Document Yjo5x39Dzo789Mz0Op23ropKO

FILE NAME: Ford (FD) DATE: 1973 May 29 DOC#: FD058 DOCUMENT DESCRIPTION: Memo - Asbestos Fiber Air Sampling-Arizona Proving Grounds with Data Sheet iq73 JUTi 1 fln 7 : n 7 1 Inter O ffice. May 29, 1973 Personnel and Organization Staff Mr. J . A . K e lle r Personnel Services Supervisor General Services D ivision ce M. A. H arris, M.D. S . M. Luke P . R. Veazey Su b ject: Asbestos Fiber A ir Sampling - Arizona Proving Grounds The Department o f Labor, under the authority o f the Occupational Safety and Health Act o f 1970 (OSHA), in Section 1910.93a o f the Federal Register dated October 18, 1972 has promulgated occupational health standards in relatio n to the use o f asbestos and asbestos laden m aterials. In response to these standards, in d u strial hygiene studies were conducted on A p ril 25-26, 1973, at the Arizona Proving Grounds to determine employe exposture to airborne asbestos fib e r . Results o f a ir samples taken and instrumentation used are attached. c Employe exposure a t the Arizona Proving Grounds to asbestos fib e r emanate from brake rebuildin g, pipe covering, and truck noise suppression te stin g . General plant v en tilatio n is the only engineering control used fo r these operations. Approved 3M, No. 8710, disposable respirators are used during mixing o f asbestos mud fo r the truck noise suppression, but respirators are not worn during brake rebuilding or pipe covering. Pipe covering and in su lation work is a normal maintenance operation. The amount o f pipe covering and insulation work is wHn-tmai and on a sporadic b a sis. I t should be noted, that management at the f a c ilit y was not aware o f the in d u stria l hygiene le tte r pertaining to proper procedures to be employed when using asbestos pipe covering or in su latio n . A copy o f th is le tte r is enclosed as part o f the Plant Engineering le tte r attacned. The truck noise suppression project being conducted at the fa c ilit y uses dry asbestos fibers' to make mud which is applied to the truck engines that are then covered with fib e rg la s , sheet lead, and f o i l . The in it ia l part o f th is p ro je ct, which included covering the engines, was Ju st being completed. The next phase o f the project involves driving the trucks for several m iles, and then removing coverings from various engine components to determine the relative contribution each engine component makes to the to ta l noise le v e l. During the removal phase o f the p ro ject, asbestos fib ers may become airborne and create a lim ited employe exposure varying in in ten sity with the method o f removal. Brake rebuilding o f disc and conventional brakes on cars and trucks is done as part o f the brake testin g program and as routine maintenance. There is no set pattern to the type o f brakes and vehicles involved, or to the frequency of the reb u ild s. The frequency of rebuilds during our v is it was three per week, 8004 0968 Mr. J . A. Keller May 29, 1973 Page 2 but could go as high as 20 per week. Dust evolves from dropping wheels from the veh icle and blowing o ff brake assemblies and drums. The p o licy o f lo c a tio n is not to permit blow o ffs , but employes fin d i t necessary to blow o ff truck brake assemblies and drums. ' The provisions o f the QSHA asbestos standard enua*rated in Section 1910.93a o f the Federal R egister applicable to employe asbestos exposure a t the Arizona Proving Grounds are: 1. A Threshold Lim it Value (TLV) o f fiv e fib e rs greater than fiv e microns in length per m illilit e r o f a ir , and a c e ilin g concentration o f 10 fib ers greater than fiv e microns in length per ml o f a ir . The TLV w ill be reduced e ffe c tiv e Ju ly 1 , 1976 to two fib e rs greater than fiv e microns in length per m illilite r of a ir . ' 2 . Local exhaust v e n tila tio n o f to o ls and processes i f airborne fib e r concentra tion s exceed the TLV or c e ilin g concentration. . 3 Sp ecial work p ractices such as wet methods and iso la tio n i f airborne fib e r concentrations exceed the TLV or c e ilin g concentration. h . Approved respirators varying with the in te n sity o f the exposure s h a ll be used when spraying, removing or demolishing equipment or structures covered with asbestos or asbestos laden m aterials. 5 Sp ecial clothin g and change rooms must be furnished employes exposed to asbestos concentrations exceeding the c e ilin g concentration lim it. 6. Sp ecial clothing furnished must be co lle cted in sealed containers and labeled per lab elin g sp ecificatio n s stated in subparagraph ( i i ) , page 221M+, of the Federal R egister. In ad d ition , the laundry must be made aware o f the asbestos hazard. 7 A ir samples must be co llected representative o f employe breathing zone ex posure a t in terv als no greater than every s ix months i f the TLV or ce ilin g concentration lim it may be expected to be exceeded. 8. I f a ir samples taken indicate exposures greater than prescribed lim its , then caution signs must be posted per pages 221^3 and 22lkk subparagraph g o f the Federal R egister and the area must be cordoned o ff . 9 . Asbestos or asbestos laden waste m aterials must be cleaned by vacuum and disposed o f in sealed containers and labeled per labeling sp ecificatio n s stated in subparagraph ( i i ) , page 221U4 o f the Federal R egister. 10. Employes exposed to concentrations o f asbestos fib e r exceeding prescribed lim its must be n o tifie d in w riting o f the exposure and corrective action contemplated within fiv e days o f the fin d in g . 8004 0969 Mr J . A. Keller May 29, 1973 Page 3 r\ v_ ' U* Sha3i pr0vlde or aake av ila b le medical examinations to _^e . ^ exPcec^ ^0 concentrations exceeding prescribed lim its 3ha11 include a pre-employment, annual and termination examination consisting o f p osterior-an terior I t x 17 inches chest roentgenoeram ffoorTcceld'de^xp^iXra7-thoTrUyaCvtolluDm` eteaSttSont0e sineccolunddeRfEoVr.cedin vaidt adliticoanp,acaithy isJVtoCryandto previous exposure to carcinogens and smoking should be obtained. R esults o f the a ir samples taken during our studies indicated an overexoosure to ^he. ^ei1 fib e rs greater than fiv e microns in length per ml o f a ir c e ilin g concen- ration lim it prescribed by GSHA. This a ir sample was taken during blow o ff o f itto d xm . ^ assem blies. The time elgbted a v e rse m S tH * employe, who was performing brake rebuilding on tru cks, was also s ig n ific a n tly greater than employes performing brake rebuilding on passenger vehicles The m itigatin g facto r is blow o ffs are not p e r f o r ^ d u r in T p a s f e L ^ M c ie S L * S S t? ' * flb e r e^ 5u" ls 1 O Based on the resu lts o f our stud ies, i t is our opinion that the follow ing are required to comply with OSHA standards and to protect employe health 1. A ll blow o ffs o f brake drums 'and assemblies should be s tr ic tly prohibited. A review o f current lite ra tu re indicates th at vacuuming with a brush attachment is a suitable altern ative from the standpoint o f dust fiber control and does not m aterially hi nder the brake rebuilding operation. I f a portable vacuum is used, a high e fficie n cy f ilt e r should be employed on the a ir discharge. 2 . A ll waste m aterials which may contain asbestos should be cleaned up by vacuum and disposed o f in properly labeled sealed containers. 3 . The employe who was found to be exposed to asbestos fib e r concentrations in excess of the ce ilin g concentration lim it prescribed by OSHA should be n o tifie d in w riting as stated in Mr. P. E . Toth's le tte r o f May 16, 1973. k . Employes whose Job description includes brake rebuilding on heavy trucks should be given an immediate medical examination meeting the requirements sp ecified by OSHA. 5 . U n til a substitute is found fo r the blow o ff procedure performed during truck brake reb uildin g, respirators approved under schedule 21 and sp ecial clothing sp ecified by OSHA should be worn by employes performing truck brake rebuilding Other procedures prescribed by OSHA re la tiv e to sp ecial clothing must also ' be follow ed. 6. Hie single use respirator used during asbestos mud mixing fo r the truck noise suppression program should also be used when removing asbestos from engine components which have completed te stin g . 8004 0970 EC * Mr. J . A. lieH er May 29, 1973 o Page If 7 ' vorfc area o f the truck must be co- rdoned o f f . 7 8 . Plant Engineering L ette r No. 28, dated A p ril 11 107-5 .a,.,-* , In d u strial hygiene standard la n d lli covering and In su la tio n , should he U l s s e S S l ^ d S e S ? "s ** , plie pFoelrlioowd-iucpami ronsaitmorpilninggwreilqlubireemcoenndtsucotefdOdSHuAri.ng October 1973 to comply with the Industrial Hygienist In d u strial Hygiene Section Employe Health Services Department ms Attachments (3 ) -* 8004 0971 Dat(Zohcet #1 Arizona Proving Grounds Asbestos Location 0S11A Asbestos Threshold Limit Value (TLV) " " TLV e ffe c tiv e Ju ly 1 , 1 9 7 6 ' " " Celling Limit 1. Truck noise suppression operation - employe D. S h a e ffe r, SS #78oQ - breathing zone a ir samples (B .Z.) - employe wearing approved 3M respirator o Concentrations o f Fibers Greater than 5 Microns jn_ I^ngth/Ml, i i i i l t e r o f 5 2 10 a) Mixing asbestos mud, dry asbestos into a p a il - peak concentration determination obtaining and returning m aterials, carrying baa o f asbestos, and cleaning up - time weighted average determination 8 2 . Passenger vehicle brake rebuilding - conventional brakes employe G. Chambers, SS #512** - B.Z. - respirator not worn. a) Dropping wheels, tear down and rebuilding - time weighted avg. determination b) Tearing down brakes and wiping out drums - peak a ir concentration " c) Mounting wheels - < < ,, 3- Passenger vehicle brake rebuilding - disc brakes on a l l * wheels employe G. Chambers, SS #512* - B.Z. - respirator not worn. a) Dropping wheels, tear down, and obtaining m aterials ' " " " ` I*5** a11, concentration determination c) Micrometer measurements and rebuilding d) " < 11 Calculated time weighted average concentration 0.1 0.9 0.3 0 . 1* 0.5 0.2 0.1 0.1 0.1 0.13 8004 0972 I C O Data Sheet #2 Location L o u isv ille 750 truck brake rebuilding - conventional brakes employe P. V asilev ak i, SS //9799 (B. Z.) - respirator not worn. a) Dropping vfaeela and te ar down b) Bloving out drums, tear down, and obtaining parts c) " " " - peal; a ir concentration determination d) " Calculated time weighted average concentration 5 L o u isv ille 750 truck brake rebuilding - same operation as item Mo. 4 general a ir sample O Concentrations o f Fibers Greater than 5 Microns in L en gth /M llllliter nr n - 0.2 3.1 1.6 12.2 1.2 0.1 Instrumentation: Mine Safety Appliances Model G Pumps with Mi111pore Type AA Membrane F ilte r s 0.8 micron pore size A nalysis: U30X Riase Contrast Microscopy by Environmental Health Laboratories, Farmington, Michigan 8004 0973 T O : Plant Engineers, All Plants Division Plant Engineers Plant Managers General Manufacturing Managers CONTENTS SECTION A: G E N E R A L INSTRUCTION!; AND IN FO R M A TIO N No Subjects Included SECTION B: MAINTENANCE INFORM/ TION Asbestos Pipe Covering and Insulation Standard Handling Procedures - Industrial Truck Maintenance Control System Fire Loss Analysis 1972 SECTION C: ENGINEERING AND CONSTRUCTION No Subjects Included L E T T E R NO. 28 April 11, 1973 Page M-201 M-202 Complete R. F. Birdsall, Manager Maintenance Department Plant Engineering Office 8004 0974 >> i rs P LA N T EN G IN EER IN G L E T T E R MO. 28 April 11, 1973 A SD ESTO S PIPE CO V ER IN G AND INSULA ION - STANDARD HANDLING PRO CED U RES j The Federal Department of Labor under the jauthority of the Occupational Safety and Health Act of 1970 (OSHA) has promulgated specific standards for the use of asbestos. i' J Pipe covering and insulation materials may cqintain asbestos, particularly in older Installations, A Plants considering new pipe covering and insulatiion projects should investigate other non-asbestos materials such as calcium silicate and fibergla$5. The attached letter recommends procedures to be followed in plants using asbestos pipe covering and insulation to avoid potential health hazard to employes and to be In compliance with OSHA regulations. Attachment M 201 8004 0975