Document 3eBjYq2Yjpmonmpb88VOmxEwE

15 1 * DEPARTMENT OF THE NAVY NAVAL SHIP ENClHCEftlNC CENTER. PHILADELPHIA DIVISION PHILADELPHIA, PA. IS! I* . m *m.v '* . * *.*764:UA:lal 9390(FA-287) .. . '*Ser 1584 .. ' ' " 24 SEP t369 r> From To: * Subjs Officer in Charge, Haval Ship Engineering Ccuter, Philadelphia Division Commandex', Naval Ship Engineering Center * * Survey of Hazards of Ashestoss*final report of ____ NAVSECPHILADXV Project FA-287 -- ~------- * * -Jtof{ (a) KAVSEC Itr 6101C:EC:an, 9390, Ser 278 of 7 Apr 1989 * * (b) KA\5CPHXUPXV Itr 6?:UA:lal, 9390{FA-287), Ser 688 /- ..of 24 Apr 1969 . _;.-- * () KmECPKXLmV Itr 6764^4aal, 9390{FA-287), Ser 1189 of 30 Jul 1969 (d) NAV5ECPHXUDXY Itr 6764:KAjlalV 9390(FA-287), Ser 1273 of 6 Aug 1969 ** (e) KAIS^PHXLADIT Itr 6764 &A:lal, 9390(FA-287), Ser 1300 of 13 Aug 1969 .(f) Mi\BECPHIXADIY Itr 6764:154:jy, 9390(FA-237), Ser 1417 .. of 26 Aug 1969 . / mmmm m , ---- > BB (g) HAVSRIT5 Tech t&nual Chapter 9390, Thermal Insulation of Sep V. (h) UTL-SID-769C (SKIPS) of 15 Nov 1967, Thermal Insulating Requirements for Machinery and Piping 1b Bacfcirround *. -- v`,a. The enormous rise in the production and industrial uses of ' * asbestos during the feast 60 years has resulted In a markedly widened ` exposure to asbestos dust for a .greatly increased number and variety . ..of workers. Sons of them, moreover, sustain aetidental.contacts either . * . when being employed in various capacities in operations where asbestos *. products arc jrocensed, used, or handled, or when working in plant areas in which an envlronaental pollution of the air with asbestos -- # exists. The hanaful effects of such, growing exposures-to.asbestosTdupiny tha past ftp oecaces are reflfected an an ingreased~nuaber of reports * * qfiJjM oeeurrenca Of asbestosis ana asbestos canter (mesothelioma) in . ` * a variety or asbestos worxers xroa a rtsmp hiihber of countries?"^' The principal worker groups exposea to respiratory contact with asbestos ----- -^--^'o-sgpAoygd.in-wie as&estos mining andadliing ^ndustries >-tn-the ---------grofluetton ana cogayrciai use of asbestos cement and piester. In tbs * production and application of asbestos for insulating purposes and' in WV-05251 * u 6764:m:lnl W9D(FA-2S7} Ser 1564 the and its samifacfrare into textile?. Ensuring adequate protection of asbestos workers against occupational health hazards related to respirator? and cutaneous contact is of paramount importance to Comment, industry, and the trotters themselves# - b, Since individual habits of vortecn play a large part in their ejuposure patterns, observations of their practices have been included in the survey. Most insulation -porkers are, mare that exposure to asbestos dustf even at loo concentrations, is nazarsous out \hey also Teel that `MioSiasardiTare unavoloaaiB ana gust be accoptea as pare Of * * ia oceopai;tan. Moreovert a recently published survey cooductecrty a naval shipyard aboard selected ships has revealed that, although dust respirators have been required during installation or risout of asbestos. 765'of the writers did not use y>em# in fact 5C& did not posses respire-- +m-1* >. it&s even thogfTthev rere~readily avaqaa^g at eghtrnirtooi: roore. This lack of worfccr discipline and the seriousness of the lung effects of asbestos could be the main deciding factors for considering the elimination of asbestos as a lagging material end as a cerent on piping, 3* ducts and boilers and thus reduce and eventually eradicate the reported incidence pf asbesiosis ranging up to 21? asoag shipyard insulation vorhers# e. One recent shoo and shin tiro study has revealed that loggers currently 25S pf their porting time wn asresys>containiiig SiTer'iiils. ihis survey also reported that the indivjdugduties of insulation workers required the f&Ueving tine aUotreat; ____________ (1) 10? of the laagers' tine involved prefabrication procedures such as the hand or porer cutting of molded pipe covering or blocks and their shaping to fit the Intended are* of application. (2) 40? of the tins*is spent in the application operation including fitting, hasnerisg into place, caning and/or attaching , insulation satcrials by wire or adhesive. * (l) 3CS of tine is spent, on the finishing operation in trhich 'insulating materials are ooated with cement, Xesin;'blth;#,r -- -- .petroleum-based sealers. . #s -- ..... "" " ' -- >-- > (4) XKTf of the tine is spent in tearing out old insulation prior ____M re-applieation.% J - * , W0{FA-2S7) #r 1584 (5) 5f of the time is Spent in blending varying combinations of eeraents is buckets, troughs or in utestatie siring machine*. * (6) General work, occupying 5J of the time, Aanprises cleaning up of old insulation, transporting material and sowing shipment. d. In an attempt to ioorove the insulation program of the Ifcvy, , Kftl'SZCPJSUMV, by reference {), was y -ted to participate in a surrey of the shipyards and the insulation sanuf* -turerr s that action can be taken to rdninite the health hazards to which insulation workers are exposed. Fulfilling the schedule proposed by reference (b), this activity has completed the suggested 6tudy of the practices of shipyards end shipyard Insulation workers. Findings of this study are presented herein. ' 49 2. Shipyard Survey . . .. a. in*AAT$f*A to the Uaval Shipyards resulted in 102S response, whereas those addressed to ccivate shin^trd^jfailed 'to elicit yeoaes rron nsrrngrt Kegs Shipbuilding and Drydock Co.^ tad jn^a^is Shrnbullding Co^ However, General pynanies, tockheed 'Shipbuilding and Bath Iron Works responded to our inquiry. Follwr~up personal visits were made to representative Navel and privets shipyards on the Sest and West Coasts and reports of visits to their installations have been suboitted to UAVSEC by references (c) through (f). Discussion meetings were held with cadical directors, industrial hygienists, safety managers, value analysis engineers end pipe-coveror shop foremen. In every instance. It was noted that shipyard personnel management is arare of mending the tg of asbestos insulating materials but does orRanizfltions have been instruaentai in securing sees" iwo>Spehts "but *'** in socuring^dirtv" orjhaaard" coney DoF" handling these materials. Shipyard safety bulletins to guide the practices of shop workers have been issued at every Haw installation, although not ell of workers abide by them. However, the workers do sutaitto semi-annual dhbSt x^rays; Tra interpretation of the x-ray plates should cot be considered lightly since variations in the technique of taking the fils nay result in disclosing a greater incidence of esbestosis than beretofpxVxealised. BtSSD should be consulted in this regard* '* * t  r- 3" 2>- 6764 :MA.'lei 9390(^281) Ser 15S4 b. Conversations with Industrial hygienists revealed that although tho methods of conducting particulate determinations are important, there t is no uniformity is the shipyards. It war also noted that the method rwoossended hr the American >{ygiene Association has not been updated * since 1942. this procedure is generally used by the shipyards, the areas of sampling, the method of Campling and the operation and material involved affect the total dust count reported. It was also expressed that the techniques of sampling, as veil os the method of counting The ysr~ ~ tides should be standardised for all shipyards, fatal dust_cpuats should be reported In lutaUlsnuta the, fiber count ...Bnd.-fibftr sian and, J.f possible --identifying these ftas The eider use of a contrast ptese microscope would enhance the identification of fibers and oaks the counting , procedure more meaningful# ^ .................. . . _ . o, The fabricating shops were surveyed and their facilities were evaluated. Generally, exhaust equipment ranged from excellent to fair due peinly'to varying ceiling heights. High ceilings favored the accumulation of overhead dust on rafters and beams. Those shops which hed wooden floors required repeated vacuum cleaning and vet sleeping. Cutting and sewing tables equipped with a water supply end local exhaust hoods were , ideal but, unfortunately, not all shops wore so equipped. The sawing operation was not always conducted under edequate ventilation. 6. A study of insulating materials used by the shipyards revealed vide range of materials. including asbestos, roek wool, -cork,. elastcccri c - foam, fibrous glass, cellular glass, calcium silicate, magnesia, dietoaeeous earth, cotton and cecentocs agents. The handling practices of these materials by the pipe coverer-insuletor varied considerably and in many .esses, the worker vbs his ova chief enemy. He failed, to veer eoveratts, . respirators, goggles, gloves and use protective skin creams and curtail smotita* habits li practice which is known to increase .the iadde*e of asbestoses jl vork aCtides were observed, one innovation Initiated et one of the shipyards wee the nixing of asbestos cement with rater under * cover of a closed polyethylene bag to eliminate dusting. All of the .JWKW** which use esosite asbestos blankets wet.them down and encloses. them in polyethylene bags prior to transportation to the application site and reopened then revet for use, them with . a fine water spray as they ere .......-- -....... - 1 - - being* &  * 6764:WAslX 9390{FA-2S?) Ser 1584 ** * . '. r cl Shipboard practices on the handling of esbestoc-coniftining materials occasionally shored failure to isolate sorting areas, improper ventilation, dusting due to emptying cement hags, fsilure to vet down insulation preliminary to ripout and disposal in polyethylene hags, and failure to vesr coveralls end properly equipped and approved respirators* * Dust counting on hoard ship during dry riperut operation of amosite revealed a total dust count as'high as 24 million parts per cubic foot (sppef), the present accepted maximum limit for eshsstoi dust is 2 mppef for an 8-hour. --*voridng day. *' - * f. in the ohservatiens made of the visited shipyards, reported on by references (c) through (f), it was indicated that in the fabrication shops, portable covers J'or flange Joints and irreg^ar^surfaces are a~pfepared`hkoa`grcde*AX'asbestos cloth (SS-`c446)"a*&e*ftiafc' a fiber glass fill conforming to V2I/-I-16411, type II. As a replacement`for the asbestos cloth, one shipyard is satisfactorily using 1005 fiber glass lagging, . manufactured by y, p. Stevens, Co. 20079, type I)# Aboard the . visited ships at these installations, the following practices were observed, as previously reported; . (1) Ventilation duets vere insulated with unfaced fibrous glass . board (Kit-1-742) and covered with revettable asbestos cloth. Fibrous glass' cloth (KXb-C-20079, type 2) adhered with J4Ib-A-1216, class 1, has been used as a suitable replacement for the asbestos lagging cloth. <2} toiler steam druse, sain steam iluges, deaerating feed tanks, vatar heaters and as&ltf propulsion turbines ere insulated with asbestos felt (umosite) 1SD-I-1$091, type A, plain. To eliminate this material for ^ihis use, calcium silicate insulating bleeks (USD-1-2819, class 2} have oecn* satisfactorily used Tor applications *up-t 1000 T* They -arc-applied as two, ^inch thicknesses covered by 1-inch open mesh wire and.posted with magnesia cement (SS-C-160, type I) or mineral wool cement (S8-C-160, type III, grade f) and finally lagged with fiber glass doth (UEL-C-20079, type !) * ^ *P*`Tinsdating'l't piping up`io 1200 f molded or preformed fibrous asbestos sections (UIL-I-2761, grade HI, class f) have been -*replseed in ssae instances by calcium silicate (molded) sections - - - 0OUI-2781, grade HI, bless ). -- i-- xt 9 . -V *N '6764 9390(FA-2*7) Ser 15S4 (4j For stress relieving procedures on welded pipe Joints end shafts, gohns-iianville, Cerafelt, refractory fiber felt (MfrX23t28, grade B), is being used to replace flaps! tc asbestos Felt (1122-2-25092, type A, plain), the temperature of the encased heating clement in these applications ranges up to >2300 F. . (5) there elastomeric foam is used as antisweat insulation on fire sains, acd cold piping, -a covering of 3 Inch vide fibrous gloss tape* or cloth (&L-C-2Q079, type 2 end 211} may be used for sailor-proofing -- "Tri place*'of asbestos doth or painting, where abuse is a problem. t-<6) Wherever asbestos cement (JJIL-C-2903A, type 2} has previously ' bees utilised, replacement say be effected -by the use of mineral wool cement (SS-C-lBO,. type.IXI, grade f). i - ---__ (7) Asbestos millboard {2J&-M-351), a highly dust producing material* during saving operations, say be eliminated in the manufacture of -removable covers by replacing with fiber glass felt (UE2/X-16421% type II). 3. Industry Survey * * . * .a. letters of inquiry addressed to some 20 manufacturers and vendors' of thermal insulation were followed by personal visits from company technical representatives, including directors of research and development and company officials. The response included submission of letters, catalogs, ___..-^amplas, field demonstrations, and, In one instance, a letter from one manufacturers representative cautioning the_^&w iefiabating the * asbestos business out of existence, in tne gain, hev, helpful letters oesers&ing new materials and psv uses for old materials we received. tansstiesreportedby these letters indicated that some B44exatiaa Is. given to the workers' safety by conducting particulate counting, by fur nishing exhaust ventilation, by wetting down the ingredients and by automating the production line frea processing the raw material to pack aging tbs finished product. 2oreover/one large Insulation manufacturer has contributed a substantial grant to the Insulation Industry }$glenc Research frogrga.uhlch is^epneezned with the hazards of asbestos and tew** toevercese thee. However, so industrial plants we visited to ohservp `their manufacturing procedures, safety precautions exercised, worker habits *--~*-or `packaging and* other pertinent sequences of producing* thermal insulating * joateriels. ** mm tmmm- 6 9 * 67d<:MA:loi 9390(fA-2e7) Ser 1#4 V, The National Insulation Manufacturing Association through its executive secretary has issued paophlets describing reeossended health safety practices for handling and applying thermal insulation products containing asbestos and mineral fibers* Additionally, application prac tices for spraying asbestos fibers have been issued by the executive secretary of the Sprayed Mineral fiber Manufacturers' Association* Adequate ventilation, netting,* vacuus 'leaning of dust and the tearing of Bureau of Mines-approved respirators are emphasised during ripout and application procedures, the associations advocate both isolating the wording area in order to prevent excessive dust contamination in adjacent areas end permitting only workmen engaged in ripout operations to be allowed in the vorfc location. In every case, unnecessary handling of scrap or permitting strep to lie around unprotected should be prohibited* the recommendations advocated by industry generally have been adopted by the Naval and private shipyards. .. c. Several responses from insulation manufacturers have indicated that new materials ere being developed for the replacement of asbestos for theinal insulation. Vhen these products beeans available, they should be subjected to Industrie! Jfc'giena studies prior to adoption, especially if the new materials contain volatile solvents. In addition, these materials should be critically evaluated with respect to the following: (1) Shipping, covenant-and storage properties (weight allowance). *. (2) lose of removal and reapplication whenever necessary, . (?) Dusting tendencies (especially if used in radioactive applications) ^cs^bustibility-(flesh point, fire point, Sftohe .density, sbofce toxicity, fuel contributed). 0 '* (5) Safety requirements (dead load year, impact or mechanical damage, forces of expansion and contraction, vibration)* (6) Compatibility with metal to which it la applied (resistance -to atmosphere, spillage) .. . -- *-->* <-- ..a---- -- -- fii _________(Z>. TlSBP^t^^Stt^XAttsji-teaaaraiure.. ------------------ ---- ----- - ------  ' * .. . * 6764tUAtlal ' . 9590(FA-2S?) * , , * Ser 1584 . e, As & result of our inquiries, industry has offered information on the following sioterials and their current prices for evaluation as alternates for minimising the hazard attending the use of asbestos: (1) Hber glass`felt, HEU-X-16411, type II with a service tenureture up to 1200 F is supplied by Pittsburgh Coming, (Temp-Hat), Eastern Refractory Inc. (Erco-Hat* 1500) And Owens-Cqrning (D-12CO-6). The ..Approximate cost.is sixty-five cents a. square foot for a one inch thick ness. * (2) Calcium silicate pipe insulation, K&-I-2761, grade I, class b; grade II, class d and grade III, class e, with a service temperature ------- yp to *1200 P is supplied by Pabco Industrial Products Division (Calter.p), Owens-Coming (Keylo), Johns-Hanville (Theraobestos), OAF Corp. (Calsiiite) and Keene Industrial Insulation (Tkermasil). . The cost of ly" NFS x 1" thick, grade I,class b is seventy-five cents a foot; grade XI, class d Is $1.20 a foot and grade III, class e Is $140 a foot. (5) Fiber glass cloth with a service temperature of 1000 F is supplied by 5. ?. Stevens Co. as style #1925 at $2,50 per square yard and -style #34205 at $1.52 per square yard. These aterials can be incorporated in MXX/-C-20079, type I by raising the maxima weight requirements per square yard. - ----------14-) Calcium silicate block insulation, 101-1-2519, classes 1 and 2 with a service temperature up to 1000 F is supplied by Pabco Industrial Products Division (Caltemp), Johns-Hanvilla (Thorsobestos), Owens-Coming (Kaylo) end Keene Industrial Insulation (Tfcerstsil). --"-The cost of a 1* thickness is fifteen cents a square foot and of a 2" thickness is twenty-eight cents a square foot* (5) Asbestos doth,* lint free, is supplied by Nicolet Industries Inc., manufactured with Nicolon and Nicofil yarns.. . Cost Is not known, - (6) Asbestos felt*-lint-free,-with ft service te*fpernture-r-550 F is supplied by B. X* Porter Co*, Inc. (Knitted Amosiie). . fif) pesa plsstie astoaexicTlpipe" insulation, WUVl5280, * foras T and S within service temperature of 160 F is supplied by lohns------ UaRVnit '(Aerbtub'e), "Keene'Industriannsulatfon'CHohc^Tlex) " 'Armstrong Cork (Ansa-flex) and Coons-Coming (O-C Flexible Tabing and Sheeting). A 1 1/2" NTS x 5/4" thickness is thirty-seven cents a foot and eightyseven cents e square foot for sheeting 3/4" thick. * \ ' *. 6764:tttslfiX - 9290(FA-267) Ser*1554 e # * ' ! (8) Refractory fiber, MIH-23123, grade 8 with a service tenpsxe- ure up to 2000 F is supplied by Johns-^ianville (Cerafoil). Cost Is net hnenm. (9) liber glass tape, MIL-C-20079, typ* II, class 3 is supplied by Heef Industries Inc.', end Carolina Karroo .Fabric Co. (Sea-Leg FbTo-I-Ciass &03 Tape) at 51.35 a s*ua*e yard. ... a (10) Asbestos cloth, a revettoble lagging cloth, is supplied by *. X. Sorter Co., Inc. .(ffVtr-lOO Legging Cloth) and Raybestos-lfanhattan Inc. (Mi Speeding Cloth) at $2.50 a square yard. 0 ' (11) Cement, finishing, mineral vool, SS-C-160, type III, class f *'*~vith s service temperature of 1200 F is supplied by Eagle Piehe? Industries - Inc. (One-Cote end Hyl Cerent), Keene Industrial Insulation (Super Power house), Forty-Eight Insulation loe. (45 Ouicfc Set Cement) and Fabeo 4 Industrial Products division (Finishing Insulating One-Coat Cement). - . Approximate cost is $4.5C/50 lb bag. (12) Fibrous glass, pipe insulation, MIL-I-22344, with a service ./ . tesperature of 370 F is supplied by Johnc-lianville (Micro-Lob), Keene . , Industrial Insulation (i&no-X&ver), Cveca-Coming (FSberglas Pipe Xnsidfttiffi) * and Certain-leed Products Corp. (Snap-On).' A l" KJS x IM thickness costs $1.17 ft foot. ** * 4. .Conclusions* . . -- . ft. Kaval and private shipyards as veil as insulation suppliers are veil evare of the serious batetfds attending the use of-asbestos. itevertheivss, V eeawiderebl* asbestos-eontoinisg insulation notori cl currently is being used In Kaval applications and stringent handling precautions are not being * enforced in all instances. * r * . . b. In the course of performing surveys of shipyards and insulation suppliers, XA\5CPKILAIIV uncovered asple information to lead this activity -- - *--to believe that the use f high-asbestos-containing thermal insulating materials should be curtailed due to hasards to the health of insulation . -.--jwarlers*. inasmuch as the Medical phase feu- the overall asbestos - study vas assigned to BtLS&rty reference (a), BttffiD should be consultod for more definitive.?plutions Jo, th?. medical aspects of this problem. # * * *v .. . 6t64:VA:U1 9?90{FJU2S7) Ser 1534 c* The results of the WWSECPKIUSXV survey indicates that suitable alternate insulation oatrials presently are available vith decreased health`hasards attending their use* ~ 5* Beioraendations Based on the finding of this survey and in order to minimise health hazards attending the use of Kaval insulation, the following action Is ... recoamended; . a* HAV3EC/)LA\5HXFS issue an interim instruction to all concerned "festivities to replace ell current utilisation of high-asbestos* containing materials vith alternate materials is the following applications: (1) Discontinue the use of aaosite asbestos insulation felt (iGL-X-15091, type A, plain) for stress relieving and as a filler in the manufacture of removable covers* Substitute calcium silicate blech insulation (UFXrZ-23l9, elesses 1 and 2} or Cerefclt, a refractory insulation * felt, conforming to J3L-I-2312S, grade B for stress relieving applications. Substitute fiber glass felt XXOL-X-X64U, type XX) for amosite felt in the manufacture of removable covers* (2) Discontinue the use of water repellent asbestos felt (UTlr-1-15091, type 8) as an entisweat insulation for cold and chilled water service, and substitute foam plastic (lOUB-15230, fozss T and S) ""in its 'place* _ " (5) Discontinue the use of preformed fibrous piping Insulation (liZL-1-2781, grade XX, class e and grade XXX, class f) and substitute ---:"calcium`sillcate (MIL-1-2761, grade X, class b, grade XX, class d, or grade XXX, class c) depending upon temperature requirements* -- .y (4) Discontinue the use of asbestos doth (6*0-466, form I, grades V. G., AA and AAA) for legging purposes. A satisfactory substitute is fiber glass fabric such as /842G5, presently, available frsa the J. F* ----Slovens-Co*,.Inc., end .which can be incorporated into Ifl2r*0-2OO79 by * . raising the weight requirements* * # asbestos cloth (SS-C-466, fora I, grades U. O., M end AAA? for the manufacturing removal covers. Fiber -""^leisTShrie* sueh'as"#1925/ MfcuTdeltfred-by JTP.* Stevens Te*yiaa.# is satisfactory for this use and can be incorporated in Mil-C-20079, with an appropriate weight adjustment* A limited use of grade AAA-U asbestos cloth as an inner surface of removable covers for rigidity of interference -10 . . " 6764jtfc2lel . 9390(FA-2S7) ... Se? XfU * cutout$ Bay be permitted until glass 'doth can be adapted Tor this purpose* ' . <[9\ ^ (6) Discontinue the use f theme! tape (hCL-I-153'9) for hoi piping up to 3/4 inch 1S and replace with fiber glass cloth, such as ^192$ f 3. p. Stevens Co., Xne., cover and a filler of fiber.glass ^ rovings (MX^X-ldOl, typelj.. . * (7) Discontinue the use of asbestos finishing ceaent (1SL-C-2908, 'types X and xr) and replace with einerel vool finishing cesent (SS--ldO, . ,,type XIX, grade f). . (6} Discontinue the use of asbestos millboard (JCJ-1V351) in the ----------manufacture of removable covers by-replacing with'fiber gl&ss'Telt (MTL- X-16411,- type XX). b.* Revise HAVSHIFS Technical Manual Chapter 9390, Theme! insulation and 121>STD.7$9C,references (g) and (h) to reflect the following; (1} Delete prohibited materials* * * ~*C?} Incorporate additional functions of presently available specification materials _ (3) Detail methods of handling end disposing of used insulating * " materials. . * (4) Describe the stress relieving procedure for welded pipe Joints and shafting depending upon the .use of a resistance or induction coil and *" *'i"*^the*insulating materials required in each instance* -- ---- . - - (5) List a realistic tabulation eaccopasaiag the quantity of Insulation and the degree of protection afforded by different thicknesses of the various insulating materiels, * ----------cp--Troaulgqte and 't*etty-enforce eooprehensive uafety regulations and required housekeeping practices in shops and ships with respect to -all..phases .f handling inflation oaterials*. Xa this regard, the vide 11 ) / 6?64:I&:lal 93?0(fA-2S7) Str 1584 adoption of a self contained battery operated respirator should he considered during ripout operations of asbestos Insulation. A Stryher Cast Cutter will minimise dusting during this shipboard ripout procedure. d. Critically evaluate new saterials as they become available for the replacement of asb.est^s for. thenral insulation. . .. Copy to: 1iAVSSC 61010(20} HMSECJTJTLA&XV 6700, 6700301, 6712, 6720, 6723, 6760, 6764 (fi) v. wfecoa By direction i * .y mcnmiga^