Document pmR5gMx6ngbNRRRaDzR8mr19E

RULES AND REGULATIONS 12343 posed to VC. Also, the eight-hour, time- Secretary of Labor's Order No. 12-71 (36 (4) Employee observation ol monitor weighted average standard suggested by PR 8754), 29 CFR Part 1910 Is amended ing. Employees working In an area or several participants at the hearing (see, by adding thereto a new i 1910.93q to opera'tlon whose ambient air is moni for Instance, TR 178), has been rejected. read as set forth below. In addition, pur tored, or thetr representatives, shall l>c The March 1974 report of tho survey re suant to section 4(b)(2) of the Act (84 given n reasonable opiwrtunlty to observe vealed that several kinds of work or op Stat. 1592; (29 U.S.C. 653)), the stand the personnel monitoring required by erations are of short duration. Loading ard In the new 3 1910.93q Is determined this section. or unloading of a tank car may require to be more effective than the corre (5) Recordkeeping. The results of alt approximately IS minutes. The cleaning sponding standards now in Subpart B cf monitoring shall be recorded In writing. of a reactor may require approximately Part )910, In Parts 1915, 1916. 1017, 1918. The records shall be retained for at least half an hour. An eight-hour, time- and 1926 of title 29. Code of Federal Reg 5 years and shall be made available for weighted average standard would permit exposure to VC at concentrations of 400 ppm for one hour. Such upward excur sions, several times the SO ppm level, can not be permitted to occur. 4. The standard. The standard set out .below contains only the requirements deemed necessary to provide protection before the conclusion of the rulemaking proceeding to be commenced shortly. Because exposure to VC Is hazardous, and because such exposure can occur in the processes of synthesizing or polym erizing of VC or in the handling of VC polymers or copolymers which contain absorbed VC. this standard applies to all such processes and to the handling, re acting, manufacturing, processing, re leasing, repackaging, or storage of any of these materials. The monitoring require ments serve two purposes, to trigger Into operation a compliance program and to check the effectiveness of the program. Also, engineering controls are favored for compliance, and respirators are intended to provide protection until such controls can be installed or in cases where such controls are not feasible. Accordingly, by reason of the foregoing and on the basis of the record of the hearing of February 15, 1974, with ex hibits, the written submissions received before the hearing pursuant to the notice of the hearing, the post-hearing written submissions by the participants at the hearing, the March 1974 report of a fact finding survey recommendations received from NIOSH, and the other data referred to herein, it is found (1) that VC at con centrations in excess of 50 ppm is physi cally harmful and carcinogenic; (2) that exposure to VC at concentrations in ex cess of a concentration of 50 ppm poses a grave danger to employees; (3) that em ployees are presently exposed to VC at concentrations in excess of 50 ppm; and (4) that the emergency temporary stand ard set out below is necessary to provide immediate protection to employees from such danger. Pursuant to section 6(c) of the Occu pational Safety and Health Act of 1970, a proceeding will commence shortly In accordance with section 6(b) of the Act. in wnich the emergency temporary standard will serve as a proposed rule, together with other subsidiary rules. As soon as possible a draft environmental impact statement will be filed with the President's Council on Environmental Quality, and copies will be provided to other appropriate Federal agencies for their comments. Pursuant to sections 6(c) and 8(c) (3) of the Willlams-Stelger Occupational Safety and Health Act of 1970 (84 Stat. ulations, and In Part 50-204 of Title 41 of the Code of Federal Regulations. There fore, these corresponding standards are superseded by the new standard in 11910.93q. 1. In 29 CFR Part 1910, { 1910.93 Is amended by deleting from Table 0-1 the line: " C Vinyl chloride 500 . 1300". 2. Part 1910 of Title 29 of the Code of Federal Regulations Is amended by adding thereto a new 11910.93q to read as follows; 8 1910.93q Vinyl chloride. (a) Scope and application. (1) This section applies to any area or operation in which vinyl chloride (Chloroethene), Chemical Abstracts Service Registry Number 75015, Is manufactured, reacted, handled, processed, released, repacked, or stored. (2) This section does not apply to the handling, storage, or other, use of vinyl chloride polymers and copolymers in the form of fabricated products. (b) Permissible exposure. The occupa tional environment shall be controlled so that no employee Is exposed to vinyl clUoride at a concentration In excess of 50 ports per million (ppm) (127.0 mg/cum). (c) Monitoring--(1) Initial monitortng As soon os possible but not later than April 22, 1974, every employer of an em ployee working in an area or operation in which vinyl chloride is manufactured, re acted, handled, processed, released, re packed, or stored shall begin monitoring the ambient air of the area to determine whether It contains vinyl chloride in con centrations in excess of 50 ppm. (2) Frequency. Monitoring of a suffi cient number of employees so that a representative sample of exposures to vinyl chloride may be determined shall be accomplished not less frequently than weekly until all results for three consecu tive w;eefcs arc at or below 50 ppm. There after, monitoring shall be conducted not less frequently than monthly so long as the concentrations of vinyl chloride do not exceed 50 ppm. If a monitoring sam ple reveals vinyl chloride in concentra tions in excess of 50 ppm, weekly moni toring shall be resumed until all results for three consecutive weeks are at or be low 50 ppm. (3) Method of monitoring. Personnel monitoring shall be accomplished by col lecting samples by suitable devices worn by the employee. The samples shall be analyzed by gas chromatography or by any other method which is of equivalent sensitivity. The analytical procedure shall be sensitive to 5 ppm of vinyl chlo ride in air with an accuracy of 20 per Inspection and copying by representa tives of the Assistant Secretary of Labor for Occupational Safety and Health and the Director of the National Insti tute for Occupational Safety and Health (NIOSH). (6) Employee access. Each employeo and former employee shall have access to such records of the results of monitoring required by this section as will Indicate his own exposure to airborne concentra tions of vinyl chloride. (7) Employee notification. Each em ployer shall promptly notify any em ployee who has been or Is being exposed to vinyl chloride in concentrations in ex cess of 50 ppm, and shall Inform him of the corrective action being taken. (d) Compliance. (1) Whenever any monitoring sample reveals vinyl chloride at a concentration in excess of 50 ppm, or whenever any accident, such as rup ture of equipment or spillage, indicates the likelihood of a greater than usual release of vinyl chloride Into the ambient air, all employees exposed to such con centrations shall be withdrawn to a safe area and shall not be permitted to re enter the work area unless they wear either Type C continuous flow or pres sure demand air supplied respirators or self-contained breathing apparatus. (2) Work which may reasonably be expected to release vinyl chloride in con centrations In excess of 50 ppm. such as repair, maintenance or cleaning of re actors or other equipment containing vinyl chloride, shall be accomplished only by employees wearing Type C continuous flow or pressure demand air supplied res pirators or self-contained breathing ap paratus. (3) In any case covered by para graphs (dHl) or (d)(2) of this section, in addition to providing the required, respirators, the employer shall examine and analyze the source of the excessive concentrations of vinyl chloride in order to determine feasible engineering or op erational controls appropriate to reduce the airborne concentrations to the per- missable level. Such controls shall be implemented as quickly as possible. (4) Periodic tests shall be conducted for equipment leaks and for emissions of vinyl chloride which may result from work practices. 3. In 29 CFR Part 1910, 3 1910.19 Is revised to read as follows; Q0 1910.19 Speciul provision* for air con- CJ\ taniiiiiint*. (a) Asbestos dust. Section I910.93a(^) shall apply to the exposure of every em- \ ployec to asbestos dust in every employ-/^ ment and place of employment covered H) by 5 1910.12. 5 1910.13, 5 1910.14,)-* 1596, 1599; (29 U.S.C. 655, 657)), and cent for a ten minute air sample. 5 1910.15, or 5 1910.16, In lieu of any dif- BFG26000 FEDERAl REGISTER, VOt. 39, NO. 67--FRIDAY, APRIL S, 1974 12344 tneat standard on exposure to asbestos dust which would otherwise be appli cable by virtue of any of those sections. (b) Vinyl chloride. Section 19l0.93q shall apply to the exposure of every em ployee to vinyl chloride in every employ ment and place of employment covered by I 1910.13. I 1910.13. I 1910.14. 11910.15, or 11910.15, In lieu of any dif ferent standard on exposure to vinyl chloride which would otherwise be ap plicable by virtue of any of those sec tions. Sffeetive date. These amendments shall become effective on April 5, 1974. (Sect. 4. e, and S. 64 8tat. IMS. ISM, 1699 (29 Of.C. eSS. eSS, SS7); Secretary of Labor's Order No. 13-71,36 FR 6764.) Signed at Washington, DC., this 2d day of April 1974. John 8tinder, Assistant Secretary ot Labor. (IS Doc.74-7890 Piled 4-4-74;8:4S am) RULES AND REGULATIONS Z809ZS22 FEDERAL REGISTER, VOL. J9. NO. *7--FRIDAY, APRIL S, 1974 BFG26001 APPENDIX B PROPOSED STANDARD ON VINYL CHLORIDE BFG26002 PROPOSED RULES DEPARTMENT OF LABOR Occupational Safety end Health Administration [29 CFR Part 1919] ~ {Dockat oea-saj . VINYL CHLORIDE Proposed Standard 1. Background. Vinyl chloride (chloroethene) Chemical Abstracts Service Registry No. 7501S, Is a synthetic chemi cal made by oxychlorination ot ethylene 43-33). Borne of the experiments have 4. Additional information. On April 15, been concluded, and others are' still on 1S74, Information and data were pre going. The experimental results reported sented to representatives of OSHA, were that tumors have been observed In groups of animals exposed to VC at con NIOSH and the EPA by the Industrial Bio-Test Laboratories, Northbrook, Illi centrations as low as 250 ppm. No tumors nois, concerning results of animal ex were observed In the group of animals exposed to VC at a concentration of 53 posure studies with VC, sponsored by the Manufacturing Chemists Association ppm. It also appears that the total num (MCA). Although only preliminary in ber of tumors, as well as the numbers nature, these results revealed that 2 out of angiosarcomas of the liver, decreased of 200 mice exposed to VC concentrations as the concentrations of VC were reduced of 50 ppm for 7 hours a day, five days a to 250 ppm. Another experiment by Pro- . week, for approximately 7 months, de fessor Maltoni was reported underway veloped angiosarcomas of the liver. or by hydrochlorination ot acetylene. It Involving the exposure of 300 animals ,, The Industrial Bio-Test Lab data in Is the parent compound ot a series ot to VC at concentrations of 50 ppm. In dicate that exposure to VC at 50 ppm themoplastlc sesin polymers and co order to assess In a more definitive way may well constitute a serious health haz polymers which are widely used tor con whether that level of exposure produces ard to employees. Also, the question of a tainers, wrapping film, electrical Insula tumors In animals. Data reported by safe level of exposure for humans can tion, pipe, conduit, and a variety of other Torkelson, C yen and Rowe (American not be determined at this time, and may products. Vinyl chloride has been made Industrial Hygiene Association J 22; 254- continue as a matter for scientific de commercially in this country since 1939 361 (1981)) indicate that exposure to liberation for many years. We therefore and present production Js In excess ot VC at concentrations of 50 ppm failed to conclude that it Is now necessary to pro- seven billion pounds per year. induce tumors In rats, hamsters, rabbits, pose to change the 50 ppm level estab Vinyl chloride (VC) Is a gas at am and dogs. lished In the ETS to as low a level as can bient temperature and pressure and Is A The employees of the B. F. Goodrich be detected using methodologies outlined chlorinated hydrocarbon which has Chemical Company who died from angio in this proposal. moderate liver toxicity. Hie previous sarcoma of the liver had an average ex (5) The proposed permanent standard. standard set a celling value of 500 parts posure of approximately 19 years to vinyl The requirements for a complete stand per million (ppm) (29 CFR 1910.93, Table chloride, at unknown concentrations, ard under section 3(b) of the Occupa 0-1). and variable exposures to other .volatile tional Safety and Health Act of 1970 On January 22,1974, the Occupational Safety and Health - Administration (OSHA) was Informed by the National Institute for Occupational Safety and Health (NIOSH) that the B. F., Good rich Chemical Company reported that deaths of several of Its employees from a rare liver cancer (angiosarcoma) may have been occupationally related. As a result of this notification and after con sultation with the National Institute for Occupational Safety and Health (NIOSH), and a Joint Inspection of the plant by OSHA, NIOSH, and the Ken tucky Department of Labor, a fact-find ing hearing on possible hazards Involved with the manufacture and use of VC was announced on January 30: 1974 (39 FR 3374) and held on February 15, 1974. 2. Carcinogenicity ot -VC. Information produced at this hearing demonstrated that exposure of laboratory animals (meetly Sprague-Dawley rats) to VC by Inhalation at and below the then current OSHA standard of 500 ppm Induced tumors, including angiosarcomas of the liver. Professor Cesare Maltoni, of the Instituto dl Cncologia, Bologna, Italy, reported on a series of experiments on the effect of exposure of rats, mice, and hamsters to VC at concentrations of 10,000; 3.000; 2,500; 500; 250; and 50 ppm for varying periods of time (TR- chemicals. <TR S3). Some employees of Union Carbide, Firestone Tire and Rub ber, and Goodyear were also reported in post-hearing comments to have had ex posure to vinyl chloride and to have died from angiosarcoma of the liver. Finally, autopsies of four deceased employees re vealed their liver angiosarcoma tumors were histologically indistinguishable from the angiosarcoma tumors observed In Professor Maltoni's experimental animals. 3. The Emergency Temporary Stand ard. On the basis of ail Information available at that time, and the fact that employees were being exposed at levels around the experimentally observed ef fect level of 250 ppm, an Emergency Temporary Standard (ETS) was promulgatedon April 5, 1974 (39 PR 12342) as 29 CFR 19!0.93q. This standard reduced the level from a celling of 500 ppm to 50 ppm ceiling. It was expressly recognized that this standard limiting exposures to a 50 ppm level was Intended to be a ten tative, interim standard, to be In effect no longer than six months, during which time the whole question of possible safe exposure to VC would be reconsidered more fully and in the light of more In formation. especially results of experi ments which were known to be under way at that time. are much more comprehensive than the provisions of the ETS promulgated on April 5. The following proposals are re sponsive to the additional information on the carcinogenicity of VC, and the requirements of the Act. A. Level of exposure. The proposed standard for employee exposure is set at no detectable level, as determined by a sampling and analytical method capable of detecting vinyl chloride at concentra tions of 1 ppm with an accuracy of 1 ppm-50 percent. Although more sensi tive methods may be available now or in the future, the methodological sensitivity proposed appears to be the most feasible and generally available. A method of ,1 ppm sensitivity has been recommended to OSHA by NIOSH. To minimize the number of persons at risk, a require ment would be established for regulating areas where vinyl chloride is manufac tured, reacted, stored, handled, released, repackaged, or used, including opera tions with polyvinyl chloride containing detectable levels of vinyl chloride. Access to the areas would be limited to author- ized employees. B. Monitoring. A program of monitor- ing would be required to establish whether there are detectable levels in regulated areas and to permit determina- tion of employee exposures on an In- xj V* \JU (j^ At dividual basis. Provision would also be GO P6DMAI KtGISTER, VOL 39, NO. 92--FRIDAY, MAY 10, 1974 BFG26003 PROPOSED RUIFS 16897 made for an opportunity to observe monitoring by employees or their desig nated representatives, as required by sec tion 8(c) (3) of the Act. C. Control method*. Where detectable levels of VC are monitored, two pro grams would be triggered; an engineer ing and work practice program to reduce levels below detectability; and while this is on-golng, a respiratory protection pro gram for employees in the regulated area. Engineering controls and work prac tices are favored methods of compliance because they tend to avoid contamina tion of the ambient air In the workplace. Accordingly, It Is proposed to require the Institution of engineering controls and of workpractlce methods as soon as feasi ble, and to require the use of respirators pending the Institution of such controls, to supplement such controls where they are Insufficient to reduce concentrations of vinyl chloride below the detectable level, in specified work situations, and In cases of emergency. The proposal for continuous flow and pressure demand types of respirators Is based on the rec ommendations of NIOSH, which has ob served leakage through chemical car tridge respirators at high concentrations of VC. A requirement would also be estab lished for the provision and use of pro tective clothing for employees In the reg ulated areas. The protective clothing would minimise skin contact with' VC vapor, and would provide some measure of protection from splash of liquid In the event of a spill or rupture of equip ment. Food, beverages, and like products would be prohibited In the regulated area. Written operational and emergency plans would be required, along with em ployee training In routine and emergency duties. Specific requirements would be established for emergency actions and for routine maintenance and decontami nation operations. Including vessel entry, which are known to present particular hazards. The purposes of operational and emer gency plans and training are to apprise employees of the hazards to which they may be exposed, of the precautions they must take to avoid such hazards, and to rehearse employees In the procedures they must follow in emergencies. D. Medical surveillance. Comprehen sive requirements for employee medical examinations are proposed. Including necessary tests. Some additional guid ance is included for the convenience of physicians. The proposed requirements have been recommended to OSHA by NIOSH as reasonably appropriate to de tect liver dysfunction which may be in dicative of, or predisposing to, the de velopment of liver angiosarcomas. E. Records and reports. Records of monitoring, medical examinations, and entry .to regulated areas are proposed, with provision for access by appropriate OSHA and NIOSH officials. Specific pro visions for employee access to monitoring records are included, as well as the re quirement to furnish a copy of a medical record to an employee's physician on the employee's request. Establishments con ducting VC operations would be required to Identify themselves to OSHA, and to report incidents (accidents) resulting la the release of vinyl chloride. Accordingly, pursuant to sections 8(b>, 8(c), and 8(c) of the Occupational Safety and Health Act of 1970 (84 Stat. 1593,1598, 1599; 30 U.8.C. 665, 857), Sec retary of Labor's Order No. 12-71 (38 FR 8754) and 39 CFR Part 1911, It. is here by proposed to amend 3? CFR Part 1910 by revising i 1910.93q as set forth below. Written data, views, and arguments concerning the proposals may be mailed to the Docket Officer. Docket OSH-36, Room 330, 1736 M Street N.W., Occupa tional Safety and Health Administra tion, Washington, D.C. 20310, post marked not later than June 10, 1974. Pursuant to 29 CFR 1911.11 (b) and (c). Interested persons may file objec tions to the proposals, requesting an In formal hearing with respect thereto, in accordance with the following condi tions: (1) Hie objections must Include the name and address of the objector; (2) The objections must be post marked on or before June 10,1974; (3) The objections must specify the provisions of the proposed rule to which objection is taken, and must state the grounds therefor; (4) Each objection must be separately stated and numbered; and (5) The objections must be accom panied by a summary of the evidence proposed to be adduced at the requested hearing. As revised, l 1910.93q would read as follows: 1910.93q Vinyl Chloride. (a) Scope and application. (1) This section applies to any area or operation In which vinyl chloride (chloroethene), Chemical Abstracts Service Registry No. 75015. is manufactured, reacted, re leased, repackaged, stored, or used,. In cluding areas and operations Involving polyvinyl chloride where detectable levels of vinyl chloride are released. (2) This section does not apply to the handling or use of fabricated products made entirely or in part of polyvinyl chloride. (b> Definitions. (1) "Assistant Secre tary" means the Assistant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor or his designee. (2) "Authorized employee" means an employee whose duties require him to be in the regulated area and who has been specifically assigned by the employer; and any employee who enters such an area as a designated representative of employees to exercise an opportunity to observe monitoring and measuring of vinyl chloride. (3; "Closed container" means any container which prevents the release of vinyl chloride to the environment. (4) "Contaminated" means capable of releasing a detectable level of vinyl chloride. (5) "Decontamination" means reduc tion of vinyl chloride concentrations to leas than detectable levels. (6) "Detectable level" means an air borne concentration of vinyl chloride measurable by a sampling and analytical method capable of measuring concentra tions of 1 ppm, with an accuracy of l ppm60 percent. (7) "Director" means the Director, Na tional Institute for Occupational Safety and Health, or any person directed by him or the Secretary of Health. Educa tion, and Welfare to act for the Director. (8) "Emergency" means an unforseen circumstance or set of circumstances, re sulting in the release of vinyl chloride Into areas occupied by employees. (9) "Exposure" means actual contact with vinyl chloride when unprotected by required personal protective equipment and clothing. (10) "Fabricated product" means a finished product or part of such product, made of polyvinyl chloride, entirely or In part, including semifinished products such as film, sheet, block, bar, or extru sion stock. .. (11) "OSHA Area Director" means the Director for the Occupational Safety and Health Administration Area Office hav ing jurisdiction over the geographic area in which the establishment Is located. (12) "Polyvinyl chloride" means poly vinyl chloride homopolymer or copol ymer before such Is converted to a fab ricated product. (13) "Protective clothing" means clothing protective against vinyl chlo ride. (14) "Vinyl chloride" means vinyl chloride monomer. (15) "Waste resin" means any resin or pther reaction products removed In the cleaning of equipment, such as ves sels and piping. (c) Reference. College of American Pathologists. 230 N. Michigan Ave., Chi cago, Illinois 60601. (4) Regulated areas. (I) A regulated area shall be established where (1) vinyl chloride is manufactured, reacted, re leased. repackaged, stored, or used; or (ii) polyvinyl chloride capable of re leasing detectable levels of vinyl chlo ride Is manufactured, reacted, released, repackaged, stored, or used. (2) Access to regulated areas shall be limited to authorized employees. (3) A daily roster of employees enter ing regulated areas shall be made and maintained. The rosters, or summaries thereof, shall be kept for at least 20 years. (e) Monitoring. (1) Every regulated area shall be monitored for detectable levels of vinyl chloride. (2) The monitoring shall assure that any exposure may be determined for each authorized employee with a confi dence level of 95 percent. (3) Employees or their designated rep resentatives shall be afforded an oppor tunity to observe monitoring and measur ing required by this paragraph. (1) Where exercise of an opportunity requires entry to an area where the use 23526085 No. 93--pt. i---10 FEDERAL REGISTER, VOl. 39, NO. 92--FRIDAY, MAY 10, 1974 BFG26004 16898 hoposso uucs of protective clothing, equipment, fa <2) There shall be tests made far . 0) Smergencv situation*. (D A writ- cilities. or procedures is required, such process or equipment leaks and for emis _ ptol l9t clothing, equipment, facilities, sad pro sion of vinyl chloride which mag result situations shall be developed for each cedures shall be provided to all persona from werkpractioM. The frequency of regulated area. entitled to exercise the opportunity, at do these testa shall be such as to insure the (3) In the event of an emergency, ap OQS& to any Qf Integrity of equipment and adherence to propriate pnrtieeis of the plan shall be (U) Persona exercising the opportu proper eorkpractices. put into operation. nity shall be instructed regarding: <g) Respiratory protection. (1) A res (t) Fasankms oondlttona cteated by (A) The toxicity and fire haaard of piretocy protection program in accord the emergency shah be aUmimried and vinyl chloride; and ance with ^ 1014-134 shall be established the adjected area shall he decontami (B) The protective steps azxi measures and implemented where respireton are nated prior to tbs resumption of normal necessary for their protection. required to be used by this section. nparatiriiu (ill) Observed shall be permitted, C3) Respirators-anall be used only in (U) Special medical surveillance by a without interference to the persons per cases at emergency and where required physician shah be instituted within 34- forming the monitoring and measuring, by any other provision of this section. hours for employees present in the af to; (A) Observe all steps and procedures related to Um collecting, processing, and evaluation of particular monitoring and measurement samples; (B) Record quantities sad results obtained; (C) Observe the condition of monitor ing and measuring equipment; Respirators may not be used in lieu of feasible engineering controls or workpractice methods. <3) Respirators or combinations at respirators for protection against vinyl chloride shall be selected from among the tollowing: (1) A positive pressure full facepiece self-contained breathing apparatus; (ID A pressure- demand full facepiece fected area at the time of the emergency. (ill) Where an employee has a known contact with liquid vinyl chloride such employee shall be required to shower as osn ae. possible, unless contraindicated by physical Injuries. (iv) An incident report on the emer gency shall be reported ae required In paragraph <q) (3) of this section. (S) Rash asrihoriaed employe* shall CD) Receive a demonstration of the self-contained breathing apparatus op be- trained in a program relating to the and function taste of the erating in the pressure-demand mode; haaards of vinyl chloride and the pre monitoring and measuring equipment performed on site; and (UD A comfatnatloa type "C" pressuredemand full facepiece rapirator oper cautions lor safe use. <i) The program shall include: <S) Rxaminc instructions and docu- ating in the pressure-demand mode and (A) The natureof the Are toward, and menta related to the procedures' and equipment for monitoring *bd measur ing. (4) Accurate and complete records of all required monitoring shall be made and maintained for not less than 30 yean. Such a record shall (1) state the date of such monitoring and the levels determined; and (li) identify the instru ments and methods used. <f) Xngtneertng controls and' workpractice methods. (1) Where detectable levels of vinyl chloride are measured, immediate protection shall be provided against exposure to vinyl chloride by the use of engineering controls, workpractlce methods, and respirators as follows: (1) Feasible engineering controls and workpractlce methods shall Immediately be used to reduce airborne concentra tions of vinyl chloride below the detect able level; (ID Wherever feasible engineering controls and workpractlce ' methods which can be instituted immediately are not sufficient to reduce concentrations of vinyl chloride below the detectable level, they shall nonetheless be used to' reduce the concentrations to the lowest prac ticable level, and shall be supplemented by means of respirators in accordance with paragraph (g) of this section; a pressui^-demand self-contained breathing apparatus operating In the pressure-demand mode; or <iv) A combination type "C" continu ous flow respirator and a preesuredemand self-contained breathing ap paratus operating in the pressure-de'mand mode. (h) Protective clothing. (1) Employees entering regulated areas shall be pro - the necessary protective steps; (B) The nature of the toxic hazard, including local and systemic effects, And cflfecti specifically the carcinogenic hazard; (O The specific nature of operations which could result in exposure to vinyl chloride, and necessary protective steps; CD) The purpose for and application of the medical surveillance program; CS) The purpose lor and application vided full-body protective clothing, foot of decontamination practices; wear or shoe covers, and gloves, at no (P) The purpose for and significance cost to them, and required to wear it of emergency practices and procedures; while in the regulated area. (0) The employee's specific role under <3) Where polyvinyl chloride powder normal operating or emergency condi containing detectable levels of vinyl tions; chloride is handled, employees shall (H) Specific Information to aid the also be: employee In recognition and evaluation (1) Provided and required to wear of conditions and situations which may headcoveriags; result in the release of vinyl chloride; (li) Required to remove all protective clothing at each exit from the regulated area; and (lit) Required to shower after the last exit of the day. - (3) Clean protective clothing shall be provided whenever contaminated or soiled, but not less frequently than weekly. Contaminated clothing shall be decontaminated before reuse by removal for laundering or disposal. (1) The purpose far and application of specific first aid procedures and prac tices; <J) A review of tills standard at the employee's first training and indoctri nation program and annually thereafter. (II) AQ materials relating to the pro gram shall be provided upon request to authorised representatives of the Assist ant Secretary and the Director. (k) -Signs and labels. (1) Entrances to regulated areas shall be posted with signs (iii) Wherever no feasible engineering (i) Hygiene laciUties amt practices. bearing the legend: control or workpractice method can be instituted immediately, immediate res piratory protection shall be provided in accordance with paragraph (g) of this section; and (tv) In any case covered by paragraph (f)(1) (il) or (Hi) of this section, the (1) Where employees are required by this section to wear protective clothing and equipment, change rooms shall be provided In accordance with { 1810.141(e). (2) Where employees are required by this section to shower, shower facilities CANCER-SUSPECT AGENT AREA AUTHORIZED PERSONNEL ONLY (2) Areas containing operations cov ered In paragraph (fc)(l>(4> of this sec tion shall be posted with signs bearing the legend: employer shall also undertake as soon as practicable a program to reduce airborne concentrations of vinyl chloride below the detectable level, or to the greatest shall be provided in accordance with i 1910.141 (d)(3). (3) 8torage or consumption of food or beverages, storage or use of smoking CANCER-SUSPECT AGENT IN THIS AREA PULL IMPERVIOUS AIR-SfIPPUED EQUIP MENT REQUIRED AUTHORIZED PERSONNEL ONLY extent feasible, solely by means of engi or non-food chewing products, and the (3) Containers of waste, or other ma neering controls and workpractlce meth storage or application of cosmetics are terials contaminated with vinyl chloride ods and as soon as feasible. prohibited in regulated areas. shall be labeled: MOCKAt MCritat, VOL 34. I0. tJ--fSlDAV, MAY 10. 1474 BFG26005 16900 worosED cum v'2) In the event that the employer (Bmb. 4(b). 4(e), aad 4<e), 44 Stot. 144S. ceases to do bustaen and there ta no suc ISM, IBM (to DAC 414, 447); Aswtary f cessor to receive and ret*In tale records Labor's Qrdsr No. 13-71 (M IB I7S4)) lor the prescribed period, these records, Signed at Washington. DC. (his 8th shall he transmitted by registered mall to Use Director, and each employee indi vidually notified In writing of this transfer. <S) Employees and their designated dayof Uay, U7. Jan Brumes, Assistant Secretary at labor. [TR Doct-74-iene rasa s-*-v;8:*s em) representatives shall be prodded access to end copy records at monitor ing and measuring. (4) Former employees shall be pro vided aeces to examine and copy reoords reflecting their own exposures. (81 Upon written request of any em ployee, a copy of the medical record of gnets employee shall be furnished to a physician designated by the employee In such-request. <q> Reportt. (1) Not later than _ the fallowing information shall be reported to tbe OBHA Area Director. Any change in such information shaB be reported to the OSHA Area Director within IS days of such change. . (1) The addresB and location of each establishment which has one or more regulated areas; and <li) The namber of employees in each regulated area during normal operations, (!) incidents which result in the re lease of vinyl chloride Into any area where employees may be exposed shall be reported in accordance with this para graph. (i) A report of the occurrence of Urn incident and tbe facts obtainable at that time including a report on any medical treatment of affected employees shall be made within 24 hours to the OSHA Area Director. (11) A written report slUOl be filed with the OSHA Area Director within 15 calendar days thereafter and shall in clude: (A) A specification of the amount of material released; (B) A desetiption of the area involved and the extent of known and potential employee exposure and area affected; (C) - A report on any medical treat ment of affected employeee and any medical surveillance program imple mented; and (D) An analysis of the circumstances of the Incident, and measures taken at to be taken, with specific completion dates, to avoid further similar releases. (I) Upon completion of any monitoring and measuring which discloses that any employee has actually been exposed to detectable levels of vinyl chloride, each such employee shall be Individually noti fied In writing. The notice shall; (1) Be delivered not later than 10 working days after completion of the z" mltoring and measuring; cii) State the actual exposure in tonne of concentration and ttae; and (Hi) State the steps which have been taken, an being taken, and will be taken, with specific completion dotes, to termi nate tbe exposure and prevent a recur rence. BFG26006 eSDCSM MOUTH, VOL. to. NO. W-NUBAf, MAY 1<L 1V74 APPENDIX C INDUSTRIAL HYGIENE SURVEY REPORT ON VINYL CHLORIDE BFG26007 APPENDIX C INDUSTRIAL HYGIENE SURVEY REPORT ON VINYL CHLORIDE AND POLYVINYL CHLORIDE MANUFACTURING FACILITIES BY DIVISION CF HEALTH STANDARDS DEVELOPJ*NT OFFICE OF STANDARDS DEVED3PNENT MARCH 1974 BFG26008 23526089 SUMMARY 1. Five vinyl chloride monomer (VCM) and two polyvinyl chloride (PVC) manufacturing facilities In the New Orleans - Baton Rouge area have been visited by the staff of the Office of Standards Development during a fact-finding survey. 2. The PVC manufacturers have a more serious problem of VCM exposure than the VCM producers because most of the polymerization process, equipment in enclosed areas and ventilation is inadequate. 3. Leaks from the process equipment, vessel entry, VCM tank car loading, unloading, and process sampling, PVC reactor cleaning, compounding and packaging are the major potential sources of VCM exposure found during this survey. 4. Engineering technology for the control of VCM exposure is available and has been implemented by the industry. 5. The observed practices relative to equipment maintenance, monitoring, medical examination and surveillance, and training are considered to be inadequate to control the employee's exposure to vinyl chloride. 6. The fact-finding survey was found to be very useful In the development of proposed rulemaking of health standards. BFG26009 INDUSTRIAL HYGIENE SURVEY REPORT ON VINYL CHLORIDE MANUFACTURING AND POLYMERIZATION FACILITIES Introduction A fact-finding survey of several vinyl chloride monaner (VCM) and polyvinyl chloride (PVC) manufacturing facilities has been conducted by the staff of the Office of Standards Development during the week of March 11. Five VCM Plants and two PVC Plants in the New Orleans and Baton Rouge area were visited during this survey. A list of all plants is presented in Table 1. Process The VCM is either produced by the direct chlorination or oxychlorination of ethylene to ethylene dlchlorlde (EDC) and pyrolysis of EDC to VCM or by the reaction between acetylene and hydrogen chloride. The crude VCM Is purified by distillation to yield a product having purity of 99.99X. The PVC is produced by either wet or dry polymerization process. The wet process is carried out by reacting VCM in aqueous solution containing dispersing or emulsifying agents and catalyst. The dry process produces PVC by direct reaction between VCM and catalyst in a two-stage reactor. The unreacted VCM is separated from the PVC and the raw PVC is classified into desirable size. Block diagrams of various processes are presented in Flguee 1 through 4. Potential Area of VCM Exposure and Its Control Based on observations of this survey, the areas where exposure to VCM is likely in a VCM plant during normal operations are: 1. Sampling and analysis of VCM for quality control. 2. Loading of VCM for shipping. 3. Entry of VCM containing vessels for maintenance and repair work. 4. Leak of VCM in the process area. -1- BFG26010 1603ZSSZ The areas of VCM exposure la e PVC pleat cea be si irlzed as the follovlag: 1. Unloading of incoming VCM. 2. Reactor cleaning. 3. Entry of VCM containing vessels for maintenance and repair work. 4. Entry of PVC storage silos. 5. Compounding of PVC into molding powder. 6. Shipping or packaging of PVC. 7. Leak of VQf in the process area. The VCM plant is operated around the clock and usually five or less employees are worked on each shift. One or two of these employees have to stay outside for one or two hours per shift to take samples, check gages and handle minor maintenance or repair work. About ten VCM samples are collected per shift by one employee. The VCM is . collected in a sampling bomb with the time of collection being about one minute. The sampling port can be modified to reduce the exposure of VCM during such operation. Loading or unloading of VCM is another area of possible VCM exposure. Most loading is done on day shift only and the employee is loading eight or less tank cars at one time. Each loading operation takes about ten minutes. However, if more than one tank car is being loaded at one time the employee may spend as much as six hours on the loading deck every day. One company official claimed that they are installing a system to reduce the emission of VCM during loading. Since the loading deck is located in open space and ventilation is good and if the emission control system is installed and the employee is standing at the upwind direction with gloves and face shield, the exposure to VCM is insignificant. The reactor cleaning is probably the area where VCM exposure is highest among VCM and PVC plants. The manufacturing of the PVC is still a batch process and the reaction time is about eight hours. The agitator and the bottom part of a wet process reactor is cleaned after two or three batches were made. The whole reactor of the dry process is -2- BFG26011 Z609ZZ cleaned after each batch was made. The average cleaning time Is 30 minutes and usually two employees are performing the task. The dry process reactor is cleaned by using scraper and chisel under local exhaust ventilation. It is a dusty operation and no personal protective equipment of any kind is being used. A filter head which separates unreacted VCM from the PVC is cleaned by compressed air. The operator also uses compressed air to blow dust off his body. The cleaning should be performed by vacuuming or by using scraper equipped with local exhaust ventilation. In addition, the operator should wear coveralls, face shield and gloves with or without supplied air respirator depending on the residual concentration of VCM in the reactor. After the reactants and products have been removed from a wet process reactor vessel, it is filled with water and rinsed one time before cleaning. The cleaning is under local exhaust ventilation. Chisel and scraper are also used for cleaning this type of reactor. Since the reactor surface is wet, dust exposure is not a problem. However, the exposure to VCM may be likely because cold water rinse is not effective to remove the residual VCM adsorbed on the walls of the reactor and steam purging is preferred. No test for VCM concentration in the reactor was made prior to entry. It is a good practice to require the use of supplied air respirator for any reactor cleaning work. Most employers indicated that they have established procedures for vessel entry and in some companies a permit is required prior to initiation of such operations. It is questionable whether these procedures are enforced, especially regarding VCM exposure A re quirement containing details regarding entry of VCM containing vessel for maintenance or repair work should be included in the proposed standard. There is no information available to date regarding the desorption of VCM from the surfaces of the PVC particles during storage and handling. However, it is preferahle to establish a procedure for the entry of PVC storage silos and require local exhaust ventilation systems be installed in all PVC compounding, packaging and loading operations where PVC dust can be released. Although the manufacturing of VCM and PVC is under pressure in a:closed system, exposure to VCM is unlikely during normal operation. However, inadequate maintenance and wear of packings and seals of process equipment can results in leaks of VCM. Nearly all the VCM exposures are outdoors in the VCM plants while most - PVC manufacturing operations except in the deep south and west coast where winter climate is mild are enclosed. The exposure of VCM from equipment leaks can be significant in a PVC plant. We found that most 23526093 -3- BFG26012 of the plants do not have maintenance crews on all three shifts and preventive maintenance program is inadequate or non-existent. We should ask the employer to implement a maintenance program to insure that the leakage of VCM is unlikely during normal operations. An equipment check list shoild be prepared and the frequency of inspection should be based on the probability of failure or mal functioning of equipment, piping or fittings. The equipment maintenance and repair record should be Included in the OSHA record keeping requirements. Ihe VCM samples collected in the bombs are analyzed by gas chromato graphy in a quality control laboratory. If the bomb is stored in an exhaust hood with good ventilation end the sample is withdrawn from the hood, no exposure of VCM is expected during such operations. Monitoring Before the outbreak of liver cancers in the Goodrich PVC plant, the VCM was considered a fire hazard and less precise sampling and ana lytical methods.were used for monitoring. This still appears to be the case from the observations gathered on this survey. We obtained some monitoring data from several VCM plants. Only one PVC manu facturer promised us to send us monitoring data on PVC operations. Another PVC plant uses a combustible vapor tester for monitoring VCM exposure and this type monitoring is neither accurate, specific, nor sensitive to low concentrations of VCM. Gas chromatograph (GC) appeared to be a common instrument used for the analysis of VCM. The VCM is either collected as grab or timeweighted-average (TWA) samples in gas-tight syringes, plastic bags or activated charcoal tubes. By reviewing the monitoring data submitted by two VCM plants (Table II & III) though the data is limited; however, it does indicate that VCM loader , process sample many and maintenance personnel are most likely exposed to higher levels of VCM than other employees in these plants. The method of control of VCM exposure for these employees are discussed in the previous section. 4- BFG26013 23526034 There is wide difference between the sampling method and analytical techniques for VCM. Standardised sampling and analytical prpaedures should be established for the monitoring of VCM. This may be obtained through NIOSH. Most plants indicated that they are acquiring fixed continuous monitoring stations and more sophisticated portable monitoring devices for VCM in their facilities. A guideline snould be laid out to gee the maximum benefit for the use of such Instruments. VCM can be detected by the GC techniques: in the order of 1 ppm. The detectable range of two promising portable direct reading VCM detectors are in the order of 1 ppm. The accuracy of these Instruments at such low concentration may be 50Z. The accuracy of GC is dependent on the preparation and cal ibration of the standard. The reliability of a prepared standard at 1 ppm may aleo pose a problem. A 2 ppm concentration may be the lowest limit at which we can have reasonable confidence on these instruments. The required method of monitoring is dependent on the permissible limit on the proposed standard. If a limit is set, the VCM exposure for each job classification should be monitored on a TWA basis. Personal breathing samples should be collected on a sampling device having a collection efficiency of at least 95Z. Sufficient number of area samples should also be collected to pin point high exposure areas for the implementation of control measures. The sensors of a continuous VCM monitoring system can be located at high exposure areas of VCM. The Initial monitoring of the workplace should take abnormal operating conditions such as hot weather into consideration and monitoring should be repeated on a periodic basis or after process modifications and repairs. If no exposure limit is being proposed, the initial monitoring is still required for the implementation of engineering controls. The mse of direct reading and continuous monitoring instruments are more imperative since no leaks can be tolerated under such circumstances. The monitoring should be conducted on a dally basis at predetermined sampling points. -5- 23526095 BFG26014 Medical All plants have preplacement physical examination programs. However, periodic physical examination Is not a common practice. Two of the six plants have a physician and nurse staff on duty, the others have a physician and nurse on the part time basis. Most supervisors and selected employees are trained in first aid. Since the outbreak of the Goodrich liver cancer, more companies have started providing SMA-12 or other tests to employees who are handling VCM. However, few of the companies Indicated that they are conducting medical surveillance of their employees as a routine program. Because Dow Chemical Company Is the leading producer of chlorinated hydrocarbons in this country, they have put more emphasis on liver function testing of their employees. The medical surveillance program as presented to us by Dow (Table IV) can be used as a basis for the medical requirement In our proposed vinyl chloride standard. Engineering Control Ventilation Is still an effective method to control the VCM exposure. The control rooms In all the VCM and PVC plants are air conditioned, however, the air Is withdrawn from the process area and discharged outdoors without any purification. The inlet air to the control room should be treated if a standard with very low or no permissible limit Is proposed. Engineering control methods are available for the control of VCM exposures during sampling and loading ooerations. However, a reasonable time should be allowed for the Implementation for such measures. This is also true for the Installation of local exhaust ventilation systems. It may be more practical to allow time for the Implementation of engineering control measures or an Interim standard could be set to give employees some protection while the employer is provided with time for Implementation of such controls. Usually, a time period of six months may be sufficient to Install VCM emission control system and one year for ventilation systems. 2352609s -6- BFG26015 Personal Protective Equipment All plants visited have self contained breathing apparatus (SCBA) or Gas Mask for emergency use and they indicated that every employee is trained to use such equipment. Two plants use canisters made for acid gases or ammonia other than organic vapor to equip their gas masks which is not considered to be suitable and one plant uses a quarter facepiece emergency escape respirator as a standard accessory for every employee and visitor in the process area containing hydro carbons. This practice may give an employee a false sense of security and he may be exposed to high concentrations of VCM and still believe he is adequately protected. Supplied air respirators, either in continuous flow or pressure demand mode should be used for reactor cleaning or maintenance and repair work inside of a vessel containing VCM. One plant used supplied air for cleaning of reactors, however, no pressure reducer nor contaminant filtering device were found in the adjacent air supply. The present OSHA standard on breathing air quality is based on the recommendation of the Compressed Gas Association (CGA) which has higher tolerance for the common contaminants in the compressed air such as oil, carbon monoxide, etc. A low tolerance of these air contaminants and VCM in the breathing air and more specific, accurate and frequent monitoring methods should be proposed to insure that the quality of the breathing air is acceptable. The use of gas masks equipped with activated charcoal adsorbent for the VCM will depend on whether we propose a standard with or without a per missible liiit. Based on a test conducted by Gary Nelson of the Lawrence Livermore Laboratory, he indicated that the activated charcoal in a organic vapor canister or catrldge is not a good VCM adsorbent. From his results, the time to reach 1% breakthrough of VCM at a concentration of 1,000 ppm, 50% relative humidity, 22* C and a breathing rate of 53.3 Lpm is 3.8 minutes against 77 minutes for carbon tetrachloride. The present problem with organic vapor adsorbent is there is no indication of the useful life of such substance. The manufacturer's common practice is to set a shelf life of about three years from the date of manufacture with the assumption that the seal of the canister or catrldge is remained intact. Once the seal is broken, the useful life will be one year. 23526097 -7- BFG26016 Use of gas masks give an operator more freedom of movement than a supplied air respirator er SCBA. This is particularly true for the process sample man and tank car loader. If gas masks are permitted to be used when a permissible limit of 5 or 10 ppm is proposed, the requirements for periodic renewal of canisters on different levels of VCM exposures should be specified in the proposed standard. Safety glasses, goggles, hardUhat and gloves are commonly used in all plants visited. Since liquid VCM is an irritant to skin and mucous membranes, the use of eye protective devices and gloves should be made mandatory for employees who may contact liquid VCM. The VCM vapor or gas is not considered to be absorbed through the skin in sufficient amounts. The use of ordinary protective clothing is useless,and the need for an air supplied impervious suit is questionable in operations involving VCM exposure. The PVC reactor cleaning can be a dusty task, and a cloth coverall or whole body covering is a good personal hygiene practice. If VCM is not found to be absorbed through the skin then the requirement for shower facilities may-not be necessary. Housekeeping Except for one plant, the general impression on housekeeping is that it is inadequate. This problem is more evident in the FVC plant since particulate material is Involved. More effort is needed on Immediate cleanup of spills and keeping the work environment in a cleaner, more orderly fashion. Maintenance is another problem area. Preventive maintenance seems nonexistent and most of the plants have maintenance staff on day shift only. Since the leak of VCM from the process equipment, pipelines and fittings may be the significant source of unnecessary exposure in the Industry, a more stringent maintenance program is imperative. 23526098 -8- BFG26017 Work Practice Most of the plants visited have either written or informal procedures regarding operations where VCM exposure is likely, such as process sampling, tank car loading, reactor cleaning and vessel entry. We may issue mandatory work practice procedures on these operations. A written procedure and checklist should be prepared for these operations. Reactor cleaning and vessel entry should be performed by permit signed by the employer or his representative to Insure that all precautionary measures regarding minimising employee's exposure to VCM during such operations are enforced. Quite a few chemicals are used in the manufacturing of VCM or PVC. Some of them can be very toxic such as hydrogen chloride, chlorine or mercury salt. fhe toxic properties of some raw materials are not available at this time. It should be a safe practice to require the employer to evaluate the toxicity of every raw material he uses and establish written procedures for the safe handling of such substances. Training Most employers Indicate that they have training courses for VCM operators and regular safety meetings to educate their employees. Some companies use the word-by-mouth training techniques)and such training is conducted by foreman. The success of such type of training Is dependent on the quality of the Instructor. In general, a written training manual should be preferred and should Include items such as the hazards of VCM and other toxic raw materials, work practices, use and care of personal protective equipment, first aid, emergency procedures, fire fighting and safe handling of the VCM. It is imperative that an untrained employee should not be permitted to work in the VCM or PVC process arsa and refresher courses on these subjects should be given on a periodic basis. A monitoring system should also be established to insure that an employee is benefiting from such training. Waste Disposal Both of the PVC plants claimed that the unreacted VCM is recycled back to the process. The off specification VCM is reprocessed to meet the requirement. One PVC producer discharges the scraps from reactor cleaning into a pond and another collects the waste into boxes for sale to a scrap dealer. One plant loads the PVC in box cars under pneumatic force. It is a closed system, any powder released from loading is sent back to the storage silos. Since the toxic effect of PVC is not known to date, it may be unreasonable to require the manufacturers to dispose of the PVC waste in Impermeable bags since the bags are probably made from PVC or to require the incineration of PVC or VCM as a means of disposal because the decomposition product is toxic. We may require procedures to be established for the destruction of these substances by a safe chemical method or just leave this paragraph open until we get more information. 03 LA Ni 9- BFG26018 <T> to to Conclusion The exposure to VCM is leBs of s problem to the VCM producers than to the PVC producers because all the process equipment of the former are located outdoors with fewer employees and control is less expensive to Implement. Most of the PVC manufacturing facilities are enclosed and more employees are involved in the production. Engineering Control is more expensive because of the high volume of air to be ventilated. However, control technology is readily available and the cost of compliance may not be prohibitive. Lack of maintenance programs, monitoring activities, inadquate employee training, medical examination and surveillance, and poor housekeeping are the common observations found during this survey. We may put emphasis on these areas m our proposed standard on the VCM. `All manufacturers were very cooperative during this survey. They answered all questions we asked and gave us the information we needed. From this survey, we were given the chance to conounicate with the production people to find out which areas present potential exposures to VCM, what the producer has accomplished to control the exposures at each area, and at which areas further control of the problem and what enforcement is required. We sincerely believe that this type survey should be Included in our regular rulemaking procedures so far as health standards development is concerned. -10- & O o BFG26019 LIST OF FIGURES 1. Manufacturing of VCM by Direct Chlorination and Oxychlorination of Ethylana 2. Manufacturing of VCM by Direct Chlorination of Acetylene 3. Manufacturing of FVC by Suapenalan or Bnulalon Polymerisation A. Manufacturing of FVC by Bulk Polymerisation LIST OF TABLES I. Manufacturing Fadlltlee of Vinyl Chloride and Polyvinyl Chloride II. Initial Monitoring Data Froai Plant A III. VCM Monitoring Dote From Plant B IV. Medical Surveillance Prograai at Dow Chant cal U.S.A. 11 BFG26020 23526101 FIGURE 1 .. MANUFACTURING OF VCM BT DIRECT CHLORINATION AND OXICHLORINAHON i cv i CjO Ul cn BFG26021 FIGURE 2 . MANUFACTURING OF VCM BY DIRECT CHLORINATION OF ACETYLENE &\19ZZ 3 ft I <*\ 5 II u 33 + 33 O BFG26022 FIGURE 3. MANUFACTURING OF PVC BY SUSPENSION A D EMULSION POLYMERIZATION BFG26023 wfigure 4. Kmkgmm m vm wxmmnm BFG26024 SGT9ZSSZ 90T92C22 BFG26025 Sampling Periods. TABLE II INITIAL VCM MONITORING DATA FROM' PLANT A November 1973 Job Classification VCM Operator VCM Operator EDC Operator EDC Operator OXY Operator VCM Loader VCM Loader VCM Loader VCM Loader Lab Technician Sampling Time VCM Concentration hr.gm 7.5 1.3 7.5 1.7 7.5 0.8 25 min. 0.6 7.5 0.3 3.0 8.7 25 min. 3.5 16.0 13.4 45 min. 43.0 10 min. 3.2 23526107 - 17 - BFG26026 TABLE III VCM MONITORING DATA FROM PLANT B Sampling period: September 1972, March & April 1973 VCM Concentration: ppm (V/V) Job classification Shift supervisor VCM boardman EDC boardman Sample man VCM loader VCM loader Shift supervisor Junior operator Q.C. specialist Lab technician Lab technician Material controller Instrument technician Pipefitter Millwright Electrlan Laborer Samples range high low 3.7 3.6 5.5 13.0 158.0 13.5 13.0 13.5 32.1 158.1 229.0 0.3 13.0 13.0 13.0 13.0 13.0 0.1 0.03 0.07 0.1 0.05 0.05 0.03 0.03 0.05 0.06 0.1 0.05 0.03 0.03 0.03 0.03 0.03 Number of samples taken 10 18 10 12 30 30 20 32 28 26 30 10 30 10 10 10 12 TWA 0.4 0.6 2.4 0.7 4.2 2.9 0.4 2.3 3.0 10.3 15.0 0.1 1.9 4.5 4.4 3.5 4.5 < IT 92S ?2 - 18 - BFG26027 APPENDIX D DISTRIBUTION LIST FOR DRAFT ENVIRONMENTAL IMPACT STATEMENT BFG26028 6 k> J S Z S Z Governmental Agencies 1. Colonel Herbert E. Bell 9. Sidney R. Galler, Ph.D. Headquarters Deputy Assistant Secretary USAF (Prev) Environmental Affairs Washington, D.C. 20330 Department of Commerce Washington, D.C. 20230 2. T. C. Byerly, Ph.D. Coordinator 10. Dr. Warren Muir Environmental Activities Department of Agriculture Council on Environmental Quality 722 Jackson Place, N.W. Room 312-E Washington, D.C. 20575 Washington, D.C. 20250 11. Mr. David Rosse 3. Colonel John E. Ward Materials Division-Chemicals Occupational Health Consultant Department of Commerce Office of the Surgeon General 14th and E Street, N.W. Department of the Army Washington, D.C. 20230 Forrestal Building, Room B207 Washington, D.C. 20314 12. Mr. George L. Feazell Director of Safety Policy 4. Mrs. Grlffltts Department of Defense Joint Medical Library The Pentagon Office of the Surgeon General Washington, D.C. 20301 Forrestal Building, Room 6E040 Washington, D.C. 20314 13. Sheldon Meyers, M.D. Director of Federal 5. Mr. M. B. Biles Activities D.S. Atomic Energy Comnission Environmental Protection Agency Washington, D.C. 20545 Waterside Mall Building Room 535, 4th & M Street, S.W. 6. Mr. Robert J. Catlin Washington, D.C. 20460 Division of Environmental Affairs U.S. Atomic Energy Commission 14. Mr. Pope Laurence Washington, D.C. 20545 Environmental Protection Agency Waterside Mall Building 7. Mr. W. H. Pennington Room 535, 4th & M Street, S.W. Division of Environmental Affairs Washington, D.C. 20460 U.S. Atomic Energy Commission 15. Mr. Paul Cromwell 8. Mr. Julius Ruben Acting Chief Environmental Assistant General Manager Officer of Environment and Safety Department of Health, U.S. Atomic Energy Commission Education and Welfare Room A303 Room 3718N Washington, D.C. 20545 300 Independence Avenue, S.W. Washington, D.C. 20201 T t9 Z S z z BFG26029 16. Ms. M. Pospur HEW North Building 300 Independence Avenue, S.W. Room 371A Washington, D.C. 20201 17. Marcus M. Key, M.D. Director, National Institute for Occupational Safety and Health Department of Health, Education, and Welfare 12420 Parklawn Drive DANAC Building Rockville, Maryland 20852 23. Mr. Martin Convisser Director Office of Environmental Quality Office of the Secretary Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 24. Deputy Secretary of the Treasury Treasury Department 15th & Pennsylvania Ave., N.W. Washington, D.C. 20220 18. Mr. Vernon Rose Office of Research and Standard Development National Institute for Occupational Safety and Health 12420 Parklawn Drive DANAC Building Rockville, Maryland 20852 19. Mr. Gene Proctor Occupational Medicine and Environmental Health NASA, 600 Maryland Avenue, S.W. Washington, D.C. 20546 20. Mr. William C. Salmon Deputy Director Office of Environmental Affairs State Department Washington, D.C. 20520 25. Mr. Walter J. Barrows Landscape Coordinator Parks Department 501 Poli Street Ventura, California 93001 26. Mr. Barry H. Lockton Director of Public Works 107 North Ventura Street Ojai, California 93023 27. Mr. J. L. Wootan Environmental Program Specialist II Occupational Health Planning Project Oklahoma State Department of Health N.E. Tenth & Stonewall Oklahoma City, Oklahoma 73105 21. Mr. Stanley D. Allen Chief, Management Analysis Division Office of the Secretary Department of Treasury Washington, D.C. 20220 22. Mr. W. J. Burns Director, Office of Hazardous Materials Department of Transportation Washington, D.C. 20590 TTT9ZSZ BFG26030 Department of Labor 1. Daniel P. Boyd, Ph.D. Director Office of Standards Development U.S. Department of Labor, OSHA Room 610, 1726 M Street, N.W. Washington, D.C. 20210 2. Mr. Edward Klein Office of the Solicitor U.S. Department of Labor 14th & Constitution Avenue, N.W. Washington, D.C. 20210 3. Mr. Ray McClure Office of Compliance Programming U.S. Department of Labor, OSHA Room 760, 1726 M Street, N.W. Washington, D.C. 20210 4. Mr. Benjamin L. Mintz Office of the Solicitor U.S. Department of Labor Room 5420, Main Labor 14th & Constitution Avenue, N.W. Washington, D.C. 20210 5. Dr. John P. O'Neill Office of Standards Development U.S. Department of Labor, OSHA Room 660, 1726 M Street, N.W. Washington, D.C. 20210 6. Mr. John E. Plummer Associate Assistant Secretary for Administrative Programs U.S. Department of Labor, OSHA Room 1100, 1726 M Street, N.W. Washington, D.C. 20210 7. Mr. Eugene Regad, Jr. Office of Standards Development U.S. Department of Labor, OSHA Room 660, 1726 M Street, N.W. Washington, D.C. 20210 8. Mr. Howard Schulte Deputy Assistant Secretary U.S. Department of Labor, OSHA Room 2116, Main Labor 14th & Constitution Ave.,N.W. Washington, D.C. 20210 9. Mr. John H. Stender Assistant Secretary for Occupational Safety and Health Administration U.S. Department of Labor Room 3115 14th & Constitution Ave.,N.W. Washington, D.C. 20210 10. Mr. Barry S. White Associate Assistant Secretary for Regional Programs U.S. Department of Labor, OSHA Room 820 1726 M Street, N.W. Washington, D.C. 20210 2352611 BFG26031 Miscellaneous 1. Mr. C. Nelson Codding Cooperate Environmental Control Jim Walter Research Corporation 10301 Ninth Street North St. Petersburg, Florida 33702 2. Mr. Charles E. Kupchella Administrative and Scientific Coordinator University of Louisville Health Sciences Center Louisville, Kentucky 40201 3. Mr. John Messervey Refinlshed Mouldings Manufacturers Association 1201 Waukegan Road Glenview, Illinois 60025 4. Mr. Edwin A. Olsen Secretary and Treasurer Compressed Gas Association, Inc. 500 Fifth Avenue New York, New York 10036 5. Mr. Ulrich H. F. Wollmann Representative of the Huls-Group for the United States of America 750 Third Avenue New York, New York 10017 Private Industry 1. Mr. Etcyl H. Blair Director of Health and Environmental Research U.S. Area Research and Development Dow Chemical U.S.A. 2020 Dow Center Bennett Building Midland, Michigan 48640 8. Mr. Harlan Bentzinger Chemical Products King Philip Road East Providence, Rhode Island 02914 2. Mr. Joseph T. Flanagan Technical Consultant The Hartford Insurance Group Loss Control Department - ESU Hartford Plaza Hartford, Connecticut 06115 3. Mr. W. M. Laughton Standards Section Engineering Assurance Stone and Webster Engineering Corporation Post Office Box 2325 225 Franklin Street Boston, Massachusetts 02107 4. Mr. R. J. O'Leary General Manager Plastic Film Department Allied Chemical Corporation Post Office Box 1057R Morristown, New Jersey 07960 5. Mr. Eugene Ritchie Ray Josephs 230 Park Avenue New York, New York 10017 6. Shell Development Company Library Biological Sciences Research Center Post Office Box 4248 Modesto, California 95352 7. Mr. G. E. Westerlund Facilities Engineering The Okonlte Company Post Office Box 340 Ramsay, New Jersey 07446 BFG26032A