Document jBd1Jrqavb6GYajR6dodbmO6O

PLAINTIFF'S EXHIBIT DUP-1599 CC: L. C. Schaller-Emp.Rel.-Wilm. D. J. Beatty-Central Res.-Exp. Sta. E. I. ou Pont de Nemours 51 Company J. E. Borden - Plastics - Victoria R. W. Calhoun - Tex. Fib. - Seaford J. T. Cavanuagh-Pigments-Edge Moor Wilmington. Delaware I98M F. H. Dineen - Elchem - Wilm. H. Lewis-Explos.-Carney's Pt. Dev.Lac W. T. Muncaster-Elaschem-Chambers WkE ENGINEERING DEPARTMENT P. A. Palmer - ESD W. S. Person - Orchem - Chambers Worr B. J. Stone - Design C. W. Van Ness-Photo Prod.-Towanda F. H. Whitaker - Design I. Zeise - Construction January 7, 1972 MEMORANDUM NO. 2 TO: D. G. WINDSOR - CHAIRMAN - EMP. REL. - WILMINGTON FROM: C. E. MARSH - STANDARDS SECTION STANDARDS SECTION - SAFETY & FIRE PROTECTION SUBCOMMITTEE S4T - MEASUREMENT AND CONTROL OF ASBESTOS DUST EXPOSURE. Our request to the Engineering Standards Committee for approval of the above standard has brought the following additional comments. s K. w. DAHL. COMMENT BY C. C. PRING - PLASTICS - SABINE RIVER WORKS \gOMMENT NO, OS - we would like to have suggested sampling equipment added /up the standard. G. S. REEDER. JR., COMMENTS BY W. 0. CHRISTY - EXPLQS. - SAVANNAH RIVER \Comment nO. 69 "-2.IT - Sampling fibers and particulates can differ. /^he battery-operated sampler approved for fiber sampling should be / specified to include millipore filter. COMMENT NO. 70 - 3*1*2 - Type of vacuum cleaner and filter should be / ''specified. Without high efficiency filters, this cleaning operation ^ Will filter out all particles and fibers, except those in the respirable fraction. VOMMENT NO. 71 - 3.1.3 - Type of respiratory protection should be ''specified. COMMENT NO. 72 - 3.1*4 - Glaze-coated insulation is satisfactory until the coating is penetrated by cutting blocks. MMENT NO. 73 - 3.1*5 - This operation can still produce dust in breathing Jnes" unless carefully controlled, perhaps a self-closing damper on the ute or flexible self-sealing slot. ^-txCOMMENT NO. 74 - 3*2.1 - Experience with cyclone collectors for asbestos `ndicates they are inefficient and in some instances cause atmospheric iQllution. DU 062091 DUP M 53863 4C13 11/8/71 2 January 7, 1972 MMENT NO. 75 - 3.2.2 - "An adequate exhaust system" should be defined. minimal exhaust rate per fan should be specified. Our experience showe _at, despite exhaust fans and no appearance of dustiness, the threshold ^imit value was still exceeded. Suitable protection is not defined. Con___^sideration should be given to exposure of other people in the work area. ~ --- - 2.3 - "Avoid Sweeping" - this should be a positive sFQMMENT NO. 77 - Air sampling will not control dust. Air samples ./should be taken to document the adequacy of controls. (3.2.4; /~'n0MMENT NO. 78 - 3*3*3 - Respiratory protective equipment should be osing of old asbestos cement. - 3*4.2 - Specify suitable respiratory protection. COMMENT NO. 80 - 3*4.4 - We have found no plant or governmental regu lations governing the disposal of asbestos. 'nQOILMENT NO. SI - 4.1 - This rule really says always wear respiratory protection when handling asbestos. Samples are sent away for analysis and results are known long after the fact - too long for corrective action. Comment NO. 82 - 4.1.2 - A reference to U. S. Bureau of Mines Schedule X21-B, Part 14, Subpart A, item 14*4, minimum efficiency 0.3 micron is needed. Several suppliers of respirators that meet this requirement are: Acme Protection Equipment Co, American Optical Company 1201 Kalamazoo Street Southbridge, Mass. South Haven, Michigan Mine Safety Equipment Co. Braddock, Thomas, and Mead Streets Pittsburgh, Pa. Recommend addition of: n and should be disinfected NO. 84 - 5*2 - Recommend addition of: "wear respirator when dusty clothing". (\0MKEI.T NO. 85 - 6.1 - Suggest clarification of this statement. Recommend addition of: "with a battery-powered personal air sampler." Suppliers of such samplers are: The Mine Safety Equipment Company and thd Union Industrial Equipment Company. CpM^NT NO. 86 - 6.1.1 - Evaluating a complete operation in this manner wi^l be very time consuming. Sampling with millipore (membrane) paper, orVits equivalent, usually is of short duration (10-15 min.) because of the\ high collection efficiency of this paper. Such a procedure, as de/soribed, might involve taking many samples for an eight-hour shift fpr each operation. At $15.00 per sample for analysis, the cost of this operation ill exceed the benefits, since the results of these /analyses are not known for some time and any reference to the TLV for DUP 1153864 DU 062092 iff*''--..-vi&z'' 5.L. 4013 11/8/71 * .3 - January 7, 1972 / that work period will be meaningless. Such a program of sampling could/be satisfactory provided the work conditions do not change. Respiratory protection must be required in all cases where the degree of exposure is unknown. C/W.KNT NO. 87 - 6.1.3 - Asbestos handling is now recognized as an extremely serious industrial hygiene problem. Analyzing asbestos samples rs /necessary. But the problems in sending samples several hundred miles by mail should be pointed out and the importance of correct handling emphasized. Some of the problems are: Transportation of samples may cause damage to the sample and possible loss of samplej delay in receiving results. This will, probably, be inevitable with laboratories receiving many svsh samples. Expensive as it may appear, the alternative may be to do local monitoring, use local laboratories, or to utilize the best engineering and personal protective measures available. A. PARMAN, COMMENT BY W. F. DOBBS - I & B - BELLE PLANT COMMENT No. 88 - 3.1.2 - Believe some exception should be made to this requirement permitting ''small" amounts of insulation to be removed without respiratory protection. Can a rule-of-thumb quantity be stipu lated which will not result in exposure to higher than permitted TLV? Can incidental removal of insulation not requiring over 5 to 10 minutes be excepted? Sixteen Engineering Standards Committee members advise an estimated total of 245 uses for this standard as reference per year. kjk DUP HS386s DU 062093