Document 2RkMkOBnJXbOmjEa9GKLbm2wL

FILE NAME Quigley QUIG DATE 1972 Mar 30 DOC QUIG017 DOCUMENT DESCRIPTION Journal Article with Cover Letter rx) Senge March 30 1972 TO RE Mr. J. J. Marino Asbestos Referring to your memo of March 20 1972 to Mr. A. Osti on asbestos products we can report that the attached reference No. 1 see below summarizes the spraying situation Restrictions on on reference No. 2 attached At the other uses are moment we know probably best of no further summarized local restrictions Reference No. 3 contains much useful additional information on work practices mixing asbestos with other materials scrap collection vacuum cleaning relation of OSHA criteria to EPA emissions standards and recommendations on clothing and laundering thereof Useful background information on derivation of the standard is also given The asbestos situation is currently highly fluid however talk has been heard of separating embedded uses from applications of free fibers We shall keep you posted as definitive rules evolve EKH sm Enclosures 8 Hamilton E. K. Hamilton CC Mr. A. P. Osti RIP Asbestos References 1. BNA -OSHR No. 45 page 950 2 BNA -OSHR No. 45 pages 959-961 . 3 Occupational Exposure to Asbestos - Criteria for a recommended standard U. S. Department of Health Education and Welfare Public Health Service Health Services and Mental Health Administration National Institute for Occupational Safety and Health A 09 0974 850 iH The disaster could have been prevented Hechler told the House The slag pile was not a dam it was just a heap created for the waste products of coal It is garbage the value of human life high time that we start putting he said It is high time above coal company profits that every federal and state agency place a higher priority 4 on protection than production ^' Violation Investigation Hechler told Osborn that Bureau regulations published May 22 water or 1971 in Section 77.216 a state if failure of a silt retaining dam will create a hazard it should be of substantial construction and shall be inspected least once each week by the operator He called Osborn to initiate an investigation under Section 103 at on of the Act Reference File 8503 including a public hearing to determine whether the dam was of substantial construction whether it was inspected on a weekly basis and whether the operator was in nolation of the law Hechler urged Osborn to seek the assistance of the geological survey and the Corps of Engineers Please me a list of all other coal mines in W. Va which provide whether the have a dam of this type and indicate to me operator of such mines is in compliance with this section of the regulation he added Alabama NEW JOB HEALTH BILL WILL BE INTRODUCED TO CONSOLIDATE ACTIVITIES Legislation to consolidate job safety and health responsibilities of various state agencies will be introduced to the Alabama state legislature in late February or early March of 1973 Howard Hendrix director of the Depart- ment of Labor told OSHR The department plans to have industrial hygienists by December a minimum he said The ment will work closely with the Department of of two departHealth which will supply laboratory services Under a federal grant of about 72,000 the department will study system and wanted the work public state conditions in employment to take a agriculture Hendrix said strong look the He at docks said he public employees Their injury and severity rates are greater than those for industrial plants The Federal Government scared small employers Hend- rix said The department preaches voluntary compliance with training and education The key element in the _ department's safety Courses in industrial and health program is safety will be developed training in trade schools and junior colleges and in high schools on a limited basis A Bachelor of Science degree program in ~ safety engineering has been initiated at Auburn Univer- sity Numerous meetings conferences and seminars will be sponsored statewide Hendrix said Last summer at the beginning of the program 500 representatives from in- dustry agriculture health and labor attended a safety and health seminar seminars were held in OCCUPATIONAL FETY & HEALTH REPORTER Current laws tion employee provisions have provide for no advance notice of inspecwalk around and right of entry but these not been used to the fullest advantage in the past Hendrix said Alabama's state plan will be equal to or better than the Occupational Safety and Health Act Hendrix said lie for state federal and local public em hploopyeedes prwoovuislidon be included in the state plan Auburn University is helping to prepare the plan In addition a program is being set up -- -- -- ' New York NEW YORK EPA OUTLAWS ASBESTOS SPRAYING IN CONSTRUCTION PROJECTS City The spraying New York of asbestos fireproofing compounds in is ^...legal as of February 25 because of the city's new air pollution control code passed August 25 1971 which allowed the construction industry six months to change over to acceptable substitutes Beginning February the Department of Air Re- sources will issue Notices of Violation at any construction site where such spraying is being done Following the notices orders to cease and desist will be issued to continued violators Spraying asbestos has been the common fireproofing the steel members of high However studies show increased rates of lung means of buildings cancer and other cancers among the workers who apply this material and concern has been expressed also for exposure to the general public the city Environmental Protection Ad- ministration said Regulations to control spraying operations were promulgated by the Department of Air Resources and the state EPA in April 1970. However even with these controls it was still common for asbestos to escape and an outright ban was sought When the new code was passed however there were no acceptable substitute materials Now three products have been approved by the City's Department of Buildings In January 1971 27 of 36 construction sites in the city were using asbestos spray By December the number was KING KING KINGKING KING oe v4 Asco Asco C . Contractors still must observe even when using the substitute the spraying regulations materials Other major Chicago Boston and San cities including Philadelphia Francisco have banned asbestos spray also Enforcement Assistant Commissioner of Air Resources Harold Romer and Deputy Director of the Bureau of Industrial Air Pollution Control Morris A. Stoltz have worked various manufacturers to develop substitute materials A four inspection force issued nearly 300 summonses and Notices of Violation on spraying opera- tions since the regulations went into effect This force will continue to monitor spraying of substitute materials and also pollution is deeply involved in enforcing the new air code's regulations on the demolition of build cooperation with the Alabama Trucking Association HARI Occupational Safety & Health Reporter ote QUIGLEY 484A01 09 0976 , 959 Full Text a (3 rf) t re LD) OF THE ADVISORY COMMITTEE ON ASBESTOS DUST RECOMMENDATIONS ASBESTOS DUST EXPOSURE - REGARDING THE PROPOSED STANDARD STANDARD FOR FOREWORD The Advisory Committee on Asbestos Dust was estab- lished January 24 1972 to review the Department of Labor OSHA proposed Standard for Exposure to Asbestos Dust published in the Federal Register Jan. 12 1972 and prepare written recommendations regarding the proposed standard The first committee meeting on February 3 1972 was for orientation by the OSHA staff and presentation of the NIOSH Criteria Document Rec- ommendations For an Occupational Exposure Standard for Asbestos by Dr. Marcus M. Key Director Four additional public meetings were held on February 14 15 22 and 23 1972. The Official Report of Proceedings in five volumes 722 pages is known to contain many typographical errors which the Advisory Committee could not correct before the February 26 1972 deadline for the recommendations included in this report The Committee suggests that the OSHA staff correct the file copy since the proceedings are available for public copying The Committee will assist if requested The recommendations which follow represent a majori- ty opinion of the Advisory Committee and are offered in the hope of developing an understandable standard which provides for the protection of the health of the employ ees As required a summary of the dissenting views is included While not charged with making recommenda tions of feasibility the majority of the Committee is concerned as noted in the proceedings and wish to emphasize that Dr. Key and his staff noted the need for variances for several of their recommendations when they presented their Criteria Document The Advisory Committee acknowledges the need for guidance for good work practices but did not have adequate background information or time to prepare a detailed list The Committee requested that the following suggestion be included in our comments Recognizing the extent of the asbestos inhalations hazard in industry and further recognizing the many areas in which work practices may either add to or reduce the hazard it is suggested to the Secretary that a work practices manual to developed which would cover all the various operations and work situations in all industries using asbestos It is felt that such a manual would be of great benefit both to those engaged in the operations and to their employers We wish to emphasize the need to provide training in monitoring techniques and call attention to the need to certify employer industrial hygienists and consultants The majority of the committee believes a variance should be granted pending proper training and availability of mon- itoring equipment // Edwin C. Hyatt Chairman CONTENTS A. Guide to compare specific paragraphs in Proposed Standard Sec 1910.a93) with Advisory Committee Recommendations Proposed Standard a b c d e f g h hour weighted average Methods of compliance Allowable respirators Particular operations and products Warning agns Monitoring Medical examinations Records Adv Committee Recommendations a Allowable Concentrations - b Methods of compliance c Respiratory protective devices d Protective clothing e Work practices f Warning label and signs g Monitoring and records h Medical i Surveillance ii Records See g and h above B. Advisory Committee Approval Views on Each Recommendation Vote Dissenting a Allowable concentrations - Majority 3 of ) No. Mr. Baliff and Mr. Weaver believe that studies and avail abe data proposed February are inconclusive and does standard of 5 fibers 15 1972 Official Report not warrant reducing| to 2 fibers See of Proceedings Mr. Weaver requested permission to submit detailed dissenting view after February 26 1972. See Feb. 22 Proceedings page 22 line 22 through line , page 25 for his initial dissenting view b Methods of compliance Unanimous c Respiratory protective devices - Unanimous d Protective clothing - Majority 3 of 5 No Mr. Baliff and Mr. Weaver believe it is too restrictive to require protective clothing when the greater than 10 times the limit They limit for example 100 to 200 times the concentration is prefer a higher limit c Work practices - Unanimous 1 Warning label and signs - Majority 4 of 5 No Mr. Weaver believes the word Danger should be changed to Caution g Monitoring and records - Majority 3 of 5 No Mr. Haas believes monitoring should be more frequent Mr. Baliff does not believe employers should be required Copyright '1972 by The Bureau of National bd ! Affairs Inc. 4 - no Anre ieer Moin < & . * 960 to monitor only OSHA inspectors for compliance frequency is not feasible See February 22 and 23 Official Report of Proceedings ) Also 1972 h Medical - Majority Mr. Weaver abstained ( Surveillance - Majority 4 of 5 2 Records - Majority 3 of 5 No Mr. Haas was concerned about medical record confidentiality and wants records stored for a longer period of time such as at least 20 years as specified in proposed standard Sec 1910.93 Asbestos dust a Airborne asbestos for any concentration employee shall Exposure to airburne not exceed 2.0 asbestos fibers greater than five microns in length per cubic centimeter of air calculated as a weighted average exposure over the entire working day and during the workday no concentration of asbestos to which workers are exposed shall exceed 10.0 fibers per cubic centimeter The above standard shall become effective 2 years after its promulgation Until that date a weighted average exposure of 5.0 fibers per cubic centimeter and a peak concentration of 10.0 fivers per cubic centimeter shall be in effect b Methods of compliance 1 Engineering methods One or more of the following engineering methods either singly or in combination shall be used to achieve and maintain airborne concentrations of asbestos fibers at or below the exposure limits prescribed in paragraph a of this section 1 Substitution of a material mixture method of operation which will prevent or dissemination of airborne asbestos fibers process or reduce the 1 Local exhaust ventilation designed constructed installed and operated in accordance with the latest revision of American National Standard Institute Funds- mentals Governing the Design Exhaust Systems ANSI Z9.2 and Operation of Local in Application of water or other wetting agent iv Enclosure or isolation of the operation 2 Housekeeping ) Housekeeping methods shall be in conformance with good engineering practices and procedures No dry sweeping of floors shall be performed Where feasible all cleanup of asbestos dust shall be performed by vacuum cleaners or wet methods ^... Asbestos containing tainers shall be collected waste scrap bags and disposed of and con in sealed impermeable paper or plastic bags or in other closed containers and shall be labeled in accordance with sub- sequent paragraph f 3 Personal protection When the limits of exposure to asbestos fibers prescribed in paragraph a of this section are exceeded and engineering control methods required by subparagraph ) of this paragraph are not feasible or do not reduce the concentration of asbestos fibers to or below the limits prescribed in paragraph a of this section the employer shall supply and the employee shall use a personal respiratory protective device and protective clothing selected in accordance with para- graph c and d of this section OCCUPATIONAL FETY & HEALTH REPORTER c Respiratory protective devices 1 Where gineering methods are not feasible or do not reduce cn the concentrations to or below the limits prescribed in paragraph a of this section respiratory protective devices respirators shall be selected and used in accordance with the following conditions Except turs shall be used only when a for envergencies respira variance is required and pending decided or on granted the basis Selection of respirators shall be of peak concentration limits Opils approved 30 CFR Part 11 respirators shall be selected The selection of allowable respirators shall be based on the following concentration limits for each type of device However a respirator approved for higher concentrations may be used 2 For protection up to 5 times the limit a single us valveless filter respirator shall be used 3 For protection up to 10 times the limit a reusable or single use type with valve filter respirator shall be used 4 For protection up to 100 times the limit a ful facepiece high efficiency f^...ter respirator shall be used 5 For protection up to 500 times the limit a power ed high efficiency filter respirator shall be used 6 For protection exceeding 500 times the limt J Type C continuous flow supplied respirator shall be used 7 The employer shall establish a respirator in accordance with the requirements of the latest of the American National Standard Practice for tory Protection Z88.2 with the exception that program revisiontrevissionts Respira no emi ployee should be assigned to tasks requiring use of respirators if his most recent medical examuration In- dicates ) Forced vital capacity less value for age height and sex or than 70 of predicted 1 Forced value for age vital capacity less than 80 of predicted height or sex in addition to at least two of the following criteria a ray evidence of asbestosis b Dyspnea shortness of breath c Rales d Clubbing of fingers 8 The employee shall use the respirator provided in accordance with the requirements of ANSI Z88 2 9 The respirators provided each employee shall be properly fitted inspected cleaned repaired and stored d Protective clothing 1 The employer shall provide each employee with protective clothing when they are required that the to work asbestos in a variance area dust concentration and it will be is projected greater than 10 times the limit Such clothing may be coveralls or similar full body protective clothing and headgear e Work practices ) Asbestos cement mortar coat- ings grout and plaster shall be mixed in closed bags or in other closed containers or in mixers equipped with local exhaust ventilation that conforms to the latest ANSI standard 29.2 covering design and operation of loca exhaust systems 2 Use of compressed air jets for cleaning purposes shall be prohibited unless the following conditions are met re tore Occupational Safety & Health Reporter - 09 0978 ) a, pa CURRENT REPORT ) All persons not engaged in the cleaning operations are vacated from the area 11 All entrances to the area are posted with warning signs or signals in The workers performing personal protective equipment paragraph b 3 of this section the cleaning work use as in accordance with 3 Employees exposed to the spraying of asbestos to the demolition of pipes structures or equipment covered or insulated with asbestos or to the demolition of insulating strippings shall be provided with personal tection in accordance with paragraph 6 of section prothis f Warning label and signs 1 Proposed warning label for raw products mixtures and finished products containing 5 or more percent by weight of asbestos DANGER DO Contains ASBESTOS fibers Do not make unnecessary dust NOT BREATHE DUST MAY CAUSE ASBESTOSIS AND CANCER 2 Proposed warning sign to products require an asbestos known hazards exist be used warning when material or label or where ) <7 DANGER Asbestos Dust Area Unauthorized persons and other trades KEEP OUT When asbestos work is being done Breathing Dust May Cause Asbestosis and Cancer g Monitoring and Records Employee exposure mon itoring shall be undertaken by the employer on the basis of the membrane tion 4 millimeter filter method at objective phase 400-450X magnifica- contrast illumination as specified by NIOSH in Criteria for a recommended standard ... Occupational Exposure to Asbestos HSM72-10267 Employers will be required to maintain records of employees exposure to asbestos in the work area based on the following monitoring schedule and procedures 1 Personal exposure Breathing Zone samples will be collected and recorded at least every six months for projected high collected from a whose exposure risk work operations Samples will be number but not necessarily all employees may be considered representative of the specific work area 2 Personal exposure samples will be collected and evaluated as both weighted average and peak values 3 Personal exposure samples will recorded at least once a month from found to be in excess of the standard be collected and those work areas 4 Monitoring will until the workplace air standard be required levels are in on a monthly basis compliance with the 961 5 The first sampling period will be completed within a time frame specified by the Secretary 6 Records of the evaluation of the workplace air will be maintained by the employer for a period of time determined by the Secretary of Labur Employees shall have access these records ; 7 Exposed employees shall be informed of the workplace air levels h Medical 1 Surveillance A comprehensive history and physical examination shall be performed on all workers and applicants This shall include a chest roent genogram posterior 14 X 17 inches and baseline pulmonary function including forced vital capacity FVC and forced expiratory volume at one second FEV 1.0 Health education should emphasize the hazards of asbestos and the importance of good occupational health practices Periodic medical evaluation is required annually on all workers with 10 or more years exposure to asbestos and every two years on workers with less than 10 years exposure Periodic medical evaluation also is required annually on those individuals ( who show roentgenographic findings such as small opacities pleural plaques pleural thickening and pleural calcification which suggest or indicate pneumoconiosis or other reaction to asbestos or ii who have changes in pulmonary function which indicate restrictive or obstructive lung disease Periodic medical evaluation shall posterior 14 x FVC and FEV 1.0 and include a chest roentgenogram 17 inches spirometry including a questionnaire for the presence and degree of respiratory symptoms including breathless- ness cough sputum production and wheezing Current smoking habits shall be recorded and smoking shall be discouraged Examination for rales and finger clubbing shall be performed Sputum cytology is recommended annually on those workers with 10 or more years exposure to asbestos and if atypia or greater classification is manifest subsequent sputum examinations should be conducted on a , month basis A comprehensive termination medical examination shall include physical examination chest roentgenogram FVC and FEV 1.0 and questionnaire for respiratory symptoms The initial and termination medical evaluations shall not be required if a similar comprehensive medical eval- uation has been performed within a 12 month period imple- 2 Records The physician charged with the mentation of the medical program shall maintain the ap- propnate medical records Only HEW and DOL physicians and medical consultants and physicians designated and authorized by the employees shall have access to the medical record Medical records shall be maintained for a period oftime to be determined by the Secretary of Labor in consultation with the Secretary of Health Education and Wel- . Copyright '1972 by The Bureau of National Affairs Inc. i 4 09 0979