Document 4a2E43enrkgK3gGD7d2E9RJE1

'. >' c"; ' P. G. Malt, Jr. General Manager. Corccraie Eng^nee'ing anc Cuality Assurance <rl' TO ALL GENERAL MANAGERS Rs: Employee Exposure to Asbestos Western Electric 222 Brcacway Newv5" v 'CC33 212 571.4533 I am writing to voice my concern, and the concerns of Dr. Cassuto and the Medical Organisation, regarding the handling and use of asbestos, an identi fied carcinogen, within Western Electric. We trust that your Location has mane substantia- prorress tewarn e*iminacthe curchns-o and tee of arcestcs containing materials. However, it should not be assumed that by eliminating asbestos containing materials in our production orccesces, and m the con struction of new plants sr.d facilities, that we have eliminated all octer.tial exposures. ' On the contrary, the potential for asbestos exposures will con tinue for some years due to past uses of asbestos (i.e. insulation or. steam, pipes, boilers and tanks, asbestos fire stops in cable runs and vaults, etc.) and exposures resulting from present uses of asbestos where suitable substi tutes are not yet available (i.e. motor vehicle brake and clutch maintenance Particular attention should be given to the following requirements of the OSHA standard 1910.1C01, whirr, regulates asbestos. 1910.1001 (c)(2)(iii) of the OSHA asbestos standard states: "Scravins;. demolition or removal - Employees engaged m.................the removal or demolition of asbestos insulation or covering shall be provided with respiratory equipment and with special clothing in accordance with................. (this standard)." v..b.... 1910.1001 (d)(2)(iv) states: "Establishment of a respirator urogram - The employer shall establish a respirator program in accordance witr. the retirements of the American National Standards Practices for Respiratory Protection. A-NSI Zio.Z-l'tR rr LLA 001083 1910.1C01. (f.)(2)(i) states: "Personal Monitoring - Samples shall be collected from within the breathing zone of employees................. Samples shall be taken for the determination of eight hour time weighted average airborne concentration and ceiling concen trations of asbestos fibers". The OSHA compliance officers have interpreted that, since spraying, demoli tion or removal work are done intermittently, and because the concentration of asbestos fibers may vary considerably, monitoring must be conducted each time work pi this nature, involving asbestos, is performed, and the moni toring must be conducted irrespective of the provision and use of respira tory protective equipment. 1910.1001 (3)Cl) states: "Medical Examinations - The employer shall provide, or make available at hi cost, medical examinations relative to exposure to asbestos................ " In a decision orovided by the U. S. Court of Arceais for the District of Columbia Circuit on June 20, 1977 (GAT Core. v. OSHEC, Docket No. ~-l 12 it was ruled that medical examinations must be orovided for workers exposed tc airborne- asbestos fibers m any mensurable ouantity. Until such time that suitable substitutes are found for'all applications and asbestos containing materials are totally eliminated from our locations we urge that suitable engineering controls be used to minimize the risk of exposing employees to excessive concentrations of asbestos fibers. General Corporate Guidelines and the requirements of the OCHA standard have beer, recently sent to all safety and health organizations by our Bioenvircnmer.ta Engineering Department. Please convey our concerns tc the appropriate Industrial Hygiene and engine ing personnel at your location, and provide them with the support necessary to ensure the full nrotecticr. of our employees from this and other healer, hazards. It is only with your support that the Company will meet both our legal and moral obligations to Western Electric's employees. Co r.. A. Levitt LLA 001084