Document KJEM93Eve21mjEp483ROByqw2

MEMORANDUM TO: FROM: DATE: COPY PLANT PHYSICIANS PLANT SAFETY DIRECTORS E. C. Irby, M.D. January 4, 1973 Cole, R. E. Hughes, J. S. Kinzey, J. M. MacMillan, R. H. Mansur, D. B. Mortimer, R. B. Newman, J. E. Nichols, S. J. Sansonetti, Bob Sasser. I am enclosing a memo which I have recently sent to all of the plant managers and which I believe you will find is self-explanatory. Needless to say, if you can think of areas which might show high asbestos counts I would be very much interested in knowing of them. ECI /aw Enclosure M.D Associate Medical Director TX TIMER RMC0086268 003578 M EMOR A N D U M TO: FROM: SUBJECT: PLANT MANAGERS E. C. Irby, M.D. Compliance with OS January 4, 1973 Within the next several weeks our Industrial Hygiene Depart ment expects to have the capability of doing asbestos counts on air samples. This is being set up in conjunction with the Metallurgical Research Department. I am enclosing a Xerox copy of the asbestos regulations as published by OSHA in the Federal Register. As you can see, the Act was effective as of July 7, 1972, and allows for 5 fibers per cc over an eight hour time weighted average. This will become 2 fibers in 1976. No employee shall be exposed at any time to more than 10 fibers and then it goes on to specify the methods of compliance and protective equip ment . At this time, we have no asbestos counts and no serious estimates as to what the counts might be in our various asbestos using areas. Since personal sampling devices will be needed and there is a limit to the number of counts that can be performed, we feel the first order of priority should be at the work station of the carpenters in our cast houses where asbestos is machined and in the areas where asbestos cement is handled. To this end, our hygienist will be doing some studies at McCook and Liberty Mutual Insurance Company's hygienist plans some studies in Arkansas and Alabama. We also have plans to measure levels in the area where asbestos insulation either is being removed or installed as insulation for piping. If there are any other operations which might exceed the levels in the areas described above, we would very much like to hear from you and place these also at the top of our priority list. When we have sufficient measurements to be reasonably sure of our asbestos levels, we plan in conjunction with the Safety Department and Engineering Department, to help advise you concerning any measures which might be necessary to comply with the OSHA regulation. In the meantime it is hoped that the obvious portions of the Act will be complied with, such as using wet methods where possible, keeping asbestos bags closed when not in use, and disposing of them promptly when they are empty, and using all means of ventilation and exhaust which might be available. a s'/ E. Claiborne Irby, M\D. Associate Medical Dirfector 003579 TX TINER RMC0088269 22142 RULES AND REGULATIONS TX TINER RMC0086270 Tabu Cl-J Material S-hourtlme welghred average Acceptable ceiling concetitratloa Acceptable maximum peak above the acceptable ceiling concentra- non lor an S-hour shill. -- Concentration Maiimtim duration Bentene |Z37.-19C!".................................... lOp.p.m___ ___ 23 p.p.m............... 50 p.p.m........ 10 minutes. Beryllium and bcry-llium compounds 2g.;Jl*....... :s ............. 30 minutes. t Z37.2-.*-1`-`70). Cadmium fume (737.3-1070)..--.......-- 0.1 mg./M1.,...... 3 mg./M*............ Cadmium du*t (Z37 5-1970)........ ............ . 0.2 mg./M*...___ 0.6 mf./M*............ Carbon di*uliile tZ37 3-1908).............. 20 p.p.m___ 100 p.p.m........... Do. Carbon tcuachlonde {Z37.17-1967)......... 10p.p-m___ 200 p.p.m........... 3 minutes In any 4 hours. Ethylene dibromide (737.31-1970).......... 20 p.p.m___ 50 p.p.m............. 6 mlnutrs. Ethylene dichlonde (Z37..*1-1969).............. .. 50p.p.m.... 200 p.p.m........... 8 minutes In any 3 hours: FormaldHivde (Z37.13-1067)........................ 3p.pmi....... 10 p.p.m........ 30 minutes. Hydrogen fluoride (Z37.28-1960). .......... Fluoride as dust (Z37.38-1969)............. 2.8 m./M*... Lead and Us inorganic com pounds (237.11- 0.2 ni|./M'~. 1969). Mathyl chloride (Z37.18-1969)...................... 100 p.p.m... .. 200 p.p.m.............. 300 p.p.m........... S minutes in any 3 hours: Mathylen* Chlorlda (237.3-1969)................. 500 p.pja... .. 1,000 p.p.m........... 2.000 p.p.m........ 3 minutes In any 2 hours. Orctmo (alkvll mercury ,237.30-1969)......... 0.01 mg./M *. .. 0.04 mgTM *.......... Styrene (Z37.13-1969).................................... 100 p.p.m... .. :oop.pjn.............. 600 p.p.m........... 3 minutes Its any 3 hours. Trichloroethylene (Z37.19-1967)................... 300 p.p.m........... 3 minutes In any 2 hours. 3 minutes In any 3 hours. Toluene (237.12-1367)................................ 200 p.pun... Hydrogen sulfide (Z37.2-1966)............... 300 p.p.m.......... 10 minutes. 30 p.pma............. 10 minutes once only It no other measur able exposure occurs. Mercury (7.37.S-1971)...............................................................1 m*./10M Chromic acid end chrometee (Z37.7-1971).................................... dot----- Table 0-3--Minebal Dusts Substance Mppcl Mg/M* Aerodynamic diameter (unit density spheral Percent passing elector Civstalllnc: Quarts (respirable).............. __ 230* lOmf/M* %SlOr+* 7rSIOr4-2 Quartz (total dust)......... ...... ........... 30mg/Bt> Cristobelite: Use H the value calculated from the count nr mass formulae lor quarts. Tridtmite- Use W the value cumulated from the for mulae for quarts. Amorphous, including natural diaiomaceous earth............... a %SeOr+2 20 SOmi/M* %S10s Silicates (less than 1% cry* talline tilica): Mica.................................... . 20 Soapiione............................. 20 Taic (non-asiiestos-fcrm)... - 20* Talc (i hrous). Use asbestos limit .. ___ _ Tremulite (see talc, fibrous) Portland cement........................ Graphite '.natural)................. IS Coal dust irrspirahie fraction less than 3% SiOil................................. For more than 3% 3iOi____--........... .. tf 2.4mg/M* or lOmg/M* tert or Nuisance Dust: Respirable fraction............ Total dust............................ %SlO+3 18 Srag/M* 30 13mg/M* Note: Conversion (acton-- mppclx33.3-mi!llon particles per cubic meter -parudes per c.e. Millions of particles per cubic foot of air. based on lmpinger samples counted by light-held teehiucs. 1 The percentage of crystalline silica In the formula Is the amount determined from air-borne samples, ex cept In those instances in which other methods have been shown to be applicable. i As determined by the membrane filter method at 430xphase contrast mncnirieiitinn. Both concentration anil percent quarts for the appli cation of this limit arc in lie determined from the fraction passing a size-selector with the following characteristics: Containing < 1% quartz; if > l% quartz, use quartz limit. 3 90 2.5 75 3s.o5 50 25 10 0 The measurements under this note refer to the use of an AEC instrument. If the respirable fraction o( coal dust Is determined with e J1RE the figure corresponding to that of 2.4 Mg/M* in the table for coal dust is i.3 Mg/M*. rTl910.93. Asbestos. (a) Definitions. For the purpose of this section, (1) "Asbestos" includes chrysotlle. amosite, crocidolite, tremollte, anthophyllite, and actinollte. (2) "Asbestos fibers" means asbestos fibers longer than 5 micrometers. (b) Permissible exposure to airborne concentrations of asbestos fibers--(1) Standard effective July 7, 1972. The 8-hour 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 centimeter of air, as determined by the method pre scribed 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 exposed shall not exceed two fibers, longer than 5 micrometers, per cubic centimeter of air, as determined by the method pre scribed 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 10 fibers, longer than 5 micrometers, per cubic centimeter of air, as determined by the method pre scribed in paragraph (e) of this section. (c> Methods of compliance-- 11 rtgineering methods. * i > Engineering con trols. Engineering controls, such as. but not limited to. isolation, enclosure, ex haust ventilation, and dust collection, shall be used to meet the exposure limits prescribed m paragraph (b) of this section. fii) Local exhaust ventilation, (a) Local exhaust ventilation and dust col lection systems shall be designed, con structed, installed, and maintained in accordance with the American National Standard Fundamentals Governing the Design and Operation of Local Exhaust Systems. ANSI Z9.2-1971. which is in corporated by reference herein. U See S 1910.6 concerning the avail ability of ANSI Z9.2-1971. and the maintenance of a histone file m connec tion therewith. The address of the Amer ican National Standards Institute is given in i 1910.100. (iil) Particular tools. All hand-op erated and power-operated tools which may produce or release asbestos fibers in excess of the exposure limits pre scribed in paragraph (b> of this section, such as, but not limited to. saws, scorers, abrasive wheels, and drills, shall be pro vided with local exhaust ventilation sys tems In accordance with subdivision fil) of this subparagraph. (2> Work practices--(1) 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 ex posure limits prescribed in paragraph (b) of this section, unless the usefulness of the product would be diminished thereby. <U) Particular products and operatiOTis. No asbestos cement, mortar, coat ing, grout, plaster, or similar material containing asbestos shall be removed from bags, cartons, or other containers in which they are shipped, without being either wetted, or enclosed, or ventilated so as to prevent effectively the release of airborne asbestos fibers in excess of the limits prescribed In paragraph (b) of this section. (iil) Spraying, demolition, or removal. Employees engaged in the spraying of asbestos, the removal, or demolition of pipes, structures, or equipment covered or insulated with asbestos, and in the removal or demolition of asbestos in sulation or coverings shall be provided with respiratory equipment in accord ance with paragraph (d)(2) (iil) of this section and with special clothing in ac cordance with paragraph (d)(3) of this section. (d) Personal protective equipment-- (1) Compliance with the exposure limits prescribed by paragraph (b) of this sec tion may not be achieved by the use of respirators or shift rotation of em ployees. except: (I) During the time period necessary to install the engineering controls and to institute the work practices required by paragraph (c) of this section: (II) In work situations in which the methods prescribed in paragraph (c) of ,FEDERAL REGISTER, VOL 37 NO. 202--WEDNESDAY, OCTOBER II, 1972 003580 RULES AND REGULATIONS tins -cc'.ion are either technically not feasible or feasible to an extent insuffl- cient to reduce the airborne concentra tions of asbestos fibers below the limits prescribed by paragraph t> of this section: or iii> In emergencies. i;v> Where both respirators and per sonnel rotation are allowed by subdivi sions i *. 'll1, or i til1 of this subpara graph. and both are practicable, person nel rotation shall be preferred and used. i 2) Where a respirator is permitted by subparagraph U> of this paragraph, it shall be selected from among those ap proved by the Bureau of Mines. Depart ment cf the Interior, or the National In stitute for Occupational Safety and Health. Department of Health. Educa tion. and Welfare, under the provisions of 30 CKR Part 11 i37 F.R. 6244. Mar. 25. 19721. and shall be used in accordance with subdivisions >i'. 'ii'. <iii'. and <iv> of this subparagraph. ii> Air purifying respirators. A reusa ble or single use air purifying respirator, or a respirator described in subdivision >ii) or i nil of this subparagraph, shall be used to reduce the concentrations of airborne asbestos fibers m the respirator below the exposure limits prescribed in paragraph ib> of this section, when the ceiling or the 8-hour time-weighted aver age airborne concentrations of asbestos fibers are reasonably expected to exceed no more than 10 times those limits. i ii' Powered air purifying respirators. A full facepiece powered air purifying respirator, or a powered air purifying respirator, or a respirator described in subdivision nil) of this subparagraph, shall be used to reduce the concentra tions of airborne asbestos fibers in the respirator below the exposure limits pre scribed m paragraph <b) of this section, when the ceiling or the 8-hour timeweighted average concentrations of asbestos fibers are reasonably expected to exceed 10 times, but not 100 times, those limits. i ui) Type "C" supplied-air respirators, continuous flow or pressure-demand class. A type "C" continuous flow or pres sure-demand, supplied-air respirator shall be used to reduce the concentra tions of airborne asbestos fibers in the respirator below the exposure limits pre scribed in paragraph <b) of this section, when the ceiling or the 8-hour time- weighted average airborne concentra tions of asbestos fibers are reasonably expected to exceed 100 times those limits. i iv i Establishment of a respirator pro gram. ia) The employer shall establish a respirator program in accordance with the requirements of the American Na tional Standards Practices for Respira tory Protection, ANSI Z88.2-1969, which is incorporated by reference herein. b. See 1910.6 concerning the avail ability of ANSI Z88.2-1969 and the main tenance of an historic file in connection therewith. The address of the American National Standards Institute is given in 5 1910.100. <c> No employee shall be assigned to tasks requiring the use of respirators if. based unon his most recent examination, .in examining physician deiertnmr-, that the employee will be unable 10 function normally wearing a respirator, or Unit the safety or health of the emp'ovec or other employees will be impaired bv his use of a respirator. Such employee -hall be rotated to another job or zivcn the opportunity to transfer to a dillereiu po sition whose duties he is able to perform with tile same employer, m the same geo graphical area and with the same senior ity. status, and rate of pay he had just prior to such transfer, if such a d.-Tcrem position is available. '3 > Special clothing: The etnnlover shall provide, and require the use of. spe cial clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot covermgs for any em ployee exposed to airborne concentra tions of asbestos fibers, which exceed the ceiling level prescribed in paragraph * to' of this section. 14) Change rooms: <i> At any fixed place of employment exposed to airborne concentrations of asbestos fibers in ex cess of the exposure limits prescribed m paragraph <b) of this section, the em ployer shall provide change rooms for employees worlcing regularly at the place. <ii). Clothes lockers: The employer shall provide two separate lockers or con tainers for each employee, so separated or isolated as to prevent contamination 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 ex posure limits prescribed in paragraph > b) of this section. (b) Any employer who gives asbestoscontaminated clothing to another person for laundering shall inform such person of the requirement in (a) of this subdi vision 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 para graph (g) of this section. (e) Method of measurement. All de terminations of airborne concentrations of asbestos fibers shall be made by the membrane filter method at 400-450 x (magnification) (4 millimeter objective) with phase contrast illumination. (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 determine whether every employee's exposure to asbestos fibers is below the limits pre scribed in paragraph (b) of this sec tion. If the limits are exceeded, the em ployer shall Immediately undertake a compliance program in accordance with paragraph (c> of this section. (2) Personal monitoring--(i) Sam ples shall be collected from within the breathing rone r,l Uic employees, on membrane fill'-'. of O ': -r.:' ron-.ctcr poitx.ity mounted ;:i mi open-fare filler holder. Samples shall be takrn lor tiic determination oi the 8-hour t:meweiGhted average airborne concentra tions and of the ceiling concentrations ot a.-bestos fibers. ii' Sampling frequency and patterns After the initial determinations required by subparagraph * 1 > of this paragraph, samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of em ployees. In r.o case shall the .sampling be done at intervals greater than 6 months for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph b > of this section. <3> Environmental monitoring--n> samples shall be collected from areas of a work environment which are represent ative of the airborne concentrations of asbestos fibers which may reach the breathing zone of employees. Samples shall be collected on a membrane filter of 0.8 micrometer porosity mounted in an open-face filter holder. Samples shall be taken for the determination of the 8hour time-weighted average airborne concentrations and of the ceiling con centrations of asbestos fibers. up Sampling frequency and patterns. After the initial determinations required by subparagraph <1> of this paragraph, samples shall be of such frequency 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 ui para graph <b) of this section. ' 4 > Employee observation of monitor ing. Affected employees, or their rep resentatives. 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. `1> Cau tion signs, (i) Posting. Caution signs shall be provided and displayed at each location where airborne concentrations of asbestos fibers may be in excess of the exposure limits prescribed in paragraph 'b> of this section. 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 be fore entering the area marked by the signs. Signs shall be posted at all ap proaches to areas containing excessive concentrations of airborne asbestos fibers. (11) Sign specifications. The warning signs required by subdivision it) of this subparagraph shall conform to the re quirements of 20" x 14" vertical format signs specified in 11910.145(d)(4), and to this subdivision. The signs shall dis play the following legend in the lower panel, with letter sizes and styles of a visibility at least equal to that specified in this subdivision. TXTINER RMC0086271 ft/nCQI FEDERAL REGISTER, VOL 37, NO. 202--WIDNISOAY, QCTOIER II, 1972 22144 RULES AND REGULATIONS TX TINER RMC0086272 Legend Asbesta* ________ Dust Hazard Avoid Breadline Dus: -- Wear Assigned Protective Equipment. Do Not Remain In Area Unless Your Work Re quires It. Breathing Asbestos Dust May Be Hazardous To Your Health. Notation 1" Sans Serif. Gothic or Block. " Sans Serif. Gothic or Blocs. V Gothic. " Gothic. V Gothic. 14 point Gothic. Spacing between lines shall be at least equal to the height of the upper of any two lines. <2' Caution labels--(D Labeling. Cau tion 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 reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentra tions of asbestos fibers in excess of the exposure limits prescribed in paragraph (b > of this section will be released. (ii) Label specifications. The caution labels required by subdivision (i) of this subparagraph shall be printed in letters of sufficient size and contrast as to be readily visible and legible. The label shall state: Caotiok Contains Asbestos Fibers Avoid Creating Dust Breathing Asbestos Dust May Cause Serious Bodily Harm (h) Housekeeping--(1) Cleaning. All external surfaces m any place of employ ment shall be maintained free of accu mulations 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 cloth ing. consigned for disposal, which may produce m any reasonably foreseeable use. handling, storage, processing, dis posal. or transportation airborne concen trations of asbestos fibers in excess of the exposure limits prescribed in paragraph <b) of this section shall be collected and disposed of in sealed impermeable bags, or other closed, impermeable containers. (i) Recordkeeping--(1) Exposure rec ords. Every employer shall maintain rec ords of any personal or environmental monitoring required by this section. Rec ords shall be maintained for a penod of at least 3 years and shall be made avail able upon request to the Assistant Secre tary of Labor for Occupational Safety and Health, the Director of the National Institute for Occupational Safety and Health, and to authorized representa tives of either. (2) Employee access. Every employee and former employee shall have reason able access to any record required to be maintained by subparagraph (1) of this paragraph, which indicates the em ployee's own exposure to asbestos fibers. (3) Employee notification. Any em ployee found to have been exposed at any time to airborne concentrations of asbes tos fibers in excess of the limits pre scribed m paragraph ib> of this section shall be notified in writing of the expo sure as soon as practicable but not later than 3 days of the finding. The employee shall also be timely notified of the cor rective action being taken. (j) Medical examinations--(1) Gen eral. The employer shall provide or make available at his cost, medical examina tions relative to exposure to asbestos re quired by this paragraph. (2) Preplacement. The employer shall provide or make available to each of his employees, within 30 calendar days fol lowing his first employment in an occupation exposed to r.irborne con centrations of asbestos fibers, a compre hensive medical examination, which shall include, as a minimum, a chest roent genogram < posterior-anterior 14 x 17 inches), a history to elicit symptom atology of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEVi -). (3) Annual examinations. On or be fore January 31. 1973. and at least an nually thereafter, every employer shall provide, or make available, comprehen sive medical examinations to each of his employees engaged in occupations ex posed to airborne concentrations of as bestos fibers. Such annual examination shall Include, as a minimum, a chest roentgenogram (posterior-anterior 14 x 17 inches). a history to elicit symptom atology of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEV,). (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 occupation exposed to airborne concentrations of asbestos fibers, a comprehensive medical examination which shall include, as a minimum, a chest roentgenogram (pos terior-anterior 14 x 17 inches), a history to elicit symptomatology of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEV,.). (5) Recent examinations. No medical examination is required of any em ployee. if adequate records show that the employee has been examined in ac cordance with this paragraph within the past 1-year period. (6) Medical records--(1) Mainte- nance. Employers of employees examined pursuant to this paragraph shall cause to be maintained complete and accurate records of all such medical examina tions. Records shall be retained by employers for at least 20 years. (11) Access. The contents of the rec ords of the medical examinations required by this paragraph shall be made available, for inspection and copying, to the Assistant Secretary of Labor for Occupational Safety and Health, the Director of NIOSH. to authorized phyi- cians and medical consultants of either of them. and. upon the request of an em ployee or former employee, to his physi cian. Any physician who conducts a medical examination required by this paragraph shall furnish to the employer of the examined employee all the infor mation specifically required by this paragraph, and any other medical in formation related to occupational ex posure to asbestos fibers. ____ 1910.94 Ventilation. (a) Abrasive blasting--(1) Defini tions applicable to this paragraph--<i) Abrasive. A solid substance used m an abrasive blasting operation. (ii) Abrasive-blasting respirator. A continuous flow air-line respirator con structed so that it will cover the wearer's head. neck, and shoulders to protect him from rebounding abrasive. (iii) Blast cleaning barrel. A complete enclosure which rotates on an axis, or which has an internal moving tread to tumble the parts, in order to expose vari ous surfaces of the parts to the action of an automatic blast spray. (iv) Blast cleaning room. A complete enclosure in which blasting operations are performed and where the operator works inside of the room to operate the blasting nozzle and direct the flow of the abrasive material. (v) .Blasting cabinet. An enclosure where the operator stands outside and operates the blasting nozzle through an opening or openings in the enclosure. (vi> Clean air. Air of such purity that It will not cause harm or discomfort to an individual if it is inhaled for extended periods of time. (vil) Dust collector. A device or com bination of devices for separating dust from the air handled by an exhaust ventilation system. (viii) Exhaust ventilation system. A system for removing contaminated air from a space, comprising two or more of the following elements (a) enclosure or hood. (b> duct work. (c> dust collect ing equipment, (d) exhauster, and (e) discharge stack. (lx) Particulate-filter respirator. An air purifying respirator, commonly re ferred to as a dust or a fume respirator, which removes most of the dusw or fume from the air passing through the device. (x) Respirable dust. Airborne dust in sizes capable of passing through the up per respiratory system to reach the lower lung passages. (xl) Rotary blast cleaning table. An enclosure where the pieces to be cleaned are positioned on a rotating table and are passed automatically through a series of blast sprays. (xil) Abrasive blasting. The forcible application of an abrasive to a surface by pneumatic pressure, hydraulic pres sure. or centrifugal force. (2) Dust hazards from abrasive blast ing. (1) Abrasives and the surface coatings on the materials blasted are shattered and pulverized during blasting FEDEIAl MOUTH, VOL 37, NO. 207--WEDNESDAY, OCTOIEi IS, 1973 003582 March 1, 1973 MEMORANDUM: TO ALL DIVISION PRODUCTION MANAGERS As you are probably aware, one of our Reynolds' plants has recently received an OSHA citation because of employees1 exposure to asbestos fibers in excess of standards in the carpenter shop. Within' the past two or three days we have been in the process of standardizing our technique for doing asbestos counts and now feel that we are capable of reasonable accuracy. Until we can develop specific data in all of our plants where asbestos is machined or worked, there is always the possibility of violation of OSHA standards. It is there fore the recommendation of the Medical Department that machining and working of all asbestos-containing products in the company ' be prohibited until we can be sure of compliance. This, we feel, would prevent OSHA compliance officers from instructing our employees to machine this material which might be on hand and thus create a violation of OSHA standards. TXTINER RMC0086273 003583