Document eva84QzzmJdQLwzVDJEKo4XMq
4 iV'
Inter Office
Messrs. C. T. Buies R. A. Fluck
J. A. 'Masters
B. M. Park E. Slscheck
A. Tytnczyk
cc A. B. Buell N. E. Burke
J. D. Carney B. E. Craig
R. J. Davis P. L. DeVries D. E. Krebs E. 0. Miller
J. Miyaura
A. J. Morefield R. U. Obringer
R. M. Ruth W. R. Quayle
G. R. Schoettley R. C. Semler F. E. Tack G. B. Wolcott ^
R. J. Womac
Subject: Asbestos Control Program - EED
Reference: Communication from C. L. Payor and D. J. Stachelski, same subject dated April 1, 1980.
The purpose of this letter is to request that each location re-review their program for control of asbestos. The Importance of proper control and handling of asbestos that remains In use In plants of this division cannot be over emphasized.
It is requested that each location review areas where asbestos materials are being used repetitively or are installed, to assure that the Corporate policy for
asbestos is being followed. Briefly stated that policy is as follows:
A. Provide employee protection equal to or exceeding OSHA requirements.
B. Users are directed to substitute non hazardous materials for any asbestos containing non-production materials already in use. where feasible.
C. Asbestos materials that are part of buildings or equipment are to be replaced with non asbestos materials if they require replacement due to deterioration, damage, plant rearrangements, etc., or regulations mandate replacement.
D. Follow the Company approved procedure for handling asbestos when repairs or replacement of asbestos is being performed.
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2 December 12, 1980 It 1b not Intended that asbestos materials that are in good condition and currently in place as insulation for piping, boilers, tanks, etc. be immediately replaced vith non-asbestos materials. It la required that deteriorated insulation, where asbestos is exposed, be repaired or replaced vith an acceptable non-asbestos material. Please provide a current report of asbestos materials used on a recurring basis and the actions being taken to replace these materials with non-hazardous substitutes. Also provide information on the condition of Installed asbestos materials such as asbes'tos pipe insulation, boiler and tank coverings, etc., and plans for repair or replacement. Tour response to this inquiry is requested by January 26, 1981. A copy of the Company recommended work practices for proper handling of materials which contain asbestos is attached.
REM/me Attachments
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PRODUCED BY FORD
PLANT ENGINEERING LETTER NO. 80-1 MARCH 17, I960
ASBESTOS - RECOMMENDED WORK PRACTICES
Asbestos is a recognized human carcinogen. The first regulation limiting employe exposure to asbestos was promulgated in 1972. In July 1976, the Occupational Safety and Health Administration (OSHA) established a two fiber per cubic centimeter exposure limit'. OSHA is considering an even lower permissible exposure limit indicating growing concern over asbestos exposure and use.
Despite the hazards associated with asbestos fiber, the reduction in allowable exposure
limits, and the number of proven cases of cancer caused by exposure to asbestos, workers tend to ignore the hazard. A potential hazard exists wherever asbestos is cut, ripped, drilled, ground, on handled in any way which causes dust to become airborne. The best way to minimize the effects of asbestos exposure is to follow good work practices and use equipment designed to protect employes from breathing asbestos.
This article lists the work practices which should be used if asbestos must be handled. These work practices are based on OSHA regulations, Company guidelmes, and common sense. In those cases where asbestos is being removed (as in thermal insulation on pipes), it is suggested that available substitutes be used for replacement. Some substitutes are listed below. Companv research projects are presently underway to attempt removal of asbestos from all Company operations wherever it is possible.
Pipe Insulation
Most pipe insulation installed prior to 1960 contains asbestos. Generally maintenance
and/or replacement of insulated pipes requires removal of the asbestos covering. To minimize the release of asbestos fibers into the air and decrease potential employe exposure, the following work practices should be followed:
. All employes removing asbestos pipe insulation roust wear approved respirators and special clothing. This is not only a good work practice, it is a requirement of OSHA regulation Z9CFR 1910.1001 (C)(2)(m). Contact Industrial Hygiene and Toxicology (313) 337-8955 for information on approved respirators.
. OSHA regulation 1910.1001 contains expbcit requirements and work practices which
must be followed when the potential for asbestos overexposure can occur. The
regulation provides details on: respirator programs, change rooms and clothes
lockers, area and personal sampling requirements, caution signs end labels, house
keeping, waste disposal, medical recordkeeping and medical examinations. The
regulation should be consulted and followed particularly in those areas where asbestos
is encountered routinely.
_
. Isolate the area to keep other employes as far as possible from the repair operation. The"suxlac.es to be repaired.should be wetted.jlown where possible or treated with
commercially available dust suppresant to control dispersion of asbestos fibres.
. Place plastic sheeting on the floor beneath the repair site so that all pieces of
insulation, however small, can be collected when finished. Pedestrian and vehicular traffic can redisburse asbestos into the air if pieces are left on the fioor.
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. If it is necessary to sweep the asbestos, the floor should be wetted down to keep the fibers from becoming airborne. Approved vacuum cleaners should be used to clean the floor of any remaining dried asbestos dust and small pieces of material (see Plant Enpneermg Office, Manufacturing Staff Maintenance Bulletin No. 137 for recom mended vacuum cleaners).
. All waste, scrap, and debris, as well as asbestos-contaminated clothing, should be
..placed in sealed, impermeable bags or containers for proper disposal. No asbestos-
containing insulation should ever be placed m open trash containers or dumpsters. All
waste materia] contaming asbestos or containers into which they are placed for
disposal must be labeled in accordance with OSHA Standard 1910.1001 (G)(2)(i)(u).
. Because asbestos fiber can be dispersed throughout adjacent areas by ventilation systems, air-supply fans m the vicinity of asbestos removal projects should be turned off: exhaust_fans should be left on (unless these fans are part of an air recirculation system) to keep the area under negative pressure.
When repair operations are complete, if the pipe must be reinsulated, asbestos containing products are not Jo be used for two reasons: (1) cutting and fitting oi asbestosoontaining msulation'generates significant amounts of airborne asbestos fiber even though it cannot be seen, and (2) eventually asbestos will be banned from use completely except where suitable substitutes are not available. Future regulations may even require complete removal of asbestos already installed in Company facilities.
Currently, there is not any one material on the market which can be substituted for asbestos in all of us applications. As regulations tighten, it is expected that manufacturers will produce substitute materials. There are insulation substitutes currently on the market and some are listed in "Mechanical Design and Equipment Standards" (Plant Engineering Office, Manufacturing Staff, Page M4-1, January 1976). Typical substitutes are listed below:
Steam Piping
Inside Boiler Houses
Manufacturer
Certain-Teed Saint Gobain (CSG) Johns-Manville Owens-Corning Celotex Corporation Pabco
Inside Manufacturing and Office Building
Manufacturer
Certain-Teed Saint Gobain (CSG) Johns-Manville Owens-Corning Fiberglas Pabco
Acceptable Material
Snap-On (to 450 F) Calcium Sulicate Kaylo Careytemp Expanded Silica (1/2'') Calcium Silicate
Acceptable Material
Snap-On Flame Safe Heavy Density Sectional Calcium Silicate
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Condensate Piping -- (Inside Building)
Manufacturer
Acceptable Material
Armstrong Cork Co. Certain-Teed Saint Gobain (CSG) Johns-Manville Owens-Corning Fiberglas
FR/Arniaflex
Snap-On Flame Safe One Piece
Brake and Clutch Repair
t
Brake and clutch mechanisms on vehicles, presses and cranes utilize asbestos friction
materials. Overexposure to asbestos fiber in the air can occur during inspection and
repair operations especially when compressed air is used to blow off dust. The Plant
Engineering Office. Manufacturing Staff Maintenance Bulletin No. 13? recommends a
procedure for minimizing asbestos fiber exposure. Important points are summarized
below:
.
. Under no circumstances should compressed air blowoffs be used to clean parts which
may contain asbestos laden dust.
* ----
. Brake and clutch mechanisms should be cleaned using an industrial vacuum cleaner with a filter system capable of capturing a three micron particle"sTze." Information is
available from the Industrial Hygiene and Toxicology Department on availability of recommended units.
. Disposal of any asbestos laden waste resultant from brake or clutch repair find maintenance or from vacuum cleaning should be by an employe wearing an approved respirator. The waste material and any vacuum cleaner bags should be placed in
sealed containers and labeled as to the hazardous nature of their contents. Vacuum cleaner bags are not to be emptied by shaking: these bags are not to be reused.
_The repair area should be kept clean of all visible dust on the floor. Even small
amounts become airborne repeatedly by pedestrian and vehicular traffic. If sweeping is practiced, it should be done only after wetting down the floor. Approved vacuum cleaners should be used to clean the dried asbestos dust from the floors. Conventional vacuum cleaners may not be capable of retaining asbestos fibers which
may penetrate the filter and he dispersed into the air.
. Any grinding or cutting of asbestos containing material must be done with local exhaust ventilation wmcfc conforms to OSHA Standard 1910.1001.
General Precautions
The work practices above are intended to help in minimizing the hazard involved in
handling this substance. In addition to insulation removal and brake and clutch repair, the following general precautions are recommended which pertain to respirator usage:
Employes must be trained in the proper use of respirators and their limitations.
. Respirators should be cleaned and disinfected after each day's use.
. Employes must be evaluated by medical personnel to determine if they are qualified to do required tasks while wearing respirators.
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Initial monitoring must be conducted (as prescribed in CFR 1510.1001 (F)(1) to determine if employes exposure to asbestos is below allowable levels.
There are other maintenance materials that may contain asbestos and may be in use at Company facilities. To the extent that commercially available alternates are available}
they should be substituted for any materials presently in use which may contain asbestos. While the following list, condensed from a government synopsis of asbestos-containing
products, is not all inclusive, it can be useful m suggesting candidate materials for which asbestos substitutes may already be available:
. Paper Products:
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pipe and boiler covering, sheets for heat insulation, millboard sheet, filtering materials.
. Cloth and Woven Products:
seals for high temperature gaskets, valve stem packing, insulation for glass-handling tools.
. Flame Resistant Garmets:
gloves and mittens, sleeves and arm protectors, aprons, blankets.
. Asbestos Cement Products: welding shields, siding.
Miscellaneous:
acoustical and sprayed thermal insulation, asbestos powder, bulk fiber.
In future Plant Engineering Letters we plan to include additional information on asbestos us well as on other material which could contain potentially carcinogenic substances.
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