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PUBLICATION 24 AUGUST 1984 . -* ,J3' > ^ J o-Jjj ' ACTS/ VCri/ tfG/GN/ 33/ 6 GUIDANCE NOTE EH ++ VINYL CHLORIDE: TOXIC HAZARDS AND PRECAUTIONS URL oon Itifi CONTENTS INTRODUCTION PROPERTIES OF VINYL CHLORIDE HEALTH HAZARDS RESPONSIBILITIES CONTROL LIMITS ALARM LEVELS ASSESSMENT CONTROL MEASURES FOR MATERIALS, PLANT AND PROCESSES Design and operation Local exhaust ventilation Venting General ventilation Cleaning and waste disposal AIR MONITORING Discontinuous methods Continuous methods Measuring equipment Location of sampling points for fixed analysers or automatic sequential fixed point sampling systems Accuracy and calibration Leak decectioo Alarm systems Recording of results PERSONAL PROTECTIVE EQUIPMENT Respiratory protective equipment Protective clothing PEAMITS-TO-WORK Confined spaces Maintenance operations MAINTENANCE OF CONTROL MEASURES EMERGENCY PLANNING REGISTERED WORKERS HEALTH SURVEILLANCE INFORMATION, INSTRUCTION, AND TRAINING introduction 1 Vinyl chloride is a colourless, highly flammable gas at room temperature sod atmospheric pressure. It Is normally stored and handled under pressure as a colourless liquid. It has a slightly sweet odour dececcable at concentrations above 2000 ppm. In the UK virtually all vinyl chloride is used as starting material for the production of polyvinyl chloride (PVC) homopoiymer; a small amount is used for copolymerisatioo with vinyl acetate. PVC is used extensively in pipes, flooring, none furnishings, electric cable insulation, blow moulded containers, packaging and records. 2 This Guidance Note has been prepared on the basis of joint discussions between representatives of cne Confederation of British Industry, the Trades Uaion Congress and Che Health and Safety Execucive within a Working Group of che Health and Safety Commission's Advisory Committee on Toxic Substances. 3 This Guidance Note provides practical guidance for employers, selfemployed persons and persons in control of vinyl chloride monomer manufacture and polymerisation plants to assist them in complying with the Control of Sustances Hazardous to Health Regulations 193- and Approved Code of Practice for the Control of Vinyl Chloride at Work. References in this note to 'employers' should be taken to include self-employed persons. This Guidance Note may also be helpful to safety representatives in fulfilling their statutory functions under the Safety Representatives and Safety Committees Regulations 1977. The guidance will be used by Inspectors of the Health and Safety Executive (HSS; as part of their criteria for assessing compliance with cne Health and Safety at Work Act 1974 and octier relevant statutory provisions. 4 The Concrol of Substances Hazardous to Health Regulations 198- apply to all toxic substances used at work, including vinyl chloride. The Directive of che Council of the European Communities (78/610/EEC) on che approximation of che laws, regulations and administrative provisions of the Member States on the protection of che health of workers exposed to vinyl chloride monomer applies to cne protection of tnose workers wno:- 1 URL 15013 FACILITIES 'Washing and changing facilities Arrangements for eaciag, drinking and smoking NOTIFICATION TO THE USE RECORDS APPENDIX l:' Properties of vinyl chloride APPENDIX 2: Sampling strategy flow chare APPENDIX 3: Model letter to the family practitioner of a vinyl chloride worker on his leaving employment with vinyl chloride APPENDIX 4; Model fora of consent for disclosure of a worker's medical records relating to vinyl chloride to Appolaced Doccoc APPENDIX 5: APPENDIX 6: Records Legal requirements URL 15014 URL 15015 (a) are employed la works la which vinyl chloride Is produced, reclaimed, scored, discharged into containers, transported or used la any way whatsoever or ia which vinyl chloride is converted into vinyl chloride polymers, and (b) are likely to be affected by exposure to vinyl chloride la a working area. 5 VINYL CHLORIDE 15 HIGHLY FLAMMABLE AND PRESENTS A CONSIDERABLE FIRE AND EXPLOSION HAZARD; THIS GUIDANCE NOTE DOSS NOT GIVE ADVICE ON SUCH RISKS. Vinyl chloride comes within the group of substaaees defined in Class 2 of Part II of Schedule 1 of the Notification of Inaealiaclcas Handling Hazardous Substances Regulations 1982. It also comes within the definition of a flammable gas as set out in Schedule 1(c)(1) of the Control of Industrial Major Accident Hazards Regulations 1984. Some of the requirements of these Regulations overlap with certain sections of this Guidance Note. Where this occurs reference is made in the text and the Regulations should be consulted for further details. 6 This Guidance Note does not give detailed advice on the control of emissions of vinyl chloride to the atmosphere. HM Industrial Air Pollution Inspectorate is responsible for the control of air pollution arising from industrial processes involving the production of ?VC and copolymers from vinyl chloride monomer. For detailed guidance on the control of emissions, reference should be made to tne HSE Note on Best Practicable Means BPrt 3/79 : Pecroleum Works (PVG Polymer Plants). PROPERTIES OF VINYL CHLORIDE 7 The properties of vinyl chloride are sec out in Appendix 1. HEALTH HAZARDS 8 Vinyl chloride is a gas at room temperature and atmospheric pressure and the most common route of absorption into the body is by lnhalaeion. 2 URL 15016 9 Acute exposure co vinyl chloride vapour causes central nervous system effects, the severity of which increase with exposure. Ac exposures of 50-500 parts per million (ppm) in air for 7 hours no apparent acute effects have been found in humans. However, exposure to 20,000 ppm (22) for 3 minutes resulted in dizziness and disorientation* Incapacitation occurred at concentrations above 80,000 ppm (82) over 5 minutes. Exposure to concentrations of 300,000 400,000 ppm (30-402) is rapidly fatal. L0 Chronic exposure co vinyl chloride has been associated with angiosarcoma of che liver, liver or spleen fibrosis (similar co the perilobular fibrosis known as Band's Syndrome), circulatory disorders in the hands and feet (similar co Raynaud's Phenomenon, also known as white finger), scleroderma (a degenerative lesion characterised by stiffness of che skin and soft tissues) and acro-osteolysis (a deterioration of certain boaes, most commonly the terminal phalanges of che fingers). Such effects have usually occurred after chronic exposure to levels la excess of LOO ppm (see para 12). Vinyl chloride is a proven human carclnogea with no known threshold of effect. 11 Ocher effects have been reported as occurring in workers chronically exposed co vinyl chloride monomer at similar levels of exposure, although such reports have been disputed by others. These include tumours of the braid, lung, haemo-lyaphopoietic system, and skin (malignant melanoma), lung function disorders, chrombocytopoenia and immune complex disorders. Effects on reproduction nave also been reported. 12 Tne general consensus of opinion is cnac polymerisation venters between 1940 and 1975 mighc have been exposed to levels of vinyl chloride of the following ocder:- 1945-55 1955-60 1000 ppm 400 - 50U ppa 1960-70 friid-197 j 1975 300 - 400 ppm 150 PPQ 5 ppm 3 n o s n fc in Throughout the world Chora will have been variations around cheae figures because of differences in plane design or process operation. RESPONSIBILITIES 13 Employers oust do all that is reasonably practicable to safeguard the health of their employees and others vno may be affected by work activities involving vinyl chloride. In particular, they have a duty to comply with the provisions of the Health and Safety at Work etc. Act 1974, the Control of Substances Hazardous to Health Regulations 198- and the ACoP on Vinyl Chloride. Employers may also have a responsibility to comply with the Factories Act 1961 and other associated health and safety legislation (see Appendix 5). 1" Section 2(3) of the HSW Act requires employers, with certain exceptions, to prepare, and revise as appropriate, a written statement of tneir general policy with respect to the health and safety at work of their employees and the organisation and arrangements used to carry out that policy and to bring the statement and any revision of it to the notice of all of their employees. The arrangements within the organisation for a formal system of joint consultation between management and employees and their representatives on all aspects of the Approved Code of Practice on Vinyl Chloride should also be set out in the safety policy. 13 In the safety policy, a member of senior management snould be given responsibility for ensuring chat the matters covered by the Vinyl Chloride ACoP, the Health and Safacy at Work etc. Act and the Factories Act, etc are implemented. These include cne responsibility for safe systems of work, safe places of work, training, monitoring, emergency procedures, joint consultation etc. He saould be provided with appropriate support as may be necessary. 16 Responsibility for implementing particular aspects of the Approved Code of Praccice and this Guidance Note should be allocated at each appropriate level within the organisation with a clear line of communication from plant operatives to the person in overall charge. Steps should be taken to ensure chat individuals understand and accept their responsibilities. 4 URL 15018 17 Employees should cooperate with management in implementing health and safety precautions and In making proper use of the equipment and facilities provided for their protection. They should report immediately to their supervisors any suspected faults or material defects la plant or deficiencies In the control measures taken to contain vinyl chloride and reduce exposure. IS Safety policies need to be reassessed at regular intervals eo ensure chat they ara still appropriate and effective, particularly vhen significant cnanges in plant or work activities occur. Such assessment should include, of course, the organisation and arrangements for complying vlth the legislation, code of practice, etc relevant to vinyl chloride. CONTROL LIMITS 19 The Control Limit for occupational exposure to vinyl chloride vapour in air is an Annual Coatrol Limit of 3 ppm and is eha value which should not be exceeded by the concentration, averaged vich respect to time, of vinyl chloride monomer in ehe atmosphere of a vorking area over a period of one year. Only periods of plant operation including, where necessary, any maintenance time should be taken into accoune. Periods during which alarm level concentrations are measured need not be taken into accoune when assessing compliance with the Annual Control Limit. In practice, the atmosphere of vorking areas should be monitored regularly (see paragraphs 3762) and the results summarised on a shift and monthly basis. A 'rolling average' time weighted average concentration of vinyl chloride-in-air can then be calculated and over any period of L2 successive calendar months it should not exceed 3 ppm. In this way, past compliance with the Annual Coatrol Limit can be checked and trends noted. This Annual.Control Limit is supplemented by an 3 hour time weighted average (TVA) Control Limit of 7 ppm for personal exposure with the proviso that the Annual Control Limit is not exceeded. These Control Limits nave been judged after detailed consideration co be reasonably practicable for the whole spectrum of work activities in Great Britain and should not normally be exceeded. 20 For substances, such as vinyl chloride, for which there are no known thresholds below which adverse effects do not occur not only should exposure be kept below the Control Limits but it snould also be reduced still further until the point is reached where the costs of further coatrol measures are not justified in terms of the additional reduction In risk. 5 URL 15019 ALARM LEVELS 21 la vinyl chloride monomer manufacturing and polymerisation plants there should be a system for the automatic detection of high levels of airborne vinyl chloride in places where these may occur (see para 54). The following concentrations of vinyl chloride in the atmosphere of a working area should be treated as alarm levels, signalling the need for evacuation and remedial action:- (a) 15 ppm when measured over a period of 1 hour, or (b) 20 ppm when measured over a period of 20 minutes, or (c) 30 ppm vnen measured over a period of 2 minutes. Where a continuous multi-point analyser (see paragraphs 40-41) is used, two successive readings above the appropriate concentration will determine the existence of an alarm level, ie 15 ppm over a period of 1 hour and 20 ppm over a period of between 20 and 30 minutes. ASSESSMENT 12 Under the Control of Substances Hazardous to Health Regulations an employer must not carry on any work which may expose his employees to any substance hazardous to health unless he has made an adequate assessment of the risxs to health created by the substance. The assessment involves identifying the nature of the substance, the risks to cne health of persona who may be exposed, the nature and degree of exposure which may occur during Che course of work and the steps to be taken to avoid rlstcs to health. In order to ensure effective control of exposure co vinyl chloride, it Is necessary to collect and assess adequate data on the circumstances under which exposure may arise. In existing plants, most of these data will already nave been obtained. All work activities which may involve exposure should be assessed to identify actual and potential sources of eaissioa of vinyl chloride vapour into tne wonting atmosphere. The nature and degree of exposure should be studied in eacn case. In Appendix 2, a flow chare sets out a sampling strategy for the assessment or exposure co toxic substances. Assessment permits the formulation of plans for the development and introduction of effective engineering, operational and ocher measures for the prevention or control of exposure, for the maintenance 6 ot such measures and for Che long-term monitoring of their effectiveness. Ic also iadicaces activities where the oaly reasonably practicable method of prevendag exposure is by using respiratory protective equipment. In existing plants, operating experience and monitoring data should already have led to the Introduction of most of these control measures. 23 The employer should ensure that whoever carries out the assessment is competent for the purpose and has received adequate information, instruction and training. 24 Examples of work activities which may give rise to exposure eo vinyl chloride include:- (aj transport, storage, discharging into containers, breaking down from bulk, polymerisation, reclamation and sampling of vinyl chloride or materials, including waste, containing it in residual.or unreaqted form; (b) the operation, cleaning, maintenance and repair of any apparatus or process plant used in the production and conveyance of vinyl chloride or in Its polymerisation and the handling and storage of freshly polymerised material. 25 An employer should consider not only the exposure of his employees engaged upon work with vinyl chloride but also that ofr- (a) ocher of his employees not directly involved with vinyl chloride vno could be affected by that work activity; (b) other people who may be exposed while on the premises, eg tne employees of outside contractors engaged on maintenance; (c) members of the public who may be affected by emissions and discharges from the workplace. 26 To estimate the degree of exposure to vinyl chloride by inhalation, it is usually necessary to carry out a comprehensive personal atmospheric sampling survey. However, vinyl chloride in air estimations need not be carried out in every individual case, particularly when sufficient information based oa URL 15021 previous measurements is already available in celadon co a specific work activity or vhere ic nay be possible co group employees on che basis of similaricy of degree of exposure and cype of work done co enable an adequate assessment of likely exposure co be made. 1c is importanc co scudy che paccern of exposure of workers in differenc jobs and locations over whole vorkshifcs and co identify when and where the highest exposures ere likely co occur cakiag inco account che possibility of unusual circumstances such, as plane breakdowns or emergencies. 27 Ic is Important co carry ouc sufficient sampling Co enable accurate 8 hour time-weighted average concentrations co be calculated. However, shorter term sampling may assist in che assessment of che performance of engineering controls. The survey of exposures should be extended over sufficient vorkshifcs co ensure tnac the variability of exposure is adequately studied. Further detailed information and advice is available in USE Guidance Note EH 42 - 'Monitoring Strategies for Toxic Substances'. 2d It is recommended chat che results of che assessment be recorded and a copy provided on request at any reasonable time during working hours to employees and/or their representatives ac che place of work. 29 The assessment should be revised whenever there is evidence or reason co suspecc chat it is no longer valid, as a result of, for example:- (a; a significant change in che work activity; this could be a change in plant, processes or mecnods of work that might affect the nature or degree of exposure, such as the raising of process temperatures or changes in engineering controls; (b) results of air monitoring at che work place revealing an increase in exposure; (c) data arising from health surveillance; (d) new information on health risks becoming available. CONTROL MEASURES FOR MATERIALS, PLANT AND PROCESSES 30 When considering appropriate control measures for reducing exposure to a toxic substance, che first strategy to examine is substitution with less 8 hazardous materials, including the alteration of synthesis routes to avoid using or producing toxic intermediates. Users or potential users of vinyl" chloride and polyvinyl chloride should consider the use of a less toxic substance but if chat Is aoc possible control measures should be applied as far as is reasonably practicable, irrespective of the size of che plant, co minimise exposure of personnel co vinyl chloride. 31 Control may be considered adequate whan exposure to vinyl chloride Is effectively controlled to Che occupational Coacrol Limits and as far below them as is reasonably practicable in the particular circumstances. The objective in applying materials, plant and process coacrol measures is to ensure adequate control of exposure without recourse to personal protective equipment so far as is reasonably practicable. Design and operation 32 Equipment and processes sh*o**; uld be designed and operated to eliminate or minimise the risks of leakages and spillages of vinyl chloride and co minimise che need for maintenance or other work which requires che breaching of and/or entry into plant in which vinyl chloride Is liable to be present. General ventilation 33 Good general ventilation should be provided for rooms and buildings in vnicn processes involving vinyl cnloride are carried on and as far as possible plant should be sited In the open. Local exhaust ventilation 34 Vinyl chloride should be handled la enclosed equipment provided with local exhaust ventilation at any- points where the emission of vapour cannot be eliminated by Improved design or maintenance. Local exhaust ventilation should also be provided at specific locations in process plant co ensure chat maintenance operations can be carried out safely. Venting 35 HM Industrial Air Pollution Inspectorate and HM Factory Inspectorate should be consulted on any points relating to plant or storage where cnere is che potential for the emission of vinyl chloride into che atmosphere co ensure that both the public and the workforce are not at risk. 9 Cleaning and waste disposal 36 Waste polyvinyl chloride slurry containing significant levels of residual vinyl chloride should be stripped of vinyl chloride prior to suitable treat ment of the liquid waste for general disposal. Solid polyvinyl chloride waste should preferably be dried before disposal. Wastes arising from vinyl chloride processes should be handled and disposed of in accordance with the Department of Environment Waste Management Paper No 15: 'Halogenaced Organic Wastes - A Technical Memorandum on Arisings, Treatment and Disposal including i a Code of Practice*. AIR MONITORING 37 The objectives of monitoring concentrations of airborne vinyl chloride in working areas are:- (1) to verify thac any technical measures and working procedures maintain adequate control of exposure; (2) to detect abnormal increases in vinyl chloride-in-air levels which may occur as a result of failure or malfunction of some part of the plant or apparatus, with references to the short term alarm levels for vinyl cniocide; (3j to provide adequate records of the exposure of individuals for the purpose of epidemiology. 36 The arrangements for monltorlag require careful planning to achieve effective and efficient use of resources. A formal air monitoring plan should be drawn up and made known to all employees working in areas where vinyl chloride is liable to be present. The plan should contain details of the air monitoring procedures and equipment chat are to be used to meet the objectives sec out in para 37, including details oft- (a) tne parts of plant, working areas and occupational groups of employees to be monitored; (b) the type of air sampling to be carried out, eg personal air sampling, fixed point air sampling; 10 URL 15024 (c) Che frequency of air sampling and Che siting of air sampling equipment; (d) Che types of sampling and analytical equipment co be used; (e) arrangements for Che cescing and calibration of sampling and analytical equlpaenc; (f) Che statistical analysis and presentation of Che air sampling results. The information obtained from Che initial and any subsequent assessments snould be used vhen planning or revising Che details of the monitoring procedures. 39 Static sampling will be the main method used rouciaely for assessing compliance vith the Annual Control Limit and detection of alarm levels in vinyl chloride monomer production and polymerisation plants. In order to assess compliance with the 3 hour TWA Control Limit personal monitoring will be necessary. 40 Static sampling may be either by discontinuous or continuously operating sequential systems, except at vinyl chloride polymerisation plants sited vlthin buildings where only the latter methods should be used. 41 Where discontinuous air sampling techniques are used, the frequency of measurements should be sufficient to predict with a confidence coefficient of at least 952' cnat there is compliance vith the Annual Coatrol Limit, in other words that the Control Limit value falls above the upper 952 confidence limit for the true annual arithmetic mean for the working area. The required frequency vill thus depend upon the variability of concentrations with time. 42 Where vinyl chloride is handled intermittently, monitoring of exposures by personal sampling should be done sufficiently often to ensure that technical control measures and working procedures are adequate to keep exposure below tne Control Limits. 4i Large working areas will normally require mors man one monitoring point and in such cases the average value of the measurements recorded should be considered as the representative value vhen assessing compliance vith the Annual Control Limit. 11 URL 1502 Measuring equipment 44 The sensitivity, range, selectivity and speed of response of an analytical device should be appropriate to the duty it is required to perform. Electrical equipment in flammable atmospheres should be suitably constructed, protected and installed; guidance is available in BS Code of Practice 1003. 45 The follovlng techniques are amoag chose suitable for detection and measurement of vinyl chloride (a) gas chromatography (b) infra-red absorption analysis (c) flame ionisation detection Flame ionisation detection is noc specific for vinyl chloride and may therefore give readings vhich are greater chan the actual concentration, 46 Gas samples may be taken by any technique vhich is recognised and acceptable for the analytical technique to be used* 47 A comprehensive description of the various analytical techniques available for the measurement of vinyl chloride are given in 'The Determination of Vinyl Chloride: A Plane Manual - Analytical rletnods for the Control of Vinyl Chloride Concentrations In and Around Manufacturing and Process Plants' pubiisned by the Chemical Industries Association Limited, Alembic House, 93 Albert Embankmenc, London SEl 7TU Details of one of the personal sampling methods used by USE are available in MDUS 24 - 'Vinyl Chloride in Air: Laboratory method using charcoal abosrbent tubes, solvent desorption and gas chromatography'. Location of sampling points for fixed analysers or automatic sequential fixed point sampling systems 48 Sampling points should be located vlthin tne working area to sample air representative of tnac breached by the vorkers. The probes should normally 12 URL 15026 be sited at breathing height and at local places where the air movement is representative of the general working area and should not impede Che movement of workers, access to or operation of equipment* 49. Other locations for sampling points may also need to be chosea so that any increase in concentration of vinyl chloride arising as a result of leakage or plane malfunction can be deeected as sooq as possible (see para 54). Accuracy and calibration 50 If a measuring system is used which records vinyl cnlorlde and ocner substances without being capable of distinguishing between them, the results obtained should be regarded as representing vinyl chloride only. Special consideration may need eo be given to the interpretation of results where there are indications chat Che Control Limit is being exceeded but Lc is known chat this Is due to other substances. 51 The precision and accuracy of che sampling systems used should be Investigated over che vinyl chloride in air concentration range of 1*30 ppm. An accuracy of 10% within this range is satisfactory. The method used and che results obtained should be recorded. 52 Measuring equipment should be calibrated regularly, io accordance with che agreed air monitoring plan, using the most appropriate technical methods. The calibration of automatic air sampling systems should preferably involve che injection of air samples containing known amounts of vinyl chloride into che system at sampling oolncs, rather chan directly into che analysing instruments. Leak detection 53 Leak detection may be carried out by che following means:* (a) portable analyser; (b) mobile sample line attached to a non-portable analyser; (c) ultra-sonic leak detector. 13 URL 15027 Alarm systems 54 Whatever sampling system 19 used Cor routine monitoring, there should also be a system for the automatic detection of high levels of airborne vinyl chloride in places where these may occur, eg in the event of plant failure. The alarm system may be integrated with a continuously operating or permanent sequential system provided for the purpose of air monitoring. Recording and presentation of results 55 The results of all atmospheric monitoring at fixed points should be available for inspection by personnel wording in areas where vinyl chloride is liable to be present and their representatives at any time during a working period. Where continuously operating multi-point sequential sampling methods are employed, the results should be displayed as far as possible within two hours of the end of each shift sampled. Where discontinuous method and/or personal monitoring ara used, the results should be displayed within 24 nours of completion of the sampling period where possible. 56 In the areas where continuously operating multi-point sequential sampling and analysing equipment is installed, results should be summarised on a shift basis for each identifiable work area showing the average concentration in the area. Basic details or the position and number of sampling points together wltn the frequency of sampling and analytical methods used should be Included at the beginning of the series of records and thereafter need only be recorded when changes occur in the monitoring procedure. 57 In the areas wnere sampling i3 carried out ocher chan on each shift, the individual time weighted average results should be recorded. These should be summarised on a monthly basis shoving the average concentration at each location with an analysis of the distribution of tne individual results. 56 Records of maintenance and monitoring should provide sufficient inform ation to enable employers, self employed persons, persons in control of premises, employees and/or their representatives at tne workplace, and enforcing authorities to:- 14 (a) ascertain whether maintenance or monitoring has been carried out; (b) monitor the performance and effectiveness of control measures; (c) gain access to information on any defects or matters requiring attention and on the remedial action taken; (d) identify exposure trends. 59 The records should contain at least the following informattion:(1) Leakages of vinyl chloride (a) description of area or plane Inspected; (b) date of inspection; (c) time of inspection and shift; (d) statement of any defects or leaks found chat might result in the release of vinyl chloride vapour above the 9 hour TVA. Control Limit or alarm levels; (e) significant uncontrolled or abnormal emissions of vinyl chloride co the atmosphere reported to HKIAPL; (f) indication of action taken following discovery of faults; (gj name, signature and appointment or person making inspection. C2; Examinations of ventilation equipment (a} location and type of plant; (bj date of examination; IS 5 rcv_o> URL 15023 (c) instruments used and results of instrument readings; (d) defects noted; (e) action taken; (f) name, signature and appointment of person making examination. C3) Excursions above the alarm levels as detected during area monitoring (a) part of faceocy to which the record refers; (b) precise location within the factory; (c) dace, time and (where known) duration; (d) maximum time weighted average concentrations recorded; (f) result of investigation; (g) action taken; (h) name signature and appointment of person making inspection. (4) Personal monitoring (a> name of employee; (b) dace; (c) time and duration of exposure; (d) time weighted average concentrations recorded; (e) precise ducy and working area vicnin factory; (f) nature and nominal efficiency of respiratory protective equipment (if worn). 16 The results of personal monitoring should be summarised on a monthly basis by job category in each plant in addition to shift results. 60 If respiratory protective equipment is worn by any personnel during air monitoring exercises, this should be recorded together with the nature and nominal protection factor of the equipment to enable an estimate of ehe 'actual' exposure to be made. 61 Records may be kept in any suitable form, including microfilm* computer or similar techniques, provided chey satisfy the foregoing requirements and can be retrieved readily when required* 62 Recorda of air monitoring should be kept for at least 30 years. In the long term, air monitoring results may be kept in Che form of monthly summaries, but in this case the detailed shift records on which they are based should be kept for at least 1 year. Records of leakages of vinyl chloride and examination of ventilation equipment should be kept for at least 2 years. PERSONAL PROTECTIVE EQUIPiffiNT Respiratory protective equipment 6i Where adequate control of exposure to vinyl chloride cannot be achieved 9 by normal engineering controls and cne provision of further control measures for materials* plant and processes is not reasonably practicable, workers should be provided with adequate and suitable respiratory protective equipment. The term 'adequate' with respect to respiratory protective equipment refers to the ability of the equipment to protect Che wearer; 'suitable' refers to the correct matching of che equipment to the job and to the person. To be considered adequate and suitable, respiratory protective equipment must be correctly selected and used. It should be noted cnat che nominal protection factor of respiratory protective equipment can only be achieved if che face fit of the equipment is very good. In che case of vinyl chloride, this means compressed air line or self-contained breaching apparatus of a cype approved by or conforming to a standard approved by cne Health and Safety Executive. 17 URL 15031 64 In particular, adequate and suitable breathing apparatus muse be vora:- (1) when le Is aat reasonably practicable to remove vinyl chloride vapour by local exhaust veneilacioa, e.g. vhea opeaiag equipment which may release appreciable quantities of vinyl chloride co the atmosphere and during the maintenance or repair of equipment. Ho such operation should be conducted without a permit-to-work issued by a competent person designated by the employer for this purpose. Precautions should be taken co ensure thac ocher unprotected personnel in the vicinity are not liable eo be exposed to concentrations of vinyl chloride above the 8 hour TWa Control limit; (2) during entry into confined spaces which have not been certified by a competent person as being safe for entry without breathing apparatus. 65 Following an alarm, adequate and suitable breaching apparatus should be worn by any person remaining in an affected area until the alarm is over. The source of an escape of vapour should be identified and appropriate corrective action eaken without delay. 66 It is recommended that no person should be required to rely for protection on respiratory protective equipment unless-he has successfully completed a training or refresher course on the use of such equipment within the previous 12 months and has been issued with a certificate co this effect. The training or refresher course could include cne following:- (,a) principles of operation and use of equipment; (b) practical use, correct fleeing, etc; (e) limitations of the equipment; (d) common defects and action required; 18 URL 15032 (*) compact? arrangements for issue, cleaning, malncenance, etc; (f) whea it is to be used. \ 67 A register of authorised personnel trained in the use of respirator? protective equipment should be kept together with a record of each persoafs training. All breaching apparatus should be maintained in a dean state, in good repair and in efficient working order. It should be inspected ever? 14 days and defects identified and remedied immediately. The maintenance schedules should specif? that the compressed air supplied to the wearer of breathing apparatus should contain not more than S ppm carbon monoxide or 500 ppm earbon dioxide or 0.5 mg m~3 oil mist and except for these should be free from contamination b? dust, dirt, metallic particles or an? ocher toxic or irritant substances whatsoever. The maintenance schedules should also include cne source of compressed air, the air line, particularly che connections, and proper cleaning and reissue of equipment. 68 Ho respirator? protective equipment which has been used should be worn again by another person unless it has been thoroughly cleaned and disinfected. 69 Records of maintenance and inspection of respirator? protective equipment should Include Che following information:- (a) name and description of equipment'; (b) person issued to. If on personal Issue; (c) dace of inspection; (d) description of any defect found and action taken; (a) name, signature and appoinemeat of person making inspection. These records should be kept for at least 2 years. Protective clotnlng 70 Under normal circumstances, where vinyl chloride is handled within 19 teosvian enclosed plant, there nay be no need for the wearing of special protective clothing by process workers. However, certain circumstances, such as entry into confined spaces or some maintenance work, may require the use of special protective dothiag. Such situations should be identified as part of the general assessment. The standard of clothing necessary will depend upon the nature of exposure. For example, where substantial body contact can be foreseen a high standard of protective clothing should be provided, eg completely enclosing air-fed suits (where respiratory protective equipment is also necessary) of wire reinforced PVC, or overalls of PVC-proofed material, completed in all cases by PVC gloves and boots. Where an area is relatively free of vinyl chloride, having perhaps been cleaned by means of high pressure noses or other methods, overalls of materials such as terylene or cotton, may be adequate. PERMITS TO WORK 7l A, permic-to-work is essentially a document which secs out the work to be done and the precautions to be taken. It predetermines a safe procedure and is a clear record that all foreseeable hazards have been considered in advance and that all appropriate precautions are defined and taken in correct sequence. It does not, in itself, make the Job safe but is dependent for its effectiveness on the persons concerned conscientiously carrying out the requirements of Che permit. There should be provision on the permit-co-work for the persons authorising the work to sign to this effect and for Che persons carrying out the work to sign the .document at each stage of the operation as it is completed. Permits to work should be issued for all entries into confined spaces and for certain maintenance operations. Copies of all permics-co-work Issued should be kept for a minimum period of 2 years. Confined soaces 72 In ctiis Guidance Note the term 'confined space' includes any chamber, tank, vat, pit, pipe, flue or similar confined space such as, for example, a reactor, duct, or bunker in which vinyl chloride vapour is known to be or is liable to be present. 73 Unless adequate precautions are taken, entry into a confined space involves a particular risk of exposure to very high levels of vinyl chloride or lack of oxygen. Concentrations of vapour may even be such as to involve a 20 URL 15034 risk of persona being overcome '-rich * consequent risk Co life, la addition Co the possible long-term effects of exposure. Plant should be designed and operated so as to reduce to a minimum time spent in vessels and the number of occasions requiring entry. 74 In order to reduce the potential short-cerm and loag-tecm risks, entry into confined spaces should be strictly controlled. A permit-to-work system should be operated and other special precautions taken as outlined in HSE Guidance Mote GS 5 - 'Entry into Confined Spaces' 75 Whenever a person enters a confined speee for any purpose, a lifeline should be worn or, where this Is not practical, some ocher method should be used, Co enable a second person posted outside the confined space to keep in constant contact. The second person should be able eo raise the alarm and equipment and trained personnel should be readily available for rescue purposes. All workers involved in any way with work in confined spaces should be fully trained and conversant with the organisation's agreed emergency procedures. 76 Unless a confined space has been certified in writing by a competent person as being, for a specified period, safe for entry without breaching apparatus and the period has not expired no person should enter or remain in Che confined space for any purpose unless he is wearing suitable breaching apparatus. The permit-to-wock should specify the type and standard of personal protective equipment to be worn and all ocher necessary precautions to be taken. 77 Entry into a confined space without breaching apparatus should not be authorised by a competent person unless (a) effective steps have been taken to prevent the entry of any vinyl chloride vapour or ocher dangerous fume and (b) any sludge or ocher deposit liable to give off vinyl chloride or ocner dangerous fumes has been removed and no ocher material liable to give off dangerous fumes is present and (c) the space has been adequately ventilated, tested for vinyl chloride and ocher dangerous fumes and has a supply of air adequate for respiration. 21 URL 15035 If there is a possibility that the proportion of oxygen In the air of a confined space has been substantially reduced no person should enter or remain in such a space unless he is either wearing suitable breaching apparatus. Alternatively the space should be adequately ventilated and a competent person should test and certify it as safe for entry without breaching apparatus. Maintenance ooeracions 73 When a noa-roucine operation or malfunction may result in the release of vinyl chloride to the atmosphere, adequate and suitable breathing apparatus of type approved by HSE should be worn. Wherever possible special measures should be taken to prevent emissions of vinyl chloride. Such operations should qoC be conducted without permission in the form of a permic-to-vork from a competent person designated by the employer for this purpose. Precautions should be taken to ensure chat other personnel are not exposed to levels of vinyl chloride above the Control Limit. MAINTENANCE OF CONTROL MEASURES 79 All plant, especially that from which vinyl chloride may escape or which' is provided for the purpose of controlling exposure to vinyl chloride, should be maintained to a high standard in order to limit the exposure of workers to vinyl chloride. Maintenance procedures should include regular and thorough examinations by a competent person at appropriate intervals of those pares of tne plant at which leakages of vinyl chloride may develop over a period of time. A suitable instrument giving a direct read-out of the concentration of vinyl chloride-in-air should be used for leak detection during such examinations. All defects found should be remedied promptly and the results of maintenance examinations and details of remedial action taken recorded. dO Regular examinations and tests should be made of ventilation equipment and otner technical control measures by a competent person, using instruments where appropriate, to check the performance of such equipment as part of a planned preventive maintenance programme. Where ventilation plant is provided in pursuance of Regulation 7 of the Control of Substances Hazardous to Health 22 Regulations, maintenance should include a visual check ac lease once a week, eo identify obvious defeccs and a thorough examination and test by a competent person at least once a year. Details of such examinations and tests, defeccs found and remedial action taken should be recorded. EMERGENCY PLANNING 31 A procedure for dealing with a substantial escape of vinyl chloride should be prepared and updated as often as is necessary. The objective is to ensure that all employees who may be affected are trained and practiced in Che arrangements for dealing with such emergencies. The emergency plan should cover (a) the definition of Che type of situation to be considered as an emergency; (b) raising the alarm; (c) evacuation of the immediate area and adjacent areas liable to be affected; (d) control of the occurrence using site resources; (a) plant shut-down and containment o'f vinyl cnlorlde leakage, and (f) obtaining assistance from the emergency services. Tne booklet "Recommended Procedures for dandling Major Emergencies", published by the Chemical Industries Association Ltd*, Alembic House, 93 Albert Embankment, London SE1 7TU, provides useful information and advice on this subject. It should be noted cnat the Control of Industrial Major Accident Hazards Regulations 1934 will apply to some vinyl chloride installations and may require the preparation of on-sice and off-site emergency plans. 32 'Whenever abnormal emissions occur which affect the environment significantly, tne District Inspector of HM Industrial Air Pollution Inspectorate and the local authority must be informed immediately. Production should not be continued with emissions outside the limits allowed without 23 c XI [I o URL 15037 having consulted the District Inspector. Under the Notification of Accidents and Dangerous Occurrences Regulations 1980 the sudden, uncontrolled release of 1 tonne or sore of vinyl chloride, eg, by rupture of a bursting disc, must be notified to the HS immediately. REGISTERED WORKERS 83 In plants subject to the requirements of the Vinyl Chloride ACoP, any worker identified during the assessment procedure required under Regulation 6 of the Control of Substances Hazardous to Health Regulations as likely to be affected by occupational exposure to vinyl chloride should be designated as a 'registered worker*. A register of such workers should be kept by the employer. Any worker generally spending less than 252 of his working year exposed to vinyl chloride need not be designated as a registered worker* Consideration should also be given to designating other persoas working regularly on site, eg contractors' employees, as registered workers where there is the potential for exposure to vinyl chloride on a scale similar to chat for an employer's own employees and che assessment warrants such action. HEALTH SURVEILLANCE 8^ Health surveillance of registered workers is intended to detect, as early as possible, any harmful effects associated with exposure to vinyl chloride at work. The initial assessment considers che individual's fitness to work with vinyl chloride and establishes baseline medical information with regard to registered workers. % 85 Workers should be subject to periodic assessment to check their fitness to continue working with vinyl chloride. The assessment may also provide additional Information which might lead to a fuller understanding of the toxicological effects of vinyl chloride. Such data could also be of value in any future epidemiological studies. Each person should be subject to medical reassessment (.a) at Intervals of not more chan 12 months; 24 URL 15038 (b) if be has reported symptoms which could be actribucable co vinyl chloride exposure; (c) i, la cbe opinion of the appointed doctor, he requires further medical assessment; (d) whan he has been absent from work because of any illness for 4 weeks or oore 86 The medical assessment of each individual is the responsibility of the appointed doctor but it will normally include (a) a full history, both clinical and occupational; (b) a clinical assessment vich particular reference to the abdomen, skin and extremities, and (c) such further tests, including radiological examination and;' laboratory tests, as may be indicated by the results of (a) or (b). 87 The employer should ensure that the leaflet "Vinyl Chloride and You" is given to every worker on commencement of his employment. Copies can be obtained free of charge from any office of the Health and Safety Executive. 88 The employer should also ensure that each employee is aware chat he has the right co request a written record of the results of any health surveillance procedures. If abnormal findings are present the individual may, if he consents, be referred co his Family Practitioner. 89 Where medical examinations need co be carried out adequate facilities should be made available. The facilities snould comprise a room which is properly cleaned, adequately warmed, well ventilated, suitably furnished and provided with a wash basin equipped with hoc and cold running water, soap and a clean towel. If it Is not reasonably practicable to provide hoc and cold running water, a means of heating water should be provided within the room. The room should be suitably quiet and not permit ordinary conversational voices to be heard outside its vails. The room should be set aside for the exclusive purpose of health surveillance whenever it is required. 25 > URL 15039 Where the number of employees co be examined or assessed is substantial, a suitable waiting area should be provided. An adjacent lavatory with hand washing facilities should be provided for employees who say be required to provide specimens for biological testing. 90 Arrangements should be made for any employee who is a registered worker co present himself, during his normal working hours, for medical examinations and any additional tests as may be aecessary.. Employees should cooperate in such examinations and tests. 91 The basic occupational health record of a registered worker's health surveillance should consist of ac least the following information:- surname, forenames, birth surname, sex, dace of birch, place of birth, (town and country), permanent address, National insurance Number, National Health Service Number, dace of commencement of present employment, and a historical record of jobs performed whilst in that employment, with appropriate details to indicate likely exposure. 92 These records may be kept in any suitable form provided thac they satisfy che foregoing requirements and can be retrieved readily when required. They should be kept in a form compatible with and capable of being linked co those for monitoring, so chat it is possible co compare che nature and degree of exposure co vinyl chloride with effects oa`health. The health record of a registered worker should be kept for at least 50 years from che dace of che last entry. 93 Some of che condicions associaced vich exposure co high levels of vinyl chloride, particularly angiosarcoma of che liver and portal hypercensioa due co non-cirrhotic periportal fibrosis, may have prolonged latent periods with symptoms not appearing until several years after exposure, possibly after a vinyl chloride worker has retired or transferred to ocher work. In all cases when a vinyl chloride worker leaves a company, ceases to be a registered worker or transfers co another location, a letter should be sent co his Family Practitioner oy che Appointed Doctor. Appendix 3 contains a suggested leccer for sending to an employee's Family Practitioner and Appendix 4 a suggested form for che employee co give his consent for the Appointed Doctor to discuss his medical and occupational history with regard to his exposure co vinyl 26 URL 15040 chloride with bis Family Practitioner. Both the suggested letter end fora of consenc have been approved by the Ethical Guidance Committee of the General Medical Council. Appointed Doctors are recommended to place copies of any letters and forms of coosenC In the occupational health records of the employees concerned. 94 When an employee ceases to be a registered worker, but continues to work at the same location and for the same employer, the Appointed Doctor shall offer to continue the employees health surveillance programme as in paras 85, 86 and 88. INFORMATION, INSTRUCTION AND TRAINING 95 Employers should ensure that employees receive adequate information, instruction and training, so chat they are aware of the nature of the hazard, the extent of the risks from exposure to vinyl chloride, the precautions to be observed to minimise these risks and Che role of joint consultation. Employers should also ensure chat employees of contractors and ocher persons working in areas involving potential exposure to vinyl chloride have received similar information, instruction and training. The topics covered should include the following la) health hazards of vinyl chloride; (b) contents of the vinyl cniotide ACoP; (c) general methods outlined in this Guidance Note and the leaflet 'Vinyl Chloride and You* for protecting persons from the health hazards of vinyl chloride and the need for health surveillance; (d) correct operation of the plant with which the employee Is concerned; 27 (e) role of the employee in observing safe working methods; (f) correct use of respiratory protective equipment sad any ocher personal protective equipment; (g) significance of monitoring procedures and results; (h) relevant emergency procedures; (i) relevant rules relating to vinyl chloride; (j) procedures for reporting defects in plant and equipment. It should be noted that Regulation 4 of the Control of Industrial Major Accident hazards Regulations 1984 requires a manufacturer to provide evidence chat persons working on a site are informed, trained and equipped as necessary to ensure their safety. 96 Basic information, instruction and training should be provided on recruitment and should be supplemented at regular intervals by training, "on* che-job" refresher courses, calks, notices, leaflets or ocher methods in order to create and sustain a high level of awareness amongst employees. 97 Any person who carries out any assessment, air monitoring or maintenance casks which require the use of instruments should be given additional instruc tion and training concerning their use including (a) objectives of air monitoring; (b) correct use of the instruments; (c) sampling techniques; (d) analysis, interpretation and recording of results. 28 FACILITIES Washing and changing facilities 98 Adequate washing and changing facilities of a high standard should be provided. All the facilities should be leapt dean* warm and in good repair. Washing facilities should include showers for Che use of persons whose skin say be contaminated by vinyl chloride. Changing facilities should be designed to ensure chat dean clochiog and chat which may be contaminated by vinyl chloride are kept separate. Arrangements for eating, drinking and smoking 99 Employees should not eat, drink or smoks in areas liable to be contaminated by vinyl chloride, so suitable facilities for these purposes should be made available. 100 Where a number of employees are involved, suitable facilities for use by persons who remain on the premises during main meal intervals should consist of a canteen, oes3-coom or ocher suitable eating area. This should be provided with suitable tables and chairs and facilities for the storage of food and drink, whether the food and drink is supplied by the employers or the employees. If drinking fountains ara provided they should be installed so as to prevent the water from becoming contaminated. 101 Smoking should not be permitted except in areas set aside for Che purpose because of the fire and explosion risks associated with vinyl chloride. NOTIFICATION TO THE HSE 102 Employers are requested to notify HMFI at ESS Area Offices and HttlAPI at District Offices of proposals for the Installations of new plant or modification of existing plant. Such notifications should be made at Che design stage. Vinyl chloride comes within the group of substances defined In Class 2 of Parc II of Schedule 1 of cne Notification of Installations Handling Hazardous Substances Regulations 1982* The Regulations require initial 29 URL 1504 ro aotificaeion. co HSE of any sice handling quantities of vinyl ehloride la excess of 22 tonnes with reaocificacioa sc three Claes this figure* Vinyl chloride also comes viehin che definition of a flaoaable gas as set oue la Schedule 1 e(i) of che Control of Industrial Major Accident Hazards Regulations 1984. Notification Co HSE is required under Regulation 4 ac SO connes of vinyl chloride and for Regulations 7-12 ac 200 tonnes for process and storage or 300 tonnes for isolated storage. Notification to HSE Is also required of significant modifications to che Industrial activity for inventories exceeding 200 or 300 connes for process and storage or isolated storage respectively. For furcher details, reference should be oade co che appropriate Regulations (see Appendix 6) and associated guidance published by HSE. REC0RES 103 There are a number of references in various sections of this Guidance Note co the keeping of registers and records. For ase of reference ehese requirements are summarised in Appendix 2. 104 Where an employer ceases to operate, it is recommended chat che Health and Safety Executive be notified and che records of air monitoring and employees' occupational health records transferred co HSE. Disc No 250/20-30 BR 30 APPENDIX 1 PROPERTIES OF VINYL CHLORIDE SYNONYMS CHEMICAL FORMULA PROPERTIES General Physical Chemical Boiling Poinc Freezing Poinc Flash Poioc (open cup) Liquid Density Vapour Density Solubility VC, Vinyl Chloride Monomer, 7CM, Moaochloroechyleae, Monochloroeeheae CH2 - CHCl Vinyl Chloride is a colourless gas ac ambient temperature and pressure with a sveecish odour ac high concentrations* lc Is aoroally scored and handled under pressure as a colourless liquid -13 *9eC -153.70C -78C 0.983 Cat 20OC) 2.15 (relative to air at 20C) Readily soluble in most organic solvents but only sparingly in water Vinyl chloride will polymerise exothermically under the influence of light, air, oxygen and initiators such as benzoyl peroxide. Pure vinyl chloride is thermally stable to quite high temperatures, however, peroxides formed by slow reaction with oxygen in air may initiate polymerisation. Stablisers, such as beazoquinone or p-methoxyphenol, and storage in an oxygen free acmosphere innlbic adventitious polymerisation URL 15044 1 APPENDIX 3 Dear Doctor CONTROL OF SUBSTANCES HAZARDOUS TO HEALTH REGULATIONS 198APPROVED CODE OF PRACTICE FOR THE CONTROL OF VINYL CHLORIDE AT WORK Mr/Mrs/Miss ................................. ................................................ .. Dace of Birth ........................................................... Address ......................................................................................................................................... is abouc co Leave/has Just left employment here where he/she was registered as a worker potentially or actually exposed to vinyl chloride monomer (VCM). Exposure co high levels of VCM has been associated with angiosarcoma fibrosis of che liver, portal hyperteasioa due to non-cirrhocic periporcal/3tad acro-osceolysis particularly of che terminal phalanges of the hands. Other effects have been reported as occurring in workers chronically exposed co vinyl chloride monomer at similar levels of exposure, although such reports have been disputed by others. These include tumours of the brain, lung, haeao-lymphopoietic system, and skin (malignant melanoma), lung function disorders, thrombocycopoenia and immune complex disorders. Effects oa reproduction have also been reported. Whilst exposure co such levels is unlikely co have been incurred since 1973, che latent period particularly cor che first two above mentioned conditions may be prolonged. May I cnerefore suggest cnac this letter which (together with che patients form of consent) has been approved by the General Medical swsnan Council, be filed in your patient's NHS record card. Should any clinical suspicions along these lines arise in the future you sight like to coasider coatacting me or my successor. I hold, and enclose a copy of, your patient's signed informed consent to this which means that you need not hesitate from taking such a step early in your considerations of differential diagnosis from fear of groundlessly alarming your patient. Should this factory have ceased trading, the Employment Medical Adviser for your area, who can be found in Che telephone book under Health and Safety Executive would know the whereabouts of your patient's factory medical and exposure records which are being preserved for 50 years from Che end of his/her employment here. If you would like any further Information or explanations, please do not hesitate to contact me now or in Che future. I will be glad to assist in any way possible la the interests of your patient's, our ex employee's, well-being. Yours sincerely, APPOINTED DOCTOR APPENDIX 4 CONTROL OF SUBSTANCES HAZARDOUS TO HEALTH REGULATIONS 198APPROVED CODE OF PRACTICE FOR THE CONTROL OF VINYL CHLORIDE AT KOBE MEDICAL SURVEILLANCE URL 1 --047 (Give surname and full forenames, give dace of birch chus eg 3 SEPT 36 I, ............................................................................................ .. born of .............................................................................................................. ...................................................................................................................... hereby give consent for Che Appointed Doctor or the Area Employment Medical Adviser to discuss with my family doctor my medical and occupacional history and I also consent Co the release to my family doctor of such records insofar as they relace to my exposure co Vinyl Chloride MoQomer. I confirm chac Dr ......... ........................................................... Appointed Doctor has explained co me the reasons for this consent being sought and I believe chac I have understood these reasons. I agree to a copy-of this consent and explanatory letter, vnlcn 1 nave seen, being sent to my present family doctor, Dr ..................................... ............................. .. Of ................................................................................................................................................. .... Signed Dace .. fitness APPENDIX 5 RECORDS The records which should be kept la relatioa to Che control of vinyl chloride sc work are summarised below with cross references to the relevant paragraphs of che oiain text of the Guidance Note. (a) Assessment (paras 22-29); (b) Atmospheric monitoring (paras 55--57>; (c) Maintenance or monitoring equimenc (para S3) (d) Leakages of vinyl chloride (para 59(1); (e) Examinations of ventilation equipment (para 59(2)); (f) Excursions above the alarm levels during araa monitoring (para 59(3)); (g) Personal monitoring (para 39(4)); (h) Names of persons trained and autnorlsed to use respiratory protective equipment (para 66); (1) Inspections of respiratory protective equipment (para 69); (j) Peraits-to-work (paras 71 and 77); (k) Maintenance of eoncrol measures (paras 79 and 30); (l) Register of registered workers' (para 33) (a) Occupational health records of regisceretf workers (paras 91 and 92). Records may be kept in any suitable forms, Including microfilm, computer or similar techniques, provided cney can be reviewed reaaily when required. Occupational health records should be kept for 50 years afcer Che last entry made in them; Records of atmospheric monitoring should be kept for at least 30 years. All other records should be kept for a miniaum of 2 years. URL 15048 APPENDIX 7 CHECKLIST OF MAIN COTOOL MEASURES CONTROL MEASURES FOR MATERIALS, PLANT k PROCESSES (Paras 30-36) CONTROL OF EXPOSURE (Faras 19-20) AIR MONITORING (Paras 37-62) ALARM LEVELS (Faxa 21) FERMITS-TO-VCRK (Faras 71-78) RESPIRATORY PROTECTIVE EQUIPMENT (Faras 63-69) MAINTENANCE OF CONTROL MEASURES (Faras 79-50) - Plant should be designed and operated to minimise exposure to vinyl chloride - Plant should be sited in the open wherever possible - Good general ventilation should be provided In process buildings - Local exhaust ventilation should be provided where emissions from plant nay occur that cannot be eliminated by improved design and maintenance - Personal exposure to vinyl chloride should be controlled to below 7 ppm 8 hour TVA - Vinyl chloride In the air of working areas should be controlled to below 3 Ppm averaged over a year - Fersonal a^nitoring is required to check compliance with the 8 hour TVA Control Limit - A static monitoring system is required for the mcnitcring of vinyl chloride in the air of working areas - Air monitoring system required for the detection of-high levels of vinyl chlori and to sound an alarm at the following levels) 15 ppm measured over 1 hour *20 ppm measured over 20 minutes 30 ppm measured over 2 minutes - Fermits-to-work required for all work in confined spaces and some maintenance - All personnel involved must be properly trained - Required for certain operations, eg entry into confined spaces, maintenance, dealing with leaks of vinyl chloride, emergencies, etc - Only equipment of a type approved or to a standard approved by H3E to be used - To be used only by trained and authorise personnel - Regular and thorough examinations of plant required, especially where leaks may occur - Regular examinations and tests of ventialtion equipment required - Regular checks of other control measures to be carried out fiw s i fan APPENDIX 6 LEGAL REQUIREMENTS Sooe additional legal requirements relevant eo che handling of vinyl chloride nay be found in che following The Health and SafeCy aC Work etc Ace 1974 The Factories Ace 1961 The Alkali etc Works Regulation Ace 1906 The Emissions into che Atmosphere Regulations 1983 The Conerol of Pollueion Ace 1974 The Conerol of Subseances Hazardous co Health Regulations 198_ The Notification of Inseallaeioas Handling Hazardous Substances Regulations 1982 The Conerol of Industrial Major Accident Hazards Regulacions 1984 The Dangerous Subseances (Conveyance by Road in Road Tankers and Taak Containers) Regulations 1981 The Dangerous Substances (Conveyance by Road in Packages etc.) Regulations 198-- The Classification, Packaging and Labelling of Dangerous Substances Regulations 1984 The Notification of Accidents and Dangerous Occurrences Regulations 1980 The Reporting of Accidents and Dangerous Incidents Regulacions 198- URL 150' EMERGENCY PLANNING (Faras 81-82) health surveillance (Paras 34-54) INFOH?!ATION, INSTRUCTION (Paras 95-97) TRAINING - Suitable plans required to deal with foreseeable emergencies - All employees should be familiar with relevant emergency procedures - Registered workers should undergo regular medical examinations - All employees should receive adequate information, instruction and training on the hazards of vinyl chloride, the precautions to be observed and the role of Joint consultation c XI cn ot-n