Document p2MJZYz5MxGKdmwpKJV7dXwRX

N. / tv- > xVj.O/'. ^ A aTT^t p r i.X SxJ 'kJ jS'1 do'ajo :.n.xr of i i. j-jaxatjon. an*d wlli !i. uj:: m.uviu. m:. ur. ior. TO : Assistant Sccrtu-.T/ of Labor ha! Occupational n-.r-'-ty and Health Administration Department of Labor 1j 13/4 J710M : Director, Motional Institute for Occupational Safety and Health SI JIBUTI : P.ecoisuended Occupational Health Standard for the Manufacture of Synthetic Polymer Iron Vinyl Chloride On January 22, 1974, representatives from the B'. F. Goodrich Chemical Company informed KIOSH that the deaths of several employees of their Louisville, Kentucky, plant rsir.hi have bec-n related to occupational exposures. An Immediate industrial hygiene uaik-through survey of the facility was conducted by KIGSH and resulted in developing and transmit ting to affected companies recommendations for precautionary ironitorirjg and control procedures for rolyscrisation processes involving vinyl chloride. Or. February 1, 1574, KIOSK/CSC conducted a briefing tor other Federal agencies vith health research responsibilities at which it was disclosed that four employees of the plant in nucscion had died of angiosarcoma of the liver, because of the cxtrcmel)' low incidence of this diseasei estimated to be on the order of 20 to 30 deaths per year in the United States, the history of four cases in a five-year period in one plant vs considered of`great importance. It was .concluded at the briefing that z new occupational cancer had been discovered i angiosarcoma of the liver. It was further concluded that this disease was associated vith the manufacture of polyvinyl cnlorice and that vinyl chloride was the prine etiological candidate in producing the disease. KIOSK, with the assistance of expert consultants froa both industry - and organized labor, began development of a recorrtcnded occupational health standard- These end other activities were discussed in more detail at the OSiiA Informal Fact-Finding Hearing on Possible Hazards of "Vinyl Chloride Manufacture and Use cm February 15, 1974. It was olao during this Hearing that Professor Cesare Maltcni or bologna, Italy, presented the preliminary results of his research which showed induction of angiosarcoma of the liver and other organs, os well os the production of other cancers in rots exposed to vinyl chloride. The results of these studies identify vinyl chloride as a corcincgeu snd further confirm its role in inducing the cancers observed in the B. F. Goodrich workers. <* t DTH 00`>';i t /cjr,iutanl Secretary of L^or, GS'iA. Since the OSUA Hear inf;, MOS1? lias learned of nt least five additional cases of nngio.vnreoisa of the liver. Two of these cast-!; were diagnosed in the current working population at the sane Louisville facility, while the other three involved deceased workers, one each from the Louisville facility, Union Carbide's South Charlestown plant, and Goodyear's niagara plant. Although vinyl chloride rust bo considered as s carcinogenic agent, the irsnediate problen appeared to be concentrated in polymerisation facilities. Consequently, the attached U30SJJ rccctssEndcd standard only applies to such operations. This is not to say, however, that appropriate standards should nor be developed for other exposures to the basic chemical. hIDSH is implementing further evaluation of the data, coupled with field observations, to determine exposure potentials in pre~.and post-polymerization operations. You will be inferxsed as further data and plans arc developed. As previously indicated, llIOSi' considers this to be a cost serious problen and strongly urges that expedited rulemaking be inplenented by OSUA to insure that the health of exposed workers is promptly and adequately safeguarded. Ve feel that, extent where employers experience problems in obtaining air supplied respirators or environmental monitoring equipment," the attached reccnnzndations can be implemented as soon as a standard is promulgated. The medical surveillance requirements which will be supplied in one to two weeks could also be implemented immediately vith the possibility that soes employers would need a short period of time for their medical staff or consultants to make arrangements for any special laboratory tests. i t f ! You should be aware that the consultants from industry vho worked with us proposed that the rccor.rcr.uea standard contain the concept of an allowable ''working level" for- vinyl chloride gas in the atmosphere, which they identified as a tire weighted average of 50 ppra. They, recommended that where workers were exposed to concentrations in excess of this level they should wear air-supplied respirators. This concept of an allowable "working level" might seem justifiable in that 1'rofessor 1'alteni found no liver tumors at 50 ppn, but there is the possibility that turners might have been produced if a larger cumber of animals had been exposed at that concentration! Based on theoretical considerations, there is probably no threshold for carcinogenesis although it is possible that vith very low Concentrations, the latency period night be extended beyond the life expectancy, fin view of these considerations and our inability to describe a safe exposure level as required in section 20(a)(3) of the Occupational Safety and Health Act, vc rejected the concept of a threshold limit for vinyl chloride gas in the atmosphere. DTH 000016699 Page 3 - Assistant Secretary of Labor, OS?iA Consequently, our recc--mendatiens as contained in the attached document are such-that where any employee is exposed to measurable concentrations ci vinyl chloriis, as determined by the reerrarended sampling and analytical rsthod, he shall vear an air supp lied respirator. This recommendation is based on -sene preliminary inform;; ticn that the standard chemical cartridge respirators are inefficient in pi otccting against vinyl chloride. KlCSii is implementing a study to evaluc te the degree or protection afforded by different types of respirators us ir>g vinyl chloride as the test gas. As information becomes available, it vill be forwarded to OSilA as recotmandstior.s for alternative respii ator usage. The employer is also required to develop a Control Plan to redi ce airborne concentrations of vinyl chloride to levels not detectable: by the recommended method. As you vill note in reviewing the re commelided standard, there are . references to the "sampling and analytical method recommended by the Director." This method, in the form of a compliance sampling data sheet, will be forwarded to OSKA within s week. Tva now estimate that the level of sensitivity of our recommended method will be around one part per jsillion, specifically for vinyl chloride. The Office of Research and Standards Development, vliich is directed by Ur. Vemon E, Rose, has had lead responsibility in developing this recommended standard. As your professional staff review and evaluate our document, questions or requests for additional information should be directed to Mr. Rose. 0 / / ii* 1 .& * j ' Marcus H, Key, 1-J.Df'/^ Assistant Surgeon General Attachment :pi*v v !T f. DTH 000016700