Document g2o7kmj2RbDaNbVwrgNaBX4oJ

,,,t,,, ,' ' :' M: j SOUTH CHARLESTON PLANT UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS P. O. BOX 8004. SOUTH CHARLESTON, W.VA. 25303 July 5, 1974 Mr* Julius Jimeno Hearing Management Officer Docket OSH-36 Room 200 Occupational Safety and Health Administration United States Department of Labor 1226 M Street, N. W. Washington, D. C. 20210 Dear Mr. Jimeno: Attached are three copies of an additional be attached to the TESTIMONY OF RICHARD J. HUGHES Vice1 President of Union Carbide Corporation Before Department of Labor Occupational Safety and Health Administration Vinyl Chloride Occupational Exposure Standard Very truly yours RNWJr/ra Attachments R, N. Wheeler, Jr, UCC 092711 APPENDIX TO TESTIMONY TO RICHARD J. HUGHES VICE PRESIDENT. UNION CARBIDE CORPORATION PROPOSED STANDARD 1910. 93q VINYL CHLORIDE LEVEL OF EXPOSURE - METHOD OF ANALYSIS PROPOSED STANDARD 1910. 93q VINYL CHLORIDE (m) TRANSPORTATION LOADING AND UNLOADING VINYL CHLORIDE MONOMER THRESHOLD ODOR CONCENTRATION IN AIR VINYL CHLORIDE RESIN OPERATIONS UNION CARBIDE CORPORATION JOB CLASSIFICATIONS AND EXPOSURE MONITORING UCC 092712 PROPOSED STANDARD 1910.93a VINYL CHLORIDE LEVEL OF EXPOSURE - METHOD OF ANALYSIS C The proposed standard for employee exposure is set at no-detectable level, as determined by a sampling and analytical method capable of detecting vinyl chloride at concentrations of 1 ppm with an accuracy of 1 ppm t 50%. This specification has been loosely interpreted as permitting exposure levels up to 1 ppm. The specification on the method of analysis and the interpretation of the permissible level of exposure resulting therefrom are imprecise. Incorporation of this specification into the permanent standard would result in confusion and ultimately endless litigation on the meaning of the results. A more precise specification of the method of analysis would be as follows: The proposed standard for employee exposure is set at nodetectable level as determined by a method capable of detecting 1 ppm with a reproducibility of t 0. 5 ppm at the 95% confidence level as defined by ASTM Standard, E 180-67. Even with the more precise specification of the method of analysis proposed, the results of single samples could vary considerably from the desired results. Assuming no errors in sampling, the employer would have to control the absolute concentration of vinyl chloride in the work space air at less than UCC 092713 2. 0. 3 ppm to run no risk of an OSHA citation for non-compliance. From the enforcement standpoint, the work space air could have es much as 3 ppm or more before there would be no risk of not getting a non-compliance citation. To reduce the 0. 3 to 3.0 ppm range of questionable compliance, the only alternatives are to specify a more precise method of analysis or to analyze more than one sample for each determination. For more details concerning the variability of the method of analysis and itB specification, see the attached letters. If the Department of Labor clearly intends to enforce the nodetectable level, they are misleading industry when they infer in testimony that this is roughly 1 ppm. Similarly, if they intend to limit employee vinyl chloride exposure to 1 ppm, then this should be made plain and the method of analysis chosen to suit the situation. RNWheelerJr/ra July 5, 1974 UCC 092714 INTERNAL CORRESPONDENCE 4EMICALS AND PLASTICS P. 0. BOX 8361, SOUTH CHARLESTON, WEST VIRGINIA 25303 Mr. K. IN. Wheeler Jon South Charleston, Bldg. 189 D.** Origln*ting D*pi. to Mr. R. L. Anderson, 511 Sutytct Mr. T. W. Carmody, NYO-31 Mr. R. E. Graebert, 511 Mr. H. R. Guest, 511 Mr. C. D. Hendrix, 511 Mr. A. W. Lutz, NYO-28 Dr. A. B. Steele, NYO-28 Mr. R. W. Wesson, NYO-32 Mr. J. W. Whittlesey, NYO-46 Dr. N. L. Zutty, NYO-32 June 3, 1974 Research and Development Proposed Standard for Exposure to Vinyl Chloride Dear Mr, Wheeler: In accordance with your telephone request of May 28, I have reviewed the wording of the proposed permanent OSHA standard for vinyl chloride with respect to the statement of background information quoted below* A. Level of exposure. The proposed standard for employee exposure is set at no detectable level, as determined by a sampling and analytical method capable of detecting vinyl chloride at concentrations of I ppm with an accu racy of I ppm 50 percent. It is the consensus of Messrs. Robert L. Anderson, Charles D. Hendrix and myself that the statement as written above leads to varied interpretations with little chance of resolving the differences in viewpoint. It could be argued that an analyds of 1.5 ppm or less would show compli ance. It could also be argued that an analysis of 0.5 ppm or more would show lack of compliance. There are two main reasons for diverging interpretations. One is that the description of the method to be used is not precise. The other is that the statement of I ppm 50% refers to the method, not the permissible limit. A permissible limit of "none detectable", is virtually undefinable, even when coupled with a definition of the method to be used. UCC 092715 -2 - In order to minimize varying interpretations,^ | ppm sensitivity and the reproducibility of the method could be worded as follows: "The proposed standard for employee exposure is set at no detectable level, as determined by a method capable of detecting I ppm with a reproducibility (2) of 0.5 ppm at the 95% confidence level (2), as defined by ASTM Stan* dard E 180-67." The above statement would provide a valid technical basis for a mutual understanding of the requirements of the method to be used. Even with the improved definition of the method, it would still be true that for all practical purposes a concentration level of 0.3 ppm or less would be required in order to assure an analysis showing compliance. (At 0.3 ppm the reproducibility of the method would be expected to be about 0.15 ppm). Similarly a concentration of 3.0 ppm or more would be required in order to give an analysis conclusively showing non-compliance. (At 3.0 ppm the re producibility of the method would be expected to be about 1.5 ppm.) These relationships can be illustrated by the attached diagram, which shows the three zones of reproducibility associated with the use of the specified method. N. Hi Ketcham (1) Federal Register, Vol. 39 No. 92, May 10, 1974, page 16896. (2) "Reproducibility" and "Confidence Level" are defined in ASTM Standard E 180-67, Reapproved in 1972. These definitions are in paragraphs A 2.14 and A 2.12, re spectively. Part F of E 180 illustrates the use of these terms in precision statements. N HK/ml Attachments UCC 092716 Repro&cibility of the method when analyzing a known con centration of 3.0 ppm Reproducibility of the method at the "detectable concentra tion " of I ppm Reproducibility of the method when analyzing a known con centration of 0.3 ppm Analysis (PpM by Vo .) 3 50% I 50% f 0.45 < 0.3 l 0.15 0.3 50% UCC092m