Document zQrX0LxVyXmbgMeQap4E2bV13

II 1 ] A SUBSIDIARY OF RODINTECH A PVC RZSINS, INC * Numbe,*i 4 --'T' ........ ~* 786 HARPY no A rv fAINESVILLC. OHIO 44377 , 1 216-352 - CP.4 1 * twx 810 425 2253 30 975 Occupational Safety t Health Administration, USDL 12^0 ast 9th Street, Room 81*7 Cleveland, Ohio Ml99 Attn: Hr, Kenneth Bowman Area Director v Dear Hr. Bowman: ** ^ The Department of Labor Standards on Vinyl Chloride, 29 CFR 1910.93q dated October 4, 197** has since its promulgat ton.given rise to several questions and possible ramifications on interpretations ofcertain sections. In accordance with our meeting June 13* 1975* during discussion on several alleged violations, we agreed I'd reduce Jthe questions to writing so that the regional or national office(s) could respond* H It Is my understanding that the Standards reference to vinyl chloride on Kay 25* 1975 (page 23072) has been changed from 29 CFR 1910.93q to 29 CFR 1910.1017. References US sections for clarIf1catIon are so indicated. Reference: I II 29 CFR 1910.I017(k)(I) and Appendix A me i --m- wW < * I Since the company must provide each employee the opportunity for examinations and tests, Is it mandatory for the employee to take tests? If abnormalities are found in Initial exam, would follow up test be mandatory on the part of both employer and employee? 2. IF It Is not mandatory for the employee to take the medical examination and tests, whet then is the company* responsibility? Reference: 29 CFR 1910.T017(k)(3) --1 *11 ip 1 1 ' 1 .. 1 3* If under the Standard, 0SHA considers an exposure of 100 ppm to be an emergency, what specific type of medical surveillance should the employee receive? If an employee is exposed to an emergency and refuses medical attention, what is the colony's responsibility? If on emergency occurs In a plant but no employees a re exposed to VCH, would this incident have to be reported within 24 hours to the 0SHA director? I | j : j \ I Occupotion.il Sjfcly Admin is trot ion,U^0L Heal tti * ~* 4 * Attn: Mr. Kenneth Bowman d Jl * i Page 2 Reference: 29 CFR 1910.10)7(k)(4) ftj How would that affect the suftobility statement that each employee ^ Is to receive after the exam from the examining physician if the examinations arc not mandatory? 7* Malpractice suits against physicians are now a major problem. If there is a refusal on the examining physician's part to issue a statement of suitability to each employee after examination, what would the company's responsibility be7 What action should the company then take? /f 4 k 1" ** * #* 1 4 I * fr - , 4. *w * 4 4 * Very truly yours Plant Manager NES :sp 4 i i I- I j VAB.0001052101