Document KRwrVpZpaaQ6oobZ2XpLwzbLx

Pittsburgh Cornfn One Gateway Center Pittsburgh. Pennsylvania 15222 BYRL. STOUT _ Vic* Pr*icnt cf MftAuiActurinc^, ^ July 2, 1969 Hr. Wendell R. Blair Regional Director U. S. Department of Labor Bureau of Labor Standards 601 Mayflower Building Dallas, Texas 75201 Dear Hr. Blair: 'i - ' Dr. Morton Com, Professor of Industrial Hygiene, Graduate School of Public Health, University of Pittsburgh, performed an industrial hygiene survey of our Tyler, Texas plant recently. A copy of his report which you requested in your June 16 letter is attached. All persons working in areas where the report shows dust levels in excess of the threshold limit values have been required to wear a dust *"; respirator approved by the U. S. Bureau of Mines for Pneumoconiosis producing^ and for nuisance dusts. They will continue to wear such respirators until the dust exposure has been reduced to safe levels. 2^ The Central Engineering Department of ^ur company, with the assistanqy*T of Dr. Com, has initiated a design program for complete dust control and - collection in this plant. The total program including installation is ,-J.. scheduled for completion by mid-February, 1970. J'TM -U s If you need additional information, please advise. Yours very truly. PITTSBURGH CORNING CORPORATION o r-` :! BMS/rb Attch. cc: Dr. L. B. Grant, M.D. Mr. H. C. Underwood (attch.) Mr. J. H. Bierer Mr. E. W. Holman Mr. C. E. van Home PITTSBURG H Byrl H. Stout Vice President of Manufacturing few*.- : . CORNING ' -i ^ - -7.- * r r V A s' A REPORT ON INDUSTRIAL HYGIENE SURVEY OF SELECTED PLANT OPERATIONS Tyler Plant, Pittsburgh-Coming Corporation Tyler, Texas May 7, 1969 by . Morton Corn, Ph-D. rv S i f- GG i9988 BB|0009046 | r- - .v f. *;:r* vr>y '-7 j** fft r TABLE OF CONTENTS Page I. II. INTRODUCTION ............................................................................................................. 4 SUMMARY AND RECOMMENDATIONS .............................................. .... 1 3 III. THRESHOLD LIMIT VALUE FOR ASBESTOS .......................... ... S IV.' DESCRIPTION OF SAMPLING AND ANALYTICAL METHODS ... 8 V. RESULTS AND DISCUSSION................................................................................. VI. ACKNOWLEDGEMENT.................................................................................... 11 . 21 ... APPENDICES APPENDIX A: 1. Letter from W. R. Blair, Regional GO UJ >C- c Director, U. S. Department of Labor, Dallas, Texas, to J. H. Bierer. 2. Letter from B. M. Stout to W. R. Blair. '. 3. Letter from . Corn to W. R. Blair' APPENDIX B: Duct Velocity Determinations (Primary ^ Data and Calculations) .^ M' APPENDIX C: Photographs of Selected Plant Oper- ations . O . c r Cfr \o989 | BB 0009047 J i- F V - Ar A. o c C I. INTRODUCTION A survey to determine the adequacy of the existing ventilation system and associated dust collection equipment to control air borne dust was performed in the production area of the PittsburghComing Tyler, Texas plant on May 7, 1969 by Dr. Morton Corn. Dr. Corn was accompanied and assisted by Mr. John L. Hyde, of the En gineering Section, Pittsburgh-Corning Research Center, 800 Presque Isle Drive, Pittsburgh, Pennsylvania 15239. The survey was per formed at the request of Mr. Byrl M. Stout, Vice President of Manu facturing, Pittsburgh-Corning Corporation. The request was made on April 28, 1969 at the Pittsburgh-Corning Research Center during a meeting called to discuss the enclosed citation of the Tyler plant by the Department of Labor (see Appendix A). The survey was concentrated exclusively on assessment of hygienic risk to airborne amosite asbestos dust and evaluation of plant facilities i to reduce this risk. During the period of the survey outdoor weather conditions were clear, sunny and warm, with temperatures in the 70-80F range. Humidity was high. (Relative humidity in plant approximately 75%).* The author is unaware of any special precautions taken to en sure that the ventilation system was operating in anything but the "normal" mode during this survey. Therefore, results of mea surements made in this survey must be considered representative of conditions in the plant during summer months when doors.and windows are open. In general, winter conditions impose more |V* :iAjr;,;*- - - c* -f Measured at 11:45 AM in plant. GG I990 I .* * c !V 2 stringent requirements on plant dust control systems because win dows and doors are closed to preserve heat. There is no benefit of "dilution ventilation" from outdoor air. With the same facil ities for dust removal by a ventilation system, in-plant dust in air concentrations during winter months will usually exceed those present during summer months. o f-O -- 'i i GG 19991 "bB 0009049_J_ \ II. SUMMARY AMD RECOMMENDATIONS An Industrial hygiene and ventilation survey of this plant performed on May 7, 1969 suggests that asbestos fiber concentra tions are high in worker breathing zones (Builder and Feeder Op- I____ erators) and at breathing level in certain other plant locations There are no hygienic guidelines for concentration of Amosite > fibers in air and the judgment of excessive dustiness in this plant is referred to guidelines for Chrysotile dust. Utilization of hygienic guidelines for Chrysotile asbestos concentration in air for Amosite asbestos fibers in air is an accepted procedure in the U. S. at this time. The finding of excessive dustiness at "spot" sampling locations in the plant is consistent with sur-:'~; vey measurements which revealed inadequate quantities of air at L local exhaust hoods. Insufficient air at local sites of dust 'nV >--. emission was reflected in low air velocities at hood faces and low air conveying velocities in branch lines and ducts. The ven tilation system was estimated for Builder and Feeder areas to move approximately one sixth of the air required to ventilate these processes. In addition to the inadequacies of the ventilation system and the resultant excessive dustiness, it was found that general house keeping is poor in the plant. Also, during the entire day of the survey not one employee in the production area was observed to wear a respirator. In the opinion of the author, this short survey strongly suggests that employees at this plant are being exposed, on a > --'b'ooo^--* c c1 4 daily basis, to excessive concentrations of Amosite asbestos dust. It is recommended that efforts be immediately focussed on design of a complete ventilation and dust collection system at this plant. The system is rudimentary in concept and is underdesigned. Efforts to "doctor up" this system would probably lead to a less than satisfactory system and would involve expenditures in time and equipment equivalent to those associated with design of a new system. v, A wim.-,***^* W^Ar-:/' r' '^.^:-- 5 III. THRESHOLD LIMIT VALUE OP ASBESTOS DUST "The threshold limit values refer to airborne concentrations of substances and represent conditions under which it is believed that nearly all workers may be repeatedly exposed, day after day, without adverse effect. Because of wide variation in individual susceptibility exposures of an occasional individual at or even H" below the threshold limit may not prevent discomfort, aggravationjXj of a pre-existing condition, or occupational illness* :5 "Threshold limits should be used as guides in the control of" health hazards and should not be regarded as fine lines between safe and dangerous conditions."* Sr cn /!) had, The American Conference of Governmental Industrial Hygienis1^~- in 1967, a T.L.V. for asbestos of 5 million particles per LU 2E o CJ> cubic foot, as determined by impinger sampling and counting by O' light-field techniques. In a considered revision (1968), the c.nn-ZZ* ference endorsed the retention of this T.L.V. for "most forms of asbestos". However, for crocidolite, because of the production of mesotheliomas, it was recommended that workers be equipped with air-supplied helmets because "no safe limit can be established for this form of asbestos at this time." The British Occupational Hygiene society recently issued hy gienic standards for chrysotile asbestos dust.** The standards are based on the objective that the risk of contracting asbestos Cf Extracted from the Preface, Threshold Limit Values for 1968. American Conference of Governmental Industrial Hygienists, 1014 Broadway, Cincinnati, Ohio 45202. Ann. Occup. Hyg. 11, 47-69 (1968). GO l`0994 j BB 0009052^ i. A- tA 6 to the dust. By "asbestosis" the committee meant the earliest --I demonstrable effects on the lung due to asbestos. These standards ^ are cited here because they are more stringent than the U. S. - Q_ guideline referred to above. The exposure guidelines are: TABLE 1 o BRITISH HYGIENIC GUIDELINES FOR ASBESTOS DUST DUST CATEGORY Negligible Low Medium High CONCENTRATION-AVERAGED OVER 3 MONTHS Fibers/cm3 MPPCF* 0 - 0.4 0.011 0.5 - 1.9 0.014 - 0.054 2.0 - 10 0.054 - 0.28 Over 10 Over 0.28 0o The concentrations refer to fibers greater than 5 microns in length as determined by the membrane filter method. The problem faced today with respect to Amosite asbestos is that there simply is insufficient data for dosage-response pre diction of exposed populations.** The guidelines for Chrysotile will undoubtedly continue to be -the threshold limit value guide line for exposure to other forms of asbestos dust for years to' come. In a survey of dust concentrations in the Unibestos facility. Port Allegheny Plant of Pittsburgh-Coming, simultaneous impinger * Million particles per cubic foot (as fibers). ** Stokinger, H. E."Development of TLV's for Fibrous Materials." Paper presented at Special Session on Fibers, Annual Meeting of American Industrial Hygiene Association, Denver, Colorado, May, 1969. j'bB 0009053_J --C- \ C 7 and membrane filter sampling was performed. The conversion of values obtained by one method to those of the other method was not possible. At each location, the numbers of the fibers and particles varied. The impinger method is based on particles while the membrane filter method assesses only fibers. For the * purposes of this preliminary survey, either method would yield data suggesting that airborne dust concentrations were acceptable or unacceptable. Therefore, the membrane filter technique was used and the British guideline is.applicable (Table I). <P NOst; NOT COME , - ^- --i ?* v*! 3^ ' ' 5 : " J F ` (F-. ppu i~ ILtb p' - ;' ' "v t c GG Iog96 ] SB 0009054 | r L V ut IV. DESCRIPTION OF SAMPLING AND ANALYTICAL METHODS A. Assessment of Airborne Dust Samples were obtained at either worker breathing zones as they performed their routine tasks, or at breathing level to re present "background air" Samples were obtained during a five or * ten minute period at a flow rate of 21 1pm by utilizing a vacuum pump in conjunction with a filter holder and sample filter. The system was precalibrated in terms of pump inlet pressure and air flow with all sampling line components,including filter, in place. A membrane filter (Type HA Millipore) was used to obtain samples for microscopic evaluation of fiber' and dust particle concentrations. This paper is composed of pores 0.45 microns in size and has been shown to_-retarn, with 100% efficiency, par- The filter was first visually examined to detect any loose dust or uneven dust deposition. In the few cases where the fil ter deposit did not pass this examination, it was necessary to re suspend the collected dust in distilled water and refilter this suspension on VF grade Millipore filter to assure an even dust distribution over the entire filter area. A pie shaped segment of the filter was then placed on a microscope'slide and rendered completely transparent with Cargille certified index of refraction liquids. Cargille liquid of index of refraction 1.500 was usually i most suitable. The counting of the dust particles and the count ing and sizing of asbestos fibers was performed with the aid of a ^Megaw, W. J. and Wiffen, R. D.: (1963) Int. J. Air Water Poll. 1, 501 0009055_J_ I 7^3 a*, , PhJit: n NOT CQfWE FROM PPG FiL Zeiss Photomicroscope using Phase Contrast Illumination. The ob jective lens was a Zeiss Neofluor Ph 63x with a numerical aperture of 0.90. The eyepiece had a magnification of 2Ox and contained a calibrated Porton graticule. The optovar feature of the Zeiss scope contributed to the total magnification of 2016x. Resolution was approximately 0.35 microns. Particles and fibers of size 0.30 microns could be detected. In the evaluation procedure, all particles and fibers in the Porton field of view were counted and the fibers were grouped by fiber length into three categories {less them five microns,, five to ten microns, and larger than ten microns). This procedure was repeated for a number of randomly selected fields on the face of the filter. Because only a portion of the total filter area was evaluated by this method, it was necessary to correct the count by the ratio of the total filter area to the evaluated area. The resultant particle or fiber number was divided by the volume of the air sample to obtain dust or fiber concentration expressed as millions of particles per cubic foot (MPPCF). The statistical reliability of the evaluation was expressed 1/2 as the standard deviation, calculated as N ' , where N is the ' particle or fiber count. The procedure outlined follows, in its essential, points, that recommended by J. R. Lynch and H. E. Ayer in their article "Mea surement of Asbestos Exposure" which appeared in the Journal of Occupational Medicine, Volume 10, January, 1968. GG 1n993 BB~0009056 r r~" F i F STT* NQrt: ni!b 10 - _ _ _ _ COME FRum FPU HU* B. Measurement of Air Velocities at Hoods A calibrated velozneter was used to measure face velocit ies of hoods and room air velocities.* C. Air Velocities in Ventilation Ducts A standard 1/4" dameter pitot tube was used in conjunct ion with a Dwyer 1:10 inclined manometer to determine velocity pressures in ducts. Ten point traverses were taken in larger ducts (>6n diameter); centerline readings only were obtained in smaller ducts. All measurements are considered to be approximate (estimated reliability + 10%) because of the conditions imposed by the system. For example, there were few locations where measure ments could be made 10 diameters from entries or elbows. Also, - -CijtVW the standard pitot'tube should not be used in lines smaller than 8" diameter. However, the reliability of measurements achieved E-N -X'i-'V is perfectly adequate for a preliminary survey of the type under taken here. ii Alnor Velometer, Illinois Testing Laboratory, Chicago, Illinois. . GGIogc \ " * SX- ^ - BB 0009057~7 c A_ 'j-pir* r.f'pE DID j bi ,-=) - jv ji..-' ' 1 v. RESULTS AMD DISCUSSION 'hot COME FROM PPG FILES A. Airborne Dust Concentrat Measured concentrations of dust particles and asbestos fibers are summarized in Table 2. In order to facilitate com parison with the guidelines from Table 1, the-last two columns (5 and 6) of Table 2 for fiber concentrations have been added to yield Column 7, which should be compared with Column 3 of Table 1. On this basis, operators at the feeders are receiving High exposures. Builder operators are also receiving High expos ures. Although much dust is present at the cutting operation the single sample obtained suggests that particles and not fibers are the major contributors to the dispersion. Table 2 suggests that outdoor air is Negligible in terms of fiber content, as is the dust collector effluent. However, the aisle of the warehouse op posite the.Feeders is High, suggesting the large zone of influence of the dust sources in the Feeder areas. It cannot be too strongly stressed that these are "spot" samples and must be viewed as sug gestive results only. However, they do convey a picture of high dust exposures in Feeder and Builder areas, as well as in adjacent zones. The author must state, based on previous experience, that dust concentrations in plant air would almost certainly increase during winter months. B. Local Exhaust Hood Face Velocities There are design guidelines for face velocities of air at local exhaust hoods?1 In general, a face velocity of 100 fpm is k X-- r-: " . r ,.1' See Chapter 5, Industrial Ventilation, 10th Ed. American Con ference of Governmental Industrial Hygienists, 1014 Broadway, Cincinnati, Ohio. 20000 Oo9>~ Sa I-- I I to I bo I t Io I^ Iw !* I-- o *"*J C"j o m o CO CO ro C""1 j"j > rv m C/j ,r\ rs j 3^/rt* t* 5 r^AjPARJ> s ' TABLE 2 - /Vy { 5 /t-fV/Z/ ASBESTOS FIBER CONCENTRATIONS AT SELECTED PLANT LOCATIONS /- t f..fttu Dust Particle or Fiber Counts, Expressed as Millions of Particles Per Cubic Foot + Standard Deviation Total Date and Time of Sample Description of Sampling Site Particles <5 u Fibers 5-10 v >10 u (Cols. 5 + 6) .7& 5/7 2:30 PM- Breathing zone of Feeder Oper 12.3+0.6 3.60+0.28 0.64+0.12 0.14+0.04 0r$2- 3> 2:35 PM ator, Lines 1 and 2 during sweeping, feeding. (Note: * 8.2? 7.t~C cooling fan at dust collector on.) 0 5/7 5/7 2:36 PM2:46 PM 2:50 PM- Breathing level in Walkway adiacent to Feeder No. 3. Effluent from Dust Collector Bags approx. 1" from Bag. Dust collector for Lines 1 and 2. 10.5+0.5 2.9+0.2 3.40+0.19 0.71+0.09 0.34+0.06 0.06+0.03 0.14+0.04 0.02+0.02 0.48 * f +*-1 i . 0.08 a.JVs* Ti/Ui I 5/7 iAl 3:05 PM3:15 PM Outdoor air sample at breath ing level on loading dock near Oil House. 1.5+0.2 0.10+0.04 0.03+0.02 0.05+0.02 0.08 X 9't rU^i 5/7 3:15 PM3:25 PM Breathing level in aisle, Unibestos Warehouse opposite Feeder Lines 1 and 2. 35.0+1.7 1.26+0.12 0.18+0.03 0.10+0.02 0.28 /0 --c: 5/7 3:30 PM3:40 PM Breathing zone of Builder Operator, Line No. 3 (3/4 x 1 Unibestos). Cycle of load ing, building, spraying, etc. Note: Fans on over Lines 2 and 3. 3.2+0.2 1.48+0.09 0.18+0,. 03 0.10+0.02 0.2B 5/7 3:45 PM3:56 PM Breathing zone of Builder Op erator, Line No. 3. Cycle of loading, building, spraying, etc. 12.5+0.6 4.02+0.20 0.20+0.04 0.21+0.05 0.41 MS-^ o o tt (1) (2) (3) (4) (5) (6) t7) Xft /?* sUrl'Uc*^y&y&f'sjf&-/Crt*> -* j' 'j. j' ^ ^afc--`l it.. ` v :' ^ v':;il>v ; '. *? . 'L * ft ^ tmm n nn i 1 TABLE 2 (continued) t I i 5/7 4:05 pm- Breathing zone of Operator, 37.4+1.8 1.11+0.11 0.07+0.03 0.05+0.024 0.12 < 4:15 pm Large Cutting Saw. \ Note: Door adjacent to cutting operation open to outdoor air. 'i J ?4 3 (1) (2) (3) (4) (5) (6) (7) r^*^y /Jo /~z. cJ)^j?ZcS t//?/*? /Z^zr. J j */ /*/<>-- -** z&txj^yC t i H -*n- ex 7~/-i/ -- ;? ^./ /*>/>cf~. * BB 0 0 0 9 0 6 0 - '"'T" 77^ ,j >^!. l t ) l i l l t i i <r> c~> ro C c? po --r -t-' eJ{ -/Jj O )( T ^j _<iS'sc/zl^et~c?Jf. 13 5^<^/ /<W T DID rG FILESi > --J :V(i recommended for control of fume and vapors, while higher veloci ties are not uncommon for control of materials emitted with great force. At the Port Allegheny Plant, Mr. John Hyde, of Pittsburgh- Coming, and the author are designing for 200 fpm face velocity at hoods which interface with plant air: designed for 100 fpm. internal process hoods are * Table 3 is a summary of measured air velocities at selected hoods in the Tyler Plant. With the exceptions of the Builder hoods and the Scrap Grinder hood, face velocities at' hoods are inadequate. Smoke tube tests performed at each hood offered visu al confirmation of this conclusion based on velocity measurements. Although the hood on the Intermediate Saw was satisfactory, it would not be so if two or more saws were used simultaneously. C. Air Flow Associated with Local Exhaust Hoods and Dust Collectors Figure 1 is a line diagram of the ventilation ducts in the Feeder and Builder Areas. The duct locations for Pitot tube tra verses are denoted by numbers. Table 4 is a summary of volume of air flowing at these points as determined on the day of this survey. The values listed in Table 4 are probably overestimates because cer tain of the ducts were partially clogged with settled fibers. All data and calculations for the Table 4 summary are included in Ap pendix B. Table 4 and data in Appendix B indicate the following: 1. Air is very poorly distributed in the ventilation system. As an example, hoods 2, 3 and 4 for similar operations were allo cated 63, 391 and 202 cfm respectively. I BB 0009061 | l< - r. IS NOTE: THIS DOCUMENT DIDpbs TABLE 3 l rr G FILES UNIBESTOS LINES: SUMMARY OF HOOD AIR VELOCITIES Location Site of Measurement* and Average Air Velocityr fpm** Line No. 1 40* Fiber Feeder* Left Side Center Right Side Top Middle Bottom Top Bottom Top Bottom 0 0 0 50 50 0 0 Note: Smoke tube test revealed poor control. text- Line No. 1 30" Fiber Feeder* Left Side Center Right Side Top Bottom Top Bottom Top Bottom 20 20-30 60 60 60 50 v, '*>**. U -v Line No. 1 30" Fiber Feeder* Left Side Top Middle Bottom 20 0 0 Center Right Side Top Middle Bottom Top Middle 20 0-10 0-10 20-30 30 Line No. 1 40" Fiber Feeder t Left Side r Center Right Side Top Middle Bottom Top Middle Bottom Top Middle Bottom 0 0 0 10 10-30 10-30 0 20 20 Line No. 2 40" Fiber . Feeder (Note: Approx. 75% of hood face blocked by fiber) Left Side Center Right Side Too Middle Bottom Top Top Bottom 50-100 75-100 75-100 30-40 30 50 Koom air in vicinity of feeders measured to be 30-40 fpm. South to North (fans off). Room air in vicinity of feeders measured to be 300 fpm. South to North (fans on). GG ZKSM W. ^ jgr'v r- =. l"ST00MW2_i F- _ * r*-'-<v % '`v-: c -c?"N- jS5?V- NOTE: THiS DOCUM-MT D!Q NOT COME FROM PPG FILES TABLE 3 (continued) Line No. 2 30" Fiber Feeder Stand by (not in use) Line No. 2 30" Scrap Feeder - Left Side Center Right Side Left Side Center Right Side Top Middle Bottom Top Kiddle Bottom Top Middle Bottom Top Bottom Top Middle Bottom Top Bottom 10-50 30 20 20 40 30 0 40 20 75-100 100 100 . 100 75-100 125 75-100 Line No. 3 20" Scrap Feeder Left Side Right Side Top Bottom Top Bottom 0 20-30 0 30-40 Builder Hoods . Line No. 2 Line No. 3 Line No. 1 125-150 150 Invalid measurements because instrument could not be properly placed. Smoke tube revealed good control. Scrap Grinder Hood Left Side Center Right Side Top Middle Bottom Too' Middle Bottom Top Middle Bottom Saw Area: Intermediate Saw+ 75-100 100-150 150 75 75-100 100 50-75 50-75 50-75 200-300 +Large Rip Saw Off. * "' All measurements in vertical plane at hood specified. ** Feet per minute. face, unless otherwise GG Losssrr $ r\ .n t: LINE 3 I i ili I CD I 1 iiI ssiiI;:! if i i^i i-- i 7 j2j 1 U-Mpj/'S- : U ! -LV y'l t. :' i ;; ' i *1 ^ l<,,d ; CD CD no /'**V cn ! :-.S OV'Ai Figure 1 Schematic of Unibestos Lines Showing Ventilation System and Pitot Traversa Poi<n& 'VOt Tyler Plant, Pittsburgh-Corning Corporation Scale: ` 1" * B'-O" . i Source: Dwg, No. 5G-2002-0 [6-12-55) Mr:1 .. ........... i!J t W fVL ,lf * , . . W-M.. *' V'/i'r ,-r^ i - `.iv >r:'d i , ' .-, tv i" , 18 NOTE: THIS DOCUMENT OH) NOT r-r*3 - r;. ' - *, -. j -^ nuj rro riLcd (THAHBQLTEP 4A ' 1 ^^ SUMMARY OF VOLUMETRIC AIR FLOWRATES IN DUCTS IN FEEDER AND BUILDER AREAS Duct Number (Ficure 4) Feeder Area; 1 2 3 >4 5 6 7 Builder Area: 8 9 Air Flow, Cubic Feet Per Minute 2,769 63 391 202 1,940 183877 1,724 810 - 7_BB 0009065 c c> r> ------------------ Y-h notz-.t;-:': NOT SOME,r^Uivi t r o s! ,-`- J 2. Conveying velocities within ducts are generally very low for handling asbestos dust. A minimum design velocity of 4000 fpm is being used for the new ventilation system.* Duct 7 (Scrap Grinder Hood) and the 10" diameter duct into the Block Dust Col lector were the only ducts with adequate air velocities for con veying asbestos dust. 3. Total air volume for the Builder and Feeder areas is very low (2769 + 1724 + 877 cfm). Estimates for Port Allegheny place the air requirements for adequate control for three lines at ap proximately 6.5x times - this amount of air. In summary, as judged by three different parameters, i.e. dust concentrations, face velocities at hoods, and duct air vol umes, the ventilation system, and hence dust control at this plant, are unsatisfactory. D. General Housekeeping In general, housekeeping is judged to be poor at this plant. Appendix C is a selection of photographs taken during this survey. Asbestos dust is on all surfaces"as well as in the air. It was noted that with the exception of Mr. Hyde and the author not a single person in the plant wore a respirator. It can only be concluded that Amosite fiber at this plant is not being handled with the care and respect that any substance with this toxic potential deserves. The practice of exhausting bag dust collectors to plant air would not be'permitted in the states of Pennsylvania and New York. Air cannot be recirculated when toxic substances are * rVt-v Port Allegheny Plant. GC 21!fif if K i_f^0009066~7 trL 1 : l . ^' k _ t=r 20 involved. In the case of nuisance substances, recirculation is permitted if the recirculated air contains the toxic agent in concentrations less than 20% of the Threshold Limit Value. *y* ,;_csr' rti i -- r : . ' 1 NO I COivii- nv*. ;vi i'r'O rsLO - 7%, -A-rt TO +--- V c c GG 2T&09 r'Dr0009067J . _.-'v h f-"-v jg_ ' cA 21 VI. ACKNOWLEDGEMENT The author wishes to express his appreciation to Mr. John L. Hyde, of Pittsburgh Coming Corporation. Mr. Hyde provided in valuable assistance with survey measurements. f'iQ7c: NOTC;^' - J * * w i i A - ::rV' j?;=.\/< ' '1 fw -7; ' . ' -, sC'-S'TV" 3* ^->v-* r t. *'**ta^, r>V*.- * -* t' rH GG 2":'" 1 BB 0009068 1 - lr'H;'-'' ,- mm J-- rf ., , ,,. lea r J'J '?tT nm NOT Cu^crviOm i*r<3 FILES APPENDIX A 1. Letter from W.R. Blair, Regional Director, D. S. Department of Labor, Dallas, Texas, to' J. H. Bierer, President, Pitts S burgh-Coming . 2. Letter from B. M. Stout, Vice-President, Pi-tsburgh-Corning to w. R. Blair. 3. Letters from M. Corn to W. R. Blair. n\t'i'.'We i& 1 BB 0009069 j N= - I c to* t \ Pittsburgh Corning Corporation One Gateway Center Pittsburgh, Pennsylvania IS222 BYRL STOUT Vie* PrBidnt of Manufacturing July 9, 1969 Mr. Wendell R. Blair Regional Director U. S. Department of Labor Bureau of Labor Standards 601 Mayflower Building Dallas, Texas 75201 Ai />, , "TJJ ! i i \J ,1. - '"C ~ ^ t t- .. ;i TM j-x t p. ; ;"w v! i ? S jj NOT COME I-' I CO lv) t V tj i J Dear Mr. Blair: Enclosed are copies of First Aid Certificates presented by the American Red Cross to members of the supervisory staff at our Tyler, Texas plant. The training given these supervisors should satisfy the require ments of 50-204.264 of your notice sent to our President, Mr. J. H. Bierer, with your letter dated April 8, 1969. Yours very truly. PITTSBURGH CORNING CORPORATION A Byrl M. Stout Vice President of Manufacturing BMS/rb Enel. cc; Mr. J, H. Bierer Mr. C. E. van Home Mr. H. C. Underwood Dr. L. B. Grant, M.D jt- :'-C PITTSBURGH r- O RN IN G -[ IX ?nn i THE AMERICAN NATIONAL RED CROSS * This certifies that _____Ntrre.L. Llndley ________ has completed the 'i ANli '.Ui.) course of instruction in FIRST A*C. f" T:JF' INJURED atSmith County Chunter. *Tyler, rexes. April 1959 ZT Sjft'fl ScT\ |L THE AMERICAN NATIONAL RED CROSS Hh This certifies that Charles E. Van Horne has completed the ' V t Ni!*AK.D course of instruction in FIRST AID TO at Smith County Chart er tyl'or," Texe s April 1969 7 '.............. ( THE AMERwAN NATIONAL RED CROb* m c? This certifies that __ _______ Everett aevil1 has completed the STANDARD course of instruction in MnTP 1 3 ,w s'* 1 * 4 ? J , * ^ nj ,, .J * * 2 r ?. Cjf C ` J i III. THE AMERICAN NATIONAL RED CROSS "a* This certifies that Billy C. viilllcmsoc has completed the STANDARD course of instruction in THE AMERICAN NATIONAL RED CROSS .t.i..i.iltihaamt E, Jenhms has completed the ~."7 \ VIJ A RD course of instruction in ! 'I'J tC -r-'E --/OREO lt __ Srlth County Ch'j.ter _________ Tyler, Texas April 1969 z Sjfctj-Stlu, A __ GG 20013 c ? a ul urn :io. 25'j 7-25-7foOTE: TH!S DCCU'AE r^yni' N0TC0KZ,-hJ,vv>;-; j ; J-vC TO ALL EMPLOYEES .. EFFECTIVE AUGUST 2, 1971 ALL PERSONNEL WILL BE REQUIRED TO WEAR ON THE IP. FACE, AT ALL TUTS IN THE PLANT A CUSTFCE #77 OR OTHER EFFECTIVE TYPE OF RESPIRATOR. THE ONLY AREAS WHERE RESPIRATORS WILL MOT 6E REQUIRED ARE IN THE CD' LUNCH RCCH, (2) SUPERVISORS* OFFICES, (3) LATRiUES AND (4) PLANT OFFICE, THE LOniVFJl'S CCi'JSITTEE FAS SEEN ADVISED OF THE COMPANY^ CDLIGATICN. THE NEW CCCUFATICY.AL, SAFETY AND HEALTH ACT CLEARLY DEFINES DOTH THE EMPLOYERS AND EMPLOYEES G3LiS,A73C:I3 T.ir r.tv-t+>*. GG 20014 i-*L 09072~7 eKpcsore, inasmuch m tiis pleat will be closing eborC'.jr after the first of the yesr. Hopefully by the tictu cf our caciioy, vc will hsvo .-tvoilcblc to us the iis-pls'r.t dust itudiro pavforsed by ..*.1.0.2.11. a veeu or so c$o. liiis uill eupplersunt ccriicr dust studios tlsce have beta. perfumed. LooUins fevuerd to r^cslng with you f.n Jcaucry, , Sincerely* 'V . Lie: :1c cc: C. Z. Yen Ho: AK. Hulrusn )*r. V, .Jobss s tee E. Cvent, M.P. Pedicel Director GG 2GG15 V-.-, r. .: - T rr,- jsn-- r:A^I7 , hL-'A;:v f.--_ ,vr------ / -t: . AA'A. U.S. DEPARTMENT OP LABOR .JctHfatiMfll Safety anJ Hlth Admii*trtio 7th Floor - 1517 Commerce Street Dalles, Texas 75101 NARRATIVE ADDRESS Pittsburg Coming Coro. P. O. Box 7057 Tyler, Texas 75701 . CSMO NO. H-7734 1. AREA *1730 L OSH*l na 1 l1 4. NtGION 6 | | DATE OSHA-1C 17/2/71 1' Cover*Se Infonas-io-. Page. . of '.ctvrer unibestos pip1! insulation affecting cortserce obtaining ram materials and distributing finished products. . *J J L,, "" ; 'i ! lU NOT CO^r niwu./it, i nV77Ti Hi u rJLrto ` * 3. Closing Conference Sununwy: Date 12/1/71, Mr. C. t. van Horne, Works Manager, C. R. Holder, AHA Compliance,and John P. Boyle, 1. H., present, AHA informed Mr, van Home alleged violations had been noted and that citation of alleged violations and proposed assessment of penalties -mould be issued. Mr. Boyle covered alleged violations noted and this portion of closing conference is cohered in the I. H, narrative report, Nr, van Home admitted Vromiadge of excessive concentrations of asbestos and stated company had reouested variance. Copy of this variance request '-as furnished by van Home and is in the file. Mr. van Horne did not object to proposed abatement dates or violations. Ho legal action expected. 1 \jb_ - Of'n t C Cuvlb I BB 0009074 | c : ? t :.xt t .T- c Th? OTl **$ T*C+ C. R. Hold ' ** ~ " * ' of 'irif.i sHl2'y*igeier.nH ist performing a survey to determine IE employees tbit** si^oj^d to ?eyxcessive amounts of asbestos floes. A teen from MTO^H k"d C'~s pla"t at the request of the Texas State Department of Heelt'- ?.nc massed on to Regional Administrator John K* Barto the in.ior- matiO'* that they felt extremely serious health hazard conditions existed at this plant due to employees being exposed to excessive amounts of asbestos fines. The entrance interview was with Hr. EdmOnd Snavley, forks Accountant, and Mr. C. E. van Kome,T,orks Manager. The ARA and Industrial Hygienist pro perly identified themselves by presenting their identification credentials and the ARA explained that the purpose of the inspection was for Mr. Boyle - to perform an industrial hygiene survey to determine if employees were being exposed to excessive amounts of asbestos fines. Copies of the Occupational Safety and Health Act of 1970, 29 CFR Part 1910, Handy Reference Guide, and Safety Standards magazine, dated May-June, 1971, were presented to them. Both of these employer representatives were familiar with the Act and when we informed them it would be necessary for an employee repre sentative to accompany us on the inspection Mr.Ray Barron, Maintenance Kan and Onion Workman Committee member, who resides at 109 E. Grandville, Tyler, Texas, and is a member of O.C.A.V., Local 4-202, the authorized representative of the employees, was called to the office and he was briefed on the purpose of our visit. , .. r. * Prior to starting the inspection a review of the accident reports was made and no serious injuries have resulted in this plant during the current calendar year. prior to the employees' representative he'ng called to the office Kr, van Home was informed that if conditions were noted during the inspection that consti tuted alleged violations of the rules and regulations, that it could cause the company to be issued a citation of alleged violations and proposed assessment of penalties. Additional information as to other employees contacted can. be found in the T.ndustria.l Hygienist's, narrative report. Hr. van Home was informed that would'be taking pictures of the equipment and people at each test site and he voiced no objection. WT7-F, 0907s"J wrC r C\ t r` c To: "r. '). Varrfir January l'f 1972 HAINTEN ~>N."3 07 PLANT VJNTILATIC?: SYSTEM P309M3TI0N Department (Batch & Forninq) Each building line 'fill be inspected at least once every three weeks. This includes scrap grinder, feeding machines, and building machines. tL . 1 i v :Jj ^ =' - r-r ! :0 . FINISHING Department U i. J . ,-*y * ;t -j >-*'i :"!w r\ ---------------------- - --><*- i i r ^ fj5 r 5 * r. . t * J. The entire-dust collection system will be inspected j , .* ___or_a regular weekly basis. *r _ * . * . ' * ' ' i ; - -: i-; *i 1.- . 'r : CSvH:sab C. s.. var. Horne, i-ar.a^sr GG`'2'J!jT : *J"bB 0009076.. 15l2^T^nJinerce Street, Dallas,|Texas /^?5201 NARRATI^ 1 EMPLOYER Pittsburg Corning Corporation ADDRESS Owentown Texas Plant. P. 0. Box 3057 Tyler, Texas 75701 DATE OSHA-1C January 14, 1972 1. Coverage Information: 4 . P*ge. 1. CSHO HO. B7S01 l.A*EA * 1730 2m OlH/kl Ma I 4*ftCGIOM 6 of. - J. A ? - `i * . HU i .' . Uj:', ' ' .- j 'i _ : ' * ` . V 7 . 1 -Vi' . ,. , aw A Uth-tUr.';^- - 3. Closing Conference Summary: A followup was made by John P. Boyle to confirm compliance on If ' * ^ T a ' ' r*' V * January 13, 1972, for all items which called for immediate correction in citations issued by C* R* Holder on December 16, 1971* The subject citations were received by ft 'i the Owentown Plant on December 17, 1971, and by the Pittsburgh Coming Corpporate office . on December 21, 1971. ` 1 \ ' CITATION STATUS: Item Description Corrective Action , \ *'.* ' 1 T 1 Personnel assigned to tasks 7m- ' requiring respirators without Reviewing records and sch&Smi -j ng medical.exams.(Immediate correction reauired). employees for physicals per C. E. Van Home on 1-13-72. 2 Air vents discharging into base Corrected on same day of large saw r-' 1' 4 ' Air vent discharging into large saw exhaust hood Open doors distrub exhaust ventilation Blowing of dust on small saw outside of hood. Corrected Corrected: controlled bv supervision; signs ordered. Corrected r. 6- 'r 1 f' ' Air U._ed_at small saw to blow off equipment Replace solid hack un block on block saw (Immediate correction required) Corrected, exhaust drop installed. Not complete, saw has been shut down until corrected. . Feeder enclosure (immediate correction required) Not complete material On hand, soma pre-cut installation schedule l-lh-7P. 3. In you: opinion , is a followup inspection necessary? 1 XI Yes _ 1 * (Conuit'ufr-1 on attached sh-c"fO f,r, ww --------------------------------------------------------------- .... ......................... 1............................................ ?nnn Cu;, f " * 1 BB 0009077~7'J ^1H ^ i -.* IJT' rr^ " ^  .ITATION STATUS (continued) Item Description 1V KOI >-y\: .e 2. ;t mn NOT COME FROM PPG FILES Corrective Action tl" * ' ^ Ventilation system maintainance schedule Bag filter discharge inside building (3/31/72) Block saw enclosure (3/31/72) Feed and Builder exhaust system duct velocities. (3/31/72) Housekeeping Respirator usage Complete. Referred to Pittsburgh. Referred to Pittsburgh- Referred to Pittsburgh. Complete in finishing area. (Three vacuum drops installed; area appearance acceptable) Ho corrective action other than imnedlate clean up after use; has been taken in feed and builder areas. Complete; Acceptable. i- r. : ' The citation status of all listed items was reviewed with Mr. Van Home on January 13, 1972. There was considerable discussion on item one, where new personnel have been assigned to tasks requiring respirators without a preliminary physical examination.' Mr. Van Home made the following statement, "My secretary is still reviewing the records to determine which employees require mdeical exams. The job has not been completed. We would like to send all of the employees in together for medical exams on a weekend where it won't interfere with the production schedule. I think we will - have to pay them." _ Mr. Van Home suggested that he would prefer to give new employees physicals after a two-week period since many new men have quit during the initial training period. These men know that the company is considering shutting down the plant and many quit after they y-- .. - : --Z Vis/r. . - draw their first check. Such a procedure of physical exams for new employees would he acceptable to J. P, Boyle. No commitment was made regarding this point. Mr. Van Home further indicated that this medical-physical requirement is being worked with E. B. Grant, M. D., who is the company medical doctor on corporate staff. He indicated that Doctor Grant believes the company employee questionnaire is adequate to assure that an employee can wear a respirator while working. A copy of the question naire was shown to Mr. Boyle. The questionnaire is comprehensive regarding past medical history. (more) GO 20020 | BB 0009078 | . *., ft'-''-'- - -- - t i* V \1 CITATION STATUS (continued) Mr. Van Home stated on item three that he did not know that h usekeeping applied to areas' other than the finishing area where exhaust drops have been installed to vacuum up dust after equipment usage. . This subject was covered during the closing Interview with Mr. Van Horae, Mr. Boyle, and Mr. Holder. The clean up problem in back of the feeder drives, in back of the builder units, in the builder work areas and also in storage areas was stressed. He was told of extensive upper-surface contamination which could not be blown off where pictures were taken to define the problem. It was pointed out that the existing vacuum cleaner used for floor sweeping could not be used to handle these problems. Mr. Van Horae asked if this meant that the plant would have to be kept as dean as a dairy. Mr. Holder stated that in his judgment, standards. Purchase orders agreed to by the Pittsburgh Corning Corporate office, include a sufficient volume of orders to keep the plant operating to the middle of March as stated by Mr. Van Horne. Apparently, there is no plan to shut down the plant until all orders are filled. No statement was made hy Mr. Van Horne regarding whether the Pittsburgh Corning Corporate office is still accepting product purchase orders for the plant. We are not aware of any firm agreement to sell the plant. Mr. Van Horne indicated that two different persons were interested during the past few weeks. I Bfl 0009079 J U.i. DEPARTMENT OP LABOR 0^*. Aitntl Salary ond Htslth Admiiiitir*t)g<i 7th Floor, Texaco Bldg. 1512 Commerce Street Dallas, Texas 75201 1. CSHO mo. B7501 2. AREA 2. REPORT MO. 1FU 4. REGION SHA-1 SAFETY AND HEALTH REPORT 7. EMPLOYE* . INSPECTION DATE 48 7070 1-13-72 . NAME OF EMPLOYER. TYPE OF LEGAL ENTITY. AND AOORMS OF PRINCIPAL OFFICE Pittsburgh Corning Corporation, 3 Gateway Center I6th Floor, Pittsburgh, Pennsylvania 15222 . STREET OR BUILDING (PI*** ,/FplpMgi.J Owentown Texas Plant, P. 0. Box 3057 . city Tyler f. TYPE OF BUSINESS Manufacture of asbestos pipe insulation CLASSIFIED CONTRACTS YES jjjj NO pTTsJc MAIM PLANT 0BRANCH PLANT only plant *1730 6 . SEC0NOAPY COVERAGE CIA WAR IqThER It. TELEPHONE NO. C214) 677-3411 IS. ZIP CODE IS. COUNTY AND CODE 75701 Smith NUMBER IS. ALL EMPLOYED SHIFTS 423 LARGEST SHIFT 67 39 INITIAL FOLLOWUP 4. MANAGEMENT OFFICIALS CONTACTED C. E. Van Home 24. COMPLAINT ms Manager *5. INSPECTION BY 70 ZT. EMPLOYEE INSPECTION REPRESENTATIVES) 42 TITLE _ .. J l&vTSrv - R'.V *. i v *tr***' j ar . MANAGEMENT INSPECTION REPRESEN TAT IVEISI C. E. Van Home Brooks Revill '0. CLOSING CONFERENCE CONTACTS (Vt* INF OJHA.1C It, detail*) C. E. Van Home Works Manager Finish Area Supervisor Works Manager 2S- OTHER EXPLOYEES CONTACTED (tf no tutharlamd *stpfor** H. L, Yandle___________________ Shipper iA) DESCRIPTION OF WORKSITE 31. (I) CONSTRUCTION OF BUILDINGS OR TYPE OF WORK AREA ftncferftotf f**J <F- - ,-yv Se. 0SIIA 1, dated 11/23/71. 32. (2) TYPE OF FIRE PROTECTION i Same as for 31 S3. (3) DESCRIPTION OF PROCESSES (Hmm **r*rf*f, */*r prw**#, *nd potfucfa, *lcj .(* -A'v' *V-. a- r vVO V* c, `it 'iP \ w- k, -. Kr' ` .''V *"* - * tW * Same as for 31 GG 20022 34. (C) SECONDARY COvEragE*LIST FEDERAL CONTACT NUMBER. AND PREFIX (Owimll* In QSHA-JC) - 1JS. ID) DID YOU OBSERVE AN INJURY OR HEALTH HAXARD NOT COVERED BY A STANDARD) ^YES | |nO IF SUBMIT AH OSHA-S FORM. ____ ____ 116. (E) (t) WAS ADVANCE HOTICE OF INSPECTION GIVEN) [ | YES ^ jN TO WHOMT . IN TOUR JUDGMENT DID THE ADVANCE NOTICE ADV ERSELY^AF FECT THE INSPECTION) [~"|yE* [~|hO IF "YES,*' EXPLAIN ON REVERSE OF THIS FORM. ____ ' IT. IF) U) DOES EMPLOYER MAINTAIN INJURY AND ILLNESS RECORDS AS REQUIRED1 [ X] YES \ i 13. (2) WERE FORMS AND INSTRUCTIONS PROVIDED1 yes Qno I )). IS) DOES EMPLOYER COMPLY WITH THE POSTING HEOUIHEMENTSI |x ] YES | |hO [HP IF **NO/# LIST A$ A VIOLATION ON OShA.IA' |_BB 0009080^7 .-i. ^REPARATION 1 ;i V! 1 1 !____________ l-- TIME INVESTED - TQ NEAREST (0.S) HOUR 46. John P- Eoyle 43. 45. TRAVEL CONFERENCE INSPECTION PREPARA TOTAL LhMO'S SIGNATURE y#/' 1 yM. ------------------ 1-- TION ---------------- 1 --------------- 1------- 47. D* T E _L^14-22_ wM 1 1 .. 1 ,1 1-14-72 Ansir.t the r.c^ianal AilinlnjEtthL'-Jt-1'-' C. K. Holder o:,c:a iy t U-i. GPa*Tmsm7 OF LAb.'R iynin iTfc. *h Oa S3 AfU* &>*-> -toc-y 1. CSMO NO. 675oi Z. AREA Z, REPORT NO. IFU 4. REGION YSHA-l SAFETY AND HEALTH REPORT ^/73<D 4? 1. STATE . CITY 7. EMPLOYER 1 INSPECTION DATE *. SCCON GARY COVERAGE *7070 I J-9 -7JL. PCA SCA 1. NAME OF EMPLOYER. TYPE OF LEGAL ENTITY. AHD ADORES* OF PRINCIPAL.OFFICE PtVibU/Yn C-or-nn# Q'rrf '-tidfiuf. 3 . C*r7t1/7 11. TELEPHONE NO* d P,CTfa Ai^rtrh Pn-irto Ctn. i-i. (Plmfmi P**t<*mmco) ySTREET OR BUILOIMG ____________________ _____________________________ T>, zip CODE 0Wfc.\un 7l&Y*M PAv/~ PO /3^x 3Ci 5*7 .. CIT----------------------------------------------------------------^----------------------------------- IS. STATE 7500) j 1 IS. COUNTY AND COOE y&< rw tSr7. type business toa.nuPt.tfuK- pip*-' j. T r-- _-- 1 4 CLASSIFIED CONTRACTS { | YES [y| NO ihsutu~t~im 11 at. sic | MAIN PLAHt[~*~] BRANCH PLANT \7| ONLY PLANTt~| number EMPLOYED MALE FEMALE ALL SHIFTS IS. LARGEST SHIFT U7 3 .1, 23. TYPE 24. COMPLAINT INITIAL FOLLOWUP yes 6. MANAGEMENT OFFICIALS CONTACTED d. E. NO TIWTLEork's hAosv' A s TV. Cf 27. INSPECTION BY TOTAL 7o 27. EMPLOYEE INSPECTION REPRESENTATI VE(S) A*- ?iv PiStJ7e~n , TITLE Mit 2ft. MANAGEMENT INSPECTION REPRESENTATIVE (SI C. H". Ya H H trK\ 4-- Ij*. nf*.-r t V </ 29, mplorooOTHER EXPLOYEES CONTACTED NprfifRMtln) (tl m muthoritod </ ;l-'v:V "V. f-*_" "', >; */"' '*X ^'-v'-v mz' -.**.*',,,. (^`rj , S; .i-J/i!-r1-1'v*T-> '---"*'. - lot dOimilt) (Vf30. CLOSING CONFERENCE CONTACTS OSHA-JC Ui* d . IT. VOs*-.., hJ PpV"M , H/f-7--/to W A* T A fij) V or(A) description worksite 31. MJ CONSTRUCTION OF BUILDINGS OR TYRE OF WORK AREA pnctudlng glto) 5** OJ//A i/ 4*-^ U /^/yj jjl. 121 TYRE OF FIRE PROTECTION t$4Ar) -t- 0-C f~C7- 3/ S3. (1) DESCRIPTION OF PROCESSES fXw nPriit /r proe*i*, tntf praAulA le) ^AtflC Ct^J At- 3/ ;ii 1 r GG 2C0Z3 l. 1C) I is. ID) SECONDARY COVERAGE-LIST FEDERAL CONTACT NUMBER, AND PREFIX (D.ltllt In OSHA-IC) . oDIO YOU OBSERVE AN INJURY OR HEALTH HAZARD NOT COVERED BY A STANDARD! | )yES IF "YES." SUBMIT AN OSHA-t FORM. I (I) RAS ADVANCE NOTICE OF INSPECTION CIVEHl | | YES NO TO WHOM? (2) IN YOUR JUDGMENT OlO THE ADVANCE NOTICE ADVERSELY AFFECT THE INSPECTION! [~~ jv IF "YES," EXPLAIN ON REVERSE OF THIS FORM, ____ m DOES EMPLOYER MAINTAIN INJURY AND ILLNESS RECORDS A* REQUIREDT | ^| YES j |nO WHEN!. NO IJ> WERE FORMS AND INSTRUCTIONS PROVIDED! YES - Jr I BB 0009081 (si oocs employer comply with the posting requirements! [^| yes | | no IF "NO." LIST AS A VIOLATION ON OSHA-IA,' | TIME INVESTED - TO NEAREST I0.S) HOUR t 43. 41. ipntrARAV ION 7NAVEL - - . I ^ i __L TO? A2. 43. CCNFCRENCC t5PrCTIO" mmry'YY'w'N 4 ------ -- *4.REPORT Prepara tion 45. TOTAL T __________ i_j __________ Am fru h'. i : CSHO'fc SIGNATURE 1 47. AREA DIRECTOR'S SIGNATURE _________ ____________________________PATE CFO Hl.ill I 0SKA-3A Dali Texas 75201 NOTIFICATION OF FAILURE TO CORRECT VIOLATION AND OF PROPOSED ADDITIONAL PENALTY C H-7734 B-7504 area *1730 TO: E. W. Holman, V. P., Technology and Manufacturing Pittsburgh Coming Corporation 3 Cateway Center . . ... 16th Floor Pittsburgh, Pennsylvania 15222 On the Sixteenth day of December a Citation(sO was(v^rof) issued Co you in accordance with che provisions of section 9(a) of the Occupational Safety and Health Act of 1970 (84 Scat. 1601; 29 U.S.C. 651, ec seq.), hereinafter referred to as the Act, noti fying you of certain alleged violations of the Act and of the rime periods in which they were to be corrected or abated. Based upon reinspection conducted on January 13, 1972 , it is alleged chat you have failed to correct or abate the violations specified below within the times prescribed: SERIOUS VIOLATIONS: Citation No. Proposed Daily Additional Penalty. - Proposed Total Additional Penalty For Failure To Abate NOTE: THIS DOCUMENT DID NOT COME FROM PPfi FILcS - OTHER VIOLATIONS: Citation No. and Item No. 50 Percent Adjustment Factor 1-1 Physically able to use respirators $27.00 1-2 Insufficient Dust Control 37.00 .1-3 Housekeeping 27.00 Proposed Daily Additional Penalty $100.00 100.00 100.00 Proposed Total Additional Penalty For Failure To Abate $2,327.00 2,337.00 2,327.00 : - -V i | EG Total for Alleged Violations: $6,990,00 -riroooioBLipv Ii The above proposed penalties WE computed on the basis of the: toss o^_ut 50 percent adjustment for timely: abatement and on the basis of a proposed assessment as shown for'each day of your failure to abate, counting from the abatement date(s) prescribed in the appropriate Citation, to the date of the reinspcctioo.; These pro posed penalties result from your failure to correct the violations and ate additional to the initial penalties pro posed. Additional penalties will be proposed, on a daily basis, for each violation that is allowed to continue una bated. You are to notify the official named below of the date and nature of any abatement action which you have taken. The payment of penalties is to be made by certified check or money order, payable to the order of "Occupa tional Safety.and Health-Labor.M Remit to the Assistant Regional Administrator whose address appears below. YOU ARE FURTHER NOTIFIED that this Notificadon and the proposed assessment shall be deemed to be the final order of the OceupMjojjal Safety and Health Review Commission snd not subject to review by anyxourt or agency unless, within 15*cays From the date of receipt of this Notification, you notify the official naroedabove in writing that you intend to contest this Notification or the proposed assessment of penalty before the Review Commission. The Review Commission is an independent quasi-judicial agency .with authority tp issue decisions respecting Citations and proposed penalties. far. There is.no requirement that this Notification be posted. Dated at of January Dallas I Texas _, this. 17th day! ?V >. ' *, 1' ' *j C. R. Holder . AnapPaacmax Assistant Regional Administrator Occupational Safety and Health Administration U.S: Department of Labor 7th Floor, Texaco Building 1512 Commerce Street Dallas, Texas 75201 hLvk-t.itV-'-- .~** ' ' cc: C. E. van Home, Works Manager Owentown Plant, Tyler, Texas HO'i -- v*' . ..V' ::? a J ' `v" ,Ji ftl-.v-f-- . $??; ;:r bb Lk >jL > J"BB-0009083^| Cj* O III V` `* t'., ' 1 'U - r. I I --I CKBKMIIPMPL-LIOOCVER tT"/- ?> Ipi A f? : upVv V >' f ) v - ^ ADDRESS 7 /'V. V- f / C ;vrV /a rh.F/^i-'; U.J. DEPARTMENT OF LABOR Occupotlonol Sufety ond HootiH Admin ialfotlo* C_^ C_D PENALTY ASSESSMENT WORKSHEET - OTHER VIOLATIONS (U*e for Determining Proposed Penalties Under Section 17(c) ond 17(d) of tha Act) I SI! -- ! '*u<> NO. I I <i-rn>7\ - I _j HE* i*Xi H CIOH L HI CITA TION ITEM NUM BER JOSHA2) ta J' STANDARDS VIOLATED USE SUSPART AND SUBDIVISION IFROM OSHA-2I ID NUOMFBER in stances (41 (51 IB) 01) 03) GRAVITY OF VIOLATION BY SYSTEM OR TYPE Aa c X PROPOSED PENALTY UNAOJUSTEO ADJUSTED PENALTY FOR EACH VIOLATION TO BE ASSESSED FOR EACH ABATEMENT DATE PENALTY VIOLATION UNOER (COLUMN 5 LESS 17(c) 0-50 51-200 201-500 SOt-LOOO ITEM 7* COLUMN S) (ITEM 10* COLUMNS) 04) DATE OF FOLLOW UP INSPECTION (IS) 1 061 1 07) ] 08) (USE ONLY ON FOLLOWUP INSPECTIONS! |AOO*nONAL PEN PROPOT.D TOTAL NUMBEROF DAYS OVER ABATEMENT DATE ALTY UNDER 17(d) FOR FAILURE TO ABATE (COLUMN S * ADO SOPERCENT FOR LOSS OF ABATEMENT CREDIT AOClTJCMAL N N ALTY FCR FAIL URE toaoatc 1COLUMN 16t COLUMN IS) 50% n COLUMN 9) COLUMN 171 r Ml 0- '%ll (\?)lo i'f to. 13-1 Ml) /4 n>, 14 }p> /?*-! fcV-0 t-' i- /oO tof' //>p" Jo" ocr""- STjl / 3 t>e> 2 S7i>- <2 ^jpC> l lih< IiJ))/ L- tz/,/7t> 0'3h>Okshir //nO I, 73 Z3 J?2 ah; v/ 3 r} r> J -1 *236 0* IV 37 3 7-'~ 3?.y.; y- >3 3 D dd1i T-l-t wn(m IRI hmrm 03 ION ion sih > JlUlll K> USE FOR DETERMINING penalty adjustment (ft penalty adjustment factors fm PERCENT! GOOD FAITH size HISTORY TOTAL 70 10 0 o 5 0 20 10 0 /. A V SjTl 10. JO PERCENT AllATKMENT CREDIT ~0 t. TOTAL .............$Stj y a. TOTAL ....S V VO.-co tz, TOTAL PROPOSED PENALTY TO BE 5 .< > t? p^> ASSESSED TO EMPLOYER UNDER 17(c) DATE CITATION SENT .................. .......................... / -A') DATE NOTICE OF PROPOSED PENALTY SENT ^ ' / DATE EMPLOYER RECEIVED NOTICE.............. DATE AND AMOUNT OF PENALTIES REMITTED___ {J_ /:o H9J TOTAL S U ct') 0' DATE NOTICE OF ADDITIONAL PROPOSED , PENALTIES SENT............................................................ H > ,r DATE EMPLOYER RECEIVED NOTICE............ ............... ________________ PENALTIES REMITTED AND DATE.................................. PREPARED BY Cf/. REVIEWED BY /% DATE // ?/'; t DATE j/k- ' i Pittsburgh Corning Corp P. O. Box 3057 Tyler, T xu 75701 ration January 17, 1972 Asst. Regional Administrator - i------- -------U. S. Department op Labor Occupational Safety & Health Adi Suite 600, Texaco Building 1512 Cohmerce Street Dallas, Texas 75201 PROGRESS REPORT CITATION OF ALLEGED OSHA VIOLATIONS Item 1 - 29 CFR, 1910 134 (b) (10) New personnel will be given a physical within 30 days of hiring. Note: Due to the rapid turnover of new employees, the Company IS NOT CIVIHG PRE-EMPLOYMENT PHYSICALS UNTIL AN EMPLOYEE HAS BEEN EMPLOYED FROM TWO TO FOUR WEEKS. Item 2-29 CFR, 1910 134 (a) (1) Three open air discharge vents on air cylinders of large saw have BEEN PIPED INTO CEILING AREA. CORRECTED ON DAY AFTER INSPECTION, December 10, 1971. A fourth air discharge vent from an air cylinder ON THE LARGE SAW HAS BEEN PIPED INTO THE ATTIC AREA, CORRECTED December 10, 1971. All open doors on East side of plant building are kept closed and SIGNS ARE OH ORDER TO BE POSTED IN THE AREAS AS SOON AS RECEIVED, CORRECTED DECEMBER 10, 1971. Use of compressed air to blow off cut insulation pipe sections AT END OF CONVEYOR HAS BEEN DISCONTINUED AND THE PIPING HAS BEEN DISCONNECTED. CORRECTED DECEMBER 10, 1971, Compressed air is no longer being used to blow off equipment. Suction tubes have been installed overhead and flexible hoses now "vacuum" the equipment. Installed January 9, 1972. Solid bacx up block for block saw has been redesigned and will be INSTALLED AS SOOH AS IT IS COMPLETED. UNTIL THE NEW BACK UP BLOCK IS RECEIVE0 FROM THE SHOP, THE EQUIPMENT WILL NOT BE USED. r TTS'RTT'R. R-TT. f! __n __ TJ tvt.._.t .....at j BB 0009035 -r- z ITEH 2-29 CFR 1910 154 (a) (1) - CoHT. All feeders ih use have been sealed on the back side. Date completed January 15, 1972. Open inspection plates are being kept closed and FEEDER OPERATORS HAVE BEEN 50 INSTRUCTED. ALL MISCELLANEOUS OPENINGS ON SIDES ARE BEING SEALED. THIS WILL BE COMPLETED JANUARY 29, 1972. A REGULAR 5ET SCHEDULE HAS BEEN DESIGNATED AND WILL BE FOLLOWED FOR INSPECTION OF VENTILATION SYSTEM TO PREVENT PLUGGING. JANUARY 13, 1972. ' ~ '.'.4t Item 3 - 29 CFR 1910 141 (a)(3)(h) Housekeeping practices have been changed. A. Work areas are cleared immediately after use. 6. Fiber and dust is now "vacuumed" up into the main Oust Collector. **' C. Three suctioh downspouts have been installed in the Finishing Department for use with flexible hoses. January 9, 1972. Other oownspouts are scheduled for the Batch and Production areas AS SOON AS THEY CAN BE INSTALLED - THUS HO COMPRESSED AIR WILL BE USED (|N-PLANT) TO CLEAN OFF MACHINERY AND EQUIPMENT. PROPOSED OATE OF COMPLETION JANUARY 23, 1972. - 5 The subject of properly worn respirators in the plant has been DISCUSSED WITH THE CHAIRMAN OF THE WORKMENS1 COMMITTEE. THE UNION (OCAW) HAS ALSO BEEN ADVISED THAT EACH EMPLOYEE HAS A RESPONSIBILITY TO CONFORM TO AND OBEY PLANT SAFETY RULES AND REQUIREMENTS UNDER OSHA AND THAT FAILURE TO 00 SO COULD RESULT IN DISCIPLINARY ACTION INCLUDING THE PENALTY OF SUSPENSION OR DISCHARGE. JANUARY 10, 1972. S'Z J, PITTSBURGH CORNING CORPORATION & I ffl \ r CEvH/em C. E. van Horne Works Hanager Plant 7, Tyler, Texas GG 2*028 t -- / U. _ ir` , r*' L<r.. -- c c( 4--_ Q- C c: Pittsburgh Corning Corporation P. O. Box 3037 Tyler, Texas 73701 January 21, 1972 1 Asst. Regional Administrator - Compliance U. S. Department of Labor Occupational Safety & Health Administration Suite 600, Texaco Building 1512 Commerce Street Dallas, Texas 75201 AMENDED PROGRESS REPORT - Citation of Alleged OSHA Violations .Item 1. New personnel will be given physicals as soon as they have been employed two weeks. Item 2. 29CFR 1910.13L (a) (1) with abatement dates of. 3/31/72. No plans are under consideration for these items due to the fact that the Tyler Plant is to cease all operations early in March, possibly by March 1, 1972. - ^ --- Item 2. 29CPR 1910.134. (a) (1) "Inadsquate enclosures of feeder units" All feeders in use have been closed in`as of January 15 as indicated in Progress Report (page 2} dated January 17, 1972. Item 3. ''Housekeeping inadequate for dust control" As indicated in Progress Report, dated January 17, 1972 (Page 2) Suction dovmspouts have been designed and contracted for installation by January 23, 1972 in the Batch &. Feeding Departments and in the Forming Department. CEvH/sab PITTSBURGH CORNING CORPORATION 'J C. E. van Home Works Manager Plant 7, Tyler, Texas C-G 20029 ., > . -- i: v - | BB 0009087 ] PITTSBURGH CORKING CORPORATION TYLER, TEXAS NOTICE January 21, 1972 The following employees are scheduled to report to Dr. Hurst at the Out Patient Clinic at the East Texas Chest Hospital for consultation on the dates and times indicated below: O GO February 2. 1972 O___1 1:30 P.M. J. J. Fitzgerald 1:30 P.M. R. F. Thomas 2:00 P.M. T. . Belcher 2:00 P.K. J. R. Lee CO 2:30 P.M. M. G. Walker 2:30 P.M. H. D. Spencer 3:00 P.M. H. L. Yandle 3:00 P.M. A. B. 3earden .. February A < 1972 t.<S. i3#.oca;s 1:30 P.M. K. V:. MoKoa 1:30 P.M. E. M. Snavsly 2:30 P.M. H. L. Stevenson 2:30.P.M. D. A. Warren February 9. 1972 /yt. w. n-i 'Msg- 1:30 P.M. in--G^-3rooko1:30 P.M. R. Stephenson 2:30 P.M. L. J. Arterberry 2:30 P.M. J. W. Ridgway 2:00 P.M. 0. L. Thorn 2:00 P.M. N. L. Lindley 3:00 P.M. V/. D. Bass 3:00 P.M. J. C. Yandle 2:00 P.M. L. Kay 2:00 P.M. I. L. Cooks 3:00 P.M. W. M. Morris /o All employees who are on duty during their scheduled appoint ment time will be paid allowed time up to 42 minutes. Each employee will clock out before departing from the plant. If an employee clocks back in for duty within the 42 minutes allowed, his pay will be continued as usual for his regular 8 hour shift. Please be advised that all employees who are scheduled for appointments are charged with the obligation .of meeting the appointment times on schedule. 'Fr^ /sab ^JU7 C. E. van Horne )A . M err'* ^ ________ _ ____ --a------ Sfl_____ GG 21*030 i .0009088' A c Pittsburgh Corning Corporation P. O. Box 3057 Tyior, TttXM 73701 February 21, 1972 Hr.' C. R. Holder Assistant Regional Administrator u. S. Department of Labor Occupational Safety and Health Adminstration 7th Floor 1512 Commerce Street Dallas, Texas 75201 Subject: Monthly Report Dear Sir: As of 4:30 P. H., February 3, 1972 all production activities at the Tyler Plant ceased permanently, and preparations are under way for the following: 1. Complete dismahtlling of all production, finishing and affiliated machinery. 2. A LARGE PIT IS BEING PREPARED TO BURT ALL EQUIPMENT EXCEPT ELECTRIC MOTORS AND PALLET SKIDS. 3. All CARTONED PIPE IN5ULAT ION WILL BE SHIPPED OUT AS SOON AS POSSIBLE. 4. All bagged and/or cartoned raw materials will be shipped out. 5. When the plant is completely emptied, high pressure water will be UTILIZED TO CLEAN THE PLANT FROM THE ATTIC 70 THE FLOOR - THEM VACUUMED OUT AND THE ENTIRE PROCESS REPEATED TO INSURE A COMPLETELY CLEAN PLANT AREA* 6. After all the above items are completed. Dr. Hart. Corn will evaluate PLANT CONDITIONS AND, IF HE APPROVES, ANY REMAINING EQUIPMENT WILL BE SOLD AND THE PLANT AREA WILL BE SOLD. If there ARE ANT QUESTIONS, please feel free TO contact me. Sincerely, PITTSBURGH CORN IMG CORPORATION CEvH:dm ~bTo00989,1 U.S. Q&PA^rMcN* Of LAjJi^ OccvpAlianot Softly And Hoallh AJ-niaiiruhy^ G t. CSHO no, n -7*cf H--7Z& 2. AREA t**? t. REPORT NO. //=sir 4. REGION OSHA-i SAFETY AND HEALTH REPORT 1710 S. STATE D *, CITY 70 70 7. employer I | . INSPECTION date z-Af/rz- PCA . SECOM3APY COVERA3C SCA CSA MAR OTHER to. NAME OF EMPLOYER. TYPE OF LEGAL ENTITY. AND AO.OR ESS OF PRINCIPAL OFFICE 11. TELEPHONE NO. Pittihufv AsnU'H* Oi'n-n JLrL /=^rt- ft/ff, Av/? / 2. STREET OR DVN-OlH'G (Plmtm ei-^rtormmcj) is, zip code OKttm/a-M&T&Xtt* Pfi P<rx. 7X70/ ^xm , *- #w,h*4- & JZZ- 17. TYPE OF BUVN E5S ' CLASSIFIED CONTRACTS | | YES NO 0 nMAIN PLANT branch plant ONLY PLANT 24. COMPLAINT pollowup ^ 26. management OFFICIALS contacted 0, TITLE y rfysTrflA 28. MANAGEMENT INSPECTION RfiPHESENTATlVElS) Az& 10.'.CLOSING CONFERENCE CONTACTS (V** mm pSi^A'lC foe d+tyj*) jf Ci> V ktcrr-Y) NUMBER EMPLOYED ALL SHIFTS ^3 largest SHIFT 26. INSPECTION BY // 27. EMPLOYEE INSPECTION REPRCSENTATIVE(S) title 'TT - - ` V. i- - ----------- -- ---------------------------------------------------- *(Ji' GT* T. ' * -A-- 29. OTHER CXPLOYEES CONTACTED (It no mulhonsij mrnptmymm repr*inia(iTtJ R<u, t. t-K7<rr? A-A;is;7ttm<u a. /Ifi-LfZ. /--| fr (A) DESCRIPTION of worksite 31. (1) CONSTRUCTION OF BUILDINGS OR TYPE OF WORK AREA (Including mi*m) i 34. 14) TYPE OF FIRE PROTECTION 3^^ f&r 3/ NOTE: r;.; i TO ojegot DIO NOT COME FROM PPG FILES S" 33. (3) DESCRIPTION OF PROCCSSCS nW>r/al, major preeaaaai, and poducdi a(J f'CT' *3/ GG' 20032 nv 3*. |CI SECONDARY COVERAGE.LIST FEDERAL CONTACT NUMBER. AND PREFIX (Dmtmilm In OSHA-1C) 35. (01 DID YOU OBSERVE AN INJURY OR HEALTH HAZARD NOT COVERED BY A STANDARD? | |yS |j(jnO IF YES." SUBMIT AN OSHA-9 FORM. 35. |CI (?) WAS ADVANCE NOTICE OF INSPECTION GIVEN? YES 0NO TO WHOM? , (2) IN YOUR JUDGMENT OIO THE ADVANCE NOTICE" A.fDtllVCEARfSEEl LlY''AA FF FENC^TY TTHilEl mINCSBPPE;CTION7 YES 0*0 iA IF ** Y ES,** EXPLAIN ON REVERSE OF THIS FORM. 37. IF) O) DOES EMPLOYER MAINTAIN INJURY AND ILLNESS RECORDS AS REQUIRED7 [/\] YES [ 39- [2! WERE FORMS AND INSTRUCTIONS PROVIDED? YES EH m JT El39. 131 DOCS EMPLOYER C=^?L WITH THE POSTING REQUIREMENTS? YES NO IF **NO,#* LIST AS A VIOLATION ON OSMA-IA,' |nO t --iL2G9090~7 TIME INVESTED - To NEAREST 10,5) HOUR rrr -in, -------- ------------iw^f.'2f -- 23. PREPARATION TRAVEL CONFERENCE INSPECTION i i i li6&VjCA 1 'W& , II t 1 1 i i1 - -1 ___________1_____ '<.hEPCRT PREPARA. TlON i 1 l l F TOTAL * Ih^&rtr X, , TM4--- AREA DIRECTOR*} SIGNATURE ri^Vv. y^y.i ____________________________ DATE CPO Hl.l)? f ~ U.J. DEPARTMENT oi LA3^)R \ ^ ^CCWpatloftsI Slftly HmI\K a4Ai 7Tf1y* f K NARRATIVE EMPLOYER ADDRESS F/tTgfAAtlSf Li#** tt ,h. 0 l.uenr*. Q MS %t ?s-iV ^ 2?. **?-* vs U C*MO NO. 8-7s*t 2. OSH A*I NO. /FT/ '*Jy3 & DATE OSHA-iC ~7-~B_ly-Cx./3~7<3- <T J 1, Coverage Information: P**e. NOTEfTHlS DOCDMENT'tyQ "RSTTCUME FROM- PPG fILtS - - 3. Closing Conference Summary: ` 02 fni_ /C-nAJ'bC/'sL`/n*_` S/Sit.if ^.n^O'-r/p s V pF. C'uJu F/ - 7fy,^ -t^-y && t// J(j-nPofPl_gp JfZf-;.! r <7 tfE T/1/ USQT-JJ /-- 5 `T'rV , P-vu(^/1l: fi rf C /) .. /*'/' " V SjI-lo.l^. ^0 . CTV 5/J jhp /r^ij // = ^ 7 i ______c ^y /Cr~"____/21 &-).zA_ ^vv .-, ^ a" L;7 & a<1<--''"Z7- <^/3 .^7^ .iCoft/dry 0 - ^r-p-77 -^?.kt 6-lUU^IlLL Li_CI LL.1 / -- y. '. /? *-7tr y cLti.v - _ . .r.r.off''^ bb J; J, // yTh/tA+ty O^OttcT se^JL-f jSlZs^ LZ-T-- /MUfLIT&P . ,s/f'r<.iXLJkfi L_____ZA-CV___ru~..rL /:. iVc.-- ,^C<L\ .iH/x-il__. l*rv,/ I.S 7 /IT .(l.. ~/Yu. n.t lL _ A.'V?/- 777 --en, -l ^ >> 7'T^V . Jj . ' __ g -g ffs P'-^.f? ? ' 0 k. K\' -/llF/zJ^ %/>'. *; f-m(.U 1T 3. 1j; yout opinion, a followup ir. *, .on'utvcr-saty* |^_ ** . f '~1 f'- i-J.009091 l 6f/ } -r' CMp 47 7-- C'onjbti & * fr>. 5 > ,.* cC.-.''.-Vv'T,,-; =-'."";_ 'teK'*>rd,y NO it. pori rle> not COW- n-w>'<lr` iLu !t GC 2GG54 8 ' "j""bB 0009092^ t- '.r. :r. ^ t " .; Jk., ,, \____ / jGT t- \C Jack B. Tarrej Industrial Hygienist February 24* 1969 Thru: M. Padilla. Wendell R. HIair- Sample for analysis collected 2/13/69. Pittsburg-Carning Corporation Ouentovn, Te ' i. Sample taken at grinder for asbestos dost (respirable) Ratal J* 9 240 lpau b. Sample taken at feeders for aabestoa dust (respirable) Rate: 10' 9 240 lpo. c. Sample taken at Building Platfora where rolls of Isosite are Dade. Rater 10 * 240 lpau .. .J; .-I 'XT Sample taken at scrap feeder for asbestos dost (respirable). Rate 10*.ft- o/ ci lpa, e. Sample at saw for asbestos dust (respirable). Rate 10* A 240 lpa. f. .<TjB.pi* taken at Packing area for asbestos dost (respirable). Bate 10' 0 240 lpn. I realise that ve are not set for ssbsstos dust analysis, but I aade an attempt to find some hint about the easting condition; for instance* if core than 5 ag. per a? are found* then ve know they have a tad condition. I Just took a chance to see if ve can get some sort of Indication while ve wait to get set for tbe other method. Mff-- MT DID 1 *, lo* - w-e* MCI CO&tft'S.Vl-PrG rlLtb >* i GG 2CX)3C| t. '... V* * ?Y f. .' ' UNITED STATES GOVERNMENT Memorandum to : M. Padilla-'' * Through: V. R. BL: PROM J. D. Torrey le date: June 2, 1969 SUBJECT: Laboratory results, Httsburg-Corning Corporation, Owantown, Texas The following results were obtained on the samples of airborne dust: Sample a b c d e f Volume 720 1 2ljOO 1 21)00 1 21)00 1 21)00 1 21)00 1 Net Weight 9.9 mg 10.3 mg 21.7 mg 13.3 mg 12.9 mg 11.0 mg Concentration 13.8 mg/m3 4.3 " 9.0 n 5.5 " 5.4 4.6 > j As you stated these values can only be used as an estimate of the dustiness of the operations* cc: McClure Schulte NOTE: THIS DOCUMENT DID NOT COME FROM PPG FILES Buy U.S. Savings Bonds Regularly on the Payroll Savings Plan INDUSTRIAL HYCICNI AIR POLLUTION c c. Morton corn. ph.d.. b. ca e. CONSULTING ENGINEER 310 aown HILL ROAD PITTSBURGH. PENNSYLVANIA 1S22B May 1, 1969 TD-IPHOHI 413 . NI4U1' Mr. Wendell R. Blair, Regional Director U. S. Department of Labor Bureau of Labor Standards Office of Occupational Safety NOTE: THiS DOCUMENT DIDRoom 601 ,, 411 North Akard Street Dallas, Texas 75201 Subject: Letter of 4/8/69 to Mr. J. H. Bierer, President, Pittsburgh Corning Corporation. Re: Survey Plant - Tyler, Texas - 2/13/69 Dear Mr. Blair: I am writing to clarify the letter from Byrl M. Stout, Vice President of Manufacturing, Pittsburgh Corning Corporation to you dated April 11, 1969. I have been working with Pittsburgh Corning Central Engineering engineers on dust control in their Port Allegheny, Pennsylvania Works. The manufacturing operation in this plant is similar to that in the Tyler, Texas Plant. We are installing an entire ventilation system and dust collectors at Port Allegheny. . However, it should be noted that I have never visited or surveyed the Tyler, Texas Plant of this Corporation. I first saw the letter from Mr. Stout to you on April 28, 1969. At that time, Mr. Stout suggested that I visit the Tyler Plant and I have scheduled to do so on May 7, 1969. you may rest assured that all the engineering skills which have been brought to bear on the Port Allegheny Plant dust control system will be focused on the Tyler Plant. Sincerely yours. cc: Lee B. Grant, M.D. Byrl Stout Morton Com, Ph.D. I BB 0009095 INDUSTRIAL HYGItNC AIR POLLUTION cc MORTON CORN. Pa D.. B. Ca E. CONSULTING .ENGINEER 310 lowm HILL ROAD PITTSBURGH PENNSYLVANIA IS226 June 6, 1969 J AM IIIAD7 Mr. Wendell R. Blair, Regional Director U. S. Department of Labor Bureau of Labor Standards Office of Occupational Safety Room SOI 411 North Akard Street Dallas, Texas 75201 Dear Mr. Blair: I am writing to indicate that I performed an industrial hygiene and ventilation survey of the Pittsburgh Corning, Tyler, Texas, Unibestos Plant on May 7, 1969. The report was*submitted to the Corporation on May 29, 1969. Mr. John Hyde, engineer with the Corporation in the Central Engineering Office, informed me yesterday that he has been authorized to start engineering design to modify the existing ventilation system. Sincerely yours MC/pfh Morton Corn, Ph.D Enclosed is a notice listing those unsatisfactory; conditions ioiad, and you should take corrective action imediately. You are requested to notify me on or before'the compliance date on the notice concerning action taken to correct the unsatisfactory.conditions Sincerely yours. Enclosure cc: Hr, Charles Van Home, 'KJcs, Vhsagor, CCastcua, Texas r r-- ; GG 2(t..9 7"BB~0009097 | V- _23_ UA. BSPAaTlIENT C? LXZCZ cuaSAU o? lascs stakdasos rn--r i;i it *, S*S3 O- 1 Ml -H ' , ~?.7' '. .* ^cj'4< L? ?-1.d *^".dU )i j i**j. _^ ' -1 1','{ XOTiCSOF - . . i-*s j-'u T/Ll. SAFETY AND HEALTH VIOLATIONS Kame of firm Pittsburg Coming Corporation STREET ADORESS Sox 3057 - Tyler, Texas CITY Oventovn C^^ICIA--S CCNTACTED - NAM AND TITLE Charles E. Van Home, Vies. Manager * . COUNTY Smith COHTflACTOA *um;; < STATE Temas zir 75701 ' plant Survey made with Mr. Van Home REPORT FURNtSHSO TO Jaxes K. Bierar, President osdl safsty engineer VCCUPUANCC JCATE 5 ' ]^7 8, 1969 iDAYrOF r' w vraa. a survey or your facilities has revealed conditions which do not COMPLY WITH USSL safety ano health requirements under the fuslic LAO CHESSES. TNE CONDITIONS ARE LISTED BELOW WITH REFERENCE TO COOES ANOSTANDARCS WHICH HAVE SEEN ADOPTED AS THE DEPARTMENT* S SAFETY AND HEALTH THZZZ UNSATISFACTORY CONDITIONS MUST BE CORRECTED. PLEASE ADVISE regional DRiCTOR _Ve:?dgIl ?*.__ Blairon OR Belong K&T 8* 1969 _ AS TO THE CORRECTIVE ACTION TAKEN* 3PUDL1C LA'H - 7A-&44 JV/ALSH-HSALSY {PUBLIC CONTRACTS ACT {?U8LIC LAW Jhcnawawa-o'hara {5SPVICC contracts act Fruclic LAW -^9-ZS7 VART AND KUWANlTIwS ^ACT |PUCL<C LA {vocational lasAaiur*rioN act fei^, xi' t \1 i' r | i f COCS-aTANOARD CORRECTIONS RSSUIRSD . & o2> HYGIENE S0P.VEY 0? H\ 3/69 Process .Area 50-204.264 No certified first aiders. Ex: P.ecommand that several employees ha trained so that each shift viil have qualified personnel to take care of emargencies. i^7- /= Tffs 50-204.275, Local exhau.sc ventilation not according to_&tsr.dards. ~~ `.-p/s./if-OS. ? lad. Vest. Ex: Local exhaust ventilation system was tested with the following ACGIH 5-93 findings: . a. Grinder hood, 25-50 f?a at face. b. Feeder at material point of entry, 50 fps. c. Scrap feeder at material point of entry,' 50 fpa. -- r d. Saving ducts 50Q fpn nt faeg^- P-scommend that employer make a study of present local exhaust ventilation, { with professional advice, to come up to standard. It is believed that present system is belov the required' capacity. ~" E4-; \Q/$C<s,00;sJ6> To Po. So-y.C'A, Ji?S, SS C/s /Oso^aoTSS / vJOZP- /AJO- /)/J /ifPP&vTJO PZ3PS,'Zs}T0/C /SJ ,wJ Tr.o/t ,/ .-.--y/. t/st Co. sj /'sot /s's i//cJsr/c/J. Gcsp/Zsns^oySSo S/rsPsPs F-`. 7Z/S3 /as /jSA J/oSOT- slPSSfS --------- . .. ------------------------- ()...s/s/SB--sfO-P^sp/C&sc/s: //S /wy. ooPr-oT- ts/- i/S,,/.s//~ sS/s/zs./Fy Pt/Bo to Cros/TP/jCT'S &cy/c/a s_) ot sooobsT- TS> SOC.T/0/S- lS&OSXl/P/SS CVg rZs)TS3.-------------- ----- *------- ------------------ (l) /)#A.4/SCSoSl//TS ,i/sop SOS/OT o]/~p,--3~*J&TScO SlOO 'so.iTrSJs.Of,jS t&O ()/gOO--//S`PTO~T-/SGjs/SS- .So -i?-~ SSS.S>-fjS'sl*J.L/J5^ GG 20040 ^-***-` rL L-j- o?S.. 'Cr A- 24 PITTS3UKGK COSNSCG C03PC3ATI0N -7t > -- - -v ' *. *, April!!# ICS3 ..v : *, u'cti-cll lists, Uagicaal Disaster V. C. Ciucrcures of Leber Surssu of Labor Ctasisrds Cuiise o; Crcuyeticsal Safety :'i Data: fibl ill Dorti: Ai;ard Street . Dalles, "esse 75201 rtu/rLeS; Subject: letter Oi 4/2/69 to Mr. J. E. Dicrer, Prcoidast, . . Pictc-urgE Cornier; Corpcratica. . T.e: Survey Pleat - Tyler, _g*aa - 2/13/59 _ ' \*j_- Dear Mr. Dleir: >': tv*"1-- ---*r a - . _ -~ , Dba ioilovir-E actios is talc" talcs to correct thcccastiafactory c cesdisicaa sated is tic report datad February 13, 1059. [_ .- - 1. Coda Stsgdard - ~cf. S0-234.SS4. '-' : >>. ~-s v All eepsrvicary employees were carolled is a first aid ecurea Civaa by fat Asaricas led Cross vif'u tbs first ccccicr. gives 4-10-69. its course is to cosaist of circa seasioss aad by 5-25-69 tiara will 5a fully esaiified pcracssal cr. all auitta. Cads sgasdart - ttsf. 50-204,275." .y-. -J, *. . ,v*~- Pittafcsrs'a Carsisg Coryerctics uses 'tbs services of ice 2. Graat, - ' :-!.D., l-ldical Director, PPG lairs tries, aad bis staff, to sssitcr - its preductics facilities for cssnlisrca vich A.C.G.I.H. thrcalcold Units for dust ccsaastrsticas, (See attscissasto II ssd III). Is oddities, tie Industrial Eyeless I'cusdotiaa cosiucta periodic dust sassurescsts to caacrtais the dust casacstraticss present. (Csa attechssst I). - ` l For those areas is vbich. dust cosesstrsties3 exceed tfca tlrachsidy 'Units, it is required, as a cosditias of esploynsst, flat aact . r : ' csyloyea-year a Dust Too 55 Ssepirater 6wi-73020 approved by tea * - Rr-r ;.^vca- 0. . Surcau of liiscs., l .. - Jr1' "' ' . .*..** .... . ' _ * * - - * ` ., . , *. . * ^t tm'vT-*1-. -. ..v ., *r :-* -' .**--**.**. , . . . -\ . - *-*. ' ? . - . ,, v*: v\.-i V * r' v ' i *-5 v ' ' - >. ^ i . * -T" - /" * *- -V . '.'I " . /`.r ' ' !> : ``''r**-' ' ,** " *' . * ; ' r'` , v ' *.. Z.*7' * M f \ \ * " i-'' ~^K--^ . G-C^rS ` ' ' ` gg mi i fS;.- i--i? 09099 7 ** ^ ** wn fe: ' - "V c r. *J. -lair -Crr ,f ` 25 .2 - ' : : j . . . V April 11, 1309 ", standard (ccsgisacJ)-:~y-' , -.......... .. r-i ... " - .` i . ^ ' * .'} In rafarcnco tc ch-i canranac of year roper- vaera yea arete, , . . '-. ,:it 1= believed tltas the peerret rysronii be lea ebo re-prirof ^ -. capacit"1', the duet nteeurtr.tr.t; da not support this billet. ` - ""V' - v i*;reci.'urih: Corning Corporation ra'taiaa the carvieaa of * - Ihr. Ib-rCon corr., a coat-altim eriliaaaf and authority in the field.- *,, -* . ' of Ininatrial hy^ions and air pollution.- Sr,.Coni cpprtvoa' ell, . . new Imtniloticnr an. vail ca any cadifiaatiana of cur daat. - C;`; ' collectin'; syataac.- , '."V -V ViV.-i*' l'"`` r : . - *. j * > . . ^;h*i"v - ;'*-:' !-* :, . - _.* *. -.. .V- ;2 GG 2(0<? _____ 1 7bb ooo9ioo_r fce--. .n^-an. '-? 7 j: f _______ f: ` t - * ^.'V - ------- _J 1 --"e-r , c- INrt.'STKML hfSICM AIR FO--UT;0>i 26 MORTON CORN. Ph. D.. B. Ch. E. CONSULTING ENGINEER 1IO DOWLit HlU. OAD PITTSBURGH. PENNSYLVANIA 1322B May 1, 1969 TCLCMtONL AIR . III4III 1 Mr. Wendell R. Blair, Regional Director U. S. Department of Labor Bureau of Labor Standards S Office of Occupational Safety '** ' t-'" Room 601 411 North Akard Street Dallas, Texas 75201 IV!nT /'>/' "UJ tuiVjLru Gif n Subject: Letter of 4/8/69 to Mr. J. H. Bierer, President, Pittsburgh Corning Corporation. Re: Survey Plant - Tyler, Texas - 2/13/69 i Li J: * * *w - - ^ 1 ; <*! .T'r** r-*., =V7?~'/ J*1' Dear Mr. Blair: I am writing to clarify the letter from Byrl M. Stout, Vice President of Manufacturing, Pittsburgh Corning Corporation 1 fei'-f- 0:,* * - -,>A. ' . C to you dated April 11, 1969. 1 have been working with Pittsburgh Corning Central Engineering engineers on dust control in their Port Allegheny, Pennsylvania Works. The manufacturing operation in this plant is similar to that in the Tyler, Texas Plant. We are installing an entire ventilation system and dust collectors at Port Allegheny. However, it should be noted that I have never visited or surveyed the Tyler, Texas Plant of this Corporation. I first saw the letter from Mr. Stout to you on April 28, 1969. At that time, Mr. Stout suggested that I visit the Tyler Plant and I have scheduled ro do so on May 7, 1969. You may rest assured that all the engineering Skills which have been brought to bear on the Port Allegheny Plant dust control system will be focused on the Tyler Plant. Sincerely yours. cc: Lee B. Grant, M.D. Byrl Stout Morton Corn, Ph.D. GG 20043 "J" bTo009 lO'.i mfc. j'.r" Qnn ;.?iiENT DID 5 > nf vUH FILLSnO< Uu.viu I AUitfi J ! O i iulo PITOT TU3E TRAVERSE Duct 1 17" Line) In front of 40" feeder. Line #1, feeds from Lines 1, 2, 3 before blower. Point Position inches from wall) Velocity Pressure (VP) "K20) /vp- Air Velocity (foa) 1 2 3 4 5 6 7 8 C9 10 1/2 1 3/8 2 1/2 3 7/8 5 3/4 11 1/4 13 1/8 14 1/2 15 3/8 16 1/2 o 0* 1 0.00 0.16 0.32 0.44 0.60 0.58 0.48 0.20 0.08 0.000 -0.200 0.400 0.566 0.663 0.774 0.762 0.693 0.447 0.283 0 -801 1602 2267 2655 3100 3052 2775 1790 1133 Totals Averages 2769 cfm 4.388 0.439 17573 1757 PITOT TUBE TRAVERSE Duct 2 5" Line) VP Centerline = 0.02 "H20; V = 566 fpm Q e 63 Cfm fv&/zL .i<-.V--'-. . r . III r' . r' - ' s-\ % K ", * : . P S," GG 2JJ545 j BB 0009103_K~ fc. . - " ' IP- _ r- ^ ^ \ cr I ^OTE: THIS DOCUMENT DID NOT COME FROM PPG FILESPITOT TUBE TRAVERSE I J U | JLLO Duct: 3*i t(6H" tLine_)l Point 1 2 3 4 5 7 8 9 10 Position (inches from wall) 1/8 1/2 7/8 1 3/8 2 4 4 5/8 5 1/8 5 1/2 5 7/8 oo , o Velocity . Pressure (VP)("K20) 1.20 1.15 1.10 0.80 0.52 0.02 0.00 0.00 0.00 /vp 1.095 1.072 1.049 0.894 0.721 0.000 0.141 0.000 0.000 0.000 Air Velocity (fpm) 4385 4293 4201 3580 2888 0000 565 0000 0000 0000 Totals Averages 4.974 0.497 19913 1991 Q = 391 cfm Point PITOT TUBE TRAVERSE Duct 4 (4" DianO Velocity Position Pressure ,/vp (inches from wall) (VP)("H20) 1 2 '3 . . 1/8 1/2 2 0.2 0.2 0.7 0.447 0.447 0.837 Totals Averages 1.731 0.577 Air Velocity (fpm) 1790 ' 1790 3352 6932 2311 q s 202 cfm c GO' 20G46 i*^oooio~i --(T- |i 29 Point 1 2 3 4 5 6 7 8 9 10 PITOT TUBS TRAVERSE Duct 5 (12" Diam) 12" Duct, Line 1+2 main leading to 17" main Position (inches from wall) Velocity Pressure (VP)("H20) 3/8 1 1 3/4 2 3/4 4 1/S . 7 7/8 9 1/4 10 1/4 11 11 5/8 0.28 0.34 0.36 0.36 0.38 0.40 0.42 0.44 0.44 0.40 Totals Averages VP 0.529 0.583 0.600 0.600 0.616 0.632 0.648 0.663 0.663 0.632 6.168 0.617 Air Velocity (fom) 2119 2335 2403 2403 2467 2531 2595 2655 2655 2531 24695 2470 Q = 1940 cfa C GG *i^?09?0 s~7 t- rV \ c1 30 -'.u PITOT TUBS TRAVERSE Duct 6 (6" Diam) Point 1 2 3 4 5 6 7 8 9 10 Position (inches from wall) Velocity Pressure (VP)(nH20) 1/8 1/2 7/8 1 3/8' 2 4 4 5/8 5 1/8 5 1/2 5 7/8 0.04 0.06 0.08 0.10 0.10 0.06 0.06 0.04 0.02 0.02 Totals Averages 0.200 0.245 0.283 0.316 0.316 0.245 0.245 0.200 0.141 0.141 2.333 0.233 Air Velocity (fnm) 801 981 1133 1266 1266 981 981 801 565 565 9339 934 Q = 183 cfm f** -4 -4 \\v*~> 1 _ ; \ * +J /V, \ ' ( c*X0 V1*-'.-.,* - V VA * 3^^ * dT - ' - if-U-'i:--/.-. u* - GG 2C048 *| BB 0009106^ K--- P^;r: o 31 PITOT TUBE TRAVERSE Duct 7 (6U Diam) Point Position (inches from wall) Velocity Pressure (VP)("H20) .Jvp Air Velocity (fran) 1 2 3 4 5 6 C7 8 9 10 1/8 1/2 7/8 1 3/8 2 4 4 5/8 5 1/8 5 1/2 5 7/8 1.12 1.26 1.26 1.28 . 1.26 1.32 1.34 1.30 1.22 1.08 1.058 1.122 1.122 1.131 1.122 1.149 1.158 1.140 1*105 1.039 4237 4494 4494 4530 4494 4602 4638 4566 ' 4426 4161 Totals 11.148 44640 Averages 1.115 4464 Q = 877 cfm r V t f K ~V ' ** c i / '>" GG 2W j_BB^0009107-7 f r- t t- 32 i* > ' I'-iOi ' ' :::~o!o :j`i a, *>' -;';>,x:J J i f\ C) PITOT T03E TRAVERSE Duct 8 (11" Diam) Point 1 2 3 4 5 6 '7 8 9 10 Position (inches fron wall) 1/4 7/8 1 5/8 2 1/2 3 3/4 7 1/4 8 1/2 9 3/8 10 1/8 10 3/4 Velocity Pressure (VP)("H20) 0.24 0.28 0.32 0.34 0.38 0.42 0.42 0.40 0.86 0.78 Totals Averages ^VP 0.490 0.529 0.566 0.583 0.616 0.648 0.648 0.632 0.927 0.883 Air Velocity (fpm) 1962 2119 2267 2335 2467 2595 2595 2531 3713 3536 6.523 0.652 26121 2612 Q = 1724 cfm i il ( i* - r' GG Zr!,!r.r' rr 7 BB 0009108 i| " " 33 NOTE: THIS DOCUMENT DIO NOT COKE EE~*S J .td PITOT TUBE TRAVERSE Duct 9 (11" Diaa) Point 1 2 3 4 5 Position (inches from wall) 1/4 7/8 r. * 1 5/8 2 1/2 ' 3 3/4 Velocity Pressure (VP)("H20) 0.36 0.38 0.38 0.38 0.38 Totals Averages yVP 0.600 0.616 0.616 0.616 0.616 Air Velocity (fom) 2403 2467 2467 2467 2467 3.066 0.613 12271 2454 Assumption; 1/2 duct area is blocked by fiber .*. Q = 810 cfm GG ZIV. 34 C' r. nnmMPNT 0!D GO VP- r.v.i>V! Pr'u PITOT TUBE TRAVERSE 17" Duct in Saw Area: Main Duct into Dust Collector Point Position (inches from wall) Velocity Pressure (VP)("H20) /vp Air Velocity (fpm) 1 2 3 4 5 c6 7 8 9 10 1/2 1 3/8 2 1/2 3 7/8 5 3/4 11 1/4 13 1/8 14 1/2 15 5/8 16 1/2 0.44 0.46 0.68 0.74 0.80 0.82 0.70 0.66 0.72 0.48 0.663 0.678 0.825 0.860 0.894 0.906 0.837 0.812 0.849 0.693 2655 2715 . 3304 3444 3580 3629 3352 3252 3400 2775 Totals 8.017 32108 Averages i 0.802 3211 Q m 5061 cfm K' c - rOrb of f1 j? rp ^b^Too 22112-1 W 35 i c NOTE:THIS DOCUMENT DIO NOT COmE-TC'TK'TFITS PITOT TUBE TRAVERSE 10" Duct into Block Dust Collector Point 1 2 3 4 5 6 7 8 9 10 Position (inches from wall) 1/4 V8 1 1/2 2 1/4 3 3/8 6 5/8 7 3/4 8 1/2 9 1/8 9 3/4 Velocity Pressure (VP)("H20) X.66 1.66 1.50 . 1.40 1.26 0.74 0.70 0.70 0.82 0.84 Totals Averages -/vp 1.288 1.288 1.225 1.183 1.122 0.860 0.837 0.837 0.906 0.93.7 Air Velocity (fpra) 5158 . 5158 4906 4738 4494 3444 3352 3352 3629 3673 10.463 1.046 41S04 4190 Q = 2285 cfm C GG 2K&J - I*BB 2222-1 ."* T TF \ i I?------- 1----- 1----------- Lines 1 and 2,Feeders.Showing Method of Emptying Bag c <.* 'i. - -1 . GG 2vv54 t- f - kw Close up of scrap feed and bag collector (Line 2) note axial fans directed at carts and feeder hoods. * <; V >.:*^v3kC w- iU - " * -- hif `S'*i -**: t s OO &: GC 2!Jj55.. *["bb"000922^.1l K-..' - -I k": 1 f.lFsssse er"if i. a . --- .. - ft. BC" h ]> - V- a- - - - : ^ -r;r~-ija *t,4>s pfy^ts*. Dust collector for scrap' hood and * feeders (Line 1-3), showing scrap hood entry closest to blower intake. ?1 r: k""3 '"* !.-. ;. inT CCiviL rRG^i PPG' FILES; l' ifti'riw? Builder on Line No. 2 t- wV.. _ if-' ,' is> -.. i'.-; t$ &'-J' | BB 0009114_| ............... "PS' ) -. < `v c" Pittsburgh Corning Corporation On QaMway C ntar Pittsburgh, Pennsylvania 15332 E. W. HOLMAN Vie# Priid*nt Technology end Manufacturing March 19, 1970 Hr, Wendell R. Blair, Regional Director U, S. Department of Labor Bureau of Labor Standards Office of Occupational Safety Room 601 411 North Akard Street Dallas, Texas 75201 Dear Mr, Blair: '^ On April 8, 1969, you wrote a letter informing us that a recent Labor Department Survey of our Tyler, Texas, facility revealed several vio lations of the Safety and Health Requirements of the Walsh-Healey Public Contracts Act. Mr. B. M. Stout, formerly Vice President, Manufacturing, for Pittsburgh Coming Corporation, wrote to you on July 2, 1969 and outlined the action our company would take to bring the Tyler plant into compliance with the provisions of the aforementioned act. This letter will serve to update your information as to our activities in this area. Pittsburgh Coming Corporation1^ Central Engineering Department with consulting assistance from Dr, Morton Com, has completed detailed plans for a ventilation system to control asbestos dust at this plant. However, purchase and installation of the required equipment have been delayed for the following reasons: 1, Engineering estimates for purchase and installation of the fabric filters, ducting, etc. are quite high when considered against the very real possibility that such equipment may prove to be obsolete in the near future. As you know, a reduction of the Threshold Limit Value of asbestos from twelve to five fibers/cc is scheduled for May 1970. This new level will require a thorough review of the proposed ventilation system by Dr. Com in order to assure its adequacy in meeting the new TLV, or possible further reduc tions in the TLV that may occur at a later date. Further reductions may make it impossible to control dust with the proposed equipment. PITTSBURGH C ORNIN "IT 00091t7_i t Mr. V. R. Blair FT VT t? <! -2 March 19, 1970 2. The equipment, on the other hand, may prove to be unnecessary. Pittsburgh Coming Corporation is vigorously pursuing develop ment of a substitute material for use in its pipe insulation. Initial results appear favorable and we are optimistic over the possibility of marketing the new pipe insulation by mid 1972. Success in this area will completely eliminate asbestos from our product and greatly reduce the need for extensive ventilation equipment. (Note: Please treat the above infor mation in a confidential manner). For the above reasons, we request a temporary variance to the health requirements of the Walsh-Healey Act. During the variance period, we will take the following steps to insure health protection for personnel exposed to asbestos dust: 1. Continue the respiratory protection program in all manufacturing areas showing excessive exposure until such areas are brought under control. 2. Initiate a health education program that will fully explain to the employees the health hazards associated with asbestos exposure and how they can protect themselves. 3. Expand the periodic medical examination program for our employees to include not only chest X-rays as performed to date but also, on all employees with more than five years seniority, an extensive medical history and physical examination, and pulmonary function tests performed biannually. We have discussed such a program with Dr. George Hurst, Clinical Director of the East Texas Tuberculosis Hospital, who is interested in providing these examinations. We would appreciate the opportunity of going over in detail the afore mentioned points. If you think this is desirable we will be happy to meet with you in your Dallas office at your convenience. In the interim, if you require additional information or if I can be of further help, please contact me. Vary truly yours, PITTSBURGH CORNING CORPORATION f EWH/rb EV \ r,G I bb wnb-oo "or tax tmn jup w |m( - MOW FORMAL n MRAMTIN OR APFROVMJ | ' 9-1-71 T0; ' John Erto, Regional Administrator, OSHA APPROVAL REVIEW SIGNATVIE NOTE AND SEE ME COAIMEMT NOTE AND Rl FOR TOUR INFORMATION/;^'^ " PREFARE REPLY FOR SCNATMRtOfi HMAMKIt B KR CONVERSATION AS REQUESTED NECESSARY ACTION From (FM ter* for (Mm) George Pettigrew roR HKW-SO R.tt/M ROUTE SLIP c: J v/ OwL*A ZJsrco* Xt:ufi7 Bvix.I3cg PXTTSBTJKOJI, 1S230 CreAitpi.i1*vA:t0*34RpZaSh* (412) 23S-3131 WAITS** O.ASCT DIA^ fcUMSEA 25S-3352 August 4, 1971 MAL:N3 ASJRUt *' MTTmS. HOI.ABOOXN,laO*O.IBfCSO BUITKW4A0B4HINMCATQO'CNOONFUFIUCIEwMMO WABwHiNenflTO3ns, -oa. oCe. todOOt MAAAI9BURC OFFICE OXHATCAxMT^CTa| Sta)Tu4Rf*ElSoEB.T^.ilUvioUiOlHO Dr. Lee Grant One C-atevay Center lUth Floor, North Wir.g Pittsburgh, Pennsylvania 15222 - .. Dear Dr- Grant: .. Please find for your information a copy of the Application for Variance filed with the Department of Labor on behalf of Pittsburgh Corning Corporation or* August 3.- 1971. f Vt* ; '. IfKz ^ ^1 4 3* ' *- ^, *- ' matter. Thank you for your comments' and cooperation in this Yours truly. Paul Marth^ / O rn o J:i ; ' ' ' '3 Lnclcsure RECEIVED AUG 5 1371 MEDICAL DIRZOTC.7 f; Ui fTM-TM O ' ' . O V.* /-)( .f & ' --"So'09^1 - * ,, J.* ,  Assistant Secretary For Occupational Safety and Health, . U. S* Department or Labor Washington, D. C. 20210 . Re: Application of Pittsburgh Corning Corporation For a Variance From Occupational Safety and Health Standards;________________________ ___ _____________ Gentleman: t Pittsburgh Corning Corporation (the "Applicant") hereby makes application for a variance from the provisions of the Willians-Stieger Occupational ' Safet. y and KealthAct of-1570 pursuant to the rules of practice of Subpart E 1505.10 under Section 6(b)(5)(a) of such Act. The Applicant's'principal office is located at One Gateway Center Pittsburgh, Pennsylvania .15222 .CV : and hereby applies for- a variance from Part-SO-SO1* of the Safcty- and Health Standards for Federal Supply Contracts, Subpart D Section 50-2Ct.50 as it applies to the Applicant's facilities at the follcviing locations; , port Allegany Works Main Street .. . ... P. 0. Box 37 ' . -,, , . Port Allegany, Pennsylvania lc-7t3 * \. T, Tyler Works ' ; `. Ovjentov:n Industrial District P. 0. Box'3057 Tyler, Texas 75705 *.y -,-C . G"tC i63 :r X K. L - - -J -,'r- " c~ w I-- j................ ------------- \ 1' ' The Applicant, at Port Allegany, Pennsylvania and Tyler, Texas, manufactures an insulation material known commercially as UiTaESSTOS which is composed primarily of asbestos. In some areas of Applicant's Port Allegany Works and Tyler Works, during the production process, the Threshold Limit Value for asbestos required by Section 50-SO5.5O is exceeded. To protect- its employees - at the afelementioned locations, the Applicant has; - . . (1) Supplied, and will continue to supply, respirators ' approved by the Bureau of Mines and require the use of said respirators; --f r.. E^ii'1 '-a,- . (2) Provided and will continue to provide dust collection and ventilation apparatus; (3) Provided and will continue to provide health education j programs that fully explain to its employees the | health hazards associated with asbestos exposure and how they can protect themselves; I l \ (li.) Expanded the periodic medical examination program for employees to include not only X-rays but also, on all employees with more than-five years exposure, an extensive medical history and physical examination and pulmonary function tests performed biennially; 't. * -'*.f f1,"' ,i - WOTE; TfffS DOCUMENT n>n W? NOT C0MfRG,\i PPG FILEC!S * fv, i\ GG * *j bb 0009122 \ F* <P: I (5) Purchased and is experimenting with the use O 00 -- UJ o___i fr/L: :. of new and approved respirators with ultra filtersj and * ,t j--- 'i' Sfe:\\. (6) Improved housekeeping procedures by the more frequent use of industrial vaccuum cleaners. .c;., i i The Applicant has been unable to attain the Threshold c- . TLv.it value required for asbestos at its Port Allegany and Tyler Works because of the ur.avaliability of effective ventilation equipHerftTI The ineffectiveness of such equipment has become particularly significant since the reduction of the TLV for asbestos -from twelve to five fibers per milliliter greater than five microns in length. This drastic reduction has rendered * '1 11 1 i I,, ,i , pre--vi-o---u---s--l--y used e.quipm.ent .inadeicua..t..e.....a nd any replacement equipm--e> nt cniy experimental. .- , . r. The Applicant, as of June, 1971, has spent nearly $200,000 in the research ana development of a mineral wool substance"to replace asbestos. Presently, the applicant is examining the production feasibility of the new product according to the following schedule: -Mineral wool to be utilized in production, in place of asbestos, by one shift per day during the' first two weeks of August, 1971. C'Pr Alt] 1 l- e."- - -Mineral' wool to be utilized, in place of asbestos, by three shifts par day during the last two weeks .of August, 1971. -3- GG 2CGG5 V*;,,- t. " \ -J'bB 0009123_y t'-r; _Adecision concerning complete conversion to the use of mineral vjooI in the. production process' beginning in September, 1971^ - -- ------ --- -- ' % The Applicant is optimistic with the results of research and development thus far and hopes to completely substitute mineral wool for asbestos at both the Tyler Works and Port Allegany Works by mid 1972. The-, employees at Port Allegany and Tyler have been informed of this Application for variance and of their right, to petition the Assistant Secretory for a hearing by;' (1) Delivery of a copy of the Application to both Mr. Charles Croop, President of the American Flint Glass Workers Union.of .North America, the employee representative at the Port Allegany Works, and Mr, Herman L. Yandle, Chairman,' Oil, Chemical and Atomic Workers Local h202, the employee representative at the Tyler Works. O GO cS Itj f s. 14., J ^*7-1 (2) Posting a summary of the application; `.A,u including notice tbat~the employees have *'*-*m-,*-- ,. r*>, '*x B 4 ' a right to petition the Assistant SccretarySC 2Z; \ of Labor for Occupational Safety and Health, 1 on the in-olant emnloyee bulletin board at * ii- - -- -| . i i.ii~i`hi|hi~i i ii i ihi ! p mt --r-~--f both Port Allegany and Tyler. G ZOO -rooo'?liLi c:.; c: Therefore, the applicant requests that it be Canted ,, varisnec^fTwa Section gO-gQft.50 of the Safety and Health fitcndardo-f^T^^rs^pIy Contracts foT~a pefTod-of one' year. .. * Respectfully submitted, - PITTSBURGH CORKIKG CORPORATION Paul Martha Reed Smith Shaw. & KcClay Attorneys For Applicant *-5- GG Z^bf T c: P V "" r:'r"> -v* >, AFFIDAVIT COiimwTEALTu OF PENNSYLVANIA COUNTY' OF ALLEGZ-oNY SSs il fi j V -J. i -P- >' Defore me, ths undersigned authority, a Notary Public in end for said Commonwealth and County, personally appeared Lee 3. Grant, K.D., who, being duly sworn according to law, deposes and says that he Is Medical Director, for PPG Industries t, . and Consultant to Pittsburgh Corning Corporation; that he'has knowledge of the matters set forth in the~foregoing application for variance, so far as said application states that the applicant has provided for its employees health education programs that explain to said employees the health hazards associated with asbestos exposure and how they can protect themselves; that the same are true to the best of his knowledge, information and belief; and thathe is authorized as Medical Consultant to applicant to make, sign, verify and file said represeptasion. . - - . 'k,/J4,4*(&. Sworn to and subscribed before me this y-----day of , 1971. - (/ //>; ,Q /As/i-,,, Nonary Pub lie Commission Expires: V/iWA J. VKCilV. V.-Mr/ ?A5i County, Pa, V.y ooniirussisn cxpi'CJ Otf.14 # 1974 W.V-',--- ; J y&cv GG 20068 i-B_0009l26~7 fx-ax i, !~ CN- i^v c: Assistant Secretary For Occupational Safety and Health, J. S. Department of Labor .. Washington, D. C MOTE: THIS DOCUMENT DID NCTCC^EFRpMPRGFlUS .He: Application of Pittsburgh Corning'Corporation For An Interun Order Pending Pinal Disposition Gf Its Application Per Yarle.noa. Gentlemen: . . Pittsburgh Corning Corporation hereby makes application for an Interim Order pursuant to Section 6(b)(6)(a) of the Occupational Safety'and Health Act of 1970 requesting relief from the enforcement of the Safety and Health Standards for Federal Supply Contracts, S\ibpart B, Section 50-204.50 pending the final disposition of its Application for a variance from said standard. Pittsburgh Corning is unable to reach immediate compliance with the aforementioned standard for the reasons stated in the Application for Variance attached hereto. Therefore, Pittsburgh Corning is applying for the appropriate interlocutory relief so as to avoid the imposition of unwarranted civil and/or criminal liability. ' ' ' ` , ' ** Respectfully submitted, . ! PITTSBURGH CORNIHG CORPORATION Raul Martha co Smith Shaw & MeClay Attorneys For Ann lie an t * Vioc^Frc/nident Technology and Manufacturing 1 . r gg mm TbB 0009127 TV i.- ' NOTE: THIS DOCUMENT DID NOT COME FROM PPG FILES' AFFIDAVIT COi-a-JoklfSALKI OF JEKIvSYLVANIA COUliTY OF ALLEGHENY SS: . Before we, the undersigned authority, a Notary Public -in and for said Commonwealth and County, personally appeared E. W. Holman, who, being duly sworn according to lav:, deposes and says that he is Vice President, Technology and Manufacturing for Pittsburgh Corning Corporation; th?t he has knowledge of the natters-set forth in the foregoing application for an interim order and application for variance; that the same arc true to the best of his knowledge -information and belief ; and that he is authorised as Vice President, Technology and Manufacturing, of 2-;Vr Commission Expires: - Y/U3A j. y::k:f.y. ry hy* Pittsburgh, AUcgkiny County, P*. ' My commission expires Ocl.W, 1974 7 bTTo 09128 c: F NOTE: THIS DOCUMENT DID riOiVI'FPG FILESn.rziif ____ _ vU:"i3 7. APP1.DAV.IT COMMONWEALTH 0? PENNSYLVANIA COUNTY OP ALLEGHENY ' SS: r> t&m** .tv r;j, . . (1.,; I, ^"=-7* -i Before Ke, the ur.dcrnigr.se! authority, f>' Notary Public in end for said Commonwealth and County, personally appeared" Morton Com, PH.D-, -who, being duly sworn according to law, ' ---- deposes and says that he is Engineering Consultant to Pittsburgh Coming Corporation;-that he has knowledge of the matters set . forth in the foregoing application for variance, so far as said application pertains to the inability of the applicant to presently attain the revised Threshold Limit Value for asbestos of five fibers -3 per milliliter greater than'five microns in length with existing . dust collection systems in some areas of its Port Allegany Works and Tyler Works; that the same are true to the best of his knowledge, information, and belief; and that-he is authorized as Engineering Consultant to applicant to make, sign, verify and file said representation. _ ' ' VV -frife-iVc'-i'-- tkux h fr Sworn to and subscribed before me this O Cf _ day of Cl ct.-/,, /> a 1971. My Commission Expires: . . ' CjJa QrU y^-c "otarjTPuoIIS-- WltDA J. Vi~"Y. tbl.vy T&U - </ PiiUo-j'sS, Allu^cny Cour.ly, ?. My te.r.T.:ijiir. expires 0:1.14 11P74 GG 2G0h r i r ila Smith iou.wv & McC j.av ltNU>N TUI'!'"!' IIl IUHNO PirrsiiM-iic.-t, J\\ mita.o - " l1'" SJ.VL UUV.^tH lie ena -:i:il * NAiUNO AS*1'i1 W -- !>' t * I3, JO sv tr *;* *-_- '**O*. F"lGt w**vh;:, w"v*-, -* r. ?^Oii J'jJ 93V?3*3 MAr.r i:;1:; i^rr:e *o-; .., v ' .* Aj-.SlMi MA**"rS*12-`* ,* **A3^ 7 tJ MQTP :. ; ; j-.O < ', ^ y * ; T Pt 3 n I'S VJ> 3 1-. i t mO i/vl/UiViili'i, ' l^iu \r "nor a PTv-.r:ry NOT COME FROM PPG FILES Filtoluifi-u :nnit!.", Corporation p. n. T; .'* Port. Ali.oyany, onnnyl vnniii lt''-:h' Dear '-'re-': Plus,w' find :i ropy of the- Applleafi->n " r V.vr Lair:*- filed -.t.11ii tit* Denar Unont of Labor on behalf of PINS:!'.':- h ohm in.: Corn-U'O Lion on Au'-ur-l '*} If you ro-nll, .'.I'.eorclin.T to t!;-' i*-;.'l-:o.;. ;l is In/un- bo.'it or.on you' ft* oc/pLy to tiie usnnloyee:. !*- t-:. A L!.":;::ny ;;;tunary cf the'Ai-.pl Lest Lon re \7a r i-'`nrr>, info rr.'.n Lion to '.: effect: that. tl'i'1-' ho ve v t.o 1 i.ti.or the Acs i r, t` >: f v-i.ei"j if T-OLcr for o ueOrin' .:*] i'.u.fn ''nip 1 inn i, Lou. <uvl iuj'-sr if.`.nil er o' " .: n- the;/ con i::\: ' : ir "< 1 .plfv of :;>.! up'.1' i c:>* If '/O'! ` W '!!!'; ; . ",[ 1 |1'1 f ',"1':* \r:'.lTl ' t!r '> h VO , jh.O'i s ritant r;c, hut X a;:, ou'i- .'.>'i l-i'i'1 ' L:v \.\v- i, vip- rut'- "u.ior C-c tie:; i ','.'`5 , .10 ('") tl.Utf bo 1`ulfiLl-*! '.-I.tlt :'C-` :'i; : <' ri L-pC l-'h. '/-orr. trul". GG 20072 i fBB 0009130 I t I f FV,-- \(- (. Seprewher 7, 1971 60SBA Application of Pittsburgh Corning Corporation for V/ frun GSHA Standard* Ur. Georg* C. Guenther* Asalstant Secretary for Occupational Safety and Health Attach! Cocneata Relative to Subject Application Hr* Georgs Pettigrew, Regional Director of N10SB-HSV, ho* been approached by Hr. Valter G. Hartln, Director, Division of Occupational Safety, Texan State Depertaont of Health, to survey the Pittsburgh Coming Corporation Tyler Marks operation st Tyler, Texas, to evaluate the situation as out lined in the application for variance. Hr. Pettigrew Is arnrtoua to !-- the stems of request for variation prior to any survey. Pleese advise ea to what action has bean taken on this natter* p.-.T,~ ! r '-~ p- > >" v v, 7* .V* 'sr -- SSSP ?-ST'" - -_<>-h j- rvt; ; ". JCHS E. BAKTO Regional Administrator Attactaents cc: Hr. George L. Pettigrew Official fiii^--' Reading file Action copy JKBarto/mnb 9/7/71 .- v- ' v* \;:' ,A . 1 ' 1 .V O 4 5 GG 20073 [ "f BT000913Vi s-: ^. C ' ( "DEPARTMENT OF LABO^ Occupational Safety and Health Administration Dm*: fopi) i* Attm *f: SnijKt: September 14, 1971 OW Application for Variance, File VAR-15 Pittsburg Corporation, Pittsburgh, Pa. T. John K. Barto, Regional Administrator wASHiNGTOKixC. mu Ref: Your memorandum dated September 7j/{97l requesting informption on subj'ect I In reviewing subj'ect application we have been notified by'the Medical investigation Branch, NICSH, Cincinnati, Ohio that this Company at both their Port Allegany, Pa', and Tyler, Texas plants have been investigated by the State Department's of Labor, and, in addition by the HEW Office for air burdens jyf" asbestos. We are presently requesting these records in order to determine what light they may shed on the application, and to the approjfri ateness of granting their request for an Interim Order. On September 10, 1971 Mr. Paul Martha, Attorney with Reed, Smith, Shaw, and^McClay, Pittsburgh, Pa., representing Pittsburgh Corning Corporation was informed that we are investigating the appropriateness of granting ''the interim Order. '* 5 ft-***- `'Joseph J. La Rocca Chief, Office of Project Management and Support or> "jv-iri J ' '! a*<?' 0- ' v a "-V 'i-'Tt r- y 'Ah ' - f -- f ', " . !r'.;V '-V* * v:\-_ r,i-r`. 84 - ; - L' rc ----------------------- --- _2_J^_0009132-J t i f { i V- G v *- November 19, 1971 Telephone conversation between C. R. Holder, John Boyle, Don Shay and Charles McClure First, I want to correct one thing 1 told you earlier. The MSA pumps were sent yesterday at noon instead of day before yesterday. The filters were shipped today. The recommendation about samplings are as follows: 1. Take breathing zone samples on the workmen. I would not use use general .area samples. Use an open face vinyl metricel type filter. Attach the sampler to the workmen if- there is no objection from the workers or from management. 2. I recommend that whoever goes from the Department of Labor - take and use a Bureau of Mines dust respirator. : F.'4V ' 3. Try to get the names of workmen, thab-you take, breath gone , ' :/J - samples on. "- M i f j \J 4. Try to establish an 8-hour tim 'ROM PrG FfilES 5. The next point and the most important one: The period of sampling may be varied and the guidance on that is as follows: The amount of dust on the filter is very important, that it not be excessive (I think you know). In a heavy dust area (200 particles per ml.) the time may be as short as two to five minutes. You will have to visibly compare the open face filter with a clean filter in order to determine there is just a slight disposition on the filter. Heavy deposits may fall off and will be difficult or impossible to count. It will be necessary for Boyle to use his judgment about the amount of deposit on the filter; a light deposit is preferred. Use as a limit 12 fibers per ml. longer than 5 microns counted by Phase Contracts methods. GG #075 r:: - prsso'iH-i; V Bag* 2. c C' 0 c The dust counting would be done in the Salt Lake City laboratories of the Public Health Service. 6. It is our recommendation that this inspection be confined solely to asbestos dust evaluation and that other items, such as noise and safety, not be cited because of the importance of the issue in this particular case hearing. Except for an imminent danger or serious violation you inspect and cite for those items on safety. Holder: Who said that? McfifaoasoexfilapcakxyxxxpxtodtjaxBioddnoAkMX McClure: Shay. Holder; Put him on the line. i <i K? i NOT COtliE FROM ?> ''i Shay: Except for an immident danger or serious violation, in other words, in case of imminent danger or serious violation, you would inspect and cite for those items on safety. 7. Take pictures of settled dust or broken vents, poor vents, poor housekeeping or any other item that you feel is pertinent to this case. 8. Look at the records of the plant.on investigation of injuries or reports required by OSHA. 9. Document precisely everything you can, especially the 8-hour time- weighted averages, even if this is done on just a few poeple. 10. If we are establishing an 8-hour operation better not interpolate the data in this case. This case is going to be in the public eye and my recommendation is to establish an 8-hour sample on 15 minutes out of i. each hour on each man, or a half hour on each, but do not take one or two samples on each man. Take as many breathing 2one samples as you can per day per^man in order to establish time-weighted averages and excursions. Stay as many days as you need to in order to do the job properly. *13 .. -* 11. Note any breakdowns, slow downs or abnormalties In operation. V'-'- &W 7 BB 00091 r: p' *- - ttn r 12. Not* carefully the extent to respirator useage, percent of time used, percent of workers using, and when on and when off the face. 13. Be sure to include an employee walk-around or an employee intcryfray. gy^ 14. Document sampling time, sample location, and length of sample carefully. Avoid general area samples. Now that is the end of my 3. 4. ' recommendation for one or both of you. McClure: Have you made any arrangements saying you should or shouldn't use local analysis of these filter samples? Holder: We have not. X thought your recommendation or instruction was it should be counted at the laboratory in Salt lake City. McClure: Did Barto tell you you should? Holder: Do you feel we would get better results if it were done locallyV'. McClure: I feel it is better to send it to Salt lake City, Holder; Let's see if Mr. Boyle has anything to say as to the sampling f procedure which is concerned, Boyle: No. This is fine. It is comparable to silica sampling where you may sample a short period of time. If it is dark, I x may get too much. We can visually compare it with a clean filter. It will be a big job. We should check the ventilation system carefully. McClure: Yes. Holder: 1 have a question for Mr. McClure. At the present time we have two MSA monitair pumps and 20 filters. Do you feel that we should delay this survey until the equipment arrives from Cincinnati, that is until " we receive out 13 pumps and filters? i McClure: I would recommend that. Holder: I have no further questions. Do you have any further questions Mr. Boyle? j j * -ooo^Li cc Peg* A Boyle; No McClure: There is an additional item that you can record. If you are faced with a situation of going on out and using the two pumps, that they be sent to Cincinnati for calibration after the job is completed. Let's stay on the one thing and not get involved in a general inspection unless a serious hazard or inminent danger exists. Shay: You're right. If in the course of your work you come upon an ioninent danger or serious hazard we would be remiss in our duties if we did not discuss it. Holder: Mr. Johnson did call back; he did not wait for me to call him. Their report was incomplete. They did not designate any time or anything. Dr. Johnson made a point that he considered this a very serious situation and a cease and desist will be in order. He asked if we were going to visit the plant and take air samples.1 He wanted to know if we were going to use NXOSH (or HEW) results and I told him we had them and we would give them every consideration; in fact we have to determine the conditions at the time of our survey. We had to investigate ourselves. Brief Dr. Farrish on this.^I think vnn tnliLhin pvactlv right. Do you think this is a one man job or in your opinion would it take more than one hygienist? McClure: More than one. Holder: We thank you for that opinion. -t/. '.y . T ~ ' - NOTE* THIS D0CUMs->'i* ^ mis not COMEFROM PPG F1L ------------ -------- c U. S. DEPARTMENT OF LABO occupational safety AND HEALTH ADMINISTRA' SUITE GOO. TEXACO BUILDING 1512 COMMERCE STREET November 22, 1971 60SHA Pittsburg Corning John K. Barto, Regional Administrator A ' DALLAS. TEXAS IS201 /w/ On November 19, 1971, I talked to Mr. John Boyle and asked If he f el^he needed help on Pittsburg Corning Asbestos* Survey. He stated needed advice on time of air sampling. He was informed rMr. Ray McClure would be contacted and he could ask any questions he wished. He said if Ray gave answers, he could handle the survey. Attached approximate context on phone conversations held with Mr. McClure on November 19 and November 22, 1971. C. R * HOLDER Assistant Regional Administrator Compliance cc: Ray McClure John Boyle CRHoldenmac MO' MO v 1 rf-X j*.V J * * n\0 -F 1' r-''t- s * i. --w GG 2COT f I BB 0009137 ^ i. - - l: - - John X. Sarto, Regional Administrator On !bveaber 19, 1971, I talked ta Hr. John BoyLa and asked 1 be salt be needed kelp os Slttscurg Carslag Asbestos* 9orray. Be stated he needed advise on time. of air sampling. lie ms infornad Mr. Bay MeClare sxuld ha contacted end he coaid ask any questions he visaed. Ca said If Bar gave answers, he could handle the survey. Attached gpprort--tn context on phone conversations held vlth Hr. KcC*nre on Hemsaber 19 and naveaber 22, 1971. I. R. EOLU^R ssistgr.t Regional Administrator lOCTplitCce :c: Ray IfcClum John Beyle Sabldertaac j ;: 'v ' v NOT "* ' - -V^rai PPG FILES COfjlc-rACwl^nt ifficial rile loading File r<5 13yt3.Jhujyzfc //Sp&AjmJl 'n.&XOL /Juu.rf" ^ xM JM&j*-U/ -Z7" JLU* i g~ .A . GG V e cc Telephone Conv rsation November 22, 1971, between Ray McClure, Washingt n. John Boyle and C. R. Holder, Dallas. C. R. Holder: Mrs. Campbell will take the notes, and Mary if you do not understand, please stop and have them repeat. Ray McClure: 1 called David Hubner of NIOSH about calibration. There is no calibra tion curve furnished with the meter. However, there is a setting given on the side of the meter which will give a flow rate of 2 HEM with a VM*1 open-faced filter. It will be necessary to split the tape on the filter holder in order to make it open-faced. You split the tape with a knife or razor blade and remove the top. half in order to make it open-faced. It will be necessary to try and maintain a flow rate of about 2 LFM by frequently checking the flow rate and resetting. Disregard the previous recommendation to sample at as fast a rate as readable. John Boyle: The information is OK, fully understood. Ray, we received a shipment of cameras, no pumps this morning. Ray: Ah huh, cameras, oh heck, I don't know what to tell you, just keep looking for them. We may be fouled up by the mail service. John: OK, no further details required here. November* 22, 1971 __ Telephone Conversation - Ray McClur C. R. Holder, A John Boyl ., ' C. ^ '^McClure: .1 called Dave Hubner. He Is with N10SH labs' In Conclnnati. He is the f engineer in charge of mailing equipment out to OSHA offices. According to Hubner they mailed samples Thursday afternoon and the filter papers Friday morning by U.S. Mail, air freight. Holder: Is it registered? McClure: Yes, registered- return receipt requested. They mailed it to OSHA, USDL, Suite 600 Texaco Building, 1512 Commerce Street, Dallas, Texas 75201. 1 would suggest that you might want to check with that substation, 75201.. Holder: Here in Dallas? McClure: Tea, in Dallas. Also you might want to check with KAO mail room. Holder: We have already done that. They said they didn't have it. .' ' 'McClure: That is the only thing I know. NOT V!-- Holder: Now maybe you can enlighten us some more erfhnfs ex^oSurfr- btisahess.'` feel free to interrupt. ' McClure: O.K. (1) You don't necesserily have to teke as many samples as Public Health Services did. You can use their date as a guide to plan your sampling strategy. It will be better to establish 8-hour time weighted averages, or TWA's, on a few heavily exposed workers than to take a grab sample on every worker. Off the record, John, do you understand that? Boyle: T understand it but there are two points here and 1 would say it is on the record; The data we got back from NIOSH indicated high level exposure from many different types of operations like feeders and those operating the saws. I don't know how many others, there were high level exposures on packaging, even on inspection, and I would anticipate there would be high levels even on the janitor. McClure: You don't have an obligation to sample and cover every worker that is under exposure. We are only trying to establish a violation of oUr standards and ...... y; Xfc>X35r` ... ^ V, x 1 BB 0009140 | Gr, ?y.\j i ..r- . \ 1gv V- It is n t lik a c mp( .e health survey where you are^^rying t m* every man's exposure is, good or bod. find ut what Boyle: Whether they had control in an area... McClure: But not with area samples. For instance, on a mixerif there are 5 men working on mixers, 1 would sample the one man that appears to have the greatest exposure and that would cut down on the total number of samples. Boyle: For that one sample you are talking in terms of a weighted sample based on IS minutes out of each hour during a working day so that we do not have to extrapolate data that we do not have. If the operation is the same for 8 hours you want to take a look at it each hour during the day rather than say we sampled for one or two hours. McClure: 1 want to sample IS minutes out of each hour but the sample period per sample paper is limited to visual judgment of the loading of the paper. Holder: Am I clear that we are talking about IS minutes out of the hour on. each individual that we choose at the feeder? We might j 0. >* !_ depending on the concentration. N. .O^T C0r/1 E'~pGN:fp! Boyle: You still want to cover him during the 8 hours so we can establish an v wvftr? :_J *r : rr _ *' Si.;;': k-. T FI EES `t ., average exposure for him by making an 8-hour TWA. So for this one individual, the total sample time would be 15 x 8, or 2 hours? McClure: Right. You will get 15 minutes out of every hour. You have the leeway of 5 minutes or 30.. We have this leeway if we are getting heavy enough samples so we have sufficient * - - `V*- sample* ^ Holder: Leaving it to Boyle, if we should take 5 or 30 minutes exposure on each employee chosen to sample. Is the reason for this choice that if we are in !>- a heavy concentration area it is possible that we would acquire at least as good samples in 5 minutes as might appear to be in a concentration not so heavy. We h- -- might only get 2 or 3 good samples in 30 minutes. Is this the reasoning behind that statement? 7 BB 0G09141_ GG Z r by.; '- fr.fi ^ .pany night claim the man * * , was assigned to some ther position r half a day that we were there and that is why w want to 1 ok at them every hour. X was trying t clear up why it might be 5minutes out each hour up to 30 minutes for each individual that Mr. Boyle might choose. The reason why it might range from 5 to 30 is because of the heaviness or lightness of the exposure. With a heavy exposure only 3 minutes would be necessary. . With a very light exposure to dust you might have to sample 30 minutes to get a countable sample. Coes that make sense C.R. ? Holder: O.K. Boyle: I have a question or two regarding the .instrument shipment. rTJT. T?/ je (1) Did Hubner precalibrate the pump? McClure: Tes I?, -)j:b;)' 7jl , .. r~ ^ r'.-vv :r ' uj Boyle: This would be acceptable since they have not been used. C2) Are these all MSA Monitors or are there other types? McClure: They are all MSA. 15 units plus charges. They are capable of sampling for 8-hour periods. -I am aware of that. Holder: Ho you are not Boyle: That was the old type. This is a different type which will operate for 8 hours. McClure: That is true. .' Boyle: What sampling rate is proposed for asbestos? They will calibrate it at 2 1pm. Is this acceptable? McClure: 2 liters per minute is an acceptable rate but I would recommend that you sample it at as fast a rate as you can conveniently read on the flow meter, Boyle: If we can sample it at a faster rate than the pump calibration can we then .post calibrate and use this calibration? GG 20064 w V "T ieClur : Do you hav ^"'cilities for calibrating? { Boyie: *N , it would have to be sent to Cincinnati. * McClure? Cincinnati has furnished a calibrated curve for each instrument. Bolder: 1 am going to show my ignorance but if the pumps have been calibrated, what has the rate of flow got to do with it? They either are or are not in calibration. Boyle? 0R the last calibration from Cincinnati only specific data was given for individual readings. Ho curve was furnished. It is not a case of ignorance, it is a difference on how it was handled. Holder: Can you get in touch with Cincinnati and see that they give us the curve? This is the only way to give us the data. McClure? All right, but it is easy enough to make a curve. t Boyle? Hot when theygdve us only one point of data. * Holder: If they onlyfurnish one point per pump X am not going. Have.they done this in the past? Has the Cincinnati Lab of NIOSH given us a calibration on gO pump of only one point? Boyle said yes. Boyle: One point per condition. 5"TM ""5* l Holder: You guys can-talk on as long as you want to I am going to hang up.' Boyle:They have several different conditions where they have to submit cj calibration data open face and closed fact? for three different filters elso the'""* use of cyclone separators prior to filter. The calibration involves a number CO of calibration readings. We have been given specific data but no curve. It IZZ does not allow us to use a pump at the higher rate of flow without post calibration. McClure? John, I don't understand the problem. Why don't you use the pump e |hh ^ w r-'S at the rate at which they calibrate it? They asked us to use this.. John: You asked us to use the pump at the highest rate possible. This would be at the calibrated rate unless we use post calibration. UK? McClure: You are complicating it too much John. We don't need to bother the tTf? * r^Wy'-' -- u-i#f___ ` - * ' (( + r - -*'.*' ' f* f!c?. :. C\ , , . | BB 0009143 | GG 2G085 r-*y \ -* -. r- /.. \ - w r^r ,g 1 taking shorthand ^ :h all of this prefilter, cyclC-.es, and all this. It ts doesn't enter ^into it. The nly thing we need t know is the sampling rate and how that ties in with calibration. Boyle: What you are really saying is they have a curve. If this is true, this is fine. McClure: Well, I think you can take the pump as supplied and sample with it'at the recommended rate and you will be o.k. . Boyle: I am for that. McClure: Now In regard to sampling at the highest rate possible you apparently did not hear me when I said 2 liters per minute would be o.k. or sample at the highest rate readable on the flow meter. Eithar/or. Boyle: O.K. ... McClure. Anything else? I will call Cincinnati and find out more particulars about the calibration data and I will call you back. Boyle: O.K. I have received a delivery record of a government shipment on my desk. 109 lbs., 6 cartons. I will have to look to see what it is. McClure: O.K- . ' Boyle: I think you have covered it. McClure. O.K. I will call you back. TV > hot > 'Vv':" * 'f . f cj--i.% v | BB 0009144 J GG 2! G5o r- 'V Xerr.--DO NOT U5t THU NOITTI JUF TO I 0*1*11/23/71 show fohmaiI tLi**Ncn on *mov*u John K. Barto, Begional_______ Administrator. Region. VI Occupational Safetr and Health. Administration U.S. Department of Labor xi12 Commerce street, tfm. 6O0 Dallas^ Texas 75201 O *mom revie# PER CONVERSATION o SIGNATURE NOT! AMD SEE ME AS REOUESTES COMMENT NOTE AND RETURN . NECESSARY ACTION O FOR TOUR INFORMATION O PREPARE REFITFOR SIGNATURE OF- REMARKS* |SIWil way 26 i37i DALLAS REGIONAL OrflCE U.3. KPARTWEfiT CF LASCR-CSHA (Fold b*rt l&r return) To William M. Johnson, M.D Ss8" Acting.. Hegnty.,,,PiJfi.flon) dfkpt fHOHE T SU1U5WO 513-684-3255-6-8 FOB noomnxosH 70- yorx msvmo azT.tu3t ROUTE SLIP , DEPARTMENT OF HEALTH, EDUCATION. AND WELFARE PUBLIC HEALTH SERVICE HEALTH SERVICES AND MENTAL health ADMINISTRATION Cincinnati, Oliio 45202 December 21, 1971 National Institute for Occupational Safety and Health James E, Peavy, MJ). Commissioner of Health Texas State Department of Health 1100 West 49th Street Austin, Texas 78756 Attention: Mr. Martin C. Wu'caseb, P.E., Director Division of Occupational Health and Radiation Control Dear Dr. Peavy: Enclosed is a report of an industrial hygiene and medical survey of the PittsburghComing Corporation plant in Tyler, Texas. This study was conducted on October 26 - 29 by the National Institute for Occupational Safely and Health at the request of the Texas State Department of Health, and Local 4202, Oil, Chemical, and Atomic Workers International Union. The principal objectives of the study were to determine the levels of asbestos dust in the working environment, to evaluate the existing environmental controls for asbestos, and to perform medical examinations of the workers. The results of the study revealed exposures to asbestos considerably in excess of present standards, which, coupled with the medical findings, represent an extremely serious occupational health problem. The report contains recommen dations for correction of the situation which we feel should be implemented immediately in order to assure that the health of the workers in this plant is adequately protected. Your cooperation in this study is greatly appreciated. If wJTCan be of further assistance, please feel free to call. Enclosure William JVL 5o5inson, JvCd'. Acting Deputy DireotpT, Division of Field Studies and' Clinical Investigations- 0009i ( Project 71-45 N.I.O.S.H. SURVEY PITTSBURGH-CORKING CORPORATION TYLER, TEXAS OCTOBER 26 - 29, 1971 Study requested by: Martin C. Wukasch, P.E., Director Division of Occupational Health and Radiation Control Texas State Health Department Austin, Texas 5 y* Local 4202 Oil, Chemical, and Atomic International Workers Study conducted by: National Institute for Occupational Safety and Health Cincinnati, Ohio 45202 Division of Technical Services Thomas L. Anania, Acting Chief Industrial Hygiene Services Branch Steven F. Alder, Engineer Francis J. LaPallo, Engineer o Uj c f -- i, O o Harry Markel, Industrial'Hygienist Region VI Division of Field Studies and Clinical Investigations William M. Johnson, M.D., Acting Deputy Director Richard Spiegel, M.D. Richard Lemon, Epidemiologist Other persons present: Charles E. Van Horne, Plant Manager Pittsburgh-Corning Corporation Tyler, Texas Horace Adrian, Chief Industrial Hygiene Program Texas State Department of Health I_BB 0009143 J ' ; - t'r-. A***! *V ,v- - -----------------------V i '1 -e SUMMARY OF REPORT . During the week of October 26 - 29, 1971, the National Institute for Occupational Safety and Health conducted a comprehensive industrial hygiene and medical survey of the Pittsburgh-Coming Corporation amosite asbestos thermal pipe insulation plant in Tyler, Texas. The survey pointed out major industrial hygiene deficiencies which included a grossly inadequate ventilation system and poor housekeeping practices;- Per sonal air samples yielded grossly excessive fiber concentrations. One hundred seventeen of 138 samples exceeded 5 fibers/ml for fibers >5p in length. The National Institute for Occupational Safety and Health medical question naires and examinations for rales and clubbing were conducted on 63 male employees in order to complement the X-rays and pulmonary function tests per- \ formed by Dr. George Hurst at the East Texas Chest Hospital in August 1971. *' Even without benefit of interpretation of the X-rays, 7 of 18 workers with 10 or more years employment meet at least 3 of 4 criteria for asbcstoslE, and reduced pulmonary function was observed in a few workers with less than 5 years employment. In conclusion, an extremely serious and critical occupational health situation exists at this plant. Immediate corrective action is necessary to reduce asbestos exposures to conform to existing standards. Appropriate recommendations are presented in this report. In all areas * and operations except the office area, average and maximum concentrations of dust greatly exceeded the presently existing Threshold Limit Value of the American Conference of Governmental Industrial Hygienists and the Emergency Standards of the U. S. Department of Labor (see Table I), I GG 2Cfij)i 1 BB 0009149 | ' r t c. -3- INTRODUCTION AND PURPOSE Id' MtJ -;J On October 26 - 29, 1971, at the request of Mr. Martin C. Wulcaseh of the Texas State Health Department and Local 4202, Oil, Chemical, and Atomic Workers International Union, an environmental and medical survey was made of the Pittsburgh-Corning Corporation plant in Tyler, Texas. The survey was made to determine the level of asbestos dust in the working environment, to evaluate the c... existing environmental controls for asbestos and to conduct medical questionnaires C:- and examinations for rales and finger clubbing. The study was conducted by the Division of Technical Services and the Division of Field Studies and Clinical CO ) t Investigations of the National Institute for Occupational Safety and Health (NIOSH). Previous industrial hygiene surveys for asbestos dust were made of this ui * +V" {*- cj plant in March 1937 and January 1970. On both occasions the levels for asbestos dust greatly exceeded the threshold limit value (TLV) for asbestos dust as set forth bj' the American Conference of Governmental Industrial Hygienists (ACGd). In this study the asbestos dust was also grossly in excess of the existing TLV's (see Table I). DESCRIPTION OF PLANT AND MANUFACTURING OPERATIONS The plant occupies two large buildings approximately 1000 ft. long and 50 ft. wide and covers approximately 100,000 sq.ft. The buildings are approxi mately 30 ft. high with corrugated metal roofs, a wooden shell, and concrete i floors. The plant employs 74 persons, including 62 hourly and 12 salaried employees. There are four major departments: 1. Production , 2. Finishing 3. Shipping, Receiving and Warehouse 4. Maintenance i I 000915Q I c -4With the exception of the production department which operates three full shifts, the plant operates only one shift. In this plant asbestos insulation for pipe is manufactured from a variable mixture of asbestos (approximately 90%) and varying amounts of natural diatomaceous earth, sodium silicate and mineral wool. The amosite asbestos used by Pittsburgh-Corning Is mined in East Africa. It arrives at the Tyler plant by railroad cars packaged in polyethylene lined hissian bags with each bag weighing 110 lbs. After the materials are received -J.hey_are stored and used as needed. There is also a large inventory of "governmental surplus" amosite asbestos in the warehouse. This material is stored in burlap bags without the polyethylene' liners. All types of used asbestos bags are sold to nursery companies to wrap trees or they are disposed of in the local dump. When the materials are ready for processing they are placed in material feeders. There are 3 feeder lines with each line having 3 stations. Each station contains different materials. The first station contains the virgin ' amosite; the second contains mineral wool (at times the final formulation con tains approximately 5% mineral wool). The third station contains scrap. (Scrap is regenerated asbestos and is approximately 25% of the formula.) The new bags of asbestos are placed on top of the feeder and cut with a knife and allowed to fall into the feed hopper. The scrap is removed from metal containers using a large fork and placed in the feeder hopper. Both systems generate excessive amounts of dust. The diatomaceous earth used in the formula (7%) is placed in large hoppers and fed by auger to the conveyor system. / Be ~ c c After the material is placed in the feeder hoppers it is transported by conveyor belts to the attrition mill which opens the amosite fibers and blends all the ingredients together. From the attrition mill the material is transported through ducts to the cyclone where the heavy material is separated out and the light material is recycled to the attrition mill. From the cyclone the heavy material goes to the building machines. In the building machine, through a system of spiked belts and lay belts, a lap is formed. The lap is a dry mass of the total blend of the raw materials. Controlling the speed of the spike belt determines the thickness of the lap. The material then goes through a mechanical rake to smooth the lap; it is theD sprayed with sodium silicate. After the lap is sprayed it exits the building machine and is rolled on a mandrel to desired size. Sand or Perlite is applied at the beginning of the roll to ease the mandrel from the finished roll. It then goes to the finishing mill. From the finishing machine it goes to the coating machine where a clay coating is applied. At the building machine in the roll-up process, small amounts of the material cling to the lap belt and are scraped off the bottom side of the turn around drum. This material is gathered up, loaded on a truck and dumped in a large field adjacent to the plant as waste. At the present time no provisions have been made to bury this material. This practice has been carried out for at least 15 years. This produces a serious air pollution problem. After the rolls have been clay coated they are removed from the mandrel and put into a drying room. From the drying oven the rolls go to the finishing department where the ends are sawed off, split down the middle, bound together with string, packaged and then removed to the warehouse for storage. c *3*3 i -6^ ENVIRONMENTAL STUDY PROCEDURES AND INSTRUMENTATION O CO Atmospheric samples for fiber count were collected on Millipore filters, CTj . ,,i Type AA*, encased in three-piece plastic Millipore aerosol field monitor with face cap removed and filter completely exposed. The samples were taken at the operators' breathing zone using battery powered Mine Safety Appliance (MSA) ,tv_: gravimetric pumps, Type G. The pumps and samplers were worn by the y employees. The pumps were calibrated to operate at 1.7 liters/minute with each sample being taken for one hour. Each employee on each shift was sampled & jT at least twice, with some employees on the first shift being samples three times.^ . Ventilation measurements were made using pitot static tubes and a H magnehelic gauge. A ten-point traverse was attempted on the larger ducts with . ' LiJ a six-point traverse on ducts six inches or smaller. A more detailed report of \ the ventilation system will appear later in this report. Face velocity measure O L-'yff y -u. " m* 'l wsw. VOW*; V1"'. < 1 at- " ments were made on hoods using a thermal anemometer. Noise measurements were also made of the plant using a General Radio sound level meter. Type 1665-A, calibrated at the time of this study. No read ings were found to be above 85dBA. TOXICOLOGY AND HYGIENIC STANDARDS Si'V`9- f ^0" . V- Asbestos is a general name given to a variety of fiberous minerals. The major asbestos minerals are chrysotile, crocidolite, amosite and anthophyllite. Asbestosis, lung cancer, pleural and peritoneal mesotheliomas may follow exposure to asbestos. The risk is related to the length of exposure and the dust concentration. GG 2PJ9!jJ, ,: ! Vv: k ^Registered trade name of the Millipore Corp., Bedford, Massachusetts V-: tr- t. The Threshold Limit Value (TLV)* for asbestos dust, as listed in the e Threshold Limit Values for 1971 of the ACG1H is 5 million particles per cubic foot of air. In 196S, the U.S. Department of Labor (Walsh-Healey Act) pro mulgated a. standard limit of 12 fibers per ml of asbestos, for fibers >Sp in length. On December 7, 1971, the U.S. Department of Labor established an "Emergency Standard for Asbestos Dust Exposure of 5 fibers per milliliter, > S[i in length for an eitht-hour weighted exposure. The ceiling exposure con ditions shall not exceed 10 fibers per milliliter > 5p in length." RESULTS OF STUDY ' C CL. " CL) CO h" * LU ) A total of 13S personal samples were taken of the various operations at the Tyler plant. These samples were analyzed in the Cincinnati laboratory of NIOSH. Each of the membrane filters were rendered transparent using a 50:50 mixture of dimethyl phtlialate and diethyl ozalate and counted using a 4 mm (43X) phase contrast objective 400X magnification and phase contrast illumination. Counts were recorded for all fibers >5p. Of the total of 138 samples taken, 117 exceed the presently accepted Hygienic Standards of 5 fibers/ml of air and >5p in length. In all areas and operations, except the office area, average and maximum concentrations of dust greatly exceeded the presently existing TLV of the ACGIH and the Emergency Standard of the U.S. Department of Labor, (see Table I.) The plant was in very poor condition including housekeeping, health hazards, ventilation, and storage and disposal methods. Each aspect will be discussed below. GG Z TLV Booklet. Threshold, limit values refer to airborne concentrations of sub stances and represent conditions under which it is believed that nearly all workers may be repeatedly exposed, day after day, without adverse effect. Because of wide variation in individual susceptibility, however, a small percentage of w'orkers may experience discomfort from some substances at concentrations at or below the threshold limit, a smaller percentage may be affected more seriously by aggra vation of a pre-existing condition or by development of an occupational illness-. c f-K- Y! dr C: 8- - CD GO O' ^ HOUSEKEEPDfG J--. f The housekeeping was very poor. At the time of our arrival, when a walk- through survey was made, the floors, ceilings and rafters had an excessive amoua^ r of dust on them. The drinking fountains and eye bubblers were very dirty as weraC',' the rest rooms. There were also small piles of dust around the machines that cY' had been swept there by the operators using push brooms. Thus, asbestos dust e,;> of was re-disbersed into the work atmosphere. VENTILATION TM i< The ventilation system, as a whole, was found to be grossly inadequate. 7-- - Some of the deficiencies are listed below. uj O 1. Blast gates were closed. 2. Small ducts on all three feeder stations were plugged. OO 3. Large holes in main and auxiliary ducts and in the bag collectors. 4. Conveyor system from feeders to attrition inillg bsve Isrgs sep2T2.tions in the facility. 5. Many of the ducts are disfigured, probably caused by bumping by machinery. ... 6. Holes in ducts were repaired by applying Permagum, a putty like substance. 7. -Too many 90" entries were attached to the main ducts, which can cause excessive air turbulance and static pressure losses. An attempt was made to do a pitot traverse of the ventilation system. This was impossible since the ducts on each of the three feeder stations were plugged. Static pressure reading could not be made due to holes in the blower housing and the bag collectors. GG 20097 :2iVv - * i '* o.v*' * "i BB 0009155^l cc SCRAP GRIXPER The scrap grinder is lo^ <** feeder stations. Scrap from various operations are ground- ->*- - ^ *" the process. The operator must lift the pieces of scrap ah-^*s= =* ^ to deed the grinder. After the scrap is ground up it is deposit** jz*=*iaX container approximately 4'x4' with wheels. After the contain** ^ -- removed and then taken to the feeder stations where it is '=*>the process. The grinding opera, tion was very dusty and the yes.*: insufficient. Velocity across the face of the opening was only 26^1 /=^ute (fpm). A slot at the floor level was pulling approximately 200 & ^ incorrectly placed; it should be located above and close to the -i*:*- ccxftainer. L*tJ -T'T' MATERIAL FEEDERS oo The material feeders cv'- ~ --ee lines "dth each liae having three _ stations. The ductsused to ver,u,-"<^ stations'are located approximately 2 ft. from the opening of the cach having a 90* entry. The ducts are 4", 5", and 6" in diameter . on the location to the main duct. Face velocities across each the area contributed to the tur from "15 fPm- A fan loc'ted in ?-ud redispersion of dust in the work atmosphere at the feeder stai. wv - --were openings 6n the feeder stations that allowed the operator to sm feeder. Although they were equipped with plexiglass they were left o^. This also contributed to the dust buildup / in the area. The scrap grinder ^ feeder stations are on the same collec tion system. This collecting consisting of three units of canvas bags . with 16 bags in each unit, is =side the plant. These bags are cleaned by mechanical shaking with t.w falling into 55 gallon drums located beneath the bags. There is a -`W- opening between the bags and the drums and when the bags are shaken ferge portion of tho dust is released to the work area. The spillage, like the the scrap grinder and the fee|e|S, r- v .. r. ' ' \ V'. -10- is swept up by using a push broom. Although the plaut has a vacuum cleaner it was not used in these areas. BLOCK SAW OPERATION The exhaust on this operation was in the best condition of any in terms of removing the dust at the source. However, the blower assembly and the collector bags had holes in them and the dust exhausted from the operation was released into the work area. LARGE SAW OPERATION hi this operation the larger sections of pipe insulation are trimmed. The pipe is put on a conveyor and both sides are trimmed simultaneously using a band saw. At the base on each side of the saw there is a 6" duct to exhaust the dust. The face velocity at these ducts was measured at 200 fpm. This does a good job at the bottom but the dust generated at the top of the cut is released to the work area. When the ends are trimmed, the pipe then goes to a splitter o -Aj, W /A oon La. J:ui *uLoa O * o or-- o}--;{ 2: which makes a cut along the length of the pipe. For exhausting the dust from this operation there is a side draft or suspended hood arrangement. It does ! a good job of exhausting the dust around the outside and along the cut, but the dust is not removed from the inside of the pipe. When it is removed it is inverted and the dust is released to the work area. There is a considerable amount of dust in this part of the operation. This was the only operation in which the dust collector was located on the outside of the building. RESPIRATORS In 1971, the wearing of respirators was made mandatory in all areas of the plant. Respirators used in the plant were MSA Comfo Mask with BM21B-90 filters. Although they have a definite application, respirators should not be worn as a regular means of protection. Respirators should be used only as an srg-zr'*iny mm- t ` hr- gg zpjw; 7^0009157^ '^ cc -11- emergencv or for backup protection. This does not seem to be the intent at this plant. Unless properly fitted, correctly used, and properly maintained, a respirator may become a hazard because it gives the wearer a false sense QJ i of security and permits him to become careless and may add to his exposure, *., If respirators must be used they should be controlled through a company _ ,, . - operated program providing for proper selection, fitting, maintenance and : r-, cleaning. This part of the program is lacking Since many workers were seen 1 _ i ii ! with straps too loose, and straps not connected. There is no maintenance and. standardization program for the respirators. . Ot w* HEALTH HAZARDS In addition to the health hazard from the amosite asbestos, the following- u potential hazards were noted: 'S' 1. The lunch room is located too close (approximately 40-50 ft.) to o the dustiest operation in the plant. oo 2. Workers are allowed to go into the lunch room wearing clothes 2Z contaminated with asbestos. 3. There is a potential health hazard from the diatomaceous earth handling operation. 4. The scrap material that is dumped into the open field may cause a serious community health problem. 5. The sand, used on the floor to enable cartons to be moved more easily, may present a silica dust problem. ADDITIONAL COMMEIxTS Some additional potential hazards were observed as follows: 1. There are 6 homemade natural gas heaters located throughout the plant. Since they are vented into the plant this may cause carbon monoxide or fire and explosion hazard. CG 2f i r.(i;..' | BB 0009JI58 J 2. Compressed air outlets operating at 90 psi are located throughout the plant for the purpose of blowing excess dust off employees. This is not only a hazard to the employees but it reintroduces the asbestos dust to the working environment. MEDICAL PROGRAM The company has no in-plant medical facilities or first aid room. Two first aid cabinets were stocked inadequately, and one first aid cabinet had a t- door with broken glass. Occupational health consultation is available from corporate headquarters in Pittsburgh, Pennsylvania. Dr. Lee Grant, Medical Director of PPG Indus tries, Inc., is Medical Consultant to the Pittsburgh-Corning Corporation. Employees are sent to the Tyler Medical and Surgical Clinic for X-rays, physical examinations, and emergency care. Pulmonary function and X-rays were performed on all male employees in August 1971, at the nearby East Texas Chest Hospital by Dr. George Hurst, an internist and specialist in chest diseases, Diffusion studies and arterial blood gases were obtained on those male employees with greater than 5 years employment. At the present time the workers do not receive pre-employment X-rays due to the high turnover of new personnel; however, after 60 days employment chest X-rays are taken. In August 1971, U.S. Bureau of Mines approved respirators were made mandatory throughout the plant concomitant with an application to the Occupa tional Safety and Health Administration, U.S. Department of Labor, for variance from the asbestos standard. In the finishing and batching area of production (feeders and scrap grinders), the use of respirators lias been mandatory since 1965. Safety glasses are required. No protective clothing is issued to employees, and there are 5 air hoses operating at 90 lbs/sq.in-. and located throughout the plant to blow off excessive dust. GG Z>r 71b 0009159 l -13- o oo LU Also, the variance request sets forth the requirement: "Continuing i. ing the present survey, many employees apparently were unaware of the serious implications of asbestos exposure. MEDICAL DATA AND "RECOMMENDATIONS Asbestos is a general name given to a variety of fibrous minerals. 2-72 LJ~l The major asbestos minerals are chrysotile, crocidolite, amosite, {--. ^ and anthrophylite. Amosite is used exclusively at this plant in the pro- i j j C 3 duction of thermal pipe insulation. Asbestos-related diseases have been well documented in the oo medical and occupational health literature. The risk of developing asbestosis or pulmonary fibrosis varies directly with length of exposure and concentration of exposure. The association between occupational exposure to asbestos and lung cancer, pleural mesothelioma, and peritonial mesothelioma is recognized. NIOSH industrial hygiene surveys in 1967 and 1970 yielded grossly excessive fiber concentrations compared to current and proposed standards. . Again, the present survey yielded grossly excessive fiber concentrations in all production, finishing, and shipping areas. L^0009uq'J \ -14- KIC5H medical questionnaires and examinations for rales and finger clubbing were conducted by our survey team on 63 male employees in order to complement the X-rays and pulmonary function tests performed by Dr. George Uurst of the East Texas Chest Hospital in August 1971, at the request of the Pittsburgh-Coming Corporation. Several films were read as possible pulmonary fibrosis. Dr. Lee Grant, Medical Consultant to Pittsburgh-Corning Corporation,' has delayed release of these films to NIOSH and its expert panel of radiologists pending his personal review of the X-rays. Even without benefit of X-rays, 7 of IS workers with 10 or more years employment at the Tyler plant meet at least 3 of 4 criteria for asbestosis. These criteria include: 1. Forced vital capacity below 80% of predicted. 2. Dyspnea. 3. Finger clubbing. 4. Rales. Positive X-rays could increase further the number of cases of asbestosis. Reduced pulmonary function was also observed in a few workers with less than five years employment. In conclusion, the following medical recommendations are set forth: 1. Chest X-rays obtained in August 1971, should be forwarded to NIOSH and its expert panel of radiologists for the benefit of the Tyler employees. * 2. Reduction of asbestos exposure levels to conform to existing standards is imperative in order to prevent any irreversible pulmonary damage. 3. Following a review of the X-rays, further and more specific medical recommendations will be made. 4. Medical follow-up of present and past employees is indicated. Certainly asbestosis has been reported to progress following cessation of asbestos exposure. | BB 0009161 | C \ 'T- tr c i: -- '* NOTtl-i^-v- -T-1 _ ~^ * ]r^* 'l ', 1 f, : ! j'1 not COWE (-ROM PPk 101 FILES DISCUSSION AND CONCLUSIONS Inhalation of asbestos dust has long been recognized as a serious occupational health hazard. Asbestos-related health effects were detected in many Tyler employees. This plant has been in operation since 1954. NIOSH surveys in 1967 and 1970 yielded excessive fiber concentrations, and again, this survey-yielded fiber concentrations grossly in excess of current and proposed standards. Housekeeping practices and the ventilation system were inadequate. According to the AIHA Industrial Ventilation Manual, a minimum capture - velocity of 200 fpm at the face of the material feeders and a duct velocity of 3500 to 4500 fpm should be maintained. Since the open area of the material feeders is approximately 9 sq.ft., the minimum effective air movement would be 8 ft. x 200 fpm = 1600 cfm. The carrying velocity in the main duct should be approximately 3100 cfm. The present system does not meet these criteria. The respirator program is inadequate and does not offer sufficient pro tection. In conclusion, immediate measures should be taken to insure the employees a safe and health work environment. Further asbestos exposure could result in irreversible pulmonary damage. Immediate corrective action is mandatory and the following industrial hygiene recommendations are set forth:' 1. A complete redesign of the ventilation system. ` y fc*- 2. Locate all dust collectors on outside building and equip collectors with automatic shakers. 3. Appoint a safety committee to educate employees to hazards of asbestos. 4. Remove all homemade gas heaters from the plant. * GG mu I BB 0009162 | tT" ` Zi't*1* ` .'.'I* -*#*. ' Y.:-r "''v i -- o y2 -16- i UJ 5. Do not allow employees to use compressed air to remove dust from clothes. * 6. Establish a company operated and controlled respirator program providing for proper selection, fitting, maintenance and cleaning. 7. The lunch room should be located in a clean area of the plant and employees should not be allowed to enter with dirty clothing. S. All employees should be issued protective clothing such as coveralls o oand cotton caps and these clothes should be removed before eating and before going home. 9. All scrap materials should be buried. 10. Used asbestos bags should be buried also and not sold to nurseries or removed to the local dump. 11. Do not use sand on floor to transport cartons. REPORT PREPARED BY: Thomas L. Anania 7 Bb"0009163-7 ^ -- ip ^ 1 Cf ........... _J o 'Si -17- RE FERENCZS 1. Documentation of Threshold Limit Values, American Conference of Governmental Industrial Hygienists, Committee on Threshold limit Values, Cincinnati, Ohio 1971, > 'J -- O 2. Threshold Limit Values of Airborne Contaminants and Physical Agents, 2 . American Conference of Governmental Industrial Hygienists (1971). "V" ' 3. Industrial Ventilation - A Method of Recommended Practice. 11th ed. - *s LU ^ o o}aii^ 0009164 I TABLE I ANALYSIS OF PERSONAL SAMPLES PITTSBURGH-CORNING ASBESTOS PLAiiT. TYLER. TEXAS ASBESTOS PIPE-INSULATORS OPERATIO!N SAMPLE CONC.fFIBERS >5u/ml> Mixing Feeder Feeder Feeder Feeder Scrap Feeder Feeder Feeder Feeder Feeder Feeder Feeder Maximum Concentration Average Concentration 45 ' ~ 139 117* 99* 10S. 60* 12* 57 82 132 29 Forming Builder Builder Builder Builder Builder Builder Builder Relief Builder Builder Builder Builder Builder Relief Builder Builder Builder Builder Builder Builder Relief Builder Builder Builder Builder Builder Builder 18 91 103 88 119 83 . . 85 105 89 121 54 25 71 90 92 120* 110 107* 111 16* 20 14 17 53 54.04 105.83 101.71 169.7 9.58 188.91 92.77 26.4 9.14 22.5 37.6 169 75 40.93 26.11 14.61 7.45 9.42 25.79 42.77 22.33 6.67 25.53 12.28 57.72 35.24 17. 37.54 90.9 70.36 103.97 30.43 134.41 53.23 44.31 59.58 42.99 Q CO UJ O ___1 S-- TV LLi CD o_ Q- .ZD o O Q BWCA uj *" O Qj <^> S---- oo !\ GG 20107 ! | BB 0009165 I lI t r' Vr . *- if* ?j i1 \ * ^__ \ ; ri^-V^rs*' -1 --i&.;rtrws\-; - -> ( Page 2 - Pittsburgh-Coming Asbestos Plant Forming Maximum Concentration Average Concentration Belief Builder 27 Builder 74 Builder 15 Builder 24* Builder 131 Builder 136 Builder 122 Builder 101 Builder 124 Builder 65 Builder 95 Builder 5S Relief Builder 56 Builder 102 Labor 52 Haxinara Concentration Average Concentration Curing Oven Tender Oven Tender Oven Tender Oven Tender Ovan Tender Hsrieia Concentration Average Concentration 47 140 112 93 84 Finishing Supervisor Wrapper Wrapper Finishing Laborer Utility-Finishing Utility-Finishing Wrapper Utility-Finishing Finishing Laborer Saw Operator Saw Operator Saw Helper Saw Operator Saw Operator SRL Saw Cutting Saw 68 130 98 1 3 66 8 4 22 30 126 78 76 94 118 51 134 42 72.12 9.74 64.35 111.15 13.8 9.9 14.8 26.9 8.44 56.45 36.41 14.75 24.27 31.2 11.26 134 35 23.5 5.C3 6.89 19.87 16.40 29 14 O on UJ O -J STM Ui LiJ 5^. iCLii^ T ..,, MM'll If CJ5 ^ CO LU 2 LlJ osiir- LU o oo *- * -.t * `-f **,' "./#* r Jvi'.>*'* '^j v.;.% 20.38 11.43 37.45 30.43 48.53 12.03 94.81 55.11 22.83 27.36 19.38 14.18 31.23 21.9 1.73 91.76 CG KH08 7 BB 0009166 J [ f X I 'i L- \ ; Page 3 - Pittsburgh-Corning Asbestos Plant Finishing SHL Cutting Saw Saw Feeder Pine Machine Cper. Saw Labor Sew Labor SBL Saw SSL Saw Saw Labor SSL Labor Maxinun Concentration Average Concentration 55 35 006* 007 116 134 141 109 26 Inspection Box Marker Weigher Fork Lift Operator Packer Packer Shipping Supervisor Packer Fork Lift Operator Labeler Inspector Weigher Inspector Packer Packer Weigher Maxisram Concentration Average Concentration 86 59 2 21 42 43 10 62 63 69 5 23 9 44 125 Miscellaneous Maintenance UtilityUtility Maintenance Utility Maintenance Maintenance Maintenance Maintenance Sweeper Maintenance Maintenance Janitor Shipping Guard 75 135 133 108 39 11 13 50 64 97 123 127 129 40 . 73 ... 40.28 2.30 208.42 97.26 6.59 25.97 1.96 11.62 91.52 203 41 20.71 34.49 11.71 9.5 1.84 2.18 13.03 20.42 20.72 92.26 29.45 73.62 3.83 .71 6.8 92 23 CTS CO TM LU C_i ______; UJ o CU tp O o CO UJ' -CH- 0 ili j-- }-- oo , 32.08 2.09 8.36 18.12 30.33 42.2B 26.81 28.43 37-54 3.61 2.10 0.94 2.29 1.36 1.94 GG ZCI09 j I BB 0009 QO / Yv Page 4 - Pittsburgh-Coming Asbestos Plant Miscellaneous Guard Guard Supervisor Supervisor Supervisor Supervisor Supervisor Supervisor Supervisor Maxima Concentration Average Concentration 113 72 128 030 19 79 77 104 115 Office Workers - Maxims Concentration Average Concentration 154 , 152 158 155 * " Appro:;!sate (too aaay to count) Ssrcples taken on October 26, 27, 28, 29, 1971 ...i! 4.53 0.64 1.57 14.92 29.91 6.23 24.25 25.2 2.28 42 14 0.04 0.04 0.03 0.66 .66 .22 O c/3 " UJ O _j Ui O ^ V* -.rt# Y-- . o O; ftb.iasa CO rirt r hr o- ill o J" OQ ;g 20110 >- \ . ' : - - *- .. r 1*BB 0009168jJ ! i i I j - %. - ,, k. \ S?` (p t\ C Oil, Chemical and Atomic Workers International Union ANTHONY MAZZOCCHt, DIRECTOR CITIIEMSHIP-LESISUATIVE DEPARTMENT tilt* liTH STREET. N. w. WASHINGTON. D. C. ZOOM RHONE: lll.JIt* CERTIFIED MUX January 14, 1972 Mr. John K. Barto Regional Administrator Occupational Safety and ^ealth Administration United States Department of Labor Suite 600, Texaco Building 1512 Commerce Street Dallas, Texas 75201 Dear Mr. Barto: wU U-r*11-'*.--s' * V/f 1ws- P'V:'\ * 3 ^ v" Per our phone conversation an January 7th, I would lik< office documents relating to the Pittsburgh Corning Co; it in Tyler, Texas If there is a copying charge, please bill us and you will be promptly reimbursed. The items are: 1) Reports of surveys conducted under the Walsh-Healey Act. 2) Copies of the citations and notice of proposed penalties issued against the Tyler plant by OSHA in 1971. 3) Report of the asbestos dust counts taken during the aforementioned OSHA inspection. The reports of Walsh-Healey inspections have been made available to us since the case of Wecksler et al. vs. Schultz. There should be no problem with the OSHA citations and notice of proposed penalties. In the matter of releasing the results of your dust sampling during the OSHA inspection, precedents have already been set in other parts of the country. For instance on September 22, 1971, OSHA Region IH issued a citation for serious violation against Kawecki-Berylco Industries in Hazleton, Pa. for excessive beryllium concentrations in workplace areas. The beryllium dust counts were listed under "Description of Alleged Violation." Besides precedents such as this one, the failure to release such data violate one of the basic premises of OSHA. Congress included the inspection provision in OSHA so that workers would have an opportunity for a third "independent" party to evaluate their workplace. Congress also wanted to guard against the serious information problem that developed during Walsh-Healey, so the posting of citations under OSHA was made mandatory. GG ZCI11 ----------------- | BB 0009169 1 V C (2) Of course, the easy way to render the citation posting provision meaningless Is to strip the citation of important technical data. Workers in the Tyler plant know that the work conditions are bad, but they also need to know where and to what extent the conditions are unhealthy so that they can protect themselves. Had this information been made available ten years ago, do you think that we would now have the seven cases of workers with the symptoms of asbestosls that both the company and N10SH have found? Furthermore, the new emergency asbestos standard calls for different respiratory protection at different levels of ambient asbestos dust. Again, the workers need to know of the specific dust levels in order to evaluate if they are being properly protected. Lastly, let me refer you to Assistant Secretary Guenther's remarks to the first meeting of the National Advisory 6ommittee on Occupational Safety and Health in Washington on August H, 1971- Mr. Guenther made several statements concerning the availability of OSHA information and he concluded by saying, "Everything we write is in the public domain." Please forward the documents in question to me as soon as possible. If future citations and penalties are assessed against the Pittsburgh Coming plant in Tyler, please forward them also. If you have any questions, please do not hesitate to call., Sincerely yours. .i*.**+ fiTfV? - V- Steven Wodka Legislative Assistant cc: Mr. Herman Tandle, OCAW Local 4-202 Mr. Morris Akin, Dir. OCAW Dxst. 4 Mr. Billie Stokes, Int. Rep. Mr. John Tadlock, OCAW Mr. Ray Davidson, OCAW Mr. George Guenther, OSHA i i \ f -\ f1-'; 7th Floe* March 13* 1972 Hr* Steve Wodka Legislative Aid* Oil* Chemical sad Atopic Workers International Onion 1124 - 16th Street, H. V* Washington. D. C. 20034 Bat Pittsburgh Corning Corporation Oweatown* Texas Dear Hr. Uodkas The files on the above captioned css* have been forwarded to Our Legal Department and yoo should be besting from us in the near futon. I apologise fox our delay In answering your request but we bad a Three-Region Meeting in Dallas and the 0. S* Department of Labor's 59th Anniversary Honor Awards Ceremony. Tours very truly* CHHoldernsls files reading files NOT COME I I BB 00091?2_2 --o t 7th Floor March 13, 1972 60SHA Pittsburgh Corning Oventown, Texas H. J. ?uaatet Regional Solicitor I am forwarding Pittsburgh Corning OSHA file and Valsh-Healey file as a result of Mr. Steve Vodka's letter of March 1 for determination as to whether or sot the information he requested may be released* JOHN K. BA2TD Regional Administrator CRHolderimls files reading files V'jVi ; - 1 ', ,, NO*kT ;U; r.n^ENT o'O LESru"i"* S : i V1 CG 2QU4 | BB 0009172 j Q1 - -0 C 7 U.S. DEPARTMENT OF LABOR OFFICE OF THE SOLICITOR Federal Building & U. 5. Courthouse - Room 7C52 Dallas, Tens 75202 DATE: REPLY TO ATTN OF: subject: AAppnril 4, 1972 SOL: trickier :Sw Request for Documents - Pittsburgh Corning Corporation John K. Barto Regional Director, OSBA DALLAS regional urrtLt U. S. DEPARTMENT OF LABOR 03HA This is in response to your request for a legal opinion as to what portions of the OSHA and Walsh-Healey files Q OO -- l? i f--^ .1 in.this case may be released to Mr. Steve Wodka, Legisla-|-- tive Aid, oil. Chemical and Atomic Workers' International^^ Union. Mr. Wodka requested the following items: CD LU reports of surveys conducted under the Walsh-Healey Act, (2) the report of the OSHA inspector and industrial fr*" hygienist resulting from the inspection on November 23-2-C'C '"C. and November 29-December 1, 1971, and also January 13, 1972, and (3)' any further citations, notices of proposed penalties and inspector reports issued since J'anuary 13, 1972. Consequently, these determinations will be liraitedCO t.S,, , to what portions of the afore-mentioned documents may be :C released. Both files in this case are being returned "5"~ with this memorandum This memorandum will be divided into two parts. The first, entitled "deleted material", will consist of a {" CD CD list of the wording to be deleted, the file and document in which it is found, and the location of the wording within the document. The second part, entitled "reasons and authority", will consist of a statement of the factors considered and the grounds for the previously stated deletions. The interrelationship between these two parts will be shown by means of a code using capital letters under the heading "Justification." vi nr c Page 3 Justifica tion___________ C or E Document same 7 ? $ s '7 r* O P ' ; s j1 NOT COWc FROM !7u Location Wording page 4, paragraph 2, lines 18-20 "It would take up to 2 months to sell the equip ment, buiding, and land." A, B Safety and bottom of page. Health Report Time Invested, for inspection Nos. 41, 42, 43, date 2/9/72 44, and 45 "4.0", "2.0", "10.0" "1.0", "3.0" and Notification of Failure to Correct Violation and of Proposed* Additional penalty may he released in its entirety A, B Safety and Health Report dated 1/14/72 bottom of page, Time Invested, Nos. 41, 42, 43, 44 and 45 "4.0", "l.O", "11.0" "2.0", "4.0" and B, C same, attach- bottom of page, ed Narrative "In your opinion, (printed form) is a follow-up inspection neces sary?" "x" marked in 'yes* box C same, attach page 1, third "Such a procedure ed Narrative, paragraph after of physical exams additional Citation Status for new employees typewritten pages list, lines 4 and 5 would be acceptable to J. P. Boyle. No commitment was made regarding this point c same page 2, para "Mr. Holder stated graph 2 8-10 lines that in his judgment equivalent house cleaning would be necessary to keep levels within the established stan dards. " GG 2GII7 7 8B 000 97 75 1 4 fi page 4 1 Nt NOT COiVIc rftGitfJ rPG Hi Justifi cation Document Location Wording c same page 2, paragraph 3 lines 3 and 4 "Apparently there is no plan to shut down the plant until all orders are filled." D, E same page 2, paragraph 4, entire paragraph "We are not aware of any firm agree ment to sell the plant. Mr. van Horne indicated that two different persons were inter ested during the past few weeks." Penalty Assessment Worksheet - Other Violations may be released in its entirety Intervening materials not requested - NIOSH report. Citation, Notification of proposed Penalty E Safety and No. 33(3) Descrip "Raw material as Health Re tion of Processes bestos (Amosite port dated fiber), Dicalite, 12/2/71 Silicate soda, Min eral wool, snowbrite Clay and recycled scrap, ground and feed through duct system to building area, sprayed with Solution of silicate of soda, rolled or mandrel into var ious sizes of pipe insulation, placed on finishing rolls, coated and placed in oven to dry end trimmed, split & packaged." t : V. GG I BB 0009m"Tp c tUvi r0\ Page 5 NOT CGiVifc FhGiVi PPG FILES Justification Document Location Wording F same, attach paragraph 2 "109 E. Granville, ed Narrative lines 12 and 13 Tyler, Texas." (typewritten) C Report of indus- page 1, paragraph "For this reason, trial hygienist 5, lines 2 and 3 the immediate hazard John P. Beyle dated 12/14/71 is not regarded as a serious violation." 6 same, attach- Page 1, "the local member ment 1, letter paragraph 2 ship of the oil to Dr. Peavy dated lines 5 and 6 Chemical and Atomic November 16, 1971 workers Interna tional Union" D same B, c same page 1, para- grapn lines 5-7 and page 2 paragraph 1, line 1 "One film was read as a pulmonary neo plasm by Dr. Hurst, and this diagnosis was confirmed following hospitalization. In addition, several films were read as possible pulmonary fibrosis." page 2, paragraph "Therefore, medical 2, entire paragraph follow-up of current and past employees is indi cated . Immediate corrective action is necessary to reduce asbestos exposure levels to conform to existing standards. 3 r* pi L4 C-G 20119 "1_?B QQ09T77 | V \ "^UlVi'uiqruttr not COME FROM PPG FILES page 6 Analysis of Personal Samples, Operations Test Data (see Footnotes) and Time Weighted Exposure Data portions of attachments may be disclosed in entirety Justifi cation Document Location Wording F same, attach- one page ment 3, Work History Data Delete entire Pa9 ventilation System Analysis, five'pages (see Footnotes) and * Picture Record, attachments 5 and 6 to report, may be disclosed in entirety. B, C same, attachment 7, Nedical Data Summary page 1 of 6, paragraph 1, lines 3-8 "It is the opin ion of Mr* Boyle and Mr. Holder that med ical file information is confidential where the employee is identified since this information was taken from per sonal medical files by Mr. van Horne without the knowledge of the individual employees. It is recommended that such medical information related to individual employees be treated as confidential information." H same pages 2 of 6, 3 of 6, 4 of 6 and 5 of 6 Delete these four pages in their entirety. | BB 0009178 | page 6 of 6, Medical Data Summary, may be released in its entirety Justifi cation Document Location Wording I same, attach ment 8, Exist ing Control Programs page 1 of 2, third paragraph under (2) Possible substitu tion -of material "Not very good when procedures similar to asbestos opera tions are used" C same page 2 of 2, paragraph 1, entire paragraph "A recent cast process for mineral wool shows some promise* The ini tial cost is high." C same page 2 of 2, . paragraph 2, entire paragraph "Pearlite may be the answer for substitution, it shows some prpmi.se. C same page 2 of 2, first paragraph under (4) Shut-down procedure "Rework of large inventories of scrap will not be a problem." Safety and Health Program Evaluation may be released in its entirety D B, C Narrative dated "3. Closing confer- 12/2/71. ence Summary", lines 5 and 6 "admitted know ledge of excessive concentrations of asbestos" same "3. Closing conference Summary", lines 8 and 9 "No legal action expected" ^3 r\ NOTr. i * i JIU NOT CCIVSE FhOivUi-'i},h-i bb 6.-U I i | BB 0009179 | ij <L .page 8 Justifi cation Document B, C same Location bottom of page "3. In your opinion, is a follow-up inspection necessarv?" Wording "x" marked in 'yes' box walsh-hsalby file (All material other than that listed below - not requested) A, B Safety and Health Report, for inspection date 2/13/69 Time invested. Nos. 3-43, 3-50, 3-53, and x-14 "1.0", "6.0", "1.5" and "8.5" C same Unsatisfactory Conditions Noted; Process Area, 2. "Ex. Recommend that several employ ees be.trained so that each shift will have qualified personnel to take care of emergencies. C same reverse side of page, handwritten notation at bottom of page "(c) Not to be cited as violations. MP" Report of industrial hygienist jack D. Torrey (dated February 24, 1969) and memo to M. Padilla from J. D. Torrey (dated June 2, 1969) may be released in their entirety. NOT FROM PPG FILE;8rVjv' * -< ;, J "1 [**BB 0Q09190_1  C page 9 REASONS AND AUTHORITY O CO General - The determinations which have been made are based " on the Freedom of Information Act and the regulations apply-5 ing its provisions to Department of Labor documents. Said regulations are contained in 29 CFR Part 70 as printed in Volume 37, Number 56, Part III of the Federal Register on Wednesday, March 22, 1972. 29 CFR 70.77(a) states, as follows: "Supplementary regulations governing the disclosure of records in the custody of the Occupational Safety and Health Administration pursuant to the WilliamsSteiger Occupational Safety and Health Act of 1970 i (84 Stat. 1590, 29 U.S.C. 651) will be published in Part 1913 of this title." While the regulations in Part 1913 have not yet been pub lished, a draft copy of them has been used as a guide in these determinations. In no case, however, was reliance placed solely on these provisions. It should be noted that 29 CFR 1913.1(b)(1) and (2) as drafted states that: "The ruj.es in this part govern the disclosure of information compiled in the administration of the safety and health provisions by the Administration or the Bureau of the following: (1) WilliamsSteiger occupational Safety and Health Act of 1970; (2) The Walsh-Healey Public Contracts Act, as amended, ..." The files in question were compiled in investigations author ized by these Acts. A - This information concerns the amount of time spent by the Government in conducting an investigation. Based on the draft version of 29 CFR 1913.33(h), its deletion.is recom mended. Such information is also a matter of intern personnel practices. j BB 0009191_l B - This information relates to internal personnel practices protected from disclosure by exemption No. 2 of the Free dom of Information Act (FIA). See also 29 CFR 70.23 and 29 CFR 1913.22(a)[draft]. C - This information consists of conclusions or opinions of an investigator and/or recommendations made in the course of developing official Department action. As such, it is exempted from disclosure by exemption No. 5 of the F.I.A., 29 CFR 70.25(c), 29 CFR 1913.25(a)[draft] and 29 CFR 1913.33(b)[draft]. f D -This material consists of statements which, by their very nature, indicate they were information furnished and accepted in confidence. As such, they are exempted from disclosure, as privileged or confidential information, by exemption 4 of the F.I.A. See 29 CFR 70.24(b), which states in part: "This exemption [No. 4] is further intended to extend protection to other information in Government records which has been furnished and accepted in confidence and which would not customarily be released to the public by the person from whom the Government obtained it." See also 29 CFR 1913.24(c)(2)[draft] Q -a E - This information consists of trade secrets and of confidential commercial and financial information relating to the operations of the investigated company. As such, it is protected from disclosure by exemption 4 of the F.I.A., 29 CFR 70.24(a), 29 CFR 1913.24(a)[draft] and 29 CFR 1913.33(b)[draft]. F - This information consists of private or personal informa tion which, if disclosed to the public, - would amount to an invasion of privacy. Exemption 6 of the F.I.A. allows nondisclosure, as do 29 CFR 70.26(b)(3) and (4) and 29 CFR 1913.26(a) and (b)(3)[draft]. e Cc Page 11 G - This information reveals the identity of an informer. As such, it is protected from disclosure hy the informer's privilege, which has its roots in exemptions 4 (information submitted in confidence) and 7 (investigatory files compiled for law enforcement purposes) of the F.I.A. See also 29 CFR 70.27(c), 29 CFR 1913.27[draft] and 29 CFR 1913.33 [draft]. H - These materials are personal medical records protected from disclosure by exemption 6 of the F.X.A., 29 CFR 70.26 (b)(2) and 29 CFR 1913.26(b)(2)[draft]. FOOTNOTES C c Consideration was given to the deletion of the names of the _ employees tested in the operations Test Data portion of the r OSHA file. It was decided that said persons probably would not be classified as informers and that the medical records "V exemption probably wasn't applicable. An invasion of privacjTM. does not appear since the examinations were for testing and . . ftf data collection rather than for treatment purposes. In othe words, these men were more like volunteers for an experiment than patients in the true sense. Consideration was also given to the deletion of the Ventila tion System Analysis portion of the OSHA file. The decision was made that this is probably not protected as a trade secret since the ventilation system is presumably not a part of the manufacturing process. Hence it is collateral and not central to Pittsburgh Coming's operations. The decision was also made not to release Dr. Morton Corn's Industrial Hygiene Survey of Selected Plant Operations. Since this was a study commissioned by the company, it wasn't a "survey conducted under the walsh-Healey Act." Hence, it isn't within the scope of the requested materials. An alternative grounds for not releasing it is that it was submitted and accepted in confidence in support of the company's position. ; i BB 0009183 1 (c page 12 Under 29 CFR 70.62, the requesting party, in this case Mr. Wodka, must be charged for the cost of producing and copying this file. The cost of determining which por tions of the file must be deleted is to be included in the charge. See 29 CFR 70.62(c). A total of six hours has been spent in making these determinations and, accordingly, Tfr 3^?. 5 D should be added to whatever other costs are incurred. M. J. Parmenter Regional Solicitor Attachment: Files (2) c- i V xmmx 7th Floor April 10, 1972 Hr. Steve Wodka, Legislative Aide Oil, Chemical and Atomic Workers International Union 1126 - 16th Street, H.W. As requested in your letter of March 1, and several phone conversations thereafter, I am attaching the material-from our files which you desired. The cost for transmission of these reports, in line with the regulations published under 29 CFR, paragraph 70-62, is as follows: Labor (Solicitor) 24 quarters Labor (Compliance Office) 16 quarters TOTAL $ 23.00 15.00 10.20 43.20 You will note some information has been removed from the reports. This is in accordance with the rules and regulations as contained in 29 CFR Part 70 as printed in Volume 37, Number 56, Part III of the Federal Register on Wednesday, March 22, 1972, as set forth in Paragraph 70.11 particular records requested which come within these categories, or portions thereof, shall nevertheless be mace available to the extent, but only to the extent, that the appropriate officer authorised to disclose information from Department records determines that the dis closure will further the public interest and will cot impede the dicharge of any of the functions of the Department of Labor I will appreciate your remittance of $48.20 to this office by certified check or money order, payable to the Secretary of Labor. If you have any questions concerning this matter, please do not hesitate to contact me. ---JL09 185~ K .cVi C T' LAW OFFICES Clint A. Parham Pans A. Parham MAIN BANK OlllLDlNO MAIN AND LAMAR DALLAS* TCXAB 7S3Q3 September lkr 1973 L-yft, mm WSJr BY APPOINTMENT ONLY . ornes phone *' AC 314 94M1AI Consumer Affairs Division Department of Commerce . Capitol Building Washington, D. C. __ * Re: Pittsburgh Corning Corporation Tyler (Cwentown), Texas Dear Sirs; Mr. Linaley G. Beekworth of Longview and I are representing three parties in Workmen's Compensation occupational disease cases in Tyler, Texas. We. have alleged in each of these esses that their condition was caused by asbestos while breathing the same as employees of the Pittsburgh Corning Corporation. * - -- We understand that yeur Division either through the Justice Department or through other agencies recommended or forced the closing of the Pittsburgh Corning Company in Cwentown near Tyler back in the middle 1900's after an intensive investigation of the working conditions with reference to the breathing of asbestos fibres. In order for us to adequately present our cases tp the Court and the jury we would appreciate your arranging to send, to us a copy of an official report, signed by the proper autiiorities that would permit the introi.ua tion of the same into evidence in behalf of our clients at your earliestconvenience. You may feel free to send to us a charge for your fee in the preparation and sending of this report to us, Tours sincerely, ` - CLEIS A. BARHAM DABS A. BARHAM CABies cc Mr. Lindley G. Beckworth, Sr. Ur. Gary Beckworth Mrs. RoGene Belcher Mr. Johnny Rufus Lee Mr. James J. Fitzgerald By. GG 2CI2Q. 7~Bb"0009186 I fe&rv-- f ` i&f v ** f. h t! |T- J Mena to Files Subjects release of informations Pittsburgh Corning, Tyler, Texas A review of this file in conjunction with several articles written for the IKew Yorker Magazine revealed that essentially all of the material requested had been disclosed and published. Accordingly, we advised HEW that the FOLA request could be answered with the exception of the medical and personnel records, which the attorneys understood would not be available except with written permission of the individuals; and the employee lists. i;r. Walderaan advises that he understood that neither of these items, if withheld, would create any problem with the requestor. If there is any problem with regard to further information on this case, HEW will contact us. Sofia ?. Fetters Counsel for Regulation# and Enforcement June 10, 1974 i BB 0009187 I