Document 3vprG6RNpJnr8aDn1xDYZa1y

Hr. A. de Jean King, Sr. U.S. Department.of Labor Occupational Safety & Health Administration 272.0 Riverside Drive ` Macon, Georgia .31204 . References CSHO No. 00637 OSHA-1 No. 56 : Fy-74 dated April 3, 1574 Progress Report Dear Hr. Kings - You will find listed below a progress report on alleged violations of the above citation and a request for an extension of the long-range abatement of Item #3 29CFR 1910.95. Item No,. 1 - Standard 29CFR 1910.93 (a) The respiratory protection requirements for all personnel working in the Openincr-Blending and Carding areas are still in force. Respirators were removed from personnel in the Weaving area last month. Studies indicate that dust'concentration levels are remaining below the standard. -. A. Opening and Blending _ . 1. The efficiency test for*filtration of our Wheelabrator system was conducted by engineers from Air Quality Testing and Design, Inc. Each of the three bachoeses was given a one hour test in which the air sampled was isokinetically extracted from the ductwork. The ' asbestos fibers vers collected cn a membrane filter and transported to a laboratory for analysis at 450X magnification {4 millimeter objective) phase contrast illumination. The asbestos concentration of fibsrs/ml were as follows: north baghouse 0.30, east baghouse 0.23, and the west baghouse 0.43. , 2. A vacuum asbestos distribution system is being studied which consists of metal hoppers below the existing condenser to handle the surges which occur in the present blending operation. Multiple mixes considerab3y complicate any proposed system. Manual valves and card hopper redesign to accept the stock is thought to be the answer. .o*y;473 -2- October 4, 1974 Connection of the duct system to the Wheelabrator network to eliminate dust is to be engineered into the system. Preliminary drawings are completed at this time. Engineering and economic feasibility studies should be completed by the next reporting date. B. Carding 1. The trial of the exhaust and fly removal beneath the ' cards has been improved and now is working better. Plan3 are underway to extend this idea to both the ' breaker and finisher cards. This will take a few . months to complete due to the close quarters and avail able personnel with know-how to do the job. 2. The ductwork to exhaust the grinder has been completed. It took the contractor much longer to fabricate this than was expected? however, it is performing better than anticipated. This hood and exhaust was installed at a cost of $2,435.95, not including engineering which is now a fixed cost. . The other grinder will be hooded by the same method or not used. Economics does play am important part in how fast we are able to move, but engineering and fabrication are also time consuming. We are trying to = improve in several areas at the same time. C. Weaving * 1. The automatic warp-wetting system has been designed and is performing satisfactorily. This is to be tried for another week; and if no bugs develop, it will be extended to all the looms. 2. Dr. NiFong was contacted and an employee was sent to the Airbourne Dust Sampling and Counting Training Course in Cincinnati, Ohio. It wa3 found that our present system was identical, except for a recent change of count ing up to a hundred fibers' or a hundred fields instead of a hun` dried fibers or 20 fields, whichever came first. Item No, 2 - Alleged failure to utilise feasible administrative or engineering controls as specified under Standard"29 CFR 1910.93 for concentrations of raw cotton dust exceeding table 6-1. . A. Garnett Machine . 1. Reworkable waste is being processed through the opening system and the idea of a new garnett machine has been scrapped for the present time. We feel we have less dust without garnetting and quality is still good. -3- October 4, 1974 B. Carding Area 1.' Twelve new "dog-legs" attachment ducts to cards have replaced old ductwork. . 2. The Cahn Electrobalance, which cost over $2,000 and never worked, has finally returned from California. We are beginning to sample cotton dust concentration and should have results by the next report. 3. The chute feeding system has been discussed with two . contractors, but designs for a workable system with bids have not been received yet. * 4. The major reduction in cotton dust has been obtained by a reduction in the amount of cotton being processed. . We are attempting to go out of cotton into 100% * synthetic. However, the supply and market may. make this non-feasible. Item No. 3 - Alleged violation of Standard CFR 1910.95 on Noise exposure. This is probably the mcst difficult and complex problem we face. We still require hearing protection'for all personnel in those areas exceeding the 50 decibel stananrd. We arp * < i , si checks as we try new procedures. The bean insignificant to the overall reduction id barriers seem to redirect more than :ation is needed requiring mere time and .ow process from design, delivery of and trial. D Duraloc product, it is administratively a sible to rotate personnel. Training time ai i of the available market. Therefore, wc 5f one year to October 1, 1975, to comply wi ea problem. ' Sincerely yours. WDC:bt blcc: Messrs. L.M. Boulware J.L. Dorrier-'"^ R.P. Sprayberry 43i