Document 5kNmDK2X4oZp3Q3GJYDgzgZwe
TEXAS DIVISION FREEPORT. TEXAS 77541
September 6, 1972
MAINTENANCE FOREMEN MAINTENANCE MANAGERS AND SUPERINTEIDENTS SAFETY AND LOSS PREVENTION
PLAINTIFFS EXHIBIT
DOW-164
GUIDELINES FOR HANDLING ASBESTOS MATERIALS
In order to obtain data on exposure levels during removal of asbestos-containing insulation, the Environmental Health
Department must take several samples, during removal, of each type or class of asbestos insulation. This data must be obtained and evaluated prior to December 1, 1972.
Most high temperature insulations (above 800F) installed
prior to August, 1970, should be suspected of containing
asbestos. Before removing this type material, the appro
priate Plant A or Plant B Insulation Foreman should be
advised of the job so that monitoring may be arranged as
required. This Information can most readily be conveyed
through Cynthia Cervenka, 4636 for Plant A or Orvilla Smith,
2581 for Plant B.
"
A complete revision of the "Handbook for Handling Asbestos Materials" is attached; it defines the procedures and safe guards required for proper handling. It should be noted that precautions for sawing of transite (cement-asbestos board) are included.
All waste asbestos-containing material must be properly bagged and labeled for disposal by the Yard Department. Labeling tags have been ordered (see attached sketch) but are not yet available. In the interim, attach a plain tag or label that is readily visible and clearly legible stating
CAUTION, CONTAINS ASBESTOS FIBERS
You will be notified os soon as- printed tags are available.
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F. B. Crouch
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HANDBOOK FOR
HANDLING ASBESTOS MATERIAL
THE DOW CHEMICAL COMPANY TEXAS DIVISION
Maintenance Department Supporting Services
July 1972 Rev.
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HANDBOOK FOR HANDLING ASBESTOS MATERIALS Ind ex
1. Purpose 2. Safety 3. Use of Handbook 4. Safe Work Procedures
Fabrication of Asbestos Materials Mixing Cement Containing Asbestos Handling and Storing AsbestosMaterials Sawing and Cutting by Hand Insulation Removal 5. Insulator Safety Check List 6. Threshold Limit Value
Page (s) 2 3 4
5 6 7 8 9 10 11
STQ5744I 7
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PURPOSE
The purpose of this handbook is to define safe handling procedures for asbestos materials used in the Texas Division. The intent is to control the exposure of employees to asbestos dust through the proper use of safe work procedures and by the sub stitution of non-asbestos containing materials. Asbestos is widely used as structural wall board, Insulation, and roofing material. Asbestos fibers are used as a mechanical reinforcing matrix in in sulation, roofing paper, certain piping systems, etc. However, Dow Ehgineering Specifications were revised to exclude asbestos-containing insulation prior to installation of Federal regulations controlling the use and handling of asbestos. Eventually, the use of asbestos will be eliminated as the ultimate solu tion to the problem. The OSHA standards which became effective July 7, 1972, define the precautions required for asbestos handling and the allowable safe working limits. Should a hazard exist, and these procedures appear insufficient, contact the superintendent of the Plant A or B Functional groups for exceptions or variations. These procedures will be reissued prior to 7 December 72 to incorporate revisions dictated by results obtained from the Division Monitoring Program.
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SAFETY
The health of those who breathe asbestos dust may be seriously affected. Results can be similar but more serious than those caused by the more common ly known materials such as silica and coal dust. This phenomena has been observed for many centuries. Current medical discoveries show that handling of asbestos by a confirmed cigarette smokerris espec ially hazardous.in the area of potentially serious lung disorders. It is recommended that those persons handling asbestos not smoke cigarettes in any quantity.
When working with materials -which contain asbestos fiber, care must be taken to eliminate as much loose dust as possible. Wetting, isolating the work area, or other suitable procedures to eliminate the dust hazard are absolutely necessary. The main problem areas will be in removal of old, deteriorated in sulation and the sav/ing of Transite.
Respiratory protection, dust collectors, blowers, etc., will be mandatory where asbestos-containing materials must be handled.
The two "nose and mouth" dust respirators v/hich have been approved by the Safety Department are: (l) MSA Dustfoe 77, Dow Stock No. 15-26005, Cartridge No. 15-23775, and (2) 'Wilson Dust Respirator, Dow Stock No. 15-25460, Cartridge No. 15-23790.
Disposal of asbestos will be in polyethylene bags, Dow Stock No. 15-05080 for large bag and 15-04170 through 15-04l85 for small bags.
As required, special protective clothing such as cover alls, head covering and gloves will be provided. Such requirements will be determined by the Division Moni toring Program.
Two lockers will be provided, so separated or Isolated as to prevent contamination of the employee's street clothes from his work clothes.
Asbestos-contaminated clothing shall be placed in labeled, polyethylene bags for shipment to the laundry.
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USE OF HANDBOOK FOR
HANDLING ASBESTOS MATERIALS
The Safe Work Procedures outlined in this handbook are minimum requirements for working with asbestos containing materials. In some cases, job conditions may dictate more stringent requirements. These could include com pletely wetting down the area with water when re moving oltrinsulation, or completely isolating the work area with tarpaulins, etc. Specific require ments for each job will be detailed on the"Insulators Safety Check List." Because Dow's Engineering Specifications have been re vised to exclude use of asbestos-containing insulation, most of the Safe Work Procedures in this section of the Manual will seldom be referred to for new installations. These procedures are to be used in conjunction with Plant Safety Rules, Maintenance Standard Safe Work Procedures for the Area, and Safety Standards.
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SAFE WORK PROCEDURE
Subject: Shop Fabrication With Asbestos Materials
Minimum Safety Equipment Requirements:
1. Side Shield Goggles muse be worn.-
2. Approved "Nose and Mouth" Dust ResDirator must be worn at all times. (See Page 3)
3. There shall be a Dust Collecting System on Power Equipment adequate to remove large amounts of dust generated.
4. An Insulator Safety Check List is to be filled out prior to the job and properly approved. Turn in to supervisor at completion of job.
Special Precautions:
1. Do not breathe asbestos dust.
2. Do,not operate equipment if provision cannot be made to eliminate dust in a safe manner.
3. Normal precautions must be taken for working with power equipment. (See specific Safe Work Procedure for Operating Power Driven Tools if in doubt).
4. When cleaning out the vacuum system of the machines, a respirator must be worn. Wet down dust prior to handling. Place the wet material in polyethylene bags,- seal, label and notify Yard Department that asbestos waste is ready for proper disposal at landfill.
5. Good housekeeping in the s-hop area is to be practiced. - --Asbestos-dust must be vacuumed ..throughout the shop
area if and when such conditions exist.
6.------ Keep all personnel not directly involved in the ------- fabrication operation away from the area unless they
observe minimum safety requirements and have been apprised of the hazards involved.
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SAFE WORK PROCEDURE
Subject: Mixing Material Which Contains Asbestos
Minimum Safety Equipment Requirements: 1. Side Shield Goggles must be worn. 2. Approved "Nose and Mouth" Dust Respirator must
be worn at all times. (See Page 3/ 3. An Insulator Safety Check List is to be filled
out prior to the job and properly approved. .Turn in to supervisor at completion of job.
Special Precautions: 1.. Do not breathe asbestos dust. 2. When mixing vihole sacks, do not open sacks and
dump into open mixing tray. Moisten asbestos by adding water through a small hole in sack until danger of dust is eliminated. Then the material can be removed if necessary to complete mixing operation to desiredconsistency. 3. Slipping or falling is a hazard to be considered when working around wet asbestos mud. 4. Back strains from handling containers of mixed mud are also a hazard. A means of handling this mixture may need to be provided, depending on the circumstances. 5. Keep all personnel not directly involved in the mixing operation away from the area unless they observe minimum safety requirements and have been apprised of the hazards Involved. 6. All contaminated bags, boxes, waste, etc., shall be wetted, placed in labeled polyethylene bags and sent to landfill.
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S I U D / '4 4 ' Z
SAFE WORK PROCEDURE
Subject: Handling and Storing Asbestos Materials
Minimum Safety Equipment Requirements:-
1. Side Shield Goggles must be worn.
2. Approved "Nose and Mouth" Dust Respirator must be worn at all times. (See Page 3)
3. An Insulator Safety Check List is to be filled out prior to the Job and properly approved. Turn in to supervisor at completion of Job.
Special Precautions:
1. Do not breathe asbestos dust.
2. Handle materials in such a manner as to minimize exposure to dust. Moisten material with water spray before removing from container if material will not be damaged.
3. Areas used to store asbestos containing materials should be-marked "Asbestos Material".
4. Cartons, boxes, etc., that have contained asbestos materials should be wetted, broken and placed in labeled polyethylene bags for disposal.
.5 Good-housekeeping of shop areas is to be practiced. Clean up all loose dust on floor, machines, shelves, etc., by vacuuming. Wet down, place in labeled polyethylene bags and dispose of dust while damp. Notify the Yard Department to dispose by landfill while material is still damp.
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SAFE WORK PROCEDURE
Subject: Sawing and Cutting by Hand
Minimum Safety Equipment Requirements:
1. Hard Hat must be worn.
2. Side Shield Goggles must be worn.
3. Approved "Nose and Mouth" Dust Respirator must be worn at all times. (See Page 3)
4. An Insulator Safety Check List is to be filled out prior to the Job and properly approved. Turn in to supervisor at completion of Job.
5. All other safety equipment which is required by Job location must be used. (Read Area Safe Work Procedures.)
Special Precautions:
1. Do not breathe asbestos dust.
2. Wear the "Nose and Mouth" Dust Respirator when removing asbestos material from package, installing, or cutting.
3. Keep all personnel not directly involved in the operation away from the area unless they observe minimum safety requirements and have been apprised of the hazards involved.
4. Special precautions shall be taken when using "Skil-Saw" for sawing asbestos materials. To eliminate dust hazards and protect all people in the area, an air operated saw shall be used and the material shall be flooded with water.
5. If water will damage the material, a hand saw shall be used and sawdust collected with a portable vacuum whenever possible. If site work prohibits use of a vacuum pick-up, cuts should be made directly over a collection box or polyethylene bag.
6. All contaminated bags, boxes, waste, etc. shall be wetted, placed in labeled polyethylene bags and sent to landfill.
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SAFE WORK PROCEDURE
Subject: Insulation Removal
Minimum Safety Equipment Requirements:
1. Hard Hat must be worn.
2. Side Shield Goggles must be worn.
3. Approved "Nose and Mouth" Dust Respirator must be worn at all times. (See Page 3)
4. An Insulator Safety Check List is to be filled out prior to the Job and properly approved. Turn in to supervisor at completion of Job.
5. All other safety equipment which is required by Job location must be used. (Read Area Safe Work Procedure.)
Special Precautions:
1. Do not breathe asbestos dust.
2. Hazards from asbestos dust that falls, blows or may be scattered throughout the area must be eliminated.
3. Keep all personnel not directly Involved in the insulation removal operation away from the area unless they observe minimum safety requirements and have been apprised of the hazards involved.
4. Use water to wet down the insulation before and during removal.
5. Seal all material in labeled polyethylene bags as removed. The Yard Department is to be notified for disposal at landfill.
INSULATOR SAFETY CHECK LIST
JOB DESCRIPTION:
DATE
LOCATION _____________________________________________________________________________________
I. AREA
1. Safe Work Permit Received
YES NO |___ [ :___|
II. ASBESTOS WORK
YES NC 1. Handbook for Handling |----- . p
Asbestos Materials Used?--1' ' --
2. Area Safe Work Procedure Known
3. Nearest Phone
4. Nearest Eyebath and Safety Shower
Job Site in Safe Condition
6. Is Pipe or Equipment Safe to Work On?
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2. Signs and//or BarricadesI-----1 1 I Up to Warn Others ?
3. Has Disposal of Debris ^- L_ Been Arranged ?
4. Is Water Needed to Control Dust ?
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5. Stencil on Job to DenotC--I L_
Materials Used ?
6. Have all Involved
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Personnel Been Informed ?
7.
Are Corrosive Chemicals Involved?
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Can lines equipment
or be
drained?
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8. Is Adjacent Piping and Equipment Safe
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9. Red Tags Needed?
1 . Burn Hazards Present?
11. Craftsmen Lined Up With Check List?
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III.
Special Safety Equipment Required:
Coveralls Chemical Goggles
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Face Shield Acid Hood
Air Mask -- Dust Respirator
Rubber Gloves Rubber Boots Slicker Coat
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Slicker Pants
Safety Belt
Hearing Protection
_ Other: Specify
Special Hazards
IV. Personnel on Job (Name) Exposure Time-Hrs.
Special Safety Precautions
Checked and Approved By: Supt. Foreman Crewleader. Craftsman
DATE:
P 3. 4. 5.
6.
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THRESHOLD LIMIT VALUE
No employee shall be exposed at any time to air borne concentrations of asbestos fibers in excess of 10 fibers, longer than 5 micrometers, per cubic centimeter of air. The eight hour, time-weighted average shall not exceed five (5) fibers per cubic centimeter.* In order to assure compliance with these limits., the Environmental Health Group will make random samples. When special field testing is desired, call Environmental Health at 238-2121. In order to keep asbestos dust concentration within the proper limits, any dusty conditions connected with the handling of asbestos materials must be kept to an absolute minimum. This must be done as out lined in the previous Safe Work Procedures by wetting down the area, pre-soaking the material, or vacuuming the material as it is cut. Each individual Job should be planned with this uppermost in mind.
* Effective 1 July 1976, this limited is reduced from five (5) to two (2) fibers per cubic centimeter.
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BACK
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DOW CHEMldSlTu.sX
TEXAS OIV FREEPORT, TEXAS 7
December 15, 1976
J. Holtz
North American Asbestos
150 N. Wacker Dr.
Chicago, 111.
60606
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ASBESTOS HANDLING - HEALTH HAZARDS
The attention given to the health hazards of asbestos continues to increase. We must do everything possible to prevent airborne asbestos fibers resulting from damage in shipment.
Shipments several months ago arrived in very poor condition. Pallets had overturned and bags were torn. The men unloading the
trucks had to tape up the bags and re-palletize them. The men wore "throw-away" coveralls and respirators: Air samples taken showed considerable contamination hundreds of feet away in the
warehouse.
I
Recent shipments have arrived in much better condition. These were shipments from the dock at Montreal rather than from a ware house in Philadelphia.
Some Oow Divisions have elected not to use Blue asbestos because it was considered a more serious health hazard than the White. This makes it extra important to prevent damage in shipment.
Please arrange for shipments out of Montreal rather than Philadelphia whenever possible.
Please tell the proper people at both locations that they should tape up, or otherwise repair, any damaged bags before shipping them further and that very careful attention should be paid to packing the trailers in order to prevent pallets from moving.
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Cpy. San Edquist'
S.F. EDQUIST
DEC 201976
A-1324
AN OPERATING UNIT OP THE OOW CHEMICAL COMPANY