Document VGaEQdXMZqjapw8aOyra9VbbN

uji rennsyivania Avenue, N.W. Washington, D C. 20004 202-737-6330 S T 0 0 7 1211 Organization Resources Counselors, Inc July 22, 1987 Memorandum To: ORC Occupational Safety and Health Group ORC Occupational Safety and Health Physicians Group ORC Occupational Safety and Health Lawyers Group ORC Asbestos Data Collection Task Force From: Darrell K. Mattheis Subject: Participation In ORC Asbestos Data Collection Project. BACKGROUND Responding to the publication by OSHA of its two new Asbestos Standards, the ORC Asbestos Task Force requested in January of 1987, that ORC fora a Task Force to facilitate the collection of high quality airborne asbestos monitoring data. This data would establish a solid, factual, basis for the prediction of probable concentrations of airborne asbestos fibers generated by particular kinds of jobs, both for individual companies and across industries. "Objective data" meeting the requirements of OSHA, could then be used, legally, to reduce the amount of monitoring required to be in compliance with OSHA requirements. THE PROBLEM However, OSHA has ruled that records of airborne asbestos concen trations generated by particular operations, compiled prior to the publication of the new OSHA Asbestos Standard on June 20, 1986, do not meet the criteria for "objective data". OSHA made this ruling because they were not collected and analyzed using the new NIOSH (7400) method, and thus would not be comparable to newer data. TASK FORCE GOALS It is the intention of the Task Force to collect high quality data on the actual concentrations of airborne asbestos fibers generated by particular jobs. This data base, meeting OSHA "objective data" requirements, and crossing many industries, may then be used to reasonably evaluate the potential concentration of asbestos fibers a given task may generate. 377835 ST007I 2 I 8 -2- THE NEED At present there are approximately 12 ORC members committed to participate in this project. For the greatest credibility and impact the Task Force would like to have at least 20 companies participating. We urge you to read the attached detailed report on the project and consider the benefits of participating. MORE INFORMATION We have attached here for your interest detailed descriptions of every phase of the project, including the sampling data and background sheets. If you have questions this material cannot answer please give us a calll HOW TO JOIN THE PROJECT All that is necessary is a letter to ORC indicating that your company wants to participate in the Asbestos Data Collection Project. COSTS The costs are $1600.00 per participating company for the first year This covers all costs of the project. ORC receives no money from this project. STARTING DATE FOR THE ASBESTOS DATA COLLECTION PROJECT The project will begin August 24, 1987 and continue to the end of August 1988. If there is enough interest and additional companies wanted to participate, it could be extended for another year. We need your participation for a statistically significant and credible project and encourage you to join the project. If you should have any questions, give me a call at 202-737-6330. 377836 ST007I2I9 INTRODUCTION TO THE ORC ASBESTOS DATA COLLECTION PROJECT PURPOSE To build a data base on the levels of airborne asbestos fibers generated during the completion of a variety of routine jobs in the chemical, petrochemical, telecommunications, manufacturing, and utility industries. HOW THE PROJECT WILL WORK Industrial hygiene monitoring data, and background information on each job monitored (where asbestos is present) will be collected on a special form and sent to ORC. ORC will remove company identification, and transmit the forms to a contractor who will enter the data into the data base. The contractor will perform statistical calculations, analyze the data, and make available reports for participating members. INTENDED USE This data base is intended to allow the participating companies to meet the requirements of the Occupational Safety and Health Administration for "objective data". The source of the data will be kept confidential with only ORC retaining knowledge of it. METHODS The intent is to monitor a variety of separate jobs, to establish a TWA exposure for each job, and record a thorough description of the kind of operation performed. We anticipate the participation of companies from the chemical, petrochemical, manufacturing, telecommunications and utilities industries. For the purposes of this study we are less concerned with the overall exposure of the individual (8 hour TWA) than we are with the actual fiber concen trations generated by each specific task. THE BENEFITS * This "objective data" should provide participants with a valid data base upon which to base a decision not to monitor each individual on a small job involving asbestos, so long as standard company procedures, which have been documented in this study, are followed. 377837 _a 2- - * Each company participating in the study can benefit from information on the average concentrations of asbestos fibers generated by particular kinds of jobs, accomplished by different companies, in a variety of industries. The key is that all the participating companies have agreed, before starting the project, to record data using the same forms, and according to the same rul Companies not part of the study, can only use the data in a general way, because their own data would not have been collected following the rules of the study. * In the telecommunications industry this data base can help document the kinds of exposures that can be expected in routine telephone and cable installation jobs where asbestos is present. Protective measures appropriate to the known hazard can then be ^ put in place to meet the requirements of the OSHA standard, and _ adequately protect workers. > ro TIME FRAME FOR THE PROJECT PO CD The project will begin on August 24, 1987 and continue to the end of August 1988. If there is interest and additional companies want to participate, it could be extended for another year. COSTS OF THE PROJECT The minimum number of participating companies necessary for the project to go forward is ten, and the minimum costs would be $1600. per company. This would cover the project up to 5000 samples entered into the data base. For a more detailed breakdown on costs see the costs sheet included here. HIGH CREDIBILITY NECESSARY The requirements that OSHA is establishing for the collection of this "historical objective data" are strict. Therefore, for the data base to be credible and thus usable, all data must be collecte in strict accordance with the rules of the study. If we accurately collect monitoring data relating to levels of airborne asbestos fibers generated during certain operations, it can be used with confidence to meet our obligations under the OSHA Asbestos Standards. If we do not make every effort to be as accurate as possible in this study, we will be wasting both our money and our time. 377338 ST007I 22 I -3- REQUIREHENTS OP THE STUDY The following are the general requirements that all participants in the study have been asked to meet in order to insure the smooth functioning and high quality of the study: 1. This study will require that participating companies monitor (on a random basis) a significant number (to be determined internally) of their employees engaged in activities where they may potentially be exposed to airborne asbestos fibers. It is important that everything possible be done to avoid selection bias in the study. One way that a random selection could be achieved, would be to record for the study, all jobs with asbestos exposure that occurred during a pre-set time period. ORC believes that this approach affords the most expedient and effective means of achieving the randomness necessary to give the study a high level of credibility. 2. Information will be collected for each operation monitored, recorded on the ORC forms, and send to ORC in a timely fashion. 3. The data base development, data entry, and analysis of results will be done by a contractor, selected by ORC and approved by the Task Force, at a price agreed upon by the Task Force. 5. The cost of the study will be divided equally among those participating in the study. 6. Each participating company will receive a block of numbers that are reserved for its use. These numbers will be used sequen tially to identify the sampling data sheets. 7. Each sheet will contain ACM exposure data for one person performing one task. 8. For each job an actual TWA and 8 hour TWA will be calculated. 9. All participants will follow the relevant requirements of the OSHA Construction Asbestos Standard (1926) or the General Industry Asbestos Standard, 1910.1001. 10. All participants agree that sampling data will be for those doing "hands-on" work, not supervisors or observers. 377839 -4- 11. All participants agree that all analytical work done for the purposes of this study will be performed by laboratories certified under the existing Proficiency Analytical Testing (PAT), or the American Industrial Hygiene Association (AIHA) Asbestos Accreditat. Program. 12. Where possible, the data collection forms .should be filled out by industrial hygienists using their organizations monitoring data forms. 13. The sampling data forms will be signed by the person filling them out. The company name and address and a phone number for the person signing the sheet should be included. All company and personal identification will be removed from sheets prior to their transmittal to the contractor. 14. Where reasonable, a certain amount of third party, (contrac tor/consultant) monitoring should done as part of the study and identified as such on the data sheet. 15. Each participating company should submit once, a separate comt cover sheet to ORC. This sheet will include overall information about the percent of the potentially exposed employee population that was monitored, the total number of employees monitored, how jobs entered into the study were selected, and the total number of employees in the corporation. This sheet will remain with ORC. 16. The company cover sheet should discuss how jobs enter the system, and how the particular job site and individual(s) who do the work are chosen. This needs to be done to document the method used internally to obtain a representative selection of samples. 17. Detailed data from this study will be available only to those organizations that participated in the study. 18. Companies not having participated in the study initially, but wishing to have access to detailed data from the study after it is completed, must agree to do a certain minimum amount of sampling using the agreed upon task force protocol and data collection forms, the results to be entered into the data base. 19. Once the information on the sampling data sheets has been entered into the data base, a summary of the compiled data will be provided to participating companies. Participants will have access to the original data, except for company names, through ORC. 20. The final results of the study will be written up and, upon review and majority approval of the task force, they will be submitted for publication to the AIHA Journal. 377840 ST007I222 ST007I223 Sampling Data Sheets Two sets of sampling data sheets will be used; one intended for use in "small jobs" as defined by OSHA, and the other for primary removal, demolition and renovation. Small jobs would include a variety of work in all industries represented in the study, where the removal of asbestos was incidental to the accomplishment of the job. Large jobs would include those where asbestos is being removed from buildings, where asbestos containing pipe insulation is be removed and will be replaced with other insulation and other operations where the removal of asbestos is the main purpose of the job. Each set of sampling data sheets will have three pages of questions designed to collect background data, one air sampling data sheet to record the actual monitoring data, and five pages of instructions related to filling out the sampling data sheets. 377841 <lZZI LOOIS Cost Estimates for Data Collection and Analysis for Asbestos Proj set: (* Based on 5,000 samples) Data Entry Low estimate of entry time; 10 min. Per sheet cost: Total cost: $ 3.33 X 5.000.00 $16,650.00 High estimate of entry time; 12 min. Per sheet cost: Total cost: 4.00 x 5.000.00 $20,000.00 Data Management Logging: Data Quality Audits: 5% of recorded data 1,000.00 1,500.00 Programming** 2,000.00 Program Management Ad Hoc Reports: 2,000.00 Estimated total for 5,000 sheets: at 10 minute entry time: at 12 minute entry time: $23,150.00 $26,500.00 ** fixed cost i.e., all other costs will vary proportionally with the number of samples entered. 377842 ASBESTOS SAMPLING DAJA SHEET Small Jobs ORC Asbestos Data Collection Project Please Use Red Ink to Complete the Form 1. SHEET NUMBER 2. TASK (REMOVAL OF ACM IS NOT PRIMARY GOAL) a. TASK DESCRIPTION (CHECK ONE PER SAMPLING ACTIVITY) Open ceiling tiles Remove cable cover Cable maintenance Splicing cable Pulling cable Task clean-up Equipment installation Equipment removal Brake work Clutch work Gasket work Boiler maintenance Pipe maintenance Valve maintenance Other equipment maintenance Shipwork ___________ Other_____________________ b. ACM ACTIVITY RESULTING FROM TASK (CHECK ALL THAT APPLY) Wetting Removal Bagging Transportation Drilling/cutting/grinding Incidental disturbing Other_____________________ None c . ACM FORM (CHECK ALL THAT APPLY) Sprayed on insulation Troweled on insulation Equipment insulation Boiler insulation Pipe insulation (g.t. 12" diameter) Pipe insulation (l.t. 12" diameter) Pipe fittings Transite Pipe Floor tiles Ceiling tiles Roofing Transite Board Asbestos cement ACM fabricated items Other d. ACM LOCATION (CHECK ALL THAT APPLY) (Telecom/Utility Specific) Above hung ceiling Beams/columns Crawl space Tunnel Manhole Cable vaults Piping Other e. LOCATION OF JOB WITH RESPECT TO ACM (Telecom/Utility Specific) Adjacent to On Through Other___________________ ST007 I 225 377843 SHEET NUMBER ORC Asbestos Data Collection Project f. DISTANCE TO ACM (Telecom/Utility Specific) <1 ft. 1-3 ft. 3-5 ft. 5-10 ft. 10-20 ft. >20 ft. 3. TYPE OF ASBESTOS (INDICATE % IF KNOWN) _____ % amosite _____ % chrysotile _____ % crocidolite Unknown 4. ACM CONDITION Loose/friable Hardened/non-friable Encapsulated 5. ACM DISTURBED Yes No 6. ESTIMATED AMOUNT OF ACM REMOVED square feet cubic feet linear feet pipe diameter unknown none 7. OTHER FIBROUS MATERIALS PRESENT . Yes No Unknown 8. PHYSICAL CONDITIONS a. indoor Outdoor b. Elevated Ground level Below ground c. Temp, of Equipment (if applicable) approximately ambient above ambient below ambient d. Air Temperature (when task begun) >32 F <32F Air Temperature (when task completed) >32 F <32F e. Wind speed (if applicable) mph 9. STRUCTURE OWNERSHIP Company Owned Leased Customer Premise ST 0071226 377844 ORC Asbestos Data Collection Project SHEET NUMBER 10. STRUCTURE (COMPLETE EITHER A OR B) a. Type of Building (CHECK ONE) School Hospital Office Telecom Central Office Warehouse Factory Garage Residential b. Structure If other than building (specify, ex. tower, boiler, etc.) 11. CONTROL METHODS (CHECK ALL THAT APPLY) Enclosure (without negative pressure) Enclosure (with negative pressure) Power tool with HEPA exhaust ventilation Local exhaust ventilation with fiber capture Wetting agent Glove bag HEPA vac Wet wipe Alternate route (telecom/utility) Removal of entire structure Mini Enclosure Other None 12. SAMPLING/ANALYTICAL METHOD Appendix A OSHA Standard Appendix A OSHA Standard; (37 mm cassette) Confirmatory Analysis (by SEM, TEM, XRD, PLM) Other 13. SAMPLING COMPLETED BY In-house Contractor Third-party contractor 14. PRIOR KNOWLEDGE OF PRESENCE OF ACM? Yes No Unknown 15. REMARKS ST007I 227 377845 AIR SAMPLING DATA ORC Asbestos Data Collection Project GO SHEET NUMBER____________ 1. Cassette#: *____________________ --ro r\j co (One worker only; One task only) * If more than one cassette Is used for the same task number each separately but combine the data for the questions b 2. Date of Sample:// (month) (day) (year) 3. Sample duration: (minutes) 4. Fiber Concentration: (f/cc) 5. Fiber Count: (f/100 fields) (if available) 6. Actual TWA Exposure:______________' 7. 8 hour TWA Exposure: 8. Pump flow rate: (Itr/min) Pre-samplePost-sample Date Checked Pre:/L________________ (month) (day) (year) Post:// (month) (day) (year) 9. Pump Serial Number 10. Worker ID (if applicable): 11. Upset conditions Yes No Comments (spills, unplanned events, etc.) Signature/title of person filling out form Print name in full:____ Company name (print) City 377846 Phone No. State ST0 0 1 1229 INSTRUCTIONS FOR FILLING OUT ASBESTOS SAMPLING DATA SHEET FOR SMALL JOBS 1. Sheet Number The sheet number will be preassigned. 2. Task The Asbestos Sampling Data Sheet is to be completed only for jobs in which removal of asbestos containing material (ACM) is not the primary goal. a. Task Description What is the nature of the actual work being performed? Check the one entry which best describes the task. b. ACM Activity Resulting from Task What was done in regard to actually working with or handling the acm: c. ACM Form What is the form of the ACM encountered on the task? Check all that apply. Questions 2(d), 2(e) and 2(f) are to be completed only by tele communications and utility industry employees. d. ACM Location Where is the specific location of the ACM encountered on the task? Check all that apply. e. Location of Job with Respect to ACM Where, in relation to the ACM, is the task being performed? f. Distance to ACM What is the distance between the site of the task and the ACM. If the distance varies, indicate the average distance. 3. Type of Asbestos (Indicate % if known) What type of asbestos is present - amosite, crocidolite, chrysotile, unknown? Check all that apply and, if possible, indicate the percentage of amosite, crocidolite, and/or chrysotile present in the ACM. 377847 ST007 I23U 2- - 4. ACM Condition Is the material being removed loose, crumbly, - does it flake off, when worked with; is it hard to the touch; or has it beer encapsulated with another material? Check the appropriate box. 5. ACM Disturbed? Was the ACM disturbed during the task. Check the appropriate box 6. Amount of Asbestos Removed During Sample How much asbestos was removed if any? Estimate in lengths of pipe removed, square feet of boiler insulation, or tiles etc. Fill in the appropriate amount. 7. Other Fibrous Materials Present Are fibrous materials other than asbestos present? Check the appropriate box. 8. Physical Conditions a. Location Is the task being performed indoors or outdoors? Check the appropriate box. b. Elevation Is the task being performed at ground level, above ground level or below ground? Check the appropriate box. c. Temperature of Eouipment If the task involves working on equipment that has ACM content, indicate the temperature of the equipment. d. Air Temperature Indicate whether the temperature is above or below freezing when the task is started and whether it is above or below freezing when the task is completed Check the appropriate box. 377848 ST007 I 23 1 -3- 9. Structure Ownership Is the task being performed on a company owned premise, company leased premise, or customer owned premise? This question addresses premise ownership only. Ownership of the ACM equipment or materials being worked on (i.e. phone company cables etc.) is not the focus of this question. Check the appropriate box. 10. Structure Complete only section a) - type of building or section b) type of structure if other than a building. Do not complete both sections. a. Type of Building If in a building, in what type of building is the task being performed? Check the appropriate box. b. Structure if Other than a 3uildinq If other than a building, identify the type of structure the task is being done in, or on (ex., tower, boiler, etc.) 11. Control Methods What method(s) are being used to minimize the release or generation of airborne asbestos fibers? Check all that apply. 12. Samplina/Analvtical Method What method is being used to analyze samples for the presence of asbestos, and if that test indicates the presence of asbestos, what kind of confirmatory analysis is performed? Check the appropriate box or identify alternate method of analysis. 13. Sampling Completed By: Was the sampling done by company employees, by an outside consultant/contractor hired by the company, or by a third party hired by the company's outside contractor? Check the appropriate box. 14. Prior Knowledge of Presence of ACM: Was there knowledge of the presence of ACM before the task was begun? Check the appropriate box. 377849 . ST007 I 232 -4- Each Task is to be Monitored from Start to Finish for the Purposes of this survey B. AIR SAMPLING DATA 1. Cassette #. One Worker Only. One Task Only Each cassette should be given a distinct identification number. If more than one cassette is used for a single task, record a separate number for each cassette in this space, combine the data for the .separate cassettes and record the data requested below for the task. Indicate the reason for using more than one cassette in "the comment section 2. Date of Sample: Enter month, day and year. 3. Sample Duration (Minutes) Sampling should begin when the task is initiated and end when the task is completed. The sample duration should be identical to the duration of the task. 4. Fiber Concentration Record the fiber concentration (fibers per cc) as determined from the laboratory analysis. Use "GT" and "LT" for "greater than" and "less than" (respectively). If the sample filter is overloaded, note GT before the result. 5. Fiber Count (f/100 fields) Enter fibers/100 fields fiber count if this information is available or obtainable. 6. Actual TWA Exposure What was the time weighted average exposure for the duration of the job. This is to be determined from the information provided in numbers 3 (sample duration) and 4 (fiber concen tration) above. 7. 8 Hour Time Weighted Average Exposure If more than one sample was taken on a person during a shift, a time weighted average should be calculated using the below formula: C1T1 + C2T2 -K...CnTn T1 + T2 . ..Tn Cn *= the fiber concentration for sample n Tn *= the sample duration for sample n 377850 ST007I 233 -57. 8 Hour Time Weighted Average Exposure fCont.) In extrapolating from an acm exposure period of less than 8 hours to an 8 hour time period, assume zero exposure during the time in which no acm task is being performed and no sampling for acm is being done. 8. Pump Flow Rate; fLiters/Min) The pump flowrate should be the averaged flowrate as determined by calibration with a primary standard such as a bubble tube. Enter the date the pre-sample and post-sample flow rate was checked. 9. Pump Serial Number: Enter the pump serial number 10. Worker ID; Enter the worker identification number, if any, used by your company. 11. Upset Conditions Was there a greater than normal exposure to asbestos due to an unplanned event? Specify the event in the comments section. Mark the appropriate box. DKM/20 377851