Document 9GDEvQBbXXaBae9DqnobnLND

1 March 29, 1983 @awt Amencan Teieohone and Tatagraon Comoany 295 North MacX# Avenue Basmng Ridge N J 07920 Phone<2011221-2000 Hr. Darrell Mactheis Organization Resources Counselors, Inc. 1625 1 Street. N. W. Washington, DC 20006 Dear Darrell: Attached are the rationale statements for sections (d) and (h) of the Draft Standard for revision of 1910.1001. 1 aa looking forward to the next meeting on April 11 and 12. Very truly yours. James M. Degen District Manager - Occupational and Environmental Safety Attachment CONFIDENTIAL 005486 DRAFT ASBESTOS STANDARD: RATIONALE (d) Compliance Program A written compliance program to reduce employee exposures to levels at or below both the PEL and the ceiling level is an integral part of any overall asbestos control program. The written program must be individu ally structured to address the specific problems, sources of exposure and unique circumstances that characterize each employer's particular situation. The wording proposed in section (d) is performance oriented to allow employers sufficient flexibility to adapt compliance programs for their specific work places that are effective, practical and cost-efficient. The important measure of the written compliance program is not length, complexity, or adherence to a mandated structure, but rather whether or not it accomplishes the desired goal; namely, reducing employee exposures to or below the PEL and the ceiling level. There is little constructive value in requiring an employer to prepare a written compliance program if no employees are exposed to airborne asbestos fibers at levels above the action level. The action level, even though below the PEL, was chosen as the trigger mechanism for a written compliance program for several reasons: . While che action level is below the PEL, both the action level and the PEL are 8 hr TWA levels and do not guarantee that che ceiling level is not exceeded. . Monitoring results are subject to variability in actual exposure from day to day as.well as errors in sample analysis. . The action level is a recognized benchmark for other provisions of the asbestos standard; introduction of a separate benchmark to trigger a written compliance program would only add needless complexity to the standard. 005487 DRAFT ASBESTOS STANDARD: RATIONALE (h) Hygiene Facilities and Practices The us* of personal protective equipment and clothing will not achieve axioms protection for employees unless supplemented with facilities and practices for personal hygiene. The requirements of section (h) provide the basis for achieving this protection while still allowing the employer sufficient flexibility to adapt the basic requirements to indi vidual facilities. Change areas should be provided for the removal of protective equipment and clothing at fixed work locations. It is both practical and good _ hygiene practice to require change areas at these fixed locations. The basic object of the change area requirement is to minimise contamination of nonasbestos work areas or other facilities used by employees. In the case of nonfixed work areas, or mobile employees and crews, fixed change areas such as locker rooms are not only impractical, but may defeat their intended purpose if employees have to travel any distance in their con taminated clothing. In cases such as these, a more practical solution is to remove protective clothing such as coveralls at the completion of the task that required the use of the protective clothing. The contami nated clothing can then be placed in appropriate containers either for reuse, laundering, or disposal. This approach will minimize contamination of public areas or vehicles in the case of mobile work forces. The requirement for washing facilities provides those elements that are necessary for employee protection whenever employees are required to use respirators or wear protective clothing. The essential element is that employees wash all exposed areas. The small Incremental gain in pro tection that may be afforded by requiring shower facilities and mandatory taking of showers would be negligible at best. The requirement for storage of clothing is flexible in that it does not mandate one method over another. The basic goal is to prevent contami nation of street clothing and clothing which may be worn by another employee. This requirement may be satisfied by provision of special lockers or special containers. The requirements for laundering are straightforward and Intended to provide protection for fellow employees, laundry personnel and the general public. The requirements do not preclude the use of disposable protective clothing, provided that such contaminated clothing is placed in sealed containers and appropriately labeled prior to disposal. 005488 OCCUPATIONAL SAFETY & HEALTH REPORTER A IM# at occupMional tally and VeMne D. Nambor S THE BUREAU OF NATIONAL AFFAIRS. MC. Jana M, INI one RECOMMENDS LOWER EKFOSURELEm. nmuau need for emfloybe trabmio Tbc OaayaUcaal fafaty eadtt MbAdMaiaNMMb ml RmWR U|*w EM y-r tHt wndmUw ^wll R mM IwmN > I Ml bet lo ccwd j abas per cable caalMalar'* ae E^l boar Ume-weigMed average alcberaeceeceatfatiao,aaaard- lag lo OrgaalraHea llaiifca Ocaacclare. lac. la a Jaae etaiwnaal t Ibc ageacy. the iimNUm autataiaed Ikat tba praeeot expoeare leva! it "iaadagaale la prelect vartan." and aaa* la bt pranptiy ncMUaN by baevUdge af tba rNb Ibc ladartni groaa tbalto Iba aeoaltoriag. ceOactiaa. aad aaalyNa at atrberoe Mall af aabaaNa." aad caatiaaod (bat tbara N "aa aft Orabald Nr eapaaara la aabaalaa Eban Ibat cm be ptaeaa by aeadan la April. OSHA aaaoaacad that I will apcalirala rataaaab- tag aa a l* agaaey prapaaal to laaar tba carnal a^eaar* MnM baa baa Eban la aaa-balf Mar yar cable caatteetar aad cayacta la Mac a aabUc aoUea Ibia aanaaar. laDevad by baailagi aad a Mai tale by IbN fall (Uarraat Raperi. April 14. p. Mil Aceanttag la ORC, geaaral lajaatry abaaM be ghaa a year tram tba effective dale af a flaal ffandard la arMavi ar Umita la cat Sbcr par coble caatinatar wttbia cat yaar aad ta BA Bben per cable caaUmalar vttbia leer yean." CONFIDENTIAL 005489