Document 6wJXEo8BappGbgnKwvOKK7L31

.!> ' J ENGINEERING REPORT for GENUINE PARTS COMPANY RAYLOC DIVISION HANCOCK, MD January 21, 1592 prepared by ; Theltayefeifsf David W. Glassraan Engineering Specialist - Industrial Hygiene & Environmental Services Unit Baltimore, MD THE TRAVELERS ENGINEERlNpjDlVISSON iI ! Engineering Services. Protecting People and Property Since .1894 t7Q2 1 A6H3 Pnniod in U.S.A. :% 1 .PLAINTIFF'S EXHIBIT LeCou*-- Alui NAPA 040 NOVO20433 SCF-NAPA-5000 if TMGcavelersj P-C Commercial Un Loss Prevention end Engineering 250. W. ; Pra tt Street Suite 920 Baltimore, MD 21201 February 18, 1992 Hr. Ron Shives, General Manager Genuine Parts Company ft; Rayloc Division 100 Rayloc Drive Hancock, HD 21750 Dear Mr. Shives: This confirms my survey of your facility to evaluate employee exposure to airborne asbestos fibers. This evaluation was -done as part of an ongoing., evaluation of controls implemented to reduce the employee exposure. ' The results of the survey are contained in the attached report. Thank you for your cooperation, if you have any questions feel free to contact me. Sincerely, David W. Glassinan Engineering Specialist - Industrial Hygiene & Environmental Services Unit 410 962-6451 report is bosca upon cne into/rot iMp^""c3ipiny'p?rsonnel era/or (tie conatciorts 'end practices ue tfffle of the visit. The report nay not 'lis't^ratttfsofe conditions and practices; others may exist. This report is not on endorsement of end it nay not be used to ev^^^^fproaote eny practices, procedures or products. Surveys and recorunendations node by The Travelers ere advisory end designed'to essist customers in the maintenance of their own safety activities. Recorasendetions ere not designed qt intended forI(ny other purpose. The Travelers is not responsible for nek 109 changes in the operations/procedures of the location or for icpl'enenting any recienmendations. Boilers, pressure vessels and machinery ere inspected only for conformance with jurisdictional lews, regulations end/or Travelers underwriting requirements. C-19102(R491) NOVO20434 8-1775.xxx/cak (February 13, 1992) Distribution: Orig: As Addressed l cc: Mr. John AderhoJ^f^' nivf elnn NaniitiArilLwii 600 Rayloc Drive, W Atlanta, GA 30378 l cc: Mr. Richard Geiger Director - Insurance and Audits ; Genuine Parts Company X'"--, 2999 Circle 75 Parkway MW 'K - Atlanta, GA 30339 1 cc: Mr. Edward R. Holben Loss Control Consultant Alexander & Alexander, Inc. 3565 Piedmont Road NE Atlanta, GA 30363 ; l cc: Mr. Jerry Jordan The Travelers Companies Loss Prevention 6 Engineering 211 Perimeter Center Parkway Atlanta, GA 30346 1 cc: Ms. Lisa Beegle The Travelers Companies Loss Prevention & Engineering 3110 Fairview Park Drive Falls Church,1; VKp`22042-4503 1 cc: Mr. Michael , Manager - Industr5tfai Hygiene & E Services &.Product Safety Unit The Travelers Companies..................- Loss Prevention & Engineering One Tower Square - 248~CP Hartford, CT 06183-4070 . 1 cc: File - David W. Classman ; ; NOVO20435 'W TABLE OF CONTERT8 X. Executive Summary A. Introduction B. Purpose ' c. Conclusions II. Findings and Recommendations A. Observations B. Sampling Results C. Sampling Methods D. Recommendations III. Appendix '" . . A. Industrial kjrg-iene Survey Data Sheets B. Laboratory :ini$ys is Reports . , - ' -W NOVO20436 I. Executive Summary A. Introduction Vj . -Uyu!#: This survey was requested as follow up to sampling preformed in October, 1990. That sampling indicated high exposures to asbestos in the Burner and Chopper operations. Additional controls were added to those operations which established the need for a reevaluation of the employee exposure to asbestos. I conducted sampling in the Bame areas as my previous survey. This is to permit a comparison of the results as a means of measuring the effects of the controls put in place to affect the employees exposure to asbestos. B. Purpose The purpose of the sampling was to determine the employee exposure to asbestos. By comparing these results to previous results, the effectiveness of the controls, put in place since the previous sampling, can be evaluated. C. Conclusions The personal air sampling indicated employees in the Disk Brake Riveting, Midas Belt, Clutch Disk Drilling, and Burner operations are exposed to fibers in excess of 50% of the Action level of o.l fibers per cubic centimeter, of air. The levels in the Midas Belt, Disk Brake Riveting, and Clutch Disk Drilling were higher than the previous sampling. ' -* The controls put in 'pla'ce in the Chopper and Burner areas have lowered the exposure in/' those areas. However, the Burner area needs additional controls to furthar reduce employee exposure to asbestos. - Until controls are in place throughout the facility, which will ensure that the employee exposure to asbestos levels are acceptable, a formal Asbestos Exposure Control Program should be implemented in accordance with osijfA 1910.-1001.-............. .......................... V Page l 'll ) .CTCC NOVO20437 II . Findings and Recommendations A. Observations Engineering controls bad been added to the burner room since my previous survey. An enclosed exhaust ventilation system was added to the sorting belt. The burning area va6 isolated from the rest of the room, vbere the operator spends mo6t of his time. This contributed to the reduction in exposure to the operator in this area. . An operational change vas^made in the chopper area to reduce the exposure there. The ''parts dumping operation was changed to reduce the generation ofodust in the employee breathing area. B. Sampling Results The personal air sampling for airborne asbestos fibers indicate exposures above 50% of the Action Level for the Disk Brake Riveting, Midas Belt, Clutch Disk: Drilling, and Burner operation areas. The results are summarized below and detailed in the Appendix. Employee R. Helmick Operation Burner Operator 8-Hr. TWA LgifeaKS/ssI 0.085 J. Bechtol Midas Belt Operator 0.085 A. Appel Clutch Disk Driller 0.074 R. McMullen Disk Brake Riveter 0.067 R. Unger Chopper Operator LT 0.034 C. Sampling Methods ......--......................- .. . yfh i3s.. v. : The air sampling was; performed-during normal working procedures., and conditions. Theisampling was performed to determine personal exposure to airborne aisbestos fibers in each area. The sampling equipment consisted of battery powered air sampling pumps, which draw air through a sampling media at a predetermined flow rate. The flow rate was monitored by means of a rotometer, and calibrated prior to use by a primary mass flow meter. The collection media for asbestos fibers is a 25mm Millipore filter. For details of the equipment and other pertinent data, refer to the "Industrial Hygiene Data Sheets" found in the Appendix. , Page 2 ..-`J NOVO20438 :: M. peife - ' ..a .i'-hS>;:. .. * " u',- ... 1 ' V 1 ' ' The samples were sealed and sent: to The Travelers Engineering Lab in Hartford, Connecticut, for analysis. The analytical methods used are indicated on the "Laboratory.. Analysis Reports* found in the Appendix. The standard for asbestos haS.' been established by the Occupational Safety and Health,. ^Administration (OSHA) under section 1910.1001. ................'' '' ' d. Eggaanendaticinfi . IH 88-2 Asbestos Exposure control Program IMPORTANT (Originally submitted 11/4/88) A formal Asbestos Exposure Control Program should be developed and implemented in accordance with OSHA 1910.1001. This program should address the following provisions: 1. Feasible engineering controls and/or .work practices should be developed and implemented to reduce and maintain employee exposure at or below the permissible exposure limit. Engineering controls include isolation, local exhaust;v:;yentilation, process enclosures, dust collection systems, etc. Work practice controls incitf^rfwet methods, prohibiting the use of compressed air for cleaning activities, etc. - Job rotation is not an acceptable means of employee exposure control. 2. Personal protective 'equipment must be provided and used by employees 'until engineering controls or work practiceCjjcontroIs can be effectively implemented. Personal protective equipment required should include: a. Approved, cartridge-type respirators should .. be provided for and .used _ Jjy._ employees. Also, a formal Respiratory- Protection--' Program in accordance with OSHA 1910.134 should be implemented immediately. b. Special clothing including coveralls, head coverings, gloves, and foot coverings should be provided and used by employees immediately. JlY >i.'I'ecillfSi .-.-Page 3 (is V* NOVO20439 c. Warning signs should be provided and displayed in each area where airborne asbestos fiber concentrations are in excess of the permissible exposure limit. d. Affected employees should be notifies in writing regarding the sampling results . within fifteen working days after the v'y;receipt of these sampling results. This '-written notification should contain corrective action being taken by the employer to reduce employee exposure to at or below the permissible exposure limit wherever sampling results indicate that the permissible exposure limit has been exceeded. . ; . , e. A Medical Surveillance Program should be implemented for all employees who are or will be exposed to airborne concentrations of asbestos fibers at or above the Action Level. Before an employee is assigned to an occupation or exposed to airborne concentrations of asbestos, a preplacement medical examination should be provided, this examination should include, at a minimum, a medical and work history, a complete physical examination of all system with emphasis on the respiratory system, cardiovascular system, and digestive track, completion of roentgenogram, pulmonary function tests to include forced vital capacity and forced expiratory volume at one second, and any additional tests deemed appropriate .by the examining physician. Eqllow-up. medical examination should be {jirsy^ded.,,on an annual basis. f. Clean change roogs with, .shower .facilities and isolated lockers should be provided for employees who work in.area? where airborne asbestos fibers /are present at or above the permissible exposure limit. Also, laundering r,. service for contaminated clothing should, be made available to all employees " who , work in these regulated areas. Page 4 NOVO20440 g. A Training Program for all employees who are exposed to airborne concentrations of asbestos at otl :above the Action Level should be disyfeloped and implemented. This Training Prdgram should include provisions for discussing the health effects associated with asbestos exposure, the relationship between smoking and exposure to asbestos, the quantity and location of asbestos, the specific nature of operations which could result in exposure to asbestos, engineering controls and work practices associated with employees job assignment, proper use of personal protective equipment, the Medical Surveillance Program, the provisions of OSHA 1910.1001. This Training Program should be repeated annually. Records should be maintained on file to document all training sessions. g. Resampling to evaluate employee exposure to asbestos should be conducted at least - semi-annual ly. Also, resampling is / "adjusted, : to ensure that any engineering controls implemented are effective in reducing employee exposure to asbestos. These are minimum requirements of the OSHA Asbestos Standard. To ensure compliance with this legal standard, a review of OSHA,Standard 1910.1001 should be conducted. A copy of * this standard was provided with a previous report^;from the sampling performed February 28, 1989. J- >a>.rjtss .i ! Page S / $ -k 'i *i>-j NOVO20441