Document YXjp6bZy88aN8p2k1nR303vK

HMBB-0006738 \ <r& j--j -.3 From WIN Date ; Suoject: Accident Prevention, U-G-IO 236-2163 January 5, 1976 Asbestos Questionnaire To Mr* Keith A. Sodden Industrial Hygiene Administrator R k D U01 3X9 cc: Mr. W. H. Ziefel, Gateway 2070 , Per our recent telephone conversation, enclosed find a duplicate copy of the 13 page Asbestos Information Association Questionnaire. The Asbestos Information Association has engaged environmental consultant, Roy F, Weston, to collect information and prepare a report covering the technological feasibility and economic impact of the proposed O.S.H.A. Standards. I received this information from our Purchasing Department and plan not to complete the questionnaire and participate in the program. Please review the enclosed information, and if you have any comments, please contact me. /ck Attachment is cs ` ' G7 T. Brady, Accident Pre-' r . 03114768 MWBB-00067i0 ASBESTOS INFORMATION ASSOCIATION MOOTM *M6RC* '560 L Street. N W Wasni.-.gicn OC 2CC35 .232] 223-1885 vnl Lr=U id -.a I hope you have received my letter enclosing a memorandum from Guy G. Gabrielson, Jr. which outlines the Association1s plan for an industry response to the pro posed revision of the OSHA asbestos standard. In my letter, I encouraged member ship in the Association to those of you not presently affiliated with AIA/NA. Whether you choose to join or not, we urge all recipients to participate in this industry-wide project and ask your consideration of financial support to help defray the expenses involved. AIA/NA has engaged the services of the highly reputable consulting firm Roy F, Weston, Inc. to gather information and prepare a report covering the technological feasibility and economic impact of the proposed OSHA standard. This proposed standard could, through the governmental law-making process, reduce the 8-hour time-weighted average exposure of 5 fibers/cc (2 fibers/cc as of July 1, 1976) to 0.5 fibers/cc. ' The study that Weston will make must be based on accurate information gathered from companies representing the various asbestos-using manufacturing processes within the industry. My letter has been sent^to more than two hundred companies. We believe the effort we are making will benefit your company by helping to achieve a reasonable and realistic asbestos exposure standard in the workplace. Therefore, we ask that you provide the fullest cooperation and assist in the development of information essential to the study. Weston will contact you in the very near future to discuss the enclosed ques tionnaire. Depending upon the project schedule and your situation, Weston will: Set up an appointment for a plant site visit; or Record your input by telecon; or Provide mailing instructions for your response. 03114769 1 r HMBB-0006741 ^=S1 Page 2 To maintain comptete conf idential ity of af! information, Weston will: Code the cover page of the questionnaire, detach this from the remainder . of the questionnaire, and keep separate the cover page from the technical and economic information; Not dupl icate either the cover page or the contents of the questionnaire; Not reveal the contents of the questionnaire to anyone outside Weston, except in the form of overall tabulations for industry segments In a form such that individual company input cannot be segregated. At the conclusion of the rule-making process, Weston will return ail data you have submitted. A meeting, which all participating companies are urged to attend, will be held in the Mayflower Hotel, Washington, 0. C., commencing at 9:00 AM February 4, 1976. At this meeting, the proposed industry response to OSHA, including medical and feasibility/economic reports and a summary report with recommendations, will be presented for approval by the attendees before the formal submission to the Department of Labor on behalf of all those companies (whether or not members of AIA/NA) who have participated. We trust that you or your representative will be present for this important meeting to endorse the presentation to OSHA. You will be sent a further reminder regarding the meeting. Due to the February 9, 1976 deadline for comments established by OSHA, it is imperative that Weston's report be prepared at the earliest date practicable. We ask that you give urgent attention to this matter, commencing as soon as possible, to assemble the information requested in the questionnaire. To expedite the process, we ask that you duplicate the questionnaire if you have more than one plant. Sincerely yours, TAO/cdc Thomas A. Dougherty President 03114770 MU8B-00U6742 ROY F WESTON. INC WESTON WAY WEST CHESTER. PA 19380 PHONE (215)692-3030 TELEX 83-5348 =3 ^3 & VO 'j--l AS8EST0S INFORMATION ASSOC IAT1QM/N0RTH AMERICA INDUSTRY QUESTIONNAIRE^ ^ Company Name Plant Address Corporate Affiliation Name of Plant Contact Phone Number Title Note: This cover page will be detached from the remainder of the questionnaire to Insure confidential handling of all information. j n==n -.3 (1) For assistance in completing the information in this questionnaire, please contact Mr. Jerry L. Hebb, Roy F. Weston, Inc., phone (215)692-3030. (2) If, for any reason, you do not choose to participate in the study by completing this questionnaire, please return it directly to Mr. Jerry L. Hebb at Roy F. Weston, Inc. CCNFIDENT1AL Company Code # Plant Code # 1 03114771 MUBB-U00671j3 rrr I. General Product/Process information 1. Which of the following industry segments best describes the asbestos . containing products in your operations? (Check more than one, if appropriate). . Asbestos Cement Products (pipes, sheets, siding shingles) Asbestos Paper Products (asbestos felts, latex sheets, underlay- ments, electrical and commercial papers) ____ Floor Tile Coatings (roof coatings, caulks, sealants, paints, adhesives and undercoatings) Friction Materials (automotive linings, disc components, blocks, clutch facings) Gasket, Packing, Sealing Devices Joint Cements Asbestos Reinforced Plastics Asbestos Textiles Asbestos Drilling Muds . Asphaltic Paving ( 0fstrfbution/Resale M?seel 1 aneous (Specify) _________________ 2. Which of the following categories best describes the operation at your plant? (Check more than one, if appropriate). a. ___ Manufacture a product where raw asbestos is used. . What tonnage of raw asbestos do you use per year? _______ b. ______ Process a product which already contains asbestos. 3. In reference to Question 1, for each industry segment, give the specific asbestos end product(s) (siding, pipe, etc.) manufactured, handled, or used at this location and the annual volume of each (in pounds, tons, square feet, etc.). / Industry Segment End Product(s) Annual Volume CONFIDENTIAL Company Code # 2 Plant Code # 00114772 v=3 U---- ij k , _p k. What was the aggregate sales value of asbestos containing products manu factured at this plant during the last five calendar years: . 1971 $ 1972 $ 1973 $ 1974 $ 1975 $ ____,______________ ' 5. What was the level of capita? expenditure for plant improvement and expansion of production facilities for asbestos containing products during the last five cafendar years? (include capital expenditures for environmental control, plant improvement and expansion). 1971 1972 1973 1974 1975 S __________________ S __________________ 5 $ $ " ' 6. What is the: total plant employment at this location? 7. Give the .approxfmate percentage of the employees whose asbestos exposure falls in the following categories: a. handling personnel) b. Frequently in the w< personnel) __________ c. (management, engineers) d. Never or very infrequen sales personnel) _______ 3. What unions (locals) represent your employees. If any? a. How active have the unions been in the area of employee health and safety (demands for hazard pay, shorter work periods, etc.)? Active Area Extent of Activity (V--Very, M--Moderate, N--None' b. What is the current pay scale range of unionized personnel? CONFIDENTIAL Company Code # -3- Plant Code # 03114773 HU8B-00067W t BWBB-0006745 v=3 K5 4. What was the aggregate sales value of asbestos containing products manu factured at this plant during the last five calendar years: 1971 1972 1973 1974 1975 $ $ $ $ $ 5. What was the level of capital expenditure for plant improvement and expansion of production facilities for asbestos containing products during the last five calendar years? (Include capital expenditures for environmental control, plant improvement and expansion). 1971 1972 1973 1974 1975 $ __________________ $ $ $ $ ' 6. What is the* total plant employment at this location? ___ 7. Give the approximate percentage of the employees whose asbestos exposure falls in the following categories: a. Continually in the work environment (operating, production, materials handling personnel) b. Frequently in the work environment ( maintenance, supervisory Dersonnel) c. Only occasionally (less than 5 times per week) in the work environment (management, engineers) d. Never or very infrequently enter the work environment (secretaries, sales personnel) 8. What unions (locals) represent your employees, If any? a. How active have the unions been in the area of employee health and safety (demands for hazard pay, shorter work periods, etc.)? Active Area Extent of Activity (V--Very, H--Moderats, N--None) b. What is the current pay scale range of unionized personnel? CONFIDENTIAL Company Code * _____ -3- Plant Code # _______ 03114774 r MMBB-00iJ67<i6 '<0 v=3 d. Did this equipment increase or decrease the plant/process energy requirements (electrical power, space heating, etc.)? Increase Decrease _____ By how much? _________ 12. What process modifications or work practice changes, if any, were instituted to reduce worker exposure to asbestos? _ a. Capital Cost (installed) $ __________________ b. Operating Cost (annual) $ c. What effects have these process modifications or work practice changes had on your process, product, or production rate? _____ d. Did these process modifications or work practice changes increase or decrease the plant/process energy requirements? Increase _____ Decrease By how much? 13. Have the Control equipment or work practice changes reduced air borne asbestos levels in all of the work areas? Yes No List the ranges of asbestos fiber counts in the work areas involved: Work Area, __________Range of Asbestos Fiber Counts Before Modifications/ After Modifications/ _______ Changes__________ _______ Changes -.3 14. Have the control equipment or work practice changes reduced airtime-weiqhted average exposure to airborne asbestos in all of the work areas? , Yes _______ No ____ CONFIDENTIAL Company Code # -5" Plant Code f* 03114775 KHfifi-0006747 Work Area Range of TWA Asbestos Fiber Counts________ Before Modifications/ After Modifications/ Changes _______ Changes i The present asbestos standard sets a maximum allowable Time-Weighted Average (TWA) exposure of 5 fibers/cc over an 8-hour period. This, by statute, will be reduced to 2 fibers/cc in July, 1976. The proposed standard would reduce this level to 0.5 fibers/cc at some time in the future. If you have already reached 0.5 fibers/cc at each step where asbestos is released into the work place, please go on to Part III; if not, please complete the following; 15. At each location where asbestos dust is released, do you feel you have installed the "8est Available Technology?,s Yes _____ No _____ Best Available Technology (BAT) is defined as control equipment, process modifications, work practice changes, or combinations thereof, which have been demonstrated to provide the most effective control or reduc tion of contaminant emission. 16. If not, what do you consider the BAT to be, and how effective will it be in reducing airborne asbestos at each location? (Can be control equipment, work practices, process modifications, or combinations thereof). Locations Estimated Asbestos 8AT Fibers/cc______ CONFIDENTIAL 03114776 Company Code ft -6- Plant Code # r O T m lb B P 5 L M S H U B 8-U U 06M 8 17. What is the expected cost of 8AT in terms of: a. Capital Cost (installed) $ ______________ b. Operating Cost (annual) $ _________________ c. Piant/Process Energy Requirements, Increase _______________ _ Oecrease _____ d. Personnel Requirements, Increase _______________ Decrease e. Process/Product Effects, Increase $ Decrease $ Explain _________________________________________________ ;______ - f. By what date could BAT be implemented? 18. If the Best Available Technology does not reduce worker exposure to a TVA of 0.5 fibers/cc and a ceiling of. 5 ftbers/cc at all points, provide your considered judgment on the possibility, cost, and timing to develop new technology to achieve this level. 'What approach might be used? ________ _____ ____________ __________ ________________________ ______ 19. If the proposed 0.5 fibers/cc level is adopted, what action is foreseen at your plant? ____________ 351 .. j III. Industrial Hygiene and Health information ' 20. The existing and proposed standards require certain industrial hygiene practices where workers are exposed to airborne asbestos below the established TWA or ceiling levels. Do you (provide cost data where avaliable) : Cost/ Total Plant yes No Man-Year Cost/Year a. Provide preplacement employee medical exams? b. Provide annual employee medical exams? c. Provide termination employee medical exams? CONFIDENTIAL -7- Company Code # Plant Code # 03114777 r s=3 L--U Mil--- u a & -3 *5< Yes No Cost/ Total Plant Man-Year Cost/Year d. Retain medical records (20 year period)? e. Maintain records of employee exposure to asbestos fiber (3 year period)? f. Dispose of waste materials which may contain asbestos in sealed containers? g. Provide caution labels for all material containing un bound asbestos? h. Provide initial monitoring (sampling) of the work place for airborne asbestos? i. Provide periodic monitoring (sampling) of the work place for airborne asbestos? 21. Certain provisions of the existing regulation require additional indus trial hyg.iene practices where levels of airborne asbestos exceed TWA of ceiling standards. Where these requirements apply to your plant, do you: Cost/ Total Plant Yes No Man-Year Cost/Year a. Wave a respirator program (for use in certain work situations or emergencies)? b. Provide worker rotation where employee is unable to func tion normally while wearing a respirator? c. Provide protective clothing (for employee exposed to asbestos greater than the ceiling 1evel)? d. Provide change rooms (where special clothing is required? e. Provide separate locker facilities (where special clothing is required)? f. Provide laundering of special clothing? g. Post caution signs (where levels are greater than the ceiling or TWA levels)? CONFIDENTIAL -8- Company Code Plant Code n 03114778 0UfiB~0006750 <7=3 22. Oo you employ a company physician? Yes ______ No If yes: Full-Time ; Part-Time _________ __ Part-Time hours/ week _______ 23. Do you employ an industrial hygienist? Yes ____ No _____ If yes: Full-Time ; Part-Time Part-Time hours/ week 24. Who performs your medical examinations (clinic, resident physician, etc.)? 25. The proposed standards expand the scope of industrial hygiene practices into areas such as: shower requirements, regulated areas, expanded respirator programs, and employee education programs, in general, how do you believe your employee will j;eact to such practices? IV. Economic Impact Information 26. Considering individually the major products manufactured at this location, has implementation of asbestos exposure control procedures and industrial hygiene programs affected the cost of these products? Yes ____ No _______ . If yes, specify: Products Implementation Cost, S/Unit of Production Increase Decrease ^ rS ---------------- ' ----------- --------------- ---- 27- Have you .experienced a shift or change in product sales due to the cost impact described in Question 26? Yes _____ No CONFIDENTIAL Company Code # -9- Plant Code # 03114779 i NUBB-08B6751 Li--J m a. If yes, specify: Products i .________ Sales Change, $/Year_________ _ Increase Oecrease b. if sales have decreased, has the demand been satisfied by: Yes Other Asbestos Products ____ Asbestos Substitute Products ___ Imported Asbestos Products __ No __ __ __ c. Which of the above has had the greatest impact on your sales? 28. Considering individually the major products manufactured at this location, do you expect the future implementation of SAT control procedures and expanded industrial hygiene programs to affect the cost of your products? Yes _______ No If yes, specify: , Products Imp 1ementation Cost, S/Unlt of Production Increase ' Oecrease CONFIDENTIAL Company Code # 10- Plant Code # 03114780 MUBB-B006752 ^=3 29. Would you expect to experience a shift or change in product sales due to the cost impact described in Question 28? Yes _______ No . a. If yes, specify: Products ____________ Sales Change.1 S/Year Increase Decrease b. If you exoect a sales decrease, will the demand be satisfied by: 1 Yes, No Other Asbestos Products __ ___ Asbestos Substitute Products __ ___ Imported Asbestos Products __ __ c. Which of the above would you expect to have the greatest impact on your sales? ________________________________-- 30. What is the typical age of production equipment in use at your plant in your particular industrial segment? Segment ________ Typical Production Equipment Age, Years 0-5 5-15 / 15 - 25 Z5+ 31. In your opinion, with the implementation of BAT and the proposed OSHA standard to control worker exposure to asbestos, what portion of the sJ existing production equipment may continue to be economically utilized? (Consider the portion of capital equipment retained as a percentage -J of the total production area investment). CONFIDENTIAL -II- Company Code " Plant Code # 03114781 HJJBfi-0006753 *T Less than 10% ____________ 10 - 25% ____________ 25 - 50% ____________ 50 - 75% ____________ Greater than 75% _______ 32. Within your community, which estimate best describes the portion of the total work force employed at your plant? Less than 10% 10 - 25% 25 - 50% 50 - 75% ____________ ____________ ____________ ____________ V. Information Regarding Manufacturers/Fabricators of Asbestos-Containing Products The proposed regulations apply to every place of employment where asbestos, or a product containing asbestos, is manufactured, processed, packaged, stored, applied, ysed, or otherwise handled. It Is extremely important to our assessment to1 include estimates of the number of people involved as your products are ultimately used and the possible asbestos exposure levels of these individuals. Insofar as is possible, kindly provide the following information: 33. Who uses the asbestos-containing products you produce (construction industry, auto repair garage, fabricator, etc,)? 34. Describe how your products move from your plant through the final con sumer _____ 35. Estimate numbers of people and what levels of asbestos dust exposure, if any, may occur at each step (from further processing, fabrication, installation, etc.)? ___________________________________ CONFIDENTIAL -12- Company Code # _____ Plant Cede # 03114782 KHBB-0006754 ^ 36. Provide names of your customers and appropriate trade association so that Weston might obtain more comprehensive information in these areas i CONFIDENTIAL / -13- Company Code # Plant Code # 03114783 r