Document BRgv6rQB07LYG3O17wqwyaZnL

FILE NAME: Chrysler (CHR) DATE: 1976 Apr DOC#: CHR113 DOCUMENT DESCRIPTION: Meeting Minutes yj Inter Company Correspondenc Sattelmeier Ind. hygiene * # ;or?ers. It 'p n i 11. 1376 Chrysler Center * : maiv' A17-05 : u i *, Lardie Fersonnei Chemical ^ Trenton 4S3-o: `2 et: ng - review o? ?. mirer report and corporate industrial HYGIENE COMMENTS r t r cur discussion, :m s U tte r w ill review the resu lts of our meeting on 'oncay, ip r il 19, 15*6. Mr. coders and I were Happy to Have the opportunity to ir.eec with you and Mr. Glazier to discuss the comments and recommendations nade by Mr. F, Mirer, so cial Security Department, U.A.W., m his report of a v i s it to review asoestos exposure m the Chemical Division. -.s you know, this plant location has made a consideraole effo rt and expen* diture of funds over the past several years to assure that we would meet the reduced OSHA Standard for Asbestos Exposure, 0 ** (2) fib e r s/c c ,), to be e ffe c tiv e on July 1, 1976, The re su lts of te sts and inspections by CSHA, the Michigan State Department of Labor, Corporate Industrial Hygiene and our own Safety personnel over th is period inaicated these e ffo rts have been su ccessfu l, and we have been under th is new standard for exposure lim its for over two years, With few exceptions, " r . M irer's recommendations and/or requests do not relate to items which represent d eficien cies with respect to this forth* coming reduced standard,*but rather to a recently proposed further reduction in the Asbestos Exposure Standard to .5 fib e r s /c c / It snould be noted, this proposed further reduction m the exposure standard to .5 fib ers/cc. has caused a great deal c f controversy and concern throughout the asoestos and related manufacturing in d u stries. F ir s t , there is consideraole doubt and a lack o f appropriate evidence to support the need for a standard this low from the standpoint of employee health and safe ty , and, secondly, more than a l i t t l e question that the affected producers and manufacturers would be able to meet a standard at the .5 fib e r s/c c . lev el. Considering these fa cto rs, i t should be noted that the implementation o f Mr. M irer's recommendanons/reouests would have sign ifican t and serious economic implications at the Chemical D ivision, p articularly in the absence of a .5 fib e r s/c c , standard, requiring sim ilar changes elsewhere in t h e _____ asbestos and frictio n nateriar*Tndustries*: ................. ......... Cur purpose m reauestm g 3 meeting with you and Mr. Glazier was to review Mr, G la sie r 's memo concerning Mr. M irer's recomaenoations and requests, wnich have already become tie suoject o f a number of grievances and demands by our Local Union. * f your o ffic e did fee l that sp ecific items contained ohrysue* m e * 'eeting * Review :i Ygiene Comments -P ru H , 976 ?age 7*o ? Mirer : s3crt ma Corporate In austn ai --------------- .r. Mr. Mirer' s report represented deficien cies* or potential proDleas with * respect ;o our compliance with tne upcoming reduce stanaard to two (2)* ' :;b e r s /c c ., it would, of course* be tne Chemical Division' s respon sib ility to take the action necessary to assure compliance with this standard by the duly 1st, 1976, effectiv e date. To the extent, however, the recommendations and requests by Mr. Mirer are not required to meet existing or the forthcoming two (2) fib ers/cc. isbestos exposure Standard, or ao not represent any other health hazard to our employees, our position would be they are negotiable local union demands, and be treated accordingly. Following x$ a summary of the major points made by Mr. Mirer in his report and the response to these items, as discussed and agreed in our meeting: 1) 3ostm g - a. language for any signs to be posted is specified in both the current and July 1 st, 1976, Asbestos Exposure Standard. Any signs to be posted w ill use th is language, without reference to lung disease or cancer, as proposed by Mr. Mirer. b. Generally, we agreed that wide*$pread or indiscriminate posting with respect to p oten tial asbestos hazards tends to d ilu te and/or weaken the effectiv en ess of th is action. c. Based on both the current and upcoming reduced Standard to two (2) fib e r s /c c ., posting i s only required in areas in which employees may be exposed to asbestos at the ''ceilin g level (ten (10) fib e rs/c c .) Tests and a ir sample an alysis by your o ffic e do not indicate that the locations id e n tifie d by Mr. Mirer have this level of exposure. We w ill, however, review these areas, again, and make any additions required. 2) Containers - a. It was recognized that covering containers o f asbestos*containing material can be a co stly measure with re lativ ely l i t t l e e ffe c t on overall asbestos exposures. Open containers of inert m aterials containing asbestos da not represent a health hazard, unless ^ p a rtic le s can become airborne. Since th is is most likely to occur during loading and unloading operations (when the covers would be removed1, :xe use of covers is questionable. b. We w ill review those instances in which containers o f material containing asbestos are moved about the plan t, creating the p o ssib ility of airborne p a rtic le s, and provide cover where needed. CWYSim 001266 "eetin g - Review c i 'vgienc Comments : ? r il U , ;976 Page T^re* -ter ; eoo: ina rporate, Industrial 3* V entilation Indicators - a. V entilation indicators of whatever type can only advise tr.e operator that the ventilation equipment is "on" or `'operative.'* Whether or not the equipment is performing adeauately can only be determined by trained personnel, using prescribed testin g devices and a ir samples. b, In most instances, the operators can determine, physically, whether or not ventilation equipment is "on11 or `'operative/* This resp on sib ility w ill be incorporated into existing ;job duties and emplovees w ill be instructed to check, ventilation equipment :or operati an at the sta r t of each sh ift. Inoperative equipment - i l l be reportea to Supervision and Maintenance, immedi ately. At those locations where physical check is not easily accomplished, some type of indicator w ilt be u t ilit e d , to aleTt Supervision and Maintenance to potential prooleas. Because o f redundant and "back.-up" systems, the use of "interlocks'* i s not fe a sib le at most location s, and the use o f sp ecific equip ment without the primary ven tilation source, is not hazardous, p a rtic u la rly on a temporary b a s is . Housekeeping - /e A* a. . ~,f . ^ Management agrees tnat good housekeeping is necessarv to the e ffe c tiv e and orderly concuct of a ll manufacturing operations, and has agreed to this m our current labor contract. ** b. w* agree the matter of ja n ito r ia l manpower and scheduling is the re sp o n sib ility of plant management. 5) Cleaning Methods a. A fter some discussion, -e agreed that the "wet" methods recownended by Mr. Mirer are not practicable or effec tiv e for our operations. b. ~ ' "Squeegees" w ill be u'secfTo move"s&ests^cntlurirrg waste m aterial and other debris, d irt and dust to the proximity of the existing network of vacuum cleaners tor proper clean-up. c. The Corporate Asbestos Review Guide w ill be revised to re flect th is method for the Chemical Oivision. CHRYSLER *0 1 2 ** f e t i n g - Review of F. Mirer Report ana Corporate Industrial Hvgiene Comments A? r i i a , " 1376 ' ---- ------------------- "------------------ ---- ?4ge Four 6 ) *ork Clothing * 4. existin g and forthcoming OSHA Scandaras require special clothing, such as co v e ra lls, for any employee exposed to airborne concentrations of asbestos which exceed the ceilin g le v e l, (ten (10) fib e r s / c c .) , Our current Corporate Standard provides for th is clothing when employees are exposed to con centrations exceeding five (5) fib e r s /c c ., and this is currently applied at this plant. Those employees at locations identified by Mr. Mirer, who are not now assigned coveralls and two (2) lockers, are not exposed to even two (2) fib ers/cc. m most instances. b. During the 1973 contract negotiation s, management at the Chemical Division agreed to provide protective aprons for employees at many of the locations noted by Mt . Mirer. Few of these employees have requested work aprons during the past three years. c. In order for coveralls to provide any protection fro possible contaminations, they must be kept apart fro employee stre e t clothes and stored in separate lockers. New locker and shower f a c i l i t i e s would have to be constructed at th is plant to pro* vide the necessary space fo r a l l Friction Products employees. d. E xisting te st and a ir sample an aly sis data do not indicate a hazardous condition at these work locations, based on the current and fortneoffling reduced exposure standards. 7) Monitoring Observations * a. It is recognized that the lo cal union Health and Safety Represen ta tiv e is n o tifie d when Corporate Industrial Hygiene enters the plant for survey purposes. b. The current Health and Safety Memorandum o f Understanding does not provide for the Representative to be excused fro his job to monitor testin g and sampling procedures, and this plant does not propose that th is be changed. c. The various te sts and a i r samples are taken by trained, professional h y gien ists. We do not believe an untrained, non-protessional, union appointed representative can take any useful contribution to the te stin g and sampling procedures. The Union, of course, does have the right to request that sp e c ific areas, locations or job operation be sampled for p o ten tially hazardous conditions, and to be informed of the' results of these te sts . CHRYSLER 06127 "eetm g * Review c i F. Mirer Report mo Corporate Industrial rivgient Comments *?ru 1976 Pag Five a. There is no agreement in the present Memorandum or Understanding to provide the local union safety representative with a copy or* le tte r s given to employees regarding over-exposures, we have, however, as a natter of p ractice, n otified the Union of these le t te r s and any over-exposure, and have allowed then to see them. e. We are agreed that inclusion o f the sp e c ific numerical results o f a ir sample analysis in over-exposure le tte rs would serve no useful purpose. S) Friction M aterials Building * a. Weigh-uc Station * We are agreed that waste bags be disposed of in se aled , impermeable containers. b. lodige Mixers - The housekeeping problem at th is equipment was caused by a breakdown, Repair had already been scheduled, prior to Mr. H irer1* v i s i t , and was accomplished shortly thereafter. We are in agreement that a ir sample re su lts show that the dust which i s seen to escape during loading of. th is equipment is composed, mainly, of non*asbestos p articu late and is below current and forthcoming, permissable le v e ls. c. Bipel Presses - We agree that improved administrative controls with respect to employee training and handling of asbestoscontaxning m aterial is required at these locations. Previous a i r sample re su lts have indicated that present engineering con trols are adequate to minimise exposure. The recent assign* ment o f new employees tor some o f these operations have caused some increased exposures in the most recent survey resu lts. We do not believe the use of p la s tic bin s, f ille d at another work s ta tio n , and covered or exhausted would make any sign ifican t change in whit are already low exposures* Protective clothing is not required by current or forthcoming OSHA Standards for the ex posures a t these work sta tio n s. d f " O.E.M. Grinders - As you are aware, we have reason to believe that " * the apparent "malfunction'1"oY vent 1 1at ion* equipment aT bHiVTocatidn"' during Mr. M irer' s v is it was not "acciden tal" . *e do not believe an in terlock is reouired at th is location , since "shake-down" operations are not conducted with employees in the area. .As we d iscu ssed , however, some type o f warning lig h t or indicator w ill be in s ta lle d to advise employees when the a ir flow to the grinder is cut o f f , due to "shake-down" operations. The noise exposure f e t i n g * 3evie* of F, Mxrer Reocr jjyglftna Comments P m n , 1976 ?*e s u and Corporate Industrial at this location has seen measured and found within allowable lim its. We agree tr.at Plant Engineering w ill not provide * ' written reports to tne Health and Safety Representative. ** Saw Area, H aaperaill Mezzanine, Air Cleaning Equipment - The items noted oy Mr. Mirer as m need or rep air have oeen fixed, as previously scneduled. is noted above, open-barrels of asbestoscontatnmg material do not present a health hazard. The scrap noted by Mr. Mirer in this area are large pieces o f scrap brake lining m aterial which present no poten tial for airborne asbestos particulate. 9) Chemical Products Building - a. Downstairs Wejgh-Uo Station - U r samples have already been taken, regularly, over tne past two years at th is location, and exposures are minimum. Because of the re la tiv e ly small asbestos usage in the Chemical Products area, time-weighted averages reduce exposures to very minimum lev els. b. Storage Areas - E fforts are being made to assure that a ll asbestos shipments are received in -p lastic bags, per Mr. M irer's comment. c. Meztanine Weigh-Uo Station - Provisions are being made for the use of avacuum" cleaner a t .th is location. d. - The hood at the loading point on the *2 Readco mixer has been repaired. He do not fee l the overall use and exposure to asbestos in the Chemical Building warrants the use o f signs o f the type which might be posted in certain areas of the Friction Products building. In summary, i t is recognired that our plant location i s and has been in com pliance with the requirements o f the new GSHA Asbestos Exposure Standard to be e ffe c tiv e on Ju ly 1, 1976. Except fo r the rep air of sp ecific equip ment o r other changes, as noted in the foregoing, none of Mr. M irer's re commendation* are required to enable th is plant to meet the current or establish ed future OSHA Standards. cc: G. D. Benson F. A. Burnett S. C. Enders 0. P. G lazier E. R. Lombard N. McCallurn W, M. O'Brien J . A. U rd ie :/o> s: C# & & &