Document G6v4YQgozdBao9vdwreLO5OMx

FROM J J. SHDCKEY SAFETY & IND. HYGIENE MANAGER POINT OCMFCRT OPERATIONS 1988 April 13 eupr 18 TO MS. L. RIPFEY PITTSBURGH - 06 Info oc: Mr. J. L. Palmer Mr. L. Flares Mr. J. Quaglia Mr. K. Keller Mr. B. F. Elliott Mr. J. Damiano - Pittsburgh RE: ASBESTOS STANDARD ~ OCUKT MANDATED RECONSIDERATION In a recent letter, you indicated that the ORC (Organization Resources Counselors) was looking for feedback on the decisions of the recent u.S. court of Appeals ruling. I have these comments for you to include: Reconsideration of the vise of supplied air (i.e,., air line respirators) or self-contained breathing apparatus exclusively for asbestos work is ludicrous. Asbestos work is not always confined to schools and public buildings. The potential hazards of asbestos (as it is currently handled) when compared with that of an employee attempting to crawl through a octiplex pipe rack thirty (30) ft in the air complete with lifelines, tools, and a 35 lb air pack with thirty (30) minutes of supplied air, is minimal. By requiring people to wear self-contained breathing apparatus (SCBA) OSHA will put greater physical demands cn asbestos workers, require even more capital equipment and additional respirator training, maintenance, and the like. The only SCBA equipment currently on hand at Fdint Comfort is reserved for fire fighting end emergency response. Air line respirators ere used at Point Comfort where work conditions permit or potential exposures are great enough to warrant the additional protection. Again, air drops ere not always readily available to every part of the plant or in every pipe rack. This requirement would also require acquisition of more air line hoods and several portable compressors. Air lines reduce flexibility in certain applications and may even encourage people to "cheat" for convenience in hard to access places. At Point Comfort Operations we've found that the powered air purifying respirator offers a very good combination of versatility and protection. We do not use any mechanical filter respirators for asbestos protection. The total number of people who would regularly use respiratory protection for asbestos work is approximately forty (40) persons; however, every general mechanic also has the potential to need to do so as well and that's about an additional two hundred (200) people. My recommendation to our Management would probably be to move from inhcuse removal to outside contractor if this new OSHA procedure requiring air line or SCBA respirators was enacted into law. This might be a point worth emphasizing since seme of the labor unions appear to be driving this E3 ALCOA *F'49) (ftCV !) Ms. L. Rippey Page 2 1988 April 13 issue in the courts. At some point it may even be worth discussing with the Steel Workers as I believe our folks at Point Comfort would like to keep this type of work and are comfortable with our current procedures and practices.