Document 37D77Lmqjxq0zd4r41pgm1kba

RECOMMENDED STANDARD FOR OCCUPATIONAL ASBESTOS EXPOSURE IN CONSTRUCTION AND OTHER NON-FIXED WORK OPERATIONS I. INTRODUCTION There is a growing recognition that many components of the health standards customarily adopted by the Occupational Safety and Health Administration (OSHA) for fixed-worksite jobs in manufacturing industries do not appreciably advance OSHA's worker health goals when applied to construction and other non-fixed work operations. OSHA acknowledged over four years ago "that alternative . . . controls may be more appropriate and feasible for the consutruction industry" because of "the uniqueness of the construction industry itself (viz., the multiplicity of non-fixed workplaces, and the utilization of highly transient workforces)." 40 Fed. Reg. 47652, 47653 (October 9, 1975). More recently, in her July 18, 1979 Memorandum asking the Advisory Committee on Construction Safety and Health to study the problem. Assistant Secretary of Labor Dr. Eula Bingham expressed concern that OSHA's "health standards . . . have been focused primarily on general industry," and, as a result "of the mobile and transient nature of their industry, construction employers and employees have had difficulty in complying with these standards.11 CAPCO JEN 0001379 2 Accordingly, both government and industry have began to examine alternative regulatory strategies which achieve ample health protection for construction workers without the need for fixed-site requirements such as engineering controls, exposure monitoring, medical surveillance, regulated areas, hygiene facilities, and other provisions which are frequently impracticable in non-fixed operations. In addition to the Construction Advisory Committee study, OSHA recently appointed a Special Assistant for Construction Affairs and, on June 7, 1979, established a Task Force on Construction. All of these steps are designed to provide OSHA with guidance on how to resolve the problems of regulating health hazards in the construction industry. Industry's efforts have focused on alternative methods for protecting worker health. Attention has been directed increasingly toward the development of safer products and work practices which eliminate the need for the often cumber some provisions of the customary OSHA health standard. In the asbestos industry, for example, unsafe asbestos-containing construction materials increasingly are being withdrawn from the market and simple work practices which minimize occupa tional asbestos exposure in construction and other non-fixed operations have been and are being developed and widely disseminated. See Appendix. The Recommended Standard for Occupational Asbestos Exposure in Construction and Other Non-Fixed Work Operations CAPCO JEN 0001380 3 proposed herein is the logical outgrowth of these efforts. In brief, the Recommended Standard establishes a classifica tion scheme designed to provide a series of economic and regulatory incentives for the development of work practices and product formulations which will provide ample health protection for workers without imposing the often impractical features of the typical fixed-site OSHA standard. More specifically, the Recommended Standard makes the current OSHA asbestos standard, which imposes the usual fixed-site requirements, presumptively applicable to construction and other non-fixed workplaces, but provides for partial and complete exemptions based on a scheme which classifies work operations according to their potential asbestos exposure, as follows: (i) Paragraph (b)(1) defines a "Category A Operation" as an operation which, based on qualified scientific tests, will not result in the release of airborne asbestos fibers in excess of the permissible exposure limits. Under Paragraph (c), such Category A Operations are exempt from all provisions of the current standard; (ii) Paragraph (b)(2) defines a "Category B Operation" as an operation which, when validated work practices or other protective measures are used, will not result in the release of airborne asbestos fibers in excess of the.permissible CAPCO JEN 0001381 exposure limits. Under Paragraph (d), Category B Operations are partially exempt from the standard, provided validated work practices are followed. This partial exemption would leave in effect labeling, housekeeping, and worker education and training requirements which would help ensure the use and effectiveness of validated work practices; and (iii) In the case of "Category C Operations" -- i.e., operations which are neither Category A Operations nor Category B Operations -- the existing standard would apply in full. Paragraphs (b)(3) and (e). The purpose of this classification scheme is to encourage the development of safer products and work practices which eliminate the need for the fixed-site requirements of the current standard, such as monitoring and medical surveillance. The proposed standard creates stronger incentives for primary manufacturers to develop validated work practices so that their construction industry customers will not be required to meet the most burdensome fixed-site requirements of the current standard. An additional incentive (in the form of a complete exemption from regulatory obligations) is provided for innovative product formulations which pose little or no foreseeable threat of significant asbestos exposure in some or all uses (Category A Operations). CAPCO JEN 0001382 5 Moreover, the Recommended Standard would provide enforce able assurances that validated work practices and product formulations are effective in protecting workers. Thus, validation of product formulations (for Category A Operations) and work practices (for Category B Operations) would be performed only by fully qualified testing laboratories based on objective performance criteria. In addition, OSHA's own enforcement activities would act as an empirical check on the scientific validity of such testing. If monitoring results from an OSHA inspection suggest that a Category A or B Operation is not effective in keeping exposures below permissible levels, the employer would, upon appropriate proof, be put on notice that he can no longer reasonably rely upon assurances from the primary manufacturer, and that additional scientific testing would be required. In short, the alternative recommended herein will serve OSHA's health protection goals far better than the customary OSHA health standard. In practical effect, the current OSHA approach often leaves construction industry employers no choice except to abandon the use of essential or highly useful construction materials. By contrast, the Recommended Standard encourages the development of cost-effective products and work practices which both protect worker health and meet the practical needs of the construction industry and the^ economy as a whole. * CAPCO JEN 0001383 6 II. THE NEED FOR A REGULATORY STRATEGY WHICH MORE CLOSELY REFLECTS THE EVERYDAY REALITIES OF CONSTRUCTION AND OTHER NON-FIXED WORKPLACES The characteristics of employment in the construction industry present unique occupational health and industrial hygiene problems which plainly call for separate regulatory treatment. Employers work in a continuously changing environ ment, moving from one temporary worksite to another. Each worksite is unique, both because the outdoor nature of much of the work results in exposure patterns that can vary widely with changing weather conditions, and because each temporary worksite involves the use of different materials and processes over differing lengths of time. As a result, occupational exposure to most toxic sub stances in construction work is highly variable and completely unpredictable. Nevertheless, high worker mobility among tasks results in exposures which are brief, intermittent and, for many substances, very low on the average. Asbestos dust is an example of such a substance, as the findings of OSHA demonstrate: Products containing asbestos are not used consistently [in construction work]. Individual workers may work with a product containing asbestos only very occasionally, although some may do so almost continuously. Thus, the total population exposed over time may be much larger than the population at risk at a moment in time, and average annual and cumulative exposure may be quite low.l/ 1/ Research Triangle Institute, Asbestos l?ust: Technological (Footnote 1 continued on next page.) CAPCO JEN 0001384 7 Apart from the nature of construction work itself, the economic structure of the construction industry strongly suggests that customary occupational health and industrial hygiene measures are not appropriate. The industry is characterized by a predominance of small firms and the absence of stable employer-employee relationships. Over 70 percent of construction industry employers are proprietorships averaging one to four employees.--' These firms them selves are highly transient. Not only does their number fluctuate widely according to seasonal variations and other short-term shifts in demand, but also firms are frequently formed to undertake specific projects and then disbanded once the projects are completed. As might be expected, the workforce is also highly transient and temporary, with turnover rates as high as 300 to 600 percent per year depending on the job or craft involved, and with casual (i.e., "walk-on, walk-off") hiring and severence practices common.^ Thus, individual workers may, over a working life, be employed by a very large number of firms. (Footnote 1 continued from previous page.) Feasibility Assessment and Economic Impact, Analysis of the Proposed Federal Occupational Standard p. 11-35 (dated September 1978 and released December 1979) (hereinafter referred to as the "RTI Report"). 2/ RTI Report p. 11-35. 3/ Statement of Fred Graham, National Constructors Associa tion (NCA), OSHA Docket H-90 (Cancer Policy), Ex. 125 at 2; RTI Report p. 11-36. CAPCO JEN 0001385 8 The typical OSHA health standard is simply not designed to accomodate the type of employment involved in the construc tion industry. Requirements for engineering controls, moni toring, medical surveillance, regulated areas and hygiene facilities can effectively protect worker health only in manufacturing or other "general industry" jobs involving stable employment relationships, and regular assignment to fixed-site operations involving repetitive tasks. Yet, nearly every fixed-site health standard thus far promulgated by OSHA under Section 6(b) of the Occupational Safety and Health Act applies to construction workplaces. 44 Fed. Reg. 8706-8805 (February 9, 1979). The current asbestos standard is a classic example of why a new regulatory strategy for construction and other non-fixed workplaces is badly needed. For example, the current asbestos standard requires construction industry employers to conduct personal and environmental ("area") monitoring which must be "of such frequency and pattern to represent with reasonable accuracy the levels of exposure of employees." 29 C.F.R. 1910.1001 (f)(2), (3). The nature of construction work makes this requirement for "representative" exposure monitoring a virtually meaningless (albeit very expensive) exercise. As pointed out above, only a few of the remarkable variety of tasks performed by construction workers involve asbestos- c containing products. Each such task may, however, present a markedly different potential for exposure to asbestos fibers. CAPCO JEN 0001386 9 Exposure levels for any given task will vary considerably depending on the duration of the work, the work procedures followed by the particular employee, the tools used, the fiber-release characteristics of the asbestos-containing product, weather conditions, and other factors.^/ These factors, coupled with high worker mobility among tasks and the absence of any regularity or pattern in worker movement among tasks, preclude any worker's exposure on a given day from being "representative" of his exposure on any other day, much less "representative" of any other worker's exposure. Consequently, the current OSHA provision for monitoring at "such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees" imposes an enormous burden, and could be read to require continuous monitoring of all of the millions of workers who may be "exposed" (even though briefly and intermittently) to detec table levels of asbestos fibers.But given the uniqueness of each operation, this endless, repetitive monitoring provides 4/ See, e.g., Statement of Lt. Col. David Smith on behalf of the Department of Defense, Docket H-004 (Lead), Ex. 130; Statement of C. R. Mattson (NCA), Docket H-004 (Lead), Ex. 98; Statement of Harry Taylor on behalf of the Council of Construction Employers, Docket H-004 (Lead), Ex. 64; Statement of I. J. Meyerson on behalf of Boeing Aerospace Company, Docket H-004 (Lead), Ex. 30. 5/ In 1975, OSHA estimated that three to five million construction workers may be exposed to asbestos dust. 40 Fed. Reg. 47653 (October 9, 1975). The RTI Report (Table I1-3 at p. 11-27) estimates that about 2.3 million workers are exposed to asbestos dust. r.APCO JEN 0001387 10 information of little or no value in determining whether an exposure limitation is being satisfied throughout all opera tions. Moreover, the monitoring task involved far exceeds the capabilities of existing analytical laboratories. And even if the resources were available, the five-to-six week period needed for laboratory analysis exceeds the life of many construction operations involving asbestos. The current asbestos standard also requires construction employers to provide preplacement, annual and termination medical examinations involving a battery of tests, including diagnostic x-rays and pulmonary function tests, to every worker exposed to virtually any detectable level of airborne asbestos dust. 29 C.F.R. 1910.1001(j); OSHA Program Directive 300-16 (October 11, 1978). While imposing a potentialy severe burden on employers, this medical surveil lance requirement does little to protect the health of construction industry workers. So long as the permissible exposure limits are being met, there is no reason for imposing such a heavy medical surveillance burden on the construction industry. As detailed above, asbestos exposures in construction operations are generally brief and intermittent. Perhaps as a result of the nature of the exposures, the available epidemiologic evidence strongly suggests the absence of any asbestos-related health risk among construction workers. Dr. Irving Selikoff's recent study of a roofing workers union from January 1960 to CAPCO JEN 0001388 11 1977 -- the only long-term epidemiologic study of a cohort of construction workers done to date -- reports the following results: [I]f there was enough asbestos exposure in built-up roofing to give a significant hazard due to asbestos, I would have seen at least one mesothelioma. I didn't in 2,500 consecutive deaths and these were all people who were in the union in 1960 and incidentally, had to be in the union also to enter that cohort in 1951. So these people were 25, 30, 35, and 40 years old from onset of their work and I didn't find mesothe lioma. So I know that there is not a significant increase although I can't prove that there is none. In the next 2,500 deaths, there may be 1 or 2, but certainly there can't be any great asbestos hazard with built-up roofing.6/ Apart from the absence of any health need, the costly medical surveillance requirements of the current standard cannot be justified because of any need for epidemologic studies of workers exposed to low levels of asbestos fibers. A far more useful data base is available from manufacturing operations covered by the existing standard, which generally involve stable, long-term employment with somewhat more regular exposures than in construction operations. Moreover, medical surveillance creates health and economic risks to the worker which outweigh the minimal (if any) health benefits achieved. The rapid turnover of both employee^ and employers creates a significant potential i. 6/ Excerpt from transcript of Dr. Selikoff's remarks at the Annual Meeting of the Asbestos .Cement Pipe Producers Associations in Mexico City, April 1977. CAPCO JEN 0001389 12 for unnecessary repeat examinations and over-exposure to diagnostic x-rays.-^ In addition, the results of the exami nation may discriminate against individual workers by making them unemployable even without any actual disability.8-'/ Other components of the typical OSHA health standard are equally inappropriate in light of the realities of construction work. For example, the concept of a limitedaccess "regulated area" is meaningless in construction worksites, where, as the National Constructors Association points out, "work is performed in a continuously changing environment", and "personnel are constantly being called upon to perform work in irregularly occupied areas on a transitory basis."-97/ Similarly "hygiene facilities" such as change rooms, shower rooms, or lunch rooms are impractical for many construc tion employers, because most construction sites have no supply of water or the buildings necessary to house these facilities, and because the cost of procuring mobile, self-contained facil ities would often be prohibitive, particularly for small-scale 7/ See "Health Standards Pose Big Problems for Industry," Engineering News-Record, October 12, 1978. Excessive x-ray exposure creates an increased risk of leukemia and other cancers. [Cites] 8/ Statement of Dr. Clark Cooper before the Subgroup on Health Standards of the Construction Advisory Committee, [date]. 9/ Statement of Fred Graham, OSHA Docket H-60 (Cancer Policy), Ex. 125 at 6. CAPCO JEN 0001390 13 construction projects such as residential dwellings or small office buildings. Nor is there any reason to believe that the generally small, transitory employers in the construction industry are likely to have the personnel or financial resources to meet these requirements. Indeed, the testimony of the National Constructors Association in OSHA's Cancer Policy proceedings stressed that the routine adoption of fixed-site requirements like those discussed above would "place an intolerable eco nomic and logistical strain on the construction industry -- particularly small contractors." NCA added that "the costs are so extreme as to threaten the continued existence of many small and medium size construction companies throughout the nation, without a clear demonstration of the necessity for such rigid health controls."^/ In Siam, many provisions of the typical OSHA health standard -- concededly designed for fixed-site employment in "general industry" -- are misplaced when applied to construc tion and other non-fixed workplaces. The unique characteris tics of these workplaces require a fresh approach which both provides ample health protection for workers and is feasible, cost-effective, enforceable, and likely to encourage the development of safer products and work practices. The next section shows, using asbestos as an example, that such a 10/ Id. at 4, 5. CAPCO JEN 0001391 14 regulatory strategy can indeed be developed for construction and other non-fixed workplaces. III. EXPLANATION AND ADVANTAGES OF THE RECOMMENDED STANDARD Occupational health standards should serve a number of different objectives. First, they should be enforceable regulations which adequately protect workers from occupational health hazards. Second, they should be practical regulations which promote voluntary compliance, avoid unnecessary burdens on employers and the public, and channel available occupational health resources to areas where those resources will achieve the greatest health gains for workers. And third, they should encourage the private sector to develop safer products and work practices which efficiently satisfy the practical and economic needs of the construction industry and the general economy. The Recommended Standard would achieve these objectives by establishing a classification scheme which would rank construction operations according to their potential for releasing airborne asbestos fibers in excess of the permissible exposure limits. Classifications would be based upon qualified laboratory tests that, over time, will be tested repeatedly by OSHA enforcement officials. Based on this classification scheme, the Standard would impose regulatory requirements commensurate with the exposure risk presented by each .opera tion, applying more stringent requirements for higher-risk CAPCO JEN 0001392 15 tasks, including full compliance with the existing standard for operations presenting the greatest risk of exposure above permissible levels. A. Explanation of the Recommended Standard 1. Scope and application Our Model Standard would apply to "construction work and other non-fixed places of employment where asbestos or products containing asbestos are processed or used." Rec. Std. H (a). The definition of the term "construction work" in Paragraph (b)(6) is identical to OSHA's definition of the term under its General Industry Standards. 29 C.F.R. 1910.12. The Standard defines the term "non-fixed work operation" to refer to "jobs which do not involve regular assignment to a particular location or set of locations." Rec. Std. U (b)(7). The purpose of this provision is to include highly mobile non-construction operations such as oil well drilling (discussed in the Appendix, Part C), where asbestos exposures may occur under circumstances similar to construc tion activities. Lastly, the Recommended Standard contains a provision which clearly separates the coverage of the current OSHA asbestos standard from the proposed new construction standard. The current OSHA standard does not contain any specification of scope and application, but the provisions of the standard CAPCO JEN 0001393 16 make clear that it applies to any workplace where there is occupational exposure to asbestos. Accordingly, the Recom mended Standard adds to the current standard a new paragraph which excludes construction and other non-fixed workplaces which would be covered by the proposed new standard. 2. Classification of Operations The categorization of construction operations involving asbestos-containing products according to their fiber-release potential is the foundation of the recommended approach. The proposal would establish three classifications (called "Category A," "Category B" and "Category C" Operations) which are defined according to an operation's capacity, under reasonably forseeable conditions of processing or use in construction and other non-fixed operations, for releasing airborne asbestos fibers in excess of the permissible exposure limits. As discussed later, different regulatory requirements would apply to each category, both to reflect the degree of risk associated with each type of operation, and to establish incentives for the development and use of safer products and work practices. A "Category A Operation" is defined in Paragraph (b)(1) as an operation which "does not result in occupational exposure to airborne concentrations of asbestos fibers in excess of" the permissible exposure limits. Category A is the safest classification and will generally involve products CAPCO JEN 0001394 17 in which asbestos fibers are coated, bound or enclosed by other materials in such a way that they will not be released in significant quantities in certain (or perhaps all) construc tion industry uses. As discussed in the Appendix, these products are likely to include mastics, mechanical packings, oil seals, compressed gaskets, sealants and caulks, and elec trical insulating paper. A "Category B Operation" is defined in Paragraph (b)(2) as "an operation . . . which, when a specified fabrication, installation or removal method is used, does not result in occupational exposure to airborne concentrations of asbestos fibers in excess of" the permissible exposure limits. In effect, Category B Operations are capable of producing airborne asbestos fiber concentrations in excess of the per missible exposure limits, but will not do so if the correct work procedures, tools or other safeguards are employed. Obviously, some regulatory controls must be applied to Category B Operations to ensure that they are used in a way that prevents the release of excessive concentrations of asbestos fibers. Nevertheless, if properly classified, Category B Operations do not require the full panoply of typical fixed-site requirements such as monitoring, medical surveillance, regulated areas, and hygiene facilities. So long as l^ie use of proper work practices, tools or other. CAPCO JEN 0001395 18 safeguards is ensured, additional requirements are unnecessary or redundant. As discussed in the Appendix, AIA/NA and AACPP have developed data showing that work practices for construction operations involving three asbestos-containing products -- asbestos-cement pipe, asbestos-cement sheet and drilling mud additives -- can be validated under Category B of the Recommended Standard. In addition, recommended work practices are being developed and field-tested for two other potential products: -- flooring products and built-up roofing with asbestos felts, -- as well as for removal and repair operations which, as discussed in the Appendix (pp. 3b-5b), represent perhaps the most significant sources of exposure to asbestos dust in construction work. The last classification -- "Category C Operations" -- covers operations which do not fall into either of the two preceeding categories. Rec. Std. H (b)(3). Because they possess neither the innate physical characteristics nor the validated work practice controls which are needed to ensure that the permissible exposure levels are met, products used in Category C Operations present the greatest potential for significant asbestos exposures, and accordingly require the most stringent regulatory controls.' 3. Validation For any classification sche&e to be successful, it is, of course, necessary to provide adequate assurances that CAPCO JEN 0001396 19 operations will properly be classified. The Recommended Standard employs three devices for achieving this goal: (i) validation by qualified testing laboratories, (ii) objec tive performance criteria, and (iii) empirical field confir mation by OSHA in connection with workplace inspections. The Recommended Standard makes clear that a construction industry employer can treat a specific operation as falling within Category A or B only if he "reasonably relies on objective data, developed by a Certified Testing Laboratory." Rec. Std. UH (c) & (d)(1). Paragraph (b)(5) defines a "Certified Testing Laboratory" as a laboratory approved by the American Industrial Hygiene Association (AIHA) and certified by the National Institute of Occupational Safety and Health (NIOSH) as qualified to test for airborne concen trations of asbestos fibers using the method prescribed in the current OSHA asbestos standard. The use of laboratories which are certified by both AIHA and NIOSH provides an important safeguard against invalid or unsupported product classifications. An additional safeguard is provided by the inclusion of objective performance criteria for classification. The Recommended Standard requires "objective data . . . which show, within confidence limits of 95 percent," that an operation falls into a particular category. Rec. Std. 11 (c) & (d)(1). This requirement would force validating laboratories to design and conduct careful field tests whigh account for the CAPCO JEN 0001397 20 varying conditions present in construction and other non-fixed workplaces, and to establish, within 95 percent confidence limits, that the applicable exposure limitations will not be exceeded in Category A and B Operations. As discussed in greater detail below (p. 28), the range of uncertainty inherent in analytical methods for measuring airborne asbestos fiber concentrations will, therefore, have been taken into account in determining whether the product or work practice can be expected to maintain exposures below the permissible exposure limit. Notwithstanding these safeguards, the Recommended Standard does not give Certified Testing Laboratories the final word on product classification. Instead, it requires "reasonable reliance" by employers on the data supplied by the validating laboratory. Rec. Std. IfH (c) & (d)(1). Nor does the Recommended Standard attempt to define "reasonable reliance," but rather leaves that issue to case-by-case determination in enforcement proceedings. Certainly the reputation of the validating laboratory, the employer's previous experience with the laboratory, the facial com pleteness of the data and the laboratory's specific conclu sions would be relevant considerations. Another key factor in specific cases would be any findings from previous OSHA inspections of an operation. * For example, if an OSHA inspection showed that the applicable exposure limits were exceeded during a Category A Operation CAPCO JEN 0001398 21 or during a Category B Operation where the proper work practices were followed, an employer's ability to continue to rely "reasonably" on the data supplied by the validating laboratory would be placed in doubt, depending on the accuracy and extent of data provided by OSHA in each case. This feature of the Recommended Standard gives OSHA a vehicle for monitoring and verifying the correctness of classifications. 4. Regulatory requirements The Recommended Standard imposes different regulatory controls on each product category, and tailors the applicable controls to the degree of the exposure hazard presented by each type of product or operation. Category A Operations are exempt from the existing standard by Paragraph (c). Since Category A Operations do not present a risk of significant exposures, no new regula tory requirements are imposed. Moreover, as discussed in greater detail below, the absence of regulatory controls on Category A Operations creates a strong incentive for the development and use of products which will not lead to significant exposure. There is one situation where the exemption of Category A Operations from the current standard does not apply: As dis cussed in greater detail in the Appendix (pp. 3b-4b), construc tion employees working (e.g., making repairs) in a facility which manufactures or fabricates asbestos-containing products will generally be protected by the current standard, which CAPCO JEN 0001399 22 applies to the owner of that facility. However, construction workers could be exposed to excessive concentrations of asbestos dust in an emergency or from dust which has accumu lated in normally inaccessible places such as on pipes and ductwork. Accordingly, Paragraph (c)(2) makes the "emergency" and "housekeeping" provisions of the current standard appli cable in those special circumstances. For Category B Operations, the Recommended Standard requires employers to comply with the "fabrication/ installa tion or removal methods" which qualify the operation under Category E. Rec. Std. fl (d)(1). The expression "fabrication, installation and removal methods" is defined in Paragraph (b)(4) to include any combination of engineering, work practice or administrative controls. While work practice controls are expected to be the predominant mode of compliance because of the special features of the construction industry discussed above (pp. 6-14), the purpose of the definition is to permit the use of tools with local exhaust ventilation or work scheduling as ancillary protective measures. The use of respirators as part of a Category B classification is not permitted under the Recommended Standard unless no other control method is feasible for a given operation. Several additional requirements are imposed to ensure the use and effectiveness of the validated work practices e and other protective measures. First, the labeling and housekeeping requirements of the current OSHA standard, CAPCO JEN 0001400 23 together with its provisions governing the use of respirators in emergencies, are made applicable to workplaces conducting Category B operations. Rec. Std. U (d)(2). Second, manufacturers of products used in Category B Operations are required to include on caution labels a reference to the "fabrication, installation or removal methods" which have been validated for the products in question, and a recommendation that such work practices, tools or other measures be used. Rec. Std. II (d)(3). Third, the employee education and training provisions of Paragraph (f) apply to Category B Operations, and include a requirement that employers provide as part of the training program "specific instructions concerning the proper use of [the] fabrication, installation or removal methods" which were validated as part of the Category B classification. Rec. Std. 1 (f)(1)(ii). For Category C Operations, which, by definition, pose the greatest potential for exposure, the current OSHA asbestos standard would apply in full. Rec. Std. II (e). As dis cussed above (p. 18), products used in Category C Operations have neither the structural product characteristics nor the validated work practice controls needed to protect workers against excessive exposures. While many components of the typical OSHA fixed-site health standard (such as the current asbestos standard) are generally inappropriate for construction and other non-fixed workplaces, those provisions should nevertheless be applied in the case of Category C Operations r.APCO JEN 0001401 24 both to ensure adequate health protection for workers and to provide a strong incentive for developing safer products and work practices. In addition. Paragraph (f) imposes a new employee education and training program (not provided in OSHA's current asbestos standard) on Category C Operations. It is important to note that the regulatory status of Category A and B Operations is expressed in the form of exemptions from the current standard. As a result, if a construction employer cannot claim one of the exemptions, the entire existing standard could be enforced against him. The threat of citations and penalties for violating the many individual requirements of the existing standard will provide a powerful incentive for employers to make doubly sure that the criteria for Category A or B classifications are met. In addition, in the case of Category B Operations, employers are subject to citation for failing to follow the validated work practices or the warning sign, labeling, housekeeping, and training requirements, even if the classification criteria have been satisfied. B. Advantages Over OSHA's Typical Fixed-Site Health Standard The Recommended Standard for Asbestos Exposure in Construction and other Non-fixed Work Operations has a number of distinct advantages over the current OSHA regulation. First, it imposes practical requirements which nevertheless provide ample assurances for worker protection. Second, it CAPCO JEN 0001402 25 creates incentives for the development of safer products and work practices without sacrificing the economic and practical advantages of asbestos-containing products for the construction industry and the economy as a whole. And third, the Recommended Standard can more efficiently be enforced than the current OSHA standard. 1. Worker protection The Recommended Standard to be sure, departs significantly from the provisions of the traditional OSHA health standard. Nevertheless, as demonstrated above (pp. 6-14), these fixed-site requirements, including monitoring, medical surveillance and other requirements, are impractical in construction and other non-fixed operations and contribute little to worker health. Even if it had unlimited enforcement resources, OSHA could not hope to achieve widespread compliance with these provisions, and construction employers would be left with the "Hobson's choice" of risking noncompliance penalties or abandoning highly useful or, in some instances, essential products. . OSHA itself has, on occasion, limited or modified its traditional regulatory approach in an effort to avoid stan dards which impose sweeping requirements without any signficant or commensurate health gain. OSHA's current labeling requirement for asbestos-containing products, for example, CJAPCO JEN 0001403 26 provides that "no label is required where asbestos fibers have been modified by a bonding agent, coating, binder or other material so that during any reasonably forseeable use, ... no airborne concentrations of asbestos fibers in excess of the exposure limits . . . will be released." The waste disposal requirement of OSHA's current asbestos standard contains an identical exemption. 29 C.F.R. 1910.1001(g)(2)(i) and (h)(2). In effect, OSHA has recognized that some asbestoscontaining materials do not pose an exposure threat which is significant enough to justify expensive regulatory controls. Another example of an effort to prevent unduly broad application of monitoring, medical surveillance and other typical OSHA requirements is OSHA's Inorganic Arsenic Standard, which excludes workplaces where inorganic arsenic is present in only small amounts. OSHA justified an exemption in that case as follows: [A]rsenic is a naturally occurring material and is present in small amounts in many substances. It is therefore inappropriate to cover situations where very low levels of arsenic may be present in substances or products in the workplace, but where they are handled in such a way that the possibility of airborne exposure is minimal. 43 Fed. Reg. 19612 (May 5, 1978). Similarly, OSHA's Cotton Dust Standard contains a series of exemptions where application of the standard would achieve little at great cost, including (i) maritime workers, because the "limited duration of exposure makes it unlikely CAPCO JEN 0001404 27 that cotton dust exposure is significant for an appreciable number of the workers handling water borne shipments of cotton"; (ii) workers handling "washed cotton," because of the effectiveness of the washing process in significantly reducing or eliminating the biological effects of cotton dust"; and (iii) harvesting of cotton, because."it is a distinctively farming operation and presents different exposure environments and possibilities for control." 43 Fed. Reg. 27831-32 (June 23, 1978). OSHA took a similar approach in formulating its Benzene Standard. There, it exempted gasoline stations and other operations where the standard would have a sweeping impact, but where exposures are not likley to exceed permissible limits. 29 C.F.R. 1910.1028(a)(2); 43 Fed. Reg. 27962 (June 27, 1978). OSHA's Acrylonitrile (AN) Standard, which more closely resembles the alternative standard we propose for asbestos exposure in the construction industry, also reflects an effort to adapt the traditional regulatory approach to unique circumstances. The AN standard imposes the traditional fixed-site requirements on manufacturers of products con taining AN, but exempts downstream processors and fabricators of such products where "objective data is reasonably relied upon" to show that a designated action level is not exceeded. 29 C.F.R. 1910.1045(a)(2)(ii). In adopting this and other exemptions from the overall AN standard, OSHA "recognized that the potential for exposure to AN in the workplace f'-APno JEN 0001405 28 extends to a multitude of workplaces, including many small fabricators, extruders, and other downstream processors of materials containing or made from AN," and that "extending the AN standard that far would be burdensome to both industry and OSHA, and would not be reasonable in light of the degree of exposure involved." 43 Fed. Reg. 45762, 45776 (October 3, 1978). Significantly, the Recommended Standard goes beyond the AN standard in protecting worker health. First, it requires that product and work practice testing be performed only by fully qualified testing labora tories . Second, it provides objective performance criteria which require a high statistical degree of confidence (95 percent) that the permissible exposure limits will not be exceeded. This latter point is especially important in the case of asbestos, where the OSHA technique for measuring airborne asbestos concentrations is subject to a margin of uncertainty so great that "[a]n actual airborne fiber concen tration of 0.5 fibers/cc will routinely produce sample counts of 2.0 fibers/cc or more."--^ Consequently, the 95 percent confidence requirement will, in practice, not be met unless the products and work practices being tested routinely produce measurements far below the permissible exposure limits, adding tl a significant extra margin of worker safety. 11/ Comments of Johns-Manvilie, OSHA Docket H-___ (Asbestos), Ex. 3-185 at ex. D, p. 42. CAPCO JEN 0001406 29 2. Incentives for the development and use of safer products and work practices Apart from providing superior health protection for workers without the cumbersome fixed-site features of the current standard, the Recommended Standard creates strong incentives for the development of safer products and work practices. Under the current standard, construction employers cannot legally avoid burdensome fixed-site requirements such as monitoring or medical surveillance no matter how safe the asbestos-containing products or work practices which they employ. Thus, they must either ignore the standard to the detriment of employees, or they must stop using extremely valuable construction materials, to the detriment of the economy. Under the Recommended Standard, the threat that the current standard might be enforced in full provides a powerful incentive for the development and use of products or work practices which qualify for Category A or B classification. As a result, two critical objectives would be advanced. First, worker health would be protected through the use of products and work practices which present no serious risk of dangerous asbestos exposure. Second, the current incentive for across-the-board substitution of inferior non-asbestoscontaining products would be eliminated and replaced with a - . . scheme which encourages the use of the be|t construction materials which do not threaten the health of workers. CAPCO JEN 0001407 30 3. Enforceability The third principal advantage of the recommended approach is that it will ease the tremendous enforcement burden OSHA faces in policing the millions of workers potentially exposed to asbestos dust in hundreds of thousands of construction sites throughout the nation. Under the Recommended Standard, in a large majority of cases, OSHA inspectors may have to do nothing more than determine whether the proper products and work practices are being used -- a task much simpler and less time-consuming and expensive than under the current standard, where exposure monitoring may have to be conducted and employer medical, industrial hygiene and other files may have to be searched and reviewed. Instead of endlessly monitoring individual construction operations to determine whether the permissible exposure limits are being met in each unique case, the Recommended Standard allows OSHA to focus its enforcement activities on identifying improper product classifications. As discussed above, once sampling results from OSHA inspections indicate that an operation may be improperly classified, construction employers and upstream manufacturers of asbestos-containing products throughout the nation will have a powerful incentive to develop substitute products or work practices which ensure that exposure limitations are met. ^ a r-tr'ni it=hJ 0001^08 31 IV. CONCLUSION There is a clear need for a new strategy to control health hazards in construction and other non-fixed work operations. The current OSHA approach, which imposes on these operations provisions for endless, repeated monitoring and medical surveillance as well as other requirements designed for fixed-site jobs in manufacturing industries, is simply not feasible. Nor do many of the requirements of the customary OSHA standard contribute appreciably to the health of construction workers. Even if it could be enforced by OSHA, the current asbestos standard would only result in the substitution of inferior materials or, in some cases, the stoppage of construction work altogether. The better approach is to substitute a regulatory scheme that strongly encourages the use of products and work practices which protect workers against excessive exposures without imposing infeasible fixed-site requirements such as monitoring and medical surveillance. As this paper has illustrated in the particular case of asbestos, such an approach provides fully adequate health protection for workers, establishes continuing incentives for the development and use of safer products and work practices, and considerably eases OSHA's enormous enforcement burden. The proposed standard recommended herein plainly meets these objectives CAPCO JEN 0001409 32 and should therefore be carefully considered by OSHA and the Construction Advisory Committee in connection with their efforts to develop an effective occupational health strategy for construction and other non-fixed work operations. The Asbestos Information Association of North America and The Association of AsbestosCement Pipe Producers CAPCO JEN 0001410 RECOMMENDED STANDARD FOR OCCUPATIONAL ASBESTOS EXPOSURE IN CONSTRUCTION AND OTHER NON-FIXED WORK OPERATIONS Part 1910 of Title 29 of the Code of Federal Regulations is amended as follows: 1. Section 1910.1001 of Title 29 of the Code of Federal Regulations is amended by adding after Paragraph (j) thereof the following new Paragraph: " (k) Scope and application. This Section applies to all places of employment where asbestos or products containing asbestos are handled, processed, used, transported, packaged, repackaged, or released, except as provided in Section 1910.1001a." *** 2. A new Section 1910.1001a is added as follows: "1910.1001a Asbestos Exposure in Construction Work and Other Non-Fixed Work Operations "(a) Scope and application. This Section applies to every place of employment in construction'work and other non-fixed work operations where asbestos or products containing asbestos are processed or used. "(b) Definitions. "(1) "Category A Operation" refers to an operation within the scope of this Section which does not result in occupational exposure to airborne concentrations of CAPCO JEN 0001411 2a asbestos fibers in excess of (i) an eight-hour timeweighted average concentration of two fibers, longer than five micrometers, per cubic centimeter of air, and (ii) a ceiling concentration of ten fibers, longer than five micrometers, per cubic centimeter of air. "(2) "Category B Operation" refers to an operation within the scope of this Section which, when a specified fabrication, installation or removal method is used, does not result in occupational exposure to airborne concentrations of asbestos fibers in excess of the exposure levels specified in Subparagraph (1) of this Paragraph. "(3) "Category C Operation" refers to an operation within the scope of this Section which is neither a Category A Operation nor a Category B Operation. "(4) "Fabrication, Installation or Removal Method" means any combination of engineering controls, tools, equipment, work practices, task assignment strategies, and respiratory protection, for controlling occupational exposure to airborne concentrations of asbestos fibers; provided, however, that a fabrication, installation or removal method may not include respiratory protection unless no other method for controlling occupational exposure to airborne concentrations of asbestos fibers is feasible. fiAPCO JEN 0001412 3a "(5) "Certified Testing Laboratory" means a labo ratory approved by the American Industrial Hygiene Association and certified by the National Institute for Occupational Safety and Health as qualified to test for asbestos fibers using the membrane filter method specified in Paragraph (e) of Section 1910.1001. "(6) "Construction work" means work for construc tion, alteration, and/or repair, including painting and decoration. "(7) "Non-fixed work operation" means non-fixed as to the location where an employee performs his duties and refers to jobs which do not involve regular assignment to a particular location or set of locations. "(8) All other terms used in this Section shall have the meanings prescribed in- Section 1910.1001 and in Section 3(8) of the Act, 29 U.S.C. 652(8). "(c) Category A Operations. "(1) Any employer who reasonably relies on objective data, developed by a Certified Testing Laboratory, which show, within confidence limits of 95 percent, that an operation covered by of this Section is a Category A Operation, is exempt from the provisions of Section 1910.1001 as they apply to such operations, except as provided in Subparagraph (2) of this Paragraph. "(2) Where a Category A Operation is located in a facility which manufactures or fabricates products CAPCO JEN 0001413 4a containing asbestos, Paragraphs (d)(l)(iii) and (h) of Section 1910.1001, relating to the use of respirators during emergencies and housekeeping, shall apply to such operation. "(d) Category B Operation. "(1) Validation. Any employer who reasonably relies on objective data, developed by a Certified Testing Laboratory, which show, within confidence limits of 95 percent, that an operation within the scope of this Section is a Category B Operation, is exempt from the requirements of Section 1910.1001 as they apply to such operation, provided that the employer takes all practicable measures to ensure the use of the fabrication, installation or removal methods which qualify the operation as a Category B Operation. " (2) Emergencies, Warning Signs, Caution Labels, and Housekeeping. Notwithstanding the provisions of Subparagraph (1) of this Paragraph, employers who use. fabrication, installation or removal methods validated under Subparagraph (1) of this Paragraph shall comply with Paragraphs (d)(l)(iii), (g)(2) and (h) of Section 1910.1001, relating to the use of respirators during emergencies, caution labels and housekeeping. "(3) Notification. "Any manufacturer of a product for which a fabrication, installation or removal method has been validated pursuant to this Paragraph, shall. riAPCO JEN 0001414 5a if he has actual knowledge of such validation, include on the label required by Paragrapy (g)(2) of Section 1910.1001 the following additional statement: "Follow Recommended Fabrication, Installation or Removal Methods." "(e) Category C Operation. The requirements of Section 1910.1001, as promulgated on June 7, 1972 (37 F.R. 11318) and amended on March 19, 1976 (41 F.R. 11504), shall apply to any operation within the scope of this Section which -is a Category C Operation. "(f) Employee Education and Training. (1) All employers covered by this Section shall institute a training program for employees working in operations within the scope of this Section (exceptfor Category A Operations covered by Paragraph (c) of this Section) and shall assure that each such employee is informed of the following: "(i) the operations where asbestos-containing products are processed or used, and the conditions of processing or use under which exposure to airborne asbestos fibers may take place? "(ii) if the employer intends to use fabrica tion, installation or removal methods which have been validated for Category B under Paragraph (d), the training program shall include 'specific instruc tions concerning the proper use o.f such fabrication, installation or removal methods. CAPHO JEN 0001415 6a "(2) The training program reguired under this Paragraph shall be provided within 90 days of the effective date of this Section or at the time of initial assignment of an employee to an operation within the scope of this Section (except for Category A Operations covered by Paragraph (c) of this Section), and at least annually thereafter. "(3) Upon request, the employer shall make avail able to employees, the Assistant Secretary or the Director, all materials relating to the information and training program instituted under this Paragraph, and any objective data concerning the validation of fabri cation, installation or removal methods used by the employer for Category B Operations pursuant to Para graph (d) of this Section. CAPCO JEN 0001416 APPENDIX A Preliminary Assessment of How the Recommended Asbestos Standard Can Successfully Be Implemented in Construction and Other Non-Fixed Work Operations CAPCO JEN 0001417 TABLE OF CONTENTS Appendix: A Preliminary Assessment of How the Recommended Asbestos Standard Can Successfully Be Implemented in Construction and Other Non-Fixed Work Operations................................................................ Introduction: Potential Asbestos Exposure in Construction and Other Non-Fixed Work Operations....................................................... A. Recommended Work Practice Procedures for Asbestos-Cement Pipe.............. 1. Sampling methodology and opera tions sampled for asbestos- cement pipe..................................................... 2. Methods.............................................................. 3. Operations sampled.................................... B. Recommended Work Practice Procedures for Asbestos-Cement Sheet............................... C. Recommended Work Practice Procedures for Drilling Mud Additives............................. Page lb 3b 9b 38b 39b 40b 49b 70b CAPCO JEN 0001418 APPENDIX A Preliminary Assessment of How the Recommended Asbestos Standard Can Successfully Be Implemented in Construction and Other Non-Fixed Work Operations As discussed in the body of this paper, the Recommended Standard for Asbestos Exposure in Construction and Other NonFixed Work Operations is intended to replace the impractical requirements of the current OSHA asbestos standard with an enforceable, cost-effective regulation which will both ensure that worker health is adequately protected and provide incen tives for the development of even safer products and work practices, all without sacrificing the important economic and practical benefits of asbestos-containing construction materials. The purpose of this Appendix is to present technical data which show that the Recommended Standard is more than just an appealing theoretical construct -- rather, it is a workable regulation which will impose requirements which are both acceptable and cost-effective. This Appendix begins with an Introduction which presents background information and data on the situations where exposure to airborne asbestos fibers may occur in construc tion and other non-fixed work operations. The Introduction also assesses preliminarily, based on the asbestos industry's experience*with these products and its knowledge of their ' CAPCO JEN 0001419 2b physical properties, the classifications (categories A, B or C) of the Recommended Standard under which the materials now in use are likely to fall. Following this preliminary qualitative assessment, the three succeeding sections of this Appendix contain detailed quantitative documentation showing that work practices for three asbestos-containing products commonly used in construc tion and other non-fixed jobs -- asbestos-cement pipe, asbestoscement sheet, and drilling mud additives -- can in fact qualify under Category B of the Recommended Standard. More specifi cally, simple work practices which have been developed by the manufacturers of these products (and which, in some instances, are already widely used) have been carefully field-tested by qualified laboratories, and the resulting data demonstrate that all three products can be validated under Category B of the Recommended Standard.i/ 1/ The exposure data presented in Parts A, B and C of this Appendix must be interpreted cautiously. As discussed in the body of this Paper (p. 28 above), the best available technique for measuring airborne concentrations of asbestos fibers is subject to a considerable degree of uncertainty, the magnitude of which (when expressed as a percentage of the actual concen tration) increases sharply as concentrations are reduced below 2.0 fibers per cubic centimeter of air. These statistical monitoring variations would, of course, be taken into account in any formal validation of the products and associated work practices involved. Nevertheless, while the exact range of the uncertainty is not now known (and is currently under study by AIA/NA), the data reported in Parts A, B and C below are so uniformly low that the products and work practices discussed can surely meet the classification criteria for Category B. CAPCO JEN 0001420 3b Introduction: Potential Asbestos Exposure in Construction and Other Non-Fixed Work Operations There are three distinct situations in which construction industry employees may be exposed to airborne asbestos fibers: (i) when they perform construction, maintenance, alteration or removal services in environments where asbestos fibers routinely may be present; (ii) when they demolish or remove construction materials which contain asbestos; and (iii) when they install or use construction materials which contain asbestos. The first type of situation will arise when a construction employee performs his services in an existing asbestos products plant. Such a facility is already subject to the current OSHA asbestos standard, and, as a result, construction workers will be protected by the controls installed by the owner of the facility pursuant to the current standard. Two special cir cumstances deserve attention, however. First, if an emergency arises requiring the use of respirators by the regular employees of the facility, the contractor must either remove his employees from the site or equip them with appropriate respirators. Second, if the work of the contractor disturbs asbestoscontaining dust which has accumulated in inaccessible places (for example, on suspended piping, ducts or wiring or on struc tural surfaces), special precautions (such as spraying with water or vacuuming) may have to be taken to avoid creating CAPCO JEN 0001421 4b airborne fiber concentrations in excess of mandated levels. As detailed above (pp. 22-23), the housekeeping and emergency provisions of Paragraphs (c)(2) and (d)(2) of the Recommended Standard are intended to deal with these special circumstances. The second health hazard situation will arise when a contractor performing maintenance, alteration or demolition work must remove construction materials containing asbestos. This is perhaps the most serious asbestos-related health hazard presented in the workplace today. It is serious first, because removal, and particularly demolition, by its nature is destructive and dust generating; second, because the presence of asbestos materials in old structures may be difficult to establish; and third, because friable, dust-producing asbestos products which no longer are marketed may nevertheless be present in older facilities. As in other construction operations where asbestos health hazards are present, work practices are the only effective means of worker protection in demolition or removal operations. Mandating changes in asbestos construction materials, or even banning their manufacture or sale, will not eliminate the hazard. Nor can permanently installed engineering controls be used to control asbestos dust created by demolition or removal. AIA/NA and AACPP have been studying these operations, and expect to be able to publish in the near future effective it work practices which would qualify under Category B of the Recommended Standard. CAPCO JEN 0001422 5b The third health hazard situation, of course, involves the fabrication and installation of asbestos-containing conduc tion materials currently offered in the marketplace. Fortu nately, the products which are being used today generate little dust. Sprayed asbestos insulations no longer are used. Spackling compounds and joint tapes contain little, if any asbestos. Air cell thermal insulations have been replaced by cheaper, more efficient glass fiber materials. Most molded thermal insulations contain no asbestos, and the few that do are used only in the most critical installations, applied by journeymen wo are thoroughly familiar with the hazards of asbestos and who know well how to protect themselves. The asbestos fibers in asbestos-cement products, asbestos-roofing and pipeline felts, drilling muds, paints, roofing mastics, vinyl asbestos floor tile and sheet vinyl flooring are bonded into or encap sulated by a matrix material, saturant, impregnant or coating. The fibers seldom are released; and the operations which may cause their reiease are well-defined. Thus, this third asbestos-health hazard situation clearly lends itself to the development and implementation of work practice controls. As the following table indicates, a variety of asbestoscontaining products are presently consumed in the United States, with asbestos-cement products, flloring products, friction materials, and asbestos-paper products comprising two-thirds total consumption; CAPCO JEN 0001423 6b U.S. Consumption of Asbestos by End Use - 1977 Asbestos Cement: Pipe Sheets and Shingles Flooring Products: Floor Tile Sheet Vinyl Friction Materials Asbestos Paper: Roofing Felt Pipeline Felt Other Gaskets and Packings Paints and Coatings Textiles Others TOTAL Short Tons 97,000 35,000 63,000 110,000 75,000 90,000 10,000 12,000 40,000 55,000 7,000 46,000 640,000 Percent 15.0 5.5 10.0 17.0 12.0 14.0 1.5 2.0 6.0 9.0 1.0 7.0 100.0 Source: Johns-Manville Corporation, 1979 Most of the annual production of these materials -- approximately 77% -- is consumed in the construction industry today. 40 Fed. Reg. 47652, 47653 (October 9, 1975). More over, based on industry's considerable experience with the use of these products in construction operations, its familiarity CAPCO JEN 0001424 7b with their physical properties, and the results of preliminary testing, there is little doubt that all of these products could be validated under Categories A or B of the Recommended Standard. Because of the efforts of manufacturers of asbestoscontaining construction materials to eliminate dangerous pro ducts from the marketplace, a large number of products could qualify under Category A for most or, in some cases, all operations in which they are used including the following products:--2/ Mastics and Black Line Products Roofing Felt Roofing Felts Mechanical Packings Oil Seals Compressed Gaskets Sealants and Caulks Electrical Insulating Paper Sheet Flooring Floor Tile In the three suceeding sections of this Appendix, detailed exposure monitoring data are presented showing that effective work practices, which in some cases are already widely used, will ensure that the permissible exposure limits 2/ Source: Johns-Manville Corporation CAPCO JEN 0001425 8b are met for three other products: asbestos-cement pipe, asbestos-cement sheet, and drilling mud additives. CAPCO JEN 0001426 9b Recommended Work Practice Procedures for Asbestos-Cement Pipe f'.APCO JEN 0001427 10b In order to reduce the generation of airborne concen trations of asbestos during the installation of A/C pipe, ACPPA designed a field manual containing specific work prac tices for use with its products. ACPPA distributed thousands of copies of this manual to OSHA, construction contractors, municipalities, insurance carriers, states, and others, in an effort to educate and to train their employees in the proper use of the recommended work practice procedures. Prior to publication, ACPPA contracted with Equitable Environmental Health, Inc. (EEH) to study employee exposure to airborne asbestos during field operations. The purpose of the EEH study was to determine the effectiveness of the work practices being recommended. To that end, EEH per formed personal monitoring on employees in the following field operations, utilizing, where appropriate, either non-pressure (sewer) pipe and/or pressure (water) pipe: 1. Unloading 2. Laying pipe in the trench 3. Cutting operations on both pressure and sewer pipe a. Cutting with hack saw b. Cutting with snap cutting equipment c. Cutting with abrasive disc, wet d. Cutting with abrasive disc, dry 4 e. Cutting with hammer, chisel and rasp ' CAPCO JEN 0001428 11b 4. Machining operations a. Machining with a manual field lathe b. Machining with a power-driven lathe c. Cutting and machining with Doty machine 5. Hole Cutting a. Hole cutting with power-operated equipment b. Hole cutting with drill, hammer and rasp 6. Tapping operations a. Dry tapping with Mueller J. tool b. Tapping operations with Mueller B-100 tool 7. Coupling removal a. Removal of coupling with hammer and chisel The above operations and processes are representative of the types ordinarily encountered at construction sites installing A/C pipe. Certain qualifications, however, should be identified. First, for those operations monitored by EEH, several options may exist for performing a particular operation, e.g. cutting with various tools or under varying conditions. Where appropriate, these operations are also listed. Second, on any given day, any one or all of those operations listed may be conducted. This, of course, depends on the individual job and its requirements. Pipe installation, cutting, machining, boring holes, and tapping are considered typical fabrication operations. A/C pipe, as with most other A/C products used in the con struction industry, requires minimal field fabrication. For CAPCO JEN 0001429 12b example, A/C pipe is supplied pre-assembled, along with a number of half and quarter lengths to minimize field cutting. When necessary, cutting to length is performed intermittently and only when the pipe terminates, as, for example, in a manhole. During the installation of smaller diameter A/C pipe, tapping is sometimes necessary, for example, when providing customer service lines from the main to the home, or when hook-up from other sources is required. The fre quency of these operations is, of course, highly variable. The total time committed to field fabrication is also quite variable. One particular survey, involving the instal lation of A/C pipe in seven major urban areas around the United States, reported that an average of 1.1 percent of the total job time involved the cutting, tapping, or machining of A/C pipe. Out of an average of 675 man-hours per job, these operations accounted for approximately 7.5 man-hours per job or 5.3 man-minutes per day. In conducting their study, EEH considered the inter mittent, infrequent, and short-term nature of the operations listed and. decided to monitor several successive operations during each sampling period. A short-term sampling period of 15 minutes was selected unless, in the industrial hygien ist's judgment, a sufficiently large sample could be obtained in a shorter time period. Additional information on the sampling and anlytical method used in the EEH study as well as a full description of the operations sampled is included CAPCO JEN 0001430 13b in pages below. The following tables summarize the results EEH obtained during its validation tests. In reporting these results, EEH cautions: "It should be emphasized that estimates of fiber concentrations below 5 f/cc are subject to increasing lack of precision, and that those below 0.5 f/cc have a fairly wide margin of error, often being based on the obser vation of relatively few fibers. Thus, although counts are reported as calculated (in some cases) to two decimal places, differences in counts in these ranges should not be over interpreted. " CAPCO JEN 0001431 14b Table VI Average Peak Exposures During Unloading/Laying A/C Pipe Operation 1. Unloading Pipe 2. Laying Pipe Background 0.1 fibers/cc 0.1 fibers/cc Below detectable limit Table VII Average Peak Exposures (Up to 15 Minutes) During Other Operations (fibers/cc) A/C Sewer Pipe A/C Pressure Pipe Operation Operator Helper Operator Helper 3. Cutting Operations 3a. Hack Saw 3b. Snap Cutting 3c. Abrasive disc, wet 3d. Abrasive disc, dry 3e. Chisel, hammer and rasp 4. Machining Operations 4a. Manual Lathe 4b. Power Lathe 4c. Cutting and Machining with Doty Machine Dry Dry, Shroud Wet Shroud 4d. Tapering Tool with Airduct Pipe 0.18 42.10 35.50 0.30 0.15 <0.10 3.83 0.23 0.20 0.18 o Vo <0.10 <.0.10 10.20 64.00 0.25 < 0.10 <0.10 65.00 20.30 1.99 0.13 0.10 0.29 0.10 0.10 <0.10 0.51 0.29 1.90 1.29 0.21 0.11 ND 49.20 59.70 0.87 0.22 0.18 2.23 0.18 0.27 CAPCO JEN 0001432 15b Operation Table VII (Continued) A/C Sewer Pipe Operator Helper A/C Pressure Pipe Operator Helper 4e. Machining with Manual Lathe on Differing Sizes of Pipe 4-inch pipe 8-inch pipe 16-inch pipe 5. Hole Cutting 5a. Powerhole Cutter 0.44 5b. Hole Cutting with Drill, Hammer & Rasp 0.23 6a. Dry Tap with Mueller J Tool 6b. Tapping Operations with Mueller B-100 <0.10 7. Coupling Removal 7a. Removal of Coupling with Hammer & Chisel 40.10 o O o r --( O \| ND 4o.io 40.10 0.13 <0.10 0.23 0.13 1.65 0.22 0.38 <0.10 40.10 ND < 0.10 0.11 0.10 0.13 ND 0.30 0.10 It is important to recognize that the above results represent one or more consecutive operations run to a maximum sampling time of 15 minutes. Two operations clearly cannot be recommended and in fact should be prohibited: cutting and machining with Doty tool without a shroud and cutting with abrasive discs. As indicated in the summary j data, significant peak exposures can result from their use. <i CAPCO JEN 0001433 16b As for the other operations, they are intermittent, short-durational operations. For the purpose of calculating 8-hour TWA's, a conservative calculation was made by assum ing employees would work at a given operation 1 hour per day. Further, assuming that during the remaining 7 hours of the day they were not exposed, the following 8-hour TWA's would be expected (excluding the two operations not recom mended) . Table VIII Computed Time-Weighted Average Exposures During Operations Involving A/C Pipe (fibers/cc) Operation A/C Sewer Pipe Operator Helper 1. Unloading Pipe ND 2. Laying the Pipe in Trench ND 3. Cutting Operations <0.10 3a. Hack Saw <0.10 3b. Snap Cutting <0.10 3c. Chisel, Hammer and Rasp <0.10 4a. Manual Lathe <0.10 4b. Power Lathe <0.10 4c. Cutting and Machining with Doty Tool Dry, Shroud <0.10 Wet, Shroud <0.10 <0.10 <0.10 <0.10 <0.10 < 0.10 <0.10 <o.rb ND A/C Pressure Pipe Operator Helper ND ND 0.25 <0.10 < 0.10 <0.10 UD 0.11 <0.10 <0.10 0.16 <0.10 \ <0.10 <0.10 CAPCO JEN 0001434 17b Operation Table VIII Continued A/C Sewer Pipe Operator Helper A/C Pressure Pipe Operator Helpe 4d. Tapering Tool with Airduct Pipe 0.10 4e. Manual Lathe 4-inch pipe 8-inch pipe 16-inch pipe 5a. Power Hole Cutter <0.10 6a. Dry Tap with Mueller J Tool <0.10 6b. Tapping Operations with Mueller B-100 <0.10 7a. Removal of Coupling <0.10 with Hammer and Chisel ND <0.10 ND ND <0.10 ND ND ND 0.21 < 0.10 <0.10 <0.10 ND < 0.10 <0.10 <0.10 <0.10 <0.10 <0.10 In addition to the analysis performed above, Table IX below was constructed to illustrate the theoretical TWA. range of exposures which might be anticipated when working with A/C pipe during pipeline installation. The theoretical TWA exposure range is calculated by assuming the duration of the operation ranged from 15 minutes to 2 hours, with the remain ing time calculated at zero exposure. % r.APCO JEN 0001435 18b Table IX Ranges of Eight-hour Time-weighted Average Concentrations Derived From Equitable Environmental Health, Inc. Data Operation A/C Sewer Pipe Operator Helper A/C Pressure Pipe Operator Helper 1. Unloading Pipe ND 2. Laying the Pipe In Trench ND 3. Cutting Operations 3a. Hack Saw *<0.10 ND-<0.10 ND ND-<0.10 3b. Snap Cutting ND-<0.10 ND-<0.10 ND ND 3c. Chisel, Hammer and Rasp <0.10 <0.10 <0.10-.50 <0.10-.22 4a. Manual Lathe <0.10 <0.10 <0.10-.12 <0.10 4b. Power Lathe ND-<0.10 ND-<0.10 <0.10 <0.10-.14 4c. Cutting and Machining with Doty Tool Dry, Shroud <0.10 ND-<0.10 <0.10-.32 <0.10 Wet, Shroud <0.10 ND <0.10 <0.10 4d. Tapering Tool with Airduct Pipe <0.10 4e. Manual Lathe 4-inch pipe ND ND 8-inch pipe ND <0.10 16-inch pipe ND ND-<0.10 5a. Power 'Hole Cutter <0.10-.12 <0.10 0.10 <0.10-.10 V No range is reported when both values were<0.10 f/cc. riAPCO JEN 0001436 19b Operation Table IX Continued A/C Sewer Pipe Operator Helper A/C Pressure Pipe Operator Helper 6a. Dry Tap with Mueller J Tool 6b. Tapping Operations with Mueller B-100 7a. Removal Coupling with Hammer and Chisel ND-<0.10 ND-(0.10 ND-<0.10 ND ND ND-<0.10 ND-0.10 ND-0.10 0.10 ND-<0.10 <0.10 ND-<0.10 As shown in Tables VI, VII, VIII, and IX, the use of certain work practices for A/C pipe will provide effective worker protection that can be feasibly and practically implemented in the construction industry. Following the completion of the EEH study, ACPPA published and distributed nearly 85,000 copies of its field manual, "Recommended Work Practices for A/C Pipe.'' The recommenda tions set forth in the manual are based on the data developed by EEH and experience gained in the field. Based on the wide-spread acceptance of the manual, the American Water Works Association (AWWA) adopted these same work practice recommendations and included them in their manual M-16 1 "Work Practices for Asbestos-Cement Pipe." ACPPA is convinced that when recommended work practices are followed, no adverse health effects will be realized during normal employment in a construction environment .where A/C pipe is used. It is the position of the asbestos CAPCO JEN 0001437 20b industry that similarly safe and effective work practices can be developed to assure employee protection during the use of all asbestos-containing products in the construction industry. The following publication sets forth recommended work practices for A/C Pipe. CAPCO JEN 0001438  l * CAPCO JEN 0001439 22b Products and Operations Types of A/CPipe Products covered by these work practices indude: "Class" Pressure Pipe "Transmission" Pressure Pipe Pressure Sewer Pipe Gravity Sewer. Pip*e Building Sewer Pipe Storm Drain Pipe Perforated Underdrain Pipe Electrical Conduit Telephone Duct Air Duct Operations to which these work practices apply indude: Shipping, Receiving and Handling Cutting Machining Hole Cutting Tapping Coupling Removal Housekeeping and Waste Disposal CAPCO JEN 0001440 23b Shipping, Receiving, Handling and Assembly* i || A/C pipe is shipped dean from the factory and carefully loaded iusing methods acceptable to the carrier. Loading, unloading j U ' stringing out and assembling A/C pipe are essentially dust-free !; operations. Even in endosed spaces, airborne asbestos fiber :j levels from pipe handling operations are far below existing and ;>! proposed occupational standards. ill All hand and mechanical tinloading operations should be car.' l tied out in accordance with the manufacturer's installation man j uaIs. f i ( | A/C Pipe Products: All Size Range: All 1 'Exposure data not currently available. Recommendationputd on exposure data j for operations believed to be comparable. [ CAPCO JEN 0001441 j ' 24b ' Cutting Carbide Blade Equipment Blade ratters consist of a frame adjustable to the circumference of the pipe and a number of outboard, seif-tradring rollers that align one or more carbide-tipped ratting blades. Blade ratters 'are typically hand-operated. Due to the relatively low mechanical ,, input and dean ratting action, significant amounts of airborne asbestos dust are not produced. A/C Pipe Products: All Size Range: 3* through 24* i i I t 3 1tt i< CAPCO JEN 0001442 25b Cutting ^ Snap Cutting Equipment r r Sp cutters or "squeeze and pop" equipment operates by means oftutting wheels mounted in a chain wrapped around the pipe bacnel. Hydraulic pressure, applied by means of a remote electric or manually-operated pump, simultaneously squeezes the cuttiag wheels into the pipe wall until the cut is made. iWC Pipe Products: All Sse Range: Pressure Pipe--3* through 24' Pressure, Gravity and Building Sewer; Storm Drain; Air, Electrical and Telephone Duct--3* through 36' CAPCO JEN 0001443 26b t Madiining Field Lathe--Manual r n -j r n c: M Mn/ ` Sfanual field lathes are designed to end-trim and re-machine fimugh pipe barrels to factory-machined end profiles. The lathe consists of an adjustable, seif-aligning arbor inserted into the pipe bore (which acts as a mandrel upon which the turning handle operates), a screw-fed turning frame, carbide machining j Blades and manual (hand or ratchet) turning handles. I n i SIC Pipe Products: All Sze Range: All if \ CAPCO JEN 0001444 27b l ! i CAPCO JEN 0001445 - 28b - Machining jj Rasp--Manual* f Short lengths of A/C pipe (MEH's fc MOA's) can be cut for pipe dosures, repairs and to locate fittings exactly. Field cat ends may be rebeveied with a coarse wood rasp to form a taper approximat ing the same profile as the factory-beveled end. A/C Pipe Products: All Size Range: All 'Exposure data not currently available. Recommendation based cn exposure data for operations believed to be comparable. V CAPCO JEN 0001446 Hole Cutting Shell Cutters \I <_i--_-_--_-_--_--_-_--_-_--_--_-_--_-_--_--_-_--_- 2 9b ii'i For field connections into A/C pipe, clean, even entry cuts may j ; :,j!! be accomplished by means of shell cutting equipment. Shell 1 ! ijl* cutters consist of a hole cutter housing mounted on the pipe, a i j:,;.; carbide or diamond-tipped hole cutter and a manual ratchet, j :;j pneumatic, electric or gasoline drive to power the cutting head. J ;j \ When cutting holes in A/C pipe products, all dust and cuttings 1 :;:r should be removed from the pipe or duct interior after the cutting j operation. Removal may be accomplished by flushing with wa- ' ter, wet mopping or vacuuming prior to placing in service. DO 1 : `;i NOT BLOW OUT WITH COMPRESSED AIR OR DRY SWEEP. \ A/C Pice Products: Pressure, Gravity and Building Sewer; !| Air Duct :)i Size Range: All 1 1 I I '1. CAPCO JEN 0001447 - 30b - Hole Cutting Drill and Rasp* i * Hi M jjr I I *!i > Field connections may be made with a heavy duty electric drill and rasp. Using a carbide-tipped drill, a series of dosely-spaced holes are first drilled around the hole outline. The disc is knocked free with a hammer and the edges of the hole are dressed with a coarse wood rasp. When cutting holes in A/C pipe products, all dust and cuttings should be removed from the pipe or duct interior after the catting operation. Removal may be accomplished by flushing with wa ter, wet mooping or vacuuming orior to placing in service. DO NOT BLOW OUT WITH COMPRESSED AIR OR DRY SWEEP. A/C Pipe Products: Pressure, Gravity and Building Sewer; Air Duct Size Range: All i;i `Exposure data not currently available. Recommendation based on exposure data for operations bedeved to be comparable. JC CAPCO JEN 0001448 - 31b - f Hole Cutting | Chisel and Rasp AV A f\ \ \\\ \\ --' --- [ Holes may be cut into A/C pipe with a hammer and chisel. The j edge of a plumber's-wood chisel is used to cat completely around the hole outline, about a Vi' from the prescribed line. The opera tion is repeated and the cut deepened until through. The edges of J the hole are then dressed with a coarse wood rasp. I When cutting holes in A/C pipe products, all dust and cuttings | should be removed from the pipe or ductinterior after the cutting operation. Removal may be accomplished "by flushing with wa ter, wet mopping or vacuuming prior to placing in service. DO NOT BLOW OUT WITH COMPRESSED AIR OR DRY SWEEP. ; A/C Pipe Products: Pressure, Gravity and Building Sewer; Air Duct Size Range: All CAPCO JEN 0001449 . 'I - 32b - Tapping Non-Pressuie r Non-pressure or "dry" tapping for service connections may be performed in or above the trench. The equipment is affixed to the pipe by means or a chain yoke. Separate drills and taps or a combination tool drills and taps the pipe wall. Corporation stops or other connections may then be affixed to the pipe. To minimize (a) the fouling of valves, regulators, meters, etc. with chips and (b) unnecessary addition of asbestos to drinking water, all dust and cuttings should be removed from the pipe interior by flushing with water, wet mopping or vacuuming prior to placing in service. DO NOT BLOW OUT WITH COM PRESSED AIR OR DRY SWEEP. A/C Pipe Products: Pressure Pipe 5ize Range: All 'Exposure data not currently available. -tecommendaeon based on exposure data for operations believed to be comparable. APCO JEN 0001450 Tapping Pressure* 33b V Pressure or "wet" tapping for service connections is performed in the trench while the pipe is under pressure. The equipment (manual or power driven) is affixed to the pipe by means of a chain yoke. A combination boring and inserting bar drills and taps the pipe wall and inserts a corporation stop or pipe plug. The pressure chamber, which protects against water leakage, also catches the asbestos-cement chips, so this is essentially a dustfree operation. To minimize (a) the fouling of valves, regulators, meters, etc. with chips and (b) unnecessary addition of asbestos to drinking water, provisions should be made for downstream flushing or use of tapping equipment with positive purge or "blow-off" features. A/C Pipe Products: Pressure Pipe Size Range: All Exposure data not cusrtntiy available. Recommendation based on exposure daa for operations believed to be comparable. fiAPCO JEN 0001451 35b Housekeeping and Waste Disposal Housekeeping is an important part of any safe construction operation. It is even more essential when airborne dust ceated by the lack of good housekeeping has the potential Sac harm to em ees or others. EQUIPMENT external surfaces of equipment should be maintained free of dust accumulations that might, if dispersed, create asbestos fiber concentrations above per missible exposure limits. WASTE DISPOSAL; Asbestos-cement chips and cut tings from the field operations described in this booklet should be disposed of in a manner that will not contribute airborne asbestos dust to the atmosphere. Where cutting and machining operations are performed at the construc tion site, the chips should be placed in the trench and buried with the pipeline. Where operations are performed at a central location such as a contractor's or distributor's yard on a more or less continuing basis, the chips and cuttings may be collected and mixed wet with cement and made into non-friable forms. These forms may be used in the trench as supports far cast iron fittings and valves, as appropriate. Otherwise, chips and cuttings should be collected in sealed bags or closed containers impermeable to asbestos dust. Loose material should never be drj strept. When vacuum equipment is available, it should be used. Water or other dust suppressants should be applied in those tircumstances where sweeping is unavoidable. DO NOT BLOW WASTE MATERIAL WITH COMPRESSED AIR. No visible emissions to the atmosphere may result from the collection, processing, packaging, transporting or de position of any asbestos-containing material. Wastes riiouid be disposed at a site operated in accordance with the requirements or applicable national, state or local laws. CAPCO JEN 0001452 1 r* - 36b - NON-RECOM MENDED PRACTICES \ Section 2 Non-Recommended Work Practices Cutting Any A-C Pipe Using Abrasive Disc-Dry Tools. r < n 1 < f l Power-driven saws with abrasive discs (masonry blades) should not be used for dry cutting or beveling A-C pipe. Abrasive disc cutters product concentra tions of airborne dust that exceed OS HA permissible levels. This work practice is therefore specifically not recommended. % I i CAPCO JEN 0001453 37b WORK PRACTICES FOR ASBESTOS-CEMENT PIPE Machining Any A-C Pipe Using Right-Angle Sanders or Other Dry High-Speed Abrasive Tools. Power-driven abrasive-disc sanden should not be used for shaping or beveling A-C pipe. Abrasive discs produce concentrations of airborne dust that exceed OSHA permissible levels. This work practice is therefore specifically not recommended. CAPCO JEN 0001454 38b Sampling Methodology and Operations Sampled for Asbestos-Cement Pipe CAPCO JEN 0001455 METHODS Air samples were collected on 37-millimeter diameter, 0.8 micron pore size Millipore cellulose ester membrane fil ters in accordance with OSHA and NIOSH recommendations. They were all "open-face" (with the cover of the filter cassette removed) samples. Personal sampling pumps were operated at flow rates ranging from 1.6 to 2 liters per minute. The pumps were calibrated by the soap bubble technique before use. Both area and personal (breathing-zone) samples were taken. In the latter, the pump was attached to the worker's belt and the filter clipped to his lapel near his face. All samples were analyzed by a laboratory accredited by the American Industrial Hygiene Association, following OSHA and NIOSH methods. Briefly, the analytic procedure consisted of rendering the filter transparent with a high viscosity solution of membrane filter material in a mixture of diethyl oxalate and dimethyl phthalate. The asbestos fibers which lie on the surface of the filter are counted with a phase contrast microscope at 400x magnification. The count area was delineated with a Porton graticule. Only fibers exceeding 5 micrometers in length were counted. The laboratory examined 100 microscopic fields or counted 100 fibers, whichever came first. Fiber identification depended upon a particle having an aspect ratio of at least 3:1 and having approximately parallel sides. CAPCO JEN 0001456 40b It should be emphasized that estimates of fiber con centrations below 2 fibers/cc are becoming increasingly less precise, and those below 0.5 fibers/cc have a fairly wide margin of error, often being based on the observation of relatively few fibers. Thus, although counts are re ported as calculated to two decimal places, differences in counts in these ranges should not be overinterpreted. OPERATIONS SAMPLED (1) Unloading. This operation was performed with a palletized or "unitized" load, the standard packing/shipping method for A/C pipe using a forklift. The 8 inch pipe was arranged on 4 foot pallets, 8 per bed, plus miscellaneous short lengths and couplings. Using a fork lift, it took approximately 15 minutes to unload a two-bed truck. For this operation, a single 24-minute personal sample was taken on the fork-lift operator while pressure pipe was being unloaded. (2) Laying the pipe in trench. The operation which was studied involved trenching, laying pipe, and back-filling simultaneously. One worker remained in the trench at the forward end of the pipe. The second worker worked both topside and in the trench. He attached a lowering clamp to the pipe, lubricated the pipe end, then entered the trench to help tguide it into place for coupling. Two 1 1/2 CAPCO JEN 0001457 41b hour samples were collected in addition to personal samplers taken from the two workers. (3a) Cutting with hack saw. A standard hack saw with a hardened steel blade was used for this operation. The blade was changed before each run. Sampling times ranged from 12 to 15 minutes, during which time it was possible to cut about one-half way through the 8" pressure pipe. This tool was not used with sewer pipe. (3b) Cutting with snap cutting equipment. For this portion of the study, a Wheeler Chain Cutter (Model 2990) was used. It has cutting discs mounted on a chain which is wrapped around the pipe. The action is controlled hydrauli cally by an operator who can stand as far as 10 to 15 feet from the pipe being cut. The set-up between cuts took about two minutes. Pumping to build up pressure required about 15 seconds. Five to 8 cuts were made during each sampling period; the average ranged from 14 to 16 minutes for sewer pipe and 13 to 16 minutes for pressure pipe. (3c) Cutting with abrasive disc, wet. A gasoline-powered abrasive disc saw (Stihl) with a 10-inch carbide blade was used. Four 1/4 inch diameter plastic hoses were mounted on the housing of the saw, two on a side. These were connected to a manifold to which was attached a hose delivering water at a rate of 2 to 3 gallons per minute. c< CAPCO JEN 0001458 42b A preliminary run was made with a saw that proved to be underpowered, requiring 18 minutes for two cuts. With a more powerful saw (1 1/2 hp motor) a cut would be completed in approximately 1 1/2 minutes. Two to 3 cuts were taken per sample, the sampling periods having been reduced to 3 to 6 minutes after an initial test sampling period of 17 minutes had led to overloading of the filter with dust. This test was run on pressure pipe only. (3d) Cutting with abrasive disc, dry. A gasolinepowered abrasive disc saw (Stihl) with a 10" diameter carbide blade was used in this test. When cutting with the saw, the operator held the saw while the helper rolled the pipe along the ground toward or away from him. No machining of the ends was performed with this method of cutting. On both sewer and pressure pipe, one cut would be made in 30 to 45 seconds. Each peak sample included four cuts. (3e) Cutting with hammer, chisel, and rasp. The pipe was cut with a hammer and chisel, and the edges then smoothed with a course file. The helper rotated the pipe as the operator worked. Two cuts of sewer pipe, each taking 4 to 6 minutes, were made during the short-term or peak sampling period. Cutting the pressure pipe lasted 11 minutes, and only one cut was made per sample. (4a) Machining with a manual field lathe. The equipment * (Pilot Ratchet Field Lathe, Model B-12R) was attached to the CAPCO JEN 0001459 43b end of an 8-inch pipe supported 2 to 3 feet from the ground. The lathe had two sets of blades, one for the actual cut and the other to machine and profile the pipe end. The depth of cut could be adjusted manually with screws. A ratchet allowed the operator to turn the lathe by pumping a handle. The helper adjusted the depth of cut as the lathe rotated about the pipe and also assisted in lathe turning. For sewer pipe, one complete cycle took about 8 minutes, i.e., 2 minutes to cut and 6 to 7 minutes for set-up and machining. Each short-term peak sample repre sented two cycles. Cutting pressure pipe took longer, 4 minutes for cutting and 8 to 9 minutes for set-up and profiling. Each short-term sample covered a single cut. (4b) Machining with a power-driven lathe. The electricpowered lathe (Pilot Powered Field Lathe, Model B-12P) worked on the same principle as the manual lathe. Due to the ease of operation, a helper was unnecessary. Sewer pipe took 1/2 to 1 minutes to cut and 4 1/2 to 5 1/2 minutes to profile. Two cycles were completed for each short-term ("peak") sample. Again, cutting pressure pipe took longer, 1 1/2 minutes to cut and 5 to 6 minutes to profile; two cycles were used per sample. (4c) Cutting and machining with Doty machine. The Doty machine is custom-manufactured equipment which has two CAPCO JEN 0001460 44b operating stations, one for cutting, and one for machining. It has three operating modes: dry, dry with shroud, and wet with shroud. The last two modifications were designed to reduce dust generation and dispersion. During tests of the tool in the dry mode with shroud and wet mode with shroud, a plastic bag was placed over the blade to reduce dust. All cuts were made wet, because a diamond blade was used. A fine spray of water was directed across the blade during operations. A single cut requires one-half minute. Machining was performed dry with no shroud, dry with shroud, and wet with shroud. Again for the wet mode, a fine spray was used. The operation took about 1 minute with most of the sampling time used for moving pipe. The Doty tool was essentially a one-man operation, a helper was needed only to move large diameter pipe. Two to four cuts and two to four machining operations were completed per sample cycle. Because visible dust was raised by the dry mode, sampling time was reduced from approximately 51 minutes to approximately 10 minutes. Observers also noted that visible dust was released during bevelling on the dry mode with shroud tests. It was sug gested that a gasket or some other seal would be helpful in preventing this. Sampling times recorded during use of the Doty tool, wet, for pressure pipe were 10 to 11 minutes and for sewer * CAPCO JEN 0001461 45b pipe 9 to 15 minutes. In operations involving the Doty tool with shroud the sampling times for pressure pipe were 13 to 17 minutes, and for sewer pipe, 12 to 14 minutes. For usage of the Doty Tool, wet with shroud, 13 to 18 minute sampling times were employed for pressure pipe, 12 to 16 minutes for sewer pipe. (4d) Use of tapering tool with A/C air duct. Testing of the tapering tool was limited to 10-inch A/C air duct pipe, which has a wall thickness of approximately 1/4 inch. Its operating principle is similar to that of the manual field lathe. Sampling times ranged from 14 to 22 minutes which included one cut and one tapering operation. (4e) Machining with manual lathe on differing sizes of pipe. In order to determine whether pipe size had a detectable influence on dust production, a manual lathing operation was carried out on pressure pipe with 4-inch, 8-inch, and 16-inch diameters. For the 4-inch pipe, there was one cut and one machining operation for each sample. The set-up required about 3 minutes, the cut about 3 minutes; the second set-up about 4 minutes, and machining about 8 minutes. The replicate samples ranged 13 to 21 minutes. For 8-inch pipe, one cut and one machining operation were performed for each sample. The set-up required about 3-1/2 minutes, the cut about 2 minutes; the second set-up took about 2 minutes and machining about 10 minutes. The replicate samples ranged from 19 to 21 minutes. CAPCO JEN 0001462 46b For the 16-inch pipe there was one partial cut per sample including some machining and some cutting. The set-up re quired 3 minutes, the cutting about 12 minutes, the second set-up about 2 minutes, and machining about 20 minutes. (5a) Hole cutting with power-operated equipment. The tool used for this operation (Pilot Hole Cutter, Model HC-38E) is available with either an electric or gasoline engine. In this test, a gasoline powered engine was used to cut a 4 1/2" diameter hole with a small center plug. The cutter was secured to the pipe with a chain. The engine rotated the blade while the operator continuously adjusted the height of the blade. The helper aided in equipment set-up. It took about 1 minute to cut a hole in sewer pipe and 1 1/2 to 2 minutes for pressure pipe. A two minute set-up time was required between hole cutting operations. Four holes were cut for each peak sample. (5b) Hole cutting with drill, hammer and rasp. For this operation, 5/8 inch holes were drilled on the pipe in a circular pattern about 6 inches in diameter, after which the central portion was knocked out with a hammer and the rough edges smoothed with a rasp. The operator used the exhaust air from the drill to blow off excess dust. The drilling took a long time to complete, so that only about 3/4 of the circumference was finished in one sampling period. Therefore, some*samples did not include the hammer and file CAPCO JEN 0001463 47b steps. Sampling times for pressure pipe ranged from 16 to 24 minutes, for sewer pipe, from 17 to 21 minutes. (6a) Dry tapping with Mueller J tool. The Mueller J tool is used for tapping pipe for customer service connec tions. In field operations, the operation may be done at the trench tap, or in the trench. A manually operated tool, which cuts a hole and threads it, was used. Two one-inch holes were cut per sampling period. Sampling periods for pressure pipe were 14 to 29 minutes, for sewer pipe 15 to 18 minutes. (6b) Tapping operations with Mueller B-100 tool. The Mueller B-100 tool is used for tapping pipes already in place and containing water. In the field, a hole is dug to expose the pipe; for the test, an uninstalled pipe was used. It has a pressure chamber to keep the -water from flowing out. For the tests, this chamber was filled with water to simulate "wet" tapping conditions. There were two holes cut per sampling period. For pressure pipe, the sampling times were 14 to 19 minutes, for sewer pipe 14 to 19 minutes. (7a) Removal of coupling with hammer and chisel. A hammer and chisel were used to make a longitudinal trough in the coupling. When this was completed, a crowbar was used to separate the coupling. For pressure pipe, this operation took about 22 minutes with one coupling being removed per sample. For sewer pipe, the saifle procedure CAPCO JEN 0001464 48b took about 10 minutes per sample. It was soon found that by placing the chisel midline on the coupling, one or two sharp hits would split the coupling, a procedure which took only 10-30 seconds per coupling. For sewer pipe, 3 to 4 couplings were cut per sample, with the major portion of the sampling time used while the pipe was moved and secured to supports. % OADO.O JEN 0001465 49b Recommended Work Practice Procedures for Asbestos-Cement Sheet fiAPCO JEN 0001466 50b Shortly after the promulgation of the original asbestos standard in 1972, the Johns-Manville (J-M) Corporation actively began pursuing the development of local exhaust systems for use with portable power tools used in the field fabrication of A/C sheets. Initial attempts to interest tool manufacturers to market a product that was equipped with a hood and suitable for attachment to a vacuum source met with little success. This setback was partially due to the fact that the demand for such specialized equipment had not evolved as rapidly as the development of the exposure stan dard. Additionally, portable vacuum systems, meeting the efficiency necessary to filter asbestos dust, were also not available. During the period between 1973 and 1975, two new vacuum systems were introduced. One was a semi-portable, high efficiency system developed by the Hoffman Company; the other, a much smaller but equally efficient unit, was de veloped by the Niefisk Company of Sweden. With these ad vances, J-M undertook an in-house tool development program. Several prototypes were examined and tested, ranging from retrofitted enclosures to systems designed specifically for individual tools. A suitable system was eventually developed in 1975. J-M approached tool manufacturers with their new designs and again, was told there was no interest in market ing such a product line. CAPCO JEN 0001467 51b The tool designs, as well as the vacuum specifications necessary for efficient operation, were first made available by J-M in 1975. AIA/NA subsequently released a pamphlet on A/C sheet illustrating the use of these systems a year later. Although considered effective, the exhaust system de signed for the circular saw was somewhat awkward, i.e., a separate vacuum box collected dust from the bottom of the sheet during cutting operations. In 1977, J-M began develop ment of an improved system. This continued through 1978 and eventually led to the development of a new hood design; one that enclosed the entire saw and eliminated the need for a vacuum box. This design was further refined in early 1979. The Pilot Tool Manufacturing Company (manufacturers of A/C pipe tools) was approached by J-M in early 1979 and agreed to purchase portable tools and equip them with the hoods designed by J-M. Subsequently, the J-M designs were further improved under Pilot's direction. Through the diligent and persistent effort of J-M, portable power tools equipped with a high velocity/low volume exhaust system are now available for use with A/C sheet. Air monitoring tests were conducted by J-M on operations involving the use of a circular saw and drill equipped with the newly designed system. The results of these tests are reported in Table XV below. CAPCO JEN 0001468 52b Table XV Air Monitoring Test Results Using Circular Saw and Drill Equipment Test Conditions* Test Duration Material Fabricated Quantity/ Type Quantity Minute Drill with dust pickup shroud 1/A inch masonary bit, opera ted at full speed. Drilled downward through horizontal board 40 min 1/4 inch flat A/C sheet 163 holes 4.08 holes Circular saw with dust pick-up shroud Totally enclosed shroud masonary blade 40 min 1/4 inch flat A/C sheet 720 holes 18 inch Dust Concentration (personal) <0.1 0.0 Based on these results, as well as the results from other testing (e.g., saber saws), a work practice manual was developed. Its primary purpose is to inform the users of A/C sheet products of the proper tool selection and work practices which would permit the field fabrication of asbestoscement sheets in an acceptably dust-free manner. Excerpts from this manual, entitled "Recommended Work Practices for A/C Sheet," are reproduced below. * All tests conducted in an open room. Source: Johns-Manville Corporation r.APCO JEN 0001469 - 53b - FIELD FABRICATION OF AS3ESTQS-CEHEJT SHEET i-'ADon JEN 0001470 54b Products and Operations The following work practices are applicable to flat and corrugated A/C sheet products. Operations to which these work practices apply include: Shipping, Receiving and Handling Cutting Drilling Hole Cutting and Cutouts Housekeeping and Waste Disposal Equipment used with these work practices is available from the sources shown in the equipment list. t o.apco JEN 0001471 55b Shipping, Receiving a: cii in A/C sheet is shipped from the'factor/ with clean surfaces, generally- in pallet loads, using shipping methods acceptable to the producer and the customer. All unloading operations should be carefully performed to avoid sheet damage. Pallet loads are normally unloaded by fork truck. Small shipments may require manual unloading. CAPCO JEN 0001472 56b Cutting - flat Sheets Circular Saw______ Circular Saw With Bust Collection Hooc Circular saws for cutting flat sheets should be used only when equipped with the specific dust collection hoods pictured above. Exhaust ventilation and dust collection is provided by a vacuum cleaner as described in the specifications (page 15). A circular saw cuts by a "pulverizing" action which releases asbestos fibers and fine particulate. The combination of hood and vacuum source is highly effective in capturing and collecting these particles and fibers. Saw operating techniques are those normally employed. No special procedures are required except adjustment of the lower hood section to suit thickness of sheet being cut. Saw design requires the use of blades recommended by the tool supplier (abrasive disc or diamond). For additional information on saw operation, refer to the supplier's instructions in Appendix"A. capco JEN 0001473 Cutting - Corrugated Sheets Circular Saw________ Circular Saw With Dust Collection Hood Circular saws for cutting corrugated sheets should be used only when equipped with the specific dust collection hood pictured above. Exhaust ventilation and dust collection is provided by a vacuun cleaner as described in the specifications (page 13). A circular saw cuts by a "pulverizing" action which releases asbestos fibers and fine particulate. The combination of hood and vacuum source is highly effective in capturing and collecting these particles and fibers. Saw operating techniques are those normally employed. Saw design requires the use of blades recommended by the tool supplier (abrasive disc or diamond). This tool. depends on pliable "fingers" to seal the cutting zone and is designed for use on sheets with 1 1/2" deep corrugations. For cutting sheets with deeper or irregular corrugations, consult the tool supplier. For additional information on saw operation, refer to the supplier's instructions in Appendix A. CAPCO JEN 0001474 58b Cutting - Handsaw Handtoois Handsaw This is a handsaw equipped with a carbide blade designed for cutting asbestos-cement sheet. Practical use of this saw is limited by its slow cutting speed. It is most useful in operations where cutting is infrequent and of short duration. 3ecause of the slow cutting speed, saw operation generates coarse particles or asbestos-cement with, few airborne fibers. Its use docs not require dust collection equipment for compliance with present exposure limits. rtAPCO JEN 0001475 59b Cutting - lint Sheets Hand Cl inners Handtoois Hand Clippers These hand clippers are designed for cutting sheet material up to 1/4" in thickness. Practical use is limited by slow cutting speed. It is most useful in operations where cutting is infrequent and of short duration. The clipper cutting action generates coarse particles of asbestos-cement with few airborne fibers. Its use does not require dust collection equipment for compliance with present exposure limits. t. \ * CAPCO JEN 00014-76 Cutting - Plat Sheets Score S Snap Knife Handtoois Scoring Knife The scoring knife can be used with sheets up to i/i" in thickness. However, it performs best with sheets 1/S" and 3/16" thick. The sheet is placed on a worktable or saw horses. A suitable guide bar is placed or clamped along the cut line and the sheet scored repeatedly. After scoring, the sheet is hand snapped along'the score line. This cutting procedure generates little dust and few airborne fibers. Its use does not require dust collection equipment for compliance with present exposure limits. CAPCO JEN 0001477 61b Drilling - Power Drill Drill V/ith Dus; Collection Hood Drilling of small holes (1/1" or less) on vertical surfaces, or downward usually can be done without dust collection equipment and in compliance with present exposure limits. Drilling of larger holes, and drilling overhead', requires dust collection equipment on the drill in order to achieve compliance. Equipment includes a hood (Cape Universal Building Products, Ltd.) and vacuum cleaner to provide exhaust ventilation and dust collection. Vacuum cleaner should be as described in specifications (page 15). Drilling techniques arc those normally employed. No special procedures are required. rtAPno JEN 0001478 -62b Hole Cutting and Cutouts - Flat Sheets S ab re o aw Sabre Saw With Dust Collection Hood Sabre saws should be used only when equipped with the specific dust collection hood pictured above. Exhaust ventilation and dust collection is provided by a vacuum cleaner as described in the specifications (page 13). Saw operating techniques are those normally employed. Mo special procedures are required. For additional information on saw operation, refer to supplier's instructions in Appendix A. fiAPCO JEN 0001479 -63b Hole Cutting and Cutouts - Drill and Hasn A simple method of making cutouts is to drill small holes around the edge of the opening to he cut and knocking nut the material to be removed with a hammer. A rasp is used to dress or bevel edges of the cut. This procedure does not require dust collection equipment for compliance with present exposure limits. r.APCO JEN 0001480 64b Vacuum Cleaner Specifications (Values shown below are minimum recommended) Circular Saw - Flat and Corrugated Sheet Cutting Vacuum (lift): 59" V/.G. (water gage) Airflow: 175 SCFM (standard cubic feet per minute) Filtration System: Multi-stage, designed for use with asbestos-containing dusts. Dust Collection: Unit must be provided with, or capable of using, a disposable plastic or paper bag for collecting and removing dust. Sabre Saw and Drill Vacuum (lift): Airflow: Filtration System: Dust Collection: 5 9" IV. G. 65 SCFM See Above See Above >v CAPCO JEN 0001481 65b Housekeeping and Waste Disposal Housekeeping is an essential part of any safe construction operation. It is even more essential when airborne dust created by the lack of good housekeeping has the potential for harm to employees and others. EQUIPMENT: All external surfaces of equipment should be maintained free of dust accumulations that might, if dispersed, create asbestos fiber concentrations above permissible exposure limits. WASTE DISPOSAL: Asbestos-cement dust chips and cuttings from the field operations described in this booklet must be collected in a manner that will not contribute airborne asbestos dust to the atmosphere. Loose materiel s>.ovl.Ic. never be dry swept. When vacuum equipment is available, it should be used. Water or other dust suppressants should be apDlied in those circumstances where sweeping is unavoidable. DO MOT BLOW WASTE MATERIAL WITH COMPRESSED AIR. No visible emissions to the atmosphere are permitted from the collection, processing, packaging, transporting or deposition of any asbestos-containing material. 'Wastes must be collected and disposed in accordance with the requirements of the U.S. Environmental Protection Agency. For full text of E?A waste disposal requirements (iO CFR, Chapter Part 61) refer to Appendix C. 9 rt apho JEN 0001482 66b Eauioment Suppliers Tools shown in this pamphlet are available front: Wheeler-Pilot International P. 0. Box 5128 20433 Earl Street Torrance, CA 90510 C213) 371-1253 Xilfisk of America, Inc. 201 King Manor Drive King of Prussia, PA 19406 (215) 277-3900 Suppliers claiming to have vacuum cleaning units suitable for use with asbestos-containing dusts are: American Cleaning Equipment Corp., Ill South Route 53, Addison, IL 60101 3eamco, Inc., 707 Stierlin Road, Mountain View, CA S4Q4Q Breuer Electric Manufacturing Co., 5100 No. Ravenswood Ave., Chicago, IL 60640 Hild Floor Machine Co., Inc., 5539 West Lake St,,. Chicago, IL 60644 Kari-Vac Inc., 4360 VI. 127th St., Alsip, IL 5G633 Nilfisk of America, 201 King Manor Drive, King of Prussia, PA 19466 Puliman/Holt Products, 10702 46th Street, Tampa, FL 35617 Vac-U-Max, 227 Main St., Belleville, N'J 07109 Wheeler-Pilot International, 20433 Earl Street, Torrance, CA 90510 Note: It is recognited that equipment suppliers other than those listed above may be available. ^Mention of any company is not to be considered an endorsement by AIA/NA. CAPCO JEN 0001483 - 67b - c.-r.'.;rx.vc xsstpsctxcsz WKZZZSP.-PXZOT FZAT Sh'ZZT CIP.CUZAP. SAW ______ XCUZZ 83 3__________________ rcj cpzpatios. ) : CUTS VACUUS CZZASZPS CZPTXFXZD PS CDZSUUKFACCSPSP FCR VSZ WITS ASPZSTOS DUST USD SA.VXSG A CASA2IZXTY OF 175 CFM APS TO PZ i7SZD WITZ THIS TOOL. A vacuus zcsz cz scr zzss that: 2 xscs diasztzp asd pot ::cpz tsas sz-r, xs to 3Z cszo zzc.izs.: tzz irzz cosszctcp. asd vacuus task, tzz VACUU.-f&suFAcrupsp.'s cpzpatxsg xsstpuctxcss asst sz psad asd uszzpstcod pzfops cpzpatxcs . 3. XSSPZCT AZZ SYSTZX ZZZSZSTS FOP. CPACXS , PUASUPZS OP. OPZilXSGS, i.e. ZCCD , VACUUS host asd co:::;zctcfs. pzpaxp. op. fs.-za.cz aa.s pauztu xtz:: op. paps. 4. co::::zcx x:-:z vaccs-i hosts as show:/, xssupssg azz A.::0 CZASPS APS XXSHX. 5. ftp.:: cs vaccus a:.d c:-:zc:< fop ass stcpaozs op. asp zzafs x:: xhz vaccs-i zx::z op. hcc: ASD XSSUPS AXXCUATZ AXP. PZCW XS TZZ OPTS APSA OF TPS SAX. n 6. XT AZS LZAXS CP. STOPASX3 APS ZCCA.TZD, C3ASGZ CP. PZPAXP. FASXT'S XTSi. R.U/TZSX. 7. ADJUST ZCWZP XVACSATOP SO CPAS TSZ rWTJrS-WS SZZP.T CONTACTS TPS S.'SZPSXXZ CF TZZ SZZZT TO 3Z COT. 8. COSSZCT CXPCSZAP. SAW TO ZZZCTPXCAZ CUTZZT ASD FZZD XSZO WORX. TPZPS SHOCZD ZZ ' VXP.TSAZZr SO VXSXZZZ DOST OP. DZPPX3. IF ZSCZSS DUST XS VXSX3ZZ, W) CP.lCK VACUCi CZZASZP. BAG FOP. CYZPSCAS-PZP iS.ASA.CTSP.ZP' S XS3TP.UCTX0S3, (b) CPZCS LXZSS FOP. AXP. ZZASS ASD (Cl CPZCX PF.OPZP. ASJUSSiZST CF ZCWZP. ZVACUATOP. 5. AVOID USISO ZXCZ33-- FOP.CZ FZZDXSG SAW X:~0 WOPS. stop asd czzc:< tool fop pp.opzp. opzpatxcs. XT GT.TAX TCP.CX XS RSQSXT.XD t 3ZASZ PSP ZA.CSiZST (XS AZDXTXOS TO DZA.CX DZCXZP. GFZPATISG XSSTP.CCTXCSS) 1. CXSCCSSZCT CHIT FPSP ZZZCTPXCAZ CUTZZT. 2. ZCWZP OP. PSP-CVZ ZCWZP. ZV'.CUATZSG HCCD. 3. PXP.O'AZ (4) scpsys ASD COVZP TO ZSPOSZ 3ZASZ. 4. GPAS? TZZ ZXPCSZD ZCWZP PCPSXCS OF TZZ PZAZZ ASD PZSCVZ HUP SCPSit WITH WP.ZSCH. 5. PZAZZ CAS PZ PZSCTZD OP PSPZACZD (CACTXOS: SXZXCCi7 CAPSXDZ PLASZZ COST PZ SCVSTZD \ WITS APPP.OPPXATZ 3XDZ CUT, TSZ 2ZAZZS APS S-SSZD ACCOPDXSGZY) . r.Avr.n JEN 0001484 68b cpzpatzxg ixstructioxs wszzlzr-pzlct ccrpugauzd szzzz circular saw X03ZL 353________________________ 70 OPZPAZIQH. .r 2 CirLZ VACUUH CZZAXZPS CZRTSPIZO 37 ZihTO'AXGPACZURZR TCP. USZ HITS AS3ZS7CS OUST 7213 BA7ZXG A CPOASILCTI 03 175 CSX PSA. APO 70 3Z USZ3 WITH THIS 7CCL. A VACUUH BOSS OF XC7 LZSS 73721 2 IXC3 3IA2ZTZR 7213 XCT BOPS 73721 10 PZZ7 LOBS ZS TO 3Z USZ3 3ZTWZZX T3Z W'Z CCXXZCZOP. 7213 VACUUH 7AXX. 73Z VACSUH l-LAXUPACTUPOR'5 cpzpatzxg ixstp.uczicxs must zz poad axd uxdzpszccd szscpo cpzpaoscx . z. ixspzcr all systzx zloxzxts top cpacxs, puxtupos or cpzxixgs, i.s., zoos, vacuux 3CSZ 720 CCHXZCZCPS. POPTOP. CP. FOPLACZ ATI FAULTY ZZZI1 OR PART. 4. CCXXZC7 73Z VATJUX 3CSZ3 70 S3CWX, IXSUPOXG POL CCXXZC7ICXS 720 CLASPS TOO 77037. 5. 7UP21 0.7 V7.CT2X 720 C3ZCX POP. 72PI S7CPAGZ3 OP. AIR LZA.-S IX 73Z VAC-JO! LZOZ CR FOOD 720 IXSURZ rOZQCP.CZ POP. PLOW I'J 73Z CFZ'2 PPOA CP 73Z SPI7. n 6. IT ACPI LZAXS OR S7CPAGZS APO LCCP.7ZD, C3AXGZ CP. RZPAIR TACL77 77SX. 7. ADJUST LCWSR ZVACCP.70R SO THAT 73Z RUXHZRS OH 73Z IXSIDE CT 73Z SKZRI FCXCSRS AP.Z f APPROXZ'.iP.ZZLZ 1/4 SXC3 PRC! 7SZ 3CT7C1! CP 7HZ S3ZZT. 8. C0XXZC7. CCRCCZPO SPJf 70 ZZZC7POCAL CC7LZT 720 PZZ3 IXZC WOPJ73ZP.Z SHOULD 2Z r VIRTUALLY .70 VZSZZLZ DUST CR 3Z3POS. IP ZXCZSS 3US7 IS VISI3LZ, (a) C3ZCX VACUUH CLZAXZP. SAG POP. CVZPLCA3-PZP. H721UTAC7UPOP.' S IXSTRUCTIOXS, (3} CSSCX LI.'.'ZS POP. 70?. LZAXS AX3 (C) C3ICX PP.CPZR ADT2S7HZXT OP LCWSR rPACJAIC?.. 5. AVOID USICG ZXCZSST/Z TCP.CZ TZZ3TJG SAW 1X70 WOPS. IT GRZAI TCRCZ IS POQUIPOD, STOP 7213 C3ZCX TOOL TOR PRQPZR 0PZRA7ZCX. 3LADZ RIPLACZXZX7 (IX A3SIII0X 70 3LACX S 3ZCTOP. CPZRA7IXG IXS7P.UC7I0XS) 1. DISC0XXZC7 IT!17 FF.CX ZZZC7POCAZ 0U7LZ7. 2. LCWZR CR RZZiCTZ LCWZR T/7.CU7CIXG 3CC3. 2. FSXCVZ (8) SCPOWS AXD COVZP. 70 ZXFCSZ 3LTOZ. ' 4. CPAS? 73Z ZXPCSZD LCWZR P0R7ZCX OP 7HZ 3LA0Z 7213 P.ZXCVZ SU3 SCPOW WZ73 WP.ZXC3. 5. 3ZA3Z CAW SZ POXCVZ3 CR P.ZPLACZD (CAV7ZCX: SIZICCX CAP.ZZ3Z 3LASTS XUS7 ZS X0UXZZ3 WITH APPP.CPPOAZZ SIZZ CUT, 73Z 3LAZZ5 APO XAPJOD ACCORSIXGLZ) CAPCO JEN 0001485 69b cpzkatixg ixstructioxs ILSEELER-PILOT SA2ZP. SAWMODEL 873__________ 73 Here Cl O 10 Ft. Ler.gth Max. Fzoa Adaptor to 7asues TasJc Ecse Clarro 1. TEE mi XCCEL 873 CSSS CXI 3LACK DECKER MODEL 3155 SA3EP. (0X0) SAX. SLACK S DECKER CPERATIXG IXSTRUCTIOXS FOR MODEL 3155 XUS7 31 READ ADD UIWERSTCOD PRIOR to operatixo txis exit. 2. CXZY VACUUM CLEAXERS CERTIFITED SY TEE XAWUFACTUPIP. FOP.-USE WITE ASSESTOS DUST ACID HAVZXG A CAPABILITY CF 65 CF!1 XIX. ARE TO 3Z USED WITH TXIS TOOL. A VACUUX EOSZ OF SOT LESS TEAM lh IXCS DIAMETER AXD .707 XCP.I TEAX 10 FEET ZCSG IS TO 3E USED. TEE VACUUX I-LWFACZURZR'S CRERAZIXG IXSZRCCTIOXS .'POST 3E READ AXD UXDERSTCCD 3EFCRE OPERATIC::. 3. IXSPECT ALL SYSTEX EZEXEXTS FOR CRACKS, PUXTIP.ES OR OFEXIXGS, i.e. HOOD, VACUUX HOSE AXD CCXXECTOPS. REPAIR OR REPLACE AXY FAULTY HEX. ASSEX3LE VACUUX XCSE .AS SECXX ABO'/E, IXSURIXG ALL CCXXECTICXS AXD CLAXPS ARE TIC3T. 5. TOPS! OX VACUUX AXD CSECX FOR AXY SEEPAGES OR AIR LEAKS IX TEE VACUUX LIXE OR ROOD AXD ISSUES ADEQUATE AIR FLOW IX TEE CPEX AREA CF TEE SAX. 6. IF Air/ LEAKS CR STOPACES ARE LOCATED, CEAi:CE OR REPAIR FAULTY ITEM. 7. CCXXECT SA3ER SAW TO ELECTRICAL OUTLET AO:D FEED IXTO WORK. TEERE SHOULD 3E XO VISIBLE DUST CP. DEBRIS. IF SXCES5 DUST IS VISI3LI, (a) CEECX VACUUX CLEAXER SAG FOR OVERLCAD-PEP. XAJFUEACUURER ' S IXSTP.UCTIOXS, (b) CHECK LIKES FCR AIR LEAKS.' TO IXSTALL OR PE.YCVE SLADE (IX ADDITICX TO SLACK S DECKER OPERATIXC IXSTRUCTIOXS)' 1. DISCCXXZCT C21ZE FP.C! ELECTRICAL OUTLET. I. REXOVE TZE TOO SCPSFXS WHICH RSTAIX TEE SHIELD. 3. PULL SHIELD STRAIGHT DCWX (SHIELD FITS FTRXLY IX PCSTTEOX. A SOFT TAP MAY 31 SECESSARY) 4. REXOVE SLADE (SEE SLACK DECKER CPERATIXG IXSTF.UCTZCXS) 5. REASSEXRLS. OAPCO JEN 0001486 70b Recommended Work Practice Procedures for Drilling Mud Additives fiAPCO JEN 0001487 71b During the early 1970's, concern was raised within the drilling industry regarding the health and safety of employees handling asbestos in drilling muds. In order to reduce the concentration of airborne asbestos fibers at the rig site, Drilling Specialties Company, the producer of these drilling mud additives, reformulated their drilling mud grade asbestos into a water-soluble flake. Subsequent field tests were con ducted to confirm the reduction in the airborne concentrations of asbestos. The results of these tests are present in Tables X-XIV below. *\ fiAPCO JEN 0001488 72b TABLE X CONCENTRATIONS OF ASBESTIFORM FIBERS IN THE WORK ENVIRONMENT DRILLING MUD ADDITIVES Phillips Petroleum Company - Peter "2", No. 2 VIell Panola County, Texas II & S Drilling Company Saapla No. X 2 3 4 5 6 7 Location and Description Breathing Zone, (3Z) Floor Han No. X 3Z, Ho toman, as conducts nomal duties during' shifts 3Z, Derrick. Han, as. conducts ncmal duties during shift. 22 bags Flosal added during shift 3Z, Floor Han No. 2, as conducts nomal duties during shift 2Z, Driller, as conducts nomal duties during shift Area Sasple collected during shift Area Sasple collected during shift _____ Sampling Tine_______ Date Hour Duration _____________Cain) Concentration (Fibers/cc) 1/3/79 1500 435 <0.1 1/3/79 1500 435 <0.1 1/3/79 1500 435 <0.1 1/3/79 15C0 435 <0.1 1/3/79 1500 1/3/79 1511 1/3/79 1515 435 424 420 '<0.1 <0.1 <C.l CAPCO JEN 0001489 H 11 73b TABLE XI CONCENTRATIONS OF ASBESTIFORM FIBERS IN THE WORK ENVIRONMENT DURING THE ADDITION OF DRILLING MUD ADDITIVES Phillips Petroleum Company - Black "A" No. 1 Well Canadian County, Oklahoma (. 1 -- -------------------------------------- ~ Sample.............. Location 2nd - No-............ Description Samling Tine Date -- Hour- Duration (sin) . Coocentrat (Fibers/c u i \ Ir 2 r~ 3r* L4 ^ [, -- i: 32, Driller, as performs nm--duties 32, Derricknan, as perfoms aomal duties 32, Floeman, as perfoms nomal duties 1/15/79 . 1/15/79 1/15/79 0805 480 0806 ~ 479 A 0808' * Aao 3Z, Derrick-jar., during addi-- cion of 3, 50-pound hags FlosalPand 12, 50-pound hags Kilgcl 1/15/79 0945 . . -- * . * * 1,2 *--filter-Loaded with unknown substance which precluded the recuired analysis. < i 1^ CAPCO JEN 0001490 74b TABLE XII CONCENTRATION OF AS3ESTIF0RM FIBERS IN IKE WORK ENVIRONMENT Norwegian North Sea - Edda Platform -Phillips Petroleum Company - Eldfisk 2/7, No. A-21 Well Loffland Bros. North Sea., Inc.* Sample No. 1 2 3. 4 S 6 Location and Description Sanding Time Date Hour Duration (min) Breathing Zone (BZ} Derrick Man as added 12, 50-pound sacks Flosal to nixing hopper NW side of rig floor about BZ height BZ, Service Engineer, as performs normal duties throughout shift BZ, Derrick Man as performs normal duties during shift including addition of Flos.al as indicated in No. 1 above BZ, Driller as performs normal duties Area Sample, near nixing hopper 2/11/79 1505 .2/11/79 2/11/79 1315 1305 2/11/79 1255 2/11/79 1255 2/11/79 . ' 1515 10 433 450 465 570 435 Concentration (Fibers/cc) .. 0.2 <0.1 <0.1 <0.1 * * * Filter loaded with unknovn substance which precluded the required analysis. CiAPCO JEN 0001491 75b TABLE' XXII COMCES7RATI03 0? AS3ESTT7QRM FT3ERS IK THE WORK ZS7TR0SHE3T EU3I36 i OTFSHORE DRILL SSI? OFERAIIOS Phi'llina Petroleun Conoairy - Mississippi. Canvon Block Mo. 282 ----------- --------- - Weil Ho. 1 - 005-3819 Louisiana Gulf Coast Sanple So. Location and Description Date Sanolina Tin o Hour Duration (nin) Concentration (Fibers/cc) MUD ENGIHEER . i az, as perioms tonal duties primarily in sd pic reon r- 2 Sane as So. 1 above 4/21/79 4/21/79 0445 0703 '_ 3 * Sane as Mo. 1 above 4/21/79 0950 TTyg--gEIGnxZa AViRAGo 138 167 137 *' 442 <0.1 <0.1 <0.1 <0.1 ' ' DERRICE MAS A 32, as perioms tonal duties 4/21/79 0500 5. 6 7 r Sane as So. 4 above 4/21/79 0705 Sane as So. 4 above 4/21/79 0920 32, as perioms Sonal duties, 4/21/79 also began addition of Flosal 1105 <4,50-pound sacks added 1015 to 1200 hours) T ( 1 r>-JJ AVi2tAVrC 125 135 105 81 311 <0.1 * <0.1 <0.1 <.0-.l MOD ROOM 8 Area sanple, near nud additive hopper 4/21/79 0505 9 10 11 ( Sane as So. 8 above 4/21/79 0707 Sana as So. 8 above 4/21/79 0922 Sanb as So. 8 above 4/21/79 1103 TIME-WEIGHTED AVERAGE 7 V? 135 106 76 439 <0.1 <0.1 <0.1 <0.1 <0.1 ___ 1 * Filter loaded with unknown substance which precluded the required analysis. r'.APOO JEN 0001492 76b ( TABLE XIII (Continued) Ssrple , Ho. Location and. Description Sasrolirg Tina Date Eour Duration ___________________________ (ain) Concentration (Fibers/cc) DRILLER jl2 BZ, as perform norm duties 4/21/79 0515 -3 Sane as Ho. 12 above < -' .4 Sane as Ho. 12 above r. r ASSISTANT DRILLER. 15 BZ, as perform nomal r duties . 4/21/79 . 0720 4/21/79 0930 TIME-WEIGHTED AVERAGE 4/21/79 0519 *5 ni7 Sane as Ho. 15 above Sane as Ho. 13 above 4/21/79 0722 4/21/79 0929 TIME-WEIGHTED AVERAGE 125 130 175 430 ' 123 127 17a 428 OA *-a <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0-1 I * ( 4 ''ADno jen 0001493 -o - 77b - TABLE XIV CONCENTRATIONS OF ASBESTIFORM FIBERS IN THE WORK ENVIRONMENT DRILLING MUD ADDITIVES Phillips Petroleum Company Burnhoff C No. 1 Canadian County, Oklahoma Sanple No. Location, and Description Date Sanolinz Tine Hour Duration Concentration (ribers/cc) DOGHOOdS 1 Area. Sanple, located across doghouse fron door near driller's console. n -2 Sane as No. 1 above 5 Sane as No. 1 above 5/29/79 . 0727 5/29/79 . 0925 5/29/79 ilia 4 r Sane as No. 1 above -. 5/29/79 1334. TZHZ-nciGETZI) J-..VERAGE MOD EOUSZ 5 .V Area Sanole, located aoout 1 foot above cone-jet hopper 5/29/79 0729 apron, even virh outside edge. P. 6 Sane as No. 5 above 5/29/79 0928 /v 7 Sane as No. 5 above 5/29/79 1141 S Sane as No. 5 above 5/29/79 1340 T Hit--n oxlrtllii) AVERAGE DE33ICS MAN ' 9 3Z, as perfoms nomal duties. 5/29/79 ' 0747 3egan addition of bentonite. . 10 - 32, continued bentonite addi- ' 5/29/79 tion and 3 sx Tlosal 0947 11 -- 12 *' 22, 1 sk rlosal added 5/29/79 1143 32, as perfoms nomal duties 5/29/79 1342 THE AVERAGE 118 133 116 . 70 437 119 133 93 70 415 120 116 119 69 424 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <Q ,1 <0.1 <0,1 <0.1 <0.1 <0.1 <0.1 I M $ rtAPCO JEN 0001494 * - 78b - TA3L2 XIV CContinued) /Sasole So. Location, and Description Date Sana line Tire Hour Duration (nin) Concentration (Fibers/cc) ( XCCRMAS 13 BZ, as perfoms coral duties 5/29/79 < 14 Sane as So. 13 above 5/29/79 o in 0752 15 ( 15 r < Sane as Ho* 13 above Sage as So. 13 above 5/29/79 1145 5/29/79 1344 'IIKE-nEIGcTID AVERAGE DRILL12. r i 17 3Z, as perfoms nomal duties' 5/29/79 0754 13 Sane as So. 17 above 5/29/79 0910 < 13 p 20 Sage as So. 17 above Sage as So. 17 above rI 5/29/79 1148 5/29/79 1335 TUfS-wcIGHIZD AVZ2AGZ 122 111 119 64 416 <0.1 . <0.1 <0.1 <0.1 _<0.1 116' ' <0.1 MALFOSCTICN -- SO SAMPLE 108 <0.1 72 <0.1 296 <0.1 'i r i hapco JEN 0001495 79 The values presented in these tables demonstrate that all sampling results are well below the permissible exposure limit specified in the current asbestos regulations. Based on these results, the following recommended work practices for a drilling mud additive (DMA) containing asbestos. When used in accordance with these recommendations, the drilling mud additives can be safely handled by personnel at the rig site. riAPno JEN 0001496 80b - .-PRODUCTS AND OPERATIONS DMA is furnished in flake fora. ' Operations to which these work practices apply include: Shipping, receiving, handling, warehousing, and storage. Additions of DMA to the mud.. .. Handling of empty sacks. O Disposing of empty sacks. Disposing of said. *' SHIPPING. PFCHIVING. HANDLING, WAREHOUSING, AND STORAGE ` DMA is furnished in loose or palletized sacks. (With palletized DMA, the pallets are sometines shrink-wrapped.) The sealed, unopened sacks should be * handled by noma! warehouse practices. Precautions cost be taken if a sack is broken, corn or punctured.. The sack ^ should be sealed with heavy duty tape or placed in a slip-over sack (over-sized, open-mouthed bag) to prevent spillage. The slip-over sack should be securely sealed, preferably by a twist wire. Any spillage should be cleaned up with a r~ vacuus sweeper equipped with a disposable bag. Unless additional protection is required under applicable federal or other regulations, a certified, reusable single-use air-purifying respirator should be worn by the person cleaning uo. r- DO NOT BLOW MATERIAL WITH COMPRESSZD AIR, NOR DRT-SWEZP. The material in broken or damaged sacks should be used first. In storing DMA, it is recommended that it be stacked no more than 10 sacks high. r ADDITIONS OP DMA TO THE MUD DMA should be added, to the mud in the sane aann'er as other dry mud additives. The DMA should be added directly to the srud system, preferably by emptying the sack at a uniform rate into the hopper of a cone-type jet mixer (eductor system. Figure 1). Other systems in use are also suitable for the addition of DMA, such as an eductor with suction hose attached to withdraw the DMA directly from the sack, or from a drum into which several sacks have been emptied (Figure 2). Care should be used in pouring the DliA into another container to reduce the amount of "fines" generated when air is displaced from the receiving hopper or drum. In adding DMA to the mud, it is a recommended practice to position oneself sc that any air currents present are moving from the individual's back toward the receiving container, rather than blowing into the face. A light weight streamer or "air sock" above the hopper may be used to determine wind direction (Figure 3) ^-Apno JEN 0001497 MUD DISCHARGE ftAPco JEN 0001498 83b * CAPCO JEN 0001499 STREAMER FIG. 3 STREAMER ABOVE HOPPER TO SHOW DIRECTION OF AIR FLOW 84b HANDLING 0? EMPTY SACKS After a sack is emptied, it should be discarded in accordance with current Federal Regulations. Normally, sacks of all types should be carried away for disposal as soon as tine permits. - DISPOSING OF EMPTY SACKS When an adequate precipitator is attached to the incinerator, onshore burial or incineration is the preferred method of disposing of enpty DMA sacks from offshore sices. DO NOT BOSS DMA, SACKS WITHOUT A PRHCIHIIAIOR. The empty sacks should be accumulated in sealed impermeable bags until a sufficient number is on hand to require burning or burial. It is preferable to bury empty DMA sacks onshore. DMA sacks are biodegradable. An incinerator with an adequate precipitator can be used. DO NOT BURN DMA SACKS WITHOUT A ?RSCUITATOR.. DISPOSING OF MUD When a well is finished, there is usually little or no DMA. left in the cud. Any accepted method of storing the mud for reuse, or disposing of it, can be used. * t\ CAPCO JEN 0001500