Document dYKmVregQZrp97JaJ4jvNnn55

ROY F. WESTON, INC, WESTON WAY WEST CHESTER PA 19380 PHONE. (2*5) 592-3030 TELEX 83-534$ JlENVIRONMENTAL V CONSULTANTSOESIGNERS As indicated in Mr. Robert Mereness' recent letter to you, Roy F. Weston, Inc. has been engaged by the Association to gather information and prepare a report on the technological feasibility and economic impact of the pro posed revision to the OSKA Asbestos Standard. This report will be based upon the data and opinion provided by your company. We believe it is in the best interest of your company, and the industry as a whole, to parti cipate in achieving a reasonable Standard. Weston's plans are to contact you to discuss the attached questionnaire. Depending upon the project schedule (Weston's report wi1i be issued to AIA/NA no later than 2 February 1976), a member of our project team will: Set up an appointment for a plant site visit, or Record your input by telecon, or o Provide mailing instructions for your response. To assure confidential treatment of your input, the cover sheet of the questionnaire will be coded, detached from the questionnaire, and kept separate. The cover sheet and questionnaire will not be duplicated. Your data will be keot by Weston until the rule-making process is completed. At that time, your original input will be returned to you. A questionnaire for each plant is required. If you have more than one plant, please duplicate the attached questionnaire. Very truly yours, JUw.. J LH:j wg Attachmen t Jerry L. Hebb Manager, Occupational Health Management Department CAPCO JEN 0016790 ROY F. WESTON, INC WESTON WAY WEST CHESTER, PA 19380 PHONE. (215) 692-3030 TELEX 83-5348 ASBESTOS INFORMATION ASSOCIATION/NORTH AMERICA INDUSTRY QUESTIONNA IRE^) ^ Company Name _________________________________________________ Plant Address ________________________________________________ Corporate Affiliation ______________________________________ Name of Plant Contact Title Phone Number ( ) Note: This cover page will be detached from the remainder of the questionnaire to insure confidential handling of all information. (1) For assistance in completing the information In this questionnaire, please contact Hr. Jerry L. Hebb, Roy F. Weston, Inc., phone (215)692-3030. (2) If, for any reason, you do not choose to participate in the study by completing this questionnaire, please return it directly to Mr. Jerry L. Hebb at Roy F. Weston, Inc. CONFIDENTIAL Company Code # Plant Code # -1- i CAPCO JEN 0016791 I. General Product/Process Information 1. Which of the following industry segments best describes the asbestoscontaining products in your operations? (Check more than one, if appropriate). j/Asbestos Cement Products (pipes, sheets, siding shingles) Asbestos Paper Products (asbestos felts, latex sheets, underlayments, electrical and commercial papers) Floor Tile Coatings (roof coatings, caulks, sealants, paints, adhesives and undercoatings) Friction Materials (automotive linings, disc components, blocks, clutch facings) Gasket, Packing, Sealing Devices Joint Cements Asbestos Reinforced Plastics Asbestos Textiles Asbestos Drilling Muds Asphaltic Paving Distribution/Resale Miscellaneous (Specify) 2. Which of the following categories best describes the operation at your plant? (Check more than one, if appropriate). a. Manufacture a product where raw asbestos is used. What tonnage of raw asbestos do you use per year? /^b. ______ Process a product which already contains asbestos. 3. In reference to Question 1, for each industry segment, give the specific asbestos end product(s) (siding, pipe, etc.) manufactured, handled, or used at this location and the annual volume of each (in pounds, tons, square'feet, etc.). Industry Segment End Product(s) Annual Volume CONFIDENTIAL Company Code # 2- Plant Code # CAPCO JEN 0016792 4. What was the aggregate sales value of asbestos containing products manu factured at this plant during the last five calendar years: 1971 '972 1973 1974 1975 $ v/v/ $f $ to $ >,7 ,, - $ /?.* / >> 5. What was the level of capital expenditure for plant improvement and expansion of production facilities for asbestos containing products during the last five calendar years? (include capital expenditures for environmental control, plant improvement and expansion). 1971 1972 1973 1974 1975 $^ $ ./ $ __ $; $ _____________ . ____________ 6. What is the total plant employment at this location? 7. Give the approximate percentage of the employees whose asbestos exposure falls in the follaving categories: a. Continually in the work environment (operating, production, materials handling personnel) L7c ; b. Frequently in the work environment (maintenance, supervisory personnel) _r;- c. Only occasionally (less than 5 times per week) in the work environment (management, engineers) d. Never or very infrequently enter the work environment (secretaries, sales personnel) ( 8. What unions (locals) represent your employees, if any? a. How active have the unions been in the area of employee health and safety (demands for hazard pay, shorter work periods, etc.)? Active Area Extent of Activity (V--Very, M--Moderate, N--None) b. What is the current pay scale range of unionized personnel? CONFIDENTIAL Company Code # -3~ Plant Code # CAPCO JEN 0016793 Control Technolcqy/Cost Information 9. Provide a brief description of each step in your operation as it relates to asbestos handling or movement. Interest is primarily in the location of dust sources (bag slitting and dumping, sanding/finishing, etc.) and in dust control at these sources (hoods, etc.) rather than in the production equipment. A block flow diagram is suggested. There should be one such diagram for each product group and/or process used. In clude raw materials entry and finished product handling. A blank page has been inserted at the end of this section for the block flow diagram(s) and description (s). If additional space is needed, please attach extra sheets. 10. Has control equipment been installed at each step or combination of steps in the block flow diagram(s) where asbestos is released to reduce worker exposure to airborne asbestos? Yes / No List control equipment in use: Type of Equipment Date Installed - X , V x' :: r - / *.-->- -. ; v.' - \ - ' ' f/ X /stos ' i*' ; .' *^ /. . /'-> , -a- //,. ... ; S , ' - 'X. ' C.,//- - r ' ' : / /. \ / - hr -- .11. What is the total cost of control equipnu a. Capital cost (installed) $ b. Operating cost (annual) $ (Note: give horsepower, exhaust volume, etc., if operating costs are unknown.) x What effect has this'equipment had on your process, product or production rate? __________________________________________ ________________ CONFIDENTIAL Company Code # -4- Plant Code # CAPCO JEN 0016794 d. Did this equipment increese or decrease the piant/process energy requirements (electrical power, space heating, etc.)? Increase Decrease By how much? .12 What process modifications or work practice changes, if any, were instituted to reduce worker exposure to asbestos? ojU-__ /V>,, . a"] Capital Cost (Installed) $ ja b. Operating Cost (annual) $ s _________ c. What effects have these process modifications or work practice changes had on your process, product, or production rate? d. Did these process modifications or work practice changes increase or decrease the plant/process energy requirements? Increase Decrease By how much? r'. 13. Have the control equipment or work practice changes reduced air borne asbestos levels in all of the work areas? Yes No List the ranges of asbestos fiber counts in the work areas involved: Work Area Ranqe of Asbestos Fiber Counts Before Modifications/ After Modifications/ Chanaes Changes fp'/ /o ^V' 14. Have the control equipment or work practice changes reduced air- time-weiqhted average exposure to airborne asbestos in all of the work areas? Yes y No CONFIDENTIAL Company Code # -5- Plant Code # CAPCO JEN 0016795 Work Area Before Modifications/ Changes After Modifications/ Changes The present asbestos standard sets a maximum allowable Time-Weighted Average (TWA) exposure of 5 fibers/cc over an 8-hour period. This, by statute, will be reduced to 2 fibers/cc in July, 1976. The proposed standard would reduce this level to 0.5 fibers/cc at some time in the future. If you have already reached 0.5 fibers/cc at each step where asbestos is released into the work place, please go on to Part III; if not, please complete the following: 15. At each location where asbestos dust is released, do you feel you have installed the "Best Available Technology?" Yes _______ No . Best Available Technology (BAT) is defined as control equipment, process modifications, work practice changes, or combinations thereof, which have been demonstrated to provide the most effective control or reduc tion of contaminant emission, r* 16. If not, what do you consider the BAT to be, and how effective will it be in reducing airborne asbestos at each location? (Can be control equipment, work practices, process modifications, or combinations thereof). Locations Estimated Asbestos BAT Fibers/cc______ 'r-y. & . -- / ' '`-v* ra U- 1U- , Ot ^ L'*'-/ y A' r */*, y.-. r -...y...- ( /, -V ' /' v ,r- -- /'/ CONFIDENTIAL ^: ./. .. ... / r, . -6- Company Code # Plant Code # CAPCO JEN 0016796 * 17. What is the expected cost of BAT in terms of: a. Capital Cost (installed) $ - , . ._____ i-.> b. Operating Cost (annual) $ c. Plant/Process Energy Requirements, Increase ________________ Decrease d. Personnel Requirements, Increase Decrease e. Process/Product Effects, Increase $ Decrease $ Explain _______________________________________________________________ f. 8y what date could BAT be implemented? . /P ..... , - 18. If the Best Available Technology does not reduce worker exposure to a TWA of 0.5 fibers/cc and a ceiling of 5 fibers/cc at all points, provide your considered judgment on the possibility, cost, and timing to develop new technology to achieve this level. What approach might be used? /-V ......., -- ...... If the proposed 0.5 fibers/cc level is adopted, what action is foreseen at your plant? ? --. // ___________ .s r- . . 111. Industrial Hygiene and Health Information 20. The existing and proposed standards require certain industrial hygiene practices where workers are exposed to airborne asbestos below the established TWA or ceiling levels. Do you (provide cost data where available): Cost/ Total Plant Yes No Man-Year Cost/Year a. Provide preplacement employee medical exams? ^ b. Provide annual employee medical exams? c. Provide termination employee medical exams? *2 _T rr> / '-s jfj. * /3, 1 CONFIDENTIAL Company Code # -7- Plant Code # CAPCO JEN 0016797 Yes No Cost/ Total Plant Man-Year Cost/Year d. Retain medical records (20 year period)? e. Maintain records of employee exposure to asbestos fiber (3 year period)? / f. Dispose of waste materials which may contain asbestos in sealed containers? g. Provide caution labels for all material containing un bound asbestos? h. Provide initial monitoring (sampling) of the work place for airborne asbestos? i. Provide periodic monitoring (sampling) of the work place for airborne asbestos? 21. Certain provisions of the existing regulation require additional indus trial hygiene practices where levels of airborne asbestos exceed TWA of ceiling standards, Where these requirements apply to your plant, do you: Cost/ Total Plant Yes No Man-Year Cost/Year a. Have a respirator program (for use in certain work situations or emergencies)? X b. Provide worker rotation where employee is unable to func tion normally while wearing a respirator? ____ c. Provide protective clothing (for employee exposed to asbestos greater than the ceiling level)? V d. Provide change rooms (where special clothing is required? _ e. Provide separate locker facilities (where special clothing is required)? f. Provide laundering of special _ clothing? _H Post caution signs (where levels are greater than the ceiling or TWA levels)? CONFIDENTIAL Company Code # -8- Plant Code # CAPCO JEN 0016798 * 22. Do you errploy a company physician? Yes If yes: Full-Time ; Part-Time week No Part-Time hours/ Do you employ an industrial hygienist? Yes No If yes: Full-Time ; Part-Time Part-Time hours/ week 24. Who performs your medical examinations (clinic, resident physician, etc.)? 25. The proposed standards expand the scope of industrial hygiene practices into areas such as: shower requirements, regulated areas, expanded respirator programs, and employee education programs. In general, how do you believe your employee^wi11 react to such practices? ___________ -y s. j! , IV. Economic Impact Information 26. Considering individually the major products manufactured at this location, has implementation of asbestos exposure control procedures and industrial hygiene programs affected the cost of these products? Yes V No If yes, specify: Products Imolementation Cost, S/Unit of Production increase Decrease 27* Have you experienced a shift or change in product sales due to the cost impact described in Question 26? Yes No ^ CONFIDENTIAL Company Code # -9- Plant Code # CAPCO JEN 0016799 spec ify: _______ Sales Change, S/Year__________ Increase Oecrease b. If sales have decreased, has the demand been satisfied by: Yes Other Asbestos Products ____ Asbestos Substitute Products ____ Imported Asbestos Products ____ c. Which of the above has had the greatest impact on your sales? 28. Considering individually the major products manufactured at this location, do you expect the future implementation of BAT control procedures and expanded industrial hygiene programs to affect the cost of your products? Yes No _______ ' If yes, specify: Products Implementation Cost, S/Unit of Production Increase Decrease CONFIDENTIAL Company Code # 10- Plant Code # CAPCO JEN 0016800 29. Would you expect to experience a shift or change in product sales due- to the cost impact described in Question 28? Yes _______ No j/ a. If yes, specify: Products ________ Sales Change, S/Year________ Increase Oecrease b. If you expect a sales decrease, will the demand be satisfied by: Yes No Other Asbestos Products ____ ___ Asbestos Substitute Products ___ ___ Imported Asbestos Products ____ ___ c. Which of the above would you expect to have the greatest impact on your sales? 30. What is the typical age of production equipment in use at your plant in your particular industrial segment? Segment Typical Production Equipment Age, Years 0-5 5 - 15 15-25 25+ 31. In your opinion, with the implementation of BAT and the proposed OSHA standard to control worker exposure to asbestos, what portion of the existing production equipment may continue to be economically utilized? (Consider the portion of capital equipment retained as a percentage of the total production area investment). CONFIDENTIAL -11- Company Code # Plant Code # CAPCO JEN 0016801 Less than 10% 10 - 25% 25 - 50% 50 - 75% Greater than 75% ____________ ____________ ____________ 32. Within your community, which estimate best describes the portion of the total work force employed at your plant? Less than 10% 10 - 25% 25 - 50% 50 - 75% ____________ P" ____________ ____________ V. Information Regarding Manufacturers/Fabricators of Asbestos-Containing Products The proposed regulations apply to every place of employment where asbestos, or a product conta in inq asbestos, is manufactured, processed, packaged, stored, applied, used, or otherwise handled. It is extremely important to our assessment to include estimates of the number of people involved as your products are ultimately used and the possible asbestos exposure levels of these individuals. Insofar as is possible, kindly provide the following information: 33. Who uses the asbestos-containing products you produce (construction industry, auto repair garage, fabricator, etc.)? - 34. Describe how your products move from your plant through the final con sumer ____ 35. Estimate numbers of people and what levels of asbestos dust exposure, if any, may occur at each step (from further processing, fabrication, Installation, etc.)? ________________ CONFIDENTIAL -12- Company Code # Plant Code # CAPCO JEN 0016802 36. Provide names of your customers and appropriate trade association so that Weston might^.obta i n more comprehensive information in these areas /' / ~r Sj C ..*/' f" / ' l-'t < _____________ -IF IDEM IAL -13- Company Code # Plant Code # CAPCO JEN 0016803