Document kD5JZQ0xdZjNk0gr9gm8KM2Z0

WRMA RUBBER MANUFACTURERS ASSOCIATION 1901 PENNSYLVANIA AVE N W WASHINGTON, 0 C 200CG (202) 785 2602 VC-3 May 8, 1974 TO*. SUBJECT: Manufacturers and Users of Vinyl Chloride/Polyvinyl Chloride OSHA Program Directive #200-29 Gentlemen: Enclosed for your information is the subject document which provides the guidelines to be followed by OSHA Compliance Officers in inspections regarding the standard on vinyl chloride published on April 5, 1974. Also enclosed are the following: 1. OSHA Program Directive #200-18, "Revised In spection Priorities," dated May 2, 1973. 2. Vinyl Chloride SIC Code Numbers 3. OSHA Questionnaire to be filled out by Com pliance Officers when conducting VC inspec tions to provide OSHA with data to consider in developing a permanent standard. These documents should provide a better understanding of the April 5th Emergency Temporary Standard as well As serving as a guide in achieving compliance. FTR:clc Frank T. Ryan Secretary RMA Occupational Safety & Health Committee GENC 007083 rcXT*9 APR 2 3 1974 April 23, 1974 U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration WASHINGTON, D.C. 20210 OSHA PROGRAM DIRECTIVE #200-29 ---------------------- ---------------------------------------------- -- To: Associate Assistant Secretaries and Assistant Regional Directors/OSH Subject: Citations and Inspections Regarding 29 CFR 1910.93q, Emergency Temporary Standard for Exposure to Vinyl Chloride Attachments: 1. Federal Register, Part 1910: 29 CFR 1910.93q, Subject: , ^"EUmm/ewrngaenn/Mcyr Tempor*a1 ry CS+-toartn^dAavrdd ffor Exposure htoa UV4irntiyfll Chloride," dated April 5, 1974. 2. OSHA Program Directive #200-J.Aj Subject: "Revised Inspection Priorities," dated May 2, 1973. 1 Purpose loride Facilities." In issuanc vinyl chlo .2 Documentation'Affected ding the standard on This directive amends the instructions in the Field Operations Manual and supplements OSHA Program Directive #200-18. 3. Explanation (29 CFR 1910.93q) a. The following lettered, numbered paragraphs are subsections para phrased from the.standards. (a)(1) Area or operation refers to, but is not limited to, activities or processes such as: o Manufacturing or processing of vinyl chloride (VC) or polyvinyl chloride (PVC). o Loading and unloading of VC and PVC (powder in bulk) relative to shipments. o Sampling and analysis of VC and PVC for quality control during their manufacturing processes. o Compounding PVC into powder or resin. GENC 007084 I s"ADVANCE COPY o Pouring PVC poWder-or~res"ih `from bags or containers, * o Packaging PVC resin powder. o Maintenance and repair of vessels and/or reactors containing VC or PVC. o Maintenance and repair of storage silos for PVC, o Leakage of VC in any area, particularly in processing areas. (b) Permissible exposure refers to a ceiling value of 50 parts per million (ppm) of VC. It does not mean a time-weightedaverage (TWA) exposure of 50 ppm of VC with results which fluctuate above and below 50 ppm. (c)(2) , Frequency. Monitoring of a sufficient number of employees so that a representative sample may be determined means that the employer shall monitor at least 75 percent of the production, maintenance, sampling, laboratory and shipping employees on each shift. The employees monitored shall be representative of each operation performed where exposure is likely to occur. Initially, representative employees from every operation should be monitored. Afterwards, where it is established that there is no likelihood of expo sure for employees in certain operations, such as those in ' offices, these employees may be exempted from monitoring requirements. (c)(3) i Method of monitoring. Personnel monitoring refers to measurements made by the employer of employee exposures. Samples should be taken at the breathing zone of the employee at the times when the highest exposures of VC are likely to occur. The standard (or this directive) does not specify the method of analyses that the employer must use; only that the procedure be sensitive to 50 ppm of VC in air with an accuracy of + 20 percent for a 10-minute air sample. ' Citations. * (1) Issuance. Each provision of 29 CFR 1910.93q became effective April 5, 1974. This means that from April 5, 1974, citations may be Issued for any failure to comply, except for monitoring. Which is not required until after April 22, 1974. (2) Categories. In evaluating violations of the standards, the guidelines of the Compliance Operations Manual, January 1972, are to be followed regarding serious and nonserious and grouping. AD r ..-7 COPY anger. Violation of 2(b) and 2(d) df 29 CFR 1910.93q exposes employees to the recognized hazard of VC in excess of 50 ppm. Therefore, such a violation may be considered for possible issuance of a Notice of Alleged Imminent Danger, depending on the facts and circumstances in each case. Circumstances permitting the issuance of a Notice of Alleged Imminent Danger would be where it is determined that employees at their breathing zones are exposed in excess of 50 ppm to VC and are not wearing the required respiratory protection., Supplied air respirators, either in continuous'flow or pressure demand or self-contained breathing apparatus (SCBA)(MESA or NIOSH-approved) are required when concentrations of VC are in excess of 50 ppm. (2) Alleged violations will be supported by compound label infor mation, employee statements, phqtographs, ventilation measure ments, other observed facts, measurements and samples taken. (3) No Notice of Alleged Imminent Danger will be posted where the employer voluntarily eliminates direct internal contact with VC substance(s) by removing the employees or by providing interim measures for their protection until permanent correc tion of the dangerous condition can be accomplished. In the citation(s) that is(are) issued later, the interim protective measures will be required until the date set for permanent correction of the danger. (4) Where the employer refuses to eliminate the recognized hazard, citations will be issued only after initial court proceedings have been concluded regarding the imminent danger. (5) If, on an inspection for any reason after April 22, 1974, it is learned that the employer has not monitored the ambient air and/or the employees, a citation will he issued. It seems most likely that the violation would be nonserious; however, each case must be evaluated on its own merits and becomes a matter of Judgment for the CSHO. * 4. Action (29 CFR 1910.93q) a. Inspections. (1) Any establishment covered by the Act likely to have VC. nav be Inspected regardless of lists (including attachment 3) issued by the Office of Federal and State Programs or Regional Programs. The guidelines of the OSHA Program Directive #200-13 are to be followed regarding inspection priorities. VC shall be included in Special Programs and will precede the Target Health Hazard Program (THHP). GENC 007036 ADVANCE COPY - (2) Inspections will be conducted by only an OSHA or State Agreement industrial hygienist (CSHO). b. Protective Equipment for the CSHO. (1) After April 22, 1974, when the CSHO goes to a VC or PVC plant to make an inspection, the monitoring records should be checked before beginning the inspection or touring the facilities to ascertain the necessary protective equipment, (2) The CSHO ,is required to utilize the principle of safe distance or the organic vapor respirator as protection in areas where it appears from the monitoring records that the exposure to VC is 50 ppm or less. It must be remembered that each cartridge of the respirator is not to be worn longer than 30 minutes. (3) If, from the monitoring records, it appears that there are areas in which the exposures to VC are in excess of 50 ppm, the CSHO shall wear either Type C continuous flow or pressure demand air supplied respirator or SCBA in these areas. (A) ^ , ' Normally, the CSHO would not enter areas where the employer has not monitored. However, if the CSHO must go in for a reason, such as a fatality, and the employer has not monitored, it will be assumed that the level of VC is above 50 ppm. Therefore, the CSHO will wear either Type C continuous flow or pressure demand air supplied respirator or SCBA in these areas, (5) In performing any inspection, the CSHO must exercise good Judgment and make the appropriate evaluation as to the protection necessary for himself. Oftentimes a factor such as distance, in lieu of respiratory protection, can be use ful as a protective measure.. c. Decontamination. When appropriate, the instructions from the manufacturer may be used as guidelines for decontamination or deactivation of VC, d. Monitoring for VC by the CSHO. (1) Personal breathing zone samples should be collected from employees where exposure to VC is likely, A Model SP-1 SIpin personal sampling pump shall be used to collect the sample on NIOSH-approved charcoal tubes. The flow rate of the pump shall be no more than 50 ml/minute and the total sample size approximately 1 liter(l), and/or a sampling time of 20 minutes where a concentration of approximately 50 ppm is suspected. Where concentrations may be greater than 50 ppm, but less than 100 ppm, the sampling time should be 10 minutes; for concentrations greater than * 4* 6ENC 007087 I 100 ppm, but less than 200 ppm, the sampling time should be 5 minutes. All measurements should represent the time when exposures are likely to be the greatest, rather than random exposure throughout the workday. Generally, no more than eight tubes per worker, per day, should be sub mitted for analysis. One or two tubes may suffice if they represent the maximum exposures. (2) It is requested that the charcoal tubes with the vinyl chloride samples be forwarded to the OSHA/NIOSH Laboratory, Salt Lake City (SLC) on the same day that the samples are taken. For shipment of samples to the laboratory, the sample(s) must be placed in a double mailing container and the inner part of the container marked'*. Cancer Causing Substance: Vinyl Chloride." <r Completion of OSHA-35 Form. rlr After each inspection of, tfrr area wherd" VC and PVC are manufactured, processed, use^^repackaged'J "released, handled, or stored, the Area Dire^btfr sha]L promptly-'forward to the Office of Management Data Sys^ms^aCc^rdpleted-'copy of OSHA Test Sample Log, OSHA-35 Form, gi^ingjTthe identification number of the vinyl chloride, 2580. This is majidatorS^-whether or not samples are taken. f'. Questionnaire, The questionnaire (attachment 3) is for the purpose of obtaining information to assist in the preparation of a permanent standard on VC. The CSHO is requested to complete this questionnaire with in 5 days after making an inspection of a VC facility. The ques tionnaire shall be submitted with a completed copy of the OSHA-1 Form to: U.S, Department of Labor Occupational Safety and Health Administration Division of Occupational Health Programing 1726 M Street, N.W., Room 760 Washington, D.C. 20210 v As soon as the results of analyses from samples taken on the inspection are received, an OSHA-35 Form should be prepared and submitted. These forms, OSHA-1 and OSHA-35, are in addition to, not in lieu of, those required by the Office of Management Data Systems. g. Special Problems. Special problems presented during inspections will require inter pretation of the standard in light of the specific situation found. The National Office, Division of Occupational Health Programing, should be consulted on such interpretative problems. -5- GEI-iC 007088 5. Effective Date This directive is effective immediately and shall be retained until fvxther notice. Associate Assistant Secretary for Regional Programs DISTRIBUTION I'al'Uff fee Field n" (3) ' lD% A.sst'/Sec. (2) Assistant Regional Director/GS (3) Rpec. Asst. (1) AARD Technical (2) Associate Asst./Sec. (3) AARD Training (2) Office Directors (3) Division Chiefs (1) SOL (35) BLS (1) Review Commission (6) HEW (1) AARD Federal/State (2) Area/District Offices (3) Training Institute (A) Professional Staff (1) Designated State Agencies NIOSH Regional Program (1) OGO Professional Staff (50) Directors (1) OS Professional Staff (50) SOL Regional Attorneys (1) Review Commission Regional Offices (1) NACOSH Subcommittee (1) Regional Directors (1) (Originator: OGH) V. S -6 GENC 0070S? Attachment 2 'VV1 U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration WASHINGTON, D.C. 20210 May 2, 1973 CPL OSHA PROGRAM DIRECTIVE #200-18 To: National Office Directors and Regional A. dmi inistrators Subject: Revised Inspection Priorities s 1* Purpose The purpose of this directive is to describe a revised system of inspection priorities and to provide instructions for implementation. This constitutes the first formal revision of the Occupational Safety and Health Administration (OSHA) original inspection priorities and Is necessitated by the changing requirements of the compliance program. Recently established program elements, (Special Emphasis Program, "Re gional Selection"), have been incorporated in the revised system and needed new categories, such as Temporary Emergency Standards, have been formally recognized. Implementation instructions include specific instructions provided in the various categories and general instructions pertaining to the system of inspection priorities. 2. Documentation Affected This directive revises the instructions given in the Compliance Operations Manual, Chapter IV, Sections A and B and supplements Program Directives, #200-13 and #200-14. 3* Background In the course of the last 6 months the Office of Federal and State Operations has reviewed the recommendations submitted by a number of task forces. Some of these recommendations have been circulated for internal review and were discussed at periodic meetings. The comments and suggestions of Regional Office and National Office officials have been taken into consideration. The revised system described here is the result of these deliberations and reflects the consensus of the thinking invo1ve d. 4, Action a. OSHA Inspection Priorities. (1) Investigation of Evidence of Imminent Danger. (2) Catastrophe and Fatality Investigations. (3) Investigation of Valid Complaints. (A) Special Programs. o Regional Selection * o Special Emphasis Programs (Such as Trenching and Excavation Cave-ins) o Temporary Emergency Standards o Target Health Hazard Program (THHP) o Target Industry Program (TIP) _ NOTE: The Special Programs listed shall be given equal priority. (5) Random Selection. . b. Specific Instructions for Implementation. / (D The following guidelines shall be utilized in the investi gation of catastrophes and fatalities. An investigation should be scheduled if any of the following conditions exist. (a) Total combination of five or more fatalities or five or more employees hospitalized, or (b) Those involving significant publicity, or (c) Frequently recurring incidents of like nature, or (d) Specific instructions issued for fatality and catastrophe investigations in connection with any Special Program. '(2) The Deputy Assistant Secretary shall be notified prior to under taking any major activity in "Regional Selection". Semiannual reports (due December 31 and June 30 of each year) shall be for warded to the Office of Federal and State Operations, Include the following information: (a) Brief, narrative description of the activity. (b) Brief description of significant problems. (c) Possible suggestions (optional) which may be useful in similar industries or operations. c. General Instructions for Implementation. (1) Percentage guidance for the five categories is not given at this time. Regional Administrators should make the necessary' arrangements for adequate servicing of all priority categories. GENC 007091 (2) The policy concerning reinspection and followup inspections is currently under study. ' Instructions appearing it. Program Directives, #200-13 and #200-14, should be considered as gunrante pending revision. (3) The following priorities shall be utilized for ininstrial hygienist personnel. (a) Despond to complaints. (b) Respond to critical CSHO and NIOSH referrals. (c) Special Programs inspections. (d) Respond to referrals of noncritical nature. (e) Random selection. */ -r (4) In the event special data reports are needed for such program; categories as "Regional Selection", Regional Administrators should contact the Office of Management Data Systems and rectoest a compilation of the data reports needed. Effective Date This directive is effective July 1, 1973 and shall be retailed until further notice. The information contained in this directive will be incorporated into the next scheduled revision of the Compliance Operations Manual. Chain Robbins Deputy Assistant Secretary DISTRIBUTION: National Office Field A/Sec. (3) Regional Administrator C3} Dep. Asst./Sec. (2) ARA Technical (2) Spec. Asst. (1) ARA Compliance (2) Associate Administrator (1) ARA State (1) Directors (3) SOL (35) BLS (1) Area/District iffices (3> Training Instimte (4) Professional Staff (1) Review Commission (6) HEW (1) 0G0 Professional Staff (50) OS Professional Staff (50) Designated State Agencies (I) NIOSH Regional Program Directors (1) SOL Regional Attorneys (!') Review Commission Regional Offices (1) NACOSH Subcommittee (l) Regional Directors (1) (Originator: OGP) VINYL CHLORIDE SIC CODE NUMBERS Attachment 3 This list is not all inclusive, or restrictive. It gives some preliminary indication of where vinyl chloride (VC) monomer can be found. Many other locations will have vinyt\chloride or poly vinyl chloride (PVC) powder or substances^dontaitiing free vinyl chloride gas. . \ Cfi ^ Vinyl chloride is shipped as a gars it/rank c^r^lots. Polyvinyl chloride is shipped as a dry^powdcY ih'"Jbags', barrels, and in bulk which may give off some vinylrChloride .gbs. Polyvinyl chloride is also shipped as a sriurry'*ph/'suspension, but this does not likely pose a vinyl chloride^ga^^xo'blera^ Many firms wil<T housing polyvinyl chloride powders which release the gas (VC) wiWn fch& batf or container is opened and the powder is poured. Vinyl cr^lor.ide gas may also be released during the mixing and blending operations. After molding, it is believed that there is no problem with vinyl chloride gas in the finished product. SIC Number 2821 5029 2851 3292 3079 2818 2813 3357 Industry Polyvinyl chloride and vinyl resins Gases, compressed and liquified Plastic base paints Vinyl asbestos tile Polyvinyl film, pipe; molding plastics Industrial organic chemicals Industrial gases Insulated wire GENC 00709 Attachment 4 QUESTIONNAIRE: VINYL CHLORIDE (VC) AND POLYVINYL CHLORIDE (PVC) FACILITIES 1. General Plant Layout: a* Is it an outdoor facility? b. How long has the plant been in operation? ________________________________ c. Is the equipment corroded? ______ t f d. Is the equipment in need of maintenance? _______ Specify: e. Is the housekeeping good? _______________ Poor?__________ In which aspects? ______________________________________________________________________ f. Where is the control room located? g. Other pertinent details re general plant layout: GEHC 007094 .2 Raw Materials \DV COPYTit TVI^'P i.' a.;- a. Indicate the raw materials; b. How are these handled? c. What provisions is made for their storage? _______ Silo? _______ Tank? ________ Car? Bags? _______ Pressure area? ________ Other? d. What controls are enforced while these materials are in storage? e. Is entry to storage facilities accomplished with an air supplied mask? If not, how? _________________________ _______ f. How are withdrawals of raw materials controlled? ^ Closed system? ______________ Exhaust system? Out of doors? ___________ Other? GENC 007095 3. Manufacturing Process a. What process is used? VC: Direct chlorination? Oxychlorination? ____ Other? ____ PVC: Polymerization? Wet? ____________ Dry? ^ Other? b. What is the method of recycle for the unreacted vinyl chloride? c. In what form is the finished product? Powder? Pellets? Gas? Other? d. How is it shipped? e. What are the container sizes? 4. GENC 007094 COPY 4. Controls for the Containment of VC and/or Control of Reaction a. What controls are utilized? ____________________________________ Describe; ____________________________________________________________ Are the controls a.rranged to fall-safe^ b. Are two sources of supply provided for? ___ Cooling water? ____________ _____________ Electricity? _____________________________ Compressed air? ___________ _____________ Refrigeration? ____________ _____________ \ Are they automatic? ____________________ c. Where is the control room/area located? la it at positive pressure with respect to contaminated areas? Is it at least 200 feet from major VC storage or processing? _ d. Are written control/startup/shutdown procedures available to operating personnel? GENC 007097 . ADVANCE COPY 5. Ventilation a. What is the type of ventilation system? _____ Is it adequate? b. Where is the air exhausted? Is the air treated before exhaustion? _____________ _____ How? c. Is makeup air introduced in sufficient volume to maintain correct A operation? _________________________________________________ ___________________ Where does the makeup air come from? Is It treated? How? Is it heated in the winter? d. Is the entry air to the control room treated? How? ' GENC 007090 1 6. Waste Materials a. What is the disposition of waste materials? I Buried? Burned? Where? City dump? How?' *i Other? Describe: Treated? How? Specify: Other pertinent specifics relative waste materials: ' GENC 00709? f itrvl 7 K TV^T? r*OPY JP: }JJ V h. 7. Sanitation a. What sanitation facilities are provided? _ Shower? ___ Washroom? Change room? Individual lockers? Lunchroom? Drinking fountains? Toilets? b. Comment on location, accessibility, adequacy, utilization, condition, etc. of pertinent sanitation facilities: ____ GENC 007100 AD v j V \i i A 'j v 8. Exposure to VC a. In which activities is there a potential for exposure to VC? How many employees are involved in each activity? What is the length of the potential exposure time? b. Are the activity areas regulated? Indicate which* _____________________ Give the rationale for establishing these: c. Are all employees generally aware of the hazards presented by VC or PVC? To what extent is labeling or posting Of signs used to appropriately\^ Inform or warn employees? GENC 007101 Protective Clothing and Equipment*. a. What articles of protective clothing and equipment are the employees provided? _______________________________________________ Are they required to wear or use these? Do they wear or use these? Specify b Do employees change into work clothes upon arrival at the plant and back into street clothes before departing? c. Do they shower at the end of the day? d. Do they wash hands and face before eating lunch? Where do they eat lunch? ______________________________ f. How are clothing and equipment articles cared for? (1) How often cleaned? _______ How? ___________________________________ Where? _______ _________________________ (2) Are they decontaminated after use? Which use? When? Where? I ' J V* .1,1 9. Protective Clothing and Equipment*--Continued g. How often are the articles replaced? What determines replacement? < * Respiratory protection devices are covered in question 10--omit here. \ \ S GENC 007103 ADVANCE COPY .10 Respiratory Protection a. What kind of respiratory protection devices are provided? Are the respirators provided specific for protection from VC or PVC? ________________ ______________ __________________________ ' ,/ Explain; |__________________________ _________________________________________ What respirators are utilized by the employees? b. "Is there a training program for employees -which includes the proper wearing of respiratory protection devices? _______________ c. How often are the respiratory protection devices checked for efficiency and effectiveness? , If applicable, how often are cartridges or cannisters replaced? d. Other comments: SENC 007104 / i f 11. Maintenance and Decontamination Activities a. What procedures are established for maintenance and decontamination? Are there periodic Inspections for the: Ventilation system? _________ Process equipment? Piping and fittings? Other? ___ b. , What transpires when leakage occurs? c. What provisions are there for the protection of employees in cleanup of leaks or spills, maintenance or repair operations on contaminated systems or equipment? ____________________________ What protective clothing and equipment are utilized? Air supplied suits? Gloves? Respirators? _________________ _____ , Others? d. How are employees decontaminated after work is completed? GENC 007105 ADVANCE COPY ii. Maintenance and Decontamination Actlvlties--Gontinued e. Are maintenance repair cleanup crews available during all shifts? GENC 007106 ADVMTCE COPY .12 Fire Protection a. What provisions are made for fire protection? Who approves the fire protection plan? ' b. Who conducts fire inspections? What is the frequency of the inspections? I c. Are there fire insurance engineers? Give particulars; ____________________ GEhC 007107 t .ADVANCE 13. Employer Monitoring a. What is the method of sampling? Are grab samples taken? _______ * How? Are continuous samples taken? How? If sensors are used, where are they located? __ b. Are personal samples taken? .______________ '_________________ . How? __________________________ For how long? What is the sampling rate? ___ ____________________________________ What areas of activity are the employees In when monitored? What percentage of employees are monitored in each area? What is the frequency of monitoring? ____________________________ c. What method is used to analyze the samples collected in the monitoring program? ______________________________________________ What is the sensitivity? What is the accuracy? /________ ______ ___________________ d. What is the disposition of the results of sample analyses? G'EfC 00?10s Employer Monitoring--Continued Are the employees informed? Are the results recorded? ____________________ ` Where are the records kept? ______________________ How long are records of the results maintained? Are the results available at all times to the employees? ,4 \ ** r 14. Medical Program ATYVnv^rvJl A. J-.V ui* V .-i--J COPY\^y*V'c-> J _ a. What does the ln-house medical program consist of? Are physical examinations of employees required? Preplacement? _______________________________________ < Periodical? __________________________________________ What does the physical examination include? Is there a medical surveillance program in effect? __________ What does it consist of? |_______________________________ ________ __ ^ Does the employee have access to his medical records? ______ 'v Is there a physician and nurse on duty at all times? _______ - If not, when? _____________________ . How many employees are trained in first aid? b.. What satellite-support medical facilities are readily available? What is the distance to the nearest hospital which would be readily available at any time? '___________________________ Would adequate, appropriate, medical services be available there? ___________________________ _____________________________________ Is there a contract or working agreement in force with this facility? ______ ;................... ........................... .................. ...................... Other comments; GENC 007ii0 15. Emergency In the event an emergency should occur for any reason within the operation Vhereby employees are involved, what plan would be implemented? ]______________________________ . a. Is there an evacuation plan? ________________ _____________________________ b. Are there definite emergency procedures established to inclbde authorization for individual control of assigned personnel? c. Is there a mutual support plan for outside assistance in the event of a catastrophic incident such as fire, explosion, massive spill? Explain: GENC 0071