Document pmpe9bbmx4Dz56bqg3xEmjNOd
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. i. du Pont de Nemours & Comfany
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HPCA OCCUPATIONAL HEALTH TASS P0r.CS lei Washington nesting 3/19/?^
1* OSHA Oversight Hearings- (Select Committee on Labor House. Committee on Labor)
"
SPCA has requested permission to participate in the proceed ings and has been told that Hearings may continue over the next 5--3 months. ...Ho date for their appearance has been set. bat Task" For ce- memS'ere" haver been asked to provida,, input.-f or the planned statement. Subject to Legal Department. approval, vie should consider offering input in the following areas of
concern;
a. Section S (a) of the Act provided for the arbitrary adoption, of consensus standards for a period of two pears (period expired April, 1973} with the under standing that such standards' would bs modified promptly to insure consistency and eliminate requirements net directly applicable to worker health and safety. POL has done an exceptitmally poor job in modification (e.g., storage of
- flammable material requireaents that emphasise protection of property rather than workers; unrealistic air contaminan*; restrictions on amorphous silica, etc,}. .Industry has a right to expect that DOL will comply with their
Concessional charge.
b. In the idevelopment of new standards or proposed standards, v?e oercuive a lack of expertise. The technique most often used 6 involves the re - interpretation of well known, infers at ion by newly established "experts *' (e.g., ACG-IB- threshold limit vilues have been halved, by H203H in several recent
proposals.)
c. net? sta.idards should CE-ecify ths pr&fcle&s to da solved and par tit Industry to' search for inrovntivo sol at lens
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EE iTES iHIMGS TOP. SETTER LIVING . . . THROUGH fHEMISTBr
with a minimum of restraint. In those cases where scnpling and. Eiibsequeno analysis are imlvsd, the methods by which performance will re measured, must be clearly defined and publicised, tut allowance must also be mace for equivalent methods,
Yinjl Chloride Monomer
The Painters arid Allied Traces letter to their national Health arid Safety Committee, (copy attached) charged that polyvinyl chloride causes cancer and that painters have been effected, In a related meeting between Task. Force 3embers and Dr. Irving J. Selikoff, it was learned that Mt. Sinai Hospital is undertaking a "vast research program" to define the YCK p rot lea. and that the paint industry will be involved. (Selikcff is reported to have a grant from HIOSH to conduct a seminar on YCM. and FYO in. August.) Selilcoff suggested that the paint industry cooperate in the study "with a sense of urgencyK end supply him with the following Information;
a. History and- current usage of FYC-containing paint formulations by year and quantity plus end use infc relation.
b. The nuriber of employees per year who could have been involved in the production of PVC-containing coatings.
c. Medical examinations of employees to determine if they display symptoms of any of the occupational diseases associated with exposure to YCM.
d. In-plant monitoring to determine likely exposures to production personnel. In addition, exposures should be determined for various application techniques such as Use in an enclosed room, if such usage could reasonably be anticipated.
The Task Force proposed, that members supply preliminary information on items (a) and (b), in confidence, to H. W* Murry. After review of the total.figures, a recommendation will probably bn made to the Community Services Steering Cctcxittve and the Executive Committee, to cooperate in Ssliiioff fs_ stin.y, (We apparently have little choice, ether than in the extent of cooperation. .However, Selikoff is certain to want medical records in a search for "leading indicators of harm" such as non-alcoholic cirrhosis of the liver.)
Murry will also contact the MCA study group for YCM with a request for data on monomer content in commercial resins and information on analytical,techniques, Mote that FP1 stated they have been getting monener convent from, their supplier() on each batch of recin purchased.
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3* DOT Ber.ulatior.s- - BK-102
Though not specifically related to the Task Force assign ment 3 Bruce Bam ill stated that 1IPC.A' K-ill petition DOT for an extension in the enforcement date of HM-10-2* One of the bases for the request -Bill he that -rie requirement to display actual flash points on certain products in transportation5. is new material not mentioned in ths proposed regulations; due process has been denied*
4*. ilOSII Trade Sans Survey
There has b-een no response fro HI OSH to KrC/ns request for a meeting to discuss the paint Indus try*s problems -Kith the survey form * Khen. received* we wiU be asked to participate with. SI# and PPG- representatives-
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FrJirslb Attachment .
B.P.S. to rl. H. Kohl: Is there any indication from Safety & Fire as to Corporate participation in the OSilA oversight hearing??
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