Document 0q8OLkanKDwoN809w3go0yqJO

FILE NAME: Avondale (AVD) DATE: 197D DOC#: AVD DOCUMENT DESCRIPTION: ,ZWZZ^Z Z ., ~ ..._::;;;.!:........., ... STATENENT OF THE SHIPBUILDr:RS COUNCIL OF AMERICA WATERGATE 600 WASHINGTON D. C. 20037 presented at A Hearing Regarding Proposed Emergency Standard on Asbestos On 14 March 1972 before Office of Safety and Heal th Standards, Mr. Arthur Goldberg, Hearing Examiner by: David R. Lavalette Representing the Shipbuilders Council PLAINTIFF'S EXHIBIT SBCA 5086 STATEMENT l{EG/>iHJ)INC PROPOSED RULE MAKING FOR ADOPTION OF EMERGENCY STANDARD ON ASBESTOS DUST.(29 CFR 1910,93) l. Although we understand,. and are in agreement with, the intent of the subject proposed rule moking, we feel that as presently draft- ed, the proposal requires clarification and is not practicable. Specific sections where a need for change is indicated are discussed, and changes are proposed which would eliminate ambiguity, render implementation practicable, and assure attainment of the objective. 2. Par.1P,raph 1910.93e states: ''Warning signs shall be provided and displayed at each location where asbestos dust hazards are present. Signs ~hall be posted at least 50 feet in each direction from the location where the haznrd is present, and at intervals of not more than 100 feet along each edge of the area -where the hazard is present." This requirement would present noproblem for fixed shore side facilities such as pipe covering fabrication shops, although there appears to be no necessity for posting such areas except on access doors, provided good ventilation control is maintained. However, this requirement would impose a hardship aboard ship. It could effectively close down a complete ship under construction or repair during pipe covering or boiler bricking operations. As stated, the proposal would require either the posting of a complete vessel or constant moving of signs as work locations change through- out the ship. The purpose of the signs is obviously to warn employes of the existence of a potential hazard in the general area of operations producing airborne asbestos dust, and hence prevent their exposure. 'i'hc key words in the proposed paragraph are "where asbestos dust hazards ::n:-e present". Since "dust hazards'' are not defined, T.Je assume that dust hazards are deemed to e~ist when the concentrations specified in Paragraph 1910.93a are exceeded. In order to clarify this and obviate the necessity for signs when levels as specified in Paragraph 1910.9Ja arc not exceeded, we propose the following addition to section 1910.93e: "Signs ,are not required in areas where the environmental sampling as conducted in accordance with Paragraph 1910.93f indicates that levels specified in Paragraph 1910.93a are not exceeded." J. P:ir.1grnph 1910.9Jf states in part: (f) Monitoring - (1) Personal. "Employes engaged in the particular opcr.'.ltions or using the purticul.:lr tools specified in paragraph (d) o( this section, or exposed to concentrations of asbestos dust in excess oE the limits specified in paragraph (c) (3) of this section sh.:i ll be moni tared in accordance with this paragraph." (iv) S.:impling frequency - "S.1mpling periods shall be of such number and p.:ittern as to represent accurately the exposure of the employes oyer their working period." (2) Envi ronmenta 1. "Environmenta 1 moni taring sha 11 be conducted in nll .:1rc.:1s in which employes are exposed to concentrations of asbestos dust in excess of the limits specified in paragraph (a) of this section." (iv) Sampling frequency. "Sampling periods sha 11 be of such number and pattern as to represent accurately the exposure of the employe~ over' their working period." - 2-  .... . Although not specifically stated, there is an implication thnt s~mpling will be required daily for all individuals and environ- ments exposed to asbestos dst. At least .the standard could be so interpreted in the absence of more specific language. We feel that representative sampling for all types of opera- tions should suffice to prove the pers_onal and environmental exposure levels 1 and serve as a basis for prescribing the need for engineering controls and/or protective equipment as appropriate. Virtually all shipbuilding and ship repair operations are repetitive and similar operations are not likely to produce exposures which vary significantly from <loy to day provided proper control measures are imposed. Wt', tlie?refon', propose th<: addition of the following state- nt('lll to Paragraph L1)10. ') J [: ''Whnrf' dw:t pr(1dueing operntions are repetitive in natur0, it is sufficient to perform and document sampling for each typical type of operation 1 and consider such results as accurate- ly reflecting employe exposures over their working period. Sampling is required whenever operations, m3tcria~s, or control measures change in such a mnnncr as to create potent- ial exposures which differ significantly from such typical operations. Sampling of typical operations shall be repeated at least annually to verify prior results." 4. We feel that adoption of the proposed rule making would seriously and unjustifiably impact shipbuilding and ship repair -3- - in p10Ll!l0 Linn o( the cmploycs ..ind the environment equ.:i l to or better th.in the proposed rule making. We feel that the addition of a qu,rntit<1.tive definition of "dust hazard" as suggested will encourage users to employ engineering controls at the source of emissions) thus minimizing the need for signs by reducing ntmospheric concentrations of asbestos dust in surrounding areas. We believe that the suggested addition regarding sampling frequency will minimize confusion, and is consistent with good industrial hygiene and engineer- in~ pr.icticc. -4-