Document wgobQDvER1eDyo5102K1JRdgV

Vista Chemical Company Lake ChaHes VCM Plant VCM Plant Rd.,P.O. Box 605 Westlake, Louisiana 70669 Phone (318)494-5000 CONFIDENTIAL February 17, 1986 Mr. L. S. Paxton Vice President Harmony Construction Corp. P O Box 2505 Sulphur, LA 70663 Dear Mr. Paxton: This letter is a followup to our meeting on February 6, 1986 related to an unexpected release of Vinyl Chloride Monomer that occurred at the plant on February 5, 1986. Your Field Superintendent has identified six of your employees who were working in an area south of Block II. These employees were potentially exposed to Vinyl Chlo ride Monomer in excess of the short term exposure limit of 5 parts-per-million for 15 minutes, set forth by the Occupational Safety and Health Administration (OSHA), in Part 1910.1017 - (Vinyl Chloride Standard). Per our discussions, you have indicated that your employ ees have been verbally notified related to the potential overexposure and have reported no acute symptoms of overexposure. I have attached a copy of the OSHA Vinyl Chloride Standard (1910.1017) for your review. Two sections of the Standard which may be applicable to your situation include: Section 1910.1017(k)(3), and Section 1910.1017(N)(3). Other sections of the Standard may be applicable, and I will be happy to provide you with any information I have that will help your company comply with the standard requirements. Steven R. Ashby Safety Director LC VCM Plant br cc: RAC-WLM vcm appe;;dtx Page 24 of 32 You, as a contractor, should also be aware that the Occupational Safety and Health Administration (OSHA) has put into effect regulations which apply to workers exposed to Vinyl Chloride Monomer (VCM) in the course of their employment. These regulations were published in the Federal Register, 29 CFR 1910.1017 and became effective April 1, 1975. A copy of the Federal Standard is attached for your information. As you are aware, Vista Chemical Vfestlake, Louisiana VCM Plant is a producer of the material covered in the regulation and therefore is subject to all provisions set forth in the standard. Co., Pursuant to a contract between Vista and your company, you are required to abide by all rules and regulations of Federal, State or local governments as well as those standards set specifically by Vista related to work done in their plant locations. The attached regulation should be considered effective irmnediately by your company and indicated action steps accomplished as soon as possible. Particular attention should be paid to the sections pertaining to medical surveillance, personnel monitoring, respiratory protection, and recordkeeping. We will be happy to discuss any aspect of this regulation with you and furnish you in formation related to medical doctors and laboratories used by Vista related to the medical surveillance requirements. In addition, contractural arrange ments related to personnel monitoring and respiratory protection are available if you so desire. 000006243 CUlH OCCUPATIONAL SAI'KTY AND HEALTH lOin.ifJlfifirKD STANDAKDS AND INTUUTJtUTATlOt 60 provided. The examination shall in clude the personal history of the em ployee, family and occupational back ground, including genetic and environ mental factors. (if) Authorized employees shall be pro vided periodic physical examinations, not less often than annually, following the preassignment examination.. ords of all such medical examinations. Records shall be maintained for the dura.tion of the employee's employment. Upon 'termination of an employee's cmjdoyment, .'including retirement or death, or in the / event that the employer ceases business without a successor, records, or notarized / true copies thereof, shall be forwarded by I registered mail to the Director. (iH) In all physical examinations, the / examining physician shall consider^ whether there exist conditions of in- / creased risk, including reduced im-f_ munological competence, those undergoing t re ament with steroids or cytotoxic agents, pregnancy and cigarette smoking.- (If) Records required by this paragraph shall be provided upon request to au thorized representatives of the Assistant Secretary or the Director, and, upon re quest of an employee or former employee, to a physician designated by tiie employee or to a new employe-]'. (2) Records. / f (1) Employers of employees examined pursuant lo this paragraph shall cause to be maintained complete and accurate rec- (iff) Any physician who conducts a medi cal examination required by this para graph shall furnish lo the emnlovcr a statement of the employee's suitability fur employment in the specific exposure. 19 75 rO* . :i qO li7J -_-_--_--_--rV?t-l!'fvJr.UpipW.lf:(MwivlbL, (a) Scope ond application. {1) This section includes requirements for the control of employee exposure to vinyl chloride (chloroethene). Chemical Abstracts Service Registry Mo. 75014. (39 F.n. 4l$i8, December 3. 1974.J (2) This section applies to the manufacture, reaction, packaging, repackaging, storage, handling or use of vinyl chloride or polyvinyl chloride, but docs not apply to the handling or use of fabricated products made of polyvinyl chloride. (3) T):is section applies to the transportal ion of vinyl chloride or polvviuyl chloride except lo the extent that the Department uf Trans portation may regulate the hazards covered by this section. (b) Definitions. vinyl chloride of 0.5 ppm averaged over an S-hour work day. (2) "Assistant Secretary" means the Assist ant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor, or hisdesigneo. (3) "Authorized person" means tiny person specifically authorized by the employer whoso duties require him to enter a regulated area or any person entering such an area as a desig nated representative of employees fur the purpose uf exercising an opportunity to ob serve monitoring and measuring procedures. `'Director" h'.eans the Director. National Institute for Occupational Safely and Health, U.S. Department uf Health, Education, and Welfare, ui' his designee. (5) `'Emergency'' means any occurrence? such (1) "Action level'' means a ooneentrat ion of ns, bisl not limited lo, equipment failure, ur Olmucc 10 642. 1 1 l!ltUf)J7(1j5> CUH 000006244 Page 26 of STANDARDS AND INTCRPRCTATJONS OCCUPATIONAL SA1T.TY AND IIKALTH operation of a relief device which is likely to, or docs, result in massive release of vinyl chloride. (6) "Fabricated product" means a product made wholly or partly from polyvinyl chloride, and which docs not require further processing at temperatures, and for times, sufficient to cause mass melting of the polyvinyl chloride resulting in the release of vinyl chloride. (7) "Hazardous operation" means any opera tion, procedure, or activity where a release of either vinyl chloride liquid or gas might be ex pected as a consequence of the operation or because of an accident in the operation, which would result in an employee exposure in ex cess of the permissible exposure limit. 133 F.H. 41848, December 3. 1074.] (8) "OSHA Area Director" means the Direc tor for the Occupational Safety and Health Administration Area Office having jurisdic tion over the geographic area in which the employer's establishment is located. (9) "Polyvinyl chlorine'' means poiyvinyl chloride homopolymer or copoiymcr before such is converted to a fabricated product. (10) "Vinyl chloride" means vinyl chioride monomer. (c) Permissible exposure limit. '(1) No employee may be exposed to vinyl chloride at concentrations greater than 1 ppm averaged over any S-hour period, and (2) No employee may be exposed to vinyl chloride at concentrations greater than 5 ppm averaged over any period not exceeding 15 minutes. (2) Where a determination conducted under paragraph (d) (1) of this section shows any employee exposures, without regard to the use of respirators, in excess of the action level, a program for determining exposures for each such employee shall be established. Such a program: (i) Shall be repeated at least monthly where any employee.is exposed, without regard to the use of respirators, in excess of the per missible exposure limit. (m} Shall be repeated not less than quar terly where any employee is exposed, with out regard to the use of respirators, in ex cess of the action level. (iii) May be discontinued for any employee only when at least two consecutive moni toring determinations, made not less than 5 working days apart, show exposures for that employee at or below the action level. (3) Whenever there has been a production, process or control change which may result in an increase in the release of vinyl chloride, or the employer has any other reason to suspect that any employee may be exposed in excess of the action level, a determination of employee exposure under paragraph (ti) (1) of this sec tion shall be performed. (4) The method of monitoring am! measure ment shall have an accuracy (with a confidence level of 05 percent) of not less than plus or minus 50 percent from 0.25 through 0.5 ppm, plus or minus 35 percent from over 0.5 ppm through 1.0 ppm, and plus or minus 25 percent over 1.0 ppm. (Methods meeting these accu racy requirements are available in the VNIOSII Manual of Analytical Methods"). (3) No employee may be exposed to vinyl chloride by direct contact with liquid vinyl chloride. (5) Employees or their designated represen tatives shall be afforded reasonable opportu nity (o observe the monitoring and measuring required by this paragraph. (ci) Monitoring. (c) Regulated area. (1) A program of initial monitoring anti meas urement shall bo undertaken in each estab lishment to determine if there is any employee exposed, without regard to the use of res pirators, in excess of the action level. l3io.ini:(ci(t)(ii 6*12. (1) A regulated area shall be established where: (} Vinvl chloride or polyvinyl chloride is manufactured, l eaded, repackaged, stored, ^ handled nr used; and C'lintiKC JO CUH 000006245 OCCUPATIONAL SAl'UTY AND ULALTH Page 27 of 3' 1010.]017ffH IKii) STANDAUDS AND INTUtrRllTAXIOMS (it) Vinyl chloride concentrations arc in ex cess of the permissible exposure limit. (2) Access to regulated areas shall be limited to authorized persons. A daily roster shall be made of authorized persons who enter. (f) Methods of compliance. resentatives of the Assistant Secretary and the Director. Such plans shall be updated at least every six months. (g) Respiratory protection. Where respiratory protection is required under this section: Employee exposures to vinyl chloride shall be controlled to at or below the permissible expo sure limit provided in paragraph (c) of this sec tion by engineering, work practice, and personal protective controls as follows: (1) Feasible engineering and work practice controls shall immediately he used to reduce exposures to at or below the permissible expo sure limit. (2) Wherever feasible engineering and work practice controls which car. be instituted im mediately are not sufficient to reduce expos ures to at or below the permissible exposure limit, they shall nonetheless be used to reduce exposures to the lowest practicable ievci, ami shall be supplemented by respiratory protec tion in accordance with paragraph (g) of this section. A program snail be established anti implemented to reduce exposures to at or below the permissible exposure limit, or to the greatest extent feasible, solely by means of engineering and work practice controls, as soon ns feasible. (3) Written plans for such a program shall be developed and furnished upon request for examination and copying to authorized rep- (1) The employer shall provide a respirator which meets the requirements of this para graph and shall assure that the employee uses such respirator, except that until April 1, 197G, wearing of respirators shall be at the discretion of each employee fur exposures not in excess of 25 ppm, measured over anv 15minute period. Until April 1, I9TG, each em ployee who chooses not to wear an appropriate respirator shall be informed at least quarterly of the hazards of vinyl chloride and the purpose, proper use, and limitations ofrespiratqry devices. MO r.n. 13211, M.irch 23, lft?;.] (2) Respirators shall be selected from among those jointly approved bv the Mining En forcement and Safety Administration. De partment of the Interior, ami the National In stitute for Occupational Safety and Health tuider the provisions of 30 CFH Part 11. (3) A respiratory protection program inerting the requirements of 1010.13-5 shall be estab lished and maintained. (4) Selection of respirators for vinyl chloride shall be as follows: ClumiH- III 642.1 13 CUH 0000062A4 iminntKxn Page 23 of 32 - jyifUOlTfirXI) OCCUPATION'A I. SAI'IITY AND nUALTII STA.NDAJtD.S AND INTbRrKLTATtONS Atmnsjihcric concentration of vinyl chlonde Rcquii'cd apparatus (i) Unknown, or above 2.C00 PPm.........................................Open-circuit, self-contained breathing apparatus, pressure demand type, with fuil facepiece. (ii) Not over 3.CC0 ppm ___ (A) Combination type C supplied mV respirator. pressure demand type, with full or half facepiece, and auxiliary self-contained air suppiy; or (B) Combination type C, supplied air respirator continuous flow type, with full or half facepiece and auxiliary self-contained aitsupply. (ill) Not over 1,000 ppm .... Type C, supplied air respirator continuous flow type, with full or half facepiece, helmet or hood. (iv) Not over 100 ppm...........(A) Combination type C supplied air respirator demand type, with full facepiece, and aux iliary self-contained air supply; or ' ' (B) Open-circuit self-contained breathing ap paratus with full facepiece, in demand mode; or (C) Type C supplied air respirator, demand type, with full facepiece. (v) Not over 23 ppm.............(A) A powered air-purifying respirator with hood, helmet, full or half facepiece, and a canister which provides a service life of at least 4 horns for concentrations of vinyl chloride up to 23 ppm, or (B) Gas mask, front- or back-mounted canister which provides a service life of at least 4 hours for concentrations of vinyl chloride up to 23 ppm. (vl) Not over 10 ppm.............(A) Combination type C supplied-air respirator, demand type, with half facepiece, and aux iliary self-cuntaincd air supply; or (B) Type C supplied- air respirator, demand type, with half facepiece: or ._ (C) Any chemical cartridge respirator with an organic vapor cartridge which provides a service life of at least I hour lor coueenl ra tions of vinyl eliloiide up to It) ppm. l!IU:.lill7<i;KI) Ian k.ii. -ims. iwmiier a. iutj.i 642 114 CUIH 000006247 Clo.n^e 10 Page 29 of 32 OCCUPATIONAL SAI-KTY AND Ill-ALTH ioin.ini7(ir)(5: STANDARDS AND tN'Tr.kmKTATlONS (5) (i) Entry into unknown concentrations or concentrations greater than 30,000 ppm (lower explosive limit) may be made only for purposes of life rescue; and (ii) Entry into concentrations of less than 3GtOOO ppm, but greater than 3,GOO ppm may be made only for purposes of life rescue, firefighting, or securing equipment so as to prevent a greater hazard from release of vinyl chloride. (6) Whore air-purifying respirators arc used: (i) Air-purifying canni.uors or cartridges shall be replaced priur to the expiration of their service life or the end of the shift in which they are first used, whichever occurs first, and {i*) A continuous monitoring anti alarm sys tem shall be provided where concentrations of vinyl chloride couid reasonably exceed the allowable concentrations for the devices in use. Such system shall be used to alert employees when vinyl chloride concentra tions exceed the allowable concentrations for the devices in use. (7) Apparatus prescribed for higher concen trations may be used for any lower concentra tion. (h) Hazardous operations. (2) Protective garments shall be provided clean and dry for each use. (i) Emergency situations. A written operational plan for emergency situ ations shall be developed for each facility storing, handling, or otherwise using vinyl.chloride as a liquid or compressed gas. Appropriate portions of the plan shall he implemented in the event of an emergency. The plan shall specifically provide thaL: (1) Employees engaged in hazardous opera tions or correcting situations of existing hazardous releases shall be equipped as re quired in paragraph (h) of this section; (2) Other employees not so equipped shall evacuate the area ami not return until condi tions arc controlled by the methods required in paragraph (0 of this section and the emergency is abated. (}) Training. Each employee engaged in vinyl chloride or polyvinyl chloride operations shall be provided training in a program relating to the hazards of vinyl chloride and precautions for its safe use. (1) The program shall include: (i) The nature of the health hazard from chronic exposure to vinyl chloride including specifically the carcinogenic hazard. . (1) Employees engaged in hazardous opera tions, including entry of vessels to clean polyvinyl chloride residue from vessel walls, shall be provided and required to wear and use; (i) Respiratory protection in accordance with paragraphs (c) and (g) of this section; and (ii) The specific nature of operations which could result in exposure to vinyl chloride in excess of the permissible limit and neces sary protective steps; (iii) The purpose for. proper use, and limi tations of respiratory protective devices; 13? K.R. 41S1S. Do-cnUwr 3. 1D7J.] (ii) Protective garments In prevent skin contact with liquid vinyl chloride or with polyvinyl chloride residue from vessel walls. The protective garments shall he selected for the operation ami its possible'exposure conditions. (iv) The fire hazard and acute toxicity of vinyl chluridc, and the necessary protective steps; (v) The purpose for and a description of the monitoring program; Ctwuwn* 10 642.1 15 000006 1010.1(1 I7(jH I lfv) J'JlO.WlTfjJUH'i* STANDARDS AND IN'TKRPRLTATIONS Page 30 of 32 OCCUPATIONAL SAfTTY AND IIDaLTM (vi) The purpose for, and :i description of, the medical surveillance program; ' (vii) Emergency procedures; (viii) Specific information to aid the employee in recognition of conditions which may result in the release of vinyl chloride; and (ix) A review of this standard at the employee's first training and indoctrination program, and annually thereafter. (2) A11 materials relating to the program shall be provided upon request to the Assistant Secretary and the Director. (k) Medical surveillance. (E) Past history of hospitalizations. (iii) A serum specimen shall be obtained and determinations made of: (A) Total bilirubin; (D) AIkalinc phosphatase; (C) Serum glutamic oxalacc-tic trans aminase (SCOT); (D) Serum glutamic pyruvic trans aminase (SCPT); and (13) Gamma glustamy! transpcptidnsc. (2) Examinations provided in accordance with this paragraph shall be performed at least: A program of medical surveillance shall be in stituted for each employee exposed, without re gal'd to the use of respirators, to vinyl chloride in excess of the action level. The program shall pruvidc each such employee with an opportunity for examinations and tests in accordance with this paragraph. All medical examinations and proce dures shall be performed by or under the super vision of a licensed physician, and shall be pro vided without cost to tiie employee. (i) Every G months for each employee who has been employed in vinyl chloride or poly vinyl chloride manufacturing for 10 years or longer; and (li) Annually for all other employees. (3) Each employee exposed to an emergency .shall be afforded appropriate medical surveil lance. (t) At the time of initial assignment, or upon institution of medical surveillance; (i) A general physical examination shall be performed, with specific attention to detect ing enlargement of liver, spleen or kidneys, or dysfunction in these organs, and for ab normalities in skin, connective tissues and the pulmonary system (See Appendix A) (II) A medical history shall be taken, includ ing the following topics: (A) Alcohol intake; (11) Past history of hepatitis; (C) Work history and past e.\posure to potential heputolox ie agents, including drugs and chemicals: (D) Past history uf blood transfusions and l o i n. luiTtUi?) 642. (4) A statement of each employee's suitability for continued exposure to vinyl chloride in cluding use of protective equipment and res pirators, shall be obtained from the examining physician promptly after any examination. A copy of the physician's statement shall be pro vided eacli employee. {5) If any employee's health would be mate rially impaired by continued exposure, such employee shall be withdrawn from possible contact with vinyl chloride. (6) Laboratory analyses for all biological specimens included in medical exam in at ions shall be performed in laboratories licensed under 12 CKK Tart 7-1. (7) If the examining physician determines that alternative medical examinations in those required bv paragraph <k) (1) of this section will provide at lea.-d equal assurance of delect ing medical conditions pertinent, to the oxpo- 6 CluillKl* i (> CUM 000006249 Page 31 of 32 OCCUPATIONAL SAI'KTY AND HEALTH IDin.inlTUtK STANDARDS AND IN ILIU'IUTATIO: sure to vinyl chloride, the employer mav ac cept such alternative examinations as meeting the requirements of paragraph (k) (]) of this section, if the employer obtains a statement from the examining physician setting forth the alternative examinations and the rationale for substitution. This statement shall be available upon request fur examination and copying to authorized representatives of the Assistant Secretary and the Director. (1) Signs and labels. (1) Entrances to regulated areas shall be posted with legible signs bearing the legend: Cancer-Suspect Acent Area Authorized IT.usonnll Only (39 F. It. 41&IS, December 3. 1971.] (2) Areas containing hazardous operations or where an emergency currently exists shall be posted with legible signs bearing the legend: Cancer-Suspect Acent in This Area Protective Kguu.vAENT Kf.ovievd Authorized Personnel Only 130 K.R. 4IS4S, December 3. 107-1.] (3) Containers of polyvinyl chloride resin waste from reactors or other waste contami nated with vinyl chloride shall be legibly labeled: Contaminated with Vinyl Chloride Cancer-Suspect Acent [39 F.R. 4ISIS, December 3. 1974.] (4) Containers of polyvinyl chloride shall be legibly labeled: POLYVINYL CHLORIDE (OR TRADE NAME) Contains VINYL CHLORIDE VINYL CHLORIDE IS A CANCER- SUSPECT ACENT or (ii) In accordance with dO CPE Par 170-lS`J, with the additional legend: Cancer-Suspect Acent applied near the label or placard. (39 F.R. 1S4S, December 3. 1974.) ' (6) No statement shall appear on or near an required sign, label or instruction which cor iradicts or detracts from the elfcct of, any rc quired warning, information or instruction. (m) Records. (1) All records maintained in accordance wit this section shall include the name and soci; security number of each employee where re levant. (2) Records of required monitoring an measuring, medical records, and authorize-' personnel rosters, shall he made and shall b available upon, request for examination am copying to authorized representatives of tin Assistant Secretary and the Director. (i) Monitoring and measuring records shall (A) State the date of such monitoring am measuring and the concentrations deter mined and identify the instruments ant methods used; (13) Include any additional informntior necessary to determine individual employee exposures where such expo sures arc determined by means other than individual monitoring of employees; and (C) Ue maintained for not less than IC years.. (ii) Authorized personnel rosters shall be maintained for not less than JO years. (5) Containers of vinyl chloride shall be legi (iii) Medical records shall be maintained fur bly labeled either: the duration of the employment af each employee plus 20 years, or JO years, 0) Vinyl Chloride whichever is longer. Extremely Flammaiile Has (3) In the event that the employer ceases to Under Pressure do business and there is no successor to re Cancer-Suspect A rent ceive and retain his records fur the prescribed dinner in 642,1 1 7 mn.iniTiiituai CUH 00006"?50 I910.I017(m>(3) STANDARDS AND INTCRPUCTATIONS Page 32 of 32 OCCUPATIONAL SAl'LTY and health period, these records shall be transmitted by c*cs *" s'in'*ar n:iturC- registered mail to the Director, and each X[3J within 10 irking davs folllowing any employee individually notified in writing of this transfer. mmfo,nnii(tnorriinngr and measuring whiech discloses that any employee has been exposed, without (4) Employees or their designated represontatives shall be provided access to examine and copy records of required monitoring and measuring. regard to the use of respirators, in excess of the permissible exposure limit, each such employee shall he notified in writing of the re sults of the exposure measurement and the steps being taken to reduce the exposure to within the permissible exposure limit. (5) Former employees shall be provided ac cess to examine and copy required monitoring |.1tl K.K. 4 1 S 18. Deccmher 3. 1 974.) and measuring records reflecting their own (o) Effective dates. exposures. (1) Until April 1, 1U75. the provisions cur (6) Upon written request of 3nv employee, a copy of the medical record of that employee rently set forth in iOIO.OCq of this Part shall apply. shail be furnished to any physician designated by the employee. (2) Effective April 1, 1975, the provisions sot forth in 1910.93q of this Part shall apply. (n) Reports. (1) Not later than 1 month after the estab lishment of a regulated area, the following in formation shall be reported to the OSHA Area Director. Any changes to such information shall be reported within 15 days. (i) The address and location of each estab lishment which has one or more regulated areas; and (ii} The number of employees in each regu lated area during normal operations, includ ing maintenance. (2) Emergencies, and the facts obtainable at that time, shall be reported within 24 hours to the OSHA Area Director. Upon request of the Area Director, the employer shall submit ad ditional information in writing relevant to the nature and extent of employee exposures and measures taken to prevent future emergen 1-iO F.1L 1321], March 23. 1973.| APrF.NOIX A -- SITPLLMENTAKY MEDICAL . INFORMATION When require*! tests under paragraph (k) (I) of this 5Cfliun show nhrorpiaiitiei. tr.c l<^ls j-nmini be repealed as soon practicable. prefernoiy within a in -J necks. IT tests remain abnormal, consnlcral ion should be eiven tn withdrawal of the cmplovcc frmn contact " illi vinyl chloride, while a more comprehensive* examination is made. Additional testa which nuv be useful: A. For kidney dysfunction: urine examination for al bumin, red blood colls, aml exfoliative abnormni veils. B. Pulmonary System: Forced vital capacity. Forced expiratory volume at I second, and chest roentgenugram (posterior-anterior. i4 x J7 inches). C. Additional scrum tests: Lactic acid dehydrogenase, lactic acid dehydrogenase isoenzyme, protein dclcrntiitalion, ami protein electrophoresis. D. For a won* comprehensive examination on re pented abnormal scrum tests: Hepatitis B antigen, and liver scanning. 130 y.R. 33SS!), October 4. 1974.) ]Din.ini7(,,H2) 642.1 18 CUH 000006251 Cluing? 10