Document 91MzKr3o4wadYkZ4d3dvZ2j06

FILE NAME: Mobil (MOB) DATE: 1973 Apr DOC#: MOBOOl DOCUMENT DESCRIPTION: Government Inspection Results - NIOSH Health Hazard Report U.S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH Section 20(a)(6) of the Occupational Safety and Health Act of 1970, 29 U.S.C. 669(a)(6), authorizes the Secretary of Health, Education, and Welfare, following a written request by any employer or authorized representative of employees to determine whether any substance normally found in the place of employment has potentially toxic effects in such concentrations as used or found. The National In stitu te for Occupational Safety and Health (NIOSH) received such a request from an authorized representative of employees regarding exposures to asbestos dust and to hot environments relevant to the company's requirement for insulators' wearing of special clothing (paper coveralls) while working with asbestos at the Mobil Oil Corporations's Refinery in Augusta, Kansas. On December 11-13, 1972, two (2) NIOSH investigators conducted an observational and environmental survey of inside operations Involving the cutting o f material containing asbestos and the mixing o f "Mud" o r "Super 88"; and outside operations involving the In sta llin g of insulation and "Mud"; and very limited stripping of old insulation. Thirty (30) personal and general area samples for airborne concentrations o f asbestos were collected during these operations. None o f the asbestos dust levels measured exceeded the present U.S. Department of Labor Standard o f 5.0 fibers/cc (8-hour time-weighted average--TWA) o r the 2.0 ffbers/cc-8-hour TWA lim it which will be in e ffe c t In 1976; and 10.0 fibers/cc (ceiling concentration). The unit measurement for the asbestos standard is the number of fibers greater than 5 micrometers in length per cubic centimeter (cc) of a ir as promulated by the U.S. Department of Labor (Federal Register, Volume 37,1910.93a, June 7, 1972). For inside operations in the in su lato rs' tool building the asbestos counts of individual personal samples varied from 0.6 to 3.3 fib e rs/c c , and the asbestos counts of general area samples varied from 0.1 to 0.9 fibers/cc. For outside operations the asbestos counts of personal samples varied from 0.2 to 1.5 fibers/cc and general area samples varied from 0.0 to 0.9 fibers/cc. The estimated 8-hour time-weighted average fo r the workers ranged from 0.3 to 0.6 fibers/cc. Page 2 - Health Hazard Evaluation Report 72-91 Interviews with the four (4) insulators did not e l i c i t any symptoms which could be attributed to overexposure of employees to asbestos, and medical records did not show any employee having a condition which could be attributed to exposure of employees to asbestos. The insulators did indicate previous symptoms (e .g ., exhaustion, e tc .) which could be attrib u ted to heat s tre s s . There have been two (2) cases of overexposure to heat or heat prostration in September 1972. I t is f e lt that the wearing of paper coveralls over their personal clothes does contribute somewhat to the problem of exposure of the four (4) employees to hot environments. It is our determination that asbestos is^ not toxic a t the concentrations used and found in the insulators' forking operation. This is based upon the environmental concentrations of asbestos obtained at the time of th is survey and upon the documentation in the lite ra tu re supporting the standard. No specific evaluation was made concerning the exposure of employees to hot environments and the concern of special clothing (paper coveralls) contributing to heat problems ( e .g ., heat prostration, e tc .) as the survey was conducted in the w inter with no operations involving any significant exposure of employees to hot environments. In th is regard, i t is determined that the wearing of special clothing such as senriporous paper coveralls over personal clothing does contribute to the potential heat stress problem, and does not meet the intent of the rules and regulations concerning the wearing of "Special Clothing" as required when environmental levels of asbestos exceed the "Ceiling Value" of 10 fibers/cc. General reconmendations consistent with the rules and regulations s e t forth by the U.S. Department of Labor and good Industrial hygiene practices have been made to management to obviate any potential hazards from the exposure of the four (4) employees to asbestos and "hot environments". Copies of the Sumnary Determination as well as the Full Report of the evaluation are available upon request from the Hazard Evaluation Services Branch, NIOSH, 508 U.S. Post Office Building, 5th and Walnut Streets, Cincinnati, Ohio 45202. Copies of both have been sent to: a) Mobil Oil Corporation, Augusta, Kansas b) Authorized Representative of Employees c) U.S. Department of Labor - Region VII For purposes of informing the "affected employees," the employer will promptly "post" the Sumnary Determination in a prominent place(s) near where the four (4) insulators work for a period of 30 calendar days. Page 3 - Health Hazard Evaluation Report 72-91 II. INTRODUCTION Section 20(a)(6) of the Occupational Safety and Health Act o f 1970, 29 U.S.C. 669(a)(6), authorizes the Secretary of Health, Education, and Welfare, following a w ritten request by any employer or authorized representative of employees to determine whether any substance normally found in the place of employment has potentially toxic effects in such concentrations as used or found. The National In stitu te for Occupational Safety and Health (NIOSH) received such a request from an authorized representative of employees regarding exposure of insulators to asbestos dust and the wearing of paper coveralls by the four (4) insulators and the special clothing contributing to heat exposure problems (e .g ., heat prostration) with th e ir exposure to hot environments a t the Mobil Oil Corporation Refinery at Augusta, Kansas. III. BACKGROUND HAZARD INFORMATION A. Standards Asbestos: The Occupational Health Standard promulgated by the U.S. Department of Labor applicable to the particular substance of this evaluation is liste d below. Permissible exposure to airborne concentrations of asbestos fibers (Federal Register, Volume 37, 51910.93a, June 7, 1972copy Included as an appendix to this report en titled , "Rules and Regu latio n s") is outlined as follows: (1) Standard Effective July 7, 1972 (2) Standard To Go Into Effect July 1, 1976 (3) Ceiling Concentration Applicable At a ll Times ....5 .0 fibers/cc* ....2 .0 fibers/cc* ...10.0 fibers/cc** * 8-hour time weighted average airborne concentration of asbestos fibers longer than 5 micrometers in length per cubic centimeter (cc) of a ir. ** Airborne concentration of Asbestos fibers longer than 5 micrometers in length per cc o f a ir not to be exceeded a t any time as determined by a minimum sampling time of 15 minutes. Page 4 - Health Hazard Evaluation Report 72-91 Hot Environments (Heat Stress): There are no current Federal Standards for exposure of employees to hot environments. However, NIOSH recommendations for such standards are contained in HSM 72-10269 en titled , "C riteria for a Reconraended Standard ....Occupational Exposure to Hot Environments", by NIOSH, Health Services and Mental Health Administration, U.S. Department of Health, Education, and Welfare. A copy of this referenced document is enclosed fo r informa tional purposes. In general, healthy adults performing continuous moderate work can easily to le ra te a wet bulb globe tenperature of 79F without developing heat disorders such as heat fatigue or prostration. B. Toxic Effects Toxic Materials: Asbestos: Prolonged inhalation of asbestos fibers may re su lt in the production of a typical pulmonary fib ro sis which may be accompanied by severe respiratory d isab ility . If large quantities of the fibers are inhaled over an extended period of time, characteristically 10 to 20 years, tissue reaction progresses until a generalized diffuse fibrosis (known as asbestosis) becomes evident. This fibrosis is seen f i r s t in the lower lobes o f the lungs but eventually, i f exposure continues, appears in the other lobes as well. Respiratory insufficiency and cardiac failure may supervene. Additionally, there is Increasing evidence th a t the frequency of bronchogenic cancer is greater among workers in certain asbestos industries than expected in the general male population as well as more evidence of an Increased ra te of occurrence of mesothelioma of the pleura or peritoneum. These asbestos associated neoplasms may occur without radiological evidence of asbestosis which means th a t pre vention of even short-term high level exposures to asbestos may be extremely important. Physical Agents: Hot Environments (Heat Stress): The physical effects o f excessive exposure to environment heat are determined to a large extent by factors other than actual temperature. Workload, re s t periods, water and s a lt supplementation, clothing, general physical fitness and acclimatization are a ll extremely important in determining levels at which e ffects can be expected to become manifest. In general, well adults performing con tinuous moderate work can easily to le ra te a Wet Bulb Globe Temperature of 79F without developing heat disorders. Heat fatigue is the mildest of the heat disorders and is characterized by decreased a b ility to concentrate, tired n ess, and ir r ita b ility . Heat prostration (heat collapse, exhaustion, o r syncope) results in weakness, Page 5 - Health Hazard Evaluation Report 72-91 dizziness, vertigo, nausea, blurred or din vision and mild muscular cramps which may progress to a lis tle s s , apprehensive semi-comatose state. In severe cases unconsciousness may re su lt due to complete circulatory collapse even though the body temperature remains normal. The prognosis is excellent and the condition is usually transient. Heat cramps are sudden, severe muscular cramps resulting from excessive physical exertion in high temperatures due to perspiration. This condition occurs mainly among unacclimated Individuals performing extremely severe physical labor in very hot environments such as strokers, miners, firemen, etc. The most severe heat disorder is heat hyperpyrexia (heat stroke). In th is condition a profound disturbance of the heat-regulating mechanism occurs following prolonged exposure to excessively high temperatures leading to high fever and collapse. Convulsions, coma and death are not infrequent despite prompt medical attention. This heat disorder is largely a problem of the elderly non working age population and the severity of the syndrome is usually related to an already compromised physical state due to heart, kidney or other underlying diseases. IV. HEALTH HAZARD EVALUATION A. In titia l V isit - Observational Survey A health hazard evaluation survey of insulation operations a t the Mobil Oil Corporation Refinery Plant was made on December 11-13, 1972, by NIOSH representatives, Messrs. Raymond L. Hervln and Raymond Rivera. The functions of the National In stitu te for Occupational Safety and Health and i ts relation to Section 20(a)(6) of the Occupational Safety and Health Act of 1970 were explained to Mr. W. W. McMullen, Manager Employee Relations; Mr. S. G ille tte , Chief of Safety; and Dr. J. J. Stanko, Regional Industrial Hygienist; who assisted in the completion of the National Surveillance Network Part I Questionnaire. Mr. Milo McNalry represented the union and employees during the in itia l walk through survey. Separate ex it interviews were held with a few members of management including Mr. R. S. Grieves, Refinery Manager; and a few members of the union including Mr. Milo McNairy to answer any questions which may have arisen due to our survey. Description of F acility , Process, and Conditions of Use: The Mobil Oil Corporation a t Augusta, Kansas employs 287 people of whom 200 are d irectly involved in the production of lig h t petroleum grade fuels, asphalt, and sim ilar products. The normal day-to-day oper ations u tiliz in g material containing asbestos involve a total of four (4) employees who are insulators. These workers wear respirators and dis posable paper coveralls during operations which may Involve airborne asbestos. Other employees (e .g ., laborers) may replace one of the four Page 6 - Health Hazard Evaluation Report 72-91 (4) insulation craftsmen when they are on vacation, sick , or other leave. There are three (3) long-term (5 or more years) regular insulators and one (1) interim insulator at the time of the survey. The insulators worked on daty s h ift only and are responsible for the maintenance, rep air, and upkeep of insulation throughout the plant on a day-to-day basis. Major operations involving the rep air and/or in sta llatio n of insulation is accomplished by contracting out to other companies. One or a ll of the four (4) insulators w ill oversee the major insulation operations of the other contractor to assure that the job is adequate. The day-to-day insulation operations normally involve one (1) hour being spent each day in the Insulators' Tool Building of. approx imately 15 feet by 50 feet by 10 fe e t high. Half of the building is used for storage of new and waste insulation materials and the remainder is used for work with sheet metal and asbestos m aterial. The cutting (hand tools only) of preformed asbestos material (thennobestos-containing less than ten (10) percent asbestos) is accomplished on a 4 feet by 4 fe e t table with 3 inch slo t ventilation on the middle, back, and sides of the table. Mixing o f "Super 88" and/or "Mud" is accomplished in a hood around 3 feet by 3 feet by 4 feet with the front open for mixing operations. The slo t ventilation provides for an average velocity of 700 feet per minute; and the hood an average velocity of 300 fe e t per minute a t 2 inches from the face. There is also a large vacuum system (55-gallon barrel with cyclone, elephant truck, e tc .) used for cleanup operations. All three (3) operations (cutting and forming, mixing of "Mud", and cleanup) are exhausted through a Roto-clone Type W(American Air F ilte r Company, Inc.) Air Exhauster which provides for a water spray wash o f the a ir p rior to discharge. The water containing the asbestos is discharged Into a French Drain with a 10 feet radius and 10 feet deep. The company has recently installed the ventilation system to be in conformance with the rules and regulations promulgated by the U.S. Department o f Labor for use of asbestos in industry which recomnends engineering out, wherever feasib le, any problems where airborne asbestos may be a problem. The ventilation in the tool shed for cutting, mixing, and cleanup appears adequate for the operations normally conducted In the tool shed as observed during this survey. Outdoor operations involving the insulators consists primarily of in sta llin g new insulation and taking off old insulation. Operations consist of placing the preformed (as bought by the company, but cut to length i f necessary by the insulator) semi-circular halves around a pipe and wiring the halves together for a tig h t f i t . The reverse operation is Page 7 - Health Hazard E valuation Report 72-91 accomplished for taking off of old insulation. These two (2) operations were predominant during the survey and did not appear to generate much dust. However, ''Hud" o r "Super 88" is used fo r insulation around elbows, and bends in the piping. This is a wet mixture which Is applied by hand around the bend in the piping and allowed to dry. There should not be much of an airborne problem as i t 1s in a wet form. However, in removing old, dried "Hud" (which contains asbestos and Is not the newer "Super 88") from the pipe, the insulators nay have to use tools (e .g ., saw, hammer, e tc.) which would present a problem concerning airborne asbestos. On two (2) occasions, the stripping o f old "Hud" containing asbestos was observed and only lasted for approximately five (5)~minutes on each occasion. Cleanup operations consisted o f placing the old asbestos in p lastic bags and sealed with storage in .the tool shed until disposal in the c ity or eomnercial waste dump by b u ria l. In observing the operations discussed above, i t is noted th a t signs or labels were not conspicuously in use during various operations and although may not be necessary, may be appropriate for some operations to be in compliance with the regulations. The company has engineered out certain problem areas (e .g ., cutting in tool shed, e tc .) and has gone to products which contain less asbestos than previous insulation products containing asbestos. For instance, the main insulation material used 1s called "Thermobestos." I t contains up to ten (10) percent asbestos; the new "Super 88" or "Hud" contains no asbestos. In addition, there are w ritten instructions to the four (4) Insulators on the wearing of cover a lls and approved respirators during operations where asbestos may be airborne such as stripping operations. Hence, i t is f e lt th a t the company has taken appropriate steps to meet the in te n t of the rules and regulations as promulgated by the U.S. Department o f Labor concerning asbestos, however, may not be in complete compliance with a ll of the regulations as contained in the appendix to th is report. B. Environmental Evaluation 1. Procedure and Methods On December 12-13, 1972, an environmental survey was conducted to determine the environmental exposure o f four (4) employees (Insulators) to airborne asbestos during outside and inside operations involving insulating materials containing asbestos. The primary operations noted at the time of the survey were the outside installation of insulation, and secondary or lim ited operations involving the inside cutting (tool shed) of insulation and mixing of "Mud". Page 8 - Health Hazard Evaluation Report 72-91 A total of 24 personal a ir samples and 6 general area samples were obtained and analyzed for asbestos during a ll hours of 2 day s h if ts . Personal and general area samples were collected with the same type of instruments and f i l t e r . MSA Model 6 battery-operated vacuum pumps were used to draw a ir through tygon tubing attached to an open-faced f i l t e r holder containing 37-millimeter M lllipore type AA filte r s a t a ra te of 2 lite r s per minute. The f il te r holder was attached to the employees' collars for the personal a ir samples, and the general area samples were collected in specific locations In th e working environment. Sampling times ranged from 2.5 to 219 minutes. All of the 3a a ir samples were analyzed by the Laboratory Services, NIOSH, Salt Lake City, Utah using the standard phase contrast illumination microscopy techniques. 2. Survey Results Twenty-four (24) personal and s ix (6) general area samples were obtained during operations involving four (4) insulators while handling asbestos containing materials. None o f the asbestos dust levels a t a ll operations exceeded the present U.S. Department of Labor's standard of 5.0 fibers/cc (8-hour time-weighted average) and 10.0 fib e rs/c c (ceiling concentration). The unit of measurement fo r the asbestos standard is the number of fibers greater than 5 micrometers in length per cubic centimeter (cc) of a ir as promulgated by the U.S. Department o f Labor (Federal Register, Volume 37, s 1910.93a, June 7, 1972). The asbestos counts of short-term individual personal samples varied from 0.6 to 3.3 fibers/cc with asbestos counts o f general area samples varying from 0.1 to 0.9 fibers/cc for inside operations In the in su lato rs' tool building. The asbestos counts of short-term individual personal samples varied from 0.2 to 1.5 fibers/cc, with general area samples varying from 0.0 to 0.9 fibers/cc for outside operations. I t is noted th a t the present Federal asbestos standard of 5.0 fibers/cc will be lowered to 2.0 fibers/cc for an 8-hour time-weighted average in 1976. The estimated 8-hour time-weighted average for December 13, 1972, which one may obtain from the results of th is survey, ranged from 0.3 to 0.6 fib e rs/c c . The Regional Industrial Hygienist for Mobil Oil Company has performed pre vious environmental studies of these operations and his re su lts are essentially in agreement with those obtained during th is survey. Also, the Regional Industrial Hygienist (Mobil) obtained personal and general a ir samples during th is survey. The re su lts of the a ir samples obtained and analyzed by NIOSH are presented in Tables I , II , and I I I , o f th is report. An evaluation o f the exposure o f the four (4) insulators to "hot environments* was not accomplished during th is survey as the survey was conducted in the winter with no operations involving any sig n ific a n t exposure of employees to hot environments. . Page 9 - H ealth Hazard Evaluation Report 72-91 C. Medical Evaluation The Medical Unit consists of a well-equipped laboratory doctor's office, x-ray room, treatment room, firs t-a id room, and a reception area for patients. The Medical S taff consists of a full-tim e registered nurse and two (2) part-time (average 9 hours total per week) physicians who are on call on a 24-hour basis. Review of OSHA Form 102 and discussion with some of the Medical S ta ff, Regional Industrial Hygienist, and the Employee Relations Manager of Mobil Oil Company did not show any respiratory conditions which could be attributed to the exposure of employees to asbestos. They were aware of the medical examination and other requirements in the rules and regulations (refer to appendix to this report) as promulgated by the U.S. Department of Labor. The NIOSH employees questioned a ll four (4) insulators concerning th e ir experiences with asbestos material with particular emphasis on outward signs and symptoms associated with lung ailments. None of the workers claimed that they were suffering any adverse effects from working with asbestos. One employee did express the fact th at he suffered from shortness of breath, but he appeared to be a heavy smoker. Further questioning of the four (4) insulators revealed that they had heard of a to ta l of three (3) employees and in p a rti cular one case, in which asbestos was suspected as the causitive agent for retirement or d isab ility but i t was rumor only and there was no agreement with the insulators th at these were 1n fact actual cases. The names of the three (3) were given to the NIOSH investigators and further questioning of the Medical Staff and others revealed th a t the three (3) cases of d isa b ility or retirement did not relate to the exposure of the three (3) employees to asbestos. The Insulators were informed of th is fact and were satisfied th a t i t was a valid conclusion. No further medical evaluation is f e l t necessary due to the lack o f apparent signs and symptoms associated with lung ailments. The company does have pre-employment and periodic physical examination program which includes chest x-rays. Medical records show th at two (2) employees suffered from heat prostration in September 1972. Both were insulators and were apparently working in a hot environment as well as the day being hot and humid. Apparently the men did not get sufficient r e lie f (e .g ., cool area, workload, re s t, e tc .) from normal operations and resulted in two (2) separate cases of insulators with heat prostration. In this regard, a copy of "Criteria fo r a Recommended Standard... .Occupational Exposure to Hot Environments" is enclosed for use as a guideline for exposure to hot environments. In discussing this natter with the four (4) insulators, Page 10 - Health Hazard Evaluation Report 72-91 i t was f e lt that working in a hot environment such as removing or installin g insulation around a hot vessel, pipe, or tank on hot and humid days during the sunmer can be exhausting but normally has not presented a problem as serious as the two (2) cases of heat prostration which occurred in September 1972. It is noted that the use of the paper su its in asbestos work was institu ted by the company sometime in the sunmer of 1972 and does contribute to potential heat prostration problems. The NIOSH in v e sti gators examined the paper s u it which was in itia lly used by the insulators and found them to be a very hard-finished, almost water tig h t non-porous type paper su it or coveralls which are worn over the employees' personal clothes. I t is fe lt that the particular s u it worn over personal clothes does contribute to a heat stress problem as i t would insulate the body from the free exchange of heat via evapor ation of sweat and other body functions. Since the Incidents o f heat prostration in September, the company has purchased and Is now using a different and more water-porous paper su it which Is s t i l l worn over the employees' clothes. The practice of wearing a complete s e t o f clothes plus an outer paper coverall even though a porous coverall would s t i l l contribute to , although to a lesser extent than non-porous su its, to a heat stress problem. Of p articu lar in te re st to the NIOSH investigators was the fact th at the paper su its of a ll four (4) insulators were seriously ripped a t various places (e .g ., elbows, crotch, e tc .) and are susceptible to holes due to normal work, heat or chemical action during the environmental survey. I t is noted th a t the reason for special clothing such as coveralls, head and foot coverings as required by the rules and regulations (refer to appendix) of the U.S. Department of Labor is to preclude an employee's personal clothing from being contaminated with asbestos and the subsequent contamination in the heme with exposure of the family and re-exposure of the employee. The use of paper clothing which is easily ripped or torn does not meet the in ten t of the "Special Clothing" section of the rules and regulations contained in the appendix. A more suitable alternate would be the complete change and separation o f the employee's stre e t clothes from his work clothes and the wearing of cloth coveralls only without the outside s tre e t clothes under the coveralls. This would meet the intent of the regulations where such special clothing is required such as when environmental levels exceed the "Ceiling" concentration of 10 fib ers/cc. It should be emphasized that In no case were any individual medical file s requested or examined by the NIOSH investigators during the medical evaluation. OSHA Form 102 was reviewed and only general medical questions were asked during the medical evaluation and questions were lim ited to information concerning asbestos and hot environments. Page 11 - Health Hazard Evaluation Report 72-91 D. Conclusions It is our determination that asbestos is not potentially toxic a t the concentrations used or found a t the Hire of th is evaluation TrTtfie insulators working operations. This is based upon the resu lts of the environmental survey being lower than current and future standards for asbestos a t the time of the survey and the lack of symptomatology which could be attrib u ted to excessive exposures to asbestos. However, i t is noted th at concentrations may well be significantly differen t on other occasions such a major stripping and insulation operations which were not observed a t the time of the survey. No environmental measurements were made concerning employees' exposure to heat s tre ss , although two (2) cases of apparent heat prostration did occur in September 1972 and is further discussed in Section III.C ., of th is report. I t is f e lt th a t the management and the Regional Industrial Hygienist a t the Mobil Oil Corporation are well aware of heat and safety requirements and have taken several steps, such as engineering out potential problems, and have, with few exceptions, met the intent of the Federal regulations and c r ite r ia . The company's e ffo rts In the area of safety and industrial hygiene are good and the use of approved respirators and special clothing 1s encouraged concerning operations involving airborne asbestos. I t is further noted th a t the company has recently used insulating material with l i t t l e (e .g ., thermobestos less than 102) asbestos and where possible material containing no asbestos. The cooperation of both management and union during the survey is most appreciated by the NIOSH investigators. V. RECOMMENDATIONS In view of the findings discussed above and in other sections of this report, i t is recomnended th a t the provisions of the rules and regulations (appendix) as contained in the Federal Register (Volume 37, 51910.93a, October 18, 1972); and in the NIOSH publication en titled , "C riteria for a Recommended Standard....Occupational Exposure to Hot Environments", should be carefully followed by management. It is further recomnended th a t cloth coveralls be provided the employees in order to obviate the necessity of wearing two (2) sets o f outer clothing as currently required by management; and the fa c t th at cloth coveralls are normally more porous than paper coveralls. The laundering of such contaminated clothes could be readily accomplished in-house at the tool shed or other available fa c ilitie s by the purchase of a Palje 12 - Health Hazard Evaluation Report 72-91 household washer and dryer i f not now available. The requirements for the use of outside laundering services are contained in the appendix i f an alternate method is needed. The furnishing of cloth coveralls would also obviate the potential contamination of the employees' clothing as required by the rules and regulations contained in the appendix. The cost of cloth coveralls and inhouse laundry of about 20 coveralls/week or 4 coveralls/day should be around or less than the cost of using 4 paper coveralls/day which are disposed as waste each day. The continued wearing of approved respiratory protection during operations where asbestos may be airborne is also encouraged and may be required under Part (c)(2)(i11) e n title d , "Spraying, demolition, or removal" of Section 1910.93a Asbestos, as contained in the appendix to th is report. APPENDIX HEALTH HAZARD EVALUATION 72-91 MOBILE OIL CORPORATION AUGUSTA, KANSAS TABLE I I I ESTIMATED 8-HOUR TIME-WEIGHTED AVERAGE OF INDIVIDUAL AIR SAMPLE RESULTS Occupation Insulator No. 1 Insulator No. 2 Insulator No. 3 Insulator No. 4 Asbestos Count* 0.3 -0.4 0.4 0.6 Units of Measurement: fibers/cc--the number of fibers longer than 5 micrometers in length per cubic centimeter (cc) of air TABLE I I OUTDOORS INSULATION OPERATIONS Personal Air Sample Results (unless otherwise noted as. general area samples) of Insulators a t Mobile Oil Corporation Plant during the tearing down o f old and in sta lla tio n of new insulation - Samples collected December 12-13, 1972. Liters Occupation &Any Sample Ho. Sampled Other Operations Asbestos Count* 36 46 Insulator No. 1 0.9 29 184 Insulator No. 1 0.3 9 232 Insulator No. 1 0.2 17 336 Insulator No. 1 0.3 45 382 Insulator No. 2 0.6 41 78 Insulator No. 2 (use of Hud or Super 48) 1.5 3 - 170 Insulator No. 2 0.9 14 228 Insulator No. 2 0.3 23 416 Insulator No. 2 0.5 50 398 Insulator No. 3 0.5 37 80 Insulator No. 3 (use of Mud or Super 48) 0.3 31 172 Insulator No. 3 1.1 26 224 Insulator No. 3 0.2 20 408 Insulator No. 3 0.2 35 186 Insulator No. 4 0.9 10 232 Insulator No. 4 0.7 25 438 Insulator No. 4 0.6 38 11 General Area during Stripping Operations 0.0 42 5 General Area during Stripping Operations 0.9 *Units of Measurement: fibers/cc--the number of fibers longer than 5 micrometers ip length per cubic centimeter (cc) of a ir TABLE I INDOOR CUTTING OPERATIONS Personal Air Sample Results (unless otherwise noted) of Insulators a t Mobile Oil Corporation Plant while cutting thermobestos material or mixing Mud or Super 48 - Breathing zone samples collected on December 12-13, 1972. Liters Occupation &Any Sample No. Sampled Other Operations Asbestos Count* 46 12 Insulator No. 1 3.1 27 136 Insulator No. 1 1.1 47 8 Insulator No. 2 2.0 48 14 Insulator No. 3 3.3 32 12 Insulator No. 4 2.2 49 46 Insulator No. 4 0.6 28 136 Insulator No. 4 1.2 33 40 Breathing Zone/General Area above Cutting 0.9 Table during cutting 0 39 24 Same as F ilte r No. 33 0.2 30 412 Same as F ilte r No. 33 except l i t t l e 0.1 cutting done 5 292 Same as F ilte r No. 30 0.1 22 -- Blank .03 Fibers/field 44 -- . Blank .06 fibers/field Units of Measurement: fibers/cc--the number of fibers longer than 5 micrometers in length per cubic centimeter (cc) of a ir HULES AND REGULATIONS ttl> Laundering: (a) Laundering of a t intervals greater th a n 8 m ontns tar fh> Housekeeping--(1) Cleaning. All asbestos contaminated clothing shall be employees whose exposures to asbestos external surfaces In any place of employ done so as to prevent Use release of air m ay reasonably be foreseen to exceed m ent shall be m aintained free of accu borne asbestos fibers in excess of the ex th e exposure lim its prescribed In para m ulations of asbestos fibers If, w ith th eir posure Unfits prescribed in paragraph <b> graph (b> of th is section. dispersion- there would be an excessive of this section. (4) Employee observation o f monitor concentration. (M Any em ployer who tire s asbestos- ing. Affected employees, o r th eir rep (2) W aste disposal. Asbestos waste, contam inated clothing to an o th er person resentatives. shall be given a reasonable scrap, debris, tag s, containers, equip {or laundering shall inform such person opportunity to observe an y m onitoring m ent. and asbestos-contam inated cloth of th e requirem ent in la ) of th is subdi required by this paragraph and shall have ing, consigned fo r dtepood. which m ay vision to effectively prevent th e release access to th e records thereof. produce in any reasonably foreseeable of airborne asbestos fibers in excess of (t) Caution signs and labels. (1) Cau use; handling; storage; processing, dis posal. o r transportation airborne concen th e exposure lim its prescribed in p a ra tion signs. (1) Posting. C aution signs graph ib of th is section. shall be provided and displayed a t each tratio n s o f asbestos fiber* In excess off the (cl C ontam inated clothing sh all be location where airborne concentrations exposure Unfits prescribed hi paragraph (b) off th is section shall be eoDeeted and transported in sealed im perm eable bags, o f asbestos fibers m ay be in excess of the or o ther dosed. Im permeable containers, exposure lim its prescribed in paragraph disposed of to sealed Impermeable bags; and labeled in accordance w ith p ara (b> of this section. Signs sh all be posted o r o th er dosed, impermeable container. (1) Recordkeeping--(1) exposure rec graph (g) of th is section. a t such a distance from such a location (el M ethed of m easurem ent. All de so th a t an employee m ay read the signs ords. Every employer shall m aintain rec term inations of airborne concentrations an d take necessary protective steps be ords off any personal o r environm ental m onitoring required by this section. Rec of asbestos fibers shall be m ade by th e fore entering th e area m arked by the m em brane filter m ethod a t 400-450 X signs. Signs shall be posted a t an ap ords sh all be m aintained for a period of (m agnification) (4 m illim eter objective) proaches to areas containing excessive a t least 9 years and shall be made avail able upon request to th e A ssistant Secre w ith phase co n trast illum ination. concentrations of airborne asbestos It) Monitoring--Cl) Initial determi fibers. tary of Labor fo r Occupational Safety and H ealth, th e D irector off the N ational nations. W ithin 6 m onths of th e publi <ii) Sign specifications. T he warning In stitu te fo r Occupational Safety and cation of th is section, every em ployer signs required by subdivision (l) of this H ealth, and to authorized representa shall cause every place of em ploym ent where asbestos fibers are released to be subparagraph sh all conform to tbs re tives off either. m onitored in such a way ss to determ ine quirem ents of 20" x 14'* vertical form at signs specified in i 1910.145(d) (4). end <2> Employee access. S ta y employee and form er employe shall have reason w hether every employee's exposure to to this subdivision. T he signs .hai) dis able acccse to any r a te d required to be asbestos fibers is below th e lim its p re play th e following legend In the lower m aintained by sribpexagnph (1 ) off tifia scribed in paragraph (b) of this sec panel, w ith letter sizes and styles of a tion. I f th e lim its are exceeded, th e em visibility a t least equal to th a t specified pcolomyperliasnhcaellproimgrmamediiantealyccournddaenrcteakwe itha in this subdivision. paragraph, which todleatce th e em piqyee's own exposure to tabestoe fibers. paragraph (c) of th is section. (3) Employee noHjloation. A n y Cta- (2) Personal m onitoring--(1) Sam Legend Notation pforee found to have been exposed a t any ples idisil be collected from w ithin the AmUs___ __ 1" flne Buffi tim e bo airborne concentrations of asbes tos fiber* in excess o f the Umlte pre breathing zone of th e employees, on G o t h i c o r scribed in paragraph (b) o f this seetton m em brane filters of 0.8 m icrom eter po Dust Hazard. % - B ue Butt. shall be notified in w riting a t th e expo rosity m ounted In an open-face filter G o th ic ou sure as soon as practicable but n o t la te r holder. Sam ples shall be taken fo r th e th an 5 day* of the finding. The employee determ ination of the 8-hour tim e- Avoid h f thing Dfivt-- . W ar Assigned Fmtaettve Gothic. Gothic shall also be tim ely notified of th e cor rective action being taken. weighted average airborne concentra (1) M edical examinations--(1) Gen tions and of th e ceiling concentrations o f Do dot Bwutn ZB a m 54" dotine. eral. T he employershall provide o r m a te asbestos fibers. Unlaw Tour Work HaHaSrmB . available a t h is eeet; medical exam ina (ii) Sam pling frequency and p attern s. m illing Asbestos D o t U point Gothic. tion# relative to exposure to asbestos re A fter th e Initial determ inations required May I s Hwudous TO quired by this paragraph. by subparagraph (1) of th is paragraph, T our Health. <2> Preptacement. T he employer shall sam ples shall be of such frequency and pattern as to represent w ith reasonable Spacing between lines sh all be a t least provide o r m ake available to each of h is employees; w ithin 88 t-- days fol accuracy the levels of exposure of em equal to the height or th e upper at any tffo lowing h is first employment far a a ployees. In no case shall th e sam pling be done a t Intervals greater th an s m onths CM Caution labels--Q) Labeling. Cau occupation exposed to tbbonoe con centrations o f asbestos fibers, a compre for employees whose exposure to asbestos tion labels shall be affixed to all raw m aterials, m ixtures, scrap, waste, debris; hensive medical examination, which shall may reasonably be foreseen to exceed and other products containing asbestos Indude, as a minimum, a chest roent- the lim its prescribed by p aragraph (b) fibers; o r to th eir containers, except th at of this section. etnogram (posterior-anterior 1 x 17 inches), a history to afiett symptom (3) Environm ental m onitoring--(1) no label ] required w here asbestos fibers have been modified by a banding agent, atology off respiratory disease, an d sam ples shall be collected from areas of coating binder, o r other m aterial so th at pulm onary function tests to Include forced vital capacity (FVC) and forced a work environm ent which are represent during any reasonably foreseeable use. ative of the airborne concentrations of handling, storage, disposal, processing; or expiratory volume a t 1 second (7H V,..). asbestos fibers which m ay reach th e transportation, no airborne concentra (S> Annual examinations. On o r be fore January 31. 18731 and a t least an breathing zone of employees. Sam ples tions off asbestos fiber* In excess off the shall be collected, on a m em brane filter exposure U nite prescribed in paragraph nually thereafter, every employer shall provide, o r m ake available, comprehen of 0.8 m icrom eter porosity m ounted in (b> of this section win be released. sive medical exam inations to each of his an open-face filter holder. Sam ples shall (11) Label specifications. The caution employees engaged in occupations ex be taken fo r the determ ination of th e S- labels required by subdivision (1) of this posed to airborne concentrations off as hour tim e-weighted average airb o rne subparagraph shall be printed in letters bestos fiber*. Such annual exam ination concentrations and of th e ceiling con o f sufficient size and co ntrast aa to be shall Include, as a minimum, a chest centrations of asbestos fibers. readily visible end legible. The label shah roentgenogram (posterior-interior 14 x (If) Sam pling fregnenev and patterns. state: A fter the initial determ inations required Caozmtv 17 Inches), a history to elicit symptom atology of respiratory disease, and by subparagraph U> of this parag rap h, Contains Asbestos Fibers pulm onary function tests to include sam ples shall be of such frequency and Avoid Creating re n t forced vital capacity (TVC) and forced pattern as to represent w ith reasonable Breaming Ashartas Dust May Cati*4 expiratory volume a t 1 second OTSVY.,). accuracy the levels of exposure of th e Sazloua BoiUy tb n n employees. In no ease shall sam pling be rimesan tKOffrs uni ua " U IB AND REGULATIONS 19\ 0 '93* />h<io<. (> D efinitions. For the purpose o this section, (l) "Asbestos'' includes chrysolite, amoslte. croddoUte, tremolite, anthophylHte. and actinolite. (2> "Asbestos fibers'* means asbestos fibers longer than 5 micrometers. (b> Perm issible exposure to airborne concentrations o f asbestos fibers-- if) Standard effective fa it 1. 1972. The 8-hour time-weighted avenge airborne concentrations o asbestos fibers to which any employee may be exposed shall no t exceed five fibers, longer than 5 micrometers, per coble centimeter of air, as determined by the method pre scribed in paragraph (e) o this section. (2) Standard effective July 1, S7C. The 8-hour time-weighted average air borne concentrations of asbestos fibers to which any employee may be exposed shall not exceed two fibers, longer than S micrometers, per cubic centimeter of air, as determined by th e method pre scribed in paragraph <e) o this section. (3) Ceiling concentration. No em ployee shah be exposed a t any tim e to airborne concentrations at asbestos fibers in excess of 10 fibers, longer than 5 micrometers, per cubic centimeter of air, as determined by the method pre scribed in paragraph (e) of this section. (c> M ethods o f compliance-- (1) B nffineertng m ethods. (!) Engineering con trols. Engineering controls, inch as, b u t not limited to. Isolation, enclosure, ex haust ventilation, an d dust collection, shall be used to meet the exposure limits prescribed in paragraph (b) of this section. (U) Local exhaust ventilation, (a) fival exhaust ventilation and dust col lection systems shah be designed, con structed. installed, and maintained in accordance with the American National Standard Fundamentals Governing th e Design and Operation of Local Exhaust Systems. ANSI Z9.S-1911. which Is In corporated by reference hereto. (b) See f 1910.0 concerning the avail ability of ANSI Z32-1911. and th e maintenance of a historic file in connec tion therewith. The address ol the Amer ican National Standards Institute is given in 1 1910.100. fill) Particular tools. All hand-op erated and power-operated tools which may produce or release asbestos fibers in excess of the exposure Umita p re scribed in paragraph <b> of this section, such as. but n o t limited to. saws, scorers, abrasive wheels, and drills, shall be pro vided with local exhaust ventilation sys tems In accordance with subdivision ill) of this subparagraph. (2) W ork practices--U> Wet m ethods. Insofar as practicable, asbestos shall be handled, mixed, applied, removed, cut, scored, or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers In excess of the ex posure limits prescribed in paragraph <b) of this section, unless the usefulness of the product would be diminished thereby. ill) Particular products and opera tions. No asbestos cement, m ortar, coat ing. grout, plaster, or sim ilar material containing asbestos shall be removed from bags, cartons, or o th er containers in which they are shipped, w ithout being either wetted, or enclosed, o r ventilated so as to prevent effectively th e release of airborne asbestos fibers in c e s s of the limits prescribed in parag rap h (b) of this section. (ill) Spraying, dem olition, o r removal. Employees engaged in th e spraying of asbestoat th e removal, o r demolition of Pipes, structures, o r equipment covered o r insulated with asbestos, and in the removal o r demolition of asbestos in sulation o r coverings shall be provided with respiratory equipment in accord ance with paragraph (d) (2) Ofl) of this section and with special clothing in ac cordance with paragraph (d) (3) of this section. (d) Personal protective equipm ent-- (1) Compliance with th e exposure limits prescribed by paragraph (b) o f this sec tion may not be achieved by th e rue of resplratora or shift rotation of em ployees, except: fi) During the time period necessary to Install the engineering controls and to institute the work practices required by paragraph (c> of this section: (li> In work situations to which the methods prescribed la paragraph Cc> of this section are either technically not feasible or feasible to a n extent insuffi cient to reduce the airborne concentra tions of asbestos fibers below th e limits prescribed by paragraph (b) of this section; or (ill) In emergencies. (iv) Where both respirators and per sonnel rotation are allowed by subdivi sions (1). (11), or (ill) of this subpara graph, and both are practicable, person nel rotation shall be preferred a n d used. (2) Where a respirator is perm itted by subparagraph (1) of this paragraph, it shall be selected from among those ap proved by the Bureau of Mines, Depart ment of the Interior, or the National In stitute tor Occupational Safety and Health, Department of Health. Educa tion. and Welfare, under the provisions of 30 CFR P art 11 (37 P J t 344. Mar. 25. 1972), and shall be used In accordance with subdivisions (1), (ID. till), and (iv) of this subparagraph. (1) A ir purifying respirators. A reusa ble or single use air purifying respirator, o r a respirator described in subdivision (ii> or (lil) of this subparagraph, shall be used to reduce the concentrations of airborne asbestos fibers in the respirator below the exposure limits prescribed to paragraph (b) of this section, when the celling or the 8-hour time-weighted aver age airborne concentrations of asbestos fibers are reasonably expected to exceed no more than IQ times those limits. til) Powered air purtfyino respirators. A full facepiece powered air purifying respirator, or a powered air purifying respirator, or a respirator described in subdivision (ill) of this subparagraph, shall be used to reduce the concentra tions of airborne asbestos fibers in the respirator below the exposure limits pre scribed in paragraph (b) of this section, when th e ceiling or th e 8-hoar tim eweighted average concentrations of asbestos fibers are reasonably expected to exceed 10 times, but not too times, those limits. <iii> Type "C" supplied-dT respirators, continuous fioto or pressure-dem and class. A-type "C" continuous flow or pres sure-demand. supplied-alr respirator shall be used to reduce the concentrato n s of airborne asbestos fibers in the respirator below the exposure limits pre scribed in paragraph (b) of this section, when th e celling or the 8-hoar tim eweighted average airborne concentra tions of asbestos fibers are reasonably expected to exceed 100 times those limits. llv) Establishm ent o f a respirator pro-, proix. (a) T he employer shall establish a respirator program in accordance with the requirements of the American Na tional Standards Practices for Respira tory Protection, ANSI 2883-1980. which Is incorporated by reference hereto. b. See 1 1910.8 concerning the avail ability of ANSI 288.3-1969 and the m ain tenance of an historic file to connection therewith. The address of the American National Standards Institute is given to i 1910.100. (c) No employee shall be assigned to tasks requiring the use of respirators if, based upon his moot recent examination, an examining physician determines that the employee will be unable to function normally wearing a respirator, or that the safety or health of the employee as other employees will be Impaired by his use of a respirator. Such employee shall be rotated to another job or Uven the opportunity to transfer to a different po sition whose duties he is able to perform with the same employer, In the same geo graphies! area and with the same senior ity. status, and rate of pay he had fust prior to such transfer, if such a different position is available. (3) Special clothing: The employer shall provide, and require the use of. spe cial clothing, such as coveralls or similar whole body clothing, head coverings. Ifioves, and foot coverings for any em ployee exposed to airborne concentra tions-of asbestos fibers, which exceed the ceiling level prescribed in paragraph (b) of this section. (4) Change rooms: (i) At any fixed place of employment exposed to airborne concentrations of asbestos fibers in ex cess of the exposure limits prescribed In paragraph (b) of this section, the em ployer shall provide change rooms far employees working regularly a t the place. (11) Clothes lockers: The employer shall provide two separate lockers o r con tainers fo r each employee, so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes. FfStlAL uemn Vffl Ty un W--w . . . . . . . BULES ANO REGULATIONS (4) Termination o t employment. The employer shall provide, nr make avail* able, w ithin 30 calendar days before o r a fte r the term ination of employment of any employee engaged in an occupation espceed to airborne eoneentratlona of asbestos fiber, a comprehensive medical Hcim ination which shall include, as a minimum, a chest roentgenogram (posLexter-anterior 14 z IT Inches), a h istory to elicit symptomatology of respiratory diseas, and pulmonary function testa to Include forced vital capacity (PTC) and forced expiratory volume a t 1 second CRSViil, (9) Recent examinations. No m edical exam ination la required of any em ployee. it adequate records show th a t th e employes baa bees examined in ac cordance w ith this paragraph w ithin the p ast 1-year period. (5) Medical records--(1) M ainte nance. Employers o t employees examined pursuant to this paragraph shall cause to be main tained complete and accurate records of all such medical nm m lnaUons. Becnrds shall be retained by employers for a t least M yearn. (ID Access. T he contents a t th e reelords ss fiu m ntfril gapgnlm tfin required by this paragraph shall be m ade available, for inspection and copying: to th e Assistant Secretary of la b o r te r O ccupational Safety and Health, tire Director of MIOSS, to autborteed P to d - m g medical consultants ot either of them. and. upon th e wmert oTa n o n - playee o r farmer employe* to " J J W 3*- d a n . Any phreJdan who e a rdneto a medical i iiiiiiiilniHnn required by this -----. .h .n fam h h to be.employer of th e examined employee aU the infor- m s rin n specifically required h r tWa naragraph. and any other morttau re formation related to occupatkmal ex- 4a asl>efrn fllw M . DEPARTMENT OF HEALTH & HUMAN SERVICES AFFIDAVIT Office of the Secretary Office of the General Counsel Pi*Be Health Division CDC/ATSDR Standi <600 Clifton Road. N.E., MIS D53 Atlanta, Georgia 30333 (404) 639-7200 I, CECI VELASCO being first duly sworn, deposes and states as follows: 1. I am a Legal Technician in the Office o f the General Counsel, Centers for Disease Control and Prevention (CDC), United States Department o f Healtli and Human Services. I make this affidavit upon personal knowledge, and where indicated, upon the basis o f information communicated to me by employees of the United States because o f my official position. 2. In my position, I am a custodian of and authorized to certify official records of the U. S. Department o f Health and Human Services. 3. The attached record, imprinted with the official CDC seal, is a true copy o f official records o f CDC, an agency o f the U. S. Department o f Health and Human Services. 4. The document referred to above are part o f the official records o f the United States Department o f Health and Human Services. Page Two I declare under penalty o f peijury that the lbregoing is to the best o f my knowledge and belief true and coned. Executed at Atlanta, Georgia. State o f Georgia) County o f DeKalb) Subscribed and sworn to before me this June, 2004. day of G M l. b* & l Notary Public 01^ OtAB. DtGtCXA,N.P. BARROWCOUNTY. GEORGIA MYCOMMISSION r.'iPt'CS SEPT. 19,2007