Document B8KDEOJ1a1Yq67bz4DVBNKXpE

TO: Distribution TGG: jet XF: _ RF FROM: DATE: Interoffice Communication SUBJ: T. G. Grumbles November 28, 1988 INDUSTRIAL HYGIENE MEETING ACTION ITEMS Below are the action items from the industrial hygiene meeting held November 15-16 at Lake Conroe. There will be detailed follow-up on several of the items. Correspondence regarding these items will follow in the near future. 1. Copies of the overheads used during the meeting will be sent to all attendees - TGG (these are attached) 2. By December 9 anyone interested in commenting to OSHA on the generic exposure monitoring ANPR should contact TGG. 3. Determine how the Houston office number can go on the Vista MSDS's to avoid Safety Directors getting calls for additional copies - MMG/AJO 4. Form a team to improve the industrial hygiene audit process (TGG will initiate action with Manufacturing Management). 5. Any Safety Director having written audit systems on file will send a copy to TGG. 6. Houston will consider copying Plant Managers on specified information such as new regulations and necessary actions to be taken. 7. Jim Harris will send information on the in-plant labelling system used at LCCC, Aberdeen and OKC to Campanella, Martin, and Lipps. 8. TGG will specifically review the TSCA training needs and explore developing a VISTA "corporate" program, 9. Jim Harris will send copies of his sampling forms to the Safety Directors. 10. TGG will summarize the results of the IH needs brainstorming session in a memo with suggested actions. 11. MMG/DLC will send a HAZWOPER data needs form to the Safety Directors for completion and return to DLC. 12. TGG will prepare a memo regarding IH data security and long term storage options. WV 000011877 Distribution Memo November 28, 1988 Page 2 13. Attendees will send their equipment lists to George Shirley for preparation of a "master" list. 14. Dr. Drumwright will prepare a memo summarizing issues raised in the generic medical testing ANPRM. Thank you for your efforts and participation at the meeting. As always we've got a lot of work to do in the near future. You'll be hearing from me soon regarding Items 4, 8, 10 and 12. T. G. Grumbles dlj .536 Distribution: Safety Directors, D. L. Morgan cc: Plant Managers, JAD, THH, JRD, WLM,' DLC, MMG, AJO, CDM VVV 000011878 Aberdeen VCM lab I.CCP OKC P&D Ham Balt B1 ane pp it VCM * Lead Bz (done) MeCl* EO * Noise Asbestos * HF Resp. Protection Noise Haz Com TSCA* Hazwoper X X X X X - X XX X X XX XX X XXX XX X X X X X XXXX XX XXX --- X XX XXX ---- XX XX XX XX -- New Emp. Contrax. X XXX XX X XX X Ins trumentation X Confined Space * Indicated need for updating VVV OOOOU879 INDUSTRIAL HYGIENE AUDITING GOALS 1. Affirm Committment to Process 2. Concensus on Purpose 3. Review Existing System/Method 4. Discuss Alternate Systems VVV ooooiiaao MY PERCEIVED NEEDS 1) Written objectives of industrial HYGIENE AND OCCUPATIONAL HEALTH PROGRAMS 2) Definition of company standards OUTSIDE OF REGULATIONS 3) Requirement for written follow-up or MEASUREMENT OF AUDIT ITEM WORK 4) Training/preparation of audit team MEMBERS IN PROCESS AND TECHNIQUES General concern on resource needs to IMPROVE AND RUN THE PROGRAM VVV 000011881 PROPOSED GOAL Audits are a management tool to measure COMPLIANCE WITH APPLICABLE REGULATORY REQUIREMENTS AND COMPANY GOALS OR POLICIES IN THE AREA OF INDUSTRIAL HYGIENE AND OCCUPATIONAL HEALTH AUDIT PURPOSE Audits should provide a measure of REGULATORY COMPLIANCE AND PROGRESS IN PROGRAMS - Audits should identify areas of DEFICIENCIES, PROGRAM NEEDS, AND PROGRAM SUCCESSES - Audits should help develop goals and OBJECTIVES OF PLANT IH PROGRAMS Audits do not - assure compliance! - SOLVE PROBLEMS vvv 000ii WHO DOES THEM Currently done with a team Options 1) Continue with team 2) Contractor 3) Plant only 4) Corporate only 5) ? Basic goal to achieve consistency & QUALITY Use same standards at each location VVV G0001188 3 SCOPE OF AUDITS Currently do all programs and REGULATIONS IN A BRIEF TIME-FRAME WITH PLANT VISIT Options 1) More detailed single or multiple REGULATORY AUDIT 2) More detailed total program audit via survey/questionnaire that is FOLLOWED-UP WITH A PLANT VISIT 3) Site visit with detailed check-list SENT PRIOR TO VISIT 4) ? VVV 000011884 REGULATORY OVERVIEW PROMULGATED SINCE ME MET Benzene Standard * Asbestos Excursion Limit Ethylene Oxide Excursion Limit * Revisions to Medical am? Exposure Records Access PROPOSED FINAL RULES SINCE WE NET * Generic Medical Surveillance * Generic Exposure Monitoring PEL Revisions * Hazard Communication Revisions WV 000011385 ANTICIPATED TO BE PROPOSED (BASED ON PUBLISHED REGULATORY AGENDA) 12/88 11/88 1/89 12/88 12/88 10/88 Respiratory Protection Confined Spaces 1-3 Butadiene Final Hazvjoper Hazwoper Training Course Certification Occupational Exposures to Chemicals Laboratories in VVV 000011886 ACCESS TO EMPLOYEE EXPOSURE Am MEDICAL RECORDS Final Rule Promulgated: Effective Date: Proposal mas in 1982 Septbber 29, 1988 Novbber 28, 1988 Revised Rule is essentially unchanged from 5/23/80 final rule with the following exceptions: 1) First aid am> nedical records of short-term EMPLOYEES ARE EXEMPTED. 2) Microfilm of X-Rays is allowed 3) Employer trade secret provisions now consistent with Haz Com 4) Union Reps are required to show an occupational health need for requested records wen seeking unconsented access to EXPOSURE RECORDS 5) No industries treated separate with respect TO TRADE SECRET DISCLOSURE ACTION REQUIRED - 1) Assure revised copy REPLACES OLD ONE 2) Communicate revision to UNION REPRESENTATIVE VVV 000011887 HAZARD COMMUNICATION STANDARD REVISIONS Proposed: August 8, 1988 Comment Period Ended: October 8, 1988 Public Hearing Held 11/15/88 o Originally expanded scope to all WORKPLACES IN OCTOBER OF 1987 o Comments received resulted in other MODIFICATIONS BEING PROPOSED o Also provided some clarifications in PREAMBLE o Some 0MB objections in expansion o Stay of effective date construction INDUSTRY ETC .... ETC .... ETC .... o Significant issues to Vista Labeling exemptions (articles) Applicability of HCS to SUBSTANCES THAT ARE RELEASED IN VERY SMALL QUANTITIES Nuisance dust - Appropriate hazard warning (target organ) Hazard determination percentages VVV 00QO11888 NUISANCE DUST OSHA HAS A GENERIC STANDARD FOR NUISANCE DUSTS ACGIH HAS SOME SPECIFIC NUISANCE DUSTS LISTED WITH TLV'S AND SOME LISTED IN "Appendix D" This makes nuisance dusts on floor list OF HAZARDOUS MATERIALS All dusts could potentially be a nuisance OSHA is LIMITING APPLICATION OF HCS TO NUISANCE DUSTS LISTED IN "APPENDIX D" vvv 00G011&89 SUBSTANCES RELEASED IN SMALL AMOUNTS If under normal conditions of use a HAZARDOUS CHEMICAL IS RELEASED, THE HCS MOULD APPLY UNLESS THE RELEASE MAS OF MINUTE OR TRACE QUANTITIES... AND DID POSE A HEALTH HAZARD Exposures exceeding TLV or PEL not only CRITERIA - MUST CONSIDER "HEALTH RlSK" ASPECT Carcinogens are health risk Purpose of HCS is information about or health risk to ensure disclosure of hazards before exposure Providing info only if PEL exceeded conflicts mith this purpose If a hazardous chemical is released employees should be informed VVV 000011890 ASBESTOS "EL" RULEMAKING Published: September 14, 1988 Effective date: October 14, 1988 o Amended 1986 asbestos rule by adding an EXCURSION LIMIT (EL) OF 1 FIBER/CC AVERAGED OVER 30 MINUTES o Also amended standard to require certain ANCILLARY PROTECTIVE ACTIONS ARE TAKEN WHEN EL IS EXCEEDED o For example Regulated areas established Decontamination facilities o Requirements - Monitoring must specifically evaluate 30-minute EXPOSURES IN OPERATIONS MOST LIKELY TO CREATE HIGH EXPOSURES Must do initial monitoring - any done since March 14 would count Representative job sampling allowed Periodic monitoring required if EXPOSURE ABOVE EL (NOT SPECIFIED) VVV 000011891 APPROPRIATE HAZARD WARNING Many labels found to contain only PRECAUTIONARY WARNINGS (DON'T INHALE) VS. SPECIFIC HAZARDS (l.E. KIDNEY DAMAGE) Not providing information on type or SEVERITY The term "including target organ effects" WAS ADDED TO HEALTH HAZARD WARNING DEFINITION Selection of hazards to be highlighted on THE LABEL WILL INVOLVE SOME ASSESSMENT OF THE WEIGHT OF THE HAZARDS This does not mean only acute hazards SHOULD BE INCLUDED May be appropriate to provide less info ON IN-PLANT LABELS DUE TO MSDS AND TRAINING PROGRAMS VVV 000011892 REGULATED AREAS Must now be established where EL is EXCEEDED - For construction (maintenance) this is NEGATIVE PRESSURE ENCLOSURE UNLESS "short-duration" job as defined Protective Clothing. Facilities. Training Surveillance. Respirators Hygiene Medical Now REQUIRED WHEN EL IS EXCEEDED Actions Required 1) Assess monitoring need 2) Revise existing programs 3) Notify contractors to ASSURE AWARENESS 4) Replace old copies OF THE STANDARD 11393 GENERIC EXPOSURE MONITORING - ANPRM Proposed: September 27, 1988 Comments: December 27, 1988 Purpose: Agency is trying to determine if generic EXPOSURE MONITORING REQUIREMENTS COULD BE USED TO SIMPLIFY FUTURE RULEMAKINGS WHERE EXPOSURE MONITORING WOULD BE REQUIRED. Backgroumd: 1) No monitoring requirements for ZTABLE PEL'S 2) Standard would establish broad PERFORMANCE CRITERIA FOR ACCEPTABLE MONITORING PRACTICES 3) Could include provisions for a) frequency b) personal vs. area monitoring c) FULL SHIFT OR GRAB d) NOTIFICATION REQUIREMENTS E) ACCURACY LIMITS F) PROVISIONS FOR OBSERVATION G) APPLICABILITY ACTION REQUIRED: 1) Review questions in ANPRM 2) Decide if we should comment VVV 000011894