Document gbe6zLyqxrNm6DzLOje5o5E8a

FILE NAME: American Biltrite (AMB) DATE: 1976 DOC#: AMB002 DOCUMENT DESCRIPTION: Letters from AIA to Dept of Labor and Attached Dept of Labor Report /Ay y F&1 ASBESTOS INFORMATION ASSOCIATION m> -- -->1,11||inmn M M W M J -- W_l-- JUJIM 1035 K Street. N.W.. Washington, p.C, 20006 (202) 223-4805 17 September 1976 Dooket Officer Docket H-033 U.S. Department of Labor Room N-3620 200 Constitution Avenue, Washington, P, C. 20210 N.tf. Dear Sir; Please refer to this Association's letter of 8 April 1976 and ~ accompanying documents prepared and submitted in response to the proposed revision to the standard for occupational exposure to asbestos (29 CFR, Part 1910) as published in the Federal Register, October 9, 1975. in the Association's response exception is taken to the statements on "New Evidence" noted at pages 47655-6, Federal Register, October 9, 1975. Specifically, it is stated, at page three, volume I of the Association's response: "Our review of the literature indicates that no credible epidemiological studies have been published which would suggest an excess 'of . malignant tumors among persons exposed to no more than 2 asbestos fibers per cc of air (TWA), using the prescribed membrane filter test method* This is a fact simply because there have yet been identified for study no populations the exposure experience of which consistently has been as low as 2 fibers. Since all populations studies to date have been ex posed to substantially higher concentrations of airborne asbestos we can conclude only that an excess of all types of asbestos disease is associ ated with levels of exposure significantly higher that the level currently mandated to become effective on July 1, 1976." This summary statement is made on the basis of the study and review pri pared by Hans Weill, M.D., Professor of Kedicine, Tulane University, which is at part 3, Volume 1 of the Association's response. 141069 AIA WL 000016 Page 2 Attention is invited to Dr; Weill's comments on the importance placed by OSHA on the orally presented (not published) report attributed to Howard, Kinlen, Lewinsohn, Peto and Doll: "A Mortality Study Among V/orkerS in an English Asbestos Factory," XVIII International Congress on Occupational Health, Brighton, England (1975). This report is noted at reference 30, proposed revision to OSHA standard for Occupational Exposure to Asbestos. Attention in further invited to the Johns-Manville Corporation comments on misinterpretation of the "English Asbestos Factory" studies. The J-M comments were formally presented to the Docket Officer (H-033) by letter dated April 9, 1976 and are part of the official OSHA record. For the purpose of fully clarifying the record on this matter, this Association requested TBA Industrial Products ltd., parent organization of the referenced ''English Asbestos Factory," to provide the data developed from the study. This data and ac companying statement from TBA Industrial Products Ltd,, is here with transmitted to OSHA as a supplement to the Association's comments of April 8. The statement and supporting tables substantiate the assertions made by Dr. Weill and the Johns-Manville Corporation that the co hort emphasized in the OSHA document provide no data to impugn the adequacy of the current U.S. standard of two asbestos fibers/ ml, TWA. Please he advised that appropriate expert personnel from TBA In dustrial Products Ltd. are prepared to testify at public hearing for the purpose of eliminating any possible further confusion as regards this matter. Acknowledgment is requested that this letter and its enclosure are included in the official record of the rulemaking procedure for consideration of revision to the standard for occupational exposure to asbestos. Sincerely yours, Executive Director RHM.-V Enclosures 141070 AIA WL 000017 J \tVw. ASBESTOS INFORMATION ASSOCIATION KJTMAh'cft'vA "*"*** r i-i.L,.-yifffyt,-f.i^1T 1 ' 1635 K Str&el, NW ,, Washmqion. DC. 20006 !20?.) 223-535 20 September 976 Dr. Morton Corn Assistant Secretary of Labor Occupational Safety and Health Administration 0, S* Dept, of Labor 3rd & Constitution Avenue, N.w. Washington, D. C. 20210 , Dear Dr. Corn: * Please recall that we advised we would request from TBA Industrial Products Ltd. the asbestos fiber exposure data pertinent to the English factory experience cited as "of significant importance* in the discussion of "new evidence" at pages 4765S-6, Federal Register, October 9, 1975. This Association and the Johns-Manville Corp. took exception to OSHA's interpretation of the British data in comments on the. proposed revision to the current standard for occupational exposure to asbestos. By letter of September 17, 1976 a statement from TBA Industrial Products Ltd with comprehensive data from the English factory was transmitted to the OSHA Docket officer. For your convenience we enclose a copy of this communication. We would welcome the opportunity to discuss this matter with you and appropriate members of your staff, if there are further questions regarding this issue. . Sincerely yours, Asbestos Standard Task Force GGG: v Enclosure 141071 AIA WL 000018 6 MDOOO H M V IV NOATN ASBESTOS INFORMATION ASSOCIATION 1835 K Stret. N;W,, W*shinglon, O.C. 20008 (202) 223-4885 26 August 1976 Memorandum For: Subjects MEMBERS OSHA Statement of Work for Asbestos Standard Construction Industry Enclosed is OSHA's Statement of Work for an Engineering Feasibility Study and Inflationary Impact Analysis for Development of Standard for Control of Occupational Exposure to Asbestos Dust in the Con-' struction Industry. Research Triangle Institute, Triangle Park, C . , has Been awarded the contract effective as of August 17, 1976 with assisgbed completion date of January 31, 1977. rti ,, is required to forward its compelted work plan to OSHA by August 27. This paper will be forwarded to addressees when available". Completion of tasks in the statement of work and "certification" by OSHA is required prior' to promulgation of a proposed asbestos standard for the construction industry. (Notes Different than with the manufacturing standard (general standard), OSHA proceedings now require an engineering feasibility study and inflationary impact analysis prior to issuance of a proposal.) Best estimate at this time, without consideration for delays and based on discussion with cognizant OSHA officials, is issuance of pro posed standard in February 1977 with public hearing,following comment period, as early as summer, 1977, Members will recall letter to Dr. Morton Corn, Assistant Secretary Of Labor (OSHA), dated July 27, 1976 (distributed by AIA/NA Memo of 7/29/76) reiterated primary recommendation of the Association that the proposed rulemaking on the manufacturing (general) standard be deferred until these proceedings could be consolidated with proceedings for the adoption of a separate regulation for occupational exposure to asbestos in the construction industry. This view was concurred in by a number of non-members, of the Association in our response to OSHA of April 9, 1976 regarding the proposed revision to the standard. To date there has been no reply to our July 27 letter, however, it has been learned informally that the Association's recommendation is now under active consideration. At Directors meeting June 10, it was announced that an Ad Hoc Committee for Construction would be established. The Committee, composed of representatives of AIA/NA Standards and Technical Committee and participants from the construction industry, held 141073 AIA WL 000020 Pag* Two an initial meeting August 12-13. Contemplated activities' of AIA/NA in connection with a standard for the construction industry will be reviewed at September 8 Board of Directors meeting. ' Executive Director Enclosure cc; Mr. G. G. Gabrielson, Chairman, Asbestos Regulation Task Force AIA/NA Ad Hoc Committee for. Construction RHMjv 3.41074 AIA WL 000021 tas;; order ?. o ? laso ti CCLTKACT J-9-r-6-C035 FOR RSEARCH T RX ACLC I AS T IT UTE ASOSTOS INFORMATION ASSOCIATION/. North America 1335 K Street, U. W. Suite 402 Washington, D. C. 20C0-3 141075 AIA WL 000022 STATEMENT OF WORK FOR AH ENGINEERING FEASIBILITY STUDY AND PREPARATION OF A N - INFLATIONARY IMPACT ANALYSIS FOR THE . DEVELOPMENT OF A STANDARD FOR CONTROL OF OCCUPATIONAL EXPOSURE TO ASBESTOS y I DUST IN THE CONSTRUCTION INDUSTRY 1 141076 AIA WL 000023 A. INTRODUCTION The Occupational Safety and Health Administration (OSHA) is in the process of revising the standard governing occupational exposure to asbestos. A proposed revision waa published on October 9, 1975. Due to the uniqueness of th9 construction industry (e.g., the multiplicity of non-fixed workplaces, and the utilization of highly transient work forces), it was exempted from that proposal with the intent that a separate proposal on asbestos exposure in construction be developed in the future. Because of a number of special problems faced in construction, an engineering feasibility study wi.ch an accompanying economic inflationary impact assessment is needed by OSHA. The study is to determine, using a variety of control methods, the levels of asbestos exposure which are technologically feasible for the various construction activities, and the economic impacts of attaining and maintaining such exposures. 8. STATEMENT OF PROBLEM 1, General Requirements , t This study should provide substantial estimates of the technological feasibility of candidate provisions of a new asbestos- construction standard and estimates of the economic consequences upon the U. S. construction industry resulting from the implementation of such an asbestos standard. Due to the widespread use of asbestos, a detailed analysis 'of the effect on each aspect of the construction industry is impractical, However, a representative group o'f construction activities where asbestos containing products are installed or removed should be selected for detailed analysis from available data and reviewed with the OSHA COTR. > l 2, Deliverables From Bidders } Deliverables from bidders are defined as: ) a. Work Plani . b. Monthly Progress Reports? : c. Draft Report on Engineering feasibility Study; d. Draft Report on Inflationary Impact (Bevel 1 or Bevel 2); I e. Final Report. : 3, Performance Measurements , Contract performance shall be monitored against a detailed work 2 141077 r v * AIA WL 000024 plan and schedule which are to be submitted by the contractor not later than ten days after receipt of authorization to proceed. Quality of work shall be judged upon thoroughness and objectivity of fact gathering techniques, establishment of credentials for source data used, logical construction and presentation of rationale, as well as the general management of resources, within established time and budget constraints. , C. BACKGROUND ON AS3EST0S 1. Description of Hazard and Health Implications Asbestos, used since antiquity, has widespread and important applications in our modern technological society. There are over 3,000 different products containing asbestos in daily use throughout the U. S. The increasing use of asbestos has added to the urgency to cope with occupational health problems related to the excessive inhalation of asbestos dust. No cure now exists for the diseases caused by inhaling asbestos fibers. Employees exposed to asbestos include an estimated 100,000 insulation workers# 50,000 manufacturing firm employees, 60,000 end-product users, and uncounted thousands of construction, ship-building, and auto repair workers. The term "asbestos*1 refers to a group of fiberous mineral silicates that are highly abrasive resistant, incombustible in air, have high, electrical resistivity, and can be separated into filaments. The present asbestos standard designates the following minerals as asbestosi . ' . Chrysotile ' Amosite Crocidolite Tremolite Anthophyllite Actinolite. Exposure to asbestos fibers, even nonrecurring, short duration inhalation of the fibers, can seriously increase the risk of developing the following diseases after a period of years; . Asbestosis - nonmalignant scarring of the lung tissue; . Bronchogenic Cancer - cancer of the lung; . Mesothelioma - a rare cancer of the lining of the chest or abdominal cavities. , , 141079 AIA WL 000025 Prolonged exposure may also increase the possibility of developing cancer o the digestive tract. Within the last few years, asbestos has been recognized as one of the most hazardous dust contain inants in the workplace. Because of the wide variety of products and users of asbestos fibers, larger numbers of workers are in danger of being exposed to the hazards of asbestos fibers. It has: been established that cigarette smoking increases the risk of developing lung cancer in workers exposed to asbestos. Although asbestos has been recognized as a hazardous substance for many years, the lack of environmental data for previous years, and the long latent period for the development of asbestos-related diseases have delayed proving the exposure relationship until recently. The scant data from previous years does not permit the establishment of the dose-response relationship at this time? however, the risk of contacting an asbestos-related disease is believed to be exposure - related. 2. Nature of the Occupational Hazard . ** More than 200,000 employees face risks from asbestos, principally by inhaling asbestos fibers. Recent studies have revealed the presence of asbestos fibers in the lungs of persons having no history of occupational exposure. Presumably, exposure was in the area of ship construction or.other work sites where the atmosphere was contaminated with asbestos by spraying operations or other sources of ashestos dust. Some evidence indicates that, exposure to an asbestos workers' contaminated clothing is hazardous to passers-by and members of the workers' family. Asbestosis cases are on record that resulted from relatively light exposure of a short duration. Asbestos related diseases exhibit no known early warning symptoms, occurring as long as 30 years after the exposure period. ' Although asbestos has been known to be hazardous for inany years, the first cases were not recorded medically until 1900, some 22 years after asbestos production had become large scale. Recent studies have shown a high correlation between exposure to asbestos and deaths caused by asbestosis, bronchogenic cancer, mesothelioma, and to 3ome extent other types of cancer. Researchers are disturbed that many cases presently encountered are the result of conditions relating back to the 1930's. Although conditions of. use are improved today, uses of asbestos have expanded, production has increased, and products are geographically more widespread. The effects of exposures in the 1970's may not be known until the end of this century. r Exposure to asbestos may occur during any construction activity 141079 AIA WL 000026 Where asbestos-containing products ace either being installed or removed. In the construction industry, these products includei . Asbestos cement pipe and sheets; ,, Vinyl asbestos floor tile; , Sheet vinyl flooring; . Roofing papers; . Packings and gaskets? . Insulation/ pipe/ and thermal; . Coatings and compounds; and . Reinforced plastics. Construction activities that have the potential to release asbestos fiber are sawing, cutting, drilling, grinding, or otherwise, handling of these products. Since asbestos has been used in building materials for many years, it should be realized that in building demolition, renovation, and remodeling, the worker is and will continue to be exposed to asbestos fibers. 3* Standards in Force and Proposed An asbestos standard of 12 fibers pec milliliter greater than 5 microns in length or 2 million particles per cubic foot ofiair was included in the initial group of OSHA standards published in the Federal Register on May 29, 1971 {36 PR 10466). It was derived from an established Federal standard promulgated under the Walsh-Healey Public Contracts Act on May 20, 1969. An emergency temporary standard for occupational exposure to asbestos dust was published in the Federal Register on December 7, 1971 (36 FR 23207). It limited exposure as follows:" "The 8-houc timeweighted average airborne concentration of asbestos dust to which employees a*.e exposed shall not exceed 5 fibers per milliliter greater than 5 microns in length, as determined by the membrane fiber method at 400-450x magnification (4 millimeter objective) phase contrast illumination. Concentrations above 5 fibers per milliliter, but not to exceed 10 fibers per milliliter may be permitted up to a total of 15 minutes in an hour for up to S hours in an 8-hour day." I On January 12, 1972, a proposal for an asbestos standard was published in the Federal Register (37 FR 466). The proposal included the emergency temporary standard and additional rulea on subsidiary issues. After receiving recommendations from the National Institute for Occupational Safety and Health and the Standards Advisory Committee 141080 AIA WL 000027 on Asbestos in February 1972 and holding public hearings on the ocoposal in March 1972, the present standard was promulgated June 7, 1972 (37 FR 11318)* The present standard established an 8-hour time weighted average (IWA) concentration exposure limit of 5 fibers longer than 5 micrometers per cubic centimeter of air with a ceiling limit of 10 fibers which became effective July 7, 1972, and a 2 fiber TWA limit to become effective July 1, 1976. By way of introduction to the proposed revision of the asbestos standard, published in the Federal Register (40 FR 47652), OSHA has stated r "This standard, as revised, would continue to apply to all employments covered by the Act, but would exclude the construction industry. It is OSHA's intention to develop and propose a separate revision to the existing asbestos standard which would be applicable only to the construction industry." . This 3tudy is intended to provide essential information for. th development of a special standard for the construction industry. * -* D. ANALYSIS APPROACH ' ; 1. General Methodology In the organization and performance of this Task Order, the contractor must recognize the importance of an interactive, relationship with OSHA personnel to facilitate timely and effective achievement of the goals. A detailed methodology, developed in the form of a specific work plan, shall be the basis for the conduct of this effort. Further, the contractor shall assemble and identify a highly experienced interdisciplinary and multidisciplinary group of professionals to accomplish this task plan. ` In the course of conducting the engineering feasibility study and inflationary impact analysis, the contractor shall structure an adequate data base upon which to substantiate those results* This data base shall reflect all published and available data sources relevant to the analysis, including all data collected by OSHA personnel, os well as technical, governmental, and industrial publications not previously surveyed. Of special importance will be material collected in support of recommendations of OSHA's Construction Safety Advisory Committee and literature obtained from the Environmental Protection Agency on asbestos which was collected to document EPA's regulations on asbestos. ` Further, additional data, essential to the substantiation of these results, shall be obtained by th contractor as required.: The engineering feasibility shall include an assessment of a'wide rajtge I 6 141081 i ) AIA WL 000028 of construction industry applications of asbestos products. Minimum feasible asbestos concentrations shall be reported based on factual data and professional engineering judgment where appropriate. This analysis will include the type and level of control effort ne%ed to maintain these minimum concentration exposures, personal protective equipment, etc. Additionally, the feasibility of requiring medical surveillance, retention of medical records, and monitoring records similar to those requirements for other industries (Ref.; Federal Register, October 9, 1975) shall be evaluated for the construction industry. . The inflationary impact analysis shall consider the most feasible and cost effective remedial approaches required to comply with these minimum levels defined by the engineering study. While it is vital that the anticipated cost of compliance shall be discussed, it is equally important that the .'`anomic ramifications of those costs be considered. In the latter case such direct issues as the financial rt>,, constraints related to these cost burdens must be considered. Moreover it is important to address both the primary and secondary effects o incurring these costs in the various sectors of the affected commerce. This consideration must include at least the effects upon employment, productivity, supply/demand of critical materials, market -structure, and energy consumption. ,, 2. Identification of Specific Sensitivities and Areas of Invited Recommendations In performance of this Task Order, the contractor should indicate the level of confidence and uncertainty in all areas of analysis. Any economic dislocations should be specifically highlighted. The contractor should review marginal construction sub-industries to determine disproportionate impacts. Certain resource constraints of administrative aspects of standards compliance should be analyzed. With only 3500 certified Occupational Physicians in the United States, the burden of the medical surveillance requirements of the- asbestos standard upon the medical community must be assessed in light of other potential demands for their services. Additionally, the specific burden of keeping records on and reporting asbestos exposures must be analyzed and recommendations must be presented. The general availability of technical capabilities and equipment necessary for environmental monitoring of the workplace, as well as that of engineering control equipment, must be assessed. Consideration must also be given to any specific conflicts or complicating factors presented by other standards, rules and regulations promulgated by OSHA or other agencies. ' . 3. T.a.sk Pl1an" I In carrying out this task order, the contractor should follow 141083 AIA WL 000029 the sequence of tasks identified in Exhibit 1, to the extent possible The contractor should initiate the task order by meeting with the OSHA Project Officer and other OSHA officials to, assure a clear understanding of OSHA's specific needs and to gain a broad overview of the pcoject, including: major assumptions, limitations, and the timetable for completion. Agreement should be reached on report contents, frequency, and the mechanisms of the review process. The contractor shall analyze the overall skill requirements needed to conduct the project and develop a highly experienced project team with appropriate interdisciplinary and multidisciplinary skills. On or before ten calendar days after receipt of authorization to proceed with this task order, the contractor shall provide a step-by-step description of the approach - the task order with a detailed schedule and staffing plan. This workplan should be in such detail that OSHA will ba able to evaluate the methodology and the contractor's understanding, of the problem. It should be segmented into -logical phases with appropriate timing and manloading estimates so as to be suitable for use as a tool for measurement of the project's progress. The work plan should also show the division of responsibilities between the economic contractor and the engineering subcontractor to be engaged in the study. The proposed workplan and project staffing shallrbe reviewed and approved by the OSHA COTR. ' - 4. Task Descriptions The following is a brief description of the efforts to be carried out under each task: " Task A - Collect Information > A review should be made for all literature and materials available from OSHA (including recommendations of the Advisory Committee on Construction Safety and Health), EPA, and other governmental and industry sources discussing: OSHA asbestos standards (including 8- hour TWA limits, ceilings, record keeping, training, . medical/environmental surveillance requirements, and engineering- controls), asbestos-related processes and the like as well as EPA Background information on National Emission Standards for Hazardous Air Pollutants and EPA Development Documents. . Individuals and organizations concerned with asbestos exposure in the construction industry should be contacted and existing files built up by these parties should be examined. Such parties include: i . OSHA and NIOSH personnel; ! . Selected members of the Advisory Committee on Construction Safety and Health (Asbestos Subgroup); t . Construction Industry Associations; 141083 AIA WL 000030 Construction Trade Unions; . ERA personnel; " * Asbestos Information Association of rtorth America; . Municipal Health Authorities. Documents relevant to asbestos exposure in the construction industry should be collected. Also, information needed to make a Level 1 Inflationary Impact Statement should be collected. Such information might include Industry Annual Reports, Census Data, and Trade Journals. Task B - Identify Sources of Asbestos Fiber Exposure Present and possible future sources of asbestos exposure in the construction industry should be identified. Some of the major sources of exposure are found in the following construction processes or segments of the construction industry; . Installation or removal of asbestos pipe covers-; . Dry wall applications; * * Remodeling/demOlition; . Construction of power stations; . i , Boiler room construction t These and other construction trades where workers are' exposed to asbestos should be identified and quantified in such groupings as; ; (i) constant exposure to asbestos. 1 (ix) intermittent, exposure to asbestos. r (iii) incidental exposure to asbestos. A thorough review of previous studies, contacts with governmental enforcement officials, and review of monitoring data and select field studies should be undertaken. The particular construction operations which emit fibrous asbestos should be identified in terms of both the level of concentration and the degree of exposure (by- operation or class of workers). Task C ~ Estimate Number of Workers Exposed; Levels of Exposure The construction industry employment associated with various 9 141084 AIA WL 000031 levels of exposure to asbestos fibers and various fiber emitting operations should be estimated. This should be carried out through a variety of'contacts with industry, unions# governmental agencies, health researchers, and other parties knowledgeable about asbestos exposure in construction. Workers who do not handle asbestos, but who1 are exposed due to proximity to emitting operations should also be identified and their exposure levels noted. Additionally, information documenting the transiency of construction employment; range of employment durations? turn-over rates; employee multi-employer exposure; seasonal variations; etc., should be developed. Correlation levels of asbestos exposure levels/d.urations with specific trades/occupations should be obtained Task D - Analyze Effectiveness of Current Controls The effectiveness of strategies currently being Used to control asbestos exposure in the construction industry should be examined. The current control methods to be examined include: * Substitution; . , local exhaust - hood with vacuum; ' - , Work practices; - wetting down; vacuum tools; j . Personal protective devices; . - respirators; - work clothes. This task should be accomplished through the cooperation of construction companies and the use of certain field studies. Also, federal enforcement agencies (e.g., OSHA and EPA) and municipal enforcement agencies (i.e., those in Minneapolis, Chicago, and Philadelphia) should be contacted. Special attention should be paid to EPA's experience in regulating asbestos emissions at demolition sites. The effectiveness of current control measures with regard to reduction of exposure levels as well as other factors such as cost of achieving reduced exposure, worker acceptance, long term practicality, changes in worker productivity and other factors should be addressed. i 10 141085 AIA WL 000032 Task E - Propose Alternative Control Strategies Alternative control strategies should be proposed for the construction industry to achieve reduced exposure levels comparable to those levels proposed in the general industry standard (0.5 f/cc -hr TWA limits). The control strategies associated with 2 or 3 alternative exposure levels should be considered foe this task. The response levels should be specified and the control strategies to meet these exposure levels should be determined. However, there might be exceptions in certain operations of the construction industry where it may only be possible to determine feasible exposure levels based on existing and available engineering and other control methods. Asbestos engineering control methods in use should be examined in terms of their applicability to the various exposure situations found in the construction industry. In addition, all experimental control methods being developed, e.g. John Mansville's portable power tools, should be investigated and evaluated. Patent searches should be made. Foreign experience should be evaluated. Analogous dust control systems should be investigated, and their applicability or lack thereof should be explained. Wet fabrication, regulated , fabrication areas, pre~fabricated materials should be discussed'using all available data based on real world experience. Work practices that enhance or complement the effectivenes of engineering controls should be identified. Practices working with other substances, 6r in analagous situations (e.g. shipbuilding) should be examined for possible extension to asbestos work, foreign and domestic experience should be explored. Particularly significant are work practices suitable for use in demolition. Whenever possible actual data should be used. Exposure monitoring schemes should be examined for applicability to representative construction work situations. The issue as to whether many of the alleged variables in construction (e.g; non-, repititive tasks and exposure to the elements) negate the effectiveness of any scheme that calls for monitoring on a less than continuous basis in supplying projected estimates of exposures between monitoring should be examined.' This would lead to an identification of the kinds of representative monitoring schemes which would work for the construction industry. When considering medical surveillance, the additional problem when dates of periodic and preplacement exams occur randomly among employment periods of the transient work force and the related problem of medical recordkeeDing should be considered. Statistically, what are the chances that'certain kinds of construction employers will be hit with medical surveillance or recordkeeping burdens unrelated to 11 141086 AIA WL 000033 their employee population or to relative employee exposures to asbestos? Other ancillary requirements include change rooms and sanitation facilities and should be discussed in terms oE prototypical and representative construction work situations. Actual data should be used to the extent possible. . Task F ~ Analyze Alternative Strategies Each aspect of the alternative proposed under Task E should be analyzed relative to a full set of relevant considerations, to inclu< , Effectiveness in reducing asbestos fiber exposure? . Cost of compliance: - Capital; - Operating and maintenance; - Energy; ' ' ** - Ancillary (monitoring, medical surveillance, record keeping, etc.); Consistency with hierarchy of controls (OSSA); Worker productivity losses; 1 Adoption of substitute materials (functionally hazardous in use, more expensive, etc.). v . i similar, : Task G - Screen Inflationary Impacts in Level of IIS Required An approximate estimate of several relevant alternative provisions should be made to determine whether an IIS will be required. Such estimates should be made for each of the alternatives proposed in Task E and analyzed in Task F. Task H - Analyze Health Benefits Potential health benefits associated with exposure levels identified in Task P should be examined. All relevant information on health benefits should be utilized in this task. The record developed on the proposed general industry asbestos standard is expected to provide additional information on health benefits which should be incorporated. Task I - Prepare Draft Report on Engineering Feasibility Study 12 ' 141087 AIA WL 000034 A draft report on the results of the analysis of Task f , incorporating the results of Task H on health benefits should be prepared. The report should provide both findings on the various aspects of the analysis and recommendations for a proposed OSHA standard on asbestos in construction. The basis for the recommendations mu3t be thoroughly documented. Task J - Collect Information for Level 2 IIS ' In case an 115 is required, the contractor shall collect whatever additional information is necessary for the more extensive report. Task K - Preoare Draft Report; Level 1 IIS In case an IIA would suffice as determined in Task G, such a report should be prepared and submitted to OSHA for review. Task L - Preoare Draft Report; Level 2 113 In case an IIS is required as determined in Task G, such a report should be prepared and submitted to OSHA for review. 'This report shall include, but not be limited to, the following? m . Compliance Costs - The compliance costs quantified inr Task F including engineering equipment costs, implementation cost, energy cost, administrative control cost and the like?* . Indirect Costs - The financial costs of compliance effected by cost of capital, cash flow, depreciation of equipment, etc,; . Energy - In terms of STU's, the change in energy requirements resulting from the most cost-effective engineering controls identified in Task F. Consideration shall also be given to the change in energy requirements resulting front the possible utilization of alternative substances in the process stream, variations in specific process rates, or variations in end product process manipulation. .Examples of these variations are changing processes, substituting process materials, and modifying end products. ,, Critical Substances - Certain substances have been placed on a list of critical materials by agencies of the Federal Government due to their importance to the security of the Nation. Asbestos is one of these critical substances. Asbestos is utilized as a raw material in the production of critical materials and in this respect has an impact on the supply of critical materials. This potential impact shall be evaluated. J . Employment - Compliance with asbestos standards might Jiave 13 141088 AIA WL 000035 significant financial effects on construction operations resulting in significant changes in the size of the work force- Several significant factors which might be found to influence employment inilufe: . - Construction sub-industry being Eorced out of business - Modifying work practices or construction activity, and - Force substitution of alternative substances- * Productivity - The implementation of alternative controls and work practices may have ah impact on construction worker productivity. In other words, to evaluate that impact, a good understanding of the construction activities involved with asbestos materials, and implications of new practices and controls must be obtained, factors which might influence productivity includes - Engineering controls hindering operations; - Personal protective equipment hindering employee movement; ' , ~ - Less efficient alternative process; - Medical surveillance implications with respect to productive manhours. ,, . Market Structure ** Examples of the types of changes in market and/oc industry "structure that this analysis might identify are: . - Smaller firms going out of business or consolidating, producing monopolistic situations; i - Significant price increases affecting supply/demand relationships; and : - Firms choosing to manufacture alternative products affecting supply/demand* - Control methods affecting product quality and, in turn, product acceptability, e.g., wet processing of textile! In developing this economic analysis, it is essential that the contractor produce reproducible rationales for determining the economic impacts including identification of variables, associative relationships, choice of surrogate measures, and levels of .uncertainty or confidence. ; 14 141089 AIA WL 000036 After receiving written and oral comments from OSHA, the contractor should revise the previously submitted draft reports and combine them into a single document for publication by OSHA, if desired* The report shall contain a logical presentation of the data basis, the methodology utilized, and the results of the component analyses including sound professional judgement. The Engineering Feasibility Assessment shall provide detailed methodologies, alternatives evaluated, and recommendations relating to the engineering feasibility of reducing asbestos exposure to minimum levels during construction activities. 15 141090 AIA WL 000037 SCHEDULE The following deliverables from the Task Order will be completed as noted* Report Dug ' Oral Progress Reports Written Progress Reports Work Plan Draft Report on Engineering Feasibility Study Draft Report? lift, (Option) Draft Report? U S (Option) Final Report Biweekly Monthly Ten days after authorization 120 days after authorization: 120 days after authorization 135 days after authorization 165 days after authorization u i ; i 16 141091 AIA WL 000038 1YUAimt--mmflui d i i EXHIBIT 1 --Flow Diagram of Efforts Under the Task Order i --- AIA WL 000039 :: i'tO'j T h i s its to li:it i a t o T-.'.o'; 2 : h n b a s t e i D'_;;;> in th.a C o n s t r u c t i o n ~-i` Z 'cz-j, cvurjna.vb to t h u off . :bor Cur.t.T-'.cf C - C - 1 h 'CO 35. ''- t".ik i-' gnr.yreliy citotvib-.'i '-..-nr Itivi 7.'. off ehi co..ira -.i ,>ch .via rr-.rntr: ir.: l a t i o n e r y i r s o c t n io.t a r a u t i^tche'''.ol.-jgy. 3CriEDV7.I The following deliverables for this Task Order will ba completed as no tei. KIRCRT DOS * Oral Progress Reports ^ `.-ic itz a r, Rro.jr.szs Reports w Work Plan * Ora.fc Report on Engineering Feasibility 3tody * Draft Report; H A (Option} * Draft Report; 113 (Option) ' Final Report Bivraekly M o n th ly Tan days after authorization 120 clays after authorization 120 day-3 after authorization. 135 days after authori^-tion 165 days after authorization 7-zzz l*=e purchased Direct `.2Z-.2 * Ail computer programs and operational JCI* used by ATI in support of Task Order 2 * File description o all master files and working storage files 165 days after authorization 165 days after authorisation 165 days aft" . norization 141093 AIA WL 000040 The followin'? evaluation COfeu .03.' UUs ?*'< CiX j.' C Tor;-, r' :r, Isi-o- hou. inrtsas the fc^val contractor ar.tlmatoC and zvv.Uv.f of -the contractor'n d prbnofted: sr'^dci.-a r;"' 'srfo'v '.neve n Lab or Cdhb Labor Cataget* Project Director Rate $41,83 X Hours 524 " Total $ 21,345 Senior Analyst 35,94 :27.0S 75 2,562 27,927 72,007 -itoet Costs 3,942 $121,079 Computer: Char5-23 (tUCC5 4.0 hr. 2cOr.oic Data2/ total Direct Costi Total Ta?> Tbi?- -".--t $72S/he.1/ ~~ 2,904 3,025 $ 5,923 $127,608 Dirac: Labor Expanses veil, be billed as specified in the Departmentof Labor Contract J-9-F-5-0035; Other Direct costs listed above will be billed as indicated. Additions Any Computer Services costs in excess of the mounfc stated in this'fcask Order will hot- ba aceepted by OSHA v/ithout priem vritten justiiieation frora RTI and approval by OSHA 141094 V Includes TUCC IBM 370/165 $600/hr. + $50 o :- s e (GA) + $66 fee 2 / Includes $2,500 purchase price 4* $250 OMASt (f,A) + $275 fee AIA WL 000041 y. !.* . V c _ r , .1 .-J \ reject Directe:: D.j. . L iSouri Scftiov Antiyst .. t-n2 i i o ji..aiyst D ri* J6 b.Hjtor. ln:1ys t M . . Ur iif'ht A UT KG ?.IZAT 10:7 p ir ?ar,suo.at to the provisions of the Department of ta for. :r:.s CT-9-F-0C2, this document constitutes a fully . ;rr.ar i s3u%>f r.! a r th state sjn t of wone'! th:a r'si h a;r,<?. therein s p a c i t o 5 ini defined. Vniiar the condition spa.ci-ri,ad rierair. chia Tas*< Ordir is ready for impi'sritati'piv, -- ?. Bell otri 'tirig Officer *s Ta clin le al r.&-: Sssiitat iva / Y .// # r Date / /> -: - /. (.) "tjo U ?.esearch Triangle Institute Data 141095 AIA WL 000042  i ! 141096 AIA WL 000043