Document 9J7xeDjbR6pxNR3pjd6JYmBrq

/a-II-73 a i'-TliOOO TITR1 /loriEsroi, Tesrs Fore. FeDE(?/-iL E", R/|. OAMPLtrS- Trii'iS'fl o kj iS*vr. "Dex.Sj 1^73 llT set U.P 3 57/iT/oue 45 1 Pcr /wTachfp Jkc'tch. Tkivv* took cl 5/nttpurs. />r e/kh stat#// om,1 //PF>RoK. 3 o'Ml IQHT oOe <7T HEI&tfT. SiE<5 ^TT/^CHlfi) DR/7LU/W^S cu .:(Vt up, l^tPiTHE R. CoaJDiTiOM^ cTiT/T I Oif D Frf- (V/>uKe~C; v>*J tfc./'lOP lA L /hfzpaQT- vipppck 3/7) U)c`oT 0(0 PlPtcT l.(o f^cai pLShJT. f\\oofO Rev-iotK)c s - jtrKip, 3^ - LO.ajd. 5'SKJ/it 10 - /SP)PH. 94?,30.3 */?PRr\. . 1/ 30 - /, Si>uJ ' /. 3?.2` l^su/u. plu^c pkci'] Cc/vnoKnoir/u.TH 'IzDisckL bem tv i/^py rpi-\ $> ref^/T'oifp/^'o TOST PefSioD, (_ UcCnn S - - M F - j/^pn ` , ) FunPi - B-Q.T ' FlOlO Rf\i - 2.5 70 30 CfP\ ' LO/U Ut/pf Dll TP Gt/^PPlOAl VOi.XOCtf.. tS pfi Pc ft. " S' > }jf*. \J O^PL SAMpLerS RtPd Tf-lKtTU AT ^T^TiOiO D-/ amp 5taT'OW D-<, ^SFD ^ Cj^Lfc^OA'*" f~IL-TC R f'lu'-pp...J.fl/ &C(\UL*1H F/LTGlp. A?4>7#/cVr?.V P-tif&K nr p. Mn.rc.v-i HtvGHT. Could> oor put both to SF'rtCC. poll out tp jokp or ' 'u\c\\ BIt _ rt T.0' Hk'C-HT 5kT UP ^aM.MEETEE''1I^ 12 ii~ Vi ' **** .J CRMC-Christensen-Micro-000003 J Hl/luli Johns-Manville I Internal Correspondence III L. I. RICHARDS - DENISON Dale: FEBRUARY 10, 1978 from D. R. CHRISTENSEN - R&D Copies: C. SMITH - DENISON G. L. SWALLOW - 1-06 T. M. FAAS - 3-07 Sub, eel: AIRBORNE ASBESTOS SAMPLE - FITTINGS LATHE OPERATOR (D- 14F) DENISON PLANT, PIPE DIVISION - 2/8/76 i A single* sample for airborne asbestos fiber was collected at the Fittings Lathe Operator dust station (D-14F) by Cecil Smith on 2/8 and forwarded Lo our lab for analysis. This sample yielded a result of 0.1 F/cc. Previous results were: 0.1 F/cc & 0.0 F/cc (11/15-16/77) and 2.3 F/cc (4/21/77). Low results since the survey of April, 1977 are apparently the result of ventilation improvements at station D-14F. D. R. Christensen KJWiDRC CRMC-Christensen-Micro-000004 0. MARKUSSON - 2-fM '' Kieroo II IJOV. 5, 197G n. rlitze - l-nr, emus n usi'm r i > asr-t.tos exposure mixing insulation cements [i. p.. cupirTrr:s::?i's memo to you - October ifj.. i()7C i po r.oT rpan to state or infer that the figures that peony cur i stenshu gave you of tiie recent sampling at ah ARP. TSTOS -CEMENT SI MULATTO MIXING SITE ART IN ANY WAY IN ACCURATE . I WOULD, HOWEVER, LIKE TO POINT OUT THAT CONDITIONS FROM JOE SITE TO JOE SITE DIFFCR. I HAVE HAD CONSIDERABLE EXPERIENCE DURING MY SELIKOFF DAYS TAKING SAMPLES ON VARIOUS .JOH SITES WHERE CEMENT MIXING WAS IN PROGRESS. MY OWN TEST RESULTS INDICATED THAT IN SOME CASES THE FIGURES RAN FROM 7.0 - 40 F/CC FOR LARGE TROUGH MIXING AMD UP TO 80 F/CC FOR Till: SMALL PAIL MIXING OPERATIONS WHICH ARE PROBABLY FAR MORE COMMON THAN THE TROUGH MIXING. W. P. REIT 7 E i is CRMC-Christensen-Micro-000005 J t i ltd Johns-M.'inwilli; i*wm Interna! O.irrest 1(1 1). Markusson - 2-03 ^ October 19, 1976 rum 1). K. Christensen - KM) C, . I,. tiwa 1 1 < w f . V i to - I-OG - 3-09 J. II. ZcUel - UM> S. lieniior - U&D pxi'uttiiKt; mixing :innui.ation ckmkntn, IMUbATbD 1`JGO's CONDITIONS, 2ND sampling, u&d The mixing of i nxul at: ions cement was repeated on October 8, L`)7G. As everyone is aware, the purpose of these tests wore to simulate conditions as they existed in the early lOGO's. Consequently, an area inside the Power House was chosen as the mixiivj site in lieu of the trailers which we re re: turned . A number of differences existed in this test compared to the last Lest. for example, the 7M-13 fiber used in this test war, pressure packed and willowed which produces a much looser fiber. The fiber was [jacked in loose plastic bays compared in a tight, pack bag initially. Also, the operator mixed 700 lbs of fiber this series, compared to 50 lbs during the first mixing operation. The willowed fiber for.this series of tests, eliminated the need for the "dry hoeing operation" performed origina11y. To determine the operator's exposure and to duplicate sampling procedure as in the 1960's tfie "Standard Impinger Sampling Method" was employed. The method utilizes a Greenburg-Smith impinger operated at. a flow rate of J.O Cl'M. This is the exact method used in lhe LOGO'S for asbestos determination. .Six impinger samples were taken over the approximate 3 hrs of mixing. All six impingors were taken for 15 minutes during the mixing operation, which consisted of: tossing the fiber into a dry tub by hand, distributing the fiber in the tub evenly by hand, adding water from a hose, mixing with a hoe to proper balmier;, and asiding the cement into a five gallon pail which eventually was dumped outside. CRMC-Christensen-Micro-000006 1). Markusson - 2-03 -2- October 19, 1976 The results appear below: Samp 1e 'll*j . 1 ) i 1 r> Descr ipt i on During During During During During During mixinq, mixinq, mixing, mixinq, mixinq, mixinq, 11: d'j 9:20 10:16 10:45 11:10 11:28 a. m. a. m. a. in. <J III * a. m. a. rn. T.L.V. (mppcf) 6.0 6.0 5.0 5.0 5.0 5.0 Result. 55 (mppe E) 2.3 2.9 2.9 2.2 2.1 1.8 A second samp I i ikj method was employed to have at hand results of" I lie currently accepted OSIIA method for asbestos determina tions. This method involves the collection of fibers on a filter media at. a flow rate of 2.0 liters per minute. A phase contrast microscope is used as the analytical tool. The results appear below: .`'.ample No. 1 2 3 4 r) 0 Description & `J1 ota 1. .6amplinq Time Durinq burinq Durinq burlnq burinq Durin(j mixinq mixinq mixing mixinq mixinq mixinq operation (30 operat on (30 operation (60 operation (60 & clean-up(80 & ciean-up(80 min) min) min) min) min) min) l'.L.V. (F/cc) 3.0 2.0 2.0 2.0 2.0 2.0 Results (F/cc) 2.0 0.9 1.9 2.6 1.8 2.0 in conelu si on, !: he mixing operation this time appeared much more indicative of 19G0's conditions. First, the fiber was not press ure pac kod (it was willowed) as it was for the or icjina 1 tes t:s , and secondly, the amount of fiber used this time appeared to be closer to what was used in the 1960's. I). R. Chris ten so mi DAA:UKC:ee CRMC-Christensen-Micro-000007 donns-Manvwe To D. 11. Markusson 2-03 miernai p. Dai*: September Fr mil' D. R. Christensen - R&D Cop.rs E. M. Fenner W. 13. Rcitze 4N3 4N2 G. L. Swallow - 4N2 J. H. Zettel - R&D Subject: ASBESTOS EXPOSURE WHILE HANDLING THERMOBESTOS INSULATION AND MIXING INSULATING CEMENTS SIMULATED 1960's CONDITIONS The purpose of these environmental determinations was to simulate and quantiate conditions that existed in the 1960's while sawing THERMOBESTOS pipe insulation and mixing insulating cements. Two 4 0 >: 0 ft enclosed trailers were rented to be used for storage, sawing and mixing. Sawing, the initial phase of the sampling, was conducted inside the trailer with no mechanical ventilation provided. Slight breezes did provide some natural ventilation through the open rear doors and the partially open side doors. The sawing phase was done on August 17, 1976. The simulation involved obtaining various sized pieces of THERMOBESTOS pipe insulation from the storage trailer, carrying the material to the second trailer, removing the cloth covering, sawing on a band saw and asiding the cut pieces. This sequence was carried on throughout the day at a pace equivalent to a normal work day. The environmental sampling was done by three methods. The first method was the "Standard Impinger Sampling Method" which utilizes a Greenburg-Smith impinger operated at a sampling flow rate of 1.0 CFM. This is the method used in the 1960's for asbestos evaluations. The results of these determinations are as follows: STANDARD IMPINGER SAMPLING METHOD (1960's) Asbestos Threshold Limit Value (1965) Test Result 5.0 mppcf* 5.0 mppcf 5.0 mppcf 5.0 mppcf 5.0 mppcf 5.0 mppcf 102.7 mppcf 109.1 mppcf 87.8 mppcf 116.9 mppcf 139.7 mppcf 112.7 mppcf Million Particles Per Cubic Foot m CRMC-Christensen-Micro-000008 D. II. Markusson - 2-03 -2- Septembor 2, 1976 The above samples were taken throughout the work day for durations of 15 minutes, as was done in the 1960's. The second technique used was the currently accepted OSHA method for asbestos exposure determination. This method involves the collection of asbestos on a filter media at a sampling flow rate of 2.0 liters per minute. The results of these determinations are as follows: CURRENTLY ACCEPTED OSHA METHOD (1976) Sample Type Operator, Personal Asbestos Threshold Limit Value (1976) 2.0 F/cc TWA** 2.0 F/cc 2.0 F/cc 2.0 F/cc 2.0 F/cc 2.0 F/cc 2.0 F/cc 2.0 F/cc 10.0 F/cc PEAK*** 10.0 F/cc Test 1Result 14.1 F/cc 9.9 F/cc 8.1 F/cc 7.1 F/cc 9.2 F/cc 10.3 F/cc 13.8 F/cc 11.3 F/cc 18.5 F/cc 16.2 F/cc Area Sample 2.0 F/cc 2.0 F/cc 2.0 F/cc 2.0 F/cc 13.4 F/cc 6.8 F/cc 3.5 F/cc 2.8 F/cc **Fibers per cubic centimeter. Time Weighted Average ***Peak Exposure (15 minutes) The third sampling technique is not related to asbestos ex posures but is supplied for informative purposes only. This sampling was for silica dust concentration determinations. The results showed that less than 1.0 percent quartz and less than 1.0 percent cristobalite existed in the respirable fraction of the generated dust. Sampling in accordance with the present day silica sampling methods was done with the following results obtained: a CRMC-Christensen-Micro-000009 D. II. Markusson - 2-03 3- September 2, 1976 CIJRKENTLY ACCEPTED OSIIA METHOD (1976) - SILICA Silica Threshold Limit Value (1976) 5.0 mg/M3 5.0 mg/MJ Test Result 6.97 mg/M3 20.63 mg/M3 The mixing of insulating cement was done on August 18, 1976. This simulation involved mixing 7M-13 fiber in a 2 x 4 ft trough inside one of the trailers. The sequence of mixing was carried on throughout the day at a pace equivalent to a normal work day. The environmental sampling consisted of the same methods employed when sawing THERMODESTOS with the exception that no silica work was done. The results of this sampling are as follows: STANDARD IMPINGER SAMPLING METHOD (1960's) Asbestos Threshold Limit Value (1965) 5.0 mppcf 5.0 mppcf 5.0 mppcf 5.0 mppcf Test Result 4.6 mppcf 3.3 mppcf 1.4 mppcf 1.6 mppcf CURRENTLY ACCEPTED OSHA METHOD (1976) Sample Operator Asbestos Threshold Limit Value (1976) 2.0 2.0 2.0 2.0 10.0 10.0 F/cc F/cc F/cc F/cc F/cc F/cc TWA PEAK Test Result 4.8 3.1 5.9 5.5 6.6 6.6 F/CC F/cc F/cc F/cc F/cc F/cc Area 2.0 F/cc 2.0 F/cc 3.6 F/cc 1.1 F/cc CRMC-Christensen-Micro-000010 I). II. Murkusson -2-03 f 4 September 2, .1976 In conclusion, I would like to make a few comments on the authenticity of the simulated conditions of our testing. During the late 1960's and early 1970's I visited several of the insulation warehouse operations in the United States. I believe that our work would represent the worst conditions that existed for sawing material and about average or slightly below average for the cement mixing operation. D. R. Christensen ee CRMC-Christensen-Micro-000011 u M l BCC: *' ' H. M. JACKSON F. J. SOLON, JR( C. L. SHECKLER CARIi THOMPSON DICK NARROW M. M. SWETONTTC After discussing w'th Hugh Jackson and Cliff Shcckler on 5/2/6 I also sent Mr. Ruddy copy of the NIMA booklets,icopy of the new tentati) standards proposed..jl/ the ACGIH and copy of J '*p**~?- by Dr. S tokingejm^ `'concerning these standards /i y Tj May 1, 1959 Mr. Ned Ruddy E:: g c u t i v e Sec r e t a r v Shipbuilders Council 1730 K. Street, N. W. Y7ashington, D. C. . Dear Ned: Many thanks for contacting Johns-Manville, through Hill & ICnowlton, with regard to the effect of the Wslsh-Healy Act upon your industry, with particular regard to the Thrashold Limit Values pertaining to asbestos fiber. As I mentioned, we recently prepared- and gave to the Department of Commerce some background material on the various research programs in the area of asbestos and human health that are being sponsored or co-sponsored by Johns-Kanville. I am attaching a copy of this material for your use in your discussion with the Labor Department on Monday. .. ,,. . A3 we agreed on the phone, it is going to take time to develop the necessary techniques and equipment to provide maximum protection to workers who handle and apply asbestos-containing products in the field. The Insulation Industry Hygiene Research Program, describedin the attached green six-page report represents, we feel, the proper approach to this problem. Embracing, as it does, science, industry and labor this research program represents a voluntary approach us contrasted to governmental regulation. If, after reading the attached, you have additional questions, please give me a call. Sincerely, wpr/eb att. W. P. Raines Director of Public Relations f uirei CRMC-Christensen-Micro-000012 (' ( April 11, 1969 ' JOHNS-WANVILLE COMMENTS FOR DEPARTMENT OF COMMERCE // RE IIR 2503: "A bill to promote the safety of workers engaged > in making asbestos products for shipment in commerce, and for other purposes." GENERAL Johns-Manville Corporation and the asbestos industry in general support the objectives of this measure -- "to promote the safety of workers engaged in making asbestos products" -- and are vigorously pursuing programs of health and safety protection in asbestos plants as well as among fabricators and applicators of certain asbestos products. It should be made clear that the manufacturing, installing, handling and selling of asbestos-containing products per se constitutes no health hazard. However, the industry recognizes, and has long been controlling, occupational conditions where excessive dusts from asbestos may constitute a health hazard for workers exposed to these dusts', over extensive periods of time. The manufacturers observe strict health safety practices under such conditions and also actively cooperate with their applicators and fabricators in promoting health safety practices in the use of asbestos products under conditions where dusts might be generated. SPECIFIC COMMENTS ON PROPOSAL 1. A special bill dealing only with the asbestos industry would be unnecessary, undesirable and duplicative. Congress has before it legislation that would establish federal administrative machinery CRMC-Christensen-Micro-000013 for health and safety protection applying to all U.S. industry. IIR 3809, the Occupational Safety and Health Act of 1969, is one of several such measures before the House and Senate Labor Counu i l i ' . Those bills would vest authority, in the Department of Labor working with the Department of Health, Education and Welfare. These proposals spell out in some detail the limitations of authority* the methods for setting safety and health standards, and the res ponsibilities of industry, labor and established standard-setting agencies for cooperating with the federal agencies. HR 2503 relating only to asbestos would vest all authority in the Department of Health, Education and Welfare, including inspection authority, which would, in effect, duplicate the existing and proposed responsibilities of the Department of Labor. 2. HR 2503 is too broad and non-specific in its provisions. As presently written, its provisions would appear to apply to many small retailers who merchandise such products as roofing, floor tiling, wallbroad, or ceiling tile which contain asbestos bonded with other materials, such as cement or plastics. Such items do not constitute a health hazard and yet the provisions of the bill would seem to encompass them. _ 3. The standard-setting authority that would be granted to the Secretary of Health, Education and Welfare does not provide for orderly consultation with established standard-setting organizations , CRMC-Christensen-Micro-000014 fr or with industry (ay iu generally recognized as desirable in other Occupational Safety and Health proposals). The fact is that standards for occupational levels of asbestos dusts (Threshold Limit Value) were re-examined and modified in 1968 by the American Conference of Governmental Industrial Hygienists, representing federal, state and municipal governments. These standards are accepted by industry as well as federal and date safety and health officials for enforcing federal and state laws respecting occupational safety and health. CONCLUSIONS If Congress decides that legislation should be enacted establishing a federal Occupational Safety and Health Program, the asbestos industry, along with other industries, would be subject to such an Act. This would be the more orderly and acceptable method of procedure ;-- legislatively, administratively, and from the industry standpoint. A separate act relating only to the asbestos industry is unnecessary and undesirable. ## (For industry health and safety pratices, see attachments.) CRMC-Christensen-Micro-000015 Jphns-Manville Internal Correspondence To from; LGi.. I. Steallew-GHQ R. J/ Haegl Dai; August 7, 1974 y\ Copies Sublet See end of memo SEMI-ANNUAL INDUSTRIAL HYGIENE SURVEY DATED, MAY 23. 1974...................... .. DEVELOPMENT DIVISION-MANVILLE ACE-^ 3 ? We comment as follows regarding the subject report of Station D16-A over TLV as follows: This area is a newly established station in which the cores of cut ACE CORSPAN Panels are filled with strips of fiberglass insulation. Apparently, loose asbestos cement dust (from cut ting) within the cores is disturbed during this procedure. The plant will investigate the use of a vacuum cleaner to remove the loose dust in the cores, prior to filling them with fiber glass^ Also, all operators will be instructed to wear a res pirator while performing this operation. A re-test will be requested as soon as the plant feels the condition has been corrected. \ cc: R. A. Paddock R. K. Hoagland a*-- J. E. Hesse D. E. Hillier E. J. Bulava D. R. Christensen W. B. ReitsL M. A. Baloga file/chrono mb H. i J Ci 6L - JLU 7 CRMC-Christensen-Micro-000016 IZ\ Johns-Manville F. J. Angelos - Waukegan E. J. Bul&va - Manville v 0. R. Christensen - Denver L. A. Schriver - Lompoc E. G. Stevens - Jeffrey From: M. A. Baloga - Denver GHQ Swallow copic?ne! chron Subjact: SEMI-ANNUAL SURVEYS ASBESTOS STATIONS OVER 2.0 F/cc Internal Correspondence Data: November 8, 1973 As part of our reorganization and revised sampling policy, the semi-annual surveys will consist of sampling all asbestos sta tions which were over 2.0 F/cc on the most recent survey prior to the semi-annual. - In order to comply with our new reporting format, it is essen tial that only those stations above 2.0 F/cc be sampled. If any stations which do not fall into this category are sam pled, please be sure to indicate those stations on the data sheets sent to D. R. Christensen. It would also be helpful if the reason for additional sampling were indicated, such as p'ant request, etc. M. A. Baloga MAB/jmb CRMC-Christensen-Micro-000017 31 Johns-Manville Internal G. L. Swallow Date: October 1, 1974 tr F. J. Angelos Copies: D. Christensen file Subject: SEMI-ANNUAL INDUSTRIAL HYGIENE SURVEY WAUKEGAN PIPE DIVISION The Semi-Annual Industrial Hygiene Survey of Waukegan Pipe was conducted September 9-30, 1974* Only three occupational dust stations (for asbestos) were within the 42.0 F/cc cat egory, i.e. D-25F, D-39F and D-13WE with station D-39F "Saw Booth Helper" not surveyed. (The saw booth was in use however but only one person - the booth operator was necessary for the machining process.) As requested by C. B. Allen, Plant Manager - stations D-40F "Operator of the Large Slash Saw" and D-25S (formerly D-11A-6) "Operator Receiving Shipment of Blue Asbestos Fiber" were sampled. Several General Area Samples were taken in conjunction with the operator unloading fiber - these samples will be denoted on the final report and will be listed with the operator samples. At the hygienist's discretion station D-16F "Operator of the Large MQA Lathe" was sampled in addition to a special test (not to be established in the permanent records) was taken at the Pipe blow-off area on the Universal Finishing Lathe. The four divisional dust collectors were sampled with the results to be included with the final survey report. , - S; Prepared by R. N. VanBendegom CRMC-Christensen-Micro-000018 Denver Industrial Hygiene Laboratory. R & D Center .. Date March 28, 1974________ .` r CONFIDENTIAL '. Plant Manager c. B. Allen , ANNUAL INDUSTRIAL HYGIENE SURVEY DIVISION Pipe PLANT Waukegan . '. i Following is a summary of the Industrial Hygiene Survey conducted 3/11/74 . 1. The following stations which were previously over TLV are below TLV in the current survey: D-29F* D-36F, D-2S___________ : 2. The following stations were not operating during the current survey: None 3. The following stations were found to be over TLV in the current survey: D-25F, D-39F, D-13WE________________________________________________ ... ALL ASB. DUST * NOISE F/V TOTAL ONLY Number of established sampling sta tions over TLV previous survey. 6 - - 0 6 6 Number of stations sampled during current survey. 6- - 0 6 6 Number of surveyed stations above TLV. 3- - 0 3 3 .09 Q D. R. Christensen Industrial Hygienist * CDCA - Cleaned Dust Control Air cc: Manager DEC Production Manager K. J. Whalen - 2 South OKTtfXNAYXNfi KTNLD LAnoitATORY - Waukegan Form ECD 1A-73 CRMC-Christensen-Micro-000019 DIVISION Pipe DATE March 28, 1974 ANNUAL INDUSTRIAL HYGIENE SURVEY STATIONS OVER TLV PROM PREVIOUS PLANT Waukegan OCCUPATIONAL PUST Station NO. STATION DESCRIPTION D-29P Operator of Moulding Saw Booth i* * . Operator of Mono-Saw HAZARD Asbestos Asbestos D-36F Take-Off Operator of Bandsaw Saw Booth Helper North Willow Operator for No. 2 Pipe Machine Inspector for Universal Lathe Asbestos Asbestos 2. 2.0 . 2. 10 Asbestos 2.0 2.0 Asbestos 2.0 2.0 .f DNO - Did Not Operate CZD- Above TLV * - Personal Protective Equipment Not Worn / \ - Ppak F.xoosure CRMC-Christensen-MicTo--000020^*" ai H/ul Johns-Manville Interna! Correspondence To: C. B. Allen - Waukegan Date: March 28, 1974 From: D. R. Christensen - R&D Center Copies: Subject: SPECIAL SAMPLINGS - WAUKEGAN PLANT, PIPE DIVISION During the recent Annual Industrial Hygiene Survey con ducted the period starting March 11, 1974, a number of Station of the Industrial Hygienist, follow: Description The results of these samples SH Hazard TLV Results D-35F Operator Feeding Band-Saw Asbestos 2.0 2.0 0.6 f/cc 0.5 f/cc >*1 D-10S GRS - Unloading Box Car of Asbestos Fiber D-11S Unloader Operator of Asbestos Fiber from Boxcar ^D-14Q GRS - Silica Unloading from Railroad Car D-22S Millwright Asbestos Asbestos 95% Quartz 0% Quartz 2.0 2.0 2.0 2.0 2.5 0.10 50.0 5.00 0.6 f/cc 0.5 f/cc ii 0.5 f/cc 0.7 f/cc HI 3.2 mppcf 0.00 mg/m3 1.2 mppcf 4 0.17 mg/m3 - Above TLV Please refer any questions pertaining to this special survey work to F. J. Angelos, Industrial Hygienist, Waukegan. . Prepared by: S. Gaburo j D. R. Christensen jet CRMC-Christensen-Micro-000021 JohnS'Manville vlftfl c% To: dedee Hillman - "4N Internal Correspondence Date: t-j- / / From: D. R. Christensen - R&D Copies: Subject: OCCUPATIONAL ENVIRONMENTAL CONTROL MONTHLY REPORT - Jl The major work done by the Occupational Environmental Control Department inas `foilows: Scheduled Industrial Hygiene Surveys Field Work at Plants: rOc, Industrial Hygiene, Housekeeping, Safety & Community Reports Issued: m g. fY Special Industrial Hygiene Surveys Field Work at Plants: Reports Issued: CRMC-Christensen-Micro-000022 Occupational Environmental Control Monthly Report - August 1976 Reports Issued: Miscellaneous /. 3^0>a</ /MDus7&i&( F/y lOof?kSl40P pb. LbmfbCL LOau. Fkao. A f PO&- uqft QrO^/O //0 Lf'O hi Q ( ^ j , ui, I liiAm J -r--r/9 ~TF)/F /<= '*\mm C_ofoFfi\OD P^feTy f)F5<DC.?R77oh oF f'^tSSo/0* PFoGFISl,'<r Pro /C^.S. 3( /aj/tta/ sis^rrup or 0,0. trterrrrrFoO . ______ <1. Co/oDudJrO Yi Ovy fis8S7ot P"' '3 Potu <o - F 'P S'. 4. OF] f) DQt D, S P/^ 'P s. fkrrFo i oriFo / a) A) ws//. Gu^ h/y 0 c r /V c. / PrcyOfn fS*y vOJO, OfurF/A.y Si hdf) f) O i0 0)<^Oer<F7c'Z' CRMC-Christensen-Micro-000023 FJ Johcr' riinviSk;' Internal Correspondence ,, Jucleo Hillman - W1IQ 1-OG Date: 4 " 2*1 " "^7 From: F. J. Angelos - Waukegan Copies: Subject: OCCUPATIONAL ENVIRONMENTAL CONTROL MONTHLY REPORT - APRIL The major work done by the Occupational Environmental Control Department in APRIL is as follows: Scheduled Industrial Hygiene Surveys Field Work at Plants: TPD (QutelERL'fllDl) ' W' Industrial Hygiene, Housekeeping, Safety & Community Reports Issued: - BMMD W. LTD M - ipd - r p*+v wSyswM*. RDcKDm.tr- BhtfD NW) - Special Industrial Hygiene Surveys Field Work at Plants: WAUtfeSflO - P+ P 5y6TEH6 T>cF//}/\jCe - Carbon Black. [ v/*\jf . Rs~ ` H-1 - ninu i iv jtc ^ Li FTS ' 'V CRMC-Christensen-Micro-000024 Occupational Environmental Control Monthly Report Page 2 Special Industrial Hygiene Surveys Reports Issued: Denude G~3o Cazbom i Miscellaneous -IPD(jOwkf&rM - Supervisors c<op?pu>smv3T oaj P" WV FROM ShfiPP^R5 Fork LIFT TRUCK-MtG-H RESULTS /aJ TH ~ flZEt Ertf7~ CA K F OUT o F CfirR- -RtFCCM rfElOD > TRUCK BE OUT OF STFA/CE FSR RFFFfRS, TEuck TA-FEN T<s> EA&AQt U. R, C+lts/S TE/C>SE/0 - &Z WO&SCOPGS CO As/SEEToS Cou/OTVtOG /OEOO MlOSf-l ER0CEOURtE>t I Iksfruct/o/us o/o aafc/s/S oF Corn. 77* R F*'-rcH--\ 03r.oCEbQR.ES - CqOEEED EE/aJ FROCEEO/J&jES FoF " PLbtOT A?eaJFEeFS 'Books Eo be Q&mPOTFTF- if X 3PEOFCE a} FTE7UOEO Ta/c^CoaFlp SfAEF/ ZfsSoC. MFEFaKc So-FEiy Mb ZOROS AT 'GQEbT&S GmFF/ C/g /}FU6F~b)fJJ< ._- l / F J' AtOQELoS ATTE/OFx KJCt CLbCSFS MnJOJF t>oaj StAet-/ //OF'/aj nOOS AT A/ OR.TH (Bo&tf&aj UtO\/. '*> (7>H` ^bGc. C.M* C&R.TFR V TGoafCLF^ ATTF/JDkE QSHP 1/oLtfA/^y Con pL /FAJCE Course MCo&eMdMTjiL, yr y/oA; L A TcH e TtQuF Peso scA/ooL ms Q' /j 7~bcJF op y'/AF IaJaU/CFORF f~A//AjF ^ y/gft) CRMC-Christensen-Micro-000025 Spt'C PuaJ of FtS&Z- 1?t&T/aJC f'e/Z 0*S3&&H &10CA? CpMduct^ B/ F<j, #/0<Fe2j>s, /fc~so cedDUOTi # RuM THS aSEVT t>Ay- t^GTH UMS /?=r 7"/r'c 2)S7':MC~ p^or s / 5iPC, TE357S ^6 <2 KAOS' SITS' AT W ? lLLlM6<& , /eWS AT *Gs*&} * yC /-J)T cptrA{ CoKpLemp f-v- m-: CRMC-Christensen-Micro-000026 i CON FIDENTIAL Environmental Control Department Denver GHQ May 4, 1972 K. J. Whalen - Manville cc: A. C. Smith JV E. Hesse M. Harris W. A. Sells - Waukegan R. W. Campbell - Manville H. M. Jackson M. B. Jamin - Finderne D. R. Christensen - Waukegan R. J. Bernard File INDUSTRIAL HYGIENE SURVEY PIPE DIVISION - WAUKEGAN PLANT JANUARY 3 - APRIL 10, 1972 W. A. SELLS' LETTER OF APRIL 21, 1972 TO G. L. SWALLOW Prior to the subject survey the List of Stations Over TLV included 22 occupational dust, 3 CDCA*, 32 noise and 2 fume/ vapor for a total of 59 stations over TLV. As a result of the survey and the Plant Manager's comments, we have deleted 2 occupational dust and 2 fume/vapor stations. In addition, 4 noise have been reinstated and 1 new noise station established. Therefore, the List now contains 20 occupational dust, t^CCScS^ > and 37 noise stations for a total of 60 stations over TLV. Enclosed is the revised List of Stations Over TLV. Also enclosed is a copy of W. A. Sells' letter and the statistical recap of the survey. Stations Deleted from the List of Stations Over TLV Occupational Dust i>'llF Hawthorne Lathe Ooerator - South Side The plant states this station is permanently corrected. Therefore, we have deleted it based on the last six survey results which were under TLV. * Cleaned Dust Control Air. CRMC-Christensen-Micro-000027 CONFIDENTIAL K. J. Whalen - Manville May 4, 1972 Page 2 Stations Deleted From the List of Stations Over TLV (Cont'd.) Occupational Dust (Cont'd.) D-12F Hydrotester Operator on Hawthorne Lathe We have also deleted this station based on the last five survey results. Fume/Vapor V-2WE #3 Pipe Machine Cleaning Screens With Acid Based on a time-weighted scale, this station is well below the allowable limits. We have, therefore, removed it from the List. V-3WE #4 Pipe Machine Cleaning Screens With Acid Upon judging this station on the newly promulgated Federal Regulations, it is well below the allowable. We have deleted it from the List. Stations Remaining on the List of Stations Over TLV Occupational Dust D-7F Monolithic Lathe #3709 The last three survey results indicate readings well below the TLV. We look forward to deleting it next survey if the counts remain below. D-8F Drag Saw Col. B-20 Operator First reading taken with large diameter pipe. Second reading taken on smaller diameter pipe. Experience shows that dust counts vary according to the pipe diameters. Experience also relates that larger pipe generally record the higher counts. We are glad to note that respirators are continuing to be used. D-9F DeWalt Saw #3824-0200 Col. B-16 Operator Same comments as for D-7F. CRMC-Christensen-Micro-000028 CONFIDENTIAL K. J. Whalen - Manville May 4, 1972 Page 3 Stations Remaining on the List of Stations Over TLV Occupational Dust (Cont'd.) D-13F Small Coupling Cut-off Col. C-25 Operator The re-ocating and subsequent exhaust set-up has significantly reduced counts. After another hlpefully low count next survey, this station is ready for deletion from the List. D-15F Large Coupling Cut-off #3603-0200 With the elimination of the sweeping process now effective, we can also look for this station to be deleted next survey. D-20F Bayard Lathe - #3300-0002 Col. E-27 According to the Hygienist, large amounts of dust are visible when pipe is machined. Evidently the dust is blown away before it gets to the operator's breathing zone. If the low readings continue during next survey, we will look forward to deleting this station. D-21F Slash Saw #3818-0001 Operator No comment. D-22F Non-Pressure Pipe Lathe #3500-0001 South Side Opr. First sample taken on 6" type 5 Air DufiiiC.Pipe. Second sample taken on a clean-up cycle. Air used to blow dust from machine. D-24F Take-off Man for Non-Pressure Pipe Lathes Respirators are required until the station is permanently corrected. D~25F Moulding Saw Booth Operator The continued use of respirators should be encouraged. D-26F Operator of Radial Drill Webo #3806 The drill is now hooked to an exhaust system. The past four counts have been well below the TLV. We look forward to deleting it after the next survey. CRMC-Christensen-Micro-000029 C0NF I DENT IAL K. J. Whalen - Manville May 4, 1972 Page 4 Stations Remaining on the List of Stations Over TLV Occupational Dust (Cont'd.) D-1WE Machine Tender #2 Pipe Machine The Hygienist reports a much improved working atmosphere a-t the #2 Pipe Machine. However, respirators should be required until the plant reports the station permanently corrected. D-13WE North Willow #2 Machine Operator Improved housekeeping should be instituted at the Willows. The Hygienist reports floor and machine surfaces covered with asbestos fiber. The continued use of respirators is required. D-15WE South Willow #3 Machine Operator -!BL ;Sfp `.1 . .Vflll t88S Improved housekeeping should also be instituted here. Again, the floors are reported to have accumulation of fiber. Bag opening and disposal are a problem. The continued use of respirators is required. :4 D-16WE Transite Pipe Scrap Grinder Between #3 and #4 Pipe Machine A significant reduction has been noted over the past 4 surveys. A continued low reading will offer this station for deletion next survey. D-5S Service Utility Man Dust House South and Northeast Houses Respirators should be continued until the plant reports the station as permanently corrected. D-10S GRS - Unloading Box Car of Asbestos Fiber D-11S Unloading Box Car of Asbestos Fiber We are glad to note the excellent condition of the box car. We will look forward to deleting these stations next survey if the conditions and the counts remain the same. D-12S Ball Mill - GRS During the next regularly scheduled survey, the Hygienist will be advised to check exposure based on an 8-hour time-weighted basis. D-14S Silica Unloading Area No comment. CRMC-Christensen-Micro-000030 CONFIDENTIAL K. J. Whalen - Manville Page 5 May 4, 1972 Stations Remaining on the List of Stations Over TLV (Cont'd.) CDCA D-2DH Parson Collector South Side Northeast of Building D-3DH Parson Collector North Side Northeast of Building The Hygienist reports that the Dust Houses are contracted to be rebuilt. He also reports that after completion, the Dust Houses should be in excellent condition. We look forward to completion of the work contracted. r, K/tflTwf / / c c To fz. & rx 1H wiU CJ ^ Noise -^N-IF Boring Mill Station reinstated as of January 3, 1972. The Hygienist has not observed hearing protection during the 1972 survey. Hearing protection is essential until the station has been permanently corrected. '/lN-2F #3609 Boring Mill We are leaving this station on the List even though it is below the TLV. The hygienist reports there was very little background noise during sample. ^N-3F #3712 Lathe at A-18 Col. No comment. - N-4F #7195 Lathe at A-19 Col. 1N-5F #566 Lathe at A-20 Col. N-6F #3824 Saw Near B-16 Col. DeWalt N-8F #7671 Lathe at Col. B-20 tN-9F Radial Drill N-10F Drag Saw N-11F #3400-0100 Lathe "'N-12F G.R.S. Epoxy Area lN-I3F So. Side #3300-0003 Hawthorne Lathe N-14F Hydro-Tester While Hawthorne Lathe Runs "N-15F Belling Unit While Hawthorne Lathe Runs -N-16F Coupling Cut-off Saw #4856 Col. 25-C Because the noise generated from the finishing end of a oipe plant is variable, it is impossible to time weigh the exposure with the present equipment. In all but two areas, hearing protection is worn. Station N9-F had a dBA reading of 118 dB. Hearing protection is required until the noise level can be reduced, CRMC-Christensen-Micro-000031 I CONFIDENTIAL K. J. Whalen - Manville Page 6 May 4, 1972 Stations Remaining on the List of Stations Over TLV (Cont'd.) ^N-17F MOA Lathe Approx. 5 ft North of Operator Reinstated as of 1/3/72. Additional noise level was coming from the truck traffic and the curing tanks. J N18-F ,,N-19F ^N-20F -N-21F -N-22F . N-23F ./N-24F -'N-25F ;N-26F N-27F ^N-29F So. Side of Wet Saw #3818-0400 UPL Approx. 10 ft Northwest of Operator Belling Unit Behind UPL - North side 5 ft 3818 Saw Northeast of D-31 Col. So. Side #5905 Lathe Between Cols. 26-E & So. Side #4836 Universal Lathe G.R.S. Beller and Tester Operator West Side of #3500-0002 Lathe Non-Pressure Lathe #3500-0001 #3500-0001 Lathe Between F-30 & G-30 Col. Under Drain Drill Press from Operator 27-E ':/Sf y ^ Because the noise generated from the Finishing End of a Pipe Plant is variable, it is impossible to time weigh exposures with the present equipment. rN-lWE Valve Operators Area Northwest End of #2 Pipe Machine Reinstated as of 1/3/72. Hearing protection should be continued until station is permanently corrected. i/ N-3WE Gauger Operator Station Northwest Side of #3 Pipe Machine No comment. N-4WE T.O. End of #3 Pipe Machine No comment. N-7WE West Side of 0314 Scrap Grinder When grinding the noise level goes up very substantially, w N-8WE Center Willows No comment. CRMC-Christensen-Micro-000032 CONFIDENTIAL K. J. Whalen - Manville Page 7 May 4, 1972 Stations Remaining on the List of Stations Over TLV (Cont'd.) Noise (Cont'd.) N-2S Just Outside Doorway to Office in Ball Mill Room This area will be tested on an 8 hour time-weighted basis next survey. */-3s- , 7 Pao-Pftt-^'Te oc.h-- ^N-4S #1340 Fork Truck No comment. N-5S #3736 Propane Truck Platform Truck driver travels throughout plant, thus he is exposed to a variation of noise levels. N-6S #2690 Hyster Fork Truck No comment. '''J-- -- G. L. Swallow DAA/ems Attachs. CRMC-Christensen-Micro-000033 Johns-P/lanville To: E. J. Bulava - Manville Date. September 19, 1974 From: G. L. Swallow - 4 North D. R. Christensen - R&D copies: W. B. Reitze - 4 North E. J. Mitchell - 2 South ( ' File sChron -rr Subject: HANDLING GOVERNMENT SURPLUS CROCIOOLITE & AMOSITE FIBER Jack Mitchell reports that he has received a number of reports from various pipe plants stating that based on a visual evaluation, some of the Government surplus shipments of amosite or crocidolite appear to be considerably dustier and dirtier than those which you sampled a month or two ago. The shipments under discussion and those which you sampled were of fiber in jute bags shipped on "pallet boxes". In view of our concern for this situation, please repeat the work you formerly did, sampling either crocidolite or amosite, whichever is available. Also, please attempt to find a time when some of the poorer pallet box loads are being handled and transoorted. Sampling should be done during unloading of fiber from the truck or rail car, during handling and transportation of fiber from the ware house to the willows, and during the feeding of this fiber to the willows. By copy of this letter to Denny Christensen, I request that he phone results of his counts to me as soon as they are available, in addi tion to issuing his normal report. #- l yr-fa. L. Swallow GLS/jmb CRMC-Christensen-Micro-000034 " u^ r.i fn*~m * Johns-Manville Interna! Correspondence To: See Below From: d. R. Christensen - R&D Center Copies: Date: October 3, 1974 Subject: WAUKEGAN PLANTS - OSHA INDUSTRIAL HYGIENE INSPECTION JOHNS-MANVILLE SIMULTANEOUS SAMPLING TO: C. R. Wikel - Waukegan C. B. Allen - Waukegan R. Winkworth - > Waukegan F. J. Angelos - Waukegan W. B. Reitze 4 North G. L. Swallow - 4 North M. A. Baloga - 4 North An OSHA industrial hygiene crew conducted sampling to determine exposures to asbestos ana quarts at the Waukegan location during the weeks of September 16 and 23, 1974. The Johns-Manville Industrial Hygiene Department, in the person of F. J. Angelos, sampled simultaneously with OSHA to enable us a means of checking results obtained by the OSHA crew. . ,, Three tests for benzene vapor were taken by OSHA that J-M was unable to sample simultaneously because of lack of identical sampling equipment. Presented in the following data sheets are simultaneous sampling results and also results from previous J-M sampl ing done at the selected Waukegan locations. This is presented to enable you a comparison of the latest result and those of the recent past. The respirable gravimetric sampling of OSHA was done by use of silver membrane filter media. This enables determination of both the Quantitative (mg/m^) and qualitative (% quartz) data in a single sample. J-M at present cannot sample by this method consequently the simultaneous sampling result is only quantitative (mg/ra^) in nature. * CRMC-Christensen-Micro-000035 Page 2 October 3, 1974 The J-M TLV data shows what has normally been found at the station in previous survey work. . r D. R. Christensen jes CRMC-Christensen-Micro-000036 2151 Johns-Manville Internal Correspondence To: N. B. Scheffel - 2 West Date: October 29, 1974 From: 6. L. Swallow - 4 North W. B. Reitze - 4 North copi: E. M. Fenner - 4 North D. R. Christensen - R&D D. A. Aldinger - R&D T. E. Renners - 2 West F. J. Angelos - Waukegan Subject: PAPER MILL TALC USAGE NORTHWEST PAPER COMPANY, POMONA, CALIFORNIA Reference: MY LETTER DATED OCTOBER 7, 1974 D. R. CHRISTENSEN'S LETTER DATED OCTOBER 18,. 1974 Enclosed Is a copy of 0. R. Christensen's letter of October 18, which is largely self explanatory. . The results of the fiber counts are given and as you can readily see, represent levels considerably higher than you and I had anticipated. Only one, the area sample between the two pulpers. Is above the pr- sent Federal Asbestos TLV. However, this Is basically Irrelevant In that you hope tr demonstrate that fiber levels, when handling J-M talc properly, are well below the future TLV of 2.0 F/cc, - In our conversation of October 17, I passed on to you Doug Aldinger's comments regarding the poor housekeeping evident throughout the area, the lack of effective ventilation, and the handling methods employed. Regarding this latter, you will recall that the operator at the Skip Hoist regularly dumps bales of oulp on top of unopened J-M talc bags. Given this treatment, a large amount of talc dust is expelled from the bags despite the fact that they are not open. These points are further covered in the enclosed letter. As we have already discussed, we believe that the results you antici pated are achievable at the Northwest Paper Company if they modified their work practices and improved both their housekeeping and dust control. As you know, we are on stand-by to do additional sampling in Dayton, Ohio and Park Falls, Wisconsin. The results of these surveys may give you the ammunition needed to encourage our custoners to improve their dust situation. Although our sampling was by prior agreement for fibers only, Doug Al dinger made the point that the general nuisance dust level was such that Northwest Paper Company would probably be in trouble if sampled on that basis alone. I would think that would be a very useful argu ment in attempting to convince Northwest that they should take mea sures to correct their present dust conditions. G. L. Swallow GLS/jmb CRMC-Christensen-Micro-000037 w... `.'A Johns-iv/ianville interna! CorresponV- a, to: G. L. Swallow - 4 North Date; October 18, 1974 From: D. R. Christensen - R&D Ctr Oimi'h: MEMBRANE FILTER SAMPLES NORTHWEST PAPER COMPANY - MINERALS DIVISION On October 15, 1974, membrane filter samples were taken at Northwest Paper Company, Pomona , California, to determine the atmospheric concentration of Asbestiform fiber. A total of fourteen (14) samples were taken in the paper mill with the emphasis on the Hydropulper area. All samples were taken with MSA Model G pumps calibre? * * 2.0 L/m. The filters were millipore type AA 37mm diantef - and 0.8*. pore size. This is the currently prescripted nau method for fiber sampling. Listed below are the results: Station Description Results (F/cc) TLV (F/cc) Fork Truck Driver (Serves #4 PM) Beaterman Pulper Operator Utility Man Area Sample - between two pulpers Machine Tender - #4 PM Fork Truck Driver (serves #3 PM) Upwind Sample - inside plant Unwind Sample - outside plant Wet End Centra Cleaner Area Machine Room - #4 PM 2.9 1.3 0.4 0.7 2.1 0.8 1.6 0.9 5.4* 0.9 0.3 0.5 0.1 C.l 5.0 5.0 5.0 5.0 5.G 5.0 5.C 5.0 5.0 5.0 5.C 5.0 ~> r Ij 5.0 * The area sample between the beaters was the only sample 1 exceeded the 5.0 F/cc TLV. CRMC-Christensen-Micro-000038 Page 2 G. L. Swallow October 18, 1974 A brief job description of the Utility Man, Beaternan and the Pulper Operator as I saw it may help at this point. The Utility Man works on the ground level with the Pork Truck Drivers in the loading of the skip hoist. The Utility Man loads the bagged products, clay, talc, by hand which are on pallets in the area. The Fork Truck Driver loads the pulp and bulk paper directly into the hoist from the truck. The Beaterman is the crew leader who works on the platform where the hydropulpers are located. He weighs dyes and generally runs the wet-end. The Pulper Operator is on the platform also. His duties ap peared to be similar to the Beaterman's. Occasionally, he is required to climb on the pulpers to push ingredients that didn't dump from the skip hoist inuo the pulper. The loading of the skip hoist on ground level causes heavy dust. The sequence of raw material which is loaded into the skip hoist may well determine the dustiness of the area. For example, if talc and clay were added first and then the pulp and bulk paper were pushed on top of it, a much greater concentration would result than if the process were reversed. Also, the ventilation located on the platform does not ex tend to the skip hoist area. Excessive dust appears on the platform which is caused by the dumping of the skip hoist into the hydropulpers. The ventilation system on the platform and over the hydropulpers may as well not exist. The system, at best, is inadequate. The lack of proper ventilation causes the entire wet-end to fill up with dust. The predominant air movement is from the wet-end to the finishing end. Two bulk samples were submitted to the Analytical Chemistry Section for a quantitative tremolite fiber content. The results will be available the week of October 21, 1974. According to N. Schneffel, the tremolite content of Cyclosorb is in the 5 percent range and Cyclofill is in the 30-40 per cent range. Number 3 paper machine uses 40 lb of Cyclosorb only. However, Number 4 paper machine uses 300 lb of Cyclofill and 40 lb of Cyclosorb. Housekeeping by Johns-Manville standards is poor. The skip hoist track is loaded with a thick layer of powder as is the shed between the two skio hoists. / , ; t - . j * . - -t - D. R. Christensen CRMC-Christensen-Micro-000039 o Environmental Control Department Denver - GHQ January 13, 1975 TO: N. B. Scheffel - 2 West FROM: G. L. Swallow - 4 North COPIES: W. B. Reltze - 4 North E. M. Fenner - 4 North D. R. Christensen - R&D T. E. RF emmers - 2 West SUBJECT: Ihron INDUSTRIAL HYGIENE SURVEY POTLATCH CORPORATION, NORTHWEST PAPER DIVISION, POMONA PLANT lit f4 (}is oOn DDee<cember 11, 1974, an Industrial Hygiene survey was con ducted at Potlatch Corporation * a Pomona, California, paper mill facility. The objective of this survey was to evaluate airborne dust levels, in the respirable particle size range, throughout the plant. In order to accomplish this purpose, a series of twelve respirable gravimetric and three highvolume air samples were collected for subsequent qualitative/ quantitative analyses. X-ray diffraction analysis of the high-volume samples for per cent silica (quartz) content yielded the following: Area % Quartz TLV (mq/M3) Wet End Refiner Area 2.50 Skip Loading Shack 3.33 Area Between Two Hydropulpers 5.00 The particular TLV (Threshold Limit Value) to be used is derived from the formula: TLV = 10 % Si02 + 2 CRMC-Christensen-Micro-000040 INDUSTRIAL HYGIENE SURVEY - POTLATCH CORPORATION NORTHWEST PAPER DIVISION, POMONA PLANT January 13, 1975 Page Two____________________ ___________________ _ The results of the twelve respirable gravimetric samples taken to quantify the dust concentrations in terras of rag/M3 (milligrams per cubic meter) of air appear below. Location Skip Loading Shack Result 0.38 TLV 3.33 rag/M3 No. 3 Fork Lift Operator 0.42 3.33 rag/M3 Pulp Utility Man 1.88 3.33 mg/M3 Starch Feeding Station (Outside of Paper Mill Building) 1.28 3.33 rag/M3 Area Between Two HydroPulpers (General Area Sample) Beater Operator 0.30 1.45 0.08 0.27 5.00 5.00 g/M3 5.00 rag/M3 5.00 rag/M3 Wet End - Refiner Area (General Area Sample) 0.27 2.50 rag/M3 No. 3 Rewinder Control Operator 0.11 2.50 rag/M3 No. 3 Machine Tender 0.24 2.50 rag/M3 No. 4 Machine Tender 0.67 2.50 rag/M3 When comparing these results with their respective TLV's, it can be seen that all sampled areas are well below the limit. The highest result obtained (1.88 mg/M3) only reached slightly over half of its permissible TLV. The respirable gravimetric sampling technique has superseded the former impinger method which is currently being phase*? out. The respirable gravimetric procedure has been proposed by NTOSH (National Institute for Occupational Safety and Health) as the method for evaluation of airborne quartz concentrations. In anticipation of this method becoming law, it has been used as the criterion in this survey. A. Swallow KJW: GLS/jmb CRMC-Christensen-Micro-000041 ,,;gr! \ 1/31 Johns-Manville Research and Development Center Report No. 259-10 Date July 10, 1978 Tide: field evaluation of hand tools for the dust-free fabrication of asbestos-cement SUMMARY - Tools for the cutting and drilling of asbestos-cement were evaluated on the job site on June 13 and 14, 1978 at the State of Utah Trade and Technical College, Phase II, located In Orem, Utah. These tools were designed ,and tested at Research. The purpose of this work was to generate field dust counts and record workers reaction to the tools. Personnel present during this operation were the author and: 1 D. R. Christensen R. Cordova B. Bullough L. Henricksen G. M. Maestas R. Micale J.M. - Health, Safety, and Environment J.M. - Health, Safety, and Environment Bullough Asbestos - Supplier Western States Industries - Contractor Industrial Hygienist, Bureau of Radiation and Occupational Health, State of Utah J.M. - Denver Sales Tools evaluated included a portable power saw with shroud and a hand drill with shroud, both used with a Nilfisk vacuum cleaner. Also used was a nibbler using a hand drill as a power source. The highest dust count recorded was 0.38 flbers/cc which is an average of all equipment run. While this gives a strong indication everything is well, another job site should be found to evaluate each tool separately. These field data confirm the lab work which indicated the satisfactory performance of these power tools. Hand tools (clippers, saw, scoring knife, etc.) were not tested but workmen thought they might be acceptable for use on thinner material (1/4 in. or less). T would recommend additional testing be dene at eating conditions are more severe. x v JWU 4 *^ ,, u -- -f HUWiiU Contents: Summary, Discussion, Conclusions, Recommendations and Appendix. ck Distribution on reverse Reported by_ G. R. Bauman Asbestos and Mineral Technology Confidential --not for general distribution or republication CRMC-Christensen-Micro-000042 Distribution: F. L. Pundsack - 1-04 (S) C. J. DeBiase - 3-15 (S) M. Harris - 2-12 (S) D. Poutlatlne - 2-14 J. Connor - 2-14 J. Reis - 2-14 D. Kelleher - 2-14 R. M. Krone - 2-20 L. Siebert - 2-14 E. M. Fenner G. L. Swallow J. V. Magee - 1-06 /- 1-06 - 2-10. J. W. McLain - 2-20 J. P. Leineweber - 1-06 P. Kotin - 1-06 K. J. Whalen - 1-05 J. Laipenieks - 1-05 J. H. Swensen - 3-07 R. E. Loeffler - 1-04 J. E. Neal - 3-03 R. W. Micale - 3-N J. R. M. Hutcheson - Asb R. E. Sampson - Asb A. R. Dennis - Asb E. J. Day - Asb M. D. Webb - Asb E. B. McKenna - Asb R. B. Gresham - Asb H. M. Hay - Asb KEYWORDS Asbestos Asbestos-Cement Environmental Health Dust Dust Collection Fabrication W. C. Strelb P. E. Dix (Attn: J. Herr) W. J. Pxichta (2) D. R. Christensen F. M. Bodycomb A. Schnabel G. R. Bauman (2) R&D Information Center (4) CRMC-Christensen-Micro-000043 IZ\ Johns-Manville turono Internal Correspondence To L. I . Richards - Dension Date: May 3, i Fionv G. L. Swallow - R&D Copies W. D. Reitze - 1-06 D. R. Christensen - R&D W. Paul - 1-06 T. M. Faas - 3-07 C. R. Smith - Denison Subject DUST SAMPLE - FITTINGS LATHE - DENISON YOUR LETTER APRIL 12, 1978 TO D. R. CHRISTENSEN In the final paragraph of your subject letter you refer to eliminating the fittings lathe operator asbestos dust station from the "monthly reporting status" and the re quirement for wearing protective clothing and a respirator. We have discussed this with Dr. Paul who agrees with your request. If you have not already received the results of your sample, you will in the very near future. ( / G. L. Swallow si CRMC-Christensen-Micro-000044 !/31 dohns-Manville internal Correspondence To C. J. Sulewski 3-15 Date: June 13, 1979 From W. B. Reitze Copies: ^P. Kotin, M.D. 1-06 1-06 / Sub|ect DUST CONTROL FOR REFRACTORY FIBER FURNACE - R&D Your memo dated March 25 regarding the above subject has been brought to my attention, and the purpose of this memo is to give you additional information and request that you pursue your stated decision to get more facts and possibly consider alternate methods for controlling this situation. On the afternoon of June 12, I visited R&D with our hygienist, Denny Christensen, and Ed McMahon of the Research staff. We inspected the refractory fiber furnace, which was in limited operation at the time, and also climbed to the roof and visually inspected emissions from the stacks. There are two separate but related problems, one dealing with the indoor employee workplace exposure and the other dealing with emissions from our stacks to ambient air. The indoor situation must be reviewed both in terms of visual inspection and the existing industrial hygiene reports. As I am sure you are aware, industrial hygiene surveys have been done and have indicated that the workers can be exposed to levels of free crystalline silica (quartz) as high as ten to fifteen times the recognized TLV for quartz. It is true that respiratory protective devices are used, at least to a limited extent. During my visit I noticed several of the workers wear ing respiratory protective devices, but during much of the time the supervisor of the operation wore his respirator around his neck rather than over his mouth and nose. I understand that this is the general rule and that not all people on the platform or in the surrounding area wear respiratory protec tive devices 100% of the time. With free crystalline silica levels as high as they are, respiratory protective devices should be mandatory for all people assigned to this area, both above and below the platform. While the mandatory wear ing of respiratory protective devices will protect our people on an interim basis, OSHA does noe permit its use for the long i i.-lifi if engineering technology is available to control the process. OSIIA does, however, have a provision which states that personal protective devices are acceptable if it is an emergency situation--a little used and infrequent process. As I read this, we do not qualify for this sporadic use pro vision. Visual inspection of the area indicated much dust CRMC-Christensen-Micro-000045 C. J. Sulewski June 13, 1979 Page 2 on the platform, below the platform, and in many areas of the fire test room. I have been told that there are a number of complaints from employees who work near this operation regarding the dusty conditions which generally exist in the fire test room when the process is operating. Emissions to ambient air present another series of problems. First of all, we should consider the fact that when we origi nally applied for permits for the Research and Development Center we promised the state people that we would not be emitting any significant amount of pollutants to the air. Emissions from the stack may not be in line with our prom ises. A second and extremely valid point is that these emissions from the stack are visible both to our employees and to our neighbors. Either group could .trigger an inspec tion by state or federal people merely by a simple telephone call. Once this telephone call is made and the first inspec tor from a regulatory agency arrives at the Research and Development Center, our problems begin in earnest. In light of J-M's less than sterling reputation among the residents of the Ken-Caryl ranch, such a phone call to a regulatory agency is a real possibility. I will not speculate on the consequences of such an inspection but only say that it could have a far-reaching effect upon not only our new building operation but also our existing facilities. If there was ever a time for maintaining a low profile, this is it. By this, I am not stating nor intimating that we are injuring any of our neighbors because of stack emissions; in fact, I firmly believe we are not. However, compliance with regu latory agencies is not always related to health problems. In summation, I would like to make the following recommenda tions . 1. The enforced mandatory wearing of respiratory pro tective devices by all persons at or near the re fractory furnace. This will serve as an interim measure only and should protect our employees from the existing extremely hazardous health condition. 2. That further engineering studies be made immediately to determine other feasible and perhaps more economi cal methods for control. The fact that the possi bility exists that this operation will be moved to the new facility within a year or two is not suffi cient cause to delay. J ; CRMC-Christensen-Micro-000046 C. J. Sulewski June 13, 1979 Page 3 3. That all due care be taken to reduce stack emissions to a bare minimum, so as not to trigger an inspec tion by a regulatory agency. I would be most happy to sit down with you and discuss this in greater detail at your convenience. W. B. Reitze bcc: Denny Christensen CRMC-Christensen-Micro-000047 IT Johns-Manvillc Internal Correspondence To W.B. Reitzc 3 -0 6 Ffo<n Christenson R&D Cn|1lfv G.L. Swallow 1-0G Subject r NTKRNATTONAH DIVT55 TON ALMERIA AND MEISA OPERATIONS RESPIRATOR PROGRAMS n''" March 1^70 The cover letters accompanying the Almeria and Meisa Industrial Hygiene Survey reports both mention the need for a comprehensive respiratory protection program. I think a good point for the plants to begin at would be a set of recommendations from your office. In talking with Bill Farrell in Mexico City I do remember him mentioning the MSA disposable respirator approved for Asbestos handling and that lie was having considerable trouble obtaining information on it's application. I think anything that we could do in Denver might mean a much earlier implementation in Mexico. The severity of the cristobalife exposures is over whelming and prompts our immediate attention. Denny CRMC-Christensen-Micro-000048  _ -a ' iJL'l Johns-f/ionvilla [n n;,! Corres i" onoer.ce To _ D. R. Christenson D.-r June 15, 1978 Fiom Cop.f 1 F. D'Ovidio V. E. Wolkodoff See Below Subjrct TEM AND OPTICAL ANALYSES OF MILLI FORE FILTERS FCR PERCENTAGES OF ASPKSTOS TIBER TYPES, PIPE DIVISIONS OF MANVITLE, GREEN GOVE SPRINGS , AND WAl'KECAN M-2 74 - M-307 - M-311 TEM analyses conducted by intercepting at least 100 fibers and in conjunction with electron diffraction patterns and chemistry by energy dispersive spectrometry. Optical method according to "Identification of Oirysotile, Anosite, and Croeidolite Fibers by Optical Mineralogy Without Benefit of Refractive Index Oils. Lcitz Orthoplan Petrographic Microscope, 500 X" by V. E. Wolkodoff October 28, 1974. Also, based on intercepting at least 100 fibers. By optical methods, fibers down to 0.5 ym in diameter sometimes could be resolved and determined whereas by TEM and EDS, fibers as small as 0.02 /in in diameter could be varified easily. Since TEM detects and verifies extremely fine fibers (not detectable in the visible spectrum) there is no reason as to why percentages determined by the two methods should agree. Percentages of each asbestos type and sample identification are listed in Tables 1,2 and 3. via CC: Dr . C. Wright C. L. Swallow E. J. Bulava F. J. Angelos S. Speil S. B. Spencer - 1-06 - 1-06 - Manville - Waukegan - RAD - RAD V. E. Wolkodot, ' riiM iii "m#f* WWW.y i imisf ovom'ii mri tt ttf- :, CRMC-Christensen-Micro-000049 Table 1 TE*! and Optical Results, M.snville Plant, February 23, 1978 Snr-.ple Identification Dll-W D12-W D15-F D19-F D55-F Microscopy Mode TEM Optical Optical TIM Optical X Chrysotile 66 65 55 81 36 X Crocidolite 26 14 29 15 51 X Amo site 8 21 16 U 13 Table 2 TEM and Optical Result*, Creen Cove Springs, April 7, 1978 Sample ldentification Dl-T Dl-T D3-T D7-1 D8-T-A D13-T Microscopy Mode TEM Optical Optical Optical Optical TEM 2 Chrysotile 64 12 36 26 25 81 2 Crocidolite 12 4 18 18 67 17 2 Amosite 24 84 46 56 8 2 Sample ldentification #1 #4 #7 #10-2 #11 Table 3 TEM and Optical Results, Waukegan Plant, April 14, 1978 Microscopy Mode TEM Optical Optical TEM Optical 2 Cbrysotilc 77 35 34 81 25 2 Crocidolite 23 65 66 19 75 2 Amosite ND NO ND ND ND <*'> t* v / 'i, CRMC-Christensen-Micro-000050 UE>1 Johns-Manville Internal Correspond i ico To L. A. Schriver - Lompoc D.ite June 15 f 1978 From Cop*t Sublet F. D'Ovidio - R4D V. E. Wolkodoff - R&D Dr. G. Wright C. L. Swallow - 1-06 - 1-06 D. R. Christensen - R>D S. B. Spencer - R&D PF.TROr.RAPUIC ANALYSES OF ASBESTOS FIBERS IN AIRBORNE DUST OH KILLIPOKE AA FILTERS, WEEK OF JANUARY 30, J978, STOCKTON PITE PLANT SURVEY. M-267 Rather than report crocidolite fiber percentages only,it was just as easy to verify other types of fiber by petrographic techniques and list their percentages also. Please refer to your letter to V. Wolkodoff dated February 14, 1978. Sample identification and results are summarized in Table 1. iL <04 D'Ovidio via NB 4873, pg. 54, 55 **ft*e' ?T uwa; , iinpm, *** /Vi' ..pi "||,ny;ir r . *" 1 CRMC-Christensen-Micro-000051 - j w .. -J*. ~w.V: >**>:*. m Johns-Manville *!).**.L\M3i+. ; * ,,/. ti'i . i'i i^i Allniii i l l, a e Internal Correspondence ^ H. J. Young & VFcm G. L fallow d. R. Christensen $-* RESPIRATORS - TORONTO AND JEFFREY. Om October 1, 1982 The question was raised at both Toronto and Jeffrey es to why they could not continue to use the 3M 8710 respirator rather than the 9920 respirator. . At Jeffrey the questioner was Jim Deacon. He was specific in noting that those who preferred the 8710 were people who typically used the respirator only a small portion of the day and therefore found the lack of an exhalation valve to be no problem. The cost factor was also of interest, it is said that the typical would-be wearer of an 8710 res pirator has it issued to him, uses it briefly then thrown it away. When this happens frequently the differential cost can be significant. Jim Deacon also asked whether the 3M 9920 couldn't be used for welding (longer term use) in place of the MSA 45-7117 with a 6MA 464807 canister. We were interrupted before the end of this conversation and he never had a chance to explain the reasons for this request. Perhaps your knowledge of the two respirators will make that clear. :' CRMC-Christensen-Micro-000052 \ m Johns-Manville E. J. Bulava - Manville C. M. Carter - Waukegan D. R. Christensen - R-24 L. A. Schriver - Lompoc E. G. Stevens - Toronto /* >, From G. L.^'^w^llow 1-06 w. b. Reitze Cop. H. J. Young 1-06 1-06 Internal Correspondence o-t# February 15# 1902 Suh|*c t RESPIRATORY PROTECTION PROGRAM ED DULAVA'S MEMO OF FEBRUARY 5th - HELEN YOUNG'S LETTER FEBRUARY 9# 1982 Enclosed are copies of the captioned letters. I believe the questions raised by Ed end Helen's answers are of interest to us all. Please review both the questions and answers for your infor mation. If there are any questions# please let me know and I will either answer them or refer them to Helen. CRMC-Christensen-Micro-000053 Johns-Manville Internal Correspondence G. L. Swallow Dm* February 9, 1982 From H. J. Young Cop** File Sublet RESPIRATORY PROTECTION PROGRAM MEMO OF 2/5/82 FROM E. BULAVA 1) The onus should be put on the plant manager regarding the Respiratory Protection Program where voluntary wearers are an issue. I believe the same standard should apply to all wearers, but enforcement would be difficult if a respirator is worn but not really required. It should be pointed out that the respirator's effectiveness is greatly diminished if not worn properly, clean, etc., and that using poor techniques could, through example, indirectly influence the effectiveness of the program for "required" wearers. 2) A brochure is being prepared for use in conjunction with the film "Mask of Life", and should be ready for distribution in the next month or so. 3) I mentioned two methods for qualitative fit-testing (noted on page 7 of 1/4/82 memo on Respiratory Protection Program). There are others, and information can be obtained from various respirator companies. A fit-testing chamber is unnecessary since we are not required to do quantitative fittesting. Each location is responsible for determining how many kits are needed, etc. 4) It will be difficult to fit-test single use respirators and yet we must. Please refer again to page 7. I suggest 3M Face Fit Kit - Brand 9912. 5) ine 05HA standard says ye. CRMC-Christensen-Micro-000054 CRMC-Christensen-Micro-000055 'X; . 7* \ ^ L- . f^Acr*: C "o ' 5uuavA ' >&TZcT": l\e.SP>^Kt\----;-c'*Ay1 P^Of^tTjoj P&O&A A/V\ a./ s*/^x. J. -kJ To T*s &&$(* A(KtOAy p0T4<r.*^ pAofrAArrx PK> f ;> ' ; ` S '$'? Si * , r * pA^*A6 PAvr/gx> ~ZjpnvutU3y V, /9 2Ta- y (4 a ^5 TVlgf Pclu<u</ij(> f3r>. *j r*5 w<juo UiK& "To &* &b .* 1, 7-V- A- AfZSP'AATO* 1.3 AJjSLi: &jejux?w.P>, i/*r~ 4 + VH-&A. fe:; jr . 1 ttfi i'? '' D65/ASD/ ^rt-A-r P*A2.AS /)& A-aj/^ 0 ^ VVg PA oMAor\ -AM OePAAr- Foe. ^>A/nP*., P&SPiAaioA. \ \c*j f P* C.OAX>S f Tft A>i (k/i m P* 0TC,. ____ 2. J- 5 I F^u.'v* A'O A5KT /./^ Au- g*J.0~>AASj**^ O kJ TA+,*t**jc- itZ**S PBQu *&> ? mSA*JT t'Sri &V` % A*S 3&C*\J*St $Ar*ry /vxesgTWtf'S ? HSg A BlS 3. AA6. MO 0)ftAor pr-rg5r AT^fl3P4t^/d X-4Aa^J * TVat X A*v> A-U/A#<. ^At- i-tfAjr / a/ Otr A. 4A A-A*/ts ^ , .kj ' LEAST KiT APfiCAAS Kj&cM'S'SAAy IK) ............... Loc*T>o*J . biouJ A^5 LO+C.KI *UIWL. Au, PuVajTS 00Ta.o TM#Sgf _L<0 /~A6F^ PuA*r5 ^ i. <. /YJa^iums, ^Aur^-Aw') IV ic /3aov /3li loijf ^Pa^** oc>a.i>is#atoA? 4. 5ju6^C*y# R&SP<A*rolJ K-sr. WM(! 15 $y6-^E<Ffr> ft/PAl^ieJlJ ^ir*Ttfr - CRMC-Christensen-Micro-000056 * ' S. /)p?wxx. jl - IZiC . *ywst* 8g X- 5 t^.3 -rn^e. ^ 7 5, %& V (s*) grAT'jgs Tt+4-r it!.` k&J*-SmT' VAi^y. i CRMC-Christensen-Micro-000057 I SiSi Johns-Manville Internal Correspondence To 52, 551, NUR (U.S. and Canatffa) d*** January 4, 1982 Fiom H. J. Young, 1-06 Cop.** W. B. Rcitze, 1-06 * Sec attached Sublet RESPIRATORY PROTECTION PROGRAM The M.invil le. Respiratory Protection Program for operating subsidiaries includes essential elements consistent with federal regulation and sound occupational health concepts, and is designed for protection of workers againsv breathing air which may contain harmful substances. It should be noted that OSHA continues to require reduction of air contamination levels through engineering controls and process design. Respirators are to be used in the interim period while making corrections or when controlling through engineering methods is technologically infeasible. OSHA requires written standard operating procedures governing the selection and use of respirators, and for compliance purposes, you may wish to retain the attached in your files. This should be considered a replacement for the sections relevant to respirators in the Manual of Standard Practices, Safety and Health, SH-302, Rev. 1/79, 4/79. (See Appendix I for OSHA Standard.) S..e..le~ct"i"on.....o...f... Re .s..p...i.r.a.. tors Factors which determine selection of respiratory devices include the nature of the hazard, severity of hazard, type of contaminant, period of exposure* distance from respirable air, and activity of wearer. Respirators can be classified into three categories by the breathing pattern during use. If negative pressure is created inside the facepiece or the inlet covering of a respirator during inhalation, it is considered s negative pressure device (-), such as non-powered air-purifying respirators, supplied air respirator or self-contained breathing apparatus (SCBA) operated in demand mode. If positive pressure is maintained ineide CRMC-Christensen-Micro-000058 r.vjo 2 tN-> r ''.nit'cc or inlet covering of the respirator during ir.h.il .11on, it is considered .1 positive pressure device (*), ich is rrvnred ur-purifying respirators, supplied air respirators or SCBA operated in pressure-demand rode. The third type is the atmospheric pressure device (0) which maintains atmospheric pressure inside the facepiece or inlet covering of the respirator such as the continuous flow supplied air respirator. See Appendix II ror classification of respiratory hazards ird Appendix III for a general guide for respirator selection. Appendix IV is the newly revised corporate approved list of respiratory protection to be used by the operating subsidiaries of Minville Corporation. All are current models, hive NIONH approval, and are adequate for providing safe coverage for the substances for which they are intended. Only these respirators should be used. (Note: Due to inconsistencies and product changes, Norton respirators are not included on approved list.) Administrative Responsibilities To ensure appropriate coordination of requirements and procedures of the OSHA Standard and the Respiratory Protection Program, responsibility should be assigned to a specific individual at each location who willt 1) Assess hazards and correlate industrial hyqiene reports to respirator need. 2) Maintain specific operating procedures for location. 3) Maintain all records: Industrial hygiene reports, respirator care and maintenance records, medical approval and job assignment information. 4) Coordinate equipment purchases, maintenance, cleaning, storage and training. See Appendix V for examples of forms that may be used in the administration of the Respiratory Protection Program, ihtse forms are taken from the American Industrial Hyqiene Association Manual on Respiratory Protection and may be adopted for your use. (Incidentally, this manual is an excellent resource for all aspects of the program.) Medical Assessment of Respiratory Wearers OSHA requires that no employee be assigned to s job fi m CRMC-Christensen-Micro-000059 Page 3 requiring respirator usage unless the person is physically able to perform the work md use the equipment. (1910.134(a) (10)) Fee Appendix VI for medical guidelines regarding use. The local physician will determine pertinent health and physical conditions based on the employee's medical history, and a physical examination that emphasizes cardiovascular and pulmonary systems. A PA chest x-ray and pulmonary function study (FVC, FEV., calculation of predicted values and the FEV./EVC ratio, afcd comparison of determined valuers to the predicted) should also be performed. An EKG may also be included if indicated for employees 45 years and over. The respirator user's medical status should be reviewed as follows: Prior to assignment to positions requiring use of respiratory equipment (plant physician may okay an employee for respirator use if the physical examination has been within last twelve months). Re-examination for employees under age 40 is to be done every three years, age 40-49 every two years and over age 50 annually. Documentation should be made in the medical record regarding the employee's ability to wear a respirator, and the information passed on to the designated coordinator of the Respiratory Protection Program. . Training Workers and supervisors should be trained in basic respiratory protection practices. Supervisors should be aware of the structure and operation of Respiratory Protection Program and the nature and extent of respiratory hazards to which workers may be exposed. Selection and use of respirators used to protect workers against exposure as well as legal requirements relative to the use of respirators are also important concepts for those with supervisory responsibilities. nohers should understand the importance of correct usage of respirators, type required, and the capacities and limitations. Discussion of the need for respirators, with emphasis on engineering corrections in progress should occur between the worker and supervisor or program coordinator. Instruction in wearing respirator, fit and maintenance must be given. Before using, workers ihotlld have the opportunity to handle the respirator, have it fit properly, test the seal, wear it in normal air to become familiar, and wear it in a test atmosphere. (1910.114 (e)(5)). See Appendix VIS for company policy regarding failure to wear c improper wearing of respirators. CRMC-Christensen-Micro-000060 Page 4 The film "The Kaek of Life" is av.iil.4ble to you on a "loan" basis and may be obtained by contacting P* Ludwick, Health Programs Coordinator ut mail stop 1-06 or Fxt. 3324. A brochure that accompanies the film is presently being designed and will be available within the next few months. Respirator Fit-Testing Fit-testing is required by OSHA (79 CFR 1910.134 (e)(5)). However, because Compliance procedures were not well defined, OSHA issued an enforcement policy (CPL 2-2.29) that describes items compliance officers should consider when inspecting for compliance to the respirator standard. This directive is repeated here for your information. "F. Enforcement Policy. When issuing citations for violations of 29 CFR 1910.134 (e)(5), use the following guidelines: 1. Respirators must be fit-tested. ' 2. A "test atmosphere" must be applied to assess the quality of fit. 3. The fit-test must be applied to each and every employee required to wear a respirator. 4. The fit-testing requirement applies to all negative pressure respirators including SINGLE-USE RESPIRATORS. 5. The "test atmosphere" must be applied using recognized qualitative fit-testing procedures utilizing iso-amyl acetate, irritant smoke, etc.,* or quantitative fit-testing using DOP, NaCl, etc. 6. Items F.1.-5. above shall be part of the training required in 29 CFR 1910.134 (b)(3), "The user shall be instructed and trained in the proper use of respirators and their limitations." 7. Cite sserious" when F.I.-5. above, is not implemented, if the toxic substance is classified as "serious" in the Industrial Hygiene Field Operations Manual (IHPOM), Chapter II." It should be noted that since many of the substances monitored by Manville industrial hygienists MSBMBKi amq/j/t CRMC-Christensen-Micro-000061 Pago 5 would carry a health code denoting a "serious1* substance, the potential for receiving a "serious" citation exists if the Respiratory Piotection Program is not in place. Quantitative/Qualitative Fit-Testing The two types of fit-testing methods in assessing respirator fit are quantitative and qualitative. According to the Regional (VIII) Consultant to Occupational Safety and Health and others, quantitative fit-testing procedures should be applied where arsenTcT lead, acrylonitrile, radioactivity or other highlytoxic materials are used. This type of testing requires an elaborate and expensive testing system which exceeds requirements relative to respirator usage in Manville operating subsidiaries. Qualitative fit-testing procedures should be applied for substances except those mentioned above, and is the method to use within company locations. Several procedures are described below. As you will note, while the OSHA Standard is silent on the preferred testing method, the compliance directive explicitly states use of iso-amyl acetate, irritant smoke, etc. Qualitative Fit-Testing For gross determination of fitt 1) Negative Pressure Test. The wearer can perform this test alone in the field. It consists of merely closing off the inlets of the canister, cartridge(s) or filter(s) by covering with the palm(s) or replacing the seals over the canister or cartridge inlets, or by squeezing breathing tubes so that air cannot passj inhaling gently so the facepiece collapses slightly} and holding the breath for ten seconds. Zf the facepiece remains slightly collapsed and no inward leakage is detected, the respirator is probably tight enough. 2) Positive Pressure Test. This test is very much like the..negative pressure test. It is conducted by closing off the exhalation valve and exhaling gently into the face piece. The fit is considered satisfactory 1 CRMC-Christensen-Micro-000062 Page 6 if slight positive pressure can bo built up inside the facepiece without any evidence of outward leakage* For some respirators, this ret hod requires the wearer to remove the exhalation valve cover and then carefully replace it after the test, often a most difficult task which can disturb the respirator fit even rore than does the negative pressure test. If removing and replacing the valve cover is required, thi3 test should be used sparingly. For respirators whose valve covers have a sinqle small port that can be covered by the palm or finger, this test is easy. It should be performed just before entering any hazardous atmosphere. Use of test agent: There are three qualitative methods used in industry today that generate a test atmosphere around the respirator attempting to concentrate it around the sealing area. If a significant leak exists, the wearer senses the presence of the test Agent; if the test agent is not detected, the respirator is judged to have an adequate fit. 1) Iso-amyl acetate or banana oil test. Iso-amyl acetate is a liquid having "tfte strong odor of bananas. The test atmosphere is usually generated by slowly passing a swab wet with the chemical around the sealing surface of the . respirator. The test atmosphere challenges each general sealing area of the respirator during the inhalation cycle of respiration-the time when leakage will most likely occur. If the wearer detects the odor, the leak is judged excessive. To utilize this test, the respirator must be air supplied or be equipped with a purifying element capable of removing organic vapors from the test atmosphere. 2) Irritant smoke test. This method is commonly used with a!r supplied respirators or airpurifying respirators equipped with efficient air-purifying elements. The "smoke" is generated by aspirating moist room air through a stannic chloride ventilation testing tube. The smoke consists of hydrolyzed stannic chloride (HCL on a very small oxide particle)* The smoke is detected around the sealing i I I f CRMC-Christensen-Micro-000063 Page 7 surface of the respirator in a manner similar to the iso-amyl acetate test. If a leak is present, the wearer detects it by reacting to the irritation, usually with in involuntary cough. Any detection of the irritant is judged proof of unacceptable leakage. . 3) Saccharin test. This method may be used on any air supplied respiratory or air- purifying' respirator equipped with any air-purifying element approved to remove any particulate hazard. The test atmosphere is generated by nebulizing a saturated water solution of the sodium salt of saccharin. Again, the sealing edge of the respirator is challenged as before, and the wearer breathes through his mouth throughout the test. If a significant leak is present, the wearer will detect the sweet taste. Any sweet taste during the test is judged proof of ' unacceptable leakage. . Fit-Test Kits/Modifications An adequate qualitative fit-test kit may be purchased from 3M Company: Brand 9912, Qualitative Face Fit Kit In response to a question regarding the necessity of and procedure for fit-testing single use respirators, the area Director of OSHA, Savannah, Georgia, offers the following: "Qualitative fit testing single use respirators is required and an employer would be subject to a citation for failure to fit test. The current available method for qualitatively fit testing single use respirators involves spraying a saturated saccharin solution around the mask using a nebulizer. If the mask leaks, the individual will be able to taste the saccharin. (Me must keep his mouth slightly open during the test.) A kit can be made by buying a asthma inhaler and saccharin from a drugstore or one may be purchased from sane of the respirator1 suppliers. If using a 3M single use respirator, an alternative to the above method would be to CRMC-Christensen-Micro-000064 Page 8 purchase a modified 3M respirator with a high efficiency filter. Irritant smoke could then be used to perform a qualitative test." Cleaning, Maintenance, Storage A respirator inspection and maintenance program must be implemented for each location. Inspection of facepiece, valves, connecting tubes, canisters and filters for such things as cracks, tears/ dirt and broken or missing parts, etc. is necessary to ensure optimum effectiveness of the respirator. Cleaning can be accomplished in a variety of ways: From hand washing with detergent and warm water to use of washing machines or dishwashers. Disinfection is not ' necessary when respirator is worn by the same person. Thorough rinsing is extremely important in the prevention of dermatitis. Respirators may be placed on a surface or be hung up to dry. Storage should be in a clean, dry location away from direct sunlight. (1910.134 (f)(lr>5)) Program Evaluation Respirator use should be monitored frequently, and the program evaluated on the basis of overall effectiveness of the combined components in ensuring that employees are protected from respiratory hazards. CRMC-Christensen-Micro-000065 Internal correspondence Date November 11, 1982 to H. J. Young - Denver 1-06 From Wanda Foster - Toronto Plant Copies W. Reitze - Denver 1-06 Subisci DISPOSABLE RESPIRATORS During the course of his recent visit, D. Christensen inquired why we were not using the respirators issued by 3M, 9900, 9910, or 9920, as noted in your correspondence of January, 1982. We must admit that this detail was completely overlooked. At Toronto Plant we do not have any stations over the TLV, however, because of the silica exposure several of our employees prefer to wear a respirator at certain work stations and we have been supplying them with the 8710. After having this brought to our attention, we decided that a trial usage period should be conducted with a few employees to give them the opportunity of deciding which of the two respirators (9900 or 9920) would be.most acceptable and com fortable to wear, keeping in mind that we were going to have to change to these respirators and that we wished to carry an inventory of only one style. The results were as follows:- 9900 - All 4 employees felt that this respirator is too hard to breathe through, and also that they were too heavy. 9920 - All 4 employees were impressed with it, with one complaint that the binding was too hard and irritat ing to the face. The 9920 was ordered for all employees and following a further assessment period, we received the following comments:- - They are irritating to the face. - Perspiration caused by the heavy physical work our employees are required to do, is absorbed into the mask, thus making the mask heavier and more irritating to the face. - Harder to draw air in - the exhalation valve makes breathing out much easier. NP\ ' Cont'd............. CRMC-Christensen-Micro-000066 H. J. Young Page 2. Disposable Respirators November 11, 1982 Our plant physician experimented and wore the respirator for a 1/2 hour while doing some desk work. He found it very difficult to breathe, it was hot and irritated his face. It was his opinion that anyone of our employees performing physical labour, would have extreme difficulty functioning with this respirator. We therefQC* request an exception to let our employees wear il# 8710. 1. We are below the TLV and therefore not required to wear respirators. 2. Because the 8710 is easier to function with in our particular operation, and more comfortable to wear, the employees are more likely to wear protection and wear it properly. May we have your comments and approval? Wanda Foster /rw CRMC-Christensen-Micro-000067 Manville To Sea below From Copies Subject: INFORMATION UPDATE Internal Correspondence Dow February 14, 1983 1 I am enclosing four documents prepared through the office of Dr. Leineweber relating to toxicology of various materials handled in the Manville operations. You may be familiar with these publications. In any case, I think they will be a valuable addition to your library materials. Three of the papers deal with fibep toxicology: 1) "Dust Chemistry and Physics: Mineral and Vitreous Fibres;" 2) "Fiber Toxicology;" and 3) "Vitreous Insulations: Are They Hazardous?" The final paper is a review and analysis of the formaldehyde problem published somewhat recently for general corporate information. I hope you find these s documents as interesting and useful as I have* E. J. Bulava - Manville C. M. Carter - Waukegan R. C. Cordova - R-24 C, L, Pauley - Lompoc R. Alie - Jeffrey E. G. Stevens - Toronto P. Class - Wissembourg CRMC-Christensen-Micro-000068 US) Johns-Manville Internal Correspondence To: See below From: W. B. Reitze.jrj Date: Apri 1 28 , 1983 Copies: Subject- MALPRACTICE INSURANCE - JOB DESCRIPTIONS After a long talk with Mel Furman regarding our malpractice insurance coverage, he advised me that it would be in our best interests to revise all the job descriptions of our headquarters people. It is doubtful that the physician at the location (Dick Liss) or any of the location nurses will have to revise their job descriptions, but those too should be reviewed. The biggest weakness in the existing job descriptions is that they do not spell out in great enough detail the fact that those of us who are attached to the headquarters function also provide medical, health, industrial hygiene and technical health information not only to employees of the corporation but also to customers who fabricate our product, consumers who use our product, and various contacts at trade associa tions. For the most part, our plant staffs provide information only to employees and therefore would be covered under the indemnification clauses. Those persons on the headquarters staff that would be most affected would be: w. B. Reitze R. Anderson H. J. Young P. L. Ludwick J. P. Leineweber K. J. Roberts D. R. Christensen All industrial hygienists (regardless of location) Pl.euso give examples, where possible, of situations where ou!:sido advice would be furnished. Please try to have these to me by May 15. R. Anderson, M.D. D. R. Bur ford G. R. Chaso 1). R. Christensen J. P. Leineweber D. H. Noyce CRMC-Christensen-Micro-000069 . y . v v t * s fi\ ( <j 1 K* / r A i v 2*// ^ ^ / ibc ^ < 'i a/. 'H"' ^* K / jJ I> * * k f i /A o+r\ "rc k 6 * / A. y* > H * Jin^ AV#i^ et*'S*` **f . * / i * X i. i/^ k . -w * * -y* f A * J * I y'*> *y^ u v <*f , j< <> A i f i i n f* * / ^ ^*J* * v <' s!:r-i- hw IV ^ t > . *, f If 4< JIi * 'J A ir // y. -f * ** / 't *i ^ l ^ f/' ^ >i\ 'k / < k v X % r w * ^ * f // C t> v 111 > * A | ^ r (. t J\yy >' * f ^*<4^ r/i < A / | 1 tff'Cs/^ A *y f/4r 1 & 4 l 4 ^ f i < # ^ -< /, j i, i < ^ > 4 A i yj < /t u t f k f B y i J d * J / wr h\ * * I * # C y sy y* ^ >i* '' k S sk i A/iV j t / * * * t A< u . A > iy/// tv A. <vii A i i r/j i wr */ * I;, y k a v >v U M A. H . t (,h.y m ,v,<y A - / a s /A I . v r / ^ a A*. O 4 (j A I * * >i * k Ail ( 11j* f * </ A * #/ * * fy ^yf/t A l # y i> > " / 4 t j I . ^ ^ < C * &v *1 f *V w 4 t A t \J )||# / /X / )n*y J t *yym4j V * * * d f f Vr^. * I S VV(I 1/iAf I i f y* *X*y A* Wry ^>^1 Bt J \f + r y /i Hi t Xy/ lj V i t > i -*. J * * y - ^V|| 4 /* M t y I v * v^y f m iv * y r j y?( ^ A % t> 9- 3 #J K 1 a k |y >K ^ i A d - --J * O I '7A i`l fyy. w | I 4 # w *y 'I ' ci^'l fc,H j ik. >*vt| y *** *' 'y Ami-* v I ** K* - ^ SJjLXZtt. mnftgi CRMC-Christensen-Micro-000071 m Johns-Manville Internal Correspondence E. J. Bulava - Manvilie F. J. Angelos - Waukegan From 0. A. Aldlnger - Denver GHQ November 9, 1973 - CONFIDENTIAL - CoP.,. L- Swallow - Denver GHfl. M. A. Baloga - Denver GHQ D. R. Christensen - Oenver RID File I Chron Sub;mi MAINTENANCE WORKERS' ASBESTOS EXPOSURE Based on the Information extracted from the Manvllle and Waukegan Industrial Hygiene records concerning asbestos exposure to main tenance workers, it Is apparent that more testing should be Ini tiated so we ray accurately evaluate the maintenance workers' ex posure. Medical records to date reveal a higher Incidence of disease among maintenance workers than anyone originally antici pated. Although the information Is not conclusive, there appears to be trend toward higher exposures to maintenance workers when main tenance Is performed outside the shop area. In conjunction with this letter, we will be corresponding with the plant managers at Manvllle and Waukegan to Inform them of our Intention to gather more Information on maintenance workers' ac tivities and exposure. We will leave it up to you to correspond with the away plants to advise them of our Intention to gather more information on maintenance workerd, prior to your regularly scheduled survey. . S' ** D.A. Aldlnger DAA/Jtb 'wmm -fc j*3: *1V ,,_t CRMC-Christensen-Micro-000072 Environmental Control Department Denver - GHQ April 10, 1973 A. W. Jung - Manvllle IPD C. F. Luquer - Manvllle RPD N. Pontus - Manvllle P/E F. Henry - Manvllle Pipe cc: D. E. Hill ter E. J. Bulava M. A. Baloga/Flle Chron ASBESTOS DUST SAMPLING MAINTENANCE WORKERS For approximately 18 months we have been attempting to obtain a representa tive cross-section of our various maintenance activities, with regard to the asbestos dust exposures involved. Because much of this work Is done only occasionally, sometimes on an emer gency basis, and In many different locations. It is extremely difficult to know In advance what maintenance work Is being done, and thus be prepared to take the necessary samples. The statistics on pneumoconiosis at Manvllle clearly show the Involvement of maintenance people. In order to better protect our employees, we must have a better understanding of those jobs which present potential health hazards. We solicit your active participation and cooperation by advising the East ern Area Laboratory (E. J. Bulava) whenever possible, of Impending mainten ance work, which may Involve an asbestos dust exposure. Our Industrial Hy giene group will make every effort to sample during these activities and will, over a period of months, build up a back-log of Information regarding fSJw / * G. L. Swallow GLS/jbs /r/l l " <--. , 7Z / f- /'/a - "/t JP*"** a CRMC-Christensen-Micro-000073 Environmental Control Department Denver - GMQ March 29. 1973 E. J. Bulava cc: nu "Chron Str.I-ArrJAL Rrvicw OF asbestos dust stations YOUR LETTER TO !. PONTUS, DATED 12/07/73 In the above referenced letter, you expressed' a desire to provide more extensive dust station coveraoe at tfanville's Asbestos Division. I would lil.e to know how this project Is progressing. L G. L. Swallow GIS/jbs CRMC-Christensen-Mi'cro-000074 SOT Johns-Manville F. J. Angelos F. J. Bulava v D. R. Christensen L. A. Schriver Fftxn G. L. Swallow Xk ^'i '< ^ Interna! Correspondence Dm* February 15* 1979 Cop.*. E. G. Stevens W. 3. Reitze w. E. Volwiler T. M. Faas Subiect MONTHLY ENVIRONMENTAL CONTROL REPORTS ASBESTOS CEMENT PIPE PLANTS W. E. VOLWILER'S LETTER FEBRUARY 9, 1979 Enclosed is a copy of the subject letter together with an example of the "stations over TLV" report being established. Please note that among other things, this report is to taV.e the place of the corrective action report we have requested subsequent to each Industrial Hygiene Survey. Since the new report will be monthly and will include the corrective action status for all stations over TLV* it should improve the' monitoring of corrective actions taken. (/ G. L. Swa'ildw si Enclosures CRMC-Christensen-Micro-000075 1' * '^'*1 Johns-Manvillo Internal Correspondence fa G. L. SWALLOW - 1-00 WIK) D.*s FEBRUARY 21, 197? . D. R. CHRISTENSEN - RAD r<-r . T. C. McGTTH'.AN - 3-N (PLAZA) J. F. HERR - RAO W. I'. KE1UE - 1-06 WIK) S. M. FENNER - l-Ob WIK) *>**'' INDUSTRIAL HYGIENE SURVEY - POWERS REGULATOR COMPANY TRANSITUBE DIVISION, DENVER, COLORADO FEBRUARY 23, 1977 - . A special Industrial Hygiene survey was recently conducted at lie Powers Regulator Company Kingsi< Street warehuuse in Denver on 2/23 by K. J. Uilllans with the help of Hr. Jisi Brietske, Product Engineer for Powers. Tlie object of this survey was to detersiinc the environmental impact, if any, when Transire Korduct (J-H) pipe containing asbestos fiber has been substituted for PVC pipe in the company's pneumatic tube systems. Particular Interest In the poten* tial tor expulsion of asbestos fibers, dislodged from tire Korduct pipe interior by attrition from frequent "carrier" travel, into the workplace was indicated. For the purposes of environmental testing, a smdei Courier brand "point-to-point" tysten equipped with Korduct piping was installed in the Kingston Street warehouse . The sysiesi consisted of seven joined 10'lengths of 4" diameter Transits Korduct (Type 1/B TEL) anchored horltontally on a warehouse wall approglauitely 13* above the floor connected at both ends, of the total 70' pipe run to 90* Transitv bends (48" radius) having a downward orientation, aa de picted in tin- attached drawing. As lire drawing shows, all piping connected below the 'JO0 bends w.>* suite of PVC. Tire entire system measured about 100* in length. Tire end oi the system having the sir moving equipment (blower) is comsonly known as tire "local" station. The opposite end of tie system is referred to as the "remote" station. Hie carrier is transported hy vacuum to the station nearest the blower and ly pressure to tire station fgrtliest from the blower. Both stations have a sliding sleeve covering an access port for canier entry and removal. The system blower delivered approx incite ly 1.3 p.s.i. pressure and 120 Ct*M volume. A one-way carrier trip took about b seconds to complete. Two types* of carrier wear bands were used on different carrloro . at certain stages of the tests .is outlined below, line was mod# of acrylic carpeting and the other of a material called VELCRO. Tests of carrier band durability werr In progress during tbo CRMC-Christensen-Micro-000076  TRANS ITLtiL DIVISION, DENVER, CULCMDO FEBRUARY 23, 1977 Page Two environmental testing. Tle carrier wear baud* wre apparently not an Important factor in influencing lest results. The carriers were operated through the pneumatic tube system on a continuous back* - and-forth basis during the sampling period. Since these systems are rarely used on a completely continuous basis in actual field use, these tests should have represented a nuxisHH* air contami nation condition. 400* carrier round trips were made during llie 5*1 hours of consecutive testing. The only significant difference between the model pneumatic tube. system and a similar one in field use was that the Pressure Relief Valve shown in the drawing as being on the horizontal pipe run, was actually located vertically at the "remote" end of tin- system (sec drawing). This modified arrangement should not have made any Mil difference in observed dust levels. SAMPLE LOCATION 1* from "local" end blower exhaust point in center of air stream (i.e., axially). SAMPLE DURATION 2 hours 2M UN RESULT 0.0 F/cc <0.1 y/cc <0.1 F/cc Area sample in vicinity of "local" end sliding sleeve (operator's position). 2M 2n Ik M 0.0 F/cc 0.0 F/cc 0.0 F/cc Area sample 10' from "local" end blower. 2H 2W <0.1 F/cc 0.0 F/cc Area sample 20' from "local" end blower. 2H 2n 0.0 F/cc <0.1 F/c I' from "remote" end pressure relief valve exhaust point in center of air stream (i.e.. axially). 2M 2N nM <0.1 F/cc 0.0 F/cc 0.0 F/cc Area aample in vicinity of "remote" end sliding sleeve (operator's position). 2 2 1% N ** M 0.0 P/cc 0.0 F/cc 0.0 F/cc Background area samples in warehouse area approximately 75* south of primary sampling area. 1* U M N <0.1 F/cc <0.i r/cc The above results were obtained using the standard Millipure filter sampling/phase contrast microscopy analysis technique called for by NIOSli. Results shown as <0.1 F/cc (f ibvrs/cubic centimeter) weft m r,, B k CRMC-Christensen-Micro-000077 1 ft e < WANS t 1 HIM'. ItlVIS ION, DKNVLK, COU'AOO H.UHUAUY *3, 1979 . Pig* Three actually small fractions of 0.1 f/cc but wire reported this way as to avoid iaplying a technique prevision d*e* iw cxtL. Mutil on the foregoing test reiulti, the particular "pointto-polwt" system . tested should be considered an almost fiber*free operation. All reaulta are well below any currently existing or proposed occupational health standards for airborne asbestos fibers. These test results should represent a typical operating condition (or a well*vorn fi.e.. several thousand completed carrier trips through the system) pneumatic tube system containing Transito Rorduct piping* However, a problem may exist during the initial shakedown operation of o new systen based on reported observation (not teetfed) of a light visible dust costing on carriers probably developing from residual dust on Korduct interiors loft during pipe manufacture. Perhaps g washing or cleaning of pipe interiors during fabrication in J*M plants would alleviate this potential dust source. At any rote, the oboerood dust source should definitely not bo ignored. ' /N/if f) A , l /1 i..t / D. R. CHRISTENSEN KJVtORC Attachment i . * l r* ,9 ft CRMC-Christensen-Micro-000078 M*^Cry<RancM P.O.BOX 5108 Otnr.CtforadD17 nirMBOD December 3* 1982 E$* Manville Nicholas J. Hluchy) Suita 909 Crystal Plsss 4 1745 Jefferson Davis Highway Arlington* VA 23201 Dear Mr. Bluchyji Data developed by the Johns-Manville Research t Center to determine airborne concentrations of asbestos dust when fabricating asbestos cement products with hand tools is enclosed. Table a gives dust counts* f/cc when the fabrication was done in a test chamber. Table B shows counts whan the work was* done in an open room. Tables 1 and 2 essentially repeat the data given in Tables A and B. They are included here because they add sens information (cutting rats). The tables are followed by description and photos of the tools tested. Some comments regarding the tests are as follower The test chamber is a glove box approximately 3d inches high* 30 inches wide* and 8 feet long. Air is drawn into one end of the chamber* through the area in which the cutting is taking place* and exits at the other end of the chamber carrying light dusts to the baghouse. Baffles inside the chamber direct the dust-laden air past a dust sasf>ler (open face membrane filter) so that the dust generated during the fabricating operation is monitored. it should be noted that a great deal of work was done during each test* i.e.* 4 holes drilled/minute* 18 linear inches cut/ainutes * etc. This rate of fabrication is probably higher than would fee encountered in the field* and thus* represents a most severe test condition. CRMC-Christensen-Micro-000079 Nicholas J. Bluchyj December 3, 1902 Pagt 2 Tha results shown la Tables A and 1 represent dust trated la a stall voluae of air carried directly past the samples, giving higher readings than ever encountered in an open area. In addition to the Johns-Manville data, we have German data covering a handsaw, hood scriber and nippers, hand acriber, hand clippers, hand drill, parallel shears sad hoed rasp. The results are shown on Table C, with pictures of the tools following. Also refer to the Annex (Testing Procedure} in the AZA Catalogue of Tools. Very truly yours. l V v - D. A. Christensen, C.X.B. Manager-In-Training Occupational Environmental Control Health, Safety k Environment Department i CRMC-Christensen-Micro-000080 9 0# TABLE A TOOLS TOR ASBE8T08 CEMENT FABRICATION TEST CHAMBER (1/4-INCH FLEABOARD) Tool ' Tool inscription Conditiona Handsaw No vacuum SEtarnit Sag pickup Ho. 99910) Tost Duration (Min.) Mork Dona IS 53.9 inchaa Material Fulvariaad (gn) 31 Fulvariaad Duat Nat'fi Captured Count (parcant)1 (f/oe) 9 0.3 Ramarke Much dabria laborioua Hand reap Mo vacuun pickup 19 229 atrokaa 17 19 0.9 Much dabria Mttrlal oapturad by baghout and/or vaouua olaanar aa a percentage of total aatarial pulveriaed. CRMC-Christensen-Micro-000081 Mtlto o TABLE B TOOLS FOR ASBESTOS-CEMENT FABRICATION PHI ROOM (1/4-INCH FLBXBOARO) Test Tool Test Duration Dticsriptimi Conditiona (Min) work Dona Duat Count (f/ee) Araa Fara, Handsaw No vacuum (Starnit Baf piokup No. 00810) IS 53.5 inchaa 0.1 Band Clippara (Ittamit Bo. 8000S) Mo vacuum piokup IS 270 inchaa 0.0 0.3 loorinf flnifa (Ittarn It RAaaaRnlv o. 80000) Mo vacuum piokup IS 272 inchaa 0.0 Hind rai No vacuum pickup 40 000 atrokaa 0.1 0.1 Ramarka Much dabrio (1/0 inch A/C) (1/0 inch A/C) Much dabria CRMC-Christensen-Micro-000082 VOGL lliype, Ssfcffill TNU C MATERIAL MOBBED 9E CORING GAMOR operate* tom Type, ihickmaa, etc. Vhf etc* * OP IDOL c%) mm am iimm scums mma am scum Proflit 3, croft cut ivoflto 5# Rltiingi cverlapping 20 cm Profile 9f longitudinal cut dual 4 an 14 m/b SO Triimli 100 v/b 105 Vh 23 0.5 25 01 wo amm mm mm* mm. urn mi mnia asm MO MSP BflGI KIP OU, HUMUS MMR MHL 1014 *w--f bmhjv MQHLS1.0 fflWl 4 Ml Miami f mi Profile Si cram cut 37 a/h 37 21 31 33 10 SMC. f/Oi 0.0 0.0 1.8 . 1.7 0.1 <0.5 <0.5 <0.5 <0.5 <0.5 0.5 0.0 0.3 CONORS Problea handling and breaking fnblen handling and breaking} high working tine (01%), not in pcactioa HBPH CRMC-Christensen-Micro-000083 atmpiawmcmix i orTABUS 1. MSOIflB wr 1GSTB ODNDDGBD ZM DOST a) ; i) tut condition - Maia clamor air wilocity In taatiMi Act)( III Jtaomfc mptecta kv wm pickup frajor) H TCBi iMadal bine fatrimto* it Oat 3.1 to 3.2 in. Bg. Air utoeiti tinoc) aa a paromfc of aatacial pnlmlad Ip tool. 1/4 la. ttdck. mm"***** CRMC-Christensen-Micro-000084 ||| Q JUfBDXX I a.mu mug op amt wra ooMucnD m men mi M Met Duration Oumity Dm (pitamtePL-- j Rkm Naadiw {RkrU %t$m. mmm Binds No. 56-10. No mt pollaction. 15 mwem Mnfi CUffin dandt asks no. aooes) No dm nUnctlon* IS 1/4 In. cm At 53.5 in. 3.57 in. ft 0.1 I/O in. 270 in. 10.0 in. 0.0 0.3 Much oonrot notorial fall to floor* a potantial clampproblm. km ooarao notarial fall to floor. L * Mm soaring no dm f nlfa {Rnit minetion* limkalT id. aim 15 1/0 in. 272 in. 10.1 in. il 0.0 l i CRMC-Christensen-Micro-000085 INSIIRT to Recommended Control Procedure No.2 (RCP2) CATALOGUE OF TOOLS for working with asbestos cement products on site COWtlHVS /bMjts CYraeiH BuiMing PrHluct% on l*rr kuK ***** i - rd!.*-M >**" rudMi A>hcsts Cement Pipe* *-- Annex Tatung 1.1: mNitf uvmgik'd iMdi n<j4,Kiw<i eul* > cvmiMifd ruling ft* dmi* 14*106 mm k* #> AC p*od><tt i*J"y sij-xlaiJ nrW d**s o* c**txteIWRI dn% Ul up fc* 70 mm nw> ioi|Ri<wd AC mduett 141 to 6 mm ctn(PS5f(l AC ^ho**ng and cutting mhts on the wot 1.7 Cidling SIMM And Hal 900 mm long ptmchmg now* up to 0 up to INCA Ckdtmg up ID 6 mm udung up to 3 mm CRMC-Christensen-Micro-000086 I 1 I 1 POWER TOOLS WITHOUT EXTRACTION KQUMflCMT i T- . t* uw`1 *" ojwn mi nr tot if ,-ft .>*. pmom **oc*ss me framed Cl J 111 lwauo mna1 * 1>"J 41 j(ff <1 ImHlMliM'l Uw fcr i .| Ih* up In f t*r> hr radius t uil*n, el 40 mm Wulicluin M Oannerf If /JO' lxI .sitf^wNoctar Wf-SI &ffr>iany IIL4 DnofUKin Specie tool f******| w**tg *. nukjt at an Hectic drd lBOSCH It 13| Pom?* 3*0 W Spued 470 rpm Use lrj tutting cvugaM shouh tp 10 8 non Su*c (HCPuion Dans* [ loftiii f b>* A S PO Bo* Tb3 UK 9100 Aaiuafg OlWM* ItMptione (00) '7 117? Ten*. 0 9/ 74 I term OK m U% ipM) U>' * In1 (N**p4) im| the malar c# an emcH. cK<" (ttfy/.H mj 1*0*14 :mow Simii snip* U' tor cutting iia trvrnn% up to 10 m Sum* (Wulxilari Dons* Lhpmi #aft* AS 1*0 Uu. na OK 9100 AatKKg Ommaffc If** 1 low |08) 1? *1.7? Tctoi t> 97 74 Item UK Oncfpkan Pimm 780* Speed 18001 mitt gusftng Oner w*i tungsten cartxde tipped Met) bMde fRH Bi*on hi IJO) U* tor mting camqaod thrall tw noss ci*iiq canugah'd ittralt hj> tastg&,j&rt& ct**tf*g corrugated note cutting l osouts (Mdut 40 mm and i MarxAactUfwt Dnmg gn* C 81 Fern Podtaett IT? moo sm^m NmGniMny Spec* guKXu drvee Hermann 34 40* hewn West Germany Special blade BmdranKG AmSuwrt)*B?3 *4> I0 BacMi 4 ftcV Qmpy iMutoutoi Nffichattsvediand *il*il/iwrt t V CO Bor ItOfaTO D 1000 Brfxn 11 4(i-.I Ijt.c .aiy Tmtfttanv 030 3*84 411 Tetti 0181271 *! Dnc(p> Pom* 400 W ttocpoulttg fl((*nmn Btartp* G 1004 7400 G WD* kv mating and cmtidMig OKunA'I Manutoctiaer tngctoft-Rand Toot Co Mdtrrs Fan Tool Dmoi Sauin Deertuto USA OWfMtof toi futopo Messrs Prato*am ltd Balwncn liabgliMe Vote. iv*to< UK Telephone 0*44 319448 Ome* blades Cetodettoped Cat No 88/87 3 m X T Manilactuwr to (Mrtoulor tor Umed Slates The Henry G Thompson Co Stanford CurmedCUl USA Dsi'Mct tor m Aboard Sa*s Md Un*3 Oi'Thorpe Road toduNnai C Own UK Telephone 0S94 47S CRMC-Christensen-Micro-000087 ORIGINA*. INVOiCEJ .2 MINE SAFETY APPLIANCES CO. POST OFFICE BOA 360838 PITTSBURGH, PA. 15230 DEPT. NO.4656640099 2621052 400>ElirfU:ENTER BOULEVARD. PITTSBURGH. PA. 15235 SHIPPED FROM FoB TERMS 39190 salt lake FOB SHPT M: T 30 DAYS CUSTOMER ORDER NO " ^Z 27 2184 3 REQ NO. 9-13-3 PNONi 412-241-5900 DATE (326 s JJHNSMNAVILLc cukp ^ GREENWLGj plaza d DENVER CjLU 60217 sJOHNS MANVILLE CORP "10100 UTE ST pJEFFERSON COUNTY COLO tATTN D CHRISTENSEN o F utchKo COPIES *EN EG shipped v>a CATALOG NO minor Pc TERR ST. CNTY. city IND. 1811 005 059 0000 0000 R/L NO K N ___C_C___ kI lTA* CODE1 DATE SHIPPED EC INVOICE DATE 9-19-7: SALESMAN 09/58854/3 1 RIO GRANDE 220781 9-17-73 J.T.LEECH | SLC DESCIIPTION QUANTITY SHIPPED UNIT PRICE AMOUNT 9o000 96106 45606 d 456059 456243 RESPIRATOR OUSTFOE 77 FILTER 50/PKG DF 77 PUNP ASSEMBLY#MONITAIRE*MODEL G BATTERY CHARGER ASSEMBLY MOOEL G HOLDER ASSEMBLY,CYCLGNE FILTER MOUNT ' FA! 3 .Y X oo % // /d)v - i^ 7/o -- *7 - IWA j, NOV 573 51895 - .06 -i- - 9-7* CHECK NO. J, 5*670 9*500 168*000 42*000 35.000 STATE STATE TfcX PAY THIS AMOUNT 45*: 19.4 2, 184.4 630.4 280.1 3,158.: 3,158.: *E HEREBY CERTIFY THAT moufJts tm rocEir ITEMS NOT SHO UNLESS NOTIFIED within thirty days REGARDING SHORTAGE SHIPMENT. CLAIMS CANNOT K HONORED. Wf HEIERV CERTIFY THAT THEIf GOODS wftf PRODUCED IN COMPUANCI WITH AU APPLICABLE REQUIREMENTS OF SECTIONS A P. AND IJ OF THC FAIR IAROC r"T"n ACT OF 1*3*. AS AMENDED. lNO OF REGULATIONS AND ORDERS OF THE AOMMSTRATOR OF THE WAGE AND HOUR DIVISION ISSUED UNDER SECTION 1 THEREOF. 26007 CRMC-Christensen-Micro-000088 Department of Health, Education and Welfare ' i CDC, NIOSH Minutes of Meeting Between JohnsManville and NIOSH Concerning Asbestos Fiber Sampling and Analysis Rockville, Maryland February 1, 1977 , Minutes Prepared By John M. Dement Attendees See Attachment I Vern Rose, Director, Division of Criteria Documenljation and Standards Development, NIOSH welcomed the attendees and introduced the NIOSH per sonnel in attendance. Mr. Rose stated that minutes would be kept and circulated to all attending parties to be certain that the minutes pro perly reflect the disposition of points discussed. He then turned the meeting over to Dr. Kotin of Johns-Manville. Dr. Kotin stated that he viewed this as a technical meeting to discuss measurement techniques for asbestos as mentioned in his letter to Dr. Finklea. Dr. Kotin introduced Johns-Manville personnel in attendance. Richard Carter of Johns-Manville stated that Johns-Manville was concerned about the accuracy of the asbestos fiber sampling and analysis method at the level recommended by NIOSH. Mr. Carter stated that they were par ticularity concerned as to the use of this method for compliance purposes and referenced Johns-Manville*s comments to the OSHA Docket Office submitted CRMC-Christensen-Micro-000089 \A April 1976 (Attachment II). This document concluded that the phase contrast counting method was not sufficient to distinguish between 0.5 and 2.0 fibers/cc. Dr. Chase next stated that the recently released NIOSH document on asbestos referenced a NIOSH document, TR84, concerning asbestos fiber sampling and analysis. Dr. Chase asked if this document had yet been published as he had received several copies labeled as "draft". -`Sf | Nelson Leidel next stated that the NIOSH asbestos analytical method had been released as a NIOSH Analytical Method (PCA&M No. 239). Mr. Leidel stated that the NIOSH document, TR84, had not yet been published. He dis tributed the most recent draft to interested parties (Attachment III). Mr. Leidel stated that the counting rules had been changed slightly to eliminate a potential counting bias. : Dr. Chase maintained that a bias could still exist when counting curved fibers. Mr. Leidel next asked why Johns-Manville had not attempted to contact him directly concerning the precision and accuracy of the NIOSH method as he was senior author on the NIOSH document. Dr. Kotin and Dr. Chase apologized that a discussion with him had not taken place. Dr. Chase stated that he had attempted, unsuccessfully, to contact Mr. Leidel. | Mr. Rose reinterated that the purpose for the meeting was to discuss asbestos sampling methods recommended by NIOSH including the basic approach and the precision and accuracy. CRMC-Christensen-Micro-000090 : Mr. Leidel next discussed, in some length, the March 1976 draft of TR84 which had been distributed. He stated that all available literature con cerning the precision and accuracy of asbestos fiber sampling and analysis including all sources of variability was reviewed. He stated that, after this review, he was still convinced that a coefficient of variation (C.V.) for the entire sampling process could best be estimated at 0.22. Mr. Leidel stated that the C.V. was only used for decisions of compliance versus non compliance and asked what Johns-Manville would consider an appropriate C.V. Dr. Chase stated that the C.V. should be applied with reason in decisions of compliance. Dr. Chase stated that he felt that a single value for the C.V. for the entire monitoring process may not be appropriate. He further stated that he was concerned with the inherent variability of the entire process starting with collection of the sample in the field. Dr. Chase maintained that NIOSH was considering only counting variability. Ken Busch next questioned what Johns-Manville considered error in the method. He stated that experimental error (inter-lab) should not be considered. Mr. Busch stated that the NIOSH Proficency Analytical Testing Program (PAT) included some laboratories which may not be properly using the prescribed NIOSH methods; therefore, results from these labs should not be used for establishing error in the method. Mr. Leidel stated that spot checks by NIOSH personnel had shown considerable variation in the methods used. John Dement also pointed out that samples prepared for PAT, by ultrasoneration, were much finer in diameter and therefore more difficult to count than actual samples collected in industrial operations. CRMC-Christensen-Micro-000091 Dr. Chase asked if NIOSH considered only variability in the method after the sample had reached the lab and asked if variations within OSHA's Salt Lake City lab were considered in the document prepared by NIOSH. Dr. Chase maintained that NIOSH placed considerable weight on the study conducted by Conway and Holland (prepared for the Asbestos Information Association) which considered only within filter and counter variation. Ken Busch stated that full-period (or consecutive full-period) breathing zone samples represent unbiased estimates of time-weighted-average concentrations and that spatial and time variations should not be included in error estimates. John Dement pointed out that a study conducted by NIOSH and presented by Weidner at the 1972 American Industrial Hygiene Conference had confirmed that breathing zone samples were unbiased. Dr. Chase again emphasized extreme variations with actual field samples citing Part III of the study by Rajhans and Bragg where side-by-side measure ments were taken. Nelson Leidel pointed out that the Rajhans and Bragg study was difficult to interpret in that only standard deviations were reported. Mr. Leidel stated that the C.V. was a better measure of variability. Mr. Leidel also questioned if the Rajhans study included temporal variations. Dr. Chase maintained that Part III of the Rajhans study showed differences between controlled and non-controlled conditions. Nelson Leidel pointed out that field variations should only include errors in sample volume (pump error). Mr. Leidel pointed out that some of the CRMC-Christensen-Micro-000092 samples collected by Johns-Manville, reported In their submission to the OSHA Docket Officer and used to calculate C.V.'s, did not follow the NIOSH method in that fiber densities (fibers/field) were very low. Dr. Chase maintained that the counting Poisson error was important but a minor source of variation. He stated that various sampling times were used for the Johns-Manville study and that sampling time was left to the judgement of the industrial hygienist. Both Dr. Fink]~ and Vern Rose asked if 8-hour samples were taken and, if so, were these data analyzed separately from the other data in the statistical analysis performed by Johns-Manville. Dr. Chase and Denny Christensen stated that only one set of the Johns-Manville samples were collected over an 8-hour period. Denny Christensen stated that difficulty was often experienced in taking extended period samples because contamination by other particulates occurred. Nelson Leidel asked if the field hygienist collecting the Johns-Manville samples were given the NIOSH report defining minimum sampling times. Mr. Rose also inquired as to the experience level of the hygienist. Denny Christensen stated that all hygienist were aware of and familiar with the NIOSH report and that all had 7-10 years industrial hygiene experience. Vern Rose pointed out that samples 1,4,8,9,10 in the Johns-Manville report had concentrations less than 0.5 fibers/cc and that the C.V.'s ranged from 0.3 to CRMC-Christensen-Micro-000093 0.6. Mr. Rose questioned, based on this data, if one could not tell the difference between 0.5 and 2.0 fibers/cc as claimed by Johns-Manville in ite report. Mr. Rose asked the Johns-Manville attendees what upper range for the C.v. they considered would include all values for C.V.'s obtained. Dr. Chase stated that he had no estimate as the observed values for the C.V. were extremely variable. Dr. Chase maintained that insufficient data were available for this estimate and that he would make no inference with only a few samples. Nelson Leidel pointed out that 30 samples with a high number of degrees of freedom were available from the Johns-Manville study. Mr. Leidel asked if an analysis of variance exercise would not be fruitful. Vern Rose pointed out that the highest C.V. observed was 0.7 and most ranged from 0.5 to 0.6. Dr. Chase stated that the Johns-Manville study, which covered few industrial operations, was not sufficient for an overall analysis covering the entire industry. Dr. Chase stated that the Rajhans' st-dy (Part I), where identical fields were counted, gave a C.V. up to 0.2. Nelson Leidel asked if Johns-Manville had performed an analysis of the C.V.1s from data in Table II and III of the study published by Ortiz. Mr. Leidel pointed out that these data, which analyzed both between counter and intra-filter variability, show c.V. values to range from 0.13 to 0.27 with an average of 0.20 to 0.22. Mr. Leidel also stated that these counters were inexperienced. CRMC-Christensen-Micro-000094 Both Dr. Kotin and Dr. Chase maintained that these data were only illustra tive and non-conclusive. Sr. Kotin also stated that the Los Alamos had been performing dust counting for several years. After a short break, the meeting was again turned over to Dr. Kotin of Johns-Manville. Dr. Kotin stated that he wished to get the meeting out of a "sparring arena". He stated that Dr. Chase had serious concerns regarding the variability in the entire series of events concerning asbestos fiber sampling. Dr. Kotin stated that, if NIOSH was convinced that these variables were insignificant, the meeting should stop. Nelson Leidel next asked the Johns-Manville attendees how decisions as to compliance and non-compliance were made from data gathered during JohnsManville' s own sampling program. Vern Bose asked if a C.V. for the asbestos sampling method was used for these decisions and, if so, what value for the C.V. did Johns-Manville use. Both Denny Christensen and Dr. Chase stated that actual values from the sample results were used with no statistical treatment of the data. Mr. Christensen stated that no single value was used for an operation and that all operations were sampled 4-12 times per year. Ken Busch pointed out that, if Johns-Manville believed that the C.V. for the asbestos sampling method were as high as 0.6 as they had stated, with a result of 1.4 fibers/cc, actual exposure levels may be as high as 3.0 fibers/cc. Mr. Busch stated that Johns-Manville's failure to use the C.V. in their estimates of compliance and non-compliance must indicate confidence in their sample data. CRMC-Christensen-Micro-000095 Dr. Kotin stated that fiber levels in most Johns-Manvills operations were less than 2.0 fibers/cc and that most were below 0.S fibers/cc. Mr. Christensen again stressed that multiple samples were taken at each sample site over a year period. Dr. Chase again stressed that all components of variability in the field sampling method should be considered. Both Nelson Leidel and Ken Busch asked Dr. Chase to explain which components of variability were not considered in the NIOSH analysis. Dr. Chase stated that the Johns-Manville study was only interested in demon strating variability to be expected from actual field samples; therefore, no analysis was undertaken to isolate major components of variability. Vern Hose stated that NIOSH would not recommend to OSHA that statistical techniques not be used for compliance/non-compliance situations. Richard Carter stated that OSHA standards are enforced in an absolute sense without taking into account sample variability. Dr. Kotin conceded that NIOSH had investigated sources of variability in the asbestos sampling method and that differences expressed at the present meeting were differences in scientific interpretation of data. Dr. Kotin offered CRMC-Christensen-Micro-000096 Johns-Manville's assistance in collecting any additional data that NXOSH might desire concerning asbestos sampling methods. Dr. Kotin questioned ! if the NIOSH recommended standard of 0.1 fibers/cc was not really an euphemism for zero exposures. Dr. Finklea stated that zero exposures were certainly a goal and product sub stitution should be of major concern. The meeting closed with Vern Rose thanking all attendees for their participa tion. CRMC-Christensen-Micro-000097 Name Dr. John Finklea Nelson A. Leidel Dr. Paul Kotin Dr. J.H. Wills Paul Schulte John M. Dement Kenneth A. Busch Dr. Jon R. May Dr. Irwin P. Baumel Dick Carter Dr. Jerry Chase D.R. Christensen Vernon E. Rose Ralph Zumwalde ATTACHMENT I Attendees Organization Director, NIOSH NIOSH Grad. Trainee V.P. Johns-Manville DCDSD, NIOSH DCDSD, NIOSH DSHEFS, NIOSH DTS, NIOSH DCDSD, NIOSH CDB/DCDSD, NIOSH Johns-Manville Johns-Manville Johns-Manville DCDSD, NIOSH DSHEFS, NIOSH Telephone 301/443-1530 617/732-1167 513/684-8210 513/684-3255 513/684-8306 301/443-5290 301/443-4216 303/979-1000 303/979-1000 303/979-1000 Ex. 4583 301/443-3680 513/684-3255 CRMC-Christensen-Micro-000098 mwu*+:e- Exhibit D MONITORING AND MEASURING AIRBORNE CONCENTRATIONS OF ASBESTOS Summary From a workplace monitoring point of view, an air environment containing 0.5 fibers/cc definitely cannot be distinguished from one of 2.0 fibers/cc with only one or a few determinations, and may not be distinguishable even with many determinations. This conclusion is apparent if the available literature on segments of the monitoring process is critically reviewed, and the conclusion is inevitable if the new theoretical and, most importantly, actual workplace sampling results presented here are added to our llmli3 Knowledge of the entire monitoring process. It is well documented that neither OSHA nor MIOSH clearly understand the "accuracy and precision'1 of the entire field monitoring process. Citing inadequate and inappropriate data, NIOSH has drawn conclusions that are obviously contradicted not only by previous and newly available studies, but even by other NIOSH data and studies. Bias from two sources is shown to be present in the monitoring for airborne asbestos fibers: (1) trained, experienced hygienists show large differences in interpreting and counting fibers, even when looking at identical fields of view in the same microscope, and (2) the recommended fiber countinq rules have built-in, theoretically proven, biases. Empirical evidence of large differences between laboratories has been presented. The most relevant data for the investigation of the "accuracy and precision" of the entire monitorinq process have been taken from a study of actual workplace simultaneous sampling carried out by Johns-Manville. The decision to undertake such a study was made because of the lack of adequate, appropriate information pertinent to the OSHA proposal to monitor accurately at 0.5 fiber/cc. A solution frequently offered to improve the precision of the entire monitoring process is to increase the number of microscope fields and/or fibers counted. Theoretical analysis, utilizing empirical results from controlled laboratory experiments and actual workplace sampling, shows that this expensive time-consuming effort would produce a minor measurable or noticeable improvement. Thus, not only is the recommended monitoring method inadequate to monitor a difference between 0.5 /cc and 2.0 f/cc in the field, but also there are no known modifications to the method that would permit such monitoring. Introduction The Occupational Safety and Health Administration's Notice of Proposed Rulemaking -- Occupational Exposure to Asbestos as 1 CRMC-Christensen-Micro-000099 published in the federal Register on October 9, 1975* states in paragraph (e), Monitoring * that: 'The purpose of all monitoring required by this paragraph is to measure accurately the airborne concentrations of asbestos fibers in a workplace to which employees would be exposed if they worked in tne area without the use of personal protective equipment, such as respirators. Monitoring shall be performed in a manner reasonably calculated to satisfy this purpose." (emphasis added) It is our judgment that the accuracy of the complete monitoring and measurement process has not been adequately studied and, as will be shown, is not clearly understood by either OSHA or NIOSH. Conclusions and recommendations have been made using inadequate and inappropriate data. The technology that would permit a determination of the true accuracy of the complete process for the monitoring and measurement of airborne asbestos fibers, that is, to determine the closeness of a sampled value to the true airborne fiber concentration, does not exist. In other words, it is not possible to create an airborne asbestos dust cloud with known fiber concentrations, and to monitor that dust cloud using workplace techniques, and thus, to compare the estimate of the airborne fiber concentration, using workplace techniques, with the true airborne fiber concentration. Even though such knowledge of the accuracy of the process would be most desirable, the absence of such knowledge does not preclude its use for some purposes of airborne fiber estimation techniques. Nevertheless, the absence of knowledge of the true accuracy of the method for monitoring and measuring the concentration of airborne asbestos fibers makes it imperative that the limitations of the monitoring and measurement process be clearly understood. It is not sufficient to know that currently measured levels of airborne fibers appear in a general fashion to follow directional differences in the visual or conceptual estimates of the airborne fiber concentrations. A knowledge of the magnitude of the actual inherent variables associated with the monitoring and measurement of airborne asbestos fibers in working environments is essential for the rational use of the complete monitoring process to regulate working environments. Otherwise we will be misled and deluded by a false sense of the meaning of a "measurement" as made by current methods. Since we do not have an absolute 'yardstick' by which to measure airborne asbestos fiber concentrations, it is useful to seek answers to the hypothetical question: What is the valid meaning of a single or even several measurements of the workplace asbestos fiber concentration? Suppose a large number of qualified industrial hygienists were to independently monitor the same work location, at the same instant on the same day: What distribution of the estimates of the airborne asbestos fiber concentration would be observed? CRMC-Christensen-Micro-000100 Such a knowledge of the distribution of estimates the individual hygienists would arrive at using their own equipment, calibrations, preparation and counting would give insight on the "empirical precision" of the entire monitoring process. By the "entire monitoring process," we mean the techniques and equipment used to both monitor and measure airborne concentrations of asbestos. By "empirical precision" we mean the variability of repeated measurements taken under equivalent workplace conditions. (The standard deviation'is often used to express precision.) Defined in this manner, it is possible to investigate the variability of the entire process for the estimation of airborne asbestos fiber concentrations without knowledge of the "true' airborne asbestos fiber concentrations. Thus, if all hygienists were to arrive always at the same estimate of airborne fibers when sampling under equivalent conditions, the monitoring process would be considered to be very "empirically precise or repeatable, even if it is impossible to determine how "truly accurate or precise tne estimates are relative to the true but unknown airborne asbestos fiber concentrations. The true `accuracy or precision" of any measurement process is generally defined only by the closeness of the measured or computed value to the true value. Our technical inability to determine the true accuracy or precision of the entire asbestos monitoring process makes a determination of the empirical precision of the entire monitoring process imperative before it is possible for employers to monitor for compliance with a standard and for regulating agencies to monitor for compliance, no-compliance decisions. The determination of the empirical precision of the entire monitoring process must be done by actual field (i.e. workplace) sampling. The results from a study designed and conducted by Johns-Manville to offer much-needed information on the empirical precision of the process is presented in later sections. The first section following the Introduction presents and contrasts pertinent paragraphs from the current and proposed OSHA standards for exposure to asbestos. In the second section, the NIOSH monitoring and measurement procedure recommended in the proposed regulations is briefly reviewed. The sections following that present and discuss empirical evidence on various components of the entire airborne asbestos fiber monitoring process. For example, hygienists differ substantially in their interpretation of identical information. The Johns-Manville factory sampling study results are presented and discussed in a subsequent section. Finally, new theoretical results are presented. Tne concluding section summarizes the information and implications of this discussion and presentation. 3 L CRMC-Christensen-Micro-000101 OSHA Standards for Occupational Exposure to Asbestos -- Current and Propose3 " ~ "~ The following sections dealing with the permissible exposure limits and monitoring requirements for airborne asbestos fiber concentrations have been reproduced from the current and proposed Part 1910 of the Occupational Safety and Health Standards. The current Standard information is on the left/ the proposed is on the right. Permissible Exposure Limits Current Proposal (b) Permissible exposure to airborne concen trations of asbestos fibers. (1) Standard effective July 7, 1972. The 8-hour time-weighted average airborne concentra tions of asbestos fibers to which any employee may be exposed shall not exceed five fibers, longer than 5 micrometers, per cubic centimeter of air, as determined by the method prescribed in paragraph (e) of this section. (2) Standard effective July 1, 1976. The 8-hour time-weighted average airborne concentra tions of asbestos fibers to which any employee may be exposed shall not exceed two fibers, longer than 5 micrometers, per cubic centimeter of air, ns determined by the method prescribed in paragraph (e) of this section. . (3) Ceiling concentration. No employee shnll be exposed at any time to airborne concentra tions of asbestos fibers in excess of 10 fibers, .longer than 5 micrometers, per cubic cen timeter of air, as determined by the method prescribed in paragraph (jp) of this section. <c Permittee ernature fo airborne ronccntrntlont o/ athetlot fibers--11) Ihtmr llme*wel0ited averape conecutraHon. No employee may be exposed to on S-hour time-elhted oversee airborne concentration of oabeetoe Abets In excess of 0.5 fiber per cubic centimeter (or 500.000 Alters per cubic metert of alr.oa determined on the basis of a 40-hour norfc neck and by the method prescribed In paragraph 'C> of this section. 2* Ceillnit concentration. No employee may be exposed to airborne concentra tion* of axbentos Abcrs In execn of 5 fiber* per cuble centimeter 'or 5 million fiber* per ruble mcteri of air. a* deter mined over s period up to 15 minutes, by the method prescribed In parssreph fe> <3< of this secUon. CRMC-Christensen-Micro-000102 I Monitoring Requirements Current Proposal (e) Method of measurement. AH determinations of airborne concentra tions of asbestos fibers shall be made by the membrane filter method at 400-450 x (mag nification) (4 millimeter objective) with phase contrast illumination. (31 Method of measurement. Alt de terminations of airborne concentrations of asbestos fibers shall be mode by the ' membrane filter method at 400-tr.o x (maimIAcatton> <4 millimeter objective! with phase contrast Illumination. (f) Monitoring. (1) Initial determinations. Within 6 months of the publication of this section, every employer shall cause every place of employ ment where asbestos fibers are released to be monitored in such a way as to determine whether every employee's exposure to asbestos fibers is below the limits prescribed in paragraph (b) of this section. If the limits are exceeded, the employer shall immediately undertake a compliance pro gram in accordance with paragraph (c) of this section. (3) Panenol monitoring. (I) Samples shall be collected from within the breathing zone of the employees, on membrane filters of 0.8 micrometer poros ity mounted in an open-face filter holder. Samples shall be taken for the determina tion of the 8-hour time-weighted average airborne concentrations and of the ceiling concentrations of asbestos fibers. (II) Sampling frequency and patterns. After the Initial determinations required by sub ' paragraph (1) of this paragraph, samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees. In no case shall the sampling be done at Intervals greater then 6 months for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph (b) of this section. ____ *e* Monitoring. The piiiyow of nil monitoring required by this paragraph Is la measure accurately the airborne conrenlratlona of asbestos fibers In a work place to which employees would be ex posed If Uiey worked In the area without the use of personal protective equipment, such aa respirators. Monitoring shall be performed In a manner reasonably cal culated to satisfy this purpose. It mar not be necessary to monitor every em ployee exposed to airborne concentra tions of asbestos fibers In order to satisfy tle purposes of this paraeraph. For in stance. the employee, or his working lo cation*. likely to be exposed to the high est airborne concentration of asbestos libers bi a work area may be termed a representative of all the employees In the area. An employee In one shlft mnv be deemed a representative of all einployeca In other shifts who, because thev perform the same operation or are sta tionery In the same area, or for other rclevant reasons, may reasonably be considered to have Utc same level of cxiwMire ns the represenInlive employee. However, the results of a monitoring of a representative employee shall be deemed to apply, end to Indicate the exposure level of. all employees represented. (1) Initial Every employer shall eauie very place of employment where asbes tos fibers may be released to be monitored In such a manner an to determine wheth er employees are exposed to concentra tions of asbestos fibers In excess of either of the two limits prescribed In paragraph (e> of this section. If either limit Is ex ceeded, the employer shall Immediately undertake a compliance program In ac cordance with paragraph (!) of this section. CRMC-Christensen-Micro-000103 Monitoring Reguiremenjts (continued) Current (3) Environmental monitoring. (i) Sample'' ahnll be collected front areas of a work environment which are rep resentative of the airborne concentra tions of asbestos fibers which may reach the breathing zone of employees. Samples ' shall be collected on a membrane filter of 0.8 micrometer porosity mounted in on open-face filter holder. Samples shall be taken for the determination of the 8-hour time-weighted average airborne concen trations and of the ceiling concentrations of asbestos fibers. (ii) Sampling frequency and pattern*. After the initial determinations required by sub paragraph (1) of this paragraph, samples shall be of such frequency and pattern v as to represent with reasonable accuracy the levels of exposure of the employees. In no case shall sampling be at intervals greater than 6 months for employees whose exposures to asbestos may reason ably be foreseen to exceed the exposure limits prescribed in paragraph (b) of this section. Proposal (3t frequency. (I) If monitoring shows that an employee's exposure Is above either limit prescribed In paragraph <ei of this section, the monitoring shall be repeated every month, except as other* wise provided In paragraph (e)(2)(H) of this section. (ID If monitoring shows that an em ployee's exposure Is below both limits prescribed In paragraph (c of this sec tion. the monitoring shall be repeated every three months, except as otherwise provided In paragraph (cW2>< or <e> ' (2) (III), or (e)(2> (tv) of this section. (III) If two consecutive monitorings made at least S days, but not more than 3 months apart, show that an em ployee's exposure Is. below both limits prescribed In paragraph (c> of this sec tion. monitoring need not be repealed, except as otherwise provided In para graph (e)(2) (Iv) of tills section. (Iv) Whenever an employer has reason to believe that an employee's level of exposure has changed because of a change In production, process, controls, or other relevant fnetors. the employee shall be monitored u soon as practicable, and thereafter paragraphs <e> (2) (1). (e) (2KII), or (e)(2)(III) shall spply. CRMC-Christensen-Micro-000104 In addition to the changes which can be contrasted above/ the October 9, 1975 OSHA proposal contains appendices with the ollowing clarifications: Appendix B -- Substance Technical Guidelines Proposal i*. unNrr<Miii an* trumncMCNT mmwimmkn <t. (!<pmI ' Measurement* taken Iw the purpose of < ' Irrmlltlng employee esposnre are tnt taken In a teihlan tilth (hat Hit arnica hanr aapnanrt mar M determined from a alntla sample or two (31 4-hmir sample*. Shori Urn* Interval samples (up I* 34 ntintiifsl mar a)** ha unt to determine the averafe espostirt knl If a minimum ( fit* (SI ' imiaanrrmciiia art taken in random maimer am the g-hour work shift. Random asm- ptlng meant that anr portion of the work ahlft Hat the name rhante ol helm; aampirti a* anr other. The arithmetic avernijo o( alt mir.li random namplee takrn on one Ii) work ' ahlft la an eallmat* of an employees areracr Irtel of etpotiir* for that wrorkahlit. Air sample* ahmitd ho taken In the employer'* breathing none (air that would ml nearly rrprraeiit Umt Inhaled by the employer). The eonrrnlrallon of duet In the air in whlrh a worker la expnned will vary. dr|wmlIng iipuu the nature of the |ieralloii and upon Ilie type of work performed hy the operator and the position of the o|ieralor relative to the aourre of the duet. The amount of duat Inhaled hy a worker ran vary daily, seasonally, and with the weather In oiyier to obtain representative sample* oC worker*' t*|M*tiic*. It I* neeessary to col lect, sample* under varying condition* of weather, on dliterent day*, and at different time* during a ahlft. TIM pareenthga of working lima spent on different task* will affect the concentration of duat the worker inhalec elnce the dir t feront task* ucually mult In ttpoattra to ` different concentration*. The percentage ean bo determined from work tchedule* and by . observation of work routines. The concentration of ony *lr contaminant . resulting from an industrial operation alio vartao with tlm*. Thtrefora, a longer sam pling tlma wilt better approalmate the actual averaga. , With tho following recommended sampling procedure, It la possible to eollaet samples at Um worker*' breathing rones for periods from 4 to hours, thus permitting the evalu ation of average esposurea for a half or full -hour shift--* desirable and recommended procedure. Furthermore, duet espostire* of a more normal work pattern reault from th* us* of personal ismplsrs. S. Aeeommenifrd meIhod Tho recommended sampling and evalu'a- tlen method Is described In a paper "U5PH9/ H!OS!t Membrsne Filter Method for Evslu- oUng Airborne Asbestos Fibers" by Nelson A. Lsldel. Stephen O. Bsyer and Ralph D. Zum- . mualde, US. Department of Health. Iducs- tlon, and Welfare. Public Health Service. Center for Disease Control. National; Insti tute for Oeeupstlonat Safety and Ifsalth, Cincinnati, Ohio <3301 (in press). A brlsf summary Is givsn below. Samples art collected by draaring air through a cellulose ester membrsne niter by means of a battery powered personal sam pling pump. Th* Alter, after collection of the sample. Is transformed from an opsone solid to a transparent, optteally homogenous gel. Tho Attars art sited and counted by phase- contrast microscopy at 404-4I0X magnifica tion. ' 7 CRMC-Christensen-Micro-000105 A comparison of the current and proposed OSHA asbestos regulations reveals: 1) The proposal lowers the TWA airborne fiber concentration from 2 f/cc (scheduled for July 1, 1976) to 0.5 f/cc. 2) The proposal lowers the permissible ceiling concentration from 10 f/cc to 5 f/cc. 3) The current regulations require that "samples shall be taken for the determination of the 8-hour time-weighted average airborne concentrations and of the ceiling concentrations of asbestos fibers. ' This is replaced in the proposed regulations by Appendix B which specifically recommends full shift sampling (or a minimum of 5 measurements over the 8-hour work shift) . 4) Appendix B in the proposal specifically references a NIOSH document for the recommended sampling and evaluation method. Specifically this paper is entitled, "USPHS/NIOSH Membrane Fiber Method for Evaluating Airborne Asbestos Fibersby Nelson A. Leidel, Stephen G. Bayer and Ralph 0. Zumwalde (in press) . Two drafts of this document, one dated 11/73 (and stamped SUBMITTED FOR PUBLICATION) and the other dated NOVEMBER 1975 (and stamped DRAFT) have been used for this discussion. CRMC-Christensen-Micro-000106 NIOSH Document Cited and Recommended in Appendix B of OSHA (1975) Proposal * ------- The NIOSH document prepared by Leidel. Bayer and Zumwalde contains detailed sections such as Apparatus, Reagents, Sampling and Calibration. The following sections. I Scope and II Summary of Method are from the November 1975 Draft of that document: USPHS/HIOSH MEMBRANE FILTER METHOD FOR EVALUATING AIRBORNE ASBESTOS FIBERS ' I SCOPE -t A. This method describes the equipment and procedures for collecting, mounting, sizing, and counting asbestos fibers on cellulose ester membrane filters in the evaluation of breathing zone samples of airborne asbestos fibers. The purpose of the method is to determine an employee's exposure to airborne asbestos fibers. The method is primarily a personal monitoring technique, but can be used for area monitoring. . B. The method has been successfully applied using 37 mm Millipore AA filters and small battery operated personal sampling pumps at a flow rate of 1.0 to 2.5 liters per minute (1pm) for time periods of a few minutes to 150 minutes at concentrations of 1 to 20 fibers (longer than 5 micrometers)/cubic centimeter. Large deviations from these conditions may result in samples with either too few or too many fibers, which will yield air concentration estimates of low.statistical precision and accuracy. C. This method considers only fibers with a length to v/idth ratio of 3 to 1 or greater and a length greater than 5 micrometers. II SUMMARY OF METHOD The sample is collected by drawing air through a membrane filter by means of a battery powered personal sampling pump. The filter is transformed from an opaque solid membrane to a transparent, optically homogeneous gel. The fibers are sized and counted by phase-contrast microscope at 400-450X magnification. 9 CRMC-Christensen-Micro-000107 Specific attention must be directed to paragraph I-B which states! "The method has been successfully applied... for time periods of a few minutes to 150 minutes at concentrations of 1 to 20 fibers (longer than 5 micrometers)/cubic centimeter. Large deviations from these conditions may result in samples witV'eitHer'tdb'few or too"many"IiB5rI7~wRrch''wIir"yIerd`"aif'concentration estiSates''of low Itatistlcil pric`:fSion"and'Tccuracy.r*(emphasisadded) ........ Incri3I5Ty7~tEe l$75"*OSHA proposal "on asbestos recommends a NIOSH document on measuring airborne asbestos fiber concentrations that specifically concludes there is low statistical precision and accuracy below airborne fiber concentrations of 1.0 fiber/cc. while proposing to monitor and measure fiber concentrations "accurately" at and below the proposed standard of 0.5 fiber/cc. It is obvious that OSHA was negligent in its responsioility to stay abreast of tne technology and scientific knowledge related to monitoring and measuring airborne asbestos fibers. Furthermore, it will be clearly documented later in this repoft that NIOSH has even overstated the precision (claiming it is better than is supported by any available data) of the entire monitoring and measuring procedure for airborne asbestos fibers in tne range where NIOSH claims it "has been successfully applied." by referencing inadequate and inappropriate studies. The following additional sections from the Leidel et al NIOSH document are pertinent to discussions in the following and later sections of this report. 10 CRMC-Christensen-Micro-000108 USPHS/NIOSH MEMBRANE FILTER METHOD (continued) X! PROCEDURE D. Achieving Comparable Results . 2. Size only fibers with a length to width ratio greater than or equal to 3:1. 2. Count only fibers greater than 5 micrometers In length. (Be as accurate as possible in accepting or rejecting fibers near this length). Measure curved, fibers along the curve to estimate the total length. . 3. Count as many fields as necessary to yield a total count of at least 100 fibers. Exceptions: a) count as least 20 fields even If you count more than 100 fibers, and b) stop at 100 fields even If you haven't reached 100 fibers. 4. Select the field of view without looking through the microscope's eyepieces to eliminate unconsciously selecting "heavy" or "light" areas. ~ 5. The fields are selected alongthe entire length of a radial # line running between the outside perimeter and the tip of the ' wedge. .' 6. When an agglomerate (mass of material) covers a significant portion of the field of view (approx. 1/6 or greater) reject the field and select another. (Do not include it in the number of fields counted.) However, report the fact as it may have meaning to sampling or medical personnel. 7. Bundles of fibers are counted as one fiber unless both ends of a fiber crossing another can be clearly resolved. 8. For fibers that cross either one or two sides of the counting field, the following procedure is used to obtain a representative count. First, arbitrarily select: a) the left and bottom sides, and b) the upper and lower left corners and vertical direction as "decision aids." Then count any fiber greater than 5 micrometers In length, but only if the fiber: . s. lies entirely within the counting area or, b. crosses the left or bottom sides, or e. crosses the upper or lower left corners, or d. crosses both the top and bottom sides. Reject and do not count all other fibers. Refer to Figures 4 through 9. U CRMC-Christensen-Micro-000109 XIII PRECISIOfl AMD ACCURACY A. An accuracy and precision study of the membrane filter counting procedure for asbestos has been conducted by Conway and Hol1and(12). They conducted an intralaboratory study involving six counters. Three of the counters were experienced while the other three had only a short familiarization with the rules for fiber counting. The conclusions of the study included: 1. The precision of the procedure for filters not containing an abundance of fine fibers can be estimated by a standard deviation of 16.2%. This value Includes variation among, counters and observed interaction effects. ' 2. The accuracy of the procedure for similar filters may be estimated for a 100-fiber count by a standard deviation of 21.4%. This assumes that the contribution of the overall .variance from the nonuniform fiber distribution is additive. 3. The fiber concentration varies significantly between angular sectors on a given filter. Where approximately 100 fibers are counted, the standard deviation of the fiber count distribution for the whole fitter appears, to be represented by 1.6 (np, rather than (np which is a property of the Poisson distribution, where (n) is the total number of fibers counted. 4. A high percentage of very fine- fibers on the filter can significantly affect the standard deviation and confidence limits for counts by different counters.. After combining variations in fiber concentrations over the entire filter with those for different counters it was concluded: a. For filters with a low concentration of the fibers, the standard deviation is estimated at 21% and the 95% confidence Interval is + 43%. b. For filters with a high concentration of fine fibers, the standard deviation is estimated at 25% and the 95% confidence Interval is + 50%. . B. Lynch, Kronoveter, and Lei del (13) have also reported on the precision of the method. Their intralaboratory study utilized the data vroir. a large number of dust counts made by different methods by experienced counters over a period of years in an epidemiologic study of the asbestos products industry. They concluded that the standard deviation of counts of fibers longer than 5 micrometers on membrane filters could be estimated from the relation cr = (n)0.591. Thus for counts of about 100 fibers, the standard deviation could be estimated at about 15.2% and the 95% confidence limits at +. 30.4%. These values are lower than the precision values reported by Conv/ay and Holland{12). CRMC-Christensen-Micro-000110 C. Systematic Inaccuracies can be Introduced by the Improper choice of microscope or by not checking a particular Individual's counts in relation to other counters. Leldel and 6usch(14) found that one Particular microscope tested yielded counts that were approximately 45% igher on the average than counts from four other microscopes in a phase contrast microscope evaluation. Also, one particular counter produced counts that were 27% higher on the average. Leldel and, Busch(14) concluded that a significant difference in asbestos fiber counts can result when the same filters are counted on different makes and models of microscopes. Significant differences can also exist between trained counters. They concluded that any laboratory counting asbestos on membrane filters should be part of an interlaboratory collaborative quality program. This participation will Insure that: 1) equipment Is properly adjusted and calibrated; 2) counters are properly trained and their counting efficiency Is continually evaluated; and 3) comparable results are obtained from each laboratory. This type of quality control program is conducted by NIOSH as the Proficiency Analytical Testing (PAT) program. The PAT program is used by the AIHA as part of their Laboratory Accreditation Program which is partially funded by NiDSH. 13 CRMC-Christensen-Micro-000111 A Basic Problem in Counting -- Counter BjLas Referring to Section XI-D, Achieving Comparable Results# reproduced from the NIOSH document in the last section# it would appear on first reading that there is little room for differences between counters as to what is a "countable fiber" and the number of "countable fibers" within a single microscope field of view. In fact differences in interpretation between counters in this regard-is a major problem and can# by itself# account for the variation ascribed to the entire monitoring and measuring procedure in Section XIII# PRECISION AND ACCURACY (also reproduced in the last section), of that same NIOSH document. The gross misrepresentation of the precision and accuracy of the entire asbestos monitoring procedure will be dealt with in more detail in a later section of this report, first, let us review the basic problem of counter bias. Differences between counters have been investigated in a variety of studies under different circumstances. However, the best illustration of counter bias is given by Ortiz et al (1975). Table IV from that paper is reproduced below: . TABLE IV " Aihsln Cminl Data Four Counter) Koch Counting the Same Twenty-Five Fields (Fibers/mm* Filter Area) Counters Sample A Sample li 1 2 3 4 Avg.: Std. Deviation (tr)` Coef. o( Variation: 1034 1966 162 2276 1000 1662 1414 27J9 1071 2216 236 403 0.22 0.11 14 CRMC-Christensen-Micro-000112 The our counters each viewed the same 25 microscope fields from sample A (a filter sample) and the same 25 microscope fields from sample B. In other words, a field of view was selected and. without changing the field of view, each of the four counters independently interpreted and counted the asbestos fibers in the field. Using the 0.0029 mm2 from Table V of that paper. 1000 fibers/mm2 corresponds to an average of 2.9 fibers/field and 73 total fibers; 2000 fibers/mm2 corresponds to an average of 5.8 fibers/field and 146 total fibers, etc. Referring to sample A results in Table IV above, counters 1,2,3 and 4 counted 75, 62. 73 and 103 total fibers, respectively, while looking at the same 25 fields! Sample B results are similar. The sample coefficients of variation (standard deviation divided by the mean) for observer bias alone were 0.22 (22%) and 0.18 (18%) for samples A and B respectively from Table IV. Referring to Section XIII, PRECISION and ACCURACY, from Leidel et al, coefficients of variation for the entire asbestos counting process are estimated at .25 (25%) and less. Paragraph B of Section XIII, reproduced in the last section of this report, referenced a report by Lynch, Kronoveter and Leidel (unpublished NIOSH report) that estimated the coefficient of variation at about .152 (15.2%) for counts of about 100 fibers. The information contained in the NIOSH-supported study by Ortiz et al (1975) is clearly inconsistent with the estimate taken from the unpublished NIOSH report by Lynch et al. While it must be emphasized that two filters and four counters can only illustrate, not prove, these results do clearly demonstrate the "state of the art. Also, the filters used in the Ortiz et al (1975) study were prepared in liquid (toluene) suspensions, not airborne; therefore other contaminants that frequently are present in the workplace are missing. It is reasonable to speculate that "dirtier filters, such as filters with other airborne contaminants, would only increase difficulties in reader interpretation and possible bias. When two or more people view identical information, but report different findings or interpretations, it is obvious that the report of a single individual must be viewed in the framework of all possible viewers, not as if a 'unique" report (which would be the case if everyone would report the same interpretation) had oeen given. The work described by Ortiz et al (1975) was "supported" by the National Institute for Occupational Safety and Health. These authors developed techniques to filter liquid suspensions to provide chrysotile asbestos standards for a laboratory proficiency testing program (Proficiency Analytical Testing -- PAT) initiated by NIOSH. Counter Bias Plus Microscope Intra-Filter Sample Variation The data presented in the last section were collected from counters interpreting the same microscopic fields of view. Therefore the only variable present was counter bias. However if we add a second variable factor, that is. permit each of the counters to randomly select their fields of view, as is the case in actual field performance, the variation in estimated fiber concentration between counters will be greater than when observer CRMC-Christensen-Micro-000113 bias is the only variable factor present. It must be kept in mind that we are still discussing only sources of error that arise after the filter sample has been collected and a segment of the filter has been mounted on a microscope slide. Table I from Ortiz et al (1975) is presented below: TABLE I Aibcitot Count Data Serin 149*132 (Flbcn/mm* Filler area) Counter Sample Identification Code 15-A 15-B 15-C 15-D 1 706 2 16) ) 1000 4 470 Average: 760 cf- 227 Cod. Var.: 0.30 Ar. Coef. Var.: 0.36 961 1255 1255 1216 1627 2216 627 ` 940 lilt 1373 426 598 0.38 0.44 2294 1882 3039 1353 2142 711 0.33 Table I illustrates typical count data obtained on four separate filter samples (15-A, 15-B, 15-C, 15-D) containing four different asbestos fiber concentrations prepared using the authors' technique to filter liquid suspensions. In this case, each counter was required to randomly select their fields for microscopic review. The differences in asbestos fiber counts between counters are substantially greater than the differences reported in Table IV. For example, the sample coefficients of variation range from .30 (30%) to .44 (44%) in Table I, in contrast to .18 (18%) and .22 (22%) in Table IV. It must be. emphasized that the small number of samples used here to illustrate counting .problems cannot be interpreted as proof that the coefficient of variation should be one value rather than another. In fact, it is questionable that a single coefficient of variation is appropriate in all situations. To conclude this section, we quote again from Ortiz et al (1975): "Extensive fiber count data from the quality control program outlined previously has demonstrated that under the ideal conditions of several experienced counters counting the iame wedges, using the same optics, variations as large as + 50% are observed, with typical variation on the order of + 30(emphasis added) ` Interlaboratocy Counting -- HIOSB PAT Program The paper of Ortiz et al (1975) documented the technique used to produce "identical and predictable sample standards for use in the NIOSH PAT (Proficiency Analytical Testing) program. We have seen in the preceding comments that observers counting the same 16 CRMC-Christensen-Micro-000114 fields (oc same filters) from filters produced for that program give dramatically different results. * The 37th'round of the NIOSH PAT program has been completed and the summary results have been returned to the participating laboratories. Four asbestos filter samples, prepared using the technique described by Ortiz et al (1975) , are sent, along with samples or other contaminants such as lead and silica, to each participating laboratory for each round. (Each laboratory analyzes only the contaminants of interest to its program.) For each round, NIOSH identifies the filters as #1, #2, #3, and #4. The #1 filters for all laboratories for a given round are prepared from a single asbestos fiber solution to be as "identical" as possible. The #2 filters for all laboratories for a given round are prepared from another asbestos fiber solution to be as "identical" as possible, but to give 'predictable" fiber concentrations different from the #1 filters. The process is repeated for |3 and #4. Each participating laboratory returns a single evaluation for each filter, even if several evaluations are done on each filter. Beginning with PAT Round 36, summary results for each filter sec (i.e. the set of all #1 filters, the set of all 42 filters, ecc.) have been prepared and circulated. Prior to Round 36, the four filter sets for each round were not summarized separately. The asbestos summaries from Rounds 36 and 37 are given in the enclosed table. NIOSH PAT Rounds 36 & 37 Asbestos Fibers/mm^ PAT Filter No. of Arithmetic Standard Round NO. Labs* Mean Deviation 36 #1 76 36 #2 76 36 #3 76 36 #4 76 37 *1 74 37 #2 74 37 #3 74 37 #4 74 1020 1932 1084 2718 2760 1194 2826 1434 562 1154 558 1276 1278 540 1230 724 After "outliers" have been removed. Coef. of Variation .55 .60 .51 .47 .46 .45 .44 .50 17 CRMC-Christensen-Micro-000115 i Eighty-four (84) laboratories submitted the readings for all four filters in Round 36, but 8 (9.5%) were not included by NZOSH because they were judged "outliers'' (essentially, this happens when some or all of a laboratory's readings are too high or too low when compared with the other laboraties; formally, NIOSH is looking at both intra- and inter-laboratory variation) by the present NIOSH criteria. In Round 37, 4 of 78 (5.1%) laboratory results were judged too extreme (i.e. "outliers") , giving the 74 in the summary table. Extreme readings could be caused by a 'bad" filter or the counter (or counters) in a participating laboratory. The documentation of the filter preparation technique by Ortiz et al (1975) suggests that laboratories, not filters, are "outliers." Would these laboratories'*B5'"recognized as outliers", and the data therefrom discarded, under actual OSHA field monitoring conditions? The results from the PAT program tell us that even after removinq the 5 to 10 percent most "extreme" laboratories, coefficients of variation as high as .60 160%) were observed. The fiber counts are reported in fibers/mm2 in the PAT program. This is logical because the receiving laboratory can only report the fiber density on the filters. Consider the following hypothetical example, using a lognormal distribution for laboratory counts, to relate fiber/mm2 to airborne fiber/cc: If an 8-hour sample is taken at 2 liters/minute in an environment with an airborne asbestos fiber concentration of 1 fiber/cc, the average fiber concentration on the filter is 1123 fibers/mm2. Using a coefficient of variation of 0.60 (60%), the lognormal approximation gives over 6 percent of the laboratories reporting fibers/cc greater than 2. The lognormal approximation was used because the NIOSH PAT communications have reported that it is a reasonable approximation after outliers are removed. Essentially, the above example means that under the ideal laboratory preparation conditions of the PAT program, NIOSH Is ITnding interlaboratory differences in counting to such an extent that if an 8-hour sample at a 1 fiber/cc airborne fiber concentration were to be taken, more than 6 percent of the g_ood (i.e. not outlier) laboratories would report an estimated fiber/cc greater than 2. This is ignoring 5 to 10 percent of the laboratories giving "extreme" results. Thus, considering all laboratories in the PAT program, perhaps as high as 16 percent would report greater than 2 fibers/ccl This is a 100-percent variation on the high side! Considering that the filters in the proqram are produced under controlled conditions, it is apparent that the difficulties in monitoring actual work conditions will result in even greater differences between laboratories. Also, considering the fact that some laboratories may report the average of more than one hygienist (at least one laboratory, Johns-Manville. does), the very real possibility exists that differences between all CRMC-Christensen-Micro-000116 Interlaboratory Comparisons of Counts from factory Samples Beckett and Attfield (1974) reported the results of a small scale interlaboratory counting study. Tables 2(a) and (b) from that study are reproduced below. All slides reported below were actual airborne concentrations of asbestos fibers taken from a factory environment, except those originating at laboratory G, which were UICC chrysotile. Ta>u 2 fa). Results or slide exchange between exmaicnced laboratories: retorted results tor chrvsotiie asbestos Slide identification Originating Density laboratory F F G* H H K. Light Medium Denso Light Medium Dense Light Medium Dense Light Medium Dense Light Medium Dense Light Medium Dense 1 3-1/ 31/ UO/ 2-4/ 8 9/ 45-0/ Reported counts for each laboratory (10* flbres/cm1) FCH K 23 12 3 I 2 3 1 S 2 4/ 31/ siwS a 2-2/ 10-7/ 420/ . 1*2/ 1-7/ 10-7/ 142/ 720/ 52-4/ # . 314/ 49/ 340/ 244/ 390/ 1430/ 3-9/ 4-25/ 443/ 1-9/ 204/ 441/ 2-7/ 31/ 146/ 1-82/ 903/ 33-3/ 1-38/ 1-34/ 83-3/ n.a. n.a. ILt. 4-1# 132# 47-0# 104# 197-0# M* * 2-29/ 13-9/ 390/ Table 2 (b). Results or slide exciiamv between r\t-r minced labor uontrs: rei-orted risults tOR ASroSIIE asristos . Slide identification Originating laboratory Density Reported counts for ench laboratory (103 (Ibrcs/cm'J U* J K 1 2 3 1 23 1 23 Light 108/ 137/ J Medium 4 4/ 273/ Dense 4J7 / 4-JJ/ Light 1 Medium Dense 3 19/ 4 30/ 893/ Light * 1*4/ K Medium 41/ l)cnsc 93 0/ 104/ 3 08/ 3-76/ # 3-78/ 429/ 7 99/ 4 35/ 8 1/ 9-6/ 2-34 / 2 03/ 4- 10-1/ 10 3/ 9 34/ *4 4/ Ar.r: 1. Initial count. 2. Count b/ rc;i,'i.-nl labaraiory. J. Repeat count hy the oitgiiinllng laboratory, / Grid method of counting. /Tull field method, n.a. No count available. 'UICC. 20 CRMC-Christensen-Micro-000117 hygienists in all the laboratories are greater than the available interlaboratory differences. I a.TM......... 19 CRMC-Christensen-Micro-000118 The tables should be read as follows: All fibec counts in a single row have been made from the same microscope slide. The numbers at the top of the columns indicate the first, second or third reading from a slide. The f and g represent the full field of view and grid methods of counting, respectively. Consider the first row H (Originating Laboratory) Medium (Density) in Table 2(a). The entry 2.06g (under H,l) indicates an initial reading (for a slide) of 2.06 X 103 2,060 fibres/cm2 (or 20.6 fibres/mm2) using the grid (g) method of counting. That slide was sent to laboratory G (under G,2) and the entry is 4.25g givinq 4,250 fibres/cm2 (42.5 fibres/mm2) using the grid method of counting. The slide was then returned to laboratory H and the final (3rd) count is in column H,3 or 1.54g (i.e. 1,540 fibres/cm2 or 15.4 fibres/mm2 ). A review of the tables will reveal that differences between two laboratories reading the same slide frequently were more than 50 percent of the original reading. The limited data obtained and reported on the above tables were analyzed by the authors using an additive linear (using logarithms) model. The results of that analysis are difficult to describe without a detailed description of the analysis technique and the results naturally are dependent on the assumptions. (For example, a constant coefficient of variation of the raw count, before taking logarithms, is a questionaole assumption we will discuss later.) The data are presented here to illustrate that the limited information currently available in the literature illustrates the problem of the counting portion of the monitoring process. One additional conclusion of the authors concerns counting with the grid method and the full field of view method. The data suggested that counting using the full field of view results in lower counts than the grid method. While this question is still under investigation, theoretical evidence will be given later to support that suggestion. NIOSH Misrepresentation of the Precision of the Entire Asbestos Monitoring Process *~ ~ " Much of the discussion thus far in this report has dealt with data related in some way to NIOSH. This is not surprising considering that NIOSH (1) recommends procedures. (2) trains personnel and (3) maintains the analysis laboratory for OSHA, for monitoring airborne asbestos fibers. Some of the visible NIOSH effort, such as the PAT program, is highly commendable. However, some of the NIOSH reports are, at best, inadequate. Furthermore NIOSH is responsible for generating considerable confusion and misunderstanding concerning the precision, true or empirical, of the entire asbestos monitoring process. in that regard, the following data have been taken from Table 2 of Leidel and Busch (1975) : 21 CRMC-Christensen-Micro-000119 Table 2. Coefficients of Variation for Some Samplinq/Analytical Procedures. i"5RiLn9/Analytical C.V. Asbestos (Sampling/counting) 0.22 The meaning of the above entry, 0.22, for the asbestos sampling/counting coefficient of variation in the context of the Leidel and Busch (1975) report can oest be illustrated by an example: Suppose a qualified industrial hygienist were to collect a full-period (8-hour) sample in a workplace with an actual airborne asbestos fiber concentration of 1 fiber/cc. According to the Leidel and Busch (1975) report, the standard deviation of the entire asbestos monitorinq procedure is 0.22 X 1* 0.22 fiber/cc. Furthermore, the report contends that the chance of an estimate of the fibers/cc airborne concentration above 1.44 fibers/cc is approximately 0.025 (2.5%) and the chance that the estimate will be greater than 2.0 fibers/cc is essentially zero (less than 0.0001 by their model). The question must be asked: How could the NIOSH authors arrive at such an unsupportable conclusion which is so clearly contradicted by even other NIOSH publications? Recall the hypothetical example derived from data from the controlled conditions of the NIOSH PAT program: an airborne asbestos fiber concentration of 1 fiber/cc would result in 6 to 16 percent of the laboratories giving estimates greater than 2.0 fibers/cc. NIOSH has reported (given in an earler section of this report) in its PAT program, coefficients of variation in excess of 50 percent (0.50) when comparing the counting results from different laboratories from the solution-prepared samples. Those coefficients of variation were obtained after 5 to 10 percent of the extreme ("outliers") laboratories were removed. As already reported here, Ortiz, et al (1975), a NIOSH-supported research endeavor, reported a coefficient of variation for four counters of approximately 20 percent (C.V. = 0.20) for interpretating and counting identical fields of view on the same microscopei " It is truly inconceivable that Leidel and Busch (1975) could have arrived at such a conclusion. An examination of the "support1 that Leidel and Busch give for their coefficient of variation of 0.22 reveals that they referenced: Leidel, N.A., Bayer, S.G., and R.D. Zumwalde, "USPHS/NIOSH Membrane Filter Method for Evaluating Airborne Asbestos Fibers." USPHS. NIOSH Tr-84 (1973). 22 CRMC-Christensen-Micro-000120 This reference is an earlier version (that has remained essentially unchanged) of the NIOSH document recommended in the October 1975 OSHA asbestos proposal. Tracing the "support'' back further through the Leidel, Bayer and Zumwalde report, two references ace given: (1) Conway and Holland (1973) and (2) Lynch, Kronoveter and Leidel (NIOSH unpublished report TX-83). Examination of these two references leads to even more astonishing facts. The Conway and Holland report was on a limited intra-laboratory counting study utilizing six counters (3 experience#, 3 inexperienced) and only three filters! To even suggest that the variability reported by Conway and Holland (from counters counting from the same filter) is the same as the variability for the entire monitoring process is indicative of a complete lack of understanding of the entire asbestos monitoring problem in the workplace. The Lynch, Kronoveter and Leidel study utilized a large number of asbestos fiber counts from one laboratory. However, they were looking at variation within each filter and relating it to the mean fiber concentratlon~on the same filter. The fact that they found less variability than Conway and Holland reported is not surprising, since they were studying only part of the factors considered by Conway and Holland. The Lynch, Kronoveter and Leidel study is even more inappropriate than the Conway and Holland study for expressing the precision of the asbestos monitoring problem under field conditions NIOSH has an obligation to publish competent scientific reports. The complete lack of scientific rigor just discussed is inexcusable and grossly misleading. The most recent draft of the Leidel, Bayer and Zumwalde report (dated November, 1975) continues to reference the two reports by Conway and Holland, and Lynch, Knonoveter and Leidel. However, it is now noted that microscopes and counters can contribute to the variation, and a third reference by Leidel and Busch is given. Incredibly, it is concluded that participation in the NIOSH PAT program will essentially remove this source of variation. It is obvious that the real scope of the problem was still not clearly understood by the authors in November 1975. Variation of the Entire Monitoring Process in the Workplace It has already been noted that the precision of the entire sampl'ing/analytic airborne asbestos monitoring process can only be determined by evaluating differences between simultaneous replications from the initial preparation of the airborne sampling apparatus (i.e. filter preparation, pump calibration, etc.) on through to the preparation of the microscope slide, interpreting and counting fibers, and calculating the estimate. In the previous section of this report, we illustrated the inapplicable 23 CRMC-Christensen-Micro-000121 and unrealistic restrictions posed by considerinq only intralaboratory differences between counters once the sampled filter has reached the laboratory and has been mounted on a microscope slide, or intra-filter variation from a single reading of a slide. The problems posed by sampling in the workplace must also be considered. Rajhans and Bragg (1975) reported on a study under both controlled laboratory conditions and field (actual factory) conditions. Series III of the study by Rajhans and Bragg consisted of data from a total of five work stations which were sampled from four plants. Seven simultaneous paired samples were taken with the sampling devices approximately 6 inches apart over an 8-hour shift in Plant A, an asbestos-cement pipe plant. Five samples were taken at each of two locations over a period of 75 minutes in Plant B, a brake-lining plant. Seven sets of paired samples were taken at the breathing zone level over a period of 105 minutes in Plant C, a brake-lining and disc pads plant. Four sets of paired samples were taken over 60 minutes in Plant D, which manufactures brake linings. The collection of simultaneous infield samples is essential to evaluate the empirical precision of the total monitoring process. Unfortunately, the infield study of Rajhans and Bragg (1975) was conducted utilizing different pump flow rates, time limits, etc., than those followed under recommended OSHA/NIOSH procedures in the U.S. Therefore, the results of this study are of limited use in evaluating the empirical precision of the entire monitoring process as performed in the U.S. For example, all tests in Series III were 15-minute samples at pump flow rates of 3 liters/minute. Three liters /minute exceeds the upper pump flow of 2 and 2.5 liters/minute of the British and NIOSH recommendations, respectively. All samples in Series III were taken and counted by the same operator, thus removing the variable factor of interoperator error from the results. The range of fibers/ml (i.e. fibers/cc) counted in Series III is from less than 1 to 4, as can be seen from Figure 5 reproduced below: r Flgwra 5 - Alt concentration volition with flint (Varying icaltt). 24 CRMC-Christensen-Micro-000122 Keeping in mind that the results of the study by Rajhans and Bragg were collected under conditions unique to that study, nevertheless, their conclusion that 'it would seem unlikely that the present technique would result in a standard deviation less than 0.5 f/ml" is important to note. Their conclusion that the standard method is sufficiently precise for industrial measurements," is difficult to challenge if for no other reason than the lack of a practical alternative method. In addition, their conclusion must also be qualified in the light of the data of that study, as the authors have done. Although it may be difficult to challenge the conclusion that "the standard method is sufficiently precise for industrial measurements," we, on the other hand, wish to say there are no data available to support a conclusion that the stan5ari?~metho(? is"sufficiently precise for- regulatory purposes (compliance enforcementf, particularly at airborne-concentrations below 2 fibers/cc. For example, using the authors' lower bound of 0.5 fiber/ml for the standard deviation, elementary"Rnowledge of empirical and theoretical distributions associated with airborne asbestos fiber monitoring will show that sample fiber counts in excess of 2 fibers/ml are to be commonly expected even if the overall average is in the range of 0.5 fiber/ml. (E.g. a lognormal distribution with mean and standard deviation of 0.5 and 0.5, respectively, has about 5 percent of the /distribution beyond 2.0.) A NEW STUDY ON THE EMPIRICAL PRECISION OF THE ENTIRE MONITORING ~ ~ PROCESS -- ...... .. " Introduction The lack of available information on the entire workplace monitoring process led to the Johns-Manville decision to carry out a study under field conditions. Johns-Manville has five Industrial Hygiene Laboratories (4 in the CRMC-Christensen-Micro-000123 U.S. and 1 in Canada), all staffed with trained and experienced asbestos-counting hygienists. Between December 1975 and March 1976/ samples were collected using static samplinq under various factory conditions and analyzed. Static sampling was used for several reasons. In the first place, it is impractical to attach several pumps and filters to the same employee. Also, to achieve the fiber counts in the desired ranges with and without other airborne contaminants, it was sometimes necessary to sample in areas where employees are not routinely working. In addition, sampling was done in areas void of locally erratic air currents. All of these constraining factors support the belief that personal sampling would have resulted in more, not less, variation. In other words, the simultaneous factory sampling in this study was conducted under somewhat "ideal" workplace conditions. Design Ten sample locations were selected to give a variety of airborne asbestos fiber concentrations and other contaminants. A variety of sampling times were also selected, with several consecutive sampling periods for some locations. The ten sample locations and the number of samples and sampling times are described in Table 1. Six simultaneous samples were taken at every sampling location for each sample time period. The filters were fixed in a generally circular pattern and separated by 4 to 6 inches. Pump calibrations (2 1/min) were performed before and after the tests (pump calibration was not done after sample number 1, but was performed on all subsequent samples). The filters were coded and one from each set of six simultaneous filters was sent to each laboratory (the sixth filter has been retained for possible further investigation). Each of the 15 participating hygienists prepared and counted a slide from the filter sent to his or her laboratory. They were asked to follow their usual procedure in the hope that the results would be typical of their routine counting standards. Representativeness of Participants in This Study How do the counters participating in this study compare with counters in other laboratories? The main laboratory of the five (laboratory C) participates in the NIOSH PAT program. The PAT filters received by laboratory C are cut into five segments, one segment going to each of the other four laboratories. The filter segments are mounted and counted at the receiving laboratories for an intracompany control program. (Only one reading for each filter can be returned to NIOSH for the PAT program.) Results from the 37th round in the PAT program were received during March 1976. Evaluation of the readers participating in this study (one reader, EJB, did not count), using the NIOSH criteria for rejecting outliers, revealed that none would be rejected. As a group, and individually, the participants tend to count above the PAT program average, but not so that they would be judged outliers (extreme CRMC-Christensen-Micro-000124 readings) using the NIOSH criteria. Thus it would appear that the participants in the study now reporting conform to the general class of those comprising the NIOSH PAT program. Results The asbestos fiber count from the ten sample locations described in Table 1 are given in Tables 2 through 11, respectively, in the attached appendix. For example, from Table 1, Sample No. 2 was taken from a location 4 feet from an extruder. Three consecutive sets of six filters were used. The first six filters ran for 91 minutes, the second set of six ran for 110 minutes and the third set of filters ran for 115 minutes. One filter from each set was labeled B and sent to the laboratory with reader TFA. Table 3 contains the count data for these three filters for reader TFA. Reading across the row: TFA counted a total of 98 fibers longer than 5 microns in 190 fields of view from the 91-minute filter sample; TFA counted a total of 104 fibers longer than 5 microns in 87 fields of view from the 110-minute filter sample, etc. The entry under F/ML after each filter's fields and fibers count is the estimated airborne fiber count for that reader and filter. For example, the 87 fields and 104 fibers longer than 5 microns for reader TFA from the 110-minute filter from Sample 2 (Table 3) gives an estimated fiber/ml of 104 X 855/ (110 X 2000 X 87 X .00297) * 1.56, where .00297 mm2 is the area of the counting field for the microscope used in the count. Blank adjustment was not made. All entries in the tables have been rounded to the first decimal. Where several consecutive sets of six filters were taxen at a sample location, the estimates of the airborne asbestos fiber concentrations were averaged, weighting each estimate by tne time of the sample. The entry in the column for TWAF/ML is the resulting time-weighted average. For reader TFA in Table 3, this calculation is illustrated by: 91 X 1.6 + 110 X 1.6 + 115 X 1.9 1.7 91 + 110 + 115 (The actual calculations were made with rounding done only at the final answer.) Continuing with the use of Table 3. Sample 2 as an example- three hygienists (readers) independently prepared and counted a segment from each filter A (i.e. readers EJB, LJG and WCBB). Two readers independently prepared and counted a segment from each filter B. etc. The combined use of Table 1 and Tables 2 through 11 will give the data for all readers and filters in this study. The data have not been "cleaned up to conform to exact counting 27 CRMC-Christensen-Micro-000125 rules. When a reader counted too few filters or fields, that information has been recorded and utilized. Examples of such counts are to be found in Table 4, Sample 3. Some samples that were taken under very clean (i.e. no other airhnrnfr rnntaminant in the vicinity) conditions resulted in low variation in the final estimates. Sample 1 (Table 2) ..is a good example. The estimates ol."airborne fibers/ml TiTeT fibers/cc) tanged- from 0.1 to 0.5. Other samples, taken under conditions wnere other airborne contaminants make fiber interpretation and counting more difficult (these conditions are perhaps the most representative of industrial settings) resulted in very large differences between readers. Sample 2, Table 3, is a good example. The estimates of fibers/ml (i.e. tibers/cc) ranged from 0.5 to 6.1. Sample 5, Table 6, estimates ranged from 1.0 f/ml to 4.4 f/ml. The selection of summary statistics for the data in Tables 1 through 11 is somewhat arbitrary. Formally, the estimates of airborne asbestos fiber concentrations could be viewed as an analysis of variance problem. Considering the filters and readers as "random" factors (effects in statistical jargon), we have an unbalanced one-way random (Model II or components of variance) effects model. Under these assumptions, the total sum f squares about the mean divided by one fewer than the total number of readers gives a conservative estimate of the variance (as a measure of precision) of the total monitoring procedure. This calculation has been used to give the standard deviations of the samples in Table 12 for the 10 samples described in Table 1. The individual sample arithmetic averages, coefficients of variation, medians, and low and high estimates are also given in Table 12. For example. Sample No. 2 gave an average estimate of 1.5 f/ml. The sample standard deviation, described earlier, is 1.5 f/ml. The ratio of the standard deviation divided by the average is 1.00 (100%), the sample coefficient of variation for Sample 2. The median count of 1.1 f/ml is lower than the average of 1.5 f/ml. This is a characteristic of data skewed to the higher values" and is often found with the measurement of airborne contaminants. This is one reason the lognormal is often used to approximate the empirical distributions. It can be seen from Table 12 that for every sample, the median is equal to or less than the average. Discussion and Conclusions -- J-M Study Although a number of individual estimates were in the 0.5 f/ml to 0.9 f/ml range, we did not achieve an overall average for any one sample in that range. (One sample, No. 6 did have a sample median in the 0.5 f/ml to 0.9 fl/ml range.) Nevertheless, the study clearly illustrates the conclusions we have been building toward throughout this report. The true accuracy and precision of the entire monitoring process alleged by NIOSH is clearly not supported by the data presented from this study. It has been shown that other NIOSH data also do 28 CRMC-Christensen-Micro-000126 1 not support the claimed accuracy and precision. It is obvious that to propose the use of a single coefficient of variation to describe the entire monitoring process in all environments is to ignore the facts. The variation of the entire monitoring process depends on many factors, among them and perhaps most importantly other airborne contaminants so commonly present in those factory settings being monitored. Although more data are needed to verify it, logic would dictate that "all other factors being equal," those uncontrollable variables in the entire monitoring process would cause the coefficient of variation to increase for smaller airborne asbestos fiber concentrations. This points out the fact that it becomes virtually impossible to monitor in the framework of compliance to a standard in the range below 2.0 f/ml. The basic data and conclusions from this study have been presented here. It is obvious that more detailed analyses and summaries can be given. The study will later be detailed and submitted to a refereed professional journal for publication. THEORY Introduction and Summary The following two sections develop theoretical aspects of the USPHS/NIOSH recommended method of counting that, to our knowledge, have not been presented previously. Theoretical knowledge of the separate components of the entire asbestos monitoring system is a prerequisite to an understanding of the system in its entirety. It is necessary to assume at least an elementary knowledge of calculus and probability in the two theoretical sections. As with the asbestos workplace monitoring study, these results will be rewritten for consideration for publication in a refereed professional journal. The first theory section shows that the recommended counting rule intrinsically will result in too many fibers being counted. The magnitude of the possible bias is large when compared with the variation attributed to the entire asbestos monitoring process by NIOSH. The second theory section also shows a bias in the estimation of the airborne asbestos fiber concentration. This bias, while small, also tends to estimate the f/cc too high. important result of this second theory section shows that only a _. manor measurable or noticeable improvement would be produced bv increasing~tme number of: microscope "fields and/or lYibe'rs"counted 29 CRMC-Christensen-Micro-000127 Theory: The Probability that a Fiber Is Counted/ Bias In the Counting Rule The purpose of this section is to prove that the probability that a fiber is counted increases with the length of the fiber. This in turn, results in a bias in the estimate of the average number of air borne asbestos fibers longer than 5 microns per milliliter of air. An understanding of the theoretical aspects of the entire monitoring process is essential far its use in a compliance, no-cotpliance framework. The USPHS/folOSH recamended method of counting, with a calibrated reticle (covering only part of the entire area visible in the microscope field of view) is: For fibers that cross either one or two sides of the counting field, the following procedure is used to obtain a representative count. First, arbitrarily select: a) the left and bottom sides, and b) the upper and lower left comers and vertical direction as "decision aids." Then count any fiber greater than 5 micrometers in length, but only if the fiber: a) lies entirely within the counting area or, b) crosses the left or bottom, sides, or c) crosses the upper or lower left corners, or d) crosses both the top and bottom sides. Reject and do not count all other fibers. Define: LS ** length of a side of the counting field (assumed a square) IF length of a fiber (assumed straight for this discussion) 3 angle the fiber makes with the bottom side of the counting field. 30 CRMC-Christensen-Micro-000128 Select a point of the viewing field/ say the lower right hand comer. While keeping the angle 6 constant, we wish to characterize the area described by the lower right hand comer for all possible locations of the view field. (A fiber of no length, i.e. point, will result in an area equal to (IS)2.) Several cases need to be considered: Case I: IF < IS (i.e. the fiber is shorter than a side of the viewing area.) The area described by a comer of the viewing field is given by, A(6) (LS)2 + sin(2 0)/4 Integrating over 8 (i.e. a fiber can fall on a filter in any position, all equally likely) tc/2 Case II: LS < IP < / 2 IS (i.e. the fiber is longer than a side of the viewing area but shorter than the diagonal) -1 If 0 < 6 < cos (LS/LF), the area described by a comer of the viewing field is given by: AX(e) * (IS)2+ (IS)(LF) sin(O)- (LS)2 tan(0)/2 If cos"1 (LS/LF) <B S sin"1_(LS/LFJ7~fhe area is-given by: Ax(0) (LS)2 + (IF)2sin(20)/4 If sin 1 (LS/LF) < Q~s~v/2~, the area is given by: Ax(0) (LS) (LF) Sin(0) + (LS) 2ctn(6)/2 As in Case I, integrating over 9 we have 31 CRMC-Christensen-Micro-000129 2A(0) dd - (2/) { (IS) (If) - (IS)2 + (LS) ((LF)2)1* + (LS)2sin 1(LS/LF) + (LP)2cos(2 cos"1 (LS/LF)) /8 " (LFJ2COs(2 sin"1 (LS/LF)) /8} Case HI: /ITIS <LF If 0 < 0 < */4, the area is given by AjO) ** (IS)2 + (IS(IF) sin(e) - (IS)2tan(0)/2. If ir/4 <1 w/2> the area is given by Aj (0) (IS) (IF) sin(0) + (IS)2 ctn(0)/2 Integrating, we obtain ir/2 C 2Aj(e) d 0 - (IS)2 + 2(IS) (IF) ) if 0 * Using the areas for the 3 cases, we can construct the following table: 32 CRMC-Christensen-Micro-000130 )2Area/ (LS far Selected Values of LF; IS = 50m IF Case No. Area/(LS) 5m I 1.002 10m I 1.006 20m I 1.025 30m I 1.057 40m I 1.102 50m I/II 1.159 60m II 1.266 70m IIAH 1.400 80m in 1.519 Essentially, the table tells us that a 40y fiber has about 10% more probability of being "counted" than a 5m fiber; an 80m fiber has about 50% more probability of being "counted" than a 5m fiber; etc. Unis, if the "true" concentration of fibers is 1.0 fibers/field and all the fibers are 5m long, the average counted would be 1.002 fibers/ field, On the other hand, if the "true" concentration of fibers is 1.0 fibers/field and all the fibers are 80m long, the average counted would be 1.519 fibers/field. The actual distribution of fiber lengths will determine how biased the sample estimate will be. Me have been discussing the USPHS/MIOSH reccnmended counting rule. The recanmendatiai of the joint AIHA-ACGIH Aerosol Hazards Evaluation Committee (1975) results in a greater bias, toe remedy for the bias is to only count a fiber if the mid-point of the fiber is in the viewing field (this would require the use of a wide angle ocular instead 33 CRMC-Christensen-Micro-000131 of a high point ocular). The magnitude of the possible bias can be a sizeable portion of the variation attributed to the entire asbestos monitoring by NIOSH. There is clearly a need for more theoretical and enpirical studies on the entire asbestos monitoring method. CRMC-Christensen-Micro-000132 Theory: The Stopping Kile, Expected Value, Variance and Coefficient of Variation Recalling the USPHS/NIOSH recommended method of counting: Count as many fields as necessary to yield a total count of at least 100 fibers. Ex ceptions: a) count at least 20 fields even if you count more than 100 fibers/ and b) stop at 100 fields even if you haven't reached 100 fibers. In other words: 1) count 20 fields, then 2) stop if you have counted at least 100 fibers, otherwise continue counting fields until you get either 10 or more fibers or 100 fields, whichever canes first. Define the following: T = total count of fibers > 5 microns N *= total number of fields counted (20 < N < 100) F T/tt, average fiber count in fibers > 5 microns/field A = area of counting field of a calibrated reticle ex pressed in nnt2/field V = MP, total volume of air drawn through the filter, in milliliters (ml), where M = number of minutes for the sample, and P * punp volume/friinute (in ml) C true average airborne count in fibers > 5 microns/inl On the average, the number of ml of air 'passing through' each segment of the filter equal to a field of view (A) is given by: M*P*A * V*A "515" 855 ' where 855 mm2 is the effective filter area for a 37mm diameter filter. CRMC-Christensen-Micro-000133 For example, a 240 minute (4 hr.) sarrple taken at a pimp setting of 2 liter/kLnute results in 1.404 ml. of air passing through an area equal to .0025 itm2, when A " .0025 mm2. Therefore, if the average airborne fiber count > 5 microns per ml of air is C, the average fiber count in fibers > 5 microns/field is (1.404)0. It follows that, if we count T fibers in N fields of view, our sample estimates of C, denoted by c, is (unadjusted for blanks): C - (T/N) / (V.A/855) " (855/V*A)*F - K*F, Assume for now that K is known without error (that assumption will be relaxed later). We can express the mean and variance of 5 as E (C) K*E(F) Var (c)K2 Var(F) and the coefficient of variation as Coef. Var. (c) =/var(c)/ E(C) (F)/e (F) *=tfVar (T/Tl) /E (T/U). Following this line of reasoning it is easy to fall into the trap of assuming that "counting" the fibers is the major source of error, unfortunately, that is not true, since the unconditional variation and expectation involve all those factors that influence T and N, beginning with the selection of a clean filter, on through to the "selection" of a counter (hygienist) and the actual "counting". Empirical evidence overwhelmingly shows that considera tion of the counting error, conditional on all of the other factors, is not the major source of variation. In fact, we will be able to illustrate how futile and misleading counting more fields and/or fibers can possibly be, by combining theoretical and onpirical results. The distribution of the fibers on the filter has been investigated in a variety of ways. Various caiparisons with the Poisson (so called 'uniform') distribution have been made by Lynch, Kronoveter and Leidel (unpublished NIOSH Tr-83), Conway and Holland (1973), Rajhans and Bragg (1975) and Harness (1973). Bartcsiewicz (1973) also looked at the distribution of the fibers on the filters. Generally, the intra-filter variation is greater than predicted by the Poisson distribution (that is the basis for the variation incorrectly attributed to the entire monitoring process by Leidel 35 CRMC-Christensen-Micro-000134 et al (1975)). Harness (1973), however, states: "the Ant parti cles on well-prepared membrane filters are deposited approximately according to the Poisson Law." It will be informative to evaluate the coefficient of variation assuming that the fibers have a Poisson distribution, with parameter X, where X is the mean number of fibers on an area of the filter equal to A. Therefore, letting X be the number of fibers in a randomly selected field: I P (X - K) - XK , K 0,1,... If the number of fields is fixed, say N* then E(F) - E (T/M') X Var(F) - X/H' and Coef. Var 0 * 1/ /x N f This means that if we fixed the number of microscope fields to count, instead of allowing N to be between 20 and 100, the coefficient of variation of the estimate of the airborne asbestos fiber concentra tion is (X N1)_35, where X N' represents the expected total number of fibers longer than 5 microns. Thus, hypothetically, if we knew X, the average fibers/field, and^selected N' such that X N' * 100, the coefficient of variation for c is equal to 0.10 (10%). Of course, allowing N to be fixed is artificial, since the stopping rule allows N to range from 20 to 100. Because N is not fixed, the distribution of T, the total number of fibers counted, is not Poisson, even if the fibers are distributed 'uniformly' on the filter. In other words, even if the distribution of fibers/field is Poisson, the fact that the numerator and denominator in F (i.e.Tand N, respectively) are both 'randan' must be taken into account. Continuing with the assumption that the fibers/field follow a Poisson distribution with parameter X, the probability that oily 20 fields are counted is given by the probability of 100 or more fibers, which is. E (20 X)K e ~20X K TM 100 Kl 99 K- O -20X (20 X)K e K1 For any 20 < N s 100, we stop counting if we have 100 or more fibers and we had fewer than 100 fibers at N-l fields. The proba bility that we stop at N fields with K > 100 fibers is, 37 CRMC-Christensen-Micro-000135 aii -- mMd ii Intuitively, the slight bias is accounted for by the rule that allows a counter to "go over" the 100 fiber limit, but not to "go under" unless 100 fields are reached. Thus, if all other errors were negligible, and the fibers followed a Poisson distribution, the coefficient of variation of the entire process (to estimate C, the airborne fiber concentration) would be around 10%. Turning to empirical evidence, the fiber distributions seem to give coefficients of variation somewhere between the theoretical 0.10 and 0.20 (The NIOSH intra-laboratory study estimated approxi mately 0.15.) This is for the intra-filter variation alone. Elsewhere in this report we have seen enpirical coefficients of variation far the entire monitoring process frequently at 0.5 and above. Return now to cur earlier assumption that K was known without error. In fact, K is also randan. If we assume that K and F are statisti cally independent, we have E(C) - E(K) E(F) Var(C) -E(K2)Var(F) + E2(F)Var(K) > E2(K) Var(F) + E2(F) VarttO. A The coefficient of variation for C is thus given a lower bound of, Coef Var(C) > { E2(k). Var(F) + E2(F) Var (K) _ - E (K) .e(F) - |Var(F) a. Var(K) ^ |E2iFr+EzTK5--J It is well documented that counters interprets and count differently, laboratories differ, etc. To identify that source of variation in the above equation, we can write: Var(F) - Var(F)a. + Var(F) o , 39 CRMC-Christensen-Micro-000136 where Var(P) .is the 'distribution variance' we investigated earlier which, when used with E(F) gave a coefficient of vari ation between 0.10 and 0.20 and Var(F) is the 'other' variation in F. We thus have, **]'coef. VSr (C) > f Var(F?d I^E2 (F) where B simply represents Var(F) /E2(F) plus YarQO /E2 tK), the ooiponents of the coefficient ofvariation of C not accounted for by Var(F)d /E2 (F), discussed earlier in detail. Talking Var(F). /E2(F) to be (0.10)2 and (0.20)2 (the range discussed earlier), and the eamonly found empirical coefficient of variation for C of 0.5, we find B < 0.24 and B < 0.21, respectively. The inequality was due to the use of E(K2) > E2(K), which is true for all distributions. Using another inequality. Var(F)c > o. we can write c> i jj 1coef. Var(C) (E (K2) Var(F)d + Efc2) - E2(K) E2(F) E2(K) which gives E(K2) _< 1.25 E2(K) for Coef Var(C) 0.50. This is in turn gives lower bounds for B of B _> 0.2375 and B > 0.20 for Var(F). /E2(F) equal to (0.10)2 and (0.20)2, respectively. Taking the upper value of (0.20)2 for Var(F)<-/E2(F), 0.20 < B < 0.21. Therefore, if we eliminate the intra-filter distribution error entirely (i.e. Var(F). * 0), but keep the other errors between filters, counters, pumps, laboratories, etc, we get 0.447 < Coef.Var(C) < 0.458. ( Thus, even taking the extreme value of 0.20 (20%) for the intra- \ filter fiber coefficient of variation, we see that counting many, many more fields results in a reduction of the coefficient of variation for C from 0.50 to about 0.45. More realistic values result in an even smaller improvement. 40 l wilHipiPPliUHL i IT* 'HWP-- CRMC-Christensen-Micro-000137 1 Summarizing: A 1) There is a snail but real bias in the estimation of C (C) due to the stopping rule, assuming a Poisson distribution for the fibers on the filter. Because of the stopping rule, this slight bias is conjectured present regardless of the distribution. 2) Assuming only the statistical independence of V and A (the total air volume and the area of the counting field) and F, by combining theoretical and empirical evidence it was proven that counting more fields and/or fibers is not the answer to reducing the coefficient of variation of the sanple estimate, C, of the airborne fiber concentration. The independence assumption was one of convenience, the same conclusion would be reached with weaker assumptions, due to small intrafilter variation and large variation inherent in the entire monitoring process. CRMC-Christensen-Micro-000138 DISCUSSION AND CONCLUSIONS -- COMPLETE REPORT In this discussion of the inherent "finai number" variation of the entire asbestos monitoring process, we have shown that the problem has been misrepresented and misunderstood. While it may be the best practical method available, it has very limited empirical precision, particularly in lower ranges of airborne fibers. An actual airborne fiber concentration of 0.5 f/cc will routinely produce sample counts of 2.0 f/cc or more. A solution frequently offered to improve the precision of the entire monitoring process is to increase the number of microscope fields and/or fibers counted. This is an an expensive time-consuming effort that perpetuates the misconception that variation of the distribution of fibers on the filter and microscope slide is the only source of variation of any importance. There have been many studies directed at the question of the distribution of fibers on the filter. Are they uniformly distributed (Poisson) or not? We have not dealt with this in detail because it represents only a part of the entire monitoring process. However, we have seen how the inappropriate use of intra-filter variation by Leidel et al resulted in a single coefficient of variation for the entire asbestos monitoring process that was completely unrealistic. What interpretation can be given to one or a few determinations for the airborne concentration of asbestos fibers in the workplace? It was stated in the Introduction and it warrants repeating in the Conclusion: the technology that would permit a determination of the "true accuracy and precision" for the entire monitoring process for airborne asbestos fibers does not exist. Therefore, it is necessary to interpret workplace estimates (i.e. field sample determinations) of airborne asbestos fiber concentrations in the framework of the "empirical precision" of the entire monitoring process, Controlled laboratory studies, theoretical investigations and, most importantly, actual workplace sampling have shown that, while the mean or median 'of'numerous " simultaneous samples may be near a particular number, for example 0.5 fiber/cc, the range of individual estimates taken at the same time and place will be commonly found above 2.0 fibers/cc. The converse is also true. While the mean or median of several simultaneous samples may be near 2.0 fibers/cc, the individual estimates commonly will be found at and below 0.5 fiber/cc. Thus, from a field monitoring point of view, 0.5 fiber/cc definitely cannot be distinguished from 2.0 fibers/cc using only one or a few determinations, and may not be distinguishable even with many determinations. The OSHA proposal to lower the permissible exposure limit from 2.0 fibers longer than 5 microns/cc to 0.5 fiber longer than 5 microns/cc with the expectation of reliably distinguishing between the two conditions in the workplace is clearly unrealistic and without foundation. It is impossible to monitor for the difference between 0.5 f/cc and 2.0 f/cc in the workplace using a monitoring process that cannot distinguish between 0.5 f/cc and 2.0 f/cc! 42 CRMC-Christensen-Micro-000139 TABLE 1= Airborne Asbestos Fiber Sample Locations and Durations: Sampling done December 1975 - Jamuary, 1976 in Multi-product Industrial Complex: All pumps Calibrated at 2 liter/minute. Sample No. 1 2 3 4 5 6 7 8 9 10 Location Dust collectorclean side Near extruder (4) Beater platformpapermlll Wearing loomrear Paper machine take-off Willow Between beaters Near winding roll (4') Lath Inspector's Area UPL Inspector's Area No. of Consecutive Sets of 6 filters 1 3 1 1* 1 5 5 5 5 5 Sample Durations (Minutes) 375 91,110,115 183 115 121 59,80,80,66,59 68,84,85,81,80 68,81,90,75,84 73,75,102,73,72 70,75,106,69,72 * One pump stopped, only 5 filters in set. CRMC-Christensen-Micro-000140 Table 2. Sample 1; Filter /Reader FLOS FIBERS "* A / CJB 100 44 *j b__ 100 55 4 A / UC V a.7 kcb " 109 38 idi~ 53 F/ML .2 .2 .2 .2 ^ B / RVS V S~T TfA " 00 lea lflO 76 5" C / OAA 100 ^C'7"CRCT"--iOo l * C / XJ 100 'c/ sg leo V \ 0/C P ^ 0 / HVC . / RLC ^ E / TLA 1*3 100 iee lea 41 44 63 54 20 38 52 83 .5 .3 .2 .2 .2 .2 .1 .2 .2 .3 Table 3. Sample 2 Filter | \ /Reader FLOS F I3ERS A / EJB 103 29 F/HL .5 A\ / US 'a/ *cb 109 __ 34__ -.6 100 56 1.0 3 FLOS FIBERS ^ 100 42 ^ 100 34 F/HL .6 .5 *100 36 .5 1 FLOS FIBERS F/HL J 100 57 .8 Ol00 J 193 82 1.2 78 1.1 TWAF/HL .7 8__ .9 B / RVB ^ 5 / TFA 190 ISO V. ' C / OAA 100 ^ C / GRC 100 C / KJ* V ^ cy s g 103 100 v *D / C P ^ D / HVO 100 92 1.5 93 1.6 53 .8 42 .7 <9 .8 40 .6 * 92 100 1.4 * 37 104 1.6 V *100 69 .9 ^ 100 53 .7 % * 100 104 1.3 ^ 100 87 1.1 ^ 51 *>67 106 100 2.6 1.9 JW 80 103 1.6 Oioo 49 .6 J * 100 104 1.3 J 100 124 1.5 A_____ " 100 53 _A______ .8 i0e 20 .3 30 ^ 100 47 .7 ^/i00 IS 2 JE / RLG ' E/JfLA 108 75 1.2 50__ 126_ ..y.. *68 IBB 1.9 426__12I_-6,3 ....--Ji *60 101 ____ St25_ 153 2.0 7.4 1.9 1.7 1.1 .7 1.1 1.1 .5 5 1.7 6.1..... CRMC-Christensen-Micro-000141 Tattle 4. Filter v /Header / EJB Va / J a ^ A / LJG 1 A / tC8 Sample JJ PECS FIBERS f/ML 20 106 4.8 28 " 9' "7* ---- ,, 4.4 29 94 3.8 j 20 97 4.4 Table 5. . Filter . /Reader Sample ^ Elds fibers * A / EJB __ ____ ^ A AJ B___ ' 100 100 9 4 A / LJG inn 9 * A / ViCB 100 11 F/HL .1 .1 .1 .2 ^ B / RVB \ ' bT TFA 10 10? 7.9 '2.5 J 3 / kvs" Ob / TFA 108 19 .2 100 6 .1 ^ C / CAA *C /"DfcC / KJW /sc 20 120 20'------ 119 20 100 20 143 4.6 4.6 3.9 5.5 ^ C / DAA V C / CKC 4 C / KJW *C/ SG 130 100 100 100 12 10 5 7 .1 .1 .1 .1 U / c ( ^ o / r.vo ^ E / RLG ^E / YLA 13 104 7.2 20 107 4.8 28 153 5.8 2S 262 B .0 /CP * D / HVD ^ E / RLG ^ E / YLA 106 7 .1 100 12 .2 100 15 .2 109 10 .1 Table 6. Filter * /Reader * A / EJB Sample*^ FLOS FIBERS ICO 101 F/KIr 1.4 4A/J B 109 86 1.2 A / J RG -i / LJG 100 ICO 76 1.0 86 1.2 J A / nCB 100 105 1.4 _J _ B / RVB / TFA 43 184 2.9 51 101 2.4 if 7 drc / xjw /c / S G 5r 59 100 106 102 105 2.2 2.1 1.2 / hvd 100 77 1.0 **E / RLG *E / YLA 55 lol 2.1 50 189 4.4 CRMC-Christensen-Micro-000142 Table 7. Filler /Reader A / EJ3 Sample 6 FLDS fibers >108 28 F/ML .8 ii / j b __ |leg 34 .9 a / jrg A / UC a / kcb lea i *100 *ioe 26 . 29 29 .7 .8 .8 tO 15 FLDS FIBERS \ 100 35 F/KL .7 FLDS FIBERS 1 '100 25 F/ML .5 FLDS FIBERS F/HL ^100 18 .4 * 108 30 .6 '100 14 .3 ^100 13 .3 ^ 100 26 .5 /lO0 15 .3 XlO0 12 .3 ~*io<T 33 .7 "^103 28 .4 "Tine 17 .4 4108 35 .7 *100 18 .4 23 .6 FLDS FIBERS F/HL AO0 9 .3 -/100 10 .3 X1C0 4 .1 ^100 13 .4 l/l00 10 .3 TWAF/KL, .5 .5 -4 .5 .5 3 / 6VB *84 B / TFA *100 * ___ 1 C / OAA *100 c / bbc )iee c / *j C / S (i ^laa * 169 101 34 33 27 43 38 2.9 .8 .9 .6 l.S .9 i ~^71 100 2.5 /leg 40 .7 / 100 *100 Jioo '-'ioe 62 1.1 61 1.1 65 1.1 75 1.3 i *76 107 2.5 J100 23 .4 | " 95 100 2.3 JlOB 29 .6 / 100 '100 73 1.8 31 .8 /100 33 .6 tar 30 .6 r iao 14 .5 Jiee 38 .5 100 12 .3 ^la# 8 .2 '/lee 26 .5 * 100 23 .5 80 11 .3 ^100 28 .4 *TW 35 .7 <^180 16 .4 2.4 .7 .7 .6 .7 .Ii 0/C 9 0 / IIVO * 188 78 62 1.7 log 3.6 E / RUG ~e / tui ^ 95 188 2.5 *Tea 115 2.7 *18. 48 .8 | J 75 103 2.8 ^79 188 2.2 *188 74 1.5 ^ 188 31 .6 .i ^52 108 4.0 ^188 VIM 71 1.2 42 .8 / 188 */l88 15 .4 76 1.9 /111 TTeF 9 17 188 J100 46 1.0 29 .7 / IBB t4 IBB 23 30 .3 .5 .5 .4 ' .t 2.6 1.5 1..2 l C *V i, i t 1 V i 1, 1 1 ( CRMC-Christensen-Micro-000143 Table 8. Sample 7 Filter ' /Reader FLDS FIBERS F/KL A / J 6 )<1 100 5.9 A/J 3 45 102 5.5 A / JRG J31 183 B.0 A /"UG 40 1B1 6.1 A / UCB * 25 104 10,1 FLDS FIBERS F/ML ^40 101 4.9 >53 101 3.7 ^29 108 6.7 O"60 138 4.5 >36 107 5.8 s FLDS FIBERS F/ML J 38 104 5.3 7 33 102 6.0 > 27 101 7.2 *rTiT; 1T6 5.6 >25 108 8.4 1\ FLDS FIBERS F/ML -*75 110 3.0 >90 103 2.3 *50 104 4.2 107 2.7 >70 105 3.0 ^V_ FLDS FIBERS F/HL . TWAF/ML >50 104 4.3 4.6 >47 100 4.4 V < 1 102 5.1 ""'40 107 5.5_ '4.4 l .2 4.8 * 56 101 3.7 li.l d 7 KVB - 1f 85 ica 2.5 B / TFA J 25 103 8.7 / 46 100 1.8 J21 100 7.5 101 2.4 >2 2 100 7.7 **100 39 1.6 >43 100 4.1 ' 86 193 2.2 V31 101 5.9 2.1 6.7 c 7"oaa C / DRC c / rjt C~f s c h1 i > 28 103 103 J 8.2 ^l Jr37 7.6 <"n 102 125 6.6 5.7 - 26 104 8.3 102 6.4 *29 103 7.4 ... 31 105 5.7 8 a >30 116 6.4 ^35 101 4.8 39 103 4.4 >*31 181 5.f >60 >76 >78 t 97 ""271 102 2.3 100 2,2 181 ' 3.0 v39` 96 4.3 >42 103 4.3 >55 101 3.2 --7*19"" 111 "4.6 5.6 4.9 4.8 5.2 0/CP 107 4.6 J 46 192 4.3 ^32 101 6.1 4^81 180 2.5 >57 101 3.6 4.3 WTVB--------:/"50------103------578--------- 7~SI------11)1------379---------- ST1------112----- 6T74---------*TBfl------- 59------T71---------- *TS----- IW2----- 778------------ 177 / ^ 1 ' 96 \* / FLG 7~rUf 101 3.5 ^50 109 4.5 >27 101 6.2 / >50 236 7.9 ' 56 100 2.9 ^""50 116 3.8 /72 100 2.4 \/ 12 ITI 277 >>35 100 5.0 111 3.9 ... . 4.0 4.6 - 1 . CRMC-Christensen-Micro-000144 4 Table 9 . Filter /Reader A / EJB Sampie^p^ FLOS FIBERS >^iaa 25 l/HL .6 FLDS FIBERS F/KL ' 100 31 .6 'A / J B .3 ^/ioa 15 .3 A / JhO J l>:o 13 .4 15 .3 A / US -^100 30 .7 JlOB 21 .4 . A / *CB -'"'loe 18 -4------- ^^100 27 .5 E / RVB "^iOB B / TFA V100 21 37 * A 100 31 .8 * 100 43 .6 .8 FLDS FIBERS F/ML ^100 24 .4 ' 100 13 .3 'loo 10 .2 *Taa 22 ,4 ^100 32 .5 XA FLDS FIBERS F/ML /103 ^100 ''100 ~10fl ' 100 22 17 21 28 21 .5 .4 .5 .6 .5 >.v FLDS FIBERS F/ML /100 14 .3 ylOO 'ino 12 19 .2 .4 7100 23 .5 100 11 .2 TKAF/HL .5 .3 .3 .5 .5 25 .4 ^lflO 29 .5 100 25 100 29 .5 T^Toa 23 .6 >100 21 .4 .4 .5 .6 _ C~T CAA "OF"108 25 .5 =^100 17 .3 '100 21 .3 ** 100 10 .2 ^leo 34 .6 C / DhC Jiao 30 .6 v/100 29 .5 -/100 29 .5 lOB 5 .1 ^ 100 27 .5 C / KJrf *100 16 r 3 ft 100 15 .3 < 100 22 .3 -'100 2 .0 ^100 27 .5 C / S c *100 2B .6 TToi 25 .4 J100 27 .4 - 100 6 .1 / 100 26 .4 D/C P o / nvo j 100 15 .4 J100 Zffio 12 .2 M00 8 .1 *100 17 .4 /"100 27 .5 8 .1 100 11 .2 16 .3 E / RLG j' 100 30 .6 * 100 14 .2 ^ 100 25 .4 -^100 i* E / TLA * JOB 33 .8 JlOO 27 .5 i100 26 .5 / 100 6 .1 100 2S .4 6 .1 ^10. 2* .6 .4 .4 3 .4 3 .3 .4 .5 1 1 | i 1 1 1 1 CRMC-Christensen-Micro-000145 Table 10. Sample\^ Filter /Reader FLOS FIBERS % / EJ8 180 7 I-/ML .2 *7 J 8 f 189 8 .2 \ / JK ^ 188 10 .2 n~ui % / tCB ~%l09 *100 5n 6 .i FLDS FIBERS f10O 9 ^ 108 5 F/ML .2 .1 /100 15 .3 Tffa 6 .1 r 108 4 .1 \s FLOS FIBERS /100 R F/ML .1 /'lao 12 .2 '100 6 .1 /\az 15 .2 S7.BB 12 .2 XV x"> FLDS FIBERS F/ML /l00 9 .2 FLDS FIBERS F/ML 12 .3 '100 7 .2 .108 16 .4 --108 5 .1 100 9 .2 TTflT" 16 .4 --7133" ia .4 / 100 7 .2 W08 15 .3 TWAF/KL .2 .2 .2 .2 .2 . - -- - i i I rr~rvb 3 / TFA i Tl00 S08 11 22 trrvk* C / OfiC C / KJ< C~7~S <T' i rsir------- 11 fioe 11 Sea V 7 s' .2-- ^ 190 ---------9------ .2 .4 / 188 27 .5 ^1W / 100 16 39 72-- .2 ^ 108 .1 ^ 180 .I~ J1W n 18 7 13 .2 --; 100 .2 /" 180 .1 .2 >100 11 11 18 id .2 ^/ioir 21 .4 /FTffB" 22 ..'.4 " .3 .6 7100 12 .2 *"100 42 .8 .5 i ___________________________ _______________________________________________________S .2----nir 7 .1 19 .4 .2 .2 / 188 5 .2 z^ioa 18 .1 7IW 14 .1-- ^100 .3 ^180 .3 J^BCT 11 10 41 .2 .2 .4 .2 .2 .2 i i i D/C P xrT"9D "1-- 108 1 ^ifr 9 10 .2 ^--108 .2 " /188 9 "40 ' .2 .9 s^lfiz /ivjy 16 .3 17 1.2' ^ 188 4 .1 ""180"" " 4 " .1 Tin 7Iair 17 12 .4 .3 .2 .to 1 1 --r C / RLG 100 19 .2 fit* 27 .5 AM 24 .3 /l89 . 22 .4 ^X"108 44 .9 rrm --iba- ' 28 .4 ~^IW 24 ^ 100 42 b 7 1DI" 43 0 1IB Ai 1*0 .4 .1 1 12 CRMC-Christensen-Micro-000146 Table 11 . 18 Samp 1e Filter /Reader FL.D3 FIBERS ' a / ejb 'loa li ___ a / j a 100_ f A / JRG -_ _ A / LJG 'lB0 ^leo !i 11 ___ A /_ WCB f 100 13 ?/HL .3 .2 .1 .3 .3 3A FLDS FIBERS F/ML ' ' 100 16 .4 _ 18 _ _.4 ' 100 -- ( 100 7 24 .2 .5 *100 12 .3 lo FLDS FIBERS 'l0H 13 F/ML -4>. `100 16 .2 B .1 ^100 17 .3 ''lOO 18 .3 *\ FLDS FIBERS F/ML J 100 9 .2 '100 16 .4 r 103 10 .2 * 183 14 .3 . 100 14 .3 FLDS FIBERS F/HL * 100 13 .3 ^100 9 .2 . 103 8 .2 9 100 22 .5 .100 5 .1 TtA t/rt'. .3 .3 .2 .4 .3 -L S / RVB 100 14 .3 _ B / 1FA 1 109 33 .7 _____, J f 100" 14 .3 100 23 .3 '100 41 .8 f10f) 36 .5 f C / DA A 1 DO 27 .S l -----/- 100 32 .6 t 100 24 .3 C / CRC 103 11 .2 ' 100 14 .3 ' 100 11 .1 C / KJ-4 ^ lea 19 .4 * 11)0 19 .4 J 100 27 .4 C/SG - ~7 .1 - 1- U00 19 .4 100 12 .2 1 0/C 9 103 13 .3 0 / UVD *100 13 .3 ( 103 13 .3 100 21 .5 f 100 15 .2 1 100 12 .2 * 100 19 .4 - 100 10 .2 - 100 B .2 100 25 .5 * .3 .5 1* 100 5l .4 100 19 .4 .4 noo 9 .2 /1O0 7 .1 .2 (100 13 .3 ^100 25 5 ,/ .4 rr0 5 .1 ^7nr 21 .2 1 - tJ 100 14 .3 14 .3 (i00 25 .6 *100 17 .4 .3 .4 E / UG \8 12 .2 E / TLA VUi 6 1 t 100 100 46 17 .9 .4 ^00 42 .6 ' 100 57 .9 t 100 39 .0 f 100 30 .6 1 '100 10 .2 100 22 .5 .6 .5 I J i 4 ] j TII j CRMC-Christensen-Micro-000147  TABLE 12: Sample Averages, Standard Deviations, Coefficient of Variation Median, Low count and High Count For Samples given in Tables 2-11. Sample No. Average Std. Dev. Coef. of var. Median Low High 1 .22 2 1.5 3 5.1 4 .13 5 1.8 6 1.0 7 4.8 8 .4 9 .3 10 .3 .09 1.5 1.6 .05 .9 .7 1.1 .09 .17 .13 .42 1.00 .31 .40 .50 .70 .23 .22 .55 .37 .19 1.1 4.7 .13 1.5 .7 4.8 .4 .2 .3 .09 .5 2.5 .06 1.0 0.4 2.1 .3 .2 .2 .5 6.1 8.0 .24 4.4 2.6 6.7 .6 .7 .6 CRMC-Christensen-Micro-000148 4 References Asbestosis Research Council: Technical Note 1 -- The Measurement of Airborne Asbestos oust by the Membrane Filter Method. Revised September, 1971. ` i Beckett, S.T., and Attfield, M.D.: Inter-laboratory comparisons of the counting of asbestos fibres sampled oh membrane filters. Ann. Occup. Hyg. 17:1-12 (1974). Conway, R.E., and Holland, N.D.: Statistical Evaluation of the Procedure for Counting Asbestos Fibers on Membrane Filters. Prepared for Asbestos information Association/North American, 1973. Edwards, G.H., and Lynch, J.R.: The method used by the U.S. Public Health Service for enumeration of asbestos dust on membrane filters. Ann. Occup. Hyg. 11:1-6 (1968). Harness, I.: Airborne asbestos dust evaluation. Ann. Occup. Hyg. 16:397-404 (1973). Joint AIHA-ACGIH Aerosol Hazards Evaluation Committee: Recommended procedures for sampling and counting asbestos filters. Am. Ind. Hyg. Assoc. J. 37:83-90 (1975). Joint ACGIH-AIHA Aerosol Hazards Evaluation Committee: Background documentation on evaluation of occupational exposure to airborne asbestos. Am. Ind. Hyg. Assoc. J. 35:91-103 (1973). Knight, G.: Overlap problems in counting fibers. Am. Ind. Hyg. Assoc. J. 36:113-114 (1975). Leidel, N.A.: Optimum Sampling Times for Airborne Asbestos Fibers. USPHS, NIOSH TR-82 , 1973. Leidel, N.A., and Busch, K.A.: Statistical methods for determination of noncompliance with occupational health standards. NIOSH:75-159 (1975). Leidel, N.A., Bayer, S.G., and Zumwalde, R.O.: USPHS/NIOSH Membrane Filter Method for Evaluating Airborne Asbestos Fibers. USPHS, NIOSH TR-84, 1973. Leidel, N.A., Busch, K.A., and Crouse, W.E.: Exposure measurement action level and occupational environmental variability. NIOSH:76-131 (1975). Lynch, J.R., Kronoveter, K.H., and Leidel, N.A.: Validity of the Poisson Distribution in Dust Counting. NIOSH unpublished inhouse report TR-83. Ortiz, L.W., Ettinger, H.J., and Fairchild, C.I.: Calibration standards for counting asbestos. Am. Ind. Hyg. Assoc. J. 43 CRMC-Christensen-Micro-000149 37:101-112 (1975) . Aajhans, G.S., and Bragg, G.M.: A statistical analysis of asbestoa fiber counting in the laboratory and industrial environment. Am. Ind. Hyg. Assoc. J. 37:909-915 (1975). 44 CRMC-Christensen-Micro-000150 m Johns-Manville Internal Correspondence 11 To: G. L. Swallow - Denver 1-06 Date: December 6, 1978 From: E. J. Bulava - Manville Copies: W. B. Reitze- Denver 1-06 N. B. Scheffel - Denver 3-15 Subject: INDUSTRIAL HYGIENE SURVEY -FLANDERS FILTER WASHINGTON, N.C.- The Industrial Hygiene Survey of Flanders Filter, Inc. was conducted on October 17 & 18, 1978, by L.J. Greco. The survey consisted of sixteen sam ples taken at eleven different locations to determine the occupational exposure to asbestos and microfiber. r, (j. fc The asbestos samples were analyzed optically at 400X and have been reported in terms of fibers per cubic centimeter (F/cc), which is then compared to a 2.0 F/cc TLV, The microfiber samples were analyzed using two distinct types of techniques. First, glass fibers were evaluated in the same manner as - for asbestos fiber dust concentrations, but a TLV of 3.0 F/cc is shown for fiberglass~dust concentrations. The second utilizes a gravimetric type. technique, a weight/ volume result in milligrams per cubic meter (mg/M3) with a 5.00 mg/M3 TLV. Ten of the sixteen samples taken, were evaluated for percent asbestos and microfiber content. The Johns-Manville R & D Center Microscopy Lab, performed the analysis. For details see attached letter. ' On October 17, 1978 samples on F800 Filter Media were taken. The product contains both asbestos and microfiber. The following day samples were taken on #700 Filter Media (Pleader), which contains only microfiber. Before sampling began on the second day, each area was cleaned. The results of the samples were as follows: D-l Mixer Operator * '* Employees: J. Ivey D. Grimes Personal samples taken while mixing. Slight visible dust when operator weighs out asbestos fiber-North American asbestos, C10F713 and microf iber-Joi.r. s-Manville, 104, 106, 110, 112, A 3-M 8710 respirator was worn Date ResuIt TLV % Asbestos % Microfiber 10/17/78 10/18/78* 6.0 0. 36 o.o 1.28 3.0 F/cc 5.0 mg/M3 3.0 F/cc 5.0 mg/M3 94 0 6 100 D-2 Corrugator Machine operator Employee: C. Nagorski Persona^! sample taken while operator was feeding asbestos paper-6,A.P., CRMC-Christensen-Micro-000151 F'age TWO December 6, 1978 G. L. Swallow D-2 (con't) type E-503-FIS into Machine. Very slight airborne dust. No respirator was worn. Pate Result TLV . 10/17/78 0.4 20 F/CC D-3 Weave Operator Employees: c. Canady, Jr. K. Mayo Personal tests taken while operator was weaving in separators. Slight airborne dust. No respirator worn. Date Result TLV % Asbestos % Microfiber 10/17/78 10/18/7-8 1.0 1.77 1.0 0.51 3.0 F/cc 5.00 mg/M'* 3.0 F/cc 5.00 mg/M'* 2 0 98 100 Band Saw Operator Employee: M. Weatherington Personal samples taken while cutting filter media to correct size. Slight to moderate airborne dust. Ventilation system present at saw. No respirator was worn, Date .. Result TLV % Asbestos % Microfiber 10/17/78 10/18/78. 5.9 2.52 1.1 1.08 3.0 F/cc 5.00 mg/M3 3.0 F/cc 5.00 mg/M3 1 1 99 . 99 D-5 Clamper-.Operator Employees: B. Wooten L. Danson Personal samples taken while operator assembled filter box. Very slight airborne dust. No respirator was worn. Date 10/17/78 10/18/78 Resu1t o.r, 0.M 0.6 0.50 TLV 3.0 F/cc 5.00 mg/M 3.0 F/cc 5.00 mg/M ?, Asbestos % Microfiber 99 CRMC-Christensen-Micro-000152 ------- Pago Three December 6, 1978 G. L. Swallow D-6 Slitter Operator Employee: F. Kwiatowski Personal sample taken while operator was slitting asbestos paper - G.A.F^VI type E-503-HS on slitter. Slight airborne dust present. No respirator was worn. . Date Result TLV ' 10/17/78 0.5 2.0 F/cc D-7 Testing Area Operator Employee: Tien Pham Personal test taken while operator was testing F800 Filters. Very slight airborne dust. No respirator was worn. Date Result TLV % Asbestos % Microfiber 10/17/78 0.2 1.21 3.0 F/cc 5.00 mg/M^ 0 100 Testing`#2 Operator Employee: C.. Bembridge ' Personal test taken while operator was checking GQT Hepa filters 24" x 48" x 6 3/8", non-asbestos product.i Very slight airborne dust. No respirator was worn. Date Result TLV 10/17/78 <0.1 0.99 3.0 F/cc 5.00 mg/M Paper Mill Operator Employee: H.. Lewis Personal samples taken on Mill operator. Slight airborne dust present. No respirator was worn. Date Result TLV % Asbestos % Microfiber 10/17/78 10/18/78 0.4 0.52 0.4 O.C) 3.0 F/cc 5.00 mq/M^ 3.0 F/cc 5.00 mg/M^ 0 - 100 - Clean Doom Area sample was taken in constructed clean room with Hepa filters enclosed in ceiling, non-asbestos filters. Date Result TLV 10/17/78 * 0.0 0.03 3.0 F/cc 5.00 mg/MJ '-................ -..... ...... CRMC-Christensen-Micro-000153 Page Four t December 6, 1978 G. L. Swallow 1 D-ll Bandsaw.Operator - Production # 2 Employee: F. Ross Personal sample taken while operator was trimming #700 superflow filter!^ Moderate to excessive visible dust. No respirator was worn. Date 10/18/78. Result 7.3 1.79 TLV 3.0 F/cc 5.00 mg/M^ % Asbestos % Microfiber 100 C.j. -R VtV. E. J. Bulava CRMC-Christensen-Micro-000154 Wi V31 Johns-Manville Internal Correspondence To: E. J. Bulava - Mvl Dato: December 1, 1978 From: Copies: V. E. Wo.lkodoff - R&D G. L. Swallow - 1-06 D. R. Christensen - R&D S. B. Spencer - R&D F. D'Ovidio - R&D Subject: PERCENTAGE OF CROCIDOLITE FIBERS IN THE PRESENCE OF GLASS MICRO-FIBERS, 0.8/Um AA MILLIPORE FILTERS, FLANDERS PLANT, M78-471 A. Per your request, Millipore filters from the Flanders plant were analyzed for percentages of "blue" fiber by optical mineralogy. The filters were collapsed and clarified by our standard technique and analyzed at 500X (Leitz Orthoplan) to be compatible with your NIOSB phase contrast microscopy method. If this were not a.study of a clean-out method, I would have recommended TEM since so many of the crocidolite fibers were barely detectable (0.2 to 0.3 um in dia meter) under conditions of best or highest resolution (100X oil immersion objective with use of a condenser having a numerical aperture of 1. 30). Sample Nos. 3714, 3713, 3712, 3711, 3709, and 3708 were collected on October 17, 1978 whereas the remainder were collected on October 18, 1978. B. The results arc as follows: Sample No. ' 3714 " 3713 ' 3712 371 1 3709 3 70 8 . 370 3- . 3707 ' 3702 . 3717 . Blank' Percentage Crocidolite Fibers 94 2 ND 1 1 ND ND ND 1 ND ND Percentage Microfibers 6 98 100 99 99 100 100 l no 99 too ND ND = Not Detect'd CRMC-Christensen-Micro-000155 E. J. Bulava - Mvl 2 - Dccember 1, 1978 C. I would like to mention that the following filters contained chrysotile fibers and possibly amosite as well: 3714. 3713 3711 3709 3707 /UU A/. . V. E. Wolkodoff vm NB 4873, pgs. 130 - 131 P CRMC-Christensen-Micro-000156 Aa-- ARM ' i/yl Johns-Manville Internal Correspondence To G. L. Swallow - Denver 1-07 From E. J. Bulava - Manville Z' Date' March 7 1978 Copies- Sub,ec INDUSTRIAL HYGIENE SURVEY HOLLINGSWORTH & VOSE COMPANY WEST GROTON AND EAST WALPOLE, MASS. The Industrial Hygiene Survey of the Hollingsworth & Vose facilities was conducted on February 2, 1978 and February 28, 1978 by L. J. Greco. The survey at the West Groton Plant consisted of two locationsi Beater Operator and Slitter Operator. An extensive survey was made at each location in question to obtain the respirable dust and fiberglass concentrations. Until a finpl version of the silica dust standard is published in the Federal Register, sampling results may be reported in two ways. Both results are determined from a single respirable gravimetric' test. The first is in terms of milligrams per cubic meter (mg/^vi3) which is obtained by weighing the filter before and after sampling. The second silica method yields a microgram per cubic meter (pg/lVI3) result, based against a TLV of 100 p.g/lVl3 of quartz. Two distinct types of sampling techniques were used in determining the fiberglass exposure. Once again a single membrane filter is employed to yield a count of glass fibers and a gravimetric result. The current NIOSH procedure setsa limit by count of 3-0 fibers per cubic centimeter (F/cc) and by total dust weight of 5-00 mg/M3. Samples were also taken at the two locations using Nuclepore Filters. These tests are being analyzed by electron microscopy and will be reported separately. Following are the descriptions and results pertinent to the two locations sampled. Dl-WG Beater Operator Employees John Froias Dates 2/2/78 Operator feeds raw materials into beater. Materials fed during the samples were J-M Microfiber //104, #106, #110'.and PPG's DE Fiber. Product being made was HB5106. CRMC-Christensen-Micro-000157 /' / -- Page Two March 7, 1978 G. L. Swallow Dl-WG (cont'd) Hazard <33# Quartz Quartz TLV >0.29 100 Survey Result 0.05 mg/ftl3 <17.04 fig/lM3 Fiberglass Fiberglass 3.0 5.00 0.7 F/cc 0.47 mg/ta3 D2-WG Slitter Operator Employees Dan Curran Dates 2/2/78 Operator slitting HB5106 Filter Paper to match order, 'Hazard TLV Survey Result <52.6$ Quartz Quartz >0.18 100 0.03 mg/lvi3 <16.56 pg/ta3 Fiberglass Fiberglass 3-0 5.00 <0 1 F/cc 0.15 mg/M3 At the East Walpole Plant the sampling was performed in seven locations: Chisel Truck Driver, Boater Operator, . Beater Area, Winder and Slitter Area - Near Scale, #2 Machine Winder and Slitter Operator, #2 Machine Tender Area and Warehouse "Storage Area. All tests were taken for asbestos fiber exposure. The results of the tests were as follows 1 Dl-EW Chisel Truck Driver * Employee: Boley Zebrowski Truck Driver supplies Beater Operator with Paperbestos No .' 5. Date TLV Survey Result 2/22/78 ..'.2/22/78 2.0 2.0 0.1 F/cc <0.1 F/cc D2-EW Beater Operator Employee: Joe Conley The Paperbestos Fiber (No. 5) used comes in pulverizable bags. This enables the operator to dump a CRMC-Christensen-Micro-000158 March 7 1978 / G. L. Swallow D2-EW (cont'd) pallet load of fiber into the beater without opening any of the bags. Date TLV Survey Result 2/22/78 2/22/78 2.0 2.0 0.1 F/cc 0.1 F/cc . Beater Area Area sample set up where Paperbestos Fiber (No. 5) is being dumped into beater. Date TLV Survey Result 2/22/78 .2/22/78 2.0 2.0 0.1 F/cc 0.1 F/cc No. 2 Machine - Tender Area The Tender services the entire line in case of a breakdown. Date TLV Survey Result 2/22/78 2/22/78 2.0 2.0 0.1 F/cc <0.1 F/cc No. 2 Machine - Winder and Slitter Operator Operator winding and slitting A4221 Gasket Paper. ' Date TLV Survey Result . 2/22/78 2/22/78 2.0 2.0 0.1 F/cc 0.1 F/cc Winder and Slitter Area. - Near Scale Area sample taken near the scale of the Winder and Slitter area. * Date TLV Survey Result 2/22/78 .2/22/78 2.0 2.0 0.2 F/cc 0.1 F/cc 1 CRMC-Christensen-Micro-000159 p .*,~r ^ CRMC-Christensen-Micro-000160 - ; j/'V cl < /t ? rtA r USTjohns -Manville Internal Corres^oncprtct To G. L. Swailow - Denver 1-06 Date: December 16, 1977 From E. J. Bulava - Manville Copies . Sub,c INDUSTRIAL HYGIENE SURVEY C. H. DEXTER COMPANY WINDSOR LOCKS, CONNECTICUT The Industrial Hygiene Survey of the C. H. Dexter plant was conducted on October 26, 1977# by L. J. Greco. The survey consisted of three locations: Beater Operator, #2 Machine Take-Off .Operator, and Slitter Operator. An extensive survey was made at each location in question to obtain the respirable.dust and fiberglass concentrations. Until a final version of the silica dust standard is published in the Federal Register, sampling results may be reported in two ways. Both results are determined from a single respirable gravimetric test. The first is in terms of milligrams per cubic meter (mg/Vl3) which is obtained by weighing the filter before and after sampling. The second silica method yields a microgram per cubic meter (p.g/^13) result, based against a TLV of 100 |ag/M3 of quartz. Two distinct.types.of sampling techniques were used in determining the fiberglass, exposure. Once again a single membrane filter" is employed to yield a count of glass fibers and a gravimetric result. The current NIOSH procedure sets a limit by count of 3.0 fibers per cubic centimeter (F/cc) and.by total dust weight of 5-00 mg/M3. * Following are the descriptions and results pertinent to the three locations sampled. D-l Beater Operator Employee: Rich Chabot and Bill Meyers Date: 10/26/77 Operator feeds raw materials into beater. Materials fed during the samples were Kuralow Staple, Tempostran and Qhopped Strend. The operator wore a 3M respirator. Hazard TLV Survey Result 2$?o Quartz Quartz 0.37 100 0.10 mg/to3 25*64 (ig/M3 Fiberglass Fiberglass 3.0 5.00 1.2 F/cc 0.24 mg/ftl3 CRMC-Christensen-Micro-000161 D-2 #2 Machine Take-Off Operator Employee: John Scirica and Ed Pagani Date: 10/26/77 Operator winds up the filter paper and then brings roll to slitter room. No respirator worn by operator. ` Hazard TLV Survey Results <16.9$ Quartz Quartz <0.53 100 0.07 mg/fo3 <11.67 |Ag/fla 0 00 Fiberglass Fiberglass 0.1 P/cc 0.08 mg/M3 Slitter Operator Employee: D. Bruce and J. Moskwa Date: 10/26/77 Operator slitting filter paper roll to match order. Slitting room is totally enclosed. No respirator worn by operator. Hazard TLV Survey Results HUi OO O O <1.0% Quartz Quartz 0.07 mg/fa3 N.D. Fiberglass Fiberglass O OO 0.2 F/cc 0.05 mg/M3 Samples were also taken at the three locations using Nude-, pore filters. These tests are being analyzed by elec:Eron microscopy.and will be reported separately. E . J . Bulava :a CRMC-Christensen-Micro-000162 fit,.* *' "i** < i !* > * * t/* .'-V..... ' *iii <v\ ' ' ' n v--'. ' * ^ 1 'V'W- i *i*S VT* V: ,*? :m* MV* V.!^* *. i TTW t j . u i *<-) --ij.i.h.... . .m*;-? V.:/ . . ft^'iVrii..iiw""IM, .i1lif'i,."i"i,w1--i--Iwtii-,t v>V''"v' :;'V.>>>"- ' *rt` TwV.v.^rir * fflFWte^SL p&f.MMi'.tXL*anaA1.V-jfa;i J-.4* : ny.*.*?*.*'a i-v;:. A.*' . , ' ' * W- "' : pai Tr'i '"Tv;tf*| yi <`V^t *5'. .** \' ;* V4>;u*C-' ..*A 5'l.rrfCftf OPBGftWA __ CRMC-Christensen-Micro-000163 Ml Manville to Attend*** mMmmUU - -------------------- -- me y Internal Correspondence >*' December 21, 1912 *>" K. A. Roberta - 1-08 c;r s 5 -- d. Chriat*ns*n - 1-06 W. A. Sella - 2-01 J. Mule* - 1-09 MINUTES OF LABELING REVIEW COMMITTEE MEETING DECEMBER 10, 1982 A meeting of the Labeling Review Committee was held on December 10, 1982. Attending were J. P. Leineweber, R. Anderson, M.D., G, W. Wright, M.D., N. B. Reitse, S. Deshetler, A. L. Masters, G. E. Fees, J. E. Crawford, D. H. Markusson, P. Kotin, M.D., J. Brown, R* M. Hutchison, B. Bryan and X. A. Roberts. Areas of discussion included* Assignments* FIBER GLASS RFA The RFA for home insulation has been approved and the new plastic bags containing the caution label are being phased into use. The RFA for industrial products, air filtration and mat le being circulated for approval. M8&E has approved. International Brown Jeff Brown will contact Fred Schlachter regarding the Cossaittee'a decision to insist upon the use of the caution worldwide. The Committee accepts the concept of having the International label refer to "all types and makes of fiber glass. F/G Health > Safety Brochure . The Committee approved the full version of the proposed brochure (Form 64B) feeling that the abbreviated version would not acc&aplieh the objective of fully Informing the uaer. Initially, the brochure will not be translated due to the difficulty of adequately tranalating a technical work. Copies will be provided to all International locations with a request that HSiE be provided with a list of all recipients of the brochure to ensure that they can be copied with updated information. * Leineweber J. P. Leineweber will work with the r/6 advertising manager to have the brochure printed. . Mil wtomu IC'-t *dtoc4re 1*1 Federal Better / Vol 17. No. 104 / Friday. May 20. 1902 / Proposed Buies 2M4I Sow covered aiphalt fumea. Although :it publithed interpretation did not peufically include the (era "aiphall fumea,' an earlier reference in OSIIA PrufErim Directive *72-21 (July 3. 1972) indicated that 119101000 war Intended to apply to avphalt fume*. The Agency incorporated asphalt fumea Into this , definition because asphalt la e comples (mature of materials, including pole)clie aromatic hydrocarbons tuck aa anthracene, acridine, pyrene, chrysene, phrnanihicne and bcruo(a)pyrene. that are referenced in Table Z-l tinder coal Ur pitch volatiles, hlany of these same pol>c)dic hydrocarbona may be d-titled m the volatile emissions from both asphalt and coal tor pitch. In a letter dated October It. 1973. the American Petroleum Institute (API) recommended to OSIIA that the definition of coal Ur pilch volatiles be amended to refer only to thoeo distillationa that are destructive, such ae occur from coal or wood distillation, and not the common petroleum distillationa that are nondestructive. Subsequently, on August 1. IfTS. the Asphalt biabtuto endorsed the 197) toiler bom API end recommended deletion of the standard insofar aa it applied to materials not containing significant amounts of hazardous fused polycyclic hydrocarbons It was the Asphalt Institute's view also that the Inclusion of the word destructive would correct the interpretation rendered by OSNA. la September 1977, the National liut.tute for Occupational Safety and Health (MOSII) submitted a criteria document fur a recommended standard for occupational exposure to asphalt nitnrs i nai awwnvni .iUw ill.'. ^ tauc effects producrd'by asphalt, taro, and pitches are quantitatively and qualitatively different. Baaedon theao findings. MOSII recommended a coiling concentration limit of g mg/m '. based oa loul particulates, for asphalt fumea. Oa February 23.1979. the Asphalt Institute wrote OSIIA urging mat asphalt fumea and CTPV bo differentiated and that NIOStfe recommended standards be adopted. In a totter dated September t, I9t\ dm Agency addressed the Asphalt institute's reuoaunendstioaa. TW Agency sc&aowtodgsd dtot asohd! mi cod tar pitch may toe produced dtHeready and have Afferent uses and properties. but reiterated that both Mi eoeaptoa polycyclic arowtia hydrocarbons- farthm. ths GfHA bn* inearthed the air mmpl&m mkmkrnm far asphalt sad CIFV end the k^ats^ aaoHuim under which dtattona * violationa of SB CPII1910l1M teoold ho (t) At the time ef taapecttoa employee* ** found te be espoaed to velaUto emUslana from diitiUatioa residues of u. iL petroleum, wood, ar athsr wgsalc mailer, and (21 Samples abtaOmd to detsnalas emplayea aspesure to dm velatils emissises are found to cantata mare thaa 02 mg d beaiene-aalubto aalsriai per cubic metsf af a*, and (3) Laboratory analysis af dm biarena soluble fraction described la HI confirms dm presence ofbenso(alp|ioM aad/or one se more of dm five additionally named fused polycyclic hydrocarbons la which dm standard refers embracena. acridine, pyrene, chrysene and phiasathreaa On Juno W. 1980. the Asphalt Institute submitted to OSNA o formal petition requesting that the &2 mg/m* level bo declared onenforcesble and Inupplicoble to asphalt fumes and that 29 CIU 1910.1002 be amended to esdude asphalL The petition also requested a rulemaking to amend 29 CTO 19101000 to establiu an occupational health standard for Ixposur* to asphalt fumea of S mg/m1 as recomownded In the NIOSII criteria document and AGCDfi 1971TLV documentation. That petition was denied on November 21IW by Assistant Secretary Bingham who reiterated the rationale foe dm toterpretation of CTPV that was given In 'the November 2L1972 (37 F* 24799) preamble explanation and repented An limited drcuawteacet that would result in citations. On April 24.1991. the Asphalt Institute filed a petition for reconsideration of the Assistant Secretory** denlaL H asked dto Assistant SecrdeMtgaorhygt*og*omvmertlruuolemamnudmA hat the decision was contrarylo low. h also asked for conflrmatioo that 29 Cm 1910.1009 Is Isipfhishh mad unenforceable as to asphalt hoses becauao MOT 1910.1002 was isauad without ootic* and comment Tha Asphalt Institute also requested that OSNA amend 29 CPU 1910.1000 to exclude asphalt and that rulemaking procedures be Inatituted to establish Bo B nm/a* limit far ssphmh Hmm la reviewing dm oppeol submitted by dm Asphaii bmdtete. os woB as velaating dm MOSH end ACCBI dote and tho eireumataiwet eurtcundinn dm Miftaul interpretation. OSNA has found dot Mo for. Msfpfotadoa ofCIFV woo not eaamtotE>3l urith uko A0CIM tetendud to cover aa eon! tor ptlch mPPekiwtite when B adkmapAtemd Ito M00 TALmV. . 0 mmr HSf Hi 1071 of an AGCIH TLV iw osphaB OacunMniodom AGC&f adopted.All TLV bacai m As esS * Asphalt Is a active atetureef hydrocarbons which occurs at so i brownish black solidor aemiaoM. It resadm bva evsperettoo af Ihs lighter bydrocartmaa Imw petroleum sad partial eaidatieeef residua. Nsteum asphalt thus Is la ba difflrrvniiamd bsm tar arprish. i brHR dm dsstroctiva diiUllsKaa Thus OSNA believes dtot dm oriotnnl ACGIH1900 standard for CTPV. which was adopted by OSNA In 1971. was m Intended to covet asphalt and that OSIlAs 1972 tatctpretolioa wot therefore la error, to addition. OSNA has net successfully enforced this interpretation. To correct this interpretation ofCTFV. OSNA intends to amend tha dcfmitioa afcoal Ur pitch volatiles by delating tha reference to -petroleum, wood, and other organic matter.- As amended. tho Interpretation would read As used lo 119101409 (TsMs >t) anal lav pitch volatile* todsde dm fused ydycyilb hydrocarbons which valetgiae ham Ae wstiilsOssi restduee ofeset While poOnlenm asphalt wfll no longer be ooverod by the cod tor pitch voUulcs stoodord under thin Interpretation. OSNA considers uphill fumes to present i recognised haired to ospooed empleyoo* and in studying what regulatory reipmio is nreol appropriate to proud omployeac bum Bus hacord. In dm hrtoriro OSHA mqt use Section 1(e)(1) of the Act (genarnl dmuklayIodomumse|)mto |p|r|oSviiBde||Mprott*e|cftli|o|nut|o| femmOSIIA`9 Sim CHW dated March 17.1 Umpotonttolt edifying dm W regulation hovo boon rmrtowod. Urn defined by BafuialaigiiiiftiHi Ml of 1 (ifB.C TWe0k llli Irecfol* Jr i > * ,1 v ?! r i! V j it i i .. CRMC-Christensen-Micro-000166 MmfcMtoaasdhtoitoUMdnufc -f 23484 Fttoii WegUtf / Vol. 47. No. 104 / Friday. May 28. 1882 / Frapp--d RnIn a pelro direct demand for uphill or coal tar pitch. !n economic terms. the product* are aupply Inelaatic Asphalt and coal tar pitch art directly competitive In roofing application* and. to a leaser extent. for highway patching and repair. Even in these weather* proofing applicationi. the two product* are not perfect subatilutes because coal tar pitch is more pliable and resistant to temperature changes and waether erroaion than asphalt Although coni tar pitch is SO percent mare expensive than avphati. many builders elect to use coal tar pitch for roofing in the belief that the life c)de costs are less and that the reduced risk of building damage due to roof leaks Justifies the greeter Initial Investment 2. Effects on Competition Any change in the competitive position of the two products would result from a reappraisal of thrir relative safety by the products' osrrs. If the modification of this interpretation of iha CTTV regulation results In a new impression that asphalt is much safer, the result might ba an increased demand for asphalt and n decreased demand for coal tar pitch. Since the supply of neither product can be expected to eery with descend, far the reasons already aisled, the relative price* will vary with change In demand. Price shift* will also bo limited by the fact that neither asphalt nor ooal tar pitch is predominantly esed for roofing applications. Approximately 28 percent of asphalt is used frrmoflrm while lees than 10 percent of coal tar pitch I* oaed fur rvmfing. Thus relative price* will bo governed by other market* In which th* product* do not compete directly. i Bert u oo evidence that QSHA compliance coats are significant aspect in th# price of asphalt roofing, or that this action svfll result in dsotesad protection for esphall roofer*. Th* ' primary detenntnenl of th* amount f asphalt fumes Is the temperature efton asphalt during Ita application. Sines the temperatura of iha asphalt suet also bn controlled to saw* proper eissoaity. sthoearies is at no apparent the expenas tncewMeo tosoduen of ssorker protection. 1b* ooat ef applying roofs will oeA change * a moult mm* petto, & No Significant tmpoem m $maff Entities or th* Boemmr. Stas* tit* lets! Mn sate* of ooal ttr pneb ssoeo approximately K24SJ mifiloo. of which Iwe ihaa I# pasnent wsa wtA to sso&sg, i to deer feat tog proposed nsNaat* not -- w Bjw-*ibi>l--iiifBJtBiy SMmVBom. . l ing UfluPSnBv aJM.fteroekowfllbsMt ` apply either product with virtually no changeover oast*. Public fastkipsUoa Since this is a modification of aa biinprelation, nottca and comment would not ordinarily be required wider either the Administrative Procedure Act (APA) or section 8(b) of th* Occupational Safety and Health Act However, since this Interpretation ha* been followed sine* l*T2 and was published and codified in the Oil. OSI1A has decided to give notice and to hivile public comment on toe proposed amendment OSilA wishes to allow those who are familiar with 29 OH 1*10.1002 and have relied on OSHA'* Interpretation an opportunity to address the intended modification. Interested person* are invited to submit swiften data, views and arguments concerning to* isiuee raised In this notice. Th* comments must be rrn ivrd by August M. IMS, end submitted In quadruplicate to the Docket Officer, Docket H-aui, Room t*212. Occupational Safety end Health Admlnlefratton. IfA Department d Labor, 3rd Street and Constitution Avenue. NW,, Wakington. DC. 20210. The data, viesvw and atguments that are aubmlttad will b* avaiiahl* far public inspection and copying at to* above address. AO timely eabmlsslona as weB as all prior petition* sad requests will be reviewed and wifl ba mad* pari of the tucoid *f tol* list of gubjocto In 20 CntMM Chemicaia. Coal tor. NecMk Occupational aalstv sal ImmMl PANT1819 OCCVPATtOWAa. BAPCTV AND HEALTH 8TANDAA0D of toe AcL It j CPU 1*181001 to read a* fsOswn As*Hfln|IMMi(MI*H mm! tar pitch volatiles include too freed Siptad at Washington. DC dHs list day sf MaylML . AasMeaTtovrHWy efteho. ttotos m uwiMvrwiassi Mm Safety and HmMi Admtamir*M*n 20 CPA Part* It and ff aagucrMinefcfetyend Health ; Notice to extend parted for :Hw Min* Safety and Health Administration (MIHA| Is eiSs-wding to |wte 28 IMfc toe neitod fas public iWhOn ' Mot* 8 mi Mf PR MUM. MBIA affrsosmsi pains t (S*APrmaIMMi.PwMMIVi nI M as pari ofa i CRMC-Christensen-Micro-000167 m Johns-Manville __ * ' ' " w . | / Internal Correspondence To: G. L. Swallow J. N. Siegfried - 4N2 - 4N2 From: D. R. Christensen - R&D Date: March 23, 1976 Copios: E. J. Riley - Marrero Subject: PICTURES AND FIBER COUNTS, ASBESTOS CEMENT MOUND, MISSISSIPPI RIVER BANK - MARRERO, L.A. PLANT, BUILDING MATERIALS MANUFACTURING DIVISION The pictures and sample results listed in the attached appendices were requested by you as a possible factor in any litigation that may arise from the impending sale of the property. The attached Appendices, A, B, C, and D, detail results of the above mentioned requests. The special work was done in conjunction with the regularly scheduled survey conducted the week of February 23, 1976. Appendage A, Pages 1 through 5, are pictures of the Asbestos Cement Mount on the banks of the Mississippi River just north of the plant. The pictures tend to show the litter, the lack of vegetation, distances and heights and the errosion that has and is taking place. Doug Aldinger was amazed at the size of the mound and the debris scattered about. Appendage B, describes from what general direction the pictures were taken. Upwind, downwind, on and off the Mound pictures were taken. Appendage C, is a rough drawing of the Mound in relation to size, distance from road, height as compared to the natural bank, etc. Appendage D, are the results of the fiber counts taken upwind, dewnt'ind and on the Mound. Although the day was relatively calm, a prevailing breeze was blowing from the Northwest at the time ot the sampling. The filters left on the Mound attracted some curiosity seekers, for one of the filters had a finger print on it. This however, did not interfer with the analytical procedure. D. R. Christensen DAAiDRC CRMC-Christensen-Micro-000168 CRMC-Christensen-Micro-000169 CRMC-Christensen-Micro-000170 If' W''r' u. =#= 7 N CRMC-Christensen-Micro-000171 r Qf /3 N CRMC-Christensen-Micro-000173 /4^p>e?v'</^ 5 ASBESTOS CEMENT MOUND ON RIVER BATTURE NORTH OF PLANT No. 1 - Looking west toward mound. No. 2 - Looking west toward mound. No. 3, 4,5 - Looking east toward mound, approximately 18 ft difference between natural bank and mound. No. 6 - Looking south toward plant (background). No. 7 - On mound looking toward river. No. 8 - West of mound.on levee toward river and mound. No. 9 - Looking west from mound, notice debris in area also notice errosiop that is taking place. Large chunks are about to be washep away. No. 10 - Also looking west from mound - debris scattering the area. Sample pumps circled. No. 11 - Looking east from mound. No. 12 - Looking west from mound. No. 13 - Large chunks of the mound that has fallen into the river. No. 14 - Same as No. 9. > CRMC-Christensen-Micro-000174 /I__ ____/. - r~*TM w PROJtCT NO.. rwiiw <> AfffiO'i ISO ts 9-ooy EL\l /Vi '''! H r;/- l&jFc Af(V"* tS / V C-fcovtfJ r>- . rvp r A('f'(\n X ?> - ,, _ / ( '' ^ lY'er*- /x'e/l/j f f # i ' i , j ft- /^#7T 7^ CRMC-Christensen-Micro-000175 APPENDAGE D DATE 2-26-76 2-26-76 2-26-76 SAMPLE DESCRIPTION TD(min.) On asbestos Cement Mound 350 Approx. 600' Downwind From Mound - V Approx. 50 yards Up wind From Mound 360 360 RESULTS(F/cc) 0.04 0.02 0.02 0.03 0.01 0.00 T.L.V.(F/cc) 5.00 5.00 5.00 5.00 5.00 5.00 * T.L.V. Of 5.00 F/cc is due to the fact that any exposures are not occupational in nature. _________________________ -H i-------------------a _ CRMC-Christensen-Micro-000176 ftil Johns-Manvtlle Research and Development Center H9pOrt NO. 411*1050-81 Date August 2, 1970 Title: evaluation of tools for the dust-free fabrication OF ASBESTOS-CEMENT Tests have been run to determine the amount of duet generated when drilling asbestos-cement sheets with twist drills and a reamer submitted by Dave Lucy. The tests were run with no dust collection, in chamber described in Report 411-10SO. The two 1/8-inch carbide tipped twist drill*^ from the Cleveland Twist Drill Company were el a 1/8-inch carbide tipped masonry drill from Expansion Company, using a 1/4-inch Blick and Dec] drill. Flat asbestos-cement, 1/4-inch thick, wasv processed at a rate of 4 holes per minute. The i filter was located downstream of the sample being fabri cated in the dust box. The Cleveland bits penetrated the I material much faster and emitted less fine dust than the common masonry bit. Dust counts for the Cleveland bits 5 were 0.6 and 0.1 f/cc compared to 1.8 f/cc for the control I masonry bit. The carbon steel taper reamer, also from the Cleveland . Twist Drill Company was compared to a 9/16-inch carbide tipped Star masonry bit. A 1/4-inch pilot hole was drilled 3 and then reamed to 9/16-inch with the Cleveland tool at' a rate of 1.3 holes per minute. Both the Cleveland reamer and 9/16--inch masonry bit gave dust counts of 0.6 f/cc but much dust was deposited on the floor of the chamber. 5 It is recommended that the reamer should not be used without I dusticontrol because of its visible dustiness. The Cleveland 1/8-inch twist drills are much more superior to common masonry bits for penetration of material and reduction of C fine dust. Even though the dust counts were well below the OSHA 2.0 f/cc acceptance level, it is recommended that the Cape Drill Shroud, with Nilfisk vacuum be used at all times ,sj to eliminate all fine dust. JC Contents: Summary and Appendix. c: a Notebook 4735 , p. 75 jhReported by , G. R. Bauman' Asbestos & Mineral Technology CRMC-Christensen-Micro-000177 Distrubtion* L. Pundsack - 1-03 (8) J. DeBiase Harris Poutiatine Connor Reis Kelleher M. Krone mm 3-13 - 2-12 - 2-14 2-14 - 2-14 - 2-14 - 2-20 (8) (8) Siebert M. Fenner 2-14 - 1-06 L. Swallow - 1-06 V. Magee - 2-10 W. McLain / " 2-20 P. Leineweber* 1-06 Kotin - 1-06 J. Wahlen - 1-05 Laipenieks - 1-05 H. Swensen - 3-07 E. Loeffler - 1-04 R. Lucy - 2-12 J. Re M. Hutcheson - Asb R. E. Sampson - Asb A. R. Dennis - Asb E. J. Day - Asb M. D. Webb - Asb E. B. McKenna - Asb R. B. Gresham - Asb H. M. Hay - Asb KEYWORDS Asbestos Asbestos-Cement Environmental Health Fabrication Dust Dust Collection ' P. B. DiX ATTMi J. Herr A. Schnabel P. N. Bodycomb D. R. Christensen 8. Gaburo N. Trosper X. J. Williams G. R. Bauman RtD information Center -- CRMC-Christensen-Micro-000178 APPENDIX TABLE 1. RESULTS OF DUST TESTS Crill - black a Decfcnr l/l-isch Carbide Tipped Masonry Bit (#1405-011 Mill - Black 4 Deckar 1/8-inch Bo. 725 Carbide Tipped Cleveland Twirat Mill (?7-*DP-4SB47) Mil1 - Hack Decker l/r-io5* Ho. 725 Carbide Tipped Cleveland Twist Drill (#25-6011-0149) Mill - Black 4 Decker 9/16-inch Carbide Tipped Masonry Bit (#1445-0) Mill - Black 4 Decker t/4-iacb Masonry Bit Pilot Cleveland Carbon Steel Steamer to 9/lfc-inch (#142 m Test Conditions Jo dust control Test Duration _ .J..o-ri5n) , .. Material Pulverised by Tool Mo. Holds Uolos/Min Material Pulverised Percent Pulverised Dust Count --m---------------T71J-- Total <m aat/ein. -------rjT^-----T7T7-------- --M----a--t-e---r-i-a--l---C---a--p--t-u--r--e--d----- f/cc ------- 'n Mo dust collection 15 60 4.0 9 0.6 16.67 9.1 Bo duet collection 15 60 4.0 B 0.53 25.0 0.6 Ho dust collection Ho dust collection >5 15 20 1.1 46 3.07 (7 3.13 6.52 6.3B 0.6 0.6 Htat CmdiUoa* - Air velocity pressure through chaaber (Measured in HstsrUl being fabricated is flat asbestos-c--ant sheet, 1/4-i ' "T" vuiti* Best visible Mt TUlUt t Visible Ooum BMt ru to botto of ___nm Boot vou to Bottoo of CbaMbss CRMC-Christensen-Micro-000179 F. J. Angelos E. J. Bulava D. R. Christensen L. A. Schrivef From G. L. Swallow Internal Correspondence Oar- February 15, 197 ciMt E. G. Stevens K. B. Reitze M. E. Volwiler ?. M. Faes MONTHLY EMVI ROfIffEBJTAL CONTROL REPORTS ASBESTOS CEMENT PIPE PLANTS . Vi. E. VOLVJILER * S LETTER FEBRUARY 9, 1979 Enclosed is a copy of the subject letter together with an example of the "stations over TLV" report being established. ' Please note that among other things, this report is to t - .<? the place of the corrective action report we have requested subsequent to each'Industrial Hygiene Survey. Since the new report will be monthly and will include the- corrective action status for all stations over 7LV, it should improve the monitoring of corrective actions taken. i si I CRMC-Christensen-Micro-000180 m Johns-Manville F. J. Angelos E. J. Bulava D. R. Christens i' L. A. Schriver E. G. Stevens J. Brederode From: Q. L. SwallOW c,W. B. Reitze Internal Correspondence Date: November 21, 1978 SnL,..ci CIRCULAR SAW FOR. DRY-CUTTING CORRUGATED A/C SHEET R&D REPORT 2411-1663 ..... ' You will all be interested in the enclosed report showing the construction of Circular Saw which has proven very suc cessful in dry cutting corrugated Asbestos Cement sheet while still maintaining low airborne concentration of Asbestos Fiber. Since field cutting of A/C sheets is common at essentially all locations, I request that you call this equipment to the attention of Plant Managers and Plant Engineers during your regular visits. I would also suggest that you be specifically on the look-out for cutting practices which could be im proved with the use of this equipment. allow \_ hi TL fi.'i c N ft.' Enclosure DEC 111378 rt.jcyS/ CRMC-Christensen-Micro-000181 m/ Johns-ManviBe F. J. Angelos - Wtelcegen E. J. Bulava - Renville 0. R. Christensen - RID L. A. Schriver - lonpoc > E. 6. Stevens - Jeffrey' S. t. Snellen - 411 Internal Correspondence October 7. If75 tf. I. At1 tee - 4R MS . NEK RESPIRATORY PROTECTIVE DEVICE During agr visit with Ed Buiavs, he Inquired about e new Welsh respirator which plant personnel hed been Inquiring about.. Evldently.theee Inquiries were a result of the Healthy Safety A Environ* went Bulletin recently Issued by tf. 8. Reltee. A copy It enclosed for your Infornetloa.* . R rI . N rr' h i: i 3 tI* 3 * CRMC-Christensen-Micro-000182 . . Environmental Control Department Denver - GHQ January 21, 1974 K,, Jones - Coalinga cc: W. E. VanDerbeek - 2 West R. t. Sampson - Jeffrey J. E. Hesse - 5 North D. E; Hillier - 4 North L. A. Schriver - Lompoc D. R. Christensen - R&D a ;.n j. G. L. Swallow/File - a, l SEMI-ANNUAL INDUSTRIAL HYGIENE SURVEY ASBESTOS FIBER DIVISION - COALINGA MINE SURVEY DATE DECEMBER 17, 1973 J* i?' - if (JL/ i Attached are the results of the Semi-Annual Industrial Hygiene surveyxCon- ducted at Coalinga during the week of December 17, 1973. In a Semi-Annual survey, only those asbestos stations above 2.0 F/cc in the previous survey are checked. '' As a result of this survey there are 12 Occupational Dust stations above the TLV. Three stations were not operating. Dust counts taken on December 17 were generally lower than those taken on December 18, as reflected by a deterioration in the appearance of the mill between the two days. On December 18, leaks developed on the second and third floors and air sifter doors and boots began leaking. One leak was covered with a burlap bag. The average of all samples taken on December 17 was 3.6 F/cc, versus 5.7 F/cc for samples taker on the next day. A visible dust deposit was noted on floors, stairwells, and overhead struc tures. ' __i_______ " 7 W. " - --- Please note that personal protective equipment was not worn at any of the stations above the TLV. The use of this equipment should be enforced. ^ V '>: m In your quarterly response to the Manager, Occupational Environmental Con trol, please comment on corrective action taken or planned for all asbestos stations over the TLV plus those stations that were not operating. Your next response is due February 15, 1974. >- '. 7.. ,V ' . V - M. A. Baloga MAB/jmb ' v' Attachments .'* * , '* . ' life*** '\v __ i_____ CRMC-Christensen-Micro-000183 AFFIDAVIT STATE OF COLORADO COUNTY OF ADAMS ) ) ss. ) I, Margaret J. Baumgardner, being of full age and first duly sworn do hereby state: 1. Iam not a party to this action. I have personal knowledge ofthe facts set forth in this affidavit, and if called as a witness, I could and would competently testify as to the truth of the matters set forth herein. 2. Iam the Research Coordinator for the Claims Resolution Management Corporation ("CRMC"), a wholly owned subsidiary ofthe Manville Personal Injury Settlement Trust ("Trust"). The CRMC was created in December 1998 and is staffed by former Trust employees. On January 1, 1999, CRMC began providing claims resolution facility services to the Trust. 3. In this position, I manage the Asbestos Claims Research Facility ("Facility"), a document and records repository located at 3390 Peoria Street, Suite 304, Aurora, Colorado. The Facility contains the business records including but not limited to correspondence, memoranda, reports, records and data compilations ("record") of Manville Corporation or related entities ("Manville"), generally, as well as Manville records relevant to litigation of asbestos liability. The Trust has managed and operated the Facility from November 28, 1988, the date on which the Manville bankruptcy plan was consummated. 4. My experience and familiarity with the documents at the Facility began in 1983 while working for Manville. In my work as a paralegal for Manville, I assisted in locating, indexing and packing many of the records which became the foundation documents for the Facility. I continued to work for Manville until September 1987. From March 1988 to September 1988,1 was hired to supervise and assist in the indexing ofthe first 20,000 boxes which were turned over to the Trust in November 1988. From September 1988 to January 1989, I assisted in the privilege review of documents to be given to the Trust. From November 1988 to April 1994,1 worked for Freeborn & Peters and was put in charge of the Facility, managing all productions and "new" acquisitions. In September 1995,1 was hired by the Trust to manage the Facility. In December 1998,1 was hired by the CRMC to manage the Facility for the Trust. Accordingly, I am personally familiar with many of the records stored at the Facility, as well as how the records have been gathered. 5. To the best ofmy knowledge, information and belief, I certify that these records were made at or near the time by, or from information transmitted by, a person with knowledge, were kept in the course ofthe regularly conducted business activity ofManville, and it was the regular practice and the business activity of Manville to make the records. 6. Attached are documents found among the microfilm collections at the Facility. These documents, bates labeled CRMC-Christensen-Micro-000001 through CRMC-Christensen-Micro000183, are true and correct copies of documents found at the Facility. ibed and sworn to before 14th day of March, 2013. 'ublic AMY W BENHAM NOTARY PUBLIC STATE OF COLORADO MY COMMISSION EXPIRES 05-23-2016