Document mEZnq2JY9orLk0Eg2XVw39Jg

FILE NAME: Kelly Moore (KM) DATE: 1976 Mar 18 DOC#: KM028 DOCUMENT DESCRIPTION: Letter from Liberty Mutual to KM with Attached Asbestos Survey Report March IS, 1976 Hr. Luis Garcia Plant Superintendent Kelly - Moore Paint Company 3600 East 45th Avenue Denver CO 80216 PE: Asbestos Survey Report Dear MT. Garcia: Enclosed is your copy of the asbestos survey report conducted January 15, 1976. Per our conversation, you isdieatsd that this department vill probably shut down all operations effective April 1, 1976. Should a change be made in this decision the four reccesnsadations reasin applicable and should receive inmediata attention. Sincerely yours, 8G:v cc: William E. Moore, President Ted Geasner, Secretary-Treasurer Robert Miller, Vice President - Production Wesley^M. Goodsesa Sr. loss Prevention Representativa KM 01127 I PLAINTIFF'S t EXHIBIT I fsyll LIBERTY MUTUAL INSURANCE COMPANY LIBERTY MUTUAL FIRE INSURANCE COMPANY LIBERTY U FE ASSURANCE COMPANY OF BOSTO HOME OFFICES: BOSTON EQUAL OPPORTUNITY EMPLOYERS / MRR 2 2 ASBESTOS SURVEY KELLY-MOORE, INC. DENVER, COLORADO Date of Survey; January 1 5 , 1976 Date of Report: March 10, 1976 Report Prepared by: Bill Lutts Asst. Southwest Div. Industrial Hygienist KM BB 5641 KELLX-MOORE, INC. DENVER, COLORADO DRY VALL MIXING AREA Date of Surrey: January 15, 1976 Date of Report: March 10, 1976 Material Sampled: Airborne Asbestos Fibers 0 Analysis Method: Phase-Contrast Micorscope Recommended Engineering Control Limit: 2 fibers greater than 5 microns in length/ml. Location 1. Middle of workroom. Breathing zone height. Pump fixed on center support column. R0 minutes sampling during batch mix. . 2. Second sample under same conditions as #1 above. 3. Personal sample. H-O minutes sampling time during mixing cycle, operator's breathing zone. k. Same conditions as #3 above. Fibers/ml 5 3 1 2 -6KM BB 5646 ASBESTOS SURVEY KELLY-MOORE, INC. DENVER, COLORADO INTRODUCTION A survey was made for airborne asbestos fibers in the dry wall products mixing area at Kelly-Moore,Inc., Denver, Colorado, on January 15 1976. The purpose of the survey was to measure the presence and quantity of airborne asbestos fibers greater than five microns in length. The shorter fibers are not considered as an asbestos hazard, but rather as a category of free silica exposure. The recommended engineering control limit for asbestos fibers at present is 2 fibers per milliliter (per cubic centimeter) of workroom air for a normal work day and work week exposure. A total of four samples was taken with two pumps. One pump was mounted on the one man working in the dry wall area and the other pump was mounted on the center column of the room and measured the overall asbestos content of the air away from the ribbon mixers. The samples were taken open face at a rate of 2 liters per minute for ^0 minutes and a blank tas submitted with the exposed filters as a control. CONCLUSIONS The two samples taken on the mixing operator indicates that his exposure is less than or equal to the recommended engineering control limit during a mixing cycle. This result is not surprising since the ventilation system on the ribbon mixers where the bags are opened and emptied is doing an excellent job. In light of the relatively low exposure of the operator, the general room air results are surprisingly high. -2KM BB 5642 An analysis of the sample taken in the center of the room at breathing zone height indicates that the number of asbestos fibers in the workroom air is greater than the recommended engineering control limit of 2 fibers per milliliter. Readings of 5 fibers per milliliter and three fibers per milliliter were obtained on each of the two +0 minute sampling runs. Measurements of the general room air flow were also made during the sample period and indicated that air was flowing in from the paint mixing area and out through the door which leads to the warehouse storage area. Given the operator's low exposure the only reasonable explanation for the difference in results is that the dust collector system beside the door which leads to the main paint mixing area is leaking or emitting fibers in some way and the general room air flow is then carrying them through the very region where we took the general room air sample. The low results obtained on the operator, who is the only man exposed in the room, indicates that the local exhaust ventilation system is performing properly at the source of contaminant. Therefore, assuming that our results give a true picture of the situation, the collector end of the exhaust ventilation system should be carefully checked for places where asbestos fibers might be escaping into the general room air. RECOMMENDATIONS 76-1. A collection barrel is located beneath the dumping chute of the main dust collector bin. There is several inches of clearance between the bottom opening of this bin and the top of the collection barrel. It would be advisable to connect the bin and the barrel with a plastic sleeve which would prevent the release of asbestos fibers into the room air when the collection bin is dumped into the collection barrel. In addition, this would reduce the possibility that a leak in the bottom bin opening, or the residual fibers in the barrel itself, is a source of room contamination. -3- KM BB 5643 76-2. Care should be taken to make sure that asbestos bags are not included in the compactor presently in use. One bag had inadvertently been placed in the compactor at the time of our visit. The operator demonstrated the normal disposal procedures and indicated that this particular bag had been placed there in error by another employee. Given the proximity of the compactor to the center post where we took the general room sample, it is possible that this single asbestos bag contributed significantly to the total fiber levels detected. 76-3. The duct work of the dust collection system should be carefully checked to make sure that there are no leaks emitting asbestos fibers and dust into the work room air. A visual inspection at the time of our visit did not reveal any leaks. But, this is one possible explanation of the high detected levels which should be investigated. 76-b, Operators in this area should continue to wear their personal protective equipment until such time as the effectiveness of the engineering controls are fully verified. The respirators presently in use are approved for asbestos fibers and pneumoconiosis producing dusts. THE SURVEY The four samples taken were collected in the standard manner using two personal sampling pumps. A flow rate of 2 liters per minute was used. A sampling period of ho minutes per sample was used. The samples were taken with the cassettes open-face and pointed downward to prevent unwanted trash from settling on them. -b - KM BB 5644 One pump was mounted directly on the operator of the ribbon mixer and a total of two samples was taken with this pump. The other personal sampling pump was mounted in the center of the room at breathing zone height and two samples were taken on this pump also. More than two samples per pump might have been taken except that the mixing operations for that dajs workload had come to an end with the conclusion of the second set of samples. The collected samples were then submitted to our Industrial Hygiene laboratory at Hopkinton, Massachusetts. They were analyzed there by means of a phase-contrast microscope. A visual counting method was used to determine the number of fibers greater than 5 microns in length collected during the sampling period. This total sample volume collected and the total number of fibers present allowed the determination of fibers per milliliter to be determined. A recommended engineering control limit of 2 fibers per milliliter is suggested in this report. BL:jl Bill Lutts Asst. Southwest Division Industrial Hygienist KM BB 5645 KM BB 5647 KELLY MOORE San Carlos, California ASBESTOS SURVEY On June 30, 1975 a visit was made to this plant to re-evaluate the asbestos exposure following installation of additional engineering controls and reduction of the amount of asbestos used along some of the lines. Mike Love, Liberty Mutual's Senior Loss Prevention Representative, accompanied the writer. CONCLUSIONS 1. All employees working in the Paco Division of this plant are not considered exposed to excessive asbestos in air concentrations. This is based on the current health standard. However, if our judgment was based on the health standard effective July 1, 1976, the "dry texture filler" would be considered exposed to an excessive amount of asbestos air.concentrations. 2. The exhaust ventilation on the dry texture bagging machine is ineffective. RECOMMENDATIONS 1. The local exhaust ventilation on the dry texture bagging machine be redesigned/increased so that dust can be effec tively captured and removed. 2. The operator of the dry texture bagging machine should be provided with coveralls as much of this dust is infiltrat ing his street clothes. This increases his chance for taking asbestos fibers home and exposing other members of his -family. 3. The ceiling texture mixer, dry texture mixer, and ready-mix mixer should wear the appropriate dust masks that have been provided for them whenever they are dumping bags of asbestos. Even though local exhaust ventilation has been provided at these dumping stations (150 linear feet per minute) the actual dumping of asbestos does create turbulence and dust which oftens billows into the operator's face before being exhausted. DISCUSSION This survey is the third that has been completed for asbestos. It is a re-evaluation to measure some of the engineering controls that were instituted (such as exhaust ventilation re-designed around the ceiling texture bager (and the reduction of asbestos primarily along the ceiling texture line which has dropped from approximately 150 pounds of asbestos per batch to 15 pounds of asbestos per batch. Survey Method.- Air samples were collected on membrane filters (0.8 micron porosity) with air feeing pulled through them via personal sampl ing pumps at approximately'two liters per minute. Air samples were collected in both the employees breathing zone (filter cassettes attached to operator's shirt lapel and pump attached to their belt) and air samples were collected in various areas of the plant to determine background air concentrations. All samples were analyzed at our Hopkinton, Massachusetts laboratory via the phase contrast microscope method. Toxicity - As you are probably how well aware, asbestos is a health hazard which when Inhaled, may cause a lung disease called asbestosis. This takes 10 to 20 years to develop after exposure. In addition, it may also cause cancer of the chest or abdominal lining referred to as meso thelioma. This may be fatal within one year after the first symptom. Health Standards - The current health standard for exposure to airborne asbestos fibers is five fibers per milliliter of air. This is an eight hour time weighted value which will drop to two fibers per milliliter of air July 1, 1976. Health standards are guidelines below which most workers would not be expected to experience any biological discomfort. Pre-existing conditions or individual susceptibility may be exceptions to this. Paco Textures Manufacturing Department - Our data indicates that most of the employees working within the Paco texture area are exposed to one fiber per milliliter of air or less. The exception to this is the dry texture filler operator. Our data indicated that all the air samples taken in his breathing zone indicated three fibers per milliliter of air. These readings are very similar to those taken back in March 1973. This current air concentration of asbestos is acceptable only until July 1, 1976; however, from a standpoint of health and exposing an employee to unnecessary asbestos fibers in the air, this level is unacceptable. The reason that this level is so high is the exhaust ventilation for the dry texture bagging machine is ineffective. The exhaust ventilation duct is directly behind the bagging slot and machine supports. The duct is so far back that it's completely ineffective Just from a standpoint of dis tance let alone being obstructed by some of the parts to the machine. It is suggested that this local exhaust ventilation system be re-designed and KM BB 5649 -3- KM BB 5650 DATA RESULTS OF: Asbestos in air DATE OF SURVEY: June 30, 1975 SURVEY METHOD: Membrane filter METHOD OF ANALYSIS: Phase contrast microscope HEALTH STANDARD: Current Effective July 1, 1976 Eight Hour Time Weighted Fibers per Milliliter of Air 5 2 l SAMPLE 1 2 3 4 5 6 7 8 LOCATION Operator's Breathing Zone (OBZ) , ceiling texture mixer. OBZ, celling texture filler. OBZ, dry texture mixer. OBZ, dry texture filler. OBZ, ceiling texture mixer. OBZ, celling texture filler. OBZ, dry texture mixer. OBZ, dry texture filler. TIME OF DAY 8:00 8:00 8:15 8:15 9:30 9:30 9:30 9:30 SAMPLING TIME MINUTES 53.5 44.5 52.0 50.5 45.0 47.0 50.5 50.5 AIR VOLUME LITERS 107 89 104 101 90 94 101 101 RESULTS ASBESTOS FIBERS/ml 1 * <0.7 3 2 A <0.9 3