Document e5B2GgGwkZgXrkZZ47Ox9XzNE

industries Messrs. D. B. Dailey/A. C. Ellsworth A. G. DeMarco/K. W. Richardson I. C. Klimas/L. W. Pi ester G. J. Lambillotte/J. W. Moore A. T. Raetzsch/T. G. Taylor 'in: INTER OFFICE CORRESPONDENCE October 16, 1974 From: J. A. Clapperton Location: 19 East subject: Revised VCM Work Practice Guideline Attached for your review cind comment is the revised Vinyl Chloride Work Practice Guideline. The changes made reflect those in the permanent standard published in the Federal Register of October 4, 1974. This Guideline does not incorporate the exact language but rather the intent of the OSHA standard. Also attached to assist you is a listing of the changes made since the original Guideline was prepared on July 25, 1974. ^Pleaie_jiave_..the appmoia_t_QQple review the Guideline and prepare comments to be returned to me no later thaiV. October 28, 1974. V P J. A ./(Clapperton /mal Attachment cc: W. R. Harris H. C. Twiehaus/F. C. Dehn/Z. G. Bell R. E. Widing G. M. Zapp L. B. Grant, M.D. W. B. Graybill/L. F. Sargert J. F. Knott 'U J /w / 7 ./ A AC, SL 091576 INDUSTRIES To-. Messrs. R. E. Widing J. A. Clapperton INTER-OFFICE CORRESPONDENCE Date. October 10, 1974 From: Zeb G. Bell, Jr. Location: 19 East subject: Revision of VCM Work Practice Guide!ine As you know, OSHA published its permanent standard on VCM in the October 4, 1974, Federal Register. As a result of that standard, I have revised our Work Practice Guideline for VCM dated July 25, 1974, which was submitted to the plants on July 26, 1974, for implementation. The plants should promptly review this revision and submit their comments to Mr. Clapperton and myself. The changes are not major and this Guideline is prepared to meet the intent of the OSHA standard and not the exact wording. To assist in the plants' review, the following changes, additions or deletions have been made in our July 25, 1974, VCM Guideline. III. Oefinitions a) "Regulated area" means an area where vinyl chloride concentrations are in excess of the permissible exposure limit. (Revised) h) "Hazardous operation" is an operation, procedure or activity where flfcplte chloride liquid or gas might,be expected as a because of an accident in the operation which would resulfTn an employee ex posure in excess of the permissible exposure limit. (Added) IV. Environmental (Workplace Air) a) Concentrations The following levels of exposure shall be met and shall be effective: (Revised) Table I Limits of Exposure for VCM in Monomer Plants Effective Date TWA, ppm Ceiling, ppm* Immediately January 1, 1975 10 25 5 (Revised) ^determined by 15 minute sample (Revised) 1F V rt I 'O SL 091577 Messrs. Widing and Clapperton October 10, 1974 Page 2 V. Medical c) The following recommendations are directed primarily at medical screening to detect liver, spleen or kidney disease and/or dysfunction of these organs. They should be considered in the context of . . . (Revised) d) 1) At time of initial employment, or ... to detecting enlargement of liver, spleen or kidneys by abdominal palpation. Abnormalities in skin suggestive of potential tumors, connective tissue and pulmonary systems should be noted. (Revised) d) 2) Complete medical checklists shall be reviewed by a licensed physician and should be . . . (Revised) d) 3) Additional tests . . . 1967, or under the supervision of a licensed physician. (Revised) d) 8) A statement of each employee's suitability for continued exposure to vinyl chloride, including use of protective equipment and respirators, shall be obtained from the examining physician promptly after any examina tion. A copy of the physician's statement shall be provided each employee and his supervisor. (Added) q) These medical records shall be maintained for the duration of the worker's employment plus twenty (20) years or for thirty (30) years, whichever is longer. (Revised) VI. Labeling and Posting a) 2) Areas where hazardous operations are performed or where an emergency currently exists shall be posted with legible signs bearing the following: CANCER-SUSPECT AGENT IN THIS AREA. PROTECTIVE EQUIPMENT REQUiftfift AUTHORIZED PERSONNEL ONLY (Added) VII. Personal Protective Equipment and Clothing a) 3) Vessel Cleaning, Draining, Charging or Maintenance [Insert 25 ppm where 50 ppm appears.] a) 4) E. Employees who monitor the workplace air shall have available appropriate respiratory protection in the event of leaks in equipment. These employees shall wear the respiratory protection when levels being measured exceed the permissible limit. (Added) SL 091578 Mev.r.. Willing mid C1 a |) | jo r Lon October 10, 1974 Page 3 VII. b) Clothing 2) For vessel cleaning, maintenance and changing charges, protective clothing shall be worn to prevent skin contact with liquid vinyl chloride monomer or other materials containing vinyl chloride monomer. (Revised) IX. Work Practices f) 2) [Insert 25 ppm where 50 ppm appears.] XI. Monitoring and Record-Keeping Requirements a) 1) a) 2) B. b) 1) [Change twenty (20) years to thirty (30) years.] (Revised) [" " "" "] [" " "" "] b) 3) Within ten (10) working days following monitoring that discloses that any employee has been exposed, each such employee shall be notified in writi of the results of the exposure measurement. An evaluation of the incident shall be made and corrective action outlined. (Added) XII. Disciplinary Action A formal disciplinary action procedure shall be a part of the employee orientation on vinyl chloride monomer and periodically instructed there after. (Revised) Our Work Practice Guideline does not incorporate the exact wording of the permanent OSHA standard for VCM. From the Industrial Hygiene standpoint, we have built in the general intent of the standard without the specific language. As an industrial hygienist, I have rejected certain requirements. For example: I have deleted the pharse, "without regard to the use of respirators in excess of the permissible exposure limit," since this is not germane. It appears that this phrase has been placed in the standard to pressure industry to make engineering changes to attain the permissible limit. However, this requirement could be applied to main tenance work and tank car loading where engineering changes have been incorporated, etc. In my opinion, our Work Practice Guideline properly addresses itself to the protec tion of the workers' health and is both responsible and progressive. Zeb G. Bell, Jr. ZGB:mal SL 091579