Document dQDOoZL7JyLVXVwxEqprj1BaQ

4 :losure 7 U.S. DEPARTMENT OF LABOR Occupatiun.il S.ih:t\* and lUultli AJmmiitrjtion WASHINGTON', PC. 20210 Mr. .R. S. Brookman, Manager Research, Development and Technical Services Firestone Plastics Company Pottstown, Pennsylvania 19464 fJ, ^ vi;'l \ *" '* l'' .1 Dear Mr. Brookman: In response to your letter of July 14, 1975, petitioning for modification of the Vinyl Chloride standard, the following determinations have been made: 1. 29 CFR 1910.1017(b)(5) Definitions In regards to the definiton of "massive release." in Program Directive #200-35, we agree that the definition should be modified. This will be addressed in a future program direc tive. In all probability the stipulation of 100 ppm will be removed. 2. 29 CFR 1910.1017(b)(6) Definitions ** The standard defines a fabricated product as being one which is "made wholly or partly from polyvinyl chloride, and which does not require further processing at temperatures, and for times, sufficient to cause mass melting of the polyvinyl chloride resulting in the release of vinyl chloride." "Release of vinyl chloride" means the release of an amount of vinyl chloride which would likely result in employee expo sure at or aDove the action level without regard to the use of engineering controls. Products which can be classified as fabricated products ore exempt from the provisions of the vinyl chloride standard. All other products are subject to the requirements of the standard. It the employer uses or manufactures a product which is not a fabricated product, he must initiate monitoring procedures. If the monitorino reveals that the employees are not exposed to vinyl chloride at or above the action level, the employers' operations will be exempt from the provisions of the standard. boR 014366 However, if the monitoring reveals exposure at or above the action level, the employer must implement the procedures specified in the standard. 3. 39. CFR 19101.1017(g)(4)(iii) Respiratory protection Regaiding your suggestion to add a Type C, Supplied Air Respirator, Pressure Demand type, with full or half facepiece to this section: If an employer can show that a respirator provides equal or greater protection than those specified in the standard, he may be granted an interim order or a variance from the standard. Your company received such an interim order, dated May 30, 1975. '4. 29 CFR 1910.1C3 7(k) Medical surveillance There is no OSHA regulation requiring an employee to submit to a medical examination. If the employee refuses any medical examination required to be provided by the employer, the employer shall inform the employee of the possible health consequences of such refusal and obtain a signed statemen from the employee indicating that the employee understand the risk involved by refusal to be examined. We greatly appreciate your sharing data, experience ar.d knowledge with us. At the present time there are no plans to formally amend or modify the vinyl chloride standard. We hope that the above clarification of the regulation will satisfy the request in your petition. Should you have further questions please do not hesitate to contact us. U rr Secretary for Regional Programs Copy to T. C. Walker 1P/26/75 Copies to: Mr. W. B. Connolly Mr. J. J. Onssidy, Mr. c. J. I'lcinert Mr. F. F. Hoy Mr. r. V. Arnold Mr. H. N. Most Mr. G. D. Lloyd Mr. R. A. Park BOR 014367