Document 3emg3Q5nn1Lmpxedo54Kw8MEO

RECEIVED. DEC 1,982 Gurfod'W- Culp*p?e- m I -- 11/4/82 Draft -- ~r a RECOMMENDED STANDARD FOR OCCUPATIONAL ASBESTOS EXPOSURE IN CONSTRUCTION AND OTHER NON-FIXED WORKPLACES November , 1982 O CTJ DU 039145 8V ^v6 TABLE OF CONTENTS g.a?e I. INTRODUCTION .................................................................................. 1 II. FINDINGS OF SPECIAL GOVERNMENT ADVISORY GROUPS ENDORSING THE PRODUCT AND WORK PRACTICE CERTIFICATION APPROACH RECOMMENDED HERE ...................... 7 A. Many of the Components of the Customary Fixed-Site OSHA Health Standard Are Neither Practicable Nor Effective in Construction Work ...................... 10 B. The Use of Products and Work Practices, Validated to Be Safe, Is the Only Cost-Effective Way to Provide Good Health Protection in Construction ........................ 17 III. EXPLANATION OF THE RECOMMENDED STANDARD ...................... 20 A. The Product and Work Practice Classification System ................................................... 22 B. Validation of Product and Work Practice Classifications ............................................ 25 C. Regulatory Requirements Tailored to the Degree of Risk Posed to Workers ...................... 31 D. The Compliance Coordinator and Other Generally Applicable Requirements ........................ 34 IV. ADVANTAGES OF THE RECOMMENDED STANDARD OVER THE TRADITIONAL OSHA FIXED-SITE HEALTH STANDARD ............. 37 A. Cost-Effectiveness .......................................................... 38 B. Improved Voluntary Compliance and Enforceability ...................... '.................................. 42 C. Built-In Incentives for the Development and Use of Safer Products and Work Practices ...................................... 44 V. CONCLUSION ...................................................................................... 45 DUP 0948219 DU 039146 APPENDIX A: RECOMMENDED STANDARD FOR OCCUPATIONAL ASBESTOS EXPOSURE IN CONSTRUCTION AND OTHER NON-FIXED WORK OPERATIONS ..................................................... APPENDIX B: A PRELIMINARY ASSESSMENT OF HOW THE RECOMMENDED ASBESTOS STANDARD CAN SUCCESSFULLY BE IMPLEMENTED IN CONSTRUCTION AND OTHER NON-FIXED WORK OPERATIONS ....................................................................................... gage la lb DUP 0948220 11 - DU 039147 RECOMMENDED STANDARD FOR OCCUPATIONAL ASBESTOS EXPOSURE IN CONSTRUCTION AND OTHER NON-FIXED WORKPLACES I. INTRODUCTION The occupational health community has recognized for a number of years that the customary occupational health standard -- designed for fixed-site manufacturing opera tions -- is poorly-suited to construction and other non-fixed, high-turnover jobs. The usual OSHA requirements for a per missible exposure limit implemented through engineering controls, routine monitoring, medical surveillance, hygiene facilities, recordkeeping and the like, have proven ineffec tive and impractical for an industry characterized by small, transient employers, high employee turnover, and outdoor work activities the nature and sites of which are continu ously changing. Thus, OSHA, federal advisory groups on the construction industry, as well as representatives of both management and labor, all have called for a fresh reappraisal of how to regulate toxic substance exposures in construction operations On February 7, 1980, the Asbestos Information Associa tion of North America (AIA/NA) and the Association of Asbestos 1/ The findings and recommendations of these groups are discussed in somewhat greater detail in Part III, below. DU 039148 DUP 0948221 2 Cement Pipe Producers (AACPP) published a recommended asbes tos standard -- modelled in part on the "performance-based exemption provision" of OSHA's Acrylonitrile Standard-^ -- to illustrate how to deal in a cost-effective manner with occupational health hazards in construction and other nonfixed workplaces.-7 The 1980 Recommendation was built around the concept of identifying products and work practices certified to be safe in the sense that exposures in excess of permissible levels will not occur under any reasonably forseeable circumstances. In brief, the 1980 Recommendation called for -- (1) the classification of products into three categories according to their potential for occupational asbestos exposure in construction uses; (2) the application of different regulatory requirements tailored to each product category, with increasingly stringent requirements imposed for products presenting higher levels of risk; and (3) the use of objective data, including validation by fully qualified testing laboratories and occasional confirmatory field monitoring by OSHA inspectors, to ensure that certified work practices and product formulations are effective in protecting workers. 2/ 43 Fed. Reg. 45762, 45778 (October 3, 1978). See the discussion of the Acrylonitrile Standard in Parts III.B. and IV.B.l., below. 3/ AIA/NA & AACPP, Recommended Standard for Occupational Asbestos Exposure in Construction and Other Non-Fixed Work Operations (February 7, 1980) (hereinafter referred to as the `'1980 AIA/NA-AACPP Recommendation"). DU 039149 DUP 0948222 3 The certification program recommended by AIA/NA and AACPP was designed to provide a strong incentive for the develop ment of safe products and work practices which eliminate the need for routine monitoring, medical surveillance, and other provisions of the customary OSHA standard; to lighten OSHA's enforcement burden; and to promote voluntary compliance in the construction industry. These advantages led to strong endorsements of the work practice certification concept in 1980 and 1981 by special advisory groups established to study the problem of develop ing sensible health standards for the construction industry. After extensive deliberations and public hearings, OSHA's Advisory Committee on Construction Safety and Health issued a report on May 16, 1980 concluding that many of the elements of the typical fixed-site OSHA health standard are inappro priate as applied to construction jobs.-/ Specifically, the Advisory Committee found that repetitive monitoring, medical surveillance, recordkeeping, and other components of tradi tional health standards that have been "developed with a factory setting in mind," do little to improve worker health in the construction industry, but nevertheless impose costly requirements that simply are not feasible for many construc tion employers. 4/ Advisory Committee on Construction Safety and Health, Report on Occupational Health Standards for the Construction Industry (May 16, 1980) (hereinafter referred to as the "Construction Advisory Committee Report"). DU 039150 DUP 0948223 4 In order to provide an effective and practical regula tory program for the construction industry, OSHA's Construc tion Advisory Committee endorsed the work practice certifi cation concept by recommending that construction industry health standards should "allow an employer or a material supplier to develop and publish work practices" which are shown, based on "legitimate measuring and monitoring," to be effective in "assur[ing] that permissible exposure limits are not exceeded.An OSHA/NIOSH Task Force, specially set-up to study the same issues and review the findings made in the Construction Advisory Committee Report, reaffirmed on January 2, 1981 the Advisory Committee's earlier recommenda tion for the use of certified work practices. Subsequently, the Building-Construction Trades Depart ment, AFL-CIO (BCTD/AFL-CO) issued in October 1981 a separate proposal^/ directed at a problem that had not been addressed by the 1980 AIA/NA-AACPP Recommendations, or by the Construc tion Advisory Committee and OSHA/NIOSH Task Force Reports. In light of the variety of different jobs performed -- often simultaneously -- on many construction projects, and in light 5/ Construction Advisory Committee Report at p. 6. 6/ OSHA/NIOSH Task Force, Response to the Report on Occu pational Health Standards for~the Construction Industry (January 2, 1981) (hereinafter referred to as the "OSHA/ NIOSH Task Force Report"). 7/ BCTD/AFL-CIO, Pre-Job & Job Site Safety and Health Guide (October 1981). DU 039151 DUP 0948224 5 of the constantly changing sites, types of work, and per sonnel involved, there is a pressing need for a more centra lized effort on the part of construction employers to formu late careful, project-wide programs for ensuring safe and healthful working conditions. To meet this need, the BCTD/ AFL-CIO recommended that Safety and Health Coordinators be designated to develop, implement and oversee health and safety programs appropriate to the particular hazards workers may face on a given construction project, and provide a focal point for resolving health or safety-related complaints by workers and for cooperative labor-management efforts to eliminate unsafe working conditions. Because they are complementary, the 1980 AIA/NA-AACPP Recommendations and the 1981 BCTD/AFL-CIO proposal have been merged into a single recommended standard, attached to this paper as Appendix A. Specifically, the 1980 AIA/NA-AACPP Recommendations have been amended to require, in the case of employers who intend to use certified products and work practices in lieu of the otherwise applicable provisions of the OSHA Asbestos Standard, the designation of a Compliance Coordinator to ensure that the appropriate products and work practices are used, and to administer employee training and other programs needed to properly implement the health pro tection goals of the Recommended Standard. If adopted by OSHA, the Recommended Standard would serve the interests of construction industry employees and DU 039152 6 employers, and OSHA as well. OSHA's current approach for regulating construction industry health hazards, including asbestos, is undeniably impractical for most employers, largely unenforceable, and, hence, ineffective in protecting workers. In contrast, the standard recommended here would -- (1) provide sound, cost-effective health protection for workers by relying on products and work practices that already have been demonstrated to be safe and that are simple and economical to use;^/ (2) create incentives for the develop ment and use of even safer products and workpractices ; (3) encourage voluntary compliance by imposing sensible requirements and by encour aging cooperative labor-management action; (4) centralize on-site supervision and voluntary monitoring of compliance with health and safety requirements; and (5) ease the existing enforcement burden on OSHA by simplifying inspection procedures. 8/ As detailed in Appendix B, a considerable amount of work has already been done, in the specific context of asbestos, to identify and develop products and work prac tices that are unlikely to result in exposures above OSHA's permissible exposure limits in any reasonably foreseeable construction industry use. DU 039153 DUP 0948226 laBiiiLliiiiiiiiaiEMiijiBilLaiailifeBBji -7- In addition, apart from the specific context of asbestos, the Recommended Standard can serve as a model for extending the work practice and compliance coordinator concepts to other health hazards involved in construction work. II. FINDINGS OF SPECIAL GOVERNMENT ADVISORY GROUPS ENDORSING THE PRODUCT AND WORK PRACTICE CERTIFICATION APPROACH RECOMMENDED HERE The question of how to regulate occupational health hazards in the construction industry has been studied inten sively for the past several years. As long ago as 1975, OSHA acknowledged -- in the specific context of asbestos -- that many of the provisions contained in customary OSHA health standards are impractical in construction operations, and, accordingly, "that alternative . . . controls may be more appropriate and feasible" because of "the uniqueness of the construction industry itself (viz., the multiplicity of non-fixed workplaces, and the utilization of highly transient workforces).Similar concerns were expressed by industry officials in connection with major OSHA proceedings in 1977 and 1978 on Lead and Cancer Policy.-^/ 9/ 40 Fed. Reg. 47657 (October 9, 1975). 10/ See for example Statement of C.R. Mattson (National Constructors Association (NCA)), Docket H-004 [Lead], Ex. 98; Statement of Harry Taylor on behalf of the Council of Con struction Employers, Docket H-004 [Lead], Ex. 64; Statement of Fred Graham (NCA), Docket H-90 [Cancer Policy], Ex. 125. DU 039154 DUP 0948227 8 Subsequently, after preliminary hearings in May of 1979, OSHA's Construction Advisory Committee -- a balanced group representing the interests of employers, employees, and the public--^ -- reached a "consensus" position that "most OSHA health standards were developed for and are best suited to the needs of manufacturing plants where employment is steady and the working environment is more stable and predictable." Accordingly, the Advisory Committee urged "that a separate set of health standards be developed to meet the special conditions of the construction industry. "--Z In response. Dr. Eula Bingham, former Assistant Secre tary of Labor for OSHA, agreed that "[b]ecause of the mobile and transient nature of their industry, construction employers have had difficulty in complying with these standards." Dr. Bingham directed the Advisory Committee to undertake a "thorough[] review" of the problem and to prepare a report making "recommendations that would provide the necessary protection to employees. / 11/ The Committee is composed of five employer representa tives, five employee representatives, and five representa tives from federal and state regulatory agencies and the general public. See Construction Advisory Committee Report at p. 57. 12/ Construction Advisory Committee Report at p. 2. 13/ Memorandum dated July 18, 1979, attached as Appendix A to the Construction Advisory Committee Report. DU 039155 DUP 0948228 9 The Advisory Committee thereafter held further hearings and received additional testimony and advice by "experts and consultants from business, labor, government, and the occu pational medical profession."^/ Based on that record, the Advisory Committee released its report on May 16, 1980, and the Committee's conclusions were largely reaffirmed in a January 2, 1981 report prepared by a special OSHA/NIOSH Task Force set up by Dr. Bingham to review the Advisory Committee Report. As detailed below, the Construction Advisory Commit tee and OSHA/NIOSH Task Force Reports support two key con clusions : (1) that many of the provisions of the customary OSHA health standard -- such as routine monitoring, medical surveillance, recordkeeping, and hygiene facili ties -- are neither practicable nor effective in con struction work; and (2) the best and only solution is to adopt simple and economical work practices that make the workplace safe and at the same time eliminate the need for most of the impractical components of the typical OSHA standard. 14/ Construction Advisory Committee Report at p. 3. DU 039156 DUP 0948229 10 A. Many of the Components of the Customary Fixed-Site OSHA Health Standard Are Neither Practicable Nor Effective in Construction Work The findings of the Construction Advisory Committee and the OSHA/NIOSH Task Force reconfirm the fact -- already widely acknowledged by the business community, labor groups, and the industrial hygiene and occupational medical pro fessions -- that the usual OSHA approach of implementing a permissible exposure limit through exposure monitoring, hazard-specific medical surveillance, recordkeeping, hygiene facilities, and the like, is simply not practical or effec tive for construction work. As OSHA had found over five years earlier, this conclusion follows inevitably from the nature of the construction industry itself, and from the fact that construction work bears little resemblance to the fixed, stable "factory" jobs for which OSHA health standards were designed. Thus, in contrast to factory work, which is "permanently placed and configurated" and involves work activities that are "constant and predictable," most construction employees work in a "continually changing" environment, moving from one temporary worksite to another.--'^ Each worksite is unique, with exposure patterns varying according to shifting weather conditions and the use of different materials and 15/ Id. at pp. 32, 53. DU 039157 DUP 0948230 ilMiaatiMHi--2 aMHUBi--an - 11 - processes over differing lengths of time. As the AdvisoryCommittee found, "in construction work[,] employment is temporary, the work location is continually changing, and environmental exposures are subject to the variability of wind and weather. Workers may use or be exposed to a given material for short periods of time," in some cases "for only a few hours" and in others for "only a few days."--^ In addition, the construction industry does not follow the pattern of "steady" employer-employee relationships that prevail in factory jobs.--^ Quite to the contrary, the construction industry is characterized by small, highly transient firms, whose number fluctuates widely according to seasonal variations and other short-term shifts in demand. Indeed, many construction firms "are created to carry out a single project and then are dissolved. Similarly, the workforce is transient and temporary, with turnover rates as high as 300 to 600 percent per year depending on the job or craft involved. Casual hiring and severance practices (i.e., "walk-on, walk-off") are common.--' 16/ Id. at pp. 15, 32. 17/ Id. at p. 2. 18/ Id. at p. 32. 19/ Statement of Fred Graham (NCA), OSHA Docket H-90 [Cancer Policy], Ex. 125 at 2; Research Triangle Institute, Asbestos Dust; Technological Feasibility Assessment and Economic Impact Analysis of the Proposed Federal Occupational Standard, p. 11-36 (Draft dated September 1978) (hereinafter referred to as the "Draft RTI Report"). DU 039158 DUP 0948231 12 Accordingly, most "construction employees change jobs regu larly, " and many "may work for three to ten employers through out the country in the course of a year."--^ In short, as the Advisory Committee found, "[t]he only consistent aspect" of construction "is its variability.--/ Customary OSHA standards, developed for fixed-site, steady employments in manufacturing industries, "do[] not take into account rapid employee turnover, a constantly changing work environment, and the concept of a workforce made up of craftsmen who are expected to bring specialized skills" to short-term jobs.--^ For example, the use of repetitive monitoring to imple ment a permissible exposure limit serves no useful purpose in most construction jobs. Because construction work typi cally involves short-term tasks, the lag-time needed to complete the necessary sampling and analysis (five to six weeks in the case of asbestos) often exceeds the life of the operation. As the Construction Advisory Committee found: Testimony from both labor and management described construction work as temporary, subject to ambient weather conditions, and changing daily with respect to envi ronmental contaminants and physical locations of work operations. Thus, the combination of industrial hygiene lag 20/ Construction Advisory Committee Report at pp. 21, 33. 21/ Id. at 53. 22/ Id. at 42. DU 039159 DUP 0948232 13 time and changing and unpredictable environmental conditions on the job means that very often by the time the industrial hygiene results are available, the job that was sampled has been finished and the workers reassigned.23/ Moreover, since exposure levels vary widely according to the nature and duration of the task, the work procedures followed by a particular employee, the tools used, the exposure potential of the product used, weather conditions, and other variables, such routine monitoring of particular workers will rarely, if ever, be meaningful for evaluating the exposure of other workers, or even of the same worker on another day.--^ The Advisory Committee agreed that "[t]hese combined variables make it extremely difficult to accurately characterize any particular worker's exposure" -- much less conduct the kind of "representative" monitoring contemplated under most OSHA health standards.--25'/ Similarly, routine medical surveillance aimed at a par ticular hazard is, as the Advisory Committee concluded, "a 23/ Id. at p. 6. See also OSHA/NIOSH Task Force Report at pp. 4, 10-11. 24/ See, e-<7- ' 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 on 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. 25/ Construction Advisory Committee Report at p. 32. See 29 C.FTrT 1910.1001(f)(2)(ii) (requiring representative monitoring for asbestos). DU 039160 14 major economic and logistical problem" "for both employees and employers" in the construction industry.^" The Committee cited high employee turnover as the "primary reason" for the "severe problems" resulting from OSHA medical surveillance requirements in construction,--^ and identified the follow ing particular difficulties: 1. Unnecessary repeat examinations and "poten- 'O tially harmful" over-exposure to diagnostic x-rays and other medical procedures;28/ 2. Discrimination against employees based on the results of OSHA-prescribed medical examina tions;^/ 26/ Construction Advisory Committee Report at p. 21. 27/ Id. The Advisory Committee observed that -- [i]n construction, employees may be hired for anywhere from one day to many years. One employee may work for three to ten employers throughout the country in the course of a year. The attempt to superimpose initial and periodic physical examinations on such a pattern of employ ment presents severe problems for both employees and employers. 28/ Id. The Committee explained that "because they routinely change employers," workers in the construction industry "may be required to take an OSHA 1 initial' medical examination several times per year throughout their working lives," and added that "if OSHA's standards development effort continues in its present pattern, an increasing group of workers will be subject to multiple medical examinations." Id. at p. 22. 29/ The Committee concluded that "medical judgment . . . may or may not be uniform among employers or even within a given medical office," and, because of the likelihood of repeat examinations, "[s]ooner or later it is possible that fa con struction employee] will not be allowed to work for medical reasons that may be quite arbitrary." Id. at p. 22. DU 039161 DUP 0948234 laiaSii' i.a:.:A,j..i_ ilfeiSul.JaMai.1 im .1 - 15 - 3. The "lack of qualified medical resources,"30/ 4. The ineffectiveness of medical surveillance due to the absence of a continuous physicianpatient relationship;31/ and 5. The heavy financial burden of the examina tions, as well as costly delays in project start-up due to the need to conduct initial examinations.32/ Quite apart from these serious practical difficulties, there are real questions about the value of medical surveil lance in many construction contexts, including those involv ing the use of asbestos products. Because of the nature of most construction work, occupational asbestos exposures are 30/ "[A]t the present time, physicians willing to accept OSHA physical examinations are difficult to locate in some parts of the country. Trips of 50 miles between the site and the physician's office are not uncommon in some areas." Id. at p. 25. 31/ "Good preventive medicine requires knowledge of environ mental conditions on the job . . . and the ability ... to follow the employee over time," but "[achieving these objectives is difficult in construction," both (1) because "[e]mployees who work for short periods are sometimes term inated before the complete results of the examination reach the employer," and (2) because "[t]he fragmented and imperfect medical system created by the standards" -- including the lack of any "continuity of medical records" -- "is unlikely to discover . . . diseases while the exposure is taking place and is even more unlikely to stimulate the necessary environmental control systems." Id. at pp. 24 & 26. 32/ "[Ejmployers may be charged anywhere between $40 and 51000," and "the necessary time lag between making the appointment for the examination and the examination itself" "delays the startup or the progress of work [on some jobs], because employees cannot be put to work until the examina tions are completed and the physicians' report has reached the employer." Id. at pp. 24-25. DU 039162 DUP 0948235 16 highly variable and, for the most part, are brief, intermit tent, and very low on the average. As OSHA's feasibility contractor for asbestos has concluded: Products containing asbestos are not used continuously [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.33/ For these and other reasons, the Construction Advisory Committee and the OSHA/NIOSH Task Force agreed that "[n]ew standards for the construction industry should recognize the impracticality of attempting to include a requirement for medical surveillance in every health standard," and recom mended consideration of alternative approaches^ The Advisory Committee and Task Force also questioned the value and workability of applying other components of the usual fixed-site standard to construction. The Advisory Committee found, for example, that requirements for creating and keeping for lengthy periods detailed records of monitor ing and medical examinations serve no real purpose in an 33/ Draft RTI Report at p. 11-35. 34/ Construction Advisory Committee Report at pp. 28-29; OSHA/glOSH Task Force Report at pp. 2 & 7. The Advisory Committee suggested that a "generic" medical surveillance program for construction be examined. DU 039163 DUP 0948236 17 industry "where employment is temporary, the work location is continually changing, and environmental exposures are subject to the variability of wind and weather."--^ Simi larly, the requirements for "hygiene facilities" typically found in OSHA standards are not feasible for many construc tion operations because of the unavailability of water and other necessary facilities .--^ B. The Use of Products and Work Practices, Validated to Be Safe, Is the Only Cost-Effective Way to Provide Good Health Protection in Construction In essence, both the Construction Advisory Committee and the OSHA/NIOSH Task Force recognized that the best and only way to avoid many of the impractical components of the typical OSHA standard is to adopt simple and practical 35/ Construction Advisory Committee Report at p. 32. The Committee noted that, for these reasons, ixposure and medical records have far less diagnostic value than they do in the manufacturing context, where stable employer-physician-emplovee relationships are more^ likely to exist. Id. at 32. In addition, "[t]hese records . . . have little value for epidemiological purposes or other long-term studies," because "a great many of these records will be lost" through busi ness closures, and the remainder "will be scattered among construction firms scattered throughout a geographical region or sometimes throughout the country." Id. at 32 & 33. In the end, the Committee found, "these records [most likely] will simply fill up government warehouses at signif icant cost to the taxpayers and the employers who originally collected them." Ld. at p. 32. 36/ Id. at pp. 53-54. DU 039164 DUP 0948237 18 methods to make the construction workplace safe. The Advi sory Committee made this point most clearly in the context of its discussion of the medical surveillance provision contained in virtually all OSHA health standards: [OSHA and NIOSH] should mount a major effort to develop and publish economical and practical methods of controlling these hazards so that the work environ ment can be made inherently safe. New standards should emphasize environmental controls and deemphasize dependence on medical controls unless they are neces sary .37/ At the same time, both groups concluded that the custo mary approach of setting a permissible exposure limit and implementing it primarily through repetitive monitoring is not a workable means of preventing unsafe exposures in construction. The alternative approach they recommended is to rely on work practices which provide reasonable assurance that safe exposure limits are not exceeded. As the Advisory Committee emphasized -- Because of the transient nature of work ing conditions in construction, both the worker and the employer could be better served in many cases by simply using an acceptable work practice at the start of a job where a potential exposure exists, and dispensing with the costly and time consuming monitoring process.38/ Specifically, the Committee recommended that " [con struction standards should . . . allow an employer or a 37/ Id. at p. 28. See also p. 52: "the development of low cost, practicable control methods should be a part of the total standards development process for construction." 38/ Id. at p. 36. DU 039165 DUP 0948238 19 material supplier to develop and publish work practices" that are "based on legitimate measuring and monitoring of actual field operations" and "designed to assure that per missible exposure limits are not exceeded./ The Commit tee added, following the scheme suggested in the 1980 AIA/ NA-AACPP proposal and incorporated in the Recommended Stan dard herein, that "[t]he effectiveness of the workpractices would be checked in the routine course of field work by employers, and by both OSHA and NIOSH."--^ The OSHA/NIOSH Task Force reaffirmed this recommendation and suggested a number of methods for implementing such a program.--^ More over, the Task Force urged that these work practice recom mendations "be reflected as soon as possible in new health standards being proposed by the Directorate of Health Stan dards Programs."--^ 39/ Id. at p. 6. 40/ Id. at pp. 6-7. 41/ OSHA/NIOSH Task Force Report at p. 2. Among other things^ the Task Force suggested: 1. Use of work practices validated by the employer "in an initial determination, based on monitoring or theoretical calculations of maximum probable exposure"; 2. Use of work practices "which have been shown by past experience under equivalent conditions" to be effective; or 3. Use of "published work practices which have been shown, to OSHA's satisfaction,*1*2 t3o be effective. Id. at 11 (emphasis in original). 42/ Id. at p. 2 (emphasis added). DU 039166 DUP 0948239 20 III. EXPLANATION OF THE RECOMMENDED STANDARD Occupational nealth standards should serve a number of different objectives. They should, of course, be enforce able regulations which adequately protect workers from occupational health hazards. In addition, as contemplated by Executive Order 12291, they should impose practical requirements 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, if possible, occupational health standards 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 -- which would replace the current OSHA Asbestos Standard--^ in "construction work"--^ 43/ The Recommended Standard (Rec. Std.) contains a pro vision 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 amplication, but the provisions of the standard make clear than it applies to any workplace where there is occupational exposure to asbestos. Accord ingly, the Recommended Standard adds to the current standard a new paragraph which excludes construction and other nonfixed workplaces which would be covered by the proposed new standard. See Rec. Std., Appendix A at p. la. 44/ The definition of "construction work" in the Recommended Standard is precisely the same as is contained in OSHA's General Industry Standards. Compare Rec. Std. (b)(8) with 29 C.F.R. 1910.12. DU 039167 0948240 21 and other "non-fixed work operations"--^ -- achieves these objectives in four ways. First, it establishes a product classification program which would rank asbestos-containing products used in con struction operations according to their potential for releas ing airborne asbestos fibers in excess of the permissible exposure limits. Second, the Standard provides for validation and empiri cal field confirmation of product classifications, including the use of (a) objective data or exposure studies conducted by fully qualified testing laboratories, and (b) empirical field testing by OSHA inspectors and others to confirm the underlying data or tests. These procedures will help ensure that validated products have innate physical characteristics, or identified work practice techniques, that prevent unsafe exposures in construction work. Third, the Recommended Standard imposes regulatory requirements commensurate with the exposure risk presented by each product category. The Standard applies more strin gent requirements for higher-risk products, including full 45/ The Standard defines the term "non-fixed work operation" to refer to "jobs which do not involve regular assignment to a permanent work location or set of locations." Rec. Std. 1 (b)(9). The purpose of this provision is to include highly mobile non-construction operations such as oil well drilling, where asbestos exposures (from the use of drilling mud additives containing asbestos) may occur under circum stances similar to construction activities. DU 039168 DUP 0948241 22 compliance with the existing OSHA Asbestos Standard for pro ducts presenting the greatest risk of exposure above permis sible levels. And fourth, the Recommended Standard includes require ments for a Compliance Coordinator to provide centralized planning, supervision, training, cooperative labor-management interface, compliance monitoring, and other elements critical to ensuring that safe products and work practices are used and followed. These four elements of the construction industry asbes tos standard recommended here are discussed in greater detail below. A. The Product and Work Practice Classification System The categorization of asbestos-containing products used in construction operations 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" Products) which are defined according to a product's capacity, under reason ably foreseeable conditions of processing or use in con struction and other non-fixed operations, for releasing airborne asbestos fibers in excess of the permissible expo sure limits. As discussed later (Part III.C.), different regulatory requirements would apply to each category, both DU 039169 DUP 0948242 23 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 Product" is defined in Paragraph (b)(1) as a "product which, based on objective data, including where appropriate an exposure study, does not result in occupational exposure to airborne concentrations of asbestos fibers in excess of the permissible exposure limits under any reasonable foreseeable conditions of processing or use." Category A is the safest product classification and will generally include products 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 any reasonably foreseeable construction industry use. As discussed in Appendix B, these products are likely to include mastics, mechanical packings, oil seals, compressed gaskets, sealants and caulks, roof coatings, and electrical insulating paper. A "Category B Product" is defined in Paragraph (b)(2) as a "product which, based on objective data, including where appropriate an exposure study, does not, under any reasonably foreseeable conditions of processing or use, result in occupational exposure to airborne concentrations of asbestos fibers in excess of the permissible exposure limits when specified fabrication, installation or removal methods are used." In effect, Category B Products are DU 039170 DUP 0948243 24 capable of producing airborne asbestos fiber concentrations in excess of the permissible exposure limits under some reasonably foreseeable construction uses, but will not do so if the proper work procedures, tools or other safeguards are employed in those situations. Obviously, some regulatory controls must be applied to Category B Products to ensure that they are used in a way that prevents the release of excessive concentrations of asbestos fibers. Nevertheless, so long as the use of proper work practices, tools or other safeguards is ensured, most of the fixed-site requirements of the typical OSHA standard are unnecessary or redundant for these products. As dis cussed in Appendix B, AIA/NA, AACPP and their member com panies have developed data showing that work practices for two asbestos-containing products -- asbestos-cement pipe and asbestos-cement sheet -- can be validated under Category B of the Recommenced Standard. The last classification -- "Category C Products" -- covers products which do not fall into either of the two preceding categories. Rec. Std. f (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, Category C Products present the greatest potential for significant asbestos exposures, and accordingly require the most strin gent regulatory controls. DU 039171 DUP 0948244 25 B. Validation of Product and Work Practice Classifications For any product classification program to be success ful, it is, of course, necessary to provide adequate assur ances that products will be properly classified. The Recom mended Standard employs two devices for achieving this goal: (1) validation based on objective data or exposure testing conducted by qualified laboratories, and (2) empiri cal field confirmation by OSHA in connection with workplace inspections. The validation procedures of the Recommended Standard are modelled on what OSHA has called the "performance-based exemption provisions" of its Acrylonitrile (AN) Standard. 43 Fed. Reg. at 45778. In order to classify an asbestoscontaining product, there must exist "objective data, including where appropriate an exposure study," which is significant to support a "reasonable reliance" by the con struction employer that the use of the product -- including the tested work practices in the case of a Category B Product -- will not result in a violation of the permissible exposure limits under "any reasonably foreseeable conditions of processing or use." Rec. Std. IT If (b)(1), (2), (c)(1) & (d)(l).^/ Thus, the Recommended Standard, like OSHA's AN 46/ This formulation closely resembles the approach OSHA a3opted in the AN Standard, which exempts -- (Footnote 46 continued on next page.) DU 039172 DUP 0948245 26 Standard, requires the use of reliable objective data, and contemplates that an "exposure study" ordinarily will be conducted to support a classification. Because exposure studies normally will form the basis of product and work practice validations, special require ments are provided for such studies. The term "exposure study" is defined as "a study, conducted by a Certified Testing Laboratory, which shows with reasonable accuracy the concentrations of airborne asbestos fibers to which employees may reasonably be expected to be exposed under specific conditions of processing or use of an asbestos-containing product." Rec. Std. U (b)(7). Paragraph (b)(6) defines a "Certified Testing Laboratory" as "a laboratory accredited by the American Industrial Hygiene Association [AIHA] as qualified to test for airborne concentrations of asbestos fibers" using the method prescribed in the current OSHA asbestos standard. The use of laboratories which are accredited by AIHA provides an important safeguard against (Footnote 46 continued from previous page.) [m]aterials made from and/or containing AN for which objective data are reason ably relied on to demonstrate that the material is not capable of releasing AN in airborne concentrations in excess of 1 ppm as an eight (8)-hour time-weighted average, under the expected conditions of processing, use and handling which will cause the greatest possible release. 29 C.F.R. 1910.1045(a)(2)(ii) (emphasis added). DU 039173 DUP 0948246 27 - invalid or unsupported product classifications. In addition, the requirement that exposure studies provide "reasonable accuracy" is identical to the current OSHA monitoring require ment for asbestos (29 C.F.R. 1910.1001(f)), and is intended to require that an "exposure study" be designed in a way that provides the same degree of accuracy as under the existing monitoring provisions. While an "exposure study" ordinarily must be conducted, it is not necessarily the sole basis for classifying a product. As discussed above, exposure testing which identi fies exposure levels associated with all "reasonably fore seeable" uses of a product "with reasonable accuracy" might require in some cases a very large number of measurements to take account of the infinite variety of work procedures, product formulations, weather conditions, and other factors which affect exposures. Accordingly, as in the AN Standard,--^ the Recommended Standard permits the use of "objective data" 47/ See 43 Fed. Reg. at 45778: OSHA recognizes that employee exposure conditions can vary greatly between plants, even though they may be using the same materials. All that the stan dard requires is for the tester to specify the conditions of the testing, such as the temperature of heating, time of heating, distance of sampling probe from the surface of the material being tested, and the like. The duty is on the employer relying upon that data to show that his operating and exposure conditions are within the conditions of the testing. DU 039174 DUP 0948247 28 in addition to data from an exposure study 'to support a classification. Such "objective data" might, for example, identify "worst case" operations which, once tested and found to result in exposures below permissible levels, would provide a sufficient basis for the classification.--7. Thus, the "objective data" provision will permit limited testing which provides a "reasonably accurate" basis for concluding that permissible levels will not be exceeded under any reasonably foreseeable conditions. For much the same reason, the Recommended Standard would not necessarily require that "exposure studies" be conducted for each individual asbestos-containing product used in construction. Entire groups of products might be validated by a single exposure study if objective data shows a sufficient degree of physical similarity among the products. 48/ See 43 Fed. Reg. at 45778-79: A manufacturer of a material made from AN cannot anticipate all possible work place conditions to be encountered in the further processing of his material. How ever, in developing data on the release of AN from his material, he can provide useful data by performing his testing on a worstcase basis, without any ventilation to dilute the AN emissions. By doing so, and by specifying the other parameters of his testing procedure, the manufacturer can demonstrate the propensity of his materials to release their AN. A down stream employer who receives data from this testing must then analyze his work place conditions to determine if he can reasonably rely upon that data for exemp tion from the standard. DU 039175 DUP 0948248 29 or if testing is done on the product which presents the greatest exposure capacity. For example, all "asbestos-cement pipe" products might be classified based on a single exposure study of one of the products, if "objective data" shows that the specific product studied has the greatest capacity to release airborne asbestos fibers. Finally, the Recommended Standard does not require that an exposure study be conducted in all cases. For some asbestos-containing products, a chemical or structural analysis of how the asbestos fibers are encapsulated, bound, or altered by another material may be enough to show that the fibers will not be released in excessive amounts under expected conditions of construction industry handling, processing, or use.--'/ However, where a product is theore tically capable of releasing significant concentrations of asbestos fibers in foreseeable construction industry uses, 49/ For example, most asbestos-containing mechanical packings are (1) impregnated with a binding or lubricating material such as petroleum-based or vegetable oils, grease. Teflon, petroleum-based waxes, or natural and synthetic rubbers; (2) coated with materials such as mica, graphite, or petroleum-based oils and waxes; and (3) fabricated by the manufacturer into preformed die cut rings. The use of these products in construction -- i.e., simply installing the per formed packing rings into valve stems, pumps, and similar devices -- will not result in excessive asbestos exposures. Similarly, any asbestos in "black line" asphaltic coat ings is bound in a liquid mixture containing asphalt and fillers such as limestone or sand. The spray, brush or trowel application of these liquid coatings in construction work is inherently unlikely to yield excessive asbestos dust. DU 039176 DUP 0948249 30 an exposure study will be necessary, particularly if specific work practices are to be validated under Category B. Regardless of what kinds of data are used, the mere availability of such data is not enough to support a classi fication. The Recommended Standard requires that the sup porting data be of such quality or quantity to justify "reasonable reliance" by the employers using the products involved. Rec. Std. ff (c)(1) & (d)(1). The term "reason able reliance" is not specifically defined, but rather is left open for case-by-case determination. At a minimum, however, the employer must study the underlying data and tests, and compare the products and exposure conditions in his own workplace, in order to reasonably conclude that his operating and exposure conditions fall within the parameters of the validating data. In addition, the reputation of the validating laboratory, the employer's previous experience with the laboratory, the completeness of the data and the laboratory's specific conclusions would be relevant conside rations . 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 appli cable exposure limits were exceeded during an operation involving a Category A Product, or during an operation involving a Category B Product where the proper work prac tices were followed, an employer's ability to continue to DU 039177 DUP 0948250 31 rely "reasonably" on the validating data would be placed in doubt, depending on the accuracy and extent of the data pro vided by OSHA in each case. This feature of the Recommended Standard gives OSHA a vehicle for monitoring and verifying the correctness of classifications. C. Regulatory Requirements Tailored to the Degree of Risk Posed to Workers The Recommended Standard regulates occupational asbestos exposure in construction work in two general ways. First, the Standard imposes different regulatory controls on each product category, and tailors the applicable controls to the degree of hazard presented by each type of product or opera tion. These category-specific requirements are discussed in this section. Second, the Standard imposes certain generally applicable requirements -- i.e., provisions for a Compliance Coordinator, access to records, emergencies, and housekeep ing -- which are discussed in the next section (Part III.D.). Under Paragraph (c) of the Recommended Standard, Cate gory A Products are subject to the least regulation. Since Category A Products present little or no risk of excessive exposure, no category-specific requirements are imposed, and operations involving these safest of asbestos-containing products are subject only to the generally-applicable provi sions (Part III.D., below). Rec. Std. (c)(2). As discussed in greater detail below, the lesser regulatory controls on DU 039178 DUP 0948251 32 Category A Products creates a strong incentive for the development and use of products which will not lead to significant exposure. For Category B Products, the Recommended Standard requires employers to comply with the "fabrication, instal lation or removal methods" which qualify the products under Category B. Rec. Std. If (d)(1). The expression "fabrication, installation and removal methods" is defined in Paragraph (b)(4) to include any combination of engineering controls, work practices or administrative controls, housekeeping, and respiratory protection. While work practice controls are expected to be the predominant mode of compliance because of the special features of the construction industry, 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 Recom mended Standard unless no other control method is feasible for a given operation. Rec. Std. f (b)(4). Employers claiming exemptions for Category B Products must, of course, take all practicable steps to ensure that validated work practices and other protective measures are, in fact, used. Rec. Std. IT (d)(2)(i). Several additional requirements are imposed to ensure the use and effectiveness of the validated work practices and other protective measures. The employer is required to provide, before a given job DU 039179 DUP 0948252 33 begins, the training and instruction needed to enable employees to use the correct work practices. Rec. Std. IF (d)(2)(ii). Further, manufacturers of Category B Products are required to include a product label warning that vali dated work practices, tools or other measures should be used. Rec. Std. f (d)(3). In addition, several of the generally applicable provisions detailed in Part III.D., below -- particularly those for a Compliance Coordinator to oversee the implementation of safe products and work practices -- will go a long way toward ensuring that employers claiming exemptions for Category B Products follow the fabrication, installation, or removal methods that are essential for the safe use of such products. Rec. Std. II (d)(2)(iii) & (iv). For Category C Products, which, by definition, pose the greatest potential for exposure, the current OSHA asbestos standard would apply in full. Rec. Std. IF (e). As discussed above, Category C Products 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 Products to provide a strong incentive for developing safer products and work practices. DU 039180 DUP 0948253 34 It is important to note that the regulatory status of Category A and B Products is expressed in the form of exemp tions from the current standard. See Rec. Std. HI (c)(1) & (d)(1). 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 Products, employers are subject to citation for failing to follow the validated work practices and training requirements, even if the classification criteria have been satisfied. Rec. Std. fl (d)(2)(i). D. The Compliance Coordinator and Other Generally Applicable Requirements In addition to the category-specific provisions described in Part III.C., above, the Recommended Standard includes a number of general requirements that are not tied to a single product category. These provisions are designed in large measure to ensure that employers who decide to take advan tage of the regulatory incentives offered under the Standard for Category A and B Products make sure that the proper products and work practices are in fact used. The most important of these general provisions is con tained in Paragraph (f) of the Recommended Standard, which DU 039181 DUP 0948254 writfeiUfl BMlBffiajhializ;. - 35 - requires employers using Category A or B Products to desig nate a "Compliance Coordinator" to assume responsibility for ensuring that uncertified products or work practices are not used. The Compliance Coordinator must be a "competent person" with the training, education or experience needed to oversee or carry out any aspect of the employer's program for complying with the Standard. Depending on the nature or scope of the operations involved, one or more additional persons may be appointed to act as the Coordinator' s "designees" on particular phases of a project, or to carry out specific aspects of the Coordinator's duties. The requirement for a Compliance Coordinator fills an important gap in OSHA's traditional approach to regulating health and safety hazards in construction work by centraliz ing the planning and monitoring of compliance activities on complex projects. In addition, a Compliance Coordinator requirement provides a much-needed focal point for coopera tive labor-management efforts to develop sensible health and safety programs appropriate to the nature and scope of the specific project involved. The flexible, cooperative approach for implementing the performance-oriented certification program recommended here is better than the customary OSHA practice of enacting rigid and detailed nationwide compliance specifications that are insensitive to the needs of particular employers and employees. DUP 0948255 DU 039182 WALL .iiMiil::, I: agjilijiiii..!./aiiallaHia wyi, _uaiML - 36 - The Standard includes several additional general require ments. First, regardless of which product category is involved, employers must satisfy the "emergency" provisions of the existing standard, requiring the use of respirators in the event of an unexpected and massive release of asbestos dust. Rec. Std. ff (c)(2)(ii) & (d)(2)(iv). This provision is needed because such unexpected releases, by their very nature, would not be included in the "reasonably foreseeable circumstances" under which Category A or B Products are validated. Second, as discussed in greater detail in Appendix B (pp. 3b-4b), construction 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 applies to the owner of that facility. However, construction workers could be exposed to excessive concentrations of asbestos dust which has accumu lated in normally inaccessible places such as on pipes and ductwork. Accordingly, Paragraph (g) makes the "housekeep ing" provisions of the current standard applicable in those special circumstances, even where the employer is using only Category A or B Products. Lastly, Paragraph (h) requires construction employers, at the request of OSHA or NIOSH, any employee, or an employee's designated representative (including a certified collective bargaining agent), to make available any objective DUP 0948256 DU 039183 ---- 1. ' iiiiSHlJMiiiiiiiillllHl^^^^^^^... :aaafii 37 data and exposure studies on which the employer relies, together with materials relating to the training of employees in the use of validated work practices and any other materials relating to the activities of the Compliance Coordinator. This records-access provision will not only assist OSHA's enforcement efforts, but in addition, it allows for external review of validating studies by OSHA, NIOSH, unions and others. IV. ADVANTAGES OF THE RECOMMENDED STANDARD OVER THE TRADITIONAL OSHA FIXED-SITE HEALTH STANDARD The core of the recommended standard for occupational asbestos exposure in construction is the same "reliable work practice" concept endorsed by the Construction Advisory Committee and the OSHA/NIOSH Task Force as the best answer to the enormous difficulties the construction industry faces in complying with the current asbestos standard, and, by analogy, with other OSHA health standards. As discussed below, the Recommended Standard would -- (1) provide a far more practical and costeffective system for protecting workers from unsafe asbestos exposures; (2) increase voluntary compliance and alleviate OSHA's enforcement burdens; and (3) establish strong incentives for new efforts -- including labor-management cooperation -- to develop and implement safer products and work practices. DU 039184 DUP 0948257 38 A. Cost-Effectiveness Both the Occupational Safety and Health Act--/ and President Reagan's Executive Order on Improving Government Regulations--^ require that OSHA standards be feasible and cost-effective in the sense that they are practicable and impose only those regulatory controls that are necessary to achieve a safe working environment. As the previous discussion makes clear, many of the components of the traditional OSHA health standard contri bute little to worker health in the construction industry. At the same time, there is no reason to believe that many of 50/ The Occupational Safety and Health (OSH) Act requires tKat health standards be both "feasible" and "reasonably necessary or appropriate to provide safe or healthful employment." OSH Act 3(8) & 6(b)(5), 29 U.S.C. 652(8) & 655(b)(5). As recently construed by the Supreme Court, these provisions not only require that occupational health standards be reasonably achievable in an economic and tech nical sense, but they also proscribe regulatory requirements which are unnecessary to achieve the necessary level of health protection. See American Textile Mfrs. Inst. v. Donovan, 101 S. Ct. 2478, 2493 n.32 (1981). 51/ Among other things, the Executive Order requires, "to tKe extent permitted by law," that -- among alternative approaches to a given regulatory objective, the alternative involving the least net cost to society shall be chosen. Executive Order 12291, 2(d), 46 Fed. Reg. 13193 (February 19, 1981). DU 039185 DUP 0948258 - 39 - the small, transitory employers in the construction industry--^ are likely to have the personnel or financial resources to meet any of these fixed-site requirements. Indeed, the National Constructors Association has stressed that the routine adoption of such requirements would "place an intoler able economic and logistical strain on the construction industry -- particularly small contractors." NCA added that "the costs are so extreme as to threaten the continued exis tence of many small and medium size construction companies throughout the nation, without a demonstration of the neces sity for such rigid health controls. In short, OSHA's present approach imposes impractical requirements that would yield little real health benefit even if they could realistically be satisfied. The Recom mended Standard would eliminate these difficulties by allow ing construction employers to use simple and inexpensive work practices that have been validated to be safe in the sense that exposures in excess of OSHA's permissible limits will not occur in any reasonably foreseeable circumstance. Thus, the Standard meets the requirements of the OSH Act and Executive Order 12291 by providing good health protection to 52/ According to OSHA's feasibility contractor for asbestos, as much as 70% of construction firms are sole proprietorships averaging 1 to 4 employees. Draft RTI Report at p. 11-35. 53/ Statement of Fred Graham (NCA), OSHA Docket H-60 [Cancer Policy], Ex. 125 at pp. 4, 5. DU 039186 DUP 0948259 40 workers without imposing the ineffective but costly fixed- site requirements of the customary health standard. To be sure, the Recommended Standard departs significantly from OSHA's historical regulatory practice. But OSHA has on a number of occasions limited or modified its traditional approach in an effort to avoid standards that impose sweeping requirements without any significant or commensurate health gain. OSHA's current labeling and waste disposal requirements for asbestos-containing materials, for example, effectively recognize that not all such materials pose an exposure threat which is significant enough to warrant full-scale regulatory controls.--/ Other OSHA standards -- such as those for inorganic arsenic--^ and cotton dust^^ -- incorporate similar 54/ The asbestos labeling requirement 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 require ment of OSHA's current asbestos standard contains an almost identical exemption. 29 C.F.R. 1910.1001(g)(2)(i) and (h)(2). 55/ OSHA's Inorganic Arsenic Standard exempts workplaces wEere the substance is present in only small amounts because "[i]t is . . . 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. at 19612 (May 5, 1978). 56/ OSHA's Cotton Dust Standard contains a series of exemp tions for operations where application of the standard would achieve little at great cost. Specifically, the Cotton Dust Standard exempts: (i) maritime workers, because the "limited duration of exposure makes it unlikely that cotton dust (Footnote 56 continued on next page.) DU 039187 DUP 0948260 : ILliUlli .^i-aMlliir'-ai^aaiaJfc- tsmm -Al limitations designed to prevent unduly broad application of monitoring, medical surveillance, and other ancillary requirements. OSHA's Acrylonitrile (AN) Standard, which more closely resembles the standard recommended here for asbestos exposure in the construction industry, also reflects an effort to adapt the traditional regulatory approach to unique circum stances. The AN standard imposes the traditional fixed-site requirements on manufacturers of products containing AN, but exempts downstream processors and fabricators of such pro ducts 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 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 (Footnote 56 continued from previous page.) exposure is significant for an appreciable number of the workers handling water borne shipments of cotton"; (ii) workers handling "washed cotton," because of the "effec tiveness 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 environ ments and possibilities of control." 43 Fed. Reg. 27381-82 (June 23, 1978). DUP 0948261 DU 039188 42 and OSHA, and would not be reasonable in light of the degree of exposure involved." 1978). 43 Fed. Reg. 45776 (October 3, Significantly, the Recommended Standard goes beyond the AN standard in protecting worker health. First, it requires that product and work practice exposure testing be performed only by fully qualified testing laboratories. Second, it requires that objective data and exposure studies provide a "reasonable assurance" 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 concentration of 0.5 fibers/cc will routinely produce sample counts of 2.0 fibers/cc or more."--^ Consequently, the "reasonable accuracy" requirement will not be met in practice unless the products and work practices being tested regularly produce measurements far below the permissible exposure limits, adding a significant extra margin of worker safety. B. Improved Voluntary Compliance and Enforceability Because of the impractical demands placed on construc tion employers by traditional health standards, OSHA could 57/ Comments of Johns-Manvilie, OSHA Docket H-033 [Asbestos], Ex. 3-185 at ex. D, p. 42. DUP 0948262 DU 039189 43 not hope to achieve widespread compliance with these provi sions, even if it had unlimited enforcement resources. OSHA does not, of course, have such resources, and accordingly any construction industry health standard is administratively feasible only if (1) a good degree of voluntary compliance can be expected, and (2) the standard can be policed without unduly consuming available OSHA enforcement resources. The Recommended Standard is designed to achieve both of these goals. Because it imposes simple and economical requirements on construction employers and avoids the unncessary and expensive provisions of the traditional standard, more voluntary compliance can be expected. Moreover, by providing for centralized compliance monitoring by employers and establishing a focal point for labor-management coopera tion, the Compliance Coordinator provision of the Standard further increases the likelihood of voluntary efforts to eliminate unsafe products or work practices. Moreover, the Recommended Standard will ease the tremen dous 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 58/ OSHA estimated in 1975 that three to five million construction and shipbuilding workers may be exposed to asbestos dust. 40 Fed. Reg. 47653 (October 9, 1975). An OSHA contractor has estimated the number to be about 2.3 million. RTI Report at p. 11-27, Table I1-3. DU 039190 DUP 0948263 44 cases, OSHA inspectors may have to do nothing more than determine whether the proper products and work practices are being used. This task is much simpler and less time-consuming and expensive than under the current standard, where exposure monitoring may have to be conducted for each operation and the employer's 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 a product 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. C. Built-in Incentives for the Development and Use of Safer Products and Work Practices Apart from providing good health protection in a manner that is cost-effective, easily-enforced, and likely to increase voluntary compliance, the Recommended Standard also creates strong incentives for the development of safer products and work practices. Under the current standard. DU 039191 DUP 0948264 45 construction employers cannot legally avoid fixed-site requirements 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 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 power ful incentive for the development and use of products or work practices which qualify for Category A or B classifica tion. 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 excessive asbestos exposure. Second, the current incentive for across-the-board substitution of inferior non-asbestoscontaining products of unknown potential hazard would be eliminated and replaced with a scheme which encourages the use of the best construction materials which do not threaten the health of workers. V. 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 monitoring, medical surveillance and recordkeeping, as well as other requirements DU 039192 DUP 0948265 46 designed for fixed-site factory jobs, is simply not feasible. Nor do many of the requirements of the customary OSHA stan dard contribute appreciably to the health of construction workers. The better approach is to substitute a regulatory scheme -- like the one recommended here -- that strongly encourages the use of products and simple, inexpensive 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 develop ment and use of safer products and work practices, and considerably eases OSHA's enormous enforcement burden. Accordingly, this Recommended Standard plainly meets the objectives and requirements of the OSH Act and Executive Order 12291, and should therefore be carefully considered by OSHA in developing an effective occupational health strategy for construction and other non-fixed work operations. DU 039193 DUP 0948266 APPENDIX A <jTr--. >- $''f DU 039194 D C TJ O Na-CtUo>OJ RECOMMENDED STANDARD FOR OCCUPATIONAL ASBESTOS EXPOSURE IN CONSTRUCTION WORK 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. However, this Section does not apply to construction work or other non-fixed work operations within the scope of Section 1910.1001a, or to working condi tions of employees with respect to which other Federal agencies exercise statutory authority to prescribe or enforce standards or regulations affecting occupational safety or health." * A * sfe "k 2. A new Section 1910.1001a is added as follows: "1910.1001a Asbestos Expoa^-re 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 con taining asbestos are processed, used, transported, packaged, repackaged, or released. DUP 0948268 DU 039195 2a "(b) Definitions. "(1) "Category A Product" refers to an asbestos-containing product which, based on objective data, including where appropriate an exposure study, does not result in occupational exposure to airborne concentrations of asbestos fibers in excess of the permissible exposure limits under any reasonably foreseeable conditions of pro cessing or use. "(2) "Category B Product" refers to an asbestos-containing product which, based on objective data, including where appropriate an exposure study, does not, under any reasonably foreseeable conditions of processing or use, result in occupational exposure to airborne concentra tions of asbestos fibers in excess of the permissible exposure limits when specified fabrication, installation or removal methods are used. "(3) "Category C Product" refers to an asbestos-containing product which is neither a Category A Product nor a Category B Product. "(4) "Fabrication, Installation or Removal Method" means any method or combination of methods for controlling occupational exposure to airborne concentrations of asbestos fibers, including engineering controls, tools, equipment, work practices, housekeeping, task assignment strategies, and respiratory protection; provided, however, that a fabrication, installation or removal method may not DU 039196 DUP 0948269 3a include respiratory protection unless no other method for controlling occupational exposure to airborne concentrations of asbestos fibers is feasibile. "(5) "The Permissible Exposure Limits" means (i) an eight-hour time-weighted 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. "(6) "Certified Testing Laboratory" means a laboratory accredited by the American Industrial Hygiene Association as qualified to test for airborne concentrations of asbestos fibers using the membrane filter method specified in Paragraph (e) of Section 1910.1001. "(7) "Exposure Study" means a study, conducted by a Certified Testing Laboratory, which shows with reasonable accuracy the concentrations of airborne asbestos fibers to which employees may reasonably be expected to be exposed under specified conditions of processing or use of an asbestos-containing product. "(8) "Construction work" means work for con struction, alteration, and/or repair, including painting and decoration. "(9) "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 permanent work location or set of locations. DUP 0948270 DU 039197 - 4a "(10) All other terms used in this Section shall have the meaning prescribed in Section 1910.1001 and in Section 3(8) of the Act, 29 U.S.C. 653(8). "(c) Category A Products. " (1) Any employer who reasonably relies on objective data, including where appropriate an exposure study, which shows that an asbestos-containing product is a Category A Product, is exempt from the provisions of Section 1910.1001 as they apply to operations where such product is processed or used, and shall comply with the provisions of this Paragraph with respect to such operations. "(2) Employers whose operations involve the use of Category A Products shall: (i) comply with Paragraphs (f), (g), and (h) of this Section (relating to Compliance Coordinators, housekeeping, and access to records); and (ii) comply with Paragraph (d)(1)(iii) of Section 1910.1001 (relating to the use of respirators during emergencies). "(d) Category B Products. "(1) Any employer who reasonably relies on objective data, including where appropriate an exposure study, which shows that an asbestos-containing product is a Category B Product, is exempt from the requirements of Section 1910.1001 as they apply to operations where such product is processed or used, and shall comply with the provisions of this Paragraph with respect to such operations. DU 039198 DUP 0948271 - 5a - "(2) Employers whose operations involve the use of Category B Products shall: (i) take all practicable measures to ensure the use of the fabrication, installation or removal methods which qualify such products as Category B Products; (ii) ensure, prior to the commencement of any operation where such fabrication, installation, or removal methods must be used, that all employees involved in such operation have been specifically instructed concerning the proper use and procedures of such fabrication, installa tion, or removal methods; (iii) comply with Paragraphs (f), (g) and (h) of this Section (relating to Compliance Coordinators, housekeeping, and access to records); and (iv) comply with Paragraph (d)(1)(iii) , of Section 1910.1001 (relating to the use of respirators during emergencies). "(3) Any manufacturer of a Category B Product who has actual knowledge of the validation of such product as a Category B Product shall include a product label that states: "Follow Recommended Fabrication, Installation or Removal Method." "(e) Category C Products. 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 DU 039199 DUP 0948272 iHiMI--) - 6a - apply to any operation within the scope of this Section which involves the processing or use of Category C Products. "(f) Compliance Coordinator. "(1) Any employer who intends to rely on Paragraphs (c) or (d) of this Section (relating to Category A and Category B Products) shall designate a competent person to serve as Compliance Coordinator; such employer may appoint one or more additional competent persons to assist the Compliance Coordinator, to carry out one or more of his duties, or to act in the place of the Compliance Coordinator for specific phases of a project. "(2) The Compliance Coordinator shall be responsible for taking all measures necessary and appropriate for ensuring compliance with the requirements of this Section. "(g) Where an operation involving the processing or use of Category A or Category B Products is located in a facility which manufactures, processes or fabricates products containing asbestos, Paragraph (h) of Section 1910.1001, relating to housekeeping, shall apply to such operation. "(h) Upon request by any employee, any employee's designated representative (including a certified collective bargaining agent), the Assistant Secretary, or the Director, the employer shall make available, in accordance with the procedures set forth in Section 1910.20, the following: (i) any objective data or exposure studies on which the employer relies pursuant to Paragraphs (c) or (d) of this Section; or DU 039200 DUP 0948273 1 7a (ii) any materials relating to the activi ties of the Compliance Coordinator, or his designees, under Paragraph (f) of this Section. DU 039201 DUP 0948274 .alWMBMajitjaiiaBa vlewaai; APPENDIX B DU 039202 DUP 0948275 APPENDIX A Preliminary Assessment of How the Recommended Asbestos Standard Can Successfully Be Implemented in Construction and Other Non-Fixed Work Operations DU 039203 DUP 0948276 jaK-Miaiyi.,11; MBfailiiaifci aatHia: TABLE OF CONTENTS Page Appendix: A Preliminary Assessment of How the Recommended Asbestos Standard Can Successfully Be Implemented in Construction and Other Non-Fixed Work Operations ........................................................ lb Introduction: Potential Asbestos Exposure in Construction and Other Non-Fixed Work Operations ............................................... 3b A. Recommended Work Practice Procedures for Asbestos-Cement Pipe 8b 1. Sampling Methodology and Opera tions Sampled for AsbestosCement Pipe ............................................. 3 6b 2. Methods ...................................................... 37b 3. Operations Sampled ............................. 38b B. Recommended Work Practice Procedures for Asbestos-Cement Sheet ......................... 47b DUP 0948277 DU 039204 lb APPENDIX 'A Preliminary Assessment of How the Recommended Asbestos Standard Can Successfully Be Implemented in Construction and Other Mon-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 cractices, 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 asbesto" .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 its products and its knowledge of their DU 039205 DUP 0948278 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 two succeeding sections of this Appendix contain detailed quantitative documentation showing that work practices for two asbestos-containing products commonly used in construc tion and other non-fixed jobs -- asbestos-cement pipe and asbestos-cement sheet -- can in fact qualify under Category B of the Recommended Standard. More specifically, 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 both oroducts can be validated under Category B of the Recommended 1/ Standard. 1/ The exposure data presented in the succeeding two sections 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 concentration) 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 below are so uniformly low that the products and work practices discussed can surely meet the classification criteria for Category B. DU 039206 DUP 0948279 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 DU 039207 DUP 0948280 Blglsl ii iiiflilMi.iriia: -alil^aBiiiiliIl - 4b - airborne fiber concentrations in excess of mandated levels. As detailed above (pp. 21-22), the housekeeping and emergency provisions of Paragraph (f) 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 work practices which would qualify under Category B of the Recommended Standard. DU 039208 DUP 0948281 5b The third health hazard situation, of course, involves the fabrication and installation of asbestos-containing construc 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. The asbestos fibers in asbestos-cement products, asbestos-roofing and pipeline felts, drilling muds, paints, and roofing mastics are bonded into or encapsulated by a matrix material, saturant, impregnant or coating. The fibers seldom are released; and the operations which may cause their release 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, friction materials, and asbestospaper products comprising approximately one-half of the total consumption: DU 039209 DUP 0948282 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 cou./.derable experience with the use of these products in construction operations, its familiarity DUP 0948283 DU 039210 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 y products: Mastics and Black Line Products Roofing Felt Roofing Felts Mechanical Packings Oil Seals Compressed Gaskets Sealants and Caulks Electrical Insulating Paper In the two suceeding sections of this Appendix, de tailed 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 are met for two other products: asbestos-cement pipe and asbestos-cement sheet. 2/ Source: Johns-Manville Corporation DU 039211 DUP 0948284 1 DU 039212 DUP 0948285 - 8b - Recommended Work Practice Procedures for Asbestos-Cement Pipe DU 039213 DUP 0948286 9b In order to reduce the generation of airborne concen trations of asbestos during the installation of A/C pipe, AACPP designed a field manual containing specific work prac tices for use with its products. AACPP 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, AACPP 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 e. Cutting with hammer, chisel and rasp DU 039214 DUP 0948287 10b 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 cond^-ted. 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 DU 039215 DUP 0948288 lib 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 in the pages below. The following tables summarize the results EEH obtained during its validation tests. DU 039216 DVJP 0948289 12b 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 IMinutes) lDuring 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 <0.10 42.10 35.50 0.30 0.15 <0.10 3.83 0.23 0.20 0.18 <.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 ::d 49.20 59.70 0.87 0.22 0.18 2.23 0.18 0.27 DUP 0948290 o *--f Vo DU 039217 ~BtaiiiriS liflMaateia&ffin 't?1 iagwrir aMliailSIlI .........................................................................................M Operation - 13b 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 5b. Hole Cutting with Drill, Hammer & Rasp 0.44 0.23 6a. Dry Tap with Mueller J Tool <0.10 6b. Tapping Operations with Mueller B-100 7. Coupling Removal <0.10 7a. Removal cf Coupling with Hammer & Chisel ND <0.10 4 0.10 0-.23 0.13 1.65 0.22 <0.10 ND <0.10 0.11 ND 0.30 <0.10 0.13 <0.10 0.38 0.10 0.13 <0.10 o r--1 VO o H VO 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 y cutting with abrasive discs. As indicated in the summary data, significant peak exposures can result from their use. y The use of water on specially adapted abrasive disc cutting equipment can reduce asbestos fiber exposures below 2.0 fibers/cc (TWA), as documented by the United Kingdom Health and Safety Execut''re. Similar results could not be dupli cated in the EEH study. DU 039218 14b 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 riot 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 A/C Pressure 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 ND ND 0.25 <0.10 < 0.10 {0.10 ND 0.16 <0.10 <0.10 ND 0.11 <0.10 <0.10 <0.10 <0.10 DUP 0948292 DU 039219 15b Operation Table VIII Continued A/C Sewer Pipe Operator Helper A/C Pressure Pipe Operator Helper 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. C6Z8V60 O c -o DU 039220 16b 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 HD 3. Cutting Operations 3a. Hack Saw *40.10 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 40.10 16-inch pipe ND ND-40.10 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. DUP 0948294 DU 039221 ----awBn r-i ^i5^11aiiSBigffta; 1iss*?! - . tkMkmrn"ijiilifUi - 17b - 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 O r--1 O Q 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, AACPP 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." AACPP 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 D C TJ CoSOk N00) cCnO DU 039222 18b 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. DU 039223 DUP 0948296 DUP 0948297 DU 039224 I t -20b - Products and Operations Types of .VCFipe Products covered by these work practices indude: "Class" Pressure Pipe "Transmission" Pressure Pipe Pressure Sewer Pipe Gravity Sewer Fipe Building Sewer Pipe Storm Drain Pipe Perforated Undardrain Pipe j 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 iI DU 039225 DUP 0948298 21b > DUP 0948299 uais. AiC F.o Produca: Ail Size Pangs: All 'Sxsofuz* data not cunrodv ivauaei*. 3*ccnc*ndaoan oaaad on closure data far opanoona b*iivd a ' comeiradf*. ! DU 039226 I I * I DU 039227 DUP 0948300 23b Cutting Snap Cutting Equipment !I Seep cutters or "squeeze and pop" equipment operates by means oreitting wheels mounted in a chain wrapped around the pipe beael. Hydraulic pressure, applied by means or a remote eieerie manually-operated pump, simultaneously squeezes the cut- deg wheels into the pipe wail until the cut is made. AJC Pipe Products: Ail Sea Range: Pressure Pipe--3' through 24' Pressure, Gravity and 3uiiding Sewer: Storm Drain: Air, Eecrical and Telephone Due:--3' through 36' i Ii f DU 039228 DUP 0948301 - 24b - Machining Field Lathe-Manual tt.: Stanual field lathes are designed to snd-chm and re-machine smgh pipe barrels to facmry-machined end profiles. The lathe consists of an adjustable, seif-aligning arbor inserted into the pipe bare (which acts as a mandrel upon which the turning bandit operates), a screw-ted turning frame, oroide machining blades and manual (hand or ratchet) turning handles. &C Pipe Produca: All Sze Range: .Ail li1 DUP 0948302 DU 039229 - 25b - r*' OVJP 0948303 ! DU 039230 26b Machining Rasp-Manual* jj Short lengris of AjC pipe (MHIi it MOA's) can be cut for pice closures, repairs and to locate fittings exacdy. Field cut ends stay be rebeveied with a coarse wood rasp to form a taper approximat ing die same profile is the factory-beveled end. AiC Pipe Products: Ail Sine Range: All 'Exposure daa not currency svwUbls. Steocunssbabsn based cn exposure baa for opriaanj beiievtd a o* compilable. DU 039231 DUP 0948304 Hole Cutting Shell Cutters 27b - Ji i' L i i ' ;i For field cortnecaons into A/C pipe, dean, even entry cuts may r be accomplished by means of* sheil cutting equipment. Shesl cutters consist of a hole cutter housing mounted on the pipe, a carbide or diamond-tipped hole cutter and a manual ratchet, pneumatic, eiemric or gasoline drive to power the catting head. When cutting holes in A/C pipe produms, all dust and cuttings should be removed tram the pipe or duct interior after the cutting operation. Removal may be accomplished by Cushing with wa r ter, wet moooing or vacuuming mar to placing in service. DO NOT BLOW OUT WITH COMPRESSED AIR OR DRY SWEEP. A/C F.pe Produces: Pressure, Gravity and 3uilding Sewer: Air Duct Size Range: Ail DUP 0948305 DU 039232 - 28b _ Hole Cutting Drill and Rasp* F:eid conneeuons nay be made with a heavy duty eiectsc drill and rasp. Using a carbide-tipped drill, a series of dcseiy-spacad holesare erst drilled around the hoie outline. The disc is knocked free with a hammer and the edges of the hote are dressed 'with a coarse wood rasp. When cutting hoies in AiC pipe products, ail dust and cuttings should be removed from the pipe or duct interior after the catting operation. Removal stay be accomplished by flushing with water. wet mooping or vacuuming otior to piaeng in service. CO MOT BLOW OUT WTIH COMPRESSED AIR OR DRY SWEEP. AjC Pipe Products: Pressure, Gravity and 3uilding Sewer Air Duct Size Range: Ail S^osure data not oarsr.dy available. Seramsttndaean based an exposure data :'er operasona betieved to be comparable. ; 1t :I 11 !;j jjj `j '! if ! ! '4 if ;1 (f DU 039233 DUP 0948306 '. \......................................... ' . ... - 29b - Hole Cutting Chisel and Rasp IS! I' { '{ i 11 | j j | ! Hole may be cut into AiC pipe with a hammer and chisel. The edge ai a plumber's-wood chisel is used a cut completely around the hole outline, about a Vi* bom the prescibed line. The opera* tibn is repeated and the cut deepened until through. The edges of the hole'are then dressed with a coarse wood rasp. When cutting holes in A/C pipe produca. ail dust and cuttings should be removed from the pipe or ductinterior after the cutting operation. Removal may be accomplished by flushing with waSet, wet mopping or vacuuminz prior to piaeng in service. CO not blow bur with compressed air or dry sweep. : A/C Pipe Produca: Pressure. Gravity and 3uilcing Sewer AirDuct ! Stze Range: All I DU 039234 DUP 0948307 30b Tapping Non-Pressure (!: It. V Uj it! ill ill I II |; .Hl!i iH N'on-pressure or "dry" tapping for service connectors cray be perforated in or above the trench. The equipment is affixed to the pipe by means of a chain yoke. Separate drills and taps or a combination tcoi drills and taps the pipe wail. Corporation stops or other connections may then be affixed to the pipe. To minimize (a) the fouling of valves, regulators, meters, ere with chips and (b) unnecessary addition of asbestos to drinking water, all dust and cuttings shouid be removed from the pipe interior by flushing with water, wet mooning or vacuuming prior to placing in service. DO NOT 3LOVV OUT WITH COM PRESSED Aa OR DRY SWEEP. Ai'C Pipe Produca: Pressure Pipe Size Range: Ail -ScposuiwdaanotctistrtfyavauMl*. JUe3cuatndae8nis*donco*udaa :or opficcfa bcikv*d to b csensarabl*, l- "{ ij DUP 0948308 DU 039235 Tapping Pressure* 31b Pressure or "wet" tapping tor service connections is performed in the trench while the pipe is under pressure. The equipment (manual or power drivers) is affixed to the pipe by means cf a chain yoke. A combination boring and inserting bar drills and taps die pipe wail and inserts a corporation step or pipe plug. The pressure chamber, which protects against water' leakage, aiso catches the asbestos-cement chips, so this is essentially a dustfree operation. To "TrrnwriTM (a) the fouling or valves, regulators, meters, etc. with chips and (b) 'unnecessary addition of asbestos to drinking water, provisions should be mace cor downseeam flushing or use of tapping equipment with positive purge or "blow-off' features. AiC Pipe Produca: Pressure Pipe Size Range: All 'Expense dan net oarendy available, Kacoosiesidacon baaed on ersoiure data far aoeasoia believed a be essaanbie. f DU 039236 Dy p 0948309 " . I........................- - ' - - * - 32b - DUP 0948310 Txoataz* can not c--.ai'.-v ivulablt. X*satiur.rdicon sud on etsooun dia ir acncons otuvd to 'o* coor.ouacl*. ,i -' j DU 039237 lit ,:jaalaai :iaa: iiiaiafE^illEiHjiiaLiiiBiMm-iiasigiagCr i - 33b - Housekeeping and Waste Disposal Housekeeping is an important 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 or others. EQUIPMENT: All external surfaces of equipment should be maintained free of dust accumulations that might, if dispersed, ceate 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 p*ipeilne. Where operations are performed at a central location snch 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-diabie forms. These forms may be used in the trench as supports for cast iron fittings and valves, as appropriate. Otherwise, chips and cuttings should be collected in sealed bags or dosed containers Impermeable to asbestos dast. Loose materdl should never be drj saept. When vacuum equipment is available, it should be used. Water or other dost suppressants should be applied in those circum stances where sweeping is unavoidable. DO NOT 3LOW WASTE MATERIAL WITH COMPRESSED AIR. No visible emissions to the atmosphere may resuit from the collection, processing, packaging, transporting or de position of any asbestos-containing material. Wastes should be disposed at a site operated in accordance with the requirements* or applicable national, state or local laws. DU 039238 DUP 0948311 1 - 34b - 1 NON-RECOMMENDSD PRACTICES Section 2 Non-Recommended Work Practices * Cutting Any A-C Pipe Using Abrasive Disc-0ry Tools. > i. ri* L Pcwer-dnvea saws with aorasive discs (masonry blades) should sot be used for dry caning or beveling A-C pipe. Abrasive disc caners produce soncentra- dons of airborne dust that exceed OS HA permissible levels. Tnis work practice is therefore specifically not recommended. 1 fi' * This recommendation was excerpted from the work practices || manual prepared by the American Water Works Association, fir D C TJ 3i oto tk C0O0 to Du 039239 35b WORK PRACTICES FOR AS3E3T0S-C2MENT 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 OS HA permissible levels. This work practice is therefore specificaUy not recommended. This recommendation was excerpted from the work practices manual prepared by the American Water Works Association. DU 039240 DUP 0948313 SaaiSBil i aaanimfI: - 36b - Sampling Methodology and Operations Sampled for Asbestos-Cement Pipe DU 039241 DUP 0948314 , is- ,.,4JMa BsUUll - 37b - 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 pimps 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. DUP 0948315 DU 039242 38b 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 guide it into place for coupling. Two 1 1/2 DU 039243 DUP 0948316 39b 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 eguipment. 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. DU 039244 DUP 0948317 Lilaiaii. iiailtin - 40b - 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 DU 039245 0 UP 0948318 !|L*_ - 41b - 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 O c -o DU 039246 0948319 MiHBi--iwHia aiisBfet a, if1, j AaiMat &e&. - 42b - 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 DUP 0948320 DU 039247 43b 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. DU 039248 DUP 0948321 44b 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 O c O 0948322 DU 039249 amim 3aaKBillia!::;8aiagiiE3alS 1" ? -y^cisegragM - 45b - 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 same procedure DUP 0948323 DU 039250 S-gfWlaiijgjhi rr jinjiiiMaa bus -i Mjiai itm.imm - 46b - 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. DUP 0948324 DU 039251 DUP 0948325 DU 039252 47b Recommended Work Practice Procedures for Asbestos-Cement Sheet DU 039253 DUP 0948326 iBswaWiiiwlMi:aiiiiiBiBiiiliiMaaai flBiiapr'waiir.;;-MBiraiaiiiaa ams - 48b - 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. DUP 0948327 DU 039254 - 49b - 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. DU 039255 DUP 0948328 50b Table XV Air Monitoring Test Results Using Circular Saw and Drill Equipment Test Conditions* Test Duration Material Fabricated Drill with dust pickup shroud 1/4 inch mason ary bit, opera ted at full speed. Drilled downward through horizontal board 40 min Quantity/ IZE Quantity Minute 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 inch 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 DUP 0948329 DU 039256 51b RECGiii'BDED WORK PRACTICES FOR FIELD FA3RI 'ion OF 1w ( DU 039257 O C -o o tO 00 w w o 52b 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. DU 039258 DUP 0948331 m an n 9S Shirnir.c. - 53b - f I / A/C sheer is shipped front the'factory with clean surfaces , Sene-rally 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. DUP 0948332 DU 039259 54b Cutting - Flat Sheets Circular Saw Circular Saw With 3ust Collection Hood Circular saws for cutting flat sheets should be used or.lv 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 "pulverising" action which releases asbestos fibers and fine particulate. The combination of hood and vacuum source is highly effective 4n capturing and collecting these particles and fibers. aw operating techniques are those normally employed. >c special procedures are required except adjustment of the lower hood section to suit thickness of shoot being cut. Saw design requires ; use o: blades rccomm; tool supplier (abrasi disc or diamond). For additional information cn saw o?er supplier's instructions in Appendix A. DU 039260 DUP 0948333 I to Circular Saw With Duse Collec Hood (-> |> lit 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 vacuum cleaner as described in the specifications (page 13). A circular saw cuts by a "pulverizing" action which role asbestos fibers and fine particulate. The combination o hood and vacuum source is highly effective in capturing collecting these particles and fibers. Saw operatin'', techniques are those normally employed. Saw design roquir the use of blades recommended by the tool supplier (abresi disc or diamond). This tool de ends on pliable "fingers" to seal the tone and is ,esigned for use or. sheets with 1 1/2" corrugations For cutting sheets with deeper or i corrugations consult the tool supplier. For additional information on saw operation, recer to the supplier's instructions in Appendix A. DU 039261 - 56b Cutting - Handsaw 4 Handtools Hands aw This is a handsaw equipped with a carbide blade designed r- for cutting asbestos-cement sheet. Practical use or this i saw is limited by its slow cutting speed. It is most useful in operations where cutting is infrequent and of short duration. secause or the Sxow cutting speed, saw operation generates coarse particles of asbestos-cement with'few airborne fibers. Its use docs not require dus 'ollection equipment for compliance with present exposure limits. DU 039262 DUP 0948335 - 57b - Cutting - l' L:it Sheets Hand Cl infers M Handcools Hand Clippers These hand clippers are designed for cutting sheet material up to l/d" 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 cearse_particles of ashestos-cement with few airborne fibers. Its use does not require dust collection equipment for compliance with present exposure limits. DU 039263 DUP 0948336 53b Cutting - Plat Sheets Score 5 Snap Kni5c Handtools Scoring Knife The scoring knife can bo used with shouts up to 1/4" in thickness. However, it performs best with shoots 1/3" and 3/15" thick. The sheet is placed cn a worktable or saw horses. A suitable guide bar is placed or clamped alon; the cut line and the sheet scored repeatedly. After scoring the sheet is hand snapped along the score line. This cutti: procedure generates little dust and few airborne fiber-. :s use coes not r :ucre aus* -.-1 r.r. irh present ; sure emits. DU 039264 DUP 0948337 WWW* .'.jg-'SS kfigiscti'lVV - 59b Drilling - ?ov:er Drill Drill With. Dust Collection Kooc Drilling of small holes Cl/'" or less) on vertical surfaces, or downward usually car. be done without dust collection eauioment and in compliance with present exposure limits. Drilling of larger holes, and drilling overhead, repair dust collection equipment on the drill in order to achi compliance. Equipment in eludes a hood fCape L'r.iversal 3uilding Products, Ltd.) and vacuum cleaner to provide exhaust ventilation ar.c dust collection. Vacuum cleans should be as described in specifications (page 13). Drilling techniques cro those normally employed. No special procedures are required. DU 039265 DUP 0948338 60b Hoi Cutting and Cutouts * Flat Sheets __________ _________Sab re Saw__ Sabre Saw ',/ith Dust Collection Hoed Sabre saws should be used or.lv when equipped with the specific dust collection hooc 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. >.'o special procedures are required. For additional information on saw operation, refer to supplier's instructions in Appendix A. DU 039266 DUP 0948339 -stagaBs jratistlKKSJitf ,j,iJSgj,; ,ii, St; ft -61b - Hole Cutting and Cutouts - Drill kasn DUP 0948340 A simple method of making curcu t5 around the edge o f the opening to the material to be removed wi*h a to dress or bsvs 1 e dges o: the' CU This procedure dees not require dus for compliance with present exposur 'ill snail h nd knocking A rasp is o.uec .IU DU 039267 62b Vacuum Cl ear. e r Sreci citations (Values shown below are minimum recommended) Circular Saw Flat and Corrugated Sheer Curtin; Vacuum (lift): S3" V;. G. (water gage) Airflow: . 173 SC ?M (standard cubic feet per Filtration System: Multi- stage, designed for use with as 'o e s t os-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: 55" W.G. 6 S SCFM See Above See Above ) L. DUP 0948341 DU 039268 - 63b - ilousekcening and 'vcsec Disncsal Housekeeping is an essential par* o any safe construction operation. It is even moro essential when airborne dust created by the task. of good housekeeping has the potential for harm to emoloyees 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 airocrr.e asbestos dust to the atmosphere. Laose nazerial should nave? he dry suept. When vacuum equipment is available, it should be used. Water or other dust suppressants should be applied in chose circumstances where sweeping is unavoidable. DO MOT 3LCW '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 ERA waste disposal requirements (iC CPR, Part 61) refer to Appendix C. DU 039269 DUP 0948342 64b Ecuiomer.c Suppliers Tools shown in this pamphlet are available cron: Wheeler-Pilot International ?. 0. Box 3123 20433 Earl Street Torrance, CA 90510 (213) 371-1233 h'ilfisk of America, 201 Xing Manor Criv King of Prussia, PA (215) 277-3500 Suppliers claiming to have vacuum cleaning units suitable for use with asbestos-containing dusts are: American Cleaning Equipment Carp., Ill South Route 33, Addison, IL 60101 Beamco, Inc., 707 Stierlin Road, Mountain View, CA 94040 Breuer Electric Manufacturing Co., 5100 No. P.avenswood Ave . , Chicago, IL 60640 Hild Floor Machine Co., Inc., 5339 West Lake St., Chicago, IL 60644 Xari-Vac Inc., 4360 W. 12 7 th St., Alsip, * r ? j C 0 0 Milfisk of America, 20 1 King Manor Drive, PA 19-66 ng or ?russ i.a, Pullman/Hoit Products, 10702 46th Street, Ta mp a, FI 3 351' Vac-U-Max, 227 Main St., Belleville, NJ 07109 Wheeler-Pilot International, 20433 Earl Street, Torrance, CA 90510 Note: It is recognited that equipment suppliers jotr.cr tear, listed above may be available. Mention o: any comma not to.be considered an endorsement by AIA/NA. 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