Document jmG5KmrYajYXOe8NG9G91NV6R

SEE DISTRIBUTION R.D.Savage June 19, 1974 PROPOSED OSHA STANDARD ON VCM EXPOSURE Attached is a copy of letter mailed lest week to domestic PVC customers. It describes the order of magnitude of residual VCM In our Geon resins, as well as environments where VCM might tend to concentrate. You should keep this letter for reference. In addition, all BFG sales operations outside the U.S. handling Geon FTC products should be sent a copyof this letter for-thelr Information. This should be attended to promptly. U.S. Government hearings on the proposed standard for residual VCM' will take place In Washington June 25. RDS/cak Attachements DISTRIBUTION W.F.Blackler S. G.Esakov T. R.Goshorn T.L.Karable W.A.Mitchell R.J.Morsek D.W.Taylor R. F.Turaski F.Wlseht S. T.Trier cc: A.L.Hatfield j.M.Reese B.I .Pfister R.E.Martin C.R.Flynn 8 ILVZ Mr. Esteban R. Chanco Project Research Supt. Mabuhay Vinyl Corporation Suite 501 Madrigal Bldg. Ayala Avenue Makati. Rizal. Philippines Dear Mr. Chancot This will acknowledge receipt of your letter of May 30, 1974. in which you expressed interest in the precautions we are observing in our PVC Plant to protect our employees who are exposed to vinyl chloride. We have passed your letter along to our International De partment. and they in turn will be contacting you with any information they may have regarding suitable precautions for PVC manufacturing and fabricating. Very truly yours. dot be: C. R. Flynn P. H. Lawrence May 30, 1974 B.F. Goodrich Chemical Co. P.O. Box 954 Bells Lane, Louiseville, KY. 4021 U.S.A. Gentlemen : v We read in an article which came out in the Chemical Marketing Reporter, and in the Wall Street Journal about the outbreak of liver cancer to workers of several PVC manufacturers. Being a local PVC manufacturer, we are very much interested in knowing the precautions you are presently observing in your PVC plant, your methods of monitoring VC gas, your method of handling and testing VC monomer,etc. We are also interested in any literature regarding the dangers involved in the production of vinyl chloride and PVC. Thank you for your assistance. Very truly yours. rr ESTfiBAta R. CHANCO Project Research Superintendent ERC/a rv 24718003 MAIBUIIrW VINYL CORPORATION SUITE 501 MADRIGAL BLDG.. AYALA AVENUE. MAKATI, RIZAL. PHILIPPINES P. O. BOX 1356 MANILA CABLE ADDRESS: FILVINYL MANILA TEL. 88-66-91 Attached is a copy of letter being mailed to customers today. The first page of all the mailings will be the same but there are three different second pages and the mailing will go to ' three separate customer lists depending on which products ^ they purchase. ^ .^ Let me know if you have any questions. *^ ez Attachments CC: R. D. Savage R. E. Martin z Malone /g-^ 247/8004 8FG-49W-B REV. M 70 i ;fMO U.S B.F. Goodrleh Chemical Company A DIVISION OF THE B.F. 6000RICH COMPANY 6100 OAK TREE BOULEVARD C L E V E L A N D , 0 H I 0 4 41 3 1 PHONE: 216-52 4 - 0 2 0 0 June 4, 1974 Gentlemen: To assist In our consideration of The Occupational Safety and Health Administration (OSHA) proposal described in our letter to you of May 30, 1974, we should like to offer additional information on vinyl chloride monomer currently remaining in our polymer products at the time of manufacture. The Occupational Safety and Health Administration (OSHA) announced on April 5, 1974, an Emergency Temporary Health Standard for exposure to vinyl chloride (Federal Register, Vol. 39, No. 67, April 5, 1974, pp. 12342-44). This emergency standard established an exposure ceiling of 50 parts per million (ppm) in air for vinyl chloride (VC). OSHA, in paragraph 1910.93q of the subject standard, has set down temporary in-plant monitoring requirements for ambient air for employee protection. On May 10, 1974, OSHA published a Proposed Permanent Standard for Exposure to Vinyl Chloride Monomer limiting the allowable exposure to a "non-dectectable" level. As PVC is manufactured in the industry today, detectable quantities of vinyl chloride monomer remain in resins and compounds. While this may not result in detectable quantities in the general atmosphere in your plant, there are conditions under which residual monomer may accumulate to measurable amounts. Since the monomer is volatile, it is released from the resin gradually in storage and more rapidly under heat and further processing. It is the intent of this letter to indicate the order of magnitude of the trace amounts of residual vinyl monomer presently in our products at the time of manu facture and also to point out potential areas of accumulation. We are working diligently to reduce these trace amounts and progress is con stantly being made, but time will be required to implement improved technology and equipment to reach the desired goal. General Purpose Resins 102EP F-5, 103EP, 140X30 Average Amount of Residual Monomer <0.00507. ( 50 ppm) 103EP F-76, 80X5 430X30, 300X6 <0.01507. (150 ppm) Continued SQQSlLfrZ 2- Dispersion & Super EP Resins Average Amount of Residual Monomer 120 Series, 130 Series, 90 Series <0.0025% ( 25 ppm) Compounds Flexible <$.0010% ( 10 ppm) Rigid <0.0100% (100 ppm) Other miscellaneous resins vary, usually being higher than any of the above. Analysis has shown that areas where vinyl monomer might con centrate are: 1. Enclosed containers such as bulk railcars, bulk trucks, and storage tanks. The air space above the resin should be purged and monitored for vinyl monomer or adequate protection provided prior to exposure of personnel. 2. Intensive compound mixing operations under heat. Suitable exhaust ventilation should be provided. Appreciable concentrations are less likely to occur in other pro cessing operations such as extrusion, molding, and calendering; but proper ventilation should be maintained around all hot processing equipment. Normal, good operating practice in exhausting volatiles may be sufficient, but should be confirmed by measurements. The concentration of vinyl chloride at the currently mandated ex posure limits cannot be detected by odor so that suitable test equipment and methods must be used as indicated in the Temporary Standard and Procedure (OSHR Vol. 3, No. 44, April 4, 1974). Copies are available at our field sales offices. Intense technical efforts by us and others in the industry are re sulting in a rapidly changing situation. As additional information becomes available, we will certainly be in touch with you. Cordially yours. 247/0006 JFMalone/ez Director of Plastic Products Management -2 - Dispersion & Super EP Resins Average Amount of Residual Monomer 120 Series, 130 Series, 90 Series <0.0025% ( 25 ppm) Compounds Flexible Rigid $.0010% ( 10 ppm) <0.0100% (100 ppm) Blending Resins 140X30 202 <$.005% ( 50 ppm) <$.170% (1700 ppm) Other miscellaneous resins vary, usually being higher than any of the above. Analysis has shown that areas where vinyl monomer might con centrate are: 1. Enclosed containers such as bulk railcars, bulk trucks, and storage tanks. The air space above the resin should be purged and monitored for vinyl monomer or adequate protection provided prior to exposure of personnel. 2. Intensive compound mixing operations under heat. Suitable exhaust ventilation should be provided. Appreciable concentrations are less likely to occur in other pro cessing operations such as extrusion, molding, and calendering; but proper ventilation should be maintained around all hot processing equipment. Normal, good operating practice in exhausting volatiles may be sufficient, but should be confirmed by measurements. The concentration of vinyl chloride at the currently mandated ex posure limits cannot be detected by odor so that suitable test equipment and methods must be used as indicated in the Temporary Standard and Procedure (OSHR Vol. 3, No. 44, April 4, 1974). Copies are available at our field sales offices. Intense technical efforts by us and others in the industry are re sulting in a rapidly changing situation. As additional information becomes available, we will certainly be in touch with you. Cordially yours. 24716007 JFMalone/ez Director of Plastic Products Management 2 Average Amount of Residual Monomer Dispersion & Super EP Resins 120 Series, 130 Series, 90 Series <@.0025% ( 25 ppm) Compounds Flexible Rigid <@.0010% ( 10 ppm) <p.oioo% (100 ppm) Soluble Resins 427 <0.08% ( 800 ppm) 222 <p.75% (7500 ppm) Other miscellaneous resins vary, usually being higher than many of the above. Analysis has shown that areas where vinyl monomer might concentrade are: 1. Enclosed containers such as bulk railcars, bulk trucks, and storage tanks. The air space above the resin should be purged and monitored for vinyl monomer or adequate protection provided prior to exposure of personnel. 2. Intensive compound mixing operations under heat. Suitable exhaust ventilation should be provided. Appreciable concentrations are less likely to occur in other pro cessing operations such as extrusion, molding, and calendering; but proper ventilation should be maintained around all hot processing equipment. Normal, good operating practice in exhausting volatiles may be sufficient, but should be confirmed by measurements. The concentration of vinyl chloride at the currently mandated ex posure limits cannot be detected by odor so that suitable test equipment and methods must be used as indicated in the Temporary Standard and Procedure (OSHR Vol. 3, No. 44, April 4, 1974). Copies are available at our field sales offices. Intense technical efforts by us and others in the industry are re sulting in a rapidly changing situation. As additional information becomes available, we will certainly be in touch with you. Cordially yours. 2477800a JFMalone/ez [rector of Plastic Products Management