Document 8VQ71EKearBQxd8JeG6jqOv6y

FRO! BROOKS PARKER ROCKDALE WORKS TO MR. T. B. BONNEY PITTSBURGH OFFICE 1982 December 22 RE: INDUSTRIAL HYGIENE AUDIT ROCKDALE WORKS 1983 JANUARY 18-20 Attached is a package of material containing: f Completed Plant Audit Evaluation worksheets f Works organization charts Membership lists for the Plant Safety and Health Steering Committee and the Plant Hazardous Materials Control Committee I A block diagram flow chart for the plant I A tentative schedule for conducting the audit Plant map After you've had an opportunity to look over the schedule, please get in touch with me so any changes you feel are necessary can be made early in January. more information, please let me know. EBP/mz Attachments cc: W. J. Drake G. H. Lantz A. G. Clayton W. T. Washam, M. D. GS ALCOA ARD 003590 $r-4963 (rev u.ee) INDUSTRIAL HYGIENE PLANT AUDIT EVALUATION WORKSHEETS 2r>rfr c (LOCATION) THESE WORKSHEETS SHOULD BE COMPLETED BY THE PLANT INDUSTRIAL HYGIENIST (OR PERSON RESPONSIBLE FOR I.H.) WELL IN ADVANCE OF THE PLANT VISIT -- AND RETURNED TO THE LEADER OF THE AUDIT TEAM. THE WORKSHEETS HAVE TWO OBJECTIVES: 1. TO ASSIST THE AUDIT TEAM IN PLANNING THE SITE VISIT. 2. TO PROVIDE THE PLANT WITH SOME IDEA OF THE SCOPE AND CONTENT OF THE AUDIT AND FORM A BASIS FOR DISCUSSIONS DURING THE AUDIT. THE PLANT INDUSTRIAL HYGIENIST (OR PERSON RESPONSIBLE FOR I.H.) IS EXPECTED TO SERVE AS A MEMBER OF THE AUDIT TEAM. THE AUDIT TEAM WILL EXPLORE HIS/HER FUNCTIONS, AS WELL AS ASSESS THE SUPPORT THEY RECEIVE IN CONDUCTING AN EFFECTIVE I.H. PROGRAM. THE QUESTIONS IN THESE WORKSHEETS ARE NOT MEANT TO BE ALL-INCLUSIVE; RATHER, THEY SERVE AS A STARTING PLACE FOR DISCUSSIONS DURING THE PLANT VISIT. /a-/s~ (DATE) ARD 003591 KEY ELEMENTS IN PLANT I.H. PROGRAMS * SECTION PAGE 1 - POLICIES & PROCEDURES............................................................................ 1 2 - ORGANIZATION & STAFFING...................................................................... 3 3 - FACILITIES & EQUIPMENT ...................................................................... 6 4 - WRITTEN I.H. PROGRAMS............................................................................ 8 5 - ENVIRONMENTAL MONITORING &SURVEILLANCE................................ 12 6 - RECORDKEEPING.................................................................................................. 16 7 - HEALTH HAZARD CONTROLS ...................................................................... 18 ^ 8 - HEALTH HAZARD TRAINING ........................................................................ 20 v' 9 - COMMUNICATIONS & COORDINATION..................................................... 22 10 - CHEMICAL CONTROL....................................................................................... 25 ARD 003592 1. POLICIES AND PROCEDURES The foundation for effective health protection management starts at the top... with the < Location Manager and his or her staff. Section 1 will explore the plant management's commitment to meeting the objectives of Industrial Hygiene. 0 What is the Location Manager's role? 0 Where and how are he and his staff involved? 0 What policies and procedures have been established? 0 What are the mechanisms for continuity of managing employee health protection? The effectiveness of any I.H. Program will be highly dependent upon the role of plant management. The following types of questions are a starting place to evaluate plant management's position. -1- ARD 003593 1. POLICIES AND PROCEDURES YES 1.1 Has an I.H. written policy been: Adopted? Published? Supplied in Orientation Literature? 1.2 Does the Location Manager participate (at least annually) in an I.H. tour of the facility? 1.3 1.4 Are potential health hazard problems discussed in Location Manager's staff meetings? Often ______ Rarely ______ Sometimes X Never ______ Don't Know ______ Is there a Joint Health & Safety Committee (Labor and Managsnent)? X. Y 1.5 1.6 1.7 Is I.H. represented as a member of the Joint Health & Safety Cenniittee? X xAre potential health hazards discussed? ' Often yC Rarely ______ Sometimes Never Don 11 Know Are results of personal exposure surveys provided to employyecces? XAlways Sometimes Never NO X -2- ARD 003594 2. ORGANIZATION AND STAFFING Discussion in this area is intended to determine if the I.H. organization and staffing are ** appropriate for the specific needs of the plant. Where I.H. responsibilities are divided, more detail as to the manner of this division will be sought. It is essential that those carrying out I.H. responsibilities be adequately trained. The Audit Team will not be looking for depth of training, per se, received by the hygienist and technician; rather, it will be matching the training received by the principals with the complexity and number of health problems at the specific plant location. There will be a considerable amount of discussion centered around the day-to-day activities of the I.H. Supervisor, who he deals with, and how he attains his objectives, through his own efforts and through cooperative ventures with other managers. The Audit Team will explore this area through discussion with the I.H. Supervisor and other appropriate managers throughout the plant. -3- "2. ORGANIZATION-AND STAFFING YES NO 2.1 - Does one individual have the clearly defined responsibility and accountability for I.H. activities? 2.2 - What are the I.H. Supervisor's qualifications? Professional Industrial Hygienist a-- .--M . X __________ SrTfO.. _ trC,K.) Gaj'/- Z./: v- v ov cz/tTA-f X Scientist or engineer, with some I.H. training 'x _ (Describe the type and source of training.) QE'T, Sc/-;; aJ A-& S, PcftZc Aj TVO / Primarily administrative Other -4- 2.3 - Are there plans for providing the I.H. Supervisor with basic or supplementary training? (If so, describe.) Pros Dev. czc/jr- r Cc- f?pc >6-rzr Se s 2.4 - Is I.H. Supervisor certified by ABIH? x 2.5 - Is I.H. Supervisor a member of AIHA? 2.6 - Does I.H. Supervisor periodically attend professional meetings? K._ ________ National ____ * Local Y Corporate-sponsored conferences y( 2.7 - Does the I.H. Supervisor have technician support? X 2.7.1 - Has the technician received training in I.H. monitoring and measuring? ^ /\ (If so, describe the type and source of training.) fij / hi / 2-0/ v E t-tt AJ fir TO A frUMOf-Z Cr-S/f-- (7&rW. SdZOC/CAjr s C 77/rr l> <S?~C . . C.c A'r` >- ' / 2.7.2 - Are there plans for basic or 7 (. supplementary training? X ________ (If so, describe.) fOJ TT/AJ//J/- prZceSrAM SET - > SC -4- C;_ ARD 003596 2. ORGANIZATION AND STAFFING (Cont.) YES 2.8 - Does the I.H. Supervisor have adequate time to devote to I.H.? 2.8.1 - What percent of his time is . devoted to I.H.? /y; - 3--6 2.9 - Does the I.H. Supervisor have direct access to all levels of plant management? 2.9.1 - Is this access frequently vised? 2.10- What is the I.H. Supervisor's perception of the visibility of I.H. in his plant within the organizational structure? More than adequate _______ Adequate yX. Less than adequate _______ \ Xx NO ARD 003597 3. I.H. FACILITIES AND EQUIPMENT An effective I.H. effort requires adequate facilities, sampling and measuring equipment, and laboratory analytical support. There should be sufficient office space and I.H. laboratory space for maintenance of sampling equipment. Methods and frequency of equipment calibration will be discussed. Plant or other laboratory analytical chemistry support will be reviewed. Decisions in I.H. matters are usually based upon or supported by sampling and analytical data. In Section 3, the Audit Team will assess the plant's I.H. and laboratory capabilities for assuring development of accurate, reliable, ' and credible data for sampling and chemical analysis. ARD 003598 _c_ 3. I.H. FACILITIES AND EQUIPMENT YES 3.1 - Is adequate I.H. work space available: Office? Storage? Laboratory? X. X-. NO 3.2 - Is the I.H. equipment inventory Xadequate to support program objectives? 3.3. 3.2.1 - Is equipment routinely calibrated and maintained? X_______ _______ (Comment on frequency and procedures for calibration.) ............. ........ As d '/ tt-rArc# /[->. C/Wr.ft (-'C J c./dB~C{<'a) >c.'A/aj6- X/r/X /And * Are I.H. samples analyzed at: ' y x'-x tt"./-: Plant laboratory (In-House) X ALCOA'S EHL (ATC) X /> ^/ Outside Laboratory (Independent) 3.3.1 -Are collected I.H. samples O refrigerated or otherwise properly stored and protected ' prior to analysis? 3.3.2 - If plant laboratory is utilized for analysis of I.H. samples, does the laboratory have the necessary: Physical Facilities for Trace Analysis? Instruments and Equipment? Trained Chemists and Technicians? X 3.4 Is there a documented analytical quality assurance program, and are quality control records properly maintained for all in-house analyses? _X 3.5 - Are approved analytical methods used for analyses? XALCOA'S EHL XNIOSH ASTM Other _______ 3.6 - If outside Laboratory is utilized for analysis of I.H. samples, is the laboratory AIHA accredited? (Comment an reason for outside laboratory analyses.) -7- ARD 003599 4. WRITTEN I.H. PROGRAM It is essential that each plant has a written program even if, in the case of the smaller *I plants, it entails only a page or two of written material. One of the more important reasons for having a written program is to enable the hygienist to manage his job... rather than have his job manage him. Without the guidelines provided by a written program, the hygienist will tend to operate in a "fire fighting" mode. Furthermore, a program in writing will assist the plant in maintaining a program that is both consistent and appropriate-, especially in the event of personnel changes. The Audit Team will explore in detail the contents of each facet of the I.H. Program. The primary thrust is to determine the adequacy of the written material for the specific plant needs. ARD 003600 -8- 4. WRITTEN I.H. PROGRAM 4.1 - Overall Program YES NO 4.1.1 -Are the contents of the plant's overall I.H. Program put into writing? 4.1.2 - If so, does this document include a statement of policy and objectives? 4.1.3 - A description of processes? 4.1.4 - An inventory of potential exposures? Including process materials? By-Products? Physical Hazards (Noise, Radiation, Etc.)? 4.1.5 - A list of job classifications? Including list of tasks each performs? Potential environmental exposures for each? 'JLt&Z C/OCE x_ x 4.1.6 - A record of hazardous materials training? 4.1.7 - A sampling schedule? 4.2 - Respirator Program ,v -X ft /< '7 /1 /r .'CO I to Detp-t ^4r-..v ASTC- 4.2.1 4.2.2 Is respiratory protection used in any area of the plant? If so, does a written program exist? X 4.2.3 Is respiratory protection mandatory where engineering controls are being instituted, or are not feasible, to ' control air contaminants to acceptable levels? 4.2.4 Is there a written Respiratory Protection Program which aims to fulfill the requiranents of 29 CFR 1910.134? -X 4.2.5 Is the responsibility for program administration clearly defined? X ARD 003601 -Y 4. WRITTEN I.H. PROGRAM (Cont.) 4.2 - Respirator Program (Cont.) YES NO 4.2.6 - Do written Standard Operating Procedures detailing selection and use of respirators exist? 4.2.7 Do SOP include a list of all jobs requiring respirator usage? ( 4.2.8 4.2.9 Is there a fit-testing program? (Describe type.) FT l C n-A-yivc F1f 7 7~ZZ ~r u tPHe.'jr /< VS GO. Are respirators adequately cleaned DisPcZf-cif-tr R.ez.f', and maintained, and are they inspected during cleaning? A/./h 4.2.10- Do respirator users receive medical approval, and is such approval documented -- and reviewed periodically? 4.2.11- Are all respirators NIOSH/MSHA approved and adequate for intended use? 4.2.12- Is program periodically evaluated to insure proper respirator use and continued effectiveness of program? 4.3 - Hearing Conservation Program 4.3.1 4.3.2 4.3.3 Are any employees exposed to noise levels equivalent to 85 dBA or higher for an 8-hr. exposure? X If so, does a Hearing Conservation Program exist? X If Hearing Conservation Program exists, is it in writing? X 4.3.4 Are hearing protectors mandatory where excessive exposures exist? X 4.3.5 - Is there enforcsnent of required hearing protection? 4.3.6 Are signs requiring hearing protection posted in areas requiring mandatory hearing protection? X -10- ARD 003602 WRITTEN IH. PROGRAM 4.4 - Other Programs YES 4.4.1 - Are tliere needs for other I.H. sub-programs in your plant (e.g., Urinary Fluoride, Ionizing Radiation, etc.)? ., /\ 4.4.2 - If so, name them: URlAJ ftfe '{ f~C VC ft f S? Uft 1/=V ft 116 aJ Bf\ p&o&Rft/ft ft TT Hi 7-tETft v- Bted/cft/- X ftft/ 4.4.3 - Are they in written form? 4.4.4 - Are they a part of the overall plant I.H. Program? \ 4 NO -11- ARD 003603 5. ENVIRONMENTAL MONITORING & SURVEILLANCE The foundation for evaluating potential I.H. problems is accurate environmental monitoring data. Through I.H. sampling, air contaminants are identified; the effectiveness of engineering controls are measured; and the magnitude of employee exposures are determined. The principal objective of this section is to determine if monitoring is being conducted correctly, baseline exposures are established, and a monitoring program is developed for continued surveillance. Special I.H. problems will be reviewed concerning the types of hazardous contaminants existing and the job classes exposed to these compounds. -12- ARD 003604 5. ENVIRONMENTAL MONITORING & SURVEILLANCE 5.1 - Air Sampling for Chemical Contaminants YES 5.1.1 - List contaminants of major health concerns and comment upon exposure levels. t * FL-U OH ' C f C (PrrAj- <T Pe(. f)uST PPo H firS&CzT?)': . kj < P*~ L "C ^ P t. l <C P EE i. <S-/ -7 V H~cx i r A_____ <- Pa Xtra ^ s p { ( NO 5.1.2 - What is the basis for sampling?. Scheduled ______ / Complaint X XRegulation 5.1.3 - Is the sampling schedule maintained? A/, /r. ' 5.1.4 - Have baselines been established for all job classes where exposures to hazardous contaminants exist? 5.1.5 - Are Sampling Data Sheets complete? 5.1.6 - Is parallel sampling performed during OSHA, MSHA inspections? x X\ X 5.1.7 -Are blanks and bulks, when required, sent with samples for analysis? X . 5.1.8 - Has an adequate amount of sampling been conducted for evaluating I.H. concerns? X 5.1.9 - Are there any areas needing more data? XL >ilm(s/ - PBcpe/A z,f - U - f^C-cy- UciCL VcHfac.ec -13- ARD 003605 5. ENVIRONMENTAL MONITORING & SURVEILLANCE (Cont.) 5.2 - Noise Monitoring & Surveillance YES 5.2.1 - Has a total plant noise survey been completed? . )\ * Personal ______ Area ______ Both X 5.2.2 - How often is it updated? /f o U//r Is 5.2.3 - Are noise measurements repeated in areas when process changes have occurred? X. 5.2.4 - Are calibrations made before X/ and after measurements? \ NO 5.3 - Radiation Monitoring & Surveillance (As Appropriate) 5.3.1- Are radiation devices (ionizing and non-ionizing) used at this plant? (If not, proceed to Section 5.4.) Microwave ______ Medical X-Ray X Density & Level Gauges _______ Others X ArT& H/ 5.3.2- Is radiation monitoring routinely conducted? X i 5.3.3- Who conducts radiation monitoring? ___ Hygienlist ______ Engineering ______ Other X M-EO/CA-L- De^T. 5.3.4- Are radiation supervisors adequately trained? 5.3.5- Type of monitoring equipment available? Beta/Gamma Survey Meter Electro-magnetic Leakage Monitor ^ArO I AT7 C A.) t~J _______ _______ X" -14- ARD 003606 ENVIRONMENTAL MONITORING & SURVEILLANCE (Cont.) 5.3 Radiation Monitoring & Surveillance (As Appropriate) (Cant.) 5.3.6 Is there a current inventory of all ionizing and non-ionizing radiation sources? YES mX NO 5.3.7 Is a radiation badge program in place? ( 5.3.8 - Is I.H. included in the approval cycle for all radiation source procurement? 5.3.9 - Are all radiation sources labeled? X X X 5.3.10- Who maintains the radiation records file? (5 AJ V , T u f>!~. H Gb / c 5.3.11- Are radiation records complete? X 5.4 - Heat Stress (As Appropriate) 5.4.1 - Are heat stress studies conducted? V -15- ARD 003607 6. RECORDKEEPING An effective I.H. Program must have a well-manag'ed* system of recordkeeping. This will help provide: a. Protection of workers' health by providing easily retrievable data on I.H. exposures. b. Protection of the Company's interests by documenting levels below the PEL. c. Procedures to meet legal requirements of recordkeeping. This section will determine whether records are stored in a manner in which they can be easily retrieved, and if the records are complete. . Specific files related to I.H. monitoring will be considered and, where appropriate, the techniques involved in handling computerized data will also be discussed. -16- ARD 003608 6. RECORDKEEPING 6.1 - Is a file maintained for personal exposures? By individual X By job class X YES NO X 6.2 - Are calibration records maintained for sampling equipment? K 6.3 - Are repair/maintenance records maintained for sampling equipment? X 6.4 - Are Sampling Data Sheets filed with survey results? 6.5 6.6 Is a computerized recordkeeping system employed? 2L Other files maintained: /SSoA/occ.- -- USfc Issuance of hearing protection & use? Mandatory \ By choice X Assignment & approval for respirator use? Respirator fit-testing? Audiometer Booth Calibration? >1 Inventory of Hazardous Materials? Material Safety Data Sheets: Company , Supplier OSHA/MSHA Inspections & Citations? Employee Health Hazard Training? _X_ ________ M f\i / iue-> / aj b <s ~r, SikfE 7 y M T& -17- ARD 003609 7. HEALTH HAZARD CONTROLS Once health hazards are identified and the degree of hazard determined, the next question to be answered is... What should be done to alleviate or control the problem? The proper sequence in seeking solutions is: 0 Substitution 0 Administrative Controls 0 Engineering Controls 0 Personal Protection In this section, the Audit Team will assess the plant's approach and degree of success in solving exposure problems. -18- ARD 003610 7. HEALTH HAZARD CONTROLS 7.1 - Are health hazard controls instituted when: YES Exposures are known to exceed standards? Exposures are unknown and judged to approach or exceed standards? Health effects or discomfort are noticed at exposure levels below standards? A A 7.2 - Are safer substitute materials, engineering controls, and work practice controls being given priority consideration? (List examples.) ^ fr<ee^ r-s 5 Be<r at.c hi ajt fthiCtr MfACr^ t'VcRK P'HAcnct.'t: -- ,, fJO G.:A ' A a Cc AAlA ( A. . HO- Pr'!< HJGtZ'.' CCflTfe-CLP 7.3 - Are ventilation and exhaust systems inspected at installation and periodically for their effectiveness? A X 7.3.1 - By whom? Po ~rP '-a la \!Ca;7 - YS . CA'-'Af- NO 7.3.2 - Are new or modified ventilation systems reviewed by I.H.? -19- ARD 003611 8. HEALTH HAZARD TRAINING Educating hourly employees, supervisors, and plant management is an important element of a successful I.H. Program. This Audit will explore a variety of aspects of health hazard training including, but not limited to: 0 Who does it? 0 How is it accomplished? Frequency and time spent? 0 Program content (previous and planned)? -- Attendance records? -20- ARD 003612 8. HEALTH HAZARD TRAINING YES NO 8.1 - Are there health hazard training programs provided for employees in the following areas: * > PROGRAM INITIAL REFRESHER Hearing Protection Heat Stress Radiation X X X Respiratory Protection Toxic Materials A JC 8.2 - Does training include both hourly and salaried personnel? A A A A X 8.3 - Do line supervisors receive training equivalent to that indicated above? X -21- ARD 003613 9. COMMUNICATIONS AND COORDINATION The overall success of a plant I.H. Program is ' * dependent upon close working relationships and communications between many departments within the plant and I.H. personnel. The purpose of this section will be to explore the scope and effectiveness of the communication between I.H. and these various critical departments, s^ntercommunication will be evaluated as relates to the ability to identify mutual potential I.H. concerns, as well as to achieve implementation of I.H. corrective actions where a joint effort is required. The nature of the communication (formal, informal, etc.) will also be pursued. -22- ARD 003614 9. COMMUNICATIONS AND COORDINATION 9.1 - Medical YES NO 9.1.1 - Is biological monitoring and medical surveillance for toxic substances being performed, where appropriate? 9.1.2 - Does the I.H. Supervisor interpret the results before informing the employee? X X 9.1.3 - Do the I.H. Supervisor and the physician discuss the results of the tests? 9.1.4 - Are survey results reported to department supervisory or management personnel? 9.1.5 - Are survey results reported to Pittsburgh Industrial Hygienist liaison contact? 9.1.6 - Does the physician participate in employee training programs? y 7---- X 9.1.7 - Is there effective liaison between Medical and I.H. as relates to potential chemical exposures? 9.2 - Safety 9.2.1 - Is I.H. involved in Safety departmental meetings and activities within the plant? 9.2.2 - Is there effective ccmmunication, where necessary, between I.H. and Safety as relates to plant exposure problems (noise, respirators, etc.) and their resolution? X 9.2.3- Are I.H. concerns considered in plant Project Safety reviews? (Discuss hew this is accomplished.) X ARD 003615 _____ Cf"CVLfr / Rff zv fcjrf erf-rtf' / XehJT ~7~O rf.rfU, euPe, f=ctrtccAJS L- rf Crf / AJ i=r) 77-feerf n.'H-fCtf Atfrtr *rr //ovc-a. ve /, fr. ta'ca.) rf/? 7-/ rf-ff rf&t - c AJ-rnrr u a- rf T~ /t f "SfL /_. Crts'rtrtrTT rffJ'/ S _23_ ' ' ' / y ' JZ -r' '* ' ' ' 9. COMMUNICATIONS AND COORDINATION (Cont.) 9.2 - Safety (Cont.) YES 9.2.4 - Do JSAs include health risks? 9.2.5 - Have I.H. and Safety developed emergency planning for high-hazard, critical events? I 9.3 - Line Production 9.3.1 - Is there effective communication between I.H. and Line Production on I.H. matters and concerns? 9.3.2 - Is the I.H. Supervisor recognized as a resource by the Line Production personnel? 9.3.3 - Is there effective implementation of I.H. recommendations by Line Production? X X 9.4 - Is there effective communication between the I.H. Supervisor and the following groups: Environmental Control? Engineering & Maintenance? Procurement? Hearing Conservation Coordinator (If other than I.H.)? X XX Works Laboratory Personnel (If they, perform services for I.H.)? Plant Management? 9.5 - Do the Corporate I.H. and Environmental Health Lab personnel provide the services you desire? NO -24- ARD 003616 t O 10. CHEMICAL CONTROL Plants purchase and maintain a wide inventory of chemical materials. Pro-active, preventive '' measures to avoid potentially hazardous exposures start with a knowledge of their existence within the plant. Management of chemicals may start with a continuously updated inventory and/or include such aspects as Material Safety Data Sheets or adequately labeled containers. Depending upon the degree of chemical material use, some plants will have a Hazardous Materials Control Committee. V The Audit Team will explore all aspects of the plant's efforts to manage and control chemical materials. -25- ARD 003617 10. CHEMICAL CONTROL YES 10.1 - Is there a plantwide materials inventory of chemicals? 10.1.1 - Are there procedures for updating the inventory? I 10.2 - Is there a Hazardous Materials Control Committee? 10.3 - Does Procurement obtain I.H. clearance prior to introducing new chemical substances into the worksite? X 10.4 - Are MSDS available and transmitted to I.H. personnel for all production chemical substances purchased in the ' workplace? NO X? <t / 4 -96- ARD 003618 CD sos . CcDr X to r-> ROCKDALE WORKS ORGANIZATION CHARTS U 4-1 CO u 3o o " cu d .. CO . Mc i CD - U CO H CJ * M 0) to co c CD Vl X CD to cd CD CD C Vi D <' ; X Cl 4J cd C X CD CD H Cl, Vi 0) CO CD C Q 2 r-4 <D O t-4 c X o <u H V 0) to CD c CD X C o 4J O 3 T3 O w 04 Vl 0) to CD c CD 2 to c r^ V* CD CJ e r4 to c w o u 3 o CO CD * Pi C CD E3 X 1 V< o to CD C CD X u 0) H r-t O U J-I d o u CO X Vt O U C CD B 0) (4 3 o o u P4 u * CD to CD d CD S u d 0) . C d CD 4J c rt u CD O. 3 CO E oo Vi XJ o &4 tX r^ .C CO U CD ,n E 0) S 0) CD XJ 4J -4 B g o o ABD 003619 TEXAS AREA MANAGER Rockdale Works Revised: 1982-10-01 Sheet 1 *I ARD 003620 PLANT MANAGER ROCKDALE WORKS Rockdale Works R evised: 1982-10-01 Sheet 2 Glade H. Lantz Rockdale Works O o ARD 003022 PRODUCTION MANAGER D J S T B A AJ o. CO 3 -3 O u AJ o 0) w AJ . AJ *a u 3 > w z n 3a co u -< -HoCO -OO >u3C3L**2S*Ca*d3*. co o Loi a u Co3COL to cw0o co H J3 > Li Li CO 3u CL 3C CO > a Li Li aj 3 c3 -jH: <0*-H (0 r-4 *4 *4 H to S to < S - O to Li O CO C o > *0 Li Li 0) CO CL O 3' co *o 01 AJ ^ r4 co C S3 C3 co C EO U QU 3 . *rl (0 CO f-H c CO H --4 r4 O o sn o * * to to h to ' to >*tcO#3o31J Lcai 2d 0) rH <uo0 to *. U)4 >L0C)iL < C3O to c rl o o o DC 1 u > CL 3 CO AJ C a 60 c 3 2d tA C3 O CL <D CO o SO Li C O o> to > 3 C ** to to w AJ Q, 3' CO 0) 3 3 H > Li 3 CO Li 3 c Li 3 H S3 AJ >> CL *3 3 3 CO O Pd toCO c E o pJ o > Li' c? AJ O CL Li O 60 co d 4 r4 >d Ll *H 3 f-4 CL AJ 3O CO CL CO AJ U 0) . X) o 02 *s to 1 Li CO >a cl o 3 H w> Li 3 0) 3 CO Li < r4 >% 3 03 CO CL u o CO 4 to >G U *|4 N *3 3 Li CL ONo to CJ j Li CL 3 0* B Jw Is * * to Z to Li O CO *4 > -< uO 3 Li CL AJ 3G CO o o AJ H e 33 to -4 3 H Pd Li O co Li H 3 > 60 /1 h3 C3 ! cl x da co 00 AJ CO rt CO c 1=3 to 3 c 3 L tOo to Li O co > to Ll AJ 3 -.4 CL *-i a i4 CO AJ a AJ c a *o rH o CL O t3o -> PS Cl 3 CO 3 4 E o AJ' < 3 Li CQ JO JO *J Pd U* u > CL 3 CO 3 Li 3 J= U 3 3 frrJt 3 Li N 3 **4 3 CO AJ r4 c o O AJ < ^d ") o *3 <0 r--i 1 AJ 3 U3 C 3 AJ 3 o <0 . h ja Q 4 CJ 3 z3. P2 s toO to 3 U3 l * AJ G 3 3 d 3 AJ c * *4 Li 3 CL 3 CO AJ O to c 1-4. 4 r4 3 3 C 3 H O oI CO 1 2d 04 U CO O OS 3^ <y --3* ~30 <T 0 O AJ 2d ** V L. ce u (T--. e: Z ' 3 s Cm CJ c u: u: 21 ee U) G V. oin bz.' ** f-- >Z az -- - oer V. H- U. b. L_* z u tr G 5. BS v: > Z cj cr. in tn u: < sc n; < z 3 a. z 3 *< H UJ *5 < u: c e. a. >: C as uK < , z o U u CZ C CL < A. H CS cj r--* Ctii -- OS > bl -t 3 b: < < ez c Ui Z o . | PI.AW /SCII. SUPERVISOR SUPERVISOR ce u: u b. ZZ U W in < as O cz oz 5< o CJ air. . -- sc UJ u z cj < 3 c/J < *2 M o "H ts UJ u z c Jz % to a4 <- tn cj >z O-- CJ CJ n c 3: t- Cm z < zcr ,J .* < > < -- Cm a c z < .-- < cn X . . n as M CJ zo uLaO zo u. tz Cf ARD 003624 o a ri JC 30 w 9^ O-- ZC o ^ uin cu *r a ^--o u >y o <y 3 " *v> 100) OOJ u ca u3 > pa> C/1 CO MC *3 <0 1 CPB3 ED Ooo < eUu HCo3 >Eca CSS o Adm. T rain R eports d ir e c t ly to M anager, Human R e s o u rc e s /In d u s tria l R e la tio n s t<oD to uc po 3O -*4 aj to O C3 *"* (35 COSSJ c C3 i-H E OJ 3 SC -Hu 1S AUJ) W3 O T3 <C Z <x "i-v< CO o ou s >> p p CO z *^ AJ JLJ Ca; uH . E 3O O 0) -t CO CU E *0 w ! CO cH 0) .c 0) X w . < c o H(PO0 AAtoJJ > *H 0) c<11 O. C/3 C/3 *H> A>J. zC uH C3O0O) 0f04 >CO a >3 * P OCO H 3>PQCJU*uCoH CO AJ AcoJ 3Cr3l CCCOO (0 QJ o j 7 AJ --0J< >1c-n1 C3 "CO* co CPaP) CaQaOJ.* rctQ-oJi 3C0 CP # < X - to 1e CPOO AoCHJO >H *--0J* 0J C3o/D. pO cO ' ,-a cCO O) o OS * ARD 003625 OI O CO I X CM uO COON 3 *- *--qj< *.t3. vO c3 QJ o c jr r<s r** rr- WORKS CONTROLLER R ockdale Works R evised: 1982-10-14 Sheet 7 ARD 003626 MANAGER PROCUREMENT AND TRANSPORTATION R ockdale Works ARD 003627 POTROOM SUPERINTENDENT c k d a le Works vise d : 1982-10-01 eet 9 Safety and Health Steering Committee Salaried Members Gary Griesbach - Safety Manager Bill Eckert - Maintenance Manager Matt Everett - Electrode Superintendent Reece Newman - Labor Relations Supervisor Brooks Parker - Environmental Superintendent Jerry Roddy - Potroom Superintendent Tom Washam, M. D. - Texas Medical Director Hourly Members Weldon Henson - Environmental Control Finis Black - Mechanical Maintenance H. P. Dick - Ingot Plant James Eichler - Atomizer Ed Gaas - Potrooms Ike Korenek - Potlining Thomas Williams - Carbon Plant * Co-Chairman / arD 003629 Hazardous Materials Control Committee Jack Fry - Manager, Procurement and Transportation W. J. Davis - Security and Sanitation Supervisor Gary Griesbach - Safety Manager Gary Johnson - Division Mechanical Engineer Brooks Parker - Environmental Superintendent Hal Reagan - Texas Public Affairs Manager Tom Washam, M. D. - Texas Medical Director * Chairman > ARD 003630 ARD 003631 Coke Unloading Coal Unloading INDUSTRIAL HYGIENE AUDIT 1983 JANUARY 18-20 Tuesday, January 18 8:00-8:30 Meet with Allan Clayton and Brooks * Parker final planning 8:30-9:00 Meet with Jack Drake and staff to outline audit procedure 9:00-10:00 Meet with Jack Drake privately 10:00-12:00 Meet with Allan Clayton and Brooks Parker review Industrial Hygiene facilities, personnel, and administration of Industrial Hygiene program 12:00-1 :00 Lunch with managers, superintendents, department heads and Safety and Health Committee. 1:00-2:00 Meet Allan Clayton and Brooks Parker to continue review of facilities, etc. 2:00-3:00 Meet with Dr. Tom Washam and Gary Griesbach to discuss interface between Medical, Safety and Industrial Hygiene 3:00-3:30 - Meet with Larry Chesney and Eddie Clark to discuss interface between Engineering and Industrial Hygiene 3:30-4:00 Meet with Jack Fry to discuss interface between Purchasing/Traffic and Industrial Hygiene 4:00-4:30 Meet with Carl Hudson/Reece Newman to discuss interface between Human Resources/Industrial Relations and Industrial Hygiene Wednesday, January 19 - Plant Tour 8:00-9:15 Carbon Plant - accompanied by Matt Everett, Thomas Williams 9:15-10:00 Rodding Room - accompanied by Matt Everett, Thomas Williams 10:00-12:00 Potrooms accompanied by Jerry Roddy and Ed Gaas 12:00-12:45 Lunch ARD 003632 Industrial Hygiene Audit Wednesday, January 19 - continued 12:45-1:45 Group 1 Ingot/Properzi accompanied by Ted Randall and Huey Dick 12:45-1:45 Group 2 - Maintenance accompanied by Bill Eckert and Finis Black 1:45-3 :1 5 Services accompanied by Bob Turner, Ike Korenek and Weldon Henson 4:30 Atomizer accompanied by Bob Hubbard and James Eichler Thursday, January 20 8:00-9:00 - Wrap-up with Allan Clayton, Brooks Parker, Glade Lantz 9:00-10:00 Wrap-up with Managers, Department Heads and Superintendents ARD 003633 ROM S. J. KNIGHT ROCKDALE WORKS f TO MEMORANDUM 1983 January 03 RE: REMOVAL OF ASBESTOS CONTAINING MATERIALS Due to health hazards associated with asbestos, special precautions must be taken anytime materials containing asbestos are removed. Attached to this letter is a list of asbestos containing materials in the plant. If you plan to remove any of the materials on this list, contact Brooks Parker at Extension 235 ahead of time, to find out what precautions should be taken. Most likely, there are asbestos containing materials in the plant which are not on this list. If you plan to remove any materials which you suspect may be asbestos^, such as old steam pipe insulation, you may use the attached procedure for determining asbestos containing materials. k i/ ' fl S. J. KNIGHT SJK 'kk 1/8 Attachment Copies to: H. E. Ryan J. P. Ochoa G. R. Hollas J. A. Church J. D. Leggett J. R. McClain J. Throckmorton N. E. Peterson R. L. McGee F. C. Korenek C. J. Rozacky L. Hammett J. R. Green F. P. Amuso S. J. Spell w. T. Eckert E. B. Parker A. Glaser S. W. Tucker R. E. Cox L. G. Parsons L. J. Chesney J. L. Chesnut t J. D. Quinn C. Allison E. V. Patschke R. E. Laskie E. D. Stough J. Z. Krai 1 C. R. Unnasch J. C. Lee S. E. McF aul1 C. . P. Kouba J. M. Mitchell V. G. Poraykal R. C. Remaley ''r' **v ALCOA ARD 003634 i, r 4 1 6 .V (r<ev ii-sa) ASBESTOS CONTAINING MATERIALS IN THE PLANT 1. Boiler insulation - Building 66. 2. Boiler stack insulation - Building 66. 3. Water filter insulation - Building 66. 4. Anode mixer insulation - Building 54. 5. Mixer insulation - Building 127. 6. Steam piping insulation - Buildings 33, 35, 45, 48, 49, 50, 80, 81. * 7. 446 reactor fume fans insulation. 8. Brake linings for crane hoists and bridge brakes. * 9. Brake linings on all plant vehicles. * - Starred items may or may not contain asbestos. ARD 003635 PTB-48-7A February 15, 1979 Replaces PTB-48-7 ASBESTOS IDENTIFICATION IN OLD CALSIL INSULATION* Because of the health hazards Involved in working with asbestos, it is essential that old asbestos-containing calsil be properly identified to avoid accidental worker exposure during maintenance or removal procedures. Prior to the early seventies, all calcium silicate insulation, and several other types as well, contained asbestos as the reinforcing fiber. Most of the asbestos used was chrysotile, but other types such as crocidolite and amosite were also used. All are hazardous to health. Since the early seventies, all manufacturers have switched to either glass or organic fibers for reinforcement. Because of the refractory nature of asbestos fibers, they are not destroyed by the flame from a propane (Bernzomatic) torch. Rather, they glow as little incandescent tpds in the propane flame. Since the newer fibers -- glass, rayon, polyester, cotton, etc. -- are destroyed by the propane flame, this provides an easy means of positive identification for asbestos. The simple procedure is as follows. 1. Break a small piece of insulation off a section of calsil. 2. Heat the broken surface with the flame from a propane torch. 3. Observe. Figure 1 shows asbestos-containing materials The material in Figure 2 does not contain asbestos. 4. With some experience, a good worker can break off a chunk of insula tion and tell by eye whether or not asbestos is present. A small magnifier makes the process even simpler to carry out. *NOTE: Since December, 1978, the Pabco Division started to mark all of their Super Caltemp production with an identifying green stripe that shows it is asbestos free. % "The technical data shown are considered by us to be Accurate end reliable; however, no warranties, express or implied, are given or Intended, and any such warranties are expressly disclaimed.'* ARD 003636 PABCO INSULATION DIVISION 1110 IS Road Fruita CnlnraHn RICOI 2 PTB-48-7A Page No. 2 Figure No. 1 Appearance of ashescoscontaining insulation in propane flame. Asbestos fiber floes not melt and shows up ns little glowing rods in the flame. K ARD 003637 ::hQV E. BROOKS PARKER ROCKDALE WORKS TO MEMORANDUM 1983 January 12 RE: INDUSTRIAL HYGIENE AUDIT - 1983 JANUARY 18-20 I recently distributed some information on Industrial Hygiene concerns and control equipment to most of you for your use in preparing for the upcoming Industrial Hygiene audit. It is intended to serve as a reminder of known major problem areas in the various departments and thereby help you in fielding any questions the auditors might have along these lines. The auditors will probably want to know something about how you indoctrinate new employees and retrain older employees in these areas. Frequency of required training is shown as an attachment to Industrial Hygiene Rule 000 in your Safety Manual. Jim Richter and I are available to help you in this effort and you will be receiving quarterly reminders of progress in meeting these requirements. In addition, you should consider using safety contacts as a supplement to the formal training. Indoctrination of new employees, whether fresh off the street or transferred in from other areas of the plant, needs to be addressed also. Specific instruction concerning health hazards needs to be included in the orientation which these people receive when they report for work. Such information should also be included in JSA's where appropriate. Knowledge of how these things are accomplished in your department will be needed in answering the audit team's anticipated questions. Give me a call if you need help. E. BROOKS PARKER EBP/mz Attachment cc: Matt Everett Bob Turner Ted Randall Q ALCOA Jerry Roddy Bob Hubbard Bill Eckert ARD 003638 SP-4563 (REV n-e) CARBON PLANT Concerns Coal Tar Pitch Volatiles Mixer floor Press Room Cleaning mixers, conveyors, screws Noise Ball Mill area Hummer screens Silica Gunniting flue walls Control Eouipment Green mill dust collection system Mixer ventilation system Sound booth - ball mill area ARD 003639 RODDING ROOM Concerns I Noise General area - 85 dBA - hearing protection recommended Hanging Station - 90 dBA - hearing protection required Friction joining Trichloroethane - stub dipping Control Equipment I Ceiling baffles for noise control Wall covering on southwest wall for noise control Noise enclosure around impactor Noise enclosure around stripping press hydraulic equipment Dampers on trolley bells I Bumpers on trolleys Ventilation system at stub dipping station ARD 003640 POTROOMS Concerns Fluorides Dust General area - ore bucket filling - ore bin filling - pattern bucket filling Bath crusher - CY 19 front end loader - respiratory protection required Noise Siphon rowelling - 115 dBA - hearing protection required TCC crews - cleaning butts, crust breaking - 85 dBA hearing protection recommended Bath crusher - belt attendant - 85 dBA - hearing protection recommended Walden Front End Loaders - CY 19 charging hopper 90 dBA, hearing protection required - Butt bath pick-up - 85 dBA, hearing protection recommended I Heat Stress Control Equipment Potroom fume collection system Gatorade dispensers Catco crane cab ventilation systems ARD 003641 POTLINING Concerns Coal Tar Pitch Volatiles/methyl napthalene Seam mix mixing Seam mix installation - respiratory protection required Mixing C38 cement - respiratory protection required Silica Installing pot insulation, respiratory protection required Dumping potshells in Bldg. 27 Asbestos Removing potshells and cleaning pot stalls, respiratory protection required when shell is underlain with asbestos millboard strips Cleaning pot bottoms when shell was underlain with asbestos millboard, respiratory protection required Metal fume Cutting collector strap bolts, respiratory protection required Fluorides i Dust Noise Potdigging, hearing protection required Seam tamping with rammer Caustic Cleaning potshells prior to pot repair Control Equipment Ventilation system in mixer building ARD 003642 ENVIRONMENTAL CONTROL Concerns Fluorides and Dust Bag changing - respiratory protection required during blowdown and bag removal Noise Bag changing - noise from operating units A398 and A446 operators - if spending extended time under reactors Coal Tar Pitch Volatiles Cnanging bags in A446 units - respiratory protection required during blowdown and bag removal Pitch burns A446 bag changing Control Equipment ARD 003643 UTILITY/CONTROL/LABOR POOL Concerns Dust Ore shed, respiratory protection required when working in basement Cleaning ore bridge Noise Ore shed when opening car hopper slide gates Repairing siphons, using air wrench Asbestos When replacing transite duct sections Confined space entry Inventorying tanks - follow confined space entry rules Fluorides Pot sampling Taking pot temperatures ARD 003644 ATOMIZER Concerns Noise Bldg. 401 - during atomizing, hearing protection required except in soundproof room Bldg. 402 - compressor house - hearing protection required when assigned to work in building Dust Cleaning rotex screens Inert gas Confined areas of the plant Ionizing radiation Portaspec unit in Bldg. 401, film badges required Control Equipment Soundproof room in Bldg. 401 ARD 003645 INGOT/PROPERZI Concerns Noise Properzi operator - 90 dBA, hearing protection required All other production areas - 85 dBA, hearing protection recommended t Chlorine DC casting areas primarily but leak could affect entire area Si CI4, Freon No. 3 D Casting area Control Equipment ARD 003646 MAINTENANCE Concerns Bldg. 44 - Machine Shop I Noise Chambersburg hammer Welding fumes Bldg. 144 - Garage Welding fumes Engine exhaust Battery fumes t Solvent Asbestos (brake linings) Bldg. 48 Yard Service Paint fumes and solvents Herbicides Bldg. 51 - Electric Shop Solvents Asbestos (brake linings) Bldg. 66 Boiler House Noise - 90 dBA, hearing protection required (except in soundproof room) when assigned to work in area Asbestos - when working with old insulation. Rules for removal of asbestos must be followed (respirators, wet down, place in bags) Bldg. 34 Ingot Noise - 85 dBA in all production areas. recommended. Hearing protection Chlorine - when working on chlorine system, respiratory protection required - when repairing chlorine leaks, self-supplied breathing equipment is required I Si Cl4/Freon - when working on Si C14 system leaks, appropriate respiratory protection is required. Bldg. 27 Pot repair Welding fumes I Noise Shell repair Melting buttons from anode buss Caustic - residue on inside of potshells Solvents Brickmasons Noise - Hearing protection required when operating brick saws. ARD 003647 Maintenance - continued Field areas Welding fumes Confined spaces Chlorine - water and sewage treatment Various Nalco water treatment chemicals Lime - Bldg. 70 Noise Control Equipment Bldg. 44 Welding fume exhaust systems Noise enclosures for electric welders Bldg. 144 Vehicle exhaust ventilation system Bldg. 66 Noise proof room Bldg. 27 Welding fume exhaust systems ARD 003648 PLANT I.H. AUDIT (LOCATION) 1. EXCELLENT 2. GOOD 3. FAIR 4. POOR 5. NONEXISTENT 1. POLICIES & PROCEDURES 6. RECORDKEEPING Management awareness, participation, and commitment. Published health protection policy. Effective Joint Safety & Health Committee. Adequacy of records. Identifying overexposures. Documenting below PEL. V Legal requirements. A 2 . ?UL^ 'S-2- *57 2. ORGANIZATION & STAFFING 7. HEALTH HAZARD CONTROLS Appropriate for plant needs. Adequate manpower. Professional and technical training. 3. I.H. FACILITIES & EQUIPMENT Substitute materials. Administrative controls. Engineering controls. Personal protection. Implementation and maintenance. &4J5LAeCn-t Environmental monitoring equipment and sampling procedures. Laboratory analytical support. / 4. WRITTEN I.H. PROGRAMS Essential for managing function Proqram continuity. Planninq a pro-active preventive program for health protection. I.H., Respiratory, Hearing Conservation, 9 and others. k 8. HEALTH HAZARD TRAINING Types of employee training. Frequency. Effectiveness. Hourly and supervisory. 1 <9 9. COMMUNICATIONS & COORDINATION t ' Working relationships between departments. I.H., Medical, Safety, Production, Engineering & Maintenance, Industrial / 1 Relations, and Procurement. 5. ENVIRONMENTAL SURVEILLANCE Monitoring employee exposures. Baseline, continuing surveillance, effectiveness of engineering controls, and special problems. HO. 3 HAZARDOUS MATERIALS CONTROL Materials Inventory, Material Safety Data Sheets, Container Labeling, Administrative Controls, Hazardous Materials Control Committee. V E. E. RUMBERGER 1982 DEC. 01/eds ARD 003649 cS- > </ ^--' <?r3> - o } - t C#n*<L^d2t^ IfcfflL dLtjt&itcef *-0 / GZe-eLstvL, 1- y^tizUc* - - cA&.%-fe- u' /fc t-^cC&Aic, - -4^-casLtC - j4Lclg&~ - /v*l$ . IU4&IS - ^fk AjZA-&-lAAA^C<> ^C/AAA-LA- kUeJs &0ti'AA. /YYLAAXa^jCAuCAX^yUi.-CtC;f~ cyijc+<*y ^/ C^JtA^ncAty /r^zA^tcJl $1&Qasgq uJ~/-Tlfft --iAjo CM Ca_aaytht^Cc^As . (AyZ-^ZoiXA ~~^&- /^/LJtJ&iA-'<-4lj j2lAAk~~ ARD 003650 CURRENT REPORT cess," as contrasted with an inspection, which looks specifi cally at physical safety and health hazards at the worksite. Thomas McCully, special assistant to OSHA Administra tor Thorne G. Auchter, told BNA Jan. 10 that "top manage ment support" is listed as the first factor in an effective occupational safety and health program because of the assistant secretary's strong belief that such a commitment is necessary for an effective program. Without top manage ment support, the OSHA document stated, an agency's pro gram "cannot obtain necessary resources, and cannot obtain the necessary cooperation of all levels of line management." Listed as minimum indicators of an agency head's com mitment are these elements: written documentation outlin ing program policies and procedures; appointment of a designated agency safety and health official with adminis trative authority, personal performance standards; personal participation in the program; and resources devoted to the program. Other Key Elements Other elements that should be common to all effective programs, according to the written procedures, are these: program planning "whereby an agency determines how to use its resources most effectively, and sets goals and objec tives for doing so"; program implementation including training, recordkeeping, inspections and accident investiga tions, and abatement; and program self-evaluation. During fiscal 1983, OSHA will develop a targeting system for evaluations based on Office of Workers' Compensation Programs data, according to the written procedures. Devel opment of such a system for evaluations as well as for inspections has been listed by OSHA Administrator Auchter as one of his initiatives for upgrading federal safety and health conditions (Current Report, Oct. 21, 1982, p. 408). However, until the new system is developed, selections for evaluations will be based on Federal Accident Reporting System data. OSHA's Office of Federal Agency Programs is responsible for selecting the evaluation team. Agencies are to be given the evaluation plan "at least one month before the opening conference" which marks the official starting date of the evaluation. "Since the opening conference sets the tone of the evaluation it is important that top managers agree on the purpose and scope of the evaluation," the OSHA docu ment stated. The evaluators will examine documents, visit agency headquarters and intermediate offices; interview program personnel, supervisors, employees, employee representa tives, and safety and health committee members; and will complete their survey with a closing conference, 90 days after the opening conference. In an effort to expedite the system, the written procedures allow 45 days, rather than 90 as previously stated, for a final report to be sent to the agency being evaluated. The agency, in turn, will have 30 days, rather than 60 days, to respond. FACOSH Approved Document McCully pointed out that members of the Federal Adviso ry Council on Occupational Safety and Health were given the opportunity to participate throughout the process of reviewing and formalizing the evaluation procedures. At its Oct. 6 meeting, the members endorsed Auchter's proposal for shortening the process by reducing the time period for issuing and responding to the final report (Current Report, Oct. 14, 1982, p. 393). 649 Litigation UNION'S REQUEST TO PERMIT ARBITRATION OF FACIAL HAIR POLICY DENIED BY COURT A company policy which required employees to shave off facial hair that would interfere in obtaining a satisfactory seal for respirators was not a proper subject for arbitration under union-company contract provisions, according to a ruling of the U.S. District Court for the Sodth&n District of Texas. This decision, issued Dec. 30 in Oil, Chemical & Atomic Workers International Union, Local 4-367 (OCAW) v. Shell Oil Company (No. H-81-1908), denied the union's request for an order compelling the company to arbitrate the reasonableness of its facial hair policy. This case arose after Shell Oil announced the policy requiring all employees in maintenance and laboratory posi tions to remove facial hair, including beards, sideburns, and mustaches. The union responded by filing a grievance on the ground that the policy was both unreasonable and discrimi natory on its face and administered in an unreasonable and discriminatory manner. It failed, however, to cite any in stances of discipline or discharge in operation of the policy. Subsequently, after receiving the company's answers to the grievance petition, the union decided to request arbitra tion of the issues. When the company refused to submit the grievance to arbitration, OCAW filed an action in the Texas federal court for an injunction requiring Shell Oil to comply with its request The court indicated that the arbitrability of the company's facial hair rule depended on a review of contractual provi sions which set up procedures for formulating and negotiat ing safety and health policies at the worksite. It distin guished this case from one involving actual discipline or discharge of an employee as a result of application of the policy. Language in applicable clauses permitted recommenda tions and proposals on safety and health matters either through a joint union-employer safety committee or at negotiation sessions between both parties, the court stated, but these provisions indicated that the subject matter dis cussed or the company's ultimate decisions were excluded from grievance and arbitration procedures. The court there fore denied OCAW's request for an injunction on the basis that the "union cannot ... obviate these exclusive proce dures agreed to by the parties, by arbitrating the reason ableness of a [facial hair] policy." This decision, written by U.S. District Judge Gabrielle K. McDonald, will appear in a future Decisions issue.- Consultation OSHA GRANTS CONTRACT TO PROVIDE ON-SITE CONSULTATION TO EMPLOYERS On-site consultation on workplace safety and health haz ards will be provided to Pennsylvania and New Hampshire employers under a one-year, $213,000 contract awarded to a Maryland consulting firm, the Occupational Safety and Health Administration announced Jan. 5. The Pennsylvania and New Hampshire programs will be operated under the contract granted to Gnviro Control, a Division of Dynamac Corporation, Rockville, Md. In all other states, consultation programs are operated by state agencies or universities. 1-13-83 Occupational Safety & Health Reporter 009S-3237/&3/&00.50 ARD 003651