Document 6RbdXz69wwnY53m324qxadGr9

iOl/-o7^5C * SHARE INTERNAL CORRESPONDENCE UNION CARBIDE CORPORATION P.O. BOX 670, BOUND BROOK. NEW JERSEY 0BB05 SPECIALTY CHEMICALS DIVISION toiName] Division Legation Area Mr. W. Bosserman -- - -- Sistersville copy*0 Mr. W. H. Barton* *Letter only Date Originating Dept. Area Subject March 3> 1983 SHARE Asbestos Procedure Per your recent request, I am enclosing the Bound Brook Procedure for Asbestos with background information giving salient points of our program in response to the OSHA citation of May 6, 1982. Also included are personal monitoring data on typical asbestos removal jobs with references to figures in the addendum of the procedure. With this background data, we prescribe disposable dust respirators (3M No. 8710 or Norton No. RIO70) as sufficient protection for up to five times the TLV. / rk att. P. A. 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Cl 1C U 49 r >- Ui X 15H3 19 X 3 -i C AHU . - c oH zUi eX z H1 U_ 91 X JUC N XX => h ui a N H tO a; d > X ^r a. ci a H* 4, UUI tO 3 VS 002 X ICD 19 * z ci Hi H X H *4* O tO 91 -* UI Z> o. a Jt iX c K) 30K X , OZU 19 t * g g H 3 Cl Cl H O o t> d J H CM -J X u Ui X c Ui X (X ic to H o Z X z H to to Ui H O A it: 1- to < to x i K Ui Z CD o to u < - tO uj OA r^ o > u x to o to UI OH CtOD ro o ;o oo CO o to UI O CD co uj O ID JJJJJJ J UCC 016219 K> O O O tCoP x o x to o Cl Xz Ui KX 3 O. Ol o o JX to OU DC H >Q O X UzI MAINTENANCE PROCEDURE By: o. J. Nadbielny W. D. Neal PLANT 312 BOUND BROOK MAINTENANCE DEPARTMENT No: . MP- 366.1 Page: i of 5 Effective Revised: Approved: 1-26-79 5/25/82 1.0 PURPOSE ASBESTOS REMOVAL PROCEDURE . . To protect workers and others from inhalation of asbestos fibers, to safely remove and dispose of insulation materials which contain friable (easily crumbled or crushed into powder) asbestos and. also to specify appropriate notification to regulatory agencies. ' 2.0 RESPONSIBILITY . It is the responsibility of the appropriate First Line Supervisors and Craftperson to control the safe removal, disposal and notification activities. 2.1 It is the responsibility of Environmental Protection/Occupational Health (EP/OH) to notify EPA of yearly amount of asbestos activity in the plant, per R. Burstein's letter (attached). Where unanticipated asbestos removal work is to be conducted (i.e. notification was not given at beginning of calendar year or end of previous calendar year), the responsible person must notify the EP Department (R. Burstein) 45 days prior to demolition. (Notification requirement is for demolition work-not required for repair work.) ' 2.3 The responsible.Supervisor shall provide the following information regarding the proposed work to the Environmental Engineer and/or the Industrial Hygienist: :. 1. Specific location of the job site. 2. Date and time interval'Of the work. 3. Initiate a Hazardous Work Permit 2.4 The responsible supervisor shall ensure that employees assigned to the work have medical clearance and respirator training. 3.0 PROCEDURES . 3.1 Overlap of EPA and OSHA regulations - the regulations do overlap some, as the OSHA objective is protection of workers and others directly involved. The EPA objective is protection of people everywhere. These procedures consider all regulations for each agency; EPA and OSHA. UCC 016220 MAINTENANCE PROCEDURE By: S. J. Nadbielny W. D. Neal PLANT 312 BOUND BROOK MAINTENANCE DEPARTMENT No: MP- 366.1 Page: 2 Of 5 Effective: Revised Approved: 1-26-79 5-25-82 ASBESTOS REMOVAL PROCEDURE 3.2 Personnel engaged in asbestos work. 3.2.1 Personnel engaged in asbestos work shall wear respirators and protective clothing according to the hazard rating of the job as follows: - . .. .. Hazard Rating Fibers Per cc Protective Clothing Respirator 1. < 10 Coveralls Optional Air Purifying (3M Disposable) 2 > 10 Air Purifying ' (3M Disposable) 3 >20 Whole Body ' Powered Air Purifying Coverings: . > Coveralls or Type C Supplied Air, Head Covering Continuous Flow or Foot .Covering Pressure-Demand Gloves >200 Type C Supplied Air Continuous' Flow or Pressure-Demand To determine the hazard rating, compare the proposed job with typical jobs already monitored (See Addendum I). If the job is not similar to one listed, it must be treated as rated 4 requiring air-supplied respiratory protection. 3.2.2 If the proposed job cannot be identified with a correspond ing job with a hazard rating, it shall be considered to have a rating of 4 until properly monitored for an initial de termination of fiber level. While this determination is being made, .it is mandatory that whole.body covering in eluding coveralls, head, foot, and hand covering and supplied breathing air be used. ' .. 3.2.3 The SHARE representative shall enter the hazard rating on the Hazardous Work Permit to release the job if the work does not have an established hazard rating. Successive Hazardous Work Permits shall be submitted to the SHARE representative or Emergency Coordinator for entry of hazard ratings in the event that the continuation of the job may ' result in a change of hazard ratings. . UCC 016221 MAINTENANCE PROCEDURE * By: S. J. Nadbielny W. D. Neal PLANT 312 BOUND BROOK MAINTENANCE DEPARTMENT ASBESTOS REMOVAL PROCEDURE No: MP- 366.1 -Page: 3 Of 5 Effective : Revised: Approved: 1/26/79 5/25/82 3.2.4' No outerwear shall be worn over disposable protective clothing. ' . ` . 3.2.5 Persons shall desuit for breaks and lunch within the protectee work area except for jobs with Hazard Rating of 1. 3.2.6 Dispose of contaminated protective clothing in sealed, mark ed plastic bags, at the end of the workday. 3-2.7 Personnel engaged in asbestos work shall make every effort to minimize air borne particles. 3.3 . Work Area Identification 3.3.1 Perimeter cf hazardous area shall be identified with -yellow barricade tape. ' 3.3.2 Warning signs (3.7.1) shall be posted at 50 feet intervals along barricade tape. ' 3.4 Removal of Insulation ' . 3.4.1 Removal prior to demolition is required if excessive dusting is expected. ' 3.4.2 . Insulation shall be wet down with "amended water" (1 oz. Tergitol Min-foam 2-X) per 5 gal. water,- prior to removal and kept wet during removal, including that on equipment to be dismantled in sections exposing the broken edges of insulation. 3.4.3 Loose insulation stripped from equipment, pipe, etc. shall not be dropped or thrown to the ground. 3.4.4 Drop cloths are required on grating to catch falling debris. 3.4.5 Loose insulation shall be placed in plastic bags, sealed, tagged and placed in sealed fiber drums (so they won't break in loading) (3.7.2) prior to disposal. 3.4.6 .` Area cleanup shall be by wet or vacuum method -- never use air, brooms or brushes. Waste shall be put in plastic bags, sealed and warning tags (or printing on bag) (3.7.2) applied. ' UCC 016222 MAINTENANCE PROCEDURE By : S. J. Nadbielny W. D. Neal PLANT 312 BOUND BROOK MAINTENANCE DEPARTMENT No: MP- 366.1 Page: 4 of 5 Effective: 1-26-79 Revised: 5-25-82 Approved: ASBESTOS REMOVAL PROCEDURE 3.5 Disposal ' . 3.5.1 Disposal is by U.C.C. EP Department. ' . 3.5.2 Small amounts of insulation removed from repair work should be put in plastic bags and deposited in fiber drums. 3.5.3 The responsible person will notify EP Department (R. Burstein) of the number of drums (after completion of work). 3.6 Notify EP Department of annual amounts of insulation to be removed (by UCC EP Department). . 3.7 Warning Communications - sign, tags and bags. ' - 3.7.1 Signs for posting work areas and'disposal sites are available from stores. They comply with OSHA copy, letter size, sign color, size, etc. Code I 69 --251 --00S. Q0**.rv wot, LoaV a. uwxIAcuJ Supplier^ _____________________________'__________^ i'll tjte. /ab. ___________________ Asbestos Dust Hazard Avoid Breathing Dust ' Wear Assigned Protective Equipment Do Not Remain In Area Unless Your Work Requires It Breathing Asbestos Dust Maybe Hazardous To Your Health 3.7.2 Tags and Bags and Drums for insulation waste and contamination clothing are available in stores. They also.comply with OSHA regulations regarding copy, letter size, size of "tag, color, etc. Tags are available in stores. : [ CAUTION ~ Contains Asbestos Fibers Avoid Creating Dust Breathing Asbestos Dust May Cause Serious Bodily Harm 3.8 The asbestos containing materials on this site are at the following locations. . ' 3.8.1 Older elbows and fittings applied before 1973 very likely were coated with asbestos cement mixtures. UCC 016223 MAINTENANCE PgOCEDURE By: S. J. Nadbielny W. D. Neal . PLANT 312 BOUND BROOK MAINTENANCE DEPARTMENT No: MP-' 366.1 _ Page: 5 of 5 Effective: 1-26-79 Revised: 5-25-82 Approved: ASBESTOS-REMOVAL PROCEDURE 3.8.2 "Pipelines containing hot liquids and vapors such as steam, hot water, Dowtherm, heating oil, etc. installed prior to 1973." - 3.8.3 "When in doubt, treat insulation of unknown composition as asbestos until proved otherwise." 3.8.4 If identification of insulation is required contact EP/OH Department (D. Neal). . . UCC 016224 ADDENDUM I TYPICAL INSULATION REMOVAL JOBS WITH HAZARD RATING OF 1 F/Gt. l: 5TILL 23 STFAM 5t/PPLr, BLP6, 21 -------- v22Lr- 3 OPS I ST e* S2'X' pire ____ V"------ ----l)c^ ktD rtJSAi Tr ------ 2~ p//>r Jr FT% J Jp/SVl-^TlfrJ r^rM^VED VrHiLf" H*T Pi ft-. 2 ..Couv ewa-tfL-J/VE5, W'FST Vv%LL, J3L-P&. 2_/ Ff&. 3; Tunnel, A7 p A 12- 4 1a CgMDE'KJ SATC r.TAh/K'-BLi.97i > V> "______ / __ F/6\ -4; i 00 5$ FT t'4? BLOCK 1 ns. . With ma5tk ^<7vr^iKie- _ UCC 016225 FJ6t. 5\* 5'PLl 2 KECF/vEf?. BU>6.2/ 3^pn lx* IMiULATI^M HIGHLIGHTS OF ASBESTOS PROGRAM OSHA 1910.1001 CANNOT BE PRACTICALLY ADMINISTERED DUE TO FULL SUIT UP AND SELF-CONTAINED BREATHING REQUIREMENT ON ALL JOBS. - ESTABLISHED COMPROMISE PROGRAM BASED UPON DEPARTMENT OF LABOR COMPLIANCE SECTION INTERPRETATIONS OF REGULATION 1910.1001 ALLOWING THAT EXACT COMPLIANCE TO 1910.1001 WOULD RESULT IN A .. DE MINIMUS TECHNICAL VIOLATION PROVIDED THAT ELEMENTS OF THE "INTERPRETATION" ARE FOLLOWED. - DEVELOPED TYPICAL JOB CATEGORIES AND GENERATED DATA SHOWING FIBER COUNT FOR EACH CATEGORY-ALL OF WHICH ARE AT LEAST 75% LESS THAN TWA STANDARD. - ESTABLISHED ONGOING PROGRAM TO EXPAND DATA BASE FOR EACH CATEGORY. - REVISED ASBESTOS REMOVAL PROCEDURE TO COMPLY WITH OSHA STANDARDS BY MEANS OF JOB CATEGORY CONCEPT. - STRENGTHENED COMPLIANCE TO PLANT'S RESPIRATOR PROGRAMS IN LINE ORGAN IATION, I.E., MEDICAL QUALIFICATIONS, FIT TESTING, FACIAL HAIR POLICY. - KEYS TO COMPLIANCE ARE: . USE OF "AMENDED WATER". . PROPER HANDLING TECHNIQUES BY PERSONNEL. . THROUGH TRAINING OF INVOLVED PERSONNEL. pas/rk 6/3/82 . UCC 016226 POINTS TO REMEMBER 1. OPERATING DEPARTMENT IS RESPONSIBLE TO IDENTIFY ALL JOBS THAT COULD INVOLVE ASBESTOS REMOVAL, 2. ALL JOBS THAT COULD INVOLVE ASBESTOS REMOVAL REQUIRE A HAZARDOUS WORK PERMIT, ON SHIFTS, ASBESTOS REMOVAL WILL BE CONSIDERED "CLASS B" WORK. 3. WETTING OF INSULATION, PRIOR TO REMOVAL, WITH "AMENDED WATER" IS REQUIRED,.'. 1 OZ. TERGITOL PER 5-GAL. WATER 4. ASBESTOS REMOVAL SIGNS ARE TO BE POSTED AT THE JOB PERIMETER AND ARE AVAILABLE IN STORES. CODE 69-251-005. 5. ALL RESPIRATOR USERS MUST BE MEDICALLY QUALIFIED. 6. ALL EMPLOYEES TRAINED IN THE ASBESTOS REMOVAL PROCEDURE SHALL BE RECORDED ON STAIRS. * ejb/rk 5/25/82 UCC 016227 STATUS_QF ASBESTOS MONITORING PROGRAM OSHA 1910.1001 TLV'S 8 TWA = 2 FIBERS/CC 15 MIN. CEILING = 10 FIBERS/CC 5 INSULATION REMOVAL JOBS MONITORED MAY 11-19. 4 HAD LEVELS UNDER 0.5 F/CC 1 EXCEEDED TLV WITH 5 F/CC DUE TO INADEQUATE WETTING. WET DOWN IS THE KEY WITH NEED FOR IMPROVED TECHNIQUES. TEST PROGRAM CONTINUING BUT END IS IN SIGHT ASBESTOS REMOVAL PROCEDURE RE-REVISED FOR CRITIQUE. DRUM OF TERGITAL MIN-FOAM 2x IS ON TAP IN BUILDING 21 SHOP. HANDY-DANDY TEST KITS RECEIVED. WORKING UP REFERENCE MANUAL FOR ASSIGNMENT OF HAZARD RATING. wdn/rk 5/20/82 UCC 016228 ADDENDUM I TO MP-566.1: ASBESTOS REMOVAL PROCEDURE REFERRING TO MAINTENANCE PROCEDURE 366.1 "ASBESTOS REMOVAL procedure", SECTION 3.2 REQUIRES the specifying of protective CLOTHING AND RESPIRATORS ACCORDING TO "HAZARD RATING" BEFORE STARTING THE JOB. COMPARE THE PROPOSED JOB WITH TYPICAL JOBS ALREADY MONITORED (SEE ATTACHED SHEET) AND FOUND TO HAVE A HAZARD RATING OF 1, THEREBY PERMITTING AIR"PURIFYING_TYPE RESPIRATORS RATHER THAN FORCED AIR. IF A SIMILAR JOB CAN BE FOUND, ASSIGN THE HAZARDOUS RATING GIVEN THE TESTED JOB. IF THE JOB IS NOT SIMILAR TO ONE LISTED, IT MUST BE TREATED AS RATED 4 REQUIRING AIR-SUPPLIED RESPIRATORY PROTECTION. wdn/rk 5/20/82 ATT. UCC 016229 PROPOSED ASBESTOS PROGRAM - u/a MODIFIED ASBESTOS REMOVAL PROCEDURE WHICH MEETS OSHA REGULATION . MEDTCAL REQUIREMENTS . PROTECTIVE CLOTHING OUTSIDE . CHANGE ROOM ISSUE FOR CONTINGENCY . - FORM UNION/MANAGEMENT COMMITTEE TO IMPROVE PROCEDURE _ / . CONSIDER RECOMMENDATIONS FROM COMMITTEE FOR INCORPORATION INTO LONG TERM PROGRAM. - FORM SHARE/MAINTENANCE COMMITTEE TO EXECUTE PRACTICAL LONG TERM PROGRAM. . pas/ejb/wdn/lem/rw/? . IDENTIFY TYPICAL ASBESTOS REMOVAL JOB CATEGORIES FOR PLANT. . DEVELOP BASELINE, BACKGROUND DATA FOR EACH OF THE ABOVE CATEGORIES. . CATEGORIES FALLING BELOW 20 FIBERS PER CM^ - WILL REQUIRE 3M-8710 DISPOSABLE FACE MASKS. ^ . CATEGORIES FALLING BETWEEN 20-200 CM^ WILL REQUIRE POWERED AIR PURIFIER. . CATEGORIES FALLING ABOVE 200 CM^ WILL REQUIRE SCBA DURING DURATION OF JOB. . ALL OF THE ABOVE FALL INTO MEDICAL SURVEILLANCE PROGRAM. - ABOVE LONG TERM PROGRAM CARRIES A"de'MININis" RISK PENALTY BUT IS SUPPORTED BY P.O.D. SHARE. . GULF COAST PLANTS PRACTICE ESSENTIALLY THE SAME PROCEDURE. . DU PONT PRACTICES THE SAME APPROACH. pas/rk 5/10/82 UCC 016230 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION CITATION and NOTIFICATION OF PENALTY Belle Mead Area Office GSA Belle Mead Depot, HLdg. T-3 Belle Mead, NJ 08502 ISSUANCE 0ATE > 0SHA NUIUSER 5/6/82 1 REGION TZ558 j -153 ` AREA TAGE . 02 2140 1 0F 1 TYPE'OFWIOLATIONIS) CITATIOVNO. INSPECTION DATE: 4/1-5/3/82 OTHER INSPECTION SITE: 1 River Road CERTIFIED MAIL-RRR RLscataway, NJ 08805 TO: THE LAW REQUIRES that a copy of this ttiion Carbide Corporation P.0. Box 670 Bound Brook, New Jersey 08805 Citation be posted immediately in a promi nent place at or near the location of the violation(s) cited below. The Citation must remain posted until the violations cited be Attn: Mr. Eric Baumann Ftersonnel Safety Coordinator low have been corrected, or for 3 working days (excluding weekends and Federal holi days) whichever is longer. - This citation describes violations of the Occupational Safety and Health Act of 1970. The penalty lies) listed below are based on these violations. You must correct the violations referred to in this citation by the dates listed below and pay the penalties proposed, unless within 15 working days (excluding weekends and Federal holidays) from your receipt of this citation and penalty you mail a notice of contest to the U.S. Department of Labor Area Office at the address shown above. (See the enclosed booklet which outlines your responsibilities and courses of action and should be raad in conjunction with this form.) ITEM NUMBER STANDARD. REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION DATE BY WHICH VIOLATION MUST BE CORRECTED PENALTIES ARE DUE WITHIN 15 DAYS OF RECEIPT OF THIS NOTIFICATIOr UNLESS CONTESTED (See enclosed Booklet) This Section Ma Be Detached Before Posting PENALTY Hie issuance of this citation does not constitute a finding that a violation of the Act has occurred unless there is a failure to contest as provided for in the Act or, if contested, unless the citation is affirmed by the Review Commission. The violations described in this citation are alleged to have occurred on or about the day the inspection was made unless otherwise indicated within the description given below. 29 CFR 1910.1001(f)(1): Initial monitoring was not conducted in such a manner to determine whether every empLoyee`s exposure to airborne asbestos fibers is below the prescribed limits: 5/3/82 $0 a) Tunnel which contains utility lines and process lines, TVro.maintenance mechanics removing asbestos insulation from pipes. 29 CFR 1910.1001(g)(l)(i): Asbestos caution signs were not posted in such a manner so employees could read them and take necessary protective steps before entering an area marked by the signs: 5/3/82 $0 a) Tunnel which contains utility lines and process lines. Bnpioyees removing asbestos insulation from pipes. UCC 016231 INTERNAL . CORRESPONDENCE' UNION CARBIDE CORPORATION p. a. box sm bound brook, new jersey obbos POLYOLEFINS DIVISION ______________________ ToiNsmai Hr. T. P. Raby Division Lon*cion Area Copy to Hr. G. H. Berry -- B--71 Mr. K. E. Martin - Texas City Mr. P.- A. Schultz - B-ll o*ce . originacinoOopc. March 16, 1982 SHARE Department Area sobj.ee Asbestos Removal Subsequent to my. comments on SH-256, I received the attached fromKi rk Martin. The letter from OSHA moderates the literal reading of 1910.1001 (c) (2) (iii) which would otherwise put workers in air supplied respirators when demolish ing insulation containing asbestos. However, the alternative places a heavy burden of administrative control and personal monitoring requirements on the employer. It would be helpful to incorporate these requirement in SH-256. /rk attachment W. D. Neal Staff Industrial Hygienist UCC 016232 INTERNAL CORRESPONDENCE UC 149- 2 P. O. BOX 471, TEXAS CiTY, TEXAS 77590 To: R. E. Cope - 500 ^W.^D.^Neal -^312 S. E. Robinson - 519 C. R. Roundtree - Bechtel March 11, 1982 Subject: Personal Protective Equipment - Asbestos Demolition Attached is a recent OSHA interpretation of standards associated with asbestos demolition, authored by Mr. Patrick R. Tyson, Acting Director of Federal Compliance and State Programs. I will not attempt to conment on Mr. Tyson's letter as it clearly outlines the current policy regarding the removal or demolition of asbestos. . Kirk E. Martin KEM:ir Attachment UCC 016233 Department of Labor '1 " ,_ J) 7 B32 Occupational Sniciy nmj McaiiM Aiimmistraiion Washington, D.C. 20210 Roply to tho Attention of: ' John M. Hochstrasser, Ph.D. Manager, Industrial Hygiene Tcnncco Chemicals Park 80 Plaza West-1 Saddle Brook, New Jersey 07662 Dear Dr. Hochstrasser: This is in response to your inquiry addressed to . Mr. Bruce Hillenbrand regarding the use of type "CH supplied-air respirators to comply with 29 CFR 1910.1001 (c)(2)(iii) (spraying, demolition or removal of asbestos). Please accept my apology for the delay in our response. OSHA has replied to similar questions in the past regarding the use of type "C" supplied-air respirators. As you know, 29 CFR 1910.1001(d)(2)(iii) states that a type "C" respirator shall be used when the ceiling or the 8-hour, time-weighted average airborne concentrations of asbestos fibers are reasonably expected to exceed 100 times the permissible exposure limits. In accordance with 29 CFR 1 91 0.1001 (c){2)(iii), employees about to engage in the spraying of asbestos, in the removal or demolition of pipes, structures, or equipment covered or insulated with asbestos, or in the removal or demolition of asbestos insulation or coverings, shall be provided with and shall use a type "C" continuous flow or pressure-demand, supplied-air respirator regardless of the concentrations of asbestos to which they may be exposed. * However, if the employer has conclusively established the upper concentration of airborne asbestos that employees . could confront during spraying, demolition or removal, and the concentration does not exceed 100 times either the 8-hour time-weighted average or ceiling limits, then any of the respirators presented in 29 CFR 1910.1001 (d)(2)(i), (ii) and (iii) that afford adequate protection at such upper concentrations of airborne asbestos may be used. In such a case, although the employer would technically be in viola tion of 1910.1001(c)(2)(iii), OSHA would regard it to be a de minimis violation of the standard, as provided in Section 9 of the Occupational Safety and Health Act. Therefore/ no citation would be issued, no penalty would be proposed, and no corrective action would be required. * To amplify these statements, we would add that the establishment of the upper concentrations of airborne asbestos fibers may require considerable effort if there are variations from operation to operation in any factors such as the following: UCC 016234 2 (1) (2) (3) (4) (5) (6) (7) (8) Binding material Type of asbestos (e.g. length of fibers, composition) Percentage of asbestos in the insulation Removal techniques Amount of insulation removed Engineering and work practice controls instituted to reduce employee exposures Complement of employees How well employees are trained in asbestos control procedures. - Proof that the average airborne concentration of asbestos fibers an employee will confront will not exceed 100 times the 8-hour, time-weighted average and/or ceiling concentrations must be determined by the employer by applying sound scientific or engineering principles. The most reliable method would be through measuring exposures under all of the various conditions that will be encountered, as described in 29 CFR 1910.1001(f) (2){ii), by collecting personal samples of airborne asbestos within the affected employees' breathing zones. The asbestos should be collected on mixed cellulose (cellulose acetate-cellulose nitrate) membrane filters that are 37 milli meters in diameter and of 0.8 micron porosity. The filters should be held in three-piece cassettes. Sampling should be performed using an open-face cassette with the filter fully exposed. That is, one end piece of the cassette (not just the small plug) must be removed when sampling. The pump drawing the air through the filter must be operated at an accurately determined flow rate in the range of 1.0 to 2.5 liters per minute, depending upon the expected airborne concentration. . A practice that possibly could reduce airborne concentrations below 100 times the permissible limits of exposure would be the application of a fine spray of "amended water" to the asbestos-containing material before and during asbestos removal operations. "Amended water" is water containing 1 ounce of a surface active detergent or wetting agent (50% polyethylene ester and 50% polyoxyethylene ether) per 5 gallons. The employer must provide his employees with the proper respiratory protection at all times, if necessary. An employee exposure to asbestos, therefore, must be determined beforehand by using valid techniques such as those described above. In some instances the employer may have to provide supplied-air respirators (as prescribed in 29 CFR 1910.1001(c)(2)(iii)) UCC 016235 until ho has determined the exposure levels of his employees to asbestos. An employer must be able to demonstrate that he is in compliance with all provisions of the asbestos standard by providing information (i.e., sampling records) to OSIIA, if requested during the course of an inspection of the employer' jobsite. We would stress the extreme importance of complying with 29 CFR 1910.1001(E)(2)(H) if an employer decides to provide respirators described in 29 CFR 1910.1001(d) (2)(i) or (ii) rather than a type "C" continuous flow or pressure-demand, supplied-air respirator. Thank you for your support and your thoughtful comments. If I can be of further assistance, please do not hesitate to contact me again. Patrick R. Tyson Acting Director, Federal Compliance and State Programs Enclosure UCC 016236