Document dayorKjqb6r2bVdp5xxjQGzKR

Interoffice Communication TO: Distribution ^G&; J0t ERT: XF: FROM: DATE: SUBJ: T. G. Grumbles August 20, 1990 EMERGENCY RESPONSE PLANNING GUIDELINES RF VISTA The AIHA has published a new series of what is contained in each document and which they exist is attached. ERPG's. the list A description of of chemicals for These are the best available guidelines for emergency planning, and are referenced in the draft OSHA Process Safety Standard. Please call me if you want copies of the specific chemicals listed. --j T. G. Grumbles dlj .135 Attachment cc: PROCESS SAFETY TEAM Paul Warner, Jay Reid-Balt, R. B. Newton, Dan Miller, Randy Polk, Steve Hillman-Aber, Graham Bacon-LCVCM, Stan Allen-LCCP Jerry Stone, James Cummings, T. G. Grumbles, Eric Meyer VVV 000013474 EMERGENCY RESPONSE PLANNING GUIDELINES /American INDUSTRIAL HYGIENE ASSOCIATION The Emergency Response Planning Guideline {ERPG) values are intended to provide estimates of concentration ranges where one might reasonably anticipate observing adverse effects as described in the definitions for ERPG-1, ERPG-2, and ERPG-3 as a consequence of exposure to the specific substance. The ERPG-1 is the maximum airborne concentration below which it is believed that nearly ail individuals could be exposed for up to 1 hr without experiencing other than mild transient adverse health effects or perceiving a clearly defined objectionable odor. The ERPG-2 is the maximum airborne concentration below which it is believed that nearly all individ uals could be exposed for up to 1 hr without experiencing or developing irreversible or other serious health effects or symptoms that could impair their abilities to take protective action. The ERPG-3 is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hr without experiencing or developing life-threatening health effects. The committee recognizes {and all who make use of these values should remember) that human responses do not occur at precise exposure levels but can extend over a wide range of concentrations. The values derived for ERPGs should not be expected to protect everyone but should be applicable to most individuals in the general population. In ail populations there are hypersensitive individuals who will show adverse responses at exposure concentrations far below levels where most individuals would normally respond. Furthermore, since these values have been derived as planning and emergency response guidelines, not as exposure guidelines, they do not contain the safety factors normally incorporated into exposure guidelines. Instead, they are estimates, by the committee, of the thresholds above which there would be an unacceptable likelihood of observing the defined effects. The estimates are based on the available data summarized in the documentation. In some cases where the data are limited, the uncertainty of these estimates is large. Users of the ERPG values are strongly encouraged to review carefully the documentation before applying these values. In developing these ERPGs, human experience has been emphasized'to the extent data are available. Since this type of information is rarely available, however, and, when available, usually is only for low level exposures, animal exposure data most frequently form the basis for these values. The most pertinent information is derived from acute inhalation toxicity studies that have included clinical observations and histopathology. The focus Is on the highest levels not showing the effects described by the definitions of the ERPG levels. Next, data from repeat inhalation exposure studies with clinical observations and histo pathology are considered. Following these in importance are the basic, typically acute, studies where mortality is the major focus. When inhalation toxicity data are either unavailable or limited, data from studies involving other routes of exposure wilt be considered. More value is given to the more rigorously conducted studies, and data from short-term studies are considered to be more useful in estimating pos sible effects from a single 1-hr exposure. Finally, if mechanistic or dose-response data are available, they are applied, on a case by case basis, as appropriate. It is recognized that there is a range of times that one might consider for these guidelines; however, it was the committee's decision to focus its efforts on only one time period. This decision was based on the availability of toxicology information and a reasonable estimate for an exposure scenario. Users who may choose to extrapolate these values to othertime periods are cautioned to review the documentation fully since such extrapolations tend to hold only over very limited time frames, if at all. VVV 000013475 J TO: Bob Seymour-Aber Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles August 20, 1990 LEAD PROTECTION POLICY VISIA In your comments on the draft Lead Protection Policy, you proposed that workplace lead exposures should be lowered to the point that we don't need the protection policy. The lead protection policy team certainly supports this concept. However, it should be noted that lead is unique in it's capability to harm a developing fetus. There is evidence that exposures to a pregnant female that are well below established permissible exposure limits can result in harm to a developing fetus. This is the rationale for the proposed limits in the "restricted job" definition in the policy. In essence they are to protect the developing fetus, while OSHA. PEL's are set to protect employees. However, to set a policy of reducing exposures to below limits that are possible, fetal hazards is impractical at this time. \ T. G. Grumbles dlj cc: J. R. Drumwright, D. J. Isaac, C. W. Niederhofer VVV 000013476 TO: John Kirkpatrick - Austin Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles August 20, 1990 POLYMERS MANAGEMENT TEAM AGENDA TGG: JCL: ERT: MJH: AJO: RF XF: VIS1A I am requesting that you obtain an hour of time at the next available Polymers Management Team Meeting to review new product development regulatory and liability issues. The polymers business areas are developing new products that must be reviewed in terms of the impact of multiple regulatory areas as well as for product liability concerns. The purpose of the presentation would be to describe the issues and concerns and begin to determine how polymers product development activities can be integrated into the new product development process being used by the other business areas. The presentation will be done by Bill McClain and myself. A detailed agenda will be available prior to the meeting. Please advise as soon as possible when the meeting will be. of the week of September 17th is best for us. The end ---- T. G. Grumbles dlj VVV 000013477