Document XOwGZjNdXyKy7QervZRGGOYpd

FILE NAME Allied Signal Bendix ASB DATE 1987 Feb 26 DOC ASB091 DOCUMENT DESCRIPTION Memo RE Asbestos Program - Compression Mold Area Feb 25 1987 e 4 es Memorandum Bendix Bendix FrictionFriction Materials Division Green Island New York PLAINTIFF'S 80-63189 EXHIBIT PENGAD Date February February 26 1987 To : S. Scott Scott From C. Larson Larson Subject : Asbestos Asbestos Program - Compression Mold Area - February 25 1987 A walk through the compression mold area with J. Skidmore and J. Herman Herman Sector resulted in the following observations Many work stations with vacuum capability were not as clean as one would expect for several reasons 1. Vacuum hoses did not have attachments which would substan- tially increase cleaning efficiency of the vacuum system 2 Administrative procedures supervision and enforcement of the administrative procedures are not as effective as they should be to enforce cleaning time that is being provided to the operators 3 In order to achieve cleaner work stations the operators have to be provided the equipment to do so Someone has to initiate and follow through on obtaining the necessary cleaning equipment attachments etc. in order to maintain work station cleanliness 4. Various high vacuum hoses were left open to atmosphere thereby reducing operating efficiency at other high vacuum locations Visible accumulations were evident but some possibly could be attributable to not having proper cleaning equipment leaks in duct work resulting in particulate raining upon equipment and inefficient dust collector pick lines on various pieces of equipment Operator work practice could be improved to reduce fugitive emissions from the work station thereby reducing employee exposure There was various pieces of equipment and work stations which were without vacuum capability and had asbestos accumulations that were quite old Book truck frames for example had sub- stantial build ups that have to be removed Book truck storage areas showed recent evidence of being vacuumed but could be 22671 WCK017297 February 26 Page -2- 1987 improved if the vacuum hoses had proper attachments to enhance vacuum efficiency There does not appear to be someone responsible for these no man's areas This has to be assigned to someone to insure proper cleaning of these areas Dust collector duct leaked in several areas near the drills { Bolted work seams should be tightened or possibly the installation of gaskets would insure duct work integrity Some of the equipment visible accumulations may be the result of ducts leaking therefore investigation of visible accumulations should include work integrity inspections Just about every drill we visited had dust collector pick line I hoding problems such as improper placement damaged pick nozzles insufficient hooding around equipment and pick lines which left to atmosphere but not being utilized because the were open obvious dust collector specific hood was not required These are maintenance problems and should be part of a continuing preventa- t for the dust collectors It is my | tive maintenance program opinion that failure to maintain dust collector pick at the a willful machines could be viewed by an OSHA inspector as we violation resulting in grave consequences Based upon this it is strongly recommended that all work cursory inspection stations are inspected to insure that all pick lines etc. are because in proper operating condition This should be a priority it is quite possible that OSHA could conduct a facility inspec- i tion in the near future There were obvious signs that there was insufficient vacuum Since the present vacuum system is cleaning capability cleaners is fully extended the purchase of portable vacuum at the recommended to provide the additional vacuum capability work stations where high vacuum lines are not available Work stations without vacuum capability were obviously not as clean as the work stations with vacuum capability Recommendations 1 Purchase the necessary vacuum hose attachments in order to enhance cleaning efficiency 2 Review administrative procedures to assure that operators are cleaning their work stations as required 3 Inspect all dust collector work and repair all leaks ie gasket installation at flanges if needed 4 Inspect all dust collector pick review all pick against equipment drawings repair as for needed and institute the equipment at the preventative maintenance programs work station 22671 WCK017298 February 26 1987 Page -3- 5 Purchase portable vacuums for work stations without vacuum capability and assign no man's land areas to insure cleaning of these areas 6 Suggest weekly tour by management to insure that administrative procedures housekeeping and dust collector maintenance is being maintained at best management prac- tices ; 7 Since Troy and Cleveland are ranked no 1 and no 3 by EPA in asbestos risk assessment I am quite sure that our two facilities will be high on the hit list by OSHA to conduct enforcement inspections Based upon this insight I strongly urge that routine maintenance operating procedures and purchase of equipment be performed in order to insure proper protection of the employee CRL CR CC D. Carter Cupicha Eads M. Fountain Scott Skidmore Willig 22671 WCK017299