Document NEaqDkM67ndJ9ZqveDo67vz08

*0** * U S * INTEROFFICE CORRESPONDENCE GA F Corporation TO Hr. a. r.--.HnM. location New York mort Vr. P.FI. Herbst location Eria Lake b-02 PLAINTIFF'S EXHIBIT GF-I9I5 Mr j >-, - oati January 7, 1972 ce Flessrs. tf. Pegs, Joliat L. FanauF, Nee York J. Jiisohl, Erie Lake supjcct C.S.H.A. COMPLIANCE In raply to your December 30, 1971, on the Subjact, I submit the folloslng report by subpart s A. The purpose and scope plus the ateaning and implications of the O.S.H.A. Standards has basn discussed aith each involved member of the staff continuously since the receipt of the first information on the project. Each staff meaber has received a copy of tha federal Register, volume 3b, No, 10b, part 2, dated Saturday, nay 29, 1971, aith an explicit instruction that tha subparts applying to their particular area of control be read, understood, and implemented Immediately. 8. Does not apply to this location. D. The Plant Engineer has completed the standard draeings for ladders, handrails, etc., so that future construction mill comply aith standards and revisions can be made to existing non-complying items. me era in tha process or line-marking all aisles and safety areas but have encountered a problem in that since tha specifications call for ahite or black or a combination for aisle marking. 81ack eon't mork eith asphalt, ehite discolors quickly, kle sill be painting on ths paint. All portable ladders have been inspected and have the proper non-slip feet plus a 6-foot length of tie-oft rope firmly attached to the top rung. An inventory hee bean taken of the dock boards, and ea are in the process of obtaining prices fof tha replacement for all non-complying boards. E. Egress has bean revisaed eith all supervisors, and a regular inspaction is made to insure that no egresses are blocked, locked, or not available for emergency use. At this point ee reouest that you clarify to us the actual make-up and color nr the gigne to be used indicating the various hazards, safety instructions, end exit instructions since there is some doubt in my mind esTo ehether or not ee need the fancy, multi-colored enameled signs or good, clear, 11 legible, economic plastic signs. (Continued on Page 2) GAF 11329 momm v i*rr0 * <J * * INTEROFFICE CORRESPONDENCE GAf Corporation to "r. Ui. Fasauliotia location Re* York Pnom Mr P. M. Herb at LOCaAtTIiOoNn Erie Lake 6-02 Page 2 OAtt January 7, 1972 cc Messrs. a. Page, Joliet L. Faneuf, Nee York j, Wilwohl, Erie Lokb sunjcct: C.5.H.A. CCMPLIANCE We have begun the survey ror installing the public building line exit signs end anticipate completion of the AFE request by March 1. F. Does not apply. f C. We do not have the menpoeer or the talent at this location to make the [ occupationalV1 aval survey nor the dust survey. V noise Mr. W. Page * as requested assistance From you in this area and until such time as assistance is available, ee are in jeopardy if such an inspection is Made. H. AH cylinders,la., acetylene and oxygervare Inspected and are handled in accordance aith the standards. Our L.P. gas system and the method for servicing tanks and trucks has been revieeed elth all Involved personnel and sill be revieeed as a regular item at the monthly safety meeting, I. This plant does have available eye, face, and head protection equipment for employees and our interest has elaays been in bump caps end safety glasses as part of the equipment. We ere working with the Union committee at the present time informing them that the use ot protection including respirators in areas where asbestos might be a problem until dust counts can be mode, aill be enforced as soon as the respirators are delivered which should be within the next 10 days. J. As far as practical, our sanitation facilities are acceptable in the various areas of the plant, and a we have instituted a eoveiefreceptacle system, but the demand far receptacle covers of this typo has been so great the suppliers have not been able to kempmp.i They are on order end will be used as soon as they are available. k. Two member* of the Erie Lake Plant have qualified aa Red Cross First Aid Instructors, srw| they ara currently in the process of selecting an adequate number of employees on each shift from each department and train them as First Aid people so that we sill have complete coverage at ail times. I might add et this point that in order to impress the individual employees on the Importance that 1 personally place on this activity, 1 will also attend the classes and quality as a Red Cross first aider. (Continued on Page 3) GAF 11330 *0*M !*' D IN w S * INTEROFFICE CORRESPONDENCE GAF COTpoMtKm T0 nr. w. Faeauliotis location Nee York no* Mr. p.n, Herbst LOCAaTtIiOoNn Erie Lake b--02 Page 3 date January V, 1972 cc naasrs. W. Page, Joliet L. Faneuf, Nee York J. Wilwohl, Erie Lake subject C.S.H.A. CGWPL1ANCE L. Fire Protection -- portable fire extinguishers havs baen checked, inspected, tested, and ehere necessary, additional units have been added, the locations have been painted and numbered. This particular unit is in good condition. The sprinkler systems have been tested, and in order to comply aith the Factory nutuai requirement, we will be requesting funds to Inspect and clean all of the dry valve systems in the plant at an early data. Additional dry chemical extinguishers have been added to Insure adequate coverage in high-risk areas such as saturators and stills department. I he fire brigade consists of "old-timers" and has been extremely successful over the years in coping with the emergencies which might arise. It Is evident that the overall awareness of the need for safe operation has been put across by the tact that four years ago the Fire Department visited this plant on a Tire call once a week. In 1971 the Fire Department was called to the plant three times. M. The compressed-sir system in the plant is under constant inspection and is in good condition tor thw age of the system. The reducing-type valves for blow-off nozzles are here and will be installed. N. Power and industrial trucks have been inspected for the safety guards and are in good condition to comply with the standards. Un February 15 and lb a complete operator training course for industrial truck drivers will be held again to complet tne continuous educational procassaa of maintaining safe ooaration of this equipment C. Equipment drivee, goerda, etc., have been checked end en sxample of what is being done la cowered in the attached copy of the letter by me to fir. Faneuf, dated January 6,' 1$72. P. The maintenance departdent has completed a study of this area, and we will complete the replacement or modification of exletlng equipment by February 1, 1972. 3. All persons involved in this area have been instructed on the standards, but we have a slight problsm of ventilation since our welding and burning occurs all over the place. Continued on Page a)  0M >*!.** INTEROFFICE CORRESPONDENCE OAF Cwvornian to Mr. W. Faaaullotla location Nee York from fflr. P.M. Herbst location Erie Lake 6-02 Page A date January 7, 1972 cc Messrs. W. Page, Joliat L. faneuf, Now York j. Wlleohl, Erie Lake auuiCT O.S.H.A. COMPLIANCE R. This aubpart la being read tor ahataver general information It any contain applicable to our operation. S. Cur electrical group baa bean keeping up with the codaa and making changes as time permita to aae that they are in compliance eith the codes, paat and present. On page 2 or your Decsmoer 30, 1971, latter you referred to teo locations' proposed tine of (50 for not having posted the notice or noticaa Informing employees of the protection and obligation provided for in the Act. 1 can report that notices eare posted in the Eria Lake Plant on October lb, 1971, and are atlll posted for all to see. On of the difficulties that I am experiencing at the present time la finding not only time to solve the non-standard items, but further get manhours of maintananca time to correct the non-standard items. A solution to this problem would assist greatly in completing the O.S.H.A. compliance attempt at this location. PMH s cmp Attachment PETER M. HERBST GA? 11332