Document G61MLJM802Va8onDXyvjZeZEq

* o-o GEO^G!A-PAC3FSC interdepartmental communication TO* FROM: Mr. E. B. Hollingsworth j. D. Rauch SUBJECTi O.S.H.A. Citation of June 13. 1973 DATE: July 9, 1973 LOCATION: Wilmington LOCATION: Akron On July 5, 1973, Mr. R. G. Tuttle and I had an informal conference in the office of Mr. Alfred Barden, Assistant Regional Director, O.S.H.A. This conference was held at our request to gain a proper understanding of the abatement procedures of the various citations, and to request a reduction or removal of the various proposed penalty assesments. This informal meeting was rather lengthy, from 9:00 A.M. to nearly 3:30 P.M. and was concluded with some degree of success. Those in the conference for O.S.H.A. were: Mr. Barden, Assistant Regional Director: Mr. John Kearney, Technical Support Director; Mr. Harold Pauly, O.S.H.A. Inspector from the Syracuse office. Each citation was discussed at length and ended with our formal written request for a 30 day extension on all citations and a request that serious violations i/2 and it3 be reduced to non-serious violations with the proposed penalties being changed from $1600.00 to $180.00 on these two violations. In a formal reply, Mr. Barden agreeded to our requests and will re issue a revised citation indicating these changes. Our total proposed penalty will now be $1340.00 from the original total of $2760.00. We should issue a check in the amount of $1340.00 to Mr. Barden's office as our first step in this matter. We have agreed to the completion of following by July 31, 1973. I. Estja^Tish a complete respirator program which will include: Instruct all employees in the proper use and care yof approved respirators. This Instruction to be v/ given by a qualified instructor/' tSf\ Provide individual lockers for storage of respirators for each employee. Provide a regular inspection program to check on condition of respirators In use and replace any found defective, worn, or in an unsanitary condition. D. Have assurance that all employees are using respirators where required with an established and working enforcement program. II. Establish a program for maintaining the area in clean, orderly and san^tpr^y condition as follows: /4\. Clean the inside area of accumulation of dust from tank tops, support beams, walls, etc. where asbestos dust may fall through the air at a later date. SGP 0007017 _1_ IS Install portable dust collection on the bag packer y/ to reduce asbestos contamination in the air.--- w\ Remove the portable fan rr^mi the bag packer. X D. Replace our present air-flow bag packer with .a non ' pressure type bag packer. /fp Enclose the bag slitter area to increase the effectiveness . , of the present dust collection system. JrS Use plastic bags with proper warning lables to dispose of all waste asbestos. IIIyO*rovide employees with protective clothing that provide total 1 / to toe protection. ' yt'l. We must provide a single change room with individual lockers, one for the provided work clothes and one for their street clothes. We must either provide disposable clothing or have provisions for their cleaning on a regular basis. jn Enforce the use of protective clothing by all who eater / the area. Iy\ Establish a personal monitoring program of all employees to determine ! exposure. To be at a minimum of 6 month intervals. Further we must have medical check-up on all area jT employees including full X-rays and respiratory^/ tests. To be at a minimum of 12 month intervals. X Provide, by July 27,1973, a plan and time table for installation of engineering controls to prevent employee exposure to asbestos dust. We have completed all of the other requirements as outlined in the O.S.i-i.A. Multi-Step Abatement Proceedurcs, such as: 1. Provide all employees tvith approved respirators. 2. Post caution signs at all approaches to the area. 3. Affix caution labels on all products. There is still a ceos'cioa regarding labels for Heady Mix. Mr. Tuttle is to cupiore this further in Portland. Mr. Barden suggested that this product should have she caution label to warn the user of the asbestos content so proper protective steps can be taken before the start of the sanding operation. In order to keep the agreement wit:; Mr. Barden and his staff we plan t..o following: 1. We have provided all effected employee's with U.S. Bureau o. Mines approved respirators designed for use in asbestos dust. We will have no unapproved available. 2. All effected employee's will be informed that constant use of these approved respirators will be a condition of employment in the Joint System manufacturing area. 3. Provide proper use ar.d care of the approved respirators through a represenative from our respirator supplier, SGP 0007018 3. Con't. Our Plant Safety Supervisor will qualify himself so he can provide future instruction as required. 4. We will provide small, individual, dust tight lockers for each employee to use as respirator storage when they are off shift. 5. We will start a regular respirator inspection program and keep a record of each employees respirator condition/-'' All of the above will be accomplished with no great expense or production delays. We have set the date of 7-20-73 to complete 1 through 5. 6. We have completed the total enclosure of the bag slitter area as suggested by Mr. George Truner. This has caused considerable complaint from the employee's working in the area. There is no doubt that it has made their regular work more difficult but should have no effect on production. This enclosure was completed at minimum expense. The enclosure was constructed with ply wood. This enclosure u3s completed on Sunday, 7-3-73. Final work had to be accomplished when the production employees were not working. 7. We must clean the inside area of dust accumulation. Due to the height of the open area we will have to sat up scaffolds to do this vork. This will be an operation that will have to be accomplished when production is curtailed. We believe this will take at least two full days work. At this time wc plan to start the celan-up work on 7-21-73 and hope to finish it on 7-22-73. If tac job cannot be completed in two cny3 we will have th following week-end to complete the work before the 7-30-73 deadline. This will be an expensive abatement procecdure as we will have several men working on clean-up with no production possible in the department--- 8. We will install a portable dust collection unit on the bag--' packer. Daring our masting with Mr. 3ardcn I was ashed if our present dust collection system could be improved to reduce the dust condition. I stated that I knew of no method that would be effective. Mr. Barden then suggested that we purchase an Industrial vaccum sweeper and ha%'c a flexable hose from the sweeper installed over each filling tube. I stated that if was my belief that this would be ineffective. At this point Mr. Barden insisted that this method be followed. We agreed to the method and will place an order for the vaccum ana required flexable ho3e on 7-10-73 and complete installation as soon as it is received. There should be no problem in meeting the 7-30-7J deadline as this Is a normal stock item. Completion costs should be less than $300.00. 9. Photos taken by Inspector Pauly on his February 1973 inspection shew a large floor fan running to blow bag packer dust away from the operator. It was pointed out that this fan also blows dust over large areas of the SGP 0007019 9. Con't building. We were ordered to remove this fan. This was completed on 7-9-73. Since this fan also provided a cooling effect on the Pecker Operator, we met with some employee dissatisfaction. 10. We have been discussing replacement of the air-flow has packer with a screw feed type packer with Mr. DiLore.iXo and George Turner. When a packer is located it will require some piar.t down tine to install and will no doubt add considerable expense to our total abatement procedure. At this tine I can provide no time schedule regarding completion time. I would suggest that we cannot complete this change by 7-30-73 and will have to request additional time from Mr. 3arden. However, I would hope at the same time I can provide proof, such as a purchase order, to prove the packer is on order but undelivered. 11. We will provide plastic bags or plastic wraps for all of our waste by_ 7-2G-73. This wrapped waste will be disposed of by moving to the mine or dumped at the plant as fill and covered with soil. 12. We will provide our employees with whole body covering protective clothing. I cannot provide a completion date at this time as we have not located a supplier. This clothing will be provided for all hourly employees, (16 men), the Department Supervisor, (1 man), the quality control employees (3 men), maintenance workers, (3 men minm.), the truck driver that removes the waste, (1 man), the Plant Safety Supervisor, (i man), clothing for myself and possible visitors such as the O.S.H.A. Inspectors, (3 men minm.). Thi3 makes a total of at least 28 sets of clothing. Approx. 20 sets will have to be changed twice each week to meet the requirements that they be maintained in a reliable and sanitary condition. I will report on the cost as soon as possible. I would expect this to be an expensive abatement that will continue until asbestos is removed from all cf our products. 13. We will provide a change room with two individual lockers for each employee. In addition this room will contain tka small respirator leaker discussed under item 4 above. At this time wc plan to move in a small, portable building we have available and outfit it to meet these requirements. Work will start on this during the current weak. Completion is expected well ahead of the 7-30-73 deadline. This will be effective during the summer and fall season. If total asbestos removal from our product line is going to extend into the winter we will have to provide a different charge room. Our present solution will not be a satisfactory change room during cold weather. Again, use of the provided clothing will be made a condition of employment in the department. SGP 0007020 14. We have established a personal monitoring program at this time. This was arranged on 6-16-73. However our meeting indicated that our program is not as complete as O.S.H.A. requires. We will make the necessary arrangements to have a complete check made before the 7-30-73 deadline. However, it appears that analysis of the monitoring tests will not be completed by 7-30-73. I do not think this 3 as important as getting the monitoring program underway. The O.S.ii.A. people indicated that they were aware of the time factor involved in the test analysis. 15. Our medical program must be updated and more comprehensive than in the past. This will require some time off at our expense for each employee and a total cost of about $60.00 each for 16 employees, or a total of $960.00. This will be a continuing cost each year as long as asbestos is used in our product. 16. By 7-27-73 submit a plan and time table for installation of engineering controls to prevent employee exposure to asbestos dust. Mr. DiLorenzo has assured us that this will present no problem. lie and George Turner are to be in Akron on 7-17-73 to go over final details before submitting these plans and timetable. This is a rather extensive plan and requires a considerable amount of work and expense between now and 7-30-73. Mr. Tuttle and I felt that we had to agree to all of the above in order to prevent a serious penalty problem with O.S.H.A. It must be remembered that the abatement time in the orignial citation had already passed when we were having our meeting on 7-5-73. Regular progress reports will follow and a complete report will be due for Mr. Barden on 7-30-73. I cannot stress the position of our other Joint System operations too strongly. It was pointed out very clearly to Mr. Tuttle and myself that the other operations fall under all of the same conditions as the Akron Plant and that good faith allowances would not be allowed at other locations. This would mean much higher fines and no extensions allowed for work completion. I think as a minimum, a written timetable for compliance should be established for the other operations to shq,w progress. It could also be very helpful if Mr. Lehnert could keep each of us posted regarding an asbestos removal timetable. All of these items can prove very helpful to other locations that find themselves in our position. Being able to show letters with past dates were very helpful during our meeting. k SGP 0007021 i