Document YKeDk517V7ZNm7M1KoX3rXv0

FILE NAME DuPont DUP DATE 1972 July 10 DOC DUP135 DOCUMENT DESCRIPTION Unpublished Report by James F. Morgan Changing Requirements Under OSHA with Discussion CHANGING REQUIREMENTS UNDER OSHA by James F. Morgan As of today the law concerning concentrations of asbestos in the air in workplaces is that which is stated in the emergency standard which was promulgated by the Department of Labor on December 7 1971 That publication in the Federal Register was followed soon afterwards according to the legal requirements by a statement from the Secretary of Labor proposing to establish a permanent rule Both of those statements are very similar In the making procedure there is opportunity for differences of opinion to be heard and it was in connection with that procedure that the National Institute of Occupational Safety and Health prepared their Criteria Document and proposed a standard different from the emergency standard Their standard and the emergency standard although they differ in the numbers do have a lot in common They also have some startling differences The emergency standard states not only the concentrations that are allowable but goes on to discuss methods of compliance and lay down some rules The statement of concentrations is rather brief It simply says The eight weighted average. airborne concentration of asbestos dust to which employees are exposed shall not exceed 5 fibers greater than 5 microns in length as determined by the membrane filter method at 400-450 X magnification 4 mm objective phase contrast illumination Concentrations above 5 fibers but not to exceed 10 fibers may be permitted up to a total of 15 minutes in an hour for up to 5 hours in an eight day They have followed that 634 sO up by issuing that to the Occupational Safety and Health Administration OSHA a sampling data sheet No. 2. This goes into a little more detail about the method of sampling Of course this is available from the Occupational Safety and Health Administration The NIOSH Criteria Document goes into much greater detail on methods of air sampling and analysis and I would recommend that each of you who has some responsibility with respect to complying with this Act send for a copy of the NIOSH Criteria Document It has a lot of valuable information in it Even if it should turn out that the Secretary of Labor does not accept their proposed standard it still is a very valuable review of the whole situation with respect to causation of disease and prevention of disease . The emergency standard after stating what the allowable concentration shall be and the method that shall be used to determine it goes on to discuss methods of compliance Of course engineering methods come first ' It doesn't go into any detail and it does not even attempt mention all the engineering methods that are available for control of asbestos in the air Notably it leaves out altogether wetting down your material during handling This is more or less a simple preface to discussing another means of compliance which is the use of personal protective equip- ment In this approach the proposed rule of the Secretary of Labor seems to be much more liberal in his approach than the NIOSH Criteria Document The Secretary of Labor simply states When the limits of exposure to asbestos dust described in paragraph a of this section are exceeded and engineering controls required by paragraph 1 of this paragraph Oh are not feasible or do not reduce the concentration asbestos dust . -3- t t, : below the limits prescribed in paragraph a of this section the employer shall require the use of respiratory protective devices The selection of respiratory protective devices shall be limited to those specified in paragraph c which follows One of the rules published June 7 1972 permits the use of respirators in lieu of engineering controls for good cause without the necessity of applying for a variance They go on to specify the types of respirators that are acceptable in varying degrees of dustiness For a situation in which the dustiness slightly exceeds the allowable a simple filter type dust respirator with negative pressure on the inhalation phase is acceptable provided it is on the approved list of the U.S. Bureau of Mines I'm sure that in all . of our plants the safety office has copies of that Bureau of Mines approved list It is incorporated by reference in the Du Pont Engineering Standard on Respiratory Protective Equipment This simple type of filter respirator approved for use in asbestos has a large number of articles listed I think that there are about 35 approved devices When the dustiness goes to a higher level this rule and also the NIOSH Criteria Document requires that a powered filter positive pressure respirator approved by the U.S. Bureau of Mines shall be used This is a fairly recent development It consists of a battery or otherwise powered blower taking room air and filtering it usually on a filter carried at the waist of the person who is going to use it and then passing the filtered air to the facepiece of the mask I inquired about approval | 6 36 whe on, for this type because I haven't seen any listed in the Bureau of Mines list that has come out I have learned that to date there is only one that is approved and it is by a company called Berke on the West Coast I haven't succeeded in learning whether any of them are locally available but with only one approved device I would guess that they are in short supply The Mine Safety Appliances Company has been working on a device and hopes to have approval on one in three or four months To determine which type of respirator must be used in situations where the dust cannot be controlled otherwise a very extensive process of air sampling and analysis is required because these numbers are not easy to come by I'll read just this one paragraph in which the powered filter ( respirator is required When the eight weighted average concentrations of asbestos dust is projected to exceed 25 fibers longer than 5 microns but not to exceed 250 such fibers and when a concentration over a period of 15 minutes exceeds 50 fibers but does not exceed 500 fibers a powered filter positive pressure respirator is required I can see a technician for every asbestos worker trying to determine whether he is going to give him the right respirator I also inquired yesterday about the expected date of publication of the standard I didn't want to stand up here this morning talking about a proposed rule and find that this morning the Federal Register carried the established rule The answer I got from OSHA was that it will be coming out in just a few days They had six months from December 7 1971 to establish a permanent rule 37 wes wes ome -5 -5 This description of types of respirators that are required under certain conditions goes on to state that when respirators are used a respirator program corresponding with that of the American National Standards Institute Standard Z88.2 shall be put into effect That Standard is available from the American National Standards Institute 1430 Broadway New York New York 10018. It includes not only the types of respirators for different purposes but also maintenance and care special problems evaluation of respirator program effectiveness methods of cleaning and maintaining respirators etc. There was an interesting ent 727 sidelight to the original OSHA regulation concerning asbestos fibers The ACGIH Threshold Limit Value used to be 5 mpcf counted by an impinger method In 1968 the ACGIH signified their intention of changing to a 12 fiber count by a membrane filter method and the option was a 2 mppof count by the impinger method These numbers derived mainly from a review of the British experience and an effort by Howard Ayer of the Public Health Service to find a correlation between impinger counts and membrane filter counts I don't thing that Howard feels now that such a correlation is really feasible at all but at that time it was given sufficient credence so that ACGIH put it in their intended change That intended change was again published in 1969. The adopted value was still 5 mpper In 1970 the ACGIH had changed their mind They dropped the 12 fibers to 5 fibers and they eliminated altogether the impinger count method It was that year when the Department of Labor was suddenly required by the Congress to adopt the rule They looked into the Walsh Public Contracts Act which had the only federal standards for air contaminants The 638 6 Walsh people had simply copied the intended change of 12 fibers That is what the Department of Labor adopted under the Occupational Safety and Health Act I have heard one of their people admit that it was a mistake but it did create a lot of furor and a demand for lowering and that is why the emergency standard came out last December DISCUSSION OF PRESENTATION James F. Morgan OSHA talks about various exposure levels and exceeding them Hodwo you propose that we know that we have a particular concentration of 5 10 15 or 200 fibers at the time that a person is being exposed A. The only possible way that I know of doing it is to take frequent 15- minute samples . Q It takes weeks to get our samples back with the results I appreciate the difficulty that you're up against But if you just put a personal sampler on a man and let him carry it through the workday you won't learn of those excursions for which he would be required to wear the respirator That is why I say you have to go to frequent 15- minute samples One thing in particular we are now required to take a sample plus two blank samples this runs into a sizeable amount of money Are we looking into any possibilities that Haskell will take over the counting so that we can get results without having to wait six weeks and possibly saving | a little money also A. Let me remark that the recommended method is not a part of the Act We are not obliged to follow that Let's wait and see what comes out in the rule Dr. Zapp might want to comment on whether within the Company . we are going to set up facilities to do this counting Dr. Zapp It seems to me that it would be only logical and sensible that we do set up facilities within the Company to do this kind of analysis After all when you have a need for something there are usually ways of getting it Now we in Haskell do have the equipment for counting i -- . we have a phase contrast microscope that meets the specifications and we have one person who is skilled in making the counts This obviously would not be enough to handle the Company's burden It might be a start But our problem is that we cannot anticipate the Company's needs and so to speak gear up for them so that we're ready when the requests come in to do the job We've got to get the pressure from within the Company in order to justify to our own management the necessity for doing the work In other words we're a service organization It will not necessarily follow that these counts will definitely be done at Haskell Laboratory It might be decided that they be done in the Engineering Department or maybe Central Research I think that if you feel you will have a sufficient load of samples so that it is not economically better to send them out to count you should make this known Perhaps the best place to make it known or at least a good place to start would be to the Departmental Member of the Company's Liaison Committee of the Environmental Quality Committee You know that there is an Environmental Quality Committee chaired by Dr. Edwin A. Gee of the Executive Committee The remaining members of the Committee are Ernest Ruppe who is the time Manager of Environmental Quality reporting to Dr. Gee and three part members namely Gene Christian of the Engineering Department Charles Welch the Assistant General Counsel of the Company and George Caldes of the Public Relations Department They have established a Liaison Committee with the departments It includes all operating departments and relevant staff departments but not all of them The Liaison Committee meets once a month Up to this point its function has been primarily concerned with such things as Corps of Engineers permits and problems of that type foxy of 41 3 uae However it does have direct entree to the Environmental Quality Committee which is the closest thing that we are going to get to a corporate form for this type of problem I think it might be a good place to call the needs to the Company management's attention So to answer the specific question I see no reason why it cannot be arranged for these counts to be made inside the Company but just who's going to do them is not clear to me There are a number of plants with laboratory facilities that have technically trained personnel and have phase contrast microscopes Is there a reasonable possibility of training local technicians to make these counts and thereby eliminating the time lag involved with sending samples out A. If they have the equipment I see no reason why it can't be done Can you train them A. Yes and you can get help from NIOSH They will gladly help train your people or even check samples with them which is a good idea at the beginning Dr. Zapp I see we have Miss Connie Eddy with us She's our trained person Connie would you like to come up and talk about the difficulties and the ease of learning the technique Constance W. Eddy I learned how to do the technique and I'm not sure I'm what Dr. Zapp calls an expert yet But I went up to the Harvard School of Public Health to learn the technique which is very straightforward Mr. Morgan put me in touch with Dr. Burgess and Jack Lynch who actually does the counting The original reference by Edwards and Lynch that describes it came out in 1968 and is almost exactly the way it is still done I gave Dick Hubiak a slightly updated procedure that was sent to - 42 -i- me by the United States Public Health Service which tells in almost minute detail everything involved I think the important thing is that this is a very much see it and count it method You have to develop consistency so that the actual technique of preparing the slides and working the microscope is very straightforward It doesn't require much in the way of technique What is important is being able to count consistently and with some reliability Counts between people should compare favorably So I think there should be some kind of checking to make sure that whoever is being trained to count counts the same way that another source will For instance Jack Lynch and I both counted some slides to see how we compared in our counts We found out that partly because I was new at it and partly because I probably saw things differently from what he did , my counts were slightly higher than his I think it comes with practice It's just like counting blood cells After a while you begin to look at them and see what you're supposed to see and this is why I think some checking should be done The method is very easy to do and he'd said it was much easier to do than the impinger counts that he used to do before this method In fact he likes to do it much better than the impinger counts Q What is the reference you refer to Is it generally available The original reference is in the Annals of Occupational Hygiene Vol 11 1968 The other reference I got by writing Jeremiah Lynch at the United States Public Health Service They have descriptions of everything that you have to slides to use etc. are using to train their people I think this is their manual that they 43 -5--5- Jim do you suggest that we get the NIOSH Criteria Document A. Regardless of what the rule is I think that is is a good document to have You made reference to the fact that if the asbestos dustiness could not be reduced to the recommended level that respirators of some type would have to be used which would require a variance Under what circumstances is the variance required Is this a recommendation or is this something that is likely to occur in the final ruling In this NIOSH Document their proposed standard states it this way Section 4. Personal Protective Equipment and Clothing this section shall apply whenever a variance from the standard set in Section 1 is granted under the provisions of the Occupational Safety and Health Act That says that if you cannot reduce the level to whatever the standard prescribes that you must seek a variance before you can ever use a respirator Reply from floor This means you shut the job down and don't do it until you get a variance 7/18/72 Dr. Zapp As you have already heard earlier this morning under the Occupational Safety and Health Act we are living under an emergency standard established in December and expiring in June Emergency standards are only good for six months at the end of which time they are to be replaced by a permanent standard can expect the permanent standard to be So between now and June 7 we issued So far the Department of Labor has kept what that will be numerically a closely guarded secret The permanent standard will be more than a number You've already heard enough of the recommended standard to realize that it not only consists of a speed limit type number or numbers but also a required procedure for surveillance Surveillance not only of the environment that is to keep a record of what concentrations you are exposing people to but also surveillance of the workers that is to say medical surveillance In a way this is a biological monitoring of the worker Henry Trochimowicz will discuss this subject 645 GENERAL DISCUSSION OF PRESENTED TOPICS What was the Du Pont standard that listed all of the containing | cements Cements 500M Q. What has Manville been doing in the area of research I certainly don't expect them to be going out of the insulation business Manville has been very quiet about this We know they are trying to develop an asbestos product but we've heard some adverse results of these materials in shipment I might mention that all of the asbestosfree calcium silicates we've seen so far by appearance and we can imagine general characteristics are somewhat less than the previous asbestos- bearing calcium silicates They have lost something We're going to nay don't , have to learn to live with it I know other than M's Thermo 12 which is a calcium silicate type insulation if they're using a glass fiber binder They make no prediction other than the end of 1972 In other products I don't know what they're heading into Is Manville doing anything in the way of research on better engineering controls In their own shops I know nothing about I can only assume they'd have to be because of the volume of asbestos they handle for many products other than just thermal insulation These substitutes , during fabrication or whatever produce fibrous materials that satisfy the geometry of this regulation Will they be Py 107 2 an ruled out because they are made of a different substance or wouldn't it satisfy the geometry requirements of the length and diameter aspect of the fiber mentioned in the standard A. The standard indicates a fiber greater than 5 microns it doesn't say anything about the chemistry of the particles I think the problem is that the asbestos fibers are ideal in that they have this tremendous aspect ratio It is very difficult to grow any kind of synthetic crystal to come anywhere near it You can get the diameter but you can't get the tremendous lengths I think people have gotten some degree of chemical resistance and some degree of diameter but to get this nice combination that asbestos does have physically and chemically is pretty hard. I was inquiring about the fact concerning monitoring and not why synthetic ( fibers cannot be found to replace the asbestos fibers What I'm interested in is what if you use substitute insulation with asbestos fibers What do you go by in terms of evaluating the air samples Will these fibers look like asbestos fibers and could you distinguish between the two if they both existed on the plant at the same time in the insulation material Would the sampling technique now stipulated tell whether you were indeed exceeding a fiber concentration This is a point I'd like to make when we can get totally away from asbestos which of course has all the nasty things said about it in OSHA We're going to have to monitor for diatomaceous earth glass fiber mineral fibers silica and what have you So there is still going to be a monitoring program but I don't know what the law makers have up their sleeves When we get away from asbestos this will take a lot of teeth out of this thing that we're now working on 6108 6108 -3- I think what you were trying to refer to is as follows If you were doing fiber counting can you distinguish these artificial fibers from the | asbestos fibers using the criteria of a 1 ratio If you look at asbestos fibers under phase contrast they will vary in diameter and length You will recall that the fibers are made of fibrils and therefore each fiber will vary depending on the number of fibrils making up the fiber There will be differences in length and diameter of each fiber If they go to these artificially manufactured fibers more than likely they will be fairly uniform and easily distinguishable from the natural asbestos fibers WhatI was wondering about in the analysis of the samples would we know by looking it under the microscope whether we had asbestos or not Probably one of the criteria that will come out and that I expect is that the insulating material would be labeled that it does contain | | asbestos At the last conference it was indicated that chrysotile could be distinguished by its being comprised of a series of circumscribed circles tell that through a microscope Can you By an electron microscope yes But you won't be able to pick up these characteristics at the magnifying levels that you count at You would also have to get a section of the fiber to detect this factor Let me rephrase my question Let's say I had a Manville product with 10 percent asbestos fiber and 90 percent calcium silicate which I ran samples on and sent them in to be counted They would report the densities and include the fibers and the calcium silicate How will they tell if the fibers are asbestos in the mixture B 4 109 109 - 4 George Lang To the best of my knowledge there are no other types of fibers in the thermal insulation other than asbestos at this time It is my feeling that when these people convert they will convert to only . . one type of fiber in the insulation A. There is another factor when determining fibers and that is refractive index Slight changes in your refraction mechanism will change the viewing of your particles and I assume that these other materials will have a slightly different refractive index You might be able to pick it up in this way Are we ready to substitute now for asbestos thermal insulation A. No sir unfortunately as I said it was the smaller outfits who made the greatest gains in the manufacturing of asbestos bearing materials The one outfit I know of is a single production line and if they get a construction type order for a couple of carloads they're just going to go up in smoke This is the problem Our only hope here is that they will lead the big ones and start frightening the big ones about how much business they are losing or are going to lose The small ones are clamoring in this direction and seem to be a little less encumbered with their investments Dr. Zapp This floor tile here may well contain asbestos pretty well locked in Is there any hope in exploring new methods in applying asbestos that will permit you to use this material have it so applied that it will be locked in and be no dust problem Is that being looked at A. George Lang I'm sure it is by Manville but of course you end up cutting floor tile by a number of methods I don't know what they're o~ doing on this but we have the same problem in a sense in the mastics 110 ( Co. -5- we use to finish insulation I don't know what percentage they contain but they do contain a fair amount of asbestos filler We have reason to believe we're on the safe side of the coin and manufacture this product which is rather reputable I have done some asking around and it has apparently gotten a fairly clean bill of health because when you spray this mastic you don't have individual fibers It's like spraying tar and the fibers are totally captive and it is very unlikely that you could do anything to that mastic even after it is cured or dried to free up the fibers They are trapped Dr. Zapp That's what I'm getting at Perhaps we can still continue to use asbestos if we used different techniques of applying and containing it after it is applied Does the law now read that you shall not spray material containing asbestos A. Yes I think so a Why can't mineral wool be looked at if asbestos is being ruled out due to its toxicity Why can't mineral wool be adopted by the asbestos processers A. They can This is the direction that a lot of people will go in but due to the diversity outdoor nature and geographic locations of most of our plants mineral wool has very poor abuse resistance If it gets wet it pretty well stays wet It will deteriorate also in cyclic wetting and drying If we could keep our thermal insulation dry which would mean no damage and with satisfactory workmanship our whole problem here ' is almost eliminated Q Everybody is putting the kiss of death on asbestos but who will put the kiss of death or blessing on a new product that will replace asbestos 111 I heard a rumor somewhere that after they get the asbestos under their belt they're going to start picking on some of the other materials What these are I don't know Let's hope they let us get this one beaten down Is the January 12 issue of the Federal Register the latest on the proposal for the public hearing James Morgan That's the latest I know of in the Federal Register The ENA Reporter has something else and it is a little confusing One aspect of the public hearing included the section on the warning signs Do you know where that stands The warning signs that the Commander passed around wouldn't meet the specifications of the January 12 issue of the Federal Register The diamond sign was absconded from the National Fire Protection Association Of course asbestos has nothing to do with fire Of the three diamonds two are zeros and one is 4 for the health hazard What I was concerned about was the one that says dust hazard on it It had to include such words as - Asbestos dust ~ may cause asbestosis a severe lung disease and is implicated with the development of certain cancers Control of exposure to asbestos dust helps to protect against the hazard These would have to be on the signs It seems like we're better off with the diamond sign What about where to put these signs We know the insulation shop areas and storage areas are probably some prime areas for placement but what about the guy in the field that applies the insulation Do the Commander's signs meet the intent of the law 112 .7 A. The placarding of areas in the field or during rip out will be necessary I'm sure and will be a portion of the law Many investigators who did a thorough industrial hygiene survey found that many individuals who were suffering from asbestos diseases were not laggers but only worked in the area around the laggers So placarding in the areas where they are applying or ripping out asbestos will probably be part of the requirement Now whether these signs meet the intent of the law we in the federal government will meet the intent of the law and these are the signs that I intend to use at the present time One other question regarding this same promulgated ruling or proposed rule This has to do with medical examinations It says that they shall be provided in the way that it has been described In the case of any employee who is exposed to asbestos dust and to limits specified in the paragraph of this Section a a fiber limit I think it was indicated earlier that 1 fiber would be a point to keep people under medical surveillance Is there any connotation here One fiber is the proposed limit in the NIOSH Criteria Document which has been forwarded to the Secretary of Labor for his consideration Anyone exposed to more than 1 fiber is by definition exposed to asbestos and comes under the surveillance program Presumably if that were adopted the rules could be changed A. There will be a final regulation sometime between now and June 7 and this will be effective in so many days There is one thing that I think you might keep in mind We talked about 1 fiber or 5 or 10 these are very small numbers But in terms of industrial hygiene the ml is a very unusual volume to talk about We talk about million particles per cubic foot for dust counts and for all the numbers that are listed 6113 6113 8 in the table of threshold limit values we have usually two numbers ppm for volume or mfor air Let's take that 2 fibers down the number for a cubic meter it's up to two million When I put It's a much bigger number and if you figure that a worker is working for eight hours consumes about or uses 10 mof air he could be taking in something like 20 million fibers per day This is the way Selikoff has been stressing it Two is not a small number 20 million fibers per day is a lot Let's keep in mind that just by choosing the British designation of fibers per ml we're making it look smaller than it would be if we were going by the usual American criteria of m I was interested in the Commander's comments about exhausting the asbestos fibers from the insulating shops and scattering it about the countryside I gather that there is not a great deal said about it Will you comment ( this a little about the disposal of the filtering media that you use for exhausted air and the disposal of the tons of waste collected by the filters How do you physically get rid of it A. The hardest material to dispose of is the material from the asbestos insulation during rip off rather than the exhaust wastes Both of these present a disposal problem We are now requiring large polyethylene bags for harvesting the material picking it up as you rip it out and placing it in bags just like you'd pick oranges or apples We also wet down some of the areas to try and cut down on the dust This is one area where there is nothing absolutely nothing in the literature about the collection methods for asbestos We have yet to get our national emission standards First the standard will come out and then we can engineer for a collection method Do you bury it at sea 8 114 . --- 9 A. No first it goes to a collector who must be warned on what the hazards might be to him We do this for the launderers also sanitary landfill disposal We recommend There is this recent promulgation of emission limits under the air pollution control act it calls for bag filters on the exhausts It | is very specific Yes it is and its interesting because when you rip out you don't bring the job to the rip out sight and I've never heard of carrying bag filters to the rip out sight I'm sure it can be done A lot of our plants have shops that already have exhaust systems Under the present regulation we're supposed to have bag filters on them You have to see what the national emissions standard is | Reply They don't list that In other words they don't have it Reply What they're requiring are the specifics of the handling system which is going to limit the discharge and this will provide controls For a fixed installation they are requiring a bag filter The considerable amount of information that was presented today was intended for informational purposes for engineers and the maintenance people at the plants Is there a comparable amount of applicable material being sent to the plant physicians so that they are aware and can cooperate . | with the maintenance people Well they should be aware of it and in fact we have several plant physicians here today Are there seminars given by the Medical Division here in Wilmington expecially for physicians - 10 - ; ae Yes there was a annual medical meeting of all the Du Pont physicians who could get to Wilmington and a presentation on asbestos was given at . that meeting One of the problems mentioned here earlier concerns the test proceedings We collect the asbestos sample and ship it to some unknown place at a fixed cost You get the results anywhere from two to six weeks later By this time we have either definitely exposed somebody to severe doses of asbestos or we come out clean of the two Unfortunately it is too late at that point The question was raised originally whether or not Du Pont can develop a local system where we can get quicker answers Is there anybody that is working on a project that is quick and where you can take a sample and run it through a device and get an answer in an hour or two so that you know if you've got a problem A. It would seem to me that the OSHA people would like to know the answer to that one Counting samples with phase contrast microscope is nothing in the way of the quickest method at the best At the moment there has not been any acceptable alternative developed I would like to ask Jim Morgan if he would comment on Bethlehem Steel's Central Laboratory As I understand it Jim they have set up a sort of corporate center for industrial hygiene analysis and the samples would be sent in there for analysis Do you have any idea what their time schedule or turnover rate is James Morgan They have a company messenger service that gets samples to the laboratory the next morning Then it depends on the laboratory C schedule Dr. Zapp Am I correct in saying that although they have a corporate responsibility for these analyses toward the plants they have no worry 6. 11t 11 - XN (o- ' now about the impending burden under OSHA James Morgan That's correct Before asbestos they went through many other things and never increased the number of help Someone asked this morning about assistance in tooling up for counting at the plant Reply Dick Hubiak said the procedure would be included in the package that each of us will get That is the article that describes the counting technique James Morgan The technique will be given to you but I think you should go one step beyond that and arrange with them to count duplicate samples 0 Earlier we were given some information about average fiber counts on different operations Is comparable information available for calcium silicate with 8 or 10 percent asbestos being used A. George Lang I'm trying to recall on my memory here back to a test that Jim Morgan directed for us over at the Test Center We hoped to test all of the calcium silicate insulations listed in the engineering standards + We hoped to put a hazard label on them and consider the possibility of dropping certain ones from the standards The interesting thing was the fiber counts did not parallel the percentages of asbestos which ranges from 8 to 15 percent by weight except for one material which was 80 percent Now the 80 percent by weight material was very dramatically different With the other materials you couldn't draw a line on fiber counts and asbestos percentage Q@ If you had a material with only 10 percent asbestos could you expect only 10 percent of what you determine on a filter to be asbestos A. No even for the same type of operation there are operator variations wind currents etc. . 117 I judge then that the minimum that a plant has to do is one establish a proper method of sampling and an analytical program for asbestos in all their areas that have to do with the handling of asbestos If the NIOSH inspector came in I presume he would first ask for our data from that test program and therefore the minimum that we would have to have is a properly established program for sampling and analytical work A. Dr. Zapp The mission of industrial hygiene is to recognize , evaluate and control hazards Now the recognititon of the hazard is that asbestos is being worked with The evaluation has got to be that point of phase one Where do you stand Are you within the limits or are you outside the limits Of course control is the important job If you have an asbestos or a presumptive asbestos exposure you should have it analyzed I guess I have a little problem with that because of the fact that I'm all an over the country in connection with asbestos in its many broad applications I'm wondering if there is some way to get around this thing If you categorize some of the things that I've seen like sawing and other " insulation shop work could these present hazardous situations and because of that the operation be automatically barred Can you then apply only those control measures that are necessary without having to go through a full sampling program on that particular aspect Can you cut down on the sampling by techniques such as this and only measure when in doubt A. Dr. Zapp In your sawing operation you'll see dust you know you have a problem of control So certainly you have to apply control measures Then you'll have to check on them by analysis to see whether you've brought them down to certain levels B 118 13 Like in dismantling you know you're going to be over the level and you're going to have to wear respirators to have the right protection So that during dismantling I would presume that sampling will be almost impossible because of the variability in dismantling Reply Which respirators are you going to wear A. Dr. Zapp There's one problem as I see it here As I interpret the standard you are first of all supposed to comply with the limits So that the worker even if he's dismantling doesn't have to wear respiratory protective equipment Then if you claim that it's impossible to meet that level you request a variance In which case you will then be permitted to put protective equipment on your worker The type of equipment is specified by the level of fibers in the air So whether there is a method of short cutting that request for variance I don't know Certainly industry is trying to get the Department of Labor to not require a variance each time they put a respirator on him They recognize the situation as you say You're tearing out insulation you know you're going to have a lot of dust So you outfit him with protective clothing give him a respirator and that's that I don't know how it's going to come out When you request a variance are these normally issued so that you can keep varying or is the intent that you are given a little more time to solve the problem by some engineering method Dr. Zapp If the problem can be solved by existing technology you are given so much time to solve it If it can't be solved by existing technology presumably you keep on the variance until new technology airports becomes available For example at _ you will notice the ground 119 - 14. crew standing outside when the plane comes in and goes out are wearing hearing protection There is no way that you can get the noise level down for a modern engine jet at that particular point If in the future they find a feasible way of doing it why then they will have to comply and engines will be modified and the ground crews can throw away their hearing protection That is the key to the whole thing right now If the existing technology is adequate to solve the problem you have to use it no matter how much it costs you In that context are there materials available so that we could do away : | with asbestos | A. Dr. Zapp Now you come back to substitution That , as Commander Barboo | Oo says seems to be the easiest way at the time I'm not talking about the ease of doing I'm talking about the law Is it defined as technology eliminating of asbestos Dr. Zapp I just say beware of what the substitutes are going to do Do glass wool and mineral wool have relatively clean bills of health when compared to asbestos A. Dr. Zapp There is a certain amount of suspicion as to glass fibers of short lengths How many years experience has there been with glass fibers to 20 Dr. Zapp Yes probably but the kind of glass fibers that we're generally talking about are relatively long not much of the short type ~ When you look at substitutes and consider possible problems later wouldn't now be the time to develop some methods to tag the problem and make them ( identifiable 6170 15 A. Yes we're trying to do that We are currently running tests on some fibers that are not asbestos Our first approach is to do intratracheal insufflation tests which will give you an answer in sixty days as to whether or not the dust produces fibrosis in the lungs It doesn't answer the question of carcinogenicity It takes much longer to develop answers for that For example we had a fibrous mineral dust that contained no silica It looked like a natural But when we did the intratracheal insufflation test it did produce fibrosis Now we're going beyond that test We're testing over a year period to see whether we get fibrosis that is recessive and whether there is any possibility of carcinogenicity So you can get a quick answer to tell you that a certain candidate fiber can or cannot cause fibrosis by the insufflation test It's very helpful to know if it has the potential for causing fibrosis In the Commander's discussion of the medical facts supporting the hazardous nature of asbestos he indicated that the levels have been established upon what appears to be rather scanty information It seems that once these laws are promulgated as of June 7 it is likely that they will be challenged almost immediately Maybe the level of 1 or 2 or 5 or whatever is still going to be open to speculation as to what is fair and proper A. Dr. Zapp Yes I think again the unfortunate thing that the data necessary for establishing another number is no better than the data used to establish the proposed 2 or 5 or 10. Usually in the case like that the courts will not decide against the government agency The regulation states that you have to have exhaust facilities for hand tools Now we have a lot of operations out in the plant I was wondering' if anyone had ideas or recommendations for providing exhaust facilities -16 . for saws which are used for insulation In the shop it is no problem you can use downdraft exhaust The ACGIH and some other groups have been touting high velocity volume exhausts You can exhaust something with 12 of mercury vacuum and use very small volume For example Hobart came out with a welding torch which is able to use 20 cfm to do the work of what has been common in the trade of 400 cfm It actually controls dust much better I think you are going to see more applications of this I'd like to talk about respirators for a minute It seems to me as though you have to put a respirator on an individual until you can prove that you don't have 5 fibers You have to have a respirator on the man doing the work before you can take the samples After you take the sample and you find that it is more than that level you realize that the man has not been wearing the proper respirator Now in looking at the slides that the Commander had it looked like most of the operations were well over 5 fibers I noticed that they were wearing Dustfoefi respirators In most cases it was over 10 fibers and which calls for positive displacement type respirators of which the Dustfoe i,s not They haven't mentioned anywhere whether you can use respirators that use high efficiency filters Wouldn't they be a better respirator or is the problem that the filters will plug up rapidly and thus require positiv^' displacement respirators Commander Barboo First of all your counts were made on a weighted average The approach in your counting procedure of obtaining a good TWA is to use a long sampling period In the incremental steps in the os 6122 the type shey may they and and U.S. U.S. That That That investigate use The phe precisely investigateprecisely 10 may Secretary schedule schedule the for Mines Bureau Bureau is not say that 100 and values greater 10 you must be Secretary Labor than whatever whatever are respirator that for the announcements other Register Register cannot Federal of of other respirators respirator the admission respirators use respirator is hygienist that once industrial So engineering engineering are out you require cannot engineer saying that the that in problem here Q correct the interpretation fi& Ts is required operations that operations A. Zapp I respirator Ae A does positive pressure pressure advantage because does 1% air coming around to advantage can does means nothing can cone have the which bewhiskered air im air does does help bewhiskered help help have does individual the face aiso ditioning be rather pipes difficult difficult advantages advantages & advantages wear respirator around type respirator to weer around ee aiffiowlt line in close spaces A. Commander power power a power good use for areas The hose from face- the face= areas battery face- respirator Ae would the and from would get athe in fresh jine nose. fresh-2i7 - 18- I think one problem we in Textile Fibers have to get some clarification on , is the difference between removing of usable insulation and just demolishing insulation There is not the degree of dust generated during removal as there is in demolishing There is a difference to an engineer It is removal so that it maintains its integrity not only because the dust is held down but the ability to reuse the material It is constructed so that the exposed surface is pretty well cemented We don't feel that there is a problem with this operation Where we have to dismantle equip- ment on a two or three year basis we are concerned with the discussion covered today regarding dust generation Therefore regarding the requirement do removal and demolition refer to the same thing For example cutting a small section off with a knife I would removal because there may ( be the intent of putting it back on Demolition changes the integrity of the insulation which differs radically from removal I think you should see the operation before you pass judgment on it I don't see where you can get around creating a mess during any kind of removal operation Reply I think the uncontrolled dust is the picture the Department of Labor had in mind when they set that requirement We have so many plants involved and it seems that to get a uniform administration of the policy could be rather difficult Can we get the Standards Committee to modify the regulation so that we can get some semblance of the uniformity needed Dr. Zapp We have to wait for the final form to come out Legal will definitely be taking a look at it 19 Reply There is an engineering standard coming out by the Standards Committee to cover the topic of asbestos along the lines of the emergency standard Perhaps changes in it will be necessary when the final law is established There is a question I have regarding a point in this proposed S4T standard It says food gum and tobacco cannot be stored or consumed in an insulating area A. Dr. Zapp The chance for oral ingestion of asbestos is dangerous to your health Cancer in the gastrointestinal tract is elevated in asbestos insulation workers It is not as elevated as much as lung cancer but it is above the baseline of the general population Would you say this would prohibit a person from smoking in an area like this Dr. Zapp I can't see as much a rationale for that as I can for eating Because whatever you're smoking you have a fairly efficient filter Q. Should we convey the information from this seminar to the plant physician and make him aware of taking a closer examination of the asbestos workers A. Yes I have a question about sampling for 10 minutes We have no problem about our people taking an eight average on a number of employees to see what that turns out to be They are very capable in this But they are reluctant however to take 10- to minute samples on every piece of equipment in the shop to obtain a number of samples and record the data Do you think we should be doing this _ If your eight samples are within the specified limits this is fine You might still be questioned , if the inspector sees an involuntary emission of some sort He might ask as to what you are doing on a 15- minute sampling basis B125 B125 B125 - 20 - om, When you have an insulator and a general class of mechanics who may spend one day no days or even up to two or three weeks insulating it would be hard to get records to find out how long they spent doing this Now in this weighted average do you assume the worst in a case like that When you know they're not going to be above the insulator's time and values are they held to the same peaks and averages as an insulator with the same exposure taking into consideration that his exposure is for only twelfth of the year A. I don't know We'll have to leave it up to the lawyers You're not permitted excursions above 10 fibers So in that case you could use single service respirators for those short exposure conditions Zapp There is standard I don't know if you'd have to another criteria that comes in was based on a work expectancy apply for a variance or not and which is that the 5 fibers ml of 30 years of exposure You multiply your 5 fibers times 30 and come up with 150 fiber years or . exposure years would be an accumulated exposure The British figure that if the exposure years factor were 100 that you would have little chance of getting asbestosis The present emergency standard is above the 100 exposure years If you went to 2 fibers for 30 years you would have 60 fiber years which is way below the 100 criteria which makes it on the safe side You could make some kind of calculation like that in terms of your occasional worker If he works 30 years but only one month of the year around asbestos you'll be well within the safety factor of 100. This would be a good argument for the application for variance @ You still would have to wear masks during those peaks wouldn't you A. Yes the difficulty is that nobody knows what a safe level of exposure is especially concerning peaks neh 7/20/72 6127