Document RJnRaER6QvVEQJ7L7bOXnpGx8

FILE NAME: Allied Signal Bendix (ASB) DATE: 1972 July 5 DOC#: ASB082 DOCUMENT DESCRIPTION: Memo from Asbestos Information Association RE AIA/NA OSHA Standards Meeting ^information 22 East 40th Street New York, M. Y. 10016 (212) ,66.1-6206 Ih America JUL 1 '91Z r\ ,jvj.Armstrong hc&i/\ if a Ju ly 5, 1972 550: AIA/NA MEMBER COMPANIES AIA/NA ENVIRONMENTAL CONTROL SUB-COMMITTEE ' AIA/NA LEGAL COUNSEL James- Armstrong E. C. Brait. G. G. Gabrielson, Jr* Bernard Gross J. Hall B* M. Jackson: W. N. Johnson A. R. Hooker C . A . Setanam . - G. W. Nick&l Clifford Seymour J. R. Stetson Philip Weinstein G. W. Wright, M..D. Bendix Corporation. Hi K. Porter Company, Inc* -- MiSpalet industries, Inc.- rican Bilt Rite Rubber Company GAP Corporation - Joitns-Manmille Corporation - Union Carbide .Corporation . - Thai Flintkate. Company - Kentile Floors Incorporated - - Armsltrong -Cork.Company , - The Carborundum Company - Congoleum Industries, Inc*. - Everuex Incorporated St. Epke^s Hospital Gentlemen r A meeting was held in Washington last: Thursday between the AIA/fiA and representatives of the GS3A standards development amt compliance sections. Attending op behalf of the AIA were John Marsh, Raybestos-Manhattann Raul Weiner, GAF; Hugh Jackson, Johns-Manville; Frank Zimmerman, National Gypsum;. Bradley Walls, AIA/NA Legal Counsel, and M. M. Swetonic, AIA/NA Executive Secretary. OSHA was represented by John O'Neill and Harry Gilbert of Standards Development; and Ray McClure of Compliance. The purpose of the meeting, a-s was discussed at the Association meeting on June 22, was to clarify a mmiber of points with regard to the interpretation and enforcement_of the asbestos standards. Because the standards are to go into effect this week, we considered it imperative to provide you with the basic points of interpretation and compliance established at the meeting. A more complete report o.n\the meeting will be forthcoming in the near future. ' ftm ttored bv A*tes Asbestos Co Cement Asbestos Products Co.. Certain-teed Products Corn Flmttotc Co.. ^ ^ ^ p . J ^ s A S l e t c r p .. National Gypsum Co . Panacon Corp. and Ba,bos,os-Manhattan. tnc. WCK006895 . - 2- The* following, are the main areas discussed and the decisions reached: 1. LABELING: The AIA/NA is applying for a _ temporary industry-wide variance on the exact wording of- the labeling requirements of the standards, in 'order that existing supplies of boxes, cartons, bags, etc. containing a label with warding somewhat different than that called for in the standards, will be permitted . until they are used up. As long as the. label. currently' being used contains, hasically the same information as the required one, it will be acceptable to OSHA until: stocks are. used up.. Products to be.labeled should.follow, the list- ` . . ing submitted. .Jay Dr.. Fred-Pundsack of. -- Jahns-Manvilla to QSHA following the. March . hearings. A copy of. Dr.. Pundsack* s list, with niTnnr alterations, i attached for your " information.. . Ho product which requires labeling will.be. permitted to be used without any label until. . existing-stocks of non-labeled bags, etc. are .. used up. A stick-on label of .some type would be satisfactory-. The size,, color, placement, etc. of the lahel. is left to the discretion of the employer, as long as the lahel is "readily visible and legible." A good rule to follow would be: if you are trying to hide.the label., OSHA will probably not accept it. 2. CLOTHES LOCKERS: Separate clothes lockers are required only for employees working at levels in excess of the five fiber TWA. 3. It was the intention of OSHA to require Type "C" supplied-air respirators and protective clothing only for insulation and fireproofing spray applications,. AIA/NA will apply for a . modification of the law to exclude other types of asbestos-spray applications from these requirements. -More- WCK006896 . -a- 4. RESPIRATORS: There..is a mistake in the standards. in paragraph (d) (2) (ii) "Powered Air Purifying Respirators." The first, sentence of that paragraph now reads.: . "A full facepiece powered air purifying respirator, or a powered air purifying respirator, or a. respirator etc." . The sentence should read.: "A full facepiece powered air purifying . respirator, or a respirator etc. " The phrase... "or,a powered air purifying respirator" should he deleted. . ' ; \ j !t | j j ' J 6 < 1 5., MGEEETQRING AND PHYSICAL. EXAMINATIONS: Company . monitoring and. physical, examinations should, he . -. conducted an. all employee^. ho; regularly work: . ' with asbestos' and are exposed tor airhorne fiber, - as well as on maintenance men, company industrial hygienists and other employees that the company '"feels require monitoring and physical examination because of the nature of their work or because of their close- proximity to dusty asbestos, operations. This would exclude office personnel, most people working in- non-asbestos using sections of~an asbestos . . manufacturing operation, etc. ' . . ! ; 1 j f --[ ' :. d. CITATIONS: A company's own. monitoring or other records will not be used as evidence to issure citations-, nor will they be used to give a plant a clean bill of health. 7. OSHA INSPECTIONS: OSHA industrial hygienists will take dust samples, if at all possible, for a full eight hours, perhaps divided into two four hour samples. In addition, samples will be taken on more than one day, so that a more, accurate count can be produced. Ceiling sampling periods will be at the discretion of the OSHA hygienist. Ceiling samples as short as five minutes may be taken if deemed appropriate.. Under some circumstances -More- WCK006897 . -4- (an obviously very heavy dust concentration), only_ ceiling samples may be taken, but this would not be normal practice. Employers will be given specific dust counts only if they are in excess of the standard. Counts taken by NIOSH hygienists will be reported to OSHA, but will not be used by OSHA for purposes of issuing citations. 8. EMPLOYEE NOTIFICATION: On the question of notifying employees if they are found to be working in dust concentrations above the limit, neither O'Neill or McClure would make a decision whether the notification clause in the standard would be satisfied by the posting on a plant bulletin board of stations above TWA, or whether-a more individualized approach, such as sending the' employee a registered letter, would be required. To answer this Question, we were asked to write, to the solicitors office in OSHA for a ruling. Unfortunately, a prior informal conversation between Paul Weiner of GAF and a member of the legal staff of OSHA in(31cated that the answer to such a question would be in favor of the registered letter approach. As_a_ result, we have decided not _^to submit this question TorT^YuTingV but" wi 11 _A*:--YE each company in the industry to decide In what manner it wishes to abide by this requirement, and wait to see if bulletin board notification will be challenged by OSHA regional inspectors. In general, the concensus of the AIA group that attended the Washington meeting was that the industry could expect reasonable treatment from OSHA as long as the industry did not try to circumvent the intent of the regulations. For example, the various requirements in the standard for protective clothing, change rooms, separate lockers, etc. have as their purpose the preventing of excessive amounts of asbestos dust being carried home on an employee's clothes from work. As long as this purpose is achieved, the industry will be given wide latitude as to the types of protective clothing, footwear and headgear required; the location and size of change rooms; -More- WCK006898