Document e2p11ba3NYanLov9VXpRNRYE

HMBB-0037A2h i/--j I From: BID Center - 4O1-3X0B WIN: 236-1362 Oat*: November 6, 1087 $ubj*cc 1088 NEGOTIATIONS POSITION PAPER T J. B. Jacoby - Gateway cc: E. P. kassaro - Gateway (without att.) Attached is a draft copy of the 1088 Negotiations Position Paper, 'Toxic or Hazardous Substances in Vestinghouse' which I have updated. Some of the attachments are dated but are still current. I did not include our asbestos guidelines with this letter but will make it available if you need it. CJU. , ----*r Corporate Industrial Hygiene Environmental Affairs /ehw i _r b--u 65 L--6? L^5 u DRAFT (T) PROPRIETARY 1988 NEGOTIATIONS POSITION PAPER ** Tone OR HAZARDOUS SUBSTANCES IN TOSHNGHOUSB* **** Prepared by C. f. Bickerstaff Manager, Industrial Hygiene Environmental Affairs RAD Center HWBB-0037425 ir-J L---- u If hS r: Tone OR HAZARDOUS MATERIALS IN TCSTINOBOUSB A. Historical Background Westinghouee [(}] was a pioneer la tbs field of Iadustrial Hygiene with tbs bistory of tbs department going back to tbs early 1930's. Tbs initial effort ni evaluating and controlling eaploye exposure to silica particulate ia the foundry operations. Efforts sere then directed toward developing a system of evaluating the chemicals and materials used in the (T) manufacturing processes to determine the potential employe health hazards and determining shat controls, precautions and protective clothing was necessary to minimise the hazards. This system was then integrated into the ffestinghouse Corporate Standards Purchasing Department Specification/Material (PDS/M) Card System as a means of communicating this information to the () plants. Once the hazardous materials were identified, then Safe Practice Data Sheets (SPDS) were developed, prepared and issued to the plants. SPDS included the physical properties, the common (J) materials which contained this hazardous material, the toxicity, fire information, first aid information, and how to safely handle and control the material. Until 1970 there was limited personnel monitoring of eaploye exposure to hazardous materials at industrial plants including (f), with the exceptions being the monitoring of employe radiation and noise exposure. If the Headquarters Industrial Hygiene Department was involved in any monitoring that was performed, these records were well maintained. However, maintenance of such historical records at the (V) plants varies from excellent to poor. Medical surveillance, e.g. audiometric exams, periodic physicals, bioassay samples, was much more prevalent including the maintenance of such records. In 1984 Mr* Stu Saltman of the Law Department issued guidelines on records retention and by including a review of plant record retention during our plant audits, maintenance of these records has improved. Vhen the Occupational Safety and Health Act came into being in 1971, more emphasis was placed on eaploye exposure to toxic materials. Industrial Hygiene training courses were developed for the plant industrial hygiene and -2- NWB8-0037h26 U~"u If qs> * safety representatives. Additional monitoring equipment, sampling pumps, noisemeters, etc., were purchased and sampling procedures were prepared for the Qp plants to -perform assessment of occupational exposure. Therefore, documentation of eaploye exposures to toxic materials or physical agents increased such that personnel sonitoring of eaploye exposure in the last 11 years is sore than twice the amount there was in the previous 40 years. The format of the () SPDS was revised to reflect the changes in the OSHA Occupational Health Standards, e.g. personnel monitoring requirements, permissible exposure limits, employe training requirements concerning the potential health hasard of toxic materials, disposal of waste and recordkeeping. Plant audits were established to review the Qp plant Industrial Hygiene and Safety Programs with a written report then issued to the General/Plant Manager discussing the findings recommendations and requesting a response. Beeaue (T) was a pioneer in developing industrial hygiene and safety programs, the OSHA regulations have had a minimum impact compared to other major corporations, e.g. chemical manufacturers, and in general OSHA has a high regard for (V) as a responsive employer. B. Present Conditions About 00-70 percent of the (V) plants use, in part or total, the (V) PDS/M card system to purchase materials and chemicals and thus these chemicals and materials are evaluated by our department as previously described. The other plants, e.g. acquisitions or new divisions, have their own method of material evaluation including material safety data sheets from their supplier. Bach plant has copies of the Qp Safe Practice Data Sheets (SPDS) which they can use for reference and training the employes. Specific hasardous awareness training has always been given to CD radiation workers. Sessions covering hasardous or toxic materials and the Qp SPDS have recently been added to the safety observer training and are also included in the () Hasard Communications/Eight-to-Know Program. In August, 1980 OSHA issued a standard 'Employe Eight of Access to Medical and Exposure Records.* This standard permits employes, or their designated representative, to have access to their medical records and their records of exposure to hasardous materials. 3- HMBB-0037b27 5=9 r---- : A letter ns issued by (V) Headquarters advising the plants of the details of the standard, and vhat steps to folios if any request was made for medical and/or exposure results (Attachment 1). v Tory few plants have received employe requests for information exposure to hasardous materials and these requests sere honored. Headquarters Industrial Hygiene has always recommended that results of employe personnel monitoring be given and explained to the employes. This is especially important with the increased emphasis on monitoring employe exposure to hasardous material and all of the nev OSHA occupational health standards now requiring it, e.g. asbestos, lead, arsenic and hearing conservation. If, hoirever, during our plant audits we find that some () plants do not have a mechanism for informing employes of their monitoring results this is then corrected. C. Hew Standards and Regulations of Concern In 1985 the OSHA Federal Hasard Communication standard became effective for the manufacturing and chemical industries. Since then about one-half of the states have legislated employe and/or community Right-To-Know laws. A recommended program of compliance was developed and issued to all (V) plants (manufacturing and non-manufacturing) advising them how and when to. achieve specific requirements for the standard (Attachment 2). As of August 1987, only three (V) plants have received citations from OSHA on their Hasard Communication Program and these were minor infractions. OSHA extended the hasard communication standard to include all industries effective August 1987. Fortunately most (V) facilities implemented our recommended program and this will have a minimum impact on the corporation. With the increasing use of video display terminals (VDTs) e.g. computers, word processors, electronic mail, is the workplace, most Qp employes will have some exposure to VDTs on a routine basis. As the use of VDTs has proliferated, so has alleged health concerns associated with their use, e.g. eye strain, back strain, cataracts, skin rash and even dusters of birth defects. The only substantiated concern is design of the workstation, i.e. ergonomics. To alleviate these concerns, Guidelines for VDTs and medical vision screen examination were developed and issued to all (W) plants (Attachments 3 and 4). HMBB-0037<|28 03 s=? ir-u m 5 Corporate Industrial Hygiene Has developed a data system to aaintain and retrieve Industrial. Hygiene monitoring records for the plants, e.g. air samples, noise aeasurenent. This system is able to track employe exposure by chemical, plant, worker occupation, dates, etc. The next nodule to be developed will be for occupational medical surveillance records, e.g. blood lead, audiograms. As this system is developed and used, it will aid in complying with these new regulations and will increase the access to record retention and access to employe exposure and health records in case of worker compensation claims or litigation (Attachment 5). OSHA issued their new asbestos standards for both industry and construction in June 1986. Guidelines for developing a control program were issued to all plants in October 1986. The industry standard will have a minimum impact because asbestos in (W) products has been reduced to only a few plants, whereas the asbestos construction standard will effect most (W) facilities because it addresses asbestos insulation in buildings: fireproofing, pipe covering, sound damping, exterior siding, floor tile, etc. Future Occupational Health Legislation of concern is the *High Hisk Occupational Disease Notification and Prevention act of 1987.1 Hepresentative Gaydos (D - PA) H.B. 162 and Senator Hetsenbaum (D - OH) 8. 79 are the authors. The House bill was recently passed and the Senate bill will probably be passed in early 1988. This legislation would require the government and participating employes to identify, notify and counsel past and present employes whom the government determines are at risk of occupational disease from exposure to hasardous chemicals or agents. Some of the major points of these bills in current form are: o Establishment of a Hisk Assessment Board which will identify those populations at risk of disease associated with occupational health hasards. o The board will then notify employes and employer of that risk. . . o The notification will identify the associated disease(s), latency periods (time of exposure to time of disease), appropriate medical monitoring, the nearest certified health center and the employer's health monitoring responsibilities. -5- HUB8~0037<i29 HNBB-0037430 SF? fi-T m 0 iff! If -i-,< D. Treads in the Unions Recently there has been aa increase in the nuaber of new OSfiA occupational health standards. However, there bar been a decline in the nuaber of OSHA inspections under the Reagan administration, which has been also true at (V) plants, therefore the unions are starting to becoae sore aggressive in this area. They now have the ability to access cheaical toxicity data. Soae are even atteapting to conduct mortality studies of previous aeabers. The United Auto Torkers have developed and issued to its aeabers a brochure on epidemiology, what to look for is the workplace, types of illness and deaths that could be work related and to report this inforaatios back to the union headquarters. All unions are aware of these state Right-To-Know regulations and the Federal Hazard Communication standard because aost have occupational health specialists os their staffs and they have been very successful in lobbying for passage of these regulations. Both represented and non-repreeented plants have experienced numerous requests for information on aaterials in the workplace from eaployes. Unions in general favor having joint Management-Union Occupational Safety and Health Coaaittees. (V) continues to promote the use of our safety observer program and we contend this program, if properly presented, will meet this need to involve the workers is the plant occupational safety and health program. In fact, Headquarters Safety revised this prograa ia 1081 and promoted its use through vTrain the Trainer* seminars. Vithia the last year we have had to respond to union requests for information on employe exposure to hasardous material at former (V) plants i.e. Lester, Bloomfield, Sharon. 11/8/87 -6j