Document RaDVd6E1E6XL9kzDweDJBbnzV

Oil, Chemical and Atomic Workers International Union ANTHONY MAZZQCCHI, DIRECTOR C1TI2ENSHIP.LEGISI.ATIVE DEPARTMENT 1126 - 16TW STREET. N. W. WASHINGTON. D. C. 20016 PHONE: 223-21'* February 11, 1D72 Office of Safety and Health Standards Room 305 400 First Street, N. W. Washington, D. C. 20210 Gentlemen: The following are the comments of the Oil, Chemical and Atomic Workers International Union on the proposed Standard for Exposure to Asbestos Dust (29 CFR Part 1910) as pub lished in the Federal Register on January 12, 1972. Exposure Limit (Sec, a) Overexposure to asbestos dust is known to cause asbestosis and cancer. While it is felt that exposures not exceeding 2 fibers per cubic centimeter will protect a worker against asbestosis, no such limit has yet been determined to prevent the cancer. The only indications arc that the "no-effect" level for the cancer is below the effect level that has been determined for asbestosis. Therefore the OCAW recommends that exposure to asbestos be minimized to the lowest extent technically possible. Dr. Irving Solikoff, of the Mt. Sinai School of Med icine in New York, has reported to us that industry currently holds the technology necessary to reduce exposures to 1 fiber per cc. Therefore in light of the cancer hazard, the OCAW recommends that a standard for unprotected exposure be adopted that would never allow such exposures to exceed 1 fiber per cc effective within two years. For that two year interim period, a standard should be adopted forbidding any unprotected exposure in excess of 2 fibers. Methods of Compliance (Sec, b and c) - Engineering Methods While wo agree that engineering methods such as enclosure, vacuum sweeping and local exhaust ventilation arc necessary measures to reduce exposure, primary emphasis must be placed on a designed performance standard of 1 fiber per cc. Performance standards are the simplest and surest way to insure that exposures to asbestos are minimized. For example, 'if a dust collection - ventilation system designed to keep exposures under 1 fiber breaks down, then both management and workers know immediately that corrective action must be taken to protect against overexposure. Dust counts, unfortunately, are always after the fact and allow for unprotected workers to be exposed to peak levels. - Other Methods The wearing of respirators as an interim control measure causes problems and dis comfort for workers. For example, in many of our factories in the Southern United States, temperatures inside during the summer often reach well over 100 F. If a worker is wearing a respirator, that is usually the first thing that is loosened. And the foreman looks the other way. This is simply human nature. To minimize the problem of respirators, we propose the following: a) all management plans to use respirators to reduce exposure as interim or permanent control be treated as a variance request so that the wearing of respirators in non-emergency situations develops as a permit system, and b) as the supplied air respirator is the most comfortable for the worker and places the least strain on his respiratory function, we recommend that only this kind of mask be authorized to protect the worker against any overexposures. We also endorse your recommendation that the respirator program be established in accordance with American National Standard Practice for Respiratory Protection 288.2-1969. Furthermore, respirators for each employee must be properly inspected, cleaned, repairQd, DlDand stored. Particular Operations and Products (Sec, d) " * J' ....^ 7=;i r*o MOT OU^VlE fh UsV'i f'V U nLi-O We endorse the engineering and procedural controls so specified with the exception that respirators shall be of the supplied air type. Waring Signs (See, o) Add a skull and crossboncs symbol. Change "1. Avoid breathing dust" to "1. Do not breath dust." Monitoring <5cc. f) We endorse the concept of both personal and environmental monitoring. However, because of the severe nature of the asbestos health hazard, wo feel that continuous monitoring of any exposure to asbestos dust is necessary. Monitoring equipment and methods must be acceptable to the employees. Furthermore, as provided by See. 8 of OSIIA, workers shall have the right to observe such monitoring. Employee access without hindrance lo monitoring records must also be guaranteed. Samples shall be processed with a minimum of delay. Monitoring records less than one month old must be posted at or near the work station or work site. ------------------------1 BB 0001379 J "Medical Examinations (Sec. g) Annual physical examinations shall be provided each employee exposed to asbestos at the expense of the employer. We further recommend that employees be given the right to have these examinations performed by the doctor of their choice but at the employer's expense. The doctor performing the examination shall be required to forward the medical report to a central record keeping facility at NIOSH. NIOSII shall review the medical data. A report indicating the health status of the employees of each facility but not revealing identities of the workers shall be made available annually to the employer and the representative of the employees and shall also bo posted in the facility. This annual physical examination shall at least include: pulmonary function and diffusion tests and a 14" x 17" chest X-ray. Rales and clubbing of the fingers shall also be xamined. The employee shall always have the right to immediate access to all his medical records. Records (Sec, h) Every employer shall maintain records of the personal and environmental monitoring, and of the NIOSH medical reports for a period of at least 35 years. Not only shall the records of monitoring be available to the Labor Department, but, as guaranteed by Sec. 8 of OSHA, employeesfir9all have the right to inspect and copy these . monitoring records. We propose that the authorized representative of the employees also lx: granted immediate access to these" records. Monitoring data loss than one month old shall be posted at or near the work station or work site. _ fqjq Further Recommendations feiji ;-ru hUs The following Sections should be added on lunchrooms and protective clothing. - Lunchrooms Lunchrooms shall be physically separate from nsbestps materials and must be enclosed and have double sealing doors (airlocks). At no time may the concentration of asbestos in the lunchroom exceed the above mentioned specified exposure limit. Employees must change into clean clothing before entering the lunchroom. -Protective Clothing * The employer shall provide each employee subject to any asbestos dust exposure with full body protective clothing and hat, which shall be worn during the working hours in areas where there is exposure to asbestos dust. The employer shall provide for maintenance and laundering of the soiled.protective clothing, which shall be stored, transported and disposed of in sealed non-rcusable containers marked "Asbestos-Contaminated Clothing" in easy-to-rcad letters. j bB 000l380_r i! Huu.*appnns - 4Protective clothing shall be bacuumed before removal. Clothes shall not be cleaned by blowing dust from the clothing or shaking. If laundering is to be done by a private contractor, the employer shall inform the contractor of the potentially harmful effects of exposure tc asbestos dust and of safe practices required in the laundering of the asbestos-soiled work clothes. All workers shall be given facilities and time at the expense of the employer to shower after working. All asbestos operations shall have separate change rooms, and no employee shall ever be allowed to wear or take his protective clothing from the plant grounds or work site. If any of these comments need further clarification, please do not hesitate to call on us. Sincerely yours Anthqhy MaeZocchi, Director Citizenship-Legislative Department v BB OQQ1381_