Document zogaJ0Z61NQdQQZjZjNogxKD3

vinyl uniGriCe: uuestions ^nd Answers Almost everything you alwey'vented toknov; about OSHA's vinyl chloride standard but were afraid toask JOB SAFETY AND HEALTH MAGAZINE APRIL 1975 "In the average year approximately 150 people are stiuck by lightning Last year 32 cases of vinyl chloride-related cancer were discovered. In view of these numbers, should not workers be required to carry a lightning rod?" Not every question n-ns get asked about its vinyl chloride (vc ) standard is ns fi ivolotis as this one from an anonymous usi of poiyvinyl chloride (rvr) resin. In fact, now that an appeal, court ha-, ruled the standaid is effective Apdl I, 1975. hundreds of logit mate questions--the on: s that get down to the nitty-gutty of how to comply in each plant --arc rolling in. Mere we offer oshv's repl'C1 to some ot the most frequently asked questions I or more general information On the vc standard, check Job Sxfety >1 ' V,VC further questions, write to OSH A Regional Programs. Division of Oecupa- ^ lionnl Health Programming. Room 760. s 1726 M S., N\\, Washington. D.C. 20210. Q. HV know tlitv the standard requires an rionti tring program to tell if an cm- ph'ire tv exposed above the action level or ft 5 ppi t. Oil in /true to monitor vc exposures tor every single employee? A. Each employee need not be per sonal!. monitored, but your moni Uiiu,.; must take into account all iiuployces -- w'hrthcr they wear rcoujinrs or not---and must gv, >. v CiJ determiuat e'iipli.yei exposuics. You might select re presentative employees h'i personal inonitorinu eceiM'dim' to these ci item. t! numhet of emplovees 1st 'luf; their duties, work v-- at,, . and opeiatinns. and wink pi intiecs in force, iinplovec's VC cxpn-aite musi be ICplCsellted lium !' In mav not be net son.alh moiiitoivd 0. II " ...... . the r.,r i: aria! monitor my he dor i s ' into ct/,s -.list A. Where a process is already in operation, monitor ing must be accomplished and regulated areas estab lished by April 1, 1975. We recommend that new processes be monitored within one week after start up and regulated areas established as soon as possible after the monitoring results are available. Q. We use pvc. but extensive monitonnv has shown that VC concentrations arc below the permissible limit--one ppm as a time-weighted average and five ppm as a ceiling. Do we hat e to establish a "regulated area1" What if concentrations arc t -'m. the "action level" of 0.5 ppm'' A. The standard sets two condition both of which must be met before regulated area is required! ( 1) vc or pvc is manufactured, reacted, pack \ aged, repackaged, stored, handled, or u<c4 2) vc concentrations are in excess o' m. \ permissible exposure limit ^ If conccr.t-cticr.:, thra. arc u permissible limit or the action in do not have to set up a regulated Does every employee in our plant u U , with vc hate to be given rranrnc ` Its about the employees exposed below t/. action level? A. There are no exception'- t training requirement ReerndLhow low the monitoring result- e each employee "encaged ms <>pvc operations" me be given training in the hazard, rckued to vc and tin p.-ono pr . . lions ini using it This nu. 'i: include innmccneinc. oratory, and super vi-r. personnel as well as g- duction workers Q. OnasiniHilh t-ia company a-w we consider ter* arv ernt'lo., rv 7/,v , pi'i'p11 would be c\pott-d obo e the naron Intel tor no ntoii than two weeks a yeai. \1ti\' w p>" them wan nted., a1 t tarns reqinrea by th. Ooiti!-. A. P the woikeiN ,u e exposed above . ., level and if they arv unit emplovees vou it-e lesp,- I7 SL 098193 sible for furnishing medical "exams and holding the records for 30 years or the duration of employment plus 30 years, whichever is longer. There arc no exceptions to the medical surveillance requirements, no matter how short tic- period of exposure, Q. Out company fabneates various packaging ma terials. untie of which use Pvc. Since one o: our plants is pretty much like another, are we allowed to monitor typical operations rather than every single pla"" H'c bilte\c nc can show that vc concentra tions arc nowhere near 0.5 ppm in our operations. A. Your program of initial monitoring must deter mine if any employee is expo ; . ,, .$$ of the action level--0.5 ppm. If the program you propose "gives- a_u tie determination of your workers' expo sures, it is satisfactory. If what you propose, how ever, gives a false reading of wonver exposures and, a> a result, you disregard requires: nts of the standa.J that ate triggered by the action iwel, then your piogrnm is unsatisfactory and you will be in violation of the standard Q. Our company has many plants throughout the country and few industrial hygienistr. hit: we do have an excellent technical center. Can nr monitor by taking giab samples of air in bags and sending them to the technical center for analysis? A. You may use any monitoring method that mea sures the exposures of employees to within the ac curacy requirements given in the standard. For eighthour exposures, the method must be accurate within pius or minus 50 percent from 0.25 ppm through 0 5 ppm within plus or minus 35 percent from 0.5 ppm through one ppm. and within plus or minus 25 pei-cni over one ppm. It must measure 15mimttc exposures within plus or minus 25 percent from or.c ppm on up, Q. How do sou figure out an eight-hour time-weight ed as erage t TV.'\)? A. 1 he basic formula is: f TWA CaT + CbTb...............CnTn 8 whet* C VC coocftntration during any given period time T - duration in hours of the exposure at contration C. For example, the twa for an employee who was exposed to 0.2 ppm for two hours. 3.0 ppm for four hours, and 1.0 ppm for two hours would be as follows: frhour TWA - 2 x 0.2 * A X 3.0 2 x 1.0 1.H ppm Q. H hut procedure will an osiia compliance officer U'C to ih ternunc ceiling-limit vc exposures? A. 1 he ceiling limit for vc is five ppm for any 20 sampling period^undcr 15 minutes. A ceiling sample should be taken when you have my leason to believe --from the context of your operation--that some exposures are higher than the eight-hour time-weight ed average. osha industrial hygienists will measure ceiling exposures as 15-minute samples. At present, we will be taking air samples with charcoal-filled tubes that absorb the vc. In the laboratory the tube can be desorbed with carbon disulfide and the vc detected through gas chromotography. For a detailed ac count of this method, write niosh. Office of Tech nical Publications, 10K liroadway, Cincinnati, Ohio 45202, and ask for a copy of "P&CAM No. 178 " Q. The standard says that within 10 days after monitoring discloses that'ah employee has been over exposed. we must non.'y him ot the results and tell him what steps we're taking to control exposures Our company, though, is using a continuous monitor ing system for vc. How often do we f\as > to nopjs our employees about overexposures if vc levels arc constantly abose or.e ppm? How many tunes do wc have to tell them about our control measun ; ' A. You should report the monitoring results ea-'h month when employees are exposed above the "action level"' ot 0 5 pnm All monitoring results must be included, but they may be reported in * summary form th?.' indic.a'es th: re:a! extent of ex posure. You must notify each individual employee in writing. If you've started to implement a regular program to control exposures, you need tel! the employee about this m detail only once and may cite your original announcement thereaftci Q. We understand that certain processes tnsolving pvc are not regulated P\ tin osha stanaa'J Ow company manw>acture< a pvc part b\ extrusion. Our customers then, nutrt -cut the pat and prat seal or heat weld it to form a gasket 7 he part is heated tc approximately 4y0 F `or J< seconds to form a seal. Is any part ot tin > operation coscrcd h\ the standard? A. The standard exuudes the handling and use of fabricated pv c pioJuei' that don t require mass melting as part of meir further prt>cessinp "Mas.melting" o-eurs wh... th,.- entire stricture t\ l-catcc so that the physical integrity and fomi ot titc input material is lost Obvieu-ly. the melting or plasticiza tion of Pvc molding pellet-, in your extrusion process is covered by the standard However, such operation., as heat scaling (like that done by your customers;, thermoforming, blister packaging, lamination, vaeii urn forming, and heat shrinking, do not destiny the essential form of the fabricated product and so are exempt from the st .nd.uJ Q, I've been a meu: \suipitet fin the last Is sears and latel. I Ii in a hn.1 a ! <t uhord tin ..tale, r- Of VC. I.sets das / Hoik Ssttlt |'\c meat l>aektl'-`ig SL 98l94 film, sometimes cutting it w a hot wire. Accord ing to the OSHA standard, what should our company be doing to protect me? A. Meat packaging films are considered a "fabri cated product" under the osha standard since mass melting docs not occur when they arc cut with the hot wire. Consequently, the packaging operation you describe is not covered by the vc: standard. niosh has conducted research into the possible release of vc during pvc packaging operations and, using instruments sensitive to approximately one ppm, has not detected any \c. However, njosh has determined that when heated, pvc film decomposes into hydrogen chloride and carbonaceous gases. The hydrogen chloride gas, which becomes hydrochloric acid on contact with the mucous membranes of the eyes, throat, and nasal passages, can be irritating at concentrations above the osha standard of five ppm for hydrogen chloride So far niosh has found no health hazard- from exposure to other pvc decom position products, though the investigation is con tinuing. Q. The standard says that it applies to the trans portation of \c or pvc "esccpt to the extent that the Department of Transportation fDOr) may regulate the hazards " Arc the placards dot requires for tank trucks carrying \ e monomer enough to fufill the labeling requirements oi the standard9 If not. what is meant by the requirement that labeling be "legible?" Is a tank truck on the road considered a "regulated areaIt the driver does not help in loading tir unload'ite. is he covered by any of the provisions of the standard? A. There need not be duplication of dot markings that co\or such h i/ardi flammability. However, markings not tequneJ by dot, such as "cancersuspect agent." must be pan of the container label. In other words, when placarding specified by DOT is not -ullicient to meet requirements outlined in the osiiv standard, additional labeling will be required. For working put poses, wc define "legible" as the same size lettering as other emergency or warning in structions on the side of the container or vehicle. A tank truck carrying vc would be considered a regulated area only if it were expected (based on measurements oi other known Diets) that vc con centrations would exceed one ppm as an eight-hour time-weighted uveinge or five ppm as a ceiling. It appears unlikely that a truck on the road would be m this situation. Whether the ttuek driver ie covered depends on the amount of vc he is exposed to. If the exposure is below the action level of 0,5 ppm---as seems likclv --onlv the ttuinim' and labeling piovisious of the Nt.mJ.ird wout.i apply. Q. (I f are expecting shipments of pvc resin after the Standard got,, ,ito effect. The resin is shipped in sealed containers 20 and 40 feet long. How w!ll the standard affect our operation? A. The osha standard does not prohibit importing vc or pvc, but each employer is responsible for know ing the working conditions of his employees and con trolling conditions to meet the standard's require ments. Our information on vc exposure levels in handling packaged resins is limited. Concentrations above the exposure limit have been measured in warehouses where pvc resin is stored. Freshly opened containers, particularly air-tight ones, may release significant amounts of vc to the air. For instance, concentra tions in tracks loaded with bagged pvc resin have been measured at 200 to 600 ppm. It appears that, at the very least, you must d r initial monitoring of employee exposures If the eight-hour time-weighted average is below O f ppn and 15-minute exposures below five ppm. then year duties are reduced basically to labeling containerand training employees. Q. The standard says that no employee can he ex posed to VC concentrations above five ppm nun 15-minute period. What about those emptns - who decide not to wear a respirator jor the o dard's first year? A. Before April I, 1976. the ceiling exposure hr * of five ppm over 15 minutes docs not apply employees who have elected not to wear respire: 'r. They may be exposed to as much as 25 ppm ovn any 15-minute period. Q. The emergency provisions of the standard into effect when sou have a "massive release Exactly how much vc does it take to trigger : provisions? << A. We define a "massive release" as any opei: or place where ihc vc concentration is greater than 100 ppm. For example, a broken pipe in a pvc y plant might cause a massive release. Q. The standard savs that no employees may i-ie. direct contact with vc. What do you mean by contact?" < A. Skin contact with liquid vc Q, The standard requires us to keep a dadv r ; of authorized persons who enter a regulated area What information should >ic include on the roster A. The daily tester should consist of leg,hie re natures--or printed or typed names--and -oci..! se curity numbers of authorized persons. l"-..`.h!c names oi numb, - on die iosiei -lisri " 1 ' sideied as faihne to h.cp a bonaliJe log Ihc , ters must be kept for 30 years. SL 098195