Document Yr539NE1agJeQzXDzaxmR3BXn

.FRICTiON MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N.J. 07652 BULLETIN ,/~ ~--- N 0. 478 June 14, 1973 Subject: ASBESTOS STUDY COMMITTEE ACTIVITIES At the June 1, 1973 meeting of the Asbestos Study Committee, it was recommended that the following information be distributed to the Membership. 1. OSHA Labeling Reguirements 2. In-plant CAUTION Sign (W. H. Brady Co.) 3. EPA Emissions Standards - A Discussion OSHA LabelinP Requirements Attached is Exhibit I, a display of four different OSHA CAUTION labels. One is with a gummed backing to attach to packaging. Another is in the form of a tag. Others are imprinted on the cartons or boxes when purchased from the box manufacturer. The Committee adopted a resolution at an earlier meeting which essentially recommended that Members obey the law. That resolution stated: That (1) where asbestos containing materials do not have their asbestos fiber completely locked in, or (2) where subsequent operations may b.e performed on asbestos containing materials, the hazardous labeling practice be adhered to in accordance with the Label Specifications in the OSHA Standards for Exposure to Asbestos Dust. The Committee has decided to make no recommendations on style, m1n1mum dimensions, etc. It recommends that the manufacturer comply with the requirements of the act, demonstrating "good faith" in their observation of the requirements. In other words, printing a miniature CAUTION label on the bottom of a large box would not be demonstrating "good faith;." According to the Standards the labels "shall be printed in letters of sufficient size and contrast as to be readily visible and legible." ln-olant CAUTION sipn (W.H.Brady Co.) Enclosed also is a copy of a letter from the W.H.Brady Co., Milwaukee, Wisconsin, to which we've added a CAUTION sign as manufactured by the Brady Co. This sign conforms to the requirements of the OSHA Standards. Several Committee members feel the cost of these signs is attractive. See Exhibit I I D--- ~ rx) FMSt 06659 - 2- EPA Emissions Standards- A Discussion At this recent Committee meeting, the new EPA Emissions Standards were discussed. As there were several different interpretations by Members and Regional EPA personnel, a digest of the minutes of the meeting are enclosed. It will be noted that there are different interpretations concerning several items: (1) 11 new source11 versus "existing source," (2) whether to quantify machines under "Process Description, 11 and (3) whether 11 Amount of Pollutant" - if given total into each Process- will then be construed as being 5 to 10 times the total asbestos entered into the process. See Exh i hit I I I. aiD/ere Enclosures: To: Active Members Regional Members E. W. Drislane Executive Director FMSl 06660 , FRICTION MATERIALS STANDARDS INSTITUTEt INC. CAUTnON Contains Asbestos Fibres Avoid Creating Dust Jreattdng Asbestos Dust Pv1ay Cau5e Serious Bodily Harm .. CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM Contains Asbestos fobers Avoid Creating Dust Breathung Asbestos Dust may cause serious Bodcly Ciarm CAUTION Contains Asbestos Fibers .__) Avoid Creating Dust Breathing Asbestos Dust May Cc:.use Serious Eot!ily Harm (AUT tO 1\J LAI2ElS - ASt?fSTOS eeo~I.ICT.S E l' H 18 tT X ' FMSI 06661 ,y H UIII\DY CO 7'27 Westl Glenclalri Avo. Mllwz.~ukec, Wif,J. 532P1 lst. 1914 Phone [414) 332-8100 T!3lax 26-677 Teletyp'a 810-262-(3151 Oabla Bradyco Attention; Plart Engine~r Dear Sir: As a s~pplier of asbestos materials to industry and commerce we thought you'd like to know Brady has asbestos hazard signs in stock, ready for immediate shipment. The sign complies in color, and size and wording with OSHA 1910;93a(g). A repro~ duction of the ~ign is attached. Stoc~ #CAU-PP-11-5 signs are m~do of non-corrpsive, non-con. ductive Brady B-450 linear polyethylene. The contrasting color black and yellow signs can be used indoors or out:doorR and have built-in ultraviolet light i,nhibiter for long life. The~ are mechanically mounte4 with fasteners. ' TheRe 14''x20" tough, durah ln signs a te priced n t $3. 99 on. (10-10 qu;mtlty) and $3.79 each in 50-99 quantities, F:Cl.'B.Milwaukee, Wise. or from aQy Brady D~stributor listed on the enclosed sheet." A oopy of our latest catalog MS-520 is also enclosed for your review qf OSHA marking requirements. Wo l0ok for~ard to receiving orders for your OSl~.marking needs. Yours truly, ASBESTOS DUST NAZARD W. H. BRAUY CO. j=>)JJJT-- P. G. Gengler Sales 1'1anager Industrial Products Divi~ion AVOID BREATHING DUST WEAR ASSIGNED PROTECTIVE EQUIPMENT DO NOT REMAIN IN AREA UNLESS YOUR WORK REQUIRES IT BREATtiiNG ASBESTOS DUST MAY BE HAZARDOUS TO . YOUR HEALTH !il\\.1 l.:o l.ltT'ii.;Ll\1 f)Ct+t.S..I.._T.':lL~ FMSI 06662 fRIGTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N.J. 07652 EPA EMISSIONS STANDARDS FOR ASBESTOS- A DISCUSSION The following comments are digested from a June 1973 discussion of an Asbestos Study Committee meeting at the Institute. These comments may be of some interest to those filing the EPA Source Reports. While the new EPA emissions standards appear to be reasonable, there is some difficulty in interpretation. For example, the standards are not simply "No visible emissions," but (1) there could be no visible emissions even if they do not meet the air cleaning requirements, or (2) one could even have visible emissions if they were using a collector with the specifications recommended by the EPA. In other words, if you have the EPA's recommended collector you could possibly have visible emissions and still be complying with the EPA requirements. It goes with- out saying, that interpretation of the requirements by individuals in the different EPA regions may vary quite a bit. The EPA is saying in their Standards that the wet collector is not as efficient as the dry-bag collector. If an EPA Enforcement Officer sees a vapor from the stack where a wet collector is used, the source best be able to prove there is no asbestos being discharged. In other words, it can be inferred that if a source has wet collectors they may more likely be cited for visible emissions. While it is apparent that the EPA's emissions standards promote the dry collection of asbestos in bags, many problems have been indicated with these collectors. One of the problems was repeated fires in the collection system. Another member stated that he too had this problem until. cigarette smoking was banned in the factory. Since discontinuing smoking in the factory, he claims they have not had more than one or two fires in the last 25 years. Another member said that may be, but they have had the No Smoking rule for many years and they still have fires. This party blames the fires on the incentive program where the workers receive a bonus for exceeding certain work standards. This promotes the taking of heavier cuts with grinding wheels and creates sparks which apparently promote the fires in the system. The op,eration that has not had any fires for the past 25 years does not have an incentive system and does not permit smoking in the work place. Where the wet collectors are now in use, apparently the EPA is permitting their use as complying with the requirements. At this point, the disposal of the materials picked up by the collectors was brought up. One member sent the dust to a pelletizing machine. In this process they add 51o-10% cement to the pelletizer. A volume reduct ion in the order of 3 to 1 was developed. The pellets are taken by truck and dumped as land fill. While the pellets could be broken down into a powder, if they receive reasonable handling they can be readi 1y moved frpm the pelletizing machine to the land fi 11 ?perat ion. It is this member's intention to install a vacuum syslem from the collecting areas to go to a central pelletizing machine. One member described his handling of dust from (1) a central collector, to (2) a screw conveyor, to (3) a truck, and to (4) the land fill. The workers in this case use respirators. The pelletizing operation not only reduces the transportation cost by three times but eliminates the need for the watering truck and an individual to wet down the land fill. However, the costs of this pelletizing equipment are substantial. A manufacturer of pelletizing equipment is Ferro Tech Inc., 1231 Banksville Road, Pittsburgh, Pa. 15216. EXHIBIT t II FMSI 06663 - 2- ' Several members mentioned that in dealing with the EPA Regional Offices they were having difficulties deciding what was a 11 new source" and what was an "existing sourc~ 11 Also, where one manufacturer adds one machine to an existing collection system he may not be in compliance without getting a Waiver of Compliance. Apparently the EPA will not give a Waiver of Campi iance that will take more than 12 months to complete. An applicant must give the steps to be taken and the schedule to be met. When each date arrives, the applicant must advise EPA concerning completion of that stage of the schedule. One member felt that we should review the EPA source report form to get a better understanding of what they were calling for. Page one of the report would be used for each factory. As there would most likely be several points of emission, page 2 would be completed for each stack or collector that emits asbestos. If a manufacturer wished to make an addition or modification in his plant withequipment that might put asbestos into the atmosphere, he must file with the EPA. On page 1 of the report he would cross off the words "Source Report" and type in either "Application to Construct a New Source," or Application to Modify Existing Source." In reviewing page 2 of the report under "Process Description," some questions came up as to how to complete this section. One member who had worked on this report with the EP'A said you should enter here the type of machinery used without quantifying. Another member indicated that the EPA insisted that he list the type of equipment and the numbers of each piece of equipment. If the EPA specifically said to list the numbers and types of equipment in this section it was suggestedthat they would have said so on page 2 of the report. The question of put- tingdown the numbers and types of equipment could become very cumbersome where a manufacturer wished to move a grinding machine from a location with one collector to another location where it would be hooked into another collector. The member who filed with the EPA worked on reports in 2 different jurisdictions: New York and Tennessee. He indicated that at neither location did he enter the number of pieces of equipment on this form. (Since the meeting he called to advise that the application filed in Tennessee without quantities was accepted by the EPA. His application in New York State had not been either accepted or rejected as of June 4, 1973.) It would appear that Regional Offices are not in agreement as regards quantification of the equipment under the "Process Description." The question came up concerning interpretation of question 3, the 11 Amount of Pollutant."' In many factories a set of dry mix brake blocks could emit into a collection system at the mixer, at the briquette press, at the cut-off wheels, at grinding, at drilling, and at inspection and boxing. The problem is that this is the same original asbestos which entered the process and might be counted 6-8 times. Sq, in effect, a factory taking in one million pounds of asbestos might list one million pounds of asbestos going into 8 different collection systems. This, in turn, would make it appear that eight million pounds of asbestos is going into the operation. From the wording of the form, it would appear that this is exactly what the EPA wants. However, another member was told that this is not what the EPA wants. He suggests that if a factory takes in one million pounds of asbestos into the process that it should not report in total more {~an one million pounds of asbestos. If he had 10 different emission points, he would divide the one million pounds of asbestos by 10 to give the "amount of pollutant." Again, their apparently has been adiffer-; ence, in interpretation from different Regional Offices of the EPA. On page 3 of the report, under "Waiver of Compliance," it was stated that Sections 2a and 2b did not have to be completed unless EPA specifically requests this information. FMSI 06664 ,. .. 3/7.J sllVfPLIFY LABELING OF ASBESTOS PRODUCTS AND ASBESTOS \VASTE MATERIALS C:O~fffJ.J~::; \' '3ET05 (~iSh.;, .' ,_l(\'1) rcr;fL::;,:;. .:,{N\~~;,... - --'"' ;c n.:;.T SfJ,;OU:- '-;CD.!.. l-IAHM '' o No extra labels to buy or put on. No tags to come off. o No labels to come unglued. e OSHA specified wording printed directly on bag. e Continuously and conspicuously displayed. Yellow lettering on a green background. o Available in two sizes and two thicknesses. Ideal for waste such as stripped insulation, scraps, etc. ~trong, durable polycthclene bags are available in two sizes, 30''x48" and 30"x37", and two thicknesses, 0.002 and 0.004 inches. These bags were conceived a!'. a workable solution to labeling asbestos waste according to OSHA 191 0.93a. You wiiJ discover they have many other uses such as consolidating storage space for preformed asbestos insulation when removed irom shipping boxe~. am.l triiusporting soiled covernlls to laundry facilities once used in asbestos work. Order today from: LOSS CONTROL PRODl.IC'TS OF 1-lOUSTON P. 0. Box 52742 HOUSTON, TEXAS 77052 FMSI 06665 . CUimE~T 1'1{1 CE Ll ST AS OF A1JG. 1 'j, 1974:,:.- POLYI~TliEI.ENE 1\i\CS WITH ASBESTOS WARN1NG LABI~L Fl~t Bags, Bottom Weld Total Quantity per Order 1,000 2,500 5,000 10,000 Cost per Cr~se(200)/Cost per 1000 .004 11 thickness 30 11 X 48" 30" X 37" 53.60/268.00 42.00/210.00 52.90/264.50 41.68/208.40 52.00/260.00 41.00/205.00 51.90/259.90 40.80/204.00 .002" thickness 30" X 48 11 30 11 X 37" 29.00/145.00 23". 50/117. 50 28.50/142.50 22.75/113.75 28.00/140.00 22.35/111.75 27.75/138.75 22.15/110.75 Minimum Order -- 1 case of 200 bags Prices F.O.B. Houston, Texas 7 inch twist ties -- $1.50 per 1000 ,h'<Due to supply difficulties and pr~c1ng changes c.f raw materials caused by the fuel shortage, prices are subject to change without notice. Current prices are available upon request. LOSS CONTROL PRODUCTS OF H01jSTON P, 0. Box 52742 Houston, Texas 77052 Samples sent upon request FMSI 06666