Document LKdmzNLxDBqpV6BdorpkM945d

SM-32-MC (REV. 4-79) Shell Oil Company Shell Chemical Company Interoffice Memorandum SEPTEMBER 4, 1984 I PLAINTIFF'S EXHIBIT FROM: TO: SUBJECT: SR. INDUSTRIAL HYGIENIST ALL MAINTENANCE MANAGERS PROPOSED CHANGES IN THE DPMC ASBESTOS MEDICAL SURVEILLANCE PROGRAM In early August, Barry Kern MD, Jim Massey and myself met to discuss asbestos medical surveillance for maintenance employees. As you may remember this was highlighted by the 1984 HS&E Corporate Audit. According to Shell Policy, all employees with 0.1 fiber/cc exposure potential (past and current employees) are to be included (See Attachment #1). A significant effort has recently gone into defining who meets this criteria. A report on this work is provided as Attachment #2. For those of you who prefer brevity I direct you to page 7 & 8 of this report, (recommendations). This study revealed the need to expand current medical coverage. This report is provided as background information prior to meeting with you on 9-25-84 at 12:45 pm. Thank you, P.J. Snyder Attachments cc: w/o attachments T.E. Gillespie J.B. Gross MD B.J. Kern MD JVG. Massey `ECB Satellite PJS Chron LAM 001968 DPMC-17658 SM-32 [REV. 5-78) ( Shell Oil Company Interoffice Memorandum JUNE 25, 1980 FROM:. VICE PRESIDENT HEALTH, SAFETY & ENVIRONMENT TO: PRESIDENT-SHELL DEVELOPMENT COMPANY VICE PRESIDENT OPERATIONS VICE PRESIDENT PROD.UCTION-E&P SUBJECT: ASBESTOS MEDICAL SURVEILLANCE ?mAh MTWJlffiL Return tftcument to h e Record Copy in File Information Coov Record Copy m Copy: Circulate: Medical surveillance of workers exposed to asbestos in the course of their* work is mandated by OSHA and Shell, accordingly, has a medical surveillance program in place. A recent coordinated review of Shell's program and policy, together with the regulations themselves, has shown a need to update our policy to ensure that Shell remains in compliance. The revised policy is attached. The principal issue clarified is the definition of "asbestos worker". Should questions arise in implementing this policy within your organizations, the Corporate Medical and Safety and Industrial Hygiene Departments will be pleased to assist. Attachment cc: Messrs. F. H. Richardson P. J. Carroll J. W. Morris V. 6. Whittington D. P. Atwood B. F. Aurelius R. L. Brunner P. A. Dennie A. J. Gonzalez R. E. Joyner, M.D. H. L. Kusnetz L. L. McDowell C. E. Ross, M.D. C. E. Stehr Ms. C. F. hi Hips ,/ ' ' // * L P. F. Deisler, Jr. Lam 001969 DPMC-17659 : - SM-32 (BEV. S-78) c/ x ftzbBzTo s /net) JC 1ER PARK G COMPLEX Shell Oil Company Interoffice Memorandum 1 O-MflP- GJi DECEMBER 16, 1980 S/TAC-S S/TECH-NO I~ S/TECH-SO S/ENG i M/P&GS MJ). FROM: MANAGER, HEALTH & SAFETY, OPERATIONS, HEAD OFFICE TO: SEE ATTACHED DISTRIBUTION LIST [SUBJECT: REVISED ASBESTOS MEDICAL SURVEILLANCE~PROGRAM CTRUt JR. S/S&IH M/CJL S/CHEM Attached is a revised asbestos medical surveillance program. This is the pecond revision since the original 1972 program. The previous revision n December 1977 called for medical surveillance of all current employees kho are regularly exposed to above 0.1 fiber/cc as an eight-hour TWA. {Jhile maintaining that guideline, this revision has been developed to: ) include employees who have had significant exposure in the past; and, ) define more precisely the frequency of exposure required for medical urveillance. s/ex. he current program includes mainly insulators. i~hErngw-programs'ncJudes ^therrcraftjsiwhere people have had or may have exposure in excess of s/m so .1 fiber/cc. Evaluations of various activities have shown that during ip-out or removal of asbestos-containing insulation, potential exposures m/efcs-sd~1ould exceed 0.1 fiber/cc. As a result, i mrotved * i n^th+s^yisesofeactiyaiysfoerthe^ engtlfTSf^tl me:sp5c1^i^dsi-the s/iis f icy^esincTUdetf^fi^thg^^^1^aT^SffrVje'iiiantg7^ro5r3nf. Exceptions to ' Ihis practice are possible if local monitoring data shows that potential IES exposure levels (without regard to respirators) are less than 0.1 fiber/cc. s/oleeiws i request that you provide Dr. Jerry G. Simpson, Corporate Medical jpartment, with a list of employees to be added to the special exam S/REFY ogram. Note that those employees already participating in one of the her special exam programs (e.g., VCM, pesticides, etc.) will not require S/UTIL separate examination. However, the separate Special Asbestos Medical amination Record should be completed for those employees. We also remind you to document for OSHA compliance those employees who opt not to S/M NO participate in the program. The Corporate Medical Department is also m/ets-KQmtdl'fy1 n9 the exam to be more specific for the potential health effects of Asbestos. That modification is explained in the attachment. S/OE s/o w s/lpa lam 001970 e.C'i3, DPMC-17660 irtv. ~-79) # Shell Oil Company Shell Chemical Company Interoffice Memorandum MAY 4, 1984 FROM: TO: SUBJECT: P.J. SNYDER - SR. INDUSTRIAL HYGIENIST B.J. KERN MD - MEDICAL DIRECTOR ASBESTOS SURVEILLANCE The attached work product reflects a review of the DPMC Asbestos Program. As you know the recent Corporate H & S Audit suggested that additional employees be considered for inclusion in the annual medical program. While one would always like to have additional data, I believe we are now in a position to revisit the issue of medical coverage. Since this document is rather lengthy you may find the recommendations on Page 7 of interest. Briefly, the key findings are: 1) Additional employees should have been included in the medical program due to past exposure. I estimate this number at 100. 2) Maintenance personnel other than insulators have brief exposures to asbestos which theoretically could exceed 0.1 F/cc. Medical surveillance should therefore be expanded. 3) A mechanism needs to be established to assure participation in the exam program (eg. are all insulators included?). 4) Recent contract changes (associated maintenance) reinforce the need to consider expanding medical coverage to crafts other than insulators. Lets discuss where we go from here. Phil Snyder Attachment cc: R.R. Erickson J.B. Gross H.L. Lee ECB Satellite PJS Chron LAM 001971 DPMC-17661 DPMC ASBESTOS MEDICAL PROGRAM REVIEW I. INTRODUCTION In 1981 DPMC Management expanded the Asbestos Medical Surveillance Program to. include employees who. worked as pipefitters end boilermakers prior to 1972. This was in addition to the insulators who were previously in the program. An action item for Health and Safety at that time, was to identify crafts who were presently in excess of the criteria for medical surveillance. Generally this 'action level' is defined as 0.1 fibers/cc, 8 hr. TWA, occurring on a "reasonably predictable and repeated basis". This determination had been deferred until additional information could be collected on asbestos exposure. This report addresses this issue and presents recommendations for future medical surveillance. . => ^ _ 1* 2- II. JOBS WITH POTENTIAL EXPOSURE TO ASBESTOS 2/ Historically asbestos exposure has been associated with insulation fabrication, handling, demolition, cleanup, tear-out, re-insulating and from nearby workers engaged in such activities. During the time period 1962 - 1972 the number of crafts and employees potentially exposed was probably increased with the introduction of the "incidental maintenance clause". A rank ordering of past asbestos exposure jobs is provided as Table 1. Jobs with current exposure to asbestos are summarized in Table 2. This summary does not reflect any impact (if any) of the recent "associated maintenance" contract provision. LAM 001972 DPMC-17662 TABLE 1 RANK ORDERING OF HISTORICAL ASBESTOS EXPOSURE Work Group Pre-1972 Exposure To Asbestos 1975 + Insulators Reinsulation & removal Procedures in place Pipefitters Incidental insulation removal Procedures in place Carpenters Cutting transite, lining Procedures in place welding enclosures with asbestos Laborers Work area cleanup Contractor cleanup Pipefitters Boilermakers Welders Entering vessels, furnaces containing asbestos Minimized Welders Asbestos containing fire blankets Eliminated CA Plant Operators 1969 - 1973 Asbestos used routinely Eliminated Epon I Operators Asbestos added to Epocryl 327 Eliminated Mechanics Performing brake jobs Procedures in place to minimize exposure Riggers Removing old exchangers and vessels which were insulated with asbestos Minimized Pipefitters, Machinist, and Boilermakers Cutting, installing and removing asbestos gaskets; sometimes with wire wheels Procedures in place to minimize exposure Warehouse Personnel Handling asbestos gasket sheets, etc. Procedures in place to minimize exposure Tinners Occasional covering insulation Procedures required Operators - Occasional exposure to asbestos if present LAM 001973 DPMC-17663 CURRENT POTENTIAL ASBESTOS EXPOSURE l/> +J 0) tSi .O <0 cn 0) o> > 00 *o o I-- E Z tO 01 UJ S. 5: _c 03 +J >3 o i. *-- *r- o o 4-> z tO to 3 tO 01 to 1-- jr 3 .O 4-> *o 01 c to o to to Ol 01 U S- IO to -- Q. >0 0) e -E 4-> 4- 01 *+-o o -rto -a ai XI CL +-> to 3 S. O <J to io * Zc O -- --i E 1-- <c o Qi to rD 1 oo CO c r-- E in i in >o XI z 4-> LU c => o cr E LlJ \ VC r-- Lu 01 <j r-- +-> J- l- to O 1) >> 1) (J s. c ai O Q- to +J to to to 11 o fl3 r-- +-> to CT*f- to 01 o to XD 01 o> - -Q C o 4-> T3 to c: to to to r-- M- 0) <0 01 -O >- to to > 01 o -x h- to V. -- 11 E to 01 {= > o cn s. M 1-- c o 1-- O to o x: >>4-> r-- +- u .-- CO) OX to O 1-- ai. ___c: - -a r-- OP*r tO M- - to to >o to i-- to o E M- to 3 01 O CO O D 4- oco a: o o *- to , __ r-- CSJ . to <d 01 4-> J- +-> i-- to i- *3" o> 1-- S- o 1 +-> .c a; o<^ zr co c ^ -C to -- +J <L) Q. 4-> X2 U 4-> *r- <D -r- 01 a. +J ! to *0 -r- XI JZ 3J o s. 3 a> 03 tO &- (O tfl 4-> o to o Nl W i. OP c -o 4-> u 00 r* <o a. to oi--* ai 0) C o W O i-r- s. to r-- 4-> "O r1 O 5 T* O p p CO *r t-- r-- *i-- c 4-> "O----- at 03 xi to to to 3 >, O --- a> JI <0 XI to S- r- +-> +-> i- 4-> V. 4-> s. aio uij^ m- c i- +J S- 01 o M i/> i-- 4J< CD.-- ig 3 o in ra oi +-> o> z s to e u .------r- S- O (O .C !-- XI o. isj +-> a> +-> o a;-- o. c +j +-> +-> s- Ni-t->>inifl+->a.o tO C 4J o to ozjos.-- ox.c s. O 3 CO o COU'DlOZBIfl 4-> E o to x: CM 1 C r-- E in to to to e 01 o r-- r-- "O to to a> -rS- +-> > O 03 01 4-> r U to U O O0 3 <o to to to c (O c r- 2 to (A OP 0} 03 "O *ro 4-> 4-> 3 3 to c xi 01 (A "O . 3 r-- 4-* crx: o 3 03 +-> O S- *r* c nv j o to s. 3 O x: i i XI -X 4-> 01 c 01 o E '--- '--- to to 0) +J P" to c to S+-> to o +-> to 01 X3 to to O? C "O r- 01 +j -o 4-3 01 3 11 OC ___ p-- 01 01 O \ 03 X C CM *p- O 1 -o >> +J f-- 01 to r au <0 01 o O "O 1-- O r- O +J -pto 4-> -- <o 3 -- to 3 tO r- p-- to o to +-> o to 4-3 11 to xs ai to to to C to *01 4-3 > iO 01 XI E > 4-> Q) O 'r-- CC OX .--, ,--, i-- CVI +J to >> *0 3 ajx ca X O) iO +J i- *o .c E c to 3 to 5- to 3 to o to a x> to -- 0J > r-- N ro in -r- >1 &. i~ o a; +toJ -r+-> C a; o> `to 3 *F- O a. a to Qj -i-- S-- t- > <+- ia to O <T3 <- a> to u_ j= O E X 00 1 CM to 03 c r-- T- XI p-- o 4-> ai 3 o r-- x: O to 01 to 3 to s. tO JO E 4- 4oO to s. U 03 r- 1- c tO to *CL CL. 01 01 *fO' QI r-- CM . o z| Ol CN. in -- CM CM - VO IO CM ~ O r-- to u ai 1--1 u_ a: to E i. 01 - r-- -M r- L- XI +-> 3 to S- 01 4-> 01 XI Cl 4-i L. L JC 4-> 3 T* - - - - o in in CM i-- ' LAM 001974 co tso. o 4-J to (-- _SI 3 4-> to S- 0o1 to 01 4J XI to 4-> Z 3 to o f-- xto: u o T3 S o 1 l-l tUTJt 0) CURRENT POTENTIAL ASBESTOS EXPOSURE QJ J= s- (XJ s- o 3 +-> QJ to So> O. CO C to I-- r- QJ z +-> S- LU (O to oZD 1 to E to ' +j * c s~ c S- r- OO QJ QJ at e O CL >, c v> a) C i- >- 1--i-eos0 c +-> 0 e qj O .C 0) +> +-> z 0 3-1-0 0. 1 C M LU 1 0 +j O T- zd .e s- o qj qj r tor +j 1 3.0 0 LU t c+ >>- +-> QJ 3ca CC O O -r- 10 S 0 QJ-f Li- Z C WS 4J u) aa > o OJ 1-- OJ l- -i" to r-- tO t/1 to ' 1-- tO QJ QJ CD QJ O >> O <4- w C 1-- <J a) 4- (Or- ro W 4- C ro O 4-> O QJ C to +J O O QJ in >1 at Cr+J O) r- tO tO QJ r-- E -Q -- O ro ro QJ O t/l 10 0 E U .Q +-> tO 3 --(0 OO t(Oo Co QOcJ) l/l T3 4- 3 C O ' to to D)i- ro o c 0) C+J|<c QJ >*r (t<f- 1-- to "3 ro +-> qj <0"O f-- > I *r-- O O > aj to O -X ro oc >c Eo> to c o T- S- E to a> oQ:J r0tJ)01-) to TD ro QJ to -C O 4-J StO QJ QJ O -Q C to ro ro -C U QJ X JC QJ +-> 44-> O to to to f-- +-> ^*TD -QXJ C to (O ro to o> z30c 1 r-- +-> C O O0)) Z to &- QJ tO QJ C S. or c Q) +-> 4-* *-- JD tO 4-> *r- QJ C 4_Q O >, tO -Q >j (O 4-> JD 3 to -- Q. L- "O 00 QJ QJ ^ 1 QJ 4-> O -C o0CT0 jO5-J t4-- *--QQJ.I--o(J to QJ C- I-- $- to r- QJ QJ 2 to c o+-> > E O ro 3 Z r-- ZD O L> '-- 0> SQJ >n O 4-> O 1- to S-. C QJ O C *rC 4-> f-- ro 4-> r-- 3 >> to 1-- c rO C to OO f~ 4-> to to ro QJ O .O U to O rO * CO to r-* co to QJ to s- to Q> L- QJ J= a 4-) 4-> C 4-> c -*-> CL S- 3 I- s- c s- LAM 001975 DPMC-17665 5 HI ASBESTOSIS CASES Ten Shell employees have recently been identified has having radiological findings compatible with a diagnosis of asbestosis (Table 3). Where possible each employee was interviewed to ascertain the known extent of his past asbestos exposures. Copies of these interviews without identifying information are provided (Attachment Case 1 2 3 4 5 6 7 8 9 10 TABLE 3 ASBESTOSIS STUDY 12/83 Years Since First Possible Exposure Years Since Last Possible Exposure Job Assignment Comments 35 35 25 - 30 35 35 30? 35 37 38 10C ,0 Not Determined 6 6 10C 10C 35 37 34 Insulator Pipefitter Engineer Insulator Exposure prior to Shell signif. Insulator Exposure prior to Shell signif. Pipefitter Boilermaker Pipefitter 1 Yr. probable exposure Welder Repairman/ Boilermaker LAM 001976 DPMC-17666 6 In all cases the interviewee described early work activities that could have had high exposure, albeit frequently of short duration. A review of the jobs worked by these individuals offers an opportunity to consider what pre-1972 crafts other than pipefitters, boilermakers and insulators should be identified for the asbestos examination program. IV. EXPOSURE LEVELS The available asbestos monitoring data reveals considerable variation in exposure levels depending on wind conditions, work location, removal procedures, etc. (Attachment II). While exposures infrequently exceed the current OSHA limit of 2 F/cc, 8 Hr. TWA, exposures associated with asbestos removal wet or dry occasionally may exceed the medical surveillance criteria of 0.1 F/cc. In part, this is a function of the amount of time involved in insulation removal. To further understand the benefit of wetting insulation prior to removal, a controlled test was set up. The results, as shown in Table 4, indicate that water helps but does not guarantee acceptable exposure levels. The work situation simulated was that of loosening the insulation with a wrench and removal by hand. Reportably pipefitters currently engage in such an activity l-4X/month for 5-15 minutes each time. This would be especially true for overtime pipefitting work. TABLE 4 MOCK ASBESTOS INSULATION REMOVAL JANUARY 1984 Air Concentration .94 F/cc 3.22 F/cc 1.33 F/cc .44 F/cc Sampling Time 11 Min. 11 Min. 10 Min. 10 Min. Work Activity Simulated Asbestos insulation inside bldg, was wet with water, loosened with a wrench and removed by hand. Same as above but not wet prior to removal. Asbestos insulation outside was wet with water, loosened with a wrench and removed by hand. Same as above but not wet prior to removal. LAM 001977 DPMC-17667 7 Considering this limited assessment and the data presented in Attachment II one may conclude that any insulation removal (wet or dry) may result in a "peak" asbestos exposure between <.l - 10. F/cc. This upper range would be a probably worse case exposure for partially wet or dry insulation. If this exposure occurred for an estimated ten minutes then the 8 hr. TWA range would be: (.1 F/cc)(10 Min.) (480 Min.) =<.l F/cc <.l upto (10 Min.)(5-10 F/cc) (480 Min.) .1 - .2 F/cc Although the actual exposure would be less if a respirator was worn, the criteria for medical surveillance would apply irrespective of respirator use. % V RECOMMENDATIONS 1. The following crafts should be added to the Asbestos Medical Program based on current exposure potential. ** Insulators (verify participation) Maintenance personnel expected to or permitted to remove or cut asbestos more than 5 days per year. f Pipefitters 'Tinners ' Carpenters Mechanics 2. The following employees should be added to the Asbestos Medical Program based on past exposure potential. Employees who worked prior to 1972 as: Pipefitters - Verify Boilermakers - Participation Carpenters Welders Epon I Operators (Attachment IV) CA Plant Operators (1969-1973) Laborers LAM 001978 DPMC-17668 8 3. Per the DPMC Asbestos Order, annual asbestos training should be provided to current Pipefitters Carpenters Tinners Insulators Mechanics Warehousemen 4. All future "presumptive cases of asbestosis" should be identified and interviewed in regard to past asbestos work. 5. To comply with the OSHA Asbestos Regulation the following jobs must be monitored every 6 months, (1 day survey) Tinners - Covering insulation Insulators - Asbestos removal work Carpenters - Cutting transite Maintenance needs to assist Industrial Hygiene by coordinating air sampling and the field work. 6. Annually maintenance should review participation in the medical program for the jobs identified in #1 above. LAM 001979 DPMC-17669 ATTACHMENT 1 9 Previous Employment: No application located. Date 7m 3/48 8/48 8/49 12/52 2/53 Occupation General Helper Pipefitter Helper No.2 Asbestos Helper No. 2 Insulator Helper Insulator No.2 Insulator No.l Department Utilities Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Location Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Narrative From Interview: 4/10/84 This employee has been assigned to the shop for the last 3 years. His work mostly involves fabrication of elbows, etc. The use of a vacuum on the saw has helped considerably over past practices (before 1970). There is only one shop insulator, the rest work in the field. According to this insulator the wetting of asbestos prior to removal doesn't always work. One can't wet the insulation all the way through and some dust is initially generated when the metal cover is removed. Before 1974 his exposures were sometimes significant, and more frequent (less asbestos in the field today). In vessels insulators would sometimes breathe through rags (when the dust was annoying). Today pipefitters will sometimes remove asbestos without following precautions. Relatively speaking they (the pipefitters) have the second highest exposure potential. Most older insulators can tell the difference between asbestos and non-asbestos insulation. However, operators don't know what areas contain asbestos and don't generally identify it for them. This employee stated that the craft foremen were pretty strict on following the work practices. 2) mm Previous Employment: 9/43 - 2/43 Jess McNeil - Tractor Operator 1/44 - 7/46 US Marines - Telephone installer 7/46 - 7/48 Westinghouse Electric - Installer Date im 8/48 2/49 2/53 2/53 Occupation General Helper Pipefitter Helper No.2 Pipefitter Helper No.l Pipefitter No.2 Pipefitter No.l Department Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Location Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Interview: This employee declined to discuss asbestos. LAM 001980 DPMC-17670 10 3) No previous employment reported. Date W 6/50 8/51 8/52 6/53 1/54 1/56 2/58 3/59 3/60 6/61 6/64 7/65 7/68 7/70 9/73 4/77 Occupation Department Location Jr. Lab Assistant Mfg. Research Lab Houston Refinery Lab Assistant Mfg. Research Lab Houston Refinery Technician Lab Mfg. Research Lab Houston Refinery Military Reserve (8/10/52 - 8/25/52) Military Reserve (6/7/53 - 6/23/83) Military Leave Released to return to school. Technologist Technologist Technologist Technologist Engineer Engineer Sr. Engineer Group Leader Process Manager Process Manager 4) Previous Employment: "Insulator. 24 years.experience in Chemical Plant". (Diamond Shamrock, Painesville Works) Navy: Radioman Date 2777-83 Occupation Insulator No. 1 Department Maint. Engr. Location DPMC Narrative Fr-om Interview: 4/10/84 Worked at Diamond Shamrock (Ohio) as an insulator between 1953 and 1976. Even in 1974-1976 they had no required precautionary procedures as does Shell. Insulators were only told about the hazard of asbestos not required to do anything different. This individual indicated that he always had used a "paper type" (Martindale) respirator even at Diamond. Much of his work at Diamond involved cutting and fabricating insulation outside. This employees assignments today are predominately at Resins. Some areas have asbestos, some don't. He encounters asbestos occasionally as during dismantlements and shutdowns. This employee stated that he was glad that he has had no effects from his past exposure (evidently he has not experienced overt symptoms from his asbestosis). He currently smokes less than 1 pack a day. lam 001981 DPMC-17671 11 Regarding current work practices he stated that the "wet procedure" is pretty effective in reducing dust levels. Residual asbestos on piping is hosed off. This employee appeared to be reasonably knowledgeable of asbestos' hazards and very aware of the hazard associated with contaminating his work clothes. He did indicate, however, that for small jobs coveralls would not be used. He is careful that his family doesn't handle his work clothing. This employee further indicated that the management of contaminated clothing isn't stressed by Shell. He occasionally brings contaminated garments to the Tool Room in unlabeled bags. He doesn't use paper coveralls because they lack pockets. Regarding other crafts, he indicated that pipefitters don't have respect for asbestos. He occasionally has to get fitters out of an area where insulation is being removed. Overall, this insulator stated that Shell had a pretty good safety program, with one exception. At Diamond Shamrock walking through roped off areas and not posting areas when work was going on overhead wasn't tolerated by management. 5) CaES&tfigigiSSt Previous Employment: 4/1/48 - 1976 Insulator Group Leader at Diamond Shamrock. Date 2/77-83 Occupation Insulator No. 1 Department Maint. Engr. Location DPMC Narrative From Interview: 4/10/84 He has worked at Diamond Shamrock since 1948. Also wore respirators about as often as he does now at Shell. However, he runs into less asbestos at DPMC since it is slowly being replaced. He changes his clothing in the Carpenter Shop (not the changehouse), but he does shower before leaving work. Contaminated clothing is given to the Tool Room for cleaning in labeled bags. Regarding pipefitters, he suggested that their asbestos exposure is about 5 minutes per day on days when they encounter it. In some occasions this may be extended especially on overtime work. By personal observation pipefitters don't always use respirators. Sometimes it is difficult to tell whether or not insulation is asbestos especially if the covering metal is new. This probably presents a greater problem to new, younger pipefitters. LAM 001982 DPMC-17672 12 6) SE23ES?. , Previous Employment: 9/47-6/48 General Helper, C.F. Braun, LaPorte,Tx. 8/46-9/47 Truck Driver, Dayton, TX. Date W 7/48 12/48 2/53 9/53 Occupation General Helper Pipefitter Helper No.2 Pipefitter Helper No.l Pipefitter Helper No.2 Pipefitter No.l Department Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field (IC) Location Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Narrative From Interview 4/9/84 Since 1948 this employee has worked as a pipefitter. In reference to early asbestos exposure, he described working along side insulators and personally removing asbestos as necessary. On occasion the clothes he wore home were "white" with insulation. This employee noticeably becomes short of breath upon exertion. He described his present difficulty in climbing pipe racks. He now has to stop to catch his breath before proceeding with the work. This employee indicated that he has never smoked. Reportably the asbestos exposure today (in comparison to the past) is like "day and night". This improvement is mostly attributable to the current practices followed by insulators, (which began about 8 yrs. ago). Current asbestos jobs include: 1) scraping (sometimes sawing) off gaskets and 2) removing insulation (5-10 min. jobs). Sometimes water is used to remove asbestos, sometimes not - depending on the individual. . A pipefitter may remove asbestos 2X/week. As this employee has worked OP-II since 1969, the above description of current practices would only apply to the Olefins OP-II area. This employee ranked pipefitters as having the second highest exposure potential (after insulators). Respectively #3 and #4 were boilermakers and machinists. Prior to Shell this individual worked for C.F. Braun as a brickmason helper. No asbestos exposure was attributed to this job. LAM 001983 DPMC-17673 13 7) Previous Employment: 46-47 Self employed mechanic. 1/51-7/52 Millwright at Portland Cement Millwright at Ethyl Corp. Millwright at Rheem Manufacturing Date JT52 10/52 10/52 1/53 1/53 4/53 9/53 5/54 6/60 8/63 8/66 12/66 7/67 6/68 10/68 Occupation General Helper Loader General Helper Truck Driver No.2 General Helper Loader Boilermaker Helper #2 Boilermaker Helper #1 Boilermaker #2 General Helper Operator #2 Loader Operator . Loader Boilermaker Department Eng. Field Shipping Eng. Field Eng. Field Eng. Field Shipping Eng. Field Eng. Field Eng. Field Eng. Field P Operations Shipping Shipping Shipping Maint.Eng. Location Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Narrative From Interview 4/9/84 As a General Helper, this employee primarily assisted the boilermakers, pipefitters and machinists. His contact with asbestos during this time was related primarily to working in areas where asbestos was being removed. At times it would look like "snow falling from overhead". Boilermakers frequently knocked off asbestos insulation to get to the heads of exchangers or boilers. This employee recalled having his clothes covered by asbestos on occasions. Respirators were not available until early 70's, however, goggles were the only way to keep it out of eyes and sometimes a rag would be tied around the nose and mouth if conditions were intolerable. When asked the difference between conditions of earlier years 50's & 60's and today, this employee said "There is no comparison between how it was then and now". He was referring to the work practices which require it to be wet, bagged, with coveralls and respiratory protection. The frequency of boilermakers having to remove the insulation has also been dramatically reduced because there "just isn't as much asbestos around". Occasions may still occur but they are infrequent compared to earlier years. This employee believes the pipefitters and boilermakers to be second only to the insulators in asbestos exposure. The areas this employee worked were field assignments all over the Chemical Plant. He was a Plannable Boilermaker for several years. Since 1983 he has been assigned to E Maintenance. Regarding the time spent as a Loader in Shipping Dept, he commented on exposure to BPA and resins dusts in the Warehouse. LAM 001984 DPMC-17674 14 8) jjy nr ny-xftt*.: Previous Employment: 7/40-7/42 Westinghouse Electric - Motor Repairman 7/42- 11/45 U.S. Navy-Radioman 1/46-3/48 The Texas Co.-Painter Date 5/48 8/48 9/52 10/52 2/56 6/56 11/76 Occupation General Helper Pipefitter Helper No.2 Pipefitter Helper No.l Instrument Man Help.No.2 Instrument Man Help.No.l Instrument Man No.2 Instrument Man No.l Instrument Man/Foreman Department Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Location Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Interview: Not Conducted (Retired) 9) Previous Employment: 8/46-7/48 The Texas Co. - Tank Truck Operator 4/46-8/46 H.H. Hardy - Guniter* *Reason for leaving was "doctor advised". Date 77W 9/48 9/48 9/48 2/53 5/68 Occupation General Helper Loader General Helper Welder Helper Welder No.l Wel-der/Craft Foreman Department Eng. Field Shipping Eng. Field Eng. Field Eng. Field (IC) Eng. Field Location Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Narrative From Interview 4/9/84 This employee clearly remembered working with an insulator in the removal of asbestos at G Plant during the first week of employment. During this initial 3 month assignment as a general helper and loader, he had "a few days" of definite exposure to asbestos. His assignment as a welder since 1948 was associated with asbestos exposure upto the time period when its hazards were better managed (early 70's). Welder field assignments did not actually involve insulation removal. However, after insulation was removed he would have to work in areas which were contaminated with the asbestos. On at least some occasions the loose asbestos would be on scaffolding (some jobs required him to work lying down on contaminated surfaces). This welders work historically has been associated with furnaces and reactors. This employee noted welders past use of asbestos fire blankets and gloves. Before asbestos controls were put in place asbestos contaminated piping was brought into the shop. As in the field the loose fibers after the insulation was removed resulted in some potential exposure. This employee has predominately worked in the shop since 1974. Prior to Shell he worked for H.H. Hardy as a guniter and could not recall any exposure to asbestos. LAM 001985 DPMC-17675 15 10) 5s*S15SSC&3E35S3 Previous Employment: 12/43-4/44 Worked on fathers farm. 9/41-1/43 Dairy Work 9/43-12/43 North American, Dallas - Plating and Buffing Has been at Sulfur Springs with father since 12/43. Date W 8/45 1/46 8/46 6/48 6/49 1/72 2/74 2/77 11/80 Occupation General Helper Repairman Helper General Helper Boilermaker Helper Boilermaker No.2 Boilermaker No.l Craft Foreman & BM #1 Zone Foreman Foreman DPC (Zone A) Maintenance Foreman Department Gas Car Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Maint. Eng. Maint. Eng. Int.& Solv. Location Houston Refinery Houston Refinery Chemical Chemical Chemical Chemical Chemical Chemical Chemical Chemical Narrative From Interview 4/18/84 - This employee is currently a multi-craft foreman in A Maintenance. He worked as a boilermaker in the Chemical Plant from 1946-1974. One significant recollection this employee had about asbestos was how craftsmen would often use air hoses to blow the insulation away from their immediate work areas. He also recalled using a hammer to remove asbestos insulation around the bolts on exchanger heads. The cleanup of stripped insulation was poor. "Unless it was a tripping hazard, it was left in the area". When asked which crafts were probably exposed the most frequently he named pipefitters and boilermakers as second and third to the insulators. Today he feels the usage of proper protective controls is about 80% by all of the crafts. The "associated maintenance" which is now in effect he feels will involve additional crafts in insulation contact ie. instrument men, electricians, machinists. This employee was not aware that an annual training requirement exists for asbestos at DPMC. He feels that reinforcement of training is very important and suggested that our department design a presentation for all of the crafts which includes demonstrating how indestructable asbestos is. Regarding protective clothing for asbestos he felt that paper coveralls should be specified for asbestos work because they can be disposed of. He commented that if craftsmen wear cloth coveralls for asbestos that they are likely to keep them on for the duration of the day. LAM 001986 DPMC-17676 16 Additional Interview: 4/19/84 (Not An Asbestosis Case) This employee is currently an hourly maintenance foreman at Aromatics. Since 1976 he has worked as a pipefitter in Maintenance East. The frequency of contact an individual pipefitter might be involved in an asbestos related job this employee estimated as once or twice a month for 15-20 minutes. The practice used today is to have the insulation checked to determine if it is asbestos before performing the work. If this cannot be done it is assumed to be asbestos. Pipefitters may not always wear coveralls, however, most will wear a respirator and sometimes wet the insulation and cover the ends to keep it from shaking out while performing their work. This employee did recall an occasion where he found out after the job that the insulation was asbestos and no protective clothing was worn. For most of the jobs he plans now he tries to have the insulation removed in advance to avoid having other crafts exposed to asbestos during insulation removal. (This was done recently in preparation for the Aromatics' Shutdown). He personally does not beat off insulation with tools but will use a saw or cut it to minimize dust because he has to clean up his own mess. This employee is not presently in any of the medical programs at DPMC. He feels that pipefitters and boilermakers with service prior to 1975 should be included in an asbestos medical program and that perhaps a random number of various craftsmen could be included post 1975 Asbestos Medical Program. He does not-think the "associated maintenance concept" will be affected any differently in regard to asbestos exposure. He also mentioned that craftsmen working in the Utilities may have more frequent contact with asbestos. When asked the order he would rank different crafts exposed to asbestos he named insulators #1, laborers #2, carpenters #3 and all of the other crafts #4. Overall the craftsmen are pretty knowledgeable about asbestos. It is frequently discussed in Safety Meetings. Practices probably vary depending on individuals and foreman but generally precautions are followed, to his knowledge. LAM 001987 DPMC-17677 Cleanup Date 1972 DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study 11/72 11/72 11/72 7/78 7/78 7/78 7/78 7/78 7/78 Demolition 1972 DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study ATTACHMENT II HISTORICAL ASBESTOS BREATHING ZONE EXPOSURE DATA 17 F/cc 4.5 1.5 2.7 1.0 1.6 .3 1.43 1.36 4.5 1.6 .15 .32 .35 0.01 0.04 0.01 0.01 0.02 0.04 Sampling Time 2 Min. 7 5 6 17 35 22 22 15 31 22 16 30 190 190 180 190 120 no Activity Type Field cleanup Unibestos Field cleanup Unibestos Field cleanup Unibestos Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Cleanup Thermobestos Cleanup Thermobestos Installing Thermobestos insulation (EA) Christensen Laborers Cleaning up asbestos insulation during demolition of water softeners (Wet) 2.55 2.62 .16 .93 .54 1.64 .85 1.01 .51 1.77 .26 1.76 1.02 1.63 15 15 15 15 9 9 15 15 15 15 9 9 11 11 Removing from charge pump Removing from transfer line Removing from exchangers II II II II II It II II Unibestos Firetard cover ing and block insulaII tion II II II II II II II LAM 001988 DPMC-17678 18 Date F/cc Sampling Time Demolition (cont'd) Christenson Co. - Utilities/Water Treaters 7/78 .02 120 7/78 7/78 7/78 7/78 7/78 .01 190 .04 190 .01 180 .01 190 .04 no Activity Cleanup of wet insulation If 11 II II II Type Carpenter Const. Insulators - 1978 Demolition of Water Softeners 8/78 8/78 8/78 8/78 0.17 0.09 0.73 0.54 195 Min. 165 200 150 Stripping insulation from water softeners (Insulation wet) MIMI 1Pipefitters At Sulfur Recovery Unit/EP 8/78 8/78 8/78 9/78 9/78 8/78 10/78 .03 130 .20 120 .14 125 .39 125 .14 120 .25 123 .18 132 Removal and disposal of asbestos insul ation off piping in . wet condition B & R Insulators at DU 1 & 3 3/80 3/80 3/80 .02 115 .01 150 .01 180 Stripping insulation from column. II B & R Insulators during DU-2 Shutdown 4/83 4/83 4/83 0.15 0.10 0.12 445 435 451 Stripping insulation off piping - wet. B & R Insulators at Thermal Cracking 5/83 5/83 5/83 5/83 0.38 0.21 0.37 0.65 420 420 420 420 Stripping insulation off piping - wet. LAM 001989 DPMC-17679 Date Replacement 1972 DOSH Study (File 752) Fabrication 1972 DOSH Study 11/72 11/72 4/79 F/cc .45 1.5 .72 1.24 1.34 1.98 .20 .45 .36 .43 .13 .13 .16 .37 1.28 1.1 Sampling Time 19 19 37 37 15 15 40 30 10 90 120 85 20 30 19 19 Activity Wiring used insulation in place. 19 Type - Unibestos Cut fabrication of insulation in Shop. Saw has exhaust ventilation Thermobestos (6% asbestos) Cutting and handling outside. Cutting outside at Solvents & Treating. Thermobestos Transite LAM 001990 DPMC-17680 o ft/', 'i '/V / /'/. o Shell Oil Company o Shell Chemical Company Inlirolllce Wcmof/indum FEBRUARY 13, 1981 PRIVATE AND CONE1DKHTTAL FROM: SUPERINTENDENT S & IH TO: COMPLEX MANAGEMENT TEAM SUBJECT: REVISED ASBESTOS MEDICAL SURVEILLANCE PROGRAM 76 Corporate Medical issued a revised asbestos medical surveillance policy late last year which included in addition to "insu.lators" who are the . . only craft currently included in the Shell asbestos medical surveillance program, other employees who'may also be exposed to asbestos as a result of their work activity. A review was made with both Maintenance - North and South of work activities prior to and following 1972. The year 1972 was used since there was a step change made in our handling of asbestos containing materials at that time. Based on this review, the following recommendations are offered: 1. Include in the asbestos medical surveillance program all pipefitters and boilermakers still with Shell who were working in these crafts prior to 1972. It is estimated that we have about 94 employees (bi> South and 39 North) that meet this criteria. 2. Initiate an expanded asbestos monitoring program to es tablish more firmly whether or not we are meeting the permitted exposure limits for employees working these crafts today. The limited data we have suggests that v/e are within the permissible exposure levels. Conse quently, no action is proposed for the employees who entered these crafts subsequent to 1972 until the addi tional monitoring has been completed. Inclusion of the craftsmen meeting the 1972 criteria in the asbestos medical surveillance program should be initiated early this year. The following plan is proposed for accomplishing this objective: 1. Identify the employees in the two crafts. 2. Advise the Workmen's Committee Chairmen and the H & S Consult tees of the revised policy. 3. Meet with the affected personnel and advise them of the now program. LAM 001991 DPMC-17681 O CMT o 2 4. Medical set time for examination, if required, and if not, a time for consultive session. 5. Issue bulletin on revised program with a follow up hazardous material bulletin outlining synergism of asbestos and smoking, etc. Be glad to discuss. k. y. i-rutiger RPF:cfh cc: M. T. Anderson D. O. Chrismer J. G. Massey F. G. Reitz P. J. Snyder -Medical Dept. i',|fmnwnTBUjmuw v ? s j w w ' - ' g w j - LAM 001992 r DPMC-17682 oo SHELL ASBESTOS MEDICAL SURVEILLANCE PROGRAM Pertinent Background Facts on Asbestos - Asbestos is a human carcinogen. Inhalation may cause lung cancer, mesothelioma, and other diseases such as asbestosis and pleural lesions. - Generally, the incidence of cancer and asbestosis among occupationally exposed persons increases with increasing intensity of exposure; the inhalation of high concentrations for short durations may be as * harmful as prolonged exposure to low concentrations. - From all available evidence, the period between first exposure to asbestos and death from lung cancer appears to be related to intensity of exposure. A latency period approximating fifteen years is probably the minimum for asbestos-related lung cancer. - Tobacco smoking increases the incidence of lung cancer and complicates asbestosis among asbestos workers. Regulatory Background - Permissible exposure limits to airborne concentrations of asbestos fibers are defined by OSHA standards (29 CFR 1910.1001) as follows: a) Permissible exposure level -- "The 8 hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed two fibers, longer than 5 micrometers, per cubic centimeter of air..." b) Ceiling concentration -- "No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers, longer than 5 micrometers, per cubic centimeter of air..." - Per OSHA Program Directive #300-16 dated October 11, 1978, titled, "Minimum Airborne Fiber Concentration For Initiating and Continuing Asbestos Medical Examinations", the term "...exposed to airborne concentrations of asbestos fibers..." is administratively interpreted to mean "...exposed to a minimum of 0.1 asbestos fibers longer than 5 micrometers per cubic centimeter of air..." on a time weighted average basis. Shell Concerns - Surveys now indicate that in addition to "insulators" who are currently included in our asbestos medical surveillance program, other employees such as pipefitters, riggers, etc. may also be exposed to asbestos as a result of their work activity. - Our current medical surveillance program does not satisfactorily address the question of past exposure to asbestos. LAM 001993 DPMC-17683 oo 2 - Employee training programs for asbestos have not sufficiently emphasized the known synergism between asbestos exposure and smoking. Objective Revise existing asbestos medical surveillance policy in order to correct any deficiencies and fully address the concerns described above. Policy - Employees whose present job assignment results in exposures to asbestos of 0.1 fibers, longer than 5 micrometers, per cubic centimeter (TWA) or greater (regardless of respirator usage), on a reasonably predictable and repeated basis,* shall be included in Shell's annual asbestos medical surveillance program. - Employees, who can be identified as having had job assignments in the past, in which exposures can be determined as probably exceeding 0.1 fibers, longer than 5 micrometers, per cubic centimeter (TWA) or greater (regardless of respirator usage), on a reasonably predictable and repeated basis,* shall also be included in an annual asbestos medical surveillance program. - Available exposure data indicate that exposures during "ripout" or removal of asbestos-containing insulation may exceed 0.1 fibers per cubic centimeter. Accordingly, all employees, regardless of job title, whose work assignments now or- in the past, would involve "ripout" or removal of asbestos-containing insulation, on a reasonably predictable and repeated basis,* are to be included in an annual asbestos medical surveillance program. - Employees who have been in an asbestos medical surveillance program prior to employment with Shell shall be included in Shell's annual program. - Once an employee has been included in an asbestos medical surveillance program, the surveillance should be continued throughout the term of his or her Shell employment. Upon leaving Shell, each employee who has been included in an asbestos medical surveillance program shall be administered according to the Shell pre-separation counseling or extended medical surveillance program policy (post-retirement physical examinations), whichever is appropriate. LAM 001994 * The phrase "reasonably predictable and repeated basis" is currently interpreted for present job assignments, to mean at least eight hours of exposure per calendar quarter. For exposures that have occurred in past job assignments, "repeated" shall mean at least two calendar quarters. It should be recognized that these exposure criteria represent an administrative judgment, since minimal exposure levels required to cause disease are not kno-wn with certainty at this time. This administrative judgment may be revised in the future, with the concurrence of Corporate Medical, Toxicology, Safety and Industrial Hygiene and the affected functional management. DPMC-17684 oo 3 Implementation: Suggested Action Plan/Guidelines - Evaluate exposures and identify employees whose job assignments, now or in the past, result in exposure to asbestos as defined in the Policy, and include them in the annual asbestos medical surveillance program. - Due to the varied nature of potential exposure throughout Shell, there may be specific employee concerns that will require the prudent, balanced judgements of both functional management and the Head Office Corporate Medical and Safety and Industrial Hygiene Department. Full consultation, prior to arriving at a decision, is encouraged in these cases. - For the above identified employees, provide improved training and information to emphasize: a) Synergism of asbestos and smoking, b) Need for participation in medical examination programs. - Review current operating procedures for reducing or eliminating physical contact between asbestos fibers and employees. J LAM 001995 DPMC-17685 w vV UJ on Z3 to o o. 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OJ 1 OJ >>gj p v to X Q CVJ to 03 c *p c r-- t-- u +-> OJ 3 o p-- zO to r OJ to 3 to C u to JO E 4- 4oO to s- s_ o> p 1- c to tO *" Q. o. c OJ OJ fac oc-- o CM vo CM VO VO CM i-- (O SOJ to E U 0> ^ u_ 1-- +-> a: r- S- DC o o O CD Z x: +-> 3 O to to u QJ +-> c OJ -C Q- +-> S- u to o oz x: 4-> 3 O CO o in CVJ i-- in oo LAM 001996 to u o *p> tO 1-- -C 3 P> to co t-- z OJ o c to c OJ +J c -C to -m s: 3 o o: CO ^ to --u on r-- C o9 to -C CD U oj in a 3 a i i- 05 CD CD CURRENT POTENTIAL ASBESTOS EXPOSURE OO LU z z o o in az i in OJ JZ i- 10 * t- O J +* a; to o> s- r-- O) OL c to i- oj +J Sto <0 0) *-- c -Q 1"O r-- c s. 0 *-- tO 10 4- J**- O 52 i in to s- 3 O =c I icf--- oot- ooc <D E <CuD as0J)- o Q. > c v> at c S- >" i-t-COS- o JZ 0) o C+J O C 0) +J +J z o a o a. 1 C 4-> LU 1 O +J O i- L. ID ai l JC E M- O' +-> 1 =3 jQ O 4- <D LU S- C 4-> >>i- 3 i- a. OC o o i- ie 3 o CD r u. ZCKlZf CO CL CL >> "O o >> <d o *- a; a; tf- to C f" o 0) M-- 10 -- tO to -C M- C <0 0) c to +> O *-> O M O O O c --+-> cn i-- tO tO tO >> CD 0) -- E Q i-- O 10 10 O O E O JQ +J to co o (0 3 O to 0) to -o r-- O 10 C 0> 4- 3 C <0 oc --------- 10 to 0)*r lO o c C <D C +J -- *r <0*L 1-- to *o to +* 0J "O i-- > p- > 0) to f- O O 3 <0 U > E ifl C C tD c o O -X <0 E lO CL) 0) C0 $- i--i i-- L *r +J q: 0)0) ^ i-- CSI to T3 <0 ito a> cu o> .a c to 10 to -C u a> x J= CD 4-> <4- +J O to C0 to 1-- +> -Q 0) -a ^ C to CO co cn a> r--> JC 4-> C O z </> Sai /i a) e s- or c v +-> +J -r- X) VI +J `I-- 0) C 4J3 O >i (/) -Q >, lO 4-> -Q 3 tn i- a i-T) . oo ai <d "--* 1 0J -t-> O -E O S- oo " >-- o cn 2 4- Q..-- i-- s- r-- J- c r- ai a> 3 E o <o E O 3 3E -- ZD O O--- 05 i-- S-. aj > JC O 4-> U i- to L. C CD O C -rC 4-> f" CO -- 3 >, to r-- C r-- *rC0 C CO oo I- +J to to to 0) C CJ to *r- O <0 +-> CSJ 00 in CO P'S* r-- lO s- 0) 4J 4-> r- CO s. to <D s. x: <c CtL O CQD. 4SJ- nQ-. o Z JC +-> 3 O OO +-> JC C +-> s. tO O a. z 0) -c C 4J c s1- o 1-- z LAM 001997 DPMC-17687 Air Concentration .94 F/cc 3.22 F/cc 1.33 F/cc .44 F/cc MOCK ASBESTOS INSULATION REMOVAL JANUARY 1984 Sampling Time 11 Min. 11 Min. 10 Min. 10 Min. Work Activity Simulated Asbestos insulation inside bldg, was wet with water, loosened with a wrench arid removed by hand. Same as above but not wet prior to removal. Asbestos insulation outside was wet with water, loosened with a wrench and removed by hand. Same as above but not wet prior to removal. LAM 001998 DPMC-17688 Cleanup Date 1972 DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study 11/72 11/72 11/72 7/78 7/78 7/78 7/78 7/78 7/78 Demolition 1972 DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study HISTORICAL ASBESTOS BREATHING ZONE EXPOSURE DATA F/cc 4.5 1.5 2.7 1.0 1.6 .3 1.43 1.36 4.5 1.6 .15 .32 .35 0.01 0.04 0.01 0.01 0.02 0.04 Sampling Time 2 Min. 7 5 6 17 35 22 22 15 31 22 16 30 190 190 180 190 120 110 Activity Jm. Field cleanup Unibestos Field cleanup Unibestos Field cleanup Unibestos Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Cleanup Thermobestos Cleanup Thermobestos Installing Thermobestos insulation (EA) Christensen Laborers Cleaning up asbestos insulation during demolition of water softeners (Wet) 2.55 2.62 .16 .93 .54 1.64 .85 1.01 .51 1.77 .26 1.76 1.02 1.63 15 15 15 15 9 9 15 15 15 15 9 9 n li Removing from charge pump Removing from transfer line Removing from exchangers 11 tl It tl tl Unibestos Firetard covering and block insulation It LAM 001999 DPMC-17689 Date F/cc Sampling Time Activity Demolition (cont'd) Carpenter Const. Insulators - 1978 Demolition of Water Softeners 8/78 8/78 8/78 8/78 0.17 0.09 0.73 0.54 195 Min. 165 200 150 Stripping insulation from water softeners. (Insulation wet) Type B & R Insulators at DU 1 & 3 3/80 3/80 3/80 .02 .01 .01 115 150 180 Stripping insulation from column. II _ - B & R Insulators during DU- 2 Shutdown 4/83 4/83 4/83 0.15 0.10 0.12 445 435 451 Stripping insulation off piping - wet. B & R Insulators at Thermal Cracking 5/83 5/83 5/83 5/83 0.38 0.21 0.37 0.65 420 420 420 420 Stripping insulation off piping - wet. Replacement 1972 D0SH Study (File 752) .45 1.5 .72 1.24 1.34 1.98 19 19 37 37 15 15 Wiring used insulation in place. Unibestos LAM 002000 DPMC-17690 Fabrication 1972 DOSH Study 11/72 11/72 4/79 .20 .45 .36 .43 .13 .13 .16 .37 1.28 1.1 JEB02/10 3-28-84 40 30 10 90 120 85 20 30 19 19 Cut fabrication of insulation in Shop. Saw has exhaust ventilation Thermobestos (6% asbestos) . Cutting and handling outside. Cutting outside at Solvents & Treating. Thermobestos Transite LAM 002001 DPMC-17691 TABLE 2 RANK ORDERING OF HISTORICAL ASBESTOS EXPOSURE Work Group Pre-1972 Exposure To Asbestos 1975 + Insulators Reinsulation & removal Procedures in place Pipefitters Incidental insulation removal Procedures in place Carpenters Cutting transite Procedures in place Laborers Work area cleanup Contractor cleanup Pipefitters Boilermakers Welders Entering vessels, furnaces containing asbestos Minimized Welders Asbestos containing fire blankets Eliminated CA Plant Operators 1969 - 1973 Asbestos used routinely Eliminated Epon I Operators Asbestos added to Epocryl 327 Eliminated Mechanics Performing brake jobs Procedures in place to minimize exposure Riggers Removing old exchangers and vessels which were insulated with asbestos Minimized Pipefitters, Machinist, and Boilermakers Cutting, installing and removing asbestos gaskets; sometimes with wire wheels Procedures in place to minimize exposure Warehouse Personnel Handling asbestos gasket sheets, etc. Procedures in place to minimize exposure Tinners Occasional covering insulation Procedures required Operators " Occasional exposure to asbestos if present LAM 002002 DPMC-17692 Previous Employment: No application located. Date 2/48 3/48 8/48 8/49 12/52 2/53 Occupation General Helper Pipefitter Helper No.2 Asbestos Helper No. 2 Insulator Helper Insulator No.2 Insulator No.l Department Utilities Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field ~'^location Houston Refinery Houston" Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Narrative From Interview: 4/10/84 has been assigned to the shop for the last 3 years. His work mostly involves fabrication of elbows, etc. The use of a vacuum on the saw has helped considerably over past practices (before 1970). There is only one shop insulator, the rest work in the field. According to this insulator the wetting of asbestos prior to removal doesn't always work. One can't wet the insulation all the way through and some dust is initially generated when the metal cover is removed. Before 1974 his exposures were sometimes significant, and more frequent (less asbestos in the field today). In vessels insulators would sometimes breathe through rags (when the dust was annoying). Today pipefitters will sometimes remove asbestos without following precautions. Relatively speaking they (the pipefitters) have the second highest exposure potential. Most older insulators can tell the difference between asbestos and non-asbestos insulation. However, operators don't know what areas contain asbestos and don't generally identify it for them. M. Crosby stated that the craft foremen were pretty strict on following the work practices. Previous Employment: 9/43 - 2/43 Jess McNeil - Tractor Operator 1/44 - 7/46 US Marines - Telephone installer 7/46 - 7/48 Westinghouse Electric - Installer Date T7M 8/48 2/49 2/53 2/53 Occupation General Helper Pipefitter Helper No.2 Pipefitter Helper No.l Pipefitter No.2 Pipefitter No.l Department Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Location Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery - Interview: R.W. Errington declined to discuss asbestos.- LAM 002003 DPMC-17693 No previous employment reported. Date 574? 6/50 8/51 8/52 6/53 1/54 1/56 2/58 3/59 3/60 6/61 6/64 7/65 7/68 7/70 9/73 4/77 Occupation Department Location Jr. Lab Assistant Mfg. Research Lab -Houston Refinery Lab Assistant Mfg. Research Lab Houston Refinery Technician Lab Mfg. Research Lab Houston Refinery Military Reserve (8/10/52 - 8/25/52) Military Reserve Military Leave (6/7/53 - 6/23/83) _ __ -- Released to return to school. Technologist Mfg. Technological Houston Refinery Technologist Mfg. Aromatics Houston Refinery Technologist Lubricating Oils Houston Refinery Technologist Mfg. Technological Houston Refinery Engineer Mfg. Eng. Services Houston Refinery Engineer Mfg. Cat Cracker Houston Refinery Sr. Engineer Technical CINIZ0 Group Leader Technical CINIZ0 Process Manager Aromatics West Houston Refinery Process Manager Gas Recovery Houston Refinery Previous Employment: "Insulator. 24 years experience in Chemical Plant". (Diamond Shamrock, Painesville Works) Navy: Radioman Date 1777-83 Occupation Insulator No. 1 Department Maint. Engr. Location DPMC Narrative From Interview: 4/10/84 Worked at Diamond Shamrock (Ohio) as an insulator between 1953 and 1976. Even in 1974-1976 they had no required precautionary procedures as does Shell. Insulators were only told about the hazard of asbestos not required to do anything different. This individual indicated that he always had used a "papertyffle" (Martindale) respirator even at Diamond. Much of his work at Diamond involved cutting and fabricating insulation outside. ; assignments today are predominately at-Resins. Some areas have asbestos, some don't. He encounters asbestos occasionally as during dismantlements and shutdowns. - stated that he was glad that he has had no effects from his past exposure (evidently he has not experienced overt symptoms from his asbestosis). He currently smokes less than 1 pack a day. LAM 002004 DPMC-17694 Regarding current work practices he stated that the "wet procedure" is pretty effective in reducing dust levels. Residual asbestos on piping is hosed off. " * appeared to be reasonably knowledgeable of asbestos1 hazards and very aware of the hazard associated with contaminating his work clothes. He did indicate, however, that for small jobs coveralls would not be used. He is careful thatTHis family doesn't handle his work clothing. McCarty further indicated that the management of contaminated clothing isn't stressed by SheTl. He occasionally brings contaminated garments to the Tool RoonMn unlabeled bags. He doesn't use paper coveralls because they lack pockets. Regarding other crafts, he indicated that pipefitters don't have respect for asbestos. He occasionally has to get fitters out of an area where insulation is being removed. Overall, this insulator stated that Shell had a pretty good safety program, with one exception. At Diamond Shamrock walking through roped off areas and not posting areas when work was going on overhead wasn't tolerated by management. Previous Employment: 4/1/48 - 1976 Insulator Group Leader at Diamond Shamrock. Date 2/77-83 Occupation Insulator No. 1 Department Maint. Engr. Location DPMC Narrative From Interview: 4/10/84 He has worked at Diamond Shamrock since 1948. Also wore respirators about as often as he does now at Shell. However, he runs into less asbestos at DPMC since it is slowly being replaced. He changes his clothing in the Carpenter Shop (not the changehouse), but he does shower before leaving work. Contaminated clothing is given to the Tool Room for cleaning in labeled bags. Regarding pipefitters, he suggested that their asbestos exposure is about 5 minutes per day on days when they encounter it. In some occasions this may be extended especially on overtime work. By personal observation pipefitters don't always use respirators. Sometimes it is difficult to tell whether or not insulation is asbestos especially if the covering metal is new. This probably presents a greater problem to new, younger pipefitters. - LAM 002005 DPMC-17695 Previous Employment: 9/47-6/48 General Helper, C.F. Braun, LaPorte.Tx. 8/46-9/47 Truck Driver, Dayton, TX. Date w 7/48 12/48 2/53 9/53 Occupation General Helper Pipefitter Helper No.2 Pipefitter Helper No.l Pipefitter Helper No.2 Pipefitter No.l Department Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field (IC) Location . Shell Chemical "Shell Chemical Shell Chemical Shell"Chemical Shell Chemical Narrative From Interview 4/9/84 Since 1948 has worked as a pipefitter. In reference to early asbestos exposure, he described working along side insulators and personally removing asbestos as necessary. On occasion the clothes he wore home were "white" with insulation. noticeably becomes short of breath upon exertion. He described his present difficulty in climbing pipe racks. He now has to stop to catch his breath before proceeding with the work, indicated that he has never smoked. Reportably the asbestos exposure today (in comparison to the past) is like "day and night". This improvement is mostly attributable to the current practices followed by insulators, (which began about 8 yrs. ago). Current asbestos jobs include: 1) scraping (sometimes sawing) off gaskets and 2) removing insulation (5-10 min. jobs). Sometimes water is used to remove asbestos, sometimes not - depending on the individual. A pipefitter may remove asbestos 2X/week. As has worked OP-II since 1969, the above description of current practices would only apply to the Olefins OP-II area. ranked pipefitters as having the second highest exposure potential (after insulators). Respectively #3 and #4 were boilermakers and machinists. Prior to Shell this individual worked for C.F. Braun as aJjridtmason helper. No asbestos exposure was attributed to this job.-' v LAM 002006 DPMC-17696 Previous Employment: 46-47 Self employed mechanic. 1/51-7/52 Millwright at Portland Cement Millwright at Ethyl Corp. Millwright at Rheem Manufacturing Date w 10/52 10/52 1/53 1/53 4/53 9/53 5/54 6/60 8/63 8/66 12/66 7/67 6/68 10/68 Occupation General Helper Loader General Helper Truck Driver No.2 General Helper Loader Boilermaker Helper #2 Boilermaker Helper #1 Boilermaker #2 General Helper Operator #2 Loader Operator Loader Boilermaker Department Eng. Field Shipping Eng. Field Eng. Field Eng. Field Shipping Eng. Field Eng. Field Eng. Field Eng. Field P Operations Shipping Shipping Shipping Maint.Eng. Location' Shell Chemical Shell "Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Narrative From Interview 4/9/84 As a General Helper, . primarily assisted the boilermakers, pipefitters and machinists. His contact with asbestos during this time was related primarily to working in areas where asbestos was being removed. At times it would look like "snow falling from overhead". Boilermakers frequently knocked off asbestos insulation to get to the heads of exchangers or boiler. recalled having his clothes covered by asbestos on occasions. Respirators were not available until early 70's, however, goggles were the only way to keep it out of eyes and sometimes a rag would be tied around the nose and mouth if conditions were intolerable. When asked the difference between conditions of earlier years^SO's & 60's and today, said "There is no comparison between how it was then and now". He was referring to the work practices which require it to be wet, bagged, with coveralls and respiratory protection. The frequency of boilermakers having-to remove the insulation has also been dramatically reduced because there "just isn't - as much asbestos around". Occasions may still occur but they are infrequent compared to earlier years. believes the pipefitters and boilermakers to be second only to the insulators in asbestos exposure. The areas worked were field assignments all over the Chemical Plant. He was a Plannable Boilermaker for severaT~yaeajrs. Since 1983 he has been assigned to E Maintenance. --- Regarding the time spent as a Loader in Shipping Dept, he commented on _ exposure to BPA and resins dusts in the Warehouse. LAM 002007 DPMC-17697 Previous Employment: 7/40-7/42 Westinghouse Electric - Motor Repairman 7/42-11/45 U.S. Navy-Radioman 1/46-3/48 The Texas Co.-Painter Date 4/48 5/48 8/48 9/52 10/52 2/56 6/56 11/76 Occupation General Helper Pipefitter Helper No.2 Pipefitter Helper No.l Instrument Man Help.No.2 Instrument Man Help.No.l Instrument Man No.2 Instrument Man No.l Instrument Man/Foreman Department Eng. Field Eng. Field Eng. Field . Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Interview: Not Conducted (Retired) . Location Houston Refinery Houston Refinery Houston"Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Previous Employment: 8/46-7/48 The Texas Co. - Tank Truck Operator 4/46-8/46 H.H. Hardy - Guniter* *Reason for leaving was "doctor advised". Date im 9/48 9/48 9/48 2/53 5/68 Occupation General Helper Loader General Helper Welder Helper Welder No.l Welder/Craft Foreman Department Eng. Field Shipping Eng. Field Eng. Field Eng. Field (IC) Eng. Field Location Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Narrative From Interview 4/9/84 clearly remembered working with an insulator in the removal of asbestos at G Plant during the first week of employment. During this initial 3 month assignment as a general helper and leaded he had "a few days" of definite exposure to asbestos. His assignment" as a welder since 1948 was associated with asbestos exposure upto the time period when its hazards were better managed (early 70's). Welder field assignments did not actually involve insulation removal'. However, after insulation was removed he would have to work in areas which were contaminated with the asbestos. On at least some occasions the loose - asbestos would be on scaffolding (some jobs required him to work lying down on contaminated surfaces). This welders work historically has been associated with furnaces and reactors. noted welders past use of asbestos fire blankets and gloves. Before asbestos controls were put in place asbestos contaminated piping was brought into the shop. As in the field the loose fibers after the insulation was removed resulted in some potential exposure. has predominately worked in the shop since 1974. Prior to SheTl^e. worked for H.H. Hardy as a guniter and could not recall any exposure^tp asbestos. LAM 002008 DPMC-17698 Previous Employment: 12/43-4/44 Worked on fathers farm. 9/41-1/43 Dairy Work 9/43-12/43 North American, Dallas - Plating and Buffing Has been at Sulfur Springs with father since 12/43. Date 4/44 8/45 1/46 8/46 6/48 6/49 1/72 2/74 2/77 11/80 Occupation General Helper Repairman Helper General Helper Boilermaker Helper Boilermaker No.2 Boilermaker No.l Craft Foreman & BM #1 Zone Foreman Foreman DPC (Zone A) Maintenance Foreman Department Gas Car Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Maint. Eng. Maint. Eng. Int.& Solv. location Houston Refinery Houston "Refinery Chemical Chemical Chemical Chemical Chemical Chemical Chemical Chemical Narrative From Interview 4/18/84 is currently a multi-craft foreman in A Maintenance. He worked as a boilermaker in the Chemical Plant from 1946-1974. One significant recollection had about asbestos was how craftsmen would often use air hoses to blow the insulation away from their inmediate work areas. He also recalled using a harraner to remove asbestos insulation around the bolts on exchanger heads. The cleanup of stripped insulation was poor. "Unless it was a tripping hazard, it was left in the area". When asked which crafts were probably exposed the most frequently he named pipefitters and boilermakers as second and third to the insulators. Today he feels the usage of proper protective controls is about 80% by all of the crafts. The "associated maintenance" which is now in effect he feels will involve additional crafts in insulation contact ie. instrument men, electricians, machinists. - - --- > i was not aware that an annual training requirement exists for asbestos at DPMC. He feels that reinforcement of training is very important and suggested that our department design a presentation for all of the crafts which includes demonstrating how indestructable asbestos is. - Regarding protective clothing for asbestos he felt that paper coveralls -- should be specified for asbestos work because they can be disposed of. He commented that if craftsmen wear cloth coveralls for asbestos that they are likely to keep them on for the duration of the day. LAM 002009 DPMC-17699 Additional Interview: ............ 4/19/84 is currently an hourly maintenance foreman at Aromatics. Since 1976 he has worked as a pipefitter in Maintenance East. j The frequency of contact an individual pipefitter might be-involved in an asbestos related job estimated as once or twfce a month for 15-20 minutes. The practice used today is to have the insulation checked to determine if it is asbestos before performing the work. If this cannot be done it is assumed to be asbestos. Pipefitters may not always wear coveralls, however, most will wear a respirator and sometimes wet the insulation and cover the ends to keep it from shaking out while performing their work. Mr. Callaghan did recall an occasion where he found out after the job that the insulation was asbestos and no protective clothing was worn. For most of the jobs he plans now he tries to have the insulation removed in advance to avoid having other crafts exposed to asbestos during insulation removal. (This was done recently in preparation for the Aromatics Shutdown). He personally does not beat off insulation with tools but will use a saw or cut it to minimize dust because he has to clean up his own mess. is not presently in any of the medical programs at DPMC. He feels that pipefitters and boilermakers with service prior to 1975 should be included in an asbestos medical program and that perhaps a random number of various craftsmen could be included post 1975 Asbestos Medical Program. He does not think the "associated maintenance concept" will be affected any differently in regard to asbestos exposure. He also mentioned that craftsmen working in the Utilities may have more frequent contact with asbestos. When asked the order he would rank different crafts exposed td^asbestos he named insulators #1, laborers #2, carpenters #3 and alT' of 'the other crafts #4. Overall the craftsmen are pretty knowledgeable about asbestos. It is frequently discussed in Safety Meetings. Practices-probably vary depending on individuals and foreman but generally precautions are followed, to his knowledge. LAM 002010 DPMC-17700 Case 1 2 3 4 5 6 7 8 9 10 TABLE 1 ASBESTOSIS STUDY 12/83 Years Since First Possible Exposure Years Since Last Possible Exposure0 Job Assignment Comments 35 10C Insulator 35 10C Pipefitter 25 Not Determined Engineer 30 6 Insulator Exposure prior to Shell signif. 35 6 Insulator Exposure prior to Shell signif. 35 10C Pipefitter 30? 10C Boilermaker 35 35 Pipefitter 1 Yr. probable exposure 37 37 Welder 38 34 Repairman/ Boilermaker PJS05/21 5-1-84 LAM 002011 DPMC-17701 SM 3? MC (REV 4-79i Shell Oil Company Shell Chemical Company Interoffice Memorandum JULY 23, 1984 FROM: TO: SUBJECT: P.J SNYDER - SR. INDUSTRIAL HYGIENIST DEER PARK MANUFACTURING COMPLEX D. MC CRAW - CORPORATE MEDICAL HEAD OFFICE ASBESTOS COHORT FOR MEDICAL FOLLOWUP As we had discussed previously, I would like to have the University of Pittsburgh research group extract for DPMC those Shell employees who had worked in certain job categories prior to 1975. Further, this listing should identify individuals who worked these jobs for at least 6 months beginning in 1955. Hopefully this will catch the majority of employees who may still be employed but not in any surveillance program. The jobs of interest are: PDI Code(s) 1. Pipefitters 2. Boilermakers 3. Carpenters 4. Welders 5. CA Plant Operators (1969-73 only) 6. Laborers 7. Insulators 06900 00700 01600 09900 01400 04800 04700 We are, of course, only interested in those employees who are still employed but I do not know if they i m make that cut. Ideally the data should be presented in the following i Name TTTJoe I.D.# T2W Dates of Assignment ~W55"" 12752-------10/68 - 11/71 Job Insulator Pipefitter Please let me know if this can be accomplished once the coding activity is completed. P.J. Snyder cc: J. Gross MD B. Kern MD ECB Satellite PJS Chron lam 002012 DPMC-17702 PROPOSED SHELL ASBESTOS MEDICAL SURVEILLANCE POLICY Pertinent Background Facts On Asbestos: Asbestos is a human carcinogen. Inhalation may cause lung ' cancer, mesothelioma, and other diseases such as asbestosis and pleural lesions. Generally, the incidence of cancer and asbestosis among occupationally exposed persons increases with increasing intensity of exposure; the inhalation of high concentrations for short durations may be as harmful as prolonged exposure to low concentrations. From all available evidence, the period between first exposure to asbestos and death from lung cancer appears to be related to intensity of exposure. A latency period approximating fifteen years is probably the minimum for asbestos-related lung cancer. Tobacco smoking increases the incidence of lung cancer and complicates asbestosis among asbestos workers. Regulatory Background: Permissible exposure limits to airborne concentrations of asbestos fibers are defined by OSHA standards (29 CFR 1910.1001) as follows: a) Permissible exposure level -- "The 8 hour time - weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed two fibers, longer than 5 micrometers, per cubic centi meter of air..." b) Ceiling concentration -- "No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers, longer than 5 micro meters, per cubic centimeter of air..." Per OSHA Program Directive #300-16 Dated October 11, 1978, titled, "Minimum Airborne Fiber Concentration For Initiating and Continuing Asbestos Medical Examinations", the term "...exposed to airborne concentrations of asbestos fibers..." is administratively interpreted to mean "...exposed to a mimimum of 0.1 asbestos fibers longer than 5 micrometers per cubic centimeter of air..." on a time weighted average basis. Shell Concerns: 0 Surveys now indicate that in addition to "insulators" who are currently included in our asbestos medical surveillance program, other employees such as pipefitters, riggers, etc. may also be exposed tq asbestos as a result of their work activity. LAM 002013 DPMC-17703 3 Our current medical surveillance program does not satisfactorily address the question of past exposure to asbestos. Employee training programs for asbestos have not sufficiently emphasized the known synergism between asbestos exposure and smoking. Objective: Revise existing asbestos medical surveillance policy in order to correct any deficiencies and fully address the concerns described above. Policy: Employees whose present job assignment results in exposures to asbestos of 0.1 fibers, longer than~5 micrometers, per cubic centimeter (TWA) or greater (regardless of respirator usage), on a reasonably predictable and repeated basis,* shall be included in Shell's annual asbestos medical surveillance C program. Employees, who can be identified as having had job assignments in the past, in which exposures can be determined as probably exceeding 0.1 fibers, longer than 5 micrometers, per cubic centimeter (TWA) or greater (regardless of respirator usage), on a reasonably predictable and repeated basis,* shall also be included in an annual asbestos medical surveillance program. yf Available exposure data indicate that exposures during "rip out" or removal of asbestos-containing insulation may exceed 0.1 fibers per cubic centimeter. Accordingly, all employees, regardless of job title, whose work assignments now or in the past, would involve "rip out" or removal of asbestos-containing insulation, on a reasonably predictable and repeated basis,* are to be included in an annual asbestos medical surveillance ( program. Employees who have been in an asbestos medical surveillance program prior to employment with Shell shall be included in Shell's annual program. LAM 002014 The phrase "reasonably predictable and repeated basis" is currently interpreted for present job assignments, to mean at least eight hours of exposure per calendar quarter. For exposures that have occurred in past job assignments, "repeated" shall mean at least two calendar quarters. It should be recognized that these exposure criteria represent an administrative judgment, since minimal exposure levels required to cause disease are not known with certainty at this time. This administrative judgment may be revised in the future, with the concurrence of Corporate Medical, Toxicology, Safety and Industrial Hygiene and the affected functional manage ment. DPMC-17704 4 Once an employee has been included in an asbestos medical surveillance program, the surveillance should be continued throughout the term of his or her Shell employment. Upon leaving Shell, each employee who has been included in an asbestos medical surveillance program shall be administered according to the Shell pre-separation counseling or extended medical surveillance program policy (post-retirement physical examinations), whichever is appropriate. Implementation: Suggested Action Plan/Guidelines Evaluate exposures and identify employees whose job assignments, now or in the past, result in exposure to asbestos as defined in the Policy, and include themJ.n the annual asbestos medical surveillance program. Due to the varied nature of potential exposure throughout Shell, there may be specific employee concerns that will require the prudent, balanced judgements of both functional management and the Head Office Corporate Medical and Safety and Industrial Hygiene Departments. Full consultation, prior to arriving at a decision, is encouraged in these cases. For the above identified employees, provide improved training and information to emphasize: a) Synergism of asbestos and smoking b) Need for participation in medical examination programs. Review current operating procedures for reducing or eliminating physical contact between asbestos fibers and employees. / V LAM 002015 DPMC-17705 INDIVIDUALS WITH POTENTIAL ASBESTOS EXPOSURE *These individuals are not on any special exam program. Ma i ntenance Spjttly "R" Pipefitter: Plannable Pipefitter: "R" Carpenter: Olefins Pipefitter:: "A" Pipefitter: "E" Pipefitter: Shop Boilermaker: Shop Carpenter: Shop Tinner: "S" Carpenter: Plannable Boilermaker: Plannable Carpenters: Maintenance North' L/PA Boilermaker: Lube Pipefitter: Phenol Pipefitter: Tank Farm Boilermaker: Utilities Boilermaker: West Boilermaker: LAM 002016 DPMC-17706 Maintenance jjoi${u,pqnt. West Boilermaker Cont. West Carpenter: Envr. Pipefitter: West Pipefitter: Utilities Pipefitter: Shop Boilermaker: Shop Carpenter: Shop Pipefitter: Plannable Pipefitter: Shop Tinner: Garage Mechanic: 2 Boilermaker Trainee: Central Pipefitter: Carpenter Trainee: Southeast Boilermaker: East Carpenter: LAM 002017 DPMC-17707 East Pipefitter: Arom/G.R. Pipefitter: 3 o LAM 002018 DPMC-17708 (( SHELL ASBESTOS MEDICAL SURVEILLANCE POLICY Pertinent Background Facts On Asbestos: Asbestos is a human carcinogen. Inhalation may cause lung ' cancer, mesothelioma, and other diseases such as asbestosis and pleural lesions. Generally, the incidence of cancer and asbestosis among occupationally exposed persons increases with increasing intensity of exposure; the inhalation of high concentrations for short durations may be as harmful as prolonged exposure to low concentrations. From all available evidence, the period between first exposure to asbestos and death from lung cancer appears to be related to intensity of exposure. A latency period approximating fifteen years is probably the minimum for asbestos-related lung cancer. Tobacco smoking increases the incidence of lung cancer and complicates asbestosis among asbestos workers. Regulatory Background: Permissible exposure limits to airborne concentrations of asbestos fibers are defined by OSHA standards (29 CFR 1910.1001) as follows: a) Permissible exposure level -- "The 8 hour time - weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed two fibers, longer than 5 micrometers, per cubic centi meter of air..." b) Ceiling concentration -- "No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers, longer than 5 micro meters, per cubic centimeter of air..." Per OSHA Program Directive #300-16 Dated October 11, 1978, titled, "Minimum Airborne Fiber Concentration For Initiating and Continuing Asbestos Medical Examinations", the term "...exposed to airborne concentrations of asbestos fibers..." is administratively interpreted to mean "...exposed to a mimimum of 0.1 asbestos fibers longer than 5 micrometers per cubic centimeter of air..." on a time weighted average basis. Shell Concerns: Surveys now indicate that in addition to "insulators" who are currently included in our asbestos medical surveillance program, other employees such as pipefitters, riggers, etc. may also be exposed to asbestos as a result of their work activity. LAM 002019 DPMC-17709 ( (2 Our current medical surveillance program does not satisfactorily address the question of past exposure to asbestos. Employee training programs for asbestos have not sufficiently emphasized the known synergism between asbestos exposure and smoking. Objective: Revise existing asbestos medical surveillance policy in order to correct any deficiencies and fully address the concerns described above.' Pol icy: Employees whose present job assignment results in exposures to asbestos of 0.1 fibers, longer than 5 micrometers, per cubic centimeter (TWA) or greater (regardless of respirator usage), on a reasonably predictable and repeated basis,* shall be included in Shell's annual asbestos medical surveillance program. Employees, who can be identified as having had job assignments in the past, in which exposures can be determined as probably exceeding 0.1 fibers, longer than 5 micrometers, per cubic centimeter (TWA) or greater (regardless of respirator usage), on a reasonably predictable and repeated basis,* shall also be included in an annual asbestos medical surveillance program. Available exposure data indicate that exposures during "rip out" or removal of asbestos-containing insulation may exceed 0.1 fibers per cubic centimeter. Accordingly, all employees, regardless of job title, whose work assignments now or in the past, would involve "rip out" or removal of asbestos-containing insulation, on a reasonably predictable and repeated basis,* are to be included in an annual asbestos medical surveillance program. Employees who have been in an asbestos medical surveillance program prior to employment with Shell shall be included in Shell's annual program. LAM 002020 The phrase "reasonably predictable and repeated basis" is currently interpreted for present job assignments to mean at least eight hours of exposure per calendar quarter. For exposures that have occurred in past job assignments, "repeated" shall mean at least two calendar quarters. It should be recognized that these exposure criteria represents an administrative judgment, since minimal exposure levels required to cause disease are not known with certainty at this time. This administrative judgment may be revised in the future, with the concurrence of Corporate Medical, Toxicology, Safety and Industrial Hygiene and the affected functional manage ment. DPMC-17710 (3 Once an employee has been included in an asbestos medical surveillance program, the surveillance should be continued throughout the term of his or her Shell employment. Upon leaving Shell, each employee who has been included in an asbestos medical surveillance program shall be administered according to the Shell pre-separation counseling or extended medical surveillance program policy (post-retirement physical examinations), whichever is appropriate. Implementation: Suggested Action Plan/Guidelines Evaluate exposures and identify employees whose job assignments, now or in the past, result in exposure to asbestos as defined in the Policy, and include them in the annual asbestos medical surveillance program. Due to the varied nature of potential exposure throughout Shell, there may be specific employee concerns that will require the prudent, balanced judgements of both functional management and the Head Office Corporate Medical and Safety and Industrial Hygiene Departments. Full consultation, prior to arriving at a decision, is encouraged in these cases. For the above identified employees, provide improved training and information to emphasize: a) Synergism of asbestos and smoking b) Need for participation in medical examination programs. Review current operating procedures for reducing or eliminating physical contact between asbestos fibers and employees. LAM 002021 DPMC-17711 Considering thi Att^hment II o dry) may^result This upper,range wet or dry 'insula' J^g <! fZc^oiUMn.DAr*J>\ foM 7 3>p*v'c [mi ted assessment and the data presented in y conclude that any insulation removal (wet or "peak" asbestos exposure between < ' ^tr0' . rF,/cc~ . ` be a probably worse case expos e^for partially If this exposure occurred for an estimateo ten minutes then the 8 hr., TWA range would be: (.1 F/cc)(10 Kin.) ^ ------- {480" M'fnT) <^/cc upto (10 Kin.)(5-10 F/cc) (480 Kin.) Although^tfie actual exposure would be less if a respiratOrv^vas worn, the criteria for medical surveillance would apply irrespective of restnrator use. V RECOMMENDATIONS* ** 1. The following crafts should be added to the Asbestos Kedical Program based on current exposure potential. Insulators (verify participation) ** Maintenance personnel expected to or permitted to remove or cut asbestos more than 5 days per year. ( Pipefitters 'Tinners ' Carpenters Mechanics 2. The following employees should be added to the Asbestos Medical Program based on past exposure potential. Employees who worked prior to 1972 as: Pipefitters - Verify Boilermakers - Participation Carpenters Welders Epon I Operators (Attachment IV) CA Plant Operators (1969-1973) Laborers A^OC *VTcD AA Ai nTc n LAM 002022 DPMC-17712 7-- M-B- g-y ,r^ ~v r? :`ij 8 3. Per the DPHC Asbestos Order, annual asbestos training should be provided to current Pipefitters Carpenters Tinners Insulators Mechanics Warehousemen 4. All future "presumptive cases of asbestosis" should be identified and interviewed in regard to past asbestos work. 5. To comply with the OSHA Asbestos Regulation the following jobs must be monitored every 6 months, (1 day survey) Tinners - Covering insulation Insulators - Asbestos removal work Carpenters - Cutting transite Maintenance needs to assist Industrial Hygiene by coordinating air sampling and the field work. 6. Annually maintenance should review participation in the medical program for the jobs identified in #1 above. Ii i '! I :i i '! i; ;i i LAM 002023 i .( DPMC-17713 SM-32-MC (REV. 4-79) Shell Oil Company Shell Chemical Company Interoffice Memorandum AUGUST 9, 1984 FROM: TO: SUBJECT: P.J. SNYDER - SR. INDUSTRIAL HYGIENIST J.B. GROSS MD R.M. KEMBALL-COOK B.J. KERN MD J.G. MASSEY ASBESTOS MEDICAL SURVEILLANCE The following items pertain to the discussion on asbestos medical surveillance scheduled for Wednesday 8-15-84, (12:45 - 1:30 pm). 1984 audit findings 12/80 Head Office recommendation Recommendations from DPMC Industrial Hygiene Options to address this issue will be offered next Wednesday. P.J. Snyder Attachment cc: ECB Satellite PJS Chron LAM 002024 DPMC-17714 l e - 7Z-0 /fs&esr&S March 25, 1980 D. O. CHRISMER J. G. MASSEY Attached is a proposed policy statement on Shell's asbestos medical surveillance policy. This proposed policy is basically the same as the one we are currently working under with one exception. That exception involves individuals exposed in the past. The new wording states - "For exposures that have occurred in past job assignments, 'repeated' shall mean at least two calendar quarters." The most probable impact of this will be the inclusion of pipefitters, and boilermakers in the asbestos medical surveillance program that were working these crafts prior to 1972. Please let me know if you -have any questions or comments. Attachment cc: JMB, RJS, RHS, DEM RPFsikg PFRUTIGER t x LAM 002025 i DPMC-17715 INDIVIDUALS WITH POTENTIAL ASBESTOS EXPOSURE *These individuals are not on any special exam program. Ma intenance South! "P" PiDefitter: Plannable Pipefitter: "R" Carpenter: Olefins Pipefitter:: "A" Pipefitter: "E" Pipefitter: Shop Boilermaker: Shop Carpenter: Shop Tinner: "S" Carpenter: Plannable Boilermaker: Plannable Carpenters: Maintenance North' L/PA Boilermaker: Lube Pipefitter: Phenol Pipefitter: Tank Farm Boilermaker: Utilities Boi1ermaker: West Boilermaker: LAM 002026 DPMC-17716 Mai ntenanqejtio.rMhCPntWest Boilermaker Cont. West Carpenter: ....................... 1 Envr. Pipefitter: West Pipefitter: Shop Tinner: Garage Mechanic: ---- /%-/% - 2 Boilermaker Trainee: Utilities Pipefitter: Shop Boilermaker: Shop Carpenter: o Shop Pipefitter: Plannable Pipefitter: Central Pipefitter: Carpenter Trainee: Southeast Boilermaker: East Carpenter: LANl 002027 DPMC-17717 Mai East Pipefitter: Arom/G.R. Pipefitter: 3 o LAM 002028 DPMC-17718