Document qkdqJ5QdzJgvjV1b4bQ6RDBKx

rblished by Heer Publishing Corporation The Rubber Industry's Fortnightly Newspaper October 21,1974 1700 First National Tower, Akron, Ohio 44308 Vinyl Chloride Final Standard |i Stirs Protests ___________ i PVC Industry Fears Tough OSHA Stand Spells Doom By RPK Washington News Bureau WASHINGTON--The U.S. Occupation al Safety and Health Administration (OSHA) issued its anxiously awaited final standard for worker exposure to vinyl chloride on Oct. 4, and while the result wasn't the "no detectable" limit originally proposed by the agency, it was tough enough to raise a storm of industry protest--and at best faint praise from . labor. Within a few minutes of the standards' announcement, the Society of the Plastics Industry filed a petition for review of the standards in the Second Circuit Court of Appeals in New York. Additional lawsuits followed in rapid succession. Hooker and Union Carbide filed similar suits in the New York Court, while Tenneco and Air Products filed in the Third Circuit Court and Firestone in the Sixth. B.F.Goodrich is expected to follow suit. THE TOUGH new standard that has stirred such vehement opposition will require industry to reduce vinyl chloride concentration in air to no more than one part per million parts of air (ppm) over any eight-hour period and no more than five ppm over any period no longer than 15 minutes. OSHA has established a three-phase schedule for plants and factories to meet the standards. Perhaps the most vehement rejection of the standard came from Todd C. Walker, president of the Firestone Plas tics Co. Walker charged that the new standard "puts the vinyl plastics industry on a collision course with economic disaster." Walker cited an economic impact study made earlier this year by the Arthur D. Little Co., based on an initial proposed standard similar to the final permanent standard issued October 4. According to the Little study, Walker said, a standard as tough as the one now going into effect would cause the loss of some 2 million industry jobs. "This [Little] study and other medical, scientific and engineering data submitted by the industry and by individual com panies in response to OSHA's request," Walker said. " appear to have been completely ignored in establishing the standard." THE RESULT, said Walker, is a standard that is "economically unrealis tic. technically unfeasible, politically motivated and medically ridiculous." It is comparable, he said, "to a law aimed at stopping automobile deaths by lower ing the speed limit to one mile per hour." Firestone. Walker said, would initiate "necessary legal steps" to challenge the new standard._________ Spokesmen for Goodyear, meanwhile, declined to comment on the substance of the standard, indicating only that the company would take the necessary steps to try to comply. And, at least one firm, | Robintech Inc., indicated that only minor alterations would be required to comply with the standard. In posting the permanent standard, OSHA officials acknowledged the diffi culty some segments of the industry. would have in achieving compliance. "There is little dispute that VC [vinyl chloride] is carcinogenic [cancer-causing] to man and we so conclude," said OSHA Chief John H. Slender. "However," Stender added, -"the pre cise level of exposure which poses a hazard and the question of whether a `safe' exposure level exists cannot be definitively answered on the record. Nor is it clear to what extent exposures can be feasibly reduced." But, Stender emphasized, OSHA "can not wait until undisputable answers to these questions are available ... lives of employees are at stake." r; Continued 37160(11 BFG26959 RUBBER & PLASTICS NEWS - October 21, 1974 VINYL CHLORIDE FINAL STANDARD STIRS PROTESTS -2- ACCORDINGLY, he said, "on the basis of the best available evidence," OSHA has judged that the exposure limit must be reduced to 1 ppm on a "timeweighted average [TWAl" to protect workers. "We also believe." Stender concluded, "that PVC [polyvinyl chloride] and VC establishments will, in time, be able to attain that level through engineering con trols, and that fabricators can do so in the immediate future." Noting that the standard will apply to the entire VC industry, including manu, facturers of vinyl chloride monomer I__(normally a gas) and polyvinyl chloride : polymer (no.rmaily a resin compound used in a number of plastic materials) 1 and fabricators of plastics products using VC and PVC (employers who use or handle finished fabricated products are exempt). OSHA officials summarized key | provisions of the standard as follows: Employers must set up "regulated | areas" where concentrations of VCM j (vinyl chloride monomer) exceed the "one and five ppm" limits, with access ! limited to "authorized" workers. Plans for reducing exposure to the j permissible "one and five ppm" levels j must be available on request of OSHA. Direct contact by employees with liquid VCM is prohibited. Monitoring and measuring programs i must be initiated to learn whether ex- , posure levels exceed 0.5 ppm. Depending 1 on levels found, repeat measurements are required at least monthly or quarterly. They may be discontinued only when i two consecutive measurements, no fewer i than five working days apart, show indi- ! dividual employee exposures to be less than 0.5 ppm. i Monitoring and measuring methods must meet accuracy requirements ranging from not less than 50% in concentra tions from 0.25 through 0.5 ppm, to 25% for levels greater than one ppm. Where the regular monitoring pro gram shows excursion levels may exceed 25 ppm, a continuous monitoring and alarm system must be used to alert em ployees to potential danger if they are using air filtering respirators (gas masks). At that level they must switch to respira tors with a clean air supply. Protective garments as well as res piratory protection must be provided for employees in hazardous situations, such as cleaning operations in PVC vessels. Medical programs must include complete initial examinations. Subse quent ones will be required every six months for employees who have worked in VCM or PVC operations for 10 or more years, and annually for all other exposed workers. Alternative medical examinations will be acceptable if the examining physician states his procedures and reasons for substitution. All medical checks are at no cost to employees. Specified signs or labels are required at entrances to "regulated areas," in hazardous operations or emergency areas, on containers of PVC resin waste, PVC containers and VCM containers. Records of required monitoring and measuring, medical records, and rosters of "authorized" workers must be kept for varying specified times, or be sent to the Director. National Institute for Occu pational Safety and Health, if an em ployer ceases to do business before the expiration of retention periods. Reports must be made to the nearest OSHA Area Director no later than one month after establishing a "regulated area," and within 24 hours of any "emer gency" exposure. Also, reports to affected employees must be made within 10 days after monitoring and measuring shows exposure in excess of the "one and five ppm" limits, including the results of the measurements and steps being taken to reduce exposure to permissible levels. 37160O2 BFG26960