Document dn4J0vRQpyQoVzZzo3Na6MNX6

C&CAMtlA PLANT INC* INTEROFFICE MEMORANDUM To: Howard Watson From: Dale H. Francke Re: Visitor Information Sheet for PVC Plant Admittance Dote: 12 March 1975 Copies: J. T Barr Jofws E. A. Primeau Attached is a copy of the proposed information sheet which will be given to visitors at the Escambia PVC Plant. Plans are to include this sheet in our unit operating procedure, which is being typed. Please comment on the attached form. If it is not satisfactory, please supply me with an acceptable form which we can use for our procedures manual. /ms Attachment Dale H. Francke AP00034549 NOTICE TO ALL VISITORS You are entering an area that may contain vinyl chloride (vcl). it is a sweet smelling gas that will deaden your sense of smell after breathing it a few times. If you smell this, immediately leave the area, since continued breathing of the fumes will cause unconsciousnes s. You have been issued an air mask which will be required in the event area levels of VCl become higher than the OSHA permissable level. All operations and procedures are designed to stay below these levels, but in the event the alarm system does indiate a high level you will be required to use the air mask or leave the area immediately. Follow the procedure below in using the air mask: HOW TO USE THE AIR MASK: Putting on the Facepiece: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. Attach filter body to belt using belt clip. Make sure all head straps are fully extended. Using both hands - Grasp together one temple strap and one cheek strap in each hand. Place the chin into position in the facepiece. (See Figure 1.) Draw the head straps over the head, be sure they all lay flat against the head. Simultaneously draw up and back - both CHEEK (bottom) straps. (See Figure 2.) Simultaneously draw-up and back - both TEMPLE (middle) straps. Place palm of either hand on the junction point where the straps join, push DOWN toward the back of the neck. This exerts a pull on the TOP strap or straps lifting the facepiece into proper position. Repeat steps 6 and 7, taking up any slack or looseness. Adjust TOP strap or straps ONLY if necessary to securely hold the facepiece comfortably and safely in position. OSHA regulations require that you be instructed that Vinyl Chloride is a cancer-suspect agent. March 12, 1975 AP00034550 A&^ck/^ot&cZi- a*u %etntca& CSCAMftl A PLANT INC. INTEROFFICE MEMORANDUM i v, iTnnrn Dots: 19 March 1975 From: D. H. Francke Copies: j. T- Barr R#: PVC Programs Related to VCl Exposure Weekly Report C,_ R` E- 'JQnes 1* Work on completing the PVC Operating Procedureis^^^^*. continuing. The manual should be ready for printing within the next two weeks. 2. Installation of the Data Processing Unit is continu ing. Initial results are being received. Some small changes are being made to make the system completely operational by 1 April 1975. 3. The CEA for the new chemical cleaning system is being reviewed before completion and issuance. 4. The CEA for the OSHA related projects was approved and work is progressing toward installation of the projects. 5. Stripping conditions of 180 F for 30 minutes have been successful in maintaining residual VCl levels below 100 ppm in PVC 1230. A procedure of delayed temperature increase during stripping was started on PVC 1230 just prior to switching to PVC 1225. Initial results looked goSfd and the procedure will continue when PVC 1230 is made again. /ms D. H. Francke AP00034551 CMR Study^ew Hazards - -r oi V I^is more apith year since the first news broke concerning the link be* tween vinyl chloride and cancer of the liver. Since January of last year it-has become evident that vinyl chloride monomer and polymer manufacturing and processing industries have en tered a new era. The Federal government has set strict limits on the'amount of vinyl chloride that workers can be exposed to at plants, and these regulations have recently been upheld in Federal court. Moreover, indus try Has, in spite of its protests of hardship, already begun to comply with the new safe ty standards for VCM. Last week a leading expert on environ mental diseases assessed with considerable satisfaction the events of the last fourteen months and concluded that "vinyl chloride is a real success story.4* THe man making this pronouncament-was Dr. Irving J. Seli- koff. of Mount -Sinai School of Medicine, New York, and'he made it at a panel dis cussion on occupational carcinogens that was part of a week-long conference on this subject held in NewYork by the New York Academy of Sciences. * SWEDISH EXPERIENCE Dr. Sellkoff's examples of the progri that can and has been made in redtu health hazards at vinyl plants inhe were matched by those brought forwa Dr. Anders Englund, a Swedish1Tp health official. Dr. Englund explained although considerable opposition hkd'^ voiced against tough new VCM standards Sweden, the operators of Sweden's1-' VCM plants (Kemanord AB) Had bean'k..1Tt to reduce VCM levels at its 60,0004on-be?v year PVC plant at Sunsvall to 1.8 ppm wfceS . forced to it and that VCM levels at other*7 vinyl processing plants in Sweden had t 51 cut to p.5 ppm. ' Dr. Selikoff cites the progress'ma& ie . date at vinyl plants as evidence that the t stringent OSHA regulations on VCM~a feasible without economic hardship ahdfa'Y continues to urge regulations requirlhg-no; exposure of workers to human carcinogens -a zero limit. This is a practical matter.' "We ask for zero'Yaays Dr. Selikoff,'^be cause to get l ppm, you have to deslgn'lor zero. He explains tftat if ngineers-n asked ta onr nnm. the vet, they design will inevltablypermlt high* levelsfly ACCaSione leakage. While "viiiyi dilAWUe his undoubtedly been the most controversial toxic chemical over the past year, it was by no means the focus of last week's New York Academy oi~ Sciences conference. Other carcinogens!; and carcinogenic environments were d]tr? cussed. --jiF.' The essential element in the success story, as Dr. Selikoff relates ip, is speed; the speed at which,government moved to adopt rigorous safety standards on work place exposure to VCM once thevh*alth hal ted was recognized and, perhaps more im portant, the spcc^at which some^segmcnts ( ' of the ^yl4qdS^|%VcLj^giiiUp comply- with theta standards^ .'Jss*ns The exposure standards on VCM. set by OceupationaJ.-8afetj^4 HealthsAdministra tion require** ambient air level of one pert of VCM per million psrtsof air at a timeweighted average over an eight-hour day, a five-hundrpd-told reduction from the for mer safety standard and a fi^y-fold, reduc tion from the temporary tmjtjgencjr.stan- dard now in effect. The OSffA-standard has been - stayed pending .an appeals* the US Court of Appeals by the SoM^poC plastics Industry, which claims ttedMulird is technologically^ and econohiuMdly -ynfeasi- Dr. Selikoff would appga^aofto share the SPI views; he is more impressed by the example of the polymerisation-plants In the US that have set out to meet the standard. Including several that he visited'where the VCM level had been cut: to two.npm six months ago. Dr. Selikoff also eitdd a-major maker (unnamed*but believed to"be Robin- tech) of PVC pipg'foi' having reduced VCM ambient air levels at its plants to the TWA equivalent of 0.5 ppm.-'4*?*" . halat products mas; and.ajleuocai& robIastbnias*of tfca>bi maliguanj- 1 -.an'" vinyl chloride;: cMcer.c!! these same "AHhedgkuTit mnUlpUvehenticil-*] these plsats end tfcatUMrf brein-and-lang caneerJdaatfcs1 seas'1employ*d at various plat die plant,'the evidence.] chJorfdiHk <he'cauf)il'S}s cesr-malignant -neopl AP00034552 SP1 Petitions for $! Of VCM Rules Denie The US Circuit Court of Appei the second district in New Yorl denied a petition by Society of ^ Plastics Industry and others for a sfty' of the vinyl chloride/standards schejij- uled to go into effect April 1. ' The SPI petition had asked that the Oc cupational Safety & Health Administra tion's VCM standards be delayed pending a decision by the Supreme Court as to wheth-- er or not it would hear an appeal. The order was signed by Tom Clark, for mer Justice of the Supreme Court; Freder ick Van Pelt Bryan, retired judge, and Jus tice* Kevin T. Duffy, Southern District of Newf Yorfc-all of whom were "sitting by designation" in the case. >The April.1 date for implementation of :'th&*itand4|B$> was set by the judges at the p end of"December when they denied a peti tion of.SPI and others for a judicial review cf4fi5VCMvstandards. - -- .........-........... ^Observers believe it's possible the indus try. gfroup may now approach one of-tbefin* ' prenrt Coart -justices with a request fo^* , lta*;whil:waiting to see if the high court \\ wilTOeAz^adf? appeal. AP00034553 VCM Work Standard iA^efled to High Court. *Swiety of the Plasties Industry will petition the.US Supreme Court to reyiew the recent US Court of Appeals decision upholding the Occupational ' Safety. & Health Administration stan- -dard on vinyl chloride monomer . (CMR, 2/10/75, pg. 3). gPI began the appeal process last week r'by filing a motion asking the US Court of * Appeals for the Second Circuit to stay its ruling of January 31- This decision upheld -the OSHA standard but gave sixty days (until April 1, 175> lor compliance. The motion for a stay would set aside ' this ruling pending application to the Su preme Court for a writ of certiorari. Contin- . uance of the temporary OSHA standard, j.e&iefc currently limit* worker exposure to "HRr parts per million of VCM, is also MnoUgbt pending final ease disposition by the raupreme Court. The emergencytemporary ^standard has been in effect during the ear lier litigation. Petitioners have stated that the applica tion-for a writ of certiorari will be filed within twenty days and that they will make Jevery effort to expedite" the new proceed- '.tags before the Supreme Court. . Certiorari will be sought on the grounds ..the Court of Appeals for the Second ^ Circuit erred in -Hi interpretation of the * ^substantial evidence" rule to uphold the * ^"^aaent vinyl chloride standard whfch promulgated October 4. 1974, and established an exposure level of 1 .mUfibn.'; farther argued that, contrary to Enabling legislation, "the standard VCM-PVC industry to a teeh- and economically infeasible code." ag to' SPI, even OSHA Adrainis- 'tJehnSteoder has conceded the in- of the standard and based the ' on,ptthe l-ppm exposure level on Judgement," rather than lactual . lding, Jr., president of SPI, F-VCM-PVC industry is making Off to tbduce worker exposure lev* idsihat this work will continue ro be petition to the Supreme stJm**"* s- u^utiyi,'the decision to ask the writ of certiorari is basfed ict.tbet the appellate court ruling We* required th# vcst-pvc ^due- rclop "infeasible engineering con. work practices in an attempt to ^unknowable practicable exposure T* ... . . ise OSHA'* variance procedures _i*lao leemed by the Industry as "insp. rpeowtay to'rectify the problems which WMljf he encountered in attempting to comwiththe sundard, Mr. Harding says the TM**WbeHe*e -Ike -Suprsme Court r _ resolve the final status of the stan dard.' OMR nr 2/24/75 AP00034554 PLASTIC MATERIALS PVC- A* PVC maker* prepare to carry their anti-0SHA ease to the Supreme Court (see new* story, pg 3), some industry sources are saying that, next to the capital expenditures involved in making manufac turing operations safe) their biggest worry is a deterioration in resin quality due to tox icity-related process changes. Says one marketer for a large producer: "I'm more concerned about losing some end-uses because of deteriorating quality than anything else. Some applications may be processed out of the market." The process changes involved are those related to reducing amounts of residual VCM in finished resin. There is heavy pres sure from fabricators that such residue be eliminated so that they will be spared the expense of protecting exployees from VCM exposure. A source at another major producer says; "We might all just have to accept lower quality resin than we've been accus. tomed to for the last five years or so." The reason, he says, is that reduction of VCM residue requires the application of more heat during drying processes. "When too much heat is applied, ultimate heat stabili ty is affected." he says.. "I don't see how that deterioration can be avoided." However, a spokesman for Goodrich, the largest PVC producer, said that company is "making progress in eliminating residual VCM" and added that "we foresee no dimi nution of resin quality." -- irtfi CMR 2/24/75 AP00034555 AP00034556