Document 5kOpKQq6abeLJbMyL8BNLd6jz

GeorgiaFfecific intracompany memo to Branch Managers from 6 7. Baiting** subject OSHA IBGOLATIOS UGABDDC ASBESTOS 1M JOIMT CCMPODWD8 II JPLAINTIFFS EXHIBIT GP-255 location location date Portland Jana 24, 1976 3 We arc currently Manufacturing joint compounds with and without unbeaten fiber. 3 For thoee producta which contain aabeatoa we coeply with the 06HA regulationa regarding the uaa of aabeatoa. These regulationa include the level of aabeatoa fiber in the air at oar plant locations. For the peat two yearn we have been Making neasurananta of the aabeatoa in the air at each plant location. The naaeureaents are in fibers per cubic eenti- aster of air. The present OSHA regulation: calls for a Maximum of five fibers/cc and this will be reduced to two fibera/cc on July 1, 1976. Our bi-annual mea- sureaants show that wa are well below the new standard of two fibers/cc. Also, we coaply with all of tike other OSHA requirements such aa product identification, housekeeping, etc. These OSHA regulations cover Manufacturing plants only. There are no regulations governing Jobs on construction sites. --- T~~r-^a We have received reports that OSHA inspectors have said that our products cannot be used on Jobs and that eonpetitivs salssnen are claiming that our product is illegal. These statements are totally false and cannot be substantiated. There 3 was also a report that OSHA has a mstImim requirement for the amount of asbestos a product can contain. This is also false. 3 Apparently these reports come from niainformed OSHA inspectors and competitive 3 sales people. Incidents where these false claims hurt our sales should be re ported to 0. B. Burch and include the customer or Job involved, the nane of the individual who made the statement and any other circumstances that nay be per 3 tinent. The aoet important message we want to get across is that we are in compliance with all the OSHA regulations regarding asbestos. GFB:de G. F. B. OP 0$ f r- Georgia-fecific intracompany memo o *See Belov rom D. C. Corfcill location location date Portland June 241 1976 *T0: Mmn. I. G. RijdoUi - Oakland Sag i V. D. Brooka - Dallas Sag D. V. MeCubbln - Chgo Bo Sag 1 S. Ballast - Grand Saplds Gyp C. S. Baallay - Clifton Sag L. H. Kaboos - Wash D.C. Sag V. T. Illis - Atlanta Sag Zntenaittantly we ancounter problems in different areas in regard to asbestos. There Is a considerable amount of alaunderatending on the part of many people concerning OSHA requirements. The attached explains tha facts very T*ell. Please sand these oat to your branches. J DCCtde 3 Attach. 3 cc: 0. E. Burch - Portland C. F. Baitinger - Portland T. V. Richards - Tigard Lab 3 E. B. Hollingsworth - Vilm Del Gyp K. V. Brown - Acme I. F. Veibel - Akron HY M. A. Palnowski - Chgo Jt Sys S. V. Favero - Marietta H. V. Bcharf - Milford Da C C. ASBESTOS ABATEMENT PROGRAM GUIDELINES Prepared By The Gypsum Association Safety Committee **\ * . w . -v.A- : *'- ***:. II The Act specifies certain maximum permi ss i b 1 - c~nc _n t ra <; i cns c ' 3.'borne a ibeS tos fibers to wh i ch an employee may be "."rict. ^ -ir ->um concentrations are expressed as an 3 hour time weighted aace ? :n- number of. fibers exceeding 5 micrometers in l ere th, ::r ;ubi; ci* t irr.e ter of Air. These maximum permissible concentrations are: 1. 'Jn t i I July I , 1973: 5 Fibers per Cubic Centimeter.. 2. After July I, 197b: 2 Fibers - per Cub i c Cen t i me ter. : - ' ! -> addition, a ccncen t ra t tori of" 10'Tiber? per cubic can t; meter.-: c air has-been-es iiabl i shed as a ceiling concentration. Mo emp i oyee-can . exposed to a concentration in excess of this amount At Anv Time. MONITORING REQUIREMENTS A monitoring program to determine every emp!ovae's exposure :c asbestos fibers is required by the Act. The Act specifies that air 36~oles be analyzed using membrane filters of 0.8 micrometer porosity c.^ted in an open face filter holder. The samples are then examired rce.' 2 Agr-b5G power microscope using phase contrast il ! um.i ng ^ ;-jr to a-tc-mine the concentration of airborne asbestos fibers. The Act states that every employer must measure the screentracion _ - as bes to a *i bers in a I i .areas where asbestos fibers ore released , to do- . zr.-- i ne wheCher "the maximum permiss ible - exposure I eve is are exceeded." ~'rrz Ic-oies must be taken v/ithin the breathing zone of employees ("Persona I ~ mi coring") and w: chin the general work area ("En v i ro.nmen to I Mon ? cor i nc:,.V 1 determine both che 8-hour time weighted average and ceiiing corcer- 3 s b J s t3 fibers. 1 r'T In al I ar'iJS where the maximum permissible s.oosure I i'ii - c.eoed, the emplovcr must immediately undertau.' an asbestos ahj*.-::; program to comply with the Act. In addition, conccn tra r i cm sanp i in-.:s ' r. these e-^eas must be taken at no longer than six nor t n : n tcrva Is . Affected employees, or their represeniat i '-s . have Lh_ r to observe any monitoring procedures. . ENGINEERING CONTROLS ' . ' `' " f 'the--con cent rat ion of ai rborne ashes tos f i bers is found be i n-iexcass'of' the maximum permissible exposure levels established the Acr^ an .'employer-wi U be required to take various steps tc ra re the numberrof-_f i bers to within the accepted limits-. The Act :c~~ends tha trrthe- fo 1 1 ow i ng Engineering Controls be employed: . A. Isolating the work area ' ' m. Enclosing the asbestos materials whenever practicable C. Installing an exhaust ventilation system 0 Installing dust collectors Tea Act cites "American National Standard Fundamentals the Design and Operation of Local Exhaust Systems'1 (ANSI 19.2-if/L' a useful reference. The Act oermi ts acceptable-respi rators (as . c i s cus s ed later) be worn only as & temporary measure until the Enqineerinq Controls 1 ins taI Ied. .- - MEDICAL EXAMINATIONS Act requires that each employee o * s expos ad ro a I r s dust be given a comprehars:ve medical exam na on i n; o'/ the employer at the following times; 1. Vi I thin 30 days of i n i t i a 1 p 1 aceinon t >n ^ job requiring exposure to asbestos- 2. At least once eve^y twelve months J. V i chin 30 days of termination of emo i c v:. on. t or crers !` - to a job no longer requiring exposure to asbestos . Tne medical exam must include, as a minimum,.a 1. Chest X-Ray . " ..-2- Pu-lmonary Function Tests - \Z__ , .Uiiitrs . a.-.''Forced-Vi tal Capacity *9 . . b.'^.Forced _ Exp i ratory-Vo 1 ume at _I Second : 3- r Medical History to Determine Whether the Employee - . ; .'hadjever had any respi ratory diseases . . .- RacordSfoF all-such medical^examinations rausfbe retained by the employer-^for a minimum of 20 years. .. ' ' RESPIRATORS -. ' '/ . The-use of respirators to protect employees from corcer: t ra t ions - - asbestos fibers exceeding the maximum exposure leve-s is not psrni tted r_o: in cases where it is not techn i ca I i y-fees i ba to recuca the cor. - =`ion to a safe level, or in emergencies. -Respirators may, however, - . : -..sec 33 an interim measure during the period necessary to install the . ~~ P'toer engineering controls to reduce the concentrations or to ins : i cute-- - : e work practices required by the Act. In these cases, personnel rotation--/= 'eb"inis t re tive con t roIs) sha1 I be used in pre ference to respira tors - '. ` it is practicable. ' ' . ''" - - -r "he Act requires the employer to establish a respirator proorom ' t cccdi^ce -( i th the "American National Standards Practices fo f ts o ;- = ro r\- -- - i : : : C ' 'A.'-;3 ! ZS3.2 1969) I r respi rotors bru to be used. The Act aiso specifies that, if a physician determines that an eroIoyee wi11-he unable to function normally, or that tha healtn or safety o' the employee or his fellow workers wiI 1 be impaired by wearing a resoirater tne employee must be rotated, to another job or given the opportunitv to transf to a different job with the same seniority and rate of pay. - The type of respirator used will depend on the maximum concen t ra t i on'-of-Ttibers to which the employee is expected to be exposed. Ali ; rasp i ratorsf mus t be-approved by either the-8ureau of Mines The Depar t.m.er. L. . of the-:fnteriort-or^The National Insti tute for Occupational-Safety anc Healtrv. ' Thai following respirator types may be used at the maximum- fiber, concentrations-speci fied: .. . - . ___ - - . .1 ' 1'Concentrations up to _50 fibers per cubic centimeter-^ - .. -.-(After J ul y 1 , 197o. the maximum wi 1 1 be 20 fibers)- - a reusabl e-or s Ingle use.air purifying respi rator, or any of the respirators listed below; . . '' 2.;. Concentrations of between 50 and 500 fibers (After ' _'^july l 1976, between 20 and 200) - A full facepiece powered air purifying respirator, a powe r ed air purifying respirator, or the respirator described. below; - 3. Concentrations exceeding 500 Fibers per cubic centi meter (After July 1, 1976, 200 fibers) - A type "C" .. continuous flow or pressure-demand, supplied-air - raspirator. . ... In all cases, the respirator must be capable of reducing the - - iPhe'ed fiber concentration to a level below the maximum permissible ' " ' exposure-concentration . ;- '. CAUTION SIGNS AND LABELS - - The Act specifies that caution signs, must be posted at each location where airborne concentrations of asbestos fibers may be in excess o: : is s/pesure limits. Signs must be posted at all epproacnes to t^ese locations, so chat employees can take necessary protective actions b=r'or; an tering.the hazardous areas. ' ` `-". Exact Specifications for the 20" x !*f" signs are Given ip Secti 13'2.53a(g) ii of-the Act. ' Each sign must state: AS 3ESTOS-OUST HAZARD 'Avoid Breathing Oust" ,`^`Wear Ass igned Protect i ve Equipment _ -_J)o No tRema bv| n -Work Area Unless .your work requi res i c -- *- ' v-- .. . --. - ' - ... ` Breath-rrTg`5Asbestos Dust May-Be.Hazardous To Your~Health 1'raw materials mixtures,~scraps, debris, produ : ts .conca i n i n unbonded asbes tos , -"contaminated work clothes, and containers for these-:'' materials musc contain a clearly legible warning label which states: CAUTION '- CONTAINS ASBESTOS FIBERS - ..- ... . Avoid Creating Dust . -- breathing Asbestos Dust Nay Cause Serious 5odily Harm These labels must.be printed in letters of sufficient size and- - contrast as to-be readily visible. . - - REVISED WORK PRACTICES .' ' '' " In order to prevent or reduce the emission of airborne fioers, t'e Ac: specifies that all asbestos must be handled or worked in a wet ; : = 13. All asbestos products in powdered form cannot be removed from bags, car tons, or other shipping containers without being either wetted. . enclosed;* or ventilated to prevent the release of asbestos fibers into .. the atmosphere.-_^..i`. . * - The Act stresses the importance of good housekeeping in ail areas where, as bes tos is used. According to the Act,- all external sur f sees *mus tibe f ree-of . accumul ations of asbestos dust.:. ._ ' - Because^of -the danger that further handling may release harardous. -Ravels of'airborne-as bes tos, all asbestos scrap, debris, containers. ccn---r:: ' *taminated.*clothrng--or equipment must bed i s posed of in sealed, i mpermeab I e vr >--Con ta*tnervi_ Each dconta i ne r must bear ah approved warning label. . ~ . .............. ! ~r clothing : ^ . ... . .. ' '-'Because of the danger that asbestos dust may be carried * . home in- an employee's clothing, special arrangements must be mace to ensuse that an employee's street clothes do not become contaminated by airborne as oas tos- fibers if the employee is exposed to concentrations of asbestos fibers exceeding the threshold limit value. (TLV) . The employer must provide special work clothing such as over-- alls, hats, gloves, and foot coverings for any employee exposed to harar- - dous concentrations of asbestos fibers. The employer also must provide _ chance rooms containing separate lockers for contaminated clocninc and Vi 's treat clothes for each employee. These lockers must be separated or .--no.- isolated to prevent dust from the work.clothes contaminating, the street ' c I ethes. a ^ The Act specifies that the employer must inform whoever launders r'->j contaminated clothing of the requirement that the clothing be laundered in such a way that the release of airborne asbestos fibers is prevented. II Clothing muse be transported to the laundry in sealed, impermeable ccr. tainers bearing the asbestos warning label. ' "; ' RECORDKEEPING " Under the terms of the Act, .every employer is requirea to keep accurace records of the plant fiber concentration monitoring program and ofitesip 1 oyse medical examinations. . . .__/^Records of personal and environmental monitoring results must be main.ta.rned for a minimum of three years, while results of employee.----. .=-- 'rfed * ca Ir.examinat ions must be---retained., on file for at-i east 20 years.- - ... !rm-. -^:_Thes ^records must be made- avai 1 able - to the Assistant Secre-tary'* of Labor-~fbf: Occupat ional_ Safety and Health or to The 0 irector. of . the - - National =lnstitute-for Occupational Safety and Health on request. in addition, every employee or former employee should be given reasonable access to records indicating his own exposure to asbestos, and the results his own medical examinations. An employee may also request that his -rec:cai records be-released to his physician. - -- The Act requires that all.employees exposed to hazardous center: t rat icns of asbestos fibers be informed in writing withfn 5 davs a~ter the hazardous condition is discovered. Employees must also be kept advised of the corrective action being taken. .......