Document NrjoYKdjKyJ4M1a5zzJevamD

iI'd i iiKn/%L CrUivi%ikioi^Uf4Di>*t4Uiis 1 "J ^MEw^CALS AND PLASTICS ONE CALIFORNIA STREET. S/lfl FRANCISCO. CALIFORNIA 9411! To (Ham*) Dirition location Copy (o Mr. J. L. Meyers Niagara Falls Messrs. W. J. Fitzpatrick H. W. Greenhood G. Kyriopoulos Onto July 17/ 1973 Originating D*pt. Amtirfflg Ufhr dat* _ gan FranciSCO Field Office Sobfitf Georgia - Pacific wants the most current information on Asbestos as it pertains to O.S.H.A. Regulations. Please forward pertinent data to me for delivery to Georgia - Pacific. X / A call onXeorgia - Pacific's Technical Center in Tigard, OregonV'V/ould be worthwhile if you come West. RCTomczak/cmm UJ^ Ciomjl b tes*. uJc*ut'-H*- Q-p *- J<U& i.,<Q (rk. ^ 4uu~ P/IwX */ it* ^ itSlLuf- ***- QA*i-4Jl!*uf &O&UA0A&. -/sun x ( '/* V e /<!X3 ^ /i0*/. f*- ^ V-O'VU)' w /! $*uZ~Jy> Strom % mynduir-X^ bJjL> ZuoZ* O^" d-@&. *LO* 'i^coH. &4jljjjf~ &C*yuL (^Q(JLOMJt/^) mJ <W /^ OUtA&tkjts/ yi$dAj*a. T uTfrcdfl ^*jz & (jiubtUA# UA v^u. eco &OL Ct;^e^/ 9^4 d^uia^) aJt- s&kJ~ Z &L0UJ ^ /yjitAc*s ujMa^Z X (La**- $cuaPy u/ti'c&. *V\*JL i**&tO /^MjLACS ^*&ry UNION CARBIDE CORPORATION MINING & METALS DIVISION P.O. BOX 579 THE DISCOVERY COMPANY NIAGARA FALLS, N. Y. 14302 TEL: 716-278-3376 July 18, 1973 Mr. John DI Lorenzo Georgia Pacific Corporation 900 SW 5th Avenue Portland, OR 97204 Dear John: Enclosed is a copy of the recently enacted EPA regulations per your request at our meeting in Akron on July 17, 1973. I've also included some information on dust sampling equipment and procedures. Please let me know if you would like any additional information or assistance. We have a "package" on the bulk handling of "Calidria" Asbestos pellets if you ever get to that stage. I enjoyed meeting you and look forward to seeing you again. Marketing Manager /ds Enclosure internal, correspondence MINING AND METALS DIVISION To (Nomo) Divition Loeotion Mr. W. C. Thurber Mining and Metals New York, NY Cosy to P. 0. BOX 579, NIAGARA FALLS, NEW YORK 14302 Oat* Originating Dopt. July 27, 1973 "Calidria" Asbestos Answering lottor dot* Subject 0SHA Citation Enclosed is a copy of the Subject issued to Georgia-Pacific Corporation, Akron, New York, for which they were fined a total of $3000. I will send a copy to all personnel without identifying Georgia-Pacific, as this should be considered confidential information. Georgia-Pacific personnel, including counsel, attended a hearing in New York City but did not contest the citation. Since they did not contest, 0SHA advised them that they could not see the dust monitoring results. Therefore, they do not know where specific improvements are needed. There seem to be several areas where 0SHA demands clearly exceed legal requirements. Based on our field experience, EPA, CSHA and state authorities are making it common practice to do this and tend to create an aura of harassment or unfounded fear for our customers. Have we received any satisfactory response on the EPA letter from Atlanta, for instance; and should v/e make some high-level waves via AIA or direct? It can only get worse if there are no complaints. Following are some specific comments (with irty thanks to H. B. Rhodes for his participation): Citation Item 1. The regulations do not specify clothing to prevent skin contact. We know of no deleterious effect of skin contact with asbestos. The most obvious reason for clothing changes is to minimize the transfer of asbestos dust to non-occupational areas. Posting of Citation - Tne asbestos regulations do not require posting of citation but are very specific on employee notification if he has been exposed to excess concentrations. Without data Georgia-Pacific does not know which employees to notify or where to take corrective action. Perhaps posting of the citation is required by the original Occupational Safety and Health Act of 1970. Mr. W. C. Thurber -2- July 27, 1973 Multi-Step Abatement - Items 3 through 7 are required to become permanent controls. It is assumed that Georgia-Pacific will install dust control equipment and take other engineering and administrative steps to reduce airborne dust to acceptable levels. Except for Item 5, it is clear in the regulations that the other items are not required unless dust levels are or are reasonably expected to exceed the prescribed levels. It seems that the prescribed abatement procedures exceed the legal requirements. This recalls one comment on the OSHA regulations: "You cannot exceed the threshold limit values - but, if you do, you must do this and this , etc. --" There is no question in our minds or in Georgia-Pacific's that the Akron plant is dirty and deserved citation. We are working closely with them on dust monitoring and possible control measures, including the use of pellets. Enclosure /ds I o. Occupational Softly and Health Adminislraflen 203 Uldtovn Plaza 700 E. Tatar St. ' Syx&ouaa, H. Y. 132X0 '< j CITATION* Citation Number- lr Pagn 1 of EMPLOYER (Street ADDRESS ( (City \ An inspection of wcrkp dHO NO. OIH4.I NO* i i P-1568 48 A<eOM 6010 2 m 131973 ana described ss follows ---------------------------------------------- Manufactures gypsum wallboard and lointing compound has been conducted. On the basis of the inspection it is alleged that you have violated the Occupational Safety and Health Act of 1970. 29 U.S.C. SSI. in the following reapects: Iteia uabar Stand*rd or rcfoJaiioo allcfodly violated Description of alleged violation Data oo which alleged violation mum be corrected l. 29 CPR 1910.93a (d)(3) u Failure of the employer to provide Multi-Step Abate Pag* 22143 and require use of special clothing, ment such as coveralls or similar whole i .i body coverings, gloves, and foot coverings to prevent skin contact with asbestos fibers, of employees (See Reverse Side of this Citation) . within the dry mix and packout area. 2 29 CPR 1910.93a (d)(4) Failure of the employer to provide Multi-Step Page 22143 change rooms, two separate clothes Abatement r lockers for work and street clothee, i I and the laundering and handling of work clothes for all employees (See Reverse Side of this Citation! exposed to airborne concentretione of asbestoe fibers in excess of prescribed limits, within the joint compound mixing and packout area. The issuance of a citation does not cooatitute q finding that a violation of the Act haa occurred unleaa there ia a failure to contest as provided lot ia the Act or, if cooteete^, palest the citation ia affirmed by the Occupational Safety and Health Review Commiaeion. RIGHTS OF EMPLOYEES Any employee or representative of employee# who believoa that any period of time fixed in this citation for the correction of a violation is unressonsble has the right to contest such time for correction by filing e notice with the U.S. Deportment of Labor at the address shown above within 1) working days of the receipc by the employer of notice of proposed penalty or notice that oo penalty is being proposed. "No person shall discharge or in any manner discriminate against any employee because such employee has filed any com* plaint or instituted o( caused to be instituted any proceeding under or related to thia Act or haa testified or is about to testify in such proceeding or because of the exercise by such employee on behalf of himself or others of any right afforded by thia Act." Sec. 11 (c)(1) of the Occupational Safety and Health Act of 1970, 29 U.S.C 6)1. The law requires that a copy of the enclosed citation(s) "shall be prominently posted" in a conspicuous place at or near each place a violation referred to in the citation occured." It mutt remain posted until all violations cited therein ate cor rected, ot for ) working days, whichever period is longer. * Alleged violations covered by this citation are those which arc not serious violations within-the meaning of the Act but Much have a direct or immediate relationship to occupational safety and health. | Farm OSH A*2 AUC. 1*71 MULTI-STEP ABATEMENT Immediate Temporary Administrative Controls Initiate immediate temporary administrative controls to prevent employee exposure to excessive asbestos dust concentrations by July 31, 1973. A Compliance Officer will determine if theae temporary controls are preventing employee exposure. (1) Provide U. S. Bureau of Mines approved respirators for all packout areas of the main plant. Continue the use of respirators until the installation of permanent engineering controls. (2) Establish a complete respirator program in accordance with the provisions of the American National Standard Practices for Respiratory Protection 288.2-1969. (3) Establish a program for maintaining the Joint compound dry mixing and packout areas of the main plant in a clean, orderly and sanitary condition to prevent asbestos dust contamination of the air. This program will include utilising sealed impermeable bags for the storage of waste asbestos. (4) Provide employees with protective clothing that can be maintained in a sanitary and reliable condition from becoming contaminated with asbestos. In addition, provide employees with individual clothes lockers to prevent their personal clothing from becoming contaminated with asbestos dust. (5) Establish a personal monitoring program to determine, at six month intervals, the concentrations of asbestos dust. (6) Post asbestos "Caution" signs at all approaches to'the work area to. prevent unprptected persons from entering. (7) Affix asbestos "Caution" labels on all raw materials, mixtures, scrap, waste, debris and other products containing asbestos to prevent exposure to asbestos dust. Permanent Engineering and Administrative Controls (1) By July 27, 1973, submit a plan for approval to the U. S. Department of Labor, Occupational Safety and Health Adminis tration, 203 Midtown Plasa, 700 E. Water Street, Syracuse, New York 13210, Mr. Chester C. Whiteside, Area Director, showing a timetable for the installation of engineering controls to prevent employee exposure to asbestos dust concentrations above allowable limits. (2) Incorporate items (3) through (7) (listed as temporary adminis trative controls in Part I) as permanent administrative controls to prevent employee asbestos dust exposure. 4. 0 i. .* . Citation Number EMPLOYER ______ ADDRESS (Street. ( (Q>y-- An inspection of UJ.0PAHIU6NT OF bADOR Occupational Safety and Health Adaioiitritha 203 Uldtown Plaza 700 E. Water St. Syracuse. S. Y. 13210 CITATION* . ,, CSHO NO. .1 P-1568 f ARILA 6010 QSHA.I NO. RCOION 2 JUN 1 3 1973 -- I _i -- * * i' ____ Manufactures gypsum wallboard and lointing fcomnound______________ has been conducted. On the basis of the inspcctioa it i* alleged chat you have violated the Occupational Safety and Hcaich | Act of 1970, 29 U.S.C. 651, in the following respects: Item number Scaodord or regulation allegedly violated Description of oUegod vieiatieo Dale on which lleged violation muftt be corrected i j 3. 4. - - - 29 CPR 1910.93* <f)<2)<ii) Failure of the employer to establish Page 22143 a personal monitoring program at intervals not greater than 6 month* within the joint compound mixing and packout areas where asbestos exposure may reasonably be foreseen to exceed prescribed limits. Multi-Step Abatement (See Reverse Side of this Citation) 29 CFR 1910.93* <g)<l)<i) Page 22143 ___ a ' ' '* ' **' -- ---- - Failure of employer to post "Caution ' signs at all approaches to the Joint compound mixing and packout area where airborne concentrations of asbestos fibers may be in exceas of prescribed Limits. Multi-Step Abatement (See Reverse Side of this Citation) | - Q _ _________ h l/&r h/ r2-U// 4 Chester C. Whiteside The issuance of s 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 Occupational Safety and Health Review Commission. RIGHTS OF EMPLOYEES j Any employee or representative of employees who believes that any period of time fised in this citation for the correction of . o violation is unreasonable has the right to contest such time for correction by filing a^notice with the U.S. Department of Labor, at the address shown above within 15 working dnya of the receipt by*he employer of notice of proposed penalty or notice that no | penalty is being proposed. "No person shall discharge or in any manner discriminate against any employee because such employee has filed any com plaint or instituted or caused to be instituted any proceeding under or related to this Act or has testified or is about to testify in such proceeding or because of die esercise by such employee on behalf of himself dr others of any right afforded by this Act." Sec. 11 (c)(l)of the Occupational .Safety and Health Act of 1970, 29 U.S.C. 651. I The law requires that a copy of the enclosed citacion(s) "shall be prominently posted*' in a conspicuous place "at or near i each place a violation referred to in the citation occured." It must remain posted until all violations cited therein arc cor rected. nr for 5 working days, whichever period is longer. Alleged violations covered by this citation arc those which arc hot serious violations within the meaning of the Act hut which have a.direct or immediate relationship to occupational safety and health. - - -- - -- -- ... . _____ _______________ Form OSHA.J juiO. 1171 MULTI-STEP ABATEMENT Imnedlate Temporary Administrative Controls Initiate inmediate temporary administrative controls to prevent employee exposure to excessive asbestos dust concentrations by July 31, 1973, A Compliance Officer will determine if these temporary controls are preventing employee exposure. (1) Provide U. S. Bureau of Mines approved respirators for all packout areas of the main plant. Continue the use of respirators until the installation of permanent engineering controls. (2): Establish a complete respirator program in accordance with the provisions of the American National Standard Practices for Kespiratory Protection Z36.2-1969. (3) Establish a program for maintaining the Joint compound dry mixing and packout areas of the main plant in a clean, orderly and sanitary condition to prevent asbestos dust contamination of the air. This program will include utilising sealed impermeable bags for the storage of waste asbestos. (4) Provide employees with protective clothing that can be ..... maintained in a sanitary and reliable condition from becoming contaminated with asbestos. In addition, provide employees ..with Individual clothes lockers to prevent their personal clothing from becoming contaminated with asbestos dust. (3) Establish a personal monitoring program to determine, at six month intervals, the concentrations of asbestos dust. . . (6) Post asbestos "Caution" signs at all approaches to'the work area to prevent unprptected persons from entering. .1.(7) Affix asbestos "Caution" labels on all raw materials, mixtures, scrap, waste, debris and other products containing asbestos to prevent exposure to asbestos dust. Permanent Engineering and Administrative Controls (1) By July 27, 1973, submit a plan for approval to the U. S. Department of Labor, Occupational Safety and Health Adminis tration, 203 Midtown Plaza, 700 E. Water Street, Syracuse, New York 13210, Mr. Chester C. Whiteside, Area Director, showing a timetable for the installation of engineering controls to prevent employee exposure to asbestos dust concentrations above allowable limits. (2) Incorporate items (3) through (7) (listed as temporary adminis trative controls in Part I) as permanent administrative controls to prevent employee asbestos dust exposure. Ij.i, in'.J'A'iiMMd <u LAUOR OwwpOlonol Safety ond Htgiiii AdMinlatritiff k 203 Midtown Plaza 700 E. Water St. Syracuse. E. Y. 13210 Citation Number lr Pa^e 3 of 5 EMPLOYER ______ : (Street ADDRESS ( (City _ An inspection of , CITATION* Date Issued CSHO NO. P-1568 AD (A OSHA. I MO. 48 region 6010 2 JUS 13 13/3 Manufactures gypsum vailboard and.jointing compound has been conducted. On the basis of the inspection it is alleged that yon hare violated the Occupational Safety and Health Act of 1970, 29 U.S.C. 651, in the following respects: Item number 5. 6. Standard or regulation allegedly violated 29 C7R 1910.93a (g)(2)(i) Pag* 22144 29 C?R 1910.93a (b)(1) Paga 22144 . Description of alleged violation Date on which alleged violatioa aiust be corrected Failure of the employer to affix a "Caution" label to all raw materials mixtures, scrap, waste, debris and other products containing asbestos fibers to prevent exposure to con centrations above prescribed limits during any reasonably forseeable use. Multi-Step Abatement (See Reverse Side of this Citation) Failure of tbe employer to maintain ail external surfaces within the Joint compound, dry mixing end packout area, free of accumulationa of asbestos fibers (dry sweeping is to be discouraged, utilize vacuum sweeping methods). Multi-Step Abatement (See Reverse Side of this Citation) -T\T Area Director's Signature' Chester C. Whiteside The issuance of s citation does oot constitute a finding that a violation of the Act had occurred unless there is a failure to contest as provided lot in tbe Act or, if contested, unless the citation is affirmed by tbe Occupational Safety and Health Review Commission. , RIGHTS OF EMPLOYEES Any employee or representative of employee* who believes char any period of time fixed in ibis cication for the correction of a violation is unreasonable hit the tight to contest such time foe cocceccion by filing a notice with the U.S. Department of Labor at the addicts shown shove within 15 working days of the receipt by che employer of notice of ptopoeed penalty ornorice that no penalty is being proposed. "No person slmll discharge ot in ony manner discriminate ngninst any employee because such employee has filed any com plain: oi institmrd or caused tn be instituted any proceeding under nr related to this Act or has testified or is about to testify in such proceeding or heenunc of die exercise by such employee on behalf of himself or others of any right afforded by this Act." See. II (c)(1) of (lie Occupational Safety and Health Act of 1970, 29 U.S.C. 651- , The law requires that a copy of the enclosed citncioa(a) "shall be prominently ponied" in a conspicuous place "at or near each place a violation referred ro in the citation occurcd." It must remain posted until all violations cited therein are cor rected. or foe 5 working days, whichever period is longer. * Alleged violation/! covered by this citation ntc tlionc which arc not ncrinus violations within (he meaning of the Act hut which have a direct or immediate relationship to occupational safety and health. ( fy Form CSIIA-2 tfif. *Hf. MULTI-STEP ABATEMENT Inroedlate Temporary Administrative Controls Initiate immediate temporary administrative controls to prevent employee exposure to excessive asbestos dust concentrations by July 31, 1973. A Compliance Officer will determine if these temporary controls are preventing employee exposure. (1) Provide U. S. Bureau of Mines approved respirators for all packout areas of the main plant. Continue the use of respirators until the installation of permanent engineering controls. (2): Establish a complete respirator program in accordance with the provisions of the American National Standard Practices for Respiratory Protection Z88.2-1969. (3) Establish a program for maintaining the Joint compound dry mixing and packout areas of the main plant in a clean, orderly and sanitary condition to prevent asbestos dust contamination of the air. This program will include utilising sealed impermeable bags for the storage of waste asbestos. . (4) Provide employees with protective clothing that can be maintained in a sanitary and reliable condition from becoming contaminated with asbestos. In addition, provide employees ::.with Individual clothes lockers to prevent their personal clothing from becoming contaminated with aabestos duat. (3)Establish a personal monitoring program to determine, at six month intervals, the concentrations of asbestos duat. 1 (6) Post asbestos "Caution" signs at all approaches to`the work area to. prevent unprptected persons from entering. i (7) Affix asbestos "Caution" labels on all raw materials, mixtures, scrap, waste, debris and other products containing asbestos to prevent exposure to asbestos dust. Permanent Engineering and Administrative Controls (1) By July 27, 1973, submit a plan for approval to the U. S. Department of Labor, Occupational Safety and Health Adminis tration, 203 Midtown Plaza, 700 E. Water Street, Syracuse, New York 13210, Mr. Chester C. Whiteside, Area Director, showing ' a timetable for the installation of engineering controls to prevent employee exposure to asbestos dust concentrations above allowable limits. (2) Incorporate items (3) through (7) (listed as temporary adminis trative controls in Part I) as permanent adminiatrative controla to prevent employee asbeatos dust exposure. *1 O: Citation Number EMPLOYER \* ' U.S. Ohl'MlMIrHI Of LAftOR OccnpClfoneJ $of*jr ood Hfollil A^MlllflliM 203 Kidtown Plaza; 700 E. Water St. &TUUM. if. X. 13210 . . CITATION* SSho no. P-1568 'AhtiA ' 6010 OSHA.I MOs 48 A*eio 2 1 r Paga L af 5 Data Issued 1 3 1373 *' ~ ADDRESS \ An inapcc ____________________ Manufactures Bvosum wallboard and lointine comaound has been conducted. On the basis of the inapection it is alleged that you have violated the Occupational Safety and Health Act of 1970, 29 U.S.C. 651, in the following respects: Item imbtf Standard ar regulation allegedly violated | Description of alleged violation Date on which alleged violation moat he corrected 7. 29 CFR 1910.93a (b)(2) Fags 22164 ' . . A A . y^\ lli?./ /u^s. Failure of the employer to collect end dispose of ell esbestos .waste, scrap, debris, begs, containers, contaminated clothing in sealed impermeable bags to prevent any forseeable airborne concentrations of'asbestos fibers above the allow able limit.. Multi-Step Abatement (See Reverse Side of this Citation) ' `1 * * a . 1 r The iaauancc ot a citatioo does not constitute a finding that a violation of the Act has occurred unless there is a failure to I contest as provided for in tbe Act at, if contested, unless the citatioo is affitaed by the Occupational Safety and Health Review Commission. ' RIGHTS OF EMPLOYEES Any employee or representative of employees who believes chat any period of time fixed in this citation for the correction of j a violation is unreasonable has the right to eonteat such time for correction by filing a notice with the U.S. Department of Labor j nt the address shown shove within 15 working days of the receipt by the employer of notice f proposed penalty of notice that no penalty is being.proposed. "No person shall discharge or in any manner fliscriminate against any employee because such employee has filed any com- ploinr or instituted or caused to be instituted any proceeding under or related to this Act or has testified or is about to testify [ in such proceeding or because of the paerciec by such employee on behalf of himself or others of any tight afforded by this Act." Sec. 11 (c)(1) of the Occupational Safety end Health Act of 1970, 29 tl.S.C. <551. The law requires chat a copy of the enclosed ctiation(s) "shall be prominently posted" in a conspicuous place * at or neat each place a violation referred to in the citation occured." It must remain posted until all violations cited therein are cor rected, or for J working days, whichever period is longer. Alleged violations covered by tills citation are thoao which ate not serious violations within tht meaning of the Act but which have a direct or iauaedt'nte relationship to occupational safety and health, LLM(1||_______________________________________________ m---------,----------- --- - Fwt - -- MULTI-STEP ABATEMENT Inmedlate Temporary Administrative Controls Initiate immediate temporary administrative controls to prevent employee exposure to excessive asbestos dust concentrations by July 31, 1973. A Compliance Officer will determine if these temporary controls are preventing employee exposure. (1) Provide U. S. Bureau of Mines approved respirators for all packout areas of the main plant. Continue the use of respirators until the installation of permanent engineering controls. (2): Establish a complete respirator program in accordance with the provisions of the American National Standard Practices for Respiratory Protection 288.2-1969. (3) Establish a program for maintaining the Joint compound dry mixing and packout areas of the main plant in a clean, orderly and sanitary condition to prevent asbestos dust contamination of the air. This program will include utilising sealed impermeable bags for the storage of waste asbestos. (4) Provide employees with protective clothing that can be maintained in a sanitary and reliable condition from becoming contaminated with asbestos. In addition, provide employees ...with individual clothes lockers to prevent their personal clothing from becoming contaminated with asbestos dust. (3) Establish a personal monitoring program to determine, at six month Intervals, the concentrations of asbestos dust. (6) Post asbestos "Caution" signs at all approaches to`the work area to, prevent unprotected persons from entering. (7) Affix asbestos "Caution" labels on all raw materials, mixtures, scrap, waste, debris and other products containing asbestos to prevent exposure to asbestos dust. Permanent Engineering and Administrative Controls (1) By July 27, 1973, submit a plan for approval to the U. S. Department of Labor, Occupational Safety and Health Adminis tration, 203 Midtom Plaza, 700 E. Water Street, Syracuse, New York 13210, Mr. Chester C. Whiteside, Area Director, showing ' a timetable for the installation of engineering controls to prevent employee exposure to asbestos dust concentrations above allowable limits. (2) Incorporate items (3) through (7) (listed as temporary adminis trative controls in Part I) as permanent administrative controls to prevent employee asbestos dust exposure. o U.S. OfRARTMtNT OR LABOR -- OcevffltlMfll Sfiiy and Health Admlnletfwfian 203 Mid-town Plaza 700 E. Water St. Syracuse, H. I. 13210 ___'_________________________________ AMENDMENT to citation*______________ Citation Number EMPLOYER 1. Page 3 of 5 ' _Date_Iauerf ADDRESS HUo ho.--------------- OSHA.I NO. P-1568 48 AREA A^gi6n 6010 2 Julv 10. 1973 I I Aft inipei Manufactures gypsum wallboard and jointing cocapound has been conducted. On the basis of the inspection it is alleged chat you have violated the Occupational Safety and Health Act of 1970, 29 U.S.C. 651, in the following respects: Item number 8. 9. _. Standard or regulation allegedly violated Description of alleged violation Date on which alleged violation must be corrected CiCations for Serious Vio .etlon #2 and #3, Issued on the 13th < ay of June, 1973 ara amended es set forth telow: 29 CPR 1910.93a (d)(2) Page 22143 Failure of the employer to provide, and for -the employees to use, U.S. Buremu of Mines approved respiretors to prevent inhalation of airborne asbestos dust fibers (within the dry mixing and packout area). Multi-Step Abatement - (See reverse side of this citation) 29 CPR 1910.93a (d)(2)(iv >Failure of employer to establish a Page 22143 ' respiratory program throughout the dry mixing area in accordance with the American National Standard Practice for- Respiratory Protection Z88.2-1969, for employees who are exposed to excessive asbestos dust concentrations. Multi-Step Abatement (See reverse, side of this citation) c Area Director's Signature Chester C. Whiteside The issuance of a 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 Occupational Safety and Health Review Commission. RIGHTS OF EMPLOYEES Any employee or representative of employees who believes that any period of time fixed in this citation for the correction of a violation is unreasonable has the right to contest such time for correction by filing a notice with the U.S. Department of Labor at the address shown above within 17 working days of the receipt by the employer of notice of proposed penalty or notice that no penairv is being proposed. "No person shall discharge or in any manner discriminate against any employee because such employee has filed any com plaint or instituted or caused to be instituted any proceeding under or related to this Act or has testified or is about to testify in such proceeding or because of the exercise by such employee on behalf of himself or others of any right afforded by this A. t." 11 (cKl) of the Occupational Safety and Health Act of 1970, 29 U.S.C. 651. The law requires that a copy of the enclosed citation(s) "shall be prominently posted" in a conspicuous place "at or near each place a violation referred to in the citation occured." It must remain posted until all violations cited therein are cor rected. or for 5 working days, whichever period is longer. * Alleged violations covered by this citation are those which are not serious violations within the meaning of the Act but which have a direct or immediate relationship to occupational safety and health. o*o M-ao Form OSH A*2 AUC. l*7i MULTI-STEP ABATEMENT Ininedlate Temporary Administrative Controls Initiate immediate temporary administrative controls to prevent employee exposure to excessive asbestos dust concentrations by July 31, 1973. A Compliance Officer will determine if these tesiporary controls are preventing employee exposure. (1) Provide U. S. Bureau of Mines approved respirators for all packout areas of the main plant. Continue the use of respirators until the Installation of permanent engineering controls. (2). Establish a complete respirator program in accordance with the provisions of the American National Standard Practices for Respiratory Protection Z88.2-1969. (3) Establish a program for maintaining the joint compound dry mixing and packout areas of the main plant in a clean, orderly and sanitary condition to prevent asbestos dust contamination of the air. This program will include utilising sealed Impermeable bags for the storage of waste asbestos. (4) Provide employees with protective clothing that can be maintained in a sanitary and reliable condition from becoming contaminated with asbestos. In addition, provide employees .with individual clothes lockers to prevent their personal clothing from becoming contaminated with asbestos dust. (3) Establish .a personal monitoring program to determine, at six month intervals, the concentrations of asbestos dust. (6) Post asbestos "Caution" signs at all approaches to`the work area to, prevent unprptected persons from entering. (7) Affix asbestos "Caution" labels on all raw materials, mixtures, scrap, waste, debris and other products containing asbestos to prevent exposure to asbestos dust. Permanent Engineering and Administrative Controls (1) By July 27, 1973, submit a plan for approval to the U. S. Department of Labor, Occupational Safety and Health Adminis tration, 203 Midtown Plaza, 700 E. Water Street, Syracuse, New York 13210, Mr. Chester C. Whiteside, Area Director, showing a timetable for the installation of engineering controls to prevent employee exposure to asbestos dust concentrations above allowable limits. (2) Incorporate items (3) through (7) (listed as temporary adminis trative controls in Part I) as permanent admlniatrative controla to prevent employee asbestos dust exposure. truct The Exchange is a 245,000- square-foot commercial center at Farmington, Conn., which is part of a "total living" community known as Talcott Village. De signed by Warren Callister and August Rath of Tiburon, Calif., the $9 million center is con structed almost entirely of wood, with laminated trusses as long as 75 feet. "We wanted to maintain the rustic atmosphere of Talcott Vil lage," said Don Wild, head of the structural department of James S. Minges & Associates, consulting engineers, "and wood was the logical choice." The job of providing laminated beams, columns and trusses to rigid specifications went to Unadilla Laminated Products (UnaLam), at Unadilla, N.Y., 200 miles from the construction site. At Una-Lam, Arkansas pine is kiln dried to 10 to 12 per cent mois ture content, converted into lam inated beams as thick as 13V2 inches for The Exchange, using Georgia-Pacific GP-117 Resi-Lam phenolic resorcinol glue fora last ing chemical weld. Well in excess of one-million board feet of laminated material and one-million board feet of decking materials will be in ser- Trusses are readied for delivery to The Ex change at Farmington, Conn. Reprinted from ADHESIVES AGE, December, 1972 i ! 5 ; I