Document RJk20y3VZoZJwo3vBrvqQoJaa

SC'10Q3(I*. 1-40] c ii r-r-1* -- ~r.; CH EMI CAL; COM ? jJ\ . EinoT"^: r,.... DECEMBER 23, l?31c'd. JAi?' I___DATE 5 1S72 to HART MANAGERS/SUPERINTENDENTS____j j thom MANAGER - INDUSTRIAL j HYGIENE - ENGINEERING ; i DEPARTMENT - HEAD OFEf'CE' ; SUBJECT ASBESTOS Lbl:? J The attached copy of an Insulation Hygiene Progress RepurL_i brought to your attention for information and circulation to appr rorlate staff. The Insulation Industry Hygiene Research Program is finan :$Jpj)ontly by the International Association of Heat & Frost Insulators and Asbestos Workers and Johns Manville Corporation. It is also supported by The ......... Sprayed Mineral Fiber Manufacturers Association. Consulaticn and technical assistance is provided by the U. S. Public Health Services Bureau of Occupational Safety and Health. The recommendations set forth in the portions of Holaday and Reitze's "procedures guide for insulation application and removal", printed in this copy, can be expected to set the "standard" for industry practice and con formance under the OSHA. It is recommended that a review of existing practices at all locations be initiated at an early date and evaluated in light of the' likelihood of producing conditions in violation of regulation 1910.93a, Asbestos Dust. N. G. White Attachment . cc - Mr. J. W. Eiger ... Divisions - Manufacturing - Managers Head Office - Engineering Department - Environmental Engrg. - Manager X I LAW 024245 ABS-007424 . r*trcnmnt*f Sciences -..Ltkocttarf - * of Th Ctey Itoivvsiqf of New Ycrfc INSULATION ri/GIENE PROGRESS REPORTS FROM THE INSULATION INDUSTRY HYGIENE RESEARCH PROGRAM ' Irvine J. SeliVoff, M.O., Pro*nm Director VoL 3. No. 4 Wintor 1971 Here Are Some of Many Ways to Reduce Dust pened in other environmental situations. b. Does the qevr material meet engi neering specifications and will it perform adequately under condi tions of use? Dust produced by use of an unventi lated band saw. Without the back light ing used here, much of the dust would not be visible. Cutting pipe with band saw equipped with high-velocity, lew-volume exhaust system. Compare absence of any air borne dust with that shown in uncon trolled cutting (picture left.) --Shipyard Procedures Guide- Helps All Insulation Men The Winter 1970 issue of Insulation Hygiene Progress Re ports announced a joint effort by the Insulation Industry Hygiene Research Program, the U-S. Navy, the Department oi Labor, and insulation manufacturers and contraclors to control shipyard asbestos dust exposures. As part of that cilort, Duncan A. Holaday and William B. Reitze of the IfflRP prepared a procedures guide for shipyard insulation application and removal. Because of its relevance to all insulation work, portions of it are given in this issue of Insulation Hygiene Progress Reports. A complete report was presented by the authors at" the Inter national Symposium on Safety and Health in Shipbuilding and Ship Repairing, at Helsinki, Finland, on August 30, 1971. by Duncan A. Holaday and William B. Reitze The general goal in all insulation work should be to maintain a clean environment.. Measurements of concentrations of asbestos fibers ("dust counts") in the atmosphere can be used to identify sources of contamination and to point out deficiencies in control methods. Primary reliance for control of ex posures, however, must be placed on faithful observance of operating rules. Control of Asbestos-Containing Ousts by Use of Substitute Materials Substitution of materials contain ing reduced proportions of asbestos or no asbestos at all, is becoming more common in ship construction. Before a material is substituted for asbestos, however, two questions must be carefully considered: a. Has the substitute material bees tested? If not, it may turn out to be of the same or greater hazard than the material of known haz ard. This sort of thing has hap- Materials containing reduced amounts of asbestos have been used in the fol lowing applications: a. Blanket and pad filling Substitution of the proper types of other pad fillers not only re.. duces asbestos dust daring fabri cation and installation but also tends to lessen the problems dur ing subsequent "rip-out". Addi tionally, asbestos cloth which has been treated with a dust suppres sant is available mid its nse should also be encouraged. There are re ports that much less dust will be produced. b. Pipe covering and block Serious consideration should be given to those products contain ing lower amounts of asbestos fiber. Several British firms have introduced asbestos-free calcium silicate block and pipe covering. To date, however, this material has not been adequately evaluated in the United States to determine how it will perform in U3e. Reduction of Dust by Changes in Work Metiiods a. Mixing Asbestos Mortar This operation bas usually been done at the job site. While the time spent in mixing is quite short, considerable dust is pro duced. A tested method of control is to mix the mortar dockside under controlled conditions and package the mixed mortar in sev eral containers for transportaliou to the job site. Mortar is also available packaged (Continued on second pice) v .v*V*s.v:x-v>. - v*.' LAM 024246 ABS-007425 * \ * ~Insulation Hygiene ...: Progress Reports Vol. 3, No. 4 Vflntor 1971 - ' '-------- ---- Procedures Used at Puget Sound Naval Shipyard from the Insulation Industry Hygiene Re search Program Editor: W. J. Nicholson, Ph.D., Published at the Environmental Sciences Laboratory (Irving J. Selikoff, M.D., Director), Mount Sinai School of Medicine of the City Uni versity of New York, New York, N.Y. 10029 Advisory Council of IIIIKP Irving J. Selikoff, M.D. Program Director and Chairman E. Cuvier Hammond, Sc.D., Vice President, American Cancer Society, New York, N.Y. Albert Hutchinson, General President, International Association of Heat and Frost Insulators and Asbestos Workers, Washington, D.C. Fred L. Pundsack, Ph.D. Vice Presi dent, Research and Development, Johhs-Manville Corporation, New York, N.Y. PURPOSES OF THE INSULATION INDUSTRY HYGIENE RESEARCH PROGRAM (Continued from first pate) in several sizes of plastic bags which have a spout through which water is introduced. Sufficient wa ter is added to moisten the mor tar; after premising, the hag is opened and the remaining water added. The carton 5n,wfcich the hag is packaged may serve as a mixing box and waste container. b. Pre-cutting pipe covering and block in the fabrication, shop Hand-cutting of pipe covering and block should be kept to an absolute minimum. Bend sections, pipe cover lengths, and blocks, should be cut in the fabrication ' shop on exhaust-ventilated equip ment ; using an exhaust-ventilated gang saw. d. Insulating pipe assemblies in the shop Some pipe assemblies are quite intricate and are troublesome to lag while in place. A satisfactory method of doing these jobs, par ticularly during ship repair, which is employed by the Puget Sound Naval Shipyard, is to re move die assembly in conveniently ' sized sections and transport them to the .shop. Here the old insula tion is removed, any necessary . repair of the pipes performed, ' and the -assembled section relagged. Relag in the Shop How the Navy Does It \ Not only is dust dispersion re At the Puget Sound Naval Ship- yard, cut sections are dipped in . ` water and then packed in plastic bags which are labeled to identify the location where they axe to be ' used. The cut sections are still damp and relatively dust-free duced, but it is much more con. venient to re-lag the section in the shop than when it is in place shipboard. Any insulation which is damaged during transport and fitting is repaired after the .sec. tions are in place. when they are applied and the e. Hand-cutting at job sites plastic bags are available for use Some hand-cutting at job sites is in collecting wastes. i > 'unavoidable. However, dispersion c. Pre-scoring blocks Insulation blocks should not be scored at the job site. Blocks which have been pre-scored by the manufacturer cao be pur chased, or standard blocks can be scored in the fabrication shop by of dusts by these operations can be minimized. A portable downdraft table is used by the Puget Sound Naval Shipyard. This table has folding legs so that it can he carried down companionwajs and set up conveniently to the work. A small industrial vacuum cleaner is the source of exhaust. Scrap is dropped into a plastic bag and a (Continued on third page) 1. To develop improved methods for minimizing ex posure of insulation workers to dusts and fumes encoun tered in their work. 2. To disseminate knowl edge of these improved methods of dust control wherever they may be ap plied advantageously and to offer cooperation, advice and assistance toward their universal adoption. . " T-/ , ^Mal - . * High temperature ' mortar packed fn plastic bag. Wster is added to bag th'reush spout and mertar moistened before opening. The moistened mortar is removed os required and mixing completed in shipping container. All wastes are placed In container and sent to disposal at end'of shift - ;c. \ > Procedure used at Pu;*t Sound Naval Shipyard for handling bend sections. Sections are cut in fabrication shop, dipped in water and placed in plastic bag. The bag is then labelled with the job-site description. LAM 024247 ABS-007426 r\ ~ .tTf r 'r* ` -- ' Hfiduclion of Dusts by Use of Logs! Exhaust Ventilation 'a*s tor cutting asbestos cement board are well controlled with .. these systems. i. Ventilation of Large Poster Tools--Band Saws Extensive use of band saws both Control of Number of Workmen Exposed Dampening fibrous glass blanket filler before cutting. Note lateral draft hood in which fabrication is done. (Continued from second page) . dropcloth is placed on the deck - _ tinder the equipment. ' /. Fabrication of Pads and Blan kets - Pads lor valves and machinery * - ' should he fabricated in the shop whenever possible. Amosite has been largely replaced by fibrous glass filling with covers of an asbestos cloth which has been treated with dust suppressants. As an effective means for suppressing dust dispersion and collection, the fibrous glass blanket is unrolled, dampened and reroll-d. This pro cedure insures that all the banket will be dampened. The blanket and asbestos cloth shapes are cut in the lateral draft booth. in dockside fabrication shops and, on board larger ships such as aircraft carriers make emissions from band saws a major source of asbestos dust. Control devices for such saws have been known for years and are relatively sim ple. Conventional low-velocity, bigh-volume systems, using a negative pressure baghouse for air cleaning, are practical in a fixed installation fabrication shop. Because some degree of porta bility is desirable in a temporary shipboard fabrication area, a high-velocity, . low-volume dust collection unit is desirable for a. Scheduling of Insulation Work . Standard industrial hygiene prac- ^ ' tices call for insolaling operations which contaminate the atmosphere with toxic materials. Areas where insulation work is being done under conditions in which dust might be created should be iso lated by non-flammable curtains or other means. Whenever possible, work should he scheduled to minimize the numbers of other tradesmen in the area. Snip con struction operations are more readily scheduled than are ship repair or ship-breaking jobs. " However, every effort should be made to keep the number of men exposed at a minimum. In par ticular, rip-out of old insulation should always be isolated and, if necessary, performed on an off- V shift. Trainer! workmen supplied with proper protective equipment" should always be used for rip-out work and it should be scheduled for rapid completion. Personal Protective Equipment In addition to dust suppression and dust control procedures, personal pro tective equipment is often necessary to reduce exposure and limit the spread of contamination. The equip ment described below is used in con- trol programs. g. Housekeeping and Clean-up Essential parts of a dust control program are hocsekeeping and clean-up procedures. Meticulous attention must be given to re stricting the spread of dust and larger wastes. Use of a dropcloth under a work area vividly illus Portable down-draft table developed by Puget Sound - Naval Shipyard tor use shipboard. Lightweight industrial vac uum cleaner is used as the air mover. Note plastic bag for scrap and drop* cloth on deck. such use; it mav also be suitable for fixed installations. The air a. Protective Clothing Protective clothing is required to keep contamination confined to the work areas. One method is to issue disposable coveralls which can be removed when leaving the (Continued on fourth page) ! trates how much waste would be distributed over the general area mover is an industrial vacuum cleaner which pulls about 30 or to lower decks if one were not cubic feet of Air per minute past ! used. the saw blade at velocity of more (*. t 4 Areas should he cleaned uo at the lunch break and the end of than 10,000 feet per minute. This system is a very efficient dust col i each shift, using an industrial lector. Uoits such as this can also vacuum cleaner to collect dust and small scrap. be designed to control dusts pro duced by table saws and gang In all possible instances, work saws. men should clean up their own b. Ventilation of Hand Power areas. Where work rules prohibit this, the dean-up crew should be under the* direction and super vision of tlic insulation fororaa:i to insure that proper attention is given to this important subject. Tools High-velocity. low-volume collec tion' systems control du-it emissiot;5 from most small power tools adequately. Sauer saws for cutting pipe covering and rotary Use of dropcloth to contain wastes and facilitate clean-up. LAM 024248 ABS-007427 \ A small industrial vacuum cleaner being used by a Local 62 asbestos worker for c.'ean-up. (Continued from third page) work area or some timr prior to .entering the locker room and '' placed in plastic bags for disposal. Resin Impregnated. Paper A satisfactory type of protective clothing consists of resin Impreg. nated paper coveralls. These are inexpensive and readily -disposa ble. They prevent spreading con lamination to laundries and elimi nate pilferage. They are worn for :. one shift, then removed and . . placed in plastic bags for disposal with' other asbestos-containing wastes. 6. Respiratory Protective Equip ment Occasionally some operations gen erate so much dust tihat it is virtually impossible to maintain satisfactory atmospheric concen trations of asbestos fibers and respiratory protection must be provided to the workers. A variety of respiratory protective equip ment is available from which devices suitable for various situa tions can be selected. American National Standard 283.3-1971, Safety Guide for Respiratory Pro. lection Against Asbestos-Contain ing Dusts (obtainable from Amer ican National Standard* Institute, 1430 Broadway, New York, N.Y. 10018) should be referred to for detailed information. Invisible Dust It is empliasized that unsatisfac tory amounts of respirable dust can Fe present in the air even though conditions are nut visibly dusty. 2. Air-snpplied Respirators Extremely dusty jobs, such as ripout of old insulation where dust concentrations are vciy high, re quire use of air-supplied respi rators which wiil deliver clean, dust-free air to a facepiece or hood. Two general . type* are available: air-line and self- Saber saw equipped with high-velocity, low-volume exhaust system. powered. a) Air-line respirators in which air .is supplied to a hood, helmet or facepiece give the greatest de gree of protection. Air is fed to the facepiece from a compressed air-line. The air source must be located in an uncor.taminated area and if the source is not specifically designed for breathing purposes, a temperature seasing alarm must be installed on the compressor or a carbon ' mon oxide monitoring device must he installed in the air-line. Disposable Hood Anti-freeze compounds should not . be used in the compressor system; water vapor must be removed by dessicant and oil mists removed by a filter. A plastic, disposable hood has been developed by the Puget Sound Naval Shipyard tor situ ations where a very high degree of protection is required. This hood and other similar ones are available commercially. The air line should be fastened to the hood with a quick-disconnec! fitting. Self-powered Respirators b) Air-line respirators connected to a compressed air supply limit ' movement, and this limitation can bo troublesome. Self-powered res pirators do not impose such limi tations, but they do add to the equipment the vorkmao must carry and they also require care ful maintenance. 2. Particulate-filtering Respira tors There are several types of par ticulate-filtering respirators. Those with a half-mask facepiece are considered most suitable for use by insulators. Only those ap proved for protection against as bestos dust by the. U. S. Bureau of Mines should be used. These devices are recommended for use in situations where the atmos pheric concentration of. asbestos libers is at relatively low leveh. All the rccommendations for res pirator-fitting, training of work men and maintenance, detailed in - Z88-3-1971 should be followed. a) Reusable particulate-filter ing respirators A variety of reusable particulate- 4 "filtering respirators are available. To insure proper fitting, several different makes should be avail able from which the workman can select one. No one model respira tor facepiece will fit all faces. Routine maintenance is absolutely ' necessary to replace clogged fillers and leaking inhalation or exhalation valves. Vnmaintair.ed res pirators produce a false sense of . security. Maintenance Troublesome b) Disposable pardecide-filter ing respirators Operation of an adequate respira tor maintenance program can be troublesome and, if only a few men are involved, impractical. Disposable respirators are avail able which are designed to be worn for no longer than one.ehift and then discarded. Education and Training No dust control program can be effec tive unless workmen and supervisors understand the hazards associated with the jobs, the sources of the hazards and the reasons for following recommended procedures carefully. Understanding is only obtained by education of personnel and training in correct operating procedures. For an education and training program to be successful, both management and labor must be concerned and partici pate. As with all safety programs, it is essential that first-lioe supervisors be interested in and cooperate in the work. The harmful effects of neglect of pro cedures for controlling asbestos dust are not apparent for many years. Therefore, it is more difficult to con vince workmen and supervisors of the necessity of following rules for working with insulating materials than if more obvious physical haz ards were involved. Education in hazards associated with use of insulating materials and in struction in correct work practices should be included in apprentice training programs. PHOTO CP.SD1T5: Pg. ], J.J.H.R.P.; pg. 2, Ryder Industries and Pug'-t Sound Naval Shipyards (P.S.N.S.); p. 3, PJS.N.S.; pg.* 4, I.I.H.R.P. and P-S.N.S. LAM 024249 ABS-007428 .23203 RULES AND REGULATIONS As Amended, Table G-3 reads as follows": TaBLI G-J--MlNKUL Dr JTJ Substance Mppcf Silica: Crystalline: Quartz (respirable)......... ; SS> lOrcc/M1 - %SlOrr5 %SjO^-2 Quartz (total dust).......... 30mr.M* Crisfobalife: Use H tJi alue calculated from the count or mass formulae lor Quarts* Tndymite: TTse H the Talue calculated from tbe for mulae for quartz. Amorphous. Including natural dlatomaccous earth................ Silicates (less than crys- . tailine silica): Mica...........................;__ Soapstone............................ - Tnl*. .............. Portland cement........... Graphite (aatural)........... ' 'Coal dust (respirable iractioa less than 5% SIOJ... Tor more than 5% SIO-_______ Inert or Xnteance Dost: Respirable fraction.___ Total dust.._________ _--. 31 SOmt'M* rSIO: 20 31 00 * 40 34 . or lOmg/M1 SJSIOrH 14 SmgfM1 0 14SS/M* Noth: Conyer-lou lactors-- xappcDC35.3-mUUon parridej per coble racier . particles per c-c. Millions of particles per cubic foot of air, based on hnpinger samples counted by ltgbt-fleld technics. * The percentage of crystalline silica In the formula la the amount determined from air-borne samples, ex cept In those instances in which other methods hare been shown to ba applicable. i As determined by the membrane Alter method at 433XPbase contrast magnification. a Both concentration and percent qcaru for the appli cation of this limit are to be determined from the fraction passing a size-selector with the following characteristics: Aerodynamic diameter (unit density sphere) Percent passing ' selector 2 . . 15 ; . 3.5 4.0 10 90 74 25 0 Hit mnreiremtots under this- sots refer to th tm of an AEC Instrument- II the respirable Iractioa ol coal dost Is determined with MKE the Stun correspondlse to that ol 2.4 Mg/M' In the table tor coal dost is U 3i(/3i, 2. A new 3 1910.93a. Is added to Fart 1910. The new J 1910.93a reads as follows: 1910.93a Asbestos dust. (a) The 8-hour time-weighted aver age airborne concentration of asbestos dust to which employees are exposed shall not exceed 3 fibers per milliliter greater than 5 microns in length, as de termined by the membrance filter method at 400-450 x magnification (4 millimeter objective) phase contrast illumination. Concentrations above 5 fibers per milliliter but, not to exceed 10 fibers per milliliter, may be permitted up to a total of 15 minutes in an hour for up to 5 hours in an 8-hour day. Cb) Engineering methods, such as but not limited to, enclosure, vacuum sweep ing, and local exhaust ventilation, shall be used to meet the exposure limits pre comply with the requirements of these scribed in paragraph (a) of this section. subparagrapiis relating to the operations Where such engineering methods are not Involved. The requirements of this para feasible, cr do not otherwise reduce the graph are in addition to those prescribed concentrations below those prescribed in in paragraph (b) of this section. paragraph (a) of this section, respira (2) Ail band- cr power-operated tools tory protective deuces snail be provided which produce asbestos dust such as, but and used in accordance with paragraph not limited to, saws, scorers, abrasive (c) of this section. -. wheels, and drills shall be provided with (c) (1) (i) When the limits of ex local exhaust ventilation and dust col posure to asbestos dust prescribed in lectors in accordance with the American ' paragraph (a) of this section are ex National Standard Fundamentals Gov ceeded and when engineering controls erning the Design and Operation of local required by paragraph (b) of this section Exhaust Systems; ANSI Z9.2--1971. are not feasible or do not otherwise re (3) Employees exposed to the spraying - duce the concentration of asbestos dust of asbestos or the demolition of pipes, below those prescribed in paragraph (a) structures, or equipment covered er in of this section, the employer shall re sulated with asbestos shall be provided quire the use of respiratory protective de with respiratory protective devices in vices. T:ie selection of respiratory protective devices shall be limited to accordance with paragraph (c) (4) of tins section. those specified in the remaining subparagraphs of.this paragraph (c). (ii) The employer shall .require that each employee test his respiratory pro (e) Asbestos cement, mortar, coatings, grout, and plaster shall be mixed in closed bags or other containers. tective device before each use in order to insure a proper fit according to the Cf) Asbestos waste and scrap shall "be collected and disposed of in sealed bags . - manufacturer's instructions. The em or other containers. ployer shall further provide for effective (g) All cleanup of asbestos dust and training or supervision of employees in blowing shall be performed by vacuum the testing of respiratory protective de cleaners. No dry sweeping shall be per vices for fit before their use. formed. (2) For an atmosphere containing not 3. Section 1910.12 is amended by more than 25 fibers per milliliter greater changing paragraph (a) in order to apply than 5 microns in length over an 8-hour the emergency standard prescribed in the average, or more than 50 fibers per milli new 3 1910.93a. which is published ln-thls liter over any period of 15 minutes, a document, to construction wort which Is reusable or single-use filter type respira subject to the Act. The amendment Is tor, operating with negative pressure necessary In light: of the rule of regala- . during the inhalation phase of breathing, tory construction set forth in i 1910.5(c). approved by the UjS. Bureau of Mines As amended, 3 1910.12 reads as follows: under the provisions of 30 CFR Part 14 (Bureau of Mines Schedule 21B), or a S 1910.12 Construction work; valveless respirator providing equivalent (a) (1) Adoption and extension of es protection, shall be used. tablished. safety and health standards (3) For an atmosphere containing not for construction. The standards pre more than 350 fibers per millfiter greater scribed by Part 1518 of tiffs title and in than 5 microns in length over an 8-hour effect on April 28, 1971, are adopted as average, or more than 500 fibers per occupational safety or health standards milliliter over any period of 15 minutes, under section 8(a) of the Act and shall a powered filter positive pressure res apply, according to the provisions pirator approved by the UB. Bureau of thereof, to every employment and place Mines under the provisions of 30 CFR of employment of every employee en Part 14 (Bureau of Mines Schedule 21B) gaged in construction work. Each em shall be used. ployer shall protect the employment and " (4) For an atmosphere containing places of employment of each of his more than 250 fibers per milliliter employees engaged In construction work greater than 5 microns in length over by complying with the appropriate an 8-hour average a type C positive pres standards prescribed by this paragraph. - sure supptied-air respirator approved by (2) The standards prescribed In. the UB. Bureau of Mines under the pro 3 1518.55(c) of this title shall apply In visions of 30 CFR Part 12 (Bureau of the case of the exposure of any em Mines Schedule 19B) shall be used. . ployee In construction work to airborne (5) The employer shall establish a asbestos dust ' N respirator program In accordance with the requirements of American National Standard Practice for Respiratory Pro Effective date. These amendments tection ZSB.2--1969. shall become effective immediately upon (8) The respirators provided each em publication in the Fracur. Regtstti ployee shall be properly inspected, (12-7-71). cleaned, repaired and stored. * - (See: 6(c). M Stat 1396. 29 U-S.C. 633; Sec (d) (1) When an employer has em retary's Order No. 12-71,36 Fit 8734) ployees who are exposed to asbestos dust, Signed at Washington, D.C., this 2d' exceeding the limits prescribed in para day of December 1971. graph (a) of this section and the ex posure results from the operations de scribed in the remaining subparagraphs G. C. GUENTHER. ~ Assistant Secretary of labor. of this paragraph (d), the employer shall (F3DOC.71-17833 Filed 12-6-71;8:47 IBj / FEDERAL .REGISTER, VOL 36, NO. 234--TUESDAY, DECEMBER 7, 1971 LAM 024250 ABS-007429 i XPZ^15 MlWK r:^Ori>l f! LAM 024244 i ABS-007423 i\i ii t