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CITATION and NOTIFICATION OF PENALTYft Indianapolis Area Offico 46 East Ohio Street, Hoorn 422 Indianapolis, Indiana 46204 Telephone Number .117-269-7290 ^i6ntf* VItSBMttt BAT* 1 MHA BIRiKn " " 7/27/78 S3255 031 IUWM ARU rut s 2210 1 2 \U 3 1978 PENALTIES ARE DUE WITlim IS DAYS OF WtYPflOWVIbfATroNlSlOVcirjCTriiW'H REPEATED 1 INSPECTION DATE: 5/23-6/1/78 INSPECTION SITE: Highway 06 Newburgh, IN IIECtlPT OF /THIS NOTIFICATION UNLESS C0NTESTE0 (See tndouil TO: nMrr*, B00o0b IPUa-r5sJ'J1s5,, sEanwv.. wConnttrroil mMaannaaggeerr THE LAW REOUIRES that a copy of thi, Booklet) ALCOA-Wa: Highway Newbi re Operations P. 0, Box 10 47630 Citation to posted immediately in a promt* item place at or near the location el the vio* lation(i) died below. The Citation must remain posted until the violations cited to* Th Section May Be Detached Before Posting low have been corrected, or lor 3 working days Iciduding woekends and Federal holi days) whichever is longor. nis citation describes violations of the Occupational Safety and Health Act of 1970. The penaltylies) listed below are based on these violations, ou must correct the violations referred to in this elution by the dates listed below and pay the penalties proposed, unless within 15 working days deluding weekends end Federal holidays) from your receipt of this elution and penalty you mail a notice of contest to the U.S. Department ol ibor Area Office at lha address shown above* (See the enclosed booklet which outlines your responsibilities end courses of action and should be id in conjunction with this formJ EM NUMBER ANDARP, REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION PATE BY WHICH VIOLATION MUST BE CORRECTED PENALTY The violations described in this citation are alleged to have occurred on or about the day the inspection was made unless otherwise indicated within the description given below. 1 29 CFR 1910,1001(g)(2)(i): Caution labels were not affixed to all raw materials, mixtures, scrap, waste, debris, or other products con:aining asbestos fibers, or to their containers, which during any easonably foreseeable use, handling, storage, disposal, processing ir transportation could release airborno concentrations of asbestos ibers exceeding prescribed exposure limits: (a) On the south side of the Ingot Plant Building #134 in the Marinite Keying area, near column A46, a metal can containing scrap marinite dust and debris from a rasping operation is not labeled as a potential airborne asbestos hazard. 8/1/78 $410. \ PLAINTIFF'S EXHIBIT AL-252 (b) On the south side of the Ingot Plant Building #134 in the Marinite Keying area, near column A46, a wooden scrap "coffin* containing marinite debris and dust is not labeled as a potential airborne asbestos hazard. These conditions arc repeated violations of a standard cited on a previous inspection. > CFR 1910.1001(h)(2): Asbestos waste, scrap, debris, bags, con fers, equipment, and asbestos-contaminated clothing, consigned for sposal, which may produce airborne levels of asbestos fibers in_ :ccss of prescribed limits was not collected and disposed of in alcd impermeable bags or other closed, impermeable containers: (a) On the south side of the Ingot Plant Building #134 in the Marinite Keying Area, near column A46, scrap marinite was improperly handled and disposed of in that waste marinite dust and debris was stored in an open metal can. 8/1/78' $820. A DIRECTOR ''Total on "'last pngc_ CE TO EMPLOYEES5 -"T1hhe tlaw give: an employee Vr hit cmativc Hie opportunity 10 object lo any abatement date r a I'inlalicm il ho believe: (he date lo tie imicasonahlc. antes! mint bu mailed lo the U.S. Depm uncut nl Lalwir lllieeal the address shown almve wilhin Hi wort in-; .lay, EMPLOYER DISCRIMINATION UNLAWFUL - The law pro hibits disci iinmation by ail cmployci aiiaimi an employee loi tiling a complaint nr tor :i:ii| any rights under Ibis Act. An eng:i^y**i' ..ho itclicvcs that lie has Iiim.-h disci iinmalcd -Mr'iusi may hie a comiilainl no later than dll il.iys allm the TDTAlPLNAir I nit THIS CI1ATI0N rlil'i'kiiiMiMii Of***'* [it "Mil OSHA" dim.i weekends aiul I edciel holiday.) <>i die luceitd by iliscimiin.inon with the U.S. Department nl Labm Ama Ollicn Until .ttoOSUAN' IM) |U*IMltIillicit iployct ol this citation a:.a penalty. at the address shown alHive. DYEIt orr.i *>-'ir.H.ITIFS and COURSES OF ACTION -- the rflc 111.1lI liiinklirt oiitlinus emi'lnyer rcsiuiiisihilitics anil . id -.Inin anil shiuilil he lead in cniijiinciinn with.Ibis iiiiIiIiimiiiiii. CHAIKIN ANIt Nl) III III At ION 1)1 I'l NAI tY leaut / m v 'arii ARD 042538 OCCUPATIONAL SAt CIV ANP HEALTH ADMINISIIIATION ' * CITATION anti NOTIFICATION OF PENALTY Indianapolis Area Office 46 East Ohio Street, Room 422 Indianapolis, Indiana 46204 Telephone Number 317-269-7290 TtSSOMCt DAlt OSIIANUMDIM 7/27/78 M6I0E SAR3E2A55 * 031 PACK 5 5210 2 #f 2 II REPEATED u 1 INSPECTION DATE: 5/23-6/1/78 INSPECTION SITE: Highway 66 Newburgh, IN to: Mr. Bob Parsons, l&iv. Control Manager ALCOA-Warrick Oporationa THE LAW REQUIRES that coov At lhii Clwtisn be postal Immediately in promi- Highway 66, P. 0. Box 10 Newburgh, IN 47630 MM plan <1 or otar ihg louden o( me tolatlon(il cited below. The Citation must remain posted until tho vioiahoni cited be* low have been corrected, or lor 3 working slay* (excluding weekends end Federel holi days! ettlcltaeor is longer. This citation describes vtoUtlOfll of tho Occupational Safety and Health Act of 1970. Tha penaltv(let) titled below ara based on these violations. You mult correct the violations referred to in this citation by the bales lined below and pay the penalties proposed, unless within 1 & working days (excluding weekends and Federal holidays) from your receipt of this citation and penally you meM a notice of contest to the U.S. Department of Labor Aroa Office et the eddress shown above. (See the enclosed booklet vmich outlines your responsibilities end courses of eetion end should bo read In conjunction with this form.} *T~en^ir--i i" ' '1 r~ i n ` 1" ITEM NUMBER STANDARD. REGULATION OR SECTION OF THE ACT VIOLATED: DESCRIPTION OATEBV WHICH VIOLATION MUST BE CORRECTED PENALTIES ARE UUC WITHIN 11 DAYS OF RECEIPT OF THIS NOTIFICATIOr. UNLESS CONTESTED (See enclosed Booklet) Tltii Seetion May De Dewched Dolor* Potting (b) On the south side of the Machine Shop Building #344 in the Marinite*Pouting Room, asbestos-containing waste was stored in an open container. (c) On the south side of the Ingot Riant Building #134 in the Marinite Keying Area, near column A46, a wooden scrap "coffin containing marinite debris and dust was not adequately scaled when not in use. These conditions are repeated violations of a standard cited on two previous inspections. ARD 042539 AREA DIRECTOR $1230, OTICE TO EMPLOtYtxS - 1 tvu law gives an cthpio^dv 01 his piescmuhve the oppoi (unity (o object to any abatement state t for a violation it he licheves the dale to bo untoasoitublc. no comctl must bo malted to Use U.S. Department, ut 1 noi ToTAfpCNATr.EEMPLOYEH DISCRIMINATION UNLAWFUL -- The law pro hibits disci imiiuuion try on employer aijainsl on employee (ot Foil THIS CITATION filing a complaint or (or cxoicisiitg any lights under this Act. jlltkndu'ckfli Millie An employee who behoves that bo bus Ixreu discrimiiKiicd Otilnr I'ayaltU* Itt iiiaOi Need tho mldtcti shown above withijv H* woiKinj)days winding weekends and FiKtatal-h,fdjy*) of tho iccoipt by e employe! ot this cilji^n *md (xmaliy. tigainst may tile complaint no luter titan 30 days altm the discrimination wilh the U.S. DepaMmenl ol Luluic Aura Oltice at the address shown alxtvc. . **t>OL IIS11A** 1imIh:H(( Ota IA N> nil IlsnnlUnru APLOYEK rtt-rtrONSIOlLITIES AND COUHSES OF ACTION -- The enclosed huoklet outlines employer iet|MinsUiilili<'S and ad ion end should he lead in tumjoudtou with this imhliCgitum. r.uAuuN ANbNunnr.AUONor pi namy OSIIA '/ Ml V *.//U jfc- ' CITATIONantl NOTIFICATION OF PENALTY Indianapolis Area Office "issuance oak ` OSllA NUMItli _.7/27/7.K_ S3255 031 > HE6I0N * AIKA FACE 46 East Ohio Street, Hoorn 422 Indianapolis, Indiana 46204 Telephone Humber ,'117-269-7290 5 2210 1 tr 3 PENALTIFS A fit UUC WITHIN 1b DA vs or OTHER INSPECTION OATE-. 5/23-6/1/78 INSPECTION SITE: Highway 66 neccii'T OF THIS . NQTIFICATI0: UNLESS CONTESTED Newburgh, IN (Sit tnclowtl TO: Mr. Dob Parsons, Env. Control Manager ALCOA-Warrick Operations Highway 66, P. 0. Box 10 Newburgh, IN 47630 THE LAW REQUIRES that a copy ol (hit Citation bo potted Immediately in a piomi* (tent piece ei or near the location ol the viototionU) cited below. Tho Citation must remain potted until the violations cued be Booklet) This Section Ma< Be Detached Uelore Potting low have been corrected, or lor 3 working days (excluding weekends end Federal holi days) whichever Is longer.. This ciiedon describes violations ol the Occupational Salety and Health Act ol 1970. The penaltylies) listed below are based on these violations. You must correct the violations referred lo in this citation by the deles listed below end pay tha penalties proposed, unless within 15 working days (excluding weekends and Federal holidays) from your receipt ol this citation end penalty you mail a notice of contest to the U.S. Department ol Labor Area Office at the address mown above. (Sere the enclosed booklet which outlines your responsibilities end courses ol action and should be reed in conjunction with this form.) 4--------------------------------------------------------------------------------------------------- ITEM NUMBER STANDARD, REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION DATE BY WHICH VIOLATION MUST BE CORRECTED | PENALTY The violations described In this citation are alleged to have occurred on or about the day the inspection was made unless otherwise Indicated within the description given below. 1 29 CPU 1910.94(d)(9)(viii): Open surface tank workers exposed to Chromic Acid(s) did not have periodic examinations of the nostrils or other ports of the body to detect incipient ulcerations Baployees involved with the operation of Coll Prep lines #3, 4, 5, and 7 in Building #819 Finishing Area are exposed to chemical treatment tonics containing chromic acid and hove not had annual physical examinations to detect ulceration. 2 29 CJR 1910.134(d)(2)(ii): Suitable in-line air purifying sorbent beds and filters were not installed in compressor(s) to further assure breathing air quality, and only a high-temperature alarm was used on oil lubricated compressor(s) and the air from the compressor was. not frequently tested for carbon monoxide to insure that it met require ments of the specification for grade D breathing air as described in Compressed Gas Association Commodity specification G-7.1 - 1966: In the Anode Building #260, there are three whitccap airline respirators supplied with breathing air from the oil-lubri cated plant compressor line. Suitable in-line .air purifying sorbent beds and filters are not installed to insure breathing air quality. In addition, air from the compressor is not either tested frequently or continuously monitored for carbon monoxide to insure it meet? the reqiiiremcnts.for.Grado D breathing air. 8/31/78 8/31/78 $0 $0 ARD 042540 ________ _ 1 AREA DIRECTOR LzA.... ^_________ total on NOTICE TO EMPtO. S -- Tito i,iw <)ive$ an tmt|n*Yeiw Ins cprcscituiivc llufopiKii (unity to otiiect to any abatement date .01 fur a .violation it he believes tho date to bo unreasonable. Tho contest* must tut mailed to the U S. Department nt Labor ...last pnr.e EMPLOOYER DISCRIMINATION UNLAWFUL - The law pro* TUI M l`l NftLT'. hums discrimination by an employer against an employee lor., filing a complaint or (> exercising any rights under this Act.. run this CITATION Mrflmvhi'iiliiiiMiiiii' An rmpinycc who Ircliovcs (hat h has (icon disci immineil OiiIpi I'.iyrfliln Tu AieaOHicuat (he eddies* shown above within 15 wuiLmn (lays itKClutlmg weekends oml FtnltMal li.awkiysruf Ihu tecuipt by iuMfinployei ol this ritjimn and ihMuilly. against may tile a complaint no later than 30 days alter the ttiM.innuMtion with Hiu U.Sv Depattuumt of Labor Amm Olhcu at tint aikhess shown above. **|)OI. ttiillA" liiilu'aip (Kll IA N* mi |li<nnHimrii :MPlOVER iirr.rONSHHUTHiS AND COURSES OP ACTION -- .......... closed booklet outlines employer responsibilities and rviim.'k ul action am) should Im lead in conjunction with this tuMiUcahon. CU A1 ION AND Nil III 1C A HON Of FI NAI.1 Y ..... . / |St v. .s././.i.. OCCUPATIONAL SAI 1Y ANO HEALTH AOMINIS1RATION CltATIOl'i'incI NOTIFICATION OF PENALTY Indianapolis Area Office 46 East Otiio Street, Room 422 Indianapolis, Indiana 4 6204 Telephone Number 317-269-7290 BSUARCl OAll i OSIIA NUMOtll 7/27/78 ftfClON SAR3E2A55 * 031 FACE _i_______ 2210 2 f 3 &TVj>6SWi YiTlofrliBf INSPECTION DATE: 5/23-6/1/78 OTHER 2 INSPECTION SITE: Highway 66 Newburgh, IN to: Mr. Bob Parsons, Env. Control Manager ALCOA-Warrick Operations Highway 66, P, 0. Box 10 Newburgh, IN 47630 THE LAW REQUIRES that copy I this Dutton be posted immedtaiciy in a promt* pent place at or near the location I the vio* JeUonfi) cited below. The Citation must remain potted until the violanom cited be low have been corrected, or for 3 working days (excluding weekends and Federal holi days) whichever is longer. This citation describes violations of the Occupational Safety end Health Act of 1970. The penalty(Jet) listed below are based on these violations. You must correct the violations raferred to In this citation by the dates listed below and pay the penalties proposed, unleu within IS working days (excluding weekends end Federal holidays) Irom your receipt of this citation and penalty you mail e notice of contest to the U.S. Department of Labor Area Office at the address shown above. (See the enclosed booklet which outlines your responsibilities end courses of action end should be reed In conjunction with this form.) i ITEM NUMBER STANDARD, REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION * DATE BY WHICH VIOLATION MUST BE CORRECTED penalties Alt DUE WITHIN IS days or RECEIPT OF THIS NOTIFICATIQ UNLESS CONTESTED (See enclosed ilooklei) Tint Section Ma Q Deitcheti Oelure Posting PENALTY 3 29 CIR 1910.1001(f)(1): Initial monitoring was not conducted in such a manner to determine whether every employee's exposure to airborne asbestos fibers is below the prescribed limits: In the Mold Shop of Building #344 Machine Shop, maintenance mechanics work with asbestos-containing marinite board and maj be exposed to asbestos fibers released from the marinite. Initial monitoring has not been performed at.this operation tc determine whether exposure to airborne asbestos is below the prescribed limits. 4a 29 era 1910.1001(f)(2)(i): Proper samples were not collected from the breathing zones of employees when determining exposure to air borne asbestos fibers: (a) In the Ingot Plant Building #134, samples have not been taken for the determination of the 8-hour time-weighted average airborne asbestos concentration on the brickmason operating the Marinite handling room 134-X. (b) In the Machine Shop Building #344, samples have not been taken for the determination of the 8-hour time weighted average airborne asbestos concentration on the maintenance mechanic operating the Marinite Pouting Room. 4b 29 CIR 1910.1001(f)(2)(ii): The airborne asbestos monitoring schedule was not of sufficient frequency and pattern as to represent with reasonable accuracy the levels of employee exposure to air borne asbestos fibers: (a) In the Ingot Plant Building #134, 8-hour time weighted average airborne asbestos sampling determinations have not been conducted on at least 6 month intervals on the brickmason operating the Marinite handling room 134-X. His exposure may reasonably be foreseen to exceed time weighted average limits, based on short term exposure results. 8/1/78 $0 8/1/78 $0 8/1/78 ARD 042541 area director -Q'-y-- NOTICE TO EMRUOJ.iiiCV- The lawgives ancihplUToc wj'lns representative (He oppot (unity to oh|ect to any abatement dale set for .a`Violation if ho (relieves the il.no to N* uiumminalile. Tito contest must Ik* mailed to th* VJ.S. Department of Leboi AicaOi lieu it the addict m.omh above within U> woiking clays {excluding .vweLuitds and Fedctal holidays) of tho receipt by 'Total on .Inst page EMPLOYt-U DISCRIMINATION UNLAWFUL-- Thu law pro*, TOTAL rENALT dibits discrimination by an employer against an employee fur F0I1 TIMS filing a complaint or (ot exercising any tights under this Act. CITATION tii Moii< An employee who (relieves that ho has been tlmtiimmated umIi'f I'uv-aa** ( agamst may lilu & complaint no later than 30 days alter the mool osiia" disciimination with the U.S. Department ol l.almi Ate.iOlhce 1.1.1.HU. UNMAN' im employer of this citatum and penally. at the addnibS shown almve. ZMFLOYLK ltCSVONSmiimi:S AND COURSES OF ACTION -- (lie citcImtHlIumklci outlines employer responsibilities and :Oinses ol action and slnnild he mad in cmi|itnch<ttt with this unidu.amm. niAiiuN AwuNnm ir.AiiuNtir hnauy (inttA v ttt v. //1 CITATION and NOTIFICATION OF PENALTY Indianapolis Area Office 46 East Ohio Street, Room 422 Indianapolis, Indiana 46204 Telephone Number 317-269-7290 TtSSUANCC BMt 0S1IANUMUCII 7/27/78 S3255 031 > RC6I0N * AflCA * PACE 5 1210 3" 3 OTHER INSPECTION DATE: 5/23-6/1/78 INSPECTION SITE; Highway 66 Newburgh, IN TO: nHrr*. aBooob rPaarrssoonnss,, mEnivv*. uCooivnctrrooil nMaannaaggcerr THE LAW requires thai a copy oi tim ALCOA-Warrick Operations Citation bt potted unmcOuiely m a promt* Highway 66, P. 0. Box 10 Newburgh, IN 47630 nent place at or near the location oi the viulationUI chod below. The Citation most remain posted until the violations cited be* low havo been corrected, or lor 3 wo/kmn days (excluding weekends and Federal hol<* days) whichever is longer. This citation describes violations of the Occupational Sofoty and Health Act of 1970. The penahyhes) listed below ere baud on these violations. You must correct the violations referred to in this citation by She dates listed below end pey the penalties proposed, unlsti within tft worktno slays leeetutfing weekends and Federal hoddeys) from your receipt of this citation and penalty you moil a notice ol contest to the U.S. Department of Labor Area Office at the address shown above. (See the enclosed booklet which outlines your responsibilities end courses of action and should ba read in conjunction with this formJ ITEM NUMBER STANDARO. REGULATION OR SECTION OP THE ACT VIOLATED: DESCRIPTION DATE BY WHICH VIOLATION MUST BE CORRECTED PENALTIES AHC DUE WITHIN IS 0AYS0F necciPT OF THIS NOTIFICATION UNLESS CONTESTED (See enclosed Booklet) This Section lAay Qi Detached Qvlure Posting (b) In the Machine Shop Building #344, 8-hour time weighted average airborne asbestos sampling determinations have not been conducted on at least 6 month intervals on the maintenance mechanic operating the Marinite Routing Room. 5 29 CFR 1910.1001(h)(1): Places of employment were not maintained free of accumulations of asbestos fibers which, if dispersed, could result in an excessive concentration: On the south side of the Ingot Plant Building #134 in the Marinite Keying area near column A46, the workbench used in conjunction with marinite keying operations was found littered with asbestos-containing marinite scrap and debris. This condition was noted after the shift change, before which time it should have been cleaned up1. 8/1/78 $0 Total of Citations #1 and #2 is $1230. 1 AREA DIRECTOR $0 MOT1CE TO EMPLOYEES; --- V/c lIajww g(lives uaiaveeitiilTpploloyy.ece 6l i/hiky ElMPLOYER DISCRIMINATION UNLAWFUL - The law pio* cpiescni.itivc (he opportunity to object to any abatement dale hihiu disci nvmutinn liy art employer against an employee for ct lor 0 violation d be believes the dale to be umeasonablc. tiling a complaint oi for cxuicising any light* undur this Act. Thu contest must ta mailed to the U.S. Dopai (merit ol tabor An employee wfio believes lhal Im has l>eim tlisci iminatetl NttNiOUuni'ji the addiess slmwu atmvc wilhin If* working (lays against may hie a complaint no later than 30 days alter the excluding, weekends ami fodmal holidays) ol lltu receipt by diMaiiniiialtun wilh tim U.S. DopaiImenl ol Lalim-Aiua Olhcu lie employer ul this citation ami penalty. ul Ihe addicts shown above. MPLOYEK RESI'ONSMULITICS AND COURSES OF ACTION -- Tin? ciic.IosinI Imokiol-autlUu* employe! responsibilities ami muses ul action and should be lead in cnniunciitiii with this notiliinhon. TOTALPENAl FOR THIS CITATION Oulm Cayalito "DDL OSHA lodir^mOSIIA mi luniiiuni CIIAriQN ANUNOIIIICAIIONUI IMNALIY trJ IA ./...I.I.I, VM. :/ fit ARD 042542 Coapany llsso: ATiTOresq ALCOA (Warrick Operations) Highway 66_______________________ Kevburgh, JN CSI10 IP StE^-Oll Dear Sir: -Qae of the requirements of the Occupational'Safety and Health Act of 1970 io that the Area Office must be informed when violations are abated. This form was. prepared to serve as a-roaindcr end to aid you in fulfilling this requirement. YJhen abatement is completed, please sign and date the appropriate lines and return to the following address: Hr. J. F. Xcppler, Area Director . U. S. Department of Labor i;6 Fast Ohio Street, Boom U22 ' Indianapolis, HI 1|620U `Fhn following items have been abated on the date indicated: OTHER Citation Item Abatement Date ' Date Abated Hdmber Humber 2__________ 1 ____ 2 ________ 3 ___________ U 8/11/78 . ?TZ7.8 ~ 8/1/78 8/1/78 _ _I 8/-1/78 s ABD 042543 Company Home: ATffmrgg . ALCOA fWarrick Onoratlonn) Highway 66_________ ;________' Newburgh, IN ___________ CSBO ID S3255-031 Dear Sir: *I * .One oi the requirenents of the Occupational 'Safety and Health Act of 1970 is that the Area Office crust be informed when violations are abated. This form was- prepared to serve as a_reminder and to' aid you in fulfilling this requirement. > Vhen abatement is completed, please sign and date the appropriate lino3 and return to the following address: Hr. J. F. Xeppler, Area Director 0. S. Department of Labor 1*6 Fast Ohio Street, Hoorn 1*22 . Indianapolis i Ilf 4 6204 She following items have been abated on the date indicated: hepeated Citation Item Abatement Date ` Date Abated HUmber Number 11 8/1/78 2 8/1/78 L S ARD 042544 RESPIRATORY PROTECTION 18.1.1 1996 JUNE PAGE 1 OF 12 This is a Safety and Health Mandated Procedure - Alcoa Controlled Entities Worldwide. 1.0 SCOPE This specification sets forth accepted practices for the use of respiratory protection. It provides guidance, on the proper selection, use, and care of respirators, and describes the essentials of a respiratory protection program. The specification conforms with regulations promulgated under the Occupational Safety and Health Act (OSHA) 29 CFR 1910.134. Specific state and non-U.S. safety and health standards may require special consideration. 2.0 DEFINITIONS 2.1 Air-Purifying Respirator A respirator designed to remove contaminants from ambient air prior to its inhalation. 2.2 Approved Respirator A respirator tested and listed as satisfactory in the United States by the Mine Safety and Health Administration, U.S. Department of Labor, and the National Institute for Occupational Safety and Health, or a government agency or nationally recognized scientific body in non-U.S. locations. 2.3 Immediately Dangerous to Life or Health Any hazardous atmosphere that poses an immediate threat to life or health or that poses an immediate threat of severe exposure to contaminants such as radioactive materials which are likely to have adverse delayed effects on health. 2.4 Negative Pressure Respirator A respirator in which the air pressure inside the facepiece is positive during exhalation in relation to the air pressure of the outside atmosphere and negative during inhalation in relation to the air pressure of the outside atmosphere. 2.5 Positive Pressure Respirator A respirator in which the air pressure inside the respiratory- inlet covering is positive in relation to the air pressure of the outside atmosphere during exhalation and inhalation. This document is the property of Aluminum Company of America and must be returned on request It shall not be reproduced or copied, in whole or in part or used on behalf of others than Aluminum Company or its subsidiaries, without permission. It is provided solely for the purpose of disclosing Alcoa's approach and is not intended to be a recommendation for any recipient other than Alcoa. No warranties, guarantees or representations, express or implied are made as to the utilities or effectiveness of the methods, processes, products or procedures described or recommended herein. ATC 00001 RESPIRATORY PROTECTION 18.1.1 1996 JUNE PAGE 2 OF 12 2.6 Qualified Personnel A qualified person is one who has completed a training course approved by the American Industrial Hygiene Association or NIOSH, or sponsored by an educational institution recognized for its training in the occupational health and safety areas. In lieu of formal training, a qualified person may have worked under the direction of a trained industrial hygienist and demonstrated the knowledge and understanding needed to administer the respiratory protection program. 2.7 Respirator A device designed to protect the wearer from inhalation of harmful atmospheres. 2.8 Shall Denotes a requirement. 2.9 Should Denotes a recommendation. 3.0 POLICY 3.1 Priorities or Control Methods Control of potentially harmful occupational exposures shall be accomplished as far as practical or feasible by work practices, or engineering control measures. When these methods of control are not practical or feasible, such as in emergency or demolition activities, or while they are being developed and instituted, or when use of respirators is determined to be appropriate as supplemental protection, employees' health shall be protected by the use of appropriate respirators. Alcoa shall provide respirators as needed for protecting the health of the Alcoa employee. 4.0 ELEMENTS OF A RESPIRATORY PROTECTION PROGRAM Elements of the program must be documented in a written respiratory protection program. 4.1 Written Respiratory Protection Program The Respiratory Protection Administrator shall prepare a written respiratory protection program which shall include, at a minimum, all of the provisions described in Section 4.0 of this specification. This document is the property of Aluminum Company of America and must be returned on request It shall not be reproduced or copied, in whole or in part, or used on behalf of others than Aluminum Company or its subsidiaries, without permission. It is provided solely for the purpose of disclosing Alcoa's approach and is not intended to be a recommendation for any recipient other than Alcoa. No warranties, guarantees or representations, express or implied are made as to the utilities or effectiveness of the methods, processes, products or procedures described or recommended herein. ATC 00002 RESPIRATORY PROTECTION 18.1.1 1996 JUNE PAGE 3 OF 12 4.2 Assignment of Responsibility 4.2.1 Respiratory Protection Administrator Where the use of respirators is required, a respiratory protection program shall be established which shall comply with the provisions of this specification. A Respiratory Protection Administrator shall be selected from plant safety, industrial hygiene or other qualified personnel to administer and coordinate the overall plant respiratory protection program. 4.2.2 Employee Responsibility Employees shall use the provided respiratory protection in strict accordance with the training received. They shall immediately report any respirator malfunctions to the responsible persons in their departments. 4.2.3 Program Evaluation An appraisal, including a formal self-evaluation, of the effectiveness of the respirator program shall be carried out at least annually by the Respiratory Protection Administrator. Action shall be taken to correct defects found in the program. 4.3 Respirator Selection The selection of a proper respirator for any given situation shall require consideration of the following factors: 4.3.1 Nature of Hazard The following factors concerning the nature of the hazard requiring the use of respirators shall be considered in respirator selection: 1) Type of hazard a) oxygen deficiency b) contaminant 2) Physical properties 3) Chemical properties This document is the property of Aluminum Company of America and must be returned on request It shall not be reproduced or copied, in whole or in part or used on behalf of others than Aluminum Company or its subsidiaries, without permission. It is provided solely for the purpose of disclosing Alcoa's approach and is not intended to be a recommendation for any recipient other than Alcoa. No warranties, guarantees or representations, express or implied are made as to the utilities or effectiveness of the methods, processes, products or procedures described or recommended herein. ATC 00003 RESPIRATORY PROTECTION 18.1.1 1996 JUNE PAGE 4 OF 12 4) Physiological effects on the body. 5) Actual or potential concentration of a toxic material a) Average b) Peak 6) Established permissible exposure limits, i.e. 8 hour time-weighted average, short term, ceiling or peak. 7) Whether the hazard is an immediately dangerous to life or health concentration of a toxic material. 8) Warning properties. 4.3.2 Location of Hazardous Area The location of the hazardous area with respect to a safe area having respirable air shall be considered in selecting a respirator, since this will permit planning for the escape of workers if an emergency occurs, for the entry of workers to perform maintenance duties, and for rescue operations. 4.3.3 Duration of Respirator Use The period of time that a respirator must be worn is an important factor that shall be taken into account in selecting a respirator. Consideration shall be given to the type of respirator application, such as for routine, nonroutine, emergency, or rescue use. It would not be desirable, for example, to select respirators that are heavy or that offer high resistance to breathing for routine wearing for many hours each day. 4.3.4 Respirator Characteristics The physical characteristics, the functional capabilities, and the performance limitations of the various types of respirators shall be considered in selecting a respirator. 4.3.5 Assigned Protection Factor The expected workplace level of respiratory protection that would be provided by a properly functioning respirator or a class of respirators to properly fitted This document is the property of Aluminum Company of America and must be returned on request It shall not be reproduced or copied, in whole or in part, or used on behalf of others than Aluminum Company or its subsidiaries, without permission. It is provided solely for the purpose of disclosing Alcoa's approach and is not intended to be a recommendation for any recipient other than Alcoa. No warranties, guarantees or representations, express or implied are made as to the utilities or effectiveness of the methods, processes, products or procedures described or recommended herein. ATC 00004 RESPIRATORY PROTECTION 18.1.1 1996 JUNE PAGE 5 OF 12 and trained users. Multiplying the permissible exposure limit or ceiling concentrations,, whichever is applicable, by the assigned protection factor gives the maximum concentration of the contaminant for which the respirator should be used. This calculated concentration may not exceed concentration limits established by the manufacturer or the respirator approval agency. 4.3.5.1 Workplace Protection Factor An experimentally determined measure of protection afforded by a respirator under conditions of use. It is defined as the ratio of the concentration of airborne contaminant outside the respirator to the concentration inside the respirator as measured during actual use situations. 4.3.5.2 Fit Factor The ratio of the concentration of airborne contaminant outside the respirator to the concentration inside the respirator determined under laboratory conditions. A protection factor is a selection and use guide, and should only be used in conjunction with the selection criteria outlined in this specification and the advice of the Respiratory Protection Administrator. (See Table 1, 18.1.1 for list of respirator protection factors.) 4.3.6 Approved Respirators Approved respirators shall be used when they are available. Any modification that is not authorized by the approval agencies of an approved respirator voids the approval. 4.3.7 Workplace Environmental Measurements Selection of a proper respirator should be based on the concentration of the respiratory hazard as measured in the work area, or anticipated potential concentration, as determined by Respiratory Protection Administrator. Air samples should be collected periodically during respirator use to ensure that continued use of the selected respirator remains appropriate. (See Alcoa Industrial Hygiene Manual, Chapter 11, for exposure monitoring guidelines). This document is the property of Aluminum Company of America and must be returned on request. It shall not be reproduced or copied, in whole or in part, or used on behalf of others than Aluminum Company or its subsidiaries, without permission. It is provided solely for the purpose of disclosing Alcoa's approach and is not intended to be a recommendation for any recipient other than Alcoa. No warranties, guarantees or representations, express or implied are made as to the utilities or effectiveness of the methods, processes, products or procedures described or recommended herein. ATC 00005 RESPIRATORY PROTECTION 18.1.1 1996 JUNE PAGE 6 OF 12 4.4 Training The supervisor, the person issuing respirators, and the respirator wearers shall be given adequate training by a qualified person(s) to ensure the proper use of respirators. 4.4.1 Training Content To ensure the proper and safe use of a respirator, the minimum training of each respirator wearer shall include the following elements: 1) The reasons for the need of respiratory protection. 2) The nature, extent, and effects of respiratory hazards to which the person may be exposed. 3) An explanation of why engineering controls are not being applied or are not adequate and of what effort is being made to reduce or eliminate the need for respirators. 4) An explanation of why a particular type of respirator has been selected for a specific respiratory hazard. 5) An explanation of the operation, and the capabilities and limitations of the respirator selected. 6) Instruction in inspecting, donning, checking the fit of, and wearing the respirator. 7) An opportunity for each respirator wearer to handle the respirator, learn how to don and wear it properly, check its seals, wear it in a safe atmosphere. 8) An explanation of how maintenance and storage of the respirator is carried out. 9) Instructions on how to recognize and cope with emergency situations. 10) Instructions as needed for special respirator use. 11) Regulations concerning respirator use. This document is the property of Aluminum Company of America and must be returned on request It shall not be reproduced or copied, in whole or in part or used on behalf of others than Aluminum Company or its subsidiaries, without permission. It is provided solely for the purpose of disclosing Alcoa's approach and is not intended to be a recommendation for any recipient other than Alcoa. No warranties, guarantees or representations, express or implied are made as to the utilities or effectiveness of the methods, processes, products or procedures described or recommended herein. ATC 00006 RESPIRATORY PROTECTION 18.1.1 1996 JUNE PAGE 7 OF 12 4.4.2Refresher Training Refresher training shall be conducted at least on an annual basis for all respirator wearers. The content of the training may vary depending on the frequency of respirator use and type of respirator worn. As a minimum, training shall include proper donning procedures, maintenance and care of assigned respirators, the hazards for which the respirators are assigned, and the limitations of the respirators used. 4.5 Medical Evaluation A physician shall determine what physiological conditions are pertinent for the wearing of different types of respirators, and whether or not a person may be assigned to a task requiring the use of a respirator. This determination shall be made, reviewed or evaluated with a frequency which meets applicable regulations, Alcoa Medical Protocol B-25 and local plant practices and policies. 4.6 Fit-Testing Each wearer of a tight-fitting face piece respirator shall pass a qualitative or quantitative fit-test to assure satisfactory fit on an annual basis. Each respirator wearer shall be required to check the seal of the respirator by appropriate means prior to entering a potentially hazardous atmosphere. Note: Fit testing on a more frequent basis may be required by specific regulations. 4.6.1Test Method A qualitative or quantitative respirator fit test shall be used to determine the ability of each individual respirator wearer to obtain a satisfactory fit with all respirators which have tight-fitting face pieces, both positive and negative pressure. The results of qualitative or quantitative fit tests shall be used to select specific types, makes, and models of respirators used by individual respirator wearers. For tight fitting face-pieces used for positive pressure respirators, a fit factor of 100 by quantitative fit test or passing a qualitative fit test assures that there is a good fit of the face-piece. Increased assigned protection factors are applied based on continuous positive pressure within the face-piece, relative to outside the face-piece. Quantitative fit test protocols used shall insure a fit factor of at feast 10 times the assigned protection factor. Qualitative protocols used shall follow validated This document is the property of Aluminum Company of America and must be returned on request It shall not be reproduced or copied, in whole or in part, or used on behalf of others than Aluminum Company or its subsidiaries, without permission. It is provided solely for the purpose of disclosing Alcoa's approach and is not intended to be a recommendation for any recipient other than Alcoa. No warranties, guarantees or representations, express or implied are made as to the utilities or effectiveness of the methods, processes, products or procedures described or recommended herein. ATC 00007 RESPIRATORY PROTECTION 18.1.1 1996 JUNE PAGE 8 OF 12 procedures. The tests shall be designed to assess fit factors 10 times greater than the assigned protection factor. Quantitative fit testing is recommended whenever a full face-piece respirator, in negative pressure mode (e.g., Air Purifying), is used for protection greater than 10X PEL or if exposures could exceed 10X PEL. (Refer to 29 CFR 1910, Appendix D to 1910.1025 "Qualitative Fit Test Protocols" for currently acceptable qualitative fit test protocols which can be followed. These protocols are subject to revision.) 4.6.2 Facial Hair A respirator equipped with a facepiece shall not be worn if facial hair comes between the sealing periphery of the facepiece and the face or if facial hair interferes with valve function. 4.7 Respirator Maintenance Respirator maintenance and inspection shall be performed regularly. Maintenance shall be carried out on a schedule which ensures that each respirator wearer is provided with a respirator that is clean and in good operating condition. 4.7.1 Cleaning and Sanitizing Each respirator shall be cleaned and sanitized to ensure that the respirator wearer is provided with a clean and sanitized respirator at all times. A respirator issued for other than continuous personal use by a particular worker, such as with routine, non-routine, emergency, or rescue use, shall be cleaned and sanitized after each use. 4.7.2 Inspection Each respirator shall be inspected routinely before and after use. A respirator shall be inspected by the user immediately prior to each use to ensure that it is in proper working condition. After cleaning and sanitizing, each respirator shall be inspected to determine if it is in proper working condition, if it needs replacement of parts or repairs, or if it should be discarded. In addition to inspection before and after each use, each respirator stored for emergency or rescue use shall be inspected at least monthly. Respirator inspection shall include a check for tightness of connections; for the condition of the respiratory-inlet covering, head harness, valves, connecting tubes, harness assemblies, filters, cartridges, canisters,- end-of-service life indicator, and shelf life date(s); and for the proper function of regulators, alarms, and other warning systems. This document is the property of Aluminum Company of Amenca and must be returned on request It shall not be reproduced or copied, in whole or in part, or used on behalf of others than Aluminum Company or its subsidianes. without permission. It is provided solely for the purpose of disclosing Alcoa's approach and is not intended to be a recommendation for any recipient other than Alcoa. No warranties, guarantees or representations, express or implied are made as to the utilities or effectiveness of the methods, processes, products or procedures described or recommended herein. ATC 00008 RESPIRATORY PROTECTION 18.1.1 1996 JUNE PAGE 9 OF 12 Each rubber or other elastomeric part shall be inspected for pliability and signs of deterioration. Each air and oxygen cylinder shall be inspected to ensure that it is fully charged according to the manufacturer's instructions. A record of inspection dates, findings, and remedial actions shall be kept for each respirator maintained for emergency or rescue use. 4.7.3 Repair Replacement of parts or repairs shall be done only by persons trained in proper respirator assembly and correction of possible respirator malfunctions and defects. Replacement parts shall be only those designed for the specific respirator being repaired. Reducing or admission valves, regulators, and alarms shall be returned to the manufacturer or to a trained technician for repair or adjustment. Instrumentation for valve, regulator, and alarm adjustments and tests must be approved by the valve, regulator, or alarm manufacturer. 4.7.4 Storage Respirators shall be stored in a manner that will protect them from dust, sunlight, heat, extreme cold, excessive moisture, or damaging chemicals. Respirators shall be stored to prevent distortion of rubber or other elastomeric parts. Respirators shall not be stored in such places as lockers and tool boxes unless they are protected from contamination, distortion, and damage. Emergency and rescue-use respirators that are placed in work areas shall be quickly accessible at all times. The storage cabinet or container in which they are stored shall be clearly marked. 4.8 Recordkeeping Records shall be maintained by the Respiratory Protection Administrator or their designee as part of the overall respiratory protection program. 4.8.1 Types of Records Recordkeeping requirements will vary greatly with the complexity of a location's use of respirators. The following represents a minimum requirement: 1) Employee training session outlines and attendance records. 2) Results of fit-test. This document is the property of Aluminum Company of America and must be returned on request It shall not be reproduced or copied, in whole or in part or used on behalf of others than Aluminum Company or its subsidiaries, without permission. It is provided solely for the purpose of disclosing Alcoa's approach and is not intended to be a recommendation for any recipient other than Alcoa. No warranties, guarantees or representations, express or implied are made as to the utifities or effectiveness of the methods, processes, products or procedures descnbed or recommended herein. ATC 00009 RESPIRATORY PROTECTION 18.1.1 1996 JUNE PAGE 10 OF 12 3) Medical acceptance or rejection of an employee's use of respirators on his/her job. 4) Reports of monthly inspections of emergency use respirators. 4.8.2 Record Retention Records required under this section shall be maintained for at least 40 years, or for the duration of employment plus 30 years. 5.0 QUALITY OF RESPIRABLE AIR 5.1 Specifications for Respirable Air Compressed air and liquid air, used for respiration shall be of high purity. Breathing air shall meet at least the requirements of the specification for Grade D breathing air as described in Commodity Specification CGA G-7.1. This currently requires that the carbon monoxide level not exceed 10 ppm, the carbon dioxide content not exceed 1000 ppm, the condensed hydrocarbons (oil mist) not exceed 5 mg/m3, and there be no pronounced odor. 5.2 Compressed Air Breathing air may be supplied to respirators from cylinders or air compressors. A breathing-air type compressor shall be used. A compressor shutoff alarm and suitable in-line air purifying sorbent bed and filters to assure breathing air quality shall also be incorporated into the system. An air-storage receiver shall also be provided to furnish the wearer with an adequate supply of escape air if the compressor fails to operate. In addition, compressor air intakes shall be situated so as to avoid the entry of contaminated air into the system. If an oil-lubricated compressor is used, it shall have a high temperature or carbon monoxide alarm, or both. If only a high temperature alarm is used, the air from the compressor shall be frequently tested for carbon monoxide to ensure that it meets the specifications for respirable air. The contents of compressed air cylinders used to provide the air supply for an airline respirator shall be tested for oxygen concentration and carbon monoxide content. The air supply in the cylinder shall be sufficient to permit completion of the work and escape. This document is the property of Aluminum Company of America and must be returned on request It shall not be reproduced or copied, in whole or in part or used on behalf of others than Aluminum Company or its subsidianes. without permission. It is provided solely for the purpose of disclosing Alcoa's approach and is not intended to be a recommendation for any recipient other than Alcoa. No warranties, guarantees or representations, express or implied are made as to the utilities or effectiveness of the methods, processes, products or procedures described or recommended herein. ATC 00010 RESPIRATORY PROTECTION 18.1.1 1996 JUNE PAGE 11 OF 12 6.0 BIBLIOGRAPHY 1) Occupational Safety and Health Act (OSHA) 29 CFR 1910.134. Federal Register, Oct. 18,1972. 2) American National Standard Practices for Respiratory Protection, ANSI Z88.2, Latest Edition. 3) Basic Elements of Respiratory Protection. Mine Safety Appliances Company, Latest Edition. 4) Fundamentals of Industrial Hygiene. J. B. Olishfski and F. E. McElray National Safety Council, 1971. 5) A Guide to Industrial Respiratory Protection, NIOSH Technical Information. U.S. Dept, of HEW - Latest Edition. 6) Respiratory Protection - A Manual and Guideline American Industrial Hygiene Association, Latest Edition 7) Industrial Hygiene Field Operations Manual Volume VI, OSHA 3058 U.S. Department of Labor, Latest Edition. 8) . Alcoa Industrial Hygiene Manual (August 1990) Chapter 11. 9) Occupational Safety and Health Act (OSHA) - 29 CFR 1910, Appendix D to 1910.1025. 10) Compressed Gas Association Commodity Specifications for Air CGA G-7.1 This document is the property of Aluminum Company of America and must be returned on request It shad not be reproduced or copied, in whole or in part, or used on behalf of others than Aluminum Company or its subsidiaries, without permission. It is provided solely for the purpose of disclosing Alcoa's approach and is not intended to be a recommendation for any recipient other than Alcoa. No warranties, guarantees or representations, express or implied are made as to the utilities or effectiveness of the methods, processes, products or procedures described or recommended herein. ATC 00011 RESPIRATORY PROTECTION 18.1.1 1996 JUNE PAGE 12 OF 12 ASSIGNED PROTECTION FACTORS (a) Type of Respirator Air Purifying Atmosphere Supplying: SCBA (demand) (c) Air Line (demand) NEGATIVE PRESSURE RESPIRATORS Respiratory Inlet Covering 1/4 Mask Half Mask (b) 5 10 . 10 - 10 Full Facepiece 50 50 50 Type of Respirator Powered Air Purifying Atmosphere Supplying: Air Line Pressure Demand Air Line Continuous Flow Self Contained Breathing Apparatus (d): Pressure Demand Open/Closed Circuit POSITIVE PRESSURE RESPIRATORS Half Mask Respirator Inlet Covering Loose Full Face Helmet/Hood Fitting Facepiece 50 250 25 25 50 1000 - - 50 1000 25 25 - >1000 - - TABLE 1,18.1.1 a) These assigned protection factors are intended to be maximum values used by Alcoa facilities. Whenever local regulations require more stringent APF, lower numbers should be used. b) Includes disposable half masks and half masks with elastomeric facepieces. c) Demand SCBA shall not be used for emergency situations such as fire fighting. d) Although positive pressure respirators are currently regarded as providing the highest level of respiratory protection, a limited number of recent simulated workplace studies concluded that all users may not achieve protection factors of 10,000. Based on this limited data, a definitive assigned protection factor could not be listed for positive pressure SCBA's. For emergency planning purposes where concentrations can be estimated, an assigned protection factor of no higher than 10,000 should be used. Note: Assigned protection factors are not applicable for escape respirators. For combination respirators e.g. air line respirators equipped with an air purifying filter, the mode of operation in use will dictate the assigned protection factor to be named. This document is the property of Aluminum Company of America and must be returned on request It shall not be reproduced or copied, in whole or in part or used on behalf of others than Aluminum Company or its subsidiaries, without permission. It is provided solely for the purpose of disclosing Alcoa's approach and is not intended to be a recommendation for any recipient other than Alcoa. No warranties, guarantees or representations, express or implied are made as to the utilities or effectiveness of the methods, processes, products or procedures described or recommended herein. ATC 00012