multiple sampling points are strategically located. Air is drawn^^t^aa automatic
^| jrj
central unitswhich monitont levels at each point by sequentially in-
"
PfrWfUL- til
-__ -
-
jecting a sontroTred air
3 directly into the gas chromatograph
AO--
juv VfU- AM/ tt-O.
foeh vinyl chloride level and sampling point is indicated on chart
cH/uC tfj U/xZ^A.` (Ks usTtiyZxtC,
QL,4ju^ ^0
pecnrdffr. The instrument is calibrated once each complete cycle.
*
S-iJLiauUaJ
These recordings indicate upsatrj -poloasas, -aad elevated concentrations.
-which activate-an alarm system. Tint pi nf '"itrnl'^SrL-riinNii K^rl'' In" p s-- dicate personal,exposures^w^Hiin the'T7!7iLro4~ieanfn anH pr>fAntvai ex-
fOosures outside are i.nrHratprf before one Ipavpc thp rnntrni rnnm,,
Th~4iemissable employee exposure levels are one part vinyl chloride
per million parts of air by volume averaged over any 8-hour period Cer hvjft
with a-sealing of 5 parts per million averaged over any 15 minute
period. No direct liquid contact is permitted. A concentration
of vinyl chloride greater than*\5 parts per million is considered an
action level which requires periodic monitoring and medical surveillance.
The periodic monitoring frequency depends on the level of employee "0Cfa/r*
explosure. Exposures above the action level but lessen the per-
missable level of 1 parti per million are monitored at least quarterly.
t ~
UCC 093644
Exposures above permissable levels are monitored at least monthly.
Monitoring will also follow changes in control, production, or process (LwuLutums
that may increase the release of vinyl chloride. {Regulated areas
----------------------------------------- --
~--------- -
are established for production areas with levels greater than the
~jtwr*r
permissable exposure levels. The regulated area is defined by a3cnse
' -off--- , lino fr signs. Personnel, other than production personnel assigned
46^^ XZLu tCuJtUt to a unit in the area, must chock in-with~~the shiRy'proctncticiir seper--
A
visor or
dpipgatfe-ttpmr enter fmr~and leaving tha a****---xtis is
done by. signing-the area log-kept in the*mit control room at Building
114. An instruction book is kept in this location and should be re
viewed before entering the area. Also to be observed are: warning
signs, rucfr as tbosa.placed on waster reccoticles which contaip VfM nr
VrM containing maturi*** cignr. tnwriiimj i-if a uhiyT-i nlnelHfr esiaflea or
signs announcing tha-t the regulated area into which unauthorized per-
sonnel may not enter. Where vinyl chloride exposures ne over the
permissable levels, authorized respiratory protection is required to
be worn and a respirator program is maintained. Three types of
equipment are provided in regulated areas. Air line respirators are
used for hazardous operations which have exposure potentials that are
known to be-feft in a lower explosive limit^whvefa is~~35~,d(]0 part? per
jnillioxu This equipment is pressure demand type equipped with an
auxiliary egress bottle and a full faced piece. It is used for
routine work involving elevated exposures. Entering the concentrations
above^ 3,600 parts per million is authorized only for rescue, fire
fighting, or securing equipment to prevent release. Air purifying
canm'ster respirators are authorized for concentrations known to be
no more than 25 parts per million. The cannister is good for 4 hours
or to the end of the shift, whichever comes first. -When-tho monitor
UCC 093645
alarro-signiTies lovoia- above 25 parts-pap-million, airline equipment must
J^o -- The cannister respirator is used within regulated areas generally
for mobility. It will not normally be required within control rooms. A
4/0
30-minute bottled air system is^prnvidpd
ush urTiy-- It is
a pressure demand type self-contained breathing apparatus with full-facef
piece. It is approved for unknown or even explosive levels for purposes
of life rescue. It should not be--used ..for .routine work. -Every ^ffort/3
is being made to lower vinyl chloride to lessen one part per milliun irrthe
vinyl area aad .to maintain it at that level. On occasion, -the- possible
exposure will rise above one part per million due primarily to leaking
valves, seals, flanges^and to release through rupturedneea or cafoty--
valves. The vapor fracti
^fJr -should be Uiecked dLj'eyu'iar I lu-efya-^j aim uyw> iai ly umun? mermy .
a quesfticmable area to determine vinyl
'WpI ased on &
'%L- A the level, the need for respiratory equipment can tro dote*
~ Drf4-
fj
1-ighti
til Pfirir^'iPlivHh'iril pii'l up point a round the suspension
nen-sulvent area. Wtren the vinyl ehlortde concentration in the Atea re
quires the use of respiratuiy equipment., Lhese rod lights will flash. A jflashinq rpd light maant that ynn murt wn.Ti" i-Prp-rr-i+rvry nqin'pmnnl nv ln.iu--
.the area. Normal operations requiring precautions are:
ace
dofr\ pttJifiZ. Kumrsampling which normally requires wearing of a fresh air mask. ,Gomprassure
/jUjajJLu^ checks may require respirators eased on the VFA reading. Connecting or
disconnecting hoses to unload vinyl chloride tank cars, requires fresh
air respiratory equipment. Sampling of these cars also requires fresh
air equipment. Vessel or confined space entry is covered by plant
procedure 1D3. This procedure calls for proper isolation, emptying,
electrical lock-out, cleaning, purging, ventilating, and testing of the
vessel before entry is allowed. Testing may be performed by either
operations or industrial hygene personnel.
UCC 093646
Entry is not allowed until the test shows a safe atmosphere and a hazardous wor.k permit has been filled out and approved. The opening of a pump, compressor^^^i|ig that normally contains vinyl chloride, should follow the same-general procedure. No equipment whose contents include vinyl chloride shoal'd be emptied directly into the atmosphere^without proper authorization to insure _aU-~frecessary precautioTT5^avg"bgerr-t-aken. --If. possible-i'^he equipment should be emptied to a part of the process where
it will not enter the atmosphere, uWhen cleaning vessels that contain
pplyvinyl rhlm^'.'U ret iiiiiuk , |ii i >
i vm r 1 < 11 li'inrj r. In l, ......... Jtn_prpupnt
skin rnntant-ifi I'h PVf i rs Muui-"'ttti vu1.'*1 in'nr In the laboratory,
samples containing high levels of vinyl chloride should be opened and f
handled under a ventilating hood. The usa of respirators during fuelJ<
camping nf ltgin'd m- vnnt 'trnnmr. mntni nine viftyl nhlnyido, -q-hflHld-Jao
based on VFA raadingg-r The distribution area is also affected by the vinyl
chloride regulation since the PVC resins, which are handled in vinyl shipping, contains some residual vinyl chloride monomer. , A1 though l/inyl _ 51 Shipping is not a regulated area# fhat, at~ cnm> art"a1 a'oa^/hs'fi.iaon
1- and 5 parts-par-mill ions last4figH-es'5 than Ip minutest These areas apply to suspension and non-solvent vinvT_r_es_ins and include work ooperations such nt nprning nnd riming hnfrhn nn Inrriril hnpprr rnn i oepning and closing hatches on van boxes., sampling hnppar. rare., sampling
jvan-hoxQSs-anri oponing van boxos to- bu wasliuilr^ Ono-particular area ofconcern is the entering of van boxes. Van boxes should not be entered until after they've been washed. Entering a van box prior to washing could result in a VCM exposure over the permissable limits. Also, all
should-be checked far VCM levels before entering in order to avoid exposure over the permissable limits. Conditions which may result in a release of vinyl chloride fall into two general categories: process upset and equipment failure.
7 UCC 093647
(2
Each unit operating manual contains a description of normal operating
conditions. Every operator should be familiar enough with his unit to
recognize abnormal -e-pei a liny conditions. Some key points to watch are:
level gages of vessels containing VCM or other materials with the VCM
content, pressure indicators for VCM containing vessels, the temperature
recorders for the -etrt-of
since an uncontrolled reaction might
lead to venting^and the rectifying column refljex recorders At the soV--
-vftnt unit since loss of reflex might cause an indirect loss of VCM at the compressor traps. jDeiaiili'ng'ur water fiuin VCM tanks to-the #3 stripping
fank the n/ppminn unit rrquires careful operator^attention to be
sure^that VCM is not releasod to tho atfflosphoc&. Equipment failures
are easy to spot but not so easy to predict. The best remedy is a
thorough inspection of all processing equipment at least once each shift. Areas to especia/ly watch ffir are improper!^ sealed safety valves, proecess valves &hich have/been left partly opened on leaking,/ pump compressor or agi/tator seal/ which are leaking or any h therecon
dition which is out of the ordinary. In the event of a massive release
of vinyl chloride the standard operating procedures will be implemented
at once. Key steps in these procedures are:
1. Activate the -dailyz-system in the infected area.
2. Alert all personnel to clear the area using the PA system.if avail able* Clear the endangered area of
__ personnel at least 25 feet upwind and 50 feet down wind of the visible vinyl chloride cloud. Personnel should exit crosswind. If the wind direction indi cates the endangered area may extend beyond the con
fines of the particular unit, the chief operator should notify the affected personnel of the danger.
3. Sound the plant fire alarm and toxic gas alarm.
4. Isolate the affected area; If possible, rope the
area off and post warning signs. Road blocks should be set up if required.
jOMu 5. Isolate the caliaf source by remote valves or pumping
arrangements outlined in unit procedures.
UCC 093648
6. Use all available water to disperse the cloud and form a water curtain.
7. Only specially trained personnel equipped with properly protective equipment including skin and respiratori^ndura reenter the area. Obvious sources of fgnition such as internal combustion engines, welding machines and so forth should be shut down.
8. If a fire occurs, do not extinguish until the source of fuel is shut off.
Union Carbide is extremely concerned about the health of its employees and has participated actively in the investigation of the vinyl chloride health hazard. There is little dispute that vinyl chloride is carso-
'TtsC' genic to man, but the level of exposure which is hazardous, can aqw be definitely established with present evidence. Workers who've developed angiosarcoma have all had many years ofhigh level exposures to vinyl chloride. It is well known that exposure levels have been dramatically reduced since the 40's. Further, there has been no evidence that man or animals have developed cancer at exposure levels of less than 50 parts per million. We urge that you protect your health by learning and following the work procedures and practices that have beeb set forth. Please cooperate with the Industrial Hygene Monitoring and Medical Surveillance Programs that have been outlined.
Q UCC 093649
VINYL CHLORIDE TRAINING PROGRAM
Following the discovery in 1974 that a number of workers engaged in the manufacture of vinyls resins had died of a rare form of liver cancer called angiosarcoma, OSHA issued a standard on October 4, 1974 covering workers exposed to vinyl chloride. Certain facts of this standard that will be covered in detail in this training program require sig nificant changes from past practices.
A medical surveillance program will establish each employees health and his suitability to continue in an area where exposure to vinyl chloride is a possibility.
euuL* Monitoring of exposure w-ill be required. Two techniques will be employed, individual personnel monitoring and area monitoring by on-site gas ana lyzers that +444 provide continuous reading of the level of vinyl chloride in the work place. Regulated areas -will be established where vinyl resin is manufactured or packaged and where vinyl chloride monomer is stored or handled whenever the permissible exposure limit 4s exceeded-. Access to regulated areas shall be limited to authorized persons, and a daily log
-cjl/' /u wV+Zi-iLQ/u-As uqs of persons who enter shall be maintained. These regulated areas wi44 -be appropriately marked by barricades and signs. The wearing of resp-
jlqs
irators wi11 be required where week or exposure may exceed permissable limits. Protective clothing t-haf- -fi tg. tha ritnatinn wiil-fw required for various levels of potential exposure. Training programs, such as
A
the one being presented here, w/lffi-To provided. A copy of the full standard as issued by OSHA will (jcTmade available to any employetf'upon request to his supervisor.
UCC 093650
CD
Vinyl Chloride is a gas with a sweet, pleasant odor. It is used to
make a solid material called Poly Vinyl Chloride. As PVC, it has a
multiple & uses in the plastics industry such as pipe, records, in-
A
sulation, upholstery, kitchen food wraps, shower curtains, floor tiles
and many more everyday plastic products. T^e_vinv1 /frhlorida-qas-has
k
1 '/3
hfn tiffed as an anr^thrtir agrnf and ac *
Vinyl Chloride is a flamiable gas at normal
aspheric conditions with
a high vapor pressure. It boils at -13 degre Centrigade. It is
more dense than air and tends to concentrajre low lying pockets. The
lower explosive limit is 3.6% by volume,
The upper explosive
limit is 33% by volume; It readily yfnites by c^umon sources such as sPar*cs flame or electrical %ark$./It has long b^en recognized that the
gas in high concentrations of 6m00 to 80,000 part^per million may
cause light headiness or.wooziriess, symptoms resembling drunkiness and even death. On removal/fron exposure to fresh aiV, the symptoms
usually clear up quickly.
In January 1974 three deaths due to a rare cancer of the liver, angio sarcoma, were discovered in workers who had-bad a long-term high level \ exposure to vinyl chloride. Subsequently, an intensive search of all former vinyl chloride workers and .medfral testing of active workers uncovered 17 cases out of 6,000 workers since 1961. This is statistically significant since only about 20 cases of this cancer, affect&wf-the walls of the blood vessels of the liveware reported each year. Angiosarcoma has also been caused by arsenic and by an X-ray dye called thoriumdioxide. Animal experimentation has also produced this condition in mice by long term exposures of 50 parts per million of vinyl chloride.
UCC 093651
As a result of these findings, the government, through OSHA has enacted a standard regulating the exposure of workers to vinyl chloride. As a part of the standard, every employee will be offered an ex amination prior to being assigned to work in the regulated areas. The examination may be repeated annually for the first 10 years. Following this, it will be offered every 6 months. The examination wiW-consists of a medical history with special attention directed toward drug and chemical exposures, hepatitis or other liver disease, blood^trans'fusions, alcoholic intake and smoking. A blood sample wVf^o drawn for an analysis of five special liver function tests, and finally a clinical examination will--be performed with special attention being directed toward detecting enlargement of the liver or spleen. These tests are not for diagnosing a cancer but are intended only as a screening to determine whether or not the employee is at any risk in continuing to work in the regulated area and whether he may safely use a respirator. Each employee will be furnished a statement advising him of the physicians opinion as to a suitability in continuing to work in the regulated area and to wear a respirator. The examination is purely voluntary on your part. If you do not choose to take it, we request you sign a statement to this effect. You will again be offered the examination at the appropriate intervals. As of now, thorough investigation of all past and present vinyl chloride workers in the Texas City Plant has failed to find any cases of angiosarcoma of the liver. The results of the examination are available to you and your personal physician on request. By law, they may also be inspected by an OSHA compliance officer. They will be kept by the medical division indefinitely. Medical divisions will welcome any questions concerning acute or chronic toxicity of vinyl chloride and will be happy to provide you or your physician with any information we have.
UCC 093652
The vinyl chloride regulation also requires monitoring a^vinyl chloride
monomer. The purpose is to determine the exposure level of each em
ployee without regard to the use of respirators. Personal monitoring
is performed by attaching an activated carbon tube to the collar of
the employee. Air is drawn through the tube at a metered rate by a
battery-powered pump attached to his belt. Vinyl chloride is absorbed
on the carbon and retained for laboratory analysis. The level of ex
posure is calculated for the total volume of air sampled. Individual
exposure records are available to each employee and will be maintained ^TfcjL.
for a period of 30 years. ^ Introduction area#, multiple sampling ^
points are strategically located. Air is drawnm automatic
central unitswhich monitor>L levels at each point by sequentially in
jecting a contrortl4d air ~~ * directly into the gas chromatograph
-eh vinyl chloride level isrJU^&Su/rXL4C cnC
T7U- CUAj <*
sampling point is indicated on a^chart
U/xlJu As &rrfHl*Xts 4)CAsn ej
QtMAJtt yO*****%-,
ryeeccaarc&r. The instrument is calibrated once each complete cycle.
*
These recordings indicate upsetsj roloasas, ^d elevated concentrations-
-which act-i-vate an alarm system. Data of eontrolBB-iuum levels In- p y-- -
dicate personal expn<;nrp_s-MHiiii l.hn
anH pntpnt.ifn ex-
josures outside arp inrii rated before one 1pvpc thp_r_nntrnl rnnm.
The^ermissahle-employee exposure levels are one part vinyl chloride
per million parts of air by volume averaged over any 8-hour period ce`(b*J6
with asealing of 5 parts per million averaged over any 15 minute
period. No direct liquid contact is permitted. A concentration
of vinyl chloride greater than 5 parts per million is considered an
action level which requires periodic monitoring and medical surveillance.
The periodic monitoring frequency depends on the level of employee
explosure. Exposures above the action level but lessen the per-
missable level of 1 parti- per million are monitored at least quarterly.
.7 UCC 093653 '
Exposures above permissable levels are monitored at least monthly.
Monitoring will also follow changes in control, production, or process
that may increase the release of vinyl chloride. [Regulated areas
----------------- ----------------- -
1
are established for production areas with levels greater than the
permissable exposure levels. The regulated area is defined by a -sense
Tline -frrr signs. Personnel, other than production oprsonnel assigned
to a unit in the area, must Ghocrc in with the Bhiffryproduction/supaE-
V.isor or his Hplpnate-HJPOtr^ITtertnTrdlllJ-TeavinQ
--This is
dene-hy signing the area 4og-kept in the-wrt control room at Building
114. An instruction book is kept in this location and should be re
viewed before entering the area. Also to be observed are: warning signs, cuch as tfanra plnrnrl nn ww.*p- i`ppppirlpc whirh r-nnfoin VPM nie
vhm rnnta^m-ng m^tpriftig signs warning uf n vinyl rhlnrliV rr-1 rr>or
signs announcing teat the regulated area into which unauthorized per77Ul^'*4_-
sonnel may not enter. Where vinyl chloride exposures are over the
permissable levels, authorized respiratory protection is required to
be worn and a respirator program is maintained. Three types of
equipment are provided in regulated areas. Air line respirators are
used for hazardous operations which have exposure potentials that are
known to be-teft in a lower explosive limit^wh^eli is 3G,U(J0 parts' per
This equipment is pressure demand type equipped with an
auxiliary egress bottle and a full faced piece. It is used for
routine work involving elevated exposures. Entering the concentrations
aboveA 3,600 parts per million is authorized only for rescue, fire
fighting, or securing equipment to prevent release. Air purifying
cannister respirators are authorized for concentrations known to be
no more than 25 parts per million. The cannister is good for 4 hours
or to the end of the shift, whichever comes first. -Mhen-tho monitor
tb*** i
UCC 093654
alam-signifies levels above '25-parts per-min ion, girl fne-equipment must
be itfechr* The cannister respirator is used within regulated areas generally
for mobility. It will not normally be required within control rooms. A
30-minute bottled air system is prnviripd
rg^nCy use nnl_v^ It is
a pressure demand type self-contained breathing apparatus with full-facef
piece. It is approved for unknown or even explosive levels for purposes
of life rescue. It-should-no-t be--used for routine work. -Every Effort/}
ic being mado to lower vinyl chloride .to lasspn one part per-mT-Herr-irr^the
vinyl area and to maintain-it--at that level. On occasion, -tbs' possible
exposure will rise above one part per million due primarily to leaking cbfiv^
valves, seals, flangese-aad to release through rupturednos-i. or safoty-
va+ve*. The vapor fraction analyzers located in Buildings 115*
mr?nZ*iUit ^ /5U
//1'p oMsL*'
Aflfr should be- cheeked ai-Lr-ereggu_r_t a_r i_n__te_ryal^-a^nd-e_sp_ec_a_a_l_ly - b_ efor_e-e__n_tering,, . * .
Q_JjuU
/ulo
<5) ruH&U, a.Mi UxjOasaa-s rfAUiA;ZtrAL,
a Que^im^ablg area, to determinfe-v-iny! cb?<*ride-exposureHevel-. Based on *
'PU. /u
__
the level, the need for respiratory equipment can fcro detoryfri-ned. -Red-
lights are located-at-tidUriiiUividua!
around-^hQ-susfijenaion
aou-suI venfares. When the vinvl chloride conccmtration in the area re
quires the use of respiratmy equipment., these red lights will-flash. A
jflashinq rprf Hqht maanc that ynn miff- i.h-i- i p r|i i i .1 Mgr nqinpmnint- m-
the-area. Normal operations requiring precautions are: atrio*ffi-a&e dofftPLZXrt*- o~zy>~'
sampling which normally requires wearing of a fresh air mask. ^Comprcssure/jlUuJju*-*
checks may require respirators &a*ed on the VFA reading. Connecting or
disconnecting hoses to unload vinyl chloride tank cars, requires fresh
air respiratory equipment. Sampling of these cars also requires fresh
air equipment. Vessel or confined space entry is covered by plant
procedure 1D3. This procedure calls for proper isolation, emptying,
electrical lock-out, cleaning, purging, ventilating, and testing of the
vessel before entry is allowed. Testing may be performed by either
operations or industrial hygene personnel.
UCC 093655
o
Entry is not allowed until the test shows a safe atmosphere and a hazardous
wor,k permit has been filled out and approved. The opening of a pump,
compressor jw^grping that normally contains vinyl chloride, should follow
the same-general procedure. No equipment whose contents include vinyl sttrCZJLs'*
chloride shouTd be emptied directly into.the atmosphere#wiidu~proper
authorization to insurp all--ngressary precautions' have" been taken. ,-JLL possiblfri^he equipment should be emptied to a part of the process where
it will not enter the atmosphere^Itlhon cloan-ing vessels that contain
polyvinyl rhWit-la . miilnmi, pvnl^tw* rlnllnmj lV-tn hn wnun to_prpypnt.^
<fkin I'nn+irt W1`ft, oyr meiiiuuc-inr um.^yaiir.. in the laboratory,
samples containing high levels of vinyl chloride should be opened and
*
handled under a ventilating hood. The use of respirators during-f-uel A
.based on VFA__readinqs- The distribution area is also affected by the vinyl
chloride regulation since the PVC resins, which are handled in vinyl shipping, contains some residual vinyl chloride monomer. .-Although t/inyl
ihipping is not a regulated area* thor-o arc enma artnal
T-and-5 parts por millions lasting-less than id minutest IHese areas apply to suspension and non-solvent vinvl resins and inrlude work
opperatinns snrh nt nprning nnd riming hntrhn nn ln-mird hnppn^rnr-n
oepning and closing hatches on van
Srunpl1'"1! hf>rPn,r
sampling
van hnwr-ii--and nprning van hour*; tfi hr Ui'i In i1~- -Qno.partiGul.afr area
concorn-is the entering of van boxes. Van boxes should not be entered
until after they've been washed. Entering a van box prior to washing
could result in a VCM exposure over the permissable limits. -ATT", all -sheuld-be checked for VGM loveTs before entering in order to avoid
exposure over the permissable limits. Conditions which may result in a
release of vinyl chloride fall into two general categories: process
upset and equipment failure.
UCC 093656
Each unit operating manual contains a description of normal operating
conditions. Every operator should be familiar enough with his unit to
recognize abnormal-operating' conditions. Some key points to watch are:
level gages of vessels containing VCM or other materials with the VCM
content, pressure indicators for VCM containing vessels, the temperature
recorders for the -ettt-of
since an uncontrolled reaction might
lead to venting^and the rectifying column refljex recorders .at the sol*-
-vent unit ^ince loss of reflex might cause an indirect loss of VCM at
the compressor traps. ^Decanling uf walei (Turn VCM tanks to tho ti3 stripping
t-iilTrn,,inn
r^qnirpT f~arrful operatorjrttentjon to be
sure that VCM is not rplased to thn ntmnnphnre Equipment failures
are easy to spot but not so easy to predict. The best remedy is a
thorough inspection of all processing equipment at least once each
shift. Areas to especially watch fdr are improperly sealed /afety
valves, process valves which have Aeen left partly/opened on leaking,
/ /pump compIressor orIagitatoIr seals which are leaking or any'other'^con-
dition which is out of the ordinary. In the event of a massive release
of vinyl chloride the standard operating procedures will be implemented
at once. Key steps in these procedures are:
4juk>^jL> 1. Activate the -daily^system in the infected area.
2. Alert all personnel to clear the area using the PA system.if available Clear the endangered area of
personnel at least 25 feet upwind and 50 feet down wind of the visible vinyl chloride cloud. Personnel should exit crosswind. If the wind direction indi cates the endangered area may extend beyond the con
fines of the particular unit, the chief operator should notify the affected personnel of the danger.
3. Sound the plant fire alarm and toxic gas alarm.
4. Isolate the affected area. If possible, rope the area off and post warning signs. Road blocks should be set up if required.
jtukJ 5. Isolate the relief source by remote valves or pumping
arrangements outlined in unit procedures.
6 UCC 093657
4
6. Use all available water to disperse the cloud and form a water curtain.
7. Only specially trained personnel equipped with properly proteive equipment including skin and respiratory^froiTVa reenter the area. Obvious sources of Ignition such as internal combustion engines, welding machines and so forth should be shut down.
8. If a fire occurs, do not extinguish until the source of fuel is shut off.
Union Carbide is extremely concerned about the health of its employees and has participated actively in the investigation of the vinyl chloride health hazard. There is little dispute that vinyl chloride is carso-
'7USC~ genic to man, but the level of exposure which is hazardous, can now be definitely established with present evidence. Workers who've developed angiosarcoma have all had many years ofhigh level exposures to vinyl chloride. It is well known that exposure levels have been dramatically reduced since the 40's. Further, there has been no evidence that man or animals have developed cancer at exposure levels of less than 50 parts per million. We urge that you protect your health by learning and following the work procedures and practices that have beeb set forth. Please cooperate with the Industrial Hygene Monitoring and Medical Surveillance Programs that have been outlined.
UCC 093658
A