Document 7RGYbk0Z16kargrNVzgbBap4V

FILE NAME: Mobil (MOB) DATE: 1973 Apr DOC#: MOB001 DOCUMENT DESCRIPTION: Government Inspection Results - NIOSH Health Hazard Report U.S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH Section 20(a)(6) o f the Occupational Safety and Health Act o f 1970, 29 U.S.C. 669(a)(6), authorizes the Secretary of H ealth, Education, and Welfare, following a w ritten request by any employer o r authorized representative of employees to determine whether any substance normally found in the place of employment has p o te n tia lly toxic effects in such concentrations as used or found. The National In s titu te fo r Occupational Safety and Health (NIOSH) received such a request from an authorized representative o f employees regarding exposures to asbestos dust and to hot environments relevant to the company's requirement fo r In su lato rs' wearing of special clothing (paper coveralls) while working with asbestos a t the Mobil Oil Corporations's Refinery in Augusta, Kansas. On December 11*13, 1972, two (2) NIOSH investigators conducted an observational and environmental survey o f inside operations Involving the cutting o f m aterial containing asbestos and the mixing o f "Mud* o r "Super 88"; and outside operations involving the in s ta llin g o f insulation and "Mud"; and very lim ited stripping of old in su la tio n . Thirty (30) personal and general area samples for airborne concentrations o f asbestos were collected during these operations. None o f the asbestos dust lev els measured exceeded the present U.S. Department of Labor Standard o f 5.0 fibers/cc (8-hour time-weighted average--TWA) o r the 2.0 fibers/cc-8-hour TWA lim it which will be in e ff e c t In 1976; and 10.0 fib e rs/c c (ceilin g concentration). The unit measurement for the asbestos standard is the number o f fibers greater than 5 micrometers in length per cubic centimeter (cc) o f a ir as promulated by the U.S. Department of Labor (Federal R egister, Volume 37,1910.93a, June 7, 1972). For inside operations in the in su lato rs' tool building the asbestos counts o f individual personal samples varied from 0.6 to 3.3 fib e rs /c c , and the asbestos counts o f general area samples varied from 0.1 to 0 .9 fib e rs/c c . For outside operations the asbestos counts of personal samples varied from 0.2 to 1.5 fib e rs/c c and general area samples varied from 0.0 to 0.9 fib e rs/c c . The estimated 8-hour time-weighted average fo r the workers ranged from 0.3 to 0.6 fib ers/cc. D E F E N D A N T 'S * EXHIBIT Page 2 - H ealth Hazard E v alu atio n R eport 72-91 Interviews with the four (4) in s u la to rs did not e l i c i t any symptoms which could be a ttrib u te d to overexposure of employees to asbestos, and medical records did no t show any employee having a condition which could be a ttrib u te d to exposure o f employees to asbestos. The in su la to rs did in d ic a te previous symptoms ( e .g ., exhaustion, e t c .) which could be a ttrib u te d to heat s t r e s s . There have been two (2) cases o f overexposure to heat or heat p ro s tra tio n in September 1972. I t is f e l t th a t th e wearing o f paper c o v eralls over th e ir personal clothes does c o n trib u te somewhat to the problem of exposure of th e four (4) employees to hot environments. I t is our determ ination th a t asbestos is^ not toxic a t th e concentrations used and found in the in s u la to rs 1 forking o p eratio n . This is based upon the environmental concentrations o f asb esto s obtained a t th e time o f th is survey and upon th e documentation in th e li te r a tu r e supporting the standard. No sp e c ific evaluation was made concerning th e exposure of employees to hot environments and the concern o f special clothing (paper c o v e ra lls) co n trib u tin g to heat problems ( e . g . , heat p ro stra tio n , e t c . ) as the survey was conducted in the w in te r with no operations involving any sig n ific a n t exposure o f employees to hot environments. In th is regard, i t is determined th at the wearing of special clothing such as semi porous paper coveralls over personal clothing does co n trib u te to the p o te n tia l heat stre ss problem, and does not meet the in te n t o f the ru le s and regulations concerning the wearing o f "Special Clothing" as required when environmental le v e ls o f asbestos exceed the "Ceiling Value" o f 10 fib e rs /c c . General recoronendations c o n siste n t with the ru le s and reg u latio n s s e t fo rth by th e U.S. Department o f Labor and good In d u stria l hygiene p ra c tic e s have been made to management to obviate any p o tential hazards from the exposure of th e fo u r (4) employees to asbestos and "hot environments". Copies o f th e Sunraary Determination as well as the Full Report of th e evaluation are av ailab le upon req u est from the Hazard Evaluation Services Branch, NIOSH, 508 U.S. Post O ffice B uilding, 5th and Walnut S tre e ts , C in cin n ati, Ohio 45202. Copies o f both have been sen t to : a) Mobil Oil Corporation, Augusta, Kansas b) Authorized R epresentative o f Employees c) U.S. Department o f Labor - Region VII For purposes o f informing the "a ffe c te d employees," the employer w ill promptly "post" the Sunrnary Determination in a prominent p lace(s) near where the fo u r (4) in su la to rs work fo r a period o f 30 calendar days. Page 3 - H ealth Hazard E v alu atio n Report 72-91 I I . INTRODUCTION Section 20(a)(6) of the Occupational Safety and Health Act o f 1970 , 29 O.S.C. 669(a)(6), authorizes the Secretary of Health, Education, and Welfare, following a w ritten request by any employer o r authorized representative o f employees to determine whether any substance normally found in the place o f employment has p o te n tia lly toxic effects in such concentrations as used or found, The National In s titu te fo r Occupational Safety and Health (NIOSH) received such a request from an authorized representative of employees regarding exposure o f insulators to asbestos dust and the wearing of paper coveralls by the four (4) insulators and the special clothing contributing to heat exposure problems ( e .g ., heat prostration) with th e ir exposure to hot environments a t the Mobil Oil Corporation Refinery a t Augusta, Kansas. I I I . BACKGROUND HAZARD INFORMATION A. Standards Asbestos: The Occupational Health Standard promulgated by the U.S. Department o f Labor applicable to the particu lar substance of th is evaluation 1s lis te d below. Permissible exposure to airborne concentrations o f asbestos fibers (Federal Register, Volume 37, sl910.93a, June 7 , 1972copy Included as an appendix to th is report e n title d , "Rules and Regu latio n s") is outlined as follows: (1) Standard Effective July 7, 1972 (2) Standard To Go Into Effect July 1, 1976 (3) Ceiling Concentration Applicable At a ll Times ....5 .0 fibers/cc* ....2 .0 fibers/cc* ...10.0 fibers/cc** * 8-hour time weighted average airborne concentration of asbestos fib ers longer than 5 micrometers in length per cubic centimeter (cc) o f a ir . ** Airborne concentration of Asbestos fib ers longer than 5 micrometers in length per cc o f a i r not to be exceeded a t any time as determined by a minimum sampling time o f 15 minutes. Page 4 - H ealth Hazard E v alu atio n Report 72-91 Hot Environments (Heat Stress): There are no current Federal Standards fo r exposure o f employees to hot environments. However, NIOSH recommendations for such standards are contained In HSM 72-10269 e n title d , "C rite ria for a Reconraended Standard ....O ccupational Exposure to Hot Environments", by NIOSH, Health Services and Mental Health Administration, U.S. Department of Health, Education, and Welfare. A copy o f th is referenced document is enclosed fo r informa tional purposes. In general, healthy ad u lts performing continuous moderate work can easily to le ra te a wet bulb globe temperature o f 79F without developing heat disorders such as heat fa tig u e or p ro stratio n . B. Toxic Effects Toxic M aterials: Asbestos: Prolonged inhalation o f asbestos fibers may re s u lt in the production of a typical pulmonary fib ro s is which may be accompanied by severe respiratory d isab ility . If large quantities of the fib ers are inhaled over an extended period of tim e, c h a ra c te ristic a lly 10 to 20 years, tissue reaction progresses until a generalized diffuse fibrosis (known as asbestosis) becomes evident. This fib ro sis is seen f i r s t in the lower lobes o f the lungs but eventually, i f exposure continues, appears in the other lobes as well. R espiratory insufficiency and cardiac fa ilu re may supervene. A dditionally, there Is Increasing evidence th a t the frequency o f bronchogenic cancer is greater among workers in c e rta in asbestos in d u stries than expected in the general male population as well as more evidence of an Increased ra te of occurrence of mesothelioma o f the pleura o r peritonei. These asbestos associated neoplasms may occur without radiological evidence o f asbestosis which means th a t pre vention of even short-term high level exposures to asbestos may be extremely important. Physical Agents: Hot Environments (Heat Stress): The physical effects o f excessive exposure to environment heat are determined to a large ex ten t by factors oth er than actual temperature. Workload, re s t periods, water and s a lt supplementation, clothing, general physical fitn e ss and acclim atization are a ll extremely important in determining levels a t which e ffe c ts can be expected to become manifest. In g en eral, well adults performing con tinuous moderate work can easily to le ra te a Wet Bulb Globe Temperature of 79F without developing heat d iso rd ers. Heat fatigue is the mildest of the heat disorders and is characterized by decreased a b ility to concentrate, tire d n e ss , and i r r i t a b i l i t y . Heat p ro stratio n (heat collapse, exhaustion, o r syncope) resu lts in weakness, Page 5 - H ealth Hazard E v alu atio n R eport 72-91 dizziness, vertig o , nausea, blurred or din vision and mild muscular cramps which may progress to a l i s t l e s s , apprehensive semi-comatose sta te . In severe cases unconsciousness may re s u lt due to complete circulatory collapse even though the body temperature remains normal. The prognosis is excellent and the condition is usually tra n sie n t. Heat cramps are sudden, severe muscular cramps re su ltin g from excessive physical exertion in high temperatures due to perspiration. This condition occurs mainly among unacclimated individuals performing extremely severe physical labor In very hot environments such as strokers, miners, firemen, e tc . The most severe heat disorder is heat hyperpyrexia (heat stro k e). In th is condition a profound disturbance of the heat-regulating mechanism occurs following prolonged exposure to excessively high temperatures leading to high fever and collapse. Convulsions, coma and death are not infrequent d esp ite prompt medical atten tio n . This heat disorder Is larg ely a problem o f the eld erly non working age population and the sev erity o f the syndrome is usually related to an already compromised physical sta te due to h e a rt, kidney or other underlying diseases. IV. HEALTH HAZARD EVALUATION A. I n titia l V isit - Observational Survey A health hazard evaluation survey of insulation operations a t the Mobil Oil Corporation Refinery Plant was made on December 11-13, 1972, by NIOSH rep resen tativ es, Messrs. Raymond L. Hervln and Raymond Rivera. The functions o f the National In s titu te for Occupational Safety and Health and i t s re la tio n to Section 20(a)(6) of the Occupational Safety and Health Act o f 1970 were explained to Mr. W. M. McMullen, Manager Employee R elations; Mr. S. G ille tte , Chief of Safety; and Dr. 0. J. Stanko, Regional Industrial Hygienist; who a ssisted in the completion of the National Surveillance Network Part I Questionnaire. Mr. Milo McNairy represented the union and employees during th e in itia l walk through survey. Separate e x it interviews were held with a few members of management including Mr. R. S. Grieves, Refinery Manager; and a few members of the union including Mr. Milo McNairy to answer any questions which may have arisen due to our survey. Description of F a c ility , Process, and Conditions of Use: The Mobil Oil Corporation a t Augusta, Kansas employs 287 people o f whom 200 are d ire c tly involved in the production of lig h t petroleum grade fu e ls, asp h a lt, and sim ilar products. The normal day-to-day oper ations u tiliz in g material containing asbestos involve a to tal of four (4) employees who are in su la to rs. These workers wear resp ira to rs and d isposable paper coveralls during operations which may involve airborne asbestos. Other employees (e .g ., laborers) may replace one o f the four Page 6 - H e alth H azard E v a lu a tio n R ep o rt 72-91 (4) in su la tio n craftsmen when they are on v acation, s ic k , o r o th er leav e. There are th ree (3) long-term (5 or more y e a rs) re g u la r in s u la to rs and one (1) interim in s u la to r a t the time o f th e survey. The in su la to rs worked on day s h i f t only and are resp o n sib le fo r the maintenance, r e p a ir , and upkeep o f in su la tio n throughout th e p lan t on a day-to-day b a sis. Major operations involving th e re p a ir and/or in s ta lla tio n o f in su la tio n i s accomplished by co n tra c tin g o u t to o th e r companies. One o r a l l o f the four (4) In su la to rs w ill oversee the major insulation operations of the other contractor to assure that the job is adequate. The day-to-day in su latio n operations normally involve one (1) hour being spent each day in the In su la to rs' Tool Building o f approx im ately 15 fe e t by 50 fe e t by 10 fe e t high. H alf o f the bu ild in g is used fo r storage o f new and waste in su la tio n m aterials and the remainder is used fo r work with sh eet metal and asbestos m a te ria l. The c u ttin g (hand tools only) of preformed asbestos m aterial (thermobestos-containing le ss than ten (10) percent asb esto s) is accomplished on a 4 fe e t by 4 f e e t ta b le with 3 inch s lo t v e n tila tio n on the middle, back, and sid es o f th e ta b le . Mixing o f "Super 88" and/or "Mud" is accomplished in a hood around 3 f e e t by 3 fe e t by 4 f e e t with the fro n t open fo r mixing o p eratio n s. The s l o t v e n tila tio n provides fo r an average v e lo c ity o f 700 fe e t per minute; and th e hood an average v elo c ity of 300 f e e t p e r minute a t 2 inches from the face. There i s a lso a larg e vacuum system (55-gallon b arrel with cyclone, elephant tru c k , e t c . ) used fo r cleanup o p e ra tio n s. All th ree (3) operations (c u ttin g and forming, mixing o f "Mud", and cleanup) are exhausted through a Roto-clone Type W (American A ir F i l t e r Company, In c .) A ir Exhauster which provides fo r a water spray wash o f the a i r p rio r to discharge. The w ater containing the asbestos is discharged in to a French Drain with a 10 f e e t radius and 10 fe e t deep. The company has re c e n tly in s ta lle d the v e n tila tio n system to be 1n conformance with the ru le s and regu latio n s promulgated by the U.S. Department o f Labor fo r use o f asbestos in industry which reconmends engineering o u t, wherever f e a s ib le , any problems where airb o rn e asbestos may be a problem. The v e n tila tio n in th e tool shed fo r c u ttin g , mixing, and cleanup appears adequate fo r the operations normally conducted 1n th e tool shed as observed during th is survey. Outdoor operations involving th e in su la to rs c o n sists prim arily o f in s ta llin g new in su la tio n and tak in g o ff old in s u la tio n . Operations c o n sist o f placing the preformed (as bought by th e company, but cut to length i f necessary by the in s u la to r) sem i-circu lar halves around a pipe and w iring the halves to g eth er fo r a tig h t f i t . The re v e rse operation is Page 7 - H ealth Hazard E v a lu a tio n Report 72-91 accomplished for taking o ff o f old in su la tio n . These two (2) operations were predominant during the survey and d id not appear to generate much dust. However, "Hud" o r "Super 88" is used fo r insulation around elbows, and bends in the piping. This is a wet mixture which is applied by hand around the bend in the piping and allowed to dry. There should not be much o f an airborne problem as i t is in a wet form. However, in removing old , dried "Hud" (which contains asbestos and is not the newer "Super 88") from the pipe, the insulators nay have to use tools ( e .g ., saw, hammer, e tc .) which would present a problem concerning airborne asbestos. On two (2) occasions, the stripping o f old "Hud" containing asbestos was observed and only la ste d for approximately five (5)~nrinutes on each occasion. Cleanup operations consisted o f placing the old asbestos in p la s tic bags and sealed with storage in .the tool shed u n til disposal in the c ity o r conmercial waste dump by b u ria l. In observing the operations discussed above, i t is noted th a t signs or lab els were not conspicuously in use during various operations and although may not be necessary, may be appropriate fo r some operations to be in compliance with the regulations. The company has engineered out certa in problem areas ( e .g ., cutting in tool shed, e tc .) and has gone to products which contain less asbestos than previous insulation products containing asbestos, fo r instance, the main insulation m aterial used is called "Thermobestos." I t contains up to ten (10) percent asbestos; the new "Super 88" or "Hud" contains no asbestos. In addition, th e re are w ritten instructions to the four (4) In su lato rs on the wearing o f cover a lls and approved re sp ira to rs during operations where asbestos may be airborne such as strip p in g operations. Hence, i t is f e l t th a t the company has taken appropriate steps to meet the in te n t of the rules and regulations as promulgated by the U.S. Department o f Labor concerning asb esto s, however, may not be in complete compliance with a l l o f the regulations as contained in the appendix to th is rep o rt. B. Environmental Evaluation 1. Procedure and Hethods On December 12-13, 1972, an environmental survey was conducted to determine the environmental exposure o f fo u r (4) employees (in su la to rs) to airborne asbestos during outside and in sid e operations involving in su latin g m aterials containing asbestos. The primary operations noted at the time of the survey were the outside in sta lla tio n of in su la tio n , and secondary or lim ited operations involving the inside cu ttin g (tool shed) o f insulation and mixing of "Mud". Page 8 - H ealth Hazard E valu atio n Report 72-91 A to ta l of 24 personal a ir samples and 6 general area samples were obtained and analyzed fo r asbestos during a ll hours of 2 day s h i f ts . Personal and general area samples were collected with the same type of instruments and f i l t e r . MSA Model G battery-operated vacuum pumps were used to draw a ir through tygon tubing attached to an open-faced f i l t e r holder containing 37-millimeter M lllipore type AA f i lt e r s a t a ra te of 2 l i t e r s per minute. The f i l t e r holder was attached to the employees' co lla rs fo r the personal a ir samples, and the general area samples were collected In sp ec ific locations in th e working environment. Sampling times ranged from 2.5 to 219 minutes. All o f the 3a a ir samples were analyzed by the Laboratory Services, NIOSH, S alt Lake C ity, Utah using the standard phase co n trast illum ination microscopy techniques. 2. Survey Results Twenty-four (24) personal and s ix (6) general area samples were obtained during operations involving four (4) insulators while handling asbestos containing m aterials. None o f th e asbestos dust le v e ls a t a ll operations exceeded the present U.S. Department of Labor's standard of 5.0 fib ers/cc (8-hour time-weighted average) and 10.0 ftb e rs /c c (c e ilin g concentration). The u n it of measurement fo r the asbestos standard is the number of fib ers greater than 5 micrometers in length per cubic centimeter (cc) o f a i r as promulgated by th e U.S. Department o f Labor (Federal R egister, Volume 37, 51910.93a, June 7, 1972). The asbestos counts o f short-term individual personal samples varied from 0 .6 to 3.3 fib ers/cc with asbestos counts o f general area samples varying from 0.1 to 0.9 fib e rs/c c fo r inside operations in the in s u la to rs ' tool building. The asbestos counts of sho rt-term individual personal samples varied from 0.2 to 1.5 fib e rs/c c , with general area samples varying from 0.0 to 0.9 fibers/cc for outside operations. I t is noted th a t the present Federal asbestos standard of 5 .0 fib e rs/c c w ill be lowered to 2.0 fibers/cc fo r an 8-hour time-weighted average in 1976. The estimated 8-hour time-weighted average for December 13, 1972, which one may obtain from the re su lts of th is survey, ranged from 0.3 to 0.6 f ib e rs /c c . The Regional Industrial Hygienist fo r Mobil Oil Company has performed pre vious environmental studies of these operations and his re s u lts are e sse n tia lly in agreement with those obtained during th is survey. Also, the Regional Ind u strial Hygienist (Mobil) obtained personal and general a ir samples during th is survey. The r e s u lts o f the a ir samples obtained and analyzed by NIOSH are presented in Tables I , I I , and I I I , o f th is report. An evaluation o f the exposure o f the four (4) in su lato rs to "hot environments" was not accomplished during th is survey as the survey was conducted in the w inter with no operations involving any s ig n ific a n t exposure of employees to hot environments. . Page 9 - H e alth Hazard E v a lu a tio n R eport 72-91 C. Medical Evaluation The Medical Unit consists o f a well-equipped laboratory d o cto r's office* x-ray room, treatment room, f i r s t- a id room, and a reception area fo r p atie n ts. The Medical S ta ff consists of a fu ll-tim e registered nurse and two (2) part-tim e (average 9 hours to ta l per week) physicians who are on call on a 24-hour basis. Review o f OSHA Form 102 and discussion with some of the Medical S ta ff, Regional Industrial Hygienist, and the Employee Relations Manager of Mobil Oil Company did not show any respiratory conditions which could be attrib u te d to the exposure o f employees to asbestos. They were aware o f the medical examination and other requirements in the ru les and regulations (refer to appendix to th is report) as promulgated by the U.S. Department of labor. The NIOSH employees questioned a ll four (4) Insulators concerning th e ir experiences with asbestos material with p a rtic u la r emphasis on outward signs and symptoms associated with lung ailments. None o f the workers claimed th a t they were suffering any adverse e ffe c ts from working with asbestos. One employee did express the fact th a t he suffered from shortness o f b reath, but he appeared to be a heavy smoker. Further questioning of the four (4 ) in su lato rs revealed th a t they had heard o f a to ta l o f three (3) employees and in p a r t i cular one case, in which asbestos was suspected as the causitive agent for retirem ent or d is a b ility but i t was rumor only and there was no agreement with the in su lato rs th a t these were 1n fact actual cases. The names o f the three (3) were given to the NIOSH investigators and fu rth e r questioning o f the Medical S taff and others revealed th a t the three (3) cases of d is a b ility or retirement did not relate to the exposure o f the three (3) employees to asbestos. The insulators were informed of th is fa c t and were s a tisfie d th a t i t was a valid conclusion. No fu rth er medical evaluation i s f e l t necessary due to the lack o f apparent signs and symptoms associated with lung ailm ents. The company does have pre-employment and periodic physical examination program which Includes chest x-rays. Medical records show th a t two (2) employees suffered from heat p ro stratio n in September 1972. Both were in su la to rs and were apparently working in a hot environment as well as the day being hot and humid. Apparently the men did not get su fficien t r e l i e f ( e .g ., cool a rea, workload, r e s t, e tc .) from normal operations and resulted 1n two (2) separate cases of in sulators with heat p ro stra tio n . In this regard, a copy o f "C riteria fo r a Recommended S tandard... .Occupational Exposure to Hot Environments" is enclosed for use as a guideline for exposure to hot environments. In discussing th is matter with the four (4) insulators Page 10 - H ealth Hazard E v a lu a tio n R eport 72-91 i t was f e l t th a t working in a hot environment such as removing o r in s ta llin g in su latio n around a hot v essel, pipe, o r tank on hot and humid days during the sumner can be exhausting but normally has not presented a problem as serious as the two (2) cases of heat p ro s tra tio n which occurred in September 1972. I t is noted th a t th e use o f the paper s u its in asbestos work was in s titu te d by the company sometime in the suovner o f 1972 and does co n trib u te to po ten tial heat pro stratio n problems. The NIOSH in v e s ti gators examined the paper s u i t which was i n i t i a l l y used by the in su la to rs and found them to be a very h a rd -fin ish e d , almost w ater tig h t non-porous type paper s u i t o r coveralls which are worn over th e employees' personal clo th es. I t is f e lt th a t the p a rtic u la r s u i t worn over personal clothes does contribute to a h eat s tre s s problem as i t would in su late the body from the free exchange o f h e a t via evapor a tio n o f sweat and o th e r body functions. Since the incidents o f h e a t p ro stra tio n in September, th e company has purchased and is now u sin g a d iffe re n t and more water-porous paper s u it which Is s t i l l worn over the employees' c lo th es. The p ractice o f wearing a complete s e t o f clothes plus an o u ter paper coverall even though a porous co v erall would s t i l l contribute to , although to a le s s e r ex te n t than non-porous s u i ts , to a heat s tre s s problem. Of p a rtic u la r in t e r e s t to th e NIOSH in v e stig a to rs was th e fa c t th a t the paper s u its o f a ll four (4) in su la to rs were serio u sly ripped a t various places ( e . g . , elbows, cro tch , e tc .) and are su scep tib le to holes due to normal work, h e a t o r chemical action during th e environmental survey. I t Is noted th a t the reason fo r special c lo th in g such as c o v e ra lls , head and fo o t coverings as required by th e ru les and reg u latio n s (r e f e r to appendix) o f the U.S. Department o f Labor is to preclude an employee's personal clothing from being contaminated with asbestos and the subsequent contamination in the heme with exposure o f th e family and re-exposure o f the employee. The use o f paper clothing which 1s e a s ily ripped o r to m does not meet th e in te n t o f the "Special Clothing" sectio n o f the ru le s and regulations contained in the appendix. A more s u ita b le a lte rn a te would be th e complete change and sep aratio n o f the employee's stre e t clothes from h is work clothes and the wearing o f cloth coveralls only without the outside s t r e e t clothes under the co v e ra lls. This would meet the in te n t o f th e regulations where such special c lo th in g is required such as when environmental lev e ls exceed th e "C eiling" concentration o f 10 fib e rs /c c . i t should be emphasized th a t In no case were any individual medical f i le s requested or examined by the NIOSH in v e stig a to rs during th e medical ev aluation. OSKA Form 102 was reviewed and only general medical q uestions were asked during the medical evaluation and questions were lim ite d to information concerning asbestos and hot environments. P a g e 11 - H e a lth H azard E v a lu a tio n R e p o rt 72-91 D. Conclusions It is our determination that asbestos is not potentially toxic a t the concentrations used or found a t the time o f th is evaluation Tn tRe insulators working operations. This is based upon the re s u lts of the environmental survey being lower than current and future standards fo r asbestos a t the time o f the survey and the lack o f symptomatology which could be a ttrib u te d to excessive exposures to asbestos. However, i t is noted th a t concentrations may well be sig n ifican tly d iffe re n t on other occasions such a major strip p in g and insulation operations which were not observed a t the time o f the survey. Mo environmental measurements were made concerning employees1 exposure to heat s tre s s , although two (2) cases o f apparent heat p ro stratio n did occur in September 1972 and is fu rth e r discussed in Section III.C ., of th is report. I t is f e l t th a t the management and the Regional In d u strial Hygienist a t the Mobil Oil Corporation are well aware o f heat and safety requirements and have taken several step s, such as engineering out potential problems, and have, with few exceptions, met the in te n t o f the Federal regulations and c r i te r ia . The company's e ffo rts in the area of safety and in d u strial hygiene are good and the use o f approved re sp ira to rs and special clothing is encouraged concerning operations involving airborne asbestos. I t is further noted th at the company has recently used in su la tin g material with l i t t l e (e .g ., thermobestos less than 1035) asbestos and where possible material containing no asbestos. The cooperation o f both management and union during the survey is most appreciated by the NIOSH investigators. V. RECOMMENDATIONS In view o f th e findings discussed above and in o th er sections of th is rep o rt, i t i s recommended th a t the provisions o f th e rules and regulations (appendix) as contained in the Federal R egister (Volume 37, 51910.93a, October 18, 1972); and in the NIOSH publication e n title d , "C riteria fo r a Recommended Standard___Occupational Exposure to Hot Environments'*, should be c arefu lly followed by management. I t is fu rther recommended th a t cloth co v eralls be provided the employees in order to obviate the necessity of wearing two (2) se ts o f ou ter clothing as c u rren tly required by management; and the fa c t th a t cloth coveralls are normally more porous than paper co v eralls. The laundering of such contaminated clothes could be readily accomplished in-house at the tool shed o r other available f a c i li ti e s by the purchase o f a Patje 12 - H e a lth Hazard E v a lu a tio n R ep o rt 72-91 household washer and dryer i f not now av ailab le. The requirements fo r the use of outside laundering services are contained in the appendix i f an a lte rn a te method is needed. The furnishing of cloth coveralls would also obviate the p otential contamination o f the employees' clothing as required by the rules and regulations contained in the appendix. The cost of cloth coveralls and in* house laundry o f about 20 coverall s/week o r 4 coveralls/day should be around or less than the cost o f using 4 paper coveralls/day which are disposed as waste each day. The continued wearing o f approved re sp ira to ry protection during operations where asbestos may be airborne is also encouraged and may be required under P art (c)(2 )(i1 1 ) e n title d , "Spraying, demolition, or removal" of Section 1910.93a Asbestos, as contained In the appendix to th is rep o rt. APPENDIX HEALTH HAZARD EVALUATION 72-91 MOBILE OIL CORPORATION AU6USTA. KANSAS TABLE I I I ESTIMATED 8-HOUR TIME-WEIGHTED AVERAGE OF INDIVIDUAL AIR SAMPLE RESULTS Occupation In s u la to r No. 1 In s u la to r No. 2 In s u la to r No. 3 In s u la to r No. 4 Asbestos Count* 0.3 -0.4 0.4 0.6 Units of Measurement: fib e rs /c c --the number o f fib e rs longer than 5 micrometers in length per cubic centim eter (cc) of a ir TABLE I I OUTDOORS INSULATION OPERATIONS Personal A ir Sample Results (unless otherwise noted as. general area samples) of In su lato rs a t Mobile Oil Corporation P lan t during the tearing down o f old and in s ta lla tio n of new insulation - Samples collected December 12-13, 1972. L iters Occupation & Any Sample No. Sampled Other Operations Asbestos Count* 36 46 Insulator No. 1 0.9 29 184 Insulator No. 1 0.3 9 232 In su lato r No. 1 0.2 17 336 In su lato r No. 1 0.3 45 382 Insulator No. 2 0.6 41 78 In su lato r No. 2 (use of Mud or Super 48) 1.5 3 170 In sulator No. 2 0.9 14 228 Insulator No. 2 0.3 23 416 Insulator No. 2 0.5 50 398 In su lato r No. 3 0.5 37 80 Insulator No. 3 (use o f Mud or Super 48) 0.3 31 172 In su lato r No. 3 1.1 26 224 In su lato r No. 3 0.2 20 408 In sulator No. 3 0.2 35 186 In su lato r No. 4 0.9 10 232 In sulator No. 4 0.7 25 438 In sulator No. 4 0.6 38 11 General Area during Stripping Operations 0.0 42 5 General Area during S tripping Operations 0.9 Units of Measurement: fib e rs/c c --the number of fib ers longer than 5 micrometers in length per cubic centimeter (cc) of a ir TABLE I INDOOR CUTTING OPERATIONS Personal A ir Sample Results (unless otherwise noted) of Insu lato rs a t Nobile Oil Corporation Plant while c u ttin g thermobestos m aterial o r mixing Mud o r Super 48 - Breathing zone samples collected on December 12-13, 1972. nple No. L ite rs Occupation & Any Sampled Other Operations Asbestos Count* 46 12 In su la to r No. 1 3.1 27 136 In su lato r No. 1 1.1 47 8 In su lato r No. 2 2.0 48 14 In su la to r No. 3 3.3 32 12 In su la to r No. 4 2.2 49 46 In su la to r No. 4 0.6 28 136 In su la to r No. 4 1.2 33 40 Breathing Zone/General Area above Cutting 0.9 Table during cutting AV 39 24 Same as F il te r No. 33 0.2 30 412 Same as F il te r No. 33 except l i t t l e 0.1 cu ttin g done 5 292 Same as F il te r No. 30 0.1 22 -- Blank .03 F ib e rs/fie ld 44 -- Blank .06 F ib e rs/fie ld Units o f Measurement: fib e rs /c c --the nunber of fib e rs longer than 5 micrometers in length per cubic centim eter (cc) of a ir U1ES AN0 REGULATIONS I1U> Laundering: (a) Laundering of at Intervals greater than 6 montns lor fh> Housekeeping--<l) Cleaving. All asbestos ooniaminated clothing shall be employees whose exposures to asbestos externalsurfaces in any place of employ done so as to prevent the release of ait* may reasonably be foreseen to exceed ment shall be maintained free of accu- borne asbestos libers in excess of the ex* th e esposnre lim its prescribed in para malattons of asbestos fibers if, with their pesure lim its prescribed in paragraph (b> graph (b> of this section. dispersion, there would be an excessive of this section. (1) Employee observation, of monitor concentration. (M Any employer who glees asbestos- ing. Affected employees, or their rep (2> Waste disposal Asbestos waste, contaminated clothing to another person resentatives. shall be given a reasonable scrap, debris, bags, containers, equip for laundering shall inform such person opportunity to observe any monitoring ment. and eSbestos-eontandaated cloth of the requirement in <a> of this subdi required by this paragraph and shall have ing. consigned for disposal, which may vision to effectively prevent the release access to the records thereof. produce in any reasonably foreseeable of airborne asbestos fibers in c e ss of the exposure limits prescribed in para if) Caution signs and labels. (1) Cau use; handling; storage, processing, dis posal. or transportation airframe concen tion signs, (i) sotiPngCaution signs graph ib of this section. shall be provided and displayed at each trations of asbestos fibers in excess of the exposure lim its prescribed In paragraph ic Contaminated clothing shall be location where airborne concentrations transported in sealed impermeable bags, o f asbestos fibers may be in excess of the <b> o f this section dial) be collected and or other dosed, impermeable containers, exposure limits prescribed in paragraph disposed of fit sealed impermeable bags; or other dosed. Impermeable containers. and labeled in accordance with para (b) of this section. Signs shall be pasted graph (?) of Urn section. a t such a distance from such a location <i> Recordkeeping--tu Exposure rec <e> M ethod 0/ measurement. All de so that an employee may read the signs ord^ Every employer shall maintain rec ord* o f any personal or environmental terminations of airborne concentrations and take necessary protective steps be or asbestos fibers shall be made by the fore entering the area marked by the monitoring required by this section. R ee- membrane filter method at 400-450 X signs. Signs ahaO be posted a t aO ap oids shall be maintained for a period o f at least 3 years and shall be made avail (magnification) (4 millimeter objective) proaches to areas containing excessive tci&h phase contrast Illumination. concentrations of airborne asbestos tfl Monitoring--(I) Initial determ i able upon request to tb s Assistant Secre tary of labor for Occupational Safety nations. W ithin fiber. 9months of the publi and Health, tho Director of the National cation of this section, every employer (it) Sign specifications.The wIanrnstiintgute for Occupations! Safety and signs required by subdivision (1) of this Health, and to authorized representa- shall cause every place of employment subparagraph shall conform to the re tlres o f either. where asbestos fibers are released to be quirements of 20" x 14" vertical format monitored in such a way as to determine C2> Employeeaccess, very employee whether every employee's exposure to signs specified in 11910.145(d)(4). and to this snixfivision. The signs shall dis and former employee shall have reason able access to any retard required to bo asbestos fibers Is below the lim its pre play the following legend In the lower maintained by subparagraph (1) o f tfcte scribed in paragraph (b) o f this sec panel, with letter sizes and styles of a tion. If the lim its are exceeded, the em visibility at least equal to that specified pcolomyeprliasnhcaellpriomgrmamediiantealyccournddaenrcteakweitha in this subdivision. paragraph, which Indicates the empluyec's own exposure to asbestos fibers. paragraph (c) of this section. (3) Employee noHAcaiion. Any em (2) Personal monitoring-- <i) Sam Upend N otation ployee found to have been exposed at any ples shall be collected from within the AfAHMa___ -- M flora flestt time bo airborne concentrations of u b estoa fibers la exec of the lim its pre breathing sane of the employees, on a e t n i e r scribed m paragraph (b) of this seetfcm membrane filters of 0.8 micrometer po Dust 8 bw4. Bora Bartt. shall be notified in writing of tho expo- rosity mounted In an open-face filter G o th ic or n u e as noon os practicable but not later holder. Samples shall be taken for the Avoid fitwUhtng Do__ fc" Gothic. than 3 days of the finding. The employes shall also be timely notified of the cor determination of the 8-hour tim e- Wear Assigned Protect*? wctghted average airborne concentra Gothic. rective action being taken. tions and of the ceiling concentrations o f t e S e S i k i xa a m K " Gothic. (1) Medicalexaminations--(1) G en- enzL The employershall provide or make asbestw fibers. (U> Sampling frequency and patterns. Unlaw Tow Work Be* qutnsza available at his cost medical examina tions relative to exposure to asbestos re After the Initial determinations required BM thlag Anastas Dost 14 point Gothic. May Bm BawOou* XU quired by this paragraph. by subparagraph (1> of this paragraph, T o u r H ealth. (2) Preplacement.The employer shall samples shall be of such frequency and pattern as to represent with reasonable Spacing between lines shall be at least provide oarmake available to each of his employees; within SO mflmrtar days fol accuracy the levels of exposure of em equal to the height of the upper of m y two Ones. lowing his first employment in on ployees. Xn no case shall the sampling be done at Intervals greater than 8 months Cl Caution labels-- Labeling. Cau occupation exposed to airborne con centration! o f aabeatos fibers, a compre for employees whose exposure to asbestos tion labels shall be affixed to an raw material, mixtures, stamp, waste, debris. hensive medical which diwJI may reasonably be foreseen to exceed (thcr product! nnhntog indude, os s minimum, a chert roent- othfethliismseitcstiporne.scribed by paragraph (b) fiber*. or to their containers, except that fleaograat (posterior-anterior 14 x IT inches), a history to aUelt symptom (3) no label Is required where asbestos fibers Environmentalmonitoring--(1h) ave been modified by a bonding agent, atology of respiratory disease, and samples shall be collected from areas of coating, binder, or other material so that pulmonary function teste to indude forced vital capacity (FVC) and forced a work environm ent which are represent during any reasonably foreseeable use. ative of the airborne concentrations of handling, storage, disposal, processing, or expiratory volume at 1 second (|H 7 U) . asbestos fibers which may reach the transportation, no airborne concentra (3) Annual tianmoxeOn or be-- fore January 31, 19731 and at leasl an breathing zone of employees. Samples tions of asbestos fibers in excess iff the nually thereafter, every employer yh*u shall be collected on a m embrane filter exposure limits prescribed m paragraph provide, or make available, comprehen of 0.8 micrometer porosity mounted in (b) of this section will be released. sive medical examinations to each of bis an open-face filter bolder. Samples shall (11) LabeispedflctUUms. The caution employees engaged in occupations ex* be taken for the determination of the 8- labels required by subdivision (1) of this posed to airborne concentrations of as hour time-weighted average airborne subparagraph shall be printed In letters bestos fibers. Such annual examination concentrations and of the ceiling con o f sufficient size and contrast as to be shall indude, as a minimum, a chest centrations of asbestos fibers. readily visible and legible. The label shah roentgenogram (posterior-anterior 14 x its Sampling frequency and patterns. state: 17 in ch ), a history to eticH xymptom- After the initial determinations required C tom iiv mtology gf respiratory disease, and by subparagraph d ) of this paragraph, Contains Asbestos Fibers pulmonary function tests to Include samples shall be of such frequency and AvoM Creating Drat forced vital capacity (FVO and forced pattern as to represent with reasonable Breaming Asbestos Drat Us? Cwui expiratory volume at 1 second (PSVLJ . accuracy the levels of exposure of the sertfNw B0SU7 H u m employees. In no case shall sampling be fG ifn u a i w a m RUUES AND REGU LATIO N S $ 19\0'93 /fthcsio*. (ll) Particular products an d opera (a> Dtflnitions. JFbr the purpose of this section . (1) "Asbestos" Includes chrysotile. am osite. croddoUte, trem o- lite, anthophylhte. and actinolite. (2> "A sbestos fibers" m eans asbestos fibers longer than S micrometers. (b> P erm issible exposure to airborne con cen tration s of asbestos fibers-- ( l ) Stan dard effective July 1, 1972. The 8-hour tim e-w eigh ted average airborne concentrations o f asbestos fibers to which any employee may be exposed shall n ot exceed five fibers, longer than 5 m icrom eters, per cubic centim eter of air, as determ ined by the method pre scribed tat paragraph (e) of this section. (2) S tandard effective 1, 1976. The 8-hour tim e-w eighted average air borne concentrations o f asbestos fibers to which any employee may be exposed shall n ot exceed two fibers, longer than tions. No asbestos cem ent, m ortar, coat ing. grout, plaster, or sim ilar material containing asbestos sh all be removed from bags, cartons, or other containers in which they are shipped, w ithout being either w etted, or enclosed, or ventilated so as to prevent effectively th e release of airborne asbestos fibers in excess o f the lim its prescribed in paragraph (b) of th is section. (ill) Spraying, dem olition , o r removal. Employees engaged in th e spraying of asbestos, th e removal, or dem olition of pipes, structures, or equipm ent covered or Insulated with asbestos, and in the removal or dem olition o f asbestos in sulation or coverings sh all be provided w ith respiratory equipm ent in accord ance w ith paragraph id ) (2) (til) of this section and w ith special cloth in g in ac cordance w ith paragraph (d ) (3) of this seettoo. S m icrom eters, per cubic centim eter of air, as determ ined by th e method pre scribed in paragraph (e) of this section. (3) C eiling concentration. No em ployee sh all be exposed a t any tim e to airborne ceocentratlons of asbestos (d) Personal p rotective equipm ent-- (Z) Compliance with th e exposure limits prescribed by paragraph (b) o f this sec tion may n ot be achieved by th e use of respirators or sh ift rotation o f em ployees; except: fibers in excess o f 20 fibers; longer than 5 m icrom eters, per cubic centim eter of air. as determ ined by the method pre scribed in paragraph (e) o f th is section. (1) During the tim e period necessary to install th e engineering controls and to institute the work p ractices required by paragraph (cl of th is section: (111 In work situation s in w hich the (c) M ethods of com pliance-- (i) E n g in e e rin g tms<hed.oi) Engineering con methods prescribed lit paragraph (c) of trols. Engineering controls, such as, but not lim ited to. Isolation, enclosure, ex th is section are either tech n ically not haust ventilation, and dust collection, feasible or feasible to an ex ten t Insuffi shall be used to m eet the exposure lim its cien t to reduce the airborne concentra prescribed in paragraph (b) of th is tions o f asbestos fibers below th e lim its section. prescribed by paragraph (b) o f this (til Local exhaust ventilation, (a ) section; or Local exhaust ventilation and dust co l (ill) In em ergencies. lection system s shall be designed, con (iv) Where both respirators and per structed. installed, and m aintained in sonnel rotation are allowed by subdivi accordance w ith th e American N ational sions (1). (11), or (ill) o f th is subpara Standard Fundam entals Governing th e graph, and both are practicable, person Design and O peration of Local B xhanst nel rotation shall be preferred and used. System s. ANSI Z9.Z-197I. which Is in (2) Where a respirator is perm itted by corporated by reference herein. subparagraph (1) o f this paragraph, it <b) S e t f 1910.8 concerning the avail shall be selected from am ong those ap ability o f ANSI Z9.3--1971, and th e proved by the Bureau o f M ines. Depart m aintenance o f a historic file in connec m ent of the Interior, or the N ational In tion therew ith. The address of the Amer stitu te for Occupational S afety and ican N ational Standards Institute is H ealth. Departm ent of H ealth. Educa given in 1 1910.100. tion. and W elfare, under th e provisions of Ciii) Particular to d s. AH hand-op 30 GFR Part 11 (37 P R . 244. Mar. 25, erated and power-operated tools w hich 1972), and sh all be used In accordance may produce or release asbestos fibers w ith subdivisions (i). (11). O il), and fiv) in excess o f the exposure lim its pre of this subparagraph. scribed in paragraph (b> of th is section, (i> A ir purifying respirators. A reusa such as, but n ot lim ited to. saws, scorers, ble or single use air purifying respirator, abrasive w heels, and drills, shall be pro or a respirator described In subdivision vided w ith local exhaust ventilation sy s (ii) or Oil) of this subparagraph, shall tems in accordance with subdivision ill) be used to reduce the concentrations of of this subparagraph. airborne asbestos fibers in the respirator (2) W ork practices-- U> W et m ethods.below the exposure lim its prescribed in Insofar as practicable, asbestos shall be paragraph (b) of this section, when the handled, m ixed, applied, removed, cu t. ceiling or the 8-hour tim e-w eighted aver scored, or otherw ise worked in a w et age airborne concentrations of asbestos state sufficient to prevent the em ission fibers are reasonably expected to exceed of airborne fibers in excess of the ex no more than 10 tim es those lim its posure lim its prescribed in paragraph (b) of th is section, unless the usefulness of the product would be dim inished thereby. ii) P o w ereaair A fu ll facepiece powered air purifying respirator, or a powered air purifying respirator, or a respirator described in subdivision (ill) o f th is subparagraph, shall be used to reduce the concentra tions o f airborne asbestos fibers in th e respirator below the exposure lim its pre scribed in paragraph <b> of this section , when th e ceiling or th e 8-hour tim e- w eighted average concentrations o f asbestos fibers axe reasonably expected to exceed 10 tim es, but not 100 tim es, those lim its. tiii) T ype "C " svpplied-air respirators, continuous flow or pressure-dem and class. A ty p e "CMcontinuous flow or pres sure-dem and. supplied-air respirator snail be used to reduce the concentra- tions o t airborne asbestos fibers in th e respirator below the exposure lim its pre scribed in paragraph (b) of this section , when th e ceiling or the 8-hoar tim e- weighted average airborne concentra tions o f asbestos fibers are reasonably expected to exceed 100 tim es those lim its. (Iv) E stablishm ent o f a respirator pro-u grcm.(a) The employer shall establish x respirator program in accordance w ith the requirem ents of the American N a tional Standards Practices for R espira tory P rotection. ANSI 288.2-1969. w h ich is incorporated by reference herein. b. See i 1919.6 concerning the a v ail ability o f ANSI Z88J-1969 and the m ain tenance of an histotie file in connection therew ith. The address of the Am erican N ational Standards Institute is given In i 1910.100. (c) No employee shall be assigned to tasks requiring the use o f respirators if , based upon h is most recent exam ination, an exam ining physician determ ines that the em ployee w ill be unable to function norm ally wearing a respirator, or th at the safety or health of the em ployee or other em ployees w ill be impaired by h is use o f a respirator. Such employee shall be rotated to another Job or given the opportunity to transfer to a different po sition whose duties he is able to perform w ith the sam e employer, in the sam e geo graphical area and w ith the sam e senior ity. statu s, and rate o f pay be had just prior to such transfer, if such a different position is available. (3) Special clothing: The employe? shall provide, and require the use o f. sp e cial clothing, such as coveralls or sim ilar whole body clothing, head coverings, gloves, and foot coverings for any em ployee exposed to airborne concentra tions-of asbestos fibers, which exceed the ceiling level prescribed in paragraph (b) o f th is section. (4) Change rooms: (i) At any fixed place o f em ploym ent exposed to airborne concentrations of asbestos fibers in ex cess o f th e exposure lim its prescribed in paragraph (b) o f th is section, th e em ployer shall provide change room s far em ployees working regularly at the place. ill) C lothes lockers: The em ployer ball provide two separate lockers or con tainers for each employee, so separated or Isolated as to prevent contam ination o f the employee's street clothes from his work clothes. FKDflAL I IC lf T f v r n pure s p ir a to r SUIES AND REGULATIONS (4) Termination of employment. Thy employer shah provide, or maka avail able, within 30 calendar dan before or after the termination of employment of ftpy CtUployfC fti IQ exposed to airborne eaaem tm ttona of asbestos fibers, a comprehensive m edical which tnglydfft | | % minimum, a chest wentienogam (pos terior-anterior 1 z ITlnehet>. a history to elicit symptomatology of respiratory iHummi miwI nnlmaturr function. tests to lnduda forced vital capacity (FVC> and forced expiratory vnhuneat 1 second m. (5) Recentexam inations. No m edical eraminaHftW jg fwjnlffn| ot any em ployee. If adequate itc cn ii show th a t Hm emolovea has been Hi u > eordaaee w ith th is paragraph w ithin the p ast 1-year period. (8) M edteai record(1) nance. Employe of employees examined pnrsnant to this paragraph shall came to be complete ffranifo records ot aO snsb medical rramlira- Hons. Record shall be retained fay employes far at least TOyean. M ainte (20 Access.The contents of the re> rtrAm A# Bio mttltcAl ^ruwitwoHfwva required by this paragraph shall be made available; for Inspection and copying; ? i s s r 'z and medical consultant at sttber of them. and.up*thoimocrt Qf a n m " ployee or former employe^ to M j w a * mation specifically required h f T-ar- fr-pH, and any other medical in formation related to ocoipaUcoal ex posure to asbestos fibers. DEPARTMENT O F HEALTH & HUMAN SERVICES AFFIDAVIT Office of the Secretary O ffice of the G eneral Counsel Pubic Health Division CDC/ATSOR Branch 1600 Clifton Road. N .E .. VUS D53 Atlanta. Georgia 30333 (404) 639-7200 I, CECI VELASCO being first duly sworn, deposes and states as follows: 1. I am a Legal Technician in die Office of the General Counsel, Centers for Disease Control and Prevention (CDC), United States Department of Health and Human Services. I make this affidavit upon personal knowledge, and where indicated, upon the basis of information communicated to me by employees of the United States because of my official position. 2. In my position, I am a custodian of and authorized to certify official records of die U. S. Department of Health and Human Services. 3. The attached record, imprinted with the official CDC seal, is a true copy of official records of CDC, an agency of the U. S. Department o f Health and Human Services. 4. The document referred to above are part of the official records of the United States Department of Health and Human Services. Page Two I declare under penalty of peijury that the foregoing is to the best o f my knowledge and belief true and correct Executed at Atlanta, Georgia. Ceci Velasco State of Georgia) County of DeKalb) Subscribed and sworn to before me this % ^ day of June, 2004. Q jU . 6 - h < i o t ^ Notary Public 01A B.CiG K X A .N P. BARROW COUNTY, GEORGIA MY COMMISSION rj?P t"E5 SEPT. 19,2007