Document N2aEV17p0vMNZmO3m2nvM5Yy

I U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION 7/ 1?^-^ Hi jn the latter of :. OSHA No. ( s 3: -/ 7 / R^S->2- '' . INFORMAL SETTLEMENT AGREEMENT ^The undersigned Employer and the undersigned Occupational Safety and Health Administration jfcOSHA), in settlement of . the above citation(s) and penalties ^ which-were issued on/&3, hereby agree as follows: 1. The Employer agrees to correct -the violations as cited, in the above citations-or as amended below. - :r2ir The Employer agrees to pay the "proposed penalties, if any, as issued' with the above citation^ s), or, if amended by this agreement, as amended below. . .. * ~3. The Employer and OSHA agree that the following citations and penalties (if any) are not being amended by this agreement: ' 4. OSHA agrees that the following citations and penalties are being amended as shov/n (see attachments): , C 002181 CBV 3103787 5. The Employer, by signing this informal settlement agreement, ' hereby waives its rights to 'contest the above citation(s) and penalties, as amended in. paragraph 4 of this agreement. 6. The Employer agrees to immediately post a copy of this Settlement Agreement in a prominent place at or near the location of the violations)r . . referred to in paragraphs 3 and 4 above. This Settlement. Agreement must . remain posted until the violation? cited have b,eeh corrected, or for 3 working days (excluding weekends and Federal Holidays), whichever is longer r.v', j=\ -V' ciinit ........ -- ' N0tlCIi>T*0 fftPLOYEES The law gives you or your representative the opportunity to object to any ` abatement date set for a violation If you believe the date to be uni'easoriable. Amy contest to the abatement dates of the citations' amended in .paragraph 4 of * this Settlement Agreement must be mailed to the U.S. Department of Labor-OSftA, 2320 LaBranch, Room- 2118', Houston, Texas 77004* within 15 working days (exclud ing weekends and Federal Holidays) of the receipt by the Employer of tills Settlement Agreement. You or your representative also have-the right to object to any of the abatement dates set for violations referred to in paragraph 3 * provided that the objection is mailed to the office shown above within the'15 working day period established by the original citation. "Mf*! : 'r ` ... C 002182 CBY ^3103788 U,S. Dspartmsnt of Labor Houston Area Office 2320 LaBranch, Room 1103 Houston, Texas .77004 August 22, 1983 Reply to th9 Attention of: Monsanto Fibers and Intermediates Company and its successors -------- P.O. Box 1311 r ~ J "" * Texas City, Texas 77590 ATTN: Mr. Gene L. Tromblee, Plant Manager 1 '' !':- RE:. H6013-I67 -- Prie evp- n. - ' " ' :!V Dear Mr.'Tromblee: '' Enclosed you toll find citations for violations of the Occupational Safety and Health Act of 1970 (the Act) which1 may have accompanying proposed penalties. Also enclosed is a booklet which explains your rights and responsibilities under"the Act. As indicated on page 2 of the booklet, you may request an informal conference with me during the 15-working-day notice of contest period. During the informal conference you may present any evidence or views which you believe would support an adjustment to the citation or the penalty. If you decide to request an informal conference, please complete the form at the bottem of this letter-and post it next to the citations immediately after determining the timei date, and place of the informal conference. If you have any questions about the enclosed citations and penalties, I would welcome further discussion art the informal conference; and, where warranted, I am authorized to enter into an informal settlement agreement with you which amicably resolves this matter without litigation or contest. If you have any questions regarding the informal conference, please contact me. (Cn n < ov*,a1 v GERALD A. BATY Area Director An informal conference-has1'"been scheduled with 03HA do discuss the citations issued on 8-/Z2- 83 .~The conference will be held at the OSHA Office located at g?2Q 4? ' 6ft ' " 9-/ - ? 3 at /0-3p . (Address) (Date) (Time) H I J CBY 3103789 C 002183 JJM1UM1LIII1J days (excluding weekends and federal nondays) whichever is longer. This citation describes violations of the Occupational Safety and Health Act of 1970. The penalty(ies) listed below are based on these violations. You must correct the violations referred to in this citation by the dates listed below and pay the penalties proposed, unless within 15 working days (excluding weekends and Federal holidays) from your receipt of this citation and penalty you mail a notice of contest to the U.S. Department of Labor Area Office at the address shown above. (See the enclosed booklet which outlines your responsibilities and courses of action and should be read in conjunction with this form.) ITEM NUMBER STANDARD, REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION DATE BY WHICH VIOLATION MUST BECORRECTED PENALTY The issuance of this citation does not constitute a finding that a violation of the Act has occurred unless there is a failure to contest as provided for in the Act or, if contested, unless the citation is affirmed by the Review Commission. --------- The violations described in this citation are alleged to have occurred on or about-the day the inspection was made unless otherwise indicated within the description given below. 1 29 CFR1910.1001 (f) (2 )/ii-) -------The-airborne- asbestos monitoring-----------schedule was not of sufficient frequency and pattern as to represent with -reasonable accuracy-the levels -of-asployee~exposure-to eirbome asbestos fibers: Immediately Upon Receipt $0 (a) Monsanto Fibers and Intermediates Company in Texas City, 1 Texas, does not conduct personal monitoring-for-airborne --------- asbestos fibers at intervals of 6 months of less for employees ------------- whose-exposure-to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph b of 29 CFR -----------1910.1001.'...-- ------r-- ----------------------------------- ---------- 2' -- ------------------- -------------------------------- ----------------- ------------------------------------------- ------------------------------------------------ 29 CFR 1910.100l(j)(2): The employer did not provide or make available, to each employee, within 30 days following his first em ployment- in. an occupation exposed to airborne levels of asbestos 'fibers, a comprehensive medical examination: ------- -- -------------- 9/26/83 I 1 $0 --`"--/a) On June 30, 1983, an employee working on Unit 16 E2 was exposed to 0.28 fibers per cubic centimeter of air. This - ' exposure occurred during an asbestos insulation removal. The sample taken was a 15-minute ceiling sample. ___c 0ti>ri85 'AREA DIRECTOR GERALD A. BATY CBY 3103791 $0 NOTICE TO EMPLOYEES -- The law gives an employee or his representative the opportunity to object to any abatement date set for a violation if he believes the date to be unreasonable. EMPLOYER DISCRIMINATION UNLAWFUL - The law pro TOTAL PENAL! FOR THIS hibits discrimination by an employer against an employee for CITATION filing a complaint or for exercising any rights under this Act. MakecheckorMot The contest must be mailed to the U.S; Department of Labor - An employee who -beHeves that hehasbeen discriminated Order Payable T Area Office at the address shown above within 15 working days (excluding weekends and-Federal-holidays) of the receipt by the employer of this citation and penalty. against may file a complaint no later than 30 days after the discrimination with the U.S. Department of Labor Area Office at the address shown above. "DOLOSHA" Indicate OSHAh on Remittance EMPLOYER RESPONSIBILITIES AND COURSES OF ACTION -- The enclosed booklet outlines employer responsibilities and courses of action and should be read in conjunction with this notification. CITATION AND NOTIFICATION OF PENALTY OSHA-2 REV. 5/76 _ days (excluding weekends and Federal hoii- -- daysl whichever is longer. This citation describes violations of the Occupational Safety and Health Act of 1970.^ The penalty(iei) listed below ere based on these violations. You must correct the violations referred to in this citation by the dates listed below and pay the penalties proposed, unless within 15 working days (excluding weekends and Federal holidays) from your receipt of this citation and penalty you mail a notice of contest to the U.S. Department of Labor Area Office at the address shown above. (See the enclosed booklet which outlines your responsibilities and courses of action and should be read in conjunction with this form.) 'item NUMBER STANDARD, REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION * DATE BY WHICH VIOLATION MUST BECORRECTED 10 PENALTY The issuance of this citation does not constitute a finding that a violation of the Act has occurred vnless there is a failure to contest as provided for in the Act or, if contested, mless the citation is affirmed by the Review Comiaaiori, The violations described in this citation are alleged to have occurred on or about the day the inspection was nade unless otherwise indicated within the description given below* l r: "r 29 CFR 1910.1001(f)(2)(H): The airborne asbestos monitoring schedule was not of suffLcLmt frequency and pattern as to represent with reasonable accuracy the levels of employee exposure to airborne asbestos fibers: ., :f - Imediately Upon Receipt $0 (a) Monsanto Fibers and Intermediates Company in Texas City, Texas, does not conduct personal monitoring for airborne asbestos fibers at intervals of 6 months of less for employees whose exposure to asbestos may reasonably be foreseen to ... . .exceed the limits prescribed by paragraph b of 29 CFR 1910 1001 2 29 CFR 1910100l(j)(2): The employer did not provide or make available, to each employee, within 30 days following his first em ployment in an. occupation exposed to airborne levels of asbestos fibers, a comprehensive medical examination: 9/26/83 $0 (a) On Jure 30, 2983, an employee working on Unit 16 E2 was exposed to 0.28 fibers per cubic centimeter of air. This exposure occurred during an asbestos insulation removal. The sample taken was a 15-minute ceiling sample. i) 002186 s&&Acfcr14 AREA DIRECTOR GERALD A. BATT cby 3o82186 NOTICE TO EMPLOYEES -- The law gives an employee or his EMPLOYER DISCRIMINATION UNLAWFUL - The law pro representative the opportunity to object to any abatement date hibits discrimination by an employer against an employee for set for a violation if he believes the date to be unreasonable. filing a complaint or for exercising any rights under this Act. The contest must be mailed to the U.S. Department of Labor" An employee who believes that he has been discriminated Area Office at the address shown above within 15 working days against may file a complaint no later than 30 days after the (excluding weekends and Federal holidays) of the receipt by discrimination with the U.S. Department of Labor Area Office the employer of this citation and penalty. at the address shown above. EMPLOYER RESPONSIBILITIES AND COURSES OF ACTION -- The enclosed booklet outlines employer responsibilities and courses of action and should be read in conjunction with this notification. $0 TOTAL PENAL! FOR THIS CITATION 1ik.ch.ckorMor Order Payable Ti "DOLOSHA" Indicate OSHAN n Remittance CITATION AND NOTIFICATION OF PENALTY OSHA-2 REV. 5/76 The undersigned (check one) For Official Use Only Area Date Received 3280 Region 6/27/83 Received By ' 6 LCB Time 11:45 AM Formal JO Non Formal Dt Employee Representative of Employees O Other (specify) _ believes that a violation at the following place of employment of an occupational safety or health standard exists which is a job safety or health hazard. Employer's Name .. TM MONSANTO CHEMICAL -______________ ______________ _ Employer's Address (Street) . . (City) 201 Bay Street _________ ~ ; Texas rityI__ (State) (Zip Code) Telephone Texas 77590 QA5 4431 ~ . ____________ 1. Kind of business Chemical plant___________ - - - - _____________________ ________ 2. Specify the particular building or worksite where the alleged violation is located, including address. Dept. 15 & 16; Dept, 19; Deot. 48-56 and Dept.. Pnwsw a?______________________________ " 3. Specify the name and phone number of employer's agent(s) in charge. Gene Tromblee. Plant Manager____________ 4. Describe briefly the hazard which exists there including the approximate number of employees exposed to or threatened by such hazard. PlEgfjtters have been removing asbestos insulation without wearing the prnppr .pprcnnal protective equipment. Company has taken samples to ript.prminp whprp thp athpcfnc fc located, but some insulation has been mistakenly idpntifiprf ac nnn.achoctoc ________ OSHA-7 IRev. October 1977) C 002187 CBY 3103793 CONTINUED ON REVERSE SIDE u mn wi MinBTimw ailiilWMI 31:8304 C C REFERENCE FILE Tabic Z-2 Material .. S-hour time weighted average . ., Acceptable ceiling concentration Acceptable maximum peak above the arreptabin celling concentre* (ton (or an 8-hour shift. -- -- -- Concentration Maximum duration $enrene <237 4 1969).......... ............................ 10 p.p.m...........25 p.p.m.. beryllium and beryllium compounds 2*g./Al>........ .... 6tg./M*... (Z37.3M97A1 Cadmium du* rZ3*!W97n)............................0.2ntg./M'............ name *M*. Cadmium futne <7,37.5-1970)........................ <M O.Smc M' . Carbon disulfide (37.3-1958)............. .. 20p.p.m........ 30p.p.m.. Carbontetraehlorldo(Z37.17-I957)............. 10p.p.m........ 26p.p.m.. Chromic acid and chromates (Z37.7-1971)..................................1 mg'lOM'.. 60 p.p.m. 26*./M. 10 minutes. 30 minutes. 100 p.p.m:...... 10 minutes. 200 p.p.m....... 6 minutes in any 4 hours. Ethylene dibromlde(Z37.3t-!970)................ 20 p.p.m..............*0 p.p.m................ 80 p.p.m.. Ethylene dlchlorlde (Z37.21-1969)................. 60p.p.m................ 100p.p.m............ 200 p.p.m, Fluoride as dust (Z37.2*-I9fl9)....................... 18 mg./M>............................................... 6 minutes 6 minutes In any 3 hours. Formaldehyde (Z37.UHW7)........ . 3 p.p-ui......... 6 p.p.m......... 10 p.p.m........ 30 minutes. Hydrogen fluoride (Z37.28-I959). ...........3 ppm. Hydrogen sulfide (Z37.2-1W).....................................................20 p.p.m.................... 60 p.p.m......... 10 minutes onca only if no other measur able etposure Lead and its inorganic compounds 0.2 mg/m* occurs. (Z 37.11-1969) Mercury (Z37.S-1971)............................ 1 mf./lOM . Methyl t ftlundn 737 18-1969> .......... 100 p.p.m........ 200 p.p.m............... 300p.p.m........... 6 minutes in any 3 hours. Methylene Chloride (Z17.23-1969)........ 600 p.p.m........ 1,000 p.p.m............ 2,000 p.p.m........ 6mlnutos In Orirano (alkyl) mercury (Z37.39-19O0) Styrene (237.14-1909)............................ 0.01 mjc/M any 2 hours. 0.(H mjr./M ....................... ................. 100 p.p.m........20U p.p.m................. 000p.p.m........... 6 minutes in any 3 hours. TetrechloroetHylene (Z37.23-IW7).... .100ppm.........200ppm............... 100 ppm............. 8 minutes In Toluene (Z37.12-IM7)........................... any 3 hours. 200p.p.m..... IQQpp.m..............6h0p v.m............ 10 minutes. Trichloroethylene (Z37.19-1907).......... .tOOppm .......2i)0 ppm............. 300 p.p.m.......... 6 minutes In nnv2bours. (Table Z-2, footnote I deleted by 46 FR 32021. June 19, 1981) Table Z-.)--Mineral Duets Substance Silica: Crystalline: Quartz (respirable)...... Quartz (total dust)........ Mpprf nsio.+ CrlstobaUti'T Use the alun calculate from the count nr mass formulae for quart*. Tndymlte: Vse *5 the value calculated (rum the for mulae for quartz. Amorphous. Including natural dletomeceous earth............. . 20 Aerodynamic diameter _ (unit density sphere) Percent pacing selector I0mg/M* $!Oi-t-2 SDnwM* %S*Oi+2 2 90 2.6 3.6 75 60 6.0 25 10 0 The measurements under this note refer to the use of an ARC Instrument. Tf the respirable fraction of coal dut Is determined with a M RE the figure corresponding to that of 2 I Mg,M5 In the tnhle for coal dust is 4.5 Mg/M*. 1910.1001 Asbestos. (a) Definitions. For the purpose of this section, (1> "Asbestos" includes OOmtr/M' chrysotile. amosite, crocidolite, tremo- %SIOi lite, anthophyllite, and actinolite. llleates (less than 1% crys talline siUca): Mica.................................... .. FnPtnne........ 20 Tale<iion-ftsl>c*tns form) . 20* Talc (lihrou*). Use asbestos limit .. .... Tromolite (see talc, fibrous) Portland cement........... 60 Oraphtte (natural) 15 Coal dust (respirable fraction . less than 6% SlOt),............ ...................... For more than 5% SlO................ ... ........ . Inert nr Vulnncc Pint: lletptrable Irartlon............ Total dust.............................. 18 60 (2) "Asbestos fibers" means asbestos fibers longer than 5 micrometers. 20 (b) Permissible exposure to airborne concentrations of asbestos fibers--(1) Standard effective July 7. 7972. The 8-hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed 2.tmg/M* shall not exceed five fibers, longer than or lOmg/M* 5 micrometers, per cubic centimeter of air, as determined by the method pre scribed in paragraph (e> of this section. (2) Standard effective July 1. 1976. ISmg .NP The 8-hour time-weighted average air borne concentrations of asbestos fibers Notrr rtnverlnn f.vtor? mP(WX35 3 million jnriitlo* |ier cubic meter to which any employee may be exposed shall not exceed two fibers, longer than ^tiurrirlei |er e.e. * Million* of |nareli*l** per ruble font of air. l*urd on Impinge? sample* roumed by lipht-fi* Id tei-limrs. r The |*'f*rnta*e of *Tysinlhne silica in tt*e formula U Ut KniQuni determined (rm aiMmrue sample*, ej- cept lu thnc tn<t.in c< ut which other n)<'ihod*iiar been 5 micrometers, per cubic centimeter of air. as determined by the method pre scribed in paragraph <e> of this section. (3) Ceiling concentration. No em shown to be Hppllt aide ployee shall be exposed at any time to * doth corn-miration Attd (NTceut quarts for the appli cation of this limit are to !* tbucrmutwl from ih" (nuifon piling a *lre-seliTttr with the following charselrrt'tilr*: airborne concentrations of asbestos fibers in excess of 10 fibers, longer than * Containing < 1% quartz; if > quartz, uo quartz, 5 micrometers, per cubic centimeter of limit. air. as determined by the method pre scribed in paragraph (e> of this section. Occupational Safety & Health Reporter (c> Methods of compliance--(1) En gineering methods, (i) Engineering con trols. Engineering controls, ?uch as, but not limited to. isolation, enclosure, ex haust ventilation, and dust collection, shall be used to meet the exposure limits prescribed in paragraph (b) of this section. (it) Local exhaust ventilation, (a) Local exhaust ventilation and dust col lection systems shall be designed, con structed. installed, and maintained in accordance with the American National Standard Fundamentals Governing the Design and Operation of Local Exhaust Systems, ANSI Z9.2-1971, which is in corporated by reference herein. <b> See S 1SH0.6 concerning the avail ability of ANSI Z9.2-1971, and the maintenance of a historic file in connec tion therewith. The address of the Amer ican National Standards Institute is given in S 1910.100. (Ill) Particular tools. AH hand-op erated and power-operated tools which may produce or release asbestos fibers in excess of the exposure limits pre scribed in paragraph fb) of this section, such as. but not limited to, saws, scorers, abrasive wheels, and drills, shall be pro vided with local exhaust ventilation sys tems in accordance with subdivision (ii) of this subparagraph. (2) IForfc practices--0> Wet methods. Insofar as practicable, asbestos shall be handled, mixed, applied, removed, cut. scored,- or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the ex posure limits prescribed in paragraph tb> of this section, unless the usefulness of the product would be diminished thereby. (ii) Particular products and opera tions. No asbestos cement, mortar, coat ing, grout, piaster, or similar material containing asbestos shall be removed from bags, cartons, or other containers in which they are shipped, without being either wetted, or enclosed, or ventilated so as to prevent effectively the release of airborne asbestos fibers in excess of the limits prescribed in paragraph (b) of this section. (Ill) Spraying, demolition, or removal. Employees engaged in the spraying of asbestos, the removal, or demolition of pipes, structures, or equipment covered or insulated witli asbestos, and in the removal or demolition of asbestos in sulation or coverings shall be provided with respiratory equipment in accord ance with paragraph <d)<2)(iii) of this section and with special clothing in ac cordance with paragraph (d)(3) of this section. (d> Personal protective equipment-- (1) Compliance with the exposure limits prescribed by paragraph <b> of this sec tion may not be achieved by the use of respirators or shift rotation of em ployees, except: (ii During the time period necessary to install tire engineering controls and to Institute the work practices required by paragraph <c> of this section; ill) In work situations in which the methods prescribed In paragraph (c) of (Sec. 1910.1001(d)(1)(ii)l 64 CBY 3103794 C 002188 TOXIC SUBSTANCES r r S-1S5 31:8305 this section are either technically not feasible or feasible to an extent insuffi cient to reduce the airborne concentra the safety or health of the employee or other employees will be impaired by hisuse of a respirator. Such employee shall (ii) Sampling frequency and patterns. After the initial determinations required by subparagraph (1) of this paragraph, tions of asbestos fibers below the limits prescribed by paragraph (b) of. this be rotated to another Job -or given the opportunity to transfer to a different po samples shall be of such frequency and pattern as to represent with reasonable section: or (ill) In emergencies.(iv) Wliere both respirators and per sition whose duties he is able to perform with the same employer, in the same geo graphical area and with the same senior accuracy the levels of exposure of em ployees. In no case shall the sampling be done at intervals greater than 6 months sonnel rotation are allowed by subdivi ity, status, and rate of pay he had just for employees whose exposure to asbestos sions (i), (ill, or (ill) of this subpara graph, and both are practicable, person nel rotation shall be preferred and used. (2) Where a respirator is permitted by subparagraph (1) of this paragraph, it shall be selected from among those ap proved by the Bureau of Mines, Depart ment of the Interior,'or the National In stitute for Occupational Safety and Health, Department - of Health, Educa tion, and Welfare, under the provisions of 30 CFR Part 11 (37 F.R. 6244, Mar. 25, 19721, and shall be used in accordance with subdivisions (1), (if); (ill), and (iv) of this subparagraph. (1) Air purifying respirators. A reusa ble or single use air purifying respirator, -or a respirator described in subdivision (ii) or (iii) of this subparagraph, shall be used to reduce the concentrations of airborne asbestos libers in the respirator below the exposure limits prescribed in paragraph (b>- ol this section, when the ceiling or the 8-hour time-weighted aver age airborne concentrations of asbestos fibers are reasonably expected to exceed no more-than 10 times those limits- (ii) Powered air purifying respirators. A full facepiece powered air purifying respirator, or a powered air purifying respirator, or a respirator described in subdivision (ill) of this subparagraph, shall be used to reduce the- concentra-. tions of airborne asbestos fibers-in the respirator below the exposure-limits pre scribed in paragraph (b) of this section, when the ceiling or the 8-hour timeweighted average concentrations-'of prior to such twister, if such a different position is available. (3) Special clothing:. The-employer shall provide, and require-the use of, spe cial clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot coverings for any em ployee exposed to airborne concentra tions of asbestos fibers, which exceed the ceiling level prescribed in paragraph (b) of this section. (4) Change rooms: (i) At any fixed place of employment exposed to airborne concentrations of asbestos fibers in ex cess of the exposure limits prescribed in paragraph (b)'of this section, the em ployer shall provide change .rooms for employees working regularly at the place. (ii) Clothes lockers: 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 plothes. (iii) Laundering: (a) Laundering of asbestos contaminated clothing shall be done so as to prevent the release of air borne asbestos fibers in excess of the ex-. posure limits prescribed in paragraph (b) of this section. (b> Any employer who gives.asbestoscontaminated clothing to another person' for laundering shall inform sifch person of the requirement in (a) of this.subdi vision to effectively prevent the release of airborne asbestos, fibers in excess of the .exposure limits prescribed in para graph (b) of this section-, may reasonably be foreseen to exceed the limits prescribed by paragraph (b) of this section. (3) Environmental monitoring--(i) samples shall be collected from areas of a work environment which are represent ative of the airborne concentrations of asbestos fibers which may reach the breathing zone of employees. Samples 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 determination of the 8hour time-weighted, average airborne concentrations and of the ceiling con centrations of asbestos fibers. (ii) Sampling frequency and patterns. After the initial determinations required by subparagraph (1) of this paragraph, samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of the employees. In no case shall sampling be at intervals greater than 6 months for employees whose exposures to asbestos may reasonably be foreseen to exceed the exposure limits prescribed in para graph (b) of this section. (4) Employee observation of monitor ing. Attected employees, or their rep resentatives, shall be given a reasonable opportunity to observe any monitoring required by this paragraph and shall have access to the records thereof. (g) Caution signs and labels. (1) Cau tion signs.' (i) Posting. Caution signs shall .be provided and displayed at each asbestos fibers are . reasonably expected to exceed 10 times, but not-100.times, 'those limits. `(iii) Type "C" supplied-air respirators, continuous ~flow or pressure-demand class. A type "C" continuous flow or pres-sure-demand, supplied-air respirator shall be used to reduce the concentra tions of airborne asbestos fibers in the respirator below the exposure limits pre scribed in paragraph (b) of this section,. when the celling or the 8-hour timeweighted average airborne concentra -(c) Contaminated clothing shall be transported-in sealed impermeable bags, or other closed, impermeable containers, and labeled in accordance with para graph (g) of this section. (e) Method of measurement. All de terminations of airborne concentrations of asbestos fibers shall be made by the membrane filter method at 400-450 X (magnification) (4 millimeter objective) with phase contrast illumination. (f) Monitoring--(1) Initial determi nations. Within 6 months of the publi location-where airborne concentrations of asbestos fibers may be in excess of the exposure limits prescribed in paragraph (b) of this section. Signs shall be posted . at such a distance from such a location so that an employee may read the signs and take necessary protective steps be fore entering the area marked by the signs. Signs shall be posted at all ap proaches to areas containing excessive concentrations of . airborne asbestos fibers. (ii). Sign specifications. The warning tions of asbestos fibers are reasonably cation of this section, every employer signs required by subdivision (1) of this expected to exceed 100 times those limits. shall cause every place of employment subparagraph shall conform to the re (iv) Establishment of a respirator pro where asbestos fibers are released to be quirements of 20" x 14" vertical format gram. (a) The employer shall establish monitored in such a way as to determine signs specified in 9 1910.145(d) (4), and a respirator program in accordance with whether every employee's exposure to to this subdivision. The signs shall dis-. the requirements of the American Na asbestos fibers is below the limits pre play the following legend in the lower tional Standards Practices for Respira scribed in paragraph (b) of this sec panel, with letter sizes and styles of a tory Protection. ANSI Z88.2-1969, which tion. If the limits are exceeded, the em visibility at least equal to that specified is incorporated by reference herein. ployer shall immediately undertake a in this subdivision. b. See 9 1910.6 concerning the avail ability of ANSI Z88.2-1969 and the'maln- tenance of an historic file in connection therewith. The address of the American compliance program in accordance with paragraph (c) of this section. (2) Personal monitoring--(1) Sam ples shall be collected from within the tegeni ' Notation Asbestos__________ _____ j'l" Sans 'Serif, Gothic or Block. National Standards Institute is given in 91910.100. (c) No employee shall be assigned to tasks requiring the use of respirators if, based upon his most recent examination, an examining physician determines that breathing zone ofT*he employees, on membrane filters of 0.8 micrometer po rosity mounted in an open-face filter holder. Samples shall be taken for the determination of the 8-hour time- weighted average airborne concentra DuSt Hazard. Avoid Breathing Dust__ Wear. Assigned Protective Equipment. Do Not Remain in Area %" Sans Serif, Gothic or Block. >4",Gothic. Gothic. ^"'Gothic. the employee will be unable to.iunctlon tions and of the ceiling concentrations of Unless Your Work Re- normally wearing a respirator, or that asbestos fibers. qmresit. {s#c i910.1001(s)(1!(li)l a-17-83 Published by THE BUREAU OE NATIONAL AP FAIRS, INC., WASHINGTON, D-C. 20037 65 CBY 3103795 681200 O w 31:8306 C C reference file Ltgind Notation fied in writing of the exposure as soon as tional exposure to asbestos fibers. Breathing Asbestos Dust 14 point Gothic. practicable but not later than 5 days of the (Section I910.1001(j)(6)(ii) amended at May be Hazardous To Your Health finding. The employee shall also be timely notified of- the corrective action being taken. spacing" between lines shall be af least' equal" to the height of the upper-of any two lines. 12) Caution labels--(1) Labeling. Cau tion labels shall 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'modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentra tion* of asbestos fibers in excess of the exposure limits prescribed in paragraph (bl of this section will be released. <ii) Label specifications. The caution labels required by subdivision (1) of this subparagraph shall be printed In letters of sufficient size and contrast as to be readily visible and legible. The label shall, state: . ^ (J) Medteatexrimtnbtiona-t-d) Gen eral. The employer shallprovide or make available at his cost, medical examinaa tions relative to exposure to asbestos re quired by this paragraph. C2) '^replacement. Tfie employer'SKall provide or make available to each of his employees, within 30 calendar days fol lowing his first employment in an occupation exposed -to rirborne con centrations of asbestos fibers, a compre hensive medical examination, which shall include, as a minimum,-a-chest roent genogram (posterior-anterior 14 x 17 inches), a history to elicit symptom atology of respiratory - disease, and pulmonary function tests to include .forced vital capacity (FVC) and forced expiratory -volume-at.leaomaul AFEVi.,)-. ~'H3)~LAnr.uai examfria&oniroil'of be'- fore January 31, 1973, and at least an-s nually thereafter/ every employer shall provide, or make available, comprehend Cumoii' " slve medical examinations to each of his: employees engaged in occupations ex--, Contains Asbestos Fibers posed to airborne concentrations of as Avoid Creating. Dust bestos fibers. Such .annual examination Breathing Asbestos Dust May Cause - shall include; as a minimum, a chest, Serious Bodily Harm roentgenogram (posterior-anterior 14 x (h) Housekeeping--(i) Cleaning.' All' 17 Inches), a history-to elicit symptom-, 45 FR 35212. May 23, 1980. effective August 21, 1980; corrected bv 45 FR 54333, August 15, 19801 6 1910.1002 Coal tar pitch volatiles; interpretation of term. As used in 1910.1000 {Table Z-l), coal tar pitch volatiles include the fused polycyclic hydrocarbons which ' volatilize from the distillation residues of coal, petroleum (excluding asphalt), wood, and other organic matter. Asphalt (CAS 6052-42-4, and CAS 64742-93-4) is not covered under the "coal tar pitch volatiles" standard. [Sec. 1910.1002 revised by 48 FR 2768, January 21, 1983] ( 1910.1003 4-Nitrobiphenyl. , (a) Scope find application. (1) This section applies to any area In which 4-Nitroblphenyl, Chemical Abstracts Bepvice Registry Number 92933 Is manu factured, processed, repackaged, re leased, handled, or stored, but shall not ppply to transshipment In sealed con tainers, except for the labeling require ments under paragraphs (e) (2), (3), ana (4) of this section. - (2) This section shall not apply to solid or liquid mixtures containing IesA than oil percent by weight or volume of '4-Nitrobiphenyl. external surfaces in any place of employ atology of respiratory disease, and (b) Definitions. For the purposes of ment shall be maintained tree of accu pulmonary function tests to include this section: (1) "Absolute filter" Is one mulations of asbestos fibers if, with their forced vital capacity (FVC) and forced capable of retaining 99.97 percent of a dispersion, there would be-an excessive expiratory volume at 1 second (FEVi.,). piono disperse aerosol of 0.3 pm particles. concentration. (4) Termination oT.emploiiment. The' : (2) "Authorized employee" means an (2)' Waste disposal. Asbestos waste! scrap, debris, bags!' containers, equip ment, and asbestos-contaminated cloth ing, consigned fair disposal, which may employer-shall provide, or make avail able, within 30 calendar daysvbefbre or after the termination of employment of any employee engaged in an occupation employee whose duties require him to be in the. regulated area and who has been specifically assigned by the employer. T3) "Clean change- room" means a produce in any -reasonably foreseeable' exposed' to airborne concentrations of room where employees put on' clean use, handling, storage, processing, dis asbestos fibers, a comprehensive medical Slothing and/or protective equipment in posal, or transportation airborne concen trations of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section shall be collected and disposed of in sealed impermeable bags, or other closed! impermeable containers. (1) Recordkeeping--(1)' Exposwe'rec ords. Every employer shall maintain-rec ords of any personal or environmental monitoring required by this section. Rec ords shall be maintained for a period of at toast 20 years and shall be made avail able upon request to the Assistant Sec retary of Labor for Occupational Safety and Health, the Director of the National Institute for Occupational Safety and Health, and to authorised representa tives of either. 11910.1001(0(1) amended at 41 FR 11505, March 19, 1976) (2) Access. Employee exposure records examination which shall include, as a minimum, * chest roentgenogram (pos-: terior-anterior 14 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 (FEVi.)' ~v______ -j . ! (5) ReEeht eiatkinaH&ris: "No ~rffedjac examination -*ls required of any em ployee, If- adequate records show that' the'employee has been'-examined in ah-' cordance' with this paragraph within the (tost 1-year' period^-" -TO) Medical' ' records--ki) Malnte- nance. Employers of employees examined pursuant to this paragraph shall cause to be maintained complete and accurate records of all such medical examina tions. Records shall be retained' by employers for at least 20 years. pn environment free of 4-Nitrobiphenyl, The clean change room shall be con tiguous to and have an entry from a shower room, when the shower room facilities are otherwise required in"this' section,^, (4> "Closed system" means an opera tion Involving 4-Nitroblphenyl where ' tinment prevents the release of 4- S blphenyl Into regulated areas, non- ated areas, or the external environ- jnenty _ __ <) "Decontamination" means the In activation of 4-Nltrobiphenyl or its said disposal.. "/T6) "Director" means the Director, National 'Institute for Occupational Jtofety and Health, or any person di rected by him or the Secretary of Health, jBducatlon, and Welfare to act for the ptrector. '(7) "Disposal" means the safe re required by this paragraph shall be pro (ii) Access. Records of the medical moval of 4-Nltrobiphenyl from the work vided upon request to employees, designated examinations required by this paragraph environment. representatives, and the Assistant Secre shall be provided upon request to em f> < (8) "Emergency'' means an tmforseen tary in accordance with 29 CFR 1910.20 ployees, designated representatives, and :circumstance or set of circumstances re- (a)-(e) and (g)-(l). [Section 1910.1001(0(2) amended at 45 FR 35212, May 23, 1980, effective August 21, 19801 (3) Employee notification. Any employ: , the Assistant Secretary m accordance with 29 CFR 1910.20(a)-(e) and (g)-(i). These records shall also be provided upon the request to the Director of NIOSH. Any physician who conducts a medical exam ination required by this paragraph shall .suiting in the release of 4-Nitroblphenyl Which may result In exposure to or con tact with 4-Nitroblphenyl-. (9) "External environment" means any environment external to regulated and ee found to have been exposed at any time furnish to the employer of the examined nonregulated areas. to airborne concentrations of asbestos fi employee all the information specifically (10) "Isolated system" means a fully bers in excess of the limits prescribed in required by this paragraph, and any other enclosed structure other than the vessel of paragraph (b) of this section shall be noti medical information related to occupa containment of 4-Nitrobiphenyl, Occupational Safety & Health Reporter [Sec. 1910.1003(b) (10)1 66 CBY 3103796 c 002136 BRIEF SUMMARY OF OSHA INSPECTION Last week (6/28-7/1) an OSHA inspector investigated an employe* .-.ra- plaint on asbestos handling in the Texas City Plant. The cotpUmi stated: " "Pipefitters have been removing asbestos insulation without wearing the proper personal protective equip ment. The Company has taken samples to determine where the asbestos is located, but some insulation has been mistakenly identified as non-asbestos." The inspector interviewed both hourly and salaried employees, observed our work practices and reviewed our medical and industrial hygiene pro cedures related to asbestos handling. The inspector was favorably impressed with much of what he saw but the possibility of citations in two instances exists. We plan further discussions with the inspector's supervisor on the areas in question. By 6WD -b 6LT^ GWD/ob 7-6-83 CBY 3103797 c 00Z19X OSHA INSPECTION OSHA Inspector, Rex F, McKinney, Industrial Hygienist, appeared at the gate at 13:00 hours on Tuesday, June 23. The purpose of his visit was to investigate an employee compaint stated as follows: ' "Pipefitters have been.removing asbestos insulation without wearing the proper personal protective equipment. The Company has taken samples to determine where the asbestos is located, but some insulation ,, has been mistakenly identified as non-asbestos." This complaint was filed with OSHA on 6/27/83,' at 11:45 a.m. It was specific to Departments 15 and 16,.Department 19, Departments 48/56, and Power 2. The complaint, was made by.-Charles E. Davis who is the pipefitter craft safety repre sentative. ,, 'irotrtt__ . . ... The visit on Monday was to hold an opening conference and go over the complaint against the Company. .At the time,- he reviewed our OSHA 200 form for 1981 thru the present and commented on our good safety record. He also received a copy of all our forms used by Medical for performing physicals and a copy of the proce dures for removal of asbestos and the testing procedure by Pabco. The personnel present for this opening conference were: Charles Davis Vernon Mapes Dora Sendejas (to review Medical) Greg Daues Bob Hammann . He also mentioned that he had reviewed Roy Pigge's report on last year's general health inspection. He was here specifically on this asbestos investigation, but would cite us for any obvious violation that he happened to note in the course of his inspection. He left at approximately 2:30 after discussions with the comment that he would return the next day to interview people and look at the areas. ----------- Day Two, Wednesday, June 29 Rex McKinney went out into the plant at approximately 9:45. Charles Davis was the craft representative and a discussion was held with Dan Campbell, Bob Hammann, and Mr. McKinney. During this discussion, which mainly revolved around sampling, he was given copies of the sampling data of personnel in the area and a copy of our "Asbestos Procedure". H.G. Bullock was called in to dicuss the interpretertion of the procedure. Specifically, who was instructed to get the sample. This was stated to be normally taken by the maintenance foreman in the field. Mr. McKinney was taken to the I.H. lab and shown the procedures for determining asbestos. He also went to the field where he interviewed numerous people. The people interviewed were: CBY 3103798 c 002192 c OSHA INSPECTION (CONT'D) c Page 2 Herbert C. Doreck, pipefitter Leonard Dinning, pipefitter Ryan Pittman, pipefitter -.1 . W.R. Sanders, pipefitter M.F. Whatley, pipefitter Ed Smith, insulator Raymond Guidry, insulator Glenn Eierdam, insulator From all these people he got the same story. Essentially, they were supplied with proper personal protective equipment, but they felt that insulators were better able to handle the work.-- The pipefitters specifically stated they didn't feel that. they were qualified. On one hand- they said , they were willing to do the work agreed to by the contract, but on "the other hand they stated they thought that the insulators should be doing work around asbestos. He was also shown the change room. He left the plant at approximately 3:15. Day Three, Thursday, June 30 Mr. McKinney arrived at the plant at 10:00. Charles Davis, Dan Campbell, and Bob Hammann were present. They went to Department 48/56 where interviews were conducted with: -r-t r . -,r- Richard Hobbs, Jr., pipefitter Pete DeGroot, pipefitter . Charles Virgin, pipefitter All expressed concern about not having proper training. In fact, Hobbs had not been trained because he had been off two weeks on sick leave and one week vaca tion just recently. No checks were made in Department 19 as they did not have maintenance personnel in the area. Contact was made with Jim Gatewood concerning any work where insulation would be removed as incidental work. It was determined that they had a job stripping insulation off piping above 16E2 and would be doing this work right after lunch. We went to the area and after the men obtained the proper equipment, sampling pumps were connected to them by both Mr. McKinney and Monsanto Industrial Hygiene for determining a 15 minute ceiling concentration. The two individuals doing this work were G.E. Hoyland and R.V. Nicol. Six pic tures were also taken of the men in action stripping the insulation. Mr. McKinney requested that he have some of these pictures. These will have to be cleared through G.L. Tromblee. After sampling was completed and return made to the lab where he took a sample of insulation that determined to be asbestos. Mr. McKinney left the plant at 3:15. He will return at approximately 1:00 July 1, to give a preliminary closing conference. A final closing conference will be given once the results of the sampling are obtained. Possible Citations During the work on stripping the insulation material was not wetted down. This is in violation of OSHA Standard 1910.1001 Asbestos, 2. Work Practices, i) Wet Methods. Also, based on the results of the sample, we may be required to pro vide a physical exam for each of the employees now exposed to asbestos. Whether we are required or should do it will depend on the results of. the sampling. CBY 3103799 c 002193 c OSHA INSPECTION (CONT'D) c Page 3 This statement under preplacement is that, "the employer shall provide or make available to each of his employees, within 30 calendar days following his first employment in an occupation exposed to airborne concentrations of asbestos fibers, comprehensive medical exam, which shall include, as a minimum, a chest x-ray, a history of elicit symptomatology of respiratory disease, and pulmonary function tests..." Thereafter, this would have to be an annual examination. These are the two items that he mentioned we could possibly be cited on. The second one would not probably be a citation, but would be something we would have to comply with within 30 days. Other points noted during the inspection: a) Training came up almost'as a broken record. We did a very poor job In our initial training of personnel. b) People are not familiar of how to take the samples, where to take the samples, where to get the proper protective equipment, though, they all new that they could at least contact an insulator to find out where to get it. c) How to dispose of the equipment (i.e., putting the gloves in a bag), how to take the sample (i.e., put it in a plastic bag and taking it to the I.H. lab), or generally what they do when they are handling asbestos. d) Doors to the change room are locked and it is not known who has the key in all cases. We need to work on a better system for this. e) Comment was made that we should possibly use the insulators to assist in the training of members of other crafts. f) We need to put more emphasis on our hearing conservation as person nel were out in areas with loud noises emitted from compressors and not wearing proper ear protection. In two cases I had to request that people get the proper ear protection. However, this was not noted by the inspector. It was corrected before he could make any' comments. 7-1-83 R. T. Hammann CBY 3103800 C 002194 rr OSHA INSPECTON -- ASBESTOS Telephone Conversation With Rex McKinney of OSHA on 7/26/83 A call was placed to Rex McKinney to discuss the status of OSHA's personal sampling and determine if a date could be set for the closing conference. OSHA has not received the analysis of their samples as yet. They've recently moved their lab and feel that there may "be some additional delay due to this. He does not expect to get the results of their sampling back for at least two more weeks. Whenever this data is received he will contact me to set up a closing conference. I did relay to him the information concerning the results of our tests (that the personal samples were 0.21 and 0.23 fibers/cc). Also discussed with him whether he had talked with his boss concerning we had met the intent of the OSHA Standard which was to establish a baseline for our employees since we do have past physicals on employees as part of our medical program. He stated that he hfid -fli it mentioned it to his boss, but that the best thing for us to do would be to wait until after the closing conference and if there was a citation on this, then we could request an informal con ference with his boss in order to present our position. At that time they would accept or reject our contention. RTH/es R. T. Hammann % CBY 3103801 c 002195 fr CLOSING CONFERENCE -- OSHA INSPECTION FOR 8/12/83 The closing conference with Rex McKinney, OSHA, was set for 1400 on 8/12/83. Mr. McKinney arrived at the plant at 1230 and was brought in from the Main Gate at 1300. Prior to the closing conference there was some discussion on steps that we have taken since the inspection of 6/28-7/1 concerning employee physi cals. We stated that we plan to initiate yearly physicals (including medical history, pulmonary function test and chest x-ray) for those individuals doing incidental work requiring them to remove asbestos insulation. Also stated that we would not force an individual to take the chest x-ray. However, if they decided not to take the x-ray, then they would be required to sign a statement stating this. He also requested medical information on the two workers, R.V. Nicol and G.E. Hoyland, on which personnel monitoring was done while they were performing job of stripping asbestos. Information given was as follows: Nicol ? Last Physical . 03/23/83- Hoyland 11/17/82 Closing Conference . Pulmonary Function Test 08/81 11/17/82 L- Chest X-ray Given slip at last physical Given slip at last physical Personnel present: ,Rex McKinney, OSHA - Charles Davis, Pipefitter Safety Representative Greg Daues Dan Campbell Mark Riddle Bob Hammann Mr. McKinney started by stating that their tests showed 0.3 fibers/cc which is well below the ceiling limit and therefore indicated no overexposure. He stated there were three possible citation areas. 1. Work practices/wet methods - 1910.1001 C.2.i We were cited as the workers did not wet down the asbestos while they were removing it. It is our practice to wet down the asbestos. He has a copy of our procedures which state this. Abatement period - immediate. This has always been our practice. 2. Personnel monitoring - 910.1001 F.2.ii Personnel monitoring must be done at .intervals no greater than six months. From the data that we have given him, this has not been done. Additional search for data will be made-to see if we have indeed complied with this. Abatement period - immediate. - CBY 3103802 C 002196 rr Closing Conference - OSHA Inspection 8/12/82 (Cont'd.) Page 2 3. Employee physicals - 1910.1001 J.2 People working with asbestos shall have a physical examination within 30 calendar days. Some discussion followed concerning this when we once again stated our opinion that this initial examination is to establish baseline data. We are willing to accept data taken from earlier physicals as being the baseline data. He could not answer this other than to state that we would have to discuss it with his boss at an informal conference sometime after receiving any citations. His boss' name is Jack Fontaine and his phone number is 750-1727. We should receive the formal citation within two weeks by registered mail. The fifteen working day period for formally contesting the citation will start the day after receipt of the citation. ::l CBY 3103803 C 002197 September 26, 1983 Monsanto MONSANTO FIBERS AND INTERMEDIATES CO. P. O. Box 1311 Texas City, Texas 775 9 0 Phone: (713) 945-4431 Gerald A. Baty, Area Director' Occupational Safety & Health Administration U.S. Department of Labor 2320 La Branch, Room 1103 Houston, Texas 77004 Re: Citation M6013-167 dated 8/22/83, as amended bythe informal settlement agreement of 9/01/83. Dear Sir: Monsanto Fibers & Intermediates Company is complying with 29 CFR 1910.1001 (F)(2)(ii) concerning personal monitoring of airborne asbestos. This monitoring has been done and will be continued at intervals of no more than six months for our employees whose exposure to asbestos may exceed the limits prescribed by paragraph (b) of 29 CFR 1910.1001. Very truly yours. R. T. Hammann, Superintendent Loss Prevention & Safety Dept. RTH/es CBY 3103804 a unit of Monsanto Company i C 002198 U.S. Department of Labor Houston Area Office 2320 LaBranch, Room 1103 Houston, Texas 77004 September 23, 1983 Occupational Safety and Health Administration Reply to the Attention of: Mr. Gene L. Tromblee Monsanto Fibers and Intermediates Co. P.0. Box 1311 Texas City, Texas 77590 RE: M6013-167 Dear Mr. Tromblee CP-/" A citation was issued to your company containing item(s) with abatement date(s) that are now past due. As a courtesy, we wish to bring this to your attention as these dates may have been overlooked.. ,Since3 your receipt of this citation, we have not received correspondence* from you indicating that you have complied or abated all the items. We are in need of documentation from you indicating the status of these items. Followup inspection indicating non-abatement may result in additional proposed penalty. It is requested that reports be made upon each abatement date as indicated in the citation in order to minimize reinspection activity. We will appreciate your prompt attention to this matter, and should you have any questions concerning this item or others regarding the Occupational Safety and Health Act of 1970, please contact this office. If you have recently mailed this abatement report, please disregard this letter as it is sent as a courtesy reminder. ginporol vr GERALD -AT"BATY Area Director CBY 3103805 C 002199 ( r \ OCC'-VATIO.'IAL SArETY A.-O as.-1 AO-WI.YIAfRA Tl CN CITATION and NOTIFICATION OF PENALTY Baiaccn Area Office "320 LiRrasch - Roca 1103 CEHt 1 TO: Monsanto fibers and Intermediates Conpany P.0. Bax 1311 isaa City, Tsana 77550 Ara.- Mr. Gone L. Trcahlee, Slat Manager MSSUA'iwX 1 > CSffA >UM* `8/22/33 yj6013i 167 > fi!GJQ1 * AAU > >A5f 6 T2S0 1 t 'VW-7/m INSPECTION SHE: SOS^Salrth Bay Strict --------------------------------------------------------- --- STANDARD, REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION "be issuance of this citation does, not constitute a finding that a violation of the Act has occurred unless there is a failure to contest as provided for in the Act or, if contested, unless the citation is affirmed by the Review Coaaissicn. B,VoV^,'SsHt f BE CORRECTED penalt The violations described 3a this cd-tatrca are alleged to have occurred on or about the day the inspection vns side unless otherwise indicated within the description given below. . 1 29 CFS 1910.1003(f)(2)(ii): The airborne asbestos monitoring schedule !<as not of sufficient frequency and pattern as to represent with reasonable accuracy the levels of employee exposure to airborne asbestos fibers: Iraedict sly Upon Receipt $0 (a) Monsanto fibers and latesnediatea Ccapao-y- in Texas City, Terns, does not conduct personal nonitorisg for airborne asbestos fibers at intervals of 6 norths of loss for employees whose exposure to asbestos nay reasonably be foreseen to exceed the limits prescribed by paragranh b of 29 C7R 1910.1001. 2 1t-h bE.L.s.re-0 ssme/tsur / 29 CTR 191u.l001(j)(^): Tile employer did rfot provide^or sake / available^ to each emloyee, within 30 days/following/fais- first ca- pleyneafin an occupation exposed to airborne levels/of asbestos fibers, & comrehehsive aedical crutination; f ` // (a) Cn Jun^ 30, 1933^ an eamloyee working-^n Gait l6,l!2 vai exposed to 0.23 fibers per cubic centimeter of air^This/ ersosure-occurred,-during an asbestos insulation removal; The sample takm/vas a 15-njnute ceiling saaple./ V** area director ;-:cu3 a...'jiff c 002200 >* '\r.' i: -V;Y .Lvj. v .. - CRY 3103906 fr i'll or;s an co MONSANTO FIBERS AND INTERMEDIATES CO. P. O. BOX 1311 Taxas City, Texas 775 9 0 Phone: (713) 945-4431 . September 7, 1983 Gerald A. Baty, Area Director Occupational Safety & Health Administration US. Department of Labor 2320 La Branch , 'Room" 11&3 Houston, Texas 77004 Re: Citation M6013-167 dated 8/22/83, as amended by the informal settlement agreement of 9/01/83. Dear Sir: Monsanto Fibers & Intermediates Company is complying with 29 CFR 1910.1001 (F)(2)(ii) concerning personal monitoring of airborne asbestos. This monitoring has been done and will be continued at intervals of no more than six months for our employees whose exposure to asbestos may exceed the limits prescribed by paragraph B of 29 CFR 1910.1001. Very truly yours, RTH/es R. T. Hammann, Superintendent Loss Prevention & Safety Dept. a unit of Monsanto Company CBY 3103806 ; . *. ?r . . r C 002201 HCC 930920 r r Monsanto (ROM NAMt 4 LOCATION) R.T. Hammann, LP&S - Texas City 0-22 = September 7, 1983 cc Ext. 3234 KMMNCi Letter of Corrective Action to OSHA Area Director TO : P.S. Park (SL) G3WB Attached is a copy of the Informal Settlement Agreement reached with OSHA on 9/01/83. In order to close the file we are required to send a letter of corrective action to Gerald Baty, the Area Director in Houston. Please let me know of any corrections needed to this letter. AlsOj should it go out under the Plant Manager's signature? Thank you for your assistance. .Attachment RTH/es R.T. Hammann CBY 3103809 C 002202 rr U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION CrS? .INFORMAL SETTLEMENT AGREEENT- The undersigned Employer ;iand the,:naersigned Occupational Safety ana Health Administration (OSHA), in settlement of the above citation(s) and penalties v/hich were , hereby agree as follows: 1. The Employer agrees to correct the violations as cited in the above citations or as amended belov/.- 2. The Employer agrees to pay the proposed penalties, if any, as issued with the- above citation(s), or, if amended by this agreement, as amended belov/. ' 3. The Employer and OSHA agree that the following citations and penalties (if any) are not being amended by this agreement: - 4. OSHA agrees that the follov/ing-citations and penalties are being amended as shown (see attachments): , CBY 3103810 t 0^002203 rr 5. The Employer, by signing this informal settlement agreement, hereby waives its rights to "contest the above citation(s) and penalties, as amended in paragraph 4 of this agreement.' 6. The Employer agrees to immediately post a copy of this Settlement Agreement in a prominent place at or near the location of the violation( s)r ' # referred to in paragraphs 3 and 4 above. This Settlement.Agreement must . remain posted until the violations cited have been corrected, or for 3 working days (excluding weekends -and Federal Holidays), whichever is longer* FOE THE OCCUPATIONAL SAFETr/AND HEALTH ADMINISTRATION ; -i, - NOTICE TO EMPLOYEES \ The law gives you or your representative the opportunity to object to any ` abatement date set fox a violation if you believe the date to be unreasonable. Tiny contest to the abatement dates of the citations amended in .paragraph 4 of this Settlement Agreement must he mailed to the U.S. Department of Labor-OSHA, 2320 LaBranch, Room 2118, Houston, Texas 77004, within 15 working days' (exclud ing weekends and Federal Holidays) of the receipt by the Employer of this Settlement Agreement. You ort. your representative also have-the right to object to any of the abatement dates set for violations referred to in paragraph 3 ! .... r provided that the objection is mailed to the office shown above within the'15 working day period established by the original citation. j it -, - -- :T *!. "-- CBY 3103811 k <3 002204 r\ informal conference with osha Held 9/01/83 Meeting was held with Gerald A. Baty, OSHA Area Director, and Jack Fontaine, Industrial Hygiene Supervisor, concerning the citation issued 8/23/83. This was as a result of the inspection of 6/28-7/01/83, on asbestos handling. Present for Monsanto were: Dan Campbell, Industrial Hygienist, and R.T. Hammann, LP&S Superintendent. Discussion of the citation consisted of the following: Point I - Asbestos Monitoring -s Monitoring done in January included a source sample which, although not attached to the individual, was construed to be a personal sample as it was hung in the breathing zone. Point: II -^replacement Exam A. History of the complaint. _ - - ' ' - -5 .. r r ` B. ' Monsanto policy oh medical exams. C. Felt that we have complied with the intent of the regulation in establishing baseline data. An informal settlement agreement was reached whereby OSHA deleted Point II and Point I will be abated by the Texas City plant. Additional Information Received During This Conference: OSHA considers that when monitoring of personnel shows greater than 0.1 fbrs/cc for an 8 hour time weighted average that these employees must receive the annual physical. RTH/es erstjune. - R. T. Hammann CBY 3103812 C 002205 Texas City, Texas July 7, 1983 OSHA Inspection (6/28-7/1/83) -To: - -G. W. Daues Copie's "to: _ - .. ' l: Clayton Callis - B3CA R. L. Hammond John L. Henshaw - G4WG D. E. Kaldenberg V. Mapes - SS-17 C. D. Norlander - G5WB Steve D. Paul - G2WB H. 0. Rei'd G. L. Tromblee W. D. Walker (See Attached) v CBY 3103813 c 002206 Monsanto MOm (Name 4 LOCATION) R.T. Hammann/M.A. Riddle, LP&S July 7, 1983 OSHA INSPECTION (6/28--7/1/83) 0-22 Ext. 3234/3236 TO : 6. W. Daues 0-1OA OSHA Inspector, Bex F. McKinney, Industrial Hygienist 13:00 hours on Tuesday, June 28. The purpose of his employee compalnt stated as follows: "Pipefitters have been removing asbestos insulation without wearing the proper personal protective equipment.' The Company has taken samples to determine where the asbestos is located, 'hut some Insulation . has been mistakenly identified as non-asbestos." This complaint was filed with OSHA on 6/27/83, at 11:45 a.m. It was specific to Departments 15 and 16, Department 19, Departments 48/56, and Power 2. The complaint was made by Charles E. Davis who is the pipefitter craft safety repre sentative. * / hold an opening conference and go over the complaint against the Company. At the time, he reviewed our OSHA 200 form for 1981 thru the present and commented on our good safety record. -Be also received a copy of all our forms used by Medical for performing physicals and a copy of the 'proce dures for removal of asbestos and the testing procedure by Pabco. The personnel present for this opening conference were: Charles Davis Vernon Mapes Dora Sendejas, R.N Greg Daues Bob Hammann He also mentioned that he had reviewed OSHA inspector. Boy Pigge's report on last year18 general health inspection of the plant. He was here specifically on this asbestos investigation, but would cite us for any obvious violation that he happened to note in the course of his Inspection. He left at approximately 2:30 after discussions with the comment that he would return the next day to inter view people and look at the areas. Day Two, Wednesday, June 29 Rex McKinney entered the plant at approximately 9:45. A discussion was held with Dan Campbell, Bob Hammann, Charles Davis, and Mr. McKinneyjgg3faring this discussion, which mainly revolved around sampling, he was give&'s|jple8 of the sampling data of personnel in the area and a copy of our "AabeixgS Procedure". H.G. Bullock, Maintenance foreman for insulators, was called in%o dicuss the interpretation of the procedure, specifically, who was instructed to get the sample. This was stated to be normally taken by the maintenance foreman in the CBY 3103814 c 002207 c OSHA Inspection (6/28--7/1/83) c Page 2 field. Mr. McKinney was taken to the I.H. lab and shown the procedures for determining asbestos. He also went to the field where he interviewed numerous people. The people interviewed were: Herbert C. Doreck, pipefitter Leonard Dinning, pipefitter Ryan Pittman, pipefitter W.R. Sanders, pipefitter M.F. Whatley, pipefitter Ed Smith, insulator Raymond Guidry, insulator Glenn Eierdam, insulator From all these people he got the same story. Essentially, they were supplied with proper personal protective equipment, but they felt that insulators were better able to handle the work. The pipefitters specifically stated they didn't feel that they were qualified. On one hand they said they were willing to do the work agreed to by the contract, but on the other hand they stated they thought that the insulators should be doing work around asbestos. He was also shown the change room. He left the plant at approximately 3:15. Day Three, Thursday, June 30 Mr. McKinney arrived at the plant at 10:00. Charles Davis, Dan Campbell, and Bob Hammann were present. They went to Department 48/56 where interviews were conducted' with: Richard Hobbs; Jr., pipefitter Pete DeGroot, pipefitter Charles Virgin, pipefitter All expressed concern about not having proper training. In fact, Hobbs had not been trained because he had been off two weeks on sick leave and one week vaca tion just recently. No checks were made in Department 19 as they did not have maintenance personnel in the area. Contact was made with Jim Gatewood concerning any work where asbestos insulation would be removed as incidental work. It was determined that they had a job stripping insulation off piping above 16E2 and would be doing this work right after lunch. We went to the area and after the men obtained the proper equip ment, sampling pumps were connected to them by both Mr. McKinney and Monsanto Industrial Hygiene for determining a 15 minute celling concentration. The two individuals doing this work were G.E. Hoyland and R.V. Nicol. Six pictures were also taken of the men in action stripping the insulation. Possible Citations During the work on stripping the insulation material was not wetted down. This is in violation of OSHA Standard 1910.1001 Asbestos, 2. Work Practices, i) Wet Methods. Also, based on the results of the air sampling, we.may be required to provide a physical exam for each of the employees now exposed to asbestos. CBY 3103815 C 002203 .c OSHA Inspection (6/28--7/1/83) c Page 3 This statement under preplacement is that, "the employer shall provide or make available to each of his employees, within 30 calendar days following his first employment in an occupation exposed to airborne concentrations of asbestos fibers, comprehensive medical exam, which shall include, as a minimum, a chest x-ray, a history of elicit symptomatology of respiratory disease, and pulmonary function tests..." Thereafter, this would have to be an annual examination. These are the two items that he mentioned we could possibly be cited on. The second one would not probably be a citation, but would be something we would have to comply with within 30 days. Day Four, Friday, July 1 Rex McKinney was scheduled to return to the plant at 1300 for the closing con ference. He arrived at 1100 and asked to talk with the supervisor, Larry Young, pipefitter leadman, Marvin Janicek, and pipefitters, R.V. Nicol and G.E. Hoyland that were involved in the asbestos stripping job observed on Thursday, June 30. He talked with these people individually and asked some basic questions to verify the area and the type of work that they were doing. Mark Riddle, Charles E. Davis, craft safety representative, and Dan Campbell were present during these discussions. After the above gentlemen who were interviewed left, Mr. McKinney asked a few other housekeeping type questions.. He then said he would not hold the final closing conference until sampling results were obtained which would take at least 30 days. He did say there was the possibility of citations and just reiterated the possible citations that were discussed on Thursday. He stated to the pipefitter safety representative that he could be contacted at any time by phone if he had further questions. We escorted Mr. McKinney to the gate and on the way he asked if we had got approval for the pictures that were taken the day before. We told him that we had and that we needed to go to Greg Danes' office to obtain them. We went to Greg Daues' office to get the pictures and while there had a short informal discussion with Daues concerning Mr. McKinney's future course of action. We discussed the statement that he had made previously that we would probably have to provide an examination for all employees within 30 days following their first exposure to asbestos fibers. We discussed our opinion that we had met the intent of the law which is to establish a baseline data, and that we have already done this due to our ongoing medical program. He said he could not make that decision himself, but that he would discuss this with his supervisor and that we should call his supervisor to discuss our opinions further. His supervisor's name is Jack Fontaine. We then provided Mr. McKinney with the pictures he requested of the asbestos removal job on Thursday, and he was escorted to the gate. Other Points Noted During The Inspection: a) Training came up almost as a broken record. Our initial training of personnel could have been improved. b) Some said they were not familiar of how to take the samples, where to take the samples, where to get the proper protective equipment. They allfciew, however, that they could at least contact an insulator cbY 3103816 C 002?09 c OSHA Inspection (6/28--7/1/83) c Page 4 to find out what to do, how to dispose of the equipment (i.e., putting the gloves in a bag), how to take the sample (i.e., put it in a plastic bag and taking it to the I.H. lab), or generally what they do when they are handling asbestos. c) Doors to the change room are locked and it is not known who has the key in all cases. d) Comment was made that we should possibly use the insulators to assist in the training of members of other crafts. e) We need to put more emphasis on our'hearing conservation as person nel were out in areas with loud noises emitted from compressors and not wearing proper ear protection. In two cases we had to request that people get the proper ear ^protection. - However, this was not noted by the inspector. It was corrected before he could make any 'Comments. Bob Hammann Mark Riddle eS " CBY 3103817 / :C 002*210 r Texas City, Texas July 7, 1983 OSHA Inspection (6/28-7/1/83) To: G. W. Daues Copies to: - _ ' Clayton Caliis - B3CA R. L. Hammond John L, Henshaw - G4WG D. E. Kaldenberg V. Mapes - SS-17 C. D. Norlander - G5WB Steve D. Paul - G2WB Hj^OiTjReid ' G. L. Tromblee . D.,Walker (See Attached) CBY 3103818 -vG 002211 Monsanto fROM (NAME 4 LOCATION) r R.T. Hammann/M.A. Riddle, LP&S 0-22 Ext. 3234/3236 PATE July 7, 1983 cc subject OSHA INSPECTION (6/28--7/1/83) reference TO : G. W. Daues O-lOA' ~" OSHA Inspector, Rex F. McKinney, Industrial Hygienist, appeared^at the gate at 13:00 hours on Tuesday, June 28. The purpose of his visit was-^tb investigate an employee compaint stated as follows: "Pipefitters have been removing asbestos insulation without wearing the proper personal protective equipment. The Company has taken samples to determine where the asbestos is located, but some insulation has been mistakenly identified as non-asbestos." This complaint was filed with OSHA on 6/27/83, at 11:45 a.m. It was specific to Departments 15 and 16, Department 19, Departments 48/56, and Power 2. The complaint was made by Charles E. Davis who is the pipefitter craft safety repre sentative. The visit on Monday was to hold an opening conference and go over the complaint against the Company. At the time, he reviewed our OSHA 200 form for 1981 thru the present and commented on our good safety record. He also received a copy of all our forms used by Medical for performing physicals and a copy of the 'proce dures for removal of asbestos and the testing procedure by Pabco. The personnel present for this opening conference were: Charles Davis Vernon Mapes Dora Sendejas, R.N. Greg Daues Bob Hammann He also mentioned that he had reviewed OSHA inspector, Roy Pigge's report on last year's general health inspection of the plant. He was here specifically on this asbestos investigation, but would cite us for any obvious violation that he happened to note in the course of his inspection. He left at approximately 2:30 after discussions with the comment that he would return the next day to inter view people and look at the areas. Day Two, Wednesday, June 29 Rex McKinney entered the plant at approximately 9:45. A discussion was held with Dan Campbell, Bob Hammann, Charles Davis, and Mr. McKinney. During this discussion, which mainly revolved around sampling, he was given copies of the sampling data of personnel in the area and a copy of our "Asbestos Procedure". H.G. Bullock, Maintenance foreman for insulators, was called in to dicuss the interpretation of the procedure, specifically, who was instructed to get the r ' sample. This was stated to be normally taken by the maintenance foreman in the CBY 3103819 --I*; OSHA Inspection (6/28--//1/83) Page 2 field. Mr. McKinney was taken to the I.H. lab and shown the procedures for determining asbestos. He also went to the field where he interviewed numerous people. The people interviewed were: Herbert C. Doreck, pipefitter Leonard Dinning, pipefitter Ryan Pittman, pipefitter W.R. Sanders, pipefitter M.F. Whatley, pipefitter Ed Smith, insulator Raymond Guidry, insulator Glenn Eierdam, insulator ..... From all these people he got the same story. Essentially, they were supplied with proper personal protective equipment, but they felt that insulators were better able to handle the work. 'The pipefitters specifically stated they didn't feel thaf-rthey were qualified. On one hand they said they were willing to do the work agreed to by the contract, but on the other hand they stated they thought that the insulators should be doing work around asbestos. He was also shown the change room. He left the plant at approximately 3:15. Day Three, Thursday, June 30 ... Mr. McKinney arrived at the plant at 10:00. Charles Davis, Dan Campbell, and Bob Hammann were present. They went to Department 48/56 where interviews were conducted with: Richard Hobbs, Jr., pipefitter Pete DeGroot, pipefitter Charles Virgin, pipefitter All expressed concern about not having proper training. In fact, Hobbs had not been trained because he had been off two weeks on sick leave and one week vaca tion just recently. No checks were made in Department 19 as they did not have maintenance personnel in the area. Contact was made with Jim Gatewood concerning any work where asbestos insulation would be removed as incidental work. It was determined that they had a job stripping insulation off piping above 16E2 and would be doing this work right after lunch. `We went to the area and after the men obtained the proper equip ment, sampling pumps were connected to them by both Mr. McKinney and Monsanto Industrial Hygiene for determining a 15 minute ceiling concentration. The two individuals doing this work were G.E. Hbyland and R.V. Nicol. Six pictures were also taken of the men in action stripping the insulation. Possible Citations During the work on stripping the insulation material was not wetted down. This is in violation of OSHA Standard 1910.1001 Asbestos, 2. Work Practices, i) Wet Methods. Also, based on the results of the air sampling, we"may be required to provide a physical exam for each of the employees now exposed to asbestos. CSV 3103820 C 002213 r OSHA Inspection (6/28--7/1/83) r Page 3 This statement under preplacement is that, "the employer shall provide or make available to each of his employees, within 30 calendar days following his first employment in an occupation exposed to airborne concentrations of asbestos fibers, comprehensive medical exam, which shall include, as a minimum, a chest x-ray, a history of elicit symptomatology of respiratory disease, and pulmonary function tests..." Thereafter, this would have to be an annual examination. These are the two items that he mentioned we could possibly be cited on. The second one would not probably be a citation, but would be something we would have to comply with within 30 days. Day Four, Friday, July 1 Rex McKinney was scheduled to return to the plant at 1300 for the closing con ference. He arrived at 1100 and asked to talk with the supervisor, Larry Young, pipefitter leadman, Marvin Janicek, and pipefitters, R.V. Nicol and G.E. Hoyland that were involved in the asbestos stripping job observed on Thursday, June 30. He talked with these people individually and asked some basic questions to verify the area and the type of work that they were doing. Mark Riddle, Charles E. Davis, craft safety representative, and Dan Campbell were present during these discussions. After the above gentlemen who were interviewed left, Mr. McKinney.asked a few other housekeeping type questions*. He then said he would not hold the final closing conference until sampling results Were obtained which would take at least 30 days.. He did say there was the possibility of citations and just reiterated the possible citations that were discussed on Thursday. * r- He stated to the pipefitter safety representative that he could be contacted at any time by phone if he had further questions. We escorted Mr. McKinney to the gate and on the way he asked if we had got approval for the pictures that were taken the day before. We told him that we had and that we needed to go to Greg Danes* office to obtain them. We went to Greg Daues* office to get the pictures and while there had a short informal discussion with Daues concerning Mr. McKinney's future course of action. We discussed the statement that he had made previously that we would probably have to provide an examination for all employees within 30 days following their first exposure to asbestos fibers. We discussed our opinion that we had met the intent of the law which is to establish a baseline data, and that we have already done this due to our ongoing medical program. He said he could not make that decision himself, but that he would discuss this with his supervisor and that we should call his supervisor to discuss our opinions further. His supervisor's name is Jack Fontaine. We then provided Mr. McKinney with the pictures he requested of the asbestos removal job on Thursday, and he was escorted to the gate. Other Points Noted During The Inspection: a) Training came up almost as a broken record. Our initial training of personnel could have been improved. b) Some said they were not familiar of how to take the samples, where to take the samples, where to get the proper protective equipment. They all new, however, that they could at least contact an insulator CBY 3103821 C 002214 r. OSHA Inspection (6/28--//1/83) r Page 4 to find out what to do, how to dispose of the equipment (i.e., putting the gloves in a bag), how to take the sample (i.e., put it in a plastic bag and taking it to the I.H. lab), or generally what they do when they are handling asbestos. c) Doors to the change room are locked and it is not known who has the key in all cases. d) Comment was made that we should possibly use the insulators to assist in the training of members of other crafts. e) We need to put more emphasis on our hearing conservation as person nel were out in areas with loud noises emitted from compressors and not wearing proper ear protection. In two cases we had to request that people get'the proper ear protection. BOwever, this was not noted by the inspector. It was corrected before he could make any comments. " ~ Bob Hammann Mark Riddle es w CBY 3103822 C 002215 f~'' ^ Z * ' 9B November 1977 Revised October 1980 INDUSTRIAL CARCINOGENS INTRODUCTION For the last 20 to 30 years, science and technology have taken giant steps. Massive amounts of new machines, processes and products are designed, pro duced and marketed annually. Thousands of new previously unknown chemi cals are introduced into the market every year. Only in the last few years have we realized that the great advantages of these new chemicals may be counteracted by posing serious health hazards to the manufacturer and user of these chemicals. The most serious of these hazards, the potential for carcinogenicity (cancer) to man, has alarmed industry and the public in general. STANDARDS Research into the carcinogenic potential of the myriad of chemicals has been very slow and in most cases inconclusive. Identification of cancer agents is fur ther complicated by the difficulty of correlating animal experiments with actual human epidemiological-data. The Occupational Safety 8c Health Administration (OSHA) has produced regulations for only 21 chemicals with carcinogenic potential to man. Strict standards and regulations have been established which are included in the Code of Federal Regulations 29 CFR 1910. Even for these, only a few have established permissible exposure limits. The American Conference of Governmental Industrial Hygienists (ACGIH) further recognizes that a few more are so toxic that no exposure or contact is permissible. However, more than half of these do not have any established Threshold Limit Values (TLV) or other permissible exposure limits. Table No. 1 shows the carcinogens listed and regulated by OSHA. The standards established by OSHA for the chemicals in Table No. 1 are specific on the various requirements. They further include exceptions by use and by per centage of carcinogen content. CONTROL PROGRAM The following is a summary of the basic requirements for a good carcinogen control program. For specific details, please consult the individual standard. 1. Substitute less toxic materials for known carcinogens. 2. A written, well-defined set of procedures should be established for the storage, use, and general control of these chemicals. Strict maintenance, cleaning, spi'lage control, and waste disposal procedures should be established. These procedures should be approved and implemented by top management. 3. Workers and supervisors who may be engaged in the use of these chemi cals should be thoroughly trained as to the recognition, use and all other aspects relating to the chemicals. Regularly scheduled retraining sessions should also be established. CBY 3103623 -9- c 002216 4. Establish and maintain a separate inventory on aU carcinogenic products. 5. Containment of the chemicals at all stages from storage to final use is vital. Open vessel systems should not be used. 6. Areas where these materials are being used or stored should be regulated and access to and exit from them should be restricted. Posted signs and documentation should be maintained as to the names of employees enter ing and leaving the restricted area. 7. If possible, oniy one well-trained person should handle these chemicals. All operations, especially the weighing and scooping of these chemicals, should be done within an effective local exhaust ventilation system. A laboratory type hood with front doors is recommended so that only the worker's hands, properly protected by gloves or glove boxes, are requited to be introduced into the hood, leaving the face behind the glass window. Intermediate transfer of these materials should always be done .n closed and tightly secured containers. These chemicals should be stored in closed containers in segregated areas under lock and key. 8. Adequate, approved respiratory and skin protection should be worn as required for each type of chemical. In most cases they may involve the use of self-contained breathing apparatus, full-body airtight suits or high effi ciency filter respirators. 9. The removal of the personal protective equipment and work clothes should be done in wash areas adjacent to, but separate from, the work area. Employees should wash their hands and shower thoroughly before leaving the plant. Work clothes should never be taken home. 10. All employees exposd to the chemicals should undergo periodic medical examinations and the results of which, as well as the personnel exposure history, be maintained and documented as required. .. RECOGNIZED HUMAN CARCINOGENS In addition to the OSHA listed carcinogens, the ACGIH has listed substances (as recognized human carcinogens) associated with industrial processes. These are shown in Table No. 2 with any applicable TLV's. SUSPECTED HUMAN CARCINOGENS ACGIH has also listed industrial substances suspect of carcinogenic potential for man. Included in this series of chemicals are substances which are associ ated with inducing cancer but are based on either (1) limited epidemiological evidence, exclusive of clinical reports of single cases, or (2) demonstration of carcinogenesis in one or more animal species by appropriate methods. These chemicals, as opposed to those in Table No. 1, are presently used in a large variety of industries and processes with a great number of workers being exposed to them. For the chemicals listed in Table No. 3, worker exposure by all routes should be carefully controlled to levels consistent with the animal and human experience data including those substances with a listed TLV. As more information becomes available, chemicals in Table No. 3 may become regulated. It is also very likely that more chemicals will be associated with human carcinogenicity. CONCLUSION Continuing research will surely develop significant conclusions. While the chemi cals mentioned in this bulletin are the most likely to be found in the work place, many more have or will be identified in pollution breakdown chains, natural animal and vegetable food items, among others. On the other hand, media -10- C&Y 3103824 c 002217 reports tend to implicate many other compounds as potential cancer agents. When reviewing the latter, one has to scrutinize these reports as to their actual scientific background, completeness of research, and dose-response relation ship (how much consumption will actually increase the potential for cancer). TABLE 1 OSHA LISTED AND REGULATED CARCINOGENS Standard 1910 1001 1910.1002 1910.1003 1910.1004 1910.1005 (Deleted) 1910.1006 1910 1007 1910.1008 1910.1009 1910 1010 1910.10,11 19'0 '012 19-0 1013 1910.1014 1910 '015 1910 1016 1910 1017 1910 1018 1910.1028 1910.1029 1910 1044 1910/045 Name Asbestos (a) Use Various, insulation filler Coal Tar Pitch Volatiles (b) 4:Nitrouiphenyl alpha-Naphthylamine 4,4' Methylene bis (2-chloroamline) (MOCA) (c) Methyl chioromethyi ether 3.3' Dichlorobenzidine (ana its salts), bis-Chlorcmethyt . ether beta -Naphthylamine Benzidine 4-Arr.inodiphenyl Ethyleneimine beia-Propiciactone 2-Acefyiaminofluorene 4-Cimethylaminoazobenzene n-Nitrosodimefhylamine Vinyl chioride (monomer) Inorganic Arsenic Benzene Coke oven emissions 1.2 dibromo-3-chloropropane (CBCP) Acrylonitrile Manufacture of steel asphalt, etc. Intermediate in production of 4-Aminodiphenyl Intermediate in dyes, herbicides and antioxidants Curing agent for isocyanatecontaining polymer. Production of ion-exchange resins and as chioromethylating agent Production of dves. curing agent for isocyanate containing polymers. Intermediate in production of various textile aids. Intermediate in ayes, antioxiaants Dye manufacture Rubber antioxicant Used to manufacture polyethyleneimine: flocculant in water treatment; intermediate oil additive, adhesives, surfactants Manufacture of acrylic acid and its esters. Initially as pesticide Manufacture of coloring polishes and other wax products. Solvent and in manufacture of rocket `uel. antioxidants, lubricant aad;tives. and in condensers to increase dielectric constant. Mainly PVC manufacture Foundries & smelters. Pigment glass & paint manufacture Solvents. Chemical intermediate Coke ovens (Steel foundries) Pesticide Plastics, pestiede Type of cancer Lung & liver Mainly biadder Bladder as 4-Aminodiphenyl Bladder with beta-naphthylamine Non conclusive data Lung (oat-cell) Bladder (suspected) Lung Bladder Bladder Bladder liver-cell 8i pulmonary (animals) (animals) Various (animals)' Liver & bladder (animals) Liver 8i kidney (animals) Liver Lung 8<. skin Leukemia, bone marrow Lung, liver & skin Cancer & sterility Lung & colon TLV 2 fibers/cc greater than 5 micro meters in length 0.2 mg/m3 NECC (ACGIH) No TLV No TLV No TLV No TLV 0.001 ppm (ACGIH) NEOC(ACGIH) NEOC (ACGiH) NEOC (ACGIH) 0.5 ppm (ACGIH) No TLV No TLV No TLV No TLV 1 ppm 10 ug/m3 10 ppm 150 ug/m3 1 ppb .2 ppm (a) A:i forms: Chrysolite. amosite. crocidolite. tremolite. anthophyllite and actinolite. (b) Particulate ciycyciic Aroma';c Hydrocarbons. (Benzene soluble fraction.) Anthracene. benz(a)pyrene. pnenantnre-e. acricme. chrysene, pyrene. (c 1 MGC- has been ceieied from the OSHA carcinogen list. TIV = Threshold Lmit Value ACGiH = American Conference of Governmental Industrial Hygienists. NE DC = No cxcosure or Contact. mg*m'' = milligrams of contaminant per cubic metes of air. pen = parts of contaminant per million parts cf air. by volume. PCP = parts of contaminant per billion parts of air. by volume. -n- CBY . 31.03825 --C 002213 TABLE 2 Recognized Human Carcinogens. Substances, or substances associated wth industrial processes, recognized to have carcinogenic or cocarcinogenic potential with an assigned TLV. Chrcn-.ite ore processing (chromate) Nickel sulfide roasting, fume & dust 1.2 Dbrcmoethane (ethylene dibromide) TLV 0.05 mg/m3 (as Cr) 1.0 mgim3 (as Ni) NEOC TABLE 3 Suspected Human Carcinogens. industrial Substances Suspect of Carcinogenic Potential for Man. 3-Amino 1.2.4-Triazole Antimony trioxide production' Arsenic trioxide production Benzene--Skin Benz(ajpyrene Beryllium Cadmium oxide production Carbon tetrachloride Chloroform Chrcmctes of lead and zinc (as Cr) Dimerhylcarbamyl chloride 1. 1-Dimethyl hydrazine Dimethyl sulfate--Skin Ethylene dibromide--Skin Hexachiorobutadiene Hexamethyl phosphoramide--Skin Hyarazine 4.4'-ty!ethylene bis (2-chloroaniline)--Skin Methyl hydrazine Methyl iodide 2-Nitrcoropane n-Phenyl-beta-naphthylamine Propane suitone Propylene imine--Skin o-Tolidine Vinyl bromide Vinyl cyclohexene dioxide uv -- -- -- 10 ppm 2.0 ug/m3 -- 5 ppm .10 ppm 0.05 mg/m3 -- 0.5 ppm 0.1 ppm -- 0.02 ppm -- 0.1 ppm 0.02 ppm 0.2 ppm 2 ppm 25 ppm (Ceiling Value) -- -- 2 ppm --5 ppm 10 ppm Cigarette smoking can enhance the incidence of respiratory cancers from this or others of these substances or processes. Prepared by: G. Gruenwald, CIH Industrial Hygienist -12- -- CBY 3103826 . C 0Q22-L9 Cf?-rJ f<f /? / D ~ C</;zz7-nT % \ $ '; 3a*c/?;/c sCsqa /fe&2/bS /3kwz&j. /So/&z iSaCtUZ &/CX/L& C//Coc/=o,z/-j ~ybx/&AiS. x Zjo;22&J`C. /9x?gv/q x /SzxfK't'S? . //wc.K/&z .... rtc,> ... X CclTo^r %..../9bff*&assj' . * ~7ZX^^ Z)vttCfiv~j7ii 1 7k/G#{o?c^T4y<&s 6J'*/ .. t x5b&=W2*'C /?C40 A&~ //AjyC C/CC.ZiAG. _____ ,, ________ ___________ . ________ `Zv'^i&VA'/C //S. ^xf X Ch'c/,-; Gv&s&'U'ZJXi'S-S' C/zys~/?(Z/A/ iScfc*} .............. ........... . - .. ............... ............. fX i/ - 7 V TU'/- Sja*? * i4 ' V CBY 3103627 'eS^feE. c 00ZZ20 NI0S1I Recoilmendcd Standards Developed under the Occupational Safely and Health Act Substance Ammonia Arsenic Revised Exposure Estimates 500,000 1,500,000 Asbestos Eenzene Beryllium 2,000,000 30,000 Carbon Monoxide Carbon Tetrachloride Chloroform Chromic Acid Chromium(VI) 80,000 .15,000 Coke Oven Emissions Cotton Dust Emergency Egress from Elevated Workstations 10,000 230,000 Fluorides Hot Environments 350,000 Identification System for Occupationally Hazardous Materials Inorganic Lead Inorganic Mercury Noiso 150,000 Si Hen 1,200,000 Date Transmitted To D0L July 15, 1974 January 21, 1974 June 23, 1975 January 21, 1972 July 24, 1974 June 30, 1972 August 3, 1972 December 22, 1975 September 11, 1974 July 17, 1973 December 1, 1975 February 28, 1973 September 26, 1974 December 1, 1975 June 30, 1975 June 30, 1972 December 20, 1974 January 5, 1973 August 13, 1973 d X'-VAI - v. ^ > /S August *10, 1972 November 11, 1974 CBY 3103828 t 19 DEC. 1975 ^rifluoride, bromine, chlorine dioxide, chlorine trifluoride, dccaborane, ^ hydrazine, iodine, nitrogen trifluoricic , nitrotoluenc, i^cntaborane, "hTos-y1 fluoride, picric acid, propyl "nitrate, selenium hexafluoride, tetranitromethan ^tryl> trinitrotoluene (TliT) GROUP R: 30 JAN. 1976 benzoyl peroxide, carbon black, carbon dioxide, carbon disulfide, cyanide, dimethyl acetamide, dimethyl fornamide, hydrogen chloride, oxyeen difluoride, phosphorus pentachloride, phosphorus pentasulfiae, phosphorus trichloride, silica, sulfur hexafluoride, sulfur pentafluoride, sulfuryl fluoride, talc, thiram GROUPS: - ^ ' 27 FEB. 1976 . aldrin, AMTU, Guthion, boron oxide, Sevin, chlorodane, DDT, ethyl silicate, graphite, hydrogen peroxide, methyl isocyanate, mica, oil mist, perchloronethyl mercaptan, Portland cement, silici, soapstone, sulfur monochloride GROUP T: ` 26 MAR. 1976 2,4- D, Systox, dichlorobenzene, dichlorvos, diel&rin, endrin, EPN, ethylene oxide, heptachlor, hydrogen cyanide, lead arsenate, lindane, methyl formate, naphthalene, nicotine, paraquat, parathion, Phosdrin GROUP U: 23 APR.. 1976 benzene. Crag, malathion, nitric acid, nitric oxide, nitrogen dioxide, pentachlorophenol, pyrethrum, ronnel, rctenor.e, sodium fluoroacetate, strychnine, 2,4,5- T, TEDP, TEPP, thallium, warfarin, xylene GROUP V: 21 MAY 1976 acetaldehyde, allyl glycidyl ether, ammonia, chlorine, dichloroethyl ether, diisobutyl ietone, ethoxyethanol, ethyl mercaptan, ferbarn, fluorine, formaldehyde, furfuryl alcohol, Lsophorone, isopropylether, methyl mercaptan, sulfur dioxide, toluene, TDI )R0UP V: 18 JUNE 1976 ammonium sulfamate, butyl mercaptan, cadmium, carbon monoxide, coal tar pitch volatiles, otton dust, dimethylsulfate, ethylene imine, fluoride, methoxychlor, methycyclohexanone, ethylcyclohexanol, organo mercury compounds, sodium hydroxide, tetraethyl lead, tetra ethyl lead CBY 3103829 C 002222  _ HI03H-03HA STANDARDS COMPLETION PROGRAM URA>T TECHNICAL STANDARDS AVAILABILITY AND DATES BY CHEMICAL GROUP " . J>ates. indicate due date of projects by HIOSH Contractors i GROUP A: (Schedules estimated as of January 31, 197$) i DELIVERED acetone, antimony, methyl ethyl ketone, cyclohexanone. methyl isobutyl ketone, hydrogen ^sulfide,,manganese,MDI, nitroaniline, pentanone GROUP B: 7. . DELIVERED camphor, chloroacetaldehyde,. chloroacetcphenone, ethyl butyl ketone, mesityl oxide, methyl (n-amyl) ketone, ethyl sec-amyl.ketone, ozone, Fival GROUB C: ' DELIVERED acrolein, butyltoluene, cumene, cyclohexane, biphenyl, ethyl benzene, furfural,' methyl styrene, styrene, terphenyls, vinyl toluene GROUP D: i DELIVERED amyl acetate, butyl acetate, butyl acetate, n-butyl .acetate, dibutylphthalate, ' dimethylphthalate, ethoxyethylacetate, ethyl acrylate, ethyl formate, hexyl acetate, isoamyl acetate, isobutyl acetate-, methyl acetate, methyl acrylate,'methyl cellosolve acetate, methyl methacrylate, octyl phthalate, propyl acetate GROUP E: . DELIVERED allyl alcohol, emyl acetate, butyl alcohol, cyclohexanol, diacetone alcohol, ethyl acetate, ethanol, hydroquinone, isoamyl alcohol, isobutyl alcohol, isopropyl acetate, isopropyl alcohol, methanol, methyl isobutyl carbinol, propyl alcohol r GROUP F: . - ' ll* FEB. 1975 butyl cellosolve, butyl glycidyl ether, toxaphene, cyclohexene, cyclcpentadiene, . Bisphenol A, dipropylene glycol methyl ether, ethyl ether, glycidol, isopropyl glycidyl ether, methyl acetylene, methyl cellosolve, methylal, phenyl ether, phenyl glycidyl ether, propylene oxide, tetrahydrofuran GROUP G: . Ik MAR. 1975 butadiene, dioxane, heptane, hexane, ketene, -liquified petroleum gas, MAPP, methylcyclohexane, coal tar naptha, octachloronaphthalene, octane, pentachloronapthalene, pentane., petroleum'naphtha, propane, propylene dichloride, Stoddard solvent, turpentine GROUP H: 11 APR. 1975 benzyl chloride, bromoform, chlorobronomethane, chloroprene, dichlorodifluoromethane, dichloroethylene, dichloromonofluoromethane, dichlorotetrafluoroethane, difluorodibror.omethane, ethyl bromide, ethyl chloride, ethylene chlorohydrin, ethylene dibronide, fluorotrichloromethane, hexachloroethane, hexachloronaphthalene, methyl chloride, aethyl iodide CBY 3103830 c 002223 CLOSING CONFERENCE -- OSHA INSPECTION FOR 8/12/83 The closing conference with Rex McKinney, OSHA, was set for 1400 on 8/12/83. . Mr. McKinney arrived at the plant at 1230 and was brought in from the Main Gate at 1300. Prior to the closing conference there was some discussion on steps that we have taken since the inspection of 6/28-7/1 concerning employee physi cals. We stated that we plan to initiate yearly physicals (including medical history, pulmonary function test and chest.x-ray) for those individuals doing incidental work requiring them to remove asbestos insulation. Also-stated that we would not force an individual to take the chest x-ray. However, if they decided not to take the x-ray, then they would be required to sign a statement stating this. ' He also requested medical information on the two workers, R.V. Nicol and G.E. Hoyland, on which personnel monitoring was done while they were performing job of stripping asbestos. Information given was as follows: Last"Physical Pulmonary Function Test Chest X-ray Nicol 03/23/83 ,'-'08/81 Given -slip- at last physical Hoyland 11/17/82 11/17/82 Given slip at last physical Closing Conference Personnel present: Rex McKinney, OSHA Charles Davis, Pipefitter Safety Representative Greg Daues Dan Campbell Mark Riddle Bob Hammann Mr. McKinney started by stating that their tests showed 0.3 'fibers/cc which is well below the ceiling limit and therefore indicated no overexposure. He stated there were three possible citation areas. 1. Work practices/wet methods - 1910.1C01 C.2.i -------- ------------- ------------------ ------ We were cited as the workers did not wet down the asbestos while they were removing it. It is our practice to wet down the asbestos. He has a copy of our procedures which state this. Abatement period - immediate. .This has a.lways been our practice. _ 2. Personnel monitoring - 910.1001 F.2.ii '. Personnel monitoring must be done at intervals no greater than Six months. From the data that we have given him, this has not been done. Additional search for data will be made to see if we have indeed complied with this. Abatement period - immediate. , , ...^ ------ ----------------------- CBY 3103831 c 002224 Closing Conference - OSHA Inspection 8/12/82 (Cont'd.) Page 2 3. Employee physicals - 1910.1001 J.2 People working with asbestos -shall have a physical examination within 30 calendar days. Some discussion followed concerning this when we once again stated our opinion that this initial examination is to establish baseline data. We are willing- to accept data taken from earlier physicals as being the baseline data. He could not answer this other than to state that we would have to discuss it with his boss at an informal conference sometime after receiving any citations. His boss' name is Jack Fontaine and his phone number is 750-1727. -, We should receive the formal citation within two weeks by registered mail. The fifteen working day period for formally-contesting the citation will start the day after receipt of the citation. ---- CBY 3103832 C 002225 Volume 1, J?ou 5 ^Industrial lggtmt r mtitnr ft i- * v S. O **N + : t ;0 & September, 1980 Certification--Closer Look The field Industrial Hygiene network staff is relatively young in Monsanto compared with othei professional disciplines. With this in mind,J. T. Garrett, Industrial Hygiene Director, has explored in a two part article the subject ofprofessional certification and its impact on industrial hygienists and hygiene chemists. It is important for a Professional In dustrial Hygienist or Hygiene Chemist to be certified by the American Board,of. Industrial Hygiene (ABIH). In the eyes of others in the public health field, this signifies that the hygienist or hygiene chemist has acquired the training and skills to be called a true professional. In addition to this obvious benefit, there are several other benefits that accrue to Monsanto and to the hygienist or hyriene chemist who reaches this plateau in .iis or her professional development. These^ire in part: OSHA and NIOSH Relations: It is abundantly obvious that governmental agency representatives, including inspec tors, are impressed with the certification status of an individual and consider the programs that include certified profes sionalism as an important element su perior to those that don't. In addition, both OSHA and NIOSH encourage cer tification within their own hygiene staff and hygiene chemists and these agencies pay the necessary expenses as a part of doing business in this field. I'ft Professional Testimony: Governmental agencies routinely determine the techni cal qualifications of witnesses and other professionals in this field through their certification status. In many cases the first question asked of a witness is whether he or she is certified and in what speciality. Certification is, there fore, important to Monsanto not only as a symbol of achievement in the profes sion but also a symbol of quality in its In dustrial Hygiene Program. Program Recognition within the Profes sion: Programs are invariably judged by industrial health professionals in all dis ciplines by the degree of certification achieved by. the program participants. This is true in occupational medicine as well as industrial hygiene and will soon be true in the case of toxicology. Certifi cation of laboratories by the American Industrial Hygiene Association (AIHA) requires certification of certain of the laboratory professionals before it is granted. Certificadon in the field has, in fact, become essential to program recog nition. Advancement in the Field: Virtually all industrial hygiene programs have certifi cadon as one of the requirements for ad vancement. This is, for example, true in the DMEH Industrial Hygiene Section. It is equally true in published job offers.There are very few such offers that do not require certification or in-training status. This is true of OSHA and NIOSH offers in advanced civil service grades as well. For the above reasons and many oth ers certification for industrial hygienists and industrial hygiene chemists is an in telligent move. Asbestos and Monsanto The following is in answer to a ques tion posed by J. T. Roberts, hygienist at the Greenwood, NC location. The ques tion concerned {the Monsanto policy on asbestos use and possible inconsistencies between Monsanto policy and CED specifications for the material oncertain projects. 4tt. DMEH has found no formal,Avritten Monsanto "policy'' for asbestos .although there is a relatively long standing corpo rate ''guideline" which recommends that substitute materials be used where they are available and meet the requirements for the application. For some years now,, Monsanto has made a conscious effort to 1 remove asbestos from the existing work place and prevent its use to the greatest degree possible for new installations. Under this informal guideline, a substi tute material should be used whenever risks and cost are reasonable and process considerations are not jeopardized. Experience has shown that substitute materials have been used in the vast ma jority of cases, although there are some applications, even today, where a suitable , substitute has net been-found,.and as bestos must beused, PJaiHWfchdCED design engineers arr~aware of this guideline and its Intent and we routinely using asbestos substitutes where available and applicable. In addition, during the LPEC&E review process; DMEH nor mally checks this requirement for accept ability. : cw^itoam In our view, the spirit of the guideline is being honored through the corporate system-in essentially all cases. If you are aware of a particular situation which ap pears to be inconsistent, make your con cerns known to plant or CED project management and your'DMEH industrial hygienist. The "Monitor" is a forum for ideas, comments, and useful news relating to occupational health, issued by the Industrial Hygiene Section, DMEH, Monsanto, St Louis, MO. Ceiling Values--An Overview New TLV's Available Recently, R. A. Baxter, Manager In dustrial Hygiene/Europe, posed concern ver the seemingly inconsistent defini tion being used in the field for ceiling concentrations, and suggested some light be shed on the subject. DMEH has received the 1980 TLV booklets. They will be distribute.il in Sep tember. If vou don't get one'or need more, contact sour staff Ingienrsi. M2COS&H In Search of a Definition The inconsistencies Richard refers to are probably no more evident than in the OSHA health statutes. When one refers to the 1910.1000 section of the OSH Act, you can find two definitions of ceiling values. If referred to Table Z-l, the defi nition states vou: "...shall at no time exceed the ceiling value given for that material in the table." The second definition refers to Table Z-2 where an exception to the above explanation allows an excursion above the ceiling: "...up to a concentration not exceeding the maximum duration and concentration allowed in the column under "acceptable maximum peak above the acceptable ceiling concentration for an 8 hour shift"." This later definition more closely fol lows- the concept of a STEL described in the ACGIH TLV booklet. The ma jor difference being that most of the values in Table Z-2 don't follow the 15 minute duration criteria used in the STEL definition. Without belaboring the reader with the other specific OSHA standards, suf fice to say that certain standards define ceilings as that concentration which can not be exceeded as averaged over a cer tain duration of time. In a word, yes, there are inconsistencies in OSHA's defi nition of ceiling values, and, yes, many definitions exist for the concept of ceil ing values. limit (STEL) values by qualifying the conditions they seek to protect against, namely: irritation chronic or irreversible tissue change narcosis of sufficient degree to in crease accident proneness,, impair self rescue, or materially reduce work effi- "--detox- ----- -- - This rationale is compatible with DMEH's approach to this subject and should provide guidance-in determining ceiling levels for materials with no listing as such. The excursion factor table ap pearing below is a good source to consult when a question arises in this area. It's time to mark your 1981 calendar with a few important dates. The Mon santo .Management Conference o'n OccuT- ~pational Saletv and Health will be held "March 15-19th here in St. Louis. Thiswill be a joint conference with members present from the Medical, Industrial Hy giene, and Safety & Property Protection functions throughout Monsanto. As usual, we are all looking for interesting, informative, and, yes, even controversial subjects to present at the conference, so call or write vour respective contact in DMEH or S&PP and suggest topics you feel would be useful. It's not that far away! , Excursion Factors For all substknces not bearing C notation TLV 0-1 Excursion (ppm or mg'm ). Factor 3- TLV 1-10 - . 2 TLV 10-100 - " ' 1.5 TLV 100-1000 - " 1.25 The number of times an excursion above the TLV-is permitted is governed by conformity with the Time-Weighted Average TLV. Remembering that STEL's are guidelines, and recognizing that hypersusceptible individuals are present in the workforce, each location should judge acceptable ceiling levels for materials on empirical data as well as consensus guides. When a question occurs in this area, DMEH should be.consulted. Richard suggested in his inquiry that to minimize confusion when speaking of ceiling values, mention of the observa tion time would be appropriate. We at DMEH think this is a step in the right di rection. We also felt it appropriate to re view the fundamental concept of ceiling values so as to provide guidance and uni formity to its use in the field. Ceiling Concept The ACGIH introduces a judgmental approach for the short term exposure CBY 3103834 C 002227 (3lnbustrtal jEHorutar TtrerrgfurtT ffiolmtte 5, ffo. 7 (cinher 1984 cutaneous irritation of the skin and the sequelae of scratching. In Scotland, workers accepted this dermatitis as a condition of employment and labeled it the "badge of the trade". This condition results in approximately 10% of new glass workers leaving the job. However, it is not a disabling form of dermatitis. The cutaneous nerve endings mediate both pain and itch, so these modes of sensation are closely related. The stimulation of these nerve endings, following contact with the fibrous glass, result in the discomfort many observe. It is important to note that the larger the fiber the higher the potential for skin irritation. Conjunctival (eye) irritation and nasopharyngitis (upper airway irritation) have also been reported. Animal studies involving the inhalation of glass fibers have neither demonstrated pulmonary fibrosis nor the presence of pulmonary or mesothelial cancers and resulted in minimal macrophage reaction. Epidemiological studies have not Facts On Fiberglass You're Itching To Know demonstrated an excess in mortality, increased chronic bronchitis, the by Tom Blank presence of mesotheliomas or harmful tissue damage. Upper airway irritation The use of fibrous glass, as a replacement for asbestos in certain individual product applications. Major uses include acoustical and thermal appears to be the only respiratory system problem of any consequence. applications, has grown in recent years. Along with this increased use stems concern about health effects surrounding the use of fibrous glass. This review should help clear some of the misconceptions and fears. insulation and the reinforcement of plastics. However, an increased number of textile products are now being developed and marketed. The ' outstanding properties of fibrous glass include: chemical resistivity, heat The body of evidence summarized here has lead the ACGIH to classify fibrous, glass a nuisance dust. Following is a list of precautions and recommended ` safety/industrial hygiene practices: Glass is one of the oldest and most versatile materials used by man. However it wasn't until 1841 that man developed the technology for spinning resistance, non-flammability and resistance to microbial degradation. Since these fibers are made of glass, they have an inherent brittleness that can be reduced through the use of coating 1) Clothing should be loose-fitting and changed on a daily basis. They should cover the extremities leaving few areas of the skin exposed. glass fibers. The Germans were the first to use fibrous glass for heat insulation. This resulted from a shortage of asbestos during World War I. In the I930's, two U.S. companies, Owens Illinois Glass Company and Corning Glass Works developed a commercial method of agents '(4 to 14% by weight), including binders and lubricants. ^ 002^28 2) Fibers should be washed off with ample amount of lukewarm or cool Many of us have experienced the water. Showering, f.ollo. wing. a "burrnngTficKingTand/or pricking- ----------------specifictask or work shift is sensation from handling fibrous glass, ' advisable in addition to a fresh whether at home or on the job. The change of clothing, fiberizing glass. Since that time, fibrous glass has been used in over 35,000 resulting dermatitis, generally observed, _ -- is caused by the transient mechanical, GBY 3103835 (Continued on page 2) The "Monitor" is a forum for ideas, comments, and useful news relating to occupational health, issued by the Industrial Hygtene.SeckHi, DMEH, Monsanto, St Louis, MO. Quality Control for the Occupational Exposure Module of MEHI by Paul Easlerday As p;u i ol any computer data collet tiou svsietn it is essential that the data entering the system is accurate. The saving "garbage in, garbage out" is apptopriaie lot computer systems where no provisions have been made to verily the accuracy of the data generated. With tlie exponential growth of data in MEHI. a need was identified to verih the accuracy ol the data. Based on this need I)MLH has developed a program designed to ensure data entering the MEHI system is accurate. The MEHI quality assurance program has been implemented to determine the accuracy of the MEHI header, work, and industrial hygiene records. This program has been designed to provide the plant immediate feedback concerning the quality of the data in their master files. This will provide an error rate lor the records that were entered during the previous calendar quarter, and will allow the plant to observe the types of errors, if any, that mat be unique to that location. Both direction in correcting errors and information on how effective the program is in collecting accurate work history and industrial hygiene data will be returned to the plant. Each quarter the plant will be sent an evaluation report based upon MEHI records that were entered during the previous quarter. The report will contain up to five computer printouts: 1. all new header records for hourly emplovees, 2. all new header records for salary employees, 3. a random sample of work records for hourly employees, 4. a random sample of work records for salary employees. 3. a random sample of industrial hvgiene records. The number of printouts that each plant will receive will depend on whether header, work, or industrial hygiene records were entered during the previous quarter. As part of the MEHI quality assurance program, it will be the plant's responsibility to compare MEHI records on the computet printouts with plant records that dottimenl all work histnrv changes for each emplovee. '1 he molds may be personnel records, payroll records, and/or departmental logs, as long as they are an original, accurate source of information (not the MEHI keypunch schedules). For industrial hygiene data, compare the MEHI records on the computer printout with the original monitoring forms (this is not the 10. 20. 30 record layouts! at each of vour locations. Whatever the source of information, the objective will be to determine the accuracy of the MEHI with respect to the plant records. c .SS-, t. - - -WCMavLi fx1---'. - T` Health evaluations including responding to proposed-health regulations, epidemiology (morbidity and mortality)'heeds.-and responding to potential litigation require a data base that is both accurate and verifiable. We believe this program is a first step at answering this expressed need. 11 you have any questions concerning the program, contact your DMEH industrial Knnnlv epidemic, ol Mi liing and iiiilalion have been icponed when work clothing has been included with other lamih laundry in the lamilv washing machine. It is suggested that clothing he washed by itseli in a tub or basin. The tub oi basin should then he thoroughly rinsed. Additionally, rubber gloves should be worn In the blunderer to prevent further imidetue of dermatitis. in conclusion, evidence indicates that fibrous glass causes transient, mechanical, cutaneous irritation ol the skin and the sequelae of sevau hitVg anti in severe instances upper respiratory irritation. Long term effects of fibrous glass exposure have not been reported. Should you have anv questions, contact your DMEH industrial hygienist. OSHA's Position on Sampling When Wearing Air Supplied Hoods Ay joe Wolfsberger "Mr. Easterday, the computer informs me that you've been kicking it." Fiberglass (Cont.) 3) It is recommended that workers not use air hoses and/or brooms to clean themselves. Such actions could result in driving the fibers deeper into the skin. ' 4) The use of personal protective equipment should include some form of gloves for hand protection and the possible use of a dust respirator to reduce the potential of upper airwayTrritation. A phenomenon known as "hardening" occurs in fibrous glass workers from which they no longer exhibit signs of skin irritationTrom exposure to the -fibers? - 5) The laundering of work clothing creates yet a different problem. On March 30. 1984 OSHA published a long awaited revision to the Industrial Hygiene Field Operations Manual (FOM). Of particular interest is a change in the requirements for sampling when employees use air supplied hoods. In Chapter II, Section F(3) the manual directs the OSHA industrial hygienist that: "In sampling' for employee exposure to air contaminants generated during work operations where air-supplied hoods are used (i.e., painters or foundry chippers and grinders), ensure that the filter cassette is located inside the employee's hood." The FOM also specifies that when sampling for air contaminants generated during burning and welding operations the filter cassette should be located inside the employee's welding hood. Sampling inside personal protective equipment (PPE) worn by employees can provide-useful information regarding the effectiveness of,the PPE. This information can be invaluable when showing the effectiveness of PPE versus other control measures. Developing a valid sampling protocol and strategy. (Continued on page 3> 2 CBY 3103836 C 002229 OSHA (Cont.) liimf'tT. can be very difficult when dc.ilinK with lespiratori protection otho ili.rn air supplied hoods. When these sampling technique problems are oven ome. this tvpe oi sampling will provide a tool to evaluate the elleiti'eness of PPE programs. Until ij i (<.isibl< to pet form tfiis tvpe of samplim I l,,, all tespnaiors remember the OSHA 1OM's llimtive f or sampling emplmee: st aring ait supplied hoods and welding helmets. there to some of our mechanics, there probably was a potentially even larger ncn-occupattonal threat from people who handle this material infrequently at home. I know I personallv do mv own routine maintenance on my vehicles and even tnv lawnmower (forget the lawnmower - I lied) and I have had a few boms of dermatitis with certain lubricants. The EPA advice certainly got ms attention and I have now saved enough plastic milk jugs to dispose of a year's worth of oil changes and I now lake them to the recycling center at my local ness, irritation, and possiblv more serious toxic effects. DON'T over-use waterless hand cleaners, soaps or detergents. Thev can remove the skin's natural pro tective barrier oils. DON'T put oily rags in pockets, or tuck them under a belt: this can cause continuous skin contact. DON'T pour used engine oil on the ground, or down drains and garage. I haye even broken down (with sewers: it is a violation of federal Jackie Gaul Promoted Av SliWPaul some subliminal encouragement from my wife) and discarded-some of my favo rite wipe rags. that were beyond the laundering stage. I should probably know better anyway front my . safety law. EPA encourages collection of used rriotor oil at collection points in compliance "with appropriate state and local ordinances. ja'eKiV^'ah'U'lhe''ChffW)lal"e' Bayou T. " background (hat'oil soaked rags are nor Plant inditstrial hygienist.' was recenth good to keep around from a fire risk (nomoied to Distribution Operation^t-r ..-I standpoint, but it's funny how a lot of Superintendent ant]be Texas Cats Plant. . ^ safety/health^.prqfe^ionals do .things at., home that they wouldn't even consider at A Brief History Of Detector Tubes In the past, some network industrial fngiene professionals'have been work. I guess we shouldn't expect our workers to be much"3ifferent.--x ----- by Gerry IV. B Hitler 11 mi exited with the lack of mobility in the )H area. Jackie s .promotion has olleied some encouragement that they tn.n he considered for other , e.ntfl - - i-jp -t assiynnients. id -c:-. e . Here are some helpful DO's and - !T(5ne of the most common direct DON'T's supplied by EPA for handling used motor oil that you may want to pass along 10 yotir maintenance workers and reading tools used by industrial hygienists for tfye determination of gases and vapors in workplace atmospheres is weekend mechanics. the detector tube. The impetus for then- development first came from the mining U c congratulate Jackie on her -.............. - Recommendations pmniotion and hope that others mav be \ . r . " " 'industry where the use of animals usually while mice or canaries was the considered for assignments which hioaden their experience and improve DO's .. ,, ,, , .___ . only means of providing an immediate warning of dangerous carbon monoxide tlu i. organizational mobility if they ' i lmose to pursue other career paths. DO follow work practices that mini^ ^-3TM^ of skin exposed, build-up. Most other techniques available prior to 1920 used conventional ________________________ _______ - EPA Chemical Advisory On Used Motor Oil and the length of time used oil stays on skin. DO thoroughly wash used oil off skin as soon as possible with soap and water. A waterless hand sampling techniques and subsequent laboratory analyses, often hours or even days later. Even.thg.use of the simpler colorimetric analytical procedures could not yield instantaneous evaluation of the carbon monoxide levels in the mines. by Glenn Hachey A few months back EPA issued one of what it refers to as "Chemical Advisories"., I hese advisories are designed to give indi viduals and organizations information to make informed decisions on how to safelv handle chemicals. The advisory stated that: cleaner can be used when soap and water are not available. Always apply skin cream after using water less hand cleaner. - DO wash oil-soaked clothing before wearing it again. Discard oil-soaked shoes. Two Americans. A. B. Lamb and C. R. Hoover, patented a detector tube for measuring carbon monoxide in 1919. It was based on the colorimetric reaction of carbon monoxide with iodine pentoxide and filming sulfuric acid. Pumice was used as the carrier material and, along with the reagent chemicals, was referred In .i labi.iaj.onj study., mice developed vkiit < .nilit after their skin Way-exposed '' t" used motor oil twice a. week without Ik-iiis; hashed off. for most of their life sp.m, While this one,study is-not con- ;, ilnsive. substance found to cause can cel in l.ihoratorv animals may also cause camel in htimansi. DO use gloves made from nitrile, Neoprene, Viton or other material that oil cannot penetrate, if practical for your kind of work. DON'T's `tfer' 3103837 DON't use-kerosene, thinnery or solvents to remove used motor oil to as "Hoolamite" and packed into thin glass tubes. As air containing carbon monoxide was drawn through the tube by some sort of pumping device, the ''Hoolamite" changed color to green. The intensity of the color could then be related to the concentration of carbon monoxide. -I- '. " V ,. :' Although this was a significant "e irlt that although there might pos They remove the skins natural advance in the field of industrial hygiene sible be some occupational exposure out protective oils, and can cause dry (Continued on page 4) 002230 ' ST Detector Tubes (Cont.) monitoring, it was not until the mid-1930's that another detector tube emerged, this time for hydrogen sulfide. The major stumbling block in the advance of this monitoring technique was the lack of adequate technology in preparing the colorimetric reactive fillings for the tubes. Many of the common wet-chemical reactions that could be used for gases and vapors could not proceed in a dry-medium such as that in the tubes. Additionally, many reagent mixtures were not stable over a ... long period of time for them to have the durability- and reliability necessary for practical use. Inevitably, these problems were overcome or at least 'circumvented because of the potential speed, Cross-interferences are common, and the hygienist should take care that he doesn't use a particular tube that is affected by nontarget compounds known to be the atmosphere he is monitoring. Deviations in the amount of air drawn through the tubes from that for which they were designed can yield errors. Nevertheless, detector tubes remain a valuable resource for the immediate assessment of air quality as long as their use is supervised and their results are interpreted by trained industrial hygienists. Field Validation Entries into MEHI used b\ DMEH to audit method perfot tnatice and validation frequent v (or the purpose of method valutas classifier assignment. With respect to the "Validation" (V) .determination tvpe only, data should be entered with the following modifications: 1) Multiple "3(1" cards on the Data 1 ransmittal Form mat be submitted for materials with the same CAS No. and the same Determination No. 2) In field 34 (L'G) of the "30" card use "B" for background samj)le(s) and use "S'" for spiked (validation) sample(s). 3) Record the appropriate convenience,*-and simplicity that this , " techniquexould provide. '.'by Paul jM Jeannol ' > concentration levelts) for the background sample(s) in the In the early T9oOss, more suitable -- "Field:validation" is an integral component of.a quality industrial "Results" fields using the appropriate unit code, using "B" chemical reagemS liripregriate&'on " v' * hygiene monitoring program. The granular supports were prepared and scheme(s) provides a means to determine new detector tubes for other vapors were n Si&eJtfng-term effectiveness^performance developed: alcohol, benzene, and water of an entire monitoring method in the for background in field "34". 4) Record the calculated theoretical spiked level(s) for the appropriate vapor. In 1952, Grosskopf reported on tubes developed for determining carbon disulfide, chlorine,-methyl bromide, .actual workplace environment where interfering"components may "exist. As such, if is equally as important to sampling period in the "Result" fields using the same unit code as f1 : the background,.using "S" for nitrous fumes,' and'sulfur dioxide. document-into MEHI the'levels and 'IT: spikedn field "34". Concentrations were indicated jn different ways as detector tube technology began .to grow. In some instances," color changes were compared directly with -charts Of-color tints:4n ,lother cases, the concentration was "'f.u recoveries'of the field validation sample(s) as it is to document the field data itself. In this regard, a temporary and somewhat unwieldy procedure for _ inputting field validation data into MEHI, was described by Jeannot, P. M., 5) Enter the spike recovery for the spiked sample(s) in the "Result" fields using the Percent (PC) unit code, also using "S" for spike in field "34". indicated .by, the length-of-stain on the "Field Validation Into MEHI", Industrial 6) Note: Sample types for validations indicator gel. Throughout the 1960's Hygiene Monitor Volume 4, No. 3, must either be Personal (P) or and 1970's, the use of this form of . March, 1983, p. 3. General Area (G) on the "10" card. monitoring greatly expanded as the number of materials which could be This present article will describe a . Example: ._ .. detected increased. Today, -over 200 - simpler inputting system which will allow Parallel Background Result - 0.5J ppm different types of detector tubes have . both DMEH and the locations greater 1st Validation Level Spiked - 1.03 ppm been developed and marketed by such capabilities to retrieve and evaluate past 1st Validation Result (Reioseni - iC.o.VT companies as Drager, Matheson- validation data. This system should be General Area Sample - XW Wall ot Kettle Kitagawa, M^^nd Bgn,dix-Gastec. integrated into the plant MEHI program No. 4 Both short term, tubes for task pr SXEE - as soon as practicable. The data will be DMEH Method Number - `3"S1A sampling and long term tubes for TWA sampling are available. More recently, diffusion detector tubes which require no pumps have come into use, such as the ones Drager makes for ammonia.. hydrogen chloride: and hydrogen ' sulfide. CBY 3103838 While detector tubes remain' important aids to the industrial hygienist, they are not without .their limitations. There arelstiKl mahy 1 ' r`: materials for which detector tubes are not available or feasible.' Alsorrrtany`,iifUjf`T the colorimetric reactions.frequemlv r 1 -Other ijiforrh|ittbn"fpr: validation samples should be entered onto the Data Transmittal used in the tubes determine only classes Form, as appropriate. of compounds or functional groups and mav not provide the specificity desired Please recall that field recoveries should not be used to correct field data for MEHI emr\. --- ' c 002231 Volume 3, 'Number 7, July 19801 Monsanto ENVIRONMENTAL ANALYTICAL SCIENCES CENTER MONSANTO RESEARCH CORPORATION DAYTON LABORATORY A SYNOPSIS OF MONSANTO AND ENVIRONMENTAL PROTECTION AGENCY ACTIVITIES --------- -- -- IN THE IDENT-IFICATIQN^AND-CQNTROL OF PRIORITY POLLUTANTS Since late 1977, both the Environmental Protection Agency; (EPA) and Monsanto Company have been very active.in-identifying. and quantifying the presence of the 129 "priority" pollutants in our plants' process and discharge wastestreams. This article presents a,brief history.,,of_both..EPA's and Monsanto's activities, the finding^ as,, 6f the present, and future regulations expected. histor^Tof^tiS^'pri^iW" "poiXinANTs" ; ** i J I In 1975, a group of environmentalists and public interest organizations spearheaded by the National Resources Defense Council (NRDO filed suit against the EPA for failing to issue regulations limiting the discharge of toxic pollutants. A consent order, which was entered in this suit in 1976, became known as. the "Flannery Decision" and committed the EPA to develop effluent limitations for 21 major industries, covering a list of 65 chemical classes, from which specific chemical species were selected!- A fist of 129 species have"become known as the. "priority" pollutants. In addition, effluent limitations for these priority po 1 lutahfs'afe"`t^'be"`based oh '"best available technology1" (DAT) . Thus, regulations to be issued have become known as BAT limitations. EPA AND MONSANTO DATA GATHERING EFFORTS Screening Studies When the consent order was agreed to, little or no information was available on -the `existence of these pollutantsin industrial discharges .---In order to do the vast job before them, EPA settled on a two-phase approach. In the first phase, analytical-methods referred to as the "Screening Protocol"-were used to collect data. These methods have a high probability of identifying any of the priority pollutants -present-in a stream-in-concentrations greater-than-10 ppb provided the matrices are "clean" (i.e., contain very few other compounds). Further, these methods- permit.-an accurate measurement-othe-amount_J3_any.of the observed species if the methods are validated in the matrices encountered. But for reasons of cost, this validation was not performed by EPA in this first phase of data gathering. Consequently, little is known about whether individual pieces of ^data collected using the "screening" protocol are either qualitatively correct or 'quantitatively accurate. -' CBY 3103839 1 - S - i b; - c 002232 ^ ** Environmental Health Letter, August 15, 1980 tumors in one or more animal species or to induce benign tumors that are generally recognized as early ' stages of malignancies, and/or if positive epidemiologic studies indicated they were carcinogenic. Although the CAG has determined that there is substantial evidence of carcinogenicity for each chemical substance on the list, the data varies to some extent with respect to the scope and quality of the studies." The EPA list was drawn up primarily for use by its own offices. Here, then, is its list of chemicals having "substantial evidence" of carcinogenicity (meaning evidence provided by animal tests that demon strate the induction of malignant tumors in one or more species or of benign tumors generally recognized as early stages of malignancies): : ` ..Mflphtton* 3W#thylcholanthrn*j Mtthy! MttftantsulfonaU; N-Merhyi*N'*nitro-N-fiitroioauantdin` Mattwithiouneii' Mitomycin C Muttard Gil; 1-Naphthylamina, technical oradi: 2*Naphthylamina; Nickil and Nickel Compounds: Nltrooen Mustard and its hydrochlorldes NItropen Mustard N-oxlde and Its hydrochloride; 5-Nltro-o-touidlnt{4-Nitroquinoline.lH?xidt. 9 MUSMr0 *"d Pentachloronltrobenzene: Phanaeatin-Pntvrhinrinata* ninh.nui.. *..#T-rr_*P5i.________ _ ... . In publishing its "candidate liSt,"OSHA emphasized that it was a tabulation only of chemicals desig nated for further scientific review and possible identification, classification and regulation as potential occu- pational carcinogens. . ,, , . The list does not mean that OSHA has determined that a substance is carcinogenic or that regulatory action on the riibstanceis necessary, nor is such a listingintended as a pre-classification warning, OSHA emphasized. In its notice in the Federal Register, OSHA states: "It is OSHA's view that the compilation and publication of this list of substances accomplishes the following: informs the public atthe very-first step in OSHA's standard-setting process that a substance is a candidate for closer scientific review; makes available to the public the data base for substances OSHA is Considering for. further scientificreview; reduces the number of substances to be subjected to such a review; guides the research community in focusing its resources qn those substances for which there is a need for testing and.further research; stimulates early public comment regarding the availability and appropriate ness of new or additional scientific data; and, over-all, assists OSHA in setting of priorities and selecting of- substances for regulation." -- ~~ ^---------------------------- - ;. Remember again that OSHA's list does not duplicate any of the chemicals on the EPA list and does not-include any substances currently being regulated by OSHA as carcinogens. With those caveats in mind, here is the OSHA chemical candidates list, which again the agency empha sizes is not an indication of carcinogenicity but merely indicates the need for closer scientific review (synonyms are used here where they are more familiar): Acanaphthene, 5-nltro-; methanecarboxamide;4-Acetylaminobiphenyl; Antol; 3-Amlno 4-cthoxyacetanilide; 3-Nitro-p^cetophenetlde; Aniline; Aniline, N,N-dlmethyi-p-nltroso-; Aniline, N,N-dimethyl-p-(m-tolylizo)-; Aniline hydrochloride; Aniline, N*methyt-N-nitroso-; Miclr- ler's Bile; Dipsone; Aniline, 4,4Mhiodl-; 2,4,6.Trfchloroanlline; Amlnomesltyiene; p-Creildine;2-AminoH- nitroanisole; Anthraquinone, 2-amlno;asphalt;azobenaene. - -------------- 2,4-Oiaminoanlsole sulfate; Benzidine dihydrochloride; Benzimidazole. 5-nltro-; Amlben;Benzoyl nydrazlde; Michler's Ketone; Qulnone dioxlme; Olacetylbenzldine;Diaminobenzldine tetrahydrochloride; DL Ethionine; Enthionine; Cirbimic acid, bit(2-hydroxyethyl)dltnio-, monopotassium; Carbazole, 3-emlno-9-ethyl;o-toluidine, 4-chloro-, hydrochloride; C.l. Direct Black SS.disodium salt: C.l. Direct Blue 6, tetri- sodium silt;C.I. Olrect Brown-95;C.l. Disperse Black 6, dlhyarocnioride; C.l. Disperse Orange 12:'Cl. Solvent Orange 2; C.l. Solvent Vellow 1; C.l. Solvent Yellow 3; C.l. Solvent Yellow 34; Benzene hexachloride. Meehloroathamlna hydrochloride; Acetomathoxen; p-NItroso-N-phenylinlllne; Diphenyinitrosamine; ethylene glycol bis (chloromethyl) ether; TDE; PjP'-Ethyl-DOD: beta-Hydroxyethylhydrezlne; Ether, 2,4-dichlorophyl p-nitrophenyl; Vinyl Bromide; p,p'-DDE; Pluoren-9-one, 2A,7<4rlnitro-; Ruorene, 2-nitro;Nltrofurezone;sym-DImethylhydrizIne dihydrochloride; Hydrazomethane; Metnylhydrazine monosultete; . Hydrazine hydrate; phenylhydrazlne hydrochloride; Hydrazine hydrogen sulfate; Cupferron. Deearbazlne; m-Tetrachlorophthilonltrlie; Mlrex; Nephtnylemlne mustard; Peracetic acid: C.l. 76555; r-Chlorophana-l,3-diamina; 4-Chloro-l,2.benzenedlamine; 1,2-benzenedlamine; 1,2-Benzeneoiimlne dihydrochloride; C.l. 76070; Tetrachlorvinphos; Methyl phosphate; HMPA; Picloram;N^i'.DInltrosoplperazlne;Bisphenol Adiglycidyl ether; Isonltropropane; Phenezopyridlne hydrochlorida; Quinoline; Quino line, 8-nltro-; Carbamylhydrazlne; Carbamylhydrazine hydrochloride; Cryogenenine; Diethylstilpestrol diproprionate; Terpane polychlorinate;: Daminozlda. '.> Sulfamethoxazole; Ethyl sulfate; Ethyl tellurac;PCT; Entramln; Procarbazine hydrochloride; m.Toluenediemihe;o-Toluidlne; o-Toluidine, 5-chloro; Trlfluralln; Uzacll, 2-thlo Monuron; N.N'-DlethyIthlourei; TMTU; N.N.N'-Trlmethylthiourea. .vi;'w.i; i. trr . --,, . ; . , 'if. ; 12 U.S. AGENCIES TO INCREASE ENVIRONMENTAL HEALTH RESEARCH SUPPORT NEXT YEAR:. . . ;s;.. : .v..`.i-ib.u..: - : - . f--->; j.~ Total Federal agency funding for environmental health researchin the fiscal year starting Oct. 1,1980, is projected to $727.7 million, an increase of $22.2 million over the current fiscal year (3.1 percent) and an'- "* * * * * 1 y ..1 ... , i;. - .. r vrv Uv rtRfcRJittWn tJ.'ii* iTWri Ltr v.-s, *; ? C 00Z233 "r 3l0,8' J.E. Fox, LP&S 0-22 - Texas City October 27, 1980 TELEPHONE CALL FROM TEXAS CITY HARBOR MASTER J. A. Glass 0--22 D.E. Kaldenberg 0-7 Fred Herzog WG Gordon Lunsford 0-21 J.T. White FD D. N. Campbell 2R-9 On Friday morning, October 24, 1980, Mr. "Doc" Holbrook, Texas -City Harbor Master, called concerning the organic vapors that entered our plant from the south or dock side the previous night. Mr. Holbrook stated that he had been visited by the County Health Unit concerning the problem and he was interested in any infor-, mation we could provide to help him trace down the source of the contaminants that entered our plant. I provided him with the time, wind direction, wind speed, and the locations where it was entering our plant from his property. He appeared cooperative and concerned about the contaminants and'stated that he. would definitely try. tp.find the source of the material and try to see that it did not happen again. - Mr. Holbrook said that he has someone on duty around-the-clock in the Harbor Master Office and they would be happy to help up. try to run down any contaminants that were coming from his direction. He left his telephone number which is 945-5011. He asked that we call him at any time that there appeared to be a problem from the dock areas. Mr. Holbrook.stated that one of their potential problems is the flare located near the new ARC0 dock. On several occasions, this flare has either blown out or has been turned off. He asked that any time we have a problem would we please first check to be sure as to whether the flare is lit and if it is not, to Call it to his attention and he would see that something was done. br CBY 3103841 c 002234 Pupaiod by D io T e c h n o io g y . inc. UPDATEACCORDINGTOCURRENT FEDERAL ANDSTATE REGULATIONS I Asbestos Workers Examinations Asbestos workers will be given the routine physical examination every 12 months, and in compliance with OSHA the following is done: 1. Chest X-ray, PA and lateral views, prior to examination by doctor, for comparison 2. Pulmonary function test 3. Interval history 4. Hemoccult slide (not required by OSHA) 5. Fasting lab is optional 3/tl ft c 002236 CBY 3103843 110-2 - ftUlCS AND UiGVIATiCMS Institute lor Occupational safety and Il-aith. and to authorized representalive's of *:thor. (2) Employee access. Ev/ry employee and former employee shal'/hive reason able accc.-s lo any record A-sqwired to be maintained 'ey subparagraph (1) of this para erauli, which indicates the em ployee's cv.a exposure Washestos fibers. t3) Employee notififation. Any em ployee found to have fc/en exposed at any time to airborne concentrations of asbes tos fibers in excess/of the limits pre scribed in paragraph (b) of this section shall be notified inheriting of the expo sure as soon as practicable but not later than 5 days of the/finding. The employee shall also be tirnay notified of the cor rective action bomg taken. txvmtiifiiim--m cenercl. Tne employer shall provide or make tions. Records ch-Jl bo retained by employers for at least 23 years. (ii) Acceis. The contents cf the rec ords of the medical examinations required by this paragraph flail be made available, for in spec ion ar.c! cc.'yh'g. to the Assistant Ec-cictary cf labor for Occupational Safety ar.d Health, die Director of NIOSII, to authorited physi cians and medical consultants cf cither of thc-m, and, upon the request of an em ployee or former employee, to Iris physi cian. Any physician who conducts a medical examination required fcy this paragraph shall furnish to tire employer of the examined employee ail the infor mation specifically required by this paragraph, and any other medical in formation related to occupational ex posure to asbestos fibers. Inst rue! ion section has been levised ac cordin'-:!;? Minor editorial changes have also been made. 1. Section 9-1.101 "rope of truerart, is re. isc-d to read a: <>flews; 5 0--1.111 Scop- tii ;irl. Tills subpsrt describes the Atomic Energy Commission Procurement Regu lations and the AFCPR Temporary Reg ulations. It also describes exclusions from the AECPR as contained in the AEC Procurement Instructions. 2. Section 9-1.102 Establishment of AEC Proc;irene?it Regulations, is revised to read as follows: 9--1.102 Eslnfilhlmie-at of the AEC Trocarrincnt fiegufrlions and the AECPR Temporary Regulations. 9--1.102-1 AEC Procurement Regula 'available at his cost, medical examina 3. A new 5 1910.10 is added to Subpart tions. tions relative to exposure to asbestos re B of Fart 1310. reading as follows: / (a) The AEC Procurement Regula quired by this paragraph. (2) PriTlaccmev.t. The employer sliail 1910.19 Asbestos provide or make available to each of his Section 1910.93a shall apply to the ex employees, within 30 calendar days fol posure of every employee to asbestos lowing his first employment in an dust in every employment ar.d place occupation exposed to airborne con of employment covered by 51310.12, centrations of asbestos fibers, a compre 11910.13,11910.11,5 1310.15, or 5 1910.15, hensive medical examination, which shall in lien of any different standard on ex include, as a minimum, a chest roent-) posure to asbestos dust which would eenegram <posterior-anterior 14 x 17l otherwise be applicable fcy virtue of any inches), a history to elicit symptom-! of those sections. at-rlog7 cf respiratory disease, and Effective date. Foragraph (b) (2) of pulmonary function tests to include 3 1910.33a shall become effective July 1, forced vital capacity (FVC) and forced 1976. Ail other provisions of Si 1019.33a, expiratory volume at 1 second (FEVi.t), 1910.93, ar.d 1310.13 shall become effec tions (AECPR) are hereby established. (b) These regulations implement and supplement the Federal Procurement Regulations (FPR) and are a part of the Federal Procurement Regulations System. (c) The effective date of FPR issu ances throughout AEC will be the date indicated in the respective issuances unless otherwise provided in the AEC Pro curement Regulations. (d; The effective date of AECPR is suances throughout AEC will be the date indicated in the respective issuances. (3) Annual examinations. On or be tive July 7, 1972. The current emergency 9-1.102-2 AECPR Temporary Rcgu- fore January1 2313, 419573, ari3 at least am temporary standard remains hi effect latlon!. iiuslly. thereafter, every employer shall until July 7, 1972. (a) The AECPR Temporary Regula provide, or make available, comprehen (Secs. 0, 8. 84 St.-.t. 1533. 1533; 29 U.3.C. 655, tions are hereby established. sive medical examinations to each of hi; 657; 29 CFit 1919.4; Secretary ot Labor's (b) These rcgulnticns implement and employees engaged in occupations ex-1 Order No. 12-71, 36 RK. 8754) supplement the Federal Procurement posed to airborne concentrations of as bestos fibers. Such annual examination shall Include, as a minimum, a chest Signed at Washington, D.C., this 2d day of June 1972. Regulations Temporary Regulations. They also contain policies and proce dures initiated by the AEC which are roentgenogram (posterior-anterior 14 x O. C. Guenttie?., expected to be effective fer a period of 17 Indies), a history to elicit symptom Assistant Secretary of tabor. . 6 months or less. atology of respiratory disease, and pulmonary function tests to include ' [IP. Doc.72-8574 Filed 6-6-72:8:48 am] (c) 'the effective date of the FPR Temporary Regulations issuances forced vital capacity (FVC) and forced throughout AEC will be the date indi expiratory volume at 1 second (FEVj.t)jp cated in `ho respective issuances unless (4) ` Termination of emplnimrni. The \ Tills 41--PUBLIC CONTRACTSemployershall provide, or make avail- ) otherwise provided in the AECPR Tem porary Regulations. ' able, within 30 calendar days before or J AND PROPERTY MAMAOEMEUTafter the termination of employment of / id) The effective date cf the AECPR Temporary Regulations issuances any employee engaged in an occupation/ exposed to airborne concentrations of) asbestos fibers, a comprehensive medical' examination which shall indude, as a minimum, a chest roentgenogram (pos terior-anterior li x 17 inche*)** history to elicit symptomatology ofcssspiratory disease, and pulmonary function tests to include forced vital capacity (FVC) Chapter 9--Atomic Energy Commission PART 9-1--GENERAL Subpart 9--1.1--Procurement Regulations Miscellaneous Amendments throughout AEC will be the date indi cated in the respective issuances. <e) The AECPR Temporary Regula tions are a part of the AEC Procurement Regulations and the Federal Procure ment Regulations System. Adi references to the AEC Procurement Regulations or AECPR in 5 3-1.103 through 9-1.109 of this subpart shall be deemed to include and forced expiratory volume at 1 second The changes made in AECPR Subpart the AECPR temporary regulations. (FEVi..). ' 9-1.1, Procurement Regulations, have 3. Section 9-1.103 Authority, is revised (5) Recent examinations. No medical been made in order to establish the to read as follows: examina: ion is required of any em ployee, if adequate records show that AECPR Temporary Regulations, which arc a part of the AEC Procurement Reg 9-1.103 Authority. the employee has been examined In ac ulations ar.d the Federal Procurement The AEC Procurement Regulations are cordance with this paragraph within the Regulations System. The AECPR Tem proscribed by `he General Manager, As pa<=t 1-year period. porary Regulations implement ar.d sup sistant General Manager for Administia- ,5) Medical rccords-r-(i) Mainli plement the FPP. Temporoiy Regula ne -ce. Employers of employees examined' tions. They also certain policies r.r.d pursuant to this paragraph shall cause procedures initiated by the A^C which to be maintained complete and accurate are to be effective for a period of 6 . records of all such medical examina months ov less. The AEC Procurement tfou. or the Director, Division of Con tracts of the AEC, pursuant to the autkarity of the Atomic Energy Act of 1354, ar.d tin Federal Property and Adminis trative Services Act cf 1949. FcbESAt REGISTER, VOL. 37, NO. 1IC -V.'EmfHOVf, JUNE 7, 1972 O 002237 CBY 3103844