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OSHC 23-1 CHEMICAL MANUFACTURERS ASSOCIATION Minutes of Meeting Occupational Safety & Health Committee Chemical Manufacturers Association General Conference Room 2501 M Street, NW Washington, DC 20037 Wednesday March 31, 1982 9:00 a.m. - 3:00 p.m. Attendees Thomas Evans (Chairman) John Dougherty, MD Ben Fay (for R. Hoots) Warren Ferguson Thomas Hamilton (for H. Eschenbach) Patrick McNulty James Pickett (for J. Wheeler) Jerry Robertson Arthur Sheldon Ronald Van Mynen Ned Walters Monsanto Company Celanese Corporation ICI Americas Incorporated Allied Corporation W. R. Grace & Company Rohm & Haas Company Standard Oil Company (Indiana) Exxon Chemical Americas M & T Chemicals Incorporated Union Carbide Corporation E. I. du Pont de Nemours & Company Members Absent Joseph Caporossi Donald Hillman, MD Charles Richards Charles Ryan, MD American Cyanamid Company Diamond Shamrock Corporation Gulf Oil Chemical Company Sun Company Task Group Leaders Present Carl Bohl Robert Brant Alfred Capuano Albert Greene (for C, Richards) Maurice Johnson, MD Jerry Schroy James Trexel Chris Waisanen Monsanto Company ICI Americas Incorporated ICI Americas Incorporated Air Products & Chemicals Incorporated BFGoodrich Chemical Company Monsanto Company E. I. du Pont de Nemours & Company ICI Americas Incorporated CMA Staff Present Christopher Cathcart (part time) Rita Comotto (part time) CMA 060625 OSHC Minutes March 31, 1982 Page 2 CMA staff Present (Con't) Milton Freifeld Patrick Joyce Christopher Nolde Janet Steel (part time) Gordon Strickland Charles Van Vlack (part time) Luncheon Guest Speaker Patrick Tyson Director State Plans OSHA ACTION ITEMS The Health Standards Task Group will develop a recommended CMA position on the1Miller Bill (HR 5735). It deals with compensating employees for certain occupational illnesses based on a set of presumtions. It also provides a means to include other illnesses in the future. Lammot DuPont Safety Awards will be presented at the CMA Annual Meeting to Velsicol Chemical Corporation in over 2,000,000 man hour category, and Dixie Chemical Company in the smaller company group. Certificates will be sent to the runners-up in each cate gory, Hooker Chemical Company and NIPRO, Inc. respectively. CMA will submit comments to OSHA in response to its ANPR of January 5, 1982, on the carcinogen policy. The reproductive hazards work group will proceed with plans for a two-day conference this fall, on the management of reproductive hazards in the workplace. CMA will develop comments on a preliminary draft of the expected OSHA Notice of Proposed Rulemaking on Access to Records, The respirator work group will develop a test to measure contami nants inside and outside of a respirator, then try to generate data demonstrating the efficacy of such equipment. CMA will forcefully point out to the Office of Technology Assess ment, shortcomings of their recent test questionnaire on genetic screening. CMA 060626 OSHC Minutes March 31, 1982 Page 3 CMA will comment favorably to OSHA on their use of personal sampling devices during inspections (47 FR 6529, Feb. 12, 1982). CMA will submit the revised ANSI Z 129.1 Standard on Labeling to the Institute for publication after dealing with the few re maining objections to it. The Worker Education Task Group will make minor changes in their questionnaire and send it to CMA member companies. NIOSH has made all the changes we requested in their protocol for studying control technology. CMA will make a renewed effort to convince member companies to make available to the Institute, data on successful sealing devices. CMA will attempt to have NIOSH verify their data before writing a report on the Second National Occupational Health Survey (NOHS, II) now in progress. ******** The meeting was convened at 9:00 a.m. 1. Minutes of the Last Meeting January 20, 1982 Minutes were approved as distributed. 2, Legislative Update Mr. Nolde reported that in a recent OSHA oversight hearing by the House Labor Standards Subcommittee, Mr. Auchter did an excellent job of describing the Agency's activities. Even Chairman Gaydos complimented Mr. Auchter for his forthright presentation and for bringing a tense of professionalism to his Agency. At another OSHA oversight hearing by Congresswoman Collins' Manpower and Housing Subcommittee, the role of the Office of Management -md Budget in the regulatory process was scrutinized. The Committee will develop a proposed CMA position on the Miller bill (HR 5735). It establishes a federal compensation system for employees disabled by occupational illness resulting from workplace exposure to as bestos or uranium ore. The proposed legislation sets up criteria for es tablishing occupational exposure as a presumtive cause of illness. Proof of cause and effect would not be required. The bill also provides a mech anism for covering other occupational diseases in the future. Committee members agreed to furnish Mr. Nolde names of independent medica_ scientists for him to recommend to Congressional minority staff as possi.ole witnesses on occupational disease causal relationships. CMA 060627 OSHC Minutes March 31, 1982 Page 4 3, Task Group Reports 3.1 Safety Statistics - This year's winner of the Lammot DuPont Safety Award in the over 2,000,000 man-hour category is Velsicol Chemical Corporation, and Hooker Chemical Company is runner-up. Among the smaller companies, Dixie Chemical Company is the winner and NIPRO Inc. is runner-up. Certificates, yet to be designed, will be sent to the runners-up. A computer program to handle occupational injury and illness reports (OIIR) is being developed to replace manual computations. The task group's telephone survey of member companies, stress ing new incentives in the award program, has increased participa tion by 50% . The Committee approved the following change in the rules for the Lammot DuPont Safety Award Program: If the identity of a member company changes by onethird or more of the exposure hours for the previous calendar year, the company should submit recalculated injury statistics for the previous four (4) years for DuPont Safety Award purposes. Such changes may in clude, but are not limited to, acquisitions, divesti tures, reorganization, relocation of a major division, etc. The change would not include changes in actual labor force due to economic factors. 3.2 Health Standards OSHA Carcinogen Policy Dr. Johnson reported that his work group has prepared a response to the Agency's Advance Notice of Proposed Rulemaking (ANPR) on this subject. Committee members were asked to com ment promptly so that CMA's submittal can be forwarded by the April 5 due date. Reproductive Hazards The work group recommended that a two-day conference be held in the fall on the management of reproductive risks in the workplace. The Committee agreed, without dissent, that the work group should proceed with the planning for this function. Access to Employee Records OSHA has released a preliminary draft of its Notice of Proposed Rulemaking (NPR) on this regulation. A work group CMA 060628 OSHC Minutes March 31, 1982 Page 5 has been organized under the leadership of Harry Eschenbach to draft comments on it. Hearing Conservation Amendment (HCA) Dr. Bohl summarized recent CMA testimony given at an OSHA hearing on this matter. After the Agency has taken action on the HCA to the Noise Standard, it is expected to deal with the permissible exposure level. Respirators The Committee approved the following portion of the work group1s charter: Develop data which reflect the efficacy of respirators in protecting against work place exposure. Develop a proposed CMA position regarding the role of respirators relative to engi neering controls in protecting against workplace exposures. The Committee felt the charter should be broadened to in clude expected reopening CFR Paragraph 1910.134 Respiratory Protection. Dr. Dougherty described the work group's effort to develop guidelines for generating data to support industry's contention that respirators are effective. Genetic Screening Questionnaire The Committee believes that a draft CMA letter to the Office of Technology Assessment regarding their questionnaire on genetic screening should be more strongly worded. Personal Sampling Devices The Committee concurred with the Health Standards Task Group's recommendation that CMA respond favorably to OSHA's request for comments on their Interpretive and Procedural Rule (47 FR 6534, Feb. 12, 1982) on the "use of personal sampling devices during inspection". 3.3 Safety Standards Model Performance Standard Mr. Brant reported that the response to OSHA's ANPR on Subpart H - Hazardous Materials (46 FR 7692-7699, Jan. 23, 1981) will be used as a vehicle for presenting a model stan- CMA 060629 OSHC Minutes March 31, 1982 Page 6 dard. This process may take several months but as por tions of it are prepared, they will be discussed with the Agency, Balanced Performance Standard Mr, Walters presented a slide talk prepared by the Safety Standards Task Group on this subject. It has been given to a variety of audiences and additional opportuni ties were solicited to explain our position in this way. Voluntary Programs Mr, Brant reviewed CMA comments submitted March 15, 1982, to OSHA on their proposals in this area. In CMA's opinion, the Agency's proposals delegated too much author ity to labor/management safety committees. We also recom mended that these programs be aimed at workplaces with poor safety records rather than those with injury rates below the national average. Chemical Protective Clothing Mr. Brant reported on the task group's recent visit to Morgantown, WV, where NIOSH conducts tests on protective clothing and equipment. He also discussed the newly estab lished Safety Equipment Institute, which certifies brand name items if they pass SEI tests. The task group will look into the composition and procedures of this newly es tablished institute. 3.4 Worker Education Task Group - Mr. Capuano reviewed the Committee's responses to the task group's questionnaire on worker education. The Committee agreed that after some minor changes the questionnaire should be sent to CMA membership. 3.5 OSHA Reform - Mr. Van Mynen solicited additional suggestions from the Committee. He is reorganizing this task group which will draft a CMA position regarding suggested changes in the OSH Act. 3.6. ANSI Z 129.1 Revision (labeling) - The canvassing procedure for the proposed revision of the ANSI Standard for the Precautionary Labeling of Hazardous Industrial Chemicals is nearly finished. Almost all objections have been overcome and the task group is working on the remaining few. Mr. Trexel expects ANSI to publish the final version of the revision before the end of this year. CMA 060630 OSHC Minutes March 31, 1982 Page 7 3.7 Liaison with Technical Societies - The Committee responded well to the request for nominees to represent CMA on key committees of NFPA and ANSI. Representatives will be selected soon and the others thanked for their efforts. ANSI Committee A 2 on Protec tion of Head, Eyes, and Respiratory Organs, has been broken up intothree separate groups. Mr. Van Mynen questioned whether we want to consider all three of these as key committees on which we should be represented. 3.8 Future issues - A highlight of Ms. Waisanen's report was a pro posal for sharing of information on product hazards. The task group is considering ways this can be done. 3.9 Process Safety Analysis - The Committee unanimously approved the following charter for this task group: Review and evaluate the systematic approaches to process safety analysis currently used in the chemical industry. Provide information to the membership on the results of this review and describe systems available. The task group has started an informal telephone survey to determine the state-of-the-art among members. 3.10. Ergonomics - Mr. Robertson reported on the group's visit to NIOSH and said the task group will also follow OSHA activities regarding ergonomics and stress. 3.11 NIOSH Control Technology Study - Mr. Schroy said that NIOSH had been extremely cooperative in modifying the protocol for their sealing devices study. We now have the obligation of helping them get the data they need. 4. Lunch Guest Speaker Mr. Patrick Tyson, OSHA Director of State Plans, gave an excellent presentation on the "new federalism" and how state and federal agency activities mesh. 5. Second National Occupational Health Survey (NOHS II) NIOSH is continuing with this activity despite industry objections. It was agreed that we should try to get NIOSH to verify some of its data before reporting it. 6. Informing Physicians Dr. Dougherty is investigating what role CMA might play in getting information about occupational medicine to family physicians who work part time for industry. CMA 060631 OSHC Minutes March 31, 1982 Page 8 7. Special Programs Advisory Committee Mr. Ferguson reported that two new special projects had been started recently, one on ethylene dibromide and the other on toulene diamines. In addition, SPAC recently reviewed the projects on arsenic and ketones. 8. International Advisory Group Mr. Sheldon reported this group is dealing with a number of regulatory initiatives, largely from Europe, on health and safety. 9. Regulatory Impact Special Committee (RISC) RISC is developing a CMA approach to risk/benefit analysis. They will work with individual committees on specific projects. 10. Informational Meeting OSHC will hold an informational meeting April 29 at the Twin Bridges Marriott In Arlington, VA. Flyers will be distributed soon. 12. Next Meeting & Retreat The next OSHC meeting will be held in Charlottesville, VA, May 24, and the Committee's retreat will be on the following two days. The meeting was adjourned at 3:00 p.m. Minutes Subject to Approval MF:mjm 4/13/82 cc: G. Cox G. Strickland R. Schumacher P. Joyce C. Nolde Milton Freifelcr Associate Director Health, Safety and Chemical Regulations CMA 060632