Document YZKbL7NMGXG55gVeojVpZD7O

Uied, Mar 21. 1990 3:47 PM PROCEDURES FOR ASBESTOS BLANKET ADMINISTRATION PLAINTIFF'S EXHIBIT ST0093508 Typically takes 4 to 5 weeks EMERGENCIES: Project that exceed the 10 Lnft. or 15 Sqft. or both resulting from equipment failure or malfunctions ere exempt from the 10 day notification. The contractor must phone the Michgan Department of Public Health as soon as possible after the discovery of the emergency during regular working hours. OFF WORKING HOURS NOTIFV UIITHIN 48 HOURS AIR CLERRRNCE: Rll contractors performing asbestos abatement work on the premises of another person, must assure that a post abatement clean air check Is performed at the completion of all friable asbestos projects. f Contractor's responslbllty Dow's responsibility Dow or Contractor's responsibility tls Procedure to follow^ 1( a Person has a possible exposure to a triable Asbestos Containing Material (ACM) ST0083509 yas 1 BMa Owner tar Oumefa Real Dial 123 tor ambuianoe (report as a posable asbestos exposure.) (Site Cleanup Redons) Bidding Pwnat.tef-PtmBi'.s Rea) Follow toe appropriate procedure to have an Asbestos Abatement Contractor perform the cleanup tis. n.tw. IlflUO IJ/SIIO Person -Get in the nearest safety shower with clothes on, shower, and remove clothing. -Put on dothes supplied by EMS as Transport person to Medical Medical -Shower person as required -Perform exam as required Send wet clothing to Dow Laundry Provide appropriate medical into to person's supervisor Person's Supervisor Write incident report and distribute as required -Advise Legal ol the Incident.___________ Emergency medical support (EMS) provide protective clothing Dow .Laundry" Launder clothes and send bach to person__________________________ MARCH 7,1989 PRO'S SCON'S 1. DOW IS ABLE TO REMOVE 260 LINEAR FT. OR 160 SQ. FT.OF ASBESTOS WITH OUT MAKING NOTIFICATION TO THE EPA OR DNR. THIS WOULD BE BENEFICIAL FOR EMERGENCY AND ROUTINE RENOVATIONS WHERE ASBESTOS IS NOT READILY NOTICEABLE BEFORE RENOVATIONS ARE STARTED. 2. CON'S IF CRAFTSEVICE'S HAD PEOPLE TRAINED TO REMOVE ASBESTOS FOR EMERGENCY AND UNFORESEEN RENOVATIONS. IT WOULD BE HARD TO CONTROL. CLIENTS WOULD EXPECT CRAFTSERV1CES TO SUPPLY THAT SERVICE TO THEM ALL THE TIME. (JOB PLANNING WOULD STOP) MOST OF NOTIFICATIONS THAT THE CONTRACTOR MAKE TO THE DEPT. OF PUBLIC HEALTH ARE LESS THAN 260 LINEAR FT. OR 160 SQ. FT. ST 0003510 3. POST ABATEMENT AIR MONITORING FOR DOW EMPLOYEES REMOVING ASBESTOS WOULD BE AFTER 25 LINEAR FT. OR 50 SQ. FT. EACH CLEAN AIR SAMPLE AND RESULTS COST APPR. 500. DOLLORS. EACH REMOVAL REQUIRES A POST ABATEMENT CLEAN AIR. ST00835I I Craft Services Asbestos Gasket Removal & Disposal The following describes an interim action plan for asbestos gasket removal and disposal until Industrial Hygiene's division wide plan is approved and distributed. GENERAL A. All Craft Services personnel who may be involved with this type of work need to know the proper procedure for disposal of the gaskets, whom to contact, where to obtain the asbestos disposal bags, etc. B. Asbestos abatement persona! monitoring is required for all planned or scheduled Line/Equipment Openings (LEO) involving asbestos gaskets. The foreman planning the work is to contact Industrial Hygiene to arrange for the personal monitoring. C. If a Line/Equipment Opening is being performed without the asbestos abatement personal monitoring and asbestos gaskets are discovered, the work should stop and not be resumed until personal monitoring has been established. GASKET REMOVAL A. Dow craftsmen may remove asbestos gaskets which remove easily from the pipe or equipment flange. No scraping, filing, or wire brushing of the gasket or flange with gasket debris is permitted. B. If the gasket, or any part of it, is adhered to the flange, the removal must be performed in a manner that protects personnel from potentially friable asbestos. This gasket removal work is to be done by one of the approved asbestos abatement contractors using the proper removal and cleanup procedures. Dow personnel should use one of the following methods to arrange for the contractor to do this work: a. If during normal working hours (8:00AM to 4:30PM, Monday to Friday), contact the abatement contract administrator at extension 6-5448 (Pager 835-0499). b. If after normal working hours and the work must be continued, contact the oncall Industrial Hygienist through their pager (139-0408). They will contact security to activate the emergency off hour release procedure (attachment 1). C. The gaskets shall be disposed of as described in the attached (attachment 2) Disposal of Asbestos Gaskets document. The organization or company removing the gasket shall dispose of the gasket. June 25,1990 ST00835 12 Craft Services Asbestos Gasket Removal & Disposal The following describes an interim action plan for asbestos gasket removal and disposal until Industrial Hygiene's division wide plan is approved and distributed. GENERAL A. All Craft Services personnel who may be involved with this type of work need to know the proper procedure for disposal of the gaskets, whom to contact, where to obtain the asbestos disposal bags, etc. B. Asbestos abatement personal monitoring is required for all planned or scheduled Line/Equipment Openings (LEO) involving asbestos gaskets. The foreman planning the work is to contact Industrial Hygiene to arrange for the personal monitoring. C. If a Line/Equipment Opening is being performed without the asbestos abatement personal monitoring and asbestos gaskets are discovered, the work should stop and not be resumed until personal monitoring has been established. GASKET REMOVAL A. Dow craftsmen may remove asbestos gaskets which remove easily from the pipe or equipment flange. No scraping, filing, or wire brushing of the gasket or flange with gasket debris is permitted. B. If the gasket, or any part of it, is adhered to the flange, the removal must be performed in a manner that protects personnel from potentially friable asbestos. This gasket removal work is to be done by one of the approved asbestos abatement contractors using the proper removal and cleanup procedures. Dow personnel should use one of the following methods to arrange for the contractor to do this work: a. If during normal working hours (8:00AM to 4:30PM, Monday to Friday), contact the abatement contract administrator at extension 6-5448 (Pager 835-0499). b. If after normal working hours and the work must be continued, contact the oncall Industrial Hygienist through their pager (139-0408). They will contact security to activate the emergency off hour release procedure (attachment 1). C. The gaskets shall be disposed of as described in the attached (attachment 2) Disposal of Asbestos Gaskets document. The organization or company removing the gasket shall dispose of the gasket. June 25,1990 ST0083513 ASBESTOS GASKET REMOVAL PROCEDUBE Rev. 1 6/25/90