Document amaXzbv6rJQq3N05dqZXo8yM

';j\4 *tv |.n tot E. I. ou Pont de!MCNO*e9mroc9urs & Com pa ny VViLMINGTON, DELAWARE -,33S3 text'ue -;se^s separtment 1 ,< ---=ry ^ TO: FECIvI: A. SIGMAN N .C J. G. PLASKY ASBESTOS SHOP APlvIIhTSTRA.TION I have received a response from each plant as shown on the attached rack-up. In summary, six plants don't allow any eating and ieur allow seme sort of eating! OSEA regulations state "No employee shall be allowed to consume food or beverages in a toilet room nor in any area exposed to a toxic material. " "A toxic material is defined as a material in concentration cr amount which exceeds die applicable limit established by a standard such as 1910. 93 and 1910. 9Sa or in the absence of an applicable standard, which is'c: such toxicity so as to constitute a recognized hazard that is causing or is likely to cause death or serious physical harm. " 1910. 93a sets the 1976 limit for asbestos at two fibers per cubic centimeter. This article also requires all external surfaces in any place of employment shall be maintained free of accumulation of asbestos fibers if, with their dispersion, there would be an excessive concentration. A.pplying the logic that if we administer the shop to meet cr exceed the requirements of 1910. 93a, we do not have a toxic material, then the regulation does not prevent eating in the shop. While this logic seems sound (based on a strict definition of toxic material) it is not the position we would like from an overall industrial hygiene standpoint. I recommend v/e do the following to achieve an objective of not eating in an insulation shop: 1. Re-emphasize item No. 7 of the asbestos dust exposure recommendation "Prohibit the practice of eating food, snacks, drinks, cr placing materials such as gum or tobacco products in the mouth in work areas.where asbestos containing materials are being handled or fabricated. 2. Reguest that those plants eating in the shop today revise/ the need to continue vs. an improved level of hygiene. These items can be dene in a letter to the Engineering Superintendent. BETTER THINGS TOR BETTER LIVING . . . THROUGH CHEMISTRY DUP 1120238 DU 055260 2- - In summar/, I feel that xe should step eating in the insulaoicr. shops, regardless c: asbestos conditions, because it is a poor industrial hygiene practice, but I cannot find any regulation or standard that is biac> and T.-hite to say ohis must happen- -nus, xe must appeal to the plant via the improved hygiene yasoificavion. - you are in agreement, I xill pursue xith the four plants involved. JGP/ssb DUP I 120239 DU 055261 DU 055262 DUI> I I W I O