Document k912VmDKv1dZowQv48yokNgMV

Washington D.C. Vinyl Chlorid Hearings Week of June,25. 1974 fj! I am Mr. Williams, Vice President, Olin Corporation. I will present information and evidence relative to the "proposed standard for vinyl chloride" (29 CFR Part 1910) (Docket OSHA-36) "as published in Federal Register of May 10, 1974." W appreciate this opportunity to express our views. Olin's Chemicals Group operates a polyvinyl chloride (PVC) plant employing 198 people near Assonet, Mass. The plant produces PVC resin powder from vinyl chloride monomer. At this same location PVC pipe is produced from the resin Olin also operates two other PVC pipe plants located at Carrollton, Ohio and Miami Florida, employing 109 and 62 people respectively. All of the aforementioned facilities were purchased by Olin between 1967 and 1969. Shortly after the purchase of these plants, Olin discovered 3 cases of acroosteolysis, a bone extremety disease caused by continued direct contact of the hands with vinyl chloride. Measures instituted by Olin have prevented new cases of this disease. A morbidity and epidemiological study among present employees and all former employees who could be traced, reveals no known cases of angiosarcoma of the liver nor any other occupational related disease. Some of the employees have worked in the Assonet PVC plant for as long as 9 years. (Also some employees had worked in a PVC plant for 11 years before moving to Assonet.) OU 1574 -2- Since announc roent, in January 1974, of th probable r lationship betw en vinyl chloride and angiosarcoma, Olin has instituted administrative procedural and engineering changes which have: significantly reduced vinyl chloride levels in ur Assonet plant. When completed, these changes will have cost Olin about $300,000. Currently, vinyl chloride levels are well below the 50 parts per million (PPM) emergency ceiling established by OSHA in April 5, 1974 Federal Register. Emergency air masks are readily available for use if excursions above 50 ppm occur. Olin requires the use of a full face air mask during reactor cleaning A thorough medical monitoring program had already been established. Atmospheric testing programs at our PVC pipe plants have revealed very low levels of vinyl chloride, usually ranging between 0.2 to 1 ppm with occasional readings as high as 4.5 ppm. Olin is committed to providing a safe healthful work place for its employees. However, we believe that many provisions of the proposed vinyl chloride standard are unnecessarily restrictive and technically or economically infeasible. The evid nc presented by the Society of the Plastics Industries (SPI) supports this contention. Olin is in full agreement with the position represented by the SPI evidence. In particular, we believe the proposed gradual reduction of VC concentation in the work place to a 10 ppm time ,ge (TWA) and 25 ppm ceiling is feasible for Olin to achieve and a safe level for employees based on known scientific and medical evidence. OLI 1575 - 3- If a detectible level standard (1 ppm or less) is imposed, it would be necessary for Olin to close its Assonet plant, thus affecting the jobs of 369 people. Our estimate of cost to achieve under 1 ppm vinyl chloride in the work environment is 5.6MM dollars. The replacement (original) cost of this plant is estimated to be. It is evident that the ratio of plant investment to "fix up" cost is unreasonable. Furthermore, technical feasibility is assumed, it is not known that specific measures considered and costed out will in fact achieve the desired results. Thus the cost could be higher. To achieve a TWA VC level of 10 ppm it will be necessary for Olin to spend about 4MM in addition to the $300,000 already spent. As you can see, this is a more reasonable cost compared to original plant cost, yet represents a considerable burden that will be passed on to the consumers of PVC products. The SPI presentation covered other provisions of the VC standard, however, ther are several elements which Olin believes must be emphasized further. These are: 1910.93q (b) (9) (h) (1) (2) (ii) (iii) and (3) (i) (3) OL1 1576 PARAGRAPH Number 1910.93q I (b) (9) "Exposure" means actual contact with vinyl chloride when unprotected by required personal protective equipment and dde^tthhUrthgaLll ^ ) i I i i i i l* 1 * MrCTION i GROUNDS Limits of time and amount of vinyl chloride It is obviously not feasible to determine actual necessary to constitute an "exposure1* are not contact with an infinitely small amount of vinyl included in the definition. Also there is no mention of vinyl chloride gas versus vinyl | chloride for an ia^iitely short time with a con fid! ence limit of 95 percent. Either the definition of chloride liquid "exposures". . "exposure" or the requirements in regard to monitoring or both should be changed. The definition of "exposure" could be accepted if 1910.93q (e) (2) did not require "any exposure" i The definition of "exposure* also relates to 1910.93q to be determined with a confidence level of 95 percent. ' (g) (2) pertaining to reporting of Incidents inv Iving | "potential employee exposure." Everything that is done I in a polyvinyl chloride polymerisation plant has the I "potential" for actual contact with vinyl chloride. I It is suggested that the term "Exposure" could be dei ! fined as follows: "Exposure" means actual contact with vinyl chloride gas in a concentration exceeding the allowable, limit in the work environment, or actual contact of the skin with sufficient vinyl chloride liquid to result in vinyl chloride gas concentrations exceeding the all wable limit in the air adjacent to the employee having such contact. OLI 1578 PARAGRAPH Number_______________________________________________________ 2 | (h) Protective clothing (1) employees entering re gulated sreas shall be provided full-body protective clothing footwear or shoe covers, .and gloves, at J J| no cost to them, and requlrM to won It while in * the regulated area. (h) (2) Where polyvinyl chloride powder containing detectable levels of vinyl chloride is handled, All I A employee shall also be: S^ (i) Provided and required to wear head coverings; (ii) Required to remove all protective clothing at JECTION The specification "protective against vinyl GROUNDS I An brdinary loosely fitting coverall will stop drop chloride", as defined in (b) (13) is not suf lets of vinyl chloride liquid from contacting the ficient for an employer to provide to a supplier of clothing to be sure of meeting the require skin: the droplet will vaporise from such clothing into the surroundSng sir since the boiling point of ments of the proposed regulation. vinyl chloride la -13.8C (+7F). Would clothing that would prevent contact of vinyl chloride liquid in amounts reasonably likely to be encountered In normal operations be, n rmally suffic ient, and a different type of protective clothing in case of accidents? Does protective cl filing have to protect against exposure (actual contact at any con centration) or only keep the vinyl chloride gas concentration between the clothing and the skin below the approved limit of vinyl chloride? "head covering" In non-descriptive. Vinyl chloride has a very low boiling point Generally, hard hats are worn by employees, and th a t are not always compatable with the use f respirators. Specifically, what type of "head covering* may be used to satisfy this requirement? Since vinyl chloride has a low boiling point (-13.SC) J^RAGRAPH Numbereach exit from the regulated area; -( I1 * 5 and (iii) Required to shower after the last exit of the day. OBJECTION GROUNDS 1 and will readily vapor!re, therefore, flow will sufficient 1 (+7F) , clothing that has been contaminecT^^ one ly decontaminate any contaminated areas, making it unneces or a few drops of vinyl chloride liquid may be sary to remove all protective clothing at each exit from the decontaminated by normal or induced evaporation. regulated area. Unnecessary - vinyl chloride vaporizes rapidly, therefore, a The objective of the proposed regulation is primarily shower would not help to protect against exposure. to protect against excessive expoaure to vinyl chloride. Since there would be no vinyl chloride present by the time an employee reached the ahower room, a shower would serve no useful purpose. 6 (3) Clean protective clothing shall be provided whenever contaminated or soiled, ! but not leas frequently than weekly. i Contaminated clothing shall be decontam1 inated before reuse by removal for laund- ering or disposal. 7 0) (3) Storage or consumption of food or beverages, storage or use of smoking Laundering for the purpose of decontaminating clothing is unnecessary as vinyl chloride vaporize before laundering can be accomplished. Unnecessarily restrictive. A shower may be desirable for personal hygiene rea sons , but not for the regulation of exposure to vinyl chloride. Physical characteristics of vinyl chloride are such that decontamination can be accomplished by natural evaporation. i The rapid rate of evaporation of vinyl chloride precludes any likely hood of exposure by ingestion OLI 1579 .GRAPH or non-food chewing products, and the storage or application of cosmetics are prohibited in regulated areas. ' I 1 to 1 OBJECTION GROUNDS or by skin absorption. Therefore, it seems unneces sarily restrictive to deny the use of such materials in areas where the atm^phere Is normally below the allowable limit of vinyl chloride. I* 1 \ i OLI 1580 I P^hGRAPH i 4-------------------------------------------------------------------------------------- ---------- -- or non-food chawing product#, and the storage or application of cosmetics are prohibited in regulated OBJECTION GROUNDS or by akin absorption. Therefore. it seams unneces sarily restrictive to deny the use of such materials in areas where the atm^phere la normally below the allowable limit of vinyl chloride. * t 4 L/l 00 no