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ROCKDALE WORKS PLAINTIFF'S I EXHIBIT AL- 6 7 T0 MANAGERS AND SUPERINTENDENTS ROCKDALE WORKS 1983 July 14 RE: INDUSTRIAL HYGIENE TECHNICAL BULLETIN - ASBESTOS EXPOSURES We recently received the attached Industrial Hygiene Bulletin dealing with asbestos exposure. Rockdale's practices for handling asbestos conform to the policies set forth. However, there is one area where additional sampling will be required. That area is in the automotive repair shop when employees are working with brake linings. As soon as it can be scheduled, we will be conducting tests to determine employee exposures when this work is being done. If you know of other areas where work is needed, please let me know. E. OKUUKJ EBP/mz Attachment cc: (without attachment) A. G. Clayton J. E. Richter 0 ALCOA ARD 003721 SF-4S63 (rev n-6e) E. E. RUMBERGER PITTSBURGH OFFICE TO 1983 June 15 RE: ASBESTOS EXPOSURE AND POTENTIAL HEALTH HAZARD Ref: I.H. Technical Bulletin No. 83-3 (Attached) The need for greater control over potential exposures to asbestos is becoming more apparent. The attached Technical Bulletin, prepared by Joan Sander, outlines Alcoa's new policy on exposure levels and industrial hygiene precautions, and reiterates the Medical Department's program for medical surveillance. Specific requirements are triggered by the Action Level, defined as 0.1 fiber/cc, and the new Alcoa Permissible Limit of 0.5 fibers/cc. At these relatively low concentration levels, the analytical method (P&CAM 239-asbestos fiber count) lacks a high level of precision due to inherent inaccuracies associated with the method. Therefore, a sampling strategy based on several samples should provide a characterization of job tasks, rather than basing decisions on a single sample. Likewise, professional judgment is advised for interpretation of results. Please call upon the Corporate Industrial Hygiene staff for assistance in this area. Due to the serious health concerns associated with asbestos exposures, all potential exposures to asbestos fibers must be eliminated or controlled to the Alcoa Permissible Limit. Employee training, medical surveillance, routine air monitoring, and personal protective equipment are essential elements of such a control program. Please let us know if we can provide assistance with any aspect of asbestos replacement or control. . E. E. RUMBERGER EER/eds Attachment Distribution: I.H. Mailing List I.H. Plant Contacts Industrial Hygienists - International I.H. Division - Pittsburgh & ATC I.H. Technicians Pittsburgh & ATC - General ARD 003722 Industrial Hygiene Technical Bulletin No. 83-3 Date: 1983 June 15 RE: ASBESTOS EXPOSURES Due to the very serious nature of asbestos exposure hazards, a closer look was taken at our policies and procedures for controlling such ex posures. Starting in 1978, Alcoa implemented an Asbestos Replacement Program with the objective of making our operations as free of asbestoscontaining materials as possible. While the program has met with con siderable success, there are still some applications where acceptable substitutes have not been found. Likewise, we currently have numerous applications where asbestos products were used in past construction and are still In place. This situation may pose a potential health hazard In the event that asbestos-containing materials become capable of fiber release (i.e. due to deterioration, water damage, etc.), or during ren ovation or demolition activities. The purpose of this technical bulletin is to clarify Alcoa's policy and procedures for job tasks Involving exposures to asbestos fibers. It ap plies to both renovation or demolition of asbestos-containing materials, as well as routine or repetitive job tasks Involving asbestos exposures. Attached please find a one page flow chart entitled "Asbestos Exposure Procedures" which summarizes the requirements outlined in the following text based upon job activity and air monitoring data. I. DEFINITIONS A. "Asbestos fiber" means a fibrous form of asbestos longer than 5 microns with a length-to-diameter ratio of at least 5 to 1, and with a maximum diameter of 3 microns. B. "Friable asbestos" means any material that contains more than 1% asbestos by weight and that can be crumbled, pulverized, or reduced to powder by hand pressure when dry. C. "Action Level" is defined as 0.1 fibers/cc (8 hour TWA). Med ical surveillance, air monitoring and employee training require ments are triggered at the action level. D. "Alcoa Permissible Limit (APL)" is defined as 0.5 fibers/cc (8 hour TWA). Respiratory protection Is required when exposures may exceed the APL. Likewise, a respiratory protection program (employee training, fit testing, medical approval, etc.) must be implemented. E. "Routine or Repetitive Job Tasks" means employees engaged in work activities involving exposures to asbestos fibers on an average frequency of an 8 hour shift per month or greater. (Ex amples Include working with marinlte headers, trough linings, thermocouple wire, brake lining, etc.). 0 ALCOA ARD 003723 Industrial Hygiene Technical Bulletin 1983 June 15 Page 2 F. 'Renovation or Demolition" means those activities involving the removing, stripping, wrecking, or taking out of friable asbestos from any structural member. (Examples include removing asbestos pipe insulation, furnace tearouts, etc.). II. JOB CLASSIFICATIONS A. Routine or Repetitive Job Tasks. The industrial hygienist should assess alj_ Job tasks Involving routine or repetitive exposures to asbestos fibers. (Examples given in Definitions section.) Industrial hygiene sampling for asbestos should be performed if such is not already the case. If asbestos concentrations are below the action level, and you are not relying on engineering controls (i.e. local exhaust) to reduce the airborne concentration, no further action is required, pending process or product changes that might potentially in crease the airborne fiber concentrations. Areas relying on en gineering controls to reduce airborne asbestos fibers should be sampled at least annually to evaluate the effectiveness of the controls. If exposure levels are between the action level and APL, employees must be trained in the safe handling of asbestos and receive medical surveillance. Routine monitoring should be performed on a 6 month basis. When exposures are found to equal or exceed the APL, the procedures mentioned above as well as respiratory protection will be required. Disposable protective clothing may also be necessary. B. Renovation or Demolition Job Tasks. Typically, maintenance tasks involving renovation or demolition activities represent likely potential excessive exposures. The prudent course for such job tasks would be to automatically im plement the appropriate precautionary measures: (1) medical sur veillance, (2) respiratory protection, (3) employee training and (4) protective clothing (as necessary). Wherever possible, wet down the material to be removed to minimize dust. Do not use water if electrical or other hazards exist (i.e., water on phos phorous-containing refractories may result in phosphine gas formation). The following sections offer supporting detail concerning re quired industrial hygiene safeguards when working with asbestoscontaining materials. III. REQUIREMENTS A. Medical Surveillance. Employees exposed above the action level on an average fre quency of one eight hour shift per month or greater will re- ARD 003724 Industrial Hygiene Technical Bulletin 1983 June 15 Page 3 celve an annual medical examination. This periodic evaluation will Include a questionnaire to elicit the symptomatology of respiratory disease, pulmonary function tests (FVC and FEVi.o), and a chest roentgenogram. Employees should be notified of any abnormalities within 30 days of such a finding by the evaluating physician. B. Employee Training All employees exposed to asbestos concentrations above the action level shall receive annual training in the proper handling of asbestos. This program should Include an ex planation of the following: (1) The requirements outlined in this bulletin. (2) Hazardous properties of asbestos. (3) Work practices and engineering controls utilized to ' reduce exposures. (4) Safe work procedures for handling asbestos-containing materials. (5) The effectiveness of personal protective equipment. Attendance at such training sessions should be documented and filed appropriately. C. Air Monitoring All tasks involving potential exposures to asbestos require baseline sampling. Routine air monitoring should be contin ued on a six month basis for routine or repetitive job tasks with asbestos concentrations at or above the action level. If exposure levels are found to be below the action level, air monitoring should be performed if process or product changes occur which might potentially increase the airborne fiber concentrations. If reliance on engineering controls is necessary to reduce exposures below the action level, annual monitoring should be performed to evaluate the effectiveness of the controls. D. Respiratory Protection Respirators are required of anyone performing a job task whose potential exposure to airborne asbestos fibers may exceed the APL. This would include all demolition/renovation activities, and may include routine or repetitive job tasks, depending upon industrial hygiene sampling data. For exposures up to 10 fibers/cc, the following NIOSH approved respirators are acceptable for protection against asbestos fibers: ARD 003725 Industrial Hygiene Technical Bulletin 1983 June 15 Page 4 3M 8710, 9900, 9910 or 9920 AO R1070 Willson 1410 MSA Comfo II with Type F Filter Exposures in excess of 10 fibers/cc require the use of a NIOSH approved powered air purifying respirator, or a type "C" sup plied air respirator. While the Alcoa Permissible Limit determines the requirement for respiratory protection, disposable respirators should be made available to all employees with potential asbestos exposure who desire to wear them, regardless of their levels of exposure. When respiratory protection is used, a respirator program in compliance with Alcoa Engineering Standard 18.1.1 must be es tablished and implemented. Annual fit-testing and training, medical approval, NIOSH approved respirators, and written SOP's should be included with this program. E. Protective Clothing The area of protective clothing (disposable garments) is best left up to the judgement of the plant industrial hygienist after an assessment of the job task and its associated dust exposures have been made. For demolition or renovation activities in which there is a considerable amount of dust generation, or when fibers may accumulate on work clothing, disposable protective clothing is warranted and required. All contaminated protective clothing, as well as respirators, should be disposed of as asbestos-containing material. F. EPA Requirements The Clean Air Act regulates removal, cleanup, and disposal of asbestos material under certain circumstances: (1) the mate rial is "friable asbestos", and (2) asbestos is removed from renovation or demolition work, and (3) asbestos material quantity is greater than 260 linear feet of pipe covering and 160 ft2 from other sources. If only the first two considerations exist, only notification procedures are required. If all three conditions exist, Clean Air Act Regulations Subpart B, Parts 61.22(d), (i), (j), (1) must be followed. Contact the Plant Environmental Control Department for assistance with the above. IV. ALCOA'S ASBESTOS REPLACEMENT PROGRAM Alcoa's Asbestos Replacement Program was instituted in 1978 with the objective of making our plants as free of asbestos materials as possible. Suitable replacements for most, but not all, asbes- ARD 003726 Industrial Hygiene Technical Bulletin 1983 June 15 Page 5 tos products have been found. Efforts to find replacements for the remaining applications will continue. It is imperative that accurate records be kept to identify areas where asbestos-containing materials are being used, or have been used in past construction. To minimize potential health hazards associated with renovation or demolition of asbestos products, all maintenance projects should be reviewed for potential asbes tos exposures prior to starting the job. If asbestos is suspected, the material should be treated as such unless laboratory analysis confirms otherwise. Samples of bulk material can be analyzed by Alcoa's Environmental Health Laboratory. Asbestos materials in good condition which do not represent likely exposures should not be removed simply because they contain asbes tos since doing so may present a greater hazard during the actual removal. However, a routine inspection program of the material should be implemented to Insure that the situation does not change. If you have any questions concerning the above, please do not hesitate to contact me. JOAN E. SANDER JES:sc Distribution: I. H. Distribution List I. H. Plant Contacts Industrial Hygienists - International I. H. Division - Pittsburgh & ATC I. H. Technicians Pittsburgh & ATC - General ARD 003727 ASBESTOS EXPOSURE PROCEDURES Job| Activity Routine/Repetitive Renovation/Demolition *--------- 1~< AL --Air Monitoring-- AU&APL ^>APL Rely On Engineering Controls? Y|S Monitor On Annual Basis NO 4 No Further Action Unless Product Or Process Change Medical Surveillance Respiratory Protection Routine Monitoring ( 6 Mo. Basis) Protective Clothing (As Necessary) Employee Training EPA Notification Procedures (Contact Envtl. Control Engr.) Medical Surveillance (Avg. Freq8 Hr. Shift/Mo.) Employee Training Respiratory Protection Protective Clothing (As Necessary) ARD 003728 AL (Action Level) 88 0.1 Fibers/cc TWA APL (Alcoa Permissible Limit) 88 0.5 Fibers/cc TWA Disposal Requirements (Contact Envtl. Control Engr.)