Document eDqdzx5vr3qw8b0Z3Xd36Lg4

DOW CHEMICAL U.S.A. PITTSBURG, Cfl October 27, 1987 Don Kruelski Building 801 Louisiana Division cc: Joe Althouse, 2,3 Fenta Scott Anderson, Environmental Dale Backlund, Spec. Chem. Kurt Detrick, Midland Randy Fischback, Starane Janice Gatlin, Research John Gray, Midland Paul Hannan, Environmental Jim Keith, Midland Jerry Kovacich, Verdict Trifluoro Bill Ledford, Louisiana Division Mike Nevlll, Louisiana Division Jim St. Qnge, Sym-Tet Helen Tobol, Industrial Hygiene Mark Van Dort, Research RE: REMOTE TSCA 5(E) REGULATED CHEMICAL DISPOSAL The attached information is intended to provide you the necessary documentation to instruct your employees and contractors as to the potential hazards associated with handling the TSCA 5(E) regulated materials shipped to you from Western Division for disposal by incineration. We ship waste to you in bulk quantities and in green plastic drums labelled FMN Type 172. These procedures apply to both disposal operations. I am still developing this indoctrination package, therefore, we can expect modifications as we proceed to use this system. It is important that each person having potential for exposure to these compounds be fully indoctrinated. I stress that this information needs to be communicated in a formal safety meeting. The warning statements must be presented both orally and in written form. Each person indoctrinated is required to sign the attendance form, a copy of which has to be kept in your local files for a minimum period of 5 years. A copy should also be forwarded to me. Some of the TSCA 5(E) orders require we give a copy of the warning statement and a list of the required protective equipment to each individual indoctrinated. To sinplify matters, I am requesting all of the written warnings be given to your workers. In addition, I have chosen the most stringent protective gear list as the official gear to wear during cleanup of leaks and spills. If any spill occurs in a poorly ventilated area, vapor emissions must be captured and vented away from the work area. Our drummed materials have been solidified leaving little opportunity for vapors to exist, however, you may need to give special attention to the bulk shipments. The "Tracking" document with which you are already familiar still needs to be conpleted and returned to us at Western, you are further required to keep written records containing at minimum the following: AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY RESTRICTED FOR USE within THE DOW CHEMICAL COMPANY =Qualitv= PcrfOTIVISnCC Means More At Dow DO 073725 CONFIDENTIAL Remote TSCA 5(E) Regulated Chemical Disposal October 22, 1987 Page 2 1. The names of persons indoctrinated, the means by which th y wer informed, the accompanying dates and information provided. 2. The dates and descriptions of leaks and spills involving the 5(E) regulated materials including the names and dates of persons directly involved in cleanup. 3. Any names used to identify these regulated materials and the accompanying dates of use (since you will likely handle mixtures of these substances, I strongly suggest you simply refer to them generically as "PMN Chemicals") These indoctrination procedures, if strictly adhered to, will substan tially meet these requirements. You should be aware that some of the information in this indoctrination package is considered Dow Confidential Business Information and should be treated as such, especially where contractors or other non-Dow workers may be involved. You should make sure that any non-Dow workers have current secrecy agreements with Dow. Please note these records are subject to inspection by both Dow and the EPA. You should immediately begin indoctrinating your workers having potential for exposure to these materials. If you have any questions or sugges tions, please direct them to me. My telephone number Is (415) 432-5650. Ollie Cotton Western Division TSCA Coordinator /eo Attachment DO 073776 OONFIDFNTTAL INSTRUCTION 1. Present orally and visually all information contained on the overhead slides. 2. Discuss as much of the data on the T.I.M.E. sheets as you feel necessary to properly convey a clear understanding of the nature of these chemicals. 3. Provide each person indoctrinated with a written copy of the Protective Gear and EPA warning statements. (I included several of each for your use.) 4. Be sure all sign the safety meeting attendance record, keep a copy in your files and send a copy to me. NOTE: Transparencies provided only for those actively involved in providing indoctrination. DO 073727 CONFTDFNTT Al Western Division TSCA 5 (e) Regulated Compound Disposal Remote Indoctrination Western Division manufactures several compounds that are regulated under the Toxic Substances Control Act, many of these have very specific operating conditions expressed as mandates in 5 (e) Enforcement Orders. In a general way, these orders require that training and indoctrination be provided all persons who have potential to be exposed to these materials. Those of you who are involved in the disposal of waste materials containing these substances may have potential for exposure in the event of a leak or spill, in which case, the clean up procedures expressed in the specific orders must be initiated and the workers involved must have been warned as to the perceived health concerns related to these 5 (e) regulated chemicals. In addition there are very specific wearing apparel and breathing apparatus which must be donned to effect any clean up of leaks and spills associated with these TSCA 5 (e) regulated materials. DO 0737P8 CONFIDENT TA( WESTERN DIVISION TSCA 5 (e) Regulated Chemicals: PMN 83-237 - 2,3-dichloro-5-trifluoromethyl pyridine PMN 83-1162 - 2,6-dichloro-3-trichloromethyl pyridine PMN 83-1163 - 2,3,6-trichloropyridine PMN 84-1219 - 2,3-difluoro-5-trifluoroinethyl pyridine PMN 85-236 - 3 -chloro- 2 -fluoro- 5-trifluoromethyl pyridine PMN 85-36 2,3-dichloro-5-chlorodifluoromethyl pyridine PMN 85-706 - 2,3,6-trichloro- 5 -trichloromethyl pyridine PMN 86-838 - 4-amino-3,5-dichloro-2,6-difluoro pyridine PMN 85-535 - 2,3,5-trichloro-4,6-difluoro pyridine PMN 85-536 - 3,4,5-trichloro-2,6-diflouro pyridine PMN 85-216 - 3,5-dichloro-2,4,6-trifluoro pyridine DO 073729 CONF JDFNTTA1 The EPA has concerns that exposure to these materials may cause health problems leading to cancer, or damage to the liver, kidnev or central nervous :svstem. In view of this, vou are reauired to successfullv complete a respirator fit test and keep documentation. For clean un. vou are reauired to wear; 1) organic vapor respirator cartridge 2) impervious suit 3) impervious gloves 4) impervious boots 5) face shield; and 6) chemical goggles (or equivalent eye protection as part of a respirator or face shield). Any protective equipment designated "impervious" has been determined by the Company to be impervious to the PMN substance under the conditions of exposure, including the duration of exposure. The Company has made this determination either by direct testing, evaluating the specifications supplied by the manufacturer of the protective equipment, or by evaluating data from equipment tested with structurally analogous substances. Testing or evaluation of specifications included consideration of permeability, penetration, and potential chemical and mechanical degradation by the PMN substance and associated chemical substances. DO 073730 CONFIDENTIAL