Document 8OR7xKLJp9aMRZRR74knxrbea

1331 Pennsylvania Avenue. N W Washington. D C. 200G-4 202737-6330 ST007 I 290 EHl Organization Resources M Counselors* Inc February 27, 1987 Memorandum To: ORC Asbestos Task Force From: Darrell K. Mattheis and Rebecca L. Daiss Subject: Report of February 17 and 18, 1986 Asbestos Task Force Meetings The two Asbestos Task Force subgroups - the chemical and petrochemical group, and the telecommunications and utilities group - which met on February 17, and 18 will combine to form a single Asbestos Data Collection Task Force. The next meeting of the combined task force will be on March 10, 1987 at ORC's Washington Office, beginning at 9:30 a.m. and continuing until approximately 3:00 p.m. Please return the attached sign-up sheet if you plan to attend. Report of the February 17 Meeting Purpose Presently under OSHA's asbestos standard, employers performing small, short duration jobs, potentially involving asbestos containing material, are required to monitor for asbestos even though, based on expertise and past experience, the employer is confident that asbestos is not present above the action level. The cost of monitoring every job is unacceptably high. OSHA has provided an alternative to monitoring within the standard, however. OSHA will accept an employers decision that monitoring is not necessary if he is able to provide OSHA with data which supports that decision. Such a data base does not presently exist. The purpose of this task force was to first determine whether the establishment of a data base is feasible, whether it is worth the time, effort, and expense involved, and if so, to determine the means of creating a reliable data base. It was agreed that, although such an undertaking will be costly and time consuming initially, the savings in the long run afforded by a sound, comprehensive data base, will far outweigh the initial costs. 377858 ST007I 29 I 2- - Discission Because the manner in which asbestos is encountered varies so greatly from industry to industry and from job to job, the estab lishment of a representative data base will be a complex task. A determined effort will have to be made to standardize, to the extent possible, every aspect of the effort - collection, compilation, and analysis of the relevant data. The group broke the task down into its primary parts and then prioritized them as follows: 1. Develop Data Collection Form 2. Establish Collection Methodology, i.e., sampling methods, quality assurance controls, etc. 3. Establish 3rd Party Monitoring Program 4. Determine Vehicle for Compilation, Entry, and Analysis of Retrieval Data Collection Form The task force spent the remainder of the meeting developing the format of a survey questionnaire designed to collect information on typical asbestos exposures of employees in the chemical/ petrochemical, and telecommunications/utility industries. It is important that the survey be brief and as simply designed as possible to ensure participation, and at the same time elicit all of the necessary information in a quantifiable, analyzable form. A long and complicated survey which involves too much time and effort to complete is likely to either be ignored or returned incomplete. A preliminary draft of what the task force narrowed down as information vital to the establishment of an effective data base is attached (attachment 1). Questions 4-8 of the attached form are specific to the chemical and petrochemical industry. The jobs performed by the chem/petrochem and telecom/utility industries differ to the extent that the information requested in this segment cannot be standardized to pertain to both. Questions specific to the jobs done in the telecommunications and utilities industries will have to be formed and the survey will have to tree into separate sections for the two types of industry. The first part of the survey, however, is applicable industry wide. The quality of the results of the survey depends as much on how data is collected as on what data is requested. The survey must be specific as to the units of measurement, collection methods, and sampling techniques. Unless these are standardized, the data will be useless. The difficulty in standardizing collection 377859 ST007I 292 -3- methoas lies in the need to be flexible enough to allow for use of different techniques already being applied, but rigid enough to ensure that the data collected in numerous industrial settings can be combined into a single set of data for purposes of analysis. The form produced at the meeting does not address the specifics of collection techniques and methodology. The precise parameters of those items involving data collection have yet to be determined and defined. Specifically: o The information which should be included in the sequence identifier will have to be determined. o Job categories will have to be standardized. o The parameters of sampling methods will have to be standardized: The specifics of personal sampling i.e., the sampling methods which deal most effectively with the problems of obtaining statistically interpretable data from short duration, low fiber concentration jobs, will have to be determined and precisely defined in the survey. One of the critical problems of any data collection effort for asbestos, is the necessity to pull enough air through your filter to assure a representative sample. If a job only lasts 15 minutes, it will be difficult to pull enough air to allow a reliable limit of detection below 0.1 f/cc on an 8 hour TWA. One suggestion was to start the pump when the installer leaves his/her vehicle, and stop it when they get back in. There are many problems with this approach, but we do need to come with a satisfactory solution to this limiting factor. One suggested approach is as follows: "For personal sampling, monitor at a flow rate of 2.0 liters/min. Monitor the amount of air necessary to allow for a reliable limit of detection below 0.1 f/cc on a TWA of 8 hours. Request that the cassette samples be analyzed by the laboratory in the following manner:" Analyze using the NIOSH Method 7400. If results are at or above 0.1 F/cc do confirmatory analysis using scanning electron microscopy, (SEM)." Thanks to Kent Kunce for the above suggested approach. Mr. Kunce has also kindly made available to the task force, the "Air Monitoring Attachment 1, Required Air Volumes," which is attached to this report (attachment 2). 377860 ST007I293 -4- o Quality assurance controls will have to be specified. o Bulk sampling categories of asbestos type, and ranges for amount of asbestos present, have to be set. o Units of measurement and measuring techniques will have to be specified. o Requirements for 3rd party monitoring as a-means of validating the results of the survey will have to be determined. Steve Dixon, Dupont and R. Wolfe Wagner, ICI Americas, and Ann Venetta, AT&T and Jim Degan, Nynex, volunteered to refine and expand upon the attached draft as discussed above for the chemical /petrochem and telecom/utilities industries respectively. Attached for review prior to the March 11 meeting is a copy of the form for recording the asbestos exposure data which Steve Dixon and Wolfe Wagner developed and which has already been sent out to the task force by facsimile transmittal to those who attended the meetings on the 17 and 18 (attachment 3). It is hoped that that form will be submitted to statisticians and industrial hygienists within each company for review and comment prior to the March 10 meeting. Input from statisticians is essential to ensure that the data produced can be statistically interpreted and analyzed. Each company will have to determine internally the number of samples needed to produce statistically significant data. That draft will be reviewed and revised as necessary at the March 11 task force meeting. Representatives from OSHA will be attending the morning session of the Marqh 10 meeting and can comment on the needs of the survey from the Agency's perspective. Purpose of the March 11 Task Force Meeting 1. To review, revise, and refine the format of the data collection survey. 2. To agree upon and standardize specific methods and techniques of data collection. 3. To determine the best route for compilation and analysis of the data retrieved from the survey. 4. To determine the estimated cost of the entire survey effort and decide how the effort is to be paid for. 377861 *16Z I LOO IS -5- Report of the February 18 Task Force Meeting Purpose This meeting was to provide a forum to examine the problems facing the telecommunication and utilities employers in particular in complying with the OSHA Asbestos Standards and develop recom mendations for OSKA. Specifically the group discussed the difficulty of meeting requirements for monitoring, showers, protective equipment, and the determination of the presence of asbestos. Conclusions Determine The Economic Costs of OSHA's Asbestos Standards The task force concluded that it should examine the feasibility of collecting economic data on the costs of compliance with the OSHA Asbestos Standards. OSHA did a poor job of costing out the impact of the asbestos standard on the telecommunications and utilities industries. This information would be useful in dealing with OSHA and enlisting the aid of OMB. For instance, what would be the costs to the telecommunications and utility industries of giving every employee who MIGHT be exposed to asbestos the physical examination required by the construction standard? What would the cost be if in fact these industries attempted to monitor each and every job? What would the economic consequences be of attempting to make showers available for every employee who might be exposed to asbestos as is required by the construction standard? Consider Legislative Action as an Alternative The most cost effective approach to achieving compliance with OSHA's Construction Asbestos Standard may be to push for national legislation to force building owners to inform all tenants of the presence of asbestos. Such legislation would render a lease legally null and void if the owner/landlord does not inform, in writing, the tenant of the presence or absence of asbestos in the building and the space being leased. We will discuss this further at the next meeting. For The Next Meeting Before we decide to try to collect costs, we must determine how much data is available and how hard it will be to collect. The Task Force should be prepared at the March 10, 1987 task force meeting to answer the following questions: 377862 ST007 I 295 -o- * What should we look at? * How can we get at it? * Examples of questions to be considered: 1. Job shifting; 2. the liability issue on less than total compliance with the OSHA Asbestos Standards; 3. Shower availability; 4. Costs of monitoring every job; Discussion On many of the jobs where telephone installers operate, the customers lease the space and do not know if asbestos is present or not. Some telephone companies are asking the customer for a certification that the premises are asbestos free before they will begin a job. If asbestos is present, they look for an alternate route, or ask the customer to remove the asbestos. If the customer will not do it, they do not do the job. This costs a company a certain number of jobs every year. Many times, the customer when faced with the situation discussed above, will turn to "mom & pop" companies who will come in and do the installation with no questions asked, no protective equipment used, and at a cheaper price. OSHA needs to be pushed hard on this issue because this job shifting is forcing companies with well organized safety & health programs out of this area. At the same time it is bringing in an influx of small installers who lack safety & health training and protective equipment, as well as any incentives to get either! The telecommunications companies are being forced to confront the question of "Do we really want or need this business?" One must make a decision, for a job is either asbestos free, or it is over the line! We must ask the question, using historical data, are you willing to accept the statistical risk of finding asbestos where you do not expect it? Most answer NO! Most organizations would rather rely on good work practices if at all possible, rather than protective equipment. If you open the ceiling and find asbestos, then you do not do the job. The problem is that after you have opened the ceiling tile, what kind of exposure did your employee receive? 377863 S T 0 0 7 1296 -7- The point that we have to make, regardless of what the data shows, is that a broad interpretation of "representative" sampling is necessary because of the diversity of jobs. If the data shows fairly consistent levels of exposure, then we need to rely upon it. We may not like what we find, because in the past we have often looked at best case situations. What do we do about PPE while monitoring is being done? The unions will push for PPE if you are sampling for asbestos exposure!! If employees are given a respirator to wear while monitoring, then they must all receive medical surveillance. One company's approach is to have all people given medical exams if there is any possibility that they may be exposed. Some organizations have attempted to use the Racal PAPR system, but that causes a problem with the customers employees as soon as it is seen! What we may need to consider is national legislation to force building owners to determine if their buildings have asbestos, and then inform their tenants. One might word legislation such that a lease would legally be null and void if the building owner or landlord did not inform the leasing company of the presence or absence of asbestos. OSHA's asbestos standards are forcing companies with good S & H programs to set such high requirements before they are willing to do the job, that customers are turning to "mom & pop " shops. Thus, OSHA is causing more exposures to more people in this business than before the standard. If a company did try to conform to the monitoring requirements of the OSHA standards, there are simply not enough industrial hygienists available in the country to do all of the monitoring, or enough analytical capacity to handle the number of samples. Most companies are already losing money on telecommunications installation, and to be forced to go into an expensive protective program may just force a lot of companies out of the business. An important question is, can we collect accurate data to demonstrate what the OSHA asbestos standards are doing to costs and job shifting? If we can collect this information in a credible way, we would have a solid case to make in discussions with OSHA or OMB. To deal with the monitoring requirements of the construction standard, we will have to rely on our data base, training, work practices and recordkeeping. What we need to do then is to collect the economic cost data on doing installations, giving medical examinations to all installers, job shifting, and monitoring. 377864 ST007I 297 Protective clothing is not a good solution unless you know from the start that there is asbestos in a particular building. The problems raised when customers- employees see telephone installers in protective equipment and respirators can be difficult to deal with, and potentially expensive. Wearing protective clothing is expensive also, and installers would have to change before each job, wasting more time and money. It usually takes 4 suits/worker/day for an 8 hour- removal job. Also on costing such a job, you must include having someone stationed outside the enclosure to hand tools etc., in to the workers. Showers must be available when a removal job is being done for the practical reason that if it is a big job, asbestos often gets down the inside of the protective suit because the neck joint is not snug enough. In the telecommunications and utility industries, virtually no one has showers available. If they had to use portable showers, you are speaking of a special vehicle costing in the range of 50100,000 dollars each. To have showers you must have water, both carrying and holding tanks, driver, etc. One approach may be to have sales people make the determination of the presence or absence of asbestos. The bottom line is that we cannot, really, in good faith ask OSHA to allow us out of the shower requirement. The requirements of the standard essentially tie OSHA's hands. Industry must simply make its own best judgement about what must be done, do it, and defend it on that basis. Consequently, following this lengthy discussion of the problems in terms of cost, time, etc. which compliance involves, the group decided that the data collection effort provided the most effective, least costly, avenue of compliance. Until it can present OSHA with data which shows that the level of asbestos to which a typical telecom/utility industry employee is exposed is not significant enough to subject those jobs to full extent of the standard, that industry is not in a position to ask OSHA to relax or alter requirements of the standard. Consequently, until a reliable data base is established, the only alternative available to industry is to take a conservative approach; assume asbestos is present when its presence or absence is unknown and implement fully the requirements of the standard. Under this approach, the cost of a job will increase significantly and jobs, where the owner of the site is unable or unwilling to cover the-added cost, may have to be rejected. We have attached copies of flow charts provided by Dean Chapell, GTE, and Andy Shapiro, U.S. West Information Systems, which delineate alternatives for dealing with OSHA's Asbestos Standard in the telecommunications industry (attachment 4) . BD/l 377865 ST007I 298 DRAFT 2/17/87 Attachment 1 ASBESTOS DATA COLLECTION FORM 1. Sequence Identifier (Date'/location/etc.) 2. Job Assignment (Maintenance, etc.) 3. Sampling Data a. Duration b. Concentration c. Type of sample 1. Personnel 2. Area d. Sampling done 1. In house 2. By contractor 3. By 3rd Party 4. Substance Monitored a. bulk sample analysis; 1. % asbestos: less than 10% - 10% to 50% - 50% to 100% 2. Type: roofing/cement/insulation/gasket/tiles/ transite etc.) b. Identify control interference (other fibers present) c. Condition of use - use EPA standard definitions 6. Process description / Work practices a. Negative pressure enclosure or not b. Glove bags c. Wet methods (yes or no) d. Small enclosure (as distinct from glove bag job) e. Amount (volume depending on job type) 1. cubic feet 2. square feet 3 . linear feet f. Duration of job 7. Task 1. Set up 2. Remove cover 3. Remove insulation 4. Clean up 5. Supervising 6. Spraying (water) 7. Ceiling removal 8. Non Removal Tasks 1-8 a. Tools used in task (power tools etc.) 1-8 b. Environmental conditions 1. inside/outside 2. wind 3. temperature 8. Unusual occurances (upsets/unplanned events) 377866 Attachment 2 ST007I 299 AIR MONITORING ATTACHMENT 2 REQUIRED AIR VOLUMES A. An adequate air volume is an essential part of obtaining meaningful sample results. B. The air volume required for acceptable sample accuracy is influenced by the legal or recommended standards to which the results will be compared and by the microscope used by the analyzing laboratory. C. The formula which is used in NIQ5H Method PCM239 and 7400 follows: Fibers/cc = (A) (100B) (T) (FR) (MFA) where F B is is the the number number of of fibers fibers counted: n in the blank:J F- B* n is the number of fields counted; = foo A is the effective collection area of the filter; T is the time sampled in minutes; FR is the flow rate of the pump; MFA is the microscopic field area. For a 37mm filter, A = 855. For a 25mm filter, A * 385. The MPA can vary from microscope to microscope. from 0.0030 to 0.0080. If Method 7400 is used, the MFA must be 0.00785. It usually ranges D. The lower limit of detection of the NIOSH method requires that at least 10 fiberB be counted in order to determine an exact fiber con centration. Otherwise, a "less than" assignment must be given to the results. __ ^*** ihii i (L*z)/)) Loo * LitrJ! 377867 13-6 SICNMUIE/TITLE OF PEftSON FILLING OUT FOfIM |V w N588S8822S2 ?$ f * : 1 U *3Cy- fy%t ^ oC (A 13 5<* *10 o3 ST S3 r ? 3 mR 2 s y fts* . s ro3ft rftr H e * (ft > s 7?I5ft- ic3 ?cr -*y*i --%" ST 3* --i ^ sr w rl fO&t. -- -- -- --ft rv 1$ .o3 ;.--o3 :t_* ?y> 23. tO Ci ro% *(A R--# X<<1L-' 3. o- 0 ^n <g x oI ^ - -- C f3 X3 377868 f# C c3" f jt<r <* yfy yft y fot r o o ns y ft yi n C * r 3 C r3 fOt** oCD CJ oo ox e O' % JC jr <* 1l I <: __* i: ST007I 30 I I-- J' INSTRUCTIONS FOR FILLING OUT FORM (to be on reverse side of form) A. BACKGROUND INFORMATION 1. Form of Asbestos Containing Materlal(s) Being Worked With What Is the type of asbestos material being removed/disturbed? 2. Method to Control Asbestos Exposure What Is the type of method(s) used to minimize the asbestos exposure? 3. Work Done Indoors or Outdoors Was the asbestos removal/disturbance done Inside a building or outdoors? 4. Percent Asbestos In Material Check the appropriate box If a bulk sample of the asbestos material has been analyzed for asbestos content. 5. Are Other Fibrous Materials Present Other fibers such as fiberglass, paper, and rock wool will be counted as fibers by the NIOSH/OSHA analytical method. 6. Asbestos Samp!Inq/Analvtlcal Method The NIOSH Method 7400 and the OSHA Appendix A method both all for the use of 25 mm filter cassettes, sampling cowls, and specific counting techniques. Please specify any modifications made to the method. B. AIR SAMPLING DATA 1. Date - enter month and day 2. Worker or Area Number Each person or area should be assigned a unique number. More than one sample can be taken on one person or In one area. 3. Pump Flowrate The pump flowrate should be the averaged flowrate as determined by calibration with a primary standard such as a bubble tube. i. 377869 ST007I 302 2- - 4. Sample Duration The duration of time for the sample. 5. Fiber Concentration } I The fiber concentration (fibers per cc) as determined from the laboratory analysis. Use "GT" and "LT" for "greater than" and "less than' (respectively). If the sample filter Is overloaded, note GT before the result. 6. Estimated 8 hour Time Weighted Average (TWA) If more than one sample was taken on a person during a shift, a time weighted average should be calculated using the below formula: gill .2--l2--.cnln Tj + T2 + ... Tn Cn = the fiber concentration for sample n Tn = the sample duration for sample n 7. Amount of Time Spent Working with Asbestos During the time of the sample, estimate the amount of time the worker was exposed to asbestos. Do not Include preparation and clean-up time. 8. Specific Activities Insert the code(s) for the specific activlty(s) of the person during the period of the sample. A = Operator performing task with direct exposure to asbestos B = Supervising task C = Operating sprayer D = Onlooker (no direct exposure) E = Monitoring exposure F = Clean-up G = Set-up H = "throwing" electrical or telephone cables above false ceiling 9. Upset Conditions Was there a greater than normal exposure to asbestos due to an unplanned event. Specify event in the comments section. 377870 'r -3 - i i i 10. Amount of Asbestos Removed For the time period sampled, estimate the amount of asbestos removed In cubic feet (length x width x thickness). For pipe Insulation, specify the pipe diameter and length of pipe Insulation removed. 11. Comments Specify any upset conditions, sampling pump malfunctions or other unusual events. RWW/tlb/870220 ST007 I 303 377871 0-1 S T 0 0 7 I3 0 4 DECISION TREE TOR OPERATIONS WITH ASIIESTOS IN BUILOINGS USUIS N o tifie s Hu I Id In.j Ownor/Manager about Asbestos Work SI 007 I 305 STEP 1 2 3 4 DESCRIPTION OF STEPS IN DECISION TREE FOR OPERATIONS IN BUILDINGS Operations Receives Work Order or Equivalent The contract will contain a clause explaining the necessity for customer and U S WEST Information Systems to adhere to Health and Safety Rules and Regulations including OSHA Asbestos Regulations in the performance of work. Does Building Owner/Manager (BOM.) Certify Asbestos-Free Environment U S WEST Information Systems is obligated to follow OSHA Asbestos regulations; it must know if asbestos is present. U S WEST Information Systems representative will query customer for responsible party to approach for certification of asbestos presence or absence. If asbestos is not present, a certification will be issued by the BOM to this effect and work should proceed. If the BOM will not or cannot issue a certification that environment is asbestos-free, asbestos could be present and the BOM may or may not know this. Does BOM have an Operations and Maintenance Plan? If the BOM knows asbestos is present and has an Operations and Maintenance plan for asbestos, U S WEST Information Systems will adhere to its own procedures and the BOM plan. Determining If Asbestos Is Present If the BOM does not know if asbestos is present, the U S WEST Information Systems representative will contact a qualified contractor (see list) to obtain small bulk samples of the possible asbestos containing materials (ACM) for analysis to determine if asbestos is present (when suggested contract language is used, cost of this work will be borne by customer). If laboratory results of bulk sample analysis indicate no asbestos, work will-proceed without any asbestos precautions. If asbestos is present, U S WEST Information Systems and the customer will seek an alternate route, etc. 377873 STEP 5 6 7 8 9 ' Is an Alternate Route-Available? If an alternate route is available, proceed with the work. If an alternate route is not available, determine if the customer/BOM will remove the asbestos prior to U 5 WEST Information Systems installation/maintenance. Customer Removes Asbestos If the asbestos is removed and the work area is certified for reoccupancy, U S WEST Information Systems will proceed with the work. USKIS Performs Work in Accordance with OSHA Regulations If the customer chooses not to remove the asbestos, U S WEST Information Systems will perform the work in accordance with OSHA regulations for asbestos work, at the customers expense when contract language is used. BDM Notification Concerning Asbestos Work U S WEST Information Systems will also formally notify the customer/BOH/our contractors of the nature of the work to be performed in so far as asbestos is involved. Suspected ACM Is Discovered In the case of discovering possible ACM after BOM certification that asbestos is not present, U S WEST Information Systems will obtain bulk samples of the suspect material, arrange for analysis and proceed from Step 4 of the decision tree. ST007 I 306 377874 ST0Q7 I 307 ATERNATIVES FOR DEALING WITH OSHA'S ASBESTOS SI IN TEUETHQNE EQUIPMENT INSTALLATION JOBS f c 1 ST007I 308 ALTERATIVE 1. DEVELOP REPRESENTATIVE DATA BASE; EXPOSURES ABOYE THE ACTION LEYEL NOT FOUND; DO NOT IDENTIFY IF ASBESTOS IS PRESENT proceed with all jobs as usual (no protection) Positives Have sound rationale for decision Can Infora employees that the hazard Is alnlnal Negatives Not easy to Identify enough jobs proximate to asbestos to obtain a "representati ve" data base. Need to do a lot of air samples Not easy to convince regulators that we have a representative data base In the event of employee suit, not easy to convince legal system our data base is representative No protection from theory which states that asbestos disease can be caused by a single fiber ALTERNATIVE 2. DEVELOP REPRESENTATIVE DATA BASE; EXPOSURES ABOYE THE ACTION LEVEL NOT FOUND; IDENTIFY IF ASBESTOS IS PRESENT If asbestos is present provide partial protection If asbestos is not present proceed with job as usual Positives Have sound rationale for decision Can inform employees that the hazard is virtually non-existant Provides additional protection from theory which states that asbestos disease can be caused by a single fiber Negatives Not easy to Identify enough jobs proximate to asbestos to obtain a `representative* data base. Need to do a lot of air sables Assuring employee compliance with protective measures may be difficult Depending on protective measures chosen, oay present relations problems with customer employees Need to determine if asbestos is present on customer premeses. Could lose business simply by asking the customer (regardless of whether asbestos is actually present) 377876 ALTERNATIVE 3: EXPOSURES ABOVE THE ACTION LEVEL FOUND; IDENTIFY IF ASBESTOS IS PRESENT If asbestos is present, provide full protection If asbestos is not present, proceed with Job Positives Employees are protected from asbestos Negatives Protection is costly Assuring employee compliance with protective measures may be difficult Need to determine if asbestos is present on customer premeses. Could lose business simply by asking the customer (regardless of whether asbestos is actually present) If protection is provided without a sufficient data base, risk OSHA citation for not conducting initial wonitoring (by providing the protection we are admitting that It is an asbestos job) May present relations problems with customer employees seeing our employees in respirators and disposable clothing ALTERNATIVE 4 EXPOSURES ABOYE THE ACTION LEVEL FOUND; IDENTIFY IF ASBESTOS IS PRESENT if asbestos is present, refuse job if asbestos is not present, proceed with job Positives Virtually eliminates liability (our employees or customer employees) and compliance problems Negatives May lose business unnecessarily because employee exposures on this job may actually be low or non-existant Need to determine if asbestos is present on customer preoeses. Could lose business simply by asking the customer (regardless of whether asbestos is actually present) May not be possible to refuse certain asbestos Jobs ST007I 309 377877 ST007I 3 I 0 ALTERNATIVE 5 EXPOSURES BELOW THE ACTION LEVEL EXPECTED (WT PROVEN), IDENTIFY IF ASBESTOS IS PRESENT If asbestos Is present, provide full protection If asbestos Is not present, proceed with jab Positives Employees are well protected from ar\y potential asbestos ensure Negatives K*y be overkill and result In unnecessary employee concern. Protection Is costly Assuring employee compliance with protective measures Is di^icult Need to determine if asbestos Is present on custoner premess. Could lose business simply by asking the customer (regardless of whether asbestos is actually present) If protection is provided without a sufficient data base, OSHA citation for not conducting Initial monitoring (b* provldirc the protection we are admitting that it is an asbestos job) Kay present relations problems with customer employees seeing our employees in respirators and disposable clothing ALTERNATIVE 6: EXPOSURES BELOW THE ACTION LEVEL EXPECTED (1CT PROVEN!. IDENTIFY IF ASBESTOS IS PRESENT If asbestos is present, refuse job if asbestos is not present, proceed as usial Positives Virtually eliminates liability or compliance problems Negatives Kay lose business unnecessarily because employee sposures y actually be low or non-exlstant Need to determine If asbestos Is present on custoaer premess. Could lose business simply by asking the customer (regardless of whether asbestos is actually present) 377878 ALTERNATIVE 7: EXPOSURES BELOW THE ACTION LEVEL EXPECTED (WOT PROYENJ; DO NOT IDENTIFY IF ASBESTOS IS PRESENT proceed with alT jobs as usual Positives Except for failure to comply with the reouire*ent for Initial eonitoring, puts burden on OSHA to show non-cc*pHance . Negatives Risk causing employee disease and/or employee suits Risk severe OSHA penalties if asbestos exposures above the PEL are found 1948p Csy* 0 O U/lo m A-f bu stMvi tuQ d UA -hCji Jan d ~}~0 -hojht- *5 touj -IA b ------ Us^Jd ST0 0 7 1311 i^ooJ <2 --^o u /J d> <-A- & /d<2 & d fa v4iU-L*SL ft duu^-of ^ Uru 377879 ST007 I 3 I 2 To: JUx Asbestos Air Monitoring The recently promulgated OSHA Asbestos Standard (1926.58) reoulres Initial air monitoring at each asbestos job or. In lieu of performing it at each Job, "representative" monitoring may be conducted. Also, the need to comply with virtually all of the other reoulrements of this standard Is based upon the results of air monitoring. Given the numerous worksites In which our employees may potentially come into proximity with asbestos on customer premises and other locations, initial monitoring at every jobsite Is not practical. As a result, we need to develop a data base which can help us to comply with the monitoring reouirement and to determine whether or not we need to Institute any new protective measures. Therefore, we are reouestlng that you arrange for NATLSCO to perform Industrial hygiene surveys at eight separate asbestos-related jobsites. We have attached a copy of the guidelines provided to NATLSCO for the conduct of these surveys. For scheduling contact John Garis at 312/540-2026. The following monitoring Is reauested: Four surveys - Equipment Installers working on customer premises Two surveys - Central Office Eaulpment Installers working on GTE premises With regards to the above, we are looking for significant Installation activities-Including running cables above suspended ceilings and in crawl spaces in and around asbestos fireproofing and construction materials. It Is not useful to sample short duration jobs as these will not be representative of the larger jobs where there may be a greater potential for asbestos exposure. You will have to work with your Service Departments to Identify well in advance customer locations where asbestos containing materials are present so that arrangements can be made for scheduling the Industrial Hygienist. 377880 Page 2 January 30, 1587 The following criteria may be helpful in starting to identify customer facilities which may contain ACM: o Buildings constructed prior to 1975 o Concrete or brick buildings with suspended ceilings o Metal buildings with exposed steel support beams and columns o Cable vaults and crawl spaces It will be necessary, of course, to ultimately confirm with the building owner that asbestos is present or take bulk samples prior to the Job. The NATLSCO lab can be used to perform the bulk sample analysis. The two other surveys we are reauesting are as follows: One survey - A brake or clutch repair/replacement job at a vehicle maintenance garage One survey - A repair or maintenance procedure utilizing a glove bag which Involves cutting or removing asbestos pipe insulation We are reouesting that all of these surveys be completed before July 1, 1987. We recognize the difficulties you may encounter In arranging for and conducting these surveys especially as It relates to those on customer premises. However, given the requirements of the OSHA standard, I don't see that we have any other choice. Please keep me advised of any problems which may be encountered in complying with this reauest and of any assistance you feel we can provide in resolving specific problems. Sincerely, Donald M. Espach Director-Employee Safety S T 0 0 7 1313 377881 ASBESTOS MONITORING GUIDELINES FOR GTE 'Da-M into " <11GI LOO IS In addition to the standard NATLSCO industrial hygiene reporting format, the following items must be included in all future industrial hygiene reports which contain air monitoring for asbestos. This information is critical In attempting to establish a "representative" data base for specific asbestos work operations. o Two general area samples should be taken outside the imnediate work area to identify any background asbestos fibers wfncn may be present in the facility. One should be taken at a distance of 10 feet and the other at 50 feet from the work area. o Each specific job must be fully described to include the tasks performed, the Quantity of work performed and the duration. For examples: cutting/sawing four 8" by 10" openings in ACM (1 hour) drilling fifteen holes in ACM floor tile (.5 hour) pulling cable in suspended ceiling containing ACM; placed approximately 25 feet of cable (2 hours) working in a cable vault/crawl space containing ACM; placed approximately 150 feet of cable (2.5 hours) o Each employee exposure must be shown as an 8 hour TWA. Sample "specific job tasks" which you feel may present potential problems. If the job is completed in less than 8 hours, sample for the remainder of the shift with a new filter to document the actual 8 hour TWA. o Describe the work procedures used such as enclosures, glovebags, wet-methods, HEPA vacuum. If PPE was used, list it, i.e. goggles, gloves, coveralls, PAPR-respirator, ventilation, etc. o Asbestos samples must be taken from the work area following SOP 3.12 Bulk Asbestos Sampling criteria. List the percentage and type of material found. o Comment on the friability and condition of the ACM using the following criteria: Condition: Friability: -- undamaged/intact -- damaged/deteriorating -- highly friable -- moderately friable -- not friable o The industrial hygienist should comment on any other items deemed appropriate and/or relevant. 377882 \)6THN 1919p Jo lI - 3^/2- ` ^7