Document VGLRyBmgvxOBKvrzNrEJYne68

TO: J. Brown Wallace Carl Riehaxdaon Fred J. Saloon E. Lin Longshore J. E. Woodward 1979 CORRESPONDENCE INDEX FROM: Industrial Civil Division Carl Richardson Charles Tedder Carl Richardson CATE: 8-17-79 10-10-79 11-26-79 Milwaukee Construction Industry Safety Council Steve Sellers 4-2-80 Ron Christesson 7-18-80 MEMO: Asbestos Progran - Job 4156. Waxahachie, Texas Asbestos Saaple of Casket Material Asbestos Sampling .Asbestos Safety t Health work Practices Guide Proper Asbestos Disposal for job in connection with South Carolina B S R - Chevron Safety Meeting Asbestos Log - Job s 34-1266 and 3S-4025K Current Report - Asbestos OSHA INSTRUCTION GIVES PRO CEDURES FOR DOCCy-ENTING PAST EMPLOYEE EXPOSURE PLAINTIFF'S exhibit B&R-65 TO: Sea Distribution B. w. Bryant* Project Managers Safety 5i$>ervisors Rick Carter Dear Colleague Fred Salmon Gordon P. Hurd 'gar Tankers ley C. L. Crane H. C. Dodd Greg Garvin Carl Richardson Bill Lynch Distribution 1979 CORRESPONDENCES INDEX FROM: Safety Department Tommy O.advie* Tossy Chadwick Carl Richardson DATE: 11-7-72 11-16-72 1-9-73 6-23-75 J. William Lloyd, Sc.D Carl Richardson Carl Richardson 8-8-75 4-1-76 3-11-77 Richard Wilson 5-4-77 L. A. Ashley Carl Riehardson William Bedman Carl Riehardson 6-17-77 9-28-77 2-6-78 4-5-78 J. W. Cos Petro-Chao Construction 1-26-79 MEMO: OSHA Safety Memo #22 of 7-17-72 OSHA Memo #22 and #25 Pertai: ing to Asbestos Recordkeeping for Asbestos Asbestos and Fiberglass Sampling Dept, of Health, Education, and Welfare Asbestos Recordkeeping Re quirements Galbestos Roofing and Siding Material Ref: letter dated 9-27-76, OSHA Asbestos Standard <290* 1910.1001) Asbestos - Cadvelding Asbestos Exposure OSHA Asbestos Standard Medi cal Examination Requirements OSHA Asbestos Standard 1910.1001 Asbestos Titls 29- Labor Chapter XVI Occupational Safety and Heal AAainistration, Depar-nner.t c Labor - standard for Exposure to Asbestos Asbestos dust - Guidelines for Control and Measurement Safety and Environmental Che list for the Solution Plant Dismantling -- Revision Asbestos Program - Job #341266, Wynnevood, Oklahoma M | H OFFICE MEMO TO: C. 1. Crane H. C. Dodd FPOM: L. A. Ashley SUBJECT: Asbestos - Cadvelding DATE: June 17, 1977 I talked with Jaaes Barry, Chief Engineer of Erlco, concerning his testing of refrasll rope for cadwelds. One of your projects furnished him a 10 ft. sample. He cold ae chat they had satisfactory results with the refrasll but were concerned with the release of flourocarbons since the material was Teflon coated. Be Is going to send ae a letter to this effect, In addition, beginning August 1, 1977 Erlco will no longer furnish asbestos rope but a ceramic type rope, I requested chat they send each of you 20 ft. prior to August In order that you alghc run aoae tests yourselves. 1 think we previously tried this aaterlal unsatsifactor uy but I'a not sure. In the meantime we will continue to use the asbestos rope. As soon as you can inform ae of the results of your testing of the ceramic rope; at the saae time I will ask our industrial hygenisc to look Into the potential flourocarbon problca. *ce: L. D. Pyeatt Bert Hale Carl Richardson V. A, Ashley Safety & Training News Hay 19, 1980 DO THE JOB RIGHT - AND IT WIDE BE DONE SAFELY The Following is a safety rule rerrir.de?: The following procedure will be followed when removing old line ar.d Vessel insulation. Dine and vessel insulation installed prior to 1972 may contain asbestos, Please follow all safety precautions described: 1. Before removing insulation, all insulating materials should be wet down. 2. Pick up and bag all asbestos scrap as soon as it is removed. J. Loose asbestos that collects on the ground should be wetted and cleaned up as soon as possible. It. Only special plastic bags with the appropriate asbestos warning label are to be used. They are available in the storehouse. 5. The bags containing asbestos wastes should be set aside for disposal by an approved hauler. . Employees removing the insulation will wear a JM 8710 single-use throwaway respirator and paper-type coveralls. The respirators are available from the storehouse. The coveralls are available from the storehouse. After use, the respirator* and coveralls should be discarded in the plastic bags. Charles C. Albrbton Safety Engineer Brown Root, Inc. Post Office Box Three, Houston, Texas 77001 MEMORANDUM TO: J. E. Woodward DATE: July 18, 1980 FROM: Ronald Christesson SUBJECT: Brown & Root - Chevron Safety Meeting RE: Attachments (1) Memo of 9 July, 1980: J.E. Woodward to F.W. Bell "Safety Procedures - Asbestos Insulation (2) Brown 8 Root Asbestos Handling Procedures (3) Chevron Asbestos Handling Procedures ATTENDEES: Brown 8 Root Frank Yancy Ronald,Christesson Chevron Bob Taggert Charlie Albritton Marty Bowin On July 17, 1960, a meeting was held at the Chevron jobsite in Pascagoula, Mississippi to discuss proposed procedures for Brown 8 Root's handling, monitoring, and disposal of asbestos Insulation on the Chevron Project. The following agreements were reached during the course of this discussion (1) It was agreed that Brown 8 Root's procedures for asbestos handling are compatible to those used by Chevron and are acceptable for the Project's needs. Chevron representatives offered Brown 8 Root employees the use of disposable respirators 8 paper-type coveralls, available at the Chevron storehouse, for protection In accomplishing this work. Disposal of the same shall comply with Chevron Asbestos Handling Procedures. (2) Chevron's representatives asserted that monitoring during asbestos handling would be unnecessary based upon results from previous monitoring reports. Brown 8 Root's represent-, atlves reconmended monitoring this asbestos work In compliance with the section entitled "Monitoring* within the Asbestos Program of the Petroleum 8 Chemical Division. Brown ifRoot.Inc. Page 2 July 18, 1980 Brown & Root-Chevron Safety Meeting (3) Regarding the disposal of asbestos waste, Chevron representatives advised Brown & Root that this is not possible within the state of Mississippi due to legal restrictions. It was recommended that Brown & Root contact Mr. James 0. Phillips of the Environ mental Pollution Control, Inc.,`P. 0. Box 16445, Jackson, Miss, phone (601) 981-9224. Mr. Phillips will assist in the asbestos disposal by coordinating the transportation and permitting necessary to have this done in Alabama. Chevron recommends Brown t Root compile an estimate of the asbestos disposal requested to be submitted to Mr. Phillips in advance. These things accomplished, this meeting was adjourned with the general consensus that the agreements reached would achieve completion of the asbestos work in a safe manner. If you have any questions, please contact the undersigned. Sincerely RC/dlb Ronald Christesson Brown CTRootlnc. /- INTEROFFICE MEMORANDUM TO: FROM: SUBJECT: F. W. Bell DATE: July 9, 1980 J. E. Woodward FILE: 420.800.50-035 Safety Procedures - Asbestos Insulation We request permission to send Mr. Ron Christesson to the plant site Thursday, July 17, 1980, to discuss safety procedures per taining to asbestos insulation. Mr. Bob Taggart of Chevron has confirmed existing units, particularly Crude Units I I II contain asbestos insulation. We would like Mr. Oiristesson, Safety Manager of Brown t Root, to discuss procedures for handling, monitoring and disposal of this material with Mr. Taggart and the plant safety manager. Mr. Taggart Is aware of the planned meeting. JEW:JR:ls cc: R. W. Harrington R. C. Chrlsttsson J. R. Routt Brown ^Root.lnc. Post Office Bo* Three, Houston. Te*as ~~0cn April 2, 1980 nr. E. Lin Longshore South Carolina Department of Health and Environmental Control Solid and Hazardous Haste Management Division 2600 Bull Street Columbia, Carolina 29201 Dear Mr. Longshore: On March 26, 1980 I spoke to you in regards to proper asbestos disposal according to your department's regulations. I as familiar with Federal 05HA and EFA regulations but am not familiar with special state regulations pertaining to asbestos disposal. Brown t Boot, Inc. is bidding a contract job in the state of South Carolina and would like to know the steps to be taken, permits needed and approximate costs of such permits to properly dispose of asbestos waste in a sanitary land fill in the area around Columbia. I would also like to know the names of reputable waste disposal companies in the Columbia area which already possess asbestos permits which could service us. Also mentioned in our conversation was the possibility of bury ing the asbestoe wait* on sita. what eritaxia and/or permits axe required for this type of operation? What is the approximate time period needed by your department for processing such permits prior to our beginning work? These questions are important to our management and answers are needed before submitting proposals to the client coapany. Thanking you in advance for your help in this matter. * SS/df Steve Sellers, Industrial Hygienist Safety t Health Department BRCVN l ROOT, INC. OFFICE MEMO TO: Fred J. Salmon FROM: carl Richardson SUBJECT: Asbestos Sampling CATE: November 16, 1979 A medical set-up was established for maintenance work to be conducted at a Mississippi Power i Light Plant in Jackson, Mississippi, job number 35-4025. Asbestos insulation tear out was to be performed as part of the job. Per conversation with Mr. Peterson at the Corsieana, Texas offiee, I was to be notified as to the date of insulation removal at the plant. This would allow the Environmental Health Section time to monitor asbestos exposure in order to comply with the CSKA standard and to docwient employee exposure levels. On November 20, 1979, I again called Mr. Peterson at the Corsicana office concerning the insulation removal. At this time, I was informed that they forgot to notify me about the removal and the job was almost ecnpleted. A more unified effort of eonnunication is needed between the jobsite, the division safety offiee, and the corporate safety office on matters of this nature. JU CR/df ce: Bert Hale Del English Pile Carl Richardson, Managtr - Environmental Health Services Safety c Health Departtent Brown OTRoot. Inc. Post Office Sox Three, Houston, Texas 77001 r: October lo; 1979 35.5019 TO; Carl Richardson FROM: Charles Tedder SUBJECT: Sample of Gasket Material Mr, F, K, Pimely" Assistant Manaaer* Power division Safety, asked me to send you two samples of Gasket Material used on Project 35-5019, Mr, Parmely asked If you could possibly tell how much asbestos', If any is contained within these materials, Charles Tedder Safety Supervisor cc: file i -- r -- Title 29--Libor .CHAPTER XVII--occupational safety l AN 0 HEALTH ADMINISTRATION, DE PARTMENT OF LASOR part mo--occupational safety I ` erdi and exposure records, end the fact that the standard required that medical i records be maintained for st least 30 I yean, the Court txpressed surprise at ,,, the ihor: three-year retention period | J lor monitoring records After reviewing ANO HEALTH STANDARDS ,);thi Secretary's obligation under toe Act Standard lor Csoosure to Asbestos ,'.,to require retention of records neces; ], sry for the development of Information Pursuant to aecuana I'b) and S'e> 1 concerning the eauses of disease and the ol the Occupational Safety and Health ; ; biaerunce of exposure data in cstab- Art ol 19T0 (14 Sut. 1993. 1399: 39 U S C. -> j. fishing this eausal relationship, toe Court US 1ST!, Secretory ol Labor Order No. fl remanded the rtcordkeepinf require- 13-71 (39 PR 97941. and 39 CPR Port S menu to toe Secretory "for such modifl- 1911. t 3919.1001(11 (1) ol Port 1910 of * cation or clarification as may be neces- Title 39. Code of redtrol Regulations. to ` aary to ensure that toe statutory objec- hereby amtnded In the manner ort forth below. In order to extend the retention period for aobestoo exposure monltorlnt records from three years to twenty years. _Hvie will be fulfilled" A99 P. 3d at 499. '7 Punuant to the Courts direction. OSHA hai completed Its review, and haa 1. tcecluded that the opinion expressed by On December 7. 1971 US PR JJ307), OSHA issued an emergency temporary standard on asbestos in response to a pe I' Ihe Court Is an accurate rtfiectlon of toe it record. and that the agency's Initial Jedrmrot warrants eorrecuon. tition by the Industrial Union Depart ment of the ArD-CIO. pursuant to sec tion <(c> of the Act (94 Btat. 1999. 39 OiC. 99S>. This emerteney temporary standard was designed primarily to Immediately reduce and eontrot occupa tions 1 exposure to ashestoe dust concen trations. and did-not contain record keeping procedures. However, on Janu ary 13. 1973 (37 PR 499). OSHA pub OSHA believes that extension of tot 2-i recordkeeping requirement for exposure Uia monitoring from three yean to twenty yean as originally proposed would be In harmony with tot twenty-year retention bwtod now required for employee medi ae! records. 39 CPR 1S10.1MKJ) (f) (I). At the court noted (499 P. 3d at 49*). toe lwo seu ef records when read to- lished a proposed comprehensive stand ard for asbestos exposure which did |t4btr would provide a more eompltt* resold of an employee I history of ex- include recordkeeping provisions. ParagTaon (hull of the proposal (37 PR vl ton a factor vitally.important with rweci to ubestos-reiated diseases The 499) provided that exposure monitoring J ueded period for retention, with re- records, and records of medical exeml-R nations, be maintained for a period of . --itont data accumulation, win bs erlt- >2 Ml* medical and eclentlfle tnveatiga- twenor years. After public hearings the 1 here itudytng auch questions as dose- Secretary promulgated a new. perma- n*ocm relationships In disease caused ` nent OSHA standard tor asbestos on J* eeeupatlenil crposure to asbetoa. June 7. 1973 ( 37 PR 1131H. in accord ok decision would ala bo rasponslve to ance with section 9(b) ef the Act (94 Slat 1993. 39 Ufi.C. 195). ThU new reg ulation. which appeared as 39 CPR 1910.93a prior 4e neodtfleatlon. con tained a three-year requirement for re taining exposure monitoring records. 39 the agency i declared concern that toe past inadequacy ef health and monitor ing records have hindered mearch Into tot consequence of asbetos apeeure at toe workplace. PR 11319. June 7.1973. The long laiapcr periods associated CPR 1910.93a(l) (1> (now 31 CP1C 1S10.9001 (I) (1)). On July 37. 1973. pursuant to section 9(f) of the Act. (94 SUt. 1997. 39 U.8.C. 999). a petition for Judicial review of the asbestos standard was hied with the United Its tee Court of Appeals for U)e - District of Columbia The principal petlMoney*. the Industrial Union Depart ment. AFL-CTO, objected to several subtantive portion* of the standard, includ ed those dealing with recordkeeping. The Court affirmed the Secrsury i Judgment* and the tundard't validity exrept for two provisions, one of which was the retention period for exposure monitoring records. "Industrial Union Department. API--CTO . Hodgson." 499 P. Id 417 (C-A.D.C. 1974). The Court directed the Secretary to re-examine the Undard with rrspect to the three-year recordkeeping provision and to recon- with asbestow relsied dlae*Ms. and the consequent seed for a standard to take men lafeney periods into account, were recognized by both to* OSHA Adetar7 Committee on Asbestos Dust (proceedtoft tt pp. 109-109. February 17. 1073) and to* HIOSH Criteria Document for a Recommended Standard on Asbetoa (fensrally chapters I and II). In addi tion. testimony by two wttneae at tot OSHA hearings also supported longer re tention periods for exposure monitoring records (Tr. at 937. 93. March 17. 1973). A consensus of to* evidence In tot record tndlciwe that expeaure monltortni rec ords should be held for at Inst 39 yean to order to mate sueh a requirement meaningful In new of what la generally reeoesiaed as toe minimum latency pe riod for manr asbssua-related diseases. OSHA li of toe view that toe Interests of worker health would be best served by rtder whether sueh time period ade- uatelr assured employee protection Uem asbestos-rtlaled diseases. In discussing this issue, the Court requiring tot retention of exposure mon itoring records for a period which re flects an Appreciation of this recognised latency factor. Poled that manr of the problems facing the Secretary in developing an asbestos standard were directly attributable to Ihe lack of Information concerning ebeetou related diseases, and pertleu- hrtj to toe lack of reliable dau on past exposure levels. Noting toe dose func tional rtiauonahlp between medical rec- Accordingly, pursuant to the Court's remand for further esnsideriuon ol u-.e mention period for monitonne records. t have concluded, based on toe exist ing record and for ihe reasons stated above, that a 30-year retenuon period is uoported by ihe evifler.ee end neces sary for toe protection of employees It i Is noted that in a new prouosai on ex posure to asbestos < 40 PR 47412. October 9. 1979). which reflects the most recent scientific and medical developments in toe field, a 40-year retention period (or toe duration of employment plus twenty yearn for both exposure measurement and medical records has been proposed. Por the reasons suited above, toe ex posure records provision of toe asbestos standard will be corrected to require re tention ol exposure monitoring records tor at least 30 yean, effective March 19. 1971. OSHA believes that a delay in toe effective date of this requirement Is not warranted since tola rule only requires that affected employers retain records which they have already compiled and therefore does not Impose a new burden ef action, and since toe initial three-year retention period for auch records has now lapsed and these records might be destroyed. Lost of such records would be Irreparable. Continued acetsa to such records by all concerned Is essential in tot public interest, end is an appropriate means of effectuating the goals of im proved worker safety and health under toe Act. Oood eause Is found, therefor*, pursuant to section 4<d>(3i of the Ad ministrative Procedure Act (9 O S C S93 (d)(3)). for making this rule effective. Accordingly, pursuant to toe direc tion of the United States Court of Aoptals (''Industrial Union Department. APL-CIO e. Hodgson, supra'), and toe above rtfereaced authority, paragraph (1X1) of 39 CTR 1910.1901 li hereby amended to read as followi; (l 1919.1001 Asbweles. ' ' (I* firrordieepise--(1) Irjwmre reeovgj. Every szlorw ahaO ***<* rec ords of any personal or esrimaseceal monitoring required by Uus section. JLec ords shell be maintained for t period of tt least 30 yean and shall be made avail able upon request to tot Assistant Sec retary of Labor for Occupational Safety and Health. Ihe Director of toe National Institute for Occupational Safety and Hteito. and to authorised rtpntenu- Ueee of either. . V 1 (8m. i t. rub l ei-set. as sut tie:. istt 19 DSC. sal. sail: Secretary or Lesova Oretv Its. 19-71 (94 P* 1794); 9 CPS Para Itil). filmed at Washington, D C. tola 13to day ef March 1171. Moscow Coaw. Agstsfanf ffrerefsry of Labor. IP* Oos.le-TTlI Plltq >-11-111 as ami industrial hy si:ne pro^ ' directives quired during the shift m avoid overloading the filters (j) Exposures 10 asbest is dust unit high levels >l conianunation. U) Several samples m.iv be required during the shin to avoid overloading the filter. (b I Filters should be changed onl> after a minimum of I hour of sampling time for exposures expected to be close to 0.1 fibers cc. Seven or eight l-hour samples can be collected during the day. d. Examples of types of violations. 21 91 S3 (II Where an employer does mu provide the required medical evamni.inons. and an eniplmee i' exposed io d.l nr mure libers cc. it would he Considered a "serious" violation of2CFR 1910. IOOKjii 2). or (Ti or id). (2) For def muons and guidance on "repealed." "u dlful." or a "lailure to correct" violation, see the FOM. Chapter VIII. 5 Ell'ccnvt D<jie This directive is effective immediately and will remain in effect until tunher notice. nit-TS Published by THE BUREAU OP NATIONAL AFFAIRS. INC.. RASHISOTON. D C. 2O0vr ar 21:9158 (3) Macc'ium arsenate. (J> Sodium arvcntic. (5) Zinc arsenate. (b) Zinc arsenite. i') Am flin'rn.irxenatc I Manufacturers nl'clcMCCants. Example ; Orvmsarseme acid. I Manufacturers of wood preservatives. Some examples of these products are as follows: O) Ammoniaca! copper arsenue. (21 Chroniated copper arsenate. (3i Mixture of chlorinated arsenate, fluoride and phenolic salts m aqueous solution. Ml Zinc-chronnum arsenate. (S) Cnpperiaed zinc-chromium arsenate, ib) Fiuorchrome arsenate phenol. h. Manufacturers of teed additives. Some examples of these products are as follows: (1) Arsanilic acid. (2) 3-Nitro-4-hydroxyphenylarsonie acid. (3) 4-Nitrophenylarsonic acid. (4) a-Ureido-l-phenylarsonic acid. i. Manufacturers of pharmaceuticals for use in veter inary medicine. Some examples of ihese products art as follows: (I) Acetarsamtde. (21 Carbarsone. (3) Dtchlorophenarsine. (4) Lead arsenate. (5) Melarsonyl. (6) Neoarsphenamine. (7) Thiacetarsamide(Caparsolate). j. Manufacturers of glass that use arsenic tnoxide as a refining agent and a decoloriaer. It. Manufacturers of alloys of nonferrous metals and arsenic. Some examples of products manufactured from these alloys are as follows: (1) Lead shot. (2) Cable sheathing (lead and arsenic). (3) Battery grids (lead and arsenic). (4) Battery electrodes (lead and arsenic). (5) Speculum metal. (6) Boiler tubes (Copper and arsenic). (') Arsenic bronze. (Si Special solders such as used on body joints and seams in the automobile industry. (91 Arsenic brass. < 10) Arsenical Babbitt. l. Users i>l vildurs that contain arsenic as a com ponent in ihe alloy. Example: Automobile and truck body manufacturers. m. Manufacturers and/or users of arsemc-bascrf fioiation reagents. n Miscellaneous. Arsenic and/or arsenic-erntaining. inorganic com pounds are used in each ol ihe follow ing types of estab lishments. However, every employer does not necessarily useihem. REFERENCE FILE II) Leathertanneries. (2) Manufacturers of ceramics and ceramic or vtireous enamel. (3) Manufacturers of analine colors. (4) Manufacturers of pyrotechnics. (5) Manutaciurcrs ni sciincnniliiciers. OSHA PROCRAV: DIRECTIVE *300-16 October 11. 1978 TO: REGIONALADM1N1STRATORS/OSHA Subject: 29 CFR )910.1001(jX2) or (3) or (4). Minimum Airborne Fiber Concentration for Initiating and Continuing Asbestos Medical Examina tions. 1. Purpose The purpose of this directive is to piovide uniform inspection and compliance procedures for the medical examination requirement in the asbestos standard. 29 CFR 1910.10010X2). or (3) or (4). 2. Documentation Affected This directive supplements and provides reference for the OSHA Industrial Hygiene Field Operations Manual (IHFOM) and the OSHA Field Operations Manual (FOM). 3. Background In 29 CFR 1910.10010X2). or (3) or (4). Medical ex aminations. the term ". . . exposed to airborne concen trations of asbestos fibers. ..." has been the subject of considerable discussion and debate as to the meaning or interpretation of "airborne concentrations." 4. Action a. Definition. In 29 CFR 1910.10010X2). or (3) or (4). Medical ex aminations. the term ", . . exposed to airborne concentra tions of asbestos fibers...." is administratively interpreted to mean exposed to a minimum of 0.1 asbestos fibers longer than S micrometers per cubic centimeter of air. as deter mined by the sampling method prescribed in section 4.c. of this directive. The phrase "fibers longer than 5 micro meters per cubic centimeter of air" shall hereafter be aobreviated as "fibers/cc." b. Scope and applicability. Medical examinations as per 29 CFR 19l0.1001ijX2.-. or (3) or (4) will be required for any 7- to 8-hour timeweighted average concentration of 0.1 fibers/cc. or for a greater concentration. c. Sampling information. (1) Sampling procedures will follow Chapter X ot the IHFOM.. with the additional guidance of 4.e.(2) ami (3) of Ibis directive. (2) Exposure to asbestos dust with lou levels of con tamination (c.g., mixed with other minerals). (a) For exposures to dust that is mostly asbestos and is expected to be below the permissible exposure limn, the same filter should be used for the entire shift, but no longer than 8 hours. (b) For exposure* expected to be at or above the per missible exposure limit, several samples may be re- OceuMtiorw 4 M*im Moon* 36 CURRENT REPORT 1325 rule "it far loo restrictive and invalidates alternative dosimeter tvpes which would be equivalently effective." de Bernardo said Regarding testing booths. Uie Chamber attornev said mat " essentially laboratory conditions would tie required to meet me low frequency noise specifications for me booms, which he called an "impractical and un workable requirement " There is confusion in me sundard of me terms "noise" and "dose" which causes "significant ambiguity * Training program requirements are escessive and pre sent "the-yotenual for harassment of employers " Recordkeeping requirements are "far too excessive and eostly." particularly for small and medium-sued businesses. The calibration requirements for dosimeters and audiometers are "exhaustive" and require more testing man necessary to ensure accuracy. Projections of me number of workers covered by me amendment, me overall cost of compliance, and me cost per worker for compliance are "badly underestimated." The requirements mat only audiologists, qualified physicians, and otolaryngologists evaluate audiograms and perform certain duues is "excessively costly and an inef ficient use of limned professional resources since trained technicians and qualified nurses could adequately perform such responsibilities " * The agency miscalculated me effect of impulse noise on measurements The Chamber has sought to stay me rule since it was issued on Jan 1< iCurrent Report. Jan 22. p. 133). Last month, me Chamber proposed to Reagan s task force on regulatory reform mat me eight-hour lime-weighted noise exposure to which workers must be exposed to be included in industrial hearing conservation programs under me new rule be raised from U dB to 90 dB (Current Report. Feb. 19, p. 12661 one racoon A similar.petition requesting suspension of me effective date of me Occupational Safety and Health Administration's new hearing conservation amendment, full review of the record compiled on me amendment, and a reopening of me record also was submitted March 2 to Secretary of Labor Raymond J. Donovan by the Organisation Resources Counselors. Inc. ORC criticised me amendment for relying on specification rimer man performance criteria and for being too technical ly complex for most employers. "In our mew. OSHA can solve me broad problem and many of the ^ecifie problems I contained in me amendment) only if it1 wbsutute* a perfor mance sundard for the excessively specification-oriented amendment." the orgmiuivm suted. ORC shares similar concerns with the Clumber of Commerce about a number of issues, including specifications for test booths, recordkeeping requiremenu. specifications required for dosimeters, whether dosimeters are reliable under me requiremenu of this program, definitions of significant threshold shift and revised baseline in me program, enforcement and need for me 14-bour quiet period, requiremenu for audiometer calibration, training requiremenu. effect of impulse noise on measurtmenu. and limiuuon of audiogram review to ceruui physicians. In addition. ORC requested that several issues, such as the cost effectiveness of me amendment, me oumoer of workers covered and me resulting overall cost of the amendment, the provision for employee monitoring of me program, possible confusion between the requiremenu of me amendment and those of me old sundard. me handling of computer programs, and me requirement that noise levels as low as 10 dBA be included in me time weighted average, receive ad ditional consideration and review before me amendment becomes effective Asbestos OSHA INSTRUCTION gives procedures FOR DOCUMENTING FAST EMPLOYEE EXPOSURE Procedures for documenting past employee exposure to airborne asbestos fibers when concentrations can not be measured by taking of air samples on me day of me inspec tion or thereafter were detailed in an Occupational Safety and Health Administration instruction issued Feb II. The instruction. CPL 2-2.21A. seu guidelines for deter mining whether asbestos had been used or handled regularly at me workplace - or. if it had been used or handled on an irregular basis, whether employees were exposed to "significant amounts" of asbestos-containing dust - for me purposes of the medical examination requiremenu of me asbestos sundard (Reference File. 31:13011. ComplUnct officers are instructed to obuin monitoring results from me employer or contractor, or from other sources. Information necessary to document asbestos use or handling is to be obumed through employee, employer represenutive. or union interviews, end through written employer information if it exisu. The instruction cancels a similar document issued in Oc tober 1971 but. except for me addiuon of me procedures for documenting pest exposure, leaves it essentially unchanged (Current Report. Nov 2. 1971. Reference File. 21.91561 Text of me instruction follows. Teat ef OSHA Inawucnen CPL 2-2.21A Subyert. 29 CFR I910.1001(jl(2>. (3) or (4). Minimum Airborne Fiber Concentration for Initiating and Continuing Asbestos Medical Examinations. A. Purpose. Hus instruction provides uniform inspection end compliance procedures for me medical examinauon re quirement in me asbestos sundard. B. Scope. This instruction ipplies OSHA-widt C. Cancellation. OSHA Instruction CPL 2-2.21. October 11. 1971. is canceled. D. Xenon. OSHA Regional Administrator and Aria Direc-. tors mail assure that enforcement of 29 CFR 1910 1001 (j><2). (3) or (4) is consistent with me guidelines in G of mis instruction. E. Federal Program Change. This instruction describes * Federal program change which effects Suu programs. Each Regional Administrator shall: 1. Ensure (hat this change is forwarded to each Sute designee. 2. ExpUin me technical content of me change to me Sute designee as requested. 3. Ensure mat Sute designees are asked to acknowledge receipt of mis Federal program change in writing, within 30 days of notification, to the Regional Administrator This acknowledgement should include a description timer of the Suit's plan to implement the change or me reasons why me change should not apply to mat Sute. 4. Review policies, instructions and guidelines issued by the SUU to determine that this change has been com municated to SUte program personnel Routine monitoring activities (accompanied inspections and ease file reviews) shall also be used to determine if mis change has bees im plemented in actual performance. F. Hurlrgruuml. OSHA has determined that generally ciutions should, as s matter of policy, be issued for J-12-gt Coovtqw 1941 by Tk* gwreew Of National affairs me 1326 violations of 25 CFR 1910 IOOKjhJi. <31 or <4<. only when employees are exposed to a minimum o1 0.1 asOestos fibers longer" than 5 micrometers per cubic centimeter of air. as determined by the sampling method prescribed in section C 2 of this instruction IThe phrase "fibers longer than S micrometers per cubic centimeter of air" shall hereafter be abbreviated as "fibers.cc."I However, for situations in which sampling of exposure is infeasible, citations may be issued as provided in C S of this instruction. G Enforcement Guidelines 1. Me<ical examinations as per 29 CFR 1910 1001 (jilt), f 31 or i S*i will be retired for any 1 to 9-hour time-weighted average concentration of 0.1 fibers/cc. or (or a greater con centration 2 Sampling procedures will follow Chapter X of the IHFOM with the additional guidelines of G.3 and 4. of this in struction 3. Sompfinp for Exposures to Asbestos Dust irith Lmv Levels of Contamination (t 0 , Mixed with Other Minerals) a For exposure to dust that is mostly asbestos and is ex pected to be below the permiaxible exposure lima, the unit filter should be used for the enure shift, but no longer than I hours. b For exposure expected to be at or above the permixxible exposure lima, several samples may be required during the shift to avoid overloading the filters. 4. Sampling for Exposure to Asbestos Duet with High Levels of Contamination. a Several samples of exposure may be required during the shift to avoid overloading the filter. b. Filters should be changed only after a minimum of 1 hour of sampling time for exposures expected to be dose to 0 l fibers/cc. Seven or tight i-flour samples caa be collected during the day 9 Hast Exposures When employees have been exposed to asbestos but air samples cannot be uheh on the day of the inspection or thereafter, citations for serious violauoa of 29 CFR 1910 1(901 (ju2*. 13) or (4) should be issued according to the following procedures: a Determine that employees wen exposed to airborne concentrations of asbestos, and that the use or handling of asbestos was performed on a regular basts: or that the use or handling of asbestos was performed on an irregular batis. but employees were exposed la significant amouata of dust containing asbestos. NOTE Compliance officers dull obtain monitoring results from the employer (contractor) or other source leg . insurance company; company or plant (or whom con tracting work it being done; building owaer/butidtng management, other Federal. State or local agency), and shall indicate expoeurt levels above 9.1 fibers/cc of asbestos. b Document, by employee, employee representative, and union interviews, that this work was performed routinely, on a repeated basts: or that the use or handling of asbestos was performed on ah irregular basis, but employees were expos ed to significant amounts of dust containing asbestos. In addition. obtain documentation from written employer infor mation on these routine operations, if it exists. c. The violative conditions must have occurred at least within the previous I months to meet the requirements of Section Si c I of the Occupational Safety and Health Act I. Types of Violations. a A "serious" violation of 29CFR 1910 lOOlijiiji. u>ar <41 would enst where an employer does not provide the re quired medical examinations, and an employee is exposed to 0 1 or more fibervec. *1M1 0<V+ OCCUPATION* 4FETY & HEALTH REPORTER b For definitions and guidance on "repeated", "willful" or a "failure to correct violation, see the FOM. Chapter Vlil. Litigation COURT RULES GRAIN DUST ACCUMULATION VIOLATES OSHA HOUSEKEEPING STANOARO An employer that has been cited twice for violation of the Occupational Safety and Health Administration s housekeep ing standard, for failure to prevent accumulations of gram dust in ns grain elevator, is in repeated, serious violation of that housekeeping standard, the U S Court of Appeals tor the Fifth Circuit. Unit A. ruled March J This decision in Bunge Corporation r. Secretary of Ixthnr and OSAIIRC (No 79-190$) affirmed a ruling of the Occupational Safety and Health Review Commission 17 OSHC 133$). The ease arose out of the inspection of the employer's Destrchan. La., gram elevator. During that inspection, the OSHA compliance officer found 42 locations where dust and grain had accumulated The citation charged that this condiuon was in violation of 29 CFR 1910 23ia)U> and that it created a fire hazard. This citation was the third such cita tion issued to the employer for violation of the same housekeeping standard. The first and third citations involved dust accumulations and the second involved material and ropes left in walking arets. After a hearing on the merits of the esse, an OSAHRC judge found the employer to be in repeated, serious violation of the housekeeping standard and assessed a * 10 000 penalty. This appeal followed. The employer did not dispute the existence of the dust ac cumulations at the grain elevator but. instead, argued that the housekeeping standard had been impermissibly expand ed to include fire and explosion hazards. According to (he employer, grain dust fire and explosion hazards can only be addressed by promulgating a specific rule covering those hazards. The appellate court rejected that argument, stating. "(*lhile a specific rulemaking may be preferable. OSHA is by so means obligsted to countenance dangerous conditions pending the promulgation of a regulation that specifically addresses one of the hazards that the condition generates." This opinion, which was written by Circuit Judge Sam D Johnson, who was joined by Circuit Judges Irving L Goldberg and Henry Point, will appear is a future Decisions issue. State Plena MONETARY PENALTIES AGAINST WORKERS SUBJECT OP OSHA INSTRUCTION TO PIELO States art not absolutely prohibited from leveling economic penalties against workers who fail to comply with job safety and health tundards. but any state considering the inclusion ot such sanctions in its state plan should evaluate the action carefully to determine whether it "weakens the effectiveness of the oyprall enforcement program." according to an Occupational Safety and Health Administration field directive. The document, OSHA Instruction STP 2-t.lA. dated Feb 24. also said that a state which includes such penalties in its plans "must show bow these sanctions would not reduce the overall effectiveness of the state's enforcement program below that of the federal enforcement program." 1432 OCCUPATION. SAFETY & HEALTH REROUTES Msximum radiofrequency emissions were 1 4 milliwatts per square centimeter iE-fieldi and 3 5 milliwatts per square centimeter <H-field>. with an occupational standard of 10 milliwatts per square centimeter f208 units measured i Lap Tttta Reported William A Herman of the division of electronic products. Bureau of Radiological Health Food and Drug Administra tion. reported on laboratory tests measuring X-ray. radiofrequencv ultrasound visible, and infrared emissions from video display units with "complete maladjustment of all controls" to produce the worst possible conditions These tests showed emission values "within existing state, federal, and international guidelines " Herman said he could not see promulgating standards for video display unit radiation emission "in the foreseeable future." adding that "we try to limit standards to things that need standards." Myron L. Wolbarsht. of the Duke University Eye Center, completed the attack on the theory of video display unit radiation emissions He said that in conducting measurements, he found background radiation levels often were greater than the radiation from the video display unit itself He added that a flourescent light emitted more ul traviolet radiation than a video display unit. The researchers did not dismiss other potential health hazards from video display units as completely as radiation hazards Most agreed, however, that these hazards were acute rather than chronic in nature. Edward J Rmalducci. of Georgia Institute of Technology, outlined visual problems such as fatigue, glare, color defec tiveness. and the effects of adaptation associated with video display unit use. Marvin J Dainoff. of the Motivation and Stress Research Section of NIOSH. reported on experimental and field in vestigations relating visual fatigue and other visual changes to video display unit work He suggested that poor contrast, glare, and insufficient work-rest breaks may contribute to worker complaints, but be concluded that causal linkages "still require substantiation." Other reported complaints included pafturaJ discomfort and muscular disorders Robert Arndt of the University of Wisconsin, attributed these problems to awkward or im proper postures, static loading of postural muscles for long periods, and repetitive motions leading to muscle fatigue and disorders involving tendons, muscles, joints, and nerves. Researchers speculated on several causes for these problems. Most agreed that the workplace was partially to blame for btalih complaints Michael J. Smith, chief of the Motivation and Sms Research Section of NIOSH. said there are good video display units on the market, and sound ergonomic principles for their use. that simply are not put into effect. "We can't always go back and try to beat up on the manufacturers." he added. Smith and others agreed, however, that job content may share the blame for causing worker health complaints "There sre s hell of s lot of complaints out there that we re not hearing" from typists, microfiche viewers, and other deficit workers. Smith said He blamed the repetitive nature of the work and the influence of the total computer system and ns requirements for high leveis of job stress and certain types of health complaints Smith announced that NIOSH plans to ask the National Academy of Sciences to review requiring vision examinations for all jobs requiring dose acuity work. NIOSH RocemmonOanone Smith also outlined general recommendations that NIOSH gave to the San Franciaco Newspaper Agency, based on a health hazard evaluation conducted there The recom mendations will be published in two months Smith esumaifd They include * Making workplaces as flexible as possible, wun ad justable chairs. kVboard height, screen height screen brightness, and conirasi. * Selling the distance between the video display unit and the operator between 450 and 500 millimeters or two-ttiirds of the accommodation range: Setting the viewing angle in the 10 to 20 percent range with the top of the screen no higher than operator rye level and the bottom of the screen no lower than 40 degrees beiow eye level; Setting the keyboard height between 740 and 790 millimeters at home row. Making keyboards detachable if possible: * Setting the illumination level between 500 and 700 lux: Controlling glare. Planning work-rest regimens with a IS-mimite break after two hnurs of continuous video display terminal work for operators under moderate visual demands, snd s 15minute break after one hour of continuous work for operators with high visual demands or repetitive work tasks: and Performing comprehensive preplacement visual ex aminations. with viewing requirements of the operator s job in mind Smith concluded that job content factors and video displav unit use contribute to the problems observed in video displayunit operators "m an interactive way." Review Commieeion CSAHRC REJECTS ECONOMIC INREA5ISILITY AS DEFENSE IN ASSESTOS VIOLATION CASE An employer may not defend against citations for violations of asbestos monitoring and medical examination standards on the ground that compliance is economically burdensome, the Occupational Safety and Health Review Commission ruled March 31 This decision, in Rgseorch-Cottrell. Inr . Hamon Coni, ing Tower Otrtston iNo H7S<i. affirmed an ad ministrative law judge's decision finding that (he employer violated the standards by failing to monitor a worksite and provide medical examinations for employees exposed to air borne concentrations of asbestos fibers.' This case arose after an inspection of the empiover s worksite in Russellville. Ark., where the firm was engaged in constructing cooling towers for a nuclear power plam The lowers consisted of concrete columns which were filied with asbestos sheets. As part of their duties employees drilled and cut the sheets prior to installing them in the columns After monitoring the employer's worksite for presence of airborne asbestos fibers, an industrial hygienist for the secretary of labor found that employee exposure to asbesms was 0 32 to 1.37 asbestos fibers, measuring greater than five microns in length, per cubic centimeter of air on an etghi hour time-weighted average basis Although exposure leveis did not exceed those limits set by the asbestos standard at 2f CFR 1910 10011bi. the evidence showed that the employer had failed to conduct its own monitoring of the worksite to determine whether employees were exposed to asbestos fibers or to give medical examinations to its employees. On the basis of this evidence, ao administrative law judge affirmed a citation issued against the empiover for violations of asbestos monitoring and medical examination standards 29CFR I9l0.l00lifitliand<j>m. Research-Cot- 4-IHI Ot CwflV*-#*'l t H*llll M BST-SI-SOOH ,1 i .1] '1 ; < r*! > i i i y I 4 l { i i i j i L:i< 1 < rTTef DEPARTMENT of health. EDUCATION, and welfare pue-ie wealth sen vice , centc* ana unease contaol- August 8, 1975 national ih'.titutc Ton oeruaaTioNAt SA>CTV ANO MCALtM So aiswta; lanc aoCkvillC. waarLANU >9<S2 Dear Colleague: This conaunieaeion is intended to alert you to recently gathered informa tion indicating a potential health hazard for persons exposed to asbestos during the servicing of motor vehicle brake and dutch assemblies. On July 21, 1975, the National Institite for Occupational Safety and Health convened a meeting of government and university scientists, industry representatives, and labor union officials to discuss the present stare of knowledge with respect to this problem. Data was presented by investigators from the Mount Siani School of Medicine in New York City indicating that workers engaged in the maintenance ar.d repair of automobile and truck brake linings are exposed to potentially hazardous levels of airborne asbestos dust. Spr<fic brake servicing operations studied included blov-cut of automobile drum brake assemblies, grinding of used truck brake linings, and bevelling of new truck brake linings. Average peak asbestos air concentra tions for these three activities based on personal samples taken within ten feet of the operator were, respectively, 10.5, 3.75, and 37.3 fibers (>5 microns in length) per ml. An analysis of samples of brake drum dust revealed that alnost all of the asbestoe fibers found were shorter than 0.4 microns in length. Previous studies of the extent of asbestos emissions from automobile brake lining veer shoved that only a very small fraction of the original asbestes content of the brake lining is found in brake drum dust (Ref. 1-3). I: was presided chat this is due to thermal degradation of the fibers during braking. The present findings indicate that enough asbestos Is preserved to product significant exposures during certain brake servicing procedures. The full extent of ssbescos-related disease in brake servicing personnel Is noe known at present because chls particular occupational group has not been studied systematically up to now. However, a review of the scientific literature on the association between asbestos exposure end mesothclisl turners cf the pleura and pcriter.cus has revealed at laast four eases of these rare tieors in persons who were employed in jobs Involving automobile brake servicing (Ref. 4-6). Page 2 j. for youv information and guidance, we are enclosing percincnc references, estimates of the population at risk, a NIOSH interia recomendation for brake and dutch servicing procedures, and a copy of the Department of Labor standard covering exposure to asbestos in ehe work place. The environmental studies of brake lining servicing operations outlined above together with observations of mesothclial tuaors in persons so employed affirms the necessity for instituting and maintaining recoeended control measures in this industry so chat the health hazards of asbestos are minimized. Enclosures Office of Occupational Health Surveillance and Biometries A... 4 REFERENCES' *4 1. lynch, J.R.: Brake Lining Decoaposition Product*. J Air Pollution Control Assoc, 18:824-26, 1968 2. Hiekish, D.E. and Knight, K.L.: Exposure to Asbestos During Brake Maintenance. Ann Occup Hyg, 13:17-21, 1970 -! 3. Jaeko, M.C. and DuChame, R.T.: Brake Eaisslons: Emission Measuresent* fros Brake -.nd Clutch Linings from Selected Sources. E?A Report 68-04-0020, 1973 .1 4. Nevhouse, M.L. and Thocpson, K.: Mesothelioaa of Pleura and Perltoneua Following Exposure to Asbestos in the London Area. Brit J Ind Med, 22:261-69, 1963 5. McDonald, A.D. ce al.: Epldeaiology of Prisary Malignant Mesothelial Tuaors in Canada. Cancer, 26:914-19, 1970 6. Greenberg, M. and Lloyd Davies, T.A.: Heaotheliooa Register 19671968. Brit J Ind. Med, 31:91-104, 1974 t J .4 4 J i H i ....----------------- X ESTE'-ATFS OF THE WORKFORCE POTENTIALLY EXPOSED TO ASBESTOS in the kamifactorino and servicing cf brake unincs and clutciss Auto Kechanlcs Carage Workers Manufacture (original and rebuilding) TOTAL 833,533 67,679 6,657 907,871 SOURCE: Adapted frca 1972 Census of Manufacturers, 1972 County Business Patterns, and Census of Population: 1970 Occupation by Industry (all are Department of Coserce, Census Bureau publications) depar.rc" nr ieal'i, educatit.:, 'md './Ei.FAr.n esc, :ncs;; Minutes of fieeusAtlonal Exposures Co Asbestos Dus t Proa Brahe Linings Maeting July 21, 1573 Attendee* See Attacked Proceed Ir.r ; Dr. John F. "inkles, Director of triCSil, vcleoaei the att.-.:ies. lie stated that the rwrrosrs of tlic neetinj vnre (1) to consider ->rulinin:ry data on asbestos exposure font brake linin' workers and (2) to iise-su a future course of action basud on this nreliair.arv inf or.: it ion. ./r. "inklca then turned the rxetin.g over to ir. Ir.'ins Sclikeff cl . lounc Sinai-for presentation of sane of his wort: on this probln. Sr. Sclikoff described the baekereund for our current concern. The health effects of asbestos are veil kn.o;.-.i. ilo-.-Tvcr, tlic kraltn h.a-ird associated vlth asbestos in brake linin'; until reecntl" nas react-'cl little attention. I: "as thought that tin Intense keac ger.rratui! -'rju braking nodifled the ishestns and that brake linin' ,,ust ejntai.iud Insignificant .mounts of asba'-tos fibera. hr. .incuse in Iv3 Ui.l describe asbestos-related health ` effects la the aa.iufatcuri-.; nf asbestos for brake linings but itrnrer.tiy tnia cause-1, lic.ls en-.cur-.. In 1573, a esae of ncsnckclioaa vat rtnorteu ir. a brake repair 'wrkco. This stimulated a re-c?:.tnln.-.tion of the problem. hr. Scliln:.* vlth Mr. Mayers of '.`AM, r. Cafalo of LAM und tic Fori Motor do:.;i.v.y a...' the grous at "t. Sinai initiated a study ts detonine if br-.kc iin.-.i.; workers ueru etnosed to significant levels of asbestos. Dr. Sellkoff introd-tend hanger uf At. Sina< vh.o rcvic-x' : eeroonition of brake lining* nr..' cku br.akd.v.r. orndneta thought tr wcc..;- fruv 'heat -/.v.-rate-.' luring hr .'.king. Previo is -.ft lie-: did t dorionstrutt: anbust's fibers l-.i tltd i.-.v'i.ita or -rnvalc-ec u ia:ie*.t. 1 'j the eurrwii: litmli'S it It. Sinai r, recent se.i.l ut c. Sin...' ill r.mstr'.ti-il typical '.krvs.'tilc ns'.-v . z<-i C< non?, vlth a of other fornr. af crystalline a :.i fibrous materials. lie i 1 :c.l i m the Ci--mesit Inn of brakelining; 3 J if for, far uuri'le, brake ii In tiie r.S. anil 'h*enc Kritaiuan-.l pro-met licre In rl.e . .S>. "iv .i.:v. underrone nanv ch.-inp-.-s over the your.-;. TV. *. is particular!." lap-art..,.. alneo Tor.i-nc d.ac.a uhnv that d b. of t:i<: no* ear v.iv'-.rl i.-J itaj.- ur '. these lienor is. Mirther raaeurch is uc'de.l t.> uliarastnr ir.c tm- ,sl>- :-a 2 concent of past and eresent dime cynosures. It should dc rccrgr.iscd .also that the health effects of ocher materials in hral.c dust .save nut been studied. nr. r.nhl fron 'It. Stnat reported on studies ~i asbestos dust expo sure-in automobile repair shops in Yor'.: Citv. Pea!: ur.nosurc*. ire". 5-3 minutes duration uere measured. Fiber counts, using the Oulu', method, 'ere from * to 3h/nl at 3-5 feet" from braise drums cleaned with eoaorcssed air. At 5-lb feet, cnur.tn ranged from 2 to 4 rtl; at 1 >--20 feet "1.4 to 4.3/nl. brums elesned with a brush generated less airborne asbestos, 1.3-3.6 fibcrs/ml in the operator:; breathinn iw>ne. Eic.it/ to 997. of the fibers as observed by electron -icroscanv veto ieon tnan ;.4 cierons in length, indicating a ouch higher exposure to asbestos fibers than indicated by ootical microscopy. Worhers cn-iri-J in criu.ing oneracions to re.nev brake linings vers etnased to 2-7 eiticnllv visible fibers/nl. Those bevelling linings had uigh exposures ranging fro- .31- 72 fibers/ml. dr. George Wright pointed out that earlier studiwi s.iwe. that 1 to 33 of brake dust is fibrous ajbustos. hr. loriner of 'It. Sinai reported on medical examination of '3 brake reoair ''orker.a I'ith 1">-41 years of exposers. A substantial number were reported to have M-r*y ar.J ventilater' function ibunratlitlua. "urther studies need ts be done in this area before wv csnennluuia..r .-a health" uffeets ear. bo cr.rvti. Kcevar, it ss out t.ut n: Iciir four cases of mesothelioma have been ranort*1 latiena'.ly amor.; act-- nobile repair "orders and this ,ends urgency ta cite problen. Dr. Fin-lea ashed for cements and reeomerulations for addressiu^ the problcB. Mr. Meyers suggested that several Practical control censures arc feasible nov. Indeed, those censures have been instituted in scvirel shoos. his union *1 freed its menders via its ne'-slctt^r and .evnlopc. posters to alert vorhere to the problem. Mr. Mevcrs mphas t-.'t tuc (yioloyert with .dim he worhivd were must corner.'. tlvL-. :vapl."'e:s tuv. encouraged to use vacuum cleaning of bribe drums .ri.!, where .;rei.-.s.,r r, masks to reduce tmosurn. His union has calc arranjenmes for Ci ntMv.i.d nodical evaluation of its nerburs. He .mohnsicccl thr i.i-orca.eu uf union representatives Iwvin;'. ucecar. to workplaces for uhs-rrvjttu.'. ef sanitary ornctlces. 1'r. Ccorrc './right, an industrial consultaat, vr-hunircl f.acturcrn have .a n.T.rnn:-.il>i*i:v to .tic. rt-.in 'd::: .ina-onc .v.-.ie.i<. > pruducts after being soil :a other!;, 'iai.a pro1!."; rv-rdiffi cult -roMca fpr t'u- manufacturer a:.l for t ;wir .ulua trial cu;t ' Mr. '..'rJrht atrcnPo.l belief that Che Ash-nuns ln.hr:trv '.wild c:u : cvwrv oorniblo '.My. r. .'right van not t'tiiiv *ur> ri-.c'. !;* r u; ri'.ur counts rvourtc.l and enurca-so.! cho bvILuf t'nv one might suLSk pc it'.y encounter the full nvctrun of .vibi-otns-r.. litcd din "ic ri.i.cm. Dr. l/rir.lit e::prc*.u*i! cure cm that cun.! it.um: ruy.iil be iie 3 ecnosurcs higher .non? sone smaller bunlncs-.ej. hr. '.'rJJU't caucij.;ci thac the inflticr.ee of fiber sire should be considered anil C.iie any cttrapolation to the General -mpul.p cion be irade t'ith caution. He ur;c. that any sub.eeraenc lover, citation.-. utilize the UICC alns^ifiention anti Che inclusion of negative controls. Ur. '.Jricie cautioned acaiurt cvurincernreting the occurrence of four ncsockcliona eases. Vs. Saruels of XVT> urred that 'HOC'!: -- Notify die Department of Labor about this problem; 'iake ninutes ef this iscccinp available to nublic along vlth a suitable preen release; -- Notify other involved unienj; -- Institute an appropriate national samlin.: pro-.r.n; -- Institute a program of surveillance and intervention. Other unions Involved include: -- United .'.uto `.iorhera -- Teamsters -- A:iriean Federation of Cavernncnc atiolcvces -- Allied Industrial Uorkers -- Laborers International -- International tssociacion of !!aehini<ts -- American Postal '..'orkers Union -- United lubber l.'orkcrs -- .'ajalpanatcd Transit talon -- Transport '..'orhurs Union of Ar.cries -- initod Tranrsnnrt.-.cion Union "s. Spruills i>f XU'i irp.iu! that tvf-*w it bo inform.- i of >. : l *t ,, e.vrilv 3">nlie.*.hlo eor.tro] nop.suri l. Ur. ..cy< rn *u ,*:r.. ,i.;v ii ;.c ..n control technology he built ij-ou Ch'.ir au'-ontos snfetv bullet!. ''r. Anprlo Uef.ilo -C lA't 1 acn-sr.c.! the ru v ! tn in."or- h'iict.;.: locals und union numbers in a:, er.ioriy i.m'ii.ui. !r. Cefn'..' to-.; c -4, the needed research "rogran should he planned .tnJ. funded. Kc offered his assistance in obtaining any needed support lor c.iis progrer. Dr. Mar.euso of the I'nivcrsdtv of Pitfsburgh a: the reoues: of t.je Iatcrnatlon.nl Association of hichiniats eendueetd a pilot .it;Hy of Jean records and identified in U7j a neiochelieru case (prove;: by ajcrr.a..-) of a garage mechanic and another ea.se of pleural nrs*taelleva in a nillright vho van bloving out asho.ntjs, frietion-tync cl'i:::ic. vith eot'ors-ssed air at a paper c-rgoany. Dr. ^iar.cuso felt the nature jf tie death records was such that other canas of r.enot'iciiur.a nay c:;iat but are unrecognised. i!c soohe of the need to use this onorri.ur.ity tv develop an affective industrial ccdieal survaillar.ee ayatcr.. Herb ?!orthroo of Ford asked than ar.y alert bulletin place this problca in perspoctiva -- pointing out other reeogniitd vovosurxs ta asbestos, John rieoent of !1FSC1 "resented srclirinary data iron n :n0S":l .-st-ik- shoving nea'.: exposures of u" t" 5 fibcrs/r.l during bra'.:e -.run bl-vi-g. He elso shoved peak lead levels cf .unoroxinacely i.5 rg/llj durin; bloving o'-orntions. 'ilOSH cleetrennieroseonic studies of broke dm dust elso sho*-ed .1 r.rcdor.ininee r sa.all csbo.-.trs fibers wi: . r-s: fibers being less than 1 r.ieroaoter in lur.gth. `t a Plant ren.s-.-i.:; lir.r.d br.'b.'S shoes, exposures of !' fibers/:.-.! (during rr'nhtnr) ar.o pc \'.j of un to n fiocrs/ul during enotying of a dru-i cnataiai:. ; cld lir.ir.gr verc observed. i)r. h'eaver of .`.PI offered to eocsvur.icate srith gasolir.a strtiua.s and he supported further studies of the probler. and en-haeiaeu c.i: .iced ce use appropriate controls of "ICC file reading Cuchr.i'-uae. Ei Alpauph of International rarvester urged "reparation rf i Joint release. v iul Toth of ford offered to he.'.n vith suggestions on c.;n:r;il technology end in disseminating infamatio.: fro,.i k'l'dSi. ,\i t.'.i'i :Mt;.i- tu appropriate Ford docor Coooany dealer relations persona,.!, John iior.an of X?A pointed wc that disc brake*, r'lcvsc a-Tt asbsstco into the general environment thaa shoe brake.-,. Kc atitu.i tha. the HPA cnorassvav roadside stud v eoulu .'.'ok .-.t .asbestos iertis a'.o.ip a gradient ava" frra the .srpronsvay. Dr. Sclikotf '-oint.-: ..;! braking. Itself, nav bo important a:u: that roadside sti.diu.-. sh .-..Id consider tho effect of braking. hr, '.tneu io - nr. ashed tr> co***.ont on th.- n.'rh'd he ,1th st-idie*.. he su.gp.es t.ul an cviiieniolory studv of t ie n.irt .ilit ig'-evieneu of i au.-.>r: of unionised 'or'ier*. a:irt their fanUir-. !!c ,;i>. asici'd lr;-- fvr care in the ever `nont.'l design. ihonr.it such a sr.i!-: -M/iid . >' for other t-nircr* i:n! Hieut'atiPn.i! rv.nir.atorv ids. o *" . .l ,nbr*;t.>:'.-r'0ati-d 'ir.er.'.evs. 1 5 It '>83 er;hasired 'Jut wethers were ctnosc-: to "ucnls, piusike dusts (bod/ shonj), .solvents and cnuie gnse' like carbon :.-.oio::i.!c. i.r. 'I.nneu.so rec-omcnd*'! clinical studies in eh1; sane pneu latino. o: .other.. Hr esreeicily rapuc-sted evaluation of so-enllcd "nuisance d'.i3t." 'Mich he* elalns r.av bo. more harnful than now realized. he uaoh.;si%ud ne-iJ tu look at ..orhers ''an left the industry as well a3 those '.Hio are ..till oployed. - !*r. Toth stressed che need to ascertain the role >( tobacco aneki.ij in any studies. Others agreed with hir.. It. 'anenso cooh excepcien tj the undue emphasis on the sno'tlng asoceta, to the. exclusion of nro-ur recognition of the magnitude of inherent health risks due to cue chcr.icals in dusts of the working environne.it. Dr. Selikoff suggested seven areas for urgent study: -- Analysis of brake materials utilized since 1?*') uui;.g literature survey ar.J laboratory analysis (EPA/hlbSh). -- Broad based national industrial hygiene survey c.j assess exposures for various oeeunational tasks OUUSii/ . -- Eridcriolopie studies of r.ort'l it-' e::"erienec jf cn*-oscworkers from snvcrsl sourtea (HI05"). he suggests t.;i: rceuivc t!ic highest priority. -- further clinical studies of i,!!D0 'orkers ir.eluuiu -. suitable controls (HXDSk). -- Autorsy surve" of lung an! antns burden of e:nosed workern in auto naintenaneu industry (;:i<'SII). -- Industrial hygiene measures to betLnr control exposure (Joint effort of unions, industry and hIDSh). -- Education of workers to iiarard and to use control v.ucv.iru.-. (dol/::icsk) . Dr. Selikoff suggested that chore be no delay l:i gecti'.v chi* nro.u-.i-. underlay. Ur. Joe 'Jhgonor of :rinsH nuncrally awoort.'d che .'ipeus'i.i-t ...m u.i program. He civik.nsirc.'. >.niv! for careful ch.ir.hct.tr 1 * it ion .nnouiu . u to agents otl'.rr than usKiotnu and the- need lo nsuire ch t: i: A L. .. research funds are used in answer somv of our rua)nr rcia.ilr.iiv uci. i/. : mier.tioiv* ni.out .he effects .f u:f'::;ir.r to rr Intivc lv lew !cv'u of short a.uUcscw:: fil-crs. '.'Illi.ci Best of hhl offi-w'. his u . ; l ; c Vi.. u. askrd whether or r.ot a enr.c-euntrol study ri'vit I u of ro-'r iu. Ip. Edvard Mpau,*H Edvard J. Caier Occo A. Scsscy, Willia:i 3est, ''..D. Hester Blejcr, w.O. Kenneth IriJbord, 'l4i. Jac!: Sutler, Angelo Ccfalo John `I. Ocscae John F. "inklea, 0. Arthur Longer, K.D. Williar. Loriner, '.'.3. Thosaa r. hancuio, "..3. Sanuel .ieyer* John derail Herb Kerthron, "..3. Arthur r.ohl, :;.D. Sheldon Sasucls Irving J. Selihsff, Paul L. Toth Jcsenh Wagoner, S.J, Hyg rleill Weaver, :!.L`. Ccorge '.'right, AT?r:r'r".s AifilinCio-' International Harvester Conn.-j.-.y :;iosu lit. Sinai National Cancer In.ititutu HI OSH KIOSK kiosk International .'jaaociatian oi .la KIOSH. NI0S11 Ht. Sinai ::t. Sinai Hnivcra.'tv of Pitt-!.ur,*h Local 13.., IX! EPA ford Itotor Connanv Ht. Sin ii H'D/ATL-Cio lie. Sinai Pori' :ioter Jar.nany KIOSH Anerica-i Petrlc-xa Inntituiu Jolina-'.lar.villa 1910 .1001 ASBESTOS A. Oefinitions 1. Asbestos - includes.chrysotile, amosite, crocidolite, . tremolite, anthophyllite, actinolite. 2. Asbestos Fibers - Longer than 5 p B. Permissible Exposure to Airborne Concentrations 1. July 7, 1372 - 5 fibers/cc 8 hour TWA 2. July 1, 1976 - 2 fibers/ec 8 hour TWA 3. Ceiling Concentration - 10 fibers/cc C. Methods of Compliance 1. Engineering Methods a. Engineering Controls - isolation, enclosure, exhaust ventilation, dust collection. b. Local Exhaust Ventilation - ANSI Z9.2-1971 c. Particular Tools - All hand-operated and poweroperated tools shall be provided with local exhaust ventilation systems. 2. Work Practices a. Wet Methods - use when feasible b. Particular Products and Operations - No asbestos cement, mortar, etc., shall be removed from containers without being either wetted, enclosed or ventilated to prevent release of fibers above standards. c. Spraying, Demolition or Removal - Employees ; involved m these processes shall be provided with respiratory equipment and with special clothing. D. Personal Protective Equipment 1. Compliance may not be achieved by the use of respirators or shift rotation of employees, except: (Personal Protec Equipment Contd.) Page 2 a. During time period installing engineering controls and to institute the work practices required. b. Where work practices are not technically feasible or feasible to an extent insufficient to reduce the airborne concentration below the limits. c. In emergencies. d. Where the above three are allowed person rotation shall be used before respirators. 2. Respirators shall be NIOSH/MESA Approved. a. Air purifying respirators - use when levels are no more than 10 times limits. b. Powered air purifying respirators times limits. 10 times 100 c. Type C supplied-air respirators - 100 times limits d. Establishment of a respirator program 1. ANSI 288.2-1969 1910.134 2. Where to get ANSI 3. No assignment if physician determines employee cannot function normally wearing a respirator or health impaired must rotate him to another job. 3. Special Clothing - shall provide and require use of special clothing (coveralls, head coverings, gloves and foot coverings) to employee which exceed ceiling level. 4. Change Rooms a. At any fixed place of employment exposed in excess of limits, the employer shall provide change rooms for employees working regularly at the place. b. Clothes Lockers - shall provide two seperate lockers or containers for each employee seperated to prevent contamination of work and street clothes. c. Laundering 1. Shall be done so as to prevent release of fibers in excess of limits. 2. Shall inform the laundress of asbestos presence and limits. (Personal Prctec e Equipment Ccr.td.) ? age 3 3. Contaminated clothes transported in sealed bags or containers and labeled. E. .Method of Measurement - All determinations shall be made by the membrane filter method at 40C-450X (magnification) * (4 millimeter objective) with phase contrast illumination. F. Monitoring 1. Initial Determinations - Every employer shall cause every place of employment where asbestos fibers are released to be monitored in such a way to determine whether every employee's exposure is below the limits. 2. Personal Monitoring a. Breathing zone samples on membrane filters of 0.8 u mounted in an open face filter holder. Determine 8 hour TWA and ceiling values. b. Sampling frequency and patterns - In ho case shall sampling be done at intervals greater than 6 months for employees whose exposure may reasonably be foreseen to exceed the limits. 3. Environmental Monitoring a. Areas representing exposure which may reach employees. b. 6 months limits 4. Employee Observation of Monitoring - shall be allowed to observe monitoring and records. G. Caution Signs and Labels 1. Caution Signs a. Posting - Provided and displayed in area where concentration may be in excess of limits. Must give employee time to protect himself. Signs shall be posted at all approaches to areas containing excessive exposure. b. Sign Specifications - Shall conform to the require ments of 20" x 14" vertical format signs 1910.145(d)(4) 2. Caution Labels a. Labeling - Caution labels shall be affixed to all raw materials, wastes, etc., containing asbestos fibers not bonded. (Caution Signs a ,abels Cor.td.) Page 4 b. Label Specifications. H. Housekeeping 1. Cleaning - All external surfaces shall be maintained ' free of accumulations of asbestos fibers. 2. Waste Disposal - Asbestos waste consigned for disposal which may produce through handling concentrations of asbestos fibers in excess of exposure limits, shall be collected and disposed of in sealed impermeable bags or containers. I. Recordkeeping 1. Exposure Records - Every employer shall maintain records of monitoring for at least 3 years. Available to OSHA, NIOSH. 2. Employee Access - Employee shall have reasonable access to records. 3. Employee notification - any employee found to have been exposed at any time to asbestos above the limits shall be notified in writing of the exposure not later than 5 days of the finding. Also, notified of the corrective action being taken. J. Medical Examinations 1. General - Employer shall provide medical examinations relative to exposure to asbestos. 2. Preplacement - Employer shall provide to each of his employees within 30 days following his first employment in an occupation exposed to airborne concentrations of asbestos fibers, a comprehensive medieal examination which shall include, as a minimum, a chest roentgenogram (post-ant 14" x 17"), a history of respiratory diseases, and pulmonary function tests to include force vital capacity and forced expiratory volume at 1 sec. 3. Annual Examinations - Annually, every employer shall provide or make available comprehensive medical , examinations to each of his employees engaged .in occupations exposed to airborne concentrations of asbestos fibers. Shall include the minimum of a chest roentgenogram (14* x 17") , history of respiratory diseases and pulmonary function tests to include force vital capacity and forced expiratory volume at 1 sec. (Medical Examine .s Contd.) Page 5 4. Termination of Employment - within 30 days before or after termination of employment shall have the same minimum tests as above. 5. Recent Examinations - No medical exam is required of any employee if adequate records show that the employee has been examined within the past 1-year period. . Medical Records a. Maintenance - maintain- complete and accurate records of all medical examinations. Records shall be retained by employers for at least 20 years. b. Access - records shall be made available to OSHA and NIOSH. f I September 27, 1976 Kr. terry V.Piite A5EPcl.it>! Assistant Director regional r'rr:;7;~-- Oc cup .--Lionel Safety 6 Health .Mclciutration 2U0 Constitution Avenue, Washington 1'C 20010 Dear J.'r. White: I vo'.ild very ouch appreciate so official interpretation of the i olio:; in ; questions: i. At v-.at point is coiled coci coring .required ..her. i/orl-ir cabas cos 7 \ \ 2. Does ,.ir sampling have to be dot:* or is the re:: .'.ice thee the crployc-e is uorhiag vita asbestos sufficient? 3. Would this apply to an employee vho is worHiag vith os esses:os glove around a hoc.furnace? 4. When a eor.pany stops using asbestos end begins using fiberglass, ere they required to continue radical conitnrir.r. for the a.-besec; exposure? Dees the conpar.y have to shou that there Is ns a;.; sstaa residual fron previous eperetions? 1'oui erpediect interpretation vlll be greatly appreciated. Sincerely . in- 3~>7- c>' ` Roger D. Tenaerslcy *- it-n-7i> av,r.< , p'.:. f.tv, X. . o- f (*, J.t. ) . '/.' " + . % ;* * . -'* " > . I..' t*'