Document k6qZ2Rpm5ZRVq8j5y7bYorZy

January 5, 1976 P. H. Lawrence, Louisville J. L. Nelson, Cleveland Chemical Attached is a copy of th^-reporl Of-thc industrial hygiene survey conducted at th^Louisville^gl^nt during August 1975. Please note that Mr. NasKhas made several recommendations. I would appreciate your advising me of their status. If there are any questions or comments concerning this report, please contact me. v CC: G. Pow H. Waltemate W. C. Holbrook R.W. Strassburg M.N. Johnson, M.D. A.V. Gold, M.D. c__ AC \^ \ ................ ^* E. B. Katzenmeyer Jr. Manager, Industrial Hygiene 26090001 BFG46360 TO P. H. Lawrence FROM R. B. Nash, Jr. Louisville Plant FIELCJ POINT OR OEPT. & BLOG. NO. Akron - D/0020, 5-H INDUSTRIAL HYGIENE SURVEY - LOUISVILLE PLANT .. ... | OATG THIK LETTER 12/22/75 On August 18-20, 1975, an industrial hygiene survey was conducted at the Louisville plant. Air samples were obtained in Abson (Bldg. 30) and Hycar (Bldg. 131) and analyzed for acrylonitrile, styrene, buta diene and ;vinyl chloride. Additional air samples were obtained in Hi-temp (Bldg. 4). All results were within acceptable levels for each material. Noise dosimeters were placed on several employees who were suspected of having a significant exposure to noise. The daily noise dose for all employees monitored was within acceptable levels under the present standard. Several dust samples were obtained, with individual samples being compared to standards for lead, antimony, carbon black and nuisance dusts. All 8-hour time weighted average exposures obtained were thin acceptable limits for each material. The antimony sample exceeded what would be considered an acceptable excursion level under good industrial hygiene practices. 26090002 Gas detector tubes were employed to check carbon monoxide levels in the warehouse areas of Bldgs. 20 and 122. All samples indicated an ambient carbon monoxide level of less than 10 parts per million at the time of sampling. Samples obtained during cold weather may be significantly higher in concentration. Recommendations: 1. Require employees to use hearing protective devices when working in noise hazardous areas (90 dbA or greater). 2. Make plug insert type hearing device protectors available for employees working in noise hazardous areas. Employees should be given a choice of muffs or plugs. 3. Maintain all respiratory protective equipment in a clean and sanitarycondition when not in use. Do not leave respirators hanging on pipes or valves. 4. Maintain exhaust system at bale dusting stations in Bldg. 122 at peak performance to assure acceptable dust exposures. 5. Weigh all antimony and lead compounds inside the ventilated booths, not in areas where multiple personnel are weighing materials. 6. Monitor a random number of employees working in areas adjacent to vinyl chloride regulated areas for vinyl chloride exposure on a routine basis. i>s oss-c iht i.i(Ma us* BFG46361 26090003 2. Discussion: Organic vapor sampling was conducted on employees in Abson (Bldg. 30) and Hycar (Bldg. 131) for exposure to acrylonitrile, butadiene, styrene, and vinyl chloride with results shown in Table I. All four materials could not be analyzed from a single carbon sampling tube, so two tubes were used for each employee, hence two numbers are listed under "Sampling Time" for the two periods of time that samples were on the employee. Acrylonitrile and butadiene were desorbed of the first tube which was worn during the morning period and styrene and vinyl chloride were desorbed off the second tube which was obtained during the after noon period. The present allowable levels are: acrylonitrile 20 parts per million (ppm); butadiene 1000 ppm; styrene 100 ppm and vinyl chloride 1 ppm. All sample results were within federally specified levels. Special attention should be given to the vinyl chloride results because these samples were obtained in non-regulated areas. These samples indicate that employees working in areas adjacent to the polymerization areas are receiving a vinyl chloride exposure approaching the action level of 0.5 ppm vinyl chloride. It is recommended that the plant's vinyl chloride monitoring program be expanded to include these employees to determine the source and level of their exposure. Air sampling should be conducted on a monthly monitoring schedule to assure that these areas are being maintained below 0.5 ppm of vinyl chloride. Two samples were taken on an operator in Hi-temp (Bldg. 4) and analyze' for carbon tetrachloride. Both samples indicated a value of 0.1 ppm, well below the 10 ppm allowable level for carbon tetrachloride. Exposures such as these do not present an inhalation health hazard with respect to CCl^ for employees working in Bldg. 4. Four dust samples were obtained and compared to the four standards for each material sampled with results shown in Table II. Sample No. 1 was taken on a weighman working with carbon black in a ventilated booth. His exposure to carbon black for the time sampled was within the allow able standard. Sample No. 2 was taken on a bagger on B-Line in Bldg. 122 where he dusts the bales before they are put into the bags. This man's exposure for the time sampled was within the nuisance dust standard. This value seemed high considering most of the operation was i nformed in a ventilated booth. Sample No. 4 was obtained on a weighman working with antimony trioxide in a three man weigh booth. Although his timeweighted average exposure was within acceptable limits, the level obtained during the sampling period was unacceptable compared to recommended permissible excursions for time-weighted average limits. For a compound such as antimony, exposures in excess of 1.5 mg/M^ should not be permitted. If larger volumes of antimony and lead com pounds were consumed at the plant, the employee's exposure may increase to a hazardous time-weighted average. Even at present consumption levels, antimony and lead vreighing should oe given increased controls beyond normal weighing procedures. It is recommended that these materials be weighed only in Idg. 22 wht ;individual exhaust venti lation bootl are vailable v::d containing Ion of other employees would be avoided. Weighing operations must be restricted zo the confines of ventilated booths. 3. Several pieces of respirator protective equipment were observed laying around or hanging on pipes in the vinyl chloride regulated areas. All respirators assigned to personnel should be on the person in vinyl areas where it may be needed at a moments notice. Extra respirators must be kept in a clean and sanitary condition in an area specifically provided for clean respirator storage and not hanging on pipes and valves. Noise hazardous areas have been identified through previous visits and were substantiated during this survey. In most noise hazardous areas, hearing protection was not being worn by the employees. This lack of protection may have been due to the choise of protective devices available to the employee. Ear muffs are an acceptable type of hearing protection, but are hard to carry when not needed. The plant should investigate the use of ear plugs which may be easier to carry around or to keep clean. It is recommended that employees be given a choice of either plug insert or muff type ear protective equipment. Examples of plugs acceptable to the Environmental Health Department are the American Optical "Hear Guard Ear Insert", Mine Safety Appliance's "Ear Defender", or the Marion Health & Safety "Silent Partner". With a program of proper fitting and instruction, these hearing protective devices can be an effective part of a hearing conservation program. Noise dosimeters were placed on several employees to evaluate their noise exposure. The noise dosimeter integrates sound pressure levels over 90 dbA to achieve an average exposure for the time sampled. Under present allowable levels for noise, a reading of 100 would be the maximum acceptable number. As shown in Table III, all daily noise doses were less than 100, indicating acceptable noise exposures for the employees on the day tested under current standards. The employee who had the 98 reading was the only person wearing ear muffs as required by the assigned work area. Gas detector tube measurements were made in the warehouse areas of Bldg. 20 and 122 for carbon monoxide. All results were less than 10 ppm of carbon monoxide, well within the 50 ppm acceptable level. Measurements made during cold weather, when most doors are closed, could be significantly higher. I wish to thank your staff for their cooperation during my visit. foooeosz v cc: J. Fannin, Louisville A. Flynn, Louisville R. B. Nash, Jr. Industrial Hygienist BFG46363 TABLE I. ORGANIC VAPOR ANALYSIS RESULTS Louisville Plant Sample Employee Job Class. Sample Time Concentrateon (ppm) (min.) Location VCL BD ST ACR CT 1. Mr. Bennett Blowdown 150/130 Bldg. 131 0.2 11.2 - 0.3 2. tir. Short HRC Oper. 140/120 11 30 0.1 - 9.0 3. Mr. Bennett Blowdown 170/140 " 131 0.4 4.8 - 0.8 4. Mr. Lafton HRC Oper. 5. Mr. A. Williams Oper. 180/150 145/120 " 30 n4 - 1.0 - 5.4 - _ - - 0.1 VCL = Vinyl Chloride ED = Butadiene ST = Styrene ACR = Acrylonitrile CT = Carbon Tetrachloride 26090005 BFG46364 TABLE II. DUST SAMPLES RESULTS Louisville Plant Sample Employee 1. Mr. Banks 2. Mr. Narma 3. -- 4. -- Bids -Location 20-Weigh Booth 122-Bagger 20-Weigh Booth 20-Weigh Booth Duration Concentration (min.) 115 2.0 305 7.8 110 0.25 19 1.7 TWA Standard 0.5 3.5 Carbon Black 7.8 15.0 Nuisance Dus 0.05 0.2 Lead 0.07 0.5 Antimony TABLE III. NOISE DOSIMETER RESULTS Louisville Plant Sample Employee Bids -Location Duration (min.) Reading 1. Mr. Williams 129-Spray Dryer 390 64 2. Mr. Croner 121-2nd Floor 450 40 3. Mr. Ashley 122-Extruder 405 83 4. Mr. Cook 115-Pump Area 420 52 Daily Noise Dose 79 43 98 59 115 Light On Off Off Off Hearing Protection No No Yes No 26090006 46365 TABLE II. DUST SAMPLES RESULTS Louisville Plant Sample Employee 1. Mr. Banks 2. Mr. Nanna 3. -- 4. -- Bids *-Location 20-Weigh Booth 122-Bagger 20-Weigh Booth 20-Weigh Booth Duration Concentration (min.) (mg/M3) TWA Standard 115 2.0 0.5 3.5 Carbon Blac 305 7.8 7.8 15.0 Nuisance Du 110 0.25 0.05 0.2 Lead 19 1.7 0.07 0.5 Antimony TABLE III. NOISE DOSIMETER RESULTS Sample Employee Louisville Plant Bldg. -Location* Duration (min.) Reading Daily Noise Dose 1. Mr. Williams 129-Spray Dryer 2. Mr. Croner 121-2nd Floor 390 450 64 79 40 43 3. Mr. Ashley 122-Extruder 405 83 98 4. Mr. Cook 115-Pump Area 420 52 59 115 Hearing light Protection On No Off No Off Yes Off No 26090007 BFG46366 Fiet-O POINT OP 06-T. S 0i.CS NO. . B. Katzenmeverf Jc Dept. 0020-Bldg. 5H. Akroni FOOM FiLO POINT C1R OEPT &. OUOG. NO. QATc YOUR LETTER j OATE THiS LETTER F. M. FisterLouisvillei 11/30/76____________________ SUEJECT LOUISVILLE PLANT SURVEY SEPTEMBER 20-22 Mr. Nash's report on his September 20-22 survey of our plant and your accompanying letter indicate to me that, with the exception of one incident on weighing antimony, all of our pigment weighing areas do have adequate ventilation and all exposure levels are well below standard. As was mentioned in the report, I am sure we can solve that one problem by better handling procedures? and this we will do.* As for the noise enclosures around our cubers, we have a real problem. Since, in many cases, these are remote to the operator, he has in the past depended on changes in sound levels to notify him of changes in operation. For this reason, the operators leave the doors ajar. This, of course, defeats the purpose of the enclosure. We are in the process of installing running lights on the critical equipment which will solve this problem. When this is complete, we will make certain that all doors remain closed. While Bob was here, an employee mentioned the possibility of formal dehyde exposure from the latex freeze roll operation. The latex being frozen contains 1000 PPM of formaldehyde. After the latex is frozen, it is dropped to a melt tank where it is thawed. This tank is maintained at 110*F. We have ordered sampling tubes for formal dehyde; and as soon as we receive them, we will sample the area. I will report the results to you at that time. Thank you. Fred M. Fister * The antimony compound must have this particular particle size for it to disperse properly in the compound. For this reason, we would not be able to use a less dusty form of this material. PY / cs: R. B. Nash, Jr. (Akron) v H. Waltemate (Cleveland) P. H. Lawrence M. D. Schrader D. P. Anderson V. W. Roberts 26091001 BpG46367 (' ' November 16, 1976 TO: P.H. LAWRENCE LOUISVILLE PLANT On September 20-22, 1976 - Mr. R.B. Nash performed an Industrial Hygiene Survey of manufacturing operations at the Louisville plant. The report of his investigations is attached. I would appreciate being advised of the status of the recommendations. One item not mentioned in this report is that of employee exposure to formaldehyde at the cold roll in the latex building. I would like to have some more information regarding possible exposures and what information the plant needs to resolve any questions. You should note that the odor of formaldehyde is such to provide a fair warning. The presence of a formaldehyde odor would warrant the need for additional s tudy. Please contact me if you have any questions concerning this report. E.B. Katzenmeyer, Jr.\ MM_a___n__.a^ge-r, TIn__ dS-_u__Js___t__ri-a1l THT` ygiene k cc: D. Anderson W.C. Holbrook/K.J. Kaminski J.L. Nelson G.R. Pruitt M.D, Shrader H. Waltemate Attachment: BFG46368 26091002 P.H. LAWRENCE LOUISVILLE, KENTUCKY PLANT PiE>_C) PC'N: DrPT. G uLZG. \S. R.B. NASH,_JR.______ DEPT. 0020, BLDG. 5-H (AKRON) date vouR usrres DATE This LcTTEfl 11-16-76 LOUISVILLE. KENTUCKY - INDUSTRIAL HYGIENE SURVEY On September 20-22, 1976 an Industrial Hygiene Survey was conducted at the Louisville plant. Several dust samples were obtained on veighmen and baggers with checks made for total dust, lead, antimony, chrome; or carbon black. Only the antimony sample exceeded acceptable levels for a short term exposure. RECOMMENDATIONS 1. Require that doors on grinder noise enclosures remain closed. This practice will insure that noise exposure of operating personnel in adjacent areas remain below OSHA exposure limits of less than 90 dBA for an eight hour day. 2. Review chemical pre-weighing operations to make certain work practices and handling techniques are effective in minimizing dust generated during these operations and that they are conducted within the confines of the ventilated booths. 3. The supplier of the antimony compound should be contacted to see if this material could be supplied in a less dusty form. A similar problem involving a lead compound was solved at the Marietta 6PC plant by this kind of product substitution. DISCUSSION Seven dust samples were obtained in the compounding and FVC bagging areas with results shown in the attached Table. The sample obtained on Mr. G. Cottrell, bagging PVC, was well below the 10 mg/M3 recommended for continuous exposure to PVC dusts.. Samples 2, 3 and 7 were obtained on employees working at the new bulk weighing area. Compounds of interest were antimony, lead and Minex F. The sampling results showed that exposures to chose materials were controlled to acceptable levels on an eight-hour time weighted average basis. The single sample for antimony collected during a 45 minute weighing period is noteworthy. The reported value is just below the recommended short term excursion value of 1.5 mg/M*5 and is indicative of the need to tighten up work practices designed to minimize the generation of dust during weighing activities. During this sampling it was observed that individual handling techniques make the difference in dust exposures. The plant should make certain that weighing operations are conducted within the ventilated control area. The new exhaust system appears to be a great improvement over the old pre-weighing area. Samples 4 and 5 were collected on employees working in the color pigment pre-weigh area. This was a well ventilated area as the low chrome results indicates. No further improvements appear necessary at this time. C00T6092 BFG46369 P.H. LAWRENCE 2 11/16/76 DISCUSSION con't A single sample was collected on an employee pre-weighing carbon black in a ventilated booth as the sampling result shows air concentrations of carbon black were well below recommended exposure limits of 3.5 mg/M?. This exposure does not present a inhalation health hazard with respect to carbon black to employees. The noise enclosures around several of the grindershad the doors open to allow the operator to hear changes in the cutters speed which might indicate a malfunction. It is important that these doors remain closed so as to contain hazardous noise inside the grinder enclosures. The practice of allowing the open doors defeats the purpose of the installation and contributes to excessive noise exposure for employees working in areas around the grinders. The plant should investigate the operation to determine the reasons why doors are left open. If this practice is necessary additional engineering controls may be needed to further reduce operator exposure to noise. I wish to thank you and your staff for their cooperation during my visit. k Attachment: Robert B. Nash, Jr. Industrial Hygienist *0 0 1 6 0 9 2 8^046370 TABLE X DUST SAMPLING SEPTEMBER 1976 - LOUISVILLE . KENTUCKY EMPLOYEE JOB G.K. Cottrell East Paste Bagger G. Gray Bulk Pre-Weigh E. Hall Bulk Pre-Weigh G. Gray Color Pre-Weigh W. Whitehovse Color Pre-Weigh B. Bland Carbon Black Pre-Weigh T. Bailey Bulk Pre-Weigh TYPE DUST SAMPLE TIME (MIN.*) PVC 420 Antimony 45 Lead 123 Chrome 347 Chrome 350 Carbon Black 357 Total 358 ALLOWABLE LEVEL 10 mg/M3 0,5 mg/Wp 0-2 mg/M3 0.5 mg/M3 0.5 mg/M3 3.5 mg/M3 10 mg/M3 MEASURED LEVEL 1.6 mg/M3 1.36 mg/M3 0.02 mg/M3 0.005 mg/M3 0.006 mg/M3 0.7 mg/M3 0.9 mg/M3 <CT. BFG46311