Document G5QEGoJgvvdgm2JkYb657YML4

(conoco) Interoffice Communication T Bjorn Arvesan, Ccnoco Norway f'0" Dr. C. acythome, Lcrdcn =" 7 June 1982 NPD's HEAMJG DRATT KB CDIDELEffiS CN ASBESTOS AND PSCOUCTS cnnxaroiG asbestos_________________ Thank you for forwarding me a copy of the above. Overall I find the proposed asbestos guideline* acceptable la concept, however there are one ae two area* which require clarification and/or e^atslai by NTO and these are detailed. atceotiena to the ban P.7, para 1. "Asbestos (hall always be replaced by products that are not a health hazard when poMible*. Doae this imply renewing all existing asbestos than an alternative exists? or only wbm herviae of operational rey.il rerents it will be disturbed? If the footer applies than the acmail df aebeatce releaead to the atmosphere, deapite precautions, will ba far In excess of tbs latter with consequent lnqsaas in health risk, is. unriletmljed asbestos provided it is known about and suitably marked Is not a health risk. Safa Handling ?-8- pare 5 Ihvder precautions it states "as far aa technically possible the work processes shall taka plaos la closed systons*. Pxaaunebly this means handling snail ebjacta thidh require mediining etc in i cctracted trade system, and alia screening off larger week areas there aefaeatoe is being handled and limiting entry to dices suitably protected. rational Protective Eoulaent P.9 No mention is mads of dsanslng reusable equlpmant cr dlyral of filters, etc. Ooaipatlcnal Hygiene Seen P-11, pars 1 Z would suggest adding ths words - aa far as Is practicable (cr possible) to this paragraph. (CON-IMt .../cent'd , DOP 0933896 DU 036447 |, ccrtt'd/. P.ll. aara 2 -2- ?*iks about 4 threshold Unit having stated in pare 1 no totally safe Unit can be established. Para 2 therefore seams to be at variance and than proceeds to halve the existing Unit presumably oi an arbitrary basis I would have anticipated that whenever there Is the poesibillty of asbestos being released through a work process into an oiployee's breathing ze, then he wear respiratory,and If required/other protection. Consequently actual expceure will be as near zero aa is possible. Additionally, measures should also be adopted to mjLnlnlae dust creation. If the above acticre were met, and Indeed they are all ocntainai in the guldellnee, then the reduction of limits trot 2 to 1 fibxVml is oily a paper exercise. Preventative Medical Measures and Samnatlme 14, Sectlm - BaaulrsBents for Medical Sandnatiai. pare 1 There it sane question as to who is to be examined. My aiderstanding would be thet if the guidelines were followed then only thcee handling' or working with asbestos in situatiena likely to exeats atmosphere centaninatiai would be potentially exposed. If this is not the case, then defining those vfco "might" be xgesei is very difficult nnglng iron the whole workforce to enly those handling it or Indeed ixxia of the workfaroe since with protection, in theory at least, no-ons is exposed. Section - Sooce of Bcandnetlcn leeks e previous occupational history and family medical history (unless latter Included in the first item of 'tills section}. As I stated at the cutest, I have no reel problem with the Guidelines. However, I feel thet mleae the above palate are clarifiei than we could be faced with amnglng unnecessary medical eninetm and also - "fear" associated with being oc. Dr. E.Ii. DeHiitt csy^ oof 0933891 X>\j 036448