Document LmRdMKmNebeZNN0R1LN71x97

/z - --jL A/o^_ PLAINTIFFS EXHIBIT Two thousand years ago whan the first use of aabaatoa was recorded, it was a sacred object, a curiosity of kings end nobles, e ueglc mineral. The Greeks, who used asbestos for the wicks of their taspla leaps were enthralled when flans did not connunc it, but burned unceasingly. Aaased, they called it asbests, which scent the "unquenchable," the "inextinguishable.* Z. What is it? Asbestos is a ten which refers to a group of acre than 30 aineral substances, all of which are silicatoe and which share the ciaaawn property ef hawing a fibrous etnetere. Their formation in nature requires a council goelsgtesl principle of the right host rock, beam rtiwtul fastens end ideel con dition* of t meritsre ietf ptreesurd. Onljfels ere of made significance astf the host lnpetss& dUmm enaMham ahem below. ; ft of world production ChryeotUu (whits) Crooidelitu (bias) Anoeltc (brown) Anthcphyllitu Trsoolitu Actlnolltu 1.1* These six flbeas possess different properties ef flexibility, length, texture, tensile streugtb, ecld resistenee, spiensbiltty cad resistance to best which render then here or less suitable for serious usee. Asbestos has been turned the 80th anbusy uinerel slues the world consuupticn bee Increased ewer e thousand fold since 1900. hp far the greatest increase has occurred since Vorld Isr ZZ. The present world production exceeds 3 silllea tens annually. 6113 22014  at..^ ~ -irr^'irrtMariinfrii rfruim -iMf 1ut.- -w rage r.-.ree Asoestcs signify disaDility. 3 Cancer of the Lung In Persons with Aspestosls The first official recognition of the existence of a possible relationship between lung cancer and asbestos was contained in the 1947 annual report of the Chief Inspector of Factories tor Greet Britain (Dr,-* . A* Xarawatnar) published in 19^9* Since that time, statis tical studies by Richard Doll have proven an association between the two conditions and have demonstrated an in creased incidence of lung cancer in persons with asbestosis. Similar reports from other countries give support to the British studies. To date, there is in sufficient statistical evidence available to Indicate whether this is true of all types of fiber or whether it is associated with all uses of asbestos. Further intensive studies are currently underway in many countr-. including Canada. 4. Mesothelioma of Pleura or Peritoneum after CBPCIDOLITE Exposure In 195*> It was first suspected in Kimberley, South Africa, that there might be an assoc1stIon between exposure to the Cape Blue fibers and this rare tumor of the lining tissues of the chest and abdomen. Sty 1962, one hundred and twenty-one cases had been dis covered of whom 110 occurred in persons either working or living in the area where crocldollte Is mined. A similar study in London, England revealed that 51 of 83 persons who died with this tvusor were In some way associated with an asbestos factory in which crocldollte was handled. Whether or not these tumors are due to the fiber Itself is not clear. There appears to be an association but further research will be needed before the matter can be clearly understood. To date, there has been no significant data which would indicate an association between either chrysotlle or amosite and mesothelioma. Intensive studies concerning a possible association are presently in progress in Canada, the U.S.A., Great Britain and several other countries. B. Quanit8tlvely In the last few years, asbestos has been recognized as one of the most hazardous of air contaminants in the 6113 22015 !ge ??ur ;sestcs workplace. Employees exposed to asbestos include an estimated 100,000 Insulation workers, 50>000 workers in manufacturing products, 60,000 using end products ena uncounted thousands in construction. Labor unions nave pushed for stricter standards governing its usage, ana the Occupational Safety and Health Administration has listed it as one of five target health hazards in a new program aimed to control health hazards in the workplace. The first case of asbeatosis was not diagnosed until 1900, 22 years after asbestos was mined on a largescale basis. The victim, a British textile worker, had inhaled the asbestos dust stirred up by the carding machine he had operated for 14 years. Ten other men had been his co-workers in the carding room. All died before their thirtieth birthdays. Since the recognition of asbeatosis 72 years ago, the disease has been widely studied the world over, from the mines of South Africa to the mills of Quebec. Today, experts believe that asbeatosis is one of the most debili tating of the pneumonoconloses - lung diseases caused by dust inhalation. Erupting 20 to 30 years after the expo sure period, the disease exhibits no warning symptoms to mark its early stages. Many studies have uncovered cases of the disease in which the exposure was relatively light and did not continue over an extended period of time. Recent studies, such as those conducted by the Mount Sinai School of Medicine and the national Research Council, have produced some disturbing statistics on the mortality rates of workers using asbestos. Or. Irving J. Sellkoff of the Mount Sinai School of Medicine discussed the implications of these studies: "At present, one in every five deaths among insulation workers is due to lung cancer, one in ten to cancer of the pleura or peritoneum, one in tan to scarred lungs of asbestosis." Since insulation workers receive relatively light exposures to asbestos compared to some other occupational groups, these results are even more somber. If working conditions are not signifi cantly altered, asbestos exposure can lead to 17*000 deaths from lung cancer, 10,000 deaths from cancer of the pleura and peritoneum and 10,000 deaths from asbeatosis, according to projections by Dr. S. Cuyler Hammond of the American Cancer Society. 6113 22016 Page Five Asbestos III. How It is Used. Occupational exposures occur in the cement-asbestos industry in which shingles and siding, water and sewer pipes and insu lation boards are produced; in the insulation trade; in the manufacture of brake linings; the weaving of asbestos cloth, fiber and cord; the manufacture of numerous types of filters; the insulation of electric wire and cable; the manufacture of certain paints; the making of floor tils and gaskets; the production of moulded plastic products and in the spraying of structural steel framework for acoustical purposes and the spraying of insulation on turbines in plants where elec tricity is produced. In addition, since this substance is so extremely useful, numerous lesser uses exist. Workers in many occupations encounter serious asbestos expo sures. Among the establishments most likely to have asbestos risks are those manufacturing asbestos textiles, valve pack ings, asbestos sheets, brake linings, boiler blankets, building materials and appliance corde. Plasterers who spray an asbestos mix on the steel foundations of buildings have heavy exposures to asbestos. A thermal insulation and fireproofing agent, the asbestos mix prevents the steel froai buckling In case of fire. Plasterers can apply it without lntsrruptlng.oonstructlon activities, and the asbes tos mixture hardens in eight hours without cracking or shrinking. Mot only steal buildings, but ships sad boats sre treated in this asnner. Brake mechanics must also cope with significant levels of air borne asbestos. Yaluabla because of its resistance to heat and its ability to withstand abraaiva forca, ehrysotila asbes tos makes up 50 percent of brake lining material, lomever, the friction breaks asbestos fibers sway from the fabric. Many mechanics remove the asbestos fibers that have accumulated around the brake drums and assemblies with a compressed sir hose. This produces a cloud of asbestos dust around the mechanic and anyone in his working area. Alternate cleaning methods are needed; for example, a vacuum cleaning device reduced the haserd in recent tests in England. Insulation workers are the largest single occupational group to handle asbestos on the Job. Their exposures, however, are relatively light. In most types of insulation, asbestos la used primarily as a binding agent and makes up only 15 percent of the material. Then, too. Insulators working with asbestos on a dally basis are encouraged to take precautions: good housekeeping measures, tools aquipped with local ventilation 6113 22017 Page Six Asbestos systems, and respirators for dusty work are safety precau tions stressed by their union. When insulation workers install materials containing a high percentage of asbestos, they often use a water spray on the cloth while unrolling it or uncovering it. Some insulation workers even cut asbestos on disposable tarpaulins in order to allow the excess material to be discarded without stirring up dust. This eliminates the need to sweep up insulation debris after a job. Usually a dusty process, sweeping Is discouraged because it holds a risk for the workers still on the construction sits. Bricklayers, carpenters, sheet mstsl workers sod boiler makers also install insulation at various tlmas, but oftan thsy fall to taka the precautions used by workers who handle asbestos on a dally basis. IV. The Panics lble Levels of Exposure A. Presently CdKCMTBATlOR - FlbersAH1111 Iter fritter that 8 mlcrams Is lamftfc Exposure Tims 8 deers ttttbstrt Bnplratfify Protection Op te S Sfl Up ts 10 218 Approved JLin. tesplrster * MrMa llttplrster Op tali Opts 80 raster teas SO B OMIk Beqatrenents On this Bete, the an (T.V.A.) for r of The celling con centration is retained et 10 fibers per elUUlter of elr greeter then 5 atones te length with no ties restriction provided the T.W.A. Is not violated. Coup1lance with future exposure Halts prescribed by the previous paragraph may not be achieved by tbs use of respirators or shift rotation of employees except 6113 22018 Page Seven Asbestos during the time period necessary to install the engineering controls and to institute the work practices required to comply with the 2 fiber standard. V. What must be done and when to meet OSHA regulations A. Clothing and Change Rooms The employer shall provide and require the use of special clothing* such as coveralls or similar whole body clothing* head coverings* gloves and foot coverings for any employee exposed to airborne concentrations of asbestos fibers which exceed the celling level prescribed In paragraph IV-B. At any fixed place of employment exposed to airborne con centrations of asbestos fibers in excess of the exposure limits prescribed in parsgrsph IV-B, the employer shell provide change rooms for employees working regularly at the place. The employer shall provide two separate lockers or con tainers for each employee, so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes. Laundering of asbestos contaminated clothing shall be done so as to prevent the release of airborne esbestos fibers in excess of the exposure limits prescribed In paragraph IV-B. Any employer who gives asbestos-contaminated clothing to another person for laundering shall Inform such parson of the requirement to effectively prevent the release of airborne asbestos fibers In excess of the exposure limits prescribed in paragraph IV-B. Contaminated clothing shall be transported In seeled impermeable bags or other closed* impermeable containers and labeled In accordance with warning paragraph. (See section VH-2b) B. Control Procedures Engineering controls* such as, but not limited to, isolation, enclosure, exhaust ventilation and dust collection* shall be used to meet the exposure limits 6113 22019 Page Eight Asbestos prescribed In paragraph IV-B. Local exhaust ventilation and dust collection ayateas shall be designed, constructed, installed and aaintained in accordance with the American Rational Standard ?undaatentals Governing the Design and Operation of Local Exhaust System, ARSI Z9.2-1971 All hand-operated and power-operated tools which say produce or release aabeetoa fibers in excess of the exposure limita prescribed in peragraphXT-B, such as, but not Halted to, saws scorers, sbraslve wheels and drills shall be provided with local extoaast ventilation systeas In accordance with AMI 9*2-1971. Insofar as practicable, asbestos shall be handled, alxed, applied, removed, cut, scored or otherwise worked In e vet state sufficient to prevent the ealsslon of airborne fibers in excess of the expo sure Halts prescribed in persgrsphXF-B unless the usefulness of the product would be diminished there by. Halts prescribed la paragraph XF-B or this sectten. Employees engaged in the spraying of asbestos, the removal or denolltlon of pipes, struttares, or equipaent covered or insulated with ssbeetoe and in the reaovsl or denolltlon of asbestos insulation or coverings shall be provided with respiratory equipment in aceordsncs with paragraph IF-B of this ssctlon and with special clothing in accordance with paragraph F-A. In work situations share the netheds prescribed to gain anglnaarlng control art slther tschnlcally not fsaslblo or fassIbis to an extent lnsufflc ant to reduce the airborne concentrations of asbestos fibers below the Unite prescribed by paragraph if-B or in emergencies respirators asy be used. 6113 22020 Page .'fine Asoestos Where both respirators and personnel rotation are allowed by this subparagraph and both are practicable, personnel rotation shall be preferred and used. Where a respirator Is permitted by this paragraph, it shall be selected from among those approved by the 3ureau of Mines, Department of the Interior or the Hatlonel Institute for Occupational Safety and Health, Education and Welfare. A reusable or single use air purifying respirator or a respirator shall be used to reduce the concentrations of airborne asbestos fibers in the respirator below the exposure limits prescribed in paragraph (B) of this section, when the celling or the 8-hour time-weighted average airborne concentrations of asbestos fibers are reasonably expected to exceed no more than 10 times those limits. A full facepiece powered air purifying respirator, or a powered air purifying respirator shall be uaed to reduce the concentrations of airborne asbestos fibers in the respirator below the exposure limits prescribed in paragraph (B) of this section, when the celling or the 8 hour time-weighted average concentrations of asbestos fibers are reasonably expected to exceed 10 times, but not 100 times, those limits. A type "C" continuous flow or pressure-demand, supplledalr respirator shall be used to reduce the concentrations of airborne asbestos fibers In the respirator below the exposure limits prescribed In paragraph (B) of this section, when the ceiling or the 8-hour time-weighted average air borne concentrations of asbestos fibers are reasonably expected to exceed 100 times those limits. C. Medical Bsqulrsmsnts 1. General The employer shall provide or make available at his coat, medical examinations relative to exposure to asbestos required by this paragraph. 2. Preplacement The employer shall provide or make available to each of his employees, within 30 days following 6113 22021 Page Ten Asbestos his first employment in an occupation exposed to airborne concentrations of asbestos fibers, a com prehensive medical examination which shall include, as a minimum, a chest roentgenogram (posterioranterior lb x 17 inches), a history to elicit symptomatology of respiratory disease and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEY). 3. Annual Examinations annuel examination shell include, ea a miniawe, a chest roentgenogram (posterior anterior 1% x 17 inches), a history to elicit symptomatology of respiratory disease, and pulmonary function testa to include foread vital capacity (7C) and forcad expiratory volums at 1 second (717). b. Work laslgnmsnt So enpleyee shell be assigned to teaks requiring the use of respirators 14 based upon hie nest recent examination, an examining physician dettrainee that the enpleyee will he unable to function normally veering a respirator, or that the safety or hoolth of tho employee or other employees will be Impaired by hie ese of e respirator, flmeh employee shell be rotated to another Job or given the opportunity to transfer to o different position shots duties ho la abia to perform with the same employer, in tho sane geographical area end with the sene seniority, states sad rate of pay he had Just prior to inch transfer, if such e different position is svsliable. 5. Examination on Termination Tho employer shall provide, or make available uithin 30 calender days before or after the termination of aaplcynsnt of any employes engaged la an occupation exposed to airborne eooeentrations of asbestos fibers, s ccnprehsnslve madleal examination which shall in clude, ee e wAnimm, e chest roentgenogram (posterioranterior lb x 17 laches), e history to elicit aynptoeetology of respiratory disease end pulaonery function 6113 22022 Page Eleven Asbestos tests to Include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEV). .6 Recent Examinations Mo medical examination is required of any employee, if adequate records show that the employee has been examined in accordance with this paragraph within the past 1-year period. 7- Records Employers of employees examined pursuant to this paragraph shell cause to be maintained cceqplete and accurate records of all such medical examina tions. Records shall be retained by employers for at least 20 years. The contents of the records of the medical examina tions required by this paragraph shall be made avail able, for Inspection end copying, to the Assistant Secretary of labor for Occupational Safety and Health, the Director of non, to authorised physicians end medical consultant* of sitter of then, end, upon the request of en esployes or former employee, to his physician. Any physician who conducts e medical examlmctlon required by this paragraph shall furnish to the employer of the examined employee ell the information specifically required by this paragraph, and any other medical information related to occupa tional axposurs to asbestos fibers. D. Monitoring 1. Initial Detsrmlnatlon of this section. iBHiHmmmrnm Is below the limits pre scribed la paragraph HP-B of this section. Xf the limits are exceeded, the employer shall immediately undertake e compliance program. 2. Personal Monitoring Seuplee shell bo collected from within the breathing tone of the employees, on neobrano filters of 0.8 6113 22023 ?dge Twelve AsDestos uterometer porosity mounted in an open-face filter nolder. Samples shall be taken for the determination of the 8-hour time-weighted average airborne concen trations and of the ceiling concentration* of a*oe*tos fibers. "arapies shall be of such frequency and pattern a* to represent with reasonable accuracy the levels of expo sure of employees. In no case shall the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph IV-B of this section. 3. Environmental Monitoring shall be collected on a membrane filter of 0.8 micrometer porosity mounted in an open-face filter holder. Samples shall be taken for the determina tion of the 8-hour tine-weighted average airborne concentrations and of the celling concentrations of asbestos fibers. After the initial determinations required, samples shall be of such frequency and pattern as to repre sent with reasonable accuracy the levels of exposure of the employees. In no caae shall sampling be et intervale greater than 6 months for employees whose exposures to asbestos asy reasonably be foreseen to exceed the exposure limits prescribed in paragraph IV-B. 4. Obssrvstion Affected employees, or thsir representatives, shell be given s reasonable opportunity to obsarva any monitoring required by this paragraph and shall have access to the records thareof. 5* Monitoring Records a) Records Required 6113 22024 | | j | j 1 Page Thirteen Asbestos Every employer snail maintain records of any personal or environmental monitoring required by this section. Records shall be maintained for a period of at least 3 years and shall be made available upon request to the Assistant Secretary of Labor for Occupational Safety and Health, the Director of the National Institute for Occupational Safety and Health, and to author ised representatives of either. b) Employee Access Every employee and former employee shall have reasonable access to any record required to be maintained by subparagraph (1) of this paragraph, which indicates the employee's own exposure to asbestos fibers. c) Employee Notification Any employee found to have been exposed at any time to airborne concentrations of asbestos fibers in excess of the limits prescribed In paragraph IV-B shall be notified in writing of the exposure as soon as practicable but not later than 5 days of the finding. The employee shall also be timely notified of the corrective action being taken. E. Records This record keeping requirement for the various aspects of asbestos exposure are listed with the appropriate section; Exposure, Medical etc. It is recommended anything that is involved with the use of asbestos or steps to protect any employee be recorded in a log. This should include but not be limited to; exposure.information, location sf and type of medical exams and records, respiratory pro gram, clothing program, system of warning signs, waste disposal and others. F. Respirator Program A respirator program shall be established In accordance with the requirements of the American Rational Standards Practices for Respiratory Protection, ANSI 2588.2-1969. 6113 22025 Page Fourteen Asbestos G. Housekeeping H. Warning Signs 1. Work Area Signs a) Posting such a distance from such e location so that an employee nay read the signs and take necessary protective steps before entering the area aarfced by the signs. Signs shall be posted at all approachea to areas containing escesslve concentra tions of airborne asbestos fibers. b) Specification it Detail The warning signs required shell conform to the requirements of 20* x it" vertical format signs specified in section 1910.lA5(d) (4) of the OSHA Standards. The signs shall display the following legend in the lower panel, with letter sixes and styles of a visibility at least equsl to that specified in this subdivision. Legend Rotation Asbestos Dust Hasard Avoid Breathing Dust Wear Assigned Protective Equipment. Do Sot Remain In Area Uhlesa Tour Work ReQuires It. Breathing Asbestos Dust May Be Hazardous To Tour 1" Sans Serif, Gothic or Block 3/A* Sans Serif, Gothic or Block 1/A" Gothic 1/A" Gothic 1/A" Gothic lA point Gothic 6113 22026 Page Fifteen Asbestos Spacing between lines shall be at least equal to the height of the upper of any two lines. 2. Product Label a) Where required Caution labels shell be affixed to all raw materials, mixtures, scrap, waste, debris and other products containing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modi fied by a bonding agent, coating, binder or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in paragrsph XV-B of this section will be released. b) Specifications and Detail The caution labels required shall be printed in letters of sufficient size and contrast as to be readily visible and legible. The label shall state: CACTIOff Contains Asbestos Fibers Avoid Creating Dust Breathing Asbestos Dust Ney Cause Serious Bodily Barm I. Waste Disposal Asbestos waste, scrap, debris, bags, containers, -------.----------- a Mil ol ntk<n processing, disposal or transportation) pnMBUMi prescribed In paregraph IT-B shall be collected and disposed of in bags or containers shall be burled In an approved sanitary landfill. 6113 22027 Page Sixteen Asbestos VI. How to Monitor A. Equipnant (37 wm, 0.8 u pore size). Face cap Is rvnoved and filter used open face during saapllng. Saapllng rate: 1) The saapllng puaps should be: 4BHNM! either Mleronair or C 115 Puap; Literature. attached Oravlaetrlc Saapllng Kit; see attached lltera ture. 2) The filter should be: field aociltor. This Is a pre-packed 3) An adapter will be needed to connect the field aonltor to the tubing froai the puap. This is Milllpore address is Milllpore Corporation, Bedford, Massachusetts 01730. 4) Before purchasing equipment, it asy be helpful to contact the Industrial lyglane section of the Medical Department for advice. B. Saapllng Technique 1. Follow the Instructions that cone with your puap and fully charge It's batteries. 2. Connect the tubing to the puap and the aerosol adaptor to the tubing. Beaove the red plug froai the field aonitor and Insert the adaptor. Banova clear plastic section which contains the blue plug. 3. Place saepler on aan. Attach the puap to his belt. Attach field Monitor to collar of shirt so that it is as close as possible to the nan's breathing zone. 6113 22028 page Seventeen Asbestos 4. Start sampler and record time, Set sampling rate at 2 liters per minute. At end of sampling period, make sure sampler Is running at a rate of 2 liters per minute then turn off and record time. 5. Keep detailed log of all Jobe workmen perform while they were wearing sampler. C. Evaluation of Sample 1. All determinations of airborne concentrations of asbestos fibers shell be made by the membrane filter method at 400-450 x (magnification) ( 4 millimeter objective with phase contrast illumina tion). Send the filter to at the Research Department or flHpm for analysis. Also send a copy of fiber count to yoo. Ve will return a Bjr sending the sample to the mlcroecoplst of C.B.D., yoo are assured of getting meeorete ccents. The actual procedure le much more complicated them de scribed in the preceedlng paragraph. Meet plant laboratories are not equipped to perform this analysis. D. Calculations Flbar Count You will race1vs from John Fairing a Total fiber count. This is the total number of fibers on the face of the membrane filter, nils is the count you need. Amount of Air a. You have recorded the flow rate in liters per minute. b. You have recorded the sampling time In minutes. c. Multiply the flow rste (I/M) times the sampling tins (minutes M) times 1000 (cc/llter). 6113 22029 MftlMMWiilMHiMBillilMa "'' ht-i i vriwi titr 'iimhi-r afi< ''tT-h *.lirffr + Page Eighteen Asbestos 3. Fiber Concentration Divide the fiber count (1) by the amount cf air (2). This will give you fiber concentration In fibers per cc of air. Compare with standards in section IV. 6113 22030