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1 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY Edition 3 DRAFT 2 August 19, 1994 CHLORINE INSTITUTE PAMPHLET 137 The Chlorine Institute, Inc., 2001 L Street, NW, Washington, DC 20036 C35703 1188 ttajble of contents PAGE 1. INTRODUCTION...................................................................................................I 1.1 Scope..............................................................................................................1 1.2 Definitions andAbbreviations......................................................................2 1.3 Disclaimer.....................................................................................................4 1.4 Approval....................................................................................................... 4 1.5 Revisions .....................................................................................................4 1.6 Reproduction...............................................................................................4 1.7 Summary of MajorRequirements.............................................................. 5 (OSHA 29 CFR PART 1910.1001) 2. ASBESTOS USE IN CHLORINE MANUFACTURING.................................6 3. REGULATIONS ....................................................................................... 8 3.1 United States ............................................................................................ 8 3.2 Canada......................................................................................................14 4. CONTROL PROCEDURES............................................................................... 15 4.1 General ...................................................................................................... 15 4.2 Purchasing................................................................................................... 15 4.3 Receiving . . ..............................................................................................16 4.4 Storage......................................................................................................... 17 4.5 Diaphragm Depositingand Treatment .....................................................18 4.6 Purchased Predeposited Asbestos Diaphragms....................................... 20 4.7 Spent Asbestos.......................................................................................... 20 5. EMPLOYEE PROTECTION ............................................................................21 5.1 General ......................................................................................................21 5.2 Warning Signs and Labels ...................................................................... 22 5.3 Respirators ....................... 23 5.4 Protective Clothing.................................................................................... 23 5.5 Change Rooms........................................................................... 24 * 6. INDUSTRIAL HYGIENE MONITORING..................................................... 25 6.1 Exposure Monitoring ............................................................................... 25 6.2 Employee Notification...............................................................................25 6.3 Records........................................................................................................ 26 C35703 1189 TABL^OF CONTENTS (cont'd) PAGE 7. MEDICAL SURVEILLANCE .........................................................................26 7.1 Preplacement Examinations............................ 26 7.2 Periodic Examinations.............................................................................. 26 7.3 Termination Examinations ........................................... 27 7.4 Physician's Involvement........................................................................... 27 7.5 Employee Notification.............................................................................. 27 7.6 Records .....................................................................................................28 8. EMPLOYEE TRAINING .............................................................................. .28 8.1 Operating ..................................................................................................28 8.2 Training..................................................................................................... 28 8.3 Contractors ............................................................................................... 29 8.4 Records .....................................................................................................29 9. REFERENCES ....................................................... ............................................30 n C35703 1190 GUIDELINES: ASBESTOS HANDLING FOR THE CHLORrALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 1 August 19, 1994 AED 1 1. INTRODUCTION 2 3 1.1 SCOPE 4 This pamphlet has been developed by the Chlorine Institute to assist member companies 5 in the continued safe handling and disposal of asbestos. 6 7 The safety and health of workers and of the general public in dealing with possible 8 airborne emissions and their protection from hazards associated with asbestos are of 9 paramount concern. 10 11 The pamphlet addresses safe asbestos handling procedures for the chlor-alkali industry. 12 Cited examples may not be universally accepted and do not represent the only safe 13 method of handling asbestos. 14 15 The pamphlet references U.S. Federal regulations that are in effect at the publication 16 date. Additional Federal, State and local, as well as foreign regulations may impose 17 different or additional obligations. All users are urged to keep abreast of all 18 governmental regulations concerning asbestos. 19 20 For purposes of this publication, the General Industry Asbestos Standard, not the 21 Construction Industry Asbestos Standard is assumed to apply to U.S. chlor-alkali cell 22 renewal operations. Member companies are encouraged to become familiar with the 23 Construction Industry Standard as it may apply in certain situations 1 C35703 7191 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUUSS TRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 2 August 19, 1994 AED 1 1.2 DEFINITIONS AND ABBREVIATIONS 2 3 Action level - a concentration of asbestos of 0.1 fibers per cubic centimeter of air 4 measured as an eight-hour TWA that triggers certain requirements of the Asbestos 5 Standard. 6 7 Approved Respirator - a respirator approved by the National Institute of Occupational 8 Safety and Health and the Mine Safety and Health Administration for asbestos use. 9 10 Asbestos - OSHA defines asbestos to include chrysotile, amosite, crocidolite, tremolite 11 asbestos, anthophyllite asbestos, actinolite asbestos and any of these minerals that have 12 been chemically treated and/or altered. 13 14 Asbestos Standard - For the purposes of this pamphlet, the Asbestos Standard means the 15 OSHA Asbestos Standard for general industry, 29 CFR 1910.1001. 16 17 CFR - U.S. Code of Federal Regulations 18 19 DOT -,U.S. Department of Transportation 20 21 EPA - U.S. Environmental Protection Agency 22 23 HEPA - High Efficiency Particle Air filter (99.97% efficient for 0.3 micron particles) 2 C35703 1192 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 3 August 19, 1994 AED 1 Institute - The Chlorine Institute, Inc. 2 3 MSDSs - Material Safety Data Sheets 4 5 NESHAP - National Emission Standards for Hazardous Air Pollutants 6 7 OSHA - U.S. Occupational Safety and Health Administration of the Department of Labor 8 9 PEL - (Permissible Exposure Limit) a concentration of asbestos of 0.2 Fibers per cubic 10 centimeter of air measured as an eight-hour TWA that triggers certain requirements of 11 the Asbestos Standard 12 13 Regulated areas - Areas where airborne asbestos levels exceed or are likely to exceed 14 the PEL 15 16 TWA - Time Weighted Average 3 C35703 1193 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 4 August 19, 1994 AED 1 1.3 DISCLAIMER 2 The information in this pamphlet is drawn from sources believed to be reliable. The 3 Institute and its members, jointly and severally, make no guarantee, and assume no 4 liability, in connection with any of this information. Moreover, it should not be assumed 5 that every acceptable procedure is included, or that special circumstances may not 6 warrant modified or additional procedures. The user should be aware that changing 7 technology or regulations may require changes in the recommendations contained herein. 8 Appropriate steps should be taken to ensure that the information is current when used. 9 These recommendations should not be confused with federal, state, provincial, municipal, 10 or insurance requirements, or with national safety codes. 11 12 - 1.4 APPROVAL 13 The Institute's Environment and Health Committee approved the third edition of this 14 pamphlet on. This third edition reflects current U.S. regulations and 15 general industry practices and, as such, replaces the second edition. 16 17 1.5 REVISIONS 18 Suggestions for revisions should be submitted to the Secretary of the Institute. 19 * 20 1.6 REPRODUCTION 21 The contents of this pamphlet are not to be copied for publication, in whole or in part, 22 without the prior written approval of the Institute. 23 4 C35703 1194 Page 5 August 19, 1994 AED 1 1.7 SUMMARY OF MAJOR REQUIREMENTS (OSHA 29 CFR PART 1910.10011 2 3 If the asbestos concentration is at or above, or may reasonably be expected to be at or 4 above, the "Action Level", the employer must: 5 6 Provide employee training about asbestos. 7 8 Provide a medical surveillance program. 9 10 If asbestos concentration is at or above, or may reasonably be expected to be at or 11 above, the "Permissible Exposure Limit", the employer must: 12 13 Establish regulated areas with demarcation signs, limited access and 14 respiratory protection. Certain activities are prohibited in regulated areas. 15 16 Institute certain engineering controls and work practices to prevent 17 employee exposure. 18 19 Develop a written compliance program to identify how exposure levels will 20 be reduced. 21 22 Provide proper respiratory protection, protective clothing and equipment 23 as well as appropriate handling, storage, cleaning, replacement and 5 C35703 1195 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 6 August 19, 1994 AED 1 disposal practices for the clothing and equipment. 2 3 Provide appropriate hygiene facilities (change rooms, lockers, showers, 4 etc.) 5 6 7 2. ASBESTOS USE IN CHLORINE MANUFACTURING 8 9 Most of the world's chlorine is produced by the electrolysis of brine in diaphragm, 10 mercury and membrane cells. Asbestos is used in diaphragm cells. 11 12 In diaphragm cells, chlorine produced in the anolyte compartment must be kept separate 13 from the alkali metal hydroxide and hydrogen formed in the catholyte compartment. 14 This separation is accomplished by an asbestos diaphragm. 15 16 Saturated brine is fed into the anolyte compartment where the chloride ion is electrolyzed 17 to chlorine. The depleted brine and the cation pass through the diaphragm to the cathode 18 compartment where the alkali metal hydroxide and hydrogen are produced. 19 20 The diaphragm material is the key to the successful operation of a diaphragm cell. 21 Essential characteristics include sufficient mechanical strength, high chemical resistance 22 to both acids and bases, low electrical resistance, uniform and consistent deposits on the 23 cathode, appropriate physical structure to permit flow of depleted brine with minimum 6 C35703 1196 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 7 August 19, 1994 AED 1 back-migration of hydroxyl ion, and an acceptable service life. 2 3 Asbestos is very well suited as a diaphragm material because it exhibits a highly 4 favorable combination of these characteristics. Chrysotile asbestos, or white asbestos, 5 is the predominant form of asbestos used for diaphragms. Although many other 6 materials have been tested as alternatives to asbestos, few have been commercially 7 successful to date. 8 9 Asbestos' unique behavioral characteristics in the chlor-alkali cell environment have been 10 studied. The deposited Fibers on the cathode act differently than just a Filter media. A 11 gel layer forms in the mat (under proper depositing and operating conditions) and plays 12 a significant role in the performance of the diaphragm, especially in minimizing the 13 back-migration of the hydroxyl ion. 14 15 North American consumption of asbestos for diaphragm cells in the chlor-alkali industry 16 in 1993 is expected to be approximately___ million pounds. Asbestos consumption, 17 pounds of asbestos used per ton of chlorine produced, has been reduced through such 18 technological advances as improved brine puriFication techniques, use of dimensionally 19 stable qnodes and polymer bonded diaphragms. 20 21 Asbestos is the universally accepted material for chlor-alkali cell diaphragms. By 22 following safe handling procedures and complying with governmental regulations, 23 asbestos can be handled, used, and disposed of safely. 7 C35703 Jj97 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 8 August 19, 1994 AED I 3. REGULATIONS 2 3 3.1 UNITED STATES 4 5 3.1.1 Asbestos Standard (OSHA 29 CFR Part 1910.100U 6 7 The following briefly summarizes the Asbestos Standard, but is not a comprehensive 8 review. 9 10 The Asbestos Standard: 11 12 Establishes a PEI. (0.2 fibers/cc of air) and an action level (0.1 fibers/cc of air). Fibers 13 are defined as particles five micrometers or longer with a length to diameter ratio of at 14 least three to one. 15 16 Establishes methods for collecting industrial hygiene monitoring samples, analyzing 17 samples and communicating sample results to employees. The standard also specifies 18 the frequency with which samples must be collected and when increased or decreased 19 sampling may be appropriate. It also permits employees or their designated representative to observe the monitoring. Establishes regulated areas which must be demarcated from the rest of the workplace, have limited access, and require personnel entering the regulated area to wear respiratory 8 C35703 1198 GUIDELINES: ASBESTOS HANDl>LLIING FOR THE CHLOR-ALKALI IND'UUS'TRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 9 August 19, 1994 AFT) 1 protection. Eating, drinking smoking, using smokeless tobaccos, chewing gum or 2 applying cosmetics are prohibited in any regulated area. 3 4 Prescribes various methods of compliance, including engineering controls and work 5 practice techniques. If the PEL is exceeded, a written compliance program must then 6 be developed which identifies how exposure levels will be reduced. 7 8 Describes the situations where a respirator must be worn, type of respirator to be worn, 9 requirements of the respiratory protection program, and respirator fit testing. 10 11 Identifies the type of protective work clothing and equipment which must be provided 12 if the PEL is exceeded, and the appropriate handling, storage, cleaning, replacement 13 and disposal practices for the clothing and equipment. 14 15 Identifies requirements for change rooms, showers and lunchrooms, if the PEL is 16 exceeded. 17 18 Prescribes specifications for warning signs, labels and MSDSs. Additionally, for all 19 employpes exposed to asbestos at or above the action level, employee training 20 requirements and frequency arc specified. 21 22 Establishes certain housekeeping requirements, including waste disposal. 23 9 C35703 1199 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 10 August 19, 1994 AED 1 Specifies preplacement, annual and termination medical examinations and the transfer of 2 information to the examining physician regarding the Asbestos Standard, employee work 3 duties, exposure levels, personal protective equipment use and previous medial exam 4 results. The Asbestos Standard requires the examining physician to submit a written 5 opinion on each affected employee's ability to perform the identified work duties and to 6 identify limitations the employee should follow. The Asbestos Standard also requires the 7 physician to inform employees of examination results. The medical examination 8 requirements apply to employees exposed at or above the action level. 9 10 Establishes certain recordkeeping requirements regarding exposure measurements, 11 medical surveillance, training and transferring of records. 12 13 3.1.2 OSHA Hazard Communication Standard 1910.1200 14 15 This regulation is commonly known as the worker right to know law. It establishes 16 guidelines for facilities to follow that handle hazardous substances. Asbestos is regulated 17 under OSHA 1910.1200 as a hazardous substance. In addition there are specific asbestos 18 regulations for asbestos use in the workplace 1910.1001. 19 20 3.1.3 OSHA 1910.120^1 Emergency Response fas appropriate) 10 C35703 1200 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 11 August 19, 1994 AED I 3.1.4 F.PA - EPCRA 2 3 The Emergency Planning and Community Right to Know Act of 1986 (EPCRA) is also 4 known as Title HI of the Superfund Amendments and Reauthorization Act. Asbestos is 5 regulated under EPCRA as a substance classified as extremely hazardous. There are 6 several sections of the Act that affect facilities that manufacture chlorine utilizing 7 asbestos diaphragm technology. 8 9 Sections 301 - 303, 305: Emergency Planning 10 11 Require facilities to prepare emergency response plans and designate an 12 Emergency Coordinator. 13 14 Extremely Hazardous Chemical list and Reportable Quantities (RQ) were 15 established. 16 17 Section 304: Emergency Notification 18 19 Release of a quantity equal to or greater than the reportable quantity (RQ) triggers 20 immediate notification to the National Response Center (NRC) and State and local 21 agencies. The RQ for asbestos is 1 pound. 22 23 Section 311: Submission of MSDS forms to emergency regulatory agencies. 11 C35703 1201 GUIDELINES: ASBESTOS HANDVLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 12 August 19, 1994 AED 1 Section 312: Annual Inventory of extremely hazardous substances. 2 3 Section 313: Annual Toxic Chemical Release Inventory - Form R Repons 4 5 3.1.5 EPA - Air (40 CFR Part 61) 6 7 Asbestos is a designated hazardous air pollutant under the Clean Air Act and is regulated 8 under the National Emission Standard for Hazardous Air Pollutants (NESHAJP). Certain 9 aspects of asbestos waste disposal standards are addressed in these regulations. 10 11 In summary, the regulations require an owner/operator of a chlorine manufacturing 12 facility utilizing asbestos diaphragm cell technology to: 13 14 Either discharge no visible emissions to the outside air, or use specified methods to clean 15 emissions containing asbestos before the emissions are vented to outside air. Air 16 cleaning devices may require daily monitoring, weekly inspections and documentation. 17 All visible emissions must be reported to the EPA quarterly. 18 19 Deposit all asbestos-containing waste material from chlor-alkali operations at waste 20 disposal sites operated in accordance with regulations and discharge no visible emission 21 to the outside air during each stage of disposal or use of specified disposal methods. 22 23 Asbestos from chlor-alkali facilities must be adequately wetted and wrapped in leak- 12 C35703 1202 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 13 August 19, 1994 AED I tight materials. Containers are used to transport debris. Large pieces may be wrapped 2 in leak tight materials. All containers must be labelled with the OSHA warning label 3 and the generator's name and address. Most states require the use of manifests for 4 asbestos waste transportation. There must be a competent supervisor on site during any 5 asbestos activities. 6 7 Submit information regarding asbestos emissions disposal practices, etc. to the EPA. 8 9 3.1.6 F.PA - Water (40 CFR Part 4151 10 11 Effluent limitations applicable to the chlor-alkali industry are not specific for asbestos, 12 although there are restrictions on the discharge of suspended solids. These regulations 13 are promulgated under the Clean Water Act. 14 15 3.1.7 EPA - Toxic Substances Control Act f40 CFR Part 763) 16 17 Regulations promulgated under the Toxic Substances Control Act impose reporting 18 obligations on manufacturers, importers or processors of asbestos. In summary, the 19 regulations require information regarding production, import and export of bulk asbestos 20 and/or asbestos mixtures, current worker exposures, pollution control equipment used 21 to control asbestos emissions, amount of waste and disposal practices. 13 c35703 1203 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 ' Page 14 August 19, 1994 AED 1 3.1.8 DOT - Hazardous Materials (49 CFR Part 1731 2 3 Regulations promulgated under the Hazardous Materials Transportation Act address 4 commercial shipments of asbestos. In summary, the regulations require that asbestos be 5 loaded, handled and unloaded in a manner to minimize occupational exposure to airborne 6 asbestos particles. Individual States also may have asbestos requirements which must be 7 met. 8 9 3.2 CANADA 10 11 The Western hemisphere's largest asbestos producer, Canada, supplies about 35 percent 12 of worldwide production. 13 14 3.2.1 Canadian Workplace Standards 15 16 Federal legislation applies only to federal facilities. There is no federal legislation 17 specific to asbestos. Provincial legislation specific to workplace asbestos is effective only 18 in the provinces of Aberta, British Columbia and Ontario. In Quebec each workplace 19 must submit a control program for approval by the Quebec Health and Safety 20 Commission, although the maximum allowable exposure level is set at 0.5 fibers/cc. All 21 other provinces require compliance with the current ACGEH threshold limit value. 22 Note to EHC-- We need to confirm 3.2.1 and 3.2.2 are still correct. 23 14 C35703 1204 GUIDELINES: ASBESTOS HANDDLLING FOR THE CHLOR-ALKALI INDUSS'TRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 15 August 19, 1994 AED I 3.2.2 Canadian Environmental Regulations 2 3 When transporting asbestos, disposing of asbestos wastes, or where the potential exists 4 for release of asbestos into the environment, the requirements of federal and provincial 5 regulations must be followed. 6 7 8 4. CONTROL PROCEDURES 9 10 4.1 GENERAL 11 12 This section addresses safe handling and disposal practices of asbestos in the chlor13 alkali industry. Examples of satisfactory asbestos control practices are only illustrative 14 and should not be construed to have universal applicability or to represent the only 15 available or suitable practices. 16 17 4.2 PURCHASING 18 19 When asbestos is ordered in bags, purchase orders should require the vendor to have 20 palletized asbestos in bags in the rail car or truck, and cover the palletized bags with 21 shrink-wrapped, stretch-wrapped or other nonporous material. This procedure minimizes 22 the likelihood of tom bags or loose material and promotes ease of movement. 23 15 C35703 1205 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 16 August 19, 1994 AED 1 4.3 RECEIVING 2 3 4.3.1 Inspection 4 5 The asbestos shipment should be inspected before unloading. The individual inspecting 6 the shipment should have an approved respirator and suitable protective clothing readily 7 available. 8 9 4.3.2 Clean-up 10 11 If broken bags or loose asbestos are evident, the individuals cleaning up the spill must 12 wear approved respirators and suitable protective clothing. Broken bags should be 13 enclosed in a heavy duty plastic bag. A HEPA filter-equipped vacuum cleaner should 14 be used for cleanup before unloading proceeds. Where possible, water should be used 15 to wash down and collect any loose asbestos. All other individuals should be kept from 16 the area until cleanup is completed. 17 18 4.3.3 Unloading 19 1 20 When moving asbestos to storage, it is important to prevent the puncturing of bags. The 21 unloading operator should have an approved respirator and appropriate protective clothing 22 readily available. 16 C35703 1206 GUIDELINES: ASBESTOS H 1NG FOR THE CHLOR-ALKALI TRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 17 August 19, 1994 AED 1 4.4 STORAGE 2 3 An appropriate storage area is an important element of the asbestos handling program 4 and its design should be carefully planned. Ideally, asbestos should be stored in an 5 isolated and enclosed area with restricted access and appropriate OSHA-specified warning 6 signs. 7 8 If an access way exists between the asbestos storage area and the major work area of a 9 cell renewal operation, it should have a well-fitted door. The door should remain closed 10 at all times and should be marked with appropriate OSHA-specified warning signs. 11 12 Another means of storage is the "assigned" railroad car. The rail car should be marked 13 with appropriate OSHA-specified warning signs. 14 15 The storage area should be kept clean and free of loose asbestos fiber. Wooden pallets 16 should not be allowed to accumulate in the storage area. Any area or surface showing 17 signs of asbestos, whether on floors, walls, or pallets, should be cleaned with a HEPA 18 filter-equipped vacuum cleaner. The asbestos waste, vacuum bag and filter should be 19 enclosed in a labeled, heavy plastic bag or other impervious container and disposed. The 20 asbestos may also be washed into a collection system or wetted down and recovered. 21 22 Periodic inspections of the storage area are recommended. 23 17 C35703 1207 GUIDELINES: ASBESTOS HANDDLLIING FOR THE CHLOR-ALKALI INDUUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 18 August 19, 1994 AED 1 4.5 DIAPHRAGM DEPOSITING AND TREATMENT 2 3 Exposure to asbestos can occur when asbestos is being prepared for use in making 4 diaphragms. 5 6 Damaged bags should be contained before transport to the point of use. A large heavy 7 duty plastic bag should be used to contain any broken bag during transport. Personnel 8 in direct contact with asbestos should wear an approved respirator and suitable protective 9 clothing. 10 11 Asbestos bag cutting and emptying should be performed under a vacuum vented hood 12 or within an enclosed system. Transferring asbestos into a slurry tank should be 13 performed under a vacuum vented or enclosed system to contain asbestos. 14 15 At times, it may be necessary to add asbestos slurry to an operating cell. Spilling the 16 treatment slurry should be prevented to avoid contaminating the work area. Any spillage 17 should be promptly cleaned up. 18 19 4.5.1 Sorting and Weighing 20 21 Asbestos bags should be opened within a vacuum-vented or enclosed system. Bags 22 should be fully cut and carefully emptied with minimal disturbance of the contents. 23 Bags should never be shaken. Delumping of asbestos and emptying of bags should be 18 C35703 1208 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 19 August 19, 1994 AED 1 done cautiously to prevent asbestos release. 2 3 Empty bags should be folded over the cut within a vacuum-vented or enclosed system 4 and be deposited in a closed labeled container. 5 6 When only partial contents of a bag are required, the partially filled bag should be stored 7 within the vacuum vented hood or enclosed system. If partially filled bags must be 8 moved outside the vacuum vented hood or enclosed system, they should be resealed 9 before moving. 10 11 4.5.2 Protective Equipment 12 13 Workers involved in the physical handling of asbestos bag transfer and slitting, sorting, 14 weighing and slurry-preparation operations should wear approved NIOSH / MSHA 15 respirators and suitable protective clothing. 16 17 4.5.3 Housekeeping 18 19 There should be no visible asbestos. Compressed air should not be used to clean up 20 loose asbestos. Fugitive asbestos fibers must be removed with a HEPA filter-equipped 21 vacuum cleaner or by wet cleaning. 19 035703 1209 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 20 August 19, 1994 AED 1 4.6 PURCHASED PREDEPOSITED ASBESTOS DIAPHRAGMS 2 3 4.6.1 Storage 4 5 Purchased predeposited diaphragms should be placed on pallets with protective plastic 6 covering or stored in the cell frame assembly. The properly protected diaphragms should 7 be stored in a designated area. 8 9 4.6.2 Shipping. Receiving and Assembly 10 11 Predeposited diaphragms should be shipped on pallets with protective plastic covering 12 or in containers designed to hold the diaphragms. Personnel should wear the proper 13 safety equipment when handling diaphragms during shipping, receiving and cell 14 assembly. 15 16 4.7 SPENT ASBESTOS 17 18 4.7.1 Hvdroblast Area 19 * 20 Asbestos diaphragms are removed by hydroblasting and replaced at some frequency, 21 depending on cell type, brine quality, and other variables. 22 23 The hydroblast area should be enclosed and have smooth surfaces to prevent asbestos 20 C357Q3 7210 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 21 August 19, 1994 AED 1 from adhering and drying. The area should also contain a trench system for receiving 2 and carrying away the asbestos and contaminated water to a sump or pit. A sloping 3 concrete floor facilitates drainage. After each use of the hydroblast area and at the end 4 of the work day, all surfaces should be carefully flushed to remove all asbestos. Where 5 appropriate, the area can be initially cleaned with a squeegee. Final wash down would 6 then require a minimal quantity of water. 7 8 4.7.2 Water Separation 9 10 Separation of spent asbestos from the hydroblasting water wash is typically accomplished 11 by pond settling, separation tanks or filtering, e.g. plate and frame filters. 12 13 4.7.3 Landfills 14 15 Landfills which accept asbestos wastes are regulated by EPA and have specific 16 recordkeeping requirements. 17 18 19 5. EMPLOYEE PROTECTION 20 21 5.1 GENERAL 22 23 Asbestos can cause serious health problems if it is not properly used and handled. 21 C35703 1211 Page 22 August 19, 1994 AED 1 Asbestos exposure may cause such diseases as pulmonary fibrosis, carcinoma and pleural 2 mesothelioma. However, quantifying the health risks associated with specific airborne 3 concentrations, fiber types and dimensions, and the chemical composition of the fibers, 4 is an inexact process. In addition, the long latency period between initial exposure and 5 the appearance of disease complicates risk estimates. Consequently, exposure should be 6 kept at or below the PEL. 7 8 The Asbestos Standard requires that engineering controls such as exhaust ventilation and 9 dust collection be used to maintain exposures at or below permissible levels. To the 10 extent practicable, the Standard also requires that asbestos be handled in a wet state to II prevent the emission of airborne fibers in excess of the PEL. 12 13 Compliance must be achieved by instituting engineering controls and work practices, 14 except when such controls are not feasible. In that event, the engineering controls and 15 wdrk practices shall be used to reduce exposure to the lowest levels achievable and those 16 controls shall be supplemented by the use of respirators. 17 18 5.2 WARNING SIGNS AND LABELS 19 3 Warning signs with OSHA-specified language must be displayed at all regulated areas 21 and all approaches to these areas, and at and around asbestos waste disposal sites. Some 22 States may also have labelling requirements for tracking/identifying. 23 22 C35703 1212 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 23 August 19, 1994 AED 1 The Asbestos Standard requires that warning labels with OS HA-specified language be 2 affixed to all raw materials, mixtures, scrap, waste, debris, etc. containing asbestos, or 3 to asbestos waste containers destined for disposal. States may also have generator 4 identification number requirements. 5 6 5.3 RESPIRATORS 7 8 Where their use is required, respirators must be approved by the Mine Safety and Health 9 Administration and the National Institute of Occupational Safety and Health. 10 11 OSHA Act regulations (reference 6) require employers to establish respiratory protection 12 programs. 13 14 Employees must wear approved respirators whenever exposures cannot be effectively 15 reduced by engineering controls and asbestos exceeds or is likely to exceed the PEL. 16 The Institute provides information for respiratory protection in Pamphlet 75 17 (reference 7). 18 19 5.4 PROTECTIVE CLOTHING 20 21 Any worker exposed to asbestos in excess of the PEL must wear protective clothing such 22 as coveralls (or similar whole body clothing) and head, hand and foot coverings. The 23 protective clothing, which must be provided by the employer, should not contain pockets 23 C35703 1213 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 24 August 19, 1994 AED 1 or side openings. 2 3 Employers may prefer to provide disposable coveralls, although reusable ones are 4 permitted. For reusable coveralls, anti-static, cotton polyester fabric of fine weave has 5 proven a satisfactory material. Laundering should be done to prevent release to the 6 ambient air of adhered asbestos fibers. If contract laundering is used, the employer must 7 inform the launderer, preferably in writing, of the applicable regulations. Contract 8 launderers should be periodically inspected. 9 10 Soiled protective clothing, whether reusable or disposable, should be placed in labeled 11 and sealed impermeable containers. Water-soluble laundry bags may minimize the 12 exposure potential in handling operations. 13 14 Once wom, disposable protective clothing should be considered contaminated with 15 asbestos and properly disposed. Reusable clothing, once wom, if contaminated, should 16 be HEPA filter-vacuumed before placing in laundry containers. Clothing must not be 17 shaken, brushed, or air blown. 18 19 5.5 CHANGE ROOMS 20 Employers must provide change rooms for workers who are exposed to asbestos in 21 excess of the PEL. Change rooms, which should be separate from other facilities, 22 including break rooms, offices, etc., must be equipped with two separate lockers or other 23 containers for each worker to prevent contamination of the worker's street clothes. If 24 C35703 1214 GUIDELINES: ASBESTOS HANDDLLING FOR THE CHLOR-ALKALI INDUUSB TRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 25 August 19, 1994 AED 1 disposable clothing is worn, it should be placed in the disposal container and the worker 2 should then enter the shower area. 3 6. INDUSTRIAL HYGIENE MONITORING 4 5 An effective monitoring program identifies employee exposure and aids in developing 6 practices to reduce that exposure. 7 8 6.1 EXPOSURE MONITORING 9 10 The Asbestos Standard requires initial and periodic exposure monitoring for employees n who are exposed or may reasonably be expected to be exposed to asbestos concentrations 12 at or above the action level. Monitoring is also required when work practice, equipment 13 or personnel change could result in new exposures above the action level. Reference 6 14 contains a detailed description of the exposure monitoring procedures. All affected 15 facilities should develop an industrial hygiene monitoring program for asbestos and audit 16 it to insure compliance with regulations and company policy. 17 IS 6.2 EMPLOYEE NOTIFICATION 19 20 The affected employee must be notified in writing of any monitoring results within 15 21 days of the employer's receipt of the results. If the exposure exceeds the PEL, written 22 notice must include the corrective steps necessary to reduce exposure to, at or below the 23 PEL. 25 C35703 1215 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 26 August 19, 1994 AED 1 6.3 RECORDS 2 3 Exposure monitoring records must be kept for at least 30 years. Additional requirements 4 for monitoring records are included in the Asbestos Standard and other OSHA Act 5 regulations such as 29 CFR 1910.120 (reference 8). 6 7 8 7. MEDICAL SURVEILLANCE 9 10 The OSHA Asbestos Standard (Reference 1) requires employers to institute a medical 11 surveillance program for all employees exposed to asbestos at or above the action level. 12 13 7.1 PREPLACEMENT EXAMINATIONS 14 15 The employer must make available a preplacement medical examination before the 16 employee is exposed to asbestos. At a minimum, the examination must include: medical 17 and work history, complete physical exam, completion of the specified questionnaire, 18 chest X-ray, and pulmonary function test. 19 \ 20 7.2 PERIODIC EXAMINATION 21 22 For employees exposed to asbestos at or above the action level, an annual medical 23 surveillance examination must be made available. It is nearly identical to the 26 C35703 1216 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 27 August 19, 1994 AED 1 preplacement examination except that the frequency of chest X-rays depends on age and 2 years since first exposure. 3 4 7.3 TERMINATION EXAMINATIONS 5 6 Within 30 days before or after termination, the employer must make available a medical 7 examination to workers exposed to asbestos at or above the action level. If the employee 8 received the OSHA-designated examination within the past year, a termination 9 examination is not required. 10 11 7.4 PHYSICIAN'S INVOLVEMENT 12 13 The employer must provide to the physician information which includes, in pan, the 14 employee's job duties, exposure levels, and protective equipment requirements. The 15 employer must obtain from the physician a written, signed opinion which includes 16 potential risks to the employee, recommended limitations and a statement that the 17 employee has been informed of the examination results. 18 19 7.5 EMPLOYEE NOTIFICATION 20 21 The employer must provide a copy of the physician's written opinion to the affected 22 employee within 30 days of its receipt. 23 27 C35703 1217 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 30 August 19, 1994 AED 1 9. REFERENCES 2 3 1. Code of Federal Regulations 29 CFR Part 1910.1001, ASbestos Standards. 4 5 2. Code of Federal Regulations 40 CFRPart 61, Clean Air Act Regulations. 6 7 3. Code of Federal Regulations 40 CFRPart 415, Clean Water Act Regulations. 8 9 4. Code of Federal Regulations 40 CFR Pan 763, Toxic Substances Control Act 10 Regulations. 11 12 5. Code of Federal Regulations 49 CFR Pan 173, Hazardous Materials Transportation Act 13 Regulations. 14 15 6. Code of Federal Regulations 29 CFR Part 1910.134, Respiratory Protection. 16 17 7. Pamphlet 75, Respiratory Protection Guidelines for Chlor-Alkali Manufacturing 18 Facilities. Edition 2, May, 1993, The Chlorine Institute, Inc. 19 * 20 8. Code of Federal Regulations 29 CFR 1910.20, Access to Exposure and Medical 21 Research. 30 C35703 1220 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKAJLI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 2S August 19, 1994 AED 1 7.6 RECORDS 2 3 Medical surveillance records must be retained for the duration of the individual's 4 employment plus 30 years. 5 6 7 8. EMPLOYEE TRAINING 8 9 A well-designed and well-conducted employee training program is an essential pan of 10 providing a safe work environment. 11 12 -8.1 OPERATING 13 14 Workers who may be exposed to asbestos should receive detailed written operating 15 instruction specific to their duties. These instructions should include appropriate 16 procedures for moving and handling asbestos and clean up practices. 17 18 8.2 TRAINING 19 20 Initial and annual training for employees exposed to asbestos at or above the action level 21 is required. 28 C35703 1218 GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 29 August 19, 1994 AED 1 The training program must include: 2 3 health effects of asbestos exposure 4 the risks to asbestos workers who smoke 5 the quantity, location, manner of use, release and storage of asbestos, and 6 which operations could result in exposure 7 engineering controls and work practices 8 procedures to be implemented to protect employees from exposure 9 purpose, use, and limitations of respirators and protective clothing 10 purpose and description of the medical surveillance program 11 review of the Applicable Standards (asbestos, OHSA, EPA, DOT, State) 12 13 8.3 CONTRACTORS 14 15 V/hen contract employees may be exposed to asbestos, the contracting company must be 16 informed of the presence and hazards of asbestos. 17 18 8.4 RECORDS 19 20 Employee training records must be maintained for the duration of employment plus one 21 year. 29 C35703 1219 I GUIDELINES: ASBESTOS HANDLING FOR THE CHLOR-ALKALI INDUSTRY PAMPHLET 137: EDITION 3 - DRAFT 2 Page 30 August 19, 1994 AED 1 9. REFERENCES 2 3 1. Code of Federal Regulations 29 CFR Part 1910.1001, ASbestos Standards. 4 5 2. Code of Federal Regulations 40 CFR Part 61, Clean Air Act Regulations. 6 7 3. Code of Federal Regulations 40 CFR Part 415, Clean Water Act Regulations. 8 9 4. Codeof Federal Regulations 40 CFR Part 763, Toxic Substances Control Act 10 Regulations. 11 12 5. Code of Federal Regulations 49 CFR Part 173, Hazardous Materials Transportation Act 13 Regulations. 14 15 6. Code of Federal Regulations 29 CFR Part 1910.134, Respiratory Protection. 16 17 7. Pamphlet 75, Respiratory Protection Guidelines for Chlor-Alkali Manufacturing 18 Facilities. Edition 2, May, 1993, The Chlorine Institute, Inc. 19 20 8. Code of Federal Regulations 29 CFR 1910.20, Access to Exposure and Medical 21 Research. 30 C35703 1220