Document 6ovmp2jjor1j01wd9exabO46

FILE NAME: Reichhold (REI) DATE: 1974 Nov 1 DOC#: REI019 DOCUMENT DESCRIPTION: Memo RE Asbestos & Reichhold Requirements in Order to Use it in Polyesters R&ichhold Chemicals, Inc. ntvr.QffictCmmmttaUm To> Hr. s. V. Morrow nomi white plains CCI Messrs. H. H. Reichhold Dak November 1, 1974 E. E. Shea P. J- Pass ***to Use of Asbestos in C. S. Stryker c. b. Breedlove- Detroit polyesters P. S. Hswett - " or. B ,Maasa zzuussaa 8. H. Melinat -/ T. P. Shnroaker Tnsaaloosa R. K. Sfcenerud A Tacoma 8. B. Walker / - ' " D. b. Wasson J - Azusa J. G. Weinmann - Elizabeth Dear vinnyt Due to the dramatic increase in the price of thixotropic agents used in polyesters, you are again considering the use of asbestos. Ao you know, there has been extensive correspondence on this subject throughout the corporation. This correspondence was initiated by a letter addressed to me iron Bd Jansen dated March 15 to which I replied with try now famous March 28 m&nbran- dun. This memorandum was written without the benefit of knowledge of any tasting that was done within SCI relating to the use of asbestos in polyesters. The memorandum to which yea have repeated ly referred giving the results of testing done in Azusa is dated Hay 7, six weeks after ay memorandum. The form of asbestos Which you contemplate using in your polyesters is a pelletized materiel supplied by the union carbide corporation, known as cal idria. Because of the pelletized form ` of this material, it la promoted as a non-dhsting material. Tfe is claimed that through the use of Celidrla few, if any, free asbes tos`fibers are released into the atmosphere thus negating to a large degree an employer's responsibility under the current OSHA asbestos standards* My letter of Marsh 28 is correct and is the corporate guideline for the use of all asbestos products regardless of form* However, this memorandum must be read in view of the specific circumstances (testing results) at any given location. fK C a V E D HGV 51374 fitlrtKM CHCMKtt, INC. UlU&.CftUR. r^ s JU-OOI52 ( f ~2~ onion Carbide conducted tests at Asusa on ROvewibet: 1, 1972 wherein they measured a ceiling concentration fiber count of 1.6 or a twa of. .27 foe the preparation of four batches in an 6 hour shift. This is considerably below the 5 fiber permissible 8 hour t k a . if you make the assumption that the twa in any worfc or storage location Lb in this range, then according to teq^ letter of March 28, Reichhold will be required to do the following t 1. Respirators - Respirators are not required as long ss the 8 hour TWA and ceiling limits are observed. Employees, however, should be required to wear respirators when (a) dump ing asbestos containers in the work area, (b) disposing of empty asbestos containers, i.e., placing them in a sealed drum and covering them, (e) cleaning up asbestos waste and spills and (e) unloading arty bene, car or 'trailer in which loose asbestos is appsrent. a respirator program complying with OSSA Regulation 1810.134 as outlined in your &CI Safety- Manual must be instituted and observed. 2. Clothing - Kb specie! clothing or change rooms and/ * or clothes lockers are required. However, rci should provide each employee who routinely handles asbestos with at least one clean work uniform each work week. Dirtv uniforms w i n bs-iauMU in a plastic bag bearing s caution label for lean- .dering at the expense of RCI. The laundry must be notified in writing of the asbestos end a standard form letter is attached. 3. Monitoring - Monitoring of both the breathing zone of the employee and the representative work areas ere required at least every six months.- Records must be maintained for at least throe years. .Employees normally working in areas sub ject to sampling and/or their designated representatives shall have acaesa to the records^ 4. Caution Signs - caution signs are not required pro viding airborne concentrations of asbestos fibers ere less than the prescribed exposure limits. However, scrap asbestos and other materials Which any contain free asbestos must be placed in sealed containers and labeled. Any outside waste disposal contractor handling any of the above must be notified that the waste m y contain asbestos, a standard form letter ia attached. RI-00I53 -3- S. Medical Examinations - xf& must provide, or make available, to each employee routinely handling or exposed to airborne concentrations of asbestos fibers, at our expense, a comprehensive medical examination as specified lathe regulations, L.e., 1910.93a (tf). these examinations will he conducted or made available to the employee at the following timesi (a) Prior to or within 30 calendar days of hia first employment in an .area where he is exposed to airborne asbestos, ' (b) Every year during his employment, as described above, within 30 calendar- dayB of the anniversary of hie lest examination. (c) Upon the employee's termination of employ ment with BCt or upon his transfer to another work area Where he is riot exposed to airborne concentra tions of asbestos fibers. All medical records shall he retained for at least 20 year. The* ***rds must be mode tvsliable upon Lhe request of an employee or formar employee to his physician. Those employees Who decline to take any medical exami nation provided by CZ, at its expense, will be required to sign a waiver form to be provided by White Plains. Each employee who has been exposed to a concentration in excess of the ceiling limit must be notified in writing' within five days. Employees or their representatives <i.e., the union) must be given access to the records. union carbide has, advised that the state of California has adopted e new rule regarding the medical examinations. Their interpretation is that if the TWft is half of the standard, then medical examinations are waived, I am currently verifying this and will advise as soon as this is confirmad. RI-00154 I I -4- Attachad 1. a copy of the OSSA Standard 1910.93a "Asheetos". Please do not hesitate to oontact me If any of my comments appear to conflict with the information provided to you by your supplier. yours. * TRMtcb Attachments T. A. Hadden RI-00155