Document Lg241BXJpgZedZze8y0xGJ4Vz

Zj(pn COMPANY. U.S.A. POST OFFICE BOX 551 - BATON ROUGE. LOUISIANA 70821 ffEFWMG DEPARTMENT 0ATON ROUCE REFINERY / November 8, 1982 Mr. Jim Beed' Refractories Division Anco Insulations, Inc. P. 0. Bo* 66596 Baton Ropge^ LA 70896 Dear Jim: I am enclosing three (3) copies of my paper on "Asbestos Removal - A New Industry," as you requested yesterday. I thoroughly enjoyed the Energy Seminar, and thank you for inviting me to participate. Very truly yours. FSV:nh Enclosure FRED S. VENABLE * DIVISION tjf Exxon CORPORATION 005,2 ASBESTOS REMOVAL - A NEW INDUSTRY To someone such as myself who has spent over 30 years in the occupational and environmental health field, one of the more interesting changes that has come about has been our * increasing knowledge jof and concern over the effects of human exposures to toxic agents. Those agents receiving such attention are largely chemical substances and other materials which have been widely used in industry for many years and Indeed, many are also found in our home environment. The number of these materials of concern is already large and is steadily increasing. The list includes carbon tetrachloride (solvent - fire extinguish ing agent) and PCB (transformer fluid) - formerly considered safe because they were nonflammable; vinyl chloride (raw material for plastics), which we thought only had anesthetic and combustible properties at high levels; formal dehyde, which is widely used as a preservative and as a component of bonding agents in plywood permapress fabrics and paper; and of course, asbestos, a t -very common and almost indispensable insulating and fireproofing material. Much, if not most, of our increased concern over the health effect of these / substances has resulted from new data derived from the testing of animals. However, the cases against some materials have been compiled from human experi ence - that branch of public health we call epidemiology. Epidemiology is the science of comparing illness or death rates in an exposed population to the rates in a nonexposed population. The capacity of asbestos to produce a rather rare and unusual form of cancer called mesothelioma has enabled epidemi ologists to pinpoint the cause to this specific material in the workplace. What we will discuss today are the stringent requirements for safe handling of asbestos materials on the job; more specifically, the removal of asbestos in sulation, all of which have resulted from our epidemiological findings. ' 0053 2 HISTORICAL The word asbestos evolved from a Greek word meaning inextinguishable or incom bustible. In addition to this important property, asbestos also does not decay, break down or otherwise change except possibly to become more frag mented. Canada, Russia and South Africa furnish most of this interesting mineral. Six different types are found. As early as 1927, a lung disease resulting from the inhalation of asbestos fibers was recognized. This disease, called asbestosis, resulted in a diffuse scarring of lung tissue and shortness of breath somewhat similar to the silicosis dust disease earlier recognized in miners. This disease was disabling but not necessarily fatal. For many years, including many within my own experience, it was felt that controlling asbestos dust levels to 5 million particles per cubic foot of air or less would essentially prevent asbestosis. At the same time, this level did not 'impose serious restrictions on many practices which were commonly used by insulators and other asbestos workers. f ^In the 1960s, Selikoff pointed out the striking incidence of lung cancer and mesothelioma in asbestos workers, and it became apparent that much lower fiber t levels must be achieved in order to prevent these diseases. In 1972, the Occupational Safety and Health Administration imposed a standard for an 8-hour work period of 5 fibers greater than 5 microns in length per cubic centimeter of air which was, later in 1976, reduced to 2 fibers per cc. Ceiling or maximum levels for any 15-minute period shall not exceed 10 fibers per cc. Almost simultaneously with OSHA's actions, the Environmental Protection Agency imposed certain requirements prohibiting the release of asbestos fibers from the exhaust stacks of manufacturing establishments, established requirements for the disposal of asbestos waste and the required prenotification of EPA of demolition jobs. t nn r 4 3 OSHA's requirements, in addition to the permissible level of asbestos fibers in air, are more detailed and burdensome. They include a series of Actions ranging from early identification of exposed employees through final medical followup. To illustrate the complexity of compliance procedures, we will refer to the following slides. OSHA STANDARD ON ASBESTOS (29 CFR 1910.1001) ENGINEERING CONTROLS Isolation/Enclosure/Exh. Vent/Dust Collection Local Exhaust Ventilation Must meet ANSI Z 9.2 - 1971 Power Tools Saws/Abrasive Wheels/Drills WORK PRACTICES Wet Methods Asbestos Handled/Mixed/Applied/Removed Products/Operations * "* Bags/Cartons Not removed unless wetted/enclosed/ventilated Spraying/Demolition f Respiratory Protection Refers to Paragraph (d)(2)(iii) Type "C" supplied Air Respirators Special Clothing PERSONAL PROTECTIVE EQUIPMENT May Not Be Used Except: Interim Periods Eng. Cont. Not Feasible Emergencies 1>6 4 Respirators Air Purifying * Powered Air Purifying Type "C" Respirator Prograa ANSI Z 88.2 - 1969 No employee required to wear respirator if medically limited Special Clothing Celling Level of Fibers Employer shall provide and require Whole body clothing ' Head covering Gloves Foot covering . Change Rooms Exposure Limits Clothes Lockers Separate Laundering * Notification of Laundry Transportation Sealed containers/labeled Method of Measurement/Monitoring Initial Determinations within 6 months Personal Monitoring 6 months/each typical operation Environmental Monitoring Areas of work environment Employee Observation/Access to Records Posting We use oil fiber/cc t 0058 5 Medical Records Maintenance/Retention Employee Access Identification One of the first decisions involved in the removal of insulation is: does the insulation contain asbestos? While this seems to be a simple and basic question, a lot of money rides on the answer. Insulation materials such as glass fibers, mineral wool, organic fibers, etc. are not subject to the costly asbestos regulation. At the same time, these materials may be difficult to differenti ate from one or more of the varieties of asbestos. Sometimes the age of the insulation will provide a clue, since most high temperature Insulation mate rials manufactured and installed prior to 1972 contained varying amounts of asbestos ranging from 7-102 up to 902. In very recent years, Asbestos substi tutes have been used, so that the interim period of 1972-80 is a time when we are uncertain of the composition. , Some familiarity with insulation materials will be useful in the visual identi fication of asbestos and non-asbestos products. . Chemical identification can be useful as a screening procedure. One commer cially available test kit makes use of the magnesium component of chrysotile and the iron content of amosite to identify about all common types. Some false positive results may be obtained with this kit, however. t 0057 6 The most certain identification procedures involve Immersion techniques or staining of fibers under the microscope. These techniques can seldom be carried out outside rather sophisticated laboratories, although consultants in this specialty are usually available. . What Can the Employer Do To Satisfy the OSHA Requirements? 1. Be can assign a responsible person to the task of evaluating asbestos removal projects and coordinating and training members of his organi zation on the various requirements of the law. 2. He can decide just what specific requirements of the regulation his organization will perform and what requirements he will arrange for others to do. 3. He can make compliance more cost-effective by performing the more routine requirements such as monitoring, training, respirator test ing and record keeping. < In summary, the actions necessary to comply with OSHA's regulations on as bestos removal indeed creates a new Industry. An employer whose plans include the removal of asbestos insulation or materials must become familiar with these requirements and prepare compliance plans accordingly. In the final analysis, the protection of our employees from the dire effects of asbestos exposure should be our primary goal. If the prevention of such diseases can be accom plished by proper wo'rk practices, personal protection programs and medical surveillance of employees-at-risk, then the cost to the employer and to the industry is in reality a bargain. FSV:nh October 26, 1982 0058 i Equivalent > "0 r-f* CD CO ro --t mmm o CO ^1 05 CO -sj o> CO -vl ro *0Ul o CJI 4*. o *005 *0fO *0o 00 o o o 00 CJI o ** o c O' o T] ~n o op>4* C11J T0 0 O > O c OMiM' O O CD D 3! o1 0 ro oi -vi 05 * ai 0 3 CD V 05 0 --* O > "0 m 33 CO CO 5 rm rm< mr- CO "TI o 33 > CO 3 m co H O CO mx T3 O CO c 3m3 co < 0053 * 30 o =T o*< 0 0 0 _ 05 3 J3 O O >9 o0 Q. 0 o3 0 0 0 W0 3 o .0 H > TJ Q 9: 5330o 3 i*2.S = *8 3 5? 000 533 3 0 = 3 -3 ~0 O 3 0 f t 0060  - 3D CD 0061 e Notification 0063 t t Clothes Lockers Laundering Notification Transportation TPyopweer"eCd" Air Purifying Respirator Program J3 0 0) TD IL o 73 *< 3' CQ T) m 33 CO o z mm^ > <P ? -0 0m o 3 on = 3 Tl H 2.r m 0w Zo HO O Q. Tl m 0m 0 0 O a; 0 # t 0064 Products/Operations Bags/Cartons Spraying/Demolition Respiratory Protection ,* Special Clothing mO o JO 0 7s oo^ tOZ 0) X > JO a> s--i aTMm hC1 2 cn H> o=T CL pOHr co Om o =rz 2. a> o co c ao < SH >o JaO oz - s 2 (- I o > (/> as # cmn H O CO o n 33 0065