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.* -V* * . . ^ *3? '-- v . | 'nS^i *" ' - iVrA * * y" ^ u . ...`,"* V`.' *$* ...... ' ^" 'v..- V' '' '* /s*v. '"V#.> wi 7-?.u V $f*'".\Cff"',/'. fe'i - > r * &u& - |f' - < ' <w , ,:'* .3^,, '- ' CAUDRIAW ASBESTOS PRODUCTS UNION CARBIDE CORPORATIO..N..x.A. f METALS DIVISION >&* < j< rA%* > ^r - ..r. '- *-*" i ``'*&"f'** BOX 579, NIAGARA FALLS, N.Y.14302 - *--' -* ' " /y'i'f-''..-/.v:... . / -'-y. f K *. $>, UCC `015066 j!M- "CALIDRIA" ASBESTOS RG-244 HEALTH AND OSHA INFORMATION October 1, 1977 A24 123 - $***- > ' "CALIDRIA" ASBESTOS RG-244 HEALTH AND OSHA INFORMATION October 1, 1977 A24 13C Union Carbide Corporation Mining and Metals Division "Calidria" Asbestos Marketing and Technology Department Niagara Falls, New York UCC 015067 CTC008564 INTRODUCTION The Williams-Steiger Occupational Safety and Health Act was passed in 1970 with the stated objective of assuring every American worker a safe and healthy workplace. The first health standard promulgated under this act covered exposures to airborne asbestos and went into effect on June 7, 1972. OSHA proposed extensive revisions of the regulations on October 9, 1975. The pro posal has been going through a variety of administrative procedures including feasibility and inflationary impact studies. The revised version is expected sometime in the first half of 1978. Asbestos has received a great deal of attention and publicity in the last several years. Unfortunately, much of the media treatment of the subject has been emotionally oriented and distorted and, in some cases, bordering on the sensational and untrue. Many users of asbestos and products containing asbestos have been mislead regarding the safety of asbestos and what is needed to comply with the OSHA requirements. The information presented in this folder has been collected as a service to "Calidria" asbestos users. It is intended to help put both the health and OSHA compliance questions in a reasonable perspective. Included are: 1. A summary of the main provisions of the OSHA Asbestos Standard and a copy of the regulations. 2. Airborne asbestos fiber count data obtained by Union Carbide at a variety of industrial locations during the blending of RG-244 into polyester resin, the spraying of the asbestos containing resin, and the sanding and grinding of the finished parts. 3. Two pamphlets, "What You Should Know About Asbestos And Health" j and "Asbestos and Health" published by the Asbestos Information * Association/North America. The first is an employee oriented discussion of both health and OSHA while the second addresses the health question. Additional copies are available on request. 4. A Material Safety Data sheet and analytical data on "Calidria" asbestos. OSHA REGULATIONS Introduction After extensive public hearings, a Federal standard for Exposure to Asbestos Dust was published in the Federal Register, Volume 37, No. 110 on Wednesday, June 7, 1972. A copy of this standard (1910.1001) is included with the literature at the back of this booklet.(') cm *3 (1) Some states have established their own regulations and enforcement programs and have been certified by OSHA. Generally, these regulations are identical to 1910.1001 but occasionally there are important differences. This dis cussion applies only to the Federal standard. Information on any particular state is available upon request. CTC008565 UCC 015068 2- - Basically, the standard can be divided into the following five major categories: 1. Standards: . Defines the allowable airborne asbestos fiber content in the workplace. 2. Monitoring: Defines the method of collecting samples and measuring the airborne fiber concentration. 3. Methods of Compliance: Defines acceptable procedures to met the allowable limits. 4. Medical: Specifies frequency and type of medical examinations required. 5. Warning Signs and Labeling: Specifies when warnings are necessary and the wording of such warnings. The essential features of these categories are discussed in the remainder of this section. Before looking at these, however, it should be made clear that in the most basic sense the regulations require that every place of employment where asbestos is used must be monitored to determine the exposure level of airborne asbestos fibers. If the levels are well within the allowable limits, the only additional requirements are those relating to medical examina tions. If the levels are not clearly within compliance, all provisions of the regulations apply. There has been a great deal of confusion on this distinction, occasionally even with OSHA field inspectors. Standards The present OSHA standards set a maximum exposure to airborne asbestos fiber of length longer that 5y of: 1. An 8-hour, time-weighted average (TWA) of 2 fibers/cc. 2. A ceiling concentration of 10 fibers/cc. Note particularly the use of the time-weighted average over the 8hour shift. An operator performing one or two short additions of RG-244 per shift, as is typical of polyester producers, would have his exposure during the dumping time averaged with zero (or a very low background level) for the rest of the shift. This, obviously, tends to greatly reduce the 8-hour TWA. CTC008566 UCC 015069 A 2 4 132 -3- Monitorinq The regulations require an initial monitoring to determine whether the workplace meets the required levels. Thus: "Within six months of publication of the regulations (June 7, 1972), every employer shall cause every place of employment where asbestos fibers are released to be monitored in such a way as to determine where every employee's exposure to asbestos fibers is below the prescribed limits." t Monitoring usually is done by the membrane filter/personal air sampler, which can be obtained from a number of manufacturers. The personal air sampler draws workplace air onto a filter which collects the particulates and fibrous dust in the air. This filter is then placed under a microscope and the number of fibers counted. After the count is complete, the actual fiber concentrations, expressed as fibers per cubic centimeter of air, are calculated by formula. After the initial monitoring, the regulations state: "...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 than 6 months for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph (b) of this section?11 The section that has been underlined shows that if the initial monitoring give levels that are well below the allowable limits and no change is made in the method of operation which would increase dust levels, no further monitoring is required. It is a good and recommended practice, however, to monitor at regular intervals to make sure that the limits are being met. It should also be understood that you cannot be cited legally for exceeding the allowable limits on the basis of your own monitoring. OSHA must base any citations issued on thiTr own tests. Methods of Compliance If monitoring shows a plant or operation to be in excess of the co ^ limits, a number of ways are prescribed to bring it into compliance. These include, but are not limited to, engineering controls such as isolation, c>i enclosure, exhaust ventilation, and dust collection. Certain work and ^ housekeeping practices and waste disposal procedures are specified. Respirators, special clothing, and change rooms are also required under certain conditions. It is most important to understand that these compliance procedures are required only if the allowable airborne asbestos fiber limits are being exceeded or can be expected to be exceeded under reasonably foreseeable circumstances. They are not automatic requirements that apply wherever asbestos is present. CTC008567 UCC 015070 -4- Medical Examinations Preplacement, annual, and termination medical examinations must be provided or offered by the employer for any employee "... engaged in occupa tions exposed to airborne concentrations of asbestos fibers." These medical, records must be kept for 20 years and are available to the employee's physician. _Ifiis_section has proved to be one of the most confusing in the regulations since it does not define any cutoff level below which examinations are not required. Finally, after five years of urging, OSHA issued a clari fication. "Exposure to asbestos" is specified as any exposure which exceeds 0.1 fiber/cc >5y in an 8-hour time-weighted average or a peak level greater than 0.5 fiber/cc >5y based on a 15-minute sample period. Caution Signs and Labeling The regulations require that: "Caution signs shall be provided and displayed at each location where airborne concentrations of asbestos fibers may be in excess of the exposure limits prescribed in paragraph '(b) of this section." Wording for the signs is also specified. There have been some cases where the OSHA inspectors have taken this to mean signs are required at any location where asbestos is present, regardless of whether or not the exposure limits are exceeded. Although this is clearly incorrect, there has been a tendency to post the signs and not contest the citation. The regulations also require that: "Caution labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material s that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos TTbers in excess of the exposure limits prescribed in paragraph (b) of this section will be released." Wording for these labels is also specified. CTC008568 UCC 015071 A 2 4134 -5- AIRBORNE ASBESTOS FIBER COUNTS Introduction This section presents air sampling data obtained in a variety of situations, mostly for typical industrial operations. All samples were collected on Mi Hipore filters and counted at 400X with phase contrast illumination in accordance with OSHA procedures. Particles which satisfied the L/D >3 criteria but which, in the judgment of an experienced counter, could not possibly be asbestos were not included in the counts. Presentation of Data Table I shows "Calidria" asbestos RG-244 fiber counts obtained at 8 different polyester manufacturing plants. Typically, several hundred pounds of RG-244 are dumped into the thin tank in a 10-25 minute period. These samples obtained during the dumping operation thus represent ceiling concen trations. They would normally be averaged with considerably lower numbers for the remainder of the shift when asbestos is not being handled to arrive at the TWA. The highest fiber count found at these eight locations was 2.8 fibers/cc which is well below the allowable limit of 10 fibers/cc. Table II shows the fiber counts at three of the same manufacturing locations at the empty bag collection point. These values are also quite low. Table III shows airborne fiber counts for "small-scale" addition of RG-244 as occurs in a variety of compounding operations. The levels found ranged from 0.4 to 2 fibers/cc. Table IV shows the airborne asbestos fiber count data obtained i during the spraying of a variety of asbestos containing resins. Much of the data are for polyester resins, but epoxies and alkyds are also included. The asbestos content of the resins ranged from 0 to 12% by weight. The highest count obtained was 0.6 fiber/cc. Polyester resin parts are often finished by sanding or grinding. Table V shows the airborne asbestos fiber counts obtained during a number of industrial finishing operations on resins with up to^3% asbestos. The highest reading obtained here was 0.4 fiber/cc. Table VI gives the results for a laboratory study where resin plaques containing a variety of fillers were abraided with an electric hand grinder in a small closed room. Even under these extreme conditions, the fiber counts were quite low with 1.2 fibers/cc, the highest observed. i CTC008569 03b UCC 015072 C>1 *4 \ AIRBORNE ASBESTOS FIBER COUNTS*1*"LARGE-SCALE- DUMPING OF RG-244 (-*100-450 lb./Batch) PI ant A B C Oata Reference -- 1929-46-2 1929-30-2 D 1929-56-1 E 1929-50-3 F 1929-26-3 6 1929-24-2 H 1929-16-1 - I 2119-8-9 J 2119-6-23 K 2119-12-9 Description of Operation Dump Sample Bags Time Time Dumped (Min.) (Min.) 10 10 10 14 9 9 15 21 21 36 12 12 15 8 8 45 20 20 10 24 24 28 15 15 13 8 8 20 10 10 34 72 72 Special Ventilation' ; None None Hood over thin tank opening None None None Hood over mixing area None None None None CEILING Concentratioi Fiber Count (Fibers/cc. >5u) 0.7 1.2 0.7 2.4 0.5 1.6 0.8 2.8 0.4 0.4 0.9 ^All samples collected in the breathing zone of the operator dumping the RG-244. ^Special ventilation refers to dust collection equipment at or near the dumping area that is specifically intended for dust control during the dumping operation. All plants had varying measures of overall building ventilation. Plant A B B 0 Data Reference 1929-40-3 1929-40-5 2119-6-23 TABLE II AIRBORNE ASBESTOS FIBER COUNTS EMPTY BAG REMOVAL Description of Operation Sample taken 3 feet above waste disposal drum for empty bags. (During dumping.) Directly over empty bag stacking area. Taken during dump. Empty bag storage area. Taken during dump as bags were put in. Sample taken during bag disposal and clean up. UCC 015073 Sample Time (Min.) 10 23 24 24 Fiber Count (Fibers/cc. >5u) 0.4 0.6 0.4 0.1 CTC008570 TABLE III AIRBORNE ASBESTOS FIBER COUNTS^ "SMALL-SCALE" DUMPING OF RG-244 (1-25 lbs./Batch) . End Use Pounds Dumped Dump Time (Min.) Sample Time (Min.) Special /\ Ventilation^' Ceiling Concentration Fiber Count (Fibers/cc >5u) Furniture Molding n ii MH i ii 1 10 10 None 12 2.5 2.5 None 1 11 11 None 6 8 8 Good Hood 1.5 1.1 2.0 0.9 Gel Coat Mfg. it ii n 9 25 25 333 None None 0.7 1.2 Artificial Brick Mfg. H ti H 5 1.5 4 10 4 10 Good Hood 0.9 0.4 Roof Coating Mfg. 12 13 13 None 1.1 Gel Coat Polyester Epoxy H 3el Coat >utty N 10.5 13 13 None 25 11 11 Outdoors 6.3 41 6.3 39 41 39 None None 20 ' 10 10 None 20 35 35 Exhaust Fan 20 34 34 Exhaust Fan 0.3 -l 1.0 2.0 0.6* . 2.1 0.2 ` >ealant iaulking Compound ii H 'atching Compound 15 6 6 3.3 19 3 11 10 19 3 11 10 None None None None r\ CO vd~ C4 i 0.2 0.5 0.2 0.7 ^All samples collected in the breathing zone of the operator dumping the RG-244. 2) . . 'Special ventilation refers to dust collection equipment at or near the dumping area that is specifically intended for dust control during the dumping operation. All plants had varying measures of overall building ventilation. * Sample taken during dump and bag disposal. CTC008571 UCC 015074 TABLE IV AIRBORNE ASBESTOS FIBER COUNTS - spraying of resin based systems containing asbestos Sample leslanatlon Commercial Application Date t - POLYESTER RESINS A. General Purpose laminating Resins 9 Boat manufacture. 12/7/72 Binder General purpose laminating resin. Approx-^ Imate Ht. 5 Asbestos Spray Gun Type Operation O.S Air-supported Operator spraying chopper. molds with resin A chopped glass. Sample Time Win.) Airborne Asbestos Fiber Concentration (Fibers/cc >J 24 0.6 1-13 N-28 N-30 11 10/31/74 a a O.S a 0.S a O.S a Operator spraying resin A chopped fiber glass. (Includes roll-out time.) Operator spraying resin A chopped fiber glass. Operator spraying resin A chopped fiber glass. 16 5 4 0.1 0.4 0.4 N-34 II 10/8/74 . - a 40 i-(2 a m II a a a B. Chemical Resistant Resins J-21 Fiber-glass pipe manufacture. 7 8/13/74 Chemical resistant resin. H-26 a a 0.5 a O.S a 0.5 a i 1.4 Airless. 1.4 a Operator spraying mold with resin. (No glass.) a a 55 0 53 0.03 35 0.1 Operator adjacent to automatic spray machine coating 28' mandrels. Operator wiping mandrels. In area near spraying. 23 0.1 14 0.4 J-5 Ship coating. 10/3/74 Chemical 0.7 Air-supported Roll-out man. In 65 0.4 resistant wand. spraying area about resin + chopped 1/4 of time. fiber glass. J-7 H aa 0.7 a Operator spraying 41 0.4 ship hull In dry dock. N-28 II a a 0.7 a n 23 0 ^ Based on total formulation as sprayed. CTC008572 A24 138 UCC 015075 TABLE IV (continued) AIRBORNE ASBESTOS FIBER COUNTS SPRAYING OF RESIN BASED SYSTEMS CONTAINING ASBESTOS Sample Designation Coamerclal Application II - EPOXY RESINS A. Filled Epoxy K-8 Ship coating. Date 10/2/74 K.-10 M>10 ' 1-27 J-l ft Binder Approx-^ ^ Imate Wt. % Asbestos Spray Gun Type Epoxy primer. ft High build epoxy. ft ft 1.5 Airless. 1.5 a 0 Air supported. 0 ft 0 ft Operation Operator spraying outside A under a ship. ft Operator spraying side of ship from scaffold. ft ft Sample Time (Hln.l x) Airborne Asbestos Fiber Concentration (Flbers/cc >5>) 33 8 31 14 60 0.2 0.2 0.1 0.3 0.03 B. Epoxy - Coal Tar IMS Coating dry dock. 10/1/74 M-l m ft K-3 Coating pipe ft interiors. Epoxy Coal-tar; solvent. ft ft 1 1 1 III > ALKYD RESIN PAINT H-7 Painting 10/6/74 building exterior N-35 ft Alkyd resin. ft 12 12 Airless. ft Air-supported wand. Operator spraying side of dry dock from suspended platform. Operator spraying side of dry dock from fixed scaffold. Operator spraying Interior of 3", 6" and 12" diameter pipe. Airless gun. ft Operator spraying building exterior wail. ft 11 38 37 9 S 0.2 0 0.1 0 0.06 0) Based on total formulation as sprayed. CTC008573 UCC 015076 CD CO C>* TABLE V AIRBORNE ASBESTOS FIBER COUNTS - c GRINOING AND SANDING OF RCS1N-BASEP SYSTEMS 1CONTAINING ASBESTOS Sanple Designation Commercial Application I. THERMCSET RESIN (Polyester) -- Molding furniture parts Date 3/15/72 Resin Polyester a 1929-40-4 N 12/6/72 a 1929-82-3 1929-82-4 1929-82-5 1-13 Fabrication of reinforced fiber glass pipe. II c ....1-6 n 1-26 G-8 Fabrication of FRP tanks and pipe. 1-39 m 2/27/73 Polyester a m 8/13/74 a a a ma 8/13/74 Polyester a a 1929-84-4 1929-84-5 Production of artificial bricks. N-20 N-25 Production of fiber glass boats. m 3/8/73 a Polyester a 11/26/74 a Polyester a Asbestos Approx, JXB* Wt. X Ooeratlon Sample Time (Min.) Airborne Astestos Fiber Concentration (Flbers/cc >L) RG-244 a 0.05 0.05 a 0.3 RG-144 2-3 a a RG-244 2-3 2-3 1.4 a 1.4 RG-244 a a 1.5 1.5 1.5 RG-244 a 2.0 2.0 Operator hand sanding small parts. Operator running power sender with Integral hood. Operator sanding and grinding molded parts. Good hood & ventilating system on grinder. 45 45 23 Operator pulls pipe along line. Saws off end with circular saw. 19 Same operation as 1929 82-3. 49 Operator removing end of 45 pipe with scarfing machine Operator shaping end of pipe with bell & spigot machine. Operator cutting off pipe end and light qrlndlng on exterior surface. 16 17 Operator grinding Inside of 13' 1.0. x 26* tank. Continuation of same operation as 1-26. Operator grinding edges of miscellaneous small parts. 16 5 25 Operator cutting with sabre saw. Operator trlmnlng with sabre saw. 44 39 RG-244 a 0.5 0.5 Operator grinding Inside of boat hull. Operator grinding. 11 4 0.002 0.002 0.3 0.1 0.1 0.04 0.3 0.2 0.4 0.3 0.3 0.1 0.2 0.0 0.0 CTC008574 UCC 015077 fl24 14C | ro -*> 4^ < o-X) _J v< lfD/l rfDt-* o o *C(</D> fD" "oO fCD<O rfDt- ~5 T.moX<3 o-v <CfD<O -cfD?+ o"O *tf<Do rfDt- T2 O mmmS fCD<O rfDt> "5 "O o hJ <VfD<O rfDt- -% a <D 70 fVD* CO O o CO c n o CcOn o c n o VP 05 o vo 0 0 o VvOo ro >v o4 ro rt* cn oi ro oO 20 75 a1 J o C7D0 1 o C2D0 _1 i 4k C2D0 r41ok -e* C2D0 r1o C2D0 r1o 44kk 2CD0 4r41okk r>f~D<oi O 3" ,>(Q-/5<> laOcfDf 0 0 o cn 4k ro O O rtft* -fD* o3Ooo o o o O O o 00 00 CO . . ro 1 o o o | ooo i 1 ro o o s<+ C0l--/>D** D* cn .. cn ro o o ooo 1 1 i 1 i rt- Ui 0> cn o CcOn o o x: & r- rt- rOtDftf3D -3fD* OO co O oo at IN5 >J o O O o DwQ(3--DlJ WO3f-0--oDJ>"o10O"frODJt co-5 l3O CD 3* of--O3Dss ' oo VO o o o o Oo230 ~cfnnfoOm3cmnfd 3a. *>o Oof-3DS rff<DD-J fD -O3-Sh 2 3 ^--bi3. o>\f"tODo5* toCfrDotOoo *n cNin ofDr* 4'' o ocn o o o o pg o con o o o o o o o 2Oo0 3 o-3OS cn GO m O3f c fOmmd <rfD- fD --sh -C5D 3Q. ^OVO 3-rf"D5thk- --'CO3frrO3-oD5Dtt>-- f*DS fmDmJ O3 2 _a. 3 ala 3o 7g0d o cd 7mcn0 CO X00 X00 cn oocmn tooo UCC 015078 o o o o 0cn0 cn LITERATURE AND REGULATIONS A24 1 42 UCC 015079 What You < Should Know About Asbestos And Health A24J43 UCC 015080 1 fc O) to ~o c c o CO I ca o ^ ^ > TJ P 04- .2 > "O 4O -X C0 CO ".O o -2 o t0o X) 0 f 0 o> c 3 a) _XcJ -c co *--obb -ocJa-r CCOD O"*= *J~oO- b 3-- 0 T3 .E 0 V 000 r o 5 c0>0 00 ^m --0 X0) 000 -0C b 0 a> (O i-4(0 CO CO o *- O) ctao 0>pc x: .b C- c0o --<D CL 0 3 0 0c)"c0 b 0g8 i5s CO o aU>- o E c>ds -4o-4 CO .S O OijO E-o~ g0o -c i- 3 0 +2 "O |ScE CO Ecoa ^-or- R -* 0 rao c 0) .CaD CQD_ ca c o Cud ^0O o> c '5 5 O) O i; 0D --c X0I ^3 c0 0 S 2 co** a> a> CO 0) CO <oC-O4 nCCOD ca o ca 51= c CO cccood --xb$: CO T3 3 to co .b 5 oQ-cra XR x CD CO LLI O C0 .E ca co c o v_ WO0 CoD u. 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' - - \ v > NORTH AMERICA ASBESTOS INFORMATION ASSOCIATION 1745 Jefferson Davis Highway, Arlington, Virginia 22202 s O UCC 015086 A 2 4 H9 Title 29--LABOR Chapter XVII--Occupational Safety and Health Administration, Depart ment of Labor PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS Standard for Exposure to Asbestos Dust On December 7, 1971, an emergency temporary standard concerning exposure to asbestos libers was published in the Federal Recister (36 F.R. 23207). In ac cordance with section 6<c) (3) of the Williams-Stciger Occupational Safety and Health Act of 1070. a notice of proposed rulemaking regarding a permanent standard for exposure to asbestos fibers was published in the Federal Register on January 12. 1972 (37 F.R. 466). The no tice invited interested persons to submit both orally and in writing, data, view's, and arguments concerning the proposal. On or about January 24, 1972. the Ad visory Committee ou Asbestos Dust was established and requested to make w*ritten recommendations with regard to the proposed standard on asbestos. On or about February 1, 1972, the Department of Health, Education, and Welfare tranr mltted to the Secretary of Labor a cri teria document containing Recommenda NOTE: The preamble to the "permanent" asbestos stan dard, issued June 7, 1972, is reproduced for informa tion. It was not included in the republication of the standard on June 27, 1974, but directly relates, pro viding background consider ations for OSHA's exposure to asbestos dust ^regulation. RULES AND REGULATIONS 11318 tions for an Occupational Exposure exposure to asbestos fibers and the ap Standard for Asbestos by the National pearance of adverse biolocical manifes Institute for Occupational Safety and tations, such as asbestosis, lung cancers, Health (NIOSII). Public notice was riven and vncsothclioma. have given rise to of the receipt of the recommendations controversy as to the validity of the and their availability for inspection and measuring techniques used and the relia copying. On or about February 25. 1972. bility of the relations attempted to be the Advisory Committee on Asbestos Dust established. Because of the long lapse submitted its written recommendations of time between onset of exposure and to the Assistant Secretary of Labor for biological manifestations, w*e have now* Occupational Safety and Health. evidence of the consequences of exposure, Pursuant to the notice of rule making, but w*c do not have, in ccncral. accurate a hearing was held on March 14 through measures of the levels of exposure oc 17, 1972. for the purpose of receiving oral curring 20 or 30 years ago. which have data, views, and arguments concerning given rise to these consequences. There the proposed standard. On or about arc also controversies concerning the March 31.1972, the presiding hearing ex relative toxicity of the various kinds of aminer certified to the Assistant Secre asbestos, and varyine hazards in dif tary of Labor for Occupational Safety ferent workplaces. and Health the record of the proceeding. It is fair to say that the controversy The record includes prehearing written has centered in the area between a two- comments, a transcript of the oral pres fiber TWA concentration and five-fiber entations made at the hearing, and nu TWA concentration, with variations on merous exhibits received during the the time.needed for compliance. Many course of the hearing or within the pe employers support a five-fiber TWA. riod allowed after the close of the Most medical opinion is divided betwreen hearing. .a two-fiber standard and a five-fiber The proposed standard dealt with (1) standard. permissible concentrations of asbestos In view of the undisputed grave con fibers: (2) methods of compliance; (3) sequences from exposure to asbestos warning signs; (4) monitoring: (5) med fibers, it is essential that the exposure be ical examinations; and (6) recordkeep regulated now, on the basis of the best ing. Each of these major proposals elic evidence, available now, even though it ited comments, arguments, objections, may not be as good as scientifically de and counterproposals. They all have been sirable. An asbestos standard can be re examined and considered. evaluated in the light of the results of 1. Acceptable concentrations of asbes ongoing studies, and future studies, but tos dust. The proposed standard would cannot wait for them. Lives of employees limit occupational exposure to 8-hour are at stake. time-weighted average (TWA) airborne It is concluded that there should be concentrations of asbestos dust not ex one minimum standard of exposure to ceeding five fibers longer than five asbestos applicable to all workplaces ex micrometers per milliliter. Concentra posed to any kind, or mixture of kinds, tions above five fibers but not to exceed of asbestos. Reasons of practical ad 10 fibers (ceiling concentration) w'ould ministration preclude a variety of stand be permitted up to 15 minutes in an hour, ards for different kinds of asbestos and but for not more than 5 hours in any one of workplaces. Also, while the evidence 8-hour day. * tends to show that crocidolite. for in NIOSH in effect has recommenued stance. is more harmful thun chrysotile, that the five-fiber TWA and 10-fiber the evidence Is not sufficient to establish peak concentrations be permitted only separate standards for varieties of for 2 years: thereafter, TWA concentra asbestos. tions should be not more than 2 fibers Because there must be one standard per cubic centimeter (cm.*) of air, and governing exposure to all varieties of peak concentrations should not exceed 10 asbestos, and in workplaces apparently fibers/cm.*, with no time restriction. more hazardous than others; because Numerous objections and counterpro some present employees with regular ex posals have been made, with regard to posure to asbestos have probably al both the limits of asbestos fiber concen ready accumulated great doses of asbes trations and the time periods to comply tos fibers, due to higher levels of ex with them. Some, for example, have rec posure in the past; because it appears ommended return to a 12-fibcr standard that levels of exposure which may be of an earlier day; i,e., a level adopted safe with regard to asbestosis are not under the Walsh-Hcaley Public Con safe with regard to mesothelioma: be tracts Act in I960..Others have recom cause the statute requires the protection mended a two-liber standard to become of every employee, even of one v ho may effective in 8 months, then a one-fiber have regular exposure to asbestos during standard for 2 years, and finally a zero- a working life which may reach, or even fiber standard after 3 years. These rec exceed. 40 years; and because of several ommendations give a fair indication of other considerations which have been the wide spread of the counterproposals. urged and are reflected in the record of No one has disputed that exposure to the proceeding, the conflict in the medi asbestos of high enough intensity and cal evidence is resolved in favor of the long enough duration is causally related health of employees. As of July 1. 1976, to asbestosis and cancers. The dispute is TWA concentrations of asbestos fibers as to the determination of a specific level longer than 5 micrometers will not be below which exposure is safe. Various allowed to exceed two liber? cc.. with a studies attempting to establish quantita ceiling value of 10 fibers cc. The current tive relations between specific levels of TWA concentrations of five fibers, and CTC008584 FCOttAl REGISTfl, VOl. 37. NO. 110--WEDNESDAY, JUNE 7, 1972 UCC 015087 _, A 4 1 5C RULES AND REGULATIONS 11319 cr'.linfT concentrations of 10 flbers/cc, fibers, so that these would not be released 6. Records. The standard, as proposed will be permitted until July 1. 197G, dur- in the normal use of the products, should and a< adopted, requires maintenance of . Inc what will be a transitional period not be required to be labeled; and (2) records of monitoring and of medical deemed necessary to allow employers to words such as "danger*' and "cancer" are examinations. Most of the controversy Ih make the reeded changes for coming unwarrantcdly alarming. . this area has revolved around the ques into compliance with the more stringent Both contentions have merit, and the tion whether on employer should be al standard. standard has been changed accordingly. lowed to have access to the results of The record shows that the many work 4. Monitoring. The proposed standard the required medical examinations. The operations subject to the single asbestos would have required personal monitor apprehension of those who have argued standard (textile, manufacturing, indus ing and environmental monitoring. against employer access is based on the trial. and marine Installation, etc.) will Many issues have been raised concerning expectation that some employers will use meet .varying degrees of difficulty in the availability and reliability of meas the medical examinations as a means of complying with the standard. In some uring instruments, frequency of moni screening employment applicants, and plant.?, extensive redesign and reloca toring. and conditions in which monitor worse, as grounds for discharging current tion of equipment may be needed. It ap ing should be required. The adopted employees, who show signs of being af pears. however, the delay in the effective standard takes the objections into con fected by c\|K>sure to asbestos. Since the date of the two-fiber standard will pro sideration. It requires periodic monitor purpose of the medical examinations is vide all employers a reasonable time to ing at intervals no longer than 6 months, to monitor the health of employees ex comply. At the same time, so long as the thus allowing considerable time and dis posed to the hazards of abestos, em ceiling limit is complied with, no harm cretion, and prescribes the use of the ployees cannot in reason be granted the is reasonably expected to result from ex membrane filter method, which is an ac privilege of refusing to disclose to their posures dunng the transitional period. ceptable method for determination of employers results of occupational expo 2. Methods of compliance. It has been asbestos fibers. sure. It docs not make sense to require pointed out by many persons, that pro It has also been recommended that employers to provide medical examina tection against asbestos fibers is best employees or their representatives should tions if they cannot know and use the obtained by controlling the generation of have an opportunity to observe the results of the examinations. For these fibers first, and secondly, by controlling monitoring. The recommendation has reasons the standard provides that em the dispersion of released fibers into the been accepted. ployers may have a restricted access to ambient air of the workplaces. Therefore, the standard requires feasible techno . logical controls and appropriate work practices as the primary means of com pliance. Rotation of employees as a wfay of meeting the TWA concentration re quirement is allowed only in stated ex ceptional circumstances, because, as a general rule, it would be difficult to im plement. Personal protective equipment, such as respirators, cannot be relied upon because, among other reasons, they may be so uncomfortable as to be bur densome, except for short periods of time. Therefore, it is expected that res pirators and shift rotation will be used during the period necessary to install en gineering controls and to train employ ees in sound work practices, but, after technological compliance has been achieved, their use must be limited to special work situations and emergencies. Where both are practicable, shift rota tion is requires. 3. Labeling. The proposed standard stopped short of requiring labeling as bestos and asbestos-containing products. The proi>oscd standard would have re 5. Medical examinations. The pro some medical information. posed standard would only require an* appropriate medical examination on a' On the other hand, there is no Inten tion to allow employers to abuse medical periodic basis. The generality of the pro**" posal has attracted many objections and information obtained pursuant to the Act. to the detriment of employees. also many helpful comments. The recom mendations of NIOSH and of the Advi Therefore, the administration of the medical records requirement will be sory Committee on Asbestos Dust were closely watched, and. in cases of abuse, much more specific with respect to both appropriate action will be considered. frequency and type of medical examina tions to be required. The comments vary os to the class of employees to be ex amined and as to the frequency of the examinations. . The issues discussed above are believed to be the major ones. Numerous other is sues have been raised in the rulemaking proceedings. Some have been referred to incidentally. Many recommendations, for The adopted standard requires medical examinations both at the beginning and instance, about work practices, are so obviously meritorious that their adop the termination of employments exposed to concentrations of asbestos fibers, and also requires annual medical examina tion needs no exposition here. Other recommendations and many objections hr.ve not been adopted for a variety of tions of every employee exposed to air borne concentrations of asbestos. It has been pointed out that in certain indus tries, such as construction, an employee reasons wliich should be manifest. Sev eral. for instance, have recommended the use of respirators only pursuant to a variance, or in cases of emergency and may work for several employers during the same year. Accordingly, the standard does not require either preemployment, occasional short-term exposures. The recommendation with respect to vari or termination, or periodic examinaton ances undoubtedly has many merits, of any employee who has been examined but is considered administratively Im quired oniy warning signs at locations in accordance with the standard within practical. * where asbestos hazards are present. the past year. ' However, labeling, rather than warning One question which has been raised siens, has proved to be a point of con goes to whether the employer or the em troversy. Both NIOSH and the Advisory ployee should be allowed to choose the Committee on Asbestos Dust recom examining physician. The standard mended labels for asbestos products and gives the option to the employer. Since containers, and these recommendations some employers already have a medical became very controversial in the course examination program in operation, and, of the proceeding. Many countcrpro- also, have medical departments with proposals have been made as to the lan some expertise in the diagnosis of abes- guage of the warning as well as to the tos-related diseases, it seems more products to be subject to the labeling reasonable to permit them to utilize the o ' requirements. Employers, in general, present procrams and expertise, than to strongly contend that (1) finished prod permit an employee to choose a private ucts which effectively entrap asbestos general practitioner. to * SgS. ) CTC008585 FEDERAL RCGI'TK, VOL 37, NO. 110--WEDNESDAY, JUNE 7, 1*71 UCC 015088 1910.1001 Title 29--Labor * Title 29 Code of Federal Regulations Parts 1900 to 1919 Revised as of July 1, 1979 1910.1001 Asbestos. - <a> Definitions. For the purpose of this section. (1) "Asbestos" includes chrysotile. amosite. crocidolitc, tremolite, anthophyllite, and actinolite. (2) "Asbestos fibers" means asbestos fibers longer than 5 micrometers. (b)Permissible exposure to airborne concentrations of asbestos fibers--{1) Standard effective July 7. 1072. The 8hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed five fibers, longer than 5 micrometers, per cubic centi meter ol air. as determined b> the method prescribed in paragraph (e) of this section. (2> Standard effective July 1, 1976. The 8-hour time-weighted average air borne concentrations ol asbestos fibers to a Inch any employee ma> be cxposed shall not exceed two fibers. / UCC 015089 CTC008586 CTC008587 Chapter XVII--Occupational Safety and Health Administration 1910.1001 longer than 5 micrometers, per cubic moved from bags, cartons, or other centimeter of air. as determined by containers in which they are shipped, the method prescribed in paragraph without being cither wetted, or en (e) of this section. closed. or ventilated so as to prevent (3) Ceiling concentration. No em effectively the release of airborne as ployee shall be exposed at any time to bestos fibers in excess of the limits airborne concentrations of: asbestos prescribed in paragraph (b) of this sec fibers in excess of 10 fibers, longer tion. than 5 micrometers, per cubic centi (iii)Spraying, demolition, or remov meter of air, as determined by the al. Employees engaged in the spraying method prescribed in paragraph (e) of of asbestos, the removal, or demolition this section. of pipes, structures, or equipment cov (c) Methods of compliance--i\) Engi ered or insulated with asbestos, and in neering methods, (i) Engineering con the removal or demolition of asbestos trols. Engineering controls, such as, insulation .or coverings shall be pro but not limited to, isolation, enclosure, vided with respiratory equipment in exhaust ventilation, and dust' collec accordance with paragraph (d)(2)(iii) tion, shall be used to meet the expo of this section and with special cloth sure limits prescribed in paragraph (b) ing in accordance with paragraph of this section. (d)(3) of this section. (ii) Local exhaust ventilation, (a) (d) Personal protective equipment-- Local exhaust ventilation and dust col (1) Compliance with the exposure lection systems shall be designed, con limits prescribed by paragraph (b) of structed, installed, and maintained in. this section may not be achieved by accordance with the American Nation the use of respirators or shift rotation al Standard Fundamentals Governing of employees, except: the Design and Operation of Local Ex (1) During the time period necessary haust Systems, ANSI Z9.2-1971, which to install the engineering controls and is incorporated by reference herein. to institute the work practices re Cb) See 1910.6 concerning the avail quired by paragraph (c) of this sec ability of ANSI Z9.2-1971, and the tion; maintenance of a historic file in con (ii) In work situations in which the nection therewith. The address of the - methods prescribed in paragraph (c) American National Standards Insti of this section are either technically tute is given in 1910.100. not feasible or feasible to an extent in (iii) Particular tools. All hand-oper sufficient to reduce the airborne con ated and power-operated tools which centrations of asbestos fibers below may produce or release asbestos fibers the limits prescribed by paragraph (b) in excess of the exposure limits pre of this section; or scribed in paragraph (b) of this sec (iii) In emergencies. tion, such as, but not limited to, saws, (iv) Where both respirators and per scorers, abrasive .wheels, and drills, sonnel rotation are allowed by para shall be provided with local exhaust graphs (d)(1) (i), (ii), or (iii) of this sec ventilation systems in accordance with tion, and both are practicable, person subdivision (ii) of this subparagraph. nel rotation shall be preferred and (2) Work practices--ii) Wet methods. used. Insofar as practicable, asbestos shall (2) Where a respirator is permitted be handled, mixed, applied, removed, by paragraph (d)(1) of this section, it cut, scored, or otherwise worked in a shall be selected from among those ap wet state sufficient to prevent the proved by the Bureau of Mines. De emission of airborne fibers in excess of partment of the Interior, or the Na the exposure limits prescribed in para tional Institute lor Occupational graph (b) of this section, unless the Safety and Health, Department of usefulness of the product would be di Health. Education, and Welfare, under minished thereby. the provisions of 30 CFR Part 11 (37 (ii) Particular products and oper F.R. 6244, Mar. 25, 1972), and shall be ations. No asbestos cement, mortar, used in accordance with subdivisions coating, grout, plaster, or similar ma (i), (ii), (iii), and (iv) of this subpara terial containing asbestos shall be re graph. 581 UCC 015090 K ) X. )  1910.1001 Title 29--Labor (i) Air purifying respirators. A reus able? or sinp.lc use air purifying respira tor. or a respirator described in para graphs (d)(2) (ii) or (iii) of this section, shall be used to reduce the concentra tions of airborne asbestos fibers in the respirator below the exposure limits prescribed in paragraph tb) of this sec tion, when the ceiling or the 8-hour time-weighted average airborne con centrations of asbestos fibers are rea sonably expected to exceed no more than 10 times those limits. (ii) Powered air purifying respira tors. A full facepiece powered air puri fying respirator, or a powered air puri fying respirator, or a respirator de scribed in paragraph (d)(2)(iii) of this section, shall be used to reduce the concentrations of airborne asbestos fibers in the respirator below the ex posure limits prescribed in paragraph (b) of this section, when the ceiling or the 8-hour time-weighted average con centrations of asbestos fibers are rea sonably expected to exceed 10 times, but not 100 times, those limits. (iii) Type "C" supplied-air respira tors, continuous flow or pressuredemand class. A type "C" continuous, flow' or pressure-demand, supplied-air respirator shall be used to reduce the concentrations of airborne asbestos fibers in the respirator below the ex posure limits prescribed in paragraph (b) of this section. wrhen the ceiling or the 8-hour tine-weighted average air borne concentrations of asbestos fibers are reasonably expected to exceed 100 times those limits. (iv) Establishment of a respirator program, (a) The employer shall es tablish a respirator program in accord ance w'ith the requirements of the American National Standards Practiers for Respiratory Protection, ANSI Z88.2-1969, which is incorporated by reference herein. (6) See 1910.6 concerning the avail ability of ANSI Z83.2-19G9 and the maintenance of a historic file in con nection therew ith. The address of the American National Standards Insti tute is given in 1910.100. (c) No employee shall be assigned to tasks requiring the use of respirators if, based upon his most recent exami nation, an examining physician deter mines that; the . employee will be unable to function normally wearing a respirator, or that the safety or health of the employee or other employees will be impaired by his use of a respi rator. Such employee shall be rotated to another job or given the opportuni ty to transfer to a different, position whose duties he is able to perform with the same employer, in the same geographical area and with the same seniority, status, and rate of pay he had just prior to such transfer, if such a different position is available. (3) Special clothing: The employer shall provide, and require the use of. special clothing, such as coveralls or similar whole body clothing, head co verings. gloves, and foot coverings for any-employee exposed to airborne con centrations of asbestos fibers, which exceed the ceiling level prescribed in paragraph (b) of this section. (4) Change rooms: (i) At any fixed place of employment exposed to air borne concentrations of asbestos fibers in excess of the exposure limits pre scribed in paragraph (b) of this sec tion, the employer shall provide change rooms for employees working regularly at the place. (ii) Clothes lockers: The employer shall provide two separate lockers or containers for each employee, so sepa rated or isolated as to prevent con tamination of the employee's street clothes from his work clothes. (iii) Laundering: (a) Laundering of asbestos contaminated clothing shall be done so as to prevent the release of air-borne asbestos fibers in excess of the exposure limits prescribed in para graph (b) of this section. (6) Any employer who gives asbes tos-contaminated clothing to another person for laundering shall inform such person of the requirement in paragraph (d)(4)(iii)(a) of this section to effectively prevent the release of airborne asbestos fibers in excess of the exposure limits prescribed in para graph (b) of this section. (c) Contaminated clothing shall be transported in scaled impermeable bags, or other closed, impermeable containers, and labeled in accordance with paragraph (g) of this section. (e) Method of measurement All de terminations of airborne concentra tions of asbestos fibers shall be made 582 CTC008588 UCC 015091 CTC008589 Chaptor XVII--Occupational Safety and Health Administration 1910.1001 by the membrane filter method at quency and pattern as to represent 40C-450 v (magnification) (4 millime with reasonable accuracy the levels of ter objective) with pha.se contrast ill.u* exposure of the employees. In no case mination. shall sampling be at intervals greater (f) Monitoring--(1) Initial determi than 6 months for employees whose nations. Within 6 months of the publi exposures to asbestos may reasonably cation of this section, every employer be foreseen to exceed the exposure shall cause every place of employment limits prescribed in paragraph (b) of where asbestos fibers are released to this section. be monitored in such a way as to de (4) Employee observation of moni termine whether every employee's ex toring. Affected employees, or their posure to asbestos fibers is below the representatives, shall be given a rea limits prescribed in paragraph (b) of sonable opportunity to observe any ' this section. If the limits are exceeded, monitoring required by this paragraph the employer shall immediately under and shall have access to the records* take a compliance program in .accord thereof. ance with paragraph (c) of this sec (g) Caution signs and labels. (1) tion. Caution signs, .i) Posting. Caution (2) Personal monitoring--(i) Sam signs shall be provided and displayed ples shall be collected from within the at each location where airborne con breathing zone of the employees, on centrations of asbestos fibers may be membrane filters of 0.8 micrometer in excess of the exposure limits pre porosity mounted in an open-face scribed in paragraph (b) of this sec filter holder. Samples shall be taken..- tion. Signs shall be posted at such a for the determination of the 3-hour distance from such a location so that time-weighted average airborne con an employee may read the signs and centrations and of the ceiling concen take necessary protective steps before trations of asbestos fibers. entering the area marked by the signs. (ii) Sampling frequency and pat Signs shall be posted at all approaches terns. After the initial determinations required by paragraph (f)(1) of this section, samples shall be of such fre quency 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 than 6 months for employees v/hose exposure to asbestos may rea sonably be foreseen to exceed the limits prescribed by paragraph (b) of this section. (3) Environmental monitoring--ii) to areas containing excessive concen trations of airborne asbestos fibers. (ii) Sign specifications. The warning signs required by paragraph (g)(l)(i) of this section shall conform to the requirements of 20" x 14" vertical format * signs specified in 1910.145(d)(4), and to this subdivi sion. The signs shall display the fol-. lowing legend in the lower panel, with letter sizes and styles of a visibility at least equal to that specified in this subdivision. Samples shall be collected from areas Legend Notation of a work environment which are rep Asbestos............... ......... ....... .......... 1" Sans Sent, Gothic or resentative of the airborne concentra tions of asbestos fibers which may reach the breathing zone of employ Block. Oust Hazard-------------------------------- %" Sans Sent. Gothic or Block. Avoid Breathing Oust........................ Y~ Gothic ees. Samples shall be collected on a Wear Assigned Protective '/" Gothic. membrane filter of 0.8 micrometer po rosity mounted in an open-face filter Equipment. Oo Not ftom.nn in Area Unless Your Yvork Requires It. * */" Gothic. holder. Samples shall be taken for the Breathing Asbestos Dust May Be *4 point Gothic. determination of the 3-hour time- Hazardous To Your Health. weighted average airborne concentra Spacing between lines shall be at least ^ tions and of the ceiling concentrations equal to the height of the upper of .p of asbestos fibers. any two lines. ^ (ii) Sampling frequency and pat (2) Caution labels--(i) Labeling. Cau terns. After the initial determinations tion labels shall be affixed to all raw ^ required by paragraph (f)(1) of this materials, mixtures, scrap, waste, section, samples shall be of such fre debris, and other products containing 40-073 0-79------IS 583 UCC 015092 ) * \  1910.1001 Title 29--Labor asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material so that during any rea sonably foreseeable use, handling, storage, disposal, processing, or trans portation, no airborne concentrations of asbestos fibers in excess of the ex posure limits prescribed in paragraph (b) of this section will be released. (ii) Label specifications. The caution labels required by paragraph (g)(2)(i) of this section shall be printed in let ters of sufficient size and contrast as to be readily visible and legible. The label shall state: Caution Contains Asbestos Fibers Avoid Creating Dust Breathing Asbestos Dust May Cause Serious Bodily Harm (h) Housekeeping--(1) Cleaning. All external surfaces in any place of em ployment shall be maintained free of accumulations of asbestos fibers if, with their dispersion, there would be an excessive concentration. , (2) Waste disposal Asbestos Waste, scrap, debris, bags, containers, equip ment, and asbestos-contaminated clothing, consigned for disposal, which may produce in any reasonably fore seeable use, handling, storage, process ing, disposal, or transportation air borne concentrations of asbestos fibers in excess of the exposure limits pre scribed in paragraph (b) of this section shall be collected and disposed of in sealed impermeable bags, or other closed, impermeable containers. (i) Recordkeeping--(1) Exposure rec ords. Every employer shall maintain records of any personal or environ mental monitoring required by this section. Recmds shall be maintained for a period of at least 20 years and shall be made, available upon request to the Assistant Secretary of Labor for Occupational Safety and Health, the Director of the National Institute for Occupational Safety and Health, and to authorized representatives of either. (2) Employee access. Every employee and former employee shall have rea sonable access to any record required to be maintained by .paragraph (i)(l) of this section, whibh indicates the employee's own exposure to asbestos fibers. (3) Employee notification. Any em ployee found to have been exposed at any time to airborne concentrations of asbestos fibers in excess of the limits prescribed in paragraph (b) of this sec tion shall be notified in writing of the exposure as soon as practicable but not later than 5 days of the finding. The employee shall also be timely no tified of the corrective action being taken. (j) Medical examinations--(1) Gen eral The employer shall provide or make available at his cost, medical ex aminations relative to exposure to as bestos required by this paragraph. (2) Preplacement. The employer shall provide or make available to each of his employees, within 30 calen dar days following his first employ ment in an occupation exposed to air borne concentrations of asbestos fibers, a comprehensive medical exam ination, which shall include, as a mini mum, a chest roentgenogram (posteri or-anterior 14 x 17 inches), a history to elicit symptomatology of respira tory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEV,.0). . (3) Annual examinations. On or before January 31, 1073, and at least annually thereafter, every employer shall provide, or make available, com prehensive medical examinations to each of liis employees engaged in occu pations exposed to airborne concentra tions oi asbestos fibers. Such annual examination shall include, as a mini mum, a chest roentgenogram (posteri or-anterior 14 x 17 inches), a history to elicit symptomatology- of respira tory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second O*'i:!V..0). (4) Termination of employment. The employer shall provide, or make avail able, within 30 calendar days before or after the termination of employment of any employee* engaged in an occu pation exposed to airborne concentra tions of asbestos fibers, a comprehen sive medical examination which shall 584 4:5b CTC008590 UCC 015093 Chaptor XVII--Occupational Safety and Health Administration include, as a minimum, a chest roent- gei.ogram (posterior-anterior 14 x 17 inches), a' history to elicit symptoma tology of respiratory disease, and pul monary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (PEV,..). . (5) Recent examinations. No medical examination is required of any em ployee. if adequate records show that the employee has been examined in accordance with this paragraph within the past 1-year period. 78 (6) Medical records--(i) Mainte nance. Employers of employees exam ined pursuant to this paragraph shall catise to be maintained complete and accurate records of all such medical examinations. Records shall, be re tained by employers for at least 20 years. (ii) Access. The contents of the rec ords of the* medical examinations re quired by this paragraph shall be made available, for inspection and copying, to the Assistant Secretary of Labor for Occupational Safety and 1919.19 Special provisions for air con taminants. (a) Asbestos dust. Section 1910.1001 shall apply to the exposure of every employee to asbestos dust in every em ployment and place of employment covered by 1910.12, 1910.13, 1910.14, 1910.15. or 1910.16, in lieu of any dif ferent standard on exposure to asbes tos dust which would otherwise be ap plicable by virtue of any of those seetions. Health, the Director of NIOSH, to au thorized physicians and medical con Note: Following defines sultants of either the request of an of them, and. upon employee or former additional occupational employee, to his physician. Any physi areas affected.by section cian who conducts a medical examina 1910.19 above: tion required by this paragraph shall furnish to the employer of the exam ined employee all the information spe 1910.12 - Construction cifically required by this paragraph, and any other medical information re lated to occupational exposure to as bestos fibers. Work (construction, alteration, and/or repair, in 129 FR 23502. June 27. li>74. Redesignated at 40 FR 27;)73. May 28. 1975. and amended cluding painting and decorating) at 41 FR 11C05. Mar. 19. 19761 ' 1910.13 - Ship repairing 1910.14 - Shipbuilding 1910.15 - Shipbreaking 1910.16 - Longshoring CTC008591 585 UCC 015094 co to CM ASBESTOS AND HEALTH Asbestos, used since antiquity, has widespread and important applications in our modern technological society. Approximately 3,000 different products containing asbestos are in daily use throughout the world. Its increased use in the 20th century has lent urgency to the need to cope with occupational health problems related to the excessive inhalation of asbestos dust. Such problems are not unique to the asbestos industry. Many substances and materials in common use today can be detrimental to the health and safety of industrial workers under uncontrolled conditions. A vital and widely used raw material, asbestos is but one of a number of potentially harmful substances used by industry. Basically, the known facts about asbestos-related disease can be summed up as follows: First, asbestos-related health risks today are almost exclusively confined to the occupational setting. Second, the effects of excessive inhalation of asbestos are both time and dose related. This means that asbestos-related diseases may develop, generally, only after the inhalation of substantial amounts of asbestos dust over a substantial period of time. Thus, there are levels of exposure that will not result in any increased risk of disease. Third, there is presently no evidence of risk to the general public from exposure to the minute amounts of asbestos that have been found in community air. Fourth, because of the long latent period of asbestos-related disease, the disease being found today among some long-term industry employees is not an indication of present day condi tions, but is a result of conditions existing decades ago, at a time when neither the industry, government, or the medical profession knew very much about the health effects of asbestos and even less about the proper means for their control. These facts are well recognized by the asbestos manufacturing industry, which has made substantial progress over the years in protecting those who work with asbestos and in eliminating emissions of free asbestos fiber into the community air. Known and Suspected Occupational Risks There are three primary diseases known to be caused or exacerbated by prolonged and heavy inhalation of asbestos fibers. They are asbestosis, bronchogenic (lung) cancer, and mesothelioma. Prolonged heavy exposure does not necessarily result in disease and death-- but there is little question that risks are significantly increased. Asbestosis This is an occupational disease characterized by lung scarring, and is one of the lung diseases called pneumoconioses. It is the most common of the three asbestos related illnesses and is found only among those who have worked regularly and continuously with asbestos under inadequately controlled conditions. The average time span from first exposure to the first clinical signs of asbestosis is 17 years, although some cases have been reported in as few as ten years. Asbestosis is neither malignant nor necessarily fatal. Many asbestos workers with minor cases can and do continue to work and lead normal lives without difficulties. The asbestos i $ 4 ? fjy y CTC008592 UCC 015095 industry has long recognized the risk of this disease and has implemented safeguards to protect workers' health. As far as can be determined, asbestosis never has been found in the general public, even amongpeople living in close proximity to asbestos mines and processing plants. Bronchogenic (Lung) Cancer A number of medical studies have linked heavy asbestos exposure'with an increased risk of lung cancer. While lung cancer occurs far less frequently among asbestos industry workers than asbestosis does, under some circumstances ,it occurs more frequently than in the general population. As with asbestosis, the amount of fiber to which an employee is exposed is an important factor in lung cancer development. A continuing study of workers in a British asbestos textile plant has shown that dust control measures, which had substantially reduced the incidence of asbestosis, also reduced the incidence of lung cancer among the workers to that existing in the general public. In addition, it is the considered opinion of many scientists that lung cancer will not develop in an employee if he did not first have asbestosis. Unquestionably, factors other than heavy asbestos exposure are important in the causa tion of lung cancer among asbestos industry workmen. The most documented example is cigarette smoking. Studies conducted of as many as 17,500 asbestos insulation workers show that those who smoke have a much greater risk of contracting lung cancer than non-smokers in the general public, but that those asbestos industry workmen who do not now smoke cigarettes and who have never smoked regularly, have no greater risk of lung cancer than the average man-in-the-street who does not smoke. Mesothelioma This disease is an extremely rare cancer of the lining of the chest (pleura) or the abdomi nal cavity (peritoneum). It is found more frequently among those with occupational asbes tos exposure than among the general population. It also has been found among people who, in the past, lived in close proximity to uncontrolled crocidolite asbestos plants or mines, and even, on rare occasions, in the households of employees who worked in crocidolite asbestos factories or mines and who presumably brought substantial quantities of this particular type of asbestos fiber into their homes on their work clothes. This has not been found to be the case with individuals exposed only to chrysotile asbestos, which accounts for 97% of the asbestos fiber used in the U.S. today. Since the latent period for mesothelioma ranges from 30 to 45 years, it is impossible at this late date to determine precisely the exposure levels experienced by these "neighbor hood" and "household" cases. However, they were probably quite high by today's stan dards. In any case, as technology was developed for the control of asbestos dust levels, both in thj plant and out, those potentially hazardous conditions were eliminated. A relatively small number of cases have also been reported among employees in shipyards and on construction projects who, while not working directly with asbestos, were exposed to heavy concentrations of airborne fiber by working in close proximity to those who did. Exposures of this type have been reduced by strictly enforced industrial safety devices and procedures. The search for answers to the mesothelioma problem is complicated by a number of factors. In the first place, the number of cases being found, even today, is still relatively small. In all of Canada, for example, only 165 cases were reported in the ten-year period ending in 1968. Secondly, it appears highly likely that certain varieties of asbestos (crocidolite and amosite) are more likely to cause mesothelioma than others. Thirdly, its diagnosis and recognition are still considered problems among medical experts. It is also certain that 2 yo *4* CM ^ CTC008593 UCC 015096 there are other causes of mesothelioma besides asbestos. Unfortunately, what those other causes might be is still unknown. Until these and other equally important factors are thoroughly investigated, the mesothelioma question will remain unresolved. Other Tumors Some researchers have reported higher-than-normal rates of gastrointestinal cancer among some heavily exposed industry groups. Other researchers have reported no increase of this type of cancer. The consensus of medical opinion is that the evidence is too scanty for a definitive conclusion. Asbestos and the General Public Medical reports of excess asbestos-related disease among occupationally exposed popula tions have been frequently cited by some writers, environmentalists, politicians and others as "proofs' that the health of the general public is endangered by the minute amounts of asbestos dust being found in community air. "Neighborhood" and "household" cases of mesothelioma are cited extensively in this regard, as are the frequent reports of the findings of free asbestos fibers and so-called ferruginous bodies (which sometimes contain asbestos) in the lungs of some city dwellers at autopsy. The truth is, however, that there is no evidence--either from experience or from scientific research--that anyone in the general public has ever contracted any asbestos-related disease from exposure to these minute amounts of airborne asbestos, which are many times lower than levels which have been demonstrated to result in no excess of disease in occupationally exposed populations. This conclusion is supported by both the Asbestos Panel of the National Academy of Sciences' Committee on Biologic Effects of Atmospheric Pollutants, and the 33 member Advisory Committee on Asbestos Cancers of the International Agency for Research on Cancer, a division of the World Health Organization. In its 1971 booklet, entitled "Asbestos: The Need For And Feasibility of Air Pollution Controls," the NAS Asbestos Panel, which consisted of seven of the nation's top experts on asbestos and health, stated that "there is no evidence that persons in the general popula tion--without occupational, household or neighborhood exposures--have any increased risk of neoplasm, even though there may be ferruginous bodies or fibers in their lungs." Warning against conclusions of the type frequently reached by the uninformed with regard to asbestos, the report further stated: "One cannot extrapolate from the mortality experi ence of, on the one hand, those who are directly and indirectly exposed to asbestos in their employment to, on the other hand, the general public, who have had moderate or slight exposures from ambient air." The report concluded with the statement that "there is no evidence that the small numbers of fibers found in most members of the general population affect health or longev ity." The report of the IARC Advisory Committee represents the consensus of present world medical opinion on all aspects of the asbestos-health problem. Meeting immediately after the October 1972 Lyon Conference on the Biological Effects of Asbestos, the Committee, with representation from teh different countries, drafted the following opinions on asbes tos-related disease and the general public: Asbestosis: "There is at present no evidence of lung damage by asbestos to the general public. The amount of asbestos in the lungs of members of the general public is very small, compared to those occupationally exposed." Lung Cancer: "The evidence ... suggests that an excess lung carcinoma risk is not de tectable when the occupational exposure has been low. These low occupa- , ^24 159 CTC008594 UCC 015097 tional exposures have almost certainly been much greater than that to the public from general air pollution/' Mesothelioma: "There is no evidence of a risk to the general public at present/' Because of some recent controversy in the United States and Canada on this subject, the question was also examined whether there is any "evidence of an increased risk of cancer resulting from asbestos fibers present in water, beverages, food or in the fluids used for the administration of drugs." The answer of the Committee was: "Such evidence as there is does not indicate any risk." While the conclusions of these two eminent scientific bodies should be reassuring to those concerned with the presence of minute amounts of asbestos in the ambient air, the asbestos manufacturing industry in the United States will continue in its efforts to reduce asbesfos emissions so that potentially hazardous levels will never be permitted to develop in the future. Asbestos and Health Research Extensive medical and technical research into the health effects of asbestos and the proper means for their control is being conducted in laboratories throughout the world. A significant percentage of this research is being sponsored, co-sponsored or cooperated in by the world asbestos industry. In fact two of the largest non-governmental sources of funds for asbestos-health research are the Institute of Occupational and Environmental Health (IOEH) in Montreal, which is sponsored by the Quebec Asbestos Mining Association, and the Asbestosis Research Council, sponsored by the British asbestos manufacturing industry. The results of research sponsored by these two agencies and also by individual companies acting independently have contributed significantly to our knowledge of the biological effects of asbestos. In addition, industry environmental control experts are constantly working to develop new or improved methods of handling asbestos and asbestos-containing products safely. Much has been learned about asbestos and health in a very short time--especially when you consider that the greater part of all medical information about asbestos-related disease is less than a decade old. According to Dr. Premysl Pelnar of the Institute of Occupational and Environmental Health, approximately 90 per cent of all information and data now available is the result of medical studies undertaken during the past ten years. Much more is still needed: In late 1972, The International Agency for Research on Cancer made recommendations for further research and indicated priorities for work of immediate and long-term value. Emphasis was placed on epidemiological and pathological studies, and high priorities were urged for certain projects. These included: . '* 1. Usefulness of early detection in the prevention of progressive fibrosis and asbestos cancers and in the identification of hazardous conditions; 2. Assessment of excess cancer risks following exposure to only one variety of asbestos; 3. Amount and type of asbestos in the lung$ of mesothelioma cases; 4. Secular changes in incidence of pleural and peritonea! mesotheliomas nationally and internationally; 5. Possible association between past exposure to asbestos and cancer of sites other than lung, pleura and peritoneum; 6. Relationship between asbestosis and risk of carcinoma. The asbestos manufacturing industry will continue to support and cooperate in research projects of this nature. The Asbestos Information Association, for example, is presently O CO CJ CTC008595 UCC 015098 sponsoring a study at the Harvard School of Public Health on chest ausculation (breathing sounds) as an early detection device in the diagnosis of asbestos-related disease. While this needed additional information and data is being developed, the industry will take ait steps necessary to assure a safe working environment for its employees and for applicators and fabricators of asbestos-containing products. Asbestos Information Association North America 1660 L Street, N. W. Washington, D. C. 20036 A24I6; 5 UCC 015099 Material Safety Data September 1,1976 UNION CARBIDE CORPORATION 4625 ROYAL AVENUE NIAGARA FALLS, NEW YORK 14302 TELEPHONE: (716) 278-3376 PRODUCT: ChrysotiIe Asbestos TRADE NAMES: "Calidria" Asbestos CHEMICAL FORMULA: Mg6(0H)8Si4010 HYSIC BOILING POINT AND MELTING POINT: Not Pertinent SPECIFIC GRAVITY (H20 = 1): 2.45 VOLATILE CONTENT: Absorbed Water 1 -- 4% By Weight. Structural Water Approximately 13% by Weight. APPEARANCE: Pellets or Fine White Powder. No odor. Very Slight Solubility in Water. OUSMfMG EDIE Asbestos contains no hazardous ingredients. However, the material itself can be hazardous under certain conditions. (See V below.) PERMISSIBLE EXPOSURE TO AIRBORNE CONCENTRATION: The current Occupational Safety and Health Standard (CFR 29, 1910.1001) contains the following exposure limits: ,, "The 8-hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed 2 fibers, longer than 5 micrometers, per cubic centimeter of air, as determined by the membrane filter method at 400-450 X magnification (4 millimeter objective) phase contrast illumination. No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers, longer than 5 micrometers, per cubic centimeter of air, as determined by the method just noted." EFFECTS OF EXPOSURE: CAUTION: Breathing asbestos may cause serious bodily harm. EMERGENCY AND FIRST AID PROCEDURES: No acute toxicity. Use respirator if airborne asbestos fiber concentration exceeds OSHA limits. STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED: Avoid inhalation of dust. Remove spilled material by vacuum cleaner or by water wash. WASTE DISPOSAL: Bags and waste and scrap materials should be disposed of in a manner which will avoid airborne concentrations of asbestos, such as the use of dust-tight trash bags or containers. Ensure that disposal complies with all applicable federal, state or local regulations. A24 ] 0O Union Carbide Corporation assumes no responsibility and makes no warranty, expressed or implied, repre sentation, promise, or statement as to completeness, accuracy, or currency of any data provided. UCC 015100 CTC008597 Local exhaust for each operation is preferable. (See American National Standards Institute booklet, Z9.2 -- 1971.) General area exhaust is acceptable. No special considerations. PROTECTIVE GLOVES: None EYE PROTECTION: None RESPIRATORY PROTECTION(1> The current Occupational Safety and Health Standard CFR 29, 1910.1001 contains the following requirements for respiratory protection. AIRBORNE CONCENTRATION*21 CEILING 8-HOUR EXPOSURE*3* CONCENTRATION 2 maximum 10 maximum 20 maximum 100 maximum 200 maximum 1000 maximum MINIMUM REQUIRED MASK TYPE*4* Not required when allowable limits are not exceeded. Reusable or single use air purifying respirator. Powered filter positive pressure. Over 200 -- Type C positive pressure, air supplied. (1) Allowed only during the time required for installation of engineering controls, when engineering controls are not technically feasible or adequate, and in emergencies. Current OSHA standards require that no em ployee shall be assigned to tasks requiring the use of respirators if, based upon his most recent examina tion an examining physician determines that the employee will be unable to function normally wearing a respirator, or that the safety or health of the employee or other employees will be impaired by the use of a respirator. (2) Fibers per milliliter greater than 5 microns in length, as determined by the membrane filter method at 400-450X magnification (4 millimeter objective) phase contrast illumination. (3) 8-Hour time-weighted average. (4) Only masks certified by NIOSH as acceptable for the exposures encountered may be used. OTHER PROTECTIVE EQUIPMENT: If the ceiling concentration limit is exceeded, clothing providing whole body covering shall be supplied and its use required. ECAUTIO Every place of employment where asbestos fibers are released must be monitored to determine exposure levels. If the permissible time-weighted average and ceiling concentration limits are not exceeded, no special pre cautions are required except: a) Bag damage and dusting should be minimized and dust inhalation avoided. b) A comprehensive medical examination is required for any employee exposed to airborne fibers within 30 days of first such employment, annually thereafter and on termination of employment. c) Personal work clothing can become contaminated with asbestos and may constitute an exposure hazard. Such clothing should be handled and laundered in a manner to avoid airborne concentrations of asbestos. d) Substantial medical evidence indicates that smoking will increase the risk from asbestos exposure. Those working with asbestos should not smoke. Where exposure limits may be exceeded, reference should be made to the regulation CFR 29, 1910.1001 for details on caution signs, monitoring, change rooms, protective clothing laundering and record keeping. Cl CO *4C\> CTC008598 UCC 015101 CALIDRIA ASBESTOS RG-244 TYPICAL CHEMICAL ANALYSIS Component Weight % MgO Si02 A1203 Fe Ca Cd Co Cr Cu Mn N1 Se Loss on Ignition (CO2 & H2O) 38.2 46.1 0.2 1.4 0.025 <0.00002 ' 0.004 0.13 0.005 0.05 0.16 <0.001 12.7 Component Ag A1 As __ Au #. Be Bi Ca Cb Cd Co Cr Cs --Cu .. Fe 6a Ge Hf Hg In Ir K La Li Mg Mn Mo TYPICAL SPECTROGRAPHIC ANALYSIS Detection Limit, Wt. % Analysis, Wt. % 0.001 0.003 0.01 0.002 0.006 0.003 0.001 0.005 0.002 0.006 --- 0.01 0.003 N.A.O) 0.001 0.006 0.01 0.005 0.03 0.02 0.03 0*03, - * N.A.*1' 0.01 0.1 0.001 0.003 0.003 0.03 N.d52* 0.08-0.8 N.D. N.D. N.D. N.D. N.D. N.D. 0.008-0.08 N.D.,on <0.00002(3) 0.004-0.04 0.02-0.2 .... N.D. 0.4-4.0 N.D. N.D. N.D. N.D. N.D. N.D. .... N.D. N.D. Major 0.008-0.08 N.D. 0.08-0.8 Component Ni Os P Pb Pd Pt Rb Re Rh Ra Sb Sc Se Si Sn Sr Ta Te Th Ti T1 U V W Y Yb Zn Zr Detection Limit, Analysis, Wt. % Wt. % 0.003 0.03 0.08 0.003 0.005 0.005.. N.A.'1' 0.03 0.02 0.03 0.01 0.01 .... 0.001 0.002 0.01 0.01 0.05 0.03 0.003 0.2 0.1 0.003 0.01 0.01 0.01 0.02 0.006 0.08-0.8 N.D. N.D. N.D. N.D. N.D. .... N.D. N.D. N.D. N.D. ^.oor^ Major N.D. N.D. N.D. N.D. N.D. 0.0008-0.008 N.D. N.D. N.D. N.D. N.D. N.D. N.D. N.D. N.A. - Not analyzed. ^ N.D. - Not detected. (3) gy chemical analysis. UCC 015102 A24 1 54