Document baGVQr6707GK8V0o9613xRk2O

MEMORANDUM TO: J. Here FROM: B. Henderson SUBJECT: Magnapore Construction W6 000607 September 12, 1979 PIAINTIF'S S*&-p 'SftWJ.'.'jj1 H . - WRG--739 Reference Is made to our conversation of Monday, September 10, during which we discussed the asbestos problem associated with the cutting and handling of the " transits" panels for the new Magnapore construction. As was mentioned, the airborne dust resulting from the cutting operation la allowing our employees to be exposed to asbestor. OSHA's regulatory manual CFR 1910.1001(b)(3) states "No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers, longer that 5 micrometers, per cubic centimeter of air." I feel relatively certain that, at times, the exposure to our employees Is greater that the celling , limit. Not only is the exposure present during the cutting operation, but ;the dust will remain on beams, ledges, walkways, etc. for weeks to come and will again create and occupational exposure to.asbestos every time there is a wind, breeze, etc. This exposure is totalling unnecessary and can be avoided with little difficulty. The employees of the Specialty Plant are aware that the material being cut contains asbestos. Even if it only contains 10Z asbestos, as they were told by the job supervisor, (this is not at all abnormal for this type of material) it still presents a hazard whan airborne. One of these employees was at the Federal Building last week with a safety complain and 1 am sure that he would not hesitate to repeat this action. The last thing that we want is a federal OSHA inspector to investigate this complain, since the contractor is la violation on numerous regulations, (i.e. all power tools that produce or release asbestor shall be provided with local exhaust systems; engineering controls such as isolations, enclosure, etc. be provided, and asbestos shall be handled, where practicable, in a wet state). Remember, we are resposnible for the contractor's employees as well as our own. # Monitoring, by the use of personal samples, would report expsoures but by '' the tlma^ijjKhad them analyzed, the siding will be complete. Thfubl on each sheet, which reads "CAUTION - CONTAINS ASBESTOS FIBERS. AVOID CRZATINC DUST. BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM..........." is required by law only if a potential hazard is present. I assure you that if it were not necessary! the manufacturer would have refrained from its application. The label alone indicates that precautionary measures must be used. W -v'*- .4 . R0000583 MEMORANDUM TO: J. Hare September 12, 1979 Page 2 Reladve co Che above, I would recommend the following: 1. Have Che concraccor leolace chac parcicular procese ee co eliminate exposure Co Grace employees (as wall as ocher concraccor personnel). People may find ic necessary co (1) go co OSHA or (2) refusing co work in Chac area. 2. Have Che concraccor minimize dusc by a vacuum or a weeting process similar co chac used in cuedng concrece, scone, etc. 3. Have che exposed concraccor employees use Che proper resplracory protection to prevent inhalation of chesa fibers. 4. Have che dusc and debris removed from che area Co avoid lc being. :, carried by che wind. 5. Have che concraccor familarlza himself with 29CFR 1910.1001 (Asbestos) relative co protection, clothing, record keeping, ecc. These recommendadons may appear somewhat stringent, but Z assure you chae this would be preferred co work stoppages, or even worse, an occupational illness resulting from chls process. Asbescosis, unlike mosc chemical expsourcs, is progressive, even in che absence of further exposure, as chose inhaled fibers which have been crapped within che lung continue their biological actions. If you have any questions pertaining to che above, contact me. BH/ap cc: J. Herryman, Jr. J. P. Fitzsimmons L. G. Garrison / L. Macneal, II B. L. Mobley S. Meyer t \ . ROC0059 )