Document oe2mQzN0jQwX8QNkxwx4q3MGg

STANDARD GUIDELINES FOR DEVELOPMENT OF DATA BY INDIVIDUAL COMPANIES ON THE ECONOMIC IMPACT OF THE OSHA GENERIC CARCINOGEN PROPOSAL @ Me A _ <Qfj I/O ajd.. j). C.. /&/7/7 7 Prepared for: Industry Task Force on OSHA Generic Carcinogen Proposal November 1977 Prepared by: Booz, Allen & Hamilton Inc. Foster D. Snell Division 66 Hanover Road Florham Park, New Jersey 07932 AP00048303 TABLE OF CONTENTS SECTION I II III IV TITLE INTRODUCTION GENERAL INSTRUCTIONS KEY PROVISIONS OF THE PROPOSAL THAT AFFECT DIRECT COSTS SPECIFIC INSTRUCTIONS TO COMPLETE FORMS A. DESCRIPTION OF FORMS TO BE COMPLETED BY YOUR COMPANY B. NONENGINEERING COST CONTROL CALCULATION GUIDELINES C. ENGINEERING COST CONTROL CALCULATION GUIDELINES D. ADDITIONAL ECONOMIC EFFECT GUIDELINES PAGE 2 5 8 11 11 12 14 16 APPENDIX A APPENDIX B APPENDIX C ECONOMICALLY SIGNIFICANT SUSBTANCES LISTED IN NIOSH LIST SUSPECTED CARCINOGENS SUGGESTED OUTLINE FOR INDIVIDUAL COMPANY COMMENTS OR TESTIMONY ON THE OSHA GENERIC CARCINOGEN PROPOSAL FOCUSING PRIMARILY ON ECONOMICS FORMS FOR CALCULATION AND REPORTING A-l B-l C-l * ** * If further information or clarification is desired on any facet of these forms, contact one of the following Booz, Allen people. Contact Business Phone Extension Ronald Kensicki 201/377-6700 260 Ronald Rubin 201/377-6700 283 Philip Gisser 201/377-6700 205 AP00048304 I* INTRODUCTION Purpose A broad-based industry committee was formed to address the scientific, legal and economic questions raised by regulations proposed by the Occupational Safety 6 Health Administration (OSHA) for the identification, classification and regulation of suspect carcinogens (cancer causing substances), hereinafter described as OSHA Generic Carcinogen Proposal, It has re tained Booz, Allen 1 Hamilton, Foster D. Snell Division, to prepare these Guidelines and the enclosed forms. i The principal purpose of thgqe materials is to assist you -in-analyzing the economic ^ impact of the USha proposal on your company or on products you make or use'.' The attached 1 imaterials are designed to facilitate your understanding of the OSHA proposal and focus you thinking on economic impact. You are urged to prepare and file comments with OSKA and/or to participate in. the public hearing scheduled for the proposal using the enclosed materials as guides. Experience has shown that sound economic arguments, particularly \ for smaller businesses, can significantly impact agency decision. The industry committee has also asked Boot Allen to prepare a broader economic Impact ^ analysis of the OSHA proposal. If you would like to cooperate m this effort , "the enclosed I roiffiis Shddia"De completed and photocopies sent to Boot, Allen on a confidential basis, by early December. 1 ^ Background On OSHA Proposal In the Federal Register of October 4, 1977 (42 Fed. Reg. 54147), OSHA published its Generic Carcinogen Proposal. Abandoning its previous substance-by-substance approach to regulating chemical substances in the work place, OSHA, through these regulations, proposes to establish a vehicle and framework for future rulemakings which will enable it to move expeditiously. The regulations set forth criteria for determining whether a substance is a carcinogen, establish a classification scheme for suspect and known carcinogens and require certain regulatory actions to be taken following such classification. There are attached to the proposed regulations model standards to be used by OSHA as essentially fill-in-the-blank modules for standards on individual substances. Once adopted, the proposed regulations should lead to a flurry of regulatory activity, the focus of which will probably be a List of Suspect Carcinogens published by the National Institute for Occupational Safety and Health (NIOSH), numbering in excess of 2400 substances, and which has been growing at the rate of 100 substances a month. The regulations represent OSHA's proposed resolution of many complex scientific and legal issues. Once resolved in this rulemaking, those issues may not be open to further question in subsequent rulemakings on individual substances. The criteria, classification scheme, and regulatory consequences in this proposal will apply to all subsequent OSHA rulemakings on suspect carcinogens. Indeed, given recent public pronounce ments on the need for cooperation and harmonious policies between federal agencies on toxic substances, the OSHA proposal may well form the basis for a national approach to similar regulations for all federal agencies. * The proposed regulations will establish criteria for classifying substances and require regulatory consequences to flow automatically therefrom. The proposal authorizes OSHA to ban substances where there are "suitable1' substitutes and to require that exposure be reduced to the "lowest level feasible." These two terms are not defined by OSHA. While the industry committee recognizes its collective and individual responsibility to provide workers with a safe workplace free from recognized hazards, particularly known carcinogens, it believes that the OSHA proposal might result in the improper classification of a substantial number of substances and that tha proposal's economic costs might be out of proportion to its possible benefits. Participation In Rulemaking Written comments to OSKA are due January 9, 1978. Persons who intend to appear at the public hearing on the proposal, scheduled to commence on March 14, 1978, are required to file a notice of intent to appear, and, if they expect to testify for more than 15 minutes, file their full testimony by January 9, 1978. Although you should make every effort to meet these deadlines, we believe, although OSHA has not so stated, that it may decide not to exclude late submissions from its rulemaking record.TO Written comments should be submitted in quadruplicate to: Docket office Docket No. H-090 Room S-G212 U.S Department of Labor 3rd Street 6 Constitution Washington, D.C. 20210 Avenue NW TO The due date for written comment.3 and notices' of inte'ht to appear noted in the Federal Register of October 4 has been extended from December 9, 1977 to January 9, 197B. -2- AP00048305 Notice of intent to appear at the hearing and testimony should be submitted (in quadruplicate) to: OSHA Office of Consumer Affairs Room N 3633 U.S. Department of Labor 3rd Street & Constitution Ave. nw Washington, D.C. 20210 How To Use This Document For Use By Your Company In Preparing Written Comments and/or Testimony You will save time in this endeavor by following the steps described below. . Make copies of the forms in Appendix C, and keep a clear original. You may need multiple copies of some sections. . Select as many chemicals as you feel you can analyze for internal case study from the ninety-nine chemicals listed with their alternate names in Appendix A. These chemicals, all of which appear on the NIOSH List of Suspect Carcinogens, ^ are ones Booz Allen believes to be economically significant. There may be other chemicals on the NIOSK list which are not listed in Appendix A but which may be significant to your company. You should, therefore, carefully review the NIOSH list. . Fill out this set of forms for each substance selected, if two of the substances are encountered in the same plant unit, one set of forms is sufficient. . Aggregate the total compliance costs for each case study substance, as shown on Form VI. The ratio of compliance coats to current costs, as well as the other ratios indicated, can be presented in your submission. . Submit written comments for the record (due January 9, 1978) . . If you intend to testify at the public hearing, notify OSHA of your intent to testify (due January 9, 1978). . If you intend to testify at the public hearing fox more than 15 minutes, file full testimony (due January 9, 1978). . Testify at public hearing commencing March 14, 1977. Retain file copies of all information collected and submissions made. If You Elect To Participate In The Broader Impact Study By Booz, Allen If you elect to cooperate with the Booz, Allen study, please follow the procedure outlined below: . Select two or three dissimilar case study substances for analysis at your company. . Inform either R. Kensicki or P. Gisser (201-377-6700, extension 260). at Booz, Allen that you are planning to analyze selected case study substances at your company. . Assign one individual responsible for getting the data and returning it. He will probably need the cooperation of plant and engineering people. For chemical producers, marketing people might provide some necessary inputs. U.S. Department of Health Education and we1fa re Suspected Carcinogens, A Subfile of the NlOSH Registry Of Toxic Effaces Of Chemioal~lTubstances, TndEdition, Washington, D.C. U. S. Government Printing Office, December 1976, HEW Publication Number (NIOSH) 77-149. -3 - AP00048306 Make copies of the forms and keep a clean original, will probably need extra copies for some sections. you Identify the plant units in which you make or use any of your selected case study chemicals. Fill out forms for each plant unit identified. Return these forms by early December 1977, to: Foster D. Snell, Division Booz, Allen & Hamilton Inc. 66 Hanover Road Florhara Park, Hew Jersey 07932 Attention: Mr. R. Kensicki The information returned will, of course, be analysed confidentially by Booz, Allen Hamilton Inc. Details of the confidentiality procedures follow; . All information will be confidential and access will be limited within Booz, Allen and Hamilton Inc., on a need-to-know basis. . Only one page carries company identification. This page will be separated from the rest and kept in a locked file for use only by authorized personnel if follow-up is needed for clarification. . The other pages will be assigned identification numbers. Personnel involved in data processing and analysis work will have access only to those numbers. . The final report will not attribute information to a specific company or identify any individual source without the company1s authorization. . The original records will be returned to you when the report is completed, and no copies will be retained. -4 - AP00048307 II. GENERAL IKS'!RUCTIONS The forms in this package refer to the cost of compliance with OSHA's Identification, Claasification and Regulation of Toxic Substances Posing a Potential Carcinogenic Risk. ~This form is organized to collect economic cTata for each of the products manufactured at your plants that may potentially be affected by the proposed regulation of substances. Substances for case study should be selected by your company from the followings i . Economically Significant List -- In Appendix A substances are listed that are on the NIOSH Suspected Carcinogens list and judged to be economically significant on the basis of total U.S. production and the number of total employees associated with their manufacture or use or both, your company may wish to select applicable substances from this list and present one or more case studies. Other Substances -- In the NIOSH publication Suspected Carcinogens, 1976, over. 240D substances are listed that may be regulated under-the proposed act. There may be other substances not listed in the NIOSH document that your company may want to study* The manufacture and use of these substances may have specific impact on your company. For each of the case studies selected, one set of forms should be completed for each production plant at your company that is associated with the substance under study. The substance may be: . Manufactured at the plant (e.g., as a product, by-product or co-product) . Used at the plant (o.g., as a raw material) . Present as in-process material (e.g., as a solvent, formulation or impurity) . Handled for wholesale or retail distribution. Therefore, your company may complete more than one set of forma depending on the number of plants that are associated with the case study substance* For example: . Only one Bet of forms may be required for a case study substance if it is used, manufactured, present or handled at only one plant site of your company . More than one set of forms may be required for a case study substance if it is used, manufactured, present or handLed at more than one plant site. Cost information will be determined on a plant-by-plant basis for each substance selected for a case study. If more than one substance is present at each plant that may potentially be regulated: . do not allocate separate compliance costs to each of the various substances present. . Assume that the compliance cost required will be the effect of all substances at the plant unit potentially regulated. . Do not complete a separate set of forms for each substance present at a plant unit, since this would result in double counting. OSHA's proposed regulation and these forms cover each of the substances that may be classified by OSHA under Category I or Category II. The four categories established by OSHA are: . Category I - Confirmed Carcinogens . Category II - Suspect Carcinogens . Category III - Substance for Which There Is Insufficient Information to Reach a Conclusion on Carcinogenicity . Category IV - Substances of Carcinogenic Potential Not Found in the American Workplace. - 5- AP00048308 To avoid prejudging the results of future oncological testing, the cost analysis Is evaluated at two assumed levels: . Assumption I - Assume that the case study substances will be classified as a Category I substance Assumption II - Assume that the case study substances will be classi fied as a Category II substances. The compliance costs calculations are similar for Category I and Category II* substances except for: . Engineering controls Category I substances will require employers to provide engineering controls to reduce exposure to the "lowest level feasible" (refer to No. 6, below) Category II substances are assumed for purposes of this study not to require engineering controls expenditures. d) . Segregation of Work Area Category I substances will require employers to segregate work areas of the plant in which Category I substances are present. Category II substances will not require segrega tion of the work area. . Lunchroom Facilities - Category I substances will require employers to provide lunchroom facilities that have a controlled temperature, positive pressure and filtered air supply whenever food or beverages are consumed in the workplace. - Category II substances require appropriate facili ties for eating and drinking. Therefore, no capital cose expenditure should have to be applied. 6. The proposed OSHA regulation requires that engineering controls be provided to reduce exposure to the "lowest level feasible." OSHA does not define the "lowest level feasible." Depending on the definition, the coat of engineering , controls may vary dramatically. Therefore, the cost of engineering controls should be calculated at three assumed levels. These assumed levels selected for the case studies were chosen to provide a range of possible standards; they do not directly reflect the level that OSHA may establish for a case study sub stance and they do not imply that these levels are technically feasible. The three assumed permissible exposure levels (PEL) for the case studv substances differ depending on the form of the substance. . For liquid or gaseous substances, the engineering controls should be est iraaee(T"at the following three PEL levels: - 10 parts per million - 1 part per million - 10 parts per billion . For solid substances, the engineering controls should be estimated at the following three PEL levels: - 100 micrograms per cubic meter of air (0.1 milligrams) - 10 micrograms per cubic meter of air - 1 microgram per cubic meter of air There are certain situations where capital coat expenditures can be called for under the proposed act. For example: If it is currently not feasible to meet an existing permissible exposure level (PEL) and your company uses respirators for compliance, engineering controls will be required to reduce exposure to the lowest level feasible, while still requiring use of respirators. Or, if the substance is not now covered by a PEL, it can be under this regulation. If these situations apply to your company, you nay want to address them in your submission. -6- AP00048309 This form establishes a standardized basis for estimating compliance cost and other economic effects. The cost data are "differential" cost information -- the Added cost of compliance over and above the cost of compliance with existing regulations. The cost of compliance should be consistent in terms of 1977 dollars. The compliance costs should assume no change in demand for the primary product. Therefore, compliance costs shall be determined at: 1976 production output . 1976 employment. The compliance costs should assume normal operations and not take into account other factors, such as changes in prices and availability. -7- AP000483I0 Ill, KEY PROVISIONS DF THE PROPOSAL THAT AFFECT DIRECT COSTS (The provisions presented apply to substances that are classified as Category I or II unless specifically noted.) Monitoring . The employer must determine the employee exposure to the toxic substance over an eight-hour period without regard to the use of respirators. Initial Monitoring shall be performed for each workplace and work operation to accurately determine the airborne concentrations to which employees may be exposed. . If the employee exposure is above the permissible exposure limits (PEL), these monitoring determinations shall be repeated at least monthly. Monthly determinations shall continue until at least two conseoutive measurements are below the PELj there after, monitoring shall be performed quarterly. . Monitoring shall be performed at least quarterly in work areas below the PEL. . Additional monitoring shall be performed wherever there has been a production, process, control or personnel change which may result in new or additional exposure, or wherever the employer has reason to suspect a change may result in new or additional exposure. . The opportunity of employee observation of monitoring exposure shall be provided to affected employees or their designated representatives. Medical Surveillance A medical surveillance program shall be instituted for each employee who is or will be exposed to the regulated substance. . An initial examination shall be provided for each employee at the time of initial assignment or upon institution of the program. . Periodic examinations shall be provided for all exposed employees. The frequency and nature of the examination will be specific to the regulated substance. . Additional examinations will be provided if signs or symptoms commonly associated with exposure occur. Sanitation Facilities, Emergency Plans, Posting and Labeling (Requirements for Category jE Substances Only) . Regulated areas shall be established where concentrations of Category I substances are in excess of the PEL. - These areas shall be demarcated and segregated from the rest of the workplace. Area access shall be limited to authorized persons. - Food, beverages or smoking products shall not be present or consumed in the area. . whenever food or beverages are consumed in the workplaco, the employer shall provide lunchroom facilities that have a temperature controlled,* positive pressure, filtered air supply and that are readily accessible to employees. -6- AP0004831I (Requirements for Category and II Substances> Emergency plans shall be developed for each workplace where the regulated substance Is present. They shall include: - Provisions for respiratory protection of employees engaged in correcting emergency conditions Means for alerting employees of high concentration levels. i . Clean change rooms and showers shall be provided. Exposed employees shall shower at the end of the workshift. Signs shall be posted to indicate clearly all workplaces where the regulated substances may be present. - Where airborne concentrations are above the PEL, signs shall additionally bear "Respirator Required" legend. Precautionary labels must be affixed to all containers and products containing trie regulated substances. Personal Protective Equipment Respirators shall be used to reduce employee exposure to within the PEL and during emergencies. Protective clothing and equipment required by the Act shall be cleaned, iaunderedT maintained or replaced at no cost to the employee. Employee Training Training programs shall be provided at the time of the initial assign ment and annually thereafter. Recordkeaping Exposure monitoring records shall be kept for a minimum of 40 years. They shall include: Results and comprehensive description of monitoring per formed to determine representative employee exposure Description of the sampling and analytical methods used Description of type of respirator protection worn Identification of all other employees whose exposure the measurement is intended to represent. Medical surveillance records shall be kept for a minimum of 40 yearsThey shall include: - Physician's written opinions -- Employee complaints relating to exposure A copy of information that must be provided to the examining physician. This includes: .. Description of duties of affected employee as they relate to exposure .. The employee's anticipated or expected exposure {preplacement and emergency] .. Description of personal protective equipment to be used ., Employee's work history. - 9- AP00048312 Engineering Controls Engineering and Work Practice Controls shall be instituted to reduce or maintain employee exposures to or below the PEL, except to the extent the employer establishes that controls are not feasible. In the event the PEL cannot be attained, the employer shall reduce exposures to the lowest level achievable and supplement the controls with use of respiratory protection. . A written Compliance Program shall be established and implemented at or below the PEL solely by means of engineering and work practice controls, 'it shall include: Process or operation descriptions - Engineering plans to determine controls - Report of technology considered - Detailed schedule of implementation (to be updated every six months). - 10 - AP00048313 IV. SPECIFIC INSTRUCTIONS TO COMPLETE FORMS IV A. Description of Forma To Be Completed By Your Company There are eight basic forms enclosed in this package. The completion of these forms will serve as a basis for estimating the economic impact of the proposed oska carcinogen standard. Rather than to prejudge future oncological testing or "safe" employee exposure levels, there are four levels for which direct costs will be estimated by these forms for each case study substance. These levels correspond to the following assumptions: . Case study substance is classified as a Category II substance and the PEL established will not require additional engineering controls. . , Case study substance is classified as a Category I substance and the PEL established is 10 ppm for liquids and gases, or 100 micrograms per cubic meter of air for solids. . Case study substance is classified as a Category I substance and the PEL established is 1 ppm for liquids and gases, or 10 micrograms per cubic meter of air for solids. . Case study substance is classified as a Category I substance and the PEL established is 10 ppb for liquid and gases, or 1 microgram per cubic meter of air for solids. Each of these forms is described below: FORM I- COMPANY IDENTIFICATION Fill out this form once for your company. Its primary purpose is to identify a contact so to provide an opportunity for clarification of data if your company elects to send the completed forms to aooz, Allen. This sheet, the only one that identifies your company, will be assigned a key number, which will also Identify the accompanying pages. It will be kept in a locked file with access limited at all times. FORM II- STATISTICAL DATA Fill out this form for each piantunit of--your company that is associated with the selected case study substance. If you elect to return it to Boos Allen, its primary purpose is to provide scale-up data. In the upper right hand side of the form , assign a plant unit number and identify the case study substance. FORM III- NONENCINEERING COMPLIANCE COST WORKSHEET Fill out this page tor each plant unit identified by Form XI. This form is used to estimate the nonengineering compliance cost for that plant unit. When completing this form refer to the Nonengineering Control Cost Calculations Guidelines on page 12 of the instructions. FORM IV- ENGINEERING CONTROL COST WORKSHEET Fill out this form for each plant unit identified by Form II. This form is used to estimate the engineering compliance costs at three assumed PEL levels for that plant unit. When completing this form refer to the Engineering control Cost Calculation Guidelines on page 14 of the instructions. FORM V- SUMMARY DATA-- DIRECT COSTS AT PLANT UNIT LEVEL Fill out this form for each plant unit-identified by Form II. Tills form summarizes the direct costs for that plant unit for the selected ease study substance. FORM VI- SUMMARY DATA-- RELATIVE COST CHANCES Fill out this form once for each case study substance, ft 'should be filled out after the- individual case studies by your company have been consolidated. FORM VII- ADDITIONAL ECONOMIC EFFECTS-- PRODUCTS Fill out this formfor the plant unit only if tha case study substance is produced or formulated at the plant unit. This form is used to identify the indirect economic effects of the proposed regulations. When completing this form, refer to the Additional Economic Guidelines on page 16 of the instructions. FORM VIII- ADDITIONAL ECONOMIC EFFECTS-- RAW MATERIALS Fill out this form for the plant unit only if the case study substance is purchased or used at the plant unit. This form is used to estimate the indirect economic effects for users. When completing this form, refer to the Additional Economic Guide lines on page 16 of the instructions. - 11 - AP00048314 IV. a. Monengineering Control Coat Calculation Guidelines (For Use with Form tip For many of the provisions of the proposed OSHA regulation, a simplified cost calculation method has been developed to assist your company in completing this questionnaire in a timely manner. ' However, some of the provisions of the regulation, such as engineering controls and sanitation facilities, require a knowledge of current facilities and estimates must be made by your company. Listed below are the simplified cost calculations for nonengineering control type cost elements. Each of the cost elements correspond to the direct cost calculation questionnaires presented on Form III. The following are symbols denoted in the cost calculations presented below: N = number of exposed employees (as determined in Form II) n= number of employees currently covered by similar programs W = number of work areas at the plant unit Initial Monitoring Cost No capital cost No annual operating cost Differential first-year operating cost $(10 N + Exposure Monitoring Cost No capital cost Annual operating cost -- $67 N Differential first-year operating cost $45 N Medical Surveillance Coat No capital cost . Annual operating cost = $155 (N - n) No differential first-year operating coat 4. Change Rooms and Showers . Capital and annual operating costs to be estimated by your company . No differential first-year operating cost 5. Emergency Alarms . Capital cost to be estimated by your company . Annual operating cost to be estimated by your company . No differential first-year operating cost 6. Respirators . No capital cost . Annual operating cost $25 N less current operating costs . Differential first-year operating cost * (Number of additional respirators purchased) X (cost per respirator) 7. Personal Protection Equipment . No capital cost . Annual operating cost * ?343N less current operating cost . Differential first-year operating cost to be estimated by your company includes purchase of uniforms, gloves, aprons, faceshields and goggles where required. TTJ Although a number of these costs might be treated as capital costs, these cost calculation guidelines treat most of these expenditures as expense items-. - 12 - AP00048315 8. Signs . Mo capital and annual operation costs . Differential first-year operating cost $ BO W 9. Emergency Plan . No capital and annual operating costs . , Differential first-year operating cost * ? 400 W 10. Recordkeeping Cost , No capital cost . Annual operating cost $15 N . Differential first-year operating costs $200 w 11. Training Program Cost . No capital cost . Annual operating cost $(160 + 15 N) . Differential first-year operating cost " $200 13. Segregation of Work Areas (Category I assumption only) . Capital costs must be estimated at the plant level for work areas. . Annual operating cost to be estimated by your company. . No differential first-year operating cost. 14. Lunchroom Facilities (Category I assumption only) . Capital costs must be estimated at the plant level for work areas. . Annual operating cost to be estimated by your company. . No differential first-year operating cost. - 13 - AP00048316 IV. c. Enaineerinq Control'cost Calculation Guidelines (For Vse With Form IV) " The key provisions of the proposed act call fox engineering controls to play the major role in reducing employee substance exposure. For purposes of this study, we have assumed control costs will only be required 1 for areas where the case study substance is evaluated as a Category I substance. Engineering control costs required for Category I will depend on the PEL level that is established for that substance. For purposes of economic analysts, we have designated several assumed levels for which engineering controls should be estimated. These levels were selected arbitrarily to provide several levels at which engineering controls could be evaluated. For substances that are in liquid or vapor form, engineering controls will be evaluated at the following three assumed PEL levels: .. 10 parts per million .. I part per million .. 10 parts per billion - For solid substances, engineering controls will be estimated at the following three assumed PEL levels: .. 100 micrograms per cubic meter of air .. 10 micrograms per cubic meter of air .. 1 microgram per cubic meter of air The capital cost calculations for each of the types of control should reflect a total project cost in 1977 dollars. Elements usually included are: Engineering - Design Materials - Equipment Construction - Contingency (to be applied as 10 percent of all costs above). The costs for typical investment items as presented on the next page reflect total project cost and if applied should not be altered to include additional project cost factors. If it is determined that in order to achieve one of the designated PEL levels, a new facility would be needed for economic or technological reasons, then the engineering control capital cost should be estimated as the cost of an equivalent new facility (same production capacity): The capital cost should be the cost of a new facility less the salvage value (or plus the demolition cost). The annual operating cost should be the differential cost of the new facility operating cost minus the existing facility operat ing cost (do not include depreciation). The differential first year costs should include start-up costs. Total engineering costs to meet the assumed PEL level must be estimated by your company. However, to assist your analysis, the following is a list of control techniques that are typically used to control exposure levels. Vapor Particulates Process change Ventilation . Storage tank vapor control Mechanical seals for pumping equipment Liquid level alarms Rupture discs for relief valves Closed loop sampling systems - Process change Ventilation Enclosures of equipment or process Washing or decontamination systems Conveying systems Leak proofing Clean up equipment The remainder of this section briefly describes the control techniques above and provides some typical costs which you may use as guides, exclusive of factors for piping, instrumentation, excavation, grading, utilities, etc. AP00048317 Process Change If process change is selected as the method af reducing substance exposure, the capital cost requirement must be determined solely for the individual process or operation. Ventilation Ventilation systems can be designed to control either the local area or a1 general area. The cost is also dependent on the specified air flow rate. Storage Tank Vapor Control Floating roof tanks, indirect combustion, activated carbon adsorption and vapor containment systems are commonly applied to control storage tank vapors. Floating roof tanks are usually more cost effective than other control tech nologies to control storage tank vapors. Mechanical Seals For Pumping Equipment Pumps that currently have packed seals can be changed to mechanical seals. The control cost per pump is normally $5,000 to $10,000. closed Loop Sampling System The installation of closed loop sampling systems will reduce employee exposure to liquid vapors during process sampling. The estimated cost for fabrication of such a system is estimated to be $500 per sampling location. Liquid Level Alarms Storage and process vessels should be equipped with high liquid level alarms to reduce the potential of overflow. The estimated cost to equip existing tanks with liquid level alarms Is $3,000 per tank. Rupture Disks Rupture disks are used to reduce leakage associated with poor sealing of relief valves. The estimated cost is $1,000 per relief valve. Enclosures of Equipment or Processes These systems consist of complete enclosure of equipment and processes using impermeable barriers. They are usually accompanied by exhaust ventilation and material collection systems. Washing or Decontamination Systems These systems are used in handling and storage areas to reduce exposure to particulate substances that adhere to exteriors of storage containers. Contami nated washings handling equipment costs should be included in these systems. Clean-Up Equipment Generally consists of vacuum equipment to prevent particulate accumulation. Conveying Systems These systems are required to transport particulate substances instead of manual handling. They are generally enclosed. Leak Proofing This is done in existing doors, enclosures and ventilation systems whenever necessary. Cost to be estimated by your company. - 15 - AP00048318 IV D. Additional Economic Effect Guidelines {For Use With Form VII h Form VIII> The requirements of the OSKA Carcinogen. Standard may result in effects on your business in addition to direct quantifiable coats. Some of these are: . Regulated substitution of raw materials. The proposal authorized OSHA to require for Category I substances "no 'occupational exposure," if it determines that there is a less hazardous suitable substitute. This may, in effect, amount to a ban on a substance for some or all applications. . Voluntary substitution of raw materials for a variety of reasons: - To avoid complexity of handling regulated materials. To avoid potential liability effects. To avoid higher-cost regulated materials. . Changes in sales levels for a variety of reasons: Substitution to avoid handling of products labeled "carcinogens.: Reduction in purchase because of higher price. Effect of a potential ban on the substance in the workplace. - Loss of sales to nonregulated foreign producers. . Loss of jobs because of sales reduction or plant closings. . Changes In productivity because of manpower requirement shifts, m change in production capacity or change in demand. . Business closings because of higher operating cost, higher raw material prices or product bans, especially as they might effect small businesses. . Changes in price because of changes in cost or demand. These issues are addressed on Forms VII and VIII. They may not all be significant for a single company but those that do apply should be addressed. They may well be significant from an overall industry point of view. Many of these areas call for subjective judgment and projections of what is likely to happen. It is important to be realistic in those assessments. Any exaggerations in this area would throw doubt on the credibility of the entire effort. Questions in this area are divided into two pages: . Form VII is to be filled out if the plant unit produces the particular case-study substance. Much of the material can be better provided if marketing people are involved in filling out this page. . Form vrn is to be filled out if the plant purchases, uses, or in another way encounters the case-study substance in the plant unit. Either one or the other, in general, should be filled out for each case-study sub stance encountered in the plant unit. Formulators should fill out both. For the survey, any areas that are not applicable should be marked, "not applicable." AP00048319 APPENDIX A ECONOMICALLY SIGNIFICANT SUBSTANCES LISTED IN NIOSH SUSPECTED CARCINOGENS, SECOND EDITION APPENDIX B SUGGESTED OUTLINE FOR INDIVIDUAL COMPANY COMMENTS OR TESTIMONY ON THE OSHA GENERIC CARCINOGEN PROPOSAL FOCUSING PRIMARILY ON ECONOMICS AP00048320 APPENDIX A ECCNQMICALLiT SIGNIFICANT SUBSTANCES LISTED IN NIOSH SUSPECTED CARCINOGENS, SECOND EDITION. (o} NIOSH NUMBER^ MAME^ NIOSH NUMBER^ NAME(b) MG21000 ACETIC ACID, (2-BUHNYLXDENE) - AF85750 AH52500 AI5250D AL31500 ACETIC ACID, CHLORO- ACETIC ACID, ETTHYLEJEDINITRILOTETTFA-, TRISODIUM SALT ACETIC ACID, LEAD (2+) SALT AL2JICNE EL64750 AS10500 ATS2500 ACEOTJE, METHYLACROLEIN ACRYLCNITRIIE JW52500 AS1050D DG19250 BW6S500 CG19250 KJ57750 f47250 ALLTOX ALLYL ALDEHYDE AMUJEN AM32C8EN2EME 3-AMINO-2,5-DICHECfCBENZOIC ACID 2-AMINGETHAiJOL AMTNOFOPM SW66500 AKENOPHEH XS9S250 3-AMINO-p-TOLUIDINE BW66500 ANZLINE SE73500 * ASPHALT (STEAM REFINED) XY56000 ATPANEX XY5600Q ATRAZINE OF99000 KVO3S00 OF98000 CY14000 BW66500 AUSTRIAN CINNABAR BAXELTXE BASIC LEAD CKRCWATE BENZENE BENZENE, AMINO CZ10500 TI3L500 CZ45000 CZ45500 BENZENE, 1-CNIOEO-4-NITBO 1,2-BENZENEDTCAF30XYLIC ACID ANHYDRIDE BENZENE, O-DICHLOEOBENZENE, p-DICHLORO DAQ7000 XS52500 DA64750 BENZENE, ETHYLBENZENE, METHYLBENZENE, NITRO WL36750 BENZENE, VINYL- DG13250 XS89250 DS14000 C617500 DS23DOO DS40250 LP89250 G078750 DU80500 DU30500 VMS4000 ED45500 PA49000 KJ85750 EL64750 KJ85750 (3078750 KJ85750 KJ35750 KJ85750 EU98000 EV01750 EV19250 EV27000 EV31500 XR22750 M452500 EY26250 PC59500 AT52500 OP07000 ZH33250 FC59500 BENZOIC ACID, 3-AMINO-2,5-DICHL3RO BENZYL CHLORIDE BERYL BERYLLIUM BEBYLLltK FLUORIDE BEKYTXH.M OXIDE BFV BHP BIBENZENE BIPHENYL S-l,2-BIS(ETKOXYCAPBONYL)ETHYL-0,0DIMETHYL TKTOPHOSPHATE BORIC ACID BFCMDMETHANE BUCS 2-BOTANCNE 2-BCJTOXYETHANOL butylwed hydroxytoluene BUTYL CELL06OLV3 O-BUTYL ETHYLENE GLYCOL BUTYL GLYCOL CADMIUM CADMIUM CHLORITE CADMIUM OXIDE CADMIUM SULFATE (1:1) CADMHI1 SULFIDE CALCOTCN5 5SHITS T CAMPHECKLOR epailon-CAPROLACIAM POLYMER CAPRCON CARBACRYL CARBAMIC ACID, ETIHYLENEBIS(DITHIO)-, tRNGANESE SALT CAFBAMIC ACID, ETHYLENE3IS (DITHIO) -, ZINC SALT CAFSAJCC ACID, METHYL-, NAPOTHYL ESTER Al AP00048321 APPENDIX A ECCMOCCCAm; SIGJIFICANT SUBSTANCES LlgTSD IN NIOSH SUSPECTED CARCINOGENS, SECOND EDITION. NIOSH NlMBSR(a) NAMBfo* NIOSH NUMBER^*) NAMECb) YH6250O FC59500 VJM84000 WM84000 SJ33250 FF66500 KX38500 E76650O FF6650O FG49000 YR62500 QR59500 WM84000 PJ59500 TQ350QO P059500 FJ59500 WMB4000 DG19250 XW52500 AF85750 CZ45000 AFB57S0 XY56000 KU96250 KV03500 FS91000 KJ29750 PA63000 CZ10500 SM63000 XS89250 GB29550 OF980Q0 GB27500 GB28500 CARBAMIDE CARBAKYL CARBEOTOXY MALATKICN CARBETOX s, CARBOLIC ACID CARBON BISULFIDE CARBCN DICHLORIDE CARBCN DISULFIDE CARBCN SULFIDE CARBCN TETRACHLORIDE CAICNYIDIAMINE CARBCNYL NICKEL POWDER CAFSQPHCS CARBCKYMEHWICELUJIDSE, SCOIUM SALT CARBONMC CABFOUN CELLULOSE, CAPBOXBffiTHVL ETHER, SODIUM SALT CHEMATHION CHLORAMBEN CHIORIXATED CAMPHEME attOROACCTIC ACID CHL02CBEN CHLORQETHANOIC ACID 2H3Qi3RD"4-ETHYIAMINOI^PfOPnAMINE-3-TRLAZINE CHLOROETHYIENE CHDMCriWLEWE POLYMER CHLOROFORM CHLOROFORM, METHYLCHD3R0METHANE 1KHLCRO-4-NITR06EMZEME CHLOROPHEM alpha-CHLQFOror/JDG CKROMATC OF SODA CHROME ORANGE CHROMIC ACID, CALCIUM SALT CHFGMIC ACID, CHROMIUM (3+) SALT GB29550 (42000 QR59500 81466500 WL36750 WL36750 WL36750 BW6SSOO XS96250 OFsaooo XR22750 DA647S0 XW52500 CZ45000 CY14000 V247250 WV52500 M484000 FC59500 <3078750 ATS2500 CY14000 VJMS4000 TQ79000 TX8750C CZ45000 XS96250 >596250 7N37500 (0192750 0078750 DGI9250 CZ45000 CZ4S500 PAS2000 KI05250 CHPa-OC ACID, DISODIUM SALT CHROMIUM C.I. 7775 C.I. 76000 CINNAMBE CDC4AMEM0L CTMRMX C.I. OXIDAXICN BASE 1 C.I. OJODATICN BASE 200 C.I. PIC24EJTT RED C.I. PI04EOT WHITE 6 C.I. SOLVHIT BLACK 5 CLOR CHEW T-590 CLOtCBEN COAL KAPtttKA COM-CM SALT COMPOUND 3956 COMPOUND 4049 CRAG SEVIN p-CRESOL, 2--6-DI-tert-BUTYLCYANCCIHYIFNE CraXtHECCATRIENE cmncN DAOCM Deep CCB 1,3-DLAMINO-4-METHYISENZENE 2,4 -DIAOTNOTOLUENE 1,2-DmRaD-3H2tLOKffraPANE 1,2-DIBSODSIHMffi 2,6-DI-tert-BUTYL-p-OESOL 2,5-DICHLORD-3-AMI2X3BENZOIC . O-DiaaORdBQJZENE p-DICHU3HDBBiZEME DiaCOROOimOfCflETMANE 1,2-DICHIiDROETHANE A2 AP00048322 APPENDIX A PXNCfrgCAU^ SIQJIFICAWT SUBSTANCES LISTED EM NICSH SUSPECTED CARCINOgENS, SEXXKD EDTTICH.(cl NIOSH NlE-SER`a> NASEfb) NIOSH NUMBER^ NAME(b) K105250 PAS0500 WN84000 KX24500 AL31500 TG01750 TC01750 TG01750 WZ12250 WZ12250 XT15750 XT19250 DU80500 QPQ70Q0 FF66500 WZ12250 XT15750 KJ85750 KH92750 PA4900Q PA49OQ0 SN157S0 SM63QOQ CZ45000 KX45500 TG01750 5A07000 KH92750 KIO5250 FJ59500 AK52SQ0 RIO5250 KK385Q0 F349000 5W52S90 DIQtLOEOETHYIZNE DICHmPO'ETCWE DIETHYL MBRCAPTOSU3CINATE, 0,0-DIMETHYL PHC6PHORODITHIQATE DIMETHYmiE OXIDE DIMETHYL KETCNE DIMEIHYL p-NTTPOPHENYL M3WIHICPHOSPHA1E 0,0-OIMETHYL 0"{p-NITROPHEWYL) PHOSPHOJCIHIOAIE DIMETHYL PARAIHICN DIMETHYL p-PHTHAEATE DIMETHYL TEREPHTHAIATE 2,4-DINITTOIOLUENE: 2,6-DDfITKyrOLUBE DIPHENYL DITHANE M22 DITHIOCARBCNIC ANHYDRIDE DMT 2,4-arc D3WANOL EB DOWFUME 40 D3WFUM5 M>2 DOWFUME MI-33 DOWICTDE 2S DCWICIOE G DCWIKERM E CW-TRL E 601 EB EC6 EEC EDIFAS B ECTA TPI300IUM SALT arc 1,656 E27E 1,860 WT 4,705 ENT 0,735 KH92750 KM34000 TG01750 FC59500 TX49000 TX49000 KX24500 TX29750 TI31500 XW52500 KH92750 KE05250 XI05250 KJ29750 KQ63000 KJ57750 KJ57750 KJS5750 KX45500 KQ63000 DA07000 UK82250 AS10500 CIP07000 ZH33250 KH92750 KI05250 KU962S0 KV03500 AH52500 KH92750 KI05250 KJB5750 KU96250 KX24SOO ENT 15,349 ENT 17,034 ENT 17,292 ENT 23,969 EPITKL0RHYDRIN EPIQUOBCHYDRIN 1,2-EPOXYETHANE 1,2-EPCXYPPDPANE ESEN E9TCN0X ETHANE, 1,2-DXBPCM> ETHANS DICHL0RXCG EIHANE, 1,2-DICHLOROEIHANE, l,l,l-TRICHLOK>ETHANOL EIHANOIAMINE ETHANOL, 2-AMUJOETHANOL, 2-BUTOXYETHINYL mrCKTORIDE ETHYL AICCHOL ETHYL BENZENE ETHYL CAPBINOL EHHYUNE AU3EHYDE ETHYLENEBIS (DITHIOCAPSMAIE) MANGANESE ETHYLENEBISfDITHXCQUSAMATE) ZINC ETHYLENE BPCKTDE ETHYLENE CHLORIDE ETHYLENE, CKLOROETHYLENE, CHLORO-, PCIYMER ETHYIENEDIAKINE71ETRAACETIC ACID, * TRISQOIUM SALT ETHYLENE DIBJCMTDE ETHYLENE DICHLDRIDE ETHYLENE GLYCCfc, M2NCBUTYL ETHER ETHYIfNE MIKOCHLORIEE ETHYLENE OXIDE AP00048323 APPENDIX A ECQKEIZCAXLY SimiFICAWT SUBSTANCES LISTED IN N1C6K SUSPECTED CflBCINOGglS, SEOCND EDITION.<c^ NICSH NWSER^ NAME051 NIOffl NUMBER1 ' TZ29750 KL36750 KX38500 KX3850Q KX45500 KX45500 EL64750 2H332SO NO850QO ND85000 PAB2000 WM84000 IJ>89250 LP89250 (S447250 LP89250 IP0925O PAS2000 PA820OO TX87SOO CN36750 XY56000 PAS2000 KJ85750 KH92750 KI05250 KJ85750 KQ63000 ND35000 PA82000 FG49000 PA49000 PA94500 WG21000 {N472S0 MS47250 ETHYLS4E OXIDE, METHYLETHYLENE, PHENYLETHYI2NE TETRAQCLORIDE ETHYLENE, TETRACHLOROETHYIENS TRICHLORIDE ETHYIfNE, TRICHLOIOETHYL METHYL KETONE EIHYL ZIMATE FECSCL fereoos SULFATE nJUCCOCABBCN-12 FOR-ftL FORMALDEHYDE FORMALIN FOR'IAMTNE FORMIC ACID FOFM3L FRECN-12 FRECN F-12 FU4A2CNE 2,4-FURANDIONE CEIGY 30,027 C2NETHCN 12 dYCOL BUTYL ETHER. GLYCOL DIBRCMinE GLYCOL DICHLORIDE GLYODL fCNCBOTYL ETHER GRAIN ALCOHOL GREEN VITRIOL HALCN HALCN 104 HALCN 1001 HALCN 10001 2,4-HEXADLENOIC ACID HEXABORM HEXAMETHYLSJEAMOE RN47250 W47250 >1470500 SJ33250 KJ57750 NP96250 PA94500 NOS5000 NP96250 NF96250 NP96250 AL31500 EL64750 AI52500 OF98000 OF98000 OT98000 TP45500 KMS4000 WM84000 WB4000 CN36750 ON36750 CIP07000 OP07000 QP07000 AF35750 KJ57750 PA49OO0 EL64750 WM34000 TG01750 TGO1750 XS52500 0250750 LP89250 HEXAAEIHYLENSTETRAMINE HEXAMWS HYDROCYANIC ACID, SALTS KYDSOXYBINZENE 2-HYDPCCCYEIHYLAMINE 1-HYDRDXYME7EHYLPROPANE IOCCMEUIANE IRCN (II) SULFATE (1:1) I5CBUIAN0L ISOBOTYX. ALOGHQL ISOPHOPXLCAIBINOL KETONE, DIMEDtYL KETCNE, ETHYL METHYL LEAD ACETATE LEAD CHKKATE, BASIC IZAD CHROMATE (VI) OXIDE IEAD OtFCfrRTE, RED LEAD, TETRAETHYL MAIACIDE FAUIHICN MALASOX MALEIC ACID ANHYDRIDE MALEIC ANHYDRIDE MANEB MANGANESE, (EIHYiaCTIS{DITOIOCARaA>t\TO)) MANZAIE i-CA MEA ME33 >S3C MERCAPTOTHICN HETACIDE METAPHOS METHACIDS HETHACPYLIC ACID, >ETHYL ESTER METHANAL A4 AP00048324 APPENDIX A ECONOMICALLY SIGNIFICANT SUBSTANCES LISTED IN NIOSH SUSPECTED CARCINOGENS, SBXND EDXTICM. NIOSH , , NU>BER'a) NAME 03 ? NIOSH NltSER(a) NAM3<b) PA49000 PA63000 PAS0500 PASO5O0 PAS2000 PA94500 XS52500 FG49000 TO49DOO FS91000 FS91000 W47250 PA49000 EL64750 LP39250 XS52500 PA49000 G07B750 KQ63000 PA63000. K729750 XT15750 PA80500 PA80500 PA80500 LP89250 EL64750 PA94500 AL31500 OZ50750 rc595oo PC59500 TZ29750 TG01750 XS96250 NP96250 METHANE, BPCf DMETHANE, CHLOROMETHANE DICHUDRIDE METHANE, DlCHDDROMETHANE, DICHLORODIFUJQfOMETHANE, I0DOMETHANE, PHENOL METHANE TETRACHLORIDE METHANE, TETRACHLOROMBIHANE TRICHLORIDE METHANE, TRICHLOSOMt,'iTtNAMTNE METHCGAS METHYL ACETONE METHYL AIDBIYEE METHYLBENZQffi METHYL BROMIDE 4-ME7IHYI^2,6-tcrt-BLrmtHQlOL MEIHYLCARBINOL METHYL CHLORIEE METHYLCHLOROFOFM l-METHYL-2,4-DINITROeBlZENE METHYIfNE BICHLORIDE METHYIH CHLORIDE METHYLENE DIOiLORIIS: METHYLENE CKICE METHYL ETHYL KETONE METHYL IODIDE METHYL KETCNE METHYL METHACRYLATE N-MEIHYL-1-NAPHTHYL CARBAMATE N-METTHYL-alpha-NAPHrHYLUJSTKAN METHYL OXIRANE METHYL PABASHICN 4-ME7IHYI/-m-PHE24YLB4EDIAMLNE 2-METHYL- 1-PHDPANOL NP9S250 FS91000 CY14000 W484000 OZ5075O KJ85750 AF85750 KU96250 PA63000 OZ50750 KJ57750 QJ05250 30952500 TG01750 1079000 0305250 QK92750 FC59500 KX38500 TX87500 QR5950O DA64750 CZL0500 TGQ1750 TG01750 XV03500 JW52500 CZ4SOOO CZ45000 KV03500 ED45500 CZ45000 KX24500 KX24500 C245500 CZ45500 2-METHYIPROPYL ALCOHOL methyl TRICHLORIDE MINERAL NAPHTHA MLT M4E MXCfitnXL GLYCOL EIHER M3KXHI0RQACETIC ACID M34CCHIJ3ICETHYI^ tCNOOOOROM&IHANE (ENOCHS METHACFYIATE MCNCMER MONCCIHAiCEAMINE MOTH BALLS H3TCK M-PARAHHCN MYLAR NAPHTHALHNE NAPHTHENIC ACID, 2INC SALT 1-NAPHTKYL N-METHYICAKBAMATE NEMA NS4AGCN NICKEL NITRCBS2JZEME p-NITBCCHLORCBEtfZEKE p-MtTROPHaiYIDIMEIHYLTElICNGPHCSPKNrE NTTROX 80 NORVtNYL OCTACHLOROCAfrPHENE OQB OOCB OPALCN ORTHOBORIC ACID QRTHODIQCLOfCBPiZENE GXIDOBIHANE CKIRANE PARACIDE PARADIGH0RCBENZENE ' AP00048325 APPENDIX A ECONOMICALLY SIGNIFICANT SUBSTANCES LISTED IN KICSH SUSPECTED CARCINCGENS, SECCWD EDITION. (Q NIOSH NUMBER'^ NIOSH hTPSER(a) KAMEfb> PA49000 PA63C00 PA8050D PAS0500 PA82000 PA94500 XS52500 FG49000 FG49000 FS91000 FS91000 MJ47250 BA49000 EL64750 LPB9250 XS52500 PA49000 GO78750 KQ63000 PA63000, KJ29750 XT15750 PA30SOO PA80500 PA80500 LP89250 EL64750 PA94500 AL3L500 OZ50750 FC59500 FCS9500 TZ29750 TG017S0 >596250 NP96250 METHANE, BRCtDMETHANE, CHLOROMETHANE DICHEORIDE METHANE, DICHLOPOMETHANE, DICHLOfODIEUXiEOMETHANE, IOCOMEIHANE, PHENYL METHANE TETRK3IIORIDE METHANE, TETRACHIORO* METHANE TRICHLORIDE METHANE, TRICHLOROMETKENAMINE METHOGAS METHYL ACETONE METHYL ALDEHYDE KETHYLBEN2ENE METHYL BROMIDE 4-METHYI/-2,6-tart-BOTYLPHENOL METHYICARBINOL METHYL CHLORIDE tETHYLQOOPQTOFM l-MEIHYL-2,4-DJNITROBENZENB METHY3BNE BICHLORIDE METHYLENE CHLORIDE METHYLENE DTCHH3RICE METHYLENE COCICE METHYL ETHYL KETCtJE METHYL IODIDE METHYL KETONE J-ETHYL ME7IHACRYIATE N-METHYL-1-NAPtfIHYL CARBAMATE N-MEIHYL-alpha-NAPfmiYLURETHAN METHYL OXIRANE METHYL PARATHION 4-METHYL-n^PHENYLENEDIAf'ONE 2-METHYL-l-PROPANOL NP96250 FS91000 CY14000 WM84000 OZ50750 KJ85750 AF85750 KU9S250 PA63000 02S0750 KJ57750 QJ05250 XWS2S00 TG01750 TQ79000 QJ05250 0102750 FC59500 KX33500 TX87500 QRS9500 DA64750 C210SOO TC01750 TC017S0 KVO3S00 XW52S0O CZ4S000 CZ45000 FCV03500 ED45500 C245000 KX24500 KX24S00 CZ45S00 CZ45500 2-METHYLPROPYL AICCHOL > METHYL TRIOCOPICE MINERAL NAPHTHA MLT M4E fCNCOOTYT, GLYCOL ETHER mxaznpopcenc acid MONOCamtOETHYLENE bCNCCHLOHOfrffilHAKB M2NCCXTE METHACRYLATE MCNOMER tONOETHANOLAMINE MOTO BAUS MOTOX M-PARA2HICN MYIAR NAPHTHALENE NAPHTHENIC ACID, 2INC SALT 1-NAPHIKYT. N-^ETHYLCAHBAMATE NFMA NEMAG5N NICKEL NITROBENZENE p-NITROCMIOnCBENZENE p-NITEOPHENYIDIMETHYLTEIONQPHOSPHATi: NITROX 80 NORVINYL OCTACHDORCCAMPHENE QEB OCCB OPAICN OKreOBORIC ACID ORniODICHIORCHENZENE CKIDCeiTONE OXIRANE PARACIDE PARADICHLDPCBENZENZ ' AS AP00048326 APPEMDIX A economically significant substances listed in niosh suspect caecimogems, st-m.jp edition. ^ NIOSH NUMBER^ MAME^ NICSH NUMBER(a) NAME(b> CZ45500 CZ45500 TG01750 ZK33250 SM63000 CZ45500 CZ45500 TQ35000 >396250 S-t63000 WG21000 KX38500 FG49000 KX45500 AH52500 SE73500 SN15750 SJ33250 SMS3000 SN15750 SM56500 OJ30500 CA07000 WL367S0 SJ33250 SX52500 TG01750 WM3400Q DU80500 TI31500 TI31500 TI31SOO TP45500 CZ10500 XN52500 PARADCW paramoTM PAFATHICN METHYL PARZATE SINES POP PDB PDCB P.E.G. 400 PELAQX GREY J PEMEACHLOROPHQ'JOL 1,3-PENTADIE2IE-1-CAK30XYLIC ACID PEK3LO0CETOYIE4E PEHOniXRCMETHANE PEfM-A-CLOR PEFMA KISER 50, raiSODICM SAW PETTHOmM ASPHALT (STEAM. REFINED ASPHALT) PHQttCHLOR PHEUGL PHENOL, PBNTOCHLOROPHENOL, 2,4,6-naattOPO PHENYLAMINE PHENYIBENZENE PHOiYIETHANE PHENYIEIHYMNE PHENYL HYDRQXKE PHENYIM5IHANB PHOSPHOEOIHICC ACID 0,0-DIMSTHYL 0- (p-NITRCPHENYt.) ESTER PHCSPHOIHION PHPH 1,3-PHTHAIANDICNE PHTHALIC ACID ANHYDRIDE PHTOALIC ANHYDRIDE PLUMBANE, TETRAETHYLPNCB POLYCHDDfOCAMPHENE TQ35000 TO79000 HL64750 WL64750 POLYETHYLENB GLYCOL POLYETHYLENE TEREPHTHAIATE POLYSTYRENE POLYSTYROL TR01000 XV03500 POLYVINYL ALCOHOL POLYVINYL rHTnftmp TX49000 TX87500 T229750 PROPANE, l-CHIOFO-2,3 -EPOXYPROPANE, l,2-DIBKM>3-CHLClfOPROPANE, 1,2-EPOXY- UH822S0 n-PRCPANOL AL31500 TZ29750 WG21000 UH82250 TZ27950 2-PRCPANCNE PROPENE OXIDE 2-P30PE2IYIACRYLIC ACID PROPYL ALCCHDL 1,2-PFCPYIINE OXIDE TR81000 PVA W733CO QR5950O QUARTZ RANEY NICKEL PA32000 REFRIGERANT 12 TI31500 . RETARDER ESEN PA49000 ROTOX VZ47250 SALT W73300 AH52500 FC59500 W73300 SAND SEQUESTRENE TRISODILM SALT 5EVIN SILICA, CRYSTALLINE - QUARTZ W73300 SILICA FI0UK (POWDERED CEYSTALLDS SILICA) W7330Q W73300 WE19000 PJ59500 SILICIC ANHYDRIDE SILICON DIOXGCE ( SAND) SODIUM BISULFIDE SODIUM CARSOXYMETHYL CELLULOSE VZ47250 O29550 SODIUM CHLORIDE SODIUM CHROMATE WE19000 SODIUM HYDRDSULFIDE WE19000 SODZUf MERCAPTAN WE19000 SOonn SULFHYDSAID A6 AP00048327 APPENDIX A ECONOMICALLY SIGNIFICANT SUBSTANCES USTEP IN NlOSH SUSPECTED CAflCD-jOGENS, SECOND EPITICK. lc) NIOSH NU>B3RW NAME*0' HIOSH , NUM3ER<aJ NAMS^ WE19000 WG21000 WG21Q00 WL36750 WL64750 WL36750 (34000 SODIUM SULFIDE SORBIC ACID SORBISTAT STYRENE STYRENE POLYMER STYRCN SUCCINIC ACID, KERCAPTO-, DIETHYL ESTER, S-ESTER WITH 0,0-DIMETHYL PHOSPHORDDITHIOATE XY56000 KX455D0 KJ29750 KX45500 FS91000 PS91000 SN15750 S-TRIAZINE, 2-CKI>RD-4-E7THYUC*nNO*6-- ISCPSQPYLAMINOTTLTCHLORAN 1,1,1-TRICHLOfOETHANE TRIQnORQETKYLEME TRIOGjORCFORM TRIOEORCMETHANE 2,4,5-TRICffiiCHDPHEMOL N3S5000 SH52600 SULFURIC ACID, IRCN(2+) SALT (1:1) SULFURIC ACID, ZINC SALT (1;1) KX45500 AH52500 TRI-CLBffi TRISODIUM EDBIATE VMS5050 TANTALUM AHS2500 TRISCCHUM VERSENAlE QJ0525Q WZ12250 TAR CAMPHOR , TEREPHTHALIC ACID, DIMETHYL ESTER YR62500 CP07000 UREA VANCIDE W212250 TEREPHTHALIC ACID, METHYL ESTER KU96250 VC KX33500 FG49000 TP45500 XR22750 XR22750 XR22750 'ren'RAQffOROBTHYTENE TETRACHLORCMEIHANE TETRAETHYL LEAD TITANIUM DIOXIDE TITANIUM QXIEE TITANOX KU96250 AH52500 KV03500 WL36750 KU96250 KU96250 VCM VERSENE 9 VINOFLEX VXHYLBaJZEMS VINYL CHLORIDE VINYL CHLORIDE NCx-CMER XS525O0 XS89250 TOLUENE TOLUENE, alpha-affCRO- KV03500 M52500 VINYL CHLORIDE POLYMER VINYL CYANIDE XS96250 XT157S0 XT19250 TOUE-2,4-CIAMEffi TOLUENE, 2,4-DINITEOTOLUENE, 2,6-DHHTEO- KVD3500 Q305250 ZH52S00 VINYXITE WHITE TAR WHITE VITRIOL XS52500 xn52soo TOLUOL TOXADUST ZH33250 QK92750 ZINC, (ETHYLENEBIS (DITHIOCAFSA^MO)) ZINC NAPKTHENATE H452500 TOXAPHENE ZH52600 ZINC SULFATE CN36750 KX45500 TOXILIC ANHYDRIDE TRI 3152600 ZK33250 ZINC VITRIOL ZINEB KX45500 TRIAD PA49000 ZYTOX KX4S500 TRIASOL (a) KICSH NINB5R is an alpha/numeric designation which is unique to the substance. Each synonym is keyed to this unique number. fa) This oolunn includes chemical, trade, and caiman names. fa) Economically significant substances are defined as these with production of 25 million pounds per year and/or significant workplace exposure. There are 99 unique substances in this list. Source; Booz*Allen & Hamilton Inc. A7 AP00048328 APPENDIX B SUGGESTED OUTLINE FOR INDIVIDUAL COMPANY COMMENTS OR TESTIMONY ON tHB 65HA GENERIC "CARCflNOGEN PROPOSAL FOCUSING PRIMARILY ON ECONOMICS Chapter I - company Background Description of the company, including: Size . Products made . Number of employees . Export-import balance . Activities in protecting worker health. Chapter II - Methodology For Estimating Economic Impact The guideline is the recommended methodology that should be referenced here. Chapter III - Direct Cost Impacts of the regulation, under two scenarios: . Scenario A - Assume all your products which are on the NIOSH List of Suspected Carcinogens are in Category I. . Scenario B - Assume all your products which ere on the NIOSH List of Suspected Carcinogens are in Category II. Scenario A direct costs should be estimated at three potential control levels: . a PEL level of 100 ppm for liquids and gases or 100 mierograms for solids a PEL level of 1 ppm for liquids and gases or 10 micrograms for solids . a PEL level of 10 ppb for liquids and gases or 1 microgram for solids. Chapter IV - Indirect Implications To The Company This section should cover those significant elements of economic impact on your company that are not direct compliance-cost items. Possibilities include effects on: . Use of substitute materials and processes . Price . Productivity . Competitive position regarding foreign producers . Possible plant closing . Employment . Small versus large companies. Chapter v - indirect Cost implications To Customer industries Using examples where possible, this section should cover effects on user industry. . Use of substitute materials and processes . Costs and prices . Productivity . Competitive position regarding foreign producers Plant and business closings . Employment . Small- versus large-volume users. **e * you, may also want to cover non-economic issues in your submission such as technical problems, questions of toxicological definition, and recommendations for changes to the rule as proposed. - Bl - AP00048329 APPENDIX C FORMS FOR CALCULATION AND REPORTING AP00048330 CONFIDENTIAL FORM I COMPANV IDStJTfFrICATION (Complete Only if your company Elects To Participate In The Industry Economic Survey) Case Study Substances: Company Name: Addresss Key Contact: Title: Telephone: Alternate Contact: Title: _____ Telephone: ____ RETURN entire questionnaire TO: booz, Allen & Hamilton Inc., Foster 0. Snell Division, 66 Hanover Road, Fiorham Park, Kew jersey 07932, Attention: R. Kensickl This sheet should be used only if your company elects to participate in the industry economic survey being performed by Booz, Allen. It will be used only if follow-up contact is required for clarification, it will be kept in a locked file, separate from the rest of the questionnaire until analysis is complete. Then it wi.lL be reattached to the rest of the questionnaire and returned. Fox clarification and assistance in filling out these forms, contact Ronald Kensicki, Ronald Rubin or Philip Gisser, Foster D. Snell, Inc., at (201) 377-6700, Extension 260; New York City Tie-bine - (212} 924-8800. AP00048331 CONFIDENTIAL FORM II Plant Unit (Assign Number) _ Case Study Substance STATISTICAL DATA --Each Plant Unit-- For each plant associated with the selected case study substance, complete this sheet. Case study substance: ____________________________ Major products manufactured by this plant unit if the case study Bubstance is not a product: Output (197$)/units of output: ___________________________________ Approximate 1976 value of ship ments from this unit (sales plus internal transfer): $____________ Number of total employees (1976-- allocate, if necessary}a _____________________________________________________ Number of production employees (1976^: ____________________________________________________________________ List the substances potentially controlled by this regulation that are present at the plant unit and the total number of employees exposed to these substances in this unit. List the case study substance first. Substances23 NIOSH Registry Number2 Number of BmpLoyees Exposed Full Time4 Part TimeS Total Tt Include all-employees assigned to the specific plant unit, e.g.: . Production workers . Maintenance employees generally assigned to the area . First-line and other supervision assigned directly to that plant unit. 2. substances and their respective NIOSH number are listed in Appendix A. other substances for which standards may be established under this regulation are listed in thf NIOSH publication, Suspected Carcinogens, 1976. 3. If an impurity, indicate its concentration. 4. Full Time - Mora than four hours per day, 90* of working days. 5. Part Time - More than 30 minutes per week, but less than full time. AP00048332 CONFIDENTIAL FORM III NON-ENGINEERING COMPLIANCE COST WORKSHEET -- Each Plant Unit -- Plant Unit Number_____ Case Study Substance Cost Element (Elements required'for Category I or II assumption.) L. Initial monitoring cost 2. Exposure monitoring, cost 3. increased medical sur veillance cost 4. Added change rooms and showers 5. Emergency alarms 6. Respirators above current use levels 7. Personal protection equip ment above current use levels 3. Signs 9. Emergency plan 10. Recordkeeping 11. 12. Training above current levels Total, Category I or II assumption Caoital Cost (1&77 Dollars) Annual Ooeratinq Cost [197T DollarTT Differential First Year Operating Cost (1977 Dollars) (Elements required for Category I assumption only) 13. Segregation of work areas 14. Lunchroom facilities 15. Total, Category I assumption (add lines 12, 13, and 14 J AP00048333 CONFIDENTIAL Plant Unit Number_____ Case Study Substance FORM IV ENGINEERING CONTROL COST WORKSHEET -- Each Plant Unit -- Assumed PEL Level 1. 10 ppm (liquids or vapors) or 100 micrograms (solids) per cubic meter Capital Cost (1977 Dollars) $ Annual Operating Cost (1977 Dollars) S Differential First Year Operating Costs <Hv7 Dollars) S Net Effect on Energy Reguirements (Equivalent barrels *of briefly describe: 2. 1 ppm (liquids or vapors) or 10 micrograms (solids) per cubic meter briefly describe: $______________________ 5____________________________________ $ AP000483 3. 10 ppb (liquid pr vapors) or 1 microgram (solids) per cubic meter briefly describe: $____________________ $_________________________________ (1) Assume one barrel of oil is equivalent to 6 million BTU's or SG7 kilowatt-hours. CONFIDENTIAL Plant Unit Number____ Case Study Substance FORM V SUMMARY DATA - DIRECT COSTS AT PIAMT UNIT LEVEL -- Each Plant Unit -- Category I Category I 10 ppm (liquid or vapor) 1 ppm (liquid or vapor) Category II or 100 micrograms {solid) or 10 micrograms (solid) AssumptionAssumption ___________________ Assumption Differ- Differ- Differ- Annual ential Annual ential Annual ential Oper- First Year Oper- First Year Oper- First Year Capital ating Operating Capital ating Operating Capital ating Operating Costs Costs Costs Costs Costs CostsCosts Costs Costs Category I 10 ppb (liquid or vapor) or 1 microgram (solid) ____________Assumption Differ- Annual ential Oper- First Year Capital ating Operating Costs Costs Costs * Non engineering costs (Form III, lines 12or 15T * Engineering costs (Form IV, lines 1,2 or 3)* * Subtotals * other annualized costs - Benefits, cost reduc tions and product re covery - Management time, com pliance costs - Capital related costs d) (25 percent of total capital costs) Total, direct costs plant unit AP00048335 ^Capital related costs include; Depreciation at 10 percent, Interest at 8 percent, Maintenance at 5 percent and Insurance at 2 percent of capital cost. Taxes CONFIDENTIAL Plant Unit Number __ Case Study Substance Substance: FORM VI SUMMARY DATA - RELATIVE COST CHANGES (Pill out this form for each case study substance by adding plant unit data.) Category II Assumption Differ- Annual ential Opeit- First Year Capital ating Operating Costs costs Costs (A) (3) (C) Category I 10 ppm (liquid or vapor) or 100 micrograms (solid) Assumption Differ- Annual ential Oper- First Year Capital ating Costs Costs Operating Costs (A) (B> <C) Category 1 1 ppa (liquid or vapor) or 10 micrograms (solid) Assumption Differ- Annual ential Oper-- First Year capital ating Costs Costs Operating Costs (A) (3) (C> - Category I 10 ppb (liquid or vapor) or 1 nicrograun (solid) Assumption Differ- Annual ential Opor- First Year Capital ating operating Costs Costs Costs (A) (3) (C) (1.) (2.) Estimated Total Direct CoststU Reference Value t2J {3.) Direct Costs as a percent of the Reference value. (1.) ~ (2.) x 100 APOO Substance: (1.) Estimated Total Direct Costs (2.1 Reference Value (3.) Direct Costs as a percent of the Reference Value. U.) 7 <2. J x 100 ________ __________ ______________ ________ _________ ____________________________________________________ (1) Consolidate Form V data from various plant units reporting case study substance. ________ (2) Reference values are defined as follows for each cost category: (write the figure on line (2.) below each applicable letter.) (A) Replacement value of production unit in its present fora (assuming identical plant). (B) Total current fixed and variable manufacturing costs including depreciation and management cost, but excluding distribution, and selling, general and administration expenses. (C) Historic 5 year average pre-tax profit on applicable substance or unit. CONFIDENTIAL (FILL OUT THIS PAGE IF YOU PRODUCE OR FORMULATE A PRODUCT WITH CASE-STUDY SUBSTANCE - USE FORM VIII IF THE SUBSTANCE IS A RAW MATERIAL) Plant: Unit Number_____ Case Study Substance FORM VII ADDITIONAL ECONOMIC EFFECTS -- PRODUCTS OR FORMULATIONS " - Each Plant Unit - 1. Assuming your direct domestic competitors are faced with comparable increased costs that wight result from this regulation, what action would you be likely to take? a. Raise prices to recover direct production cost increases Yes b. Raise prices above increased costs. Yes___________ No____________ What % No What effect would this action have on sales, increase (decrease) , percent ___________________ 2. Do technically feasible substitutes for this substance exist in its major applications. (Include both direct substitution and alternate production methods.)? If yes, what application (Use separate pages for separate applications.) a. What material is the most likely substitute? b. What share of your product sales is subject to substitution, % c. How quickly could this occur (discuss)? d. What effect will such substitutes have on the users of this substance? . Raw material cost increase (decrease) $/unit . Other production cost increase (decrease) $/unit . What is the unit of output above? . RtD costs to substitute, ^/company . Capital investment required S/unit output . Other costs (explain)________________________________________ AP00048337 e. At what level of price increase will significant substitution (10% of sales) occur (percent)? f. What actions do you feel users of this substance would take if the substance were to be designated a "suspect carcinogen" (category 11)7___________________________________________________________________________________________________________ g. What 'actions do you feel users of this substance would take if this substance were to be designated "confirmed' carcinogen" (category I) and an Emergency Temporary Standard were issued requiring immediate action, plus later engineering controls to reduce concentrations to the lowest level feasible? __________________________ h. Would the added costs be likely to influence users to go out of business? To what extent? i. What^particular' effects-would you expect on customers who are lanall businesses?' Less than $30 million in gross annual sales? Less than $5 million in gross annual sales? ______________________________________________________________________________________________________' Are there other costs that: you are likely to incur as a result of shifting demand patterns, such as technical service costs? . Explain? _______________________________________________________________________________________________________________________ 3. To what degree do you see a potential threat in this and downstream products from overseas manufacturers, assuming nil domestic manufacturers must comply, but no similar regulations will control overseas manufacturers in their plants? CONFIDENTIAL (FILL OUT THIS PAGE ONLY IF YOU PURCHASE OR USE THE CASE STUDY SUBSTANCE IN THIS PLANT UNIT USE FORM VII I? YOU MANUFACTURE IT) Plant Unit Number Case Study Substance" FORM VIII ADDITIONAL ECONOMIC EFFECTS - RAW MATERIALS - Each Plant Unit - 1. Do technically feasible substitute raw materials (or alternate Yes approaches) exist for this substance? Ua 2. Describe ,_____________________________________________________________________________________________________________________ 3. If you switched to this alternative, what would be the effect a. Total raw material cost increase (decrease) 5/year b. Other production cost increase (decrease) (exclude depreciation), 5/year _______________ c. R&D costs to substitute, 5 d. Capital Investment required $ e. Other costs, explain, Capital _____________________________________________________________________________ Annual " Differential First Year " ' 4. What percent chance exists that increased costs of compliance with Category I regulation would result in your closing the unit rather than complying? _____________________________________% a. If this occured, what would be the effect on overall employment? Number effected Percent of employees in this unit ____________________________________ ~ ~ ~' 5. How would a 10% price increase affect your use of this substance, assuming no parallel increase in competitive substances? 6. What action would you probably take if this substance were to be designated as a "suspect carcinogen" {Category II) and standards were issued requiring the actions described herein?_______________________________________________________________________________________1____________________________ 7. what action would you probably take if this substance were to be designated as a "confirmed carcinogen" (category I), and an Emergency Temporary Standard were issued * requiring immediate compliance plus later engineering controls to reduce concentrations to the lowest level feasible? 3. Whac actions would you take if use of this substance in this application were to be prohibited? 9. What do you feel will be the effect of the proposed regulations on productivity in your plant under the three assumptions below: a. Increase in production workers, % of production workers in this unit b. Increase in non-production employees, % of non-production employees in this unit c. Decrease in production, % of production d. Change in productivity, (production per employee), % change Assume Category il Assume Category I Difficult Extremely to meet Difficult to Requirement Meet Requirement AP00048338 October 28, 19.77 TO: OSHA List Board of Governors OSHA Generic Proposal for the Regulation of Carcinogens Gentlemen: On October 19th, we sent you a memorandum describing OSHA's proposed generic standard for the regulation of suspected carcinogens which was published on October 4, 1977. This regu lation, if adopted in its present form, will almost certainly be the single most restrictive, arbitrary and costly regulation ever imposed on the chemical industry. As some of you may know, the number of comments filed or companies testifying at a hearing is often used by agencies as a guage for the acceptability of a proposal and the necessity for modification thereto. It is, therefore, essential that you analyse the impact of the regulation on your business and either (a) file your comments by December 8, 1977, or (b) noti fy OSHA of ycur intention to appear and testify and file an out line of your proposed testimony by December 8, 1977. You should not view comments filed by MCA, SOCMA or other associations or companies as a substitute for your own comments and participa tion . Because of the terrible time constraints and because OSHA has published neither a list of commercial chemicals which are at hazard under the regulation, nor an environmental impact statement, we are writing this memo to give you some guidance in preparing your comments. Technical Issues The proposed generic standard is very similar to that disclosed by OSHA on January 24, 1977. Thereafter, there were hearings before the National Advisory Committee on Occupational Safety and Health. We will shortly send you copies of statements by SOCMA and MCA stating the technical objections to the proposed generic standard. These objections will be elaborated on in the hearings now scheduled for March 1978. In the meantime, these statements will give you guidance on the kind of technical criticism which will be made. If you have any member of your staff capable of asserting or elaborating on these technical points, start work on a statement NOW. The time for filing is virtually upon you. It is essential that as many companies as possible with the v scientific capability file a statement. AP00048339 (c) the international trade impact (i.e., if you could not use an intermediate or had to use a much more expensive one, could your international com petitors increase imports). [Note: Substitution may not be complete, i.e., there may be substitutes for some uses but not others. OSHA may require subsitution for only certain uses.) 4. If a product you sell is involved, comment on the effect of a ban (because of substitutes) on your customers. Estimate the cost to your customers, job and trade impact. 5. If there are no substitutes, then determine what it would mae<a n. ^toa go ^toa M"1lowes4t> feasibklle^ exposuvrae"I* byt aemnagt iinn aeaer ing controls (not personal protective devices) without regard to cost. Calculate the cost -- (a) Which products would you abandon? Calculate cost, job and trade impact, on you and your customers. (b) What would be the cost to you to achieve lowest feasible exposure on remaining substances? (c) What would be the cost to your customers of achieving lowest feasible exposure in their use of your product? How many would drop use of your product? (Note: The lowest feasible exposure requirement applies not only to the work place but to labs as well.] Plan to get your comments in. help, call the SOCMA office. Start now! If you need Sincerely, Executive Director 3