Document gELbr6aQgemvKLmBQ5Rp6G0XQ

A k r nit w HuJI a- a S3 a js May 8, 197U The General Tire & Rubber Company General Street Reading, Mass 01867 Attention: Mrs R Holak Gentlemen: On April 5, 197U, The Occupational Safety and Health Administration issued an Emergency Temporary Standard for Exposure to Vinyl Chloride (29 CFR 1910.93q) A copy is attached for your review. Since there is residual vinyl chloride monomer in polyvinyl chloride resins, this ldtter is to bring you up to date concerning Goodyear's PLIOVIC resins. Testing of PLIOVIC resins at our plant facilities hap generally shown residual vinyl chloride monomer content of our finished resins to be as follows: Residual VC Monomer* PLIOVIC K-Resins PLIOVIC M-Resins PLIOVIC AO, WO <0.03$ (300 ppm) <0.05%($OQ ppm) . . <0.001$ (10 ppm) , * As tested immediately after production. These values should be maximums under normal operating conditions. Because of monomer volatility, resin received by customers should be even lower. By mid-197U, we expect to have residual vinyl chloride monomer in PLIOVIC BK-resins reduced to <0.02$ (200 ppm). Goodyear has initiated programs to improve its manufacturing processes and is participating in an industry effort to reduce the residual vinyl chloride monomer in polyvinyl chloride resin. However, since vinyl chloride monomer is volatile, it can continue to be released from the resin and can concentrate in closed spaces during storage and shipment. AY 1974 s' \ -\ 3 In view of this, resin users should exercise certain precautions. Enclosed areas and head spaces in hopper cars and bulk storage tanks should be purged and tested prior to personnel entering the areas. In adequately ventilated warehouses, we have not found detectible levels of vinyl chloride monomer. In processing areas, adequate ventilation of equipment should be provided and, if feasible, local exhaust ventilation should be used on mixing equipment. The odor threshold for vinyl chloride monomer is considerably above the recommended safe exposure limit for health purposes and, therefore, odor cannot be relied on as an index of safe exposure. Instrument testing must be employed to evaluate atmospheric concentrations. Sampling procedures and safe exposure limits for vinyl chloride are specified in the Temporary Emergency Standard (attached). Medical surveillance practices and procedures are not specified as yet but are expected to be covered in a proposed permanent standard to be issued soon. Toxicological information which is available is discussed in the opening sections of the Temporary Emergency Standard (p 123U2). At this time, the Food and Drug Administration and the Environmental Protection Agency have taken no action on polyvinyl chloride resins or their production. However, both agencies are gathering information which may lead to regulations. A, Wa hope that this information is helpful to you at this time. We will inform you a3 more information becomes available. Very truly yours, \t Attachment M J Rhoad CHEMICAL DIVISION General Manager GENC 00034A I2-T-I2 RULES AND REGULATIONS Title 29--Labor 50 ppm, In order to assess In a more rary standard. In a telegram to the As CHAPTER XVII--OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION, DE PARTMENT OF LABOR PART 1910--OCC UPATIONAL SAFETY AND HEALTH STANDARDS definitive way whether that level of ex posure produces tumors In animals. Data reported by Torkelson, Oyen and Rowe (American Industrial Hygiene Associa tion J 22:354-361 (1961)) Indicate that exposure to VC at concentrations of 50 sistant Secretary of Labor, received on or about March 14, 1974, the President of the United Rubber Workers Interna tional Union urged the establishment of an emergency temporary standard for VC, During the hearing of February 15, Emergency Temporary Standard for ppm failed to Induce tumors in rats, 1974, the Industrial Union Department, Exposure to Vinyl Chloride hamsters, rabbits, and dogs. AFL-CIO, and the United Rubber Work 1. Background. Vinyl chloride (chloro- ethene), Chemical Abstracts Service Registry No, 75015, is a synthetic chemi cal made by oxychlo'rination of ethylene or by hydrochlorination of acetylene. It is the parent compound of a series of thermoplastic resin polymers and co polymers which are widely used for con tainers, wrapping tissues, electrical In sulation, pipe, conduit and a variety of other products. Vinyl chloride has been made commercially In this country since 1939 and present production Is in excess of seven billion pounds per year. Vinyl chloride (VC) Is a gas at am bient temperature and pressure and Is a chlorinated hydrocarbon which has mod erate liver toxicity. The present standard sets' a ceiling value of 500 parte per million (ppm) (20 CFR 1910.93). On January 22, 1974, the Occupational Safety and Health Administration was informed by the National Institute for Occupational Safety and Health (NIOSH) that the B. F.Goodrlch Chem ical Company reported that deaths of several of its employees from a rare form of liver cancer may have been cfccupationally related. As a result of this notifi cation, and after consultation with NIOSH and a joint inspection of the plant by OSHA, NIOSH, and the Ken tucky Department of Labor, a fact-find ing hearing on possible hazards Involved with the manufacture and use of both VC and polyvinyl chloride was an nounced on January 30, 1974 (39 FR 3874), and held on February 15, 1974. The employees of the B. F. Goodrich Chemical Company who died from an giosarcoma of the liver had an average exposure of approximately 19 years to vinyl chloride, at unknown concentra tions. and variable exposures to other volatile chemicals. (TR 93). Some em ployees of Union Carbide Company and Goodyear Company are also reported In a post-hearing comment' from NIOSH dated March 11. 1974, to have had ex posure to vinyl chloride and to have died from angiosarcoma of the liver. Finally, autopsies of four deceased employees re vealed that liver angiosarcoma turner; were histologically indistinguishable from the angiosarcoma tumors observed in Professor Maltoni's experimental ani mals. It Is concluded therefore, that vinyl chloride Is carcinogenic for hu mans. We therefore conclude that the present standard for VC should be lowered from a celling of 500 ppm to a ceiling of 50 ppm for the following reasons: (a) In light of the evidence referred to above including the Maltonl experi ments demonstrating that VC Is carcino genic in animals at 250 ppm, we conclude that VC must be considered carcino genic in man at the same level; (b) Although Professor Maltonl did not Induce tumors in his experimental animals at an exposure concentration of 50 ppm, these data do not support the concept that occupational exposure of employees to concentrations of 50 ppm throughout their working lifetime would be without detrimental health effects; 2. Carcinogenicity of VC, Information (c) The question whether safe levels produced at the hearing demonstrated of exposure to carcinogens exist for hu ers International Union made a Joint petition for an emergency temporary standard for VC (TR 141-148), which was also Joined by the Oil, Chemical and Atomic Workers International Union (TR 37). At the same -hearing, several participants urged, on the other hand, a regular rulemaking proceeding as the most suitable for the orderly develop ment of relevant Information (TR 112, 180). The petitions for an emergency tem porary standard specified in detail the contents of the standard requested. In substance, the request Is to Issue a com prehend'. e fu!,w-developed standard based on the recommendations of the Standards Advisory Committee on Car cinogens submitted to the Assistant Sec retary of Labor on or about August 27. 1973. The recommendations are farranging, and cover special categories of operations, signs and labels, medical sur veillance, reporting, etc.. Including a per mit system for the use of a carcinogen. We agree that an emergency tempo rary standard is necessary; we cannot say on the basis of the information developed so far that a comprehensive standard, such as the one requested, is either neces sary or even desirable, it has been de cided to promulgate a standard contain ing only those essential provisions which are deemed necessary to provide protec tion to employees from grave danger until a regular rulemaking proceeding in accordance with sections 6 (b) and (c) of the Act can be concluded. The rea sons for a decision to establish a celling value of 50 ppm have already been stated. A decision on other possible, ap that exposure of laboratory animals (mostly Sprague-Dawley rate) to VC by inhalation at and below the current mans and. If so, what such levels would; propriate provisions Is best made after be, is the subject of continuing scientific consideration of all relevant data and deliberation. In the case of VC, Profes views that Interested persons may sub OSHA standard of 500 ppm Induced sor Maltonl did not observe tumors In mit during the proceeding soon to be tumors. Including angiosarcomas of the liver, ihrofessor Cesare Maltonl, of the Institute dl Oncologla, Bologna, Italy, re his animals at exposure concentrations of 50 ppm. m addition. Torkelson, Oyen, and Rowe found that exposure to con initiated. With respect to arguments In opposi tion to Issuance of an emergency tem ported on a series of experiments on the centrations of 50 ppm of VC failed to In porary standard, the concern and efforts effect of exposure of rats, mice, and duce tumors In rats, hamsters, rabbits, of several companies participating at the hamsters to VC at concentrations of 10,- and dogs. Accordingly, there Is insuf hearing for the protection of their em 000; 6,000; 2,500; 500; 350; and 50 ppm for varying periods of time (TR 43-63). ficient evidence at this time to conclude that VC at concentrations of 50 ppm or ployees ore recognized. It may also be that some employers In some plants have Some of the experiments have been con cluded, and others are still ongoing. The experimental results so far reported are that tumors have, been observed In below poses a grave danger to humans. (d) The emergency temporary stand ard adopted represents a substantial re duction In the permissible level of expo fully complied with the Interim controls recommended by NIOSH on January 30, 1974. There Is, however, reason to believe that employees are currently being ex groups of animals exposed to VC at con sure and. In our practical judgment, Is posed to VC at concentrations well above centrations as low as 250 ppm. No tumors the lowest level that can be complied 50 ppm. This was asserted several times have been observed In the group of ani mals exposed to VC at a concentration with Immediately; and (c) This standard will be In effect for at the hearing, and not seriously ques tioned. Moreover, a report, dated March of 50 ppm. It also appears so far that a period of no longer than six months, 1974, of a survey by the staff of the Office the total number of tumors, as well as the numbers of angiosarcomas of the during which time the whole question of possible sale exposure of humans to VC of Standards Development. OSHA, of several facilities manufacturing VC and liver, decrease as the concentrations of will be reconsidered more fully and In polyvinyl chloride revealed concentra VC are reduced to 250 ppm. Finally, the light of more Information, Including tions for some job classifications as high another experiment by Professor Mal experiments which are under way at this as 229 ppm. , Therefore, a regulation is tonl Is underway involving the exposure time (TR 47,49.71-74). considered necessary to provide, immedi of 300 animals to VC at concentrations of 3. Petitions for an emergency tempo ately, adequate protection to workers ex- > FEDERAL REGISTER, VOL 39, NO. 67--FRIDAY, APRIL i, 1974 i_!0';y y ij ij4 3 a QhNC OO'J RULES AND REGULATIONS 12343 pasod to VC. Also. the eight-hour, timeweighted average standard suggested by several participants at the hearing (see. for instance. TF; 178). has been rejected. I7ie March 197'- report of the survey re vealed that several kinds Of work or optrationd are of short duration. Loading or unloading of a tank car may require approximately 15 minutes. The cleaning of a reactor may require approximately half an hour. An eight-hour, timeweighted average standard-would permit exposure to VC at concentrations of 400 ppm for one hour. Such upward excur sions, several times the 50 ppm level, can not be permitted to occur. 4. The standard. The standard set out below contains only the requirements deemed necessary to provide protection before the conclusion of the rulemaking proc-'cdlng to be commenced shortly. Because exposure to VC Is hazardous, and l>ecause such exposure can occur in the processes of synthesizing or polym erizing of VC or in the handling of VC polymers or copolymers which contain ab.-.oibed VC. this standard applies to all such processes and to the handling, re act ing. manufacturing, processing, re leasing, repackaging, or storage of any of these materials. 1dm monitoring require ments serve two purposes, to trigger into opci ation a compliance program and to cluck the effectiveness of the program. Also, engined mg controls are favored for compliance, and respirators are intended to piovirie protection until such controls can be installed or in cases where sucli conlioJs arc not feasible. Aceoicluigly, by reason of the foregoing and on the basis of the record of the hearing of February 15, 1974, with ex hibits, the written submissions received befoic the hearing pursuant to the notice Of tin- hearing, the post-hearing written submissions by the participants at the hearing, the March 1974 reiKirt of a factfindin r survey recommendations received from NIOSII, and the other data referred to herein, it is found (!' that VC at con centrations in excess of 50 ppm is physi cally hmmful and carcinogenic; (2) that exposure to VC*at concentrations in ex cess of a concentration of 50 ppm poses a grai e danger to employees; (3) that em ployees are presently exposed to VC at concentrations m excess of 50 ppm; and (4) that the emergency temporary stand ard set out below is necessary to provide immediate protection to employees from such danger. Pursuant to section G(c) of the Occu pational Safety and Health Act of 1970, a proceeding will commence shortly In accordance with section 6(b) of the Act, In which the emergency temporary standard will serve as a proposed rule, together with other subsidiary rules. As soon as possible a draft environmental Impact statement will be filed with the President's Council on Environmental Quality, and copies will be provided to oilier appropriate Federal agencies for their comments. Pursuant to sections G(c) and 8(c) (3' of the WUliams-Stciger Occupational Safety and Health Act of 1970 (84 Stat. 1596, 1599; (29 U.S-C. G55, 657)), and Secretary of Labor's Order No. 12-71 (36 FR 8754), 29 CFR Part 1910 is amended by adding thereto a new ( 1910.93q to read as set forth below. In addition, pur suant to section 4(b)(2) of the Act (84 Stat. 1592; (29 U.S.C. 653)), the stand ard in the new 5 1910.93q Is determined to bo more effective than the corre sponding standards now in Subpart B of Part 1910, in Parts 1915, 1916, 1917, 1918, and 1926 of title 29, Code of Federal Reg ulations. and in Part 50-204 of Title 41 of the Code of Federal Regulations. There fore, .these corresponding standards are superseded ' by the new standard in S 1910.93H. 1. In 29 CFR Part 1910, 1910.93 is amended by deleting from Table G-l the line: "* * * C Vinyl chloride * * 500 * * 1300". 2. Part 1910 of Title 29 of the Code of Federal Regulations is amended by adding thereto a new 51910.93q ip read as follows: 1910.93q Vinyl chloride. (a) Scope and application. (1) This section applies to any area or operation in which vinyl chloride (chloroethene), Chemical Abstracts Service Registry Number 75015, Is manufactured, reacted, handled, processed, released, repacked, or stored. (2) This section does not apply to the handling, storage, or other use of vinyl chloride polymers and copolymers in the form of fabricated products, (b) Permissible exposure. The occupa tional environment shall be controlled so that no employee Is exposed to vinyl chloride at a concentration In excess of 50 parts per million (ppm) <127.0 tng/cum). (c> Monitoring---(1) Initial monitor ing. As soon as possible but not later than April 22, 1974, every employer of an em ployee working in an area or operation in which vinyl chloride is manufactured, re acted, handled, processed, released, re packed, or stored shall begin monitoring the ambient air of the area to determine whether it contains vinyl chloride in con centrations in excess of 50 ppm. (2) Frequency. Monitoring of a suffi cient number of employees so that a representative sample of exposures to vinyl chloride may be determined shall be accomplished-not less frequently than weekly until all results for three consecu tive weeks are at or below 50 ppm. There after. monitoring shall be conducted not less frequently than monthly so long as the concentrations of vinyl chloride do not exceed 50 ppm. If a monitoring sam ple reveals vinyl chloride in concentra tions in excess of 50 ppm, weekly mqnli toring shall be resumed until all results for three consecutive weeks are at or be low 50 ppm, (3) Method of monitoring. Personnel monitoring shall be accomplished by col lecting samples by suitable devices wom by the employee. The samples shall be analyzed by gas chromatography or by any other method which is of equivalent sensitivity. The analytical procedure shall be sensitive to 5 ppm of vinyl chlo ride in air with an accuracy of 20 per cent for a ten minute air sample. (4) Employee observation of monitor ing. Employees working m an area or operation whose ambient air is moni tored, or their representatives, shall be given a reasonable opportunity to obser-. e the personnel monitoring required by this section. (5) Recordkeeping. The results of all monitoring shall be recorded in writing. The records shall be retained for at least 5 years 'and shall be made available for inspection and copying by representa tives of the Assistant Secretary of Labor for Occupational Safety and Health and the Director of the National Insti tute for Occupational Safety and Health (NIOSH), (6) Employee access. Each employee and former employee shall have access to such records of the results of monitoring required "by this section as will indicate his own exposure to airborne concentra tions of vinyl chloride. (7) Employee notification. Each em ployer shall promptly notify any em ployee who has been or 1s being exposed to vii^yl chloride in concentrations in ex cess of 50 ppm, and shall inform him of the corrective action being taken. (d) Compliance. (1) Whenever any monitoring sample reveals vinyl chlor.de at a concentration in excess of 50 ppm, or whenever any accident, such as rup ture of equipment or spillage, indicates the likelihood of a greater than usual release of vinyl chloride into the ambient air, all employees exposed to such con centrations shall be withdrawn to a safe area and shall not be permitted to re enter the work area unless they wear either Type C continuous flow or pres sure demand air supplied respirators or self-contained, breathing apparatus. (2) Work which may Feaeonably be expected to release vinyl chloride in con centrations in excess of 50 ppm. such as repair, maintenance or cleaning of re actors og other' equipment containing vinyl chloride, shall be accomplished only by employees wearing Type C continuous flow or pressure demand air supplied res pirators or self-contained breathing ap paratus. (3) In any case covered by para graphs (d)(1) or (d)(2) of this section. In addition- to providing the required respirators, the employer shall examine and analyze the Source of the excessive concentrations of vinyl chloride in order to determine feasible engineering or op erational-controls appropriate to reduce the airborne concentrations to the permissable level. Such controls shall be implemented as quickly as possible. (4) Periodic tests shall be conducted for equipment leaks and for emissions of vinyl chloride which may result from work practices. 3. In 29 CFR Part 1910, $ 1910.19 Ls revised to read as follows: 1910.19 Special provisions for air con taminants. (a) Asbesfos dust. Section 1910.93a shall apply to the exposure of every em ployee to asbestos dust in every employ ment and place of employment covered by 1910.12, 5 1910.13. ! 1910 14. 1910.15, or S 1910.16, in lieu of any dif- No 67--FU, FEDERAL REGISTER, VOL. 39, NO. 67--FRIDAY, APRIL 5 , 19Z4 GEHC 0003411 12344 ferent standard on exposure to asbestos dust which would otherwise be appli cable by virtue of any of those sections. (b) Vinyl chloride. Section 1910.930 shall apply to the exposure of every em ployee to vinyl chloride in every employ ment and place of employment covered by | 1910.12, 5 1910.13, } 1910.14, i 1910.15. or {1910.16, In lieu of any dif ferent standard, on exposure to vinyl chloride which would otherwise be ap plicable by virtue of any of those sec tions. Effective date. These amendments shall become effective on April 5, 1974, (Sees. 4, 6, and 8. 84 Stat. 1S92, 1596,1599 (38 O.8.C. 653. 655, 657); Secretary ot tabor* Order No. 12-71,36 TO 8764.) Signed at Washington, DC., this 2d day of April 1974. SJohn tender, Assistant Secretary of tabor. |TO Doc.74-7890 Filed 4-4-74)8:45 am] GB-Jf i