Document gDrvxBVzYLdd31rNV0grLkzR9

sum Association PLAINTIFFS EXHIBIT GP-249 01 North Wells Street, Chicago, Illinois 60600 (312) 72C-5675 July 6, 1973 TO ALL MEMBERS OF THE TECHNICAL COMMITTEE Re: Asbestos In Joint Treatment Compound Gentlemen; The Board of Oirectors of the Association approved an in vestigation of the problem of hazards resulting from asbestos re leased in sanding and mixing joint compound. As a result, a meeting was held in Washington, 0. C. with representatives of 0SHA, in which they encouraged the Association to pursue a testing and monitoring program to determine the extent of hazards occuring in the use of joint compound as well as other effects of gypsum dust. To date, Oirectors have responded to my report of the OSHA meeting dated July 11, 1973,- with support and concurrence that the Association undertake a program to assess asbestos hazards in the use of joint compound. Therefore, it is requested that available data be sent to me, for collection and consolidation, of investigations' of the asbestos problem undertaken within the member companies. Also, it Is requested that each company nominate a candidate to serve on an Association sub committee to appraise the data, analyze the problem, and develop a monitoring program for presentation to OSHA that would reflect the consensus position of the Association's membership. The candidate proposed should have good knowledge of appropriate testing, screening, field application procedures, and possibly OSHA and NIOSH requirements. A four man subcommittee would seem practical. It is recommended that this subcommittee meet in August to begin the work. Please give this your early consideration. Yours very truly,' GYPSUM ASSOCIATION 6 >0*. J HBC'.mj cc: Board of Directors Chairman of all Committees f H. B. Carlsen, Secretary Technical Committee Citation No 1. 2. 3. PROPOSEO PENALTY Proposed Penalty $800.00 800.00 800.00 Item No 1. 2. 3. 4. 5. 6. 7. OTHER VIOLATIONS Proposed Penalty $ 90.00 90.00 None None None 90.00 90.00 Total for All Alleged Violations $2760.00 CITATION FOR SERIOUS VIOLATION Standard or Regulation Allegedly Violated Description of Alleged Violation Date on Which Alleged Violation Must be Corrected 29 CFR 1910.93a (b) Page 22142 Citation No. 1 Failure of the employer to maintain employee exposure to airborne con centrations of asbestos fibers be low acceptable levels: 1) Concentrations below 5 fibers, longer than 5 microns, per CC, based on an 8 hour Time Weighted Average, MULTI-STEP ABATEMENT 2} Concentrations, at any time, below 10 fibers, longer than 5 microns, per CC. 29 CFR 1910.93a (d) (2) Page 22143 Citation Mo. 2 Failure of the employer to provide, and for the employees to use, U.S. Bureau of Mines approved respirators to prevent inhalation of airborne asbestos dust fibers (within the dry mixing and packout area). MULTI-STEP ABATEMENT 29 CFR 1910.93a (d) (2) (iv) Page 22143 Citation No. 3 Failure of employer to establish a respiratory program throughout the dry mixing area in accordance with the American National Standard Practice for Respiratory Protection Z38.2-1969, for employees who are exposed to excessive asbestos dust concentrations. MULTI-STEP ABATEMENT CITATION t Item Number Standard or Regulation Allegedly Violated 1. 29 CFR 1910.93a (d) (3) Page 22143 2. 29 CFR 1910.93a (d) (4) Page 22143 3. 29 CFR 1910.93a (f) (2) (11) Page 22143 4. 29 CFR 1910.93a (9) 0) (i) Page 22143 Description of Alleged Violation Date on Which Alleged Violation Must Be Corrected Failure of the employer to provide and require use of special clothing, such as coveralls or similar whole body coverings, gloves, and foot coverings to prevent skin contact with asbestos fibers, of employees within the dry mix and packout area. Multi-Step Abatement Failure of the employer to provide change rooms, two separate clothes lockers for work and street clothes, and the laundering and handling of work cothes for all employees exposed to airborne concentrations of asbestos fibers in excess of prescribed limits, within the joint compound mixing and packout area. Multi-Step Abatement Failure of the employer to establish a personal monitoring program at intervals not greater than 6 months within the joint compound mixing and packout areas where asbestos exposure may reason ably be foreseen to exceed prescribed limits. Multi-Step Abatement Failure of employer to post "Caution" signs at all approaches to the joint compound mixing and packout area where airborne concentrations of asbestos fibers may be in excess of prescribed limits. . Multi-Step Abatement -2 - 5. 29 CFR 1910.93a Failure of the employer to Multi-Step Abatement (g) (2) (i) affix a "Caution" label to all Page 22144 raw materials, mixtures, scrap, waste, debris and other products containing.asbestos fiber to prevent exposure to concentra tions above prescribed limits during any reasonably foreseeable use. 6. 29 CFR 1910.93a Failure of the employer to (h) (1) Page maintain all external surfaces 22144 within the joint compound, dry. mixing and packout area, free of accumulations of asbestos fibers (dry sweeping Is to be discouraged, utilize vacuum sweeping methods). Multi-Step Abatement 7. 29 CFR 1910.93a Failure of the employer to Multi-Step Abatement (h) (2) Page collect and dispose of all 22144 asbestos waste, scrap, debris, bags, containers, contaminated clothing in sealed impermeable bags to prevent any forseeable airborne concentrations of asbestos fibers above the allow able limits. MULTI-STEP ABATEMENT Immediate Temporary Administrative Controls Initiate immediate temporary administrative controls to prevent employee exposure to excessive asbestos dust concentrations by July it 1973. A Compliance Officer will determine if these temporary controls are preventing empLoyee exposure.. (L) Provide U. S. bureau of Mines approved respirators for ali employees working within the joint compound dry mixing and pack out areas of the main plant. Continue the use of respirators until the installation of permanent engineering controls. (2) Establish a complete respirator program in accordance with the provisions of the American National Standard Practices for Respiratory Protection Z88.2-1969. (3) Establish a program for maintaining the joint compound dry mixing and pack out areas of the main plant in a clean, orderly and sanitary condition to prevent asbestos dust contamination of the air. This program will include utilizing ; scaled impermeable bags for the storage of waste asbestos. (4) Provide employees with protective clothing that can be maintained in a sanitary and reliable condition from becoming contaminated with asbestos. In addition, provide employees with individual clothes lockers to prevent their personal clothing from becoming contaminated with asbestos dust. (5) Establish a personal monitoring program to determine, at six month intervals, the concentrations of asbestos dust. (6) Post asbestos "Caution" signs at all approaches to the work area to prevent unprotected persons from entering. (7) Affix asbestos "Caution" labels on all raw materials, mixtures, scrap, waste, debris and other products containing asbestos to prevent exposure to asbestos dust. Permanent Engineering and Administrative Controls (1) By July 27, 1973, submit a plan for approval to the U. S. Department of Labor, Occupational Safety and Health Adminis- showing a timetable for the installation ot engineering controls to prevent employee exposure to asbestos dust concentrations above allowable limits. (2) Incorporate Items (3) through (7) (listed as temporary adminis trative controls in Part I) as permanent administrative controls to prevent employee asbestos dust exposure.