Document GmnGGjXv4QN7GMMzzaENMV2jN

frjp] Organization Resources * Gounsebi^hc March 31, 1988 yjiORC. National Place, Suite 911 1331 Pennsylvania Avenue, N.W. Washington, D.C. 20004 202-737-6330 fiEC'O APR l l 1988 Memorandum PLAINTIFF'S EXHIBIT AL-929 To: ORC Occupational Safety and Health Group ORC Asbestos Task Force ORC Respirator Task Force From Darrell K. Mattheis and Rebecca L. Daiss Subject: D.C. Appeals Court Decision Regarding Respirator Requirements in the Asbestos Standard (CFR 1926) In its February 2 ruling, the D.C. Court of Appeals told OSHA that it must reconsider requiring the use of supplied air respir ators to achieve levels lower than the Permissible Exposure Limit (PEL) set for Asbestos. As a consequence of this ruling, it is possible that OSHA may revise the Asbestos Standard to require that Self Contained Breathing Apparatus (SCBA) or other Supplied Air Respirators (SARs) be used in every instance (i.e., prohibit the use of negative pressure respirators). The ORC Asbestos Task Force believes strongly that the increased cost and the increased risk of compliance with such a provision cannot be justified. The group decided to compile information to support this position and submit it in comments to both OSHA and OMB. ORC is, therefore, requesting that companies, which may be af fected by such a revision of the respirator provisions, send us information on the following: 1. The cost of equipping employees with Atmosphere-Supplying Respirators (SCBAs and Airline Respirators) to replace nega tive pressure respirators currently being used; 2. Cost of training employees in the use of Atmosphere-Supply ing Respirators; 3. Cost of storage and maintenance of additional AtmosphereSupplying Respirators; -2- The attached form has been provided for ease of entry and com pilation of data. Please complete the form as accurately-as possible'and return it to ORC. We believe that it is^in dn-" dustry's best interest to provide OSHA and OMB with data on1 >the probable consequences of allowing only the use of supplied*iir respirators. ^ We would like to recieve the completed questionnaire by the end of May, 1988. BD/3A Q I -O mA i i *4 4 \ :! ' i-4 `v $ :k i Please return to Rebecca L. Dalss Organization Resources Counselors, Inc. National Place, North Lobby - Suite 911 1331 Pennsylvania Avenue, N.W. Washington, D.C. 20004 ORC 8UPPLIED AIR RESPIRATOR QUESTIONNAIRE The purpose of this questionnaire is to estimate the cost to industry of replacing all negative pressure respirators with Atmosphere-Supplying Respirators (SCBAs and/or airline respira tors) for work involving Asbestos. 1. Approximately how many Atmosphere-Supplying Respirators will your company need to purchase to replace all negative pres sure respirators currently being used for work involving Asbestos? (If unable to supply information on the entire company, identify type of unit for which you are providing information, e.g., a division within the corporation.) 2. What is the estimated cost of replacing negative pressure respirators with Atmosphere-Supplying Respirators for work involving Asbestos? (Number provided in question l, . times cost per respirator.) 3. What is the estimated additional cost of training workers, who had previously used negative pressure, in the use of Atmosphere-Supplying Respirators for work involving Asbestos? (For the unit identified in question 1.) 4. What is the estimated cost of storage and maintenance of additional Atmosphere-Supplying Respirators for work involv ing Asbestos? (For the unit identified in question 1.) 5. Any additional comments you wish to make: Organization Resources Counselors,Inc. i33i Pennsylvania Avenue, n.w. Washington, d.c. 20004