Document peeDe4L95vgqmGXnEzaVkw8Oa

(conoco) Conoco Chemicals Continental Oil Company Park Eighty Plaza East Saddle Brook. N.J. 07662 (201)845-3800 June 20, 1974 Docket Officer Docket OSH-36 Room 230 1726 M Street, N.W. Occupational Safety and Health Administration Washington, D. C. 20210 ' Dear Sir: Continental Oil Company manufactures about 500 mi 11 ion pounds of polyvinyl chloride (PVC) per year at two plants, one located in Aberdeen, Mississippi, and the other at Oklahoma City, Oklahoma. Continental Oil Company also produces about 700 million pounds of vinyl chloride monomer (VCM) at a plant located in Lake Charles, Louisiana. The proposed occupational health and safety regulations regarding vinyl chloride as published in the Federal Register, pp. I6896-I69OO, Vol. 39, No. 92 - Friday, May 10, 1974, are of significant concern to Continental Oil Company. We wish to record comments regarding (a) proposed permanent standard for Vinyl Chloride, 1910.93q, (b) problems associated with analytica.1 detection of vinyl chloride, (c) information related to large polymerization reactors, and (d) the economic impact of a "no detectable level" of VCM upon Continental 0i1 Company emp1oyees. In summary, the recommended Occupational Health Standard regulating vinyl chloride, dated May 10, 1974, will have a significant impact upon the economy of the United States and upon Continental Oil Company operations should the standard be implemented as proposed. It is our belief that the proposed standards would result in the cessation of production for an extended period of time because of the improbability of meeting a "non-detectable level" for VCM in the work place. Continental Oil Company has made significant improvements in its PVC manufacturing operations towards reducing exposure of employees to VCM vapors and we are convinced that considerable additional improvements in this respect can and wi11 be made by our plants and the industry. Very truly yours, R. W. Gerwig, Vice President Continental Oil Company mk DTH 000012276