Document jBdbpKVkQEjYmQ0YbdkGp1Qoy

(CONOCO Interoffice Communication To All VCM Plant Employees From C. E. GremilUon Date May 22, 1974 Subject VCM Air Sampling Continued VCM Air Sampling using the Personal Monitoring Devices will resume beginning this week* The schedule for the testing is attached. You will note that the majority of the testing during the next several weeks will consist of leadmen and supervisors. This is necessary to obtain sample data for all plant employees. You will be contacted when you're scheduled to wear the apparatus. The same procedures specified in the earlier letter on this same subject apply relative to personal monitor wearing, malfunctions, etc. Please direct all questions and/or comments to the undersigned. C. E. Gremillion Safety Director brc Distribution Bullentin Boards VVC 00000254Q CIRCULATE TO: RETURN TO PLANT MANAGER'S OFFICE VVC 000002549 THE NEW YORK ACADEMY OF SCIENCES WORKING GROUP ON TOXICITY OF VINYL CHLORIDE-POLYVINYL CHLORIDE "ENVIRONMENTAL CONCERNS BEYOND THE WORKPLACE" Glenn E. Schweitzer Director, Office of Toxic Substances Environmental Protection Agency 401 M Street, S. W. Washington, D. C. 20460 Copies for: RWG JDBu JJL LNV KLS JDBr JFP WRBe OCK AJLu WRS DVP (EAS REL) RCA RDG EMS Okla. City vvc o 00002550 Presentation to the Working Group on Toxicity of Vinyl Chloride-Polyvinyl Chloride The New York Academy of Sciences New York City, New York May Tl, 1974 "ENVIRONMENTAL CONCERNS BEYOND THE WORKPLACE" Glenn E. Schweitzer Director, Office of Toxic Substances Environmental Protection Agency Washington, D. C. During the past several months vinyl chloride has awakened all elements of the environmental community to the presence of the plastics industry. In some respects it is fortunate that we have been alerted in a rather dramatic fashion to the need for greater attention to this important segment of our industrial base which will surely continue to expand in the years ahead. While this symposium is directed to the existing and potential risks involved in the manufacture, distribution, and use of vinyl chloride monomer (VCM) and polyvinyl chloride (PVC), many of the types of considerations and uncertainties that punctuate these deliberations undoubtedly characterize a far broader swathe of concerns over chemicals in general. Hopefully, we can extrapolate from our current experiences with VCM and PVC in identifying problems with other potentially important commercial chemicals early in their embry onic stage and thus minimize the economic dislocations attendant to corrective actions. Unfortunately, the proposed Toxic Substances Control Act has been lodged in a Joint Committee of the Congress for ten months. Thus, a very powerful tool for addressing the vinyl chloride problem, and similar problems with other chemicals, in an adequate manner is not available to the Federal Government. We must rely on other statutory authorities and on the power of persuasion in our efforts to insure that our population is not being unnecessarily exposed to concentrations of VCM and other chemicals used in connection with VCM. It is particu larly distressing that until this statutory authority is on the books, the Federal Government will not be equipped - in terms of experienced personnel and supporting resources - to grapple with the intricacies of this type of toxic substance problem in a manner which will insure full attention to the balancing of risks and benefits. Today I will report to you on the preliminary investigations under taken by the Environmental Protection Agency during the past three months. We are still several weeks away from reaching even tentative conclusions as to what additional steps, if any, should be taken by the Agency concerning VCM/PVC activities. Our monitoring data are not yet VVC 000002551 in hand. Similarly, our analytical studies are not yet completed. Nevertheless, we are pleased to share with you some of our initial thoughts. We will welcome your comments on the efforts to date and on further steps which are necessary. In this regard, the prioritization of our efforts is particularly important in view of the speed with which this problem is evolving and the limitations on our resources. At the outset it is important to underscore that the progress made to date would not have been possible without the extensive cooperation of other federal agencies, industry, and environmental groups. We have profitted greatly from our discussions with these organizations, through our on-site industrial visits, and through constructive suggestions that we have received. EPA Regulatory Authorities To date EPA has exercised its authority in the pesticides area to suspend the use of vinyl chloride as a propellant in all pesticide pro ducts registered for indoor use in homes, food handling establishments, hospitals, and other enclosed areas, with a mandatory recall of stocks in the channels of trade. In addition, in response to the Agency's request, all registrants of pesticides which are used outdoors have agreed either to withdraw their registrations or to amend them to provide for the substitution of another propellant in their products. We are currently investigating what regulatory actions, if any, are needed with regard to air emissions, water effluents, and solid waste disposal at facilities involved in VCM and PVC activities. In addition the Agency has responsibility in the areas of drinking water standards, ocean disposal, and municipal waste disposal -- all areas of some relevance to the VCM/PVC concerns. As previously mentioned a principal authority which is currently missing is the Toxic Substances Control Act. The requirements for reporting of industrial production data envisaged in the Act would enhance our knowledge of the types and extent of different uses of VCM. The testing provision would enable us to obtain much needed data -- and particularly data on toxicity and persistence -- for assessing the risks associated with low concentration levels of VCM, including those levels that are likely to persist beyond the workplace. The proposed regulatory provisions would provide a mechanism for addressing those products using VCM not now subject to regulation under other laws. Also, if considered appropriate, steps might be taken to limit the amount of unreacted VCM in certain PVC products which may eventually migrate out of these products to pose an unnecessary risk. VVC 000002552 2 The Materials Balance EPA's initial concern in this area centered on reports in February of a materials loss of six percent in the PVC production process. Our detailed investigations indicate that these initial reports were in the correct range. Clearly, the percentage of losses will vary with the type of process, the age of the plant, the level of technology that is employed, and manufacturing practices. However, there is no doubt that in the United States substantial amounts of VCM -- probably exceeding 200 million pounds annually -- and large quantities of PVC -- probably exceeding 50 million pounds -- are being discharged into the environment during the PVC production process. Most of the VCM escapes directly into the atmosphere as air emissions, with lesser amounts dissolved in water effluent streams and entrapped in sludge and solid wastes. PVC losses occur as particulate in air emissions, suspended solids in water effluents, and components of solid wastes. Clearly, a principal area of VCM leakage is associated with the operation of the polymerization kettles, including losses when they are opened for recharging, cleaning, or sampling. Other losses occur during the transfer of VCM from tank cars to storage, during the drying process, and from leaks at a variety of valves, flanges, and pump seals throughout the process. Polymer losses are similarly distributed among a variety of activities including dust collector losses, disposal of oversize particles, and sampling losses. The enclosed flow diagram for a typical suspension process reflects such losses which according to our estimates usually range from four to eight percent. In this regard two aspects are particularly significant: there are a variety of PVC processes with differing problems and control possibilities, and in every case the number of potential leakage points is very large. For economic reasons and in view of the fire hazard from VCM, industry has always been concerned with reducing its losses down to a point. Now some plants, are taking steps to reduce these losses further in view of worker and environmental concerns. We understand that the tightening up on maintenance and housekeeping activities can indeed have a significant impact, and several PVC plants reportedly are now operating close to the four percent level for total losses. The data needed for conducting material balance analyses during VCM production and PVC compounding and fabrication processes are less readily available. However, we do not believe that these activities pose as serious an environmental concern beyond the fence line of the plant, at least at the present time, as the polymerization process. At the same time in the absence of constant vigilance VCM losses to the atmosphere during the latter phases of the VCM production process and during trans fer to and from storage can be significant. Also, throughout the process there are many seals and valves which inevitably lead to leaks. With regard to compounding and fabrication, unreacted monomer is inevitably vvc 000002553 3 associated with the polymer following the polymerization process. In some cases this monomer concentration reaches 7000 ppm although a more representative level probably is in the range of 500 to 1000 ppm. Dur ing the mixing and heating processes in the compounding and fabrication plants, some of this VCM undoubtedly escapes into the environment. Now, in efforts to reduce further the level of unreacted VCM in the final product many companies are introducing new techniques which increase the migration rates during this phase of production. The Need for Epidemiological and Toxicological Studies Since some elements of our population in addition to the plant worker are being exposed to some level of VCM, we must address the question: What is the risk of such exposure? In considering non-worker populations, we are confronted with a host of new unanswered questions. How relevant to this concern are the data generated for estimating worker exposure risks? Can meaningful extra polations be made from toxicological tests at relatively high dose levels to the lower levels of the dose-response relationship? Can realistic extrapolations be made from intermittent exposure, which characterizes the past and present toxicological and epidemiological investigations (e.g. eight hours per day, five days per week) to sustained exposure at the same dose levels or at lower levels? Are synergistic effects that result from exposure to other chemicals as well as VCM influencing the worker's response to VCM, and are there similar opportunities for such synergism within a non-worker population? There are not sharp answers to these questions, and indeed they go to the heart of many of the fundamental uncertainties of the biological sciences. To date the epidemiological and toxicological data that have been generated have been directed almost exlusively to concerns over workers. This is the data base that we in EPA presently have available. I doubt that anyone is more aware of its inadequacy than are those of us responsible for regulatory actions based on this data. Unfortunately, we often have no choice but to make judgemental decisions using whatever scientific information is available. Other reports presented at this symposium review past, current, and future studies directed to VCM. While they will undoubtedly be helpful to our assessment of the environmental problem, from our point of view they are clearly not adequate in improving the basis for estimating non worker risks. Let me cite three examples of the types of studies which appear to be needed: -- Epidemiological investigations of populations near chemical plants that are likely to have been exposed to low ambient levels of VCM over a prolonged period of time. It is the VVC 000002554 4 responsibility of industry to support sucn efforts which will help clarify whether manufacturing activities pose a ri to neighborhood residents. At the same time we recognize the com plexities involved in designing and carrying out such studies, the advantages of drawing on governmental experience in this area, and the prototypic nature of such an undertaking. There fore, it seems likely that EPA will be prepared to participate in such efforts along with industry and other interested parties. -- Toxicological tests at appropriate dose levels, with a bufriciently large number of animals, and with appropriate exposures to provide the basis for meaningful conclusions concerning the likely health effects of VCM in ambient air near chemical plants. Such tests are clearly the responsibility of industry. Indeed, industrial responsibility for the testing of the safety of its products is a basic tenet of the Toxic Substances Control Act. At the same time, we are aware that some industrial firms are concerned about the possible inadequacy of commercial test facilities to accommodate the needed tests. Therefore, if necessary, the National Center for Toxicological Research, which is supported by FDA and EPA, is prepared to work with industry toward suitable arrangements for utilizing available buildings in Jefferson, Arkansas. -- Research on animals and _in vitro experiments to help clarify the toxicological significance of impurities in VCM, synergistic effects due to exposure to other chemicals in addition bo VCM such as vinylidine chloride, and metabolic reactions induced by VCM. Government, industry, and academia all have responsibilities in this area, and EPA is currently considering specific steps that might be taken to contribute to advancing the frontiers of our knowledge. Monitoring, Persistence, and Migration Studies We are obviously concerned about current and future background levels of VCM in the air and in the water throughout the country. Our more immediate efforts, however, are being directed to determining ambient and peak levels near chemical plants. Recently, we initiated a nationwide sampling and analysis program to determine, at least in a preliminary fashion, the VCM levels in ambient air and in water and semi-solid effluents at about ten PVC plants. These activities are currently underway, and we hope to have the results within several weeks. VVC 000002555 5 As a precursor to this nationwide effort, several weeks ago we conducted a preliminary monitoring program at the B. F. Goodrich plant in Louisville using inadequately tested sampling and analysis methods. At that time VCM levels were detected of 1 to 2 ppm in the ambierr, air outside the plant, 2 to 3 ppm in the primary water effluent, and 100 to 200 ppm in the sludge at the plant site. However, these numbers ruuld be in error by as much as an order of magnitude due to the pioneering nature of the effort, and no conclusions should be drawn at this time. During the past several weeks we have made a major effort to develop credible and standardized sampling and analysis procedures, building on this initial experience. Our current monitorinq efforts are based on this recently improved methodology. The limit of detection for our current technique is approximately .06 mg/liter in water and .06 ppm (volume/volume) in air. However, when vacuum cans are used, the detection limit is .2 ppm because the gas sample must be diluted, 'he technique we are using is now publicly available with the hope that our efforts toward standardization will lessen the chaos characterizing current monitoring efforts of several federal agencies and industry. While the near-term objective of these monitoring efforts is to gain a limited perspective of the levels of VCM near PVC plants, we should also learn more about the persistence of VCM in air and water from our measurements. Samples are to be taken during daytime and at night, and there undoubtedly will be a range of temperature and humidity conditions. However, we have not structured the measurements with research as a prin cipal objective, and we will not be able to quantify persistence char acteristics witn any degree of precision. Limited laboratory experiments are also being attempted to clarify persistence characteristics of VCM. Related to our decision to suspend pesticide sprays containing VCM, one laboratory test showed that in an unventilated and unlighted chamber, less than one percent of the VCM initially present was dissipated after four days. Current efforts are directed to clarifying the rate of retention of VCM entrapped in water effluent streams, as well as further work to understand the effect of light, heat, and moisture on VCM in air. There has been considerable discussion of the amount of unreacted VCM monomer remaining in PVC and the rates of migration out of the PVC. Many companies are now seized with this problem, and I suspect the number of samples being taken to determine VCM concentrations and migration rates has increased considerably in recent weeks. We do not know whether such migration from finished products contributes significantly to back ground levels of VCM, but as you are aware FDA is seized with several aspects of this problem directly related to food. Should there be hiqh levels of VCM background in the environment, then our concern over all sources of VCM -- including migration from many products -- should intensify. VVC 000002556 6 In all of these areas industry has a major responsibility determining and alerting the public about the behaviour of its products. I would hope that in the months and years ahead industrial monitoring efforts at the fence line will increase dramatically; persistence mill become a key concern; and the ultimate fate of chemicals will be less uncertain. Already some chemical establishments have rather broad sampling and analysis programs, and as a direct result of VCM conc-mis, others are also making new efforts in this regard. At the same time EPA has a responsibility to help insure the adequacy of the national effort in keeping abreast of the chemical crosssection of our environment. Concerns over Disposal of PVC While we tend to lump all types of PVC into one category, 1 am sure you are aware of the variances in the chemical and physical properties of different grades of PVC. Also, end products made from PVC include a variety of other chemicals which are added throughout the production cyrl To date EPA's principal concerns relating to PVC have been dieted to possible problems attendant to its disposal -- either in incinerators or landfills. We have not investigated in depth any of the speiial problems associated with inhalation or ingestion of low concent* c f.ions of PVC particulate. With regard to incineration, HC1 is a primary product of concern. Also, toxic metals may be present as additives and thus cause inhalation problems, either as metal or oxide vapors. Landfill disposal operations have traditionally assumed that PVC is stable with little likelihood of biological degradation or undent^ b'e leachates. Taking a long-term perspective these assumptions se^rr. Itariy overly simplistic, and we should address in greater depth problems attend ant to the disposal of plastics. Experiences in the tropics, tor sample, have demonstrated the effect of bacteria on PVC which has not been specially treated for use in humid areas. The Risks, the Benefits, and the Costs The current problems with VCM have brought into sharp focus ere practical aspects of balancing the risks and benefits associated vim commercial chemicals. The costs involved to reduce these risks substan tially may be formidable -- or indeed may be prohibitive. 1 he aspect which is perhaps the most troublesome goes to the heart, of this meeting What is the risk now and under alternative regulatory approaches? 000002557 vve 7 In the years ahead more chemicals will be in commerce, the pro perties of many chemicals will be better understood, and consequent!1; the list of chemicals considered to be hazardous to man and the environment will undoubtedly be much longer. Also, improved research and analytical capabilities will show that the effects of these chemicals -- acting individually and synergistically -- are much farther reaching than currently suspected effects. As these realities of the chemical age unfold, there must be a far greater sophistication in approaches to responsible regulation. Hope fully, we will develop the necessary precautionary measures that will limit exposure to chemicals when necessary, but not unnecessarily cur tail commercial activities. VVC 000002558 8 HAY CQRTMK 01000 PPH W tWACTWHYC 9 2 us 00 UJ OO CO O o RO MJ H- CO MJ > cs c <tZ~ s 1 bu IDS a. o 3 a u 3 2 eg ac BASIS: 1QCLB. MXtftTD HYC iXTCPUaf COooK From the desk of R. S. MATHEWS vvc 00002S60 SKYTOP Telephone: 717-595--7401 Conoco Group Secretary--Dictation Separate Copies to: L. N. Vernon K. L. Schurter Per your telephone request, the history, status, and recom mended position on EPA action follows: 1. EPA sent letters to all VCM and PVC manufacturers including our three plants asking for a considerable amount of data. These letters are dated May 30 and ask for response by June 14. 2. Agency is "gathering information for possible use in develop ment of air pollution control standards for VCM in accordance with the Clean Air Act of 1970." EPA is now taking samples of ambient air near plants and data will be made public as soon as processed and verified. At present, no Federal control standards exist for vinyl chloride. 3. Request is for (a) identification of emission points with quantities, (b) cost and economic data for each emission con trol device, and (c) ambient air data which have been col lected by plants. vvc 000002561 Page 2 Status 1. Call to EPA office in Triangle Park, North Carolina. Mr. Evans verbally granted one week extension for VCM plant and four weeks for PVC plant. 2. Team of supervisory engineer with four engineers and all analytical help needed are at both PVC plants starting the work. VCM plant is in better shape to meet timing required since more work had been done to meet Louisiana state emission requirements. 3. Review discussion held with Legal Department and direction of response based on this review. Legal will review the final document prior to issue. 4. Computer simulation of dispersion from our highest level points in Aberdeen would indicate very low resultant ground level concentrations. Marcus Smith has result from a few samples taken outside fence. Recommended Position From my discussions with EPA office., from Gerlach's discussions with EPA, and from Legal Department, following points emerge: 1. The EPA office is quite aware of the importance of the VCM-PVC industry to the country's economy. VVC 000002562 Page 3 2- The Washington meeting is to put all on notice of the problem and the urgency to obtain a solution. At this point, it would appear to be an appeal for cooperation and to achieve results before emotionalism takes control. 3. EPA office to this point has been most cooperative and anxious to help us understand their request for informa tion . 4. We will not provide any information in the response which will endanger our trade secrets, which will be unrealistic estimates, or which will in any way be uncomfortable to us. Fugitive emission estimates and potential control devices will, for the most part, be covered by discussion rather than quantified. 5. In my opinion, backed by the recent technology survey, the Oklahoma City plant is and can continue to be equal to or better than any competitor in yield and thus in lowest VCM emission levels. 6. OSHA controls or policies inside plant fence and EPA con trols outside. There appears to be some interagency sensitivity? thus I would recommend we speak in Washington to our on-going emission reduction program and not emphasize who the program is for or who caused its initiation. VVC 000002563 Page 4 7. Extension request was based on following: a. Information requested in extensive and requires some sequential steps. Collection and interpretation of data are the starting points. Considerable analytical work is required. Some cost estimating and speculative design work is included. b. We have a Central Engineering group, a Central Analyti cal group, and a Central Environmental group serving the technical needs of our plants. This particular request calls for work at three different locations, and our manpower is -just not sufficient to parallel this work. Legal Department agreed that extension request was in order. 8. My guess at total man-days to fill this request based on Process Engineering requirement alone of 180 man-days is 300 man-days. This would include analytical. Legal, management, etc. R. S. Matthews lkm vvc. ooooo*56* Conoco C 3N 7C3 JC 3< ONCA 7 may 30 CON Tl \'E N TAL OIL CD PONCA CITY OKLA J ,J Lfi-M CHORD - SH R 0 GAM ALIN - LAKE CHARLES CONOCO VCM PONCA 7 MAY 30 CONTINENTAL OIL CO PONCA CITY OKLA J J LAN GOOR 0 - SO R D GAMBLIN - LAKE CHARLES VCM E M SMITH - ABERDEEN Vt E ELLIOTT - HO'JSTDN C H KLUMICK - HOUSTON H R WALL - STAMFORD (Vv/C 000002565 NOTE TO J J LANGFORD - PLEASE HAVE COPIES MADE FOP LNV KLS JFA JFG Juno JOHN ; ATTACHED IS A DRAFT OF CONOCO CHEMICALS* OBJECTIONS TO THE PROPOSED PERMANENT STANDARD FOR EXPOSURE TO VINYL CHLORIDE < FEDERAL REGISTER* page ? or 3 0 BJECTI1 NUTTER PROVISION OBJECT! 0 -! * ECO '-1 M E M d A V I 0 N S G -<0 `.NO S 1 CPU C 6) IT IS OUR POSITION THAT THE "DETECTABLE L VEL" REQUIREMENT STATED THROUGHOUT THE STANDARD IS NOT A FEASIBLE RE9UI RENENT IN VI E W OF EXISTING TECH NOLOGY. HE PROPOSE THAT THIS DEFINITION HE CHANGED TO "BASE LEVEL" AND THATTHE " BASE LEVEL" OF '/CM BE DEFINED AT 40 3PM CEILING CO AND os PPM TINE WEIGHTED AVERAGE CT>,A). SUCH A REQUIREMENT FOR ATMOSPHERIC VCH LEVELS IS, HE HELIEvE, FEASIBLE AY OCTOBER 1974. IT IS OUR INTENTION TO CONTINUE TO STRIVE TO ACHIEVE THE LOWEST POSSIBLE LEVEL OF EMPLOYEE EXPOSURE. IN THOSE OF OUR OPERATIONS WHICH AR BASED ON LARGE POLY ^ERIEATI ON REACTORS, WHICH REPRESENT 65 PERCENT OF OUR CAPACITY, OUR OB JECTIVE IS TO REACH A LEVEL OF EMPLOYEE EX POSURE BELOW 05 PPM ON A TIME WEIGHTED AVERAGE BASIS BY OCTOBER 1974. IT IS ALSO OUR POSITION THAT REDUCTION }F EM: PLOYEE EXPOSURE TO AN AVERAGE LEVEL OF 15 PPM ON A TIME WEIGHTED AVERAGE BASIS SHOULD OE ACHIEVABLE IN OUR OPERATIONS AS A "BASE LEVEL" BY OCTOBER 1975 VVC 000002566 p ARE 3 T-~ (!)( '< ) since the hali:atio-j : = nd detectable level 1F VCM I \' .vO 1KPLACE ENVI RO NMENTS IS NOT FEASI -3L '.vE PROPOSE THAT AN EME AGENCY A E rj&Fl N ED TO RE FLECT a\j UNFORESEEN CI RCUM STANCE OH SET OP Cl RCUMSTANCEs RESULTIN G IM THE RELEASE OF VINYL CHLORIOE J F CHEAT EH THAO AO ALLOWABLE CEILING 10 TO AREAS OCCUPIED TV EMPLOYEES. AN ALLOWABLE CEILING SHOULD BE DEFINED as ATMOSPHERIC CONCENTRATIONS OP VCM HOT 10 EXCESS OP THE CEIL IOC- VALUE. 0 (0X9) CONSISTENT WITH THE COMMENTS MADE ABOVE* PE PEEL THAT EXPOSURE SHOULD PE DEFINED TO DESIGNATE ACTUAL CONTACT PITH VINYL CHLORIDE IN CONCENTRA TION5 ABOVE THE CEILING VALUE* A (A)(SIC) THE PECULATED AREAS DEFINED Iv THE STANDARD ARE GENERAL ENOUGH TO INCLUDE THE ENTIRE PLANT AREA. E PEEL THAT THERE SHOULD PE AT LEAST Tl-,0 CATEGORIES OF LIMITED ACCESS AREAS. FORE EXAMPLE* A REGULATED area is an area ^herein A LIKELY OPPORTUNITY POR EXPOSURE EXISTS AND A CONTROLLED AREA IS AO AREA ..HERETO THERE IS NOT a REASONABLE CHANCE FOR EXPOSURE. THIS WOULD ALLOW THE DEFINITION AMO POLICING OF 000002567 WC HTGH RISK*' REGULATED AREAS* VHILE NOT RF.OUIR- ^ ARr ix i f s 5 (E) mONI TO *1 NO <EBUI CEMENTS SHOULD -LL ) W T-iS -tSE )F MORE SOP 41STICATED SYSTEMS THAN PERSONNEL MOUNTED DEVICES, SUCH AS CO N TI N UO US, FIXED POINT MONITORS. THESE OMITS SHOULD HE ALLOWED AS PRIMARY UNITS WITH PERSONNEL MOUNTED DEVICES SUCH AS BACKUP UNITS. OPTIONS SHOULD EXIST, HOWEVER, TO ALLOW ONLY PERSONNEL MONITORING where continuous, fixed point monitors are IMPRACTICAL. THE ROUIREMENTS OF SECTION (E> C2> ARE UNCLEAR AND NEED TO PE REPHRASED AND DEFINED. ENTIRE SECTIONCE)Co) SHOULD RE DELETED AND REPLACED WITH DNE ALLOWING THE INDIVIDUAL EMPLOYEE AND OSHA EMPLOYEES FREE ACCESS TO MONITORING RECORDS, TECHNIQUES, ETC. ALLOW ING ANY "DESIGNATED REPRESENTATIVE" TO DO THE EXTENSIVE OBSERVING DEFINED IN THIS SECTION A3 IT EXISTS NOW COULD LEAD TO DIFFICULTIES WITH INSURANCE, SECRECY, LICENSING AGREEMENTS, EVALUATIONS BY UNQUALIFIED PERSONS, ETC. 6 CF) 7 (G) ALL ENGINEERING CONTROLS AND /.ORK PRACTICE METHODS INDICATED IN THIS SECTION WOULD PE ACTIVATED BY VCM LEVELS EXCEEDING THE BASE LEVEL. THE WORK "AIRBORNE" SHOULD BE REPLACED BY "ATMOSPHERIC" TO AVOID POSSIBLE CONFUSION. (vvc 000002568 WE PROPOSE THAT FULL FACE PIECE MASKS SHOULD TO f * < H) 9 CK) THE REM'JI RECENT THAT -3 ER HO N N IiL H - E J UI < E 0 TO WEAR GLOVES r->J REGULATED AREAS I S VOT .JUSTIFIED IN LIGHT OF DATA AVAILABLE. THE '.-jEARING IF GLOVES AT ALL TIMES COULD CREATE SAFETY RO.RL EH S THE LABELING REQUIREMENTS AS DEFINED IN SECTIONS Cl) C 3) (A) AND C 5) SHOULD HE MODIFIED TO DE CLARE VINYL CHLORIDE AS A "HAZARDOUS CHEMICAL" INSTEAD OF A "CANCER-SUSPECT AGENT." WE RE LIEVE THAT THE DECLARATION OF V'C-M AS A CANCERSUSPECT AGENT AT THIS TIME WILL UNDULY ALARM PEOPLE. WE FEEL THAT SECTION S3) SHOULD BE DELETED AS UNNECESSARY FOR REASONS DISCUSSED LATER CCF.* OBJECTION IOC!) SECTION (4)). PAGE 5 OF 3 OBJECTION NUMBER PROVISION OBJECTIONS RECOMMENDATIONS GROUNDS 7 CG) WE PROPOSE THAT FULL FACE PIECE MASKS SHOULD BE REQUIRED WHENEVER RESPIRATORY PROTECTION IS SPECIFIED. HOWEVER, WE ALSO PROPOSE THAT THE REQUIREMENTS F)R \VVC 000002569 COMBINATION UNITS AS SPECIFIED 3Y (III) AND CIV) BE 9 CK) THE LABELING i EO UI R EM EN T S AS DEFINED IN SECTIONS Cl) < 3) (4) AMD (5) SHOULD BE MODIFIED TO DECLARE VI NYL CHLORIDE AS A "HAZARDOUS CHEMICAL" INSTEAD OF A "CANCER-SUSPECT AGENT." WE BELIEVE THAT THE DECLARATION OF VCM AS A CANCER-SUSPECT AGENT AT THIS TIME WILL UNDULY ALARM PEOPLE. WE FEEL THAT SECTION C2) SHOULD HE DELTED AS UNNECESSARY FOR REASONS DISCUSSED LATER XXRKKMXaBaKX C CF., OBJECTION 10 Cl) SECTION C4) ). PAGE 6 OF 8 OBJECTION NUMBER PRO VI SION OBJECTIONS RECOMMENDATIONS GROUNDS 10 Cl) COMPLIANCE WITH THE SECOND SENTENCE OF Cl) AND ALL OF C SO WOULD, WE FEEL, CREATE SAFETY AND FI 'RE HAZARDS. THESE PORTIONS OF THE STANDARD SHOULD, THEREFORE, 3E DELETED. ' WC 000002570 SECTION (4) REQUIRES THE USE OF WHOLE-BODY, A I RStJPPLIED SUITS FOR CERTAIN OPERATIONS INCLUDING VESSEL ENTRY. THIS IS AN IMPRACTICAL AND SECTI D\' (7) (1!( <B) SHOULD RE 04^JGED TO ALL 3w THE USE OF DO UAL E BLOCK AMO BLEED VAL VE ARRANGEMENTS FDR ISOLATION OF ANY VESSEL, NOT MERELY FOR VESSELS HAVING -'.`ELDED PIPE. THE TWO VALVES IN SERIES REQUIREMENT IN THE STANDARD IS, INCIDENTALLY, UNSAFE WITHOUT A PRESSURE BLEED. WE RECOMMEND THAT THERE BE NO REQUIREMENT FOR A HOLE WATCH OVER ALL 'REACTORS WHEN THEY ARE ENTERED. ADEQUATE VENTILATION AND MONITORING PRIOR TO ENTRY SHOULD INSURE THAT VERY LOW LEVELS OF MONOMER ARE PRESENT BEFORE ENTRY. PAGE 7 OF S OBJECTION NUMBER PROVISION OBJECTIONS RECOMMENDATIONS GROUNDS VVC 000002571 11 CM) SECTION Cl) SHOULD READ AS FOLLOWS: "FACILITIES FOR THE LOADING AND UNLOADING OF VINYL CHLORIDE TO AND FROM CONTAINERS SHALL HAVE EACH TRANSFER LINE AND VAPOR EQUALIZER LINE EQUIPPED WITH VENT CONNECTIONS, AND SHALL HAVE AN INERT GAS OR VACUUM PURGING SYSTEM. VENT AND =>URGE EFFLUENT SHALL BE RETURNED TO A PROCESS STREAM OR VENTED OR FLARED IN A SAFE LOCATION." UNDER SECTION INSTITITUION ) F A M EDI CAL v.QHXSHOP IS REOUI RED. UNLESS WORKSHOP IS A TYPO GRAPH I CAL ERROR POP WORK-UP, THE TE.R4 -ORXSHOP SHOULD B E OEFI 'JED. 13 CP) (3) THE PRIVILEGE TO EXAMINE AMD COPY RECORDS OF MOM I TO RIM G AMD MEASURING SHOULD HE RESTRICTED TO THE EMPLOYEE AMD OSHA REPRESENTATIVES AS DISCUSSED IN OBJECTION 'JUMPER 5. PAGE 5 OF P OPJECTIOM MUMPER PROVISION OBJECTIONS RECOMMENDATIONS GROUNDS 1 A CD) THE REPORTING REOUIREMEMTS DEFINED IN SECTION Cl) AND CR) ARE UNNECESSARY. THESE SECTIONS SHOULD PE REPLACED WITH ONE DEFINING REPORTING RED UIREM ENTS IN ACCORDANCE WITH STANDARD OSHA PROCEDURES* ' Wc 000002 572 MANUFACTURERS SHOULD M AIN T AIN EXPOSURE LOGS RECORDING ANY INFORMATION JUDGED NECESSARY. THESE LOGS COULD PE MADE AVAILABLE TO OSHA. SEMI-ANNUAL REPORTS COULD ALSO BE MADE TO OSHA TO PROVIDE ANY ADDITIONAL INFORMATION THEY REQUIRE. PARAGRAPH C3) DEALS WITH EMPLOYEE NOTIFICATION OF EXPOSURE AND REQUIRES, AMONG OTHER THINGS, THAT THE CT ,VI O! V C* IT D !T T \1 m .I^ITn O ff CDCT'T CT f' ^14 01 FTTA >1 HATP5