Document j56M3N7gK4p7zJYyv3xepN12
FILE NAME Packings and Gaskets PAG
DATE 2003 Mar 14 DOC PAG049 DOCUMENT DESCRIPTION Letter to OSHA
08-24-2004 02:53
Director of Compliance Programs
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March , 2003
W
:
Ms. Cynthia Weaver Technical Support U.S. Dept. of Labor - OSHA - TS
230 S. Dearborn Street Room 3244
Chicago IL 60604
202-893-1881
9-84 P.002 | - 888
Boelter & Yates Inc.
Environmental Engineers & Scientists
RECEIVED
RECEIVED
MAR
MAR
2
2
2062
2062
Re Regulatory Opinion
.
Asbestos Regulations 2BCFR1910.26 G vi
Dear Ms. Weaver
UNI
aes
IF wyg
of In the course of our business we have been asked to look at the application 29CFR 1910.26
vi to gaskets and packings containing more than % asbestos and have Asbestos fibers modified by a bonding agent coating binder or other material
__
I conducted a search of the scientific literature and have conducted a study of gaskets and packings which was published in the November 2002 American Industrial Hygiene Association
Journal My article a copy of which is attached also critiques other literature on the subject
' My study correlates well with other competently conducted published and unpublished studies of
gaskets and packings The range of concentrations on a hour time weighted average TWA
for thefen tests of five activities documented total fiber release under worst case scenarios as follows
Industrial # - Flat blade scraping
Industrial 2 - Hand wire brushing
brushing Industrial $ - Power wire
Industrial # Making gaskets with a ball peen
hammer
Personal Personal Personal
# - Stem packing removal and replacement | Personal
Personal
Personal
# - Power wire Personal Maritime brushing
Maritime 9 Making
gaskets with a
ball peen | Personal Maritime 10 - Stem packing removal and
hammer Personal
replacement
=e
eRe
0.007
0.023
* | 0.052
0.027
0.010
0,004
0.010
0.029
0.010
| 0.021
!
0.038
f 0.024
0.014
0,000
0.008
0.022
0.008
Given these findings I would appreciate OSHA's opinion as to whether or not gaskets and
packings require labeling per 29CFR1910.26 vi
|
Sincerely
Frederick W. Boelter CIH PE 1300 Hladins Road Suite 301 Park Ridge Minois 60068-6772 - 647 | 692-4700 = 1ax 847 / 692-3127
08/24/2004 TUE 14:49 TX NO 9122 0002