Document 5knQk8j4Vx1ymV65de4LRVBYe

PLAINTIFF'S EXHIBIT Asbestos Abatement and Asbestos Containing Materials Management! I QUESTIONS _________ DOW-1299 1. Galbestos is primer paint that is tire retardant and is sandwiched between metal or another type of material with paint covering the primer. Percent of asbestos is unknown. Nonfriable if not cut or ground on. Question is, should an asbestos abatement contractor be required to remove this material? ST0083542 2. Since 1926.58 (e)(6) states enclosures shall be erected when feasible, what should we be doing about transite removals? 3. Possible asbestos exposures: Contractor's have experienced problems finding an enclosed shower. Also, asbestos is not something that can be seen or felt so people are reluctant to get in a safety shower and may not admit to possible exposure. A. We had one incident where a contractor had a possible exposure, then went home. Has Dow any responsibility for his personal car, home and family? B. Contractor's exposure to asbestos or any chemical: During the introduction to the plant, is asbestos talked about as a chemical and are showers required regardless of what chemical someone is exposed to? C. Dow is using contractors more and more for maintenance work. Dow personnel are told not to take their work clothing home to be laundered. Should we continue our current policy of having contractors launder their own clothes? 4. Why won't Dow wash clothing that may have been contaminated with asbestos? And if Dow will: A. Have the people at the laundry been medical fit-tested for asbestos work? B. Have they had the proper physicals? C. Have they had two (2) hours of awareness training? D. Are any or all of the above required? 5. Should each project be inspected and prepared before contractors are assigned or awarded a project? This should include having leaks, spills, slipping hazards, chemicals and asbestos checked by a knowledgeable person. 6. Should Michigan Division have an Operations & Maintenance Program that addresses asbestos in place? If we should, should each facility have one or should there be one that covers all buildings? Asbestos Abatement-and Asbestos-Containing Materials Management 7. Should Dow hire the 3rd party air clearance contractor? A. This has proven to be expensive. B. Each abatement contractor subs this work to different labs, which causes more than one lab to be in the plant at the same time, when one could be sufficient. tls. 1/29/90 ST0083543 nhseeoois BUILDING OPERATIONS & MAINTENANCE PROGRAM FOR ASBESTOS 1. Develop an inventory of all visible asbestos-containing material in the facility: A. The insulation on piping and equipment is being done through the Insulation Identification Program. All equipment and piping will be identified with labels as being asbestos or non asbestos containing materials in buildings constructed prior to 1972. All newly installed insulation will be labeled as non asbestos. B. Building materials will be identified before each renovation project is initiated, such as( drywall, floor tile, ceiling and insulating material.) C. Acid proof grouts, asbestos gaskets and structural steel with sprayed on fire retardant will be identified before maintenance activities are required. 2. Periodic examination of all identified asbestos-containing materials to detect deterioration will be conducted. Building inspections will be required every six months on all existing asbestos containing material. Should deterioration or damage be found appropriate action will be initiated. The superintendent .of each building will initate action and will maintain piping and equipment identification records for that building. 3. Procedures for handling asbestos-containing materials during the performance of small scale, short duration maintenance and renovation activity will be followed. (Refer to standard I.H. 140 paragraph VIII and IX attached) 4. Procedures for asbestos disposal will be followed. (Refer to standard I.H. 140 paragraph VIII D) 5. Procedures for dealing with asbestos-related emergencies will be followed. (Refer to standard I.H. 140 paragraph X) 6. Members of the building's maintenance engineering staff (electricians, heating and air conditioning engineers, plumbers, janitorial staff, etc.) who may be required to handle asbestos-containing materials shall be trained in safe handling procedures. Such training should include as a minimum: All maintenance personel entering Michigan Division shall be required to complete the Two Hour Asbestos Awareness Training as per Act 147 Bill No.770 sec. 59e. 7. Prohibited activities during maintenance are: A. Drilling holes in asbestos-containing materials. B. Hanging plants or pictures on structures covered with asbestos-containing materials. C. Sanding asbestos-containing floor tile. D. Damaging asbestos-containing material while moving furniture or other objects. ST00B35i>5 E. Installing curtains, drapes or dividers in such a way that damage is caused to asbestos-containing materials. F. Dusting floors, ceilings, moldings or other surfaces in asbestos-contaminated environments with dry brushes or sweeping with a dry broom. G. Using an ordinary vacuum to clean up asbestos-containing debris. H. Removing ceiling tile below asbestos-containing materials without wearing the proper respiratory protection, clearing the area of other people, and observing asbestos removal disposal procedures. L Removing ventilation system filters dry. J. Shaking ventilation system filters. 8. Proper identification of asbestos containing material and maintenace of warning labels for asbestos-containing materials is essential. (As per 29 CFR 1910.1200 (f) of OSHA's Hazard communication standard and 29 CFR 1926. 58.) tls. 3/8/90 rev. 3/29/90 rev. 10/1/90 ST0083546 PERMITS & INSPECTIONS FOR ALL ASB.REMOVAL PROJECTS 1. Before any asbestos project removal, encapsulation, or enclosure a permit must be abtained by the owners' repersentive from the asbestos inspector. 2. Reasons for and asbestos permit and inspector. A. uniformity for inspections and removals B. provide a central location for all asb. work in the Michigan devision. C. provide consistent contract admistration for asbestos abatment work. D. documentation of safety procedures E. uniformity in asb. exposures F. documentation of post abatement clean air. 3. The inspector and permit signer should knowlegable in asbestos rules and procedures and have completed the competent person training. 4. this job will probobly be a full time job and this person will have to work close with asbestos contract administrator. uiseeoois ASBESTOS REMOVAL SITE CHECKLIST JOB NO. _______________________________ DATE LOCATION ___________________________________________ SUPERVISOR ___________________________________________ YES BARRIERS Floor Covering Intact Wall Coverings Intact Sharp Protrusions Covered (to keep barriers trom ripping) Decontamination Chambers Erected Door Raps Intact Visible Emission _______ _______ _______ _______ _______ _______ FILTRATION AFD Positioned Property (opposite entry) Negative Air Pressure Developed on enclosures and glove bags (door flaps being drawn in) HEPA Vacuums Operating Properly _______ _______ _______ WARNINGS Barrier Tape Up Warning Signs Posted (at each entry) Labeled Bags On-hand DECONTAMINATION FACILITIES _______ _______ _______ Shower On-site Warm Water (supplied or heater) Towels/Soap/Shampoo Drained Filtered _______ _______ _______ _______ TQQLS/EQU1PMENT Scrapers/Knives/Brushes Wetting Agent Used Protective Suits Kept Intact Respirators Appropriate Filter Cartridges Changed Daily (min.) Hardhats/Safety Glasses/Sat ety Belts _______ _______ _______ _______ _______ _______ WORK PRACTICES Material Removed Wet Material Properly Bagged Respirators Left On In Work Area All Personnel Decontaminated Each Exit Equipment Decontaminated Each Exit _______ _______ _______ _______ _______ MONITORING Background Samples Taken (if YES, by whom) Personal Samples Taken (no.) Area Samples Taken (no.) Clearance Samples Taken (if YES, by whom) _________________________________ _______ _______ _______ NO _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ _______ N/A _____ _____ _____ _____ _____ _____ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ INSPECTED BY STOO835118 JOB NUMBER 33M312155Q. ASBESTOS REMOVAL PLAN A plan for removal shall be submitted with the bid and shall include in detail the following. How regulated area are to be handled with: barriers signs barricades detailed safety activity plan All monitoring results shall be copied to Industrial hygiene and the owners rep: Employees personal monitoring post abatement clean air Methods of compliance: Name of competent person on site Use of negative air Us of hepa vacuum cleaners Amended water Encapsulant Hygiene facilities: Shower and change room facilities Lunch room facilities Detailed removal procedures Negative pressure containment Glove bagging procedure Containment of the asbestos material House keeping procedures Disposal On site storage area Waste container to be used Services to be provided by Dow: Electrical water sewer disposal site The following would be described, but would assumed to be in the bid. Removal site Quantity of material to be removed description of material to be removed Friable or non-friable asbestos ST 0000676 Graph I. Relationship between ffpay spent handling insulation materials containing asbestos anc $Dcse (indoors). ,---------------------------------------------------------------------------- ) (43) i/f/Tfr/Tr/7rr/7777rft ow Operation Apply i . '71 (15*) Y//////7////////////////A (25$) r"i <&) 777777] (75J) Cut Remove (3$) VEH (5$) D J30 (5$) Cleanup Mix f777TWT (15*) (5*) Enr^) Breaks Set-up Stock Code: [ |* V77A $3ay $Dose Graph II. STQ0OO677 Relationship between Day spent handling insulation materials containing asbestos and Dose (outdoors). Operation Apply 1 (15*) v////////////Tr//f//m (23SS) mm m[Z112?) (1555) Cut Cleanup Breaks Remove |j__ (2) U7T\ (use) Mix m c?5 -1 . : STQ000678 om: rzs?] PATCPY PP.CTZCTZCN HZQUIH2:2XTS Material________________ I Herove j Mix ! Cut j Apply i Air Cell 1 x I Xaylo (Cal sil) | X j Xj X High Ter.? Mag Cxice No. 1 Plus (Webbers) j. j 1 jX j 1 ix i 111 > 1 Arr.entite (Asbestos Shorts 352) ! j | 1X i j Super Power Therm bastes !! j jj * Fiberglass . You shall wear a respi . C. vwr--- when ceir.g the above operations roarhe d X. You should wear a rsstirator* nar.avar a custy situation exists *X3A Dustfoe o Sure Guard (R-20$0) are the only allowed types __ \ : ; ucJ-v