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NOT FOR PUBLICATION 24 AUGUST 1984 ACTS/VCd/WG/GN/33/6 GUIDANCE NOTE EH ^ VINYL CHLORIDE: TOXIC HAZARDS AND PRECAUTIONS CMA 007289 CONTENTS INTRODUCTION PROPERTIES OF VINYL CHLORIDE HEALTH HAZARDS RESPONSIBILITIES CONTROL LIMITS ALARM LEVELS ASSESSMENT CONTROL MEASURES FOR MATERIALS, PLANT AND PROCESSES Design and operation Local exhaust ventilation Venting General ventilation Cleaning and waste disposal AIR MONITORING Discontinuous methods Continuous methods Measuring equipment Location of sampling points for fixed analysers or automatic sequential fixed point sampling systems Accuracy and calibration Leax detection Alarm systems Recording of results PERSONAL PROTECTIVE EQUIPMENT Respiratory protective equipment Protective cloching PERMITS-TO-WORK Confined spaces Maintenance operations MAINTENANCE OF CONTROL MEASURES EMERGENCY PLANNING REGISTERED WORKERS HEALTH SURVEILLANCE INFORMATION, INSTRUCTION, AND TRAINING FACILITIES Washing and cnanging facilities Arrangements for eating, drinking and smoking NOTIFICATION TO THE HSE RECORDS APPENDIX 1: Properties of vinyl chloride APPENDIX 2: Sampling strategy flow chart APPENDIX 3: Modal letter to the family practitioner of a vinyl chloride worker on his leaving employment with vinyl chloride APPENDIX 4: Model form of consent for disclosure of a worker's medical records relating to vinyl chloride to Appointed Doctor APPENDIX 5: APPEND LX 6: Records Legal requirements CMA 007291 INTRODUCTION 1 Vinyl chloride is a colourless, highly flammable gas ac room temperature and atmospheric pressure. It is normally stored and handled under pressure as a colourless liquid. It has a slightly sweet odour detectable at concentrations above 2000 ppm. In tne UK virtually all vinyl chloride is used as starting material for the production of polyvinyl chloride (PVC) homopolymer; a small amount is used for copolymerisation with vinyl acetate. PVC is used extensively in pipes, flooring, nome furnishings, electric cable insulation, blow moulded containers, packaging and records. 2 This Guidance Note has been prepared on the basis of joint discussions between representatives of the Confederation of British Industry, the Trades Union Congress and the Health and Safety Executive within a Working Group of the Health and Safety Commission's Advisory Committee on Toxic Substances. j This Guidance Note provides practical guidance for employers, selfemployed persoas and persons in control of vinyl chloride monomer manufacture and polymerisation plants to assist them in complying with the Control of Sustances Hazardous to Health Regulations 198- and Approved Code of Practice for the Control of Vinyl Chloride at Wont. References in this note to 'employers' should be caken to include self-employed persons. This Guidance Note may also be helpful to safety representatives in fulfilling their statutory functions under the Safety Representatives and Safety Committees Regulations 1977. The guidance will be used by Inspectors of tne Health and Safety Executive (HSE; as part of their criteria for assessing compliance with the Health and Safety ac Work Act 1974 and other relevanc statutory provisions. 4 The Control of Substances Hazardous to Health Regulations 198- apply to all toxic substances used ac work, including vinyl chloride. The Directive of the Council of the European Communities (78/610/EEC) on the approximation of the laws, regulations and administrative provisions of Che Member States on Che protection of the health of workers exposed to vinyl chloride monomer applies to cne protection of tnose workers wno:- 1 CMA 007292 (a) are employed in works in vnich vinyl chloride is produced, reclaimed, scored, discharged into containers, transported or used in any way whatsoever or in which vinyl chloride is converted into vinyl chloride polymers, and (b) are likely to be affected by exposure to vinyl chloride in a working area. 5 VINYL CHLORIDE IS HIGHLY FLAMMABLE AND PRESENTS A CONSIDERABLE FIRE AND EXPLOSION HAZARD; THIS GUIDANCE NOTE DOES NOT GIVE ADVICE ON SUCH RISKS. Vinyl chloride comes within the group of subscaaces defined in Class 2 of Part II of Schedule 1 of the Notification of Installations Handling Hazardous Substances Regulations 1982. It also comes within the definition of a flammable gas as set out in Schedule 1(c)(1) of the Control of Industrial Major Accident Hazards Regulations 1981. Some of the requirements of these Regulations overlap with certain sections of this Guidance Note. Where this occurs reference is made in the text and Che Regulations should be consulted for further details. 6 This Guidance Note does not give detailed advice on the control of emissions of vinyl chloride to the atmosphere. HM Industrial Air Pollution Inspectorate is responsible for the control of air pollution arising from industrial processes involving the production of PVC and copolymers from vinyl chloride monomer. For detailed guidance on the control of emissions, reference should be made to tne HSE Note on Best Practicable Means BPM 3/79 : Pecroleum Works (PVC Polymer Plants). PROPERTIES OF VINYL CHLORIDE 7 The properties of vinyl chloride are set out in Appendix 1. HEALTH HAZARDS 8 Vinyl chloride is a gas at room temperature and atmospheric pressure and Che most common route of absorption into the Dody is by inhalation. 2 007 293 9 Acute exposure co vinyl chloride vapour causes central nervous system effects, che severity of which increase with exposure. At exposures of 50-500 parts per million (ppm) in air for 7 hours no apparent acute effects have been found in humans. However, exposure to 20,000 ppm (22) for 3 minutes resulted in dizziness and disorientation. Incapacitation occurred at concentrations above 80,000 ppm (82) over 5 minutes. Exposure to concentrations of 300,000 400,000 ppm (30-40%) is rapidly fatal. 10 Chronic exposure to vinyl chloride has been associated with angiosarcoma of the liver, liver or spleen fibrosis (similar co the perilobular fibrosis known as Banti's Syndrome), circulatory disorders in che nands and feet (similar to Raynaud's Phenomenon, also known as white finger), scleroderma (a degenerative lesion characterised by stiffness of che skin and soft tissues) and acro-ostealysis (a deterioration of certain bones, most commonly the terminal phalanges of the fingers). Such effects have usually occurred after cnronic exposure co levels in excess of 100 ppm (see para 12). Vinyl chloride is a proven human carcinogen with no known threshold of effect. 11 Ocher effects have been reported as occurring in workers chronically exposed to vinyl chloride monomer at similar levels of exposure, although such reports have been disputed by others. These Include tumours of che brain, lung, haemo-lymphopoietic system, and skin (malignant melanoma), lung function disorders, chrombocycopoenia and immune complex disorders. Effects on reproduction nave also been reported. 12 fne general consensus of opinion is cnac polymerisation workers between 1940 and 1975 might have been exposed co levels of vinyl chloride of tne following order:- 1945-55 1000 ppm 1955-60 400 - 50U ppm oO 1960-70 300 ppm biid-197 J 150 ppm 1975 5 ppm 3 CMA 007294 Throughout the world chare will have been variacions around these figures because of differences in plant design or process operation. RESPONSIBILITIES 13 Employers must do all that is reasonably practicable to safeguard the health of their employees and others wno may be affected by work activities involving vinyl chloride. In particular, they have a duty to comply with tne provisions of the health and Safety at Work etc. Act 1974, the Control of Substances Hazardous to Health Regulations 198- and the ACoP on Vinyl Chloride. Employers may also have a responsibility to comply with the Factories Act 1961 and ocher associated health and safety legislation (see Appendix 5). 14 Section 2(3) of the HSW Act requires employers, with certain exceptions, to prepare, and revise as appropriate, a written statement of tneir general policy with respect to the health and safety at work of their employees and the organisation and arrangements used to carry out chat policy and to bring Che statement and any revision of it to the notice of all of their employees. The arrangements within the organisation for a formal system of joint consultation between management and employees and their representatives on ell aspects of tne Approved Code of Practice on Vinyl Chloride should also be set out in the safety policy. 13 In cne safety policy, a member of senior management should be given responsibility for ensuring that the maccsrs covered by the Vinyl Chloride ACoP, the Health and Safety at Worst etc. Act and the Factories Act, etc are implemented. These include tne responsibility for safe systems of wortt, safe places of worst, training, monitoring, emergency procedures, joint consultation etc. He should be provided with appropriate support as may be necessary. 16 Responsibility for implementing particular aspects of the Approved Code of Practice and this Guidance Note should be allocated at each appropriate level within the organisation with a clear line of communication from plant operatives to the person in overall charge. Steps should be taken to ensure cnat individuals understand and accept tneir responsibilities. 4 CMA 007295 17 Employees should cooperate with management in implementing health and safety precautions and in making proper use of the equipment and facilities provided for their protection. They should report immediately to their supervisors any suspected faults or material defects in plant or deficiencies in the control measures taken to contain vinyl chloride and reduce exposure. 13 Safety policies need to be reassessed at regular intervals to easure that they are still appropriate and effective, particularly when significant cnanges in plant or work activities occur. Such assessment should include, of course, Che organisation and arrangements for complying with the legislation, code of practice, etc relevant to vinyl chloride. CONTROL LIMITS 19 The Control Limit for occupational exposure to vinyl chloride vapour in air is an Annual Concrol Limit of 3 ppm and is the value which should not be exceeded by the concentration, averaged with respect to time, of vinyl chloride monomer in the atmosphere of a working area over a period of one year. Only periods of plant operation including, where necessary, any maintenance time should be takea into account. Periods during which alarm level concentrations are measured need not be taken into account when assessing compliance with the Annual Concrol Limit. In practice, the atmosphere of working areas should be monitored regularly (see paragraphs 3762) and the results summarised on a shift and monthly basis. A 'rolling average' time weighted average concentration of vinyl chloride-in-air can then be calculated and over any period of 12 successive calendar months it should not exceed 3 ppm. In this way, past compliance vicn the Annual Concrol Limit can be checked and crends noted. This Annual,Concrol Limit is supplemented by an 3 nour time weighted average (TWA) Concrol Limit of 7 ppm for personal exposure with the proviso chat cne Annual Concrol Limic is not exceeded. These Control Limits have been judged after detailed consideration to be reasonably practicable for the whole spectrum of work activities in Great Britain and should not normally be exceeded. 20 For substances, such as vinyl chloride, for which there are no known thresholds below wnich adverse effects do not occur not only should exposure be xept below the Control Limits but it snould also be reduced still further until the point is reached wnere Che costs of further concrol measures are not justified in terms of the additional reduction in risk. CMA 007296 5 ALARM LEVELS 21 In vinyl chloride monomer manufacturing and polymerisation plants there should be a system for the automatic detection of high levels of airborne vinyl chloride in places where these may occur (see para 54), The following concentrations of vinyl chloride in the atmosphere of a worsting area should be treated as alarm levels, signalling the need for evacuation and remedial action:- (a) 15 ppm when measured over a period of 1 hour, or (b) 20 ppm when measured over a period of 20 minutes, or (c) 30 ppm vnen measured over a period of 2 minutes. Where a continuous multi-point analyser (see paragraphs 40-41) is used, two successive readings above the appropriate concentration will determine the existence of an alarm level, ie 15 ppm over a period of 1 hour and 20 ppm over a period of between 20 and 30 minutes. ASSESSMENT 22 Under the Control of Substances Hazardous to Health Regulations an employer must not carry on any work which may expose his employees to any substance hazardous to health unless he has made an adequate assessment of the risxs to health creaced by tne substance. The assessment involves identifying the nature of the substance, the risks to cne health of persons who may be exposed, the nature and degree of exposure which may occur during the course of worse and the steps to be taken to avoid risxs to health. In order to ensure effective control of exposure to vinyl chloride, it is necessary to collect and assess adequate data on the circumscances under which exposure may arise. In existing plants, most of these data will already nave been obtained. All work activities which may involve exposure should be assessed to identify actual and potential sources of emission of vinyl chloride vapour into tne wonting atmosphere. The nature and degree of exposure should be studied in eacn case. In Appendix 2, a flow chart sets out a sampling strategy for the assessment of exposure to toxic substances. Assessment permits tne formulation of plans for the development and introduction of effective engineering, operational and other measures for the prevention or control of exposure, for the maintenance CMA 007297 6 of such measures and for Che long-term monitoring of their effectiveness. It also indicates activities where the only reasonably practicable method of preventing exposure is by using respiratory protective equipment. In existing plants, operating experience and monitoring data should already have led to the introduction of most of these control measures. 23 The employer should ensure chat whoever carries out the assessment is competent for the purpose and has received adequate information, instruction and training. 24 Examples of work activities which may give rise to exposure to vinyl chloride include (aj transport, storage, discharging into containers, breaking down from buix, polymerisation, reclamation and sampling of vinyl chloride or materials, Including waste, containing it in residual.or unreacted form; (b) r the operation, cleaning, maintenance and repair or any apparatus or process plant used in the production and conveyance of vinyl chloride or in its polymerisation and the handling and storage of freshly polymerised material. 25 An employer should consider not only the exposure of his employees engaged upon work with vinyl cnloride but also that of:- (a) ocher of his employees not directly involved wicn vinyl chloride wno could be affected by chat work activity; (b) ocher people who may be exposed while on the premises, eg tne employees of outside contractors engaged on maintenance; (c) members of the public who may be affected by emissions and discharges from the workplace. 26 To estimate the degree of exposure to vinyl chloride by inhalation, ic is usually necessary to carry out a comprehensive personal atmospheric sampling survey. However, vinyl chloride in air estimations need not be carried out in every individual case, particularly when sufficient information based on CMA 007298 7 previous measurements is already available in relation to a specific work, activity or where it may be possible to group employees on the basis of similarity of degree of exposure and type of work done to enable an adequate assessment of likely exposure to be made. It is important to study the pattern of exposure of workers in different jobs and locations over vttole workshifts and to identify when and where the highest exposures are likely to occur caking into account the possibility of unusual circumstances such as pianc breakdowns or emergencies. 27 It is important to carry out sufficient sampling to enable accurate 3 hour time-weighted average concentrations to be calculated. However, shorter term sampling may assist in the assessment of the performance of engineering . controls. The survey of exposures should be extended over sufficient workshifts to ensure tnat the variability of exposure is adequately studied. Further decailed information and advice is available in RSE Guidance Note EH 42 - 'Monitoring Strategies for Toxic Substances'. 23 It is recommended that the results of the assessment be recorded and a copy provided on request at any reasonable time during working hours to employees and/or their representatives at the place of work. 29 The assessment should be revised whenever there is evidence or reasoa to suspect that it is no longer valid, as a result of, for example (a; a significant cnange in the work activity; this could be a change in plant, processes or metnods of work chat might affect the nature or degree of exposure, such as the raising of process temperatures or changes in engineering controls; (b) results of air moaitoring at the work place revealing an increase in exposure; (c) data arising from healcn surveillance; (d) new Information on health risks becoming available. CONTKUL MEASURES FOR MATERIALS, PLANT AND PROCESSES 30 When considering appropriate control measures for reducing exposure to a toxic substance, the first strategy to examine is substitution with less 8 OK* 007299 hazardous materials, including the alteration of synthesis routes to avoid using or producing toxic intermediates. Users or potential users of vinyl chloride and polyvinyl chloride should consider the use of a less toxic substance but if that is not possible control measures snould be applied as far as is reasonably practicable, irrespective of the size of the plant, to minimise exposure of personnel to vinyl chloride. 3L Control may be considered adequate when exposure to vinyl chloride is effectively controlled to the occupational Control Limits and as far below them as is reasonably practicable in the particular circumstances. The objective in applying materials, plant and process control measures is to ensure adequate control of exposure without recourse to personal protective equipment so far as is reasonably practicable. Design and operation 32 Equipment and processes should be designed and operated to eliminate or minimise the ri3ks of leakages and spillages of vinyl chloride and to minimise Che need for maintenance or other work whieh requires the breaching of and/or entry into plant in which vinyl chloride is liable to be present. General ventilation 33 Good general ventilation should be provided for rooms and buildings in vnicn processes involving vinyl cnlorida are carried on and as far as possible plant should be sited in the open. Local exhaust vencilaclon 34 Vinyl chloride should be handled in enclosed equipment provided with local exhaust ventilation at any points where Che emission of vapour cannot be eliminated by improved design or maintenance. Local exhaust ventilation should also be provided at specific locations in process plant to ensure chat maintenance operations can be carried out safely. Venting 35 HM Industrial Air Pollution Inspectorate and HM Factory Inspectorate should be consulted on any points relating to plant or storage where cnere is the potential for the emission of vinyl chloride into Che atmosphere to ensure that both the public and the workforce are not at risk. 9 CMA 007300 Cleaning and waste disposal 36 Waste polyvinyl chloride slurry containing significant levels of residual vinyl chloride should be stripped of vinyl chloride prior to suitable treat ment of the liquid waste for general disposal. Solid polyvinyl chloride waste snould preferably be dried before disposal. Wastes arising from vinyl chloride processes should be handled and disposed of in accordance with tne Department of Environment Waste Management Paper No 15: 'Ealogenated Organic Wastes - A Technical Memorandum on Arisings, Treatment and Disposal including a Code of Practice'. AIR MONITORING 37 The objectives of monitoring concentrations of airborne vinyl chloride in working areas ara:- (1) to verify that any technical measures and working procedures maintain adequate control of exposure; (2) to detect abnormal increases in vinyl chloride-in-air levels which may occur as a result of failure or malfunction of some part of the plant or apparatus, with references to the short cerm alarm levels for vinyl cnloride; (2) to provide adequate records of the exposure of individuals for the purpose of epidemiology. 38 The arrangements for monitoring require careful planning to achieve effective and efficient use of resources. A formal air moaicoring plan should be drawn up and made known to all employees working in areas where vinyl cnloride is liable to be present. The plan should contain details of Che air monitoring procedures and equipment that are to be used to meet the objectives sec out in para 37, including details of:- (a) tne parts of plant, working areas and occupational groups of employees to be monitored; (b) the type of air sampling Co be carried out, eg personal air sampling, fixed point air sampling; 10 CMA 007301 (c) che frequency of air sampling and the siting of air sampling equipment; (d) the types of sampling and analytical equipment to be used; (e) arrangements for the testing and calibration of sampling and analytical equipment; (f) the statistical analysis and presentation of the air sampling results. The information obtained from the initial and any subsequent assessments snould be used when planaing or revising the details of the monitoring procedures. 39 Static sampling will be the main method used routinely for assessing compliance with Che Annual Control Limit and detection of alarm levels in vinyl chloride monomer production and polymerisation plants. In order to assess compliance with Che 3 hour TWA Control Limit personal monitoring will be necessary. 40 Static sampling may be either by discontinuous or continuously operating sequential systems, except at vinyl chloride polymerisation plants sited within buildings where only the latter methods should be used. 41 Where discontinuous air sampling techniques are used, the frequency of measurements should be sufficient to predict with a confidence coefficient of at least 952' cnat there is compliance with the Annual Control Limit, in other words chat the Control Limit value falls above the upper 95Z confidence limit for the true annual arithmetic mean for the working area. The required frequency will thus depend upon the variability of concentrations with time. 42 Where vinyl chloride is handled intermittently, monitoring of exposures by personal sampling should be done sufficiently often to ensure chat technical control measures and working procedures are adequate to keep exposure below cne Control Limits. 43 Large working areas will normally require more than one monitoring point and in such cases tne average value of the measurements recorded should be considered as the representative value when assessing compliance with the Annual Control Limit. 007302 11 Measuring equipment 44 The sensitivity, range, selectivity and speed of response of an analytical device should be appropriate to the duty it is required to perform. Electrical equipment in flammable atmospheres should be suitably constructed, protected and installed; guidance is available in BS Code of Practice 1003. 45 The following techniques are among those suitable for detection and measurement of vinyl chloride (a) gas chromatography (b) infra-red absorption analysis (c) flame ionisation detection Flame ionisation detection is not specific for vinyl chloride and may therefore give readings which are greater chan the actual concentration. 46 Gas samples may be taken by any technique which is recognised and acceptable for the analytical technique to be used. 47 A comprehensive description of the various analytical techniques available for the measurement of vinyl chloride are given in 'The Determination of Vinyl Chloride: A Plant Manual - Analytical rletnods for the Control of Vinyl Chloride Concentrations In and Around Manufacturing and Process Plants' pubiisned by tne Cnemical Industries Association Limited, Alembic douse, 93 Albert Embankment, London SE1 7TU. Details of one of the personal sampling methods used by HSE are available in MDES 24 - 'Vinyl Chloride in Air*. Laboratory method using charcoal abosrbenc tubes, solvent desorption and gas chromatography'. Location of sampling points for fixed analysers or automatic sequential fixed point sampling systems 43 Sampling points should be located within tne working area to sample air representative of tnat breathed by the workers. The probes should normally 12 007303 be sited at breaching height and at local places where the air movement is representative of the general working area and should not impede the movement of workers, access to or operation of equipment. 49. Other locations for sampling points may also need to be chosen so that any increase in concentration of vinyl chloride arising as a result of leakage or plant malfunction can be detected as soon as possible (see para 54). Accuracy and calibration 50 If a measuring system is used which records vinyl cnloride and ocner substances without being capable of distinguishing between them, the results obtained should be regarded as representing vinyl chloride only. Special consideration may need to be given to Che interpretation of results where there are indications chat the Control Limit is being exceeded but it is known that this is due to other substances. 51 The precision and accuracy of the sampling systems used should be investigated over the vinyl chloride in air concentration range of 1-30 ppm. An accuracy of 1QZ within this range is satisfactory. The method used and the results obtained should be recorded. 52 Measuring equipment should be calibrated regularly, in accordance with the agreed air monitoring plan, using the most appropriate technical meenods. The calibration or automatic air sampling syscams should preferably involve the injection of air samples containing known amounts of vinyl chloride into Che system at sampling points, rather chan directly into the analysing instruments. Leak detection 53 Leak detection may be carried out by the following means:- (a) portable analyser; (b) mobile sample line attached to a non-portable analyser; (e) ultra-sonic leak detector. 13 CrtA 007304 Alarm systems 54 Whatever sampling system is used for routine monitoring, there should also be a system for the automatic detection of high levels of airborne vinyl chloride in places where these may occur, eg in the event of plant failure. The alarm system may be integrated with a continuously operating or permanent sequential system provided for the purpose of air monitoring. Recording and presentation of results 55 The results of all atmospheric monitoring at fixed points should be available for inspection by personnel worsting in areas where vinyl chloride is liable to be present and their representatives at any time during a working period. Where continuously operating multi-point sequential sampling methods are employed, the results should be displayed as far as possible within two hours of the end of each shift sampled. Where discontinuous method and/or personal monitoring are used, the results should be displayed within 24 nours of completion of the sampling period where possible. 56 In the areas where continuously operating multi-point sequential sampling and analysing equipment is installed, results should be summarised on a shift basis for each identifiable work area showing the average concentration in the area, dasic details of the position and number of sampling points together witn the frequency of sampling and ahalytical methods used should be Included at the beginning of the series of records and tnereafcer need only be recorded when changes occur in the monitoring procedure. 57 In the areas wners sampling i3 carried out ocher than qq each shift, the individual time weighted average results snould be recorded. These should be summarised on a monthly basis shoving the average concentration at each location with an.analysis of the distribution of tne individual results. 5d Records of maintenance and monitoring should provide sufficient inform ation to enable employers, self employed persons, persons in control of premises, employees and/or their representatives at tne workplace, and enforcing authorities co:- 14 007305 (a) ascertain whether maintenance or monitoring has been carried out; (b) monitor the performance and effectiveness of control measures; (c) gain access to information on any defects or matters requiring attention and on the remedial action taken; (d) identify exposure trends. 59 The records should contain at least the following information (1) Leakages of vinyl chloride (a) description of area or plant inspected; (b) date of inspection; (c) time of inspection and shift; (d) statement of any defects or leaks found that might result in the release of vinyl chloride vapour above the 8 hour TWA Control Limit or alarm levels; (e) significant uncontrolled or abnormal emissions of vinyl chloride to the atmosphere reported to HMIAPI; (f) indication of action taken following discovery of faults; (gj name, signature and appointment of person making inspection. (2J Examinations of ventilation equipment (a) location and type of plant; (b) dace of examination; 15 007306 (c) instruments used and results of instrument readings; (d) defects noted; (e) action taken; (f) name, signature and appointment of person making examination, O) Excursions above the alarm levels as detected during area monitoring (a) part of faccory to which the record refers; (b) precise location witnin the factory; (c) dace, time and (where known) duration; (d) maximum time weighted average concentrations recorded; (f) result of investigation; (g) action taken; (h) name signature and appointment of person maxing inspection. (4) Personal monitoring (a> name of employee; (b) dace; (c) time and duration of exposure; (d) time weighted average concentrations recorded; (e) precise duty and working area witnin factory; If) nature and nominal efficiency of respiratory protective equipment (if worn). 16 CMA 007307 The results of personal monitoring should be summarised on a monthly basis by job category in each plant in addition to shift results. 60 If respiratory protective equipment is worn by any personnel during air monitoring exercises, this should be recorded together with Che nature and nominal protection faccor of the equipment to enable an estimate of the 'actual' exposure to be made. 61 Records may be kept in any suitable form, including microfilm, computer or similar techniques, provided cney satisfy the foregoing requirements and can be retrieved readily when required. 62 Records of air monitoring should be kept for at least 3C years. In cne long term, air monitoring results may be kept In the form of monthly summaries, but in this case the detailed shift records on which they are based snouid be kept for at least 1 year. Records of leakages of vinyl chloride and examination of ventilation equipment should be kept for at least 2 years. PERSONAL PROTECTIVE EQUIPMENT Respiratory protective equipment 6J Where adequate control or exposure co vinyl chloride cannot be achieved by normal engineering controls and tne provision of further control measures for materials, plant and processes is not reasonably practicable, workers should be provided with adequate and suitable respiratory protective equipment. The term 'adequate' with respect to respiratory protective equipment refers to the ability of the equipment to protect the wearer; 'suitable' refers co the correct matching of the equipment to Che job and co the person. To be considered adequate and suitable, respiratory protective equipment must be correctly selected and used. It should be noted cnac tne nominal protection factor of respiratory protective equipment can only be achieved if the face fit of the equipment is very good. In the case of vinyl chloride, this means compressed air line or self-contained breaching apparatus of a type approved by or conforming co a standard approved by cne Health and Safety Executive, 17 CMA 007308 64 In particular, adequate and suitable breaching apparatus oust be worn:- (1) when it is not reasonably practicable to remove vinyl chloride vapour by local exhaust ventilation, a.g. when opening equipment which may release appreciable quantities of vinyl chloride to Che atmosphere and during the maintenance or repair of equipment. No such operation should be conducted without a permit-to-work issued by a competent person designated by the employer for this purpose. Precautions should be taken to ensure that ocher unprotected personnel in the vicinity are not liable to be exposed to concentrations of vinyl chloride above the 8 hour TWa Control Limit; (2) during entry inco confined spaces which have not been certified by a competent person as being safe for entry without breathing apparatus. 65 Following an alarm, adequate and suitable breathing apparatus should be worn by any person remaining in an affected area until the alarm is over. The source of an escape of vapour should be identified and appropriate corrective action taken without delay. 66 It is recommended that no person should be required to rely for protection on respiratory protective equipment unless-he has successfully completed a training or refresher course on the use of such equipment within the previous 12 months and has been issued with a certificate to this effect. The training or refresher course could include tne following la) principles of operation and use of equipment; (b) practical use, correct fitting, etc; (c) limitations of the equipment; (d) common defects and action required; 18 CMA 007309 (a) company arrangements for issue, cleaning, maintenance, etc; (f) when it is to be used. 67 A register of authorised personnel trained in the use of respiratory protective equipment should be icept together with a record of each person's training. All breaching apparatus should be maintained in a clean state, in good repair and in efficient working order. It should be inspected every 14 days and defects identified and remedied immediately. The maintenance schedules should specify that the compressed air supplied to the wearer of breaching apparatus should contain not more than 5 ppm carbon monoxide or 500 ppm carbon dioxide or 0.5 mg m"3 an misc and except for these should be free from contamination by dust, dirt, metallic particles or any ocher toxic or irritant substances whatsoever. The maintenance schedules should also include cne source of compressed air, the air line, particularly the connections, and proper cleaning and reissue of equipment. 68 No respiratory protective equipment which has been used should be worn again by another person unless it has been thoroughly cleaned and disinfected. 69 Records of maintenance and inspection of respiratory protective equipment should include the following information:- (a; name and description of equipment*; (b) person issued to, if on personal issue; (c) dace of inspection; (d) description of any defect found and action taken; (a) name, signature and appointment of person making inspection. These records should be kept for at least 2 years. Protective doming 70 Under normal circumstances, where vinyl chloride is handled within 19 CMA 007310 enclosed plane, there may be no need for the wearing of special protective clothing by process workers, however, certain circumstances, such as entry into confined spaces or some maintenance work, may require the use of special protective clothing. Such situations should be identified as part of tne general assessment. The standard of clothing necessary will depend upon the nature of exposure. For example, where substantial body contact can be foreseen a high standard of protective clothing should be provided, eg completely enclosing air-fed suits (where respiratory protective equipment is also necessary^ of wire reinforced PVC, or overalls of PVC-proofed material, completed in all cases by PVC gloves and boots. Where an area is relatively free of vinyl chloride, having perhaps been cleaned by means of high pressure noses or other methods, overalls or materials such as terylene or cottoa, may be adequate. PERMITS TO WORK 71 A permit-to-work is essentially a document which secs out the work to be done and the precautions to be taken. It predetermines a safe procedure and is a clear record that all foreseeable hazards have been considered in advance and chat all appropriate precautions are defined and taken in correct sequence. It does not, in itself, make the job safe but is dependent for its effectiveness on the persons concerned conscientiously carrying out the requirements of the permit. There should be provision on the permit-co-work for tne persons authorising the work to sign to this effect and for the persons carrying ouc the worn to sign the 'document at each stage of the operation as it is completed. Permits to work should be issued for all entries into confined spaces and for certain maintenance operations. Copies of ail permits-co-work issued should be kept for a minimum period of 2 years. Confined soaces 72 In cnis Guidance Note the term 'confined space' includes any chamber, tank, vac, pic, pipe, flue or similar confined space such as, for example, a reactor, duct, or bunker in which vinyl chloride vapour is known to be or is liable to be present. 73 Unless adequate precautions are taken, entry into a confined space involves a particular risk of exposure to very high levels of vinyl chloride or lack of oxygen. Concentrations of vapour may even be such as to iavolve a 20 CMA 007311 rislc of persons being overcome with a consequent risk co life, in addition to the possible long-term effects of exposure. Plant should be designed and operated so as to reduce to a minimum time spent in vessels and the number of occasions requiring entry. 74 In order to reduce the potential short-term and long-term risks, entry into confined spaces should be strictly controlled. A permit-to-vork system should be operated and other special precautions taken as outlined in HSE Guidance Note GS 5 - 'Entry into Confined Spaces'. 75 inJhenever a person enters a confined space for any purpose, a lifeline should be worn or, where this is not practical, some ocher method should be used, to enable a second person posted outside Che confined space to keep in constant contact. The second person should be able to raise the alarm and equipment and trained personnel should be readily available for rescue purposes. All workers involved in any way with work in confined spaces should be fully trained and conversant with the organisation's agreed emergency procedures. 76 Unless a confined space has been certified in writing by a competent person as being, for a specified period, safe for entry without breaching apparatus and the period has not expired no person should enter or remain in i the confined space for any purpose unless he is wearing suitable breathing apparatus. The permit-co-work should specify the type and standard of personal protective equipment co be worn and all otner necessary precautions to be taken. 77 Entry into a confined space without breaching apparatus should not be authorised by a competent person unless:- (a) effective steps have been taken to prevent the entry of any vinyl chloride vapour or other dangerous fume and (b) any sludge or other deposit liable to give off vinyl chloride or otner dangerous fumes has been removed and no ocher material liable co give off dangerous fumes is present and (c) the space has been adequately ventilated, tested for vinyl chloride and other dangerous fumes and has a supply of air adequate for respiration. 21 CMA 007312 If there is a .possibility that the proportion of oxygen in the air of a confined space has been substantially reduced no person should enter or remain in such a space unless he is either wearing suitable breathing apparatus. Alternatively the space should be adequately ventilated and a competent person should test and certify it as safe for entry without breaching apparatus. Maincgnance operations 73 When a non-routine operation or malfunction may result in the release of vinyl chloride to the atmosphere, adequate and suitable breaching apparatus of a type approved by HSE should be worn. Wherever possible special measures should be taken to prevent emissions of vinyl chloride. Such operations should not be conducted witnout permission in the form of a permit-to-work from a competent person designated by the employer for this purpose. Precautions should be taken to ensure chac ocher personnel are not exposed to levels of vinyl chloride above Che Control Limit. MAINTENANCE OF CONTROL MEASURES 79 All plant, especially that from which vinyl chloride may escape or which is provided for the purpose of controlling exposure to vinyl chloride, 3hould be maintained to a high standard in order to limit the exposure of workers to vinyl chloride. Maintenance procedures should include regular and thorough examinations by a competent person at appropriate intervals of chose parts of tne plant at which leakages of vinyl chloride may develop over a period of time. A suitable instrument giving a direct read-out of the concentration of vinyl chioride-in-air should be used for leak detection during such examinations. All defects found should be remedied prompciy and the results of maintenance examinations and details of remedial action taken recorded. 30 Regular examinations and tests should be made of ventilation equipment and otner technical control measures by a competent person, using instruments wnere appropriate, to check the performance of such equipment as part of a planned preventive maintenance programme. Where ventilation plant is provided In pursuance of Regulation 7 of the Control of Substances Hazardous to Health 22 CMrt 007313 Regulations, maintenance should include a visual check ac lease once a week to Identify obvious defects and a thorough examination and test by a competent person at least once a year. Details of such examinations and tests, defects found and remedial action taken should be recorded. EMERGENCY PLANNING 31 A procedure for dealing with a substantial escape of vinyl chloride should be prepared and updated as often as is necessary. The objective is to ensure that all employees who may be affected are trained and practiced in the arrangements for dealing with such emergencies. The emergency plan should cover:- (a) the definition of the type of situation to be considered as an emergency; (b) raising the alarm; (c) evacuation of the immediate area and adjacent areas liable to be affected; (dj control of the occurrence using site resources; (s) plant shut-down and containment of vinyl cnlorlde leakage, and (f) obtaining assistance from the emergency services. Tne booklet "Recommended Procedures for Handling Major Emergencies", published by the Chemical Industries Association Ltd., Alembic House, 93 Albert Embankment, Londoa SE1 7TU, provides useful Information and advice on this subject. It should be noted tnat Che Control of Industrial Major Accident Hazards Regulations 1984 will apply to some vinyl chloride installations and may require the preparation of on-site and off-site emergency plans. 82 tfnenever abnormal emissions occur which affect the environment significantly, tne District Inspector of HM Industrial Air Pollution Inspectorate and the local authority must be informed immediately. Production should not be continued with emissions outside the limits allowed without 23 CMA 007314 having consulted the District Inspector. Under the Notification of Accidents and Dangerous Occurrences Regulations 1980 the sudden, uncontrolled release of 1 tonne or more of vinyl chloride, eg. by rupture of a bursting disc, must be notified to the HSE immediately. REGISTERED WORKERS 33 In plants subject to the requirements of Che Vinyl Chloride ACoP, any worker identified during the assessment procedure required under Regulation 6 of the Control of Substances Hazardous to Health Regulations as likely to be affected by occupational exposure to vinyl chloride should be designated as a 'registered worker'. A register of such workers should be kept by the employer . Any worker generally spending less than 252 of his working year exposed to vinyl chloride need not be designated as a registered worker * Consideration should also be given to designating ocher persons working regularly on sice, eg contractors' employees, as registered workers where there is the potential for exposure to vinyl chloride oa a scale similar to chat for an employer's own employees and the assessment warrants such action. HEALTH SURVEILLANCE 84 Health surveillance of registered workers is intended to detect, as early as possible, any harmful effects associated with exposure co vinyl chloride at work. The initial assessment considers the individual's fitness to work with vinyl chloride and establishes baseline medical information with regard co registered workers. 85 Workers should be subject co periodic assessment to check their fitness co continue working with vinyl chloride. The assessment may also provide additional information which mighc lead co a fuller understanding of cne coxicological effects of vinyl chloride. Such data could also be of value in any future epidemiological studies. Each person should be subject co medical reassessment (a) at intervals of not more chan 12 months; 24 CMA 007315 (b) If he has reported symptoms which could be attributable to vinyl chloride exposure; (e) if, in the opinion of the appointed doctor, he requires further medical assessment; (d) when he has been absent from work because of any illness for 4 weeks or more. 86 The medical assessment of each individual is the responsibility of Che appointed doctor but it will normally include (a) a full history, both clinical and occupational; (b) a clinical assessment with particular reference to the abdomen, skin and extremities, and (c) such further tests, including radiological examination and.1 laboratory tests, as may be indicated by the results of (a) or (b). 87 The employer should ensure that the leaflet "Vinyl Chloride and You" is given to every worker on commencement of his employment. Copies can be obtained free of charge from any office of the Health and Safety Executive. 88 The employer should also ensure that each employee Is aware that he has Che right to request a written record of the results of any health surveillance procedures. If abnormal findings are present the individual may, if he consencs, be referred to his Family Practitioner. 89 Where medical examinations need to be carried ouc adequate facilities should be made available. The facilities snould comprise a room which is properly cleaned, adequately warmed, well ventilated, suitably furnished and provided with a wash basin equipped with hot and cold running water, soap and a clean towel. If It is not reasonably practicable to provide hot and cold running water, a means of heating water should be provided within cne room. The room should be suitably quiet and not permit ordinary conversational voices to be heard outside its wells. The room should be sec aside for Che exclusive purpose of health surveillance whenever it is required. 25 CMA 007316 Wtare che number of employees to be examined or assessed is substantial, a suitable waiting area should be provided. An adjacent lavatory with hand washing facilities should be provided for employees who may be required to provide specimens for biological testing. 90 Arrangements should be made for any employee who is a registered worker to present himself, during his normal working hours, for medical examinations and any additional tests as may be necessary. . Employees should cooperate in such examinations and tests. 91 The basic occupational health record of a registered worker's health surveillance should consist of at least the following information:- surname, forenames, birth surname, sex, date of birth, place of birth, (town and country), permanent address, National Insurance Number, National Health Service Number, dace of commencement of present employment, and a historical record of jobs performed whilst in that employment, with appropriate details to Indicate likely exposure. 92 These records may be kept in any suitable form provided chat they satisfy che foregoing requirements and can be retrieved readily when required. They should be kept in a form compatible with and capable of being linked to cnose for monitoring, so chat it is possible to compare the nature and degree of exposure to vinyl chloride with effects on'heelch. The health record of e registered worker should be kept for at least 50 years from che date of che last entry. 93 Some of che conditions associated with exposure to high levels of vinyl chloride, particularly angiosarcoma of che liver and portal hypertension due to non-cirrhotic periportal fibrosis, may have prolonged latent periods with symptoms not appearing until several years after exposure, possibly after a vinyl chloride worker has retired or transferred co other work. In all cases when a vinyl chloride worker leaves a company, ceases to be a registered worker or transfers co another location, a letter should be seat co his family Praccitioner oy the Appointed Doctor. Appendix 3 contains a suggested letter for sending to an employee's Family Practitioner and Appendix 4 a suggested form for che employee co give his consent for the Appointed Doctor to discuss his medical and occupational history with regard to his exposure co vinyl 26 CHA 007317 chloride with his Family Practitioner. Both the suggested letter and form of consent have been approved by the Ethical Guidance Committee of the General Medical Council. Appointed Doctors are recommended to place copies of any letters and forms of consent in the occupational health records of the employees concerned. 94 When an employee ceases to be a registered worker, but continues to work at the same location and for the same employer, the Appointed Doctor shall offer to continue the employees health surveillance programme as in paras 85, 86 and 88. INFORMATION, INSTRUCTION AND TRAINING 95 Employers should ensure chat employees receive adequate information, instruction and training, so that they are aware of the nature of the hazard, che extent of the risks from exposure to vinyl chloride, the precautions to be observed to minimise these risks and che role of joint consultation. Employers should also ensure that employees of contractors and ocher persons working in areas involving potential exposure to vinyl chloride have received similar information, instruction and training. The topics covered should include the following (a; health hazards of vinyl chloride; (b) contents of the vinyl enloride ACoP; (c) general methods outlined in this Guidance Note and che leaflet 'Vinyl Chloride and You' for protecting persons from che health hazards of vinyl chloride and che need for health surveillance; (d) correct operation of che plant with which the employee is concerned; 27 CMA 007318 (e) role of the employee in observing safe working methods; (f) correct use of respiratory protective equipment and any other personal protective equipment; (g) significance of monitoring procedures and results; (h) relevant emergency procedures; (i) relevant rules relating to vinyl chloride; (j) procedures for reporting defects in plant and equipment. It should be noted chat Regulation 4 of the Control of Industrial Major Accident hazards Regulations 1984 requires a manufacturer to provide evidence that persons working on a site are informed, trained and equipped as necessary to ensure their safety. 96 Basic information, instruction and training should be provided oa recruitment and should be supplemented at regular intervals by training, "onche-job" refresher courses, calks, notices, leaflets or other methods in order to create and sustain a high level of awareness amongst employees. 97 Any person who carries out any assessment, air monitoring or maintenance casks which require che use of inscruments should be given addicional instruc tion and training concerning their use including (a) objectives of air monitoring; (b) correct use of the instruments; (c) sampling techniques; (d) analysis, interpretation and recording of results. 23 CMA 007319 FACILITIES Washing and changing facilities 98 Adequate washing and changing facilities of a high standard should be provided. Ail the facilities should be kept clean, warm and in good repair. Washing facilities should include showers for tne use of persons whose skin may be contaminated by vinyl chloride. Changing facilities should be designed to ensure chat clean cloching and chat which may be contaminated by vinyl chloride are kept separate. Arrangements for eating, drinking and smoking 99 Employees should not eat, drink or smoke in areas liable to be contaminated by vinyl chloride, so suitable facilities for these purposes should be made available. 100 Where a number of employees are involved, suitable facilities for use by persons who remain on the premises during main meal intervals should consist of a canteen, mes3-room or other suitable eating area. Thi3 should be provided with suitable cables and chairs and facilities for the storage of food and drink, whether the food and drink is supplied by the employers or Che employees. If drinking fountains are provided they should be installed so as to prevent the water from becoming contaminated. 101 Smoking should not be permitted except in areas set aside for the purpose because of the fire and explosion risks associated with vinyl chloride. NOTIFICATION TO THE USE 102 Employers are requested to notify HMFI at HSE Area Offices and HMLAPI at District Offices of proposals for the installations of new plant or modification of existing plant. Such notifications should be made at the design stage. Vinyl chloride comes within the group of substances defined in Class 2 of Part II of Schedule 1 of tne Notification of Installations Handling Hazardous Substances Regulations 1982. The Regulations require initial 29 CMA 007320 notification to HSE of any site handling quantities of vinyl chloride in excess of 25 coones with renocificacion at three times this figure. Vinyl chloride also comes within the definition of a flammable gas as set out in Schedule 1 e(i) of the Control of Industrial Major Accident Hazards Regulations 1984. Notification to HSE is required under Regulation 4 at 50 tonnes of vinyl chloride and for Regulations 7--12 at 200 tonnes for process and storage or 300 tonnes for isolated storage. Notification to HSE is also required of significant modifications to the industrial activity for inventories exceeding 200 or 300 tonnes for process and storage or isolated storage respectively. For further decails, reference snould be made to the appropriate Regulations (see Appendix 6) and associated guidance published by HSE. REC0RES 103 There are a number of references in various sections of this Guidance Note to the keeping of registers and records. For ase of reference these requirements are summarised in Appendix 5. 104 Where an employer ceases to operate, it is recommended chat the Health and Safety Executive be notified and the records of air monitoring and employees' occupational health records transferred to HSE. Disc No 250/20-30 BH 30 CM* 007321 APPENDIX 1 PROPERTIES OF VINYL CHLORIDE SYNONYMS CHEMICAL FORMULA PROPERTIES General Physical Chemical Boiling Point Freezing Point Flash Point (open cup) Liquid Density Vapour Density Solubility VC, Vinyl Chloride Monomer, VCM, Monochioroethylene, Monochloroethene CH2 - CHC1 Vinyl Chloride is a colourless gas at ambient temperature and pressure with a sweetish odour at high concentrations. It is normally stored and handled under pressure as a colourless liquid -13.9C -153.7C -78C 0.983 (at 20C) 2.15 (relative to air at 20C) Readily soluble in most organic solvencs but only sparingly ia water Vinyl chloride will polymerise exothermically under the influence of light, air, oxygen and initiators such as benzoyl peroxide. Pure vinyl chloride is thermally stable to quite high temperatures, however, peroxides formed by slow reaction with oxygen in air may initiate polymerisation. Stablisers, such as benzoquinone or p-methoxyphenol, and storage in an oxygen free acmosphere tnnibic adventitious polymerisation CMA 007322 APPENDIX 3 Dear Doctor CONTROL OF SUBSTANCES HAZARDOUS TO HEALTH REGULATIONS 198APPRO VED CODE OF PRACTICE FOR THE CONTROL OF VINYL CHLORIDE AT WORK Mr/Mrs/Miss Dace of Birth Address is about to leave/has just left employment here where ha/she was registered as a worker potentially or actually exposed to vinyl chloride monomer (VCM). Exposure to high levels of VCM has been associated with angiosarcoma fibrosis of the liver, portal hypertension due to non-cirrhotic periportal/and acro-ostsolysis particularly of the terminal phalanges of the hands. Other effects have been reported as occurring in workers chronically exposed to vinyl chloride monomer at similar levels of exposure, although such reports have been disputed by others. These include tumours of tne brain, lung, haemo-lymphopoietic system, and skin (malignant melanoma), lung function disorders, thrombocytopoenia and immune complex disorders. Effects on reproduction have also been reported. Whilst exposure to such levels is unlikely to have been incurred since 1975, the latent period particularly for the firsc two above mentioned conditions may be prolonged. May I cnerafore suggest that this letter which (together with the patients form of consent) has been approved by the General Medical CMA 007323 Council, be filed in your patient's NHS record card. Should any clinical suspicions along these lines arise in che fucure you might like co consider contacting me or my successor. I hold, and enclose copy of, your patient's signed informed consent to this which means chat you need not hesitate from taking such a step early in your considerations of differential diagnosis from fear of groundlessly alarming your patient. Should this factory have ceased trading, the Employment Medical Adviser for your area, who can be found in the telephone book under Health and Safety Executive would know the whereabouts of your patient's factory medical and exposure records which are being preserved for 50 years from the end of his/her employment here. If you would like any further information or explanations, please do not hesitate to contact me now or in the fucure. I will be glad to assist in any way possible in che interests of your patient's, our ex employee's, well-being. Yours sincerely, APPOINTED DOCTOR APPENDIX 4 CONTROL OF SUBSTANCES HAZARDOUS TO HEALTH REGULATIONS 198APPROVED CODE OF PRACTICE FOR THE CONTROL OF VINYL CHLORIDE AT WORK MEDICAL SURVEILLANCE (Give surname and full fore names, give date of birth thus eg 3 SEPT 36 I, ............................................................................................... born of ........................................................................................ ................. ................................................................................................................. hereby give consenc for the Appointed Doctor or the Area Employment Medical Adviser to discuss with my family doctor my medical and occupational history and I also consent to the release to my family doctor of such records insofar as they relate to my exposure to Vinyl Chloride Monomer. I confirm that Dr .................................................................. , Appointed Doctor has explained to me the reasons for this consent being sought and I believe thac I have understood these reasons. I agree to a copy-of this consent and explanatory letter, vnicn I nave seen, being sent to my present family doctor. Dr .............................................. ....................................... of ....................................................................................... .................................................... Signed 3ate .. Witness CMA 007325 APPENDIX 5 RECORDS The records which should be kept in relation Co the control of vinyl chloride at work are summarised below with cross references to the relevant paragraphs of the main text of the Guidance Note. (a) Assessment (paras 22-29); (b) Atmospheric monitoring (paras 55-57); (c) Maintenance of monitoring equiment (para 53) (d) Leakages of vinyl chloride (para 59(1); (e) Examinations of ventilation equipment (para 59(2)); (f) Excursions above che alarm levels during area monitoring (para 59(3)); (g) Personal monitoring (para 59(4)); (h) Names of persons trained and autnorised to use respiratory protective equipment (para 66); (i) Inspections of respiratory protective equipment (para 69); (j) Permits-to-work (paras 71 and 77); (k) Maintenance of control measures (paras 79 and 30); (l) Register of registered workers' (para 33) (m) Occupational health records of registered" workers (paras 91 and 92). Records may be kept in any suitable forms, including microfilm, compucer or similar techniques, provided tney can be reviewed readily when required. Occupational health records should be kept for 50 years after che last entry made in them; Records of atmospheric monitoring should be kept for at least 30 years. All other records should be kepc for a minimum of 2 years. CMA 007326 APPENDIX 6 LEGAL REQUIREMENTS Some additional legal requirements relevant to the handling of vinyl chloride may be found in the following:- The Health and Safety at Work etc Act 1974 The Factories Act 1961 The Alkali etc Works Regulation Act 1906 The Emissions into the Atmosphere Regulations 1983 The Control of Pollution Act 1974 The Control of Substances Hazardous to Health Regulations 198 The Notification of Installations Handling Hazardous Substances Regulations 1982 The Control of Industrial Major Accident Hazards Regulations 1984 The Dangerous Substaaces (Conveyance by Road in Road Tankers and Tank Containers) Regulations 1981 The Dangerous Substances (Conveyance by Road in Packages etc.) Regulations 198The Classification, Packaging and Labelling of Dangerous Substances Regulations 1984 The Notification of Accidents and Dangerous Occurrences Regulations 1980 The Reporting of Accidents and Dangerous Incidents Regulations 198- CMA 007327 APPENDIX 7 CHECKLIST OF MAIN CONTROL MEASURES CONTROL i'SASURES FOR MATERIALS. PLANT & PROCESSES (Paras 30--36) CONTROL OF EXPOSURE (Faras 19-20) AIR MONITORING (Paras 37-62) ALARM LEVELS (Fara 21) FERMITS-TO-VCRK (Paras 71-78) RESPIRATORY PROTECTIVE EQUIPMENT (Faras 63-69) MAINTENANCE OF CONTROL MEASURES (Faras 79-80) - Plant should be designed and operated to minimise exposure to vinyl chloride - Plant should be sited in the open wherever possible - Good general ventilation should be provided in process buildings - Local exhaust ventilation should be provided where emissions from plant may occur that cannot be eliminated by improved design and maintenance - Fersonal exposure to vinyl chloride should be controlled to below 7 opm 8 hour TWA - Vinyl chloride in the air of working areas should be controlled to below 3 ppm averaged over a year - Fersonal monitoring is required to check compliance with the 8 hour TWA Control Limit - A static monitoring system is required for the monitoring of vinyl chloride in the air of working areas - Air monitoring system required for the detection of-high levels of vinyl chlori and to sound an alarm at the following levels! 15 ppm measured over 1 hour "20 ppm measured over 20 minutes 30 ppm measured over 2 minutes - Fermits-to-work required for all work in confined spaces and some -maintenance - All personnel involved must be properly trained - Required for certain operations, eg entry into confined spaces, maintenance, dealing with leaks of vinyl chloride, emergencies, etc - Only equipment of a type approved or to a standard approved by H3E to be used - To be used only by trained and authorise personnel - Regular and thorough examinations of plant required, especially where leaks may occur - Regular examinations and tests of ventialtion equipment required - Regular checks of other control measures to b carried out CMA 007328 EMERGENCY PLANNING (Faras 81-82) HEALTH SURVEILLANCE (Paras 8^-$4) INTCP.rATIOV, INSTRUCTION 4 TRAINING (Faras 95-97) - Suitable plans required to deal with foreseeable emergencies - All employees should be familiar with relevant emergency procedures - Registered workers should undergo regular medical examinations - All employees should receive adequate information, instruction and training on the hazards of vinyl chloride, the precautions to be observed and the role of joint consultation CMA 007329