Document 4J3QryZmZdmykYknMO2YJpdOV

FILE NAME: Avondale (AVD) DATE: 197& DOC#: AVD DOCUMENT DESCRIPTION: Es^,/W^/ZZZZ , SHIPBUILCU:J:;S COUNCIL OF AMERICA WATeRGATe six HUNDRED I WASHINGTON, o. c. 2 37 February 4, 1972 To: ACCIDENT PREVENTION COMMITTEE M. P. Redford, Chairman Harry H. Howard J. Radcliffe Maumenee Harold J. Morgan Maurice Mosier William L. Rich J. Samuel Stratton Paul Sousa R. A. Stubblefield Manuel C. Val Dez Edward Verderane G. P. Walls Searle T. Walton Subject: NAVSHIPS Instruction on Asbestos Expsoure Hazards The enclosed NAVSHIPS instruction dated 9 February 1971, is for your information as to Navy's approach on asbestos dusts on Navy work in private yards. We unde rstanc;l that some yards have already received their instruction directly from NAVSHIPS, Note that on page 4, item paragraph (17) mentions the 5 fibers limit as in the Dece-mber 7, 1971, OSHA Emergency Standard. cc: Thomas J. Defoe Otho Hauns child Thomas Hayes R. E. Mingledorff Kent Savage E. P. Ruddy Secretary PLAINTIFF'S EXHIBIT SBCA 5036 E j E " ~ 1.-------- ~ DEPARTMENT OF THE NAVY NAVAL ~HIP ~YSTEMS COMMAND WA~lllt-lGTON, 0.C, 20360 f!II ftlf'I Y HCtr.R TO NAVSHIPSINS'l' 510( O?D:JC:lb Ser ?0-07D 9 February 1971 l!A. VSHIPS INSTRUC'l'IO'.l ~ 100. 26 From: Commander, lJaval Ship Systems Command Subj: Asbc:stos Expo~ure Hazards; control of -- Ref: (a) HIL-STD 769C of 15 Nov 1969, Thermal Insulating Requirements for Y.ac:!1inery and Piping (b) NJ.VSHIPS .Technical :Manual 9390 of Sep 1967 (c) NAVMAT P-5100 11Safety Precautions for Shore Activities 11 {d) NAVNAT P-10470 11Safety Equipment Manual11 Encl: (1) Suggested Warning Signs 1. Pur;-1ose. To prescribe appropriate safety precautions during the use of asbestos, 1 c: .' .,I ' a. Asbestos is a broad term applied to a group of fibrous minerals such as amosite, chrysotile, crocidolite, etc., composed of silic.a tes of iron, sodiu.-rn, calcium and/or magnesium. I b. The most critical use of asbestos in the Navy from a safety vievpoint is in the fabrication, installation, repair or removal of pipe and boil<~r insulation materials. Some workers sustain accidental contact~ eH,her while employed in various capacities Yhere asbestos products are processed or when worl:in6 in plant areas in which an environmental pollution of the nir exists due to asbestos. The severe effects of asbestos on the lungs is the main factor for considering the elimination of azbc::;tos as an insulation material oh piping, ducts and boilers, References (a) and. ( b) s<=?t s"tandurds of IT'.:it(:!'ials which a re to be used. Those references will be reviewed periodically and changed as necessary to reflc~~t the use of new materials that rneet or exceed the standards now in use:. Reference ( c) also prov.i.dos Guidance on precautions regard- ing asbestos. 3. Action. The following safety precautions \./ill be ohserved by all supcrvisor3 and ,:orker.':l c:nr,uced in the fa!Jrication, installation and/or removal (rip-out) of a:~bustos-containing lnsulation/rr.:i. tcrial. The proVisions of this in!Jtruction \Jill be effcctiv~ as cf this date. The provisions of this instruction arc considered as minimum health and sn.fety rcquirc:::cnt~; more strinecnt restrictions mo.y be applied by local Co:rJ:~ndcr~. S202 UAVSilIPSIHST 5100. 26 9 Februe.ry 1971 a. FEthric~ttion: ( 1) As Lcstos operations should be segrec;rt ted frc.in1 . U~c~~, operations so as not to expose other personnel to asbestos dl, :_ :1 the work cannot bo separated, personnel in immediately adjacG -, i.,,_.~~,1.:: ,. will wear a Bureau of Mines approved respirator for irritant ,L :J ,:.s ;.:.r1d other prescribgd, personnl, protective equipment, The vnrj.ou 1-:1t:rt:~~ c<: personal, protecti vc equipment will be those approved by the ;!,}11st:;:fr -~ Hygienist, the !-JJdical Officer, or as authorized by rcfe:rence (d)c (2) The hundling and fabrication areas will be res~ :.d'..:-d tr, the ncces~ary work rs, supervisors and inspection per'sonnel di .c 1:.;" concerned \tith the asL,3s-to:.~ opc:::-ations. Cd.sual visitors or pf. will be restricted from entry into any area where asbestos con materials are being fab~icated. All supervisors, workers, ins etc., will wear approved reGpira tors for irritan'!: dusts when t' .. .,, . "Working with dry r::.atcrial containing asbestos or are in asbestr. ;;-~c,):-,tamimlted areas of- work spaces . .. (3) Asbestos cloth cutting tables or benches provide, ,r,L_;; adequate loeal exl1aust ventilation should be used whenever cutt r-', operations are pcrfo1mod. Exhauzt air containing asbestos dust , be dispersed into the atmosphere without being adequately filte; Filteru will be carefully changed or cleaned to prevent atmosph,_ contamination. (4) Power saws will be located in a suitable enclosw., 1-.ih:f.c.:, is equipped with exhaust ventilation to a filter trap. This ex:-, .-:.1:, ventil,.tion wiJ.l _bJ indefiendent of the shop ventilation supply/~ _',,.,.::/.. sys tern. The switches will be interlocked so that the exhaust sy - t:""r;J operates at all times \.lhile the sav blades are in operation. ( 5) Sui table 'w'aste containers lined with disposable pJ -=.di::: l::or;s will be provided at each cutting table/fabrication operatior-. Llt.>, carded and scrap ar~bestos materials will be ir.uncdia tely placed ir: p:i_;1 J Uc t.:ae;s which are thc:i .sealed for dispo::;o.l. Scrap :;t:::n!.ld be dispose.:l .)f w. a daily basis. (6) The Indu$trio.l Hygienist or Medical Officer vill r r'(11:.1c:,:'l the cxnct method and place of disposal of asbestos dusts and scrs. 1 o minimi zc exposure:;. ( 7) Shep 1-iall::;, ccilin{? and floors should be design.ed ,. prevent dust accumulation~ and to facilitate housekeeping measure: 2 NAVSHIPSINST 5100. 26 9 February 1971 (8) Indu:::;trinl type vacuum cleaners should be used to pick up du1,;ts and scrap. The vac:iu."!1 cleaner operator w-tll wear an approved respirator when operating his cleaner, The water impaction collection system vn.c.:uwns best and safely. Dry s-weeping of scrap or dust snould not be permitted. If s"Wecping is necessary, the scrap and possible dust \Jill uc wet dmm \.Jith a fine water spray prior to sweeping. Drop cloths will be placed under work tables or areas if scraps and dust will fall into difficult to clean areus or crevices, (9) Asbe~tos cloth or tape "Will not be torn or ripped. Scis8ors or cutting knives will be used. (10) In-Shop operations for mixing of all cements will be provic.lec!. with pc:n1a1lqnt e:x.i"laust ventilation equipment. This exhaust air : will not be vented into the shop atmosphere and must be adequately filtered before its release to the outside atmosphere. In-bag mixing m:1.y l;e done wi lhout exhaust ventilation so long as bag integrity is I t rua.int3ined. ~ .. (11) The asbestos cloth shall be wet down prior to fabrication. r: (12.) All regularly nssigned inm.uation workers and supervisors \Jill be given a 1411 x 17n annual chest X-ray. This will be done an the same continuing, periodic basis even if the worker is transferred or reassigned into another job title. X-ray films of asbestos workers, active, reassigned or retired, will be specially identified to.the consulting :r;adiolot:;ist to alert him to the need for a special type of reporting. The health records of insulation vorkers will be marked "Asbestos worker 11 ( 13) Insulation workers should be provided w'i th clean coveralls s nt the beainning of each shift or as often as needed. The coveralls will b~ rcr.-,oved before the removal of the respirator and should not be 11 bcai..en 11 to remove excess dunts or scrap adhering to it. Contaminated coveralls will be placed in plastic bags, until disposed of or laundered. ,1. 1 : ( 14) ~h tcrials will bo removed from their cartons or package :<'. ( with care to reduce dust or -scrap generation, Wetting of the material prjor to removal substantially reduces dust production. (15) The Industrial H:n:;icnist \.Jill provide ut least t\.licc yearly ~ indoctrim.tion tnlks to all ns bestos workers on the proper measures of pcno1nl protection n1:;,:1inr.t nsbostos exposure. 3 NAVSHIPSlNST 5100, 26 9 Fabrua1y- 1971 (16) Ad8quat.c \Jarninc ::dr;ns (enclosure (1) or similar) 'will be posted at all entruncc.s t0 tb0 fn uriw tion shop ~i tes to alert \lorkcrs and other personnel t~1ai., a~bcst.os operations are in progress. (17) The Industrial Hygionist should make frequent inspection of the Fabrication a11d Installation situs to check the level of airborne contamina.tion, These inspections should be done monthly or more often as rquired. The Thre!::hold Limit Value (TLV) for airborne asbestos is 5 fibers creater than 5 r.:icrons per milliliter. If this TLV is exceeded, the Industrial Hygienit i,;ill assist the shop foreman in dedgning better preventive measures to control the aiJoorne contamination. - Anbc::;tos instn.llnti011, fabrication or rcrr.ova.J. operations should be suspenclecl 1mtil the pr(,pc: TLV ct.n be maintained so as to rrotect the worl:e:i.;; and others in the area. (18) Cement l.-3.gs will he opened wide to permit emptying of the contents ,1ithout shaking. The material should be made into a slurry as quickly as possibJ.e to prevent dust generation. Empty bags will be wet do\.:n end placed in a W!S te cont.ainer . (19) Suitable replacement materials for asbestos will be used when prr~cticnble. Ne\.r or untested rcpJ.acr:;n,ent materials will be submitted to l!AVSI:C for evalun.tion and approval pri,:.r to i...se. b. Instal1at5 or.: (1) Personnel engaged in Installation operations will ~ear Industrial Hygienist approved respirators whenever asbestos containing materiA.ls are being h,rnd~ed. The Hecilcal Offic~r will be the approval authority for any exceptions. (2) Unpacking and application of insulation materials at the installation site will be done in such a manner that will minimize airborne dust. (3) The arc<1 around U:e installation procedures should be isolated when possible. Adequate warning signs (enclosure (1)) will be posted. Only persons whose \.fork requires their presence should be permitted in such areas. If airborne asbestos dust is pre5ent, they will wear 13urc:iu of Min0s upproved respirators for dusts or leave the area. (4) The Industrial HyGienist will be requested to deteIT.line suitable methods for prcventinG large scale contamination of machinery and engine !;pa'ccs \.:hen inst.:i.lln.tion or removal operations are performed in these areas. 4 , - J ' ( NAVSl!Il~SINST :,100.26 9 February 19? 1 {5) Su1 V1 bl war.to cont:i 'i.11ern linc:<l wlth d:i sporiublc plactic h'lGf.i wlJ.l lie l~(1,!.. avail:1blu rit Uw i11:;L~,lJ...d.io11 sitr..! ~o thnt <li!.:cnrde<l or scrap ln~ulution 1r.at.0rialn can be immc:<liatcly plu_ced in tltem. (6) 'he exact method and place of disposal of scrnp asbestos and asbestos dust \.Jill be approved by the Industriul Hyc:;ienist or the Medical Officer. Per:onncl assigned these tasks will be specifically advit:ed on needed precautions by the Industrial Hygienist or the shop .supervisor. (7) The ventilation requirements of shipboard or confined spaces will be determined by the Industrial Hygienist or Safet.y Officer and vill be in accord with Article 0212 101-1-5-1054 of reference (c). (8) Po:table dust collectors/indu~trial-type vacuum cleaners should be placed in use at the point of operations within confined 6paces when possible. (9) Decks and spaces contaminated by insulation debris will not be dr-J s1.,rept. These areas must be wet dmm by a fine spray prior to sweeping (,,,hen vacuum clean., ers . cannot be used) (10) Workers performing insulation vork should be provided "1ith clean ps.per coveralls when dusty conditions are to be encountered. The coveralls will be removed before the respirator is removed. The coYc::-o.lls sr.ould not be 11 beaten" to remove excess dusts or scraps adherine to it. Contaminated coveralls will be disposed of by placement in the asbestos scrup tag. c. Rc~oval (Rin-Out): __ , (1) Personnal engaged in Removal oper~tions will wear Bureau of MineB approved respirators whenever asbestos containing materials are beinG handled. The Medical Officer will be the approval authority for any exceptions. (2) The area cround. the Removal procedures should be isolated when po~siblc. /,dequute \.Jarning signs (enclo.:rnrc (1 )) will CG pos-ced. Only persons whose work requires their presence will be permitted in such arens. If airborne asbestos du~t is present, they will wear Bureau of Hines approved rei.piro.tors for irritant dusts or l~ave the area. (3) The Industrial Hygicnist/Hedical Officer should designate specific procedures to collect scrap and ~ust in the machinery spaces. 5 t , . NAVSHIP$IlWT 5100.26 9 February 1971 {i~) Tho nroei {s) in uhich a:;ho~los r0moval takos place will be confined when ponsible by n:cans of curta.ilis, portable partii..ions, drop cloths, e'Lc. J to prevent excessive contnmiua. tion of other areas. (5) In removal operations thai.. involve dusty work, clean paper coveralls will be supplied at the start of each shift; then for lunch, the workers will dispose 0 the dirty coveralls, then dispose of their respirntcr filters. After lun~h they \.lill put on clean coveralls and respirators with nc:w filters. At the end of the shift all contaminated cover~lls viill be dh;posed of ?Y placer:ient in the asbestos scrap bags. (6) Suita11J..e was~~~ contain,:,rr; lined with disposable plastic ba.6:=; will be kept hVLil2blc at the removal ~ite so that discarded or scrap insul~tion materials can be immediately placed in them. (7) The exn.ct method a.nd place of disposal of scrap asbestos and asbestos dust will be approved by the Iridus'Lrial Hygienist/Medical Officer, This is particularly applicable on-board ships and in machinerJ spaces. (8) High asbestos-containing scrap material should be wet down oof0re collection, hauling or dumping. Personnel assiened these tasks will be specifically advised on needed precautions by the Industrial Hygienist or the insulation shop supervisor. (9) The ventilation requirenents of shipboard or confined spaces will be deter!l'ined by the Industrial Hygienist or Safety Officer and will be in accord with articles 0212, 1045-1054 of reference (c). . . (10) Portable dust collectors/industrial-type vacuum cleaners should be placed in use at the point of operations within confined f.:paccs. 1'h~y mn.y bE! used to temporarily and partially clean a worker -who has to leave the work area for a short time. (11) Decks arid space::; contaminated by insulation debris should not b~ dry swept. The"e arons must be wet down by a fine spray prior to sweeping (whenvacuum cleaners cannot be used). (12) A ca1;t cul.tcr ~imiJ.n.r to the Number 845 STRYKER CUTTER will be u:::cd \/hen possible during removal operations. This is a cutter used by doctors to remove plaster casts from patients. Old insulation should not l.ie ripp,~cl or torn. It should cc cut whenever possible. The addition of a vacuum .:t ttachmcnt to tr.e STRY:2::R. CUTTER will materially aid in co:itrollin:; dust gener?..tion. This attachment should be used 'whenever practicuble. 6 \ ..----. .. ) . I \ NAVSHIPSIN- ' 9 February (13) '!'he InJu.st.rial Hygicni::;t ,,,ill pcrioclicully cvahu1tc"thr level of asbestos (!xpor,urc nnd reconmen<l positive mcnsuros for dust control in various ureo.s. This ovalmtion should be done nt the stari of e:.i.ch ne'w asbesto;. operation and as o.ftcn thereafter as the finding~ indicate to provide effective control over dust producing operations, (14) The use of off-hours work should bi; considered to minirr z~ the number of personnel susceptible to exposure of irritant dusts. ( 1) The Industrial Hygienist \:ill recommend and ,tpprove the various types of re~pirators, over~lls nn<l other needed p~rsonal protcctive eq11'ipr:-ic.nt to be used by personnel enguged in various asbestos op~rations, Only personal protective equipment approved in accordance with Fcd.ernl Specification GGG-M-125, Type III, Classes 1 and 2 as set forth in reference (d) will be used. (2) Each worker will be responsible for maintaining his respirntor and filters in a satisfactory condition. He will wear it in a proper manner when working on dust producing operations and during al} c:. asbestos removal operations. (J) Supervisor;; will enforce the proper use of perso:-w.l protective equipment during all phases of asbestos work, They will . arrnnec for pra!':1pt, scheduled physical examinations and prescribed by the Medical Officer (normally annually), X-rays us (4) Supervisors will arrange for an adequate supply of clean coveralls and ne\.1 filt~rs for the respirators used by insulation workers. e. ~Imlication of SubRti t1.ite Materials For Ashestos! (1) Any proposed materials for use in place of asbestos will be submitted to NAVSEC for evaluation and approval prior to use . Dl r.tri bu-Lion: SNDL FKL1 NAVSHIPYD FKL2 SUPSHIP FKL6 FBJO . II1ACTS:!IPFAC NA VSHIPfGPF ;_c FBJ/,. FLEACT SASE30 . wdrd)? DAputy Con~~~~ for F!eld Activities/lfogram Director for Shipyard Hodcrniza.tion and Manag ~~';'t' 7 NAVS!ITl\"ilNS'l' ') 100.2& . 9 }\--l1rti!u-y 19'11 Distril>uLl.on (Continued): Copy SNDL to: A5 B5 FKA 1C FKli 1F FF5 A/Jt AJ BWD (732) COG/1RD NA VFAC NAVSUP NAVSAFECE~l NA Vl-~\T (Of+(.,) OPNA V ( 098 } NAVSEC (101, 611.0, 6105E, 61)1, 6153) N.AVSilII'.3 ( 07D) ( 100) NAVSHIFS .Speci<il Li:;t Y-2 Stocked at: Supply & Fical Department Code 514.32, Naval Station ... 1 Washington, D. C~ 20390 J. Crawford, x27606 L. Breidinccr, 2/1/71 8 4 . ,: . . NAVSHIPSINST 5100.26 9 February 1971 SUGGESTED WAillrIHG SIGNS ' RESTRICTED ACCESS ASBESTOS FABRICATION AREA .... - -- - - - .... - - - - - - --- RESTRICTED ACCESS ASBESTOS IllSTALLATIOi'l/RIP OOT WEARING OF RESPTilATORS REQUIRED ' 9 , ENCI.OSURE (1)