Document zzL9Gg0E606MgdZb0N5mo310R

. ij: THE CHLORINE INSTITUTE, INC. 342 MADISON AVE., NEW YORK, N Y. 10017 - . - -**X\ 212 682-4324 .v`rr.,- NOVEMBER 3, 1978 TO : PLANT SAFETY COMMITTEE; PACKAGING COMMITTEE; AND PSC RESPIRATORY EQUIPMENT TASK FORCE FROM : JAMES. H. DOYLE SUBJECT* OSHA CITATION RE. RESPIRATORY PROTECTION VIOLATIONS The ATTACHED twoexamplesof recant OSHA citations issued as Information Items that are cause: for concern to producers, packagers, and consumers of chlorine. The Mead Incident was particularly surprising In that It would appear that the regional OSHA office Is establIshing a precedent In the decision that full- facepiece respirators are the.minimum acceptable protection for chlorine releases. Thelristltutereactedto the citation as noted in the ATTACHED cor-respondenee. Whether the protests registered will prove effective in obtaining a-concession by.the-regional OSHA office remains to be seen. The-othsnrcitation further Illustrates the strict application of OSHA regula- ' tlons once an Incident occurs. Deficiencies in chlorine detectors, written stan dards for respirator use and inspection, and chlorine exhaust and scrubbing systems are Items whichwould cause problems for many chlorine handling faci 1- Ities. .' v> ` --------/^recommended reference to members needing to become morefanrlTlar with OSHA'"'--'-- -~*1 ^ Inspectors1 evaluation method is Program DI rective-#300-^.- For the cost of -- - -..... -- t reproduction* copies. o-this directive, which covers the OSHA Standard Method for*determination'of respiratory protective program acceptabiltty,-can be ob tained from the. Institute offices. This document is issued to OSHA field per- sonnel asa guide In administering the res pi ratory ^regulations contained in - ... 29 CFR 19ID.134* " " r jHD/kss.. .:........ enclosures - - vV LAM023135 f .'.i-'f'-'Xw'V" -> LAA/I023134