Document 82z6pYdaej2OkOGLvqO7yV3qB

OP o-t c| INTERDEPARTMENTAL COMMUNICATION T> Mr. K. W. Browri^ Mr. A. Palmowski FROM: T. W. Richards Xr/* J SUBJECT: ASBESTOS CONTROL PROGRAM PLAINTIFF'S EXHIBIT GP-208 March Acme Chicago ;ard Attached is a copy of the Gypsum Association Asbestos Control Program. You will note that it is similar to what we have sent out in the past. We are looking into a monitoring program but there is a drawback; namely, OSHA will not accept any findings unless the sampling is conducted by one of their hygienists. Having the analysis done by an approved laboratory is rather costly. The discs or cassette samples can be done by plant personnel and the cost would be small. Analysis of cassettes usually carry a cost estimate of $50.00 per cassette, a minimum of 12 cassettes for an hour exposure, fee of $600.00. We are hoping to have someone in our employ trained and approved by the Bureau of Mines. This person or persons could conduct other tests in the mining and milling operations when required by the Mine Safety Act. Engineering Controls: No change. Medical Examinations: Each employee exposed to asbestos dust. Previously the mixer operator. Note the termination clause, paragraph 3 also paragraph, outline of medical. Respirators. The MSA Bureau of Mines approved one use type. Also complete instructions on the use of respirators. Note it could be a bomb. This part is new, previously he would be taken off the job but no reference was made regarding the pay. aution signs and labels. We conform; We are adding "when emptying bags or sanding respirators shall be worn." *^GaundBng of clothes. There are disposable uniforms available, 'Contactvyour safety equipment supplier. . .^ * \ ' ?'^3ag disposal, a must. Plastic bags or containers can be * obtained. -It has been suggested that the trash bag will meet specifications. . i Recordkeeping. Some changes. JMostl^of the changeroom laundering and change of clothing clauses are mandatory when the TLV exceeds the allowable as^stated in the act. MFF:jg Attachment i ASBESTOS ABATEMENT PROGRAM GUIDELINES Prepared By The Gypsum Association Safety Committee Jt , MAXIMUM PERMISSIBLE EXPOSURE LEVELS I ii The Act specifies certain maximum permissible concentrations of ai rborne asbestos fibers to which an employee may be expos.ed. These maximum concentrations are expressed as an 8 hour time weighted average of the number of fibers exceeding 5 micrometers in length, per cubic centimeter of Air. These maximum permissible concentrations are: i, * i 1. Until July 1, 1978: 5 Fibers per Cubic Centimeter. 2. After July 1, 197: 2 Fibers per Cubic Centimeter. In addition, a concentration of 10 fibers per cubic centimeter of air has been established as a ceiling concentration. No employee can be exposed to a concentration in excess of this amount A^t Any Time. * MONITORING REQUIREMENTS A monitoring program to determine every employee's exposure 4 V to asbestos fibers is required by the Act. The Act specifies that air samples be analyzed using membrane filters of 0.8 micrometer porosity mounted in an open face filter holder. The samples are then examined under a L00-L50 power microscope using phase contrast illumination to tI determine the concentration of airborne asbestos fibers. > "a i The Act states that every employer must measure the concentration of asbestos fibers in all areas where asbestos fibers are released to de termine whether the maximum permissible exposure levels are exceeded. Samples must be taken within 'the breathing zone of employees ("Personal Monitoring") and within the general work area ("Environmental Monitoring") / to determine both the 8*hour time weighted average and ceiling concen trations of asbestos fibers. 4 In all areas where the maximum permissible exposure limits are exceeded, the employer must immediately undertake an asbestos abatement program to comply with the Act. In addition, concentration samplings in these areas must be taken at no longer than six month intervals. Affected employees, or their representatives, have the right to observe any monitoring procedures. ENGINEERING CONTROLS If the concentration of airborne asbestos fibers is found to be in excess of the maximum permissible exposure levels established by the Act, an employer will be required to take various steps to re duce the number of fibers to within the accepted limits. The Act recommends that the following Engineering Controls be employed; A. Isolating the work area T. Enclosing the asbestos materialswhenever practicable C. Installing an exhaust ventilation system 0. Installing dust collectors The Act cites "American National Standard Fundamentals Governing the Design and Operation of Local Exhaust Systems" (ANSI 29.2-l972) as a useful reference. The Act permits acceptable respirators (as discussed later) to be worn only as a temporary measure until the Engineering Controls arc installed. MEDICAL EXAMINATIONS - The Act requires that each employee who is exposed to air borne asbestos dust be given a comprehensive medical examination paid for by the employer at the following times; 1 i i 1. Vith,in 30 days of initial placement in a job requiring exposure to asbestos i i iiiii 2. At least once every twelve months 3. Within 30 days of termination of employment or transfer to a job no longer requiring exposure to asbestos \ The medical exam must include, as a minimum, a 1. Chest X-Ray 2. Pulmonary Function Tests .1i a. Forced Vital Capacity I ii b. Forced Expiratory Volume at 1 Second ] 3. Medical History to Determine Whether the Employee had ever had any respiratory diseases. i Records of all such medical examinations must be retained i by the employer for a minimum of 20 years. t, l RESPIRATORS The use of resp.irators tp protect employees from concentrations I t of asbestos fibers exceeding the maximum exposure levels is not permitted except in cases where it is not technically feasible to reduce the con l centration to a safe level, or in emergencies. Respirators may, however, be used as an interim measure during the period necessary to install the S. proper engineering controls to, reduce the concentrations, or to institute I the work practices required by the Act. In these cases, personnel rotation I1 (administrative controls) shall be used in preference to respirators - 1 if it is practicable. The Act requires the employer to establish a respirator program i ) in accordance with the "American National Standards Practices for Respiratory Protection" (ANSI Z88.2 1969) if respirators arc to he used. The Act also specifies that, if a physician determines that an employee will be unable to function normally, or that the health or safety of the employee or his fellow workers will be impaired by wearing a respirator, the employee'must be rotated to another job or given the opportunity to transfer to a different job with the same seniority and rate of pay. The type of respirator used will depend on the maximum concen tration of fibers to which the employee is expected to be exposed. All respirators must be approved by either the Bureau of Mines, The Department of the Interior, or The National Institute for Occupational Safety and Health. The following respirator types may be used at the maximum fiber concentrations specified: 1. Concentrations up to j>0 fibers per cubic centimeter (After July l, 1976, the maximum will be 0 fibers)a reusable or single use air purifying respirator, or any of the respirators listed below; 2. Concentrations of between 50 and 500 fibers (After July 1, 1976, between 20 and 200) - A full facepiece powered air purifying respirator, a powered air purifying respirator, or the respirator described, below; 3. Concentrations exceeding 500 fibers per cubic centi meter (After July 1, 1976, 200 fibers) - A type "C" continuous flow or pressure-demand, supplied-air respirator. In all cases, the respirator must be capable of reducing the inhaled fiber concentration to a level below the maximum permissible exposure concentration. CAUTION SIGNS AND LABELS The Act specifies that caution signs must be posted at each location where airborne concentrations of asbestos fibers may be in excess of the exposure limits. Signs must be posted at all approaches to these locations, so that employees can take necessary protective actions before entering thn hazardous areas. Exact specifications for the 20" x 1**" signs are given in Section 1910.93a (g) ii of the Act. Each sign must state: ASBESTOS OUST HAZARD Avoid 8reathing Dust i , Wear Assigned Protective Equipment Do Not Remain In Work Area Unless your work requires it Breathing Asbestos Dust May Be Hazardous To Your Health All raw materials, mixtures, scraps, debris, products containing unbonded asbestos, contaminated work clothes, and containers for these materials must contain a clearly legible warning label which states; CAUTION a CONTAINS ASBESTOS FIBERS Avoid Creating Dust Breathing Asbestos Dust May Cause Serious Bodily Harm These labels must be printed in letters of sufficient size and contrast as to be readily visible. REVISED WORK PRACTICES In order to prevent or reduce the'emission of airborne fibers, the Act specifies that all asbestos must; be handled or worked in a wet state...All asbestos products in powdered form cannot be removed front bags, cartons, or other shipping containers without being either wetted, enclosed, or ventilated to prevent the release of asbestos fibers into the atmosphere. The Act stresses the importance of good housekeeping in alt areas where asbestos is used. According to the Act, all external sur faces must be free of accumulations of asbestos dust. Because of the danger that further handling may release hazardous levels of airborne'asbestos, all asbestos scrap, debris, containers, con taminated clothing or equipment must be disposed of in sealed, impermeable containers. Each container must bear an approved warning label. CLOTHING Because of the danger that asbestos dust may be carried home in an employee's clothing, special arrangements must be made to ensure that an employee's street clothes do not become contaminated by airbornr asbestos fibers if the employee is exposed to concentrations of asbestos fibers exceeding the threshold limit value (TLV). The employer must provide special work clothing such as over alls, hats, gloves, and foot coverings for any employee exposed to hazar dous concentrations of asbestos fibers. The employer also must provide change rooms containing separate lockers for contaminated clothing and street clothes for each employee. These lockers must be separated or isolated to prevent dust from.the work clothes contaminating the sired clothes. The Act specifies that the employer must inform whoever launders the contaminated clothing'of the requirement that the clothing be laundered in such a way that the release of airborne asbestos fibers is prevented. Clothing must be transported to the laundry In sealed, impermeable con tainers bearing the asbestos warning label. RECORDKEEPING v. Under the terms of the Act, every employer is required to keep accurate records of the plant fiber concentration monitoring program and of employee medical examinations. Records of personal and environmental monitoring results must be maintained for a minimum of three years, while results of employee medical examinations must be retained on file for at least 20 years. These records must be made available to the Assistant Secretary of Labor for Occupational Safety and Health or to The Director of the National Institute for Occupational Safety and Health on request. In addition, every employee or former employee should be given reasonable access to records indicating his own exposure to asbestos, and the result of his own medical examinations. An employee may also request that his medical records be released to his physician. The Act requires that all employees exposed to hazardous concentrations of asbestos fibers be informed in writing within 5 days after the hazardous condition is discovered. Employees must also be kept advised of the corrective action being taken. --^z-ocsg^r a/Ovlz,' ^2W^^23L Jjuc*<&- Cc^Jb, J&ast> ^ dZocA^, ?/#>+J ^sJuStcc^ zzo J&2*ex~<--^"T-*--^-^' JZ*^G> <zO?f<2^ij jZtlA^p 6&SUU+ J&t &^ZzzZ^ &l-C &^e> 0&A <y?z u*z> ^di<Ayti ~**^z<<4LZ7L& ^ s &,' ^&^csS%^<t6' Q&ifsJ^' Cc*>S 2- ^1 ^7rp j2AUL4Zj2^^^3& ^c^-C OlsLj^' 'uZZL^^<s5^p' C^J e#c/ &AL-'<5l^ ^#2 J?A <:^&a*r^r &cA-?~s7Zr *<^A<^X^~^J P2c*i/L/ ^f04Zr*xZ*Z&L /?&P*->~esUsri^, "?&&~r~-o y -^^^>o5ie/ y^<&'txZJ .s^fefe/^ ^ZeeJ&u^ >75^ ^Zj>tf*jf&&z&\&kj sg&htj -c**-u/' i