Document EqaXD9qRvZ9mV61zVOy3EqpZL

FILE NAME Firestone FIRE DATE 1979 Dec 5 DOC FIRE039 DOCUMENT DESCRIPTION Asbestos Manual distributed to US & Canadian Firestone plant safety engineers with OSHA and EPA regulations Ex 372 ASBESTOSASBESTOSASBESTOSASBESTOS MANUALMANUALMANUALMANUAL JACKSON 049606 Firestone F TO U.S. AND CANADIAN PLANT SAFETY ENGINEERS December 5 1979 ASBESTOS MANUAL Please find attached a copy of the Corporate Asbestos Manual which was compiled jointly by Environmental Engineering Physical Distribution and Industrial Hygiene The purpose of this manual is to assist the plants in complying with applicable EPA OSHA and DOT regulations If you have any questions regarding the manual please contact the following 1. For OSHA regulations T. Georgiadis ext 6405 2 For EPA regulations A. H. King ext 7924 3. For DOT regulations R. G. Schmitt ext 7121 Very truly yours Theodore Frongiadis T. Georgiadis Corporate Industrial Hygienist jk jk Att CC Dr. L. H. Ballou Messrs A. H. King G. N. N. J. J. J. B. R. R. A. S. S.L. M. Daigle Daigle Lepkowski Schultz Swenson Walter THE FIRESTONE TIRE & RUBBER COMPANY 1200 FIRESTONE PARKWAY ' AKRON OHIO 44317 JACKSON 049607 TO ALL HM CONTACTS FROM R. G. SCHMITT DATE DECEMBER 4 1979 REFERENCE SUBJECT ASBESTOS MANUAL File 140-211D F Firestone INTEROFFICE Attached you will find a copy manual is intended to provide information on all regulatory of a recently released Asbestos Manual This you with a single document which contains requirements pertaining to Asbestos Since other copies of and EPA Coordinators Coordinator the manual are being mailed to Safety Supervisors this copy should be retained on to the HM Your comments concerning the desirability of manuals like this would be appreciated RG Schmitt R. G. SCHMITT Physical Distribution RGS sr Attachment S1273A BATO JACKSON 049608 ASBESTOS MANUAL November 9 1979 The Firestone Tire & Rubber Company BATO JACKSON 049609 CONTENTS Page Introduction s.scsccarecvacnnennesecesccsseecess 1 Asbestos May Still be Found in Tire Plants oo recereesnees 1 All Other Plants ene eeeennne 22 OSHA Regulations occ esccenns asecee acces 3 Permissible Average Exposure Limit and Ceiling Concentration oe cee ee cones ww Air Monitoring and Sampling Frequency ww Employee Notification and Recordkeeping of Exposure Results c nce occ cceeee . 4 Methods of Compliance a cp 4 Particular Too cel ccccs cccccetces eee Wet Methods oe eevsenesee Spraying Demolition or Removal of Asbestos Insulation ee seees 4 5 Respiratory Protective Equipment Air Purifying Respirators Powered Air Purifying Respirator Type C Supplied Respirators Continuous Flow or Pressure- demand Type ce ees ences secee 5 Special Clothing - Clothes Lockers - 56 Laundering .. ccc wesc ene ser esees Caution Signs and Caution Labels JACKSON 049610 CONTENTS Cont'd) Page Housekeeping - Waste Disposal 7 Medical Examinations 7 Asbestos saccesee wer ee er cccsccccae 7 A. Reason for medical surveillance 7 B. Forms of asbestos included oe 7 C. Level of exposure D. Types of medical tests and E. procedures ... seccccccecnene eee neae . Frequency of medical tests and procedures a eer cece ec cewsees aveee F. Interpretation of medical tests and procedures eves eccceneeee EPA Regulation cee ceeeece vecceccceccecee Introduction Reason for Control of Asbestos 8 8 8 9 88 88 Emissions cecccscccsccvceccuncececesececes 11 Emission Standard for Asbestos soecsesesee 11 Section 61.22 of the Emission Standard .... oe 13 Department of Transportation Regulation 14 Medical Surveillance Flow Chart eoee 16 JACKSON 049611 1 INTRODUCTION Asbestos and materials containing asbestos are now regulated by several federal regulatory agencies The purpose of this manual is to compile in one document all applicable federal regulations and assist and guide the plants in complying with these regulations The use of asbestos or materials containing asbestos in our plants is now very limited According to the information that we have available asbestos insulation may still be used or found in the following areas Tire Plants 1. Curing area a Old pipe insulation b Curing press heat shields C. Board type asbestos insulation between press platens or domes and in the curing press frame This asbestos material is cut or machined by the McNeil Company or NRM and is only installed by Firestone people d Pipe insulation installed by McNeil or NRM on new presses that are shipped to Firestone plants e NRM well insulation 2 Powerhouse - Plants ten years old or older a Pipe insulation b Deaerator heater 3 Maintenance a Gaskets made from a material containing asbestos b Welding blankets or guards 4 Tire building - Hot knife boxes long two per machine This tubing insulates the heated magnets from the rest of the assembly Asbestos tape 0.5 wide x 15 long four per machine This tape is wrapped around the heating elements and tubing described above JACKSON 049612 2 b All Radial First Stage TAM's Radial sidewall knife - Heat sink hot box Manganese wire with asbestosglass insulation AWG 14 16 required per machine All Other Plants 1 Gaskets made from a material containing asbestos that are cut to size and drilled to open holes 2 Experimental formulation of small batches of rubber products containing asbestos This is done in an Akron laboratory of the Synthetic Rubber Division Maintenance operations in plants often require the removal or demolition of old asbestos insulation The removal of asbestos insulation is of considerable importance from the standpoint of compliance with federal regulations since the potential of employee exposure to airborne asbestos fibers is usually higher than in other operations The manual is divided into three sections The first section describes the OSHA standard on asbestos The second section de- scribes the EPA regulations on asbestos which are applicable to Firestone operations The third section summarizes the current Department of Transportation regulations on asbestos JACKSON 049613 3 I. OSHA REGULATION SECTION 1910.1001 The OSHA standard on asbestos is 1001 of the OSHA standards book described in Section 1910 Permissible Average Exposure Limit and Ceiling Concentration The present hour weighted average permissible exposure limit is two 2 fibers longer than 5 microns per cubic centimeter of air The permissible ceiling exposure limit is ten 10 fibers longer than 5 microns per cubic centimeter of air as determined over a period of 15 minutes Air Monitoring and Sampling Frequency All operations where asbestos and materials containing asbestos are being used or old asbestos insulation is being removed replaced or repaired must be monitored by air sampling to determine employee exposure to airborne asbestos fibers Samples should be collected from within the breathing zone of the employees on membrane filters mounted in an open face filter holder cassette Samples should be taken for the determination of the hour weighted average concentration and of the ceiling concentration of asbestos fibers Cassettes for collecting air samples for asbestos are provided to the plants by the Industrial Hygiene Department After sampling these cassettes are returned to Industrial Hygiene for analysis and calculation of the airborne concentration of asbestos fibers Detailed instructions on how to collect air samples for asbestos have been sent to the plant safety engineers by the Industrial Hygiene Department After the initial determination samples should be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees to asbestos fibers In no case should the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos exceeds the permissible exposure limit or the permissible ceiling concentration Affected employees or their representatives should be given an opportunity to observe the monitoring operation JACKSON 049614 4 Employee Notification and Recordkeepinogf Exposure Results Any employee found to have been exposed at any time to air- borne concentrations of asbestos fibers in excess of the per- missible exposure limit or the permissible ceiling concentration must able must be notified in writing of the exposure as but not later than 5 days of the finding also be timely notified of the corrective soon as practicThe employee action taken to reduce the airborne concentration of asbestos fibers Every employer must maintain records of any personal or environ- mental monitoring required by Section 1910.1001 Records must be maintained for a period of at least 20 years and must be made available upon request to the Assistant Secretary of Labor for OSHA the Director of NIOSH tives . and to their authorized representa- Every employee and former employee shall have reasonable access to any records required to be maintained by this standard which indicate the employee's own exposure to asbestos fibers Methods of Compliance 1 Particular Tools All operated and operated tools which may produce or release asbestos fibers in excess of the exposure limits listed above such as saws scorers abrasive wheels and drills must be provided with local exhaust ventilation sys- tems 2. Wet Methods Insofar as practicable asbestos must be handled mixed applied removed cut scored or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the permissible exposure limits unless the usefulness of the product would be diminished by wetting it Spraying Demolition or Removal of Asbestos Insulation Employees engaged in the spraying of asbestos the removal or demolition of pipes structures or equipment covered or insulated with asbestos and in the removal or demolition of asbestos insulation or coverings must be provided with respiratory protective equipment and special clothing as described below JACKSON 049615 5 Respiratory Protective Equipment 1 Air Purifying respirators A reusable or single use disposable air purifying res- pirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 2 but not greater than 20 fibers per cubic centi- meter of air 2 Powered Air Purifying Respirator A powered air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 20 but not greater than 200 fibers per cubic centimeter of air 3. Type C Supplied Respirators Continuous Flow or Pressure Type A type C continuous flow or pressure supplied respirator must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 200 fibers per cubic centimeter of air The OSHA standard specifies that employees engaged in the removal or demolition of asbestos insulation shall be provided with supplied respirators For the removal of large sections of insulation which would normally last several days a supplied- air respirator must be provided As a general guideline when the amount of asbestos to be removed is small and the operation will only last a few hours or less a should still be provided if feasible supplied respirator If this is not feasible at least an air purifying respirator should be provided Special Clothing - Clothes Lockers - Laundering The employer must provide and require the use of special clothing such as coveralls or similar whole body clothing head coverings gloves and foot coverings for any employee exposed to airborne concentrations of asbestos fibers which exceed the permissible exposure limits or who is engaged in the removal or demolition of asbestos insulation At any fixed place of employment exposed to airborne concentrations of asbestos fibers in excess of the permissible exposure limits the employer must provide change rooms for employees working regularly at the place JACKSON 049616 6 The employer must provide two separate lockers or containers for each employee so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes Laundering of asbestos contaminated clothing must be done so as to prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Any employer who gives asbestos contaminated clothing to another person for laundering must inform such person of the requirement to effectively prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Contaminated clothing must be transported in sealed impermeable bags or other closed impermeable containers and labeled in accordance with paragraph ii of the standard It is now common practice among employers to provide their employees who are engaged in asbestos insulation removal with dis- posable coveralls head coverings and shoe coverings The of disposable protective clothing eliminates the necessity laundering work clothes contaminated with asbestos and all use of other problems associated with it Caution Signs and Caution Labels Caution signs must be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the permissible exposure limits Signs must be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps before entering the area marked by the signs Signs must be posted at all approaches to areas containing excessive concentrations of asbestos fibers signs The signs must display a legend which is described in paragraph of this standard Since during the short time needed for a demolition or removal of asbestos insulation it is not usually possible to determine if the concentration of airborne fibers is above or below the permissible exposure limits caution signs should be all asbestos removal operations These signs should after the work is completed posted at be removed Caution labels must be affixed to all raw materials mixtures scrap waste debris and other products containing asbestos fibers or to their containers where asbestos fibers have been except that modified by no label is required a bonding agent JACKSON 049617 7 coating binder ably foreseeable fibers in excess released or other material so that during any reason- use no airborne concentrations of asbestos of the permissible exposure limits will be The statement that is required on the label is described in paragraph ii of this standard Housekeeping - Waste Disposal All external surfaces in any place of employment must be main- tained free of accumulations of asbestos fibers Collection of settled dust or debris should be done by vacuum cleaning Do not clean up asbestos by blowing or dry sweeping Asbestos waste scrap debris bags containers equipment and contaminated clothing that is to be disposed of must be collected and disposed of in sealed impermeable bags or other closed impermeable containers The federal regulations pertaining to asbestos waste disposal practices and procedures are described in the next section of the manual under EPA Regulations Medical Examinations The standard requires that the employer provide or make available at his cost medical examinations to each of his employees exposed to asbestos fibers The medical examinations program required by OSHA is presented below this is a copy of the medical surveillance program for asbestos which has been adopted by the Corporate Medical Department ASBESTOS A. Reason for medical surveillance 1 Required by the OSHA asbestos standard 29 CFR 1910 1001 j B. Forms of asbestos included 1 Chrysotile 2 Amosite JACKSON 049618 8 Crocidolite Tremolite . 5 . Anthophyllite Actinolite Level of exposure 1 Airborne exposure to asbestos at or above 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour weighted average Note This definition of exposure has been established by OSHA Program Directive 300-16 effective October 11 1978 and will not be found in the original OSHA asbestos standard Types of medical tests and procedures 1. Detailed work and medical history with particular - attention to a Respiratory and cardiopulmonary disorders b Smoking habits Comprehensive physical examination with particular attention to respiratory and cardiovascular systems Chest rays - PA on 14 x 17 plate a lateral ray is also strongly recommended 4 Pulmonary function tests - FEV and FVC Frequency of medical tests and procedures 1. All tests and procedures a Prior to or within 30 days after placement in an exposure area where airborne asbestos levels exceed 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour time- weighted average b At least annually while working in the exposure area JACKSON 049619 9 C. Within 30 days before or after termination of employment in an exposure area unless all the tests and procedures have been performed within the past year F. Interpretation of medical tests and procedures 1 Chest rays should be interpreted by a radiologist 2 In order to unify and standardize the pulmonary function tests the actual administration of the tests should be done by as few people as possible The original tracing and interpretation should be given to the plant physician for medical management A copy of each should be sent to the Corporate Medical Department for short and long term interpretation study and storage Whenever an employee shows signs or symptoms of chronic malignant or malignant lung disease or cardiopulmonary disorders which may be due to occupational exposure to asbestos the Corporate Medical Department should be consulted Any abnormality in the chest rays as compared to established norms or earlier findings a definite reduction in the FEV or FVC or degeneration of the employee's general respiratory condition should be reasons for not employing or for removing the employ- ee from the asbestos exposure area The responsibility for medical removal and reinstatement is that of the plant physician in consultation with as many other physicians as he deems necessary Medical records of employees examined under this protocol including examination and test results written medical opinions and records of employee complaints should be retained for at least five years after the last employment for each employee or for twenty years from the date of the record whichever is longer BATO JACKSON 049620 II 10 EPA REGULATION Introduction The EPA has established emission standards for certain hazardous air pollutants under its National Emission Standards for Hazardous Air Pollutants Regulations NESHAPS is included as one of the four substances currently under these regulations 40 CFR Part 61 Subpart Asbestos regulated The NESHAPS regulations are applicable to the following oper- ations asbestos mills roadways manufacturing demolition and renovation ; ) spraying f fabricating g insulating bh waste disposal Engine ring's Based upon Environmental Engineering's knowledge Firestone is mainly involved in Items and h above EPA intentions are to administer these regulations on a state by state basis by delegating authority to the individual state air control agencies i.e. once they have met all the necessary requirements To date 31 states have been given this authority as follows Alabama Arizona California Colorado Connecticut Delaware Georgia Indiana Kentucky Maine Massachusetts Michigan Minnesota Montana Nevada New Hampshire New Jersey New York North Carolina North Dakota Oregon Pennsylvania Rhode Island South Carolina Texas Vermont Virginia Washington Wisconsin Puerto Rico and U. S. Virgin Islands These regulations i.e. NESHAPS for controlling asbestos emissions were first promulgated on April 6 1973 38 FR 8820 in fulfilling requirements under Section 112 B of the Clean Air Act as amended December 1970. Since then they have undergone various revisions the most recent of which was promulgated February 7 1979 giving the State of Texas authority to administer the NESHAPS program and issue permits etc. in the state From time to time additional pollutants which are found to be hazardous will be included under EPA NESHAPS regulations i.e. vinyl chloride was added to the original list on October 21 1976 41 FR 46560 May cause or contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness - Clean Air Act Section 112 December 1970 JACKSON 049621 11 Reason for Control of Asbestos Emissions A large number of studies have shown an association between occupational exposure to asbestos and a higher than expected incidence of bronchial cancer Asbestos also has been identi- fied as a causal factor in the development of cancers of the membranes of the chest and abdomen Emission Standard for Asbestos Basically the regulations prohibit any discharge of asbestos to the outside air which creates a visible emission which may be detected without the aid of instruments By definition outside air means the air outside buildings or structures A source can use a specified method of air cleaning fabric filter systems etc. to eliminate such emissions provided that the emission control equipment is approved by the administrator of the EPA or his authorized representative Specifically the asbestos standards are 1 There shall be no visible emissions to the outside air from any asbestos mill except when a specified method of air cleaning emissions also part escape to of these standards is used before the the outside air In general these cleaning systems filter asbestos emissions to the point that visible emissions would not be produced anyway 2 The surfacing of roadways with asbestos tailings is prohib- ited except for temporary roadways in an area of asbestos ore deposits 3 There shall be no visible emissions to the outside air unless the specified air cleaning methods are used from any operation which manufacturers cloth cord wicks tubing tape twine rope thread yarn roving lap other textile products cement products fireproofing and insulating materials friction products paper millboard felt floor tile paints coatings caulks adhesives sealants plastics and rubber materials and chlorine 4 The regulations covering demolition and renovation of buildings are a Asbestos materials used to insulate or fireproof any boiler pipe or structural member shall be wetted and removed from any building before the wrecking begins The asbestos debris shall be wetted at all stages of demolition and related handling operations JACKSON 049622 12 No pipe or structural member covered with asbestos insulating or fireproofing material shall be dropped or thrown from any building but shall be carefully lowered to ground level No asbestos debris shall be dropped or thrown to the ground or from one floor to another For buildings 50 feet or greater in height asbestos debris shall be lowered to the ground via tight chutes or contain- Written notice of intention to demolish shall be pro- vided to the EPA Regional Administrator at least 10 days prior to commencement of demolition This notice shall include items under Section 61.22 of this regulation e Certain demolition operations are exempt from the reg- ulations except for the wetting of asbestos debris and the notification requirement if a building has been declared to be structurally unsound and in danger of imminent collapse Asbestos waste shall be sealed in tight containers while wet prior to being sent to an approved waste disposal site g The tight containers Item f should be labeled with a warning label which reads CAUTION Contains Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hazardous to Your Health The owner or operator of a demolition operation is ex- empted from these requirements with the exception of Item d above provided the amount of friable asbestos materials in the building or portion thereof to be de- molished is less than 80 meters ca. 260 feet used on pipes and feet used less than 15 on any duct square meters boiler tank ca. 160 reactor square turbine furnace or structural member These regulations also set forth collection processing and disposal requirements which the waste disposal firm must adhere to in handling and disposing of this waste Since Firestone in most cases if not all outside firms for disposal of its asbestos 40 CFR will be wastes 61.25 utilizing no further BATO JACKSON 049623 13 discussion of these requirements will be presented herein Firestone however must verify that any firm selected to dispose of its asbestos waste will meet the requirements of paragraph 61.25 i.e. approved operation Following is Section 61.22 of the Emission standard Written notice of intention to demolish or renovate shall be provided to the Administrator by the owner or operator of the demolition or renovation operation Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demolition or as early as possible prior to commencement of emergency demolition subject to paragraph 6 of this section and as early as possible prior to commencement of renovation Such notice shall in- clude the following information i Name of owner or operator ii Address of owner or operator iii Description of the building structure facility or installation to be demolished or renovated including the size age and prior use of the structure and the approximate amount of friable asbestos materials present iv Address or location of the building facility or installation structure v Scheduled starting and completion dates of demolition or renovation vi Nature of planned demolition or renovation and method to be employed vii Procedures to ments of this this section be employed to meet the paragraph and paragraph require) of viii The name and address or disposal site where the will be deposited location of the waste friable asbestos waste ix Name title and authority of the State or local governmental representative who has ordered a demolition which is subject to paragraph d of this section JACKSON 049624 III 14 DEPARTMENT OF TRANSPORTATION REGULATIONS The Department of Transportation DOT currently only the transportation of commercial asbestos regulate regulates They do not 1 Asbestos which has no commercial value such as products which contain trace amounts as a contaminant 49 CFR 173 1090 2 Waste asbestos which is currently proposed to be regulated under DOT hazardous waste regulations preamble to final commercial asbestos rule issued December 4 1978 3 Asbestos which is immersed or fixed in a natural or artificial binder material such as cement plastic asphalt resin or mineral ore 49 CFR 173.1090 DOT does regulate commercial asbestos which is defined as any material or product which has commercial value because of its asbestos content 49 CFR 173.1090 When regulated DOT requires that shipments of asbestos meet the following requirements 1 Packaging must be as specified in 49 CFR 173.1090 a tight packages such as metal or fiber drums b Bags which are dust and sift proof and are unitized on a pallet Pallet loads should be encased in a shrink wrapped plastic film or fiberboard secured by strapping C. Bags placed inside wooden or fiberboard boxes 2. Each outside package must be marked with the word Asbestos and the name and address of the consignee or consignor 49 CFR 173.304 and 173.306 3. Each outside container must be marked ORM in an approp- riate rectangle 49 CFR 172.316 Labels which can be used for this purpose are available through normal Firestone stationery store channels The form number and description for ordering purposeiss 8974 ORM Label 4 Asbestos shipped via the water or air mode must also meet the following shipping paper requirements 49 CFR 172.200 JACKSON 049625 15 The total amount of commercial asbestos being shipped i.e. the net weight of the product containing commercial asbestos 49 CFR 172.202 The proper shipping name and hazard Asbestos ORM 49 CFR 172.202 class i.e. If shipped on the same bill ous materials the asbestos hazardous entries or in lighted CFR 172.201 of lading with hazardentry should be before any a contrasting color high- d A signed certification 49 CFR 172.204 There are no shipping paper requirements when commercial is shipped via truck or rail modes 49 CFR 172.200 asbestos JACKSON 049626 16 FEDERAL ASBESTOS STANDARD MEDICAL SURVEILLANCE COMPLIANCE FLOW CHART Is exposure at or above .1 fiber longer than 5 microns as an 8 hour TWA -No- No further action is required Yes Provide medical surveillance to employees prior to placement in exposure area Y Detailed work and medical history with particular attention to respiratory and cardiopulmonary disorders and smoking habits d Comprehensive physical examination with particular attention to respiratory and cardiovascular systems Are test results normal Yes -No- Refer to Medical Surveillance Manual and consult with Corporate Medical Director Repeat tests annually and upon termination of work in exposure area t 1. Chest rays on x17 plate a lateral ray is strongly recommended 2. Pulmonary function tests FEV and FVC y JACKSON 049627 * . SEE ATTACHED FOR MAILING LIST Firestone F TO U.S. AND CANADIAN PLANT SAFETY ENGINEERS December 5 1979 ASBESTOS MANUAL Please find attached a copy of the Corporate Asbestos Manual which was compiled jointly by Environmental Engineering Physical Distribution and Industrial Hygiene The purpose of this manual is to assist the plants in complying with applicable EPA OSHA and DOT regulations If you have any questions regarding the manual please contact the following 1. For OSHA regulations T. Georgiadis ext 6405 2. For EPA regulations A. H. King ext 7924 3. For DOT regulations R. G. Schmitt ext 7121 Very truly yours Theodre T. Georgiadis Corporate Industrial Hygienist TG jk Att cc Dr. L. H. Ballou Messrs A. H. King R. G. Schmitt N. A. Daigle J. R. Laman J. S. Lepkowski B. C. Schultz R. L. Swenson R. M. Walter THE FIRESTONE TIRE & RUBBER COMPANY 1200 FIRESTONE PARKWAY ' AKRON OHIO 44317 JACKSON 049628 | THE ASBESTOS MANUAL WAS MAILED TO THE FOLLOWING | i G. L. SHIVELY PLANT I T. E. ANDERSON RESEARCH V. A. PULK SYNTHETIC L. J. USINSKI DEFENSE A. E. BERGSTRASSER ABILENE J. L. DEAN ALBANY E. E. SEMPLE BLOOMINGTON F. F. HOY BATON ROUGE , G. T. SHIELDS BOWLING GREEN \ M. D. COLEMAN BENNETTSVILLE H. CONOVER . . G. COTE CORRY ~ A.P. ALLENDER NS D. GRIFFIN CONOVER . T. D. COFFMAN DANVILLE \, L. GOFF DAYTON K. L. HOWARD DECATUR L. J. MAIN DES MOINES 1 A. R. PEREIRA EAST PROVIDENCE F. M. LIMA ELKHART C. R. BOWLES FT STOCKTON W. E. PASSMORE GASTONIA G. A. CLEOTELIS HOPEWELL J. J. FERREN HENDERSON S. BOROCKI HAMILL 6 W. V. HILSON HAMILTON S. DURAND JOLIETTE J. C. PERRODIN LAKE CHARLES W. H. SCHWARZ LONDON M. I. DALES LOS ANGELES J. H. STREET MAGNOLIA M. J. FOLEY MEMPHIS P. A. BELLAMY MIDLAND J. H. COOK MILAN R. WOOD NASHVILLE H. H. SANE NEWPORT M. SHCALL NOBLESVILLE P. E.E. McCOWAN OKLAHOMA CITY J. R. N.N. WHITEHEAD JR ORANGE P. ELDRETH PERRYVILLE G. PETROKA POTTSTOWN TIRE G. D. LLOYD POTTSTOWN PLASTICS D. C. MARSHALL PRESCOTT R. L. HABER QUINCY G. L. WOLFGANG RAVENNA D. D. HENKE RUSSELLVILLE N. S. GRUBB SALISBURY G. W. HANSON SALINAS E. PRISBY SEIBERLING B. W. LAYTON SPARTANBURG A. W. BOBECK THOMASVILLE J. A. SCOTT WHITBY G. M. HACOCK WOODSTOCK R. B. TUCKER WILSON R. D. NEWMAN WEST CALDWELL M. W. CROWELL WILLIMASPORT L. T. FRANKLIN WYANDOTTE . JACKSON 049629 \ ASBESTOS MANUAL November 9 1979 The Firestone Tire & Rubber Company JACKSON 049630 CONTENTS Introduction .. eee ccccec cv ccene Page 1 Asbestos May Still be Found in Tire Plants erence rene sceuee pa cecacee 1 All Other Plants .cccencccvccaccccensscce 2 OSHA Regulations ceca ec cesee M Permissible Average Exposure Limit and Ceiling Concentration Air Monitoring and Sampling Frequency Employee Notification and Recordkeeping of Exposure Results oesee Compliance Methods of sc eercecnce Particular Tools see ccescnecse oe 4 Wet Methods sec ccccnwnncee eeoes Spraying Demolition or Removal of Asbestos Insulation cecscccrcoccces . 45 0 Respiratory Protective Equipment Air Purifying Respirators .ccccccessees Powered Air Purifying Respirator Type C Supplied Respirators Continuous Flow or Pressure- demand Type 5 Special Clothing - Clothes Lockers - Laundering .... 5 Caution Signs and Caution Labels 10 JACKSON 049631 CONTENTS Housekeeping - Waste Disposal Medical Examinations ... Page 7 7 Asbestos cece mene ees acseneenae 7 A. Reason for medical surveillance 7 B. Forms of asbestos included 7 C. Level of exposure ccm nece rene eeaee . D. Types of medical tests and E. procedures ... occa nec ne wees Frequency of medical tests and procedures .. seceee wean F. Interpretation of medical tests and procedures eee ccesnccsses EPA Regulation ... seresccecescece Introduction 8 8 00 9 55 55 Reason for Control of Asbestos Emissions ew eccsccecsseese 11 Emission Standard for Asbestos eceseeee 11 Section 61.22 of the Emission Standard 13 Department of Transportation Regulation 14 Medical Surveillance Flow Chart cee sessees 16 BATO JACKSON 049632 1 INTRODUCTION Asbestos and materials containing asbestos are now regulated by several federal regulatory agencies The purpose of this manual is to compile in one document all applicable federal regulations and assist and guide the plants in complying with these regulations The use of asbestos or materials containing asbestos in our plants is now very limited According to the information that we have available asbestos insulation may still be used or found in the following areas Tire Plants 1. Curing area a Old pipe insulation b Curing press heat shields C. Board type asbestos insulation between press platens or domes and in the curing press frame This asbestos material is cut or machined by the McNeil Company or NRM and is only installed by Firestone people d Pipe insulation installed by McNeil or NRM on new presses that are shipped to Firestone plants e NRM well insulation 2 Powerhouse - Plants ten years old or older a Pipe insulation D. Deaerator heater 3 Maintenance 2 Gaskets made from a material containing asbestos b Welding blankets or guards 4 Tire building - Hot knife boxes 2 99R3 TAM - Asbestos tubing 1.5 o.d. - 1.25 i.d. x 1 long two per machine This tubing insulates the heated magnets from the rest of the assembly Asbestos tape 0.5 wide x 15 long four per machine This tape is wrapped around the heating elements and tubing described above JACKSON 049633 2 b All Radial First Stage TAM's Radial sidewall knife - Heat sink hot box Manganese wire with asbestosglass insulation AWG 14 16 required per machine All Other Plants 1 Gaskets made from a material containing asbestos that are cut to size and drilled to open holes 2 Experimental formulation of small batches of rubber products containing asbestos This is done in an Akron laboratory of the Synthetic Rubber Division Maintenance operations in plants often require the removal or demolition of old asbestos insulation The removal of asbestos insulation is of considerable importance from the standpoint of compliance with federal regulations since the potential of employee exposure to airborne asbestos fibers is usually higher than in other operations The manual is divided into three sections The first section describes the OSHA standard on asbestos The second section de- scribes the EPA regulations on asbestos which are applicable to Firestone operations The third section summarizes the current Department of Transportation regulations on asbestos JACKSON 049634 3 I. OSHA REGULATION SECTION 1910.1001 The OSHA standard on asbestos is 1001 of the OSHA standards book described in Section 1910 Permissible Average Exposure Limit and Ceiling Concentration The present hour weighted average permissible exposure limit is two 2 fibers longer than 5 microns per cubic centimeter of air The permissible ceiling exposure limit is ten 10 fibers longer than 5 microns per cubic centimeter of air as determined over a period of 15 minutes Air Monitoring and Sampling Frequency All operations where asbestos and materials containing asbestos are being used or old asbestos insulation is being removed replaced or repaired must be monitored by air sampling to determine employee exposure to airborne asbestos fibers Samples should be collected from within the breathing zone of the employees on membrane filters mounted in an open face filter holder cassette Samples should be taken for the determination of the hour weighted average concentration and of the ceiling concentration of asbestos fibers Cassettes for collecting air samples for asbestos are provided to the plants by the Industrial Hygiene Department After samp- ling these cassettes are returned to Industrial Hygiene for analysis and calculation of the airborne concentration of as- bestos fibers Detailed instructions on how to collect air samples for asbestos have been sent to the plant safety engineers by the Industrial Hygiene Department After the initial determination samples should be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees to asbestos fibers In no case should the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos exceeds the permissible exposure limit or the permissible ceiling concentration Affected employees or their representatives should be given an opportunity to observe the monitoring operation JACKSON 049635 4 Employee Notification and Recordkeeping of Exposure Results Any employee found to have been exposed at any time to air- borne concentrations of asbestos fibers in excess of the per- missible exposure limit or the permissible ceiling concentration must be notified in writing of the exposure as soon as practicable but not later than 5 days of the finding The employee must also be timely notified of the corrective action taken to reduce the airborne concentration of asbestos fibers Every employer must maintain records of any personal or environmental monitoring required by Section 1910.1001 Records must be maintained for a period of at least 20 years and must be made available upon request to the Assistant Secretary of Labor for OSHA the Director of NIOSH and to their authorized representa- tives Every employee and former employee shall have reasonable access to any records required to be maintained by this standard which indicate the employee's own exposure to asbestos fibers Methods of Compliance 1 Particular Tools All operated and operated tools which may produce or release asbestos fibers in excess of the exposure limits listed above such as saws scorers abrasive wheels and drills must be provided with local exhaust ventilation sys- tems 2 Wet Methods Insofar as practicable asbestos must be handled mixed applied removed cut scored or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the permissible exposure limits unless the usefulness of the product would be diminished by wetting it Spraying Demolition or Removal of Asbestos Insulation Employees engaged in the spraying of asbestos the removal or demolition of pipes structures or equipment covered or insulated with asbestos and in the removal or demolition of asbestos insulation or coverings must be provided with respiratory protective equipment and special clothing as described below JACKSON 049636 5 Respiratory Protective Equipment 1 Air Purifying respirators A reusable or single use disposable air purifying res- pirator or used by the a respirator of higher efficiency must be employees when the hour weighted aver- age airborne concentration of asbestos fibers is greater than 2 but not greater than 20 fibers per cubic centi- meter of air 2 Powered Air Purifying Respirator A powered air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 20 but not greater than 200 fibers per cubic centimeter of air 3 Type C Supplied Respirators Continuous Flow or Pressure Type A type C continuous flow or pressure supplied respirator must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 200 fibers per cubic centimeter of air The OSHA standard specifies that employees engaged in the removal or demolition of asbestos insulation shall be provided with supplied respirators For the removal of large sections of insulation which would normally last several days a suppliedair respirator must be provided As a general guideline when the amount of asbestos to be removed is small and the operation will only last a few hours or less a should still be provided if feasible supplied respirator If this is not feasible at least an air purifying respirator should be provided Special Clothing - Clothes Lockers - Laundering The employer must provide and require the use of special cloth- ing such as coveralls or similar whole body clothing head for any employee exposed coverings gloves and foot coverings to airborne concentrations of asbestos fibers which exceed the permissible exposure limits or who is engaged in the removal or demolition of asbestos insulation At any fixed place of employment exposed to airborne concentrations of asbestos fibers in excess of the permissible exposure limits the employer must provide change rooms for employees working regularly at the place JACKSON 049637 6 The employer must provide two separate lockers or containers for each employee so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes Laundering of asbestos contaminated clothing must be done so as to prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Any employer who gives asbestos contaminated clothing to another person for laundering must inform such person of the requirement to effectively prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Contaminated clothing must be transported in sealed impermeable bags or other closed impermeable containers and labeled in accordance with paragraph ii of the standard It is now common practice among employers to provide their employees who are engaged in asbestos insulation removal with disposable coveralls head coverings and shoe coverings The use of disposable protective clothing eliminates the necessity of laundering work clothes contaminated with asbestos and all other problems associated with it Caution Signs and Caution Labels Caution signs must be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the permissible exposure limits Signs must be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps before entering the area marked by the signs Signs must be posted at all approaches to areas containing excessive concentrations of asbestos fibers signs The must display a legend which is described in paragraph ii of this standard Since during the short time needed for a demolition or removal of asbestos insulation it is not usually possible to determine if the concentration of airborne fibers is above or below the permissible exposure limits caution signs should be all asbestos removal operations These signs should after the work is completed posted at be removed Caution labels must 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 JACKSON 049638 7 coating binder ably foreseeable fibers in excess released or other material so that during any reason- use no airborne concentrations of asbestos of the permissible exposure limits will be The statement that is required on the label is described in paragraph ii of this standard Housekeeping - Waste Disposal All external surfaces in any place of employment must be main- tained free of accumulations of asbestos fibers Collection of settled dust or debris should be done by vacuum cleaning Do not clean up asbestos by blowing or dry sweeping Asbestos waste scrap debris bags containers equipment and contaminated clothing that is to be disposed of must be collected and disposed of in sealed impermeable bags or other closed impermeable containers The federal regulations pertaining to asbestos waste disposal practices and procedures are described in the next section of the manual under EPA Regulations Medical Examinations The standard requires that the employer provide or make available at his cost medical examinations to each of his employees exposed to asbestos fibers The medical examinations program required by OSHA is presented below this is a copy of the medical surveillance program for asbestos which has been adopt- ed by the Corporate Medical Department ASBESTOS A. Reason for medical surveillance 1. Required by the OSHA asbestos standard 29 CFR 1910 1001 j B. Forms of asbestos included 1 Chrysotile 2 Amosite JACKSON 049639 8 3 Crocidolite 3 4. Tremolite 5. 5. Anthophyllite Actinolite Level of exposure 1 Airborne exposure to asbestos at or above 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour weighted average Note This definition of exposure has been established by OSHA Program Directive 300-16 effective October 11 1978 and will not be found in the original OSHA asbestos standard Types of medical tests and procedures 1. Detailed work and medical history with particular attention to a Respiratory and cardiopulmonary disorders b Smoking habits Comprehensive physical examination with particular attention to respiratory and cardiovascular systems Chest rays - PA on 14 x 17 plate ray is also strongly recommended a lateral . Pulmonary function tests - FEV and FVC Frequency of medical tests and procedures 1. All tests and procedures 3 Prior to or within 30 days after placement in an exposure area where airborne asbestos levels exceed 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour time- weighted average b At least annually while working in the exposure area JACKSON 049640 9 C. Within 30 days before or after termination of employment in an exposure area unless all the tests and procedures have been performed within the past year F. Interpretation of medical tests and procedures 1 Chest rays should be interpreted by a radiologist 2 In order to unify and standardize the pulmonary function tests the actual administration of the tests should be done by as few people as possible The original tracing and interpretation should be given to the plant physician for medical management A copy of each should be sent to the Corporate Medical Department for short and long term interpretation study and storage 3 Whenever an employee shows signs or symptoms of chronic malignant or malignant lung disease or cardiopulmonary disorders which may be due to occupational exposure to asbestos the Corporate Medical Department should be consulted Any abnormality in the chest rays as compared to established norms or earlier findings a definite reduction in the FEV or FVC or degeneration of the employee's general respiratory condition should be reasons for not employing or for removing the employ- ee from the asbestos exposure area The responsibility for medical removal and reinstatement is that of the plant physician in consultation with as many other physicians as he deems necessary Medical records of employees examined under this protocol including examination and test results written medical opinions and records of employee complaints should be retained for at least five years after the last employment for each employee or for twenty years from the date of the record whichever is longer JACKSON 049641 II 10 EPA REGULATION Introduction The EPA has established emission standards for certain hazardous air pollutants under its National Emission Standards for Hazardous Air Pollutants Regulations NESHAPS Asbestos currently is included as one of the four substances currently under these regulations 40 CFR Part 61 Subpart regulated The NESHAPS regulations are applicable to the following oper- ations a) asbestos mills b roadways c manufacturing d demolition and renovation e spraying f fabricating g insulating h waste disposal Engine ring's Based upon Environmental Engineering's knowledge Firestone is mainly involved in Items and h above EPA intentions are to administer these regulations on a state by state basis by delegating authority to the individual state air control agencies i.e. once they have met all the necessary requirements To date 31 states have been given this authority as follows Alabama Arizona California Colorado Connecticut Delaware Georgia Indiana Kentucky Maine Massachusetts Michigan Minnesota Montana Nevada New Hampshire New Jersey New York North Carolina North Dakota Oregon Pennsylvania Rhode Island South Carolina Texas Vermont Virginia Washington Wisconsin Puerto Rico and U. S. Virgin Islands These regulations i.e. NESHAPS for controlling asbestos emissions were first promulgated on April 6 1973 38 FR 8820 in fulfilling requirements under Section 112 B of the Clean Air Act as amended December 1970. Since then they have undergone various revisions the most recent of which was promulgated February 7 1979 giving the State of Texas authority to administer the NESHAPS program and issue permits etc. in the state From time to time additional pollutants which are found to be hazardousl will be included under EPA NESHAPS regulations i.e. vinyl chloride was added to the original list on October 21 1976 41 FR 46560 May cause or contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness - Clean Air Act Section 112 December 1970 JACKSON 049642 11 Reason for Control of Asbestos Emissions A large number of studies have shown an association between occupational exposure to asbestos and a higher than expected incidence of bronchial cancer Asbestos also has been identified as a causal factor in the development of cancers of the membranes of the chest and abdomen Emission Standard for Asbestos Basically the regulations prohibit any discharge of asbestos to the outside air which creates a visible emission which may be detected without the aid of instruments By definition outside air means the air outside buildings or structures A source can use a specified method of air cleaning fabric filter systems etc. to eliminate such emissions provided that the emission control equipment is approved by the administrator of the EPA or his authorized representative Specifically the asbestos standards are 1 There shall be no visible emissions to the outside air from any asbestos mill except when a specified method of air cleaning also part of these standards is used before the emissions escape to the outside air In general these cleaning systems filter asbestos emissions to the point that visible emissions would not be produced anyway 2 The surfacing of roadways with asbestos tailings is prohibited except for temporary roadways in an area of asbestos ore deposits 3 There shall be no visible emissions to the outside air unless the specified air cleaning methods are used from any operation which manufacturers cloth cord wicks tubing tape twine rope thread yarn roving lap other textile products cement products fireproofing and insulating materials friction products paper millboard felt floor tile paints coatings caulks adhesives sealants plastics and rubber materials and chlorine 4 The regulations covering demolition and renovation of buildings are a Asbestos materials used to insulate or fireproof any boiler pipe or structural member shall be wetted and removed from any building before the wrecking begins The asbestos debris shall be wetted at all stages of demolition and related handling operations JACKSON 049643 12 No pipe or structural member covered with asbestos insulating or fireproofing material shall be dropped or thrown from any building but shall be carefully lowered to ground level No asbestos debris shall be dropped or thrown to the ground or from one floor to another For buildings 50 feet or greater in height asbestos debris shall be lowered to the ground via tight chutes or contain- ers Written notice of intention to demolish shall be pro- vided to the EPA Regional Administrator at least 10 days prior to commencement of demolition This notice shall include items under Section 61.22 of this regulation Certain demolition operations are exempt from the regulations except for the wetting of asbestos debris and the notification requirement if a building has been declared to be structurally unsound and in danger of imminent collapse Asbestos waste shall be sealed in tight containers while wet prior to being sent to an approved waste disposal site The tight containers Item f with a warning label which reads should be labeled CAUTION Contains Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hazardous to Your Health The owner or operator of a demolition operation is exempted from these requirements with the exception of Item d above provided the amount of friable asbestos materials in the building or portion thereof to be demolished is less than 80 meters ca. 260 feet used on pipes and less than 15 square meters ca. 160 square feet used on any duct boiler tank reactor turbine furnace or structural member These regulations also set forth collection processing and disposal requirements which the waste disposal firm must adhere to in handling and disposing of this waste 40 CFR 61.25 Since Firestone in most cases if not all will be utilizing outside firms for disposal of its asbestos wastes no further JACKSON 049644 13 discussion of these requirements will be presented herein Firestone however must verify that pose of its asbestos waste will meet any the firm selected to requirements of dis- paragraph 61.25 i.e. approved operation Following is Section 61.22 of the Emission standard Written notice of intention to demolish or renovate shall be provided to the Administrator by the owner or operator Such notice of the demolition or renovation operation shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demolition or as early as possible prior to com- mencement of emergency demolition subject to paragraph 6 of this section and as to commencement of renovation early Such as possible prior notice shall in- clude the following information i Name of owner or operator ii iii Address of owner or operator Description of the building structure facility or installation to be demolished or renovated including the size age and prior use of the structure and the approximate amount of friable asbestos materials present iv v Address or location of the building facility or installation structure Scheduled starting and completion dates of demolition or renovation vi Nature of planned demolition or renovation and method to be employed vii Procedures to ments of this this section be employed to meet the paragraph and paragraph requirej of viii The name and address or disposal site where the will be deposited location of the waste friable asbestos waste ix Name title and authority of the State or local governmental representative who has ordered a demolition which is subject to paragraph 6 of this section JACKSON 049645 III 14 DEPARTMENT OF TRANSPORTATION REGULATIONS The Department of Transportation DOT currently only the transportation of commercial asbestos regulate regulates They do not 1 Asbestos which has no commercial value such as products which contain trace amounts as a contaminant 49 CFR 173 1090 2 Waste asbestos which is currently proposed to be regulated under DOT hazardous waste regulations preamble to final commercial asbestos rule issued December 4 1978 3 Asbestos which is immersed or fixed in a natural or arti- ficial binder material such as cement plastic asphalt resin or mineral ore 49 CFR 173.1090 DOT does regulate commercial asbestos which is defined as any material or product which has commercial value because of its asbestos content 49 CFR 173.1090 When regulated DOT requires that shipments of asbestos meet the following requirements 1 Packaging must be as specified in 49 CFR 173.1090 a tight packages such as metal or fiber drums 10 Bags which are dust and sift proof and are unitized on a pallet Pallet loads should be encased in a shrink wrapped plastic film or fiberboard secured by strapping C. Bags placed inside wooden or fiberboard boxes 2 Each outside package must be marked with the word Asbestos and the name and address of the consignee or consignor 49 CFR 173.304 and 173.306 3 Each outside container must be marked ORM in an approp- riate rectangle 49 CFR 172.316 Labels which can be used for this purpose are available through normal Firestone stationery store channels The form number and description for ordering purposes is 8974 ORM Label 4 Asbestos shipped via the water or air mode must also meet the following shipping paper requirements 49 CFR 172.200 JACKSON 049646 15 The total amount of commercial asbestos being shipped i.e. the net weight of the product containing commercial asbestos 49 CFR 172.202 The proper shipping name and hazard class Asbestos ORM 49 CFR 172.202 i.e. If shipped on the same bill ous materials the asbestos hazardous entries or in lighted CFR 172.201 of lading with hazardentry should be before any a contrasting color high- d A signed certification 49 CFR 172.204 There are no shipping paper requirements when commercial is shipped via truck or rail modes 49 CFR 172.200 asbestos JACKSON 049647 16 FEDERAL ASBESTOS STANDARD MEDICAL SURVEILLANCE COMPLIANCE FLOW CHART Is exposure at or above .1 fiber longer than 5 microns as an 8 hour TWA -No- No further action is required Yes Provide medical surveillance to employees prior to placement in exposure area q Detailed work and medical history with particular attention to respiratory and cardiopulmonary disorders and smoking habits X Comprehensive physical examination with particular attention to respiratory and cardiovascular systems r 1. Chest rays on x17 plate a lateral ray is strongly recommended 2. Pulmonary function tests FEV and FVC y Are test results normal Yes No- Refer to Medical Surveillance Manual and consult with Corporate Medical Director Repeat tests annually and upon termination of work in exposure area JACKSON 049648 ASBESTOS MANUAL November 9 1979 The Firestone Tire & Rubber Company JACKSON 049649 CONTENTS Introduction ccscccccccsvcscccecsesves Page 1 AsbestoMasy Still be Found in Tire Planct ccs cece cc accccnes eee eeccceee All Other Plants eens OSHA Regulations eeeeas @oeoesvevevp @eoeeseee Permissible Average Exposure Limit and Ceiling Concentration ..... Air Monitoring and Sampling Frequency Employee Notification and Recordkeeping of Exposure Results .. . 4 Methods of Compliance ... Particular Tools Wet Methods .. a eeees Spraying Demolition or Removal of Asbestos Insulation ..... 4 in Respiratory Protective Equipment Air Purifying Respirators wee ewcnene Powered Air Purifying Respirator 5 Type C Supplied Respirators Continuous Flow or Pressure- demand Type ..... Special Clothing - Clothes Lockers - Laundering ... . Caution Signs and Caution Labels sees JACKSON 049650 CONTENTS Cont'd Housekeeping - Waste Disposal cone Medical Examinations .cscsccecccccscsceccccces Page 7 7 Asbestos 7 A. ... cceaccccnsececscecscnesencenccces Reason for medical surveillance . B. Forms of asbestos included .ceccceveee C. Level of exposure 7 D. Types of medical tests and procedures ..... wewese E. Frequency of medical tests and proc .... . e.d .u . cr ecee vans e ascsceses F. Interpretation of medical tests and proc ..e acd ccscu nccr sscce sses ces EPA Regulation cscccccccccccvevecscccscsncces Introduction .. . 9 10 10 Reason for Control of Asbestos Emissions ...... ...... ccscescccccsscnscsccecs 11 Emission Standard for Asbestos 11 Section 61.22 of the Emission Standard Department of Transportation Regulation 14 Medical Surveillance Flow Chart canes 16 JACKSON 049651 1 INTRODUCTION Asbestos and materials containing asbestos are now regulated by several federal regulatory agencies The purpose of this manual is to compile in one document all applicable federal regulations and assist and guide the plants in complying with these regulations The use of asbestos or materials containing asbestos in our plants is now very limited According to the information that we have available asbestos insulation may still be used or found in the following areas Tire Plants 1. Curing area a Old pipe insulation b Curing press heat shields C. Board type asbestos insulation between press platens or domes and in the curing press frame This asbestos material is cut or machined by the McNeil Company or NRM and is only installed by Firestone people d Pipe insulation installed by McNeil or NRM on new presses that are shipped to Firestone plants e NRM well insulation 2 Powerhouse - Plants ten years old or older 8 Pipe insulation b Deaerator heater 3. Maintenance a Gaskets made from a material containing asbestos b Welding blankets or guards 4 Tire building - Hot knife boxes a 99R3 TAM - Asbestos tubing 1.5 o.d. - 1.25 i.d. x 1 long two per machine This tubing insulates the heated magnets from the rest of the assembly Asbestos tape 0.5 wide x 15 long four per machine This tape is wrapped around the heating elements and tubing described above JACKSON 049652 2 b All Radial First Stage TAM's Radial sidewall knife - Heat sink hot box Manganese wire with asbestosglass insulation AWG 14 16 required per machine All Other Plants 1 Gaskets made from a material containing asbestos that are cut to size and drilled to open holes 2 Experimental formulation of small batches of rubber products containing asbestos This is done in an Akron laboratory of the Synthetic Rubber Division Maintenance operations in plants often require the removal or demolition of old asbestos insulation The removal of asbestos insulation is of considerable importance from the standpoint of compliance with federal regulations since the potential of employee exposure to airborne asbestos fibers is usually higher than in other operations The manual is divided into three sections The first section describes the OSHA standard on asbestos The second section de- scribes the EPA regulations on asbestos which are applicable to Firestone operations The third section summarizes the current Department of Transportation regulations on asbestos JACKSON 049653 3 I. OSHA REGULATION SECTION 1910.1001 The OSHA standard on asbestos is 1001 of the OSHA standards book described in Section 1910 Permissible Average Exposure Limit and Ceiling Concentration The present hour weighted average permissible exposure limit is two 2 fibers longer than 5 microns per cubic centimeter of air The permissible ceiling exposure limit is ten 10 fibers longer than 5 microns per cubic centimeter of air as determined over a period of 15 minutes Air Monitoring and Sampling Frequency All operations where asbestos and materials containing asbestos are being used or old asbestos insulation is being removed replaced or repaired must be monitored by air sampling to determine employee exposure to airborne asbestos fibers Samples should be collected from within the breathing zone of the employees on membrane filters mounted in an open face filter holder cassette Samples should be taken for the determination of the hour weighted average concentration and of the ceiling concentration of asbestos fibers Cassettes for collecting air samples for asbestos are provided to the plants by the Industrial Hygiene Department After sampling these cassettes are returned to Industrial Hygiene for analysis and calculation of the airborne concentration of as- bestos fibers Detailed instructions on how to collect air samples for asbestos have been sent to the plant safety engineers by the Industrial Hygiene Department After the initial determination samples should be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees to asbestos fibers In no case should the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos exceeds the permissible exposure limit or the permissible ceiling concentration Affected employees or their representatives should be given an opportunity to observe the monitoring operation JACKSON 049654 4 Employee Notification and Recordkeepinogf Exposure Results Any employee found to have been exposed at any time to air- borne concentrations of asbestos fibers in excess of the per- missible exposure limit or the permissible ceiling concentration must be notified in writing of the exposure as soon as practicable but not later than 5 days of the finding The employee must also be timely notified of the corrective action taken to reduce the airborne concentration of asbestos fibers Every employer must maintain records of any personal or environmental monitoring required by Section 1910.1001 Records must be maintained for a period of at least 20 years and must be made available upon request to the Assistant Secretary of Labor for OSHA the Director of NIOSH and to their authorized representa- tives Every employee and former employee shall have reasonable access to any records required to be maintained by this standard which indicate the employee's own exposure to asbestos fibers Methods of Compliance 1 Particular Tools All operated and operated tools which may produce or release asbestos fibers in excess of the exposure limits listed above such as saws scorers abrasive wheels and drills must be provided with local exhaust ventilation sys- tems 2 Wet Methods Insofar as practicable asbestos must be handled mixed applied removed cut scored or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the permissible exposure limits unless the usefulness of the product would be diminished by wetting it Spraying Demolitioonr Removal of Asbestos Insulation Employees engaged in the spraying of asbestos the removal or demolition of pipes structures or equipment covered or insulated with asbestos and in the removal or demolition of asbestos insulation or coverings must be provided with respiratory protective equipment and special clothing as described below JACKSON 049655 5 Respiratory Protective Equipment 1 Air Purifying respirators A reusable or single use disposable air purifying res- pirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 2 but not greater than 20 fibers per cubic centi- meter of air 2 Powered Air Purifying Respirator A powered air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 20 but not greater than 200 fibers per cubic centimeter of air 3. Type C Supplied Respirators Continuous Flow or Pressure Type A type C continuous flow or pressure supplied respirator must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 200 fibers per cubic centimeter of air The OSHA standard specifies that employees engaged in the removal or demolition of asbestos insulation shall be provided with supplied respirators For the removal of large sections of insulation which would normally last several days a suppliedair respirator must be provided As a general guideline when the amount of asbestos to be removed is small and the operation will only last a few hours or less a supplied respirator should still be provided if feasible If this is not feasible at least an air purifying respirator should be provided Special Clothing - Clothes Lockers - Laundering The employer must provide and require the use of special clothing such as coveralls or similar whole body clothing head coverings gloves and foot coverings for any employee exposed to airborne concentrations of asbestos fibers which exceed the permissible exposure limits or who is engaged in the removal or demolition of asbestos insulation At any fixed place of employment exposed to airborne concentrations of asbestos fibers in excess of the permissible exposure limits the employer must provide change rooms for employees working regularly at the place BATO JACKSON 049656 6 The employer must provide two separate lockers or containers for each employee so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes Laundering of asbestos contaminated clothing must be done so as to prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Any employer who gives asbestos contaminated clothing to another person for laundering must inform such person of the requirement to effectively prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Contaminated clothing must be transported in sealed impermeable bags or other closed impermeable containers and labeled in accordance with paragraph ii of the standard It is now common practice among employers to provide their employees who are engaged in asbestos insulation removal with disposable coveralls head coverings and shoe coverings The use of disposable protective clothing eliminates the necessity of laundering work clothes contaminated with asbestos and all other problems associated with it Caution Signs and Caution Labels Caution signs must be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the permissible exposure limits Signs must be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps before entering the area marked by the signs Signs must be posted at all approaches to areas containing excessive concentrations of asbestos fibers signs The must display a legend which is described in paragraph ii of this standard Since during the short time needed for a demolition or removal of asbestos insulation it is not usually possible to determine if the concentration of airborne fibers is above or below the permissible exposure limits caution signs should be all asbestos removal operations These signs should after the work is completed posted at be removed Caution labels must 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 JACKSON 049657 7 coating binder ably foreseeable fibers in excess released or other material so that during any reason- use no airborne concentrations of asbestos of the permissible exposure limits will be The statement that is required on the label paragraph ii of this standard is described in Housekeeping - Waste Disposal All external surfaces in any place of employment tained free of accumulations of asbestos fibers must be mainCollection of settled dust or debris should be done by vacuum cleaning Do not clean up asbestos by blowing or dry sweeping Asbestos waste scrap debris bags containers equipment and contaminated clothing that is to be disposed of must be collected and disposed of in sealed impermeable bags or other closed impermeable containers The federal regulations pertaining to asbestos waste disposal practices and procedures are described in the next section of the manual under EPA Regulations Medical Examinations The standard requires that the employer provide or make available at his cost medical examinations to each of his employees exposed to asbestos fibers The medical examinations program required by OSHA is presented below this is a copy of the medical surveillance program for asbestos which has been adopted by the Corporate Medical Department ASBESTOS A. Reason for medical surveillance 1 Required by the OSHA asbestos standard 29 CFR 1910 1001 ) B. Forms of asbestos included 1 Chrysotile 2. Amosite JACKSON 049658 8 Crocidolite Tremolite Anthophyllite Actinolite Level of exposure 1 Airborne exposure to asbestos at or above 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour weighted average Note This definition of exposure has been established by OSHA Program Directive 300-16 effective October 11 1978 and will not be found in the original OSHA asbestos standard Types of medical tests and procedures 1. Detailed work and medical history with particular attention to a Respiratory and cardiopulmonary disorders b Smoking habits Comprehensive physical examination with particular attention to respiratory and cardiovascular systems Chest rays - PA on 14 x 17 plate ray is also strongly recommended a lateral 4 Pulmonary function tests - FEV and FVC Frequency of medical tests and procedures 1. All tests and procedures a Prior to or within 30 days after placement in an exposure area where airborne asbestos levels exceed 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour time- weighted average b At least annually while working in the exposure area JACKSON 049659 9 C. Within 30 days before or after termination of employment in an exposure area unless all the tests and procedures have been performed within the past year F. Interpretation of medical tests and procedures 1 Chest rays should be interpreted by a radiologist 2 In order to unify and standardize the pulmonary function tests the actual administration of the tests should be done by as few people as possible The original tracing and interpretation should be given to the plant physician for medical management A copy of each should be sent to the Corporate Medical Department for short and long term interpretation study and storage Whenever an employee shows signs or symptoms of chronic malignant or malignant lung disease or cardiopulmonary disorders which may be due to occupational exposure to asbestos the Corporate Medical Department should be consulted Any abnormality in the chest rays as compared to established norms or earlier findings a definite reduction in the FEV or FVC or degeneration of the employee's general respiratory condition should be reasons for not employing or for removing the employ- ee from the asbestos exposure area The responsibility for medical removal and reinstatement is that of the plant physician in consultation with as many other physicians as he deems necessary Medical records of employees examined under this protocol including examination and test results written medical opinions and records of employee complaints should be retained for at least five years after the last employment for each employee or for twenty years from the date of the record whichever is longer JACKSON 049660 II 10 EPA REGULATION Introduction The EPA has established emission standards for certain hazardous air pollutants under its National Emission Standards for Hazardous Air Pollutants Regulations NESHAPS Asbestos currently is included as one of the four substances currently under these regulations 40 CFR Part 61 Subpart regulated The NESHAPS regulations are applicable to the following oper- ations a} asbestos mills b roadways c manufacturing d demolition and renovation e) spraying f fabricating g insulating h waste disposal Engine ring's Engineering's Based upon Environmental Engineering's knowledge Firestone is mainly involved in Items h above EPA intentions are to administer these regulations on a state by state basis by delegating authority to the individual state air control agencies i.e. once they have met all the necessary requirements To date 31 states have been given this authority as follows Alabama Arizona California Colorado Connecticut Delaware Georgia Indiana Kentucky Maine Massachusetts Michigan Minnesota Montana Nevada New Hampshire New Jersey New York North Carolina North Dakota Oregon Pennsylvania Rhode Island South Carolina Texas Vermont Virginia Washington Wisconsin Puerto Rico and U. S. Virgin Islands These regulations i.e. NESHAPS for controlling asbestos emissions were first promulgated on April 6 1973 38 FR 8820 in fulfilling requirements under Section 112 B of the Clean Air Act as amended December 1970. Since then they have undergone various revisions the most recent of which was promulgated February 7 1979 giving the State of Texas authority to administer the NESHAPS program and issue permits etc. in the state From time to time additional pollutants which are found to be hazardous will be included under EPA NESHAPS regulations i.e. vinyl chloride was added to the original list on October 21 1976 41 FR 46560 May cause or contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness - Clean Air Act Section 112 December 1970 JACKSON 049661 11 Reason for Control of Asbestos Emissions A large number of studies have shown an association between occupational exposure to asbestos and a higher than expected incidence of bronchial cancer Asbestos also has been identi- fied as a causal factor in the development of cancers of the membranes of the chest and abdomen Emission Standard for Asbestos Basically the regulations prohibit any discharge of asbestos to the outside air which creates a visible emission which may be detected without the aid of instruments By definition outside air means the air outside buildings or structures etc. A source can use a specified method of air cleaning fabric filter systems to eliminate such emissions provided that the emission control equipment is approved by the admin- istrator of the EPA or his authorized representative Specifically the asbestos standards are 1 There shall be no visible emissions to the outside air from any asbestos mill except when a specified method of air cleaning also part of these standards is used before the emissions escape to the outside air In general these cleaning systems filter asbestos emissions to the point that visible emissions would not be produced anyway 2 The surfacing of roadways with asbestos tailings is prohibited except for temporary roadways in an area of asbestos ore deposits 3. There shall be no visible emissions to the outside air unless the specified air cleaning methods are used from any operation which manufacturers cloth cord wicks tubing tape twine rope thread yarn roving lap other textile products cement products fireproofing and insulating materials friction products paper millboard felt floor tile paints coatings caulks adhesives sealants plastics and rubber materials and chlorine 4 The regulations covering demolition and renovation of buildings are 8 Asbestos materials used to insulate or fireproof any boiler pipe or structural member shall be wetted and removed from any building before the wrecking begins The asbestos debris shall be wetted at all stages of demolition and related handling operations JACKSON 049662 12 No pipe or structural member covered with asbestos insulating or fireproofing material shall be dropped or thrown from any building but shall be carefully lowered to ground level c No asbestos debris shall be dropped or thrown to the ground or from one floor to another For buildings 50 feet or greater in height asbestos debris shall be lowered to the ground via tight chutes or contain- ers ; d Written notice of intention to demolish shall be pro- vided to the EPA Regional Administrator at least 10 days prior to commencement of demolition This notice shall include items under Section 61.22 of this regulation e Certain demolition operations are exempt from the regulations except for the wetting of asbestos debris and the notification requirement if a building has been declared to be structurally unsound and in danger of imminent collapse Asbestos waste shall be sealed in tight containers while wet prior to being sent to an approved waste disposal site 6 The tight containers Item f should be labeled with a warning label which reads CAUTION Contains Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hazardous to Your Health The owner or operator of a demolition operation is exempted from these requirements with the exception of Item d above provided the amount of friable asbestos materials in the building or portion thereof to be demolished is less than 80 meters ca. 260 feet used on pipes and less than 15 square meters ca. 160 square feet used on any duct boiler tank reactor turbine furnace or structural member These regulations also set forth collection processing and disposal requirements which the waste disposal firm must adhere to in handling and disposing of this waste 40 CFR 61.25 Since Firestone in most cases if not all will be utilizing outside firms for disposal of its asbestos wastes no further JACKSON 049663 13 discussion of these requirements will be presented herein Firestone however must verify that any firm selected to dispose of its asbestos waste will meet the requirements of paragraph 61.25 i.e. approved operation Following is Section 61.22 of the Emission standard Written notice of intention to demolish or renovate shall be provided to the Administrator by the owner or operatoorf the demolition or renovation operation Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demolition or as early as possible prior to commencement of emergency demolition subject to paragraph d of this section and as early as possible prior to commencement of renovation Such notice shall in- clude the following information i Name of owner or operator ii Address of owner or operator iii Description of the building structure facility or installation to be demolished or renovated including the size age and prior use of the structure and the approximate amount of friable asbestos materials present iv Address or location of the building facility or installation structure v Scheduled starting and completion dates of demolition or renovation vi vii Nature of planned demolition or renovation and method to be employed Procedures to ments of this this section be employed to meet the paragraph and paragraph require- j of viii The name and address or disposal site where the will be deposited location of the waste friable asbestos waste ix Name title and authority of the State or local governmental representative who has ordered a demolition which is subject to paragraph d of this section JACKSON 049664 III 14 DEPARTMENT OF TRANSPORTATION REGULATIONS The Department of Transportation DOT currently only the transportation of commercial asbestos regulate regulates They do not 1 Asbestos which has no commercial value such as products which contain trace amounts as a contaminant 49 CFR 173 1090 2 Waste asbestos which is currently proposed to be regulated under DOT hazardous waste regulations preamble to final commercial asbestos rule issued December 4 1978 3 Asbestos which is immersed or fixed in a natural or artificial binder material such as cement plastic asphalt resin or mineral ore 49 CFR 173.1090 DOT does regulate commercial asbestos which is defined as any material or product which has commercial value because of its asbestos content 49 CFR 173.1090 When regulated DOT requires that shipments of asbestos meet the following requirements 1 Packaging must be as specified in 49 CFR 173.1090 2 tight packages such as metal or fiber drums b Bags which are dust and sift proof and are unitized on a pallet Pallet loads should be encased in a shrink wrapped plastic film or fiberboard secured by strapping C. Bags placed inside wooden or fiberboard boxes 2. Each outside package must be marked with the word Asbestos and the name and address of the consignee or consignor 49 CFR 173.304 and 173.306 3. Each outside container must be marked ORM in an approp- riate rectangle 49 CFR 172.316 Labels which can be used for this purpose are available through normal Firestone stationery store channels The form number and description for ordering purposes is 8974 ORM Label 4 Asbestos shipped via the water or air mode must also meet the following shipping paper requirements 49 CFR 172.200 JACKSON 049665 15 a The total amount of commercial asbestos being shipped i.e. the net weight of the product containing commercial asbestos 49 CFR 172.202 b The proper shipping name and hazard class i.e. Asbestos ORM 49 CFR 172.202 C. If shipped on the same bill of lading with hazardous materials the asbestos entry should be before any hazardous entries or in a contrasting color highlighted 49 CFR 172.201 d A signed certification 49 CFR 172.204 There are no shipping paper requirements when commercial asbestos is shipped via truck or rail modes 49 CFR 172.200 JACKSON 049666 16 FEDERAL ASBESTOS STANDARD MEDICAL SURVEILLANCE COMPLIANCE FLOW CHART 1s exposure at or above .1 fiber longer than 5 microns as an 8 hour TWA -No- No further action is required Yes Provide medical surveillance to employees prior to placement in exposure area Y , Detailed work and medical history with particular attention to respiratory and cardiopulmonary disorders and smoking habits . Comprehensive physical examination with particular attention to respiratory and cardio- vascular systems i 1. Chest rays on x17 plate a lateral ray is strongly recommended 2. Pulmonary function tests FEV and FVC Y Are test results -No- normal Refer to Medical Surveillance Manual and consult with Corporate Medical Director Repeat tests annually and upon termination of work in exposure area JACKSON 049667 ASBESTOS MANUAL November 9 1979 The Firestone Tire & Rubber Company JACKSON 049668 CONTENTS Introduction ... eee Page 1 AsbestoMasy Still be Found in Tire Plants 22 All Other Plants 22 OSHA Regulat csico secnses csccvccccnvecccrecs oe 3 Permissible Average Exposure Limit and Ceiling Concentration 3 Air Monitoring and Sampling Frequency 3 Employee Notification and Recordkeeping of Exposure Results 4 Methods of Compliance wen cen eeenee aoe 4 Particular Tools 4 Wet Methods wet v cere sec scens 4 Spraying Demolition or Removal of Asbestos Insulation eeceee . 4 Respiratory Protective Equipment 5 Air Purifying Respirators eescees 5 Powered Air Purifying Respirator 5 Type C Supplied Respirators Continuous Flow or Pressure- demand Type eee r ence envenncce 5 Special Clothing - Clothes Lockers - Laundering ... 50 Caution Signs and Caution Labels JACKSON 049669 CONTENTS Housekeeping - Waste Disposal eaves Medical Examinations ... Asbe.s . t caco ens asenscecs oe ec cece cc ccccens A. Reason for medical surveillance . B. Forms of asbestos included ..ccscaaees C. Level of exposure D. Types of medical tests and pro.. c .. ce ece d nenau svccr cssse cesss ses E. Frequency of medical tests and procedures .. F. Interpretation of medical tests and procedures ceacrsscccccassccsesacs EPA Regulation .cccccccscccccscscuvscccnscacces Introduction .. Reason for Control of Asbestos Emissions eee eee ccnasnes ae ceanee Emission Standard for Asbestos ..ccccceccces Section 61.22 of the Emission Standard .... Department of Transportation Regulation Medical Surveillance Flow Chart 9 10 10 11 11 14 16 JACKSON 049670 1 INTRODUCTION Asbestos and materials containing asbestos are now regulated by several federal regulatory agencies The purpose of this manual is to compile in one document all applicable federal regulations and assist and guide the plants in complying with these regulations The use of asbestos or materials containing asbestos in our plants is now very limited According to the information that we have available asbestos insulation may still be used or found in the following areas Tire Plants 1. Curing area a Old pipe insulation b Curing press heat shields C. Board type asbestos insulation between press platens or domes and in the curing press frame This asbestos material is cut or machined by the McNeil Company or NRM and is only installed by Firestone people d Pipe insulation installed by McNeil or NRM on new presses that are shipped to Firestone plants e NRM well insulation 2 Powerhouse - Plants ten years old or older a Pipe insulation b Deaerator heater 3 Maintenance a Gaskets made from a material containing asbestos b Welding blankets or guards 4 Tire building - Hot knife boxes a 99R3 TAM - Asbestos tubing 1.5 o.d. = 1.25 i.d. x " long two per machine This tubing insulates the heated magnets from the rest of the assembly Asbestos tape 0.5 wide x 15 long four per machine This tape is wrapped around the heating elements and tubing described above JACKSON 049671 2 b All Radial First Stage TAM's Radial sidewall knife - Heat sink hot box Manganese wire with asbestosglass insulation AWG 14 16 required per machine All Other Plants 1 Gaskets made from a material containing asbestos that are cut to size and drilled to open holes 2 Experimental formulation of small batches of rubber products containing asbestos This is done in an Akron laboratory of the Synthetic Rubber Division Maintenance operations in plants often require the removal or demolition of old asbestos insulation The removal of asbestos insulation is of considerable importance from the standpoint of compliance with federal regulations since the potential of employee exposure to airborne asbestos fibers is usually higher than in other operations The manual is divided into three sections The first section describes the OSHA standard on asbestos The second section de- scribes the EPA regulations on asbestos which are applicable to Firestone operations The third section summarizes the current Department of Transportation regulations on asbestos JACKSON 049672 3 I. OSHA REGULATION SECTION 1910.1001 The OSHA standard on asbestos is 1001 of the OSHA standards book described in Section 1910 Permissible Average Exposure Limit and Ceiling Concentration The present hour weighted average permissible exposure limit is two 2 fibers longer than 5 microns per cubic centimeter of air The permissible ceiling exposure limit is ten 10 fibers longer than 5 microns per cubic centimeter of air as determined over a period of 15 minutes Air Monitoring and Sampling Frequency All operations where asbestos and materials containing asbestos are being used or old asbestos insulation is being removed replaced or repaired must be monitored by air sampling to determine employee exposure to airborne asbestos fibers Samples should be collected from within the breathing zone of the employees on membrane filters mounted in an open face filter holder cassette Samples should be taken for the determination of the hour weighted average concentration and of the ceiling concentration of asbestos fibers Cassettes for collecting air samples for asbestos are provided to the plants by the Industrial Hygiene Department After sampling these cassettes are returned to Industrial Hygiene for analysis and calculation of the airborne concentration of as- bestos fibers Detailed instructions on how to collect air samples for asbestos have been sent to the plant safety engineers by the Industrial Hygiene Department After the initial determination samples should be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees to asbestos fibers In no case should the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos exceeds the permissible exposure limit or the permissible ceiling concentration Affected employees or their representatives should be given an opportunity to observe the monitoring operation JACKSON 049673 4 Employee Notification and Recordkeeping of Exposure Results Any employee found to have been exposed at any time to air- borne concentrations of asbestos fibers in excess of the per- missible exposure limit or the permissible ceiling concentration must be notified in writing of the exposure as soon as practicable but not later than 5 days of the finding The employee must also be timely notified of the corrective action taken to reduce the airborne concentration of asbestos fibers Every employer must maintain records of any personal or environmental monitoring required by Section 1910.1001 Records must be maintained for a period of at least 20 years and must be made available upon request to the Assistant Secretary of Labor for OSHA the Director of NIOSH and to their authorized representa- tives Every employee and former employee shall have reasonable access to any records required to be maintained by this standard which indicate the employee's own exposure to asbestos fibers Methods of Compliance 1 Particular Tools All operated and operated tools which may produce or release asbestos fibers in excess of the exposure limits listed above such as saws scorers abrasive wheels and drills must be provided with local exhaust ventilation sys- tems 2 Wet Methods Insofar as practicable asbestos must be handled mixed applied removed cut scored or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the permissible exposure limits unless the usefulness of the product would be diminished by wetting it Spraying Demolition or Removal of Asbestos Insulation Employees engaged in the spraying of asbestos the removal or demolition of pipes structures or equipment covered or insulated with asbestos and in the removal or demolition of asbestos insulation or coverings must be provided with respiratory protective equipment and special clothing as described below JACKSON 049674 5 Respiratory Protective Equipment 1 Air Purifying respirators A reusable or single use disposable air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 2 but not greater than 20 fibers per cubic centi- meter of air 2. Powered Air Purifying Respirator A powered air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 20 but not greater than 200 fibers per cubic centimeter of air 3. Type C Supplied Respirators Continuous Flow or Pressure Type A type C continuous flow or pressure supplied respirator must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 200 fibers per cubic centimeter of air The OSHA standard specifies that employees engaged in the removal or demolition of asbestos insulation shall be provided with supplied respirators For the removal of large sections of insulation which would normally last several days a suppliedair respirator must be provided As a general guideline when the amount of asbestos to be removed is small and the operation will only last a few hours or less a supplied respirator should still be provided if feasible If this is not feasible at least an air purifying respirator should be provided Special Clothing - Clothes Lockers ~ Laundering The employer must provide and require the use of special clothing such as coveralls or similar whole body clothing head coverings gloves and foot coverings for any employee exposed to airborne concentrations of asbestos fibers which exceed the permissible exposure limits or who is engaged in the removal or demolition of asbestos insulation At any fixed place of employment exposed to airborne concentrations of asbestos fibers in excess of the permissible exposure limits the employer must provide change rooms for employees working regularly at the place JACKSON 049675 6 The employer must provide two separate lockers or containers for each employee so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes Laundering of asbestos contaminated clothing must be done so as to prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Any employer who gives asbestos contaminated clothing to another person for laundering must inform such person of the requirement to effectively prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Contaminated clothing must be transported in sealed impermeable bags or other closed impermeable containers and labeled in accordance with paragraph ii of the standard It is now common practice among employers to provide their employees who are engaged in asbestos insulation removal with disposable coveralls head coverings and shoe coverings The use of disposable protective clothing eliminates the necessity of laundering work clothes contaminated with asbestos and all other problems associated with it Caution Signs and Caution Labels Caution signs must be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the permissible exposure limits Signs must be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps before entering the area marked by the signs Signs must be posted at all approaches to areas containing excessive concentrations of asbestos fibers signs The signs must display a legend which is described in paragraph of this standard Since during the short time needed for a demolition or removal of asbestos insulation it is not usually possible to determine if the concentration of airborne fibers is above or below the permissible exposure limits caution signs should be all asbestos removal operations These signs should after the work is completed posted at be removed Caution labels must 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 JACKSON 049676 7 coating binder ably foreseeable fibers in excess released or other material so that during any reason- use no airborne concentrations of asbestos of the permissible exposure limits will be The statement that is required on the label is described in paragraph ii of this standard Housekeeping - Waste Disposal All external surfaces in any place of employment must be main- tained free of accumulations of asbestos fibers Collection of settled dust or debris should be done by vacuum cleaning Do not clean up asbestos by blowing or dry sweeping Asbestos waste scrap debris bags containers equipment and contaminated clothing that is to be disposed of must be collected and disposed of in sealed impermeable bags or other closed impermeable containers The federal regulations pertaining to asbestos waste disposal practices and procedures are described in the next section of the manual under EPA Regulations Medical Examinations The standard requires that the employer provide or make available at his cost medical examinations to each of his employees exposed to asbestos fibers The medical examinations program required by OSHA is presented below this is a copy of the medical surveillance program for asbestos which has been adopted by the Corporate Medical Department ASBESTOS A. Reason for medical surveillance 1 Required by the OSHA asbestos standard 29 CFR 1910 1001 ) B. Forms of asbestos included 1 Chrysotile 2. Amosite JACKSON 049677 8 . Crocidolite 3. Tremolite 5.5. Anthophyllite Actinolite Level of exposure 1 Airborne exposure to asbestos at or above 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour weighted average Note This definition of exposure has been established by OSHA Program Directive 300-16 effective October 11 1978 and will not be found in the original OSHA asbestos standard Types of medical tests and procedures 2 Detailed work and medical history with particular attention to a Respiratory and cardiopulmonary disorders b Smoking habits Comprehensive physical examination with particular attention to respiratory and cardiovascular systems Chest rays - PA on 14 x 17 plate a lateral ray is also strongly recommended 40 Pulmonary function tests - FEV and FVC Frequency of medical tests and procedures 1 All tests and procedures a Prior to or within 30 days after placement in an exposure area where airborne asbestos levels exceed 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour time- weighted average b At least annually while working in the exposure area BATO JACKSON 049678 9 c Within 30 days before or after termination of employment in an exposure area unless all the tests and procedures have been performed within the past year F. Interpretation of medical tests and procedures I. Chest rays should be interpreted by a radiologist 2 In order to unify and standardize the pulmonary function tests the actual administration of the tests should be done by as few people as possible The original tracing and interpretation should be given to the plant physician for A copy of each should be sent to Medical Department for short and medical management the Corporate long term interp- retation study and storage 3 Whenever an employee shows signs or symptoms of chronic malignant or malignant lung disease or cardiopulmonary disorders which may be due to occupational exposure to asbestos the Corporate Medical Department should be consulted Any abnormality in the chest rays as compared to established norms or earlier findings a definite reduction in the FEV or FVC or degeneration of the employee's general respiratory condition should be reasons for not employing or for removing the employ- ee from the asbestos exposure area The responsibility for medical removal and reinstatement is that of the plant physician in consultation with as many other physicians as he deems necessary Medical records of employees examined under this protocol including examination and test results written medical opinions and records of employee complaints should be retained for at least five years after the last employment for each employee or for twenty years from the date of the record whichever is longer JACKSON 049679 II 10 EPA REGULATION Introduction The EPA has established emission standards for certain hazardous air pollutants under its National Emission Standards for Hazardous Air Pollutants Regulations NESHAPS Asbestos currently is included as one of the four substances currently under these regulations 40 CFR Part 61 Subpart regulated The NESHAPS regulations are applicable to the following oper- ations a asbestos mills b roadways c manufacturing d demolition and renovation e) spraying f fabricating g insulating h) waste disposal Engine ring's Engine ring's Based upon Environmental Engineering's knowledge Firestone is mainly involved in Items and above EPA intentions are to administer these regulations on a state by state basis by delegating authority to the individual state air control agencies i.e. once they have met all the necessary requirements To date 31 states have been given this authority as follows Alabama Arizona California Colorado Connecticut Delaware Georgia Indiana Kentucky Maine Massachusetts Michigan Minnesota Montana Nevada New Hampshire New Jersey New York North Carolina North Dakota Oregon Pennsylvania Rhode Island South Carolina Texas Vermont Virginia Washington Wisconsin Puerto Rico and U. S. Virgin Islands These regulations i.e. NESHAPS for controlling asbestos emissions were first promulgated on April 6 1973 38 FR 8820 in fulfilling requirements under Section 112 B of the Clean Air Act as amended December 1970. Since then they have undergone various revisions the most recent of which was promulgated February 7 1979 giving the State of Texas authority to administer the NESHAPS program and issue permits etc. in the state From time to time additional pollutants which are found to be hazardous will be included under EPA NESHAPS regulations i.e. vinyl chloride was added to the original list on October 21 1976 41 FR 46560 May cause or contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness - Clean Air Act Section 112 December 1970 JACKSON 049680 11 Reason for Control of Asbestos Emissions A large number of studies have shown an association between occupational exposure to asbestos and a higher than expected incidence of bronchial cancer Asbestos also has been identi- fied as a causal factor in the development of cancers of the membranes of the chest and abdomen Emission Standard for Asbestos Basically the regulations prohibit any discharge of asbestos to the outside air which creates a visible emission which may be detected without the aid of instruments By definition out- side air means the air outside buildings or structures etc. A source can use a specified method of air cleaning fabric filter systems to eliminate such emissions provided that the emission control equipment is approved by the admin- istrator of the EPA or his authorized representative Specifically the asbestos standards are 1 There shall be no visible emissions to the outside air from any asbestos mill except when a specified method of air cleaning also part of these standards is used before the emissions escape to the outside air In general these cleaning systems filter asbestos emissions to the point that visible emissions would not be produced anyway 2 The surfacing of roadways with asbestos tailings is prohibited except for temporary roadways in an area of asbestos ore deposits 30 There shall be no visible emissions to the outside air unless the specified air cleaning methods are used from any operation which manufacturers cloth cord wicks tubing tape twine rope thread yarn roving lap other textile products cement products fireproofing and insulating materials friction products paper millboard felt floor tile paints coatings caulks adhesives sealants plastics and rubber materials and chlorine 4 The regulations covering demolition and renovation of buildings are a Asbestos materials used to insulate or fireproof any boiler pipe or structural member shall be wetted and removed from any building before the wrecking begins The asbestos debris shall be wetted at all stages of demolition and related handling operations JACKSON 049681 12 No pipe or structural member covered with asbestos insulating or fireproofing material shall be dropped or thrown from any building but shall be carefully lowered to ground level No asbestos debris shall be dropped or thrown to the ground or from one floor to another For buildings 50 feet or greater in height asbestos debris shall be lowered to the ground via tight chutes or contain- ers Written notice of intention to demolish shall be pro- vided to the EPA Regional Administrator at least 10 days prior to commencement of demolition This notice shall include items under Section 61.22 of this regulation e Certain demolition operations are exempt from the regulations except for the wetting of asbestos debris and the notification requirement if a building has been declared to be structurally unsound and in danger of imminent collapse Asbestos waste shall be sealed in tight containers while wet prior to being sent to an approved waste disposal site g The tight containers Item f should be labeled with a warning label which reads CAUTION Contains Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hazardous to Your Health The owner or operator of a demolition operation is exempted from these requirements with the exception of Item d above provided the amount of friable asbestos materials in the building or portion thereof to be de- molished is less than 80 meters ca. 260 feet used on pipes and less than 15 square meters ca. 160 square feet used on any duct boiler tank reactor turbine furnace or structural member These regulations also set forth collection processing and disposal requirements which the waste disposal firm must adhere to in handling and disposing of this waste 40 CFR 61.25 Since Firestone in most cases if not all will be utilizing outside firms for disposal of its asbestos wastes no further JACKSON 049682 13 discussion of these requirements will be presented herein Firestone however must verify that any firm selected to dispose of its asbestos waste will meet the requirements of paragraph 61.25 i.e. approved operation Following is Section 61.22 of the Emission standard Written notice of intention to demolish or renovate shall be provided to the Administrator by the owner or operatoorf the demolition or renovation operation Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demolition or as early as possible prior to commencement of emergency demolition subject to paragraph 6 of this section and as early as possible prior to commencement of renovation Such notice shall in- clude the following information i Name of owner or operator ii Address of owner or operator iii Description of the building structure facility or installation to be demolished or renovated including the size age and prior use of the structure and the approximate amount of friable asbestos materials present iv Address or location of the building facility or installation structure v Scheduled starting and completion dates of demolition or renovation vi Nature of planned demolition or renovation and method to be employed vii Procedures to ments of this this section be employed to meet the paragraph and paragraph require- j of viii The name and address or location of the waste _ disposal site where the friable asbestos waste will be deposited ix Name title and authority of the State or local governmental representative who has ordered a demolition which is subject to paragraph d of this section JACKSON 049683 III 14 DEPARTMENT OF TRANSPORTATION REGULATIONS The Department of Transportation DOT currently only the transportation of commercial asbestos regulate regulates They do not 1 Asbestos which has no commercial value such as products which contain trace amounts as a contaminant 49 CFR 173 1090 2. Waste asbestos which is currently proposed to be regulated under DOT hazardous waste regulations preamble to final commercial asbestos rule issued December 4 1978 3 Asbestos which is immersed or fixed in a natural or arti- ficial binder material such as cement plastic resin or mineral ore 49 CFR 173.1090 asphalt DOT does material asbestos regulate commercial asbestos which is or product which has commercial value content 49 CFR 173.1090 defined as because of any its When regulated DOT requires that shipments of asbestos meet the following requirements 1. Packaging must be as specified in 49 CFR 173.1090 a. tight packages such as metal or fiber drums b Bags which are dust and sift proof and are unitized on a pallet Pallet loads should be encased in a shrink wrapped plastic film or fiberboard secured by strapping C. Bags placed inside wooden or fiberboard boxes 2. Each outside package must be marked with the word Asbestos and the name and address of the consignee or consignor 49 CFR 173.304 and 173.306 3. Each outside container must be marked ORM in an approp- riate rectangle 49 CFR 172.316 Labels which can be used for this purpose are available through normal Firestone stationery store channels The form number and description for ordering purposes is 8974 ORM Label 4 Asbestos shipped via the water or air mode must also meet the following shipping paper requirements 49 CFR 172.200 JACKSON 049684 The total amount of commercial asbestos being shipped i.e. the net weight of the product containing commercial asbestos 49 CFR 172.202 The proper shipping name and hazard class Asbestos ORM 49 CFR 172.202 i.e. If shipped on the same bill ous materials the asbestos hazardous entries or in lighted CFR 172.201 of lading with hazardentry should be before any a contrasting color high- d A signed certification 49 CFR 172.204 There are no shipping paper requirements when commercial asbestos is shipped via truck or rail modes 49 CFR 172.200 JACKSON 049685 16 FEDERAL ASBESTOS STANDARD MEDICAL SURVEILLANCE COMPLIANCE FLOW CHART Is exposure at or above .1 fiber longer than 5 microns as an 8 hour TWA -No No further action is required Yes Provide medical surveillance to employees prior to placement in exposure area i Detailed work and medical history with particular attention to respiratory and cardiopulmonary disorders and smoking habits 7 Comprehensive physical examination with particular attention to respiratory and cardio- vascular systems Are test results normal Refer to Medical -No- | Surveillance Manual and consult with Corporate Medical Director Y 1. Chest rays on a x17 plate a lateral ray is strongly recommended 2. Pulmonary function tests FEV and FVC y Repeat tests annually and upon termination of work in exposure area JACKSON 049686 ASBESTOS MANUAL November 9 1979 The Firestone Tire & Rubber Company JACKSON 049687 CONTENTS Introduction i re ee Page 1 AsbestoMasy Still be Found in Tire Plants Cece c wen w ence cence scens 1 All Other Plants eaae N OSHA Regulations weeeces estes W Permissible Average Exposure Limit and Ceiling Concentration ... WW Air Monitoring and Sampling Frequency WW Employee Notification and Recordkeeping of Exposure Results 4 Methods of Compliancesees ences censeee 4 Particular Tools 4 Wet Methods 4 Spraying Demolition or Removal of Asbestos Insulation seen ccce . 4 Respiratory Protective Equipment 5 Air Purifying Respirators ew enw eeese . 5 Powered Air Purifying Respirator ees 5 Type C Supplied Respirators Continuous Flow or Pressure- demand Type eee eenee 5 Special Clothing - Clothes Lockers - Laundering .. 5 Caution Signs and Caution Labels ....seeee 6 JACKSON 049688 CONTENTS Housekeeping - Waste Disposal Medical Examinations Asbestos .... .... cece wcrc neem ccc eaccssesanscece A. Reason for medical surveillance B. Forms of asbestos included C. I. E. Level of exposure wee ceweecne oe Types of medical tests and procedures ... se necccnesencsesccesecse Frequency of medical tests and procedures ... cccccscessesnsccscecce F. Interpretation of medical tests and procedures .. nes EPA Regulation oe ese eeene enw eaweace owes Introduction Introduction ... eesvacess #ee@eesvpecespnvnseoeoaenvpeeeozoesaeoen Reason for Control of Asbestos Emissions ... ... cescecescccsccccscseceesee Emission Standard for Asbestos Section 61.22 of the Emission Standard Department of Transportation Regulation Medical Surveillance Flow Chart 7 7 7 7 7 8 8 8 9 10 10 11 11 13 14 16 JACKSON 049689 1 INTRODUCTION Asbestos and materials containing asbestos are now regulated by several federal regulatory agencies The purpose of this manual is to compile in one document all applicable federal regulations and assist and guide the plants in complying with these regulations The use of asbestos or materials containing asbestos in our plants is now very limited According to the information that we have available asbestos insulation may still be used or found in the following areas Tire Plants 1 Curing area a Old pipe insulation b Curing press heat shields C. Board type asbestos insulation between press platens or domes and in the curing press frame This asbestos material is cut or machined by the McNeil Company or NRM and is only installed by Firestone people d Pipe insulation installed by McNeil or NRM on new presses that are shipped to Firestone plants e NRM well insulation 2 Powerhouse Plants ten years old or older a Pipe insulation b Deaerator heater 3. Maintenance a Gaskets made from a material containing asbestos b Welding blankets or guards 4 Tire building - Hot knife boxes a 99R3 TAM - Asbestos tubing 1.5 o.d. - 1.25 i.d. x 1 long two per machine This tubing insulates the heated magnets from the rest of the assembly Asbestos tape 0.5 wide x 15 long four per machine This tape is wrapped around the heating elements and tubing described above JACKSON 049690 2 b All Radial First Stage TAM's Radial sidewall knife - Heat sink hot box Manganese wire with asbestosglass insulation AWG 14 16 required per machine All Other Plants 1 Gaskets made from a material containing asbestos that are cut to size and drilled to open holes 2 Experimental formulation of small batches of rubber products containing asbestos This is done in an Akron laboratory of the Synthetic Rubber Division Maintenance operations in plants often require the removal or demolition of old asbestos insulation The removal of asbestos insulation is of considerable importance from the standpoint of compliance with federal regulations since the potential of employee exposure to airborne asbestos fibers is usually higher than in other operations The manual is divided into three sections The first section describes the OSHA standard on asbestos The second section de- scribes the EPA regulations on asbestos which are applicable to Firestone operations The third section summarizes the current Department of Transportation regulations on asbestos JACKSON 049691 3 I. OSHA REGULATION SECTION 1910.1001 The OSHA standard on asbestos is 1001 of the OSHA standards book described in Section 1910 Permissible Average Exposure Limit and Ceiling Concentration The present hour weighted average permissible exposure limit is two 2 fibers longer than 5 microns per cubic centimeter of air The permissible ceiling exposure limit is ten 10 fibers longer than 5 microns per cubic centimeter of air as determined over a period of 15 minutes Air Monitorianngd Sampling Frequency All operations where asbestos and materials containing asbestos are being used or old asbestos insulation is being removed replaced or repaired must be monitored by air sampling to determine employee exposure to airborne asbestos fibers Samples should be collected from within the breathing zone of the employees on membrane filters mounted in an open face filter holder cassette Samples should be taken for the determination of the hour weighted average concentration and of the ceiling concentration of asbestos fibers Cassettes for collecting air samples for asbestos are provided to the plants by the Industrial Hygiene Department After sampling these cassettes are returned to Industrial Hygiene for analysis and calculation of the airborne concentration of as- bestos fibers Detailed instructions on how to collect air samples for asbestos have been sent to the plant safety engineers by the Industrial Hygiene Department After the initial determination samples should be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees to asbestos fibers In no case should the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos exceeds the permissible exposure limit or the permissible ceiling concentration Affected employees or their representatives should be given an opportunity to observe the monitoring operation JACKSON 049692 4 Employee Notification and Recordkeeping of Exposure Results Any employee found to have been exposed at any time to air- borne concentrations of asbestos fibers in excess of the per- missible exposure limit or the permissible ceiling concentration must be notified in writing of the exposure as soon as practicable but not later than 5 days of the finding The employee must also be timely notified of the corrective action taken to reduce the airborne concentration of asbestos fibers Every employer must maintain records of any personal or environmental monitoring required by Section 1910.1001 Records must be maintained for a period of at least 20 years and must be made available upon request to the Assistant Secretary of Labor for OSHA the Director of NIOSH and to their authorized representa- tives Every employee and former employee shall have reasonable access to any records required to be maintained by this standard which indicate the employee's own exposure to asbestos fibers Methods of Compliance 1 Particular Tools All operated and operated tools which may produce or release asbestos fibers in excess of the exposure limits listed above such as saws scorers abrasive wheels and drills must be provided with local exhaust ventilation sys- tems 2 Wet Methods Insofar as practicable asbestos must be handled mixed applied removed cut scored or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the permissible exposure limits unless the usefulness of the product would be diminished by wetting it Spraying Demolition or Removal of Asbestos Insulation Employees engaged in the spraying of asbestos the removal or demolition of pipes structures or equipment covered or insulated with asbestos and in the removal or demolition of asbestos insulation or coverings must be provided with respiratory protective equipment and special clothing as described below JACKSON 049693 5 Respiratory Protective Equipment 1 Air Purifying respirators A reusable or single use disposable air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted aver- age airborne concentration of asbestos fibers is greater than 2 but not greater than 20 fibers per cubic centimeter of air 2 Powered Air Purifying Respirator A powered air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 20 but not greater than 200 fibers per cubic centimeter of air 3. Type C Supplied Respirators Continuous Flow or Pressure Type A type C continuous flow or pressure supplied respirator must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 200 fibers per cubic centimeter of air The OSHA standard specifies that employees engaged in the removal or demolition of asbestos insulation shall be provided with supplied respirators For the removal of large sections of insulation which would normally last several days a suppliedair respirator must be provided As a general guideline when the amount of asbestos to be removed is small and the operation will only last a few hours or less a supplied respirator should still be provided if feasible If this is not feasible at least an air purifying respirator should be provided Special Clothing Clothes Lockers - Laundering The employer must provide and require the use of special clothing such as coveralls or similar whole body clothing head coverings gloves and foot coverings for any employee exposed to airborne concentrations of asbestos fibers which exceed the permissible exposure limits or who is engaged in the removal or demolition of asbestos insulation At any fixed place of employment exposed to airborne concentrations of asbestos fibers in excess of the permissible exposure limits the employer must provide change rooms for employees working regularly at the place JACKSON 049694 6 The employer must provide two separate lockers or containers for each employee so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes Laundering of asbestos contaminated clothing must be done so as to prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Any employer who gives asbestos contaminated clothing to another person for laundering must inform such person of the requirement to effectively prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Contaminated clothing must be transported in sealed impermeable bags or other closed impermeable containers and labeled in accordance with paragraph ii of the standard It is now common practice among employers to provide their employees who are engaged in asbestos insulation removal with disposable coveralls head coverings and shoe coverings The use of disposable protective clothing eliminates the necessity of laundering work clothes contaminated with asbestos and all other problems associated with it Caution Signs and Caution Labels Caution signs must be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the permissible exposure limits Signs must be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps before entering the area marked by the signs Signs must be posted at all approaches to areas containing excessive concentrations of asbestos fibers The ii The signs must display a legend which is described in paragraph 1 of this standard Since during the short time needed for a demolition or removal of asbestos insulation it is not usually possible to determine if the concentration of airborne fibers is above or below the permissible exposure limits caution signs should be all asbestos removal operations These signs should after the work is completed posted at be removed Caution labels must 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 JACKSON 049695 7 coating binder ably foreseeable fibers in excess released or other material so that during any reason- use no airborne concentrations of asbestos of the permissible exposure limits will be The statement that is required on the label is described in paragraph ii of this standard Housekeeping - Waste Disposal All external surfaces in any place of employment must be main- tained free of accumulations of asbestos fibers Collection of settled dust or debris should be done by vacuum cleaning Do not clean up asbestos by blowing or dry sweeping Asbestos waste scrap debris bags containers equipment and contaminated clothing that is to be disposed of must be collected and disposed of in sealed impermeable bags or other closed impermeable containers The federal regulations pertaining to asbestos waste disposal practices and procedures are described in the next section of the manual under EPA Regulations Medical Examinations The standard requires that the employer provide or make available at his cost medical examinations to each of his employees exposed to asbestos fibers The medical examinations program required by OSHA is presented below this is a copy of the medical surveillance program for asbestos which has been adopted by the Corporate Medical Department ASBESTOS A. Reason for medical surveillance 1. Required by the OSHA asbestos standard 29 CFR 1910 1001 j B. Forms of asbestos included 1 Chrysotile 2. Amosite JACKSON 049696 8 Crocidolite 4 Tremolite Anthophyllite 6. Actinolite Level of exposure 1 Airborne exposure to asbestos at or above 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour weighted average Note This definition of exposure has been established by OSHA Program Directive 300-16 effective October 11 1978 and will not be found in the original OSHA asbestos standard Types of medical tests and procedures 1. Detailed work and medical history with particular attention to a Respiratory and cardiopulmonary disorders b Smoking habits Comprehensive physical examination with particular attention to respiratory and cardiovascular systems Chest rays - PA on 14 x 17 plate a lateral ray is also strongly recommended 4 Pulmonary function tests - FEV and FVC Frequency of medical tests and procedures 1. All tests and procedures 2 Prior to or within 30 days after placement in an exposure area where airborne asbestos levels exceed 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour time- weighted average b At least annually while working in the exposure area JACKSON 049697 c Within 30 days before or after termination of employment in an exposure area unless all the tests and procedures have been performed within the past year F. Interpretation of medical tests and procedures 1 Chest rays should be interpreted by a radiologist 2 In order to unify and standardize the pulmonary function tests the actual administration of the tests should be done by as few people as possible The original tracing and interpretation should be given to the plant physician for medical management A copy of each should be sent to the Corporate Medical Department for short and long term interpretation study and storage Whenever an employee shows signs or symptoms of chronic malignant or malignant lung disease or cardiopulmonary disorders which may be due to occupational exposure to asbestos the Corporate Medical Department should be consulted Any abnormality in the chest rays as compared to established norms or earlier findings a definite reduction in the FEV or FVC or degeneration of the employee's general respiratory condition should be reasons for not employing or for removing the employ- ee from the asbestos exposure area The responsibility for medical removal and reinstatement is that of the plant physician in consultation with as many other physicians as he deems necessary Medical records of employees examined under this protocol including examination and test results written medical opinions and records of employee complaints should be retained for at least five years after the last employment for each employee or for twenty years from the date of the record whichever is longer JACKSON 049698 II 10 EPA REGULATION Introduction The EPA has established emission standards for certain hazardous air pollutants under its National Emission Standards for Hazardous Air Pollutants Regulations NESHAPS Asbestos currently is included as one of the four substances currently under these regulations 40 CFR Part 61 Subpart regulated The NESHAPS regulations are applicable to the following oper- ations a asbestos mills b roadways c manufacturing d demolition and renovation e spraying f fabricating g insulating h waste disposal Engine ring's Based upon Environmental Engineering's knowledge Firestone is mainly involved in Items d and above EPA intentions are to administer these regulations on a state by state basis by delegating authority to the individual state air control agencies i.e. once they have met all the necessary requirements To date 31 states have been given this authority as follows Alabama Arizona California Colorado Connecticut Delaware Georgia Indiana Kentucky Maine Massachusetts Michigan Minnesota Montana Nevada New Hampshire New Jersey New York North Carolina North Dakota Oregon Pennsylvania Rhode Island South Carolina Texas Vermont Virginia Washington Wisconsin Puerto Rico and U. S. Virgin Islands These regulations i.e. NESHAPS for controlling asbestos emissions were first promulgated on April 6 1973 38 FR 8820 in fulfilling requirements under Section 112 B of the Clean Air Act as amended December 1970. Since then they have undergone various revisions the most recent of which was promulgated February 7 1979 giving the State of Texas authority to administer the NESHAPS program and issue permits etc. in the state From time to time additional pollutants which are found to be hazardous will be included under EPA NESHAPS regulations i.e. vinyl chloride was added to the original list on October 21 1976 41 FR 46560 May cause or contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness - Clean Air Act Section 112 December 1970 JACKSON 049699 11 Reason for Control of Asbestos Emissions A large number of studies have shown an association between occupational exposure to asbestos and a higher than expected incidence of bronchial cancer Asbestos also has been identified as a causal factor in the development of cancers of the membranes of the chest and abdomen Emission Standard for Asbestos Basically the regulations prohibit any discharge of asbestos to the outside air which creates a visible emission which may be detected without the aid of instruments By definition outside air means the air outside buildings or structures A source can use a specified method of air cleaning fabric filter systems etc. to eliminate such emissions provided that the emission control equipment is approved by the administrator of the EPA or his authorized representative Specifically the asbestos standards are 1 There shall be no visible emissions to the outside air from any asbestos mill except when a specified method of air cleaning also part of these standards is used before the emissions escape to the outside air In general these cleaning systems filter asbestos emissions to the point that visible emissions would not be produced anyway 2 The surfacing of roadways with asbestos tailings is prohibited except for temporary roadways in an area of asbestos ore deposits 3 There shall be no visible emissions to the outside air unless the specified air cleaning methods are used from any operation which manufacturers cloth cord wicks tubing tape twine rope thread yarn roving lap other textile products cement products fireproofing and insulating materials friction products paper millboard felt floor tile paints coatings caulks adhesives sealants plastics and rubber materials and chlorine 4 The regulations covering demolition and renovation of buildings are a Asbestos materials used to insulate or fireproof any boiler pipe or structural member shall be wetted and removed from any building before the wrecking begins The asbestos debris shall be wetted at all stages of demolition and related handling operations JACKSON 049700 12 No pipe or structural member covered with asbestos insulating or fireproofing material shall be dropped or thrown from any building but shall be carefully lowered to ground level No asbestos debris shall be dropped or thrown to the ground or from one floor to another For buildings 50 feet or greater in height asbestos debris shall be lowered to the ground via tight chutes or contain- ers Written notice of intention to demolish shall be pro- vided to the EPA Regional Administrator at least 10 days prior to commencement of demolition This notice shall include items under Section 61.22 of this regulation e Certain demolition operations are exempt from the regulations except for the wetting of asbestos debris and the notification requirement if a building has been declared to be structurally unsound and in danger of imminent collapse f Asbestos waste shall be sealed in tight containers while wet prior to being sent to an approved waste , disposal site The tight containers Item f with a warning label which reads should be labeled CAUTION Contains Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hazardous to Your Health The owner or operator of a demolition operation is exempted from these requirements with the exception of Item d above provided the amount of friable asbestos materials in the building or portion thereof to be demolished is less than 80 meters ca. 260 feet used on pipes and less than 15 square meters ca. 160 square feet used on any duct boiler tank reactor turbine furnace or structural member These regulations also set forth collection processing and disposal requirements which the waste disposal firm must adhere to in handling and disposing of this waste 40 CFR 61.25 Since Firestone in most cases if not all will be utilizing outside firms for disposal of its asbestos wastes no further JACKSON 049701 13 discussion of these requirements will be presented herein Firestone however must verify that any firm selected to dispose of its asbestos waste will meet the requirements of paragraph 61.25 i.e. approved operation Following is Section 61.22 of the Emission standard Written notice of intention to demolish or renovate shall be provided to the Administrator by the owner or operatoorf the demolition or renovation operation Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demolition or as early as possible prior to commencement of emergency demolition subject to paragraph d of this section and as early as possible prior to commencement of renovation Such notice shall in- clude the following information i Name of owner or operator ii Address of owner or operator iii Description of the building structure facility or installation to be demolished or renovated including the size age and prior use of the structure and the approximate amount of friable asbestos materials present iv Address or location of the building facility or installation structure v Scheduled starting and completion dates of demolition or renovation vi Nature of planned demolition or renovation and method to be employed vii Procedures to ments of this this section be employed to meet the paragraph and paragraph require- j of viii The name and address or disposal site where the will be deposited location of the waste friable asbestos waste ix Name title and authority of the State or local governmental representative who has ordered a demolition which is subject to paragraph 6 of this section JACKSON 049702 III 14 DEPARTMENT OF TRANSPORTATION REGULATIONS The Department of Transportation DOT currently only the transportation of commercial asbestos regulate regulates They do not 1 Asbestos which has no commercial value such as products which contain trace amounts as a contaminant 49 CFR 173 1090 2. Waste asbestos which is currently proposed to be regulated under DOT hazardous waste regulations preamble to final commercial asbestos rule issued December 4 1978 3 Asbestos which is immersed or fixed in a natural or arti- ficial binder material such as cement plastic resin or mineral ore 49 CFR 173.1090 asphalt DOT does regulate commercial asbestos which is defined as any material or product which has commercial value because of its asbestos content 49 CFR 173.1090 When regulated DOT requires that shipments of asbestos meet the following requirements 1 Packaging must be as specified in 49 CFR 173.1090 a tight packages such as metal or fiber drums b Bags which are dust and sift proof and are unitized on a pallet Pallet loads should be encased in a shrink wrapped plastic film or fiberboard secured by strapping C. Bags placed inside wooden or fiberboard boxes 2 Each outside package must be marked with the word Asbestos and the name and address of the consignee or consignor 49 CFR 173.304 and 173.306 3 Each outside container must be marked ORM in an approp- riate rectangle 49 CFR 172.316 Labels which can be used for this purpose are available through normal Firestone stationery store channels The form number and description for ordering purposes is 8974 ORM Label 4 Asbestos shipped via the water or air mode must also meet the following shipping paper requirements 49 CFR 172.200 JACKSON 049703 15 a The total amount of commercial asbestos being shipped i.e. the net weight of the product containing commer- cial asbestos 49 CFR 172.202 b The proper shipping name and hazard class i.e. Asbestos ORM 49 CFR 172.202 C. If shipped on the same bill of lading with hazard- ous materials the asbestos entry should be before any hazardous entries or in a contrasting color high- lighte4d9 CFR 172.201 d A signed certification 49 CFR 172.204 There are no shipping paper requirements when commercial asbestos is shipped via truck or rail modes 49 CFR 172.200 JACKSON 049704 16 FEDERAL ASBESTOS STANDARD MEDICAL SURVEILLANCE COMPLIANCE FLOW CHART Is exposure at or above .1 fiber longer than 5 microns as an 8 hour TWA Nofurther -No- action is required Yes Provide medical surveillance to employees prior to placement in exposure area Detailed work and medical history with particular attention to respiratory and cardiopulmonary disorders and smoking habits < vy Comprehensive physical examination with particular attention to respiratory and cardio- vascular systems ! y 1. Chest rays on x17 plate a lateral ray is strongly recommended 2. Pulmonary function tests FEV and FVC y Are test results -No- Refer to Medical - Surveillance Manual and consult with Corporate Medical Director Repeat tests annually and upon termination of work in exposure area JACKSON 049705 ASBESTOS MANUAL November 9 1979 The Firestone Tire & Rubber Company JACKSON 049706 CONTENTS Introduction cccccccccccccscasccsvsuseercare oes Page 1 Asbestos May Still be Found in Tire Plants aac ceaee eee eecscese 1 All Other Plants wee cere cere nassene 2 OSHA Regulations ...... Permissible Average Exposure Limit and Ceiling Concentration een cees . Air Monitoring and Sampling Frequency Employee Notification and Recordkeeping of Exposure Results ween eeeee Methods of Compliance .cccceccvccccucvece Particular Tools .... c we e n ee Wet Methods eer ce cree nccccece 3 ww ww 4 / Spraying Demolition or Removal of Asbestos Insulation 4 S Respiratory Protective Equipment Air Purifying Respirators ..... Powered Air Purifying Respirator Type C Supplied Respirators Continuous Flow or Pressure- demand Type 5 Special Clothing - Clothes Lockers - Laundering .-cccccscccccssssces eeesce 5 Caution Signs and Caution Labels .ccvcene 6 JACKSON 049707 CONTENTS Housekeeping - Waste Disposal eeeeee Page 7 Medical Examinations ....csccccccccccccevscces 7 Asbestos ... ... carer scc cscs a sanasesancasscees 7 A. Reason for medical surveillance 7 B. Forms of asbestos included 7 C. Level of exposure .. oe 8 D. Typeosf medical tests and procedures ... cccccccneccccrscccaces 8 E. Frequency of medical tests and procedures were cece nsec ceaee . 00 F. Interpretation of medical tests and procedures eee 9 EPA Regulation wee e ccc r ec esecccens eecee 10 Introduction ccccesccccsssses cane wccassccses 10 Reason for Control of Asbestos Emics cc es sc cci c so ennans aenesevccces 11 Emission Standard for Asbestos 11 Section 61.22 of the Emission Standard 13 Department of Transportation Regulation 14 Medical Surveillance Flow Chart 16 JACKSON 049708 1 INTRODUCTION Asbestos and materials containing asbestos are now regulated by several federal regulatory agencies The purpose of this manual is to compile in one document all applicable federal regulations and assist and guide the plants in complying with these regulations The use of asbestos or materials containing asbestos in our plants is now very limited According to the information that we have available asbestos insulation may still be used or found in the following areas Tire Plants 1. Curing area 2 Old pipe insulation b Curing press heat shields C. Board type asbestos insulation between press platens or domes and in the curing press frame This asbestos material is cut or machined by the McNeil Company or NRM and is only installed by Firestone people d Pipe insulation installed by McNeil or NRM on new presses that are shipped to Firestone plants e NRM well insulation 2 Powerhouse - Plants ten years old or older a Pipe insulation b Deaerator heater 3. Maintenance 2 Gaskets made from a material containing asbestos b Welding blankets or guards 4 Tire building - Hot knife boxes a 99R3 TAM ~ Asbestos tubing 1.5 o.d. - 1.25 i.d. x 1 long two per machine This tubing insulates the heated magnets from the rest of the assembly Asbestos tape 0.5 wide x 15 long four per machine This tape is wrapped around the heating elements and tubing described above JACKSON 049709 2 b All Radial First Stage TAM's Radial sidewall knife - Heat sink hot box Manganese wire with asbestosglass insulation AWG 14 16 required per machine All Other Plants 1 Gaskets made from a material containing asbestos that are cut to size and drilled to open holes 2 Experimental formulation of small batches of rubber products containing asbestos This is done in an Akron laboratory of the Synthetic Rubber Division Maintenance operations in plants often require the removal or demolition of old asbestos insulation The removal of asbestos insulation is of considerable importance from the standpoint of compliance with federal regulations since the potential of employee exposure to airborne asbestos fibers is usually higher than in other operations The manual is divided into three sections The first section describes the OSHA standard on asbestos The second section de- scribes the EPA regulations on asbestos which are applicable to Firestone operations The third section summarizes the current Department of Transportation regulations on asbestos JACKSON 049710 3 ( I. OSHA REGULATION SECTION 1910.1001 The OSHA standard on asbestos is 1001 of the OSHA standards book described in Section 1910 Permissible Average Exposure Limit and Ceiling Concentration The present hour weighted average permissible exposure limit is two 2 fibers longer than 5 microns per cubic centimeter of air The permissible ceiling exposure limit is ten 10 fibers longer than 5 microns per cubic centimeter of air as determined over a period of 15 minutes Air Monitoring and Sampling Frequency All operations where asbestos and materials containing asbestos are being used or old asbestos insulation is being removed replaced or repaired must be monitored by air sampling to determine employee exposure to airborne asbestos fibers Samples should be collected from within the breathing zone of the employees on membrane filters mounted in an open face filter holder cassette Samples should be taken for the determination of the hour weighted average concentration and of the ceiling concentration of asbestos fibers Cassettes for collecting air samples for asbestos are provided to the plants by the Industrial Hygiene Department After sampling these cassettes are returned to Industrial Hygiene for analysis and calculation of the airborne concentration of as- bestos fibers Detailed instructions on how to collect air samples for asbestos have been sent to the plant safety engineers by the Industrial Hygiene Department After the initial determination samples should be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees to asbestos fibers In no case should the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos exceeds the permissible exposure limit or the permissible ceiling concentration Affected employees or their representatives should be given an opportunity to observe the monitoring operation JACKSON 049711 4 Employee Notification and Recordkeeping of Exposure Results Any employee found to have been exposed at any time to air- borne concentrations of asbestos fibers in excess of the per- missible exposure limit or the permissible ceiling concentration must be notified in writing of the exposure as soon as practicable but not later than 5 days of the finding The employee must also be timely notified of the corrective action taken to reduce the airborne concentration of asbestos fibers Every employer must maintain records of any personal or environmental monitoring required by Section 1910.1001 Records must be maintained for a period of at least 20 years and must be made available upon request to the Assistant Secretary of Labor for OSHA the Director of NIOSH and to their authorized representa- tives Every employee and former employee shall have reasonable access to any records required to be maintained by this standard which indicate the employee's own exposure to asbestos fibers Methods of Compliance 1 Particular Tools All operated and operated tools which may produce or release asbestos fibers in excess of the exposure limits listed above such as saws scorers abrasive wheels and drills must be provided with local exhaust ventilation sys- tems 2. Wet Methods Insofar as practicable asbestos must be handled mixed applied removed cut scored or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the permissible exposure limits unless the usefulness of the product would be diminished by wetting it Spraying Demolition or Removal of Asbestos Insulation Employees engaged in the spraying of asbestos the removal or demolition of pipes structures or equipment covered or insulated with asbestos and in the removal or demolition of asbestos insulation or coverings must be provided with respiratory protective equipment and special clothing as described below JACKSON 049712 5 Respiratory Protective Equipment 1 Air Purifying respirators A reusable or single use disposable air purifying res- pirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 2 but not greater than 20 fibers per cubic centi- meter of air 2. Powered Air Purifying Respirator A powered air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 20 but not greater than 200 fibers per cubic centimeter of air 3. Type C Supplied Respirators Continuous Flow or Pressure Type A type C continuous flow or pressure supplied respirator must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 200 fibers per cubic centimeter of air The OSHA standard specifies that employees engaged in the removal or demolition of asbestos insulation shall be provided with supplied respirators For the removal of large sections of insulation which would normally last several days a suppliedair respirator must be provided As a general guideline when the amount of asbestos to be removed is small and the operation will only last a few hours or less a supplied respirator should still be provided if feasible If this is not feasible at least an air purifying respirator should be provided Special Clothing - Clothes Lockers - Laundering The employer must provide and require the use of special clothing such as coveralls or similar whole body clothing head coverings gloves and foot coverings for any employee exposed to airborne concentrations of asbestos fibers which exceed the permissible exposure limits or who is engaged in the removal or demolition of asbestos insulation At any fixed place of employment exposed to airborne concentrations of asbestos fibers in excess of the permissible exposure limits the employer must provide change rooms for employees working regularly at the place JACKSON 049713 6 The employer must provide two separate lockers or containers for each employee so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes Laundering of asbestos contaminated clothing must be done so as to prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Any employer who gives asbestos contaminated clothing to another person for laundering must inform such person of the requirement to effectively prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Contaminated clothing must be transported in sealed impermeable bags or other closed impermeable containers and labeled in accordance with paragraph ii of the standard It is now common practice among employers to provide their employees who are engaged in asbestos insulation removal with disposable coveralls head coverings and shoe coverings The use of disposable protective clothing eliminates the necessity of laundering work clothes contaminated with asbestos and all other problems associated with it Caution Signs and Caution Labels Caution signs must be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the permissible exposure limits Signs must be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps before entering the area marked by the signs Signs must be posted at all approaches to areas containing excessive concentrations of asbestos fibers The signs must display a legend which is described in paragraph g ii of this standard Since during the short time needed for a demolition or removal of asbestos insulation it is not usually possible to determine if the concentration of airborne fibers is above or below the permissible exposure limits caution signs should be all asbestos removal operations These signs should after the work is completed posted at be removed Caution labels must 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 JACKSON 049714 coating binder ably foreseeable fibers in excess released or other material so that during any reason- use no airborne concentrations of asbestos of the permissible exposure limits will be The statement that is required on the label paragraph ii of this standard is described in Housekeeping - Waste Disposal All external surfaces in any place of employment must be main- tained free of accumulations of asbestos fibers Collection of settled dust or debris should be done by vacuum cleaning Do not clean up asbestos by blowing or dry sweeping Asbestos waste scrap debris bags containers equipment and contaminated clothing that is to be disposed of must be collected and disposed of in sealed impermeable bags or other closed impermeable containers The federal regulations pertaining to asbestos waste disposal practices and procedures are described in the next section of the manual under EPA Regulations Medical Examinations The standard requires that the employer provide or make available at his cost medical examinations to each of his employees exposed to asbestos fibers The medical examinations program required by OSHA is presented below this is a copy of the medical surveillance program for asbestos which has been adopted by the Corporate Medical Department ASBESTOS A. Reason for medical surveillance 1. Required by the OSHA asbestos standard 29 CFR 1910 1001 ) B. Forms of asbestos included 1 Chrysotile 2. Amosite JACKSON 049715 8 Crocidolite 3 . Tremolite 6.. Anthophyllite Actinolite Level of exposure 1 Airborne exposure to asbestos at or above 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour weighted average Note This definition of exposure has been established by OSHA Program Directive 300-16 effective October 11 1978 and will not be found in the original OSHA asbestos standard Types of medical tests and procedures 1. Detailed work and medical history with particular attention to a Respiratory and cardiopulmonary disorders D. Smoking habits Comprehensive physical examination with particular attention to respiratory and cardiovascular systems Chest rays - PA on 14 x 17 plate a lateral ray is also strongly recommended 4. Pulmonary function tests - FEV1 and FVC Frequency of medical tests and procedures 1. All tests and procedures a Prior to or within 30 days after placement in an exposure area where airborne asbestos levels exceed 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour time- weighted average b At least annually while working in the exposure area JACKSON 049716 9 C. Within 30 days before or after termination of employment in an exposure area unless all the tests and procedures have been performed within the past year F. Interpretation of medical tests and procedures 1 Chest rays should be interpreted by a radiologist 2 In order to unify and standardize the pulmonary function tests the actual administration of the tests should be done by as few people as possible The original tracing and interpretation should be given to the plant physician for medical management A copy of each should be sent to the Corporate Medical Department for short and long term interpretation study and storage Whenever an employee shows signs or symptoms of chronic malignant or malignant lung disease or cardiopulmonary disorders which may be due to occupational exposure to asbestos the Corporate Medical Department should be consulted Any abnormality in the chest rays as compared to established norms or earlier findings a definite reduction in the FEV or FVC or degeneration of the employee's general respiratory condition should be reasons for not employing or for removing the employ- ee from the asbestos exposure area The responsibility for medical removal and reinstatement is that of the plant physician in consultation with as many other physicians as he deems necessary Medical records of employees examined under this protocol including examination and test results written medical opinions and records of employee complaints should be retained for at least five years after the last employment for each employee or for twenty years from the date of the record whichever is longer JACKSON 049717 II 10 EPA REGULATION Introduction The EPA has established emission standards for certain hazardous air pollutants under its National Emission Standards for Hazardous Air Pollutants Regulations NESHAPS Asbestos currently is included as one of the four substances currently under these regulations 40 CFR Part 61 Subpart regulated The NESHAPS regulations are applicable to the following oper- ations a asbestos mills b roadways c) manufacturing ad) demolition and renovation e) spraying f) fabricating g insulating h waste disposal Engine ring's Based upon Environmental Engineering's knowledge Firestone is mainly involved in Items and h above EPA intentions are to administer these regulations on a state by state basis by delegating authority to the individual state air control agencies i.e. once they have met all the necessary requirements To date 31 states have been given this authority as follows Alabama Arizona California Colorado Connecticut Delaware Georgia Indiana Kentucky Maine Massachusetts Michigan Minnesota Montana Nevada New Hampshire New Jersey New York North Carolina North Dakota Oregon Pennsylvania Rhode Island South Carolina Texas Vermont Virginia Washington Wisconsin Puerto Rico and U. S. Virgin Islands These regulations i.e. NESHAPS for controlling asbestos emissions were first promulgated on April 6 1973 38 FR 8820 in fulfilling requirements under Section 112 B of the Clean Air Act as amended December 1970. Since then they have under- gone various revisions the most recent of which was promulgated February 7 1979 giving the State of Texas authority to administer the NESHAPS program and issue permits etc. in the state From time to time additional pollutants which are found to be hazardous will be included under EPA NESHAPS regulations i.e. vinyl chloride was added to the original list on October 21 1976 41 FR 46560 1May cause or contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness - Clean Air Act Section 112 December 1970 JACKSON 049718 11 Reason for Control of Asbestos Emissions . A large number of studies have shown an association between occupational exposure to asbestos and a higher than expected incidence of bronchial cancer Asbestos also has been identi- fied a causal factor in the development of cancers of the membranes of the chest and abdomen Emission Standard for Asbestos Basically the regulations prohibit any discharge of asbestos to the outside air which creates a visible emission which may be detected without the aid of instruments By definition outside air means the air outside buildings or structures etc. A source can use a specified method of air cleaning fabric filter systems to eliminate such emissions provided that the emission control equipment is approved by the admin- istrator of the EPA or his authorized representative Specifically the asbestos standards are 1 There shall be no visible emissions to the outside air from any asbestos mill except when a specified method of air cleaning also part of these standards is used before the emissions escape to the outside air In general these cleaning systems filter asbestos emissions to the point that visible emissions would not be produced anyway 2 The surfacing of roadways with asbestos tailings is prohibited except for temporary roadways in an area of asbestos ore deposits 3 There shall be no visible emissions to the outside air unless the specified air cleaning methods are used from any operation which manufacturers cloth cord wicks tubing tape twine rope thread yarn roving lap other textile products cement products fireproofing and insulating materials friction products paper millboard felt floor tile paints coatings caulks adhesives sealants plastics and rubber materials and chlorine 4 The regulations covering demolition and renovation of buildings are 8 Asbestos materials used to insulate or fireproof any boiler pipe or structural member shall be wetted and removed from any building before the wrecking begins The asbestos debris shall be wetted at all stages of demolition and related handling operations JACKSON 049719 12 No pipe or structural member covered with asbestos insulating or fireproofing material shall be dropped or thrown from any building but shall be carefully lowered to ground level No asbestos debris shall be dropped or thrown to the ground or from one floor to another For buildings 50 feet or greater in height asbestos debris shall be lowered to the ground via tight chutes or contain- ers Written notice of intention to demolish shall be pro- vided to the EPA Regional Administrator at least 10 days prior to commencement of demolition This notice shall include items under Section 61.22 of this regulation Certain demolition operations are exempt from the regulations except for the wetting of asbestos debris and the notification requirement if a building has been declared to be structurally unsound and in danger of imminent collapse Asbestos waste shall be sealed in tight containers while wet prior to being sent to an approved waste disposal site The tight containers Item f with a warning label which reads should be labeled CAUTION Contains Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hazardous to Your Health The owner or operator of a demolition operation is exempted from these requirements with the exception of Item d above provided the amount of friable asbestos materials in the building or portion thereof to be de- molished is less than 80 meters ca. 260 feet used on pipes and less than 15 square meters ca. 160 square feet used on any duct boiler tank reactor turbine furnace or structural member These regulations also set forth collection processing and disposal requirements which the waste disposal firm must adhere to in handling and disposing of this waste 40 CFR 61.25 Since Firestone in most cases if not all will be utilizing outside firms for disposal of its asbestos wastes no further BATO JACKSON 049720 13 ~ discussion of these requirements will be presented herein Firestone however must verify that any firm selected to dis- pose of its asbestos waste will meet the requirements of paragraph 61.25 i.e. approved operation Following is Section 61.22 of the Emission standard Written notice of intention to demolish or renovate shall be provided to the Administrator by the owner or operatoorf the demolition or renovation operation Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demolition or as early as possible prior to commencement of emergency demolition subject to paragraph 6 of this section and as early as possible prior to commencement of renovation Such notice shall in- clude the following information i Name of owner or operator ii Address of owner or operator iii Description of the building structure facility or installation to be demolished or renovated including the size age and prior use of the structure and the approximate amount of friable asbestos materials present iv Address or location of the facility or installation building structure v Scheduled starting and completion dates of demolition or renovation vi Nature of planned demolition or renovation and method to be employed vii Procedures to ments of this this section be employed to meet the paragraph and paragraph require- ) of viii The name and address or disposal site where the will be deposited location of the waste friable asbestos waste ix Name title and authority of the State or local governmental representative who has ordered a demolition which is subject to paragraph d of this section JACKSON 049721 III 14 DEPARTMENT OF TRANSPORTATION REGULATIONS The Department of Transportation DOT currently only the transportation of commercial asbestos regulate regulates They do not 1 Asbestos which has no commercial value such as products which contain trace amounts as a contaminant 49 CFR 173 1090 2. Waste asbestos which is currently proposed to be regulated under DOT hazardous waste regulations preamble to final commercial asbestos rule issued December 4 1978 3 Asbestos which is immersed or fixed in a natural or arti- ficial binder material such as cement plastic resin or mineral ore 49 CFR 173.1090 asphalt DOT does material asbestos regulate commercial asbestos which is defined as or product which has commercial value because of content 49 CFR 173.1090 any its When regulated DOT requires that shipments of asbestos meet the following requirements 1 Packaging must be as specified in 49 CFR 173.1090 2 tight packages such as metal or fiber drums b Bags which are dust and sift proof and are unitized on a pallet Pallet loads should be encased in a shrink wrapped plastic film or fiberboard secured by strapping C. Bags placed inside wooden or fiberboard boxes 2 Each outside package must be marked with the word Asbestos and the name and address of the consignee or consignor 49 CFR 173.304 and 173.306 3 Each outside container must be marked ORM in an approp- riate rectangle 49 CFR 172.316 Labels which can be used for this purpose are available through normal Firestone stationery store channels The form number and description for ordering purposes is 8974 ORM Label 4 Asbestos shipped via the water or air mode must also meet the following shipping paper requirements 49 CFR 172.200 BATO JACKSON 049722 15 The total amount of commercial asbestos being shipped i.e. the net weight of the product containing commercial asbestos 49 CFR 172.202 The proper shipping name and hazard class Asbestos ORM 49 CFR 172.202 i.e. If shipped on the same bill ous materials the asbestos hazardous entries or in lighte4d9 CFR 172.201 of lading with hazardentry should be before any a contrasting color high- d A signed certification 49 CFR 172.204 There are no shipping paper requirements when commercial asbestos is shipped via truck or rail modes 49 CFR 172.200 JACKSON 049723 o 16 FEDERAL ASBESTOS STANDARD MEDICAL SURVEILLANCE COMPLIANCE FLOW CHART Is exposure at or above .1 fiber longer than 5 microns as an 8 hour TWA -No- No further action is required Yes Provide medical surveillance to employees prior to placement in exposure area y 1 Detailed work and medical history with particular attention to respiratory and cardiopulmonary disorders and smoking habits bd Comprehensive physical examination with particular attention to respiratory and cardio- vascular systems j 1. Chest rays on x17 plate a lateral ray is strongly recommended 2. Pulmonary function tests FEV and FVC Y Are test results -No- normal Refer to Medical Surveillance Manual and consult with Corporate Medical Director Repeat tests annually and upon termination of work in exposure area JACKSON 049724 ASBESTOS MANUAL November 9 1979 The Firestone Tire & Rubber Company JACKSON 049725 CONTENTS Introduction ... eee e wc eee cece encene Page 1 AsbestoMasy Still be Found in Tire Plants wee sereseee 22 All Other Plants ..ccccccccsccccccccvvsess 22 OSHA Regulations oer wasensecess eenee 3 Permissible Average Exposure Limit and Ceiling Concentration ...... Air Monitoring and Sampling Frequency Employee Notification and Recordkeeping of Exposure Results ac ee ce e eee Methods of cceccccecceces wee Compliance Particular Tools eeees + Wet Methods ... owcases ves eenece Spraying Demolition or Removal of Asbestos Insulation ve easee 4 75 Respiratory Protective Equipment Air Purifying Respirators Powered Air Purifying Respirator Type C Supplied Respirators Continuous Flow or Pressure- demand Type .... LY Special Clothing - Clothes Lockers - Laundering c wee ecw eseee eceees 56 Caution Signs and Caution Labels 56 BATO JACKSON 049726 CONTENTS Page 7 Medical Examinations ....ccccccescerceens esses 7 Asbestos 7 A. Reason for medical surveillance . B. Forms of asbestos included ..eseccsees 7 C. Level of exposure . D. Types of medical tests and pro.. c .... ...e . ceed c enu ce nr cncse ccnss ece E. Frequency of medical tests and proce ced ca u cccr ccce cccs ceecceas eanee F. Interpretation of medical tests and procedures EPA Regulation wcrc cece cccces Introduction cccscccccccccccassssnnssanseecs 9 10 10 Reason for Control of Asbestos Emissions ee 11 Emission Standard for Asbestos 11 Section 61.22 of the Emission Standard Department of Transportation Regulation 14 Medical Surveillance Flow Chart .... 16 JACKSON 049727 1 INTRODUCTION Asbestos and materials containing asbestos are now regulated by several federal regulatory agencies The purpose of this manual is to compile in one document all applicable federal regulations and assist and guide the plants in complying with these regulations The use of asbestos or materials containing asbestos in our plants is now very limited According to the information that we have available asbestos insulation may still be used or found in the following areas Tire Plants 1 Curing area 2 Old pipe insulation b Curing press heat shields C. Board type asbestos insulation between press platens or domes and in the curing press frame This asbestos material is cut or machined by the McNeil Company or NRM and is only installed by Firestone people d Pipe insulation installed by McNeil or NRM on new presses that are shipped to Firestone plants e NRM well insulation 2 Powerhouse - Plants ten years old or older a Pipe insulation b Deaerator heater 3. Maintenance a Gaskets made from a material containing asbestos b Welding blankets or guards 4 Tire building - Hot knife boxes a 99R3 TAM - Asbestos tubing 1.5 o.d. - 1.25 i.d. x " long two per machine This tubing insulates the heated magnets from the rest of the assembly Asbestos tape 0.5 wide x 15 long four per machine This tape is wrapped around the heating elements and tubing described above JACKSON 049728 2 b All Radial First Stage TAM's Radial sidewall knife - Heat sink hot box Manganese wire with asbestosglass insulation AWG 14 16 required per machine All Other Plants 1 Gaskets made from a material containing asbestos that are cut to size and drilled to open holes 2 Experimental formulation of small batches of rubber products containing asbestos This is done in an Akron laboratory of the Synthetic Rubber Division Maintenance operations in plants often require the removal or demolition of old asbestos insulation The removal of asbestos insulation is of considerable importance from the standpoint of compliance with federal regulations since the potential of employee exposure to airborne asbestos fibers is usually higher than in other operations The manual is divided into three sections The first section describes the OSHA standard on asbestos The second section de- scribes the EPA regulations on asbestos which are applicable to Firestone operations The third section summarizes the current Department of Transportation regulations on asbestos JACKSON 049729 3 I. OSHA REGULATION SECTION 1910.1001 The OSHA standard on asbestos is 1001 of the OSHA standards book described in Section 1910 Permissible Average Exposure Limit and Ceiling Concentration The present hour weighted average permissible exposure limit is two 2 fibers longer than 5 microns per cubic centimeter of air The permissible ceiling exposure limit is ten 10 fibers longer than 5 microns per cubic centimeter of air as determined over a period of 15 minutes Air Monitoring and Sampling Frequency All operations where asbestos and materials containing asbestos are being used or old asbestos insulation is being removed replaced or repaired must be monitored by air sampling to determine employee exposure to airborne asbestos fibers Samples should be collected from within the breathing zone of the employees on membrane filters mounted in an open face filter holder cassette Samples should be taken for the determination of the hour weighted average concentration and of the ceiling concentration of asbestos fibers Cassettes for collecting air samples for asbestos are provided to the plants by the Industrial Hygiene Department After sampling these cassettes are returned to Industrial Hygiene for analysis and calculation of the airborne concentration of as- bestos fibers Detailed instructions on how to collect air samples for asbestos have been sent to the plant safety engineers by the Industrial Hygiene Department After the initial determination samples should be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees to asbestos fibers In no case should the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos exceeds the permissible exposure limit or the permissible ceiling concentration Affected employees or their representatives should be given an opportunity to observe the monitoring operation JACKSON 049730 4 Employee Notification and Recordkeeping of Exposure Results Any employee found to have been exposed at any time to air- borne concentrations of asbestos fibers in excess of the per- missible exposure limit or the permissible ceiling concentration must be notified in writing of the exposure as soon as practicable but not later than 5 days of the finding The employee must also be timely notified of the corrective action taken to reduce the airborne concentration of asbestos fibers Every employer must maintain records of any personal or environmental monitoring required by Section 1910.1001 Records must be maintained for a period of at least 20 years and must be made available upon request to the Assistant Secretary of Labor for OSHA the Director of NIOSH and to their authorized representa- tives Every employee and former employee shall have reasonable access to any records required to be maintained by this standard which indicate the employee's own exposure to asbestos fibers Methods of Compliance 1 Particular Tools All operated and operated tools which may produce or release asbestos fibers in excess of the exposure limits listed above such as saws scorers abrasive wheels and drills must be provided with local exhaust ventilation sys- tems 2 Wet Methods Insofar as practicable asbestos must be handled mixed applied removed cut scored or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the permissible exposure limits unless the usefulness of the product would be diminished by wetting it Spraying Demolition or Removal of Asbestos Insulation Employees engaged in the spraying of asbestos the removal or demolition of pipes structures or equipment covered or insulated with asbestos and in the removal or demolition of asbestos insulation or coverings must be provided with respiratory protective equipment and special clothing as described below JACKSON 049731 5 Respiratory Protective Equipment 1. Air Purifying respirators A reusable or single use disposable air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted aver- age airborne concentration of asbestos fibers is greater than 2 but not greater than 20 fibers per cubic centi- meter of air 2. Powered Air Purifying Respirator A powered air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 20 but not greater than 200 fibers per cubic centimeter of air 3. Type C Supplied Respirators Continuous Flow or Pressure Type A type C continuous flow or pressure supplied respirator must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 200 fibers per cubic centimeter of air The OSHA standard specifies that employees engaged in the removal or demolition of asbestos insulation shall be provided with supplied respirators For the removal of large sections of insulation which would normally last several days a suppliedair respirator must be provided As a general guideline when the amount of asbestos to be removed is small and the operation will only last a few hours or less a supplied respirator should still be provided if feasible If this is not feasible at least an air purifying respirator should be provided Special Clothing - Clothes Lockers - Laundering The employer must provide and require the use of special clothing such as coveralls or similar whole body clothing head coverings gloves and foot coverings for any employee exposed to airborne concentrations of asbestos fibers which exceed the permissible exposure limits or who is engaged in the removal or demolition of asbestos insulation At any fixed place of employment exposed to airborne concentra- tions of asbestos fibers in excess of the permissible exposure limits the employer must provide change rooms for employees working regularly at the place . JACKSON 049732 6 The employer must provide two separate lockers or containers for each employee so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes Laundering of asbestos contaminated clothing must be done so as to prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Any employer who gives asbestos contaminated clothing to another person for laundering must inform such person of the requirement to effectively prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Contaminated clothing must be transported in sealed impermeable bags or other closed impermeable containers and labeled in accordance with paragraph ii of the standard It is now common practice among employers to provide their employees who are engaged in asbestos insulation removal with disposable coveralls head coverings and shoe coverings The use of disposable protective clothing eliminates the necessity of laundering work clothes contaminat wietd h asbestos and all other problems associated with it Caution Signs and Caution Labels Caution signs must be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the permissible exposure limits Signs must be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps before entering the area marked by the signs Signs must be posted at all approaches to areas containing excessive concentrations of asbestos fibers ii The signs must display a legend which is described in paragraph g of this standard Since during the short time needed for a demolition or removal of asbestos insulation it is not usually possible to determine if the concentration of airborne fibers is above or below the permissible exposure limits caution signs should be all asbestos removal operations These signs should after the work is completed posted at be removed Caution labels must 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 JACKSON 049733 7 coating binder ably foreseeable fibers in excess released or other material so that during any reason- use no airborne concentrations of asbestos of the permissible exposure limits will be The statement that is required on the label is described in paragraph ii of this standard Housekeeping - Waste Disposal All external surfaces in any place of employment must be main- tained free of accumulations of asbestos fibers Collection of settled dust or debris should be done by vacuum cleaning Do not clean up asbestos by blowing or dry sweeping Asbestos waste scrap debris bags containers equipment and contaminated clothing that is to be disposed of must be collected and disposed of in sealed impermeable bags or other closed impermeable containers The federal regulations pertaining to asbestos waste disposal practices and procedures are described in the next section of the manual under EPA Regulations Medical Examinations The standard requires that the employer provide or make available at his cost medical examinations to each of his employees exposed to asbestos fibers The medical examinations program required by OSHA is presented below this is a copy of the medical surveillance program for asbestos which has been adopted by the Corporate Medical Department ASBESTOS A. Reason for medical surveillance 1 Required by the OSHA asbestos standard 29 CFR 1910 1001 ) B. Forms of asbestos included 1 Chrysotile 2. Amosite JACKSON 049734 Crocidolite 3 Tremolite .. Anthophyllite 5 Actinolite Level of exposure 1 Airborne exposure to asbestos at or above 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour weighted average Note This definition of exposure has been established by OSHA Program Directive 300-16 effective October 11 1978 and will not be found in the original OSHA asbestos standard Types of medical tests and procedures 1 Detailed work and medical history with particular attention to a Respiratory and cardiopulmonary disorders b Smoking habits Comprehensive physical examination with particular attention to respiratory and cardiovascular systems Chest rays - PA on 14 x 17 plate a lateral ray is also strongly recommended 4 Pulmonary function tests - FEV and FVC Frequency of medical tests and procedures 1. All tests and procedures 3 Prior to or within 30 days after placement in an exposure area where airborne asbestos levels exceed 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour time- weighted average b At least annually while working in the exposure area JACKSON 049735 9 C. Within 30 days before or after termination of employment in an exposure area unless all the tests and procedures have been performed within the past year F Interpretation of medical tests and procedures 1 Chest rays should be interpreted by a radiologist 2 In order to unify and standardize the pulmonary function tests the actual administration of the tests should be done by as few people as possible The original tracing and interpretation should be given to the plant physician for medical management A copy of each should be sent to the Corporate Medical Department for short and long term interpretation study and storage Whenever an employee shows signs or symptoms of chronic malignant or malignant lung disease or cardiopulmonary disorders which may be due to occupational exposure to asbestos the Corporate Medical Department should be consulted Any abnormality in the chest rays as compared to established norms or earlier findings a definite reduction in the FEV or FVC or degeneration of the employee's general respiratory condition should be reasons for not employing or for removing the employ- ee from the asbestos exposure area The responsibility for medical removal and reinstatement is that of the plant physician in consultation with as many other physicians as he deems necessary Medical records of employees examined under this protocol including examination and test results written medical opinions and records of employee complaints should be retained for at least five years after the last employment for each employee or for twenty years from the date of the record whichever is longer JACKSON 049736 II 10 EPA REGULATION Introduction The EPA has established emission standards for certain hazardous air pollutants under its National Emission Standards for Hazardous Air Pollutants Regulations NESHAPS Asbestos currently is included as one of the four substances currently under these regulations 40 CFR Part 61 Subpart regulated The NESHAPS regulations are applicable to the following oper- ations a asbestos mills b roadways c manufacturing d demolition and e) spraying ) fabricating g insulating h waste disposal renovation Engine ring's Based upon Environmental Engineering's knowledge Firestone is mainly involved in Items d and above EPA intentions are to administer these regulations on a state by state basis by delegating authority to the individual state air control agencies i.e. once they have met all the necessary requirements To date 31 states have been given this authority as follows Alabama Arizona California Colorado Connecticut Delaware Georgia Indiana Kentucky Maine Massachusetts Michigan Minnesota Montana Nevada New Hampshire New Jersey New York North Carolina North Dakota Oregon Pennsylvania Rhode Island South Carolina Texas Vermont Virginia Washington Wisconsin Puerto Rico and U. S. Virgin Islands These regulations i.e. NESHAPS for controlling asbestos emissions were first promulgated on April 6 1973 38 FR 8820 in fulfilling requirements under Section 112 B of the Clean Air Act as amended December 1970. Since then they have undergone various revisions the most recent of which was promulgated February 7 1979 giving the State of Texas authority to administer the NESHAPS program and issue permits etc. in the state From time to time additional pollutants which are found to be hazardousl will be included under EPA NESHAPS regulations i.e. vinyl chloride was added to the original list on October 21 1976 41 FR 46560 May cause or contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness - Clean Air Act Section 112 December 1970 JACKSON 049737 11 Reason for Control of Asbestos Emissions A large number of studies have shown an association between occupational exposure to asbestos and a higher than expected incidence of bronchial cancer Asbestos also has been identi- fied as a causal factor in the development of cancers of the membranes of the chest and abdomen Emission Standard for Asbestos Basically the regulations prohibit any discharge of asbestos to the outside air which creates a visible emission which may be detected without the aid of instruments By definition outside air means the air outside buildings or structures etc. A source can use a specified method of air cleaning fabric filter systems to eliminate such emissions provided that the emission control equipment is approved by the admin- istrator of the EPA or his authorized representative Specifically the asbestos standards are 1 There shall be no visible emissions to the outside air from any asbestos mill except when a specified method of air cleaning also part of these standards is used before the emissions escape to the outside air In general these cleaning systems filter asbestos emissions to the point that visible emissions would not be produced anyway 2 The surfacing of roadways with asbestos tailings is prohibited except for temporary roadways in an area of asbestos ore deposits 3 There shall be no visible emissions to the outside air unless the specified air cleaning methods are used from any operation which manufacturers cloth cord wicks tubing tape twine rope thread yarn roving lap other textile products cement products fireproofing and insulating materials friction products paper millboard felt floor tile paints coatings caulks adhesives sealants plastics and rubber materials and chlorine 4 The regulations covering demolition and renovation of buildings are a Asbestos materials used to insulate or fireproof any boiler pipe or structural member shall be wetted and removed from any building before the wrecking begins The asbestos debris shall be wetted at all stages of demolition and related handling operations JACKSON 049738 12 No pipe or structural member covered with asbestos insulating or fireproofing material shall be dropped or thrown from any building but shall be carefully lowered to ground level No asbestos debris shall be dropped or thrown to the ground or from one floor to another For buildings 50 feet or greater in height asbestos debris shall be lowered to the ground via tight chutes or contain- ers Written notice of intention to demolish shall be pro- vided to the EPA Regional Administrator at least 10 days prior to commencement of demolition This notice shall include items under Section 61.22 of this regulation Certain demolition operations are exempt from the regulations except for the wetting of asbestos debris and the notification requirement if a building has been declared to be structurally unsound and in danger of imminent collapse Asbestos waste shall be sealed in tight containers while wet prior to being sent to an approved waste disposal site The tight containers Item f with a warning label which reads should be labeled CAUTION Contains Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hazardous to Your Health The owner or operator of a demolition operation is exempted from these requirements with the exception of Item d above provided the amount of friable asbestos materials in the building or portion thereof to be demolished is less than 80 meters ca. 260 feet used on pipes and less than 15 square meters ca. 160 square feet used on any duct boiler tank reactor turbine furnace or structural member These regulations also set forth collection processing and disposal requirements which the waste disposal firm must adhere to in handling and disposing of this waste 40 CFR 61.25 Since Firestone in most cases if not all will be utilizing outside firms for disposal of its asbestos wastes no further BATO JACKSON 049739 13 ~ discussion of these requirements will be presented herein Firestone however must verify that firm selected to dis- pose of its asbestos waste will meet the requirements of paragraph 61.25 i.e. approved operation Following is Section 61.22 of the Emission standard Written notice of intention to demolish or renovate shall be provided to the Administrator by the owner or operatoorf the demolition or renovation operation Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demolition or as early as possible prior to commencement of emergency demolition subject to paragraph 6 of this section and as early as possible prior to commencement of renovation Such notice shall in- clude the following information i Name of owner or operator ii Address of owner or operator iii Description of the building structure facility or installation to be demolished or renovated including the size age and prior use of the structure and the approximate amount of friable asbestos materials present iv Address or location of the building facility or installation structure v Scheduled starting and completion dates of demolition or renovation vi Nature of planned demolition or renovation and method to be employed vii Procedures to ments of this this section be employed to meet the paragraph and paragraph require- j of viii The name and address or disposal site where the will be deposited location of the waste friable asbestos waste ix Name title and authority of the State or local governmental representative who has ordered a demolition which is subject to paragraph 6 of this section JACKSON 049740 III 14 DEPARTMENT OF TRANSPORTATION REGULATIONS The Department of Transportation DOT currently only the transportation of commercial asbestos regulate regulates They do not 1 Asbestos which has no commercial value such as products which contain trace amounts as a contaminant 49 CFR 173 1090 2 Waste asbestos which is currently proposed to be regulated under DOT hazardous waste regulations preamble to final commercial asbestos rule issued December 4 1978 3 Asbestos which is immersed or fixed in a natural or arti- ficial binder material such as cement plastic resin or mineral ore 49 CFR 173.1090 asphalt DOT does regulate commercial asbestos which is defined as any material or product which has commercial value because of its asbestos content 49 CFR 173.1090 When regulated DOT requires that shipments of asbestos meet the following requirements 1 Packaging must be as specified in 49 CFR 173.1090 a tight packages such as metal or fiber drums b Bags which are dust and sift proof and are unitized on a pallet Pallet loads should be encased in a shrink wrapped plastic film or fiberboard secured by strapping C. Bags placed inside wooden or fiberboard boxes 2. Each outside package must be marked with the word Asbestos and the name and address of the consignee or consignor 49 CFR 173.304 and 173.306 3. Each outside container must be marked ORM in an approp- riate rectangle 49 CFR 172.316 Labels which can be used for this purpose are available through normal Firestone stationery store channels The form number and description for ordering purposes is 8974 ORM Label 4 Asbestos shipped via the water or air mode must also meet the following shipping paper requirements 49 CFR 172.200 JACKSON 049741 15 The total amount of commercial asbestos being shipped i.e. the net weight of the product containing commercial asbestos 49 CFR 172.202 The proper shipping name and hazard class Asbestos ORM 49 CFR 172.202 i.e. If shipped on the same bill ous materials the asbestos hazardous entries or in lighte4d9 CFR 172.201 of lading with hazardentry should be before any a contrasting color high- d A signed certification 49 CFR 172.204 There are no shipping paper requirements when commercial is shipped via truck or rail modes 49 CFR 172.200 asbestos BATO JACKSON 049742 16 FEDERAL ASBESTOS STANDARD MEDICAL SURVEILLANCE COMPLIANCE FLOW CHART Is exposure at or above .1 fiber longer than 5 microns as an 8 hour TWA Nofurther -No- action is required Yes Provide medical surveillance to employees prior to placement in exposure area j Detailed work and medical history with particular attention to respiratory and cardiopulmonary disorders and smoking habits i Comprehensive physical examination with particular attention to respiratory and cardio- vascular systems Y X 1. Chest rays on x17 plate a lateral ray is strongly recommended 2. Pulmonary function tests FEV and FVC " Are test results Yes Refer to Medical Surveillance Manual and -No- ; consult with Corporate Medical Director Repeat tests annually and upon termination of work in exposure area JACKSON 049743 ASBESTOS MANUAL November 9 1979 The Firestone Tire & Rubber Company JACKSON 049744 CONTENTS Page Introduction 1 AsbestoMasy Still be Found in Tire Plants ... HN All Other Plants HN OSHA Regulations M Permissible Average Exposure Limit and Ceiling Concentration Air Monitoring and Sampling Frequency Employee Notification and Recordkeeping of Exposure Results 4 Methods of Compliance ...cccenceaccccceeee 4 Particular Tools 4 Wet Methods .. 4 Spraying Demolition or Removal of Asbestos Insulation Jun Respiratory Protective Equipment Jun Air Purifying Respirators . Jun Powered Air Purifying Respirator eee 5 Type C Supplied Respirators Continuous Flow or Pressure- demand aeees 5 Special Clothing - Clothes Lockers - Laundering 5 Caution Signs and Caution Labels 6 JACKSON 049745 CONTENTS Page Housekeeping - Waste Disposal eooeee 7 Medical Examinations 7 Asbestos eee m merce ease eerveseseccene 7 A. Reason for medical surveillance 7 B. Forms of asbestos included 7 C. Level of exposure 8 D. Types of medical tests and procedures ... ... eppas @egenunpoeseeeeea 8 E. Frequency of medical tests and procedures eve mere scnncccscncee 8 F. Interpretation of medical tests and procedures oeanee 9 EPA Regulation .. aeses 10 Introduction ccccccnccuccecvecsvececeecsesens 10 Reason for Control of Asbestos Emissi ....o ....ns eeccnccceece esscceseeese Emission Standard for Asbestos 11 11 Section 61.22 of the Emission Standard ceaeee 13 Department of Transportation Regulation 14 Medical Surveillance Flow Chcca c ccesr scccct eess 16 BATO JACKSON 049746 1 INTRODUCTION Asbestos and materials containing asbestos are now regulated by several federal regulatory agencies The purpose of this manual is to compile in one document all applicable federal regulations and assist and guide the plants in complying with these regulations The use of asbestos or materials containing asbestos in our plants is now very limited According to the information that we have available asbestos insulation may still be used or found in the following areas Tire Plants 1. Curing area a Old pipe insulation b Curing press heat shields C. Board type asbestos insulation between press platens or domes and in the curing press frame This asbestos material is cut or machined by the McNeil Company or NRM and is only installed by Firestone people d Pipe insulation installed by McNeil or NRM on new presses that are shipped to Firestone plants e NRM well insulation 2 Powerhouse - Plants ten years old or older a Pipe insulation b Deaerator heater 3 Maintenance 2 Gaskets made froma material containing asbestos b Welding blankets or guards 4 Tire building - Hot knife boxes 2 99R3 TAM - Asbestos tubing 1.5 o.d. - 1.25 i.d. x " long two per machine This tubing insulates the heated magnets from the rest of the assembly Asbestos tape 0.5 wide x 15 long four per machine This tape is wrapped around the heating elements and tubing described above JACKSON 049747 2 b All Radial First Stage TAM's Radial sidewall knife - Heat sink hot box Manganese wire with asbestosglass insulation AWG 14 16 required per machine All Other Plants 1 Gaskets made from a material containing asbestos that are cut to size and drilled to open holes 2 Experimental formulation of small batches of rubber products containing asbestos This is done in an Akron laboratory of the Synthetic Rubber Division Maintenance operations in plants often require the removal or demolition of old asbestos insulation The removal of asbestos insulation is of considerable importance from the standpoint of compliance with federal regulations since the potential of employee exposure to airborne asbestos fibers is usually higher than in other operations The manual is divided into three sections The first section describes the OSHA standard on asbestos The second section de- scribes the EPA regulations on asbestos which are applicable to Firestone operations The third section summarizes the current Department of Transportation regulations on asbestos JACKSON 049748 3 I. OSHA REGULATION SECTION 1910.1001 The OSHA standard on asbestos is 1001 of the OSHA standards book described in Section 1910 Permissible Average Exposure Limit and Ceiling Concentration The present hour weighted average permissible exposure limit is two 2 fibers longer than 5 microns per cubic centimeter of air The permissible ceiling exposure limit is ten 10 fibers longer than 5 microns per cubic centimeter of air as determined over a period of 15 minutes Air Monitoring and Sampling Frequency All operations where asbestos and materials containing asbestos are being used or old asbestos insulation is being removed replaced or repaired must be monitored by air sampling to determine employee exposure to airborne asbestos fibers Samples should be collected from within the breathing zone of the employees on membrane filters mounted in an open face filter holder cassette Samples should be taken for the determination of the hour weighted average concentration and of the ceiling concentration of asbestos fibers Cassettes for collecting air samples for asbestos are provided to the plants by the Industrial Hygiene Department After sampling these cassettes are returned to Industrial Hygiene for analysis and calculation of the airborne concentration of as- bestos fibers Detailed instructions on how to collect air samples for asbestos have been sent to the plant safety engineers by the Industrial Hygiene Department After the initial determination samples should be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees to asbestos fibers In no case should the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos exceeds the permissible exposure limit or the permissible ceiling concentration Affected employees or their representatives should be given an opportunity to observe the monitoring operation JACKSON 049749 4 Employee Notification and Recordkeeping of Exposure Results Any employee found to have been exposed at any time to air- borne concentrations of asbestos fibers in excess of the per- missible exposure limit or the permissible ceiling concentration must be notified in writing of the exposure as soon as practicable but not later than 5 days of the finding The employee must also be timely notified of the corrective action taken to reduce the airborne concentration of asbestos fibers Every employer must maintain records of any personal or environmental monitoring required by Section 1910.1001 Records must be maintained for a period of at least 20 years and must be made available upon request to the Assistant Secretary of Labor for OSHA the Director of NIOSH and to their authorized representa- tives Every employee and former employee shall have reasonable access to any records required to be maintained by this standard which indicate the employee's own exposure to asbestos fibers Methods of Compliance 1 Particular Tools All operated and operated tools which may produce or release asbestos fibers in excess of the exposure limits listed above such as saws scorers abrasive wheels and drills must be provided with local exhaust ventilation sys- tems 2 Wet Methods Insofar as practicable asbestos must be handled mixed applied removed cut scored or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the permissible exposure limits unless the usefulness of the product would be diminished by wetting it Spraying Demolition or Removal of Asbestos Insulation Employees engaged in spraying of asbestos the removal or demolition of pipes structures or equipment covered or insulated with asbestos and in the removal or demolition of asbestos insulation or coverings must be provided with respiratory protective equipment and special clothing as described below JACKSON 049750 5 Respiratory Protective Equipment 1. Air Purifying respirators A reusable or single use disposable air purifying res- pirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 2 but not greater than 20 fibers per cubic centi- meter of air 2 Powered Air Purifying Respirator A powered air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 20 but not greater than 200 fibers per cubic centimeter of air 3. Type C Supplied Respirators Continuous Flow or Pressure Type A type C continuous flow or pressure supplied respirator must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 200 fibers per cubic centimeter of air The OSHA standard specifies that employees engaged in the removal or demolition of asbestos insulation shall be provided with supplied respirators For the removal of large sections of insulation which would normally last several days a suppliedair respirator must be provided As a general guideline when the amount of asbestos to be removed is small and the operation will only last a few hours or less a supplied respirator should still be provided if feasible If this is not feasible at least an air purifying respirator should be provided Special Clothing - Clothes Lockers - Laundering The employer must provide and require the use of special clothing such as coveralls or similar whole body clothing head coverings gloves and foot coverings for any employee exposed to airborne concentrations of asbestos fibers which exceed the permissible exposure limits or who is engaged in the removal or demolition of asbestos insulation At any fixed place of employment exposed to airborne concentrations of asbestos fibers in excess of the permissible exposure limits the employer must provide change rooms for employees working regularly at the place JACKSON 049751 6 The employer must provide two separate lockers or containers for each employee so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes Laundering of asbestos contaminated clothing must be done so as to prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Any employer who gives asbestos contaminated clothing to another person for laundering must inform such person of the requirement to effectively prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Contaminated clothing must be transported in sealed impermeable bags or other closed impermeable containers and labeled in accordance with paragraph ii of the standard It is now common practice among employers to provide their employees who are engaged in asbestos insulation removal with disposable coveralls head coverings and shoe coverings The use of disposable protective clothing eliminates the necessity of laundering work clothes contaminated with asbestos and all other problems associated with it Caution Signs and Caution Labels Caution signs must be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the permissible exposure limits Signs must be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps before entering the area marked by the signs Signs must be posted at all approaches to areas containing excessive concentrations of asbestos fibers The ii The signs must display a legend which is described in paragraph 1 of this standard Since during the short time needed for a demolition or removal of asbestos insulation it is not usually possible to determine if the concentration of airborne fibers is above or below the permissible exposure limits caution signs should be all asbestos removal operations These signs should after the work is completed posted at be removed Caution labels must 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 JACKSON 049752 7 coating binder ably foreseeable fibers in excess released or other material so that during any reason- use no airborne concentrations of asbestos of the permissible exposure limits will be The statement that is required on the label is described in paragraph ii of this standard Housekeeping- Waste Disposal All external surfaces in any place of employment tained free of accumulations of asbestos fibers must be mainCollection of settled dust or debris should be done by vacuum cleaning Do not clean up asbestos by blowing or dry sweeping Asbestos waste scrap debris bags containers equipment and contaminated clothing that is to be disposed of must be collected and disposed of in sealed impermeable bags or other closed impermeable containers The federal regulations pertaining to asbestos waste disposal practices and procedures are described in the next section of the manual under EPA Regulations Medical Examinations The standard requires that the employer provide or make available at his cost medical examinations to each of his employees exposed to asbestos fibers The medical examinations program required by OSHA is presented below this is a copy of the medical surveillance program for asbestos which has been adopted by the Corporate Medical Department ASBESTOS A. Reason for medical surveillance 1 Required by the OSHA asbestos standard 29 CFR 1910 1001 j B. Forms of asbestos included 1 Chrysotile 2 Amosite JACKSON 049753 8 Crocidolite 3 4. Tremolite 6. Anthophyllite Actinolite Level of exposure 1 Airborne exposure to asbestos at or above 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour weighted average Note This definition of exposure has been established by OSHA Program Directive 300-16 effective October 11 1978 and will not be found in the original OSHA asbestos standard Types of medical tests and procedures 1. Detailed work and medical history with particular attention to a Respiratory and cardiopulmonary disorders b. Smoking habits Comprehensive physical examination with particular attention to respiratory and cardiovascular systems Chest rays - PA on 14 x 17 plate a lateral ray is also strongly recommended 4 Pulmonary function tests - FEV and FVC Frequency of medical tests and procedures 1. All tests and procedures a Prior to or within 30 days after placement in an exposure area where airborne asbestos levels exceed 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour time- weighted average b At least annually while working in the exposure area JACKSON 049754 9 C. Within 30 days before or after termination of employment in an exposure area unless all the tests and procedures have been performed within the past year F. Interpretation of medical tests and procedures 1 Chest rays should be interpreted by a radiologist 2 In order to unify and standardize the pulmonary function tests the actual administration of the tests should be done by as few people as possible The original tracing and interpretation should be given to the plant physician for medical management A copy of each should be sent to the Corporate Medical Department for short and long term interpretation study and storage 3 Whenever an employee shows signs or symptoms of chronic malignant or malignant lung disease or cardiopulmonary disorders which may be due to occupational exposure to asbestos the Corporate Medical Department should be consulted Any abnormality in the chest rays as compared to established norms or earlier findings a definite reduction in the FEV or FVC or degeneration of the employee's general respiratory condition should be reasons for not employing or for removing the employ- ee from the asbestos exposure area The responsibility for medical removal and reinstatement is that of the plant physician in consultation with as many other physicians as he deems necessary Medical records of employees examined under this protocol including examination and test results written medical opinions and records of employee complaints should be retained for at least five years after the last employment for each employee or for twenty years from the date of the record whichever is longer JACKSON 049755 II 10 EPA REGULATION Introduction The EPA has established emission standards for certain hazardous air pollutants under its National Emission Standards for Hazardous Air Pollutants Regulations NESHAPS Asbestos currently is included as one of the four substances currently under these regulations 40 CFR Part 61 Subpart regulated The NESHAPS regulations are applicable to the following oper- ations a) asbestos mills b roadways c manufacturing a) demolition and renovation e) spraying f fabricating g insulating h) waste disposal Engine ring's Based upon Environmental Engineering's knowledge Firestone is mainly involved in Items and h above EPA intentions are to administer these regulations on a state by state basis by delegating authority to the individual state air control agencies i.e. once they have met all the necessary requirements To date 31 states have been given this authority as follows Alabama Arizona California Colorado Connecticut Delaware Georgia Indiana Kentucky Maine Massachusetts Michigan Minnesota Montana Nevada New Hampshire New Jersey New York North Carolina North Dakota Oregon Pennsylvania Rhode Island South Carolina Texas Vermont Virginia Washington Wisconsin Puerto Rico and U. S. Virgin Islands These regulations i.e. NESHAPS for controlling asbestos emissions were first promulgated on April 6 1973 38 FR 8820 in fulfilling requirements under Section 112 B of the Clean Air Act as amended December 1970. Since then they have undergone various revisions the most recent of which was promulgated February 7 1979 giving the State of Texas authority to administer the NESHAPS program and issue permits etc. in the state From time to time additional pollutants which are found to be hazardous will be included under EPA NESHAPS regulations i.e. vinyl chloride was added to the original list on October 21 1976 41 FR 46560 May cause or contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness - Clean Air Act Section 112 December 1970 JACKSON 049756 11 Reason for Control of Asbestos Emissions A large number of studies have shown an association between occupational exposure to asbestos and a higher than expected incidence of bronchial cancer Asbestos also has been identi- fied as a causal factor in the development of cancers of the membranes of the chest and abdomen Emission Standard for Asbestos Basically the regulations prohibit any discharge of asbestos to the outside air which creates a visible emission which may be detected without the aid of instruments By definition outside air means the air outside buildings or structures A source can use a specified method of air cleaning fabric filter systems etc. to eliminate such emissions provided that the emission control equipment is approved by the administrator of the EPA or his authorized representative Specifically the asbestos standards are 1 There shall be no visible emissions to the outside air from any asbestos mill except when a specified method of air cleaning also part of these standards is used before the emissions escape to the outside air In general these cleaning systems filter asbestos emissions to the point that visible emissions would not be produced anyway 2 The surfacing of roadways with asbestos tailings is prohibited except for temporary roadways in an area of asbestos ore deposits 3 There shall be no visible emissions to the outside air unless the specified air cleaning methods are used from any operation which manufacturers cloth cord wicks tubing tape twine rope thread yarn roving lap other textile products cement products fireproofing and insulating materials friction products paper millboard felt floor tile paints coatings caulks adhesives sealants plastics and rubber materials and chlorine 4 The regulations covering demolition and renovation of buildings are a Asbestos materials used to insulate or fireproof any boiler pipe or structural member shall be wetted and removed from any building before the wrecking begins The asbestos debris shall be wetted at all stages of demolition and related handling operations JACKSON 049757 12 No pipe or structural member covered with asbestos insulating or fireproofing material shall be dropped or thrown from any building but shall be carefully lowered to ground level No asbestos debris shall be dropped or thrown to the ground or from one floor to another For buildings 50 feet or greater in height asbestos debris shall be lowered to the ground via tight chutes or contain- ers Written notice of intention to demolish shall be pro- vided to the EPA Regional Administrator at least 10 days prior to commencement of demolition This notice shall include items under Section 61.22 of this regulation Certain demolition operations are exempt from the regulations except for the wetting of asbestos debris and the notification requirement if a building has been declared to be structurally unsound and in danger of imminent collapse Asbestos waste shall be sealed in tight containers while wet prior to being sent to an approved waste disposal site The tight containers Item f with a warning label which reads should be labeled CAUTION Contains Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hazardous to Your Health The owner or operator of a demolition operation is exempted from these requirements with the exception of Item d above provided the amount of friable asbestos materials in the building or portion thereof to be demolished is less than 80 meters ca. 260 feet used on pipes and less than 15 square meters ca. 160 square feet used on any duct boiler tank reactor turbine furnace or structural member These regulations also set forth collection processing and disposal requirements which the waste disposal firm must adhere to in handling and disposing of this waste 40 CFR 61.25 Since Firestone in most cases if not all will be utilizing outside firms for disposal of its asbestos wastes no further JACKSON 049758 13 discussion of these requirements will be presented herein Firestone however must verify that any firm selected to dispose of its asbestos waste will meet the requirements of paragraph 61.25 i.e. approved operation Following is Section 61.22 of the Emission standard Written notice of intention to demolish or renovate shall be provided to the Administrator by the owner or operator of the demolition or renovation operation Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demolition or as early as possible prior to commencement of emergency demolition subject to paragraph d of this section and as early as possible prior to commencement of renovation Such notice shall in- clude the following information i Name of owner or operator ii Address of owner or operator iii Description of the building structure facility or installation to be demolished or renovated including the size age and prior use of the structure and the approximate amount of friable asbestos materials present iv Address or location of the building facility or installation structure v Scheduled starting and completion dates of demolition or renovation vi Nature of planned demolition or renovation and method to be employed vii Procedures to ments of this this section be employed to meet the paragraph and paragraph require- j of viii The name and address or disposal site where the will be deposited location of the waste friable asbestos waste ix Name title and authority of the State or local governmental representative who has ordered a demolition which is subject to paragraph 6 of this section JACKSON 049759 III 14 DEPARTMENT OF TRANSPORTATION REGULATIONS The Department of Transportation DOT currently only the transportation of commercial asbestos regulate regulates They do not 1 Asbestos which has no commercial value such as products which contain trace amounts as a contaminant 49 CFR 173 1090 2. Waste asbestos which is currently proposed to be regulated under DOT hazardous waste regulations preamble to final commercial asbestos rule issued December 4 1978 3 Asbestos which is immersed or fixed in a natural or arti- ficial binder material such as cement plastic resin or mineral ore 49 CFR 173.1090 asphalt DOT does regulate commercial asbestos which is defined as any material or product which has commercial value because of its asbestos content 49 CFR 173.1090 When regulated DOT requires that shipments of asbestos meet the following requirements 1 Packaging must be as specified in 49 CFR 173.1090 a tight packages such as metal or fiber drums 10 Bags which are dust and sift proof and are unitized on a pallet Pallet loads should be encased in a shrink wrapped plastic film or fiberboard secured by strapping C. Bags placed inside wooden or fiberboard boxes 2 Each outside package must be marked with the word Asbestos and the name and address of the consignee or consignor 49 CFR 173.304 and 173.306 3. Each outside container must be marked ORM in an appropriate rectangle 49 CFR 172.316 Labels which can be used for this purpose are available through normal Firestone stationery store channels The form number and description for ordering purposes is 8974 ORM Label 4 Asbestos shipped via the water or air mode must also meet the following shipping paper requirements 49 CFR 172.200 JACKSON 049760 15 a The total amount of commercial asbestos being shipped i.e. the net weight of the product containing commercial asbestos 49 CFR 172.202 The proper shipping name and hazard class Asbestos ORM 49 CFR 172.202 i.e. If shipped on the same bill ous materials the asbestos hazardous entries or in lighte4d9 CFR 172.201 of lading with hazardentry should be before any a contrasting color high- d A signed certification 49 CFR 172.204 There are no shipping paper requirements when commercial is shipped via truck or rail modes 49 CFR 172.200 asbestos JACKSON 049761 16 FEDERAL ASBESTOS STANDARD MEDICAL SURVEILLANCE COMPLIANCE FLOW CHART Is exposure at or above .1 fiber longer than 5 microns as an 8 hour TWA -No- No further action is required Yes Provide medical surveillance to employees prior to placement in exposure area 5 Detailed work and medical history with particular attention to respiratory and cardiopulmonary disorders and smoking habits ~ , Comprehensive physical examination with particular attention to respiratory and cardio- vascular systems Y j 1. Chest rays on x17 plate a lateral ray is strongly recommended 2. Pulmonary function tests FEV and FVC y Are test results -No- Yes | Repeat tests annually and upon termination of work in exposure area Surveillance to Medical Surveillance Manual and | consult with Corporate Medical Director JACKSON 049762 ASBESTOS MANUAL November 9 1979 The Firestone Tire & Rubber Company JACKSON 049763 CONTENTS Introduction enc cece reser ec esnesceseses Page 1 AsbestoMasy Still be Found in Tire Plants eae eneen wee H All Other Plants .cscccccscccsececces eas N OSHA Regulations se W Permissible Average Exposure Limit and Ceiling Concentration cccccccccccces M Air Monitoring and Sampling Frequency M Employee Notification and Recordkeeping of Exposure Results 4 Methods of Complianc.e.. ccc cece cee eeences 4 Particular Toco cs wwl w wees s cccscccces o- 4 Wet Methods occa cece nec cesane 4 Spraying Demolition or Removal of Asbestos Insulation .ccscccsccsccaace 4 Respiratory Protective Equipment 5 Air Purifying Respirators Powered Air Purifying Respirator 5 Type C Supplied Respirators Continuous Flow or Pressure- demand Type cccsccccencusccccccecnas 5 Special Clothing - Clothes Lockers - Laundering coma eeesenscaes eveeoe 5 Caution Signs and Caution Labels BATO JACKSON 049764 CONTENTS Cont'd) Housekeeping - Waste Disposal Medical Examinations pee cceencocrs veces Asbestos c cee wee een eanee sev aesecccees A. Reason for medical surveillance . B. Forms of asbestos included C. Level of exposure D. Types of medical tests and proc ...e necd es nu ccccr sccee rescs ces E. Frequency of medical tests and proce ... .d .. cu ecr cee ces cesses sesnneces F. Interpretation of medical tests and procedures ee cenceee ween. EPA Regulation ee recccen weneves Introduction cccccccccccccccncnccsncees senecs Reason for Control of Asbestos Emissions ..... ..... cccscccccccceccscsccece Emission Standard for Asbestos .ccccccccacceee Section 61.22 of the Emission Standard ea ceesccees Department of Transportation Regulation Medical Surveillance Flow Chart 10 10 11 11 13 14 16 BATO JACKSON 049765 1 INTRODUCTION Asbestos and materials containing asbestos are now regulated by several federal regulatory agencies The purpose of this manual is to compile in one document all applicable federal regulations and assist and guide the plants in complying with these regulations The use of asbestos or materials containing asbestos in our plants is now very limited According to the information that we have available asbestos insulation may still be used or found in the following areas Tire Plants 1 Curing area a Old pipe insulation b Curing press heat shields C. Board type asbestos insulation between press platens or domes and in the curing press frame This asbestos material is cut or machined by the McNeil Company or NRM and is only installed by Firestone people d Pipe insulation installed by McNeil or NRM on new presses that are shipped to Firestone plants e NRM well insulation 2 Powerhouse - Plants ten years old or older a Pipe insulation b Deaerator heater 3. Maintenance a Gaskets made from a material containing asbestos b Welding blankets or guards 4 Tire building - Hot knife boxes 2 99R3 TAM - Asbestos tubing o.d. - 1.25 i.d. x " long two per machine This tubing insulates the heated magnets from the rest of the assembly Asbestos tape 0.5 wide x 15 long four per machine This tape is wrapped around the heating elements and tubing described above JACKSON 049766 2 b All Radial First Stage TAM's Radial sidewall knife - Heat sink hot box Manganese wire with asbestosglass insulation AWG 14 16 required per machine All Other Plants 1 Gaskets made from a material containing asbestos that are cut to size and drilled to open holes 2 Experimental formulation of small batches of rubber products containing asbestos This is done in an Akron laboratory of the Synthetic Rubber Division Maintenance operations in plants often require the removal or demolition of old asbestos insulation The removal of asbestos insulation is of considerable importance from the standpoint of compliance with federal regulations since the potential of employee exposure to airborne asbestos fibers is usually higher than in other operations The manual is divided into three sections The first section describes the OSHA standard on asbestos The second section de- scribes the EPA regulations on asbestos which are applicable to Firestone operations The third section summarizes the current Department of Transportation regulations on asbestos JACKSON 049767 3 I. OSHA REGULATION SECTION 1910.1001 The OSHA standard on asbestos is described in Section 1910 1001 of the OSHA standards book Permissible Average Exposure Limit and Ceiling Concentration The present hour weighted average permissible exposure limit is two 2 fibers longer than 5 microns per cubic centimeter of air The permissible ceiling exposure limit is ten 10 fibers longer than 5 microns per cubic centimeter of air as determined over a period of 15 minutes Air Monitoring and Sampling Frequency All operations where asbestos and materials containing asbestos are being used or old asbestos insulation is being removed replaced or repaired must be monitored by air sampling to determine employee exposure to airborne asbestos fibers Samples should be collected from within the breathing zone of the employees on membrane filters mounted in an open face filter holder cassette Samples should be taken for the determination of the hour weighted average concentration and of the ceiling concentration of asbestos fibers Cassettes for collecting air samples for asbestos are provided to the plants by the Industrial Hygiene Department After sampling these cassettes are returned to Industrial Hygiene for analysis and calculation of the airborne concentration of as- bestos fibers Detailed instructions on how to collect air samples for asbestos have been sent to the plant safety engineers by the Industrial Hygiene Department After the initial determination samples should be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees to asbestos fibers In no case should the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos exceeds the permissible exposure limit or the permissible ceiling concentration Affected employees or their representatives should be given an opportunity to observe the monitoring operation JACKSON 049768 4 Employee Notification and Recordkeepinogf Exposure Results Any employee found to have been exposed at any time to air- borne concentrations of asbestos fibers in excess of the per- missible exposure limit or the permissible ceiling concentration must be notified in writing of the exposure as soon as practicable but not later than 5 days of the finding The employee must also be timely notified of the corrective action taken to reduce the airborne concentration of asbestos fibers Every employer must maintain records of any personal or environmental monitoring required by Section 1910.1001 Records must be maintained for a period of at least 20 years and must be made available upon request to the Assistant Secretary of Labor for OSHA the Director of NIOSH and to their authorized representa- tives Every employee and former employee shall have reasonable access to any records required to be maintained by this standard which indicate the employee's own exposure to asbestos fibers Methods of Compliance 1 Particular Tools All operated and operated tools which may produce or release asbestos fibers in excess of the exposure limits listed above such as saws scorers abrasive wheels and drills must be provided with local exhaust ventilation sys- tems 2 Wet Methods Insofar as practicable asbestos must be handled mixed applied removed cut scored or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the permissible exposure limits unless the usefulness of the product would be diminished by wetting it Spraying Demolition or Removal of Asbestos Insulation Employees engaged in the spraying of asbestos the removal or demolition of pipes structures or equipment covered or insulated with asbestos and in the removal or demolition of asbestos insulation or coverings must be provided with respiratory protective equipment and special clothing as described below JACKSON 049769 5 Respiratory Protective Equipment 1 Air Purifying respirators A reusable or single use disposable air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted aver- age airborne concentration of asbestos fibers is greater than 2 but not greater than 20 fibers per cubic centi- meter of air 2 Powered Air Purifying Respirator A powered air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 20 but not greater than 200 fibers per cubic centimeter of air 3. Type C Supplied Respirators Continuous Flow or Pressure Type A type C continuous flow or pressure supplied respirator must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 200 fibers per cubic centimeter of air The OSHA standard specifies that employees engaged in the removal or demolition of asbestos insulation shall be provided with supplied respirators For the removal of large sections of insulation which would normally last several days a suppliedair respirator must be provided As a general guideline when the amount of asbestos to be removed is small and the operation will only last a few hours or less a supplied respirator should still be provided if feasible If this is not feasible at least an air purifying respirator should be provided Special Clothing - Clothes Lockers - Laundering The employer must provide and require the use of special clothing such as coveralls or similar whole body clothing head coverings gloves and foot coverings for any employee exposed to airborne concentrations of asbestos fibers which exceed the permissible exposure limits or who is engaged in the removal or demolition of asbestos insulation At any fixed place of employment exposed to airborne concentrations of asbestos fibers in excess of the permissible exposure limits the employer must provide change rooms for employees working regularly at the place JACKSON 049770 6 The employer must provide two separate lockers or containers for each employee so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes Laundering of asbestos contaminated clothing must be done so as to prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Any employer who gives asbestos contaminated clothing to another person for laundering must inform such person of the requirement to effectively prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Contaminated clothing must be transported in sealed impermeable bags or other closed impermeable containers and labeled in accordance with paragraph ii of the standard It is now common practice among employers to provide their employees who are engaged in asbestos insulation removal with disposable coveralls head coverings and shoe coverings The use of disposable protective clothing eliminates the necessity of laundering work clothes contaminated with asbestos and all other problems associated with it Caution Signs and Caution Labels Caution signs must be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the permissible exposure limits Signs must be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps before entering the area marked by the signs Signs must be posted at all approaches to areas containing excessive concentrations of asbestos fibers ii The signs must display a legend which is described in paragraph g of this standard Since during the short time needed for a demolition or removal of asbestos insulation it is not usually possible to determine if the concentration of airborne fibers is above or below the permissible exposure limits caution signs should be all asbestos removal operations These signs should after the work is completed posted at be removed Caution labels must 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 JACKSON 049771 coating binder ably foreseeable fibers in excess released or other material so that during any reason- use no airborne concentrations of asbestos of the permissible exposure limits will be The statement that is required on the label paragraph ii of this standard is described in Housekeeping- Waste Disposal All external surfaces in any place of employment tained free of accumulations of asbestos fibers must be mainCollection of settled dust or debris should be done by vacuum cleaning Do not clean up asbestos by blowing or dry sweeping Asbestos waste scrap debris bags containers equipment and contaminated clothing that is to be disposed of must be collected and disposed of in sealed impermeable bags or other closed impermeable containers The federal regulations pertaining to asbestos waste disposal practices and procedures are described in the next section of the manual under EPA Regulations Medical Examinations The standard requires that the employer provide or make available at his cost medical examinations to each of his employees exposed to asbestos fibers The medical examinations program required by OSHA is presented below this is a copy of the medical surveillance program for asbestos which has been adopted by the Corporate Medical Department ASBESTOS A. Reason for medical surveillance 1 Required by the OSHA asbestos standard 29 CFR 1910 1001 ) B. Forms of asbestos included 1 Chrysotile 2 Amosite JACKSON 049772 8 Crocidolite Tremolite Anthophyllite Actinolite Level of exposure 1 Airborne exposure to asbestos at or above 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour weighted average Note This definition of exposure has been established by OSHA Program Directive 300-16 effective October 11 1978 and will not be found in the original OSHA asbestos standard Types of medical tests and procedures 1. Detailed work and medical history with particular attention to a Respiratory and cardiopulmonary disorders b Smoking habits Comprehensive physical examination with particular attention to respiratory and cardiovascular systems Chest rays - PA on 14 x 17 plate ray is also strongly recommended a lateral 4 Pulmonary function tests - FEV and FVC Frequency of medical tests and procedures 1. All tests and procedures a Prior to or within 30 days after placement in an exposure area where airborne asbestos levels exceed 0.1 fibers longer than5 micrometers per cubic centimeter of air as an hour time- weighted average b At least annually while working in the exposure area JACKSON 049773 9 C. Within 30 days before or after termination of employment in an exposure area unless all the tests and procedures have been performed within the past year F. Interpretation of medical tests and procedures 1 Chest rays should be interpreted by a radiologist 2 In order to unify and standardize the pulmonary function tests the actual administration of the tests should be done by as few people as possible The original tracing and interpretation should be given to the plant physician for medical management A copy of each should be sent to the Corporate Medical Department for short and long term interpretation study and storage Whenever an employee shows signs or symptoms of chronic malignant or malignant lung disease or cardiopulmonary disorders which may be due to occupational exposure to asbestos the Corporate Medical Department should be consulted Any abnormality in the chest rays as compared to established norms or earlier findings a definite reduction in the FEV or FVC or degeneration of the employee's general respiratory condition should be reasons for not employing or for removing the employ- ee from the asbestos exposure area The responsibility for medical removal and reinstatement is that of the plant physician in consultation with as many other physicians as he deems necessary Medical records of employees examined under this protocol including examination and test results written medical opinions and records of employee complaints should be retained for at least five years after the last employment for each employee or for twenty years from the date of the record whichever is longer JACKSON 049774 II 10 EPA REGULATION- Introduction The EPA has established emission standards for certain hazardous air pollutants under its National Emission Standards for Hazardous Air Pollutants Regulations NESHAPS Asbestos currently is included as one of the four substances currently under these regulations 40 CFR Part 61 Subpart regulated The NESHAPS regulations are applicable to the following oper- ations a) asbestos mills b roadways c manufacturing d) demolition and renovation e) spraying f fabricating g insulating h waste disposal Engine ring's Based upon Environmental Engineering's knowledge Firestone is mainly involved in Items and h above EPA intentions are to administer these regulations on a state by state basis by delegating authority to the individual state air control agencies i.e. once they have met all the necessary requirements To date 31 states have been given this authority as follows Alabama Arizona California Colorado Connecticut Delaware Georgia Indiana Kentucky Maine Massachusetts Michigan Minnesota Montana Nevada New Hampshire New Jersey New York North Carolina North Dakota Oregon Pennsylvania Rhode Island South Carolina Texas Vermont Virginia Washington Wisconsin Puerto Rico and U. S. Virgin Islands These regulations i.e. NESHAPS for controlling asbestos emissions were first promulgated on April 6 1973 38 FR 8820 in fulfilling requirements under Section 112 B of the Clean Air Act as amended December 1970. Since then they have undergone various revisions the most recent of which was promulgated February 7 1979 giving the State of Texas authority to administer the NESHAPS program and issue permits etc. in the state From time to time additional pollutants which are found to be hazardousl will be included under EPA NESHAPS regulations i.e. vinyl chloride was added to the original list on October 21 1976 41 FR 46560 1May cause or contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness - Clean Air Act Section 112 December 1970 BATO JACKSON 049775 11 Reason for Control of Asbestos Emissions A large number of studies have shown an association between occupational exposure to asbestos and a higher than expected incidence of bronchial cancer Asbestos also has been identi- fied as a causal factor in the development of cancers of the membranes of the chest and abdomen Emission Standard for Asbestos Basically the regulations prohibit any discharge of asbestos to the outside air which creates a visible emission which may be detected without the aid of instruments By definition outside air means the air outside buildings or structures A source can use a specified method of air cleaning fabric filter systems etc. to eliminate such emissions provided that the emission control equipment is approved by the administrator of the EPA or his authorized representative Specifically the asbestos standards are 1 There shall be no visible emissions to the outside air from any asbestos mill except when a specified method of air cleaning also part of these standards is used before the emissions escape to the outside air In general these cleaning systems filter asbestos emissions to the point that visible emissions would not be produced anyway 2 The surfacing of roadways with asbestos tailings is prohibited except for temporary roadways in an area of asbestos ore deposits 3. There shall be no visible emissions to the outside air unless the specified air cleaning methods are used from any operation which manufacturers cloth cord wicks tubing tape twine rope thread yarn roving lap other textile products cement products fireproofing and insulating materials friction products paper millboard felt floor tile paints coatings caulks adhesives sealants plastics and rubber materials and chlorine 4 The regulations covering demolition and renovation of buildings are a Asbestos materials used to insulate or fireproof any boiler pipe or structural member shall be wetted and removed from any building before the wrecking begins The asbestos debris shall be wetted at all stages of demolition and related handling operations JACKSON 049776 12 No pipe or structural member covered with asbestos insulating or fireproofing material shall be dropped or thrown from any building but shall be carefully lowered to ground level C. No asbestos debris shall be dropped or thrown to the ground or from one floor to another For buildings 50 feet or greater in height asbestos debris shall be lowered to the ground via tight chutes or contain- ers Written notice of intention to demolish shall be pro- vided to the EPA Regional Administrator at least 10 days prior to commencement of demolition This notice shall include items under Section 61.22 of this regulation Certain demolition operations are exempt from the regulations except for the wetting of asbestos debris and the notification requirement if a building has been declared to be structurally unsound and in danger of imminent collapse Asbestos waste shall be sealed in tight containers while wet prior to being sent to an approved waste disposal site 6 The tight containers Item f should be labeled with a warning label which reads CAUTION Contains Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hazardous to Your Health The owner or operator of a demolition operation is ex- empted from these requirements with the exception of Item d above provided the amount of friable asbestos materials in the building or portion thereof to be demolished is less than 80 meters ca. 260 feet used on pipes and less than 15 square meters ca. 160 square feet used on any duct boiler tank reactor turbine furnace or structural member These regulations also set forth collection processing and disposal requirements which the waste disposal firm must adhere to in handling and disposing of this waste 40 CFR 61.25 Since Firestone in most cases if not all will be utilizing outside firms for disposal of its asbestos wastes no further JACKSON 049777 13 discussion of these requirements will be presented herein Firestone however must verify that any firm selected to dispose of its asbestos waste will meet the requirements of paragraph 61.25 i.e. approved operation Following is Section 61.22 of the Emission standard Written notice of intention to demolish or renovate shall be provided to the Administrator by the owner or operatoorf the demolition or renovation operation Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demolition or as early as possible prior to commencement of emergency demolition subject to paragraph d of this section and as early as possible prior to commencement of renovation Such notice shall in- clude the following information i Name of owner or operator ii Address of owner or operator iii Description of the building structure facility or installation to be demolished or renovated including the size age and prior use of the structure and the approximate amount of friable asbestos materials present iv Address or location of the building facility or installation structure v Scheduled starting and completion dates of demolition or renovation vi Nature of planned demolition or renovation and method to be employed vii Procedures to ments of this this section be employed to meet the paragraph and paragraph require- j of viii The name and address or disposal site where the will be deposited location of the waste friable asbestos waste ix Name title and authority of the State or local governmental representative who has ordered a demolition which is subject to paragraph d of this section JACKSON 049778 III 14 DEPARTMENT OF TRANSPORTATION REGULATIONS The Department of Transportation DOT currently only the transportation of commercial asbestos regulate regulates They do not 1 Asbestos which has no commercial value such as products which contain trace amounts as a contaminant 49 CFR 173 1090 2 Waste asbestos which is currently proposed to be regulated under DOT hazardous waste regulations preamble to final commercial asbestos rule issued December 4 1978 3 Asbestos which is immersed or fixed in a natural or arti- ficial binder material such as cement plastic resin or mineral ore 49 CFR 173.1090 asphalt DOT does regulate commercial asbestos which is defined as any material or product which has commercial value because of its asbestos content 49 CFR 173.1090 When regulated DOT requires that shipments of asbestos meet the following requirements 1 Packaging must be as specified in 49 CFR 173.1090 2 tight packages such as metal or fiber drums b Bags which are dust and sift proof and are unitized on a pallet Pallet loads should be encased in a shrink wrapped plastic film or fiberboard secured by strapping . C. Bags placed inside wooden or fiberboard boxes 2 Each outside package must be marked with the word Asbestos and the name and address of the consignee or consignor 49 CFR 173.304 and 173.306 3 Each outside container must be marked ORM in an approp- riate rectangle 49 CFR 172.316 Labels which can be used for this purpose are available through normal Firestone stationery store channels The form number and description for ordering purposes is 8974 ORM Label 4 Asbestos shipped via the water or air mode must also meet the following shipping paper requirements 49 CFR 172.200 JACKSON 049779 The total amount of commercial asbestos being shipped i.e. the net weight of the product containing commercial asbestos 49 CFR 172.202 The proper shipping name and hazard class Asbestos ORM 49 CFR 172.202 i.e. If shipped on the same bill ous materials the asbestos hazardous entries or in lighte4d9 CFR 172.201 of lading with hazardentry should be before any a contrasting color high- d A signed certification 49 CFR 172.204 There are no shipping paper requirements when commercial is shipped via truck or rail modes 49 CFR 172.200 asbestos JACKSON 049780 16 FEDERAL ASBESTOS STANDARD MEDICAL SURVEILLANCE COMPLIANCE FLOW CHART is exposure at or above .1 fiber longer than 5 microns as an 8 hour TWA -No- No further action is required Yes ! Provide medical surveillance to employees prior to placement in exposure area t Detailed work and medical history with particular attention to respiratory and cardiopulmonary disorders and smoking habits bi Comprehensive physical examination with particular attention to respiratory and cardio- vascular systems 1 1. Chest rays on a x17 plate a lateral ray is strongly recommended 2. Pulmonary function tests FEV and FVC Y Are test results normal -No- Refer to Medical Surveillance Manual and consult with Corporate Medical Director Repeat tests annually and upon termination of work in exposure area JACKSON 049781 VY ASBESTOS MANUAL November 9 1979 The Firestone Tire & Rubber Company JACKSON 049782 jf CONTENTS Introduction cece ccees .....ceeceeee eee eseees Asbestos May Still be Found in Tire Plants cc sce eee sewn cccnes wc wee ece n ce All Other Plants ee eaeceee sees Page 1 OSHA Regulations oe Permissible Average Exposure Limit and Ceiling Concentration ae eesees Air Monitoring and Sampling Frequency Employee Notification and Recordkeeping of Exposure Results Methods of Compliance ..cccsccsccccccce eee Particular Tools ccc ween cee ec ce wcee Wet Methods ..... ccc cccccsucvvcccccse ^ + Spraying Demolition or Removal of Asbestos Insulation Respiratory Protective Equipment 455 Air Purifying Respirators 455 Powered Air Purifying Respirator 5 Type C Supplied Respirators Continuous Flow or Pressure- demand Type .. Special Clothing - Clothes Lockers - Laundering scsacccccscccesccnece wcccee 50 Caution Signs and Caution Labels JACKSON 049783 CONTENTS Housekeeping - Waste Disposal een eecene Page Medical Examinations 7 Asb .. cce c erens ce reet r enc os cereaaenscceccnaas 7 7 A. Reason for medical surveillance B. Forms of asbestos included ....eeeee00% C. Level of exposure wo D. Typeosf medical tests and pro. cc ccce ccccd cccnu cacar nasve ccucs ace E. Frequency of medical tests and procedures eae enensen eeeseee wae F. Interpretation of medical tests and procedures ccccvcescccceccecsccces EPA Regulation ...ccceccscccscccccenccunascees Introduction 9 10 10 Reason for Control of Asbestos Emissions ane ceececcceecese 11 Emission Standard for Asbestos 11 Section 61.22 of the Emission Standard seeewes Department of Transportation Regulation Medical Surveillance Flow Chart ccccaccace ee enae 14 16 JACKSON 049784 1 INTRODUCTION Asbestos and materials containing asbestos are now regulated by several federal regulatory agencies The purpose of this manual is to compile in one document all applicable federal regulations and assist and guide the plants in complying with these regulations The use of asbestos or materials containing asbestos in our plants is now very limited According to the information that we have available asbestos insulation may still be used or found in the following areas Tire Plants 1. Curing area a Old pipe insulation b Curing press heat shields c Board type asbestos insulation between press platens or domes and in the curing press frame This asbestos material is cut or machined by the McNeil Company or NRM and is only installed by Firestone people d Pipe insulation installed by McNeil or NRM on new presses that are shipped to Firestone plants e NRM well insulation 2 Powerhouse - Plants ten years old or older a Pipe insulation b Deaerator heater 3. Maintenance a Gaskets made from a material containing asbestos . Welding blankets or guards 4 Tire building - Hot knife boxes a 99R3 TAM - Asbestos tubing 1.5 o.d. - 1.25 i.d. x 1 long two per machine This tubing insulates the heated magnets from the rest of the assembly Asbestos tape 0.5 wide x 15 long four per machine This tape is wrapped around the heating elements and tubing described above JACKSON 049785 2 b All Radial First Stage TAM's Radial sidewall knife - Heat sink hot box Manganese wire with asbestosglass insulation AWG 14 16 required per machine All Other Plants 1 Gaskets made from a material containing asbestos that are cut to size and drilled to open holes 2. Experimental formulation of small batches of rubber products containing asbestos This is done in an Akron laboratory of the Synthetic Rubber Division Maintenance operations in plants often require the removal or demolition of old asbestos insulation The removal of asbestos insulation is of considerable importance from the standpoint of compliance with federal regulations since the potential of employee exposure to airborne asbestos fibers is usually higher than in other operations The manual is divided into three sections The first section describes the OSHA standard on asbestos The second section de- scribes the EPA regulations on asbestos which are applicable to Firestone operations The third section summarizes the current Department of Transportation regulations on asbestos JACKSON 049786 3 I. OSHA REGULATION SECTION 1910.1001 The OSHA standard on asbestos is described in Section 1910 1001 of the OSHA standards book Permissible Average Exposure Limit and Ceiling Concentration The present hour weighted average permissible exposure limit is two 2 fibers longer than 5 microns per cubic centimeter of air The permissible ceiling exposure limit is ten 10 fibers longer than 5 microns per cubic centimeter of air as determined over a period of 15 minutes Air Monitoring and Sampling Frequency All operations where asbestos and materials containing asbestos are being used or old asbestos insulation is being removed replaced or repaired must be monitored by air sampling to determine employee exposure to airborne asbestos fibers Samples should be collected from within the breathing zone of the employees on membrane filters mounted in an open face filter holder cassette Samples should be taken for the determination of the hour weighted average concentration and of the ceiling concentration of asbestos fibers Cassettes for collecting air samples for asbestos are provided to the plants by the Industrial Hygiene Department After samp- ling these cassettes are returned to Industrial Hygiene for analysis and calculation of the airborne concentration of as- bestos fibers Detailed instructions on how to collect air samples for asbestos have been sent to the plant safety engineers by the Industrial Hygiene Department After the initial determination samples should be of such fre- quency and pattern as to represent with reasonable accuracy the levels of exposure of employees to asbestos fibers In no case should the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos exceeds the permissible exposure limit or the permissible ceiling concentration Affected employees or their representatives should be given an opportunity to observe the monitoring operation JACKSON 049787 4 Employee Notification and Recordkeeping of Exposure Results Any employee found to have been exposed at any time to air- borne concentrations of asbestos fibers in excess of the per- missible exposure limit or the permissible ceiling concentration must be notified in writing of the exposure as soon as practicable but not later than 5 days of the finding The employee must also be timely notified of the corrective action taken to reduce the airborne concentration of asbestos fibers Every employer must maintain records of any personal or environmental monitoring required by Section 1910.1001 Records must be maintained for a period of at least 20 years and must be made available upon request to the Assistant Secretary of Labor for OSHA the Director of NIOSH and to their authorized representa- tives Every employee and former employee shall have reasonable access to any records required to be maintained by this standard which indicate the employee's own exposure to asbestos fibers Methods of Compliance 1 Particular Tools All operated and operated tools which may produce or release asbestos fibers in excess of the exposure limits listed above such as saws scorers abrasive wheels and drills must be provided with local exhaust ventilation sys- tems 2 Wet Methods Insofar as practicable asbestos must be handled mixed applied removed cut scored or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the permissible exposure limits unless the usefulness of the product would be diminished by wetting it Spraying Demolition or Removal of Asbestos Insulation Employees engaged in the spraying of asbestos the removal or demolition of pipes structures or equipment covered or insulated with asbestos and in the removal or demolition of asbestos insulation or coverings must be provided with respiratory protective equipment and special clothing as described below BATO JACKSON 049788 5 Respiratory Protective Equipment 1 Air Purifying respirators A reusable or single use disposable air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 2 but not greater than 20 fibers per cubic centi- meter of air 2. Powered Air Purifying Respirator A powered air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 20 but not greater than 200 fibers per cubic centimeter of air 3. Type C Supplied Respirators Continuous Flow or Pressure Type A type C continuous flow or pressure supplied respirator must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 200 fibers per cubic centimeter of air The OSHA standard specifies that employees engaged in the removal or demolition of asbestos insulation shall be provided with supplied respirators For the removal of large sections of insulation which would normally last several days a suppliedair respirator must be provided As a general guideline when the amount of asbestos to be removed is small and the operation will only last a few hours or less a supplied respirator should still be provided if feasible If this is not feasible at least an air purifying respirator should be provided Special Clothing - Clothes Lockers - Laundering The employer must provide and require the use of special clothing such as coveralls or similar whole body clothing head coverings gloves and foot coverings for any employee exposed to airborne concentrations of asbestos fibers which exceed the permissible exposure limits or who is engaged in the removal or demolition of asbestos insulation At any fixed place of employment exposed to airborne concentrations of asbestos fibers in excess of the permissible exposure limits the employer must provide change rooms for employees working regularly at the place JACKSON 049789 6 The employer must provide two separate lockers or containers for each employee so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes Laundering of asbestos contaminated clothing must be done so as to prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Any employer who gives asbestos contaminated clothing to another person for laundering must inform such person of the requirement to effectively prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Contaminated clothing must be transported in sealed impermeable bags or other closed impermeable containers and labeled in accordance with paragraph ii of the standard It is now common practice among employers to provide their employees who are engaged in asbestos insulation removal with disposable coveralls head coverings and shoe coverings The use of disposable protective clothing eliminates the necessity of laundering work clothes contaminated with asbestos and all other problems associated with it Caution Signs and Caution Labels Caution signs must be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the permissible exposure limits Signs must be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps before entering the area marked by the signs Signs must be posted at all approaches to areas containing excessive concentrations of asbestos fibers ii The signs must display a legend which is described in paragraph g of this standard Since during the short time needed for a demolition or removal of asbestos insulation it is not usually possible to determine if the concentration of airborne fibers is above or below the permissible exposure limits caution signs should be all asbestos removal operations These signs should after the work is completed posted at be removed Caution labels must 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 JACKSON 049790 7 coating binder ably foreseeable fibers in excess released or other material so that during any reason- use no airborne concentrations of asbestos of the permissible exposure limits will be The statement that is required on the label paragraph ii of this standard is described in Housekeeping - Waste Disposal All external surfaces in any place of employment must be main- tained free of accumulations of asbestos fibers Collection of settled dust or debris should be done by vacuum cleaning Do not clean up asbestos by blowing or dry sweeping Asbestos waste scrap debris bags containers equipment and contaminated clothing that is to be disposed of must be collected and disposed of in sealed impermeable bags or other closed impermeable containers The federal regulations pertaining to asbestos waste disposal practices and procedures are described in the next section of the manual under EPA Regulations Medical Examinations The standard requires that the employer provide or make available at his cost medical examinations to each of his employees exposed to asbestos fibers The medical examinations program required by OSHA is presented below this is a copy of the medical surveillance program for asbestos which has been adopt- ed by the Corporate Medical Department ASBESTOS A. Reason for medical surveillance 1 Required by the OSHA asbestos standard 29 CFR 1910 1001 ) B. Forms of asbestos included 1 Chrysotile 2. Amosite JACKSON 049791 8 Crocidolite 3. Tremolite 5 Anthophyllite Actinolite Level of exposure 1 Airborne exposure to asbestos at or above 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour weighted average Note This definition of exposure has been established by OSHA Program Directive 300-16 effective October 11 1978 and will not be found in the original OSHA asbestos standard Types of medical tests and procedures 1 Detailed work and medical history with particular attention to a Respiratory and cardiopulmonary disorders b Smoking habits Comprehensive physical examination with particular attention to respiratory and cardiovascular systems Chest rays - PA on 14 x 17 plate a lateral ray is also strongly recommended 4 Pulmonary function tests - FEV and FVC Frequency of medical tests and procedures 1. All tests and procedures 2 Prior to or within 30 days after placement in an exposure area where airborne asbestos levels exceed 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour time- weighted average b At least annually while working in the exposure area JACKSON 049792 9 C. Within 30 days before or after termination of employment in an exposure area unless all the tests and procedures have been performed within the past year F. Interpretation of medical tests and procedures 1 Chest rays should be interpreted by a radiologist 2 In order to unify and standardize the pulmonary function tests the actual administration of the tests should be done by as few people as possible The original tracing and interpretation should be given to the plant physician for medical management A copy of each should be sent to the Corporate Medical Department for short and long term interpretation study and storage Whenever an employee shows signs or symptoms of chronic malignant or malignant lung disease or cardiopulmonary disorders which may be due to occupational exposure to asbestos the Corporate Medical Department should be consulted Any abnormality in the chest rays as compared to established norms or earlier findings a definite reduction in the FEV or FVC or degeneration of the employee's general respiratory condition should be reasons for not employing or for removing the employ- ee from the asbestos exposure area The responsibility for medical removal and reinstatement is that of the plant physician in consultation with as many other physicians as he deems necessary Medical records of employees examined under this protocol including examination and test results written medical opinions and records of employee complaints should be retained for at least five years after the last employment for each employee or for twenty years from the date of the record whichever is longer BATO JACKSON 049793 II 10 EPA REGULATION Introduction The EPA has established emission standards for certain hazardous air pollutants under its National Emission Standards for Hazardous Air Pollutants Regulations NESHAPS Asbestos is included as one of the four substances currently regulated under these regulations 40 CFR Part 61 Subpart B The NESHAPS regulations are applicable to the following oper- ations a asbestos mills b roadways c manufacturing d} demolition and renovation e spraying f fabricating g insulating h waste disposal Based upon Environmental Engineering's knowledge Firestone is mainly involved in Items d and h above EPA intentions are to administer these regulations on a state by state basis by delegating authority to the individual state air control agencies i.e. once they have met all the necessary requirements To date 31 states have been given this authority as follows Alabama Arizona California Colorado Connecticut Delaware Georgia Indiana Kentucky Maine Massachusetts Michigan Minnesota Montana Nevada New Hampshire New Jersey New York North Carolina North Vermont Dakota Oregon Pennsylvania Rhode Island South Carolina Texas Virginia Washington Wisconsin Puerto Rico and U. S. Virgin Islands These regulations i.e. NESHAPS for controlling asbestos emissions were first promulgated on April 6 1973 38 FR 8820 in fulfilling requirements under Section 112 B of the Clean Air Act as amended December 1970. Since then they have under- gone various revisions the most recent of which was promul- gated February 7 1979 giving administer the NESHAPS program state the and State issue of Texas permits authority to etc. in the From time to time additional pollutants which are found to be hazardous will be included under EPA NESHAPS regulations i.e. vinyl chloride was added to the original list on October 21 1976 41 FR 46560 May cause or contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness - Clean Air Act Section 112 December 1970 JACKSON 049794 11 Reason for Control of Asbestos Emissions A large number of studies have shown an association between occupational exposure to asbestos and a higher than expected incidence of bronchial cancer Asbestos also has been identi- fied as a causal factor in the development of cancers of the membranes of the chest and abdomen Emission Standard for Asbestos Basically the regulations prohibit any discharge of asbestos to the outside air which creates a visible emission which may be detected without the aid of instruments By definition outside air means the air outside buildings or structures A source can use a specified method of air cleaning fabric filter systems etc. to eliminate such emissions provided that the emission control equipment is approved by the administrator of the EPA or his authorized representative Specifically the asbestos standards are 1 There shall be no visible emissions to the outside air from any asbestos mill except when a specified method of air cleaning also part of these standards is used before the emissions escape to the outside air In general these cleaning systems filter asbestos emissions to the point that visible emissions would not be produced anyway 2. The surfacing of roadways with asbestos tailings is prohibited except for temporary roadways in an area of asbestos ore deposits 3. There shall be no visible emissions to the outside air unless the specified air cleaning methods are used from any operation which manufacturers cloth cord wicks tubing tape twine rope thread yarn roving lap other textile products cement products fireproofing and insulating materials friction products paper millboard felt floor tile paints coatings caulks adhesives sealants plastics and rubber materials and chlorine 4 The regulations covering demolition and renovation of buildings are a Asbestos materials used to insulate or fireproof any boiler pipe or structural member shall be wetted and removed from any building before the wrecking begins The asbestos debris shall be wetted at all stages of demolition and related handling operations ~ JACKSON 049795 12 No pipe or structural member covered with asbestos insulating or fireproofing material shall be dropped or thrown from any building but shall be carefully lowered to ground level No asbestos debris shall be dropped or thrown to the ground or from one floor to another For buildings 50 feet or greater in height asbestos debris shall be lowered to the ground via tight chutes or contain- ers Written notice of intention to demolish shall be pro- vided to the EPA Regional Administrator at least 10 days prior to commencement of demolition This notice shall include items under Section 61.22 of this regulation Certain demolition operations are exempt from the regulations except for the wetting of asbestos debris and the notification requirement if a building has been declared to be structurally unsound and in danger of imminent collapse Asbestos waste shall be sealed in tight containers while wet prior to being sent to an approved waste disposal site The tight containers Item f with a warning label which reads should be labeled CAUTION Contains Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hazardous to Your Health The owner or operator of a demolition operation is exempted from these requirements with the exception of Item d above provided the amount of friable asbestos materials in the building or portion thereof to be demolished is less than 80 meters ca. 260 feet used on pipes and less than 15 square meters ca. 160 square feet used on any duct boiler tank reactor turbine furnace or structural member These regulations also set forth collection processing and disposal requirements which the waste disposal firm must adhere to in handling and disposing of this waste 40 CFR 61.25 Since Firestone in most cases if not all will be utilizing outside firms for disposal of its asbestos wastes no further JACKSON 049796 13 discussion of these requirements will be presented herein Firestone however must verify that any firm selected to dispose of its asbestos waste will meet the requirements of paragraph 61.25 i.e. approved operation Following is Section 61.22 of the Emission standard Written notice of intention to demolisohr renovate shall be provided to the Administrator by the owner or operator of the demolition or renovation operation Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demolition or as early as possible prior to commencement of emergency demolition subject to paragraph d of this section and as early as possible prior to commencement of renovation Such notice shall in- clude the following information i Name of owner or operator ii Address of owner or operator iii Description of the building structure facility or installation to be demolished or renovated including the size age and prior use of the structure and the approximate amount of friable asbestos materials present iv Address or location of the building facility or installation structure v Scheduled starting and completion dates of demolition or renovation vi Nature of planned demolition or renovation and method to be employed vii Procedures to ments of this this section be employed to meet the paragraph and paragraph requirej of viii The name and address or disposal site where the will be deposited location of the waste friable asbestos waste ix Name title and authority of the State or local governmental representative who has ordered a demolition which is subject to paragraph d of this section JACKSON 049797 III 14 DEPARTMENT OF TRANSPORTATION REGULATIONS The Department of Transportation DOT currently only the transportation of commercial asbestos regulate regulates They do not 1 Asbestos which has no commercial value such as products which contain trace amounts as a contaminant 49 CFR 173 1090 2. Waste asbestos which is currently proposed to be regulated under DOT hazardous waste regulations preamble to final commercial asbestos rule issued December 4 1978 3 Asbestos which is immersed or fixed in a natural or arti- ficial binder material such as cement plastic resin or mineral ore 49 CFR 173.1090 asphalt DOT does material asbestos regulate commercial asbestos which is or product which has commercial value content 49 CFR 173.1090 defined as because of any its When regulated DOT requires that shipments of asbestos meet the following requirements 1 Packaging must be as specified in 49 CFR 173.1090 a tight packages such as metal or fiber drums b Bags which are dust and sift proof and are unitized on a pallet Pallet loads should be encased in a shrink wrapped plastic film or fiberboard secured by strapping C. Bags placed inside wooden or fiberboard boxes 2. Each outside package must be marked with the word Asbestos and the name and address of the consignee or consignor 49 CFR 173.304 and 173.306 3. Each outside container must be marked ORM in an approp- riate rectangle 49 CFR 172.316 Labels which can be used for this purpose are available through normal Firestone stationery store channels The form number and description for ordering purposes is 8974 ORM Label 4 Asbestos shipped via the water or air mode must also meet the following shipping paper requirements 49 CFR 172.200 JACKSON 049798 15 The total amount of commercial asbestos being shipped i.e. the net weight of the product containing commercial asbestos 49 CFR 172.202 The proper shipping name and hazard class Asbestos ORM 49 CFR 172.202 i.e. If shipped on the same bill ous materials the asbestos hazardous entries or in lighted 49 CFR 172.201 of lading with hazardentry should be before any a contrasting color high- d A signed certification 49 CFR 172.204 There are no shipping paper requirements when commercial is shipped via truck or rail modes 49 CFR 172.200 asbestos JACKSON 049799 16 FEDERAL ASBESTOS STANDARD MEDICAL SURVEILLANCE COMPLIANCE FLOW CHART Is exposure at or above .1 fiber longer than 5 microns as an 8 hour TWA -No- No further action is required Yes Provide medical surveillance to employees prior to placement in exposure area v Detailed work and medical history with particular attention to respiratory and cardiopulmonary disorders and smoking habits a 1 Comprehensive physical examination with particular attention to respiratory and cardio- vascular systems j 1. Chest rays on x17 plate a lateral ray is strongly recommended 2. Pulmonary function tests FEV and FVC y Are test results normal Yes Refer to Medical No- | Surveillance Manual and consult with Corporate Medical Director Repeat tests annually and upon termination of work in exposure area JACKSON 049800 ASBESTOS MANUAL November 9 1979 The Firestone Tire & Rubber Company JACKSON 049801 CONTENTS Page Introduction .. 1 Asbestos May Still be Found in Tire Plants ...... All Other Plants OSHA Regulations Permissible Average Exposure Limit and Ceiling Concentration .ccccccccceces Air Monitoring and Sampling Frequency Employee Notification and Recordkeeping of Exposure Results Methods of Compliance ....cceneuccessvcecs Particular Tools Wet Methods ... cevccccccccvsesesccssceces 4 + Spraying Demolition or Removal of Asbestos Insulation .ccscsccccnvccee Respiratory Protective Equipment Air Purifying Respirators Powered Air Purifying Respirator 5 Type C Supplied Respirators Continuous Flow or Pressure- demand Type ccccnecccccvessesccesccs Special Clothing - Clothes Lockers - Laundering .. 56 Caution Signs and Caution Labels 56 JACKSON 049802 CONTENTS Housekeeping - Waste Disposal Medical Examinations ...... Asbestos ... A. Reason for medical surveillance B. Forms of asbestos included C. Level of exposure Page 7 7 7 7 7 8 D. Types of medical tests and procedures ... 3 8 E. Frequency of medical tests and procedures ... 8 F. Interpretation of medical tests and procedures .. 9 EPA Regulation .... 10 Intr .. ..o nced cc cu ccvcc cnnct ccssi eseeo sesen ese 10 Reason for Control of Asbestos Emissions ...... ...... ...... Emission Standard for Asbestos Section 61.22 of the Emission Standard .... Department of Transportation Regulation Medical Surveillance Flow Chart 11 11 13 14 16 JACKSON 049803 1 INTRODUCTION Asbestos and materials containing asbestos are now regulated by several federal regulatory agencies The purpose of this manual is to compile in one document all applicable federal regulations and assist and guide the plants in complying with these regulations The use of asbestos or materials containing asbestos in our plants is now very limited According to the information that we have available asbestos insulation may still be used or found in the following areas Tire Plants 1 Curing area a Old pipe insulation b Curing press heat shields c Board type asbestos insulation between press platens or domes and in the curing press frame This asbestos material is cut or machined by the McNeil Company or NRM and is only installed by Firestone people d Pipe insulation installed by McNeil or NRM on new presses that are shipped to Firestone plants e NRM well insulation 2 Powerhouse > Plants ten years old or older a Pipe insulation b Deaerator heater 3. Maintenance a Gaskets made from a material containing asbestos b Welding blankets or guards 4 Tire building - Hot knife boxes 2. 99R3 TAM - Asbestos tubing 1.5 o.d. - 1.25 i.d. x " long two per machine This tubing insulates the heated magnets from the rest of the assembly Asbestos tape 055 wide x 15 long four per machine This tape is wrapped around the heating elements and tubing described above JACKSON 049804 2 b All Radial First Stage TAM's Radial sidewall knife - Heat sink hot box Manganese wire with asbestosglass insulation AWG 14 16 required per machine All Other Plants 1 Gaskets made from a material containing asbestos that are cut to size and drilled to open holes 2 Experimental formulation of small batches of rubber products containing asbestos This is done in an Akron laboratory of the Synthetic Rubber Division Maintenance operations in plants often require the removal or demolition of old asbestos insulation The removal of asbestos insulation is of considerable importance from the standpoint of compliance with federal regulations since the potential of employee exposure to airborne asbestos fibers is usually higher than in other operations The manual is divided into three sections The first section describes the OSHA standard on asbestos The second section de- scribes the EPA regulations on asbestos which are applicable to Firestone operations The third section summarizes the current Department of Transportation regulations on asbestos JACKSON 049805 3 I. OSHA REGULATION SECTION 1910.1001 The OSHA standard on asbestos is described in Section 1910 1001 of the OSHA standards book Permissible Average Exposure Limit and Ceiling Concentration The present hour weighted average permissible exposure limit is two 2 fibers longer than 5 microns per cubic centimeter of air The permissible ceiling exposure limit is ten 10 fibers longer than 5 microns per cubic centimeter of air as determined over a period of 15 minutes Air Monitorianngd Sampling Frequency All operations where asbestos and materials containing asbestos are being used or old asbestos insulation is being removed replaced or repaired must be monitored by air sampling to determine employee exposure to airborne asbestos fibers Samples should be collected from within the breathing zone of the employees on membrane filters mounted in an open face filter holder cassette Samples should be taken for the determination of the hour weighted average concentration and of the ceiling concentration of asbestos fibers Cassettes for collecting air samples for asbestos are provided to the plants by the Industrial Hygiene Department After sampling these cassettes are returned to Industrial Hygiene for analysis and calculation of the airborne concentration of as- bestos fibers Detailed instructions on how to collect air samples for asbestos have been sent to the plant safety engineers by the Industrial Hygiene Department After the initial determination samples should be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees to asbestos fibers In no case should the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos exceeds the permissible exposure limit or the permissible ceiling concentration Affected employees or their representatives should be given an opportunity to observe the monitoring operation JACKSON 049806 4 Employee Notification and Recordkeeping of Exposure Results Any employee found to have been exposed at any time to air- borne concentrations of asbestos fibers in excess of the per- missible exposure limit or the permissible ceiling concentration must be notified in writing of the exposure as soon as practicable but not later than 5 days of the finding The employee must also be timely notified of the corrective action taken to reduce the airborne concentration of asbestos fibers Every employer must maintain records of any personal or environmental monitoring required by Section 1910.1001 Records must be maintained for a period of at least 20 years and must be made available upon request to the Assistant Secretary of Labor for OSHA the Director of NIOSH and to their authorized representa- tives Every employee and former employee shall have reasonable access to any records required to be maintained by this standard which indicate the employee's own exposure to asbestos fibers Methods of Compliance 1 Particular Tools All operated and operated tools which may produce or release asbestos fibers in excess of the exposure limits listed above such as saws scorers abrasive wheels and drills must be provided with local exhaust ventilation sys- tems 2 Wet Methods Insofar as practicable asbestos must be handled mixed applied removed cut scored or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the permissible exposure limits unless the usefulness of the product would be diminished by wetting it Spraying Demolition or Removal of Asbestos Insulation Employees engaged in the spraying of asbestos the removal or demolition of pipes structures or equipment covered or insulated with asbestos and in the removal or demolition of asbestos insulation or coverings must be provided with respiratory protective equipment and special clothing as described below JACKSON 049807 5 Respiratory Protective Equipment 1. Air Purifying respirators A reusable or single use disposable air purifying res- pirator or a respirator of higher efficiency must be used by the employees when the hour weighted aver- age airborne concentration of asbestos fibers is greater than 2 but not greater than 20 fibers per cubic centi- ee, met ofe airr prea 2 Powered Air Purifying Respirator ets er _ rn ee ee a A powered air purifying respirator or a respirator of ewe higher efficiency must be used by the employees when the hour weighted average airborne concentration of greater asbestos fibers is greater than 20 but not fibers per cubic centimeter of air than 200 3. Type C Supplied Respirators Continuous Flow or Pressure Type A type C continuous flow or pressure supplied respirator must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 200 fibers per cubic centimeter of air The OSHA standard specifies that employees engaged in the removal or demolition of asbestos insulation shall be provided with supplied respirators For the removal of large sections of insulation which would normally last several days a suppliedair respirator must be provided As a general guideline when the amount of asbestos to be removed is small and the operation will only last a few hours or less a supplied respirator should still be provided if feasible If this is not feasible at least an air purifying respirator should be provided Special Clothing - Clothes Lockers -- Laundering The employer must provide and require the use of special clothing such as coveralls or similar whole body clothing head coverings gloves and foot coverings for any employee exposed to airborne concentrations of asbestos fibers which exceed the permissible exposure limits or who is engaged in the removal or demolition of asbestos insulation At any fixed place of employment exposed to airborne concentrations of asbestos fibers in excess of the permissible exposure limits the employer must provide change rooms for employees working regularly at the place JACKSON 049808 6 The employer must provide two separate lockers or containers for each employee so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes Laundering of asbestos contaminated clothing must be done so as to prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Any employer who gives asbestos contaminated clothing to another person for laundering must inform such person of the requirement to effectively prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Contaminated clothing must be transported in sealed impermeable bags or other closed impermeable containers and labeled in accordance with paragraph ii of the standard It is now common practice among employers to provide their employees who are engaged in asbestos insulation removal with disposable coveralls head coverings and shoe coverings The use of disposable protective clothing eliminates the necessity of laundering work clothes contaminated with asbestos and all other problems associated with it Caution Signs and Caution Labels Caution signs must be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the permissible exposure limits Signs must be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps before entering the area marked by the signs Signs must be posted at all approaches to areas containing excessive concentrations of asbestos fibers ii The signs must display a legend which is described in paragraph g of this standard Since during the short time needed for a demolition or removal of asbestos insulation it is not usually possible to determine if the concentration of airborne fibers is above or below the permissible exposure limits caution signs should be all asbestos removal operations These signs should after the work is completed posted at be removed Caution labels must 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 JACKSON 049809 7 coating binder ably foreseeable fibers in excess released or other material so that during any reason- use no airborne concentrations of asbestos of the permissible exposure limits will be The statement that is required on the label paragraph ii of this standard is described in Housekeeping - Waste Disposal All external surfaces in any place of employment must be main- tained free of accumulations of asbestos fibers Collection of settled dust or debris should be done by vacuum cleaning Do not clean up asbestos by blowing or dry sweeping Asbestos waste scrap debris bags containers equipment and contaminated clothing that is to be disposed of must be collected and disposed of in sealed impermeable bags or other closed impermeable containers The federal regulations pertaining to asbestos waste disposal practices and procedures are described in the next section of the manual under EPA Regulations Medical Examinations The standard requires that the employer provide or make available at his cost medical examinations to each of his employees exposed to asbestos fibers The medical examinations program required by OSHA is presented below this is a copy of the medical surveillance program for asbestos which has been adopted by the Corporate Medical Department ASBESTOS A. Reason for medical surveillance 1 Required by the OSHA asbestos standard 29 CFR 1910 1001 ) B. Forms of asbestos included 1 Chrysotile 2. Amosite JACKSON 049810 8 3 Crocidolite 4 Tremolite 5 Anthophyllite 6. Actinolite Level of exposure 1 Airborne exposure to asbestos at or above 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour weighted average Note This definition of exposure has been established by OSHA Program Directive 300-16 effective October 11 1978 and will not be founidn the original OSHA asbestos standard Types of medical tests and procedures 1. Detailed work and medical history with particular attention to a Respiratory and cardiopulmonary disorders b Smoking habits Comprehensive physical examination with particular attention to respiratory and cardiovascular systems Chest rays - PA on 14 x 17 plate a lateral ray is also strongly recommended 4 Pulmonary function tests - FEV and FVC Frequency of medical tests and procedures 1. All tests and procedures a Prior to or within 30 days after placement in an exposure area where airborne asbestos levels exceed 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour time- weighted average b At least annually while working in the exposure area JACKSON 049811 9 C. Within 30 days before or after termination of employment in an exposure area unless all the tests and procedures have been performed within the past year F. Interpretation of medical tests and procedures : Chest rays should be interpreted by a radiologist In order to unify and standardize the pulmonary function tests the actual administration of the tests should be done by as few people as possible The original tracing and interpretation should be given to the plant physician for medical management A copy of each should be sent to the Corporate Medical Department for short and long term interpretation study and storage Whenever an employee shows signs or symptoms of chronic malignant or malignant lung disease or cardiopulmonary disorders which may be due to occupational exposure to asbestos the Corporate Medical Department should be consulted Any abnormality in the chest rays as compared to established norms or earlier findings a definite reduction in the FEV or FVC or degeneration of the employee's general respiratory condition should be reasons for not employing or for removing the employ- ee from the asbestos exposure area The responsibility for medical removal and rein- statement is that of the plant physician in consult- ation with as many other physicians as he deems necessary Medical records of employees examined under this protocol including examination and test results written medical opinions and records of employee complaints should be retained for at least five years after the last employment for each employee or for twenty years from the date of the record whichever is longer JACKSON 049812 II 10 EPA REGULATION Introduction The EPA has established emission standards for certain hazardous air pollutants under its National Emission Standards for Hazardous Air Pollutants Regulations NESHAPS Asbestos currently is included as one of the four substances currently under these regulations 40 CFR Part 61 Subpart regulated The NESHAPS regulations are applicable to the following oper- ations asbestos mills roadways he manufacturing demolition and renovation spraying fabricating g insulating ) waste disposal Engine ring's Based upon Environmental Engineering's knowledge Firestone is mainly involved in Items d and above EPA intentions are to administer these regulations on a state by state basis by delegating authority to the individual state air control agencies i.e. once they have met all the necessary requirements To date 31 states have been given this authority as follows Alabama Arizona California Colorado Connecticut Delaware Georgia Indiana Kentucky Maine Massachusetts Michigan Minnesota Montana Nevada New Hampshire New Jersey New York North Carolina North Dakota Oregon Pennsylvania Rhode Island South Carolina Texas Vermont Virginia Washington Wisconsin Puerto Rico and U. S. Virgin Islands These regulations i.e. NESHAPS for controlling asbestos emissions were first promulgated on April 6 1973 38 FR 8820 in fulfilling requirements under Section 112 B of the Clean Air Act as amended December 1970. Since then they have under- gone various revisions the most recent of which was promul- gated February 7 1979 giving the State of Texas authority to administer the NESHAPS program and issue permits etc. in the state me e From time to time additional pollutants which are found to be hazardous will be included under EPA NESHAPS regulations i.e. vinyl chloride was added to the original list on October 21 1976 41 FR 46560 May cause or contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness - Clean Air Act Section 112 December 1970 JACKSON 049813 ans BF en rey EN Pr 11 Reason for Control of Asbestos Emissions A large number of studies have shown an association between occupational exposure to asbestos and a higher than expected incidence of bronchial cancer Asbestos also has been identi- fied as a causal factor in the development of cancers of the membranes of the chest and abdomen Emission Standard for Asbestos Basically the regulations prohibit any discharge of asbestos to the outside air which creates a visible emission which may be detected without the aid of instruments By definition outside air means the air outside buildings or structures A source can use a specified method of air cleaning fabric filter systems etc. to eliminate such emissions provided that the emission control equipment is approved by the administrator of the EPA or his authorized representative Specifically the asbestos standards are 1 There shall be no visible emissions to the outside air from any asbestos mill except when a specified methoodf air cleaning also part of these standards is used before the emissions escape to the outside air In general these cleaning systems filter asbestos emissions to the point that visible emissions would not be produced anyway 2 The surfacing of roadways with asbestos tailings is prohibited except for temporary roadways in an area of asbestos ore deposits 3. There shall be no visible emissions to the outside air un- less the specified air cleaning methods are used from any operation which manufacturers cloth cord wicks tubing tape twine rope thread yarn roving lap other textile products cement products fireproofing and insulating paints adhesives sealants materials friction products paper tile coatings caulks and rubber materials and chlorine millboard felt floor plastics 4 The regulations covering demolition and renovation of build- ings are a Asbestos materials used to insulate or fireproof any boiler pipe or structural member shall be wetted and removed from any building before the wrecking begins The asbestos debris shall be wetted at all stages of demolition and related handling operations ana * ere nee a Yo * JACKSON 049814 12 No pipe or structural member covered with asbestos insulating or fireproofing material shall be dropped or thrown from any building but shall be carefully lowered to ground level No asbestos debris shall be dropped or thrown to the ground or from one floor to another For buildings 50 feet or greater in height asbestos debris shall be lowered to the ground via tight chutes or contain- ers Written notice of intention to demolish shall be pro- vided to the EPA Regional Administrator at least 10 days prior to commencement of demolition This notice shall include items under Section 61.22 of this regulation Certain demolition operations are exempt from the regulations except for the wetting of asbestos debris and the notification requirement if a building has been declared to be structurally unsound and in danger of imminent collapse Asbestos waste shall be sealed in tight containers while wet prior to being sent to an approved waste disposal site g The tight containers Item f should be labeled with a warning label which reads CAUTION Contains Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hazardous to Your Health The owner or operator of a demolition operation is exempted from these requirements with the exception of Item d above provided the amount of friable asbestos materials in the building or portion thereof to be demolished is less than 80 meters ca. 260 feet used on pipes and less than 15 square meters ca. 160 square feet used on any duct boiler tank reactor turbine furnace or structural member These regulations also set forth collection processing and disposal requirements which the waste disposal firm must adhere to in handling and disposing of this waste 40 CFR 61.25 Since Firestone in most cases if not all will be utilizing outside firms for disposal of its asbestos wastes no further JACKSON 049815 13 discussion of these requirements will be Firestone however must verify that any pose of its asbestos waste will meet the presented herein firm selected to dis- requirements of OR paragraph 61.25 i.e. approved operation woe _ ee . . -# - ~ Following is Section 61.22 of the Emission standard Written notice of intention to demolish or renovate shall be provided to the Administrator by the owner or operator of the demolition or renovation operation Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demolition or as early as possible prior to commencement of emergency demolition subject to paragraph d of this section and as early as possible prior to commencement of renovation Such notice shall in- clude the following information i Name of owner or operator ii Address of owner or operator iii Description of the building structure facility or installation to be demolished or renovated including the size age and prior use of the structure and the approximate amount of friable asbestos materials present iv Address or location of the building facility or installation structure v Scheduled starting and completion dates of demolition or renovation vi Nature of planned demolition or renovation and method to be employed vii Procedures to ments of this this section be employed to meet the paragraph and paragraph require- j of viii The name and address or disposal site where the will be deposited location of the waste friable asbestos waste ix Name title and authority of the State or local governmental representative who has ordered a demolition which is subject to paragraph d of this section JACKSON 049816 III 14 DEPARTMENT OF TRANSPORTATION REGULATIONS The Department of Transportation DOT currently only the transportation of commercial asbestos regulate regulates They do not 1 Asbestos which has no commercial value such as products which contain trace amounts as a contaminant 49 CFR 173 1090 2. Waste asbestos which is currently proposed to be regulated under DOT hazardous waste regulations preamble to final commercial asbestos rule issued December 4 1978 3 Asbestos which is immersed or fixed in a natural or arti- ficial binder material such as cement plastic asphalt resin or mineral ore 49 CFR 173.1090 DOT does regulate commercial asbestos which is defined as any material or product which has commercial value because of its asbestos content 49 CFR 173.1090 When regulated DOT requires that shipments of asbestos meet the following requirements 1 Packaging must be as specified in 49 CFR 173.1090 a tight packages such as metal or fiber drums . Bags which are dust and sift proof and are unitized on a pallet Pallet loads should be encased in a shrink wrapped plastic film or fiberboard secured by strapping C. Bags placed inside wooden or fiberboard boxes 2 Each outside package must be marked with the word Asbestos and the name and address of the consignee or consignor 49 CFR 173.304 and 173.306 3 Each outside container must be marked ORM in an approp- riate rectangle 49 CFR 172.316 Labels which can be used for this purpose are available through normal Firestone stationery store channels The form number and description for ordering purposes is 8974 ORM Label 4 Asbestos shipped via the water or air mode must also meet the following shipping paper requirements 49 CFR 172.200 JACKSON 049817 15 a The total amount of commercial asbestos being shipped i.e. the net weight of the product containing commercial asbestos 49 CFR 172.202 b The proper shipping name and hazard class i.e. Asbestos ORM 49 CFR 172.202 C. If shipped on the same bill of lading with hazardous materials the asbestos entry should be before any hazardous entries or in a contrasting color highlighted CFR 172.201 d A signed certification 49 CFR 172.204 There are no shipping paper requirements when commercial is shipped via truck or rail modes 49 CFR 172.200 asbestos JACKSON 049818 16 FEDERAL ASBESTOS STANDARD MEDICAL SURVEILLANCE COMPLIANCE FLOW CHART Is exposure at or above .1 fiber longer than 5 microns as an 8 hour TWA 7? Nofurther -No- action is required Yes Provide medical surveillance to employees prior to placement in exposure area a r Detailed work and medical history with particular attention to respiratory | and cardiopulmonary disorders and smoking habits hd Comprehensive =f physical examination with particular attention to : respiratory and cardio- vascular systems P y y Are test results -No Refer to Medical ,| Surveillance Manual and consult with Corporate Medical Director Yes | Repeat tests annually and upon termination of work in exposure area r 1. Chest rays on x17 plate a lateral ray is strongly recommended 2. Pulmonary function tests FEV and FVC Y JACKSON 049819 ASBESTOS MANUAL November 9 1979 The Firestone Tire & Rubber Company JACKSON 049820 CONTENTS Introduction eeeeee veeveces Page 1 AsbestoMasy Still be Found in Tire Plants en sercecece HN All Other Plan ccc t nec s n cs cnccnaces aaae 2 OSHA Regulations 3 Permissible Average Exposure Limit and Ceiling Concentration wees M Air Monitoring and Sampling Frequency 3 Employee Notification and Recordkeeping of Exposure Results 4 Methods of Compliance cassenncenccce oes 4 Particular Tools once een cees os + Wet Methods ... ee nee + Spraying Demolition or Removal of Asbestos Insulation ees 4 Respiratory Protective Equipment aes in Air Purifying Respirators 5 Powered Air Purifying Respirator eee in Type C Supplied Respirators Continuous Flow or Pressure- demand Type cccccccscacncccucee eenee 5 Special Clothing - Clothes Lockers - Laundering 560 Caution Signs and Caution Labels 560 JACKSON 049821 CONTENTS ..... Cont'd Page Housekeeping - Waste Disposal 7 Medical Examinations .sseeoess ee ccc ew eenes peace 7 Asbestos seme e ccc rc cas cece eesns . 7 A. Reason for medical surveillance . 7 B. Forms of asbestos included ..ccccceces 7 C. Level of exposure .cccccccccvsvccececses 8 D. Types of medical tests and procedurecesce wcceee wee c cere eenenee 8 E. Frequency of medical tests and procedures .. cece cece cca scccnaseruees 00 F. Interpretation of medical tests and procedures sseeeese EPA Regulation .csccccevesccce eevee scecseeese 9 10 Introduction ... 10 Reason for Control of Asbestos Emissions women eeweenocen eeseee 11 Emission Standard for Asbestos -.- 11 Section 61.22 of the Emission Standard 13 Department of Transportation Regulation 14 Medical Surveillance Flow Chart - 16 JACKSON 049822 1 INTRODUCTION Asbestos and materials containing asbestos are now regulated by several federal regulatory agencies The purpose of this manual is to compile in one document all applicable federal regulations and assist and guide the plants in complying with these regulations The use of asbestos or materials containing asbestos in our plants is now very limited According to the information that we have available asbestos insulation may still be used or found in the following areas Tire Plants 1 Curing area a Old pipe insulation b Curing press heat shields C. Board type asbestos insulation between press platens or domes and in the curing press frame This asbestos material is cut or machined by the McNeil Company or NRM and is only installed by Firestone people d Pipe insulation installed by McNeil or NRM on new presses that are shipped to Firestone plants e NRM well insulation 2 Powerhouse - Plants ten years old or older 2. Pipe insulation b Deaerator heater 3 Maintenance 2 Gaskets made from a material containing asbestos b Welding blankets or guards 4 Tire building - Hot knife boxes a 99R3 TAM - Asbestos tubing 1.5 o.d. - 1.25 i.d. x 1 long two per machine This tubing insulates the heated magnets from the rest of the assembly Asbestos tape 0.5 wide x 15 long four per machine This tape is wrapped around the heating elements and tubing described above JACKSON 049823 2 b All Radial First Stage TAM's Radial sidewall knife - Heat sink hot box Manganese wire with asbestosglass insulation AWG 14 16 required per machine All Other Plants 1 Gaskets made from a material containing asbestos that are cut to size and drilled to open holes 2 Experimental formulation of small batches of rubber products containing asbestos This is done in an Akron laboratory of the Synthetic Rubber Division Maintenance operations in plants often require the removal or demolition of old asbestos insulation The removal of asbestos insulation is of considerable importance from the standpoint of compliance with federal regulations since the potential of employee exposure to airborne asbestos fibers is usually higher than in other operations The manual is divided into three sections The first section describes the OSHA standard on asbestos The second section de- scribes the EPA regulations on asbestos which are applicable to Firestone operations The third section summarizes the current Department of Transportation regulations on asbestos JACKSON 049824 3 I. OSHA REGULATION SECTION 1910.1001 The OSHA standard on asbestos is 1001 of the OSHA standards book described in Section 1910 Permissible Average Exposure Limit and Ceiling Concentration The present hour weighted average permissible exposure limit is two 2 fibers longer than 5 microns per cubic centimeter of air The permissible ceiling exposure limit is ten 10 fibers longer than 5 microns per cubic centimeter of air as determined over a period of 15 minutes Air Monitorianngd Sampling Frequency All operations where asbestos and materials containing asbestos are being used or old asbestos insulation is being removed replaced or repaired must be monitored by air sampling to determine employee exposure to airborne asbestos fibers Samples should be collected from within the breathing zone of the employees on membrane filters mounted in an open face filter holder cassette Samples should be taken for the determination of the hour weighted average concentration and of the ceiling concentration of asbestos fibers Cassettes for collecting air samples for asbestos are provided to the plants by the Industrial Hygiene Department After sampling these cassettes are returned to Industrial Hygiene for analysis and calculation of the airborne concentration of as- bestos fibers Detailed instructions on how to collect air samples for asbestos have been sent to the plant safety engineers by the Industrial Hygiene Department After the initial determination samples should be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees to asbestos fibers In no case should the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos exceeds the permissible exposure limit or the permissible ceiling concentration Affected employees or their representatives should be given an opportunity to observe the monitoring operation BATO JACKSON 049825 4 Employee Notification and Recordkeepinogf Exposure Results Any employee found to have been exposed at any time to air- borne concentrations of asbestos fibers in excess of the per- missible exposure limit or the permissible ceiling concentration must be notified in writing of the exposure as soon as practicable but not later than 5 days of the finding The employee must also be timely notified of the corrective action taken to reduce the airborne concentration of asbestos fibers Every employer must maintain records of any personal or environmental monitoring required by Section 1910.1001 Records must be maintained for a period of at least 20 years and must be made available upon request to the Assistant Secretary of Labor for OSHA the Director of NIOSH and to their authorized representa- tives Every employee and former employee shall have reasonable access to any records required to be maintained by this standard which indicate the employee's own exposure to asbestos fibers Methods of Compliance 1 Particular Tools All operated and operated tools which may produce or release asbestos fibers in excess of the exposure limits listed above such as saws scorers abrasive wheels and drills must be provided with local exhaust ventilation sys- tems 2. Wet Methods Insofar as practicable asbestos must be handled mixed applied removed cut scored or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the permissible exposure limits unless the usefulness of the product would be diminished by wetting it Spraying Demolition or Removal of Asbestos Insulation Employees engaged in the spraying of asbestos the removal or demolition of pipes structures or equipment covered or insulated with asbestos and in the removal or demolition of asbestos insulation or coverings must be provided with respiratory protective equipment and special clothing as described below JACKSON 049826 5 Respiratory Protective Equipment 1 Air Purifying respirators A reusable or single use disposable air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 2 but not greater than 20 fibers per cubic centi- meter of air 2 Powered Air Purifying Respirator A powered air purifying respirator or a respirator of higher efficiency must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 20 but not greater than 200 fibers per cubic centimeter of air Continuous 3. Type C Supplied Respirators Pressure Type Flow or A type C continuous flow or pressure supplied respirator must be used by the employees when the hour weighted average airborne concentration of asbestos fibers is greater than 200 fibers per cubic centimeter of air The OSHA standard specifies that employees engaged in the removal or demolition of asbestos insulation shall be provided with supplied respirators For the removal of large sections of insulation which would normally last several days a suppliedair respirator must be provided As a general guideline when the amount of asbestos to be removed is small and the operation will only last a few hours or less a supplied respirator should still be provided if feasible If this is not feasible at least an air purifying respirator should be provided Special Clothing - Clothes Lockers - Laundering The employer must provide and require the use of special clothing such as coveralls or similar whole body clothing head coverings gloves and foot coverings for any employee exposed to airborne concentrations of asbestos fibers which exceed the permissible exposure limits or who is engaged in the removal or demolition of asbestos insulation At any fixed place of employment exposed to airborne concentrations of asbestos fibers in excess of the permissible exposure limits the employer must provide change rooms for employees working regularly at the place JACKSON 049827 6 The employer must provide two separate lockers or containers for each employee so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes Laundering of asbestos contaminated clothing must be done so as to prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Any employer who gives asbestos contaminated clothing to another person for laundering must inform such person of the requirement to effectively prevent the release of airborne asbestos fibers in excess of the permissible exposure limits Contaminated clothing must be transported in sealed impermeable bags or other closed impermeable containers and labeled in accordance with paragraph ii of the standard It is now common practice among employers to provide their employees who are engaged in asbestos insulation removal with disposable coveralls head coverings and shoe coverings The use of disposable protective clothing eliminates the necessity of laundering work clothes contaminated with asbestos and all other problems associated with it Caution Signs and Caution Labels Caution signs must be provided and displayed at each location where airborne concentrations of asbestos fibers may exceed the permissible exposure limits Signs must be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps before entering the area marked by the signs Signs must be posted at all approaches to areas containing excessive concentrations of asbestos fibers signs The g must display a legend which is ii of this standard described in paragraph Since during the short time needed for a demolition or removal of asbestos insulation it is not usually possible to determine if the concentration of airborne fibers is above or below the permissible exposure limits caution signs should be all asbestos removal operations These signs should after the work is completed posted at be removed Caution labels must 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 JACKSON 049828 7 coating binder ably foreseeable fibers in excess released or other material so that during any reason- use no airborne concentrations of asbestos of the permissible exposure limits will be The statement that is required on the label is described in paragraph ii of this standard Housekeeping - Waste Disposal . All external surfaces in any place of employment must be main- tained free of accumulations of asbestos fibers Collection of settled dust or debris should be done by vacuum cleaning Do not clean up asbestos by blowing or dry sweeping Asbestos waste scrap debris bags containers equipment and contaminated clothing that is to be disposed of must be collected and disposed of in sealed impermeable bags or other closed impermeable containers The federal regulations pertaining to asbestos waste disposal practices and procedures are described in the next section of the manual under EPA Regulations Medical Examinations The standard requires that the employer provide or make available at his cost medical examinations to each of his employees exposed to asbestos fibers The medical examinations program required by OSHA is presented below this is a copy of the medical surveillance program for asbestos which has been adopt- ed by the Corporate Medical Department ASBESTOS A. Reason for medical surveillance 1 Required by the OSHA asbestos standard 29 CFR 1910 1001 ) B. Forms of asbestos included 1 Chrysotile 2 Amosite JACKSON 049829 8 Crocidolite Tremolite Anthophyllite Actinolite Level of exposure 1 Airborne exposure to asbestos at or above 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour weighted average Note This definition of exposure has been established by OSHA Program Directive 300-16 effective October 11 1978 and will not be found in the original OSHA asbestos standard Types of medical tests and procedures 1 Detailed work and medical history with particular attention to a Respiratory and cardiopulmonary disorders b Smoking habits Comprehensive physical examination with particular attention to respiratory and cardiovascular systems Chest rays - PA on 14 x 17 plate a lateral ray is also strongly recommended 4 Pulmonary function tests - FEV and FVC Frequency of medical tests and procedures 1. All tests and procedures a Prior to or within 30 days after placement in an exposure area where airborne asbestos levels exceed 0.1 fibers longer than 5 micrometers per cubic centimeter of air as an hour time- weighted average b At least annually while working in the exposure area JACKSON 049830 9 c Within 30 days before or after termination of employment in an exposure area unless all the tests and procedures have been performed within the past year F. Interpretation of medical tests and procedures 1 Chest rays should be interpreted by a radiologist 2 In order to unify and standardize the pulmonary function tests the actual administration of the tests should be done by as few people as possible The original tracing and interpretation should be given to the plant physician for medical management A copy of each should be sent to the Corporate Medical Department for short and long term interpretation study and storage Whenever an employee shows signs or symptoms of chronic malignant or malignant lung disease or cardiopulmonary disorders which may be due to occupational exposure to asbestos the Corporate Medical Department should be consulted Any abnormality in the chest rays as compared to established norms or earlier findings a definite reduction in the FEV or FVC or degeneration of the employee's general respiratory condition should be reasons for not employing or for removing the employ- ee from the asbestos exposure area The responsibility for medical removal and reinstatement is that of the plant physician in consultation with as many other physicians as he deems necessary Medical records of employees examined under this protocol including examination and test results written medical opinions and records of employee complaints should be retained for at least five years after the last employment for each employee or for twenty years from the date of the record whichever is longer JACKSON 049831 II 10 EPA REGULATION Introduction The EPA has established emission standards for certain hazardous air pollutants under its National Emission Standards for Hazardous Air Pollutants Regulations NESHAPS Asbestos currently is included as one of the four substances currently under these regulations 40 CFR Part 61 Subpart regulated The NESHAPS regulations are applicable to the following oper- ations a asbestos mills b roadways c manufacturing d demolition and renovation e spraying f fabricating h insulating h waste disposal Based upon Environmental Engineering's knowledge Firestone is mainly involved in Items d and h above EPA intentions are to administer these regulations on a state by state basis by delegating authority to the individual state air control agencies i.e. once they have met all the necessary requirements To date 31 states have been given this authority as follows Alabama Arizona California Colorado Connecticut Delaware Georgia Indiana Kentucky Maine Massachusetts Michigan Minnesota Montana Nevada New Hampshire New Jersey New York North Carolina North Dakota Oregon Pennsylvania Rhode Island South Carolina Texas Vermont Virginia Washington Wisconsin Puerto Rico and U. S. Virgin Islands These regulations i.e. NESHAPS for controlling asbestos emissions were first promulgated on April 6 1973 38 FR 8820 in fulfilling requirements under Section 112 B of the Clean Air Act as amended December 1970. Since then they have undergone various revisions the most recent of which was promulgated February 7 1979 giving the State of Texas authority to administer the NESHAPS program and issue permits etc. in the state From time to time additional pollutants which are found to be hazardous will be included under EPA NESHAPS regulations i.e. vinyl chloride was added to the original list on October 21 1976 41 FR 46560 May cause or contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness - Clean Air Act Section 112 December 1970 JACKSON 049832 11 Reason for Control of Asbestos Emissions A large number of studies have shown an association between occupational exposure to asbestos and a higher than expected incidence of bronchial cancer Asbestos also has been identi- fied as a causal factor in the development of cancers of the membranes of the chest and abdomen Emission Standard for Asbestos Basically the regulations prohibit any discharge of asbestos to the outside air which creates a visible emission which may be detected without the aid of instruments By definition outside air means the air outside buildings or structures etc. A source can use a specified method of air cleaning fabric filter systems to eliminate such emissions provided that the emission control equipment is approved by the admin- istrator of the EPA or his authorized representative Specifically the asbestos standards are _ 1 There shall be no visible emissions to the outside air from any asbestos mill except when a specified method of air cleaning also part of these standards is used before the emissions escape to the outside air In general these cleaning systems filter asbestos emissions to the point that visible emissions would not be produced anyway 2 The surfacing of roadways with asbestos tailings is prohibited except for temporary roadways in an area of asbestos ore deposits 3 There shall be no visible emissions to the outside air unless the specified air cleaning methods are used from any operation which manufacturers cloth cord wicks tubing tape twine rope thread yarn roving lap other textile products cement products fireproofing and insulating materials friction products paper millboard felt floor tile paints coatings caulks adhesives sealants plastics and rubber materials and chlorine 40 The regulations covering demolition and renovation of buildings are a Asbestos materials used to insulate or fireproof any boiler pipe or structural member shall be wetted and removed from any building before the wrecking begins The asbestos debris shall be wetted at all stages of demolition and related handling operations BATO JACKSON 049833 12 No pipe or structural member covered with asbestos insulating or fireproofing material shall be dropped or thrown from any building but shall be carefully lowered to ground level No asbestos debris shall be dropped or thrown to the ground or from one floor to another For buildings 50 feet or greater in height asbestos debris shall be lowered to the ground via tight chutes or contain- ers Written notice of intention to demolish shall be pro- vided to the EPA Regional Administrator at least 10 days prior to commencement of demolition This notice shall include items under Section 61.22 of this regulation Certain demolition operations are exempt from the regulations except for the wetting of asbestos debris and the notification requirement if a building has been declared to be structurally unsound and in danger of imminent collapse Asbestos waste shall be sealed in tight containers while wet prior to being sent to an approved waste disposal site The tight containers Item f with a warning label which reads should be labeled CAUTION Contains Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hazardous to Your Health The owner or operator of a demolition operation is ex- empted from these requirements with the exception of Item d above provided the amount of friable asbestos materials in the building or portion thereof to be demolished is less than 80 meters ca. 260 feet used on pipes and less than 15 square meters ca. 160 square feet used on any duct boiler tank reactor turbine furnace or structural member These regulations also set forth collection processing and disposal requirements which the waste disposal firm must adhere to in handling and disposing of this waste 40 CFR 61.25 Since Firestone in most cases if not all will be utilizing outside firms for disposal of its asbestos wastes no further JACKSON 049834 13 discussion of these requirements will be presented herein Firestone however must verify that any firm selected to dis- pose of its asbestos waste will meet the requirements of paragraph 61.25 i.e. approved operation Following is Section 61.22 of the Emission standard Written notice of intention to demolish or renovate shall be provided to the Administrator by the owner or operatoorf the demolition or renovation operation Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demolition or as early as possible prior to commencement of emergency demolition subject to paragraph d of this section and as early as possible prior to commencement of renovation Such notice shall in- clude the following information i Name of owner or operator ii Address of owner or operator iii Description of the building structure facility or installation to be demolished or renovated including the size age and prior use of the structure and the approximate amount of friable asbestos materials present iv Address or location of the building facility or installation structure v Scheduled starting and completion dates of demolition or renovation vi Nature of planned demolition or renovation and method to be employed vii Procedures to ments of this this section be employed to meet the paragraph and paragraph require- j of viii The name and address or disposal site where the will be deposited location of the waste friable asbestos waste ix Name title and authority of the State or local governmental representative who has ordered a demolition which is subject to paragraph d of this section JACKSON 049835 III 14 DEPARTMENT OF TRANSPORTATION REGULATIONS The Department of Transportation DOT currently only the transportation of commercial asbestos regulate regulates They do not 1 Asbestos which has no commercial value such as products which contain trace amounts as a contaminant 49 CFR 173 1090 2. Waste asbestos which is currently proposed to be regulated under DOT hazardous waste regulations preamble to final commercial asbestos rule issued December 4 1978 3 Asbestos which is immersed or fixed in a natural or arti- ficial resin binder material such as cement plastic or mineral ore 49 CFR 173.1090 asphalt DOT does regulate commercial asbestos which is defined as any material or product which has commercial value because of its asbestos content 49 CFR 173.1090 When regulated DOT requires that shipments of asbestos meet the following requirements 1 Packaging must be as specified in 49 CFR 173.1090 a tight packages such as metal or fiber drums b Bags which are dust and sift proof and are unitized on a pallet Pallet loads should be encased in a shrink wrapped plastic film or fiberboard secured by strapping C. Bags placed inside wooden or fiberboard boxes 2. Each outside package must be marked with the word Asbestos and the name and address of the consignee or consignor 49 CFR 173.304 and 173.306 3. Each outside container must be marked ORM in an approp- riate rectangle 49 CFR 172.316 Labels which can be used for this purpose are available through normal Firestone stationery store channels The form number and description for ordering purposes is 8974 ORM Label 4. Asbestos shipped via the water or air mode must also meet the following shipping paper requirements 49 CFR 172.200 JACKSON 049836 15 The total amount of commercial asbestos being shipped i.e. the net weight of the product containing commercial asbestos 49 CFR 172.202 The proper shipping name and hazard class Asbestos ORM 49 CFR 172.202 i.e. If shipped on the same bill ous materials the asbestos hazardous entries or in lighted CFR 172.201 of lading with hazardentry should be before any a contrasting color high- d A signed certification 49 CFR 172.204 There are no shipping paper requirements when commercial is shipped via truck or rail modes 49 CFR 172.200 asbestos JACKSON 049837 16 FEDERAL ASBESTOS STANDARD MEDICAL SURVEILLANCE COMPLIANCE FLOW CHART Is exposure at or above .1 fiber longer than 5 microns as an 8 hour TWA Nofurther -No- action is required Yes Provide medical surveillance to employees prior to placement in exposure area 1 Detailed work and medical history with particular attention to respiratory and cardiopulmonary disorders and smoking habits Y Comprehensive physical examination with particular attention to respiratory and cardiovascular systems t v 1. Chest rays on x17 plate a lateral ray is strongly recommended 2. Pulmonary function tests FEV and FVC } Are test results normal Yes Refer to Medical -No- ,| Surveillance Manual and consult with Corporate Medical Director Repeat tests annually and upon termination of work in exposure area BATO JACKSON 049838