Document nk4rObG9G7066GvKvVq1No9K2

FILE MEMORANDUM C.A_ NIOSH-RECOMMENDED OCCUPATIONAL HEALTH STANDARD FOR THE MANUFACTURE OF SYNTHETIC POLYMER FROM VINYL CHLORIDE March 20, 1974 Industry representatives (PVC/VCM producers) convened at MCA Headquarters on Tuesday, March 19, 1974 to review NIOSH recommendations concerning subject health standards. The meeting was chaired by Mr. A. Vitone - President B. F. Goodrich Chemical. Mr. Vitone's opening comments focused on recent rejection by NIOSH (attached 3/11/74 correspondence) of the concept of a . threshold limit for vinyl chloride gas in the atmosphere. This posture of "zero tolerance" (no minimum threshold level) adopted by NIOSH was described by Mr. Vitone as a precursor to shut-down of the industry should the present recommended standards be promulgated. Issuance of the proposed regulations (OSHA) was described by Mr. Vitone as imminent with the possi bility of DOL action by March 22, 1974. A summary of immediate action items agreed to by a majority of industry representatives present follows: 1. ^ issuance of a statement to OSTIA within 1-2 days regarding industry's position (incompatibility with zero tolerance). NOTE: Telex copies of di'aft statement will be forwarded by MCA's A- Clark to management contacts (Allied - W. SFerguson) for review and endorsement. MCA will then present to OSI-IA on behalf of the VCM Research Group. 2. individual firms present were urged to' wire Assistant Secretary of Labor Stonder advising him of the economic consequences of the NIOSH recommendations. The support of key (VCM/PVC) customers in this undertaking through their issuance of similar wires was also recommended. (1) Committee Chrmn.; R. Fleming - Air products Members: Borden, Diamond-Shamrock, Uniroyal 00023525 2 March 20, 1974 3, Immediate involvement of the Society of the Plastics industry wil] be sought to obtain prompt and effective support of PVC converters. SPI involvement will also be directed toward development of an informational program for Congressional representatives. Lastly, .independent company contacts with OSHA were advocated to provide effective industry inputs to DOL regarding current effort: and programs. (industry/OSHA liaison contact Lou Cox) J. M- Quinn Director Environmental Services JMQ/sm cc: Mr. W. S. Ferguson Attachment (2) Committc:e Chrmn. : Ross Adams Membc rs: Goodyear, Diam on d-Shamro ck AS! 00023526 GENERAL .INFORMATION PRESENTED 1. B. F- Goodrich average worker exposure level for all plants now approximuten 15 PPM with loss, than 1% of worker population exposed to neater than 50 PPM. Preliminary personal monitor ing results have been in the 25-30 PPM range. Most of the BFG data has been derived from use of the portable Century organic vapor analyser ( results include U-C background compounds present). Three Bendix Analyzers have been installed at BFG's Avon Lake (1) and Louisville (2) plants. Each of these units provides a continuous read-out of ambient VCM concentrations from six (6) stationary sample points. A high reading from one of the six stationary points is area "spot-checked" utilizing the portable Century unit. The stationary units are inter locked to sound an alarm at 30 PPM. Immediate respirator use is required at the 30 PPM level with building evacuation re quired at 70 PPM. NOTE: BFG reports canister masks operate without break-through for one-hour in an atmosphere containing 100 PPM VCM. 2. Union Carbide, Diamond-Shamrock, Hooker and Stauffer expressed support for a "livable" TWA standard of 50 PPM. Typical ambient VCM concentrations in polymer operating areas were described as: TWA (8 hr.) - 5 min. - 30 max. PPM Excusions beyond 50 PPM are encountered quently due to leaks, etc. infre 3. BFG reported liver dysfunction in new applicants (Louisville area) approximates 40% of personnel interviewed (SMA-12 blood test). 4. Formal comments have been submitted to NIOSH/OSHA by Air Pro ducts, UCC, Firestone, Conoco, Shell, Dow, BFG, Monsanto. 5. BFG reported total labor force involved in PVC/VCM manufacture and related is as follows*. (extrapolated from A. D. Little) Labor Force PVO/weti Manufacture Compounders and Processors Users (Auto, Refrigeration) 14,000 51,000 842,000 ASI 00023527 .6 E p i d e m x o 1 o g i c 01 r e p o rJ:. (Taber s h aw -Cooper) w i 11 s?'Kj April 15, 1974 . 7- Mr. Vitone presented data from the work of Prof. Maltoni .reflecting the % incidence of tumors vs. exposure time. In summary, the probability of cancer incidence approaches zero (0) at concentrations of VCM in the 50-100 PPM range (95% confidence lim.its). (Statistics based on animal (rats) studies.) 0. Assistant Secretary stendcr inspected Dow and UCC plants in Texas on 3/16/74. Dow - VCM Freeport, Texas UCC - PVC Texas City, Texas Mr. Stendcr has requested a tour through a PVC conversion plant within the next several days (Firestone volunteered to conduct Mr. Stendcr through their Pottstown, Pa. facility). Mr. Clark advised the VCM Research Group members in attendance that other companies now wished to supxport the research effort. Those seeking to participate are not producers but rather con sumers (60 MM lbs/year). Member representatives concurred in accepting new firms of this type at the minimum fee of $2700. ASI 00023528