Document mB24j0Q5w4mBkzDMEMpaazmVB
The B. F. Goodrich Company
5oo s n u r h
main
s t re et
akro n ,
ohio
a,, ^, 8
AOORESS REPLY 10: OEP1 0020 biOS 5-H
April 22, 1975
0 DISTRIBUTION (ATTACHED):
Dr. Ralph Cook of Dow Chemical Company and I feel that it would be desirable for some of the physicians who are respon sible for employees exposed to vinyl chloride to get together for an exchange of ideas on our testing programs. We feel it would be useful to review our experiences to date and to discuss our plans for the future.
Although the vinyl chloride standard outlines a specific examination, it does allow some latitude on the part of the examining physician, and I am sure that there is by no means
any unanimity of opinion as to how the results should be interpreted.
We are going to meet at the Sheraton-Hopkins Hotel at the Cleveland Airport at 9:00 A.M. on May 13th. We would welcome the medical representative(s) from your company to participate
in the discussion. We have reserved a meeting room at the hotel, but you should make your own travel and lodging arrange ments .
We thought that, at the time of this^ meeting, it might also be
appropriate to discuss the medical aspects of the proposed
EPA vinyl chloride standard.
~'
" - ' 'r`
Since I will be traveling during the next two weeks, please let my secretary know if you or anyone from your company plans to attend. (216-379-3298).
Sincerely,
M. N. Johnson, M.D. Director Department of Environmental Health
v
GENC Q06tll
Jfinyl-Chloride Emissions Would Beirut
90% Under Standard Proposed by EPA
%-
By a Wall Street Journal Sta8 Reporter public exposure to the gas. Vinyl-chlorjde
WASHINGTON--Declaring that a health production is up about 900% from 15 to 20
risk exists for 4,6 million people living near years ago.
,.
,.
vinyl-chloride plants, the government pro In October 1974, after months of fact-find
posed requiring a 90% cut in air emissions ing and hearings marked by, bitter contro
of the cancer-linked chemical.
versy, the Labor Department ordered a cut
The standard proposed by the Environ in worker exposure to vinyl chloride within
mental Protection Agency would require the plant to one*part per million, from the
that the 60 or so existing manufacturers of previously allowed 50 parts per..miljibn. In
vinyl chloride and two sister compounds, dustry officials had warned that the, rulf
ethylene dichloride and polyvinyl chloride, was so harsh it could lead to a total closi install "best available" technology to limit down of plants making PVC plastic vinyl
emissions from their plants. Concentrations chloride gas.
of the chemicals in air around the plants
currently average, less than one part1 per million, the EPA said.. The new standard would reduce that level to about 0.1 part per million. , .
So far, however, only Unlroyal 'Inc. has announced plans to: close aplant rather fhan meet the worker-exposure standards',, It plans to close its Painesville, Ohio, PVC res ins plant by March 1.
Vinyl-chloride gas Is used primarily in The new EPA standard won't be adopted
the plastics industry to . make polyvinyl formally until after a 45-day period for pub
chloride, or PVC, a plastic that is (widely lic comment and a public hearing. Mr.
used in consumer products and construction. Train said he hopes to complete the, process
It has been under intense scrutiny, spurred by late spring. Manufacturing plants .would
in part by a B. F. Goodrich Co. unit report then have 90 days to install ,'the. emission-
in January 1974 that several, of its employes control equipment or to apply for .an exten
had dle<| from a rare liver cancer linked to sion. The agency could grant; extensions of
exposures to thegas
..... ....
up to two years., - ,1, ,
, 1
,,*
. EPA Administrator Russell Train ,'said Industry spokesmen agreed , on the ,nee< mat his agency doesn't _hnow,,precisely,what to restrict plant emissions of, vinyl-chloridi
Level is low, enough to eliminate any cancer gas but at the same time.denied there wa:
frisk but that he hopes the proposed standard any known risk from , such leaks, into. the
Will reduce most of the Cancer cases, traced atmosphere.
,, ' ' ,
to the substance. From one to '20 casesj of "In the Public Interest'?-. ;
^
cancer each, year are attributable to vicinity "We don't believe that there is any cur
exposure to vinyl.chloride, he said.* ,/ . rent, nor has there been any past, risk to the
Cost to Manufacturers . ,
;
health of individuals residing in the proxim
Mr. Train said that meeting the new ity of vinyl-chloride gas and polyvinyl-chlor-
standard would /cost manufacturers about ide-resin plants, but the VCM-PVC produc
$198 million plus another $70, million' each ers agree that rigorous emission controls
year to, maintain the required emission are in the public.interest,''paid Ralph,L.
levels. ,
Harding Jr,, president of the' Society of the
That cost, he said,1 could force) four Plastics Industry Inc. ' ,, r ` ` .
small plants, or ,0.5%. of the industry, to The society'represents makers of 99% .of
close. These ' facilities, according*fo the the vinyl-chloride-monomer and. polyyinyl-
EPA, are Occidental Petroleum Corp.'s poli- chloride plastic made in the U.S- Mr. Hard
vinyl-chloride plant in Hicksville, N.y., and ing said his group views the EPA's action as
three' Janhet Corp. polyvinyl-chloride plants `primarily a precautionary st^p-" But he
in Torrence, Calif.; Tucker, Ga., and Somer noted that the EPA's propose*! standard
set, N.J. The, plants employ a total of 30 hasn't been studied in detail by industry re] -
workers.
resentatives and that further comment wi I
Mr. Train said the agency considered re be made within the normal rule-making pr< -
quiring that emissions he eliminated en cedures preceding imposition of the requir -
tirely but feared that such a stringent stan- irient,
V,
' 11
,rd would effectively close the, entire in- A spokesman for B. P. Goodrich Chemi
istry. Because the lapse1 between exposure cal Co., a unit of B, F, Goodrich Go., said In
t|> vinyl chloride and the appearance of can- Akron, Ohio, "We recognize that there is a
r may be as much as 20 years, Mr. Train need for control requirements and emission
said the EPA couldn't ignore the growing limitations." He said the company expects
to be able to meet the requirements, even
though untried technology would have to be
developed to do It.
Goodyear Tire & Rubber Co., another
major maker, sXid the proposed standard is attainable "and poses no overriding problem
for Goodyear, Which already is well along the way to meeting it" A; spokesman said*in Akron that the company expects to make
"rather substantial" capital expenditures to meet the standard- and that "regrettably, these additional coss ultimately will be re flected in product costs.''
Both companies declined to estimate the cost to- them of meeting the EPA regulation.
Tenneco Ipc. said in Houston that it Is currently id /compliance with some sections, of the proposed regulation and would be able to meet-the rest within the EPA's time Urn-,
bhHC QQ61"A
yf.
INTER-ORGANIZATION
TO. DISTRIBUTION ATTENTION:
FROM: W. C. Douglas DATE: February ^7, 1975 SUBJECT: r strength of Low VCM Products
The data listed below show the strength of products produced .early in 1974 compared to late in 1974 after the VC in the resin was substantially reduced. Fisher Body has been told that a small amount of VC improved .physical properties of PVC products. The data below show this is not.true. The data also show we are low in some of our physical properties compared to the specifications. We should not give these figures to Fisher Body.
It should be noted that T-10812 as produced at Textileather is made from plastisol resin. We do not have a good story on whether the plasti'sol resin differs in VC levels in the period shown.
Textileather Production - Averages
T-9012 Tensile WF
Tear WF
Pilot Samples, Early 1974
97.10 89.57 5.61 4.10
Production After 98.27 91.09 5.24 4.18 September, 1974
Specification
90.00 90.00 5.00 3.50
T-10812 Tensile WF
Tear WF
91.14 83.28 5.76 4.52
96.05 88.45 5.96 4.94 90.00 90.00 5.50 4.50
W. C. Douglas
WCD:jlr
Distribution: J. Weber W. Coder R. Laundrie D. Markus son/
R. N. Johnson^ M. G. Glenn
A. Urbanic
fOHM 1 BOND
GENC 006413 BETTER Service Is Our Business