Document pmgd63yJej7Q1Vr8ZGEoOy106

Vinyl Chloride: Questions Almost everything youaNwyswwrtedtoknowabbut OSHA's VftiyTfftti ..... i -Jb*< ;-v./:;* , 4*ns; -**v. JOB SAFETY AND HKALT& iMAGiZIHE^Jj^jy _ -:5.cr/v-^ ' SiSiteK'^'SSKM "In th*,Hz*&5$ HgftNf* Struck 32 0Se*; chloride-related layoff? * Vm. i<?pie4 to .carry a Nt ryi -V> irt&cf-*' asked about.: its ,,vipyi^c^k (vc) standard is as fnvolousas this onefrom anaaonymoe*' user* ofipriyvinytf>cfatorid^rj (pvc) reate;'1' f thstafl-appeak courthah ruled-die standard iadfecdVC April !, 1975,? hundreds legitimate questions--Aeones that get <kwh te'ibe muy^rttyt of hourto-compl^fe .wfcflMbl* --are foiling in. ' replies to somep Tor .TMe;..........' - *--- the vc stark *- further^ ^ ^ ^ t RegionartoffSK,^?^^ vh , tibnal v BA. jfrpgraipmrofc JutaaiJ60, 1726 <KJKV Ar sonally taring ums^. employee*^ respirators sQC ^fipt 1 and ;^must- give a valid determination: of ' employee exposures. You might *dectre: preseatadve employ**** for personal monitoring according 10 these criteria:^ the number- gmj per-shift, ..their areas and*! Each even pxpi mkasa, Cancer 'OctfonteveT'i sets lable. rs. (taring rns.are jfU-one and have dreaT' below if pack- used. rpiorinissi ire re 4i^STn;:e*.S^*s<T^i:`of the concentrations, then,, are below either . permissibie limits or the cdon level, do not Uavc to setupar^dated area Doeseyery employee ihdwrplant who -W Aelwr fo&ie gfviir'trmnhig^ What entpbye^'^ddsed'helow the rfftci?, e#KK*r: .awsr.- i:-..x *439 nociceptions to the g reqtoremepw&4gB*dle^ of low the monitoring results are, lo ve or operations* Hu& 'be given to^y^and' the'^^p^pfecau- forus&g^Yllifl aright jtgtogppce, lab oratory, ana?-supervisory sonnei as null as pro- >7'^TV'' : Q. Occasionally our company uses what congdegtempor- eniptfiyees. These levator fide. VVV 00GQG2772 film, sometimes cutting it with a hot wire. Accord ing to the Osha standard, what should our company be doing to protect me? A. Meat packaging films are considered a "fabri cated product" under the osha standard since mass melting does not occur when they are cut with the hot wire. Consequently, the packaging operation you describe is not covered by the vc standard. niosh has conducted research into the possible release of vc during pvc packaging operations and, using instruments sensitive to approximately one ppm, has not detected any vc. However, niosh has determined that when heated, pvc film decomposes into hydrogen chloride and carbonaceous gases. The hydrogen chloride gas, which becomes hydrochloric acid on contact with the mucous membranes of the eyes, throat, and nasal passages, can be irritating at concentrations above the osha standard of five ppm for hydrogen chloride. So far niosh has found no health hazards from exposure to other pvc decom position products, though the investigation is con tinuing. Q. The standard says that it applies to the trans portation of vc or pvc "except to the extent that the Department of Transportation (dot) may regulate the hazardsAre the placards dot requires for tank trucks carrying vc monomer enough to fufill the labeling requirements of the standard? If not, what is meant by . the requirement that labeling be "legible?" Is a tank truck on the road considered a "regulated area?" If the driver does not help in loading or unloading, is he covered by any of the provisions of the standard? A. There need not be duplication of dot markings that cover such hazards as flammability. However, markings not required by dot, such as "cancersuspect agent," must be part of the container label. In other words, when placarding specified by dot is not sufficient to meet requirements outlined in the osha standard, additional labeling will be required. For working purposes, we define "legible" as the same size lettering as other emergency or warning in structions on the side of the container or vehicle. A tank truck carrying vc would be considered a regulated area only if it were expected (based on measurements or other known facts) that vc con centrations would exceed one ppm as an eight-hour time-weighted average or five ppm as a ceiling. It appears unlikely that a truck on the road would be in this situation. Whether the truck driver is covered depends on the amount of vc he is exposed to. If tbefiXjyiftUfe is below the action level of 0.5 ppm--at --only the training and labeling provt standard would apply. Q. We are expecting shipments of pvc resin standard goes into effect. The resin is shipped in sealed containers 20 and 40 feet long. How will the standard affect our operation? A. The osha standard does not prohibit importing vc or pvc, but each employer is responsible for know ing the working conditions of his employees and con trolling conditions to meet the standard's require ments. Our information on vc exposure levels in handling packaged resins is limited. Concentrations above the exposure limit have been measured in warehouses where pvc resin is stored. Freshly opened containers, particularly air-tight ones, may release significant amounts of vc to the air. For instance, concentra tions in trucks loaded with bagged pvc resin have been measured at 200 to 600 ppm. It appears that, at the very least, you must do initial monitoring of employee exposures. If the eight-hour time-weighted average is below 0.5 ppm and 15-minute exposures below five ppm, then your duties are reduced basically to labeling containers and training employees. Q. The standard says that no employee can be ex posed to vc concentrations above five ppm over a 15-minute period. What about those employees who decide not to wear a respirator for the stan dard's first year? A. Before April 1, 1976, the ceiling exposure limit of five ppm over 15 minutes does not apply to the employees who have elected not to wear respirators. They may be exposed to as much as 25 ppm over any 15-minute period. Q. The emergency provisions of the standard go into effect when you hare a "massive release" of vc. Exactly how much VC does it take to trigger these provisions? A. We define a "massive release" as any operation or place where the vc concentration is greater than 100 ppm. For example, a broken pipe in a pvc plant might cause a massive release. Q. The standard says that no employees may have direct contact with vc. What do you mean by "direct contact?'' -y A. Skin contact with liquid vc. Q. The standard requires us to keep a daily roster of authorized persons who enter a regulated area. What information should we indude an the roster? A. The daily_ rost^r should^consist of . legible sig- Uursarr se- ity spo a9-op 21 VVV 0 0 0 0 0 2 7 7 3