Document 2qrmZgx5n0LRQ4N1ZBv2NJGyb

September 26/ 1978 TO: FROM: CDSP PLANT MANAGERS CDfiP O.H. COORDINATORS CD&P SAFETY SUPERVISORS J. R. MACCON^77!? OSHA INSPECTIONS - ASBESTOS STANDARD Within the past several months, OSHA has been increasing it's efforts and focusing attention on compliance with the asbestos standard. In view of OSHA's increased activity in this arjaa, it is recommended that each site review its1 present compliance position with respect to this standard and take whatever steps are necessary to strengthen its' position with respectj to compliance. A list of points to be reviewed is attachejl. Background - Several Du Pont plants either have had or are in the process oz having inspections wherein compliance with the asbestos standard is the prime issue. OS^A appears, to be increasingly concerned about potential xposurp to personnel not directly involved with handling asbestos or asbejstos containing materials, e.g. all maintenance personnel. In one instance, the OSHA Area Director specifically asked for medical records of welders, pipefitters, instrument mechanics, etc. under tie authority of the asbestos standard. The request was denied on the basis that the site did not consider the individuals mentioned as being covered by the standard (i.e. - their exposure, if any, was considered "casual"). The asbestos standard is not specific concerning covered employee^ and we are currently awaiting further action by OSHA on this point. An article summarizing HEW Secretary Califano's recent remarks on occupational cancer is attached for your information. Note the oiphasiij placed on asbestos exposure. We do not agree with Califanc numbersr but this subject received wide publicity. a c TJ O r0o0 M to Ut TTfnTumr mill li I !--WillMnumMB DU 011710 The plants are reminded that EPA also regulates asbestos under the regulations promulgated for hazardous air pollutants. These regulations (40 CFR 61.20-61.25) require EPA notification prior to demolition or renovation of friable asbestos and specify asbestos handling and disposal procedures. Any plant program on JBM/bam Att. DU 011711 DUP 0821296 REVir:: procedure - asbestos standard An ijn-depth, step-by-step, review of the asbestos standard should be undertaken by the site OSH coordinator. Subsequent discussions should be held with mechanical supts. and plant physicians to ensure understanding of the standard by all concerned. A survey of the site should be made to catalog all asbestos containing material, e.g. insulation, gasketing, etc. Only those' materials wherein the asbestos is. in an unbound condition (i.e,. can result in airborne fibers) need be considered. A decision must be made as to the sites' coverage by the asbestos standard. Care must be exercised not to arbitrarily discount coverage on the basis that asbestos insulation is no linger used. Many sites, while not. presently using asbestos containing insulation, may well have significant quantities of old insulation already installed which would warrant the site being covered by the standard until all such insulation has been removed. If the investigation and review leads to a conclusion that the site is not covered by the standard, that fact should be documented and filed for possible future use, especially if significant judgement had to be employed in arriving at the conclusion. Xf tte 3ite decision is that it is covered bv the standard,. a~liat of~the specific individuals involved should be developed. This list~should be reviewed at least semi-annually The nodical records of the individuals covered should be reviejwed tc ensure that those items specifically required by the asbestos standard have been addressed, i.e. (1) annual x-ray:? (2) annual pulmonary function test; (3) annual history o symptoms related to respiratory disease. Note that the medical requirements are not age dependent. The sites' air-monitoring program relative to asbestos exposure should be reviewed for compliance with the standard. Work practices related to handling asbestos containing materials should be reviewed for compliance with the standard. An aujiit for actual use of the "wet method" during asbestos handling should be conducted. DU 011712 D C "P N0o0) croo -n| 9* Other points to keep in mind: (a) an employee newly assigned to an occupation wherein the potential exists for exposure to airborne concentrations of asbestos must receive a physical exam within 30 days of such assignment, (b) an employee covered by the standard must receive a physical within 30 days of termination. This includes transfers, lay-offs, retirements, etc. (c) the standard requires annual physical examinations. Care must be exercised to avoid backlogs at. medical facilities which would result in an extended period between examinations. (For reference, a letter outlining corporate medical advice is attached.)' (d) If some part of the medical requirement is not accomplished at the annual physical (e.g. no pulmonaryfunction because of a "cold"), that part should be rescheduled when it can be completed. D13 Oin13 DUP 0821298