Document vmqV841oYDZeJN0ymq834xQq

i-ia. * ti inert NOVEMBER 5* 1974 f. P. HOY COMMENTS CIT GdHA VCK STANDARD AT 7/u3A Oki^AlTJ, 63C. 31 - HOY. 1, 1974 This report covcr3 the comments of the second day of the above meeting, the subject being the permanent VCM standard. It will be given only limited circulation since it contains interpretations and conjectures which may not be valid and could cause much confusion and argument over the standard. Another report will cover the first day '.hen general safety considerations were discussed and will receive normal circulation. John 3arr of Air ixoducts interpreted the standard point by point as he understood it and in the light of the clarifica tions gotten from QoHA by .Air Products lawyers, *hile I have respected and admired John Barr's capabilities, I felt he took a pessimistic attitude toward the standard, leaning toward the nose difficult interpretation of each point. He seemed defeated and petulant. The result, if his advice is taken, -will be much use `>_i. goo masks, much reporting, protective clothing throughout cue ;Lanes, 'many hours of training, more of each of these and vther practices then we expected to do. GHA will expect to find in all plants as much' activity as they find in a few. After seeing the combination of very tight interpretation by some and general confusion among some others, both Bill Madden and 1 refrained from asking a lot of questions feeling we would not get additional light. This attitude was apparently shared by a few other people. For example I questioned John Ploros of Great American who didn't 3eem caught up in the pessimism and got the answer that he was going to make his own interpretation, look after protecting his employees as best he could and let oho compliance officers tell him if they *vere unhappy. I don't feel the meeting was a vasts of time, however. We did got a good look at what seme of the companies are doing and planning. A tabulation of comments as given follows. Interpretation of ObHA Permanent VCM Standard John Barr - Air Products (Many comments with which we are in agreement are omitted) 1. Expects individual directives as they are given to be more stringent than the standard as written. OCC 2893 ^aid all companies have consolidated their suits with Jil in the second court in Hew York; that oral arguments are to be given in December, 1974. 3- Air Products will not be in compliance by January, 1975-- too much to do. A. 4aid all provisions cover everyone who comes into plant truckers, telephone repairmen, canteen servicemen, etc. Pelt PVC makers would wind up negotiating with contractors, suppliers, telephone company, etc., on handling medical programs, records, reporting on their employees, felt these type people would be reluctant to deal with F\TO manufacturer 5. felt vs would find shipment of small lots by common carriers a problem. 6. All but one company (a monomer manufacturer) expect to do area monitoring for alarms plus personnel monitoring. 7. ?elt a fence around regulated areas was not necessary unless entrance could not be controlled otherwise. Ap parently in some of the plants where the FVd plant is only part of a large complex, there is much general travel through the FVJ area. 3. Mentioned that regulated areas need not all be permanent, temporary regulated areas can be set up. 9. ?elt that notifying employees once a month of their ex posure when they are monitored personally was nor enough. Interpreted that since area monitoring will show daily that they are over 1 ppm i`WA, they must be notified daily. Had ruling from odllA that posting on bulletin board ic not adequate notification. 1C. Claimed Air Products lawyers were told by GSHA that 100 ppm 7CH in the atmosphere constituted an emergency condi tion requiring notification to GGHA and employees and medical surveillance. We did not intend to consider such a low level an emergency and again will need a clarifi cation. Dr. Brockman in a conversation with me later said he felt Air Products had misunderstood OSHA regarding the 100 ppm level and that CSHA did not consider this the emergency level mentioned in the standard but rather the level above which a man had to wear the auxiliary Pottle to avoid mask changing. 11. A man from General Tire claimed to have a ruling from OCHA that auxiliary bottles need not be carried but only kept in the area. Based on Dr. Brockman's comment above, this v/ould appear to apply only up to 100 ppm. 13. John Barr 3aid only Scott air packs are approved so far. 13. Said they were told by MBA that MCA will not submit a cartridge type mask to iJIGHH. NIGSH test requires a humid air stream be passed over the cartridge before it is tested with VCM. MSA says moisture in the carbon will prevent VGK adsorption. OCC 2894 -3- W`+. i-lckcd uo comment that worsk Hydro had shut down their IrVJ plant because of employee Xoars and wuuld not start up till this problem is solved, Norsk iJydro representative vas oresont but I did not personally tallc to him. Lb Air Products will use canisters in warehouse and air line in poly. iO Barr stated that a separate CailA regulation covering ?ir masks requires that employees leave the exposure envi ronment when r'Qfis oX the auxiliary air supply is exhausted, -ii p7< < ^ o- i haid a sal's haven, for mask changing must be provided. A side comment on securing leaks above 36*000 ppm was that "life rescue" might be interpreted to include the lives oX people outside the exposure area who night be injured by an explosion, there vas little support Xor this interpretation. General comment was that the rule this refers to--no safing out over >0,000 ppm--could not be obeyed. 19. Felt that the offset of overtime would be i# W V/ *W 41* For example, 0.5 ppm for 16 hours would equal the allowed 1 ppm ?.:A for 3 hours. I relt protective clothing (work clothes} van necessary in all regulated areas. interpretation is that it only required where contact with liquid VCT! or rea: cr cleanings is likely. a. Had legal opinion medical surveillance could be discontinued for any employees who go to Jobs in areas below the action level or -. here areas change to less than the action level. Jonsono commented that they will continue medical surveil lance eX all employees ones exposed and all retirees at company expense and oX quits at their own personal expanse. Barr mentioned that all silos, reactors, sample bombs, etc., will need labeling. He wondered about pipe lines. . V# Air .Products will microfilm records. A-* A poll was taken oX estimated T -'A values for the various companies, dome are monomer manufacturers, 'this table may be grossly in error since XVA values are not truly measured but in most cases are estimates from individual checks, Phis tabulation indicates the number of companies estimating the various exposure levels. Ir-m ^5nrm <10pon cP^Pon ^5Cpsci Poly .Area 0 3 14 13 Finishing Area VJTC Leading or Unloading 19 13 o -f a Other (compounding; 0 50 '5. Fifteen companies said they have control rooms. All of these said they have a separate air source from outside. All expect to get the control rooms below 1 ppm. One company said their control room is better than their lunch room. :g. Joe ftudd of General Tire at this time took the podium ancl said they vill use 5" x 4" gummed labels for trash con tainers etc., IF" x 14" signs with half inch letters Xor areas and a stamp for bags. occ 2895 baici boyd of GaiiA had told General fire lawyers that the optional use of masks to :"5 ot.ti ceiling did not ovsr ride the i ppm fbA but only the ppm coiling. IX than .ere true, it would have meant essentially 1QO& mandatory us of musics. A numoer of companies wore acceptihg this interpretation and planning for mandatory use. ..0 sub sequently got a clarification chat our earlier inter pretation -aas correct - meske optional to employees up to .15 pp regardless of 5 ?pn ceiling or 1 ppm TFA. General Tire -bashes choir c-01 protective clothing, '1. hudti said their president nad ruled that there would oe no /bio in their rosin going to fabricating plants. It appeared their market is essentially all captive. They are going tc restrict the problem tc the f-VO producing plant. They till strip at 1/p'f for T'j minutes and expect to hove 10 ppm residual VGM. They have run tests "hj.eh indicate this. 51, They don't intend to pipe VJTr vapors outside work areas os part of solution since this -..ill run afoul of ifA. s I hiactccn companies claimed to have air piped through the plant. Five.use water sealed compressor. Gome use bottles, five have carbon filters on breathing air compressors, uleven have particulate filters. Three monitor air quality. General feeling .as that 0;lying air in >: iw. - \r, \ `"Vs r* ea* 1 ^*i7^ y*1 "1 /"> V - - J \.*4 1 ^ 4- Wa V lAw A Oi.if j +V< ' '-I 4 * Sr-rvan >.:-xp:ri 00.: ..on rosicuni /fi;; rosin s` uischarge .;ns given by the representative from iiax Average f TVG (coars-i suspension Fass lv, ppm OG 10 GO loco ~ rrom ICO '* iltage 10-1000 iongo 100-1000 34. sixteen companies said residuals in their suspension resins are below 1GC0 ppm. Five said below 300 ppm. (These polls should not be taken literally. The que*tions often don't fit prorerLy, are poorly posed, are hard to answer or are rai3understooc. Also, each company .lay have a different answer for different areas or processes.) 3?. Goodrich i3 checking residual VO;i via what they call a 'head space" method with a gas chromatograph. Advantage is ;nultiple samples at once. Thby will submit the pro cedure to the secretary who will mail it to members. A comment was that automatic injection of the sample improves reproducibility. 36- There are additional comments regarding cos rliar.ee with the USEA standard in the general safety notes. ... vurnola C. Grooicaan f. .Sadden 1 , k-T\\lJ~k OCC 2896