Document 6ROYqQ6KBg9XaZEDeja8j9d24

c INTERNAL CORRESPONDENCE UNION CARBIDE CORPORATION 13 Q. BOX 1020, GRAND JUNCTION. COLORADO 81502 mei alS division |303) 2X15-3700 To (Name) OlvfeiOr* Locaton Area # p . Wolff Metals - Section Danbury, CT 1371 Cofjy co Ms. S. L. Baye Messrs. W. F. McClure J. L. Myers W. C. Thurber dTM-; Qf'igioauog Qep;, December 21, 1983 E/R-Occupational Health Product Safety Product Risk Assessment (3.3.16.1) The 1983 Metals Division Product Safety Plan submitted to the Corporation contained a commitment to prepare a plan for the risk assessment of one product. At that time the Corporate Product Safety Manual contained five alternative procedures for preparation of risk assessments. These were reviewed, two of the most applicable alternatives were selected, and a "first pass" estimate was made using asbestos as the product. On the basis of these two estimates, the plan shown in the attachment was developed to obtain more knowledgeable input on the various components of the risk estimate. It is estimated that a total of two to four person weeks, spread over a variety of departments, would be needed to accomplish this. It is intended that this plan meets our 1983 commitment to develop a plan with the specific,dates for completion to be added as part of our 1984 plan. The approach just described is a useful exercise in that it provides a systematic review of the risk management program for the chosen product and highlights any deficiencies that need to be corrected. The end result, however, is an arbitrary risk index number which has little meaning in itself. Recent discussions with Mr, Carmody have made it clear that what the Corporation really wants now is not only this type of analysis but also one that includes a risk assessment (increased cancer cases per year) and a liability assessment ($/year). The draft risk assessment/liability assessment procedure has been obtained from the Corporation and has been reviewed as it might be applied to asbestos, more particularly to lung cancer due to or allegedly due to asbestos exposure. To apply the procedure would be necessary to make an estimate of how many new people per year are exposed to our asbestos and probably also of the total people now who might be able to claim exposure at some time during their lives. A series of assumptions is then applied to these estimates to calculate risk and liability. A wide range of results can be obtained, depending on the assumptions made. \*. Vv' of -j - e; 3f7>\"L UCASB00473403 2- - In the case of asbestos, however, we have a fairly extensive history of our annual litigation costs and have already made a projection of such costs over the next five years. (Letter of Sul a Baye to 0.* L. Myers and W. C. Thurber of August 25, 1983.) The addition of an estimate of settlement or verdict costs for the next five years would appear to be a much more meaningful approach to obtain an annual cost than the use of the Corporate procedure. It was clear from our discussions with Mr. Carmody that we will have to include some sort of risk estimate in our 1984 Product Safety Plan. The draft plan submitted to the SHOC with your letter of December 13, 1983, showed an assessment of the liability risk from the asbestos business being made during the second and third quarters. It is suggested that this assessment consist of the finalization of the attached Plan and the modification of Ms. Baye's estimate noted above. If this is not acceptable to the Corporation, a risk/liability assessment using the Corporate procedure can be added at a cost of about one to two person weeks of time. Your comments and suggestions are requested. HBR/sw Attachment H. 8. Rhodes bcc: R. F. Wolff A copy of Ms. Baye's letter and the Corporate draft procedure are provided for your information. H. B. Rhodes UCASB00473404 ATTACHMENT PLAN - ASBESTOS RISK ASSESSMENT 1. Use basically Procedure (C) in Corporate Product Safety Manual with overview from Procedure (A) to help identify areas needing attention more specifically. 2. The time frame of reference needs to be defined. (But, may not be critical if emphasis is on risk management needs.) 3. Assistance will be needed from other departments as follows: - product Factor J. L. Myers - Frequency Due to User Factors J. L. Myers, G. L. Dickson - Managerial Factors 0 Organizational/Administrative - H. B. Rhodes/J. L. Myers 0 Communications - H. B. Rhodes/Sales/Distribution 0 Product Service/Management - Sales/D. F. Kapral 0 Marketing/Distribution - Sales/J. L. Myers 0 Quality Control and Documentation - J. L. Myers 0 Recall, Replacement, and Repair - Sales/J. L. Myers - Severity tf ;. ' - J. L. Myers, Corporate Law Department 4. Basic Approach H. B. Rhodes organize, coordinate and prepare report. UCASB00473405 q.C-C's OfCMICAL PR6DU.CT Si^FETy P fa & L E M S UCASB00473406 K IN D OF CHEMICAL h* o X2 o h- 40 ft* e QC 4 %> J9 4 y *3 3 y i ^<c -- O f- cn 5T LU __ I OQ O c>r 0-4 (VN > r4 S' * & i 8S I UCASB00473407 zy /^Wf /V *-*3 Lu i- < o fcr e o 10 X o "Z K- z C u. o V~ Uj t^ H vii ? Zi S5 Kd VI *: . *fc v* 4* <0 v/> * .s -p a_ 5 I$f)t cl V <X X ts 0 <* o sf f" # i *t >V - im * I i ? *w o oi 49 Ql *0* M F 0> 1 w Ql. iC t-a f* 3 1~ rJ fs ^o' sr fo 4/1 *- if _<o& ' $T* v uF *- H %<J */ Ji **A *JC 3 u *4 U ~1> If ~i L Ml * mv m 5i fH v*k- I * 2t>if V> * ^l r H%- %# ? 1> v> if u V%I/ V> i in -- iu *'3 18 4. S o .& * ^ V <c ^ >- ^ t % vi <j UCARRnnA7^df)R 12/21/83 Metals Division Policy For the Preparation and Distribution of Experimental Product and Experimental Product Safety Data Sheets The Corporate Product Safety Policy includes a requirement that EACH COMPONENT ESTABLISH AND IMPLEMENT A PROGRAM FOR THE PREPARA TION of Experimental Product Safety Data Sheets for every new POTENTIALLY HAZARDOUS CHEMICAL SUBSTANCE OR MIXTURE THAT IS OFFERED TO PROSPECTIVE CUSTOMERS. The Metals Division adopts the Corporate Category 11 "Experimental Product Safety Data Sheets (EPOS) Policy" (attached) as Division Policyv and establishes the following procedures for the distri EPDSbution of experimental products/ the preparation of and the distribution of EPDS. It is recognized that: IT may be desirable to distribute experi mental products during various stages of development; that the available information at the time of distribution may vary; that the hazards of different products may vary; that customer appli cations may range from laboratory research to plant development programs; that customers may posses varying capabilities for handling hazardous materials; and that this diversity requires a judgement with respect to each distribution of an experimental product. . UCASB00473414 Page 2, Each proposed distribution of an experimental product will BE REVIEWED BY THE DlRECTOR-TECHNOLOGY WHO, AFTER CONSIDERING THE FACTORS CITED IN THE PRECEEDING PARAGRAPH, MAY REQUIRE THAT ADDITIONAL PRODUCT SAFETY INFORMATION BE DEVELOPED BEFORE THE DISTRIBUTION OF THE PRODUCT AND THE EPDS ARE APPROVED. No DISTRIBUTION OF PRODUCT OR EPDS WILL BE MADE WITHOUT THE APPROVAL OF THE DlRECTOR-TECHNOLOGY. The Manager of Product Safety is the coordinator for the prepara tion AND REVISION OF EPDS.? He WILL: ASSEMBLE THE VARIOUS INPUTS AND CHECK THESE FOR CONSISTENCY; SECURE APPROVAL OF EACH EPDS OR EPDS REVISION BY THE DlRECTOR-TECHNOLOGY BEFORE IT IS ISSUED; MAINTAIN A COMPLETE FILE ON ALL EPDS; AND FILES FOR EACH EPDS CONTAINING THE INDIVIDUAL INPUTS AND THE APPROVAL SIGNATURE. The EPDS format (copy attached) will follow the OSHA form 29 WHICH CONSISTS OF NINE SECTIONS. EACH SECTION WILL BE COMPLETED TO THE EXTENT ALLOWED BY AVAILABLE INFORMATION. WHERE INFORMA TION IS NOT AVAILABLE IT SHALL BE SO NOTED. The development and updating of information for each section WILL BE DONE BY TECHNICALLY QUALIFIED INDIVIDUALS, AS FOLLOWS: . Section 1 Identification Product technical name. ............................. Chemical formula (or alloy composition). Synonyms Developed by Technology Department UCASB00473415 Page 3. Section 11 Physical Data Physical properties, including, where applicable, appearance, ODOR.* MELTING POINT, BOILING POINT, VOLATILITY, VAPOR PRESSURE, SPECIFIC GRAVITY-DENSITY, VAPOR DENSITY AND WATER SOLUBILITY. Developed by Technology Department. Section 111 TLV Data Exposure standards mandated by the Occupational Safety and Health Administration (OSHA) and/or the Mine Safety and Health Adminis tration (MSHA): the recommendations of American Conference of Governmental and Industrial Hygienists (ACGIH) and/or the National Institute for Occupational Safety and Health (NIOSH). Where no TLV DATA are available, data for related material may be listed. Developed by the Manager-Product Safety and Manager-Occupational Health. Section IV Fire and Explosive Hazard Combustibility Explosive tendency . Developed by Technology Department Fire Fighting Procedures Developed by the Director of Safety Section V Health-Hazard Data First-Aid procedures for: inhalation, swallowing, skin contact, eye contact. Health effects of exposure to the product. Developed by the Medical Department through its Corporate Applied Toxicology Department UCASB00473416 Page 4, VISection Reactivity Stability Conditions to avoid Materials to avoid.......................... Hazardous decomposition products Developed by Technology Department Section Vll Spill Leak and Disposal Information Procedures to contain and clean up a spill or leak, Disposal recommendations, ~ Developed by the Manager-Product Safety through consultation with operating, technical and environmental personnel, VlllSection Employee Protection Information Respiratory protection Eye protection Other protection Ventilation Developed by the Manager-Occupational Health . IXSection Additional Information Labeling Handling and storage Developed by the Manager-Product Safety in cooperation with the Corporate Distribution and Corporate Applied Toxicology Department. Each individual or department responsible for the development of information will maintain a file in which data sources and references used are identified. UCASB00473417 Z Page 5. The Director-Sales is responsible for the distribution of ALL APPROVED EPDS TO THE PROSPECTIVE CUSTOMERS FOR THE PRODUCT. For each distribution of an experimental product that has been APPROVED BY THE DIRECTOR-TECHNOLOGY, HE WILL ASSURE THAT AN EPDS IS RECEIVED BEFORE OR AT THE TIME OF THE FIRST DELIVERY. The Director-Sales will maintain a list which contains the DATE ON WHICH AN EPDS OR REVISED EPDS IS SENT TO EACH CUSTOMER AND THE NAME OF THE INDIVIDUAL REQUESTING THE DISTRIBUTION. To ASSURE THAT THE LIST IS COMPLETE EACH REQUEST FOR AN EPDS SHOULD BE IN WRITING TO THE DlRECTOR-$ALES/ AND A COPY SENT TO the Manager of Marketing Services. EPDS WILL BE REVISED AS REQUIRED BY CHANGES IN REGULATIONS OR TO INCLUDE NEW OR IMPROVED INFORMATION REGARDING THE PRODUCT. IN ANY CASE/ EACH EPDS WILL BE REVIEWED AT LEAST EVERY YEAR AND REISSUED UNDER A NEW DATE/ OR WITHDRAWN IF APPROPRIATE. UCASB00473418