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NEWMYER ASSOCIATES. INC.. 1220 L STREET. N.W.. SUITE 425. WASHINGTON. D C. 20005
T0 Westinghouse Electric Corporation_______
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Re: Asbestos -- Final OSHA Workplace Standards___ ___________
A sharply lower exposure standard for employees who come In contact with asbestos while on the job was issued in final form by the Occupa tional Safety and Health Administration June 13.
The new limit -- which applies generally to industry and for the first time to construction as well -- is contained in mammoth (900 pages) rulemakings announced by John A. Pendergrass, the new head of OSHA.
Exposures to airborne asbestos would be limited to 0.2 fibers per cubic centimeter of air averaged over an eight-hour day. The current limit is two fibers (2.0). The agency originally proposed lowering the limit to 0.5 fibers, but said the 0.2 fiber level ultimately selected would reduce the lifetime risk of dying from cancer caused by asbestos to 6.7 per 1,000 employees, compared to the risk of 64 per 1,000 under the existing standard.
The general Industry standard also provides that when exposures reach 0.1 fibers -- the action level -- employers must institute monitor ing, training, and other protective measures. A practice of rotating em ployees in and out of work areas with excessive levels of asbestos, per mitted under the existing standard, would be prohibited. Engineering controls to reduce asbestos levels to the permissible level must be used where feasible; respirators may be employed under limited circumstances, OSHA said.
The rule is to be published soon in the Federal Register. Attached are copies of a fact sheet summarizing the principal elements of the standards and a chronology of the regulatory history of OSHA control of asbestos, starting in 1971 with the adoption of a 12 fiber standard.
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Newmyer Associates
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PECULATOR? HISTORY OF ASBESTOS (Chronology)
May 29, 1971
-- OSHA adopts a permissible exposure level (PEI) of 12 fibers per cubic centemeter averaged over an eight-hour day H12 f/cc). The PEL for asbestos was among the consensus
-- standards then adopted in accordance with the OSH Act.
Dec. 7, 1971 -- OSHA issues an emergency temporary standard with a PEL of
5 f/cc and a peak exposure of 10 f/cc in response to a
petition fran the AFL-CIO,
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June 7,1972
-- OSHA pramilgates a new final standard with a PEL' of 5 f/cc and a ceiling limit of 10 f/cc. This was the agency's first comprehensive health standard.
Oct. 9, 1975
-- OSHA publishes proposal to revise the standard for general industry, lowering the PEL to 0.5 f/cc with a ceiling limit of 5 f/cc for 15 minutes. The PEL was proposed as the lcwest technologically and eccnanically feasible level then achievable. The Supreme Court decision on benzene caused the
agency to withdraw the proposal.
Julv 1, 1976 -- The PEL was reduced to 2 f/cc as called for in the 1972 standard.
May 24, 1983
-- The Advisory Ccmittee for Construction Safety and Health endorsed OSHA's position that any new PEL adopted for general industry should also apply to the construction industry.
Nov. 4, 1983 -- OSHA publishes an Emergency Temporary Standard lowering the PEL to 0.2 f/cc. The ETS, however, was held invalid by the
U.S. Court of Appeals for the Fifth Circuit.
Aor.10, 1984 -- OSHA publishes a proposed rule covering occupational exposure to asbestos in all industries governed by the OSH
Act (maritime, construction and general industry).
Seo. 28 , 1985 -- OSHA announces plans at a meeting of the Advisory Committee for Construction Safety and Health that it vrould be issuing a separate standard to cover asbestos exposure in the construction industry.
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enployee exposu^ - in no case ledger than six months for enployees whose exposures can be foreseen to be above the action level. Presently, monitoring is required no"more than six months apart for employees exposed above the PEU The new standard, for the first time, sets required methods of monitoring which will inprove the accuracy.
Regulated Area; The new rule establishes the reguirenant 'for a "regulated area" which only authorized persons can enter. Regulated areas are to be set up where exposures are above the PEL. Persons entering regulated areas must wear respirators. In such areas, eating, smoking, drinking, chewing tobacco or gum, and applying cosmetics are prohibited. The proposal would have established regulated areas where exposures are above an action level or the PEL. The present standard does not require a regulated area.
tethods of Cqipllance; Engineering controls and \ork practices
must be used to maintain erployee exposures at or below the PEL, except
to the extent such controls are not feasible. With limited exceptions,
engineering controls Bust be' used to the extent feasible to reduce exposures
to or below the PEL; vhere such controls do not lower levels sufficiently,
respirators will be used to achieve caipliance. The proposal wculd have
permitted any feasible ccmbinaticn of engineering controls, Mark practices
and respiratory proteertian. The present standard permits rotating enployees
in and out of asbestos exposed areas as a means of caipliance; the new rule
prohibits this practice.
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Reoiratory Protection: Order the new standard, where respirators are necessary, the level of exposure determines which type of respirator is required. Although similar to the present standard, the new rule provides increased respiratory protection.
Conmunication of Hazards to Enployees: The present standard contains no specific training .requirements for employees; it does, hewever, require warning signs in areas where asbestos concentrations exceed the PEL and it requires warning labels on products containing asbestos. The new rule requires a detailed annual training program wherever ambient levels exceed the action level. Also, Material Safety Data Sheets (MSDS) are to be used in the program as prescribed in CSKA's Hazard Canmnication Standard. In the new rule, warning signs are required in regulated areas and warning
labels are also required.
M**Me*l Surveillance: Under the present rule, a preplacement physical is required within 30 days after employment for exposed enployees; the exam is to include, as a miniimm, a chest X-ray, comprehensive medical history, and a pulmonary function test. The same exam is to be provided annually thereafter and upon termination of employment. Requirements under the new rule are essentially the same except that chest X-rays would be required less frequently for younger workers and annually only for older workers whose first exposures were 10 or more years ago.
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