Document 7O1gB3QEokLYDnME1R67a6paa
PLAINTIFFS EXHIBIT
sum Association
GP-249
201 North Welli Street, Chicago, niinole 60600 (312) 72G-5675
' July 6, 1973
TO ALL MEMBERS OF THE TECHNICAL COMMITTEE
Re: Asbestos In Joint Treatment Compound
Gentlemen;
The Board of Directors of the Association approved an in vestigation of the problem of hazards resulting from asbestos re leased In sanding and mixing joint compound. As a result, a meeting was held In Washington, 0. C. with representatives of 0SHA, in which they encouraged the Association to pursue a testing and monitoring program to determine the extent of hazards occuring in the use of joint compound as well as other effects of gypsum dust.
To date. Directors have responded to my report of the OSHA meeting dated July 11, 1973, with support and concurrence that the Association undertake a program to assess asbestos hazards in the use of joint compound.
Therefore, it is requested that available data be sent to me, for collection and consolidation, of investigations* of the asbestos problem undertaken within the member companies. Also, it Is requested that each company nominate a candidate to serve on an Association sub committee to appraise the data, analyze the problem, and develop a monitoring program for presentation to OSHA that would reflect the consensus position of the Association's membership. The candidate proposed should have good knowledge of appropriate testing, screening, field application procedures, and possibly OSHA and NI0SH requirements. A four man subcommittee would seem practical. It Is recommended that this subcommittee meet in August to begin the work.
Please give this your early consideration.
Yours very truly,'
GYPSUM ASSOCIATION
HBC:mj
cc: Board of Directors Chairman of all Committees
H. B. Carlsen, Secretary Technical Committee
ir
Citation No 1. 2. 3.
PROPOSED PENALTY
Proposed Penalty $800.00
` 800.00 800.00
Item No.
1. 2.
3.
4.
5.
6.
7.
OTHER VIOLATIONS Proposed Penalty
$ 90.00
90.00
None
Hone
None
90.00
90.00
Total for All Alleged Violations $2760.00
CITATION FOR SERIOUS VIOLATION
Standard or Regulation Allegedly Violated
Description of Alleged Violation
Date on Which Alleged Violation Must be Corrected
29 CFR 1910.93a (b) Page 22142
Citation No. 1
Failure of the employer to maintain employee exposure to airborne con centrations of asbestos fibers be low acceptable levels:
MULTI-STEP ABATEMENT
1) Concentrations below 5 fibers,
longer than 5 microns, per CC,
based on an 8 hour Time
Weighted Average,
'
2) Concentrations, at any time, below 10 fibers, longer than 5 microns, per CC.
29 CFR 1910.93a (d) (2) Page 22143
Citation Mo. 2
Failure of the employer to provide. and for the employees to use, U.S. Bureau of Mines approved respirators to prevent inhalation of airborne asbestos dust fibers (within the dry mixing and packout # area).
MULTI-STEP ABATEMENT
29 CFR 1910.93a (d) (2) (1v) Page 22143
Citation No. 3
Failure of employer to establish a respiratory program throughout the dry mixing area in accordance with the American National Standard Practice for Respiratory Protection Z88.2-1969, for employees who are exposed to excessive asbestos dust
concentrations.
MULTI-STEP ABATEMENT
CITATION
Item Number
Standard or Regulation
Allegedly Violated
1. 29 CFR 1910.93a (d) (3) Page 22143
2. 29 CFR 1910.93a
(d) (4) Page 22143
3. 29 CFR 1910.93a
(f) (2) (ID
Page 22143
4. 29 CFR 1910.93a
(9) 0) 0)
Page 22143
Description of Alleged Violation
Failure of the employer to provide and require use of special clothing, such as coveralls or similar whole body coverings, gloves, and foot coverings to prevent skin contact with asbestos fibers, of employees within the dry mix and packout area.
Failure of the employer to provide change rooms, two separate clothes lockers for work and street clothes, and the laundering and handling of work cothes for all employees exposed to airborne concentrations of asbestos fibers in excess of prescribed limits, within the joint compound mixing and packout area.
Failure of the employer to establish a personal monitoring program at intervals not greater than 6 months within the joint compound mixing and packout areas where asbestos exposure may reason ably be foreseen to exceed prescribed limits.
Failure of employer to post "Caution" signs at all approaches to the joint compound mixing and packout area where airborne concentra tions of asbestos fibers may be in excess of prescribed limits.
Date on Which Alleged Violation Must Be Corrected Multi-Step Abatement
Multi-Step Abatement
Multi-Step Abatement
Multi-Step Abatement
If
-2 -
5. 29 CFR 1910.93a Failure of the employer to
Multi-Step Abatement
(9) (2) (1)
affix a "Caution" label to all
Page 22144
raw materials, mixtures, scrap,
waste, debris and other products
containing asbestos fiber to
prevent exposure to concentra
tions above prescribed limits
during any reasonably foreseeable
use.
6. 29 CFR 1910.93a Failure of the employer to
Multi-Step Abatement
(h) (1) Page
maintain all external surfaces
22144
within the joint compound, dry.
mixing and packout area, free
of accumulations of asbestos
.
fibers (dry sweeping is to be
discouraged, uti1ize vacuum
sweeping methods).
7. 29 CFR 1910.93a Failure of the employer to
Multi-Step Abatement
(h) (2) Page
collect and dispose of all
22144
asbestos waste, scrap, debris,
bags, containers, contaminated
clothing in sealed Impermeable
bags to prevent any forseeable
#
airborne concentrations of
asbestos fibers above the allow
able limits.
1r
MULTI-STEP ABATEMENT
Immediate Temporary Administrative Controls
Initiate immediate temporary administrative controls to prevent employee exposure to excessive asbestos dust concentrations by July 1, 1973. A Compliance Officer will determine if these temporary controls are preventing employee exposure*
(1) Provide U* S* Bureau of Mines approved respirators for all
employees working within the joint compound dry mixing and
pack out areas of the main plant* Continue the use of
'
respirators until the installation of permanent engineering
controls*
.
.
(2) Establish a complete respirator program in accordance with the provisions of the American National Standard Practices for Respiratory Protection Z88*2-1969.
(3) Establish a program for maintaining the joint compound dry mixing and pack out areas of the main plant in a clean* orderly and sanitary condition to prevent asbestos dust contamination of the air* This program will include utilizing sealed impermeable bags for the storage of waste asbestos*
(4) Provide employees with protective clothing that can be maintained in a sanitary and reliable condition from becoming contaminated with asbestos* In addition, provide employees with individual clothes lockers to prevent their personal clothing from becoming contaminated with asbestos dust*
(5) Establish a personal monitoring program to determine* at six month intervals* the concentrations of asbestos dust.
(6) Post asbestos "Caution" signs at all approaches to the work area to prevent unprotected persons from entering*
(7) Affix asbestos "Caution" labels on all raw materials, mixtures, scrap, waste, debris and other products containing asbestos to prevent exposure to asbestos dust*
Permanent Engineering and Administrative Controls
(1) By July 27, 1973, submit a plan for approval to the U* $ Department of Labor* Occupational Safety and Health Adminis-
showing
a timetable for the installation ot engineering controls to
prevent employee exposure to asbestos dust concentrations above
allowable limits*
.
(2) Incorporate items (3) through (7) (listed as temporary adminis trative controls in Psrt I) as permanent administrative controls to prevent employee asbestos dust exposure*