Document KGMwEr322QgVVGzz2479Ep8mo

To: Division Superintendents Staff Heads Subjact Asbestos Usage PLAINTIFF'S EXHIBIT United States Steel ICorporation _z. EASTERN STEEL DIVISION Oats: August 19, 1980 From: T. Stevenson General Superintendent Fairfield Works OSHA promulgated an asbestos health standard in 1972, and since then, efforts have been made within Fairfield Works to eliminate usage of this hazardous material. However, recent investigations indicate a significant amount of asbestos usage still remains. Improper use of asbestos can produce health damage and/or OSHA citations. These adverse effects are to be prevented to the greatest extent feasible. Your approach should be as follows: 1. Make an inventory of potential asbestos exposure in your area, or update your past Inventory. Pay attention to potential asbestos exposure during repair and maintenance work, eg. during pipe insulation replacement, heat seal and gasket installation, brake lining replacement, etc. 2. Try to replace the asbestos with substitute materials wherever possible. Substitution will likely involve less trouble than complying with the standard. Purchasing and Environmental Health.may be able to suggest substitute products. 3. Ifno substitute can be found and asbestos must be used, take the necessary steps to comply with the OSHA asbestos standard. A copy of the standard is attached. The standard basically requires potential exposures to be cheeked for air contamination, and where such contamination Is significant, periodic air monitoring and medical examinations of the exposed workers are then necessary. Where exposures are excessive, the standard requires engineering controls, respiratory protection, etc. There are also provisions for &abel'ihg warning signs and recordkeeping. A copy of your asbestos exposure inventory should be sent within 30 days to R. H. Deibert, Fairfield Environmental Health, MS J-32, ext. 4475, who will arrange for an initial survey and for periodic surveys as necessary. Medical examinations can be arranged through the Medical Center, ext. 4193. cc ' E. J. SCollc F. J. Lakotlch M. E. Garner, M.D. USX-98-05651 Titi* 3?--labor CfcopUr XVU--Occupational Safety and Health Administration 19T0.10CJ fi 1910.1001 AibdUM. (a) Definitions. For the purpose of this section. (1) "Asbestos" Includes chrysotile. amosite, crocidolite, tremolite, anthophylllte. and actlnolite. (2) "ASbestos fibers" means asbestos fibers longer than S micrometers. (b) Permissible exposure to airborne concentrations of asbestos fibers--ll) Standard^affective July 7, 1972. The 8hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed five fibers, longer than 5 micrometers, per cubic centi meter of air. as determined by the method prescribed in paragraph (e) of this section. <2) Standard effective July 1. 1976. The 8-hour time-weighted average air borne concentrations of asbestos fibers to which any employee may be ex posed shall not exceed two fibers, longer than 5 micrometers, per cubic centimeter of air, as determined by the method prescribed In paragraph (e) of this .section, (3) Ceiling concentration. No em ployee shall be exposed at any time to ` airborne concentrations of asbestos fibers In excess of io fibers, longer - than 5 micrometers, per cubic centi meter of air, as determined by the method prescribed in paragraph (e) of this section. (c)Methods of compliance--tl) Engi neering methods. (1) Engineering con trots. Engineering controls, such as. but not limited to. Isolation, enclosure, exhaust ventilation, and dust collec. tion, shall be used to meet the expo: sure limits prescribed in paragraph (b) V of this section. (11) Local exhaust ventilation, la) ; local exhaust ventilation and dust col- lection systems shall be designed, con- atructed, Installed, and maintained In accordance with the American Nation' a] Standard Fundamentals Governing the Design and Operation of Local Ex haust Systems. ANSI Z9-2-1971. which ; to Incorporated by reference herein. et) See 11910.8 concerning the avafl- ? ability of ANSI Z9.2-197I. and the -. maintenance of a historic file In eonnectlon therewith. The address of the / American National Standards Insti: tute to given In 11910.100. (ill) Particular tools. All hand-oper'. ated and power-operated tools which may produce or release asbestos fibers in excess of the exposure limits pre scribed In paragraph (b) of this seetion. such as, but not limited to, saws. ; scorers, abrasive wheels, and drills, *h*U be provided with local exhaust : ventilation systems in accordance with subdivision (11) of this subparagraph. (2) Work practices--li) Wet methods. insofar as practicable, asbestos shall - be handled, mixed, applied, removed, - cut, scored, or otherwise worked in a ) wet state sufficient to prevent the emission of airborne fibers in excess of -. the exposure limits prescribed in paragraph (b) of this section, unless the usefulness of the product would be dl mintohed thereby. USX-98-056S2 (II) Particular products and oper sonaoiy expected to exceed no more ations. No asbestos cement, mortar, than 10 times those limits. coating, grout, plaster, or similar ma (II) Powered air purifying respire., terial containing asbestos shall be re tors. A full facepiece powered air purl- moved from bags, cartons, or other fying respirator, or a powered air purl- containers In which they are shipped, 1 fylng respirator, or a respirator de without being either wetted, or en- scribed 1q paragraph (d)(2)(i!i) of this closed, or ventilated so as to prevent ' section, shall be used to reduce the effectively the release of airborne as concentrations of airborne asbestos bestos fibers in excess of the limits fibers In the respirator below the ex prescribed in paragraph (b) of this sec posure limits prescribed In paragraph tion. (b) or this section, when the celling or (III) Spraying, demolition, or remov the 8-hour time-weighted average con al. Employees engaged in the spraying of asbestos, the removal, or demolition of pipes, structures, or equipment cov centrations of asbestos fibers are rea sonably expected to exceed 10 times but not 100 times, those limits. ered or Insulated with asbestos, and in (III) Type "C" supplied-air respira the removal or demolition of asbestos tors, continuous flow or pressure- insulation or coverings shall be pro demand class. A type "C" continuous vided with respiratory equipment in accordance with paragraph (d)(2)(IIl) flow or pressure-demand, supplied-air respirator shall be used to reduce the of this section and with special cloth concentrations of airborne asbestos ing In accordance with paragraph (d)(3) of this section. fibers in the respirator below the ex posure limits prescribed In paragraph (d) Personal protective equipment-- (I) Compliance with the exposure limits prescribed by paragraph (b) of this section may not be achieved by the use of respirators or shift rotation (b) of this section, when the ceiling or the 8-hour time-weighted average air borne concentrations of asbestos fibers are reasonably expected to exceed 100 times those limits. of employees, except: (iv) Establishment of a respirator (1) During the time period necessary to install the engineering controls and to institute the work practices re quired by paragraph (c) of this sec tion; (U> In work situations in which the methods prescribed In paragraph (c> of this section are either technically not feasible or feasible to an extent in sufficient to reduce the airborne con centrations of asbestos fibers below the limits prescribed by paragraph (b) of this section: or (ill) In emergencies. program, la) The employer shall es tablish a resplrator`<program In accord ance with the requirements of the American National Standards Prac tices for Respiratory Protection. ANSI 388.2-1969, which to incorporated by reference herein. (6) See 11910.6 concerning the avail ability of ANSI 283.2-1969 and the maintenance of a historic file In con nection therewith. The address of the American National Standards Insti tute to given In S 1910.100. (c) No employee shall be assigned to tasks requiring the use of respirators (lv) Where both respirators and per If, based upon his most recent exami sonnel rotation axe allowed by para nation. an examining physician deter graphs (d)(1) (1). (11). or (111) of this sec- ) mines that the employee will be tlon, and both are practicable, person unable to function normally wearing a nel rotation shall be preferred and respirator, or that the safety or health used. ! of the employee or other employees (2) Where a respirator is permitted _ by paragraph (dxl) of this section, it ' shall be selected from among those ap proved by the Bureau of Mines, De partment of the Interior, or the Na tional Institute for Occupational Safety and Health. Department of Health. Education, and Welfare, under the provisions of 30 CTO Part 11 (37 FR 6244, Mar. 25. 1972), and shall be used In accordance with subdivisions (1). (U>. (ill), and (lv) of this subpara graph. (1) Air purifying respirators. A reus able or single use air purifying respira tor. or a respirator described in para graphs (d)(2) (li> or (ill) of this section, shall be used to reduce the concentra tions of airborne asbestos fibers in the respirator below the exposure limits j will be impaired by hto use of a respl] rator. Such employee shall be rotated ! to another Job or given the opportune ! ty to transfer to a different position : whose duties he Is able to perform with the same employer, in the same geographical area and with the same seniority, status, and rate of pay he had lust prior to such transfer, if such a different position Is available.. - (3) Special clothing: The employer shall provide, and require the use of. special clothing, such as coveralls or similar whole body clothing, head co verings, gloves, and foot coverings for any employee exposed to ai: borne con centrations of asbestos fibers, which ' exceed the celling level prescribed in paragraph (b) of this section. (4) Change rooms: (I) At any fixed prescribed In paragraph (b) of this sec tion. when the eeillng or the 8-hour time-weighted average airborne con centrations or *asbestos fibers are rea- place of employment exposed to air borne concentrations of asbestos fibers in excess of the exposure Um<tB pre scribed In paragraph (b) of this sec tion, the employer shall provide ""change rooms for employees working regularly at the place. (II) Clothes lockers: The employer shall provide two separate lockers or containers for each employee, so sepa rated or Isolated as to prevent con tamination of the employee's street clothes from his work clothes. (III) ^Laundering: (a) Laundering of asbestos contaminated clothing shall be done so as to prevent the release of air-borne asbestos fibers In excess of the exposure limits prescribed in para graph (b) of this section. lb) Afly employer who gives asbes tos-contaminated clothing to another person for laundering shall Inform such person of the requirement In paragraph (dX4XliiXa) of this section to effectively prevent the release of airborne asbestos fibers In excess of the exposure limits prescribed In para graph (b) of this section. (c) Contaminated clothing shall be transported In sealed Impermeable bags, or other closed. Impermeable containers, and labeled In accordance with paragraph (g) of this section. <e) Method of measurement All de terminations of airborne concentra tions of asbestos fibers shall be made by the membrane filter method at 400'450 x (magnification) <4 millime ter objective) with phase contrast illu mination. (f) Monitoring--(l) Initial determi nations, Within 6 months of the publi cation of this section, every employer shall cause every place of employment where asbestos fibers are released to be monitored In such a way as to de termine whether every employee's ex posure to asbestos fibers is below the limits prescribed in paragraph (b) of this section. If the limits are exceeded, the employer shall immediately under take a compliance program In accord ance with paragraph (c) of this sec tion. (2) Personal monitoring--(I) Sam ples shall be collected from within the breathing gone of the. employees, on membrane filters of 0.8 micrometer porosity mounted in an open-face filter holder. Samples shall be taken for the determination of the 0-hour time-weighted average airborne con centrations and of the celling concen trations of asbestos fibers. (ID Sampling frequency and pat terns. After the initial determinations required by paragraph (fXl) of this section, samples shall be of such fre quency and pattern as to represent with reasonable accuracy the levels of exposure' of employees. In no ease shall the sampling be done at interval! greater than 0 months for employees whose exposure to asbestos may rea sonably be foreseen to exceed the limits prescribed by paragraph (b) of this section. (3> Environmental monitoring--(it samples shall be collected from areas of a work environment which are rep resentative of the airborne concentra tions of asbestos fibers which may reach the breathing tone of employ ees. Samples shall be collected on a membrane filter of 0.8 micrometer po jroslty mounted In an open-face filter holder. Samples shall be token for the determination of the 8-hour timeweighted average airborne concentra tions and of the ceiling concentrations . of asbestos fibers. (II) Sampling frequency and pat terns. After the initial determinations required by paragraph (f)(1) of this section, samples shall be of such fre quency and pattern as to represent with reasonable accuracy the levels of exposure of the employees. In no case shall sampling be at Intervals greater than 6 months for employees whose exposures to asbestos may reasonably be foreseen to exceed the exposure limits prescribed In paragraph (b) of this section. (4) Employee observation of moni toring. Affected employees, or their representatives, shall be given a reasonable opportunity to observe any monitoring required by this paragraph and shall have access to the records thereof. (g) Caution signs and labels, (i) Caution signs. <j) Posting. Caution signs shall be provided and displayed at each location where airborne con centrations of asbestos fibers may be in excess of the exposure limits pre scribed In paragraph (b) of this sec tion. Signs shall be posted at such a distance from such a location so that an employee may read the signs and ' take necessary protective steps before entering the area marked by the signs. Signs shall be posted at all approaches to areas containing excessive concen trations of airborne asbestos fibers. (11) Sign specifications. The warning signs required by paragraph (gXlXD of this section shall conform to the re quirements of 20M x 14" vertical format signs specified in f 1910.148(d)(4), and to this subdivi sion. The signs shall display the fol lowing legend in the lower panel, with letter sizes and styles of a visibility at least equal to that specified in this subdivision. IWM fUbatm -- /rotation , rtuiiiifl, Oothle or Block. Put Bmrd.......................... .. W- S*n Serif. Gothic or Blocs. Atom Brrtthtfg Pi* ____ - M-Qothlc. , War Antfned PfoMctlm W Gothic. Equipment. Do Not Bomoln In Arc* W* OoUUc. Unlaw Tour Wore )tqulroo n. Breathing Aotontot Pint Mar It point Oothlc. Be HocorSoua To Tour Health. Spacing between lines shall be at least equal to the height of the upper of any two lines. (3) Caution labels--(i) Labeling. Cautlow labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers, except that no label Is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material so that during any rea sonably foreseeable use, handling, storage, disposal, processing, or trans portation. no airborne concentrations of asbestos fibers In excess or the ex posure limits prescribed in paragraph .(b) of this section will be released. USX-98-05653 (11) label specifications. The caution labels required by paragraph (g)(2i(D of this section shall be printed In let ters of sufficient size and contrast as to be readily visible and legible. The label shall state: Caption Contains Asbestos Fibers .Avoid Creating Dust Breathing Asbestos Dust May Cause Serious * Bodily Harm (h> Housekeeping--(1) Cleaning. All external surfaces In any place of em- * ptoyment shall be maintained free of accumulations of asbestos fibers if with their dispersion, there would be an excessive concentration. (2) Waste disposal Asbestos waste, scrap, debris, bags, containers, equip.' ment. and asbestos-contaminated clothing, consigned for disposal, which may produce In any reasonably fore seeable use, handling, storage, process ing, disposal, or transportation air borne concentrations of asbestos fibers In excess of the exposure limits pre scribed in paragraph (b) of this section shall be collected and disposed of In sealed impermeable bags, or other closed. Impermeable containers. (1) Recordkeeping--(1) Exposure rec ords. Every employer shall maintain records of any personal or environ mental monitoring required by this section. Records shall be maintained for a period of at least 20 years and shall be made available upon request to the Assistant Secretary of Labor for Occupational Safety and Health, the Director of the National Institute for Occupational Safety and Health, and to authorized representatives of either. (2) Employee access. Every employee and former employee shall have rea sonable access to any record required to be maintained by paragraph (ixi) of this section, which Indicates the employee's own exposure to asbestos fibers. (3) Employee notification. Any em ployee found to have been exposed at any time to airborne concentrations of asbestos fibers In excess of the limits prescribed in paragraph (b) of this sec tion shall be notified in writing of the exposure as soon as practicable but not later than 8 days of the finding. The employee shall also be timely no tified of the corrective action being taken. fj) Medical examinations--(1) Gen eral The employer shall provide or make available at his cost, medical ex aminations' relative to exposure to 'as bestos required by this paragraph. (2) Preplacement The employer shall provide or make available to each of his employees, within 30 calen dar days following his first employ ment in an occupation exposed to air borne concentrations of asbestos fibers, a comprehensive medical exam ination. which shall include, as a mini mum. a eh at roentgenogram (posteri or-anterior 14 X 17 inches), a history to elicit symptomatology of respira tory disease, and pulmonary function testa to Include forced vital capacity (FVC) and forced expiratory volume it 1 second <FVMl. (3) Annual examination!. On or before January 31. 1973. and at least annually thereafter, every employer hall provide, or make available, com prehensive medical' examinations to each of hi* employees engaged In occu pations exposed to airborne concentra tion^ of asbestos fiber*. Such annual examination shall Include, m a mini mum^* chest roentgenogram (posteri or-anterior 14 x 17 inches), a history to elicit symptomatology of respira tory disease, and pulmonary function tests to Include forced vital capacity . (FVC) and forced expiratory volume at 1 second (7EVi.li (4) Termination of employment The employer shall provide, or make avail able, within 30 calendar days before or after the termination of employment of any employee engaged In an occu pation exposed to airborne concentra tions of asbestos fibers, a comprehen sive medical examination which shall Include, as a minimum, a chest roent genogram (posterior-anterior 14 x 17 Inches), a history to elicit symptoma tology of respiratory disease, and pul monary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEY,.), (8) Recent examination!. No medical examination la required of any em ployee. If adequate records show that the employee has been examined In accordance with this paragraph within the past 1-year period. () Medical records--<l) Mainte nance. Employers of employees exam ined pursuant to this paragraph shall rwn: to be maintained complete and accurate records of all such medical examinations. Records shall be re tained by employers for at least 30 years. (U) icon. The contents of the rec ords of the medical examinations re * quired by this paragraph shall be t* made available, for inspection and copying, to the Assistant Secretary of habor for Occupational Safety and Health, the Director of NIOSH. to au thorised physicians and medical con sultants of either of them. and. upon the request of an employee or former . employee, to his physician. Any physi v/< 5 cian who conducts a examina tion,required by this paragraph shall furnish to the employer of the exam ;:-A ined employee all the Information spe cifically required by this paragraph, and any other medics] information re lated to occupational exposure to as bestos fibers. CM re XS90X June XT. 1X74. ltedmlcnsted at 40 m XI07S. Stay tt. 1S7*. sad tmsnded t 41TR11903, Ibr. is. imi % : 'i T .;*> ; *i . USX-98-05654