Document 91QkD5YDMQo9G2qLkzaMw3ZO3

CONFIDENTIAL EXHIBIT DUE-1349 June in, 1972 TO: PRCX: J. S. TC:5 ASBESTOS SAPETY - PROGRAM Our aebeetoe safety prograr. Is divided late flvs 1. Control of asbestos dust 2. Respiratory protection 3. Personal hygiene t. Stapling 5. Medical nenitoring 1. Control of Asbestos Oust The principal sources of asbestos dust exposure are saving and cutting, removing old insulation, opening boxes ef new insulation, nixing and handllna asbestos eeseat and . - . reaovsl of clothing after ccspleting insulating work. Our progrts includes a aunber of activities for controlling the dust hazard froa these sources: . * Further lapreveaents and reflneaents will be aade to the exhaust aystsas In the insulation fabricating shop. * Portable work benches that collect the dust when block Insulation Is hand cut or sawed in the field will be provided. - * Insofar aa possible, the werk areas and Insulation sterage*. areas will ba Isolated free the gang headquarters and . eating areas. ' Vacuum clean-up- systecs will be provided for ainlsixing dusting during cleanup of shops and storage areas. . Vacuuming the aeeusulated dust froa new cartons cf blcck insulation whan the eartona are opened will be established as a writ practice. Insofar as possible the natural *dust catchers" in the insu lation fabricating shop, such as cracks, erevless, ledges, etc. will be ellslnated. DUP 090186* S000257 DU 023258 *. 2. 5rSy UUiii IUL.H i mu 2 June ii, l?72 * Th procedures for handling b tightened up to minimise and mixing asbestos exposure. eeir.cnt win Our procedure will be tightened up on removal of old insu lation from piping, vessels', etc. by requiring wetting down prior to and during removal and the use of respirators. The handling and disposal of scrap insulation will be control led more rigorously by including wetting down, use of scaled plastic bags and "insulation only" dumpsters for keeping scran insulation separate from other types of scrap materials. Warning signs as per OSHA specifications will be obtained asd displayed at locations where asbestos dust hasards are present. The timing on the completion of the various activities hss net been established yet. frimarlly this la because we are duet getting started and bceauee insulator supervision has been in a state of change. H. Nunley.replaced J. B. Vlnfree as Insulator Supervisor on funs 12, 1972. J. Givens will be assigned foremen responsibilities for roughly one half of the insulators for the first time when he returns from vsestlen on June 19. S. Vend*vender, the ether insulator foreman, hss (until this weak) been running a gang of 25-35 insulators and has not been available to work on the program The longer range items in this part ef the program are' the vacuum systems and the isolation of the work areas and storage areas free the headquarters and eating areas. Some of the other items... Involve, more than anything else, educating the Insulators' to do things differently than they have dene them in the past. Our objective is to train thea and change their work habits but with out sctrim then. The speed with which these items can be accomplished will be governed largely by this objeetlvo. 2. Pesolrstorv Protection A number of things will be done to improve respiratory protsetlon and bring our praetlcas in lino with OSHA, requirements: * A respirator program will be established in accordance with the-requirements of the American National Standard Practice for Respiratory Protection Z68.2-1969. (We have ordered a copy of 2*.2-199.) * Procedures will' be established for inspecting, cleaning, and storing'respirators.' * The proper types ef respirators mooting 03HA requirements fer our particular levels ef asbestos dust eeneentratloas will be determined, specified and obtained. OOP 0901869 S000J5S DU 023259 W. H. Eraiy wum luum ial -3- June It V IM use of respirateri vill be expanded from toe prse-` ltvtlt of uss. Per example, respirators will be required when tabtste* insulation is removed and when hand euttlnc and sawing where vacuum removal of the duat la not pro. vided. A (lma tabl* for completing this phaa* of th pregrshat not yet been aatabllihad. Again, wa ara Just gattlng started'.' The flrat task la to find out exactly what la required to maat OSHA apaelfleatiena. Harry Nunley haa baaa glvan this responsibility. a 3. Personal Hygiene Tha elothing of man working with aabastos Insulation must ba kapt fraa of dust accumulations. Also, It la aasantlal that thay avoid breathing aabastos dust whan removing thalr work elothaa. Zt la also naeassary to avoid asbestos duat when placing food, .tobacco, gum, ete. In the mouth. The following steps will be taken to Improve our position as regards the problem of perscnal hygiene: * Isolate (Insofar as possible) the work areas and insulation storage areas from the headquarters and eating areas (this : Item listed In the first section also). -- * Restrict men from putting food, gum, tobacco, and other materials In the mouth in work areas where asbestos dust may ba present, and prohibit these materials from being kapt In tha work areas. ...... * Provide vacuum facilities so men can vaeuum their work elothas " prior to coffee' break, luneh, and quitting time. ^ The isolation of the work areas and storage 'areas from the headquarters and eating areas will pose the greatest problem la the west end of the pleat where the present facilities are temporary and where a time schedule fer moving Into permanent facilities in the old nylon offioe has not been established (as far aa we know). A study is underway for effecting the necessary changes-and rearrangement -at the Insulation fabricating ahep and :-.at the east-mnd-lmsulator headquarters. .-At this point, we see . " no reason vhy the changes at -these latter two locations will net. be completed by around sld-year. ; .* , * ' 1 -rTho restrictions on the consumption ef food, tobaceo, etel in the work great is a mattar ef education and then enforce- . sent. We will move In on this as soon as we get the eating areas Isolated fro* the work areas. " A schedule fer the vaeuum systems has not been established. The first order ef business here la to determine what la needed and the eost. Sere again, we are Just getting started. DUP 0901.70 ,000JH DU 023260 I !>.*-! I I- : - 1, - 72 . Sameling We took our first air sample to determine asbestos fiber concentration on 3/7/72. To date, a total of five samples have been taken. All.were made in the insulation fabricating shop which is our greatest ex&osure area. All of the sample results have been below OSHA permissible limits with the highest reading being 2.8 fibers. Much more sampling work is planned. This is necessary in order to develop the documentation necessary to represent accurately the level of exposure of our 'people. .Beginning this month and for an indefinite period of time, Jl-5 samples will be taken every month. - Samples will be collected with the sampler intake attached ' to the worker's lapel within the normal breathing zone or as per OSHA specifications.' Both 8-hour time weighted average samples and 15-minute highconcentration samples will be taken. Sampling will be conducted in all areas in which our people : lare'exposed to concentrations of air-borne asbestos dust*- 'not Just in the shop area. The need foz- a second sampler will be determined, and if one 'is needed authorization for the purchase of this second unit 'will be requested. 5. Medical Monitoring ' It appears that something more than in the past will be required In the way of record keeping and medical monitoring of employees exposed to asbestos dust. A program will have to be developed -in conjunction with Medical when sufficient information becomes available to determine what is needed. Again, we are Just getting started. *$!*?** :r* JBY:orm ; A DUP 0901871 B000260 DU 023261