Document wqanJOLzxgq6pDRDpRxb2M6xE

Memorandum AIR / PRODUCTS To: F. J. RYAN From: R. E. GAQOHSKI Oate: 26 OCTOBER 1984 Subset. OCCUPATIONAL HEALTH Deot.. Oeot *! CHEMICALS HANUFACTURING/5987 cc: A. E. Greene H. 3. Ortega (139) H. L. Watson J. M. Norwood P. L. T. Brian R. C. Sander J. T. Wharton i BACKGROUND As indicated to you In June of this year, a PVC worker at our Calvert City Plant, died on 28 October lii^^^^Wiesses which were Initially diagnosed as cirrhosis of the liver (non-alcoholic). Subsequent evaluation by Armed Forces Institute of Pathology Indicated' the condition to be angiosarcoma of the liver. The family of ^^^^^^^^|recent1y gave permission to have the autopsy materials evaluated by Fenton Schaffner, M.O., Chief, Division of Liver Diseases, the Mount Sinai Medical Center, New York, N.Y. On 27 September 1984 a confirmation of the diagnosis of angiosarcoma of the liver was made. This Is our first case of angiosarcoma. To date there have been 110 cases of angiosarcoma found worldwide with 35 of these being In the United States. Angiosarcoma Is a rare form of cancer that has occurred among a small fraction of persons who had been exposed to vinyl chloride monomer over a prolonged period at very high concentrations. The prognosis of the Illness Is fatal; analysis of the cases that have occurred worldwide indicates that VCM exposures that may give rise to this disease were generally In the range of hundreds of parts per million (ppm) and occasslonally even above the thousand ppm level. The exposure conditions which led to Jesse Boren's Illness are believed to no longer be present In our operations. Currently our VCM 'exposures are limited to 1 ppm or less. WORKMEN'S COMPENSATION CLAIM After her husband's death, 1 led a workman's compensation claim. Air Products Is maintaining weekly compensation payments to Now that we have confirmed the cause of death the claim will be fully resolved. Is 60 years old and, at an actuarial life of 14.1 years and a weekl^Hjene^^^of $138.83, will receive $102M during her lifetime. Since this case Involves two employers, we anticipate that the state of Kentucky will pay the bulk of the claim, reducing APCI's total liability to less than $25M. APCI's Legal Department will resolve any outstanding claim Issues as soon as possible. AP00034038 2- - POTENTIAL FOR FUTURE ILLNESS ^^This case win be classified as an occupational Illness, fatality. ^^^started working In PVC In 1963. At that time, the harmful effecl^^^ high continuous exposures to vinyl chloride and the Incidence of angiosarcoma were not recognized. His early work history Included that of reactor cleaner, one of the Jobs now recognized to have the highest exposures and Incidence of angiosarcoma. Exposure levels at that time are believed to have been several thousand ppm for long periods and are many orders of magnltbde greater than today's levels of less than 1 ppm. Few Industrial hygiene controls were In effect at that time; the principal concern was the flammability of VCH. APCI has about 75 persons with vinyl chloride exposure history approaching or past 20 years, with another 35-40 nearing the 15-20 year bracket. Based on the worldwide Incidence rate of angiosarcoma In heavily exposed workers whose work history predates 1974, we would expect not more than one additional case of angiosarcoma may be found among our workers. There are no routine (non-lnvaslve) diagnostic techniques which are effective for early detection of this disease, nor are there any known successful treatment procedures. CONTROLS IMPLEMENTED TO PREVENT VCH OVEREXPOSURE Starting In 1974, there have been many engineering controls Implemented to control exposure. We believe the risk to the health of the present workers Is very small. Among the controls which have been Implemented are the following: a) Prohibition of discharge of vinyl chloride to the atmosphere. b) Closed system operation with purging and verification before opening any vessels to the atmosphere. c) Incineration of any purge or off gases to destroy vinyl chloride content. d) Development of "large reactor" technology which have reduced the number of places where leaks can occur. e) Stripping of PVC product to reduce the free vinyl chloride remaining. f) Use of on-line monitoring systems together with warning signals to give notice of any leak In the breathing zone. g) Implementation of a 'rigorous respiratory protection program to be used In conjunction with on-line monitoring and leak patrols. h) Use of leak patrols to quickly address even minor leak sources. I) A medical program which though non-specific for detection of angiosarcoma Is designed to permit Identification of those Individuals who may be pre-dlsposed to liver abnormalities and may be at greater risk If they work with vinyl chloride. J) Changes have been made In PVC technology by the development of solvent cleaning methods and anti-fouling techniques to eliminate such high exposure jobs as reactor cleaner where Jesse Boren worked In his early career. k) Work practices and employee training in the hazards of vinyl chloride have been Implemented. AP00034039 -3- Today we handle vinyl chloride In both our PVC plants and our Calvert City emulsions (EYCL) operations. We believe that the control measures that have been implemented are adequate and that there is little threat to the health of our workers from present day operations and exposures. We are also not aware of any actions we can take at this time which would be beneficial to those of our worker population (about 115) who may have been exposed to much higher and prolonged exposures to vinyl chloride In their early working careers. MANAGEMENT COMMITTEE ' 1 plan to review case with the Management Committee on November 6th. Our principal thrust will be our Industrial Hygiene programs. You will recall we promised such a presentation to Oexter Baker when the claim was resolved. REG:mes Attachments R. E. GADOMSKI AP00034040 CHEMICALS GROUP INDUSTRIAL HYGIENE POLICY AIR PRODUCTS RECOGNIZES AND ACCEPTS ITS MORAL AND LEGAL RESPONSIBILITY REGARDING SAFETY, HEALTH, AND ENVIRONMENTAL MATTERS. WE WILL CONDUCT ALL CHEMICALS GROUP ACTIVITIES WITH A MAXIMUM CONCERN FOR THE SAFETY, HEALTH, AND ENVIRONMENT OF OUR EMPLOYEES, OUR CUSTOMERS, THE COMMUNITIES IN WHICH WE OPERATE, AND THE GENERAL PUBLIC. WITH REGARD TO INDUSTRIAL HYGIENE, IT IS OUR POLICY TO PROVIDE A WORK ENVIRONMENT FREE OF HARMFUL EXPOSURES TO CHEMICALS AND OTHER AGENTS WHICH MAY POSE A HAZARD TO HEALTH. AP00034041 OCCUPATIONAL DEATH - ANGIOSARCOMA - DATE OF BIRTH: DIED: AGE AT DEATH: 29 AUGUST 1922 28 OCTOBER 1983 61 WORK HISTORY: 21 MARCH 1960 - HIRED AS MATERIALS HANDLER IN`PLASTI CIZER PLANT 1 JAN, 1962 - TRANSFERRED TO PVC COMPOUNDING AS A MATERIALS HANDLER 1 JAN. 1963 - TRANSFERRED TO PVC POLYMER AREA AS AN OPERATOR TRAINEE 31 DEC, 1970 - CALVERT CITY PLANT ACQUIRED BY APCI 30 JULY 1982 - TRANSFERRED TO UTILITY AREA 8 SEPT, 1983 - WENT ON SICK LEAVE DATE OF EMPLOYMENT TO DATE OF DEATH: DATE INTO PVC TO DATE OF DEATH: TIME IN PVC AS AN APCI EMPLOYEE; 23 YEARS 20 YEARS llh YEARS AP00034042 ANGIOSARCOMA CASES BY COUNTRY UNITED STATES WEST GERMANY FRANCE CANADA UNITED KINGDOM SWEDEN YUGOSLAVIA ITALY CZECHOSLOVAKIA JAPAN NORWAY BELGIUM TOTAL 35 21 17 10 3 5 4 4 2 2 1 1 110 AP00034043 CHRONOLOGY OF U,S. DEATHS FROM ANGIOSARCOMA DEATHS, 1961 1962 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1 o 0 \ 1 0 0 0 3 2 1 1 0 3 1 4 3 1 2 0 4 0 1 2 5 TOTAL 33* AP00034044 ANGIOSARCOMA CASES IN THE U,S. BY COMPANY GOODRICH, LOUISVILLE UNION CARBIDE, S. CHARLESTON GOODYEAR, NIAGARA OTHERS 15 9 4 7 TOTAL 35 AP00034045 INDUSTRIAL HYGIENE MILESTONES ACTIONS-J&KEN VCM SAFETY ASSOCIATION FORMED CMA STUDIES ON VCM STARTED CMA EPIDEMIOLOGY RESULTS AVAILABLE TDA PLANT DESIGN MODIFIED TO ADDRESS HYGIENE CONCERNS VCM EXPOSURE REDUCTION o REACTOR BUILDING VENTILATION o ON-LINE AIR MONITORING o FRESH AIR MASKS INITIAL VCM PERSONNEL MONITORING MEDICAL SURVEILLANCE OF VCM WORKERS STARTED LOCAL MEDICAL CONSULTANTS ESTABLISHED CHANGE ROOMS/SHOWER FACILITIES IN CHEMICALS GROUP PLANTS DATE 1969 _ 1971 1973 1972-1975 STARTING 1973 STARTED .1973 1974 STARTING 1975 AP00034046 INDUSTRIAL HYGIENE MILESTONES (continued) ACTIONS TAKEN 1 DATE COMPUTERIZED MEDICAL RECORDS PROGRAM INITIATED FOR ALL CHEM. GROUP MFG. PERSONNEL CORPORATE MEDICAL DIRECTOR HIRED INDUSTRIAL HYGIENISTS HIRED IN CHEMICALS GROUP PVC REACTOR SOLVENT CLEANING TECHNOLOGY DEVELOPED LARGE REACTOR PVC TECHNOLOGY IMPLEMENTED o ESCAMBIA o CALVERT CITY PVC REACTOR ANTI-FOULING TECHNOLOGY DEVELOPED WORK PRACTICE STANDARDS DEVELOPED o PVC o AMINES o DABCO o DNT/TDA 1975 ' 1976 1974 1976-1978 1977 1978 1979 STARTING 1974 AP00034047 INDUSTRIAL HYGIENE MILESTONES (continued) ACTIONS TAKEN CUT DEVELOPMENTS; STARTED RESULTS o STUDIES TO DEVELOP DNT BIOLOGICAL MONITORING SURVEY OF PEER COMPANIES IN THE CHEMICALS INDUSTRY o REVIEW/COMPARE PROGRAMS o UPDATE MEDICAL/RECORDS SYSTEM INITIATE MIS STUDY TO REPLACE MEDICAL SYSTEMS PLAN FOR IMPLEMENTATION OF RIGHT-TO-KNOW LAWS ESTABLISH PRODUCT SAFETY DEPARTMENT DATE 1977 1979 1980-1984 1984 1985 1984-1985 1985 AP00034048 EBOGRAM EXECUTION PERSONNEL LEVEL o TRAINING o AWARENESS o AUDITS o SAFE WORK PRACTICES o ON-LINE MONITORING (VINYL CHLORIDE) PROFESSIONAL EVALUATIONS o HEALTH HAZARD INVENTORY/PERSONNEL MONITORING o CUSTOMER AND TOLLER HYGIENE SUPPORT o EMERGENCY RESPONSE o DEVELOPMENT AND CERTIFICATION OF PLANT S.H.E. MANAGERS OF INDUSTRIAL HYGIENE AP00034049 r OUTSIDE CONTACTS PROGRAM EXECUTION (continued) o CUT LIAISON - DEVELOPMENT OF BIOLOGICAL MONI TORING METHODS ON NITROAROMATICS o INDUSTRY AND TRADE ASSOCIATION CONTACTS (CMA, CUT, AIHA, AAIH, ETC.) o GOVERNMENTAL QUESTIONNAIRES/INPUT TO RULES AND LEGISLATION MEDICAL PROGRAM o COMPUTERIZED MEDICAL AND HYGIENE RECORDS o MEDICAL SURVEILLANCE o EMPLOYEE COUNSELING RELATED PROGRAMS o MSDS PROGRAM o PHR'S/PLANNED CAPITAL PROGRAM o PRODUCT SAFETY PROGRAM AP00034050 r HEALTH RELATED CAPITAL SPENDING* W EL HEALTH 78 297 79 422 80 802 81 426 82 609 83 500 84 1826 AP00034051 OPERATIONAL EXPENSES TOTAL SAFETY AND HEALTH OPERATING EXPENSE FYS4: INCLUDES HEALTH RELATED ACTIVITIES OF: o CHANGE ROOM/WORK CLOTHING SV o MEDICAL SURVEILLANCE o HEALTH RELATED LABOR COST, INCLUDING - NURSES: - CERTIFIED INDUSTRIAL HYGIENISTS: - ANALYSTS: 3 5 7,600 699 352 350 AP00034052 REGULATORY CLIMATE REGULATED BY: o OSHA o EPA NEW REGULATORY INITIATIVES: o OSHA HAZARD COMMUNICATION RULE (RIGHT-TO-KNOW) o STATE RIGHT-TO-KNOW LAWS BIGGEST IMPACT NEW JERSEY FLORIDA KENTUCKY MARYLAND CALIFORNIA OTHER STATES (AFFECTS PRODUCT SAFETY) PENNSYLVANIA MICHIGAN MAINE ALASKA ILLINOIS NEW HAMPSHIRE WISCONSIN WEST VIRGINIA OREGON MASSACHUSETTS MINNESOTA o OSHA VERSUS EPA JURISDI CATION o TDA o OSHA EASIER TO DEAL WITH o SELF-REGULATION - AP00034053 KEY ISSUES FY85-86 o COMPLIANCE WITH FEDERAL AND STATE RIGHT-TO-KNOW LAWS. o MODERNIZE MEDICAL/INDUSTRIAL HYGIENE RECORDS SYSTEM ($500M). ' o IMPLEMENT EPIDEMIOLOGY PROGRAMS. o UPGRADE HYGIENE FACILITIES AT ST. GABRIEL. o UPGRADE PASADENA SITE FACILITIES. DNT BIOLOGICAL MONITORING DEVELOPMENT. o STRENGTHEN R&D INDUSTRIAL HYGIENE PROGRAMS. o CONTINUE PROGRAM TO DEVELOP FIELD S.H.E. MANAGERS AS CERTIFIED INDUSTRIAL HYGIENISTS. o STRENGTHEN PRODUCT SAFETY PROGRAMS - TOLLERS - CUSTOMERS AP00034054