Document gbXE43md8LjK9L6n2z8GJ8NoV

CW*007i E. I. DU Pont de Nemours & Company Wilmington, Delaware EMPLOYEE RELATIONS DEPARTMENT January 11, 1973 CC: W. I. Morton - S6F, Wilnington W. E. Neff Fils Dept. , Kiln. W. R. LoFlour - Fil* Dept., Clinton J. F. Morffta - ERD, Haskell Lab. PLAINTIFF'S EXHIBIT DUP-848 L. C. LENTZ CLINTON PLANT FILM DLP/.RTMF. .'T ACR2ST0S BEST CONTROL (Ref. Meae L. C. Beatz to J. B. Howard, 10/19/72) In accord with our conrarsatlon yesterday, I aa forwarding the abore aeao to J. F. Morgan, Consultant, Haskell Laboratory, for further review and coraent, since preliminary discussion indicates sone aspects of your plan nay not ho in accord with developing Coapany guidelines. Examples include ceiling ex( posurc liaits and evaluation of sampling data. As you are perhaps aware, an Engineering Standard is being developed to further advise retarding atbeatoa hazard control considerations. Haskell it collaborating in this preparation and has done considerable work in the field recently. Vt ex- Ject that this standard will he issued in the near future, owever, concensus on its wording is yat to ho ostablishod. A copy of the tentative standard presently under the Standards Cosmittea's consideration is attached for information only. To expedite covwurication, we suff.est by copy of this ero to Morgan that ha forward comments directly to you, with a copy to the writer for information. If wo can ho of further as sistance , plsase advise. SAFETY AND FIRE PROTECTION DIVISION $!: J. F. Gantry, Senior Engineer Engineering Section { JEG:srd Attachment DUP 1142325 DU 059701 SAFtif L FfilE prsilltTw;) 8>. Rtf. JO H3V271S72 J. B. HOWARD AM ANS. PM ?lu|s|in|uu:iuisi3i4.|iie I I I I I I l I i l i* ENGINEERING SERVICES SUPVR. R. W. WcIIman C, R, Edwards L. R. Redman J. L. Sparks - J.J, Young L. C. Bontz - Tile Cl Inton, I owa October 19, 1972 C087 ASBESTOS DUST CONTROL A review has been made of the requirements, procedures, and equipment needed to comply with the Occupational.Safety and Health Act regarding exposure to asbestos dust/ -The--1-aw-doa-U-wi-th* the fol lowing major areas: <* /,, V/e/ i'// ZS (1) Permissible concentrations of asbestos fibers (2) Methods of compliance (3) Warning signs > labelling (b) Monitoring (5) Medical examinations (6) Record keeping l - Perm!sslble concent rat Ions of asbestos dust cr,/; / JThe limit of occupational exposure to eight hours of asbestos dust v J*7, Sfc. r !'mmuust not exceed five fibers longer than five microns per cubic (.centimeter. (Concentrations above five fibers but not to exceed -, r-./* --------- ___ ten fibers arc permitted up to JMft^cn. mlnutcs/hr.), I cy.AfJ'"-------------------------------------------- - c.*// r' v/,. ) Syv, To determine what the asbestos dust exposure is In pipe coverer's work areas, a 91.1*9 work order is being processed to purchase a Bendlx Cl 15 Personnel Monitor. This sampler is recommended by Frank Fuller, CSO, and is available thru the Polymer Intermediates Dept, of the Company at a 10% price discount. Delivery Is estimated at three weeks. , 2 - Hethods of compliance Reducing the creation and dispersion of asbestos dust Is the best method of compliance. To achieve this reduction the following items are proposed: A f Wearing of respirators by all maintenance personnel when working with (or In the Immediate area of) O.,, IM.i) osbestos InsulatIon material. To implement this proposal, six H.S.A. Oustfoe H 77 respirators fjt* C </ * --n4j appropriate filters are on order (November 1st \ delivery). -Cr AW >*/*-. ^ !- /j wi ' */ 4?*a' \ | ' *' * * - y Ivor v w/v rv) \ Provide * separate room, complete with a separate CsS< rcc/*/ exhaust system, for the fabrication of asbestos T/c> <r 7 11 ft 1 Insulation (see attached sketch) . This "asbestos r./ room" would contain lockers for each pipe-cover's * tv* / r ft - t coveralls, a Torit down-draft work bench, and new ' A v. uti iivffftf f y jband sow ($ 700) . Tho lockers would he vented to >eA>'' -*. rc i.kJjes* s<-* tLz/11 ;the room exhaust system as would tho work bench c'.-w*/l-.... ./ rgyfftA (tnJ i iityfirw tU land band saw. /it (c 7X.I,, /o it /'At DUP 1142326 (< */** '/'/ tAtf./u -/or ..e.j/nt/, ' tun* W.J r*._tin * CJ ->/a/ , /< . /*> t /k / >i /> '"/ y DU 059702 Asbestos Oust Control October 17. If)72 2 - Methods of compliance (Cont'd.) r Ow oco C - Vacuuming of all asbestos material storage areas and work shops at least once each week. In the cast of asbestos work shop areas, It Is further recommended that they be vacuumed at the end of each work day that asbestos material was processed (handled, fabricated, etc.) D - All asbestos scraps to be sealed In a plastic bag ond labelled prior to disposal. E - The consuming or storing of food should not bo-W/>*'* J - -ce allowed In pipe covering shop. Ci>*iT S'e*. ^ 3 " Warning signs and label!Ino Asbestos Oust cautions' signs have been ordered as per proposed Engineering Standard S4T, Figure I. These signs are enclosed In an acrylic cover and are from the same vendor that supplies this sign for the Construction Oivision. A sign should be secured to the pipe covers shop until such time as the proposed "asbestos .room" Is completed, then the sign should be relocated to that door. Asbestos warning signs to be posted at each plant work areas (outside of pipo coverers shop) In which asbestos work Is being done. It will be necessary to attach a label (Engr. Std. SbT, Figure 2) to all raw material or scrap bags containing asbestos products. The appropriate labels are to be printed up. k - MonitoringI ***/>' y (*>`4 j-The-OSHA -re gu I a tlon--request.-tha t_tbece_b7^pers ona I and {environmental monitoring at Intervals no longer than six . 'months. After receipt of the Oendix sampler a program [will bo started whoreby each plpc-coverer will initially ,,*w ;bo sampled five times (the high and the low samples to . * Ibe thrown out). The average of the remaining three samples >1) # C'w5//Or.r/.-,.'to be co. mpared with subsequent samples taken at six month `Intervals. Form EN273I Is on order from the Engineering Department to ** ^I\rr^/' provide tho appropriate form for record keeping *4Mt -tfl /*/ ' Purchasing Is searching for testing labs that can make the proper, analysis df the test filters. So far they have made S-^4 contacts with two such testing labs and arc getting cost estimates for/this type of work. . t ,f?/ . ?.>re 4oij . Jft A r ire ) i '`.'Due/ t /siazur* - A r < . '-/ d < t r'/ Ar c /.#-> /oi i Atrt DUP 1142327 DU 059703 Asbestos Oust Control October 17. 1972 5 " Medical examination? , The law requires an appropriate medical examination annually and our present plant oroqram should suffice In this regard. Kto thif 6 - Record keenI no A record must be kept on each individual and shop area to be certain that, that person or work area has not been exposod to asbestos dust beyond the permissible concentrations. The previously mentioned form EN2731 will provide this record and must be kept on file for at least three years where it must be made available upon request to the OSHA inspector. ff ` c F> In addition to'thc programs outlined above, an Informal education program should be undertaken by Maintenance Supervision to Inform the plpecovercrs of the procedural and equipment changes that arc needed to assist In asbestos dust control. Also as these steps are undertaken to meet the immediate requirements of OSHAf a long range study Is to be Initiated for the purpose of finding substitute materials to replace asbestos. L. C. Ocntz Senior Design Engineer 0089 DUP 1142328 DU 059704