Document 8OBeYEwo4pjXXLGYyEJ6qy0d

FILE NAME: DuPont Remington (DRM) DATE: 1972 June 13 DOC#: DRM007 DOCUMENT DESCRIPTION: Memo from DuPont RE OSHA Standard S4T Measurement and Control of Asbestos Dust Exposure, with Comments by the Safety & Fire Protection Subcommittee cv. E. I. du Pont de Nemours & C ompany Wilminoto^. Delaware im CNaiNESKINO OCPAHTMCNT . UOUVICRS BUILDING June 13,* 1972 cc D.G. Windsor-Emp.Rel.-Wilm. Subcommittee Members J.D. Anthony - ERD H.A. Heidelberger - Design Refer to S e r ia l Le tte r 4013 Dated November 8 , 1972 R.D.CARLTON, BIOCHEM., WILM. (2 ) R.E.ROBBINS, CENT. R ES., EXP.STA. (2 ) H.F EATON, ELASCHEM, WILM. (9 ) J . C . BRECHENRIDGE,EMP.REL.,WILM. (1 ) C .S.ELLER , BMfelD, LOUVIERS (1) C.DjBRCWN, CONSTRUCTION, LOUVIERS (1 ) R.F.STEWART, DESIGN, LOUVIERS (8 ) J.P.KLIMCWICZ, ERD, EDL (1) F.J.MARTIN, ESD, LOUVIERS (1) H.H.KOHL, F&F, WILM. (12) V.E.N EFF, FILM, WILM. (7) W.H.MC COY, IND.CHEM. ,WILM. (U C.W.ANDRUS,INTL., WILM. '1, J.V.FLYNN, ORCHEM, CH.WKS. 16. J. J.LAURINO,PHOTO PROD.,WILM. (5, R.H.MC CONNELL,PIGM.,EDGE MOOR ^6} K . V.DAHL, PLASTICS, WILM. (7 ) T .C .H IL L , POLYMER INTER., WILM. U } H.G.SHULBY,PURCHASING,LOUVIERS (2 ) J.A.SIGMAN, T E X .F IB ., WILM. (2 ) R .H .GRUSS,REM.ARMS,BRIDGEPORT ( 2 ) STANDARDS SECTION - SAFETY L FIRE PROTECTION SUBCOMMITTEE S4T - MEASUREMENT AND CONTROL OF ASBESTOS DUST EXPOSURE . This standard was approved without comment by the following departments: Elaschem, Employee Relations, ESD, FicF, International, Film, Pigments, Purchasing. In addition, the following comments have been received from the Engineering Standards Committee. These have been reviewed by the subcommittee, with replies as shown below. Comments have been arranged to put like replies together due to the number involved, rather than the usual procedure. J. V. FLYNN. COMMENTS BY R. D. GOTWALS/W. S. PERSON - ORCHEM - CH. WKS. TOEMEKT Hfl. 1 - Does tKe TLV'TSSTT meet proposed Federal limits'.' REPLY - The threshold limit value (TLV) for asbestos listed in S2T was basec on 1970 values of American Conference of Governmental Industrial Hygienists. A new, more restrictive limit for asbestos has been included in the OoHA regulation promulgated ir. the U.S. Federal Register of June 7, 1972, pages 11313-11322. Both S2T and S4T must be changed accordingly. J. J. LAURINO, COMMENT 3Y J. J. LAURIN 0 - PHOTO PRODUCTj - WILMIMTC:. CMmENT NO. 2 - Recommend that this stancarc not be issuao until c.-.e n s x format indicating the part coverea by OSHA is in use. REPLY - Standard has been delayed as you suggested. Also, see reply tc Comment -No. 1. The part covered by OSHA will be prir!teo in rea. W. H. Mu COY COMMENTS BY J. PAVLOSKI/R. FISHER - IN O . CHEM. - REP.-.UI.O COMMENT N-Q. 3 - Will this concept be extenaed to al+ insulating materia.; and not limited tc Just asbestos? Many insulations cor.taa.ri no asbestos out are dusty and fibrous. Insulations containing silica, although less text: can cause silicosis and chronic lung disease. 268 5 DUP 0902730 DRM0000073 4013 11/3/71 ' 2 June 13, 1972 REPLY - This standard is limit ad to asbestos. Other insulating materials, although dusty and fibrous, do not contain carcinogenic material. J. V . FLYNN, COMMENT SY R. D. OOTWALS/W. S. PERSON (CON'T.) COI-lKbhT N0~. L - Exposure in a shop operation is sonewnat different from working on pipelines in the field. Should we not mention the application of this standard in field work as well? REPLY - It is intended as a guide for all cases of asbestos exposure including field work, as outlined in the scope. J. ' aIGt'.AN. COMMENT BY G. B. KIRKPATRICK - TEX. FIB. - OLD HICKORY cO.-^dlTTirD. ti - 3.4.1 - This wetting down of insulation should carry a caution to refrain from wetting down hot lines where: a) water could be flashed off to vapor and cause ourns; b) water could fracture pipe or weldments; c) water could freeze out or slow down process flow in ''on stream" lines. REPLY - Wetting down is carried out on lines that are still insulated, therefore direct contact by the water should not create a problem. Wording will be changed to "damper" vs. "wet down". Supervision should review unusual situations.. [COM-lbr."? NO. 6 - 6.1.1 - Each area group of insulators at Old Hickory are laskac to tn.-.o at least one sample (not necessarily of 3-hr. duration) on a different job each week. More samples are requested when there are indi cations of any change taking place or new types of materials are being tried. This type of sampling provides us with new data in some jobs ana shows results of our efforts to improve dust control in other jobs. J. A. bI3KAN, COMMENTS BY Vi. ft. CLAftX - TSX. FIB. - SZAFORJ P L A N T ' cbldMENf n G. 7 - fa.1.1 - Full s-hr shift not necessary-one hr is sufficient. J. A. bin:cAu. COMMENT 3Y 3. li. BOLTON - TEX. FIB. - MARTINSVILLE PLANT - Question need for sampling each operation for a full 3-hr shift monthly, Many operations are not continuous and 8-hr sampling is impractical. Also, sampling can show 7LV limits have never been exceeded in a particular operation. Some samples should be taken monthly, others semi-monthly, or annually.' J. A. blhMAN, COrfrUNT BY W. K . READING - TEX. FIB. - KINSTON PLANT i OIL A ? ? . ) . y - b.x'.l - Iwe are taking 2 eight-nour sam.pj.es mor.tr.j.y as a cneck and for histrociai file. . " . bx.j.'..iN, COMMENT 3Y A.. PAETSCK - TEXTILE FIBERS TrOIL.-tRl LJ). iL o.l.l - Paroling sncula be carried fa time. -/it a wonon-y \orztr v.. O fi.`*x.a\cM?Jcxo,r ,--<--o--x:r.~C.::Tm.3Y" W. C. CKRIaTY w\dau3>c*. a c3 Il.O. CHEM. - S AVANNA!- H opdr"al.2 - .n. wTi*s Ir.a be very time concur, ng. Sampling with r.illipore (mem,crane) paper, or equivalent, usually is of snort duration (10ll5 min.) because of tr.e n DUP 0902731 DRM0000074 S.L. 4013 11/8/7 - 3 - June 13 1972 collection efficiency of this paper. Such a procedure, as described, might involve taking many samples for an 8-hour shift for each operation, it $15.00 per sample for analysis, the cost of this operation will exceed the benefits, since the results of these analyses are not known for some time a and any reference to the TLV for that work period will be meaningless. Such program of sampling could be satisfactory provided the work con ditions do not change. Respiratory protection must be required in all cases where the degree of exposure is unknown. REPLY TO COMMENTS 6-11 - Eight-hours' sample is advisable in the preliminary sampling in accordance with frequency ana pattern by QSHA. Subsequent samples may be tailored to the individual needs of the location. 6.1 1 revised accordingly. J. A. SIGMAN, COMMENTS BY P. E . M . SOPHS - TEX. FIB. - DORDRECHT CoMMeNT Mo. 12 1 Change 5 .2 as follows: ^Clothes must be kept free of dust accumulation. Clothes contaminated with dust shall be vacuum-cleaned before taking them oS~, Avoid breathing asbestos dust when removing clothes*7. Bein* fiiore specific at this point is desirable. J. A. SIGMAN. COMMENT BY W. R. CLARK - TEX. FIB. - SEAFORD PLANT COMMENT fro. 13 - 5.2 - Intent good - but how and to what extent? REPLY TO COMMENTS 12 AND 13 - We do not agree the underlined sentence should be added. Specific techniques for removing dust accumulation from clothes should be developed locally. Vacuum cleaning is one way, but it may not be the best method available. J. A. SIGMAN, COMMENT BY W. R. CLARK - TEX. FIB. - SEAFORD PLANT COMMENT"'NO'. 11 - 3.1.S'- omit'. ---------------------------------- REPLY - This is considered a large source of asbestos dust; therefore we feel it is necessary. COMMENT NO. 15 - 3.1.3 - Include vacuum or respiratory protection. Should be done only if sample analyses so indicate. REPLY - Subcommittee prefers current wording. COMMENT NO. 16 - 3-2.1 - Recommend use of respirator with or without exhaust system. REPLY - We do not feel that a respirator should be required when it is net necessary. Requirements of Sect, w will determine need. COMMENT N 0 17 - 3*2.3 - Assume portable vacuum cleaners are acceptable. REPLY - Yes, also see reply to comment No. 45. J. A. S!GMAK COMMENT BY W. R. CLARK (CON'T.) COMMENT Nc . 18 - 3.3.1 - Why not eliminate use of asbestos cement? Use Power House cement, which contains no asbestos. DUP 0902732 DRM0000075 S.L. 4013 11/8/71 - 4 - June 13 1972 J. A.. SIGMAN, C0MML.CT BY J. M. MARTIN - TEX. FIB. - CHATTANOOGA PLANT COMMENT NO. 19 - Asfctstos-cement should be avoided whemaver"possible. REPLY TO COMMENTS 18 AND 19 -2.7 encourages the substitution of non asbestos bearing materials wherever possible. J. A. SIGMAN, COMMENTS BY W. R. CLARK (CON*T.) COMMENT NO. 20 - 3.4.1 - Po not recommend wetting down. vacuum before removal and for job cleaning. Do recommend J. A. SIGMAN, COMMENTS BY W. M. READING (CCN'T.) CAMm INt NO. 21 - 3747T al, wouJT3~^r^^ate a slipping hazard. Also) 'Si. -ssible to protect electrical equipment. There is little likelihood that this would be done unless a most elaborate and unusual precautionary pro cedure was followed. J. A. SIGMAN. COMMENT BY A. PAETSCH (CON'T.) CqMMEn t NO. 22 - 3.4.1 - Insulation w i n be used more than one time. Wet Insulation cannot be used. Insulation with finish is water-resistant. COMMENT NO. 23 - 3-4.3 - Area should be cleaned with vacuum system. Water should not beused. REPLY TO COMMENTS 20-23 - We consider wetting down the desirable technique, local conditions may indicate other control measures. "Wetting" changed to __ // en. . SIGMAN. COMMENT BY W. R. CLARK (CON'T.) COMm e Nt n o . 24 - Add- where dust problem exists (5.3) J. A. SIGMAN. COMMENT BY W. M. READING (CON'T.) COMMENT n o . 25 - 5 . 3 - We have not insisted on this. ment is questionable. Practical enforce J.A.SIGMAN, COMMENT BY A. PAETSCH (COW'T.) TOMMEn T n C. 26 - 5.3 - Gum or eating-tobacco can be consumed in working areas because breath-way will be kept wet. N o smoking. No food. REPLY TO COMMENTS 24-26 - Food, tobacco and gum should be restricted, since dust concentrations are not always known. J. A. SIGMAN, COMMENT BY P. F. PHILTAW - TEXTILE FIBERS - WAYNESBORO PLANT 6KKNt NO. 27 - 5.1 - Adherence to this item will create problems in tnat alternate facilities must be provided which will result in lost time from the job. Unless there is a clear need for this item, it should be deleted. REPLY - This restriction is recommended to prevent ingestion of asbestos particles into the system orally. We consider it is needed. J. A. SIGMAN, COMMENT 3Y J. K. MARTIN (CON'T.) gOTISEKYUS. 23"-' Not necessary to isolate power cutting equipment ir. a separate woric area if adequate exhaust system is provided. REPLY - Agree. An adequate exhaust system will eliminate the need for total isolation of the equipment. DUP 0902733 DRM0000076 S .L . 4013 11/6/71 5 June 13 1972 J. A. SIGMAN. COMMENT BY J. M. MARTIN (CONfT.) COMMENT iio. a - Question necessity of extensive daily clean-up; good Judgement should be exercised for frequency of clean-up. REPLY - Daily clean-up is strongly recommended. yo J. A. SIGMAN, COMMENT BY W. K. READING {CONTT . ) COMMENT n o ; r In general". We~beTiTve that the standard is basically good but unrealistic. We would, at best, require a major modification of our equipment and procedures to comply. REPLY - We understand that a major modification of equipment and procedures ma.v 5e required; however, we believe the standard is reasonable when con sidering worker health and OSHA regulations. Also, see reply to Comment No.l COMMENT NO. 31 - Neither vacuum or ask are believed to be necessary(3.1-3) REPLY - Vacuum or respiratory protection is considered necessary since this operation is a major source of airborne asbestos fibers. CO^tffiNT NO. 32 - Would like to know where to purchase and what type of insulation is available.^ We cannot accept Unibestos (3.1.4). COMMENT NO. 33 - 3*3.2 - Would like to know where this type of cement could be purchased. REPLY TO COMMENTS 32 AND 33 - This information is being included in insul ation specifications^ Contact the Insulation Standards Subcommittee. COMMENT NO. 31 - 3-2.1 - Our saws are not isolated, but we have not been above the TLv in our tests. Our exhaust system performs very well; however, the dust is not wet down. Adjacent carpenter shop's outside exhaust system is tied into same system. Contents from cyclone drop into closed dumpster. Some fibers are lost in cyclone air exhaust outside of the building. REPLY - Saws must not necessarily be isolated in the sense of partitioning off. They should be in a separate area and the efficiency of the exhaust systems measured to assure they are functioning properly. (See Comment 1.) COMMENT NO. 35 - 4.1.1 - We do not believe this is necessary, but the information is pertinent. R. D. CARLTON, COMMENT BY W. F. DOBBS - BIOCHEMICALS - BELLE PLANT COMMENT NO. 3o - 3.4.2 - Believe some exception should be maae to this requirement permitting "small" amounts of insulation to be removed without respiratory protection. Can a rule-of-thumb quantity be stipulates which will not result in exposure to higher than permitted TLV? Can in iaental removal of insulation not requiring over 5-10 minutes excepted? REPLY TO COMMENTS 35 AND 36 - Local conditions should be monitored and pro- ;edures established In consideration of other sections of this standard." Also, see reply to Comment No. 1. DUP 0902734 ^ S C # '-*' DRM0000077 S .L . 4013 11/8/71 - 6- June 13 2-972 J. A. aIGMAN, COMfcliT BY A. PAET5CH (CON'T.) CCm m n T NO. 37 - 2.3 - Standard S2T should be in conformity to the latest threshold limit values (TLV's) or to the limits of German authorities (Staubforschunginstitut). REPLY - S2T is revised annually to conform with latest TLV's. See reply to comment No. 1. c o m m 1 NO. 38 - 3.1.5, 3.4.1 - Design of proposed work table is required. COMMENT NO. 39 - 3*4.5 (New) - If possible transportable work-table with vacuum system should be used for working in the areas. REPLY TO COMMENTS 38 AND 39 - Tables should be designed to meet local needs. COMMENT NO. 40 - 3.4.2 - Which dimension should the area haveV REPLY - Dimensions of the area would be determined by monitoring. K . W . DAHL. COMMENT BY C. C. PRING - PLASTICS - SABINS RIVER WORKS COMMENT No . 41 - We would like to have suggested sampling equipment added to the standard. W. H. MC COY. COMMENT BY W. 0. CHRISTY (CON'T.J -2.4' - Sampling fibersand particulates can differ. The battery-operated sampler approved for fiber sampling should be specified to include millipore filter. COMMENT NO. 43 - 6.1 - Suggest clarification of this statement. Recommend addition of: "with a battery-powered personal air sampler". Suppliers of such samplers are: The Mine Safety Equipment Company, and the Union Industrial Equipment Company. COMMENT NO. 44 - 6.1.3 - Asbestos handling is now recognized as an extreme ly serious industrial hygiene problem. Analyzing asbestos samples is necessar But the problems in sending samples several hundreds of miles by mail shoui be pointed out and the importance of correct handling emphasized, come of the problems are: transportation of samples may cause damage to the sample and possible loss of sample; delay in receiving results. This will, probably, be inevitable with laboratories receiving many such samples. Expensive as it may appear, the alternative may be to do local monitoring, use local laboratories, or to utilize the best engineering and personal protective measures available. REPLY TO COMMENTS ul-44 - We recognize that fibers and particulate sampling differs.hasKell Laboratory will recommend appropriate pump ana filler for various applications. DUP 0902735 .s C .S 'k 1 DRM0000078 S .L . 4013 11/8/72 - 7- June 13, 1972 COMMENT NO. 45 - 3.1.2 - Type of vacuum cleaner and filter should be specified. Without high efficiency filters, this cleaning operation will filter out all particles and fibers, except those in the respirable fraction. REPLY - Type of vacuum cleaners and filters will vary with location, valuation should be made and selection based on local need. COMMENT NO. 46 - 3.1.3 - Type of respiratory protection should be specified. COMMENT NO. 47 - 3.4.2 - Specify suitable respiratory protection. RPT l TO COMMENTS 46 AND 47 - Required type of respiratory protection is specified as that which complies with Bureau of Mines Schedule 21B, see 4.1.2. There are various manufacturers who sake an acceptable type. COMMENT NO. 48 - <..1.2 - A reference to U.S. Bureau of Mines Schedule 'iB, Part 1 4 , Subpart A, item 14.4, minimum efficiency 0.3 micron is needed. Several suppliers of respirators that meet this requirement are: Acme Protection Equipment 1201 Kalamazoo Street South Haven, Michigan Company Mine Safety Equipment Sraddock, Thomas, and Pittsburgh, Pa. American Optical Company Southbridge, Mass. Co. Mead Streets REPLY - All requirements of Schedule 21B must be met and we should not pinpoint the part and subpart. We will delete the effective filtration range to avoid- possible confusion. COMMENT NO. 49 - 3.1.5 - This operation can still produce dust in breathing zones unless carefully controlled, perhaps a self-closing damper on the shute or flexible self-sealing slot. REPLY - Some dust is inherent in all operations. If this is above the acceptable TLV, respiratory protection should be provided. COMMENT NO. 50 - 3-2.2 - "An adequate exhaust system" should be defined. A minimal exhaust rate per fan should be specified. Our experience showea that, despite exhaust fans and no appearance of dustiness, the TLV still was exceeded. Suitable protection is net defined. Consideration should be given to exposure of other people in the work area. REPLY - Ar. adequate exhaust system is on# which maintains asbestos fiber concentrations below the acceptable TLV. 3.2.2 revised. COMMENT NO. 51 - 3*4.4 - We have found nc plant or governmental regulations TSVftffting the disposal of asbestos. EEFLY - QoHA Regulations recently issuea on an emergency basis, anc new permanent, -.re specific as to the disoosal of asbestos. See Federal Register reference in Ccmr.er.t Nc. 1 reply. DUP 0902736 DRM0000079 S.L. 4-013 11/3/71 - 8 - June 13, 1972 COMMENT NO. 32 - 4 1 - This rule really says always wear respiratory pro tection when handling asbestos. Samples are sent away for analysis and results are known long after the fact - too long for corrective action. REPLY - Respiratory protection should be provided until sample results are received and it is established that TLV's are not being exceeded. y . - H . M C COY. COMMENTS BY J. PAVLOSKI/R, FISHER - IND. CHEM, - REPAUNO WORKS COMStiTlirS.;^ - In paragraph 2.2. sprav asbestos for insulation and fireproofing should be added as this is discharged directly from a hose to the atmosphere. Contractors sometimes do this work at Plant sites and adequate isolation of the area is advisable. J. a . SIGMAN. COMMENTS BY 0. B. KIRKPATRICK (CON'T.) COMMENT NO. - 2.2'o - "pening boxes of new Insulation" should read, wOpening boxes and stocking bins from new boxes of insulation". Old Hickory has made repeated sampling testa of this bin stocking operation and found them over TLV limits. Our safety rules are being changed to include this operation where dust respirators will be w orn. COMMENT NO. 55 - 3*1 - This may have to be rewritten to harmonize with comments above for 2.2b. COMMON? K'Q. 36 - Duct respirators are to be worn anyway when removing insulation (2.2c J. J. a . COMMENT BY P. E. M. S05KS - TEX. FIB. - DORDRECHT COMMENT NO. 57 - Change point 3.1.4 as follows: ''laze coating on block insulation reduces asbestos as a potential dust source" . Available or not available is of minor importance here. COMMENT NO. 33 - Add to 3-2.2: "Consideration also must be given to exposure of other personnel working in the area who are not directly involved. The same warning has been given in point 3.4.2. To our opinion, it applies here, too. J. a . q I g m a ;-;, c o m m e n t b y u . a. c l a r k (c o n / t .) COMMENT NO. - 3.1.5 - Do not agree - lise of vacuum cleaner to clear, up workbench. Ose of plastic bag okay, but question value of wetting bag unless done continually. This is not practical. J. A. s IO.Va .,. COMMENTS LY ?. F. PHILYA'* (CON'T.) COMMENT NO. 60 - 3.2.1 -Asbestos oust coes not precipitate readily i. cyclone collectors. A bag filter for asbestos dust shoula be require j. a . m . m a r t i n (c c n 't .) cCKKENTrT... o- - Prefer to wear protective equipment when stripping insulation rather than wetting so that insulation can be reuseu. J A j !ji'--.1 CC'J CJRKsi;? n .,. O - 3.-5 - we are not using a plastic bag cr wettir scrap because of slipping hazards and housekeeping problems that '.vOUcreate :. '..e ire uentlv brush waste from table'top into paper art posai and to net filow accumulations to build up. DUP 0902737 DRM0000080 b .L . 4013 11/8/71 - 9- June 13, 1972 J. A. SIGMAN, COMMENT BY A. PASTSCH (CON'T.) COMMENT Ko. >3 - 3 .1 .$, 3.4.1 - Dust should be eliminated through vacuum system. Wetting seems not to be successful because fine dust cannot be absorbed through water and will reduce the effect of the cyclone. COMMENT NO. 64 - 3.2.1, 3.4.1 - Dust should not be wetted (see 3.1.5). Dust collecting bag should be closed and thrown away. Vacuum system should be designed for using one-way bags. R. F. STEWART. COMMENT BY E. B. HALL - DESIGN - LOCVIERS COtoHNi Ko. 65 - uggest paragraph 3.1.3 be reworded as below in order to effect parallel construction and improve clarity*. "3.J..3 - Asbestos insulation blocks should be handled with care. If dust cannot be removed by vacuum, respiratory protective equipment oust be used*. W. H. MC COY, COMMENT BY W. 0. CHRISTY (CON'T.) COMMENT No. oo - 3.2.1 - Experience with cyclone collectors for asbestos indicates they are inefficient and in some instances cause atmospheric pollution. COMMENT NO. 67 - Air sampling will not control dust. Air samples shbuld be taken to document the adequacy of controls (3.2.4). COMMENT NO. 68 - 5.1 - Recommend addition of: "and should be disinfected after earn use". (See 32H). COMMENT NO. 69 - 5.2 - Recommend addition of: "wear respirator when removing dusty clothing" . REPLY TO COMMENTS 53-69 - The standard will be revised as suggested. R. D. CARLTON, COMMENT BY J. A. FLATTMANN - BIQCHSMICAL5 - GRAbSELLI P U N T cflMMnhTlir tip. 70 - Will probably have to incorporate some of this into Plant safety Instruction. COMMENT NO. 71 - If this comes under Q3HA, we will also have to cover in arrangements with insulating contractors. J. A. oISMAN. COMMENT BY J . M. MARTIN (CONTT.) COMMENT NO. 72 - hot necessary to wet insulation when emptying cyclones if dischargee into a plastic bag and sealed. J . A b i O ^ K . CQ ^ S N T SY W. M. READING (CC-N'T.) COMMENt iC. -3 - 3.1.2 - Insulation is liftes from boxes and cartons put in trasr uumpster, COMMENT NO. 71 - 3.2.3 - The ledges, lights, inside of storage bins are cleaned on a weekly schedule. Other parts of work area are cleanse daily or more frequently. DUP 0902738 DRM0000081 S .L . 4013 11/8/71 10 - June 13, 1972 COMMENT NO. 7$ - 3-2.4 - We are using Mine Safety air sampling pump with the Millipore filter type Aerosol Cat. MAWG037A0 pore size .8. The pump is battery powered. COMMENT NO. 76 - 3.3.1 - We are using Eagle-Picker Super 66 which conforms to Commercial Standard C.S. 117-49 issued by U.S.D.C. COMMENT NO. 77 - 3.4.2 - We are barricading the work area to keep people out. a certain amount of dust inevitably drifts outside of the roped off enclosure. Infrequent large removals have created considerable dust at times. CO*' ENT NO. 78 - 3*4-3 - We are putting our scrap insulation in boxes and cans but not wetting it down, nor do we believe it necessary to do so. COMMENT NO. 79 - 5.2 - The men wear coveralls when working; however, nothing is being done to keep them free of dust other than a brushing off from time to time. The statement is ambiguous. COMMENT NO. 30 - 6.1.3 - Samples are sent to Felix Stein, Department of Occupational Health, University of Pittsburgh. J. A. 0IGMA.N. COMMENT BY A. PAETSCH (CON'T.) COm Me Nt NO. SI - .4 - Sample for asbestos fiber analysis may be obtained by using an instrument as it is used by German authorities (Staubforschungsinstitut), i.g., Konimeter. COMMENT NO. 82 - 3.2.1, 3*4.1 - Working area should have a little vacuum in order to keep the adjointed areas free of dust. COMMENT NO. 83 - 3.2.1, 3.4.1 - Exhaust system should have provision of keeping work place free of dust. COMMENT NO. 4 - 3.3.2 - Not possible because the whole quantity cannot be used at any time. H. H. KOHL. CONMSNT BT W. H. THOMPSON - Ffc ? - PAELIN PLANT COMMENT NO. 5 - This is not necessarily good measurement on the Plant level in as much as this standard will probably form the basis for Plant standard Practices or Standard Operating Procedures, which will take precedence from then on. Without a standard on this subject, local practices will vary from no protection to unnecessarily involved protection. This looks like an excellent guide from the Plant standpoint. W. K. KC COY. COMMENTS BY W- 0. CHRISTY (CON1!.) C0MM5NlrT.u. id - 3.1-4 - Glaze-coatea insulation is satisfactoiy until the coating is penetrated by cutting blocks. COMMENT NO. 37 - 3-2-3 - "Avoid sleeping" - this shouldbe a positive rule. Co not sweep. DUP 0902739 DRM0000082 S.L. 4013 11/8/71 - 11 - June 13, 1972 COMKbNT N O . S3 - 3.3.3 - Respiratory protective equipment should be worn when disposing of old asbestos cement. REPLY TO COMMENTS 70-88 - Your' comments are appreciated. Mo action is required. Sixteen Engineering Standards Committee members advise an estimated total of 245 uses for this standard as reference per year. In the absence of additional comments, which should be received by July 6, 1972, this standard will be issued with the revisions shown above. DESIGN DIVISION Standards Section CEM:kjk C. E. Marsh Senior Standards Engineer DUP 0902740 DRM0000083