Document 3QqGR1QmENOx9vmNmj6pLk9JO

FILE NAME: Chrysler (CHR) DATE: 1976 Apr 2 DOC#: CHR111 DOCUMENT DESCRIPTION: Internal Report - Industrial Hygiene Reply to Asbestos Survey with Cover Memo  *(*4 3* a4:l***r*d#lt, --..P e c orine l_Marijig<r__ D. p S U t u t r I n d u s t r i! HvaUne *m t U*A.W ASSESTOS SURVEV rnter com pany worresponatiu; * >* c>m :** - TM---- 3 Apri i 2, \ 5t6____________ _ .... * ; wi * Stanping & Assemfal y " ~; . Trento^ chermes l ***<'<*et *51*02*00 " "Tt\ <-** Eraploy* A Ci<cy*ltf Ind t . jU la t. . Ce n c t r __ M7Q1*l? Attaehtd fot your rvlv 1$ cht uJEs rr i tRtyfto lapide to eh U^Txwafc'UtCfctftlcai Pl*tt Aafcto 3unry. f ha Attachmane cc: F. A* 8urnct C* 0* Btnson E. R* Lombari N. McCaltua W. H* O*Brian C. A. S * tta la l r L rv-- 0* ? C U x ltr Industri! Hy|lnlst chrysl&i M iasa INDUSTRIAL HYCISNE REPLY TO THE LAW TRENTON CHEMICAL PLANT - ASBESTOS SURVEY C ENERA L A. Posting OSHA Rules and Regulations do not require posting in art where airborne asbestos concentration* *re onft.*i*.*xce<s of the maximum allowable llmj*. (COramly 3 U bert/cc, July l f 1976/* 2 fibers/eeF 1 t posti*$ were required, the slgw%fMifleetlo* required by OSHA would be as follows; Asbestos Oust Hazard Avoid Breathing Ouse Wear Assigned Protective Equipment Do Not Remain In Area Unless Your Work Requires I t Breatning Asbestos Oust May Be Hazardous To Your Health v ' J 00 In addition, we believe that the i000SSH 9snim ti'peetiCg of areas which have low airtorne asbestos fiber conccnerstlons from the jjectlvenV 3 of OSHA required posting dMMMMrgKtere the airborne coacantretlMts are, In fact, 4Te*e6!Sttt**ttovabfcr limit* S* Containers In d u strial Hygiene believes chet lfe*fc*ng dMM4ftour||piaMxrtqu*ca* for i ib iitM centainlnf materials hem* mm, bam a ilftsbpw a bonding agent, coating# b in d e r or ocher material which w ill prevent the ralease of an excessive airborne concentration of asbestos fibers (i*c*,*tn excess of the maximum allowable limit)* C* Ventilacin indicators In d u strial Hygltne agrees th at, "wfcere feeatlWh* chare should ba an ummrWck to prevent the operation of equlpmew*-srtefoerventtteiVn." However, in relation to v isib le ventilation indicators, we ballave th a t while i t is not d iffic u lt for an operator to determine whether en exhaust system is in operation, i t may be very d iffic u lt for the operator to determine whether or not the system Is "performing adequately*" Performance evaluations should be the reepensiWllfy of the approprete engineering peTsonndt, who have the required technical axperclse* D. Housekaaping In d u strial Hygltne agrees that mealcslouhousekaepday standards are necessary *- order to prevent accumutationa of aabeatas fiber?which could crtace excessive airborne concentrations upon th eir dispersion* However, we believe that ja n ito ria l manpower and scheduling decisions are* the responsibility of the plant managamaiyi* CHRYBU3R W 2 5 4 - 2- &* Cleaning Methods while OSHA Rules and Regulations state that wet methods snail he used only, "insofar as practicable" Cor the control oi airborne asbestos concentrations, the Corporate Asbestos Review Guide states th at, cnly vacuum cleaning method* end wee sweeping shall be used to co llect asbestos fibers* F. Work Clothing Section lbl0*93a (d)<3) of the Federal Register stipulates chat, "tne employer shall provide, and require the use of special cloth ing, such as coveralls or similar whole body c l o t h i n g , . . . . . . , . . , . for any employee exposed to airborne concentrations of asbestos fibers which exceed the ceiling lev*l>" <10 U ber^/cc). Tfcatamc* stringent Corporate standard provides that protective clothing must be provided and wont byJ i l l epioyees exposed tw concentre* tions of asbestos fib ers whiefet exceed the FermisslblerExposure Level, (currently 5 flbers/cct)* In addition, the,Corporation provides disposable eprotge to those employees who'work in are where tn eir personal clothing may come in contact with loose asbestos dust* I t is therefor* evident that Chrysler Chemical has achieved more than simple compliance with the OSHA Regulation, and we believe that the plant has, in fact, provided protective garments for those employees whose personal clothing may tend to become contaminated with asbestos fibers* 0* Monitoring Observations H istorically the In d u strial Hygiene Department has attempted to notify the local Union Health and Safety Representative of our survey intentions upon our entry into the plant* We have a^ objection to being accompanied by local unto* safety represent* ative during regularly schfduled_4.fb*stos survey*, but i t should be noted that the Health asid Safety Memorandum of Understanding * provides thee the KeaUh end Safety representative w ill be excused from his job without loss of pay, only on the following occasions: 1) to accompany Governmental Health and Safety inspectors 2) to accompany International Union Health and Safety professionals on plant tours and Corporate Health and Safety professionals on Union requested surveys The Industrial Hygiene Department has noc provided the local union safety representative with a copy of an individual employee's notif* lcacion of over*exposur* to asbestos dust, because there is no agree* ment to th is effect mentioned in the Memorandum of Understanding. In regard to the wording of the employee over-exposure notification le tte r , we do noc object to pointing out in the body of the le tte r th at his exposure exceeded allowable lim its, but wt do object to providing the employ* with the numerical resu lt of the air sampla an aly sis. Wa believe that the evaluation of a ir sampling results should be the responsibility of a professional in d u strial hygienist, who has the knowledge and experience required to put th is type of information in tht correct perspective. chryslm ****** H* Receiving of Asbestos Shipments Industrial Hygiene agrees with Dr. H irer's recommendation* regard mg the receiving of asbestos shipments. FRICTION PRODUCTS BUILDING A. Weigh-Up Station QSHA regulations require that asbestos waste must be disposed et in sealed impermeable bags wnen disposal may produce "tn any reasonably foreseeable usefMan airborne asbestos fiber concentra tion which is in excess of the allowable lim it. In legtrd to t ! e above requir-ment, Industrial Hygiene feels tnac asbestos waste .hould be disposed of in impermeable bags rather tnan by attempting t-> control airborne Itvels by in stallin g local exhaust ventilation for the waste containers. h relation to point 2. see our ventilation indieotnr comments listed under I* C* We have no objection to providing covers for transport carts, but i t should be noted that such covers would provide only marginal effectiveness because they would have to be removed prior to skip hoist loading. 8* Lodige Mixers In d u strial Hygiene agrees with Dr* M irer's housekeeping and main* tenanee recommendations for the Lodige mezzanine* However, we do take exception to point #2* Air sample resu lts have shown that the dust which is seen to escape from the skip hoist when the loading c a rt is turnad upside down, is composed mainly of non asbestos particulate* we believe at chis tima that the use of additional engineering controls to prevent airborne dust at the Lodige skip h oist, would not prove to be a cost effective control measure* C* Blpel Press In d u strial Hygiene believes that much of the recent increase in employee exposure to airborne asbestos dust at the Bipel work statio n s is due to haphazard handling of the loose disc brake pad materiel* I f administrative controls cannot reduce the magnitude of employee exposure tu asbestos dust et the Bipel work stations, additional engineering controls w ill have to be evaluated* A problem, which should be noted, is that the in stallatio n of high capture velocity local exhaust ventilation at the Bioel work statio n s could resu lt in underweight pads, because of the related loss of the loose disc brake pad material through the exhaust system* In regard to protective clothing, note our comments listed in Section I F. D. O.E.M. Grinders We heve no objection to Or. H irer's comments regarding interlocks CHRYSLER setatw and to th* determination of the operator's noise exposure but we feet th at his recommendation that the plant engineering function report to the health and safety representative is plainly beyond the scope of the memorandum of understanding# E* Sew Are* F* Hanroermltl Mezzanine C* Air Cleaning Equipment In d u strial Hygiene has no objection to Dr* Mirer's torments as listed tn Sections 11* * F and G* of his report* XXX CHEMICAL P U N T A* Downstairs Weigh-Up Station As regards posting please refer to our comments as listed in Section X A* Industrial Hygiene has no objection to obtaining an a ir sample at the downstairs weigh-up station* th is operation involves the velgh-up of less than one bag quantities of asbestos on an approximately once per week basis* 8* Storage Area See our reply as listed in X* H* C* Mezzanine Weigh-Up Station We have no objection to Dr* Mirer1 comments on housekeeping. See Section I* A., for our posting recommendations* D* Mixers We do not concur with Dr* Mirer1s posting recommendation (see X* A .). In d u strial Hygltna ha* no objection to the housekeeping and maintenance recommendations* D. P. Glazier Industrial Hygienist CHRYSU o1287