Document RpJ4MwR8J429dagymvV5gEo0a

) I Subfact: Manufacturing Guideline O Mew 0 Revleed RECOMMENDED WORK PRACTICES FOR HANDUNG ASBESTOS Issued by Plant Engineering Office Number C3-19 ' 0at* September 1984 * APVUCASUI TO. MAMurscruemo tMOmeiMMo V ruurr CMOMeemtM CM1AUTY CONTROL Y effective: ___ immediately O J c 3 3 1. SCOPE Asbestos is a recognized human carcinogen. The permissible exposure level (PEL) set by OSHA is 2J3 fibers per cubic centimeter for an 8 hour time-weighted-average and 10 fibers ceiling concentration per cubic centimeter of air for fibers longer than 5 microns as protection against asbestosa or scarring of king tissues. A lower PEL has been proposed. Medical monitoring of employes must be conducted when 8-hour average exposures to dust exceed 0.1 fibers per cubic centimeter. This guideline outlines a basic approach for limiting employe exposure to asbestos fibers during inspection and repair operations. A slide-tape asbestos training program is available to all components from Employe Health Services. 2. APPUCATION t This Guideline b directed to all Company operations. Manufacturing Guidelines are available tpon request to all Company subsidiaries and affiliates. 3. GENERAL A potential hazard exists wherever asbestos b cut, ripped, drilled, ground, or handled in any way which causes dust to become airborne. The best way to minimize asbestos exposure b to follow good work practices and use equipment designed to protect employes from breathing asbestos. . When adbestos materials are being replaced (Le. thermal insulation on pipes) or when new facilities or additions are being planned, non-a&estos materials should be utilized. Asbestos materials should be used only when no sxfcstitute b available. Some substitutes are listed in this Guideline. Company research projects are presently underway to identify additional substitutes. CFR 61.20, Subpart B, establishes the requirement that the local EPA Administrator be notified prior to the start of demolition or renovation activities involving asbestos. Contact the Stationary Source Environmental Control Office in order to Insure that this requirement b met. 4. WORK PRACTICES Under the provisions of the OSHA standard, strict work practices and special equipment are required when adxestas b handled In such a way as to cause potential employe exposure to airborne fibers and dust. The following work practices are required when airborne concentrations of asbestos fibers may exceed exposure limits. ' i * If more than three years old. eee Manuel Index lor latest review date. c O Tt ro o O rj Ot o PRODUCED BY FORD IN Kl!2i!XHl SCF-ALLF-09310 SSLTMManufacturing Guideline Number G3-19 Pag* Oat* Sept. 1984 2 4.1 Pipe Insulation . | Most pipe Insulation Installed prior to 1972 contains ad>estos. Generally maintenance and/or replacement of insulated pipes requites removal of the ad>estos covering. To minimize the release of asbestos fibers kite the air and decrease potential employe exposure, the following work practices must be followed! . ' 4.1.1 All employes removing adbestos pipe Insulation must wear approved respirators and 3>ecial clothing. This is not only a good work practice. It b a requirement of OSHA regulation 29CFR 1910.1001 (CX2XLU). Contact hdustrlal Hygiene and Toxicology for information an approved respirators. 4.1.2 OSHA regulation 1910.1001 contains explicit requirements and work practices whidi must be followed when the potential far siestas ejqxwure can occur. The regulation provides details am respirator programs, change rooms and clothes lockers, area and personal sampling requirements, caution signs and labels, house keeping, waste disposal, medical recordkeeping and -medical -examinations. This regulation must be consulted and followed. 4.1.3 Isolate the repair area to keep other employes as far as possible from the repair operation. The surfaces to be repaired must be wetted down whew possible or treated with commercially available dust sigtpressant to control dispersion of adrestos fibers. Vet methods of duqt suppression are most effective in controlling exposure to airborne fibers. 4.1.4 Place plastic sheeting on the floor beneath the repair site so that all pieces of Insulation, however small, can be collected when finished. Pedestrian and vehicular traffic can redisperse asbestos Into the air If pieces are left an the floor. Pieces of equipment, structures, ettu, which are covered with friable adbestos material must be wetted down and must not be thrown or dropped during removal. 4.1.5 If It is necessary to sweep the adtestos, the floor must be wetted down to keep the fibers from becoming airborne. Approved vacuum cleaners must be used to clean the floor of any remaining dried ad>estos dust and small pieces of material. Industrial Hygiene and Toxicology can recommend approved, highly efficient vacuum cleaners. 4.1.6 All waste, scrap, and debris, as well as asbestos-contaminated clothing, must be wetted and placed in sealed impermeable bags or containers for proper disposal. No asbestos-containing insulation should be placed In open trash containers or dumpsters. Ail waste material containing adtestos or containers into which waste Is placed for disposal must be labeled In accordance with OSHA Standard 1910.1001 (GXzXiXU). See Section 4.4.6 for diq>osal requirements. . 4.1.7 Because asbestos fiber can be dispersed throughout adjacent areas by ventilation systems, air-supply fans In the vicinity of adbestos removal projects should be turned off; exhaust fans should be left on (unless these fans are part of an air recirculation system) to keep the area under negative pressure. Any grinding or cutting of ad>estos containing material must be done with local exhaust ventilation which conforms to OSHA Standard 1910.1001. * It mors than three years old, aaa Manual Index tor latest review date. COATES V T0 R0 - 0209 PRODUCED BY FORD IN TITO its SLnManufacturing Guideline Number G3-19 Oats Sept. 1924 Pass 3 4.1.2 When repair operations are complete, if the pipe must be reinstated, asbestos containing products are not to be used for two reasons: (a) cutting and fitting of asbestos-containing insulation can generate significant amounts of airborne asbestos fiber even though it cannot be seen, and (b) asbestos may be banned from use completely except where suitable substitutes are not available. 4.1.9 Currently, there is not any one material on the market which can be substituted for asbestos in all of its applications. It is expected that manufacturers will produce substitute materials. There are insulation substitutes currently on the market and some are listed in "Mechanical Design and Equipment Standards" (Plant Engineering Office, Manufacturing Staff, Page M4-1, January 1976). Typical substitutes are listed below: 4.1.10 Steam Piping Inside Boilerhouses Manufacturer Acceptable Material Certain-Teed Saint Gobain (CSC) Johns-Manville Owens-Corning Celotex Corporation , Pabco Snap-On (to 450 F) . Calcium Silicate Kaylo Careytemp Expanded Silica (1/2") Calcium Silicate Inside Manufacturing and Office Building Manufacturer Acceptable Material Certain-Teed Saint Cobain (CSG) Johns-Manville Owens-Corning Pabco Snap-On (to 450 F) Flame Safe Heavy Density Sectional Calcium Silicate 4.1.11 Condensate Piping - (Inside Building) Manufacturer Acceptable Material Armstrong Cork Co. Certain-Teed Saint Gobain (CSG) Johns-Manville Owens-Corning FR/Armaflex Snap-On (to 450 F) Flame Safe Once Piece 4.2 Brake and Clutch Repair Brake and clutch mechanisms on vehicles, presses and cranes utilize asbestos friction materials. Exposure to asbestos dust in the air can occur during inspection and repair operations especially if compressed air is used to blow off debris. To minimize the potential for employe exposure, the following work practices must be adhered to: H more than three years old. see Manual Index for latest review date. COATES V FORD - 0210 PRODUCED BY FORD IN TO its Manufacturing Guideline Number 53.19 Page D,t* Sept- 1984 4 ) 4.2.1 Under no circumstances shall compressed air biowoffs be used to clean parts which may contain asbestos laden dust. 4.2.2 Brake and clutch mechanisms should be cleaned using an industrial vacuum cleaner with a filter system capable of capturing a three miaron or smaller particle size. Information on recommended units is available from the Industrial Hygiene and Toxicology Department- . .. 4.2.3 The filters on the discharge ports of approved vacuum cleaners must be disposed of when they become loaded per asbestos disposal procedures (see 4.1.6). Do not attempt to clean these filters. . 4.2.4 4.2.5 Disposal of any asbestos laden dust resulting from brake or clutch repair and maintenance or from vacuum cleaning must be carried out by an employe wearing an approved respirator. Such waste material and any vacuum cleaner bags must be placed in sealed containers and labeled as containing asbestos wear debris. Vacuum cleaner bags are not to be emptied by shaking; these bags are not to be reused. It should be noted that brake shoes, clutch-plates and other manufactured articles containing encapsulated asbestos need not be specially handled, marked or disposed of. Customary solid waste disposal techniques may be employed for such materials. See Section 4.4.6 for disposal requirements applicable to asbestos containing wastes. The repair area should be kept clean of all visible dust. Even small amounts become airborne repeatedly as a result of pedestrian and vehicular traffic. 11 sweeping is practiced, it must be done only after wetting down the floor. Approved vacuum cleaners must be used to clean the dried asbestos dust from the floors. Conventional vacuum cleaners may not be capable of retaining asbestos fibers which may penetrate the filter and be dispersed into the air. ) 4.2.6 All hand-operated and power-operated tools, which may produce or release asbestos fibers in excess of permissible levels, must be equipped with local exhaust ventilation which conforms to OSHA Standard 1910.1001. 4.3 Other Maintenance Materials - There are other maintenance materials that contain asbestos and may be in use at Company facilities. To the extent that commercially available alternates are available, they should be substituted for any materials presently In use which may contain asbestos. While the following list, condensed from a government synopsis of asbestos-containing products, is not all inclusive, it can be useful in identifying materials for which asbestos substitutes may already be available: Paper Products: pipe and boiler covering, sheets for heat insulation, millboard sheet, filtering materials, roofing felt. i orc . Cloth and Woven Products: . Flame Resistant Garments: seals' for high temperature gaskets, valve stem packing. Insulation for glass-handling tools. gloves and mittens, sleeves and arm protectors, aprons. blankets. ) * If more than three years old. see Manuel Index (or latest review date. COATES V FORD PRODUCED BY FORD IN Number ^3-19 Pag* Guideline( Manufacturing * Sept. 1984 .5 . Asbestos Cement Products: welding shields, siding, mastics, sealers. . Miscellaneous: acoustical and sprayed thermal insulation, asbestos powder, bulk fiber. 4.4 General Precautions . The work practices listed in Sections 4.1 and 4.2 are intended to help minimize the hazards involved in handling asbestos during insulation removal and brake and clutch repair. In addition, the following general precautions are recommended: 4.4.1 Employes must be trained in the proper use and limitations of respirators. A slide-tape training program is available from Employe Health Services. 4.4.2 Respirators must be cleaned and disinfected after each day's use. 4.4.3 Employes must be evaluated by medical personnel to determine if they are qualified to do required tasks white wearing respirators. 4.4.4 Initial monitoring must be conducted (as prescribed in CFR 1910.1001 (FX1)) to determine if employes exposure to asbestos is below permissible levels. a. ( 4.4.3 If an asbestos exposure problem Is suspected, the Industrial Hygiene and Toxicology Department must be contacted to measure asbestos levels and advise of other provisions of the applicable standard relating to respirator usage and record keeping. An industrial hygiene survey including air sampling will assure that employe health is protected and that tfw Company is in compliance with OSKA regulations. 4.4.6 Regulations promulgated by EPA under the Resource Conservation and Recovery Act (RCRA) identify asbestos as a listed hazardous waste. When disposed of as a waste "commercial chemical product," such materials must be disposed-of only in a RCRA-permitted hazardous waste landfill. This requirement underscores the need for segregation of asbestos-containing waste from other plant waste. Encapsulated materials and manufactured articles containing nonfriable asbestos are not classified as hazardous wastes tmder RCRA. Refer to Stationary Source Environmental Control Office for specific federal, state and local disposal requirements for asbestos containing materials. 2-26-17 * II more than three years old. see Manual Index lor latest review date. PLAINTIFFS^ EXHIBIT PRODUCED BY FO] CATES V F0R0 - 0212