Document jgXVVkjmz9NK1NkvzzxmrZKdZ

6 I iM Z 0 0 3 HA 9 i, PPG INDUSTRIES, IN../ONE GATEWAY CENTER/PITTSBURGH, PENNSYLVANIA 15222/AREA 412/434-2585 July 31, 1974 ZCB G. BELL, Jr., Sc.D., Director Environmental Control, Industrial Chen'ic.il Division Mr. John Stender Assistant Secretary Department of Labor Room 31/T5 14th prtd Constitution Avenue, N.W. The reason for this correspondence is to express my objection to the position taken by the American Chemical Society on the proposed permanent standard for vinyl chloride presented at the Public Hearing in Washington, DC. The past president of AIHA requested in a telephone conversation that I repre sent the Association at the American Chemical Society meeting scheduled for May 21, 1974, on vinyl chloride. I received a confirming letter dated April 26 thanking me for consenting to represent the AIHA (Enclosure No. I). On April 29, 1974, Mr. H. H. Fawcett sent me a letter ar.J additional correspon dence (Enclosure No. II). The American Chemical Society ad hoc Task Force met on May 21, 1974. The basic questions confronting the ACS were: 1) Should the Society take a position on the proposed standard? 2) Is VCM the chemical that has caused the problem? 3) In the opinion of the Society, is the proposed standard reasonable and appropriate? The ad hoc Task Force on Vinyl Chloride had only two members currently employed in industry--myself (representing AIHA) and Mr. George Wilson of Firestone Tire and Rubber (representing the ASTM, E-34). VRD 0002007320 Mr. John Stender July 31, 1974 Page 2 The attendence at the ad hoc Task Force meeting on May 21 is shown in Enclosure No. III. The outgrowth of this meeting was a draft of a position to be taken by the Society (Enclosure IV - May 23, 1974, cover letter from H. H. Fawcett and copy of first draft). This draft addressed itself to the basic rationale used in setting the proposed standard and not directly to the specifics of the proposed standard. Further, this draft did not indicate any endorsement of the proposed "non-detectable" level concept nor was technical feasibility discussed at the May 21, 1974, meeting. Upon review of the draft position by the Society, I had no major objections. In the subsequent correspondence package from the Society (Enclosure No. V - transmittal letter from Mr. Halley Merrell, dated June 12, 1974, and from Mr. S. T. Quigley, dated June 7, 1974), it can be seen that a dead line of 5:00 p.m., June 12 was set for comments on the third revision of the draft. Howevei, this draft was received in my office on June 13, 1974. Concurrently, I was on vacation curing that entire week. In addition, the accompanying cover letter stated: "It would likely be helpful if the ad hoc Task Force and CCS members were on record as recorrmending Board approval of the statement. If you approve the statement, ..tay I request that you telephone me immediately." I did not telephone approval. Through retrospective deduction, I must assume there was a second draft which I did not receive or review. Because of my extensive traveling, a recent bereavement, and a presumption that subsequent drafts would not deviate substantially from the original draft, I did not appreciate the substantive changes that were incorporated in the latest draft or the final testimony given by the American Chemical Society. I was given no further opportunity to review the final position taken by the American Chemical Society nor was any other meeting of the ad_ hoc Task Force members called before the final position was presented at the Public Hearing . 0002007321 Mr. John Stender July 31, 1974 Page 3 I personally cannot support the final position taken by ACS nor do I believe that it is proper to necessarily imply that the AIHA endorses the American Chemical Society's position. Very truly yours. SO o Attachments cc: Daniel Boyd - OSHA Howard H. Fawcett - National Academy of Sciences Paul Halley - Standard Oil Co. Jerome H. Heckman - Keller and Heckman Edward Kline - Office of the Solicitor Donald Lassiter - OSHA William E. McCormick - AIHA John A. Pendergrass - AIHA Stephen T. Quigley - ACS Jerome T. Siedlecki - AIHA W. Mayo Smith - Air Products Henry Stremba - ASTM George L. Wilson - Firestone ENCLOSURE NO. Ill A M lSUICAN C II K MICAL S O C I 10 T V COMMIT IT:E ON CHEMICAL SAFETY esj <S3 <S) r^J 04 ro ro Attendance A.C.S. Meeting on Vinyl Chloride Marvel Hall - 21 May 1974 Name Dr. Victor Brum Dr. Zeb Bell Ms. Joan Broom Mr. Howard Fawcett Dr. Herman Kraybill Dr. Donald Lassiter Dr. Nina McClelland Dr. Bernard McNamara Mr. Halley Merrel1 Dr. Glenn Schweitzer Dr. F.A. Van Atta Dr. Elizabeth Weisberger Mr. George White Mr. George Wilson Mai ling Address VA Center, Medical Research Lab 15-A, Togus, Maine 04330 A.I.H.A., PPG Industries, 1 Gateway Center, Pittsburgh, PA 15222 NAS-NRC, 2101 Constitution Ave., N.W. Washington, D.C. 20418 NAS-NRC, 2101 Constitution Ave., N.W. Washington, D.C. 20418 National Cancer Institute, National Institutes of Health, Cethesda, MD 2001 OSHA, 1726 M St., N.W., Room 620, Washington, D.C. 20210 National Sanitation Foundation, P.0. Box 1468, Ann Arbor, Michigan Edgewood Arsenal, SAREA-CL, Aberdeen Proving Ground, MD 21010 A.C.S. , 1155 16th Street, Washington, D.C. 20036 EPA, Office of Water Programs, Division of Oil and Water Hazardous Materials, 401 M St., S.W., Room 1113 E, Washington, D.C. 20460 Office of Standards, Department of Labor, 1726 M St., N.W., Room 410, Washington, D.C. 20210 Stop #205 National Cancer Institute, National Institutes of Health, Bethesda, MD 20014 NAS-NRC, 2101 Constitution Ave., N.W. Washington, D.C. 20418 ASTM, E-34, Firestone, Akron, Ohio ENCLOSURE NO. Ill n tL iB M B d an t ENCLOSURE NO. IV A M K RICAN C 55 K M I C AL SOCIK TY COMMIT TEE ON CHEMICAL SAl-ETY 23 May 1974 MEMORANDUM To: Attendees at ad hoc Panel on Vinyl Chloride, May 21, 1974 Members, Committee on Chemical Safety Subject: Proposed ACS Comments on Vinyl Chloride Regulation (Federal Register, Vol. 39, No. 92, May 10, 1974, Pages 16896-16900) Please note the attached draft of the proposed statement by the Society on the vinyl chloride regulation. I have taken the liberty of editing this to a minor degree but am hopeful this contains your thoughts and opinions. Due to the extreme urgency of time, we ask you to telephone any comments (rither positive or negative) directly to the American Chemical Society so appropriate action can be taken as soon as possible. Specifically, if you will call Dr. Nathan J. Karch on telephone number 202-872-4466 or 4467, or Mr. Halley Merrell on 872-4610 (202) by noon Tuesday, May 28, we would greatly appreciate it. We would of course welcome any comments in writing, but recognizing the urgency of time, we must ask you please to telephone your comments to Dr. Karch or Mr. Merrell. Your continuing cooperation in this matter will be greatly . appreciated by the ACS, by Dr. Victor Brum who chaired the meeting, and by myself. Sincerely yours, HHF:rj Enclosure H. H. FAWCETT Chairman Committee on Chemical Safety RECEIVED MAY 2 4 1974 MFG. DFPT. The American Chemical Society has a strong interest and recog nizes its responsibilities to both the public and the private sectors concerning both the benefits and potential hazards from chemicals and their uses. For these reasons, we have noted and carefully reviewed the most recent information on the subject of vinyl chloride in occupa tion exposures and its relationship to sarcomas. Angiosarcoma is a rare carcinogenic lesion in the general popu lation. The appearance of angiosarcoma in occupationally exposed groups,much higher than in the general population,shows a casual re lationship for an occupational vector. There is enough data to charac terize vinyl chloride as a carcinogen--a potent hepatocarcinogen. There is sufficient data to indicate that this is a carcinogen for other sites, i i.e., kidney, bone. Epidemiologically, this should be sought for beyond liver. Survey reports now show extrahepatic angiosarcoma. Referring to Federal Register, Kay 10, 1974, pages 16896-16900, Vol. 39, No. 92 [29 CFR Part 1010], (f)i), it is suggested a grace period of reasonable but limited duration be extended for industry to meet these standards considering engineering design and their economic effects, with feasible controls to be instituted as soon as possible. Regarding limits of exposure, the following quotation, extra'CtKT from page 11 of the report, CHEMICALS AND HEALTH, Report of the Panel on Chemical and Health of the President's Science Advisory Committee (National Science Foundation) September 1973, chaired by Professor John W. Tukey, appears germane to the subject: 2. "A 'no-detectable amount' clause is a refuge in the face of ignorance. Were mature scientific knowledge presently available regarding dose-response relationships and extrap olation to man, the problem of carcinogenicity could be dealt with a scientifically rational manner. Vie have good reason to believe--though it is not yet proved-- that some, perhaps most, chemical carcinogens will have definable thresholds." Vinyl chloride has an apparent threshold and a definable dose response curve.. , Regarding (g) and (h), we endorse the control methods outlined but suggest further consideration to the possible air-supplied suits fabricated from material impervious to the expected exposure. The air i supplied for breathing must be as good as or better than that required by CFR 1910.134. Consideration should be given by NIOSH/B of M for an approval schedule commensurate with specific needs for protective equipment for vinyl chloride and polyvinyl chloride exposures and appropriate mainte nance and decontamination procedures for such equipment. We strongly endorse the concept that transporters or disposers of any chemical, including vinyl chloride, should be properly informed of the potential hazards and adequately trained in the safety precautions to be observed. The American Chemical Society continues to encourage the rapid and wide dissemination of information and data on the potential hazards of chemicals, and will continue to provide a forum for such purposes on all chemicals and chemically-related substances. 0002007325 30 o 26732 applicant will be the date of tl/.c loan PROJ^ 3SED RULES .4. In section a) (2) In Appendix A. <s <S9 <K3 Bldg., 400 Seventh Street. SYVr^Wa land the date from which interest Accrues. [(20 US-C. 4-1S<3>) I 142.43 Hi'pnjTnFnt. I (a) Schedule of Tcyayncrii. Repay- :cnts of principal with accrw/.I lnt'-rcat be made o:i those dates f-.s may be k";reecl upon by the CoimnLJtcncr and applicant. I b) Dale of maturity. A lorn may be appearing at pas 24156. the formula in tlic definition or K` should ' read _b' t : 5. In section 2 i) In Appendix A, aprearing at page ;il5G, the formula in the definition iyr S` should read P,, i * Ington, D.C. Interested pcrcor.s?tre vited to attend the hearing r-.ncf^rc- oral or written statements pa fms y posal. It Is requested that an^yic ; string to attend the hearing r.oufy Executive Secretary at least ton dry: advance of the tune needed for hii ; entation. Written summaries or coof oral prcrentations are encourarcd. Closmg date for cowmcr.Li. All cc jde for any period of time Except that thi date of maturity shall bt not more ttv.Vi ten years after the dotj; cn which theuo.m is made. I (tv /'rrptTvracTjfs. Loans it.ay be pre- paid\in full or in part at any time, with accrued interest to the date f f payment, without penalty for prepayment. (20 uA.C. 440(1) ) 142.11 Ropnrt? am! r co:| <a> A'cporf.s. Each applicant receiving a loan iy.al! inrnish r. cctn:4-:l.'on report Upon crynpletiivr the appiir.ed project, and shall furnish such pro <r-:-s or oth.er reports :A the Commissic-!":- may from time to tano require re-TsJ-ciinq the use of loan fAn.i-i. Mhe com/dc-Lon report shell be ju:Yiii",_cl by the /.'.si clay o: the fiscal year yellowing the|lhc:.l yc-ar in which the r.;\p.ii<-ation waj- anpioved un less the Conj.nisrior.er ektcu-.ls the pe riod upon ti.,i written toqucM of the applicant. \ j <b> J-;cccrtfs\Lech au/ho.-v. receivin': r. loan shall kc.p hue Iran in a separate bank account oi\rr.aintr`n a reparnte ac 6. In section 3(4'(2> In Appendix A, appearing at page 241 DO, the word "is" should be added af cr "lu" in the second sentence. 7. In section (3) c> In Appendix E. appcavirh at cr.ee 21 56, the first sentence should read as foil. \vs: Where damage in alvcs transverse bulkheads as specified. n paragraphs fa) (1) and f2) cf this sc/.ion, transverse water tight bulkheads ixurl be spaced at least at a distance eqi\l to the longitudinal extent of the assumed damage specified in paragraph fb) oL this section in order to vs considered cli< j-tive. Dated: July 18, 1C-J4. D. II. CblFTOt.', Captain. U.S. Feast Guard. Act- ing CLt"-/. if"cr^o/ Merchant AfarmcVta'l ly.f (Fit Doc.74--1678X^^^^7-22--74;3:45 am] [45 Cm Parts 40,151] (COD 7-5 -'1C7 J munications received before Septem 6, 1074, will be evaluated before f : action is taken on this proposal. I proposed regulations may be changed the light of comments received. The Occupational Safety end II;; Administration, Department of La announced in the E-'rdckai, Ftrcusrrr. Friday, April 5, 1574 (25 Fit 122-52) i: vinyl cldoride is carcinoyeric far hum. and that the new exposure .i.andard . vinyl chloride 15 50 ppm. OrhA al -.-j : nounccd m the Fudsral Rd-h;:; of 1 day, May 10, 1974 <3d Fit IP :.. J) thr. new level of exposure standard of ` detectable level" is pronewd. Coast Guard regulations for vinyl ch ride penult restricted gauging au.i v-.: ins of vinyl chloride to th-.- a::uc;-r;a during cargo transfer opc-:nti-ans. S> both the use of a, restricted gauge 1 the vcitting of vinyl chloride vapors the atmosphere during cr.rro Iran:, operations result in vinyl chltride c; centrutions in excess of 50 i-tm. act was necessary to protniv p:u.otci.-n. personnel from th:.-; danger. counting oi a!] suih Imres suub.-icru rrrd51y to identify' all trnnjuctirui.i with the loan funds. En:;\ npi/b-.'.nt shell also ma.ir.te.tn intact All records suppor'inj the use cf loan fW.df. fur three years after the Icon has\b.>un repaid in full. Such records shall rcjinnc'e available to fiscal iepre:vutr.tive\ pf the Government for audit purpc .es. (20 US.C. 1C32?('j) (2)A`3)) JFIt Doc.7-i-lG75f i i'J A 7-22-74:0:45 am] nEFART^'uVlT Or TRAhJSFplVO'.OiJ Coast Guard T33 CFfl Part] [CCp 74-321 TANK VESSELS ErGAOEDYM DOMESTIC ?"EE \ Protce*cPtioronpoosiedManncar.iEcfrd.viuirpeuh-o'.ermr.tc; lioNnotice In: HID- n 7-i-; 1 nun:-: A tpeeei 24150-7 in th:- / -i;c for }-r:2; y. June 23, VINYL CHLCJRiDE Accordingly, the Coast Guard d:"*r natccl by message 1131512Z 157 Proposed Carriage Requirements Interim nicasurcs to prevent t-xy.vsu The Coast_.Ouard... Is cor.sidcrinc amcnd:n';__the bulk c,anycrous_ car.,,ocs_ fe:.itk:r:c:i3 for" chloride (vinyl the ennave of vinyl cb'aridc `mohc:nerr`by~ reguirip-j venting,, gauging and cargo transfer systems. w!i:c !i provide prcnlcf of personnel to vapors during c:.transfer operations. These in.tix.M ru-;: ures are proposed to be supeisec.d the followin': ic^uialions: (a) Prohibitiun of liquid levrl fav.r- otlter than cloned gauges, on eaugo t.u. containing vinyl chloride. proircdon to personnel.than those pres ently permitted. These amended regu lations will apply to all lank vessels, both (b> Prohibition of vent;,." cf vi, chloride vapors to the aim-'-y,here ci ins cargo tr.an.-fer opcraiic.-r.G (re::-., existing and new construction,"carrying yiiijdchloride.^ meat of vapor return to.a siiorc ta-.; stream). Written coin77:cf'fs. Interested persons (e) Requirement of conliruious d: '. p.re invited to r^ilieipate in this pro tion for vinyl c-liiaride vap.-.r !;r In r.'e- posed rulemaking by submitting written, tank verge's unric-rgoins vnijl chic;" data, 4lews, or arguments to the Execu transfer operation:-.. tive Secretory, Marine Safety Council, (d) Discouiiuuir.q of tr, Tnfc-r r . U.S. Coast Guard iIc:ul-.f.J-.u-leis <C- tions whenever viuyi ch:o:n'.- v.u CMC/521. Room 823-1. 4C0 Seventh centr.-.tions in excess of 53 rp: 1 art- ^ Street. &\V., Wf^bineton, D.C. 2C550. tecicd. (T.'-lephoue 272 426-1477). Koch peismx (e> rittiuiremcnt of puryln.- c f c:.: submitting rotuneni:. fliouid include his linas to a ::m;c proecss st: ;-. i.umo eud aildrc-sx, identify the notice completion of ci.iyo tr.in.-.' : : J974. the loll. coiru'Ci'.";? .'hoidd be made: j I 1. i*i : 357.t7 t-'' (li, aiv'cr.I'.pg r-t pare 4153. Die V.j;u "bih`j!c'` h.tvMd read "visaie". j j 2. JV.biV.rJ 5 157,11. r.pucm at page 25155, a not./riiould be r.dch-.Arcadiric as follows: j * Novr: An I vi-ci'l m,r t comply with the rccjvilrvy.-uis m { 157.11 bifoie Decem ber 3i, lavs' (COD 7-1-167). and cite reasons for any recommendations. Conur.cr.ts received will be available for examination by in(ercst-Tvl persons in Eouai `>2')'. Lb-ixiitment of Transportation, fan'.-if Building, -102 Seventh Strict. SW.. WashijiMnn. D.C. Copu a will be Jurni.-hed upon pay ment of fei-s I'rcscrujed m -19 Cl-lt 7.01. Public hcnrtnti. Tue Coast Guaul will ho!.] a hearing on Am m-d 15. 1074. at before rlrconru-c.tur.: car-.o :.y 'o : cIucj.> vmyl ui.loriuu vapor to 50 ppm or levs, Ttie jHu:Jc.--f c! vxpc: urc Junh of f-9 V may he chanjed ar. a re: 1 ; . f O. F CNpo.-urv limit c't tc.-nitinci i r i'..- J 25, 1U7-! hcari:.::. and cc.mut'.-uir. 1 ;i following pro;x).--r(l rctulaX':::; i-b. uP.i. made with this fast in iiniui. In considcrai lull of the fui ,:oir:r*. H proposed to amend Parts 47 arid ).,i 3. In 5 157.20(a). appearing at pare 9:30 a.m. in Confct.-m-i- iioriin i.331. De Chapter I. Title 4G, Code of i-'vcicrr.l IP. 2-1155. the word "and" should read "or". partment of 'll an: jiorlation, Nassif ulalions as follows: FEDERAL REGISTER, VOL 39, NO. 142--TUfSDAY, JULY 23, 1974 PROPO-- , RULES . 2G753 zm m m 1. Ey amending Part 40 of Chapter I. Title 46, Code of Federal Regulations by adding a new Suupart 40.15--Vftyl Chloride, applicable to p.ll tankships car rying vinyl chloride in bulk, tvs follows: Subpart 40-15--Vinyl Chloride (Vinyl Chloride Monomer) 40.13--1 General--T/AIJj. (a> A tank containing vinyl chloride may not have any liquid level gauges, other than clusecl gauges. (b> The person in charge of cargo transfer shall ensure: (1) That caigo vapors are returned to a shore process stream during cargo transfer operations: (2> That contir.uv.i3 detection for vi nyl chloride vapor halts is conducted aboard a unkship ur.dei'&iug vinyl chlor ide transfer operations, with detc^t-iou capability of 1 ppei-t.j ppm; (3) That cargo transfer operation is aboard a tank'hip undergoing vinyl chloride vapor concentration an exce.ri of 50 ppm is detected; and (4) Tkiit upon completion of cur;;o transfer, before ti'-iccnnectim? cargo tap ing, all c:.r..o iir.es aie purged to a inure process stream to reduce vinyl ciikr.de vap.or concentrations to 50 ppm or less. 2. Ey chancing the re-1 uircir.cnt for gauging in Table 151.05--.SiiMnarv of Minimv.rr. Rcc;::irc-n:r.is for vinyl Chlo ride from restricted to chwsd. 3. 15y adding paragraphs (q> and (h> to 5 151.:C'-i'.4 containim: special reruireirents for the carnage ci v.nyl chiuridet 131."0--31 Vinyl chloride (\Lnjl chlo ride monomer). * (g> A tank containing vinyl chloride may not h?ve any l.amcl level gaur-as. other than closed gauges. (h) The person in charge of cargo transfer shall ensure: (1) Thai cargo vapors are returned to ft shore process stream during cargo transfer operatic nr.; (2) Tint continuous drloction for vi nyl cldcride vapor leaks Is conducted aboard % tank bar-a undurgeing m:;T chloride ivanr-fcr op-`rrkiO::?. with detec tion capability of 1 pprnw 0.5 ppm; (31 That cargo transfer operut.cn is discontinued whenever a vinyl chloride vapor coucenirui.on in excess of 50 ppm is detected; and (m That upon completion of erruo transfer, baforu c.imovncct:r.g cargo y >tup. cli cargo lines arc purged to a shore prcco.-.s it rear.: to recitre vinyl chic ride va;\>r cc::c:r.:::cue.-.:. u u mu: cr ia.:s. (Bo sut. :?7; 44 u.h.c. f.o. S31&, 075, 4:0 muse. ;c:h5);nn w an: l/d <05 l-.-.i () (Jo) Dated: July IS, 1)74. D.ir Clifvov. Captain, V.S. CV.tif Guard, Act ing Chief. G: ee 0/ fd credit ;;i JicriTif Scfci''. (F21 Dar.74-lW3 M'-d 7-22-71;8:55 waj Federal Aviation Administration I14CFR Part 71] [Airspace Docket No. 74--OLr-IS| CONTROL ZONE Proposed Designation Issued In July 3. 1974. Des Plaines, Illinois. on R. O. ZlTCLBS, Acting Director. Great Lakes Region. [FR DOC.74-I672S Filed 7-22-74:^15 am I The Federal Aviation Administration Is considering amending Pert 71 of the Federal ViUuiioa Regulations so as to designate\ a control zone at Aurora, Illinois. Interest?i persons may participate in the proposes rule making by submitting such written sj-ta, views or arguments as they ir.ny cieu-V. Communications should be submitted i:\triplicatc to the Director, Great Lakes Region, Attention: Chief, [ 14CFR Part 71 {Airspace Docket No. 74/121^-24] I\EA tion Air Traffic Divi. ion. Federal Aviation Ad ministration, 2306. East Devon Avenue. Dos Plaines. ElincXs 0013. All cemmu- rdcctions received o:\pr before August 22. !S74, will be cor.sidei\<i before action is taken on the proposed. p-mcr.dmer.t. No public hc-r-ring is comutr.pl'icd at this time, but arrangements XcS; informal con ferences wi:h Federal AncV:c:: Adminis tration officials lr.ay be uir.d\by contact ing the Eirionai Air TrcFte Division ministration Is Chief. Any data, views or arguments pre 71 of the Fed- sented during such conferences must also ro os to alter be submitted in writing in r-.ccLrd.ance liviky. Ohio, with this notice in order to beccuSe part participa'.c in of the record for consideration. Tk\propor-al cor.futued in this notice max be by iubmitthu; arguments as changed in the light of csaimt: cac.crts sb.cuid received. to the D'rce- A public docket win bs available f/ n. Attention: cnr.minr.tio:: by interested rerccns in/v.e' Federal Avia- Office of the Regional Counsel, lmr'cml i Ea.:t Devon Aviation Admlnistraiion. 2350 :0is CJ018. All Devon Avenue, De* PDir.cs, on or before 63013. 1974. will be considered bc:o;e An FAA control tower will be ohmnus- r.cubr/is taken on ike jn-onosed amsnd- rioned at the Aurora Jdimucipny'Airporc, n;c:r/ Ifo puciic hec::::g is coutemplaied Aurora, Illinois. / at f.v.s time, but arrange meats for i*i- A control rone will be rc-q'/red when io'/n.-J conferences with Federal Avir.i.on the control tower is in operation and trill .j/imiui.nrr.tion ck.icials may t>e made by have the same effective k/urs oX the ^or.tr.r'ir.g the Regions.! Air Trade Divi tower. f sion Chief. Any cala. views or arguments In consideration of the /oregoincr, the prossutod during such conferences must Ftderrd Aviation Adnalnhnrr.ticn'pro also be submitted i:i writing in accord poses to amend Part 71/cf the Federal ance wi;h this notice in order to Lc-come Aviation Regulations a/ hereinafter set of tits record for consnuration. Tha forth: f Vropo5.il contained m this notice may In 71.171 (29 FR /o4), the following control rone is added, Aur.onii cerke>ac:?ne.givjp\ceiurcd.iba.ltiiiciRnotminc.deagtbohnuiyceidlvakiitneiPilcit^tgesn/rwhcrteuttistla7iltuoset.bfdJheci cpel ueaorterovnhsiauuoneirnvlaa.slttf-birtveiltnedsr-utrfheur.e--tlr That Rlrryst-f vlm.ln ft 5-milp r.acltun of tliB Autc-t\ Mu:/:lp.kl A\rr>:.:-t fl-LiUics <si*4C'co" ic-Z-wds f-O'^i co" vr.>. Kiid within 1'; r- ;;-/r.:!-rr f:k* c' tie D-P;.to VOI-l 217* r:.- ireta :k> L~v-t;'.iio r'.dsus to 7"-, /. NE c-i t`.:c v:-. -r-. -.i-iri. This cor.'.r-/zor.a is elTcctivf ciurlon iUO ryecUl-.t cl:.-1'". ...od tiaii =i tl`-.-1:;.d U: r.ci- v.'.nco br / o to Alnntn. c'.eckve date ru'd/;:: c v..,i t:.cr;:i'*.-.T cor.:.r.v.ovMy pcbJlsrKOi )u ti.o Airman'3 Irkuna^; Ion lUamii/. (c-'c/r.07'M c* tbft Fe-:!,,ral Avlatk-n Act of ivib {is v.s c. is:3i. r.ra r^c, e.o <>r tso Dcpr.r.r.'.rriV cr Trar.-porlaUda Art T73 C. 15(R))) OfacAof the Regicr.rd Counsel, Ftxicral Aviation AdminisTt1ra4t.i'.o)n), th2e30fo0'Iu L\ians?t Devon \\venue, Dos Plaines, Hiiaois 60013. A slancbard instrument approach pro cedure ha.\been developed based upon the rc'.oeatei^Sandusky VGR. Aecorc.tngly. it is r.ece:\?.ry to alter 'lie Snndu.krr, Ohio trap.sitioi; area to ac'r-r.uateiy prot-ect uie ajrcra:t>cxecut:ng this procc.vtre. In considcratiV-i of the forc-poinv. ihe Federal Aviatlon\ Admini'lrotion pro poses to amend Psrt Atiation R: forth; la 1 71.131 <39 Fi trr.r.;-:i:on area is ruccnV-d to read: S.ixi'CiKV. c\to No.ua--rt. i aLrrpr.c? cMcnd'.r.T itV^rird freo '.'CO 7c-;t oVovf* The svrtr.co i v.ii r. AmiIc rc-.-ii ; ct tkd Oriilr.c Sausu.-:? /.i r -\-t f i r.v. FEDERAL fiECISTER, VOL 3*, NO. 142--TUESDAY, JULY 234, ]`1:9:r/4c'i" n. lcoj.i_->''ce/' v..i; 3 r.-.i'.os ei'.hiT : or tr\ S.'.o,!-- :? VO'-. ! r.'.dkd <?x;r::C.:-i fren tV !,ve ::j*. to 7'v mk? t-.-.t of I'm- ;N.-t'tv c;:- c'.'jii::- `.h.il Tjcr'-io:: t'-.r/. ov; ri! -j'u/ JU>rt C.n.t .u transition nre.v. (C v. 0-77!al cf th^ X-'-n-craJ Avi.itlon Ant of M. L, Shsrrah Senior Vice President Research and Engineering August 2, 1974 Continental OH Company High Ridge Park Stamford, Connecticut 06904 (203) 359-3500 <33 N) CHEMICALS RESEARCH ro A ' * * I Dr. Robert W. Cairns Executive Director American Chemical Society 1155 Sixteenth Street, N.W. Washington, D. C. 20036 Dear Dr. Cairnsj The position taken by the American Chemical Society in regard to vinyl chloride monomer (VCM) safety standards (C&EN, July 15, 1974, page 4) may appear to many readers as well thought out, in view of the fact that it was developed by the Committee on Chemical Safety and reviewed by Committees on Environmental Improvement and on Chemistry and Public Affairs, followed by approval from the Board of Directors of the Society. It may, on the contrary, represent a dangerous position for the chemical industry as a whole, and in this specific instance is a position that is simply not consistent with the realities imposed by an industrial society. No serious doubt can be raised as to the carcinogenicity of VCM, nor is there any doubt whatever that a major effort must be made to reduce the exposure of workers to VCM. There is also no doubt whatever that these efforts are under way in full scale by every segment of the industry with results, that are, we believe, already dramatic in the reduction of VCM levels. There will continue to be a reduction in VCM levels that finally reach an extremely low and irreducible minimum, but at a level, however, that no one should permit himself to think will be "undetectable". No mechanical apparatus within the compass of industrial practice is destined to provide containment to such a degree that no analytical method will be able to detect it. The Society's support of a proposed standard bearing a "no detectable level" requirement, and its recommendation of a "minimum practical" detectable level are consistent steps only if the latter is conceived in the vicinity of 1 ppm. We are returned, thus, to the prospect of an impossible demand on an industrial operation. The ACS must be aware better than most organizations that chemicals are at least two things: 1. They are at the very heart of a modem society; 2. They are in most cases not pleasant in their effects when people are exposed to them in excess of certain levels. n tu a iu t ^ ha Dr. Robert W. Cairns - 2. August 2, 1974 The Society also knows that the larger society can survive the existence of the chemicals it needs, better, in fact, than it can survive, in the civilized form it prefers, without them. The Society must also know that the experience and judgment of those at the heart of an industry can have something of value to say about the issues arising within that industry. One wonders if the Society consulted in any depth with the VCM-PVC industry itself in arriving at its decision. (So often it is that those who know the most are consulted the last and are believed the least.) One wonders if the Society's Board of Directors have much experience in what VCM polymerization plants are like now versus what they were five years ago; whether the Committee on Chemistry and Public Affairs knows enough to accurately assess the question of PVC plant operations in space suits; whether the Environmental Improvement Committee can really be sure that any chemical is safe if present at a detectable level, or that VCM is a life threat at the industry-proposed levels. The ACS position is not far now from its own reduction to absurdity, which would be a posture that all chemicals must be manufactured under an essentially no-detectable ruling. That posture contains, as the Society knows, the same know-nothing quality as the pithy observation by one witness at the OSHA hearings to the effect that having lived for 200 years without PVC we can commence doing so again. It needs no repeating to say that industry, now aware of the VCM problem, is determined to cope with it. Nor does industry want no tough standards and time targets imposed. Industry does want a sense of reality to prevail and would have expected the ACS to be a leader in this direction. No matter how august the approval process in reaching its position, that position taken would in truth appear too briefly considered and non-responsible for the Society whose conceptions of the chemical industry should be without peer. Youts very truly. MLS:ow cc: Mr. Albert F. Plant, Editor Chemical & Engineering News