Document 1Qpe5dLdZ7yQRmQdqLD1wD58X

FILE NAME: Goodyear (GY) DATE: 1981 June 24 DOC#: GY054 DOCUMENT DESCRIPTION: Goodyear Standard Practice Letter - Akron, OH - OSHA & EPA Asbestos Standards C560-A ,7 7; THE GOODYEAR TIRE & RUBBEk COMPANY STANDARD PRACTICE LETTER AKRON. OHIO PERSONNEL FO & GO GENERAL NOTICE PLUS INTERPLANT DELIVER DECATUR TO: SP. NO. OATE June 24, 1981 SUBJECT: ( I) USE OF ASBESTOS - (OSHA STANDARD 1910.95a) (II) DISPOSAL OF ASBESTOS WASTE (EPA STANDARD - CFR - 61) The handling and disposal requirements given in this memorandum apply only to friable asbestos material where fibers can or may become airborne. Such item as Goodyearite gasketing and asbestos reinforced plastics are not included unless the material has been, altered or has deteriorated to where loose fibers are present. ( I) OSHA Asbestos fibers in the atmosphere have been determined to be a health hazard at concentrations exceeding an 8-hour time-weighted average of 2 fibers (longer than 5 micrometers) per cubic centimeter of air. Under Section 1910.93a (f) Monitoring, every employer, "where asbestos fibers are released," must undertake a monitoring-medical surveillance program of considerable expense and duration. It is important that plants not manufacturing asbestos type products avoid being classified as an employer "where asbestos fibers are released" thus avoiding the necessity for implementing a program for monitoring airborne concentrations of asbestos fibers and subsequent medical surveillance of personnel so exposed. Each facility where asbestos type products may now be incidentally used (ie, thermal piping insulation, building insulation, exposed insulating cover for tire builders' hot knife receptables, etc) is to immediately avoid the obvious use of same. This includes the purchase of equipment incorporating exposed fibrous asbestos components subject to operating damage resulting in possible release of airborne fibers. An area of particular concern relates to the need for implementing the proper procedures when removing and disposing of asbestos insulation. Herewith is the1proper procedure for handling asbestos as recommended by Corporate Environmental Engineering, Corporate Safety and Corporate Industrial Hygiene.v . ISSUED BY L . i.* ; ; I OFFICERS OF I THE COMPANY GENERAL MANAGERS -S A L E S D I V I S I O N -, COMPTROLLERS M ANUFACTURING GEN CO U N SEL & d iv is io n SERVICES SECRETARYS DIV IN D U S T R IA L R E LA T IO N S PUBLIC R E LA T IO N S (Tully Leary Hehir "I IN T E R N A T IO N A L C O R P O R A T IO N M ATERIALS MANAGEMENT Moats TREASURY . O IV IS IO N PR O D U C T IO N O IV IS IO N ioltshouser RESEARCH & D EVELO PM EN T Cummings MANAGEMENT E N G IN E E R IN G 1 OTHER 1 Betzhold j CTD nnnn-Tc n Burkett ' -2- ' o y - c :< o ~ < y . L. Issuance and Distribution of an In-Plant Safety Standard Practice Letter Containing the Following Information: _____ " " . Reference: Removing, repairing, and handling friable asbestos When it becomes necessary to repair or remove'friable asbestos material, personnel must use the following procedure*^.:, 1. Notify supervision ; 2. Rope off (barricaide) the areas that could, be contaminated by airborne asbestos fibers . 3. Clear the area of all unnecessary employees 4. Around barricaded areas, place warning signs reading: CAUTION . ASBESTOS DUST HAZARD. AVOID BREATHING DUST. WEAR ASSIGNED PROTECTIVE EQUIPMENT. DO NOT REMAIN IN AREA UNLESS YOUR WORK REQUIRES IT. BREATHING ASBESTOS DUST MAY BE HAZARDOUS TO YOUR HEALTH !! !!! 5. All employees required to work in the affected area shall wear an approved respirator. . . 6. If insulation is to be removed or worked in such a way that fibers may become airborne, the insulation shall be thoroughly wet down before removing or handling. 7. For .all repair work, non-asbestos type .insulation is to.be applied. . . . ., . 8. When each job is complete or at the end ^f^each work shift, whichever comes first, all material thdt-has been removed shall be picked up and placed In an^impermeable1bag or : metal drum and sealed and properly identified. (Material - must be wetted before bagging and d r u m m i n g ? ) ' yjiyostax: asdw *9, ,JoWJ-.e*'ial Is tq.be disposed ,qf-in accq^dance-jWith ,the . ais - iprocqdure* outlined in -Section , 1 1 . - .;, . *10. When job is finished or at end of work shift, clothing shall V; . be placed in an impermeable bag~and sealed. Bag.-shall have ---- -the appropriate' label'applied ^ f t e ^ Q c it ,-shail be sent - .out for proper laundering. Disposable clothing may be used ..... as an alternative. ' ' * Warning sign or lable to read: . : ...... CAUTION .... ...r........ CONTAINS ASBESTOS FIBERS. AVOID CREATING DUST. BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM. ' RTR nnnn7fi 81-82 .. \ -3- June 24, 1981 (II) EPA Hazardous Air Pollutants - Asbestos (40 - CFR-6I) (Copy Attached) . * A. Demolition and Renovation " 1. Demolition or renovations involving friable asbestos material with a surface area of GREATER than 260 linear feet of .piping insulation or 160 square feet of friable asbestos material (egiTeactors, boiler, ceiling insulation): - Notification must be sent to the regional EPA office 2Q_ days prior to starting the work. Detailed information : must be supplied. (See Section 61.22(d) for details). 2. Demolition involving LESS than 260 linear feet of friable asbestos piping insulation or 160 square feet of friable asbestos insulation. - Notification must be sent 10 days prior to starting the work. Minimal information is required. (See section 61.22(B) for details). 3. Renovation - involving. LESS than 260 linear feet of piping insulation or 160 square feet of insulation. - No EPA notification is required. NOTE: Renovation excludes work where load bearing structural members are removed; demolition includes it. Therefore such items as removing piping insulation or reactor insulation or ceiling insulation do not require EPA notification unless more than 260 linear feet of piping insulation or 160 square feet of friable insulation is removed. B. Notification Notification required by EPA is to be handled by each plant. A copy of the correspondence is to be sent to Corporate Environmental Engineering. C. Disposal The procedure outlined in Section 61.22(j)(3)(i) must be followed. This section provides an acceptable disposal procedure which includes wetting down any asbestos wastes and sealing them in a leak tight container for disposal in an approved landfill. Asbestos is not classified as a hazardous waste under the USEPA's RCRA (Resource Conservation and Recovery Act) regulations. However, most states have restrictions on which landfills can accept friable gtr nnnn77 (Over) 4- (II) (con't) . . .. ...... .' . v, 0. Disposal (con't) ... . - ; asbestos material. Also note that although this regulation does not require a metal drum or other rigid disposal container to be used, some state or. areas (eg. Ohio) normally require that metal or rigid drums be used. ; Therefore,'you should review local, applicable agency rules for restrictions and approved disposal sites. ., . : . Section 61.25 gives the criteria for the operation of a landfill site. Assurances should be obtained from the plant's waste contractor that the material is disposed of in the proper manner. If there are any questions, consult the local," applicable agency for details. (Ill) Contractor Handling of Friable Asbestos Then a contractor or other non-Goodyear person may be handle friable asbestos material, the same procedures I and II must be followed. This memorandum should be the agreement we enter into with the contractor. required to outlined in made part of GTR 000078