Document e7p3oBopqbGX5GNwX6MQ8DLXy

(2/ 06T 13 1977j October 6* 1977 Hr, Hal Hollister* Director Division of Operational and Environmental Safety U,, S. Energy Research h Development Administration Washington* D. C. 2C545 \jt ^ ( )w*sLi a%-r i ----------- -T^tX Dear fir. Hoi lister: Draft Criteria Tor Occupational Exposure ^ vTo Vinyl Conc-ounds In accordance with your memorandum of September 8, 1977, the following com ments resulted fro cur review of the proposed standard for occupational exposure to vinyl compounds. The proposed standard is applicable to seven compounds* 1*e., vinyl chloride, vinylIdene chloride* 1,2-dichlcroethylens, vinyl fcrcinlds. vinyl fluoride, vinylIdcne fluoride and vinyl acetate. We have noted that only ylr.yl acetate has boon used on an intermittent basis at this location and, tncreTcre, nave no experience In the monltorlng/surveillance asprgt of vinyl compounds. A brief review of tne proposed standard, however, requires special comment be cause of a number of Inconsistencies tiat wou4 invalidate the proposed standard* 1) Section 1910*1003 of the OSHA Standards has already promulgated an emergency standard for vinyl chloride with environmental concentration not to exceed 1 ppm. The proposed standard of 0,1 (.04 orm soulvalentl Is a reduction oy a factor of 25 and biological or epideml^logical evidence was not cited In the document to merit this chance. The only epidemiological evidence ctterf.ffrprevlou& vtnyl chloride, literature tas the confirmed angle- .. sarcco*. caser associatedta workers .Involved^ frr reactor- vessel cleaning- at - alleged^ vaporr concentrations exposures; of approxleateTy 5CGO ppaJ The writer at this time cuestfcns a sampling ptsnp that vdll sample enough air to n*- flect a calling concentration of Q.t-ing/K^ In a 15 g-lnute period* RSV 0011232 Mr. Hal Hollister -Z October 6* 1977 2) A similar situation exists for vlnylldene chlorlae tr. It: t;r--xsed reduction fra 10 r>r*i to a proposed .25 prm where a celling raeasureoent during a lb sainute period is STJ5C1IioTT; also for 1,2-dlchloroethylene where a 40 time decrease In concentration Is proposed. In either case, carcinogenic potentials at the existing standards have not been noted. Picas note Section 4, Itenv 6, Tines 410 through 413 that cites chemical cartridges or cannlsters not be worn by eaplcyes exposed to vinyl chloride or vinylIdens chloride even for evacuation or escape because of the poor warning properties of theso compounds. Yet lines 436 through 433 under respirator selection* recosirends gas mask with full face piece or bsekmeunted organic vapor cannlster etc. for ex posures to less than or egual to 64 This Is contradictory. 4) Mote further lines 611 through 617 where half masks are satisfactory for use In concentrations less than or enual to 17,500 ng/M^. At these concentrations, Irrltatlon/damage to the eyes and the use of a half mask appears inconsistent with accepted Industrial hygiene practice. With the noted deficiencies. It can only be concluded that the docursent lacks credibility and should fco returned to filGSH for modification and re-writing. If additional Information Is needed, please advise. Very truly yours, AGBrar ,-j. o. ETT A* G. Barnett Manager, Safety and Environmental Technology cct Mr* 3. A* Chacon (3) bet 3.WMK-St.:EoirisfcVV> - If:'-E.-HWfmBrre-1-`-'TJ-= -- TV. 1C. Kozuszek. HV. A. PartTow-St. Louis r.i DD'AjriMi.xT or r.Di.x.vnpx AND V.'I.hrAIU x. J It. IJi.M.llJ M UVit.I. tor. I'mIA'I. uiMkiu. d- TO 'Assistant Secretr.r/ of Leber uaf/: .Y.AR 1 i 1374 Occupational Gef-usy nnd Health Administration l>cpnrr*v.nt of I^.hor niOM : Director, National Institute for Occupational Safety and Health SlJCjtCT: P.ccnwr.cnicd Occupational Health Standard fox the JIanutacturo of Syrlhnzic Polymer frea Vinyl Chlcride On January 22, 1374, representatives from the S', F. Goodrich Chemical 'Company informed HICSH that the deaths of several employees of their Louisville, Kentucky, plane ni^ht have been related to occupational exposures. An i-mrodicte industrial hygiene uaik-rhrough survey t>f the facility vas conducted by >tIOSH 3nd resulted in. developing and transmit ting to effected companies recc--sr.datior.s for precautionary ronizoring and control procedures for rolymerication processes involving vinyl chloride. On February 1, 1974, KICSbYCGC conducted a briefing for ,, other Federal agencies vith health reresrch rcpr-onsibilities at which it vos disclosed that four employees of the plant in question had died of angiosarcoma of the liver. Because of the extremely lev incidence of this disease, estimated to be on the order of 20 to 20 deaths per year in the Hr.itad States, the history of four cnees in a iivc-ycar period in one plant uss considered of'great importance. It \?nc .concluded at the briefing that a nev occupational cancer had been discovered: angiosarcoma of the liver. It vas further concluded that this disease was astneiuted with the rvanut suture of polyvinyl chlcxicc end that vinyl chloride was the prime etiological candidate in producing the disease. KIOSHj with the assistance of expert consultants from both industry ... and organised labor, began development of a rcccmcnded occupational ' health standard. These and other activities were discussed in more detail at the OF HA Informal Fact-Finding Hearing on Possible Hazards of Vinyl Chloride >iaru*.iaccurc end Use cm Vchrunry 15, 197m. It was also during this hearing that Professor Cor. arc Mslconi of bolojtnn, Italy, presented the preliminary results cf his research vrhich showed induction of angiosarcoma of the liver and other organs, as v/cll as .the production of other cancers in rats exposed to vinyl chloride. The results of these studies identify vinyl chloride as a carcinogen end further confirm its role in inducing the cancers observed in the B. F. Goodrich workers. 4* RSV 0011234 X'a;;c 2 - Aur; li;Lant Secretary-of Labor, OSHA Since the OHllA hearing, J.'IOSil has learned of nt least five additional ca?;cs of angiosarcoma of the liver. Two of Lh'.'ft: cart!; were Ulcr/nonud in the current working population at the cer.c Louisville facility, while the other three involved deceased workers* on? each from the Louisville facility. Union Carbide's South Charlestown plant, and Goodyear's Niagara plant. Although vinyl chloride must be considered as a carcinogenic agent, the immediate problcn appeared to be concentrated in polymerisation facilities. Consequently, the attached J'lOSJi roccrrrer.ucd standard only applies to such operations. This is not to say, however, that appropriate standards should nor be developed for other closures to the basic chemical. UiCSll is ir.plcff.entJ.sig further evaluation of the data, coupled with field observations, to determine exposure potentials in pro- and past-polymcrirmtien operations. You will be informed as further data aud plans arc developed. As previously indicated, J:I0S?. considers this to be a "cost serious problem end strongly urges that expedited rulemaking be implemented by OSUA to insure that the health of exposed workers is promptly and adequately safeguarded. Ve feel that, exccnt where employers experience pr obi eras in obtaining air supplied respirntors or environmental monitoring equipment,' the attached recommendations can be implemented as soon as a standard is promulgated. The medical sun'cillancc requirements which will be supplied in one to two weeks could also be implemented immediately with the possibility that sots employers \:ould need a short period of time for their medical staff or consultants to make arrangements for any special laboratory tests. You should be aware that thu consultants from industry vho worked with us proposed Lhat the recommended standard contain the concept of an allowable ''working level*1 for- vinyl chloride gas in the atmosphere, which they identified as a tint weighted average of 50 ppn, They recommenced that where workers were exposed to concentrations in excess of this level they should wear air-supplied respirators. Tills concept of an allowable "working level" might seer, justifiable in that I'rofcssor Mnltcni found no liver tur.ors at 50 ppn, but there is the possibility that tumors eight have been produced if a larger number of animals had been exposed at that concentration! Based on theoretical considerations, there is probably no threshold for carcinogenesis although it is possible that with very low Concentrations the latency period right be extended beyond the life expectancy. 4,In view of these considerations and our inability to describe a safe exposure level as required in section 20(a)(3) of the Cccvipationnl Safety and health Act, \:e rejected the. concept of a threshold limit for vinyl chloride gas in the atmosphere. * . RSV 0011235 Page 3 - Ascicrcnt Secretary of Labor, OZIVi .Consequently. our rcccmcndaticnc cs contained in the attached document ore suc'i thee vhcrc any employee is exposed to measurable concentrations of vinyl chloride, ec determined by the recor--ended sampling end analytical method, he shall veer an air supplied respirator. This rccemendation is based on cccc preliminary information that the standard chemical cartridge respirators are inefficient in protecting against vinyl chlcri.de. \I05il is implementing a study to evaluate the degree of protection afforded by t different types of respirators using vinyl chlorine as the test gas. As information becomes available, it vi.il he fervarded to OSUA as recom mendations for alternative respirator usage. Tee employer is also required to develop a Control Plan to reduce airborne ccsteatrsticns of vinyl chloride to levels not detectable by the recommended method. A? you vill note in reviewing the recommended standard, there arc references to the "sampling and analytical method recommended by the Director." This method, in the form of a. compliance sampling data sheet, trill be forvarded to C-SI-IA vithin s week. T?e now estimate that the level of sensitivity of our recc-mrcnded method vill be around one part per ttillion, specifically for vinyl chloride. The Office of Research and Standards Development, vhich is directed by .Hr* Vernon E. Rose, has had lead responsibility in developing this recommended standard. As your professional staff revievaad evaluate our document, questions or requests for additional information should be directed to Mr. Rose. Attachment 'llsrcus H. Key, II.H'{j Assistant Surgeon General RSV 00L1236