Document oeMZmz4MrxVdEzw9J5Yzv95bo

IlCSTRZ " u.s DLPAR.TM ENT OF LABOR Cc-upa oil:.1 S-mcv mi: I'....hr. - .Funnc.. Washington. u C. ;. i D - \ 7 '375 Hr. R. S. 3 rook", an Manager Research, Develop- unt and Technical Firestone Plastics Company Pottscown, Pe.nnsyl vania 1 9 4 6 4 Services :--~r Dear Hr. Brockman: In response to your letter of July 14, 19 75, oetitior. inc for modification o : the Vinyl Chloride Standard, the following de term ini ions have been made: 1. 29 CFR 1910.101 (b)(5) De f initions In regards to the (fefiniton of "massive release" in Program Directive "200-35, we agree that the definition snould be modified. This vi 1 be addressed in a future program directive. In all prcfc bilitv the stimulation of 130 com will be r amoved . 2. 29 CFR 1910.10 7(b)(6) Definitions The standard defin <:s a fabricated produce as being one. which is "made wholly or partly from polyvinyl *::lorice, and which does not rocuire f other processing at t w.r.nn r a a u: a 3 , and for o cause mass melting of the polyvinyl chloride resulting in the release of vinyl chloride." "Release of vinyl chloride" means the release of an amount of vinyl chloride wh:ich would likely result in om.nloyee expo- sure at or aoove t lie action level without regard to the use of engineering con ols. Products which can be classified as fabricated prod ts.arc exenmt frem ;h.> previsions c: the vinyl chloride sta ard. All other products are sucject to the requirements o the st.i.-.ca:: . Is temcl oyer uses or manufactures a ?ro't ct which is net a : icated or: u: i to ring procedures. *.f the r.:o nice ring reveals that tne er; love as are not expos-cc to vinyl chloride at or aoove the ac ion level, the employers' operations will be examet from the provisions of the sta tare. SPf-00874 However, if the radni toring reveals exposure at or above the action level, the employer must implement the procedures specified in the sltandard . 3. 29 CFR 19101. 017(g)(4)(iii) Respiratory protection Regarding your sug gestion to add a Type C, Supplied Air Respira tor, Press ure Demand type, with full or half face- piece to this sect ion: . If an employer can show that a respirator provides equal or greater protec ion than those specified in the standard, he may be granted an interim order or a variance frcm the standard. Your c on pany received such an interim order. dated hay 30, 1975 4. 29 CFP. 1910.1017(k) Medical surveillance There is no OSHA regulation requiring an employee to submit to a medical exam nation. If the employee refuses any medical examination requi red to be provided by the employer, the employer shall inf ora the employee of the possible health consequences of s uch refusal and obtain a signed statement ' from the employee indicating that the employee understands the risk involved by refusal to be examined. We greatly apprect ate your sharing data, ex:;er:encs anc knowledge with us. At the present time the;e are no olans to formally amend o.r modify the vinyl chloride standard, We hope that the above clarification of the regulation will satisfy the recue st in your petition. Should you have fur the: cuestions olease do not hesitate to contact us. S i n c " r e 1 v, Ejs-rty J j r*n l te AsscciaL: Ass is tan,:t Secretary for Regional Programs 'r: C. Valler 12/25/75 Contes to: 3. Connolly, J. Cassidy, <7: Kr. C. J. Kleinert Hr. 7. ?. -ov /r _ p ^ W. Arnold V N. West _ HV. c! D. Lloyd A. Park SPI-00875