Document JngVn4XGeR9YgXGk7MDOk6EB

PLAINTIFF'S EXHIBIT AL-1296 FROM RICHARD A. MIUTO ENVIRONMENTAL HEALTH LABORATORY ALCOA TECHNICAL CENTER - C TO MEMORANDUM 1989*04-01 RE: INTERPRETATION OF 29CFR PARTS 1910 AND 1926, "OCCUPATIONAL EXPOSURE TO ASBESTOS. TREMOLITE. ANTHOPHYLUTE AND ACT1NOLITE" The purpose of this memorandum is to aid in the interpretation of the captioned asbestos regulation and its ambiguity of the terms tremolite, anthophyllite and actinolite as associ ated with the term `asbestos.' Because asbestos is defined as a family of naturally occuring fibrous mineral silicates/3) the inclusion of the terms tremolite, anthophyllite and actinolite with the term asbestos becomes a source of confusion. Some questions that come to mind are: 1. Is OSHA regulating both the fibrous and non-fibrous forms of the minerals tremolite, anthophyllite and actinolite? 2. Is OSHA excluding tremolite, anthophyllite and actinolite from the accepted definition of asbestos? 3. If the non-fibrous forms of tremolite, anthophyllite and actinolite are being regulated under 29CFR Parts 1910 and 1026, how can the sampling and analytical method recom mended (modified NIOSH 7400) in the regulation be justified? In order to clarify some of these questions I contacted Mr. John Martonik of OSHA's Health Standards Program. Mr. Martonik was extremely helpful and covered the following points from 29CFR Parts 1910 and 1926: 1. The naturally occurring fibrous forms of tremolite, anthophyllite and actinolite (although relatively rare) are still regulated under the conventional definition of asbestos. 2. Cleavage of non-fibrous mineral forms of tremolite, anthophyllite and actinolite resulting from physical processes such as grinding, mining, transfer, etc., are under regulation if such fragments fall under the definition of a fiber (>5 fjm in length with a length to width aspect ratio >3:1). 3. Use of the sampling and analysis methods, as outlined in the regulation, for 1 and 2 above. 0 ALCOA HQ 001427 SF-4S63 iREv *. 7, 4. There is, at present, a `stay' on the regulation of cleavage fragments as an occupational health risk. The standard presently being used is 29CFR1910,1001 (June 20,1986). 5. As a matter of note, OSHA has participated in sampling of airborne cleavage fragments during processing and analysis of the samples has never produced liber' concentrations greater than 0.1 f/cc. This observation was also made during sampling at a chrysotile (naturally occurring fiber) source. Although somewhat inconclusive it does support the rarity of airborne cleavage fragments in the atmosphere. In conclusion I would like to offer the following suggestions regarding interpretation of asbestos results: 1. `Asbestos' refers only to the fibrous forms of the six regulated minerals ~ there is no such thing as a `non-fibrous' asbestos. 2. Analysis of samples using X-ray diffraction (XRD) is not a valid determination of asbestos by itself since XRO cannot distinguish between fibrous and non-fibrous species. Visual ex amination of the sample for fibrous content prior to XRO analysis is, however, a valid ap proach to the assignment of 'asbestos' to the sample. Assumption of the presence of asbestos based on XRD analysis alone is not a responsible interpretation and can result in unwarranted concerns. At present we are awaiting the ruling by OSHA concerning 29CFR parts 1910 and 1926 concerning the 'stay'. If you have questions or comments, please contact me. Note (a) - McCrone, W.C., Asbestos Particle Atlas. p4, Ann Arbor Science, Ml, 1980. cc: C. F. DiMascio, Pittsburgh-6 J. Damiano, Pittsburgh-6 R. W. Barr, Pittsburgh-6 R. M. James, Pittsburgh-6 L L Rippey, Pittsburgh-6 S. Sinha, Pittsburgh-6 J. A^Shockey, Pittsburgh-6 R. S. Danchik D. R. Balya HQ 001428 SAMPLE LOG AND SAMPLE NOTES Sample Number Receiver's Initials Photo UKCKlPTWtTW SAMPLED MATERIAL------------------------------Number Inspectors' NameInspector's Firm Inspector's Signature Dates Samples Collected HQ 001429 Building Number and Name HOMOGENEOUS AREA REPORT Give this Sample Area a relevant name Sample Area Number and Name Locate this sample Area within the buildinq SAMPLING STRATEGY Ceiling Height +1 I I +2 | Square Feet of Ceiling Materials | SAMPLE ANALYSIS SUMMARY SECTION Total Number of Samples Collected Square Feet of Wall Materials Square Feet of Floor Surfaces | | Total Number of Samples Analyzed Square Feet of Structural Steel | Square Feet of Str. Steel Coatings | Square Feet of Other ACM | Total Square Feet of ACM in this Sample Space SALIENT CONDITION ASSESSMENT Date: Salient Description ACBM PRESENT? Suspected or Conf1rmed Mat. Type* Friable T DC PD * Refers to material type and damage categories T - Material As: T - Thermal Systems, S - Surfacing, M - Miscellaneous DC - Damage Condition: ND - No Damage, D - Damage, SD - Significant Damage PD - Potential Damage Categories: NPD - No Potential Damage, PD - Potential Damage PSD - Potential Significant Damage HQ 001430 HOMOGENEOUS AREA REPORT Building Number and Name____________ Give this Sample Area a relevant name Sample Area Number and Name Locate this sample Area within the building Sample Analysis Summary Section Total Number of Samplers Collected | | Average Percent Asbestos Content Total number of Samplers Analyzed I I Linear feet of duct or piping ACM in this Sample Area Square Feet of Equipment ACM in this Sample Area n Inches Diameter Linear Feet Tank-Boiler Inches Diameter Linear Feet Elbows or Valves '| Square Feet *| Square Feet Salient Description SALIENT CONDITION ASSESSMENT Date: ACBM PRESENT? Suspected or Confirmed Mat. Type* Friable T DC PD * Refers to material type and damage categories T - Material As: T - Thermal Systems, S - Surfacing, M - Miscellaneous DC - Damage Condition: NO-No Damage, D - Damage, SO - Significant Damage PD - Potential Damage Categories: NPD - No Potential Damage, PO - Potential Damage PSD - Potential Significant Damage HQ 001431 IDENTIFICATION Physical Daiage CDSignificant Damage Damage No Damage CD CD Hazard Assessment Factors Homogeneous Area . DAMAGE Water bamage Extensive f1 Moderate Slight CD Hone CD FACTORS ' Triable y CD .5------ .5=3 Sard Surface [ | Soft Surface f [ Deterioration Heavy Moderate Light Rone 1) l Il CD DISTURBANCE FACTOIW Proximity to repels Item* Less then 1 ft. --I 1 to 5 ft. I 1 More then 5 ft. ID Accessible t Within Reach p*} Barely Reach I Not Reachable t 1 I Texture Rough 1 Pitted 1 Moderate Textl Smooth 1 1 1 1 i Adjacent Rooms Gymnasium 1 "1 Music Room 1 1 Mechanical Room Elevators CD f~ i Barriers 'ermanent Enclosure Enclosured CD CD EEEEESEEEEs Ventilation Tea |-----| Air Movement High CD Air Conduits Air Plenum | ~ ' 1 Encapsulated 1 1 None CD Intake 1 I Exhaust i | Moderate 1 1 CD Air Shaft Elevator 1> CD GENERAL OCCUPANCY CHARACTERISTICS _______________ i SAMPLE AREA OCCUPANT GENERAL PUBLIC Record a description of the most important factors observed in this sample that may increase the likelihood of fiber release____________________ ___ Population Duration (No. of People) (Man-days/yr.) MAINTENANCE ONLY I--IHov many sqquare feet of ACM is never accessed by anyone? Demarcate such on the sample area sketch. Bow many square feet of ACM is routinely! 1 accessed only by maintenance personnel? Demarcate such on the sample area sketch. Explain any abnormal access features. ---------------------------------------------------------uonomon Aseei mcm______________ ACBM ?nf. TlimAffA Suspected Confirmed Friable X ID No damage SPD No. pot. D - Damage damage PD Potential D Significant damage * damage PSD Potential slgnif. damage HQ 001432 Document Humber B u ild in g Number and Name 309083 j au-pea zi 93-pma xz Bmo3ra oz mnad^o 6T aaqTd 9T39q3n^s 81 aanbvdo ii B3TH 91 uem 93TI0O93X SI K S 93TT0OP33V n 93TI^qdoq30V 1 *fo ft aaeporg n *3anl) 07 9003S9VP1 g 93Tin3TaA 8 5TTd L Toon *oth 9 mrSuqu S *TnIT0 9 3TIOPT9OJ0 93Teomy z IT3oaAxqo x 39qmn(i (n qn jaqang exdmag 1 -- i i H" -- i1 1 ! I i i 1 i un i \i t i! r f 1 i i . * | r' "1 i i ... i __ P oaitlvea .. . Count o f m > 00 2 ?s uo n > HQ 001433 r y/) M'. J ^7 / >--,------ -^$ 2. C4+**i -- **-? 4s*T'ffrcd,//'^ffe , 7/* Tpz >~'J -' /*^.t^VC^' /fs^cJ? i" X, 5*~p, ' *`^e~i{Lif/ s&ypZyp+&*L^ ] / /*>?* Lf &*+/(* ' /0 /?cjtS7 7Z*~~J>} flic - fin 2~fit24s6y - / # /itr*~iaie^t*i*?y*-j aAl-Si - A-ti&H. P^a4^C - Cfatf^y Acs7 ~eXe^c^JUcr^ - /^r^Xp /fj*~T/<s^e^ ^ -<!*> 6X&rryit+ii 'o -- > /^Ay eCtf* ^ 3-f /y^s*^7 Jcs*~~*i*<j,r t/ "F-. V' (sTP^l ~- Acr'<?~i y'*siy$%p $?/&*i%^> ^Jf^fj 24rl6r ^ 7^ - /A-j <,b J*~~j *U~*iA* jf%.JZS+yzS&-Aj' T/tJ~r**jP- t/fc 6 ft1" ,,/c** *_Jt---7'- a r*fp**&* c*v s>*y*v^ ^ yr 6-*'M+JA~r/ **/^ I * =- \ r^vn^l-C **4~ /y A/Vn - /?(* Atfwt /VK^-y> * ~~ I; foenfr**'}r*4jh~-r<,***. HQ 001434 i^LuS -1 i f> 1910 Sunderland Place. N \\ Wa-hiriRion, D C. 20036 202-293-2980 Fav 202-293-2915 ij=n Organization Resources is! Counselors, Inc December 7, 1989 Memorandum To: ORC Asbestos Task Force From: Rebecca L. Daiss Subject: Concern over "HazardousExposures" to Asbestos Resulting from Buffing Vinyl Floor Tiles! For your information, as a result of an investigative report exposing the "hazards" associated with buffing asbestos containing vinyl floor tiles, OSHA is anticipating a possible swell of criticism and questions regarding the adequacy of the asbestos standard and possibly pressure to lower the action level and the PEL. The report was aired on WRC, a local D.C. news station and NBC affiliate. According to the report, samples taken by government industrial hygienists showed "hazardous levels" of asbestos during buffing operations. The report made no reference to OSHA or to the levels established in the asbestos standard. The focus of the piece was not the workplace but schools and homes and the hazard to children was emphasized. We understand that the hazardous level referred to was the clearance level of .01 f/cc established in EPA's AHERA regulation and that the levels found were in the .05 to .08 f/cc range. Evidently, EPA has the data on which the report is based but has not made it available. EPA is putting together a fact sheet on the problem but does not plan to issue a press release at this point. If you have any floor tile buffing exposure data, please send it to either OSHA or ORC. OSHA wants the data to establish a defense against the claims regarding the inadequacy of the standard that may arise during remand hearings. Although it has not been confirmed, knowledgeable persons who watched the report said that the buffers being used were a highly abrasive type that is prohibited by floor tile manufactures and not used in normal buffing operations. OSHA expects data on normal buffing operations to show levels well below .01 f/cc. Merry Christmas! BD3 hQ 001435 Joe Damiano To: EXCELLENCE THROUGH QUALITY 1990 May 15 U.S. Industrial Hygiene Supervisors R. W. 5hRR RtTTSBURGH OPR ICE 001 RE; ASBESTOS For your information ... recent correspondence from Dean Belk to physicians. JOE DAMIANO /pdn Attachment ALCOA 1501 Alcoa Building Pittsburgh, Pennsylvania 15219 HQ 001436 FROM H. DEAN BELK, M.D. PITTSBURGH OFFICE - 6 TO MEMORANDUM April 25, 1990 RE: AMENDMENTS TO OSHA'S ASBESTOS STANDARD ANNOUNCED IN FEDERAL REGISTER OF FEBRUARY 05. 1990 (VOLUME 55. NO. 24) Effective May 07, 1990, there are several additional practices which must be implemented to assure full compliance with OSHA's recently amended Asbestos Standard. These are as follows: Ban smoking in work areas where any occupational exposure to asbestos exists. Augment asbestos training programs to include names, addresses, and telephone numbers of public health organizations which provide information, materials, and/or conduct programs for smoking cessation. Alternatively, we may distribute a list of such organizations to comply with this requirement. (See Attachment 1) Augment training programs to inform employees about the availability of self-help smoking cessation programs. Upon an employee's request we must provide a copy of such material. Example -- NIH Publication No. 89-1647, or equivalent. Augment training programs to inform employees about OSHA requirements for posting signs and affixing labels and about the meaning of the required signs and labels. Training must cover the location, posting, and contents of mandated labels and signs. Employees should be shown actual signs and labels and the content reviewed during training. During the required medical evaluation the physician must provide the following information and must certify for the record he has informed the employee: a. About the synergistic relationship between cigarette smoking and asbestos exposure in developing lung cancer; b. That cessation of smoking will reduce lung cancer risk; c. That he or she should stop smoking. (After the occupational medical exam for asbestos, we already are required to provide each employee with a letter setting forth medical findings and assessing the risk of developing asbestos disease. In addition to informing the employee verbally, I suggest modifying letters now being provided employees to include the above information about smoking.) HQ 001437 ALCOA <HSV 1 -> Memorandum April 25, 1990 Page 2 Attachment 2 is a package of information providing recommended procedures for medical surveillance following OSHA'S 1986 revision of the Asbestos Standard. The above recommendations supplement material in Attachment 2. H. DEAN BELK. M.D. HDB:bal (01890.hdb) Attachments Distribution: Edmund Gray, M.D., Addy Works David Stewart, M.D., Arkansas Operations Whitman Smith, M.D., Badin Works Anthony M. Puleo, M.D., Cleveland Works S. Louis Casta, M.D., Davenport Works James M. Pickerill, M.D., Lafayette Works William W. Klatchko, M.D., Lebanon Works Jean-Louis Murat, M.D., Massena Operations W. Kahle Johnson, M.D., New Kensington, ARL/ATC John F. Tomayko, M.D, Pittsburgh Office 15 Stanly Heckrodt, M.D., Point Comfort Operations Francis B. Warrick, M.D., Richmond Works W. Thomas Washam, M.D., Rockdale Works E. Stephen Ellis, M.D., Tennessee Operations Ralph M. Simonian, M.D., Vernon Works Thomas C. Burger, M.D., Warrick Operations Gerald E. Gibbons, M.D., Wenatchee Works cc: Joe Damiano, Pittsburgh 6 Bob James, Pittsburgh 6 Emma Pessolano King, Pittsburgh 6 HQ 001438 ATTACHMENT 1 The following organizations provide information on smoking cessation and related material for programs: 1. Office of Cancer Communications National Cancer Institute National Institutes of Health Building 31, Room 10A24 Bethesda, Maryland 20892 Telephone (toll-free) 1-800-422-6237 for the Cancer Information Service. Trained personnel will assist the caller. 2. American Cancer Society 3340 Peachtree Road, N.E. Atlanta, Georgia 30028 Telephone: 404/320-3333 The American Cancer Society (ACS) is a voluntary organization with local affiliates in 55 states and regions. A variety of publications and audiovisual materials is available. The ACS helps people learn about the health hazards of smoking and become successful ex-smokers. 3. American Heart Association 7320 Greenville Avenue Dallas, Texas 75231 Telephone: 214/730-5300 The American Heart Association (AHA) is a voluntary organization with 130,000 members (physicians, scientists, and laypersons) in 55 state and regional groups. AHA produces a variety of publications and audiovisual materials about the effects of smoking on the heart. AHA also has developed a guidebook for incorporating a weight-control component into smoking cessation programs. 4. American Lung Association 1740 Broadway New York, NY 10019 Telephone: 212/245-8000 A voluntary organization of 7500 members (physicians, nurses, and laypersons), the American Lung Association (ALA) conducts numerous public information programs about health effects of smoking. ALA has 59 state and 83 local units. The organization actively supports legislation and information campaigns for non-smokers' rights and provides help for smokers who want to quit, for example, through "Freedom From Smoking," a self-help smoking cessation program. HQ 001439 ATTACHMENT 1 Page 2 5. Office of Smoking and Health U.S. Department of Health and Human Services 5800 Fishers Lane Park Building, Room 110 Rockville, Maryland 20857 The Office of Smoking and Health (OSH) is the Department of Health and Human Services' lead agency in smoking control. OSH has sponsored distribution of publications on smoking-related topics such as free flyers on relapse after initial quitting, helping a friend or family member quit smoking, the health hazards of smoking, and the effects of parental smoking on teenagers. Spanish-speaking staff members are available during daytime hours to callers from the following areas: California, Florida, Georgia, Illinois, New Jersey (area code 201), New York, and Texas. Consult your local telephone directory for listings of local chapters. (01891.hdb) HQ 001440 ATTACHMENT 2 H. DEAN BELK, M.D. PITTSBURGH OFFICE - 6 TO MEMORANDUM June 23, 1987 RE: RECOMMENDED PROCEDURES FOR MEDICAL SURVEILLANCE OF EMPLOYEES EXPOSED AT OR ABOVE THE ACTION LEVEL FOR ASBESTOS In mid-1986 the Occupational Safety and Health Administration issued a revised standard for asbestos. The effective date for the Revised Standard at Alcoa's domestic locations was January 16, 1987. Attached for your review and implementation are actions recommended to assure Alcoa's compliance with medical requirements of the Revised Standard. The first attachment is a revised medical protocol for employees exposed to asbestos at or above the action level (0.1 fiber/cc for 30 or more days a year). The second attachment contains recommended medical administrative procedures. Implementation of these procedures will assure good medical management of employees under medical surveillance as well as compliance with the Standard. The Revised Standard requires that employees be given a written statement after the medical examination. Attachment 3 contains examples of letters which contain information required by OSHA. H. DEAN BELK, M.D HDB:bal ALCOA is-rj HQ 001441 Memorandum June 23, 1987 Page 2 Distribution: Edmund Gray, M.D., Addy Works Rex C. Ramsay, M.D., Arkansas Operations William H. Freeman, M.D., Badin Works Anthony M. Puleo, M.D., Cleveland Works Medical Department, Corona Works S. Louis Casta, M.D., Davenport Works G. B. Zeiner, M.D., Lafayette Works Medical Department, Lancaster Works William W. Klatchko, M.D., Lebanon Works Medical Department, Massena Operations Frank J. Pessolano, M.D., New Kensington, ARL/ATC E. A. Brethauer, M.D., Pittsburgh Office 15 B. D. Dinman, M.D., Pittsburgh 30 E. H. Slagle, M.D., Pittsburgh 15 Stanly Heckrodt, M.D., Point Comfort Operations Francis B. Warrick, M.D., Richmond Works W. Thomas Washam, M.D., Rockdale Works Colin L. Kamperman, M.D., Tennessee Operations Ralph M. Simonian, M.D., Vernon Works Thomas C. Burger, M.D., Warrick Operations Raymond J. Bunker, M.D., Wenatchee Works N. Ormonde, M.D., Kwinana, Western Australia Greg Duck, M.D., Pinjarra, Australia J. Fisher, M.D., Point Henry Works, Australia Clovis de Toledo Sanjar, M.D., Pocos de Caldas, Brazil Marcos Antonio Couto, M.D., Sao Luis, Brazil Manuel Estrala, M.D., Sao Luis, Brazil Osiris Pinotti, M.D., Sao Paulo, Brazil B. A. F. Morgan, M.D., Kingston, Jamaica Santiago Schleske, M.D. Veracruz, Mexico Johan Peter Luetzow-Holm, M.D., Elkem A/S, Oslo, Norway Allard I. Van De L'isle, M.D., Paramaribo, Suriname Neil Upton, M.D., Waunarlwydd Works, Swansea, Wales cc: Marcelo D. Barreto Vianna, Sao Paulo, Brazil Abel Newton 0. Penteado, Sao Luis, Brazil Jose Lucena de Oliverina, M.D., Itapissuma: Alconor Edi Claudio Antunes dos Souza, M.D., Pindamonhangaba D. G. Applegate, Mobile Works J. E. Burns, Pittsburgh 6 E. A. Pessolano, Pittsburgh 6 G. Schmitz, Vanexco L. F. Schneider, Pittsburgh 13 Pittsburgh Industrial Hygienists ATTACHMENT 1 PROTOCOL DESCRIPTION: OCCUPATIONAL MEDICAL EVALUATION: ASBESTOS CONTENTS: PROCEDURES: RECOMMENDED: o Cardiovascular History o Respiratory History o Physical Examination OPTIONAL: o Medical History (Short Form) TESTS: RECOMMENDED: o Blood Analyses (Series 24) o Blood Count o Chest X-Ray o ECG o Spirometry OPTIONAL: o Blood Gases with pH o Urinalysis SCHEDULE: No tissue reaction - annualmedicalevaluation for employees exposed at or above theaction level. Evidence of pulmonary/pleural tissue reactions annual medical evaluation offered as long as individual employed at Alcoa. Frequency for chest x-rays -- X-ray chest (exposure <10 years): every 5 years X-ray chest (exposure >10 years): a. <35 years: every 5 years b. Age 35 <45 years: every 2 years c. Age >45 years: annually HQ 001443 FROM H. DEAN BELK, M.D. PITTSBURGH OFFICE - 6 ATTACHMENT 2 TO MEMORANDUM June 23, 1987 RE: STANDARD PROCEDURES FOR MEDICAL SURVEILLANCE OF EMPLOYEES HAVING POTENTIAL ASBESTOS EXPOSURE AT WORK Since OSHA revised its asbestos standard in 1986, Alcoa physicians discussed the Revised Standard at our April, 1987 Meeting and agreed upon some general procedures for medical follow-up in Alcoa's Asbestos Medical Surveillance Program. The following procedures encompass the collective judgment of the physicians and should be followed to assure compliance with OSHA's requirements and Alcoa's medical standards. For the purpose of defining standard procedures, employees have been grouped below into categories determined by whether medical findings are positive or not and by whether the findings could be related to asbestos exposure or not. A. Employees without significant medical findings a. A written statement should be provided to the employee indicating no significant medical findings related to asbestos exposure. From findings at this medical examination the employee is not at increased risk of developing asbestosis. b. No special medical follow-up is necessary at this time; however, medical monitoring for asbestos will continue as long as the employee is exposed at or above the action level for asbestos. c. No work restrictions are indicated. B. Employees with significant medical findings but unrelated to asbestos exposure (assumes abnormality for organ other than the lung) a. Positive findings should be discussed with the employee by medical personnel, and a recommendation for medical follow-up should be made. The employee is not at increased risk for developing asbestosis. b. Periodic medical monitoring for asbestos exposed employees will continue as long as the employee is exposed at or above the action level; medical surveillance for other medical problems are at the discretion of the plant physician. c. No work restriction is indicated for potential asbestos exposure. Work restrictions for other conditions are at the discretion of the physician. 0 ALCOA HQ 001444 $'440 i*fv CS-'l Memorandum June 23, 1987 Page 2 C. Employee with significant medical findings related to the lung but not caused by asbestos a. After medical findings have been discussed with the employee by medical personnel, a recommendation for medical follow-up should be made. If positive finding(s) are localized on chest x-ray and pulmonary function test results demonstrate little or no impairment, the employee is not at increased risk of developing asbestosis. Should asbestosis develop, this employee may suffer additional lung impairment. If the employee smokes, he should be urged to stop. b. Periodic medical monitoring for asbestos must continue for employees as long as he/she is exposed at or above the action level for asbestos. The physician must apply good medical judgment in making a decision regarding the need for medical monitoring for the non-asbestos lung problem. If the pulmonary lesion is localized on the chest x-ray and pulmonary function tests are normal, no work restriction is indicated for asbestos exposure. If the chest x-ray lesion is generalized and/or pulmonary function tests are abnormal, the employee should be restricted from asbestos exposure. Although the risk of developing asbestosis is very small today when exposures are minimal, asbestosis, if it should develop, could severely aggravate already impaired pulmonary function. D. Employees with significant medical findings consistent with tissue reactions to asbestos 1. Pleural plaques or calcifications on chest x-ray (without evidence of parenchymal disease of the lungs) a. A written statement to the employee must indicate presence of pleural plaques and/or other evidence consistent with tissue reactions to asbestos. The employee should be informed that he does not have asbestosis, which is a disease of the lung tissue, and we cannot with certainty predict whether such a reaction will or will not occur in the future. The employee is at greater risk for developing asbestosis and should carefully follow industrial hygiene guidelines for safe tear-out of asbestos, and the plant industrial hygienist should be notified about this risk. If the employee smokes, he should be urged to stop. b. Periodic medical monitoring for asbestos exposure will continue as long as the person is employed at Alcoa, and medical personnel will keep him informed if further changes occur. HQ 001445 Memorandum June 23, 1987 Page 3 c. Unless asbestos work is undertaken with conscientious application of work practices prescribed by industrial hygiene guidelines for personal protection of workers, the employee should be restricted from work involving potential exposure to asbestos. 2. X-ray evidence of parenchymal disease of the lung consistent with a lung tissue reaction to asbestos a. Upon the initial discovery of x-ray evidence of lung changes consistent with a reaction to asbestos the employee should be referred to a local specialist in lung disease for a thorough medical evaluation. In advance the physician should be given all relevant information and should be informed that the purpose of the evaluation is to establish a diagnosis for the x-ray changes. After positive findings have been discussed with the employee by medical personnel, the employee should be given a copy of the report unless information contained in it could cause emotional stress. If the specialist diagnoses asbestosis, the plant Workers' Compensation Administrator should receive a copy of the report to initiate an investigation of the employee's asbestos exposure at Alcoa. Once asbestos exposure at Alcoa and/or elsewhere has been determined, the plant physician, Workers' Compensation Administrator and hygiene/safety professional should arrange for a telephone conference call with their respective functional staff members in Pittsburgh to discuss all findings in the case and attempt to establish whether or not (1) the findings are likely caused by asbestos exposure, (2) exposure likely did occur during work at Alcoa, (3) the case should be filed filed with OSHA as a case of occupational disease (asbestosis). Because of the risk for progression of asbestosis, the employee should be informed that he must avoid all future exposure to asbestos. In addition, if he smokes, he should stop immediately. b. Periodic medical monitoring will continue as long as the individual is employed by Alcoa. c. The employee should be restricted from work which may-result in further asbestos exposure. H. DEAN BELK, M.D HDB:bal (ASP:HDB) HQ 001446 ATTACHMENT 3 Proposed Letters Containing Medical Findings and Recommendations for Employees in the Asbestos Medical Surveillance Program A. For employees without significant medical findings To: _______________________ (employee's name) (date) Re: Results of Examination Provided Under Alcoa's Asbestos Medical Surveillance Program OSHA and Alcoa health standards require that regular medical examinations be offered to employees while they are potentially exposed to asbestos at work. You completed your medical examination on . As far as we can determine medically at this time, you demonstrated no medical evidence of reaction to asbestos and you are not at increased risk of developing asbestosis. (physician's signature) HQ 001447 Attachment 3 June 23, 1987 Page 2 B. Employees with significant medical findings but unrelated to asbestos exposure (assumes abnormality for organ other than the lung) TO: (employee's name) (date) Re: Results of Examination Provided Under Alcoa's Asbestos Medical Surveillance Program OSHA and Alcoa health standards require that regular medical examinations be offered to employees while they are potentially exposed to asbestos at work. You completed your medical examination on. As far as we can determine medically at this time, you demonstrated no medical evidence of reaction to asbestos, and you are not at increased risk of developing asbestosis. In accordance with OSHA's requirements this letter will not address medical findings, if any, which are unrelated to asbestos exposure. Such significant medical findings with recommendations for follow-up have been discussed with you by medical personnel. (physician's signature) HQ 001448 Attachment 3 June 23, 1987 Page 3 C. Employees with significant medical findings related to the lung but not caused by asbestos TO: ________________________________ (employee's name) ___________________ (date) Re: Results of Examination Provided Under ______ Alcoa's Asbestos Medical Surveillance Program OSHA and Alcoa health standards require that regular medical examinations be offered to employees while they are potentially exposed to asbestos at work. You completed your medical examination on . As far as we can determine medically at this time, you demonstrated no medical evidence of reaction to asbestosis, and you are not at increased risk of developing asbestosis. In accordance with OSHA's requirements this letter will not address medical findings, if any which are unrelated to asbestosis exposure. Such significant medical findings with recommendations for follow-up have been discussed with you by medical personnel. (physician's signature) HQ 001449 Attachment 3 June 23, 1987 Page 4 D-l. For employees with significant medical findings consistent with tissue reactions to asbestos (pleural plaques) TO: ________________________________ ______________________________________ (employee's name) (date) OSHA and Alcoa health standards require that regular medical examinations be offered to employees while they are potentially exposed to asbestos at work. You completed your medical examination on. As a result of this examination, medical personnel discovered the presence of (pleural plaques) (pleural calcifications) which may be evidence that your body is reacting to previous asbestos exposures. You do not have asbestosis, which is a disease of the lungs. On the basis of present medical findings we cannot predict whether you will develop asbestosis in the future, but you are at increased risk of doing so. (We urge you to stop smoking now because smoking will increase your risk of further, more serious lung problems in the future.) (where applicable) (If your job requires you to work with asbestos and you faithfully follow industrial hygiene recommendations for your protection, you will not further increase your risk for developing asbestosis in the future.) or as a plant medical option for consistent application -(Because your risk for developing asbestosis is greater, you are restricted from jobs which require occasional work with asbestos.) (physician's signature) HQ 001450 Attachment 3 June 23, 1987 Page 5 D-2. For employees with medical findings in the lung consistent with asbestosis TO: ________________________________ (employee's name) ___________________ (date) OSHA and Alcoa health standards require that regular medical examinations be offered to employees while they are potentially exposed to asbestos at work. You completed your medical examination on . As a result of your examination in the Medical.Department and your evaluation by a specialist in lung diseases, doctors discovered the presence of in your lungs. These findings are consistent with changes which occur in cases of asbestosis. To reduce further damage to your lungs in the future, we urge you to avoid exposure to substances potentially harmful to your lungs. (If you smoke, we urge you to stop.) [if appropriate] You should not hold a job which requires you to work with asbestos, and a medical restriction has been issued in this regard. (physician's signature) HQ 001451 From L.L. RIPPEY PITTSBURGH OFFICE 1991 April 30 RE: ALCOA CORPORATE ASBESTOS MANAGEMENT POLICY - FINAL The attached Alcoa Asbestos Management Policy has been developed as a subset of Alcoa's Environmental Policy. This policy was jointly written by representatives of Environmental, Industrial Hygiene and Safety, Procurement, Real Estate and Legal. Drafts were twice reviewed by operating locations from some of the U.S. and non-U.S. plants. Input from these sources has been incorporated into the attached policy. All of the locations polled agreed that the attached policy should represent a minimum operating standard for the protection of Alcoa employees and the management of risk. Any location could write their own internal management program to exceed the standard set in this policy. The basic philosophy expressed in this policy is that when Alcoa controls a facility, asbestos can be managed via remediation and monitoring, but if a facility is sold, friable asbestos must be removed to minimize Alcoa's long term liability. The policy itself doesn't contain an implementation schedule for the development of the written Asbestos Management Program described in item 3. Each Alcoa location's implementation plan and schedule should be negotiated within their business unit and approved by the appropriate Management Committee Member. This concept is modeled after the written plans for corrective action described in the Environmental Policy. P.R. C.F. J.L. R.E. R.M. W.L. Atkins, Pgh. 19 DiMascio, Pgh 6 Fungaroli, Pgh 13 Yester, Pgh 20 James, Pgh 6 Wells, Pgh. 26 ALCOA HQ 001452 ASBESTOS POLICY MEMO 1991 April 30 Page 2 L\ASBEST1.LLR DISTRIBUTION: Plant Managers - Worldwide IH and Safety contacts - Worldwide Environmental Contacts - Worldwide Procurement Managers - Worldwide P.H. O'Neill, Pgh. 30 G. E. Bergeron, Tennessee D.W. Ray, Pgh. 28 R.C. Rawe, Tennessee C.P. Fletcher, Pgh. 29 R.F. Slagle, Pgh. 29 M. J. Schreier, Arkansas N. F. Stephen, Australia Executive Safety Ccumittee C.F. DiMascio, Pgh. 6 V.R. Scorsone, Pgh. 29 J.L. Diederich, Pgh. 29 R.R. Hoffman, Pgh. 29 A. Belda, Brazil C. F. Fetterolf, Pgh. 30 T.L. Carter, Pgh. 29 H. M. Goern, Pgh. 29 D. R. Whitlow, Pgh. 29 1991 April 30 ALCOA CORPORATE ASBESTOS MANAGEMENT POLICY SCOPE: Proposed policy will apply to all Alcoa owned or controlled facilities including industrial as well as office buildings. Relevant aspects of the policy also extend to properties leased by Alcoa where Asbestos Management Programs should be required of building owners. Some variations may occur where local regulations or special circumstances dictate. POLICY OBJECTIVES: 1. Uniform and consistent practices are hereby established for the purchase of facilities, equipment and new products and for the divestiture of equipment and facilities including real estate. A. Sponsoring managers shall require that environmental surveys conducted prior to purchase of new facilities involve asbestos surveys and risk assessments. Full compliance with all Alcoa asbestos management policies will apply if properties with asbestos are purchased. B. Procurement agents shall insure that only non-asbestos products are purchased. Every effort will be made to find non-asbestos substitutes for the remaining asbestos containing products used in Alcoa facilities. Deviations from this policy will require written approval of the Location Manager. The Procurement Manager must maintain written records of asbestos products purchased in exception to this policy. C. Procurement agents shall insure that equipment sold by Alcoa must be free of friable asbestos prior to sale unless an exception is made by Pittsburgh Environmental Control. Where an exception is granted, written disclosure of the presence of asbestos must be provided to the purchaser and this record shall be maintained for a period of 30 years. D. Sponsoring managers shall insure that before any sale of real property, an asbestos survey will be conducted. All friable asbestos materials must be removed and disposed of properly. In some cases, non-friable asbestos materials should also be removed if it is suspected that the future use of the property will subject them to damage, thereby releasing asbestos fibers. Exceptions to the removal policy can only be made by Pittsburgh Environmental Control. Buyers must be informed in writing of the presence of any asbestos in buildings which are sold. This record shall be maintained for a period of 30 years. HQ 001454 ASBESTOS POLICY 1991 April 30 Page 2 2. Operations Managers shall require surveys for all Alcoa facilities to determine the presence of Asbestos Containing Materials, "ACM" (greater than 0.1 % of any fibrous asbestos mineral forms). Surveys must follow the general format recommended in the Alcoa Engineering Standard on Asbestos Surveys and must include the condition of ACM in addition to the location accessibility and an estimate of ACM quantity. 3. Plant managers operating facilities having any ACM shall develop written Asbestos Management Programs which must be approved by a member of Alcoa's management committee or by the Managing Director Alcoa of Australia as is appropriate. The Location Asbestos Management Program is to include: A. Identification of ACM via direct labels or any alternatives to direct labeling which would clearly communicate the presence of ACM to affected employees. Such alternatives could include placards, inventories, diagrams, or marked blueprints. To effectively communicate the presence and location of ACM, some of the alternatives should be associated with training and be made accessible to employees. B. Communication of the presence of asbestos to facility employees and contractors who work in areas where asbestos is present C. A plan for reinspection of ACM on a periodic basis (minimally, every 3 years) with written inspection reports D. Remediation, through removal, repair, enclosure or encapsulation of ACM in a deteriorated condition (Attachment 1) E. Assurance that all asbestos work including removal and disposal is carried out in compliance with all relevant Federal, State and local regulations (ref. Alcoa Engineering Standard 18.18 "Asbestos Removal Standard") F. Directions to ensure that Operation and Maintenance procedures will be defined to prevent employee exposure to asbestos during normal day- to-day operation of facilities where ACM is present. G. Acknowledgement that all U.S. asbestos contracts will be written in Pittsburgh in close cooperation with the various field Procurement Departments and will be retained for a minimum of 30 years accordance with the 1989 Pittsburgh Procurement policy. Sample contracts can be provided to international Alcoa locations for informational purposes. HQ 001455 ASBESTOS POLICY 1991 April 30 Page 3 H. A plan to address any potential emergencies where asbestos may be released in the facility. The SPCC (Spill Prevention Control and Countermeasures Plans) could be revised to include this contingency where appropriate. I. A long range strategic plan that recognizes that at the end of a facilities life, prior to its sale or demolition, all friable asbestos must be removed 4. Alcoa locations will comply with all applicable asbestos laws and regulations and will employ more restrictive internal standards where necessary to conform with the above policy. HQ 001456 Attachment 1 MANAGEMENT OF ASBESTOS CONTAINING MATERIALS IN ALCOA FACILITIES ACM - Asbestos Containing Materials both friable and non-friable materials containing > 0.1% fibrous asbestos mineral forms. Friable - EPA definition - asbestos containing materials which can be crushed with hand pressure. Examples of friable asbestos include sprayed on fireproofing, most asbestos insulation and any other ACM which is deteriorated to the point that it can be crushed with hand pressure. Non-friable - Examples asbestos include transite (asbestos cement products) and vinyl asbestos tile. HQ 001457 PROCUREMENT CONTACTS T. W. Dodson, Arkansas R. Hartmayer, San Diego (Alcoa Electronic Packaging) J. Feder, TRE-Aztech T. C. Spurlock, Vernon R. A. Topp, Fort Meade L. Lauderdale, Tifton - GA w. R. Pottgen, HC Products J. R. Mitchell, Lafayette G. C. Bailey, Richmond A. Atkins, Richmond E. T. Klenske, Jr., Warrick V. Poleshaj, Davenport H. R. Sands, New Orleans (Alcoa Export Supply Division) A. R. Hering, vidalia F. E. Lux, Massena D. W. Pettit, Badin J. R. Rettinger, Cleveland G. Branco, Stolle T. G. Snyder, ATC D. L. Utley, Lebanon G. E. Babinsack, Halco Mining T. Agostine-Allen, Warrendale L. Blackwell, AFL - Spartanburg W. S. Zuber, Tennessee B. McDevitt, El Paso T. A. Innes, Point Comfort J. R. Fry, Rockdale C. H. Barker, Jr., Paradise Point M. Brooks, Northwest Alloys (Addy) R. Surbeck, Vanexco R. D. Huber, Wenatchee V. L. Hammersmith, Permatech KEY\Procure.key HQ 001458 PLANT ENVIRONMENTAL CONTACTS (Domestic) J. A. Shockey, ATC KEY\Environ.key J. Harper, Arkansas C. A. Carter, Badin R. C. King, Cleveland G. O. Pratt, Davenport A. Ness, Ft. Meade D. E. Huddleston, Lafayette K. L. Adams, Lebanon J. A. Lease, Massena D. G. Applegate, Mobile O. E. Wilkinson, Northwest Alloys C. H. Barker, Paradise Point J. C. Mayfield, Point Comfort J. L. Eicher, Richmond J. C. Saxton/C. L. Green, Rockdale H. G. Sakoian, Tennessee W. Housworth, Tifton-GA T. Schmidt, Tifton-Delhi M. B. Dalrymple, Washington Office J. P. Hupy, Knoxville T. L. Fearington, ACI - Santa Ana, CA G. Emanuelson, ACI - Monrovia, CA R. B. Shick, ACI - Springville, UT S. H. Myers, Vancouver J. S. Stratton, Vanexco A. B. Piecka, Vernon B. R. Hopper, Vidalia J. K. Mackay, Warrick J. A. Thompson, Wenatchee J. Jackson, AFL/Nashville D. Heatherl, AFL/Spartanburg K. D. Meholic, Alcoa Electronic Pkg. - San Diego, CA R. S. Hospodar, Alcoa Steamship - Pgh. 24 S. L. Anderson, Alcotec Wire Co. - Traverse City, MI C. E. Coker, Dalton Alumina & Chemicals - Rocky Face, GA J. K. Clark, HC Industries - Crawfordsville, IN G. Calvery, HC Industries of MS - Olive Branch, MS G. R. Hartnett, HC Products - Princeville, IL F. Kile, Illinois Water Treatment - Rockford, IL J. K. Steelman, Permatech - Graham, NC D. A. Krich, Pimalco - Chandler, AZ J. E. Francis, Alcoa Separations - Warrendale, PA J. H. Gemmill, Southco Metals Services - Atlanta, GA J. McCarty, TEPCO - El Paso, TX F. F. Viguerie, Alcoa Coastal - Houston R. K. Shuler, Alcoa Coastal - Nashville C. Webster, Ragsdale Machinery - Englewood, CO A. Titscomb, Randolph Machinery - Randolph, NY M. Decker, Randolph Machinery - Randolph, NY P. DeSocio, Autoprod - Clearwater, FL R. H. Gatewood/J. M. Brown, Stolle Corp. - Sidney, OH HQ 001459 PLANT ENVIRONMENTAL CONTACTS (Worldwide) M. B. Vianna, Sao Paulo J. Mauricio de Macedo Santos, Sao Luiz G. A. Morgan, Clarendon - Jamaica w. Luders, Pocos de Caldas J. Kerkhof, Drunen G. Thomas, Swansea G. Slessar, Booragoon J. Lippelgoes, Portland J. Eyles, Pt. Henry R. H. Ramden, Suriname J. R. Archibald, Mexico City J. M. Leach, Barcelona Y. Shibazaki, Tokyo R. Armbruester, Worms H. J. Preub, Worms H. H. Pohland, Ludwigshfen KEY\Environ.key HQ 001460 Laura L. Rippey 1990 Pot-Sc We cen t wait tor tomorrow! J.-- OjUpt'wu. Ju ~w\. 'jC-i-cuS -ft* &t. Ml'iJ^QC&'dicjdzJ (c?^ tOH n 5& .0 faUi&tc'z- OtfcoA-'s p&&Cc^ - /9e . pco 0k Qgvr- Utijuo A^lC^J jQM'hj /UU&tCf CS-/A Pk/it& tj^ Qjjyi^e /Itf^cJhsO ^/<o p/o /ztftpfrd-- M&& sfbjL* CIaJUm/j-a_ , GfldOL do&- A/ft /yUA-Z't-j <a> Cnydt ^tz> cfZtyzsa/ but petic^ ^u/i/cf9^ pldcftOZ. /W^. tks. 0ALCOA ^ <-/ ATf/ pmcidb 1501 AIcoj Building Pittsburgh. Pennsylvania 15219 NEGATIVE PRESSURE CONTAINMENT NEEDED FOR ROOF ASBESTOS REMOVAL. OSHA DECIDES OSHA's plans to treat certain roof removal jobs the same as asbestos abate ment has left roofing contractors stunned. The agency's pending regulation will force contractors to construct negative pressure containment around roofs when feasible. The decision is "absolutely ludicrous," said Carl Good, director of the Asbestos Task Force of the National Roofing Contractors Association. NRCA had sought to exempt the roofing industry from OSHA's asbestos standard. Instead, OSHA notified NRCA last month that, "in essence, OSHA plans to regulate roofing (Continued) Page 156Occupational Health & Safety Letter"October 4, 1989 ROOF REMOVAL REGULATED AS 'ABATEMENT' (Continued) jobs as asbestos removal jobs," Good said Sept. 19 at a conference sponsored by the Asbestos Information Association/North America. The ruling promises to "virtually change our entire industry," Good said. NRCA intends to pursue the matter further, Good told OHSL, and will take it to federal court if necessary. An OSHA compliance official confirmed the decision during a session at the National Asbestos Council trade show in Indianapolis Sept. 26. "Roofing is con sidered by the standard to be an asbestos abatement activity," said Joseph Hopkins of OSHA's compliance office. Each job would need to be evaluated to determine whether it could be exempted from the regulation, he said. If a roofing job is regular maintenance, the contractor would not be re quired to construct negative pressure containment, he said. However, if the job entails "removing an entire roof, it is considered an abatement job" requiring containment, Hopkins added. OSHA will waive the requirement if the contractor can demonstrate it is not feasible to construct containment, such as if the roof is very steep or winds are too severe. HQ 001463 From L. L. RIPPEY PITTSBURGH 6 To PENNY BOBER PITTSBURGH 6 1989 JULY 7 RE: HEALTH & SAFETY NEWSLETTER An article from the June 22, 1989 issue from Plant Engineering indicates that although OSHA will not exempt the roofing industry from air monitoring for asbestos, individual contractors may be able to obtain variances for particular jobs. (See attached article) Data from an ATC roofing job where contractors removed areas of roof flashing which contained asbestos indicated exposures were all less than the 0.1 f/cc action level. 8hr TWAs ranged from 0.0015 to 0.0353 f/cc with a median level of 0.0057 f/cc. LAURA L. RIPPEY LLR:j f 0016.Hr ATTACHMENT cc: R. M. James, Pittsburgh 6 Asbestos file: Typical Exposures ALCOA HQ 001464 Edited by Vera M. Steiner, Senior Editor Made in America -- Good Enough? What are the industrial weaknesses holding back America? What are the strengths? To uncover the underlying issues, the Mas sachusetts Institute of Tech nology (MIT) undertook a 2-year investigation of eight industries that account for about 50% of America's to tal volume of imports and exports of manufactured goods, and 28% of Ameri can manufacturing activity. The recently published findings describe what went wrong and suggest ways the U.S. can gel back on the path of high productivity. Weaknesses cited by the MIT commission are long standing: outdated strate gies, short time horizons, technological weakness in development and produc tion, neglect of human re sources. failures of coopera tion between individuals and between organizations, and government and indus try at cross purposes. Five imperatives were drawn up by MIT's investi gating commission on what America must do if it is to continue as a major eco nomic power Focus on producing well; put production ahead of fi nance and monetary manip ulation. The report said managers who do not know production will lose the competitive battle to man agers who know their busi ness intimately. Cultivate a new economic citizenship with an in volved. educated, responsi ble. and rewarded work force, who will maximize productivity. Promote the most pro ductive blend of individual ism and cooperation. Or ganizational hierarchies should be restructured into fewer job categories to pro mote cooperation. Learn to live in the world economy, understand other languages, cultures and technologies. Protectionism only invites retaliation, but the U.S. must also insist that our goods are treated abroad as fairly as theirs are treated here. Provide for the future; in vest in education and save for productive investment. Americans must be pro- 1 with a fundamentally rent education from y receive today. The rjx>rt points out that, "Only 4. tiny fraction of young Americans are tech nologically Hierate and have some knowledge of foreign societies. Unless the nation begins to remedV tlwse in adequacies, it canxp^ke no real progress/ Emerging industrial practice' successful U.S. firms wi noted by the commission. In the MIT view, these prac tices are mutually reinforc ing and form an integrated strategy; Simultaneous improve ment in quality, cost, and delivery Staying close to the customer Closer relations with suppliers Using technology for stra tegic advantage Hatter and less compart mentalized organizations. Affirming the importance of the country's industrial base for future economic health, MIT's President Paul E. Gray slated, "We believe manufacturing is absolutely essential to this nation's economic future. Technology is the main engine that drives the economy EPA Monitoring Chemical Emissions Results of the Environmental Protection Agency's (EPA) first national inventory of chemical releases into the environment have just been made public. The Tox ic Release Inventory (TRI) reports a total of 22.5 bil lion lb of chemicals were released in 1987, including more than 2.4 billion lb of toxic pollutants released into the air and 9.7 billion lb of chemicals that were released to streams and other surface waters. The chemical industry was the largest source of air toxics, releasing some 886.5 million lb annually. Texas had the most toxic air pollutant releases of any state, with 230 million lb emitted. Seven other states (Illinois, In diana, Louisiana, Michigan, Ohio, Tennessee, and Vir ginia) had emissions greater than 100 million lb annually. An EPA spokesperson called the TRI results "star tling and unacceptably high," underscoring the need for changes in manufacturing processes to reduce the amount of toxic substances produced. Exemptions Possible for Asbestos in Roofing Materials The Occupational Safety and Health Administration's (OSHA) position on asbestos regulations and exemp tions was recently clarified with regard to asbestos-con taining roofing materials. Although the agency denied an industry-wide exemption from air monitoring re quirements as requested by the National Roofing Con tractors Association, individual contractors may be able to gain exemption on specific jobs and for specific asbestos-containing products. To date, OSHA has no evidence on file to indicate there is a health hazard to roofing industry personnel from handling asbestos-con taining roofing materials. Plant Modernization Strategy Adopted for Competitive Gain Despite grim predictions for the metals industry in the mid-1980s, Alcoa was one manufacturer that chose to believe a decline was not inevitable. The 100-year-old tz PLANT ENGINEERING JUNE Z2. HQ 001465