Document gbReM9oE6QXk0Xoo6XXqmvao3
TABLE Cr CfLTCiTS
IMBDUCTItH
I. Scope of the Vihyl Qhloride Industry
II. Toxicology of Vinyl Chloride
III. Health Parameters Studied in Vinyl Chloride
WORKERS
IV.
Industrial Hygiene
'
**
V. Safety in the Vinyl Chloride . Industry
VI. Analytical Methodology
VII. ReCOTMENDATIONS FOR GOVERNMENT"INDUSTRY Action
Appendix I,
Published References to thetiological
Effects of vinyl Chldirde (Including
CHEMICAL ABSTRACTS 12b2 - JANUARY 14,
and Biological Abstracts 1952-
Appendix II.
" Industrial Hygiene Surveys Involving Vinyl Chudride
i .<&CH APPENDIX TO THE TESTIMONY IS A COMPLETE VOLUME
IN A HARD-BACK BINDER. EACH IS SUBMITTED IN TRIPLICATE).
AP00022838
-1-
iiirRODurnc;]
I ahV,
fe.c of r.;..: Chehical ll.S.A. Currently I ah a research
Scfjj.'iTST CONCERNED WITH THE UVR-ALL BROAD ASPECTS OF Dow's HEALTH
and &tvi;".-:r-3iTAL Research, Prior to being naked to this post in late 1373/ I was Director of our Toxicology Jj\sopatcry and Industrial
HYGIENE RESEARCH,
I SHALL SLvV-ARIZE FOR THE RECORD THE FOLLOWING: (1) SCOPE OF THE
VINYL CHLORIDE INDUSTRY; (2) THE BASIC TOXICOLOGICAL INFORMATION;
(3) THE HEALTH PARAMETERS STUDIED IN VINYL CHLORIDE WORKERS; W) ' OUR INDUSTRIAL HYGIENE EXPERIENCE IN ALL OF OUR PLANTS; (5) ANALYTICAL
AI MONITORING PROCEDURES; (6) ITENiS FOUND EFFECTIVE IN MAINTAINING
SAFE OPERATING CONDITIONS; AND FINALLY (7) SOME SUGGESTIONS FOR THE FUTUREi I BELIEVE IT WILL BE APPARENT THAT THE INDUSTRY LEARNING CURVE FOR VINYL CHLORIDE IS FAR ADVANCED.
- -/' "* *> rv "
AP00022839
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-2-
I. SCOPE OF TIE VlliYL CHLORIDE I;E-USTRY
IfcW CkEMJCAL U.S.A. BEGAN PRODUCING VINYL CHLORIDE MCNCM.ZR ON A VERY MODEST SCALE IN MIDLAND, IiICHIGMI, IN 1939 AND PRODUCTION REMAINED
RELATIVELY LOW THROUGHOUT THE WAR PERIOD. I,N 1945, PRODUCTION OF
VINYL CHLORIDE BEGAN IN OUR TEXAS DIVISION AT FREEPORT, TEXAS,
ICapacity was expanded at this location through 1955.
n 1S58 our
SECOND MONOMER PLANT WAS BROUGHT ON STREAM IN PLAQUEHINE, Uw AND"
A THIRD WAS ADDED IN 1969 AT OUR OYSTER CREEK DIVISION, In 1952
Dow WAS ONE OF SEVEN U,S, PRODUCERS OF THE MONOMER AS REPORTED IN THE-
first U.S. Tariff Commission report on vinyl chloride. Today there ARE TEN PRODUCERS OF VINYL CHLORIDE MONOMER;' EbW BEING ONE OF THE
LARGE MERCHANT SUPPLIERS, IN ADDITION TO PRODUCING MONOMER, DCW
OPERATES A SMALL POLYMERIZATION PLANT,
U.S,The quwtity of vinyl chloride produced in the
has grown quite
rapidly, Production increased from approximately 321 million pounds
IN 1952 TO 1 BILLION POUNDS IN I960; 2 BILLION POUNDS IN 1955j 4
BILLION IN 1970, TO AN ESTIMATED 5.3 BILLION IN 1973, THIS MONOMER
GROVTTH RATE ILLUSTRATES THE HIGH DEMAND FOR THE PLASTICS PRODUCED FROM VINYL CHLORIDE (SEE FIGURE 1). VlNYL CHLORIDE IS THE SECOND LARGEST VOLLTCE MONOMER PRODUCED IN THE UNITED STATES, THERE ARE TWO COMMERCIAL PROCESSES FOR PRODUCTION OF THE MONOMER, One ROUTE INVOLVES THE ADDITION OF HYDROGEN CHLORIDE TO ACETYLENE.
hq + om--------- >o)2=on
AP00022840
u.s. producers of vinyl chloride
Year
Total IKS. Production
Million 4
Pounds
es
rt t>
o ri E4> JZ o
H .c
E(U orl
,c Sh
u 'O cy
o j->
coG
cU o
o
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ec
ca
o o
5
o a
o o
41
G c o -
g
4) a
o o oc
<ux, CU
<y 0 H g
<y A O
H r-C O A CO
-
ft.
u 0 0
r~* ? A
W
o
c
0 a
<3
*4
Q
O
O 4>
A ^1
t* &-*
(U
CJ t--t
C
O H G G> `
h
0
G 4)
u
(>
A
CJ> t.
C!
TJ .n
C _o
0 C3 j
3
G
t-4
J-.
<D
(0 O >
V) A 'O co
cEo
03o
sUo
j. 1973s* 5,333
X XX XXX XXX X
1 1972** 5,103
X XX XXX XXX X
[ 1971
4,336
X X X X X X X X X X
1970
4,040
X XX XXX XX
XX
19$9
3,736
X XX XXX XX
X XX
1968 1967 r-19^6
2*969 2,424 2,500
X XX XXX XX
X XX
XX
XX
X XX
XX X
XXX XXX XXX
XX
f
-.4
X X ' X *x
*. i
XX XX
"19 65
2,000
X XX
X
X
XXX
XX
XX
1964 _ 1,615
X XX
X
X
'* 1963
M35
X XX
X
X
^962
1,313
X XX
X
X
XXX XXX XXX
XX XX XX
XX XX XX
rJ.961
1,044
X XX
X
XXX
XX
XXX
"i960
1,037
X XX
X
XXX
XX
XX X
: "l959
978
X
X
X
"1958
691
X
X
X
1957
627
X
X
X
XXX X XX X X X XX
X X X x
% -4956
597
X
X
X
"1955
529
XX
XX X X X XX X X X
L954
'393
XX
XX X X X
_ 1953
402
XX
XX
X
"1952
321
XX
XX
X
*Source : U.S
chi i5 :'u.s. TTcei`n1i:t`:' Cc:::::iic:uloM - Monthly Reports (subject to revision)
1997o3 qquu: amni tity e.:tKr.ntos 1'ron 11 month, data.
XX
X *x
of ViT
AP0002284I
.-4-
Ib.'EvrR, t::e mi;; ;!PAL PROCESS, USED BY DOW AND MOST OTHER PRCDUCi in the U.S., INVCi .VES THE THERMAL DEHYBROI 'ALCOENATION Or ETHYLENE DICHLORfDE.
CH2CICH2Q--------------* CH^CHCl + HQ
Vinyl chloride is one of the purest organic compounds produced commercially.
DariA typical analysis of vinyl chloride produced BY
SHOWS LESS THAN 20 PPM
*"
OF-TOTAL-ORGANIC IMPURITIES. - THESE TRACE-ORGANIC- IMPURITIES ARE ACETYLENE/
L3-BUTADlEIiE^ METHYL CHLORIDE^ AND VINYL ACETYLeJE,
*
*-'
.Nearly all vinyl chloride monomer shipped by Dow is uninhibited; however, A SMALL AMOUNT IS INHIBITED WITH 25-75 PPM PHENOL. The PHENOL IS SUB
SEQUENTLY REMOVED BY USE OF A CAUSTIC WASH.
I WISH TO EMPHASIZE THE DIVERSITY OF PLANT AND PROCESS OPERATIONS IN PRODUCING AND USING VINYL CHLORIDE. COMMERCIAL PLANTS FOR PRODUCING VINYL CHLORIDE RANGE IN CAPACITY FROM MODEST SIZE UP TO SEVERAL HUNDRED MILLION POUNDS. SOME ARE NEW PLANTS, SOME ARE 15 TO 20 YEARS OLD.
Three distinctly different polymerization processes have been commercialized TO PROVIDE Th WIDE VARIETY OF ESSENTIAL PLASTIC MATERIALS PRODUCED FROM
AP00022842
STW'iDARDy DEPENDING ON THE -PARTICULAR PLANT SITUATION
AP00022843
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II. TCXIC0LC3Y CF VlfJYL GLORIEE
EARLIEST STUDIES C.`I VINYL CHLORIDE WERE LIMITED TO ACUTE EXPOSURE?, AS
TYPICAL CP TOXICITY STUDIES OF THE DAY, THESE OBSERVATIONS LED TO ITS
CDHSIC2RATIGN AS A SURGICAL ANESTHETIC. GNERALLY,THESE STUDIES SHOWED
VINYL CHLORIDE TO BE LOW IN ACUTE TOXICITY, TO BE ANESTHETIC IN ACTION, AND
TO HAVE LITTLE CAPACITY TO CAUSE LIVER INJURY FROM EXPOSURES OF A FEW HOURS.
MaSTROHATEO 1 AU (1960) AND LESTER El b (1963) REPORTED ON ACUTE
EXPOSURES OF ANIMALS AND HUMANS,
.
They reported yery little effect until exposure concentrations approaches^?-
10,000 PPM VfriEH HUMANS REPORTED DIZZINESS AFTER 5 MINUTES EXPOSURE,
.
DEATHS OCCURRED IN RATS EXPOSED FRCf-1 1/2 TO 2 HOURS TO 100,090 PPM.
Exposures to 150,030 to 200,000 ppm for 1/2 to 2 hours caused anesthetic
u DEATHS AS DID HIGHER CONCENTRATIONS FOR SHORTER PERIODS OF TIME,
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AP00022844
-7-
aclr'e
or toxicity
OF VINYL G1GXIEE
Seuoes.
Rats, mice, and GUINEA PIGS
Concentration (ppm)
100,003 - (10%)
200.033 " 300.033
Guinea pigs Rats
400,003
100,000
150,033
Huyans
None
4,000
... 8,030 CO
12,000
'x r *. '**
4 . /
16,000
20,000
. Death or Other Effect
No DEATHS IN 0,5 HR ^
1/15 0/5 mice):** - : 11/15 (5/5 rats "And mi ce : r
1/5 GUINEA PIGS)
& .... .
2/5 (1 ihi'iediatelyJ 1 in -24 hr$:
No DEATHS IN 2 HRS^ 1 OF 2 DIED IN 2 HRS
-- .. (9) KJ
/* 1/6 SLIGHT DIZZINESS IN 5 MIN u
0/6
1/6 SLIGHTLY UNSTEADY 2/6 (1 SLIGHTLY UNSTEADY,
1 REELING) Intoxication of varying degree Intoxication of varying degree,
MORE SEVERE
(1)
,Hwtrommeo ElALw AINA J,_2L 394 (33EO) ..
(2) Lester, Greenberg and Adams, AIllA J, JJi 265 (1S53)
AP00022845
$ UIJ8 CONGESTION AND ElH-'A WERE PRESENT AFTER 42 MINUTES EXPOSURE TO
15)v0) PPrl/ BUT LIVER ,V!D KIDN'EY INJURY WERE NOT APPARENT,
Since 1952,, numerous non Li.S, articles on vinyl chloride have appeared, PARTI aCARLY IN THE RUSSIAN LI TEXTURE, SEVERAL OF THESE STUDIES N/VOLVED ACUTE EXPOSURES AND THE OBSERVED EFFECTS WERE GENERALLY SUBTLE REVERSIBLE CHANGES,
The CHRONIC TOXICITY OF VINYL CHLORIDE HAS BEEN STUDIED BY SEVERAL.^.
INVESTIGATORS. TORKELSON, OyEN, AND ROWE Q951) REPORTED THE FOLLanNG"
"
results.
. . : t;
.y . Results of-Repeated Se^n-HourJ]aily_Exfosures to Vinyl CHLORi^^g-y-;v .y
Bpcsuri
PPM
Tilths
5oa 4.5
Dogs
Guinea pigs
NOT EXPOSED NOT EXPOSED
200 6
NO EFFECT ; NO EFFECT
; *: t
100 6 50 6
V*rJ`TY
NO EFFECT
NO EFFECT
NO EFFECT
NO EFFECT
Rats
Rabbits
SLIGHT LIVER 8
NOT EXPOSED
KIDNEY HISTOPATKOLOGY
(CENTRAL lobujvv granular degeneration
AND INTERSTITIAL & TUBULAR CHANGES)
SLIGHT LIVER . WEIGHT INCREASE
' * t,
m
SLIGHT LIVER
histopathology
(CENTRAL LICULAR
DEGENERATION 8
NECROSIS WITH VACUALAT1 CM AND
SOME PERIPORTAL CELLULAR infiltration)
SLIGHT LIVER WEIGHT INCREASE
NO EFFECT
NO EFFECT . NO EFFECT
AP00022846
-9-
Tiay concluded that worrrns cxposur?: ciculd limited to lest "
PPM Vi IT! I ATII-c-WEIGfltD AVERACE *;OT TO EXCEED 50 PPM,
ICO
LESTER, Gr.EEKEEP.3, AMD AlVMS TOOK EXCEPTION TO CONCLUSIONS OF TCF.XELSON,
ET AAL AND HECC;"'ENDED 5CO PPM AS TIME-WEIGHTED AVERAGE EXPOSURE
FX^nj}fLi-y\LJ^D FK3LE
50>0CC ppm - 19 DAYS
20>OCO ppm - SO days
' --Besulil
Incoordination, Normal hematology.
* *" $ -** -
Increase
LIVER WEIGHT. NORMAL GROSS PATHOLOGY. SLIGHT
LIVER HISTOPATHOLOGY,
Normal hematology. Increased liver weight. Normal gross pathology. Slight liver HISTOPATHOLOGY^ WHICH WAS CONSIDERED TO EE WITHIN NORMAL LIMITS.
AP00022847
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I
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Because OF 71 >ES,CONFLICTING RLPCTrS, TIC TLV Co.'VU"FEE OF THE ACGIilin 1963 chose, to change their TLV FneM 530 ppm as a maximum tim=-wei cited AVERAGE FOR INDUSTRIAL EXPOSURE TO 503 PPM AS A CEILING VALUE * (AMERICAN
Conference of CovEmc'smL Industrial Hygiene/ 1553).
P, L.Because of the report of acrcosteclysis in klt,\n$/ Professor
Viola
ELEVAOF THE RcGIMA
INSTITUTE FOR CANCER RESEARCH IN ROME, ITALY/ ATTEMPTED
TO PRODUCE THE filSEASE IN ANIMALS. He EXPOSED RATS 4 HOURS PER DAY/ 5 DAYS PER WEEK TO 30/000 PPM (37) VINYL CHLORIDE VAPOR, (VlOLAj MARCH 1970)* >-<
In his first report on the results of 12 ^souths exposure/ he described
J M-TAPLAStlC CHANGES IN THE BONES WHICH HE CONSIDERED SIMILAR:"TO tHE
* l ' * v' -- DISEASE ACROOSTEOLYSIS. He MADE NO MENTION OF HAVING OBSERVED CANCER IN#--
.-X'' -T
THESE ANIMALS UNTIL THE TENTH INTERNATIONAL CANCER CONGRESS IN MAY 1970,
In the abstracts of this meeting/ (Viola/ 1970)/ and subsequently in
May 197L Viola/ BigottI/ at Caputd G971) reported tutors of the skin/
LUNGS/ AND BONES OCCURRING FIRST AFTER ID-MONTHS EXPOSURE. THE AUTHORS
SUMMARIZED THIS WORK AS FOLLOWS I
.
'
'*: N,, *
n LJ
JO
lu'
j-
AP00022848
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wHats (/WIRE V/istar strain) exposed ron 12 urn is to vafc-rs CP VINYL
CHLORIDE DEVELOPED TU-ms OF THE SKIN, LUNGS, AND BONES, Tiii ; CUTANECUS
TUMORS, vr.na-i ALWAYS APPEARED IN THE AREA IN WHICH SU2iVC<ILLARY AMD PAKOT1D GLANDS ARE LOCATED, HAVE 3EEN HISTOLOGICALLY RECOGNIZED A3 EPIDERMOID CARCINOMAS^ PAPILLOMAS/ Af'JD MUCOEPIDERMOID CARCINOMAS. THE
MORPHOLOGICAL CHARACTERISTICS OF LUNG TUMORS, WHICH OCCURRED IN A LOWER PERCENTAGE, WERE MAINLY OF USE ADEIiOCARC 11 ICr A TYPE, WITH THE EXCEPTION OF *A SINGLE EPJDERTOID TUMOR ORIGINATING FROM THE EPITHELIAL. COVERING -* CELLS. In A MINOR NU-TEER OF RATS, A LARGE PROLIFERATION OF C/vRTILAGINOUS
TISSUE DIAGNOSED AS OSTEOCHONDROMA DEVELOPED IN THE METACARPAL AND META' V rtkt...
TARSAL REGIONS OF THE FOUR LUBS."
t
- , %
v*
This report by Viola_exjiLJ is apparently the earliest and only publication'-'"-'
ALIN WHICH CARCIK'OSNIC ACTIVITY HAS BEEN ASCRIBED TO VINYL CHLORIDE.
THOUGH THERE ARE POSSIBLE DEFICIENCIES IN ViOLA's STUDY, SUCH AS THE
QUALITY OF THE VINYL CHLORIDE SAMPLE USED IN THE STUDY, THE PRESENCE OF
-
FOOD AND BEDDING IN THE EXPOSURE CHAM3ER, AND THE EXCESSIVE EXPOSURE
CONCENTRATION USED, THE REPORT NEVERTHELESS GAVE RISE TO SERIOUS CONCERN
AND RESULTED IN THE INITIATION OF ADDITIONAL ANIMAL STUDIES AND EPIDEMIOLOGICAL STUDIES WHICH*ARE CURRENTLY UNDERWAY (MCA PRESS RELEASE)
aj
i
t .**
AP00022849
r'
Summarizing, it s:culd be emphasized:
A. * B.
c.
Acute effects from short term exposure occur
ONLY AT high ENVIRONMENTAL CONCENTRATIONS. CHRONIC OR LONG-TERM effects occur at noderate CONCENTRATIONS. The MOST SENSITIVE TOXICOUOGICAL RESPONSE OBSERVED TO DATE IS THE EFFECT ON THE LIVER. The CENTRAL NERVOUS SYSTEM EFFECT IN HUMAN BEINGS IS RELATED TO THE CONCENTRATION OF INHALED AIR,
i-w rv
We are submitting triplicate copies OF THE TOXICOLOGICAL LITERATURE ONV-~^
OSKAVINYL CHLORIDE FOR
REFERENCE. THESE ARE APPENDIX I OF THIS TESTIMONY.
\
AP00022850
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?***?*>>.^v*>*nr/-'V,<v.v-=
-33-
III. HEALTH PAHYiETERS STUDIED III VDRKERS
Ibw is cooperating with the m^jufacturing chemists association which
HAS RETAINED TaSERSHAVJ-CoOPGR TO EG AN INDUSTRY-WIDE STUDY OF THE
HEALTH OF WORKERS EXPOSED TO VINYL CHLORIDE. CuRRBTTYLj WE IJAVE APPROX
IMATELY 320 EMPLOYEES IN VINYL CHLORIDE OPERATIONS. Vfe HAVE ` SUBMITTED *
TO TaBERSHAW-CcOPER EMPLOYEE RECORDS COVERING 916 PERSONNEL WHO HAVE
BEEN INVOLVED IN VINYL CHLORIDE OPERATIONS OVER THE YEARSTVlIS STl^|%fV'
IS INCOMPLETE AND WILL BE REPORTED AT AN APPROPRIATE DATE. HOWEVER/ 7y^..$k
jr-. -' v* vJBRf-.J*
WE CAN MAKE THE FOLLOWING PRELIMINARY CONTENTS ON THE HEALTH' PARAMETERS^l-^L. %i A*?#* v
P OF Daw VINYL CHLORIDE WORKERS.
L.- -ra*/&Lpy<!k
Preliminary data from Dow kanufactiring umits reveal no deaths due to ....
v*.*
CANCER OF THE LIVER. U
n * Preliminary data likewise reveal no deaths due to cirrhosis of the
LIVER. life HAVE NO CASES OF ACROOSTEOLYSIS.
At the present time, we are unaware of any living employee who has
JI
*
BEEN EXPOSEDJO VINYL CHLORIDE SUFFERING FROM CANCER OF THE LIVER.
n :
Likewise], we*know of'no case of cirrkoiss of the liver in employees
EXPOSED TO VINYL CHLORIDE. HOWEVER, THIS INFORMATION IS INCOMPLETE
AND IS BEING SUBJECTED TO A CRITICAL SEARCH.
AP00022851
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PRELIMINARY STUDIES IN TWO MAJOR MANUFACTURING LOCATIONS, WIT:! THE LONGEST HISTORY OP VINYL CHLORIDE PRODUCTION, REVEAL HO INCREASE IN ABNORMAL LIVER FUNCTION TESTS ADOVE THAT EXPECTED IN A SIMILAR UNEXPOCXD POPULATION.
%
C. G. KRAMER, M.D. AMD J. E. MUTCHLER PUBLISHED IN THE AMERICAN
INDUSTRIAL HYGIENE ASSOCIATION JOURNAL IN 1972, A STUDY OP VINYL
CHLORIDE WORKERS IN ONE LOCATION. FINDINGS SUGGEST THAT REPEATED
EXPOSURE TO VINYL CHLORIDE AT TWA LEVELS OP 300 PPM OR! ABOVE
FOR A WORKING LIFETIME TOGETHER WITH A VERY LOW LEVEL OF...
. ?/- -
VINYLIDENE CHLORIDE MAY RESULT IN SLIGHT CHANGES IN CERTAIlF PHYSIOLOGICAL AND CLINICAL LABORATORY PARAMETERS'. THE POSSIBILITY
'
*
OF SOME IMPAIRMENT IN LIVER FUNCTION MUST BE CONSIDERED.^ EVEN.,;';
THOUGH NO OVERT CLINICAL DISEASE 'WAS EVIDENT IN ANY OF THE
INDIVIDUALS STUDIED. THIS STUDY SHOWED A DEFINITE DOSE-RESPONSE '
CORRELATION BETWEEN THE INTENSITY OF EXPOSURE AND THE DEVIATION
./
FROM NORMAL VALUES. ' ,
V
VE WILL CONTINUE TO COOPERATE WITH THE MANUFACTURING CHEMISTS ASSOCIATION IN THE TABERSHAW-COOPER STUDIES. ADDITIONAL IN-. DEPTH 'STUDIES WILL BE CONTINUED WITHIN THE VARIOUS MANUFACTURING UNITS'OF THE COMPANY AND WILL BE REPORTED UPON WHEN COMPLETE.
AP00022852
' l.-,
vt*4:
'
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* **
IV. INDUSTRIAL HYGIENE MEASUREMENTS OP VINYL CHLORIDE IN WORKPLACE
DOW HAS MONITORED THE WORKPLACE ENVIRONMENT BY A VARIETY 0? TECHNIQUES, INCLUDING:
(A) CONTINUOUS MONITORING OP REPRESENTATIVE OH SELECTED WORKPLACE AREAS BY A COMBUSTION - CONDUCTIVITY
' ANALYZER. (B) "GRAB" SAMPLES OF WORKPLACE AIR COLLECTED IN
' IMPERVIOUS PLASTIC BAGS OR ACTIVATED CARBON-"SLUGS" (ABSORPTION). ANALYSIS OF SUCH SAMPLES IJ^NOW ' * ' GAS CHROMATOGRAPHY, BUT YEARS AGO ANALYSIS..WAS .fY^y '?
DETERMINATION OF TOTAL CHLORIDE OR BY
.
SPECTROSCOPY.
.
(C) PERSONNEL MONITORS BASED ON ABSORPTION ON ACTIVATED
CARBON SLUGS, FOLLOWED BY GAS CHROMATOGRAPHIC ANALYSIS.
MONOMER PLANT #1 STARTED OPERATION IN 19*16. HISTORICALLY, SPOT
SAMPLING WAS CONDUCTED. LOADING OF TANK CARS, COLLECTION OF
SAMPLES FOR PRODUCT ASSAY AND DISTILLATION OPERATIONS WERE THE e
ONLY TASKS WHICH NEEDED ATTENTION IN THE EARLY OPERATION OF
THIS PLANT* V4 IN11972, AN EXTENSIVE INDUSTRIAL HYGIENE SURVEY WAS CONOTu^EDi ^MULTIPLE GRAB SAMPLES WERE COLLECTED IN IMPERVIOUS
*.*Sw5a*v4j--'r-' *
PLASTIC BAGS AND ANALYZED BY GAS CHROMATOGRAPHY. THE FOUR
CONTROL OPERATOR CLASSIFICATIONS HAD TWA VALUES BETWEEN 0.2
AND 1,3 PPM. MAINTENANCE EMPLOYEES HAD A TWA VALUE OF 1.7 PPM
AND THE SUPERVISORY EMPLOYEES HAD A TW.A OF 1.3 PPM. THE LOADING
AP00022853
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operations had a IL*- value of 45 ppm and the la-:o;?atc;:y employees
WHO COLLECT SATPLES FROM STORAGE TANKS HAD A TVW OF 1{\ PPM.
Persc;yjll munitcruig is presently being carried oin* on a systematic .IAND PERIODIC EASIS IN THIS PRODUCTION UNIT. n 1973, ALL TO VALUES
WERE BELOW 10 PPM EXCEPT FOR THE LABORATORY EMPLOYEES WHO HAD Tl'iA
EXPOSURES OF U? TO 30 PPM, A LEVEL WELL BELOV! OUR INDUSTRAIL HYGIENE
GUIDELINE CF 50 PPM.
t
.. >- l
: *
LMonoC'Ier .Plant. started operation.in 1958.
imited surveys yiere^-''
^.?
CONDUCTED IN 1955 AN*D REPEALED Ws RANGING FROM 9 TO 60 PPM.
`
IN-DEPTH SURVEY WAS CARRIED OUT IN 1973, ALL TO VALUES WERE
-j
- -- -it.* 'Me 10 PPM EXCEPT FOR THE LABORATORY EMPLOYEES, IHEIR VALUES WERE BETWEEN*T
10 AND 15 PPM,
>
Fbrmi Plant #5 began operation in 1969.' In a 1973 - 1974 personnel MONITORING STUDY, TO VALUES RANGED FROM LESS TON 1 PPM TO 10 PPM.
'J
O P *1 1946 1972. 1950lr polymer lant
was operated from
to
Between
and
1959 L' ^T Asevera indust al hygiene surveys were conducted. . number of job
CLASSIFICATIONS fPOLYMER IZER OPERATORS, DRIER OPERATORS, MONOMER STILL
OPERATORS,'AND MONOMER TRANSFER OPERATORS) HAD WORKPLACE ENVIRONMENTAL
LEVELS RANGING FROM 50 TO 335 PPM VINYL CHLORIDE, AFTER INSTALLATION OF
A CONTINUOUS ANALYZER -
*'
Y" . ;
' wt1;
AP00022854
.'*.\fVi*j''iSw-ae-^-Ui. -17-
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FOR TIE WORKPLACE AIR IN 1533, UTRCVEP2NTS WERE ACHIEVED, ViNYL CHLCfllUE TO VALUES RANGED FROM 25 TO 85 PPM DURING THE PERIOD 19-30-1557,
Our PRESENT FOLYf-ERIZATICN PLANT.# POLYMER PLANT NUMBER TWO, BEGAN OPERATION in 1953* Historically the TO values have been decreased over this period
of tike. In the early history, TO values of 103-240 ppm were observed.
Diking 1975, TO values for vinyl chloride in the air were in the 1 to 25 ppm
.r
We EMPHASIZE THAT THERE IS SOME VARIATION IN TO VALUES FRCM DAY TO'
:
INVOLVED IN LOADING OPERATIONS HAD TO VALUES RANGING FROM 8 TO 31 PPf-TT
Vfe ENCOURAGE RECOGNITION THAT SUCH VARIATION WILL OCCUR IN NORMAL DAY TO DAY
OPERATIONS INVOLVING TRANSFER OF MONOMER.
-f~
- -.< ' *
Vfe ARE INCLUDING REPORTS ON A NUMBER OF OUR -INDUSTRIAL HYGIENE MONITORING
STUDIES AS WRITTEN SUPPLEMENTS TO THIS STATEMENT.
Appendix II.
ThESE ARE LABELED
fe^t..iie> r;/^
In SUMMARY* THE INDUSTRIAL HYGIENE DATA SHOW THAT LEVELS OF EXPOSURE BELOW
50 PPM ARE ATTAINABLE IN BOTH PRODUCER AND USER PLANTS- OF VINYL CHLORIDE.
l!
AP00022855
pL ft -. ^ ,.
.. ^ -
rM.
HtVvW^MffV
It must be noted, hcwevcPw that with older rums the achievement OF SUCH GOALS HAY EE DIFFICULT, AND IN ALL PROD/31 LITY WILL REQUIRE MAJOR MODIFICATIONS THAT WILL TAKE TIME TO ACCOMPLISH,
F
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AP00022856
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V. SATuTY iii HE Vliril GLGiUDE IilDliSHY
The operation of a safe plant involving the handling of toxic, hazardous MATERIALS REVOLVES AROUND:
1. ESTABLISHMENT OF SAFE, PRACTICAL ALLOWABLE
ENVIRONMENTAL LEVELS. 2. Il-PLEHENTIHG APPROPRIATE ENGINEERING AND
OPERATING PROCEDURES TO ACHIEVE OR BETTER THESE LEVELS. 3. Providing analytical monitoring capability to
INSURE THE FWIRONMENT IS MAINTAINED BEUM THE
ESTABLISHED LEVELS AND TO-DETECT EXCURSIONS
ABOVE SUCH LEVELS. 4. Initiating appropriate corrective action when
- 5.
BREAKDOWNS OCCUR AND GUIDELINES ENVIRONMENTAL *'
' . .....
..
-! -f~
LEVELS ARE EXCEEDED. . - .
Developing, and supporting an appropriate medical
surveillance program.
VitSA
tVi. f . '*:*>. r ,iHi` Dow tfAS A^SAFHTY"philosophy THAT THE SAFETY OF OUR EMPLOYEES, OUR CUSTOMERS AND
CUR wEIGHBORs IS OF PRIME AND OF UTMOST IMPORTANCE. THIS SAFETY PHILOSOPHY PERFEATCS OUR OPERATIONS, To ACHIEVE OUR GENERAL SAFETY GOALS FOR VINYL CHLORIDE OPERATIONS AND TO ACHIEVE A GOAL THAT INDUSTRIAL EXPOSURE TO VINYL
- Vi- '
AP00022857
rs kept l;:lcw 50 riM or* a tif.: weichted am:ragz, we irz.c i:?iZE2nED 1HZ rc;.Lc.,'i;;o design and ehgi.ncERIuS principles for VINYL CHLORIDE CFEPATIC.N3:
L* Processing systems are closed with no open vessel operatic:;.
2, CuREEi!T BUILDINGS WHERE VINYL CHLORIDE IS MANUFACTURED
OR POLYMERIZED ARE OPEN TO THE ATMOSPHERE OR HAVE VENTILATION TO MINIMIZE CONCENTRATION BUILD-UPS, 3, Engineering design emphasizes reasonable process
AUTOMATION AND REASONABLE REMOTE OPERATION IN ORDER TO MINIMIZE PERSONNEL EXPOSURE,
?
~
~
& VBfT EXHAUST SYSTEMS ARE SELECTIVELY LOCATED TO *
MINIMIZE THE POSSIBILITY OF PERSONNEL EXPOSURE,
5, Tf NUT-3 ER AND QU/ViTITY OF SAMPLES FOR CONTROL
'V ` > -
^ ANALYSES ARE MINIMIZED,
n . ' Careful application of the above principles has led essentially to the ^ ATTAINMENT CF OUR GOAL OF TiiA VALUES OF LESS THAN 50 PPM IN OUR OPERATIONS,
LI -Ife BELIEVE THAT GOOD opiating procedures must be tailored to each specific PLANT# THAT PLANT SIZE, AND THE NATURE OF THE PROCESS AND PLANT LOCATION
ALL WILL. INFLUENCE 77TE EXACT PROCEDURES TO BE CARRIED OUT, I WILL MENTION
AP00022858
i
i i i i i j
ri> | \
A fen cf the forf. ir-rcFr rr c-zp.uir~7
and techniuls
FOR ONE OF OUR MONOMER P
ic:i planis to illuotrate the complexity of
0:00 plant cpe-ation.
1; EMPLOYEES ARE F/'JTILI/UTIZED WITH B-ERG3ICY PROCEDURES A AND SKILLS; rCR EXAMPLE/ WIND DIRECTIONAL SIGNALS, HORN EMERGENCY CALLS, A' EVACUATION ROUTES,
2, Collection cf analytical samples of vinyl chloride
FROM STORAGE TANKS INVOLVES A CLOSED LOOP SAMPLING SYSTEM .IN ORDER TO RETURN VINYL CHLORIDE TO THE PROCESS RATHER THAN VENTING VAPOR IN THE WORKPLACE ENVIRONMENT, LABORATORY SAMPLES CF VINYL CHLORIDE
ARE HANDLED IN HCCD5 AND SAMPLE CYLINDERS ARE GROUNDED WHEN DISCHARGED. ON-LINE GAS CHROMATOGRAPHY
IS BEING USED EXTENSIVELY TO MONITOR PRODUCT PURITY AND PROCESS OPERATION; THIS HAS REDUCED MARKEDLY THE NUMBER OF MANUAL SAMPLE COLLECTIONS REQUIRED,
3, Specially designed vapor equalizing lines
o CONNECTED BACK TO THE STORAGE TANK ARE EXPLOYED IN THE LOADING OF TANK CARS..
*1. .Environmental monitoring of air is being conducted
BY A MI-3ER CF TECHNIQUES. GaS DETECTOR ALARMS ARE
LOCATED THROUGHOUT THE PLANT AT A NUMBER OF STRATEGIC
AP00022859
22- -
LOCATIONS TO
or ANY FLAT:'ABLE CCNCEffTTATICNS.
Portable rziEcrcr: instruments ape available for
checking plant /alas cr process ecuif.ment prior to us-,'-routine operations and procedures. Air
OAL1TT SUT-EYS WERE CONDUCTED IU J4C.WER PLANT
nifuer 1 in 1971. Dicing the first quarter of
J27lh A CONTINUOUS ANALYZER SYSTEM FOR 12 STRATEGIC LOCATIONS iri THE PLANT WILL EE INSTALLED. THIS
WILL PROVIDE CO!.71 NIDUS BACKGROUND INFORMATION AND PROVIDE INSTANTANEOUS SISALS FOR ANY UN USUALLY HIGH CONCENTRATIONS THAT MIGHT OCCUR DUE TO LEAKS, SPILLS OR OTHER NpN-ROUTINE SITUATIONS. *'
'& * i.V.
In our pdlykeri z\tion operations, we have not had problems of worker ILLSS FROM THE CLEANING Or POLYMERIZATION VESSELS. We UTILIZE HIGH
PRESSURE WATER JETS AFTER EACH POLYMERIZATION REACTION TO PREVENT POLYMER BUILD-UP. Our EMULSION POLYMERIZATION KETTLES RECUIRE MANUAL CLEAN-CUT EVERY TtO CR THREE MONTHS. AFTER WATER CLEANING OF THE VESSEL, ALL LINES
ARE BLANKED TO PREVENT ANY MATERIAL FROM ENTERING THE VESSEL; THE A7K03PHERE
IS TESTED FOR OJCVGEN SUPPLY, AND A CONTINUOUS VINYL CHLORIDE MONITORING ,
50mm IS PUT INTO THE VESSEL. CONCENTRATIONS MUST EE BELOW
PPM PRIOR
AlRTO VESSEL ETTRY.
PURGE IS MAINTAINED ON THE VESSEL DURING THE CLEANING
OPERATION,
r=
AP00022860
FOUR METHODS ARE AVAILAj'L.** FOR E: ,"/] RCNHBrTAL monitoring of air for the n.zs::::a: c.* vinyl chloride:
1. Cc.'-3L'ST! c: :-cc: cxcir/nv
2* Gas a:RCMA7Cr.?HY 3. INFRARED SPECTROPHOTOMETRY 4. FLAf'iE IONIZATION SPECTROPHOTOMETRY
GAS CHROr'ATOCRAFHY IS VERY SPECIFIC, BUT REQUIRES A3CUT 10 MINUTES per sample. Flam- ionization detectors have no specificity-responding ''
TO ALL CARBCN-CARSCN OR CARBON-HYDROGEN BONDS, BUT ARE PORTABLE AND THE KEASUREKHJJT IS INSTANTANEOUS. THE CGM2UST 1 CN"CONDXTI VITY METHOD RESPONDS
ITO ANY MATERIAL WHICH BURNS TO PRODUCE IONS, t RESPONDS RAPIDLY, INFRARED
ANALYZERS ARE VERY SPECIFIC, RESPOND QUICKLY AND ARE P0RTA3LE, ALL OF
THESE TECHNIQUES HAVE ADEQUATE SENSITIVITY, DETECTING CONCENTRATIONS OF
1 PPM,
Personnel monitoring is achieved through use of absorption tubes filled with .ACTIVATED CARBON, THE ABSORBED CHLORINATED HYDROCAR30NS ARE DETERMINED DY
GAS CHROMATOGRAPHY AFTER THERMAL RELEASE OR EXTRACTION BY CARBON DISULFIDE.
At Dow, most of our emvircnmental monitoring has been with combusticn-
CONDUCTIVITY ANALYZERS, Vfe HAVE USED THESE ANALYZERS FCR CONTINUOUS MONITORING
SINCE 1930 WITH EXCELLENT RESULTS,
*
AP0002286f
vii. raaiBEATtes roR 0v,`\;:3f[-];;r.5i:;Y actei
i i
.n
D:w1. urcgs 0S!:\ to recognize the yole.taty industry
actio:; to lower 11:5 levels of exposure to vinyl
CHLORIDE AND THE LEAD ROLE OF INDUSTRY IN OBTAINING DATA ON THE VINYL CHLORIDE PROBLEM,
2, DCW BELIEVES THE INDUSTRY RECOGNIZES TVS. NEED TO MAINTAIN BT/IRCXMELTAL LEVELS BELCH THE OSPA STANDARD OF 500 PPM ANT) EVEN BELOW THE ACGIH RECQMMENDATION OF 200 PPM.
3. Dow believes that it is industry's and government's
RESPONSIBILITY*TQ INFORM ALL EMPLOYEES OR PERSONS WORKING WITH VINYL CHLORIDE ABOUT ITS HAZARDS AND TO DEVELOP AND IMPLEMENT TRAINING PROGRAMS TO HELP PREVENT OVER EXPOSURE AND INSURE PROPER REACTION IN EMERGENCY SITUATIONS. V'E BELIEVE INFORMED-EMPLOYEES WILL CO OPERATE IN ELIMINATING OVER- EXPOSURE MID SUGGEST METHODS FOR IMPROVEMENT.
4. . Based upon the medical and toxicological data available TO U3 AT THIS TIME, DOW BELIEVES THAT AN EIGHT-HOUR TWA OF 50 PPM IS A SATISFACTORY ENVIRONMENTAL STANDARD FOR VINYL CHLORIDE.
AP00022862
INHALATION, METABOLISM
EPIDEMIOLOGICAL STUDIES IN
O.UER TO CD7AJN THE HOST PRECISE DATA POSSIBLE RELATING
TO TIE POTENTIAL FOR OCCUPATIONAL HEALTH ASSESSMENT,
(a) We WILL STRONGLY SUPPORT INTUSmY-GOVERNMElfT
f
EVALUATION OF THE DATA AS IT BECOMES AVAILABLE.
Cb)
Results of the epidemiological survey of vinyl
CHLORIDE WORKERS INITIATED ABOUT A YEAR AGO BY" MCA VIA CONTRACT WITH TaEERSMW-COOPER WILL BE AVAILABLE IN THE NEAR FUTURE. It SEEMS REASONABLE
TO EXPECT THAT THESE RESULTS WILL PROVIDE ' ADDITIONAL AND SUBSTANTIVE BASIS FOR RULE-MAKING,
DOW BELIEVES RULE-MAKING SHOULD NOT BE BASED ON CONDITIONS THAT EXISTED IN THE PAST BUT SHOULD BE BASED ON CONDITIONS AS THEY EXIST TODAY, BASED ON NI OSH ACTIVITY AND ON WIDESPREAD VOLUNTARY ACTIONS BY INDUSTRY, WE BELIEVE THERE IS NO NEED FOR A TEMPORARY EMERGENCY STANDARD. REALISTICALLY, WE BELIl?/E A TEMPORARY EMERGENCY STANDARD WOULD RESULT IN
POLARIZATIONS RATHER TON CONSTRUCTIVE DEFINITION OF AREAS
OF CONCERN AND CONSTRUCTIVE PROBLEM SOLVING.
AP00022863
-26-
lE BELIEVE {-/XT r^OSUCuRS/L;Ci'.S OF ViiTtL CHLORITE HAVE OR VERY GOGN WILL JAVE THE CAPPD'ILITY TO I'M!,'TAIN A',' EICriT"
TiMs-wEiGhTED average (7VA) of SO ppm or eglow, THERE
FORE WE SUGGEST THAT STEPS EE TAKEN IN ORDER TO DEVELOP THE STANDARD IM A REASONABLE WAY.
In(a)
ORDER TO ASSESS the state and magnitude of the
PROBLEM, WE SUGGEST THAT EACH PRODUGER/USER OF ,
VINYL CHLORIDE COMPLETE AN INDUSTRIAL HYGIENE.
SURVEY OF HIS OPERATIONS AND A MEDICAL SURVEY OF
>
VINYL CHLORIDE WORKERS WITHIN THREE MONTHS AND
REPORT THE RESULTS OF EACH SURVEY TO NIOSH/OSHft.
(b) If THE SURVEY REVEALS T/iA's IN EXCESS OF 50 PPM,
.
THE MANUFACTURER OR PROCESSOR SHOULD IMMEDIATELY TAKE STEPS TO REDUCE EXPOSURE SY OPERATIONAL AND/OR
ENGINEERING CHANGES AND REQUIRE THE USE OF APPROPRIATE
RESPIRATORY PROTECTION BY HIS EMPLOYEES LIKELY TO
t
'(c)
BE EXPOSED TO SUCH LEVELS,
If the medical surveillance program indicates
ABNORMALITIES THAT COULD BE ATTRIBUTED TO EXCESSIVE
EXPOSURE TO VINYL CHLORIDE OR A CONDITION THAT COULD
REASONABLY BE EXPECTED TO BE AGGRAVATED BY CONTINUED
AP00022864
such
n r^CO>''ciJ
ASoISl/VtvE
HI DIFiiilNG THE PRIORITY OF HEALTH PARAMETERS
FOR STUDY.
OSKVsDo.-/ SUPPORTS
ESTA2LI SKYENT OF A PERMANENT HEALTH STANDARD
FOR VINYL CHLORIDE BY REGULAR RULEMAKING PROCEDURES.
Vfe RECOMMEND 7}{AT THE STANDARD STATE V.HAT SHOULD EE. ACCOMPl.1SHFD,
LEAVING THE "t-CVMO-ACHlEVE CCr-PLIANCE" TO INDIVIDUAL PLANT ?
IMPLEi'cHTATIOrJ,
s
AP00022865
INDUSTRIAL KYGIEE SURVEYS EWOLVIiffi VINYL CHLORIDE
A, Summary Tables for Environmental Levels of Vinyl Chloride in Industrial Operations,
B, Industrial Hygiene Engineering and the Process-Environment
E.System. J.
Mjtchler. Am. Ind. Hygiene J. 31, 233, 1970, ^
C. Monitoring Exposures to Vinyl Chloride Vapor: Breath
E. D. R. D.Analysis and Continuous Air Sampling.
Baretta,
E. A . 537, 1969,Stewart, J.
Mutchler.
m Ind, Hygiene Assn, J.
D. The Application of Computer Science to Industrial Hygiene.
E. E.J, Rtterson, H, R. Hoyle, J, Schneider.
J.Hygiene Assn,
27, 180, 1966.
Am. Ind.
j
AP00022866
SIH'ARY TABLES Or EiVIRGE'EUTAL LEVELS OF VINYL OiLCRIBE IN
INDUSTRIAL OPERATIONS
Dow Chemical U.S.A.
Midland, Michigan February 25, 197^4
AP00022867
Table I
INDUSTRIAL HYGIENE SURVEYS OF VINYL CHLORIDE LEVELS IN MONOMER PLANT NO. 1
4
JOB CLASSIFICATION
TWA, PPm Vinvl Chloride *
1972
- 1973
. 1st Qtr 3rd Qtr 4th Qtr
Control Opr. 1
0.7 1.1
3.6
3.1
Control Opr. 2 Control Opr. 3
0.6 2.4 0.2 9.5
N.D.** 3.3
oCO.
1.0
Control Opr. 4
1.3
N.D.**
0.6 \
2.3
Loading Opr.
45 2.5 0.5 0.2
Lab Tech.
14 6.8 30 27
Maintenance
1.7 4.7 0.4 4.8
Supervisory
1.3 0.8 0.4 2,3
* slug samples, 6.5 hour personnel monitors--analyzed by VPC o
** not detected
AP00022868
I f 1
Table II
INDUSTRIAL HYGIENE SURVEYS OF VINYL CHLORIDE
levels in monomer plant no. 2
JOB CLASSIFICATION
TWA, ppm Vinyl Chloride*
1973
Laborer Millwright Electrician Pipefitter Operator 1 Material Controller Operator 2 Instrument Tech. Loader Operator Lab Jr. Op. Technician Quality Control Tank Farm Operator
i Lab Op. Technician Shift Supvr. Shift Supvr.(day) Sample Man
4.5 4.4 3.5 4.5
0,6
Q.l 2.4 1.5 4.2 IQ.3 2.3 3.0 2,9 15.1 Q .4 0.4 0.7
',
*slug samples analysed by VPC
i
AP00022869
-Table III
INDUSTRIAL HYGIENE SURVEYS OP VINYL CHLORIDE LEVELS IN MONOMER PLANT NO. 3
JQ3 CLASSIFICATION
TV/A. ppm VINYL CHLORIDE*
Control Opr. 1
1.0
Control Opr. Control Opr. 3
N. D.#
O. 1
Maintenance
0.1
Supervision
N. D.#
Laboratory
10.4
Loader
2.1
Distillation
o
O.015 -
^absorption on slug - 8 hour sample analyzed by VPC (1973-74 survey)**
**none detected
AP00022870
4
Table IV
INDUSTRIAL HYGIENE SURVEYS OF'VINYL CHLORIDE LEVELS IN POLYMER PLANT NO. 1
JOE CLASUiFTCATION
Polymer Si Dry in q 'Foremen L Crev/ Leader
Color & Elendinq Foreman Shipping Clerk Utility'Man Mechanic Packer, Ass't Opr, Shift Miller Polymer Ass*t Opr,' Alternate, Spare, Class 1 & 2 Opr. Dryer Opr.
C
Monomer Still Opr. Flash Dryer Opr. Tank Car Unloader, Monomer Transfer Man
TWA, Dpn Vinyl Chloride*
1950 - 59*
.1960 67**
10-50
5 5-10 5-10
so;
10
5 5 5 25
`M l # .
i
`r\
5-10
5
120 - 385 95 - 350 50 - 85 15 - 150
100
25 - 80 25 - 85 25 - 45 10 - 15
25
* grab samples, total halogen calculated as vinyl chloride.
** continuous analyzer for total halogens calculated as vinyl chloride.
AP00022871
Table V
INDUSTRIAL HYGIENE SURVEYS OF VINYL CHLORIDE LEVELS IN POLYMER PLANT NO. 2
JOB CLASSIFICATION
Foreman Utility Janitor Handyman Spare Alternate Blender-Packer Tank & Wheel Opr. Dryer Opr. Polymerizer Opr. Clerk Mechanic . Pumping Opr.
o
TWA, ppm Vinyl Chloride* 1953 -- 59* I960 - 66** 19 67 ** 1973'* <> *
5 - 10
5
5 1-5
10 10 10 1 - 5
'10
5 - 15
10
1-5
10
5 - 15
10
1- 5
30 - 40
30
1-5
50 - 65 10 - 25 .
30 - 50 10
---
1- 5 5
125 *- 140
140 - 240 80
kick
50 - 60
35 - 105 35
1-5
50 - 65
30 - 50
30
5 - 25
5 5 5 1-5
50 50
50 1 - 5
4.1
* grab samples total halogen calculated as vinyl chloride.
**(continuous analyzer for total halogens calculated as vinyl chloride.
*** process changes with a change of job classification - slug absorbent samples analyzed by VPC.
AP00022872
Table* VI
VARIABILITY IN VINYL CHLORIDE LEVELS ON A DAY-TO-DAY BASIS - POLYMER PLANT NO. 2
Operator
1 2
3
Job Pumping Pumping Pumping
Hours 6 7
ppm Vinyl Chloride 0.98
IX. 5 34.0
1
Loading
6
2
Loading
7
3
Loading
6
1.0 28.0
1.1
Operator
ij
1
Loading
5
n
2
Loading
7
3
Loading
6
8.0 25.0 31.0
(Data collected by operator wearing a sampling device
J
on belt during course of his normal operations.)
'~1
AP06022873