Document KGQML6qLpyV7J6K6eOvm2LomN

. FB^TION MATERIALS STANDAn 'INSTITUTE, INC., .E-210 ROUTE 'ARAMUS, N.J. 07652 BULLET 1 N N 0. 478 June 14, 1973 Subject: ASBESTOS STUDY COMMITTEE ACTIVITIES At the June 1, 1973 meeting of the Asbestos Study Committee, it was recommended that the following information be distributed to the Membership. 1. OSHA Labeling Reguirements 2. In-plant CAUTION Sign (W. H. Brady Co.) 3. EPA Emissions Standards - A Discussion ' C!A Labe? i.~.o Recuit'ements -- Attached is Exhibit- I, a disprlay of four different OSHA CAUTION labels. One is with a gummed backing to attach to packaging. Another is in the form of a tag. Others are imprinted on the cartons or boxes when purchased from the box manufac turer. . The Committee adopted a resolution at an earlier meeting which essentially recom mended that Members obey the law. That resolution stated: _ That (l) where asbestos containing materials do not have their asbestos fiber completely locked in, or ' (2) where subsequent operations may be performed on asbestos containing materials, the hazardous labeling . practice be adhered to in accordance with the Label ' Specifications in the OSHA Standards for Exposure to . * Asbestos Dust. ' The Committee has decided to make no recommendations on style, minimum dimensions-, etc. It reconmends that the manufacturer comply with the requirements of the act, demonstrating "good faith" in their observation of the requirements. In other words, printing a miniature CAUTION label on the bottom of a large box would not be demonstrating "good faith." According to the Standards the labels "shall be print ed in letters of sufficient size and contrast as to be readily visible and legible.11 In-clant CAUTION sion (W.H.Bradv Co.) Enclosed also is a copy of a letter from the W.H.Brady Co., Milwaukee, Wisconsin, to which we've added a CAUTION sign as manufactured by the Brady Co. This sign conforms to the requirements of the OSHA Standards. Several Committee members feel the cost of these signs is attractive. See Exhibit 1I. D'L r*) - 2- E?A Emissions Standard*; - A Discussion At this recent Committee meeting, the new EPA Emissions Standards were discussed. As there were several different interpretations by Members and Regional EPA per sonnel, a digest of the minutes of the meeting are enclosed. It will be noted that there are different interpretations concerning several items: (D "new source" versus "existing source," (2) whether to quantify machines under "Process Description," and (3) whether "Amount of Pollutant" - if given total into each Process - will then be construed as being 5 to 10 times the total asbestos entered into the process. See Exhibit III. . E\7D/erc Enclosures? . To: Active Merafeef-Sr Regional Members -" E. W. Drislane Executive Director 3-{ FRICTION MATILx^IAXS STANDARDS INC. CAU730W Contains Asbestos Fibres Avoid Creating Dust reathing Asbestos Dust May Guise Serious Bodily Harm * CAUTION- CONTAINS ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUS SERIOUS BODILY HARM Contains Asbestos Fibers Avoid Creating Dust . Breathing Asbestos Dust mcy cause serious Bodily Harm CAUTION * Contains Asbestos Fibers Q Avoid Creating Dust : Breathing Asbestos Dust M Cluss Serious EccJily Harm eE?eESEsnA*T ive os ha C-AOTfONJ LA Pecs asbestos RgoaocTs Efc H 6 rr .wHbiiADTCQ 727 Wesc Gltzrrclala Avo. Mllwnuhno. Win. 53201 LsL 19m Phone l<11-3 332-9100 Telex 2S-S77 Teletype S10-2S2-31S1 - Cable Qrejjy Attention: ' Plant Engineer Dear Sir: ' ' As a supplier of asbestos materials to industry and commerce we thought you'd like to know Brady has asbestos hazard signs in stock, ready for immediate shipment. The sign complies ' in color, and size and wording with OSHA 1910;93a(g). A repro-i duction of the sign is attached. Stock #CAU-?P-ll-5 signs are made of non-corrosive, non-con- .ductive Brady B-450 linear polyethylene. The' contrasting - color black and yellow signs can be used indoors or outdoors and have built-in ultraviolet light inhibitor for long life. They are mechanically mountec| with fasteners. These 14Mx20M tough, durable signs are priced at $3.99 on, (10-40 quantity) and $3.79 each in 50-99 quantities, F.O.B.* Milwaukee, Wise, or from any Brady Distributor listed on the enclosed sheet. . A copy of our latest catalog MS-520 is also enclosed for your review of OSllA marking requirements. Wo look forward to receiving orders for your OSHA .marking ncods. V 1(2)1 Yours, truly, W. H. BRADY CO. ASBESTOS DUST HAZARD P. G. Genglerw Sales Manager Industrial Products Division AVOID BREATHING DUST WEAR ASSIGNED PROTECTIVE EQUIPMENT DO NOT REMAIN IN AREA UNLESS YOUR WORK REQUIRES IT BREATHING ASBESTOS DUST MAY BE HAZARDOUS TO ` * YOUR HEALTH i.;i eXHi^'T ILL: 9-1 FRICTION MATERIALS STANDAF"* INSTITUTE, INC., E-210 ROUTE ' PARAMUS, N.J. 07652 EPA EMISSIONS STANDARDS FOR ASBESTOS - A DISCUSSION The following comments are digested from a June 1973 discussion of an Asbestos Study Committee meeting at the Institute. These comments may be of some interest .to those filing the ERA Source Reports. Chile the new EPA emissions standards appear to be reasonable, there is some dif ficulty in interpretation. For example, the standards are not simply "No visible emissions," but (l) there could be no visible emissions even if they do not meet . the air cleaning requirements, or (2) one could even have visible emissions if they were using a collector with the specifications recommended by the EPA. In other words, if you have the EPA's recommended collector you could possibly have visible emissions and still be complying with the EPA requirements. It goes with out saying, that interpretation of the requirements by individuals in the different EPA regions may vary quite a bit. The EPA is saying in their Standards that the wet collector is not as-efficieni as the dry-bag collector- If an EPA Enforcement Officer sees a vapor from the stack where- a wet collector is used, the" source best be able to pruve thei e is no asbestos being discharged. In other words, it can be inferred that if a source has wet collectors they may more likely be cited for visible emissions. Chile it is apparent that the EPA's emissions standards promote the dry collection of asbestos in bags, many problems have been indicated with these collectors. One of the problems was repeated fires in the collection systesw Another member stated that he too had this problem until, cigarette smoking was banned in the factory. Since discontinuing smoking in the factory, he claims they have not had more than one or two fires in the last 25 years. Another member said that may be, but they have had the No Smoking rule for many years and they still have fires. This party blames the fires on the incentive program where the workers receive a bonus for exceeding certain work standards. This promotes the taking of heavier cuts with grinding*wheels and creates sparks which apparently promote the fires in the'systenu The operation that has not had any fires for the past 25 years does not have an incentive system and does not permit smoking in the work place- Ehere the wet collectors are now in use, apparently the ffA is permitting their use as complying with~the requirements.' ~ At this point, the disposal of the materials picked up by the collectors was brought up. One member sent the dust to a pelletizing machine. In this process they add 5/s-10% cement to the pelletizer. A volume reduction in the order of 3 to 1 was developed. The pellets are taken by truck and dumped as land fill. While the pellets could be broken down into a powder, if they receive reasonable handling they can be readily moved fromthe pelletizing machine to- the land fill operation. It is this member's intention to install a vacuum system from the collecting areas to go to a central pelletizing machine. One member described his handling of dust from (l) a central collector, to (2) a screw conveyor, to (3) a truck, and to (4) the land fill. The workers in this case use respirators. ' The pelletizing operation not only reduces the transportation cost by three times but eliminates the need for the v/atering truck and an individual to wet down the land fill. However, the costs of this pelletizing equipment are substantial. A manufacturer of pelletizing equipment is Ferre Tech Inc., 1231 Sanksville Road, Pittsburgh, Pa. 15216. EXHIBIT III . - - - 2- V Several members mentioned that in dealing with the EPA Regional 0: ces they were having difficulties deciding what was a "new source"and what was ar "existing source." Also, where one manufacturer adds one machine to an existing collection system he may not be in compliance without getting a Waiver of Compliance. Appar ently the EPA will not give, a Waiver of Compliance that will take more than 12 months to complete. An applicant must give the steps to be taken and the schedule to be met. When each cate arrives, the applicant must advise EPA concerning completion of that stage of the schedule. One member felt that we should review the EPA source report form to get a better understanding of what they were calling for. Page one of the report would be used for each factory. As there would most likely be several points of emission, page 2 would be completed for each stack or collector that emits asbestos. If a manufacturer wished to make an addition or modification in his plant withequip^ meni that might put asbestos into the atmosphere, he must file with the EPA. On page 1 of the report he would cross off the words "Source Report1* and type in - either "Application to Construct a New Source," or Application to Modify Existing Source." In reviewing page 2 of the report under "Process Descript ion," some questions came up as to how to complete this section. One member who had worked on this report with the EPA said you should enter here the type of machinery used with out quantifying. Another member indicated that the EPA insisted that he list the type of equipment and. the. numbers of each pit-ae^of equipment, if* the EPA specific ally said to list the nmnfcr<w=ranri- iypp,cFiit in ihistsection it was. sug gested that they would have said so on page 2 of the report. The question of put--ting down the numbers and types of equipment could become very cumbersome where a manufacturer wished to move a grinding machine from a location with one collector to another location where it would be hooked into another collector. The member who filed v/ith the EPA worked on reports in 2 different jurisdictions; New York and Tennessee. He indicated that at neither location did he enter the number of pieces of equipment on this form. (Since the meeting he called to advise that the application filed in Tennessee without quantities was accepted by the EPA. His application in New York State had not been either accepted or rejected as of ibrne L, 1973.) It would appear that Regional Offices are not in agreement as regards quantification of the equipment under the "Process Description." .. The question came up concerning interpretation of question 3, the "Amount of Pollu- tant."* In many factories a set of dry mix brake blocks could emit into a collection system at the mixer, at the briquette press, at the cut-off wheels, at grinding,, at drilling, and at inspection and boxing. The problem is that this rs the same orig inal asbestos which entered the process and might be counted 6-8 times. Sq, in effect, a factory taking in one million pounds of asbestos might list one million pounds of asbestos going into 8 different collection systems. This, in turn, would make it appear that eight million pounds of asbestos is going into the operation. From the wording of the form, it v/ould appear that this is exactly what the EPA wants. However, another member was told that this is not what the EPA wants. Ke suggests that if a factory takes in one million pounds of asbestos into the process that it should not report in total more than one million pounds of asbestos. If he had 10 different emission points, he would divide the one million pounds of asbestos by *0 to give the "amount of pollutant." Again, their apparently has been adiffef-r ence . in interpretation from different Regional Offices of the E?A. On page 3 of the report, under "Waiver of Compliance," it was stated that Sections 2a and 2b did not have to be completed unless EPA specifically requests this in-- formation. /\ SIMPLIFY LABELING OF ASBESTOS PRODUCTS AND ASBESTOS WASTE MATERIALS --' ... :s rtjST. *:*'= ' BUST C^JSE SEJviiUS . . + .% /.. ?, . .MG. vm r-.t'.! i7 .' fH ?% *1 !1 - - i >n -j . CGN'TA'^' >-* ^ZST05 c: dcst^ Aii 3*52 nu. ' *--.y c 4*. r- SEf.iO'J-- 1C Z.L. HAKlVi V *: , *^. * ^i #-v r * *. :* f:;< i ^. \ Ci No extra labels to buy or put on. No tags to come off. No labels to come unglued. o OSHA specified wording printed directly oa bag. e Continuously and conspicuously displayed. Yellow lettering oa a green background. -- o Available in two sizes and two. thicknesses. Ideal for waste such as stripped insulation, scraps, etc. Strong, durable polyethelene bags are available in two sizes. 30"x4S" and cO"x37', and two thick nesses, 0.002 and 0.004 inches. These bags were conceived as a workable solution to labeling asbestos waste according to OSHA 1910.53a. You will discover they have many other uses such as consolidating storage space for preformed asbestos insulation when removed from shipping boxes, and transparent soiled coveralls to laundry facilities once used in asbestos work. Order today from: LOSS CONTROL PRODUCTS OF HOUSTON P. O. Box 52742 HOUSTON, TEXAS 77052 CURRENT FRICK l.1ST AS OF AIIR. 15. 1974W-* POI/YTTHEI.KNI-: BARS WITH ASBESTOS UARWTKf.* LABEL Flat Bags. Bottom Weld Total Quantity per Order 1,000 2,500 5*000.. 10,000 Cost per Rase(2001/Cost per 1000 .004'' thickness 002" thickness 30" x 48" 30" x 37" 30" x 48" 30" x 37" 53.60/268.00 42.00/210.00 29.00/145.00 23.50/117. 52.90/264.50 41.68/208.40 ,28.50/142.50 22.75/113. 521007260.00 41.00/205^00.- 28. 00/140.00 22.35/111. 51.90/259.50 40.80/204.00 27.75/138.75 22.15/110. Mininum Order -- 1 case of 200 bags Prices F.O.B. Houston, Texas 7 inch twist ties -- $1.50 per 1000 ,--*Due to supply difficulties and pricing changes of raw materials caused by the fuel shortage, prices are subject to change without notice. Current prices are available upon request. '' LOSS CCKiF.OL rROuuwS GF HOUSTON P. 0. Box 52742 Houston, Texas 77052 Samples sent upon request