Document Qkn70ron5GwM3Lz6mbzkeZjdk

Acceturo v. A bex Corp., e ta l, Superior CL, Law Division, Middlesex Cty., New Jersey, Docket No. M ID -L-6601-99-A S ; 10/03/05. AcceturorV. A bex Corp., e ta l, Superior CL, Law Division, Middlesex Cty,, Ne)v Jersey,Docket No. M ID -L-6601-99-A S ; 10/03/05. -4 October igB6 EHPLOTEB TRAINING PROGRAM FOB ASBESTOS /&>6e /ee// INTRODGCTION BATON CORPORATION Gallatin, Tennessee Effective July 21, 1986, the Occupational Safety and Health Administration (OSHA) amended its standard regulating occupational exposure to aBbeatos. Among the changes, the permissible exposure limit was lowered from 2 fibers per oubio centimeter or air (fibers/oa) down to 0.2 flbers/cc. Through this facility's efforts prior to the standard being amended, the exposure levels for employees working with asbestos have been reduced to below the permissible exposure limit, as demonstrated by the semiannual exposure monitoring program conducted bere. The purpose of this training program is to review the requirements of the standard, to disousa in detail certain parts of the standard pertinent to the employees of this faoillty, such as the facility's respirator polioy and medical surveillance program, and to discuss the specifio procedures, work practices, and engineering controls implemented by this facility in order to continue to aahleve compliance with the OSHA Standard and to protect the health of employees. Additionally, this training program will present information on the health effeots associated with asbestos exposure and the relationship between smoking and exposure to asbestos in producing lung cancer. Tba standard aa amended addressed asbestos and the non-asbestos forma af tremollte, anthopbyllite, and aotinolite. On Ootober 17, 1986) OSHA issued a partial administrative stay of the revised standard, in whioh the regulation of non-asbestiform tremolite, anthophyllite, and aotinolite under the revised standard was stayed and the provisions of the 1972 standard remained in efreat for these non-asbestos Torus. However, for the purpose of this braining program, whenever the term "asbestos" is U3ed, it may be ooosldered to also include the non-asbestiform tremolite, anthophyllite, and aotinolite. P-EAT-0323 EXHIBIT FAR 018689 SCF-EC-3225 A ccetiiro v. A b e x C o rp ., etaL, Superior C t, Law Division, Middlesex Cty., New Jersey, D ocket No. M ID -L-6601-99-A S ; 10/03/05. Accetiiro. v. A bex Corp., et aL, Superior CL, La>v Division, Middlesex C ty N e w Jersey, Docket No. M ID -L-6601-99-A S ; 10/03/05. HEALTH EFFECTS ASSOCIATED WITH ASBESTOS EXPOSURE Asbestos is a widely used class of magnesium-silicate minerals that occur in fibrous form. It is used as a component of many products and materials because of its beneficial properties, such as durability and resistance to heat and chemicals. However, asbestos also has a detrimental property; it can cause disease. The inhalatioa of asbestos fibers has been olearly associated with three olinioal conditions: asbestosis, mesothelioma and lung cancer. Many studies have also observed increased gastrointestinal cancer risk. Risk from cancer at other sites, such as the larynx, pharynx, and kidneys, is also suspected. Asbestosis is pulmonary fibrosis caused by the accumulation of asbestos fibers La the lungs. Symptoms Include shortness of breath, ooughing, fatigue, and vague feelings of slalcness. When the fibrosis worsens, shortness of breath occurs even at rest. The diagnosis of asbestosis is based on a history of exposure to asbestos, the presence of characteristic radiologio changes, end-inspiratory crackles (rales), and other clinical features of fibrosing lung disease. Pleural plaques and thickening are observed on X-rays taken during the early stages of the disease. Asbestosis is often a progressive disease even in the absence of continued exposure, although this appears to be a highly individualized characteristic. In severe cases, death may be caused by respiratory or cardiac failure. Initial exposure Halts for asbestos were based on efforts to reduce asbestosis, which was known to be associated with asbestos exposure. The reduction in the number of oases of asbestosis, bowever, resulted in workers living long enough to develop cancers that are now recognized as being ' associated with asbestos exposure. P-EAT-0324 EAB 01869(1 v. A bex Carp., e ta l, Superior C t, Law D ivision, Middlesex Cty., New Jersey, D ocket No. M ID -L-66Q 1-99-A S ; 10/03/05. A bex Corp., et aL, Superior CL, L a w D iv is io n Middlesex. Cty., New_ Jersey, Docket No. M ID -L-6601-99-A S ; 10/03/05. The signs and symptoms of lung cancer and gastrointestinal cancer Induced by exposure to asbestos are similar to non-aabestos-re.lated cancers of these types, except that a cheat X-ray of an asbestos-exposed patient with lung oanoer may show pleuraL plaques, pleural oaloifieation, or ploural fibrosis. Lung cancer generally has a latency period of about 15 to 20 years; latency period means the amount of time necossary for symptoms of disease to become present after exposure. Mesothelioma is a oanoer of the mesothelial lining of tbe pleura, or chest, and the peritoneum, or abdomen. Symptoms characteristic of mesothelioma include shortness of breath, pain in the walla of tbe cheat, or abdominal pain. Compared to lung oanoer, mesothelioma generally has a much longer latency period of about 40 years. Mesothelioma is always fatal. Clinical evldenoe of the adverse effects associated with exposure to asbestos is present, in the form of several well-conducted epidemiological studies of occupationally exposed workers, . family contacts of workers, and persons living near asbestos mines. These studies have shown 3 definite association between asbestos exposure and an increased incidence of the described diseaaos. Tables & and B present data from OSHA showing the relationship of cancer mortality to various exposure concentrations, various ages of first exposure, and various durations of exposure. Epidemiological, studies indicate that the risk of lung cancer among exposed workers who smoke cigarettes is greatly increased over the risk of lung oanoer among, non-exposed smokers or exposed nonsmokers. These studies suggest that cessation of smoking will reduce the risk of lung oanoer for a person exposed to asbestos, but will not reduce It to the same level of risk as that existing for an exposed worker who has never smoked. . sCv.i IVj P-EAT-0325 KAB 018691 tj u A cceturo v. A bex Corp., e ta L , S uperior CL, Law Division, M iddlesex Cty., New Jersey, D ocket No. M ID -L-6601-99-A S ; 10/03/05. A cceturo y. A bex Corp., etaL, Superior CL, Law D ivision, Middlesex Cty., New Jersey, D ocket No. M ID -L-6601-99-A S ; 10/03/05. Table k Estimated asbestos related cancer mortality from a one year exposure to various fiber concentrations " Asbestos fiber concentration (f/jnl ^ Cancer mortal I ty /IQQ.OOQ exposed 11 Mesoths-- * ' 1 Lung lloma Gastrointestinal 1 Total Oil 0.2 0.5 2.0 Age at first exposure: 20 7.2 9.5 .7 16.2 . 14.3 18.9 - 1.4 34.6 ' 35.B- 47.3 -. 3.6 ' 86.7 142.8 186.7 14.3 . 345.8 0.1 . 0-2 ` 0.5 2.0 ' 0.1 ' 0.2 0.5 2.0 Age at First exposure: - 30 7.3 14.536.3 144-9^ 4.9 * ' -.7 - 9.8 1.4 '24.4- 3.6 97.4 ' ' 14.5 . 12". 9 . 25.7 64.3 256.8 . 7.1 14.1 35.3 '. 140.9 Ade at first exposure: 40 - '2.r 4.3 ' 10.7 42.6 .7- . . 1.4 ' - : . 3-5 : 14.1 : 9.9 19.8 . 49.5 197.6 ` 0.1 0.2 0.5 2.0 0.1 . 0.2 0.5 ' 2.0 ' Age at first exposure: 50 . ' . 6.1 0.7 12.2 1.5 30-4 ` 3-7 121.7 14.7 .6 ,.1.2 .3.0 12.2 7A 14.9 \ 37,0 148.6 .Age at first exposure : 60 4.0 . .6.0- . 19 J 79.6 0.2 0.3 0.9 3.4 ' .4 .8 ' 2.0 8.0 . 4'. 6 9.1 .* 22.8 91.0 . Estimated as IQJC.of lung cancer risk rather than calculated using dose-response Information. - .t " - P-EAT-0326 FAB0ISC92 A ccetiiro v. A bex Corp., et aL, Superior C t, L a w Division, Middlesex Cty., New Jersey, D ocket No. M ID -L-6601-99-A S ; A cceturo v. A bex Corp., etaL, Superior C t, Lm vD ivision, Middlesex Cty., N o v Jersey, Docket No. M 1D -L-66G I-99-AS; 10/03/05. l **< Table 6' Estimated Asbestos Related Cancer Mortality per 100,000 by Number of Years Exposed and Exposure Level- Asbestos fiber concentration V Cancer mortality 7100,000 exposed'' " . Mesothe.- ' Lung lioma Gastrointestinal^ Total- ..... 1 year exposure ' 0.1 . 0.2 0.5' - 2.0 ' 4.0 ' - 5.0 10.0 - 7.2 ' 14.4 36.1 (44 ' 238 ' 360 715 . ' 6-. 9 . 0.7 . 14.8 ' 13.8 1.4- . -Z9.6 34.6 - 3.6 - : 74.3 - 138 - - 14.4 ' - 1 296.4 275 - 28.8 - ; 591.8 - 344 . 36.0 ' 740.0 . ' 684 .71.5 . - 1470.5 ' 20 year exposure * 0.1 ' . 0.2 - 0.5 '. 2.0 ' 4:o: - 5.0-' ' 10.0 * 139278 692 2713 527B6509 .1?177 73 13.9 ' 146 27.B 362 . 69.2 - . 1408' ' . 271.3' 2706 . . '527.8 3317 ' . 650.9 . 6024 1217.7 - . 45 years "exposure ! 225.9 ; . 451.8 1123.2 4392.3 8511.8' 10476.913996.7 .* 0.1 0.2 . 0.5 2.0 4.0 5.0 10.0 . 231 - 82 - 23.1 . 336.1 . .460 - 164. .. 46.0.:.:: - 670.0 1143 ' 407 ' ' 114.3 - - 1664.3 . 4416 1554 441.6 6411.6 8441 . 2924 844.1 12209.1 10318 3547 1031.8 . 14896.8 18515 6141 1851.5 - - 26507 .S Assumes exposure begins at age 25. Risks are calculated using U.S. male .lung cancer background rates for 1977. ' . ^ Estimated as 1CEC of lung cancer.risk rather than calculated using . dose-response'information. IfLUftC CflOC lilO-M-e P-EAT-0327 EA13 018693 A cceturo v. Abex Corp., etaL, Superior CL, Law Division, Middlesex Cty., Neu> Jersey, D ocket No. M ID -L-6601-99-A S ; A cceturo v. Abex Corp., et a t, S uperior CL, Law Division, Middlesex Cty., New Jersey, D ocket No. MTD-L-6601-99-A S ; i I REVIEW OF THE STANDARD i Applicability: Tbe general industry standard for asbestos applies to the exposure to asbestos of every employee In oertain specified places of employment, of which this facility Is included. Permissible Exposure Limit (PEL): The PEL for asbestos Is the airborne concentration, averaged over an eight-hour work period, that should not be exoeeded. The ourrent PEL for asbestos is 0.2 fibers per cubic centimeter of air, 33 determined by the prescribed method. The employer has the responsibility for ensuring that the PEL la not exceeded. Another airborne concentration amount that also has significance in the standard Is referred to as the action level, which is an airborne asbestos concentration of 0.1 fiber/cc as an eight-hour time-weighted average. Concentrations at this action level, even though the PEL standard is not exceeded, cause certain requirements or responsibilities for the employer. Exposure Monitoring: Whenever exposures to asbestos may be foreseen to exceed the action level of 0.1 fiber/cc, exposure monitoring la required to be conducted at Intervals no greater than six months. Determinations of employee exposure ere to be made from breathing zone air samples that are representative of the eight-hour time-weighted average of the various employees in various Job classifications in various work areas, for each shift if different. At this faoility, certain employee exposures can be foreseen to be above tha action level. Therefore, representative employee monitoring at six-month intervals will continue to he conducted as usual. Tbe standard requires that the employer shall, within 15 working days after receipt of tbe results of any monitoring performed under the standard, notify the affected employees of these results In writing. Whenever monitoring results Indicate that the permissible exposure limit has been exoeeded, the written notification*is required to contain the aorreotivc action being taken by the employer to reduce employee exposure to or below the permissible exposure limit. P-EAT-0328 F-AB 018094 Acceturo v. A bex Corp., et aL, Superior C t, L a w Division, Middlesex Cty., Neiv Jersey, Docket No. M ID -L-6601-99-A S ; 10/03/05. Acceturo~v. A bex Corp., et aL, Superior CL, Law. Division, M iddlesexC ty., New Jersey, Docket No. M LD-L-6601-99-AS; Observation of Monitoring: The employer shall provide affected employees or their designated representatives an opportunity to observe any monitoring of employee exposure to asbestos conducted in accordance with the Exposure Monitoring paragraph of the standard. Where any protective equipment Is required In any area in which the observation of monitoring will take place, the observer shall be provided with and required to uae such protective equipment. Regulated Areas: Wherever airborne concentrations of asbestos are in excess of the permissible exposure limit, the employer shall establish regulated areas, demarcate and limit access to these areas, provide and require the use of respirators for each person entering these areas, and prohibit certain activities in these areas. Currently, exposure monitoring data for this facility has indicated that there are not any areas that are above the permissible exposure limit of 0.2 fiber/co. Therefore, regulated areas are not required by the standard In this facility. However, in the work area in which brake shoes are riveted and grinded, signs have been erected demarcating this work area, as facility policy. Also, warning signs have been provided at the opening to thB eoolosure around the baghouse hopper. Although not required by the standard because the permissible exposure limit is not exceeded, J.t is strongly recommended that the prohibited activities that would bo a requirement for regulated areas still be adhered to by employees In the brake shoe riveting and grinding work area. These prohibited aotlvities are eating, drinking, smoking chewing tobaoco or gum, or applying ooametloa in the area. Additionally, access to this area should be limited only to those persons authorized or with a work-related need. Methods of Coaplianne; In order to reduce and maintain employee exposure to or below the permissible exposure limit of .0.2 flber/oc, the standard requires that the employer institute engineering oontrols and work practices, except to the extent that such controls are nqt feasible. Respiratory proteotlon aannot be used as a means of compliance with the permissible exposure limit, except in aertain specified circumstances. An example of engineering controls would be local exhaust ventilation and dust collection systems, designed, constructed, installed and maintained in accordance with good practice. Examples of work practices would be the use of wet methods 1 P-EAT-0329 HAH (118695 A cceturo v. A bex C o rp .,e t aL, S uperior CL, Law D iv is io n Middlesex Cty., Nmv Jersey, D ocket No. M ID -L -6 6 0 1 -9 9 -A S ; 10/03/05. where feasible and the prohibition of the use of compressed air to remove asbestos or clean. Prior to the effective date or this amended standard, this facility undertook a program to upgrade engineering controls and work practices. As demonstrated by recent results from exposure monitoring, it has been Indicated that the program has achieved compliance with the permissible exposure limit. A description of the specific engineering controls and work practices installed or implemented at this facility will be discussed in detail later. ft Housekeeping: The standard requires that the following housekeeping procedures and practices be followed: (1) All surfaces shall be maintained as free as practicable of accumulations of dusts and waste containing asbestos. (2) Ail spills and sudden releases of material containing asbestos shall be cleaned up as soon as possible. (3) Surfaces contaminated with asbestos may not be cleaned by the use of compressed air. (4) HEPA-filtered vacuuming equipment shall be used for any vacuuming. _j/ (5) Shoveling, dry sweeping and dry alean-up of * asbestos may be used only where vacuuming and/or wet cleaning are not feasible. jJ-- (6) Haste, scrap, debris, bags, containers, "" equipment, and clothing contaminated with asbeatos consigned for disposal, shall he collected and disposed of in sealed impermeable bags, or other closed, impermeable containers. It is facility policy that these housekeeping procedures be followed. ! 6a: i: 0\ I\ 2 'O I I u 55 ev S' $' $ 8. |! ! -5! 55. a: n* Q* P-EAT-0330 CS u. .55 hi t CO -4 <3 vj CU & 3 8 CAB 0186% s a bS u u Abex Corp., et a l, Superior C t, Law Division, Middlesex Cty., New Jersey, D ocket No. M ID -L-6601-99-A S ; 10/03/05; Accem ro v. A bex Corp., e ta l, S uperior CL, Law Division, Middlesex Cty., New Jersey, Docket No. M LD -L-6601-99-AS; Respiratory Protection; In oases where the permissible exposure Unit of 0.2 fiber/co la exceeded, the employer la required by the standard to provide respirators and ensure that they are used. Respirators, where required, are to be aeleoted for degree of protection in accordance with Table 1 of the standard, relative to the extent that the permissible exposure limit ia axoeeded. Respirators are required by the standard to be used in the following circumstances: (1) During the interval necessary to install or implement feasible engineering and work practice controls. (2) In work operations, suoh as maintenance and repair activities, or other activities for which engineering and work praotice controls are not feasible. (3) In work situations, where feaaible engineering and work practice controls are not yet sufficient to reduce exposure to or below the exposure limit. (t) In emergencies. Where respirators are required by the standard, the employer is required to soleot and provide the appropriate type of respirator as speolfied in Table I of the standard. Where respiratory protection is required, the employer is required to Institute a respirator program and perform respirator face fit testing in accordance with the procedures and requirements of the standard. For all employees in which this training program is intended, ocnduoblng their assigned duties using installed engineering controls and following implemented work practices, respiratory protection 13 not required by the standard because data from previous exposure monitoring has indicated that the permissible exposure limit of 0.2 fiber/co is not being exceeded. However, a3 facility pplicy, a degree of respiratory protection is required for certain job classifications for additional protaotion for affected employees. For employees whose Job assignments include riveting or grinding brake shoes, 3M Brand 0710 single-uae respirators are provided by the facility. New respirators are provided at. the beginning of each shift, as desired by the affected employee during the shift, or when breathing becomes difficult. The used respirators are appropriately discarded as asbestos-contaminated waste. There is no need for a sanitation program for these disposable respirators. V) I CsR K. a (U P-EAT-0331 EAD 01869/ u 00 0 *o Co 0\ Os i <o VO VO ft *>* u Q I1 .b i Although short-torm, the duties assigned to the employee responsible for the dally baghouse hopper lnspootlon and cleanout, a3 necessary, subject that employee to a potentially Increased concentration af airborne asbestos. However, based on current exposure monitoring data, when the eight-hour timeweighted everage for this employee is calculated from the 3hort-tern concentration during baghouse cleanout and the conoentratlon for the remainder of the work shift, the permissible exposure limit is not exceeded. As facility policy, however, during baghouse hopper duties, the employee is required to use a Willson Brand 1210 reusable air-purifying respirator with RIO replacement filters. The respirator, assigned for the exalusivi^upe. of the employee, and replacement filters are provided by the facility, 41c. replacement filters are provided at the beginning of each daily use, as desired by the employee, during the use, or when breathing becomes difficult. The used filters are appropriately discarded as asbestos-contaminated waste. *n 1 P <0 VO VO l I u o C| S & I ' < 3 Vj a& 6& 3 -o 3 *Q <5 s a *u u 8 1 S p-EAT-0332 HAD 018698 ai u u <r> trj 1! On 1 Vo 4 1 I S o Ci ! i 1 3 :os .a Q s V. 0 1 Co -j CJ *Wl CO & <3 8 -Cl C5 * I J For any affected employee who desires an additional degree or protection, any one of the following reusable respirators will bo provided and assigned Tor the exclusive use of the employee, although not required by the standard: (1) Willson Brand 1210 with replacement filters. (2) Half-mask or full faaeplece air-purifying respirator equipped with high effioiency filters. (3) Powered air-purifying respirator equipped with high efficiency filters. Respirators, where applicable, are selected, assigned, maintained, fitted and inspected in accordance with this facility's written Respirator Protection Program, Protective Work Clothing and Equipment: If an employee la exposed to asbestos above the permissible exposure limit, or where the possibility of eye irritation exists, the standard requires chat the employer shall provide to the affected employees appropriate protective work clothing and equipment, such as: (1) Coveralls or similar full-body work clothing. (2) Gloves, head ooverings, and foot coverings. (3) Face shields, vented goggles, or other appropriate protective equipment. ir the protective work olothing and equipment are required by tho standard, there are associated requirements for removal, storage, cleaning and replacement of the clothing and equipment. For all employees in which this training program is intended, conducting their assigned duties using installed engineering controls and following implemented work praotioes, protective work clothing and equipment should not normally be required by the standard because data from previous exposure monitoring has indicated that the permissible exposure limit is not being exceeded. However, for the previously stated reasons, the employee assigned to daily baghouse hopper inspection and oleanout is required by facility policy to wear disposable protective clothing during the short-term interval in which bagbbuse hopper duties are talcing place. Upon completion of these duties, the 12D p-EAT-0333 EABUIB69 A cceturo v. A b e x Corp., e t a l, Superior C t, Law Division, Middlesex Cty., New Jersey, D ocket No. M ID -L-6601-99-A S , A cceturo v. Abex Corp., e ta l, Superior C l, Law Division, Middlesex Cty., New Jersey, D ocket No. M ID -L-6601-99-A S ; protective clothing la appropriately discarded as asbestos-contaminated waste. For any other affected employee who desires an additional degree of protection, protective work aiothing and equipment will be provided to the employee, although not required by the standard. Hygiene Facilltiea and Practices: For employees who work in areas where tbeir airborne exposure to asbestos is above the permissible exposure limit, the standard requires that the employer provide clean change rooms, showers, and lunchroom facilities meeting specific requirements. Where the permissible exposure limit Is exceeded, the employer Is required to ensure that affected employees do not leave the workplace or enter the lunahroom facilities wearing any clothing or equipment worn during the work shift, and that affected employees wash their hands and faces prior to eating, drinking, or smoking. Medical Surveillance: For all employees who are or wilt ho gxpesod to airborne concentrations of fibers of asbestos at or above the action level of 0.1 fiber/co, the standard requires that the employer Institute a medioal surveillance program for these affected employees. The medioal surveillance program la required to include preplaoemont examinations having certain requirements prior to an employee being assigned to an occupation exposed to airborne concentrations of asbestos, periodic examinations having certain requirements on an annual basis, and termination of employment examinations, similar to periodic examinations, given within 30 calendar days before or after the date of termination of employment. One point of interest in this revised standard pertaining to periodic annual examinations, chest roentgenograms { or X-rays) are no longer required to he conducted annually, but can be done at a frequency specified in Table 2 of the standard. The standard requires that the employer shall ensure that all medical examinations and procedures are performed by or under the supervision of a licensed physician, end shall be provided without cost to the employee and at a reasonable time and place. lh.e employer Is required to provide specific information to the examining physician. The employer is required to obtain a written signed opinion from the examining physician, containing the results of the medical examination and other specific information. The employer is required to provide a copy of the physician's written opinion to the affected employee within 30 days from its receipt. <5 cr s? 3 I 3 d X. 6 qi a6 P-EAT-0334 aX. qi F.AB 018700 Acceturo v. A bex Corp., et a t, S uperior C t, Law Division, Middlesex Cty., New Jersey, Docket No. M ID -L-6601-99-A S ; 10/03/05. Acceturo v. A bex Corp., et a t, S uperior CL, Law Division, Middlesex Cty., N p v Jersey, Docket No. M JD -L-6601-99-AS; 0/03/05.! At this facility, certain employee exposures can be foreseen to be above the action level. This facility has previously had and will continue to have a medical surveillance program for these affected employees. Communication of Hazards to Employees: For regulated areas in which the airborne concentration of asbestos is above the permissible exposure limit, warning signs are required to be provided and displayed at all approaches to regulated areas. Exposure monitoring data has Indicated that tbis facility Is not required to have any areas designated as regulated areas. However, as previously described, warning signs have bean provided as an extra precaution around the work area in which brake shoes are riveted and ground, and at the opening to the enclosure around the baghouse hopper, Warning labels are required to be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos, or to their uontainers. The use of warning labels is the pollay of this facility. Material Safety Data Sheets (MSDSs) are reoeived from all manufacturers or suppliers of incoming asbestos-containing materials. MSDSs arn provided by this facility with all asbestos-containing products supplied by this facility. For all employees who are exposed to airborne concentrations of asbestos at or above the action level, the employer is required to institute a training program and ensure tbB participation of ail affected employees in the program. The training program presented here includes all the elements required by the standards. The training program la required to be provided prior to or at the time of initial assignment and at least annually thereafter. The employer is required to make a copy of the OSHA general industry standard and its appendloes readily available without coat to all affeoted employees. Hecordkeeplng: The employer is required by the standard to keep certain records for specified periods of time: 0) Records of exposure measurements are required to be maintained for at least 30 years. (2) Objective data for exempted operations are required to be maintained for the duration of the employer's reliance on such data. ** ~ P-EftT-0335 l-AB 018701 A cceturo v. A bex Co/p., e ta l, S uperior C t, Lcnv Division, Middlesex Cty., New Jersey, D ocket No. M ID -L-6601-99-A S ; 10/03/05. A cceturo v. A bex Corp., et a t, S uperior CL, Law D ivision, M iddlesex Cty., New Jersey, Docket No. M ID -L-6601-99-A S ; 10/03/05, (3) Medical surveillance records for eaoh employee are required to be maintained for the duration of employment plus 30 years. (4) All employee training records are required to be maintained for one year beyond the last date of employment of that employee. Upon request by subject employees or their designated representatives, exposure records- and employee medical records are required to be made available for examination and copying. ' Appendices to the Standards: The OSHA general industry standard contains several appendices for support bo the standards. These appendices inalude the mandatory OSHA Reference Method and the non-mandatory, but recommended, detailed prooedure for asbestos sampling and analysis. An appendix presents mandatory qualitative and quantitative fit testing procedures for respirators required by the standard. Appendices related to medloal surveillance programs include mandatory medical questionnaires and mandatory interpretation and classification of cheat roentgenograms procedures. Also inoluded are non mandatory substanoe technical Information for asbestos and non-mandatory medical surveillance guidelines for asbestos. A3BE5T05-C0KTAIHING MATERIALS USED IN MANUFACTURE Certain types of brake linings used in this facility In the manufacture of brake shoes contain asbestos. The containers in which these brake linings are received from suppliers have asbestos warning labels affixed. Other types of brake linings used in this facility do not contain asbestos; the containers in which these linings are received do cat have asbestos warning labels affixed. Tho amounts of the various types of brake linings used In manufacturing varies at any point in time, dependent upon the orders of the purchasers of the final product. Certain job classifications have beeo identified as having potential employee exposures to asbestos above tbe action level. At this time, exposure monitoring has indicated that the exposure levels of these job classifications have bean reduced through various means to below the permissible exposure P-EAT-0336 l-AR 018702 A cceiuro v, A bex Corp., etaL, Superior C t, L a w Division, Middlesex C ty N e w Jersey, Docket No. M W -L -6 601-99-AS; 10/03/05. Acceturo v. A b e x Corp., etaL, Superior C t, Law Division, MiddlesexCty.}.New Jersey, Docket No. M ID -L-6601-99-A S ; 10/03/05. level- The fallowing ia a list of thBae Job classifications, inaludlng a descriptions of the facility location and the manner of .use, release and storage of asbestos-containing materials. (1) Cast Shoe Assembly: located in the cast shoe assembly area; cast shoes are assembled; asbestos fibers may be released during handling and assembly. (2) Riveting: located In the brake shoe riveting and grinding area; brake linings are riveted to shoes; asbestos fibers may be released during bandling of linings and riveting linings to shoes; brake linings are reoelved at the work area in cardboard containers and the riveted 'shoos are stacked onto pallets. (3) Grinding: located in the brake shoe riveting end grinding area; the ILnings on certain brake shoes require surface grinding; asbestos fibers may be released during handling of shoes and grinding on linings; brake shoes are received at the work area on pallets and are replaced onto pallets after grinding. (H) Baghouse Hopper Inspection and Cleanout: located adjacent to the exterior of the facility building at the close capture ventilation fabric filter baghouse; on a daily basis, a short-term duty includes inspecting the baghouse hoppers for bridging of oolleated dust and the plastic-lined waste drums under the hoppers for remaining capacity, and, as necessary, removing and sealing full waste drums and replacing empty drums; asbestos fibers may be released during tha inspection and during the removing, sealing and replacement of drums. P-EAT-0337 EAB 018703 Acceturo v. A bex Carp., etaL, Superior C t, L a w Division, M iddlesex Cty., New Jersey, D ocket No. M ID -L-6601-99-A S ; Acceturo v. A bex Corp., et aL, Superior C t, Law D ivision, Middlesex Cty., New Jersey, Docket No. M ID -L-6601-99-A S ; RECORD Op PARTICIEATIOH IK THE OCTOBER 1986 EHPLOTEB TRAIHIBQ PROGRAM FOB ASBESTOS EATOH CORPORiflOH Gallatin, Tennesaaa As a necessary part of employee recordkeeping, this record documents participation of the employee designated below in the Oataber 1906 Employee Training Program for Asbestos.- Tha written material presented in this training program is on file at the Gallatin, Tennessee facility of Eaton Corporation. This training program .included presentations of the following information: I. Health effeats associated with asbestos exposure and the relationship between smoking and exposure to asbestos In producing lung canoer. II. A review of the OSHA general industry standard for asbestos (29 CFR 1910.1001), o inoludlng appendices, with emphasis placed on the purpose, proper use, and limitations or respirators and protective clothing, and also the purpose and a description of the medical surveillance program. III. Tha quantity, location, manner of use, release, and storage of asbestos, and tho specific nature of operations which could result in exposure to asbestos. IV. The engineering aontrols and work practices associated with the employee's job assignment, V. The specific procedures implemented to protect employees from exposure to asbestos, suoh as appropriate work prnctioea, emergency and olean-up procedures, and personal protective equipment to be used. I have attended the employee training program for asbestos outlined above and b&va received a oopy of 29 CFR 1910.100,1. I understand the requirements presented in the training program. Verification Name:________ Signature:__ Date: I P-EAT-0338 CAL) 1H8704 A cceturo v. A bex Corp., etaL, Superior C t, Law Division, M iddlesex Cty., New Jersey, D ocket No. M ID -L -6 6 0 1 -9 9 -A S ; 10/Q3/0S. Acceturo v. Abex Corp., et a l, Superior CL, Law Division, Middlesex Cty., New Jersey, Docket No. M LD-L-6601-99-AS; 0 Health Hazards Associated with Asbestos-Containing HaterLaIs . Certain materials used in the manufacturing process contain asbestos. Bcaause there are health hazards associated with the use of aahastas, various precautionary measures have been implemented which require oonaoientious compliance. Asbestos is the name of a naturally-occurring group of fibrous mineral substances, Including chryaotile, amosita, orocidollte, anthophyllte, aotinoiite and tremolito. Asbestos has been used in a multitude of aommeroial products because of its beneficial properties: non-combustible, resistant to oorroslon, high tensile strength, low electrical conductivity, and durability. However, there are oertain health hazards associated with the use and handling of asbestos-containing materials, most notably associated with the breathing of asbestos fibers that may become suspended In the air. The potential of an asbastoa-contalnlng material to release fibers to the air is dependent upon the degree of friability, which means the ability of that material to be crumbled by hand pressure and thus to potentially emit fibers. Exposure to asbestos Is a serious health hazard. Anytime sc asbestoscontaining material is handled, disturbed or damaged, asbestos fibers may be released into the air. Fibers that are Inhaled or swallowed oan penetrate ' body tissues and cause diseases. Medical studies suggest that theredoes not appear to be a safe level of exposure below which there would be no chanoe of disease. As described by the Environmental Protection Agency, the following diseases cac result from inhalation of airborne asbestos fibers: Asbestosis - A nencanceroua respiratory disease that consists of scarring of lung tissues. Symptoms of asbestosis include shortness of breath and rales, a dry crackling sound in the lungs during inhalation. Advanoed asbestosis is may produae oardlac railure and death. Asbestosis is rarely caused by neighborhood exposure. Lung Cancer - Inhaled asbestos particles can produce lung cancer independent of the onset of asbestosis. In most lung cancer patients, a cough of a change in cough habit is found. A persistent chest pain unrelated to coughing Is the second most common symptom. Heaothellona - This is a rare cancer of the thin membrarte lining of the chest and abdomen. Mast incidences of mesothelioma have been traced dlreotly to a history of asbestos exposure. The earlier in life that one begins .Lnhallng asbestos, the higher the likelihood of developing mesothelioma in later life. Thus, there is concern over exposure'of school children to asbestos, The common symptoms are shortness of breath, pain in the walls of the chest, or abdominal pain. Mesothelioma is always fatal. Other Cancers - Some medical studies have suggested that exposure to asbestos is responsible for some cancers of internal organs including the esophagus, larynx, oral cavity, stomaoh, oolon, and kidney. It La theorized that Inhaled asbestos fibers are absorbed into the blood stream and carried to these other parts of the body. i P-EJVT-0339 I-AD 0l870.i A c c e tiiro v. A bex Corp., et aL, Superior C l, L a w Division, Middlesex Cty., New Jersey, D ocket No. M ID -L-6601-99-A S ; 10/03/05: A cceturo v. A bex Corp., et aL, S uperior C l, Law D ivision, Middlesex Cty., New Jersey, Docket No. M JD -L-6601-99-AS; 10/03/05. . %A * Generally, symptoms of asbestos diseases do not appear for many years after the Initial exposure to asbestos. However, early disease detection Is possible by medical examinations Including medical histories, breathing capacity tests, and chest x-rays, whloh are provided to all emiiloyeeB who have an exposure potential to an airborne concentration above 0,1 fibers per cubic centimeter of air. Medical studies have shown that exposure to asbestos and cigarette smoking combine to create a slgniflaantly higher risk of developing an asbestos-related disease. The combined effect of smoking and asbestos exposure appears to be more thani the simple addition of the individual risks. In faot, statistics compiled by the National Institute of Occupational Safety and Health indicate that the risk of contracting lung oancer for a smoker exposed to asbestos is rather like a multiplication of the individual risks of ^ exposure to asbestos and smoking. EPA reports that some information suggests ' that quitting smoking can reduce this high risk. A standard for asbestos has been promulgated by the Occupational Safety and Health Administration (OSHA), whloh inoludes permissible exposure limits as an eight-hour time-weighted average concentration of 2 fibers, longer than five micrometers, per cubic centimeter of air (ribers/oc) and as a oeiling concentration of 10 flbers/cc. Because OSHA determined that workers exposed to asbestos under conditions existing under that standard faced a grave danger of developing incurable cancer and asbestosis, and that an immediate reduction in exposure levels to 0.5 fibers/oo, eight-hour, time weighted averago was necessary to protect such employees from this grave danger, OSHA reduced the permissible exposure limit in an Emergency Temporary Standard (ETCS) issued on November >1, 1983* Although this ET3 has been stayed in the court, It is being followed pending a permanent revision of the standard. The ourrect standard also presents requirement methods for oomplianee (engineering oontrola and work practices), personal protective equipment, exposure monitoring, caution signs and labels, housekeeping, recordkeeping, and medical examinations. The asbestos-containing materials used in the manufacturing process are brake blacks and brake linings. These materials, as received from suppliers, are resin-bonded and are relatively non-friable, whloh reduces the potential for asbestos fibers to be released and become airborne. However, it is recognized that fibers may be released during various phases of the manufacturing process, suoh as unpacking, handling, installation, riveting, grinding, and repackaging. Therefore, various precautionary measures have been implemented in our manufacturing prooess to reduae the potential for exposure to airborne asbestos fibers. . These precautionary measures include engineering oantrols suoh as 'enclosure of oertain operations, exhaust ventilation at work stations, and dust filtration of air from ventilation systems. For housekeeping, HEPA vacuuming equipment, dust suppressant agents, and properly labeled disposal dontalners have been provided. Respiratory protection meeting the requirements of the ETS is provided and required for all employees who work with asbeotos-cootalnlng materials or wastes. Personal and environmental monitoring for asbestos exposure concentrations are oondueted semi-annually. The monitoring data are used to determine compliance with permissible exposure limits and to assess any work practices that might require correction. This data is available for review by P-EAT-0340 GAD 018706 A cce tiiro v. A b e x Corp., et a l, Superior C t, L a w Division, Middlesex Cty., New Jersey, D ocket No. M ID -L-6601-99-A S ; A cceturo v. A b e x Corp., e ta l, S uperior C t, L a w Division, Middlesex Cty., N o v Jersey, D ocket No. M W -L -6 6 0 1 -9 9 -A S ; affected empllooyyeeeess. ' c Employees whose work requires them bo come in contact with asbestoscontaining materials or wastes should properly utilize all equipment provided for minimizing asbestos exposure. In addition, the fallowing work practices should be conscientiously adhered: 1. Appropriate personal protection equipment should be properly used at times in accordance with the directions provided in training programs. H. All handling of asbestos-containing materials during unpacking, riveting, installing, grinding, stacking, and packing should be done in a manner to minimize disturbing or damaging surfaces, except under exhaust ventilation. 3. Exhaust ventilation systems provided for work stations should be properly used. Any problems observed with ventilation systems should be immediately reported to supervisors. 4. All activities ia work areas where asbestos-containing materials are handled should be conducted in a manner to minimize the disturbance of settled dust. This Includes stacking parts, moving pallets or equipment, and housekeeping. 5. Housekeeping in areas where asbestos-containing materials are handled should be conducted by HBPA vacuuming or 3urractant wet wiping. Dry sweeping should not bo conducted. Waste materials should be placed In properly labeled containers provided for disposal. 3 I P-EAT-0341 HAD 018707