Document mqZjkRBe4Lb2aoRzYGB1jQ4Ed

socma SYNTHETIC ORGANIC CHEMICAL MANUFACTURERS ASSOCIATION. INC. 1075 CENTRAL PARK AVENUE. SCARSDALE. N. Y. 10583 (314) 725-1492 November 30, 1977 TO: OFFICIAL REPRESENTATIVES ECONOMIC IMPACT OF QSHA PROPOSAL Gentlemen: As you know, the Occupational Safety and Health Administration (OSHA) has recently proposed regulations for identifying, classifying and regulating suspect carcinogens (cancer-causing substances). The proposal, which has serious potential consequences for both manufacturers and users of chemicals and chemical-containing products, is one of the single most important documents published in recent years, for it is expected to be the basis for a national policy on carcinogens to which all federal agencies will subscribe. The proposed regulations establish criteria for classifying substances and require regulatory consequences to flow automatically therefrom. The proposal authorizes OSHA to ban substances where there are "suitable11 substitutes and to require that exposures be reduced to the "lowest level feasible." Industry, of course, collectively and individually recognizes its responsibility to provide workers with a safe workplace, free from recognized hazards, particularly known, human carcinogens. However, it is believed that the OSHA proposal will, because of its unscientific criteria, unfairly indict a substantial number of substances and that it is seriously deficient in other ways as a matter of science and policy. Further, the economic cost of the proposal to Industry is likely to be substantially out of proportion to any possible achievable benefits. A broad-based industry committee the American Industrial Health Council, with which SOCMA is cooperating, has been formed to address the scientific, legal and economic questions raised by the proposal. This Council is urging, and we urge, that each of you file comments and/or participate at the scheduled hearing on the OSHA proposal. As many of you know, the sheer number of comments filed, particularly by small businesses, plays an important part in agency decision-making. We recognize that many of you may not be able to address the complex scientific and legal issues raised by the OSHA proposal. However, we believe that each of you can, and should, at least address the economic impact of the proposal on your business or on particular products you make or use. Experience has shown that economic arguments made by industry, particularly small businesses, can also significantly impact agency decisions. AP00048341 2- - To assist you in addressing the economic questions, the industry committee has retained the consulting firm of Booz, Allen & Hamilton, Foster D. Snell Division, to prepare guidelines which will assist you in filing comments with OSHA and participating in the hearing, Enclosed for your use are Guidelines which summarize the key provisions of the OSHA proposal and focus the economic impact for you, Also enclosed is a set of forms to assist you In calculating the economic Impact, Instructions for use of the forms are contained in the Guidelines. Also enclosed is a computer printout which attempts to both separate the major commercial chemicals from NIOSH's Tumorogenic Subfile and indicates EPA's ranking of the test results on which the listing was based. We believe the enclosed materials will greatly expedite your understanding of the proposal and simplify the task of economic impact analysis. If you are not able, within the time frame allotted by OSHA, to precisely quantify the economic impact, less than precise or qualitative analyses should nonetheless be submitted to OSHA, focusing, perhaps, on job and foreign trade impacts of the proposal. The industry committee has also asked Booz, Allen to prepare a broader economic impact study of the OSHA proposal. If you would like to cooperate in this effort for any of the products which you make or use, you should complete the enclosed forms and send photocopies to one of the individuals at Booz, Allen noted below as soon as available. Booz, Allen has executed a confidentiality agreement in which they have agreed to maintain the confidentiality of all the information they receive. No information will be related to a specific company without that company's approval, and access within Booz, Allen will be limited to authorized personnel. Written comments to OSHA are due January 30, 1978. Persons who intend to appear at the public hearing on the proposal, scheduled to commence on April 4, 1978, are required to file a notice of intent to appear, and, if they expect to testify for more than 15 minutes, file their full testimony by January 30, 1978. OSHA may decide not to exclude from the rulemaking record submissions made after these dates, but you should nonetheless make every effort to meet these deadlines. If you have any questions on the enclosed materials, you should feel free to contact either Ron Kensicki or Phil Gisser at Booz, Allen (201) 377-6700. We appreciate your assistance and cooperation on this very important project. Sincerely, Enel. c /Ronald A. Lang ' Executive Director AP00048342 STANDARD GUIDELINES FOR DEVELOPMENT OF DATA BY INDIVIDUAL COMPANIES ON THE ECONOMIC IMPACT OF THE OSHA GENERIC CARCINOGEN PROPOSAL Prepared for: Industry Task Force on OSHA Generic Carcinogen Proposal November 1977 Prepared by: Booz, Allen & Hamilton Inc. Foster D. Snell Division 66 Hanover Road Florham Park, New Jersey 07932 AP00048343 TABLE OF CONTENTS SECTION I II III IV TITLE INTRODUCTION GENERAL INSTRUCTIONS KEY PROVISIONS OF THE PROPOSAL THAT AFFECT DIRECT COSTS SPECIFIC INSTRUCTIONS TO COMPLETE FORMS A. DESCRIPTION OF FORMS TO BE COMPLETED BY YOUR COMPANY B. NONENGINEERING COST CONTROL CALCULATION GUIDELINES C. ENGINEERING COST CONTROL CALCULATION GUIDELINES D. ADDITIONAL ECONOMIC EFFECT GUIDELINES PAGE 2 5 8 11 11 12 14 16 APPENDIX A ECONOMICALLY SIGNIFICANT SUSBTANCES LISTED IN NIOSH LIST SUSPECTED CARCINOGENS A-l APPENDIX B SUGGESTED OUTLINE FOR INDIVIDUAL COMPANY COMMENTS OR TESTIMONY ON THE OSHA GENERIC CARCINOGEN PROPOSAL FOCUSING PRIMARILY ON ECONOMICS B-l APPENDIX C * FORMS FOR CALCULATION AND REPORTING ** C-l * If further information or clarification is desired on any facet of these forms, contact one of the following Booz, Allen people. Contact Business Phone Extension Ronald Kensicki 201/377-6700 260 Ronald Rubin Philip Gisser 201/377-6700 201/377-6700 283 205 AP00048344 I. INTRODUCTION Puroese A broad-based industry committee was formed to address the scientific, legal, and economic questions raised by regulations proposed by the Occupational Safety & Health Administration (OSHA) for the identification, classification and regulation of suspect carcinogens (cancer causing substances^, hereinafter described as OSHA Generic Carcinogen Proposal. It has re tained Booz, Allan i Hamilton, roster D. Snell Division, to prepare these Guidelines and the enclosed forms. The principal purpose of these materials is to assist you in analyzing the economic impact of the OSHA proposal on your company or on products you make or use. The attached materials are designed to facilitate your understanding of the OSHA proposal and focus your thinking on economic impact. You are urged to prepare and file comments with OSHA and/or to participate in the public hearing scheduled for the proposal using the enclosed materials as guides. Experience has shown that sound economic arguments, particularly for smaller businesses, can significantly impact agency decision. The industry committee has also asked Booz Allen to prepare a broader economic impact analysis of the OSHA proposal. If you would like to cooperate in this effort, the enclosed forms should be completed and photocopies sent to Booz, Allen on a confidential basis, by early December. Background On OSHA Proposal In the Federal Register of October 4, 1977 (42 Fed. Reg. 54147), OSHA published its Generic Carcinogen Proposal. Abandoning its previous substance-by-substance approach to regulating chemical substances in the work place, OSHA, through these regulations, proposes to establish a vehicle and framework for future rulemakings which will enable it to move expeditiously. The regulations Bet forth criteria for determining whether a substance is a carcinogen, establish a classification scheme for suspect and known carcinogens and require certain regulatory actions to be taken following such classification. There are attached to the proposed regulations model standards to be used by OSHA as essentially fill-in-the-blank modules for standards on individual substances. Once adopted, the proposed regulations should lead to a flurry of regulatory activity, the focus of which will probably be a List of Suspect Carcinogens published by the National Institute for Occupational Safety and Health (NIOSK), numbering in excess of 2400 substances, and which has been growing at the rate of 100 substances a month. The regulations represent OSHA's proposed resolution of many complex scientific and legal issues. Once resolved in this rulemaking, those Issues may not be open to further question in subsequent rulemakings on individual substances. The criteria, classification scheme, and regulatory consequences in this proposal will apply to all subsequent OSKA rulemakings on suspect carcinogens. Indeed, given recent public pronounce ments on the need for cooperation and harmonious policies between federal agencies on toxic substances, the OSHA proposal may well form the basis for a national approach to similar regulations for all federal agencies. The proposed regulations will establish criteria for classifying substances and require regulatory consequences to flow automatically therefrom. The proposal authorizes OSHA to ban substances where there are "suitable" substitutes and to require that exposure be reduced to the "lowest level feasible." These two terms are not defined by OSHA. While the industry committee recognizes its collective and individual responsibility to provide workers with a safe workplace free from recognized hazards, particularly known carcinogens, it believes that the OSHA proposal might result in the improper classification of a substantial number of substances and that the proposal's economic costs might be out of proportion to its possible benefits. Participation In Rulemaking Written comments to OSHA are due January 9, 1978. Persons who intend to appear at the public hearing on the proposal, scheduled to commence on March 14, 1978, are required to file a notice of intent to appear, and, if they expect to testify for more than 15 minutes, file their full testimony by January 9, 1978. Although you should make every effort to meet these deadlines, we believe, although OSHA has not so stated, that it may decide not to exclude late submissions from its rulemaking record. Written comments should be submitted in quadruplicate to: Docket Office Docket No. H-090 Room S-6212 U.S Department of Labor 3rd Street s Constitution Avenue NW Washington, D.C. 20210 (1) The due date for written comments and notices of intent toappear noted in the Federal Register of October 4 has been extended from December 8, 1977 to January 9, 1978. -2 - AP00048345 Notice of intent to appear at the hearing and testimony should be submitted [in quadruplicate) to: OSHA Office of Consumer Affairs Boom N 3633 U.S. Department of Labor 3rd Street Constitution Ave. NW Washington, D.C. 20210 How To Use This Document For Use 3y Your Company in Preparing Written Comments and/or Testimony You will save time in this endeavor by following the steps described below. Make copies of the forms in Appendix C, and keep a clear original. You may need multiple copies of some sections. Select as many chemicals as you feel you can analyze for internal case study from the ninety-nine chemicals listed with their alternate names in Appendix A. These chemicals, all of which appear on the NIOSH List of Suspect Carcinogens, are ones Booz Allen believes to be economically significant. There may be other chemicals on the NIOSH List which are not listed in Appendix A but which may be significant to your company. You should, therefore, carefully review the NIOSH list. . Fill out this set of forms for each substance selected. If two of the substances are encountered in the same plant unit, one set of forms is sufficient. . Aggregate the total compliance costs for each case study substance, as shown on Form vi. The ratio of compliance costs to current costs, as well as the other ratios indicated, can be presented in your submission. Submit written comments for the record (due January 9, 1973). . If you intend to testify at the public hearing, notify OSHA of your intent to testify (due January 9, 1978). If you intend to testify at the public hearing for more than 15 minutes, file full testimony (due January 9, 1978). . Testify at public hearing commencing March 14, 1977. . Retain file copies of all information collected and submissions made. If You Elect To Participate In The Broader impact Study By Booz, Allen If you elect to cooperate with the Booz, Allan study, please follow the procedure outlined below: . Select two or three dissimilar ease study substances for analysis at your company. . Inform either R. Kensicki or P. Gisser (201-377-6700, extension 260) at Booz, Allen that you are planning to analyze seLected case study substances at your company. . Assign one individual responsible for getting the data and returning it. He will probably need the cooperation of plant and engineering people. For chemical producers, marketing people might provide some necessary inputs. U.S. Department of Health Education and Welfare Suspected Carcinogens, A Subfile of the niosh Reqistrv of Toxic Effects Of Chemical~gubstances7^'nd Edition, Washington, D.C. U. S. Government Printing Office, December 1976, HEW Publication Number (NIOSH) 77-149. -3 - AP00048346 Make copies of the forms and keep a clean original. will probably need extra copies for some sections. You Identify the plant units in which you make or use any of your selected case study chemicals. Fill out forms for each plant unit identified. Return these forms by early December 1977, to: Foster D. Snell, Division Boos, Allen i Hamilton Inc. 66 Hanover Road Florham Park, New Jersey 07932 Attention: Mr. R. Kensicki The information returned will, of course, be analyzed confidentially by Booz, Allen s, Hamilton Inc. Details of the confidentiality procedures follow: All information will be confidential and access will be limited within Booz, Allen and Hamilton Inc., on a need-to-know basis. . Only one page carries company identification. This page will be separated from the rest and kept in a locked file for use only by authorized personnel if follow-up is needed for clarification. . The other pages will be assigned identification numbers. Personnel involved in data processing and analysis work will have access only to those numbers. The final report will not attribute information to a Specific company or identify any individual source without the company's authorization. . The original records will be returned to you when the report is completed, and no copies will be retained. -4 - AP00048347 IX. GENERAL INSTRUCTIONS The forms in this package refer to the cost of compliance with OSHA's Identification, Classification and Regulation of Toxic Substances Posing a Potential Carcinogenic Risk. This form is organized to collect economic 5ata for each of the-products manufactured at your plants that may potentially be affected by the proposed regulation of substances. Substances for case study should be selected by your company from the following: ,, . Economically Significant List -- In Appendix A substances are listed that are on the NIOSH Suspected Carcinogens list and judged to be economically significant on the basis of total CJ.S. production and the number of total employees associated with their manufacture or use or both. Your company may wish to select applicable substances from this list and present one or more case studies. . other Substances -- In the NIOSH publication Suspected Carcinogens, 1976, over 2400 substances are listed that may be regulated under the proposed act. There may be other substances not listed in the NIOSH document that your company may want to study. The manufacture and use of these substances may have specific impact on your company. For each of the case studies selected, one set of forms should be completed for each production plant at your company that is associated with the substance under 3tudy. The substance may be: Manufactured at the plant (e.g., as a product, by-product or co-product) . Used at the plant (e.g., as a raw material) Present as in-process material (e.g., as a solvent, formulation or impurity) . Handled for wholesale or retail distribution. Therefore, your company may complete more than one set of forms depending on the number of plants that are associated with the case study substance. For example: . Only one set of forms may be required for a case study substance if it is used, manufactured, present or handled at only one plant site of your company . More than one set of forms may be required for a case study substance if it is used, manufactured, present or handled at more than one plant site. Cost information will be determined on a plant-by-plant basis for each substance selected for a case study. If more than one substance is present at each plant that may potentially be regulated: . Do not allocate separate compliance costs to each of the various substances present. . Assume that the compliance cost required will be the effect of all substances at the plant unit potentially regulated. . Do not complete a separate set of forms for each substance present at a plant unit, since this would result in double counting. OSHA's proposed regulation and these forms cover each of the substances that may be classified by OSKA under Category 1 or Category II. The four categories established by OSKA are: . Category I - Confirmed Carcinogens . Category II - Suspect Carcinogens . Category III - Substance for Which There Is Insufficient Information to Reach a Conclusion on Carcinogenicity . Category IV - Substances of Carcinogenic Potential Not Found in the American Workplace. - 5- AP00048348 .J TO avoid prejudging the results of future oncological testing, the cost analysis is evaluated at two assumed levels; Assumption 1 - Assume that the case study substances will be classified as a Category I substance Assumption II - Assume that the case study substances will be classi fied as a Category II substances. The compliance costs calculations are similar for Category I and Category IT substances except for: . Engineering Controls Category I substances will require employers to provide engineering controls to reduce exposure to the "lowest level feasible" (refer to No. 6, below) Category II substances are assumed for purposes of this study not to require engineering controls expenditures. Segregation of Work Area Category I substances will require employers to segregate work areas of the plant in which Category I substances are present. Category II substances will not require segrega tion of the work area. . Lunchroom Facilities Category I substances will require employers to provide lunchroom facilities that have a controlled temperature, positive pressure and filtered air supply whenever food or beverages are consumed in the workplace. - Category II substances require appropriate facili ties for eating and drinking. Therefore, no capital cost expenditure should have to be applied. 6. The proposed OSHA regulation requires that engineering controls be provided to reduce exposure to the "lowest level feasible." OSHA does not define the "lowest level feasible." Depending on the definition, the cost of engineering controls may vary dramatically. Therefore, the cost of engineering controls should be calculated at three assumed levels. These assumed levels selected for the case studies were chosen to provide a range of possible standards; they do not directly reflect the level that OSHA may establish for a case study sub stance and they do not imply that these levels are technically feasible. The three assumed permissible exposure levels (PEL) for the case study substances differ depending on the form of the substar.ee. . For liquid or gaseous substances, the engineering controls should be estimate^-at"the following three pel levels; - 10 parts per million 1 part per million 10 parts per billion . For solid substances, the engineering controls should be estimated at the following three PEL levels; - 100 micrograms per cubic meter of air (0.1 milligrams) - 10 micrograms per cubic meter of air 1 microgram per cubic meter of air (l)There are certain situations where capital cost expenditures can be called for under the proposed act. For example: If it is currently not feasible to meet an existing permissible exposure level (PEL) and your company uses respirators for compliance, engineering controls will be required to reduce exposure to the lowest level feasible, while still requiring use of respirators. Or, if the substance is not now covered by a PEL, it can be under this regulation. If these situations apply to your company, you may want to address them in your submission. -6- AP00048349 7. Thi.3 form establishes a standardized basis for estimating compliance cost and other economic effects. The coat data are "differential" cost information -- the added cost of compliance over and above the cost of compliance with existing regulations. 8. The cost of compliance should be consistent in terms c 1977 dollars. 9. The compliance costs should assume no change in demand for the primary product. Therefore, compliance costs shall be determined at: . 1976 production output 1976 employment. The compliance costs should assume normal operations and not take into account other factors, such as changes in prices and availability. -7- AP00048350 III. KEY PROVISIONS OF THE PROPOSAL THAT AFFECT DIRECT COSTS (The provisions^ presented apply to substances that are classified sb Category r or II unless specifically noted.) Monitoring - The employer must determine the employee exposure to the toxic substance over an eight-hour period without regard to the use of respirators. . Initial Monitoring shall be performed for each workplace and work operation to accurately determine the airborne concentrations to which employees may be exposed. . If the employee exposure is above the permissible exposure limits (PEL)< these monitoring determinations shall be repeated at least monthly. - Monthly determinations shall continue until at least two consecutive measurements are below the PEL; there after, monitoring shall be performed quarterly. . Monitoring shall be performed at least quarterly in work areas below the PEL. . Additional monitoring shall be performed wherever there has been a production, process, control or personnel change which may result in new or additional exposure, or wherever the employer has reason to suspect a change may result in new or additional exposure. The opportunity of employee observation of monitoring exposure shall be provided to affected employees or their designated representatives. Medical Surveillance A medical surveillance program shall be instituted for each employee who is or will be exposed to the regulated substance. . An initial examination shall be provided for each employee at the time of initial assignment or upon institution of the program. Periodic examinations shall be provided for all exposed employees. The frequency and nature of the examination will be specific to the regulated subBtance * Additional examinations will be provided if signs or symptoms commonly associated with exposure occur. Sanitation Facilities, Emergency Plans, Posting and Labeling (Requirements for Category I Substances Only) * Regulated areas shall be established where concentrations of Category I substances are in excess of the PEL. These areas shall be demarcated and segregated from the rest of the workplace. Area access shall be limited to authorized persons. Pood, beverages or smoking products shall not be present or consumed in the area. . Whenever food or beverages are consumed in the workplace, the employer shall~provide lunchroom facilities that have a temperature controlled, positive pressure, filtered air supply and that are readily accessible to employees. AP00048351 (Requirements for Category I_ and II Substances) Emergency plans shall be developed for each workplace where the regulated substance is present. They shall include; Provisions for respiratory protection of employees engaged in correcting emergency conditions - Means for alerting employees of high concentration levels. . Clean change rooms and showers shall be provided. Exposed employees shall shower at the end of the workshift. . Signs shall be posted to indicate clearly all workplaces where the regulated substances may be present. Where airborne concentrations are above the PEL, signs shall additionally bear "Respirator Required" legend. . Precautionary labels must be affixed to all containers and products containing the regulated substances. Personal Protective Equipment . Respirators shall be used to reduce employee exposure to within the PEL and during emergencies, . Protective clothing and equipment required by the Act shall be cleaned, laundered, maintained or replaced at no cost to the employee. Employee Training . Training programs shall be provided at the time of the initial assignment ana annually thereafter. Exposure monitoring records shall be kept for a minimum of 40 years. They"shall include: - Results and comprehensive description of monitoring per formed to determine representative employee exposure - Description of the sampling and analytical methods used Description of type of respirator protection worn Identification of all other employees whose exposure the measurement is intended to represent. Medical surveillance records shall be kept for a minimum of 40 years. They shall "include": Physician's written opinions - Employee complaints relating to exposure A copy of information that must be provided to the examining physician. This includes: .. Description of duties of affected employee as they relate to exposure .. The employee's anticipated or expected exposure (preplacement and emergency) .. Description of personal protective equipment to be used .. Employee's work history. -9- AP00048352 Engineering Controls Engineering and Work Practice Controls shall be instituted to reduce or maintain employee exposures to or below the PEL, except to the extent the employer establishes that controls are not feasible. In the event the PEL cannot be attained, the employer shall reduce exposures to the lowest level achievable and supplement the controls with use of respiratory protection. A written Compliance Program shall be established and implemented' at or below the PEL solely by means of engineering and work practice controls. It shall includes - Process or operation descriptions Engineering plans to determine controls Report of technology considered Detailed schedule of implementation {to be updated every six months). - 10 - AP00048353 IV. SPECIFIC INSTRUCTIONS TO COMPLETE FORMS IV A. Description of Forms To Be Completed By yOUr Company There are eight basic forms enclosed in this package. The completion of these forms will serve as a basis for estimating the economic impact of the proposed OSHA carcinogen standard. Rather than to prejudge future oncological testing or "safe" employee exposure levels, there are four levels for which direct costs will be estimated by these forms for each case study substance. These levels correspond to the following assumptions: . Case study substance is classified as a Category II substance and the PEL established will not require additional engineering controls. Case study substance is classified as a Category I substance and the pel established is 10 ppm for liquids and gases, or 100 micrograms per cubic meter of air for solids. . Case study substance is classified as a Category I substance and the PEL established is 1 ppm for liquids and gases, or 10 micrograms per cubic meter of air for solids. . Case study substance is classified as a Category I substance and the PEL established is 10 ppb for liquid and gases, or 1 microgram per cubic meter of air for solids. Each of these forms is described below: FORM I- COMPANY IDENTIFICATION Fill out this form once for your company. Its primary purpose is to identify a contact so to provide an opportunity for clarification of data if your company elects to sand the completed forms to Boot, Allen. This sheet, the only one that identifies your company, will be assigned a key number, which will also identify the accompanying pages. It will be kept in a locked file with access limited at all times. FORM II- STATISTICAL DATA Fill out this form for each plant unit of your company that is associated with the selected case study substance. If you elect to return it to Boos Allen, its primary purpose is to provide scale-up data. In the upper right hand side of the form , assign a plant unit number and identify the case study substance. FORM III- NONENGINBERIMG COMPLIANCE COST WORKSHEET Fill out this page for each plant unit identified by Form II. This form is used to estimate the nonengineering compliance cost for that plant unit. When completing this form refer to the Nonengir.eering Control Cost Calculations Guidelines on page 12 of the Instructions. FORM IV- ENGINEERING CONTROL COST WORKSHEET Fill out this form for each plant unit identified by Form II. This form is used to estimate the engineering compliance costs at three assumed PEL levels for that plant unit. When completing this form refer to the Engineering Control Cost Calculation Guidelines on page 14 of the instructions. FORM V- SUMMARY DATA-- DIRECT COSTS AT PLANT UNIT LEVEL Fill out this form for each plant unit identified by Fonn II. This torn summarizes the direct costs for that plant unit for the selected case study substance. FORM VI- SUMMARY DATA-- RELATIVE COST CHANGES Fill out this form once for each case study substance. It should be filled out after the individual case studies by your company have been consolidated. FORM VII- ADDITIONAL ECONOMIC EFFECTS-- PRODUCTS Pill out this form for the plant unit only if the case study substance is produced or formulated at the plant unit. This form i3 used to identify the indirect economic effects of the proposed regulations. When completing this form, refer to the Additional Economic Guidelines on page 16 of the instructions. FORM VIII- ADDITIONAL ECONOMIC EFFECTS-- RAW MATERIALS Fill out this form for the plant unit only if the case 3tudy substance is purchased or used at the plant unit. This form is used to estimate the indirect economic effects for users. When completing this form, refer to the Additional Economic Guide lines on page 16 of the instructions. - 11 - AP00048354 IV. B. Nonengineering Control Cost Calculation Guideline (For Use With Form IIlT ' ~~ For man/ of the provisions of the proposed OSHA regulation, a simplified cost calculation method has been developed to assist your company in completing this questionnaire in a timely manner.* J However, some of the provisions of the regulation such as engineering controls and sanitation facilities, require a knowledge of current facilities and estimates must be made by your company. Listed below are the simplified cost calculations for nonengineering control type coat elements. Each of the cost elements correspond to the direct cost calculation questionnaires presented on Form III The following are symbols denoted in the cost calculations presented below: N- number of exposed employees (as determined in Form ID n" number of employees currently covered by similar programs W = number of work areas at the plant unit 1. Inltiai Monitoring Cost . No capital cost . No annual operating cost . Differential first-year operating cost ${10 N + 450) 2. Exposure Monitoring Coat . No capital cost Annual operating cost = $67 N . Differential first-year operating cost * $45 N 3. Medical Surveillance Cost . No capital cost . Annual operating cost * $155 (N - n) . No differentialfirst-year operating cost 4. Change Rooms and Showers . Capital and annual operating costs to be estimated by your company . No differential first-year operating cost 5. Emergency Alarms . Capital cost to be estimated by your company . Annual operating cost to be estimated by your company . No differential first-year operating cost 6. Respirators . No capital cost . Annual operating cost > S25 N less current operating costs . Differential first-year operating cost - (Number of additional respirators purchased) X {cost per respirator) 7. Personal Protection Equipment . No capital cost . Annual operating cost = S343N les3 current operating cost . Differential first-year operating cost to be estimated by your company includes purchase of uniforms, gloves, aprons, faceshields and goggles where required. TTJ Although a number of these costs might be treated as capital costs, these cost calculation guidelines treat most of these expenditures as expense items. 12 AP00048356 8. Signs . No capital and annual operation costs . Differential first-year operating cost S 80 W 9. Emergency Plan , No capital and annual operating costs . Differential first-year operating cost * $ 400 W 10. Recordkeeping Cost . No capital cost . Annual operating cost * $15 N . Differential first-year operating costs * $200 W 11. Training Program Cost . No capital cost , Annual operating cost * $(160 * 15 N) . Differential first-year operating cost * $200 13. Segregation of Work Areas (Category X assumption only) . Capital costs must be estimated at the plant level for work areas. . Annual operating cost to be estimated by your company. . No differential first-year operating cost. 14. Lunchroom Facilities (Category I assumption only) . Capital costs must be estimated at the plant level for work areas. . Annual operating cost to be estimated by your company. . No differential first-year operating cost. - 13 - AP00048357 IV.C. > \.s Engineering Control Coat Calculation Guidelines (For Use With" Form IVT The key provisions of the proposed act call for engineering controls to play the major role in reducing employee substance exposure. For purposes of this study, we have assumed control costs will only be required for areas where the case study substance is evaluated as a Category I substance. Engineering control costs required for Category I will depend on the PEL leyel that is established for that substance. For purposes of economic analysis, we have designated several assumed levels for which engineering controls should be estimated. These levels were selected arbitrarily to provide several levels at which engineering controls could be evaluated. - For substances that are in liquid or vapor form, engineering controls will be evaluated at the following three assumed PEL levels: .. 10 parts per million .. 1 part per million .. 10 parts per billion For solid substances, engineering controls will be estimated at the following three assumed PEL levels: .. 100 micrograms per cubic meter of air .. 10 micrograms per cubic meter of air .. 1 microgran per cubic meter of air The capital cost calculations for each of the types of control should reflect a total project cost in 1977 dollars. Elements usually included are: Engineering - Design - Materials Equipment - Construction - Contingency (to be applied as 10 percent of all costs above). The costs for typical investment items as presented on the next page reflect total project cost and if applied should not be altered to include additional project cost factors. Xf it is dstsrmined that in order to achieve one of the designated PEL levels, a new facility would be needed for economic or technological reasons, then the engineering control capital cost should be estimated as the cost of an equivalent new facility (same production capacity): The capital coat should be the cost of a new facility less the salvage value (or plus the demolition cost) . The annual operating cost should be the differential cost of the new facility operating cost minus the existing facility operat ing cost (do not include depreciation! The differential first year costs should include start-up costs. Total engineering costs to meet the assumed PEL level must be estimated by your company. However, to assist your analysis, the following is a list of control techniques that are typically used to control exposure levels. Vapor Particulates Process change Ventilation Storage tank vapor control Mechanical seals for pumping equipment Liquid level alarms Rupture discs for relief valves Closed loop sarapLing systems Process change yentilation Enclosures of equipment or process Washing or decontamination systems Conveying systems Leak proofing Clean up equipment The remainder of this section briefly describes the control techniques above and provides some typical costs which you may use as guides', exclusive of factors for piping, instrumentation, excavation, grading, utilities, etc. - L4 - AP00048358 1. Process Change If process change is selected as the method of reducing substance exposure, the capital cost requirement must be determined solely for the individual process or operation. 2. Ventilation Ventilation systems ean be designed to control either the local area or a general area. The cost is also dependent on the specified air flow rate. ' 3. Storage Tank Vapor Control Floating roof tanks, indirect combustion, activated carbon adsorption and vapor containment systems are commonly applied to control storage tank vapors. Floating roof tanks are usually more cost effective than other control tech nologies to control storage tank vapors. 4. Mechanical Seals For Pumping Equipment Pumps that currently have packed seals can be changed to mechanical seals. The control cost per pump is normally $S,000 to $10,000. 5. Closed Loop Sampling System The installation of closed loop sampling systems will reduce employee exposure to liquid vapors during process sampling. The estimated cost for fabrication of such a system is estimated to be $500 per sampling location. 6. Liquid Level Alarms Storage and process vessels should be equipped with high liquid level alarms to reduce the potential of overflow. The estimated cost to equip existing tanks with liquid level alarms is $3,000 per tank. 7. Rupture Disks Rupture disks are used to reduce Leakage associated with poor sealing of relief valves. The estimated cost is $1,000 per relief valve. 8. Enclosures of Equipment or Processes These systems consist of complete enclosure of equipment and processes using impermeable barriers. They are usually accompanied by exhaust ventilation and material collection systems. 9. Washing or Decontamination Systems These systems are used in handling and storage areas to reduce exposure to particulate substances that adhere to exteriors of storage containers. Contami nated washings handling equipment costs should be included in these systems. 10. Clean-Up Equipment Generally consists of vacuum equipment to prevent particulate accumulation. 11. Conveying Systems These systems are required to transport particulate substances instead of manual handling. They are generally enclosed. 12. Leak Proofing This is done in existing doors, enclosures and ventilation systems whenever necessary. Cost to be estimated by your company. - 15 - AP00048359 XV D. Additional Economic Effect Guidelines (For Use With Form VIZ & Form villj The requirements of the OSHA Carcinogen Standard may result in effects on your business in addition to direct quantifiable costs. Some of these are: . Regulated substitution of raw materials. The proposal authorized OSHA to require for Category I substances "no occupational exposure," if it determines that there is a less hazardous suitable substitute. This may, in effect, amount to a ban on a substance for some or all applications. . Voluntary substitution of raw materials for a variety of reasons: To avoid complexity of handling regulated materials. -- To avoid potential liability effects. To avoid higher-cost regulated materials. . changes in sales levels for a variety of reasons: Substitution to avoid handling of products labeled "carcinogens.: - Reduction in purchase because of higher price. Effect of a potential ban on the substance in the workplace. Loss of sales to nonregulated foreign producers. . Loss of jobs because of sales reduction or plant closings. . Changes in productivity because of manpower requirement shifts, change in production capacity or change in demand. . Business closings because of higher operating cost, higher raw material prices or product bans, especially as they might effect small businesses. . Changes in price because of changes in cost or demand. These issues are addressed on Forms VII and vtix. They may not all be significant for a single company but those that do apply should be addressed. They may well be significant from an overall industry point of view. Many of these areas call for subjective judgment and projections of what is likely to happen. It is important to be realistic in those assessments. Any exaggerations in this area would throw doubt on the credibility of the entire effort. Questions in this area are divided into two pages: . Form VII is to be filled out if the plant unit produces the particular case-study substance. Much of the material can be better provided if marketing peopLe are involved in filling out this page. . Form VIII is to be filled out if the plant purchases, uses, or m another way encounters the case-study substance in the plant unit. Either one or the other, in general, should be filled out for each case-study sub stance encountered in the plant unit. Formulators should fill out both. For the survey, any areas that are not applicable should be marked, "not applicable." - 16 - AP00048360 APPENDIX A ECONOMICALLY SIGNIFICANT SUBSTANCES LISTED IN NIOSH SUSPECTED CARCINOGENS, SECOND EDITION APPENDIX B SUGGESTED OUTLINE FOR INDIVIDUAL COMPANY COMMENTS OR TESTIMONY ON THE OSHA GENERIC CARCINOGEN PROPOSAL FOCUSING PRIMARILY ON ECONOMICS AP00048361 APPENDIX A ECONOMICALLY SIQdFICANT SUBSTANCES LISTED IN NICSH SUSPECTED CARCINOGENS, SEXXND EDITION. (c) NUMBER^8* NAME(b^ WG21000 AF85750 AH52500 AI52500 AL31500 EL64750 AS10500 AT52500 XW52500 AS10500 0319250 3*66500 DG19250 KJ57750 MJ47250 BW66500 XS96250 3*66500 SE73500 XYS6000 XY56000 OF98000 KV03500 OF98000 CY14000 BW66500 CZ10500 TI31500 CZ45000 CZ45SOO QA07000 XS52500 DA64750 WL36750 ACETIC ACID, (2-B'JITNYLIDENE)ACETIC ACID, CHLDPOACE1TIC ACID, EIHYIHIEDINITRUXM'JiTRA-, TRISODIUM SALT ACETIC ACID, IAD (2+) SALT ACETONE ACETONE, METOYLACHXEIN ACHYIINITRIIB ALUP3X AILYL ALDEHYDE AMIBEN AMINCBENZENE 3-AMINO-2,5-DICHIOROBENZOIC ACID 2-AMDJCETHANOL AMMOFORM AMJNCPHEN 3-AraND-p-TCLUIDINE ANILINE ASPHALT (STEAM REFINED) ATRANEX ATRAZINE AUSTRIAN CHHA3AR BAKELITE BASIC LEAD CHRCMATE BENZENE BENZINE, AMINOBENZENE, 1-OILC1PO-4-NITRO 1,2-BENZENEDICARBQXYLIC ACID ANHYDRIDE BENZENE, 0-DICHD3H> BENZENE, p-DICHLOiO BENZENE, ETHYLBENZENE, METHYLBENZENE, NTHBENZENE, VINYL- NIQSH NUMBER^*' NW(b) DG19250 XSS9250 DS14000 C617500 CS28000 DS40250 1^89250 0376750 DU80500 DU80500 VW84000 ED45500 PA49000 KJB5750 EL64750 KJ85750 0078750 KJ85750 KJ85750 KJ85750 EU98000 EV01750 EV19250 EV27000 EV31500 XR22750 XW52500 SY26250 FC595D0 AT52500 CIP07000 ZH33250 1059500 BENZOIC ACID/ 3-AMINO-2 , 5-DICHDDPI> BENZYL CHLORIDE J BERYL BERYLLIUM BERYLLIUM FLUORIDE EERYLLILM QXICE BEV BHT BIBENZENE BIPHENYL S-l, 2-BIS (EHHOXYCAFSCNYL) EHKYL-0,0DIMETHYL TtHQPHCSPHATE BORIC ACID BRCMOMEIHANE BOOS 2-BUTANCNE 2-BUTOXYETHAN3L BUTYLATED HYDECXYTULLJSNE BUTYL CEXIOSQLVE O-BUTYL ETHYLENE GLYCOL BUTYL GLYCOL CADMIUM CADMIUM CHLORIDE caemum oxide CADMIUM SULFATE (1:1) CATMTUM SULFIDE CALCOTCNE WHITE T CAMPHECHLDR epsilm-CAPROLACTAM POLYMER CAPROLDJ CARBACEYL CARBAMIC ACID, ETHYLENEBIS (DITHIO) -, MANGANESE SALT CARBAMIC ACID, ETHYLENEBIS (DITHIO)-, ZINC SALT CAFBAMIC ACID, METHYL-, NAPHTHYL ESTER Al AP00048362 AaPpPpQqTtOoIi p imjrwrrAT.T.v significant substances listed in NICSH SUSPECTED CAir-TOmsKS. SECOND B5ITIOJ.(c' NI06H NUMBER a NRME(b) NICSH mtimrpb (a) NAME,b} YR62500 CARBAMIDE FC59500 CARBARYL WM84000 CARBSTHOXY MALA1HICN WMB4000 CAIEEIOX SJ33250 FFS6500 CARBOLIC ACID CAJSCN BISULFIDE KX38500 FF66500 CARBCN DICHLORIDE CARBCN DISULFIDE FFS650Q FG49000 CARBCN SUIFIDE CARBCN TETRACHLORIDE YR62SOO QR59500 CARBCNYIDIAMDffi CARBONYL NICKEL POWDER WM84000 CAHBQPHOS FJ59500 ' C2^B0XYMETOYLCEri;.ITCSE, SCOIUM SALT TQ35000 CARBOWAX PCS9500 FJ59500 CAREOLIN CELLULOSE, CAKBCKYMETHYL ETHER, SODIUM SALT WM34000 CG19250 CHEMATHICN CHLQBAtBEN XW5250C CHLCWNAT2D CW^HENE AF8S750 CZ45000 AF85750 xys6oqo CHLOPOACET3C ACID CKLOSOBEN CKLORCSETTHANOIC ACID 2-CHLOR>4 -EOHYIAMINOISCIPKiraAMINE-S-TRIAZ INE KU96250 KV03500 CHLOHDErFfYUNE CHIORCETHYLElffi POLYMER FS91000 aJLORDPCUM KJ29750 PA63000 CZ10500 CHLDBDFOPM, MEIHYLCHLOROE1HANE 1<HL0R>4-NITKBEN2ENE SM63000 XS89250 GB29550 CKLOROPHHH alpha-CHTOPCTOIjUENE CHROMATE OF SODA OF98000 GB2750Q GB28500 CHRCME ORANCE CHROMIC ACID, CALCIUM SALT CbQCMlC ACID, CHECMIUM (3+) SALT GB29550 042000 QR59500 W66500 WL36750 ML36750 WL36750 BW66500 XS96250 CF98000 XR227S0 IA64750 M4S2500 CZ45000 CY14000 VZ47250 >3452500 VW84000 FC59500 0078750 AT52500 CY14000 WM34000 TQ79000 TX87500 CZ45000 >596250 XS96250 TX87500 KH92750 0078750 DG19250 C245000 CZ45SOO PA82000 KI05250 CHfCMIC ACID, DISCDIUM SALT CHRCMIU4 C.I. 7775 C.I. 76000 CIMW1ENE CH*JAMENOL CDWAMOL C.I. OXIDATION BASE I C.I. OXIDATION BASE 200 C.I. PIG-ENT RH5 C.I. PIO-ENT WHITE 6 C.I. SOLVENT BLACK 5 CLOR CHEM T-590 CLORCBEN COAL NAPHTHA CCM-EN SALT CCMPCCND 3956 COMPOUND 4049 CRAG SEVIN P-C3ESX. 2-6-DI-tert-BUTYLCYANCETOYLH4E CYOOHEXATRIENE CYTHICN DACRCN EBCP DCB 1,3-DIAMINO-4-MEIHYLBENZENE 2,4-D1AMXNCTCUJENE 1,2-DIBRCM>3<HIJDROPPClPANE 1,2-DIBRCMOEIHANE 2,6-DI-tert-BUTYL-p-CRESOL 2,5--DICHUOSO-3-AfCNCBENZOIC ACID O-DICHICJRCBENZQiE p-DICHLDRCBENZa DICHICPCOIFLtXJPCMETHANE 1,2-DICHIORCETHANE A2 AP00048363 V/ APRIL A A ECCNCMICALUT SICNIFICANr SUBSTANCES LISTED IN NIOSH SUSPECTED CARCINOGENS, SECOND EDITION. NIOSH NVHBER(a) NAME(b> NICSH NUMBERfa> NAME(b) KI05250 PA90500 WH34000 KX24500 AL3I500 TG0I750 TG01750 TG01750 WZ12250 WZ12250 XT15750 XT19250 DU8G500 CP07000 FF66500 WZ12250 XT15750 KJ85750 KH92750 PA49000 PA49000 SN15750 SM63000 CZ45000 KX45500 TG01750 DA07000 KH92750 KI05250 FJ59500 AH52500 KI05250 KX39500 KS49000 M452500 DICHLORDEIHYIiNE DICHLDKMETHANE DIETHYL HEK2APTDSLCCXNATE, 0,0-DIMETHYL PHCePHORODimiCATE DIMEHHYIfNE OXIDE DEMEIHYL KETCNE DIMEIHYL p-NITICPHENYL tCKOTKIOPHCSPHAIE 0,0-DIMBTHYL 0- [p-NTTROPHENYL) PHOSPHOBOIHICATE DIMETHYL PARATHION DI2EIHYL p-PHTHAIATE DIMETHYL TEKEPHIHA1ATE 2,4-DINTTSQTQLUENE 2,6-DXNITJCTOLUENE DIPHENYL DITHANE K22 DITHIOCARBCNIC ANHYDRICE DMT 2,4-ENT DCWANOL EB DCWFUME 40 DCWFUME MC-2 DOMFUME MI-33 DCWICIDE 2S DOWICIDE G DONTHERM E CCW-TRI E 601 EB SDB SDC SDIFAS B EDTA TRISODIEM SALT ENT 1,656 ENT 1,860 ENT 4,705 ENT 9,735 KH92750 WM84000 TG01750 FC59500 TX49000 TX49000 KX24500 TX29750 TT31500 XW52500 KH92750 KI05250 KI05250 KJ29750 KQ63000 KJ57750 KJ57750 KJ85750 KX45500 KQ63000 DA07000 UH82250 AS10500 ap07000 ZH33250 KH92750 IC05250 KU96250 XVO350O AH52500 KH92750 KI05250 KJ85750 KU96250 KX24500 ENT 15,349 ENT 17,034 ENT 17,292 ENT 23,969 EPICH1XRHYDRIN EPICHLORCHYDRIN 1,2-EPOXYETHANE 1,2-EPOXYPROPANE ESEN ESTCNOX ETHANE, 1,2-DIBH0M>E7IHANB DICHD0RICE E7IHANE, l,2-DICHLOB> ETHANE, 1,1,1-TRICHLOPOETHANOL ETHANOIAMINE ETHANOL, 2-AMEM> ETHANOL, 2-BUIOXYETHINYL TRICHLORIDE ETHYL ALCCHOL ETIHYIi EZNZENE ETHYL CARBTNOL ETHYLENE ALDEHYDE edhylenebis (dithiccapbamate) manganese 2THYLENEBIS(DI1HICCARBAMATE) ZINC ETHYLENE BRCMHE gTHYTJWR CHLORIDE ETHYLENE, CHIDEETHYIfNE, CHIDHO-, POLYMER BIHYIiNE3)IAMINbTL,i'HAACT7riC ACID, TRISODIUM SALT ETHYLENE DIBROMIDE EIHYIiNE DICHLORIDE ETHYLENE GLYOOL, UNCBOTYL ETHER ETHYINE M2JCCHLORICE ethylene: oxide A3 AP00048364 APPEND1. EtXMCMICM.T.Y STftHTIcasr SUBSTANCES LISTED IN NIOSH SUSPECTED CARCINOCSNS, SEXXND EDITION. (ci NICSK NUMBER1** NAMEfb) NIOSH NUMBER13' NAME[b> TZ29750 WL36750 KX38500 KX33500 KX45500 XX45500 EL64750 ZH33250 N085000 N085000 PA820G0 WM84000 LP89250 LP89250 M447250 LP89250 LP89250 PA82000 PA820Q0 TX87500 CN36750 XY56000 PA82000 KJ85750 KH32750 KI05250 KJ35750 KQS3000 N085000 PA32QD0 FG49000 PA49000 PA94500 W321300 MM 7250 M44725D ethylene oxide, meihylETHYLENE, PHENYLEnHYl^T^AOiLORIDE ETHYLENE, TSTRACHLOROETHYLENE TRICHLORIDE ETHYLENE, TRICHLOROETHYL METHYL KETTCNE ETHYL ZIMATE FEOSOL FERROUS SULFATE FUX>PCCAraCN-12 FOR4AL FORMATJ'CTVHE FORMALIN FOWftMINE FORMIC ACID FOBMOL FRECN-12 FREON F-L2 FUMA2CNE 2,4-FURANDiCNE CEIGY 30,027 GEN5TRCN 12 GLYOOL BUTYL ETHER GLYCOL DIBFCMIDE GLYOOL DZCHT/TRIDE GLYCOL MZfcBUTYL ETHER GRAfN ALCdBQL GREEN VITRIOL HAICN I1ALCN 104 HALCN 1001 HALCN 10001 2,4-HEXADIENOIC ACID HEXAFORM HEXAMETHYLENEAKINE MM7250 MJ47250 M470500 SJ33250 KJ57750 NP962S0 PA94500 N085000 NP9625Q NP96250 NP96250 AL31500 EL64750 AI52500 QF98000 QF98000 OF98000 TP45500 VW840QQ VJM84000 VW34000 CN3S750 CN36750 OP07000 P07000 CP07000 AF85750 KJ57750 PA49000 EL64750 WM34000 TG01750 TGO1750 XS52500 OZ50750 LP89250 HEXAMETHYLENETETRAMINE HEXAMINE HYDROCYANIC ACID, SALTS HYDROXYBENZENE 2-HYDR3XYEIHYIAMINE 1-HYCfOXYMETHYLPROPANE IOCOMEMANE UCN (ID SULFAIE (lil) ISCffitTEANOL ISOBOTYL ALCOHOL ISOPROPYLCARBINOL KETONE, DIMETHYL KETONE, ETHYL METHYL IBRD ACETATE LEAD CHR3KATE, BASIC LEAD CHROME (VI) OXTEG HAD CHRCMWE. RED LEAD, 'iKIHAESHL MALACICE MAIATHICN MALAICX MALEIC ACID ANHYDRIDE MALEIC ANHYDRIDE MANES MANGANESE, (ETHYLENE3LS (DITHIOCASBAMAIO)) MANZATE MCA MEA MEBR MEK MERCAPTOTHICN MTOCIEE METOPHDS METHACIDE METHACPYLIC ACID, METHYL ESTER METWWAL A4 AP00048365 ECCNCMICAII.Y SICMIFIQWT SUBSTANCES LISTED IN NIOSH SUSPECTED CARCINOGENS, SECOND EDITlCM.(c) NICSH NUMBER'*' NAMElti) NIOSH NUMBER'^ NAME^ PA49000 PA63000 PA80500 PA80500 PA82000 PA9450D XS52500 FG49000 FG49000 FS91000 FS91000 JW47250 PA49000 EL647S0 IP99250 XS52SOO PA49000 G078750 KQS3000 PA63000 KI29750 XI15750 PA80500 PASO500 PAB0500 LP99250 EL64750 PA94500 AL31500 OZ50750 FC59500 PC59500 TZ29750 TG01750 XS96250 NP96250 METHANE, BRCMDMETHANE, CKORDMETHANE DICHLORIDE METHANE, DICHLQRDMETHANE, DIOHDRDDimJDPDMETHANE, IODOMETHANE, PHENYL METHANE TETRACHLORIDE METHANE, TETFACHDDROMETHANE TRICHLORIDE METHANE, TRICHI/3ROMETHENAMINE METHCGAS METHYL ACETONE METHYL AIXEHYDE MEIHYLBINZENE MEIHYL BROMIDE 4-MEWYL-2,6-tBrt-BOTYLPHENOL METHYICAreiNOL .`ETHYL CHLORIDE METHYICHLOROFOm 1-METHYL-2,4-DINITFCBENZIHE MEIHYIQJE BICHLORIDE METHYLENE CHLORIDE MEIHYIHJE DICHLORHE hETHYLSNE CBtTTtt ME7IHYL ETHYL KETCNE METHYL TmtriR METHYL KETCNE MEIHYL MEIKACKYIATE N-MEnHYL-l-NAPOTHYL CARBAMATE N-MEniYL-alpha-NAPHIHYLURETIHM! METHYL OX3RANE MEIHYL PARAIHION 4-MEIHYL-nb-FHENYLEDIAMINE 2-METHYL-l-PROPANlX NP96250 FS91000 CY14000 VW84000 OZ50750 KJ85750 AF85750 KU&6250 PAS3000 0250750 KJ57750 0705250 XW52500 TG01750 TQ79000 0705250 QK92750 FC59500 KX38500 TX87500 QR59500 DA64750 CZ10500 TC01750 TG01750 KV03500 XW52500 CZ45000 CZ45000 KV035D0 ED455D0 CZ45000 KX24S00 KX24500 CZ45500 CZ45500 2-ME7IHYLPRQPYL AICCHOL METHYL TRICHLORIDE MINERAL NAPHTHA MLT frE MXOBUTYL GLYCOL ETHER MaCCHLOPOACETIC ACID WOCHDDRCIETHYiaffi M3NOCHE0RCMEIHANE MCNOCITE METHACHYIATE M2NCHER MBX2ETHAN0LAMINE MOTH BALLS MDIOX M-PARMHICN MYLAR NAPHTHALENE NAPHTHENIC ACID, ZINC SALT 1-NAPHTHYL N-MEIHYICAfBAMttE NEKA NEMAflCN NICKEL NITRCBENZENE p-NITRCCHIOBCBHfZENE p-NICTtOPHENYIIJIMEIHYLTHICNOPHCSPHATT! NITRDX 80 NORVHJYL OCTACHLORCCAMPHENE CCS OCCB OPAICN OBmceoRic acid ORIHODICHLDRCBENZENE OXICCETHANE OXERANE PARACIDE PARADICHLORCBENZaE A5 AP00048366 APPENDl. BCCWCMTCALIY SIOUFICftMT SUBSTANCES LISTED IN NlOSH SUSPECTED CABCHCGEbS, spttnd EPtTICK.(c> NUMBER*^ NAME`b) NinSH NUMBER*a5 NAHS*b} CZ45SDO CZ4S500 IG01750 ZH33250 SMS3000 CZ45500 CZ45500 TQ350DO XS96250 SM63000 W321000 KX38500 FG49000 KX4550D AH52500 SE73S00 SN15750 SJ33250 SM53QOQ SN1575D BW66500 DU8Q5QQ CA07000 WL36750 SJ332S0 5X52500 TG01750 WM84000 DU80500 TI31500 TI31500 1131500 TP4S500 CZ1D500 XW52500 PAHADCW PARAM3IH PABATHI JKMYL PARZATE 2INE3 PCP PDB PDCB P.E.G. 400 PEIAGOL GRES J PE2WACHLOROPHENX 1,3-FJIADJ32NE-1--CAraCCOELIC ACID PEROILORCEIHYINE PERCHMRCMECHANE PERM-A-CLDR PEPMA KTgER 50, TRISCOTUM SALT PETROLEUM ASPHALT (STEAM REFINED ASPHALT) PHENACHLOR PHENOL PHENOL, PENIACHLQROPHENOL, 2,4,5-TPICHIORO PHQttlAMINE PHFNYTRFNy.FNP. PHQJYIEIHANE PHENYLETWIB4E PHENYL HYDROXIDE PHENYIMETHANE PHOSPHOR3TOIOC ACID 0,0-DIMEHfYL 0- (p-NCTFCPHEJBL) ES7TER PHOSPHOWICN' PHPH 1,3-PHTHAIANDICNE PHTHALIC ACID ANHYDRIDE 2H5HALIC ANHYDSCLEE PLLM9ANE, TETRAETHYLPNCB POIS3CDRCCAMPEENE TQ35000 TQ79000 WL64750 WL64750 TR81000 KV0350Q TX49000 TX87500 T229750 UH82250 AL31500 T229750 WG21000 UH82250 TZ279S0 TR81000 W73300 QR59500 PA32000 TI31500 PA49000 VZ47250 W73300 AH52500 FC59500 W73300 W73300 W73300 W73300 WE19000 FJ595DO VZ47250 GB29550 'JE19000 WE19300 WE19000 POLYETHYLENE GLYCOL POLYETHYLENE TEREPHTOAIATE POLYSTYRENE POLYSTYH3L POLYVINYL ALCOHOL POLYVINYL CHLORIDE PROPANE, l-CHLOPO-2, 3-EPOXYPROPANE, 1,2-DIBRCM> 3-CHLORDPRCPANE, 1,2-EPOXYn-PRQPAMX 2-PTOPWJ3ffi PROPQJE OXIDE 2-PR3PENYLACRYLIC ACID PROPYL AICOHGL 1,2-PSCFYXJNE OXIDE PVA QUARTZ RANEY NICKEL SEFRIGERPMT 12 RETARCGR ESIN ROIOX SALT SAND SEQUE9TRENE TRISODIUM SALT SEVIN SILICA, CRYSTALLINE - QUARTZ SILICA FLOUR (PCWDEFEB CFttSIMUNE SILICA) SILICIC ANHYDRIDE SILIOCN DIOXICE ( SAND) SODIUM BISULFIDE SODIUM CAE30XYMGIHYL CELLULOSE SODIUM CHLORIDE SODIUM CHROMATE SODIUM HYDR06ULF2DE SODIUM MEPCAPTfN SODIUM SULEHYDRATE Afi AP00048367 0 APt. :X A ECONOMICALLY SiaJOTCANT SUBSTANCES LISTED IN NIOSH SU3PECTED CARCINOGENS, SECOND SDITICU. ~cl NICSH NUMBER NAME*b> NIOSH ,, NUMBER(a) NAME03' WE19000 WG21000 WG21000 WL36750 WL64750 WL36750 WM84000 SODIUM SULFIDE SORBIC ACID SORBISTAT STYRENE STYRENE POLYMER STYRCN SUXENIC ACID, MBRCAPTO-, DIETHYL ESTER, S-ESTER WITH 0,0-DIMETHYX. PBDSPHOHDDITHIQAIE XYS6000 KX45500 KJ297S0 XX45500 FS91000 FS91000 SN15750 3-TRIAZDJE, 2--(HLORD-4--EnHYLAMINCVfiISOPHUPYLAMTNO- TRICHLORAN 1,1,1-TRICHLORClETHANE TRICHXRCBTHYIENS trichlorcporm TRICHLDRCMEIHANE 2,4,6-TRICHLOROPHENX N085000 SULFURIC ACID, IRCN(2+) SALT {1:1} KX45500 TRI-CLENE ZH52600 SULFURIC ACID, ZINC SALT (1:1) AH52500 TRISODIUM SDETOIE WWS5050 TANTALUM AH52500 TRISCDIUM VERSENATE 0705250 TAR CAMPHOR YR62500 UREA WZ12250 TEREPHIHALTC ACID, DIMETHYL ESTER QP07000 VANCIE6 WZ12250 TEREPHTHALIC ACID, METHYL ESTER KU96250 VC KX38500 lETRACHLOfCCTTHYIiNE KU96250 V24 FG49000 TETRAmLOFCMETHfNE AHS2500 VERSENE 9 7P45500 TETRAETHYL IAD KV03500 VXNOFIEX XR22750 XR22750 XR22750 TITANIUM DIOXIDE TITANIUM OXIDE TITANDX WL36750 KU96250 KU96250 VTNYISH4ZENE VINYL CHLORIDE VINYL CHLORIDE MONOMER XS52500 XS89250 TCOJQ TOLUINE, alpha-CHLORO- KV03500 AT52500 VINYL CHLORIDE POLYMER VINYL CYANIDE XS96250 XT15750 TOLUENE-2,4-DIAMINE TOLUENE, 2,4-DlNITRO- XV03500 QJ05250 VDJYLTTE WHITE TAR XT19250 TOLUENE, 2,6-DINITRO- ZH52600 WHITE VITRIOL XS52500 TOLUOL ZH33250 ZINC, (ETHYLQffiBIS (DITHIOCARBAMATO)) XW52500 TOXADUST QK92750 ZINC NAPKTHENATE XW52500 TOXAPHENE ZH52600 ZINC SUIFAIE CN36750 IOXILIC ANHYDRITE ZH52600 ZINC VITRIOL KX4S500 TRI ZI533250 ZT^JhlH KX45500 TRIAD PA49000 ZYTOX KX45500 TRIASCL (a) -Q-ja NIOSH NUMBER is an alpha/numsric designation which is unique to the substance. this unique nutter. (o) This colurm includes chemical, trade, and crrrrron names. Each synonym is keyed to Ecoraric&lly significant, substances are defined as those with pcoducticn of 25 million pounds per year and/or significant workplace exposure. There are 99 unique substances in this list. Source; Booz-Allen & Hamilton Eras. A7 AP00048368 APPENDIX B SUGGESTED OUTLINE FOR INDIVIDUAL COMPANY COMMENTS OR TESTIMONY ON THE OSHA GENERIC CARCINOGEN PROPOSAL FOCUSING PRIMARILY ON ECONOMICS Chapter I - Company Background Description of the company, including! . Size . Products made . Number of employees . Export-import balance . Activities in protecting worker health. Chapter II - Methodology For Estimating Economic Impact The guideline is the recommended methodology that should be referenced here. Chapter III - Direct Cost Impacts o the regulation, under two scenarios! . Scenario A - Assume all your products which are on the NIOSH List of Suspected Carcinogens are in Category I. . Scenario B - Assume all your products which are on the NIOSH List of Suspected Carcinogens are in Category II. Scenario A direct costs should be estimated at three potential control levels: . a PEL Level of 100 ppm for liquids and gases or 100 micrograms for solids . a PEL level of 1 ppm for liquids and gases Tsr 10 micrograms for solids . a PEL level of 10 ppb for liquids and gases or 1 microgram for solids. Chapter IV - Indirect Implications To The Company This section should cover those significant elements of economic impact on your company that are not direct compliance-cost items. Possibilities include effects on: . Use of substitute materials and processes . Price . Productivity . Competitive position regarding foreign producers . Possible plant closing . Employment . Small versus large companies. Chapter V - Indirect Cost implications To Customer Industries Using examples where possible, this section should cover effects on user industry. . Use of substitute materials and processes . Costs and prices . Productivity . Competitive position regarding foreign producers . Plant and business closings Employment . Small- versus large-volume users. * * * You, may also want to cover non-economic issues in your submission such as technical problems, questions of toxicological definition, and recommendations for changes to the rule as proposed. - B1 - AP00048369 APPENDIX C FORMS FOR CALCULATION AND REPORTING AP00048370 CONFIDENTIAL FORM I COMPANY IDENTIFICATION {Complete Only IE Your Company Elects To Participate In The Industry Economic Survey) Case Study Substances: Company Name: Address: Key Contact: Title: Telephone: Alternate Contact: Title: ___ Telephone: _____ RETURN ENTIRE QUESTIONNAIRE TO: Boo*, Allen & Hamilton Inc., Foster D. Snell Division. 66 Hanover Road, Florham Park, New Jersey 07932, Attention: R. Kensicfci This sheet should be used only if your company elects to participate in the industry economic survey being performed by Booz, Allen. It will be used only if follow-up contact is required for clarification. It will be kept in a locked file, separate from the rest of the questionnaire until analysis is complete. Then it will be reattached to the rest of the questionnaire and returned. For clarification and assistance in filling out these forms, contact Ronald Kensicki, Ronald Rubin or Philip Gisser, Foster D. Snell, Inc., at (201) 377-6700, Extension 260j New York City Tie-Line - (212) 924-8800. AP0004837I CONFIDENTIAL 0 Plant Unit (Assign Number) _____________ FORM II Case Study Substance___________ STATISTICAL DATA --Each Plant Unit-- For each plant associated with the selected case study substance, complete this sheet. Case study substance: Major products manufactured this plant unit if the case stance is not a product: by study sub ________________________________________ Output (1976) /units of output: _____________________________________ Approximate 1976 value of ship ments from this unit (sales plus internal transfer): 5______________________________________ Number of total employees (1976-allocate, if necessary)j Number of production employees (1976fs __________________________________________________________________________ List the substances potentially controlled by this regulation that are present at the plant unit and the total number of employees exposed to these substances in this unit. List the case study substance first. Substances^ >3 NIOSH Registry Number2 Full Time* Number of Employees Exposed Parfc ?jma5 Total TI Includeall employees assigned to the specific plant unit, e.g.: . Production workers . Maintenance employees generally assigned to the area . First-line and other supervision assigned directly to that plant unit. 2. Substances and their respective NIOSH number are listed in Appendix A. Other substances for which standards may be established under this regulation are listed in the NIOSH publication, Suspected Carcinogens, 1976. 3. If an impurity, indicate its concentration. 4- Full Time - More than four hours per day, 90% of working days. S. Part Tine - More than 30 minutes per week, but less than full time. AP00048372 CONFIDENTIAL FORM III NON-ENGINEERING COMPLIANCE COST WORKSHEET -- Each Plant~Un.it -- Plant Unit Number_____ Case Study Substance Cost Element (Elements required for Category I or II assumption) 1. Initial monitoring cost 2. Exposure monitoring cost 3. Increased medical sur veillance cost 4. Added change rooms and showers 5. Emergency alarms 6. Respirators above current use levels 7. Personal protection equip ment above current use levels B. Signs 9. Emergency plan 10. Recordkeeping 11. Training above current levels 12. Total, Category I or II assumption Capital Cost (1^7*? Dollars) Annual Operating Cost (1977 Dollars) Differential First Year Operating Cost (1977 Dollars) (Elements required for Category I assumption only) 13. Segregation of work areas 14. Lunchroom facilities 15. Total, Category I assumption (add lines 12, 13, and 14) AP00048373 AP00048 Ul CONFIDENTIAL Plant Unit Number_____ Case Study Substance FORM IV ENGINEERING CONTROL COST WORKSHEBT -- Each Plant Unit -- Assumed PEL Level 1. 10 ppm (liquids or vapors) or 100 iricrogranis (solids) per cubic meter Capital Coat (1977 Dollars $ Annual Operatinq Cost <1977 Dollars) S Differential First Year Operatinq Costs (1977 Dollars) $ briefly describe: Net Effect on Energy Requirements_______ (Equivalent barrels of oil)d) 2. 1 ppm (liquids or vapors) or 10 micrograms (solids) per cubic meter briefly describe: $ $ $ 3. 10 ppb (liquid pr vapors) or 1 microgram (solids) per cubic meter briefly describe: $______________________ $ $_ (1> Assume one barrel of oil is equivalent to 6 million BTU's or 567 kilowatt-hours. CONFIDENTIAL Plant Unit Number_____ Case Study Substance FORM V SUMMARY DATA - DIRECT COSTS AT PLANT UNIT LEVEL -- Each Plant Unit -- Category I 10 ppm (liquid or vapor) Category II or 100 raicrograms (solid) Assumption Assumption Assumption Assumption Differ- Differ- Annual ential Annual ential Oper- First Year Oper- First Year Capital ating Operating Capital ating Operating Costs Costs Costs Costs Costs Costs Category I 1 ppra (liquid or vapor) or 10 micrograms (solid) Capital Costs Annual Operat ing Costs Differential First Year Operating Costs Category I 10 ppb (liquid or vapor) or 1 microgram (solid) Capital Costs Annual Oper-- ating Costs Differential First Year Operating Costs * Non engineering costs (Form ill, lines 12or isT * Engineering costs (Form IV, lines 1,2 or 3) * subtotals Other annualized costs - Benefits, cosL reduc tions and product re covery - Management time, com pliance costs - Capital related costs (1) (25 percent of total capital costs) Total, direct costs plant unit AP00048375 U> Capital related costs include: Depreciation at 10 percent. Interest at 8 percent and Insurance at 2 percent of capital cost. Maintenance at 5 percent Taxes Ijfc )* /4fc - 00 04 *>4 i CONFIDSWTIAL Plant Unit Number ___ Case Study Substance row vi Subatrmco: SUMMARY DATA - RELATIVE COST CHANGES (Fill out this for for each case sttkdy substance by adding plant unit data.) Category 11 Assumption Differ- Annual entiai Oper- First Year Capital afcing Operating Costs Costs Costs (A) (3) (C) Category I 10 ppm (liquid or vapor) or 100 micrograms (solid) Assumption Differ- Annual entiai Oper- First Year Capital ating Costs Costs Operating Costs (A) (U) (C) Category 1 ppm (liquid or vapor) or 10 micrograms (solid) AaiBiirnDtion Differ- Annual entiai Opercapital ating Costs Costs Pirst Year Operating Costs (A) (3) (C) Category 1 10 ppb (liquid or vapor) or 1 microgram (solid) Assumption Differ- Annual entiai Oper- First Year Capital ating Costs Costs Operating Costs fA> O) <C) (1-) Estimated Total Direct Costs(1) (2.) Reference Value (3.) Direct Costs as a percent of the Reference Value. (1. ) i (2.) x 100 Substancei {1.] Estimated Total Direct Costs (2.) Reference value (3.) Direct Costs as a percent of the Reference Value, (1.) g (2.) x 100 _________ _________________________________________ _________ ______________ ____________________________________ _________ (1) Consolidate Form V data from various plant units reporting case study substance. (2) Reference values are defined as follows for each cost category: (write the figure on line (2.) below each applicable letter.) (A) Replacement value of production unit in its present form (assuming identical plant). (B) Total current fixed and variable manufacturing costs including depreciation and management cost, but excluding distribution, and selling, general and administration expenses. (C) Historic 5 year average pre-tax profit on applicable substance or unit. APOO CONFIDENTIAL [FILL OUT THIS PAGE IF YOU PRODUCE OR FORMULATE A PRODUCT WITH CASE-STUDY SUBSTANCE - USE FORM VIII IF THE SUBSTANCE IS A RAW MATERIAL) Plant Unit Number_____ Case Study Substance FORM VII ADDITIONAL ECONOMIC EFFECTS -- PRODUCTS OR FORMULATIONS ~ - Each Plant Unit - 1. Assuming your direct domestic competitors are faced with comparable increased costs that might result from this regulation, what action would you be likely to take? a. Raise prices to recover direct production cost increases Yes b. Raise prices above increased costs. Yes____________ No_____________ What % No What effect would this action have on sales, increase (decrease), percent 2. do technically feasible substitutes for this substance exist in its major applications. (Include both direct substitution and alternate production methods.]? If yes, what application (Use separate pages for separate applications.) ________________ a. What material is the most likely substitute? b. What share of your product sales is subject to substitution, % c. How quickly could this occur (discuss)? d. What effect will such substitutes have on the users of this substance? . Raw material cost increase (decrease) S/unit . Other production cost increase (decrease) $/unit . What is the unit of output above? RsD costs to substitute, $/company . Capital investment required S/unit output . Other costs (explain)_________________________________________________________________________________ e. At what level of price increase will significant substitution (10% of sales) occur (percent)? f. What actions do you feel users of this substance would take if the substance were to be designated a "suspect carcinogen" {category II)? g. What actions do you-feel "users'~ot this substance would take if this substance were to be designated "confirmed carcinogen" (category I) and an Emergency Temporary Standard were issued requiring immediate action, plus later engineering controls to reduce concentrations to the lowest level feasible? ____________________________________ h. Would the added costs be likely to influence users to go out of business? To what extent? i. What particular effects would you expect on customers^ who are small businesses? Less than $30 million in gross annual sales?__________________________________________________________________________________ Less than $5 million in gross annual sales?________________________________________________ Are there other costs that you are likely to incur as a result of shifting demand patterns, such as technical service costs? Explain?. 3. To what degree do you see a potential threat in this and downstream products from overseas manufacturers, assuming all domestic manufacturers must comply, but no similar regulations will control overseas manufacturers in their plants? a AP00048377 USE ADDED PAGES FOR FURTHER COMMENTS CONFIDENTIAL (FILL OUT THIS PAGE ONLY IF YOU PURCHASE OR USE THE CASE STUDY SUBSTANCE IN THIS PLANT UNIT USE FORM VII IF YOU MANUFACTURE IT) Plant Unit Number____ Case Study Substance FORM VIII ADDITIONAL ECONOMIC EFFECTS - RAW MATERIALS - Each Plant Ur.it - 1. Do technically feasible substitute raw materials (or alternate Yes____________ No approaches) exist for this substance? 2. Describe______________________________________________________________| t 3. If you switched to this alternative, what would be the effect a. Total raw material cost increase (decrease) 5/year b. Other production cost increase (decrease) (excLude depreciation), $/year c. R&D costs to substitute, $ d. Capital Investment required 5 e. other costs, explain. Capital Annual ________________________________________________________ Differential First Year _______________________________ _______________________________ ______________________________ ______________________________ 4. What percent chance exists that increased costs of compliance with Category I regulation would result in your closing the unit rather than complying? \ a. If this occured, what would be the effect on overall employment? Number effected Percent of employees in this unit ________________________________________ 5. How would a 10% price increase affect your use of this substance, assuming no parallel increase in competitive substances? 6. What action would you probably take if this substance were to be designated as a "suspect carcinogen" (Category II) and standards were issued requiring the actions described herein? ________ 7. what action would you probably take if this substance were to be designated as a "confirmed carcinogen" (category I)P and an Emergency Temporary Standard were Issued requiring immediate compliance plus later engineering controls to reduce concentrations to the lowest level feasible?____________________________ ____________________________________________________ 8. What actions would you take if use of this substance in this application were to be prohibited?___________________________________________________________________________________________________________________ 9. What do you feel will be the effect of the proposed regulations on productivity in your plant under the three assumptions below: a. Increase in production workers, % of production workers in this unit b. Increase in non-production employees, % of r.cm-production employees in this unit c. Decrease in production, % of production d. change in productivity, (production per employee), % change Assume Category II Assume Category I Difficult to meet Extremely Difficult to Requirement Meet Requirement __________________ __________________ __________________ ___________________________ ____________________ ____________________ __________________ ___________________ AP00048378