Document 4JaQg3wVLn789LR8VdZnv98mR

Draft 12/27/79 RECOMMENDED STANDARD FOR ASBESTOS EXPOSURE IN CONSTRUCTION AND OTHER NON-FIXED WORK OPERATIONS Submitted to the Subgroup on Health Standards of the Advisory Committee on Construction Safety and Health by The Asbestos Information Association of North America and The Association of Asbestos Cement Pipe Producers CAP CO JEN 0012540 TABLE OF CONTENTS ?*ge I. INTRODUCTION......................................................................................... 1 II. THE NEED FOR A REGULATORY STRATEGY WHICH MORE CLOSELY REFLECTS THE EVERDAY REALITIES OF CONSTRUCTION AND OTHER NON-FIXED WORKPLACES.......... 6 III. EXPLANATION AND ADVANTAGES OF THE MODEL STANDARD RECOMMENDED BY AIA/NA ANDAACPP....................... 15 A. Explanation of theModelStandard................................. 16 1. Scope and application............................................. 16 2. Product classification.......................................... 18 3. Validation................ 20 4. Regulatory requirements........................................ 23 B. Advantages Over OSHA's Typical Fixed-Site Health Standard............................................................... 26 1. Worker protection.................................................... ' 27 2. Incentives for the development anduse of safer products and workpractices............ 31 3. Enforceability............................................................. 32 IV. CONCLUSION............................................................................................. 33 MODEL ASBESTOS STANDARD FOR CONSTRUCTION AND OTHER NON-FIXED WORK OPERATIONS...................................................................... APPENDIX: A Preliminary Assessment of How the Model Asbestos Standard Can Successfully Be Implemented in Construction and Other Non-Fixed Work Operations........................... ........................................ ............. la lb Introduction: Potential Asbestos Exposure in Construction and Other Non-Fixed Work Operations.......................... ..................................................... 3b CAP CO JEN OOI2541 Page A. Recommended Work Practice Procedures for Asbestos-Cement Pipe................................................. 9b 1. Sampling methodology and operations sampled for asbestos-cement pipe................... 38b 2. Methods--...................................................................... 39b 3. Operations sampled............ ....................................... 40b B. Recommended Work Practice Procedures for Asbestos-Cement Sheet.............................................. 49b C. Recommended Work Practice Procedures for Drilling Mud Additives...................................................... 71b CAP CO JEN 0012542 RECOMMENDED STANDARD FOR OCCUPATIONAL ASBESTOS EXPOSURE IN THE CONSTRUCTION INDUSTRY I. INTRODUCTION The Asbestos Information Association of North America (AIA/NA)-/ and the Association of Asbestos-Cement Pipe Producers (AACPP)2-'/ endorse the efforts of the Subgroup on Health Standards of the Advisory Committee on Construction Safety and Health in developing a workable strategy for regulating health hazards in the construction industry. As detailed in previous AIA/NA testimony before the Subgroup and the Committee on May 17, September 28, and November 26, 1979, traditional fixed-site, "manufacturing"-type standards -- which are routinely adopted by the Occupational Safety and Health Administration (OSHA) and inflexibly applied to all types of employment -- simply do not reflect the everyday realities and health needs of construction workplaces. 1/ AIA/NA is an incorporated, non-profit organization representing 54 firms engaged in the mining and milling of asbestos ore and the manufacture, sale or use of asbestos fiber or asbestos-containing products in the United States and Canada. 2/ AACPP represents corporations in the United States, Canada, Mexico, France, Switzerland, Australia, Greece, India and Finland engaged in the manufacture and sale of asbestos-cement (A-C) pipe products. CAP CO JEN 0012543 2 This paper fulfills our commitment to the Subgroup to show, using asbestos as an example, that an acceptable alternative can be developed to satisfy OSHA's need for an enforceable regulation which effectively protects the health of workers. In brief, our Model Asbestos Standard for Construction and Other Non-Fixed Work Operations establishes a series of economic and regulatory incentives for the development of work practices and product formulations which will provide adequate health protection for workers without imposing the impracticable and unnecessary features of the typical fixed-site OSHA standard, such as monitoring, medical surveillance, regulated areas and hygiene facilities. More specifically, our recommended Model Standard makes the current OSHA asbestos standard, which imposes the usual fixed-site requirements, presumptively applicable to construc tion and other non-fixed workplaces, but provides for partial and complete exemptions based on a product classification scheme, as follows: (i) Paragraph (b)(1) defines a "Category A Product" as any product which, based on qualified scientific tests, will not, under any reasonably forseeable use, release airborne asbestos fibers in excess of the permissible exposure limits. Under Paragraph (c), construction workplaces where such Category A Products are used are exempt from all provisions of the current standard; CAP CO JEN 0012544 3- (ii) Paragraph (b)(2) defines a "Category B Product" as any product which, when validated work practices or other protective measures are used, will not release airborne fibers in excess of the permissible exposure limits. Under Paragraph (d), construction workplaces where such Category B Products are used are partially exempt from the standard, provided validated work practices are followed. This partial exemption would leave in effect warning sign, labeling, housekeeping, and worker education and training requirements which would help ensure the use and effectiveness of validated work practices; and (iii) In the case of workplaces involving "Category C Products" -- i.e., products which are neither Category A Products nor Category B Products but the processing or use of which may release asbestos fibers in excess of the permissible exposure limits -- the existing standard would apply in full. Paragraphs (b)(3) and (e). The purpose of this product classification scheme is to encourage the development of safer products and work practices which eliminate the need for the impractical fixed-site requirements of the current standard, such as monitoring and medical surveillance. Our alternative creates stronger incentives for primary manufacturers to develop validated CAP CO JEN 0012545 4 work practices so that their construction industry customers will not be required to meet the most burdensome fixed-site requirements of the current standard. An additional incentive is provided for innovative product formulations (Category A Products) which pose little or no foreseeable threat of dangerous asbestos exposure. Moreover, our approach would provide enforceable assur ances that validated work practices and product formulations are effective in protecting workers. Thus, validation of product formulations (Category A Products) and work practices (for Category B Products) would be performed only by fully qualified testing laboratories based on objective performance criteria. In addition, OSHA's own enforcement activities would act as an empirical check on the scientific validity of such testing: if monitoring results from an OSHA inspection suggest that the use of any Category A or B Product is not effective in keeping exposures below permissible levels, the employer would, upon appropriate proof, be put on notice that he can no longer reasonably rely upon assurances from the primary manufacturer, and that additional scientific testing would be required. In short, our recommended standard is far superior to the current OSHA approach of inflexibly imposing fixed-site requirements such as monitoring and medical surveillance on construction and other non-fixed workplaces. By contrast to the current OSHA approach which, in practical effect, gives CAP CO JEN 0012546 5 construction industry employers no choice except to abandon the use of essential or highly useful construction materials (or else to disregard altogether the burdensome fixed-site requirements of the existing standard), our alternative encourages the development of cost-effective products and work practices which will both protect workers and meet the practical needs of the construction industry and the economy as a whole. In Part II below, we briefly review the reasons why many components of the usual fixed-site OSHA standard, particularly provisions for monitoring, medical surveillance, regulated areas and hygiene facilities, are infeasible and impractical, while contributing little or nothing to the health of workers potentially exposed to asbestos fibers in construction and other non-fixed workplaces. In Part III, we describe how our recommended standard will work and why it provides an enforceable mechanism for achieving OSHA's health goals, while at the same time imposing reasonable, cost-effective requirements which are far more likely to result in voluntary cooperation by the construction industry. Attached as addenda to these comments are (i) our recommended Model Asbestos Standard for Construction and Other Non-Fixed Work Operations, and (ii) a technical appendix which outlines how our Model can successfully be implemented, including detailed field-testing data which show that effective work practices can indeed be validated for three important asbestos-containing products. CAP CO JEN 0012547 II. THE NEED FOR A REGULATORY STRATEGY WHICH MORE CLOSELY REFLECTS THE EVERDAY REALITIES OF CONSTRUCTION AND OTHER NON-FIXED WORKPLACES OSHA's traditional approach for regulating occupational health hazards has been to impose inflexible fixed-site standards across-the-board, regardless of the differing characteristics of the many kinds of employment covered. As OSHA's recent compilation of occupational safety and health standards applicable to construction shows, the vast majority of health standards thus far promulgated by OSHA under Section 6(b) of the Act apply to construction workplaces. 44 Fed. Reg. 8706-8805 (February 9, 1979). In nearly every case, these standards impose requirements such as monitoring, medical surveillance, regulated areas, and hygiene facilities, which were designed for application to fixed-site manufacturing or other "general industry" operations. The current asbestos standard reflects the traditional OSHA approach. Construction industry employers, like all other employers whose operations involve asbestos-containing products, must conduct personal and environmental ("area") monitoring which must be "of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees." 29 C.F.R. 1910.1001(f)(2), (3). In addition, employers must also provide preplacement, annual and termination physical examinations involving a battery of tests, including diagnostic x-rays and pulmonary function tests, to every worker exposed to virtually any detectable level of airborne CAP CO JEN OO 1 254-8 7 asbestos fibers. 29 C.F.R. 1910.1001(j ); OSHA Program Directive 300-16 (October 11, 1978). Since the current asbestos standard was adopted in 1972, there has been a growing recognition, both inside and outside of government, that these and other fixed-site requirements, such as provisions for establishing "regulated areas" and "hygiene facilities" (e.g., shower rooms, change rooms, lunch rooms), are neither effective nor appropriate in the construction industry. As testimony and evidence submitted to the Subgroup, the Advisory Committee, and OSHA demonstrate, the unique characteristics of the construction industry cry out for separate regulatory treatment.--^ The key distinguishing features of construction and other non- fixed worksites are the following: rapid employee turnover due to the employment of a highly transient and temporary workforce; high employer turnover due to a predominance of small firms and proprietorships whose number fluctu ates widely with seasonal variations and other short-term shifts in demand; and the nature of construction work itself, i.e., performance of a multiplicity of discrete outdoor tasks, only a few of which involve potential asbestos exposure, and the absence of any pattern or regularity in worker movement among these tasks. 3/ Statement of Guy Gabrielson on behalf of AIA/NA before the Subgroup, November 26, 1979; Statements of Richard Trachtman on behalf of AIA/NA before the Advisory Committee, (Footnote 3 continued on next page.) CAP CO JEN 0012549 8 As the National Constructors Association (NCA) testified in OSHA's Cancer Policy proceeding, these features make many of the provisions in the typical fixed-site, "manufacturing"-type standard infeasible and impractical in construction and other non-fixed worksites. For example, the nature of construction work makes monitoring a virtually meaningless (albeit very expensive) exercise. `As pointed out above, only a few of the remarkable variety of tasks performed by construction workers involve asbestos-containing products.^ Yet, each task presents a markedly different potential for exposure to asbestos fibers.--^ For any given task, exposure levels will vary consideraly depending on the duration of the work, the work procedures followed by the particular employee, the tools used, the fiber-release characteristics of the asbestos-containing product being used, weather conditions, and other factors. (Footnote 3 continued from previous page.) May 17, 1979, and the Subgroup, September 25, 1979; Statement of Fred W. Graham on behalf of the National Constructors Association in the Proposed Cancer Policy proceedings. Docket H-60, Ex. 125; Statement of Harry P. Taylor on behalf of the Council of Construction Employers in the Proposed Lead Standard proceedings. Docket H-004, Ex. 64; Statement of C. R. Mattson (NCA), Docket H-004, Ex. 98. 4/ [Support] 5/ [Support] 6/ See, e.q., the Statements 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 (Footnote 6 continued on next page.) CAP CO JEN 0012550 -9- These facts, coupled with high worker mobility among tasks and the absence of any regularity or pattern in worker movement among tasks, make it obvious that a worker's exposure on any given day will necessarily not be "representative" of his exposure on any other day, nor will it be "representative" of any other worker's exposure. Consequently, the current OSHA provision for monitoring at "such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees" imposes an enormous burden, and could be read to require continuous monitoring of all of the 3 to 5 million workers who may be "exposed" (even though briefly and intermittently) to detect able levels of asbestos fibers. But given the uniqueness of each operation, this endless, repetitive monitoring provides information of little or no value in determining whether an exposure limitation is being satisfied throughout all operations. Similarly, the current requirement for preplacement, annual, and termination medical examinations for all construc tion workers exposed to virtually any detectable level of asbestos imposes an enormous burden with little or no counter vailing health benefits. Not only is the number of workers potentially exposed to asbestos large (OSHA estimates the (Footnote 6 continued from previous page.) Council of 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. CAP CO JEN 0012551 FBC23-D 12 IV. POTENTIAL ADDITIONAL CONTROL TECHNOLOGIES A). Engineering Controls The Research Triangle Institute has suggested that local exhaust ventilation could be used on power tools cutting asbestos cement pipe in order to reduce exposure levels.^/ Such a system would require a mobile vacuum unit and a mobile engine generator power source. According to RTI, this system could keep peak fiber levels below 2.0 f/cc.i*/ RTI also has proposed process modifications -to reduce exposure levels. The use of special field cutting tools, such as snap cutting, might be required for asbestos cement pi.pe.--20'/ Alternatively, RTI would consider a require' ment that all necessary cutting, machining and hole cutting be performed prior to shipping the pipe to the field. In this way, worker exposure would be controlled by a manufac turer, who is likely to have systems in place for control ling fiber levels.--^ 18/ Id. at IV-54. 19/ id. at IV-55. 20/ Id. at IV-59. 21/ Id. at IV-59. CAP CO JEN 0011967 10 - number at 3 to 5 million (40 Fed. Reg. 47653)), but in addition the workforce is subject to rapid turnover -- as much as 300-600 percent per year depending on the job or craft involved.-^ With the costs of the current OSHA medical examination now exceeding $100,the economic burden of this one requirement will run into the hundreds of millions and perhaps even billions of dollars for the construction industry alone. So long as the permissible exposure limits are being met, there is no reason for imposing such a heavy medical surveillance burden on the construction industry. As detailed above, asbestos exposures in construction operations are generally brief and intermittent, and, perhaps as a result of the nature of the exposures, the available epidemiologic evidence strongly suggests the absence of any asbestos-related health risk among construction workers. Dr. Irving Selikoff's recent study of a roofing workers union from January 1960 to 1977 -- the only long-term epidemiologic study of a cohort of construction workers done to date -- reports the following results: (I]f there was enough asbestos exposure in built-up roofing to give a significant hazard due to asbestos, I would have seen at least one mesothelioma. I didn't in 2,500 consecutive deaths and 7/ Statement of Fred Graham (NCA), Docket H-60 (Cancer Policy), Ex. 125 at 2. 8/ [cite] CAP CO JEN 0012552 11 these were all people who were in the union in 1960 and incidentally, had to be in the union also to enter that cohort in 1951. So these people were 25, 30, 35, and 40 years old from onset of their work and I didn't find mesothe lioma. So I know that there is not a significant increase although I can't prove that there is none. In the next 2,500 deaths, there may be 1 or 2, but certainly there can't be any great asbestos hazard with built-up roofing. Apart from the absence of any health need, the costly medical surveillance requirements of the current standard cannot be justified based on the need for epidemologic studies of workers exposed to low levels of asbestos fibers, since a far more useful data base is available from manufac turing operations covered by the existing standard, which generally involve stable, long-term employment with somewhat more regular exposures than in construction operations. Moreover, the rapid turnover of both employees and employers creates a significant potential for unnecessary repeat examinations,9-/' which themselves create a health hazard and add to the already heavy financial burden of compliance.--^ 9/ Although the existing standard does not require medical surveillance if there are "adequate records" showing that an examination has been provided within the past year (29 C.F.R. 1910.1001(j)(5)), high turnover rates among both workers and employers may, in many cases, prevent employers from obtaining the necessary documentation. See "Health Standards Pose Big Problems for Industry," Engineering News-Record, October 12, 1978. 10/ Because the required preplacement annual and termination medical examinations all include a diagnostic x-ray, employers who change jobs frequently may be exposed to excessive x-ray exposure and, hence, an increased risk of leukemia and other cancers. [Cites] CAP CO JEN 0012553 12 Thus, the current OSHA medical surveillance requirement accomplishes little good but nevertheless imposes an extreme cost burden and exposes workers to unnecessary health risks. Other components of the typical OSHA health standard are equally inappropriate in light of the realities of construction work. For example, the concept of a limitedaccess "regulated area" is meaningless in construction worksites, where, as NCA points out, "work is performed in a continuously changing environment", and "personnel are constantly being called upon to perform work in irregularly occupied areas on a transitory basis."--^ Similarly "hygiene facilities" such as change rooms, shower rooms, or lunch rooms are obviously impractical in the construction industry, because most construction sites have no supply of water or the buildings necessary to house these facilities, and because the cost of procuring mobile, self-contained facili ties would often be prohibitive, particularly for smallscale construction projects such as residential dwellings or small office buildings. Nor is there any reason to believe that the generally small, transitory employers in the construction industry are likely to have the personnel or financial resources to meet these requirements. Indeed, NCA's testimony in OSHA's Cancer Policy proceedings stressed that the routine adoption 11/ Statement of Fred Graham, OSHA Docket H-60 (Cancer Policy), Ex. 125 at 6. CAP CO JEN 0012554 13 of fixed-site requirements like those discussed above would "place an intolerable economic and logistical strain on the construction industry -- particularly small contractors." NCA added that "the costs are so extreme as to threaten the continued existence of many small and medium size construction companies throughout the nation, without a clear demonstration of the necessity for such rigid health controls."^/ Accordingly, the current OSHA approach' is far from likely to encourage voluntary compliance by employers in the construction industry. Workers, too, may often be unwilling to cooperate -- particularly with respect to the medical surveillance program, which could render them unemployable.--^ Yet, given the hundreds of thousands of worksites and millions of workers involved, and given OSHA's limited enforcement resources, an effective occupational health strategy for the construction industry must inevitably depend on voluntary compliance by employers and employees alike. OSHA itself has recognized that the unique characteris tics of the construction industry warrant separate regulatory treatment. For example, OSHA's recent occupational health standard for lead exposure exempts construction work because application of the standard's provisions would be infeasible in construction operations. 43 Fed. Reg. 52952 (November 14, 1978). Similarly, OSHA's 1975 proposed revisions to the 12/ Id. at 4, 5. 13/ "Health Standards Pose Big Problems for Industry," Engineering News-Records, October 12, 1978. CAP CO JEN 0012555 14 - asbestos standard "recognize[d] that alternative administrative and engineering controls may be more appropriate and feasible for the construction industry," because of "the uniqueness of the construction industry itself (viz., the multiplicity of non-fixed workplaces, and the utilization of highly tran sient workforces)." 40 Fed. Reg. 47652, 47653 (October 9, 1975). More recent OSHA initiatives confirm the need for a different regulatory strategy for construction and other non-fixed workplaces. The Subgroup on Health Standards of the Construction Advisory Committee was itself created because, as Assistant Secretary of Labor Dr. Eula Bingham stated in her July 18, 1979 charge to the Subgroup, OSHA's "health standards . . . have been focused primarily on general industry," and, as a result "of the mobile and transient nature of their industry, construction employers and employees have had difficulty in complying with these standards." In addition, OSHA recently appointed a Special Assistant for Construction Affairs to provide advice concerning regulation of the construction industry and, on June 7, 1979, established a Task Force on Construction to assist in resolving the problems of regulating health hazards in con struction . In sum, many provisions of the typical OSHA health standard -- concededly designed for fixed-site employment in 14/ BNA, Occupational Safety and Health R'eporter, Current Report dated June 14, 1979, at p. 31. CAP CO JEN 0012556 15 "general industry" -- are misplaced when applied to construc tion and other non-fixed workplaces. The unique characteris tics of these workplaces require a fresh approach which is feasible and cost-effective, enforceable, and likely to encourage voluntary compliance as well as the development of safer products and work practices. In the next section, we show, using asbestos as an example, that such a regulatory strategy can indeed be developed for construction and other non-fixed workplaces. III. EXPLANATION AND ADVANTAGES OF THE MODEL STANDARD RECOMMENDED BY AIA/NA AND AACPP In our view, occupational health standards should serve a number of different objectives. First, they should be enforceable regulations which adequately protect workers from occupational health hazards. Second, they should be practical regulations 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 third, they 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. AIA/NA and AACPP believe that none of these goals need be sacrificed in developing an asbestos standard for construction and other non-fixed workplaces. CAP CO JEN 0012557 16 Our alternative would achieve these objectives by establishing a classification scheme which would rank asbestoscontaining products according to their potential for releasing airborne asbestos fibers in excess of the permissible exposure limits. The basis for classifying each product would rest upon qualified laboratory tests that, over time, will be tested repeatedly by OSHA enforcement officials. Based on this classification scheme, our alternative would impose regulatory requirements commensurate with the exposure risk presented by each product, applying more stringent requirements for higher-risk products, including full compliance with the existing standard for products ("Category C Products") presenting the greatest risk of exposure above permissible levels. Attached to this paper is a Model Standard which would implement our recommendations. After explaining the details of our Model in Part III.A. below, we discuss in Part III.B. the advantates of this approach over the current OSEA asbestos standard. A. Explanation of the Model Standard 1. Scope and application Our Model Standard would apply, to "construction work and other non-fixed places of employment where asbestos or products containing asbestos are processed or used." Model H (a). The definition of the term "construction work" in CAP CO JEN 0012558 17 Paragraph (b)(6) is identical to OSHA's definition of the term under its General Industry Standards. 29 C.F.R. 1910.12. In addition, our model contains a non-exclusive listing of the principal construction activities where occupational asbestos exposures occur, including the removal of asbestoscontaining materials from buildings, the spraying of asbestoscontaining materials, and other activities involving the processing of such materials which may produce exposures. Model U (a). We also define the term "non-fixed work operation" to refer to "jobs which do not involve regular assignment to a particular location or set of locations." Model H (b)(7). The purpose of this provision is to include highly mobile non-construction operations such as oil well drilling (dis cussed in the Appendix, Part C), where asbestos exposures may occur under circumstances similar to construction activities. Lastly, the Model contains a provision which clearly separates the coverage of the current OSHA asbestos standard from the proposed new construction standard. The current standard does not contain any specification of scope and application, but the provisions of the standard make clear that it applies to any workplace where there is occupational exposure to asbestos. Accordingly, our Model adds to the current standard a new paragraph which excludes construction and other non-fixed workplaces which would be covered by the proposed new standard. CAP CO JEN 0012559 18 2. Product Classification The categorization of asbestos-containing products according to their fiber-release potential is the foundation of our recommended approach. Our Model would establish three product categories (called "Category A," "Category B" and "Category C" Products) which are defined according to a product's capacity, under reasonably forseeable conditions of processing or use in construction and other non-fixed operations, for releasing airborne asbestos fibers in excess of the permissible exposure limits. As we discuss later, different regulatory requirements would apply to each product category, both to reflect the degree of risk associated with each type of product, 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) of the Model as "an abestos-containing product which, under any reasonably forseeable conditions of use, handling or processing, is incapable of releasing airborne concentra tions of asbestos fibers in excess of" the permissible exposure limits. Category A is the safest product classifi cation under our Model and will generally include products in which asbestos fibers are coated, bound or enclosed by other materials in such a way that they will never be released in significant quantities except perhaps in unforseeable cases of intentional misuse, destruction or alteration of the product. As discussed in the Appendix, a number of CAPCO JEN 0012560 - 19 asbestos-containing products used in construction are potential candidates for Category A classification, including mastics, mechanical packings, oil seals, compressed gaskets, sealants and caulks, and electrical insulating paper. A "Category B Product" is defined in Paragraph (b)(2) of our Model as "an asbestos-containing product which, when a specified fabrication, installation or removal method is used, is incapable of releasing airborne concentrations of asbestos fibers in excess of" the permissible exposure limits. In effect. Category B Products are products which are capable of producing airborne asbestos fiber concentra tions in excess of the permissible exposure limits, but will not do so if the correct work procedures, tools or other safeguards are employed. 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, if properly classified. Category B Products do not require the full panoply of typical fixed-site requirements such as monitoring, medical surveillance, regulated areas, and hygiene facilities. So long as the use of proper work practices, tools or other safeguards is ensured, additional requirements are unnecessary or redundant. As discussed in the Appendix, AIA/NA and AACPP have developed data showing that three asbestos-con taining products -- asbestos-cement pipe, asbestos-cement CAP CO JEN 0012561 20 sheet and drilling mud additives -- can be validated as Category B Products. In addition, recommended work practices are being developed and field-tested for two other potential Category B Products: flooring products and built-up roofing with asbestos felts, as well as for demolition in removal operations which, as discussed in the Appendix (pp. 3b-5b), represent perhaps the most significant sources of exposure to asbestos dust in construction work. The last product classification -- "Category C Products" -- covers asbestos-containing products which do not fall into either of the two preceeding categories and are capable of releasing airborne asbestos fibers in excess of permissible levels. Model H (b)(3). Because they possess neither the innate physical characteristics nor the validated work practice controls which are needed to ensure that the permis sible exposure levels are met, Category C Products present the greatest potential for dangerous asbestos exposures, and accordingly require the most stringent regulatory controls. 3. Validation For any product classification scheme to be successful, it is, of course, necessary to provide adequate assurances that products will properly be classified. Our Model employs three devices for achieving this goal: (i) validation by qualified testing laboratories, (ii) objective performance criteria, and (iii) empirical field confirmation by OSKA in connection with workplace inspections. CAPCO JEN 0012562 21 The Model makes clear that a construction industry employer can treat a specific product as falling within Category A or B only if he "reasonably relies on objective data, developed by a Certified Testing Laboratory." Model HU (c) & (d)(1). Paragraph (b)(5) of the Model defines a "Certified Testing Laboratory" as a laboratory approved by the American Industrial Hygiene Association (AIHA) and certified by the National Institute of Occupational Safety and Health (NIOSH) as qualified to test for airborne concen trations of asbestos fibers using the method prescribed in the current OSHA asbestos standard. The use of laboratories which are certified by both AIHA and NIOSH provides an important safeguard against invalid or falsified product classifications. An additional safeguard is provided by the inclusion of objective performance criteria for classification. The Model requires "objective data . . . which show, within confidence limits of 95 percent," that a product falls into a particular category. Model UU (c) & (d)(1). This require ment would force validating laboratories to design and conduct careful field tests which account for the varying conditions present in construction and other non-fixed workplaces, and to establish, within 95 percent confidence limits, that the applicable exposure limitations will not be exceeded, either under any reasonably forseeable use (in the case of Category A Products), or where specified work CAP CO JEN 0012563 - 22 practices are used (in the case of Category B Products). As discussed in greater detail below (pp. 30-31), the range of uncertainty inherent in analytical methods for measuring airborne asbestos fiber concentrations will therefore have been taken into account in determining whether the product or work practice can be expected to maintain exposures below the permissible exposure limit. Notwithstanding these safeguards, our Model does not give Certified Testing Laboratories the final word on product classification. Instead, it requires "reasonable reliance" by employers on the data supplied by the validating laboratory. Model HU (c) & (d)(1). The Model does not attempt to define "reasonable reliance," but rather leaves that issue to case-by-case determination in enforcement proceedings. Certainly the reputation of the validating laboratory, the employer's previous experience with the laboratory, the facial completeness of the data and the laboratory's specific conclusions would be relevant considerations. 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 applicable exposure limits were exceeded notwithstanding the use of Category A Products or the use of Category B Products together with proper work practices, an employer's ability to continue to rely "reasonably" on the data supplied by the validating laboratory would be placed in doubt, depending on the accuracy CAPCO JEN 0012564 23 and extent of data provided by OSHA in each case. This feature of our Model gives OSHA a vehicle for monitoring and verifying the correctness of product classifications. 4. Regulatory requirements Our Model imposes different regulatory controls on each product category, and tailors the applicable controls to the degree of the exposure hazard presented by each type of product. Operations involving Category A Products are exempt from the existing standard by Paragraph (c) of the Model. Since Category A Products do not present a risk of dangerous exposures under any reasonably forseeable circumstances, no new regulatory requirements are imposed. Moreover, as discussed in greater detail below, the absence of regulatory controls on Category A Products creates a strong incentive for the development and use of products which will not lead to excessive exposure under any reasonably foreseeable circumstances. There is one situation where the exception of Category A Products from the current standard does not apply: As discussed in greater detail in the Appendix (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, but could be exposed to excessive concentrations of asbestos dust in an emergency or from .dust which has CAP CO JEN 0012565 24 accumulated in normally inaccessible places such as on pipes and ductwork. Accordingly, Paragraph (c)(2) of our Model makes the "emergency" and "housekeeping" provisions of the current standard applicable in those special circumstances. For operations involving Category B Products, the Model requires employers to comply with the "fabrication, installa tion or removal methods" which qualify the product for the Category B classification. Model If (d)(1). The expression "fabrication, installation and removal method" is broadly defined in Paragraph (b)(4) to include any combination of engineering, work practice or administrative controls. It expressly excludes, however, the use of respirators as a permissible means of validation. While we expect that, because of the special features of the construction industry discussed above (pp. 6-15), work practice controls will be the predominant mode of compliance, the purpose of the definition is to permit the use of tools with local exhaust ventilation or work scheduling as ancillary protective measures. Several additional requirements are imposed to ensure the use and effectiveness of the validated work practices and other pretective measures. First, the warning sign, labeling and housekeeping requirements of the current OSHA standard, together with its provisions governing the use of respirators in emergencies, are made applicable to workplaces where Category B Products are used. Model H (d)(2). Second, r.apr.o .ifn nmpsee 25 - manufacturers of Category B Products are required to include on caution labels "a reference to the "fabrication, installa tion or removal methods which have been validated" for the products in question, and "a recommendation that such work practices, tools or other measures be used." Model H (d)(3). Third, the employee education and training provisions of Paragraph (f) of the Model apply to .operations involving Category B Products, and include a requirement that employers provide as part of the training program "specific instructions concerning the proper use of [the] fabrication, installation or removal methods" which were validated as part of the Category B classification. Model H (f)(1)(ii). For operations using Category C Products, which pose the greatest potential for exposure, the current OSHA asbestos standard would apply in full. Model H (e). As discussed above (p. 20), 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, AIA/NA and AACPP believe that, in the case of Category C Products, those provisions should be applied both to ensure adequate health protection for workers and to provide a strong incentive for developing safer products and work practices. Our Model also imposes a new employee education CAPCO JEN 0012567 26 and training program (not provided in OSHA's current asbestos standard) on operations involving Category C Products. Model II (f). 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. As a result, if a construc tion 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 classification are met. In addition, in the case of Category B Products, employers are subject to citation for failing to follow the validated work practices or the warning sign, labeling, housekeeping, and training requirements, even if the classification criteria have been met. B. Advantages Over OSHA's Typical Fixed-Site Health Standard Our Model Standard for Asbestos Exposure in Construction and other Non-fixed Work Operations has a number of distinct advantages over the current OSHA regulation. First, our Model imposes practical requirements which nevertheless provide ample assurances for worker protection. Second, it creates incentives for the development of safer products and CAP CO JEN 0012568 27 work practices without sacrificing the economic and practical needs of the construction industry or the economy as a whole. And third, our Model is an enforceable regulation which is more likely to encourage voluntary compliance than the current OSHA scheme. 1. Worker protection To be sure, the Model Standard we propose departs significantly from the provisions of the traditional OSHA health standard. In particular, the usual OSHA requirements for monitoring, medical surveillance, regulated areas and hygiene facilities are not applicable to Category A and B Products under the Model. Nevertheless, as we demonstrated above (pp. 6-15), these fixed-site requirements are plainly impractical in construction and other non-fixed operations and contribute little to worker health. Even if it had unlimited enforcement resources, OSHA could not hope to achieve widespread compli ance with these provisions, and construction employers would be left with the "Hobson's choice" of risking noncompliance penalties or abandoning highly useful or, in some instances, essential products. OSHA itself has, on occasion, limited or modified its traditional regulatory approach in an effort to avoid stan dards which impose sweeping requirements without any signficant or commensurate health gain. OSHA's current labeling CAPCO JEN 0012569 28 requirement for asbestos-containing products, for example, 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 requirement of OSHA's current asbestos standard contains an identical exemption. 29 C.F.R. 1910.1001(g)(2)(i) and (h)(2). Similarly, EPA's national emission standard for asbestos carefully distinguishes among product categories according to their fiber-release potential, and exempts what it calls "encapsulated" asbestos-containing products from the require ments covering demolition and renovation, spraying and waste disposal. 40 C.F.R. 61.22(d), (e)(3), (j)(4). In effect, both EPA and OSHA have recognized that some asbestos-containing materials do not pose an exposure threat which is significant enough to justify expensive regulatory controls. Another example of an effort to prevent unduly broad application of monitoring, medical surveillance and other typical OSHA requirements is OSHA's Inorganic Arsenic Standard, which excludes workplaces where inorganic arsenic is present in only small amounts. OSHA justified an exemption in that case as follows: [A]rsenic is a naturally occurring material and is present in small amounts in many substances. It is therefore CAPCO JEN 0012570 29 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. 19612 (May 5, 1978). Similarly, OSHA's Cotton Dust Standard contains a series of exemptions where application of the standard would achieve little at great cost, including (i) maritime workers, because the "limited duration of exposure makes it unlikely that cotton dust exposure is significant for an appreciable number of the workers handling water borne shipments of cotton"; (ii) workers handling "washed cotton," because of the effectiveness 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 environments and possibilities for control." 43 Fed. Reg. 27831-32 (June 23, 1978). OSHA took a similar approach in formulating its Benzene Standard. There, it exempted gasoline stations and other operations where the standard would have a sweeping impact, but where exposures are not likley to exceed permissible limits. 29 C.F.R. 1910.1028(a)(2); 43 Fed. Reg. 27962 (June 27, 1978). OSHA's Acrylonitrile (AN) Standard, which more closely resembles the alternative standard we propose for asbestos exposure in the construction industry, also reflects an effort to adapt the traditional regulatory approach to CAP CO JEN 0012571 30 unique circumstances. The AN standard imposes the traditional fixed-site requirements on manufacturers of products con taining AN, but exempts downstream processors and fabricators of such products 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 and OSHA, and would not be reasonable in light of the degree of exposure involved." 43 Fed. Reg. 45762, 45776 (October 3, 1978). Our Model goes beyond the AN standard in protecting worker health. First, the Model requires that product and work practice testing be performed only by fully qualified testing laboratories. Second, it provides objective perfor mance criteria which require a high statistical degree of confidence (95 percent) 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 CAP CO JEN 0012572 31 sample counts of 2.0 fibers/cc or more.'1--^ Consequently, the Model's 95 percent confidence requirement will, in practice, not be met unless the products and work practices being tested routinely produce measurements far below the permissible exposure limits, adding a significant extra margin of worker safety. 2. Incentives for the development and use of safer products and work practices Apart from providing superior health protection for workers without the objectionable fixed-site features of the current standard, our Model creates strong incentives for the development of safer products and work practices. Under the current standard, construction employers cannot legally avoid burdensome fixed-site requirements such as monitoring or medical surveillance no matter how safe the asbestos-con taining products or work practices which they employ. Thus, they must either ignore the standard to the detriment of employees, or they must stop using extremely valuable construc tion materials, to the detriment of the economy. Under our Model, the threat that the current standard might be enforced in full provides a powerful incentive for the development and use of products or work practices which qualify for Category A or B classification. As a result, two critical objectives would be advanced. First, worker health would be protected through the use of products and 15/ Comments of Johns-Manviile, OSHA Docket H-____ (Asbestos), Ex. 3-185 at ex. D, p. 42. CAPCO JEN 0012573 32 work practices which present no serious risk of dangerous asbestos exposure. Second, the current incentive for acrossthe-board substitution of inferior non-asbestos-containing products 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. 3. Enforceability The third principal advantage of our approach is that it will ease the tremendous enforcement burden OSHA faces in policing the 3 to 5 million workers potentially exposed to asbestos in hundreds of thousands of construction sites throughout the nation. Under our Model, in a large majority of cases, OSHA inspectors may have to do nothing more than determine whether the proper products and work practices are being used -- a task much simpler and less time-consuming and expensive than under the current standard, where exposure monitoring may have to be conducted and employer 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 Model allows OSHA to' focus its enforcement activities on identifying improper product classifications. As discussed above, once sampling results from OSHA inspections indicate that a CAPCO JEN 0012574 33 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. Finally, our Model is far more likely to result in voluntary compliance and cooperation by construction employers and employees alike. In contrast to the current OSHA standard, the requirements of our Model are workable, practical and far better-suited to the everyday realities of construction and other non-fixed work operations. Accordingly, employers and employees will be far more willing to take the precau tionary measures which are essential if worker health is to be protected, and OSHA will thus be able to more efficiently allocate its finite enforcement resources among the many health and safety standards it is required to police. IV. 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, repeated monitoring and medical surveillance as well as other requirements designed for fixed-site jobs in manufacturing industries, is simply not feasible, nor do its enormously expensive require ments contribute appreciably to the health of construction CAPCO JEN 0012575 34 - workers. Even if it could be enforced by OSHA, the current asbestos standard would only result in the substitution of inferior materials or, in some cases, the stoppage of con struction work altogether. AIA/NA and AACPP believe that the better approach is to substitute a regulatory scheme which strongly encourages the use of products and 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 incen tives for the development and use of safer products and work practices, and considerably eases OSHA's enormous enforcement burden. We strongly commend this approach to the Subgroup, the Advisory Committee, and OSHA. The Asbestos Information Association of North America and The Association of AsbestosCement Pipe Producers CAPCO JEN 0012576 MODEL ASBESTOS STANDARD FOR CONSTRUCTION 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, except as provided in Section 1910.1001a." 2. A new Section 1910.1001a is added as follows: "1910.1001a Asbestos Exposure 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 contain ing asbestos are processed or used, including (i) the removal of asbestos or mixtures containing asbestos from buildings or other structures; (ii) the spraying of asbestos or mixtures containing asbestos; (iii) dry handling or use of free asbestos fibers, either alone or together with other mate rials; and (iv) dry sawing, drilling, milling, sanding, tapping, scoring, punching, shearing, or otherwise abrading CAP CO JEN 0012577 2a - or violating the integrity of products or materials contain ing asbestos. "(b) Definitions. "(1) "Category A Product" refers to an asbestos- containing product which, under any reasonably foresee able conditions of use, handling or processing, is incapable of releasing airborne concentrations of asbestos fibers in excess of (i) an eight-hour timeweighted 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. "(2) "Category B Product" refers to an asbestoscontaining product which, when a specified fabrication, installation or removal method is used, is incapable of releasing airborne concentrations of asbestos fibers in excess of the exposure levels specified in Subparagraph (1) of this Paragraph. "(3) "Category C Product" refers to a product which is neither a Category A Product nor a Category B Product, and the processing or use of which may result in the release of asbestos fibers in excess of the exposure levels specified in Subparagraph (1) of this Paragraph. "(4) "Fabrication, Installation or Removal Method" means any combination of engineering controls, tools. CAP CO JEN 0012578 3a equipment, work practices, and task assignment strategies for controlling occupational exposure to airborne asbestos fibers. "(5) "Certified Testing Laboratory" means a labo ratory approved by the American Industrial Hygiene Association and certified by the National Institute for Occupational Safety and Health as qualified to test for asbestos fibers using the membrane filter method specified in Paragraph (e) of Section 1910.1001. "(6)'"Construction work" means work for construc tion, alteration, and/or repair, including painting and decoration. "(7) "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 assign ment to a particular location or set of locations. "(8) All other terms used in this Section shall have the meanings prescribed in Section 1910.1001 and in Section 3(8) of the Act, 29 U.S.C. 652(8). "(c) Category A Products. "(1) Any employer who reasonably relies on objective data, developed by a Certified Testing Laboratory, which show, within confidence limits of 95 percent, that one or more asbestos-containing products are Category A Products, is exempted from the provisions of Section 1910.1001 as they apply to workplaces or opera tions where such Category A Products are processed or CAP CO JEN 0012579 - 4a - used, except as provided in Subparagraph (2) of this Paragraph. "(2) Where a construction or other non-fixed work operation involving Category A Products is located in a workplace or facility which manufactures or fabricates products containing asbestos, Paragraphs (d)(l)(iii) and (h) of Section 1910.1001, relating to the use of respirators during emergencies and housekeeping, shall apply to such construction or other non-fixed work operation. "(d) Category B Products. "(1) Validation. Any employer who reasonably relies on objective data, developed by a Certified Testing Laboratory, which show, within confidence limits of 95 percent, that one or more asbestoscontaining products are Category B Products, is exempt from the requirements of Section 1910.1001 with respect to operations where such products are used, provided that the employer takes all practicable measures to ensure the use of the fabrication, installation or removal methods which qualify the product as a Category B Product. "(2) Emergencies, Warning Signs, Caution Labels, and Housekeeping. Notwithstanding the provisions of Subparagraph (1) of this Paragraph, employers who use fabrication, installation or removal methods validated CAP CO JEN 0012580 5a under Subparagraph (1) of this Paragraph shall comply with Paragraphs (d)(l)(iii), (g) and (h) of Section 1910.1001, relating to the use of respirators during emergencies, warning signs, caution labels and house keeping. "(3) Notification. Any manufacturer of a Category B Product which is required to be labeled under Paragraph (g)(2) of Section 1910.1001, and for which fabrication, installation or removal methods have been validated under this Paragraph, shall include on such labels for such products a reference to the fabrication, installa tion or removal methods which have been validated and a recommendation that such fabrication, installation or removal methods be used. "(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 apply to any operation within the scope of this Section which involves the processing or use of Category C Products. "(f) Employee Education and Training. (1) All employers covered by this Section shall institute a training program for employees who process or use products containing asbestos (except for Cate gory A Products covered by Paragraph (c) of this Sec tion) and shall assure that each such employee is informed of the following: CAPCO JEN 0012581 6a - "(i) the operations where asbestos-containing products are processed or used, and the conditions of processing or use under which exposure to airborne asbestos fibers may take place; "(ii) if the employer intends to use fabrica tion, installation or removal methods which have been validated under Paragraph (d), the training program shall include specific instructions concerning the proper use of such fabrication, installation or removal methods. "(2) The training program required under this Paragraph shall be provided within 90 days of the effective date of this Section or at the time of ini tial assignment of an employee to a workplace where asbestos or products containing asbestos (except for Category A Products covered by Paragraph (c) of this Section) are processed or used, and at least annually thereafter. "(3) Upon request, the employer shall make avail able to employees, the Assistant Secretary or the Director, all materials relating to the information and training program instituted under this Subparagraph, and any objective data concerning the validation of fabrication, installation or removal methods used by the employer pursuant to Paragraph (d) of this Section. CAP CO JEN 0012582 7a "(3) Upon request, the employer shall make avail able to employees, the Assistant Secretary or the Director, all materials relating to the information and training program instituted under this Subparagraph, and any objective data concerning the validation of fabrication, installation or removal methods used by the employer pursuant to Paragraph (d) of this Section. CAP CO JEN 0012583 APPENDIX A Preliminary Assessment of How the Model Asbestos Standard Can Successfully Be Implemented in Construction and Other Non-Fixed Work Operations CAPCO JEN 0012584 TABLE OF CONTENTS Page Introduction: Potential Asbestos Exposure in Construction and Other Non-Fixed Work Operations.................................................... 3b A. Recommended Work Practice Procedures for Asbestos-Cement Pipe............................... 9b 1. Sampling methodology and opera tions sampled for asbestos-cement pipe.................................................................. 38b 2. Methods........................................................... 39b 3. Operations sampled................................. 40b B. Recommended Work Practice Procedures for Asbestos-Cement Sheet..................... 49b C. Recommended Work Practice Procedures for Drilling Mud Additives.......................... 71b CAPCO JEN 0012585 APPENDIX A Preliminary Assessment of. How the Model Asbestos Standard Can Successfully Be Implemented in Construction and Other Non-Fixed Work Operations As discussed in the body of this paper, the Model Stan dard 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 pro vide incentives for the development of even safer products and work practices, 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 our Model is more than just an appeal ing theoretical construct -- rather, it is a workable regu lation which will impose requirements which are both accept able and cost-effective. We begin with an Introduction which presents background information and data on the situations where exposure to air borne asbestos fibers may occur in construction and other non-fixed work operations. The introduction also assesses preliminarily, based on our experience with these products CAP CO JEN 0012586 2b and our knowledge of their physical properties, the product classifications (Categories A, B or C) of our Model Standard under which the materials now in use are likely to fall. Following this preliminary qualitative assessment, the three succeeding sections of this Appendix contain detailed quantitative documentation showing that three asbestoscontaining products commonly used in construction and other non-fixed jobs -- asbestos-cement pipe, asbestos-cement sheet, and drilling mud additives -- can in fact qualify as Category B Products under our Model. More specifically, simple work practices which have been developed by the manu facturers 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 all three products can be validated as Category B Products^ */ The exposure data presented in Parts A, B and C of this Appendix must be interpreted cautiously. As discussed in the body of this Paper (pp. 30-31 above), the best available tech nique for measuring airborne concentrations of asbestos fibers is subject to a considerable degree of uncertainty, the magni tude of which (when expressed as a percentage of the actual concentration) increases sharply at 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 in Parts A, B and C below are so uniformly low that we are confident that the products and work practices discussed can meet the classi fication criteria for Category B Products. CAP CO JEN 0012587 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 circumstances 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 con tractor disturbs asbestos-containing dust which has accumu lated in inaccessible places (for example, on suspended piping, ducts or wiring or on structural surfaces), special precautions (such as spraying with water or vacuuming) may CAPCO JEN 0012588 - 4b - have to be taken to avoid creating airborne fiber concentra tions in excess of mandated levels. As detailed above (pp. 23-24), the housekeeping and emergency provisions of Paragraphs (c)(2) and (d)(2) of our Model Standard are intended to deal with these special circumstances. The second health hazard situation will arise when a con tractor performing maintenance, alteration or demolition work must remove construction materials containing asbestos. This, without doubt, is 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 opera tions. Mandating changes in asbestos construction materials, or even banning their manufacture or sale, will not elminate the hazard. Nor can permanently installed engineering con trols be used to control asbestos dust created by demolition or removal. AIA/NA and AACPP have been studying these opera tions, and expect to be able to certify in the near future CAPCO JEN 0012589 5b - effective work practices which would qualify under Category B of the Model Standard. The third health hazard situation, of course, involves the fabrication and installation of asbestos-containing construction materials currently offered in the marketplace. Fortunately, 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. Most molded thermal insulations contain no asbestos, and the few that do are used only in the most critical installations, applied by journeymen who are thoroughly familiar with the hazards of asbestos and who know well how to protect themselves. The asbestos fibers in asbestos-cement products, asbestos-roofing and pipeline felts, drilling muds, paints, roofing mastics, vinyl asbestos floor tile and sheet vinyl flooring 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, CAP CO JEN 0012590 6b with asbestos-cement products, flooring products, friction materials, and asbestos-paper products comprising two-thirds total consumption: 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.--*'/ Moreover, based on our considerable experience with V See OSHA's Proposed Standard for Occupational Exposure to Asbestos, 40 Fed. Reg. 47652, 47653 (October 9, 1975). CAP CO JEN 0012591 7b the use of these products in construction operations, our familiarity with their physical properties, and the results of preliminary testing, there is little doubt that the overwhelming majority of these products could be validated under Categories A or B of our Model Standard. Because of the efforts of manufacturers of asbestos-containing construction materials to eliminate dangerous products from the market place, the only product currently in use which may fall within Category C is untreated textiles, and 99 percent of all the asbestos-containing products currently consumed in the United States are likely to fall within Categories A and B.--* '/ In fact, as much as 50 percent of current asbestos consumption could qualify under Category A, including the following products:*-'/ Mastics and Black Line Products Roofing Felts Mechanical Packings Oil Seals Compressed Gaskets Sealants and Caulks Electrical Insulating Paper Sheet Flooring Floor Tile V Source: Johns-Manville Corporation CAP CO JEN 0012592 8b The remaining products would likely qualify under Category B of the Model Standard. In the three succeeding sections of this Appendix, we present detailed exposure monitoring data showing that effective work practices, which in some cases are already widely used, will ensure that the permissible exposure limits are met for three of these products: asbestoscement pipe, asbestos-cement sheet, and drilling mud additives. CAP CO JEN 0012593 9b Recommended Work Practice Procedures for Asbestos-Cement Pipe CAP CO J1E N 0012594 - 10b - In order to reduce the generation of airborne concen trations of asbestos during the installation of A/C pipe, ACPPA designed a field manual containing specific work prac tices for use with its products. ACPPA 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, ACPPA 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 CAP CO JEN 0012595 lib - 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-IOO 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 conducted. 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 CAP CO JEN 0012596 12b - 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 CAP CO JEN 0012597 13b in pages below. The following tables summarize the results EEH obtained during its validation tests. In reporting these results, EEH cautions: "It should be emphasized that estimates of fiber concentrations below 5 f/cc are subject to increasing lack of precision, and that those below 0.5 f/cc have a fairly wide margin of error, often being based on the obser vation of relatively few fibers. Thus, although counts are reported as calculated (in some cases) to two decimal places, differences in counts in these ranges should not be over interpreted. " CAPCO JEN 0012598 - 14b - 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 Minutes) During 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 <-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 ND 49.20 59.70 0.87 0.22 0.18 2.23 0.18 0.27 CAP CO JEN 0012599 15b Operation 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 0.44 5b. Hole Cutting with Drill, Hammer & Rasp 0.23 6a. Dry Tap with Mueller J Tool 40.10 6b. Tapping Operations with Mueller B-100 <0.10 7. Coupling Removal 7a. Removal of Coupling with Hammer & Chisel 40.10 ND 40.10 4o.io 0.23 0.13 1.65 0.22 4.0.10 ND < 0.10 0.11 ND 0.30 40.10 0.13 40.10 0.38 4 0.10 0.10 0.13 0.10 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 cutting with abrasive discs. As indicated in the summary data, significant peak exposures can result from their use. CAPCO JEN 0012600 16b 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 not 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 .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 <0.10 ND A/C Pressure Pipe Operator Helper ND ND 0.25 <0.10 < 0.10 <0.10 ND 0.11 <0.10 <0.10 0.16 <0.10 < 0.10 <0.10 CAP CO JEN 0012601 Operation - 17b 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. CAP CO JEN OOI2602 - 18b 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 ND 3. Cutting Operations 3a. Hack Saw *<0.10 ND-<0.10 ND ND-CO.10 3b. Snap Cutting ND-<0.10 ND-<0.10 ND ND 3c. Chisel, Hairaner 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 <0.10 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 weire<0.10 f/cc. CAPCO JEN 0012603 - 19b 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 ND-<0.10 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, ACPPA published and distributed nearly 85,000 copies of its field manual, "Recommended Work Practices for A/C Pipe.1' 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." ACPPA 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 CAP CO JEN 0012604 20b 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. CAP CO JEN 0012605 / \ - - 21b cr j Li n n i= u ii :n jc CAP CO JEN 0012606 22b - Products and Operations Types ofAVCFipe Products covered by these work practices indude: "Class" Pressure Pipe "Transmission" Pressure Pipe Pressure Sewer Pipe Gravity Sewer Fire Building Sewer Pipe Storm Drain Pipe * Perforated Underdrain Pipe Electrical Conduit Telephone Duct iorDuct Operations to which these work practices apply indude: Shipping, Receiving and Handling Cutting Machining Hole Cutting Tapping Coupling Removal Housekeeping and Waste Disposal CAPCO JEN 0012607 V., L r L ri ;. c u n t i t_ r- - 23b CAPCO JEN 0012608 I .u n L n li ni t.: n !,, G r L CAP CO JEN 0012609 ! Cutting ] Snap Cutting Equipment I L p .i Li nL Ji P' iili i#/Js IN u .nI !1 S*p cutters or "squeeze and pop" equipment operates faymeans ofratting wheels mounted in a chain wrapped around the pipe baereL Hydraulic pressure, applied by means of a remote electric ccmanually-operated pump, 'simultaneously squeezes the cut- u tag wheels into the pipe wall until the cut is made. AC Pipe Products: All See Range: Pressure Pipe--3* through 24' Pressure, Gravity and Building Sewer; Storm Drain; Air, Eecirieal and Telephone Duct--3' through 36' CAPCO JEN 0012610 .\. i i... G - 26b - Machining Field Lathe--Manual GTD n H Manual field lathes are designed to end-tea and re-machine L-i naugh pipe barrels to factciy-machined end profiles. The lathe consists of an adjustable, self-aligning arbor inserted into the ppe bore (which acts as a mandrel upon which the turning i fisindle operates), a screw-fed turning frame, carbide machining U | Hades and manual (hand or ratchet) turning handles. n i SJC Pipe Products; AH Sze Range; All CAP CO JEN 0012611 27b < j ; ti i 1 .! CAP CO JEN 0012612 - 28b - Machining jjj Rasp-Manual* jj | A/C Pipe Products: AU Size Range All J| | Exposure dza not currently available. Recccuscndattcn bwi cn exposure data fer operations believed to be comparable. i CAP CO JEN 0012613 Hole Cutting Shell Cutteis L j. 2'3b - r iI -ii; i iji L n : LI- HP tit- !n For field connexions into A/C pipe, dean, even entry cuts may be accomplished by means of shell cutting equipment. Shed cutters consist of a hole cutter housing mounted on the pipe, a carbide or diamond-tipped hole cutter and a manual ratchet, j pneumatic, electric or gasoline drive to power the cutting head. J When cutting holes in A/C pipe products, all dust and cuttings 1 should be removed torn the pipe or duct interior after the cutting J operation. Removal may be accomplished by Cushing with wa- | ter, wet mopoing or vacuuming prior to placing in service. DO 3 NOT BLOW C3UT WITH COMPRESSED AIR OR DRY SWEEP. 4 j A/C Pipe Products: Pressure, Gravity and Building Sewer: l 'ii Sice Range: AH Air Duct L CAP CO JEN 0012614. X-- i- ? i ! 0 0 :Q Ir 0 n n _ Li ] n ri i - 30b - Hole Cutting Drill and Rasp* f Field connections may- be made with a heavy duty electee drill and rasp. Using a carbide-tipped drill, a series of dcseiy-spaeed holesare first drilled around'the hoie outline. The disc is knocked free with a hammer and the edges of the hole are dressed with a coarse wood rasp. When cutting holes in A/C pipe products, all dust and cuttings shouldbe removed from the pipe or ductinterior after the cutting operation. Removal may be accomplished by Gushing with wa ter, wet moeping or vacuuming prior to placing in service. DO NOT BLOW OUT WIIH COMPRESSED AIR OR DRY SWEEP. A/C Pipe Products; Pressure, Gravity and Building Sewer; Air Duet Size Range: All Stposur* data not csrrendy available. Seeocmendatfon based on exposure data for operations beiieved to be comparable. CAP CO JEN 0012615 L ; r 0 :0 D n .G ; r!" ' [_ L if i Hole Cutting :p4.! Chisel and Rasp ;)! = 'j! ; - 31b - i ' ; ill it 1,1! ill t-.i IS: Holes may be cutinto AJC pipe with a-haramer and chisel. The edge of a plumber's-wood chisel is used to rat completely around the hole outline, about a V*' from the prescribed line. The opera tion is repeated and the cut deepened "until through. The edges of the hole axe then dressed with a coarse wood rasp. When cutting holes in AJC pipe products, all dust and cuttings shouldbe removed from the pipe or ductinterior after the cutting operation. Removal may be accomplished by Gushing with wa ter, wet mopoing or varaumine prior to placing in service. DO HOT BLOW OUT WITH COMPRESSED AIR OR DRY SWEEP. AJC Pipe Products: "Pressure, Gravity and Building Sewer; AirDuct Site Range: All CAPCO JEN 0012616 - 32b - Tapping Non-Pressure ij n L. n r Non-pie;sure or "dry" tapping for service connections may be performed in or above the trench- The equipment is afSxed to the pipe by means or a chain yoke. Separate drills and taps or a combination tool drills and taps the pipe wail. Corporation stops o or other connections may then be affoced- to the pipe. To minimize (a) the fouJing of valves, regulators, meters, etc with Chios and (b) unnecessary addition of asbestos to drinking water, all dust and cuttings should be removed from the pipe interior by flushing with water, wet mooping or vacuuming prior to placing in service. DO NOT BLdW OUT WTTH COM PRESSED AIR OR DRY SWEEP. AIQ Pipe Products: Pressure Pipe Size Range: All I Exposure data not cuaer.dy available. Recouuner.dadon based on ecpoaure data for operations believed to be comparable. CAPCO JEN 0012617 .. * t t r if i i V... r r L* r-- j: L. C Tapping Pressure s* - 33b - C r* G L |5 i-J-P ' `1 ' K .i' .?, : !.' ;. I ;;; j it Pressure or "wet" tapping tcrservice connections is performed in the trench while the* pipe is under pressure. The equipment (manual or power driven) is axnxed to the pipe by means of a chain yoke. A combination boring and inserting bar drills and taps the pipe wall and insera a corporation stop or pipe plug. The pressure chamber, which protects against water lealage, also catches the asbestos-cement chips, so this is essentially a dust- free operation. To minimize (a) the fouling of valves, regulators, meters, etc. with chips and (b) unnecessary addition of asbestos to drinking water, provisions should be made for downstream flushing or use of tapping equipment with positive purge or "blow-off' features. A/C Pipe Products: Pressure Pipe Size Range: All *Scpcaun dia not csreatiy available. Rgcssaaendation feared on ceserme dat> for operations believed to be csisraxabie. CAPCO JEN 0012618 34b ;v Is r D D G G r /* i ! CAP CO JEN 0012619 - t - 35b i 11 U o L i 0 [ c Housekeeping and Waste Disposal Eousekeepingis an importantpart of any safe construction operation. It is even more essential when airborne dust treated by the loot of good housekeeping has the potential ibr harm to employees or others. EQUIPMENT: All external surfaces of equipment should be maintained free of dust accumulations that might, if dispersed, create 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 pipeline. Where operations are performed at a central location r such as a contractor's or distributor's yard on a more orless 4.` " I . continuing basis, the chips and cuttings may be collected and mixed wet with cement and made into non-friable Sums. 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 closed containers impermeable to asbestos dnst Loose material should never he dry strept. When vacuum equipment is available, it should be used. Water or other I 'I dnst suppressants should be applied in those circum stances where sweeping is unavoidable. DO NOT BLOW WASTE MATERIAL* WITH COMPRESSED AIR. i No visible emissions to the atmosphere may result from the collection, processing, packaging, transporting or de h position of any asbestos-containing material. Wastes .i diould be disposed at a site operated in accordance with the requirements or applicable national, state cr local laws. U r i L-- 1 CAP CO JEN 0012620 I - 36b - NON-SHCOMMENDED PRACTICES \ Section 2. Non-Recommended Work Practices Cutting Any A-C Pipe Using Abrasive Disc-Dry Toais. n u D T7 : L J : V Power-driven saws with abrasive discs (masonry blades) should not be used for dry earring or beveling A-C pipe. Abrasive disc cutters produce concentra tions of airborne dust that exceed OS HA permissible levels. This workpractice is therefore specifically not recommended. CAPCO JEN 0012621 37b WORK practices for ASBESTOS-CEMENT pipe Machining Any A-C Pipe Using Right-Angle Sanders or Other Dry High-Speed Abrasive Tools. Power-driven abrasive-disc sandets should not be used for shaping or beveling A-C pipe. Abrasive discs produce concentrations of airborne dust that exceed OSHA permissible levels. This work practice is therefore specifically not recommended. t. i;1f CAPCO JEN 0012622 - 38b - I Sampling Methodology and Operations Sampled for Asbestos-Cement Pipe CAP CO JEN 0012623 - 39b 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 pumps 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. CAPCO JEN 0012624 - 40b 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 CAP CO JEN 0012625 41b 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 equipment. 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. J CAPCO JEN 0012626 42b 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 CAP CO JEN 0012627 i - 43b - 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 CAPCO JEN 0012628 44b 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 CAP CO JEN 0012629 45b 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. CAPCO JEN 0012630 46b 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 CAP CO JEN 0012631 47b 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 CAP CO JEN 0012632 48b 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. CAP CO JEN 0012633 - 49b Recommended Work Practice Procedures for Asbestos-Cement Sheet CAP CO JEN OOI2634 50b - 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. CAPCO JEN 0012635 51b - 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. CAP CO JEN 0012636 52b Table XV Air Monitoring Test Results Using Circular Saw and Drill Equipment Test Conditions* Test Duration Material Fabricated Quantity/ Type Quantity Minute Drill with dust pickup shroud 1/A inch mason ary bit, opera ted at full speed. Drilled downward through horizontal board 40 min 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 holes 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 CAP CO JEN 0012637 - 53b - FIELD FABRICATION OF AS3ESTOS-CEHBI7 SHEET t CAP CO JEN 0012638 54b 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. CAP CO JEN 0012639 55b - Shi.3oi.ng. deceiving ar r.ci- S. n n L Li r* 'L A/C sheet is shipped from the'factory with clean surfaces, generally 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. )- CAPCO JEN 0012640 56b Cutting - Plat Sheets Circular Saw______ Circular Saw With Dust Collection Hood Circular saws for cutting flat sheets should be used only 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 "pulverizing" action which releases asbestos fibers and fine particulate. The combination of hood and vacuum source is highly effective in capturing and collecting these particles and fibers. Saw operating techniques are those normally employed. No special procedures are required except adjustment ov the lower hood section to suit thickness of shoot being cut. Saw design requires the use of blades recommended by the tool supplier (abrasive disc or diamond). For additional information cn saw operation, refer to the supplier's instructions in Appendix" A. CAP CO JEN 0012641 - 57b - Cutting - Corrugated Sheets _____Circular Saw__________ f' t r U r u Circular Saw With Dust Collection Hood Circular saws for cutting corrugated sheets should be used only when equipped with the specific dust collection 0 hood pictured above.* Exhaust ventilation and dust collection is provided by a vacuum cleaner as described in the specifications (page IS). 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 in capturing and collecting these particles and fibers. Saw operating L techniques are those normally employed. Saw design requires the use of blades recommended by the tool supplier (abrasive disc or diamond). This tool depends on pliable "fingers" to seal the cutting tone and is designed for use on sheets with 1 1/2" deep corrugations. For cutting sheets with deeper or irregular corrugationsconsult the tool supplier. For additional information on saw operation, refer to the supplier's instructions in Appendix A. \ CAP CO JEN 0012642 - 58b Cutting - Handsaw i r~ L r~ L 0. n< i u Handtools Handsaw This is a handsaw equipped with a carbide blade designed for cutting asbestos-cement sheet. Practical use of this saw is limited by its slow cutting speedy It is most useful in operations where cutting is infrequent and of short duration. Because of the slow cutting speed, saw operation generates coarse particles of asbestos-cement with*few airborne fibers. Its use docs not require dust collection equipment for compliance with present exposure limits. . LJ i CAP CO JEN O01 264-3 59b Catting - I'Ut Sheets Hand dinners Handtools Hand Clippers These hand clippers are designed for cutting sheet material up to 1/4" in thickness. Practical use is limited by siow cutting speed. It is most useful in operations where cutting is infrequent and of short duration. The clipper cutting action generates coarse particles of asbestos-cement with few airborne fibers. Its use does not require dust collection equipment for compliance with present exposure limits. CAPCO JEN 0012644 60b Cutting - Flat Sheets Score 6 Snap Knife The scoring knife can be used with sheets up to 1/4" in , thickness. However, it performs best with sheets 1/S" L. and 3/16" thick. The sheet is placed on a worktable or saw horses. A suitable guide bar is placed or clamped along / the cut line and the sheet scored repeatedly. After scoring, the sheet is hand snapped along the score line. This cutting procedure generates little dust and few airborne fiber?. Its use does not require dust collection equipment for compliance with present exposure limits. CAP CO JEN 0012645 61b Drilling - Power Drill Drill With Dust Collection Kood Drilling of small holes (1/4" or less) on vertical surfaces, or downward usually can be done without dust collection equipment and in compliance with present exposure limits. Drilling of larger holes, and drilling overhead', requires dust collection equipment on the drill in order to achieve compliance. Equipment includes a hood (Cape Universal Building Products, Ltd.) and vacuum cleaner to provide exhaust ventilation and dust collection. Vacuum cleaner should be as described in specifications (page IS). Drilling techniques are those normally employed. No special procedures are required. CAP CO JEN 0012646 -62b Hole Cu ting snd Cutouts _____ Ssbre Saw Flat Sheets r* I... f; r-~ ) ni . Li U C Sabre Saw With Dust Collection Hood Sabre saws should be used only 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 IS). Saw operating techniques are those normally employed. Mo special procedures are required. For additional information on saw operation, refer to supplier's instructions in Appendix A. .L. CAP CO JEN 0012647 64b Hole Cutting and Cutcuts - Drill and 3asn A simple method of making cutouts is to drill small holes around the edge of the opening to be cut and knocking out the material to be removed with a hammer. A rasp is used to dress or bevel edges of the cut. This procedure does not require dust collection equipment for compliance with present exposure limits. CAP CO JEN 0012648 Vacuum Cleaner Specifications (Values shown below are minimum recommended) Circular Saw - Flat and Corrugated Sheet Cutting Vacuum (lift): 59" W.G. (water gage) Airflow: 175 SCFM (standard cubic feet per minute) Filtration S/stem: Multi-stage, designed for use with asbestos-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: 59" W;G. 65 SCFM See Above See Above CAPCO JEN 0012649 66b Housekeeping ar.d Waste Disnosal Housekeeping is an essential part of any safe construction operation. It is even more essential when airborne dust cteated by the taak of good housekeeping has the potential for harm to employees 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 airborne asbestos dust to the atmosphere. Loose material should never be dry swept. When vacuum equipment is available, it should be used. Water or other dust suppressants should be applied in those circumstances where sweeping is unavoidable. DO MOT BLOW WASTE MATERIAL WITH COMPRESSED AIR. Mo 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 EPA waste disposal requirements (40 CrR, Chapter 1, Part 61) refer to Appendix C. CAPCO JEN 0012650 Equipment Suppliers Tools shown in this pamphlet are available from: Wheeler-Pilot International P. 0. Sox 3128 20433 Earl Street Torrance, CA SOS10 (213) 371-1233 Nilfisk of America, Inc. 201 King Manor Drive King of Prussia, PA 19406 (215) 277-3S00 Suppliers claiming to have vacuum cleaning units suitable for use with asbestos-containing dusts are: American Cleaning Equipment Corp., 111 South Route 33, Addison, IL 60101 Beamco, Inc., 707 Stierlin Road, Mountain View, CA S4040 3reuer Electric Manufacturing Co., 5100 h'o. Ravenswooc Ave., Chicago, IL 60640 Hild Floor Machine Co., Inc., 5339 West Lake St., Chicago, IL 60644 Kari-Vac Inc., 4360 W. I27tn St., Alsip, IL 60633 Milfisk of America, 201 King Manor Drive, King of Prussia, PA 19466 Pullman/Holt Products, 10702 46th Street, Tampa, FL 53617 Vac-U-Max, 227 Main St., Belleville, N'J 0 7109 Wheeler-Pilot International, 20433 Earl Street, Torrance, . CA 90510 Mote: It is recognited that equipment suppliers jsthcr than those listed above may be available. Mention of any company is not to be considered an endorsement by AIA/h'A. CAP CO JEN OOI2651 ray: - 68b - cferatzwg zwstructecws E-PELOr ELAT SHEET CZP.CULAP. SAW .gsr; 3; ______ 73 r \ s'- I. i.:- O ,G n. G :=o o i. :U TO CPERATIOW......... ,, easy vacuus cleahers cep.tzpled ze tts^:l'o.-vpactupsr pcr use sera aohssocs rear avc eavewg a csPAsaxrr? or Z7S era *s-3 are to =s esro wars eras rsca. a vacuus rose c~ hop less teas 2 xr:c? leaseter awd :;ct sure teas zs zzz~ lc-ig zs to ss csed zzzvzzs tee :rzs cqwwectce awd vacszs tahx. zee vacuus ioultacttrsr's CPERATZWG ZWSTRUCTECWS SUST ZZ RSIS AWS CWDSRSTCCD 3ZPCPE CPERATZOW. 3. zwspzct asi szspzx elesewts rcr emess, pmmTRss or cpswzhgs, i.e. sees, vacuus ecsz Ain csswsctcrs. rspazr cr replace ass racist ites or part. 4. coarser tee vacuus soszs as secww, iwsurewg all cowwecticws awd clasps arz tiget. tors cw vacuus a;.? csscx pgr Air/ storages cr air zzazs iw ASS ISSUES ASZCCRTZ AZR RLPW IW TER CPSt ARRA OR TER SAW. VACUUS sr cp. sees .6 ZZ ASS ZEAXS CR STORAGES ARE LOCATES, CEAiXiS CR RRPAZR EASZTS TREE. /Imres*. 7. ADUUST LOVER EVACUATCR SO TRAP TER iimSIGSiS SHEET CCWTACTS TER BWDSRSZDS CR TER SERES TO 3E CSS. S. CCWWECT CZRCSZAR SAW TO RIRCTRRCAL CUTLET AES ERRS ZERO SVEX. TERRE SECURE SR 7RRTUALLS SO VESSELS SUSS OR DEERES. IS EXCESS DUST XS 7ZSR3LZ, (a.) CSSCX VACUUS CLEARER 3AG TOR OVERLOAD-PER SAWURACTURER`S IWSTRUCTIOWS, (5) C3ECX LEARS TOR AIR LEARS ATE) (C; CZECH PROPER ADJUSUSEWT CR LOWER EVACUATCR. AVOID VSZHG Ritezssrsz ROP.CR RZSDIHG SAW ZERO HOPS. IE GRRAE RCF.CS IS RECURRED, STOP AiX3 CZECH TOOL POP. PROPER CPERATZOW. 3LAER RZPLACESEWT (EH ALCIT1CZ TO 3LACX 6 DECHER QPZSATZHG ZHSTPDCTZCWS) .1. DZSCOWWECT CHET PROS ELECTRICAL CUTLET 2 LOWER OR RESC7E LOWER ZVACTATZHG 000. 3. RESCUE (4) SCREWS ADD COVER TO EXPOSE .3EARS. 4. GRASP TER EXPOSED LOWER PCSTZCll CR TEE' ELATE AWD RESCUE SUE SCREW WETS WRZWCE 3LARE CAW 3E RESC7ED CR REPLACED (CAVE.ECS: SEZZOCH CAREERS SLADES HOST 3E SCUl 'ED WELZ APRFOPPZAZZ SZZE CUT, TEE RLADES A. RE iL-RXED ACCSRDIWGZT) . CAP CO JEN 0012652 - 69b - cprs.sre.YG i.vsrsrcrrcvs ilSSSZSS-PZZCS CCSSrCArZO 5ZZZT CZ5CSZA3 SAW _aseg_9.g -11-7i L' is so ss csss rrrwzr.v rrr ms ecvvrcrcs nos vserra rsvx. rrr tacccu lasvrscsvssz's OPSSSSSSG SaSSSBGXOSS SC3S SS PSAO SSS GS3SSSSC0B 3SPCPS CPSPASSClt. 3. zvsrrcr sn ssssss rn.vr.vrs res csaczs, pghsgpss os cpsussgs, i.a., seen, vscrr.v Hess avs ccvvrcrcss. sr?ses os sipiacz ah? paclss errs os pass. 4. csiascs sss vsevr:; resrs as ssoni, xasvszss sis cs.vvrcrzc.vs svs ciaips ssr zzorr. i. s. rear o.v vxcszH saa error sop. avy srersors os szs izais zv err nee-erf szvr os sees Sf Z.VS5SS ssrffcrszr sis ric.v z.v rrr err:; ssss or rrr saw. 0 6. zr An izsxs os srorsers ssr iccsrre, czavcz os srrszs rsvsrz rrr-:. 7. ssjssr iotss rvserszos so rrsr rrr sssvsss c.v rrr zvszer or rrr srrsr rrvorss ssr ['; jsppscxsxasszs 1/4 sacs T?.at rrr rerrev or rrr srrrr. 8. anuses, czscczss saw ro srserszess eerier avo ssss r/ro area.?. rrrsr secirie ss G 7isrsAirr vo Tzrzrrr aosz os srsszs. zr rzesss rose zs Tzszrie, fc; error tsotw CISL7Z3 BAG 70S GVS3ZSAS-PSZ SSSUSSCSSSSS'S Z-.'SCSSCZZCVS, (a) CSSCX LZUSS PCS ATS Hass svzr fc; error ssosrs Arjvsrvzvr or icvrs r/Acsszos. 5. &VCZ3 CSZ2IG SXCSSSZ7S POP.CS PSSSZSG SAW Z.VTO .VOSS. ZS OSIAZ 7CSCZ ZS ?*QCZPS3, szo? avz ceres reel ros rsoprs opspuzzou. L riser 3spu.cpy.pr.rs (i:t aooxzzg:i so rises s crccs errsArzve z. Disaasses c;zr rsc.v srerszess eerier. 2. rovrs cs sszgts ier:rs r/scrArrcc roes, z. srscvr (31 scssas sva coves ro expose riser. 4. csss? rrr exposes ices pesrzev or rrr riser avz srr;cvr rrr sesrv szzr server, s. riser es_v rr ssscvsd cs p.spzacsb ressrrev.- srzreev csreisr risers vrrr sr .veevrrs sirs s?rsc?sisrr szzr cor, rrr risers ssr ;essrrz Aocc.-erveiz; CAPCO JEN OOI26S3 CPZTP.CZSG zsszpucczcss 1ESSZSP-PZZCC SASZP SAAf 373 11-79 1. CSS SPZ HCSSZ S73 CSSS CSS 3ZA.CX G BSCXSP. .'XDSL 3155 SA3SP (JZS) SAW. 3ZACX S BSCXSP CPSPACSSG ZSSTPCCCZCSS TCP. HCSSZ 3155 HISC 3S PSAS ASB CSSSPSCCOB PPSCP SO CPSPACZSG CSSS CSZC. .i . _ ____ 2. CULT VSCSClt CZSASSPS CS3CSTCCSB 3T CSS HAJSjTACTUPSP TCP CSS WZT3 ASSSSSCS DCSS ASS SAVZSG A CAPA3SZZCT CT 65 CTl{ .'SS. APS SO SS CSSS WZCS SSZS SCOL. A VACCCH SCSS CT SCC ZSSS CSSS Vi ZSC3 DZASSCSP ASS SOS SOPS SPAS 10 TSSS 20.75 ZS SO 3S CSSS. SS3 VACUCH HAISTACCUPSP'S CPEPASZSC ZSSSPVCZZCSS SCSS 3S PSAS ASS C3SSPSTCGS 3STCPS CPSPASZCS. z. zsstscs azz srscss szshsscs tcr eases, pcscupss cp cpsissgs, VACUUS SCSS ASS CCSSZCSCPS. PSTAZP CP PSTZACZ ASS TAOZSS ZCSS. sees, 4. ASSSH3ZS VACUUS SCSS AS SZCtTS ASQVS, ZSSCPZSS AZZ CCSSSCSZCSS ASS CZASPS APS CZG3C. 5. TOPS QS VACTJUX ASS C3SCS TCP Air' SZCPAC-SS CP ASP ZSA1S3 ZS CSS VACUUS ZZSZ CP sees Aip ZSSUP3 ABSUUACS AZP TZCW ZS USS CPSS APSA CT CSS SAW. 6. ZT AST ZSAXS CP SZCPACS3 APS ZCCACSB, CSASCS OP PSTAZP TAUZCT ZCZS. 7. CCSSSCS SA3ZP SAJI CO SZSCZPZCAZ CUCZSC ASO TSSO ZS7C WCPX. CSSPS SSCUZO 3S SO VZ5Z3ZS SC3? CP BS3PZS. ZT SXCZSS OUST ZS VZSZ3ZS, (i) CS3CX VACUUS CZSASSP SAG TCP CVSPZCAS-PSP 11A1"ACZUPSP`S ZSSZPCCCZOSS, (b) CSSCX ZZSSS TCP AZP ZSAXS. TO ZSS7AZZ0P PS31CVS 3ZAPS (SS ABDZTICS CO 3ZACX G BSCXSP CPSPACZSG ZSSCPUCCZCSS) 1. DZSCCSSSCT CSZC TPCX SZSCZPZCAZ CUCZSC. 2. PSHC7S CSS CSC SCPSSS SEICS PSCAZ1T CSS SSSSZO. 3. PCZZ S2ZSZO SZPAZGST ZO-TJ (SSZSZO TZZS TZPSZT ZS PCSZCZCS. A SCTU CAP HAS SS SSCSSSAPS) 4. PSXCVS 3ZA0S CSSS SZACX S OSCXSP CPSPACZSG ZSSZPUCZZCSS) 5. PSASSZSSZ5. CAPCO JEN 0012654 71b Recommended Work Practice Procedures for Drilling Mud Additives CAPCO JEN 0012655 72b During the early 1970's, concern was raised within the drilling industry regarding the health and safety of employees handling asbestos in drilling muds. In order to reduce the concentration of airborne asbestos fibers at the rig site. Drilling Specialties Company, the producer of these drilling mud additives, reformulated their drilling mud grade asbestos into a water-soluble flake. Subsequent field tests were con ducted to confirm the reduction in the airborne concentrations of asbestos. The results of these tests are present-in Tables X-XIV below. CAP CO JEN 0012656 i - 73b TA3L2 :x coMcarrsAnoHS o? as33S7ifo3m tiszss ct t?.z vohz shvi?.okh5ht FLOSA1 FT3&E 3fPD A3DIIZ7S IH S3ZZ.LIHC MOP S7STZH Fhilllns Fetroleun Ccsoany - Fctcr "2", Ho. 2 Veil Panola County, "eras E & S Drilling Cocoany ^'Sasple Ho. . G 1' G1 P .* r. ^4 u .0 5 r s . l: \V 7. V.- .Location and "`Description Breathing Zone, (3Z) Floor Han Ho. L 3ZV Ho toman, as conducts comal- duties during' shifts 3Z, Derrick. Han, as.conducts terra1 duties during shift. 22 hagsFlosal added during shift 3Z, Floor Han Ho. 2, as conducts coral duties during shift 3Z, Driller, as conducts aortal duties during shift Area Ssnple collected during shift Area Sarnie collected during shift Sarnlinz Ti=as Date Hour Duration Cron) Concentration (?ibers/cc) 1/3/79 1500 435 <0.1 . . 1/3/79 1500 435 <0.1 1/3/79 1500 435 <0.1 1/3/79 1500 435 1/3/79 1500 1/3/79 1/3/79 1511 1515 435 424 420 <0.1 <o.i <tf.l <0.1 CAP CO JEN 0012657 ^^rrwTWATTOSS (g'ASBSSggraf SI3E3S IS T^ 5S TOIRS gTVg.Cragrr DCM3.C ' m aiidttiok QF 'rtosiufflPRiiXErc hop asduxts Sanple . . So- . Phillips Petrsleua Ccagauy - Black "A" So. 1 Veil .. . . Canadian County, Oklakcssa .... . .. . ....... LDoecsactrioipntioannd- ........-..-...... Sansliaz Tine Date Hour Duration (nan) # Caccentraticn (~ibers/cc) 1 3Z, Drillerr as periorrs 1/15/73 0805 480 * totral duties 2 32, Derricksan, as perfoms 1/15/79 0306 479 noreal duties .V 3- 32,' rifleman,, as perfoms 1/15/79 0808' ' 480 coral duties sir * 4 32, Derrickaan, during addi 1/15/79 0945 . . ** tion. of 3, 50-pound bags 1.3 TlosalPard 12, 50-pound bags Kilgel * 2 - V rilcsr loaded with unknown substance which precluded the required sz&ljsis. - 75b - . . TA3LS XII CONCENTBATIOH 07 ASBESTIF03M FIBEBS IN THE WORK ENViaONKENT v_. ' ' Norwegian Horth Sea - Edda Flacfora J i z . .Phillips Petroleum Coranany'- Eldfi.sk 2/7,'No. A-21 Well Loffland Bros. North Sea., Inc. . . L. ` * r~: i 'Sample Ho. U1 . D Location and Description Breaching Zone (BZ) Derrick Han as 'added 12 50-pound sacks rlosal to mixing hopper Sampling Time .. Date Hour Duration (min) Concentration (Fibers/cc) : 2/11/79 ; 1505 10 - 0.2 0 2 NW side of rig floor 2/11/79 1315 433 about BZ height <0.1 P- 3.' BZ, Service Engineer, . 2/11/79 1305 450 as performs normal duties throughout shift c 4 BZ, Derrick Man as 2/11/79 1255 465 performs normal duties z*1* 'during shift including addition of Flosal as u indicated in Ho. 1 above ' <0.1 <0.1 0 5 BZ, Driller as ' 2/11/79 1255 570 performs normal duties r <. 6 Area Sample, near mixing hopper ' `2/11/79 - `1515 435 * * u r L * Filter loaded with unknown substance which precluded the required analysis. - 76b TA3L2' XIII cshcsheacioh o? asssstifosm ?I3F3S is is soss Errry.cHMErr gg?.z:rc OTFSSOKS D3BL SHI? OFSHASIOH Fhillins ?etroleua Coraany -- M,ississippi. Canyon 31ock Ho. 282 ri * c Well Ho. 1 - OCS-3819 Louisiana Gulf Coast ; Samole c" Ho. / Location and Description Saraliaa 7i Data Sour Duration (aim) r~HDD 2HGIH323. <- l 3Z, as performs normal duties primarily in rad pit toon 1: i. 2 Sane as Ho. 1 above 4/21/79 * 0445 4/21/79 ' 0703- 138 167 n3 d Sane'as Ho. 1 above 4/21/79 0950 TTHZ-TZTIlh3 AVH3AG2* 137 442 n DH3SICS K1H ' 4 3Z, as performs normal duties 4/21/79 0500 125 r 5. $ r, li 7 n Same as Ho.. 4 above 4/21/79 Same as Ho. 4 above 4/21/79 32, as performs dermal duties, also began addition of Flcsal (4, 50-pound, sacks added 1015 to 1200 hours) 4/21/79 * * * HOD MOM U 8 Area sample, near mud additive bopper 4/21/79 0705 0920 1105 0505 135 105 81 311 122 L- 9 Same as Ho. 8 above 4/21/79 0707 135 I 1 Sams as Ho. 8 above 4/21/79 0922 106 11 u- Samh as Ho. 8 above 4/21/79 1103 - TES-WE!:SHI3D A7-3AG2 76 439 Concentration (Fibers/cc) <0.1 * <0.1<0.1<0.1- <0.1 sir <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 ___ -- Jilsar loaded -;ith unknown substance which precluded the required analysis. 3 - 77b - ra,?xs XIII ' asple ' r** location and Description Sasalznz Tire Sate Hour Duration (sin) Concentration (Fibers/ec) ! PRIUXS 12 32, as performs somi -- duties 4/21/75 0515 VI3 Sane as Fa. 12 above- . . 4/21/79 . 0720 G4 Sa=e as So. 12 above 4/21/7? 0930 SUE-SS2G52SD A723AG2 ASSISTiin P5H.7.53. 15 32, as perroms aortal in duties Sane as So. 15 above 4/21/79 4/21/79 0519 0722 ,rn Sane as Jto. 15 above 4/21/79 0929 TES-5EIGH2Z3 A7ZEAG2 125 130 175 430 . ' 122 12T 17S 42S , <0.1 ' <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 AO H4 0 'r i i;, t ;i. CAPCO JEN 0012661 78b TATT.-g XIV / cohcsstsarrcss or AssssnrosH- nszzs r? ths toas zst^ckhsht 3X0SAL 51323. WTO ADDITTV2 ET DHIILEJG HUD SYST2H ' ........ ............... . "" '" ' ' ' ^ Phillips Petrolsas Ccspary . ' Burnhoff C So. 1 ' '' f. Canadian Cocks?, Oklahoma " -Sample So. Location sad Description Sasolizz Tiro - Date Hour Duration Concentration (iibers/cc) D0GE0CS2 *< I Lj a Sample, located across doghouse fron door near nlj 2 driller's console. Sane as So. 1 above 5/29/79 0727 118 5/29/79 . 0925 ' 133 \ 3 Sane as So. 1 above 5/29/79 1138 11S . 4 0 Sane as So. 1 above 5/29/79 1334TTHB-wniGHTEJ ,A723AG2 70 437 MUD H0uS2 5 Area Sample, located aoout 5/29/79 0729 I foot above cone-jet bopper apron, even rich outside edge. G6 Sane as So. 5 above 5/29/79 0928 ri '* 7 Sane as So. 5 above 5/29/79 1141 8 Sans as So. 5 above 5/29/79 1340 TES-nouGSTSD A722AGE- ' L- . DESSia: HAS 9 L_ 3Z, as performs normal duties. 5/29/79 0747 3egaa addition of bentonite. 10 fW 32, continued bentonite addi-- 5/29/79 0947 Cion and 3 sac 31csal % 11 32, 1 sk Flosal added 5/29/79 1143 12 32, as performs nomai duties 5/29/79 1342 , ttv? -rtiXCHTZD A723AG2 119 - 133 93 70 415 120 . ns n9 69 424 <0.1 . t. <0.1 <0.1 <0.1 <0.1 <0.1 . - <0.1 <0,1 <0.1 <0.1 <0,1 <0.1 <0.1 <0.1 <0.1 CAP CO JEN 0012662 * r~' l CTO ' T'sanole Ho. location. and. Description L" TLCCK^AH 13 BZ, as perfoms noma 14 Sane as Ho. 13 above 13 Sane as Ho- 13 above 15 Sane as Ho- 13 above r DSHL23. 17 / * 13 u 19 Sane as Ho. 17 above Sane as Ho. 17 above 20 Sane as Ho- 17 above r" L t 79b - T&3L2 XIV (Continued) Sagsling Tine Date ccur Duration (ain) Concentration (risers/cc) 5/29/79 0752 5/29/79 0954 5/29/79 1145 5/29/79 1344 AVE3AG& 122 111 . ' 119 64 416 <0.1 . <0.1 <0.1 <0.1 _<0.1 5/29/79 0754 5/29/79 0910 5/29/79 U4a 5/29/79 . 1336 4VE34GE . * 116 <0.1 vilauHCnCH - HO SAH912 10S <0.1 72 <0.1 296 <0.1 CAP CO JEN 0012663 00b The values presented in these tables demonstrate that all sampling results are well below the permissible exposure limit specified in the current asbestos regulations. Based on these results, the Drilling Specialities Company prepared the following draft on "Recommended Work Practices for FlosalW Drilling Mud Asbestos." When used in accordance with these recommendations, the drilling mud additives can be safely handled by personnel at the rig site. CAP CO JEN OOI2664 - 81b - Drilling Specialties Company TECHNICAL SERVICES DIVISION o 8ARTLESVILLE. OKLAHOMA 74C04 25C0MMEHDED WOKE ??ACTIC2S for TLOSAlP PRUXIHG HDD AS5SST0S cats?ac CaiSPAC SUPS5N. CP.ISCCSc CMC SCL7HX ossco R.CSAU C1ASHAL M OJAca. o cwca. LWL CWCS. A rmoDtrcTiCT The following recommenced work practices are iatended as general guides respect ing the handling of Flosai drilling nud grade asbestos (hereafter referred to as DUk). We believe this booklet rill be helpful to engineers, superintendents, contractors, forenen, and drilling crews in understanding and explaining such procedures, yield tests conducted to date indicate that the reccerecced work practices- set forth in this booklet, if followed, should result in an employee's 8-hour tine-weighted average (TWA) exposure-.being below 0.1 fibers per cubic cuncineter (f/cs) of air. (Such exposure would be well below OSEA's currently prescribed Units of two fibers longer than five sicrsceters per cubic centineter of air as an 8-h'cur TWA exposure and 10 fibers longer than five sicrcneters per cubic centimeter of air, as a ceiling concentration.) However, since field conditions 'do vary, these recomcended work practices do hot purport to be ex clusive, and adherence to these recomcended work practises does not guarantee an exposure level (8-hour TWA) the sane as that shown by the aforersntisnad field tests, nor cospliance with applicable federal,, state or local health and/ or safety laws or regulations. Oc October 11, 1373, OSSA issued rfogras Directive 200-15, which provides uniform inspection and cospliance procedures for nodical examination -requirements of the asbestos standard. The principal actions tjaken by OSEA in this directive were to clarify the tea "exposed to airborne concentrations of asbestos fibers," and to indicate the scape and applicability of nedical exaninarion requirements under the asbestos standards as follows; a. The tin "...exposed to airborne concentrations of asbestos fiber..." is administratively interpreted to nean "exposed' to a rritvyara of 0.1 asbestos fibers longer than five niersneters per cubic centineter of air..." b. Jfedical examinations will be required for any 7 to 3-hour TWA concentration of 0.1 f/cc,. or for a greater concentration. We believe that if the following work practices are followed, one night reasonably expect 8-hour TWA exposure levels to be below those specified by OSEA Ercgraa Directive 200-16. If, however, there is reasonable cause to believe that air borne asbestos concentrations exceed p.l f/cc greater than five riersns oc an 3-hour TWA basis, or have peak levels above 0.5 f/cc greater than five sicrcts based ca 15-ninuta sample periods, then the site should be monitored for airborne asbestos, and appropriate action taken as required by applicable safety cr health laws and/or regulations. CAP CO JEN 0012665 PRODUCTS AND OPERATIONS DMA is furnished in flake fora. Operations to which these work practices apply includer Shipping, receiving, handling, warehousing, and storage. Additions of DMA to the =ad.. Eendling of espty sacks. Disposing of espty sacks. Disposing of end. SHIPPING. -gC-ITING. EASDLING, WASISOUSING, AND STORAGE DMA is furnished is loose or palletized sacks. (With palletized DMA, the pallets are sanetines shrink-wrapped.) The sealed, unopened sacks should he handled by neraal warehouse practices. Precautions cost he taken if a sack is broken, tarn or punctured.. The sack should`he sealed with heavy duty tape or placed in a slip-over sack (over-sized, cpen-ncuthed bag) to prevent spillage. The slip-over sack should be securely sealed, preferably by a twist wire. Any spillage should be cleaned up with a vacuus sweeper equipped with a disposable bag. Unless additional protection is required under applicable federal or other regulations, a certified, reusable single-use air-purifying respirator should be worn by the person cleaning uo. DO NOT BLOW KA32S1AL WITS C0MP3SSSID Aik, NOS. DKT-SWeZ?. The naterial in broken or danaged sacks should be used first.. In scoring DMA, it is racennended that it be stacked no nore than 10 sacks high. ADDITIONS OP DMA TO TSS HUD DMA should he added to the uud in the sac- nanaer as other dry taid additives. The DMA should be added directly to the said systen, preferably by enp tying the sack at a unifora rate into the hopper of a cone-type jet riser (eductor systen, Eigure 1). * Other systass in use are also suitable for the addition of DMA, such as an eductor with suction hose attached to withdraw the DMA directly fron the sack, or fron a drsa into which several sacks have been eeptied (Eigure 2). Care should he used in pouring the DMA into another container to reduce the assunt of "fines" generated when air is displaced fren the receiving hopper or drzu. In adding DMA to the aid, it is a recscaended practice to position oneself sc chat any air currents present are roving frer the individual's back toward the receiving container, rather than blowing into the face. A light weight strearer or "air sock" above Che hopper.ray be used to detemine wind direction (Eigure 3). CAP CO JEN 0012666 MUP PISCIIAHGR - 83b 1 r* i; i 1r r-- U .u .n Li i i Q=3 CAP CO JEN 0012667 - 85b CAP CO JEN 0012668 TO SHOW DIRECTION OF AIR FLOW 86b SAMPLING 07 SHPTI SACRS After a sack is esptied, it should be discarded in accordance with current !-' federal Regulations- Normally, sacks of all types should be carried away for disposal as soon as tine perries. r~ DISPOSING or IMPTT SACKS _ When an adequate precipitator is attached to the incinerator, onshore burial or incineration is the preferred aethod of disposing of espty DMA sacks froa Li offshore sites. DO NOT BURN DMA SACSS WITHOUT A PRZCTSItAIOR. The espty sacks should be accuanlated in sealed irremeable bags until a sufficient nunber is P on hand to require burning or burial. It is preferable to bury espty DMA sacks onshore. DMA sacks are biodegradable. ~ An incinerator with an adequate precipitator can be used. DO NOT 3URN DMA SACRS WITHOUT A PR2CIHITAT0R- r PisRosiNG cr mud U When a. well is finished, there is usually little or no DMA^left in the cud. Any accepted rethod of storing the red for reuse, or disposing of it, C3n be used-. / CAP CO JEN 0012669