Document pmqgMm2XJwpwODVdmdx7eVE1w

STANDARD GUIDELINES FOR DEVELOPMENT ORJjA^A BY INDIVIDUAL ^2MP*,NTTrF THE pmt'ni|Tn -TuTninm nr* THP OS^S~GENERIC CARCINOGEN PROPOSAL Prepared for: Industry Task Force on OSHA Generic Carcinogen Proposal November 1977 Prepared by: Booz, Allen & Hamilton Inc. Foster D. Snell Division 66 Hanover Road Florham Park, New Jersey 07932 J ALCOAO 00432 2 r 1- TABLE OF CONTENTS SECTION I II III IV TITLE INTRODUCTION GENERAL INSTRUCTIONS KEY PROVISIONS OFTHE PROPOSAL THAT AFFECT DIRECT COSTS SPECIFIC INSTRUCTIONS TO COMPLETE FORMS A. DESCRIPTION OF FORMS TO BE COMPLETED BY YOUR COMPANY B. NONENGINEERING COST CONTROL CALCULATION GUIDELINES C. ENGINEERING COST CONTROL CALCULATION GUIDELINES D. ADDITIONAL ECONOMIC EFFECT GUIDELINES PAGE 2 5 8 11 11 12 14 16 APPENDIX A APPENDIX B APPENDIX C ECONOMICALLY SIGNIFICANT SUSBTANCES LISTED IN NIOSH LIST SUSPECTED CARCINOGENS SUGGESTED OUTLINE FOR INDIVIDUAL COMPANY COMMENTS OR TESTIMONY ON THE OSHA GENERIC CARCINOGEN PROPOSAL FOCUSING PRIMARILY ON ECONOMICS FORMS FOR CALCULATION AND REPORTING A-l B-l C-l ** * * If further information or clarification is desired on any facet of these forms, contact one of the following Booz, Allen people. Contact Business Phone Extension Ronald Kensicki 201/377-6700 260 Ronald Rubin 201/377-6700 283 Philip Gisser 201/377-6700 205 ALCOA0004323 W1 I. introduction Purpose A broad-based- industry committee was formed to address the scientific, legal and economic questions raised by regulations proposed by the Occupational Safety k Health Administration (OSHA) for the identification, classification and regulation of suspect carcinogens (cancer causing substances), hereinafter described as OSHA Generic Carcinogen Proposal. It has re tained Booz, Allen & Hamilton, Foster D. Snell Division, to prepare these Guidelines and the enclosed forms. The principal purpose of these materials is to assist you in analyzing the economic impact of the OSHA proposal on your company or on products you make or use. The attached materials are designed to facilitate your understanding of the OSHA proposal and focus your thinking on economic impact. . You are urged to prepare and file comments with OSHA and/or to participate in the public hearing scheduled for the proposal using the enclosed materials as guides. Experience has shown that sound economic arguments, particularly for smaller businesses, can significantly impact agency decision. The industry committee has also asked Booz Allen to prepare a broader economic impact analysis of the OSHA proposal. If you would like to cooperate in this effort, the enclosed forms should be completed and photocopies sent to Booz, Allen on a confidential basis, by early December. Background On OSHA Proposal In the Federal Register of October 4, 1977 (42 Fed. Reg. 54147), OSHA published its Generic Carcinogen Proposal. Abandoning its previous substance-by-substance approach to regulating chemical substances in the work place, OSHA, through these regulations, proposes to establish a vehicle and framework for future rulemakings which will enable it to move expeditiously. The regulations set forth criteria for'determining whether a substance is a carcinogen, establish a classification scheme for suspect and known carcinogens and require certain regulatory actions to be taken following such classification. There are attached to the proposed regulations model standards to be used by OSHA as essentially fill-in-the-rblank modules for standards on individual substances. Once adopted, the proposed regulations should lead to a flurry of regulatory activity, the focus of which will probably be a List of Suspect Carcinogens published by the National Institute for Occupational Safety and Health (HIOSH), numbering in excess of 2400 substances, and which has been growing at the rate of 100 substances a month. The regulations represent OSHA's proposed resolution of many complex scientific and legal issues. Once resolved in this rulemaking, those issues may not be open to further question in subsequent rulemakings on individual substances. The criteria, classification scheme, and regulatory consequences in this proposal will apply to all subsequent OSHA rulemakings on suspect carcinogens. Indeed, given recent public pronounce ments on the need for cooperation and harmonious policies between federal agencies on toxic substances, the OSHA proposal may well form the basis for a national approach to similar regulations for all federal agencies. The proposed regulations will establish criteria for classifying substances and require regulatory consequences to flow automatically therefrom. The proposal authorizes OSHA to ban substances where there are "suitable" substitutes and to require that exposure be reduced to the "lowest level feasible." These two terms are not defined by OSHA. While the industry committee recognizes its collective and individual responsibility to provide workers with a safe workplace free from recognized hazards, particularly known carcinogens, it believes that the OSHA proposal might result in the improper classification of a substantial number of substances and that the proposal's economic costs might be out of proportion to its possible benefits. Participation In Rulemaking Written comments to OSHA are due January 9, 1978. Persons who intend to appear at the public hearing on the proposal, scheduled to commence on March 14, 1978, are required to file a notice of intent to appear, and, if-they expect to testify for more than 15 minutes, file their full testimony by January 9, 1978. Although you should make every effort to meet these deadlines, we believe, although OSHA has not so stated, that it may decide not to exclude late submissions from its rulemaking record.ID Written comments should be submitted in quadruplicate to: Docket Office Docket No. H-090 Room S-6212 U.S Department of Labor 3rd Street & Constitution Avenue NVJ Washington, D.C. 20210 TD The due date for written comments and notices of intent to appear noted in the Federal Register of October 4 has been extended from December 8, 1977 to January 9, 1978. 2 ALCOA0004 324 Notice of intent to appear at the hearing and testimony should be submitted (in quadruplicate) to: OSHA Office of Consumer Affairs Room N 3633 U.S. Department of Labor 3rd Street t Constitution Ave. NW Washington, D.C. 20210 How To Use This Document For Use By Your Company In Preparing Written Comments and/or Testimony You will save time in this endeavor by following the steps described below. . Make copies of the forms in Appendix C, and keep a clear original. You may need multiple copies of some sections. . Select as many chemicals as you feel you can analyze for internal case study from the ninety-nine chemicals listed with their alternate names in Appendix A. These chemicals, all of which appear on the KIOSK List of Suspect Carcinogens, are ones Booz Allen believes to be economically significant. There may be other chemicals on the NIOSH list which are not listed in Appendix A but which may be significant to your company. You should, therefore, carefully review the NIOSH list. Fill out this set of forms for each substance selected. If two of the substances are encountered in the same plant unit, one set of forms is sufficient. Aggregate the total compliance costs for each case study substance, a: shown on Form VI. The ratio of compliance costs t> current costs, as well as the other ratios indicated, an be presented in your submission. . Submit written conr ients for the record (due January 9, 1978). If you intend to testify at the public hearing, notify OSHA of your intent to testify (due January 9, 1978). . If you intend to testify at the public hearing for more than 15 minutes, file full testimony (due January 9, 1978). . .Testify at public hearing commencing March 14, 1977. . Retain file copies of all information collected and submissions made. If You Elect To Participate In The Broader Impact Study By Booz, Allen If you elect to cooperate with the Booz, Allen study, please follow the procedure outlined below: Select two or three dissimilar case study substances for analysis at your company. . Inform either R. Kensicki or P. Gisser (201-377-6700, extension 260) at Booz, Allen that you are planning to analyze selected case study substances at your company. . Assign one individual responsible for getting the data and returning it. He will probably need the cooperation of plant and engineering people. For chemical producers, marketing people might provide some necessary inputs. U.S. Department of Health Education and Welfare Suspected Carcinogens, A Subfile of the NIOSH Registry Of Toxic Effect s Of Chemical Subs t ances, 2nd Edition" Washington, D.C. U. S. Government Printing Office, December 1976, HEW Publication Number (NIOSH) 77-149. 3 ALCOAO 004 325 Make copies of the forms and keep a clean original. You will probably need extra copies for some sections. Identify the plant units in which you make or use any of your selected case study chemicals. Fill out forms for each plant unit identified. Return these forms by early December 1977, to: - Foster D. Snell, Division Booz, Allen & Hamilton Inc. 66 Hanover Road Florham Park, New Jersey 07932 Attention: Mr. R. Xensicki The information returned will, of course, be analyzed confidentially by Booz,' Allen & Hamilton Inc. Details of the confidentiality procedures follow: . All information will be confidential and access will be limited within Booz, Allen and Hamilton Inc., on a need-to-know basis. . Only one page carries company identification. This page will be separated from the rest and kept in a locked file for use only by authorized personnel if follow-up is needed for clarification. . The other pages will be assigned identification numbers. Personnel involved in data processing and analysis work will have access only to those numbers. . The final report \ ill not attribute information to a specific company or identil * any individual source without the company's authorization. . The original records will be returned to you when the report is completed, and 10 copies will be retained. -A- ALCOA0004 326 r II. GENERAL INSTRUCTIONS The forms in this package refer to the cost of compliance with OSHA's Identification, Classification and Regulation of Toxic Suhstances Posing a Futential Carcinogenic Risk. This form is organized to collect economic data ior each of the products manufactured at your plants that may potentially be affected by the proposed regulation of substances. Substances for case study should be selected by your company from the following: Economically Significant List -- In Appendix A substances are listed that are on the NIOSH Suspected Carcinogens list and judged to be economically significant on the basis of total U.S. production and the number of total employees associated with their manufacture or use or both. Your company may wish to select applicable substances from this list and present one or more case studies. . Other Substances -- In the NIOSH publication Suspected Carcinogens, 1976, over 2400 substances are listed that nay be regulated under the proposed act. There may be other substances not listed in the NIOSH document that your company may want to study. The manufacture and use of these substances may have specific impact on your company. For each of the case studies selected, one set of forms should be completed for each production plant at your company that is associated with the substance under study. The substance may be: . Manufactured at the plant (e.g., as a product, by-product or co-product) . Used at the plant (e.g., as a raw material) . Present as in-process material (e.g., as a solvent, formulation or impurity) . Handled for wholesale or retail distribution. Therefore, your company may complete more than one set of forms depending on the number of plants that are associated with the case study substance. For example: . Only one set of forms may be required for a case study substance if it is used, manufactured, present or handled at only one plant site of your company . More than one set of forms may be required for a case study substance if it is used, manufactured, present or handled at more than one plant site. Cost information will be determined on a plant-by-plant basis for each substance selected for a case study. If more than one substance is present at each plant that may potentially be regulated: . Do not allocate separate compliance costs to each of the various substances present. . Assume that the compliance cost required will be the effect of ' all substances at the plant unit potentially regulated. . Do not complete a separate set of forms for each substance present at a plant unit, since this would result in double counting. OSHA's proposed regulation and these forms cover each of the substances that may be classified by OSHA under Category I or Category II. The four categories established by OSHA are: . Category I - Confirmed Carcinogens . Category II - Suspect Carcinogens Category III - Substance for Which There Is Insufficient Information to Reach a Conclusion on Carcinogenicity . Category IV - Substances of Carcinogenic Potential Not Found in the American Workplace. 5 ALCOA0004327 To avoid prejudging the results of future oncological testing, the cost analysis is evaluated at two assumed levels: j Assumption I - Assume that the case study substances will be classified as a Category I substance | . Assumption II - Assume that the case study substances will be classi fied as a Category II substances. The compliance costs calculations are similar for Category I and Category II substances except for: . Engineering Controls - Category I substances will require employers to provide engineering controls to reduce exposure to the "lowest level feasible" (refer to No. 6, below) - Category II substances are assumed for purposes of this study not to require engineering controls expenditures. j . Segregation of Work Area Category I substances will require employers to segregate work areas of the plant in which Category I substances are present. ' Category II substances will not require segrega tion of the work area. . Lunchroom Facilities Category I substances will require employers to provide lunchroom facilities that have a controlled temperature, positive pressure and filtered air supply when:ver food or beverages are consumed in the workplace. - Category II substances require appropriate facili ties for eating and drinking. Therefore, no capital cost expenditure should have to be' applied. 6. The proposed OSHA regulation requires that engineering controls be provided to reduce exposure to the "lowest level feasible." OSHA does not define the "lowest level feasible." Depending on the definition, the cost of engineering controls may vary dramatically. Therefore, the cost of engineering controls should be calculated at three assumed levels. These assumed levels selected for the case studies were chosen to provide a range of possible standards; they do not directly reflect the level that OSHA may establish for a case study sub stance and they do not imply that these levels are technically feasible. The three assumed permissible exposure levels (PEL) for the case studv substances differ depending on the form of the substance. < --- . For liquid or gaseous substances, the engineering controls should be estimated at the following three PEL levels: - 10 parts per million 1 part per million 10 parts per billion . For solid substances, the engineering controls should be estimated at the following three PEL levels: - 100 micrograms per cubic meter of air (0.1 milligrams) 10 micrograms per cubic meter of air 1 microgram per cubic meter of air l-UThore are certain situations where capital cost expenditures can be called for under the proposed act. For example: If it is currently not feasible to meet an existing permissible exposure level (PEL) and your company uses respirators for compliance, engineering controls will bo reouired to reduce exposure to the lowest level feasible, while still requiring use of respirators. Or, if the substance is not now covered by a PEL, it can be under this regulation. If these situations apply to your company, you may want to address them in your submission. -6 ALCOA0004328 This_-arm--establishes a standardized basis for estimating compliance cost and other economic effects. The cost dataare "differential" costinformation -- the added cost of compliance over ar.dabove the cost ofcompliance withexisting regulations. The cost of compliance should be consistent in terms of 1977 dollars. The compliance costs should assume no change in demand for the primary product. Therefore, compliance costs shall be determined at: . 1976 production output . 1976 employment. The compliance costs should assume normal operations and not take into account other factors, such as changes in prices and availability. 7 ALCOA0004329 HI. KEY PROVISION'S OF THE PROPOSAL THAT AFFECT DIRECT COSTS (Tho provisions presented apply to substances that are classified as Category 1 or II unless specifically noted.) Monitoring . The employer must determine the employee exposure to the toxic substance over an eight-hour period without regard to the use of respirators. . Initial Monitoring shall be performed for each workplace and work operation to accurately determine the airborne concentrations to which employees may be exposed. . If the employee exposure is above the permissible exposure limits (PEL), these monitoring determinations shall be repeated at least monthly Monthly determinations shall continue until at least two consecutive measurements are below the PEL; there after, monitoring shall be performed quarterly. . Monitoring shall be performed at least quarterly in work areas below the PEL. . Additional monitoring shall be performed wherever there has been a production, process, control or personnel change which may result in new or additional exposure, or wherever the employer has reason to suspect a change may result in new or additional exposure. . The opportunity of employee observation of monitoring exposure shall be provided to affected employees or their designated representatives. Medical Surveillance * A medical surveilLance program shall be instituted for each employee who is or will be exposed to the regulated substance. . ' An initial examin ition shall be provided for each employee at the time of initial assignment or upon institution of the program. . Periodic examinations shall be provided for all exposed employees. The frequency and nature of the examination will be specific to the regulated substance. . Additional examinations will be provided if signs or symptoms commonly associated with exposure occur. Sanitation Facilities. Emergency Plans, Posting and Labeling (Requirements for Category I Substances Only) . Regulated areas shall be established where concentrations of Category I substances are in excess of the PEL. - These areas shall be demarcated and segregated from the rest of the workplace. - Area access shall be limited to authorized persons. - Food, beverages or smoking products shall not be present or consumed in the area. . Whenever food or beverages are consumed in the workplace, the employer shall provide lunchroom facilities that have a temperature controlled, positive pressure, Filtered air supply and that are readily accessible to employees. -8- ALCOA0004330 r* (Requirements for Category I and 11 Substances) --Emergency plans shall be developed for each v.'orkplace where the reguiate-d substance is present. They shall include: Provisions for respiratory protection of employees engaged in correcting emergency conditions Means for alerting employees of high concentration levels. . Clean change rooms and showers shall be provided. Exposed employees shall shower at the end of the workshift. . Signs shall be posted to indicate clearly all workplaces where the regulated substances may be present. - Where airborne concentrations are above the PEL, signs shall additionally bear "Respirator Required" legend. . Precautionary labels must be affixed to all containers and products containing the regulated substances. Personal Protective Equipment . Respirators shall be used to reduce employee exposure to within the PEL and during emergencies. . Protective clothing and equipment required by the Act shall be cleaned, laundered, maintained or replaced at no cost to the employee. Employee Training . Training programs shall be provided at the time of the initial assign ment and annually thereafter. Recordkeeping . Exposure monit''ring records shall be kept for a minimum of 40 years. They shall inc ude: - Results a:.d comprehensive description of monitoring per formed to determine representative employee exposure - Description of the sampling and analytical methods used - Description of type of respirator protection worn - Identification of all other employees whose exposure : the measurement is intended to represent. Medical surveillance records shall be kept for a minimum of 40 years, 'they shall include: - Physician's written opinions - Employee complaints relating to exposure - A copy of information that must be provided to the examining physician. This includes: Description of duties of affected employee as they relate to exposure .. The employee's anticipated or expected exposure (preplacement and emergency) .. Description of personal protective equipment to be used .. Employee's work history. 9 ALCOA0004331 ' Engineering Controls Engineering are Work Practice Controls shall be instituted to reduce or maintain employee exposures to or below the PEL, except to the extent the employer establishes that controls are not feasible. In the event the PEL cannot be attained, the employer shall reduce exposures to the lowest level achievable and supplement the controls with use of respiratory protection. A written Compliance Program shall be established and implemented at or below the PEL solely by means of engineering and work practice controls. It shall include: - Process or operation descriptions - Engineering .plans to determine controls - Report of technology considered - Detailed schedule of implementation (to be updated every six months). - 10 - ALCOA0004332 IV A. iv. specific ixsjp'-CTio?:; 70o FORMS Description of rorrr.s To Be Completed By Your omoanv There are eight basic forms enclosed in this package. The completion of these forms will serve as a basis for estimating the economic impact of the proposed OSHA carcinogen standard. Rather than to prejudge future oncological testing or "safe" employee exposure levels, there are four levels for which direct costs will be estimated by these forms for each case study substance. These levels correspond to the following assumptions: 1 . Case study substance is classified as a Category II substance and the PEL established will not require additional engineering controls. I . Case study substance is classified as a Category I substance and the PEL established is 10 ppm for liquids and gases, or 100 micrograms per cubic meter of air for.solids. . Case study substance is classified as a Category I substance and the PEL established is 1 ppm for liquids and gases, or 10 micrograms per cubic meter of air for solids. . Case study substance is classified as a Category I substance and the PEL established is 10 ppb for liquid and gases, or 1 microgram per cubic meter of air for solids. Each of these forms is described below: FORM I- COMPANY IDENTIFICATION Fill out this form once for your company. Its primary purpose is to identify a contact so to provide an opportunity for clarification of data if your company elects to send the completed forms to Booz, Allen. This sheet, the only one that identifies your company, will be assigned a key number, which will also identify the accompanying pages. It will be kept in a locked file with access limited at all times. FORM II- STATISTICAL DATA Fill out this form fcr each plant unit of your company that is associated with the selected case study substance. If you elect to return it to Booz Allen, its primary purpose is to prcvide scale-up data. In the upper right hand side of the form , assign a plant uni : number and identify the case study substance. FORM I'll- NONENGINEERTNG COMPLIANCE COST WORKSHEET .Fill out this page for each plant unit identified by Forn II. This form is used to estimate the nor.engineering compliance cost for that plant unit. When completing this form refer to the Nonengineering Control Cost Calculations Guidelines on page 12 of the instructions. FORM IV- ENGINEERING CONTROL COST WORKSHEET Fill out this form for each plant unit identified by Form II. This form is used to estimate the engineering compliance costs at three assumed PEL levels for that plant unit. When completing this form refer to the Engineering Control Cost Calculation Guidelines on page 14 of the instructions. FORM V- SUMMARY DATA-- DIRECT COSTS AT PLANT UNIT LEVEL Fill out this form for each plant unit identified by Form II. This form summarizes the direct costs for that plant unit for the selected case study substance. FORM VI- SUMMARY DATA-- RELATIVE COST CHANGES Fill out this form once for each case study substance. It should be filled out after the individual case studies by your company have been consolidated. FORM VII- ADDITIONAL ECONOMIC EFFECTS-- PRODUCTS Fill out this form for the plant unit oniy if the case study substance is produced or formulated at the plant unit. This form is used to identify the indirect economic effects of the proposed regulations. When completing this form, refer to the Additional Economic Guidelines on page 16 of the instructions. FORM VIII- ADDITIONAL ECONO?!IC EFFECTS-- RAW HATERIALS Fill out this form for the plant unit only if the case study substance is purchased or used at the plant unit. This form Is used to estimate the indirect economic effects for users. When completing this form, refer to the Additional Economic Guide lines on page 16 of the instructions. 11 ALCOAOO04333 IV. b. J' roi no:iy of the :.-rovisio:is of tr.e prcposec OEIIA rt-qulaticr., a simplified cost calculation method has: oeen developed' to assist your company in completing this questionnaire in a timely aanner. 1 however, some of the provisions of the regulation, such as engineering controls and sanitation facilities,> require a knowledge of current facilities and estimates must be made by your company. 1 Listed below are the simplified cost calculations for noner.cineering control type cost elements. Each of the cost elements correspond to the direct cost calculation questionnaires presented on Form III. The following are symbols denoted in the cost calculations presented below: N= number of exposed employees (as determined in Form II) n= number of employees currently covered by similar programs W = number of work areas at the plant unit 1. Initial Monitoring Cost No capital cost No annual operating cost Differential first-year operating cost = $(10 N + 450) 2. Exposure Monitoring Cost . No capital cost . Annual operating cost = $67 N Differential first-year operating cost = $45 N 3. Medical Surveillance Cost . No capital cost . Annual operating cost = $155 (N - rj) . No differential first-year operating cost 4. Change Rooms and Showers . Capital and annual operating costs to be estimated by your company . No differential first-year operating cost 5. Emergency Alarms . Capital cost to be estimated by your company 1 Annual operating cost to be estimated by your company . No differential first-year operating cost 6. Respirators . No capital cost . Annual operating cost = $25 N less current operating costs . Differential first-year operating cost = (Number of additional respirators purchased) X (cost per respirator) 7. Personal Protection Equipment . No capital cost . Annual operating cost = $343N less current operating cost . Differential first-year operating cost to be estimated by your company includes purchase of uniforms, gloves, aprons, jaceshields and goggles where required. j ) > 1 Although a number of these costs might be treated as capital costs, those cost calculation guidelines treat most of these expenditures'as expense items. 12 ALCOA0004334 l k .* - IV. B. . Jf* C'J 1 3 For it any of the provisions of the rrcr.r-sei OSH.-*, regulation, a simplified cost calculation method has been developed' to ass:st your company in completing this questionnaire in a timely manner. *' .However, some of the provisions of the regulation, such as engineering controls and sanitation facilities, require a knowledge of current facilities and estimates must be made by your company. Listed below are the simplified cost calculations for noner.gineering control type cost elements. Each of the cost elements correspond to the direct cost calculation questionnaires presented ori Form III. The following are symbols denoted in the cost calculations presented below: N= number of exposed employees (as determined in Form II) n= number of employees currently covered by similar programs W = number of work areas at the plant unit 1. Initial Monitoring Cost . Ho capital cost v No annual operating cost . Differential first-year operating cost = ${10 N + 450) 2. Exposure Monitoring Cost . No capital cost Annual operating cost = $67 N . Differential first-year operating cost = $45 N 3. Medical Surveillance Cost . No capital ccst . Annual operating cost = $155 (N - n) . No differential first-year operating cost 4. Change Rooms and Showers . Capital and annual operating costs to be estimated by your company . No differential first-year operating cost 5. Emergency Alarms . Capital cost to be estimated by your company . Annual operating cost to be estimated by your company . No differential first-year operating cost 6. Respirators No capital cost . Annual operating cost = $25 N less current operating costs . Differential first-year operating cost = (Number of additional respirators purchased) X (cost per respirator) 7. Personal Protection Eauinment No capital cost Annual operating cost - S343N less current operating cost Differential first-year operating cost to be estimated by your company includes purchase of uniforms, gloves, aprons, faresftields and goggles wnore required. TT) Although a number of these costs might- be treated as capital costs, these cost calculation guidelines treat most of these expenditures as expense items. ALCOA0004335 wr 1 8. Signs . No capital and annual operation costs . Differential first-year operating cost = $ 80 Vi 9. Emergency Plan . No capital and annual operating costs . Differential first-year operating cost = $ 400 W 10. Recordkeeping Cost No capital cost . Annual operating cost = SI5 N . Differential first-year operating costs = $200 K 11. Training Program Cost . No capital cost . Annual operating cost = $(160 + 15 N) . Differential first-year operating cost = $200 13. Segregation of Work Areas (Category 1 assumption only) . Capital costs must be estimated at the plant level for work areas. . Annual operatingcost to be estimated by your company. . No differential first-year operating cost. 14. Lunchroom Facilities (Category I assumption only) . Capital costs must be estimated at the plant level for work areas. Annual operating tost to be estimated by your company. . No differential first-year operating cost. ALCOA0004336 13 IV.C. E.ngineerinn Cor.trol'Cost Calculation Guidelines (For Esc '.M'.h I'arr. IV) The key provisions of the proposed act call for engineering controls to play the major role in reducing employee substance exposure. For purposes of this study, we have assumed control costs will only be required for areas where the case study substance is evaluated as a Category I substance. Engineering control costs required for Category I will depend on the PEL level that is established for that substance. for purposes of economic analysis, we have designated several assumed levels for which engineering controls should be estimated. These levels were selected arbitrarily to provide several levels at which engineering controls could be evaluated. - For substances that are in liquid or vapor form, engineering controls will be evaluated at the following three assumed PEL levels: .. 10 parts per million .. 1 part per million .. 10 parts per billion For solid substances, engineering controls will be estimated at the following three assumed PEL levels: .. 100 micrograms per cubic meter of air .. 10 micrograms per cubic meter of air .. 1 microgram per cubic meter of air The capital cost calculations for each of the types of control should reflect a total project cost in 1977 dollars. Elements usually included are: Engineering - Design Materials Equipment - Construction - Contingency (to be . pplied as 10 percent of all costs above). The costs for typical in- estment items as presented on the next page reflect total project cost and if appl ed should not be altered to include additional project cost factors. If it is determined that in order to achieve one of the designated PEL levels, a new facility would be needed for economic or technological reasons, then the engineering control capital cost should be estimated as the cost of an equivalent new facility (same production capacity): - The capital cost should be the cost of a new facility less the salvage value (or plus the demolition cost). The annual operating cost should be the differential cost of the new facility operating cost minus the existing facility operat ing cost (do not include depreciation). The differential first year costs should include start-up costs. Total engineering costs to meet the assumed PEL level must be estimated by your company. However, to assist your analysis, the following is a list of control techniques that are typically used to control exposure levels. Vapor Particulates Process change Ventilation Storage tank vapor control Mechanical seals for pumping equipment Liquid level alarms Rupture discs for relief valves Closed loop sampling systems Process change Ventilation Enclosures of equipment or process Washing or decontamination systems Conveying systems Leak proofing Clean up equipment The remainder of this section briefly describes the control techniques above and provides some typical costs winch you may use as guides, exclusive of factors for piping, instrur.icntut ion, excavation, grading, utilities, etc. ALCOA0004337 14 1 9* 1 P,L222IL1 Change If process change is selected as the method of reducing substance exposure, the capital cost requirement must oe determined solely for the individual process or operation. 2. Ventilation Ventilation systems can be designed to control either the local area or a general area. The cost is also dependent on the specified air flow rate. 3. Storage Tank Vapor Control Floating roof tanks, indirect combustion, activated carbon adsorption and vapor containment systems are commonly applied to control storage tank vapors. Floating roof tanks are usually more cost effective than other control tech nologies to control storage tank vapors. 4. Mechanical Seals For Pumping Equipment Pumps that currently have packed seals can be changed to mechanical seals. The control cost per pump is normally $5,000 to $10,000. 5. Closed Loop Sampling System The installation of closed loop sampling systems will reduce employee exposure to liquid vapors during process sampling. The estimated cost for fabrication of such a system is estimated to be $500 per sampling location. 6. Liquid Level Alarms Storage and process vessels should be equipped with high liquid level alarms to reduce the potential of overflow. The estimated cost to equip existing tanks with liquid level alarms is $3,000 per tank. 7. Rupture Disks Rupture disks are us ad to reduce leakage associated w:th poor sealing of relief valves. The estimated cos-, is $1,000 per relief valve. 8. Enclosures of Equipment o Processes These systems consist of complete enclosure of equipment and processes using impermeable barriers. They' are usually accompanied by exhaust ventilation and material collection systems. 9. Washing or Decontamination Systems These systems are used in handling and storage areas to reduce exposure to particulate substances that adhere to exteriors of storage containers. Contami nated washings handling equipment costs should be included in these systems. 10. Clean-Up Equipment Generally consists of vacuum equipment to prevent particulate accumulation. 11. Conveying Systems These systems are required to transport particulate substances instead of manual handling. They are generally enclosed. 12. Leak Proofing This is done in existing doors, enclosures and ventilation systems whenever necessary. Cost to be estimated by your company. A -> ALCOA0004338 IV D. Additional Economic Effect huidelir':es (For Use With Form VII 6 Form VIII; The requirements of the CSHA Carcinogen Standard may result in effects on your business in addition to direct quantifiable costs. Some of these are: i . Regulated substitution of raw materials. The proposal authorized 0S1!A to require for Category I substances "no occupational exposure," if it determines that there is I a less hazardous suitable substitute. This may, in effect, , amount to a ban on a substance for some or all applications. . Voluntary substitution of raw materials for a variety of reasons: To avoid complexity of handling regulated materials. - To avoid potential liability effects. To avoid higher-cost regulated materials. . Changes in sales levels for a variety of reasons: Substitution to avoid handling of products labeled "carcinogens.: Reduction in purchase because of higher price. - Effect of a potential ban on the substance in the workplace. Loss of sales to nonregulated foreign producers. . Loss of jobs because of sales reduction or plant closings. . Changes in productivity because of manpower requirement shifts, change in production capacity or cnange in demand. . Business closings because of higher operating cost, higher raw material prices or product bans, especially as they might effect small businesses. . Changes in price because of changes in cost or demand. These issues are addressed on Forms VII and VIII. They may not all be significant for a single company but those that do apply should be addressed. They may well be significant from an overall industry point of view. Many of these areas call for subjective judgment and projections of what is likely to happen. It is important to be realistic in those assessments. Any exaggerations in this area wocld throw doubt on the credibility of the entire effort. Questions in this area are divided into two pages: . Form VII is to be filled out if the plant-unit produces the particular case-study substance. Much of the material can be better provided if marketing people are involved in filling out this page. . Form VIII is to be filled out if the plant purchases, uses, or in another way encounters the case-study substance in the plant unit. Either one or the other, in general, should be filled out for each case-study sub stance encountered in the plant unit. Formulators should fill out both. For the survey, any areas that are not applicable should be marked, "not applicable." 16 ALCOAO004339 APPENDIX A ECONOMICALLY SIGNIFICANT SUBSTANCES!LISTED IN NIOSH SUSPECTED CARCINOGENS, SECOND EDITION APPENDIX B SUGGESTED OUTLINE FOR INDIVIDUAL COMPANY COMMENTS OR TESTIMONY ON THE OSHA GENERIC CARCINOGEN PROPOSAL FOCUSING PRIMARILY ON ECONOMICS ALCOA0004340 ECOt-iot-ucALLY sisnricw suBSTArcts U3n.i- r: ''Z1SY. -'J!':rTE'7TrlJ r- (C; NIOSH NL'BEH*3) NAME(b) NIOSH humphe^ NAMC WG21000 AF857S0 AH52500 AI52500 AL3X500 EL64750 AS10500 AT52500 XW52500 AS10500 DG19250 HW66500 DG19230. KJ57V50 EN47I 50 BW66500 XS96250 BK6G500 SE73500 XY56000 XY56000 CF98000 KV03500 OF98000 CY14000 BW66500 C210500 TI31500 CZ45000 CZ45500 DA07000 XS52500 DA64750 WL36750 ACETIC ACID, (Z-BUTENYLIDENE) ACETIC ACID, CHLOROACETIC ACID, ETHYIINEI)INTTRIIJTLTRA-, TRISODIUM SALT ACETIC ACID, LEAD (2+) SALT ACETCra ACETONE, .'-ETHYLACROLEIN ACRYLCU1TRIIE ALLTOX ALLYL ALDEHYDE AMIBEN AKINOBENZENE 3-AMB.>>2,5-DICHLOncaENZOIC ACID 2-A'-LI'XXTHANOL A'nNOFORM AMINOPHEN 3-A' CNO-p-TOLUTDINE ANILINE ASPHALT (STEAM REFINED) ATRA'CX ATRAZINE AUSTRIAN CINNABAR BAKELITE BASIC LEAD CHRCMATE BINZENE BENZENE, AMINOBENZINE, 1-CHLORO-4-NITRO 1,2-DFNZENEDICARBOXYLIC ACID ANHYDRIDE BENZINE, O-DICHLQRObinz-nx, p-dichioroBENZENE, ETHYLBENZINE, METHYLBTNZINE, N1T,lNRINZINE, VTNY1.- DG19250 BENZOIC ACID, 3-AMINO-2,5-DICHLORO- XS89250 BENZYL CHLORIDE DS14000 BERYL DS17500 BERYLLIUM DS23000 BERYLLIUM FLUOFIDE DS40250 BERYLLIUM OXIDE LP89250 BFV 0078750 BUT DU80500 BIBENZENE DU80500 BIPHENYL VM84000 S-l, 2-BIS (EJTHOXYCAR3CXTYL) ETHYL-0,0DIMETHYL THIGPHCSPHATE ED45500 BOPJC ACID PA49300 BROMDMEniANE KJ85750 BUCS EL64750 2-BUTANCN1 KJ85750 2-SOT0XYEE IA.NOL GO78750 BUTYLATED HYDRQXYTOLUENE KJ85750 BUTYL CELLOSOLVE XJ8575P O-BUTYL ETHYLENE GLYCOL KJS5750 BUTYL GLYCOL EU98000 CADMIUM EV01750 CADMIUM CHLORIDE EV19250 CADMIUM OXIDE EV27000 CAD'-UUM SULFATE (1:1) EV31500 CADMIUM SULFIDE XR22750 CALCOTCNE WHITE T XW52500 CAMPHECHIOR EY2C250 epsiIon-CAPROLACTAM POLYMER FC59500 CAPROLIN AT52500 CAKJIACRYL orenooo GARHAMIC ACTD, ClHYLINEPrS(DIimO)-, MANGANESE SALT ZH 3 3250 CARRAMIC ACID, UiHYUNnBIS (DITHIO) - , ZINC SALT P'595on CARRWC ACID, kT7D!YL-, HAPHTHYL ESTER A1 ALCOAO 004 341 A o.'ori'or-ao'-u.v sis=T;.*;crr ::~r in "TO"'; S':Z~l^77ETi c-:c::rDzc:.3, snccml edition.(c' NIOSr! KUMT-'R*2* NICER YR62500 FC59500 WM84G30 VJ184000 SJ33250 FF66500 KX38500 FF66500 FF66500 FG49000 YR62SOO QR59500 KM84090 FJ59500 TQ35C 00 FC59:00 FJ59? 30 WT'SS4C DO DG19250 >5452500 AF85750 CZ45000 AF85750 XY56000 KU96250 KV03500 FS91000 KJ29750 PA63000 CZ10500 SM63000 XS89250 GB29350 OF9HOOO (3327500 Q328500 CARBAMIDE CAPBAFYL ' CAKBLTHOXY MALAIHICN CAJSEPOX CARBOLIC ACID CAHBCN BISULFIDE CAP3CN DICHLORIDE cap3Ck disulfide CAR3CN SUIFIDE CARBON TETRACHLOP.IDE CARBa.TLDLA'-IINE CARBONYL NICKEL POLDER CAPBOrriOS CAPEOXYNETirYUTLLULCSE, SCDIUM SALT CAPB3SVX cabpole: CELLULOSE, CAR30XYM7IHYL ETHER, SODIUM SALT am-MTHION CHL0RAM3EN CHLORINATED CAMPHENE CHDOBQACETIC ACID CHLORC3EN ' CHLDSDEEHANOIC ACID 2-CHIORC>~4~ET!rYLAMINOISQPROPYZAMINE~S"TRIAZINE CHLOHDEIHYIiUE CJflOnOETHYIEIE POLYMER CHLOROFORM CHLOROFORM, MF7IHYLanonot-EniANE 1-CHLORD- 4-NITRODENZENE aruDRipi'EN alpiia-aCO.EOTOULTJE chromate of soda aum: orange CHROMIC ACID, CALCIUM SALT CHROMIC ACID, aiPOflHM (30 SALT G329550 GB42000 QR59500 BW66500 KL36750 WL36750 KL36750 BW56500 XS95250 OF9SOOO XR22750 DA64750 XW52500 CZ45000 CY'14000 VZ47250 XK52500 WMS4000 FC59500 GO78750 AT52500 CY14000 WM84000 1079000 TX87500 CZ45000 XS96250 XS96250 TX87500 KH92750 Q078750 DG19250 CZ45000 CZ45500 PA82000 KI05250 chfemic acid, DisocrjM salt chrcmiim C.I. 7775 C.I. 76000 arcw-E CINNAMCNOL CINNAMX C.I. OXIDATION BASE 1 C.I. OXIDATION BASE 200 C.I. PIGMENT RED C.I. PIC24ENT WHITE 6 C.I. SOLVENT BIACK 5 CDDR CKEM T-590 CLOPODEI COAL NAPHTHA CCfPEN SAI T COMPOUND 3956 COMPOUND (049 CRAG SEYTN p-CRESOL, 2-6-DI-tert-BUTYLCYANOETHYLENE Cl'CLOHEXATRUNE CYTHICN D3CHCN EBCP . DCS 1,3-DIAMTNO-4-; IETHYLBENZQIE 2,4-DIAMINOTOLUENE 1,2-DTBRQMO-.3-QLLOROPIOPANE 1,2-DIBRCMOLTHANE 2,G-DJ-tort-BUlAX-p-CRESOL 2,5-DICHL0n0-3-,VirNCBEr,'7.0IC ACID O-DlCHLOPOnrNZlDE p-Did EOlODrNZlNE di a nodddi fijjorometi lane l, 2-m a norain lane A2 ALCOA0004342 } 'T.y::* NUTIHK'*' k.u comically s-tytyizz..- listed 9 APPENDIX A j-r- r-cr.irr"^1ttj c-arrxjczzx, strc*." i_nrrra;.`c) SIOSH NIZ-3EP !a) (b) K105250 PA80500 WM84000 KX24500 AL31500 TG01750 TG01750 TG01750 WZ12250 WZ12250 XT15750 XT19250 DO3950Q OP07000 FF66500 WZ12250 XT15750 KJ35750 KH92750 PA49000 PA49000 SN15750 346 3000 CZ45000 KX45500 TG01750 DA07000 KH92750 KI05250 FJ59500 AH92500 KI05250 KX38500 EVMOOOU XK52500 DianxiroE^r/UNE KH92750 DiaaDFaErniANE KM84000 DIETHYL .MEIXAPTOSyCCBCATH, 0,0-DIMETHYL PHO6F1 lORGDITHIOATE DLMETHYIZNE OXIDE DIMETHYL KETONE DBCTHYL J^.LTROPIIENYL MOEMraiOHiOSPnAIE 0,0-DL'rTiIYL 0-(p-NITBOPHEMYL) PI10SPHDROT-1IOATE DIMETHYL PAPATHION DBETHYL p-PHTHALATE DIMETHYL TEREPHTHAIAIE 2,4-DIXTTRCTIOLL'ENE 2,6-DINITSOTOLUENE DIPHENYL DITHANE Ji22 DI7KI0CAR30NIC ANHYDRIDE DW 2,4-ENT DCNANOL EB DOWFir-E 40 D0NFUT-E MC-2 DOWFIJC M2-3 3 . DOWICIDE 2S DOWICIDE G DOWTHERM E DOW-TRI E 601 EB EDB EDC EDIFAS B TG01750 P259500 TX49000 TX49000 KX24500 3729750 TI31500 XN52S00 KH92750 KI05250 KI05250 KJ29750 KQ63000 KJ57750 KJ57750 J4J85750 KX45500 KQ63000 DA07000 UH82250 AS10500 OP07000 ZH33250 KH92750 KI05250 KU96250 KV03500 AH52500 EDTA TRISODIUM SALT K3192750 FOT 1,656 XI05250 BCT 1,860 KJ85750 ENT 4,705 KU96250 mr-9,735 KX24500 ENT 15,349 ENT 17,034 BTT 17,292 BTT 23,969 EPICHLORHYDRIN EPICHLDR2HYDRIN 1,2-EPQXYETHANE 1,2-EPQXYPRQPANE ESEN ESTONOX ETHANE, 1,2-DIBHOMOETHANE DIQILORIEE ETHANE, l,2-DICHLOH> ETHANE, 1,1,1-TRICHLOROETHANOL ITRANOIAEZ NE ETHANOL, 2 -A'-HNOETHANOL, ' -BLTOXYETHINYL TIICHIORIEE ETHYL ALOOHOL ETHYL BENZENE ETHYL CARBINOL ETHYLENE ALDEHYDE E7HYLENE3IS (DITHIOCAPHA'-IATE) MANGANESE ETHYLBJEBIS(DITHIOCARRA"ATE) ZINC ETHYLENE BROMIDE ETHYLENE CHLORIDE ETHYLENE, aiLOROETHYLENE, CHIORD-, POLYMER ETIlYLBIEDLAMBaJlTTRAVCETIC ACID, trisodium salt ETHYLENE DIBRCMIDE ETHYLENE DICHU1RIDE EIHYUNE GLYCOL, EPNOBITYL CHER EHIYUNE MONtXltDOMDE EIHYUNE OXIDE A3 ALCOA0004343 V.'/t;':' in) 1Y29750 KL36750 KX335C0 KX33500 KX45000 KX45500 ELC4750 ZH32250 NO-35000 KOo^OCO PAS2000 KMS4000 LPS9250 LFS925C MN4725G LPS9250 LPS9250 P.A82GC0 PA82C00 TX87500 CK36750 XYS6000 PA82000 KJ85750 KH92750 KI05250 KJ85730 KQG300C N035000 FAH2000 r.7-19000 PA49000 pAy-VvOO W VI003 1N47200 .'N472O0 ETHYLENE OXIDE, MHIHVLeihyute, phetiyletoyltl'e tetrachi/iptds etuylmie, tetsachlokjeut/lene triqiioride ERJYLENE, TP.iaiLO.HOETHYL METHYL KETOi.X ranx zr-srs FBOSOL FERROUS SULFATE FLUOSOCAR2CK-12 FOFT1AL FOPHALDEHYT': FORT-ALUv FOFMV-UJiE formic acid FOR-BL FKECH-12 ran-; f-12 FUMAZOtlB 2,4-FTRANDICNE GEIGY 30,027 GE24ETF0N 12 GLYOOL BITYL ETCER GI.YCOL DIBFOM1DG GLYOOL DICIPOPIDE GLYOOL ' tFTDBLGYL ETHER GRAIN' ALCOHOL GREEN VITRIOL IIALON lLAICN 104 IIALON 1001 IIALON 1000] 2,-i-nr:v pJHNnTe ,vi:i IDJaAKW! i u rv a: n iyli-neami n i: ViZCG'.i , . ' *t^pr, (3^ W47250 M4472S0 I-K70500 SJ33250 KJ57750 NP96250 PA94500 NC35000 NPDG250 NPS6250 NP962S0 AL31500 EL64750 .M52500 orosnoo OF98000 OF98000 TP45500 K484000 1-2184000 K484000 ON36750 ON36750 OPOTOOO OP07000 OP07000 AF85750 KJ57750 PA49000 ELG47S0 10134000 TGG1750 TG0]750 XSVjOO 0030780 ipporoo hex?: 'tthylt:jett;ravine KDMRCNE HADRCCYANIC ACID, S-LTS HYDRDXVEEN2EE 2-hydroxythiyia' te l-HYDIBllYl-TTHYLPROFAME IG30MLTI !ANE IEOH (II) SULFATE (1:1) ISOBUTAVOL ISOB7TYL ALCOHOL ISOPPOFYICAP3INOL KETCND, DD-nUYL kuraE, ethyl :-L,*;rr.rL T rj.n AC3TTf\TE LEAD CHTYII.TE, EASIC LEAD CHPa 7.TE (VI) OXIDE LEAD CHPO.' ' TE, REO LEAD, TETIAETOYL MALACIDE MAIATHION JRLATOa MALEIC ACID ANHYDRIDE MALEIC ANHYDRIDE MANED MANGANESE, (EIHYLINE3IS (DITHIOCARCAMATO)) MANDATE MCA MEA ME3R MEK .'ERDAintmilON MTTACIDE .^TTAT'i !Of< :?:n \ o MRHAC'HYLIC ACjn, METHYL ESTER Mi'HUNAL ALCOA0004344 f/ elxnujcally nyj;ir:a:ri susnx-zs i.;~.nv jr: v 'IPnCTKI1 ca-cth'.gex, leodo ftiiticx;. ic> kicci; N wirr.H :D.-x;b) PA49000 METHANE, BSCrt> PA63000 METHANE, CHLOHO- PA30500 methane dichioride PA305D0 1 METHANE, DiatLORD- PAS2000 ME1HANE, DICHLOPODIFLOOFSD- PA94oOO ' .methaix, IODO- XS52500 ME7HIANL, P;-EICYL FG4900C methaie tetrachloride FG49000 McTItlAI'C, 1 ILOrO- FS9J000 METV-YX TRICHLORIDE FS91000 METHA1X, TRICHLGRO M447250 METtllXAMINE PA49000 ME1H0GAS ELC4750 .MEETYL ACETOtX IP8: 250 METHYL ALDEHYDE XS52300 MEIirYLSENZEX FA45000 METHYL BROMIDE GO78750 4-METKlXr 2,6-tert-BUIYLTHEi40L KQ63000 PETHYLCARBIIOL PA63000 METHYL CHLORIDE KJ29750 MEIHYLCHIORQrTORM XT15750 l-METHYL-2 ^-DINITROBENZEE PA80500 METHYXENE BICHLORIDE PA80500 MEIHYLENE CHLORIDE PA80500 METHYLENE DICHIORIDE LPB9250 METHYLEXX OXIDE - EL64750 METHYL ETHYL KETONE PA94500 METHYL IODIDE AL31500 MEIHYL KETOTX 0250750 MEllfYL METHACRYLATE 1X59500 N-MLT1 IYL-1-NAP! rn TYL G\1 V iAHYTE PC59500 N-r-EnATj-aip)m-NAj';r;irYU.Ta:nLV4 T229750 METHYL OXIRYX TCOI750 MLTHYX PARATHION XS96250 4-^VttL-m-Pi D NYLTT^K;^ TAT-ITMT NP%250 2-MI :niYI/-1-PHOPAJOL NP96250 2-meihylpropyl alcohol FS91000 METHYL TRICHLORIDE CY14000 MINERAL NAPHTHA K484000 MLT 0250750 K4E KJ35750 M3TOSCTYL GLYOOL ETHER AT85750 inOCHLOnOACETIC ACID 1X195250 M3,'OrrXDfOnirYLEX PA63000 JOJCCHLORO'ETHANE OZ50750 M3 K301TX METHACRYLATE MONOMER KJ57750 ' MOvOEIHANOLAlDX QJ05250 M3IH BALLS XW52500 M7TOX TG01750 M-FARATHICN 11279030 MYLf-R QJ05250 NAPHTRALEX QK92750 KAFHTHHSIt ACID, ZINC BALT FC59500 1-NAPHTHiT N-METHYLCAKBA'iATE KX38500 KHTirt TX87500 NEMAGON QR59500 NICKEL DA64750 NITROBENZENE CZ10500 p-NITRQCHLOROBENZENE TC017S0 p-NITOOPHENYLOIMETHYLTHIONOPHOSPHATE TG01750 NITFQX 80 KV03500 NORVINYL XW52500 CCTACHIOKXAMPHENE CZ45000 CZ45000 OCB oncn KV03500 OP.ALON ED45500 OETHCTORIC ACID CZ45000 OKIHODiau OROBHNZENE KX24500 OXTDOETHANE KX24500 OX1 RANK CZ45500 paracide CZ45500 PARAnra 1LO1TO0LNZENE AS ALCOA0004345 JTTOVTI W'SCPto) lb) C7,45500 CZ45500 TC01750 ZH33250 SM63000 CZ455C0 CZ45500 TO35000 XS96250 S163000 WG21000 KX38500 FG49000 KX45500 AH52500 Si;? 3500 s;;l5750 SJ33250 SM63000 SN15750 BW66500 DU80500 DA07000 WL36750 SJ33250 SX52500 TG01750 WM84000 DU80500 TI31300 TX31500 TX31500 TP45500 CZ10500 XW5250O PARADOK PARAMOT! PARAIHICN METHYL PARZATE ZINEB PCP PCB PDCB P.E.G. 400 PELAGOL GREY J PENTADILDROPHENOL 1,3-PHNTADIINE-l-CARBOXYLIC ACID PERCHIOFOETifi'XZM; PERCHlJC'ri2-i:JHA;XE PEK4-A-CLOR FERMA KLEER 50, TRISODIUM SALT PETRDLE!!-! ASPHALT (STEAK REPINED ASPHALT) PI 3Z PHENOL PHXXCL, PCTTAOiLORDPHENOL, 2,4,6-TRiaJIDPDPHEXYIA-XME PHENYLBENZENE PHENTLCTHANE PHENYUEHYLENE PHENYL HYDROXIDE PHENAXi-ETOANE PllOSP'HOROTHIOC ACID 0,0-nLMETHYL 0(p-NITKOPHENYL) ESTER PHOSPHOmiCN PHP!I 1,3-FirrrIAlANDIONE PimiALic acid ,\\'iy;:rt;t. phtilajic anhydride PU.MBANE, TETRAFTHYLPNO? POLYO a DROCAMP! ENE , NIOSHi , NV Dipl' "' lb) TQ35000 1079C00 KIA4750 KL64750 TR81000 i;V33500 TO490,00 11 TX87500 TZ297i50 UH82250 AL31500 TZ29750 WG21000 UK82250 TZ27950 TR81000 W7|300 QR59500 PA82000 TI31500 PA49000 VZ47250 W73300 AH52500 FC59500 W73300 W73300 W73300 YV73300 KE19000 FJ595JO VZ47250 GD29550 WE19000 KEl'lOOO WE1900O POLYETHYLENE GLYCOL POLYETHYLENE TEREPiriKALATE POLYSTYKTNE POLYSTYFQL POLYVINYL AimiQL POLYVINYL CHLORIDE PROPANE, l-aXLORO-2,3-riOXYPROPANE, 1,2-DIEROMO-3-a!LOrr> PROPANE, 1,2-EPOXYn-PRQPANOL 2-PRDPAN0CIE PROPELS OXIDE 2-PR0PEAXACRYL1C ACID FROFYL ALCOHOL 1,2-PRCPYLENE OXIDE FVA QGAKfZ RANEY NICKEL REFRIGERANT 12 RETARDER ESIN ROIOX SALT SAND SEQUESTRC1E TRISODIUM SALT SEVIN SILICA, CRYSTALLINE - QUARTZ SILICA FLOUR (POWDERED CRYSTALLITE SHICIC ANirYDRIDD SILICON DTOXIDE ( SAND) SODILfM DISULFIDE SODIIN GAR30XYN171HYL nu. !*A sodium aaoiunr SODIUM CHROMATE sooium iiramsi'ii iL'!SODIin MUAIM'IA') sonnr-i siTunmv.-vri-; i | ) .. > h Ao ALCOA0004346 0 1 1' / 'v ` ': ;*' ' y " f*. ' ' ; ... [.'} :r.* V.V.1S0C0 WG21 000 W-32I009 v.7.7670c i;LS 4 750 -.0,35750 (C434 300 HD35099 Z1152C00 SODIUM SULFIDE SOPHi'C ACID SOPEISTAT STYFLNH STY/ITH POLYMER Sri'P.3-i succinic acid, mucapto, DirrirTL. ester, s-cstsr KITH 0,0-2,;:-37HYL rKUSP-iOECOITHICATE SULFURIC ACID, IIB!7(2+i SALT (1:1) SULFURIC ACID, 71NC SA.LT (1:1) XY36000 KX45500 KJ23750 rOi4 SS1`0 FS31GC0 rsoiooo SM15750 KX4 odOQ ,>H52500 S-7 PXVZr ", 2-0 XORO-4-Enr./lA'-3NO- 6ISOPIOFTiA/ C NOTRiaiOVA'J i, i, 1-tria iraoniuE CFiaiLO?CTHYLE:X ThiaxonaimM TRiaaoEat-ErmwE 2,4,6-TRIGIDORCPHa 1QL TPI-CUIX TRISODIUN EIETATE KW55330 TAITTALUM AH52500 TPISODIUM VERSH1ATE 0703250 TAS CAMPHOR YR62500 CTEA KZ12250 K212250 TfPKP.1"LAL1C ACID, DIM37HYL ES;:_P TE.ATTHXiALIC ACID, .THIIYL ESTEP CP07000 17790253 VANCIDE . VC KX322a,J. FG 70300 TP45305 XR22750 XR22V50 XP.22750 ITTPAC; r.OP?mr.'I^T tla a ,a xo.-a lte x TFDvrrrn, lead TITANIUM DIOXIDE TITANIUM OXIDE TITANOX >7.36250 AH32500 KV03500 WL36750 KU96250 KU96250 vc-: \XPSE>X 9 vFxmix /T/.XLPXXi: E VHWL CHICO IDE \1NYL OEiOPIDE MOXOXR XS52500 XSS9250 XS9R250 XT15750 XT19250 XS52500 >7732550 >7.752500 0735750 KX43500 KX455CIO r.viGSC-u 7DUDI TOLUENE, alpha-OILOPOTOLUENE- 2,4-DLVn:,X TOLUENE, 2,4-0DiIT3OTOLUE2X, 2,0-DINITFDTOLUOL TOLL JUST' TCMAFISIX TOXILIC ANHYDRIDE TRI TRIAD K\'03500 AT52500 17/03500 CC05250 ZH52600 ZH33250 CN92730 ZH52600 ZH52600 ZH33250 PA49000 VINYL OiLOFJDE PCLYl-ER VINYL CTAXIDE VINYLITE WHITE TAP. WHITE \TTPJOL ZINC, (ETirilXNEBISfDimiOCAlClW.TO))ZINC.' N/l'imffHATE ZINC SULFATE ZINC \1TRIOL ZINEB . ZYTOX Ti>*. KiOfti :<IV)}*7 is an alnhc/r.ijrcric Jcsi<jim ion which is o;ii*r^ to the substance. Each synonym is keved to hiv ^ -.-t ! j": i r/itymic.tl , .:nd c.xm'-' rutws. 'cJ I vc.-.'8-u*.:-i 1 Lv si<p :M. in! *.* jc.v.c si .uc vWiiV'i is th .;v with product ion of million pounds \>ir year and/or ; ! vi. c.'ij i *-;ui\\. Yne:v jie \`'i iiraewc suburaujos m Lais list. font iv: HuoivAXlen \ ii.uiiiiton Inc. AV ALCOA0004347 i/ cow- i> c "t ri::o"E:: r. Chapter I - Company Background Description of the company, including: . Size . Products made . Number of employees . Export-import balance Activities in protecting worker health. Chapter II - Methodology For Estimating Economic Impact The guideline is the recommended methodology that should be referenced here. Chapter III - Direct Cost* 1 Impacts of the regulation, under two scenarios: . Scenario A - Assume all your products which are on the NIOSH List of Suspected Carcinogens are in Category I. . Scenario B - Assume all ycur products t.'hich are on the MICS-H List cf Suspected Carcinogens are in Category II. Scenario A direct costs should be estimated at three potential control levels: a PEL level of lit- run. for liquids and gases or 100 nicrocrams fur solids . a PEL level of 1 ppm for liquids and gases or 10 microgram.s for solids a PEL level of 10 ppb for liquids and gases or 1 microgram for solids. Chapter IV - Indirect Implications To The Company This section should cover those significant elements of economic impact or. your company that are not direct compliance-cost items. Possibilities include effects on: . Use of substitute materials and processes . Price . Productivity . Competitive position regarding foreign producers . Possible plant closing . Employment . Small versus large companies. Chapter V - Indirect Cost Implications To Customer Industries Using examples where possible, this section should cover effects on user industry. . Use of substitute materials and processes . Costs and prices . Productivity . Competitive position regarding foreign producers Plant and business closings . Employr-ci.t . Small- versus larce-volumo users. ** * You, may also want to cover non-oconomtc issues problems, questions of tex i eol o.i i ca 1 definition, and the rule as proposed. * m your submission such as technical re.eontrenda.tions for changes to - !U - ALCOA0004348 APPENDIX C 0RI-1S FOR CALCULATION AND REPORTING ALCOA0004349 C'.' i;,r, Piant Unit (Assign Number) Case Study Substance FOP.M II STATISTICAL DATA --Each Plant Unit -- For each plant associated with the selected case study substance, complete this sheet. Case study substance: __________________________________________________________ Major products manufactured by this plant unit if the case study sub stance is not a product: Output (1976)/units of output: __________________________________________________________ ______________________________ / Approximate 1976 value of ship ments from this unit (sales plus internal transfer): $ Number of total employees (1976-- allocate, if necessary): Number of production employees (1976^: List the substances potentially controlled by this reculation that are present at the plant unit and the total number of employees exposed to these substances in this unit. List the case study substance first. Substances-< 5 NIOSH Regi;try Number^ Number of Employees Exposed Full Tine4 Part Time5 ' Total TT Include all employees assigned to the specific plant unit, e.g.: . Production workers . Maintenance employees generally assigned to the area First-line and other supervision assigned directly to that plant unit.. 2. Substances and their respective NIOSH number are listed in Appendix A. Other substances for which standards may he established under this regulation are listed in the NIOSH publication, Suspected Carcinogens, 1976 . 3. If an impurity, indicate its concentration. 4. Full Time - More than four hours per day, 90% of working days. 5. Part Time - More than 30 minutes per week, but less than full time. ALCOA0004350  / NGN COST V.'Cr.KSilNET . In It - .'i , | Cost EleSner.t 1 (Elements required for Category I or II assumption) 1. Initial monitoring cost 2. Exposure monitoring cost 3. Increased medical sur veillance cost 4. Added change rooms and showers 5. Emergency alarms 6. Respirators above current use levels 7. Personal protection equip ment above current use levels 8. Signs 9. Emergency plan 10. Recordkeeping 11. Training above current levels 12. Total, Category 1 or II assumption Canital Cost (1 9 77 dollars) (Elements required .for Category I assumption only) 13. Segregation of work areas 14. Lunchroom facilities 15. Total, Category 1 ns sump tier, (add lines 12, 13, ar.c 14) Annual Operating Cost (1977 Collars) ____________________ ____________________ Differentia) First Year Poorcting Cost (1977 Dollars) ALCOAO 004 351 i uO i~J XM XI 33 2W JJ > C3 D -u CO a; CC i--Oi c[fl c. u 6-1 t} kUS !I Cj C. i 3I gb > 5!.^: t ;C U o U0 zu cs 1 C3, M z H o z ta tLu*. cgL.l:i-c-i -* .J ~ u c^ 3 C <--* -- .^j r. O XM c :-i> kCir c --` U- l. Is-' v. tz, O', o>! ol r: 13 WIC3 C; o4Vr- h cl <1 o 4-*' I* CO' V, 0 V 0 D ojr^ rj ^ UH to u 0 Ll --o lo Cl. 1 0~ a v> 0 T3 >-- n0 0v. 'J' W. Wi Si * C* O ^ G 4-> y| o C' X W O T3 > a 13 fc-- / / t* (1 ) /Vssume cne b a r r e l o o i l is e q u iv a le n t to 6 m illio n BTU 's o r 567 k ilo w a tt- h o u r s . co to co to L 0 u ~C w a. u o~ a. 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G3 C GC >. ft 1 0 5 ft u X ft 4J u ft 3 p X 0 0 0kd * 4toJ X Gc ll-i CO >u1 ft c c ft 0 0iH 44 >c 0 ft 1 E 0ft ft- E --441 to --1 (0 4J 0 ft ft E ft ft ft tP c GG C G -p--H' rr a. CO 44 1-4 CO G 0 A-1 ft 404 Xft VM ___ p+GHj c 4.' 4JJ'. to ft u c ft 0ft H Ifdt H 4G4 fdt 4G4 rH pH dlO 0. G CN G O -- ft 4J 1 11 O 4to1 to 0 ft 4> O fVjt JJ H *H Xc -3 >H JJ 4GJ CG O pH ha C a p ita l re la te d c o s ts in c lu d e : D e p re c ia tio n a t 10 p e rc e n t. In te re s t a t 8 p e rc e n t. M aintenance a t 5 p e rc e n t. Taxes and Insurance a t 2 percent o f c a p ita l c o s t. ALCOA0004353 *i --' o k ?% tO(7-. O* 61 5 eQl* ac ;i > w {u h* L. tr. ^! C. V>,*c0 Su -*Sj,' rt *p i5- rri - v U~ E < B0M --T53 I *<0- > I--I .G *U1w>0 <yK> I E G fZ > k| wj a- ~ "Z v. I --ti c -V. Uv uOl: ; '1 5 i iktt...' --pS- >I - S sui oS.HI <O Ca**J3 cOUM c^* ~i?cH.' ^: AtvfJ.!:|II Cl ' V\ JO u| ~ <0 I c v: = 5 < *' o ,d -- Oiy si 2 Oi uac <i c * ri jcj ac uz u uO! * 3 V. ~ -- IN -SUMMARY DATA RKT-ATIVE COST CHANCES (A) Pcplnc. n o n t v o iu e o f p ro d u c tio n u n it in it s p re s e n t form (a e u c iin g id e n tic a l p la n t) . (3 ) T o ta l e'j i r e n t f ix e d and v a r ia b le m a n u fa c tu rin g c o s ts in f'l u d : ng d e p r e c ia tio n and m anagem ent co s bat e xclu d in g d is trib u tio n , and s e llin g , general and a d n in in tra tio n expenses. (C) H is to r ic 5 /e a r average p re -ta x p r o f it on a p p lic a b le su b sta n ce o r u n it . s 2 oc uc rC. I ALCOA0004354 c o c UG 0P X tn 6X 33 zw 4J >, "4 *0 C3 D -P W 44 co G tfl 1-4 o aa >< a D -< CO I CJ (0 < u s H~ MX Z< w Ha uw DH a <1 U< H 52 n OZ Cm < K CO oa z> U CO u => u DX CH CC 0. 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P X GG 2O aO 4-J 3 mH 3 0 Z Mi G a 44 G Ji*Q 2 r^* CO 0-. 0 to 1-4 0 G CO G (0 r4 G <-H 3G r. 3 33 a3 tz to tn to 0 to u0 C7* u 3* 3 H H 3 03 --4 0 E -H E o m u*> v> w cc d 'O -C X ttoo ttoo 0 <1> U m2 0 3 0 :* o o f'. uc 0 *H X ro P r-< oa x a t: c X o* 0 yn ^o <0 0 M4 O' 43 H nd ul a g e s r i h r t a l i in m i t s a re no th ut l b a o te n ti om ply, p c To what degree do you see a dom estic m a n u fa ctu re rs m ust H IN ALCOA0004355 sum ing p la n ts? a ll rout vir if to-: it) ro?.'' viii ADDITIONAL ECONCVIC I.-TECTS - PAW XATEPIALS - c.uz':-. P-c-.-.t Lr.it - Do technically feasible substitute raw materials (or alternate approaches) exist for this substance? Ves__________ No Descr ibe_______________________________________________________________________________ ______ If you switched to this alternative, what would be the effect a. Total raw material cost increase (decrease) S/year _____________ b. Other production cost increase (decrease) (exclude depreciation;, S/ycnr _____________ c. P&D cost.s to substitute, $ . _____________ d. Capital Investment required S _____________ <_. Other costs, explain, Capital ____________________________________________________________________ Differential First Vear What percent chance exists that increased costs of compliance with Category I regulation would result in your closing the unit rather than complying? _______________________________ * a. If this occured, what would be the effect on overall employment? Number effected Percent of employees m this unit _______________________________ _______________________________ How would a 10% price increase affect your use of this substance, assuming no parallel increase ir competitive substances? What action would you probatl'.. take if this substance were tc be designated as a "suspect carcinogen" (Category II) and standards weie issued recuirint the actions described herein? What action would you probably Labe if th.s substance were to be designated as a "confirmed carcinogen" (category I', and an Emergency Temporary Standard were issued requiring immediate compliance plus later engineering controls to reduce concentrations to the lowest level feasible? What actions would you take if use of this substance in this application were to be prohibited? What do you feci will be the effect of the proposed regulations on productivity in your plant under the three assumptions below: a. Increase in production workers, % of production, workers in this unit b. Increase in non.-nioiutt x 0:1 employees, t of non-product-ion employ . ns in this unit c. Decrease in production, 1 of production d. Change in productivity, (production per employee), % change Assume Category II Assume Category I Difficult Extremely to meet Difficult to Requ irer.ier.t `ioet. Requirement ALCOA0004355