Document B8GG73KrB2OgMZ0zMXxY8oy88
FILE NAME: Asbestos Information Association (AIA)
DATE: 1976
DOC#: AIA108 DOCUMENT DESCRIPTION: Letters from AIA to Dept of Labor and Attached Dept of Labor Report
1 )404,,t,.Ain:.Aco, ASBESTOS INFORMATION ASSOCIATION
1835 K Street, N.W., Washington. D.C. 20006 (2021 223-4885
17 September 1976
Docket Officer Docket H-033
U.S. Department of Labor
Room N-3620
200 Constitution Avenue, N.W.
Washington, D. C. 20210
Dear Sir:
Please refer to this Association's letter of S April 1976 and accompanying documents prepared and submitted in response to the proposed revision to the standard for occupational exposure to asbestos (29 CFR, Part 1910) as published in the Federal Register, October 9, 1975.
In the Association's response exception is taken to the statements on "New Evidence" noted at pages 47655-6, Federal Register, October 9, 1975. Specifically, it is stated, at page three, volume I of the Association's response:
"Our review of the literature indicates that nO credible epidemiological studies have been published which would suggest an excess.of malignant tumors among persons exposed to no more than 2 asbestos fibers per cc of air (TWA), using 'the prescribed membrane filter test method. This is a fact simply because there have yet been identifi6dfor study no populations the exposure experience of whiCh. consistently has been as low as 2 fibers. -Since all populations studies to date have been exposed to substantially higher concentrations of airborne asbestos we can conclude only that an excess of all types of asbestos disease is associated with levels of exposure significantly higher than the level currently mandated to become effective on July 1, 1976."
This summary statement is made on the basis of the study and review pre pared by Hans Weill, M.D., Professor of Medicine, Tulane University, Which is at Part 3, Volume I of the Association's response.
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Page 2
Attention is invited to Or Weill's comments on the importance
placed by OSHA on the orally presented (not publiShed) report
attributed to Howard, Kinlen, Lewinsohn, Peto and P011: "3
Mortality Study Among Workers in an English Asbestos Factory,"'
xviii. International Congress on Occupational Health, Brighton,.
England (1975). This report is rioted at reference 30, proposed
revision to OSHA standard for Occupational EXposure to Asbestos.
Attention in further invited to the Johns-Manville Corporation
comments on misinterpretation of the . "English Asbestos Factory"
studies. The
comments were formally presented to the Docket
Officer (H-033) by letter dated April 9, 1976 and are part of the
official OSHA, record.
For the purpose of fully clarifying the record on this Matter, this Association requested TBA. IndUstrial Products Ltd.:, parent organization of the referenced "English Asbestos FactOry," to provide'. the data developed from the study. This data and accompanying statement from TB.A Industrial Products Ltd. is herewith transmitted to OSHA as a supplement to the Associations comments of April 8.
A
The statement and supporting tables substantiate the assertions made by Dr. Weill and the Johns-Manville Corporation that the cohort emphasized in the OSHA document provide no data to impugn the adequacy of the current U.S. standard of two asbestos fibers/ ml, TWA.
Please be advised that appropriate expert personnel from TEA Industrial Products Ltd. are prepared to testify at public hearing for the purpose of eliminating any possible further confusion as
regards this matter.
Acknowledgment is requested that this letter and its enclosure are included in the official record of the rulemaking procedure for consideration of revision to the standard for occupational exposure to asbestos.
Sincerely yours,
e eness 4xecutive Director
RHM:v Enclosures
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CAI ASBESTOS INFORMATION ASSOCIATION
1635 K Street, N W.,
D C. 20006 0 '202) 223,1555
20 September 19/6
Dr. Morton Corn Assistant Secretary of Labor Occupational Safety and Health
Administration U. S. Dept. of Labor
3rd & Constitution Avenue, N.W.
Washington, D. C. 20210
Dear Dr. Corn:
Please recall that we advised we would request from TBA Industrial Products Ltd. the asbestos fiber exposure data pertinent to the English factory experience cited as "of significant importance" in the discussion of "new evidence" at pages 47655-6, Federal Register, October 9, 1975. This Association and the Johns-Manville Corp, took exception to OSHA's interpretation of the British data in comments OA the proposed revision to the current standard for occupational exposure to asbestos.
By letter of September 17, 1976 a statement from TBA Industrial Products Ltd with comprehensive data from the English factory was transmitted to the OSHA Docket officer. For your convenience we enclose a copy of this communication. We would welcoMe the opportunity to discuss this matter with you and appropriate members of your staff, if there are further questions regarding this issue.
Sincerely yours,
Guy. G. Gabrielson, Jr. Chairman Asbestos Standard Task Force
GGG:v Enclosure
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$.0.TR
A
ASBESTOS INFORMATION ASSOCIATION Amiaroniaa--ims
1835 K Street. N.W., Wa.stlington, D.C. 20008 (202) 223-4885
26 August 1976
Memorandum Fore MEMBERS
Subject:
OSHA Statement of Work for Asbestos Standard Construction Industry
Enclosed is OSHA's Statement of Work for an Engineering Feasibility Study and Inflationary Impact Analysis for Deveiopment of Standard
for Control of Occupational Exposure to Asbestos Dust in the Construction Industry. Research Triangle Institute, Triangle Park, N. C., has been awarded the contract effective as of August 17, 1976 with assisgted completion date of January 31, 1977. RTI is required to forward its compelted work plan to OSHA by August 27. This paper will be forwarded to addressees when aVailable.. Completion of tasks in the statement of work and "certification" by OSHA is required priorto promulgation of a propOsed asbestos standard for the construction induStry. (Note: Different than with the manufacturing. standard (general standard)., OSHA Proceedings now require an engineering feasibility study and inflationary impact analysis prior to issuance of a proposal.) Best estimate at this time, without consideration for delays and baSed on discussion with cognizant OSHA officials, is- issuance; Of pro, posed standard in February 1977 with public hearing,following comment period, as early as summer, 1977.
Members will recall letter to Dr. Morton Corn, Assistant Secretary of Labor (OSHA), dated July 27, 1976 (distributed by AIA/NA Memo of 7/29/76) reiterated primary recommendation of the Association that the proposed rulemaking on the manufacturing (general) standard be deferred until these proceedings could be consolidated with proceedings for the adoption of a separate regulation for occupational exposure to asbestos in the construction industry. This view was concurred in by a number of non-members of the Association in our response to OSHA of April 9, 1976 regarding the proposed revision to the standard. To date there has been no reply to our July 27 letter, however, it has been learned informally that the Association's recommendation is now under active consideration.
At Directors meeting June 10, it was announced that an Ad Hoc CoMmittee for Construction would be established. The Committee, compOsed of representatives of AIA/NA Standards and Technical Committee and participants from the construction' industry, held
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page Two an initial meeting August 12-13. 'Contemplated activities-of AIA/NA in connection with a standard fOi the construction industry will be.r:eviesed.at September f! Board of DireCtors meeting.
R. H. Mareness Executive Director Enclostire cc: Mr. G. G. Gabrielson, Chairman, AAbeetos Regulation Task Force
AIA/NA Ad Hoc Committee for ConStruction
RHM:v
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TASi: ORDZR 2 MITIATZMI3OT 07 TAIVI COI:TRACT J-c;-r- -6-03-5
FOR 11F,SECti TRINGU: =STITUTE
ASUSTOS INFORMATION ASSOCIATION!. forth America
1835 K Suet, N. W. Suite 4'32 Washington, D. C. 20Cai
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STATEMENT. (JP WORK FOR AN ENGINEERING. FEASIBILITY STUDY. AND PREPARATION OF
INFLATIONARY IMPACT ANALYSIS FOR THE DEVELOPMENT OF A STANDARD FOR CONTROL OF .00CUPA'TIONAL EXPOSURE TO ASBESTOS
DUST IN THE CONSTRUCTION INDUSTRY
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A. INTRODUCTION
The Occupational Safety and Health Administration (OSHA) is in the process of revising the standard governing occupational exposure to asbestos. A proposed revision was published on October 9, 1975. Due to the uniqueness of the construction industry (e.g., the multiplicity of non-fixed workplaces, and the utilization of highly transient work forces), it Was exempted from that proposal with the intent that a separate proposal on asbestos expOsure in construction be developed in the fUture. Because of a number of special problems faced in construction, an engineering feasibility study wth an accompanying economic inflationary impact assessment is needed by OSHA.. The study is to determine, using a variety of control methods, the levels of asbestos exposure which are technologically feasible for the various construction activities, and the economic impacts of attaining and maintaining such expOsures.
B. STATEMENT OF' PROBLEM
1. General Requirements
This study should provide substantial estimates of the 7 technological feasibility of candidate provisions of a new asbestos-- construction Standard and estimates of the economic consequences upon the U. S. construction industry resulting from the implementation of such an asbestos Standard. Due to the widespread use of asbestos, a detailed analysis'of the effect on each aspect of the construction industry is impraCtical. However, a representative group of construction activities where asbestos containing products are installed or removed ShoOld be selected for detailed analysis from available data and reviewed with the OSHA COTR.
2. Deliverables From Bidders
Deliverables from bidders are defined as:
a. Work Plan;
b. Monthly Progress Reports;
c. Draft Report on Engineering Feasibility Study; d. Draft Report on Inflationary Impact (Level 1 or. Level 2);
e. Final Report.
Performance Measurements
Contract performance shall be monitored against a detailed work
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plan and schedule which are to be submitted by the contractor not later than ten days after receipt of authorization to proceed. Quality of work shall be judged upon. thoroughness and objectivity of fact gathering techniques, establishment of credentials for source data used, logical construction and presentatiOn of rationale, as well as the, general. management of resources, within established time and budget constraints.
C. BACKGROUND O1 ASBESTOS
1. Description of Hazard and Health Implications
Asbestos, used since antiquity, has widespread and important applications in our modern technological society. There are over 3,000 different products containing asbestos in daily use throughout the U. S. The increasing use of asbestos has added to the urgency to cope with occupational health problems related to the excessive inhalation of asbestos dust. No cure now exists for the diseases caused by inhaling asbestos fibers. Employees exposed to asbestos include an estimated 100,000 insulation workers, 50,000 manufacturing firm employees, 60,000 end-product users,. and uncounted thbusands of construction, ship-building, and auto repair workers.
The term "asbestos" refers to a group of fiberous mineral silicates that are highly abrasive resistant, incombustible in elr, have high electrical. resistivity, and can be separated into filaments.The preSent asbestos standard designates the following minerals as
asbestos:
Chrysotile
Amosite
Crocidolite
Tremolite
Anthophyllite
Actinolite.
Exposure to asbestos fibers, even nonrecurring, short duration inhalation of the fibers, can seriously increase the risk of developing the following diseases after a period of years:
Asbestosis - nonmalignant scarring of the lung tissue;
Bronchogenic Cancer - cancer of the lung;
Mesothelioma - a rare cancer of the lining of the chest or
abdominal cavities.
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Prolonged exposure may also increase the possibility of developing cancer of the digestive tract.
Within the last few years, asbestos has been recognized as one of the most haSerdous dust contaminants in the workplace. Because of the wide variety of products and users of asbestoS fibers, larger numbers of workers are in danger of being exposed to the hazards of asbestos fibers. It haS been established that cigarette smoking increases the risk of developing lung cancer in workers exposed to asbestos.
Although asbestos has been recognized as a hazatdods substance, for many years, the lack of environmental data for previous years, and the long latent period for the development of asbestos-related diseases have delayed proving the exposure relationship until recently. The scant data from previdpUs years does not perMit the establishment of the dose-responSe relationship at this time; however, the risk of contacting an asbestos-related disease is believed to be exposure related.
2. Nature of the Occupational Hazard
More than 200,000 employees face risks from asbestos, prinCipally by inhaling asbestos fibers. Recent:studies have revealed the presence of asbestos fibers in the lungs of persons having no history of occupational exposure. Presumably, exposure was in the area of ship construction or other wank sites where the atmosphere was contaminated. with asbestos by Spraying operations or other sources of asbestos dust. Some evidence indicates that exposure to an asbesto workers' contaminated clothing is ha2ardous to passers-by and members of the workers' family. Asbestosis cases are on record that resulted from relatively light exposure of a short duration. Asbestos related diseases exhibit no known early warning symptoms, occurring as long as 30 years aftet the exposure period.
Although aSbestoS has been known to be hazardous for Many yearS, the first cases were not recorded medically until 1900, some 22 years after asbestos production had become large scale.
Recent studies have shown a high correlation between exposure to asbestos and deaths caused by asbestosis, bronchogenic cancer, mesothelioma, and to some extent other types of cancer. Researchers are disturbed that many cases presently encountered are the result of conditions relating back to the 1930's. Although conditions of, use are improved today, uses of asbestos have expanded, production has increased, and products are geographically more widespread. The effects of exposures in the 1970's may not be known until the end of
this century.
exposure to asbestos may occur during any construction activity
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where asbestos-containing products are either being installed or removed. In the construction industry, these products include:
Asbestos cement pipe acid sheets;
Vinyl asbestos flOor tile;
Sheet vinyl flOdring;
Roofing papers;
Packings and gasketS;
Insulation, pipe, and thermal;.
Coatings and compounds; and
Reinforced plastics.
Construction activities that have the potential to release asbestos fiber are sawing, cutting, drilling, grinding, or otherwise, handling of these products. Since asbestos has been used in building materials for many years, it should be realized that in building demolition, renovation, and remodeling, the worker is and will continue to be exposed to asbestos fibers
3: Standards in. Force and Proposed
Ah asbestos standard of 12 fibert per milliliter greA'er than 5 microns in length or 2 million particles per cubic foot +affair was included in the initial group of OSHA standards published in the Federal Register on may 29, 1971 (36 PR 10466). It was derived from an established Federal standard promulgated under the Walsh,-Healey Public Contracts Att on May 20, 1969.
An emergency temporary standard for occupational exposure to asbestos duet was published, in the Federal Register on December 7, 1971 (36 FR 23207). It limited exposure as follows: "The 87hout timeweighted average airborne concentration of asbestos dust to which employees aLe exposed shall not exceed 5 fibers per milliliter greater than 5 microns in length, as determined by the Membrane fiber method at 400-450x magnificatiOn (4 millimeter objective) phase contrast illumination. Concentrations above 5 fibers per milliliter, but not to exceed 10 fibers per milliliter may be permitted up to a total of 15 minutes in an hour for up to S hours in an 8-hour day."
Qt January 12, 1972, a proposal for an asbestos standard was published in the Federal Register (37 FR 465). The proposal included the emergsncy temporary standard and additional rules on .subsidiary issues. After receiving recommendations from the National Institute for Occupational Safety and Health and the Standards Advisory Committee
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on Asbestos in February 1972 and holding public hearings on the proposal in March 1972, the present standard was promulgated June 7, 1972 (37 FR 11318).
The present standard established an 8-hour time weighted average (TwA) concentration exposure limit of 5 fibers longer than 5 micrometers per cubic centimeter of air with a ceiling limit of 10 fibers which became effective July 7, 1972, and a 2 fiber TWA limit to become effective July 1, 1976.
By way of introduction to the proposed revision of the asbestos standard, published in the Federal Register (40 FR 47652), OSHA has stated:
"This standard, as revised, would continue to apply to all employments covered by the Act, but would exclude the construction industry. It is OSHA's intention to develop and propose a separate revision to the existing asbestos standard which would be applicable only to the construction industry."
This study is intended to provide essential information for, the development of a special standard for the construction industry.
D. ANALYSIS APPROACH
1. General Methodology
In the organization and performance of this Task Order, the contractor must recognize the importance of an interactive,. relationship with OSHA personnel to facilitate timely and effective achievement of the goals. A detailed methodology, developed in the form of a specific work plan, shall be the basis for the conduct of this effort. Further, the contractor shall assemble and identify a highly experienced interdisciplinary and multidisciplinary, group of professionals to accomplish this task plan.
In the course of conducting the engineering feasibility study and inflationary impact analysis, the contractor shall structure an adequate data base upon which to substantiate those results. This data base shall reflect all published and available data sources relevant to the analysis, including all data collected by OSHA personnel, as well as technical, governmental, and industrial publications not previously surveyed. Of special importance will be material collected in support of recommendations of OSHA's Construction Safety Advisory Committee and literature obtained from the Environmental Protection Agency on asbestos which was collected to document EPA's regulations on asbestos.
Further, additional data, essential to the substantiation of these results, shall be obtained by the contractor as required.: The engineering feasibility shall include an assessment of a:wide rapge
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of construction industry applications of asbestos products. minimum feasible asbestos concentrations shall be reported based on factual data and professional engineering judgment where appropriate. This analysis will include the type and level of control effort needed to maintain these minimum concentration exposures, personal protective equipment, etc. Additionally, the feasibility of requiring medical surveillance, retention of medical records, and monitoring records similar to those requirements for other industries (Ref.; Federal Register, October 9, 1975) shall be evaluated for the construction industry.
The inflationary impact analysis shall consider the most feasible and cost effective remedial approaches required to comply with these minimum levels defined by the engineering study. While it is vital that the anticipated cost of compliance shall be discussed, it is equally important that the ''.emomic ramifications of those costs be considered. In the latter case such direct issues as the financial constraints related to these cast burdens must be considered. Moreover, it is important to address both the primary and secondary effects of incurring these costs in the various sectors of the affected commerce. This consideration must include at least the effects upon employment, productivity, supply/demand of critical materials, market -structure, and energy consumption.
2. Identification of Specific Sensitivities and Areas of Invited Recommendations
In performance of this Task Order, the contractor shoulA indicate the level of confidence and uncertainty in all areas of analysis. Any economic dislocations should be specifically highlighted. The contractor should review marginal construction sub-industries to determine disproportionate impacts. Certain resource constraints of administrative aspects of standards compliance should be analyzed. With only 3500 certified OCcupational Physicians in the United States, the burden of the medical surveillance requirements of the asbestos standard upon the medical community must be assessed in light of other potential demands for their services. Additionally, the specific burden of keeping records on and reporting asbestos exposures must be analyzed and recommendations must be presented.
The general availability of technical capabilities and equipment necessary for environmental monitoring of the workplace, as well as that of engineering control equipment, must be assessed.
Consideration must also be given to any specific conflicts or complicating factors presented by other standards, rules 4nd regulations promulgated by OSHA or other agencies.
3. Task Plan
In carrying out this task order, the contractor should follow
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the sequence of tasks identified in Exhibit 1, to the extent possible
The COOtractor should initiate the task order by: meeting with the OSHA PrOjeCt Officet and other OSHA officials to.. 'assure a clear understanding of OSHA's specific needs and to gain a broad overview of the project, including: major assumptions, limitations, and the timetable for completion. Agreement should be reached on report contents, frequency, and the mechanisms of the review process. The contractor shall analyze the overall skill requirements needed to conduct the project and develop a highly experienced. project team with appropriate interdisciplinary and multidisciplinary skills. On or before ten calendar days after receipt of authorization to proceed with this task order, the contractor shall provide a step-by-step description of the approach the task order with a detailed schedule and staffing plan. This workplan should be in such detail that OSHA will be able to evaluate the methodology and the contractor's understanding, of the problem. It should be segmented into logical phases with appropriate timing and manloading estimates so as to be suitable: for use as a tool for measurement of the project's progress. The work plan should also show 'the division of responsibilities between the economic contractor and the engineering subcontractor to be engaged in the study. The proposed workplan and project staffing shall7be reviewed and approved by the OSHA COTR.
4. Task Descriptions,
The following is a brief description of the efforts to' be carried out under each task:
Task A - Collect Information
A review should be made for all literature and materials available from OSHA (including recommendations of the Advisory Committee on Construction Safety and Health), EPA, and other governmental and industry sources discussing: OSHA asbestos standards (inclUding 8hour TWA limits, ceilings, record keeping, training, medical/environmental surveillance requirements, and engineering.. controls), asbestos-related processes and the like as well as EPA. Background Information on National Emission Standards for Hazardous Air Pollutants and EPA Development Documents,
Individuals and organizations concerned with asbestos exposure in the construction industry should, ba contacted and existing files built up by these partiet should be examined. Such parties include:
OSHA and NIOSH personnel;
Selected members of the Advisory Committee on Construction Safety and Health (Asbestos Subgroup);
Construction Industry Associations;
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Construction Trade Unions;
EPA personnel;
Asbestos Information Association of North America;
Municipal Health Authorities.
Documents relevant to asbestos exposute in the construction industry should be collected. Also, informatiOn needed to make a Level
I Inflationary Impact Statement should be collected. Soch information might inclOde Industry Annual Reports, Census Data, and Trade Journals.
Task B - Identify Sources of Asbestos Fiber Exposure
Present and possible future sources of asbestos exposure in the
construction industry. should be identified. Some of the major sources. of exposure are found in the following construction processes or
segments of the construction industry:
Installation or removal of asbestos pipe covers;
Dry wall applications;
Remodeling/demolition;
Construction of power stations;
Boiler rppm construction
These aria other construction trades where workers are exposed tp asbestos should be identified and quantified in such groupings as:
(1) constant exposure to asbestos.
(ii) intermittent exposure to asbestos.
(iii)
incidental exposure to asbestos.
A thorough review of previous studies, contacts with governmental ehforOement officialsi and review of monitoring data and select field studies. should be undertaken. The particular construction operations which emit fibrous asbestos should be identified in terms of both the level of concentration and the degree of exposure (hy! operation or class of workers).
Task C - Estimate Number of Workers Exoosed; Levels of EXPOSUC-1
The construction industry employment associated with various
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levels of exposure to asbestos fibers and various fiber emitting operations should be estimated. This should be carried out through a variety or contacts with industry, unions, governmental agencies, health researchers, and other parties knowledgeable about asbestos exposure in construction. Workers who do not handle asbestos, but who are exposed due to proximity to emitting operations should also be identified and their exposure levels noted.
Additionally, information documenting the transiency of construction employment; range of employment durations; turn-over rates; employee multi-employer exposure; seasonal variations; etc., should be developed. Correlation levels of asbestos exposure levels/durations with specific trades/occupations should be obtained
Task D Analyze Effectiveness of Current Controls
The, effectiveness of strategies currently being used to control
asbestos exposure in the construction industry Should be'examined. The current Control methods to be examined include:
SUbstitution;
Local exhaust - hood with vacuum;
Work practices;
wetting down;
vacuum tools;
Personal protective devices;
respirators;
work clothes.
This task should be accomplished thrOugh the cooperation of construction companies and the use of certain field studies. Also, federal enforcement agencies (e.g., OSHA and EPA) and municipal enforcement agencies (i.e., those in Minneapolis, Chicago, and Philadelphia) should be contacted. Special attention should be paid
to EPA's experience in regulating asbestos emissions at demolition
sites.
The effectiveness of current control measures with regard to reduction of exposure levels as well as other factors such as cost of achieving reduced exposure, worker acceptance, lOng term practicality, changes in worker productivity and other factors should be addressed.
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Task E 7 Propose Alternative Control Stratelies,
Alternative control strategies should be proposed for the construction industry to achieve reduced exposure levels comparable to those levels proposed in the general industry standard (U.5 f/cc el -hr TWA limits). The control strategies associated with 2 or 3 alternative exposure levels should be considered for this task. The response levels should be specified and the control strategies to meet these exposure levels should be determined. However, there might be exceptions in certain operations of the construction industry where it may only be possible to determine feasible exposure levels based on existing and available engineering and other control methods.
Asbestos engineering control methods in use should be examined in terms of their applicability to the various exposure situations found in the construction industry. In addition, all experimental control methods being developed, e.g. John Mansville's portable power tools, should be investigated and evaluated. Patent searches should be made. Foreign experience should be evaluated. Analagous dust control systems should be investigated, and their applicability or lack thereof should be explained. Wet fabrication, regulated fabrication areas, pre-fabricated materials should be discussed using all available data based on real world experience.
Work practices that enhance or complement the effectivenes of engineering controls should be identified. Practices working with other substances, or in analagous situations (e.g. shipbuilding) should be examined for possible extension to asbestos work, foreign and domestic experience should be explored. Particularly significant are work practices suitable for use in demolition. Whenever possible actual data should be used.
Exposure monitoring schemes should be examined for applicability to representative construction work situations. The issue as to whether many of the alleged variables in construction (e.g; non--, repititive tasks and exposure to the elements) negate the effectiveness of any scheme that calls far monitoring on a less than continuous basis in supplying projected estimates of exposures between monitoring should be examined. This would lead to an identification of the kinds of representative monitoring schemes which would work for the construction industry.
When considering medical surveillance, the additional problem when dates of periodic and preplacernent exams occur randomly among employment periods of the transient work force and the related problem of medical recordkeeping should be considered. Statisically, what are the chances that certain kinds of construction employers will be hit with medical surveillance or recordkeeping burdens unrelated to
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their employee population or to relative employee exposures to asbestos?
Other ancillary requirements include change rooms and sanitation facilities and should be discussed in terms of prototypical and representative construction work situations. Actual data should be Used to the extent possible.
Task F - Analyze Alternative StrategieS
Each aspect of the alternative proposed under Task E should be analyzed relative to a full set of relevaht considerations, to inclO
Effectiveness in reducing asbestos fiber exposure;
Cost of compliance:
Capital;
- Operating and maintenance;
- Energy; - Ancillary (monitoring, medical surveillance, recdrd-
keeping, etc.);
Consistency with hierarchy of controls (JSSA); WOtker productivity losSes;
Adoption of substitute materials (functionally similar, hazardous in use, more expensive, etc.). Task G - Screen . Inflationary Impacts in Level of I1S Required An approximate estimate of several relevant alternative provisions should be made to determine whether an XIS will be required. Such estimates should be made for each of 'the alternatives proposed in Teak a and analyzed in Task F. Task H - Analyze Health Benefits Potential health benefits associated with exposure levels identified in Task F should be examined. All relevant information on health benefits should be utilized in this task. The record developed on the proposed general industry asbestos standard is expected to provide additional information on health benefits which should be incorporated. Task T - Prepare Draft Report on Engineering F'easibi'lity Study
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A draft report on the results of the analysis of Task F, incorporating the results of Task H on health benefits should be prepared. The report should provide both findings on the various aspects of the analysis and recommendations for a proposed OSHA standard on asbestos in construction. The basis for the recommendations must be thoroughly documented.
Task - Collect Information for Level 2 IIS
In case an 11S is required, the contractor shall collect whatever additional information is necessary for the more extensive report.
Task K - Preoare Draft Report: Level 1 IIS
In case an IIA would suffice as determined in Task G, such a report should be prepared and submitted to OSHA for review.
Task L - Prepare Draft Resort; Level 2 IIS
In case an IIS is required as determined in Task G, such a report should be prepared and submitted to OSHA for review. 'This report shall include, but not be limited to, the following;
Compliance Costs - The compliance costs quantified in' Task F including engineering equipment costs, implementation cost, energy cost, administrative control cost and the like;'
Indirect Costs - The financial costs of compliance effected by cost of capital, cash flow, depreciation of equipment, etc.;
Enerov - In terms of STUis, the change in energy requirements resulting from the most cost-effective engineering controls identified in Task F. Consideration shall also be given to the change in energy requirements resulting from the possible utilization of alternative substances in the process stream, variations in specific process rates, or variations in end product process manipulation. .Examples of these variations are changing processes, substituting process materials, and modifying end products.
Critical Substances - Certain substances have been placed on a list of critical materials by agencies of the Federal Government due to their importance to the security of the Nation. Asbestos is one of these critical substances. Asbestos is utilized as a raw material in the ptoduction of critical materials and in this respect has an impact on the supply of critical materials. This potential impact shall be evaluated.
Employment - Compliance with asbestos standardi might pave
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significant financial effects on construction operations resulting' in significant changes in the size of the work
force._ Several significant factors which might be found to influence employment Intlt:'!e:
- Construction sub-industry being forced out of busines:
- Modifying work practices or construction activity, an
Force substitution of alternative substances.
Productivity - The implementation Of alternative controls and work practices may have an impact on construction worker
productivity. In other words, to evaluate that impact, a good understanding of the construction activities involved
with asbestos materials, and implicatiOnS of new practiCes and controls Must be Obtained. Factors which might influence
productivity include:
Engineering controls hindering 'operations;
- Personal protective equipment hindering employee movement.;
Less efficient alternative process;
- Medical surveillance implications with respect to
productive manhours.
0
Market Structure -Examples of the types of changes in market an-alor industry structure that this analysis might identify are:
Smaller firms going out of bUsiness or consolidating, producing monopolistic situations;
- Significant price increases affecting supply/demand relationships; and
-
Firms choosing to manufacture alternative products
affecting supply/demand.
- Control methods affecting product quality and, in turn, product acceotability, e.g., wet processing of textiles
In developing this economic analysis, it is essential that the contractor produce reproducible rationales for determining the c.7.no,Ttic impacts including idriiEicat.ion of variables, associative relationships, choice of surrogate measures, and levels of uncertainty or confidence.
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Task - Prepare Final Report After receiving written and oral comments from OSHA, the contra.ctaK should revise the previOusly submitted draft reports and combine them into a single document for publication by OSHA, if desired. The report shall contain a logical presentation of the data basis, the methodology utilized, and the results of the component analyses including sound professional judgement. The Engineering Feasibility Assessment shall provide detailed methodologies, alternatives evaluated, and recommendations relating to the engineering feasibility of reducing asbestos exposure to minimum levels during construction activities.
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SCHEDULE
The following deliverables from the Task Order will be completed as noted.
ReoOrt
Due
Oral Progress Reports written Progress Reports Wdrk :Plan Draft Report on ttuji.neeriAg
Feasibility St.OY Draft Report; II
(.Option) Draft Report; XIS
(option) Final Report
Biweekly Monthly Ten days after aUthrit;iza. tjon 120 days aftet aUthoritatiom
120 days after. a6thorizatton
.135 days after authoti,zation
15 days after authorization
oT
16.
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Ij
EXHIBIT 1 - Flow Diagram of Efforts Underth`TeaO skrder
C
Estimate No. of Workers Exposed; Levels ,--_LILF_:xpo sure
Analyze Alternative Strategies,
H
Analyze Health Benefits
identif ySources Analyze Effecof Asbestos -jp..k tiveness of Fiber Exposure Current Con -
trO Is
A Collect Information
E
Prop. Alternative Control Strategies
I
y
aPrepare Draft
Report on
Eng. Feas.
Study
OSHA Review
C
Screen
re Level I IIS
K Prepare Draft Report; Level 1 IIS
Collect Info. for Level Z
IIS
L
Prepare Draft Report; Level Z HS
M
Prepare Final Reporl
6E00001MVIV
This to 11:liac T%%1;'4 i:ur.:.aa.1.% to th.:
PL,o;astol
in .:1%e
of ..,hor
ne following daliversh1es for this Task Ode..: will 'c completzd as notetl.
Ra'r,cav
* Oral Progress Peoarts ',;ritren ?ro4r%*as F:eyorts war :;,1 an
Dra.!c Report on Engineering reasibiIity at' :iy
Draft Report; ZIA (Option) Draft R%vort; II3 (Option)
.eJoy..
Biweekly Nonthly tU.n days 0.fter autho:citation
120 days after authorization .120 days after authorization
135 days after euthoriz,Ation 165 days after authoriOtion
All computer cragrams and operational JCL used by P.TI in stpport of Task Ordar 2
File description of all master files and working storage files
165 days after authorization
165 days after atIt'..:orizeticn
165 d ys aft,
,:orization
141093 AIA WL 000040
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oa;'4.ts Ir.
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31x1.-.$artzez, ti e.Pd pro7')6?6:
cor.tr.Wcp:r ce:117,rar,5
perttoe..
Labor Caheqa7
Rate
X HO'.its = Total
Proi0-77t PirOPtOr
$41.68
524
$ 21;90
Oeniar
36,54
750
27;927
1:nalyst
:27.05
2.,562
72,007
3,992
$121,675
7:it'eCt Cattt
t:OmputerChatos (tUCC) 4,0 hr. $726/hr.1/ 02.1.ta2/ 0iraCt
Total 724.#
:20504., 3,025 $ 5,929 $127010p
Dira.rt Labor Ex.7ara.es
hi.11aa as sce0:Eied in. the Departr.F:nt
of L.e_Zor Contract J-5-F-.6-00:;5; Other arf,!ot.Costs, listed above W.I.1
be. W.11ed as i474icated.
.44y Computer terVides Costs in excess Of the atiolant stated is this't'atk!oraet toil, rcit. be accepted by OSRA withbut prior: tirittn justiaoation from. RTI and approval by 0$RA,
141094
lr Inclua,s TUCC inm 370/165 $G00/hr. + $50 ON ASE
$66 fee
2/ Incluaas $2,500 Purcheze price + $25,0 WASt (;,6 A) + $275 '6,
AIA WL 000041
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es3Arah By:
InstitlYte
141095
AIA WL 000042
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141096 AIA WL 000043