Document gaBwDjKv7ZeaOdEEOaenXxr93

c... r U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY MO HEALTH ADMINISTRATION In the titter of:<32?. OSHA No.(s): 7 Sp&. / <Z>S7irt!>GZL. ' .' ' INFORMAL SETTLEMENT AGREEMENT The undersigned Employer and the undersigned Occupational Safety and Health Administration (OSHA), in settlement of the above citation(s) and penalties Y/hich were issued on^^<i/%g31 hereby agree as follows: 1. The Employer agrees to correct the violations as cited, in the above citations or as amended below. 2. The Employer agrees to pay the proposed penalties, if any, as issued' with the- above citation( s), or, if amended by this agreement, as amended below. ' 3. The_ Employer and OSHA agree that the following citations and penalties (if any) are not being amended by this agreement: 4. OSHA agrees that the following citations and penalties are being amended as shown (see attachments): , C 002181 CBY 3103787 (r 5. The Employer, by signing this informal settlement agreement, hereby waives its rights to 'contest the above citation(s) and penalties, as amended in paragraph 4 of this agreement. 6. The Employer agrees to immediately post a copy of this Settlement Agreement in a prominent place at or near the location of the violations )~' . referred to`in paragraphs 3 and 4 above. This Settlement. Agreement must . remain posted -until the violations cited have been corrected, or for 3 . . working days (excluding weekends and Federal Holidays), whichever is longer* FOR THE OCCUPATIONAL SAFETYAMD HEALTH ADMINISTRATION NOTICE-TO EMPLOYEES The law gives you or your representative the opportunity to object to any ' abatement date set for a violation if you believe the date to be unreasonable. Any contest to the abatement dates of the citations' amended in .paragraph 4 of this Settlement Agreement must be mailed to the U.S. Department of Labor-OSRA, 2320 LaBranch, Room 2118, Houston, Texas 77004, within 15 working days (exclud ing weekends and Federal Holidays) of the receipt by the Employer of this Settlement Agreement. You or your representative also have-the right to object to any of the abatement dates set for violations referred to in paragraph 3 provided that the objection is mailed to the office shown above within the'15 working day period established by the original citation. C 002182 CBY 3103768 ( U,3. Department Of Labor Houston Area Office 2320 LaBranch, Room 1103 Houston, Texas 77004 August 22, 1983 c Cz ;jpational Sa'ety and Health ; :t -A'Z'Mn Reply to ths Attention of: Monsanto Fibers and Intermediates Company and its successors P.0. Box 1311 Texas City, Texas 77590 ATTN: Mr. Gene L. Tromblee, Plant Manager RE: M6013-167 Dear Mr. Tromblee: Enclosed you will find citations for violations of the Occupational Safety and Health Act of 1970 (the Act) which may have accompanying proposed penalties. Also enclosed is a booklet which explains your rights and responsibilities under the Act. As indicated on page 2 of the booklet, you may request an informal conference with me during the 15-working-day notice of contest period. During the informal conference you may present any evidence or views which you believe would support an adjustment to the citation or the penalty. If you decide to request an informal conference, please complete the form at the bottom of this letter and post it next to the citations immediately after determining the time, date, and place of the informal conference. If you have any questions about the enclosed citations and penalties, I would welcome further discussion at the informal conference; and, where warranted, I am authorized to enter into an informal settlement agreement with you which amicably resolves this matter without litigation or contest. If you have any questions regarding the informal conference, please contact me. Sincerely, GERALD A. BATY Area Director Enclosures 'S q..AA^ An informal conference has been scheduled with 03HA do discuss the citations issued on 8-23-83 . The conference will be held at the 0SHA office located 2*ZQ on 9-/ - 83 at J03 Q (Address) (Date) (Time) CBY 3103789 C 002183 days (excluding weekends and federal non- days) whichever is longer. This citation describes violations of the Occupational Safety and Health Act of 1970. The penalty(ies) listed below are based on these violations. You must correct the violations referred to in this citation by the dates listed below and pay the penalties proposed, unless within 15 working days (excluding weekends and Federal holidays) from your receipt of this citation and penalty you mail a notice of contest to the U.S. Department of Labor Area Office at the address shown above. (See the enclosed booklet which outlines your responsibilities and courses of action and should be _re_a_d _in_c_o_n_ju_n_ct_io_n_w_i_th__th_is_f_o_rm_._) ITEM NUMBER STANDARD, REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION DATE BY WHICH VIOLATION MUST BE CORRECTED 10 PENALTY The issuance of this citation does not constitute a finding that a violation of the Act has occurred unless there is a failure to contest as provided for in the Act or, if contested, unless the citation is affirmed by the Review Commission. The violations described in this citation are alleged to have occurred on or about the day the inspection was made unless otherwise indicated within the description given below. 1 29 CFR 1910.1001(f)(2)(ii): The airborne asbestos monitoring schedule was not of sufficient frequency and pattern as to represent with reasonable accuracy the levels of employee exposure to airborne asbestos fibers: Immediately Upon Receipt $0 (a) Monsanto Fibers and Intermediates Company in Texas City, Texas, does not conduct personal monitoring for airborne asbestos fibers at intervals of 6 months of less for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph b of 29 CFR 1910.1001. 2 29 CFR 1910.100l(j)(2): The employer did not provide or make available, to each employee, within 30 days following his first em ployment in an occupation exposed to airborne levels of asbestos fibers, a comprehensive medical examination: 9/26/83 $0 (a) On June 30, 1983, an employee working on Unit 16 E2 was exposed to 0.28 fibers per cubic centimeter of air. This exposure occurred during an asbestos insulation removal. The sample taken was a 15-minute ceiling sample. '* AREA DIRECTOR GERALD A. BATY sd a / 0 0dl?185 CBY 3103791 $0 NOTICE TO EMPLOYEES -- The law gives an .employee or his representative the opportunity to object to any abatement date set for a violation if he believes the date to be unreasonable. The contest must be mailed to the U.S. Department of Labor Area Office at the address shown above within 15 working days (excluding weekends and Federal holidays) of the receipt by the employer of this citation and penalty. EMPLOYER DISCRIMINATION UNLAWFUL - The law pro hibits discrimination by an employer against an employee for filing a complaint or for exercising any rights under this Act. An employee who believes that he has been discriminated against may file a complaint no later than 30 days after the discrimination with the U.S. Department of Labor Area Office at the address shown above. EMPLOYER RESPONSIBILITIES AND COURSES OF ACTION -- The enclosed booklet outlines employer responsibilities and courses of action and should be read in conjunction with this notification. TOTAL PENAL! FOR THIS CITATION MakecheckorMot Order Payable T "POLOSHA*' Indicate OSHA K on Remittance CITATION AND NOTIFICATION OF PENALTY OSHA-2 REV. 5/76 days {excluding weekends and Federal holi days) whichever is longer. This citation describes violations of the Occupational Safety and Health Act of 1970.. The penalty(ies) listed below are based on these violations. You must correct the violations referred to in this citation by the dates listed below and pay the penalties proposed, unless within 15 working days (excluding weekends and Federal holidays) from your receipt of this citation and penalty you mail a notice of contest to the U.S. Department of Labor Area Office at the address shown above. (See the enclosed booklet which outlines your responsibilities and courses of action and should be read in conjunction with this form.) ITEM NUMBER STANDARD, REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION DATE BY WHICH 10 VIOLATION MUST BECORRECTED PENALTY The issuance of this citation does not constitute a finding that a violation of the Act has occurred mless there is a failure to contest as provided for in the Act or, if contested, unless the citation is affiraed by the Review Consaisaicn. The violations described in this citation are alleged to have occurred cm or about the day the inspection was made unless otherwise indicated within the description given below. 1 29 CFR 1910.100l(f)(2)(ii): The airborne asbestos monitoring schedule was not of sufficient frequency and pattern as to represent with reasonable accuracy the levels of employee exposure to airborne asbestos fibers: Immediately Upon Receipt $0 (a) Monsanto Fibers and Intermediates Company in Texas City, Texas, does not conduct personal monitoring for airborne asbestos fibers at intervals of 6 months of less for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph b of 29 CFR 1910.1001. 2 29 CFR 1910.100l(j)(2): The employer did not provide or make available, to each employee, within 30 days following his first em ployment in ao. occupation exposed to airborne levels of asbestos fibers, a comprehensive medical examination: 9/26/83 $0 (a) Cn Jwe 30, 1983, an employee working on Cult 16 E2 was exposed to 0.28 fibers per cubic centimeter of air. This exposure occurred during an asbestos insulation removal. The sample taken was a 15-oinute ceiling sample. C 002186 "AREA DIRECTOR GERALD A. BATY CBY 3CoD02186 $0 NOTICE TO EMPLOYEES -- The law gives an employee or his representative the opportunity to object to any abatement date set for a violation if he believes the date to be unreasonable. The contest must be mailed to the U.S. Department of Labor Area Office at the address shown above within 15 working days (excluding weekends and Federal holidays) of the receipt by the employer of this citation and penalty. EMPLOYER DISCRIMINATION UNLAWFUL - The law pro TOTAL PENAL! FOR THIS hibits discrimination by an employer against an employee for CITATION filing a complaint or for exercising any rights under this Act. Mliik.ch.ckorMor An employee who believes that he has been discriminated Order Payable Ti against may file a complaint no later than 30 days after the "DOLOSHA" discrimination with the U.S. Department of Labor Area Office Indicate OSHA N n Remittance at the address shown above. EMPLOYER RESPONSIBILITIES AND COURSES OF ACTION -- The enclosed booklet outlines employer responsibilities and courses of action and should be read in conjunction with this notification. CITATION AND NOTIFICATION OF PENALTY OSHA-2 REV. 5/76 The undersigned (check one) For Offici*1 Use Only Area Date Received 3280 Region 6/27/83 Received By ' 6 LCB Time 11:45 AM Formal 0 Non Formal O 13 Employee Representative of Employees Other (specify) believes that a violation at the following place of employment of an occupational safety or health standard exists which is a job safety or health hazard. Employer's Name MONSANTO CHEMICAL Employer's Address (Street) (City) 201 Bay Street (Stete) Texas 1. Kind of business Chemical plant -- (Zip Code) 77590 Texas Citv Telephone 945 4431 2. Specify the particular building or worksite where the alleged violation is located, including address. Dept. 15 & 16; Dept. 19; Dent. 48-56 and Dept. Power #2________________________________________ 3. Specify the name and phone number of employer's agent(s) in charge. Gene Tromblee. Plant Manager________________ 4. Describe briefly the hazard which exists there including the approximate number of employees exposed to or threatened by such hazard. Pipefitters have been removing asbestos insulation wif-hmtf- wparing the PrnPpr P(ar^nn*'1 V protective equipment. Company has taken samples to determine where the ashftstns ic located, but some insulation has been mistakenly identified nnn-achnctnc OSHA-7 (Rev. October 1977) C 002187 CBY 3103793 CONTINUED ON REVERSE SIDE 31.8204 in r c REFERENCE FILE Tabic Z-2 Materia] 3*hotir time weighted average Acceptable ceiling concentration Acceptable maximum peak above the acceptable celling conccntra* tlon lor an 8-hour shut, -- Concentration Maximum duration Benzene <ZJ7 1961) ...................... .............. 10 p.p.m............25 p.p.m.......... ... 60 p.p.m............. 10 minutes. UerylUutn and beryllium compounds 2 .............. 5 ........... 26 ...... 30 minutes. (Z37,29-1970) Cadmium dM*t <7.37.8-1970)..........................0,2mf./M............*Ml....................................................... Cadmium fume (Z.17.6-1970)............... 0.1 mg./M*.......... 0 3nif \f' ................................ . Carbon dlsulftdM7.37.3-l98).......................20 p.p.m............... 30 p.p.m................. ICO p.p.m:...Ill 10 minutes. Carbon tetrachloride (Z37.I7-1087).............. I0p.p.m............... 26 p.p.m............... 200 p.p.m....... 6 minute* In Chromic add and chromate* (Z37.7-I971).................................I mg'lOM'........... ............................. . any 4 hours. Kthylanedihromlda (737.31-1970)............. 20 p.p.m............. 30 p.p.m...............50 p.p.m............... 6 mlnufM. Ethylene dichlorlde (Z37.2M9W)................ 60 p.p.m............. 100 p.p.m............. 200 p.p.m........... 6 minutes In any 3 hours. Fluoride a* du*t (237.9-1000)...................... 2.8m*VM*......................................................................... Formaldehyde (Z37.id-tMrt7)............... 3 p.p.ui......... 5 p.p.m......... 10 p.p.m........ 30 minute*. Hydrogen fluoride (7.37.V-KM9)....................3 pp m..................... .................. .................................... Hydrogen sulflde (Z37.2-1M6)..................................................... p.p.m................ fiop.p.m............... 10 minute* once only If no other measur able exposure Lead arid its inorganic compound! 0.2 mg/m* oevun. (2 37 11-1969) Mercury (7.37.8-1971)................................................................ 1 mg./lOM .................................. Mclhvl (blonde >7.37 I8-I9S9) .................... lOOp.p.in.......... 200 p.p.m.................. 300p.p.m.. 6 minutes In any 3 hours, Methylene Chloride (Z37.23-I96II....................... 600 p.p.m......... 1,000 p.p.m........... 2,000 p.p.m 6 minutes In Organo (alky!) mercury (Z37.30-1900)...........0.01 mg./M*... 0.04 m*./M .......................................... any 2 hours. Btyrana (Z37.16-t06!............................. 100 p.p.m............ 20t)p.p.m.................. 600 p.p.m6.m. inutes In any 3 hmjrs, Tatrachloroathylana (Z37.23-1M7)..................... 100 p p m............200 p p m......................too ppm... Toluene (Z37.12-1M7)............................................. 200p.p.m..... 300pp.m.....................600p|..m.a 6 minutes In any 3 hours. 10 minutes. Trichloroethylene (7,37.19-1967).................... too ppm ........2i>o p p m..........--. 300 p.p.m........ 6 minutes In any 2 hours. [Table Z-2. footnote 1 deleted by 46 FR 32021. June 19, 1981} Table 2*3--Mineral Dust* Aerodynamic ritnmetrr Percent p**fng Substance Mppef Mg/M* (unit density sphere) selector Silica: Crystalline: Quarts (respirable).............. 250* lOmg/M1* %SlOi+8 9e?10i*-2 Quarts (total dust)................................... 30mg/M* CrlMobaUt*: Tallin caletilatM from Hie %SiO,f2 2 90 2.5 76 3.5 60 6.0 26 10 0 The measurements under this note refer to the u<e of an KV.C Instrument, ft the respirable fraciluii of coal duf I* determined with a.MRE the flutire corrp-pondln* to that of 2 t Mg.M* in the table lor coal dust Is 4 3 count or mass formulae for quartz. Tndymite: Vxe the value calculated from the for mulae lor quant. 1910.1001 Asbestos. (a) Definitions. For the purpose of Amorphous. Including natural diatomaceous earth.......... this section, (1) ``Asbestos" includes 20 80mr,'M* chrysotile. amoslte, crocidolite, tremo- %S1Qi lite, anthophyllite. and actinollte. Slllrales (less than 1% crys- (2) "Asbestos fibers'' means asbestos talline silica): Mica...................................... SonpUnne............................. Talc (non-oshcMnx form)' . Talc (tihmu*). Use asbestos limit .. ... . Tremolite(eo tale, fibrous) Portland cement........... . Oraphite (natural).......... ,,..... . Coal dust ireplral*le fraction less than &% SiOj)............... 20 20 20* 50 15 For more than 5% SlOt............... ...... ....... Inert nr Vulancc Oust: Itepirahle fraction......... . 16 fibers longer than 5 micrometers. (b) Permissible exposure to airborne concentrations of asbestos fibers--(1) Standard effective July 7. 1972. The 8-hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed 2.4mg/.M* shall not exceed five fibers, longer than or lOmt/M* ftSiOt+2 5 micrometers, per cubic centimeter of air, as determined by the method pre scribed in paragraph (e) of this section. 6m%!$V (2) Standard effective July 1, 1976. Total dust............................ 60 I6mg M1 The 8-hour time-weighted average air borne concentrations of asbestos fibers S'orr- rnnrrron factors tnpprfx35 3"million prh |o per cubic meter to which any employee may be exposed shall not exceed two fibers, longer than -i:ifriclci per c.e.. * Millions of |tariU'M por nthle font of air. 1ned mi Implncer xitniplex rmiiiiM by liyht-fl* Id l/vhmr*. 5 micrometers, per cubic centimeter of air. as determined by the method pre * The iwciuae* of rryxtnlhue silica in the formula scribed in paragraph ie> of this section. 1* thn amount doirrfiuned from aiMmrne sample*, c*. cept in ihnso Uimh. * in *vliich other method* have in-rn (3) Ceiling concentration. No em ritnwn to he Hpplh aide ployee shall be exposed at any time to * tloih fitm-rntratinn and fn-rmit qtmrtt for Die appli cation of Uns hunt are In !* rii'tf'rmniMl from Hi** friu M.*n p.wlng a Mi*xeleeinr with Die foUiming iharactcrHth-*: airborne concentrations of asbestos fibers in excess of 10 fibers, longer than "Containing < I% quartz; If > quartz, uo quartz, 5 micrometers, per cubic centimeter of limit. air. as determined by the method pre scribed in paragraph (e> of this section. (c) Methods of compliance--(1) En gineering methods. (1) Engineering con trols. Engineering controls, such as. but not limited to. Isolation, enclosure, ex haust ventilation, and dust collection, shall be used to meet the exposure limits prescribed in paragraph (b) of this section. Ul> Local exhaust ventilation, (a) Local exhaust ventilation and dust col lection systems shall be designed, con structed. installed, and maintained in accordance with the American National Standard Fundamentals Governing the Design and Operation of Local Exhaust Systems. ANSI Z9.2-1971, which is in corporated by reference herein. (b) See 9 1SH0.6 concerning the avail ability of ANSI Z9,2-1971, and the maintenance of a historic file In connec tion therewith. The address of the Amer ican National Standards Institute is given in { 1910.100. (lit> Particular tools. All hand-op erated and power-operated tools which may produce or release asbestos fibers In excess of the exposure limits pre scribed in paragraph <b> of this section, such as. but not limited to. saws, scorers, abrasive wheels, and drills, shall be pro vided with local exhaust ventilation sys tems in accordance with subdivision <li> of this subparagraph. (2) Work practices--<l) Wet methods. Insofar as practicable, asbestos shall be handled, mixed, applied, removed, cut. scored, or otherwise worked In a vet state sufficient to prevent the emission of airborne fibers in excess of tiie ex posure limits prescribed in paragraph <b) of this section, unless the usefulness of, the product would be diminished thereby. (ii> Particular products and opera tions. No asbestos cement, mortar, coat ing. grout, plaster, or similar material containing asbestos shall be removed from bags, cartons, or other containers in which they are shipped, without being either wetted, or enclosed, or ventilated so as to prevent effectively the release of airborne asbestos fibers in excess ol the limits prescribed in paragraph (b) of this section. (Hi) Spraying, demolition, or removal. Employees engaged in the. spraying of asbestos, the removal, or demolition of pipes, structures, or equipment covered or insulated with asbestos, and in the removal or demolition of asbestos in sulation or coverings shall be provided with respiratory equipment In accord ance with paragraph (d)<2Hiii> of this section and with special clothing in ac cordance with paragraph (d)(3) of this section. (d) Personal protective equipment-- (1) Compliance with the exposure limits prescribed by paragraph (b) of this sec tion may not be achieved by the use of respirators or shift rotation of em ployees. except: (i> During the time period necessary to install tiie engineering controls and to institute the work practices required by paragraph (c> of this section: (li) In work situations in which the methods prescribed In paragraph (c) of Occupational Safety g. Health Reporter (See. 1910.1001 (dll 11 (it) I 64 CBY 3103794 C 002188 TOXIC SUBSTANCES r r S- 1S5 31:8305 this section are either technically not feasible or feasible to an extent insuffi the safety or health of the employee or other employees will be impaired by Ms- (ii) Sampling frequency and patterns. After the initial determinations required cient to reduce the airborne concentra use of a respirator. Such employee shall by subparagraph (1) of this paragraph, tions of asbestos fibers below the limits prescribed by paragraph (b) of, this be rotated to another Job -or given the opportunity to transfer to a different po samples shall be of such frequency and pattern as to represent with reasonable section: or sition whose duties he is able to perform accuracy the levels of exposure of em (ill) In emergencies.- with the same employer, in the same geo ployees. In no case shall the sampling be (iv) Wliere both respirators and per graphical area and with the same senior done at intervals greater than 6 months sonnel rotation are allowed by subdivi sions (i), (il), or (ill) of this subpara ity, status, and rate of pay he had Just prior to such trp-isfer, if such a different for employees whose exposure to asbestos may reasonably be foreseen to exceed graph, and both are practicable, person position is available. the limits prescribed by paragraph (b) nel rotation shall be preferred and used. (3) Special clothing: The-employer of tMs section. (2) Where a respirator is permitted by subparagraph (1) of this paragraph, it shall be selected from among those ap proved by the Bureau of Mines, Depart ment of the Interior,'or the National In stitute for Occupational Safety and Health, Department of Health, Educa tion. and Welfare, under the provisions of shall provide, and require the use of, spe cial clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot coverings for any em ployee exposed to airborne concentra tions of asbestos fibers, which exceed the ceiling level prescribed in paragraph (b) of this section.- (3) Environmental monitoring--(i) samples shall be collected from areas of a work environment wMch are represent ative of the airborne concentrations of asbestos fibers wMch may reach the breathing zone of employees. Samples shall be collected on a membrane filter of 0.8 micrometer porosity mounted in 30 CFR Part II (37 FH. 0244, Mar. 25, 1972$, and shall be used in accordance with subdivisions (1), (11), (ill), and (iv) of this subparagraph. (1) Air purifying respirators. A reusa (4) Change rooms: (1) At any fixed place of employment exposed to airborne concentrations of asbestos fibers in ex cess of the exposure limits prescribed in paragraph (b) of this section, the em an open-face filter holder. Samples shall be taken for the determination of the 8hour time-weighted, average airborne concentrations and of the ceiling con centrations of asbestos fibers. ble or single use air purifying respirator, -or a respirator described in subdivision (ii) or (ill) of this subparagraph, shall be used to reduce the concentrations of airborne asbestos fibers in the -respirator below the exposure limits prescribed in paragraph (b) of this section, when the celling or the Sihour time-weighted aver age airborne concentrations of asbestos fibers are reasonably expected to exceed no more, than 10 times those limits.. (il) Powered air purifying respirators. A full facepiece powered air purifying respirator, or a powered air purifying respirator, or a respirator described in subdivision (ill) of this subparagraph, shall be used to reduce the concentra tions of airborne asbestos fibers-in the respirator below the exposure.limlts pre ployer shall provide change .rooms for employees working regularly at the place. (ii) Clothes lockers: The employer shall provide two separate lockers or con tainers for each employee, so separated or isolated as to prevent contamination of the employee's street clothes from his work .clothes. (iii) Laundering: (a) Laundering of asbestos contaminated clothing shall be done so as to prevent the release of air borne asbestos fibers In excess of the ex posure limits prescribed in paragraph (b) of this section. (b) Any employer who gives asbestoscontaminated clothing to another person' for laundering shall inform sUch person of the requirement in (a) of this.subdi vision to effectively prevent the release (ii) Sampling frequency and patterns. After the initial determinations required by subparagraph (1) of tMs paragraph, samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of the employees. In no case shall sampling be at intervals greater than 6 months for employees whose exposures to asbestos may reasonably be foreseen to exceed the exposure limits prescribed in para graph (b) of this section. (.4) Employee observation of monitor ing. Affected employees, or their rep resentatives, shall be given a reasonable opportunity to observe any monitoring required by this paragraph and shall have access to the records thereof. scribed in paragraph (b) of this section, of airborne asbestos fibers in excess of (g) Caution signs and labels. (1) Cau when the ceiling or the 8-hour time- the .exposure limits prescribed in para tion signs, (i) Posting. Caution signs . weighted average concentrations - of asbestos fibers are reasonably expected to exceed 10 times, but not-100-.times, 'those limits. graph (b) of this section. (c> Contaminated clothing shall be transported in sealed impermeable bags, or other closed, impermeable containers, shall be provided and displayed at each location where airborne concentrations of asbestos fibers may be in excess of the exposure limits prescribed in paragraph (ill) Type "C" supplied-air respirators, and labeled in accordance with para (b) of this section. Signs shall be posted continuous -flow or pressure-demand graph (g) of this section. at such a distance from such a location, class. A type "C" continuous flow or pres-- sure-demand, supplied-air respirator shall be used to reduce the concentra tions of airborne asbestos fibers in the respirator below the exposure limits pre scribed in paragraph (b) of this section, - when the ceiling or the 8-hour time- (e) Method of measurement. All de terminations of airborne concentrations of asbestos fibers shall be made by the membrane filter method at 400-450 X (magnification) (4 millimeter objective) with phase contrast illumination. (f) Monitoring--(1) Initial determi so that an employee may read the signs and take necessary protective steps be fore entering the area marked by the signs. Signs shall be posted at all ap proaches to areas containing excessive concentrations of . airborne asbestos fibers. weighted average airborne concentra nations. Within 6 months of the publi (ii). Sign specifications. The warning tions of asbestos fibers are reasonably cation of this section, every employer signs required by subdivision (1) of this expected to exceed 100 times those limits. shall cause every place of employment subparagraph shall conform to the re (iv) Establishment of a respirator pro where asbestos fibers are released to be quirements of 20" x 14" vertical format gram. (a) The employer shall establish monitored in such a way as to determine signs specified in 91910.145(d)(4), and a respirator program in accordance with whether every employee's exposure to to this subdivision. The signs shall dis the requirements of the American Na asbestos fibers is below the limits pre play the following legend in the lower' tional Standards Practices for Respira scribed in paragraph (b) of this sec panel, with letter sizes and styles of a tory Protection, ANSI Z88.2-1969, which tion. If the limits are exceeded, the em visibility at least equal to that specified is incorporated by reference herein. ployer shall immediately undertake a in this subdivision. b. See 9 1910.6 concerning the, avail ability of ANSI Z88.2-1969 and the'malntenance of an historic file in connection therewith. The address of the American compliance program in accordance with paragraph (c) of this section. (2) Personal monitoring--(l) Sam ples shall be collected from within the tegcnd Aabeftos Ji" San* Bertf. ' Notation Gothic or Block. National Standards Institute is given in breathing zone of -the employees, on Du*t Hazard____: %" Sana Serif, 9 1910.100. membrane filters of 0.8 micrometer po Gothic or <c) No employee shall be assigned to tasks requiring the use of respirators if, based upon his most recent examination, rosity mounted in an open-face filter holder. Samples shall be taken for the determination of the 8-hour time- Avoid Breathing Dust-- Wear. Assigned Protective Equipment. Block. % ".Gothic. V4" Gothic. an examining physician determines that weighted average airborne concentra Do Not Remain In Ares )4 "Gothic. the employee will be unable to.function tions and of the ceiling concentrations of Unless Your Work Re normally wearing a respirator, or that asbestos fibers. quires it. 2-17-83 [Sec. 1910.1001(B>(lHii)l Published by THE BUREAU OE NATIONAL AFFAIRS, INC., WASHINGTON, D.C. 20037 65 c 002189 CBY 3103795 31:8306 c ( REFERENCE FILE Notation fied in writing cf the exposure as soon as tional exposure to asbestos fibers. Breathing Asbestos Dust 14 point Gothic. practicable but not later than 5 days of the (Section 1910.1001(j)(6)(ii) amended at May be Hazardous To Your Health finding. The employee shall also be timely notified of the corrective action being taken. Spacing between lines shall be af least' equal to the height of the upper of any two lines: (2) Caution, labels--(1) Labeling. C&u.tlon labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been- modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentra tion* of asbestos fibers in excess of the exposure limits prescribed In paragraph (bl of this section will be released. <li) Label specification*. The caution labels required by subdivision (0 of this subparagraph shall be printed in letters of sufficient size and contrast ae to be readily visible and legible. The label shall, state: . Caution' 7 - <J) Medtcat tftwtnbffoi*4-.(l) Gen eral. The employer shall provide or make available at his cost, medical examines, tions relative to exposure to asbestos re quired by this paragraph. (2) Preplacement. The employer'liKall provide or make available to each of his employees, within 30 calendar days fol lowing his first employment in an occupation exposed to firborne con centrations of asbestos fibers, a compre hensive medical examination, which shall include, as a minimum, a chest roent genogram (posterior-anterior 14 x 17 inches), a history to elicit symptom atology .of respiratory . disease, and pulmonary function tests to include .forced vital capacity (FVC) and forced expiratory wolmaaat --red -fFEVi,.)-. ~'t(Z\'-Anr.uai examinaHoni~ Oiror-'be fore January ~31, 1973, and at least an-s nually thereafter/ every employer shall provide, or make available, comprehen-, sive medical examinations to each of his; employees engaged in occupations ex-: 45 FR 35212. May 23, 1980. effective August 21. 1980; corrected bv 45 FR 54333, August 15. 19801 8 S 19(0.1002 Coal tar pitch volatiles; Interpretation of term. As used in 1910.1000 (Table Z-l), coal tar pitch volatiles include the fused polycyclic hydrocarbons which ` volatilize from the distillation residues of coal, petroleum (excluding asphalt), wood, and other organic matter. Asphalt (CAS 8052-42-4, and CAS 64742-93-4) is not covered under the "coal tar pitch volatiles" standard. (Sec. 1910.1002 revised by 48 FR 2768, January 21, 1983] % 1910.1003 4-Nitrobiplienyl. , (a) Scope pud application. (1) This section applies to any area in which J-Nitrobiphenyl, Chemical Abstracts Service Registry Number 92933 is manu factured, processed, repackaged, re* leased, handled, or stored, but shall not UPply to transshipment in sealed con* tainers, except for the labeling require ments under paragraphs (e) (2), (3), ana Contains Asbestos Fibers posed to airborne concentrations of as (4) of this section. - Avoid Creating- Dust bestos fibers. Such annual examination G2> This section shall not apply to Breathing Asbestos Dust May Causa shall include,- as a minimum, a chest, solid or liquid mixtures containing lesi Serious Bodily Harm. roentgenogram (posterior-anterior 14 * than (f.l percent by weight or volume of (h) Housekeeping.--(i) Cleaning. All' 17 inches), a history to elicit symptom-: '4-Nitrobiphenyl. external surfaces in any place of employ atology of respiratory disease, and (b) Definitions. For the purposes of ment shall be maintained free of accu pulmonary function tests to include .this section: (1) "Absolute filter" is one mulations of asbestos fibers if, with their forced vital capacity (FVC) and forced capable of retaining 99.97 percent of a dispersion, there would be an excessive expiratory volume at 1 second (FEV,.a). mono disperse aerosol of 0.3 /*m particles, concentration. (4) Termination oTemployment. The' (2) "Authorized employee" means an (2) Waste disposal. Asbestos waste! employer shall provide, or make avail employee whose duties require him to be scrap, debris, bags,' containers, equip ment, and bsbestoS-contaminated cloth ing, consigned for disposal, which may produce in any reasonably foreseeable able, within 30 calendar dayj'befbre or after the termination of employment of any employee engaged in an occupation, exposed' to airborne concentrations of in the regulated area and who has been Specifically assigned by the employer. (3) ""Clean change room" means a room where employees put on' clean use, handling, storage, processing, dis asbestos fibers, a comprehensive medical Slothing and/or protective equipment in posal, or transportation airborne concen examination which shall include, as a to* environment free of 4-Nltroblphenyl, trations of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section shall be collected and disposed of in sealed impermeable bags, or other closed; Impermeable containers. (i) Recordkeeping--Exposure rec ords. Every employer shall maintain-rec ords of any personal or environmental monitoring required by this section. Rec ords shall be maintained for a period of at toast 20 years and shall be made avail able upon request to the Assistant Sec retary of Labor for Occupational Safety and Health, the Director of the National Institute for Occupational Safety and Health, and to authorised representa tives of either. 11910.1001(0(1) amended at 41 FR 11505, March 19, 1976) (2) Access. Employee exposure records required by this paragraph shall be pro vided upon request to employees, designated representatives, and the Assistant Secre tary in accordance with 29 CFR 1910.20 (a)-(e) and (g)-(I). [Section 1910.1001(0(2) amended at 45 FR 35212, May 23, 1980. effective August 21. 1980] (3) Employee notification. Any employ ee found to have been exposed at any time minimum, a chest roentgenogram (pos-: The clean change room shall be con terior-anterior 14 x 17 inches), a history- tiguous to and have an entry from a Jto elicit symptomatology of respiratory disease, and pulmonary function tests to Include forced vital capacity <FVC1. hower room, when the shower room acuities are otherwise required ln'thls section^ and forced expiratory volume at 1 second (4> "Closed system" means an opera (FEVi.).:-. ''> ' ' "(5) ReEeht examinations. "No "hiedidir examination :ls required of any em ployee, if adequate records show that' Uwemployee has been'-examined in ae-' tion involving 4-Nitroblphenyl where iinment prevents the release of 4- Eblphenyl into regulated areas, non- ated areas, or the external environ- jnenty _ ;__ cordance with this paragraph within tit* gast l-year period. -7, ' (6) Medical' * records--71) Maintenance. Employers of employees examined pursuant to this paragraph shall cause to be maintained complete and accurate records of all such medical examina tions. Records shall be retained' by employers for at least 20 years. (ii) Access. Records of the medical examinations required by this paragraph <) "Decontamination" nwanAthe In activation of 4-Nltrobiphenyl or Its safe disposal. .... "/T6) "Director" means the Director, national ' Institute for Occupational Safety and Health, or any person di- Tscted by hint or the Secretary of Health, jEducatlon, and Welfare to act for the ptrector. '(TT'^Bisposal" means the safe re moval of 4-Nltroblphenyl from the work environment. shall be provided upon request to em ployees, designated representatives, and the Assistant Secretary m accordance with 29 CFR 1910.20<a)-(e) and (g)-(i). These records shall also be provided upon the request to the Director of NIOSH. Any physician who conducts a medical exam r> (S) "Emergency" means an unforseen .-circumstance or set of circumstances re.suiting in the release of 4-Nitroblphenyl which may result in exposure to or con tact with 4-NltrobiphtenyL (9) "External environment" means any ination requirecTby this paragraph shall environment external to regulated and furnish to the employer of the examined nonregulated areas. to airborne concentrations of asbestos fi employee all the information specifically (10) "Isolated system" means a fully bers in excess of the limits prescribed in required by this paragraph, and any other enclosed structure other than the vessel of paragraph (b) of this section shall be noti medical information related to occupa- containment of 4-Nitrobipheny), Oceupafional Safety & Health Reporter [Sec. 1910.1003(b) (10)1 66 c CAY 3103796 C 002190 BRIEF SUMMARY OF OSHA INSPECTION Last week (6/28-7/1) an OSHA inspector Investigated an employe# plaint on asbestos handling in the Texas City Plant. The complaint stated: "Pipefitters have been removing asbestos insulation without wearing the proper personal protective equip ment. The Company has taken samples to determine where the asbestos is located, but some insulation has been mistakenly identified as non-asbestos." The inspector interviewed both hourly and salaried employees, observed our work practices and reviewed our medical and industrial hygiene pro cedures related to asbestos handling. The inspector was favorably impressed with much of what he saw but the possibility of citations in two instances exists. We plan further discussions with the inspector's supervisor on the areas in question. GWD/ob 7-6-83 6LT'* Staws CBY 3103797 c 002191 cc *c- s-LI OSHA INSPECTION OSHA Inspector, Rex F. McKinney, Industrial Hygienist, appeared at the gate at 13:00 hours on Tuesday, June 28. The purpose of his visit was to investigate an employee compaint stated as follows: "Pipefitters have been removing asbestos insulation without wearing the proper personal protective equipment. The Company has taken samples to determine where the asbestos is located, but some insulation has been mistakenly identified as non-asbestos." This complaint was filed with OSHA on 6/27/83, at 11:45 a.m. It was specific to Departments 15 and 16, Department 19, Departments 48/56, and Power 2. The complaint was made by Charles E. Davis who is the pipefitter craft safety repre sentative. The visit on Monday was to hold an opening conference and go over the complaint against the Company. At the time, he reviewed our OSHA 200 form for 1981 thru the present and commented on our good safety record. He also received a copy of all our forms used by Medical for performing physicals and a copy of the proce dures for removal of asbestos and the testing procedure by Pabco. The personnel present for this opening conference were: Charles Davis Vernon Mapes Dora Sendejas (to review Medical) Greg Daues Bob Hammann . He also mentioned that he had reviewed Roy Pigge's report on last year's general health inspection. He was here specifically on this asbestos investigation, but would cite us for any obvious violation that he happened to note in the course of his inspection. He left at approximately 2:30 after discussions with the comment that he would return the next day to interview people and look at the areas. ----------- Day Two, Wednesday, June 29 Rex McKinney went out into the plant at approximately 9:45. Charles Davis was the craft representative and a discussion was held with Dan Campbell, Bob Hamming and Mr. McKinney. During this discussion, which mainly revolved around sampling, he was given copies of the sampling data of personnel in the area and a copy of our "Asbestos Procedure". H.G. Bullock was called in to dicuss the interpreta tion of the procedure. Specifically, who was instructed to get the sample. This was stated to be normally taken by the maintenance foreman in the field. Mr. McKinney was taken to the I.H. lab and shown the procedures for determining asbestos. He also went to the field where he interviewed numerous people. The people interviewed were: CBY 3103798 c 002192 c OSHA. INSPECTION (CONT'D) c Page 2 Herbert C. Doreck, pipefitter Leonard Dinning, pipefitter Ryan Pittman, pipefitter W.R. Sanders, pipefitter M.F. Whatley, pipefitter Ed Smith, insulator Raymond Guidry, insulator Glenn Eierdam, insulator From all these people he got the same story. Essentially, they were supplied with proper personal protective equipment, but they felt that insulators were better able to handle the work, THie pipefitters specifically stated they didn't feel that they were qualified. On one hand they said they were willing to do the work agreed to by the contract, but on the other hand they stated they thought that the insulators should be doing work around asbestos. He was also shown the change room. He left the plant at approximately 3:15. Day Three, Thursday, June 30 Mr. McKinney arrived at the plant at 10:00. Charles Davis, Dan Campbell, and Bob Hammann were present. They went to Department 48/56 where interviews were conducted with: Richard Hobbs, Jr., pipefitter Pete DeGroot, pipefitter . Charles Virgin, pipefitter All expressed concern about not having proper training. In fact, Hobbs had not been trained because he had been off two weeks on sick leave and one week vaca tion just recently. No checks were made in Department 19 as they did not have maintenance personnel in the area. Contact was made with Jim Gatewood concerning any work where insulation would be removed as incidental work. It was determined that they had a job stripping insulation off piping above 16E2 and would be doing this work right after lunch. We went to the area and after the men obtained the proper equipment, sampling pumps were connected to them by both Mr. McKinney and Monsanto Industrial Hygiene for determining a 15 minute ceiling concentration. The two individuals doing this work were G.E. Hoyland and R.V. Nicol. Six pic tures were also taken of the men in action stripping the insulation. Mr. McKinney requested that he have some of these pictures. These will have to be cleared through G.L. Tromblee. After sampling was completed and return made to the lab where he took a sample of insulation that determined to be asbestos. Mr. McKinney left the plant at 3:15. He will return at approximately 1:00 July 1, to give a preliminary closing conference. A final closing conference will be given once the results of the sampling are obtained. Possible Citations During the work on stripping the Insulation material was not wetted down. This is in violation of OSHA Standard 1910.1001 Asbestos, 2. Work Practices, i) Wet Methods. Also, based on the results of the sample, we may be required to pro vide a physical exam for each of the employees now exposed to asbestos. Whether we are required or should do it will depend on the results of the sampling. CBY 3103799 c 002193 c OSHA. INSPECTION (CONT'D) c Page 3 This statement under preplacement is that, "the employer shall provide or make available to each of his employees, within 30 calendar days following his first employment in an occupation exposed to airborne concentrations of asbestos fibers, comprehensive medical exam, which shall include, as a minimum, a chest x-ray, a history of elicit symptomatology of respiratory disease, and pulmonary function tests..." Thereafter, this would have to be an annual examination. These are the two items that he mentioned we could possibly be cited on. The second one would not probably be a citation, but would be something we would have to comply with within 30 days. Other points noted during the inspection: a) Training came up almost as a broken record. We did a very poor job in our initial training of personnel. b) People are not familiar of how to take the samples, where to take the samples, where to get the proper protective equipment, though, they all new that they could at least contact an insulator to find out where to get it. c) How to dispose of the equipment (i.e., putting the gloves in a bag), how to take the sample (i.e., put it in a plastic bag and taking it to the I.H. lab), or generally what they do when they are handling asbestos. d) Doors to the change room are locked and it is not known who has the key in all cases. We need to work on a better system for this. e) Comment was made that we should possibly use the insulators to assist in the training of members of other crafts. f) We need to put more emphasis on our hearing conservation as person nel were out in areas with loud noises emitted from compressors and not wearing proper ear protection. In two cases I had to request that people get the proper ear protection. However, this was not noted by the inspector. It was corrected before he could make any' comments. 7-1-83 R. T. Hammann CBY 3103800 C 002194 rr OSHA INSPECTON -- ASBESTOS Telephone Conversation With Rex McKinney of OSHA on 7/26/83 A call was placed to Rex McKinney to discuss the status of OSHA's personal sampling and determine if a date could be set for the closing conference. OSHA has not received the analysis of their samples as yet. They've recently moved their lab and feel that there may be some additional delay due to this. He does not expect to get the results of their sampling back for at least two more weeks. Whenever this data is received he will contact me to set up a closing conference. I did relay to him the information concerning the results of our tests (that the personal samples were 0.21 and 0.23 fibers/cc). Also discussed with him whether he had talked with his boss concerning we had met the intent of the OSHA Standard which was to establish a baseline for our employees since we do have past physicals on employees as part of our medical program. He stated that he had -discussed it mentioned it to his boss, but that the best thing for us to do would be to wait until after the closing conference and if there was a citation on this, then we could request an informal con ference with his boss in order to present our position. At that time they would accept or reject our contention. RTH/es R. T. Hammann % CBY 3103801 c 002195 rr CLOSING CONFERENCE -- OSHA INSPECTION FOR 8/12/83 The closing conference with Rex McKinney, OSHA, was set for 1400 on 8/12/83. Mr. McKinney arrived at the plant at 1230 and was brought in from the Main Gate at 1300. Prior to the closing conference there was some discussion on steps that we have taken since the inspection of 6/28-7/1 concerning employee physi cals. We stated that we plan to initiate yearly physicals (including medical history, pulmonary function test and chest x-ray) for those individuals doing incidental work requiring them to remove asbestos insulation. Also stated that we would not force an individual to take the chest x-ray. However, if they decided not to take the x-ray, then they would be required to sign a statement stating this. He also requested medical information on the two workers, R.V. Nicol and G.E. Hoyland, on which personnel monitoring was done while they were performing job of stripping asbestos. Information given was as follows: Last Physical Pulmonary Function Test Chest X-ray Nicol Hoyland 03/23/83 11/17/82 08/81 11/17/82 Given slip at last physical Given slip at last physical Closing Conference Personnel present: Rex McKinney, OSHA Charles Davis, Pipefitter Safety Representative Greg Daues Dan Campbell Mark Riddle Bob Hammann Mr. McKinney started by stating that their tests showed 0.3 fibers/cc which is well below the ceiling limit and therefore indicated no overexposure. He stated there were three possible citation areas. 1. Work practices/wet methods - 1910.1001 C.2.i We were cited as the workers did not wet down the asbestos while they were removing it. It is our practice to wet down the asbestos. He has a copy of our procedures which state this. Abatement period - immediate. This has always been our practice. 2. Personnel monitoring - 910.1001 F.2.ii Personnel monitoring must be done at intervals no greater than six months. From the data that we have given him, this has not been done. Additional search for data will be made.to see if we have indeed complied with this. Abatement period - immediate. CBY 3103802 c 00219S r Closing Conference - OSHA Inspection 8/12/82 (Cont'd.) r Page 2 3. Employee physicals - 1910.1001 J.2 People working with asbestos shall have a physical examination within 30 calendar days. Some discussion followed concerning this when we once again stated our opinion that this initial examination is to establish baseline data. We are willing to accept data taken from earlier physicals as being the baseline data. He could not answer this other than to state that we would have to discuss it with his boss at an informal conference sometime after receiving any citations. His boss' name is Jack Fontaine and his phone number is 750-1727. We should receive the formal citation within two weeks by registered mail. The fifteen working day period for formally contesting the citation will start the day after receipt of the citation. CBY 3103803 C 002197 ' cr j'/lonsailto MONSANTO FIBERS ANO INTERMEDIATES CO. P. O. Box 1311 Texas City, Texas 77590 Phone: (713) 945-4431 September 26, 1983 Gerald A. Baty, Area Director Occupational Safety & Health Administration U.S. Department of Labor 2320 La Branch, Room 1103 Houston, Texas 77004 Re: Citation M6013-167 dated 8/22/83, as amended by- the informal settlement agreement of 9/01/83. Dear Sir: Monsanto Fibers & Intermediates Company is complying with 29 CFR 1910.1001 (F)(2)(ii) concerning personal monitoring of airborne asbestos. This monitoring has been done and will be continued at intervals of no more than six months for our employees whose exposure to asbestos may exceed the limits prescribed by paragraph (b) of 29 CFR 1910.1001. Very truly yours. R. T. Hammann, Superintendent Loss Prevention & Safety Dept. RTH/es a unit of Monsanto Company CBY 3103804 C 002198 U.S. Department of Labor Houston Area Office 2320 LaBranch, Room 1103 Houston, Texas 77004 Occupational Safety and Health Administration September 23, 1983 Mr. Gene L. Tromblee Monsanto Fibers and Intermediates Co. P.0. Box 1311 Texas City, Texas 77590 RE: M6013-167 Dear Mr. Tromblee <s>-f- A citation was issued to your company containing item(s) with abatement date(s) that are now past due. As a courtesy, we wish to bring this to your attention as these dates may have been overlooked. Since your receipt of this citation, we have not received correspondence from you indicating that you have complied or abated all the items. We are in need of documentation from you indicating the status of these items. Followup inspection indicating non-abatement may result in additional proposed penalty. It is requested that reports be made upon each abatement date as indicated in the citation in order to minimize reinspection activity. We will appreciate your prompt attention to this matter, and should you have any questions concerning this item or others regarding the Occupational Safety and Health Act of 1970, please contant this office. If you have recently mailed this abatement report, please disregard this letter as it is sent as a courtesy reminder. Sincerely, GERALD ~Ar~BATY Area Director CBY 3103805 C 002199 rr \ OCCUPATIONAL SAi-sTV A.'.J -ify* :m AC-VHNIjTKA TiC.N CITATION and NOTIFICATION OF PENALTY Itoustm Area Office 2300 Lahmnch -- Raca 1103 Houston, Texas 77034 PEER T01 ftensanta Sibera sad Intermediates Company sad its successors ?.0. Sox 1311 Taxis Cit7, Texas 77550 A'iTTJ: Mr. Gene L. Treablee, Pleat lbn>w iSSUiHCA. '. C5*A ' s/^/S31 :ioiot > RtGIOt I* AAIA 6 K^o 167 1 > l l l___ 1NSSPPECTlp?i.OATS: _ 6/23./.5.3 - 7/1/33 INSPECTION SITE: 20VSouth Hay Street 'C/Si.Cy-' .gj1 S tes&Xlt?, Texas 77590 ' X' .It- ''' ' */ -/-f" "JS*1?}..5 ITEM MIMSES STANOARO. REGULATION OH SECTION OF THE ACT VIOLATED: DESCRIPTION The issuance of this citation does not constitute a finding that a riolatioa of the Act has occurred unless there is a failure to contest as provided for in the Act or, if contested, unless the citation is affirmed by the Review Coaaissica. The violaticas described in this citation are alleged to have occurred on or about the day the inspection was aide unless otherwise indicated within the description given below. 1 29 C7S 1910.1COl(f)(2){ii): The airborne asbestos isonitorins schedule ins not of suffiriant frequency and pattern as to represent with reasonable accuracy the levels of enployae exposure to airborne asbestos fibers; Monsanto fibers and Intermediates Ccajssay- in Texas City, Veins, does not conduct personal taeniaering for airborne asbestos fibers at intervals of 6 norths of less for employees whose exposure to asbestos nay reasonably be foresee! to exceed the limits prescribed by paragranh b of 29 CFR 1910.1301. DATE BY WHICH |" VIOLATION MUST | BE CORRECTED , 1 1 lII l i I l l l l ll Immediately { Upon Receipt 1 I1 IIIII IIIIII1 PENALT $0 2 i-rC-M >LcrC ss.TTt-G.M<~^r 29 CFS 19lu. 130l(j)(^}: Tile employer did dot provide'W make/ available^ to each enployee, within 30 daya/follawing/nis first erw plcyaeat in an occupation exposed to airborne levels/of asbestos fibers, a connrehensive uedical cxnniruxtAcn: / ** > ' (a) Cn Jiaid 30, 1933, an employee woxking'oa Bait 16,^2 vai exposed to' 0.2-3 fibers per cubic centimeter of air./This / exposure-occurred,-during an asbestos insulation rtnovnU The sample takca/vas a 15-njnute ceiling sanple.^ 9/^/sS { * AREA DIRECTOR :c.L3 a. 'nr' s//7. c 002200 $0 .V ' - - ** ;/ - \.v ** CBN 31018^6 5r-VIVr,^> 'j m **..*i?~ :Vv~r rr Mon son to MONSANTO FIBERS AND INTERMEDIATES CO. P. O. Box 1311 Texas City, Texas 77590 Phone: (713) 945-4431 September 7, 1983 Gerald A. Baty, Area Director Occupational Safety & Health Administration U.S. Department of Labor 2320 La Branch, Room 1103 Houston, Texas 77004 Re: Citation M6013-167 dated 8/22/83, as amended by the informal settlement agreement of 9/01/83. Dear Sir: Monsanto Fibers & Intermediates Company is complying with 29 CFR 1910.1001 (F)(2)(ii) concerning personal monitoring of airborne asbestos. This monitoring has been done and will be continued at intervals of no more than six months for our employees whose exposure to asbestos may exceed the limits prescribed by paragraph B of 29 CFR 1910.1001. Very truly yours, RTH/es R. T. Hammann, Superintendent Loss Prevention & Safety Dept. a unit of Monsanto Company CBY 3103808 C 002201 fr R.T. Hammann, LP&S - Texas City 0-22 Ext. 3234 September 7, 1983 CC Letter of Corrective Action to OSHA Area Director TO : P.S. Park (SL) G3WB Attached is a copy of the Informal Settlement Agreement reached with OSHA on 9/01/83. In order to close the file we are required to send a letter of corrective action to Gerald Baty, the Area Director in Houston. Please let me know of any corrections needed to this letter. Also, should it go out under the Plant Manager's signature? Thank you for your assistance. Attachment RTH/es R.T. Hammann CBY 3103809 C 002202 rr U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION INFORMAL SETTLEMENT AGREEMENT- The -undersigned Employer and the undersigned Occupational Safety and Health Administration (OSHA), in settlement of the above citations) and penalties % v/hich were issued on , hereby agree as follows: 1. The Employer agrees to correct the violations as cited in the `above citations or as amended below. 2. The Employer agrees to pay the proposed penalties, if any, as issued' with the above citation(s), or, if amended by this agreement, as amended below. . 3. The Employer and OSHA agree that the following citations and penalties (if any) are not being amended by this agreement: '* * 4. OSHA agrees that the following citations and penalties are being amended as shown (see attachments): CBY 3103810 ' 0^02203 rr 5. The Employer, "by signing this informal settlement agreement, hereby waives its rights to 'contest the above citation(s) and penalties, as amended in paragraph 4 of this agreement. 6. The Employer agrees to immediately post a copy of this Settlement Agreement in a prominent place at or near the location of the violation(s)' ' * '. referred to`in paragraphs 3 and 4 above. This Settlement. Agreement must . remain posted until the violations cited have been corrected, or for 3 working days (excluding weekends and Federal Holidays), whichever is longer. 'FOR TfLE. EMPLOYER . ?// //3 DATE f t AJt FOR THE OCCUPATIONAL SAFETY/AMD HFALTH ADMINISTRATION MOTION TO EMPLOYEES " The law gives you or your representative the opportunity to object to any ` abatement date set for a violation if you believe the date to be unreasonable. Tuny contest to the abatement dates of the citations amended in.paragraph 4 of this Settlement Agreement must be mailed to'the U.S. Department of Labor-OSHA, 2320 LaBranch, Room 2118, Houston, Texas 77004, within 15 working days' (exclud ing weekends and Federal Holidays) of the receipt by the Employer of this Settlement Agreement. You or your'representative also have-the right to object to any of the abatement dates set for violations referred to in paragraph 3 * provided that the objection is mailed to the office shown above within the'15 working day period established by the original citation. CBY 3103311 ' e 002204 r( informal conference with osha Held 9/01/83 Meeting was held with Gerald A. Baty, OSHA Area Director, and Jack Fontaine, Industrial Hygiene Supervisor, concerning the citation issued 8/23/83. This was as a result of the inspection of 6/28-7/01/83, on asbestos handling. Present for Monsanto were: Dan Campbell, Industrial Hygienist, and R.T. Hammann, LP&S Superintendent. Discussion of the citation consisted of the following: Point I - Asbestos Monitoring Monitoring done in January included a source sample which, although not attached to the individual, was construed to be a personal sample as it was hung in the breathing zone. Point II - Preplacement Exam A. History of the complaint. B. Monsanto policy on medical exams. C. Felt that we have complied with the intent of the regulation in establishing baseline data. An informal settlement agreement was reached whereby OSHA deleted Point II and Point I will be abated by the Texas City plant. Additional Information Received During This Conference: OSHA considers that when monitoring of personnel shows greater than 0.1 fbrs/cc for an 8 hour time weighted average that these employees must receive the annual physical. RTH/es R. T. Hammann CBY 3103812 C 002205 m r r Texas City, Texas July 7, 1983 OSHA Inspection (6/28-7/1/83) To: G. W. Daues Copies to: Clayton Callis - B3CA R. L. Hammond John L. Henshaw - G4WG D. E. Kaldenberg V. Mapes - SS-17 C. D. Norlander - G5WB Steve D. Paul - G2WB H. 0. Rei'd G. L. Tromhlee W. D. Walker (See Attached) CBY 3103813 c 002206 MliaillBIBBi * Monsanto P(0m (NAME 4 LOCATION) R.T. Hammann/M.A. Riddle, LP&S *TI July 7, 1983 subject OSHA INSPECTION (6/28--7/1/83) 0-22 Ext. 3234/3236 cc. HKUNCi TO : g. W. Daues 0-10A OSHA Inspector, Rex F. McKinney, Industrial Hygienist,*appe 13:00 hours on Tuesday, June 28. The purpose of his visit employee compaint stated as follows: ;he*?jgate at fartigate an "Pipefitters have been removing asbestos insulation without wearing the proper personal protective equipment. The Company has taken samples to determine where the asbestos is located, but some insulation has been mistakenly identified as non-asbestos." This complaint was filed with OSHA on 6/27/83, at 11:45 a.m. It was specific to Departments 15 and 16, Department 19, Departments 48/56, and Power 2. The complaint was made by Charles E. Davis who is the pipefitter craft safety repre sentative. . The visit on Monday was to hold an opening conference and go over the complaint against the Company. At the time, he reviewed our OSHA 200 form for 1981 thru the present and commented on our good safety record. He also received a copy of all our forms used by Medical for performing physicals and a copy of the proce dures for removal of asbestos and the testing procedure by Pabco. The personnel present for this opening conference were: I Charles Davis Vernon Mapes Dora Sendejas, R.N. Greg Daues Bob Hammann He also mentioned that he had reviewed OSHA inspector, Roy Pigge's report on last year's general health inspection of the plant. He was here specifically on this asbestos investigation, but would cite us for any obvious violation that he happened to note in the course of his inspection. He left at approximately 2:30 after discussions with the comment that he would return the next day to inter view people and look at the areas. Day Two, Wednesday, June 29 Rex McKinney entered the plant at approximately 9:45. A discussion was held with Dan Campbell, Bob Hammann, Charles Davis, and Mr. McKinney^JDuring this discussion, which mainly revolved around sampling, he was givenjidpies of the sampling data of personnel in the area and a copy of our "Asbecg{S Procedure". H.G. Bullock, Maintenance foreman for Insulators, was called in to dicuss the interpretation of the procedure, specifically, who was instructed to get the sample. This was stated to be normally taken by the maintenance foreman in the CBY 3103814 C 002207 * -3 r "^ r OSHA Inspection (6/28--7/1/83) c Page 2 field. Mr. McKinney was taken to the I.H. lab and shown the procedures for determining asbestos. He also went to the field where he interviewed numerous people. The people interviewed were: Herbert C. Doreck, pipefitter Leonard Dinning, pipefitter Ryan Pittman, pipefitter W.R. Sanders, pipefitter M.F. Whatley, pipefitter Ed Smith, insulator Raymond Guidry, insulator Glenn Eierdam, insulator From all these people he got the same story. Essentially, they were supplied with proper personal protective equipment, but they felt that insulators were better able to handle the work. The pipefitters specifically stated they didn't feel that they were qualified. On one hand they said they were willing to do the work agreed to by the contract, but on the other hand they stated they thought that the Insulators should be doing work around asbestos. He was also shown the change room. He left the plant at approximately 3:15. Day Three, Thursday, June 30 Mr. McKinney arrived at the plant at 10:00. Charles Davis, Dan Campbell, and Bob Hammann were present. They went to Department 48/56 where interviews were conducted with: Richard Hobbs, Jr., pipefitter Pete DeGroot, pipefitter Charles Virgin, pipefitter All expressed concern about not having proper training. In fact, Hobbs had not been trained because he had been off two weeks on sick leave and one week vaca tion just recently. No checks were made in Department 19 as they did not have maintenance personnel in the area. Contact was made with Jim Gatewood concerning any work where asbestos insulation would be removed as incidental work. It was determined that they had a job stripping insulation off piping above 16E2 and would be doing this work right after lunch. We went to the area and after the men obtained the proper equip ment, sampling pumps were connected to them by both Mr. McKinney and Monsanto Industrial Hygiene for determining a 15 minute ceiling concentration. The two individuals doing this work were G.E. Hbyland and R.V. Nicol. Six pictures were also taken of the men in action stripping the insulation. Possible Citations During the work on stripping the insulation material was not wetted down. This is in violation of OSHA Standard 1910.1001 Asbestos, 2. Work Practices, i) Wet Methods. Also, based on the results of the air sampling, we may be required to provide a physical exam for each of the employees now exposed to asbestos. CBY 3103815 c 002203 c OSHA Inspection (6/28--7/1/83) c Page 3 This statement under preplacement is that, "the employer shall provide or make available to each of his employees, within 30 calendar days following his first employment in an occupation exposed to airborne concentrations of asbestos fibers, comprehensive medical exam, which shall include, as a minimum, a chest x-ray, a history of elicit symptomatology of respiratory disease, and pulmonary function tests..." Thereafter, this would have to be an annual examination. These are the two items that he mentioned we could possibly be cited on. The second one would not probably be a citation, but would be something we would have to comply with within 30 days. Day Four, Friday, July 1 Rex McKinney was scheduled to return to the plant at 1300 for the closing con ference. He arrived at 1100 and asked to talk with the supervisor, Larry Young, pipefitter leadman, Marvin Janicek, and pipefitters, R.V. Nicol and G.E. Hoyland that were involved in the asbestos stripping job observed on Thursday, June 30. He talked with these people individually and asked some basic questions to verify the area and the type of work that they were doing. Mark Riddle, Charles E. Davis, craft safety representative, and Dan Campbell were present during these discussions. After the above gentlemen who were interviewed left, Mr. McKinney asked a- few other housekeeping type questions.. He then said he would not hold the final closing conference until sampling results were obtained which would take at least 30 days. He did say there was the possibility of citations and just reiterated the possible citations that were discussed on Thursday. He stated to the pipefitter safety representative that he could be contacted at any time by phone if he had further questions. We escorted Mr. McKinney to the gate and on the way he asked if we had got approval for the pictures that were taken the day before. We told him that we had and that we needed to go to Greg Daues' office to obtain them. We went to Greg Daues' office to get the pictures and while there had a short informal discussion with Daues concerning Mr. McKinney's future course of action. We discussed the statement that he had made previously that we would probably have to provide an examination for all employees within 30 days following their first exposure to asbestos fibers. We discussed our opinion that we had met the intent of the law which is to establish a baseline data, and that we have already done this due to our ongoing medical program. He said he could not make that decision himself, but that he would discuss this with his supervisor and that we should call his supervisor to discuss our opinions further. His supervisor's name is Jack Fontaine. We then provided Mr. McKinney with the pictures he requested of the asbestos removal job on Thursday, and he was escorted to the gate. Other Points Noted During The Inspection; a) Training came up almost as a broken record. Our initial training of personnel could have been improved. b) Some said they were not familiar of how to take the samples, where to take the samples, where to get the proper protective equipment. They alltoew, however, that they could at least contact an insulator CBY 3103816 c 002209 c QSHA. Inspection (6/28--7/1/83) c Page 4 to find out what to do, how to dispose of the equipment (i.e., putting the gloves in a bag), how to take the sample (i.e., put it in a plastic bag and taking it to the I.H. lab), or generally what they do when they are handling asbestos. c) Doors to the change room are locked and it is not known who has the key in all cases. d) Comment was made that we should possibly use the insulators to assist in the training of members of other crafts. e) We need to put more emphasis on our hearing conservation as person nel were out in areas with loud noises emitted from compressors and not wearing proper ear protection. In two cases we had to request that people get the proper ear protection. However, this was not noted by the inspector. It was corrected before he could make any comments. Bob Hammann Mark Riddle es CBY 3103817 C 002210 Texas City, Texas July 7, 1983 OSHA Inspection (6/28-7/1/83) To: G. W. Daues Copies to: ' Clayton Callis - B3CA R. L. Hammond John L. Henshaw - G4WG D. E. Kaldenberg V. Mapes - SS-17 C. D. Norlander - G5WB Steve D. Paul - G2WB H:";o;rReid ' G. L. Tromblee W. D. Walker (See Attached) CBY 3103818 c 002211 Monsanto PKOm |Nam( A iOCaTiON) r R.T. Hammann/M.A. Riddle, LP&S o*'1 July 7, 1983 Iu'"" OSHA INSPECTION (6/28--7/1/83) tPEUNCt c. 0-22 Ext. 3234/3236 cc, TO : g. W. Daues 0-10A OSHA Inspector, Rex F. McKinney, Industrial Hygienist, appeared At the gate at 13:00 hours on Tuesday, June 28. The purpose of his visit was.to investigate an employee compaint stated as follows: --. "Pipefitters have been removing asbestos insulation without wearing the proper personal protective equipment. The Company has taken samples to determine where the asbestos is located, but some insulation has been mistakenly identified as non-asbestos." This complaint was filed with OSHA on 6/27/83, at 11:45 a.m. It was specific to Departments 15 and 16, Department 19, Departments 48/56, and Power 2. The complaint was made by Charles E. Davis who is the pipefitter craft safety repre sentative. The visit on Monday was to hold an opening conference and go over the complaint against the Company. At the time, he reviewed our OSHA 200 form for 1981 thru the present and commented on our good safety record. He also received a copy of all our forms used by Medical for performing physicals and a copy of the proce dures for removal of asbestos and the testing procedure by Pabco. The personnel present for this opening conference were: Charles Davis Vernon Mapes Dora Sendejas, R.N. Greg Daues Bob Hammann He also mentioned that he had reviewed OSHA inspector, Roy Pigge's report on last year's general health inspection of the plant. He was here specifically on this asbestos investigation, but would cite us for any obvious violation that he happened to note in the course of his inspection. He left at approximately 2:30 after discussions with the comment that he would return the next day to Inter view people and look at the areas. Day Two, Wednesday, June 29 (J Rex McKinney entered the plant at approximately 9:45. A discussion was held with Dan Campbell, Bob Hammann, Charles Davis, and Mr. McKinney. During this discussion, which mainly revolved around sampling, he was given copies of the sampling data of personnel in the area and a copy of our "Asbestos Procedure". H.G. Bullock, Maintenance foreman for insulators, was called in to dicuss the interpretation of the procedure, specifically, who was instructed to get the sample. This was stated to be normally taken by the maintenance foreman in the CBY 3103819 r OSHA Inspection (6/28--//1/83) r Page 2 field. Mr. McKinney was taken to the I.H. lab and shown the procedures for determining asbestos. He also went to the field where he interviewed numerous people. The people interviewed were: Herbert C. Doreck, pipefitter Leonard Dinning, pipefitter Ryan Pittman, pipefitter W.R. Sanders, pipefitter M.F. Whatley, pipefitter Ed Smith, insulator Raymond Guidry, insulator Glenn Eierdam, insulator From all these people he got the same story. Essentially, they were supplied with proper personal protective equipment, but they felt that insulators were better able to handle the work. The pipefitters specifically stated they didn't feel that they were qualified. On one hand they said they were willing to do the work agreed to by the contract, but on the other hand they stated they thought that the insulators should be doing work around asbestos. He was also shown the change room. He left the plant at approximately 3:15. Day Three, Thursday, June 30 Mr. McKinney arrived at the plant at 10:00. Charles Davis, Dan Campbell, and Bob Hammann were present. They went to Department 48/56 where interviews were conducted with: Richard Hobbs, Jr., pipefitter Pete DeGroot, pipefitter Charles Virgin, pipefitter All expressed concern about not having proper training. In fact, Hobbs had not been trained because he had been off two weeks on sick leave and one week vaca tion just recently. No checks were made in Department 19 as they did not have maintenance personnel in the area. Contact was made with Jim Gatewood concerning any work where asbestos insulation would be removed as incidental work. It was determined that they had a job stripping Insulation off piping above 16E2 and would be doing this work right after lunch. We went to the area and after the men obtained the proper equip ment, sampling pumps were connected to them by both Mr. McKinney and Monsanto Industrial Hygiene for determining a 15 minute ceiling concentration. The two individuals doing this work were G.E. Hoyland and R.V. Nicol. Six pictures were also taken of the men in action stripping the insulation. Possible Citations During the work on stripping the insulation material was not wetted down. This is in violation of OSHA Standard 1910.1001 Asbestos, 2. Work Practices, i) Wet Methods. Also, based on the results of the air sampling, we may be required to provide a physical exam for each of the employees now exposed to asbestos. CSV 3103820 C 002213 r OSHA Inspection (6/28--7/1/83) r Page 3 This statement under preplacement is that, "the employer shall provide or make available to each of his employees, within 30 calendar days following his first employment in an occupation exposed to airborne concentrations of asbestos fibers, comprehensive medical exam, which shall include, as a minimum, a chest x-ray, a history of elicit symptomatology of respiratory disease, and pulmonary function tests..." Thereafter, this would have to be an annual examination. These are the two items that he mentioned we could possibly be cited on. The second one would not probably be a citation, but would be something we would have to comply with within 30 days. Day Four, Friday, July 1 Rex McKinney was scheduled to return to the plant at 1300 for the closing con ference. He arrived at 1100 and asked to talk with the supervisor, Larry Young, pipefitter leadman, Marvin Janicek, and pipefitters, R.V. Nicol and G.E. Hoyland that were involved in the asbestos stripping job observed on Thursday, June 30. He talked with these people individually and asked some basic questions to verify the area and the type of work that they were doing. Mark Riddle, Charles E. Davis, craft safety representative, and Dan Campbell were present during these discussions. After the above gentlemen who were interviewed left, Mr. McKinney.asked a few other housekeeping type questions. He then said he would not hold the final closing conference until sampling results were obtained which would take at least 30 days.. He did say there was the possibility of citations and just reiterated the possible citations that were discussed on Thursday. He stated to the pipefitter safety representative that he could be contacted at any time by phone if he had further questions. We escorted Mr. McKinney to the gate and on the way he asked if we had got approval for the pictures that were taken the day before. We told him that we had and that we needed to go to Greg Danes' office to obtain them. We went to Greg Daues' office to get the pictures and while there had a short Informal discussion with Daues concerning Mr. McKinney's future course of action. We discussed the statement that he had made previously that we would probably have to provide an examination for all employees within 30 days following their first exposure to asbestos fibers. We discussed our opinion that we had met the intent of the law which is to establish a baseline data, and that we have already done this due to our ongoing medical program. He said he could not make that decision himself, but that he would discuss this with his supervisor and that we should call his supervisor to discuss our opinions further. His supervisor's name is Jack Fontaine. We then provided Mr. McKinney with the pictures he requested of the asbestos removal job on Thursday, and he was escorted to the gate. Other Points Noted During The Inspection: a) Training came up almost as a broken record. Our initial training of personnel could have been improved. b) Some said they were not familiar of how to take the samples, where to take the samples, where to get the proper protective equipment. They all new, however, that they could at least contact an insulator CBY 3103821 C 002214 r OSHA. Inspection (6/28--//1/83) r Page to find out what to do, how to dispose of the equipment (i.e., putting the gloves in a bag), how to take the sample (i.e., put it in a plastic bag and taking it to the I.H. lab), or generally what they do when they are handling asbestos. c) Doors to the change room are locked and it is not known who has the key in all cases. d) Comment was made that we should possibly use the insulators to assist in the training of members of other crafts. e) We need to put more emphasis on our hearing conservation as person nel were out in areas with loud noises emitted from compressors and not wearing proper ear protection. In two cases we had to request that people get the proper ear protection. However, this was not noted by the inspector. It was corrected before he could make any comments. Bob Hammann Mark Riddle CBY 3103822 C 002215 mmmmm mm November 1977 Revised October 1980 INDUSTRIAL CARCINOGENS INTRODUCTION For the last 20 to 30 years, science and technology have taken giant steps. Massive amounts of new machines, processes and products are designed, pro duced and marketed annually. Thousands of new previously unknown chemi cals are introduced into the market every year. Only in the last few years have we realized that the great advantages of these new chemicals may be counteracted by posing serious health hazards to the manufacturer and user of these chemicals. The most serious of these hazards, the potential for carcinogenicity (cancer) to man, has alarmed industry and the public in general. STANDARDS Research into the carcinogenic potential of the myriad of chemicals has been very slow and in most cases inconclusive. Identification of cancer agents is fur ther complicated by the difficulty of correlating animal experiments with actual human epidemiological data. The Occupational Safety 8t Health Administration (OSHA) has produced regulations for only 21 chemicals with carcinogenic potential to man. Strict standards and regulations have been established which are included in the Code of Federal Regulations 29 CFR 1910. Even for these, only a few have established permissible exposure limits. The American Conference of Governmental Industrial Hygienists (ACGIH) further recognizes that a few more are so toxic that no exposure or contact is permissible. However, more than half of these do not have any established Threshold Limit Values (TIV) or other permissible exposure limits. Table No. 1 shows the carcinogens listed and regulated by OSHA. The standards established by OSHA for the chemicals in Table No. 1 are specific on the various requirements. They further include exceptions by use and by per centage of carcinogen content. CONTROL PROGRAM The following is a summary of the basic requirements for a good carcinogen control program. For specific details, please consult the individual standard. 1. Substitute less toxic materials for known carcinogens. 2. A written, well-defined set of procedures should be established for the storage, use, end general control of these chemicals. Strict maintenance, cleaning, spi'lage control, and waste disposal procedures should be established. These procedures should be approved end implemented by top management. 3. Workers and supervisors who may be engaged in the use of these chemi cals should be thoroughly trained as to the recognition, use and all other aspects relating to the chemicals. Regularly scheduled retraining sessions should also be established. CBY 3103823 -9- c 002216 4. Establish and maintain a separate inventory on ail carcinogenic products. 5. Containment of the chemicals at all stages from storage to final use is vital. Open vessel systems should not be used. 6. Areas where these materials are being used or stored should be regulated and access to and exit from them should be restricted. Posted signs and documentation should be maintained as to the names of employees enter ing and leaving the restricted area. 7. If possible, oniy one well-trained person should handle these chemicals. All operations, especially the weighing and scooping of these chemicals, should be done within an effective local exhaust ventilation system. A laboratory type hood with front doors is recommended so that only the worker's hands, properly protected by gloves or glove boxes, are required to be introduced into the hood, leaving the face behind the glass window. Intermediate transfer of these materials should always be done in closed and tightly secured containers. These chemicals should be stored in closed containers in segregated areas under lock and key. 8. Ad squate, approved respiratory and skin protection should be worn as required for each type of chemical. In most cases they may involve the use of self-contained breathing apparatus, full-body airtight suits or high effi ciency filter respirators. 9. The removal of the personal protective equipment and work clothes should be done in wash areas adjacent to, but separate from, the work area. Employees should wash their hands and shower thoroughly before leaving the plant. Work clothes should never be taken home. 10. All employees exposd to the chemicals should undergo periodic medical examinations and the results of which, as well as the personnel exposure history, be maintained and documented as required. RECOGNIZED HUMAN CARCINOGENS In addition to the OSHA listed carcinogens, the ACGIH has listed substances (as recognized human carcinogens) associated with industrial processes. These are shown in Table No. 2 with any applicable TLV's. SUSPECTED HUMAN CARCINOGENS ACGIH has also listed industrial substances suspect of carcinogenic potential for man. Included in this series of chemicals are substances which are associ ated with inducing cancer but are based on either (1) limited epidemiological evidence, exclusive of clinical reports of single cases, or (2) demonstration of carcinogenesis in one or more animal species by appropriate methods. These chemicals, as opposed to those in Table No. 1, are presently used in a large variety of industries and processes with a great number of workers being exposed to them. For the chemicals listed in Table No. 3, worker exposure by all routes should be carefully controlled to levels consistent with the animal and human experience data including those substances with a listed TLV. As more information becomes available, chemicals in Table No. 3 may become regulated. It is also very likely that more chemicals will be associated with human carcinogenicity. CONCLUSION Continuing research will surely develop significant conclusions. While the chemi cals mentioned in this bulletin are the most likely to be found in the work place, many more have or will be identified in pollution breakdown chains, natural animal and vegetable food items, among others. On the other hand, media CBY 3103824 c 002217 awitmMmtemmmmsmsa reports fend to implicate many other compounds as potential cancer agents. When reviewing the latter, one has to scrutinize these reports as to their actual ) scientific background, completeness of research, and dose-response relation ship (how much consumption will actually increase the potential for cancer). TABLE 1 OSHA LISTED AND REGULATED CARCINOGENS Standard Name 1910 1001 Asbestos (a) Use Various. Insulation filler Type of cancer Lung & liver 1910.1002 *9`0.1003 1910.1004 1910 1005 (Deleted) 1910 1006 1910 1007 19J0. '008 1910.1009 1910 1010 1910.1011 19`0 '012 19'0 '013 19'0.1014 1910 '015 19'0 `016 1910 1017 1910 1018 1910.1028 1910.1029 1910.1044 1910.`045 Coal Tar Pitch Voiatiles (b) Manufacture of steel asphalt, etc. 4-Nitrooiphenyl Intermediate in production of 4-Aminodiphenyl alpha-Nachthyiamine intermediate in dyes, herbicides and antioxidants 4.4' Methylene bis (2-cnloroamhne) (MCCA) (c) Curing agent for isocyaratecontaming polymer. Methyl chioromethyl ether Production of icn-exchange resins and as chioromethylating agent 3 3' Dichlorcbenzidine Production of dves. curing (ana its salts) agent for isocyanate containing polymers. bis-Chlcrcmethvt ether Intermediate in production of various textile aids. beta Naphthylamme Intermediate m dyes, antioxiaants Benzidine Dye manufacture 4-Aminodiphenyl Rubber anticxicant Efhylenelmine Used to manufacture polyethyleneimme: tlocculant in water treatment; intermediate oil adaitive. aahesives. surfactants fcefaPrcpiciactone Manufacture of acrylic acid and its esters. 2-Acefyiaminofluorene Initially as pesticide 4-0imethylaminoazo- Manufacture of coloring polishes benzene and other wax products. n-Nitrcscdimethylamine Solvent and in manufacture of rocket `uel, antioxidants, lubricant acaifives. and ;n condensers to increase dielectric constant. Vinyl cnicride (monomer) Mainiy PVC manufacture Inorganic Arsenic Foundries & smelters. Pigment glass & paint manufacture Benzene Solvents. Chemical intermediate Coke even emissions Coke ovens (Steel foundries) 1.2 dibromo-3-chloro- Pesticide propane (CBCP) Acrylonitrile Plastics, pestiede Mainly biadder Bladder as 4-Aminodiphenyt Bladder with teta-naphthylamine Non conclusive data Lung (oat-cell) Bladder (suspected) Lung Bladder Bladder Bladder Liver-cell & pulmonary (animals) (animals) Various (animals) Liver & blcdder (animals) Liver & kidney (animals) Liver Lung & skin Leukemia, bone marrow Lung, liver 8t skin Cancer & sterility Lung Sr colon TLV 2 fibers/cc greater than 5 micro meters in length 0.2 mg/m3 NECC (ACGIH) No TLV No TLV No TLV No TLV 0.001 ppm (ACGIH) NEOQACGIH) NEOC (ACGIH) NEOC (ACGIH) 0.5 ppm (ACGIH) No TLV No TLV No TLV No TLV 1 ppm 10 ug/m3 10 ppm 150 ug/m3 1 ppb 2 ppm (a) Ail forms: Chrysotiie. amcsite. crocidolite. tremolite. anthophyllite and actinolite. ;tj) Particulate 0oiycvciic Aromahc Hydrocarbons. (8enzene soluble fraction.) Anthracene. benz(a)pyrene. pnenantnrere. acncme. chrysene, pyrene. (cl MCC.-' has been aeieted from the OSHA carcinogen list. TLV = Threshold Lmit Value -. ACGiH = American Conference of Governmental Industrial Hygienists. NE SC = No Excosure or Contact. mg.m-' = milLgrcms of contaminant per cubic meter of air. pcm = parts cf contaminant per million parts cf air, by volume. PCD = parts of contaminant per billion parts of air, by volume. -11- CBY 3103825 . ----- -- - c 002213 TABLE 2 Recognized Human Carcinogens. Substances, or substances associated wth industrial processes, recognized to have carcinogenic or cocarcmogenic potential with an assigned TLV Chromite ore processing (chromate) Nickel sulfide roasting. fume 3t dust 1,2 Dbrcmoethane (ethylene dibromide) TLV - 0.05 mg/m3 (as Cr) 1.0 mg/m3 (as Ni) NEOC TABLE 3 Suspected Human Carcinogens. -- industrial Substances Suspect of Carcinogenic Potential tor Man. 3-Amino 1.2.4-Triazoie Antimony trioxide production" Arsenic trioxide production Benzene--Skin Benz(a)pyrene Beryllium Cadmium oxide production Carfccn tetrachloride Chloroform Chrcmctes of lead and zinc (as Cr) Dimethylcarbamyl chloride 1. 1 -Cimethyl hydrazine Dimethyl sulfate--Skin Ethyiene dibromide--Skin Hexdchiorobutadiene Hexamethyl phosphcramide--Skin Hyarazine 4.4'-Methylene bis (2-chlcroaniline)--Skin Methyl hydrazine Methyl iodide 2-Nitrcoropane n-hhenyl-beta-napbthylamine propane suitone Propylene imine--Skin o-fciidine Vinyl bromide Vinyl cyclohexene dioxide TLV -- -- -- 10 ppm -- 2.0 ug/m3 -- 5 ppm 10 ppm 0.05 mg/m3 0.5 ppm 0.1 ppm -- 0.02 ppm -- 0.1 ppm 0.02 ppm 0.2 ppm 2 ppm 25 ppm (Ceiling Value) -- -- 2 ppm -- 5 ppm 10 ppm ' Cigarette smoking can enhance the incidence of respiratory cancers from this or others of these substances or processes. Prepared by: G. Gruenwald, CIH Industrial Hygienist -12- CBY 3103826 c 002219 /< /7?D MC3// C/cJT/7,2/;] . Z C^p-J^F /'Js&GsjbS C//Co,Zc^o,v^ * JZ/o/s&i*S`C. /p'i-ssv/t: * COO'S? . &Q2&US Ml twA: C'^eosrc /?C> * CcTfo'-' &j*T V../5&/7V&3S51T J&'QG //of&Z *SaCG*Z 2)/cJf/jUz ~7bCc/AiZ \ ~7Zt'Uls/S` yh'QYCo e&s7Wy<&/g cns '/o/J ^udJ=uZ'C /?c*<0 ACsz?~ 6//Ajyc C/C4&&5 X CTq/gS' ^M5V^V/XTOr'-4T tSCfOl 7Zl/" / ^ '/ <\ CBY 3103827 NI0S11 Recommended Standards Developed under the Occupational Safety and Health Act Substance Ammonia Exposure Estimates 500,000 Arsenic Revised 1,500,000 Asbestos Benzene 2,000,000 Beryllium 30,000 Carbon Monoxide Carbon Tetrachloride Chloroform Chromic Acid Chromium(VI) 80,000 .15,000 Coke Oven Emissions 10,000 Cotton Dust Emergency Egress from Elevated Works tations 230,000 Fluorides 350,000 Hot Environments Identification System for Occupationally Hazardous MateriaIs Inorganic Lead Inorganic Mercury i. Noise 150,000 Si 1ica 1,200,000 0 Date Transmitted To D0L July 15, 1974 January 21, 1974 June 23, 1975 January 21, 1972 July 24, 1974 June 30, 1972 August 3, 1972 December 22, 1975 September 11, 1974 July 17, 1973 December 1, 1975 February 28, 1973 September 26, 1974 December 1, 1975 June 30, 1975 June 30, 1972 December 20, 1974 January 5, 1973 August 13, 1973 d X'aAH-^!j 1 * /1 August i.0, 1972 November 11, 1974 i i` CBY 3103828 19 DEC. 2375 trifluoride, bromine, chlorine dioxide, chlorine trifluonde, decaborane, hydrazine, iodine, nitrogen trifluoride , nitrotoluenc, pentaborane, ^loryl fluoride, picric acid, propyl nitrate, selenium hexafluoride, tetranitrometh an ^tryl* trinitrotoluene (TNT) f GROUP R: 30 JAN. 1976 < ** benzoyl peroxide, carbon black, carbon dioxide, carbon disulfide, cyanide, dimethyl acetamide, dimethyl fornamide, hydrogen chloride, oxyeen difluoride, phosphorus penta- chloride, phosphorus pentasulfiae, phosphorus trichloride, silica, sulfur hexafluoride, sulfur pentafluoride, sulfuryl fluoride, talc, thiram * GROUP S: 27 FEB. 1976 \ aldrin, ANTU, Guthion, boron oxide, Sevin, chlorodane, DDT, ethyl silicate, graphite, hydrogen peroxide, methyl isocyanate, mica, oil mist, perchloromethyl mercaptan, Portland cement, silici, soapstone, sulfur monochloride GROUP T: 26 MAR. 1976 2,4- D, Systox, dichlorobenzene, dichlorvos, dieldrin, endrin, EPIi, ethylene oxide, heptachlor, hydrogen cyanide, lead arsenate, lindane, methyl formate, naphthalene, nicotine, paraquat, parathion, Phosdrin GROUP U: 23 APR. 1976 benzene. Crag, malathion, nitric acid, nitric oxide, nitrogen dioxide, pentachlorophenol, pyrethrum, ronnel, rctenone, sodium fluoroacetate, strychnine, 2,4,5- T, TEDP, TEPP, thallium, varfarin, xylene GROUP V: 21 MAY 1976 acetaldehyde, allyl glycidyl ether, ammonia, chlorine, dichloroethyl ether, diisobutyl ketone, ethoxyethanol, ethyl mercaptan, ferbam, fluorine, formaldehyde, furfuryl alcohol, isophorone, isopropylether, methyl mercaptan, sulfur dioxide, toluene, TDI GROUP V: 18 JUNE 1976 ammonium sulfamate, butyl mercaptan, cadmium, carbon monoxide, coal tar pitch volatiles, cotton dust, dimethylsulfate, ethylene imine, fluoride, methoxychlor, methycyclohexanone, aethylcyclohexanol, organo mercury compounds, sodium hydroxide, tetraethyl lead, tetramethyl lead CBY 3103829 c 002222 Dates indicate due date of projects by NIOSH Contractors (Schedules estimated as of January 31, 1975) I GROUP A: DELIVERED acetone, antimony, methyl ethyl ketone, cyclohexanone. methyl isobutyl ketone, hydrocerTsulfide, .manganese, MDI, nitroaniline, pentanone GROUP B: DELIVERED camphor, chloroacetaldehyde, chloroacetcphenone, ethyl butyl ketone, mesityl oxide, methyl (n-amyl) ketone, ethyl sec-amyl.ketone, ozone, Fival CROUB C: DELIVERED acrolein, butyltoluene, cumene, cyclohexane, biphenyl, ethyl benzene, furfural, methyl styrene, styrene, terphenyls, vinyl toluene GROUP D: DELIVERED amyl acetate, butyl acetate, butyl acetate, n-butyl acetate, dibutylphthalate, ' dimethylphthalate, ethoxyethylacetate, ethyl acrylate, ethyl formate, hexyl acetate. isoamyl acetate, isobutyl acetate-, methyl acetate, methyl acrylate, methyl cellosolve acetate, methyl methacrylate, octyl phthalate, propyl acetate GROUP E: DELIVERED allyl alcohol, emyl acetate, butyl alcohol, cyclohexanol, diacetone alcohol, ethyl acetate, ethanol, hydroquinone, isoamyl alcohol, isobutyl alcohol, isopropyl acetate, isopropyl alcohol, methanol, methyl isobutyl carbinol, propyl alcohol - GROUP F: ll FEB. 1975 butyl cellosolve, butyl glycidyl ether, toxaphene, cyclohexene, cyclcpentadiene, Bisphenol A, dipropylene glycol methyl ether, ethyl ether, glycidol, isopropyl glycidyl ether, methyl acetylene, methyl cellosolve, methylal, phenyl ether, phenyl glycidyl ether, propylene oxide, tetrahydrofuran GROUP G: t 14 MAR. 1975 butadiene, dioxane, heptane, hexane, ketene, liquified petroleum gas, MAPP, methylcyclohexane, coal tar naptha, octachloronaphthalene, octane, pentachloronapthalene, pentane, petroleum'naphtha, propane, propylene dichloride, Stoddard solvent, turpentine GROUP H: 11 APR. 1975 benzyl chloride, bromoform, chlorobromomethane, chloroprene, dichlorodifluoromethar.e, dichloroethylene, dichloromonofluoromethane, dichlorotetrafluoroethane, difluorodibror.owethane, ethyl bromide, ethyl chloride, ethylene chlorohydrin, ethylene dibromide, fluorotrichloromethane, hexachloroethane, hexachloronaphthalene, methyl chloride, methyl iodide CBY 3103830 X22GE G-002223 CLOSING CONFERENCE -- OSHA INSPECTION FOR 8/12/83 The closing conference with Rex McKinney, OSHA, was set for 1400 on 8/12/83. Mr. McKinney arrived at the plant at 1230 and was brought in from the Main Gate at 1300. Prior to the closing conference there was some discussion on steps that we have taken since the inspection of 6/28-7/1 concerning employee physi cals. We stated that we plan to initiate yearly physicals (including medical history, pulmonary function test and chest x-ray) for those individuals doing incidental work requiring them to remove asbestos insulation. Also stated that we would not force an individual to take the chest x-ray. However, if they decided not to take the x-ray, then they would be required to sign a statement stating this. He also requested medical information on the two workers, R.V. Nicol and G.E. Hoyland, on which personnel monitoring was done while they were performing job of stripping asbestos. Information given was as follows: Nicol Last Physical 03/23/83 Hoyland 11/17/82 Closing Conference Personnel present: Pulmonary Function Test 08/81 11/17/82 Chest X-ray Given slip at last physical Given slip at last physical Rex McKinney, OSHA Charles Davis, Pipefitter Safety Representative Greg Daues Dan Campbell Mark Riddle Bob Hammann Mr. McKinney started by stating that their tests showed 0.3 'fibers/cc which is well below the ceiling limit and therefore indicated no overexposure. He stated there were three possible citation areas. 1. Work practices/wet methods - 1910.1C01 C.2.i We were cited as the workers did not wet down the asbestos while they were removing it. It is our practice to wet down the asbestos. He has a copy of our procedures which state this. Abatement period - immediate. This has always been our practice. 2. Personnel monitoring - 910.1001 F.2.ii Personnel monitoring must be done at intervals no greater than six months. From the data that we have given him, this has not been done. Additional search for data will be made to see if we have indeed complied with this. Abatement period - immediate. CBY 3103831 C 002224 Closing Conference - OSHA Lnspection 8/12/82 (Cont'd.) Page 2 3. Employee physicals - 1910.1001 J.2 People working with asbestos shall have a physical examination within 30 calendar days. Some discussion followed concerning this when we once again stated our opinion that this initial examination is to establish baseline data. We are willing to accept data taken from earlier physicals as being the baseline data. He could not answer this other than to state that we would have to discuss it with his boss at an informal conference sometime after receiving any citations. His boss' name is Jack Fontaine and his phone number is 750-1727. We should receive the formal citation within two weeks by registered mail. The fifteen working day period for formally contesting the citation will start the day after receipt of the citation. CBY 3103832 C 002225 $JoImns 1, ^o* 5 <3ltutustrial $tggtsn unitor rv o& jieptembrr, 1980 Certification-Closer Look The field Industrial Hygiene network staff is relatively young in Monsanto compared with other professional disciplines. With this in mind,J. T. Garrett, Industrial Hygiene Director, has explored in a two part article the subject ofprofessional certification and its impact on industrial hygienists and hygiene chemists. It is important for a Professional In dustrial Hygienist or Hygiene Chemist to be certified by the American Board,of. Industrial Hygiene (ABIH). In the eyes of others in the public health field, this signifies that the hygienist or hygiene chemist has acquired the training and skills to be called a true professional. In addition to this obvious benefit, there are several other benefits that accrue to Monsanto and to the hygienist or hy giene chemist who reaches this plateau in .iis or her professional development. These_are in part: OSHA and NIOSH Relations: It is abundantly obvious that governmental agency representatives, including inspec tors, are impressed with the certification status of an individual and consider the programs that include certified profes sionalism as an important element su- perior to those that don't. In addition, both OSHA and NIOSH encourage cer tification within their own hygiene staff and hygiene chemists and these agencies pay the necessary expenses as a part of doing business in this field. iS . .. Professional Testimony: Governmental agencies routinely determine the techni cal qualifications of witnesses and other professionals in this field through their certification status. In many cases the first question asked of a witness is whether he or she is certified and in what speciality. Certification is, there fore, important to Monsanto not only as a symbol of achievement in the profes sion but also a symbol of quality in its In L dustrial Hygiene Program. Program Recognition within the Profes sion: Programs are invariably judged by industrial health professionals in all dis ciplines by the degree of certification achieved by. the program participants. This is true in occupational medicine as well as industrial hygiene and will soon be true in the case of toxicology. Certifi cation of laboratories by the American Industrial Hygiene Association (AIHA) requires certification of certain of the laboratory professionals before it is granted. Certification in the field has, in fact, become essential to program recog nition. Advancement in the Field: Virtually all industrial hygiene programs have certifi cation as one of the requirements for ad vancement. This is, for example, true in the DMEH Industrial Hygiene Section-. It is equally true in published job offcrs.There are very few such offers that do not require certification or in-training status. This is true of OSHA and NIOSH offers in advanced civil service grades as well. For the above reasons and many oth ers certification for industrial hygienists and industrial hygiene chemists is an in telligent move. Asbestos and Monsanto The following is in answer to a ques tion posed by J. T. Roberts, hygienist at the Greenwood, NC location. The ques tion concerned the Monsanto policy on asbestos use and possible inconsistencies between Monsanto policy and CED specifications for the material on certain projects. | J DMEH has found no formal, Written Monsanto "policy'' for asbestos although there is a relatively long standing corpo rate "guideline" which recommends that substitute materials be used where they are available and meet the requirements for the application. For some years how,, Monsanto has made a conscious effort tor remove asbestos from the existing work place and prevent its use to the greatest degree possible for new installations*, Under this informal guideline* a substi tute material should be used whenever risks and cost are reasonable and process considerations are not jeopardized. Experience has shown that substitute materials have been used in the vast ma jority of cases, although there are some applications, even today, where a suitable substitute has net been- founekand as bestos must be used. Flanyand CEI> design engineers are awarirof thia. . guideline and iumtrat and are routinely using asbestos substitutes whey*. available, and applicable. In addition; during the LPEC& review process; DMEH- not> mally checks this requirement for accept-. ability. Cf^3iOW3^- In our view, the spirit of the guideline is being honored through the corporate system in essentially all cases. If you are aware of a particular situation which ap pears to be inconsistent, make your con cerns known to plant or CED project management and your'DMEH industrial hygienist. The "Monitor" is s forum for ideas, comments, and useful news relating to occupational health, issued by the Industrial Hygiene Section, DMEH, Monsanto, St. Louis, MO. Ceiling Values--An Overview New TLV's Available Recently. R. A. Baxter, Manager In dustrial Hygiene/Europe, posed concern Aver the seemingly inconsistent defini tion being used in the field for ceiling concentrations, and suggested some light be shed on the subject. In Search of a Definition The inconsistencies Richard refers to are probably no more evident than in the OSHA health statutes. When one refers to the 1910.1000 section of the OSH Act. you can find two definitions of ceiling values. If referred to Table Z-l, the defi nition states you: "...shall at no time exceed the ceiling value given for that material in the table." The second definition refers to Table Z-2 where an exception to the above explanation allows an excursion above the ceiling: "...up to a concentration not exceeding the maximum duration and concentration allowed in the column under "acceptable maximum peak above the acceptable ceiling concentration for an 8 hour shift"." " This later definition more closely fol lows- the concept of a STEL described in the ACGIH TLV booklet. The ma jor difference being that most of the values in Table Z-2 don't follow the 15 minute duration criteria used in the STEL definition. Without belaboring the reader with the other specific OSHA standards, suf fice to say that certain standards define ceilings as that concentration which can not be exceeded as averaged over a cer tain duration of time. In a word, yes, there are inconsistencies in OSHA's defi nition of ceiling values, and, yes, many definitions exist for the concept of ceil ing values. DMEH has received the 1980 TLV booklets. They will be distribute.# in Sep tember. If you don't get one'or need more, contact your staff IngienRt. M'COS&H It's time to mark your 1981 calendar with a few important dates. The. Mon santo .Management Conference bn OcciTJ>ational Saietv and Health will be helcl "March 15-19th here in St. Louis. Thiswill be a joint conference with members present from the Medical, Industrial Hy giene, and Safety &: Property Protection functions throughout Monsanto. As usual, we are all looking for interesting, informative, and, yes, even controversial subjects to present at the conference, so call or write your respective contact in DMEH or S&PP and suggest topics you feel would be useful. It's not that far away! limit (STEL) values by qualifying the conditions they seek to protect against, namely: irritation chronic or irreversible tissue change narcosis of sufficient degree to in crease accident proneness, impair self rescue, or materially reduce work effi ciency. This rationale is compatible with DMEH's approach to this subject and should provide guidance in determining ceiling levels for materials with no listing as such. The excursion factor table ap pearing below is a good source to consult when a question arises in this area. Excursion Factors For all substances not bearing C notation TLV 0-1 (ppm or mg/m). TLV 1-10 TLV 10-100 TLV 100-1000 Excursion Factor 3 2 1.23 The number of times an excursion above the TLV is permitted is governed by conformity with the Time-Weighted Average TLV. Remembering that STEL's are guidelines, and recognizing that hypersusceptible individuals are present in the workforce, each location should judge acceptable ceiling levels for materials on empirical data as well as consensus guides. When a question occurs in this area, DMEH should be consulted. Richard suggested in his inquiry that to minimize confusion when speaking of ceiling values, mention of the observa tion time would be appropriate. We at DMEH think this is a step in the right di rection. We also fell it appropriate to re view the fundamental concept of ceiling e values so as to provide guidance and uni formity to its use in the field. Ceiling Concept The ACGIH introduces a judgmental approach for the short term exposure 2 CB* 3103834 C 002227 I]e <3Jnbustrml IMggten* ^nnttar ffiolmne 5, ffio- 7 October 1984 cutaneous irritation of the skin and the sequelae of scratching. In Scotland, workers accepted this dermatitis as a condition of employment and labeled it the "badge of the trade". This condition results in approximately 10% of newglass workers leaving the job. However, it is not a disabling form of -dermatitis. The cutaneous nerve endings mediate both pain and itch, so these modes of sensation are closely related. The stimulation of these nerve endings, following contact with the fibrous glass, result in the discomfort many observe. It is important to note that the larger the fiber the higher the potential for skin irritation. Conjunctival (eye) irritation and nasopharyngitis (upper airway irritation) have also been reported. Animal studies involving the inhalation of glass fibers have neither demonstrated pulmonary fibrosis nor the presence of pulmonary or mesothelial cancers and resulted in minimal macrophage reaction. Epidemiological studies have not Facts On Fiberglass You're Itching To Know demonstrated an excess in mortality, increased chronic bronchitis, the by Tom Blank presence of mesotheliomas or harmful tissue damage. Upper airway irritation The use of fibrous glass, as a replacement for asbestos in certain individual product applications. Major uses include acoustical and thermal appears to be the only respiratory system problem of any consequence. applications, has grown in recent years. Along with this increased use stems concern about health effects surrounding the use of fibrous glass. This review should help dear some of the misconceptions and fears. insulation and the reinforcement of plastics. However, an increased number of textile products are now being developed and marketed. The outstanding properties of fibrous glass include: chemical resistivity, heat The body of evidence summarized here has lead the ACGIH to classify fibrous glass a nuisance dust. Following is a list of precautions and recommended * safety/industrial hygiene practices: Glass is one of the oldest and most versatile materials used by man. However it wasn't until 1841 that man developed the technology for spinning resistance, non-flammability and resistance to microbial degradation. Since these fibers are made of glass, they have an inherent brittleness that can be reduced through the use of coating 1) Clothing should be loose-fitting and changed on a daily basis. They should cover the extremities leaving few areas of the skin exposed. glass fibers. The Germans were the first to use fibrous glass for heat insulation. This resulted from a shortage of asbestos during World W'ar 1. In the 1930's, two U.S. companies, Owens Illinois Glass Company and Corning Glass Works developed a commercial method of agents (4 to 14% by weight), including binders and lubricants. ^ QQ2^28 2) Many of us have experienced the burning, itching, and/or pricking sensation from handling fibrous glass, whether at home or on the job. The Fibers should be washed off with ample amount of lukewarm or cool water. Showering, following a specific task or work shift, is advisable in addition to a fresh change of clothing. fiberizing glass. Since that time, fibrous resulting dermatitis, generally observed, glass has been used in over 35,000 is caused by the transient mechanical, CBf 3103835 (Continutd on Page 2> The Monitor" is a forum for ideas, comments, and useful news relating to occupational health, issued by the Industrial Hygiene Section, DMEH, Monsanto, St Louis, MO. Quality Control for the Occupational Exposure Module of MEHI by Paul Easterday As part ol anv computer data collection system it is essential that the data entering the system is accurate. The sating "garbage in. garbage out" is appropriate for computer systems where no provisions have been made to verify the accuracy of the data generated. With the exponential growth of data in MEHI. a need was identified to verify the accuracy of the data. Based on this need I)MLH has developed a program designed to ensure data entering the MEHI system is accurate. The MEHI quality assurance program has been implemented to determine the accuracy of the MEHI header, work, and industrial hygiene records. This program has been designed to provide the plant immediate feedback concerning the quality of the data in their master files. This will provide an error rate for the records that were entered during the previous calendar quarter, and will allow the plant to observe the types of errors, if any. that ma\ be unique to that location. Both direction in correcting errors and information on how effective the program is in collecting accurate work history and industrial hygiene data will be returned to the plant. Each quarter the plant will be sent an evaluation report based upon MEHI records that were entered during the previous quarter. The report will contain up to five computer printouts: 1. all new header records for hourly employees, 2. all new header records for salary employees. 3. a random sample of work records for hourly employees, 4. a random sample of work records for salary employees. 5. a random sample of industrial hvgiene records. The number of printouts that each plant will receive will depend on whether header, work, or industrial hvgiene records were entered during the previous quarter. As part of the MEHI quality assurance program, it will be the plant's responsibility to compare MEHI records on the computet printouts with plant records that document ait work hivtmv changes for eacli employee. 1 he tecoids may be personnel records, pay roll records, and or departmental logs, as long as they are an original, accurate source of information (not the MEHI keypunch schedules). For industrial hygiene data, compare the MEHI records on the computer printout with the original monitoring forms (this is not the 10. 20. 30 record layouts) at each of vour locations. Whatever the source of information, the objective yvill lie to determine the accuracy of the MEHI with respect to the plant records. Health evaluations including responding to proposed health regulations, epidemiology (morbidity and mortality ) needs, and responding to potential litigation require a data base that is both accurate and verifiable. We believe this program is a first step at ansyvefinglhis expressed need. U you have any questions concerning the program._contact your DMEH industrial EimiK ejjidcmK \ ot irt iiing'.nut irritation have turn K-pnued when yvotk clothing has been included with other family laundry in the family washing machine. It is suggested that clothing be washed by itself ill a tub or basin. The tub m basin should then be thoroughly rinsed. Additionally, rubber gloves should he worn by the l.umderei to prevent further incidence of dermatitis. In conclusion, evidence indicates that fibrous glass causes transient, mechanical, cutaneous irritation ol the skin and the sequelae oi scratching and in severe instances upper respiratory irritation. Long term effects of fibrous glass exposure have not been reported. Should you have anv questions, contact vour DMF.H industrial hygienist. OSHA's Position on Sampling When Wearing Air Supplied Hoods fry Joe Woljfberger "Mr. Easterday, the computer informs me that you've been kicking it." Fiberglass (Cont.) 3) It is recommended that workers not use air hoses and'or brooms to dean themselves. Such actions could result in driving the fibers deeper into the skin. 4) The use of personal protective equipment should include some form of gloves for hand protection and the possible use of a dust respirator to reduce the potential of upper airway irritation. A phenomenon known as "hardening" occurs in fibrous glass workers from which they no longer exhibit signs of skin irritation from exposure to the fibers. 5) The laundering of work clothing creates yet a different problem. On March 30, 1984 OSH A published a long awaited revision to the Industrial Hy giene Field Operations Manual (FOM). Of particular interest is a change in the requirements for sampling when employ ees use air supplied hoods. In Chapter II, Section F(3) the manual directs the OSHX industrial hygienist that: "In sampling'for employee exposure to air contaminants generated during work operations yvhere air-supplied hoods are used (i.e., painters or foundry chippers and grinders), ensure that the filter cassette is located inside the employee's hood." The FOM also specifies that when sampling for air contaminants generated during burning and yvelding operations the filter cassette should be located inside the employ ee's welding hood. Sampling inside personal protective equipment (PPE) worn by employees can provide useful information regarding the effectiveness of the PPE. This information can be invaluable when showing the effectiveness of PPE versus other control measures. Developing a valid sampling protocol and strategy. (Continued on page 3) 2 CBY 3103836 C 002229 OSH A (Cont.) however. c.m be very dill'ic ult when dealing "''l1 iUcrv protection oilier ill.m air' supplied hoods. When these sampling technique problems are oseiiome. ibis ivpe ol sampling will provide a mol to evaluate the ell< ( tiseness of PPE programs. Until it is |( .isiblr to perform this t\pe ol sampling toi all lesjinatovs rtuiemliei the OSHA IOM's Ditettive for sampling employees wealing ail supplied hoods and welding helmets. Jackie Gaul Pr6moted by Sieve Pit iiI Jackie C.atil. the Chocolate Bayou Plant industrial hvgienist. was recentlv ptonioied to Distribution Operatiotis .Superintendent at the Texas City Plant. In the past, some network industrial Ingiene professionals have been mmerned with the lack of mobility in the 1H area. Jackie's promotion has olleied some encouragement that diet tu.n he considered for other assignments. We congratulate Jackie on her pioinotion and hope that others mac be con-ideied lor assignments which hinaden their experience and improve tht 11 organizational mobility if thev c boose to pursue other career paths. EPA Chemical Advisory On Used Motor Oil by Glenn Hachey A few months back EPA issued one of what it refers to as "Chemical Advisories", t hese advisories are designed to give indi viduals and organizations information to make informed decisions on how to safely handle chemicals. The advisory stated that: lit a laboratory study, mice developed skin cancer after their skin was exposed i** used motor oil twice a week without Ix'ing washed off. for most of their life span While this one study is not con clusive. substance found to cause can cel in l.iboratorv animals may also cause canter in humans. "f felt that although there might pos sible be some occupational exposure out there to some of our mechanics, there probably was a potentially even larger ncn-occupational threat from people who handle this material infrequently at home. I know I personally do my own routine maintenance on my vehicles and even my lawnmower (forget the lawnmower - I lied) and I have had a few bouts of dermatitis with certain lubri cants. The EPA advice certainly got my attention and 1 have now saved enough plastic milk jugs to dispose of a year's worth of oil changes and 1 now take them to the recycling center at my local garage. I have even broken down (with some subliminal encouragement from my wife) and discarded some of my favo rite wipe rags that were beyond the laundering stage. I should probably know better anyway from my safety- ness, irritation, and possibh more serious toxic effects. DON'T over-use waterless hand cleaners, soaps or detergents. Thev can remove the skin's natural pro tective barrier oils. DON'T pul oily rags in pockets, or tuck them under a belt: this can cause continuous skin contact. DON'T pour used engine oil on the ground or down drains and sewers; it is a violation of federal law. EPA encourages collection of used motor oil at collection points in compliance \vith appropriate state and local ordinances. background that oil soaked rags are not good to keep around from a fire risk standpoint, but it's funny how a lot of safety'heaith professionals do things at home that they wouldn't even consider at work. I guess we shouldn't expect our workers to be much different. A Brief History Of Detector Tubes by Gerry IV. Buttler Here are some helpful DO's and DON'T's supplied by EPA for handling used motor oil that you may want to pass along to your maintenance workers and weekend mechanics. Recommendations DO's One of the most common direct reading tools used by industrial hy gienists for the determination of gases and \ apors in workplace atmospheres is the detector tube. The impetus for thefr development first came from the mining industry where the use of animals usually white mice or canaries was the only means of providing an immediate warning of dangerous carbon monoxide DO follow work practices that mini mize the'amount of skin exposed, and the length of time used oil stays on skin. DO thoroughly wash used oil off skin as soon as possible with soap and water. A waterless hand cleaner can be used when soap and water are not available. Always apply skin cream after using water less hand cleaner. build-up. Most other techniques available prior to 1920 used conventional sampling techniques and subsequent laboratory analyses, often hours or even days later. Even the use of the simpler colorimetric analytical procedures could not yield instantaneous evaluation of the carbon monoxide levels in the mines. Two Americans, A. B. Lamb and C. R. Hoover, patented a detector tube for measuring carbon monoxide in 1919. It was based on the colorimetric reaction of DO wash oil-soaked clothing before wearing it again. Discard oil-soaked shoes. DO use gloves made from nitrile. Neoprene, Viton or other material that oil cannot penetrate, if practical for your kind of work. carbon monoxide with iodine pentoxide and fuming sulfuric acid. Pumice was used as the carrier material and, along with the reagent chemicals, was referred to as "Hoolamite" and packed into thin glass tubes. As air containing carbon monoxide was drawn through the tube by some sort of pumping device, the "Hoolamite" changed color to green. DON'T'* 3103837 DON't use kerosene, thinners or solvents to remove used motor oil They remove the skins natural protective oils, and can cause drv- 3c The intensity of the color could then be related to the concentration of carbon monoxide. Although this was a significant advance in the field of industrial hv giene 002230 (Continued on page 4) i 1 , i , . ! Detector Tubes (Cont.) monitoring, it was not until the micl-1930's that another detector tube emerged, this time for hydrogen sulfide. The major stumbling block in the advance of this monitoring technique was the lack of adequate technology in preparing the colorimetric reactive fillings for the tubes. Many of the common wet-chemical reactions that could be used for gases and vapors could not proceed in a dry-medium such as that in the tubes. Additionallv, many reagent mixtures were not stable over a long period of time for them to have the durability and reliability necessary for practical use. Inevitable, these problems were overcome or at least circumvented because of the potential speed, convenience, and simplicity that this technique could provide. In the early 1950's, more suitable chemical reagents impregnated on granular supports were prepared and new detector tubes for other vapors were developed: alcohol, benzene, and water vapor. In 1952, Grosskopf reported on tubes developed for determining carbon disulfide, chlorine, methyl bromide, nitrous fumes, and sulfur dioxide. Concentrations were indicated in different ways as detector tube technology began to grow. In some instances, color changes were compared directly with charts of color tints: in other cases, the concentration was indicated by the length-of-stain on the indicator gel. Throughout the 1960's and 1970's, the use of this form of monitoring greatly expanded as the number of materials which could be detected increased. Today, over 200 different types of detector tubes have been developed and marketed by such companies as Drager, MathesonKitagawa, MSA. and Bendix-Gastec. Both short term tubes for task or STEL sampling and long term tubes for TWA sampling are available. More recently, diffusion detector tubes which require no pumps have come into use. such as the ones Drager makes for ammonia, hydrogen chloride, and hydrogen sulfide. While detector tubes remain important aids to the industrial hvgienist. they are not without their limitations. There are still many materials for which detector tubes are not available or feasible. Also, many of the colorimetric reactions frequentlv used in the tubes determine only classes of compounds or functional groups and mav not provide the specificitv desired Cross-ititci ferences are common, and the hygienist should take care that he doesn't use a particular tube that is affected Try nontarget compounds known to be the atmosphere he is monitoring. Deviations in the amount of air drawn through the tubes from that for which they were designed can yield errors. Nevertheless, detector tubes remain a valuable resource for the immediate assessment of air quality as long as their use is supervised and their results are interpreted by trained industrial hygienists. Field Validation Entries into MEHI by Paul M. Jeannot "Field validation" is an integral component of a quality industrial hygiene monitoring program. The scheme(s) provides a means to determine the long-term effectiveness^performance of an entire monitoring method in the actual workplace environment where interfering components may exist. As such, it is equally as important to document into MEHI the levels and recoveries of the field validation sample(s) as it is to document the field data itself. In this regard, a temporary and somewhat unwieldy procedure for inputting field validation data into MEHI, was described by jeannot. P. M., "Field Validation Into MEHI", Industrial Hygiene Monitor, Volume 4, No. 3, March, 19B3. p. 3. This present article will describe a simpler inputting system which will allow both DMEH and the locations greater capabilities to retrieve and evaluate past validation data. This system should be integrated into the plant MEHI program as soon as practicable. The data will be used bv DMEH to audit method perfoimance and validation frequentv for the purpose of method valtditv classifier assignment. With respect to the "Validation" tV) determination tvpe onh. data should be entered with the following modifications: 1) Multiple "30" cards on the Data Transmittal Form mav be submitted for materials with the same CAS No. and the veev/r Determination No. 2) In field 34 fUG) of the "30" card use "B" for background samj)le(s) and use "S" for spiked (validation) sample(s). 3) Record the appropriate concentration level(s) for the background sample(s) in the "Results" fields using the appropriate unit code, using "B" for background in field "34". 4) Record the calculated theoretical spiked level(s) for the appropriate sampling period in the "Result" fields using the same unit code as the background, using "S" for spike in field "34". 5) Enter the spike recovery for the spiked sample(s) in the "Result" fields using the Percent (PC) unit code, also using "S" for spike in field "34". 6) Note: Sample types for validations must either be Personal (P) or General Area (G) on the "10" card. Example: Parallel Background Result - tk.VJ ppm 1st Validation Level Spiked - 1.03 ppm 1st Validation Result (Recovervi - SIT.u.VT General Area Sample - N\V Wall ol Kettle No. 4 DMEH Method Number - 30S1A Other information for validation samples should be entered onto the Data Transmittal Form, as appropriate. Please recall that field recoveries should not be used to correct field data for MEHI entrv. 4 o 002231 CBY 3103838 Monsanto Volume 3, Number 7, July 1980 ENVIRONMENTAL ANALYTICAL SCIENCES CENTER MONSANTO RESEARCH CORPORATION DAYTON LABORATORY A SYNOPSIS OF MONSANTO AND ENVIRONMENTAL PROTECTION AGENCY ACTIVITIES IN THE IDENTIFICATION AND CONTROL OF PRIORITY POLLUTANTS Since late 1977, both the Environmental Protection Agency (EPA) and Monsanto Company have been very active in identifying and quantifying the presence of the 129 "priority" pollutants in our plants' process and discharge wastestreams. This article presents a brief history of both EPA's and Monsanto's activities, the findings as of the present, and future regulations expected. HISTORY OF THE "PRIORITY" POLLUTANTS In 1975, a group of environmentalists and public interest organizations spear headed by the National Resources Defense Council (NRDC) filed suit against the EPA for failing to issue regulations limiting the discharge of toxic pollutants. A consent order, which was entered in this suit in 1976, became known as the "Flannery Decision" and committed the EPA to develop effluent limitations for 21 major industries, covering a list of 65 chemical classes, from which specific chemical species were selected. A list of 129 species have become known as the "priority" pollutants. In addition, effluent limitations for these priority pollutants are to be based on "best available technology" (BAT). Thus, regulations to be issued have become known as BAT limitations. EPA AND MONSANTO DATA GATHERING EFFORTS Screening Studies When the consent order was agreed to, little or no information was available on the existence of these pollutants in industrial discharges. In order to do the vast job before them, EPA settled on a two-phase approach. In the first phase, analytical methods referred to as the "Screening Protocol" were used to collect data. These methods have a high probability of identifying any of the priority pollutants present in a stream in concentrations greater than 10 ppb provided the matrices are "clean" (i.e., contain very few other compounds). Further, these methods permit an accurate measurement of the amount of any of the observed species if the methods are validated in the matrices encountered. But for reasons of cost, this validation was not performed by EPA in this first phase of data gathering. Consequently, little is known about whether individual pieces of data collected using the "screening" protocol are either qualitatively correct or quantitatively accurate. CBY 3103839 c 0223z ^ Environmental Health Letter, August 15, 1980 tumors in one or more animal species or to induce benign tumors that are generally recognized as early stages of malignancies, and/or if positive epidemiologic studies indicated they were carcinogenic. Although the CAG has determined that there is substantial evidence of carcinogenicity for each chemical substance on the list, the data varies to some extent with respect to the scope and quality of the studies." The EPA list was drawn up primarily for use by its own offices. Here, then, is its list of chemicals having "substantial evidence" of carcinogenicity (meaning evidence provided by animal tests that demon strate the induction of malignant tumors in one or more species or of benign tumors generally recognized as early stages of malignancies): _ 2-Ac*tyl*mlnofluoroj Acrylonltrllt; Aflitoxins: Aldrln; 4*Amlnoblphtnyt; AmltrolcJ^rimltt; Arsenic ind Arsenic Comsoundt* Aibiitos; Auremine; Azeserine; Benz(c)acridine; BenzVsjanthrecent; Benzene; Benzidine; Benzo(e)pyrent; Benzofpiftuoranthene* Btnzo'filflua* renthene; Beryllium end Beryllium Compounds; NfN*Bis(2-Cnioroethyl)*2*NiPthylamlnt: Cadmium end cidmiumcomtoufiTrirhS^ Itnt: Cnrviant: Cltrui Rid No. 2*. cnal Tar and Rnnt * r.nka n..n . r..#...*. ___ -i_ ,1 A nV*i_ a _ ; Dibenzo(a.a) -Diathylhydrazine; *,- 3,3'-Dlmethyl- .___ :me; uimiinyi bunat*. ' ffispittHoeirDamat*: Ethylanaimina; Etnylana Hu.a..xAahchiAlo.AroAcUyd.ioAhha.xaAna..;'uHMydrr.a,z!Ain.t; lndtno{l,2,3i-cd)pyr#ne; iron O.ayxetirdaanI d; aishoysdaafr:oHlee;oKtaacpholner;TLHa*sXioWcailorproinbea. nzn*; Haxactilorobutadiane; Malphalin; Mathipyrllina; 3-Mathylcbolanthranai Mathyl Mathantsulfonatt; N-Methyi-N'-nitro-N-nitrosoguanidina; Mathylthiouradl; ^JLom-!!5ln.SiNlaU,'.tirA<l?iJi .VNipthy ,t.9el!nic*1 rM'sZ-NapMhylamintiNickal and Nickel Compound*; Nitrogen Mustard and it* hydrochloride; Nitrogen Mustard N-oxide and its hydrocnloride; 5-Nltro-o-toluidine; 4-Nitroouinotin*-l-oxid*. PentachloronltroPenzene; Phenacetln; Polychlorinated Biphenyls; Prortamlde; 1,3-Propana Sultona; 8-Proplolactone: Propylthiouracil: Tha 10*ctrnIId#: Thlouraa,o*T^oluIdIn* Hydrochloride; Toxaphana;Trichlortore*tchny,loernoeb;ib2,naz,6o-'.TP-rdiciholxoirno:pTheatrnaocl:hTlorlrso(el-tahzyirieidnin* y(lP)pahrcohslporhoinathsyuiairnidaa); (Thlo-TEPA); Trls{2,3-dibromopropyl)pnosphate; Trypan Blua, commercial grade: Uracil Mustard; Urathana; Vinyl Chlorida; Vinylidana Chloride. " In publishing its "candidate list," OSHA emphasized that it was a tabulation only of chemicals desig nated for further scientific review and possible identification, classification and regulation as potential occu pational carcinogens. ` : ' - ; T.. - The list does not mean that OSHA has determined that a substance is carcinogenic or that regulatory action on the substance is necessary, nor is such a listing intended as a pre-classification warning, OSHA emphasized. In its notice in the Federal Register, OSHA states: "It is OSHA's view that the compilation and publication of this list of substances accomplishes the following: infonns the public at the very first step in OSHA's standard-setting process that a substance is a candidate for closer scientific review; makes available to the public the data base for substances OSHA is :` 'Considering for further scientific review; reduces the number of substances to be subjected to such a review- guides the research community in focusing its resources qn those substances for which there is a need for testing and further research; stimulates early public comment regarding the availability and appropriate ness of new or additional scientific data; and, over-all, assists OSHA in setting of priorities and selecting of- substances for regulation." Remember again that OSHA's list does not duplicate any of the chemicals on the EPA list and does not include any substances currently being regulated by OSHA as carcinogens. - With those caveats in mind, here is the OSHA chemical candidates list, which again the agency empha ! sizes is not an indication of carcinogenicity but merely indicates the need for closer scientific review (synonyms are used here where they are more familiar): Acenaphthene, 5-nitro-: methan#carboxamld#';4-AC#tylaminoblPh#nyl; Antol: 3-Amlno 4-*tnoxyacetanilide; 3-Nitro-p-acetophenetlde; Anliin.; Aniline, N,N-dim*tnyi-p-nitroso-; Aniline, N,N-dim*thyl-p-(m-tolyUzo)-; Aniline hydrochloride; Aniline, N-methyl-N-nitroso-; Mich- ler's Base; Dapsone; Aniline, 4,4'-thiodl-; 2,4,6-Tnchloroanllin*; Aminomesitylane; p-Cresidine; 2-Amlno-r nitroanisolt; Anthraquinone, 2-amlno; asphalt; azobenzane. 2,4-Olaminoanlsole sulfate; Benzidlna dihydrochloride; Benzimidazole, 5mitro-; Amlben; Benzoyl hydrazlde; Michler's Katone; Qulnone dloxlme; Olacatylbenzidine; Oiamlnobanzidlnt tatrahydrochlorida; DU Ethionlne; Enthionine; Carbamic add, bls(2-hydroxy*thyi)dlthio-, monopotassium; Carbazole, 3-amlno-9-etnyl; o-toluidina, 4-chloro-, hydrochloride; C.l. Direct Black 38, disodium salt: c.l. Direct Blue 6, tetre- sodium salt; C.l. Direct Brown 95; C.l. Disperse Black 6, dlhydrocnlortde; C.l. Disperse Orange IX; C.I. Solvent Orange 2: C.l. Solvent Yellow 1; C.l. Solvent Yellow 3; C.l. Solvent Yellow 34; Benzene rtexacniorid*. Mechtoroettiamlne hydrochloride; Acetomethoxan; p-Nitroso-N-phenylanlline; Diphenylnitrosamine; ethylent glycol bis (chloromsthyl) ether; TDE; PrP'-Ethyl-ODD; beta-HydroxyethylhydrazIne; Ether, 2,4-dlchlorophyl p-rtitrophenyl; vinyl Bromide; p,p'-ODE; Fluoren-9-one, 2/4,7-trinitro-; Fluorene, 2-nltro; Nltrofurazont; sym-DImethylhydrazine dihydrochloride; Hydrazomethane; Metnylhydraztne monosulfate; . Hydrazine hydrate; phenylhydrazlne hydrochlorlda; Hydrazlna hydrogen sulfata; Cupfarron. DacarOaztna; m-Tetrachloropnthalonltrile;Mlrax; Naphthylamina mustard; Peracatic add; C.l. 76555; r-Chloropnene-1,3-diamine; 4-Chloro-l,2-benzanadUmlna; 1,2-benzenediamlne; 1,2-Benzenaoiamlne dlhydrochlorida; C.l. 76070;Tetrachlorvinphos; Methyl phosphate; HMPA; Pidoram; N-N'-Dlnltrosopiparazlne; Blsphanol A dlglycidyl atbar; Isonitropropane; Phenazopyridlna hydrochloride; Quinoline; Quino line, 8-nltro-; Carbamylhydrazine; Carbamylhydrazine hydrochloride;Cryogenenine; Olethylstllbestrol diproprionate;Terpen* polychlorinat*;= Oamlnozid*. 1_ Sulfamethoxazole;Ethyl sulfate; Ethyl telluractPCT; Entramln;Procarbazine hydrochloride;m-Tolu*n*diamine;o-Toluidlne;o-Tolui- dine, Se^tlorotTrlfluralln; Uracil, 2-thlo-; Monuron; N,N'-Olcthylthlouraa;TMTU; N,N,N'-Trimathylthiourea. j*.. t ' I; .. i /'T -. '* 12 U.S. AGENCIES TO INCREASE ENVIRONMENTAL HEALTH RESEARCH SUPPORT NEXT YEAR:. , .. ,si.. .. I'.xl:.'/ A / i* ` 1. 'tT :"?*?*''' .. - ..j.. , a**t - * , ~ -- . c**" - * < Total Federal agency funding for environmental health research in the fiscal year starting Oct. 1,1980, is projected to 5727.7 million, an increase of $22.2 million oyer the current fiscal year (3.1 percent) and an'- rtnciiguan uuiUz.u'o: A-3-f htrt . $. *; s j,. C 00Z233 C8r 3103840 * c c J.E. Fox, LP&S 0-22 - Texas City October 27, 1980 TELEPHONE CALL FROM TEXAS CITY HARBOR MASTER D.E. Kaldenberg Fred Herzog WG Gordon Lunsford J.T. White FD D. N. Campbell 2R-9 0-7 0-21 JA Glass 0--22 On Friday morning, October 24, 1980, Mr. "Doc" Holbrook, Texas City Harbor Master, called concerning the organic vapors that entered our plant from the south or dock side the previous night. Mr. Holbrook stated that he had been visited by the County Health Unit concerning the problem and he was interested in any infor-. mation we could provide to help him trace down the source of the contaminants that entered our plant. I provided him with the time, wind direction, wind speed, and the locations where it was entering our plant from his property. He appeared cooperative and concerned about the contaminants and'stated that he would definitely try to find the source of the material and try to see that it did not happen again. Mr. Holbrook said that he has someone on duty around-the-clock in the Harbor Master Office and they would be happy to help up try to run down any contaminants that were coming from his direction. He left his telephone number which is 945-5011. He asked that we call him at any time that there appeared to be a problem from the dock areas. Mr. Holbrook stated that one of their potential problems is the flare located near the new ARCO dock. On several occasions, this flare has either blown out or has been turned off. He asked that any time we have a problem would we please first check to be sure as to whether the flare is lit and if it is not, to Call it to his attention and he would see that something was done. br CBY 3103841 c 002234 10/78 AcrylonitrlU 0/76 Ally) chlorlda 11/78 4-Aminodlphanyl 7/74 Ammonia For thOM rrp o u d to tubtUnca at or abova action In a l For th o u axpotad to airborna concantrationt 3? to ? o OD f 3 2 1 >3*_ cT 0 5^00; > 2 *3 1" <3 1 8x 1 O >t473o*T s 8 >r 3 3 & o VC*j >O0to* to* OXaJ) Oto S T 00 3 30* co* t3o s > v 1f I* -o%i z> ll If -x0SO 033 C2m* ^ =33 jT m jr /k / YyA I* m m> o s 3 HI 3 C> 3 Ml 1! 3 >zz sc< tx 9 9 m zto 9 9 HI >zz 9 9 fa >zz 9 9 in r z * 9 m >zz 9 9 m soz> orZ 2* 9 m z(A 9 9m > > Zz 9 9m iy/WM/XCy 1 O XX X X XX X X X X X X X x' ' XX XX X X X X 3lz3 ll X XXX XX XXXX X X XX /ym X XXX XX XXXX X X XX XX //x XX / y$y X XX X X. X X X X X X X X X ym 9 99 I *> > P s & CD sro XX XX X X XX X y>yy g /Ay y&yy! I XX XX XX XX / VV*1 / rj / V/* / to / /-PV -H / -P ZhV/ //A>y&vv0> //w & GO Fl 1 Q C*5 XX XX IV 3 Ps ST 2fP -2 25 $ / an ^ J 1/ ^ C 0022ns C -DBRP DETERMINED BY RESPONSIBLE PHYSICIAN Asbestos Workers Examinations Asbestos workers will be given the routine physical examination every 12 months, and in compliance with OSHA the following is done: 1. Chest X-ray, PA and lateral views, prior to examination by doctor, for comparison 2. Pulmonary function test 3. Interval history 4. Hemoccult slide (not required by OSHA) 5. Fasting lab is optional ihl /vA C 002236 CBY 3103843 H ` 11S22 - ,7%'sfss WJICS AIO rt2Q';L.\7iC'i5 '< ' . J- ' Institute lor Occupational Safety and limit!-.. and to authorized /epresentati-es of - :*her. (2) Employee access. Ev/ry employee and former employee shal'/hive reason able r.rrz:' to any record/squired to be mclnhfir.ed by sv.bparasrfph (1) of this paragraph, which indi/atr's the em ployee''! own exposure traisbestos fibers. (3) Employee notification. Any em ployee found to have fc/en exposed at any time to airborne conc/itrations of asbes tos fibers in excess/of the Unfits pre scribed in parasnap* (b) of this section shall be notified in/writing of the expo sure as soon as practicable but not later than 5 days of tbe/finding. The employee shall also be tinKjy notified of the cor rective action bomg taken. f p Medical examinations--Q) Gen eral. The employer shall provide oir make tions. Records chn'l be rcAv-asd by employers for at least 20 years. (ii) Access. The contents cf the rec ords cf the medical cxrxmnnens required by this paragraph si ad be made available, for :nr.:c Ion tr.d c,: y::-g, to the Assistant Eeaciary cf .Tabor for Occupational Safely ar.d Health, the Director of NIOS1I, to author: red physi cians and medical consultants of cither of them, and, upon the request of an em ployee or former employee, Pi his physi cian. Any physician who conducts a medical examination required by this paragraph shall furnish to the employer of tire examined employee ail the hiformation specifically required by this paragraph, and any other medical in formation related to occupational ex posure to asbestos fibers. Inshuc! ion section has been lc.Fed acoortiinrly I hr.or editor:?.I changes hr'-'e also been made. 1. Section 9-1.loi Scope of sverert, is re; isoi to read a: f'Si.ws; 5 9-1.191 SCOpS !1! .5!!.;, art. Til's sub pert describes the Atomic Energy Commission Procurement Regu lation! and the AECPR Temporary Reguhitiar.s. It also describes exclusions from the AECPR as contained in the AEC Procurement Instructions. 2. Section 9-1.102 Establishment of -1EC Proc arene'it Regulations, is revised to read us follows; 9-1.102 fblnldbbmcnt ot the AEC I'roe'irrmeiU nernilc tions and tltc AECPR Temporary Regulations. 9 -1.102-1 AEC Procurement Regula `available at his cost, medical examina-. 3. A new j 1910.13 is added to Subpart tions. tions relative to exposure to asbestos re B of Part 1910, reading as follows: < quired by this paragraph. . (2) Prerljcener.t. The'employer shall 1910.19 Asbestos <lut. provide or make available to each of his Section 191').93a shall apply to the ex employees, within 30 calendar days fol posure of every employee to asbestos lowing his first employment in an dust in every employment and place occupation exposed to airborne con of employment covered by 1010.12, centrations of asbestos fibers, a compre $ 1910.13, 5 1910.14,5 1010.15, or | 1910.13, hensive medical examination, which shall In lien of any different standard on ex Include, as a minimum, a chest roent-) posure to asbestos dust which would ge-nogram (posterior-anterior 14 x 17{ otherwise be applicable by virtue of any Inches), a history to elicit symptom-) of those sections. atelcsT' of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced errpiratory volume at 1 second (FEVi.o), Effective date. Paragraph fb) (2) of 5 1910.33a shall become effective Juiy 1, 1973. All other provisions of 51 1919.93a, 1910.93, and 1910.13 shall become effec (a) The AEC Procurement Regula tions (AECPR) are hereby established. (b) Thesa regulations implement and supplement the Federal Procurement Regulations (FPR) and are a part of the Federal Procurement Regulations System. (c) The effective date of FPR issu ances throughout AEC will be the date indicated in the respective issuances un less otherwi:-: provided in the AEC Pro curement Regulations. (d) The effective date of AECPR is suances throughout AEC will be the date indicated in the respective issuances. (3) Anaval examinations. On or be " tive July 7, 1972. The current emergency 9-1.102-2 AECPR Temporary Regu fore January !!!, iU','3, arul at least an temporary standard Terrains La effect lations. nually tlieroaftor, every employer shai: until July 7, 1972. (a) The AECPR Temporary Regula provide, or make available, comprehen sive medical examinations to each of hi: employees engaged in occupations ex-1 posed to airborne concentrations of as' bestos fibers. Such annual examination shall Include, as a minimum, a chest (Secs. 3, 8, 84 St.'.t. 1593, 1533; 20 U.3.C. 3oS, 057; 20 CFR 1910.4; Secretary ot Labor's Order No. 12-71. 36 F_R. 37S4) Signed at Washington, D.C., this 2d day of June 1972. tions are hereby established. . (b) These rcguir.ticr-s implement and supplement the Federal Procurement Regulations Temporary Regulations. They also contain policies and proce dures initiated by the AaC which are roentgenogram (posterior-anterior 14 x 17 inches), a history to elicit symptom G. C. Guehtties, Assistant Secretary of Labor. expected to be effective fer a period of 6 months or less. atology of respiratory disease, and pulmonary function tests to include [FR Doc.72-3574 Filed 6-3-72; 3:-13 amj (c) The effective date of the FPR Temporary - Regulations issuances forced vital capacity (FVC) and forced throughout .AEC will be the date indi expiratory volume at 1 second (FEVi..)*/ cated in Tic respective issuances unless (4) Termination of emplcysiesiL The \ Title 41--PUBLIC CONTRACTSemployer shaiFprovide, or make avail otherwise provided in the AECPP. Tem porary Regulations. able, within 30 calendar days before or after the termination of employment of any employee engaged in an occupation exposed to airborne concentrations of asbestos fibers, a comprehensive medical examination which shall include, as a minimum, a chest roentgenogram (pos terior-anterior 11 x 17 inche^-% history to elicit symptomatology ofcseplratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second AND PROPERTY MAHAOELIENT Chciptc-r 9--Atomic Energy Commission PART 9-1--GEME3AI. Subpart 9-1.1--Procurement Regulations Miscellaneous Amendments The changes made In AECPR Subpart <d> The effective date cf the AECPR Temporary Regulations issuances throughout AEC will be the date indi cated hi the respective issuances. (e) The AECPR Temporary Regula tions are part of the AEC Procurement Regulations and the Federal Procure ment Regulations System. All references to the AEC Procurement Regulations or AECPR In 9-1.103 through 9-1.109 of this subpart shall be deemed to include the AECPR temporary revelations. (FEVi.,). (5) Recent examinations. No medical examination is required of r.ny em ployee, if adequate records show that 9-1.1, Procurement Regulations, have been made in order to establish the AECPR Temporary Regulations, which are a part of the AEC Procurement Reg 3. Section 9-1.103 Authority, is revised to read as follows: 9-1.103 Authority. the employee has been examined in ac ulations and the Federal Procurement The AEC Procurement Regulations are cordance with this paragraph within the Regulations System. The AECPR Tem proscribed by `ha Gouerrl Manager, As pa-=t 1-year period. porary Regulations implement r.r.d sup sistant General Manager for Administra 5) Medical records--U) Mainte- plement tho EPF, Temporary Regula nc 'ce. Employers of employees examined' tions. They also certain policies r.r.d pursuant to this paragraph shall cause procedures initiated by the AEC '-.hich to be maintained complete and accurate are to be effective fer a period of 0 tion. or the Director, Division of Con tracts of the AEC, pursuant to the au thority of the Atomic Energy Act of 1954, and the Federal Property and Adminis rewords of all such medical exanfina- months or less. The Al-fC Procurement trative Services Act of 1949. FcOEitAl REOISTER; VOL 37, NO. 110 --WcONSsOAr, JUNS 7, 1972 c 002237 CBY 3103844