Document zQaVONb6ay3XK3v7OgrRkKaN3

JERRY C.' BIALKO FROM R. D. HARDESTY SUBJECT FIELD POINT OR DIP!. & BLDG. NO. ALTC FIELD POiNt OR DEPT. & BLDG. NO. ALTC ' DATE YOUR LETTER DATE THIS LETTER MARCH 25, 1982 RDH-27-82 . AREA MONITORING UNIT FOR B/413 The VCM polymerization labs in B/413, currently have a six cycle total hydrocarbon analyzer. A yellow warning light comes on at 3PPM, a red light at 5PPM, and a horn at 100PPM. These labs have been expanded with the addition of the two story remodeled stock room, J. C Bialko listed the possible locations for monitoring points. The total number of points was 17; 6 of which were reactors and 2 were weighing stations. The labs in question are not officially designated "regulated areas" as described in the VCM OSHA regulation 1910.1017, because the vinyl chloride concentrations as measured by personnel monitoring, are not in excess of the permissible exposure level. I analyzed the section of the VCM standard requiring continuous monitoring and have determined that legally such a system is not required in this case. Listed ^ below are my arguments. 1. Section 1910.1017 (g)(6) applies only where air-purifying respirators are used. These labs use supplied air respirators with continuous flow. 2. A very strict reading of (g)(6)(ii) leads one to conclude that the purpose of continuous monitoring is to alert employees where the use of a certain respirator is inadequate, not when to don a respirator. In this case, the alarm level would be 3,600 PPM. Except for catastrophic failure of a vesse" this level would never be reached in a lab situation. 3. A more liberal reading of (g)(6)(ii) and adding a similar ruling of OSHA f the acrylonitrile standard 1910.1045 (i)(2) which requires employees to alerted when the ceiling limit exposure to AN is exceeded, would mean tha continuous monitoring should be done to determine when employee exposure exceeds 5PPM. VCM for 15 minutes. This interpretation suggests warning e ployees when to don respiratory protection. Even accepting this interpr tation, there are probably only three operations where 5PPM is likely t exceeded: a. Charging lab VCM cylinders b. Charging reactors c. Dropping reactors into 5 gal pails Therefore, I feel that as a minimum, the existing THA system should be r< monitor these operations. If each reactor had a monitor, this would be It would be possible to double up on some of the reactor stations and g* the existing 6 unit. UFG-49S6-E 1V80LVTHOSNU.S.A. A better solution which would give more peace of mind and a larger safety margin to our employees would be to purchase another collection and GC unit to measure only VCM. This would give us probably 10 VCM monitoring points every li minutes and 6 total hydrocarbon monitoring points every 12 minutes. While I can't say this solution is absolutely required by the regulations. I do feel, due to the experimental nature and associated uncertainty of the operations, it-is the desir able solution. It should also be borne in mind that some of these operations are run 24 hrs. per day, 5 days a week with only one operator on the off shifts. This type operation increases the need for early warning of major leaks. Another possible solution which I do not find acceptable, would be to add another collection unit to the existing THA. This would lengthen the turn around time between the same sample point to 24 or 32 minutes which is just too long for a meaningful warning system. Attachments:. OSHA Stds. Highlighted RDH/wb NGC 15116 RULES AND REGULATIONS 33897 <U<nu,9hrrle eonciintrottM Of Vinyl chtortd* JlffjulrtA apjivotiu (vl) The purpose for. and o> descrip tion cf. the medical surveillance (I) Unknown, or abor 3.<300 ppm... Opon-circult. s*lf-co3U1nl hraihblcg*&pp*;*Uu, pros- program; uro demand typa, with ;ui r.v^pia*^. ivlli Emergency procedures: (II) Not orar 3,400 ppm_____....... (A) CouihlniV.oa V/p* G ituppUed tlr :wplrtor, pr- tvHh Spedttc Information to aid the jsurw demand '.yp. ~'-"a full t* iinU factplece. employee In recognition of conditions tr. l nuxiiliry scll-coaialned air supply: cr (U) Typ C. supplied air ;ntratv'r continuous flor typo. r!ia full or h-Jf fneeplece, tvad ^.-axillary Kli-eontilard sir supply. (Ill) Not over 100 (A) Coatlaaiica typo c supplied nir r'lylrsicr de- tdsrul type, with full f.ir*plw. and auxiliary If-cootained air aupplyi'nr (a) Opea-ctrcuH seU-contelned breathing apparatus With fuH fseplece. In demand mods; or (C) Type C supplied air respirator, demand, type, with full f>veeplec. (It) NotorarSS ppm_______________(A) A powered alf-purtrylasp respirator with hood. helmet* full or half facepiece. &ad a canister WblCh provides a s^rrlc llf of at leaet 4 * hours lor concenrations or vinyl cbiortdo up which may result 1a the release of vinyl chloride: and (lx) A review of this standard at the employee's Itrst training and indoctrina tion program. And annually thereafter. <2> Ail material! relating to the pro gram shall be provided upon request to the Assistant Secretary and the Director. (k) Medical sxrc+xtlance. A program of medical surveiilaac-s shall be insti tuted for each, employee exposed, with out regard to the use of respirators, to vinyl chloride in excess of the action level. The program shall provide each to 26 pom. or such employee with an opportunity far (v) Not over 10 ppm. (B) Qu saaeic. front- or back-roounted canUter which provides a service life of nt least 4 hours for concentrations of vinyl chloride tin to 25 ppm. (A) Combination type C supplled-atr respirator, de mand type, with half facepiece, and auxiliary self-contained air supply; or (&) Typo C supplied-etr respirator, demand type, with half facepiece: or (C) Any chemical cartridge respirator with nn organic vapor cartridge which provides a service Ufa of at least l hour for concentrations of vinyl chloride up to 10 ppm. examinations and tests In. accordance with this paragraph. Ail medical ex aminations and procedures shall be per formed by or unaer the supervision of & licensed physician, vr-d snail be provided without cost to the employee. (l) At the time of initial assignment, or upon institution of medical surveil lance: (1) A general physical examination shall be performed, with sDecide atten tion to detecting enlargement of liver, (5) (1) Entry Into unkown concentra tions or concentrations greater than 38,000 ppm (lower explosive limit) may he made only for purposes of life rescue; find . <ii) Entry Into concentrations of less than 36,000 ppm. but sweater than 3.C00 ppzn may be mads only for purposes of life rescue, itredyruing. or securer* equipment so to prevent a skater hazard from Trieste cf vinyl chloride. <6) Wherb viair-piirifylng'i'respir.atpr^ ^gp-te. used: 3 (i) Air-purlfyin* cannisters or car tridges shall be replaced prior to the expLratlon of their service life or the - end of the shift m which they r.re flrr.t used, whichever occurs first, and <ii> A continuous monitoring' .anit &lann system shall be provided where concentre lions of vinyl chloride could reasonably exceed the allowable concen trations for the derices in use. Such sys tem shall be used to alert employees when vinyl chloride concentrations exceed the allowable concentrations for the devices fn use. (7) Apparatus prescribed for higher concentratio ns may be used for any lower concentration. (h> Jfocnrdox? operations. (1) Em ployees engaged In hazardous operations, including entry of vessels to clean poly vinyl chloride residue from vessel walls, shall be provided ancl required to wour and use; spleen or kidneys, cr dysfunction in these (2) Protective garments shall be pro organs, and for abnormaities In skin, vided clean and dry for each use. connective tissues and the pulmonary U> Emergency situations. A written system (See Appendix A). Operational plan for emergency situa (it) A medical history shall be taken. tions shall be developed for each facility Including the following topics: storing, handling, or otherwise using (A! Alcohol intake; vinyl chloride as a liquid or compressed gas. Appropriate portions of the plan (3> Past history of hepatitis; (C> Work history and ptvst exposure shall be implemented In the event of an to potential hepatotoxic agents, Includ emergency. The plan shall specifically ing druas and chemicals: provide that: (D) Past history of blood transfu (1) Employees engaged Ln hazardous sions: nr.d operations or correcting situations cf ex (S.* Past history of hospitalizations. isting hazardous releases shall be equipped as required ln paragraph (h) of this section: (2) Other employees not so equipped (ill) a serum specimen shall be ob tained and determinations made of: (A) Total bilirubin; (B) Alkaline phosphatase: shall evacuate the area and not return Until cor.dii.5ons are controlled by the methods required in paragraph if) of this section and :he emergency Is abated. (j) Trciir.rtj. Each employee engaged in vinyl chloride or polyvinyl chloride operations shall ce provided training In a program relating to the hazards of vinyl chloride nr.d precautions for Its sale use. cl) The provmm shall Include: (l i The nature of the health hazard from chronic exposure to vinyl chloride including specifically the carcinogenic hazard; <C) Serum glutamic oxa'.acetlc trans aminase u*3COT>; (D> Serum glutamic pyruvic transam inase C3GPT): and (E) Gamma glustamyl traosoeptldnse. (2) Examinations provided in accord ance with this paragraph shall be per formed ac. least: (I) Every <3 months for each employee who has been employed in vinyl chlo ride or polyvinyl chloride manufacturing for IQ years or lotitgr; and (II) Annually lor all other employees. (3) Each employee exited )o an emergency shall be afforded appropriate (iil The specific nature of operations medical surveillance. which could result in exposure to vinyl <!) A statement of each employee's chloride in excess of th.j permissible suitability for continued exposure to limit arid necessary protective a tops; vinyl chloride Including use of protec ' (1) Respiratory protection In accord (IL) The purpose for, proper use. cmd' tive equipment nr.d respirators, shall be ance with i>aragrnpli3 (c) and (g> of limitations of respiratory protective obtained from the examining physician thLv section; nnd (It) Protective garments to prevent skin contact with liquid vinyl chloride cv With polyvinyl chloride n-sLtue from vessel walla. Tho protective garments shall be selected for the c'peratien and devices: <lv) The fire hazard and acute toxic ity of vinyl cldorlde, and the necessary protective .steps: (v) The purpose for and a description promptly after any examination. A copy of the physician's statement shall be pro vided each employee. (5) If any employee's health would ba materially Impaired by continued ex Its possible exposure conditions. of the monitoring program; posure, such employee shall be wlth- NOC 15117 ffOtRAl REGISTER, VOL 39, MO. 194--FRIDAY, OCTOBril 4, 1974 VC M RULES AND REGULATIONS i 45811 Tabu: t.--Kmpi ra lory Protection for AcrvtonUrite tANi W n-.iiiifir (k) Watte disposal AN waste, scrap. i oi ..., jb.u.debris, bags, containers, or equipment ------- > shall be decontaminated before being Concentration of AN or uindlllun of um HhpInUir Dik incorporated in the general waste dis <eiFI(tFighting. <f Euipe ' >al KrKraniMnnl nri-aitiina pruiu oil la <ill .fsfrphrr in poM(l*V pr,-s-.iir- nxHlr. .:..'tSrtr.WU;im<.l tirrnlluAK 4Hir*lus with I oil rarepn-Ct m li*M live priMMiif iiiimU* .. . ill Any larawnar r*tnraior. or 121 Any M'lt runlmiK'd li<-.>thlnK aoiaarnt'iJ. .. posal system. . (mi Hygiene facilities and practices. . < 1) Where employees art* exposed to -.airborne concentrations of AN above the permissible, exposure limits, or whore employees are required to wear <{[> The employer shall select respi rators from nmonq those unproved for use with organic vapors by the Nation al Institute for Occupational .Safety to AN Uv excess of the ceiling limit; a. general alarm .shall be installed and used "to promptly alert employees of such occurrences. protective, clothing or equipment pur suant to paragraph <j) of this section. the facilities required by 29 CFH 1910.141. including clean change rooms and shower facilities, shall be and Ileal tit under the provisions of 30 CTO part 11. (3) Eespiratorpragrain. <i The em ployer shall Institute a respiratory protection program in accordance v/ilh 20 CFR 1910.134 (b), <d). <e). and <t). <ll> Where air/purifying respirators <chcmical cartridge- or canister-type) are used, the air-purifying canister or cartridgets) shall be replaced prior to the expiration of their service life or at the completion of each shift, which ever occurs first. A label shall bo at tached to the cartridge or canister fo Indicate the date and time at w hich it Is first installed on the respirator. (Ui) Testing. Pit testing of respira tors shall be performed to assure that the respirator selected provides the protection required bv table I. (A) Qualitative fit. The employer shall perform qualitative fit tests at the time of initial firtlng and at least semiannually thereafter for each em ployee wearing respirators. <B) Qtatfifftofipe fit. Each employer with more than 10 employees nearing negative pressure respirators shall per form quantitative fit resting at the lime of initial fitting ar.d at Wst sn-miannually thereafter for each snrh em ployee. <tv> Employees who wear respirators shall be allowed to wash tneir faces and to wipe clean the fuee-t o-fae^piei-o seals on their respirators to irinimi'/c potential skin irritation associated with respirator use. -1til Emergency situations. 11 U'rif ten plans, (i) A written plan for emer gency situations shall be devi loped for each workplace where liquid AN is present. Appropriate portions of Uu* plan shall be Implemented in the event of an emergency. (ii> The plan shall specifically pro vide that employees enraged in cor recting emergency conditions shall he equipped as required in paragraph <h> of this section until the emergency is abated. Uii) Employees not engaged in cor <j> ProfrWns* clothinfl and equip- ment.--111 Provision end use. Where eye or skin contact with liquid AN mav occur, the employer shall provide at no cost to the employee, and assure that employees wear, impermeable protective clot him: or other equipment to protact any area of the body which may come in contact with liquid AN. Tb" provision of $-31910.132 ruid 1910.133 shall be complied with. (2l Cleaning and replacement, fit The employer >tia!! clean, launder, maintain, or replace protective cloth ing and equipment required by this section as needed to maintain their effoe: ivenexs. (ii> The employer shah assure that impermeable proicctivu cloLhini: which tonlaets or is likely to havu con tacted liquid AN shall be decontami nated before being removed by the employee. (iii) The employer shall assure Unit an employee whose nommpcrnvabl** clothing becomes wcUcd with liquid AN .shall imn-.cd'e-v!.'.' remove that clothing and piouevU in aliowcr. The cluthiiiK .shall be oeeor.'.animated belts ru it is removed from the l emulat ed area. (iv) Tile employer shall assure that no employee removes protective clout ing or equipment fivm the change room, except -for th-s-e employee.! au- theti/ed to do .so tor the purpose of laundering, mnintei.auee, or disposal. (v) The rniplovcf shall inform any person who launders or deans protec tive clothing or equipment of the po tentially harmful effects of exposure to AN. (k) tiouscktvinng. (1) All surfaces shall be maintained free of visible ac cumulations of liquid AN. 12) For operations involving liquid AN. the employer shall m.-iUVutL* a pro gram lor detecting leaks and spills oi liquid AN. iiit-liub.ni: regular tismd in spections. (3) Where spills of liquid AN arc de- provided by the employer for the use of those employees, and the employer .shall assure that the employees use the facilities provided. (2) The employer shall assure that employees wearing protective clothing nr equipment Tor protection from akin contact with liquid AN {-hall shower at the end of the work shift. CO The employer shall assure that, in the event of skin or eye cynosure to liquid AN. the affected employee shall shower immediately to minimize the dancer of skin absorption. (4) The employer shall assure that employees working in the regulated area wash their hands and faces prior lo earing. (n) il/edicol surci'tllance. --(l > Gener al. <i> The employer shall institute a program of medical surveillance fer each employee who is or will be ex posed to AN at or above the action level, without tcftard to the use of res pirators. The employer shall provide each such employee with an opportu nity for tiuMtcul examinations and LcSUl in accordance with this p;ir.igirtpli- (ii> The employer shah assure that all medical examinations and proce dures are perform d by or under the supervision ol a licensed physician, and tl:a Uwy shall be provided with out ca-il lo the employee. (2> Initial examinations. At the time of initial assignment, or upon in.sl.iiulion of 'he medical suneiliauce promam. the employer .shall provide each alreeled employee an opportunity for a medical examination, including at least the following elements: (I) A work history and medical histo ry with .special attention to skin, respi ratory. and gastrointestinal systems, and those nonspecific symptoms, such as headache, nausea, vomitmv. uivyiness. weakness, or other central ner vous system dysfunctions that may be axsociuled Aith acute or with chronic exposure to AN: recting the emergency shall he evacu ated from the area ami shall not be permitted to return until Urn emergen cy Is abated. . terted. the employer shall assure that surfaces contacted hy the liquid AN are decontaminated. Employee.'; not engaged In decontamination activities shall leave the area of the spill, and (II) A complete physical examination giving particular attention to the pe ripheral and central nervous system, gastrointestinal system, respiratory system, skin, and thyroid; (2) Aferffrto embfoyeeA Where there Is the possibility of employee exposure shnll not be permitted (ti the area until decontamination Is completed. (iii) A 14- by 17-inch posteroantertor chest X-ray; and FEDERAl REGISTER, VOL 43, NO. 1V2--TUESDAY^ OCTOBER 3/ AN NOC 13118