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. Schultz
UCC 016214
I I
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Wr
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UCC 016215
REPORT DNOI
KCNITCRING -CRT A BOUND BROOK PLA NT/ 1580 THRU 1982
PAGE
UCC 016216
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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