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WAV ? 1979 VINYL CHLORIDE Proposed Standard Organization Resources Counselors, Inc. Study Analysis May 10, 1974 . FEDERAL REOISTER, VOL 3t, NO. *3--MIDAY, MAY IP, 1*74 pp. 16895-16900 t Background. Vinyl chloride fchlorotthcne) Chemical Abstracts Service Registry No. 75015, is a synthetic chemi cal wade by oxvchlorination of ethylene or by hydrcohlonnation of acetylene. It Is the parent compound of a senes of themoplastic resin polymers and co polymers which are widely used for con tainers, wrapping film, electrical insula tion, pipe, conduit, and a variety of other products. Vinyl chloride has been made ^Macrcially in this country since 1939 present production is in excess of seven billion pounds ner year. Vinyl chloride (VO is a gas at am bient temperature and pressure and is a chlorinated hydrocarbon which has moderate liver toxicity. The previous standard set a celling value of 500 cam I t*r million (ppm) t29 CFH 1910.93. Table | n-n. On January 23,1974. the Occupational Safety and Health Administration (OSHA) was Informed by the National Institute for Occupational Safety end Health (NIOSH) that the B. P. Good rich Chemical Company reported that deaths of several of its employees from A rare liver cancer (angiosarcoma) mar hwvc horn occimationally telatcd. As a result of this notification and alter con sultation with the National Institute for Occupational Safety and Health (NIOSH), and a Joint Inspection of the plant by OSHA, NIOSH. and the Ken tucky Department of Labor, a fact-find ing hearing on possible hazards involved with the manufacture and me of VC j was announced on January 30, 1974~7OT ra 3874) and held on February 15. ISJjT. I "Documentation of the Threshold Limit Values" ACGIH-Thira Edition 1971, page 277- "Vinyl Chloride 200 ppm". "Vinyl Chloride is a flam mable gas with anesthetic properties at high concentrations..." "A subsequent report by Lester, Greenberg and Adar on the effect of repeated exposure of rats to vinyl chloride assaying 99+ percent purity at 2 and 5% concentration stated that, although liver changes were noted, they were not considered to be of pathological significance. In their opinioi a recommended TLV of 500 ppm was satisfactory for worker exposure" NIOSH held "briefing" -February 12, 1974 Cleveland Airport-Sheraton; Dr. Marc Key stated .. "tending to implicate Vinyl Chloride"... "we will next loo) into the production of Vinyl Chloride and the use of polyvinyl in manufacture - forming, shaping extruding" OLI 1019 b. Tarcinonerticitv / VC. Information proodduucceed r.t this hearing demonstrated that exposure of laboratory animals mostly Sprague-Dawley rats) to VC by Inhalation at and below the then current The then current OSHA Standard was based on th PS1IA standard of 500 nam induced timers, including angiosarcomas of the ACGIH TLV which was a Walsh-Healey Standard h nee liver. Professor Cesare Maltoni, of the Instituto di Or.cologia. Bologna, Italy, reported on a scries of experiments on a Federal Standard available for Section 6(1) pro mulgation - Note word "standard" the effect of exposure of rats, mice, and hamsten to VC at concentrations of 10,000; 6,000; 2,500; 500; 250; and 50 ppm for varying periods of time tTR- 43-C3). Some of the experiments have been concluded, and others are still on going. The experimental results reported were that tumors have been observed in groups of animals exposed to VC at con centrations as low as 250 asm. Ka tumwf wacerree offbwseyrvreodi in the rrono cf annimaoli:s MMWCfl *9 ySL '.t a concent; lM. ppm. It also appears that the total num ber of tumors, as well as the numbers of angiosarcomas of the liver, decreased Therefore the incident of tumors will approach 0 as the concentrations of VC were reduced ^Jas exposure approaches 0, and 0 * 0 to 250 ppm. Another experiment by Pro fessor Maltoni was reported underway Involving the exposure of 300 animals to VC at concentrations of 50 ppm. Jq, Note particularly "tumors in animals" order to assess in a more definitive wav whether that level nr exposure produces tumors in animals. Data reported by Torkelson, Oycn and Rowe (American strial Hygiene Association J 22: 254- *C19CZ>) Indicate that exposure to" l-This is the justification for a 50ppm limit t concentrations of 50 ppm failed to :e tumors in rats, hamsters, rabbits, and dogs. The employees of the B. F. Goodrich Chemical Company who died from angio sarcoma of the liver had an average ex posure of approximately 19 years to vinyl chloride. *t unknown concentrations and variable exposures to otner volatile rhPTnicais. tTR 93). Some employees Of Union Carbide, Firestone Tire and Rub ber. and Goodyear were also reported in post-hearing comments to have had ex posure to vinyl chloride and to have died from angiosarcoma of the liver. Finally, autopsies of four deceased employees re vealed their liver angiosarcoma tumors were histologically indistinguishable from the angiosarcoma tumors observed In Professor Maltoni's experimental animals. In this kind of situation X is not the relevant measu of central tendency, and N is so small as to render any such measure suspect. R would be all I would consider. IMPORTANT! Cause and effect? Synergism/antagonism OLI 1020 .S * 3. The Emergency Temporary Standsrd. On the basis of all information available at that time, and the fact that employees were bears exposed at levels around the experimentally observed el* feet level of 250 ppm. en Emergency Temporary Standard <ETS> was promul gated on April 5, 1974 (39 FR 12343) ^_ 29 CFR 1910.93(1. This standard reduced Vinyl Chloride Standard Ceiling? standard? TLV? the level from a cclllni: of 500 ppm to 50 nnm ceiling it was expressly rccosmaca that this standard limiting exposures to a 60 ppm level was intended to be a ten tative, interim standard, to be in effect no longer than six months, during which time the whole question of possible safe exposure to VC would be reconsidered more fully and in tire light of more in formation. especially results of experi ments wliich were known to be under way at that time. 4. Additional information. On April 15, 1974. information and data were pre The first paragraph is factual and verifiable; but tl sented to representatives of OSHA. NIOSH and the EPA by the Industrial Bio-Test Laboratories. Northbrook. IU1- second paragraph is conclusion, and then conclusion on conclusion, and suspect. n^^conccrmng results of animal ex- studies with VC. sponsored by the J.ramfacturir.2 Chemists Association (MCA). nature, Although only preliminary these results revealed that 2 :n_ out "| Incidence of angiosarcoma in this strain of mice of 200 mice exposed to VC concentrations of 50 ppm for 7 hours a day, five days a without vinyl chloride exposure? week, for approximately 7 months, de Concentration in experiment not found in work exposu; veloped angiosarcomas of the liver. The Industrial Bio-Test Lab data -- in = How does this compare with the working life span of dicate that exposure to VC at 50 ppm a worker? mav well constitute a serious health hazT gl_fq_i2miQiis,,Also, the Question of a conclusion 1 safe level of exposure lor humans can not be determined at this time, and may Conclusion 2 continue as a matter for scientific de- liberation for many yearj\Ve therefore conclude that it is now necessary to pro -Conclusion 3 pose to change the 50 ppm level estab lished in the ETS to as low a level as can be detected using methodologies outlined In this proposal. (5) The proposed permanent startdard. The requirements for a complete stand ard under section C(b) of the Occupa tional Safety and Health Act of 1970 are much more comprehensive than the provisions of the ETS promulgated on S. The following proposals are reto the additional information onBic carcinogenicity of VC, and the requirements of the Act. oli 1021  A. Level o/ exposure. The proposed standard for employee exposure is set at no detectable level, as determined by a sampling and analytical method capable of detecting vinyl chloride at concentra tions of l ppm with an accuracy of 1 ppm--50 percent. Although more sensi tive methods may be available now cr in the future, the methodological sensitivity proposed appears to be the most f.v^-hu and generally available^ ppm sensitivity has been recommended to OSHA by XIOSH. To minimice the number of persons at risk, a require- repackaged, or used, jer ttec~ tia,mne lre.v:e'lrs o;v';in1y1 l;vc7h{l'ocricd`f>er.i*A1Trrr-`mn~- o ine areas would be limited Lo author-ced employees. B. Monitoring. A program of monitoric wgjjld be required to establish hether there are detectable levels in .'Eulatcd areas and to permit determina- Bf employee exposures on an inlal basis. Provision would also be iade lor an opportunity to observe innltorinc by employees or their desigvted representatives, as required by secion 8(CM3> f the Act. - .5 to 1.5 ppm the controlling fact is the presence of vinyl would the use of the word "would" is puzzling and likely not carefully chosen for any particular significance. q Control methods. Where detectable levels of VC are monitored, two pro- crams would be triggered; an cr.aincer- t-r work practice program to reemee levels below oetectabiluy; and while this Is on-going, a respiratory protection pro- cram for employees in the regulated area. * wnglneerinc controls and work ^rrc- Hresnre favored methods of compliance f&ause they tend to avoid conte.nnna- liftii ol the ambient air in the workplace. Accordingly, it is proposed to require the Institution of engineering controls and f workpractice methods as soon as feasi- i.e. engineer as far as you can (e.g. 49 ppm) and to reouire tl-.e me m respirators pending the institution Of rontrols. supplement beyond. Could this principle, by to supplement such controls where they repetition become accepted practice? Wfc'insulfTFTein to rcr.uce rnnrentrat:oiis_ i >t vinyl chloride below the detectable cvel. Tn~sr>ccificfl work situations and_ In cases Of emergency. The proposal tor Continuous flow and pressure demand H*pes of respirators is based'on the rec ommendations of KIOSH. ',vh;-h has ob-_ served leakage through cncmical car tridge respirators at high concentrations Of VC. and OLI 1022 * A requirement would also be estab lished for the provision and use of pro tective clothing for employees in the reg ulated areas. The protective clothing would minimize skin contact with VC vapor, and would provide some measure of protection from splash of liquid in the event of a spill or rupture of equip- I ment. Food, beverages, and like products I Maybe OK - could change eatin' on the fly featur would be prohibited in the regudlated area. |" of work schedules; already probably required Written operational and emergency plans would be required, along with em ployee training in routine and emergency duties. Specific requirements would be established for emergency actions and for routine maintenance and decontami nation operations, including vessel entry, by general Sanitation Standard which are known to present particular hazards. The purposes of operational and emer gency plans and training are to apprise :mployees of the hazards to which they nay be exposed, of the precautions they nust take to avoid such hazards, and to ehearse employees in the procedures hey must follow in emergencies. D. Medical surveillance. Comprehen sive requirements for employee medical examinations are proposed, including necessary tests. Some additional guid ance Is included for tne convenience of vsiclans. The proposed requirements gvc been recommended to OSHA by NIOSH as reasonably appropriate to de tect liver dysfunction which may be in dicative of. or predisposing to. the de velopment of liver angiosarcomas. OK standing alone, but roust be considered in light of all other requirements E. Records and reports. Records of nonitoring, medical examinations, and ntry to regulated areas are proposed, rith provision for access by appropriate 3SHA and NIOSH officials. Specific proisions for employee access to monitoring ecords are included. ^ well as the relulrement to furnish a copy oi a medical 3vrm-rt in an employee's physician on the f-mnlovrr's rcnue<t Establn'l.ments coiv- ducting VC operations would be required to identify themselves to OSHA, a.nd to report incidents (accidents) resulting in till release of vinyl chloride. Recall proposal for Asbestos Standard would have denied employer access to medical record OU 1023 6 rtCEordingly, pursuant to sections 6(b). Vc. and 8(0 ot the Occupational Safety and Health Act of 19"0 (84 Stat. 1993.1596.1599; 29 U.S.C. 655. 657). Sec retary of Labor's Order No. 12-71 (36 FR 8754) and 29 CFR Part 1911, It is hereoy. proposed to amend 29 CFR Part 1910 by revising * 1910.63b as set forth below. Written data, views, and arguments concerning the proposals may be mailed to .the Docket Officer. Docket OSH-36, Room 230. 1726 M Street. N.W., Occupa tional Safety and Health Administra tion, Washington. D.C. 20210. post marked not later than June 10. 1974. Pursuant to 29 CFll 1911.11 (b> and fc>, interested persons may file objec tions to the tuoposnls. rccv.es;;nc anTTPiflfr.ial hearing with respect thcrekilTn accordance with the following condi tions: (1) The objections must include, the name and address of the objector; 12) The objections must be post marked on or before June 10.1974 : (3 The objections must specify the provisions of the proposed rule to which objection is taken, and must state the grounds therefor; (4> E5ch objection must be separately stated and numbered; and (5) The objections must be accom panied by a summary of the evidence proposed to be adduced at the requested 1,1....NOTE, deadline: one month from publication flat* ' hearing may be requested. Seer#bify has not set up a Standards Advisory committee. As revised, f 1910.93q would read as follows; 1910-93(1 Viiijl Chloride. fa> Scope find application. (1) This* section applies to any ?r.ea or operation in which vinyl chloride (chloroethene). Chemical Abstracts Sen-ice Registry No. Vinyl Chloride wherever found 75015, is manufactured, reacted, re leased, repackaged, stored, or used, in cluding areas and operations involving polyvinyl chloride where detectable levels of vinvl chloride are released, _ (2) This section does not apyjytoTjjg* handling or use of fabricated products mane entirely or in part of polyvinyl chloride. But the point at which such fabrication exists is unclear. When has a "fabricated product" been (b) Definitions. (1) "Assistant Secre tary" means the Assistant Secretary of born? Labor for Occupational Safety and Health. U.S. Department of Labor or his designee. (2> "Authorized employee" means an employee whose duties require him to be in the regulated area and who has been This opens loopholes; what about employees of con- tnfvvfiraliv assigned bv the employer: tractor, supplier or service company? and area any as employee who enters such a designated representative an of -- What is the status of a full-time union official, an employees to exercise an opportunity to who is his employer? Do local and international unio observe monitoring vinyl chloride.." and measuring of \ assume an employer obligation and liability? "Closed container" means any ^.ainer which prevents the .release of 'opportunity, responsibilities, mandate? ^wyl chloride to the environment. (4 "Contaminated" means cY'lhl* of relating a detectable level of vinyl -- Could we be back to fabricated products? chloride. OLI 1024 7 (5) "Decontamination" means reduc.ion of vinyl chloride concentrations to less than detectable levels. <6> "Detectable level" means an air borne concentration of vinyl chloride neasurable by a sampling and analytical nethod capable of measuring concentra tions of 1 ppm, with an accuracy of 1 >pm50 percent. (7) "Director" means the Director, Naional Institute for Occupational Safety md Health, or any person directed by lim r the Secretary of Health. Educa-. ion. and Welfare to act for the Director. fg) "Emergency" means an unforseen ircumstance or set of circumstances, reulting in the release of vinyl chloride nto areas occupied by employees. (9) "Exposure" means actual contact vith vinyl chloride when unprotected by equired personal protective equipment .nd clothing. (10) "Fabricated product" means a inished product or part of such product, aaclc of polyvinyl chloride, entirely or in <art, including scmninished products ucli as film, sheet, block, bar, or extruion stock. . (11) "OSHA Area Director" means the )irector for the Occupational Safety and lealth Administration Area Office hav oc jurisdiction over the geographic area i ]^feh the establishment is located. (^"Polyvinyl chloride" means polyinyr chloride homopelymer or copolmcr before such is converted to a fabicated product. .5 - 1.5 ppm V. JS* X Even at undetectable levels! Therefore excluded? (13) "Protective clothing" means lothlng protective against vinyl chloide. (14) "Vinyl chloride" means vinyl ihloride monomer, (15) "Waste resin" means any resin rr other reaction products removed in he cleaning of equipment, such as vesels and piping, (C> Reference. College of American atholoeists. 230 N. Michigan Ave., Chi-ago. Illinois 60601, (4) Regulated areas. (1) A regulated rca shall be established where (1) vinyl hloride is manufactured, reacted, re eased, repackaged, stored, or used: or ii) polyvinyl chloride capable of re fusing detectable levels of vinvj chloide is manufactured, reacted, released, epackaged, stored, or used. f2) Access to regulated areas shall be imited to authorized employees. (3) a daily roster of employees enterng regulated areas shall be made and naintained. The rosters, or summaries V, shall be kept for at least 20 Where does this fit? Note junibled numbering vinyl Chloride as such Polyvinyl Chloride capable of releasing vinyl chlori OLI 1025 What about union officers, government officials unknown? If I owned the company or purchased an ongoing compa I would want this kept forever and ver, Amen. Would it be nice to italicize these specicially defined words? See ANSI .1) ' Engineering controls end r.:ork- sacticc methods. (1) Where detectable levels of vinvl chloride are measured, immediate protection snail be provided against exposure to vinyl chloride by the yst of engineering controls, workpractice methods, and respirators as follows: ' <n Feasible engineering controls and vrorkprnctlre methods shall immediately be used to reduce airborne concentra tions of vinyl chloride bclotv the detect- . able level; (ID Wherever feasible engineering controls and _ work-practice methods wliich can be instituted immediately ere not sufficient to reduce concentrations of vinyl chloride below the detectable level. ev shall nonetheless be used to reduce e concentrations to the lowest prac ticable level, and shall be supplemented by means of respirators in accordance with paragraph (g) of this section; (111) Wherever no feasible en.-ineerlne control or workpractice mother! can be instituted immediately, immediate res piratory protection shall be provided in accordance with paragraph <g) of tills section; and (iv) In any case covered by paragraph (f)(1) (ii) or tiii) of this section, the employer thall also undertake as -con as practicable a nrorram to reduce airborne mlmuous .aJLyiityl d.ionoe neiow Idotfctfiblc level, or to the rrcat-'St nT fenMoIe. solely bv means of cnct-~ fleering controls and workpractice meth od and as soon as icasible. "Detectable levels" requires action Note frequent use of "feasible" Engineer as far as feasible supplemented If no immediately instituted engineering or workpractice method is available then respiratory protection (2) There shall be tests made for process or equipment leaks and for emis sion of vinyl chloride which nay resuit from workpractices. The frequency of these tests shall be such as to insure the integrity of equipment and adherence to proper workpractices. tg) Respiratory protection. (1) A res piratory protection program in accord ance with {1910 134 shall be established and implemented where respirators are required to be used by tins section. i2) Respirators shall be used only in cases of emergency ami where renuired by any other provision of this section. Rc-vurotors may not be used in lieu of feasible cneineciir.p controls or workpractict metnods. Subpart I, Respiratory Protection, pg 22231, Fed. Reg. 10/18/72 "ANSI Z88.2 1969, Standard Practice for Respiratory Protection" This could lead to arguments, the counterpart of (iv) above -- "solely by means of engineering controls and workplace methods" OLI 1027 3) Respirators or combinations of respirators tor protection against vinyl chloride shall be selected from among tire lollowing: <1) A positive pressure lull facepiece self-contained breathing apparatus: '<ii) A pressure-demand full facepiece self-contained breathing apparatus op erating in the pressure-demand mode; (iii) A combination type "C" pressuredemand full facepiece respirator oper ating in tire pressure-demand mode and a pressure-demand self-contained breathing apparatus 'operating in the pressure-demand mode; or Uv) A combination type "C" continu ous flow respirator and a pressuredemand self-contained breathing ap paratus operating in the pressure-de mand mode. h) Protective clothing. <1) Employees _ entering regulated areas shall tie PIjvided full-body protective clothing, foot- . wear or shoe covers, and gloves, at no cost to them, and required to wear gpwhile in the regulated area. 2) Where polyvinyl chloride powder ining detectable levels of vmyl idc is handled, employees shall >c: U) provided and required to wear headcoverings: ----------------- ------------- US) Required to remove all protective clothing at each exit lrom the regulated area: and (iii) Required to shower after the last exit of the day. Note restriction to employees What is this? .or them? Also? certainly means: such employees also; not: in addition: or to (b)(1) What kind? "day" must mean workshift (3) Clean protective clothing shall be rovided whenever contaminated or oiled, but not less frequently than ccekly. Contaminated clothing shall be .econtaminatcd before reuse by removal or laundering or disposal. ___ <i) Hygiene facilities and practices. 1) Where employees are required by his section to wear protective clothing aid equipment, change rooms shall jc provided in accordance with : 1910.141(e). 4 (2) Where employees are required by .his section to shower, shower facilities .hall be provided in accordance wiuy 5 1910.l4UdH3). k Storage or consumption of fooi ^Beverages, storage or use of. smoking jffion-lood chewing products, and the storage or application of cosmetics are prohibited in regulated areas. _ Clarity 1910.141 is general santitation standard Requirement of sanitation standard OLI 1028 u <j) Emergency situations. <i> a written operational plan for enicrjtcnai situations shall be developed for each, regulated area <2) in the event of an emergency. ap propriate portions of the plan shall be put Into operation. (i) Hazardous conditions created by tiie emergency shall be eliminated anti the affected area shall be decontami nated prior to the resumption of normal operations. <ii) Special medical surveillance by * physician shall be instituted within 24hours for employees present in the af fected area at the time of the emergency^ till) Where an emt' contact with liquid \ employee shall be req soon-as possible.- unit by physical imuriesT - <iv> An incident report on the emer gency shall be reported as required in paragraph <q><2> of this section. Note the number of written requirements leaning what? Each authorized employee shall T^p-amedin a program relating to the hazards of vinyl chloride and the pre cautions for safe use. *i) The pregram shall include: <A) The nature of the fire hazard, and the necessary protective steps; (B) The nature of the toxic hazard, including local and systemic effects, acute and chronic effects including specifically the carcinogenic hazard: <C> The specific nature of operations which could result in exposure to vinyl chloride, and necessary protective steps: <D> The purpose for and aopheation of the medical surveillance program: <; Tne purpose for and application of decontamination practices: <F) The purpose for and significance of emergency practices and procedures: (G) Tire employee's specific rcle under normal operating or emergency condi tions: <H> Specific information to' aid the employee in recognition and evaluation of conditions and situations which may result in the release of vinyl chloride; fl) The purpose for and application of specific first aid procedures and prac tices; (J) A review of this standard at the employee's first training and indoctri nation program and annually thereafter. *ii) All materials relating to the pro gram shall be provided upon rep nest to ^^rorl2ed representatives of the Assist- ^R^ecretary and the Director. 4--This is not same as 'persons entitled to the opportunity." Could argue property, but not worth it. OLI 1029 t) Signs ana taocts, n Entrances 10 regulated areas shall be posted with signs bearing the legend: cancer-susrrcr agent area AUTHORIZED PERSONNEL ONLY (2) Areas containing operations cov ered In paragraph Oc> (l) t4> of this sec tion shall be posted with signs bearing tho legend: CANCER-SUSPECT AGENT IN THIS AREA PULL IMPERVIOUS AIR-SUPPLIED EQUIP MENT REQUIRED AUTHORIZED PERSONNEL ONLY 3> Containers of waste or other ma terials contaminated with vinyl chloride shall be labeled: ' vtNYL CHLORIDE CONTAMINATED MATERIAL cancer-suspect acent mVOSE OP OR DECONTAMINATE USING ^ AUTHORIZED PRICEDURES (4)* Containers of polyvinyl chloride containing detectable levels of vinyl chloride shall be labeled: POLYVINYL CHLORIDE CONTAINS VINYL CHLORIDE VINYL CHLORIDE IS A CANCFR-SUSPECT AGENT absorbed by breathing and . THROUGH skin Containers of vinyl chloride shall be labeled: VINYL CHLORIDE DANGER EXTREMELY FLAMMABLE OAS UNDER PRESSURE MAY rOLYMERU'-E WITH EXPLOSIVE FORCE POISON CANCER SUSPECT ACF.NT AND anesthetic ABSORBED BY BREATHING AND THROUGH SKIN Why all the different signs & labels? (6) No statement shall appear on or near any required sign, label or instruc tion, which contradicts or detracts from the effect of any required warning, in formation or instruction. (1) Maintenance and decontamina tion. (1) Emphasis shall be placed upon immediate clean up of spills, periodic in spection, prompt repair of equipment and leaks, and proper handling, storage and disposal or decontamination of materials to prevent airborne contamination ana accidental skin contact with vinyl chlo ride. Waste materials, equipment, and other sources of vinyl chloride in closed containers, may not be placed in areas of excessive temperature or sunlight since ^HUd-up of internal pressure may result ^rupture of the container, fire or explosion. > OLI 1030 } Waste resins or other materials aminatcd with vinyl chiorirte shall be placed in closed containers pending dis posal or decontamination. (3) Appropriate procedures shall be developed and implemented lor the de contamination or disposal of all such waste material. (4) In maintenance or repair opera tions on contaminated--systems or equipment, _including vessel entry, cmployecs engaged in such operations shall be (i) provided with and required to wear and use a whole-body air-supplied suit impervious to vinyl chloride, and a respirator in accordance witn paragraph <K> of this section; and (ii> required to ah wer after removing protective equip ment. (5) Protective clothing and equipment ahall be clean and dry for cacli use. <6) When vessels or piping systems are opened local exhaust ventilation shall be provided to remove the escaping vapor from all occupied areas. <7) Cl) Vessels to be entered shall first be ventilated and monitored so tnat the concentration of vinyl chloride is reduced to a level within the protection factor capability of the protective equipment. Vessel entry Vessel entry (ID When vessels are to be entered, all piping to such vessel shall be: (A) Opened, b'.anltcd and tapped; or (B) Whero welded piping is in Use. not less than 2 valves in series, which isolate the vessel from any other connection to such line, must be closed and secured. Ciii) No employee shall enter a vesselT except when another employee properly trained and equipped for entry is pres ent and is observing the employee in the vessel. The observer shall have means for signalling for help in the event the employee experiences problems. Under such conditions, the observer shall sig nal for help, and shall not enter to assist the employee until another person is cre-cj.t to observe. _____ Standard on entering closed vessels & confined spaces should be followed <m) Transportntion loading and unading. (1) Facilities for the loading id unloading of vinyl chloride to and om containers shall nave each transfer ic and vapor-equalizing line equipped ith vent connections, and shall have i inert gas purging system. Vent and urge effluent shall be returned to a procs stream or flared in a safe location. ^^Troccdiircs shall be developed and !^phented for the transfer of vinyl iloride. Written..copies cf such rrocelrcs shall be provided employees cnujed in such operations, end such oni- oyees shall be fully trained and rcrarsed in all procedures. ."Written" <3) Employees encaged In transfer opci^bns. shall be provided with and rt^B^d to wear respirators in aecordan^Mvith paragraph ig> oi this section. fn> Polymer handling operations. (1) Containers of nolvvinvl chloride releas,ng detectable levels of vinvl cmontTF shail be opened and transferred only under local exhaust ventilation which reduces the concentration of vinyl chlo ride below the detectable level. (2) Hot operations, such as but not lmitcd to milling, calendering and ex.ruding, which release detectable levels jf vinvl chloride, shall be carried on only inacr local exhaust ventilation which educes the concentration of vinyl chloide below the detectable level. (0) Medical surveillance. Not later han ............ 1974. a program if medical surveillance shall be lr.stiuted, and shall provide each authorized mployee with an opportunity ior ex~mir.a'.ions in accordance with this para-~ rapn. All medical examinations and rocedures shall be performed by or x.dcr the supervision of a licensed doctor of Medicine (MD) or Doctor of Osteopathy <DO). All medical examir.aions and tests shall be provided without ost to the employee. (1) At the time of initial employment, r upon institution of screening, a physial examination shall be performed with pccific attention to detecting enlargelent of liver or spleen by abdominal ^^^ion. // Polyvinyl chloride releasing vinylchloride Department of Labor should face issue, a medical surveillance program at employee option seems to be illusory. At time of initial employment "examination shall be performed" (2) At the time of Initial employment or upon institution of screening, and an- u ,thfrc""er- medical history hecklist shall be completed by the em ployee. This list shall Include Questions oncerning: <i> Alcohol intake: til) Past history of hepatitis: tili) Past exposure to potential hepaotoxic agents, including drugs and hcmicals; <iv) Past history of blood transfuions: and (v) Past history of hospitalizations__ (3) At the time of initial employment, r upon institution of screening, a scrum PCCimen shall be obtained for screening ith respect to the following bio-chemial determinations of liver function: <i) Total bilirubin; 411) Alkaline phosphatase: (Jii) Serum glutamic oxalacctic transminase <SGOT>; tiv) Serum glutamic pyruvic transminase (SGPT); and (v) Gamma glustamyl transpeptlda; jGTP) , f4i Additional tests that may optioi considered for use in screenir in Lactic dehydrogenase; Uii Scrum protein determinations: IQtin) Scrum protein electrophoresi: tivi Platelet count. Some of this "shall be completed" is not consistent with "opportunity" A man who wants a job may not be totally honest with you. OLI 1032 ju^borf.tory analyses for all blologl- rspecimens included in medical exam inations shall be performed In labora tories accredited by the College of --Just who ar these? American Pathologists or licensed under 43 CFR Part 74. <C) If the results of screening required In paragraph 'o)<3> of this section are Jiormal. n-Mniny ha11 he ------ . .Shall be? U) Every six months for employees who have been employed in vinyl chlo ride related operations for 10 years or store; and til) Annually for all other employees entering regulated areas. (7) If one or more liver function tests ,A salesman with a customer? Bow about the customer? performed are abnormal, serum testing shall be repeated as soon as possible, Contractor's employee? ** preferably within two to four weeks. If Service employee? no abnormalities are present upon re- screening. scrum testing shall be re peated in three months. (81 If abnormalities persist upon re screening, the employee shall be with Transfer, seniority, earnings, maintenanc and drawn from areas where-contact" v. itlt vinyl chloride is possible, and an individ other employee relations questions are involved, ualized medical workshop shall he in- 'A<fi ""iWorkshop" must be typo for "workup". stitntotT. Suggested as initial steps are a complete physical examination and vari ous special procedures such as hepatitis l-----W hat does this mean? B antigen determination and liver scan ning. If liver function abnormalities are determined to be unrelated to liver dis ease. the employee may be permitted to return to vinyl chloride-related crnploy- t. subject to individual medical uatlon. ) A complete and accurate record of the results of medical examinations snail --Why the shift? Monitoring is for flat 20 years. Note requirement to forward to NIOSH be made and maintained for the filia tion of employment plus five years, or at end of retention is not specified. for 20 years, whichever is longer. __ Such requirement has appeared in NIOSH <p) Records. <1) Records of monitor ing and measuring, medical records, and Criteria Documents; regulated area entry rosters and sum maries. shall bo made available for ex However note amination and copying upon request to authorized representatives cf the Assist ant Secretary and the Director. (2) In the event that the employer ceases to do business and there Is no sue- f cessor to receive and retain his iccords \ lor the prescribed period, these records shall be transmitted by registered mail to the Director, and each emninvcc indi vidually notified In writing of this transfer. <31 Employees and their designated representatives shall be provided access to examine and ropy records of monitor ing and measuring. (4) Former employees shall be pro vided acccs to examine and copy records reflecting their own exposures. ^45) Upon written request of any em^Hrcc, a copy of the medical record of ^Wh employee shall be furmshed to a physician designated by the employee in such request. -Former employees? OLI 1033 . (q) Rrports. (l) Not later than_____ > ______the following information shall be reported to the OSHA Area Director. Any chance in such information shall be reported to the OSHA Area Director within 15 days of such change. (t) The address and location of each establishment which has one or more regulated areas; and (U) The number of employees in each regulated area during normal operations, including maintenance. (2) Incidents which result in the re lease of vinyl chloride into any area where employees may be exposed shall be reported in accordance with this para graph. (1) A report of the occurrence of the incident and the facts obtainable at that time including a report on any medical treatment of affected employees shall be made within 24 hours to the CEIL*. Area Director. (ii) A written report shall be filed with the OSHA Area Director within 15 calendar days thereafter and shall in clude: (A) A specification of the amount material released; __ j^^p) A description of the area involved wWl the extent of known and nmentifii employee exposure and area afleeted; <C> A report on any medical treat ment of allccted employees and any medical surveillance program imple mented; and CD) An analysis of the circumstances of the incident, and measures taken or to be taken, with specific completion dates, to avoid further similar releases. <3) Upon completion of ar.y monitoring and measuring which discloses that any employee has actually been exposed to detectable levels of vinyl chloride, each *tich employee shall be individually noti fied in writing. The notice shall: (!) Be delivered not later than 10 working days after completion of the monitoring and measuring; (11) Stale the actual exposure in terms of concentration and time: and (lil) State the steps which .have been taken, are being taken, and will be taken, with specific completion dates, to termi nate the exposure and prevent a recur rence. anployees including maintenance, or operations including maintenance? ,,[may have been exposed] j.--How can yyou always be this accurate? exposed affected must be synonomous OLI 1034