Document YGdNMRgQOjr7bgnYywL60R0D

JS .2 * 5* u) o in 3 oy c w3 - 'O 0 rJ o DO o co x tf) U w a. o C O o g5 X -30 pH >p4 >c* (0 rQ* ** V u H o .: -o ^ pO -c V CU . I , '-/MU /AIN ( /X/ X^<\ PRIVATE & COnNfFIiDdEe}:ntiai A-j "l'^ ^ t-A / --.' , ,r Q y-'.i !'*. J\b- ''.m ff\ C-r. TO REFINERY MANAGERS ,P- ,,.\CM anacortes HOUSTON MARTINEZ 0DESSA/CIM2A WILMINGTON WOOD RIVER-v^J plaintiff's exhibit NORCO 0AT! AUGUST 7, 1972 pom GENERAL MANAGER REFINING - HEAD OFFICE umcr osea ASBESTOS STANDARDS SH-1361 X Manufacturing Engineering^^memorHldum of June 28, 1972, discussed provisions of a permanent standard to control employee exposure to asbestos, vhich vas published in the Federal Register on June 7, 1972. Some specific plans vhich have now been formulated for implementation of paragraphs (f) Monitoring, and (j) Medical Examinations of the standard are discussed belov. With reference to monitoring, the nev standard requires an initial determination of potential employee exposure to asbestos at each refinery by December 7, 1972. The purpose of this monitoring program is to determine vhether any employee's exposure exceeds the limits specified In paragraph (b) of the standard. When excessive exposure occurs, the employer vill be reauired to take special precautions end initiate engineering controls. Since a determination of the airborne concentrations of asbestos fiber; is a complex procedure, ve decided it vould be prudent to defer widespread sempli until some specific information vas obtained regarding atmospheric levels of n.sbe tos which might be expected in "^conjunction with performance of typical' refiner:.' work Involving materials containing asbestos. This information will be procured from studies to be conducted at Houston end Wood River Refineries within the next few weeks under the general supervision of Head Office industrial hygienists. An attempt will be made to characterise employee exposure to asbestos from various tasks such as fabrication, application, removal, and demolition of insolation.. Results of the preliminary studies should yield information in regard co what, if any, changes in our work practices will be required to avoid exposure of employee to limits above the specified levels. , r - Information on results of the monitoring programs at Houston end Wood River vill be forwarded as soon as. available to all locations along with specific advice on any action vhich is considered necessary to reduce exposure of employees to asbestos fibers. While awaiting the outcome of results from the monitoring progrea, employees engaged in any operation involving asbestos where there is any visible dust should continue to wear en air purifying resyvirntor . approved by the Bureau of Mines or by NIOSH. A list of approved respirators is shown In Attachment A. Regardless of results of the findings at Houston and Wood River, in order to comply with paragraph (f), each refinery will still be required to cor.dv a comprehensive monitoring program in work areas where asbestos exposure nay occv In preparation for this, ve suggest you proceed with purchase of equipment for sampling asbestos. Recommended equipment end suppliers are shown in Attachment B Phase contrast microscopes will not be required as it is anticipated all micro- :lscooic evaluation of asbestos fibers will be performed at one central location. LAM 024318 ABS-007497 Refinery Managers Page 2 In addition to procurement of sampling equipment, each location should prepare an inventory of all materials containing asbestos which are used within the refinery and develop a plan to permit ready identification of these materials. Consideration will also have to be given to the frequency and duration of various Jobs involving asbestos exposure to individual employees. This information will influence the length of sampling periods and evaluation of results in terms of potential exposure exceeding either an eight hour time-weighted average concentra tion of five fibers per cubic centimeter or a ceiling concentration of ten fibers per cubic centimeter. < Also attached is a copy of a July 10 memorandum which contains specific recommendations of Shell's Medical Director covering a. program to achieve complicnc with medical examination requirements of the OSHA asbestos standard. The memoran dum is self-explanatory and our only comment pertains to scope of coverage. Regarding examination of current employees, within Manufacturing we propose to include only those whose regular assignment involves working with asbestos. At most locations these employees are classified as insulators, but in some coses are designated as cement workers or as combination insulators end brick masons. Currently, this involves about T5 employees at our eight refineries. \>>;/ i{ ^ As specified in the permanent asbestos regulations, a medical examination' must be performed on all employees currently exposed to asbestos on or before January 31, 1973v In the case of newly assigned employees or for situations in volving termination, the examination must be performed within 30 calendar days. Insofar as scope of coverage is concerned, the same criteria should be applied in regard to both new assignments or terminations as was specified above for current employees. , Any questions or comments pertaining to the recommendations in this memorandum should be referred to this office or Head Office Manufacturing Engineering. . ^7. - G. Holzman Attachment ' .. cc: Senior Advisor - Manufacturing . Occupational Safety and Health - Manager Medical Director - Dr. R. E. Joyner Manufacturing Engineering - Manager Manufacturing Operations - Mr. R. H. Tubman Legal Department - Mr. James Evans Shell Engineering Council - Chairman Shell Chemical Company - Engineering - Manager * Exploration and Production - Mr. P. A. Dennie LAM 024319 ABS-007498 ATTACHMENT A The asbestos standards call for the use of an air-purifying respirator to be selected from those used under ^the provisions of 30 CFR Part 11 (37 73. 6244, Mar. 25, 1972). h Since this is a new schedule, and since NIOSH has ju9t taken over the responsibility for respirator approval, there are few, if any, respirators on the market which have been approved under the new schedule. The schedule calls for two types: 1. Respirators, with replacement filters, designed as respiratory pro tection against asbestos-containing dusts and mists. - 2. Single-use dust respirators...[for] ... asbestos ... Only chose respirators approved by NI0SX/US3M can, be so marked. - | , NIOSH has advised us that anv respirator meeting the old Bureau of Mines . Schedule 213 requirements will suffice until there are sufficient respirators on the market under Che new schedule. ... Single-use respirators. :':^fype 8500. Three-M Co. 3M Center St. Paul, Minn. 55101 Schedule.21-B respirators (Representative List) * American Optical Corp. 14 Mechanic Street Southbridge, Mass. 01550 ' Bnusch & Lotnb Incorporated 035 Sc. Paul Street Rochester, N. Y. 14602 Pulraosan Safety Equip. Corp. 30-48 Linden PI. Flushing, N. Y. 11354 Rochester Safety Equip. Co., Inc. S3 Kovell Street Rochester, N. Y. 14607 Ce.^co Safety Products, Inc. 100 E. 16th Street Kansas City, Mo. 64108 Welsh Mfg. Co. 9 Magnolia Street Providence, R. I. 02909 Mine Safety Appliances Co. 201 North Sraddock Ave. Pittsburgh, Pa. 15208 Willson Products Div. 2nd and Washington Sts. Reading, Pa.- 19603 LAM 024320 ABS-007499 ATTACHMENT A EQUIPMENT NEEDED . A. Sampling Pump (One of Che following three. Specify t'naC pump should meet the OSiLA requirements for pulsation dampening.) 1. Bendix-Unico C-115 Air Sampler, with battery and charger. Catalog No. 3650 - $240.00 .2. Bendix-Unico Micronair Personal Air Sampler, with battery and charger. Catalog No. 3900-10 - $195.00 3. MSA Portable Pump, Model G, with battery and charger. Catalog No.-456252 - $200.00 ... 3. Sampling Accessories (Item 1 is Che complete 3-piece plastic cassette with filter and pad. i'L'cia 2 is Che replacement filter and support pad for use in the plastic cassette.) - 1. Millipore Aerosol Analysis Monitor, with type AA filter, white, plain, and thin support pad. Catalog No. NAN? 037 AO. Carton of 50. $30.00 2. Millipore Type AA Filter, white, plain, 37 urn, with thin support pad. Catalog No. AAU? 017 00. Package of 100. $18.50 (Choice of Items 3 and 4, the metal adapter which connects-the plastic cassette to the sampler hose.) i 3. Millipore Aerosol Adapter. Catalog No. XX62 000 04. Each $6.00 4. Adapter, hose end for 1/4 inch tubing.to male leur slip. Catalog No. Lll/L (Price unknown) . (Beeton, Dickinson and Company) ' * (Items 5 and 6 are a 3 foot length of plastic hose for connecting the filter assembly to the pur.?; has clips to secure to.clothing.) 5. Bendix-Unico 3-Foot Sampling Hose with clip. Catalog No. 3900-903 - Each $1.25. 6. KSA Sampling Line Assembly Catalog No. 456226 - Each $1.25 * ' LAM 024321 (Items 7 and 8 are cellulose bands placed over Che filter-end and mid-sections of the plastic cassette to help keep chern together and prevent leakage of air and dust contamination.) 7. MSA Cellulose Bands, jar of 60. Catalog No. 625415 - Jar $1.50 S. White, opaque, cellulose bands, 41 x 25, No. 28 (Price unknown) V'a2;cr U. Jolly 4 Co., Inc.) ABS-007500 -2- Respiratory Disease History Eliciting a history for symptomatology of respiratory disease can be accomplished by a nurse or technician, A special history and examination form to meet this requirement is attached as Appendix A. It is suggested, that affected locations reproduce this form for their ovm use. Soirometrv Pulmonary function tests involve the use of specialized medical equipment. In locations vhere relatively few . examinations will be scheduled, or where a nurse Is not . available to administer the test, this procedure will have to be accomplished through an arrangement with out side medical facilities. In larger locations, the purchase of equipment and performance of the test on-site - . can be economically Justified. If it can be projected that as many as 15 or 20 spirometry tests will be performed A ^ annually at a given location, the purchase of a spirometer ' will be economically advantageous. Spirometry equipment recommended for an in-plant testing program is detailed in Appendix 3. The nurse conducting spirometry tests should familiarize herself thoroughly with the literature and instructions accompanying the machine, and should be further qualified through a brief training course, which can be arranged w.'.ch an outside facility currently providing spirometry testing. Physicians specializing in internal medicine and/or chest diseases are most likely to have this equipment in their offices. Most hospitals also utilize such equipment ur.d .the nurse's training might be arranged through the hospital administrator. An essential element of an effective spiro metry program is the nurse's ability to elicit, through instruction and encouragement, the patient's maximum, ventilatory effort. Physician'sc.eviev The chest x-ray report, respiratory disease history, end pulmonary function test results should be reviewed by a physician, and his comments and evaluation documented in writing on the previously mentioned form (Appendix A). % LAM 024322 ABS-007501 w, / to MESSRS* 1'* 3aro:; J. W. ELGER R* L. FERRIS J. 3. HENDERSON A. C* HOGGE J. V. SHEEHAN F. H. S7AIT3 S. G. STILES 0. L. STONE G. C. BANKSTON JULY 10, 19T2 hom medical director* \ PUBLIC AFFAIRS subject MEDICAL REQUIREMENTS TO . , MEET OSHA ASBESTOS STANDARDS On December T, 1971, an emergency standard pursuant to the Occupational Safety and Health Act of 1970, regulating employee exposure to asbestos fibers was published in the Federal Register (36 F.R. 23207). Since that date, appropriate hearings have been held by OSHA, and a per manent standard has now been issued (37 F.R. 11318), portions of vhich will become effective this month. j The purpose of this memorandum is to adYiee all concerned of the applicable regulations and to recommend what would appear to be the most feasible methods of implementation. The permanent standard contains specific requirements relating to medical services to employees. These requirements, all of vhich vere effective July 7, 1972,lare as follows: 1. Preolacenent Examinations ^"The employer shall provide or make available to each of his employees, within 30 calendar days following his first employ ment in an occupation exposed to airborne concentrations of asbestos fibers, a comprehensive medical examination, which shall include, as a minimum, a chest roentgenogram (posterioranterior lU x 17 inches), a history to elicit symptomatology of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FZV^q)/'/ The implementation of the program outlined in the above para graph will necessarily hinge upon industrial hygiene studies to identify those specific areas in plant locations where the ? new employee can reasonaoi~y~be~'expected to be "exposed to _ airborne concentrations of asbestos fibers77^ Once these areas are delineated, then all employees entering work in such areas must be provided the specific medical examinations. _ 7l Chest X-Rav Since none of Shell's locations have on-site x-ray capability, the chest x-ray will usually have to be performed in an out side facility. Local arrangements should be made to provide for taking the x-ray and for a written interpretation by a physician. \ LAM 024323 ABS-007502 ADDRESSES OF SUPPLIERS 0? EQUIPMENT AND ACCESSORIES LISTED 1. Bendix-Unico items: National Environmental Instruments, Inc. P. 0. Box 590 Fall River, Massachusetts 02722 2. MSA items: Mine Safety Appliances Company 400 Penn Center Blvd. Pittsburgh, Pa. 15235 3. ' Millipore Corporation i Bedford, Masoachuoetts 01730 4. Becton, Dickinson and Company Rutherford, New Jersey 07070 5. Whiter !I. Jelly L Co., Inc. 2822 Dirch Street Franklin Park, Illinois 60130 LAM 024324 ABS-007503 - 3- Vhether or not the "comprehensive medical examination" referred to above should include a clinical examination oy the physician has not yet been determined. In the case of preplacement examinations, this presents no problem, since a clinical examination is conducted as an integral part of the preplaceinent examination. Annual re-examinations for exposed employees, however {Item 2), will have to be tailored according to future CSHA guidelines. For the present, test results should be reviewed by a physician as noted above, and clinical examinations should be performed only on those employees which, in the opinion of the physician, have valid indications for such examination. These indications should include: (a) An abnormal chest x-ray reading indicative of possible chronic pulmonary disease. (b) A vital capacity less than 70,of the predicted value. (Method of determining predicted vital capacity is detailed in Appendix C.) .(c) A forced expiratory volume (one second) less than 70 of the measured vital capacity. (d) Respiratory history responses Indicative of possible chromic pulmonary disease. Those locations already having part-time medical services available may utilize this channel for the physician's review procedure. Where adequate physician services ore not available, the report of the Special Medical Examina tion- Asbestos, may be forwarded to the office of the . Medical Director for review. 2. Annual Examinations ^"On or before January every employer shall provide, or make available,' comprehensive medical examinations to each of^KTs-employees engaged in occupa tions exposed to airborne concentrc.tiono of asbestos fibers."^. I Annual examinations must include all features of the preplacement examinations set forth above, and the physician's review and recommendations should be conducted in the same manner. The incidence of clinical examinations necessitated by this standard will naturally increase with the employee's age and. length of service. LAM 024325 ABS-007504 - It _ 0 3, Termination Examinations ^ "The employer shall frovide I[Q^nake_availbie'iwithin 30 calendar days before or after the termination of employ ment of any employee engaged in an occupation exposed to airborne concentrations of asbestos fibers, a comprehensive medical examination."y Termination examinations must include all features of the preplacenient examinations set forth above, and the physician's review and recommendation should be conducted in the seme manner.... / /. , 4 !, Use of Respirators , i ' */ ^"No employee shall be assigned to tasks requiring the use of respirators if, based upon his most recent examination, an examining physician determines that the employee will be unable to function normally wearing e respirator, or that the safety or health of the employee or other employees will be impaired by his use of a respirator. Such employee snail be rotated to another Job or given the opportunity to transfer j j to a different position whose duties he is able to perform j' with the same employer, in the same geographical area and I with tne same seniority status, and rate of pay he had Just I prior to such transfer, if such a different position is available." / This provision__of_th.e_ataJidard appears clear-cut end requires no comment .(^''Hopeful 1 y ^-very few instances will occur in which the use of arespirator is prohibited. 5. ' Medical Records `""Employers of employees examined pursuant to this paragraph shall cause to be maintained complete and accurate records of all such medical examinations for a period of at least 20 years."/ In locations where a Medical Department staffed by at least one nurse exists, records of these examinations should be permanently maintained in individual medical Jackets designated for each employee. Where in-plant departments do not exist, records should be forwarded to the office of the Medical Director. LAM 024326 ABS-007505 6. Access to Medical Records "^"Access to medical records is limited to the Assistant Secretary of Labor for Occupational Safety and Health, the Director of :;:0Si, authorized physicians and medical consultants of either of the above, and upon request of an employee or former employee, his personal physician."^. It would appear that, in practice, the above text will limit access to medical records to physicians only. This interpreta tion is in keeping with OSnA's general philosophy that individual medical records do not have to be made available .to a Compliance Officer in the event of an inspection. Controversy over employer access to medical records is expected as additional standards requiring medical examinations are promulgated. The Department of Labor has said "... there is no intention to allow employers to abuse medical information obtained pursuant to the Act to the detriment of employees. Therefore, the administration of the medical records requirement will be closely watched, and, in cases of abuse, appropriate action will be considered." Medical records obtained pursuant to the Act should, accordingly, . be kept by the Medical Director or other physicians and/or para. medical personnel under his supervision or acting upon his advice. I will be happy to furnish any assistance requested to further the implementat Ion of this program. 1 am located in Room 1570 - One Shell Plaza; telephone 220-6359* ' ' \ Attachments cc (w/attachments) Messrs. R. J. Bauer C. A. Burton K. N. Papadopoulos H. E. Walker J. E. Creen K. R. Kemraerer B. W. Dunbar P. A. Dennie * H. T. Zgliht Y. G. Whittington ?. A. Crain t ,* LAM 024327 ABS-007506 C3 Ihell Dcvwl&pnnt Coapafly Other Location "ursuuit to OSltA Regulation* published la th* Federal Register (37 F.H. 11213), the following procedures vere performed on :",*e-nul employee: HCTTCA1. hiSTORY I (Pleas* check Ye* or 5o) 1. Have you had *hortn*sa of breath In the' past fev Booths? 2. Boca your shortness of breath baXc you stop for breath after clloblsg one flight of stairs? 3. Docs shortness of braath interfere with your work? It, Does shortness of breath ever awaken you fron sleep? 5, Doea shortness of breath ever occur at rest? 6. Do you have to sleep on aeveral pillows at night in order to breathe easily? .7. Do you hove a bothersome cough nearly every day? 6 Is your cough mainly on lying down? ?. Is your cough mainly on arising In the morning? .10 Is your cough ahouf the same ail through the t'ny? .11 Jo you cough up yellowish or greenish tputun? 12. have you coughed up blood within the past six oontbs ? 13. Do you thlnX the blood eaxe from your nose, throat, or chest? (Circle one) lb. Are you frequently aware of whistling or wheer.lng when you breathe? 15. i'.as a Doctor ever said you hove eapbysenal 16. Do you get frequent chest colds? Remarks I II. SPIROMETRY: Ht, Measured Vital Capacity ____ Forced Exp. Vol. (l second) employee's Signature ___ Age _______ Predicted Vital Capacity _____ which is It of Predicted Vital Capacity __, vhich is ft of .Measured Vital Capacity III. CHEST X-RAY: Date Where is film filed? - Where perfomed? Result: (Attach reading of chest x-ray.) Remarks: IV. PHYSICIAN'S TV/LCATICN: History and test results above do not shov evidence of chronic respiratory disease. I___L Marginal findings. Recommend follov-up as noted below, CZl Reqoramend immediate further study as noted below. I___l Employee may wear respirator. i---- 1 Employee should not wear respirator. Remarks: * Physician's name (print) ' Physician's signature Date V* CLINICAL EXAMINATION: (when indicated) - (Attach report of examination). V?! ADDITIONAL PROCEDURES, REMARKS, ETC.: _____ LAM 024328 ABS-007507 APPENDIX. 3 RECOMMENDED SPIROMETRY ECUIRMEirr 1 Monaghan Portable Pulmonary Function Analyz er - Model M 1*03 vith dig read-out. Price - $950.00. Manufacturer: Monaghan, Inc. 500 Alcott Street Denver, Colorado 802CU The major advantage of this machine is its portability (veight - 10 pounds), vhich vould enable it to be moved to various locations vhere high density employee populations exist. One such unit, for example, vould probably meet the demands of the entire Houston area insofar as asbestos examinations are concerned. Subsequent 0SHA standards may require increased pulmonary function testing, at vhich time additional equipment may become necessary. This machine has no ; special installation requirements, and training in operation can be . accomplished in three to four hours. 2. Jones Pulmonor III Price - $728.00 Manufacturer: Jones Medical Instruments Company 200 Windsor Drive Oakbrook, Illinois 60521 National Distributor: Reynolds & Reynolds 503 V. Main Street . Mayvoot*, Illinois 60153 This is a suitable optional choice. Its major disadvantages are veight, space requirements, and the fact that the operator must make manual calculations in order to derive the needed figures. 3. Certain pieces of equipment have been found unsatisfactory. If purchases other than the above-mentioned models are anticipated, please contact the Medical Director for further information. U. There is a possibility that OSHA vill, at some later date, issue guide lines setting forth specifications on type of test machine, certification of training for operators, etc. It is, therefore, suggested that locations ' considering equipment purchases update the information contained in this memorandum through a telephone call to the Medical^Director Just prior to taking such action. / LAM 024329 ABS-007508 appzxoix c CAIC'ILATIOX OF PREDICTED VITAL CAPACITY The Predicted or "Normal" Vital Capacity is calculated froa the equation "below, using the age, height and sex of the patient: Males = .133H. - .022A' 3.60 Feaales 3 .10lH - .iSfiA - .2.69 ' ! ' . I I 1t ' * | * . . , Where H = height in inches, and A 3 age in years ' (Example: a l0-year old, 5'7" Bale vould he calculated hy multiplying .133 x 67" and subtracting ! froa the result .022 x 1*0 years. Froa the second result, subtract 3.60 to obtain a value of U.l3 liters, or UU30 cc. A 37-year old, 5'5" feaale J I will similarly show a Predicted Vital Capacity of 3".bO liters, or 3l*0h cc.) LAM 024330 ABS-007509