Document kad1j1omYvwNo4pZamOpjggNJ
Reply to Lee v MSA et al Interrogatory of August 1989
Interrogatory |8_ From 1976 to present, please state the types, models and serial numbers of all single-use disposable respirators, half-mask dust respirators and air-fed hood respirators along with the manufacturer and vendor of each, that were purchased by Shell and provided tD independent contractors or Shell employees involved in sandblasting operations on the premises.
Answer To our knowledge no respiratory protection of any type were routinely provided to independent contractors engaged in sandblasting at the Deer Park Manufacturing Complex from 1976 to present. Independent contractors performing sandblasting have been expected to provide their own equipment including respiratory protection.
Respiratory protective devices purchased and soley supplied to Shell employees engaged in sandblasting include:
3M 9920 dust masks MSA 1/2 mask and Scott 1/2 mask respirators with high
efficiency filters Me Donald air fed hood Cesco air fed hood. Encon sandblast hood E.D. Bullard 77-sh-ml (used since 1987)
Interrogatory t>9 From 1972 to present, please state the dates of all air sampling tests which were taken at the Shell Oil and Chemical plant refinery for the purpose of monitoring ambient-free silica during any on-site sandblasting operation. Specifically, please state the date of each test, the person who carried out the test(s) and the identity of the locations where the tests were taken.
Air sampling was conducted within the Deer Park Manufacturing Complex on the following occasions:
September 1974 Survey of Shell sandblasters at the Refinery sandblast yard by David Atwood (Shell Industrial Hygienist).
October 1975 Survey of Shell sandblasters at the Refinery sandblast yard by Jerry Ransdell (Shell Industrial Hygienist).
November 1975 Air sampling done by J.D. Ransdell, Shell Industrial Hygienist
LAM 016390
DPMC-13135
Various monitoring 1976 Monitoring conducted in January, November and December
October 1978 Survey of non-silica grit silica exposure by G.L. Buchanan, Shell Industrial Hygiene Assistant to verify that silica exposure did not exist
Interrogatory IIP From 1972 to present, did Shell Oil Company establish and/or implement written standard operating procedures for the selection and use of respirators for any person involved in sandblasting operations while on the premises of the Shell Chemical & Oil Plant? If so, please state:
a) The datels) these guidelines were established b) The datels) they were changed or modified, and c) The identity of all persons responsible for promulgating
such procedures and/or guidelines.
Answer Written operating procedures for the selection and/or use of sandblasting respirators by Shell employees have been established for many years. When revised, the original document typically has not been retained.
Only "approved" blasting hoods were reportedly used by Shell sandblasters at the Deer Park Manufacturing Complex. A change in hoods was made in 1975 following an Industrial Hygiene study conducted by D.P. Atwood.
Date
Procedure/Document
Author
1976 1978 1978
i9eo
1984
19e4
1984
1986
Silica Safety Bulletin Respirator Safety Order Silica Safety Bulletin #2 Respirator Safety Order Guideline for Inorganic
Lead and/or Chromate Exoosure Potential Reauirements established
for A322 tank job Guidelines for Blastinq
Inside Tanks Respirator Safety Order
Health it Safety Dept. Health & Safety Dept Health !c Safety Peg*. Health h Safety Dept
Health ?< Safetv Deot Health & Safety Dept
Health & Safety Dept
Health & Safetv Dept
( Copies are provided for those underlined )