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INTERNAL. CORRESPONDENCE
` MINING AND METALS DIVISION
rofWomaJ o.Wbo* location
K. S. Lane, MD 22nd Floor New York, NY
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R. J. Kronkhyte
R. 0. Marsten H. B, Rhodes
W. C. Thurber
G. L. Vessels D. Hyd e, MD
P. 0. BOX K. KING CITY, CALIFORNIA 93930
Data July 16, 1981
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SoSjoct Revised Medical Exam Requirements CAL/OSHA
Attached is a copy of the Medical Surveillance section of CAL-OSHA's asbestos regulations, as revised on 3/21/81. These revisions have not been approved by Federal OSHA, but apparently would be enforced by CAL-OSHA wherever appropriate. The revisions include:
1. Reduction from 1.0 f/cc to 0.1 f/cc exposure level to trigger the exams.
2. Different requirements depending on age and time since first exposure.
3. An additional X-ray. 4-. Addition of rectal examination and stool guaiac test. 5. Requirement for physician's opinion on whether or not
employee should continue to work with asbestos.
As you probably remember, the proposed revisions also included sputum cytology; but, this was dropped from consideration at the Standards Board hearing which I attended.
Through some unexplained oversight, plant personnel have not been aware of the revisions in the CAL-OSHA Medical Surveillance requirements, although I do not consider this a "health" problem since our exposure levels are relatively low. However, we could be cited for non-ccmpliance, and we should base a new program on the new rules as a minimum.
Bob Kronkhyte and I met with Dr. Hyde on 7/15/81 to discuss the revisions and initiate an implementation program, which I would like to have in effect before the end of the year. Most of our employees fit the "over 4-0 and over 10 years exposure" category, and we may have problems with acceptance of Item Ho. 4 above. Dr. Hyde uses a "Hemoccult" Kit by Smithkline Diagnostics for his stool examina tions. He is willing to demonstrate the use of the kit on video tape and to con duct educational seminars on the revised standards for all personnel.
I would appreciate comments from you and/or Dr. Rhodes on the attachment and the contents of this letter at ycur earliest convenience.
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UCC 014060