Document emMG418pazDjwMXQ4DMZLbQNm

FILE NAME Caterpillar CAT DATE 1986 Nov 20 DOC CAT029 DOCUMENT DESCRIPTION Memo - Asbestos Standards Update - Safety Complaint CINTEROFFICE MEORANDUM [ | ' MEMORANDUM OFFICE DEPARTMENT ATTENTION FAC GENERAL OFFICES DATE November 20 1986 PLANTS OFFICE DEPT ATTI U.S.Safety Managers & Physicians Aurora F. M. McCuskey M. T. Neu M.D. Bettendorf R. L. Verbeke Corinth J. J. Winterscheidt Dallas OR G. Fulton Davenport R. L. Buckles R. Garcia J. C. Donahue M.D. Decatur K. A. Harm J. H. Ringer East Peoria S. Clark M.D. R. G. Daniels M.D. Joliet D. Reynolds M. T. Neu M.D. Lafayette J. Dougherty G. Underwood M.D. DC DESTROY FILE UNTIL DATE Mapleton R. B. Allsop J. R. Barron M.D. Morton C. Carter N. A. Vlachos M.D. Mossville B L. Becker D. J. Crane M.D. Pontiac D. Russell J. B. Maticka Tech Center J. C. Adams M.D. J. B. Maticka M.D. York W. Glass M. A. Zittle D.O. ce F. M. Bock - AB1410 J. Busche -AB4225 G. W. Grawey M.D. - AB1410 D. S. Janetka - Mapleton J. M. Kale - East Peoria T. VonEinem -Aurora L. Walsh - Mossville B W. Webster - Joliet G. E. Williams - AB1410 4 - Subject Asbestos Standards Update There are two asbestos standards one for general industry 1910.19 and one for the construction industry 1926.58 We will be covered by both standards According to OSHA our production use of asbestos and asbestos under the General Industry Standard 1910.19 containing products will fall Our maintenance type jobs asbestos removal and repair will fall under the Construction Standard 1926.58 There are similarities between the two and also differences as you would expect Both standards have areas that will be difficult to comply with but the Construction Standard is by far the more difficult of the two 01-480505-04 2402 1023688 01 The present status of these standards is that they are being challenged in the court by the CIO and by the Asbestos Information Association Testimony is presently being heard It is uncertain at this point whether the standard will be upheld or remanded back to OSHA for modification If the standard is upheld the startup dates are as follows ' 1926.58 - June 20 1986 + 210 days e 1910.19 - Various dates from October 17 1986 to July 1988 for specifics see standard On all OSHA standards the Washington office sends out a directive to the area offices stating how the standard is to be enforced They also offer training courses for their inspectors Thus far neither activity has taken place We will be getting a copy of this directive which will enable us to better advise you on this very difficult standard The Organizational Resources Council ORG an industry lobby group to which Caterpillar belongs is preparing a list of questions on these standards to be presented to the Washington D.C. OSHA office The answers to these questions will also help clarify the standard As part of our 1986 objectives the Industrial Hygiene Division G.O. is reviewing plant procedures for asbestos and will make their recommendations later this year Up to now we have advised the plants to identify asbestos production use and take appropriate airborne samples Most of those samples have been taken You were recently advised that the approved throw away dust masks are no longer appropriate We deferred making that change until after 3M's last challenge to this portion of the standard was denied In the same memo we asked you to review the respirator fit testing protocol There are three methods The irritant smoke test looks like the most reasonable approach The plant physicians are reviewing the medical portion of th the standand With the uncertainties facing the asbestos standards I recommend that we become familiar with these standards wait for the court decision wait for the OSHA directive wait for industrial hygiene's review of the plant procedures before we embark on a permanent program for handling asbestos removal and repair 1023689 015 I believe asbestos is a highly emotional political problem It is not in my opinion a serious health problem for Caterpillar Airborne samples taken on our production uses have been quite low The only area that will give us problems will be tear out and removal of old asbestos insulation Asbestos becomes a problem when made airborne We should not get into immediate massive removal projects Removal should be our last choice We should be locating our asbestos insulation inspecting it repairing damaged areas and encapsulating others It is my recommendation that we use reputable experienced outside contractors for jobs of this sort In so doing we avoid many portions of the standard and future liabilities Please relay this information to the appropriate plant personnel Plant Engineering etc. who are engaged in maintenance asbestos removal We will continue to closely monitor this situation and keep you informed If think after we have all the facts we need to have a meeting at you General Offices to discuss these matters and plan compliance strategy I would like to hear from you -Nkon -Nkon -Nkon -Nkon HKThompson Industrial Hygiene Division Medical G.O. 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