Document dY2EjD79zZRrBw858nDmERogR

/} A* ~CL 0 / FEB DEPARTMENT OF HEALTH, EDUCATION. AND WELFARE public WEALTH SERVICE CENTER FOR DISEASE CONTROL 4 1974 5-1 eft NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AMO HEALTH 5f>OSTISI<r>!S LAWS ROCKV'ILLC, MAhVLANO JCSE1 ,/ C- Kr. George E. Best Manufacturing Chemists Association 1825 Connecticut Avenue, K.W. Washington, D.C. 20009 Dear Mr. Best: On January 22, 1974, representatives from the 3. F. Goodrich Chemical Coopany, net vith myself and other staff of the National Institute for Occupations! Safety and Health (FXOSH) to present their concerns that recent deaths of several of their employees at their Louisville, Kentucky plant might be related to occupational conditions, Had not the Company taken the initiative it did in following up on suspicions aroused by the occurrence of the rare type of liver cancer (i.e. angiosarcoma) discovered in several of it s at autopsy, it is entirely possible that the significam 1 attached to the appearance of those tumors would not hav izsd for several sore years. As a result of this information, a valk-l on January 24 in the Company's facility i Also participating in the survey at the s were representatives from the Department Kentucky, tha Occupational Safety and Hef V-S. Department of Labor and the Epidemic of the Center for Disease Control (CDC). vey vras conducted Le by NIGSH. ^uest of 2<I0SU E the State of stration of the nee Service (SIS) Ve were cost pleased vith the Company's excellent cooperation vith the survey teas in providing access to Company employees, union representatives and Company records of medical ond employment history significance. The agreement of officials of the Louisville facility to provide continuing cooperation vith the organizations participating in the survey demonstrates the sincerity and concern of the 5, F. Goodrich Chemical Company in determining the significance of past and present conditions of employment which may have either precipitated or initiated the induction of tumors in certain of its employees. On February 1, KIOSH will brief representatives of the Rational Cancer Institute 0CI), the Food and Drug Administration (FDA), 20105001 IFG.1893 BFG01893. Page 2 - Hr. George E. Best and the National Institute for Environmental Health Sciences (KIEHS), as to the results of the initial survey of the Louisville plant and also review the results of the investigation thus fsr. Subsequent to this nesting, I3I0SH will develop a protocol for further field studies as veil as recommendations for nodical diagnosis andfollow up. At this tire the etiologic role of vinyl chloride in the induction of the observed liver tutors is not certain. The occupational exposure of tha deceased workers to over 50 other chemicals at the Louisville facility precludes a clear definitive role for this substance as a carcinogenic agent until.the degree of exposure to other chemical substances and work histories of deceased employees can be evaluated. However, the implication of vinyl chloride as the possible etiologic agent is not readily distiissable acu, unless an association with another of the chemical substances is revealed, vinyl chloride must remain as the principal etiologic agent of i suspicion. Until well-documcntcd rccottacndations to OSHA can be developed, we ere recommending that the preliminary work practices and monitoring i ana control procedures for the polymerisation of vinyl chlorides (Enclosure 1) be instituted as interim measures, These preliminary procedures are based, in part, on the information on hand concerning the operation of the Louisville facility and on the results of the walk-through survey conducted by members of the Institute's staff. These recommendations in more specific detail have been transmitted to the B. P. Goodrich Chemical Company for impleaentst3.oa at their Louisville facility. Mr. Vernon 5. Rose, Acting Assistant Institute Director for Research i and Standards Development will provide NIOSH coordination in develop f i ment of controls and/or standards to be recojnmended to OSHA. Hr. Rose or members of his staff may be coached by telephone at (301) 443-3680. They will insure that all requests for technical information or assistance concerning this situation are directed to appropriate NIOSH staff or members of the other Federal agencies involved with the ongoing study. , The possible significance of vinyl chloride as a carcinogenic substance requires close cooperation between the vinyl chloride industry and State and Federal agencies. Consequently, it is A ,'tsy hope that through your organization the above information and 20105002 >t FG,1894 BEG9.18?4 20105003 sjir.aoxocs i i f i . i' Ii i i. ssssaooid ssohi Sutsh ssTucdcoo isqao 01 co-pnqfjtiSTP asgp-fA oipj SAxnoaa uao suo-pepuaunrooaa pasopotra 3S3S *2 sSaocO *JH - sSs, Enclosure 1 NIQSH Recommended Precaucionary'Kcnitorins and Control Procedures for' Polymerisation Processes Involving Vinyl Chloride I. General Housekeeping Procedures A. The spillage of Vinyl Chloride end Polyvinyl Chloride in and , around the production facilities should be controlled as follows: 1, Housekeeping procedures should be implemented to a s sui'eiussediate removal of VC and FVC material around polymerization operations including drying, packaging and loading operations. 2. Recovered FVC enterial vhich is to be packaged should be stored in closed containers. 3. Haste PVC material should be stored in closed containers ar.d consideration should be given to the adequacy of its disposal and/or destruction. Care should be taken in the storage of closed containers to insure that unsafe conditions do not result froa an internal build-up of pressure in the container. * . i B. Inventories of beginning and recovered quantities of VC and quantities of PVC produced, packaged and recovered should be cade to determine losses and probable areas affected. C. PVC material should be removed from overhead structures and conduits where it tends to'collect. ' JD. Consumption of food should be permitted only in separate facilities provided for this purpose, and no food products should be permitted elsewhere in the polymerization facility. \ II. Protective Clothing A. A daily change of protective clothing including full coveralls, or the cquilvalent, should be provided each employee in areas where \ . possible exposure to VC PVC could occur. Clothing contaminated by , accidental spills should be changed as soon as feasible. B. Protective gloves and footwear, or footcovcrs, should be worn as appropriate in those PVC operations where exposure to PYC material is ipossible. ;'C. Protective head covers should be worn during PVC operations as appropriate (e.g. hard hats in those areas where physical protection of the head is necessary and hair coverings, or the cquilvalent, in BFG01896 T 20105004 operations such as cleaning of polymerisation reactor tanks and packaging operations). D. Where employees arc engaged in maintenance or cleaning operations of polymerisation reactors tanks they should wear full impervious suits to guard against skin contact of PVC material and VC vapors. Procedures for safe entry to confined spaces should be observed. III. Shavers Showers at the termination of an eight-hour work shift should be mandatory for all workers with possible contact with VC-ITC. IV. Monitoring A. Environmental Monitoring 1. 7n-plant environmental monitoring programs should be implemented; and where workers are required to cater polymerization t3nks, a survey of the VC concentrations should be cade in the reactors imaediatGiy after opening, immediately prior to entry of maintenance personnel and during the tank cleaning operation. 2. Data obtained from the environmental monitoring program should be used co indicate those areas where efforts should bs directed to reduce airborns levels of VC. 3. Positive programs to initially control VC levels well below the present Federal Standard of 500 ppm should be dcyeloped Cscme companies are targeting at 50 ppm) and efforts to further reduce levels should be given consideration concomitantly with the necessary codifications in engineering and design controls. ` 4. The concentration of VC in exhaust ventilation should be determined to estimate the amount of VC lost during operations and the possible exposure of personnel immediately outside the facility. * 5. Monitoring for PVC particulate material should be eccosplishcd to estimate the degree of exposure to this substance throughout the facility. B. Personal Monitoring 1, Integrated, eight-hour personal-monitoring samples should be obtained from those employees considered to receive the greatest exposure, to VC or PVC. 20105005 BFG,1897 BFG01S97 2. Breathing sone samples should bo obtained 't`6 complement environmental monitoring program for VC* and similar samples should be obtained for PVC, V. Respiratory Protection Because VC is a gas under asbiont conditions and ?VC is a solid under these conditions, it is recommended that respiratory protection for employees take these circumstances into consideration. A. Where employees are engaged in cleaning and maintenance operations inside polymerization reactors they should be equipped with an atmosphere-supplied respirator in order to protect against both VC vap.or and ?VC Farticulatcs. B. During housekeeping procedures and packaging operations where the possibility of PVC dust inhalation is a factor, it is recoitnendcd that an air-purifying respirator equipped with a mechanical filter designed to remove particulate material be worn. Respiratory protective devices which meet this requirement, as veil as protect against VC vapors in concentrations las* than 0.1% hove been approved by the KIOSK Testing and Certification Laboratory and bear the numbers: TC-23C-40, TC-23C-47, TC-23C-48. C. Where employees are engaged in transfer operations of YC from railway tsnkcars to storage facilities or at; any similar transfer point which requires manual operations, they should wear 5 selfcontained breathing apparatus (SCB/i) during such operations to guard against unexpected release of VC during such operations, D. Other operations involving possible exposure to VC or PVC should ' ba evaluated as the individual situation exists and respiratory protection provided as appropriate. r . BFG01898 T