Document QkyVKdbKNeaqpkeqwR1J627JR

G. E. SALINAS MR. C. A. PHILLIPS 1978 February 15 cc: Mr. A. A. Dohmann Mr. W. H. Floyd Mr. D. J. Fisher 1Mr. R. E. Podhora Mr. K. M. Rose RE: ASBESTOS CONTENT IN CALIDRIA P.G-244 THIXOTROPIC ADDITIVE When this additive was first ordered in 1976, questions and concerns arose about its asbestos content. At that time, C. E. Steele, R. E. Podhora, and E. P. Cox were involved in determining the potential hazard of this material. It was decided that this material was hazardous only when it was not handled or used properly. After the material was purchased, tests were run as a safeguard by Dr. M. F. Jones, R. E. Podhora, and the manufacturer's representative from Union Carbide, to determine the amount of hazard the material presented. Tests showed that the amount of asbestos dust given off during its handling and use was negligible. However, protective apparel and equipment were recommended for use to reduce potential injuries due to accidents. Because this material is still used in Chlor-Alkali and is stocked in the Storeroom, the writer has requested that this material be removed from D. C. Stores and placed in the proper Stores Stock No. X270-625-0004. If there are any further questions or comments, please contact the writer. GES:ga G. E. SALINAS APC 004338  *! I UNION CARBIDE CORPORATION 4G2b ROYAL AVENUE * NIAGARA FALLS. NF.W YORK 14302 TELEPHONE: (710 235-3311 EXT. 6567 PRODUCT: Chrysotile Asbestos TRADE NAMES: "Calidrin" Asbestos CHEMICAL FORMULA: Mg6(OH)8Si4O10 BOILING POINT AND MELTING POINT: Not Pertinent -1 SPECIFIC GRAVITY (H?0 - 1): 2.45 VOLATILE CONTENT: Absorbed Water 1 -- 4% By Weight. Structural Water Approximately 13% by Weight. APPEARANCE: Pellets or Fine White Powder. No odor. Very Slight Solubility in Water. Not Applicable. Material is not Combustible. No Fire or Explosion Hazard. INERT MATERIAL: No Decomposition or Polymerization Conditions. PERMISSIBLE EXPOSURE TO AIRBORNE CONCENTRATION: The current standard of the Occupational Safety and Health Act of 1970 contains the following exposure limits: "The 8-hour time-weighted average airborne concentration of asbestos fibers to which employees are exposed shall not exceed 5 fibers per milliliter greater than 5 microns in length, as determined by the membrane filter method at 400-450X magnification (4 millimeter objective) phase contrast illumination. No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers per milliliter, longer than 5 microns." (Federal Register -- Vol. 37. June 7, 1972, page 11320). EFFECTS CF OVER EXPOSURE: Prolonged over exposure may result in lung damage. EMERGENCY AND FIRST AID PROCEDURES: Not applicable. Material has no acute toxicity. 4y . ",uj STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED: Avoid inhalation of dust. Remove spilled material by vacuum cleaner or by water wash. WASTE DISPOSAL METHOD: If reasonably foreseeable handling will not produce airborne concentrations in excess of exposure limits, no special procedures are required. When limits are likely to be exceeded, waste and scrap shall be collected and disposed of in impermeable sealed bags or other closed, impermeable containers, suitably labelled. Union Carbide Corporation assumes no responsibility and makes no warranty, expressed or implied, repre sentation, promise, or statement as to completeness, accuracy, or currency of any data provided. APC 004340 VENTILATION: Local exhaust for each operation is preferable. (See American National Standards Institute booklet, Z9.2 -- 1971.) General area exhaust is acceptable. No special considerations. PROTECTIVE GLOVES: None EYE PROTECTION: None OTHER PROTECTIVE EQUIPMENT: If time weighted average or ceiling concentration limits are exceeded, clothing providing whole body covering shall be supplied and its use required. ______ ____ ______ ___________________ _________________ RESPIRATORY PROTECTION*11 The current standard of the Occupational Safety and Health Act of 1970 contains the following guidelines: AIRBORNE CONCENTRATION*21 j 8-HOUR EXPOSURE*31' CEILING CONCENTRATION REQUIRED MASK TYPE J ACCEPTABLE MODEL*41 5 maximum 10 maximum None required. |- 50 maximum 500 maximum 100 maximum 1000 maximum U.S. Bureau of Mines Schedule 21B. Willson Model 1009 , Negative pressure on breathing. j with R-520 Filter and ! Covers nose and mouth. M-S-A No. 86432 with i Type H, Ultra Filter I and others. U.S. Bureau of Mines Schedule 21B Powered filter positive pressure. Personal Environment Systems, Inc. Hood 330 or 351 with 1900 Scries filter. Over 500 - U.S. Bureau of Mines Schedule 19B j Willson GA2H M-S-A Type C positive pressure, air supplied. ! Lead-Foe and others. 1 (1) Allowed only during the time required for installation of engineering controls, when engineering controls are not technically feasible or adequate, and in emergencies. An employee may not be assigned to tasks requiring respirator if his most recent medical examination indicates he will be unable to function normally. (2) Fibers per milliliter greater than 5 microns in length, as determined by the membrane filter method at 400-450X magnification (4 millimeter objective) phase contrast illumination. (3) 8-Hour time weighted average. (4) Examples of masks approved by U.S. Bureau of Mines under the appropriate schedule. Reference -- Federal Register, Volume 37, Pages 11318-11322, June 7, 1972. If the time weighted average and ceiling concentration limits are not exceeded, no special precautions are required except: a) Bag damage and dusting should be minimized and dust inhalation avoided. b) Every place of employment where asbestos fibers are released must be monitored by December 7, 1972 to determine exposure levels. c) A comprehensive medical examination is required for any employee exposed to airborne fibers within 30 days of first such employment, annually thereafter and on termination of employment. When exposure limits are exceeded, reference should be made to the regulation for details on caution signs, monitoring, change rooms, protective clothing laundering and record keeping. APC 004341 CALIDRIA" ASBESTOS RG-244 HEALTH AND OSHA INFORMATION February 1, 1875 Union Carbide Corporation Mining and Metals Division "Calidria" Asbestos Marketing and Technology Department Niagara Falls, New York INTRODUCTION The Williams-Steiger Occupational Safety and Health Act was passed in 1970 with the stated objective of assuring every American worker a safe and healthy workplace. The first health standard promulgated under this act coverea exposures to airborne asbestos and went into effect on June 7, 1972. This asbestos standard survived a broadside legal attack filed by the IUD and is now being revised by OSHA to clear up certain ambiguities. The revised version is expected about midyear 1975. Asbestos has received a great deal of attention and publicity in the last several years. Unfortunately, much of the media treatment of the subject has been emotionally oriented end distorted and, in some cases, bordering on the sensational and untrue, '-`.any users of asbestos and products containing asbestos have been mislead regarding the safety of asbestos and what is needed to comply with the OSHA requirements. The information presented in this folder has been collected as a service to "Calidria" asbestos users. It is intended to help put both the health and OSHA compliance questions in a reasonable perspective. Included are: 1. A summary of the main provisions of the OSHA Asbestos Standard and a copy of the regulations. 2. Airborne asbestos fiber count data obtained by Union Carbide at a variety of industrial locations during the blending of RG-244 into polyester resin, the spraying of the asbestos containing resin, and the sanding and grinding of the finished parts. 3. Two pamphlets, "What You Should Know About Asbestos And Health" and "Asbestos and Health" published by the Asbestos Information Association/North America. The first is an employee oriented discussion of both health and OSHA while the second addresses the health question. Additional copies are available on request. 4. A Material Safety Data sheet and analytical data on "Calidria" asbestos. OSHA REGULATIONS Introduction After extensive public hearings, a standard for Exposure to Asbestos Dust was published in the Federal Register, Volume 37, No. 110 on Wednesday, June 7, 1972. A copy of this standard is included with the literature at the back of this booklet. Basically, the standard can be divided into the following five major categories: 1. Standards: Defines the allowable airborne asbestos fiber content in the workplace. APC 004343 o 2. Monitoring: Defines the method of collecting samples and measuring the airborne fiber concentration. 3. Methods of Compliance: Defines acceptable procedures to met the allowable limits. 4. Medical: Specifies frequency and type of medical examinations required. 5. Warning Signs and Labeling: Specifies when warnings .are necessary and the wording of such warnings. The essential features of these categories are discussed in the remainder of this section. Before looking at these, however, it should be made clear that in the most basic sense the regulations require that every place of employment where asbestos is used must be monitored to determine the exposure level of airborne asbestos fibers. lf_ the levels are well within the allowable limits, the only additional requirements are those relating to medical examina tions. If the levels are not clearly witnin compliance, all provisions of the regulations apply. There has been a great deal of confusion on this distinction, occasionally even with OSHA field inspectors. Standards The present OSHA standards set a ma> 'mum exposure to airborne asbestos fiber of length longer that 5y of: 1. An 8-hour, time-weighted average (TWA) of 5 fibers/cc. 2. A ceiling concentration of 10 fibers/cc. On July 1, 1976, the allowable TWA is reduced to 2 fibers/cc. The ceiling concentration remains unchanged. Note particularly the use of the time-weighted average over the 8hour shift. An operator performing one or two short additions of RG-244 per shift, as is typical of polyester producers, would have his exposure during the dumping time averaged with zero (or a very low background level) for the rest of the shift. This, obviously, tends to greatly reduce the 8-hour TWA. Monitorinq The regulations require an initial monitoring to determine whether the workplace meets the required levels. Thus: "Within six months of publication of the regulations (June 7, 1972), every employer shall cause every place of employment where asbestos fibers are released to be monitored in such a way as to determine where every employee's exposure to asbestos fibers is below the prescribed limits." APC 004344 * -3- Monitoring usually is done by tin: membrane filtcr/personal air sampler, which can be obtained from a number of manufacturers. The personal air sampler draws workplace air onto a filter which collects the particulates and fibrous dust in the air. This filter is then placed under a microscope and the number of fibers counted. After the count is complete, the actual fiber concentrations, expressed as fibers per cubic centimeter of air, are calculated by formula. After the initial monitoring,' the regulations state: "...samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees. In no case shall the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos may reasonably be foreseen to exceed the 1imits prescribed by paragraph (b) o~f this section." The section that has been underlined shows that if the initial monitoring give levels that are well below the allowable limits and no change is made in the method of operation which would increase dust levels, no further monitoring is required. It is a good and recommended practice, however, to monitor at regular intervals to make sure that the limits are being met. It should also be understood that you cannot be cited legally for exceeding the allowable limits on the basis of your own monitoring. OSHA must base any citations issued on their own tests. Methods of Compliance If monitoring shows plant or operation to be in excess of the limits, a number of ways are prescribed to bring it into compliance. These include, but are not limited to, engineering controls such as isolation, enclosure, exhaust ventilation, and dust collection. Certain work and housekeeping practices and waste disposal procedures are specified. Respirators, special clothing, and change rooms are also required under certain conditions. It is most important to understand that these compliance procedures are required only if the allowable airborne asbestos fiber limits are being exceeded or can be expected to be exceeded under reasonably foreseeable circumstances. They are not automatic requirements that apply wherever asbestos is present. Medical Examinations Preplacement, annual, and termination medical examinations must be provided or made available by the employer for any employee "...engaged in occupations exposed to airborne concentrations of asbestos fibers." These medical records must be kept for 20 years and are available to the employee's physician. This section has proved to be one of the most confusing in the regulations since it does not define any cutoff level below which examinations are not required. OSHA has declined to provide any official clarification but reports from plants that have been inspected indicate that they are generally taking the very reasonable approach of requiring examinations for employees who regularly handle asbestos, who are regularly in the area where APC 004345 -4-. asbestos is being handled, and for maintenance personnel who work on asbestos handling equipment. It is anticipated that the revised regulations will provide a more specific definition such as that originally proposed by NI OSH in the Criteria Document: "For purposes of this requirement the term 'exposed to asbestos' will be interpreted as referring to time-weighted average exposures above 1 fiber/cc or peak exposures above 5 fibers/cc." Caution Signs and Labeling The regulations require that: "Caution signs shall be provided and displayed at each location where airborne concentrations of asbestos fibers may be j_n excess of the exposure limits prescribed in paragraph '(b) of this section." Wording for the signs is also specified. There have been some cases where the OSHA inspectors have taken this to mean signs are required at any location where asbestos is present, regardless of whether or riot the exposure limits are exceeded. Although this is clearly incorrect, there has been a tendency to post the signs arid not contest the citation. The regulations also require that: . "Caution 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 u_Sje, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released." Wording for these labels is also specified. AIRBORNE ASBESTOS FIBER COUNTS Introduction This section presents air sampling data obtained in a variety of situations, mostly for typical industrial operations. All samples were collected on Millipore filters and counted at 400X with phase contrast illumination in accordance with OSHA procedures. Particles which satisfied the L/D >3 criteria but which, in the judgment of an experienced counter, could not possibly be asbestos were not included in the counts. APC 004346 Presentation of Data Table I shows "Calidria" asbestos RG-244 fiber counts obtained et 3 different polyester manufacturing plants. Typically, several hundred pounds of RG-244 arc dumped into the thin tank in a 10-25 minute period. These samples obtained during the dumping operation thus represent ceiling concen trations. They would normally be averaged with considerably lower numbers for the remainder of the shift when asbestos is not being handled to arrive at the TWA. The highest fiber count found at these eight locations was 2.8 fibers/cc which is well below the allowable limit of 10 fibers/cc. Table II shows the fiber counts at three of the same manufacturing locations at the empty bag collection point. These values are also quite low. Table III shows airborne fiber counts for "small-scale" addition of RG-244 as occurs in a variety of compounding operations. The levels found ranged from 0.4 to 2 fibers/cc. Table IV shows the airborne asbestos fiber count data obtained during the spraying of a variety of asbestos containing resins. Much of the data are for polyester resins, but epoxies and alkyds are also included. The asbestos content of the resins ranged from 0 to 12% by weight. The highest count obtained was 0.6 fiber/cc. Polyester resin parts are often finished by sanding or grinding. Table V shows the airborne asbestos fiber counts obtained during a number of industrial finishing operations on resins with up to^3% asbestos. The highest reading obtained here was 0.4 fiber/cc. Table VI gives the results for a laboratory study where resin plaques containing a variety of fillers were abraided with an electric hand grinder in a small closed room. Even under these extreme conditions, the fiber counts were quite low with 1.2 fibers/cc, the highest observed. APC 004347 TAGI.E i AIRBORNE ASBESTOS EIRCR CUL'MS^- "LARGE-SCALE" CUV,PING OF r.o~ ? (*'100-* E0 Ib./B;itch) Plant A B C D E F G H Data Reference 1929-46-2 1929-30-2 1929-55-1 1929-50-3 1929-26-3 1929-24-2 1929-16-1 Description of Ooeration Dump Sample Bags Time lime L'unocd (Min.) (Min.) 10 10 10 14 9 9 15 21 21 36 12 12 15 8 8 45 20 20 10 24 24 28 . 15 15 Special Vent i 1 :;ti or.t ") CEILING Concentration Fiber Count (Fibers/oc. >5^ ) None 0.7 None 1.2 Hood over thin tank opening 0.7 None 2.4 None 0.5 None, 1.6 Hood over mixing area 0.8 None 2.8 <A11 samples collected in the breathing zone of the operator dumping the RG-244. (21 ' 'Special ventilation refers to dust collection equipment at or near the dumping area that is specifically intended for dust control during the dumping operation. All plants had varying measures of overall building ventilation. TABLE II Plant A B B Data Reference -- 1929-40-3 1929-40-5 AIRBORNE ASBESTOS FIBER COUNTS EMPTY BAG REMOVAL Description of Ooeration Sample taken 3 feet above waste disposal drum for empty bags. (During dumping.) Directly over empty bag stacking area. Taken during dump. Empty bag storage area. Taken during dump as bags were pul in. Sample Time (Min.) 10 23 24 Fiber Count (Fibers/cc. >5^) 0.4 0.6 0.4 APC 004348 TABLE III AIRBORNE ASBESTOS FIBER COUNTS^ "SMALL-SCALE" PUMPING OF RG-244 (1-12 lbs./Batch) End Use Furniture Molding It II II It It II i Pounds Dumped 1 12 1 6 Dump Time (Min.) 10 2.5 11 8 Sample T i me (Min.) Special ,9\ Ventilation' 10 2.5 11 8 None None None Good Hood Ceiling Concentration Fiber Count Fibers/cc >5u 1.5 1.1 2.0 0.9 Gel Coat Mfg. II II II 9 25 25 None 3 3 3 . None 0.7 1.2 /artificial Brick Mfg. II II II 54 1.5 10 4 10 Good Hood 0.9 0.4 Roof Coating Mfg. 12 13 13 None 1.1 ^ All samples collected in the breathing zone of the operator dumping the RG-244. (2) Special ventilation refers to dust collection equipment at or near the dumping area that is specifically intended for dust control during the dumping operation. All plants had varying measures of overall building ventilation. APC 004349 Ainnon;,r Attirsic;. r 1 rm cr.jms - srpy.Tir.r, cr nsn; tvjp s suns Asncsio; Simple tvsior.atlri Comercial Application Date 1 - POlftSTER f.tSl'.'S A. General Purpose Laninatino Prsins G9 Boat manufacture. 12/7/72 Bl-d*r General r-rtese laminating resin. L-13 10/31/74 K-28 11-30 N-34 -4n 1-12 10/8/74 a Approx-^ irate Vt. t Asbestos I Spray Gun Tvoc Opcr*tion Sample line (Win.) Alrborr Asbcsto f iter Concentra (Fibrrs/cc 0.5 0.5 0.5 0.5 0.5 -0.5 0.5 Air-supported chopper. Operator spraying raids with resin 1 chopped glass. Operator spraying resin l chopiud fiber glass. (Includes ` roll-cut tlr.e.) a Operator spraying resin l chopped fiber glass. a Operator spraying resin l chopped fiber glass. a Operator spraying nold with resin. (No glass.) aa aa 24 16 5 4 $5 52 35 0.6 0.1 0.4 C.4 0 o.o: 0.1 ft. Chemical Resistant Resins J-21 Fiber-glass pipe manufacture. 8/13/74 H-26 a Chemical resistant resin. 1.4 Airless. 1.4 a Operator adjacent to autcr.itic spray machine coating 28' manorcls. Operator wiping mandrels. In area near spraying. 23 0.1 14 0.4 J-5 Ship coating. 10/3/74 Chemical 0.7 Air-supported Roll-out man. In 65 0.4 resistant wand. spraying area about resin chopped 1/4 of time. fiber glass. J-7 a aa 0.7 a Operator spraying 41 0.4 Ship hull in cry dock. M-28 a a 0.7 a 23 0 0) Based on total fomjlatlon as sprayed. APC 004350 Unit IV (rn;t IrujrH) airborne r.v.'i.vn rmrg counts - SPRAYING OF RESIN r.vp M'WZ CfVlTMNlv.. .'SCESTOS Sar.plc Desicnation Correrclal ApoHcation i: - trerr resis^ A. 1 tiled Eporv K-B Ship coatln;. K-10 H-10 * 1-27 J-l Date 10/2/74 Binder Approx-^ ^ lute wt. : Asbestos Sprav Cun Tv.t . Epoxy prlner. High build epoxy. * l.S n.s 0 0 0 Airless. Air supported- a a Onrratinn Operator tpre;. ir.; outside i L -.Car a Ship. a Operator snreyirg side of sL*.p fren scaffold. a a Sarple Tire (""> Airbrr. Asbest. i lb< Conccn.r 31 C.2 8 0.2 31 0.1 14 0.3 CO o.c: B. f?0*Y * Coal Tar H-45 Coating dry dock. 10/1/74 K-3 Coatirg ptpe Interiors, IM - AIKYO RESIN FAINT H-7 Paintirg 10/6/74 building exterior. K-3S a Epoxy Coal-tar, solvent. 1 1 1 Alkyd resin. 12 12 "Airless. a Air-supported Mind. Operator spraying side of dry d:z>. from suspir.dcd platform. Operator spraying side of dry dock from fixed scaffold. Operator spraying interior cf 3", C and 12' diameter pipe. Airless pun. a Operator spraying building exterior wall. 11 3B 37 9 S 0.2 0 0.1 0 o.cs (l) Cased on total fcrrulatlon as sprayed. APC 004351 mnosfit AirtsTOS r;cm cp'jnts GRINDING AND SWING rr pi M'i.pA*rn <-YSTfM5 COYMIKIKC A511CSTPS SiT'le fas lf;na i tc*> I /'plication 1. THr.'.VSCT rr^t'i (rt-ivcstcr^ -* Holding furniture parts * Date 3/15/72 1929-<0-4 12/6/72 Pcsin Pollster 1929-82-3 1929- E2-< 1929-82-S 1-13 1-6 Fabrication of reinforced fiber glass pipe. 2/27/73 8/13/74 Tolyester 9 . ,1-26 g-s 1-39 Fabrication of FRP tanks ar.d pipe. 8/13/74 Polyester 1929-64-4 1929-84-5 Production of artificial bricks. N-29 6-25 Production of fiber glass boats. 3/8/73 Polyester 11/26/74 Polyester Asb:?stes Approx Type Wt. I Operation Sample 1 ime (*in.) Airborne Asrestcs fiber Coocenfratton fflbers/cc >1*1 RG-244 0.05 0.05 0.3 RG-144 2-3 RG-244 2-3 2-3 1.4 1.4 RG-244 1.5 1.5 1.5 RG-244 2.0 2.0 RG-244 0.5 0.5 Operator hand sanding snail parts. Operator running power sander with integral hood. Operator sanding and grinding inolded parts. Good heed i ventilating system on grinder. 45 45 23 Operator pulls pipe along line. Saws off end with circular saw. 19 Same operation as 192962-3. 49 Operator removing end of 4S pipe with scarfing machine Operator shaping end of pipe with bell t spigot machine. 16 Operator cutting off pipe end and light grinding on exterior surface. 17 Operator grinding Inside Of 13* 1.0. x 26* tank. Continuation of same operation as 1-26. Operator grinding edges of miscellaneous small parts. 16 5 25 Operator cutting with sabre saw. Operator trirning with sabre saw. 44 39 Operator grinding inside of boat hull. Operator grinding. 11 4 0.002 0.002 0.3 O.l 0.1 0.04 0.3 0.2 0.4 0.3 0.3 0.1 0.2 0.0 0.0 APC 004352 cor~ o4ticCUCO-o->D cr- +S<-D>- <4-- :e --o(Ti- *orCs3--- 4OEi_<D ---<C>J1DJ LO-tCCL>-> rx +-> E <Hf/O> uUV. OoO o o o o o o o o LO O o CM O o u t<d in N Lu j4tOCCtO-OoOD> ^X4ULLSC-JOD>--. -<rCoO&s"D.- *--" E f- o ai U a cr-- iS^-<D >a) -J cioo CL 4-> HU. O Crcio--D- to is) S- ir> r-- o a: CT o 4-> C fO tco o r--a au3 S- CO CD L. CX (D o a- Q. E ro cn o o o o o o C\J o o o CVJ (NJ r-- O CM oo CM r-- CO o i <d CD C EO -- *9 Ura) <r/>- 34-> o ^or O O S- to V? a> trOo OC U*r-.O-- S4->! o CoM OO OO CM r-- O S9 CO CO o O O O o. o +J O o CM LO oE r-- o M O 7a) C3 *0 CO >0 CD Q. -C CD 1-- <0" CM CD cc O' a* CM CD CM CD Q <0* CM CD CC CCDl o I CceD: o *9 CD CM CM o o o o Q 4-> CT> on cn CoOn CoOn CO LD CD a: CD CO CD a: i- u s. i- U CD CD CD (D CD 4-> 4-> M M P ai lO to to to to Q. CD CD CD CD > CD >3 H- r-- r-->n >> r-- >* r-- X o >> O a. o o. aO. aO. rx O UJ CL P o lye ste r 35.0 RG-110 10.0 10.0 10.0 35.0 0.0 0.0 0.0 P o lye s te r 30.0 SG-200 18.0 - 2 .0 50.0 0.3 0.9 0.06 APC 004353