Document o3m1M0BxLn98OMQG0RJZnxvw

RECD. MAR i l 1977 FSE ETERNAL CORRESPONDENCE COeesc 7*o /) Tfl'/LOli sMji i<J-, Jk ,-.c elastics / / uJIvllksty S3HS OK LV)iUu (T) l ^Mr. R. L. Fra.tr ? \J TTEEXXAASS CCIITTYY PPLLAANNTT ^ Jff* ^ Vl\e /Of Ur*vOt*44, MrAPtSUW* TO (JL>- . (^V5 L Mr. D. E. Deese Mr. M. E. Eisenhour (D Mr. W. A. Mazzolini 4r. F. S. Provenzano Mr, R. J. Taylor Mr. R. N. Wheeler - 514 ,tcr 3M Brand Vinyl Chloride Respirator No. 8716 Ref; Letters on Subject: (1) D. E. Deese dated Feb. 17, 1977 (attached) (2) R. J. Taylor dated Feb. 22, 1977 (attached) (3) J. W. Whittlesey dated Feb. 28, 1977 (attached In answer to your inquiry of February 10, 1977, I would summarize as follows: Subject mask could be used if its use can be properly controlled to less than 10 ppm concentrations of Vinyl Chloride, and a record keeping system can be maintained to insure ourselves as well as OSHA, that the masks are being used only within the specified design limits. The deminimus citation would pose no legal problem according to Mr. Whittlesey. However, I would strongly suggest management U/A on this question. Please refer to specific comments/concerns of Messrs. Deese, Taylor, and Whittlesey, attached. If you have additional questions please contact me. JBL:ir Attachments /<7. B. Leverton UCC 094682 MEMORANDUM To: Mr. J. B. Leverton Date: February 17, 1977 From: D. E. Deese Subject: Letter from R. L. Frantz dated February 10, 1977 Dear John: The initial selection of respirators for VCM regulated areas was based on the following criteria: 1) Shall be selected from those jointly approved by MESANIOSH. 2) Shall be selected per Schedule 1910.1017 (g)(4). 3) Shall offer maximum protection for the respective categories of respiratory types -- namely, (1) self-contained emergency equipment, (2) Type C supplied air respirator, and (3) Airpurifying canister or cartridge type. Additionally, 1910.1017 (g)(6) further requires where air-purifying respirators are used: 1) Replacement prior to the expiration of their service life or the end of the shift in which they were first used, whichever occurs first, and 2) Use of a continuous monitoring and alarm system "to alert employees when VCM concentrations exceed the allowable concentrations for the devices in use." Considering the above, the respirators selected were: (1) M-S-A Self-contained Breathing Apparatus, pressure demand type, with full facepiece ........... good for unknown concentrations or above 3600 ppm*, (2) M-S-A combination Type C Supplied Air Respirator, pressure demand type, with full facepiece and auxiliary air supply----good for not over 3600 ppm; and (3) M-S-A Gas Mask, 4-hour canister ----good for not over 25 ppm. The latter is the one inquestion. UCC 094683 2- We do not recommend use of the 3-M Respirator No. 8716 until the following are realized: 1) MESA-NIOSH approval. 2) Fewer incidents of VCM concentrations above 10 ppm occur. 3) An alarm system at 10 ppm exists. Our observations and calculations indicate the need to upgrade the type respirator used -- not downgrade. We cannot abandon quality protection solely to comfort and convenience. These same basic criteria were expressed by letter dated April 21, 1976 on the subject of half- facepiece respirators. Your comments are welcome. D. E. Deese Industrial Hygiene Director ec UCC 094684 INTERNAL CORRESPONDENCE i V ED MAK 2 1977. received FEB 2 2 1977 "sSFirrwpr:*- ' S and plast/cs /.Mr. R, J. Taylor Mr. J. W. Whittlesey - 501 (46) !j ->X 4,'I, U ',4j i lT`f. TEXfcS tf February 17, 1977 Ref. (1) Letter of R. L. Frantz to J. B. Leverton re. 3M Brand Vinyl Chloride Respirator No. 8716 dated February 10, 1 977 (attached) 3M Brand Vinyl Chloride Respirator No, 8716 Ref. (2) Letter of W. P. Harris of 3M Company to R. L, Frantz dated January 19> 1977 (attached) Gentlemen: This is to request your input and guidance regarding the use of subject respirator in VCM exposure situations. Specifically: (11 Do you recommend use of the mask in our vinyls departments at this time ? (2) What would our legal liability be considering possible "de minimus citations' J ilL. Any comments you may have would be most appreciated. Please contact me if you have any questions. o. K- bnttd CXyvJ bjU Thanks, TAaAANt't'Wr'ju)- E-.tj. ^-10^ ^ LlU,<VV1 d hwJL JLQ-tP ^JUAuAjiiyi X.U //JDM/VU . Joihhp/fe. Leverton kcdw. UiuP JBLur Attachments Cn-T" r) ' jja JcMflktAp \mhJL' P- ^^ CUwiCii/V'i'u' la Z*J- cJot-i)uu . '^Uff AJM^~ UCC 094685