Document j13omqVX5zQz9x741RZGRj0y

FILE NAME: Ford (FD) DATE: 1973 Apr 11 DOC#: FD057 DOCUMENT DESCRIPTION: Memo with OSHA Asbestos Directive Attached PLAINTIFF'S EXHIBIT Bettor Offloa -, ; ; O m ini Parts Division Satina Piani April U s 1973 T. V. Mdtauaoo, M. . Subject: Asbesto* K a fu to e t: % previous m w n t e i t lo u o f 11- 20- 72, 1*3-73 and 1-10*73 sod lad o atr i a l Hygiene rap o rt by B. Lick o f 3- 16-73 la tb a b o n referenced eonaunlcatlons, th a O.S.H.A. r a q u lr ia n t fo r parfo ralq g parlod&c aad lea l ok--I nation a discussed. I t la wj understandlog fro * a conversa tio n w ith yoo on January 13 1973 th at par L. Teach, Or. Block t r i l l r s corasand a t sona fa ta r d ata what taat a ra to ba given aad v lU alno nana tb a aqulpaant necessary to parlor* tbaaa taata* 1 bava attached a copy o f a progra* d lra c tlv a u b id appeared la tb a A pril Ss 1973 Bureau o f M attonai A ffair* . Since ve aov know th a t a t le a st one parson baa been aopoaad la excess o f allow able 1la tta * I an o f tb a opinion . th a t tea eould ba c ite d . I would Ilk a to i to detersine tbs l ST* ; th a t you contact Or. Block ones again In an e ffo rt fo r S aline S lan t to comply w ith th is portion o f the P t\) J . . Hood* ce J. f. MeCalloa y Asbestos fll ri ' "C ? * i & & * ?* .* ,* ; ... * ' 8008 0047 O O A T M T /'cn tavr c - A n n 8009 0048 CURRENT REPORT * Medical aurveBlanc* would be required when the daily noise doae exceed* 80 percent o f the environmental limit. ' The OSHA document would limit the daily noiie doae to 9 0 dBA, but five y eajrafter the effective date o f the standard, the limit would be lowered to 85 dBA unless unequivocal evidence is developed to show that the lower level would not result in reduced hearing impairments. Other differences existed between the two documents with respect to certification o f audiometric technicians, and changes in the formulae for determining the attenua tion characteristics of ear protectors. Environmental lim it The existing OSHA noise standard o f 90 dBA time weighted average for an eight-hour day should be retain ed, Hill a id . He described a program conducted by duPont which included hearing conservation measures and regular audiometric testing. During the entire program, testing riiowed no evidence o f hearing Io n among employ ees expoied to noise levels below 90 dBA, HU said. Dr. HOdyard presented a aeries o f dem ents that he considered riiould be included in any noise standard. Environmental limits o f occupational exposure to noise should be set and wearing o f ear protection riiould be compulsory wherever the limit is exceeded, he said. Node levels which exceed the limit should be reduced by engineering procedures where posribie. Periodic monitor ing of the workplace ought to be required dong with preemployment and follow-up audiometric testing with recordkeeping. Employees riiould be educated in die proper use of personal protective equipment and in die recognition of rymptoms of overexposure to noise. Both employers and employees riiould be disciplined for figure to comply with die standard. Warning rip riiould be required for those areas which exceed die standard. Dr. Hildyard said. The existing standard knowingly allows eight to 20 percent o f the noise exposed population to suffer some hearing loss, Dr. Van Atta told the committee. While this is not a good standard, a large segment o f industry cannot meet even this minimum, and an environmental limit of 85 dBA still would permit a hearing lost to affect 4 to 5 percent o f the noise exposed population, he said. The committee should consider this* things in developing an environmental lim ite d .V ',5 , 1. C o n se m tk . o f Iw ariM (whoa* and by how much). 2. The practical'paaaibfllq^o( meeting the environ mental lim it 5. H it ccooomfc im pact o f A r lim it on industry. Other Buriweie Some 20 written comments were received by the committee and Wold suggested that these be digested or summarized for use by the committee members. Some members objected, preferring to review each comment in its entirety, and the suggestion was dropped. The committee also requested diet OSHA provide date concerning the number o f citations issued for alleged vicSatica o f the current noise standard. OSHA agreed to do this and oho win include the average size o f the establishments cited for alleged violations and the decibel levels found. 127S The next meetings of die advisory committee an scheduled for May 9-10 and May 30-31. Both meeting! wfll be held in Washington, D.C. The main business at the first meeting will be carried on by the subgroups Written comments may be filed for the committee*! consideration by sending 20 copies to OSHA Office o! Standards, Railway Labor Building. 400 First St. N.W. Room 509, Washington, D.C. 20210 ' Program Directly ^ OSHA DIRECTIVE SPECIFIES EMPLOYERS MUST OFFER ASBESTOS RULE EXAMINATIONS Employers who make a good faith offer to provide ot make available, at cost to the employer, the medical examination for employees as required in the asbestos standard, are in compliance with the standard according to Occupational Safety and Health Administration Pro gram Directive 200-17 issued on March 16. The directive is concerned with the medical examina tion requirements o f 1910.93a and supplements the Com pliance Operations Manual with special emphasis on Chap lets IV, V, VIII, and XIII, and OSHA Program Directive 72-1 and 20 0 4 . The standard requires and employer to provide ormake available at cost to the employer, medical examinations to employees engaged in occupations exposed to airborne concentrations o f asbestos fibers. Employees are not required to take the examinations. If an employee refuses to take the examination, it riiould be determined if the employer made a good faith offer. If the employer has demonstrated good faith, he is in compliance with the regulations. An appropriate statement o f refusal should be kept by the employer as a record under 1910.93a (jX6). A written form signed by the employee, to the effect that he will not take a physical examination, would be such an appropriate statement. Program Directiva ~ OSHA DIRECTS INSPECTORS TO USE ONLY NIOSH CERTIFIED DETECTOR TUBES Compliance officers were directed to use only detector tubes which come from a batch certified by the National Institute for Occupational Safety and Health, in Occupa tional Safety and Health Administration Program Direc tive 7 3 4 issued on March 12. The directive was issued to provide OSHA supervisory stalT and field petsonnel with guidelines for the use of detector tubes in the assessment o f hazardous at mospheres. Length o f stain detector tubes have been issued for determination o f HS, SO, 0 , and CO*. OSHA specifi cations require that the tubes be tested at one-half, one, two. and four times the Threriiold Limit Value (TLV) and show an accuracy o f 3S percent in the lower ranges and 25 percent in die higher ranges with about 85 percent probability o f being within these ranges. NIOSH has a project to certify detector tubes as being Copyright e 1973 by Tb* Bv w m 1 Affair, Inc.