Document GXpL7QQ04NrV06GDmxx1m0Xx

'73 JIM 1 flfl 7 : 4 7 May 29, 1973 Personnel and Organization Stall Mr. J. A. Keller Personnel Services Supervisor General Services Division . ~ cc M. A. Karris, M.D. S. M. TjiIcp P. R. Veazey Subject: Asbestos Fiber Air Sampling * Arizona Proving Grounds The Department of Labor, under the authority of the Occupational Safety and Health Act of 1970 (06HA), in Section 1910.93a of the Federal Register dated October Id, 1972 has promulgated occupational health standards in relation to the use of asbestos and asbestos laden materials. In response to these standards, industrial hygiene studies were conducted on April 25-26, 1973, at the Arizona Proving Grounds to determine employe exposure to airborne asbestos fiber. Results of air samples taken and instrumentation used are attached. Employe exposure at the Arizona Proving Grounds to asbestos fiber emanate from brake rebuilding, pipe covering, and truck noise suppression testing. General plant ventilation is the only engineering control used for these operations. Approved 3M, No. 6J10, disposable respirators are used during mixing of asbestos mud for the truck noise suppression, but respirators are not worn during brake rebuilding or pipe covering. Pipe covering and insulation vork is a normal maintenance operation. The amount of pipe covering and insulation vork is minimal and on a sporadic basis. It should be noted, that management at the facility vas not avare of the industrial hygiene letter pertaining to proper procedures to be employed when using asbestos pipe covering or insulation. A copy of this letter is enclosed as part of the Plant Engineering letter attacned. The truck noise suppression project being conducted at the facility uses dry asbestos fibers to make mud which is applied to the truck engines that are then covered with fiberglas, sheet lead, and foil. The initial part of this project, which included covering the engines, vas Just being completed. The next phase of the project involves driving the trucks for several miles, and then removing coverings from various engine components to determine the relative contribution each engine component makes to the total noise level. During the removal phase of the project, asbestos fibers may become airborne and create a limited employe exposure varying in intensity with the method of removal. Brake rebuilding of disc and conventional brakes on cars and trucks is done as part of the brake testing program and as routine maintenance. There is no set pattern to the type of brakes and vehicles involved, or to the frequency of the rebuilds. The frequency of rebuilds during our visit was three per week, 8004 0968 SCF-FORD-1070 Mr. J." A. Keller May 29, 1973 Page 2 c but could go as high as 20 per week. Dust evolves from dropping wheels from the vehicle and bloving off brake assemblies and drums. The policy of this location Is not to permit blov offs, but employes find It necessary to blow off truck brake assemblies and drums. The provisions of the OSHA asbestos standard enumerated in Section 1910.93a of the Federal Register applicable to employe asbestos exposure at the Arizona Proving Grounds are: 1. A Queshold limit Value (TLV) of five fibers greater than five microns in length per milliliter of air, and a celling concentration of 10 fibers greater than five microns In length per ml of air. The TLV will be reduced effective July 1, 1976 to two fibers greater than five microns In length per milliliter of air. '_ 2. Local exhaust ventilation of tools and processes if airborne fiber concentra tions exceed the TLV or celling concentration. 3 Special work practices such as vet methods and isolation If airborne fiber concentrations exceed the TLV or celling concentration. 4. Approved respirators varying with the intensity of the exposure shall be C used when spraying, removing or demolishing equipment or structures covered with asbestos or asbestos laden materials. 3. Special clothing and change roams must be furnished employes exposed to asbestos concentrations exceeding the ceiling concentration limit. 6. Special clothing furnished must be collected in sealed containers and labeled per labeling specifications stated in subparagraph (11), page 22144, of the Federal Register. In addition, the laundry must be made aware of the asbestos hazard. 7> Air samples must be collected representative of employe breathing zone ex posure at Intervals no greater than every six months if the TLV or ceiling concentration limit may be expected to be exceeded. 6. If air samples indicate exposures greater then prescribed limits, then caution signs must be posted per pages 22143 and 22144 subparagraph g of the Federal Register and the area must be cordoned off. 9. Asbestos or asbestos waste materials must be cleaned by vacuum and disposed of in sealed containers and labeled per labeling specifications stated in subparagraph (ii), page 22144 of the Federal Register. 10. Employes exposed to concentrations of asbestos fiber exceeding prescribed limits must be notified in writing of the exposure and corrective action contemplated within five days of the finding. 8004 0969 Mr. J. A. Keller May 29, 1973 Page 3 V-' 11. 'Hie employer shall provide or make available medical examinations to employes vho may be exposed to concentrations exceeding prescribed limits. These examinations "hjtJi include a pre-employment, annual and termination examination consisting of posterior-anterior 14 x 17 Inches chest roentgenogram and pulmonary function test3 to Include forced vital capacity JVC and forced expiratory volume at one second FEV. in addition, a history to previous exposure to carcinogens and smoking should be obtained. Results of the air samples taken during our studies Indicated an overexposure to the ten fibers greater than five microns in length per ml of air ceiling concen tration limit prescribed by QSEA. This air sample was taken during blov off of truck brake drums and assemblies. The time weighted average exposure of this employe, vho vas performing brake rebuilding on trucks, vas also significantly greater than employes performing brake rebuilding on passenger vehicles. The mitigating factor is blov offs are not performed during passenger vehicle brake rebuilding. The available literature pertaining to asbestos fiber exposure an-M ng brake rebuilding, concludes that asbestos fiber exposure is minimal vfaen blov offs are prohibited or limited. Based on the results of our studies, it la our opinion that the following measures are required to comply with OSHA standards and to protect employe health. O 1. All blov offs of brake drums 'and assemblies should be strictly prohibited. A revlev of current literature indicates that vacuuming vith a brush attachment is a suitable alternative from the standpoint of dust and fiber control and does not materially hinder the brake rebuilding operation. If a portable vacuum is used, a high efficiency filter should be employed on tbe air discharge. 2. All waste materials which may contain asbestos should be cleaned up by vacuum and disposed of in properly labeled sealed containers. 3. The employe vho vas found to be exposed to asbestos fiber concentrations in excess of the celling concentration limit prescribed by OSHA should be notified In writing as stated la Mr. P. E. Toth's letter of May 16, 1973* 4. Employes whose job description Includes brake rebuilding on heavy trucks should, be given an Immediate medical examination meeting the requirements specified by OSHA. 5. Until a substitute is found for the blov off procedure performed during truck brake rebuilding, respirators approved under schedule 21 and special clothing specified by OSHA should be vom by employes performing truck broke rebuilding. Other procedures prescribed by OSHA relative to special clothing must also be followed. 6. The single use respirator used during asbestos mud mixing for the truck noise suppression program should also be used when removing asbestos from engine components which have completed testing. 800* 0970 E2T Mr. J. A. Keller May 29, 1973 Page 4 7* Until a substitute la found for the blov off procedure performed during truck brake rebuilding, caution signs oust be posted as specified by CSHA and the work area of the truck must be cordoned off. 8. Plant Engineering Letter No. 28, dated April 11, 1973, which contains industrial hygiene standard handling procedures for the use of asbestos pipe covering and insulation, should be implemented Immediately. Follow-up monitoring will be conducted during October 1973 to comply vlth the periodic air sampling requirements of OSEA. Industrial Hygienist Industrial Hygiene Section Employe Health Services Department ms Attachments (3) ' 8004 0971 A rizona P roving Grounds d Lim it c tlv e J' Lim it ling - c B.Z. Ling - d B.Z. - C alculated time weighted average concentration ri & <0 3 2.2s r\ *3 u O O lf\ 3+-44 sa iq ^ a +> -t ir\ cvi o g Q\ o n i ooo CU H H H i oooo Xt^ *Sfli 3 gH u 1 2 VOi 3 1 1. . 1 g .5 2a <9 | , ga O 2 i* I sU Ot * 5 =&4h 2a* :>o |2 wM I** Ha 2 a dS a>> a>i 35 0Sa# 0Ba4 ii .rQCU5VHS Vgs. W > BM--6Ht0 o M: Jah n>-*' &a o Ha s |+0aa0>/ s s c& 59 a to 23 1 a, < * g s o 8* = <OOH0 tt 6S0 s3 . 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SP 1 <2 B * 4> H 3 OS S aa 5 2 3 3 3 S3 t&o S* Ie a > i! >k -o eH 8 CO o&o SH o iaHt,s<h9 CO Eo s sp> fpct 4J 53 i 4d 6 3 22 Vuj Sm co 5* 8004 0973 TO: Plant Engineers, All Plants Division Plant Engineers Plant Managers General Manufacturing Managers , LETTER NO. 28 April 11 1973 CONTENTS SECTION A: GENERAL INSTRUCTION? AND INFORMATION No Subjects Included SECTION B: MAINTENANCE INFORM/TION Asbestos Pipe Covering and Insulation Standard Handling Proccdu Industrial Truck Maintenan Control System Fire Loss Analysis 1972 SECTION C: ENGINEERING AND CONSTRUCTION No Subjects Included Page. M-201 M-202 Complete R. F. B|rdsall, Manager Maintenance Department Plant Engineering Office 8004 0974 i n PLANT ENGINEERING LETTER NO. 28 April 11, 1973 ASOESTOS PIPE COVERING AND INSULAjtON - STANDARD HANDLING PROCEDURES The Federal Department of Labor under the authority of the Occupational Safety and Health Act of 1970 (OSHA) haa promulgated specific standards for the use of asbestos. Pipo covering and insulation materials may c^imain asbestos, particularly in older Installations, Plants considering new pipe covering and insula tion projects should investigate other non-asbestos materials such as calcium silicate and fiberglass. The attached letter recommends procedures to be followed in plants using asbestos pipe covering and insulation to avoid potential health hazard to employes and to be In compliance with OSHA regulation! f, Attachment >j M 201 8004 0975