Document oD13BpYpO0RJV6Q8XxpoX0j68

Vtsto Chemical Company 15990 N. Barker's Landing Rd. Post Office Box 19029 Houstonjexos 77224 Phom (713) 531-3200 I Co-54, June 19* 1986 Mr. Jeff Almondlnger Plant Superintendent Northwlre 100 Industrial Drive Osceola, WI 54020 VIS1A Dear Jeff: As we discussed, the Information below discussed PVC labeling issues and requirements. Under current regulations* there are two standards which potentially impact PVC labeling, those being the 0SHA Vinyl Chloride Standard and the 0SHA Hazard Communication Standard. The 0SHA Vinyl Chloride Standard (29 CFR 1910,1017) requires PVC containers to be labeled with a VCM cancer warning label. However, current legal opinion and interpretation of the 0SHA labeling requirement is summarized as follows: containers holding PVC product need not carry the OSHA warning label when the handling, transport, or processing of that product could not reasonably be expected to release VCM to the atmosphere which could result in worker exposure to VCM above the action level of 0.5 ppm, eight-hour time-weighted average. Technical data in the open literature has shown that PVC product containing less than 8.5 ppm residual vinyl chloride monomer (RVCM) will not release VCM in concentrations that could result in exposures exceeding 0.5 ppm, even under adverse conditions of heat and storage. Based on the above, if your products contain less than 8.5 ppm (RVCM) the VCM warning label would not be required. Vista's PVC Compound does contain less than 8.5 ppm RVCM. The OSHA Hazard Communication Standard (29 CFR 1910.1200) requires manufacturers to evaluate the hazards of their products, according to OSHA criteria, and among other things label containers of those products determined to be hazardous. There is an "article" exemption in the standard which may apply to your products. Although PVC compound may contain hazardous materials as additives, such as lead, the important issue is whether handling the material under normal conditions of use could create an exposure. Vista's experience in our manufacturing plants is that there is no significant exposure to compound additives when handling the actual compound product. The potential for exposure would be even less WV 000016978 Mr. Jeff Almondinger Page 2 June 19, 1986 when handling your finished product. It is Vista's position that our compound products are not hazardous under the Hazard Communication Standard. Also, I have enclosed a letter regarding the status of PVC under the Hazard Communication Standard, and a copy of the latest OSHA enforcement directive for your general information in developing your plant's hazard communication program. Please feel free to call me at 713/531-3445 if you have questions regarding the above. Sincerely, Thomas G. Grumbles, CIH Environmental Quality Manager ajo/9 cc Winton Gibbons vw 0000169T9