Document DGpLRR8L9GE9b7bDJxmpx1LOn

T^iOMAS A. BOZICH & A 4 9 3 C A TV IN ROAD CLtVELAND, OHIO 44143 1.1_ v. c. I V t. O July 19, 1974 21 ICWRUI 216-368-2906 I PLAINTIFFS (- EXHIBIT FOS-877 Mr. David Woodbury Foseco Incorporated 20200 Sheldon Road Brook Park, Ohio 44142 Dear Mr. Woodbury: The following is a report of an industrial hygiene survey which was performed on July 3, 1974, at your request. Mr. Jeff Ferguson provided the necessary coordination; Mr. Greg Thomas and a Trainee were present during the survey. I.PURPOSE AND S.COPE: As a result of recent OSKA inspections at your plant, it has been alledged that prevailing airborne concentrations of asbestos at some locations could be exceeding the permissible level. Tne pur pose of this survey was to determine if in fact the prevailing concentrations are excessive, and if 60, to determine the locations and magnitude of the problem. Review of raw material records which you furnished enabled identification of all materials which contain asbestos, and in turn all departments where these materials are being handled. These departments were then ranked on the basis of their potential for producing excessive airborne concentrations. Air samples were collected in as many of these departments (based upon priority) as time permitted during the survey. Because cf the review currently being undertaken in the plant regarding controls, exhaust ventilation, etc., this evaluation excludes any measure ment and/or discussion of these aspects. II. FINDINGS: Tnree raw materials used in the plant are of concern for this evalu ation: fibrous talc (#12) which is ranked as asbestos toxicologically, amosite asbescos (#89), and chrysotile asbestos (#100). The following is a summary of locations where these materials are used: 000-00-0000000536 - v3 3Sr - David Woodbury J 2 July 19, 1974 II. FINDINGS: (cont'd) Depa rtmen t 103 Flux 105/106 Kalmin, Kalrainex 107/108/114 Profax, Proflex 110 Moldcote 133 Salvage 134 Receiving 145 Pre-Batch 1S2 Workshop Type Material Used 12 89, 100 89., 100 12 89, 100 12, 89, 100 89, 100 89, 100 In addition to the above materials, it was reported that wollastonite was being purchased in proprietary form (#124) end was being phased into some production areas as an "asbestos substitute." It was re ported that the manufacturer of this material claims it does not exhibit the toxicological properties of asbestos. Based generally, upon the results of the sampling by OSHA, you reported that, (1) the wollastonite was found in the air along with asbestos, (2) the wol lastonite has a microscopic appearance similar to that of asbestos fibers and would therefore probably normally be included in the as bestos count, and (3) OSHA was able to accomplish some differentia tion which enabled the elimination of the wollastonite from the asbestos count. An extra sample was prepared from some bulk wollastonite material furnished. This sample was examined microscopieslly under phase contrast illumination, along with the air samples collected. As a result of this examination, it was established that visual differ entiation between wollastonite and the asbestos forms was possible, except for those wollastonite fibers with a diameter of less than approximately 1.5 microns. All cf the wollastonite fibers, therefore, which were distinguishable on the filters 'were eliminated from the asbestos counts which are noted in this report. Battery operated personal air samplers were used to collect breathing cone (B.Z.) air samples for two operators who were loading mixers on the large pulping platform in Department 100. Asbestos was being loaded into 3 out of 8 mixers. Wollastonite was being loaded in some of the other mixers. Because of the heavy dust loading, sampling was limited to approximately 1 hour. Examination of the filters re vealed that one had been ruptured during the sampling and was there fore discarded. Result of analysis of the other was 2-S fibers/ml. The filter had a heavy dust loading and some wollastonite. The prevailing cross-draft at the time of the survey was blowing from the above platform cowards Ovens ff3 and i'4. A general room air sample was collected in this location just inside of Department 107, west of Oven #3 at the loading position. The sample was collected r Ob -- 00 -- 00O030 J. 3 Oc o David Woodbury 3 July 19, 1974 FINDINGS: (cont'd) for over 1 hour,and the result was 0.3 fibers/ml. The filter hod a heavy dust loading and a slight amount of wollastoni le. A personal sampler was used to collect a B.Z. air sample for the operator on the pulping platform in Department 106. Tne sample was collected during the loading of one batch which contained asbestos but no wo liastonite. Sampling time was approximately 6 minutes. Result of the analysis was 9.2 fibers/ml. The filter hod moderate dust loading and no distinguishable wollastonite. Another B.Z. sample was collected for the operator on he pulping platform in Department 107. The sample was collected curing the loading of two batches, one of which contained asbestos, the other wa1 lastonite. Sampling time was approximately 8 minutes. Resulc of the analysis was 6.1 fibers/ml. The filter had moderate dust and' heavy wollastonite loading. Another B.Z. sample was collected for one of the operators who was unloading the product from Oven 03 in Department 107. Sampling time was nearly 1 hour. Resulc of the analysis was 0.9 fibers/ml. The filter had light dust loading and moderate wollastonite loading. The current OSHA permissible 8-hour time-weighted average concentra tion for asbestos fibers is 5 fibers/ml of-air. Only fibers longer than 5 microns are to be counted. Tne ceiling concentration is 10 fibers (over 5 microns)/ml of air. On July 1, 1976, the 8-'nour timeweighted average concentration will be reduced to 2 fibers (over 5 microns) /ml of air. Tne ceiling limit will remain che same. CONCb'JS IONS ANT) RZCOISIZNDATIONS : 1. The B.Z. concentration of asbestos on the pulping platform in Department 108 was found to be less than the current permissible but greater than che new limit which will be effective in 1976. The reported concentration of 2.8 fibers/ml could be considered an approximation of the S-'nour average since the operation is generally repetitive and continuous for the entire shift. If on some days more asbestos is loaded than was being loaded during the survey, however, the concentration would be expected to be greater than that measured. 2. The general room air sample collected near the entrance to Oven *3 was found to be well below the current and 1976 8-hour per missible. Tnis value of 0.3 fibers/ml appears reasonable in view of the previous results reported for the platform. The result would be considered a good approximation of the 8-hour ave ra ge. FQS-00--SQ000)3129 Hr. David V.'oodbury ) 4 July 19, 1974 III. CONCLUSION'S AlyD RECOHHZNTtATIONS : (cont'd) 3. The B.Z. sample on the pulping platform in Department 106 was found to be in excess of the current 8-hour permissible, and very close to the ceiling concentration. The reported concentra tion of 9.7. f i bers /nl . however, is not considered to approximate the 8-hour average, since only one batch was sampled. The operator obviously does not load constantly, and at times prepares some batches which do not have asbestos. In addition to these factors, the 8-hour average concentration would also depend on how fast the air "clears" between asbestos loadings. Consequently, the S-hour average would depend on the ratio of the time spent loading asbestos to the total work time, corrected for air "clearance" rate. Assuming an. optimum condition of immediate "clearance" of the air between loadings, the ratio would have to be at least 1 1 to 5 in order to meet the 1976 permissible. 4. The B.Z. sample on the pulping platform in Department 107 was found to be in excess of the current 8-hour permissible. The re-; ported concentration of 6.1 fibers /ml is considered a good approxi mation of the 8-hour average if the operator loads asbestos half of his time. Since one batch of asbestos and then one non-asbestos was loaded, the result would reflect an asbestos to total work time ratio of 1 to 2, and would include the allowance for air "clearance" of asbestos between loadings. On this basis, a ratio of at least 1 to 6 would be required to meet the 1976 permissible (NOTE: Air "clearance" factor included in this estimated ratio was based on the amount of "clearance" which occurred during collection of the sample while actually operating at a ratio of 1 to 2.). 5. The B.Z. sample collected during unloading of Oven ?3 was found to be well below the current and 1976 8-hour permissible. The result of 0.9 fiber/nl is considered a good approximation of the S-hour average, assuming an average amount of asbestos was being handled. 6. On the basis of the above results, which reflect operating con ditions on the day of the Survey, it is recommended that additional or improved dust control measures be considered for all of the pulping platforms sampled, in order to be able to meet the new 1976 permissible concentration. The alternative v.-ould be to phase down (if possible and practical) the use of asbestos to a level necessary to maintain an 8-hour average concentration below the 2 fibers/ml limit. In the event non-asbestos dust concentrations generated in these same areas are also determined to be excessive, however, the alternative course of action may not be a viable option. Sincerely yours, TA3/nh Thomas A. Bozich ' Industrial Hygiene Consultant FOS-03-0000G2>2i30