Document aBX8zXnk05rdZmpNevwVxm5ne

FILE NAME: Chrysler (CHRY) DATE: 1976 Apr DOC#: CHRY113 DOCUMENT DESCRIPTION: Memo with Minutes - Meeting, Review of F. Mirer Report and Corporate Industrial Hygiene Comments Inter Company Correspondence -- >.. <vj '"'oncav^ :o meet with vou'a^d -ade by Mr. ?. Mire- ^ -.0 review G li, -l ;3C<a . s, ` thC r5SUltS f ur -- on W*r f happ/ t0 have th# PPrtunity ! "5S "he C5rjnents " d recommendations " diture * conslderaole effo" d expen. the -dueed ncu* c .r '!" P*st severl years to assure that we would meet C; SR4 -s 11i; .u i "' ? 60-t A^?hs:stroessults of testCstuaond(!i>nspec"tio/ns b"v 5 ; Ind 2 i * a1'* 0e?ar ent of Corporate In d S sS a l ' erfo -ts have been " ' aret^ Pe" onnel over this period inaicated these for Exposure ^ ^ " " " " d" d relate'to 'item s'w h ic- Mirer' s recommendations and/or requests do not' iomine A d u l l T . r ) '*PTMsent deficiencies with respect to this forth- .w lc1. anaarc, but r a t h e r to a rec e n tly proposed fu rth e r reduction :n ioUd t 2 ! SUe# tandard -S ^ers/cc.*-7T lH 3-uld be noted, t . ^ caused a zrea't IaUC-U n in the *JC? 0Sure standard to .5 fibers/cc. has -lated -I-,,, 41 01 controversy and concern throughout the asoestos and a " Uri" ! industries. F irst, there is clnsideraole doubt anT *TOB -he stSSdnofnrt e -eVldenCe t0 suPPr t the need f r a standard this low I li-ti! w08 enplo-v.ee and safety, and, secondly, more than aaobilee"ttoo mmeeeett aa*s?t?antd`)aarto.tha#t tahfefec.3tedfibperorsd/uccce.rs leavndel.manufacturers would be i>n*ifi**?* these factors, i t should be noted that the implementation of -rnno-f! recommenaatlons/reouests would have significant and serious of a c ications at the Chemical Division, particularly in the absence - - k- . - x; j r /CC' sta n d a rd re q u irin g s im ila r changes elsewhere in the asbestos and f r i c t i o n m a te rla l"T n d u s trie s v ~ ---- ------------------------------- ----------- 'Cr purpose in reoues tin ; 3 meeting with you and Mr. Glatier was to review r . u la iie r 's memo conoeming Mr. M irer's recommendations and requests, which nave already become t ne suoject of a number of grievances and demands by our Local Union, if your office did feel that specific items contained CHRYSt-ER / etmg Review igiene Comments 'Pr li 976 Page T.o r t ana Corporate I. ns us tna i ' r `>_'^r9 r,s report represented deficiencies, or potential oroolems with . .espec. .a our compliance -ith tne upcoming reduceo stanaard to two (2)* _ :ioers/cc^, i t would, of course, be tne Chemical Division's esponsibility ,C2Jie actlon.,,necessary to assure compliance with this standard by the -uly 1st, 1976, effective cate. To the extent, however, the recommendations ana requests by Mr. Mirer are not required to meet existing or the forthcoming -wo !..j tibers/cc. isbestos Exposure Standard, or ao not re present any other health hatard to our employees , our position would be tney are negotiable ocal union demands, and be created accordingly. Following is a summary of the major points made by Mr. Mirer m his report and the response to these items, as discussed and agreed m our meeting: ') 3: s t n ; - a. Language for any signs to be posted is specified in both the current and July 1st, 1976, Asbestos Exposure Standard. Any signs to be posted w ill use this language, without reference to lung disease or cancer, as proposed by Mr. Mirer. b. Generally, we agreed that wide-spread or indiscriminate posting with respect to p o ten tial asbestos hazards tends to d ilu te and/or weaken the effectiveness of this action. c. 3ased on both the current and upcoming reduced Standard to two (2) fib e rs/c c., posting is only required in areas in which employees may be exposed to asbestos at the "ceiling level (ten (10) fib e rs/c c .). Tests and a ir sample analysis by your office do not indicate that the locations id e n tifie d by Mr. Mirer have this level of exposure. We w ill, however, review these areas, again, and make any additions required. 2) Containers - a. It was recognized th at covering containers of asbestos-containing "serial can be a costly measure with relativ ely l i t t l e effect on overall asbestos exposures. Open containers of inert materials containing asbestos do not represent a health hazard, unless p articles can become airborne. Since this is most likely to occur during loading and unloading operations (when the covers would be removed1, :.-.e use of covers is questionable. b. We w ill review those instances in which containers of material containing asbestos are moved about the plant, creating the possib ility of airborne p a rtic le s, and provide cover where needed. CWY8LER M12M eeting - Review c r-'giene Commen t s ___ ; ? n : - i . .976------- ?age Three epor: ina parate. Industriai -ent:lation Indicators - a. entilation indicators of whatever type can only advise tr.e operator that the ventilation equipment is "on" or "operative." Whether or not tr.e equipment is performing adeouately can only e determined by trained personnel, using prescribed testing devices and a ir samples. b. In nost instances, the operators can determine, physically, whether or not ventilation equipment is "on" or "operative." This responsibility will be incorporated into existing job uuties and enplovees will be instructed to check ventilation equipment for operation at the s ta r t of each sh ift. Inoperative equipment - i l l be reportea to Supervision and Maintenance, tamedi- ateiy. ' i t those locations where physical check is not easily accomplished, some type of indicator w ill be u tiliz e d , to a lert Supervision and Maintenance to potential oroolems. Because of redundant and "back-up" systems, the use of "interlocks" is not feasible at most locations, and the use of specific equip ment without the primary v en tilatio n source-is not hazardous, p a rtic u la rly on a temporary basis. Housekeeping - / a. Management agrees tr.at good housekeeping is necessarv to the et"^ectlve and orderly conduct of a ll manufacturing operations, and has agreed to this m our current labor contract. b. We agree the matter of ja n ito ria l manpower and scheduling is the resp o n sib ility of plant management. 5) Cleaning Methods - a. A fter some discussion, we agreed that the "wet" methods recommended by Mr. Mirer are not practicable or effective for our operations. b. "Squeegees" w ill be"usea'Tb move'as&esf6s"'-c6nYaTriIFg"waste'material"" and other debris, d irt snd dust :a the proximity of the existing network of vacuum cleaners for proper clean-up. c. The Corporate Asbestos Review Guide w ill be revised to reflect th is method for the Chemical Division. CHRYSLER SS12SO M* e t i n g - Review o ^ ' g i e n e Comments "PfU : i , "1976 ??e Four Mirer Report ana Corporate Industrial ) ;<ork Clothi ng - <>3 w; - aau $mjf-nwcnung usha ^tanaaras r*ue sceciai - ot. mg, iuch as coveralls, for any employee exposed to a ir ome concentrations of asbestos which exceed the ceiling level (ten (10) fib e rs /c c .). Our current Corporate Standard provides tor this clothing when emolovees are exposed to con centrations exceeding five (S) fib e rs/c c ., and this is currently applied at this plant. Those employees at locations identified y Mr. Mirer, who are not now assigned coveralls and two (2) lockers, are not exposed to even two (2) fibers/cc. in most instances. During w.-.e 197j contract negotiations, management at the Chemical Division agreed to provide protective aorons for emoloyees at many or me locations noted by Mr. Mirer. Few of these employees have requested work aprons during the past three years. c. In order for coveralls to provide any protection from possible contaminations, they must be kept apart from employee stre e t clothes and stored in separate lockers. New locker and shower fa c ilitie s would have to be constructed at th is plant to pro vide the necessary space for a ll Friction Products employees. d. Existing te st and a ir sample analysis data do not indicate a hazardous condition at these work locations, based on the current and fortncoming reduced exposure standards. *) Monitoring Observations - a. It is recognized that the local union Health and Safety Represen ta tiv e is notified when Corporate Industrial Hygiene enters the plant for survey purposes. b. The current Health and Safety Memorandum of Understanding does not provide for the Representative to be excused from his job to monitor testin g and sampling procedures, and this plant does not propose that th is be changed. c. The various te sts and a ir samples are taken by trained, professional hygienists. We do not believe an untrained, non-professional, unionappointed representative can rake any useful contribution to the testin g and sampling procedures. The Union, of course, does have the right to request th a t sp ecific areas, locations or job operations be sampled for p o te n tia lly hazardous conditions, and to be informed of the results of these te sts. CHRYSLER 001270 Meeting - Review o rvgiene Cjnm>nf< :?rl1 -1.^976 Page rive r s r Resort *na Corporate i n d u s t r i a l i ` I L 1S.n a*res=ent the present Memorandum of Understandine '. rl0106 the l3Cal union safet>' representative with a copy ofr given to employees regarding over-exnosures. '<e have nowever, as a n atter of practice, notified the Union of these' le tte rs and any over-exposure, and have allowed them to see them. e. We are agreed that inclusion of the specific numerical results of a ir sample analysis in over-exposure le tte rs would serve no useful purpose. s ) fric tio n M aterials Building - a` 'jg.igh-uo Station - <*'e are agreed that waste bags be disoosed of m sealed, impermeable containers. ` b' Lodigg Mixers - The housekeeping problem at th is equipment was caused by a breakdown. Sepair had already been scheduled, prior to Mr. M irer's v is it, and was accomplished shortly thereafter, we are in agreement that a ir sample resu lts show that the dust wnich is seen to escape during loading of. th is equipment is composed, mainly, of non-asbestos p articu late and is below current and forthcoming, permissible levels. c' Presses - We agree that improved administrative controls with respect to employee training and handling of asbestos- containing material is required at these locations. Previous a ir sample resu lts have indicated th at present engineering controls are adequate to minimise exposure. The recent assign ment o f new employees to some of these operations have caused soma increased exposures in the most recent survey results. We do not believe the use of p la stic bins, fille d at another work s ta tio n , and covered or exhausted would make any significant change in what are already low exposures. Protective clothing is not required by current or forthcoming OSHA Standards for the ex posures at these work statio n s. -- i- O.E.M. Grinders - As you are aware, we have reason to believe that the apparent "malfunction" dT ventilation'equipment at" tTiis'location' during Mr. M irer's v is it was not "accidental". We do not believe an interlock is reauired at this location, since "shake-down" operations are not conducted with employees in the area. .As we discussed, however, some type of warning light or indicator will be in s ta lle d to advise employees when the a ir flow to the grinder is cut o ff, due to "shake-down" operations. The noise exposure CHRYSUa 001371 - u n j - review jygxen^ Comments P m : i , 1976 ?a?e Six ^'-W4wn ;us lim its. We aaggrreeee t..at pPl,an":t *Engineering`ouwncilll Wnlotitunoroavlliodwable . " ?0r--s " I < Safety .p r e te jta tm ' e. ~ - r" -n'l" , |" lll| . ^ ` ! " i "*' A` r C :,," ln EauiPJenr . noted bv Mr ? * lS 9) Cnemical Products Building - ?r#s#nt a health hazard. The scrap *' re gularly8 ov ef-'-e . ,, l * ? " , ' S" P`" l,1,e i l r ' * ^ *en taken, b. Stgrage Areas - Efforts are being made to assure that a ll asbesto, shipments are received in -p lastic bags, per Mr. xlS eM C' ^ ^ ^ ^ r ^ 5\llTA lnns re being Bade for the " d' S T e p a i e d b00d " ' h# l0adin* P in t n th# *2 Readco " r has C h e m ic a l'sin i-thC overail use and exP0Sure to asbestos in the mi!hi hi Building warrants the use of signs of the type which night be posted m certain areas of the Friction Products building. P lian c^w ith ^rh i5 rec0inized that our plant location is and has been in com- to h requirements of the new OSHA Asbestos Exposure Standard Sn5 o r JUl / '* 1976' ExCept f0 r th* " Pa ir `Pecific eqiip- comaendatio!! chan*e s ' . as noted w the foregoing, none of Mr. Mirer*s re- SesStaEbliSshKedT ifu*ture rO^SuHAlr#Sdtant0daerdnsa.ble thi5 Plant * current or /ph cc: G. D. Benson F. A. Burnett S. C. Enders 0. P. Glacier E. R. Lombard N. McCallurn W. M. 0 '8 n e n . ,, ' % ^ V ^ . w**>u J --^w -3 :? 5 J . A. Lardie