Document oD3d04rLaNgvm821DJ0aq559E

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION MARY A. DENDINGER, etc., Plaintiffs, vs. CHRYSLER PLASTIC PRODUCTS CORPORATION, et al.. Defendants. ) Case No. C 87-7117 ) ) [Hon. Nicholas J. Walinski] ) ) RESPONSE OF DEFENDANT UNION ) CARBIDE CORPORATION TO ) PLAINTIFFS' REQUESTS FOR ) PRODUCTION OF DOCUMENTS ) DIRECTED TO ALL DEFENDANT ) PVC MANUFACTURERS -0O0- Now comes defendant Union Carbide Corporation and for its response to plaitniff's Requests for Production of Documents, states as follows: 1. All records of sales, direct or indirect, of Polyvinyl Chloride (PVC) resin from you to Chrysler Plastic Products Corporation (Chrysler) between January 1, 1967 and December 31, 1980. ANSWER: See Attachment 1. 2. All documents indicating the extent to which PVC resin sales to Chrysler during the time period indicated above, represented sales of PVC resin manufactured in the: (a) suspension; (b) emulsion; (c) bulk; or, (d) solution process. ANSWER: See Attachment 1 3. All documents indicating the extent to which PVC resin sales to Chrysler during the time period specified in request number 1, were of (a) Homopolymer; (b) copolymer; or, (c) terpolymer. ANSWER; See Attachment 1. 4. All written documents indicating, with respect to PVC resin sold to Chrysler during the time period specified above, the size (in microns) of the resin sold. ANSWER: No records which would be responsive to this request have been located. 5. All written documents indicating the results of any tests done on any PVC resin by you or any other entity to determine the concentration (in parts per million) of residual vinyl chloride monomer in PVC resin of the type sold to Chrysler during the time period specified in request number 1. ANSWER; See Attachment 2. 6. All Material Safety Data Sheets published by you prior to January 1, 1986, relating to any PVC resin manufactur d by you. ANSWER; See Attachment 3. -2- UCC 082836 1* V 7. All documents in your possession indicating the dates of manufacture and the dates of shipment of PVC resin sold to Chrysler. ANSWER; See responses to Request for Production No. 1 and Interrogatory No. 12. 8. All written results of any testing done on the PVC resin identified in the prior request to determine the concentration of residual vinyl chloride monomer. ANSWER: See response to Request for Production No. 5. 9. All documents sent by you to the Occupational Safety & Health Administration, relating, in any way, to PVC. ANSWER; See Attachment 4. 10. All documents reporting or summarizing efforts taken by you, at any time since January 1, 1967 to reduce the percentage of residual vinyl chloride monomer in PVC resin manufactured by you. ANSWER; No records which would be responsive to this request have been located, see response to Interrogatory No. 19. 0628i! -3- \ 11. Each and every document sent to Chrysler, informing Chrysler of any known or potential human health hazard 4 relating to exposure or over exposure to vinyl chloride monomer. ANSWER: See Attachments 3 and 5. AS TO OBJECTIONS: Of Counsel For Defendants The BFGoodrich Co., The Goodyear Tire & Rubber Co., Firestone Tire & Rubber Co., Conoco, Inc., Uniroyal, Inc., Union Carbide Corp., Diamond Shamrock Corp., Tenneco, Inc. and Occidental Chemical Corp.; FULLER & HENRY 1200 Edison Plaza 300 Madison Avenue P.O. Box 2088 Toledo, Ohio 43603 Robert A. Bunda 1200 Edison Plaza 300 Madison Avenue P.O. Box 2088 Toledo, Ohio 43603 Telephone: (419) 255-8220 Attorney for Defendants The BFGoodrich Co., The Goodyear Tire & Rubber Co., Firestone Tire & Rubber Co., Conoco, Inc., Uniroyal, Inc., Union Carbide Corp., Diamond Shamrock Corp., Tenneco, Inc. and Occidental Chemical Corp. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Responses to Plaintiff's Requests for Production of Documents Directed to all Defendant PVC Manufacturers was mailed by United States mail, postage prepaid, to Kirk J. Delli Bovi, Esq., attorney for plaintiff, at his office located at Murray & Murray Co., L.P.A., 300 Central Avenue, Sandusky, Ohio 44870, and to defense counsel as set forth in the attached Schedule of Service this day of February, 1987. An Attorney for Defendants The Goodyear Tire & Rubber Company, The BFGoodrich Company, Firestone Tire & Rubber Company, Conoco, Inc., Uniroyal, Inc., Union Carbide Corporation, Diamond Shamrock Corp., Tenneco, Inc. and Occidental Chemical Corp. SCHEDULE OF SERVICE M. Donald Carmin, Esq. 800 United Savings Building Toledo, Ohio 43604 Attorney for Defendants Chrysler Plastic Products Corporation Norman P. Phillips Albert W. Cramer Robert D. Gustine William C. Holsapple Ron C. Abbott Willis P. Jones, Jr., Esq. 200 Toledo Legal Building 416 N. Erie Street Toledo, Ohio 43624 Attorney for Defendant DiversiTech General, Inc. S. Stuart Eilers, Esq. Douglas N. Barr, Esq. Timothy J. Coughlin, Esq. 1100 National City Bank Bldg. Cleveland, Ohio 44114 Attorney for Defendant Stauffer Chemical Company H. William Bamman, Esq. 414 N. Erie Street Toledo, Ohio 43624 Attorney for Defendant A. Schulman, Inc. Ellis F. Robinson, Esq. 610 United Savings Building Toledo, Ohio 43604 Attorney for Defendant Shintech, Inc. UCC 062840 <972 1973 1974 1975 1976 1977 Suspension PVC Homopolymer - 40,500 lbs. In November and 40,450 lbs. in December.. Solution Vinyl (PVC) VYHH 2,000 lbs. Nonsolvent (PVC) Copolymer YYNW-5 - 11,000 lbs. Solution Vinyl (PVC) YYHH - 16,000 lbs. Nonsolvent Copolymer YYNW-5 - 9,000 lbs. Solution Ytr\yl YYHH - 12,000 lbs. Nonsolvent Copolymer YYNW-5 - 3,800 lbs. Solution Vinyl YMCH - 50 lbs. Nonsolvent Copolymer YYNW-5 - 17,000 lbs. Solution Vinyl YMCH - 2,750 lbs. Solution Vinyl VYNS-3 - 200 lbs. Solution Yinyl VYHH - 6,750 lbs. Nonsolvent Copolymer YYNW-5 - 11,000 lbs. Solution Vinyl YYNS-3 - 2,250 lbs. ucc 062841 Attachment 1 DETERMINATION OF RESIDUAL VINYL CHLORIDE MONOMER IN VINYL RESINS 1 PURPOSE A procedure for determining the amount of residual vinyl chloride present in vinyl rosins is described. The resin is dissolved in a solvent and tho vinyl chlorido analyzed using a gas chromato graphic technique. The method is applicable for use with poly- (vinyl chloride), vinyl chloride-vinyl acetate copolymers and other vinyl resins in which there are no volatiles which interfere in the determination. 2 EQUIPMENT AND REAGENTS Gas Chromatograph, Hewlett-Packard (F and II) Model 5750 or equivalent, equipped with a hydrogen flame ionization detector. Tetrahydrofuran, reagent grade. Balance with accuracy to 0.10 gram. 2 SAMPLE PREPARATION Prepare the sample for chromatograph injection by dissolving the test resin in tetrahydrofuran (THF). Weigh 9 grams of THF into a suitable vial. Add 1 gram of the resin to be tested to the THF. Resin addition should be made as quickly as possible. Cap the`bottle and place it on a can-roller to attain complete solution. When complete solution has occurred, the sample is ready for injection into the chromatograph. 4 INSTRUMENT PARAMETERS Instrument Hewlett-Packard (F and M) Model 5750 (or equivalent) equipped with hydrogen flame ionization detector. Column Six-feet by 1/8-inch stainless steel tubing packed with Cbromosorb 102, 60/80 mesh. Temperatures: Column Injector Detector 100*C for 4 minutes, manually Increased to 250C 100C (maximum) 300C (flame ionization) Sample Size 4 Microliters Flows: Helium Carrier Gas Hydrogen Compressed Air 25 cc/mlnute 20 psi at cylinder head 40 psi at cylinder bead Attachment 2 \ (Continued) Elution Tines Vinyl Chloride Tetrahydrofuran 2.8 minutes 6.3 minutes 5 CALIBRATION Prepare solution mixtures of varying amounts of vinyl chloride in tetrahydrofuran to cover the expected range of concentration. Obtain from the chromatograph scan the area percent of vinyl chloride for each sample of known monomer content. Prepare a chart plotting the area percent vinyl chloride versus the known weight percent vinyl chloride to establish the relative detector response of the vinyl chloride with respect to tetrahydrofuran. 6 calculation Determine the area percent vinyl chloride from the chromatograph scan for the resin solution to be characterized. Multiply this figure by 10, which converts the data to area percent vinyl chloride based on resin weight. Using the chart developed with the cali bration samples, read off the corresponding weight percent of vinyl chloride. ycc 062843 JHfcTM m 'J..-'K- --^ b- -y HJ=3~3:* 3jfcj':irt:;r*~ .v.ir.u '.'/urv.ttrrr**; r.vt. vr.;.n. .nvr ^rr U-.L-ttll 3^ S3* SH i*^3=5|=3; ff-t xTjri:^r|J L=i "UJrr~;~xrj ?.Ssji."`.jj:: {r.-rjr^jx-i: 43: ^rtrtrr j3Ii ;4^H m.4ji^*M**T.v*:.'*ri\`CTr;rt m~nr:r* ,.,i,l.'K.2 *ift :rr.i:vt u;,r, ,i .-3L 53= -r- if - ~C-V~' IT-gagSE 0.0050 ?-sxpnfrt irn^ra rrtvis. ^rs:rsgfieH; t;at^gsgs?:4^1^ris,~sut:TMa; --~~?~?a=an3 -at] 4S.4: i** | rffip |5yT5! :sfcw iTSH'iw rf!ilT.!ivrn=s LUj -,l .l!Hl:l. iAlU.lB4Ii4iSijiSiliLi-! -ijillJi-'.ljl'L! ijiJ^ Wwm\1P asE 4i iiiilk [.,;; ji :rai"S!i *.*; ii.,- to* lirili njMil 1rTl ^ "T-" : m stasi:a1s#. ~ xa^~ Tgvsyrs K3= Ti'^jS^fS.ca?. ss. saggraerax ~ 0.0010 0.002W00eig.0ht0P3e0rc*** 0.00*oft UCQ 062844 r "trafift" IL1ATERIAL SAFETY DATA SHEET (Approval by U-5. D*prtmnt of Labor *-ntiily Similar" to Form LS0-OO5-4) CHEMICAL NAME: BAKEUTE VINYL CHLORIDE-ACETATE RESIN VYHH r SYNONYMS: FORMULA: i ill 'CHa-CH\ /CHj -- CH I ^0 OC~CH3 CHEMICAL FAMILY: Chlorirfe-Vinvl Acetate _____________ Copolymer (85:15 ratio! MOLECULAR WEIGHT: Wn - 14,800 TRADE NAME AND SYNONYMS: 'ILING POINT, 760 mm. H9 8AKELITE Vinyl Chloride-Acetate Retin VYHH I. PHYSICAL DATA Not applicable FREEZING POINT CIFIC GRAVITY (HaO 1) OR DENSITY (air1J ENT VOLATILES LUME RANCE AND ODOR 1.351 0.005 at 20/20#C. VAPOR PRESSURE AT 20eC. Not applicable SOLUBILITY IN WATER. % by wt. EVAPORATION RATE (Butyl Acetate 1) White powder; mild, alcohol-etter like odor. II. HAZARDOUS INGREDIENTS^ Not applicable Not applicable Nil Not applicable MATERIAL Not applicable % TLV (Unit*) ................................................................................................................. III. FIRE AND EXPLOSION HAZARD DATA >600F., Cleveland open cup * AufoiGNITION " 17Q9*t aTBaE->.M>aPeeEinR--aA.iTwU.jRe --E______ m--* on--'_w__w_w__e_e_e_Mi MITS IN AIR, % by volume LOWER Not applicable UPPER Not applicable Carbon dioxide or dry chemical for small fire*. Water for large fire*. TNG None Hydrogen chloride may be formed under fire condition*. Self-contained breathing equipment may be neceuary. _ EMERGENCY PHONE NUMBERS____________ OrTc. U. Dernehl 212/551-478*5; 914/946-0646*TnightT Or. K. S. Lene. 212/551-4787; 914/666 3656 (night) C. P. Carpenter, Ph.D., 412/327-1020; 412/241-7896 (night) - k eoumed only (or the feet thet ell nudies reported her* end *lt opinion* or* ** 'ORATION - Attachment " (d ' \ THRESHOLD LIMIT VALUE EFFECTS OF OVEREXPOSURE IV. HEALTH HAZARD DATA 15 mg./M.3 inert dust value No systemic effects. Very high dust concentrations may irritate respiratory passages and eyes as will any dust at high air levels. ;MERGENCY AND FIRST ID PROCEDURES None STABILITY STABLE I STABLE V. REACTIVITY DATA CONDITIONS j jq AVOID None 'PATfBTtTnT ils to avoid) None DOUS 'OSITION PRODUCTS 'OUSPOLYMERIZATION cur Will not Occur V Thermal decomposition may produce hydrogen chloride, jarbon monoxide, and/or carbon dioxide. _May evolve hydrogen chlonde at temperatures above 150C.___ ___________ __ __________ CONDITIONS None VI. SPILL OR LEAK PROCEDURES ^J TAKEN mm. IS RELEASED Sweep up end put in waste containers; flush excess with water. 1AL METHOD Bury in a landfill. VII. SPECIAL PROTECTION INFORMATION ROTECTIQN 'pel 'CAL EXHAUST CHANICAL (general) ES Dust respirator in very high dust levels Preferable Acceptable Not required SPECIAL OTHER : eye l PROTECTION Eye bath and safety shower VIII. SPECIAL PRECAUTIONS Safety spectacles LING BAKELITE VINYL CHLORIDE-ACETATE RESIN VYHH On the basis of toxicological, physical, and chemical properties of BAKELITE Vinyl Chloride-Acetate Resin VYHH, precautionary labeling used on the containers is as follows; FOR INDUSTRY USE ONLY FlIATERIAL safety data sheet (Approved by US. Dprtmnt of tbor *'E*ntilly to Form I.S6-OOS-4) J_ CHEMICAL NAME: SYNONYMS: FORMULA: BAKEUTE VINYL CHLORIDE-ACETATE RESIN VYNS Vinyl Chloride-Vinyl Acetate CHEMICAL FAMILY: Copolymer (90:10 ratio) r**r \ L oj + OC-CM, + MOLECULAR WEIGHT: Mn -34,800 TRADE NAME AND SYNONYMS: r-------------------- BOILING POINT, 760 mm. Hg SPECIFIC GRAVITY (H,0 - 1) VAPOR DENSITY (air - 1) PERCENT VOLATILES BY VOLUME APPEARANCE AND ODOR BAKEUTE Vinyl Chloride Aceute Resin VYNS i; PHYSICAL DATA Not applicable j FREEZING POINT 1.36 4 0.005 at 20/20eC. VAPOR PRESSURE AT 20*C. Not applicable 0 SOLUBILITY IN WATER. % by wt. EVAPORATION RATE (Butyl Acetate * 1) White, powdered solid; mild, alcohol-ester like odor. II. HAZARDOUS INGREDIENTS MATERIAL ^ Not applicable % Not applicable Not applicable Nil Not applicable TLV (Units) III. FIRE AND EXPLOSION HAZARD DATA VSH POINT >500*F.. Cleveland open cup : method) I B02*F. (estimated) MMABLE LIMITS IN AIR, % by volume LOWER Not applicable UPPER j Not applicable NGUISHING A Carbon dioxide or dry chemical for small fires. Water for large fires. VL FIRE FIGHTING DURES None M. FIRE AND ION HAZARDS Hydrogen chloride may be formed under fire conditions. Self-contained breathing equipment may be necessary. EMERGENCY PHONE NUMBERS Dr. C. U. Dernehl, 212/551-4785; 914/946-0646 (night) Dr. K.S. Lane, 212/551-4787; 914/666-3656 (night) C. P. Carpenter. Ph D., 412/327-1020; 412/241-7B96 (night) Legal responsibility it essumed only tor the feet that a studies reported here and all opinion! are thpie at --l; ON CARBIDE CORPORATION a CHEMir' o\$&> - K- fc. -TV- v\ THRESHOLD LIMIT VALUE IV. HEALTH HAZARD DATA 15 mg /M 3 inert dust value EFFECTS OF OVEREXPOSURE No systemic effects. Very high dust concentrations may irritate respiratory passages and eyes as will any dust at high air levels. EMERGENCY AND FIRST AID PROCEDURES None [......... .... .................................. .........V. REACTIVITY DATA stability le STAB l V INCOMPATIBILITY (materials to avoid) None HAZARDOUS DECOMPOSITION PRODUCTS Thermal decomposition may produce hydrogen chloride, carbon monoxide, and/or _carbon dioxide. May evolve hydrogen chloride at temperatures above 150rC. HAZARDOUS PO LYME RIZ ATI ON ----~------------ 1---rr------~---------- CONDITIONS May Occur Will not Occur TO AVOID .. None .......... " ...... VI. SPILL OR LEAK PROCEDURES STEPS TO BETAKEN IF MATERIAL IS RELEASED OR SPILLED Sweep up and put in waste containers; flush excess with water. WASTE DISPOSAL METHOD Bury in a landfill. [ VII. SPECIAL PROTECTION INFORMATION RESPIRATORY PROTECTION (specify type) Dust respirator in very high dust levels VENTILATION ~P^AL exhaust MECHANICAL _______________ (general) PROTECTIVE GLOVES OTHER PROTECTIVE rEQU-IPME-NT - - Preferable Acceptable Not required SPECIAL OTHER EYE 1 PROTECTION 1 Safety shower and eye bath VIII. SPECIAL PRECAUTIONS -- S*,etv 993' BAKELITE- VINYL CHLORIDE-ACETATE RESIN VYNS PRECAUTIONARY LABELING On the basis of toxicological, physical, and chemical properties of BAKELITE Vinyl Chloride-Acetate Resin VYNS. precautionary labeling used on the container* is as follows; FOR INDUSTRY USE ONLY OTHER HANDLING AND STORAGE CONDITIONS *431M >* *# _ UCC 062848 r'lnlid In U.S-A. MATERIAL SAFETY DATA SHEET (Approved toy U S. OepeMmem of L**bcH*`Eintf#lly Smi/r" to Form LSB-OOS<4) r C L CHEMICAL NAME: BAKEUTE VINYL CHLORIDE-ACETATE RESIN VMCH SYNONYMS: FORMULA: VMCH; Vinyl Chloride-Vinyl AcetateMaleic Acid Terpolymer ' /CHj-CH\ /CHa-CH \ J CH------CH \ ' \ Cllt OA^ "\COOH COOH/, rurMirAi cmhi vCHEMICAL FAMILY: Vinyl Chloride Vinyl Acetate.M3,eic Acid Terpolymer MOLECULAR WEIGHT: - 21,000 (average) TRADE NAME AND SYNONYMS: BAKEUTE Vinyl Chloride-Acetate Resin VMCH [ ........... ... ...... "" ">. PHYSICAL DATA BOILING POINT. 760 mm. Hg Not applicable FREEZING POINT SPECIFIC GRAVITY (HaO 1) VAPOR DENSITY (air - 1) PERCENT VOLATILES BY VOLUME APPEARANCE AND ODOR [ 1.3510.005 at 20/20C. VAPOR PRESSURE AT 20C. Not applicable SOLUBILITY IN WATER. % by wt. EVAPORATION RATE (Butyl Acetate 1) White, powdered solid; very slight, pleasant odor. II. HAZARDOUS INGREDIENTS MATERIAL Not applicable % Not applicable Not applicable Nil Not applicable TLV (Units) f "' ____ III. FIREAND EXPLOSION HAZARDDAJA^ ftefmeSf1 \ >500F.. Cleveland open cup j AUTOIGNITION 788*F. (estimated) FLAMMABLE LIMITS IN AIR, % by volume LOWER Not applicable 1 UPPER j Not applicable EXTINGUISHING MEDIA Carbon dioxide or dry chemical for small fires. Water for large fires. SPECIAL FIRE FIGHTING PROCEDURES None UNUSUAL FIRE AND EXPLOSION HAZARDS Hydrogen chloride may be formed under fire conditions. Self-contained breathing equipment may be necessary. I uccEMERGENCY PHONE NUMBERS Dr. C. U. Dernehl. 212/551-4785; 914/946-0548 (night) Dr. K. S. Lane, 212/551-4787; 914/666 3656 (night) 062849 C. P. Carpenter. Ph D., 412/327-1020; 412/241-7896 (night) Legal responsibility fc assumed only lor the feet that all studies reported here and all opinions are those of Qualified experts. * ie t^eetee t m , z. T |\ THRESHOLD LIMIT VALUE EFFECTS OF OVEREXPOSURE IV. HEALTH HAZARD DATA None None expected. An inert, nuisance-type dust. - EMERGENCY AND FIRST XID PROCEDURES Flush eye contact with water. No other care should be needed. V. REACTIVITY DATA STABILITY UNSTABLE -- STABLE V CONDITIONS TO AVOID None 'COMPATIBILITY " Materials to avoid) ^ZARDOUS :COMPOSITION PRODUCTS \ZARDOUS POLYMEfflZATlON May Occur -- Will not Occur V None Thermal decomposition may produce hydrogen chloride, carbon __monoxjde, and/or carbon dioxide.____________ CONDITIONS TO AVOID None VI. SPILL OR LEAK PROCEDURES cPS TO BE TAKEN MATERIAL IS RELEASED SPILLED Clean up spilled material and put in waste containers; flush excess with water. STE DISPOSAL METHOD Bury in a landfill. VIL SPECIAL PROTECTION INFORMATION PlRATORY PROTECTION (specify type) LOCAL EXHAUST TJLATION MECHANICAL (general) FECTIVE GLOVES Dust respirator, Bureau of Mines approved -- Acceptable Not required SPECIAL OTHER ' PROTECTION | -- -- Safety spectacles ER PROTECTIVE iPMENT Safety shower and eye bath VIII. SPECIAL PRECAUTIONS BAKELITE VINYL CHLORIDE-ACETATE RESIN VMCH AUTIONARY LABELING On the basis of toxicological, physical, end chemical properties of BAKELITE Vinyl Chloride-Acetate Resin VMCH, precautionary labeling used on the containers is es follows: FOR INDUSTRY USE ONLY R HANDLING AND \GE CONDITIONS 7 M ucc 062850 r ;/ ic IMTERIftL SAFETY DATA SHEET rp*oved byUS c* l thru teniiai\ .m. *r i Ftm V SB-DOS'4' r [" ft CHEMICAL NAME BAKELITEff VINYL CHLORIDE ACETATE RESIN VYNW SYNONYMS. CHEMICAL FAMILY; Vinyl Resins FORMULA 2 T 2 1 v4CH,-CH +I+CHJ-CH4V Cl OC - CH, II 3 O MOLECULAR WEIGHT; TRADE NAME AND SYNONYMS. BAKELITE Vinyl Chloride-Acetate Resin VYNW - 140.000 t ' : "l. PHYSICAL DATA " -- BOILING POINT. 760 mm. Hg Not applicable FREEZING POINT Not apphcabl SPECIFIC GRAVITY (H-O =1) VAPOR DENSITY iair si) PER CENT VOLATILES BY WEIGHT >APPEARANCE AND ODOR il 1.4 Not applicable 1 White powder; odorless. VAPOR PRESSURE at 20C. SOLUBILITY IN WATER, % by wt at 20'C. *EVAPORATION RATE (Butyl Acetate 1) II. HAZARDOUS INGREDIENTS MATERIAL Not applicable % Not apphcablNil Not apphcabl TLV (Units' III. FIRE AND EXPLOSION HAZARD DATA FLASH POINT (test melhod'1 >500CF.,Cleveland open cup AUTOIGNITION TEMPERATURE 820CF. (estimated) FLAMMABLE LIMITS IN AIR. % by volume LOWER | Not applicable UPPER Not applicable EXTINGUISHING MEDIA Carbon dioxide or dry chemical for small fires. Water for large fires. SPECIAL FIRE FIGHTING PROCEDURES None % UNUSUAL FIRE AND EXPLOSION HAZARDS Hydrogen chloride may be formed under fire conditions. Self-contained breathing equipment may be required. EMERGENCY PHONE NUMBERS " Dt. C U. Demehl. 212'551-4785. 914'946-0646 (night) Dr. K. S. Lane, 212 '551-4787; 914 666-3656 (night) C. P. Carpenter, Ph.D.. 412 327 1020; 412.241-7896 (night) ucc 062851 b itty %% itsumts n`> i iht Uct ihi? an studies repoMec and ar opinions art most of out' (t3 t&ptnt UNION CARBIDE CORPORATION-CHEMICALS AND PLASTICS-270 PARK AVENUE, NEV. YORK, N.Y. 10017 { 7" ~..... THRESHOLD LIMIT VALUE EFFECTS OF OVEREXPOSURE jV.~ HEALTH HAZARD DATA 15 mg./M.* inert dust value. No systemic effects. Very high dust concentrations may irritate respiratory passages and eyes, just as any dust will at high air levels. EMERGENCY AND FIRST vID PROCEDURES None required. V. REACTIVITY DATA STABILITY ^STABLE STABLE V DMPATlBlL itV* erials to avcjid) 4.RDOUS IMPOSITION PRODUCTS CONDITIONS TO AVOID None None Thermal decomposition may produce hydrogen chloride, carbon monoxide, and/or carbon dioxide. RDOUS POLYMERIZATION ' Occur Will not Occur CONDITIONS TO AVOID -- V None VI. SPILL OR LEAK PROCEDURES TO BE TAKEN mRIAL IS RELEASED OR Sweep up and put in waste containers. Flush excess with water. DISPOSAL METHOD Bury in a landfill. VII. SPECIAL PROTECTION INFORMATION -ORY PROTECTION >ecify type) Dust respirator in very high dust levels LOCAL EXHAUST ON ME(gCeHnAeNraICl) AL E GLOVES Preferable Acceptable * * H " -** * Not required SPECIAL OTHER * * .***. ._ EYE | PROTECTION | 'TECTIVE Safety shower and eye bath -- Safety spectacles VIII. SPECIAL PRECAUTIONS BAKEUTEVINYL CHLORIDE-ACETATE RESIN VYNW *RY LABELING On the basis of toxicological, physical, and chemical properties of BAKELITE Vinyl Chloride-Acetate Resin VYNW, precautionary labeling used on the containers is as follows: FOR INDUSTRY USE ONLY AND Editions SOUTH CHARLESTON PLANT UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS P. 0. BOX B004, SOUTH CHARLESTON, W, VA. 2S303 December 2, 1974 Mr. John Stender Assistant Secretary of Labor for Occupational Safety and Health U. S. Department of Labor 14th Street and Constitution Avenue Washington, D. C. 20004 Re: Dear Mr. Stender Occupational Safety and Health Standard for Exposure to Vinyl Chloride The Occupational Safety and Health Standard for Exposure to Vinyl Chloride promulgated on October 4, 1974 applies to the transportation of vinyl chloride and polyvinyl chloride.......... The broad application of this standard is such that all employees of distributive organizations must be monitored for exposure and trained in the hazards of vinyl chloride, and that records of thos employees monitoring and training be maintained for thirty years. A fourounce sample of polyvinyl chloride shipped by parcel post in a sealed can would require monitoring, training, and records for a mass of postal employees despite the fact that no significant exposure to vinyl chloride monomer could occur. A single, fifty-pound, paper bag of resin is essentially treated the same as a rail car containing fifty tons. In the case of the large bulk container be it ship, rail car, or truck, adherence to the letter of the standard regarding monitoring, training, and record keeping is relatively easy and the transporta tion company has an economic incentive to transport the product. In the case of the single bag shipment, the multi-bag shipment, or the sample shipment, the logical move on the part of the transportation company is simply to refuse shipment to spare themselves the obvious expense involved in monitoring, train ing, and record keeping. The same applies to the public warehouse man and the terminal operator. Many of these distributive companies have indicated that they plan to handle direct truck load or rail car load shipments only of poly vinyl chloride* Union Carbide Corporation owns and operates major polyvinyl chloride resin production facilities at South Charleston, West Virginia and at Texas City, Texas. Production facilities at these locations produce a variety of polyvinyl chloride resins by four different processes - suspension polymeri zation, bulk polymerization, mulsion polymerization, and solution polymeriza tion. Only on of these polyvinyl chloride resin products, suspension r sins. Attachment 4 fn. 1 nf on Mr. John Stender -2- December 2, 1974 contains significant amounts of vinyl chloride monomer; this material is generally shipped by bulk and represents no considerable problem in distribu tion. Products from the other three processes are distributed world-wide via a network of warehouses and transportation companies. Of these resins, approximately one half or 100, 000, 000 pounds per year are ultimately deliver d to about 1,500 customers in less -than-truck-load quantities. The average ship ment is estimated to be 11, 000 pounds. These less-than-truck-load shipments (9, 500 per year) involve 41 public warehouses and up to 200 different common carrier trucking companies in the United States alone. The value of these sales to Union Carbide Corporation is approximately $22,000, 000 per year. A sub stantial number of trucking and warehouse companies have indicated they do not wish to handle these shipments in the future. Union Carbide Corporation thus finds itself with having to meet a very difficult standard in its production facilities and with being unable to supply many of its smaller customers. Other companies are faced with similar problems. Union Carbide Corporation is also concerned about the distribution problem as it is related to its customers. Many of Union Carbide's customers are formulators of lacquers, plastisols, and organosols for coating and molding applications. These liquids are normally shipped in closed steel drums by common carrier truck. As required by the Standard, monitoring, training, and record keeping are needed. It is very hard to conceive how a vinyl resin con taining no detectable vinyl chloride monomer, formulated into a coating material, and shipped in a sealed steel drum can be a hazard to a trucker or anyone else. This problem was discussed with Mr. Grover Wren, Chief of Health Standards Development, by Dr. R. S. Brookman of Firestone Plastics Company, Mr. Wayne T. Brooks of Organization Resources Counselors, and me on November 26, 1974. The consensus of the discussion was that good monitoring studies of shipments correlated with type of PVC, weight of the shipment, vinyl chloride content of the PVC, the mode of shipment, and the resin container could be used to develop shipping rules, freight classifications, and resin containers to fulfill the spirit of the vinyl chloride standard without requiring all of the monitoring, et Cetera burdens of the transportation company. With adequate guidelines for the shipper and the transportation company owners, application of the Standard's requirements for monitoring, training, and record keeping can be avoided without any sacrifice of employee safety. Due to the diversity of the industry interests and the broad sweep of the vinyl chloride Standard in its safety objective, I think the Department of Labor should take the initiative in providing clear-cut rules and procedures for vinyl resin transportation and distribution. Certainly, a trucking company in i ICC 062854 Mr. John Stender -3- December 2, 1974 Des Moines, Iowa, hauling 2, 000 pounds of solution polymerized VYHH resin containing no detectable vinyl chloride monomer, should not have to monitor its employee vinyl chloride exposure, train them in its hazard, and keep such records thirty years. A task force or committee, under the direction of the Assistant Secretary of Labor, should certainly be able to arrive at performance standards and rules for the distribution industry that achieve the objectives of the Standard. Union Carbide Corporation, Firestone Plastics Company, and many others would be willing to contribute data and alternative distribution technics to such a group. The formation of such a group could do much to clear up other questions regarding this Standard and to demonstrate that the Department of Labor considers employee safety a cooperative effort by all concerned. Very truly yours RNWJr/ra R. N. Wheeler, Jr. 'tUVAUVI SOUTH CHARLESTON PLANT UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS P-O. BOX *004, SOUTH CHARLESTON, W. VA. 253* , < :* February 14p 1975 Mr, Grover C, Wrehn Chief, Division of Health Standards Development Occupational Safety and Health Administration U. S. Department of Labor =\. 1726 M Street, N. W. Washington, D, C, 20210 Re: * Dear Mr, Wrenn: Classification of Union Carbide Corporation Vinyl Coating ResinB Occupational Safety and Health Administration Standard Exposure to Vinyl Chloride Union Carbide Corporation's vinyl coating resins from its Dispersion and Solution Vinyl Resin processes should be considered fabri cated products under the Occupational Safety and Health Administration Standard Exposure to Vinyl Chloride for the following reasons: 1. Dispersion and Solution Vinyl Resins are "fabricated" for use and application via coating technology. f 2, Dispersion and Solution Vinyl Resins are controlled to contain less than one part per million by weight of residual monomer. Storage, transport, or use of these resins does not result in work place air vinyl chloride concentrations in excess of die standard's action level of 0, 5 ppm* * ' A plastic, by definition, is a material which, when subjected to heat and pressure, can be formed into useful articles. In the case of a vinyl resin, the vinyl chloride monomer, with or without other monomers, is reacted to form a free-flowing, non-dusty powder. The resin particles are approximately'one hundred microns. To convert this material to a finished plastic pr duct, the powder is first mixed and heated in a high intensity mixer for ap* proximately ten minutes at 200*F. From this mixer the batch is transferred to a Banbury mixer, a two-roll mill, or an extruder where it is mechanically mixed and heated to 375-400*F, converting the resin plasticizer and additives v Mr. Grover C, Wrenn -2- February 14, 1975 to a hot, doughy mass. This mass is then calendered to produce a film, molded to make records or extruded into a shape such as garden hose. The finished product is then cooled. The mixing and forming requires five to ten minutes followed by cooling for possibly ten minutes. The heating for periods up to twenty minutes, coupled with mechanical working which constantly ex poses new surfaces, drives out contained residual vinyl chloride monomer. This vinyl chloride monomer driven out mustbe removed or destroyed to avoid serious contamination of the work space air. A coating is a polymeric composition applied to a substrate. This polymeric composition iB made applicable by dissolution in a solvent or by a fine particle dispersion in an organic or aqueous medium. The fluid coating composition is sprayed, rolled, brushed, or poured on the substrate where by evaporation, dissolution, or reaction a film is formed. For industrial appli cations, such as can lining, film formation is accelerated by brief periods of heating - one to five minutes at temperatures up to 350*F followed by cooling. There i6 no mechanical working of the coating and no need to have a hot plastic mass for an extended period. The brief heating period serves to drive out the solvent, or the dispersing medium, to react the polymeric materials and to dissolve the plasticizer or film-former in the resinous coating material. A vinyl resin for coating application may be said to be a material fabricated in manufacture as a particular composition, molecular weight, or particle size which makes it suitable for use via coating technology, A few examples of such resins and coatings utilizing Union Carbide Corporation products are as follows: * 1. Air dry vinyl coating systems for ship bottoms consist of a primer coat of vinyl butyral resin XYHL, zinc chromate, and phosphoric acid dissolved in alcohols and sprayed on the clean metal. This is followed by vinyl chloride copolymer resin, VAGH, and pigment in ketone-toluene medium. The top coat, carrying anti-fouling pigments, consists of VMCH and VYHH resins in ketone-toluene medium. 2. Beer and soft drink can linings consist of an epoxy, primer on tin plate topped with a sprayed coating of VYHD and VMCC resins, j The spraying is followed by baking; all handled automatically on a can manufacturing line. . 3. Container caps and closures utilize the unique properties of vinyl chloride resins to their fullest. A flat, metal substrate may be given a white pigmented VAGH resin coating on one side and it decorative QYNV resin organosol coating on the other side. The metal sheet is baked and the closures punched and formed without destruction of the coat ing. The formed closure is then coated inside with a QYKV plastisol and bak d again, yielding a gasket surface* Mr. Grover.C. Wrenn -3- February 14. 1975 4. Strippable coatings provide the basis for such useful items as surgical gloves. A hand-shaped form is dipped into a QYKV resin plastisol. Fhe form is then baked briefly to set the coating. On. cooling, the very thin vinyl glove is stripped off the form for use in surgical operations. The fact that these Solution and Dispersion Vinyl Resins contain essentially no residual monomer is very important. Solution vinyl resins are first stripped free of residual monomer while they exist in solution; this is followed by hot-water washing and vacuum stripping when the resin particle has been formed. The Dispersion Resins are made as a very small particle, 1 to 2 microns suspended in water as a latex. This fine particle size latex is spray dried. The spray-dried resin is then ground suspended in an air stream to break up any large or agglomerated small particles. Analysis of both Solution and Dispersion Vinyl Resins, at this point, shoWB they contain less than one part per million by weight of residual monomer. Even this small amount of monomer leaves the resin quickly so that within twenty-four hours they are nearly monomer free. Study of these resins, monitoring closed con tainers, warehouses, and customers' plants is reported in the attached memo randum entitled Solution and Dispersion Vinyl Resins Vinyl Chloride Monitoring Study. This study shows that the probability of employee exposure to work space air concentrations of vinyl chloride in excess of 0. 5 ppm is very low. The foregoing discussion show6 the difference between coating technology and usual vinyl resin fabricating operations 6uch as callendering, molding/or extrusion. It also points out that the vinyl resins produced by Union Carbide's Solution or Dispersion processes are essentially free of residual monomer as a result of specialized operations. These two differences from normal industrial polyvinyl chloride resin operations are the basis for Union Carbide Corporation's statement that its Solution and Dispersion Vinyl Resins for coating operations should be considered fabricated products as defined in the Occupational Safety and Hea.lth Administration Standard, The particular resins manufactured by Union Carbide Corporation for inclusion in this category are* J f \ Grover C. Wrena -4- r Resin Code Tvoe of Polmver VYNS VYHH VYHD VMCH ' VMCC VMCA VAGD . VAGH VROH VERR VYLF QYNV QYKV QYJV QYOH VLFV Copolymer Copolymer Copolymer Copolymer Copolymer Copolymer Copolymer Copolymer Copolymer Copolymer Copolymer Homopolymer Homopolymer Homopolymer Homopolymer Homopolymer February 14 Inherent Viscosity 0.7 0.5 0.4 0.5 0.3 0.3 0.4 0.5 0..3 0.3 0.3 1.25 1,20 0.9 1.25 1.00 i * Union Carbide resins for the coating market include but are not necessarily limited to the above resins. In this highly specialized area, n w products and new applications are developed frequently. J RNWJr/ra Very truly yours, R, N. Wheeler, Jr. 01 UNION CARBIDE CORPORATION 870 PARK AVENUE, NEW YORK, N,Y, 10017 CERTIFIED MAIL NO. 309779 RETURN RECEIPT REQUESTED June 17, 1975 Mr. John H. Stender (4 Copies) Assistant Secretary of Labor Occupational Safety and Health Administration United States Department of Labor 14th Street and Constitution Avenue Washington, D.C. 20004 Re; Petition for Modification and Amendment of the Occupational Safety and Health Standards for Exposure to Vinyl Chloride Dear Mr. Stender; Union Carbide Corporation, 270 Park Avenue, New York, New York 10017, hereby petitions the Occupational Safety and Health Administration, United States Department of Labor for modification and amendment of the standard for exposure to vinyl chloride (29 CFR Sec. 1910.93 (q)) published October 4, 1974 and in effect since April 1, 1975 This standard was admittedly a pioneering effort in establishing employee exposure levels for a suspected carcinogen manufactured and used world-wide in large quantities. As with all such efforts, time and experience have pointed out areas where the standard should be amended to enhance worker safety; to focus the regulation more specifically on problem areas; and to eliminate unnecessary and costly restrictions on industry which hamper its ability to provide work for labor. Additional information Is now available on the impact of the standard, and, through discussions between 0SHA personnel, industry, and labor, there is a better understanding of the problems involved in protecting the worker while not unduly restricting the industry In the performance of its basic function. ; Union Carbide Corporation, therefore, submits this petition; asks that it be consolidated with others already submitted, such as that by Dow Chemical Corporation on May 12, 1975j or which may be later submitted; and urges that the Secretary propose an amend atory rule on the standard for exposure to vinyl chloride; for ;he adoption of the amendments to the standard herein considered, 'he proposed amendments we suggest are here limited in scope to pecific areas of the standard. There is no desire on the part of nion Carbide to argue the question of the need for the standard. Union Carbide Corporation accordingly proposes the following endments to Part 1910, Bee. 1910.93 (q) Vinyl Chloride: '' \ ' Mr. John H. Stender -2 June 17, 1975 states; X. 1910.93 (q) (a) (2), Scope and Application, currently "(2) This section applies to the manufacture, reaction, packaging, repackaging, storage, handling, or use of vinyl chloride or polyvinyl chloride, but does not apply to the handling or use of fabricated products made of polyvinyl chloride." This should be amended as follows: (2) This section applies to the manufacture, reaction, packaging, repackaging, storage, handling, or use of vinyl chloride or polyvinyl chloride but does not apply to the reaction, packaging, repack aging, storage, handling, or use of fabricated products, or of polyvinyl chloride containing less than one part per million by weight of vinyl chloride monomer. Union Carbide Corporation has conducted extensive monitoring studies of the storage, handling, and use of resins containing less than one part per million by weight of unconverted vinyl chloride. Based on these studies, we conclude that when these resins are used and fabricated even by heat and pressure under minimal ventilation conditions, vinyl chloride monomer standard's "action level" of 0.5 parts per million vinyl chloride monomer concentration in the work space, air is not exceeded. These studies are set forth in full detail in the attached memorandum entitled Union Carbide Corporation Solution and Dispersion Vinyl Resins, Vinyl Chloride Monitoring Study. II, 1910.93 (q) (a) (3)> Scope and Application, currently states: "(3) This section applies to the transportation of vinyl chloride or polyvinyl chloride except to the extent that the Department of Transportation may regulate the hazards covered by this section." It should be amended as follows: (3) This section applies to the transportation of vinyl chloride or polyvinyl chloride except: ucc, 062861 Mr. John H. Stender -3- June 17. 1975 Polyvinyl chloride or materials made in whole or in part of polyvinyl chloride containing less than one part per million hy weight of vinyl chloride monomer. The Department of Transportation regulations may not be abrogated or made less stringent by this section. Union Carbide Corporation's data, supporting the amendment first proposed also amply supports this amendment. III. 1910.93 (9) (h) (5)* Definitions, currently states: "(5) 'Emergency' means any occurrence such as, but not limited to, equipment failure or operation of a relief device which is likely to, or does, result in massive release of vinyl chloride." This should be amended as follows: I (5) "Emergency" means any occurrence s,uch as, but not limited to, equipment failure or operation of a relief device which is likely to, or does, result In firej explosion; exposure of employees to skin con tact with liquid vinyl chloride; or require the use of self-contained breathing apparatus as set forth in section (g) (4) below. In OSHA Program Directive #200-35* under 3. Explanations (29 CFR 1910.93 (q)) Item 4 (a),' a massive release is defined to apply where there is a vinyl chloride concentration "greater than 100 parts per million". This statement of concentration corresponds to 1 cubic foot of vinyl chloride gas in 10,000 cubic feet of air or 0.16 pounds of vinyl chloride. Such a release can hardly be termed massive or even immediately hazardous to life, and certainly not warranting emergency action. Massive does not mean relatively insignificant or momentary. There is a need for a more explicit definition in the standard of what constitutes an emergency. The current definition 'destroys the meaning and efficacy of true emer gency planning and reporting. Indeed, the language of the standard itself contains no such requirement; yet an amendment thereto is clearly necessary to reverse an interpretation by OSHA which cannot be described as authorized. 0 Mr. John H. Stender -4- June 17, 1975 IV. 1910.93 (q) (b) (6), Definitions. currently states: "(6) 'Fabricated product' means a product made wholly or partly from polyvinyl chloride and which does not require further processing at temperatures and for times sufficient to cause mass melting of the polyvinyl chloride, resulting in the release of vinyl chloride.'* This should be amended as follows: (6) "Fabricated product" means a product consisting wholly or partly of polyvinyl chloride and which does not require further processing at temperatures and for times sufficient to cause the release of vinyl chloride monomer into the work-space air in excess of the action level. We would, moreover, be receptive to any amendment that substituted "exposure" for "action" level. We see no reason to regulate industry in areas that have already been stated to be appropriate exposure levels. When the present standard was promulgated, OSHA was not wholly knowledgeable in many aspects of the polyvinyl chloride indus try and the industry was wholly unsure as to how to meet the scope of the standard. The result was that many of its provisions address themselves to the suspension vinyl resin process and the subsequent fabrication of these resins solely by calendering, molding, and extrusion techniques. This was logical enough since suspension resin and its fabrication make up over three-quarters of the Industry. There are, however, other resin processes which do not supplement the suspension resin industry. They exist because they supply markets or permit fabricating techniques that are not available for the suspension resins; and include solution coating; latex coating; organosol coating; plastisol casting and coating; and others similar in nature. OSHA. has sought, in its Program Directive 200-35, diligently to adapt the Standard to these less-understood applications. The objective has been to maintain the level of worker safety required by the Standard while easing some of its many burdensome require ments. The result has been only partially effective, however, and confusion in the industry is rampant. The primary difficulty lies in uncertainty as to what is "mass melting", as applied to the definition of "fabricated product". UCC 062863 Mr. John H. Stencler **5- June 17. 1975 The term "mass belting" is unfortunate, in that thermoplastic materials including polyvinyl chloride resins do not melt when heated. They merely become progressively softer and are thus more easily formed by pressure. They do not change as to physical integrity or form of input material merely on application of heat. Theoretically, it is true, any plastic could be heated to a temper- ' ature v;here it would flow with no pressure. Moreover, the thermoplastic will likely decompose or be destroyed long before this "melt" temperature is reached. In the case of polyvinyl chloride, it decomposes more readily than polystyrene or other such materials. The objective of the definition for a "fabricated product" is to set a limit on the scope of the standard. The fact is that the above-described situation makes it unrealistic to do so as outlined. The standard currently sets an "action level" exposure of 0.5 parts per millionj thus, the simplistic approach would be to define a "fabricated product" in terms of residual vinyl chloride monomer content of the product and the potential release of vinyl chloride monomer in terms of the "action level," V. 1910.93 (q) (d) (4), Monitoring, currently provides: "(4) The method of monitoring and measurement shall have an accuracy (with a confidence level of 95 percent) of not less than plus or minus 50 percent from O.25 through 0.5 ppm, plus or minus 35 percent from over 0,5 ppm through 1.0 ppm, and plus or minus 25 percent over 1.0 ppm. (Methods meeting these accuracy requirements are available in the' NIOSH Manual of Analytical Methods).11 This should be amended is follows: (4) The method of monitoring and measurement shall have an accuracy and a precision rating equivalent to the method available in the NIOSH Manual of Analytical Methods. The specification of the method of analysis in the standard is confusing, does not conform to the generally-accepted practice for specification of analytical method accuracy and precision, and implies (incorrectly) that accuracy of the NIOSH method is known. The specification is confusing in that it states that the method of monitoring shall have certain accurace. This specification UCC Mr, John H. Stender , 5* June 17, 1975 of the method makes no reference whatever to the number of samples required for each monitoring or to the ultimate accuracy of the monitoring measurement. Despite this clear omission in the standard, OSHA Program Directive #200-35 on Page 7, Item (12) (a) adds to its requirements via a putative interpretation thereof as follows: "(a) The '95 percent confidence level' means that the employer is required to take a sufficient number of measurements so that the results obtained are statistically valid." If this statement is the official interpretation, then the employer wholly contrary to the standard's requirements, would have to take multiple samples per monitoring determination. The total number would depend on how close the monitoring results v/ere to the exposure limits. I.E., to be 95 percent "confident" that his vinyl chloride monomer exposire is not above the permissible one part per million limit, an infinite number of samples is required when the actual level is one part per million. From C3SHA's point of view, this poses an impossible enforcement problem. ACSHQ will have to have quite a few sample results to put it mildly before he can recommend a citation for exceeding the permissible exposure limit This same requirement for multiple samples is implied in Program Directive #200-35> Page 4, Item 6: "Assuming an error of + 25# in the sampling procedure and analytical method for a six-hour sampling * period, the concentration should be 1.66 ppm" (presum ably for a citation). Methods of analysis are conventionally defined In terms of accuracy and precision indices, both of which affect the result. To clearly separate the factor of accuracy from the factor of pre cision (as is done in the Program Directive) enough determinations of a single situation must be made to secure a significant mean value which, in turn, may be directly related to method accuracy, as the Program Directive does. The American Society for Testing Materials, as well as NIOSH, however, specify analytical methods in terms of accuracy and precision indices. A representative calculation of these terms could be as follows: / Mr. John H. Stender -7- June 17. 1975 The results of ten determinations on a standard sample containing 0,45 parts per million vinyl chloride monomer yield a mean value of 0.483 parts per million and a standard deviation of + 0,046 parts per million. (0.483-0.45) (100) * 7.3# Accuracy percent Systematic error * (100) 9.5# These terms are widely used as criteria for evaluating and specifying methods of analysis. To specify accuracy only implies a sufficient number of results so that precision is not a significant factor, which ignores the generally accepted definition of measurement methods, as used by NIOSH. The method of analysis from the NIOSH Manual of Analytical Methods for vinyl chloride, issued as part of Program Directive #20035',"is "defined by NIOSH as being operational but the accuracy and precision are unknown. Thus, unless NIOSH has yet unpublished studies of accuracy and precision on this method, there is no way of knowing whether it meets the cirterion of accuracy cited in the standard. Since the NIOSH method Is obviously the reference method for compli ance, there is no alternative but to modify the standard we have, as proposed. Furthermore, as regards Union Carbide Corporation strongly recommends that the NIOSH analytical method be modified to provide for calibration of the sample pump before and after any monitoring, not merely once every 2 to 3 months. For a critical analysis, such as monitoring, the assumption that a sample pump will maintain its calibration ovpr an extended period is not valid. VI. 1910.93 (9) (<0 (1) under Permissible exposure limit statt "(c) (l) No employee may be exposed to vinyl chloride at concentrations greater than 1 ppm averaged over any 8-hour period." This should be amended as follows: (1) No employee may be exposed to vinyl chloride at concentrations greater than 1 part per million, averaged over any S-hour period as determined by a monitoring frequency at the minimum provided In the /' Mr. John H. Stender -8- June 17, 1975 standard. When an employee's work space Is monitored hourly by automatic analyzers, the permissible exposure limit is two parts per million averaged over the eight hour period. The proposed amendment, to the layman, appears to be a plan 100$ increase in the permissible exposure limit and a lowering of level of safety provided by the standard. This is not true. The proposal utilizes available technology to achieve a greater degree of control over the employees' exposure to vinyl chloride, and thereby actually improves the level of safety provided the employee. Control of a worker's environment is not achieved or demonstrated in terms of a single eight hour sample taken once a month or once a quarter. The quality of control is dependent upon the following factors: 1. The number of samples taken 2. The accuracy and precision of the method of analysis. 3. The time that elapses between sampling and the corrective action This proposal involves improvement of Items 1 and 3. It replaces a requirement of one sampling per month with 720 individual samples and determinations per month. Statistically, this means that the possibility of bias or error is reduced tiemendously, as the following table demonstrates: / Number of Samples Bias or Standard Error of the System 1 2 10 100 1,000 00 1.414 1.054 1.005 1.0000 For example, in a work environment where the mean vinyl chloride monomer concentration is 0.5 parts per million and the precision of the determination of this concentration is 1.2 parts per million (the precision of the test method in this case was 0.07 I Mr. John H. Stender -9- June 17, 1975 parts per million), one-half the test values will be less than the action level of 0,5 end 65.5$ of the test values will be below 1.0. If a single monitoring test is done during the month, the odds are one-to-one that It will be below the action level limit and 65.5 to 34.5 that it will be within the permissible exposure limit. In actuality, the worker is exposed to concen trations over the permissible exposure limit 34.5$ of the time. This is actual data taken from an automatic chromatograph sample point. Personal samples taken on employees in this same area, at the same time as required by the standard, showed no exposure over the permissible limit. Testimony submitted by Union Carbide Corporation at the 1974 public hearings on the vinyl chloride standard substantiated further the recommendation we make herein. Multiple manual sampleB showed a plant to have an average vinyl chloride monomer concen tration of 10.24 parts per million with 95$ of the values under 46 parts per million. The automatic chromatograph in the same plant, though not at the same time, showed an average vinyl chloride monomer concentration of 16.3 parts per million with 95$ of the values less than 69 parts per million. It is clear that the chromatograph sampling more nearly represents the true situation. As to the time elasping between .'-.impling determination and corrective action, the difference in d ;ree of control is even more striking. If a manufacturer is large nough to maintain a full-time industrial hygiene laboratory, tr. samples, as required by the standard, are taken one day and thr: 1 esults are available the next day; thus, at least twenty-fours ...;st elapse before any Indicated corrective action can be initiated. For*the small manu facturer who cannot economically support his own Industrial hygiene laboratory, the sample taken one day Is mailed to a contract laboratory The result is known and corrective action is taken only after five to seven days, as a usual matter. An automatic chromatograph on the other hand delivers its results in less than five minutes; thus, corrective or control action can be initiated almo'st immedlat ly. Thus, in terms of absolute worker safety, the proposal to raise the permissible exposure limit to two parts per million averaged over an eight hour period, when an automatic analyser is used full time. Is fully Justified. This proposal recognizes clearly the limitations of current OSHA prescribed methods, of analysis, and states that the exposure level achieved through \ Mi*. John H. Stender -10- June 17, 1975 automatic chromatograph monitoring at 2 parts per million will be no greater --and indeed, probably will be less-- than the exposur levels ascertained through currently permissible methods. Much more is known about the worker's exposure, the possibility of error is reduced, and corrective action can be initiated almost immediately. The automatic analyser, generally, is being used throughout the vinyl chloride monomer and polyvinyl chloride industry by knowledgeable, concerned manufacturers. 03HA should recognize the contribution to safety and that this equipment pro vides incentive for its use in worker safety. VII, 1910.93 (q) (j), Training, states: . "(d) Each employee engaged in vinyl chloride or polyvinyl chloride operations shall be provided train ing in a program relating to the hazards of vinyl chloride and precautions for its safe use," This should be amended as follows: (O') Training. Each employee engaged in vinyl chloride or polyvinyl chloride operations, where exposures exceed the "action level", shall be provided training in a program relating to the hazards of vinyl chloride and precautions for its safe use. The training program required by the Standard is applicabl to the manufacture of vinyl chloride monomer and to the manufacture of polyvinyl chloride resins. In these areas it is useful and appro priate. The standard, however, goes on to apply the same costly, time-consuming training requirement to areas where it is not necessary ' and where they add little or nothing to worker safety. While there are indications that OSHA has not intended to require that the full training program be given truck drivers, fabricating industry workers, and other employees vjhose exposure is less than the "action level", the industry should not be required to comply with the letter of the standard, on penalty of being subjected to variable enforcement action where no worker benefit will result; where no prohibited expo sure levels will occur; and no training to meet them will be anything but an. empty exercise. The proposed amendment provides for .clarification of tnls section. Oi 9 Mr. John H. Stender -11 June 17, 1975 VIII. 1910.93 (q) (1) (3) under Signs and labels states: "(3) Containers of polyvinyl chloride resin waste from reactors or other waste contaminated with vinyl chloride shall be legibly labeled: Contaminated with VINYL CHLORIDE CANCER-SUSPECT AGENT" This should be amended as follows: (3) Containers of polyvinyl chloride resin waste, contaminated with vinyl chloride monomer so that the air in the immediate area shows vinyl chloride monomer concentrations in excess of the action level, shall be legibly labeled: Contaminated with VINYL CHLORIDE CANCER-SUSPECT AGENT The purpose of the label is to protect workers from excessive exposure to vinyl chloride monomer; thus, the requirement for label ing should relate to that purpose. Broad requirements for unnecessary signs and labels on products that will not in any way subject employees to Impermissible exposures or hazards, are burdensome and reduce the impact of the label on the worker to those situations where its need is clearly demonstrated. IX. 1910.93 (q) (1) (4) under Signs and labels states "(4) Containers of polyvinyl chloride shall be legibly labeled: POLYVINYL CHLORIDE (or TRADE NAME) Contains VINYL CHLORIDE VINYL CHLORIDE IS A CANCER-SUSPECT AGENT" This should be amended as follows: 0 t Mr. John H, Stender -12- June 17* 19V?j (*0 Containers of polyvinyl chloride, contaminated with vinyl chloride so that the air in the immediate area shows vinyl chloride monomer concentrations in excess of the action level or so that the polyvinyl chloride resin by analysis contains more than one part per million vinyl chloride monomer by weight, shall be legibly labeled: POLYVINYL CHLORIDE (or TRADE NAME) Contains VINYL CHLORIDE VINYL CHLORIDE IS A CANCER-SUSPECT AGENT The purpose of signs and labels is to protect the worker from excessive exposure to vinyl chloride monomer. The requirement for such labels should thus be related to that purpose, as discussed previously. In the absence of an emission standard on vinyl chloride from the Environmental Protection Agency, it is not possible to propose amendments to the OSHA standard or the Environmental Pro tection Agency standard to reduce overlapping requirements and to establish common bases of regulation where possible. Union Carbide Corporation believes that, with the many governmental agencies concerned with various aspects of safety, each agency should \<ork toward a goal of common nomenclature, common methods, and common regulations where possible. As a result of this belief. Union Carbide Corporation may propose additional amendments to the OSHA standard when the need is apparent. Very truly yours. JWW:me Vinyl Chloride Resins Manager A John W. Whittlesey Senior Labor Law Counsel Union Carbide Corporation SOUTH CHARLESTON PLANT UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS P.O. BOX *004, SOUTH CHARLESTON, W. VA. 2530* July 21, 1975 Mr, Grover C, Wrenn Chief, Division of Health Standards Development Occupational Safety and Health Administration U. S. Department of Labor Room N3663 200 Constitution Avenue, N. W, Washington, D. C. 20004 Subjects Interpretation of Occupational Safety & Health Administration Vinyl Chloride Standard Dear Grover Thank you very much for arranging the meeting on July 16, 1975 with Messrs. Edward Klein, Gene Regad, and yourself to discuss the problems involved in amending the Vinyl Chloride Standard and to dis cuss ways to provide the vinyl chloride resin industry with relief from burdensome and unnecessary parts of the Standard. The discussion did much to create an understanding of the problems of both parties. In reviewing my letter to you, dated May 2, 1975, on Classifica tion of Union Carbide Corporation Vinyl Resins, I believe it still clearly states the problem and a possible solution of the low residual monomer vinyl resin. Summarizing the letter it states: 1. The health hazard protected against by the Occupational Safety and Health Administration Vinyl Chloride Standard is the inhalation of vinyl chloride monomer. The objective of reducing the inhalation of vinyl chloride monomer should be achieved with a minimum of industrial disruption while perniitting OSHA to concentrate its enforcement effort in the most hazardous areas.2 2. .Vinyl resins containing less than one part per million of vinyl chloride monomer are subjected to one or more additional processing steps; i. e., they are "fabricated" to contain extremely low residual monomer content. Mr. Grover C. Wrenn -2- July 21, 1975 3. Data has been presented showing that when resins containing less than one part per million of residual monomer are processed, including so-called "mass melting", the amount of vinyl chloride released to the work space does not even approach the action level limit of 0. 5 ppm set by the OSHA Standard. Based on the objective of the Vinyl Chloride Standard and the data presented, the logical approach to effectively utilize limited OSHA enforcement personnel, to provide for worker safety, and to provide relief for those resin manufacturers who are producing these low monomer resins at extra cost is to classify these resins as "fabricated" products, thus limiting the application of the Standard to areas where excessive hazard exists. Union Carbide Corporation, a producer of many specialty vinyl chloride resins, markets these products world-wide to many customers - large and small. Within the United States alone it has 1,483 individual customers for vinyl resins. Most of these customers are small manufacturing establishments that purchase less than truck-load quantities. These customers, in turn, produce semifinished goods such as lacquers, plastisols, and organosols which are shipped to the ultimate user. These customers, as well as transportation companies, are withdrawing from handling and use of vinyl resins. The nature of this business is such that a clear statement of damage is not possible, but we can cite many cases of individual withdrawal as well as internal directives to not use vinyl resins in new applications. The loss of many small customers, as well as the loss of new applications, is tantamount to a slow termination of the business. We would appreciate your expediting the response to our request for an interpretation of the status of our products and thus clarify our situation. Very truly yours, R. N. Wheeler, Jr. 062813 PLASTICS MONITORING THE CONCENTRATION OF VINYL CHLORIDE IN THE WORK PLACE OR AMBIENT AIR Attachment 5 V OUR APPRECIATIVE THANKS TO Century Systems Corporation ... Analytical Instrument Development, Inc.... Mine Safety Appliancei Company ... for granting us parmmion to reprint their publications in thit booklet. NOTE: Union Carbide Corporation doe* not andorM the equipment Harm or the method! of analyiit presented herein to the exclusion o< ell other vendors equipment or methods of analysis. Union Carbide Corporation does use these methods of analysis end the equipment items in its monitoring operefioni, end believtt Itt monitoring procedures represent good practice. Union Carbide Corporation assumes no responsibility for the monitoring results of others using the equipment or enelyticel methods listed in this booklet. IMPORTANT -- This information is offered solely for your consideration, investigation, end verificetion and is not to be construed n warranty or rapresentetion for which we assume legal responsibility. In using these materials, you must establish for yourself the most suitable formulations, production methods, and control tests to ensure the uniformity end quality of your product. UNION CARBIDE is a registered trade mark of Union Carbide Corporation, VSJL C> 1974 by Union Carbide Corporation. UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS 270 PARK AVENUE. NEW YORK. N.V. 10017 oWSfeSs V MONITORING THE CONCENTRATION OF VINYL CHLORIDE IN THE WORK PLACE OR AMBIENT AIR \ Monitoring the concentration of vinyl chloride in the work place air is currently required by the U.S. Department of Labor's Occupational Safety and Health Administration under the temporary standard for vinyl chloride, and will continue to be required under the permanent standard as promulgated in the Federal Register of October 4, 1974, and scheduled to become effective January 1, 1975. In addition, the Environmental Protection Administration will issue regulations requiring ambient air monitoring or setting specific limits on vinyl chloride emissions. The current and future OSHA regulations cover the vinyl chloride pro ducer, the resin manufacturer, and the resin pro cessor or fabricator who makes finished or semi finished products. OSHA regulations require monitoring of areas where employees may be exposed to vinyl chloride emissions or to polyvinyl chloride resins under a definite written program which includes the pos sibility of employee observers; the keeping of complete and accurate records for long periods of time, stating dates, levels, and type of equipment used; and with very high (95%) confidence levels for such monitoring procedures. . The method of analysis and the details of the program are at this time, within the above frame work, left up to the employer. Any monitoring system must take into considrration the following factors: Potential for exposure to vinyl chloride is obviously higher for an employer manufac turing, using, or handling vinyl chloride mono mer, This potential for exposure is relatively lower for a polyvinyl chloride resin user. Response time is important for the employer vorking with vinyl chloride monomer. If an vcr-limits emission occurs, he must take action nmediately to protect the employees. A resin ier is concerned only with the potential release ` the vinyl chloride monomer contained in the an as a raw material. He is far less likely to >t an emergency which would expose emyees to high concentrations of vinyl chloride nomer. sitivity to low concentrations of vinyl chlorthe monitoring system is required in all Such sensitivity is 0.25 ppm. in air under ermanent standard. Flexibility of the monitoring system is of considerable importance, particularly, in a small business. With relatively few resources, such a company must be prepared to cope with regula tions from EPA, as well as OSHA, on vinyl chloride as well as other materials. Specificity of the monitoring system to vinyl chloride, such as a manufacturer of suspension vinyl chloride homopolymer, i.e., PVC. Data from an organic vapor analyzer should be adequate. The vinyl chloride monomer pro ducer; the lacquer formulator; or any other manufacturer who works with other monomers or solvents needs to know the concentration of vinyl chloride and not the concentration of vinyl chloride plus naphtha or vinyl acetate. OSHA requirements also are a factor. The monitoring data should be acceptable to the compliance officer. The data should be com parable with the data from tests he performs. While not a part of the vinyl chloride standard, the employer should be able to monitor nui sance dusts as per OSHA requirement. Resin dust in the work space air may well be a factor in any OSHA inspection. Vinyl resin processors or users should consider their monitoring needs as they relate to the following categories: 1. When measurable amounts of vinyl chloride monomer exist or are likely to exist in the work space air. Polyvinyl chloride resins produced by the suspension or bulk polymerization process generally contain amounts of unconvened vinyl chloride monomer ranging from 0.01 to 0.2 per cent, depending on the particle size of the resin, the porosity of the particle, and the vendor's plant operation. This contained unconverted monomer weathers out of the resin slowly during storage, and is driven out by heat in the initial processing steps. Processors of this type of resin will likely And high concentrations of vinyl chloride monomer in storage areas, bins, bags, hopper cars or trucks, blenders, intensive mixers, "Banbury" mixers, extruders or calen ders. The results of monitoring are likely to indicate needs for improved ventilation, changes in work practices, or changes in processing equipment. These resin users must monitor rH 1 work space air vinyl chloride concentration, so that they can take appropriate action to protect their employees as well as meet the OSHA standard for monitoring. 2. When no measurable amounts of vinyl chloride monomer exist or are likely to exist in the work space air. Polyvinyl chloride resins produced by the dispersion or solution polymerization pro cess or vinyl resin compound that has already been hot processed generally contain 0 to 0.001 per cent free vinyl chloride monomer. Further hot processing, manufacture of organosols or plastisols, or the formulation of lacquers results in very little, if any, release of vinyl chloride monomer into the work space air. These resin users are concerned only with sufficient moni toring to meet OSHA requirements. They are not exempt from them even though the likeli hood of detecting vinyl chloride monomer in the work space air is remote. Resin users in this category might consider contracting out the monitoring work if commercial laboratory facilities are available, since needs are minimal. As with all simplifications, there is a large number of resin users who clearly fit neither category or who are not sure where they fit. These resin users or processors should query their resin or compound suppliers regarding the vinyl chloride content of the resin or resins being purchased. Since this content varies with the type of resin and the vendor, it is wise to make such inquiries thoroughly and carefully. Resin users or processors in Category No. 1 ould consider a basic industrial hygiene labora ry consisting of the following items: ^ chromatograph with a flame ionization detecor, such as Model 5J1 supplied by Analytical nstrument Development, Inc., Avondale, tnnsylvania 19311 for about $7,000 including cessory equipment. This instrument is sensitive to less than 0.1 m. vinyl chloride, and is generally useful for a `ety of other solvent monitoring operations. tral portable sampling pumps, such as the t Safety' Appliance "Monitaire" pump, e may be clipped to a worker's belt for nal sampling of vinyl chloride in air or dust . These pumps, including a battery charger, pproximately $280 each. ical balance sensitive to 0.01 milligram. ortment of sample tubes, syringes, and glassware for sample collection. The laboratory should be well ventilated with a hood for employee protection. Other facilities might include equipment for sample pump calibra tion and preparation of standard samples. This description is intended to portray only the broad outlines of such a laboratory. The actual outfitting of a laboratory is best left to a chemist or industrial hygienist. Analytical methods for determining vinyl chloride concentrations in air as ceiling values or time weighted averages as well as the concentration of vinyl chloride in resin are given in the Appendix. Vendor's descriptions of the specific equipmentitems are also included. Resin users or processors in Category No. 2 could use the same type laboratory facilities described for Category No. 1 users, or they could reduce the equipment cost by use of the following: A Century Systems Corporation Portable Or ganic Vapor Analyzer with Flame Ionization Detector, Model OVA-98. This analyzer has good sensitivity, good reproducibility, and is easy to operate. It costs approximately $3,000. The main disadvantage is that it is sensitive to all organic vapors, including vinyl chloride; thus, if other vapors are present, the reading translated to vinyl chloride concen tration will be higher than the actual concen tration. Century Systems Corporation is currently offering this instrument with chromatographic capability at a cost of approximately $3,500. The instrument with this option is specific for vinyl chloride or certain other solvents. This option, while relatively untested in the field, appears to be useful for the resin processor with limited laboratory facilities (see data sheet in Appendix.) One or more portable sample pumps with equipment for gravimetric sampling of air borne dusts, such as the Mine Safety Appliance Pump described previously. These cost approximately $200 each. Analytical balance sensitive to 0.01 milligram for dust monitoring weighings. These facilities would have to be supplemented with other laboratory equipment selected by the chemist or industrial hygienist. Methods of analysis and operating instructions for the equipment should be obtained from the vendor of the equipment purchased. The equip-vent and analytical instruments list- ed arc precision measuring devices; therefore, they need to be operated and maintained by skilled, knowledgeable technicians. Again, like any other precision measuring device, they should be cali brated and tested with standard samples either prepared in the laboratory or purchased from a commercial supplier of such samples. This booklet attempts to review the factors involved in vinyl chloride monitoring and their application to a resin processor. It also suggests equipment and methods of analysis for considera tion. Its principal purpose is to stimulate thoughts and plans with regard to the problem of monitor ing vinyl chloride monomer concentrations. | | J-K i  . APPENDIX 1. Department of Labor, Occupational Safety and Health Administration: Exposure to Vinyl Chloride, Federal Register, Volume 39, No. 194, pp. 35890-35898, Friday, October 4, 1974. 2. Vendors' Publications on Analytical Instru* ments: Century Systems Corporation, Portable Or ganic Vapor Analyzer, Model OVA-98. Analytical Instrument Development, Inc., Portable Flame Photometric Gas Chromato graph, Model 511. Mine Safety Appliances Company, Model S Monitaire Sampler. 3. Methods of Analysis for Determining Vinyl Chloride in Air and in Resin: Vinyl Chloride, Determination in Air by Gas Chromatography. Vinyl Chloride, Determination in Air by Adsorption on Activated Charcoal and Analysis by Gas Chromatography. Determination of Residual Vinyl Chloride Monomer in Vinyl Resins. Dust, Determination of Total and Respirable Airborne Dust by Membrane Filter Sampling and Gravimetric Analysis. FRIDAY, OCTODER 4, 1974 WASHINGTON, D.C. Volume 39 n Numbor 194 PART II DEPARTMENT OF LABOR Occupational Safety And Health Administration EXPOSURE TO VINYL CHLORIDE Occupational SaFcty and Health Standards UCC 7 062882 35890 RULES AND REGULATIONS . Title 29--labor ployees from a rare liver canctt (angio and abroad OSHA proposed to revise 'vNAPTER XVII--OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION, DE PARTMENT OF LABOR PART ielO--OCCUPATIONAL SAFETY AND HEALTH STANDARDS sarcoma) may have been occupationally related. As a result of this notification and after consultation with NlOSH. and a joint Inspection of the B. F. Goodrich plant by OSHA, NlOSH and the Ken tucky Department of Labor, a fact-find 1910 93q and published a comprehensive proposal (39 FR 16696) on May JO. 1974. to prefect employees from hazards of exposure to VC. The propasai called for limitation of employee exposure to VC to "no dctectrble level," as measured by a Standard for Exposure to Vinyl Chloride ing hearing was announced on Janu sampling and analytical method sensitive Pursuant to sections 6<b), 6<c>, and >ic> ol the- Occupational Safety and Health Act of 1S70 <84 Elat. 1593, 1598, 1599; 29 USC 655, 657) Secretary of Labor's Order No. 12-71 <36 PR 8754) and 29 CFR Part 1911. I 1910 93 of Part 1910 of Title 29, Code of Federal Regu lations ia hereby amended in the manner set foith below. In order to provide an Occupational Safety and Health stand ard dealing with the exposure of em ployees to vinyl chloride. 1. Background--<I) Vinyl chloride. Vinyl chloride tcMoroclhene), Chemical Abstracts Service Registry No. 75014, Is a synthetic organic chemical made from ethylene or acetylene and chlorine by any of several processes. It Is the parent compound of a series of thermoplastic resin polymers and copolymers which are widely used for containers, wrapping film, electrical insulation, pipe, conduit, and a variety of other industrial and consumer products. Vinyl chloride has been made commercially In this country since 1939. and present production is in excess of seven billion pounds per year. The iinyl chloride industry divides into three segments; monomer production, polymer production, and fabrication. Production of the monomer is a largescale continuous process, involving only a few firms. There are comparatively few employees in this segment of the indus try. because the processes lend them selves to automation. Vinyl chloride (VC) Is used pilmarily In the production of polyvinyl chloride tPVO.a resin which is produced through batch processing The conversion of the VC monomer lnlo a polymer or copolymer Is an incomplete process. ie,, not all of the monomer Is reacted. PVC is fabricated by a variety of tech niques. Including extrusion, Injection molding and calendering, to form a fin ished product that needs no further chemical handling. The vast majority ary 30, 1974 <30 FR 3874) and held on February 15,1974. Information obtained from this hear ing, particularly the preliminary reports of experiments conducted by Professor Cesaie Maltonl of the Institute dl On- cologia, Bologna, Italy, demonstrated that vinyl chloride Induced angiosarcoma in rats at levels as low as 250 ppm, and in other speries at higher levels. Experi ments performed at lower levels of ex posure were not completed at that time. Other testimony from medical witnesses and NlOSH. and the tesulls of autopsies, led to the conclusion that the Goodrich workers had angiosarcoma of tlse liver and that VC probably was the causal agent In the angiosarcomas observed. In post hearing comments, additional angiosarcoma deaths weie reported among workers who had been exposed to VC In plants operated by Union Carbide Corporation, Firestone Plastics Corpora tion and Goodyear Tire L Rubber Com pany. On the basis of all Information avail able at that time, and the fact that em ployees were being exposed at levels around the experimentally observed ef fect level of 250 ppm, an emergency temporary standard <TG) was promul gated on April 5. 1974 (39 PR 12341) pursuant to section 6<c> ol the Act, as 29CFR 1010 93q. This standard reduced the permissible exposure level from a celling of 500 ppm to a 50 ppm ceiling, and established other requirements, including, for example, monitoring and respiratory protection. It was expressly recognized that this stands)d limiting exposures to a 50 ppm celling was a tentative, interim standard, end that the whole Question of exposure to VC would be considered more fully In the light of additional infoimatlon, especially the results of experiments which were known to be underway at that time. to 1 ppm, with an accuracy of 1 ppm *50 percent. The proposal also called feir the establishment of regulated areas and limited acce.ss to such areas to au thorized persons. A requliement for monitoring of emp'oyee exposures was proposed, along with engineering and work practice controls to be Implemented when exposures over the detectable limit were measured. Respiratory protactlon would have been required while engineering and work practice controls were being Implemented or where exposures exceeded the per missible limit even after feasible en gineering controls were Instituted. In addition, the proposed standard Included requirements for medical sur veillance, protective clothing, emergency Procedures, training, specific protection during maintenance and decontamina tion operations, transportation loading and unloading operations and record keeping. (4) Hearing on the proposal. The pro posal. as published on May 10, 1974, ellow-ed 30 days for Interested parties to submit written comments and to request an informal rulemaking hearing In formal contacts with OSHA staff and early responses Indicated that the subJect was of great Interest and importance to many persons Because of the limited time available before expiration of the six month period provided in section 6(c)(3) of the Act for promulgation of A final standard. It was decided to hold a hearing as soon as possible. Accord ingly, on May 24.1974, a notice of a hear ing was published <39 FR 18303), setting a hearing date of June 25. 1974. The hearing wo* conducted from June 25 through June 28, and again from July a. through July II. before Administrative Law Judge Oordon J. Myatt. All partici pants were given the opportunity to pre sent testimony and to cross-examine other witnesses. Persons participating In of employees involved in the VC Industry On April IS. 1974. Information and data the hearing were given until August 23, are employed by fabrication firms. Such firms range in size from those with few employees and simple equipment to Urge were presented to representatives of OSHA, NlOSH, and the Environmental Protection Agency by the Industrial Bio- 1974, to file additional posthearing com ments. including various Items of infor mation which were requested during the plants Involving many employees and Test Laboratories. Northbrook, Illinois, examination of witnesses. considerable capital. concerning results of animal exposure (5> Economic and technical impact Vinyl chloride (VC>, a gaa at ambient temperature and pressure, U a chlori nated hydrocarbon, which heretofore has been regarded as having moderate liver toxicity. The initial standard, contained in Table-O-t of 1910 93. established a ceiling value o( 500 ptrU of VC per mil lion parts of air. (2) The emergency temporary ttand- studios with VC, These studies were sponsored by the Manufacturing Chem ists Association. Although only pre liminary In nature at that time, these results revealed that 1 out of 200 mice exposed to VC concentrations of 50 ppm lor 7 hours a day, five days a week, for approximately 7 months, had developed angiosarcoma of the liver. etude. During the hearing, OSHA deter mined that additional facts would be needed to determine the practicality of certain aspects of the proposed stand ard. Accordingly, OSHA contacted an in dependent consultant, Poster D. Snell Corporation, to conduct studies of the feasibility of compliance at various ex posure levels. Including those proposed ard. On January 22, 1974, the Occupa f3) The propoied permanent stand by 06HA and others advanced by in tional Eafety and Health Administra ard Based on the demonstrated evidence dustry spokesmen. Bnell was also com tion (OSHAI was Informed by the Na of VC's carcinogenicity in three animal missioned to collect Information regard tional Institute for Occupational Safety species (rata, mice and hamsters), and ing the economic costs of compliance. and Health INIOSH) that the B. T. the substantial probability that VC had This action was announced at the close Goodrich Chemical Company had re been the causal agent in the coses of liver of the hearing, and Judge Myatt further ported that deaths of several of Its tm- angiosarcoma found in workers both here announced that the record would be kept ItOEIAl KtGltTtl, VOL. 3f, NO. 144--ftIBAY, OCTOStl 4. 1474 IULES AND REGULATIONS 35891 pen for e period of time beyond August studies of Melton! and Bio-Test Lobora- may create a carcinogenic hazard, the 23. to aliow Interested persons to com- toiles Moreover. Malloni's investlf aliens amount ol exposure which U hazardous , menl In wTWng on the itudy. On August have demonstrated a dose-dependent re must be determined. The Burgeon Qen- 18,1H4. OSHA announced that the pre lationship for induction of tumors <1 e., eral'* Ad Hoc Committee referred to liminary study was available end that more tumors occur at higher exposure above concluded that safe exposure levels comments were to be submitted no later If\els). Including amrfo^reoma ol the for carcinogenic substances esnnot be than September fl. 1874 139 FR 30844). liver. In rats The Investigations of Ih- scientifically determined. Thlj position On September 13, 1974. OSHA Invited durti lal Blo-Tesl Laboratories have dem- Is supported by the testimony of NJOSH comments on both the preliminary and oirstrated a similar relationship for at the hearing, Its recommendation* for the fined study, which was to be received both rats and mice. These Investigators a standard of no detectable level, and by on or before September 25. 1874 <38 t tt have indured angiosarcoma of the liver the testimony of expert witnesses from 33009). In rate and mire at exposure concentra the National Cancer Institute. <6) Environmental Impact statements. tions ol 60 ppm. and in hamsters at high Several witnesses and persons who sub A notice of Intent to file an environmen er concentrations of exposure Additional mitted comments have taken a contrary tal -Impact statement assessing the im tumors Involving other oreana, Including view and have suggested that man is less pact of a proposed standard on occu the kidneys. lungs, and skin of exposed sensitive to biologic aberrations Induced pational exposuie to VC wa* published animals, were also observed In frequen by vinyl chloride exposure than experi In the FedexaL rtrciSTt* on April 24. cies much in excess of control animals. mental animals Proponent* of this posi 1874 433 >R 14532>. The notice Invited The Incidence of tumors in mice in the tion have argued that if humans were a* any person having Information or data Industrial Bio-Test Laboratories Investi sensitive 'as rodents, an "epidemic" of on the environmental Impact to submit gations Is particularly pertinent Ol 200 cancer resulting from VC exposures It to 03HA by May 17. 1874 On June 12. rruce 1100 malc6. 100 females) exposed to should have already been discovered 1974. a draft environmental Impact 50 ppm of vinyl cliloridc by Inhalation for among employees. They also argue that Statement was prepared and circulated eleven montlis. 100 died Sixty-four ani the employees In whom tumors have been to all Interested persons Ten copies were mals died without gross postmortem observed are those who have considerable forwarded to the Council of Environ pathologic examination being performed. employment experience as polymeriza mental Quality <CEQ>, which published a notice of Its filing and availability In Of the 36 remaining animals for which a gross postmortem pathologic examina tion reactor cleaners Because it Is gen erally agTted that reactor cleaning In the FscrsAL Recistex on June 25, 1974 (38 FR 22975). A 45 day period was al tion was performed. 13 <36 percent) were found with liver tumors <lncluding volved high exposures to vinyl chloride In years past, It is argued that the lower lowed for the submission of comments on angiosarcomas), 31 <58 percent) with levels currently found In the workplace the draft statement On September 5. 1874, the final environmental Impact statement was prepared and a copy of it lung tumors. 9 <25 percent) with skin tumors, and one with a kidney tumor. Accoiding to the 1870 report by the have not Induced cancer and are there fore safe. We reject this argument. The fact that approximately three- and all substantive comments were sent to appropriate governmental agencies, private organizations, and other inter ested persons CEQ published a notice of availability for the final statement on September 6, 1974 <38 FR 32350). The submission of comment was Invited un til September 26, 1874. The final state ment and all significant comments have been carefully considered In arriving at the final standard on occupational expo sure to VC. (7) The record. The record In this proceeding U one of the most exhaustive ever relied upon by OSHA. It consists of pre and post-hearing comments and testimony received at both factfinding and rulemaking hearings, the studies and Inspections conducted by OSHA person nel. the environmental Impact state ments. the economic and technical Impact studies, and alt other relevant Information In all, over BOO written com ments have been received, with more than 200 separate oral and written sub missions made with regard to the two hearings. The record Itself exceeds 4,000 pages. Employers, employees, labor unions, public health groups, Independ ent experts, physicians, research scien tists, and specialists in many fields have teen Invited to submit Information and have made their views, knowledge and experience available to OSHA. The en tire record encompassing these submis sions waa thoroughly reviewed and evaluated In reaching the determina tions aet forth below. II. Findings regarding carcinogenicity, Butgeon General's Ad-Hoc Committee on the Evaluation of Low Levels of En vironmental Chemical Carcinogens, the finding of cancer in two or more animal species may be extrapolated to indicate a carcinogenic hazard to humans Here, such a finding was made In three species that were exposed to VC by inhalation-- a route comparable to employee ex posure. In addition, there were at least 13 confirmed cases of angiosarcoma of the liver among employ ees exposed to VC, a particularly significant number In view of the extieme rarity of this cancer In the U 8 adult male population testi mony ol Dr. Marcus Key, Director of NIOSH, at the rulemaking hearlngi. The findings of angiosarcoma of the liver in both experimental animals and exposed employees is compelling evi dence that exposure of humans to vinyl chloride Induces this tumor. Industry spokesmen, at the hearing, conceded that VC is carcinogenic for human* te g. testimony of Dr. McBumey, Rulemaking hearing, 1041). Accordingly, It Is con cluded that VC must be regarded at a human carcinogen, and the probable causal agent of angiosarcoma of the liver, and that exposure of employees to VC must be controlled. Additional evidence of tumor Induction in a vanety of other organs, including lung, kidney, brain and skin, a* well as non-mallgnnnt alterations, such as fi brosis and connective tissue deteriora tion, indicates additional oncogenic and toxicologic pioperties of vinyl chloride, which must be considered in establlsliing control regulations. <6ee testimony and quarter* of those employees with the longest exposure to VC tgreater than 20 year* since Initial exposure) have not yet been located, make* it Impossible to determine the actual number of afiected employee* The cases of liver tumors ob served to date have an average latency period, since initial exposure, of approxi mately 20 years If It Is assumed that In duction of angiosarcoma is a dose-re lated phenomenon, and If employees en gaged In cleaning reacton did. in fact, receive larger doses of vinyl chloride. It would be expected that such tumor* would be observed earlier for this em ployee population For this reason, the significance of presumed lower doses cannot be accurately assessed until a longer period of time ha* passed, as a longer induction period would be expected. initiation of exposure to chemical carcinogen* and induction of cancer are not neresasrlly synchronous events. Be cause of the physiologic complexities In volved with carcinogenesis, Induction of tumors does not occur in all employee* with similar exposure histories. For ex ample, Dr. Bchneiderman of the Na tional Cancer Institute emphasized dur ing his testimony that only about a filth of longer-term heavy smokers develop lung cancer. Accordingly, the Industry contention that exposure level* have been dramatically reduced since the 1840'* Is not reliable evidence that cur rent levels of exposure are safe. Borne Industry spokesmen also sug gested that the apparent nonrandom exposure levels and feasibility--<li Car- results of studies by Bio-Test Labora distribution of observed cancer In em cinogeniclty of vinyl chloride. The car tories. Tnbcr-haw-Cooper, Maltonl. ployees may Indicate an exposure thres cinogenicity of vinyl chloride for three MOSH. and SelikofT.) hold for tumor Induction, based on varia animal species frat. mouse, hamster) has (2> Exposure lim if*. Upon finding that tions In the workplace design or prac been documented on the record by the exposure of employees to vinyl Chloride tice and resultant employee exposures KDtIAl IfOlflll, VOL 3*. NO- 1*4--MlDAT. OCTOItl 4. t*74 ucc 062834 5892 EUUS AND CEGULATtOKS (testimony rad questioning by Tenneeo eg. testimony of Bellioff, firestone, NCI, confident that Industry will continue to Llemical*, lot.). It be* also been em and MOSH.) do so. phasised thet in only U! I polymeriza In our view, the demonstration of can 14) Conclusion*. The conclusions be tion plants where employees hove been cer induction In humans at a pedicular low arc bcsM on a thorough review and exposed to VC for more than 20 yews level is net a prerequisite to a determina evT.Iuatioo of cli the evidence submitted. have any employee* developed angiosar tion that a substance represents a can Where dodrioni tan be baaed on record coma ot the liver. Thi* argument 1* very cer haznrd for humans at (hat level. It evidence, this has been done. Where, similar to that raised concerning vari would be Imprudent to assume man to however, factual ceitainties arc lacking ability of prst employee exposure. Al be leas sensitive to VC exposure than ex or whera the facts olone do not provide though geographic and workprsetice dif perimental snlmsls In the abwnce of an answer, policy Judgments have been ference* may ultimately be demonstrated conclusive evidence. It would also be un made. to be factor* In distribution of angiosar founded to assume that animals will not There is little dispute that VC It car coma, sufficient Information ts unavail develop tumors when exposed at concen cinogenic to man nd we ao conclude. able to exclude from consideration of trations of VC of less than 50 ppm. However, the precise level of exposure risk those employees la workplaces for EhnuJd a sufficiently large number of ex which poses a hazard and tht question which cases of tngloaarcoma have not perimental animals be exposed to VC at of whether a "safe" exposure level exists, been observed: concentrations of less than 50 ppm, cannot be definitively answered on the It baa also been suggested that the Bchneiderman said that It would be ex record. Kor Is it clear to what extent absence of cancer In a population of 335 pected that *ome would develop VC In exposures can be-feasibly reduced. We Dow Chemical Company poly merizatlon duced tumors. cannot wait until Indisputable answers employees monitored over a period ol 1 (3) Feasibility. There la virtually no to these questions are available, because years, indicates that exposure to vinyl dispute that most. If not all, fabricators lives of employees are at stake. There chloride at concentrations ot less than are currently capable of reaching ex fore. we have had to exercise our best 300 ppm Is safe (Bee study by Dr. Cook, posure levels of 1 ppm through engineer judgment on the basis of the beat avail- submitted at the hearing by Dow Chem ing controls. These employers employ able evidence. These Judgment* have re ical Company.) However, the group sur well over 95 percent of all employees ex quired a balancing process. In which the veyed did not Include all workers who posed to VC. Indeed, several fabricators overriding consideration ha$ been the had been exposed, and the missing em ployees Included many who had the longer term (over 20 years) exposures. Moreover, the statistically Insignificant are already operating at this level (see SPI testimony >. However, Industry spokesmen have universally claimed that It is infeasible for the VC and the PVC protection of employees, even those who may have regular exposure* to VC throughout their working live*. Based on the available evidence and In the of the sample population decreases Industdcs to remain below 1 ppm con view of the above considerations, includ the possibility that tumors would be sistently, using engineering control* In ing feasibility, we believe that employee observed. addition, the Pnell *tudy on technical exposures to VC must be reduced to a 1 Dow also presented preliminary data feasibility concluded th't a I ppm ceil ppm time-weighted average (TWA). We In testimony at tl<e hearing on the pos ing la not feasible for the VC and PVC also believe that PVC and VC establish sible metabolic pathways of VC. The Industrie* with pretent technology, but ments will, in time, be able to attain that hypothesis presented was that VC may that the VC Industry could currently at level threugh engineering controls, and exert its carcinogenic effect by a metab tain lower exposure level* than the PVC that fabricator* can do so In the Im olite, and that the metabolite Is pro lnduitry. Labor union spokesmen and the mediate future. duced only when VC ts metabolised by a Health Research Group. Inc., however/ In addition to the TWA requirement, secondary metabolic pathway operating have suggested that such a level Is at we have established 5 ppm celling only when enzyme* regulating the pri tainable. (averaged over a 15-mlnute period) In mary pathway are saturated, as would Since there I* no aetual evidence that order to prevent exposure of employees be tha result at higher exposures. The any of the VC or PVC manufacturers to unacceptable high excursions From preliminary data indicated the possi have already attained a I ppm level or In an operation standpoint, this celling bility of an additional pathway for fact instituted all available engineering level is realistic because minor excur metabolism of VC In rats exposed to con and work practice controls, any estimate sions up to the celling level are likely to centration* of VC In excess of 230 ppm. as to the lowest feasible level attainable occur on a regular basis. However, the occurrence of angio must necessarily involve subjective Judg HI. The final standard--f 1) Scope and sarcoma In both rats and mice at VC ment Like* lee. the projections of Indus application. Both the ETS and the pro exposure concentrations of 50 ppm In try, labor, and others concerning feasi posal would apply the standard to the dicates that if a metabolite of VC Is the bility are essentially conjectural. Indeed, entire VC Industry. Including manufac ultimate carcinogen, then It must be as Firestone has suggested. It ts not pos turers of VC and PVC and fabricator*, generated at lower exposure concentra sible to accurately predict the degree of but excluding employers handling or tions In these species. Although this re search may be helpful to the thorough understanding of the carcinogenicity of VC, It appears that It does not yet offer evidence which can assist In determina tion of safe exposure concentrations for employees, or even that such safe ex posures exist. A number of witnesses representing employers have stressed that there is no evidence of cancer, either in employees or experimental animals, at exposure concentrations ol VC less than SO ppm. tSee eg., testimony of Firestone. Ten ures Chemicals) The conclusion of these witnesses was that no decision can be Improvement to be obtained from en gineering changes until such changes are actually Implemented. We agree that the PVC and VC estab lishment* win not be able to attain a 1 ppm TWA level for all Job classifications In the near future. W'e do believe, how. ever, that they win, In time, be able to attain level* of 1 ppm TWA for most job classifications most of the time. It Is ap parent that reaching such levels may re quire some new technology and work practices. It may also be necessary to utilize technology presently used In other Industries In any event, the VC and PVC Industries have already made gTttt using fabricated products made from VC. There la no dispute that a standard U required for the monomer and polymer Industries. However, the Society of Plas tics Industry (SPI) and various fabdea lers (sec testimony of Goodyear, Gen eral Cable, etc.) recommended that fabricator* be excluded from the stand ard. or that a separate requirement be established for them because many of them were already at or bslow the pro posed celling level. The record evidence establishes that t least some employees in the fabricat ing industry are exposed In excess of the made concerning risk of exposure to VC strides In reducing exposure levels. (Sec permissible control limits (See HIOSH at concentrations te* than 50 ppm. testimony of Dow Chamical Co, TR #73), testimony, TR 106; Roblnlech TR M2). On the other hand, the testimony nf For example, B. F. Goodrich testified In these circumstances, we believe that ft most expert witnesses, Including some in dustry biomedical experts, stated that quantification of a safe exposure con centration ts not possible with the pres (TR 1130) that It has reduced average exposure levels In several PVC plants from 35--40 ppm early this year to 15-13 Is Imprudent to grant a blanket exemp tion for all fabricators. Therefore, the final standard Is applicable to the fabri ent state of scientific knowledge. (See ppm at the time of the hearing. We are cation Industry, u well as the monomer eiDiiAi etoiiigg, vol tf. no. 1*4--1CAV, ocrotfv I, W4 II I lA vs. 062885 HULES AND REGULATIONS 3589.1 and polymer Industrie* Employer* who. temperature as PVC. for further pro below the action level, no further moni In fact, are eubstantlally below the ex cessing. Indicate* that a potential for re toring Is required unless the employer posure Jlr.Jt will be subjected to only lease of the residue still exists. It ap has reason to suspect that any employee ' minimal burdens by virtue of the "action pears that the exemption of fabricated Is exposed tn excess of the aetlon level, sevel'' to be discussed below. products should be limited to Just those or unless changes have been made In Where employers in the fabricating items which will not undergo such mass production, process, control, type of resin, l-dustry have exposures approaching the heating Further, the opportunity to etc. permissible limit, they will appropriately demonstrate that exposures are below Where the exposure level, without re be subject to the elAndard Employers the action level, and thus, discontinue gard to respirators, excetds the permis handling or using fabricated products many duties of the standard, provides a sible levels, monitoring must be conduc made of PVC were not Included In the more positive control and an adequate ted at least monthly. Where exposures ETS or the proposal and are excluded relief, are less than the permissible levels, but from the final standard. This conclusion (2) Permissible expoture limit. The greater than the action level, monitoring Is based on the absence of adequate evi utanJard sets an exposure limit of 1 ppm must occur at least quarterly. dence of exposure to VC In these opera averaged over any 8 hour period, and a (5) Methods of compliance. The stand tions The final standard clarifies the ex ceiling of S ppm averaged over any per ard, like the proposal, requires that em emption by defining a fabricated prod iod not exceeding 15 minutes. ployers Immediately Institute feasible uct as a product made wholly or partly As more fully disrussed above, this engineering and work practice controls from PVC which does not require further limit is based on an evaluation of the best to reduce exposures to at or below the processing at temperatures, and for available evidence and on a Judgment permissible exposure limit. times, sufficient to cause mass melting of that the health and safety of employees Where feasible engineering and work the PVC. BPI and others (cf. TR 3441 must be protected to the fullest extent practice controls will reduce exposures requested that PVC resins with less than feasible. In view of the fact that release below the permissible levels, they must 0 1 percent residual monomer be ex of VC in the VC and PVC manufacturing be Instituted. Where such controls will empted from the regulation now, and processes are variable, the 1 ppm celling not reduce exposures below the permis that the exemption level be reduced to level provided In the proposal would sible level, they must nonetheless be im 0 01 percent In three years SPI suggested that the exemption of materials with less than 0 1 percent of 14 carcinogens from 29 CFR 1910 93p (30 FR 31561 was an appropriate precedent. The cases are not comparable, because no attempt had been made to set air concentration limits for the 14 carcinogens. The record did not Include Information that reliable moni toring and measuring techniques were available. Moreover, the exemption did not exempt airborne trace* of carcino gens. The administrative cutoff was pro vided to avoid regulation of materials about which there was no health haz ard Information, and which would have broadly extended the application of the regulation beyond the record Herein, no Information was presented to show aafe concentration results from the use of resins with specific levels Indeed, the proposal to change the level later, when Improved technology would permit such reduction, would seem to Indicate that 8P1 has doubts about the safety of 0.1 percent residue level Diamond Shamrock (Exhibit 142) testified that there la no require maintenance or an average level significantly more difficult to attain through feasible engineering controls. Therefore, the exposure limit prescribed In the proposal has been rejected. (3) Action level. The final standard, unlike the ETS and the proposal, pro vides for an "action level" of 0,5 ppm TWA, one-half of the permissible ex posure limit. The purpose of the action level Is to minimize the Impact of the standard on the employers who have attained exposure levels well below the permissible limit. Thus, where the re sults of monitoring under paragraphs (d)(1) or (d>(2) demonstrate that no employee Is exposed In excess of 0.5 ppm TWA, employers may. fn effect, be exempted from some provisions of the standard For example, fabricators who are below the action level are not re quired `o provide medical surveillance or to monitor again, unless the employer has reason to suspect that any employee is exposed In excess of the action level. In our Judgment, exposures below the action level do not present a sufficient plemented to reduce exposures to the lowest practicable level, and be supple mented by the use of respirators to pro vide the necessary protection. There upon, a continuing program of engineer in' and work practice controls must be Instituted to reduce exposures to the low est practicable level. When exposures are at or below the permissible exposure limits, the program may be discontinued. In addition, a plan for achieving con trol by engineering and work practice methods must be drawn up and be made available, upon request, to represent atives of OSHA and NIOSH. We recognize that many employers covered by the standard can not cur rently achieve compliance with the per missible exposure limit solely by the use of feasible engineering and work practice controls. The record also reflects broad generic distinction* between the compli ance capabilities of the VC and PVC Industries. Borne Industry spokesmen. Including SPI (TR. 356-362), recom mended that a schedule of different permissile exposure limits and compliance direct relation. They lndleatt that the hazard to warrant application of the en dates be established for the VC and PVC airborne concentration Is more related to the physical form of the resin and the ventilation provided Also, monitor ing data from industry (cf. Exhibits 131. tire standard to the many employers who are or will be below that level. (4) Monitoring. The final standard, like the proposal, requires that Individual segments of the Industry. This view assumes that the ability and the time required to feasibly reach In creasingly tower control levels Is similar 168. 1?0> and OSKA (Exhibit 151) Indi cate that levels in excess of 1 ppm may be found In fabrication operations. In view of these facts and of the opportunity employee exposure levels be determined. This may be accomplished by personal or area monitoring. Gome witnesses and persons who submitted comments did within each Industry, but differs mark edly between Industries While the record does suggest that such differences do exist between Industries, as noted above. for employers to discontinue many duties not understand the meaning of the term It is clear that Intra-industry differences upon a show ing of no exposures above the -95 percent confidence level" In the also exist. Thus, the ability and time re action level, it doe* not appear that any proposal. Essentially ft means that the quired by each employer to attain lower residue exemption Is either justified or employer is required to take a sufficient control levels may depend upon auch necessary at this time. This course also number of measurements so that the re factors a* the climate in which the plant agrees with a number of industry pro sults obtained are statistically valid. We Is located, the age of equipment, the size posals (cf. TR 660). have modified the proposal to establish of reactors, or the type of resin manu BPI (TR 34S). among others, asked accuracy range requirements for various factured or used. (Snell study. Firestone that compounded PVC pellets be ex measurement levels. These ranges are testimony, etc.) empted from the standard on the grounds narrow enough to ensure that a deter Monitoring data also tends to support that the pellets had too low a residue to mination of compliance can be made, and auch Intra-Industry variations. (See, cause harmful or measurable emissions. broad enough to allow the application C g Dow, Firestone, Tenneco.) While It appears that PVC pellets would of a variety of technologies As noted above, the standard requires have a lower residue level than virgin AH covered employers are required to all employers to institute feasible engi PVC. ihe fact that the pellets must be conduct Initial monitoring Where moni neering controls to the fullest extent and boated to a molten mass at the same toring and measuring results are at or to continue to Improve and apply tngl- ftDKAl Mount. VM. *, NO. IV4--MIDAT, OCTOItt 4, 1924 35S94 RULES AND REGULATIONS twexLua costrail until Tull compliance 1* achieved. We have net established any deadlines for full compliance through engineering control* because at are presently unable to determine when It will be feaeible for most establishments to reduce exposure levels to the permissible level. We also believe that the requirement thet each employer reduce airborne con centrations to the permissible level, or to the lowest level feasible as soon as practicable will provide for Inter-Indus try and Intra-Industry technological dif ferences which do exist, and will avoid the setting of separate industry stand ards on the hasls of tbe general situation and conditions In each Industry. (6) Regulated area*. Tbc proposed standard would have required that regu lated areas be established, that access be limited to authorized employees, and that dally rosters or summaries of those entering be kept for at least 20 years In objection to these requirements. It was asserted that such control of access was not necessary from a health standpoint. Secondly, It was claimed that these con trols would Interfere with operations by preventing access of needed employees or non-employees, such as contractors, truck drivers, customers and consultants. The purpose of establishing regulated areas In Che proposal was to limit the ifck of exposure to as few employees as possible. TTils concern b still paramount, and thus the limited access feature re mains. The final standard amends the proposal slightly to allow "authorized persons" to enter regulated areas. This change, ft Is felt, will allow operations to continue without undue Interference. The final standard has also Increased the length of time dally rosters must be maintained from 20 to 30 years. This change was based largely on epidemio logical considerations. (See NIOSH testi mony. tr. 119.) (7) Rerptratarg protection. The final standard, like the proposal, requires the use of respirators where employee expo sures exceed the permissible control level. Industry representatives made a number of objections to proposed requirements for respiratory protection. They stated that the "no detectable level" would ef fectively require continuous wearing of respirators In PVC and VC plants, and that this Is not feasible because respira tors are cumbersome, present a safety hazard, and employees would not use them. We would agree that respirators have many drawbacks; the proposal did not contemplate them as a final solution. The record shows that the PVC Industry par ticularly may need several yean before plant environmental levels can be re duced so that respirators are necessary only occasionally. However, we cannot agree that respiratory protection should ttot be required simply because It Is In convenient, may require additional per sonnel. toterferes with production, or may require extensive retraining of em ployees and restructuring of work prac tices. We have carefully considered all the objections, and have concluded that If the environmental level te not con trolled to the permissible exposure limit, then employees must be afforded respira tory protection. While exposures In excess of tbe per missible level do constitute a hazard, we believe that It Is necessary to mitigate some of ilia problems associated with Implementing a program of respiratory protection while employees are being Tilted and trained In respirator use. and while other adjustments which may be required are Implemented. Therefore, until January 1, 187C, where exposures are not In excess of a 25 ppm celling, each employer must provide each em ployee wiih an appropriate respirator. However, employees whose exposures do not exceed a 25 ppm celling, may decline to use the respirator. In which case the employer Is not obligated to require Its use. During this adjustment period, em ployees will be trained In the uses, pur poses and limitations of respirators, and the hazards of exposure to vinyl chloride. Moreover, each employee will be notified In writing If be has been exposed In ex cess of the permissible exposure limit. Where exposures exceed a 25 ppm cell ing, respiratory protection Is mandatory in light of our Judgment that much greater risks are associated with such exposures. The provisions In the final standard regarding the selection and use of respi ratory protective devices differ from those in the proposal. The descriptions of etmosphere-supplying respirators have been revised to indicate more clearly the types of device-. Intended, and the maxi mum permissible concentration level for each devlc.'. Moreover, the number of type* of atmocphere-supplyins devices has been Increased. At the bearing Mr. Edwin C. Hyatt, an 06HA consultant, made suggestions re garding the use of particular respiratory devices. We have concluded that his sug gestions are meritorious. Therefore, the provisions for selection of atmospheresupplying devices follow closely the rec ommendations contained in his testi mony of SPI and B. F. Goodrich) <TR with Hyatt's suggestions. (See e g. testi mony ot 6PI and B. F. Goodrich) iTR 85 (!) We had originally omitted air* purifying respirators because none had been approved by NIOSH for use against VC, principally because they lacked in dicators to signal the expli-atlon of the service life of the sorbent. Hystt and other witnesses discussed in detail the desirability of being able to use canisters or cartridge air-purifying respirators, provided a sorbent could be shown to effectively absorb vinyl chloride with an adequate service life. Recently, OSHA has received respiratory, data from labo ratories regarding the effectiveness of commercially available canisters and cartridges for vinyl chloride. These evalnations were conducted separately by NIOSH and by the B. F. Goodrich Com pany and tubmltted to OSHA In post hearing comments. The results Indicate that certain presently available cents- ten and cartridges effectively absorb vinyl chloride at relatively low concen trations. In discussions of these findings with N106H. It hss Indicated that It Is willing to consider on an expedited basts the approvrJ of atr-purlfylng respirators for use against VC. Consequently, we hsve Included three lypee of air-purify ing respirators iff the list of acceptable units, subject to the approval of such units by NIOGH. The maximum concen tration foe which each respirator may be used ie based upon our evaluation of the data submitted by NIOSH and Goodrich. Because sir-purifying respi rators do not indicate sorbent exhaustion or breakthrough of VC, and bees use VC has no Inherent warning properties at levels for which these devices are used, strict administrative controls will be re quired for their use. Such controls In clude a program to assure timely re placement of canisters or cartridges and an alarm system to alert employees when vinyl chloride concentrations exceed the concentrations allowed for the particu lar type of respirator In use. (8) Hazardous operations. This la a new section wJlhin the final standard. It encompasses essentially the proposal's requirements for maintenance and de contamination but has restated them In terms of performance language to allow greater flexibility for employers to deal with such operation*. The Intent of Uve new section is to protect employees en gaged In activities that present a risk of exposure to vinyl chloride in excess ot the permissible levels. An example would be the cleaning ot a filter where resin con taining high residual monomer la trapped. The proposal's requirement for fullbody. impervious clothing has been re placed by tbe direction to use Impervious garments suited to the particular situa tion and probable extent at expoeure. Thus, full-body clothing Is not always necessary, and is therefore not required where less protection Is adequate. Since vessel entry falls within the definition of a hazardous operation, the vessel entry section of the proposal ha* been deleted from the final standard. (8) Emergency situations. The defini tion of emergency has been recast In terms of an unexpected massive release. The main objection to tbe section on emergency situations in the proposal was that, as the term was defined, many ordinary leaks or operations resulting In a small release of vinyl chloride would be considered emergencies. This was not the Intent of the proposal. The final standard has been clarified to correct this ambiguity. It should be noted that the written operational plan required by the standard need not be developed for minor excursions above the permissible exposure limit, and that such excursions need not be reported. (10) Signs and labels. The thrust of the signs and labels section Is to apprise employees of the cancer and fire haz ards. No objections have been raised with respect to Informing employees of the fire hazard. However, a number of ob jections were raised at the hearing and In written submissions to the require ment that the word "cancer" appear on all signs and labels. The principal argu- KDtlM liOliTO. VOt- Jt, NO. 1*4--TKIOAV, OCIOStt 4, 1*74 IS UCC 062887 nnv ftCUULAllONS 35 >95 jncnt advanced against Us use was that indicated that the medical tests proposed posal is the requirement for maintenance the term "cancer" or "canccr-suspect are currently the only ones available of monitoring records and daily rosier agent" seares employees and that In which are useful for medical surveillance sheets of authorized persons for 30 years. stead, 'ha mac sage should contain In <TR 121. Exh 65, TO 869--691 k. Conse Instead of 20 years. Additionally, the em structions on how to deal with the sub quently, the specific blood tests proposed ployer 1* required to maintain medical stance <TR 347). We believe that a have been retained as a minimum re records for the duration of an employee'* diluted form of naming will not suffice. quirement to assist the examining physi employment plus 20 years, or 30 year*, V>'e appreciate the concern of employers cian in determining fitness of potential whichever Is longer. The original pro with the reaction of their employees But employees for assignment to workplaces posal called for only 20 year*. we consider It Imperative that a worker Involving VC exposure In addition, al This change has been Implemented be be fully fnformrd, and that he realize the ternative medical examinations may be cause the latency period for induction of possible risks involved In his occupation. used where the examining physician de angiosarcoma ranges up to 30 years from Coupled with the training requirement termines that they are at least as good Initial exposure. Therefore, aa a mini In the standard, wt believe thBt the,signs as those specified by the standard. mum, medical records must be main and labels required will adequately In The Tabershaw-Coopcr study and the tained for at least that long It should be form employees of the hazard In addi various animal experiments suggest that noted that spokesmen for both labor and tion, such signs will warn unauthoilzed VC may produce a wide spectrum of ma industry recommended that this change personnel to keep out of regulated areas. lignant and non-mnJignant disorder*. be made. Hit proper application of most protec Tile general scope of the required medical The reporting requirement* are not tive measures requires an amount of examination has, therefore, been broad significantly different from those In the training and Indoctrination of employees ened to Include kidneys, skin, connective original proposal. However, Instead of that cannot easily be conveyed on a sign tissue, spleen, and pulmonery system, as the requirement for reporting incidents or label Also, the variety of measures well as the liver. No additional specific which result in the release of VC into that could be prescribed would result In procedures or tests are required, but rec areas where employees may be exposed, an unwleldly or excessively detailed leg ommendations have been included in the the final standard clarifies our original end Consequently, the required message Appendix to assist the examining physi intent by stating that only emergencies on signs and labels will not Include In cian. Because of the nonspecific nature must be reported. AIvy the requirement formation on precautions, relevant of the required medical teste. It Is not for filing a detailed, written report symptoms, etc. The addition of suitable appropriate to prescribe timing, or type within IS days has been deleted. It ha* Information by the employer would be of follow-up tests, or to mandate with been concluded that submission, within permitted, providing It does not detract drawal from exposure based solely on re 24 hour*, of an initial report that in In any way from the required statement. sults of the tests. Instead, the employer cludes facta immediately available, would The requirement In the proposal for Is required to obtain a statement from ordinarily be sufficient However, if the labeling containers of vinyl chloride has the examining physician of the em OSHA Area Director requests further in teen amended by deleting the reference ployee's suitability for continued expo formation relevant to the emergency, the to the possible hazard of violent polym sure, when the examining physician has employer will be required to furnish such erization. Very little Information was developed on this hazard during the standard-setting procedure It does ap pear that this hacard Is essentially under control and that the fire and carcino genic hazards at present are the most significant. Since labeling or placarding that Is In compliance with the V S De partment of Transportation regulations <49 CPU Part 173. Subpart Hi already warns of the lire hazard, only a state ment concerning the carcinogenic haz ard need be added to the Department of Transportation labela. completed such teste as he considers ap propriate. The employer la required to withdraw an employee only when this statement Indicates that the employee may be at added nsk from continued VC exposure. As with monitoring, there appear* to be no basis for complete exemption of the fabrication Industry from the require ment for mtdical examination. The rec ord does show fabricating establishments with concentrations of VC monitored considerably above the action level. In these Instances, medical surveillance of Information. (14) Deletes portions of the proposal. The proposal contained provision* re quiring that shower facilities and change rooms be provided, and that storage or consumption of food be prohibited in regulated areas. We have deleted these provisions because it is our conclusion they are no longer necessary. Showering facilities are not required because pro tective clothing, where required by the final standard, should protect employees from skin absorption by direct contact with VC and because there Is no reliable <111 Medical tvrveiflance. The princi affected employees will provide baseline evidence that VC vapor Is absorbed pal questions that have been raised re data for future evaluation of their health, through the skin. In addition, since we garding medical surveillance are the even if both monitoring and medical sur anticipate that meet employees wilt not necessity and efficacy of requiring cer veillance are discontinued because Im be wearing protective clothing and that tain specific serum enzyme determina proved controls reduce concentrations employee* who wear protective clothing tions (8MA-12 series) and the applica below the action level. Where exposures will change auch clothing Infrequently, tion of medical examination require are below the action level, the medical we are not requiring that change rooms ments to the fabrication segments of the surveillance requirement* do not general be provided. Industry where employees are'exposed to ly apply. In addition, we feel that there la In lower levels of VC The objection has also <12) Training A separate provision for adequate evidence ahowlng that hazar been raised that the specification of tests employee training hat been added to the dous amounts of VC can be absorbed and procedures Interferes with the ap final standard rather than including it through Ingestion. Tor this reason, the plication of advances In medical knowl within the section on emergency situa requirement prohibiting the storage or edge. tions as in the proposal. The new para consumption of food in regulated areas A particular difficulty In considering graph provides for training of employees has been deleted. medical surveillance Is that the most concerning the carcinogenic hazard of The proposal also contained provisions commonly discussed lesion, angiosar VC, emergency procedures, the need for on malntentance and decontamination, coma -cf the liver, currently cannot be monitoring and an annual review of the transportation loading and unloading, diagnosed until the victim is terminal standard It also provides for training of and polymer handling operations. These and, usually, within months of death. employees concerning the purpose for, requirement* are not mentioned in the Precursor physiologic alterations, which proper use of, and limitations connected final standard because attention to these might be reversible, have not yet been with respiratory protection. items i* implicit In the requirement that directly associated with the lesion. Con (13) Accords end reports. The Provi each employer reach the permlssable ex sequently, there are no specific diagnos sions for recordkeeping contained In the posure limit or attain the lowest feasible tic testa which can be prescribed which final standard require the preparation level. will determine presence or absence of end maintenance of essentially the same <13) tffeettoe Sate. In order to eneure this tumor at an early stage of develop Information required by the proposal. that affected employers and employee* ment. However, most medical witnesses The major change from the original pro will be informed of the existence of these notu.1 tfoitfta. voi at, no. tee--etioar, octom 4. m is US 01 3&S96 RULES AND REGULATIONS * provision*- and that employer* affected f the operation or beecus* of an acci opportunity to observe the monitor erg given an opportunity to familiarize dent In the operation, which would result ing and measuring required by this themselves and their employee* with the In an employee exposure In excess of the paragraph. existence of the new retirements, the permissible exposure limit <e) Regulated area. (1) A regulated elective date of the amendment to (8) "DOHA Area Director" means the area shall be established where: 11910.f"q trill be January 1.1975. To pro* Director for the Occupational Safety 1) Tlnyl chloride or polyvinyl chloride vide continued protection for employees and Health Administration Area Office Is manufactured, reacted, repackaged, until that date, the provisions currently having Jurisdiction over tire geographic stored, handled or used: and cdnu.lnc-d In 119l0.93q are hereby area In which the employer's establish <il> Vinyl chloride concentrations are promuti^,ted. pursuant to section 6ib>, ment b located. In excess of the permissible exposure 6(c) uvl Etc) ol the Occupational Safety <9) "Polyvinyl chloride" means poly limit. and Health Act, as an occupational vinyl chloride homopolymer or copoly <2> Access to regulated areas shall be Oarc.fteotbyeran4d, health standard effective 1974. the amendment to mer before such Is converted to a fabri cated product. limited to authorized persons. A dally roster shall be mode of authorized per 11P10 93q set out below will supersede <10> "Vinyl ehloride" means vinyl sons who enter, these provisions as of January 1, 1975. chloride monomer, if) Methods of compliance. Employee Accordingly, upon consideration of the (c) Permissible exposure limit. <11 No exposures to vinyl chloride shall be con whole record of this preceding. Part 1910 employee may be exposed to vinyl chlo trolled to at or below the permissible ex cf Title 29, Code of Federal Regulations ride at concentrations greater than 1 ppm posure limit provided in paeggranh <c) Is amended, effective January 1, 1975, by averaged over any 8-hour period, and of this section by engineering, work prac revision of 1 1910 93q to read ae follows: <2> No employee may be exposed to tice. and personal protective controls as 1910.55* Vinyl chloride. vinyl chloride at concentrations greater follows; than 5 ppm averaged over any period not (1) Feasible engineering and work fa) Scope and application. (1) This exceeding 15 minute*. practice controls shall immediately be section Includes requirements for the <3) No employee may J>e exposed to used to reduce exposures to at or below control of employee exposure to vinyl vinyl chloride by direct contact with the permissible exposure limit. chloride (ehloroethene), Chemical Ab liquid vinyl chloride. (2) Wherever feasible engineering and stracts Service Registry No. 75015. <d) Monitoring. (I) A program of work practice controls which can be In <27 This section applies to the manu Initial monitoring and measurement stituted Immediately are not sufficient to facture, reaction, packaging, repackag shall be undertaken In each establish reduce exposures to at or below the per ing, storage, handling err us* of Vinyl ment to determine If there Is any em missible exposure limit, they shall none chloride or polyvinyl chloride, but does ployee exposed, without regard to the use theless be used to reduce exposures to not apply to the handling or us* of fabri of respirators. In excess of the action the lowest practicable level, and shall be cated products made of polyvinyl chlo level. supplemented by respiratory protection ride. ta> Where a determination conducted In accordance with paragraph <gt of thla <31 This section applies to the trans tinder paragraph <d)(l) of this section section. A program shall be established portation of vinyl chloride or polyvinyl shows any employee exposures, without and Implemented to reduce exposures to chloride except to the extent that the regard to the use of respirators, in ex at or below th* permissible exposure Department of Transportation may cess of th* action level, a program for de limit, or to the greatest extent feasible, regulate the hazards covered by this sec termining exposures for each such em solely by means of engineering and work tion. ployee shall be established. Such a pro practice controls, as soon as feasible. (b> Definitions. (11 "Action level" gram: <3) Written plans for such a program means a concentration of vinyl chloride <1) Shan be repeated at least monthly shall be developed and furnished upon of 0 5 ppm averaged over an (-hour work where any employee ta exposed, without request for examination and copying to day. regard to the use of respirators, In ex authorized representatives of the Assis <7> "Assistant Secretary" means the cess f the permissible exposure limit. tant Secretary and the Director. Such Assistant Secretary of Labor for Occupa (11) Shall be repeated cot leas than plans shall be updated at least every (lx tional Bofety and Health, US. Depart quarterly where any employee la exposed, months. ment of Labor, or his designee. without regard to the us* of respirators. (g) Respiratory protection. Where <31 "Authorized person" means any In excess of the action level. respiratory protection Is required under person aperificaUy authorised by the em fill) May be discontinued for any em this section: ployer whoa* duties require him to enter ploye* only when at least two consecu (1) The employer shall provide o a regulated area or any person entering tive monitoring determination*, made not respirator which meets the requirement* such an area as a designated representa leas than 5 working days apart, show ex of this paragraph and shall assure that tive of employee) for the purpose of ex posures for that employee at or below the employee uses such respirator, exrept ercising an opportunity to observe moni the action level. that until December 31, 1975, wearing of toring and measuring procedures. (3> Whenever there has been a pro respirators shall be at the discretion of <4) "Director" means the Director, duction, process or control change which each employee for exposures not In ex National Institute for Occupational may result In an Increase In the release cess of 35 ppm, measured over any 15- Safety and Health, D S. Department of of vinyl chloride, or the employer has minute period. Until December 31. 1975, Health. Education, and Welfare, or hia any other reason to suspect that any em eoch employee who chooses not to wear designee. ployee may be exposed In excess of the an appropriate respirator shall be in <51 "Emergency" means any occur action level, a determination of employee formed at least quarterly of the hazards rence such as, but not limited to. equip exposure under paragraph <d>(l) of this of vinyl chloride and the purpose, proper ment failure, or operation of a relief de aectlon ahall be performed. use, and limitations of respiratory vice which Is likely to, or does, result In <4) The method of monitoring and devices. massfve release of vinyl chloride. measurement shall have an accuracy <3> Respirators shall be selected from <gl "Fabricated product" means a fwlth a confidence level of 95 percent) of among those jointly approved by tha product made wholly or partly from not less than plus or minus 50 percent Mining Enforcement and Safety Admin polyvinyl chloride, and which does cot from 0 25 through 9 5 ppm, plus or minus istration, Department of the Interior, require farther processing at tempera 38 percent from over 0.8 ppm through and the National Institute for Occupa tures. and for times, sufficient to cause 1.0 ppm. and plus or minus 25 percent tional Safety and Health under the pro mass melting of the polyvinyl chloride over 1.0 ppm. (Methods meeting these resulting tn the release of vinyl chloride. accuracy requirements are available In (7> "Hazardous operation" means any the "NIOSR Manual of Analytical operation, procedure, or activity where a Methods"). release of either vinyl chloride liquid or (S) Employee* or their designated rep gas might be expected as a consequence resentatives shall be afforded reasonable vision* of 30 CFR Part II. (3> A respiratory protection program meeting the requirements of 119)0.134 ahall be established and maintained. <4) Selection of respirators for Vinyl ehloride shall be as follows: rtpctAt itoima. voi. it. no. tts_nipAt, ocioata a, me RULES AND REGULATIONS 35897 gfnteyXeric conerntrcttcm of Cvt) The purpose for. and a descrip cSlorido RtqvltrS tppermtti* tion of, the medical surveillance (() ffolsovn. or sbov* >,600 ppta.,, Op*n-rlrcuti, lf-conuiol bnutbloc apparatus. pr*#- program; f \ ^ Sure <JmnS tjp*. vlth pull fawplaoa. *vh> Emergency procedures; (tt) Bc4 1,600 ppm_._....... (A) Oombin&tlou typ* C supplied sir rt*P>niof, pre*. lun demand type, wish full or hall raceplsce, nd utllUrj **lf-etmutr.ed (r supply; or (B) Typ* C, supplied lr ruplrstor continuous fiow typu. wltn full or blf fsccplew. rod auxiliary Self-contained Mr supply, (Ul) Ifoiovw 100 ppm.(A) CombloMlon typo C supplied lr rsfplrstor dtoJind typo, with full rscsptscs, ml auxiliary elf-oonttned oil supply; or (B) Open-circuit slf-eontsIned brstMn| Apparatus with full faopicc*. In d*msnd mod*, or (O) Typo c supplied Mr rotplrotor, demand (ypo, with (rill) Specific Information tp aid the employee In recognition of conditions which may result la the release of vinyl chloride; and (Ixl A review of this standard at the employee's first training and Indoctrina tion program, end annually thereafter. (3) All materials relating to the pro gram shall be provided upon request to the Assistant Secretary and the Director. (k> tSedieal turveiilanat. A program full focoplcco. of medical surveillance shall be Insti (It) CotOTcrppm..........n (A) A p-oucrcd slr-purlTylng respirator with hood. tuted for each employee exposed, with helmet, full or balf fooeplcco, ond o contour out regard to the use of respirators, to which provide* o oervlco Ilf# of ot Itoot 4 vinyl chloride in excess of the action hour* for eoncanrMlons of vinyl chlciida up level. The program shall provide each to 36 ppm, or such employee with an opportunity for (8) Ou uii'l. front* or back-mounted tonlitrr which examinations and tests In accordance (r) Kotovsr 10ppm.............. provide* 0 MrTlor Ilf* of ot tract 4 hour* for eonorotratlona of tIdjI chlcrld* up to 36 ppm. (A) Combination typo C *upplied.air mpleator, do. maod typo, with hMf focrplror, ond auxiliary self-contained tlr rjppty. or (B) Typo C uppl|ed-alr rtipirotor, dtmoDd typo, with bolt facepiece, or (C) Arty chemical enrtrldg* respirator dlth on organic ropor cartridge which provide* * irrvlro llfo of ot lout I hour for concentration* of tlnyl chlond* up to 10 ppm. with this paragraph. All medical ex aminations and procedures shall be per- formed by or under the supervision of a licensed physician, and shall be provided without cost to the employee. (1) At the time of initial assignment, or upon institution of medical surveil lance; (1) A general physical examination shall be performed, with epeetfle atten tion to detecting enlargement of liver, (5) (l) Entry Into uniown concentra tions or concentrations gre-ster than St,000 ppm (lower explosive limit) may be made only for purposes of life rescue; And (11) Entry Into concentration* of less than 3C.OOO ppm, but greater than 3,600 ppm may be made only for purposes of life rescue, firefighting, or securing equipment ao as to prevent a greater hazard from release of vinyl chloride, () Wbert air purifying respirators arc used: (t) Air-purifying cannlster* or car tridges shall be replaced prior to the expiration of their service life or the end of the shift In which they are first Used, whichever occurs first, and (11) A continuous monitoring and alarm system shall be provided where concentration* of vinyl chloride could reasonably exceed the allowable concen trations for the devices In use. Such sys tem shall be used to alert employees when vinyl chloride concentrations exceed the allowable concentrations for the devices In use. (7) Apparatus prescribed for higher concentrations may be used for any lower Concentration. (h) Hazardous operefton*. (1) Em ployee* engaged In hazardous operations. Including entry of vessels to clean poly vinyl chloride residue from vessel walls, shad be provided and required to wear and us; (3) Protective garments shall be pro vided clean and dry for each use. (I) Emergency situations. A written operational plan for emergency situa tions shall be developed for each facility storing, handling, or otherwise using vinyl chloride as a liquid or compressed gas. Appropriate portions of the plan ahAll be Implemented In the event of an emergency. The plan shall specifically provide that: (1) Employees engaged In hazardous operations or correcting situations of ex isting hazardous releases shall be equipped as required In paragraph (h) of this section; (2) Other employees not so equipped shall evacuate the area and not return unto conditions are controlled by the methods required In paragraph (f> of this section and the emergency Is abated. (J) Training. Each employee engaged In vinyl chloride or polyvinyl chloride operations shall be provided training In a program relating to the hazards of vinyl chloride and precautions for Us safe use. (1) The program shall Include: (I) The nature of the health hazard from chronic exposure to vinyl chloride Including specifically the carcinogenic hazard; (II) The specific nature of operations which could result In exposure to vinyl chloride In excess of the permissible limit and necessary protective steps; spleen or kidneys, or dysfunction In these organs, and for abnormaltles in skin, connective tissues and the pulmonary system (See Appendix A). (11) A medical history shall be taken, including the following topics: (A) Alcohol Intake; (B) Past history of hepatltle: <C> Work history and past exposure to potential hepatotoxlc agents, includ ing drugs and chemicals; <D) Past history of blood transfu sion*; and <> Past history of hospitalizations. (1111 A serum specimen shall be ob tained and determinations made of: (A) Total bilirubin: (B) Alkaline phosphatase; <C> Serum glutamic oxalacetic trans aminase (SOOT); (D) Serum glutamic pyruvic transam inase (SGPT); and (El Gamma glustamyl tran*peptidase. (2) Examinations provided In accord ance with this paragraph shall be per formed at least: (l) Every 6 months for each employee who has been employed in vinyl chlo ride or polyvinyl chloride manufacturing for 10 years or longer; and (U> Annually for all other employees. (3> Each employee exposed to an emergency shall be afforded appropriate medical surveillance. (4) A statement of each employee's suitability for continued exposure to vinyl chloride Including use of protec (1) Respiratory protection In accord (U) The purpose for, proper use, and tive equipment and respirators, shall be ance with paragraphs (c) and (g) of limitations of respiratory protective obtained from the examining physician this section; and (tl> Protective garment* to prevent aUn contact with liquid vinyl chloride or with polyvinyl chloride residue from Vessel wills. The protective garments devices; (tv) The fire hazard and acute toxic ity of vinyl chloride, and the necessary protective steps; promptly after any examination. A copy of the physician's ststement shall be pro vided each employee. (5) If any employee's health would be ahalj be selected for the operation and (?) The purpose for and a description materially Impaired by continued ex lie possible exposure conditions. of the monitoring program; posure, such employee shall be with- RPttAl MOUTH, VOC >*, NO- 174--StlOAV, OCtOMI 4, W 062&0 is 35898 EUUS ANO REGULATIONS trm from postils OMtal with vinyl -hlnrlrfg. (6) Laboratory analyse* for all bio logical specimens Included In medical e.caminaon* shall be performed In labo rs loriee licensed under 43 CFR Part 14. <7) It thr examining physician deter mines that alternative medical examina tions to those required hy paragraph tkxl> of tld* section win pi-ovlde at least equal assurance of detecting med ical eandifleas pcrtinecl to the exposure to vinyl chloride, the employer may ac cept such cJtemstive examinations as meeting the require rncpts of paragraph <k)tl) of this section. If the employer obtains a statement from the examining physician setting forth the alternative examinations and the rationale for sub stitution. This statement shall be avail able uptxt request for examination and copying to autboriwd representatives of the Assistant Secretary and the Director, t!> Siexj <nd labels. il> Entrances to regulated areas shall be posted with leg ible signs bearing the legend: CiMcn-Swra Agint Aua Aciuotuatt Pp&ONTO, OnV ' (2) Areas containing hazardous oper ations er where an emergency currently exists shall be posted with legible signs bearing the legend: C*nnx-SuxmcT ActKt sit Txa Axes Piotoc- Trt-a Eqcypnanr Beqcaxp Atmtoeicxo Feuoxsu Omxt 13) Containers of polyvinyl chloride resin waste from reactor* or other waste contaminated with vinyl chloride ahull be legibly labeled: Contamlnilad wtUi Turn Chum ms Ciscn-Svincr Acntv (4) Container* of polyvinyl chloride ahall be legibly labeled: PocvvlNtl CHioimi (or Tsois Haul) Contains Torn. Cnioura Tin it Cfeuxsl a a CiHcaa-ficaetct Aiut ffi) Containers of vinyl chloride shall be legibly labeled either: Vu*tv C ic.ax me First welt ytiKMiaii Om Csan Panama Ciaca-StincT Aunt or (11) Ih accordance with 49 CTTt Part 173, Subpart H, wKh the additional legend*: CxracM-Susricr Acnre applied near the labcw or placard. <B> No statement ahall appear on or near any required sign, label or Instruc tion which contradicts or detracts from (il) The nrolxi ri amTiayaes In each the effect of, any required warning. regulated area during normal operations. Information or lustmcHaa. Including maintenance. (mi Record!. (1) AH records main <3) Emergencies, and the facts ob tained in accordance with this section tainable at that time, shall be reported ahall include the name arid social secu within 24 hours to the OSHA Area Di rity number of etch employes where rector. Upon request of the Area Direc relevant. tor, the employer shall submit additional (2) Records of required monitoring Information In writiig relevant to the and measuring, medical records, and au nature and extent of employee exposures thorized personnel rosters, shall be made and measures taken to prevent future and shell be available upon request for emergencies of similar nature. examination and copying to authorized <3) Within 10 working days following representatives of the Assistant Secre any monitoring and measuring which tary and the Director. discloses that any employee has been (1) Monitoring and measuring records exposed, without regard to the use of shall: respirators in excess of the permissible (A) State the date of such monitor ing and measuring and the concentra tions determined and identify the instru exposure limit, each such employee shall be notified In writing of the results of ments and methods used: the exposure measurement and the steps (B) Include any additional informa being taken to reduce the exposure to tion necessary to determine individual employee exposures where such expo sures are determined by mean* other than Individual monitoring of employee*; and within the permissible exposure limit. to) Effective dales. (1) UntU Janu ary 1, 1975, the provisions currently set forth In 11910.93q of this Part shall (C) Be maintained for not less than apply. 30 years. (2) Effective January 1,1975, the pro ill) Authorized personnel rosters shall visions set forth in I 1910 93q of this Part be maintained for not less than 30 years. (ill) Medical records shall be main shall apply. tained for the duration of the employ ment of each employee plus 20 years, Appendix A--EuppLzHzicraav Mutest. lailOIlUTIOM or 30 years, whichever is longer. Whan required testa undar paragraph (3) In the event that the employer (R)U) of this section (how abnormalities, ceases to do business and there is no the ttsu should ba repeated a> soon as prac-' successor to receive and retain his rec ords for the prescribed period, these rec livable, preferably within 3 to 4 weeks If tests rrmils abnormal, consideration should be given to withdrawel of the employee from ords shall be transmitted by registered eomact with vinyl chloride, while a more mail to the Director, and each employee, eomprebeoslve examination la made. individually notified in writing of this Additional testa which may be useful: transfer. A. Fur kktery dysfunction, urine eiamina- 14) Dnpfoyees or their designated representatives shall be provided access to examine and copy records of required monitoring and measuring. (5) Dormer employees shall be pro tint) for albumin, red blood cells, and eifoUatltt abnormal cells. B. Pulmonary system: Forced vital capac ity. Forced nplratory volume at I second, and ebrst roentgenogram (posterior-anterior. 14 a 17 Incbee). vided access to examine and copy re C. Additional senjm testa- Lactic arid de quired monitoring and measuring records hydrogenase. tactic arid dehydrogenase reflecting their own exposures. (6) Upon written request of any em ployee, a copy of the medical record of that employee shall be furnished to any physician designated by the employee. (a) Reports, il) Not later than 1 month after the establishment of a reg ulated area, the following Information Isoenzyme, protein determination, and protein electrophoresis. D For a more comprehensive examination on repeated abnormal serum testa Hepatitis B antigen, and liver scanning. (Sees < and I. *4 Stat lies. 1681 ( BBC 666. 661); Secretary Of Labor'* Order No. 13-71.36 FB 67*4) shAll be reported to the OSHA Area Di Signed at Washington, DC., Dili 1st rector. Any changes to such information day of October, 1974. shall be reported within IS daya. (1) The address and location of each establishment which has one or more John Stcndla, Assistant Secretary of Labor. regulated areas; and (PR Doc.74-33176 Filed 10-1-74.3:64 paa) KDHAl lECISTfl, VOL 19. NO. ltd--TtiDAT, OCT0IC1 4, 1974 It O&Sl in t: vv o ............................................. . N G'Gfff'Ciry Adds Chromatographic Capability to their Portable and Fixed Organic Vapor Analyzers CENTURY MODEL OVA-98 PORTABLE INSTRUMENT WITH CHROMATOGRAPH ADAPTION A STRIP CHART RECORDER ADDED AS SHOWN. Now for the first time a portable, continuous sampling Organic Vapor Analyzer which also has gas chromatographic capability is available in our OVA instrument series. And the most exciting fact of all is that this new analyzer, including the strip chart recorder, still maintains the lightweight portability and reliability features which are characteristic of all OVA's. This unique instrument permits not only the detection and quantitative analysis of potentially hazardous vapors but also an "on-the-spot" qualitative analysis within minutes, depending upon the components under analysis. Elaborate and timeconsuming laboratory analysis is now significantly reduced because a compact, unique, gas chromatograph system is built right into the instrument. After location of potentially hazardous vapors, using the stan dard quantitative sample survey and analysis methods describ ed in ihe brochure "Century Portable Organic Vapor Analyzer", simply depressing the Column Valve will "swiich" the chromaiographic system into operation. This diverts a portion of the vapor sample through the column for separation and subsequent readout on the strip chart recorder. At the same time, a charcoal titter is switched into the sampling system to reduce the hydrocarbon background during analysis. When the Column Valve is depressed, an immediate negative reference indication is printed on the strip chan recorder which establishes a "starting time baseline" for ihe chromatographic analysis Subsequently, each component of the sample exits Irom the column into the detector chamber after its respective retention time Each produces a peak on the logarithmic strip chart recorder and on the hand-held, logarithmically scaled meter. Examples of typical analysis recordings of the linear time versus logarithmically scaled vapor level are shown in this brochure. Column selection (or specific applications is facilitated by the availability of interchangeable columns, which can easily be changed by simply loosening two swagelok fittings. In addition lo standard columns, which are designed lot most standard in dustrial applications, special custom columns can be provided lo customer specifications or the customer can easily provide his own column. In summary, employers concerned with the safety of their employees can now rapidly determine the ppm composition of potentially hazardous gases within minutes after the "heart and extent of the problem" is determined. Give the OVA with column and recorder options a dose look. It's at least one state of the art level-ahead of any instrument available tor industrial hygiene or air quality control applications. 17 052892 Vinyl Chloride Note that time base la linear but hydrocarbon level la log scaled lor measurement of low level trace elements. TYPICAL OVA PRINTOUTS SHOWING CLEAR COMPONENT SEPARATION ucc It 062893 Portefelo rgjsiET:! /Lrst^Eysep I i ucc it 062S9A -i . (SEKTURV ForestsE \ regaFeis ^fEpor ^rasiEs/ser pc' s ifoui srscS E"fi rBVEror?rEriiont INTRODUCTION A completely portable Or ganic Vapor Analyzer (OVA) is now available to detect and measure hazardous gases found in almost all industries, including manufacturing, petro-chemical, and natural gas transmission and distri bution. The Century OVA is a highly sensitive instrument designed to measure trace quantities of organic mate rials in air. It incorporates a hydrogen flame ionization detection system which has similar analytical capabilities to those utilized in gas chroma tographs. The flame ioniza tion detector is an almost universal detector for organic compounds with the sensi tivity to analyze for them in the parts per million range (V/V) in air in the presence of moisture, nitrogen oxides, carbon monoxide and carbon dioxide. The instrument has broad application, since it has a continuous, chemically re sistant air sampling system and can be readily calibrated to measure almost all organic vapors. It has a single loga rithmically scaled readout from 1 ppm to 100,000 ppm or with lower maximum level, if desired. Designed for use as a portable survey instrument it can also be readily adapted to fixed remote monitoring or mobile installations. It is ideal for the determination of many organic air-pollu tants and in the monitoring of air in potentially con taminated areas. The unique feature of the instrument it its complete portability which enables an entire facility to be surveyed rapidly and thoroughly. When vapors are detected, the continuous sampling feature enables the origin of those vapors to be readily traced and corrective action initiated, tn most cases a qualitative analysis is not justified until the presence of potentially hazardous vapors is detected and the source of the vapors is determined. If, after locating the source, the vapors or mixture of va pors cannot be readily identified, a sample can be taken and a qualitative anal ysis performed on standard laboratory equipment. How ever, location of the vapor source will many times reveal the type of vapor and the concentration level can then be read directly, by simply changing the instrument cali bration to the predetermined setting for that particular vapor. The OVA thus enables comprehensive survey of an entire facility to be performed rapidly and economically in contrast to ineffective and costly spot sampling techniques. PRINCIPLE OF OPERATION The instrument includes detector chamber where the organic vapor being analyzed is introduced into e small hy drogen flame. Air sample is drawn into the instrument at a constant rate of nominally two (2) liters per minute through a chemically resis tant line and pump. The oxy gen in the air sample is used to support the small hydro gen flame. Flames characteristically have electrical conductivity due to the presence bf electrons and ions generated from the burning fuel. When even trace amounts of organic material enter the hydrogen flame, car bon-containing ions are formed and the electrical con ductivity increases signifi cantly. This change in con ductivity is measured and the output is directly related to the concentration of organic materials. The exception to this phenomenon is carbon monoxide and carbon diox ide which evidently, due to their structure, do not pro duce appreciable ions in the detector flame. Thus, other organic materials may be analyzed in the presence of CO and COa. An electric field in the cham ber drives the ions to a col lecting electrode which causes a current to flow into a pre amplifier that is proportional to the ion collection rate. The rate of ion generation is a function of the quantity and structure of the carbon com pound present in the sample. The ionization current is am plified in a logarithmic electro meter preamplifier, the out put of which varies as the logarithm of the input. This logarithmic feature enables measurement and readout of ionization rates over a range of up to five (5) decades (1 to 100,000) without range scaling. The output signal from the preamplifier is fed to the signal conditioning and con trol circuits for subsequent readout and alarm signalling. A fuel handling system in cluding storage tank, velvet, regulators and gauges b in corporated to maintain the small hydrogen flame jet in the chamber. The instrument response is read on a hand held meter assembly or can be read out utilizing the exter nal monitor signal. An audible detection alarm is provided which can be pre-set to any desired level and which has a freauencv modulated tone which varies as a function of the signal level. The standard instrument includes an audi ble flame out alarm, battery test indicator and internal electronic calibration. The internal electronic calibration provides reference signals which are used in conjunction with a panel mounted gas selector adjustment to readily change the instrument calibra tion from one gas to another. Since the response of the in strument is dependent upon the chemical nature of the material being analyzed, it is necessary to calibrate the de vice with a standard sample of that particular organic vapor. However, the approxi mate response of the instru ment to hydro-carbons or compounds containing halo gens, oxygen, or nitrogen can be estimated from the structure of the compounds nd utilization of empirical data. The internal electronic reference signals are provided so the operator can readily recheck the instrument re sponse from the point of ion collection to the readout meter. A low pTuurf gtug* il to monl- l \ ucce 062896 \ APPLICATIONS 0) Measurement of most toxic organic vapors present in industry for compliance with OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA1 requirement*. (2) Survey of gas distribution and transmission tines and equipment for compli ance with OFFICE OF PIPELINE SAFETY (OPS) requirement*. (3) Various measurement and monitoring applications in the air pollution field. (4) Leak detection in gas handling equipment. (51 Detecting explosive-level gas conditions in indoor and outdoor location*. (61 Measurement of methane in underground mine*. OTHER TYPICAL USES (1) Controlling and monitoring atmospheres in manufacturing and packaging operations. (2) Mudlogging, gas and mineral exploration. (3) Leak detection related to volatile fuel handling equipment. SPECIFICATIONS Sensitivity. 1 ppm (methane) Response time: Less than 2 seconds Readout: 250 logarithmic scaled meter, various scales in the range of 1-100,000 ppm. External monitor connector. Sample flow rate: Nominally 2 liters per minute. Fuel supply: 75 cubic centimeter tank of pure hydrogen at max. pressure of 2300 PSIG, tillable while in case. Primary electrical power: Rechargeable and replaceable battery pack, at 12 VDC. Service life: Hydrogen supply and battery power - 8 hour* operating time minimum. Size: Side Pack Assembly 8s/," wide x 11*4" long x 414" deep. Probe/Readout Assembly -- variable Weight Side Pack Assembly -- lest than 9 pound*. Probe/Readout Assembly -- less than 2 Pound*. Operator requirements: One man, one hand operation. Detection alarm: Frequency modulated audible alarm. Can be pre-set to desired level. Flame-out indication: Battery test Pickup fixtures: Probe: Umbilical cord: Filtering: Side pack case: Standard accessories: Frequency varies as a function of detection level. Audible alarm plus visual meter indication. Battery charge condition indicated on readout meter or battery recharger. Variety of types for various applications. Telescoping adjustment over 8 inches or probe can be completely removed from Readout Assembly. Five (5) feet long with connectors for electrical cable and sample hose. In-line disposable and permanent particle filters and optional activated charcoal filter. Molded high impact plastic case with carrying handle and shoulder strap. 1) Instrument carrying and storage case. 2) High pressure fuel filling hose assembly. 3) A C. Battery charger. UCC 062897 LITHO IN . MODEL 511 FLAME IONIZATION PORTABLE GAS CHROMATOGRAPH O COMPLETELY PORTABLE O RECHARGEABLE BATTERIES C SELF-CONTAINED, REFILLABLE GAS SUPPLY C ON-SITE ANALYSIS LOW POWER CONSUMPTION LOW WEIGHT -- 40 lbs. ISOTHERMAL OPERATION TO 175C ON-COLUMN INJECTION INTERCHANGEABLE FID-EC-TC DETECTORS USS GLASS OR METAL COLUMNS The Model 511 Portable Gas Chromatograph is a completely self-contained instrument. Con taining rechargeable Nickel-Cadmium batteries and a refillable gas supply this instrument may be carried fully operational to the sampling area and operated immediately upon arrival. The availability of three interchangeable detection systems allows the selection of the appro priate detector to perform virtually any isothermal gas chromatographic analysis. Accessability to the column and detector compartment is readily accomplished by the removal of the lid assembly from the instrument. Located on this lid assembly are the column, injector, det ctor, heaters and associated feed back circuits. For operator ease, all electrical connections are made through a mating plug. Incorporating state of the art electronic design, the Model 511 Portable Cas Chromatograph may be powered from a 110 volt source or from the self-contained Nickel-Cadmium batteries. The batteries are capable of powering the instrument for a minimum of 8 hours at oven tem peratures of up to 200C before they must be recharged. While the batteries are being re charged the instrument remains operational and may be used to perform additional analys s. Where external gas supplies are available, they may be used with the instrument in order to conserve the gases located in the power pack. ucc 062898 APPLICATIONS Methane, Total and Non-Vtethane Hydrocarbons 45 ppm The use of valving systems allows the analysis of Total Hydrocarbons in one mode of oper ation and the separation of these materials in the other mode. Utilization of the back flush valve after the methane has been determined flushes all of the other compounds back into the detector where they can be measured if desired. Organic Solvent Vapors The .determination of the various individual compounds present in an air sample is an im portant analysis in the Environmental Health and Industrial Hygiene areas. Since the Model 511 separated the sample into its individual compounds it is possible to determine the con centration of each chemical. i* PP* CWtNt |l4 HOW TO ORDER Model 511 Portable Flame Ionization Gas Chromatograph including rechargeable Nickel-Cad mium batteries, recharger and lecture bottles of all gases required for detector operation. Also includes a 6 ft. x Vi inch column packed with 10% DC-200 on Chromosorb W HP. Fittings provided on power pack for recharging lecture bottles to high pressure. Consult Price List for instrument and accessory prices. t,ANALYTICAL INSTRUMENT DEVELOPMENT, INC. RT. 41 NEWARK RD., AVONDALE, PA. 19311 PHONE: (215)-268-3181 All Prices FOB Avondale, Pa. PB122 7/73 14 ucc r 062899 Printed in USA Dala Sheet 08-01-01 Model S t \ Monitaire Sampler Application The Model S MonitaireTM Sampler by MSA provides the necessary vacuum (or sampling atmospheres which may contain certain toxic and combustible gases, vapors, dusts, fumes, and mists. Description The Model 5 Monilaire Sampler is a rechargeable-battery-operated dia phragm pump which supplies a vacuum source for many atmospheric testing devices including (liter paper holders, charcoal tubes, impingers, and numer ous MSA portable gas detection instru ments. Flow rate is adjustable. Pump can be clipped to a worker's belt so that a continuous air sampling can be made over several working hours. The Model S pump features a dual valve assembly: a sample valve controls the sample . flow directly, end i e bypass valve controls bypass sir which may enter through the center of the stem. The bypass valve permits the pump to operate efficiently by compensating for sample-flow restrictions. Low sampleflow requirements or highly restrictive sample devices introduce a pressure differential which must be reduced. The bypass valve introduces atmospheric air directly into the pump, reducing the pressure differential; the bypass may be partially or totally closed at higher sample rates. Proper bypass settings are specified in the instruction mate rials that are part of the Monitaire Sampler Kit. A tube fitting on the exhaust side of the pump permits use of the Monitaire Sampler for pressure operations. The battery charger has two charging rates to charge the Model S pump over night or over weekends; fully charged battery will run the pump continuously for up to eight hours. The Model S Moni taire Sampler Kit includes: selfcontained batteryoperated pump, battery charger. Instruction man ual. pump maintenance card, and L attache- type carrying case with room for accessories. lire 062900 Data Sheet 08-01-01 1 \ Sampling method# Dust and mist collection. Filter paper holders adapt the Model S pump lo the collection ot dust, fiber, and particulate samples, plus detection of chromic acid This respirable dust sampler uses a cyclone and preweighed filter cassette or filter holder to collect only the respirable fractions of a variety of dusts, such as coal and silica. This holder assembly adapts the Model S pump to chem ically detect chromic acid mist and lead dust and fumes. Collection data are given on chart at right Sampling data for chromic acid mist and lead dust and fumes Measured Component Threshold Limit Value for 1873 Calibration Range Sampling Time Chromic acid mist Lead dust and fumes 0.1 mg/M* .15 mg/M 0.1-2.1 mg/M* .05-6.3 mg/M 1 to 105 minutes IV* to 48 minutes Filter weighing balance Hazards of dust are often evaluated on a weight basis. A high degree of sensi tivity (.01 milligram) is required to relate collected samples to Threshold Limit Values. The Ainsworth Model 22MF Balance from MSA meets these requirements. coal sampling lobes. When used he Model S Monitaire Sampler e MSA Tube Holder, MSA Charimpting Tubes provide for t collection of organic and r vapors for subsequent analysis Moratory equipment Each tube .eparate layers of charcoal: section and a reference ic vapor sampling tube will organic compound which is being collected, desorbed, d; such compounds include rbon tetrachloride, chloroe, ethylene dichloride, trir , and xylene. The meri tube collects both eleemically bound mercury articulates containing aintess-steel tube itive, teak-free seal; -.lip attaches to lapel g near wearer's tmpfnger tests r The Monitaire Sampler can be used with MSA Midget Impinger flask assemblies for dust, gas, \ and vapor sam pling. Total air borne particles t are wetted down and collected in the impinger flask. Because of the pump design, a 0.1 cfm sampling rate at 12 in., H20 vacuum can be obtained. This rate can be mainlained for up to eight hours with a fully charged battery. For sampling toluene diisocyanate (TOI), loluene diisocyanate urea, methylene di-para-phenylene isocya nate (MDI), and polymethylene polyphenylisocyanate (PMPPi) vapors, an alt-glass impinger flask is used with the Model S pump. Testing with MSA portable gas detection Instruments, The Monitaire Sam pler will also provide a con tinuous vacuum for drawing gas samples through MSA portable detection equip ment for testing periods up to eight hours. The test instruments can be placed up to 100 feet from the test location when sampling lines of V< -inch 10 tubing are used. MSA gas detection instruments that can be used with the Monitaire Sampler include: Portable Gas Indicator Model 20 Portable Gas Indicator Model 21 Portable Gas Indicator Model 30 Portable Gas Indicator Model 40 Expiosimeter* Model 2 Expiosimeter Model 2A Expiosimeter Model 2B Expiosimeter Model 3 Expiosimeter Model 4 Expiosimeter Model 5 Expiosimeter Navy Type B Expiosimeter Navy Type E Expiosimeter AF Navy Type R-1 Gascope* Model 53 Portable Oxygen Indicator, 0-25% Range Portable Oxygen Indicator, 5-40% Range Approvals and standards Sampling pump has USBM Approval No. 2G-2239-2 as "permissible" lor meihane/air atmospheres. Factory Mutual approved as "intrinsically safe" for Class I, Division I, Groups C and D hazardous locations. Specifications Pump Type: diaphragm Dimensions: 2Vz in. x 5 in. x 5 in. Weight: 31 oz, including battery Battery and performance: 6-volt rechargeable battery, 8-hour continu ous operation on full battery charge Flow indication: 0 to 10 scale Maintenance: (1) valve stems should be cleaned periodically by removing valve and blowing with air; (2) flow-tube assembly is easily removed and replaced; (3) pump and charger should be stored in container when not in use Battery charger Dimensions: 2% in. x 3 in. X 416 in. Weight: 1216 oz Power source: 16-hour rate for over night charging, 64-hour rate for week end Charging Ordering information Catalog numbers 459660 458475 456059 996097 996338 459662 93385 459182 457629 Model S Monitaire Sampler Kit, complete with pump, charger, maintenance card, instruction manual, and carrying case Pump, ModetS Battery Charger Maintenance card Instruction manual Carrying case Flow-tube assembly, 0 to 10 range Batlery pack, replacement Calibration check unit for sampling pumps 92944 456243 456242 456228 456226 456246 625412 449347 459743 457392 Dusl and mis) collection accessories Holder assembly, filter disc Holder assembly, respirable dust, complete with cyclone and sampling line assemblies Holder assembly only, respirable dust Cyclone assembly only Sampling line assembly Kit, supplementary parts, including: 1 press/pry tool for 2- or 3- piece aerosol filter holder (456223) 1 brush (625416) 1 tweezer (625417) 3 screens, stainless steel support (456224) Holder, aerosol filter, 2-piece; pkgof 12 Holder, aerosol filter, 3-piece; pkgof 10 Coupler, sampling line; pkg of 3 Coupler, stainless steel, for aerosol filter holder sampling with cyclone assembly 457391 39642 39643 Coupler, plastic, for pre weighed cassette sampling with cyclone holder assembly Balance, filter weighing Carrying case for balance . 459003 459004 459054 Charcoal sampling tubes and accessories MSA Charcoal Sampling Tubes, mercury vapor, pkg of 12 MSA Charcoal Sampling Tubes, organic vapor, pkg of 12 MSA Tube Holder 93470 93495 Impinger lest accessories Connector assembly for Midget Impinger flask Tubing for TDI or MDI flask 3 C .4 Note:This Data Sheet contains only a general description of the Model S Monitai'e Sampler. While uses and performance capabilities are described, under no circumstances should this device be used until the instructions, labels, or Other literature accompanying the product have been carefully read and the precau tions therein set forth followed. Only they contain the complete end detailed informa tion concerning this product. MSA MINE SAFETY APPLIANCES COMPANY 400 PENN CENTER BLVD.. PITTSBURGH. PA. 15235 At your service: 76 branch offices in the United States. MSA CANADA. Downsview, Ontario (Metro Toronto), Halifax, Montreal, Winnipeg, Saskatoon. Edmonton. Calgary, Vancouver; representatives in principal cities ol the world, cable address--"MINSAF" Pittsburgh Oats Sheet 0S41 Pontes in U.S.A. 7*1(1) A. A '9lu \ VINYL CHLORIDE DETERMINATION IN AIR BY ADSORPTION ON ACTIVATED CHARCOAL AND ANALYSIS BY GAS CHROMATOGRAPHY 15-MINUTE SAMPLE X PURPOSE AND LIMITATIONS This paper describes a procedure for measuring the exposure of personnel to vinyl chloride in the working environment. The method describes the preparation of standards which will determine vinyl chloride in the range of 9 to 90 parts per million by volume in air, based on a 15-min. sample at a flow rate of 100 ml per minute. Lower or higher ppm ranges can be determined by preparing additional standards to cover the range desired. (Vinyl chloride can be determined to at least 0.05 ppm by volume in air by this procedure, using more dilute standards.) 2 PRINCIPLE The sample is collected by passing air through a glass tube containing activated charcoal which adsorbs any vinyl chloride vapors present. The vinyl chloride is then desorbed from the charcoal by carbon disulfide extrac tion and analyzed by gas chromatography. 3 INSTRUMENT PARAMETERS Chromatograph Column 'Column temperature Injection temperature Detector Carrier Hydrogen flow rate Air flow rate Sample size Retention time AID (Analytical Instrument Development, Inc.) Portable Chromatograph, Model 511, or equivalent chromatograph, with flame ionization detector. Six-foot x 1/8-inch stainless steel packed with 10% di (2-ethylhexyl) sebacate on Chromasorb P, 80/100 mesh, NAW. 100eC isothermal 100*0 ' flame ionization detector helium or nitrogen 23 cc per minute 133 cc per minute 2 pi solvent flush technique 0.5 minute (adjust carrier flow until vinyl chloride elutes at this time) jNote; If this column is used In a conventional chromatograph, r better separation of vinyl chloride from other light ,rnrm boiling impurities wilO>e~ obtained by operation oi the column oven near ambi'enV'*temperature'j'-3o"C. The "AID portable chromatograph cannot be used at ambient temperature without modification since the heat from . the flame ionization detector wilfcause''the temperaturo in the column oven to rise to 60 to 70 C. ... ...... \ Alt mat Column - Better Resolution Instrument Column Detector Column temperature Detector temperature Injector temperature Carrier gas Air flow Hydrogen flow Sample size Approximate elution time Hewlett-Packard 5750 gas chromato graph - dual column, or equivalent, 25-foot x 1/S inch stainless steel packed with 25% by weight 75% CO8S0/25% Tergitol E-35 on 40/60 mesh rescreened Chroraosorb P. flame ionization 40 to 100C at 4*0 per minute 125'C 125#C helium, 30 ml per minute 350 ml per minute 30 ml per minute 10 /i 1 6.5 minutes 4 REAGENTS AND APPARATUS a) Personal sampling pump. MSA Model G or Bendix Micronair. Insert an in-line orifice made from a cut-off and restricted (pinched) hypodermic needle in the sampling line to the pump in order to obtain a 100cc per minute flow on these pumps. b) Hypo-vials, 15-ml size, Cat. No. 12911; Neoprene septa, Cat. No. 13233; alumina seals, Cat. No. 13214; and hand crimper. Cat. No. 13212, Pierce Chemical Company, Rockford, Illinois. c) Carbon disulfide, epectrophotometric grade d) Activated charcoal, Cat. No. 660-26, Barnebey-Cheney, Columbus, Ohio e) Soap film flow meter, 10-ml size f) Stop watch 5 PREPARATION OF THE ACTIVATED CARBON ADSORPTION TUBE a) Prepare the activated charcoal by placing the charcoal on a 40-mesh sieve and wash with demineralized water until no visible fines appear in the washings. b) Dry the carbon in a drying oven at 110rC until dry and free flowing (overnight). Store in a screw-top, glass bottle until needed. c) Cut 8-mm O.D. x 6-mm I.D. Pyrex glass tubing into 6-inch lengths and fire polish the ends. d) Insert a Pyrex glass wool plug two-thirds of the distance into the glass tubes. The longer section of tubing will be designated as the primary end, while the shorter side of the tubing is the back-up end. e) Pack the tubes with the activated carbon, using a length of 60 mm in the primary section and 35 mm in the back-up section. Retain the carbon with glass wool plugs. f) Seal the tubes with a red rubber septum or parafilm until ready for use* ucc 062905  6 SAMPLING PROCEDURE a) Remove the seals from the charcoal tube and attached the back-up section to a portable pump by means of a length of 1/4-inch Tygon tubing. b) Set the flow rate at 100 ml per minute through the tube with a calibrated rotameter. (NOTE: The 10-ml soap bubble flow meter can be used to obtain a more precise reading of the air flow through the tube if desired). c) Record the time the air sampling was started and the time when the sampling is completed. A 15-minute sample may be taken with this system. d) After sampling, recheck the flow rate and reseal the ends of the charcoal tube. Return the tube to the laboratory for analysis. e) Record the temperature and barometric pressure at the sampling site. 7ANALYTICAL PROCEDURE a) Make a small hook at the end of a piece of wire and remove the glass wool plug from the primary end of the charcoal tube. Make sure that no charcoal particles adhere to the glass wool plug. b) Pour the charcoal into a 10-ml glass-stoppered volumetric flask and cool the flask and carbon in a wet-ice hath. . c) Pipet 3 ml of carbon disulfide (CS2) into the cooled flask and stopper securely. (CAUTION: Carbon disulfide is toxic and should be handled under a hood.) d) Agitate the flask periodically for at least 30 minutes. c) Solvent Flush Injection Technique# This injection technique Is designed to eliminate difficulties arising from blow* back or distillation with the needle of the microliter syringe. f) Flush a 10-jjI syringe with CS2 several times to wet the barrel and plunger. g) Draw 2 jil of CS2 into the syringe and remove the tip of the needle from the solvent. Withdraw the plunger an additional 0.5 pi to separate the CS2 from the sample with a pocket of air. h) Dip the needle into the sample solution In the volumetric flask and withdraw the plunger until the air bubble between the solvent and the sample has passed the 2-pl mark on the syringe. I) Remove the tip of the needle from the sample solution and adjust the volume in the syringe until the meniscus of the air bubble rests on the 2-yul mark. Remove the excess sample solution from the tip of the needle. J) Pull the plunger back an additional 0.5 ;il to prevent the sample solution from evaporating from the tip of the needl k) Inject the entire contents of the syringe into the chromato- graph. l) Measure the peak height and determine the vinyl chloride oontent from a previously prepared calibration curve. OCC at 06290^  8CALIBRATION CURVE a) Pipet 10 ml of carbon disulfide (CS2) into each of five 15-ml hypo-vials. Cap the vials with the Neoprene septa and aluminum seals, using the hand crimper. b) Place the hypo-vials in wet ice to reduce the vapor pressure of CS2. c) Cap one of the valves on a steel sample cylinder containing vinyl chloride with a 1/8-inch Swagelok tubing nut which has a chromatographic septum installed in the nut. d) Insert a hypodermic needle through the septum on the cylind r, open the valve and allow the vinyl chloride to vent through the needle for about 10 seconds to purge the air from the system. Remove the needle. e) Using the appropriate gas-tight syringe fitted with a number 27 gauge hypodermic needle, Insert the needle through the septum on the cylinder and allow the pressure of the vinyl chloride to displace the volume of the syringe. Flush the syringe two times to remove any air which may have been trapped in the needle. f) Into the respective hypo-vials, inject 0.2, 0.3, 0.5, 1.0, and 2.0 cc of vinyl chloride from the syringe. E> Shake the hypo-vials for one minute to put the vinyl chloride in solution. These standards will contain 56, 82, 133, 260, 515 jjgm of vinyl chloride per ml. (NOTE: These calcula tions are corrected for the dead space in the gas syringe needle. The cold CS2 solutions in the hypo-vials are under slight negative pressure. Measurements have shown that the dead space in the syringe needle amounts to 0.04 cc, and 0.02 cc of this volume is pulled into the hypo-vial by the negative pressure.) h) Allow the standards to warm up to room temperature, then inject these standards into the chromatograph using the procedure described in Section 7, paragraphs e through k. Shake the hypo-vials each time just prior to withdrawing a sample. i) Plot peak height versus micrograms of vinyl chloride per ml. 9 CALCULATION TML"'x 62~5~~ " yinyl chloride, PP by volume at 25"C and 760 mm A pgm per ml of vinyl chloride read from calibration curve L - total liters of air sample (flow rate x time) VINYL CHLORIDE DETERMINATION IN AIR BY ADSORPTION ON ACTIVATED CHARCOAL AND ANALYSIS BY GAS CHROMATOGRAPHY * 4-HOUR SAMPLE X PURPOSE AND LIMITATIONS This paper describes a procedure for measuring the exposure of personnel to vinyl chloride in the working environment. The method describes the preparation of standards which will determine vinyl chloride in the range of 9 to 90 parts per million by volume in air, based on a 4-hour sample at a flow rate of 28 ml per minute. Lower or higher ppm ranges can be determined by preparing additional standards to cover the range desired. (Vinyl chloride can be determined to at least 0.05 ppm by volume in air by this procedure, using more dilute standards.) 2 PRINCIPLE The sample is collected by passing air through a glass tube containing activated charcoal which adsorbs any vinyl chloride vapors present. The vinyl chloride is then desorbed from the charcoal by carbon disulfide extrac tion and analyzed by gas chromatography. 3 INSTRUMENT PARAMETERS Chromatograph Column 'Column temperature Injection temperature Detector Carrier Hydrogen flow rate Air flow rate Sample size Retention time AID (Analytical Instrument Development, Inc.) Portable Chromatograph, Model 511, or equivalent chromatograph, with flame ionization detector. Six-foot x 1/8-inch stainless steel packed with 10% di (2-ethylhexyl) sebacate on Chromasorb P, 60/100 mesh, NAW. 10QeC isothermal_______ ' To"oc -- flame ionization detector helium or nitrogen 23 cc per minute 133 cc per minute 2 pi solvent flush technique 0.5 minute (adjust carrier flow until vinyl chloride elutes at this time) /Notet If this column is used in a conventional chromatograph, ir' better separation of vinyl chloride fronTother light ft boiling Impurities will be obtained by operafidn oi * .the column oven near ambient temperature -30*C.'"The ,,AID portable chromatograph cannot be used at ambient temperature without modification since the heat from Tthe flame ionization detector will cause the temperature *~Yn the column oven to rise to 60 to ~70 C. n ucc 062908 Altercate Column - Better Resolution Instrument Column Detector Column temperature Detector temperature Injector temperature Carrier gas Air flow Hydrogen flow Sample size Approximate elution time Hewlett-Packard 5750 gas chromato graph - dual column, or equivalent 25-foot x 1/8 inch stainless steel packed with 25% by weight 75% C0880/25% Tergitol E-35 on 40/60 mesh rescreened Chromosorb P. flame ionization 40 to 100C at 4"C per minute 125C 125 C helium, 30 ml per minute 350 ml per minute 30 ml per minute 10 >il 6.5 minutes 4 REAGENTS AND APPARATUS a) Personal sampling pump. MSA Model G or Bendix Micronair. Insert an in-line orifice made from a cut-off and restricted (pinched) hypodermic needle in the sampling line to the pump in order to obtain a 28 cc per minute flow on these pumps. b) Hypo-vials, 15-ml size, Cat, No. 12911; Neoprene septa, Cat. No. 13233; alumina seals, Cat. No. 13214; and hand crimper, Cat. No. 13212, Pierce Chemical Company, Rockford, Illinois. c) Carbon disulfide, spectrophotometric grade d) Activated charcoal, Cat. No. 580-26, Barnebey-Cheney, Columbus, Ohio e) Soap film flow meter, 10-ml size f) Stop watch 5 PREPARATION OF THE ACTIVATED CARBON ADSORPTION TUBE a) Prepare the activated charcoal by placing the charcoal on a 40-mesh sieve and wash with demineralized water until no visible fines appear in the washings. b) Dry the carbon in a drying oven at 110yC until dry and free flowing (overnight). Store in a screw-top, glass bottle until needed. c) Cut 8-mra O.D. x 6-mm I.D. Pyrex glass tubing into 6-inch lengths and fire polish the ends. d) Insert a Pyrex glass wool plug two-thirds of the distance into the glass tubes. The longer section of tubing will be designated as the primary end, while the shorter side of the tubing is the back-up end. e) Pack the tubes with the activated carbon, using a length of 60 mm in the primary section and 35 mm in the back-up section. Retain the carbon with glass wool plugs. f) Seal the tubes with a red rubber septum or parafilm until ready for ust* e SAILING procedure a) Remove the seals from the charcoal tube and attached the back-up section to a portable pump by means of a length of 1/4-inch Tygon tubing. b) Set the flow rate at 28 ml per minute through the tube with a calibrated rotameter. (NOTE: The 10-ml soap bubble flow meter can be used to obtain a more precise reading of the air flow through the tube if desired). c) Record the time the air sampling was started and the time when the sampling is completed. A four-hour sample may be taken with this system. d) After sampling, recheck the flow rate and reseal the ends of the charcoal tube. Return the tube to the laboratory for analysis. e) Record the temperature and barometric pressure at the sampling site. 7 ANALYTICAL PROCEDURE a) Rake a small hook at the end of a piece of wire and remov the glass wool plug from the primary end of the charcoal tube. Make sure that no charcoal particles adhere to the glass wool plug. b) Pour the charcoal into a 10-ml glass-stoppered volumetric flask and cool the flask .and carbon in a wet-ice bath. _ c) Pipet 3 ml of carbon disulfide (CS2) into the cooled flask and stopper securely. (CAUTION: Carbon disulfide is toxic and should be handled under a hood.) d) Agitate the flask periodically for at least 30 minutes. e) Solvent Flush Injection Technique. This injection techniqu is designed to eliminate difficulties arising from blowback or distillation with the needle of the microliter syringe. f) Flush a 10-^1 syringe with CS2 several times to wet the barrel and plunger* g) Draw 2 jil of CS2 into the syringe and remove the tip of the needle from the solvent. Withdraw the plunger an additional 0.5 pi to separate the CS2 from the sample with a pocket of air. h) Dip the needle into the sample solution in the volumetric flask and withdraw the plunger until the air bubble between the solvent and the sample has passed the 2-jj1 mark on the syringe. 1) Remove the tip of the needle from the sample solution and ' adjust the volume in the syringe until the meniscus of the aiJr bubble rests on the 2-yul nark. Remove the excess sample solution from the tip of the needle. j) Pull the plunger back an additional 0.5 pi to prevent the sample solution from evaporating from the tip of the needle. k) Inject the entire contents of the syringe into the chromato graph. l) Measure the peak height and determine the vinyl chloride content from a previously prepared calibration curve* uccrt 062910 3 CALIBRATION CURVE , a) Pipet 10 ml of carbon disulfid (CS2) into each of five 15-mi hypo-vials. Cap the vials with the Neoprene septa and aluminum seals, using the hand crimper. b) Place the hypo-vials in wet ice to reduce the vapor pressur of CS2. c) Cap one of the valves on a steel sample cylinder containing vinyl chloride with a 1/8-inch Swagelok tubing nut which has a chromatographic septum installed in the nut. d) Insert a hypodermic needle through the septum on the cylinder,' open the valve and allow the vinyl chloride to vent through the needle for about 10 seconds to purge the air from th system. Remove the needle. e) Using the appropriate gas-tight syringe fitted with a number 27 gauge hypodermic needle, insert the needle through the septum on the cylinder and allow the pressure of the vinyl chloride to displace the volume of the syringe. Flush the syringe two times to remove any air which may have been trapped in the needle. f) Into the respective hypo-vials, inject 0.2, 0.3, 0.5, 1.0, and 2.0 cc of vinyl chloride from the syringe. g) Shake the hypo-vials for one minute to put the vinyl chloride in solution. These standards will contain 56, 82, 133, 260, 515 pgm of vinyl chloride per ml. (NOTE: These calcula tions are corrected for the dead space in the gas syringe needle. The cold CS2 solutions in the hypo-vials are under slight negative pressure. Measurements have shown that the dead space in the syringe needle amounts to 0.04 cc, and 0.02 cc of this volume iB pulled into the hypo-vial by the negative pressure.) h) Allow the standards to warm up to room temperature, then inject these standards into the chromatograph using the procedure described in Section 7, paragraphs e through k, Shake the hypo-vials each time just prior to withdrawing a sample. i) Plot peak height versus micrograms of vinyl chloride per ml. 9 CALCULATION ^ L x 62^5 ~ " vinyl chloride, ppm by volume at 25#C and 760 mm A - pgm per ml of vinyl chloride read from calibration curve L - total liters of air sample (flow rate x time) 1 'CC 062911 DETERMINATION OF RESIDUAL VINYL CHLORIDE MONOMER IN VINYL RESINS 1 PURPOSE A procedure for determining the amount of residual vinyl chloride present in vinyl rosins is described. The resin is dissolved in a solvent and tho vinyl chloride analysed using a gas chromato graphic technique. The method is applicable for use with poly(vinyl chloride), vinyl chloride-vinyl acetate copolymers and other vinyl resins in which there are no volatiles which interfere in the determination. 2 EQUIPMENT AND REAGENTS Gas Chromatograph, Hewlett-Packard (F and II) Model 5750 or equivalent, equipped with a hydrogen flame ionization detector. Tetrahydrofuran, reagent grade. Balance with accuracy to 0.10 gram. 2 SAMPLE PREPARATION Prepare the sample for chromatograph injection by dissolving the test resin in tetrahydrofuran (THE). Weigh 9 grams of THF into a suitable vial. Add 1 gram of the resin to be tested to the THF. Resin addition should be made as quickly as possible. Cap the"bottle and place it on a can-roller to attain complete solution. When complete solution has occurred, the sample is ready for injection into the chromatograph. 4 INSTRUMENT PARAMETERS Instrument Hewlett-Packard (F and M) Model 5750 (or equivalent) equipped with hydrogen flame ionization detector. Column Six-feet by 1/8-inch stainless steel tubing packed with Chromosorb 102, 60/60 mesh. Temperatures: Column Injector Detector 100C for 4 minutes, manually Increased to 250C 100C (maximum) 300"C (flame ionization) Sample Size 4 Microliters Flows: Helium Carrier Gas Hydrogen Compressed Air 25 cc/minute 20 psi at cylinder head. 40 psi at cylinder head. tt  (Continu d) Elution Tines Vinyl Chloride Tetrahydrofuran 2.8 minutes 6.3 minutes 5 CALIBRATION Prepare solution mixtures of varying amounts of vinyl chloride in tetrahydrofuran to cover the expected range of concentration. Obtain from the chromatograph scan the area percent of vinyl chloride for each sample of known monomer content. Prepare a chart plotting the area percent vinyl chloride versus the known weight percent vinyl chloride to establish the relative detector response of the vinyl chloride with respect to tetrahydrofuran. 6 CALCULATION Determine the area percent vinyl chloride from the chromatograph scan for the resin solution to be characterized. Multiply this figure by 10, which converts the data to area percent vinyl chloride based on resin weight. Using the chart developed with the cali bration samples, read off the corresponding weight percent of vinyl chloride 0.0050 0.0040 0.0030 0.0020 0.0010 0.0010 Ar a Percent 0.0020 0.0030 0.0040 0.0050 i ( l ufchh's DUST DETERMINATION OF TOTAL AND RESPIRABLE AIRBORNE DUST BY MEMBRANE FILTER SAMPLING AND GRAVIMETRIC ANALYSIS 1 PURPOSE This procedure has been written to conform to recommended methods of sampling for dusts as published by the National Institute of Occupational Safety and Health (1) and the American Industrial Hygiene Association. (2) 2 PRINCIPLE Total dust concentration is measured by drawing a known volume of air through a preweighed, 37-mm polyvinyl chloride membrane filter, sampling with the top cover of the filter holder removed (open faced). The filter is dried by means of vacuum and reweighed to give a measure of the dust concentration. Respirable dust is measured by using a 10-mra nylon cyclone ahead of the membrane filter to remove the larger or non-respi'rable dust particles before they reach the filter. The filter is treated the same as described for total dust. The table below gives the theoretical deposition of the dust particles. Aerodynamic diameter (^ua), unit density sphere Percent passing cyclone APPARATUS a) Personal sampling pump and charger. Model G, Part No. 456252, Mine Safety Appliance Co., Pittsburgh, Pa., or equivalent. (NOTE - Earlier models of the Model G pump were not equipped with a pulsation damper. If such a model is used, then the pulsation damper kit, MSA Part No. 449614 - should be ordered and installed before taking dust samples.) b) Cyclone and holder; Part No. 456243, MSA holder assembly complete with cyclone and sampling line assemblies. c) Filter holders for 37-mm filters; 2-section, Catalog No. M000037PO, 3-section Catalog No. M000037AO, Millipore Corp., Bedford, Mass. d) Backup pad for 37-mm filter, Catalog No. AP1003700, Millipore Corp. e) Polyvinyl chloride membrane filters; 5.0 y pore diameter. Vinyl Metrlcel, VM-1, 37-mm diameter. Catalog No. 60714, Gelman Instrument Co., Ann Arbor, Mich. 41 t f) Vacuum desiccator (use with a safety shield to contain glass fragments in the event of implosion if a glass desiccator is employed). g) Mercury manometer h) Analytical balance capable of weighing to the nearest 0.01 mg. i) Vacuum pump - capable of reducing pressure in the desiccator to 5 mm of Hg. j) Cellulose bands; 2-section holder part No. 625415, Mine Safety Appliances Co. 3-section holder - 41x25 mm, No. 28, Valter H. Jelly and Co., Franklin Park, Illinois. PREPARATION OF FILTER a) Place the VM-1 polyvinyl chloride filter into the vacuum desiccator and reduce the pressure to 5 mm Hg. b) After 15 minutes at the 5-mm pressure, allow the desiccator to return to atmospheric pressure. c) Make sure the balance is zeroed before weighing. Holding the filter by the edge with tweezers, place it on the balance pan and record the weight to the nearest 0.01 mg (V^). d) Insert a backup support pad into the bottom section of the filter holder. Carefully place the weighed filter on the support screen. e) For total dust sampling (3-section filter holder), place the middle and top sections on the bottom section. Press the sections together firmly until the outer edge of the filter is tightly held against the backup support pad. f) For respirable dust sampling (2-section filter holder) place the top section on the bottom section and press firmly. g) Insert the red and blue plugs into the inlets of the filter holders and slip a cellulose band from the storage solution over the outside of the holder. Allow the band to dry thoroughly before using. 5 RESPIRABLE DUST AIR SAMPLING PROCEDURE a) Remove the red and blue plugs from the 2-section filter holder, and insert the filter holder into the cyclone holder assembly, make sure the filter face is pointing downward toward the cyclone. b) Clamp the filter holder securely into the cyclone holder, so that the O-rings are held tightly against the filter holder seats. c) Clip the cyclone holder assembly on the shirt collar of the employee. Attach the sampling lines from the cyclone to the inlet of the portable pump. d) Adjust the air flow through the cyclone by turning the adjusting screw on the pump until the flowmeter ball on the pump is centered on the red band on the flowmeter (1.8 liters per minute). If samples are to be taken for respirable coal dust, then the recommended flow rate through the cyclone and filter is 2.0 liters per minute.' This can be obtained by adjusting the flow on the pump until the flowmeter ball is centered under the orange band on the flowm ter. 42 e) Place the pump on a belt around th employe 's waist. Record the time the pump was started. f) At the end of the working shift, stop the pump and record the time. Note: respirable cfust samples need a minimum of 4-hours sampling time to provide enough sample to obtain an adequate amount of dust to weigh. g) Carefully remove the sampling assembly from the employee. Remove the filter and holder from the cyclone assembly and replace the red and blue plugs. Do not invert the cyclone assembly during this time as the larger particles of dust from the cyclone can fall onto the filter to give an erroneous weight gain. h) In the laboratory, split the cellulose band at the junction of the top and bottom section of the filter holder. Carefully pry off the top section. 1) Place the bottom section containing the filter into the desiccator and reduce the pressure to 5 mm Hg for 15 minutes to dry the filter. j) After the desiccator returns to atmospheric pressure, gently lift the filter out of the bottom section of the filter holder by using a small rod through the hole in the bottom section. k) Check the zero setting on the balance to make sure it hasn't changed from previous weighing of the filter. Grasp the edge of the filter with the tweezers and reweigh the filter on the balance. Record the weight to the nearest 0,01 mg (W2). l) Clean the dust from the cyclone body before the next use. 6 TOTAL DUST AIR SAMPLING PROCEDURE a) Take a 3-section filter holder which has been prepared according to the directions in Section 4. Slice the cellulose band at the junction of the top section and center retaining ring. b) Remove the top section and the plug from the bottom section outlet. Attach a piece of tubing from the bottom outlet and connect the other end of the tubing to the Model G MSA pump. c) Adjust the air flow through the filter by turning the adjusting screw on the pump until the flowmeter ball on the pump is centered on the orange band (2.0 liters per minute). d) Place the pump on a belt around the employee's waist and clip the filter to the shirt collar of the employee with the face of the filter pointing down. e) Record the time the sampling pump was started. f) At the end of the working shift, stop the pump and record the time. g) Carefully remove the filter from the employee. Replace the top cover and the plug in the bottom outlet. h) In the laboratory, split the cellulose band at the Junction of the bottom section and the middle retaining ring. Care fully pry off the top and middle sections. i) Place the bottom section containing the filter into the desiccator and reduce the pressure to 5 mm Hg for 15 minut s to dry the filter. uccrt o Q629AS j) After the desiccator returns to atmospheric pressure, gently lift the filter out of the bottom section of the filter holder by using a small rod through the hole in the bottom section. k) Check the zero setting on the balance to make sure it hasn't changed from previous weighing of the filter. Grasp the edge of the filter with the tweezers and reweigh the filter on the balance. Record the weight to the nearest 0.1 (W^). 7 CALIBRATION OF MSA SAMPLING PUMP a) Assemble the apparatus as shown in Figure 1. Tape the cap on the gallon bottle with vinyl electrical tape to insure a tight seal. b) Start the pump and adjust the flow until the ball in the flowmeter is centered on the red band (1.8 liters per minute). APPARATUS FOR CALIBRATION OF MSA PERSONAL SAMPLING PUMP Figure 1 c) Hoisten the interior surface of the buret with soap solution. d) Dip the end of the buret into the soap solution to start a bubble moving up the buret. e) T.'ith a stopwatch, measure the time in seconds that it takes for the bubble to move from the zero graduation mark on the buret to the 1000-ml mark. f) Divide the time in seconds into 60 to obtain the flow rate in liters per minute. g) Repeat the determination, centering the flowmeter ball on the pump on the orange band (2.0 liters per minute). h) A wet test meter may be used in place of the soap-film buret if desired. 8 CALCULATIONS a) Respirable dust (W2-W1) x 10* i FxT respirable dust concentration in milligrams per cubic meter (mg/li3) F Flow rate in liters per minute through the cyclone t and filter T * Total sampling time in minutes W. * Initial weight of the polyvinyl chloride filter in grams Wg Final weight of the polyvinyl chloride filter in grams b) Total dust Use identical calculation except to report the value as total dust concentration in mg/143. (F * flow rate in liters through the filter) UCC 062920 UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS 270 v'ARK AVENUE. New York, N,Y. 10017 Safes Offices United Stataa ATLANTA GEORGIA 30329.......................................17 Executive Perk Dr. .............. . ..........404-633-6161 BALTIMORE (MOORESTOWN. N.J. SALES OFFICE)........................................................ ........ 301-944-8211 BOSTON. MASSACHUSETTS 02194 ........................ 300 First Av*.. Needham Hgt*. ......... 617-444-5400 BUFFALO (CLEVELAND, OHIO SALES OFFICE)................................................................ .......... 716-837-6450 CHARLOTTE (ATLANTA GA SALES OFFICE)................................................................... .......... 704-364-1400 CHICAGO. ILLINOIS 60606...................................... 120 South Riverside Plan...... ..... .........J12-822-7000 CINCINNATI, OHIO 45227.................................... ,,.3814 West St..................... ...........513-272-0206 CLEVELAND. OHIO 44114......................................... 1300 Lakeside Ave.. N.E. .......... 216-621-4202 DALLAS, TEXAS 75207 ........................................... 2710 Stemmons Freeway ............ ......... .214-631-0010 DETROIT (SOUTHFIELD. MICH. SALES OFFICE).... ..................................... .................. ...........313-354-0800 HOUSTON (DALLAS. TEXAS SALES OFFICE)...................... ........................................... .......... 214-631-0010 INDIANAPOLIS (CINCINNATI. OHIO SALES OFFICE)...................................................... ........... 317-255-3181 KANSAS CITY (CHICAGO, ILL SALES OFFICE)................................................................ .......... 913-362-2200 LOS ANGELES, CALIFORNIA 9005S........... ........... 2770 Leoni* Blvd............................ .......... 213-583-3061 MEMPHIS (ATLANTA GA SALES OFFICE)........... ................................................. ........ .......... 901-396-5375 METROPOLITAN AREA SALES OFFICE; HACKENSACK. N.J. 07601 ................................ One University Ptaxe...................... ......... 201-646-1111 MINNEAPOLIS (CHICAGO, ILL SALES OFFICE)............................................................... .......... 612-927-4221 MOORESTOWN. NEW JERSEY 08057..................... Route 38 and Pleasant Valley Rd. ......... 609-235-6200 NEW YORK (METROPOLITAN AREA SALES OFFICE; HACKENSACK, NJ.)..................... ..........212-695-5054 PHILADELPHIA (MOORESTOWN, N.J. SALES OFFICE).................................................. .......... 215-923-3200 PITTSBURGH (MOORESTOWN, N.J. SALES OFFICE)................................... ................. . ..........412-922-5700 ST. LOUIS (CHICAGO, ILL SALES OFFICE)..................................................................... ......... J14-726-0324 SAN FRANCISCO (LOS ANGELES, CALIF. SALES OFFICE)................. ..................... ...... ...........415-7651000 FROM IDAHO. NEVADA. OREGON, UTAH, OR WASHINGTON............ ................ .... ....800-421-6050 SOUTHFIELD, MICHIGAN 48076............-.............26500 Northwestern Hway............ ........... 313-354-0800 Affiliates Pan Ammrlca Europm Africa tlffl Ml ARGENTINA .........................Union Carbide Argentine, S.A.I.C., Buenos Aire* BRAZIL____ _______ .._____ Union Carbide do Brazil S. A_, Sao Paulo. Rio de Janeiro CANADA __________________ Union Carbide Canada Ltd.. Amherst Calgary, Fort Garry, Lachine. Undssy. Surrey. Toronto, Vancouver CARIBBEAN ____ ____...__ Union Carbide Inter-Amenta. Inc., San Juan, hrerto Rico COLOMBIA .__________ ....Union Carbide Colombia, S. A., Bogota ECUADOR.............. ...............Union Carbide Ecuador, CA. Guayaquil MEXICO ................................ Union Carbide Mexicans, S. A, Mexico. D. F. Guadalajara, Monterrey PERU ..... ..............................Union Cerbide Inter-America, Inc.. Lime VENEZUELA ..... ................... Union Cerbide de Venezuela. C. A.. Caracaa WESTERN HEMISPHERE ....Union Carbida Inter-America, Inc. New York. N.Y. AUSTRALIA ______ _...Union Carbide Australia Ltd., Sydney, N. S W. CEYLON ................................ Union Carbide Ceylon, Ltd., Colombo HONG KONG _Union Cerbide Asia lid., Hong Kong INDIA.....................................Bate lit* Hylem Ltd., Bombay INDIA ______________ ....___Union Carbide India Ltd., Calcutta. Bombay, Madret, New Delhi INDONESIA ______ _________P. T. Union Carbide Indonesia, Djakarta JAPAN ....______________ __ Union Carbide Service* Eastern Lid., Tokyo MALAYSIA ................. ..........Union Carbide Asia, Ltd., Petaling Jaya. Salangor NEW ZEALAND_____ ______ Union Carbide New Zealand ltd., Auckland PAKISTAN ____________ ...National Carbon Co. (Pakistan) Ltd., Karachi PHILIPPINES Union Carbide Philippines Inc. Manila SINGAPORE_____________ Union Carbide Asia Ltd. TAIWAN ___ _______ _______ Union Carbide Formosa Co., Ltd., Taipei THAILAND______,,._,,..Unlon Carbide Thailand Limited, Bangkok AUSTRIA ... ........ ...... Union Carbide Austria Gm.b.H. Vienna BELGIUM , Union Carbide Belgium, B-1030 Brussels FRANCE__ _____ ...__ ...Union Carbide France, F-94533 Rungls (Parti) GERMANY ________________ Union Carbide Deutschland, G-m.b.H. DOsseldorf GREECE _____ .....Union Carbida Hellas Industrial and Commercial SJL, Athene , ITALY______________ ...____ Union Carbide Italia S.pJL, Milan NETHERLANDS ___Union Carbide Belgium, Amsterdam SCANDINAVIA .............. ...Union Carbide No'den AB, Stockholm, lamdan SPAIN ....________ Uninn Carbide fberica, SA-, Madrid SWITZERLAND ____ ____ Union Carbide Europe. SA. Geneva UNITED KINGDOM_______ Bakelite Xylonite Lid.. London; England Union Carbide U. K. Limited, London, Manchester, Rickmansworth; England . AFRICA (EAST)Union Carbide Africa Ltd.. Nairobi. Kenya AFRICA (SOUTH) ....... .....Union Carbida South Africa (Pty.) Ltd., Johannesburg Capetown, Durban; Republic of South Africa AFRICA (WEST)Union Carbide Africa Ud. Abidjan, Ivory OmR MIDDLE EAST AFRICA (NORTH)______ Union Carbida Middle Cast Ud. Athene. Greece ucc 062921 Printed In U-S.A. BARELITE VYHH is a medium molecular weight vinyl chloride-vinyl acetate copolymer resin* It dissolves readily in ketones, esters, chlorinated hydrocarbons, and combinations of these with aromatic hydrocarbons* APPLICATIONS BAKELITE VYHH is recommended for general coatings use. FOOD ADDITIVE STATUS BAKELITE VYHH is chemically identified in Food Additive Regulations >121.2514 for Resinous and Polymeric Coatings, and $121.2526 for components of Paper and Paperboard. Properties of BAKELITE Vinyl Resin Solution VYHH Properties Appearance Specific Gravity at 20/20'C. Size, through a No. 20 USBS sieve. per cent by weight Apparent Density, lb. per ft.' Heating Loss, 45 minutes at 105C., per cent by weight Poly(vinyl chloride), per cent by weight Lead, ppm. Test Methods Visual D 792 WC-7-F WC-2-B WC-160-H WC-294-B or D WC-20-D or K Required Values White powder 1.36 t 0.005 98, minimum 30, approximate 3.0, maximum 85.0 - 86.5 5, maximum June, 1970 F-42808 (continued) BAKELITE and UNJ.ON CARBIDE are registered trade marks of Union Carbide Corporation, U.S.A* O This information it not to bt taktn at a warranty or rpprtstntation for which wt tttumi legal responsibility nor at permission or roepm* mndat*on to practice any patented invention without a lieansa. It is offered solely for your consideration, investigation *nd verification. UNION CARBIDE CORPORATION 270 PARK AVENUE. NEW YORK, N.Y. 10017 o 062922 i i Solution Properties 22 Per Cent Solution of Resin in 1:1 MIBK:Toluene Viscosity at 25C., cps. Color, per cent transmission Turbidity 10 Per Cent Solution of Resin in 1:1 MIBK:Toluene Insoluble Matter, per cent by volume Test Methods Required Values WC-31-W WC-5-K-2 WC-5-K-2 200 - 400 85, minimum 85, minimum WC-322-C 0.03, maximum TESTING METHODS Designated tests are made in accordance with current issues of ASTM or UNION CARBIDE (WC) Testing Methods. The former can be obtained from the American Society for Testing and Materials, Philadelphia, Pa., while the latter are available from Union Carbide Corporation upon request. 1-42808 Printed in U.S.A. UC oft! r F2^wiS3 vinyl '"' v RESINS BAKELITE VINYL CHLORIDE-ACETATE RESIN VYNW-5 /..'rVuvs DESCRIPTION BAKELITE VYNW-5 is a vinyl chloride - low vinyl acetate copolymer nonsolvent resin. APPLICATIONS BAKELITE Vinyl Chloride-Acetate Resin VYNW-5 is a blotter-type resin that is recommended for nonrigid applications, such as electrical insulation, film and sheeting, contour extrusion molding, injection and compression molding, and flooring. Properties of BAKELITE Vinyl Chloride-Acetate Resin VYNW-5 Properties Test Methods Size, per cent by weight through USBS sieve WC-7-F No. 40 No. 80 Heating Loss, per cent by weight. 45 minutes at 105C. WC-160-H Polyvinyl Chloride, per cent by weight Foreign Matter, slurry WC-294-A WC-15-P-1 Inherent Viscosity, 0.2 g. of resin/100 ml. of cyclohexanone at 30eC. High Temperature Mill Stability: D 2857 WC-163-B-3 Initial Color, per cent transmission Ultimate Stability, minutes Hard Resin Particles, per ft.2 WC-15-K-2 Plasticizer Absorption, per cent by weight Apparent Density of Powdered Resin, lb./ft.3 D 1755 WC-2-B D 1895 Typical Values 100 98 0.3 97.5 2 1.07 75 25 2 175 18.5 (continued) April, 1971 F-433S0 i irr 062924 BAKELITE and UNION CARBIDE are registered trade marks of Union Carbide Corporation, U.S.A, TTtii information it not to bt tofctn it warranty or roprciffttotion for which wt atium* legal rtipomibility nor at permifftion or racoro mandation to practice any patented invention without licence. It it offered toltly for yowr consideration. investigation end varification, UNION CARBIDE CORPORATION 270 PARK AVENUE. NEW YORK. N.Y. 10017 I \ TEST METHODS 1 Designated tests are made in accordance with current issues of ASTM or UNION CARBIDE (WC) Testing Methods. The former may be obtained from the American Society for Testing and Materials, Philadelphia, Pa., while the latter are available from Union Carbide Corporation upon request. PACKAGING AND LABELING The standard package for BAKELITE Vinyl Chloride-Acetate Resin VYNW-5 is a four-ply multiwall Kraft paper bag containing 50 lb. net. desired, this resin can also be supplied in hopper cars containing approximately 75,000 lb. The package will be plainly marked with the product and lot numbers and the quantity. Shipments will be properly addressed to assure complete delivery to the purchaser. If PRECAUTIONARY LABELING On the basis of the toxicological, physical, and chemical properties of BAKELITE Vinyl Chloride-Acetate Resin VYNW-5. precautionary labeling used on the containers is as follows: FOR INDUSTRY USE ONLY P-43380 4/71-4M Printed in U.S.A. o'Jl2C9C25 DESCRIPTION An acid modified vinyl chloride-vinyl acetate copolymer resin of medium-molecular weight. Solubility characteristics are similar to those of BAKELITE VYHH resin. BAKELITE VMCH resin is recommended for general coatings use either alone or in combination with other vinyl resins to obtain good air dry adhesion to metal, paper, and other substrates. This resin is listed by chemical identity in the Resinous and Polymeric Coatings Food Additive Regulation 121.2514. Properties of BAKELITE Vinyl Solution Resin VMCH Property Testing Method Required Values Appearance Specific gravity Size, % by wt. through a No. 20 USBS Sieve Apparent Density, lb./cu.ft. approximate Heating Loss, 45 minutes at 105 SC. , % by wt. Poly(Vinyl Chloride), % by wt. Maleic Acid, % by wt. Lead, ppm. Solution Properties, 22% solution of resin in 1:1 MIBK:Toluene Viscosity at 25 "C.., cps. Colorilight transmission at 475 nvf/600 m-y, per cent Turbidity:light transmission at 600 nvf Insoluble Matter, % by wet volume, 10% solution Visual ASTM D 792 WC-7-F WC-2-B WC-160-H WC-294-B or D WC-308-A WC-20-D or K WC-31-W WC-5-K-2 WC-5-K-2 WC-322-C White, powdered solid 1.35 0.005 98, minimum 30 3.0, maximum 85.0 - 88.0 0.8 - 1.2 5, maximum 200 - 400 85, minimum 80, minimum 0.03, maximum November, 1972 F-44259 BAKELITE and UNION CARBIDE are registered trade marks of Union Corporation, U.S.A. 2926 Thi infprmation la net to bt token 01 o warranty or rapraaantatien (O' which wo attumt let*I raaponaibility nor >i pfrmitoion pr racommandatipn to practice any patented invention without t licontt. It ic offer'd ootity for your contidorotiOn. invalidation and trerrfrcetion. UNION CARBIDE CORPORATION 270 PARK AVENUE, NEW YORK. N.Y. 10017 TESTING METHODS Designated tests are made in accordance with current issues of the ASTM or UNION CARBIDE (WC) testing methods designated. The former can be obtained from the American Society for Testing and Materials, Philadelphia, Pa., \^hile the latter are available from Union Carbide Corporation upon request. PACKAGING AND LABELING The standard package for BAKELITE VMCH is a multi-wall paper bag containing 50 pounds of product. The package will be plainly marked with the product and blend numbers and the quantity of material contained. BAKELITE VMCH is also available in bulk; by hopper car containing approximately 150,000 pounds;and in certain geographic areas, by hopper truck containing approximately 40,000 pounds. SHIPPING AND STORAGE BAKELITE Vinyl Solution Resin VMCH is a stable material when kept in closed containers stored in a cool dry place. PRECAUTIONARY LABELING On the basis of the toxicological, physical, and chemical properties of BAKELITE Vinyl Solution Resin VMCH, precautionary labeling used on the containers is as follows: FOR INDUSTRY USE ONLY TOXICOLOGICAL PROPERTIES BAKELITE Vinyl Solution Resin VMCH is a powdered resin which is essentially inert and non-toxic. Its dust is classed as a nuisance dust which is not known to cause lung disease. However, it is prudent not to exceed the recommended Threshold Limit Value for nuisance dust of 10 mg. per cubic meter of air or 30 million particles per cubic foot, whichever is the smaller r-44259 11/72-4N Printed in U.S.A. 7 COATINGS AND S3' PLASTICS MATERIALS L BAKELITEVINYL RESIN SOLUTION VYHH FOR COATINGS DESCRIPTION BAKELITE VYHH is a medium-molecular weight vinyl chloride-vinyl acetate copolymer resin. It dissolves readily in ketones, esters, chlorinated hydrocarbons, and combinations of these with aromatic hydro carbons. APPLICATIONS BAKELITE VYHH is recommended for general coatings use. FOOD ADDITIVE STATUS BAKELITE VYHH is chemically identified in Food Additive Regulations ^121.2514 for Resinous and Polymeric Coatings and by reference in $121,2526 for Components of Paper and Paperboard and in 121.2550 for Components of Closures. Properties of BAKELITE Vinyl Resin Solution VYHH Properties Appearance Size, per cent by weight. through a No. 20 USBS Sieve Heating Loss, 45 minutes at 105*C., per cent by weight Poly (vinyl chloride). per cent by weight Test Methods Visual WC-7-F WC-160-H WC-294-B or D Required Values White powder 98, minimum 3.0, maximum 85.0 - 86.5 (continued) October, 1973 F-42808A 06Z92 BAKELITE and UNION CARBIDE are registered trade marks of Union Carbide Corporation. U.5.A.____________________ This Information It not to bt taken os a warranty or roprtsantation for which we assume letat responsibility nor os permission or rtcpm* vnandation to practice ony patented Invention without a license. It is offered aoltly for your consideration, investigation and verification. UNION CARBIDE CORPORATION 270 PARK AVENUE. NEW YORK. N.Y. 10017 -2 } Solution Properties 22 Per Cent Solution of Resin in 1:1 MIBK:Toluene Viscosity at 25C., cps. Color, % transmission at 475 Hn^/bOO mi* Turbidity, light transmission at 600 mu 10 Per Cent Solution Resin 1:1 MIBK: Toluene Insoluble Matter, per cent by wet volume Test Methods V7C-31-W WC-S-K-2 WC-5-K-2 WC-322-C Required Values 200 - 400 85, minimum 85, minimum 0.03, maximum TESTING METHODS Designated tests are made in accordance with current issues of ASTM or UNION CARBIDE (WC) Testing Methods. The former can be obtained from the American Society for Testing and Materials, Philadelphia, Pa., while the latter are available from Union Carbide Corporation upon request. LABELING All containers of BAKELITE Vinyl Resin Solution VYHH are plainly marked with the product nomenclature, blend number, and net weight. Shipments will be so addressed as to provide complete delivery to the purchaser. PRECAUTIONARY LABELING On the basis of the toxicological, physical, and chemical properties of BAKELITE Vinyl Solution Resin VYHH, precautionary labeling used on the con tainers is as follows: FOR INDUSTRY USE ONLY P-42808A 10/73-4M I ICC 062929 Jointed in U.S.A. .kVV`>>*; - 5***y. *se*. ^ r'aM^mfes - 1 "y _ .-' COATINGS AND :/ : plastics ;.;, -: MATERIALS p- v *. r y 1 BAKEUTEVINYL SOLUTION RESIN VMCH FOR COATINGS DESCRIPTION BAKELITE Vinyl Solution Resin VMCH is an acid-modified vinyl chloridevinyl acetate copolymer resin of medium-molecular weight. Solubility characteristics are similar to those of BAKELITE VYHH resin. BAKELITE VMCH resin is recommended for general coatings use either alone or in combination with other vinyl resins to obtain good air dry adhesion to metal, paper, and other substrates. FOOD ADDITIVE STATUS BAKELITE Vinyl Solution Resin VMCH is cited by chemical identity in Food Additive Regulations 5121.2514 for Resinous and Polymeric Coatings and by reference in 1121.2526 for Components of Paper and Paperboard and in 121.2550 for Components of Closures. Properties of ` BAKELITE Vinyl Solution Resin VMCH Property Testing Method Required Values Appearance Size, per cent by weight. through a No. 20 USBS Sieve Heating Loss, 45 minutes at 105C., per cent by weight Poly(vinyl chloride), per cent by weight Maleic Acid, per cent by weight Solution Properties, 22& solution of resin in 1:1 MIBK:Toluene Viscosity at 25*C., ops. Color, % light transmission at 475 imV600 im\ Turbidity, light transmission at 600 m\ Insoluble Matter, 10? solution. % bv wet volume Visual WC-7-F WC-160-H WC-294-B or D WC-308-A WC-31-W WC-5-K-2 WC-5-K-2 WC-322-C White powder 98, minimum 3.0, maximum 85.0 - 88.0 0.8 - 1.2 200 - 400 85, minimum 80, minimum 0.03. maximum October, 1973 F-44259A BAKELITE and UNION CARBIDE are registered trade marks of Union Carbide Corporation. U.S.A.__________ ________________ _______________________________ This information it not to b token os 0 warranty or representation for which we assume leg* I responsibility nor as permission or recom* mendetion to practice ony patented invention without a license. It is offered solely for your consideration, investigation and verification. i. ICC 062930 UNION CARBIDE CORPORATION 270 PARK AVENUE. NEW YORK. N.Y. 10017 ' .> TESTING METHODS Designated tests are made in accordance with current issues of the ASTM or UNION CARBIDE (WC) testing methods designated. The former can be obtained from the American Society for Testing and Materials, Philadelphia, Pa., while the latter are available from Union Carbide Corporation upon request. PACKAGING AND LABELING The standard package for BAKELITE VMCH is a multi-wall paper bag containing 50 pounds of product. The package will be plainly marked with the product and blend numbers and the quantity of material contained. BAKELITE VMCH is also available in bulk; by hopper car containing approx imately 150,000 pounds; and in certain geographic areas, by hopper truck containing approximately 40,000 pounds. SHIPPING AND STORAGE BAKELITE Vinyl Solution Resin VMCH is a stable material when kept in closed containers stored in a cool dry place. PRECAUTIONARY LABELING On the basis of the toxicological, physical, and chemical properties of BAKELITE Vinyl Solution Resin VMCH, precautionary labeling used on the containers is as follows: FOR INDUSTRY USE ONLY TOXICOLOGICAL PROPERTIES BAKELITE Vinyl Solution Resin VMCH is a powdered resin which is essentially inert and non-toxic. Its dust is classed as a nuisance dust which is not known to cause lung disease. However, it is prudent not to exceed the recommended Threshold Limit Value for nuisance dust of 10 mg. per cubic meter of air or 30 million particles per cubic foot, whichever is the smaller. P-44259A 10/73-4M 062^931 Printed in U.S.A. 1 COATINGS AND PLASTICS MATERIALS BAKELITEVINYL SOLUTION RESIN VYHH 1 FOR COATINGS DESCRIPTION a BAKELITE VYHH is a medium-molecular weight vinyl chloride-vinyl acetate copolymer resin. It dissolves readily in ketones, esters, chlorinated hydrocarbons, and combinations of these with aromatic hydro carbons. APPLICATIONS BAKELITE VYHH is recommended for general coatings use.. FOOD ADDITIVE STATUS BAKELITE VYHH is chemically identified in Food Additive Regulations 121.2514 for Resinous and Polymeric Coatings and by reference in $121.2526 for Components of Paper and Paperboard and in 121.2550 for Components of Closures. Properties of BAKELITE Vinyl Solution Resin VYHH Properties Appearance Size, per cent by -weight. through a No. 20 USBS Sieve Heating Loss, 45 minutes at 105C., per cent by weight Poly (vinyl chloride). per cent by weight Test Methods Visual WC-7-F WC-160-H WC-294-B or D Required Values White powder 98, minimum 3.0, maximum 85.0 - 86.5 (continued) December, 1973 F-42808B ucc 062932 BAKELITE and UNION CARBIDE are registered trade marks of Union Carbide Corporation, U.S.A. This information It not to be tikcn at a warranty or raprttentation for which we assume left) responsibility nor at permission or recom mendation to practice any patented invention without a license. It it offered toieiy for your consideration, investigation and verification. UNION CARBIDE CORPORATION 270 PARK AVENUE, NEW YORK. N.Y. 10017 I t \ y .> 2- Solution Properties 22 Per Cent Solution of Resin in 1:1 MIBK:Toluene Viscosity at 25C., cps. Color, % transmission at 475 mi|/600 mH, Turbidity, light transmission at 600 mu, per cent Test Methods WC-31-W WC-5-K-2 WC-5-K-2 Required Values 200 - 400 85, minimum 85, minimum 10 Per Cent Solution Resin 1:1 MIBK:Toluene Insoluble Matter, per cent by wet volume WC-322-C 0.03, maximum TESTING METHODS Designated tests are made in accordance with current issues of ASTM or UNION CARBIDE (WC) Testing Methods. The former can be obtained from the American Society for Testing and Materials, Philadelphia, Pa., while the latter are available from Union Carbide Corporation upon request. LABELING All containers of BAKELITE Vinyl Solution Resin VYHH are plainly marked with the product nomenclature, blend number, and net weight. Ship ments will be so addressed as to provide complete delivery to the purchaser. PRECAUTIONARY LABELING On the basis of the toxicological, physical, and chemical properties of BAKELITE Vinyl Solution Resin VYHH, precautionary labeling used on the containers is as follows: FOR INDUSTRY USE ONLY F-4280BB 12/73-4M UCC 062933 Printed in U.S.A. f -V- l-#--!.* -s- COAT1NGS AND PLASTICS MATERIALS BAKELITEVINYL SOLUTION RESIN VYNS FOR COATINGS DESCRIPTION i&r v"i - - .. EAKELITE VYNS is a vinyl chloride-vinyl acetate copolymer resin of highmolecular weight. It provides the maximum in physical properties such as tensile strength, elongation, and abrasion resistance that can be obtained from a solution applied coating of practical solids content. BAKELITE VYNS requires essentially straight ketone solvents, and it can tolerate very high plasticizer concentrations without becoming tacky. BAKELITE VYNS resin is recontnended as an adhesive, ink, or topcoat for plasticized vinyl film or coated fabric. FOOD ADDITIVE STATUS BAKELITE Vinyl Solution Resin VYNS is cited by chemical Identity in Food Additive Regulations 121.2514 for Resinous and Polymeric Coatings and by reference in 5 121.2526 for Components of Paper and Paperboard and in S 121.2550 for Components of Closures. Properties of BAKELITE Vinyl Solution Resin VYNS Properties Testing Methods Required Values Appearance Size, per cent by weight through a No. 20 USBS Sieve Heating Loss, 45 minutes at 105C., per cent by weight Poly(vinyl chloride), per cent by weight Inherent Viscosity at 30"C., CL2 g. in cyclohexanone Solution Properties, 17?6 solution of resin In 70:30 MEK:Toluene Viscosity at 25*C., cps. Color:% light transmission 475 my/600 im^ Turbidity: light transmission 600 mu, per cent Visual WC-7-F WC-160-H WC-294-B D 1243 WC-31-W WC-5K-2 WC-5K-2 White powder 98, minimum 1.5, maximum 88.5 - 90.5 0.72 - 0.75 200 - 400 80, minimum 85. minimum November, 1973 F-44632 BAKELITE and UNION CARBIDE are registered trade marks of Union Carbide Corporation. U.S.A. * ucc 062934 This Information Is not to be taken os warranty or representation for which wt mutnt |*gs( responsibility nor os permission or tocomrendition to predict ony patented invention without e license. It Is offered solely tor your consideration, investigation end verification. UNION CARBIDE CORPORATION 270 PARK AVENUE. NEW YORK. N.Y. 10017 TEST METHODS Tests are made in accordance with current issues of the ASTM or UNION CARBIDE (VO testing methods designated. The former can be obtained from the American Society for Testing and Materials, Philadelphia, Pa., while the latter are available from Union Carbide Corporation upon request. LABELING All containers of BAKELITE Vinyl Solution Resin VYNS are plainly marked with the product nomenclature, blend number, and net weight. Shipments will be so addressed as to provide complete delivery to the purchaser. SHIPPING AND STORAGE BAKELITE Vinyl Solution Resin VYNS is a stable material when kept in closed containers stored in a cool dry place. PRECAUTIONARY LABELING On the basis of the toxicological, physical, and chemical properties of BAKELITE Vinyl Solution Resin VYNS, precautionary labeling used on the containers is as follows: FOR INDUSTRY USE ONLY / T-44632 .11/73-4M ucqc 062935 Printed in U.S.A. BAKELITE VYNW-5 is a vinyl chloride-low vinyl acetate copolymer blottertype resin. By reason of its mode of manufacture, it has an open-type particle resulting in low bulk density. APPLICATIONS BAKELITE Vinyl Chloride-Acetate Copolymer Resin VYNW-5 is manufactured without suspending agents, catalysts, etc., and, therefore, is suited to the most demanding applications requiring purity of ingredients. Because of its extremely high plasticizer absorption, it is used as a blending resin where such properties aid processing. Properties of BAKELITE Vinyl Chloride-Acetate Resin VYNW-5 Property Size, per cent by weight through USBS sieve No. 40 No. 80 Heating Loss, per cent by weight. 45 minutes at 105cC. Polyvinyl Chloride, per cent by weight Foreign Matter, slurry Inherent Viscosity, 0.2 g. of resin/100 ml. of cyclohexanone at 30C. Hard Resin Particles, per ft.2 Plasticizer Absorption, per cent by weight Apparent Density of Powdered Resin, lb./ft.3 Testing Methods WC-7-F WC-160-H WC-294-A WC-15-P-1 D 2857 WC-15-K-2 D 1755 WC-2-B D 1895 Typical Value 99 96 1.0 97.5 2 1.07 2 175 18.5 December, 1976 F-4338QA BAKELITE and UNION CARBIDE are registered trade marks of Union Carbide Corporation, U.S.A. Thi iMo'mttion It not to bt t wcrrcnty *r foPr***t*tiQn for which w* ottum* ltgf rtiponiibility nor m pcrmtoion *r rocom mcridttior* to predict ony p*t*ni*d inv*ntn without 0 lietnit. It i otOltly lor your cent'Ot'otion, inv*tT0dtOri,tnd wtrilicttibn. UNION CARBIDE CORPORATION 270 PARK AVENUE, NEW YORK. N.Y. 10017 ^ O TEST METHODS Designated tests are made in accordance with current issues of ASTM or UNION CARBIDE (WC) Testing Methods. The former may be obtained from the American Society for Testing and Materials, Philadelphia, Pennsylvania 19103, while the latter are available from Union Carbide Corporation upon request. PACKAGING AND LABELING The standard package for BAKELITE Vinyl Chloride-Acetate Resin VYNW-5 is a four-ply multiwall Kraft paper bag containing 40 lb. net. If desired, this resin can also be supplied in hopper cars containing approximately 75,000 lb. The package will be plainly marked with the product and lot numbers and the quantity. Shipments will be properly addressed to assure complete delivery to the purchaser. PRECAUTIONARY LABELING On the basis of the toxicological, physical, and chemical properties of BAKELITE Vinyl Chloride-Acetate Resin VYNK-5, precautionary labeling used on the containers is as follows: FOR INDUSTRY USE ONLY MEED ' OTHER UNION CARBIDE* PRODUCTS--SERVICES? CALL Tht Nll'dl CDffk0r.lt l.fprinilieA Ctnttr MtoYart---- iriJISSt-JHl Cfcicieo............131}) 4M 2072 Moution ......... (701*71-1000 lone lun . . . (71)1 4K-1721 F-43380A 12/76 - 5M Printed in U.S.A