Document yp2ogabQKr4BjpV25O49myewn
CHEMICALS
INTEROFFICE / LAKE CHARLES
TO R. E. Hanna FROM B. W. Walker
DATE
June 17, 1974
SUBJECT OSHA Inspection t2
DATE OF INSPECTION: COMPLIANCE OFFICER: CAUSE OF INSPECTION: UNION REPRESENTATIVE:
MANAGEMENT REPRESENTATIVE:
June 12 - 13, 1974
Steven D. Herron
Routine - (VCM Process)
Mitchell Andrews Bill Andreas
Bob Lynch Bryant Walker
OPENING CONFERENCE
Mr. Steven D. Herron, Industrial Hygienist with the Department of Labor, arrived at the Lake Charles Plant on June 12, 1974. He requested to see a management representative and was referred to Murry Davis, Safety and Security Director. An opening conference was established at Dewey Duncan's office with the Compliance Officer, D. L. Duncan, R. E. Hanna, J. M. Davis and B. W. Walker present at the conference. A questionaire concerning VCM and PVC was given to Mr. Duncan to be filled out by his choice of personnel. Another questionaire was given to R. E. Hanna concerning routine information, i.e., number of employees, names of PPG Officials, address, etc. Mr. Herron asked questions from another questionaire which established whether PPG is covered by the law and other routine questions. Mr. Herron was asked for some identification and he presented his Department Of Labor Credentials. Mr. Herron stated that his primary purpose was to inspect our VCM process and VCM shipping. He also stated that he would like to inspect cur asbestos insulation shop and storage area if he had time. Mr. Herron requested an interview with an employee representative. Mitchell Andrews was called to Mr. Duncan's office for the interview with Mr. Herron. After the interview, Mitchell Andrews stated that Bill Andreas would accompany Mr. Herron on the inspection. Mr. Duncan informed Andrews that the employee representative would not be paid by PPG during the inspection. Mr. Duncan appointed Bob Lynch and Bryant Walker as the employer representatives for the inspection.
INSPECTION
The inspection began in tre Safety Director's office so that Mr. Herron could review our accident records. All recordkeeping was in compliance with OSHA.
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R. E. Hanna 03HA Inspection f2 Page 2
Mr. Herron also reviewed cur personnel and area monitoring results of VCM exposure.
After inspection of the records, Mr. Herron proceeded to the VCM plant to inspect the facilities and monitor an operator for VCM exposure. John Jordan, VCM Operator, and 3111 Andreas were questioned in private by Mr. Herron before the samples were taken. Jordan was asked to collect a VCM sample so that an air sample of his exposure to VCM could be taken. Our lab personnel took air samples at the same time. A picture was taken of Jordan as he attached a sample container to the VCM sample line. Jordan was also monitored as he analyzed the VCM sample in the VCM plant lab. Another picture was taken in the plant lab. Before leaving the VCM plant, John Jordan explained that he had operated the wrong valve on the sampling job which caused VCM to spray out onto his hands. Mr. Herron stated that this will not cause the sample to be invalid due to the probability of this type of incident occuring at any time.
Mr. Herron then requested to be taken to the Shipping Department VCM Tank Car Loading Rack for inspection. After arriving at the loading rack, Mr. Herron determined that monitoring would not be necessary due to new inovations which eliminated exposure. His conclusion was reached after a discussion of the loading procedure with Dean Thibodeaux, Shipping Department Loader, and Charles Burns, Shipping Department Foreman.
After leaving the loading rack, Mr. Herron requested to see our asbestos operation in the Cell Repair Area. Mr. Herron inspected the asbestos storage area first and then walked through the Cell Repair Area. The following proposed violations were noted by Mr. Herron on his first inspection of the Cell Repair Area.
1. Failure to post appropriate asbestos hazard warning signs in the asbestos storage and handling areas and on containers which contained asbestos.
2. Failure to keep a safety shower unobstructed for use. (A floor fan had been placed under the safety shower.)
3. Failure to utilize eye wash fountains in place of hose attached to safety shower.
4. Failure to maintain bench grinder in compliance with standards.
a. The tool rest was not adjusted within 1/8" of the wheel.
b. The top of the guard opening was greater than 1/4" between the wheel and the guard.
5. Failure to provide a safe walking surface around a wet operation. (Later on floor around cathode dip tanks and around cement mixing operation.)
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R. E. Hanna OSHA Inspection nZ Page 3
When Mr, Herron noticed tea lead pouring operation, the asbestos fluffing operation, and the solder ^-irg operation, he decided to return the following cay to obtain personnel -`.-^coring samples on each operation. Before leaving he stated that he would c:'`t..c,: a closing conference and would like to review cur monitoring records on one above mentioned operations.
We proceeded to the Safety Director's office to look at the records and have the closing conference. M. Davis produced the monitoring records as requested and Mr. Herron asked for a copy of each. Copies of the records that were given to Mr. Her-cn are attached as attachments #1, 2, and 3. The closing conference was conducted and will be discussed in a later paragraph.
The following day, June 13, 1374, Mr. Herron obtained personnel monitoring samples from Dennis Clifton and Sydney Clemet on the lead pouring operation; from Peter Carrier on the asbestos fluffing operation; and from Robert Hartman on the solder wiping operation. After Hartman completed the solder wiping operation, Mr. Herron requested an examination of the respirator due to Hartman coughing during the operation. Upon examining the MSA Comfo Respirator it was found to contain two Mersorb cartridges on it instead of the required GMA organic vapor cartridges. This resulted in another proposed violation and possible citation.
6. Failure to provide proper respiratory protective equipment.
CLOSING CONFERENCE
A closing conference was conducted on June 12, 1974, with Mr. Herron, Bob Lynch, J. M. Davis, B. W. Walker and Bill Andreas present at the conference. I should point out that it was the employer's prerogative to allow the employee representative to be present at the closing conference. Mr. Herron explained the proposed violations and the employers responsibility in handling any citations resulting from such proposed violations. He also explained that due to a delay in receiving his sample results, it may be six weeks to two months before any information on the sampling would be available. If the results of the samples indicate a violation of the allowable concentrations, we could receive additional proposed violations which could result in citations In reviewing the proposed violations, it was pointed out to Mr. Herron that the specific standard covering safety showers and eye wash facilities allowed the use of a hose attached to the safety shower. Mr. Herron stated that it was the Area Director's interpretation that "eye wash fountains" must be installed. He remarked that he would check this proposed violation with the Area Director and call us on the decision if it results in a proposed violation.
CONCLUSION
All violations noted by the Compliance Officer are only proposed violations that may or may not resulo in a citation. Issuing citations and establishing
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R. , Hanna OSHA Inspection #2 Page 4
penalties is the prerogative of the Area Director for the Louisiana.Office. If a citation is issued, the violation is considered as alleged until a.15 working day waiting period ends after issuance. During this 15 day period, the employer has an opportunity to contest the proposed violations. If they are not contested, the proposed violations are considered as violations and must be corrected within the prescribed abatement period.
Personnel monitoring samples were taken by our lab personnel each time the Compliance Officer took samples. The results of our sampling are as follows with the TLV indicated for each chemical.
ITEM VCM - Process Operator VCM - VCM Lab Lead - Feed Pot Lead - Pourer Lead - Soldering Job
RESULTS 5.0 ppm 2.2 ppm 71 jjg/m3 34 ijg/m3 169 ;jg/m3
TLV 50 ppm 50 ppm 200 ^g/m3 200 ;jg/m3 200 >ig/m3
BWW/bc
Attachment (3)
cc: A.T. Raetzsch D. L. Duncan R.E. Baker T.G. Taylor J.M. Davis L. Krause J.H. Morgan R.P. Lynch R.E. Eakin J.C. Lafleur H.J. Hoenes C.A. Burns E. L. Cook H.C. Underwood R.E. Sourwine
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'.':Szzrz - ,,,=i cr
" ll"1 i " "3 CT2 S!T-l"Or Z-2~"z::or
SzL'l^r Pot Coerotor
7 - c. v* IP-*' " ^ ** r -- e* >* - - p ^ ~Z At 3 2. Setter Wiping --.rea Pb ;oi Ar02 Solder Wiping Area Fd Pot Area
Az'sst older Wiping lorea Fd Pot Area
Fd Pot Area
Fd Pot Area Fd Pot Area Solder wiring area Solder Wiring Area Fd Pot Area Solder Wiring Area Fd Pot Area Solder Wiring Area
7*v -- ^
\ * , ` _ z' _
___ /* _
P T1
10- 7-vj:
1C- 2- 4-72- 1--71 J *3-15-71
11- -71 11- -71 11- -71 n-ic-71
3-14-72
3-14-72 3-14-72 'p-i4-f2 3-14-72
n-ic-72 11-1C-72
6-21-73 6-21-73
' " V 1.;
Method
Fd
MFul
A
A
A
A
Serried 0'SIY while wiping
A
Ins oars '..1th molten solder. A
B
B
B
B
B B
Sampled OIHY while wiping 1)015.3
Samrled CleY while pouring lead.
B
Semoled while removing slag fren Pot
B
Sampled while pouring lead. Sampled while pouring lead.
B
Sampled while wiping bars. Sampled while pouring Fb. Sampled while wiping bars. Sampled while pouring lead. Sampled while wiping bars.
B
B
B
B B
< 0.03 0.20 0.13 0.05
> o.4o
0.10 < 0.05 < 0.05 < 0.05 < 0.05 < 0.05 < 0.05
0.05
0.10
0.05
SO < 0.05 < 0.05 < 0.05 < 0.05 < 0.05 0.05 < 0.05 < 0.05
Method A: MSA Personael Monihnr, 12 to 48 min samplings. Merced 3: MSA Universal Fd Test Hit, approximately 2 min sample near personnel.
/tT7
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To: From:
Tommy R. Vizena
EMPLOYEE
DATE OF SAMPLE
VOL. LITERS
Alton Thomas Murlin Fontenot Emmanuel Gui11ory Robert Hartman John McNabb Charles DnJcan
Clifton Dennis Peter Carrier Jos. Guidry Raymond Landry Wickley Boullard Simon Woods
4/17/74 4/26/74 4/17/74 4/17/74 4/26/74 4/19/74 5/15/74 4/26/74 4/19/74 4/22/74 4/16/74 4/26/74 5/15/74
0.68 0.64 0.56 0.60 1.60 0.86 0.44 0.58 2.00 0.48 0.74 0.34 1.74
SP. GR.
1.024 1.018 1.021 1.017 1.011 1.002 1.030 1.029 1.007 1.026 1.025 1.020 1.012
UNCOR.
Date:
June 3, 1974
Subject: Houston Chemical1s results
on blood & urine lead.
URINE mg/L , COR.(1.024)
BLOOD mg/100 gm
0.038 0.033 0.057 0.035 0.021 0.027 0.145 0.041 0.034 0.035 0.027 0.033 0.024
0.038 0.044 0.065 0.049 0.047 0.324 0.116 0.034 0.120 0.032 0.026 0.040 0.040
0.033 0.062 0.053 0.060 0.030 0.100
0.045 0.041 ' 0.000 0.050 0.051
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'V
Late 3,,c5-74 3-05-74 3-08-74 3-08-74 3-13-74 3-13-74
3-13-74 3-llf--T2*>14-74 3-15-74 3-15-74 3-15-74
Tyne Personnel Personnel Personnel Personnel Personnel Personnel
Area Personnel Area Personnel Area Personnel
AIR I- FOR WET/H FUMES AlfD RUSTS Fo, Sn, Cu, Zn
Cur:iticn 5 Hours 5 Hours
k Eburs
4 Hours 3 Hours 3 Hours
Job or Area
Anode Pouring
(Dejean)
Solder Wiping
(Guillory)
Anode Pouring
(Clifton)
Solder Wiping'
(Clement)
Anode Pouring
(Dejean)
Solder Wiping
(Guilloiy)
Concentration, ps/m3
88o Fd
580 Fo
170 Fb
1,030
Fo
34o Pb
(310 (280
Fb Sn
3 Hours 3 Hours
Lunch Table Lead Pot Addition
(McNahh )
3 Hours East Wall on Temperature Recorder
3 Hours* Maintenance Welder-Copper (Hayes)
6;3 Hours Between Fb Pots
2.5 Eburs
Cathode Hand Tinning
(Hartman)
7T Pb 500 Fb
25 Pb 450 Cu
69 Fb
( 35
Pb
( 14
Zn
((29 as ZnCl2)
Threshold limit Values for
Above Metal Funss and Dusts (from OSEA Tables)
Fb (Lead, inorganic)
200 pg/M3
Sn (Tin, inorganic)
2.000 ng/M3
Cu (Copper, funs)
100 fig/M3
Cu (Copper, dusts and mists)
1.000 |ig/M3
Zn (Zinc chloride fume)
1,000 iig/M3
* 3 hours continuous cutting of copper with copper rod. This type of work dona appro:ciuately once in two weeks (3 hours).
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