Document VJEgBDkbdz3QVBKqB6OYmaJKN

I I l I I COMMENTS ON ABT DRAFT OF TRAINER'S GUIDE FOR BRAKE SHOP MANAGERS Page 15 The presentation on cancer is quite simplistic, which may be okay for the purpose of this guide; but it does not seem quite right to present mesothelioma the way this text does. It makes it sound as though mesothelioma is a kind of lung cancer which is not correct. The closing statement that mesothelioma "is extremely rare except among people exposed to asbestos" makes it sound as though mesothelioma is common among people who have been exposed to asbestos, and this really isn't the case. Mesothelioma is rare even among people e~posed to asbestos. Page 19 I think this discussion should include. a description of how inhaled fibers are rejected from the respiratory tract and swallowed in saliva. I believe this is the primary means of fiber entering the digestive tract. The discussion should include remarks on the effects of smoking on the respiratory rejection mechanism. Page 21 The word "smokers" in the third line of the first paragraph should be changed to "asbestos workers who smoke." I question the validity of the statement "almost every case can be traced to the victim having been exposed to asbestos" in reference to mesothelioma. I believe most recent information indicates a significant incidence of mesothelioma cannot be traced to exposure to asbestos. Page 23 I also question whether the statement on autopsys and mesothelioma "they almost always find high concentrations of asbestos fibers" is correct. I thought many mesotheliomas were associated with low fiber exposures, and presumably, low concentrations of fiber in the lung tissue. Page 24 It should be pointed out that dust levels shown for beveling lining are for uncontrolled operations. FMSI 06913 ABT DRAFT (Continued) - 2- Page 32 The illustration of the industrial hygienist taking a sample as shown on the right hand side of slide llb is not.a valid representation. Asbestos samples usually are taken with a worker wearing the sampling apparaturs; or by taking a stationery sample with the pump mounted on a stand or merely resting on a-stationery surface. I have never known an asbestos sample to be taken in the manner illustrated. It is important this illu~tration be shown correctly, as it appears numberous times on other slides shown throughout the Abt Drafts. Page 37 Item 2 regarding grinding used truck linings is incorrect. Lining is not ground "to remove grease and dirt." Grease and dirt usually ar~ removed by solvent vapor degreasing or a caustic wash or by exposure to very high temperature. If arc or radius grinding is done to achieve exact fit of lining to drum, exhaust control is needed to avoid generation of excessive airborne fibe~ levels. Page 38 Slide 13 escapes me. The grinder shown is not typical of types commonly used for brake service work. Nor is the one shown on Slide 12 on page 36. I simply can't tell what the guy on the right side of the slide is doing with what looks like a hose. Page 42 On Slide 14 it would be better to show the drum lying on the floor and the backing plate assembly mounted on a vehicle axle, as this is usually v1here these items are when they are cleaned. The grinder shown on Slide ).5 is not typical of grinders used for arcing or beveling brake linings. Page 43 The remarks regarding Slide 14 should include wet spray cleaning and/or wiping with a damp cloth as alternates to vacuum cleaning. Page 45 The conclusion of the remarks regarding Slide 15 should allow a dust ventilation system as an alternate to a vacuum cleaner. A FMSI 06914 '. ABT DRAFT (Continued) - 3- Page 45 (continued) dust system with proper hooding, duct work, fan. and dust collector actually is better than a vacuum cleaner for medium sized and large shops. Concerning Slide 16, I prefer "removed" to "disabled" in reference into compressed air nozzles in shop areas as mentioned the final. sentence of this paragraph. Page 48 The grinder shown on Slide 20 is not typical. Long flexible hose as shown on this slide and Slides 13 and 15 should not be used for stationery equipment because of excessive friction loss and lower durability than metal duct work. Page 51 I suggest the "plastic bags" referred to be given some qualifications such as heavy duty, heavy wall, or some similar characterization. The way also should be kept open for using dust-tight containers other than plastic bags. Page 56 I question whether the three types of respirators illustrated are really characteristic of what normally is used in asbestos operations. I've never seen anyone use a full face piece mask, and the dual filter half face piece masks are only rarely used. Our people usually pr.efer the lighter weight, smaller .single filter half face masks or a disposable type of mask. I don't believe the belt mounted type of powe=ed respirator shown is presently approved or available in this country. Perhaps they should consider changing this illustration to show a back mounted powered respirator, which I believe is approved and available. Page 57 I question whether the last paragraph regarding supplied air versus filter respirators is factual. Supplied-air respirators must be continuously connected to an air supply hose, which can be a cumbersome uncomfortable nuisance to the worker. In most cases I should think a worker would prefer a good filter respirator for exposure levels within its limitations. Page 59 Reference is made to the ANSI guidelines for a respirator program. FMS\ 06915 - 4 -. ABT DRAFT (Continued) Page 59 (continued) These are generally quite good, but I don't like the ANSI instructions for testing respi~ators for fit. I think they are impractical for field use by asbestos construction and/or production workers in some respects. The reference to problems from clothing exposure appear unnecessarily alarming for low level exposures. I think this paragraph should point out that problems of this nature only occur where exposures are high . Page 64 The illustration of the industrial hygienist taking sample as shown on the right hand side of Slide 29 is not a valid representation. Asbestos samples usually are taken with a worker wearing the sampling apparatus, or by taking a stationery sample with the pump mounted on a stand or resting on a stationery surface. Page 71 Is 20 years long enough for medical record storage? I thought this was changed to at least 40 years. Page 74 I suggest "wet processing" be added to "vacuum lines" as a method of engineering control shown on Slide 41. I think it might be better to list the following three items under engineering controls in place of "vacuum lines" on this slide: 1. Isolation 2. Ventilation 4. Wet Processing FMSI 06916 ABT ASSOCIATES INC. 55 WHEELER STREET, CAMBRIDGE. MASSACHUSETTS 02138 TELEPHONE November 18, 1977 Mr. Robert Mereness Asbestos Information Association 1745 Jefferson Davis Highway Arlington, Virginia 22202 Dear Mr. J.1ereness: As you are aware, Abt Associates is currently developing training materials for workers who are exposed to carcinogens in their places of employment. The work is sponsored by the Occupational Safety and Health Administration [contract no. J-9-F-6-0125) as part of their Cancer Alert Program. A brief project description is appended to this letter. One carcinogen with which we are concerned is asbestos. Specifically, we are developing training materials for both workers and managers in two industries, brake repair and building construction. These materials are now in draft form, and are being reviewed by OSHA and by outside experts. Because of the clinical importance and political sensitivity of occupational cancer, we are anxious to have our materials reviewed by leading workers in the field; this group obviously includes you and your colleagues at the Asbestos Information Association. The enclosed package contains trainers' manuals for two managers' courses, one aimed at construction and one aimed at the brake repair industry. I have not included the participants' materials; since they are summarized in the trainers' manuals. Also, I have omitted most of the background readings since these are chiefly reprints of government documents, with which you are no doubt familiar as well as publications of your own Association. The one background reading which I have included is Dr. Richard Glasser's a~ticle, "The :Real Cause of Cancer." While I do not want to constrain your comments in any way, there are a few general questions which are of particular concern. These are: Is the technical content complete and correct? Are the materials properly balanced between technical informa- tion and "consciousness-raising?" Is the tone of the materials appropriate to the audience(s}? These are the general issues on which we seek guidance, in addition to any specific criticisms you may think appropriate. FMS\ 06917 Mr. Robert Mereness Page 2 In regard to your response, please use whatever method is most convenience for you and your staff. If you are able to respond in writing, we would appreciate it. Otherwise, a telephone conversation, scheduled in advance, would be quite satisfactory for our purposes. Your conunents will be most useful if we could receive them in about two weeks' time. Thank you for your kind assistance. GEF:jhs vfJ:~nl;,YJ;q ..1it!!e E. Fax Senior Analyst encs. FMSI 06918 I / .~ ~~ntcntsvj~~ .. of Participants' Packa9es A. Brake Shop Managers 1. Hard copes of slides, with brief intrpductory text 2. "Fabrication and Use of Asbestos Friction Materials," 40-page booklet publi~hed by the Asbestos Information Assoc~ation 3. Occupational Safety and Health Administration, "Standard for Exposure to Asbestos Dust," 36 Federal Register 10466, 29 May .1971. 4. National Institute for Occupational Safety and Health, "Reconunended (Interim) Procedures for Asbestos Brake and E:lutch Servicing!" and cover letter, August 8, 1975. 5. "Industrial Hygiene Consultants," American-Industrial Hygiene Association Journal, Vol. 38, No. 6, June 1977. 6. National Institute for Occupational Safety and Health, "Suppliers of Protective Equipment," undated. 7. National Institute for Occupational Safety and Health, "OSHA Handbook for Small Businesses," OSHA 2209, Revised 1977. 8. Posters (published by the Asbestos Information Association): a. "When required, always use your respirator" b. "If.you don't smoke now, don't start; l.f you do smoke, quit." c. "Use change rooms and lockers; leave dusty clothes at work." 9. Sample "Asbestos Hazard" labels 10. All About OSHA, Program and Policy Series, U.S. Department of Labor, Occupational Safety and Health Administration (revised) 1976. B. Brake Service Workers 1. Hard copies of slides with captions and space for notetaking 2. What,You Should Know About Asbestos and Health, Asbestos Information Association. 3. Caution: Asbestos Dust .. Is Hazardous to Your Health, National Institute for Occupational Safety and Health, Public Health Service, U.S. DHEW, Cincinnati; Ohio~ 45202. 4. How to Use OSHA, A Workers' Action Guide to the Occupational Safety and Health Administration, Occupational Health and Safety Project, Urban Planning Aid, Cambridge, Mass. 02139 5. All About OSHA, Program and Policy Series, U.S. Department of Labor, Occupational Safety and Health Administration (Revised) 1976. 6. Occupational Safety and Health Administration, "Standard for Exposure to Asbestos Dust I" 36 Federal Register 10466 r 29 May 1971. 7. Readings for optional exercises in Hodules 1 and 4. 8. Picture Puzzle and Answer Key for Closing Exercise. It is a garage scene with several violations of the Standard and poor work practices depicted. FMSI 06919 9. CUbic centimeter fold-up 10. Color pester of do's and don'ts of worker practices using negative symbol format like that in slide fi37. Each picture will have a brief caption. The poster will be suitable for hanging in a locker, in the work area or at home. 11. OSHA Complaint Form C. Construction Managers 1. Hard copies of slides, with brief introductory text 2. 40-page booklet published by the Asbestos Information Association: "Shop. and Field Fabrication of Asbestos Sheet Products" 3. Occupational Safety and Health Administration, "Standard for Exposure to Asbestos Dust," 36 Federal Register 10466, 29 May 197,l. 4. National Institute for Occupational Safety and Health, "Recommended (Interim) Procedures for Asbestos Brake and Clutch Servicing," and cover letter, August 8, 1975. 5. "Industrial Hygiene Consultants," American Industrial Hygiene Association Journal, Vol. 38, No. 6, June 1977. 6. National Institute for Occupational Safety and Health, "Suppliers of Protective Equipment," undated. 7. National Institute for Occupational Safety and Health, "OSHA Handbook for Small Businesses," OSHA 2209, Revised 1977. B. Posters (published by the Asbestos Information Association): a. "When required, always use your respirator" b. "If you don't smoke now, don't start' if you do smoke, quit" c. "Use change rooms :and lockers; leave dusty clothes at work" 9. S~ple "Asbestos Hazard" labels 10. All 'About OSHA, Program and Policy Series, u.s. Department of Labor, Occupational Safety and Health Administration (Revised) 1976. D. Construction Workers ~ 1. Hard copies of slides 'with captions and space for notetaking 2. What Your Should Know About Asbestos and Health, Asbestos Information Association 3. Caution: Asbestos Dust . Is Hazardous to Your Health, National Institute for Occupational Safety and Health, Public Health Service, U.S. DHEW, Cincin~ati, Ohio, 45202. 4. How To Use OSHA, A Workers' Action Guide to the Occupational Safety and Health Administration, Occupational Health and Safety Project, Urban Planning Aid; Cambridge, Mass. 02139. 5. All About OSHA, Program and Policy Series, U.S. Department of Labor, Occupational Safety and Health Administration (Revised) 1976. FMSI 06920 7. Occupational Safety and Health Administration, "Standard for Exposure to Asbestos Dust," 36 Federal Register 10466, 29 May 1971. B. Cubic centimeter fold-up. 9. Color Poster of do's and don'ts of worker practices suitable for hanging in a locker in the worker area or at home. 10. OSHA Complaint Form Packaging of Materials Trainer' s packages \-Till be contained in vinyl three-ring binders with inside pouches to contain background materials. Participants' packages will be contained in manila expansion envelopes. Binders and envelopes will be labelled to identify course content and sponsoring agency. --- FMSI 06921 1\ttl:A c.~7: ..,CI;:"Jtoo PHOJEC'r: "Preventive llcnlth Training Program on Occupntional Cancer Hazards." CLIE:'lT: Department of Labcir, Occupational Safety nnd Health Administration, {OSllli.) (Stanley Kalin, acting project officer) . Vl\LllE: $300,963. (CPFF) - Contract No. J-9-F-6-0125 PEPJOD: 7/1/76 - 12/31/77 --------------------------------------------------------------------------- lillt Associates is cun~ently developing training materials for workers (and in some cases fer rr:n!1agcrr.cr.t) who u.re potentially expo~>ed to cancer nazards in their workplace. 'l'his cont.ract is part of OSHA's Cancc~ ]\..J..crt PJ:.-og::-~r.! .....~ich al~o i;~ ..vcJ.v.ss C,eoTg2 t~ashingtr.~n Ul~~.V(~rsity ~n0 Den'.'er F:~scu;_-~~ I~~t.i t~~t.e.. ~b~-. j_s C\.Lrrtntl~,. fu1:rtzli2ing cne t.r~.:!ir.ing plai1s for 'vmrkers exposed to the follmiing substances: Substance ' Inorganic arsenic Coke oven emissions Solvents hsbestos JJexavalent chromates \~orker Group Copper smelter 'vWrkers Coke oven '''orkers Rubber \vorkers Construction and friction products \vorkers Chrome pigment production and pc:int production vwrkers and spray painters For each of the \mrkcr groups a plan for tra:i ning materials has been or soon \Jill be proposed. The summer r..onths V!ill be spent actually developing the materials. In the enrly fall ;,,c ,,,ill be ready to pilot test the materials and then to n:o<'l.ify or revise them before final submission to OSHA. Disscmin2.t.ion of the matc1:ials to ,,orkers is the responsibility of George \lashing ton U:Jivcrsi ty <'ifter we huvc submi tt:.cd our final product.. FMSI 06922