Document jgZk7qo25qz4rG1VX4XGXbwN5

INTERNAL CORRESPONDENCE MINING AND METALS DIVISION To (Namt) Division Location Messrs. R. E. Byrne, Jr. J. V. Murray J. L. Myers W. C. Thurber-^ Copy to File P. 0. BOX 579, NIAGARA FALLS, NEW YORK 14301 Data Originating Dopt. An*wring latter data February 4, 1975 "Calidria" Asbestos Subject "Calidria" Asbestos Health and 0SHA Information February 1, 1975 The final version of the above information package for J&=2M and RG-600 are attached. We expect to be revising this periodically as more information becomes available. Any comments or suggestions on how it may be improved will be welcome. HBR:cjb Attachments H. B, Rhodes UCC 001704 "CALIDRIA11 ASBESTOS HEALTH AND OSHA INFORMATION February 1, 1975 Union Carbide Corporation Mining and Metals Division "Calidria" Asbestos Marketing and Technology Department Niagara Falls, New York UCC 001705 INTRODUCTION The Williams-Steiger Occupational Safety and Health Act was passed in 1970 with the stated objective of assuring every American worker a safe and healthy workplace. The first health standard promulgated under this act covered exposures to airborne asbestos and went into effect on June 7, 1972. This asbestos standard survived a broadside legal attack filed by the IUD and is now being revised by OSHA to clear up certain ambiguities. The revised version is expected about midyear 1975. Asbestos has received a great deal of attention and publicity in the last several years. Unfortunately, much of the media treatment of the subject has been emotionally oriented and distorted and, in some cases, bordering on the sensational and untrue. Many users of asbestos and products containing asbestos have been mislead regarding the safety of asbestos and what is needed to comply with the OSHA requirements. The information presented in this folder has been collected as a service to "Calidria" asbestos users. It is intended to help put both the health and OSHA compliance questions in a reasonable perspective. Included are: 1. A sumnary of the main provisions of the OSHA Asbestos Standard and a copy of the regulations. - 2. Airborne asbestos fiber count data obtained by Union Carbide at a variety of industrial locations during the blending of RG-244 into polyester resin, the spraying of the asbestos containing resin, and the sanding and grinding of the finished parts. 3. Two pamphlets, "What Every Employee Should Know About Asbestos" and "Asbestos and Health" published by the Asbestos Information Association/North America. The first is an employee oriented discussion of both health and OSHA while the second addresses the health question. Additional copies are available on request. 4. A Material Safety Data sheet and analytical data on "Calidria" asbestos. OSHA REGULATIONS Introduction After extensive public hearings, a standard for Exposure to Asbestos Dust was published in the Federal Register, Volume 37, No. 110 on Wednesday, June 7, 1972. A copy of this standard is included with the literature at the back of this booklet. Basically, the standard can be divided into the following five major categories: 1. Standards: Defines the allowable airborne asbestos fiber content in the workplace. UCC 001706 2- - 2. Monitoring: Defines the method of collecting samples and measuring the airborne fiber concentration. 3. Methods of Compliance: Defines acceptable procedures to met the allowable limits. 4. Medical: Specifies frequency and type of medical examinations required. 5. Warning Signs and Labeling: Specifies when warnings are necessary and the wording of such warnings. The essential features of these categories are discussed in the remainder of this section. Before looking at these, however, it should be made clear that in the most basic sense the regulations require that every place of employment where asbestos is used must be monitored to determine the exposure level of airborne asbestos fibers. 21 the levels are well within the allowable limits, the only additional requirements are those relating to medical examina tions. If the levels are not clearly within compliance, all provisions of the regulations apply. There has been a great deal of confusion on this distinction, occasionally even with OSHA field inspectors. Standards The present OSHA standards set a maximum exposure to airborne asbestos fiber of length longer that 5p of: 1. An 8-hour, time-weighted average (TWA) of 5 fibers/cc. 2. A ceiling concentration of 10 fibers/cc. On July 1, 1976, the allowable TWA is reduced to 2 fibers/cc. The ceiling concentration remains unchanged. Note particularly the use of the time-weighted average over the 8hour shift. An operator performing one or two short additions of RG-244 per shift, as is typical of polyester producers, would have his exposure during the dumping time averaged with zero (or a very low background level) for the rest of the shift. This, obviously, tends to greatly reduce the 8-hour TWA. Monitoring The regulations require an initial monitoring to determine whether the workplace meets the required levels. Thus: "Within six months of publication of the regulations (June 7, 1972), every employer shall cause every place of employment where asbestos fibers are released to be monitored in such a way as to determine where every employee's exposure to asbestos fibers is below the prescribed limits." UCC 001707 -3- Monitorying usually is done by the membrane filter/personal air sampler, which can be obtained from a number of manufacturers. The personal air sampler draws workplace air onto a filter which collects the particulates and fibrous dust in the air. This filter is then placed under a microscope and the number of fibers counted. After the count is complete, the actual fiber concentrations, expressed as fibers per cubic centimeter of air, are calculated by formula. After the initial monitoring, the regulations state: "...samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of employees. In no case shall the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph (b) of this section?11 The section that has been underlined shows that if the initial monitoring give levels that are well below the allowable limits and no change is made in the method of operation which would increase dust levels, no further monitoring is required. It is a good and recommended practice, however, to monitor at regular intervals to make sure that the limits are being met. - It should also be understood that you cannot be cited legally for exceeding the allowable limits on the basis of your own monitoring. OSHA must base any citations issued on theTr own tests. Methods of Compliance ^ monitoring shows a_ plant or operation to be iji excess of the limits, a number of ways are prescribed to bring it into compliance. These include, but are not limited to, engineering controls such as isolation, enclosure, exhaust ventilation, and dust collection. Certain work and housekeeping practices and waste disposal procedures are specified. Respirators, special clothing, and change rooms are also required under certain conditions. It is most important to understand that these compliance procedures are required only if the allowable airborne asbestos fiber limits are being exceeded or can be expected to be exceeded under reasonably foreseeable circumstances. They are not automatic requirements that apply wherever asbestos is present. Medical Examinations Preplacement, annual, and termination medical examinations must be provided or made available by the employer for any employee "...engaged in occupations exposed to airborne concentrations of asbestos fibers." These medical records must be kept for 20 years and are available to the employee's physician. This section has proved to be one of the most confusing in the regulations since it does not define any cutoff level below which examinations are not required. OSHA has declined to provide any official clarification but reports from plants that have been inspected indicate that they are generally taking the very reasonable approach of requiring examinations for employees who regularly handle asbestos, who are regularly in the area where UCC 001708 -4- asbestos is being handled, and for maintenance personnel who work on asbestos handling equipment. It is anticipated that the revised regulations will provide a more specific definition such as that originally proposed by NIOSH in the Criteria Document: "For purposes of this requirement the term 'exposed to asbestos1 will be interpreted as referring to time-weighted average exposures above 1 fiber/cc or peak exposures above 5 fibers/cc." Caution Signs and Labeling The regulations require that: "Caution signs shall be provided and displayed at each location where airborne concentrations of asbestos fibers may be in excess of the exposure limits prescribed in paragraph (b) of tFis section." Wording for the signs is also specified. There have been some cases where the OSHA inspectors have taken this to mean signs are required at any location where asbestos is present, regardless of whether or not the exposure limits are exceeded. Although this is clearly, incorrect, there has been a tendency to post the signs and not contest the = citation. The regulations also require that: "Caution labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos TTbers in excess of the exposure limits prescribed in paragraph (b) of this section will be released." Wording for these labels is also specified. AIRBORNE ASBESTOS FIBER COUNTS Introduction This section presents air sampling data obtained in a variety of situations, mostly for typical industrial operations. All samples were collected on Millipore filters and counted at 400X with phase contrast illumination in accordance with OSHA procedures. Particles which satisfied the L/D >3 criteria but which, in the judgment of an experienced counter, could not possibly be asbestos were not included in the counts. UCC 001709 -5- Presentation of Data Table I shows "Calidria" asbestos RG-244 fiber counts obtained at 8 different polyester manufacturing plants. Typically, several hundred pounds of RG-244 are dumped into the thin tank in a 10-25 minute period. These samples obtained during the dumping operation thus represent ceiling concen trations. They would normally be averaged with considerably lower numbers for the remainder of the shift when asbestos is not being handled to arrive at the TWA. The highest fiber count found at these eight locations was 2.8 fibers/cc which is well below the allowable limit of 10 fibers/cc. Table II shows the fiber counts at three of the same manufacturing locations at the empty bag collection point. These values are also quite low. Table III shows airborne fiber counts for "small-scale" addition of RG-244 as occurs in a variety of compounding operations. The levels found ranged from 0.4 to 2 fibers/cc. Table IV shows the airborne asbestos fiber count data obtained during the spraying of a variety of asbestos containing resins. Much of the data are for polyester resins, but epoxies and alkyds are also included. The asbestos content of the resins ranged from 0 to 12% by weight. The highest count obtained was 0.6 fiber/cc. - Polyester resin parts are often finished by sanding or grinding. Table V shows the airborne asbestos fiber counts obtained during a number of industrial finishing operations on resins with up ^^3% asbestos. The highest reading obtained here was 0.4 fiber/cc. Table VI gives the results for a laboratory study where resin plaques containing a variety of fillers were abraided with an electric hand grinder in a small closed room. Even under these extreme conditions, the fiber counts were quite low with 1.2 fibers/cc, the highest observed. UCC 001710 TABLE I AIRBORNE ASBESTOS FIBER COUNTS*1*"LARGE-SCALE" DUMPING OF RG-244 (*100-450 lb./Batch) Plant A B C D E F G H Data Reference -- 1929-46-2 1929-30-2 1929-56-1 1929-50-3 1929-26-3 1929-24-2 1929-16-1 Description of Operation Oump Sample Bags Time Time Dumped (Min.) (Min.) Special Ventilation(2) 10 10 10 None 14 9 9 None 15 21 21 Hood over thin tank opening 36 12 12 None 15 8 8 None 45 20 20 None 10 24 24 Hood over mixing area 28 15 15 None CEILING Concentration Fiber Count (Fibers/cc. >5^) 0.7 1.2 0.7 2.4 0.5 1.6 0.8 2.8 - ^All samples collected in the breathing zone of the operator dumping the RG-244. ^Special ventilation refers to dust collection equipment at or near the dumping area that is specifically intended for dust control during the dumping operation. All plants had varying measures of overall building ventilation. TABLE II Plant A B B Data Reference -- 1929-40-3 1929-40-5 AIRBORNE ASBESTOS FIBER COUNTS EMPTY BAG REMOVAL Description of Operation Sample taken 3 feet above waste disposal drum for empty bags. (During dumping.) Directly over empty bag stacking area. Taken during dump. Empty bag storage area. Taken during dump as bags were put in. Sample Time (Min.) 10 23 24 Fiber Count (Fibers/cc. >5<-) 0.4 0.6 0.4 UCC 001711 TABLE III AIRBORNE ASBESTOS FIBER COUNTS^ ^ "SMALL-SCALE" DUMPING OF RG-244 (1-12 lbs./Batch) End Use Furniture Molding II II II II II II Pounds Dumped 1 12 1 6 Dump Time (Min.) 10 2.5 11 8 Sample Time (Min.) 10 2.5 11 8 Special Ventilation'*^ None None None Good Hood Ceiling Concentrati Fiber Count Fibers/cc >5y 1.5 1.1 2.0 0.9 - GIeI l CIoI at MIIfg. 9 25 25 333 None None 0.7 1.2 ArtifiIIcial BrIiIck MIIfg. 5 1.5 4 10 4 10 Good Hood 0.9 0.4 Roof Coating Mfg. 12 13 13 None 1.1 ^ All samples collected in the breathing zone of the operator dumping the RG-244. (21 ' ' Special ventilation refers to dust collection equipment at or near the dumping area that is specifically intended for dust control during the dumping operation. All plants had varying measures of overall building ventilation. UCC 001712 AIRBORNE ASBESTOS FIBER COUNTS - SPRAYING OF RESIN BASED SYSTEMS CONTAINING ASBESTOS Suple Dtslanitlon Commercial Application Date I POLYESTER RESINS A. General Purpose Laminating Resins 69 Boat manufacture. 12/7/72 Binder General purpose laminating resin. L--13 10/31/74 ft N-28 N-30 m II * N-34 N-4n ME 10/8/74 ft ft ft m m Approx-^ Imate Wt. 1 Asbestos Sorav Gun Type Operation Sample Time (Win.) Airborne Asbestos Fiber Concentration (Flbers/cc >5.* 0.5 Air-supported Operator spraying chopper. molds with resin 1 chopped glass. 24 0.5 0.5 4* 0.5 ft ft 0.5 0.5 0.5 Operator spraying resin 1 chopped fiber glass. (Includes roll-out time.) Operator spraying resin 6 chopped fiber glass. Operator spraying resin 6 chopped fiber glass. Operator spraying" mold with resin. (No glass.) 16 5 4 55 53 35 0.6 0.1 0.4 0.4 0 0.03 0.1 8. Chemical Resistant Resins J-21 Fiber-glass pipe manufacture. 8/13/74 H-26 Chemical resistant resin. IP 1.4 Airless. 1.4 Operator adjacent to automatic spray machine coating 28' mandrels. Operator wiping mandrels. In area near spraying. 23 0.1 14 0.4 J-5 Ship coating. 10/3/74 Chemlcal 0.7 Air-supported Roll-out man. In 55 0.4 resistant wand. spraying area about resin + chopped 1/4 of time. fiber glass. J-7 m ft 0.7 ft Operator spraying 41 0.4 ship hull In dry dock. H-23 nm 0.7 H H 23 0 0) Based on total formulation as sprayed. UCC 001713 TABLE IV (continued) AIRBORNE ASBESTOS FIBFH COUNTS spraying of resin based ststehs containing asbestos Senile Daslonatfon Conntrcfj) Aooltcatlort II - EPOXT resixs A. Filled Epoxy K-8 Ship coating. K-10 K*10 II ' n 1-27 J-l Date 10/2/74 Binder Approx-^ Imate Wt. 1 Asbestos Sorav (Sun Type Epoxy primer. H High build epoxy. 0 P 1.5 Airless. 1.5 0 Air supported* 0m 0m Operation Operator spraying outside 1 under a Ship. a Operator spraying side of ship from scaffold. R a Sample Time (Hln.l Airborne Asbeitos Fiber Concentration IFIbers/cc 5,J 33 8 31 . 14 60 0.2 0.2 O.l 0.3 0.03 B. Eooxv - Coal Tar H-45 Coating dry dock. 10/1/74 K-l a a K-3 Coating pipe Interiors. Epoxy Coal-tar, solvent. R 1 1 1 III - ALKYD RESIN PAINT H-7 Painting 10/6/74 building exterlon N-35 1* Alkyd resin. 12 12 Airless. a Air-supported wand. Operator spraying side of dry dock from suspended platform. Operator spraying side of dry dock from fixed scaffold. Operator spraying interior of 3", 6* and 12" diameter pipe. Airless gun. a Operator spraying building exterior wall. a -= 11 0.2 38 0 37 0.1 90 5 0.06 (I) Based on total formulation as sprayed. UCC 001714 TABLE Y AIRBORNE ASBESTOS FIBER COUNTS GRIMING AMD SANDING OF RESIN-BASED SYSTEMS CONTAINING ASBESTOS Saavle Designation Connercltl Application I. THERM05ET RESIN (Polyester) -- Holding furniture parts * Date 3/15/72 Resin Polyester II 1929-40-4 " 12/6/72 k 1929-82-3 1929-82-4 1929-82-5 1-13 1-6 Fabrication of reinforced fiber glass pipe. a N a 2/27/73 Polyester a 8/13/74 a a a a 1-26 G-8 1-39 Fabrication of FRP tanks and pipe. M a 8/13/74 a m Polyester a a 1929-84-4 1929-84-5 Production of artificial bricks. N-20 N-2S Production of fiber glass boats. a 3/8/73 Polyester a 11/26/74 Polyester a Asbestos Approx. Type Wt. X Operation Sample Time jHtJLi Airborne Astestos Fiber Concentration IFIbers/cc >ix) RG-244 0.05 0.05 * 0.3 RG-144 2-3 a a RG-244 2-3 2-3 1.4 a 1.4 RG-244 a 1.5 1.5 1.5 RG-244 a 2.0 2.0 Operator hand sanding small parts. Operator running power sender with Integral hood. Operator sanding and irindlng molded parts, lood hood 1 ventilating system on grinder. 45 45 23 Operator pulls pipe along line. Saws off end with circular saw. 19 Same operation as 192982-3. 49 Operator removing end of 45 pipe with scarfing machine. Operator shaping end of pipe with bell 1 spigot machine. Operator cutting off pipe end and light grinding on exterior surface. 16 17 Operator grinding Inside of 13' 1.0. x 26' tank. Continuation of same operation as 1-26. Operator grinding edges of miscellaneous small parts. 16 5 25 Operator cutting with sabre saw. Operator trliming with sabre saw. 44 39 RG-244 a 0.5 0.5 Operator grinding Inside of boat hull. 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V, UCC 001731 ' v. < ,, , 1 L'i'? **Uv"f> . * * 3ffv ^ 22 . 40th Street New York, New York 10016 (212) 689-3378 RULES AND REGULATIONS Title 29--LABOR Chapter XVII--Occupational Safety and Health Administration, Depart ment of Labor PART 19T0--OCCUPATIONAL SAFETY AND HEALTH STANDARDS Standard for Exposure to Asbestos Dust On December 7, 1971, an emergency temporary standard concerning exposure to asbestos fibers was published in the Federal Register (36 F.R. 23207). In ac cordance with section 6(c)(3) of the Williams-Steiger Occuptaional Safety and Health Act of 1970, a notice of proposed rulemaking regarding a permanent standard for exposure to asbestos fibers was published in the Federal Register on January 12, 1972 (37 F.R, 466). The no tice invited interested persons to submit both orally and in writing, data, views, and arguments concerning the proposal. On or about January 24.1972, the Ad visory Committee on Asbestos Dust was established and requested to make writ ten recommendations with regard to the proposed standard on asbestos. On or about February 1, 1972, the Department of Health, Education, and Welfare trans mitted to the Secretary of Labor a cri teria document containing Recommenda tions for an Occupational Exposure exposure to asbestos fibers and the ap Standard for Asbestos by the National pearance of adverse biological manifes Institute for Occupational Safety and tations, such as asbestosis, lung cancers, Health (NIOSH). Public notice was given and mesothelioma, have given rise to of the receipt of the recommendations controversy as to the validity of the and their availability for inspection and measuring techniques used and the relia copying. On or about February 25, 1972, bility of the relations attempted to be the Advisory Committee on Asbestos Dust established. Because of the long lapse submitted its written recommendations of time between onset of exposure and to the Assistant Secretary of Labor for biological manifestations, we have now Occupational Safety and Health. evidence of the consequences of exposure, Pursuant to the notice of rule making, but we do not have, in general, accurate a hearing was held on March 14 through measures of the levels of exposure oc 17, 1972, for the purpose of receiving oral curring 20 or 30 years ago, which have data, views, and arguments concerning given rise to these consequences. There the proposed standard. On or about are also controversies concerning the March 31,1972, the presiding hearing ex relative toxicity of the various kinds of aminer certified to the Assistant Secre asbestos, and varying hazards in dif tary of Labor for Occupational Safety ferent workplaces. and Health the record of the proceeding. It is fair to say that the controversy The record Includes prehearing written has centered in the area between a two- comments, a transcript of the oral pres fiber TWA concentration and five-fiber entations made at the hearing, and nu TWA concentration, with variations on merous exhibits received during the the time needed for compliance. Many course of the hearing or within the pe employers support a five-fiber TWA. riod allowed after the close of the Most medical opinion is divided between hearing. a two-fiber standard and a five-fiber The proposed standard dealt with (1) standard. permissible concentrations of asbestos In view of the undisputed grave con fibers; (2) methods of compliance; (3) sequences from exposure to asbestos warning signs; (4) monitoring; (5) med fibers, it is essential that the exposure be ical examinations; and (6) recordkeep regulated now, on the basis of the best ing. Each of these major proposals elic evidence available now, even though it ited comments, arguments, objections, may not be as good as scientifically de and counterproposals. They all have been sirable. An asbestos standard care be re examined and considered. evaluated in the light of the results of 1. Acceptable concentrations of asbes ongoing studies, and future studies, but tos dust. The proposed standard would cannot wait for them. Lives of employees limit occupational exposure to 8-hour are at stake. time-weighted average (TWA) airborne It is concluded that there should be concentrations of asbestos dust not ex ceeding five fibers longer than five micrometers per milliliter. Concentra tions above five fibers but not to exceed one minimum standard of exposure to asbestos applicable to all workplaces ex posed to any kind, or mixture of kinds, of asbestos. Reasons of practical ad 10 fibers (ceiling concentration) would ministration preclude a variety of stand be permitted up to 15 minutes in an hour, ards for different kinds of asbestos and but for not more than 5 hours in any one of workplaces. Also, while the evidence 8-hour day. tends to show that crocidolite, for in NIOSH in effect has recommended stance, is more harmful than chrysotile, that the five-fiber TWA and 10-flber the evidence is not sufficient to establish peak concentrations be permitted only separate standards for varieties of for 2 years; thereafter, TWA concentra asbestos. tions should be not more than 2 fibers Because there must be one standard per cubic centimeter (cm.3) of air, and governing exposure to all varieties of peak concentrations should not exceed 10 asbestos, and in workplaces apparently fibers/cm.3, with no time restriction. more hazardous than others; because Numerous objections and counterpro some present employees with regular ex posals have been made, with regard to posure to asbestos have probably al both the limits of asbestos fiber concen ready accumulated great doses of asbes trations and the time periods to comply with them. Some, for example, have rec ommended return to a 12-fiber standard of an earlier day; i.e., a level adopted under the Walsh-Healey Public Con tos fibers, due to higher levels of ex posure in the past; because it appears that levels of exposure which may be safe with regard to asbestosis are not safe with regard to mesothelioma: be tracts Act in 1969. Others have recom cause the statute requires the protection mended a two-fiber standard to become of every employee, even of one who may effective in 6 months, then a one-fiber have regular exposure to asbestos during standard for 2 years, and finally a zerofiber standard after 3 years. These rec ommendations give a fair indication of the wide spread of the counterproposals. a working life which may reach, or even exceed, 40 years; and because of several other considerations which have been urged and are reflected in the record of No one has disputed that exposure to the proceeding, the conflict in the medi asbestos of high enough intensity and cal evidence is resolved in favor of the long enough duration is causally related health of employees. As of July 1, 1976, to asbestosis and cancers. The dispute is TWA concentrations of asbestos fibers as to the determination of a specific level longer than 5 micrometers will not be below which exposure is safe. Various allowed to exceed two flbers/cc., with a studies attempting to establish quantita ceiling value of 10 flbers/cc. The current tive relations between specific levels of TWA concentrations of five fibers, and FEDERAL REGISTER, VOL. 37, NO. 110--WEDNESDAY, JUNE 7, 1972 UCC 001732 RULES AND REGULATIONS 11319 celling concentrations of 10 flbers/cc, fibers, so that these would not be released 6. Records. The standard, as proposed will be permitted until July 1, 1970, dur in the normal use of the products, should and as adopted, requires maintenance of ing what will be a transitional period not be required to be labeled; and (2> records of monitoring and of medical deemed necessary to allow employers to words such as "danger" and "cancer" are examinations. Most of the controversy In make the needed changes for coming unwarrantedly alarming. this area has revolved around the ques into compliance with the more stringent Both contentions have merit, and the tion whether an employer should be al standard. standard has been changed accordingly. lowed to have access to the results of The record shows that the many work 4. Monitoring. The proposed standard the required medical examinations. The operations subject to the single asbestos would have required personal monitor apprehension of those who have argued standard (textile, manufacturing, indus ing and environmental monitoring. against employer access is based on the trial, and marine installation, etc.) will Many issues have been raised concerning expectation that some employers will use meet varying degrees of difficulty In the availability and reliability of meas the medical examinations as a means of complying with the standard. In some uring instruments, frequency of moni screening employment applicants, and plants, extensive redesign and reloca toring, and conditions In which monitor worse, as grounds for discharging current tion of equipment may be needed. It ap ing should be required. The adopted employees, who show signs of being af pears, however, the delay in the effective standard takes the objections into con fected by exposure to asbestos. Since the date of the two-fiber standard will pro sideration. It requires periodic monitor purpose of the medical examinations is vide all employers a reasonable time to ing at intervals no longer than 8 months, to monitor the health of employees ex comply. At the same time, so long as the thus allowing considerable time and dis posed to the hazards of abestos, em celling limit is complied with, no harm cretion, and prescribes the use of the ployees cannot in reason be granted the is reasonably expected to result from ex membrane filter method, which is an ac privilege of refusing to disclose to their posures during the transitional period. ceptable method for determination of employers results of occupational expo 2. Methods of compliance. It has been asbestos fibers. sure. It does not make sense to require pointed out by many persons, that pro It has also been recommended that employers to provide medical examina tection against asbestos fibers is best employees or their representatives should tions if they cannot know and use the obtained by controlling the generation of have an opportunity to observe the results of the examinations. For these fibers first, and secondly, by controlling monitoring. The recommendation has reasons the standard provides that em the dispersion of released fibers into the ambient air of the workplaces. Therefore, the standard requires feasible techno logical controls and appropriate work practices as the primary means of com pliance. Rotation of employees as a way of meeting the TWA concentration re quirement is allowed only In stated ex ceptional circumstances, because, as a general rule, it would be difficult to Im plement, Personal protective equipment, such as respirators, cannot be relied upon because, among other reasons, they may be so uncomfortable as to be bur densome, except for short periods of time. Therefore, it is expected that res pirators and shift rotation will be used during the period necessary to install en gineering controls and to train employ ees in sound work practices, but, after technological compliance has been achieved, their use must be limited to special work situations and emergencies. Where both are practicable, shift rota tion is required. 3. Labeling. The proposed standard stopped short of requiring labeling as bestos and asbestos-containing products. The proposed standard would have re been accepted. 5. Medical examinations. The pro posed standard would only require an appropriate medical examination on a periodic basis. The generality of the pro posal has attracted many objections and also many helpful comments. The recom mendations of NIOSH and of the Advi sory Committee on Asbestos Dust were much more specific with respect to both frequency and type of medical examina tions to be required. The comments vary as to the class of employees to be ex amined and as to the frequency of the examinations. The adopted standard requires medical examinations both at the beginning and the termination of employments exposed to concentrations of asbestos fibers, and also requires annual medical examina tions of every employee exposed to air borne concentrations of asbestos. It has been pointed out that In certain indus tries, such as construction, an employee may work for several employers during the same year. Accordingly, the standard does not require either preemployment, or termination, or periodic examinaton of any employee who has been examined ployers may have a restricted access to some medical information. On the other hand, there is no Inten tion to allow employers to abuse medical Information obtained pursuant to the Act, to the detriment of employees. Therefore, the administration of the medical records requirement will be closely watched, and, in cases of abuse, appropriate action will be considered. The Issues discussed above are believed to be the major ones. Numerous other is sues have been raised in the rulemaking proceedings. Some have been referred to incidentally. Many recommendations, for instance, about work practices, are so obviously meritorious that their adop tion needs no exposition here. Other recommendations and many objections have not been adopted for a variety of reasons which should be manifest. Sev eral, for Instance, have recommended the use of respirators only pursuant to a variance, or in cases of emergency and occasional short-term exposures. The recommendation with respect to vari ances undoubtedly has many merits, but is considered administratively im quired only warning signs at locations in accordance with the standard within practical. where asbestos hazards are present. the past year. Accordingly, after consideration of the However, labeling, rather than warning signs, has proved to be a point of con troversy. Both NIOSH and the Advisory Committee on Asbestos Dust recom mended labels for asbestos products and One question which has been raised goes to whether the employer or the em ployee should be allowed to choose the examining physician. The standard gives the option to the employer. Since whole record of the proceeding, and pursuant to sections 6 (b> and (c) and 8(c) of the WUllams-Steiger Occupa tional Safety and Health Act of 1970 (84 containers, and these recommendations some employers already have a medical Stat. 1593, 1596, 1599; 29 UH.C. 655, became very controversial in the course of the proceeding. Many counterpro proposals have been made as to the lan guage of the warning as well as to the products to be subject to the labeling requirements. Employers, in general, examination program in operation, and, also, have medical departments with some expertise in the diagnosis of abestoe-related diseases, it seems more reasonable to permit them to utilize the present programs and expertise, than to 657), 29 CFR 1910.4, and to Secretary of Labor's Order No, 12-71 (38 FJR. 8754), Fart 1910 of Title 29 of the Code of Fed eral Regulations is amended as set forth below. strongly contend that (1) finished prod permit an employee to choose a private (1) Section 1910.93 is amended by re ucts which effectively entrap asbestos general practitioner. vising Table G-3 to read as follows; FEDERAL REGISTER, VOL. 37, NO. 110--WEDNESDAY, JUNE 7, 1972 UCC 001733 11320 RULES AND REGULATIONS 6 1910.93 Air eoniaminanU. to which any employee may be exposed (d) Personal protective equipment-- * shall not exceed two fibers, longer than (I) Compliance with the exposure limits Tabu 0-(--Mmxui Dim 5 micrometers, per cubic centimeter of prescribed by paragraph (b) of this sec air. as determined by the method pre tion may not be achieved by the use of Sobttene* Hppd Mf/H* scribed in paragraph (e) of this section. respirators or shift rotation of em (3) Celling concentration. Mo em ployees, except: Silica: Crystalline: Quarts (respirable) Quarts (total dust) Crlstnballte: Cm H the value calculated from the count or man formulae for quarts. Ti'ldyrnlte: Use M the value calculated from the for mulae for quarts. Amorphous, Including natural dlatomaceous earth................ WO' %aiOi+4 20 lQmtfbP %B10r+2 JUmf/M1 %BiOj+a SOmg/M* %8IO, ployee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers, longer than 5 micrometers, per cubic centimeter of air, as determined by the method pre scribed In paragraph (e) of this section. (c) Methods of compliance--(X) En gineering methods. (1) Engineering con trols. Engineering controls, such as, but not limited to, isolation, enclosure, ex haust ventilation, and dust collection, shall be used to meet the exposure limits prescribed in paragraph (b) of this section. (1) During the time period necessary to install the engineering controls and to Institute the work practices required by paragraph (c) of this section; (li) In work situations in which the methods prescribed In paragraph (c) of this section are either technically not feasible or feasible to an extent insuffi cient to reduce the airborne concentra tions of asbestos fibers below the limits prescribed by paragraph (b) of this section; or (Hi) In emergencies. Eillcatw (less than 1% crys talline silica): Mica.......... ................. frmpsume................... ...... Talc....................... ................... Portland cement.............. Omphlic (natural!................... Coat dust (respirable fraction 30 30 30 00 14 (11) Local exhaust ventilation, (a) Local exhaust ventilation and dust col lection systems shall be designed, con structed, installed, and maintained in accordance with the American National Standard Fundamentals Governing the Civ) Where both respirators and per sonnel rotation are allowed by subdivi sions (1), (ti), or (ill) of this subpara graph, and both are practicable, person nel rotation shall be preferred and used. (2) Where a respirator is permitted by ls than 4% BiOt).................................... . For mote than 5^ SIO*...................... 2.4ihk/M> or lOing/lf* Design and Operation of Local Exhaust subparagraph (1) of this paragraph, it Systems, ANSI Z9.2-1971, which is in - shall be selected from among those ap Jnrrt or Nuisance Dust: %8iOr+2 corporated by reference herein. lb) See S 1910.6 concerning the avail Kmpinibtc fraction............... Total dust................................. 1ft 40 Bifift/M* lftiUg/M* ability of ANSI Z9.2-1971, and the maintenance of a historic file In connec Note: Conversion factors-- mppcfX35.3-million particles per cubic meter particles per c,c. i Millions of particles per cubJe. foot of air, based on Impinge? samples counted by Hght'fleld technics. tion therewith. The address of the Amer ican National Standards Institute is given in { 1910.100. (ill) Particular tools. All hand-op t The percentage of crystalline illtea In the formula L* the amount determined from air-borne samples, except In those Instances In which other methods hare been shown to be applicable. - As determined by the membrane filler method at 43i) X phase contrast magnification. Both concentration and percent Quarts for the erated and power-operated tools which may produce or release asbestos fibers In excess of the exposure limits pre scribed in paragraph (b) of this section, such as, but not limited to, saws, scorers, application of this limit are to be determined from the fraction passing a sire-selector with the following chamcieristics: ' abrasive wheels, and drills, shall be pro vided with local exhaust ventilation sys tems In accordance with subdivision til) Aerodynamic dUsnolcr Percent passing of this subparagraph. vunit. density sphere) selector (2) Work practices--(1) Wet methods. Insofar as practicable, asbestos shall be 2 90 handled, mixed, applied, removed, cut, 2.5 3-8 7ft 40 scored, or otherwise worked in a wet fi.U 2ft state sufficient to prevent the emission 1U 0 of airborne fibers in excess of the ex TJie measurements under this note refer to the nee of an AET instrument. U the respirable fraction of coal dust is determined with a MR E the figure corresponding to that of 2.4 Mg.M* ia the table for cool dust la 4,& Mg/M1* posure limits prescribed In paragraph (b) of this section, unless the usefulness of the product would be diminished thereby. 2. A new { 1910.93a is added to Part 1910, reading as follows: 1910.93a Asbestos. (U) Particular products and opera tions. No asbestos cement, mortar, coat ing, grout, plaster, or similar material containing asbestos shall be removed (a) Definitions. For the purpose of this section, (1) "Asbestos" includes chrysotile, amosite, crocidolite, tremolite, anthophyllite, and actinollte. (2) "Asbestos fibers" means asbestos fibers longer than 5 micrometers. (b) Permissible exposure to airborne from bags, cartons, or other containers in which they are shipped, without being either wetted, or enclosed, or ventilated so as to prevent effectively the release of airborne asbestos fibers in excess of the limits prescribed in paragraph (b) of this section. concentrations of asbestos fibers--(1) (Ill) Spraying, demolition, or removal. Standard effective July 7. 1972. The Employees engaged in the spraying of 8-hour time-weighted average airborne asbestos, the removal, or demolition of concentrations of asbestos fibers to pipes, structures, or equipment covered proved by the Bureau of Mines. Depart ment of the Interior, or the National In stitute for Occupational Safety and Health, Department of Health, Educa tion, and Welfare, undr the provisions of 30 CFR Part II (37 FJt. 6244, Mar. 25. 1972), and shall be used In accordance with subdivisions (l>, (li), (iii), and (lv) of this subparagraph. (!) Air purifying respirators. A reusa ble or single use air purifying respirator, or a respirator described In subdivision (II) or (iii) of this subparagraph, shall be used to reduce the concentrations of airborne asbestos fibers in the respirator below the exposure limits prescribed in paragraph of this section, when the ceiling or the 8-hour time-weighted aver age airborne concentrations of asbestos fibers are reasonably expected to exceed no more than 10 times those limits. (ill Powered afr purifying respirators. A full facepiece powered air purifying respirator, or a powered air purifying respirator, or a respirator described in subdivision Oil) of this subparagraph, shall be used to reduce the concentra tions of airborne asbestos fibers in the respirator below the exposure limits pre scribed in paragraph (b) of this section, when the ceiling or the 8-hour time- weighted average concentrations of asbestos fibers are reasonably expected to exceed 10 times, but not 100 times, those limits. (111) Type "C" supplied-air respirators, continuous flow or pressure-demand class. A type "C" continuous flow or pres sure-demand, supplied-air respirator shall be used to reduce the concentra tions of airborne asbestos fibers in the respirator below the exposure limits pre scribed in paragraph (b) of this section, which any employee may be exposed or insulated with asbestos, and In the when the ceiling or the 8-hour time- shall not exceed five fibers, longer than removal or demolition of asbestos in weighted average airborne concentra 8 micrometers, per cubic centimeter of sulation or coverings shall be provided tions of asbestos fibers are reasonably air, as determined by the method pre scribed in paragraph (e) of this section. (2) Standard effective July 1, 1976. with respiratory equipment in accord ance with paragraph (d) (2) (iii) of this section and with special clothing in ac expected to exceed 100 times those limits. (iv) Establishment of a respirator pro The 8-hour time-weighted average air cordance with paragraph (d) (3) of this gram. (a) The employer shall establish borne concentrations of asbestos fibers section. a respirator program in accordance with FEDERAL REGISTER, VOL. 37, NO. 110--WEDNESDAY, JUNE 7, 1973 UCC 001734 RULES AND REGULATIONS 11321 the requirements ol the American Na where asbestos fibers are released to be subparagraph shall conform to the re tional Standards Practices for Respira monitored In such a way as to determine quirements of 20" x 14" vertical format tory Protection, ANSI Z88.2-1969, which whether every employee's exposure to signs specified in 11910.145(d)(4), and Is incorporated by reference herein. asbestos fibers Is below the limits pre to this subdivision. The signs shall dis b. See 11910.6 concerning the avail scribed in paragraph (b) of this sec play the following legend in the lower ability of ANSI Z88.2-1969 and the main tion. If the limits are exceeded, the em panel, with letter sizes and styles of a tenance of an historic file In connection ployer shall immediately undertake a visibility at least equal to that specified therewith. The address of the American compliance program In accordance with in this subdivision. National Standards Institute is given in } 1910.100. <c) No employee shall be assigned to tasks requiring the use of respirators If, paragraph (c) of this section. (2) Personal monitoring-- Sam ples shall be collected from within the breathing zone of the employees, on Legend Asbestos_____________ Notation 1" Sans Serif, Gothic or Block. based upon his most recent examination, membrane filters of 0.8 micrometer po- Dust Hazard V4'' Sana Serif, an examining physician determines that rossity mounted in an open-face filter Gothic or the employee will be unable to function holder. Samples shall be taken for the Block. normally wearing a respirator, or that the safety or health of the employee or other employees will be impaired by his- use of a respirator: Such employee shall be rotated to another Job or given the opportunity to transfer to a different po determination of the 8-hour time- weighted average airborne concentra tions and of the ceiling concentrations of asbestos fibers. (il) Sampling frequency and patterns. After the initial determinations required Avoid Breathing Dust___ Wear Assigned Protective Equipment. Do Not Remain In Area Unlesa Your Work Re quires It. Breathing Asbestos Dust Vi" Gothic. Vi " Gothic. 14" Gothic. 14 point Gothic. sition whose duties he is able to perform by subparagraph (1) of this paragraph, May Ba Hazardous To with the same employer. In the same geo samples shall be of such frequency and Your Health. graphical area and with the same senior ity, status, and rate of pay he had Just prior to such transfer, if such a different position is available. <3) Special clothing: The employer shall provide, and require the use of, spe cial clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot coverings for any em ployee exposed to airborne concentra tions of asbestos fibers, which exceed the ceiling level prescribed in paragraph (b) of this section. (4) Change rooms: (1) At any fixed place of employment exposed to airborne concentrations of asbestos fibers In ex cess of the exposure limits prescribed in paragraph (b) of this section, the em ployer shall provide change rooms for employees working regularly at the place. di) Clothes lockers: The employer shall provide two separate lockers or con tainers for each employee, so separated or Isolated as to prevent contamination of the employee's street clothes from his work clothes. pattern as to represent with reasonable accuracy the levels of exposure of em ployees. In no case shall the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph <b) of this section. (3) Environmental monitoring--(i) samples shall be collected from areas of a work environment which are represent ative of the airborne concentrations of asbestos fibers which may reach the breathing zone of employees. Samples shall be collected on a membrane filter of 0.8 micrometer porosity mounted in an open-face filter holder. Samples shall be taken for the determination of the 8hour time-weighted average airborne concentrations and of the celling con centrations of asbestos fibers. (ii) Sampling frequency and patterns. After the initial determinations required by subparagraph (1) of this paragraph, samples shall be of such frequency and pattern as to represent with reasonable Spacing between lines shall be at least equal to the height of the upper of any two lines. (2) Caution labels--(1) Labeling. Cau tion labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentra tions of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released. (ii) Label specifications. The caution labels required by subdivision (i) of this subparagraph shall be printed in letters of sufficient size and contrast as to be readily visible and legible. The label shall state: Caution Contains Asbestos Fibers (iii) Laundering: (a) Laundering of accuracy the levels of exposure of the Avoid Creating Dust asbestos contaminated clothing shall be employees. In no case shall sampling be Breathing Asbestos Dust May Cause done so as to prevent the release of air at intervals greater than 6 months for Serious Bodily Harm borne asbestos fibers In excess of the ex employees whose exposures to asbestos (h) Housekeeping--(1) Cleaning. All posure limits prescribed in paragraph (b) of this section. (b) Any employer who gives asbestoscontaminated clothing to another person for laundering shall inform such person of the requirement In (a) of this subdi vision to effectively prevent the release of airborne asbestos fibers in excess of the exposure limits prescribed in para graph of this section. (c> Contaminated clothing shall be transported in sealed impermeable bags, or other closed, impermeable containers, and labeled in accordance with para graph (g) of this section. (e) Method of measurement. All de terminations of airborne concentrations may reasonably be foreseen to exceed the exposure limits prescribed in para graph (b) of this section. (4) Employee observation of monitor ing. Affected employees, or their rep resentatives, shall be given a reasonable opportunity to observe any monitoring required by this paragraph and shall have access to the records thereof. (g) Caution signs and labels. (1) Cau tion signs, (i) Posting. Caution signs shall be provided and displayed at each location where airborne concentrations of asbestos fibers-may be in excess of the exposure limits prescribed in paragraph (b) of this section. Signs shall be posted at such a distance from such a location external surfaces in any place of employ ment shall be maintained free of accu mulations of asbestos fibers if, with their dispersion, there would be an excessive concentration. <2> Waste disposal. Asbestos waste, scrap, debris, bags, containers, equip ment, and asbestos-contaminated cloth ing, consigned for disposal, which may produce in any reasonably foreseeable use, handling, storage, processing, dis posal, or transportation airborne concen trations of asbestos fibers in excess of the exposure limits prescribed iriv paragraph (b) of this section shall be collected and disposed of in sealed impermeable bags, or other closed, Impermeable containers. of asbestos libers shall be made by the so that an employee may read the signs (1) Recordkeeping--(1) Exposure rec membrane filter method af~40tt-450 X and take necessary protective steps be ords. Every employer shall maintain rec (magnification) (4 millimeter objective) with phase contrast illumination. (f) Monitoring--(1) Initial determi nations. Within 6 months of the publi fore entering the area marked by the signs. Signs shall be posted at all ap proaches to areas containing excessive concentrations of airborne asbestos fibers. ords of any personal or environmental monitoring required by this section. Rec ords shall be maintained for a period of at least 3 years and shall be made avail able upon request to the Assistant Secre cation of this section, every employer , (11) Sign specifications. The warning tary of Labor for Occupational Safety shall cause every place of employment signs required by subdivision (1) of this and Health, the Director of the National FEDERAL REGISTER, VOL. 37, NO. 110--WEDNESDAY, JUNE 7, 1472 UCC 001735 11322 RULES AND REGULATIONS Institute for Occupational Safety and tions. Records shall be retained by Health, and to authorized representa employers for at least 20 years. tives of either. <2) employee access. Every employee end former employee shall have reason able access to any record required to be maintained by subparagraph (1) of this paragraph, which indicates the em ployee's own exposure to asbestos fibers. (3) Employee notification. Any em ployee found to have been exposed at any time to airborne concentrations of asbes tos fibers in excess of the limits pre scribed in paragraph (b) of this section shall be notified in writing of the expo sure as soon as practicable but not later than 5 days of the finding. The employee shall also be timely notified of the cor rective action being taken. (j) Medical examinations--(1) Gen eral. The employer shall provide or make available at his cost, medical examina tions relative to exposure to asbestos re (ii) Access. The contents of the rec ords of the medical examinations required by this paragraph shall be made available, for inspection and copying, to the Assistant Secretary of Labor for Occupational Safety and Health, the Director of NIOSH, to authorized physi cians and medical consultants of either of them, and, upon the request of an em ployee or former employee, to his physi cian. Any physician who conducts a medical examination required by this paragraph shall furnish to the employer of the examined employee all the infor mation specifically required by this paragraph, and any other medical in formation related to occupational ex posure to asbestos fibers. ( 3. A new { 1910.19 is added to Subpart B of Part 1910, reading as follows: quired by this paragraph. (2) Preplacement. The employer shall provide or make available to each of his employees, within 30 calendar days fol lowing his first employment in an occupation exposed to airborne con centrations of asbestos fibers, a compre hensive medical examination, which shall include, os a minimum, a chest roent 1910,19 Asbestos dust. Section 1910.93a shall apply to the ex posure of every employee to asbestos dust in every employment and place of employment covered by {1910.12, 1 1910.13, t 1910.14, { 1910.15, or } 1910.16, in lieu of any different standard on ex posure to asbestos dust which would genogram (posterior-anterior 14 x 17 otherwise be applicable by virtue of any Inches), a history to elicit symptom of those sections. atology of respiratory disease, and pulmonary function tests to Include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEV,,). Effective date. Paragraph (b)(2) of { 1910.93a shall become effective July 1, 1976. All other provisions of |{ 1919.93a, 1910.93, and 1910.19 shall become effec (3) Annual examinations. On or be tive July 7,1972. The current emergency fore January 31, 1973, and at least an temporary standard remains in effect nually thereafter, every employer shall until July 7, 1972. provide, or make available, comprehen sive medical examinations to each of his employees engaged in occupations ex posed to airborne concentrations of as bestos fibers. Such annual examination shall Include, as a minimum, a chest (Secs. S, a, 84 Stat. 1693, 1698; 29 U.S.C. 865, 657; 29 CFR 1910.4; Secretary of Labor's Order No. 12-71. 36 F.R 8764) Signed at Washington, D.C., this 2d day of June 1972. roentgenogram (posterior-anterior 14 x 17 Inches), a history to elicit symptom G. C. Guenther, Assistant Secretary of Labor, atology of respiratory disease, and pulmonary function tests to include (FR Doc.72-8574 Filed 6-8-72:8:46 am] forced vital capacity (FVC) and forced expiratory volume at 1 second (FEVi o). (4) Termination of employment. The employer shall provide, or make avail able, within 30 calendar days before or after the termination of employment of any employee engaged in an occupation exposed-to airborne concentrations of asbestos fibers, a comprehensive medical examination which shall' Include, as a minimum, a chest roentgenogram (pos terior-anterior 14 x 17 Inches), a history to elicit symptomatology of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEVi ,,>. (5) Recent examinations. No medical examination is required of any em ployee, if adequate records show that the employee has been examined in ac cordance with this paragraph within the past 1-year period. (6) Medical records--(i) Mainte nance. Employers of employees examined pursuant to this paragraph shall cause to be maintained complete and accurate records of all such medical examina UCC 001736 UNION MaterialCARBIDE September 1, 1972 UNION CARBIDE CORPORATION 4625 ROYAL AVENUE NIAGARA FALLS, NEW YORK 14302 TELEPHONE: (716) 278-3376 PRODUCT: ChrysotiIe Asbestos TRADE NAMES: "Calidria" Asbestos CHEMICAL FORMULA: Mg6(0H)8Si4010 I. PHYSICAL DATA BOILING POINT AND MELTING POINT: Not Pertinent SPECIFIC GRAVITY (H20=1): 2.45 VOLATILE CONTENT: Absorbed Water 1 -- 4% By Weight. Structural Water Approximately 13% by Weight. APPEARANCE: Pellets or Fine White Powder, No odor. Very Slight Solubility in Water. II. HAZARDOUS INGREDIENTS Not Applicable. III. FIRE AND EXPLOSION HAZARD DATA Material is not Combustible. No Fire or Explosion Hazard. IV. REACTIVITY DATA INERT MATERIAL: No Decomposition or Polymerization Conditions. V. HEALTH HAZARD DATA PERMISSIBLE EXPOSURE TO AIRBORNE CONCENTRATION: The current standard of the Occupational Safety and Health Act of 1970 contains the following exposure limits: "The 8-hour time-weighted average airborne concentration of asbestos fibers to which employees are exposed shall not exceed 5 fibers per milliliter greater than 5 microns in length, as determined by the membrane filter method at 400-450X magnification (4 millimeter objective) phase contrast illumination. No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers per milliliter, longer than 5 microns." {Federal Register -- Vol. 37, June 7, 1972, page 11320). EFFECTS OF OVER EXPOSURE: Prolonged over exposure may result in lung damage. EMERGENCY AND FIRST AID PROCEDURES: Not applicable. Material has no acute toxicity. VI. SPILL OR LEAK PROCEDURES STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED: Avoid inhalation of dust. Remove spilled material by vacuum cleaner or by water wash. WASTE DISPOSAL METHOD: If reasonably foreseeable handling will not produce airborne concentrations in excess of exposure limits, no special procedures are required. When limits are likely to be exceeded, waste and scrap shall be collected and disposed of in impermeable sealed bags or other closed, impermeable containers, suitably labelled. Union Carbide Corporation assumes no responsibility and makes no warranty, expressed or implied, repre sentation, promise, or statement as to completeness, accuracy, or currency of any data provided. UCC 001737 CALIDRIA ASBESTOS RG-244 TYPICAL CHEMICAL ANALYSIS Component MgO Si 02 AI2O3 Fe Ca Co Cr Cu Mn Ni Se Loss on Ignition {CO2 & H2O) Weight % 38.2 46.1 0.2 1.4 0.025 0.004 0.13 0.005 0.05 0.16 <0.001 12.7 Component Ag A1 As Au B Ba Be Bi Ca Cb Cd Co Cr Cs Cu Fe Ga Ge Hf Hg In Ir K La Li Mg' Mn Mo Na TYPICAL SPECTROGRAPHIC ANALYSIS Detection Limit, Wt. % 0.001 0.003 0.01 0.002 0.006 0.003 0.001 0.005 0.002 0.006 0.01 0.01 0.003 N.A.(l) 0.001 0.006 0.01 0.005 0.03 0.02 0.03 0.03 N.A. 0.01 0.1 0.001 0.003 0.003 0.03 Analysis, Wt. % N.D. ^ 0.08-0.8 N.D. N.D. N.D. N.D. N.D. N.D. 0.008-0.08 N.D. N.D. 0.004-0.04 0.02-0.2 -- N.D. 0.4-4.0 N.D. N.D. N.D. N.D. N.D. N.D. -- N.D. N.D. Major 0.008-0.08 N.D. 0.08-0.8 Component Ni Os P Pb Pd Pt Rb Re Rh Ra Sb Sc Se Si Sn Sr Ta Te Th Ti T1 U V W Y Yb Zn Zr Detection Limit, Analysis, Wt. * Wt. % 0.003 0.03 0.08 0.003 0.005 0.005 N.A. 0.03 0.02 0.03 0.01 0.01 0.001 0.002 0.01 0.01 0.05 0.03 0.003 0.2 0.1 0.003 0.01 0.01 0.01 0.02 0.006 0.08-0.8 N.D. N.D. N.D. N.D. N.D. ---- N.D. N.D. N.D. N.D. N`D*f3l <o.oor Major N.D. N.D. N.D. N.D. N.D. 0.0008-0.008 N.D. N.D. N.D. N.D. N.D. N.D. N.D. N.D. ^ N.A. - Not analyzed. ^ N.D. - Not detected. ^ By chemical analysis. PLEASE TYPE AND BE CONCISE ADDRESS SECTION MESSAGE ADDRESSEE V . W . T AURTROM MESSAGE ENTRY FORM MESSAGE BILLING CODE^- (INDICATE A DIGIT NUMERIC CODE) 6 DIVISION/DEPARTMENT CITY/STATE UNION CARBIDE METALS KING CITY 7 : 8: 0 DESTINATION ADDRESSEE CODE CALIFORNIA MESSAGE SECTION (--------------------------- --------------------------------- ) PLEASE ADVISE BY TWX ON SEPTEMBER 8. TOTAL TONS AND TONS MEETING SPEC s OF RG-244 AND SX-24 PRODUCED SEPTEMBER 1 THROUGH 7. THANKS. W. C. THURBER NYC - 38th floor DATE ORIGINATOR 9/4/75 W. C. THURBER UCC 001739 DIVISION/DEPARTMENT METALS CITY LOCATION NYC - 38th floor UC 149-28 B - TO COMMUNICATIONS MESSAGE ENTRY LOCATION -