Document jB0mVVvavw1Yaewe834pBNqa9
FRICTION MATERIALS STANDARDS INSTITUTE, ESC.
Asbestos Exposure and Medical Examinations
flatter of employers providing nedical surveillance pro gram as set forth in OSHA asbestos standard for occupa tional exposure to asbestos dust has been an unsettled subject for several months (N s N Feb.). At issue has been lack of clarification of the term "...exposed to airborne concentrations of asbestos fiber..." as it re lates to requirement for medical examinations.
Both U.S. Court of Appeals for District of Columbia and Occupational Safety and Health Review Commission have ruled that current asbestos standard requires such ex aminations be provided employees exposed to airborne asbestos in any measurable concentration. These deci sions related to a Jan. 1977 policy letter from OSHA to an individual employer which stated medical examinations would be required only when employee exposures to air
borne asbestos exceed 0.1 f/cc. A three-member OSHA panel was designated by Asst. Secretary of Labor (OSHA) Eula Bingham to study problem. AIA/NA requested OSHA in Mar. 1978 to provide workable and reasonable inter pretation at earliest possible date.
On. Oct. l'J,1978, OSHA issued Program Directive #300-16 to its regional administrators providing uniform in spection and compliance procedures for medical exam ination requirements of the asbestos standard. Princi pal actions in this directive are:
. The term "exposed to airborne concentrations
of asbestos fiber.." is administratively inter
preted to mean "exposed to a minimum cf 0.1
asbestos fibers larger than 5 micrometers per
cubic centimeter of air..."
,
. Medical examinations will be required for any 7 to 8-hour time-weighted average concentration of 0.1 f/cc, or for a greater concentration.
An OSHA spokesman has advised that, agency's Oct. 11 direc tive is considered internal policy and, further,directive does not amend the asbestos standard, but rather provides an administrative interpretation of the. standard for' use by compliance officers.
Reprinted from Asbestos Information Association News and Notes of 31 October 1978
FMSI 03456
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