Document LOzqNEMBwzJ8JXVBwjEnEDY3

OEOF&OSA-PACSaFIC INTERDEPARTMENTAL COMMUNICATION CO^ to: J. D. Rauch from: M. F. Fink SUBJECT: ASBESTOS CONTROL PROGRAM date: February 21, 1973 location: Akron location: Tigard CC: Messrs: E. B. Hollingsworth - Wilmington Gypsum H. W. Peele, Wilmington Gypsum R. Schifferle - Akron PLAINTIFF'S EXHIBIT CP-2145 First on the agenda is the report from OSHA to determine whether a hazard exists and the seriousness of the exposure. We have had a check made at Acme conducted by the State of Texas and the determination was that the hazard was not too serious and they made two recommendations: 1. Respirators, approved type, be worn by the mixer, vibrator and the bag filling operations. The latter was added as there was a high count mainly mica and other ingredients. 2. The storage of sacks of asbestos. The piles shall be covered with plastic or pliofilm, cloth not recommended. This would keep the asbestos fibers from moving about the plant. They were satisfied with the X-ray program which is similar to the program in your plant. We have requested information as regards a control program and the answer we received was "emphasis must be placed on good practical, protective measures". I will add that several hygienists and toxicology personnel have voiced displeasure with OSHA. According to their societies, they are lacking in professional standards. Another complaint is that NIOSH (OSHA) were careless in analysis and have reported very high concentrations of asbestos; however, the counts were combined asbestos, mica, and talc. They lack the practical experience enough to evaluate what is available. Getting back to 4 and '5. Counts must be based on S hour tests and exposure. When the 8 hour exposure exceeds the threshhold limit all personnel exposed to the hazard must have the physical. Unless the laboratory technician only makes occasional trips to the area to obtain samples, he would not be required to have the physical. This rule would apply to the supervisor but they would be required to wear a respirator. I have checked this with Employers Mutual of Wausau and they recommend to their clients that all employees working in areas where asbestos is being used, be required to undergo the physical. SGP 0006728 J. D. Rauch -2- February 21, 1973 Any new employee or transferee to the Joint System department on a permanent basis must have the chest X-ray 14x17 inch size plus a record of any respiratory illness. Rather than take a chance we should not permit a person with any ailment work in this department. Termination of employment. Within 30 calendar days before or after termination, a comprehensive medical examination including the 14x17 inch chest X-ray, pulmonary function tests and history of respiratory illness shall be provided or made available to the employee, at our cost. This record must be kept on file for 20 years. These interpretations are noted to alert you if the findings are rated hazardous. If we are doubtful of the findings or question the accuracy of the analysis, we can obtain the services of a certified hygienist. There is a possibility that we may be able to reduce the quantity of asbestos used in our products which will remove some of the hazard; however, a campaign is started to class talc as harmful but the limits being suggested are not as severe as the asbestos standards. We wish to caution you on two items: 1. Peter Breysse, Professor of Environmental Health, University of Washington, addressed our seminar. According to him the best control method would be to ban all cigarette smokers from working with asbestos. It seems that the combination is synergistic as far as cancer incidence is concerned. When the exposure in Akron is determined to be hazardous, we should make an effort to control the smoking. 2. Asbestos bag disposal. This definitely is a problem. We have been informed that burning of the bags in an ordinary incinerator is not permitted as the asbestos fibers are released in the atmosphere. It is recommended that the bags be buried or disposed in a manner to prevent releasing the fibers. Probably we should consider taking them underground, the moisture and dampness would contain the fibers. We plan to attend a seminar on March 7, 1973, when the medical control part of the program will be reviewed. In conclusion our program will depend on the findings of the last monitoring. When this is available we will have to decide whether we should request a variance, also just what must be done to comply. Pending this report we shall not make a move. MFF: jp- SGP 0006729