Document r9Mb3RZ76KeqDZnnpVYV2NK0

/-(v-v > *7 ,, J-JjJ j U'-Au J- NOT fOR PUBLICATION 24 AUGUST 1984 ACTS/VCN/MC/GN/33/5 GUIDANCE NOTE EH -mVINYL CHLORIDE: TOXIC HAZARDS AlfD PRECAUTIONS CMA 007646 CONTENTS INTRODUCTION PROPERTIES OF VINYL CHLORIDE HEALTH HAZARDS RESPONSIBILITIES CONTROL LIMITS ALARM LEVELS ASSESSMENT CONTROL MEASURES FOR MATERIALS, PLANT AND PROCESSES Design sad operation Local exhaust ventilation Venting General ventilation Cleaning and waste disposal AIR MONITORING Discontinuous methods Continuous methods Measuring equipment Location of sampling points for fixed analysers or automatic sequential fixed point sampling systems Accuracy and calibration Laa'x detection Alarm systems Recording of results PERSONAL PROTECTIVE EQUIPMENT Respiratory protective equipment Protective clothing PSRMITS-TO-WORX Confined spaces Maintenance operations MAINTENANCE OF CONTROL MEASURES EMERGENCY PLANNING REGISTERED WORKERS HEALTH SURVEILLANCE INFORMATION, INSTRUCTION, AND TRAINING CM* 007647 FACILITIES _Waahiag and changing facilities Arrangements for eaciag, dr inicing and smolting NOTIFICATION TO THE HSE RECORDS APPENDIX 1: Properties of vinyl chloride APPEND LX 2: Sampling strategy flow chart APPENDIX 3: Model letter to the family practitioner of a vinyl chloride worker on his leaving employment with vinyl chloride APPENDIX 4: Model form of consent for disclosure of a worker's medical records relating to vinyl chloride to Appointed Doctor APPENDIX 5: APPENDIX 6: Records Legal requirements CMA 007648 INTRODUCTION 1 Vinyl chloride is a colourless, highly flammable gas ac room cemperacura and atmospheric pressure. It is normally scored and handled under pressure as a colourless liquid. It has a slightly sweet odour detectable at concentrations above 2000 ppm. In tne UK virtually all vinyl chloride is used as starting material for the production of polyvinyl chloride (PVC.) homopolymer; a small amount is used for copolymerisation with vinyl acetate. PVC is used extensively in pipes, flooring, home furnishings, electric cable insulation, blow moulded containers, packaging and records. 2 This Guidance Note has been prepared on the basis of joint discussions between representatives of tne Confederation of British Industry, the Trades Union Congress and the health and Safety Executive within a Working Group of the health and Safety Commission's Advisory Committee on Toxic Substances. j This Guidance Note provides practical guidance for employers, selfemployed persons and persoas In control of vinyl chloride monomer manufacture and polymerisation plants to assist them in complying with the Control of Sustances hazardous to health Regulations 193- and Approved Code of Practice for the Control of Vinyl Chloride at Work. References In this note to 'employers' should be taken to include self-employed persoas. This Guidance Note may also be helpful to safety representatives in fulfilling their statutory functions under the Safety Representatives and Safaty Committees Regulations 1977. The guidance will be used by Inspectors of tne health and Safety Executive (hSEj as part of their criteria for assessing compliance with tne health and Safety ac Work Act 1974 and otner relevant scatucory provisions 4 The Control of Substances Hazardous to Health Regulations 193- apply to all toxic substances, used at work, including vinyl chloride. The Directive of the Council of Che European Communities (78/610/ESC) on the approximation of the Laws, regulations and administrative provisions of tne Member States on the protection of the health of workers exposed to vinyl chloride monomer applies to the protection of tnose workers vno:- 1 CMA 007*49 (a) -are employed la works la waieh viayl chloride is produced, reclaimed, scored, discharged into containers, :cansporead or used la any way whatsoever or in which vinyl chloride is coaverced iaeo vinyl chloride polymers, and (b) are likely to be affected by exposure to vinyl chloride in a working area. 5 VINYL CHLORIDE IS HIGHLY FLAMMABLE AND PRESENTS A CONSIDERABLE FIRE AND EXPLOSION HAZARD; THIS GUIDANCE NOTE DOES NOT GIVE ADVICE ON SUCH RISKS. Vinyl chloride cooes within the group of substances defined in Class 2 of Pare II of Schedule 1 of the Notification of Installations Handling Hazardous Substances Regulations 1982. It also cooes within the definition of a flammable gas as set out in Schedule 1(c)(1) of the Control of Industrial Major Accident Hazards Regulations 1981. Some of the requirements of these Regulations overlap with certain sections of this Guidance Note. Where this occurs reference is made In the text and the Regulations should be consulted for further details. 6 This Guidance Note does not give detailed advice on the coacrol of emissions of vinyl chloride to the atmosphere. HM Industrial Air Pollution Inspectorate Is responsible for the control of air pollution arising from industrial processes involving the production of PVC and copolymers from vinyl chloride monomer. For detailed guidance on the control of emissions, reference should be made to the HSE Note on Best Practicable Means BPM 3/79 : Petroleum Works (PVC polymer Plants). PROPERTIES OF VINYL CHLORIDE 7 The properties of vinyl chloride are set out in Appendix I. HEALTH HAZARDS 8 Vinyl chloride is a gas at room temperature and atmospheric pressure and the most common route of absorption into the body is by Inhalation. 2 007650 CHA 9 Acute exposure to vinyl chloride vapour causes central nervous system effects, Che severity of which increase with exposure. Ac exposures of 50-500 parts-per million (ppm) in air for 7 hours no apparent acute effects have been found in humans. However, exposure to 20,000 ppm (23) for 3 minutes resulted in dizziness and disorientation. Incapacitation occurred at concentrations above 80,000 ppm (33) over 5 minutes. Exposure to concentrations of 300,000 400,000 ppm (30-40%) is rapidly fatal. 10 Chronic exposure co vinyl chloride has been associated with angiosarcoma of Che liver, liver or spleen fibrosis (similar co the perilobular fibrosis known as Band's Syndrome), circulatory disorders in cne hands and feet (similar co Raynaud's Phenomenon, also known as white finger), scleroderma (a degenerative lesion characterised by stiffness of the skin and soft tissues) and aero-osteolysis (a deterioration of certain bones, most commonly tne terminal phalanges of the fingers). Such effects have usually occurred after cnronic exposure to levels in excess of LQ0 ppm (see para 12). Vinyl chloride is a proven human carciaogen with no known threshold of effect. 11 Ocher effects have been reported as occurring in workers chronically exposed to vinyl chloride monomer at similar levels of exposure, although such reports have been disputed by others, these include tumours of Che brain, lung, haemo-lymphopoietic system, and skin (malignant melanoma), lung function disorders, chrombocytopoenia and immune complex disorders. Effects on reproduction nave also been reported. 12 Tne general consensus of opinion is tnac polymerisation vomers between 1940 and 1975 might have been exposed to levels of vinyl chloride of cne following order:- 1945-33 1000 ppm 1953-6U 1960-70 400 - 5QU Ppm 300 - 400 ppm Mid-1973 130 PP 1975 5 ppm 3 CMA OO 765 Throughout the world there will have been variations around these figures because of differences in plant design or process operation. RESPONSIBILITIES 13 Employers must do all chat is reasonably practicable to safeguard Che health of chair employees and others wno may be affected by work activities involving vinyl chloride. In particular, they have a duty to comply with the provisions of the dealch and Safety at Work. etc. Act 1974, the Control of Substances Hazardous to Health Regulations 198- and the ACoP on Vinyl Cnloride. Employers may also have a responsibility to comply with the Factories Act 1961 and ocher associated health and safety legislation (see Appendix 3). U Section 2(3) of the H5W Act requires employers, with certain exceptions, to prepare, and revise as appropriate, a written statement of cneir general -.policy with respect to the health and safety at work of their employees and che organisation and arrangements used to carry out chat policy and Co bring the statement and any revision of it to che notice of all of their employees. The arrangements within the organisation for a formal system of joint consultation between management and employees and their representatives on all aspects of cne Approved Code of Practice on Vinyl Chloride should also be sec out in che safety policy. 13 In che safety policy, a member of senior management snould be given responsibility for ensuring chat che matters covered by che Vinyl Chloride ACoP, cne Heaich and Safety at Woe*. etc. Act and che Factories Act, etc are implemented. These include cne responsibility for safe systems of work, safe places of worst, training, monitoring, emergency procedures, joint consultation etc. He snould be provided with appropriate support as may ba necessary. L6 Responsibility for implementing particular aspects of che Approved Code of Practice and this Guidance Noca should be allocated at each appropriate level within che organisation with a clear line of communication from plant operatives to the person in overall charge. Steps should be taken to ensure chat individuals understand and accept cneir responsibilities. 4 CMP* 007A52 17 Employees should cooperate with management la implementing health and safety precautions and la making proper use of the equipment and facilities provided for their protection. They should report immediately to their supervisory any suspected faults or material defects in plant or deficiencies in the control measures taken to contain vinyl chloride and reduce exposure. 13 Safety policies need to be reassessed at regular intervals to ensure chat they are still appropriate and effective, particularly when significant cnanges in plant or work activities occur. Such assessment should include, of course, the organisation and arrangements for complying with the legislation, code of practice, etc relevant to vinyl chloride. CONTROL LIHI'CS 19 The Control Limit for occupational exposure to vinyl chloride vapour in air is an Annual Control Limit of 3 ppm and is the value which should not be exceeded by the concentration, averaged with respect to time, of vinyl chloride monomer in the atmosphere of a working area over a period of one /' year. Only periods of plant operation including, where necessary, any maintenance time should be taken into account. Periods during which alarm' level concentrations are measured need aot be taken into account when assessing compliance with the Annual Control Limit. In practice, the atmosphere of working areas should be monitored regularly (see paragraphs 3762) and the results summarised on a shift and monthly basis. A 'rolling average' time weighted average concentration of vinyl chloride-in-air can then be calculated and over any period of 12 successive calendar months it should not exceed 3 ppm. In this way, past compliance with the Annual Control Limit can be cheeked and trends noted. This Annual.Control Limit is supplemented by an 3 nour time weighted average (TWA) Control Limit of 7 ppm for personal exposure with the proviso chat the Annual Control Limit is not exceeded. These Control Limits have been judged after detailed consideration to be reasonably practicable for the whole spectrum of work activities in Great Britain and should not normally be exceeded. 20 For substances, such as vinyl chloride, for which there are no known thresholds below which adverse effects do noc occur noc only should exposure be kept below the Control Limits but it snould also be reduced still further until the point is reached where the costs of further control measures are not justified in terms of Che additional reduction in risk. 3 007& alarm levels 21 In vinyl chloride monomer manufacturing and polymerisation planes there should be a system for the automatic detection of high levels of airborne vinyl chloride la places where these may occur (see para 54). The following concentrations of vinyl chloride in the atmosphere of a working area should be treated as alarm levels, signalling the need for evacuation and remedial action (a) 15 ppm when measured over a period of 1 hour, or (b) 20 ppm when measured over a period of 20 minutes, or (c) 30 ppm wnen measured over a period of 2 minutes. Where a continuous multi-point analyser (see paragraphs 40-41) is used, two successive readings above the appropriate concentration will determine the _* existence of an alarm level, le L5 opo over a period of 1 hour and 20 ppm over a period of between 20 and 30 minutes. ASSESSMENT 22 Under the Control of Substances Hazardous to Health Regulations an employer must not carry on any work which may expose his employees to any substance hazardous to health unless he has made an adequate assessment of the risxs to health created by the substance. The assessment Involves identifying the nature of the substance, the risks to cne health of persons who may be exposed, Che nature and degree of exposure which may occur during the course of worm and the steps to be taken to avoid risKs to health. In order to ensure effective control of exposure to vinyl chloride, it is necessary to collect and assess adequate data on the circumstances under which exposure may arise. In existing plants, most of these data will already nave been oDrained. All work activities which may involve exposure should be assessed to identify actual and potential sources of emission of vinyl chloride vapour into cne worming atmosphere. The nature and degree of exposure should be studied in eacn case. In Appendix 2, a flow chart secs out a sampling strategy for the assessment of exposura to toxic substances. Assessment permits the formulation of plans for the development and introduction of effective engineering, operational and ocher measures for the prevention or control of exposure, for the maintenance CM* 007&54 6 of such measures and for the long-term monitoring of their effectiveness. It also-lndicaces activities where the only reasonably practicable aethod of preventing, exposu're is by using respiratory protective equipment. In existing plants, operating experience and monitoring data should already have lad to the introduction of most of these control measures. 23 The employer should ensure chat whoever carries out the assessment is competent for the purpose and has received adequate information, instruction and training. 2b Examples of work activities which may give rise to exposure to vinyl cnloride include (a; transport, storage, discharging into containers, breaking down from bulK, polymerisation, reclamation and sampling of vinyl chloride or materials, Including waste, containing it in residual or unreacced form; (b) / the operation, cleaning, maintenance and repair of any apparatus'or process plane used In the production and conveyance of vinyl chloride or in its polymerisation and the handling and storage of freshly polymerised maeerial. 25 An employer should consider not only the exposure of his employees engaged upon work with vinyl chloride but also that of:- (a) ocher of his employees not directly involved with vinyl chloride wno could be affected by chat work activity; (b) ocher people who may be exposed while on the premises, eg tne employees of outside contractors engaged on maintenance; (c) members of the public who may be affected by emissions aad discharges from the workplace. 26 To estimate the degree of exposure to vinyl chloride by inhalacioa, it is usually necessary to carry out a comprehensive personal atmospheric sampling survey. However, vinyl chloride in air estimations need not be carried out in every Individual case, particularly when sufficient Information based on 7 CM<A 00765 previous measurements is already available in relation to a specific work activity or where it may be possible to group employees on the basis of similarity of degree of exposure aad type of work done to enable an adequate assessment of likely exposure to be made. It is important to study the pattern of exposure of workers in different jobs and locations over whole workshifcs and to identify when and where the highest exposures are likely to occur taking into account the possibility of unusual circumstances such as plant breakdowns or emergencies. 27 It is important to carry out sufficient sampling to enable accurate 3 hour time-weighted average concentrations to be calculated. However, shorter term sampling may assist in the assessment of the performance of engineering controls. The survey of exposures should be extended over sufficient workshifts co ensure tnat the variability of exposure is adequately studied. Further detailed information and advice Is available in USE Guidance Mote EH "2 - 'Monitoring Strategies for Toxic Substances'. 23 It is recommended that the results of the assessment be recorded and a copy provided on request at any reasonable time during working hours to employees and/or their representatives at the place of work. 29 The assessment should be revised whenever there is evidence or reason to suspect that it is no longer valid, as a result of, for example (a) a significant change la che work activity; this could be a change in plant, processes or mecnods of work that might affect che nature or degree of exposure, such as tne raising of process temperatures or changes in engineering controls; (b) results of sir monitoring at che work place revealing an increase in exposure; (c) data arising from healcn surveillance; (d) new information on health risks becoming available. CONTROL MEASURES FOR MATERIALS, PLANT AND PROCESSES 30 When considering appropriate control measures for reducing exposure to a toxic substance, che first strategy to examine Is substitution with less 8 ChA 007656 hazardous materials, including Che alteration of synthesis routes to avoid using or producing toxic intermediates. Users or potential users of vinyl chloride and polyvinyl chloride should consider the use of a less toxic substance but if that is not possible control measures snould be applied as far as is reasonably practicable, irrespective of the size of the plant, to minimise exposure of personnel to vinyl chloride. 31 Control may be considered adequate when exposure to vinyl chloride is effectively controlled to the occupational Control Limits and as far below them as is reasonably practicable In the particular circumstances. The objective in applying materials, plant and process control measures is to ensure adequate control of exposure without recourse to personal protective equipment so far as is reasonably practicable. Design and operation 32 Equipment and processes should be designed and operated to eliminate or minimise the risks of leakages and spillages of vinyl chloride and to minimise the need for maintenance or other work which requires the breaching of and/dr entry into plant in which vinyl chloride is liable to be present. General ventilation 33 Good general ventilation should be provided for rooms and buildings in wnicn processes involving vinyl cnloride are carried on and as far as possible plant should be sited in the open. Local exhaust ventilation 34 Vinyl chloride should be handled in enclosed equipment provided with local exhaust ventilation at any points where the emission of vapour cannot be eliminated by improved design or maintenance. Local exhaust ventilation should also be provided at specific locations in process plant to ensure chat maintenance operations can be carried out safely. Venting 33 HM Industrial Air Pollution Inspectorate and HM Factory Inspectorate should be consulted on any points relating to plant or storage where mere is the potential for Che emissloa of vinyl chloride into the atmosphere to ensure chat bach the public and the workforce are not at risk. 9 CMA 00 Cleaning and waste disposal 36 Vast* polyvinyl chloride slurry containing significant levels of residual vinyl chloride should be stripped of vinyl chloride prior to suitable treat ment of the liquid waste for general disposal. Solid polyvinyl chloride waste should preferably be dried before disposal. Wastes arising from vinyl chloride processes should be handled and disposed of in accordance with tne Department of Environment Waste Management Paper Mo 13: 'Halogenaced Organic Wastes - A Technical Memorandum on Arising*, Treatment and Disposal including a Code of Practice'. AUl MONITORING 37 The objectives of monitoring concentrations of airborne vinyl chloride in wording areas ara:- (1) to verify that any technical measures and working procedures maintain adequate control of exposure; (2) to detect abnormal Increases in vinyl chlorlde-in-air levels which may occur as a result of failure or malfunction of some part of tne plant or apparatus, with references to the short term alarm levels for vinyl cnloride; (3; to provide adequate records of ctie exposure of individuals for the purpose of epidemiology. 38 The arrangements for monitoring require careful planning to achieve effective and efficient use of resources. A formal air monitoring plan should be drawn up and made known to all employees working in areas where vinyl chloride is liable to'be present. The.plan should contain details of the air monitoring procedures and equipment that art to be used to meet the objectives sec out in para 37, including details of:- (a) tne parts of plant, working areas and occupational groups of employees to be monitored; (b) the type of air sampling to be carried out, eg personal air sampling, fixed point air sampling; 10 CMA 007658 (c) the frequency of air sampling and the siciag of air sampling equipment; (d) the types of sampling and analytical equipment to be used; (e) arrangements for the testing and calibration of sampling and analytical equipment; ({) the statistical analysis and presentation of the air sampling results. The information obtained from the initial and any subsequent assessments snould be used when planning or revising the details of the monitoring procedures. 39 Static sampling will be the main method used routinely for assessing compliance with the Annual Control Limit and detection of alarm levels in vinyl chloride monomer production and polymerisation plants. In order to / assess compliance with the 8 hour TWA Control Limit personal monitoring will be necessary. 40 Static sampling may be either by discontinuous or continuously operating sequential systems, except at vinyl chloride polymerisation plants sited within buildings where only the latter methods should be used. 41 Where discontinuous air sampling techniques are used, the frequency of measurements should be sufficient to predict wich a confidence coefficient of at lease 95%' cnat there is compliance with the Annual Control Limit, in other words that the Control Limit value falls above the upper 95% confidence limit for the true annual arithmetic mean for the working area. The required frequency will thus depend upon the variability of concentrations with time. 42 Where vinyl chloride is handled intermittently, moaitoring of exposures by personal sampling should be done sufficiently often to ensure that technical control measures and working procedures are adequate to keep exposure below tne Control Limits. 1J Large working areas will normally require more tnan one monitoring point and in such cases tne average value of the measurements recorded should be considered as the representative value when assessing compliance with the Annual Control Limit. 11 CMA 007659 Measuring equipment 44 The sensitivity, range, selectivity and speed of response of an analytical device should be appropriate to the duty it is required to perform. Electrical equipment in flammable atmospheres should be suitably constructed, protected and installed; guidance is available in BS Code of Practice 1003. 43 The following techniques are among chose suitable for detection and measurement of vinyl chloride (a) gas chromatography (b) infra-red absorption analysis (e) flame ionisation detection Flame ionisation detection is not specific for vinyl chloride and may therefore give readings which are greater than the actual concentration. 46 Gas samples may be taken by any technique which is recognised and acceptable for the analytical technique to be used. 47 A comprehensive description of the various analytical techniques available for the measurement of vinyl chloride are given in 'The Determination of Vinyl Chloride: A Plant Manual - Analytical Mecnods for the Control of Vinyl Chloride Concentrations In and Around Manufacturing and Process Plants' pubiisned by the Chemical Industries Association Limited, Alembic douse, 91 Albert Embankment, London SE1 7TU. Details of one of the personal sampling mecnods used by HSE are available in MDttS 24 - 'Vinyl Chloride in Air: Laboratory method using charcoal abosrbenc cubes, solvent desorption and gaa chromatography'. Location of sampling points for fixed analysers or automatic sequential fixed point sampling systems 46 Sampling points should be located within tne working area to sample air representative of tnat breached by the workers. The probes should normally 12 CMA 007660 b si cad -at breaching height and at local places where the air movement is representative of Che general working area and should aoc impede che movement of workers, access to or operation of equipment. 49. Other locations for sampling points may also need to be chosen so thae any increase in concentration of vinyl chloride arising as a result of leakage or plant malfunction can be detected as soon as possible (see para 54). Accuracy and calibration 50 If a measuring system is used which records vinyl cnlocide and ocner substances without being capable of distinguishing between cnem, the results obtained should be regarded as representing vinyl chloride only. Special consideration may need to be given to che interpretation of results where there are indications chat che Control Limit is being exceeded but it is known chat this is due to ocher substances. 51 The precision and accuracy of che sampling systems used should be investigated over the vinyl chloride in air concentration range of 1*30 ppm. An accuracy of 102 within this range Is satisfactory. The method used and che results obtained should be recorded. 52 Measuring equipment should be calibrated regularly, In accordance with che agreed air monitoring plan, using che most appropriate technical methods. The calibration of automatic air sampling systems should preferably involve che Injection of air samples containing known amounts of vinyl chloride into che system at sampling points, rather chan directly into che analysing instruments. Leak detection 53 Leak detection may be carried out by the following means:* (a) portable analyser; (b) mobile sample line attached to a non-portable analyser; (c) ultra-sonic leak detector. 13 CMA 007661 Alarm systems 54 Whatever sampling system is used for routine monitoring, there should also be a system for Che automatic detection of high levels of airborne vinyl chloride-in places where these may occur, eg in Che event of plant failure. The alarm system may be integrated with a continuously operating or permanent sequential system provided for the purpose of air monitoring. Recording and presentation of results 55 The results of all atmospheric monitoring at fixed points should be available for inspection by personnel working in areas where vinyl chloride is liable to be present and their representatives at any time during a working period. Where continuously operating multi-point sequential sampling methods are employed, the results should be displayed as far as possible within two hours of the end of each shifc sampled. Where discontinuous method and/or---personal monitoring are used, the results should be displayed within 24 Hours of completion of the sampling period where possible. 56 In the areas where continuously operating multi-point sequential sampling and analysing equipment Is Installed, results should be summarised on a shift basis for each identifiable work area showing Che average concentration in the area. Sasic details of the position and number of sampling point3 together witn the frequency of sampling and analytical methods used should be Included at the beginning of the series of records and thereafter need only be recorded when changes occur in the monitoring procedure. 57 In the areas where sampling is carried out other than oa each shifc, the individual time weighted average results should be recorded. These should be sumarlsed on a monthly basis showing cne average concentration at each location with an analysis of the distribution of cne individual results. 58 Records of maintenance and monitoring should provide sufficient inform ation to enable employers, self employed per3oas, persons In control of premises, employees and/or their representatives at cne workplace, and enforcing authorities to:- 14 CMft 0076^2 (a) ascertain whether maintenance or monitoring has been carried out; (b) monitor the performance and effectiveness of control measures; (c) gain access to information on any defects or matters requiring attention and on the remedial action taken; (d) identify exposure trends. 59 The records should contain at least the following information:(1) Leakages of vinyl chloride (a) description of area or plant inspected; (b) dace of inspection; (c) time of inspection and shift; (d} statement of any defects or leaks found that might result in the release of vinyl chloride vapour above the 3 hour TVA Control Limit or alarm levels; (e) significant uncontrolled or abnormal emissions of vinyl chloride to the atmosphere reported to HMIAPI; (f) indication of action taken following discovery of faults; (g) name, signature and appointment of person making inspection. (2) Examinations of ventilation equipment (a) location and type of plant; (b; data of examination; 15 007 _ (e) \instruments used and results of instrument readings; (d) defects noted; (a) action taken; (f) name, signature and appointment of person making examination. (3) Excursions above the alarm levels as detected during area monitoring (a) part of factory to which the record refers; (b) precise location within the factory; (c) data, time and (where known) duration; (d) maximum time weighted average concentrations recorded; (f) result of Investigation; (g) actioa taken; (h) name signature and appointment of person maxing Inspection. (4) Personal monitoring (a> name of employee; (b) dace; (c) time and duration of exposure; (d) time weighted average concentrations recorded; (e) precise duty and working area wlcnin factory; if) nature and nominal efficiency of respiratory protective equipment (if worn). CMA 007664 16 The results of personal monitoring should be summarised on a monthly basis by Job-eacegory in each plant in addition to shift results. 60 If respiratory protective equipment is worn by any personnel during air monitoring exercises, this should be recorded together with the nature and nominal protection factor of the equipment to enable an estimate of the 'actual' exposure to be made. 61 Records may be kept in any suitable form, including microfilm, computer or similar techniques, provided they satisfy the foregoing requirements and can be retrieved readily when required. 62 Records of air monitoring should be kept for at least 30 years. In tne long term, air monitoring results may be kept in the form of monthly summaries, but in this case the detailed shift records on which they are based snould be kept for at least 1 year. Records of leakages of vinyl chloride and examination of ventilation equipment should be kept for at lease 2 years. PERSONAL PROTECTIVE EQUIPMENT Respiratory protective equipment 63 Where adequate control of exposure to vinyl chloride cannot be achieved by normal engineering controls and tne provision of further control measures for materials, plant and processes is not reasonably practicable, workers should be provided with adequate and suitable respiratory protective equipment. The term 'adequate' with respect to respiratory protective equipment refers to tne ability of the equipment to protect the wearer; 'suitable* refers to the correct matching of cha equipment to the job and to the person. To be considered adequate and suitable, respiratory protective equipment-muse be correctly selected and used* It should be noted tnac tne nominal protection factor of respiratory protective equipment can only be achieved if the face fit of the equipment Is very good. In the case of vinyl chloride, this means compressed air line or self-contained breathing apparatus of a type approved by or conforming to a standard approved by tne Health and Safety Executive. 17 CMA 007665 64 In particular, adequace and suitable breaching apparatus muse be worn:- (L) when it is not reasonably practicable to remove vinyl chloride vapour by local exhaust ventilation, a.g, when opening equipment which may release appreciable quantities of vinyl chloride to the atmosphere and during the maintenance or repair of equipment. No such operation should be conducted without a parmic-eo-work issued by a competent person designated by the employer for this purpose. Precautions should be taken to ensure chat ocher unprotected personnel in the vicinity are not liable to be exposed to concentrations of vinyl chloride above the 8 hour TVA Control Limit; (2) during entry into confined spaces which have not been certified by a competent person as being safe for entry without breathing apparatus. 65 Following an alarm, adequace and suitable breaching apparatus should be'worn by any person remaining in an affected area until the alarm is over. -The source of an escape of vapour should be Identified and appropriate corrective action taken without delay. 66 It is recommended chat no person should be required to rely for protection on respiratory protective equipment unless-he has successfully completed a training or refresher course on che use of such equipment within the previous 12 months and has been Issued with a certificate to this effect. The training or refresher course could include cne following (.a) principles of operation and use of equipment; (b) practical use, correct fitting, etc; (c) limitations of the equipment; (d) common defects and action required; 18 CMA 007666 () company arrangements for issue, cleaning, maintenance, etc; (f; wnen it'is to be used. 67 A register of authorised personnel trained in the use of respiratory protective equipment should be kept together vich a record of each person's training. All breaching apparatus should be maintained in a clean state, in good repair and in efficient working order. It should be inspected every 14 days and defects identified and remedied immediately. The maintenance schedules should specify chat the compressed air supplied to the wearer of breaching apparatus should contain not more chan 5 ppm carbon monoxide or 500 ppm carbon dioxide or 0.5 mg m~3 oil mist and except for these should be free from contamination by dust, dirt, metallic particles or any ocher toxic or irritant substances whatsoever. The maintenance schedules should also include tne source of compressed air, the air line, particularly the connections, and proper cleaning and reissue of equipment. 68 No respiratory protective equipment which has been used should be worn again by another person unless it has been thoroughly cleaned and disinfected. 69 Records of maintenance and inspection of respiratory protective equipment should include the following information:- (a; name and description of equipment'; (b) person issued to, if on personal issue; (c) date of inspection; (d) description of any defect found and action taken; (e) name, signature and appointment of person making inspection. These records should be kept for at least 2 years. Protective clocnlng 70 Under normal circumstances, where vinyl chloride is handled within enclosed plane, chare say be no need for the wearing of special protective clothing by process workers. However, certain circumstances, such as entry into confined spaces or some maintenance work, may require the use of special protective clothing. Such situations should be identified as part of the general assessment. The standard of clothing necessary will depend upon the nature of exposure. For example, where substantial body contact can be foreseen a high standard of protective clothing should be provided, eg completely enclosing air-fed suits (where respiratory protective equipment is also necessary) of wire reinforced FVC, or overalls of PVC-proofed material, completed In all cases by PVC gloves and boots. Where an area is relatively free of vinyl chloride, having perhaps been cleaned by means of high pressure noses or other methods, overalls of materials such as tarylene or cotton, may be adequate. PERMITS TO WORK 71 A permit-co-work is essentially a document which secs out the work to be done and the precautions to be taken. It predetermines a safe procedure and ' is a clear record that all foreseeable hazards have been considered in advance and that all appropriate precautions are defined and taken in correct sequence. It does not, in itself, make tha Job safe but Is dependent for its effectiveness on the persons concerned conscientiously carrying out tha requirements of the permit. There should be provision an the permit-co-work for the persons authorising Che work to sign to this effect and for the persons carrying out the worse to sign the .document at each stage of the operation as It is completed. Permits to work should be issued for all entries into confined spaces and for certain maintenance operations. Copies of all permics-to-work issued should be kept for a minimum period of 2 years. Confined spaces 72 In this Guidance Note the term 'confined specs' includes any chamber, tank, vac, pic, pipe, flue or sinilar confined space such as, for example, a reactor, duct, or bunker in which vinyl chloride vapour is known to be or is liable to be present. 73 Unless adequate precautions are taken, encry into a confined space involves a particular risk of exposure to very high levels of vinyl chloride or lack of oxygea. Concentrations of vapour may aven be such as to involve a 20 CMA 007668 risk of persons being overcone with a consequent risk, to life, in addition to the--possible long-term effects of exposure. Plant should be designed and operated.so as to reduce to a minimum time spent in vessels and the number of occasions requiring entry. 74 In order to reduce the potential short-term and long-term risks, entry into confined spaces should be strictly controlled. A peraic-co-vork system should be operated and other special precautions taken as outlined in USE Guidance dote GS 5 - 'Entry into Confined Spaces'. 75 Whenever a person enters a confined space for any purpose, a lifeline should be worn or, where this is not practical, some ocher method should be used, to enable a second person posted outside the confined space to keep in constant contact. The second person should be able to raise the alarm and equipment and trained personnel should be readily available for rescue purposes. All workers Involved in any way with work la coafined spaces should be fully trained and conversant with the organisation's agreed emergency procedures. 76 Unless a confined space has been certified in writing by a competent person as being, for a specified period, safe for entry without breathing apparatus and the period has not expired no person should enter or remain in the confined space for any purpose unless he is wearing suitable breaching apparatus. The permic-co-work should specify cne type and standard of personal protective equipment to be worn and all other necessary precautions to be taken. 77 Entry into a confined space without breaching apparatus should noc be authorised by a competent person unless (a} effective steps have been taken to prevent the entry of any vinyl chloride vapour or ocher dangerous fume and (b) any sludge or other deposit liable to give off vinyl chloride or ocner dangerous fumes has been removed and no ocher material liable to give off dangerous fumes is present and (e) Che space has been adequately ventilated, tested for vinyl chloride and ocher dangerous fumes and has a supply of air adequate for respiration. 21 CMA 007669 If there is a possibility that the proportion of oxygen in the air of a confined space has been substantially reduced no person should enter or remain in such a space unless he is either wearing suitable breaching apparatus. Alternatively the space should be adequately ventilated and a competent person should test and certify it as safe for entry without breaching apparatus. Maintenance operations 73 When a non-routine operation or malfunction may result in the release of vinyl chloride to the atmosphere, adequate and suitable breathing apparatus of a type approved by HSE should be worn. Wherever possible special measures should be taken to prevent emissions of vinyl chloride. Such operations 3hould not be conducted witnouc permission in Che form of a permlc-co-vork from a competent person designated by the employer for this purpose. Precautions should be taken to ensure that ocher personnel are not exposed to levels of vinyl chloride above the Control Limit. MAINTENANCE OF CONTROL MEASURES 79 All plant, especially that from which vinyl chloride may escape or which is provided for the purpose of controlling exposure to vinyl chloride, should be maintained to a high standard in order to limit the exposure of workers to vinyl chloride. Maintenance procedures should Include regular and thorough examinations by a competent person at appropriate intervals of ttiose parts of tne plant at wnich leakages of vinyl chloride may develop over a period of time. A suitable instrument giving a direct read-out of the concentration of vinyl chloride-in-air should be used for leak detection during such examinations. All defects found should be remedied promptly and the results of maintenance examinations and details of remedial action taken recorded. dQ Regular examinations and tests should be made of ventilation equipment and ocner technical control measures by a competent person, using instruments wnere appropriate, to check the performance of such equipment as part of a planned preventive maintenance programme. Where ventilation plant is provided in pursuance of Regulation 7 of the Concrol of Substances Hazardous to Health ZZ CMA 007670 Regulations, maintenance should include a visual cheek at lease once a week co identify obvious defects and a thorough examination and test by a competent person at least once a year. Details of such examinations and tests, defects found and remedial action taken should be recorded. EMERGENCY PLANNING 81 A procedure for dealing with a substantial escape of vinyl chloride should be prepared and updated as often as is necessary. The objective is co ensure chat all employees who may be affected are trained and practiced in the arrangements for dealing with such emergencies. The emergency plan should cover (a) the definition of the type of situation co be considered as an emergency; (b) raising the alarm; 1'. (c) evacuation of the immediate area and adjacent areas liable to be~ affected; (d) control of the occurrence using sice resources; (e) plant shut-down and containment o'f vinyl cnloride leakage, and (f) obtaining assistance from the emergency services. The booklet 'Recommended Procedures for dandling Major Emergencies', published by the Chemical Industries Association Ltd., Alembic House, 93 Albert Embankment, London SE1 7TU, provides useful information and advice on this subject. It should be noted cnac the Control of Industrial Major Accident Hazards Regulations 1984 will apply to some vinyl chloride installations and may require the preparation of on-site and off-sice emergency plans. 92 '^nenever abnormal emissions occur which affect the environment significantly, tne District Inspector of HM Industrial Air Pollution Inspectorate and the local authority must be informed immediately. Production should not be continued with emissions outside the limits allowed without 23 CMA 007^71 having conaulcad the District Inspector. Under the Notification of Accidenta and Dangerous Occurrences Regulations 1980 the sudden, uncontrolled release of l tonne or more of vinyl chloride, eg. by rupture of a bursting disc, must be notified to the HSR immediately. REGISTERED WORKERS 33 In plants subject to the requirements of the Vinyl Chloride ACoP, any worker identified during the assessment procedure required under Regulation 6 of the Control of Substances Hazardous to Health Regulations as likely to be affected by occupational exposure to vinyl chloride should be designated as a 'registered worker'. A register of such workers should be kept by the employer. Any worker generally spending less than 25E of his working year exposed to vinyl chloride need not be designated as a registered worker * Consideration should also be given to designating other persons working regularly on site, eg contractors' employees, as registered workers where there is the potential for exposure to vinyl chloride on a scale similar to that for an employer's own employees and the assessment warrants such actien. HEALTH SURVEILLANCE 3A Health surveillance of registered workers is Intended to detect, as early as possible, any harmful effects associated vich exposure to vinyl chloride at work. The initial assessment considers the individual's fitness to work with vinyl chloride and establishes baseline medical information with regard to registered workers. 33 Workers should be subject to periodic assessment to check their fitness to continue working with vinyl chloride. The assessment may also provide additional information which might lead to a fuller understanding or tne toxicological effaces of vinyl chloride. Such data could also be of value in any future epidemiological studies. Each person should be subject to medical reassessment (a) at intervals of noc mor-i chan 12 months; 24 CHA 007A72 (b) if he has reported symptoms which could be attributable to vinyl -- chloride exposure; (c) if, in the opinion of the appointed doctor, he requires further medical assessment; (d) when he has been absent from work because of any illness for 4 weeks or more. 86 The medical assessment of each individual is the responsibility of the appointed doctor but it will normally include (a) a full history, both clinieal and occupational; (b) a clinical assessment with particular reference to the abdomen, skin and extremities, and (c) such further tests. Including radiological examination and.' laboratory tests, as may be indicated by the results of (a) or (b). 87 The employer should ensure that the leaflet "Vinyl Chloride and You" is given to every worker on commencement of his employment. Copies can be obtained free of charge from any office of the Health and Safety Executive. 88 The employer should also ensure that each employee is aware chat he has the right to request a written record of the results of any health surveillance procedures. If abnormal findings are present the individual may, if he consents, be referred to his Family Practitioner. 39 Uhere medical examinations need to be carried out adequate facilities should be made available. The facilities snould comprise a room which is properly cleaned, adequately warmed, well ventilated, suitably furnished and provided with a wash basin equipped with hot and cold running water, soap and a clean towel. If it is not reasonably practicable to provide hoc and cold running water, a means of heating water should be provided within the room. Tne room should be suitably quiet and not permit drdinary conversational voices to be heard outside its walls. The room should be sec aside for the exclusive purpose of health surveillance whenever it is required. 25 CMA 1 0^3 J Where che number of employees co be examined or assessed is substantial, a suitable waiting area should be provided. An adjacent lavatory with hand washing facilities should be provided for employees who may be required to provide specimens for biological testing. 90 Arrangements should be made for any employee who is a registered worker to present himself, during his normal working hours, for medical examinations and any additional tests as may be necessary. . Employees should cooperate in such examinations and tests. 91 The basic occupational health record of a registered worker's health surveillance should consist of at least che following information surname, forenames, birth surname, sex, date of birth, place of birth, (town and country), permanent address, National Insurance Number, National Health Service Number, dace of commencement of present employment, and a historical record of jobs performed whilst in that employment, with appropriate details to indicate likely exposure. 92 These records may be kept in any suitable form provided that they satisfy the foregoing requirements and can be retrieved readily when required. They should be kept in a form compatible with and capable of being linked co cnose for monitoring, so chat it is possible to compare cne nature and degree of exposure co vinyl chloride wlh effects on'heaith. The health record of a registered worker should be kept for at lease 50 years from che date of che last entry. 93 Some of the conditions essociated with exposure to high levels of vinyl chloride, particularly angiosarcoma of the liver and portal hypertension due co non-cirrhotic periportal fibrosis, may have prolonged latent periods with symptoms not appearing until several years after exposure, possibly after a vinyl chloride worker has retired or transferred co ocner work. In all cases when a vinyl chloride worker leaves a company, ceases co be a registered worker or transfers to another location, a letter should be sent to his Family Practitioner ay che Appointed Doctor. Appendix 3 contains a suggested letter cor sending to an employee's Family Practitioner and Appendix 4 a suggested form for che employee co give his consent for che Appointed Doctor co discuss his medical and occupational history with regard to his exposura co vinyl 26 CHA 007674 chloride with hie Family Practitioner. Both the suggested letter and form of eonsTOt have been approved by the Ethical Guidance Committee of the General Medical Council. ~ Appointed Doctors are recommended to place copies of any letters and forms of consent in the occupational health records of the employees concerned. 94 When an employee ceases to be a registered worker, but continues to work at the same location and for the same employer, the Appointed Doctor shall offer to continue the employees health surveillance programme as in paras 85, 36 and 38. INFORMATION, INSTRUCTION AND TRAINING 95 Employers should ensure that employees receive adequate information, instruction and training, so chat they are aware of the nature of the hazard, the extent of the risks from exposure to vinyl chloride, the precautions to be observed to minimise these risks and Che role of joint consultation. _ Employers should also ensure that employees of contractors and ocher persons ' working in areas involving potential exposure to vinyl chloride have received similar information, instruction and training. The topics covered should include the following ta) health hazards of vinyl chloride; (b) concents of the vinyl chloride ACoP; (c) general methods outlined in this Guidance Note and the leaflet 'Vinyl Chloride and You' for protecting persons from the health hazards of vinyl chloride and the need for health surveillance; (d) correct operation of the plant with which the employee is concerned; 27 CMA 007675 () cola of che employee in observing safe wording methods; (f) correct use of respiratory protective equipment and any ocher personal protective equipment; (g) significance of monitoring procedures and results; . (h) relevant emergency procedures; (1) relevant rules relating to vinyl chloride; (j) procedures for reporting defects in plant and equipment. It should be noted that Regulation 4 of Che Control of Industrial Major Accident hazards Regulations 1984 requires a manufacturer to provide evidence chat persons working on a site are informed, trained and equipped as necessary to ensure their safety. 96 Basic information, instruction and training should be provided on recruitment and should be supplemented at regular intervals by training, "onthe-job" refresher courses, calks, notices, leaflets or ocher methods in order to create and sustain a high level of awareness amongst employees. 97 Any person who carries out any assessment, air aoaicoring or maintenance casks wtiich require che use of instruments should be given additional instruc tion and training concerning their use including;- (a) objectives of air monitoring; (b) correct use of che instruments; (c) sampling techniques; Cd) analysis, interpretation and recording of results. 28 CMA 007676 FACILITIES Washing and changing facilities 98 Adequate washing and changing facilities of a high standard should be provided. All the facilities should be kept clean, warn and in good repair. Washing facilities should include showers for tna use of persons whose skin guy be contaminated by vinyl chloride. Changing facilities should be designed to ensure chat clean clothing and chat which may be contaminated by vinyl chloride are kept separate. Arrangements for eating, drinking and smoking 99 Employees should not eat, drink or smoke in areas liable to be contaminated by vinyl chloride, so suitable facilities for these purposes should be made available. 100 Where a number of employees are involved, suitable facilities for use by pcrsoas who remain on the premises during main meal intervals should consist of a canteen, mess-room or ocher suitable eating area. This should be provided with suitable cables and chairs and facilities for the storage of food and drink, whether the food and drink is supplied by Che employers or the employees. If drinking fountains are provided they should be installed so as to prevent the water from becoming contaminated. 10L Smoking should not be permitted except in areas set aside for the purpose because of the fire and explosion risks aaaociaad with vinyl chloride. NOTIFICATION TO THE HSE 102 Employers are requested to notify HMF1 at HSE Area Offices and HMlAPI at District Offices of proposals for the installations of new plant or modification of existing plant. Such notifications should be made at the design stage. Vinyl chloride comes within the group of substances defined in Class 2 of Parc II of Schedule 1 of tne Notification of Installations Handling Hazardous Substances Regulations 1982. The Regulations require initial 29 CMrt 007677 notification co BSE of any site handling quantities of vinyl chloride in excess of 25 connes with renocificacion ac chree times this figure. Vinyl chloride also comes within the definition of a flammable gas as sec out in Schedule 1 e(i) of Che Control of Industrial Major Accident Hazards Regulations 1984. Notification to HSE is required under Regulation 4 at 50 tonnes of vinyl chloride and for Regulations 7-12 ac 200 tonnes for process and storage or 300 connes for isolated storage. Notification to BSE is also required of significant modifications to the industrial activity for inventories exceeding 200 or 300 connes for process and storage or isolated storage respectively. For further details, reference snould be made to the appropriate Regulations (see Appendix 6) and associated guidance published by BSE. RECORES 103 Thera are a number of references in various sections of this Guidance Note to the Reaping of registers and records. For ase of reference these requirements are summarised in Appendix 5. 104 Where an employer ceases to operate, it is recommended chat the Heaich and Safety Executive be notified and che records of air monitoring and employees' occupational heaich records transferred to BSE. Disc No 250/20-30 BH 30 CMA 007678 APPENDIX l PROPERTIES OF. VINYL-CHLORIDE SYNONYMS CHEMICAL FORMULA PROPERTIES General Physical Chemical Soiling Poinc Freezing Poinc Flesh Point (open cup) Liquid Density Vapour Density Solubility VC, Vinyl Chloride Monomer, VCM, Monochloroethylene, Monochloroechene CH2 - CHC1 Vinyl Chloride is a colourless gas at ambient temperature and pressure with a sweetish odour at high concentrations. It is normally scored and handled under pressure as a colourless liquid -13.9C -153.7C -78C 0.983 (at 2QC) 2.15 (relative to air at 20C) Readily soluble in most organic solvents but only sparingly in water Vinyl chloride will polymerise exothermically under the influence of light, air, oxygen and initiators such as benzoyl peroxide. Pure vinyl chloride is thermally stable to quite high temperatures, however, peroxides formed by slow reaction with oxygen in air may initiace polymerisation. Stablisers, such as benzoquinone or p-mechoxyphenol, and storage in an oxygen free atmosphere innlbic adventitious polymerisation CMft 007679 APPENDIX 3 Dear Doccor CONTROL OF SUBSTANCES HAZARDOUS TO HEALTH REGULATIONS 198APPROVED CODE OF PRACTICE FOR THE CONTROL OF VINYL CHLORIDE AT WORK Mr/Hrs/Miis .............................................................................. Dace of Birch ...................................................... Address .................................................... ......................................................................... . is abouc Co leave/has jusc lefc employment here where he/she was registered as a worker pocencially or actually exposed eo vinyl chloride monomer (VCM). Exposure co high levels of VCM has been associaced with angiosarcoma fibrosis of Che liver, portal hypertension due Co non-cirrhotic periportal/and acro-ostsolysis particularly of Che terminal phalanges of the hands. Other effects have been reporced as occurring in workers chronically exposed co vinyl chloride monomer ac similar levels of exposure, although such reporcs have been disputed by others. These include tumours of cne brain, lung, haemo-lymphopoiecic syscsa, and skin (malignant melanoma), lung function disorders, chrombocycopoenia and immune complex disorders. Effects on reproduction have also been reported. Whilst exposure Ce such levels is unlikely co have been Incurred since 1975, the latent period particularly for the first two above mentioned conditions may be prolonged. May I cnerefore suggest cnac this letter which (together with the patients form of consent) has been approved by the General Medical CMA 007680 Council, be filed in your patient's NHS record card. Should any clinical, suspicion* along these lines arise In the fucure you might like co consider concaccing me or ay successor. I hold, and enclose a copy o, your patient's 3igned informed consent to this which means that you need not hesitate from taking such a step early in your considerations of differential diagnosis from faar of groundlessly alarming your patient. Should this factory have ceased trading, the Employment Medical Adviser for your area, who can be fouad in the telephone book under Health and Safety Executive would know the whereabouts of your patient's factory medical and exposure records which are being preserved for 50 years from the end of his/her employment here. If you would like any further information or explanations, please do not hesitate to contact me now or in che fucure. I will be glad co assist In any way possible in che interests of your patient's, our exemployee's, well-being. Yours sincerely, APPOINTED DOCTOR CMA 007681 APPENDIX 4 CONTROL OF SUBSTANCES HAZARDOUS TO HEALTH REGULATIONS 198AFPROVED CODE OF PRACTICE FOR THE CONTROL OF VINYL CHLORIDE AT WORK MEDICAL SURVEILLANCE (Give surname and full forenames, give date of birth thus eg 3 SEPT 36 I, of . hereby give consent for the Appointed Doctor or the Area Employment Medical Adviser to discuss with my family doctor my medical and occupational history and I also consent to the release co my family doctor of such records insofar as they relate co my exposure to Vinyl Chloride Monomer. I confirm chat Dr .......................... ............ ......................... , Appointed Doctor has explained co me the reasons for this consent being sought and L believe chat I have understood these reasons. I agree to a copy-of this consent and explanatory letter, vnicn I have seen, being sent co my present family doctor, Dr .................................................................................... of .......................................................................................................................................... Signed 2ate . fitness CHft 007682 APPENDIX 5 RECORDS The records, which -should be kept la relation to the control of vinyl chloride at work are summarised below with cross references to the relevant paragraphs of the main text of the Guidance Note. (a) Assessment (paras 22-29); (b) Atmospheric monitoring (paras 35-57); (c) Maintenance of monitoring equlment (para 53j (d) Leakages of vinyl chloride (para 59(1); (e) Examinations of ventilation equipment (para 59(2)); (f) Excursions above the alarm levels during area monitoring (para 59(30; (g) Personal monitoring (para 59(4)); (h) Names of persons trained and aucnorised to use respiratory protective equipment (para 66); (i) Inspections of respiratory protective equipment (para 69); (j) Peraits-to-work (paras 71 and 77); (k) Maintenance of control measures (paras 79 and 30); (l) Register of registered workers' (para 33) (a) Occupational health records of registered"workers (paras 91 and 92). Records may be kept in any suitable forms, including microfilm, computer or similar techniques, provided cney can be reviewed reaaily when required. Occupational health records should be kept for 50 years after the last entry made in them.' Records of atmospheric monitoring should be kept for et least 30 years. All other records should be kept for a minimum of 2 years. 007683 CM* APPENDIX 6 LEGAL REQUIREMENTS Some additional legal requirements relevant to the handling of vinyl chloride may be found in Che following The Health and Safety at Work etc Act 1974 The Factories Act 1961 The Alkali etc Works Regulation Act 1906 The Emissions into the Atmosphere Regulations 1983 The Control of Pollution Act 1974 The Control of Substances Hazardous to Health Regulations 198 The Notification of Installations Handling Hazardous Substances Regulations 1932 The Control of Industrial Major Accident Hazards Regulations 1984 The Dangerous Substances (Conveyance by Road in Road Tankers and Tank Containers) Regulations 1981 The Dangerous Substances (Conveyance by Road in Packages etc.) Regulations 198The Classification, Packaging and Labelling of Dangerous Substances Regulations 1984 The Notification of Accidents and Dangerous Occurrences Regulations 1980 The Reporting of Accidents and Dangerous Incidents Regulations 198-- ChA 007684 AFFSTOIX 7 CHECKLIST ,CF MAIN CONTROL MEASURES CONTROL i-ZASUHES FCR MATERIALS, PLANT k PROCESSES (Paras 30-36) CCNTRCL 0? EXPOSURE (Paras 19-20) AIR MONITORING (Paras 37-62) ALARM LEVELS (Fara 21) PERMITS-TO-WORK (Paras 71-78) RESPIRATORY PRCTSCTTVE EQUIPMENT (Paras 63-69) MAINTENANCE CF CONTROL MEASURES (Faras 79-80) t, - Plant should be designed and operated to minimise exposure to vinyl chlorid - Plant should be sited in the open wherever possible - Good general ventilation should be provided In process buildings - Local exhaust ventilation should be provided where emissions from plant nay occur that cannot be eliminated by Improved design and maintenance - Personal exposure to vinyl chloride should be controlled to below 7 ppm 8 hour TWA - Vinyl chloride in the air of working areas should be controlled to below 3 ppm averaged over a year - Personal monitoring is required to check compliance with the 8 hour TWA Control Limit - A static monitoring system is required for the monitoring of vinyl chloride in the air of working areas - Air monitoring system required for the detection of high levels of vinyl chloz^^ and to sound an alarm at the following levels* 15 ppm measured over 1 hour '20 ppm measured over 20 minutes 30 ppm measured over 2 minutes - Fermits-to-work required for all work in confined spaces and some maintenance - All personnel involved must be properly trained - Required for certain operations, eg entry into confined spaces, maintenance, dealing with leaks of vinyl chloride, emergencies, etc - Only equipment of a type approved or to a standard approved by HSS to be used - To be used only by trained and authorise personnel - Regular and thorough examinations of plant required, especially where leaks may occur - Regular examinations and tests of ventialtion equipment required - Regular checks of other control measure to be carried out CHA 007685 EMERGENCY PLANNING (Faras 81^82) HEALTH SURVEILLANCE (Faxas 34-9*0 iii7CR;*jVTiorr, instruction (Faras 95-97) TRAINING - Suitable plana required to deal with foreseeable em rgencies - All enployees should be familiar with relevant emergency procedures - Registered workers should undergo regular medical examinations - All employees should receive adequate information, instruction and training on the hazards of vinyl chloride, the precautions to be observed and the role of joint consultation CMA 007686