Document dYzqmbpayXVEVrZZ7wGGd7BeR

nun i iillilUIUHIilii ,! PREPARED TEXT ORAL PRESENTATION BEFORE THE CALIFORNIA STATE OCCUPATIONAL SAFETY AND HEALTH STANDARDS BOARD Concerning TITLE 8: GENERAL INDUSTRY SAFETY ORDERS [Asbestos, Section 5208, Subsection (c)(2)] HELD IN SAN DIEGO, CALIFORNIA Asbestos Information Association/North America 1745 Jefferson Davis Highway Crystal Square 4, Suite 509 Arlington, VA 22202 X404 ! 08 Hy name Is Harrison B. Rhodes and I am employed by the Union Carbide Corporation as a Technology Manager in the Health, Safety and Environmental Affairs Department. I am speaking today for the Asbestos Information Association/ North America (AIA/NA). The AIA/NA is an association of more than 50 companies engaged In the mining and processing of asbestos and asbestos-containing products. The California Occupational Safety and Health Standards Board is con sidering a change in the General Industry Safety Orders, Section 5208(c)(2), Asbestos, as follows: 2. Asbestos spills or debris generated from any process or handling procedure shall be cleaned up promptly. (Words to be added are underlined) The AIA/NA believes that the proposed change fails to take into account the wide differences that can exist between asbestos fiber itself and the debris generated from asbestos-containing materials. This makes the change unnecessarily restrictive and burdensome in that it mandates actions in many cases which have little or no impact on worker health. It would also be extremely difficult to achieve compliance in non-fixed work locations such as the construction industry. The basic Intent of the Asbestos standard is obviously to limit worker exposure to airborne asbestos fiber. The spilled asbestos or debris is not in itself airborne fiber but represents a potential source of such fiber if It is blown, swept, walked on, run over by equipment or otherwise disturbed. The word "promptly" has the connotation of "quickly", "immediately1', "done at once". The present regulation applied to raw asbestos fiber is quite strict and requires a substantial effort to achieve compliance. Although there may be X4C4iG9 specific Instances where It Is truly Impractical, It Is not generally considered to be unreasonable. The modification, however, treats all debris from the use of asbestoscontaining products as if they had the same potential for airborne fiber generation as raw asbestos. Cut pieces of vinyl-asbestos floor tile, resilient sheet floor ing, packings and gaskets, and any even minute spills of fibrated roof coatings, to cite a few examples, would have to be cleaned up immediately. This places an extreme burden on the user with little or no impact on the airborne concentration. It Is suggested that this problem can be overcome by a simple para phrasing of Part (5) of the same subsection as follows: 2. Asbestos spills shall be cleaned up promptly. Asbestos-containing debris generated from any process or handling procedure which may produce in any reasonably foreseeable event employee exposure in excess of the 1imits prescribed in Section 5208(a) shall be cleaned up promptly. (Words to be added are underlined) These changes retain the present strict requirements for raw asbestos fibers. They also incorporate the definition of debris suggested by the staff In the proposal and apply the same criteria for cleanup that is now used in the regulations for waste disposal. Good housekeeping is important on any job but there should be a solid justification for the extensive additional requirements of "prompt" cleanup that this change would impose. We believe that the wording suggested will provide X4C41 1C I liWllllll: -3- illlfllllll mini i i appropriate limitations and will also meet the criteria of reasonable, enforce able and "positive benefit in protecting worker health" that the Board has applied to the Standards it develops. X 4 C 41 11