Document pemgDbayB4zEy75z9newp2M2X

.dU 'C**:; V; j r\*V^J yL.jCT% PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" I uh r* a \lynfirti\UnUaWhtLJc'iJtL RIER S 1 f<* ,b FOR COMPLIANCE WITH OSHA STANDARD ON VINYL CHLORIDE AND POLYVINYL CHLORIDE (Published by Safety Department, American Trucking Assns, Inc. 6-1-75) Motor earners are now subject to OSHA standard 1910.93q v/hich sets forth requirements for protecting employees safety and health when shipments of vinyl chloride and polyvinyl chloride are handled. General information about the hazards, monitoring procedures and employee training is set forth in Appen dix I. In response to the requirement for training carriers may want to issue a bulletin of a type similar to Appendix I, to their employees. The information is based upon a premise that the exposure level for vinyl chloride will be very low in motor carrier operations and thus only a minimum compliance program is required. If, after monitoring, a earner determines that exposure levels are higher than expected it will be necessary to establish a more detailed program than the minimum. Every' carrier handling VC and PVC should obtain a copy of the complete standard which is contained in Federal Register, Volume 39. No. 194 -- Friday. October 4. 1974, or from OSHA. The motor earner should first read Appendix I for general information and should then read the following which gives more specific detail on a course of action. Shippers should then be contacted to determine the genera! nature of materials being shipped, the general levels of hazard and the assistance that they wiii give the carrier to monitor shipments of VC and PVC. In its contact with the shipper the carrier should as certain: i: The various types of PVC being shipped, fre quency and size of VC and PVC shipments, gen era! exposure levels for PVC. 2. If the shipper will provide special identification on shipping papers so that PVC shipments can be easilyjdentified and not confused with ether ship ments of plastics. 3. If the shipper can assist with monitoring by provid ing technical people to do the monitoring, by pro viding personaf monitoring units, by analyzing samples. 4. If the shipper can help establish a control program which will assure that exposure levels are below the "aclion levei" of .5 ppm. And if the shipper will establish a procedure to notify the carrier of any process change that will necessitate additional monitoring of a particular type of commodity. ACTION PROGRAM MONITORING Manufacturers of vinyl chloride and polyvinyl chloride have indicated they will assist carriers in carrying out the monitoring requirements. Thus the first step toward com pliance should be: The second step of a motor carrier program in monitoring. Some information about monitoring is pro vided in the Appendix for employees but is presented a) Review past shipping documents to determine herein in greater detail lor management. who the shippers are. On documents VC will be When monitoring exposure levels, air samples must described as "Vinyl chloride" and classed as be taken at the level of an employee's mouth and nose -- ``Flammable compressed gas". Documents lor his breathing area. Personal monitoring units clipped to polyvinyl chloride wifi describe the shipment as his shirt sen/e this purpose. Samples of air at floor levels "Plastic Materials. N.O.I.". Or. some documents should not be used because vinyl chlorides are heavier the words 'polyvinyl chloride' will be shown m ad than air and tend to settle at floor level -- well below the dition to the shipping name. employee's breathing area. b) Check freight containers to determine who the shippers are. Vinyl chloride will be in cylinders bearing the label "Flammable compressed gas" and a label "Cancer-suspect agent". Polyvinyl chloride rnay be in bags, boxes and drums and ' will bear a label reading ".. . contains vinyl There should be monitoring for each shipper and for each of his products that may have a different exposure level, as the exposure varies according to manufacturing processes if a shipper changes his processes and ex posure levels are increased there must be additional monitoring. chloride. Vinyl chloride is a cancer-suspect The exposure level also vanes by time and tempera- agent". lure. Thus the monitoring should be after a vehicle has ucc 1 024151 PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" soad lime to ventilate. Exposure levels, if any. will be r higher immediately after trailer doors are opened but the process of opening the doors and backing the trailer to the unloading platform will reduce levels. The carrier should monitor immediately after the trailer is moved to the platform, and again after it has been at the platform for 10 to 20 minutes to determine if the additional time lag reduces exposure levels significantly. If such is the case, the carrier should issue instructions to employees that VC and PVC shipments should not be handled until the trailer has been open for a specified period of time. The exposure level varies by size of shipment. Truckloads will probably be handled by shipper and consignee and there is no responsibility on the carrier if his employees are not exposed. Monitoring of LTL should be for the largest shipments usually loaded and un loaded by earner employees. Monitoring of dock operations must be carried out if VC and PVC are to be kept on the freight platform. Results of the monitoring are obtained through use of an analyzer. The samples taken are processed through the analyzer and the results are averaged over a time medical survei'iance records must be kept, and if regu lated areas are established there must be records of persons authorized m the regulated areas. It does not appear likely that motor carriers will have an exposure level above the "action level" o! .5 ppm and. if such is the case, regulated areas and medical surveillance will not be required. Monitoring and measuring records must be kepi for 30 years and state: date of monitoring, concentrations determined, identification of instruments and methods used. They must also include any additional information' necessary to determine individual employee exposures where such exposures are determined by means other than individual monitoring. Monitoring and measuring records must be open for examination and copying by employees or their desig nated representatives. Former employees may examine and copy records of their own exposure. ..A written report must be made to an employee within ten days after his exposure lo levels above the permissi ble limit, without regard to use of a respirator. Such a report must tel! the exposure level and steps being taken period to determine the exposure level for a 15 minute to reduce exposure to allowable limits. period, and for an eight hour period. If the exposure level is at or below the "acjion level" of .5 parts per million for eight hours the carrier is allowed to conduct a minimum program. If the level is at or below one part per million (but above .5) the carrier must conduct a more extensive program, including medical surveillance of employees. If Reports are required concerning establishment of regulated areas but this does not appear to be applica ble to motor carriers because of low exposure levels. ADrsDn11 iuin-imn L nncrU~vini-cmc-i'nj i oi the level is above one part per million, or 5 parts per million in 15 minutes, the carrier must establish adminis trative and engineering controls to reduce exposure levels. If levels cannot be reduced sufficiently through administrative and engineering controls, the carrier must provide respirators to employees that are exposed to the higher levels. TRAINING Information on training requirements is provided in Appendix I. Each carrier must determine if it wants to issue employee training information similar to that in Ap pendix I. or if its exposure levels necessitate more exten sive training. If a motor carrier has exposure levels above the "ac tion level" he must engage in monitoring at least every quarter. Monthly monitoring is required despite use of respirators, if exposure levels are above permissible limits. Regulated areas are required if concentrations are above permissible limits and only authorized persons can have access to such areas. Daily rosters must be kept of persons who enter such areas. Engineering and work practice controls are required to bring exposure levels within permissible limits of one ppm in an eight hour day, or 5 ppm in a 15 minute period. If such controls do not bring levels to permissible limits they must be used and supplemented by use of pre scribed respiratory equipment. Written plans for such RECORDS AND REPORTS The fourth slep for a motor carrier program is to establish a system of records and reports, in addition to required items the motor carrier should keep a record of controls must be developed and available to OSHA rep resentatives. OSHA has provisions for "hazardous operations" and "emergencies" but these are designed for manufacturing operations and do not seem applicable to truck opera tions. except possibly for bulk transportation of vinyl every effort it has made toward compliance with OSHA requirements. Thus documents relating to shipper con tacts. review of shipping records, etc. will indicate to an OSHA inspector that the carrier is making a good faith effort to comply, even though its compliance program might not be in full lorce. The basic record keeping requirement is that there must be a record of monitoring and measuring. If there is chloride. These provisions do not contemplate the handl ing of PVC in powder, pellet or liquid form. "Hazardous operations" are those where a release of vinyl chloride liquid or gas migh! be expected as a con sequence of the operation or of accident which would result in exposure in excess of limits. An "emergency" is defined as an occurrence which is likely to, or does result in a massive release of VC. It does o n?41cn /j[ seem possible that a general freight carrier can have such a release because of the small quantities of VC handled and the integrity of the VC containers. Carriers should obtain copies of the complete stan dard for a full understanding of what is required, and so that they can determine its applicability to their opera tions. ....................... .. D.O.T. JURISDICTION The Department of Transportation exercises jurisdic tion over vinyl chloride gas and thus it does not appear to ATA that OSHA has jurisdiction. Informally, OSHA has claimed that D.O.T. is exercising jurisdiction only over the flammability and compressed gas hazards and that it (OSHA) has jurisdiction over the carcinogenic (cancer) hazard. The ATA position is that D.O.T. is exercising jurisdiction over the commodity and protects employees from hazards of flammability, compressed gas and car cinogens because of its rules, including those governing type and strength of containers. Until this difference is resolved by the agencies themselves or in a test case, the motor carrier handling vinyl chloride must determine for hirnself what course to follow. D.O.T. does not regulate polyvinyl chloride and thus it appears that OSHA has jurisdiction to promulgate these rules. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 024153 PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" Vi a . Q bssa (1 \J i-nss U ^ OSHA RULES COVER TRANSPORTATION OF VINYL CHLORIDE AND POLYVINYL CHLORIDE To help assure the safety and health of employees, the Occupational Safety and Health Administration has established rules that govern the handling, including transportation, of vinyl chloride (VC) and polyvinyl chloride (PVC). The rufes were designed primarily for workers in plants and factories where VC and PVC are made and where employees may have exposure to high levels of VC gas or liquid. Thousands of workers had contact with the vinyl chloride gases during processing since the 1940's. It was found that a few workers having worked in processing tor an average of 19 years developed a rare form of liver cancer. Exposure of transportation workers is not comparable to that of manufacturing employees because of differ ences in the nature of their work. Transportation workers have low exposure because they don't handle VC and PVC in the same form as manufacturing employees and because they handle it infrequently and for short periods of time. Their exposure is also lower because of protec tion offered by packaging and because new production methods for PVC have reduced the presence of sub stances that might cause cancer after long-time and high level exposure. The danger tc trucking company employees is believed to be very low and almost nil. Nonetheless, OSHA has made the rules applicable to truck operations just as they did.for the companies that manufacture these materials. VINYL CHLORIDE Shipments of vinyl chloride are classed as flammable compressed gases and move primarily in tank trucks and tank cars. They hardly ever move by van type vehicles but when they do they are in cylinders. Vinyl chloride will be listed cn shooing pacers as "Vinyl Chloride" and classed on shipping papers as "Flammable Compressed Gas", in accordance with D.O.T. regulations. Cylinders will bear a "Flammable Compressed Gas" label required by D.O.T.. and a label required by OSHA which reads "Cancer-Suspect Agent." Exposure hazards for VC are nil in transporiation be cause the cylinders must meet requirements of D.O.T. to prevent escape of gases and to protect against the main hazard of flammability. POLYVINYL CHLORIDE Polyvinyl chloride represents approximately 40 per cent of all plastic-materials moving by truck. Estimates are that mere than 2 billion pounds move annually by motor carrier. PVC may be in the form of powder, pellets or liquid, thereby moving in bags, boxes and drums when it moves in van type vehicles. Shipping papers will read "Plastic Materials. NOI". but not all plastics are PVC. and not all PVC shipments are subject to the OSHA regulations. Those that are sub ject to the regulations will have a label on containers which reads "Polyvinyl chloride (or trade name) contains vinyl chloride. Vinyl chloride is a cancer-suspect agent". Exposure hazards for PVC are usually very low. Employees should be aware that PVC itself is not hazardous and thus there is no danger from accidentally coming in contact with the material. The exposure hazard is due to the possibility that some of the vinyl chloride gas may be trapped in the material, and may bp released into the atmosphere. SUMMARY OF THE OSHA REQUIREMENTS The basic rule is that an employee cannot be ex posed to a ratio of more than one part of vinyl chloride concentration to one million parts of air over an eight hour period, or more than 5 parts per million (ppm) over any continuous 15 minute period. The exposure is on a time weighted basis and so. for example, an employee ex posed to 4 parts per million for a one hour period is not in excess of the limit of one part per million for an eight hour day. The time weighted average (twa) for such an employee, for eight hours, would be .5 parts per million. OSHA provides that employers can establish a minimum program of activity if employees are not ex posed above an "action level" of .5 parts per million (twa) tor an eight hour day. The minimum program require ments for a trucking company are: 1. MbriffareypcsuTe fevelsta determine tfthenefaany expcsuTe above the attach level of ,5 pptn 2. Provide training for employees engaged i* ths handling of vmyl chlorides ana polyvinyl enforces. 3. Maintain records. UCC MONITORING 024154 Employers are required to monitor and measure ex posure levels for shipments of vinyl chloride and 4 PRIVILEGED AND / "CONFIDENTIAL MATERIAL / SUBJECT TO PROTECTIVE ` /* ORDER" v'jlyvinyl chloride, and ejmployees or their designated ' representatives are to be afforded a reasonable oppor tunity to observe the process of monitoring and measur ing, Monitoring will be for the various types of shipments handled by the employer, as the exposure level varies according to differences in manufacturing processes. If a shipper changes his processes and exposure levels are increased there must be additional monitoring. The monitoring procedure consists of taking air sam ples at the level of an employee's mouth and nose -- his breathing area. Personal monitoring units are clipped to a person's shirt for this purpose. Samples of air at floor levels are not used because vinyl chlorides are heavier than air and tend to settle at floor level -- well below the employee's breathing area. Monitoring should be of loca tions where there may be exposure such as vehicle in teriors and on freight platforms. Truckloads, loaded by shipper and unloaded by con signee, need not be monitored because there is no ex posure to trucking company employees. Monitoring of LTL should be for the larger shipments usually loaded and unloaded by carrier employees as exposure level varies according to size of shipment. Exposure level, if any, also varies by time and temp erature. Additionally, air flow is a factor in reducing levels as the vehicle moves down streets and highways and as the vehicle is backed to the ioading platform. Monitoring alter the vehicle is at the platform will determine levels, if any, to which employees will be exposed. As a result of monitoring employers may determine that shipments should not be handled until the vehicle has been allowed to ventilate for a period of time. After air samples have been taken they will be pro cessed through an analyzer to determine exposure levels. If the levels are at or below the "action level" of .5 parts per million for eight hours the carrier is allowed to conduct a minimum program. If the level is at or below one part per million (twa) but above .5, the carrier must conduct an extensive program which includes medical surveillance of employees. H the level is above one part per million, or 5 parts per million in 15 minutes, the carrier must establish administrative and engineering controls to reduce exposure levels. If levels cannot be sufficiently reduced through administrative and engineering con trols, the carrier must provide respirators to employees that are exposed to higher levels. 1. OSHA REQUIRES: explain nature of the health hazard for chronic exposure to vinyl chloride includ ing specifically the carcinogenic hazard. Explanation for employees: Vinyl chloride in com pressed gas cylinders is extremely flammable and is under pressure. It also presents a risk of cancer to employees who inhale the gas. Trucking industry employees do not handle vinyl chloride frequently and so they do not have the risk of chronic exposure. (The few workers in processing who suffered cancer had a daily exposure for an average of 19 years) In fact, there is no exposure to transportation -workers unless a cylinder leaks. Polyvinyl chloride shipments may release a very low amount of vinyl chloride gas. Again, trucking industry employees do not have the risk of chronic exposure, nor are they exposed to high levels of gas and so the -nature of health hazard is almost non-existent. 2. OSHA REQUIRES: explain the specific nature cf op erations which could result in exposure to vinyl chloride fn excess of permissible limit and necessary protective steps. Explanation for employees: In routine operations it is not expected that there will be a possibility of expo sure in excess of permissible limits. However, in case of a leak from cylinders the exposure may reach the permissible limit or slightly above in a confined area. Employees should leave an area if there is a leaking cylinder. The exposure levels of polyvinyl chloride are not likely to reach the permissible limit under routine conditions or if a container is leaking. 3. OSHA REQUIRES: explain the purpose for. prooer use and limitations of protective devices. Explanation for employees: Protective devices are designed to protect the employee from breathing air mixed with vinyl chloride above the permissible limit. !n general, protective devices will not be provided to trucking employees because exposure levels do not exceed the permissible limit. If an employee is issued a protective device, or required to use such a device there will be explanation of proper use and limitations. ucc 094-1 c-r TRAINING OSHA requires that each employee engaged in VC or PVC operations be provided training in a program relat 4. OSHA REQUIRES: explain the fire hazard and acute toxicity of vinyl chloride and necessary protective steps. ing hazards and precautions for safe use of vinyl chloride. Training is necessary for those who load and unload and for their supervisors. The items of training required by OSHA are listed below and are followed by employee information de Explanation for employees: Vinyl chloride gas may act as an anesthetic when the exposure level is very high -- at about 3.600 parts per million or higher. The vapor is harmful so employees should evacuate on area if they determine that a vinyl chloride cylinder is signed to meet the training requirements. leaking. The gas is more dangerous because of its 5 flammability characteristics. It is extremely flammable and may be ignited by heat, sparks or open flame. If a cylinder is leaking employees should shut off leaking valves if il can be done quickly and with a minimum of exposure. Otherwise they should notify supervisors and evacuate the area. 5. OSHA REQUIRES: explain the purpose for and a de. scription o! the monitoring program. Explanation for employees: The purpose of the monitoring program is to 'determine the level of employee exposure to vinyl chlorides so that a prog ram to protect the employee safety and health can be instituted as needed. A description of the monitoring program is included in the monitoring section of this information bulletin. 6. OSHA REQUIRES: explain the purpose for and de scription ol the medical surveillance program Explanation for employees: The purpose of the medi cal surveillance program is to determine if there are any adverse effects developing in employees ex posed to levels above the action level. The medical surveillance program will be described to employees if exposure levels for motor carriers employees is above .5 parts per million in which case a medical surveillance program will be instituted, 7. OSHA REQUIRES: explain emergency procedures. Explanation for employees: It is not anticipated that there will be any opportunity for the type of massive release that will result in a need for emergency action. However, in the event of a leaking cylinder of vinyl chloride the employee should evacuate the area to protect himself. If he feels that he can shut off a leaking valve or source of ignition without exposure to danger he should do so quickly. 8. OSHA REQUIRES: provide specific information to aid employees in recognition of conditions which may result in release of vinyi chloride. Explanation to employees: The condition which will result in release of vinyl chloride is a leaking con tainer. Employees should not handle containers which appear defective -- they should notify their supervisor for instructions. Employees should use care in handl ing containers. Avoid use of equipment which is likely to damage containers, do not handle containers roughly or drop them, do not store cylinders near heat or open fiame. In general, follow good freight handling practices. 9. OSHA REQUIRES: a review of this standard at the employees first training and indoctrination program and annually thereafter. Explanation for employees: Your employer will pro vide a review to comply with the OSHA requirement. RECORDS The employer is required to maintain records of monitoring, and if a medical surveillance program is necessary appropriate records must be maintained. Employees or their representatives must be granted ac cess to examine and copy records of required monitoring and measuring. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 024156 July 29, 1975 Union Carbide Corporation River Road Bound Brook, New Jersey 08805 RE: Polyvinal Chloride ATTENTION: Mr. W. N. Sanservino Dear Mr. Sanservino: Thank you for your letter of July 3, 1975. We have reviewed our records for 1974-75, and find several shipments of the material in question. We would appreciate it if you would advise us of several items..... l..Are your shipments below the 5 ppm. If they are will you have a procedure to advise us if the level i Is above 5 ppm. 2...Are you providing the special notification or ident ification on each piece of a shipment. If the above is followed we feel that the exposure for our employees is almost non-existent except in the case of a leaking cylinder or rupture of a container. Very truly yours PEERLESS TRANSPORT CORP James R. irsley \ Director of Safety JRY: jf cc: M. Pollock PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" ucc 024157 TEtePHO.Ni 7A8R4E-A6304:01 >/ McLean Trucking Company' EXECUTIVE OFFICE, 617 WAUCHTOWM STREET WINSTON-SALEM, NORTH CAROLINA 27107 September 10, 1975 MAILING A DO HESS P. O. BOX 213 tlP CODE 7*102 Union Carbide Corp. 270 Park Avenue New York, N. Y. 10017 Gentlemen: Kotor carriers are subject to 0SHA standard 1910.93q which sets forth require ments for protecting employees safety and health when shipments of vinyl chlor ide and polyvinyl chloride are handled. In order for us to comply -- we need to have the following information: 1. The various types of PVC being shipped, frequency and size of VC and PVC shipments, general exposure levels for PVC, 2. Will you provide special identification on shipping papers so that PVC shipments can be easily identified and not confused with other shipments of plastics? 3. Will you assist with monitoring by providing technical people to do the monitoring, by providing personal monitoring units and by analyzing samples? A. Can you establish a control program which will assure that exposure levels are below the "action level" of .5PPM? Will you establish a procedure to notify us of any process changes that will necessitate additional monitor ing of a particular type of commodity? 5. Do you ship PVC in bags, boxes Or drums? * 6. Do you ship trailer loads? Will your company and the consignees handle the loading and unloading of trailer loads so our employees will not be exposed? We will appreciate an early reply and look forward to handling your products safely and without incident. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" HTWjdb Sincerely, McLEAN TRUCKING COMPANY - A/. T. (jJcjkC-- H. T, Wal ton Director, Department of Safety \\ uce 024158