Document MGpoyjRvL6xXN1p79pMXBRLaM

[/ ' SHELL OIL COMPANY WOOD RIVER MANUFACTURING COMPLEX Interoffice Memo TO: J. A. DEETER FROM: W. N. CUNNINGHAM y SUBJECT: ASBESTOS REQUIREMENTS-INCIDENTAL HANDLING DATE: MAY 6, 198o PLAINTIFF'S EXHIBIT SH-2876 \ JIM, In response to your question reqardinq the requirements for training and medical surveillance for employees involved in incidental removal of asbestos containing insulation, let me offer the following guidance. MEDICAL SURVEILLANCE REQUIREMENTS. The current guidelines require medical surveillance for employees exposed to 0.1 f/cc 8hr TWA or more for one day per quarter. (For purpose of medical surveillance no credit is taken for respirators). As you can see the key is to keep exposure below the 0.1 level. Our experience to date would indicate that incidental asbestos removal (incidental is defined as roughly 15 min) with proper wet down and cleanup procedures would create exposures below 0.1 f/cc 8hr TWA. It is therefore not likely that medical surveilance would be necessary. We would suggest monitoring several typical tasks so verify our judgement. TRAINING REQUIREMENTS If exposure is below permissible levels, no training would be required bv OSHA. However, to maintain the low levels, crafts need to understand and use proper procedures. Training should focus on the procedures. of health effects from overexposure would also be help with motivation to follow the procedures. We have two video aids. One is the Shell Explanation prudent to audisrsn ABS-000315 LAM 019504 A/T/Mcx-s.rw which ru/is -for about 15 minutes and the other is a videotape which goes about 45 minutes. Both cover health e-f-fects and good work practices. One o-F these coupled with a review o-f the Insulator kit and a discussion o+ the asbestos P.H. which describes incidental removal and proper procedures would seem appropriate training. Annual training would not be mandated since exposure levels are law, so the -frequency would be a matter of good judgement to assure ourselves the proper practices were being carried out. WMC cc:TLR HGR LAM 019505 ABS-000316