Document zda3zpMQ25O7X3JeY0Zy9pkea

<F^ U.S. DEPARTMENT OF LAHOR Occupational Safety ami McaJch Adminutratiun WASHINGTON, D.C. 20210 WAR 1 2 1975 FIELD INFORMATION MEMORANDUM # 76-12 TO: Regional Adminlstrators/OSHA SUBJECT: Vinyl Chloride, 1910.1017 The Vinyl Chloride standard 29 CFR 1910.1017(g)(1) provides that until April 1, 1976 the use of respiratory protection as mandated by the standard 6hall be at the discretion of each employee for exposures not in excess of 25 ppm* measured over any 15 minute period. Please note that this period is about to expire and that as of April 1, an employer shall provide appropriate respiratory protection and shall assure that employees use such protection. Questions may be directed to Ray McClure in the Washington, D.C. National Office, 202-523-8096 marry J^/white Associate Assistant Secretary for Regional Programs oooozo539 V VC David A. Kuhn :c-onoco) 1 A. DaBerr.ami . LC-VCK c. c . G remi 1 lion, LC-VCM R. A. Darling, Aberaaen J. Uptain, Aberdeen R. T. Ferre 1 1, Oklahoma City W. V. Henry, Oklahoma City F. Ke nnedy , Punca City C. Whetstone, Ponca City D. V. Porchey, Ponca City Dati VI 7/75 Attached are letters from the Department of Labor to Firestone Plastics and Union Carbide giving clarifica tion of certain sections of the OSHA VCH standard. These interpretations may be considered official and may give us some help as we try to comply. In particu lar, I call your attention to a changing attitude some options for respiratory ition of medical surveillance. att. VVC 000020539 c 49 ENCLOSURE / r, Mr. r. 5. Brooknaii , Manager Research , Dcvelo pmeri t and Technical Firestone Plastics Company Pottstown, Pennsylvania 19464 Ser v ices t \ Dear i r . B r o o k rri a n - In response to your letter of July 14, 1975 , petitioning for modification of the Vinyl Chloride Standard , the following determinations have been made: 1- 29 CFR 1910.1017(b)(5) Definitions In regards to the definition of "massive release" in Program Directive 200-35, we agree that the definition should be modified. This will be addressed in a future program direc tive . In all probability the stimulation o' 100 ocm ; 111 be removed. 2. 29 CFR 1510.1017(b)(6) Definitions The standard defines a fabricated product as being one which is "made wholly or partly from polyvinyl chloride, and which does not require further processing at temperatures, and for times, sufficient to cause mass melting of the polyvinyl chloride resulting in the release of vinyl chloride." "Release of vinyl chloride" means the release of an amount of vinyl chloride which would likely result in employee expo sure at or above- the action level without regard to the use of engineering controls. Products which can be classified as fabricated products ore exempt from the provisions of the vinyl chloride .standard. All other products are subject to the requirements ol. the standard. It the employer uses or manufactures a product which is not a fabricated product, he must initiate monitoring procedures. If the monitoring reveals Ltnnt the employees are not exposed to vinyl chloride at or above the action level, the employers' operations will be exempt from the provisions of the standard. VVC 0000205^0 However, if kh e woiiitoi mg rcvsals exposure at or u'dovg the action level, the employer must implement the procedures specified in the standard. 3 = 29 CFR 1 3101 ,1017 (cj J { i ) ( ii i ) Respiratory protection Regarding your suggestion to add a Type C, Supplied Air Respirator, Pressure Demand type, with lull or half facepiece to this sect!on: If an employer can show that a respirator provides equal or greater protection than those specified in the standard, he may be granted an interim order or a variance from the standard* Your company received *n interim order . dated May 30, 1975. 4, 29 CFR 1910 . i. 7 ( k ) Medical surveillance There is no OCHA regulation requiring an employee to submit to a medical examination. If the employee refuses any medical examination required to be provided by the employer, the employer shall inform the employee of the possible health consequences of such refusal and obtain a signed statement from the emolovee indicating that the c-n.plovee understands the risk involved by refusal ro be examined. We greatly appreciate your sharing data, experience and knowledge v/ith us. At the present time there are no plans to formally amend or modify the vinyl chloride standard. We hope that the above clarification of the regulation will satisfy the request in your petition. Should you have further questions please do not hesitate to contact us. for Reg ional r r o V ' n s Copy -h o ?. C, l/alk ?r 1P/26/75 Copie s to: \ r P. Connolly Mr . J ,, J. Cnsr.idv, Mr . c. J. I-leinert Mr I p1-i . P. u Hoy Arnold Mr . H. x * V.'ast Mr . G ! P. LI oyd Mr A Park oooozo^1-