Document zo3BRw4nVma7kJo7wG7zwZ15g

POTTSTOWN PLANT EVALUATION OF OSHA COMPLIANCE ISSUES November 16, 1989 by Mike Buczynski Action Items Updated January 30, 1990 Corporate Medical Department OCC 11306 f-' mo OOO MEMO To: Bill Lessig December 13, 1989 From Mike Buczynski cc: Robert Gilligan, M.D. S' Subject: Industrial Hygiene Program - Pottstown j I visited the Pottstown facility on November 15 and 16 for the purpose of evaluating the industrial hygiene needs identified by the Industrial Hygiene Questionnaire. The Industrial Hygiene Questionnaire concentrated on compliance issues in the following six areas: 1) Hazard Communication 2) Respiratory Protection 3) Noise - Hearing Conservation 4) Chemical Exposure 5) Substance Specific Standards 6) Access to Exposure and Medical Records GENERAL INFORMATION The Pottstown facility is part of the Plastics & Polymers group. The plant is made up of three independently operated entities: the Resin Plant, the Fabricated Products Plant, and the Pilot Plant. The Pottstown facility was acquired from Firestone Plastics in late 1980. Previous to the acquisition, the site had housed a tire plant along with the plastics facilities. The Resin Plant manufactures suspension and dispersion types of PVC homopolymer and copolymer resins. It employs approximately 275 hourly and 86 salaried persons, including site service personnel. It has OXY \s Occidental Chemical Corporation OCC 11308 industrial Hygiene Program-Pottstown page 2 the capacity to produce 120 million pounds of dispersion, and 72 million pounds of suspension resins per year. The plant operates 3 shifts per day, seven days per week. PVC resins are manufactured by reacting vinyl chloride monomer (VCM) or VCM and vinyl acetate in the presence of initiators and various dispersing and suspending agents. The reaction is exothermic and takes place under pressure in temperature controlled reactors. Product is shipped in bulk in rail cars and tank trucks as well as in bags. The Fabricated Products Plant takes various resins acquired on the open market and blends them with other ingredients such as plasticizers, stabilizers, fillers and pigments. The blended material is then Banburyed, milled and calendered into films on three of four calender lines. In addition to PVC resins, the plant also calenders ABS resins. Product films are shipped as rolls to either the Salisbury Plant for printing or to customers. This operation will be shut down January 1, 1990. The Pilot Plant has the capacity to produce either dispersion or suspension resins in 50 to 2,400 gallon reactors. It employs 8 hourly and 5 salaried personnel. In addition, the site houses a boiler house, wastewater treatment plant, technical service laboratory and research facilities. cc: B. Donahue B. Driscoll T. Jennings S. Kemp G. Lloyd D. Lull OCC 11309 otctHHo r-i ouo POTTSTOWN PLANT Evaluation of OSHA Compliance Issues HAZARD COMMUNICATION The plant has a written HazCom program, and their labelling system follows the Hazardous Materials Identification System (HMIS) except in some instances where a batch ticket containing all of the ingredients is used on a batch tank. This is perfectly acceptable for process vessels. A complete set of MSDSs is kept in the following locations: Raw Materials for the Areas All Raw Materials Building #1, Reactor Safe Room Building #1, Stripper Safe Room Building #1, Relief Safe Room Building #2, Reactor Safe Room Building #2, Stripper Safe Room Building #2, Relief Safe Room Power House Tank Farm (All Bldg. #1, #2, and Tower Water & Effluent Chems.) Foreman's Office Shipping & Receiving Office Analytical Lab Control Lab Maintenance Office Pilot Plant Prod. Manager's Office Plant Manager's Office Environmental Office Safety Office Engineering, Staff Engineering, Process The chemical inventory for both the Chemical and Calender Plants are up to date except for new CAS numbers and new HMIS ratings received from OxyChem Product Stewardship. These very recent changes need to be added. OCC 11311 Pottstown Plant Evaluation of OSHA Compliance Issues Page 2 Action Plan: Add new CAS numbers and HMIS codes to existing chemical inventory. Target Date: January 31, 1990. Training as required by this standard has been completed, but employees who transfer must be tracked and given proper training. Action Plan: 1) An individual designated for training must be selected. 2) A tracking mechanism for Hazard Communication training of transfers must be developed and instituted. Target Date: December 31, 1989. The tracking system for the receipt of new chemicals and their introduction into the workplace is very elaborate (see attached flowchart). In the course of a walkaround, all containers observed had appropriate labels and their respective HMIS codes. The procedure for informing contractors about the chemicals on site is weak. Action Plan: Revamp and organize contractor policy for information about the chemicals on site. Contractor policy should include the selection and use of proper personal protective equipment. MSDS information should include target organs. This policy should be completed before the maintenance shutdown in July 1990. Target Date: June 1, 1990. I t OCC 11312 I Pottstown Plant Evaluation of OSHA Compliance Issues Page 3 RESPIRATORY PROTECTION The plant has a written respiratory protection program. This program has not been reviewed annually. It was last reviewed on March 4, 1987. Action Plan: Review the written respiratory protection program on an annual basis. Target Date: December 31, 1989. The training of workers in the use and limitations of their respirators is not current. Action Plan: Improve the respirator training program to include proper storage of respirators. It was observed that many full-face respirators were stored in lockers that were full of dust. Even though the individual is responsible for the maintenance and cleaning of his own respirator, an auditing procedure by a responsible foreman is needed to ensure proper cleaning and storage. Target Date: February 1, 1990. NOISE The Pilot Plant and Power House are the only areas that still need sound level surveys. This will complete the sound level survey of the whole facility. Areas with noise are appropriately posted. Representative 8-hour dosimetry data is very old (early 1980s). The equipment used is a General Radio dosimeter, which is very old. Action Plan: Complete the sound level surveys in the Pilot Plant and Power House. The data will then be used to develop a monitoring strategy for representative 8-hour dosimetry to be conducted. Order new Metrosonics db-3100 in sufficient quantity to conduct representative dosimetry. Finally, conduct representative 8-hour OCC 11313 Pottstown Plant Evaluation of OSHA Compliance Issues Page 4 dosimetry for all job classifications identified as having the potential of being exposed to noise at levels 85 dB and above over an 8-hour TWA. Target Date: 1) Complete sound level survey and order equipment by December 31, 1989. 2) Develop sampling strategy for dosimetry by February 1, 1990. 3) Conduct representative 8-hour dosimetry by April 30, 1990. A copy of the OSHA noise standard is made available to all employees, but it must be posted. Target Date: December 31, 1989, for the posting of a copy of 29 CFR 1910.95 in the workplace. CHEMICAL EXPOSURE There are two main plants at Pottstown: 1) A Chemical Plant, which is a PVC plant. 2) A Calendering Plant, which produces PVC film in a variety of colors and thicknesses as required by the customer. The Calendering Plant will be shut down on December 15, 1989, with the exception of the Color Department (see Substance Specific Standards: Lead). During the past year, the ventilation on the Banbury mixers and the calendering line were measured and the ventilation was improved. The closing of the Calendering Plant alleviates the responsibility of air monitoring schedules since there will be no active processes. The Chemical Plant, Pilot Plant and Color Department will have to have a sampling strategy developed and representative air monitoring of OCC 11314 pottstown Plant Evaluation of OSHA Compliance Issues Page 5 hazardous substances present for compliance with OSHA PELs and ACGIH TLVs, whether they are 8-hour TWA or Ceiling or STEL values. There is no formal ventilation survey in the chemical plant since there is very little local exhaust. Most of the ventilation is of the general dilution type and is addressed by an on-going preventive maintenance system. The safe rooms are under positive pressure. Action Plan: Develop a sampling strategy for monitoring all chemical and physical hazards in the Chemical and Pilot Plants. This sampling strategy will include a monitoring schedule with completion dates. Target Date: February 1, 1990. SUBSTANCE SPECIFIC STANDARDS The Pottstown facility must comply with the OSHA standards which regulate the following specific substances. Asbestos - There is asbestos at the Pottstown facility. It is present in the pipe insulation. OxyChem has embarked on an identification and removal policy for all asbestos-containing insulation. As a result, all asbestos at the Pottstown facility has been identified and is slated for removal as funds permit. The asbestos removal is conducted by a licensed asbestos removal contractor. To maintain control of asbestos-related activities, Gerry Lloyd and appropriate selected personnel from maintenance should attend an EPA-certified asbestos removal course. Action Plan: Select a site where the EPA-approved course is taught and send the appropriate attendee. Target Date: March 30, 1990. OCC 11315 Pottstown Plant Evaluation of OSHA Compliance Issues page t> * Lead - The Color Department mixes pigments, some of which contain lead and chromate, to produce the required color in the vinyl film. Even though the Calendering Plant will be shut down, the Color Department will remain in operation. Over the years, industrial hygiene air monitoring was conducted until the pigment's physical state was changed from a dust to an oil dispersion. Medical monitoring is conducted (blood leads) and all values are well below any standards requiring action. VCM - The Chemical Plant uses vinyl chloride monomer and produces the polyvinyl chloride resins. There is a very extensive respirator program in place for employees in the VCM areas, which is in compliance with 29 CFR 1910.1017 (g)(4). Proper signs are posted warning of the cancer-suspect-agent area in accordance with 29 CFR 1910.1017 (L)(l). Employees interviewed indicated they have had extensive training as the hazard communication standard requires. They knew where to look or whom to contact for information. While on the job, full-face respirators are kept in canvas bags which are readily accessible to air hook-ups in the control room. The control rooms, or safe rooms as they are called, are maintained under positive pressure. This can be checked by a monometer in the room. While conducting the walkaround and observing the monometer, it appeared that the safe room was under negative pressure. This was due to the fact that the doors to enter the safe room were wedged open. Once this was corrected, the monometer registered a positive pressure in the room. While walking up the stairway to go to the thirdfloor safe room, it was observed that all exit doors were wedged open. Finally, during the walkaround, a white alarm light in the stairwell was on. According to the procedure, there are four alarm lights which indicate various air levels of vinyl chloride monomer. These alarm lights are the result of air monitoring by an extensive fixed point monitoring system. As per the procedure (see attachment), if a white alarm light is on "immediately evacuate affected area, re-enter only if wearing air line respirator (or airpack)." OCC 11316 Pottstown Plant Evaluation of OSHA Compliance Issues Page 7 As stated earlier, the white light was on, but workers were observed on the floor without the respiratory protection outlined above. The safe room doors were open. When interviewed, the employees stated that no one had turned the alarm light off. Clearly, this is a breakdown in communication of procedure and deserves close scrutiny by management. Action Plan: Review VCM respiratory and alarm procedures with respective job classifications in the chemical plant and ensure that they are adhered to. Target Date: March 1, 1990. EMPLOYEE EXPOSURE MONITORING - VCM Representative air monitoring of employee exposure to VCM in all job classifications is conducted. Approximately 150 to 175 employees are monitored each month. The current method is the use of a 3M badge. The badge is uncapped and clipped on to an employee's time card. The employee is relied upon to place the badge on his lapel and remove it at the end of the shift and deposit it uncovered in a collection box. John Sperat collects the badges, caps them, and sends them to the lab (in-house) for analysis. Jack Larkin, chemist, is responsible for the analysis using a NIOSH-approved method, and extreme care is taken to obtain the analysis, complete with standards comparison and quality assurance. After the sample is analyzed, the calculations to determine the 8hour TWA always assumes an exact 8-hour (480 minute) sampling time. This simply does not occur every time, especially since the employee is relied upon to place his/her badge and remove it with no time-on/time-off recorded. occ 11317 Pottstown Plant Evaluation of OSHA Compliance Issues Page 8 Action Plant: Change the computer program which assumes sampling time of exactly 8 hours, and regain control of the placement of the badge with recorded time-on and time-off. Placement and removal of the badge should be by a qualified individual trained in industrial hygiene. Target Date: February 1, 1990. ACCESS TO RECORDS Due to the awareness of the requirements of notification by the Vinyl Chloride Standard, employees know where records are kept, their right of access, and are knowledgeable of the requirement of the Hazard Communication Standard. REMAKES A useful tool for communication is the monthly safety meeting. The three subjects that should be included on an annual basis are: 1) Noise 2) Respiratory Protection 3) Hazard Communication, including access to medical and exposure records. By incorporating these three into the safety meetings, the plant will fulfill the OSHA requirements. MAB:dah OCC 11318 POTTSTOWN PLANT ACTION PLANS For Evaluation of November 16, 1989 by Mike Buczynski 01-89 Action Plan: Target Date: Add new CAS numbers and HMIS codes to existing chemical inventory. January 31, 1990. 02-89 Action Plan: Target Date: An individual(s) designated as HazCom trainer for new employees and transfers must be selected. December 31, 1989. 03-89 Action Plan: Target Date: A tracking mechanism for Hazard Communication training of transfers must be developed and instituted. December 31, 1989. QCC 11320 Pottstown Plant Action Plans Page 2 04-89 Action Plan: Target Date: Revamp and organize contractor policy for information about the chemicals on-site. Contractor policy should include the selection and use of proper personal protective equipment. MSDS information should include target organs. This policy should be completed before the maintenance shutdown in July 1990. June 1, 1990. 05-89 Action Plan: Target Date: Review the written respiratory protection program on an annual basis. December 31, 1989. 06-89 Action Plan: Target Date: Improve the respirator training program to include proper storage of respirators. It was observed that many full-face respirators were stored in lockers that were full of dust. Even though the individual is responsible for the maintenance and cleaning of his own respirator, an auditing procedure by a responsible foreman is needed to ensure proper cleaning and storage. February 1, 1990. OCC 11321 Pottstown Plant Action Plans Page 3 07-89 Action Plan: Target Date: Complete the sound level surveys in the Pilot Plant and Power House. Complete sound level survey and order equipment by December 31, 1989. 08-89 Action Plan: Target Date: The data will then be used to develop a monitoring strategy for representative 8hour dosimetry to be conducted. Order new Metrosonics db-3100 in sufficient quantity to conduct representative dosimetry. Develop sampling strategy for dosimetry by February 1, 1990. 09-89 Action Plan: Target Date: Conduct representative 8-hour dosimetry for all job classifications identified as having the potential of being exposed to noise at levels 85 dB and above over an 8hour TWA. Conduct representative 8-hour dosimetry by April 30, 1990. occ 11322 Pottstown Plant Action Plans Page 4 10-89 Action Plan: Target Date: A copy of the OSHA noise standard is made available to all employees, but it must be posted. December 31, 1989, for the posting of a copy of 29 CFR 1910.95 in the workplace. 11-89 Action Plan: Target Date: Develop a sampling strategy for monitoring all chemical and physical hazards in the Chemical and Pilot Plants. This sampling strategy will include a monitoring schedule with completion dates. February 1, 1990. 12-89 Action Plan: Target Date: Select a site where an EPA-approved asbestos removal course is taught and send the appropriate attendee. March 30, 1990. 13-89 Action Plan: Target Date: Review VCM respiratory and alarm procedures with respective job classifications in the chemical plant and ensure that they are adhered to. March 1, 1990. OCC 11323 Pottstown Plant Action Plans Page 5 14-89 Action Plan: Target Date: Change the computer program which assumes sampling time of exactly 8 hours, and regain control of the placement of the badge with recorded time on and time off. Placement and removal of the badge should be by a qualified individual trained in industrial hygiene. February 1, 1990. OCC 11324 QUESTIONNAIRE irng tn OOU l L IIndustrial hV61enf]------- 1 [ Facility: s. Prepared By: --ci^u<r Date: r- rS'8? (t CuoTQ Industrial Hygiene Questionnaire facility: Page 1 1 I. HAZARD COMMUNICATION J|8 Pafsy" AU plants must have a written HaiCom program in place which addresses container labeling, material safety data sheets (MSDSs), and training. All new employees must be given training within 30 days of hire and before being assigned to work with hazardous chemicals. The written program should be reviewed annually and signed by the facility manager. The following items are designed to insure that your facility is in compliance with the HazCom standard. a. Do you have an up-to-date chemical inventory? b. Do you have a written hazard communications program? c. Has there been a hazard determination made on all hazardous chemicals? d. Has everyone been trained in the hazards and properties of the chemicals he/she works with within 30 days of the introduction of the chemicals? e. Does training include target organs? f. Are all appropriate containers, tanks, etc. labeled? g. Is the H MIS labeling system used? h. Are these labels in good condition and legible? i. Do you have an MSDS file that is up-to-date and readily accessible? j. Is there a designated individual responsible for assuring that workers are informed of MSDS changes/additions that results in a new hazard being introduced into the workplace? YES z' NO I hi l\ OCC 11327 Industrial Hygiene Questionnaire Facility: ___________ ________ _ Page 2 I. HAZARD COMMUNICATION (Con't) k. 1$ there a procedure in place that requires the Purchasing Department to request and receive a MSDS on all new chemical purchases? l. Is there a tracking system for new chemicals to assure that they do not leave the receiving dock until a MSDS has been received, reviewed and distributed to the appropriate departments? m. Do you have a procedure for informing contractors about the chemicals on site? 1**^0*-*--j / . YES NO occ 11328 Industrial Hygiene Questionnaire Facility: ___ _________________ Page 3 H. RESPIRATORY PROTECTION If the facility uses or provides employees with respirators of any kind (even nuisance dust disposables) or emergency SCBAs (such as Scott Air Paks), the facility must have a respiratory protection program which contains, as a minimum, the following elements: YES NO a. Do you have a written respirator program? * Is the program reviewed annually? b. Have the respirators been selected for the type of contaminant protected against? c. Have workers been trained in the use and limitations of their respirators? Does their training include: 1. an opportunity to handle the respirator? 2. having it fitted properly? Qualitative Quantitative 3. is the fit test current (annual)? 4. if asbestos is handled at your facility, is fit testing conducted semi-annually? 3, testing its facepiece-to-face seal (beard, glasses, etc.)? ^ 6. wearing it in normal air for a long familiarity period? 7. wearing it in a test atmosphere? 8. is the training documented? Have respirators been individually assigned, where appropriate? e. Are respirators regularly cleaned? (This requirement does not apply to disposables.) Are they disinfected? f. Are respirators stored in a clean, convenient and sanitary location? j/; * OCC 11329 * isKtfir , 0 ^ ^ OwioSO; Z. MJo^TW ns-f uo Mt&ZRX \Jar <o-r.MS^y ^ SUMMARY 1^ K IM M ^ industrial Hygiene Questionnaire Facility: --____________ . Page 4 II. RESPIRATORY PROTECTION (Coo t) g. Have workers been instructed to inspect respirators for wear or damage including a leak check, before and after each use? h. Are monthly inspections of SCBA equipment conducted and records maintained? i. Is Grade D breathing air utilized for all supplied-air respirators? Is oxygen content checked? j. Do supervisors maintain awareness of possible changes in workplace exposure conditions and respirator effectiveness through frequent random inspections? k. Hu each worker in the respiratory protection program been medically certified for ability to wear? l. Is his/her status reviewed periodically? YES NO 'ktfV.t*w IfcOi-riFy AcUfvjkS U-.-K. r-Vrj fiats' /.iofX.Ce'1 * If kUt~ /C*o,-o OCC 11330 Industrial Hygiene Questionnaire Facility: . FageS III. XQISB - HEA&CiCL CQ^S&yA.TION There is no OSHA requirement for a written noise program. The regulation does require that we determine whether our employees are exposed at it above the "action level" of 85 dBA as an eight*hour time-weighted average TWA). If they are, the affected employees must be given training, access to tearing protection and audiometric testing. Our practice has been to include all darn employees in the program if there are any sources of noise above 90 dBA in he plant You should hive an up-to-date noise survey on file to show the compliance fficer. Noise surveys should be updated whenever new noise sources are added, r at least every two years. If indicated by the survey, dosimetry should be erfonned on employees in high noise environments. a. Has a sound level survey of the facility been performed to identify areas above 85 dBA within the past two yean? b. Are areas above 90 dBA posted with signs? c. Are workers offered an annual audiometric exam? d. Has representative 8-hour dosimetry been conducted on those individuals identified by the sound level survey? e. Are employees given annual training? f. Doe* thia training include effects of noise on the ear* and the principles of noise generation? g. Is a copy of the OSHA Noise Standard 1910.95 readily available for employees to examine? h. Is proper hearing protection provided for identified employees? Are employees trained in care and use? i. In areas over 90 dBA* is hearing protection usage enforced? YES */ _____ ^ \/ - yl . *-<1. NO OCC 11331 Indusori*i Hygiene Questionnaire Facility: _________________ ____ Page 6 HL NOISE,. HEARINGLCONSERVATION fCon'Q j. Does the program include documentation of: 1. Area and personal sampling? 2. Audiometric testing? 3. Annual training? k. Is the documentation readily available? l. Is special training given to employees who have experienced a standard threshold shift? YES NO OCC 11332 Industrial Hygiene Questionnaire Facility: _____________________ Page 7 IV. CHEMIC At, EXPOSURE For all chemicals in your facility for which there are QSHA Permissible Exposure Limits (PELs) or Threshold Limit Values (TLVs), employee exposure should be determined or estimated. A listing of these limits & values may be obtained from Corporate Industrial Hygiene. Sometimes, a careful review of the exposure potential will result in the conclusion that exposure is minimal or non existent, In other cases, it will be necessary to actually sample to determine the extent of exposure. If exposure (without regard to the use of personal protective equipment) is above the action level (1/2 of the limit), then a program of routine sampling must be established, and an engineering solution investigated. Chemicals for which there are substance-specific standards (asbestos, formaldehyde, vinyl chloride, etc.) should be sampled routinely to generate sufficient data to allow exposure to be estimated with more confidence. (See section V.) YES a. If as a result of sampling an overexposure is believed to exist, have the individual, employees who were monitored been provided with proper personal protective equipment? Is its use enforced? b. Is there ah acticr. plan to engineer out the source of overexposure? c. Is ventilation checked regularly and results documented? d. Have representative exposure samples been taken for all chemicals with OSHA-PELs or ACGIH-TLVs at your facility? e. Are samples taken on a scheduled basis? f. Are they representative of an 8-hour TWA? g. Are area STEL and Ceiling samples taken? . _____ h. Are employees notified of monitoring results? i. Is there prompt 'ollow-up on high exposures? j. Is there proper documentation of: 1. Monitoring data? 2. Sampling/Analytics procedures? 3. Results NO OCC 11333 Industrial Hygiene Questionnaire Facility: ____________________ Page 8 V. SUBSTANCE SPECIFIC STANDARDS If your facility handles chemicals which have been specifically regulated by OSHA as listed below, the requirements of that standard(s) must be met If there are any questions in this area, please call Corporate Industrial Hygiene. Substance Specific Standards have been promulgated by OSHA for the following: 1. Asbestos 2. Coal tar pitch volatiles 3. 4-Nitrobiphenyi 4. a-Naphthylamine 5. Methyl chloromethyl ether 6. 3,3'-Dichloiobenzidine and salts 7. bis-Chloromethylether 8. b-Naphthylamine 9. Benzidine 10. 4-Aminodiphenyl 11. Ethyleneimine 12. b'Propiolactooe 13. 2-Acetylaminofluorene 14. Dimethylaminoazobenzene 15. N-Nicrosodimethylamine 16. Vinyl chloride 17. Inorganic arsenic 18. Lead 19. Coke oven emissions 20. Cotton dust 21. l,2-Dibromo-3-chloropropane 22. Acrylonitrile *4 IfffUC---T-C24. Formaldehyde 25. Ethylene oxide Have the specific requirements of these standards been addressed as to... YES a. Sampling to measure action level? b. PEL, ceiling and STEL concentration? c. Change rooms & shower facilities? d. Medical monitoring? e. Medical removal from workplace exposure? f. Recordkeeping & training? Iz. g. Is there a written program where required? zh. Have regulated areas been established and demarcated as required? NO -- -- /s?/A^ MmHMWM \f fi - OCC 11334 Indusmai Hygiene Questionnaire Facility: _________________ _ Page 9 VI, ACCESS TO EXPOSURE AND MEDICat. ttr OSHA regulations require that employees be informed ann^iiv that they have a right to see and/or obtain a copy of their exposure and medical records Should an employee ask to see his/her data, we have fifteen days to comply' Requests for exposure data will likely be minimized if you discuss the results of any sampling with employees as they tie obtained. The notification of right of access can be done by posting an appropriate announcement on the bulletin board, or by discussion during a safety or communications meeting. If you use the latter method, you must document that fact. Records are required by the standard to be preserved and maintained for the duration of employment, plus thirty yean. a. Are employees informed annually of their right to exposure data and medical records, both put and present? b. An employees notified of their personal exposure data u collected? c. Can you meet the 15-day time frame to supply , requested records? d. Do the employees know of the existence, the locarl-m and availability of records? 2. Do employees know the designated person who maintains these records? f. Do employees know of their right of access? g. Is a copy of the standard (OSHA 1910.20) readily available for employee examination? -m* NO OCC 11335 I OCC 1 1 3 3 6 POTTSTOWN PLANT Summary of Compliance Questionnaire (Percent Complete) Date Evaluate^ Respiratory -HazCotp -Protecting Noise Buczynski Audit 1 l/l 6/89 85 67 93 Buczynski Phone 1/30/90 85 91 93 Chem -EEL. 54 54 Substance Specific Medical Notificpfjpift 100 100 100 100 Open Action 14 10 OCC 11337 ATTACHMENTS OCC 1 1 3 3 8 occo :r pgN-r al oh x c: al corporation F>VO IRESXNS P X V X S X O NT POTTSTOWN , PENNSYLVAN X A location of inventory of hazardous materials in the work area: INVENTORY OF ALL OF OUR RAW MATERIALS IS KEPT IN THE FRONT OF EACH RAW MATERIEL SAFETY DATA SHEET (MSPS) BOCK THAT HOUSES THE SHEETS FOR THE MATERIALS THAT YOU USE IN YOUR AREA. THE WORK AREA USDS BOCKS ARE LOCATED IN THE WORK AREA AS FOLLOWS: (?AW MATERIALS FOR THE AREAS__________ BUILDING #1, REACTOR SAFE ROOM BUILDING #1, STRIPPER SAFE ROOM BUILDING #1, RELIEF SAFE ROOM BUILDING #2, REACTOR SAFE ROOM BUILDING #2, STRIPPER SAFE ROOM BUILDING #2, RELIEF SAFE ROOM POWER HOUSE ^____TANK FARM (ALL- BLDG #1 & #2 & TOWER WATER S, EFFLUENT CHEMS ALL RAW MATERIALS 1 FOREMANS OFFICE SHIPPING & RECEIVING OFFICE \ ANALYTICAL LAB CONTROL LAB MAINTENANCE OFFICE PILOT PLANT PROD. MANAGERS OFFICE PLANT MANAGERS OFFICE ENVIRONMENTAL OFFICE SAFETY OFFICE ENGINEERING, STAFF ENGINEERING, PROCESS P0S5I3LE ROUTES OF ENTRY FROM EXPOSURE TO HAZARDOUS MATERIALS: THERE ARE THREE ROUTES OF ENTRY THAT A HAZARDOUS MATERIAL MAY TAKE TO ENTER THE BODY. THESE ARE INHALATION, INGESTION. AND SKIN CONTACT. MATERIAL. DUST MASKS ARE PROVIDED AND ARE REQUIRED TO BE WORN WHEN WORKING WITH ANY SUCH MATERIAL. REMEMBER THAT INHALING THE DUST CAN ALSO HAPPEN WHEN YOU ARE DOING OTHER WORK IN A DUSTY AREA, SUCH AS SWEEPING THE FLOOR, OR DOING MAINTENANCE WORK ON DUST EQUIPMENT. INHALATION OF HAZARDOUS MATERIALS CAN ALSO OCCUR BY BREATHING IN VAPORS OF MATERIALS THAT VAPORIZE AT ROOM TEMPERATURE OR WHEN HEATED. OTHER ROUTES OF ENTRY ARE POSSIBLE BUT LESS LIKELY TO HAPPEN. FOR EXAMPLE; INGESTION, OR TAKING THE MATERIAL IN BY MOUTH, CAN OCCUR IF YOU EAT OR SMOKE WITHOUT FIRST WASHING YOUR HANDS AFTER WORKING WITH THE MATERIALS, OR IF YOU EAT IN AN AREA CONTAMINATED WITH DUST CONTAINING HAZARDOUS MATERIALS. SOME MATERIALS MAY BE ABSORBED THROUGH THE SKIN WHICH INCLUDES THE SyfiKj. LIQUIDS ARE MOST LIKELY TO USE THIS ROUTE OF ENTRY INTO THE V. 3U? SOME DRY MATERIALS CAN ALSO BE ABSORBED IN THIS MANNER. nWerOUS LIQUIDS AND DRY MATERIALS CAN BE IRRITATING TO THE SKIN WHEN OCC 11339 OCCIDENTAL CHEMICAL CORPORATION ALL AREAS, POTTSTOWN, PA NUMBER: LSP-50 PAGE: IX. REQUIRED RESPIRATORY PROTECTION IN RESPONSE TO VINYL CHLORIDE WARNING LIGHTS AND ALARMS BUILDING I, BUILDING II, THE TANK FARM, BLEND TANK AND SPRAY DRYER AREAS AND PILOT PLANT ARE EQUIPPED WITH CONTINUOUS MONITORING SYSTEMS FOR VINYL CHLORIDE CONCENTRATION LEVELS. THIS SYSTEM INCLUDES A SERIES OF LIGHTS AND ALARMS TO WARN EMPLOYEES WHEN VARIOUS CONCENTRATION LEVELS HAVE BEEN REACHED SO THAT PROPER PROTECTIVE MEASURES CAN BE TAKEN/ THE SYSTEM ALERTS EMPLOYEES AT FOUR CONCENTRATION LEVELS, EACH DESIGNATED BY A DIFFERENT COLORED LIGHT AND AUDIBLE ALARM. THE LIGHT COLORS, CORRESPONDING VINYL CHLORIDE LEVELS, AND PROPER PROTECTIVE MEASURES ARE OUTLINED ON ATTACHMENT #1. WHENEVER ANY LEVEL WARNING LIGHT AND ALARM IS ACTIVATED, EMPLOYEES IN THE AFFECTED AREA MUST IMMEDIATELY LEAVE THAT AREA. EMPLOYEES ARE NOT TO RE-ENTER ANY AFFECTED AREA UNLESS THEY ARE WEARING AT A MINIMUM AN AIR LINE RESPIRATOR, OR UNLESS THE ATMOSPHERE HAS CLEARED AND THE WARNING LIGHTS HAVE GONE OFF. ANY AREA IN WHICH THE CONCENTRATION HAS REACHED 1000 PPM (AMBER LIGHT) CAN ONLY BE ENTERED IF EMPLOYEES ARE WEARING SELF-CONTAINED BREATHING APPARATUS (MSA AIR PACK). ANY AREA IN WHICH THE CONCENTRATION HAS REACHED 36,000 PPM CAN ONLY BE ENTERED FOR THE PURPOSE OF LIFE RESCUE. EMPLOYEES ENTERING SUCH AN AREA MUST WEAR SELF-CONTAINED BREATHING APPARATUS (MSA AIR PACK). OCC 11340 OCC 1 1 3 4 1 LIGHT COLOR WHITE BLUE AMBER (YELLOW) RED VINYL CHLORIDE CONCENTRATION LEVEL 5 PARTS PER MILLION (PPM) OR GREATER, BUT LESS THAN 100 PPM REQUIRED PROTECTIVE MEASURES IMMEDIATELY EVACUATE AFFECTED AREA, RE-ENTER ONLY IF WEARING AIR LINE RESPIRATOR (OR AIR PACK) " 100 PPM OR GREATER, BUT LESS THAN 1000 PPM IMMEDIATELY EVACUATE AFFECTED AREA, RE-ENTER ONLY IF WEARING AIR LINE RESPIRATOR (OR AIR PACK) "' 1000 PPM OR GREATER, BUT LESS THAN 36,000 PPM IMMEDIATELY EVACUATE AFFECTED AREA, RE-ENTER ONLY IF WEARING AN AIR PACK (SELF-CONTAINED BREATHING APPARATUS) AIR LINE RESPIRATORS ARE NOT APPROVED AT THIS CONCENTRATION LEVEL. 36,000 PPM OR GREATER IMMEDIATELY EVACUATE AFFECTED AREA. RE-ENTER ONLY FOR PURPOSE OF LIFE RESCUE. RE-ENTER ONLY IF WEARING AN AIR PACK (SELF-CONTAINED BREATHING APPARATUS). AIR LINE RESPIRATORS ARE NOT APPROVED AT THIS CONCENTRATION LEVEL. sp3-10 ATTACHMENT #1