Document gbNr53RMggZexk245dw8yLXzV

American Cyanamid Company Chemicals Group One Cyanamid Plaza Wayne NJ 07470 REGISTERED November 7, 1985 James J. Concannon, Director Office of Variance Determination Occupational Safety and Health Administration U. S. Department of Labor Third Street and Constitution Avenue, N.W. Room N-3656 Washington, DC 20000 Dear Mr. Concannon: American Cyanamid Company, Wayne, Hew Jersey, requests for our Chicago manufacturing facility that our application for a continuance in relief from the final blood trigger level of 50 ug/lOOg for Medical Removal Protection be withdrawn. In our letter of August 15, 1985, requesting a continuance in relief, we indicated that one employee, which was 5% of the workforce, was above 50 ug/lOOg. As of this date no employees are above 50 ug/lOOg and therefore our decision to withdraw the request for continuance in relief. Yours truly B. Cpopersmith, Manager Polymer Chemicals Department CSH:kn cshll06a bcc: j. Caporossi H. Gaffney B. Coopersmith N. Yin E. Malone D. Morgan NA MG NA NA NA Cleary CYWI 3-001091 U.S. Department of Labor Occups'iona1 Safety and Health Administration Washington. D.C. 20210 Reply to the Attention of: _/2 2.ryy-3 Mr. Mark N. Duvall Counsel for American Cyanaaid Company Cleary, Gottlieb, Steen & Hamilton 1752 N Street, N.W. Washington, D.C. 20036 Dear Mr. Duvall: This letter is in response to your letter dated February 111, 1983 requesting a variance from Section 1910.1025(e)(1) Lead - Engineering Controls, of the Occupational Safety and Health Standards. A request for a variance from Section 1910.1025(e)(1) is unnecessary in your situation. The modified version of the lead standard provides for the use of protective equipment (respirators) or any other protective measures when full compliance cannot be attained through engineering or administrative controls. A competent industrial hygienist or othfer technically qualified person must approve any equipment and/or technical tooasures used for the purpose of complying with the standard. A decision must be made to determine whether the administrative controls and the respiratory system mentioned in your application are sufficient to protect the employees at risk. Furthermore, your engineering report must provide the rationale to support why it is not feasible to implement engineering controls in each particular operation. Affected employees and their authorized employee representatives shall be informed of this clarification in the same manner they were informed of your application for a variance. No further action will be taken on your application. If I can be of further assistance, please contact my office at (202) 523-7183. Sincerely, ./ Director Office of Variance Determination CYWI 3-001092 N14756.01 -***' "eft?, . y- American Cyanamid Company Chemicals Group One Cyanamtd Piaza Wayne, NJ 07470 REGISTERED NOV i 2 1985 November 7, 1985 James J. Concannon, Director Office of Variance Determination Occupational Safety and Health Administration U. S. Department of Labor Third Street and Constitution Avenue, N.W. Room N-3656 Washington, DC 20000 Dear Mr. Concannon: American Cyanamid Company, Wayne, New Jersey, requests for our Chicago manufacturing facility that our application for. a continuance in relief from the final blood trigger level of 50 ug/lOOg for Medical Removal Protection be withdrawn. * ,In our letter of August 13 1995 requesting a continuance in relief, we indicated that erne employee, which was 5% of the workforce, was above 50 ug/lOOg. As of this date no employees are above 50 ug/lOOg and therefore our decision to withdraw the request for continuance in relief. Yours truly, Polymer Chemicals Department t CSHftkn cshll06a bcc: j. Caporosei-^ H. Gaffney B. Coopersmith N. Yin E. Malone D. Morgan NA MG NA NA NA Cleary CYWI 3-001093 N14756.02