Document Lpaod5aX1b3GaxzDL1nyMVn83

f. >.* PLAINTIFF'S EXHIBIT DOW-1774 S T 07U1739 GUIDELINES: ASBESTOS HANDLING IN THE CH LOR-ALKALI INDUSTRY Edition 1 November 1978 DOW CONFIDENTIAL MEMBER INFORMATION REPORT 137 Th Chlorine Initttulo, Ine.. 342 Madison Art.. New York, N.Y. 10017. Additional copies ol Ihts pamphlet art available at nominal toil. ST 0741740 COHTEHTS I. IMTMOUCTIOH I I SU 1.2 Definitions t.) 0)iel*l>r >.* Approval 1-5 Revisions 1-0 Reproduce Ion 2. ASBESTOS USE IK CHLORINE MANLFACTVRE ). REGULATIONS 3. I 3.1.1 3.1.2 3.1.3 3-1.A 3.1.5 3.2 3.2.1 3.2.2 3.2.3 united States OSHA EPA-AIr tIA<Vaiuntar CPA-Maaardous Wastes MT-Haaardeut Materials Canada Workplace Air Water A. COKTML PROCIOURES A. I A.2 A.3 A.A A.5 A.S.1 A.S.2 A. 5.3 A.5.A A.A A.6.1 A.5.2 A.A.3 A.A.A Central Purchasing Receiving Storage WIng-Olaphregn Depositing Sorting and Weighing Protective Equipment Housekeeping Personal Hygiene Spent Asbestoi Wash Area Olsposa! Water Re-Use Landfills 5. EMPLOYEE PROTECTION 5.1 Cenersl 5.2 Caution Signs and Lahels 5*3 Respirators 5-A Proteeclve Clothing 5.5 Housekeeping A. EXPOSURE HOM1TORIHQ A.l A.I.I A. 1.2 A.I.3 A.l.A A.2 A.2.I A.2.2 A.2.] A.2,A A.2.5 Hygiene Monitoring Personal Monitoring Environmental Monitoring Records Cup lores Access and Notification Medical Surveillance Pre-Placeoent Periodic Tarolneclon Record Retention Employee Access 7.1 7.1.1 7.1.2 7.1.3 7.1.A a.l a.2 A.3 5.A 7. CW.0YCC TRAINING Ope rat log Procadures Raspfratori Pretectlva Clothing Parsonsl Nyglana Smoking I. references ool (u.s.) epa (u.s.) Miscellaneous Other Information Sourcat . APPENOICES 5.1 Analytical Mathods 5.2 Regulation! (U.S.) DOW CONFIDENTIAL ST07M7UI I. INTflWUCHflB scon increased iwriftiii of the Km 1th hdlards of asbestos, cou&led with regulations promulgated by governmental agencies over the past several years, eaehasJae eho desirability of developing guidelines for the safe handling of asbestos fiber and waste products by cMor-alkali producers. Industry end government share concern and responsibilities to Insure the health and welfare of workers and the general public that eight be exposed to asbestos, especially that which (j airborne and can be Inhaled, by providing safeguards to protect than fro* hazards associated with asbestos mining, transport, fabrication, use and disposal operations. This pamphlet Is United to cons Iderat Ions relative only to esbeitos safe handling end disposal practices applicable to the cMor*a)kalt Industry, examples of satisfactory asbestos control practices, where given, are Intended to be only Mlestretive and arc not to be construed either as having universal applicability or representing the only available or suitable means of control. Off I NITIQfll In this pamphlet the following meanings apply: Asbestos means chrysoUla, amoflte, creddotlte, tremllce, enthophyMUte, and ectlonoMte end, In cne case of OSHA regulations, those of such fibers that ere longer then $ micrometers. (The chrysotlle variety accounts for most of all fiber used in the U.5.J. Cf* means the U.S. Code of federal Regulations. 00t means the U.S. Department of labor. ERA means the U.S. Environmental Protection Agency. iWSTITUn means The Chlorine Institute, Inc. KIOSK meens the Rational Institute for Occupational Safety and Health of (he U.S. Department of Health, education and vie I fare. OSKA means the Occupational Safety and Health AdministratIon of the U.S. Department of labor. OSH Act means the U.S. Occupational Safety and Health Act of 1570 (b.l, 31-556). Particulate asbestos material means finely divided particles of asbestos material. Visible emissions means any emissions which are visually detectable without the aid of Instruments ana wnich contain particulate asbestos material. DISCLAIMER The Information In this pamphlet f$ drawn from sources believed to bo reliable. The Institute end Its members. Jointly and severally, make no guarantee, and assume no liability, in connection with any of this Information. Moreover, It should not be assumed that evrv acceptable procedure is Included, or that special clrcianstances may not warrant modified or additional procedure. The user should bm aware that changing technology or regulations nay race I re a change In the reconmendatIons herein. Appropriate steps should be taken to Insure that the informally Is current when used. These suggestions should not be confused with federal, state, provincial, municipal or Insurance requirements, or with national safety codes. APPROVAL The Institute's Environmental Protaction Committee approved the first Edition of this pamphlet on February 13, 1579. REVISIONS Suggestions for revisions should be directed to the Secretary of the tnstltuta. RgpaOOUCTIQH The contents of this pamphlet are not to be copied for publication. In whole or In part, without prior institute permission. I. ASBESTOS USj 'H CHLORINE KAJHJFACT'JRIftfl. Most of the World's chlorine It produced by the electrolysis of brine In either mercury calls or diaphragm ceils. In the electrolytic process, It Is necessary to keep ehlorlne separated from the alkali natal hydroxide co-product to prevent cnemlcal reaction. In addition, hydrogen produced with the alkali must be kept separated from tne chlorine to prevent potentially violent explosions. in mercury cells, separation It achieved by hydraulic seals which separate the chlorine and spent brine in the electroiyter from the decomposer where the alkali metal hydroxide product and hydrogen are produced. Ho asbestos is Involved. t , : mr J.I 3.1.1 .. .......r inn i. .thieved by ll of a dlephraqm <dieh il basically a porou, in dlapnregm **F anolvta and catholyte chambr. rlne It led to lha anolyte mechanical barrier ****'' . . aleetrollaad to chlorine. The depleted brine and the cation ^rt"o$i thediaphra^m to the c.thod. -era hydro,en and alkali natal hydro.lde are produced. ,uccl*M operation of dlephrag* cell Is the diaphragm Micritl. It nu't have the fol Inning proport lots To be Suitable, * sufficient rwchanlcel rmgO: . Mgh chemical r*lt*nce; . - (gw electrical resistance; readily depot I table on the cathode with uniform thickness and without voids; - appropriate physical structure to permit percolation of depletes brine with minimum tack-miration of hydroxyl fort; and - acceptable service life. These properties are of prime Importance as they have a vary significant effect on both capital and manufacturing costs. Asbestos Is uniquely suitable as a diophr-7o material, as It exhibits a most favorable combination of these properties. Asbestos Is a general term covering a group of impure, naturally occurring magnesium silicate minerals which exist in fibrous form. One of theta Is tha mineral chrysotile which Is made gp of comparatively long and strong flexible fibers, It Is a highly hydrated magnesium silicate of general composition, Hg6(0H)gSi^0|Q. Over 95* of the asbestos mined is chrysotile and it is the form used for diaphragms by the chlor-aUell Industry. A great deal of research has been done to study the behavior of asbestos In enlor-aikall cell environments to explain itl unique behavior. The deposited fibers do not merely function as a deooslted mat such as is found In a filter bed. The eel layer that >cms in the mat under proper cell diaphragm depositing conditions plays an i<>ortMt role in the performance of the diaphragm, particularly in minimizing bacA*migratloft of the hydroxyl ion. North American consumption of asbestos for chlor-alkall celts In 1)78 Is estimated to be in the order of 3.500 tons per year. Asbestos consumption per ton of chlorine produced has been slgnifieently reduced over the years through advancements In cell design. Improved brine purification techniques and new anode materials. Asbestos diaphragm life has been increased very significantly, The first major Increase occurred with the change-over from carbon to graphite anodes, more recently the change to metal anodes has extended diaphragm life by some three to four fold compared to experience with graphite anodes. A newer development, resin bonding of the deposited asbestos fibers, is expected to Increase the stability of asbestos diaphragms and further extend thalr life. Asbestos Is the universally accepted material for chlor-alhall cell diaphragms, and If handled properly. It can be used and disposed of safely both with respect to worker nealth end protection of the environment. J. ACCUlATfQNS UMITtP STATES Currently In the U.S. regulations applicable to asbestos have been Issued by the EPA, OSHA, COT, Food and Drug Administration, (ha Consumer Product Safety Coanitsion and the Mining Safety and Health Administration, Only the first two are of direct concern in the operation of chlor-alkall plants. States may also promulgate standards which can be more stringent man the federal standards. OSHA The stated purpose of the OSH Act Is to "assure so far as possible every working men and woman In the nation safe and healthful working conditions'*. 0SNA*s activities are the development, promulgation end enforcement of federal safety and health standards; the dveloo*enc aspect is shared with HIOSH. The current OSKA asbestos standard was Published in J7FMI3I8 (June 7, 1972) and is embodied in 29CFAI9I0.IM!. In *<mnery, the stendsrdi Establish., an tight-hour tlmt--tlghiad average (TWA) or*r exposure Unit of airborne asbestos <t two(J) fiber, p,r cc of elr longer tnan $ mlcreme lari. And, , ceiling concentration, tne regulation state, Ih.t no employee me II be exposed at any tin. to Iietitn conceal ration! in C.I! of 10 fleer, per cc of .if longer chan 5 micrometer! 129CFA1JI0.1001 (ol(2) end (J)]; * Fr.icrlbei various method! of compliance, incleding en,lne.ring natnodl end control! tuck ,, Isolation, exposure, amt collection and canantt .animation, and-or. practice, including rulai governing -at method!, handling of asbestos product! ate. (29CfAIJI0.I0SI(c)(I) and (2)); * Fermitt for euroosas of comollenca the ute of -ork thift rotation (preferred) *,,d r.ipir.tor, 22,11 aaftai" -ork ,ltv.Hon>. (Sa. S5-1). To, regulations further toaelfv the type of r*,plretort to ba utad under various condition, [29CFM910. 1001(d) (1) ana (2)); * Frovidas that employer, shall provide and r,quire tne use of protactlva clothing for employee, tape,ad to asoesios concentration, exceeding in. prescribed ceiling level. |29CrAI9IO.1001 (d) ())) ST074!742 Prescribes that employers shell provide change room et any fixed piece of employment exposed to airborne concentration* of asbestos fiber in excess of allowable exposure Mlu, and two separate lockers or contelners for each eeoloyea to keep street cloches separate from work clothes. [25CFM910.1001(d) <*>h Provides for the labeling, transport end leunderreg of asbestos contaminated clothing. Including off-preeliai laundering (29CFAl9tO.1001(d) <4)<ll r>: Establishes e method for measuring the airborne concentration of asbestos, (See $9. I) (25CFR19I0.1001(a)J t Establishes monitoring Methods end frequency relating both to tha work environment and Individual employees, and requires that employees or their representatives bo given a reasonable opportunity to observe the monitoring and to have access to eon I tor I ng records [2}CF*I9)0.1001 (D]; Prescribes rules for the posting of eaucfoo signs In areas where asbestos concentrations may exceed the allowable Holts, end labels to be affined on raw materials, mixtures, scrap, waste, debris or theJr containers (2fCP*ISI0.1001(g)]s Establishes certain housekeeping requirements Including tha cleaning of the work place and asbestos waste dliposal [29CPR1910.1001<h)11 Establishes certain recordkeeping reeuirementt governing Individual and envlronmental Monitoring exposure records, employee access to exposure records, and employee notification of exposure to asbestos t29CFRI910.1001(l)]. Requires preplacement, annual, and work termination medical examination* and the maintenance of. and employee access to, medical records (2?Cfftl9l0.100t (J)l. ST07I) 1743 J.1,2 CPA-Air Emission standards on asbestos applicable specifically to tha chlor-alkall Industry were published bv CPA In 16FR6820 (April 6, 1971) end emended 40FRA3292 (October lb, 1975), as part of the Clean Air Act's $112 National emission Standards for Hatardous Air Pollutants (NESNAPj. They era embodied in MKFft Part SI, Subpart I, In sumnrnry^the standard: 3.1.3 J.l.k Provides that there shell be no visible emissions to the outside air (i.e. air outside buildings and structures) or directly from chlorine manufeccurIng operations If they are conducted outside of buildings or structures (kOCFRbl.22(c)]; or, Provides, at the owner/ooeracor11 option, use of specified methods to clean emissions con* tainlng particulate asbestos material before such emissions escape to. or ere vented to, outside air (AOCFfttl.22(f) and ACCM6I.HJ; Requires asbestos waste generator* to Insure that the waste Is disposed of In a properly operated disposal site (AOCFRbl ,22{j) end *XFR4r.25l; Establishes reporting requirements in connection with the handling pf ebescoi~conce>n)ng waste materials (bOCFRbl.2b|, CPA-tfastewater Ft 92-pM, in, Faderal Veter Folluclon Control Act AMn.ndn.ot* of )J72, ,* an.w, (pl 95-217) raq.lm Out Industrial lourc.s tro.t tbelr affluent by AWlyin, the "beat practicable control technology currently available" (FT> by July I. 1977. Cffluent ll.nltbUon gulicllro. eicablisli the degree of effluent quality eeceitary to noet 6FT llialts. Though not iptclflc for asbestos tfT total suspandad toll9a ll.itatlon* aoallcaOla both to .xietlag and no* dl.pfcr.g* call chlorine -onufecturln, operations are eetabllsned fJAlS.62(b)! at follo-s: Pellv Raxlmwi 10day Average haxlmym kg/1000 lbs/1000 kgC Is IbsCU O.be 0.4k kg/1000 kgCU 0.12 lbs/1000 IbsCU 0. J2* CPA-Hetardous Wests* Regulations pursuant to Subtitle C of PC 94*580, the Resource Conservation end Recovery Act of 1974. h*v* net vet been promulgated. Such regulations at do currently apply to the handling of *sbe*tot*cofttminated wattes ere embodied in the NESHAA regulatioos discussed in $).|,2. 3,1.5 7.2 1.2.I 1.2.2 3.2-5 POT-Hazardous haterlels kegulafion, relative to coverclal asbestos shipment, were pubIIihad by T In A)rR56664 (Dacenbar 6, 1978). They ara cnbodiad In *9CF9, fartt 172 thru 177; set $ 9.2.1. caitaoa Canada I, the Vast.rn -orla's largest producer of asbestos and supplla, about )J per cent of the global production. As ts the case for O.T.. bom federal and Provincial regulations sr* applicable. Workplace No federal regulations have thusfar been promulgated. At the provincial level, the Quebec draft Regulations dated feoruary 1975 propose to reduce the present allowable level from 12 flbers/cc (all form > S micrometers) to $ flbers/cc.The workpiece standard for the province of Ontario, ho*aver, is 2 fibert/cc. Air FeoeraI Clean Air Act regulations for esbgstot promulgated July I), 1977 require that air emitted to tne atmosphere from crushing, drying and milling operations and dry rock storage shell not contain more then 2 f?beri/cc of ar (fibers being >5 micrometers in length and having a length to width ratio of > 3), Water HoTeeeral asbestos regulations have yet been promulgated but they are in process of develoomene. At the Provincial level, it has seen established with the Quebec Ministry of Environment that "Asbestos sludge **t be prevented from entering the water course and can only be reneved from the site after consultation with an Environmental Official", DOW CONFIDENTIAL *l*l I *|L0S C|4 CONTROL PtOCCMJftES k. | k.2 4.3 4.4 tlHtML -- . ItMi to considerations relative only to etbestos safe mndlim and disposal TNfi pamphlet is |0 ,hft ch|0r.#|iu| | industry. Ixamples of satisfactory asbestos control ?/Kt e" *PP ^ given, are intended to be only illustrative are not to be construed either *hevt^g u"lr**' *bP,lc>b,,lt>' ** representing tne onljf available or suitable means of control PlWCHASIHC While the handling of asbestos U presumed to start when a box car or truck is received at the plant* there ar# some eerlier opportunities for minimizing leter handling problems such as at the tlne of issuance of purchase orders. See $9.2.1. It Is recommended that purchase orders be written to the vendor h!cn includes t-x> Itmt, namely; (I) palletizing of the asbestos bags in the ran car or truck, and (2) provision for shrink-wrapped coating of Visqueen or other non-porous material covering the palleted bags, Thi* procedure is especially effective In preventing torn bags and minimizing the threat of loose materiel during unloading. In addition, the palletized, shrink-wrapped pc<aging procedure allows ease of movement to the confinement areas. In plants that do not have forklift unloading, it is suggested that asbestos shipments have sufficient dunnage included to prevent movement and damage to the bags during transport. ncaviHL Where atoestos is received In palletized form, whether by rail car or truck, the contents should be carefully Insoected before the unloading ooeratlon begins. If broken bays or loose asbestos are in evidence at the time, a heavy duty vacuum cleaner should be usee before the major work crew Is called for the unloading operation. A heavy duty bag vacuum cleaner closely aooroximates the blower/bag system recommended by EPA for emission control, broken bags should be enclosed in e heavy duty plastic bag before the vacuum clean up is started. that person charged wfth the initial inspection of the shioment should be equipped with an approved dust mask ($$.)) as well as wear suitable protective clothing If unsafe conditions exist all other individuals should be kept away from the area until such time as the condition Is corrected. When transporting palletized asbestos co storage, cere should be teen to prevent puncturing the bags with the forks of the truck or damage ay running Into corners or loose objects. The plestiewraoped pallet cover makes it possible to unload even during inclement weather, If desired. The operator of the fork truck should have available a dust mask and wear appropriate protective clothing if the situation warrants. An effort should bp made co *eep to e minimum the nuiber of employees used for the unloading operation, while at the same time avoiding any safety risks. Contract labor used by the plant must be protected in the same manner as a permanent employee. Workable agreement* between the company and the contractor, preferably in writing, should be clearly understood and adhered to at ail timet. STORAGE An lmoor tint aspect of the total asbestos handling program Is an appropriate storage area. AM plants require an inventory of asbestos on hand for normal operations, and careful thought should be given to the storage area desigm* Ideally the asbestos storage area should have no direct interconnect ion with the primary work area of the cell renewal ooeratlon. The entry should be sufficiently large to permit easy aecess of the forklift Into the storage compound. The entry door should be equipped with # rubber gasket on the sealing lip to provide for a reasonably tight system. Th cel lino should be as low as possible to limit unused space and at the same time provide the clearance hegot needed for pellet slacking. The approach to the storage area ust be appropriately narked with caution sign stipulated by OSHA regulations (29CPRI9.1001(g)J. When an access way eaitU between the asbestos storage area and (he major work area of e cell renewal operation it should have a well-fitted door with good weather strioping. The door should remein closed at all time* and should be marked with an 0$HA*ipproved caution sign. In such cases It Is recommended that the storage area oe maintained under a slight negative pressure. Another means of storage Is the "assigned* railroad ear, tf trackage is available near the operation area. This method not only Insures improved condition of asbestos shipments but also decreases the amount of handling and the potential for spillage. The rail ear must be properly marked with warning signs. A first-in, first-out inventory system Is recommended end, thus, If possible, the storage area should be designed end appropriately sized to accomodate this type of inventory control. The logic of a first-ln flrst-out inventory control is simply that this control reduces problems associated with long term storage of asbestos begs. The asbestos storage ere# should be kept (less and free of loose asbestos fiber. This can best be accomplished with a common sente approach to housekeeping, Wooden pallets should not bp Itxed to accumulate In the storage area. Any area or surface showing signs of asbestos, whether on floors, walls, or pellets, should be vacuumed using an eporopriate industrial*type vacuum cleaner. The disposal of the vaceun cleaner peg must be handled in an environniaMy sound ranner such as by enclosing it in a labeled, heavy plastic type bag or other impervious DOW CONFIDENTIAL container that will be Sent to an opr'oved asbestos landfill site. AI ternacl ve I y, the erei may be washed Into a waste asbestos collection system o** the asbestos wetted down and picked up. it Is suggested that a periodic Inspection of the storage area be nace by a supervisor end that (mediate action be taken to prevent or reduce the possibility of airborne atoeicoi fiber, fc.5 USIMG-OIAPHPACH PCPOSlTfMC A potential exposure to asbestos In chlor-elkai? ooeratlons occurs when it Is being preoared for use in making diaphragm*. When handling Industrial bags from storage to point of use, cere should be taken to be Sure that the bag is not split or open. A supply of large heavy duty plastle bags should be evallable for containing any broken bags before movement is allowed to take place. Those emoloyees working in direct contact with asbestos should wear an approved dust mask and appropriate protective clothing. Bags of asbestos to be added to the diaphragm bath should be moved carefully to prevent or minimise any dust emission that may arise, legs should never be thrown or dropped as this will result In asbestos contamination of the air. There are a variety of safe ways of handling dry asbestos In preparing for diaphragm depositing operations. Aegerdless of the approach used. i( Is Imperative that emissions of dry asbestos In the worker breathing ion# or to Che analent air be controlled to within regulatory limitations. The mere weighing and dumping of asbestos Into a depositing bach without benefit of a vacuum venting system to contain and trap asbestos dust should be avoided. As < mini<%r*. asbestos 649 cutting, emptying, sorting, weighing and slurry praparaelon should be performed under a vented hood; <c figure I. A more sopnistIcated approach would be to perform men operations In a tightly sealed, vented enclosure into nieh the operator inserts Hi hands in gloves fastened to the inside of the enclosure. ST07U745 k.5.1 FICUAC I. 4SKST0S OUST C01UCT0A Vritten detailed operating procedures should be available to workers and it snculd be determined they are being followed. These mould include Information as to the types of protective clothing and mesh* to be worn, including their ultimate disposal; checking of vacuum and exhaust system; details of ilerry mane-up operations; shut-down and housekeeping procedures etc. Sorting and Weighing treat o> t care s nowI a be exercised in opening asbestos bags, especially if not done within a seated System, A suggested technique Is to use a healed knife to cut the bags. Bags should be fully sMt, always under a vacuum vent system, ana carefully folded over to allow erpcytng of the bag with a minimum disturbance of the contents, lags should never be snoken. Any necessary de luding of asbestos similarly should be done cautiously 10 minimise dust release, Tmpty bags should be carefully folded with slit area Inside, agam within the sealed or vacuum vent system. Within that system they should be deposited in a lidded, labeled container reserved for (he purpose or placed in a labeled, plastic bag that is tied or otherwise fastened Shut. When only oarcial contents of 4 bag is required, the bag Should t< resealed effectively, such as with wide duct face, to contain the remaining asbestos. Weighing of asbestos should be done, again wtthle a seeled or vacuum vent system. In such a manner as to minimize dust release. The same applies to preparation of the asbestos slurry, Containers of sighed asbestos must have a lid in place as soon as the proper weight Is obtained. DOW CONFIDENTIAL s T074 1746 (,5.1 brotective Eouioment Co^eri involve Jft asbestos beg transfer Ktd slitting, sorting. i9^iend slurrypreparation operation* should wear 4" approved mesk or retpiretor as well at suitable protective Clothng. k.5.3 Housekeeping Uoof collet ion of operations any asbestos Albert thou Id bo removad. tueh at by a vacuum hose. Tha work aroa thou Id than b carefully flushed down with water; hitting dried esbeitos with high/ madium pressure water might causa soma of It to bicone airborne. 6.$.4 Personal Hygiene Used oust mates, glove*, and other protective clothing should be removed end pieced In the labeled recepteclei't) eat aslda for tha purpose, and the receptacle than should be closed or otherwise fastened. Mon-dlsposabte protective clothing should be Inspected end any fibers vacuum-removed; clothing should nee be air blown, shaken or brushed for this purpose, workers should wash hands and face before leaving asbestos-contaminated areas. 6.6 SPENT ASftESTOS l, 1,1 Slash Area Asbestos diaphragms need be removed and replaced at some frequency depending on cell type, brine quality! end other variables. The wash area should be constructed with a smooth surface to prevent asbestos from adhering and drying, and from becoming a possible source of airborne asbestos. The area should also contain a trench system for receiving and carrying away the asbestos to a sump or pit. If possible, some sort of minimus sloping of the concrete floor should be used 10 facilitate drainage. The collection trench should be covered with removable type grating to allow for ease of clean-up. 4.6,2 After use of the wash area and at the end of each work day, all areas should ba carefully flushed to remove all traces of asbestos. If water use If a probfam tha area can b Initially cleaned using e lerge rubber squeegie; final wash down then can be accomplished with a minimum quantity of water. Disposal A* it the case with diaphragm depositing operations, there are several alternate ways of safely disposing of spent asbestos. Separation of spent asbestos from tne diaphragm water wash generally Is accomplished by approved pond settling or by filtering, such as in plate and frame filters. The system choeem will depend largely on the availability of soaca and Its optimum utilization. bonding and settling of asbestos-containing cell renewal wastes can be facilitated by the addition of a poiyelectrolyte flocculant. bond size will, of course, depend on the volume of waste to be handled, climatic conditions, etc. bonds will require occasional clean-out of settled materials; this can be accomplished by e carefully-planned clam shell bucket trensfer operation with the solids being emptied Into covered, water-tight trucks for transfer eo an approved landfill disposal site. Cor ve -t lone I plate end frame filters affectively remove asbestos per* ides* and reeulrc regular maintenance, filtered asbestos should be deposited Into a suitable water-tight, covered container, for eventual transfer to an approved landfill disposal site. Such containers should pc kept wetted to prevent any airborne asbestos and must beer the required OSHA caution label. k.6.) 6.6,k 5,I Veter Re-Use If water reuse from a diaphragm renewal operation Is contemplated, some treatment prior to use may be necessary . Lendf?111 LandfTl Is into which asbestos wastes are deposited, whether on or off-premiset, are strictly controlled by EbA [40Cf*6l.25), as are reports pertain# to seme I40CPR61,24), Transportation of wastes to contract disposal sites must be accomplished In accord with any applicable regulations. 5. EHbtQVEC bkOTtCTlpq CtHERAl Asbestos can cause serious health probeIms unless It It properly used and handled. Excessive exposure to asbestos dust esn cause human disease, specifically pulmonary fibrosis, carcinoma and pleural mesothelioma. The quetIfIcation of the health risk associated with specific airborne concentrations, fiber dimensions, and Che chemical composition of the fibers, however, is inexact, in addition the problem of estimating the magnitude of the risk Is complicated by the 20- to 40year latency period between the onset of exposure end the appearance of disease. Consequently, human exposure must be reduced to within allowable exposure levels. Regulations require that engineering controls, such as, but not limited to, isolation, enclosure, exhaust ventilation, and dust collection, be employed to meet the limiting TVA and ceiling level exposure concentrations [29CbkI9IO,1001(c)]. They also require, Insofar as practicable, that asbestos be handled, mixed, applied, removed etc. in a wet state sufficient to prevent the emission of airborne fibers in excess of the 1Imltlno worker exposure concentrations. Comp11 area ^wnTTe f i Iters are effective for asbestos particles or bundles. It has been suggested that they are not effective on smel I fibrils. q\00^- ST074I747 av not be achieved by the use of respirators or shift rotation* except In those work situation* where (e) prescribed engineering control method* end/or work practices er technically hoe feasibl or feasible to an extent Insufficient to reduce the airborne concentrations of asbestos fibers below permissible TWA end celling concent rations, *nd (b) during emergencies: in those Instances, end where both respirator* end personnel rotation ere practicable, personnel rotation shell be preferred end *ed f29CFA|$IO,1001(d)J, 5.2 CAUTtW 5IGH$AA01A&ELI Caution signs must be provided end displayed et tech location where airborne concentrations of asbestos ray exceed Hotting worker exposure concentrations (23CFR1$IQ.t001(g)(t)l end et end around asbestos waste disposal if tel (40CFA61.22O)J. The signs must be of such dimensions end posted in such a meaner Chet e person may easily reed them end take necessary precautions <*tf protective measures before entering the area marked (29CFftf9IO. 1001 (g) (I) and 60CFA61,22(0(2}). It Is recommended that caution signs be posted wherever asbestos Is handled or used. Caution labels ust be affixed to ell raw eaterlals, mixtures. icraos, waste, debris etc, tnnteinjng unbonded asbestos. or to their containers (I9GFA1910.1001(g)(2)), including sealed, leak-eight containers of asbestos-containing westet (e,g. empty begs, dust masks, disposable clothing, sludges ate.) destined for wl timet# disposal at approved lanofill sites (A9CFA6i,22(jJ). S.) KsrmroAS Where use of respirators are permitted they must be selected from those approved by either the <J.S. bureau of Hines or *t03H/HInIng Snforcameet and Safety Administration {25CFAI9I0.1001(d)(2}J (See Aef. S.I.I) or other appropriate approving authority. OSMA General Industry Standards on Respiratory Protection (Z5CFA13I&.1001.I) rtdwi're that a respiratory protective program be established by the *'oy*r eng chat the respiratory protective equipment used be effective. (Sea also 2SCFA))I0.1001;.} (2). It \i recommended that employees wear an approved dust respirator whenever there exists a good possibility of exposure In excess of allowable standards. This is especially applicable wen performing maintenance work on dust collector components. I AROTfCTlVC CtOTHmG Regulations require that workers exposed to asbestos in excess of the allowable ceiling concentration of 10 flberi/cc wear protective ciocning such as overalls or similar -noIe body clothing, head coverings, gloves and foot coverings: such clothing must g# employer.provided (29CFAI9I0.1001(d)(3)). it is reconnwneed that protective clothing contain no poc*et* or side Openings. employers also are obligated to provide change rooms for workers In situations where workers may be exposed to asbestos fiber in excess of the alienable TVA and catling concentrations, and two separate lockers or other containers for each worker so separated or Isolated as to prevent contamination of the worker's street clothes from his work clothes{29CfAI910.100!(d)(k)]. Many employers prefer to provide disposable-type overalls although reusable ones ere permitted. (n the latter case, antl-statlc, cotton polyester fabric of fine wsave has proven highly seeisfactory. laundering, whether on or off premises, should be done In such a way at :o prevent airborne contamination In excess of allowable limits. Vhere contract laundering exists, it Is Incumbent on the employer to Inform the launderer (preferably In writing) of this obligation (29CFA13IO.1001(d)(k)); It Is also recommended that the operation be inspected on a periodic basis, Soiled protective clothing, whether of the reusable or disposable type, should be placed in sealed, imerneeb1e bees or other closed, impermeable containers which must bear the required c.ucioA l.bcl iJJCraiSIO.IOOH.XMdli)); [WC6I.JJ(J)]. Utt OF ..(cr-tolubl, liun.ry 6j,s. if available, would minmite exposure potential In handling operations. It Is raconmendeu that protective clothing be Issued and collected on a daily basis. Soiled disposable type protective clothing shoulo be considered to be contaminated with asbestos and, therefore, disposal must be In accord with {PA regulations (kOCFAbl.22). Reusable clothing should be vacuum-cleaned prior to placing in containers for laundering; they should not be shaken, brushed, or air blown, 5.5. HOUSmsunG All external surfaces In any place of employment must be maintained free of accumulations of asbestos fiber. If with their dispersion, there would be an excessive concentric Ion [29CFAI910, lOOk(ht), This can be accomplished with the use of a controlled central vacuum system or dltposable*baq vacuum cleaner designed so that there Is no discharge of asbestos iron the filter. 6. HONimtHG Prescribed monitoring involves both industrial hygiene sampling and nrndica! surveillance programs. 6.1 HTGJEH nquiTQAinG Both personal and envlronaienta1 monitoring are prescribed. The tempting frequency ana patterns must be sue* as to represent with reasonable accuracy th worxer's exposure levels, for workers whose exposure (o asbestos may reasonaely be forsaen to exceed the Hulling TWA and celling concentrations, the Intervals hist not exceed six months (23CFAI910,1001 !F)1. Varners or their representative* must be given opportunity to observe any required non'taring, as well as access to results of same. DOW CONFIDENTIAL ( 6.1.1 Perioral HtfnitqftOO derates tor oetereunat ion of both TVA worker'* Breathing to**; See ffgdf* 2, celling asbestos concantrat loos must be u*n within- the ST074I748 FliWt 2. ASICSTCS 5WU* 6.1.2 6.1.3 6.1.6 6.2 6.2.K 6.2.2 6.2.3 6.2.6 nyfronrantal Honltorlnq Semples nuit be collected fro* areas of a work environment that art representative of airborne Concentrations of aibestos which ray reach worker* breathing /ones. Records nvi rpnmental and personal monitoring records retulred by OJHA regulations vut be maintained for a mi hi anon of 20 year* and, upon request, soft be made available to OSHA and M10SH author!tie* and their author)ted representatives (2JCfR19IO. I0&K1}). Employe Access end Notification Present ana pest employee* are guaranteed right of access to hygiene monitoring record* oartelnlng to their Individual asbestos exposure, employees exposed to asbestos In excel* of Halting TUA and calling concentrations Must be notified within five days of the finding and of corrective action being taken (29CPR1J10.1001(1)(2) and (3)]. It It recommended that records be kept of any such notlflcation*. MCpicAt sumaiAwci 6sHA regulations |29CPRt9IO.1001(J)(3)J provide for radical surveillance of worker* Mengeged In any occupation* exposed to alrbore* concentrations of asbestos fiber*." Required radical exa* nations mult be provided, or rade available, by the employer.* Pre-Hacarant A co*pr*nefTiVve radical examination It required within 30 days of a worker'* assignranf to an occupation involving exposure to airborne asbestos. As a minimum the examination snail Include: Chest roentgenogram (Posterior-Anterior, 16" x 17") History, to allclt symptoratology of respiratory dlteasa Pulmonary function tesu, including forced vital capacity (FVt) and forced expiratory volume at 1 second 4ftV)gg) In addition, It is recommended that a complete smoking history should be recorded. Including average dally consumption. The examining physician shall rake a determination of tne anility of the worker to effectively wear a respirator, Period!c Reputation* require that employer's provide or rake available comprehensive radical examination at least annually and Including, as a minimi**, those element! listed in (6.2.I. Termination Regulation* require that employers provide or make available a comprehensive radical examination within P aays before or after termination of employment Including, as a minimum, those element* I fated In {6.2.1. Record Retention Lmpreyers ere ooIIgated to maintain all medical records for a minimum of 20 year*. An eommistrative interpretation Is provided In 0SHA Program Directive f309-l6 (10/11/73); the (arm "exposed to airborne Concentration* of asbestos fiber" 1* interpreted to newt ''exposed to e minim** of 0.1 asbestos fibers larger than 5 microratqrs per cubic centimeter of air." Also, Chet radical examination* art required for any 7 to B-hour time-weighted average concentration of 0.1 f/ce, or for a greater concentration. DOW CONFIDENTIAL ST074I7U9 6.2.5 Cmolovea Access Concern* of records of required medical examinations must be n4i available for inspection copy I [2*CF 1*10.1001 (J)J to: The Assistant Secretary of Labor for OSIA and/or to hit authorized physician consultants? The Director of N10SM end/or to hie authorized physician and medical consultants; Upon request of an employee or former employee, hie physician. 7.1 7.'.I 7,1.2 7.1.) 7-1.% ? CMPtOyCt TMINIHG The effectiveness of a program for the safe handling of aibeitot depends in large "mature upon the manner it Is implemented by workers, Management has a respondibll Ity not only to provide tefe workolace but. through detailed work practices and adequate protective equipment, the eoens by which employees can protect themselves in the event of excessive airborne asoastes amissions. Inherent and fundamental CO the sucess of Che program Is tha need to provfde regular Horkar training in tha handling of routine job assignments. CftM-TlttC P*DCt9WS It is recommended that workers having a potential for exposure to airborne asbestos have available to them, and follow, written operating Instructions specific to their Job assignment. Hanagmeenc should determine that these Instructions are bming applied. Preparatory to bting assigned to a job having a potential for exposure to airborne asbestos, workers should be apprised of all hazards, and proper conditions and precautions concerning esoescos use or exposure, including personal hygiene and housekeeping practices. 00c 0S*u form 20 "Materiel Safety data lhaat," pr the equivalent, should be kept an rile and readily accessible to workers; See CxhibftNo.I. Review of the contents of KS0S*s it a valuable tool for worker orientation and periodic training exercises. Other valuable sources are indicated in Pespirotors Cmp<oyers are obligated to have written standard operating procedures governing tha selection and use of respirators |2*CP*I910. IJb(b) ()) and (e)(5)]. The employer respirator training program must include, as e minimum: The nature of respiratory haaards In the workpiece and how to select respiratory Use of respirators and proper fitting Capabl11 ties and limitations of respirator* Cleaning, disinfection. Inspection, maintenance end storage of respirators Oates of training and subject matter presented should be retained by employers. Proudtve Clothing iperacmg Procedure* ihould Incorporate Information on the smlectton, use, care and disposal of protective clothing. personal Hygiene High standards of personal hygiene should be established end maintained. Workers should be prevented from eating in areas where asbestos Is stored, processed, used or disposed. They should be Instructed to wash hands and fact before eating, Smoking employees should be made aware that It has been established that cigarette smoking greatly Increases the risk of developing lung cancer In persons exposed to asbestos. On the other hand, asbestos workers who do not smoke cigarettes, and who never have smoked regularly, have shown no greater frequency of lung cancer then the average person who does not smoke. In any event, smoking should be permitted In assigned areas only. 'YfVAiuif,(. Mr LjJ_ i. nnnncis 1.1 B.I.; 8.1.2 0.1.3 8.1.6 8.1.5 8.2 8.2.1 8.2.2 8.2.3 8.) 8.3.1 8.5.2 8.6 8.6.1 8.6.2 PHEW (U.S.) "Certi fled Raiplrator Equipment" (12/15/7$) and "Cumulative Supplement" (6/77) snd/or later Issues. Aval I able fro* CHEW, NIOSH, Hoi^KKOm, . 26505 'Criteria for a Aecasestftded Standard! Occupational Exposure to Asbestos," Report H$M72-102$7 (1972). Available from U.S. Government Printing Office, Washington, D.C. 20602 'VfOSM Manual of Sampling Oats Sheets - 1977 Edition", Available from BHEV, Canter for Disease Control, Cincinnati, OH 65226 "NIMH Atvised Pecanmended Asbestos Standard," CHEW Publication 77**69 {De&ewer 1976). Avi1aola from U.S. Government Printing Office, Washington, O.C. 20602 "Membrane Filter Method for Evaluating Airborne Asbestos fibers," NIOSH Puollcatlo* TR86 (1976). Available from the U.S. Government Printing Office, Washington, O.C. 20602 EPA (U.S.) "Electron Microscope Measurement of Airborne Asbestos Concentrations, A Provisional Methodology Manual," EPA Report 600/2-77*178 (June, 1978)* Available from CPA Office of Research and Development, Research Triangle Parfc, NC 277M. 'Iveluating and Optimizing Electron Mlcroscooe Methods for Characterizing Airborne Asbestos," CPA .import 600/2-78-0)8 (Juno, 1978}," Available from EPA Office of Research and Development, Research Triangle Park. NC 17711. "Preparation of Watar Samples for Asbestos Fiber Counting by Electron Microscopy," EPA Report 600/6-78-011 (January, 1978). Available from EPA Office of Research and Development, Athens, GA 30601. MISCELLANEOUS 'Measurement of Asbestos Exposure." J. Occupational Medicine 10:1, 21 (January 1968). "Asbestos: An Information Resource," SHEW Publication (NIK) 78-1681 (May 1978). Available from office of Cancer Coueteilcaclons, National Cancer Institute, Sethtsda, a0 20016 OTHER INFORMATION SOURCE) Asbestos Information Association, 176$ Jeffarton Davis Highway, Crystal Square 6, Arlington, VA 22202 Johns Menvtlle Corporation, Environmental Affairs Department, P 0 8ox 5108, Denver, CO 80217 J.l 9.1.1 9.1.2 9.2 9.2.1 9.2.2 9.2.3 9. APPENDICES ANALYTICAL METHODS CPA Method for Asbestos In Water NIOSH Sampling Data Sheet 72.02 (Sept. 6, 1975) REGULATIONS DOT ; 69 CFR Parti 172 - 177 CPA : 60 CFR Part 61 D0L-0SMA 1 29 CFR 1910.1001 ST074I750 DQW CGNnuui'iiiAL