Document RjZXZKjp4QryXzzLkNr6wBg2a

' >'ir. i IjJL Shell Oil Compjjny o Shell Chomicnl Company Inkrolllce f/,cmornndum fEBRUARY 13, 1931 Yo PLAINTIFF'S EXHIBIT pRTV/YTE_ AND CPNE3 DENTI7\L FROM: SUPERINTENDENT S l IH TO: COMPLEX MANAGEMENT TEAM SUBJECT: REVISED ASBESTOS MEDICAL SURVEILLANCE PROGRAM Corporate-Medical issued a revised asbestos medical surveillance policy late last year which included in addition to "insulators" who are the only craft currently included in the Shell asbestos medical surveillance program, other employees who may also be exposed to asbestos as a result of their work activity. A review was made with both Maintenance - North and South of work activities prior to and following 1972. The year 1972 was used since there was a step change made in our handling of asbestos containing materials at that time. Based on this review, the following recommendations are offered: 1. Include in the asbestos medical surveillance program all pipefitters and boilermakers still with Shell who were working inMhese crafts prior to 1972. It is estimated that we have about 94 employees [bb South and 39 North) that meet this criteria. 2. Initiate an expanded asbestos monitoring program to es tablish more firmly whether or not we are meeting the permitted exposure limits for employees working these crafts today. The limited data we have suggests that we are within the permissible exposure levels. Conse quently, no action is proposed for the employees who entered these crafts subsequent to 1972 until the addi tional monitoring has been completed. Inclusion of the craftsmen meeting the 1972 criteria in the asbestos medical surveillance program should be initiated early this year. The following plan is proposed for accomplishing this objective: 1. Identify the employees in the two crafts. 2. Advise the Workmen's Committee Chairmen and the H & S Coauiittees of the revised policy. LAM 016821 3. Meet with the affected personnel and advise them of the new program. DPMC-10565 OCMT 2 4. Medical set time for examination, if required, and if not, a time for consultive session. 5. Issue bulletin on revised program with a follow up hazardous material bulletin outlining synergism of asbestos and snicking, etc. Be glad to discuss. R. P. frutiger RPF: cfJi cc: M. T. Anderson D. O. ChrismerJ. G. Massey F. G. Reitz ' P. J. Snyder Medical Dept. LANl 016822 DPMC-10566 oo SHELL ASBESTOS MEDICAL SURVEILLANCE PROGRAM Pcrtinent Background Facts on Asbestos - Asbestos is a human carcinogen. Inhalation may cause lung cancer, mesothelioma, and other diseases such as asbestosis and pleural lesions. - Generally, the incidence of cancer and asbestosis among occupationally exposed persons increases with increasing intensity of exposure; the inhalation of high concentrations for short durations may be as harmful as prolonged exposure to low concentrations. - From all available evidence, the period between first exposure to asbestos and death from lung cancer appears to be related to intensity of exposure. A latency period approximating fifteen years is probably the minimum for asbestos-related lung cancer. - Tobacco smoking increases the incidence of lung cancer and complicates asbestosis among asbestos workers. Regulatory Background - Permissible exposure limits to airborne concentrations of asbestos fibers are defined by OSHA standards (29 CFR 1910.1001) as follows: a) Permissible exposure level -- "The 8 hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed two fibers, longer than 5 micrometers, per cubic centimeter of air..." b) Ceiling concentration -- "No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers, longer than 5 micrometers, per cubic centimeter of air..." - Per OSHA Program Directive #300-16 dated October 11, 1978, titled, "Minimum Airborne Fiber Concentration For Initiating and Continuing Asbestos Medical Examinations", the term "...exposed to airborne concentrations of asbestos fibers..." is administratively interpreted to mean "...exposed to a minimum of 0.1 asbestos fibers longer than 5 micrometers per cubic centimeter of air..." on a time weighted average basis. Shell Concerns - Surveys now indicate that in addition to "insulators" who are currently included in our asbestos medical surveillance program, other employees such as pipefitters, riggers, etc. may also be exposed to asbestos as a result of their work activity. - Our current medical surveillance program does not satisfactorily address the question of past exposure to asbestos. LAM 016823 DPMC-10567 UO 2 - Employee training programs for asbestos have not sufficiently emphasized the known synergism between asbestos exposure and smoking. Objective Revise existing asbestos medical surveillance policy in order to correct any deficiencies and fully address the concerns described above. Policy - Employees whose present job assignment results in exposures to asbestos of 0.1 fibers, longer than 5 micrometers, per cubic centimeter (TV.'A) or greater (regardless of respirator usage), on a reasonably predictable and repeated basis,* shall be included in Shell's annual asbestos medical surveillance program. - Employees, who can be identified as having had job assignments in the past, in which exposures can be determined as probably exceeding 0.1 fibers, longer than 5 micrometers, per cubic centimeter (TWA) or greater (regardless of respirator usage), on a reasonably predictable and repeated basis,* shall also be included in an annual asbestos medical surveillance program. - Available exposure data indicate that exposures during "ripout" or removal of asbestos-containing insulation may exceed 0.1 fibers per cubic centimeter. Accordingly, all employees, regardless of job title, whose work assignments now or- in the past, would involve "ripout" or removal of asbestos-containing insulation, on a reasonably predictable and repeated basis,* are to be included in an annual asbestos medical surveillance program. - Employees who have been in an asbestos medical surveillance program prior to employment with Shell shall be included in Shell's annual program. - Once an employee has been included in an asbestos medical surveillance program, the surveillance should be continued throughout the term of his or her Shell employment. Upon leaving Shell, each employee who has been included in an asbestos medical surveillance program shall be administered according to the Shell pre-separation counseling or extended medical surveillance program policy (post-retirement physical examinations), whichever is appropriate. * The phrase "reasonably predictable and repeated basis" is currently interpreted for present job assignments, to mean at least eight hours of exposure per calendar quarter. For exposures that have occurred in past job assignments, "repeated" shall mean at least two calendar quarters. It should be recognized that these exposure criteria represent an administrative judgment, since minimal exposure levels required to cause disease are not known with certainty at this time. This administrative judgment may be revised in the future, with the concurrence of Corporate Medical, Toxicology, Safety and Industrial Hygiene and the affected functional management. DPMC-10568 LAM 016824 Q 3 Imp 1 emeritationj__ Suggested Action Plan/Guidelines - Evaluate exposures and identify employees whose job assignments, now or in the past, result in exposure to asbestos as defined in the Policy, and include them in the annual asbestos medical surveillance program. - Due to the varied nature of potential exposure throughout Shell, there may be specific employee concerns that will require the prudent, balanced judgements of both functional management and the Head Office Corporate Medical and Safety and Industrial Hygiene Department. Full consultation, prior to arriving at a decision, is encouraged in these cases. - For-the above identified employees, provide improved training and ) information to emphasize: a) Synergism of asbestos and smoking. b) Need for participation in medical examination programs. Review current operating procedures for reducing or eliminating physical contact between asbestos fibers and employees. ) LAM 016825 DPMC-10569 ATTACHMENT IV PDU - 1956-1976 - Epon I 1968-1976 .B. 20 H^btbl/04 5-2-84 L*M 016826 DPMC-10570