Document qaVGw6J4ob7XZoL79bk44yE8G

of residual vinyl chloride monomer in polyvinyl chloride resins. While these goals are not yet possible or feasible within the limits of present technology, we.have taken steps which haye resulted in dramatic reductions>of vinyl chloride exposure in our polymer plant and residual levels of vinyl chloride in our .polyvinyl^chloride1 resinff*. We are confident that our efforts will continue to bring positive results, and with regard to polyvinyl chloride resins, that we will achieve production^of 3uch resinsvirtually* free- of^residualrvinyl chloridef. We urger,,'.the' adoptlon' and^ endorsement--of^-a time weighted average-7approchHbecauseiTmere^cellinglevels*alone-are^meaningless. The crxix of exposure levels is - what concentration over what period of time - and this can only be dealt with by the time weighted average principle. Scope and Definitions: There appears to be a conflict between 1910q(a)(l) and 1910(d) in that (d)(ii) uses the word "capable" whereas 1910(a)(1) does not. We suggest the deletion of the word "capable" from 2910(d) can be made without adversely effecting the standard. The term "released" is found throughout the standard, and we find such term ambiguous. The standard is concerned with levels of exposure to vinyl chloride in the atmosphere and should be so stated thereby deleting the use of the word "released." If, in the polyvinyl chloride manufacturing plants a no detectable level of vinyl chloride is technologically impossible at present, which we submit is the case, then 1910.93q(b)(8) "Emergency" must be redrafted. As written, there would be an 3- - SEHC 00 "emergency" 2h hours per day. "Dnergency" should be llmltedVito those few extraordinary situations which might give use to. a risk of exposure-to unusually, high levels of vinyl chloride. Monitoring: We support a system of combined area and personal monitoring. For area monitoring, we recommend a sequential fixed automatic system, whicn would trigger alarms at 25 parts per million and again at 40 parts per million. Hie first .alarm would alert personnel of elevating levels of vinyl chloride and allow time for corrective measures to be taken. Hie second alarm would, of course, be the signal to don respiratory equipment. itforwpersonal JSOPitoring^lJi^LS^our .opinion that carbon-charcoal^ tubes^*be tttili'zedsunti'taatfbetteir'method?. isvdeveloped. Respiratory Protection: With regard to respirators, we submit that at=?the~low levels^ of ^exposure;, contemplated that self-contained canister 'typetresprtortttwouldvbexadequate.and feasible*. We would, however, support the iuss^fafresh^ai^respiratons of the type set forth in 1910.93q(3) during the process of loading or unloading vinyl chloride monomer, and in other extraordinary situations where*.exposureta*'high^levels, of vinyl- chloride might:-'rMWrtaTJiyc'be,s-contemplateU'. Labeldnm* 1910.93 (k) (2) 'Shouid*bein,chrfged*rtOt''reflecttheT permissible <u8e^ofesel^centSi,tted5CSrtiStsr.type*,respirators. - 4- We auppogfr the--labeling of containers as set forth In 1910.93()cyt^&Miy-liAre residual vinyl chloride Is In excess of 0.1^6. This would be consistent with known carcinogen labeling requirements and is reasonable. Maintenance and Decontamination: 1910.93(1)(4) as proposed is neither necessary nor feasible. For vessel entry we support the use of Impervious clothing such as a rain slicker type suit, fresh air respiratory equipment, boots, gloves and headcovering. This combined with engineering controls and workpractice.s to provide for purging and venting the vessel prior to entry will provide more than satisfactory against vinyl chloride exposure. There should be a distinction drawn between vessel entry and normal maintenance and repair operations. Many normal repair and maintenance operations do not involve the danger of exposure to excessive levels of vinyl chloride, and these operations could be conducted safely with self-contained canister type respirators and normal protective clothing. Only such operations as involve an extraordinary risk of exposure to high levels of vinyl chloride should require the use of fresh air respirators and impervious clothing. . Record Keepings- __ The reoondwkeepingjrequiremente proposed are-unduty bujsdensoaajagandKftQiyuiterpgoduot-lveeiwIXhiifottgevery: ^excursion,al}flve thoTipermifeted? exposurefrlevefeno matter how slight or of limited - 5- duration a notification to the Occupational Safety and Health Administration and detailed written report is necessary there could be several-per day per plant being submitted. Data of this type would be virtually meaningless. We would suggest a quarterly form be submitted which would present exposure data for that quarter in an orderly and compiled faohion. 1910q(3) should provide time for the compilation of data inasmuch as such compilation will be necessary to determine if the permissible levels have been exceeded. Fabrication Operations; Our testing data indicates that there is, at worst, only* minimalyexposurei>ttOAVinyi chloride vlnv<fabrleatings plants. in fact, our evidence would indicate that in the operative breathing zone exposures to vinyl chloride are running zero^to^-lO^partsvpermillions These minimal Navels? are presently sbeingy reduced even further throughstthe-'uae ofxresins lower: in.:residual:.vinyl chloride, and by dnoreasedwentilatiom These ateps to further reduce vinyl chloride exposure, especially the reduction of resiaual vinyl chloride in the resin, are the key to solving any problems in the fabricating plants and are fteas-ible? and; technologically ..possible'. Accordingly, we submit that at this time there& is >no; need .for*a standardccoverlng^polyvinylAchloride ifabricating-.plants. The General Tire & Rubber Company suggests that while a detailed standard is not necessary at this time that bhesevshould betsome<monltorihgfbr5^Vlhy'l*chlbride>within^fabricating-.'plantS>, -6- and If any such, monitoring discloses vinyl, chloride exposure -levelsuabovetthoseasuggested for thepermanent standard,, that fiamedlate^notifi^ation be givenTto the Occupational Safety and Health Administration :andK&Qrrective^aotion.taken. In addition, the Occupational Safety and Health Administration should receive regular reports of the results of the monitoring in the N fabricating plants. If however, it is determined that there should be some regulation of vinyl chloride exposure In the fabricating plants, then we submit that such regulation should be in the form of a standard limited solely to fabricating plants. Feasibility, economics, logistics and the vast number of people and plants Involved coupled with minimal exposures dictate a conclusion that .polyvinyl#chlOSidftoEe#Ahsman^liftPture#>ife-not^suitablej'Knec es sary orfcsadvisKble^forrappli'eAtforrto^fabrlcabing plants. Respectfully submitted. TIRE & RUBBER COMPANY Sam Salem - President Chemical/Plastics Division \ genc 0000