Document G55p3yO6G2jLNpmBqYZYOkORY

BENDIX MEETING - AUGUST 7, 1972 Wimpt } THE OCCUPATIONAL SAFETY AND HEALTH ACT OF 1970 ESTABLISHES f AS LAW/LITERALLY THOUSANDS OF SAFETY AND HEALTH STANDARDS. t, IT PLACES ON MANAGEMENT THE FULL FES PONSIJ3II.TTY aFQR MEETING THESE STANDARDS. SLIDE 1 - ON UNDER THE ACT, THE SECRETARY OF LABOR IS REQUIRED TO ESTABLISH SAFETY AND HEALTH STANDARDS THAT "WILL INSURE THAT NO EMPLOYEE/ WILL SUFFER MATERIAL IMPAIRMENT OF HEALTh/oR FUNCTIONAL CAPACITY IN A WORKING LIFETIME". /// t /' /<? ... /. '//' V M A7*?!At. ___ >- ? t i l' ON APRIL 28, 1971/ THE WALSH-HEALY,/lONGSHOREMAN/'AND OTHER FEDERAL ACT STANDARDS-AND-THE NATIONAL CONSENSUS STANDARDS/ SUCH AS THOSE OF THE NATIONAL FIRE PROTECTION ASSOCIATION AND AMERICAN NATIONAL STANDARD INSTXTUTEI WERE ESTABLISHED AS OSHA STANDARDS WITH THE FULL EFFECT OF THE LAW. THESE STANDARDS COVER ACTUALLY EVERY FACET/OF O&R OPERATIONS AND FACILITIES. THEY RANGE FROM STANDARDS FOR WORK SURFACES, LADDERS, MANLIFTS, SANITATION,''MEDICAL SERVICES/TO MATERIALS HANDLING,/ MACHINE GUARDING^ WELDING, ELECTRICAL EQUIPMENt/tO HAZARDOUS MATERIALS, AIR CONTAMINANTS/ NOISE AND RADIATION. 1 IN THE AREA OF TOXIC MATERIALS ALONE/ /THERE ARE EXPOSURE STANDARDS/FOR MORE THAN 500 SUBSTANCES. A THIRD SOURCE OF OSHA STANDARDS/ARE THOSE PROMULGATED BY THE SECRETARY OF LABOI^AS EMERGENCY,/ REVISED /6r ENTIRELY NEW. THE / ASBESTOS STANDARD EFFECTIVE JULY 7, 1972/ IS AN EXAMPLE OF THIS. / SLIDE 1 - OFF BECAUSE OF THE SCOPE AND COMPLEXITIES OF SAFETY AND HEALTH MATTERS,/THE 1970 ACT ESTABLISHED A RESEARCH FACILITY/wiTHIN THE f DEPARTMENT OF HEALTH, EDUCATION AND WELFARE/TO ADVISE THE SECRETARY OF LABOR. THIS ORGANIZATION IS THE NATIONAL INSTITUTE OF OCCUPATIONAL SAFETY AND HEALTH ~ NIOSH./ ESSENTIALLY, THIS GROUP WAS FORMERLY THE OCCUPATIONAL SAFETY AND HEALTH SECTION./ OF THE U.S. PUBLIC^ HEALTH SERVICe/wITH WHOM WE HAVE HAD CLOSE AND SATISFACTORY RELATIONSHIPS FOR MANY YEARS/ UNDER THE ACT, HOWEVER,/ NIOSH HAS A BROADER SCOPE OF RESPONSIBILITY7AND MUCH // MORE AUTHORITY. FORMERLY THEY HAD TO OBTAIN INDUSTRY'S WILLING /,/ ' COOPERATION/ON THEIR HEALTH RESEARCH EFFORTS. SLIDE 8 - ON NOW/ THEY HAVE THE AUTHORITY TO REQUIRE; 2 1. THE REPORTING OF EXPOSURE MEASUREMENTS .2 THE REPORTING OF HEALTH EXAMINATIONS AND TESTS 3. INDUSTRY-WIDE STUDIES OF CHRONIC LOW LEVEL EXPOSURES. 4. THEY CAN CONTRACT WITH RESEARCH ORGANIZATIONS ACADEMIC, INDUSTRY AND STATE/1TO UNDERTAKE THESE PROJECTS. 5. THEY HAVE THE RESPONSIBILITY TO ADVISE EMPLOYERS AND EMPLOYEES REGARDING THE TOXICITY OF ANY / r'" /t; St) // / / /- /! S' { | SUBSTANCE. f . - ^ ' '' SLIDE 8 - OFF ONE OF THE MOST IMPORTANT FUNCTIONS OF NIOSh/eS TO DEVELOP AND RECOMMEND TO THE SECRETARY OF LABOR/CRITERIA DOCUMENTS / FOR NEW OR REVISED STANDARDS. / THE FIRST CRITERIA DOCUMENT THAT NIOSH DEVELOPED/UNDER THEIR NEW AUTHORITy/wAS THAT FOR ASBESTOS FIBER. i t. WHY ASBESTOS FIRST?/ AN INTERESTING QUESTION./ NIOSH HAS A 5 FACTOR FORMULA;FOR ESTABLISHING THE PRIORITY OF THEIR EFFORTS. WE HAVE BEEN PRIVATELY ADVISED/THAT ON THIS BASIS/ ASBESTOS FIBER WAS RANKED 11TH. HOWEVER,/ UNDER CONSIDERABLE PRESSURE FROM THE AFL-CIO, THE SECRETARY OF LABOR ISSUED AN EMERGENCY/1 TEMPORARY STANDARD FOR 3 ASBESTOS ON DECEMBER 7, 1971. THIS LOWERED THE INITIAL OSHA STANDARD OF 12 FIBERS PER CUBIC CENTIMETER/TO 5 FIBERS PER CC. THIS ACTION BY THE SECRETARy/sET INTO MOTION 1. HIS REQUEST TO NIOSH FOR A CRITERIA DOCUMENT, 2. THE APPOINTMENT OF AN ADVISORY COMMITTEE TO REVIEW ALL RECOMMENDATIONS, 3. THE SETTING OF DATES FOR PUBLIC HEARINGS/ AND FINALLY THE PROMULGATION OF A PERMANENT STANDARD''WITHIN 6 MONTHS./ IN DEVELOPING THE ASBESTOS CRITERIA DOCUMENt/thE NIOSH STAFF REVIEWED THE FINDINGS OF THEIR 8 YEAR STUDY OF THE ASBESTOS JINDUSTRY. (IN WHICH WE HAD COOPERATED VOLUNTARILY) THEY SEARCHED THE WORLD SCIENTIFIC LITERATURE,/ AND CONSULTED WITH A SMALL AD HOC ADVISORY COMMITTEE/WHICH INCLUDED OUR MEDICAL CONSULTANT, DR. GEORGE WRIGHT. ON OUR INITIATIVE SEVERAL OF US MET WITH DR. KEY,/ THE DIRECTOR OF NIOSH,/ 7/ TO PROVIDE SOME INDUSTRY INPUT. THE STORY IS MUCH LONGER THA# THIs/aND MANY MORE J-M PEOPLE WERE DEEPLY INVOLVED/ BUT IN OUR OPINION,/ THE NIOSH CRITERIA DOCUMENT, SUBMITTED TO THE SECRETARY OF LABOr/waS NOT REASONABLE,/PRACTICAL,' SOUNDLY BASED'NOR TO OUR LIKING. NEITHER WERE THE RECOMMENDATIONS OF THE SECRETARY OF LABOR'S ADVISORY COMMITTEE/WHICH WAS APPOINTED TO REVIEW THE NIOSH CRITERIA DOCUMENT. 4 SUBSTANTIAL J-M AND INDUSTRY INPUT WAS DEVELOPED,'' PRESENTED/' AND WRITTEN INTO THE RECORD/* AT THE PUBLIC HEARINGS CONDUCTED j BY THE DEPT. OF LABOR/IN WASHINGTON, IN MARCH. /_ THE CREDIT LIST OF THOSE J-M'ERS WHO SPENT HOURS, DAYS AND i/sr i EVEN WEEKS IN THESE EFFORTS IS TOO LONG TO READ HERE/BUT IT of ft / INCLUDED SEVEKALi CORPORATE VP'S/AND MANY OTHER MANAGEMENT PERSONNEL. SLIDE 9 - ON THE ACT REQUIRES THAT ALL STANDARDS NEWLY DEVELOPED BY OSHA^ WILL PRESCRIBE: LABELS THAT WARN EMPLOYEES OF ALL HAZARDS/ PROTECTIVE EQUIPMENT AND PRECAUTIONS FOR SAFE USE/J METHODS AND INTERVALS FOR MEASURING AND RECORDING EMPLOYEE EXPOSURE / TYPE AND FREQUENCY OF MEDICAL EXAMINATIONS AND TESTS ON JUNE 7TH./tHE SECRETARY OF LABOR PROMULGATED THE FIRST OSHA DEVELOPED STANDARD - THE PERMANENT STANDARD FOR ASBESTOS FIBER j- WHICH INCLUDED ALL OF THESE FACTORS. SLIDE 9 - OFF 5 SLIDE 10 - ON EFFECTIVE JULY 7, THE THRESHOLD LIMIT VALUE FOR ASBESTOS/iS 5 FIBERS PER CUBIC CENTIMETER FOR AN 8 HOUR TIME WEIGHTED AVERAGE/WITH A CEILING LIMITATION OF 10 FIBERS PER CC. 'l'" ON JULY 1, 1976, THE TLV IS^2 FIBERS PER CC - AN 8 HOUR TIME . WEIGHTED AVERAGEjWITH A CEILING OF 1U FIBERS PER CC. THERE ARE SPECIFIC STANDARDS AND REQUIREMENTs/sPELLED OUT IN DETAIL/1 FOR: ~ EXHAUST VENTILATION/ RESPIRATORY EQUIPMENT AND PROTECTIVE CLOTHING/ LABELS AND WARNING SIGNS '' ENVIRONMENTAL MONITORING AND RECORDS/ MEDICAL EXAMINATIONS,/ TESTS AND RECORDS/ EMPLOYEE NOTIFICATION AND ACCESS TO RECORDS/' AT A RECENT WASHINGTON MEETING WITH OSHA STANDARDS AND COMPLIANCE MANAGEMENT PERSONNEL,/WE OBTAINED VERBAL APPROVAL/to USE OUR PRESENT INVENTORY OF J-M LABELLED CONTAINERS AND BAGS,/BEFORE CHANGING TO THE NEW LABEL REQUIRED/AS WELL AS CONCURRANCE ON OUR i INTERPRETATION^OF SEVERAL OF THE REQUIREMENTS - SLIDE 10 - OFF 6 OTHER CRITERIA DOCUMENTS/'ALREADY IN PREPARATION WILL HAVE T /.-' of /L''oc//. f SUBSTANTIAL IMPACT ON OUR^OPERATIONS, AS--WBLL, THESE WILL BE READY FOR THE SECRETARY OF LABOR TO REVIEW/WITHIN THE NEXT 6 TO 12 MONTHS. AMONG THESE ARE HEAT STRESS,/ NOISE,/SILICA,/ LEAD,j TOLUOL AND FIBER GLASS. FROM OUR ASBESTOS STANDARD EXPERIENCE,/IT IS OBVIOUS THAT THE TIME AND TALENTS OF MANY ARE ESSENTIAL TO THE PROTECTION /,S`d /'W / , OF OUR INTERESTS/THROUGH THE DEVELOPMENT OF VALID,/ PRACTICAL OSHA STANDARDS. IN ADDITION TO UsM MANAGEMENT'S RESPONSIBILITY TO IMPLEMENT THE ALREADY ESTABLISHED OSHA STANDARDS/WITHIN THEIR ORGANIZATION, EACH OF US HAS, AS WELL/ THE RESPONSIBILITY TO DO WHATEVER IS NEEDED /TO INSURE THAT OUR BUSINESSES ARE NOT CRIPPLED/BY UNWARRANTED,/ ILL-FOUNDED.' OSHA STANDARDS AND REQUIREMENTS. v IL. IN THE INFORMATION MANUALS FURNISHED TO YOu/WE HAVE INCLUDED OUR INTERNAL J-M "OSHA LETTERS" ~ #8 AND #9. THEY INCORPORATE OUR / rtu / INTERPRETATIONS'7 OFA SPECIFIC ASBESTOS STANDARD REQUIREMENTS,/ ' > M-1---r>'-c AS WELL AS J-M POLICY./ TIIEY/.M5GHT"BE~USEFUL 'TO YOU 'AS 'A REFERENCE". THE RESPONSIBILITY FOR THE CORPORATE ADMINISTRATION,OF OSHA COMPLIANCE/IS WITHIN MY OFFICE. WE USE THIS FORM OF COMMUNICATION t TO ADVISE ALL CORPORATE AND DIVISION MANAGEMENT OF THE CURRENT AND DETAILED OSHA REQUIREMENTS. ;'/f 7'**r T~/t s 7 T t'r > C r, iip i. f.t r / r ' V'v { ' . r r ' ' -7 f` A ` ^ x-r r.i //-t / S' >' P't'tn DHQ - Asbestos Fiber Sales August 15, 1972 /" ~L N. W. Hendry cc: W. L. Vanderbeek J. R. Hutchenson F. J. Solon, Jr. H. B. Moreno C. L. Stake E. M. Fenner H. Jackson BENDIX CORPORATION SOUTHFIELD, MICHIGAN ASBESTOS HEALTH SEMINAR 3/8/72 . A seminar on Asbestos Health was held at the Executive Offices of the subject company on the above date. The format is attached, as is the list of Bendix attendees. This presentation can form the basis for future J-M presentations on A/H as well as for the A.I.A. regional seminars now being planned. Our presentation was very well received, and from the Chief Operating Officer on down, all Bendix personnel expressed their appreciation and acknowledged that the information presented is of considerable help to them. During our visit we had an opportunity to hold meetings with B.B. Burton, J. Armstrong, H. Stolar and C. Menz. These occurred at dinner, breakfast, and lunch as well as immediately before and after the seminar. Questions were as follows: 1. Cost per employee to meet QSHA TVL Requirements al of 5 fiber/cc (.Arthur D. Little Study estimate $1,600/employee bj of 2 fibers/cc (estimate $2,800/employee) 2. Accuracy of Tests for fiber content in air (our answer + 20-25% at TLV of 5) 3. How is brake lining dust disposed of (Resulted in general discussion covering pelletizing, land fill, etc.). 4. Questions by Heitman to Dr. Wright during presentation were answered by Wright's total presentation. An example was risk on grinding linings in garages. 2. Answer: Do not flow dust off brakes. Use vacuum. 5. Any time limit an employee can be on a job that is hazardous and do we rotate people on such jobs. Answer: No, we correct the problem so that the hazard is controlled. 6. Can technological approach work in controlling problems? Answer: We do the following a. reduce forming and finishing by technical changes. b. educate personnel to reduce costs and work better c. work towards least expensive solution. Ex use of wet or damp resin mix. 7. Have we been cited by OSHA. % Answer: Yes . 8. How do wc handle OSHA Requirement to notify individual employees of stations that are hazardous? Answer: Cl) Post on bulletin board results of station surveys that are over limit, C2! advise what is being done to correct.9 10 9. Any value in taking your own dust counts side by side with OSHA Inspector? Answer: We try to take simultaneous samples. 10. Does #9 help in getting more cooperation from OSHA? Answer: We really can't tell any difference. Bendix has tried this and where it was done no citations so far from OSHA. 3 XI. General questions on air samplers and pumps. a. how many do we Have Answer: 100 b. Cost Answer: $15Q/pump (note we do have some Bendix pumps} $ 50/charger 12. How do you secure Industrial hygenists, what type of man and how much training. Answer: (1} Secure man with 2 yr. college or college grad. (4 yrs.]. Train in house. Takes 6 months for man to become fully operative. 13. How many do you have. ` Answer: 20 full time 14. If glass fiber lodges in lung, what damage. Answer: a. glass has almost no effect vs. asbestos b. However, there is some evidence that very thin glass (micro-fibers) can cause a problem. Still under investigation. c. some coatings have been found to render glass inert In the lung. d. if we could determine the method of coating1 particles or fiber similar to the natural method in the lung (by iron & protein) problem would be solved. Work going on in an attempt to do this. PVNP (Polyvinyl N Pyridene) works on some silicates and quartz). On quartz PVNP destroys free bond present on quartz surface. 15. With advent of OSHA have we found any marked increase in compensation claims. Answer: No great increase 16. How do you comply with, requirements 'on including employees in Environmental Control Committees. Answer: We've done this for years in our employee safety committees - just changed the group's name. This is an excellent employee communication media. I discussed the possibility of our securing business at the Cleveland Plant with Harry Stolar and Charlie Menz. They were encouraging and I will pursue it through our contacts. I talked with Bob Burton on August 13 and discussed it with him. He said there was some discussion at the top level on this. I expect our visit will pay dividends. Will keep you informed. 1 2 3 Attachments: 1. Attendees From the Bendix Corporation 2. Agenda 3. Health Aspects of Exposure by Inhalation of Asbestos Fiber