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STANDARD GUIDELINES FOR DEVELOPMENT OF DATA BY INDIVIDUAL COMPANIES ON THE ECONOMIC IMPACT OF THE OSHA GENERIC CARCINOGEN PROPOSAL Prepared for: Industry Task Force on OSHA Generic Carcinogen Proposal November 1977 Prepared by: Booz, Allen & Hamilton Inc. Foster D. Snell Division 66 Hanover Road Florham Park, New Jersey 07932 ALCOA0004220 1 TABLE OF CONTENTS SECTION I II III IV TITLE INTRODUCTION GENERAL INSTRUCTIONS KEY PROVISIONS OF THE PROPOSAL THAT AFFECT DIRECT COSTS SPECIFIC INSTRUCTIONS TO COMPLETE FORMS A. DESCRIPTION OF FORMS TO BE COMPLETED BY YOUR COMPANY B. NONENGINEERING COST CONTROL CALCULATION GUIDELINES C. ENGINEERING COST CONTROL CALCULATION GUIDELINES D. ADDITIONAL ECONOMIC EFFECT GUIDELINES PAGE 2 5 8 11 11 12 14 16 APPENDIX A APPENDIX B APPENDIX C ECONOMICALLY SIGNIFICANT SUSBTANCES LISTED IN NIOSH LIST SUSPECTED CARCINOGENS SUGGESTED OUTLINE FOR INDIVIDUAL COMPANY COMMENTS OR TESTIMONY ON THE OSHA GENERIC CARCINOGEN PROPOSAL FOCUSING PRIMARILY ON ECONOMICS FORMS FOR CALCULATION AND ' REPORTING A-l B-l C-l *** * If further information or clarification is desired on any facet of these forms, contact one of the following Booz, Allen people. Contact Business Phone Extension Ronald Kensicki Ronald Rubin Philip Gisser 201/377-6700 201/377-6700 201/377-6700 260 283 205 ALCOA0004221 Purpose I. INTRODUCTION i A broad-based industry committee was formed to address the scientific, legal and economic questions raised by regulations proposed by the Occupational Safety & Health Administration (OSHA) for the identification, classification and regulation of suspect carcinogens (cancer causing substances), hereinafter described as OSHA Generic Carcinogen Proposal. It has re tained Booz, Allen i Hamilton, Foster D. Snell Division, to prepare these Guidelines and the enclosed forms. The principal purpose of these materials is to assist you in analyzing the economic impact of the OSHA proposal on your company or on products you make or use. The attached materials are designed to facilitate your understanding of the OSHA proposal and focus your thinking on economic impact. You are urged to prepare and file comments with OSHA and/or to participate in the public hearing scheduled for the proposal using the enclosed materials as guides. Experience has shown that sound economic arguments, particularly for smaller businesses, can significantly impact agency decision. The industry committee has also asked Booz Allen to prepare a broader economic impact analysis of the OSHA proposal. If you would like to cooperate in this effort, the enclosed forms should be completed and photocopies sent to Booz, Allen on a confidential basis, - by early December. Background On OSHA Proposal In the Federal Register of October 4, 1977 (42 Fed. Reg. 54147), OSHA published its Generic Carcinogen Proposal. Abandoning its previous substance-by-substance approach to regulating chemical substances in the work place, OSHA, through these regulations, proposes to establish a vehicle and framework for future rulemakings which will enable it to move expeditiously. The regulations set forth criteria for determining whether a substance is a carcinogen, establish a classification scheme for suspect and known carcinogens and require certain regulatory actions to be taken following such classification. There are attached to the proposed regulations model standards to be used by OSHA as essentially fill-in-the-blank modules for standards on individual substances. Once adopted, the proposed regulations should lead to a flurry of regulatory activity, the focus of which will probably be a List of Suspect Carcinogens published by the National Institute for Occupational Safety and Health (NIOSH), numbering in excess of 2400 substances, and which has been growing at the rate of 100 substances a month. The regulations represent OSHA's proposed resolution of many complex scientific and legal issues. Once resolved in this rulemaking, those issues may not be open to further question in subsequent rulemakings on individual substances. The criteria, classification scheme, and regulatory consequences in this proposal will apply to all subsequent OSHA rulemakings on suspect carcinogens. Indeed, given recent public pronounce ments on the need for cooperation and harmonious policies between federal agencies on toxic substances, the OSHA proposal may well form the basis for a national approach to similar regulations for all federal agencies. The proposed regulations will establish criteria for classifying substances and require regulatory consequences to flow automatically therefrom. The proposal authorizes OSHA to ban substances where there are "suitable" substitutes and to require that exposure be reduced to the "lowest level feasible." These two terms are not defined by OSHA. While the industry committee recognizes its collective and individual responsibility to provide workers with a safe workplace free from rebognized hazards, particularly known carcinogens, it believes that the OSHA proposal might result in the improper classification of a substantial number of substances and that the proposal's economic costs might be out of proportion to its possible benefits. Participation In Rulemaking Written comments to OSHA are due January 9, 1978. Persons who intend to appear at the public hearing on the proposal, scheduled to commence on March 14, 1978, are required to file a notice of intent to appear, and, if they expect to testify for more than 15 minutes, file their full testimony by January 9, 1978. Although you should make every effort to meet these deadlines, we believe, although OSHA has not so stated, that it may decide not to exclude late submissions from its rulemaking record.(1) Written comments should be submitted in quadruplicate to: Docket Office Docket No. H-090 Room S-6212 U.S Department of Labor 3rd Street & Constitution Avenue NW Washington, D.C. 20210 The due date for written comments and notices of intent toappear noted in the Federal Register of October 4 has been extended from December 8, 1977 to January 9, 1978. "2' ALCOA0004222 Notice of intent to appear at the hearing and testimony should be submitted (in quadruplicate) to: OSHA Office of Consumer Affairs Room N 3633 U.S. Department of Labor 3rd Street & Constitution Ave. NW Washington, D.C. 20210 How To Use This Document For Use By Your Company In Preparing Written Comments and/or Testimony You will save time in this endeavor by following the steps described below. . Make copies of the forms in Appendix C, and keep a clear original. You may need multiple copies of some sections. . Select as many chemicals as you feel you can analyze for internal case study from the ninety-nine chemicals listed with their alternate names in Appendix A. These chemicals, all of which appear on the NIOSH List of Suspect Carcinogens, d) are ones Booz Allen believes to be economically significant. There may be other chemicals on the NIOSH list which are not listed in Appendix A but which may be significant to your company. You should, therefore, carefully review the NIOSH list. . Fill out this set of forms for each substance selected. If two of the substances are encountered in the same plant unit, one set of forms is sufficient. . Aggregate the total compliance costs for each case study substance, as shown on Form VI. The ratio of compliance costs to current costs, as well as the other ratios indicated, can be presented in your submission. . Submit written comments for the record (due January 9, 1978). . If you intend to testify at the public hearing, notify OSHA of your intent to testify (due January 9, 1978). If you intend to testify at the public hearing for more than 15 minutes, file full testimony (due January 9, 1978). . Testify at public hearing commencing March 14, 1977. . Retain file copies of all information collected and submissions made. If You Elect To Participate In The Broader Impact Study By Booz, Allen If you elect to cooperate with the Booz, Allen study, please follow the procedure outlined below: . Select two or three dissimilar case study substances for analysis at your company. Inform either R. Kensicki or P. Gisser (201-377-6700, extension 260) at Booz, Allen that you are planning to analyze selected case study substances at your company. . Assign one individual responsible for getting the data and returning it. He will probably need the cooperation of plant and engineering people. For chemical producers, marketing people might provide some necessary inputs. U.S. Department of Health Education and Welfare Suspected Carcinogens, A Subfile of the NIOSH Registry Of Toxic Effects Of Chemical Substances, 2nd Edition, Washington, D.C. U. S. Government Printing Office, December 1976, HEW Publication Number (NIOSH) 77-149. 3 ALCOA0004223 i: 4 ii n ii : Make copies of the forms and keep a clean original. You will probably need extra copies for some sections. Identify the plant units in which you make or use any of your selected case study chemicals. Fill out forms for each plant unit identified. Return these forms by early December 1977, to: Foster D. Snell, Division Booz, Allen & Hamilton Inc. 66 Hanover Road Florham Park, New Jersey 07932 Attention: Mr. R. Kensicki The information returned will, of course, be analyzed confidentially by Booz, Allen & Hamilton Inc. Details of the confidentiality procedures follow: All information will be confidential and access will be limited within Booz, Allen and Hamilton Inc., on a need-to-know basis. . Only one page carries company identification. This page will be separated from the rest and kept in a locked file for use only by authorized personnel if follow-up is needed for clarification. . The other pages will be assigned identification numbers. Personnel involved in data processing and analysis work will have access only to those numbers. . The final report will not attribute information to a specific company or identify any individual source without the company's authorization. . The original records will be returned to you when the report is completed, and no copies will be retained. .! C 4- ALCOAO 004224 XI. GENERAL INSTRUCTIONS ------------------------------------------ 1 t' The forms in this package refer to the cost of compliance with OSHA's Identification, Classification and Regulation of Toxic Substances Posing a Potential Carcinogenic Risk. This form is organized to collect economic data for each of the products manufactured at your plants that may potentially be affected by the proposed regulation of substances. Substances for case study should be selected by your company from the following: . Economically Significant List -- In Appendix A substances are listed that are on the NIOSH Suspected Carcinogens list and judged to be economically significant on the basis of total U.S. production and the number of total employees associated with their manufacture or use or both. Your company may wish to select applicable substances from this list and present one or more case studies. Other Substances -- In the NIOSH publication Suspected Carcinogens, 1976, over 2400substances are listed that may be regulated underthe proposed act. There may be other substances not listed in the NIOSH document that your company may want to study. The manufacture and use of these substances may have specific impact on your company. For each of the case studies selected, one set of forms should be completed for each production plant at your company that is associated with the substance under study. The substance may be: . Manufactured at the plant (e.g., as a product, by-product or co-product) . Used at the plant (e.g., as a raw material) . Present as in-process material (e.g., as a solvent, formulation or impurity) . Handled for wholesale or retail distribution. Therefore, your company may complete more than one set of forms depending on the number of plants that are associated with the case study substance. For example: . Only one set of forms may be required for a case study substance if it is used, manufactured, present or handled at only one plant site of your company . More than one set of forms may be required for a case study substance if it is used, manufactured, present or handled at more than one plant site. Cost information will be determined on a plant-by-plant basis for each substance selected for a case study. If more than one substance is present at each plant that may potentially be regulated: . Do not allocate separate compliance costs to each of the various substances present. . Assume that the compliance cost required will be the effect of all substances at the plant unit potentially regulated. . Do not complete a separate set of forms for each substance present at a plant unit, since this would result in double counting. OSHA's proposed regulation and these forms cover each of the substances that may be classified by OSHA under Category I or Category II. The four categories established by OSHA are: . Category I - Confirmed Carcinogens Category II - Suspect Carcinogens . Category III - Substance for Which There Is Insufficient Information to Reach a Conclusion on Carcinogenicity . Category IV - Substances of Carcinogenic Potential Not Found in the American Workplace. i l ^ i j ; 5 - ALCOA0004225 To avoid prejudging the results of future oncological testing, the cost analysis is evaluated at two assumed levels: Assumption I - Assume that the case study substances will be classified as a Category I substance . Assumption II - Assume that the case study substances will be classi fied as a Category II substances. The compliance costs calculations are similar for Category I and Category II substances except for: . Engineering Controls - Category I substances will require employers to provide engineering controls to reduce exposure to the "lowest level feasible" (refer to No. 6, below) - Category II substances are assumed for purposes of this study not to require engineering controls expenditures, d) . Segregation of Work Area Category I substances will require employers to segregate work areas of the plant in which Category I substances are present. - Category II substances will not require segrega tion of the work area. . Lunchroom Facilities - Category I substances will require employers to provide lunchroom facilities that have a controlled temperature, positive pressure and filtered air supply whenever food or beverages are consumed in the workplace. - Category II substances require appropriate facili ties for eating and drinking. Therefore, no capital cost expenditure should have to be applied. 6. The proposed OSHA regulation requires that engineering controls be provided to reduce exposure to the "lowest level feasible." OSHA does not define the "lowest level feasible." Depending on the definition, the cost of engineering controls may vary dramatically. Therefore, the cost of engineering controls should be calculated at three assumed levels. These assumed levels selected for the case studies were chosen to provide a range of possible standards; they do not directly reflect the level that OSHA may establish for a case study sub stance and they do not imply that these levels are technically feasible. The three assumed permissible exposure levels (PEL) for the case study substances differ depending on the form of the substance. . For liquid or gaseous substances, the engineering controls should be estimated at the following three PEL levels: 10 parts per million 1 part per million 10 parts per billion . For solid substances, the engineering controls should be estimated at the following three PEL levels: 100 micrograms per cubic meter of air (0.1 milligrams) - 10 micrograms per cubic meter of air 1 microgram per cubic meter of air l-W There are certain situations where capital cost expenditures can be called for under the proposed act. For example:' If it is currently not feasible to meet an existing permissible exposure level (PEL) and your company uses respirators for compliance, engineering controls will be required to reduce exposure to the lowest level feasible, while still requiring use of respirators. Or, if the substance is not now covered by a PEL, it can be under this regulation. If these situations apply to your company, you may want to address them in your submission. 6 ALCOA0004226 7. This form establishes a standardized basis for estimating compliance cost and other economic effects. The cost data are"differential" costinformation -- the added cost of compliance over andabove the cost ofcompliance withexisting regulations. 8. The cost of compliance should be consistent in terms of 1977 dollars. 9. The compliance costs should assume no change in demand for the primary product. Therefore, compliance costs shall be determined at: . 1976 production output . 1976 employment. The compliance costs should assume normal operations and not take into account other factors, such as changes in prices and availability. 7 ALCOA0004227 III. KEY PROVISIONS OF THE PROPOSAL THAT AFFECT DIRECT COSTS (The provisions presented apply to substances that are classified as Category I or II unless specifically noted.) Monitoring . The employer must determine the employee exposure to the toxic substance over an eight-hour period without regard to the use of respirators. . Initial Monitoring shall be performed for each workplace and work operation to accurately determine the airborne concentrations to which employees may be exposed. . If the employee exposure is above the permissible exposure limits (PEL), these monitoring determinations shall be repeated at least monthly. Monthly determinations shall continue until at least two consecutive measurements are below the PEL; there after, monitoring shall be performed quarterly. . Monitoring shall be performed at least quarterly in work areas below the PEL. . Additional monitoring shall be performed wherever there has been a production, process, control or personnel change which may result in new or additional exposure, or wherever the employer has reason to suspect a change may result in new or additional exposure. . The opportunity of employee observation of monitoring exposure shall be provided to affected employees or their designated representatives. Medical Surveillance A medical surveillance program shall be instituted for each employee who is or will be exposed to the regulated substance. An initial examination shall be provided for each employee at the time of initial assignment or upon institution of the program. . Periodic examinations shall be provided for all exposed employees. The frequency and nature of the examination will be specific to the regulated substance. . Additional examinations will be provided if signs or symptoms commonly associated with exposure occur. Sanitation Facilities, Emergency Plans, Posting and Labeling (Requirements for Category 1^ Substances Only) . Regulated areas shall be established where concentrations of Category I substances are in excess of the PEL. These areas shall be demarcated and segregated from the rest of the workplace. - Area access shall be limited to authorized persons. Food, beverages or smoking products shall not be present or consumed in the area. . Whenever food or beverages are consumed in the workplace, the employer shall provide lunchroom facilities that have a temperature controlled, positive pressure, filtered air supply and that are readily accessible to employees. 8 ALCOA0004228 (Requirements for Category I_ and II Substances) . Emergency plans shall be developed for each workplace where the regulated substance is present. They shall include: - Provisions for respiratory protection of employees engaged in correcting emergency conditions Means for alerting employees of high concentration levels. . Clean change rooms and showers shall be provided. Exposed employees shall shower at the end of the workshift. . Signs shall be posted to indicate clearly all workplaces where the regulated substances may be present. Where airborne concentrations are above the PEL, signs shall additionally bear "Respirator Required" legend. . Precautionary labels must be affixed to all containers and products containing the regulated substances. Personal Protective Equipment . Respirators shall be used to reduce employee exposure to within the PEL and during emergencies. . Protective clothing and equipment required by the Act shall be cleaned, laundered, maintained or replaced at no cost to the employee. Employee Training . Training programs shall be provided at the time of the initial assignment and annually thereafter. Recordkeeping Exposure monitoring records shall be kept for a minimum of 40 years. They shall include: Results and comprehensive description of monitoring per formed to determine representative employee exposure Description of the sampling and analytical methods used - Description of type of respirator protection worn - Identification of all other employees whose exposure the measurement is intended to represent. Medical surveillance records shall be kept for a minimum of 40 years. They shall include: Physician's written opinions - Employee complaints relating to exposure A copy of information that must be provided to the examining physician. This includes: .. Description of duties of affected employee as they relate to exposure .. The employee's anticipated or expected exposure (preplacement and emergency) .. Description of personal protective equipment to be used .. Employee's work history. - 9' - ALCOA0004229 Engineering Controls . Engineering and Work Practice Controls shall be instituted to reduce or maintain employee exposures to or below the PEL, except to the extent the employer establishes that controls are not feasible. In the event the PEL cannot be attained, the employer shall reduce exposures to the lowest level achievable and supplement the controls with use of respiratory protection. . A written Compliance Program shall be established and implemented at or below the PEL solely by means of engineering and work practice controls. It shall include: - Process or operation descriptions Engineering plans to determine controls Report of technology considered Detailed schedule of implementation (to be updated every six months). - 10 - ALCOA0004230 IV. SPECIFIC INSTRUCTIONS TO COMPLETE FORMS IV A. Description of Forms To Be Completed By Your Company There are eight basic forms enclosed in this package. The completion of these forms will serve as a basis for estimating the economic impact of the proposed OSHA carcinogen standard. Rather than to prejudge future oncological testing or "safe" employee exposure levels, there are four levels for which direct costs will be estimated by these forms for each case study substance. These levels correspond to the following assumptions: . Case study substance is classified as a Category II substance and the PEL established will not require additional engineering controls. . Case study substance is classified as a Category I substance and the PEL established is 10 ppm for liquids and gases, or 100 micrograms per cubic meter of air for solids. . Case study substance is classified as a Category I substance and the PEL established is 1 ppm for liquids and gases, or 10 micrograms per cubic meter of air for solids. . Case study substance is classified as a Category I substance and the PEL established is 10 ppb for liquid and gases, or 1 microgram per cubic meter of air for solids. Each of these forms is described below: FORM I- COMPANY IDENTIFICATION Fill out this form once for your company. Its primary purpose is to identify a contact so to provide an opportunity for clarification of data if your company elects to send the completed forms to Booz, Allen. This sheet, the only one that identifies your company, will be assigned a key number, which will also identify the accompanying pages. It will be kept in a locked file with access limited at all times. FORM II- STATISTICAL DATA Fill out this form for each plant unit of your company that is associated with the selected case study substance. If you elect to return it to Booz Allen, its primary purpose is to provide scale-up data. In the upper right hand side of the form , assign a plant unit number and identify the case study substance. FORM III- NONENGINEERING COMPLIANCE COST WORKSHEET Fill out this page ior each plant unit identified by Form II. This form is used to estimate the nonengineering compliance cost for that plant unit. When completing this form refer to the Nonengineering control Cost Calculations Guidelines on page 12 of the instructions. FORM IV- ENGINEERING CONTROL COST WORKSHEET Fill out this form for each plant unit identified by Form II. This form is used to estimate the engineering compliance costs at three assumed PEL levels for that plant unit. When completing this form refer to the Engineering Control Cost Calculation Guidelines on page 14 of the instructions. FORM V- SUMMARY DATA-- DIRECT COSTS AT PLANT UNIT LEVEL Fill out this form for each plant unit identified by Form II. This form summarizes the direct costs for that plant unit for the selected case study substance. FORM VI- SUMMARY DATA-- RELATIVE COST CHANGES Fill out this form once for each case study substance. It should be filled out after the individual case studies by your company have been consolidated. FORM VII- ADDITIONAL ECONOMIC EFFECTS-- PRODUCTS Fill out this form for the plantunit only if the case study substance is produced or formulated at the plant unit.This form is used to identify the indirect economic effects of the proposed regulations. When completing this form, refer to the Additional Economic Guidelines on page 16 of the instructions. FORM VIII- ADDITIONAL ECONOMIC EFFECTS-- RAW MATERIALS Fill out this form for the plantunit only if the case study substance is purchased or used at the plant unit. Thisform is used to estimate the indirect economic effects for users. When completing this form, refer to the Additional Economic Guide lines on page 16 of the instructions. 11 ALCOA0004231 XV. B. Nonenqineerinq Control Cost Calculation Guidelines (For Use With Form III) For many of the provisions of the proposed OSHA regulation, a simplified cost calculation method has been developed to assist your company in completing this questionnaire in a timely manner.1 ' However, some of the provisions of the regulation, such as engineering controls and sanitation facilities, require a knowledge of current facilities and estimates must be made by your company. Listed below are the simplified cost calculations for nonengineering control type cost elements. Each of the cost elements correspond to the direct cost calculation questionnaires presented on Form III. i The following are symbols denoted in the cost calculations presented below: N -- number of exposed employees (as determined in Form II) | n = number of employees currently covered i by similar programs W = number of work areas at the plant unit 1. Initial Monitoring Cost . No capital cost . No annual operating cost . Differential first-year operating cost = $(10 N + 450) 2. Exposure Monitoring Cost . No capital cost . Annual operating cost = $67 N . Differential first-year operating cost = $45 N 3. Medical Surveillance Cost . No capital cost . Annual operating cost = $155 (N - n) . No differentialfirst-year operating cost 4. Change Rooms and Showers . Capital and annual operating costs to be estimated by your company . No differential first-year operating cost 5. Emergency Alarms . Capital cost to be estimated by your company . Annual operating cost to be estimated by your company . No differential first-year operating cost 6. Respirators . No capital cost . Annual operating cost = $25 N less current operating costs Differential first-year operating cost = (Number of additional respirators purchased) X (cost per respirator) 7 Personal Protection Equipment . No capital cost . Annual operating cost = $343N less current operating cost . Differential first-year operating cost to be estimated by your company includes purchase of uniforms, gloves, aprons, faceshields and goggles where required. TTJ Although a number of these costs might be treated as capital costs, these cost calculation guidelines treat most of these expenditures as expense items. 12 ALCOA0004232 8. Signs . No capital and annual operation costs Differential first-year operating cost = S 80 W 9. Emergency Plan . No capital and annual operating costs . Differential first-year operating cost = $ 400 W 10. Recordkeeping Cost . No capital cost . Annual operating cost = $15 N . Differential first-year operating costs = $200 W 11. Training Program Cost No capital cost . Annual operating cost = $(160 + 15 N) . Differential first-year operating cost = $200 13. Segregation of Work Areas (Category I assumption only) Capital costs must be estimated at the plant level for work areas. . Annual operating cost to be estimated by your company. . No differential first-year operating cost. 14. Lunchroom Facilities (Category I assumption only) . Capital costs must be estimated at the plant level for work areas. . Annual operating cost to be estimated by your company. . No differential first-year operating cost. 13 ALCOAO 004233 XV.C. Engineering Control Cost Calculation iGuidelines (For Use With Form IVT ] The key provisions of the proposed act call for engineering controls to play the major role in reducing employee substance exposure. For purposes of this study, we have assumed control costs will only be required for areas where the case study substance is evaluated as a Category X substance. Engineering control costs required for Category I will depend on the PEL level that is established for that substance. For purposes of economic analysis, we have designated several assumed levels for which engineering controls should be estimated. These levels were selected arbitrarily to provide several levels at which engineering controls could be evaluated. For substances that are in liquid or vapor form, engineering controls will be evaluated at the following three assumed PEL levels: .. 10 parts per million .. 1 part per million 10 parts per billion - For solid substances, engineering controls will be estimated at the following three assumed PEL levels: .. 100 micrograms per cubic meter of air 10 micrograms per cubic meter of air .. 1 microgram per cubic meter of air The capital cost calculations for each of the types of control should reflect a total project cost in 1977 dollars. Elements usually included are: Engineering Design Materials Equipment - Construction Contingency (to be applied as 10 percent of all costs above). The costs for typical investment items as presented on the next page reflect total project cost and if applied should not be altered to include additional project cost factors. If it is determined that in order to achieve one of the designated PEL levels, a new facility would be needed for economic or technological reasons, then the engineering control capital cost should be estimated as the cost of an equivalent new facility (same production capacity): The capital cost should be the cost of a new facility less the salvage value (or plus the demolition cost). The annual operating cost should be the differential cost of the new facility operating cost minus the existing facility operat ing cost (do not include depreciation). The differential first year costs should include start-up costs. Total engineering costs to meet the assumed PEL level must be estimated by your company. However, to assist your analysis, the following is a list of control techniques that are typically used to control exposure levels. Vapor Particulates Process change Ventilation Storage tank vapor control Mechanical seals for pumping equipment Liquid level alarms Rupture discs for relief valves Closed loop sampling systems Process change Ventilation Enclosures of equipment or process Washing or decontamination systems Conveying systems Leak proofing Clean up equipment The remainder of this section briefly describes the control techniques above and provides some typical costs which you may use as guides, exclusive of factors for piping, instrumentation, excavation, grading, utilities, etc. 14 ALCOA0004234 1. Process Change If process change is selected as the method of reducing substance exposure, the capital cost requirement must be determined solely for the individual process or operation. 2. Ventilation Ventilation systems can be designed to control either the local area or a general area. The cost is also dependent on the specified air flow rate. 3. Storage Tank Vapor Control Floating roof tanks, indirect combustion, activated carbon adsorption and vapor containment systems are commonly applied to control storage tank vapors. Floating roof tanks are usually more cost effective than other control tech nologies to control storage tank vapors. 4. Mechanical Seals For Pumping Equipment Pumps that currently have packed seals can be changed to mechanical seals. The control cost per pump is normally $5,000 to $10,000. 5. Closed Loop Sampling System The installation of closed loop sampling systems will reduce employee exposure to liquid vapors during process sampling. The estimated cost for fabrication of such a system is estimated to be $500 per sampling location. 6. Liquid Level Alarms Storage and process vessels should be equipped with high liquid level alarms to reduce the potential of overflow. The estimated cost to equip existing tanks with liquid level alarms is $3,000 per tank. 7. Rupture Disks Rupture disks are used to reduce leakage associated with poor sealing of relief valves. The estimated cost is $1,000 per relief valve. 8. Enclosures of Equipment or Processes These systems consist of complete enclosure of equipment and processes using impermeable barriers. They are usually accompanied by exhaust ventilation and material collection systems. 9. Washing or Decontamination Systems These systems are used in handling and storage areas to reduce exposure to particulate substances that adhere to exteriors of storage containers. Contami nated washings handling equipment costs should be included in these systems. 10. Clean-Up Equipment Generally consists of vacuum equipment to prevent particulate accumulation. 11. Conveying Systems These systems are required to transport particulate substances instead of manual handling. They are generally enclosed. 12. Leak Proofing This is done in existing doors, enclosures and ventilation systems whenever necessary. Cost to be estimated by your company. 15 ALCOA0004235 IV D. Additional Economic Effect Guidelines (For Use With Form VII & Form VIII) The requirements of the OSHA Carcinogen Standard may result in effects on your business in addition to direct quantifiable costs. Some of these are: . Regulated substitution of raw materials. The proposal authorized OSHA to require for Category I substances "no occupational exposure," if it determines that there is a less hazardous suitable substitute. This may, in effect, amount to a ban on a substance for some or all applications. Voluntary substitution of raw materials for a variety of reasons: - To avoid complexity of handling regulated materials. To avoid potential liability effects. - To avoid higher-cost regulated materials. Changes in sales levels for a variety of reasons': - Substitution to avoid handling of products labeled "carcinogens.: - Reduction in purchase because of higher price. - Effect of a potential ban on the substance in the workplace. - Loss of sales to nonregulated foreign producers. . Loss of jobs because of sales reduction or plant closings. . Changes in productivity because of manpower requirement shifts, change in production capacity or change in demand. . Business closings because of higher operating cost, higher raw material prices or product bans, especially as they might effect small businesses. . Changes in price because of changes in cost or demand. These issues are addressed on Forms VII and VIII. They may not all be significant for a single company but those that do apply should be addressed. They may well be significant from an overall industry point of view. Many of these areas call for subjective judgment and projections of what is likely to happen, it is important to be realistic in those assessments. Any exaggerations in this area would throw doubt on the credibility of the entire effort. Questions in this area are divided into two pages: . Form VII is to be filled out if the plant unit produces the particular case-study substance. Much of the material can be better provided if marketing people are involved in filling out this page. . Form VIII is to be filled out if the plant purchases, uses, or in another way encounters the case-study substance in the plant unit. Either one or the other, in general, should be filled out for each case-study sub stance encountered in the plant unit. Formulators should fill out both. For the survey, any areas that are not applicable should be marked, "not applicable." 16 ALCOA0004236 APPENDIX A ECONOMICALLY SIGNIFICANT SUBSTANCES LISTED IN NIOSH SUSPECTED CARCINOGENS, SECOND EDITION APPENDIX B SUGGESTED OUTLINE FOR INDIVIDUAL COMPANY COMMENTS OR TESTIMONY ON THE OSHA GENERIC CARCINOGEN PROPOSAL FOCUSING PRIMARILYjON ECONOMICS i ) i, alCOA000423J7 NICSH NUMBER<a> ` NAHE^ WG21000 AF85750 AH52500 AI52500 AL31500 EL64750 AS10500 ATS2500 XW52500 ASI0500 DG19250 BW66500 DG19250 KJ57750 W47250 BW66500 XS96250 BW66500 SE73500 XY56000 xy56ooo OF98000 KV03500 OF98000 CY14000 BW66500 CZ10500 TI31500 CZ45000 CZ45500 DA07000 XS52500 DA64750 WL36750 ACETIC ACID, (2-BUTENYLIDENE)ACETIC ACID, CHORDACETIC ACID, EffiYIENEDINITRIIlJlETKA-, TRISODIUM SALT ACETIC ACID, IEAD (2+) SAIT ACETONE ACETONE, METHYLACROLEIN ACRYLCNITRII AILTOX ALLYL AIDEHYDE AMIBEN AMINCBENZENE 3-AMINO-2,5-DIOgORCBENZOIC ACID 2-AMINCEIHANaL AMmarom AMINCPHEN 3-AMDJO-p-TQLUIDINE ANILINE ASPHALT (STEAM REFINED) ATRANEX ATRAZINE AUSTRIAN CINNABAR BAKET.TTE BASIC LEAD CHROMATE BENZENE BENZENE, AMINOBENZENE, 1-CHIDRD-4-NITRD 1,2-BENZENEDICARBQXYLIC ACID ANHYDRIDE BENZINE, o-DICHLOROBENZENE, p-DICHLOROBENZINE, ETHYLr BENZENE, METHYLBENZINE, NITROBENZINE, VINYL- 1 in APPENDIX A IN NIOSH SUSPECTED CARCINOGENS, SEOCND EDITION. (c> NIOSH number^ NRME(b) DG19250 XS89250 DS14000 DS17500 D628000 DS40250 LP89250 GO78750 DU80500 DU80500 H484000 ED45500 PA49000 KJ85750 EL64750 KJ85750 GO78750 KJ85750 KJ85750 KJ85750 EU98000 EV01750 EVL9250 EV27000 EV31500 XR22750 XW52500 EY26250 PC59500 AT52500 QP07000 ZH33250 PC59500 BENZOIC ACID, 3-AMINO-2,5-DICHLOR> BENZYL CHLORITE BERYL BERYLLIUM BERYLLIUM ELUORIEE HERYILUM OXIDE BEV BHT BIBENZENE BIPHENYL S-l, 2-BIS (ETHOXYCAPBONYL) ETHYL-0,0DIMETHYL TKLOPHOSPHAIE . BORIC AdD BRQMDMETHANE BOOS 2-BUIANCNE 2-BOTOXYETHANDL BLTTYIATED HYDROXYTOLUENE BUTYL CEUOSQLVE O-BUTYL ETHYLENE GLYCOL BUTYL GLYCOL CADMIUM CADMIUM CHLORIDE CADMIUM OXIDE CADMIUM SULFATE (1:1) CADMIUM SUIFIDE CAIOOTCNE WHITE T CAMPHECHIOR epsilon-CAPRQLACTAM POLYMER CAPROLIN CARBACRYL CARBAMIC ACID, ETHYLENEBIS (DITHIO)-, MANGANESE SALT CAIEAMIC ACID, ETHYLENEBIS (DITHIO) -, ZINC SALT CARBAMIC ACID, METHYL-, NAPHIHYL ESTER A1 ALCOA0004238 APPENDIX A ECONOMICALLY SIQCTFICAWT SUBSTANCES LISTED IN NIOSH SUSPECTED CARCINOGENS, SECOND EDITION.^ NIOSH NUMBER(a) NAME NIOSH NUMBER<a> NAME1 YR62500 PC59500 WMB4000 WM84000 SJ33250 FF66500 KX38500 FF66500 FF66500 PG49000 YR62500 QR59500 WM84000 FJ59500 TQ35000 PC59500 FJ59500 WM84000 DG19250 M452500 AF85750 CZ45000 AF85750 XY56000 KU96250 KV03500 FS91000 KJ29750 PA63000 CZ10500 SM63000 XS89250 GB29550 OF98000 GB27500 <2328500 CARBAMIDE CARBARYL CARBETHOXY JMAIHICN CAIEETOX CARBOLIC ACID CARBON BISULFIDE CARBON DICHLORIDE CARBON DISUITIDE CARBON SUIfTXE CARBON TETRACHLORIDE CAFBCNYIDIAMINE CARBONYL NICKEL PCHDER CARBQPH06 CARBCIXYMEHHYLCELLULQSE, SODIUM SALT CARB0W3X CARPQLIN CELLULOSE, CARBQXYMETHYL EIHER, SODIUM SALT CHEMA3HI0N CHLQRAMBEN CHLORINATED CAMPHENE CHLOROACETIC ACID CHLOROBEN CHLORCETHANOIC ACID 2-CHLORO-4-E1HYIAMENOISOPROPYIAMINE--S-TRIA2INE CHLOROETHYIZNE CHLORCETHYLENE POLYMER CHLOROFORM CHLOROFORM, METHYLCHLORCMEIHANE 1-CHLORO-4-NITRCBINZENE CHLORQPHEN alpha-CHLOROTOLUENE CHROMATE OF SODA CHROME ORANGE CHROMIC ACID, CALCIUM SALT CHROMIC ACID, CHROMIUM (3+) SALT GB29550 (2342000 QR59500 BW66500 WL36750 WL36750 WL36750 BH66500 XS96250 CF98000 XR22750 DA64750 XW52500 CZ45000 CY14000 VZ47250 XW52500 HM84000 FC59500 0078750 AT52500 CY14000 VW84000 TQ79000 TX87500 CZ45000 XS96250 XS96250 TX87500 KH92750 (3078750 DG19250 CZ45000 CZ45500 PA82000 KI05250 CHROMIC ACID, DISODIUM SALT CHROMIUM C.I. 7775 C.I. 76000 CDNNAMENE CDflNAMENDL CINNAMOL C.I. OXIDATION BASE 1 C.I. OXIDATION BASE 200 C.I. PICHENT RED C.I. PIOGNT WHITE 6 C.I. SOLVENT BIACK 5 CLOR OEM T-590 CLQRCBEN COAL NAPHTHA OMEN SALT COMPOUND 3956 COMPOUND 4049 CRAG SEVIN p-CRESOL, 2-6-DI-tert-BOTYLCYANOEHHYLENE CYCLOHEXAIRIENE CY1HICN DACRON DBCP DCB 1,3-DIAMINO-4-METHYTI3ENZENE 2,4-DIAMINOrOljUENE 1,2-DIBRCMO- 3-CHLOROPROPANE 1,2-DIBROMDETHANE 2,6-DI-tert-BUTYL-p-CRESOL 2,5-DICHLORO-3-AMENOBENZOIC ACID o-DICHLDROBENZENE p-DICHLOROBENZENE DICHLORODIFLUORQMETHANE 1,2-DICHLOROEIHANE A2 ALCOA0004239 APPENDIX A ECONOMICALLY SI3JIFICANT SUBSTANCES LISTED IN NI06H SUSPECTED CARCINOGENS, SECOND EDITION. (c) NIOSH i NtMBER(a) NAME(b) NIOSH NUMBER'4* NAME(b) i ! KE05250 DICHIJOROETHYIENE KH92750 ENT 15,349 1 PAB0500 DICHDDRCMETHANE WM84000 ENT 17,034 i WM84000 DIETHYL MEHCAPTOSU3CINA3E, 0,0-DIMETHYL TG01750 ENT 17,292 : PHCEPHORDDITHIQAIE i P KX24500 DIMETHYIENE OXIDE F359500 ENT 23,969 TX49000 EPICHLOKHYDRIN AL31500 DIMETHYL KETCNE i ;i TG01750 DIMETHYL p-NITRQPHENYL MCNCTHIOPHOSPHA1E TX49000 EPICHLORCHYDRIN KX24500 1,2-EPQXYETHANE \ TG01750 0,0-DIMETHYL 0-(p-NITKPHENYL) PHOSPHOROTHIOATE 1X29750 1,2-EPOXYPROPANE | TG01750 DIMETHYL PARAIKEON TI31500 ESIN WZ1225Q DIMETHYL p-PHTHAIATE XW52500 ESTONOX WZ12250 DIMETHYL TEREPHIHAIATE a KH92750 ETHANE, 1,2-DIBRCMD- XT15750 2,4-DINITFOroUlEME KT05250 ETHANE DICHLQRIDE XT19250 2,6--DD4ITRCTOLUENE KI05250 ETHANE, 1,2-DICHLORO- DU80500 DIPHENYL KJ29750 ETHANE, 1,1,1-TRICHLORO- OP07000 DITHANE M22 FF66500 WZ12250 DITHIOCARBCNIC ANHYDRIDE DMT KQ63000 KJ57750 ETHANOL ETHANOIAMINE XT15750 KJ85750 KH92750 PA49000 2,4-ENT DOWANOL EB DOWFUME 40 DCWFUME M3-2 KJ57750 KI85750 KX45500 KQ63000 ETHANOL, 2-AMINOETHANOL, 2-BUIOXYETHINYL TRICHLORIDE ETHYL ALOCHOL PA49000 SN15750 DOWFUME M3-33 DOWICIDE 2S DA07000 CHS 2250 ETHYL BENZENE ETHYL CARBIM3L SM63000 DOWIdEE G AS10500 ETHYLENE ALDEHYDE CZ45000 DOWIHERM E 0=07000 ETHYLENEBIS(DITHIOCARBAMATE) MANGANESE KX45500 DCW-TRI ZH33250 ETHYIENEBIStDITHIOCARBAfRTE) ZINC TG0I750 E 601 KH92750 ETHYLENE BROMIDE DA07000 EB KI05250 ETHYLENE CHLORIDE KH92750 EDB KU96250 ETHYLENE, CHLORD- 1 KI05250 EDO KV03500 ETHYLENE, CHLORD-, POLYMER FJ59500 EDIFAS B AH52500 ETHYIENEDIAMINETETRAACETTC ACID, TRISODIUM SALT AH52500 EDEA TRISODIUM SALT KH92750 ETHYLENE DDBROKIDE KI05250 ENT 1,656 KI05250 ETHYLENE DICHLORIDE KX38500 PG49000 ENT 1,860 ENT 4,705 KJ85750 KU96250 ETHYLENE GLYCOL, MONCBOTYL ETHER ETHYIENE M3NOCHLORIDE XW52500 ENT 9,735 KX24500 ETHYLENE OXIDE A3 ALCOA0004240 APPENDIX A BCCNGMICALLY SiannCANT SUBSTANCES listed in niosh suspected carcinogens, sbccnd EDITICN.(c) NIOSH NUMBER (a> NAME(b) NIOSH number'3' NAME031 TZ29750 WL36750 KX38500 KX38500 KX45500 KX45500 EL64750 ZH33250 N085000 N085000 PA82000 WM84000 LP89250 LP89250 MJ47250 LP89250 LP89250 PA82000 PA82000 TX87500 CN36750 XY56000 PA82000 KJ85750 KH92750 KI05250 KJ85750 KQ63000 ND85000 PA82000 FG49000 PA49000 PA94500 WG21000 JM47250 MJ47250 ETHYLENE OXIDE, METHYLETHYLENE, PHENYLETHYLENE TETRACHLORIDE ETHYLENE, TETRAOLLORDETHYLENE TRICHLORIDE ETHYIENE, TRICHIORDETHYL METHYL KETCNE ETHYL ZIMATE EEOSOL ferrous SULFATE ELUOROCAHBCN-12 FORMAL FOFMAIXEHYDE TOIWALIN POIMAMINE FORMIC AdD EOFMX FREON-12 FREJCN F-12 FCMAZCNE 2,4-FURANDICNE (3IIGY 30,027 GENETRCN 12 GLYCOL BUTYL ETHER GLYCOL DLBRCMLEE GLYCOL DICHLORIDE GLYOOL MCNCBUTYL ETHER GRAIN ALCOHOL GREEN VITRIOL HAICN HALCN 104 HAICN 1001 HAICN 10001 2,4-HEXADHNOIC ACID HEXAPORM HEXAMETHYUNEAMINE M447250 M447250 EK70500 SJ33250 KJ57750 NP96250 PA94500 NC85000 NP96250 NP96250 NP96250 AL31500 EL64750 AI52500 CF98000 CF98000 CF98000 TP45500 WM84000 WM84000 WC4000 CN36750 CN36750 CP07000 QP07000 CP07000 AF85750 KJ57750 PA49000 EL64750 WM84000 TG01750 TG01750 XS52500 OZ50750 LP89250 A4 HEXAMETHYLENETETRAMINE HEXAMINE HYDROCYANIC AdD, SALTS HYDRQXYBENZENE 2-HYDRDXYETHYIAMINE 1-HYDRQXYMETHYLPRQPANE IODCMETHANE IRCN (II) SUIEATE (1:1) ISCBUEANQL ISCBOTYL ALCOHOL ISOPHCPYLCARBINX KETCNE, DIMETHYL KETCNE, ETHYL METHYL IEAD ACETATE IEAD CHHMCTE, BASIC IEAD CHRCMAIE (VI) CKHE LEAD CHROMATE, IED IEAD, TETRAETHYL MAIACIDE MAIATHICN MAIATC3X MALEIC ACID ANHYDRIDE MALEIC ANHYDRIDE MANEB MANGANESE, (ETHYIFNEBIS (DITHIOCAfBAMATO))- MANZATE MCA MEA MEBR MEK MERCAPTDTHICN METAdDE METAPHOS METHACIDE METHACKYLIC AdD, METHYL ESTER METHANAL -> ALCOAO 004241 APPENDIX A BQCNCMICAIU SIOLTFICANT SUBSTANCES LISTED IN NIOSH SUSPECTED CARCINOGENS, SBOSND EDITION. (c> NIOSH NlMBER(a) NRMEfo) NIOSH NCMBEFo3) NAME(b) PA49000 METHANE, BRCMO- PA63000 PA80500 MEHHANE, CHORD-. METHANE DICHLORIDE PA80500 METHANE, dichlqrd- PAS2000 METHANE, DICHLOSODUTUDHO- PA94500 MEDHANE, IODO- XS52500 METHANE, PHENYL PG49000 iethane HMEACHLORUE PG49000 METHANE, TETRACHLORD- FS91000 METHANE TRICHLORIDE FS91000 METHANE, TRICHL3HO- l \ MJ47250 METHENAMINE PA49000 MEIHOCTiS EL64750 METHYL ACETONE IP89250 METHYL ALDEHYDE XS52500 METHYLBENZENE PA49000 METHYL BROMIDE QO78750 4-METHYL-2,6-tert-BOTYHHENOL KQ63000 METHYLCAPBIMX PA63000 METHYL CHLQRIEE KJ29750 METHYICHLDRQFOFM XT15750 l-MEIHYL-2,4-DTNITHCBENZENE PA80500 MEIHYIfNE BICHLORIDE PAS0500 METHYLENE CHLORIDE PA80500 METHYLENE dichloride IP89250 methylene OKIDE EL64750 METHYL ETHYL KETCNE PA94500 METHYL IODIDE AL31500 METHYL KETONE OZ50750 METHYL ME7IHACRYIATE EC59500 N-METHYL-l-NAPHTHYL CAH3AMATE PC59500 tKMETHYL-alpha-NAPHTHYLURETHAN TZ29750 METHYL OXIRANE T301750 METHYL PARATHICN XS96250 NP96250 4-METHYL-m-PHENYIINEDIAMrNE 2-METHYL-1-PROPANOL NP96250 FS91000 CY14000 VM84000 OZ50750 KJ85750 AF85750 KU96250 PA63000 OZ50750 KJ57750 QJ05250 XW52500 TG01750 TQ79000 QJ05250 QK92750 PC59500 KX38500 TX87500 QR59500 DA64750 CZ10500 TS01750 TC01750 KV03500 XW52500 CZ45000 CZ45000 KV03500 ED45500 CZ45000 KX24500 KX24500 CZ45500 CZ45500 2-METHYIf>RCX,YL ALOOHOL METHYL TRICHLORIDE MINERAL NAPHTHA MLT (ME MONOBOTYL GLYCOL ETHER MCNOCHLOROACETIC ACID MTNOCHLOROEDHYUNE MWOCHLORCMEHHANE MajOCITE MEOTACHYIAIE MONOMER MONCETHAfKttAMINE MOTH BAILS M3TOX M-PARA3HICN MYIAR NAPHTHAUNE NAPHTHENIC AdD, ZINC SALT 1-NAPHTHYL N-METHYLCARBAMATE NEMA NENAOCN NICKEL NITROBENZENE p-NITROQTDORCGENZENE p-NTTTCIHENYLDTMEHHYLTHICNOPHOSPHATE NITRQX 80 NORVINYL OCEACHLOHOCAMPHENE CEB ODCB OPALON QR3HCBORIC ACID QRTHODICHLOHCBENZENE OXIDCEIHANE OXIRANE PARAODE PARADlaTLORtTlfNZENE A5 ALCOAO 004242 APPENDIX A eocncmicaely sianncawr substances listed in nio33 suspected carcp)oc3ns, second edition. (c) NIOSH MT1MRPR (a) NAME(b) NIOSH NUMBER^ NAME<b) CZ45500 CZ45500 TG01750 ZH33250 SM63000 CZ45500 CZ45500 TQ35000 XS96250 SM63000 M321000 KX38500 PG49000 KX45500 AH52500 SE73500 SN15750 SJ33250 SM63000 SN15750 BW66500 DU80500 DA07000 WL36750 SJ33250 SX52500 TO01750 WM84000 DU80500 TI31SOO TI31500 TI31500 TP45500 CZ10500 XW52500 PARADCW PARAM3IH PARATHICN METHYL PARZAIE ZINEB PC3> PDB PDCB P.E.G. 400 PEUGQL GREY J PENTACHLOROPHENCL 1,3-PENIADIENE-1-CARBOXYLIC ACID PEKHUOROETHYIENE PERCHLDRCMEDHANE PEFM-A-CLOR PEFMA KLEER 50, TRISODIUM SALT FETfGLELM ASPHALT (STEAM REFINED ASPHALT) FHENACHLOR PHENOL PHENOL, PENTACHLOROPHENOL, 2,4,6-TRICHLOROPHENYIAMINE PHENYLBENZENE PHENYLE7IHANE phenyiethylene PHENYL HYDROXIDE PHENYI/EIHANE PHOSPHOROHilOC ACID 0,0-DIMETHYL 0(p-NITROPHENYL) ESTER PHOSPHOIHICN PHPH 1,3-PHTHAIANDICNE PHTHALIC AdD ANHYDRIDE PHTHALIC ANHYDRIDE PLUMBANE, TETRAETHYLFNCB POLYCHLOROCAMPHENE TQ35000 TQ79000 WL64750 WL64750 TR81000 KV03500 TX49000 TX87500 TZ29750 UH82250 AL31500 TZ29750 WG21000 UH82250 TZ27950 TR81000 W73300 QR59500 PA82000 TI31500 PA49000 VZ47250 W73300 AH52500 FC59500 W73300 W73300 W73300 W73300 WE19000 FJ59500 VZ47250 029550 WE19000 WE19000 KEI9000 POLYETHYUNE GLYCOL POLYETHYLENE TEHEEHTHALAIE POLYSTYRENE POLYSTYRQL POLYVINYL ALOOHCL POLYVINYL CHLORIDE PROPANE, l-CHDORO-2,3-EPOXYPROPANE, 1.2-DIBHOMO-3-CHLOROPROPANE, 1,2-EPCKYn-PROPANGL 2-PRCPANCNE PRCPENE OXIDE 2-PRCPENYIACRYLIC ACID PROPYL ALOCBOL 1,2-PROPYLENE OXIDE FVA QUARTZ RANEY NICKEL REFRIGERANT 12 RETARDER ESEN Rcrrox SALT SAND SEQUESTRENE TRIS0DHM SALT SEVIN SILICA, CRYSTALLINE - QUARTZ SILICA ETOUR (POWDERED CRYSTALLINE SILICA) SILICIC ANHYDRIDE SILICON DIOXIDE ( SAND) SODIUM BISULFIDE SODIUM CARBOXYMETHYL rFT.TJtmRF SODIUM CHLORIDE SODIUM CHROMATE SODIUM HYDROSULFIDE SODHW MERCAPTAN SODIUM SULFHYDRATE A6 ALCOAO 00424 3 APPENDIX A BXNOMICAT.ty SIGNIFICANT SUBSTANCES LISTED IN NIOSH SUSPECTED CARCINOGENS, SECOND EDITION. NIC6H NlWBER<a> NAMEfb) NIOSH NUMBER'a' NAME(b) WE19000 WG21000 WG21000 WI36750 WL64750 WL36750 VX484000 sodium suutde SORBIC ACID SORBISTAT STYRENE STYRENE POLYMER STYRCN SUCCINIC ACID, MERCAPTO-, DIETHYL ESTER, S-ESTER WITH 0,0-DIMETHYL PHOSPHORODITHIQATE XY56000 KX45500 KJ29750 KX45500 ES91000 FS91000 SN15750 S-TRIAZINE, 2-CHLORD-4-ETHYIAMINO-6ISQPRQPYIAMOIDTRICHLORAN 1,1,1-TRICHL0RCEIHANE TRIOOORCETHYUNE TRIOEORCEOHM TRIOHJDRCMETHANE 2,4,6-TRICHLCfRCEHENOL N085000 SUIEURIC ACID, IRCN (2+) SALT (1:1) KX45500 TRI-CEJSNE ZH52600 : SULFURIC ACID, ZINC SALT (1:1) AH52500 TRISODUM EDEDATE WJ55050 TANTALUM AH52500 TRISODUM VERSENATE QJ05250 TAR CAMPHOR YR62500 UREA HZ12250 TEREPHIHALIC AdD, DIMETHYL ESTER CP07000 VANCIDE WZ12250 TEREPHIHALIC ACID, METHYL ESTER KU96250 VC KX38500 TETRACHLORQETHYIfNE KU96250 VCM FG49000 tetrachlorcmethane AH52500 VERSENE 9 TP45500 TETRAETHYL IEAD KV03500 VINCflEX XR22750 TITANIUM DIOXIDE WL36750 VINYIflENZENE XR22750 TITANIUM OXIDE KU96250 VINYL CHLORIDE XR22750 TTTANOX KU96250 VINYL CHLORIDE MCNOMER XS52500 XS89250 TOLUENE TOLUENE, alpha-CHLORO- KV03500 AT52500 VINYL CHLORIDE POLYMER VINYL CYANIDE XS96250 TOLUENE-2,4-DIAMINE KV03500 VINYLITE XT15750 XT19250 XS52500 XW52500 XW52500 CN36750 KX45500 KX45500 KX45500 : TOLUENE, 2,4-DINITROTOLUENE, 2,6-DINITROTOLUOL TOXADUST TOXAPHENE TOXILIC ANHYDRIDE TRI TRIAD TRIASOL QJ05250 ZH52600 ZH33250 QK92750 ZH52600 ZH52600 ZH33250 PA49000 WHITE TAR WHITE VITRIOL ZINC, (ETHYLENEBIS (DITHIOCARBAMATO)) ZINC NAPHIHENATE ZINC SULFATE ZINC VITRIOL ZINEB ZYTOX (a) The NIOSH NUMBER is an alpha/numeric designation which is unique to the substance. Each synonym is keyed to this, unique number. This column includes chemical, trade, and ccnnpn names. (c) Eoanotucally significant substances are defined as those with production of 25 million pounds per year and/or significant workplace exposure. There are 99 unique substances in this list. Source! Booz-Allen & Hamilton Inc. A7 ALCOAO 004244 APPENDIX B SUGGESTED OUTLINE FOR INDIVIDUAL COMPANY COMMENTS OR TESTIMONY ON THE OSHA GENERIC CARCINOGEN PROPOSAL FOCUSING PRIMARILY ON ECONOMICS Chapter I - Company Background Description of the company, including: . Size . Products made . Number of employees . Export-import balance . Activities in protecting worker health. Chapter II - Methodology For Estimating Economic Impact The guideline is the recommended methodology that should be referenced here. Chapter III - Direct Cost Impacts of the regulation, under two scenarios: . Scenario A - Assume all your products which are on the NIOSH List of Suspected Carcinogens are in Category I. . Scenario B - Assume all your products which are on the NIOSH List of Suspected Carcinogens are in Category II. Scenario A direct costs should be estimated at three potential control levels: . a PEL level of 100 ppm for liquids and gases or 100 micrograms for solids . a PEL level of 1 ppm for liquids and gases br 10 micrograms for solids a PEL level of 10 ppb for liquids and gases or 1 microgram for solids. Chapter IV - Indirect Implications To The Company This section should cover those significant elements of economic impact on your company that are not direct compliance-cost items. Possibilities include effects on: . Use of substitute materials and processes Price . Productivity . Competitive position regarding foreign producers . Possible plant closing . Employment . Small versus large companies. Chapter V - Indirect Cost Implications To Customer Industries Using examples where possible, this section should cover effects on user industry. . Use of substitute materials and processes . Costs and prices . Productivity . Competitive position regarding foreign producers . Plant and business closings . Employment . Small- versus large-volume users. You, may also want to cover non-economic issues in your submission such as technical problems, questions of toxicological definition, and recommendations for changes to the rule as proposed. B1 ALCOA0004245 I I APPENDIX C FORMS FOR CALCULATION AND REPORTING ALCOA0004246 \ --------------- S CONFIDENTIAL FORM I COMPANY IDENTIFICATION (Complete Only If Your Company Elects To Participate In The Industry Economic Survey) Case Study Substances: Company Name: Address: Key Contact: Title: Telephone: Alternate Contact: Title: Telephone: RETURN ENTIRE QUESTIONNAIRE TO: Booz, Allen & Hamilton Inc., Foster D. Snell Division, 66 Hanover Road, Florham Park, New Jersey 07932, Attention: R. Kensicki This sheet should be used only if your company elects to participate in the industry economic survey being performed by Booz, Allen. It will be used only if follow-up contact is required for clarification. It will be kept in a locked file, separate from the rest of the questionnaire until analysis is complete. Then it will be reattached to the rest of the questionnaire and returned. For clarification and assistance in filling out these forms, contact Ronald Kensicki, Ronald Rubin or Philip Gisser, Foster D. Snell, Inc., at (201) 377-6700, Extension 260: New York City Tie-Line - (212) 924-8800. ALCOAO 004 247 CONFIDENTIAL Plant Unit (Assign Number) _ Case Study Substance FORM II STATISTICAL DATA --Each Plant Unit -- For each plant associated with the selected case study substance, complete this sheet. Case study substance: ________________________________________________________ Major products manufactured by this plant unit if the case study sub stance is not a product: ________________________________________________________ Output (1976)/units of output: _______________________ / Approximate 1976 value of ship ments from this unit (sales plus internal transfer): S Number of total employees (1976-- allocate, if necessary): ________________________________________________________ Number of production employees (1976f: List the substances potentially controlled by this regulation that are present at the plant unit and the total number of employees exposed to these substances in this unit. List the case study substance first. Substances2'33 NIOSH Registry Number2 Number of Employees Exposed Full Time4 5 Part Tinted Total TT Include all employees assigned to the specific plant unit, e.g.: . Production workers . Maintenance employees generally assigned to the area First-line, and other supervision assigned directly to that plant unit. 2. Substances and their respective NIOSH number are listed in Appendix A. Other substances for which standards may be established under this regulation are listed in the NIOSH publication, Suspected Carcinogens, 1976. 3. If an impurity, indicate its concentration. 4. Full Time - More than four hours per day, 90% of working days. 5. Part Time - More than 30 minutes per week, but less than full time. ALCOA0004248 CONFIDENTIAL Plant Unit Number____ Case Study Substance FORM III NON-ENGINEERING COMPLIANCE COST WORKSHEET -- Each Plant Unit --. Cost Element Capital Cost (1977 Dollars (Elements required for Category I or II assumption) 1. Initial monitoring cost 2. Exposure monitoring cost 3. Increased medical sur veillance cost 4. Added change rooms and showers 5. Emergency alarms 6. Respirators above current use levels 7. Personal protection equip ment above current use levels 8. Signs 9. Emergency plan 10. Recordkeeping 11. Training above current levels 12. Total, Category I or II assumption ___________________ Annual Operating Cost (1977 Dollars) ___________________ Differential First Year Operating Cost (1977 Dollars) ____ (Elements required for Category I assumption only) 13. Segregation of work areas 14. Lunchroom facilities 15. Total, Category I assumption (add lines 12,' 13, and 14) t .' ALCOAO00424`9 0> 0c u <0 QJ JJ .O <0 6 -Q z3 3 cn >i a* c T3 3 D 4-> w 4-> c CJ ITJ (0 i-H <0 cu u >Ou1' 0c1 to ac oc s$0) 4-> -P P O -H C0) O 0> 3 i-^ 44--11 OQ)' ro vt-i >O u 3 -p O' z0) U to 4J 4J t0 to O PU (U0i Em 0>| <0 C <TJ <4-> H <0 l -P U MC0) O0a) 1r* r Q) <4-1 U ' u n *h a o > to o </> </> FORM IV ENGINEERING- - CONTROL COST WORKSHEET Each P la n t U n it -- Assume one b a r r e l o f o i l i s e q u iv a le n t to 6 m illio n BTU s o r 567 k ilo w a t t - h o u r s .' ALCOA0004250 FORM V SUMMARY DATA DIRECT COSTS AT PLANT U N IT LEVEL-- Each P la n t U n it -- C a p ita l re la te d c o s ts in c lu d e : D e p re c ia tio n a t 10 p e rc e n t. In te r e s t a t 8 p e rc e n t, M aintenance a t 5 p e rc e n t. Taxes and Insurance a t 2 percent o f c a p ita l c o s t. p <0 O' 1 Q1 C P M Jm .H CO Li 01 (0 P P 0a--t3 4<p-4 H p P <p0 oCO P C p 0) u > *H Q IIP Q, 0 (u O M OP CO w oC >* *P P <0 op ic Pa <0 i o co 3 p C -p Oai 3cr Po E3 Cc 4a1 -*pP CoO JJ.H o w < O <o u fljp cn L> ~ u 4 P w 0 p ao 01 R3 -P P <4-1 -H -p CD CO <0 (0 P 41 (ft L O > ~ p C P 0) u M C a up a P CO O ao >iO E *p P fU P rH o tJ p a CD 1 O' CO 0*p o E 3 P C -P 0) 3 0 3 C 0) *H CO P CT P M c a-p o njp U in < O CD U ~E Eo a<H a p ^0 p-4 ID CO JJ P H CO ao (D u o P -- t3 <0 o P *H 0^ ao 1 41 C p >< -H CO 01 CD jj P cO W 4-1 -H JJ <0 CO > ^ Mj JJ CO p O P CO P C P 4> L> a a) -p a MOE C b- o mo >1*0 P -H --1 p -H O' -P CD 1 O' CO o3oa O' cr p E ai -h u a JJ P P (ft CD E w L> ~ u co o < 41 c u *p x *p 41 <0 P v> P *H P ID P P P (0 P CO p q c0)-uh oai uo PC c a, o >vH0 Po JaJ Jo0J) 3(01 CD CO U co 1 O' CO C3. pD-HC J(fJt <c oa jcjo uo i--t PCD P(0 P ao CD L* O II P3 < ip E-< Z w a M Cu Z o u oO oi ^u> 4c) p 41 ,, 4C) MH *HO' M ?41. 2u CO O fa* z~ * u0 r-i M *-( P (0 CO Oo 4Pc1 Ocp ^c^ p41 >M 4) cE *H P OC [0i. u^ CpO CO P po 3 C/3 tO3J 4p1 a> p 3Li O p -a a0) OOCO 4*00JJ3 t03) C0uO CO iOp' P C01 <0 0u <0 3 (0 p C(0 4e1 4i eP oP fP C c CD P <4p-1 cn >i p 41 C c 0 >41 41 p O 41 O O<0 Cco CtO .rpp co 41 CO pH apP am a CD CN fC 41 Q p 0 s a u ^ v p t ii O p a 41 pp p *p t3 C 3 iH P PCO cCo O o wg>--aji 4J w O V Aaa 6 > uiQ Eaa -( ao <T5 V) >-- ocr Hc3r ow s3a, *fl>H*0*H0101 uw e< IlH 4J JJ IQ V) -aH I^fHt) cC CO m & cHi u0 ; a *i o' :o u *HfHl >< 4J i*4 4-> cn u o oh oc> a-nh aOv u cD 'H* fat) c ao a(Q uo o J1HJ0 uaic uo: a< S' hin i4a>1i UO b. o M n CO ^ rsi OUft> ><B O ^^ a mo o"* -- Ift c XU ALCOA0004252 (A) R eplacem ent v a lu e o f p ro d u c tio n u n it in i t s p re s e n t fo rm (a ssu m in g id e n tic a l p la n t ) . (B) T o ta l c u rre n t fix e d and v a ria b le m a n u fa c tu rin g c o s ts in c lu d in g d e p re c ia tio n and m anagem ent c o s t, (C ) H b u t e x c lu d in g is to ric 5 year d a i v s e t r r a ib u ge ti p on re - , ta a x n dp r so ef li lti ng on , a g p ene p lic ra l ab l a e n d s u a b d s m ta i n n c is e tr o a r t io u n n i t e . x p e n s e s . (U u e X (C 01 4-1 A03) Z CO X >i H T3 C3 9X CO X C 0) Id CO pH (0 aa *a D e* CO I w cn < o sEh > 1 Mi-} cn Z w< HK oK a E* U U Uw da e-i < 6j & U oK t CL. Z UM < <K u< < cn XM 3 zw 2u oz tu < El k cn O C3Q u cn O z o utd J < z Mo MEh a o H M td cc id ox a id 0) ao* o CO 3 i-l 0) u CO O' C 3 c Id 0 z X o *H CO 4J c <d oo CQ H *H X X pH n id a 0 o> a U -i-l |Q pH 0 &X 0) a id 0) id x id CO X X x a) c 0 * cj in 01 *m co c cj X i&d o>>i 0) a 0) CJ c <d 4J CO A 3 CO A id C X id o a CO Z E 0) 0) 4J o cj w id oX 0) H o> 0) X x o o 0) c 01 0 p4 XX 3 X p4 X CO A 3 01 X \ o to x <n- *0 0) at .* aid xid X 0 01 X X X 0) 0 CJ 0) 0) C >4 0 X c id .0 fw 3-- . co *0 3C o 3 p4J 01 \ 0) O- X W W 01 X hj id XU -- 01 3 01 C 01 X 4-> *r-- c- owe H --. id ai X 3 0, X 3 0 >*x id > X 0) X O 4-1 3 <0 01 Cl 'O f** C `H X CJ 0) X X WCOCO>l4--'OJ<dC cn oi 3 X XX A 3 <d o > a 3 x ^ *0 id a> 301UH4lOE\ Ox xx X om XX an Oi x E 0 c xe CO -H CO T3 CO A O **> -- ro fO O > to *o oi 01 \T3 X 01 00 0 0) X X CJ CQ X a0 01 01 X e 3 0> 'O > X 0 0 0 X 01. id 3 3 u >% X CO X x o *o id XO rH 0) X 01 X X W 01 O' M M Id 3 X CidO Oc 3a -*Xh X CO X *H 0) -H H-> 01 3 pH 3 4J X 3 4J CP 4J OC0OXO30>"- X 0 O X C to 4-> X c CJ *0 XX X3 01 c X X XX 0 wa 01 u p^ X CO 3 O 3 -H o H H *H O TJ CO o 0 X 4J Id O CO 4J to C H W 0 > c X 3 01 01 O x o CO X o) X -H ax u oco co -hhj x 3 oei xa E oe o o CJ 01 01 X> td <0 3C w XX X X 3 O -h c co X 01 4J k CO X 3 3 *0 M t> O 0) XX jQ H 4- Id ill Ohh fl 3 fl> 4J > CO H >1 3 M-H 0 X cx CaJi iud Wnj H<c O-h O -H X O X CO -H to HIU O 3 O M x O CO CO oi -1 id o hj a co WHO *0 <d 0} 01 aa x T3 a H >,X Id -H O m c a X 01 pH CJ E X CJ X x xJ H *H XX j io pH ai X x j* o a x Id CJ 1*4 5 X Id *H 01 a ax 3 aa H C Cl (0XHH Id 4-1 X <4 <d x O> e x0e*xx0q Ex 0CH1O X0(01 id id KK CJ XX01 01 0id X xO X 4J iXd XC X3 m a cQj1 xX 0C1O " (0 3 Q) KUO X X cr X Xid Xid 5 id OX zzz 3CO 30O1' <X id X X Xid z X CO X X QO 3a Xo a b c d X IN X 0) C3 Oo paH id c fV. O' C 01 0) *0 0 X 0) 01 X a ~o X X 3 0> OX O0 0?) -- 0> a cj 01 c pH (0 id x n co X OH 3 o CO tfp a) OX rH X CX 0 H 01 XX 3 Id XX H X *0 CO pH X3 3O to Z X 01 Cto CcJ cj id -X X X to H X C3 S' cn pH C0 CQ H Xx X x fw H --i 5 44 W OM 01 CO CO >1 id m Jh 01 01 0 u to O' 0 3 0) CX H pH <d 01 001) ^o oX H S U3C a o ai > O' xo 0oc 0 -H p0H1 10 uCJ > c id 01 o o Xo Xid * id Xid aCO 3 X X cn Z8 T3 C 01 0 X -H id x co 'OH' <d CO 01 01 X 'O id H 01 *o X 0) 0u) 01 O' C fH UH pQH1 H x 3 -x O' co oi id U 01 CO *0 X 01 X ^ 3 01 co cn > CO 01 QHH pH C 01 X X in to X 0*1 0?1 H O *0 pH 0) X x <0 oi id 'o x X CX id -o x o XwX O3 >1 w xc id o 0) X -H Cl O X c a io Id 6 x X 01 X CO fH C X 01 X >. CJ woe co CO 01 o H O' Lc x 01 UJ 0) o ,x feaj T3J 0 01 ex co <d x 01 TJ xo co c 3 id co 0 01 1 Xc Xo 300 0 o* >1 01 O' _c O id *h VOX 01 CO 01 cs e o e -h _ O' X O' c O o 01 io c xX X O 01 id x x fxe iOd Xm 01 X <d 0 X c X 0 01 X CO id X o 3 id a *0 c id E a> *0 O' e r. to f4 01 w x 01 id x co iidn X fQ X 3 id S3 cc <d e cn id to CO Ox wo O' x O' e H C X c oc XO XX ex 0e rn lo v> </> ce <0 Id X XX CCOQ CtoO 01 01 -3 1-3 01 M Q> X id 3 0 id X 0 o fv- Xc x0) xid XX 0a X 01 u X 01 X X CO X 01 10 x0 < CJ O' to cx Xc E id 3x to a cn <a u H m- xai xx oi xe 3x X CJ co id x x ai 3X Cid x3 e CJ id co x id 3 >w O id 0) co OX X Q1 X> 0 0) XX CJ o 3X x 0c xo a cj ex id x xai x* x cn cn ee 5O 0X *o X id 'O x C3 id O' oi CQ X X XX x id X Cx XE *H xm xm01 oe x XX 3 xX id X X >i Cx ai a xe oo ao co 01 3 01 E cn CO 3X O 01 >1 X 3 0X T3 CJ id 01 X 0x) 3e O' <d 01 E *0 CJ Xx QX X CO 5E OO *3 (/) Z w o u K U X D ti er: c h cn u o < o- a u c Q ALCOAO 004253 CONFIDENTIAL (FILL OUT THIS PAGE ONLY IF YOU PURCHASE OR USE THE CASE STUDY SUBSTANCE IN THIS PLANT UNIT USE FORM VII IF YOU MANUFACTURE IT) Plant Unit Number____ Case Study Substance FORM VIII ADDITIONAL ECONOMIC EFFECTS - RAW MATERIALS - Each Plant Unit - 1. Do technically feasible substitute raw materials (or alternate Yes_________ No approaches) exist for this substance? 2. Describe 3. If you switched to this alternative, what would be the effect a. Total raw material cost increase (decrease) $/year ____________ b. Other production cost increase (decrease) (exclude depreciation), $/year ____________ c. R&D costs to substitute, $ ____________ d. Capital Investment required $ ____________ e. Other costs, e^>lain, Capital _________________________________________________________________ Annual Differential First Year_________________________________________________________________ 4. What percent chance exists that increased costs of compliance with Category I regulation would result in your closing the unit rather than complying? ______________________________ % a. If this occured, what would be the effect on overall employment? Number effected Percent of employees in this unit ______________________________ ______________________________ 5. How would a 10% price increase affect your use of this substance, assuming no parallel increase in competitive substances? 6. What action would you probably take if this substance were to be designated as a "suspect carcinogen" (Category II) and standards were issued requiring the actions described herein? 7. What action would you probably take if this substance were to be designated as a "confirmed carcinogen" (Category I), and an Emergency Temporary Standard were issued requiring immediate compliance plus later engineering controls to reduce concentrations to the lowest level feasible? 8. What actions would you take if use of this substance in this application were to be prohibited?_________________________________________ 9. What do you feel wi),l be the effect of the proposed regulations on productivity in your plant under the three assumptions below: a. Increase in production workers, % of production workers in this unit b. Increase in non-production employees, %. of non-production employees in this unit c. Decrease in production, % of production d. Change in productivity, (production per employee), % change Assume Category II Assume Category I Difficult Extremely to meet Difficult to Requirement Meet Requirement _____________ _____________ _______________ ' _______________ ALCOA0004 254