Document n9YEdOxqzdNkMRMRJ6bDjNXBw

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA DENNIS C. EISENREICH and VICTORIA 1. EISENREICH, his wife. Plaintiffs, vs. OWENS-CORNING FIBERGLAS CORPORATION, et al.. Defendants. CIVIL DIVISION - ASBESTOS NO. GD 97-16440 USX CORPORATION'S OBJECTIONS AND ANSWERS TO INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANT USX CORPORATION BY PLAINTIFFS Code: 012--Asbestos Filed on behalf of Defendant USX CORPORATION Counsel of Record for this Party Richard H. Taylor, Esq. PA I.D. No. 59197 Timothy J. Cometti, Esq. PA I.D. No. 76501 USX CORPORATION Firm No. 435 USX Tower, Room 1500 600 Grant Street Pittsburgh, PA 15219-4776 (412)433-2854 (412)433-2823 PLAINTIFF'S j EXHIBIT Sa USX- SuV INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANT USX CORPORATION AND NOW COME the above-named Plaintiffs by and through their attorneys, Janice M. Savinis, Esquire and Goldberg, Persky, Jennings & White, P.C. and file the following Interrogatories and Request for Production of Documents Directed to Defendant USX Corporation which Defendant is required to answer fully and completely, under oath, within thirty (30) days of the date of service thereofpursuant to the Pennsylvania Rules of Civil Procedure. INSTRUCTIONS AND RECOMMENDATIONS: The term "Source" means any person or any document The term "this defendant" includes USX CORPORATION, f7k/a United States Steel Corporation, its predecessors or subsidiaries. The term "asbestos-containing products" includes asbestos, raw asbestos, mined asbestos milled asbestos, asbestos compounds, materials and products containing asbestos, and the asbestos particles, dust and fibers resulting therefrom. To the extent that information is unknown or not applicable, please indicate that this is the case and provide as complete an answer to the question as possible. USX CORPORATION'S OBJECTIONS AND ANSWERS TO INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANT USX CORPORATION NOW COMES, Defendant USX Corporation, formerly United States Steel Corporation ("USX"), by and through its undersigned attorneys, and hereby files the following objections and answers to Interrogatories and Reguests for Production of Documents directed to Defendant USX Corporation by Plaintiff. I. Defendant USX's General Objections and Reservations of Rights Applicable to All Interrogatories. A. General Objections 1. The discovery seeks information which is not relevant to the subject of the pending action, which will not be admissible, or as to which testimony will not be admissible at trial, and which is not reasonably calculated to lead to the discovery of relevant admissible evidence. To the extent that any objection made herein is based on the irrelevancy of the Interrogatory and/or its failure to lead to the discovery of admissible evidence, said objection incorporates by reference the foregoing general objection as if fully set forth therein. 2. The discovery sought is unreasonably annoying, oppressive, burdensome, and expensive taking into account the needs of the case, the amount in controversy, the limitations on USX's resources, the ability of Plaintiff to discover such information as easily as USX by using the applicable discovery rules of the Pennsylvania Rules of Civil Procedure, and the importance of the issues at stake in the litigation. 3. The discovery sought is not limited to the relevant periods of time or relevant USX facilities where Plaintiff Dennis C. Eisenreich alleges exposure to asbestos dust and fibers from asbestos-containing products. Further, such discovery bears no relationship to Plaintiff Dennis C. Eisenriech's alleged job activities as an employee of independent contractors at such relevant USX facilities. B. Conditions Without waiver or limitation of the foregoing objections or of any of the objections of specific Interrogatories hereinafter set forth, USX conditions its response to Plaintiffs Interrogatories, including any and all answers which it has famished to these Interrogatories, as follows: All answers of USX to Plaintiffs Interrogatories are made without in any way waiving or intending to waive but on the contrary, preserving and intending to preserve: 1. All questions as to competency, relevancy, materiality, privilege, or admissibility as evidence far any purpose in any subsequent proceedings of the trial of this or any other action: 2. The right to object upon any grounds, to the use of any such answers, or the subject matter thereof, in any subsequent proceedings of the trial of this or any other action; 3. The right to object, upon any ground, and at any time, to any demand for farther responses to the Interrogatories in Plaintiffs Interrogatories or to any other discovery requests involving or relating to the subject matter of the'lnterrogatories to which answers are herein or hereafter given; and -2- 4. The right at any time to revise, correct, supplement, clarify, and/or amend any answers furnished herein. All answers of USX to Plaintiffs interrogatories provided herein are limited to those relevant periods of time and relevant USX facilities where Plaintiff Dennis C. Eisenreich alleges exposure to asbestos dust and fibers from asbestos-containing products. nSTEKRQgAT-QMES 1. Recount in detail the history of defendant's business, with relevant dates and events, including: a) a list of locations of all past or present facilities and the function of each facility; b) a list of names of every past and/or present owner, c) a list of every past and/or present division; d) a list of every past and/or present subsidiary; e) a list of every predecessor-in-interest; f) a list of every trademark owned by this defendant and the dates of ownership; g) a list of every insurance company which has written a policy protecting this defendant from liability deriving from asbestos related injuries; h) the date this defendant had its inception; i) list of each and every name under which this defendant has done business; and j) a list of each past and/or present parent company of this defendant and the years of ownership. -3- i) list of each and every name under which this defendant has done business; and j) a list of each past and/or present parent company of this defendant and the years of ownership. ANSWER: (a-f) See General Objections 1,2 and 3 above. (g) Sfifi General Objection 3. Without waiving the foregoing objections, USX states that currently it believes it is uninsured for the alleged injuries to this Plaintiff during the time periods relevant to this pending action. (h) United States Steel Corporation originally was incorporated on February 25,1901 in New Jersey and was subsequently incorporated in Delaware on September 10,1965. On July 9,1986, United States Steel Cooperation's name was changed to USX Corporation. (i) See General Objections 1,2 and 3 above. (j) See Answer to subpart (h) above. 2. Did this defendant own or operate any of the following steel mills at any point between 1968 and 1972? a) USX Clairton Works, Clairton, PA 5/68-9-/68; b) USX Neville Island, Pittsburgh, PA 4/69-9/69, 5/71-9/71, 5-72/9/72 -4- ANSWER: (a) During the relevant time period, Clairton Works was not a steel mill rather it was a coke distillation facility. United States Steel Corporation (currently, USX Corporation) owned and operated Clairton Works during the time period referenced in this interrogatory. (b) During the relevant time period, USS Chemicals Neville Island facility was not a steel mill rather it was a chemical production facility. United States Steel Corporation (currently, USX Corporation) owned and operated USS Chemicals Neville Island facility during the timeperiods referenced in this Interrogatory. 3. For each steel mill listed in Interrogatory #2 which this defendant owned and/or operated, please: a) list the years that this defendant owned and/or operated the facility; b) if applicable, list the names of any and all co-owners of the facility; c) state whether this defendant has always operated the facility, or if another company shared or had that responsibility at any time; d) list the names of the individuals who were responsible for the operation of the facility, and the company by which they were employed; e) if the individuals listed in response to #3(d) are not employees of this defendant, list the names of the individual employees of this defendant who were responsible for overseeing, managing and/or representing this defendant's interest in the facility; f) list the dates of construction of each facility; g) state the name of the architectural/engineering firm retained to design the facility; h) list the names of all sub-contractors who were hired or contracted to construct the plants, and the dates of their contracts; i) list the dates of any and all additions and/or modifications to the plants, and describe the nature of the addition and/or modification; -5- yJTx PtMT j) list the names of each architectural/engineermg firm retained to design additions and/or modifications to the plants; and k) list the names of all sub-contractors hired or contracted to work on any and all additions and/or modifications to the plants, and the dates of their contracts. ANSWER: Clairton Works: (a-c) In 1904, United States Steel Corporation (now USX Corporation) purchased Clairton Steel Company. Upon the purchase, the Clairton facility was initially operated by Carnegie Steel Company, a subsidiary of United States Steel Corporation. In 1935, Carnegie Steel Company, along with two other subsidiaries of United States Steel Corporation, combined to form one subsidiary, Camegie-lllinois Steel Corporation. The Clairton facility continued to operate under the name 'Camegie-lllinois" until 1951. In 1951, Camegie-lllinois and three other subsidiaries of United States Steel Corporation merged to form a new subsidiary, United States Steel Company. In 1953, United States Steel Company merged into United States Steel Corporation, and United States Steel Company was dissolved. Currently, U.S. Steel Clairton Works is owned and operated by U.S. Steel Group, a unit of USX Corporation. (d-e) See General Objections 1,2 and 3 above. USX further objects to these subparts of this Interrogatory on the basis that they are vague, ambiguous and unintelligible. (f-h) See General Objections 1,2 and 3 above. USX further objects to these subparts of this Interrogatory on the basis that they are vague, ambiguous and unintelligible. Without waiving the foregoing objections, USX states that it does not currently know the identity of any individuals who would have personal knowledge concerning the original construction of Clairton -6- Works. Inasmuch as the original construction must have occurred sometime prior to 1904, when United States Steel Corporation purchased it, USX doubts that any such persons are still living. (i-k) See General Objections 1,2 and 3 above. USX further objects to these subparts of this Interrogatory on the basis that they are vague, ambiguous and unintelligible. Without waiving the foregoing objections, USX states that currently it has been unable to locate information relating to any "additions and/or modifications" that may have been constructed during the time period relevant to this matter. USX will supplement this answer if and when any such information becomes available. Nevertheless, USX believes that construction of the By-Products Section of Clairton Works (also referred to as the Keystone Project) was on-going during the time period relevant to this litigation. Neville Island: (a-c) In 1964, the assets of the Industrial Chemicals and Protective Coatings Divisions of Pittsburgh Chemical Company, including its Neville Island facility, were purchased by United States Steel Corporation (now USX Corporation) and became the Pittsburgh Chemical Company, a division of United States Steel Corporation. In 1966, the Pittsburgh Chemical Company division combined with two other entities to form the USS Chemicals Division of United States Steel Corporation. From that point, the Neville Island plant was operated by USS Chemicals until 1986 when USX Corporation sold its USS Chemicals Division, including the Neville Island facility, to Aristech Chemical Corporation. (d-e) See General Objections 1,2 and 3 above. USX further objects to these subparts of this Interrogatory on the basis that they are vague, ambiguous and unintelligible. (f-h) See General Objections 1,2 and 3 above. USX further objects to these subparts of this Interrogatory on the basis that they are vague, ambiguous and unintelligible. Without -7- waiving the foregoing objections, USX states that it does not currently know the identity of any individuals who would have personal knowledge concerning the original construction of Neville Island. USX will supplement this answer if and when any such information becomes available. (i-k) See General Objections 1,2 and 3 above. USX further objects to these subparts of this Interrogatory on the basis that they are vague, ambiguous and unintelligible. Without waiving the foregoing objections, USX states that currently it has been unable to locate information relating to any "additions and/or modifications" that may have been constructed during the time period relevant to this matter. USX will supplement this answer if and when any such information becomes available. Nevertheless, USX believes that construction of the Phataiic Anhydride Plant and/or the Maleic Anhydride Plant were on-going at Neville Island during the time period relevant to this litigation. 4. Did this defendant ever purchase or otherwise obtain the following asbestoscontaining products for use at the steel mills listed in Interrogatory #2 at some point between 1968 1972? a) pipe covering and/or lagging; b) gaskets and/or packing; c) electrical wire, cable and/or the'insulation therein; d) electrical circuit boards and/or the insulation therein; e) electrical motor controls and/or the insulation therein; f) electrical thermocouplesand/or the insulation therein; g) electrical components including arc shields, arc chutes, conduit, conduit packing, and/or the insulation therein; h) block insulation; i) mortars, cements, mud, castables and/or other refractory material; -8- j) sealants, mastics, paints and/or coatings; k) gunnite and/or gunning mix; l) welding rods; m) board; n) paper; o) rope; p) cloth and/or blankets; q) clothing, including but not limited to hoods, coats, jackets, pants, leggings, spats, gloves and/or mittens; r) brake pads and/or shoes; s) tape; t) spray on fire-proofing; u) plaster, v) wick and/or string; and w) miscellaneous items and other asbestos-containing products, components, accessories, attachments, and materials not described above. ANSWER: USX states that as a result of historic document retention policies, it no longer possesses purchase orders or invoices documenting the purchase of any products during the time period relevant to this matter. Nevertheless, USX believes that the following general types of asbestoscontaining products could have been in place and may have been applied and/or removed during the relevant time period as indicated below: (a) Both facilities. -9- (b) Both facilities. (c) Possibly both facilities. (d) Unknown. (e) Unknown. (f) Clairton Works only. (g) Possibly Clairton Works, not used at Neville Island. (h) Possibly Clairton Works, not used at Neville Island. (i) Possibly Clairton Works, not used atNeville Island. O') Clairton Works only. (k) Neither facility. (l) Neither facility. (m) Possibly Clairton Works, not used at Neville Island. (n) Neither facility. (o) Clairton Works only. (p) Both facilities. (q) Clairton Works only. (r) Both facilities. - 10- (S) Neither facility. (t) Possibly both facilities. (u) Neither facility. (v) Neither facility. (w) USX objects to this Interrogatory subpart on the basis that it is vague, ambiguous and unintelligible. By way of further response, see documents produced herewith. 5. For each sub-part #4<a)-(w) to which the answer is yes, please list by steel mill: i. the asbestos-containing products by manufacturer and tradename; ii. the specific dates on which this defendant purchased each product and the quantity of each purchase; iii. the suppliers) of each product; and iv. the locations within the steel mill at which each product was utilized; ANSWER: See Answer to Interrogatory 4 above. 6. For each sub-part #4(a)-(w) to which the answer is yes, if the asbestos-containing products were utilized and/or installed by an outside contractor, please list by steel mill: i. the locations within each steel mill where the products were utilized; ii. the dates when the products were utilized; iii. the contractor who utilized the products. -11- iv. whether this defendant specified a particular manufacturer and/or tradename for the product; and v. whether this defendant specified that the product contain asbestos. ANSWER: See Response to Interrogatory 4 above. 7. Has this defendant ever warned employees at the steel mills listed in Interrogatory #2 about the possible presence of asbestos in the mill and the health hazard created by exposure to asbestos? Ifyes, please state by steel mill: a) the date that this defendant first undertook to warn employees about the potential asbestos hazard; b) the means by which such warnings were communicated to employees; c) the exact language of such warnings; d) the name, address, and relationship with the defendant corporation of all persons responsible for the decision to institute such warnings; and e) the name, address, and relationship with the defendant corporation of all persons responsible for actually communicating such warnings to employees at the steel mill. ANSWER: See General Objections 1, 2 and 3 above. USX further objects to this Interrogatory on the basis that it is vague, ambiguous and unintelligible. This Interrogatory is irrelevant in that it seeks information regarding USX's interactions with its own employees, while the Plaintiff in this action was not an employee of USX. Moreover, this Interrogatory is objected to on the basis that it presumes exposure to asbestos, at any level, is harmful and that USX had a duty to warn its employees about the potential hazards of exposure to asbestos. -12- 8. Has this defendant ever warned invitees at the steel mills listed in Interrogatory #2 about the possible presence of asbestos in the mill and the health hazard created by exposure to asbestos? If yes, please state by steel mill: a) the date that this defendant first undertook to warn invitees about the potential asbestos hazard; b) the means by which such warnings were communicated to invitees; c) the exact language of such warnings; d) the name, address, and relationship with the defendant corporation of all persons responsible for the decision to institute such warnings; and e) the name, address, and relationship with the defendant corporation of all persons responsible for actually communicating such warnings to invitees at the steel mill. ANSWER: See General Objections 1,2 and 3 above. USX further objects to this Interrogatory on the basis that it is vague, ambiguous and unintelligible. Moreover, this Interrogatory is objected to on the basis that it presumes exposure to asbestos, at any level, is harmful and that USX had a duty to warn the employees of others about the potential hazards of exposure to asbestos. 9. Has this defendant ever warned former invitees/contract employees who may have been previously exposed to asbestos at the steel mills listed in Interrogatory #2 of their potential harmful exposure? If yes, please state: a) the date that this defendant first undertook to warn former invitees/contract employees of their potential harmful exposure; b) the means by which such warnings were communicated to former invitees/contract employees; c) the exact language of such warnings; -13- d) the name, address, and relationship with the defendant corporation of all persons responsible for the decision to institute such warnings; and e) the name, address, and relationship with the defendant corporation of all persons responsible for actually communicating such warnings to former invitees/contract employees. ANSWER: See Response to Interrogatory 8 above. 10. Did this defendant ever contact a newspaper and/or other news media in an effort to notify those people who may have been previously exposed to asbestos at the various steel mills listed in Interrogatory #2 of the need for medical monitoring? If yes, please: a) list which newspapers and/or other news media were contacted; b) list the dates on which this defendant contacted each newspaper and/or other news media; and c) state the exact language of the notice that was published and/or broadcast. ANSWER: See General Objections 1,2 and 3 above. USX further objects to this Interrogatory on the basis that it is vague, ambiguous and unintelligible. This Interrogatory seeks information that is irrelevant to this action. Moreover, this Interrogatory is objected to on the basis that it presumes exposure to asbestos, at any level, requires a "need for medical monitoring" and that USX had a duty to warn its former employees as well as the former employees of others about such a "need for medical monitoring." Without waiving the foregoing objections, USX states that it has made no such "contacts" with newspapers or the news media. -14- 11. Did this defendant ever contact any labor union whose members may have worked at the various steel mills listed in Interrogatory #2 in an effort to notify those people who may have been previously exposed to asbestos of the need for medical monitoring? If yes, please: a) list the labor unions contacted; and b) give the date on which each union was contacted. ANSWER; See General Objections 1,2 and 3 above. USX further objects to this Interrogatory on the basis that it is vague, ambiguous and unintelligible. This Interrogatory seeks information that is irrelevant to this action. Moreover, this Interrogatory is objected to on the basis that it presumes exposure to asbestos, at any level, requires a "need for medical monitoring" and that USX had a duty to warn its former employees as well as the former employees of others about such a "need for medical monitoring." 12. When were asbestos warnings first posted in each of the various steel mills listed in Interrogatory #2? ANSWER: SfiS General Objections 1 and 3 above. USX further objects to this Interrogatory on the basis that it is vague, ambiguous and unintelligible. Moreover, this Interrogatory is objected to on the basis that it presumes that USX had a duty to post "asbestos warnings." 13. When were asbestos warnings first posted at the entrance to each of the various steel mills listed in Interrogatory #2? -15- ANSWER: See General Objections 1 and 3 above. USX further objects to this Interrogatory on the basis that it is vague, ambiguous and unintelligible. Moreover, this Interrogatory is objected to on the basis that it presumes that USX had a duty to post "asbestos warnings" at facility entrances. 14. On what date was asbestos abatement first done at each of the various steel mills listed in Interrogatory #2? ANSWER: See General Objections 1 and 3 above. USX further objects to this Interrogatory on the basis that the use of the term "asbestos abatement" renders this Interrogatory vague, ambiguous and unintelligible. Without waiving the foregoing objections, USX states that to the extent it understands this Interrogatory, in the earfy 1970s, USX initiated a program whereby it actively sought and began utilizing suitable substitutes for all specific asbestos applications, whenever they became available, at both facilities relevant to this litigation. 15. In what year was all asbestos removed from each of the various steel mills listed in Interrogatory #2? ANSWER: See General Objections 1 and 3 above. USX further objects to this Interrogatory on the basis that it is vague, ambiguous and unintelligible. Moreover, this Interrogatory is objected to on the basis that it presumes that USX has a duty to remove "all asbestos" from its facilities. - 16- 16. Did this defendant ever conduct, direct or commission any investigations or studies to determine the amount of airborne dust containing asbestos fibers in the steel mills listed in Interrogatory #2? a) If yes, for each mill please:: i. list the names of any and all companies commissioned to conduct each such study or investigation; ii. list the dates each such study or investigation was performed; iii. state the result or conclusion of each such study or investigation; iv. identify all documents which refer, relate or pertain to each such study or investigation and the custodian thereof v. state the technique used for each such study or investigation. vi. state what action, if any, has been taken in response to the findings of each such study or investigation; and vii. identify the living person who has the most knowledge about the matters herein. b) If no, please state the basis of this defendant's determination that the air quality was of a safe level and did not need to be studied. ANSWER: See General Objection 3 above. Without waiving the foregoing objections, see documents produced herewith. 17. Has this defendant ever required that everyone entering each of the steel mills listed in Interrogatory #2 wear a dust mask and/or respirator? a) For each mill at which this defendant required the use of a dust mask or respirator, please state the time period during which this defendant required that all persons entering the facility wear a dust mask and/or respirator. -17- b) For mill station at which this defendant did not require that everyone entering wear a dust mask and/or respirator, what was the basis for this defendant's determination that the air quality was of a safe level? ANSWER: See General Objections 1 and 3 above. USX further objects to this Interrogatory on the basis that it is vague, ambiguous and unintelligible. Moreover, this Interrogatory is objected to on the basis that it presumes that USX has a duty to require 'everyone entering* its facilities to wear a dust mask or respirator. Without waiving the foregoing objections, USX does not have any such requirement. By way of further response, see documents produced herewith. 18. Does this defendant now, or has it ever, required invitees/contract employees at any of the steel mills listed in Interrogatory #2 to sign a waiver of rights? If yes, for each mill where this defendant required such waivers, please: a) state the time period during which this defendant required such waivers. ANSWER: See General Objections 1 and 2 above. Without waiving the foregoing objections, USX states that currently it has been unable to locate information relating to this interrogatory. USX reserves the right to supplement this answer if and when any such information becomes available. 19. Do this defendant's contracts with third party invitees at the various mills listed in Interrogatory #2 now, or have they ever, contained language shifting the burden of warning invitees of the potential asbestos hazard from the United States steel Company to the contractors? If yes, for each mill please: . a) state the time period during which such language was used. -18- ANSWER: See General Objections 1, 2 and 3 above. With regard to the relevant time period to this matter and without waiving the foregoing objections, see answer to Interrogatory 18 above. 20. If applicable, what other efforts has this defendant made, through contract or otherwise, to avoid potential liability due to the asbestos hazard and/or ambient air quality in the various steel mills listed in Interrogatory #2? ANSWER: See General Objections 1 and 3 above. 21. If this defendant is not currently taking steps to avoid potential liability due to the asbestos hazard and/or ambient air quality, what has it done to ensure that the steel mills listed in Interrogatory #2 are safe to inhabit now? ANSWER: See General Objections 1 and 3 above. 22. Has this defendant ever maintained a formal or informal library or libraries, or collection ofmaterials which in any way concerned or contained information relating to asbestos, industrial hygiene, medicine, hazardous substances, safety and/or health? ANSWER: USX historically has maintained informal libraries. - 19- 23. If the answer to all or part of interrogatory #22 is yes, please state: a) the date this defendant established each such library or collection of materials; b) the location of each such library or collection of materials; c) the names and addresses of the librarians or custodians of each such library or collection of materials since 1930; d) the title, author and publisher of all journals subscribed to or acquired by this defendant concerning asbestos, industrial hygiene, medicine, hazardous substances, safety and/or health, as well as the dates of subscription or acquisition of each; e) the title, author, publisher and the date of publication of all books and articles which were or are in such library or collection of materials, dealing with asbestos, industrial hygiene, medicine, hazardous substances, safety and/or health; whose use the library or collection of materials was established; and f) who, in fact, used or uses the library or collection ofmaterials. ANSWER: See General Objections 1,2 and 3 above. Without waiving the foregoing objections, USX states that the Medical and Industrial Hygiene Departments, or individuals within each, maintained materials related to health issues which varied in size and form since approximately the late 1930's. The materials were located at USX's corporate headquarters in Pittsburgh. USX's Medical Directors and staff were responsible for disseminating information to plant physicians and staff at all U.S. Steel facilities. At varying times, these libraries maintained a selection of literature and topical journals and periodicals pertaining to industrial hygiene practices and occupational medicine issues. The Medical and Industrial Hygiene libraries were informal and did not maintain card catalogs or indices. Years that particular materials were acquired are unknown. Further, the -20- defendant does not maintain a list of journals to which its various departments, facilities, and offices subscribed. 24. Has this defendant ever maintained a formal or informal library or libraries, or collection of materials which, in any way concerned or contained information relating to engineering? ANSWER: See General Objections 1,2 and 3 above. Without waiving the foregoing objections, USX states that its corporate engineering department currently maintains no library, formal or informal. Specific information related to whether any library, formal or informal, may have been maintained in the past is unknown at this time. USX will supplement this answer if and when information becomes available. 25. If the answer to interrogatory #24 is yes, please state: a) the date this defendant established each such library of collection of materials; b) the location of each such library or collection of materials; c) the names and addresses of the librarians or custodians of each such library or collection of materials since 1930; d) the title, author, and publisher of all journals subscribed to or acquired by this defendant concerning engineering, as well as the dates of subscription or acquisition or each; e) the title, author, publisher and date of publication of all books and articles which were or are in such library or collection of materials, dealing with engineering; f) for whose use the library or collection of materials was established; and -21 - g) who, in fact, used or uses the library or collection of materials. ANSWER: See Answer to Interrogatory 24 above. 26. Does this defendant belong to, or receive information from, or has it at any time since 1930 belonged to, or received information from, any inter-company or industrial organization or group, including but not limited to: a) the Industrial Health Foundation; b) the Industrial Hygiene Foundation; c) the Iron and Safety Institute; d) the Mellon Institute; e) the Asbestos Information Association ofNorth America; f) the American National Standards Institute; g) the National Safety Counsel: h) the Air Hygiene Foundation; i) the Institute of Occupational Environmental Health; j) the American Conference of Governmental Industrial Hygienists; k) the American Association ofTesting Materials; l) the American Industrial Hygiene Foundation; m) the North American Industrial Hygiene Association; n) the American Society of Safety Engineers; o) the American Industrial Hygienists; and p) any other inter-company or industrial organization or group. -22- ANSWER: See General Objections 1, 2 and 3 above. Without waiving the foregoing objections, USX states as follows: (a) Yes. (Membership:1935-77,1980-81,1984-86).USX received the Industrial Health Foundation Digest, although it is unclear duhng what time period(s). USX can verify receipt of only a few issues. (b) See Answer to subpart (a) above. This is the same organization as the Industrial Health Foundation. At some point in time, the name of the organization changed. (c) Unknown at this time. USX will supplement this answer if and when information becomes available. (d) Unknown at this time. USX will supplement this answer if and when information becomes available. (e) No. (f) Yes. (Membership: 1967 to present). (g) Yes. (Membership: 1932 to present).USX receivedperiodic bulletins from the National Safety Council beginning in the mid-1980's. (h) Unknown at this time. USX will supplement this answer if and when information becomes available. (i) Unknown at this time. USX will supplement this answer if and when information becomes available. -23- O') No. (k) Unknown at this time. USX will supplement this answer if and when information becomes available. (l) USX is not aware of an organization by the name of American Industrial Hygiene Foundation. However, USX has been a member of the American Industrial Hygiene Association from 1948 to present. (m) Unknown at this time. USX will supplement this answer if and when information becomes available. (n) Unknown at this time. USX will supplement this answer if and when information becomes available. (o) Unknown at this time. USX will supplement this answer if and when information becomes available. (p) USX objects to this Interrogatory subpart on the basis that it is vague, ambiguous and unintelligible. 27. If the answer to all or part of interrogatory #26 is yes, please state: a) the name and address of each such inter-company or industrial organization or group; b) the dates ofthis defendant's membership in each; c) the requirements for membership in each; t' d) the amount ofmoney this,defendant contributed.annually to each; and e) the dates of the first meeting of any such inter-company or industrial organization at which the hazards of asbestos were discussed. -24- ANSWER: (a) See General Objections 1,2 and 3 above. (b) See Answer to Interrogatory 26 above. (c) See General Objections 1, 2 and 3 above. Without waiving the foregoing objections, the answer to this Interrogatory subpart is unknown to USX. (d) See General Objections 1,2 and 3 above. (e) See General Objections 1,2 and 3 above. Without waiving the foregoing objections, the answer to this Interrogatory subpart is unknown to USX. 28. Prior to 1973, had any of this defendant's employees ever made a claim under any state or federal compensation statute for occupational pulmonary and/or respiratory disease and/or injury, including but not limited to pneumoconiosis of any sort, silicosis, asbestosis, lung cancer and/or mesothelioma? ANSWER: See General Objections 1, 2 and 3 above. USX further objects to this Interrogatory to the extent that it seeks information with regard to any non-asbestos related injuries, which are not relevant to this matter. Without waiving die forgoing objections, USX states that none of its employees "made a claim" against it for any of the following alleged diseases prior to 1973: asbestosis, asbestos-related lung cancer or mesothelioma. -25- 29. If the answer to all or part of Interrogatory #28 is yes, for each such claim under please state: a) the date on which this defendant first received notice of any such claim; b) the identity of the claimant; c) the nature and description of the claim; d) the job location and job function of each claimant; e) the date of employment of each claimant; f) the case number and jurisdiction; g) the resolution of the claim; and h) the custodian, identity and location of all documents which relate or pertain to each claim. ANSWER: Not applicable. 30. Prior to 1973, had this defendant voluntarily provided benefits to any employee for occupational pulmonary and/or respiratory disease and/or injury, including but not limited to pneumoconiosis of any sort, silicosis, asbestosis, lung cancer and/or mesothelioma? ANSWER: See General Objections 1, 2 and 3 above. USX further objects to this Interrogatory to the extent that it seeks information with regard to any non-asbestos related injuries, which are not relevant to this matter. Without waiving the forgoing objections, USX states that it did not -26- "voluntarily provide benefits to any employee" for alleged asbestosis, asbestos-related lung cancer or mesothelioma prior to 1973. 31. If all or part of the answer to #30 is yes, please state: a) the date this defendant first received notice of the employee's occupational disease or injury; b) the identity ofthe employee; c) the nature of the disease and/or injury; d) the job location and job function ofthe employee; e) the dates of the employee's employment; and f) the custodian, identity and location of all documents which relate the this voluntary provision ofbenefits. ANSWER: Not applicable. 32. If the answer to either #28 or #30 is yes, what was the date of the very first claim for asbestosis, mesothelioma and/or lung cancer? ANSWER: Not applicable. 33. At any time from 1930-present, did this defendant employ medical directors and/or consultants, safety directors and/or consultants, industrial hygienists, physicians, biological scientists and/or any other person who was responsible for issues of employee health and/or safety? -27- ANSWER: Yes. 34. If the answer to interrogatory #33 is yes, please state: a) the name and address of each such person; b) the professional specialization of each such person; c) the relationship of each such person to the defendant corporation; d) the time period of each such person's affiliation with the defendant; e) the reason for hiring each such person; f) the name and address ofthe person responsible for hiring each such person; and g) whether each such person kept files and/or records, and, if yes, where and how such files and/or records are kept ANSWER: See General Objection 2 above. These persons were located at both the plants and Headquarters sites. During the relevant time period, USX employed various physicians, biological scientists, toxicologists and other individuals who were, in part responsible for employee health and/or safety. The individuals who were the Directors/Managers of the relevant Departments are as follows: Medical Directors: (1) Dr. Joseph Schwerha, 1982-1998 -28- (2) Dr. Merle Bundy. 1961-1982 (3) Dr. Robert O'Connor (deceased), 1955-1961 (4) Dr. Hugh Wagner (deceased), 1925-1955 Directors/Manaoers of Environmental Health/Industrial Hygiene: (1) James F. Quealy, 1996-present (2) John B. Masartis, 1991-1996 (3) Frederick Toca, 1981-1991 (4) William Janes (deceased), 1973-1980 (5) Kenneth Morse (deceased), 1952-1973 Directors/Manaoers of Corporate Safety: (1) James P. Jones, 1997-present (2) Thomas Mott, 1991-1997 (2) Everett M. Gordon, 1984-1991 (3) Walter Holloway, 1980-1984 (4) T. F. Fisher, M.D., 1979-1981 (5) Douglas Brown, 1967-1978 (6) D. A. Farrell (deceased), 19467-1967 -29- 35. At any time from 1930-present, did this defendant ever consult, hire and/or contract with any outside person and/or company regarding employee health or safety? ANSWER: Yes. 36. If the answer to interrogatory #35 is yes, please state: a) the name and address of each such person and/or company; b) the professional specialization of each such person and/or company, c) the relationship of each such person and/or company to the defendant corporation; d) the date that this defendant consulted, hired and/or contracted with each such person and/or company, e) the reason for consulting, hiring and/or contracting with each such person and/or company; and f) the name and address of the person responsible for consulting, hiring and/or contracting with each such person and/or company. ANSWER: See General Objections 1,2 and 3 above. USX further objects to this interrogatory on the basis that it is vague, ambiguous and unintelligible. This Interrogatory is also objectionable in that during the time period referenced, the number of outside persons and/or companies with whom USX has consulted, contracted or hired "regarding employee health or safety" is too voluminous to compile and list here. -30- 37. Please state whether any of the medical directors, safety directors, industrial hygienists, physicians, biological consultants, consultants in these fields, and/or other people responsible for issues of employee health and safety identified in your Answers to Interrogatories ever made any recommendations and/or suggestions to this defendant pertaining to the risks or hazards to persons exposed to asbestos-containing products. If yes, identify: a) the date when such recommendations and/or suggestions were made; b) the individual to whom such recommendations and/or suggestions were made; c). the individual who made such recommendations and/or suggestions; d) the substance of the recommendations and/or suggestions; e) what actions, if any, were taken by this defendant as a result of such recommendations and/or suggestions; and if no action was taken by this defendant as a result of such recommendations and/or suggestions, state the reason(s) why and the person(s) responsible for making that decision. ANSWER: See General Objections 1, 2 and 3 above. USX further objects to this Interrogatory on the basis that it is vague, ambiguous and unintelligible. Without waiving the foregoing objections, see documents produced herewith. 38. Please state when and how this defendant first learned that the inhalation or ingestion of asbestos fibers posed a potential health hazard to human beings? ANSWER: See General Objections 1,2 and 3 above. USX further objects to this Interrogatory on the basis that it is vague, ambiguous and unintelligible. Without waiving the foregoing objections, USX states that it is difficult to pinpoint a precise date as to when USX became aware of any -31- potential health hazard of asbestos. USX's awareness of the potential dangers associated with different exposures and forms of asbestos and other dusts developed gradually over the years, as did the general public's awareness of such dangers. USX was aware of the publication in the mid1960's of Or. Selikoffs views on the potential dangers associated with asbestos exposure. USX was also aware of the promulgation of OSHA regulations concerning permissible exposure levels in or about 1972. 39. Regarding this defendant's first communication with any manufacturer of asbestos containing materials regarding the hazards of asbestos, please state: a) the date ofthe communication; b) the content of the communication; c) with which manufacturer this defendant first communicated; d) who initiated the communication; and e) the form of communication. ANSWER: See General Objections 1,2 and 3 above. USX further objects to this Interrogatory on the basis that it is vague, ambiguous and unintelligible. Without waiving the foregoing objections, USX states that it is unaware of any such "communications." 40. Regarding this defendant's first communication with any contractor regarding the hazards of asbestos, please state: a) the date of the communication; b) the content of the communication, c) with which contractor this defendant first communicated, -32- d) who initiated the communication; and e) the form of communication. ANSWER: See General Objections 1,2 and 3 above. USX further objects to this Interrogatory on the basis that it is vague, ambiguous and unintelligible. 41. Regarding this defendant's first communication with any other steel facility regarding the hazards of asbestos, please state: a) the date ofthe communication; b) the content of the communication; c) with which other steel facility this defendant first communicated; d) who initiated the communication; and e) the form of communication. ANSWER: See General Objections 1, 2 and 3 above. USX further objects to this Interrogatory on the basis that it is vague, ambiguous and unintelligible. 42. Has this defendant ever brought a lawsuit against any manufacturer of asbestoscontaining products to recover damages due to the cost of asbestos abatement? a) Ifyes, please list: i. the caption and citation of each such lawsuit; and ii. the outcome of each such lawsuit -33- b) Ifno, please state the basis of this defendant's belief that such an action would not benefit the owners and/or shareholders of USX Corporation. ANSWER: See Genera! Objections 1,2 and 3 above. USX further objects to this interrogatory on the basis that it is vague, ambiguous and unintelligible. 43. Does this defendant currently have a corporate policy to not use asbestos? Ifyes, please state: a) when that policy was instituted; b) how that policy was published; and c) how that policy was implemented. ANSWER: See General Objections 1 above. Withoufwaiving the foregoing objections, USX states that in the early 1970s, USX initiated a program whereby it actively sought and began utilizing suitable substitutes for all specific asbestos applications, whenever they became available, at both facilities relevant to this litigation. By way of further response, see documents produced herewith. 44. Does this defendant have any records showing that it purchased, obtained and/or supplied asbestos-containing products that were utilized at any or all of the above referenced steel mills? If so, please: a) identify the location where said records are stored; and -34- b) identify the custodian of the records. ANSWER: USX states that as a result of historic document retention policies, it no longer possesses purchase orders or invoices documenting the purchase of any products during the time period relevant to this matter. By way of further response, see documents produced herewith. 45. Please identify all persons and sources which, in any manner, provided information used in answering these Interrogatories, and for each named source please indicate the number of the Interrogatory and its sub-part for which the source was used. ANSWER: The following individuals assisted in answering the within Interrogatories: R. Patrick Baughman, Esquire; Timothy J. Cometti, Esquire; John C. Grossman; Susan S. Henderson, Esquire; Richard H. Taylor, Esquire and John B. Masaitis. Messrs. Cometti, Grossman, and Taylor are employees of the Law Department of USX-U.S. Steel Group, 600 Grant Street, Pittsburgh, PA. Mr. Baughman and Ms. Henderson are partners in the law firm of Baughman & Associates, 55 Public Square, Cleveland, OH. Mr. Masaitis is the former Director of Industrial Hygiene for USX (1991-1996) and was employed as a corporate industrial hygienist for USX (1964-1996). 46. If any of the sources consulted in answering these Interrogatories are individuals, please list the following for each individual: a) name and address; b) relationship to the defendant corporation; and -35- c) time period of affiliation with this defendant. ANSWER: See Answer to Interrogatory 46 above. 47. Regarding each document consulted as a source in answering these Interrogatories, please do the following: a) list the location of the original document; b) list the name and address of each individual who prepared the individual document; and c) attach a photocopy of the document ANSWER: See documents produced herewith. -36- REQUEST FOR PRODUCTION OF DOCUMENTS 1. Please attach copies of all invoices, purchase orders, bills of lading, contracts, or other non-privileged documents relating to the purchase by this defendant of asbestos-containing products for use at the USX Clairton Works or USX Neville Island Plant. RESPONSE: See General Objection 3. Without waiving the foregoing objections, USX states that it is not in possession of any such documents relating to the time period relevant to this matter. 2. Please attach copies of the blueprints which were used in the construction of, or for additions or modifications to, the above-referenced steel mills. RESPONSE: See General Objection 3. Without waiving the foregoing objections, USX states that currently it has been unable to locate any such documents relating to the time period relevant to this matter. However, USX1 search is on-going, and USX will supplement this response if and when any such documents are located. 3. If applicable, attach an index of this defendant's records which show that it purchased asbestos-containing products. RESPONSE: See General Objection 3. Without waiving the foregoing objections, USX states that it is not in possession of any such documents relating to the time period relevant to this matter. -37- 4. Please attach all copies of contracts, records or other documents in which the use or installation of asbestos-containing products is specified in the construction, modification-or maintenance of the above-referenced steel mills. RESPONSE: See General Objection 3. Without waiving the foregoing objections, USX states that currently it has been unable to locate any such documents relating to the time period relevant to this matter. However, USX's search is on-going, and USX will supplement this response if and when any such documents are located. 5. Please attach copies of all documents relating to claims brought by, or benefits provided to, employees of this defendant for occupational pulmonary and/or respiratory disease and/or injury from 1930-1973. RESPONSE: USX is not in possession of any such documents. 6. If applicable, please attach a catalog or index to any and all journals, articles and/or books in this defendant's library or libraries or collection ofmaterials during the time period from 1930-1973', which deal with asbestos, industrial hygiene, medicine, safety, health and/or engineering. RESPONSE: See General Objections 1,2 and 3 above. 7. If applicable, please attach copies of all policy statements, internal memoranda, and/or other internal correspondence relating to this defendant's program for warning employees and/or invitees at the above-referenced steel mills of the asbestos danger. -38- RESPONSE: See General Objection 3. Without waiving the foregoing objections, see documents produced herewith. 8. If applicable, please attach copies of all files and/or records kept by the persons responsible for occupational health-and/or safety at the above-referenced steel mills relating to insulation, asbestos, dust, and/or other respiratory hazards. RESPONSE: See General Objections 1,2 and 3 above. 9. Please attach copies of all documents relied upon to answer the Interrogatories propounded by the plaintiffs. RESPONSE: See documents produced herewith. 10. If applicable, please attach the citations of the cases in which a depositions was taken of any corporate representative ofthis defendant relating to any asbestos litigation and attach the name of the individual deposed. RESPONSE: See General Objections 2 above. -39- 11. Please attach copies of all policy statements, memoranda, and/or other internal correspondence concerning any potential hazards associated the presence of asbestos in this defendant's steel mills. RESPONSE: See General Objection 3. Without waiving the foregoing objections, see documents produced herewith. 12. Please attach copies of all policy statements, memoranda, and/or other internal correspondence concerning this defendant's efforts to warn employees and/or invitees of the health hazard posed by the presence ofasbestos in the above referenced steel mills. RESPONSE: See General Objection 3. Without waiving the foregoing objections, see documents produced herewith. 13. If applicable, please attach copies of all policy statements, memoranda, and/or other internal correspondence concerning this defendant's decision to substitute asbestos-free products for asbestos-containing products in the above referenced steel mills. RESPONSE: See General Objection 3. Without waiving the foregoing objections, see documents produced herewith. -40- 14. Attach captions of all lawsuits based on alleged injuries resulting from exposure to asbestos in which this defendant has gone to verdict. RESPONSE: See General Objections 2 above. 15. Attach the captions of all lawsuits based on alleged injuries resulting from exposure to asbestos in which this defendant has answered interrogatories. RESPONSE: See General Objections 2 above. 16. Attach the captions of all lawsuits in which this defendant sought to recover damages for the cost of asbestos abatement RESPONSE: See General Objections 2 above. -41- 17. Please attach copies of all dust and/or air quality studies which were conducted at tne above referenced steel mills. RESPONSE: See General Objection 3. Without waiving the foregoing objections, see documents produced herewith. Submitted by, GOLDBERG, PERSKY, JENNINGS & WHITE, P.C. By:___/s/ Janice M.Savinis Janice M. Savinis, Esquire Attorney for Plaintiffs Answered By, Dated: May 15,1998 Richard H. Taylor USX CORPORATION USX Tower, Room 1500 600 Grant Street Pittsburgh, PA 15219-4776 Attorney for Defendant USX Corporation -42- COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY ) ) VERIFICATION ) PERSONALLY appeared before me the undersigned, Richard F. Lerach, who being first duly sworn, deposes and says: That he is an officer/agent of USX Corporation; that he has read the foregoing Responses to Plaintiffs' Interrogatories and subscribes to same on behalf of USX Corporation; that said responses were prepared with the assistance and advice of counsel and other responses were prepared with the assistance and advice of counsel and other representatives ofUSX Corporation; that said responses, subject to inadvertent or undiscovered errors, are based on, and, therefore, limited by the records and information still in existence, presently recollected and thus far discovered in the course of preparation of these responses; that consequently, USX Corporation reserves the right to make changes in the responses if it appears at any time that omissions or error have been made therein or that more accurate information is available; and that subject to the limitations set forth herein, that said answers are true to the best of his knowledge, information, and belief. USX CORPORATION SWORN to and subscribed before me RICHARD F. LERACH iNQiary ruouc " Notarial Seal Rosemarie E. Sawicki, Notary Public Pittsburgh. Allegheny County My Cotnmisson Expires Feb. 7, 2000 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing USX Corporation's Objections and Answers to Interrogatories and Request for Production of Documents Directed to Defendant USX Corporation By Plaintiff was served upon Plaintiffs counsel by hand delivery and notice of same upon all other counsel of record by first dass mail this 15th day of May, 1998 at the following addresses: SEE ATTACHED LIST (JSS DtcM^Y ELIMINATION OF USE CF ASBESTOS In 1972, the Federal Government published a proposed standard for employee exposure to asbestos dust. At that time, we made a survey of the products In our plants which contained asbestos. From that survey, a program was begun to consider replacing asbestoscontaining items with alternative products. The following is a listing of the replacement products we are new using: sbestos Product - Cost Replacement Product Cost Comments sbestos Gloves 8.W pr. Aluminized "Thermo- 16.70 pr. Not satisfactory best" gloves for high heat sbestos Gloves AB-L gloves, aluminized back 14,18 pr. Not for extreme heat sbestos Gloves AB gloves, aluminized 10.70 pr. Not forextreme back, heat resistant heat leather palms . . sbestos Cloth 4?.00 siding Shield "C-Lite" welding shield **6.80 ea. Not as durable as asbestos curtain Frooelt Reyfoil welding curtains 33.00 ea. Same as above sbestos Welding 37.00 lankets White Pyrotex safety320.00 ea. For extreme heat blanket l", 2400 sbestos Cloth 6.70 sq. yd. Sil-Temp sat Shield 16.00 sq. Good protection from heat, low strength sbestos Cloth 6.70 sq. yd. Sil-Temp. o wrap hoses n electric furnaces 16.00 sq. Not fully yd. satisfactory luminized sbestos coats 1^0.00 each Aluminized Pre-Ox coat 112.05ea. Limited experience but appear satisfactory Aluminized Fiber Glass Coat 52.90 ea. Satisfactory for light use USEI000001 Gvmi> f*. l ^ A i r . i n i , n . O ftf.f 5h i Sy 'b C,t.tn iu Mu.r Vo A N. or:L gw t3_ /*** :c - w ?5 52 _WCi4S. >"r *w' -R5w U 5wc. 3<(i0f Oc -J c?3 * * ,* . w4W*C JTL* C^* r M<d9l OX<< 1sW?< wm^ e*u` ^a*O* W 2 w9a^ *2 5 n* 25(T* c53 faI * 9 W r, r ^ OP . * r * ** 3 5 .* * * j; mo* c2 - ^ ^ S 5o ^O%?C,^* ^ * 2"* - >a r l *" 3i 3 *S**** ? *i z% <O** * a n ': *-- S%t 3 3^ ___________(.Q ^ ackH ^ /-<N? C2 * * -) Q U .. . $ w - . ... /-s . . 0Vr * j <I2*t W /Wf .......................5 'wsce *x "o *~ ir Ps- cKia* l^/low ooL (& M to f*l 1 U U rjx ') pRobuhl (MWmArtugf*!) MftTlRtAL __________________ * 7 25 <r 4 Jl* 4' O ri I* 2 5 TO f *i 1 r USEI000002 ? 5C fi. . -i * 5c 9 5 * w 4! S 1sid S 5<5 3 i- j.. As* ft V c" cJI 3* vi w ou 1-1 C wv"> I c= <c Qw '* ,aH5 w * |3?I * S iJ t* J r* cfi * r fi l'1 <cJ1-> Cr slS O* J -o5 i s i i^.i J . 1 >4 3 >- A ^r c "u S"o zx . w^ ^ ,5 ^ S J< 5 | 5 } <2V >S e i 2 A W -J y 4.' S5 - 3 3 = f 9 * ^1 !3 i*? W -s _ ot>' * s2f> i**? ~ y> At* v*^> -1 | 2 5c?3 2 3 | a ^ 5** & k-< :* - f*c : S* o> 5 2 w i * =5 %o 0 &w Jd 2a 3 5w S 3rS *4 I G J 2 Ilutf <2- -i*. *'-? v-A! lA! u <? 6 7W-S"' USEI000003 & *' Hn n M _ V t r U ,o * *MM| ^%.-iApC< . 'in i % A r.tt H A l , --s i "v f< WV *C 3N W -* .3 ?f a Stmr *-- V* V*.* s>- < v *r 5 * $ W u95 ?> #i 5 <c * % s z w t g . A iw * wr twf * w , r V* 1w r2 15* *C <- * *1 ts*c o2 c*rf c.* i* * wS w> o8 r5 3& iZ (/>i ^\ . ... ... 53 c 0hv1 < - * ; N r-' 5 i Q s_/ 5 -* W V IwwV -- O r -? A MJ **- >2* vfd LJ C 5 !? W * f~2- rx v9i aa )U2-i c grU*>* a* Mw a. EW0 ^ r(/> V-N T<'-" s? { it. i 5 w= s < v> W ** w *r* ? S-* 0? 5 2 '4 w- 5 V* i 3 *2 ^ 'r^1 O < u2 w 5 * % E. M ? 2^ f ^ C j 5 ^ ct ^ I . C 2 u; J? 3 f* 4 -5 > k5 ** g 5 s < . P^ ^ Ucl "2 t- 02 !3 r *' 1 '1 S' ww?*' *cr0i <* - k w ** H*iiO , M (,r ----------- -1----------- USEI000004 c ~ -1 iX /N ^ c Cl s2J *2. * ? y ^ w-. i u IS t 2 x * X $ w ;> Z k ve r I' n; a E js a j 3 o a C iy t c* vc .3 O 4 U- c/' 5 ^ w J - ft VA < v> SI tti ^ I! ;* l d Z X5& k VC < 5 o<- io CC XX _ _) l1 -le1 or a. t U2. "je* 1 W Tf ir % w 7tf I** 'i w w w J* * ?i c. ^?i SJ s iw C, * <-2 * *! S5 V 2^ W LTN -6nC 5 js a t* s * V2 gC> (*2 ^c *> S. in 5 y JrT rr * rt S i w C oWuw<. / </> -* i * e2 J? *= <5; (..O! z zC V1 I V| ol -wS < 2 U 5 I r* lr i u* i: USEI000005 * 1 2 TMi WtURilu. U)*". C.*t> to 8. JL IfC.Vtfj I l I I I x i c * 3 A* 5sS 5 * P 4 Is 5 J c p< f't % ' s5 z - A a* -* i a 5 ?' "*- 3 h. <<u ^ J; 1 S * *<* li. 'if "I? <-3 *jz*- * --' t* 8 VX;* w c:. {M* 2v3 x rz WJ "^ ** - x i %aw?s\ J2 Si 5 c w S r ** : ax C U. 5o M u, !? S2 k S e 1 --JX w*u z* 25 * 5s * a iS( tf * w*. * sS < V* V/* < <2 * V* X*> < X X9 v X J* a ____ _______^ _ _______ (to Ah<a>fttuvttfg C i s 2r $W C> t sVfb K V XC At<tt ac CtkjlfCCT X sxd.: j cw <. ]I *5 r*~ C* USEI000006 Vt*y l.ticf 1*jrUR^/n f r r,Hf^ -------------------------- G intiX M l\ w < y2\ %* v> & ll p5 Is *5 c V ** p * * c -* 3 2 3 D w WJ- ^ <^ i *C 2 aJ- r St t u> 4 /wr*J Cl V 0 r U * O tf* /V v*S wo 8- J2*l *c22x< 5A 3V X W 5 1* s* ?**$ i c*- ~ .O S r r $ 5 * -w ^ a 5 v* - v>s U1 Sgw 4* o* c2 SS* S,,' * 'V * 3 cw* V f WIV ^S (* * r S* 4 e ? xC j tultbf rv . v- tf 2 3 s w c CTifc2 3 * r-* liftow t MO| ttSVlft>*t <A>Uf.lMt> ftusTvjs, Vliwiic KtAxyta!* friM HM tt. ____________ ________ iW n ( ta* c i2 <U>J V* 2 ri XV 3O '-k USEI000007 UNITED STATES STEEL CORPORATIO to Merit Bundy, M. D Director Industrial Medicine oath October 28, 1970 reoN uajccT P. R. Wray Director Metallurgical Engineering Use of Asbestos in U. S. Steel Plants East week you requested that 1 survey our mills to see if we were using asbestos as a mold coating in view of the health hazard involved. 1 had a survey made to determine any known uses of asbestos in our mills and you will find the results in the attached memorandum. While we are not using asbestos as a mold coating, you will note that it is used as a heat protection and sealant in many places although not in great quantity. I hope this serves your purpose. USEI000008 memorandum Mr- IK. 8. Kayo: BSE OF ASBESTOS ZN STEELMAKING AND MOLD MANUFACTURING OPERATIONS October 27, 1970 A pnCHnlnary sdWey of plant Metallurgical peraonnal Indicates that all plants m* asbestos safety equipment. In most steel producing plants some fora f asbestos coating Is sprsyed on open hearth checker chamber vails. ' Asbes&mm la also generally used to shield thermocouples, to cover pipes, sod ssss insulating block component In many furnace applications. Following Is a Hating of spcelal applications or uses of asbestos as known to HefetiJsrglcal Department personnel Is the concerned plant: Duluth Duquesne 8. Thomson Fairfield Fairless Cary Geneva Boaestead Johnstown Asbestos rope Is used to wipe galvanise off "wiped galvanise wire". Nothing except as noted above - Nothing except as noted above. - An asbestos blanket Is used to cover the Ignition unit of the sintering machine In the ore conditioning plant. Sothlng except as noted above. Slabs are covered with asbestos sheets In the plate mill "in-and-out" furnaces and "continuous" furnaces. Asbestos rope Is used around starter bar head in the continuous caster. 0.8. - Rope to seal chills used in pouring charging boxes. Asbestos curtain In tank used In setting ladle stoppers. Foundry - lope to seal eopes and drags. ' Mold cores set on transits plates for transfer to drying evens. (Transits is a cement-asbestos mixture.) Flats mill slabs are covered with asbestos sheets before reheating. Asbestos compound on roll flask parting line USEI000009 ) Lorain othing except ec noted above, loll * Machine- foil rope seed for sealing. South - Foundry Paper facing on sand of flasks for special castings. II.Fee. - Caskets on peep sights and doors. Torrance Youngstown - Asbestos rope eround starter bar bead In' continuous caster. * - Hothlng except as noted above. ec: C. H. Fltxvilson 2. 1. Queneau P. t. Wray X. Morse USEI000010 1. linked .States Steel Corporation T Mr. D. W. Brown Director of Safety From USX Medieat Dept Files Intarorganizstion Corraapondanca 04t.: May 17, 1971 Kenneth M. Morse, Director Environmental Health Asbestos Protective Apparel The article which appeared in the Duluth newspaper, which has been of concern to Bill Slaughter, has been re viewed. Dr. Irving J. Selikoff who was mentioned in the article, found lung cancers in construction workers who were spraying and cutting asbestos insulation and in the processing of certain types of asbestos. Subsequently he has become an alarmist and a most controversial figure as he has expanded his work at New York's Mt. Sinai School of Medicine through government grants. Once one has built up an organization on such grants, his continuation of the program can result only by creating more and more concern among industry and the general public. I believe that the facts are that in the case of insulation workers, in the processing of asbestos and among the cutters and others engaged in the manufacture of asbestos coats, the problem is real. However, I believe that in the wearing of asbestos coats and asbestos protective apparel, a problem has not been shown. I do not know of any factual report of asbestos being a problem in industry from the use of asbestos protective apparel, and I would not recommend that we dispense with the use of such apparel at this time. It is difficult to estimate how much further inroads the alarmists in the environmental health field will be able to prevail. It is within the realm of possibility that should a man who has been wearing asbestos protective clothing, at various times throughout his worklife, develop lung cancer, he may endeavor to attribute it to the asbestos. Therefore, should the alarmist type of publicity continue, it may be desirable to investigate the future possibility of the use of other types of materials affording protection against molten metal splashes or a more tightly woven asbestos cloth. I do not know whether NOMEX would be adequate for this purpose, and I am aware that its cost is considerably greater than asbestos. In any event, I do not believe that there is a need to dis pense with the use of asbestos protective apparel which is now being used in the Corporation nor do I believe that we should discontinue its purchase at this time. mt CtpfM tc Plant Medical Directors USEI000011 United States Steel , Corporation i lottrorginintion Comipondtnee o*t: December 10, 1971 Tk General Superintendents and mw Kenneth M. Morse, Director Plant Managers Environmental Health Superintendents - Personnel Services Supervisors of Safety MJact* Threshold Limit Value for Asbestos Dust Exposure Federal Occupational Safety And Health Act (OSHA) In the December 7, 1971 issue of the Federal Register, the previous standard for airborne concentrations of asbestos dust was drastically'reduced from that which appeared in the threshold limit list (Table G-3) of the original set of stand ards which appeared in the May 29, 1971 Federal Register. You may be cognizant of the considerable furor which has been de veloped by some people on the development of lung cancer from long-term exposure to very low concentrations of asbestos dust. While some of this information is questionable, the fact remains that it is now accepted by the Federal government with the re sult that the above action has been taken, and compliance with the standard is required. % The original TLV which appeared in Table G-3 of the May 29, 1971 standards was 10 fibers per cubic centimeter of air, greater than 5 microns in length (2 million particles per cubic foot of air). This has been lowered to 5 fibers per cubic centimeter of air, based on an 8-hour time-weighted average exposure, with a maximum concentration for any 15 minute period in an hour for up to 5 hours, not to exceed 10 fibers per cubic centimeter. Zn view of the fact that we utilize asbestos either in sheets, for pipe covering, or in the loose form in several of our operations, which involves intermittent exposure of employees to asbestos dust, it is most important that your health and safety staff and engineering department be fully cognizant of the control measures which are required. These control measures are as follows: 1. The first effort in control must be engineer ing methods, where such are feasible. tK J. E. Angle T. W. Hunter R. A. McClure G. A. Jedenoff G. F. Willard F. H. Wickline J. P. Marner R. B. O'Connor M. Bundy D. W. Brown USEI000012 -2- I 2. Where engineering methods are not feasible ox cannot reduce the concentrations within the limits above prescribed, respiratory protective devices must be utilized con sisting of the following:' a. Respirators meeting the U. S. Bureau of Mines Schedule 21-B, for individuals ex posed to 25 fibers per cubic centimeter of air averaged over an 8-hour shift, or exposed to 50 fibers per cubic centimeter of air over any 15 minute period. A valveless respirator providing equiva lent protection may also be utilized. b.' Where the exposures involve concentra tions of 250 fibers per cubic centimeter of air, averaged over an 8-hour shift, * or more than 500 fibers over any 15 minute period, a powered-air supplied filter respirator of a type approved by the U. S. Bureau of Mines under their * Schedule 21-B must be used. c. For exposures in excess of 250 fibers per cubic centimeter of air averaged over an 8-hour shift, a Type C positive pressure supplied air respirator approved by the USBM under their Schedule 19-B shall be utilized. 3. All hand or power-supplied tools which produce asbestos dust such as saws, scorers, abrasive wheels and drills shall be provided with local exhaust ventilation and dust collectors. 4. Employees exposed to the spraying of asbestos or demolition of pipes, structures or equipment covered with asbestos insulation shall be pro tected by the use of respiratory protective devices above mentioned. 5. Asbestos cement, motors, coatings, grout, and plaster shall be mixed in closed bags or other containers. 6 . No dry sweeping or blowing of surfaces contain ing asbestos shall be performed and such clean up shall be done by vacuum methods. I 3 The above regulations and the hazards associated with asbestos dust warrants immediate attention to determine those occupations in your facilities which utilized asbestos in any form and in determining the concentrations to which workers may be exposed. In the latter category this office will shortly be in a position to assist you in determining such concentrations. In addition, workers exposed to asbestos dust should be given pre-employment and periodic chest x-rays. mt 1touted latartrganiutioA Crrwpoa4nc t General Superintendents Plant Managers and Attendees at OSRA Regional Meetings June 26, 1972 free Kenneth M. Morse, Director Environmental Health M)Mt: Proposed Permanent Asbestos Standard OSKA published its permanent (final) Standard for Exposure to Asbestos Dust, in the Federal Register of June 7, 1972. A copy of this standard is enclosed for your informa tion. We suggest your thorough review of this standard due to the highly restrictive requirements that are established. It is further suggested, that you inventory your uses of asbestos compounds as to location, jobs and quantity used per month or year in order to. establish a priority list of jobs and areas for monitoring. We are indicating, below the pertinent aspects of this standard. 1. Permissible Maximum Dust Exposure a. As of July 7, 1972, the 8-hour time-weighted average exposure is limited to S fibers per milliliter of air for dust not exceeding 5 micrometers in length. However, as of July 1, 1976, the limit is reduced to 2 fibers per milliliter. b. While a time-weighted average is determined over an 8-hour work period, the dust concen tration to which a worker is exposed cannot exceed 10 fibers per milliliter for any period of time (ceiling value). c. This standard applies to the use of any type of asbestos. 2. Methods of Compliance Feasible technological controls and appropriate work practices must be the primary means of controls. Rotation of employees is allowed only in stated exceptional circumstances. The use of respirators and shift rotation* of employees will be limited. The methods for controls consist of, but are not limited to, the following: USEI000013 a Engineering Controls (1) Oust collection systems of the local exnaust ventilation The design criteria for such systems is the American National Standard Fundamentals Covering the Design and Operation of Local Exhaust Systems (ANSI Z9.2-1971). (2) Particular Tools -- All tools which release dust in excess of the exposure limits when used on asbestos must be equipped with local exhaust ventilation. b. Work Practices (1) Wet methods must be used, when handling asbestos, to preclude excessive dust exposure, unless the usefulness of the product would be diminished. (2) Asbestos products cannot be removed from containers in which they are shipped un less they are wetted, or enclosed, or ventilated. (3) Employees engaged in spraying asbestos, the removal, or demolition of pipes, structures or equipment covered or in sulated with asbestos, or demolition of asbestos insulation or coverings, shall be provided approved respiratory equip ment and special clothing. Personal Protective Equipment a. Respirators and shift rotation of workers are permitted only under the following conditions: (1) During the period necessary to install engineering controls and the changes in work practices. - * (2) Where the work practices, as listed above , are not feasible or cannot reduce the dust to within the exposure limits. USEI000014 -3- (3) In emergencies (4) Where both respirators and personnel " rotation are allowed, the latter shall be preferred. b. The types of air-purifying respirators allowed are based upon the dust concen tration to which an employee is exposed and must be of the types approved by .the U. S. Bureau of Mines CUSBM)- and the National Institute of Occupational Safety and Health (NIOSH). (1) When the employee may be expected to receive an exposure no more than 10 times the exposure limits, a reusable or single use air purifying respirator of the non-powered or supplied air type may be used. (This is the commonly used mechanical filter type.) (2) When the exposure is expected to be be tween 10 to 100 times the exposure limits, a full face piece, oral-nasal, or continuous flow or pressure-demand types of supplied-air respirators must be used. (3) When the exposure is expected to be in excess of 100 times the exposure limits, only the supplied-air respirators of the continuous flow or pressure-demand class can be used. These are now classed by USBM and NIOSH as Type aC". (4) A respirator program must be established by the employer in compliance with the American National Standards Practices For Respiratory Protection (ANSI 288.21969). If an employee cannot function normally when wearing a respirator, as determined by a physician from the employee's most recent examination, he must be rotated to another job or provided the opportunity for a job transfer. The job to which he i. USEI000015 may be rotated or may transfer must be in the same geographical area and with the same seniority, status and rate of pay. c. Special Clothing Protective clothing must be provided to employees exposed to a dust concentration in excess of the "ceiling value" (10 fibers per milliliter). The use of such clothing must be required by the employer. d. Change Rooms (1) Change rooms for employees regularly employed must be provided when employees have dust exposures in excess of the exposure limits. (2) Two separate lockers, or containers, must be provided for each employee ex cessively exposed to dust. They must be separated, or isolated, to prevent con tamination of street clothes. (3) Laundering Clothing (a) Laundering of asbestos contaminated clothing must be done. Zt appears that such laundering shall be the responsibility of the employer but it is not so stated. (b) The employer must notify the person to whom he gives clothing for laundering that it shall be done in a manner preventing exposures in ex cess of the exposure limits. (c) Contaminated clothing must be trans ported in properly labeled closed impermeable containers. Measurement of Asbestos Dust a. Method Asbestos dust surveys will be conducted fay Headquarters-Environmental Health for the present, due to the detailed procedure which such a survey involves. Requests for such survey should be directed to K. M. Morse, Director of Environmental Health. USEI000016 b. Monitoring Requirement* <1) Initial Survey: Within six months a survey must be conducted to de termine the exposure of every em ployee to asbestos dust. If the exposure limits are exceeded, a control program, as herein indicated must be immediately initiated. (2) Periodic Survey: At least every six months for all employees who may be reasonably expected to have exposures exceeding the exposure limits. (3) Personal and Area Samples: Both personai and area air samples are required. No significant reason for both appears justified. Exposures of workers are best determined by having workers wear battery-operated sampling devices (per sonal samplers) which provide a timeweighted concentration to which the wearer is exposed. If this sampling is done, area sampling would be superflu ous . c. Employee Observation of Monitoring Affected employees, or their representa tives, must be given a reasonable oppor tunity to observe monitoring and shall have access to the records thereof. Caution Signs and Labels a. Posting of Asbestos Areas Caution signs of prescribed specifica tions must be posted at all approaches to areas containing excessive concen trations of dust and at each location where dust may be excessive. b. Labels Caution labels arp required on all asbestos containing materials or on their containers except when a bonding agent is used to pre vent in any foreseeable use, airborne dust in excess of the exposure limits. Speci fications for such labels are prescribed. i USEI000017 -6 Housekeeping . Cleaning All external surfaces must be main tained free of accumulations of asbestos fibers if their dispersion could result in an excessive dust concentration. b. Waste Disposal Asbestos waste, containers and-con taminated clothing shall be collected and disposed of in sealed or closed .impermeable containers if its handling may produce excessive dust. Recordkeeping a. Exposure records must be maintained on personal and area monitoring for a minimum period of three years and shall be available upon request to OSHA or NZOSH. b. Employee Access? Every employee or former employee shall have reasonable access to any record which indicates his exposure and is required to te main tained. c. Employee Notification: Any employee who has received an excess exposure must be notified in writing of such exposure within five days of the finding. Medical Examinations a. Extensive medical examinations are re quired to be provided, or made avail able, at the employer's cost. Head quarters-Medical is alerting plant physi cians on this program. b. Types of Medical Examinations: (1) Preplacement'examinations within 30 calendar days following the first exposure of an employee. Such exami nation shall include a chest x-ray, medical history and pulmonary func tion tests. V USEI000018 7- (2} On or before January 31, 1973, and at laaat annually thereafter, very exposed employee shall be provided, or have available to him, a comprehensive medical examination. (3) A comprehensive medical examination shall be provided, or made available to every exposed employee within 30 days before, or after termination of employment. (4) No medical examination is required if records show such an examination within the past 1-year period. c. Records (1) Employers shall maintain complete and' accurate medical records for at least 20 years. Such records shall be made available, for inspection, ahd copying, to OSHA, NIOSH, author ized physicians and medical con sultants of OSHA and NOISH, and to the personal physician of employees or former employees if requested by such employees. (2) The employer shall be furnished all the medical information of the re quired medical examination by the physician who conducts same. mt i USEI000019 '.MJh RULES ANO REGULATIONS Ooru (or an Occupational Exposure exposure to avlioxt/)* doers snd tuc agi. Standard for Asbestos bv the National pearanc* ol adverse oiotuqic*! mamle..- Institute for Occuoauonal Safety and vauons. such a* asbcstoaU. lune cancers, Health <HIOSHi. FuMie node* waa clven and moMtheltoma. have given rue to of Bit receipt of the (weomoiendauoru controversy a* to Uie validity of the aad their areliability for ineneotlsi aad measuring technloue* used aad the relia copying. On or about February 39. 1173. bility of Uie relations auemnted to be the Advtaory Cooimiita* on A*booto* Duet eetahllahtd. Because of Uie long lapse auomiUed iu written racommeadauoe* tl ume between cuset at exposure and to Uie Aaeiatant Secretary of Labor for biological maolfosuuon*. r have now Occupational Safety and Health. evidence of the coaaequenctt of exposure, Furruant to the notice of nil# making. but we do not have. In general, accurate -* a hoanne waa held oo March 14 throufh measures of the levels of exposure oc 17.1(73. for the purvoM of reeetvtnc oral curring 30 or >0 years ago. which lusve data, views. and argument* oonoeminc given rise to these consequences. There the prooaaed standard. On or about are also cootrovervias concerning Uie March 31.1(73. the praeidlnc hearing ex* relative toxicity of tnc various kinds of amlner certified to the Assistant Secre a*oxtot. and varying nsrards in dif tary of Labor for Occupational Safety ferent workplaces. and Health the record of tho proceeding. It is fair to say that the controversy Tito record include* prehearing written ha* centered in the area between a two- oommaou. a transcript of tho oral pree* fiber TWA concentration and five-fiber amotion* made at the hearing, and nil* TWA concentration, with, variations on merou* exhibit* reelred during tho Uie Ume needed for compliance. Many course of tho hearing or within the pe* employers' support a five-fiber TWA. nod allowed after the otoee of the Must medical opinion Is divided between hearing. a two-fiber standard and n fit e-fiber The propoeed ftandard dealt with (11 standard. pennlaotble concentrations of aobeotoe In view of tho undisputed grave eon- fiber*; (2) methods of oompUanct; <J> sequences from exposure to asbestos warning signs: (4< monitoring: tli mod* fiber*, it tx omenilisl Uiat Uie eximaurt: be leal examinetiooe: and <*< rcoonlfceep* regulated now. on the basis of Uie best tag. Each of theee major ucopuaalf elic evidence available now. even though it ited ooaimante. Argument*. objoctloae. may not bo a* good a* soenuficstlly de and counterproposal*. They all hare been sirable. An asbestos standard can be re examined and conctdend. evaluated tn Uie light of Uie results of 1. 4eccpfdblc coney* frsflorn* of orbor* ongoing studies, and future studies. but fee daef. The propoeed gundard wuaJd cannot wait for litem. Lives of employees limit ocrupoannal exposure to (*hour are at stake. Ume*weichtod arerage (TWA) airborne It is concluded that there should be concentration* of aobeotoe dust not ex* one mlulmum standard of exposure to I raodtng five fiber* longer than fir* aabostoo applicable to all workplace* ex interomeier* per milliliter. Concentre* posed to any kind, or mixture of kinds, Uon* abore Art fiber* but not to exceed of asbestos. Reasons of practical ad Title 29--LABOR 10 fiber* (tolling eoacestrationi would ministration preclude a variety uf stand bo permuted up to 19 mtoute* tn an hour, ards for different kinds cf asbestos and Chap**' XV1U--Occupational Safety and Hal)h Adminjstiotion, Depart* nent a( Labor but for net more than ( huun tn any one l-liour day. NIOfift in effect haa rteummaided that the five-fiber TWA and UMlber of workplaces. Also, while the evidence tends to show Uiat croctdolltr. lor in stance. la more harmful than chrvsouir. the rvtdence U nut sufllelent tn e.-itabhkh PART 1*10--OCCUPATIONAL SAFETY AND HEALTH STANDARDS paak eoncentrattona be nermitted only for 3 yean: thereafter. TWA concentra tion* ahould be not more than 2 fiber* separate standards for varieties of axtietui* ItccaiiM1 there nuwl U- one standard Standard far Exposure fa Alhttlat Dust per cubic cculimetrr lem.'i of air. and guveiiilng exposure Ui all varlettc.-. <i( Iwee euncentrauona mould not emceed 10 uiheatiai. and In workplace* appnt cutty fibera/ent.*. with no' time restriction. morn hazardous than others; because On December T. 1171. an rmerxeney p-mporary standard concerning sxuoxure Ui asbestos fiber! na published In UM I'raciu. Rtetnt* <3* FJl. 33207). La ac- Numcroua objections and eaunterpro* vault hare been nude, with retard to both the limit* of asbestos fiber concen tration* and tha Uma period* to comtaly xotne present employees with rccui.tr ex posure to OAbcswix have probably al ready accumulated great dose* of tubesUa fibers, due to Idulicr level* uf e*- cirdwict with aeeuen i'ci (3) at the WII- with Uiera Some, tot example, lutrc rec poaure tn Uie post: beeause it snvn liuiui-AUieer OocueiaJoaal fiaf*ly and ommended return to o 13*fiber staudard Uiat level* of expoeur* which may he Health Act of 1*70. a notice of prooaaed of on earlier day; tx- a level adopted safe with regard to a.*be*tn*ix are not rilrmaxin* retarding a permanent tadcr tho Walah*Hcaley Public Con* safe with regard to meaotlieluxita: lieotandard for exposure to asbestos libera tract* Act In !M(. OUwr* nave recom eaiixe Uie xuuue require* Uie itruiretion iu published in the ItKiu Rmuxvca on mended a two-fiber standard Ui become of every employee, even of mu- wn may January 12. 1(72 <37 TJL Uti.The no* effective in g month*. Uien a une-flher have rcgulnr exposure to axbeshi* ilunng uee invited tnteraated peraonc to aubmlt aland*rd for 3 year*, and finally a ktu* a wurkhik Ilf* which m.ly reneh. or even n.ui orally aod la wnun*. data, new*, fiber standard after 9 year*. TTiese rec* exrcvd. 40 yearn: and because of *>-*eral and arguments concerning the proposaL ommendaUan* gtye a fair indication of uUier eonxlderaUon* whlcli Itave been On or about January 34.1(72. the Ad* tho wide spread of tho counterproposals. urged and are reflected In U revurtl uf rtwiry Committee oo Aabeatoa Duet aa No one ha* disputed that exposure to Uie proceedlag. the conflict la Uie mrdi- oitabiuned and rvqusxted to make amt* esboetof of high enough intensity aad cal evidence I* rxooived in favor of the ten recommendations with recard to the long enough duration u causally related health uf employee*. As of July 1 1*14. proposed ftandard on axbatoa. On or to asbeitosi* and cancers The duoute Is TWa concentration* of n*bes(<i.\ fibers about February 1. 1(73. the Department as to the determination oi a specific level longer than i micrometers sill nut be of Health. Education, and Welfare t.**ns- below wmen exposure is safe. V.irtous allowed to exceed two fibers n-. *un a mitted tn the Secretary of Labor a cri studies attempting tn establish Quantita ceding value of 10 fibers-`ec. Tlic current teria doeuaent contalaiai Reeomsicada* tive relations between specific levels uf TWa cunuentrsuons of fir*.- fiber; and MOItAl ItOltUt. VOW 37. NO. HO--WtDHtlOST. JUKI 7. 177) l USEI000020 *UUS ANO 1EGUIATIONS 11310 -ctCini concentrations of 10 fibxrs/ee. be permuted unoi July 1. HU. durInc whet win be a transitional period deemed oeeeeaary to allow employ*!* to nuie tbs aoadod changes for earning fibers, so lliat these * fluid not be released In the normal use of the products, iheutd ot be reduired to be labeled: and (31 words such as "danger* and "tencar" are unwarranted)/ alarming. g. Accord. The standard, as pronoeed end aa adopted, requires mauttennne* or records of monitoring sod cf medical examination*. Most of the controversy u. this aria has revolved around the sues- into compliance with the more lUiartnt Both contentions have meric and the Uoo whether an employer should be al standard. standard hat been changed accordingly. lowed to have acecm to the results of The record shows that the many work 4. Monitoring. The proposed standard the required medical examinations. Tlir operation* subloet to the single aahaetoe would have required personal monitor apprehension of those who have argued standard (textile. manufacturing. Indus* ing and environmental munitortng. against employer access i ba-cd on the trial. and marine Installation, etc.) erul Many Issues have been raised concerning expectation that seme employers will um- meet varying degrees of difficulty In the availability and reliability of meas the medical examinations as a means cl complying with the standard. In some uring instruments, frequency of moni screening employment applicants, and Plante, extensive redesign and reloca toring. and condition* in whteti monitor worse, aa grounds tor di.tcnarginc currcia tion of soulpmcot may he needed. It an- ing should be reoulrcd. Tbe adopted employees, wlto show signs of being i- (cart, however, the delay in the effective standard takes Uie ubieetlons tnto con lecud by exposure to asbestos Since the date of the two-fiber standard ertli pro* sideration. It requires periodic monitor purpose of the medical examinations u vide all employers e reasonable time to ing at intervals no longer than months, to monitor the health of employees e> comply. At the same time, so long as the thus allowing coruudrrsblc use and dis posed te the hazards of abcstce. em cctltng limit is complied with, no harm cretion. and prescribes the use of the ployees cannot tn reason be granted the is reasonably expected to result from ex membrane filter method, which Is tn ac privilege of refuzlnc to disclose to their posures during the treaslOoeal period. ceptable method for determination of employers results of occupational expo, 2. jfstAods o/ compliance. It has teen asbestos fiber*. sure-ft docs not make sense u require pointsd out by many persons, that pro* It has also beeb recommended that employer* to provide*medical examine- tecilon against asbestos flbers Is hart employees or their representatives should tloniCTf they cannot know and use the obtained by controlling the generation of have an opportunity .to observe the results of Uie examinations For three flbers first, and secondly, by controlling monitoring. The recommendation has reasons the standard providr* that etc the dispersion of released fiber* into the bMtt ififilCNid. plover* stay have a restricted access to ambient air of the workplaces. Therefore, I. Mtdieal cansfncttear. The pro some medical information. the standard requires feeslbte techno* logical controls and appropriate work posed standard would only require an appropriate mortice! eveminslkia an a On the outer hand. Uiere is no Intei.Uoo to allow employers to abut* medlral practices u the primary means of com* ptianee. Rotation of employees as a way of meeting the TWA concentration re quirement is allowed only in stated ex periodic basts. The generality of the pro posal has attracted many objections and also many helpful-comments. The recom mendations of KIOSH and of the Advi Information obtained pursuant to uic Act. te Uw detriment of employee.. Therefore, the administration of uie medical record* requirement sill be ceptional circumstances, because, as a sory Committee on Asbestos Duet were closely watched, and. In case* of abuse, general rule. It would be difficult to 1m* much awr* specific with respect te both appropriate action will be considered. piement. Personal protective equipment, such ss respirators, cannot bo railed upon because, among other reasons, they may ba so uncomfortable as to be bur densome. exeept for short periods of frequency and type of medical examina tions to be required. The comments vary as to Uia else* of employees te be ex amined aad as te the frequency of the eliminations. . The Issues discussed above are believed te bo the major ones. Numerous other Is sue* have been raised in the rulemaking proceeding*, Roane have been referred in tactdmtally. Many recommcnrtauoiti. fur time. Therefore. It ta expected that re*ptreters and shift rotation will be used The adopted standard requires medical etsmlnaUnrn both at the beginning end Instance, about work practice*, are so obviously memonous that their adop during the ported norsaury to Install en gineering controls and ts train employ ees in sound srort practices, but, after technological compliance has been arJUeved. their use must be limited te special wort situations and emergencies. When both are practicable, shift rota tion is required. 3. Labeling. The proposed standard stopped short of requiring labeling as the termination of employments exposed to concentrations of asbestos fiber*, sod also requires annual medical examina tions of every employee exiiosod to air borne eaneealretions of asbastoe. It bas been pointed out that tn certain indus tries. such as construction, an employee may work for aoverel unpioyers during the same year. Accordingly, the standard does not require either preemployment, tion needs no exposition here. Other recommcndaUons end many objertior.s have not been adopted for a vanetv ol mwiu which should be manifest. S\ oral, for instance, hurt* m-ttmmundcil the use of respirator* only pursuant to a variance, or in enarx of cnicri-.rnry and occasional short-term exposures. Tin- recommendation with resnrvi to vari bestos and asbestos-containing products. or termination, or periodic examineton ance* undoubtedly has many merit*, The proposed standard would have re of any employee wlto lias been examined but Is considered sdniinixlr.iitvcly liu.' quired only warning signs at locations tn accordance with the standard within practical. where asbestos hazards arc present. However, labeling, rather than warning sicna. has proved to be a point of con troversy. Both NIOSH and the Advisory Committee on Asbestos Oust recom the past year. One question which has been raised goes te whether Uu employer or U em ployee should be allowed te choose the stemming physician. The standard Accordingly, after consideration of the whole record of Uie proceeding, and pursuant to seeiiomc 6 <bl and ic) and l(e> of the WUUams-fitetger Occupa mended labels for asbestos products and gives the option to Uia employer. Bines tional Safety and Health Act of live (te containers, and these recommendstIons some employers already have a medical Stet. 1S83. ISM. 151*; 39 Uff C. 6S5. became very controversial In the course of the proceeding. Many eounterprw* proposals have beta made as te the lan guage of the warning as wall aa te ths products to be subled te the labeling requirements. employer*, la general, examination program in operation, and. also, have medical det-aruneats with coma expertise In the diagnosis of abastos-rdsted diseases. It seems mere reasontil i to permit them te utilize the present programs and expertise, thruf to 511. 2* CTO IllO.t. and to decretory of Labor's Order No. 12-71 (3t F.R. gist*. Part mo of TlUo 29 of Uic Cud* of Fed eral Regulations is amended as set* forth below. strongly contend that (1) finished prod permit an employee w choose a private (I* Section 1110.13 Is amended by re ucts which effectively entrap asbestos general practiuuoer. vising Table 0-3 to reau as follows: ' IBIUl IMISTU. VOC 37. NO. I IS--WtPNlMST. JUKI 7, It re 1 USEI000021 11 00 tUlEE AND tECULAnONS J Air muaiuiiik. to which any employee may be exposed (d) Ptrtanol protective ttruiomtnt-- * hall oot azcaad two fiber*, ioa*r than <1> Pomp1 Lance with the exposure limits Tiiu <1 I.iMimii Bna I coiurometer*, per cubic ocamaster ot preeertbed by paracrapb <b> of UUs sec air. ot determined by the method pre- tion Buy sot bo achieved by the ism of UsVW N|AI* aenbod la paracraph <) of thlc acctioa. respirators or shift rotation of em (I) CtUinp eonctntreUon. Ho em ployees. except: C '* f WiIMn*1 <d*MPU ployee chalt be exposed at any tuna to (0 Durtne the ume period necessary airboma concentration* ot un-in* to Inssail the *n(tnacrtn emstrols and fiber* In exooaa of 10 fiber*. 1oncer than to institute the work practice* required QWMII < fMMWIii <* M tM fwwmimiMum mn im HMEIt ManMMMtV I/m M ** tMv* -rTMX`1 M (M Mr- * m Itt^i Anmiimml Mini " -;h", %mo. i mlerometera. per euble centimeter ot air. aa determined by the mttltod pre- tenbed in paracraph (e) of thU eactioa. ici HttKodi a! compliance--U) Jfa- tuutrtnf method*. (I) t*nncrrt*f eon troll. Cnclnoartnc control*. eucii a*, but not limited to. Uolatlun. eneloiure, oxhauct ventilation, and duct collection, ahall be uaed to meet the exposure Umita prescribed in paracraph <b> of thu action. by paracraph <c> of this section: Oil In work tu*uoa* in which the methods prescribed In paracraph <c> of this section are etcher technically not feasible or feesibls io sn extent iruudleient to reduce the airborne eoneentraUons of asbestos fiber* below the limits prescribed by peracraph <b> of thu ccUon: or (ill) In emercencies. fofrfWMT fM TI'mwkllaMl --M I'm* 4MMMUtflbO... um <U> Local exheutt PcnLUalton. (a) Local exhaust ventilation and duct col lection eyitem* ahall be dsslfitcd. eon* ctruetcd. Installed, and maintained In accordance erlth the American National Standard Fundamentals Governins the <lv> Where both respirators and per sonnel rotation ore allowed by suodivi sions <|tv <11*. or <US> of this suboars- rraph. and both are practicable, person nel rotation ahall be preferred and used. (2) Where a respirator U permiurd by t*A IlM *% St4| ... > NT iM (am C . MmM4/U* Oeslsn and Operation of Local exhaust fiysum*. ANSI ZCS-1071. which U in suboaracrenh <1 ef this tiarscraph. it snail be selected from amon* those ap Imi * VuMrt lM UwtrMtMImiM , ..... ^1 a*>M/m> corporated by reference herein. tb) See 11010.0 eoneeralnc the avail* ability of ANSI Z9J-1071. and `the proved by the Bureau of Mines. Depart ment of the Interior, or the National In stitute for Oocimotinnal Safety and . .... ............. Mill** UrfMssN* * MflNN M f *. N--4 HM|M 1>IN ft? ifMMaM IMMMMM. Tim tUtm Mi M* IM I>M(M MMwMM N Mr M>im Ml, M MMMUW Ml *** MM** iHl--M Mf ll * I iWM>H |*| IM MliUW |NM MMmI M * V MMMMI HMU !-- MMIM M4 IMMill MMU IBT 0s M MiM ImiH M M ts MMIMW< Mm ib *---- i--r~r mm wMM (M iiimn iw *M*r masmwj *:A * hA* t* **t.(iM iMtfvtAMiM||*t IA* AiibMiMMIiMt*Mt aMntvIuMi MMMMMM* in i--* Mb MHKlit*Mrsw*mi--Mim t~* W / M/tf M IM WM W flteM MM 14 M|AI*. 2 A new ( tllO.Ua U added la Part 1910. readme ot follows: 6 1V10.VJ., Ashen--. maUttenanee of o Itlatortc file in connec tion therewith. The addreaa of the Amer ican National Standard* Xastitutc Is Clvan la 11010400. (Ill) Ftrtteuler tool*. AO hand-op erated aad powar-operated tool* which may produce or reieeee aabeatne fiber* in eaeeae of the cxmetira Halt* pre scribed in paracraph (b) of this section, aueh aa. but not limltad to. saw*, scorer*, abrasive whoala. and drills, ahall be pro vided with local exhaust ventilation systeens in accordance with subdivision Ul> of thu cubparacrapb. <21 Work practice]--(!) Wet mclhod*. Insofar ae practicable, asbestos shall ba handled, talced, applied, removed, cut. scored, or otherwise sorbed in a wet stale sufficient to prevent the emission of airborne fibers in exeats of the ex posure 1Unite prescribed In paragraph (b> ot thu aoetlon. unite* the usefulness of tna product would bo diminunod thereby. (If) Fortlentmr product! end opera tion*. No asbestos cement, mortar, caatinc. crout. plaster, or similar material eonuttunc asbestos shall be removed Health. Department of Health. Educa tion. and Welfare, under the provestons of 30 Cnt Fort 1! (37 rJt. 33M. Mar. 33. 1373). and shall be used In aooordanca with subdivisions <n. <U). (ill), and (ivi of thU subparacratth. (1) Air vurttiftno respirator*. A reusa ble or finds uc sir purtfoc rwqilretor. or o respirator daseribsd In subdlvUlon <U) or tUU of this subruirarap!i. shell be used to reduce the concrntrauoivt of airborne asbeatos fiber* in Uie rosiurator below the exposure limits prescribed In paracranh <b) of this section, when the ctillnc or the l-hour Uote-wnetitrd over see airborne oone~ntrailoat of atbectoa fiber* are icnsonnhlv exneeted to exceed no more than 10 Ilmen these lunik.. <UI Covered olr prl/ybio resobeiert. A full facepiece powered air purtfyinc respirator, or a powered air purtfyinc respirator, or o respirator dsscrlbcd in aubdtvuton <Ut) o( Utit lubparasrault. Hail be usod to reduce the eoneentra- Uons of airborne asbestos fibers la the respirator below the exposure limits pre scribed In perecraph <b) of this section, when the ceiUnc or the l-hour timeweichtod avarxoe eonccntrauons of , <a) OeAmtloot. For the purpose of tin* aocuon. in "Aibui* includes cnrysouie. amasite, eroeidofiu. treasd- from Pact, carton*, or other oonUdntrs hi which they ora shipped, without belac either wetted, or enclosed, or ventilated asbestos liber* or* reasonably expected to exeeed 10 times, but not 100 tunes, those limits. tits. antnophyfiito. aad actinouu. t2) "Asbestos fiber*" mcaru asbestos tutor* lonaer than 3 micrometer*. ti> Fermuilbte trtMt't to airborne eimcmcrattoiu of Hktilai itttrt--(1) 2lntor0 (EkIIh ll| 2. 1372. TIm hour thn*-wal*ht*d averse* alrbcro* concentration* ot aslwwtoa fiber* to which aay employee may be aapoaad Utah not exceed five fiber*, loader than so as to prevent effectively the release of airborne asbestos fibers la excess of the limit* prescribed in pstrmcraiih tbi of thU section. till) Spreptnp. dcaieiltioa, or removal. Employees eosaced in the spmytnc of asbestos. Uw removal, or demolition of pipes, structures, or equipment covered or insulatad with asbestos, and in the removal or demolition of asbestos In < 111) Typo "C~ tupplted-air retptrotor*. rMUsiwi flaw or pretiurt*drme*a elm. A type "C" cenunueus flow or pres sure-demand. auppUed-atr respirator haU be used to reduce the concentra . tions ot airborne asocstas nben in respirator below the cxiasure llnuu Uie pre scribed la paracraph <hi oi thu section, wben the eoiliac or tit* S-hour time- wichtsd averace airborne oenrentrs- 5 micrometer*, per euble e*aamt*r of air. aa determined by in* method fire* scribed In paracraph tel ot thu (action. (2) Standard effective July 1, I07C. sulation or eovannr* shall be provided with respiratory equipment in accord ance with paracraph <t'i(2i(liH of UUs ' Uons ut asbestos fibers art reasonably expected to exceed 100 times those limits. action and with special elotiiinc in ee- <iv) Cttabluhpteni ot a respirator pro The I-hour Urnt-vetchted overact air- eoraaacs wttit paracraph <d) (li of UUs pram (u< The employer shall astsbiuih borne concaatrsUmu ot asbaeto* flban action. s resplrstoi; procram In accordance with tmtiai stcitui. voc ar. no. no--wsoNUoar. juni 7. WJ USEI000022 Ultt ANO IEGUIATIONS 11321 the requirements of tb Americas Mi- where asbestos fiber* rt released (0 be subparagraph sitail conform to Use re uonal tandieas Practice* lor Haaptra* monitored in such a way u 10 determine quirement* of 30** x 14" vertical format van Protection. ANSI ZMA-IMf. watch whether every employee* exposure to signs specified in I tfio.MSidi 10. and u incorporated by rtfaraac* herein. ssbosta* fibers U below the limits pre* to this subdivision. The sign* snail dis k. c | lfilo.fi oonaarrung the oral]* scribed In paragraph (b* of this see* play the foliowtpg legend in the lower ability of ANSI U1.3-1MI end the matt* tioo. If the UmiU are exceeded, the em panel, with letter site* and style* of * ininei of an historic file m connection ployer shall immediately undertake a visibility at taut equal to that specified tharvwttn. The address of the Amenean compliance pruttrara tn accordsue* with tn this subdivision. National Standard* Institute U fives in peragrapfa id at this section. t ifio.ioo. (31 Prraowgf monitoring--<ll Sam* <ci No employee shall be assigned to Idas shall be roilccted (rant wtUiln Uie lain* requiring the use of respirators If. breathing sunc or the eraidoyret. an Upend ............................ -........- Petal wn 1 s*w xvtir. f* 1t< 1 c # r based uoon hi* most recent examination, membrane inters of t.c micrometer po* Dual llssard. li" kens IMrlf. an examintnc physician determines that lie employee will be unable to function normally wearing a respirator, at that the ssLicty or health at the employe* or other employees will be impaired by hie uae of a respirator. Such empttyce shall roasity mounted in an open-fae* Alter holder. Asmpies shall be taken for the determination of the hour tune* weighted average airborne concentra tion* and at the ceiling ouncenlrailoti* of asbestos fibers. AMd e".iAC I--` .. sever xeelgnve l-rvwvtiw Kueipowni. Da Net RkmIii lu *(* bidre* Ywr Wr* it-- <*. ethic Meek. VCawit. Is ' Ouuuc. dutiiic *1 be rotated to another lob or taven the nil Sampling frequency and patterns. fuirt- H orportunity to transfer to a different po- After the initial determinations rewired MreaUUAC A--!** O--l 14 pauiit U'hls Muon a-hose duties he Is able to perform by subparagraph <l) at this oeraxranh. Ms) Se llwerat.u. u with the umt employer. In the same are- samples shall be of aoeft fraqueiu-y and raw Um<u#. crapiucal area and with Uie same senior* paturn ax ta rapresent with rvastaiaWe Bumrutr. between line* -Judi be at least ny. status, and rate of pay 1m had lust accuracy the levels at exposure ( cut* equal tu Ue IMlalit id Uw upper oi any prior to such transfer. If such a different tdeyeas. ta ne ease shall the samiUnx be Ute HAN position is available. don* at interrais graaler than months 3) lxbvf-- <1* touting r;au- 3i Special ciuthinc: The employer for capiuyacx wlwe aspeettra ta wumurw Utn label* ahail br ailised to all raw tliall provide, and reouire Uie use at. ape* may raaeonably be foresect to essrvd matrrnuji. miaturr.. vrruii, waste, debris, utl clothing. such as cererails at similar the UmiU prescribed fey patagrapn ibi aud eUarr iweducts eontainmg asbeatna whole body dothine, head coverings, of tiili muon gloves, and foot oovcrtnfs far any cm* (3) Xamrp*mental moxifarlay .It) fibers, or to Uietr ctxitxmcr*. except Uwt no label is required where asbestos fibers pleyee exposed to airborne concentra aamplos shall ha eoUaetad from areas at have been modified by a bonding agrtiL tions of asbestos libers, winch exceed the reding level prescribed in paragraph lb) a work environment which are rapmeat* aura at tlM airborne concentration* at costing, (under, or otiwr material so that during any reasonably foreseeable me, at this section. to Change men: (l> At any fixed asbestos fibers which aaay nmeh Uto breathing aone of employed. ffwmpies Ilandline, storage, disposal, proreasine. or transportation, no airborne concentra place of employment exposed to airborne shall be collected on a membrane finer tions at asbestos fibers in excm* at the concentrations of asbestos fibers in ex* ma of Ute exposure limits prescribed in of 94 micrometer penalty mounted in an epen-ftee filter holder, fiaapiee shall exisMiirr Until* prescribed in paragraph <b* at Uii* wrilon will lie released. paragraph tb at tide section, the am* pieytr shall provide change rooms for employees workins regulartr at the pisea be taken tor the determtnaUeo of the g hour thnc-wslghtad overage airborne concentrations and of the railing con ill) Label aptaiAeatnma. The caution labels required by subdivision <i> of Uus subnaragrapti shall be printed in Idler* lii Clothes lockers: The employer rJudi provide two separate lackers or eon* looter* for each employee, so separated or isolated as to prevent contamination centration* of asbestos fibers. IU) fieerphae frequency and peffvrut. AfUr the initial determination* required by tubparagrapn (1) of this paragraph, 01 sufficient star and contrast a* tn I* readily rt-utlc and ler.mtr Hie label /JiU tele: Ciitnti* of the employee s street cloUtae from bis work clothes. till Laundartne: (si Laundering at aafeaswos contaminated etoUung shall be "one so as to prevent the release of air* stasias shall bo of such frequency and pattern ae to represent with reasonable accuracy the levels at exposure at Uie employees. In no ease sitail sampling bo at intervals greater Uian mouUta lor CtMitalu* moil* PWn *mM Crtatlna Dust reau.inc Asnviuw tu**' M*v Cuv uvrkHW Ouauy llum unis asoeitot fibers In esrexs at the ex* eumleyee* wnose espaxures to asbextos ill' ffuxsefcerpixp--<l> Cleaning All puaurc limits prescribed in paragraph lb) may reasonably be foreseen to exceed external surfaces ui tny place of employ of uus section. the exposure limits prescribed tn para ment shall be mslntstiivd tree of accu <b Any employer who gives asbestos* graph tb> of this section. mulations of aseextos fibers if, wun their -anlaminated clothing to another person Ml ffaspfoyee ofetcreallo* of mowiior* dispersion. Uiera would be an cxeesute for laundering shall inform such person fog. Affected employer*, or their ran- cotieeturauuti. it the requirement In to at this subdi vision to effectively prevent the release o< airborne asbestos fibers In stems of uw exposure limits prescribed m para graph >bi of thu aenuon. Contaminated clothing shall be transported In sealed Impermeable bags, or other dosed, impermeable containers, and labeled In accordance with para* crash tgi of this section. rassntetivea. shall be given a reasonable appommity to ebsires any monitoring required by this paragraph and shall bare access to the raesrds thereof. lg> Cashew *1gas gag tehcfs. tl) Canflew signs. (Ii Patting. Caution signs shall be provided and displayed st caeii location where airborne coneentrauotia of ssbestea fiber* may be tn exeess nf the exposure notita prescribed In parae.rapn (3) Wattt dupotat. Asbestos waste, scrap, debris, bar*, containers, raoil ment, and axboto*-conlaminated eiotiitnc. consigned for duqwssl. which msv produce in any reasonably forcMesaie use. handling, atomic, piocassinc. dtpoaal. or transportation airborne eonctmtranorw of asbestos fibers tn nets* of U>* esiaasur* limits praaeribed in paraersph bi of UUS secUun shall be eollectco and <e< Method at mcasarcMeai. All de* <b) ef this svetion. signs shall be posted disposed of la sealed impermeable bnes. terminations of airborne concentrations at sueh a distance from turn a location ar other dosed, impermeable cootamer*. of asbestos fibers shall bo made by the se that an employe* may read the sign* _. Ui Aeeordkcvtf--<! ffraosuve r- membrane filter method at <00-454 X and take necessary protective steps be srgt. Ivery employer snail maintain rec magnification) 14 millimeter objective! with pn*e contrast Illumination. <fi Monuortns--<)> falllai defemsi* fore muring the ares marked be the sign*, fiigns shall be posted at all ap proaches to areas containing exressir* concentration* at airborne asbestos mationt. Wtthtn < months of the r--*>n- fiber*. ords of any persons I or environments! monitoring required by Ihir. section Kwords shall be maintained lor a Rental uf at least 3 years and shall be made avail able upon request to tic Assistant Secre cation of this section, every employer (ID Sian spcet/icaiions. The warning tary of Labor im Occupational Butetr shall cause every place of rtnuioymU signs required by subdivision u> el this and HaalUi. the Director 0/ the National MSitat mitm. vot. tr. so. no--wiONitOAT. nort 7. ttrj USEI000023 it'iuur * f. ' Oeiimalioiial Safety and liana. Itaeords ehalt be retained by trailV -av*d to suuionsed npmenu* amployere far at taaat 34 yuan. in oi riuier. U) deceit. The eontenu of u>e roe* <2 Employee acrr. Every employee orda of uie medical examinations r/i lurnier employee snail have rtuon- required by UU* parxmpb ahall be made t*ir recta to tnr record required to ho available, for Inspection and copyte. nuinuunea hr suBparaermph <1> < tills to Uu Assistant Secretary of Labor for wirayrMp.'i. winch indicates ths sm* Occupational Safety and fTtaitn. the own exposure toaxOcstos Abort. Director af KIOSK, to authorised phyti* 3, Cmnovte nollAceium. Any cm* clan* and medical coneuliAtiu of either *..yre found to liar* been etpoeed ot any of them. and. upon Uie reoueet of an cm* oil* i a.raonie concentrations of ubi- Plum or former employee, to Itie pityst fliA-r. la acta of Uic limit* pro* olen. Any physician who conduct* a cnhed in oarmcrepn (bi of Uu* section medical examination required by this `iaii be notified in wriuns of the expo* * paragraph ahall furnish to the employer uire or. woo m practicable but not later of tho examined employer all Uie Infor i*. it S iwyi f Lite Ondlnc. Tlie employee mation specifically required by UUe nail ai*o be timely aotiflcd of the cor* paragraph, and any outer medical in* . relive action beinc taken. ; Xedical nsmiaeiiofu--U) Oen* XomaUon rtlaUd to oecupauonal ex posure to asbestos Aben. *rai. The employer ahall provide or make ivaiiablr at liu coal. medleaJ txamina- 9. A new f 1910.19 is added to Subpart joni rt'iative to espoaurt to aabertoa re* B ot Part 1910, reertlur aa follows: iutred Q; this parmcrapn. 21 I'replaecmtnt. The employer ahall .-irovii!- or make available to eaeb of hie -muicvrr* within 30 calendar day* fol- -<nir am Art employment in aa v-rupuuon exposed to ijrborne eon* antra* ions of aeoeatoe Abort, a cempre* .ensue medirai uaminauon. erhieh tftall n.eiudr, aa a minimum, a client roent* I 1910.19 Sahaslas dust. ( Section 191&S94 snail apply to the ex posure of every employee to asbestos dust In every employment and place of employment covered by 11910-13. I 1910.13.11910.14.11910.14. or 11910.10. In Ueu of any dlScrent standard on ex posure to asbestos duct which would *nnriii innatcnor-antenor I 4 a 17 oihcrwtse be oppllcahlo by virtue ot oar -tcht*.. a Matnry to elicit symptom* ot these sections. ttciiocy of respiratory diaeaae. end todmenary funeaon tern to include lorccrt vital capacity <7VCi and forood xolratnry volume at 1 aecond (TTVi i. <3) a aauai rnaiMtimi. On or he* f*oc January 31. 1373. and at ieaet aa* miaUy tAerealter. every employer ahall provide. or make available, comprehmt* ive mruiral examination* to each af hie *tup)05W entaani m oeeunauoae as* woaed to airborne eoaccntratioAe of aa* hretne Ab^rs. Sueh annual examination thall include. as a minimum, a cheat ffSerftar Safe. Paracraph <hi (21 ot 11410.43a than become effective July 1. 1970. All ether pcwvtttonc of II 1919J3a. 1910.43. aad 1910-19 shall hooooM effes* Uve July 7.1979. The current emerrrncy tantporarjr standard remains in effect until July 7. 1972. (Sees, a a 94 9tai 1999. *9S: 99 VAC. SC*. o7: m orn istec Iivrup SS tssars Orese <sa ll-Ti. m PJL otm> Signed at Washington. D.C, Uds 3d day af June 1979. , , njenfenovram <poeterior*antcrtor 14 x :7 inriie**. a history to dieit symptom* atoinry of rcenimtory diaeaae. and puim<..*mnr function imu to include J*ir*t*e vital capacity iPVC) and forced exmrutnrr volume at 1 aecond (7XV.O. O. C. OnnTiisa AMttlatU Seerefary ot tabor. Mf ' ITO DSC.T3-SS74 run 9 4>iat: emUf 4* TVi-atnufioa of empioymeaf. The mukTvr shall provide, or make avail* wtuun 3u calendar aar< before or after uie termination of employment of any einuloyee encxeed in an oeeunaaon rspo-eid tn airborne concentrations of ajtpwton fibers. a comprehensive medical examination watch shall include, as a minimum, a ehect roentgenogram fpoa* teruir-anicnor 14 x 17 Inchesi. a history to elicit symptomatology of respiratory disease. aad pulmonary function lasts to include forced vital capacity ifVC1 ami fiir-ed expiratory volume at 1 aecond PEV .*. i- Accent rzemmetiom. Ko medical rxaminaUen Is required af any am* iUoy>r. it adequate records show that ute employee hat been examined In ac* "uvrtm.ee with uitx patacreph within the laid t-year period. <c Jfedieaf records--<i) iielntt- a * P*niiloyen of employees examined <ur.uunt to this pareersph shall cause -n ii>- maintained ecmpletr and accurate records of all such medical examina* rttitat tfdtttit. you it. mo. no--wionmoat. Junt t. wj United States Steel Corporation T: General Superintendents, Plant Managers and Attendees at OSHA Regional Meetings Inttrorganization Corraapondanca Data: July 3 , 1972 fnm: Kenneth M. Morse, Director Environmental Health Subjaet Proposed Permanent Asbestos Standard OSHA published its permanent (final) Standard for Exposure to Asbestos Dust, in the Federal Register of June 7, 1972. A copy of this standard is enclosed for your informa tion. We suggest your thorough review of this standard due to the highly restrictive requirements that are established. It is further suggested that you inventory your uses of asbestos compounds as to location, jobs and quantity used per month or year in order to establish a priority list of jobs and areas for monitoring. We are indicating below the pertinent aspects of this standard. 1 Permissible Maximum Dust Exposure a. As of July 7, 1972, the 8-hour time-weighted average exposure is limited to-5 fibers per milliliter of air for dust not exceeding 5 micrometers in length. However, as of July 1, 1976, the limit is reduced to 2 fibers per milliliter. b. While a time-weighted average is determined over an 8-hour work period, the dust concen tration to which a worker is exposed cannot exceed 10 fibers per milliliter for any period of time (ceiling value). c. This standard applies to the use of any type of asbestos. 2. Methods of Compliance Feasible technological controls and appropriate work practices must be the primary means of controls. Rotation of employees is allowed only in stated exceptional circumstances. The use of respirators and shift rotation of employees will be limited. The methods for controls consist of, -tnrt are not limited to, the following: USEI000025 2- - a. Engineering Controls (1) Dust collection systems of the local exnaust ventilation The design criteria for such systems is the American National Standard Fundamentals Covering the Design and Operation of Local Exhaust Systems (ANSI 29.2-1971). (2) Particular Tools All tools which release dust in excess of the exposure limits when used on asbestos' must be equipped with local exhaust ventilation. b. Work Practices (1) Wet methods must be used, when handling asbestos, to preclude excessive dust exposure, unless the usefulness of the product would be diminished. (2) Asbestos products cannot be removed from containers in which they are shipped un less they are wetted, or enclosed, or ventilated. (3) Employees engaged in spraying asbestos, the removal, or demolition of pipes, structures or equipment covered or in sulated with asbestos, or demolition of asbestos insulation or coverings, shall be provided approved respiratory equip ment and special clothing. 3. Personal Protective Equipment a. Respirators and shift rotation of workers are permitted only under the following conditions: (1) During the period necessary to install engineering controls and the changes in work practices. (2) Where the work practices, as listed above, are not feasible or cannot reduce the dust to within the exposure limits. USEI0QQ026 -3- (3) In emergencies (4) Where both respirators and personnel rotation are allowed, the latter shall be preferred. b. The types of air-purifying respirators allowed are based upon the dust concen tration to which an employee is exposed and must be of the types approved by the U. S. Bureau of Mines (.USBM) and the National Institute of Occupational Safety and Health (NIOSH). (1) When the employee may be expected to receive an exposure no more than 10 times the exposure limits, a reusable or single use air purifying respirator of the non-powered or supplied air type may be used. (This is the commonly used mechanical filter type.) (2) When the exposure is expected to be be tween 10 to 100 times the exposure limits, a full face piece, oral-nasal, or continuous flow or pressure-demand types of supplied-air respirators must be used. (3) When the exposure is expected to be in excess of 100 times the exposure limits, only the supplied-air respirators of the continuous flow or pressure-demand class can be used. These are now classed by USBM and NIOSH as Type "C". (4) A respirator program must be established by the employer in compliance with the American National Standards Practices For Respiratory Protection (ANSI Z88.21969). If an employee cannot function normally when wearing a respirator, as determined by a physician from the employee's most recent examination, he must be rotated to another job or provided the opportunity for a job transfer. The job to. which he USEI000027 -4- may be rotated or may transfer must be in the same geographical area and with the same seniority, status and rate of pay. c. Special Clothing Protective clothing must be provided to employees exposed to a dust concentration in excess of the "ceiling value" (10 fibers per milliliter). The use of such clothing must be required by the employer. d. Change Rooms (1) Change rooms for employees regularly employed must be provided when employees have dust exposures in excess of the exposure limits. (2) Two separate lockers, or containers, must be provided for each employee ex cessively exposed to dust. They must be separated, or isolated, to prevent con tamination of street clothes. (3) Laundering Clothing (a) Laundering of asbestos contaminated clothing must be done. It appears that such laundering shall be the responsibility of the employer but it is not so stated. (b) The employer must notify the person to whom he gives clothing for laundering that it shall be done in a manner preventing exposures in ex cess of the exposure limits. (c) Contaminated clothing must be trans ported in properly labeled closed impermeable containers. 4. Measurement of Asbestos Dust a. Method Asbestos dust surveys will be conducted by Headquarters-Environmental Health for the present, due to the detailed procedure which such a survey involves. Requests for such survey should be directed to K. M, Morse, Director of Environmental Health. USEI000028 -5 b. Monitoring Requirements (1) Initial Survey: Within six months a survey must be conducted to de termine the exposure of every em ployee to asbestos dust. If the exposure limits are exceeded, a control program, as herein indicated must be immediately initiated. (2) Periodic Survey: At least every six months for all employees who may be reasonably expected to have exposures exceeding the exposure limits. (3) Personal and Area Samples: Both personal and area air samples are required. No significant reason for both appears justified. Exposures of workers are best determined by having workers wear battery-operated sampling devices (per sonal samplers) which provide a timeweighted concentration to which the wearer is exposed. If this sampling is done, arej; sampling would be superflu ous. c. Employee Observation of Monitoring Affected employees, or their representa tives, must be given a reasonable oppor tunity to observe monitoring and shall have access to the records thereof. Caution Signs and Labels a. Posting of Asbestos Areas Caution signs of prescribed specifica tions must be posted at all approaches to areas containing excessive concen trations of dust and at each location where dust may be excessive. b. Labels Caution labels are required on all asbestos containing materials or on their containers except when a bonding agent is used to pre vent in any foreseeable use, airborne dust in excess of the exposure limits. Speci fications for such labels are prescribed. USEI000029 -6- 6. Housekeeping a. Cleaning All external surfaces must be main tained free of accumulations of asbestos fibers if their dispersion could result in an excessive dust concentration. b. Waste Disposal Asbestos waste, containers and con taminated clothing shall be collected and disposed of in sealed or closed impermeable containers if its handling may produce excessive dust. 7. Recordkeeping a. Exposure records must be maintained on personal and area monitoring for a minimum period of three years and shall be available upon request to OSHA or NIOSH. b. Employee Access: Every employee or former employee shall have reasonable access to any record which indicates his exposure and is required to be main tained. c. Employee Notification: Any employee who has received an excess exposure must be notified in writing of such exposure within five days of the finding. 8. Medical Examinations a. Extensive medical examinations are re quired to be provided, or made avail able, at the employer's cost. Head quarters-Medical is alerting plant physi cians on this program. b. Types of Medical Examinations: (1) Prepl3cement examinations within 30 calendar days following the first exposure of an employee. Such exami nation shall include a chest x-ray, medical history and pulmonary func tion tests. USEI000030 -7- (2) On or before January 31, 1973, and at least iinnually thereafter, every exposed employee shall be provided, or have available to him, a comprehensive medical examination. (3) A comprehensive medical examina tion shall be provided, or made available to every exposed employee within 30 days before, or after termination of employment. (4) No medical examination is required if records show such an examination within the past 1-year period. Records (1) Employers shall maintain complete and accurate medical records for at least 20 years. Such records shall be made available, for inspection, and copying, to OSHA, NIOSH, author ized physicians and medical con sultants of OSHA and NOISH, and to the personal physician of employees or former employees if requested by such employees. (2) The employer shall be furnished all the medical information of the re quired medical examination by the physician who conducts same. USEI000031 11151$ RULES AVO REGULATIONS |TJP 72 1U| tions for an Occupational Exposure exposure to asbestos fibers and the ap part to--articles conditionally FREE, SUBJECT TO A REDUCED Standard for Asbestos by the National Institute for Occupational Safety and Heal Ui (NIOSH i. Public notice was given pearance of adverse biological manifes tations, such as asbestosLs. lunc cancers, and mesothelioma, have given rise to RATE, ETC. of the receipt of the recommendations controversy as to the validity of the Free Withdrawal of Supplies and Equipmont for Aircraft and their availability for inspection and measuring techniques used and the relia copying. On or about February 35, 1973, bility of the relations attempted to be the Advisory Committee on Asbestos Dust established. Because of the long lapse Tn accordance with section 109'di. Tariff Act of 1930. as amended '19 US.C. 1309'dit. Lite Department of Commerce has found and under date of April 35, 1973. has advised the Treasury Depart ment that Poland allows privileges to aircraft registered in the United States and engaged in foreign trade substan tially reciprocal to those provided for in sections 309 and 317 of the Tariff Act of 1930, as amended (19 U.S.C. 1309, 1317). The same privileges are therefore hereby extended to aircraft registered in Poland and engaged in foreign trade effective as of the date of such notification. Accordingly, paragraph <f) of 110.59. submitted its written recommendations to the Assistant Secretary of Labor for Occupational Safety and Health. Pursuant to the notice of rule making, a hearing was held on March 14 through 17,1973, for the purpose of receiving oral data, views, and arguments concerning the proposed standard. On or about March 31, 1973, the presiding hearing ex aminer certified to the Assistant Secre tary of Labor for Occupational Safety and Health the record of the proceeding. The record Include* prehearing written comments, a transcript of the oral pres entations made at the hearing, and nu merous exhibits received during the of time between onset of exposure and biological manifestations, we have now evidence of the consequences of exposure, but we do not have, in general, accurate measures of the levels of exposure oc curring 30 or 30 years ago. which have given rise to these consequences. There are also controversies concerning the relative toxicity of the various kinds of asbestos, and varying hazards tn dif ferent workplaces. It is fair to say that the controversy has centered in the area between a two- fiber TWA concentration and five-fiber TWA concentration, with variations on the time needed for compliance. Many customs regulations, is amended by the course of the bearing or within the pe employers support a five-fiber TWA. insertion of Poland in appropriate al riod allowed after the close of the Most medical opinion is divided between phabetical order and the number of this heeling. a two-flber standard and a five-fiber Treasury decision in the opposite col The proposed standard dealt with <1) standard. umn headed "Treasury Decision's)" in, permissiole concentrations of asbestos In view of the undisputed grave con the list of nations in that paragraph. (Secs. S00. S17. S34. 44 Stst. #0. u emended. S9. es amended, 7S; 19 US.C. 130*. 1317, 1034) (siALl Eswnt P. Rains. Acting Commissioner o/ Customs. fibers; (3) methods of compliance; (1) warning signs; (4) monitoring; (5) med ical examinations; and (6) recordkeep ing. Each of these major proposals elic ited comments, arguments, objections, and counterproposals. They all have been examined and considered. sequences from exposure to asbestos fibers, it is essential that the exposure be regulated now. on the basis of the best evidence available now, even though it may not be as good as scientifically de sirable. An asbestos standard can be re evaluated In the light of the results of Approved: May 35,1973. EOCCNt T. Ross13ES. Assistant Secretary o/ the Treasury. int Doc 72-SS78 rued --72::SO am) 1. Acceptable concentration* ot asbes tos dust. The proposed standard would limit occupational exposure to t-hour time-weighted average (TWA) airborne concentrations of asbestos dust not ex ceeding five fibers longer than five ongoing studies, and future studies, but cannot wait for them. Lives of employees are at stake. It is concluded that there should be one minimum standard of exposure to asbestos applicable to all workplaces ex micrometers per milliliter. Concentra posed to any kind, or mixture of kinds, tions above five fibers but not to exceed of asbestos. Reasons of practical ad Title 29--LABOR 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 Chopler XVII--Occupolionol Safety and Health Administration, Depart ment of labor but for not more than 5 hours in any one 8-hour day. . NIOSH in effect has recommended that the-five-fiber TWA and 10-fiber of workplaces. Also, while the evidence tends to show that crocidolite. for In stance. is more harmful than chrysotile. the evidence is not sufficient to establish PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS peak concentrations be permitted only for 3 years: thereafter. TWA concentra tions should be not more than 3 fibers separate standards for varieties of asbestos. Because there must be one standard Standard far Exposure to Asbestos Dust per cubic centimeter (cm.*) of air, and governing exposure to all varieties of peak concentrations should not exceed 10 asbestos, and in workplaces apparently flbers/em.*, with no time restriction. more hazardous than others; because On December 7. 1971. an emergency Numerous objections and counterpro some present employees with reguiar ex temporary standard concerning exposure posals have been made, with regard to posure to asbestos have probably al to asbestos fibers was published In the both the limits of asbestos fiber concen ready accumulated great doses of asbes PestfAL Ricitrca <36 PJt. 33307). In ac trations and the time periods to comply . tos fibers, due to higher levels of ex cordance with section 6<c) <3) of the Wil- with them. Some, for example, have rec posure in the past: because it appears liams-Steiger Occuptalonai Safety and ommended return to a 13-flber standard that levels of exposure which may be Health Act of 1970. a notice of proposed of an earlier day; l.e,, a level adopted safe with regard to asbestosis are not rulemaking regarding a permanent under the Walsh-Healey Public Con safe with regard to mesothelioma: be standard for exposure to asbestos fibers tracts Act in 1969. Others have recom cause the statute requires the protection was published in the FtotxAt Rzctsrxx on mended a two-fiber standard to become of every employee, even of one who may January 13. 1973 (37 PJt. 466.'. The no effective in 6 months, then a one-fiber have regular exposure to asbestos during tice invited interested persons to submit itanderd for 3 years, end finally a zero- a working life which may reach, or even both orally and in writing, data, views, fiber standard after 3 years. These rec exceed. 40 year.i; and because of several and arguments concerning the proposal. ommendations give a fair indication of other considerations which have been On or about January 34. i973. the Ad the wide spread of the counterproposals. urged and are reflected In the record ot visory Committee on Asbestos Dust was No one has disputed that exposure to the proceeding, the conflict in the medi established and requested to make writ-' asbestos of hich enough intensity end cal evidence Is resolved, in favor ot the ten recommendations with regard to the long enough duration is cnusully related health of employees. As of July | jots proposed standard on asbestoe. On or to asbcslosis and cancers. The dispute Is TWA concentrations 51 asbestos fibers about February 1. 1972. the Department as to the determination of a specific level longer, than X mlcrnmet^p will nn- he of Health. Education, and Welfaie trans below which exposure Is safe. Various allowert in evreef tm u -3b.s mitted to the Secretary of Labor a cri studies attempting to establish quantita ceiling vnlue ot 10 fibers cc The current teria document containing Recommenda tive relations between specific levels of TWA concentrations n( fl\T~?Tbers. and EEOEtAt REGISTER, VOL 37, NO. ) 10--WEDNESDAY. JUNE 7. 1772 USEI000032 RULES AND REGULATIONS 1131!) fibers, so that these would not be released 8. Records. The standard, as proposed In the normal use of the products, should and as adopted, requires maintenance of IKK not be required to be labeled; and (2) records of monitoring and of medical deemed neresiwry lo allow employers to words such as "dancer" and "cancer" are examinations. Most of the controversy m make the needed changes for coming unwarrantedly alarming. this area has revolved around the ques Into coiupUaucc with the more stringent Botli contentions have merit, and the tion whether an employer should be si- 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 operation! 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 dial, 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 relocae toring. and conditions in which monitor worse, as grounds for discharging current tlon 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 tha 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 ceiling 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. Methodt o/ 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 ben accepted. ployers may have a restricted access to ambient air of the workplaces. Therefore, 3. Medical examinations. The pro some medical information. 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 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 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 record* requirement will be ceptional circumstances, because, as a sory Committee on Asbestos Dust were closely watched, and. In coses of abuse, general rule, it would be difficult to im much more specific with respect to both appropriate action will be considered. 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 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 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 time. Therefore, it is expected that res The adopted standard requires medical instance, about work practices, are so pirators and shift rotation will be used examinations both at the beginning and obviously meritorious that their adop during the period necessary to install en the termination of employments exposed tion needs no exposition here. Other gineering controls and to train employ to concentrations of asbestos fibers, and recommendations and many objections ees in sound work practices, but. after also requires annual medical examina have not been adopted for a variety of technological compliance has bees tions of every employee exposed to air reasons which should be manifest. Sev achieved, their use must be limited to special work situations and emergencies. borne concentrations of asbestos. It has been pointed out that In certain indus eral. for instance, have'recommended the use of respirators only pursuant to a 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. 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 variance, or in cases of emergency and occasional short-term exposures. The recommendation with respect to vari ances undoubtedly has many merits, The proposed standard would have re of any employee who has been examined but is considered administratively Im quired only warning signs at locations tat accordance with the standard within practical. where asbestos hazards are present. the past year. Accordingly, after consideration of the However, labeling, rather than warning One question which has been raised whole record of the proceeding, and signs, has proved to be a point of con troversy. Both NIOSH and the Advisory Committee on Asbestos Oust recom mended labels for asbestos products and 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 pursuant to sections 8 <b) snd (c> and 8(e) of the WUliams-Steigcr Occupa tional Safety and Health Act of 1970 (14 containers, and these recommendations some employers already have a medical StaL 1593. 1598. 1599; 29 US.C. 855. became very controversial In the course examination program In operation, and, 657). 29 CFR 1910.4. and to Secretary of of the proceeding. Many counterpro also, have medical departments with Labor'* Order No. 12-71 (38 F.R. 8754). 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, some expertise In the diagnosis of abestos-related diseases, it seems more reasonable to permit them to utilize the present programs and expertise, than to Fart 1910 of Title 29 of the Code of Fed eral Regulation* 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 0-3 to read s follows: EEOEKAl 8E6I5TEI, VOL IT, NO. 110--WEDNE50AT, JUNE T, l*rj USEI000033 11.EO RULES AND REGULATIONS ] 910.01 Air ronlaminanU. to which any employee may be exposed (d> Personal protective equipment-- shall not exceed two fibers, longer than <1> Compliance with the exposure limits Ti* 0+ Miniiui Ocm S 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 Wppto to*/** scribed In paragraph <e> of this section. respirator* or shift rotation of em (3) Ceiling concentration. No em ployees. except: Plflrn4 it tilth.*' ployee shall be exposed at any time to (|) During the time period necesjt nr airborne cencentratlons of asbestos to install the engineering controls and fibers In excess of 10 fibers, longer than to institute the work practices required rrt.o4,AiU' U* lh# ?siw* from th* ffimui r wnm tunuJft hr l|UAfU. TtiJvtmtr U**M mkuiftttd from fV* IMUlO* for qUATU. lr*kj<lio< uttUfAJ UUt'MitACtvUl mru*.................... 30 vat# tomtit* to> S micrometers, per cubic centimeter of by paragraph <e) of this section; air. as determined by the method pre scribed m paragraph (e) of this section. (c> Method* of compliance--(1) En-. gineering method*. <1> Engineering con trol*. 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. 01) 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 (til) In emergencies. f;:h On thtA l?4 wy+ t-iillii* ftlttOK *<(*............................. Tuie........................................ 3D l*trth>od war..................... nnphfu (BAturti).................... > r;dost (forplrobto (rpcttoa *# tts fiot)......................................... F*f Iftta W.\ IfOt---................. 3.4mt*P or Ji **1 ut Xufeane* t)vt* h^t.irohH fractiui... Iwtal du*(....................... *IM>t+2 IS kite M* th Umc Mi Soji fno.n Punic porifckp*r; i MUImtn of LwrtieJai pr ItMimcT >*jnp** enenitd * Th* rxrctnia** of vy*. h <h tmouiH dttrnatn*' oxcrfii in thovr irvuiNOP s trtrft il*^n to bo appHoobt* A% by (he x phM oHUrut nacfli both aoRfeAntittfen * M><*tton to thM item (I** fftctk.fi puhii<c mi* rinxt#ruties: prf mb* H.Arf tlfc foot of air, booed lerltMtA. mm mlto m Ui tarmute iron air*liori* amyfeo, trieh other method* nbfVM filter lotohod to tun. prmnt noarts tor tk# to b tW^fniirwid from <tor o-ith tt* tottott ArrMvnamte dUmrtfr (aim dmuty aCifrr) P>ir*nt wirlr X-s |.U 10 ? kj St 0 T'* ander immc M*r u Urn >* a:. AF.t )Tirpte*t7t. It \u 'ptr*>4+ tfoclwn to onto do-' o dAATmir>*1 with X n* aoTTAiniooUHt Wtl.iL Vn'.M SlC M**I* llFU"' fmi dtltt is 44 2. A new 11910.93a U added to Part 1910. readme aa follow*: ill) 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 Design and Operation of Local Exhaust Systems. ANSI Z9.2-1971, which Is in corporated by reference herein. <b> See 11910.6 concerning the availability of ANSI Z9.2-1971, and the maintenance of a historic file in connec tion therewith. The address of the Amer ican National Standards Institute is given in i 1910.100. (Ill) Particular tool*. All hand-op erated and power-operated tool* 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, abrasive wheels, and drills, shall be pro vided with local exhaust ventilation sys tems in accordance with subdivision (11) ol this subparagraph. (2) Work practice*-- d) Wet methods. Insofar a* practicable, asbestos shall be handled, mixed, applied, removed, cut. (cored, or otherwise worked in a wet state lufllclent to prevent the emission of airborne fibers in excess of the ex posure limit* prescribed In paragraph tb) of this section, units* the usefulness of the product would be diminished thereby. (II) Particular product* and opera tion*. No asbestos cement, mortar, coat ing. grout, plaster, or similar material (iv) Where both respirators and per sonnel rotation are allowed by subdivi sions (1). 01). 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 subparagraph (1) of this paragraph, it shall be selected from among those ap proved by the Bureau of Mines. Department of the Interior, or the National In stitute for OccumUionsl Safety and Health. Department of Health, Educa tion. and Welfare, under the provisions of 30 CFR Part II (37 PJL 6244, Mar. 23, 1972). and shall be used in accordance with subdivisions M>. (11), (lilt, and (tv) of this subparagraph. (I) Air purifying respirator*. A reusa ble or single use air purifying respirator, or a respirator described In subdivision <ii) or (iti> of this subparagraph, shall be used to reduce the concentrations of airborne asbestos fibers In the respirator below the exposure limits prescribed In paragraph (b> of this section, when the ceiling or the l-hour time-weighted aver age airborne concentrations of asbestos fibers are reasonablr expected to exceed no more than 10 times those limits. (II) Powered air purifying respirators. A full facepiece powered air purilying respirator, or a powered air purifying respirator, or a respirator described in subdivision (111) 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 l-hour time- 1910.93a AobccMM. containing asbestos shall be removed weighted average concentrations of a) Definition*. Tor the purpose of from bags, cartons, or other containers asbestos fiber* are reasonably expected this xectlon. <l> "Asbestos" Include* chrysotlle. amoaite. crocidolitc, tremo- in which they are shipped, without being either wetted, or enclosed, or ventilated to exceed 10 times, but not 100 times, those limits. Ute. anthophylllte, and aetinollt*. 2i "Asbestos fiber*" means asbestos fibers longer man S micrometers. <b) Permisitblt exposure to airborne concentrations of asbestos fiber*--ill to as to prevent effectively the release of airborne asbestos fibers in excess of the limits prescribed In paragraph <b) of this section. (III) Spraying, demolition, or removal. (ill) Type "C" tvpplied-air respirators, continuous flow or pressure-demand class. A type "C" continuous flow or pres sure-demand. supplied-alr respirator shall be used to reduce the concentra Standard effective July 7, 1172. The Employees engeged in the spraying of tions of airborne asbestos fibers in the (hour time-weighted average airborne asbestos, the removal, or demolition of respirator below the exposure limits pre concentrations of asbestos fibers to pipes, structures, or equipment covered scribed In paragraph (b) of this section, which any employee may be exposed or insulated with asbestos, and In the when the celling or the l-hour time- shell not exceed five fibers, longer than removal or demolition of asbestos In weighted average airborne concentra 5 micrometers, per cubic centimeter of sulation or coverings shall be provided tions of asbestos fibers are reasonably air. a* determined by the method pro,>crlbed in paragraph <e> of this section. <2i Standard effective July 1, 1976. with respiratory equipment in accord ance with paragraph (d)(2) (111) 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-weluhted 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 fiOCSAl MSISTtt, VOL 37. NO. 110--WtONtSOAT, JUNC 7. ivrj USEI000034 l i.:-j RULES AND REGULATIONS f*. f'ir (Icc'in <linfuiI .Tuf'ity *!td tion . lUicords shall be retained by Instruction section has been revised ac ai.'l t/i kinliiirwd Mi*"7V:t.Uk- employers for at least 20 ycurs. cordingly. Minor editorial changes have Ljvc.> 'il riiin r 'in Access. The contents of the rec also been made. 12' Emiihnr-c am-.- Every employee ords of the medical examinations 1. 8ectlon 9-1.101 Scope of subpart, i.-, und tormvr nwiln\w -hail have reason required by this paragraph shall be made revised to read as follows: able aeceii to nv ii.c/rd required to be maintained by submtragrauli Ht ot this available, for inspection and copying, to the Assistant Secretary of Labor for 9--1.101 Scope of -ubpsri. imra.-rapli. which indicates the em- Occupational Safety and Health, the This subpart describes the Atomic j.,,i'.,ec s ov. n exposure to asbestos fibers. Director of NIOSH, to authorired physi Energy Commission Procurement Regu <2i Employe noitdcahon. Any em* cians and medical consultants of either lations and the AECPR Temporary Reg. found to hate been exiwsed atony of them, and, upon the request of an em illations. It also describes exclusions t.//.<. '<1 airoornc concentrations of asbes- ployee or former employee, to his physi from the AECPR as contained in ths tr.' fibers in excess of the limits pre- cian. Any physician who conducts a AEC Procurement Instructions. ttno'-d in pangrauli <t>> of this section medical examination required by this 2. Section 9-1.102 Establishment ot be notified in ten tin* of the expo* paragraph shall furnish to the employer AEG Procurement Herniations, is revised ture as soon as practicable but not later of the examined employee all the infor to read as follows: than 5 days of the findmr. The employee r.'.s:: also be ume<y notified of the cor* reetite action being taken. i* Medical examinations--'ll Gen mation specifically required by this paragraph, and any other medical in formation related to occupational ex posure to asbestos fibers. 9--1.102 EalaMielimenl of tin- .W.C. Procurement Regulations end tlie AECl'R Temporary Regulation-. eral The employer shall provide or make 9-1.102-1 AEC Procurement Resolu available at his cost, medical exaituna* 3. A new 11910.T9 Is added to Subpart tion*. tions relative to exposure to asbestos re* B of Part 1910'. reading as follows: quired by tnis paragraph. <21 Preplacement. The employer shall | 1910.19 Asbestos dust. provide or make atailablc to each of his Section 1910.93a shall apply to the ex employees, in thin 30 calendar days fol* posure of every employee to asbestos lowing his first employment m an dust In every employment and place occupation exposed to iJrboine con* of employment covered by 11910.13. cenirauons ol asbestos fibers, a compre I 1910.13. f 1910.14, | 1910.15. or I 1910.16, hensive medical examination, which shall la lieu of any different standard on ex- Include, as a minimum, a chest roent pocure to asbestea dust which would genogram (posterior-anterior 14 x 17 ' otherwise be applicable by virtue of any lnche:->. a history to elicit lymptom- of those sections. wtoiogy of respiratory disease, and Effective date. Paragraph <b><3> of pulmonary function tests to include i 1910.93a shall become effective July 1, forced vital capacity iFVC) and forced 1976. All other provisions ol It 1919.93a. expiratory volume at 1 second <FEV,.), 1910.93. and 1910.19 shall become effec <3< Annual examination*. On or be tive July 7,1973. The current emergency fore January 31. 1973, and at least an temporary standard remains In effect (a) The AEC Procurement Regula tions (AECPR) are hereby established. (b> These regulations implement and supplement the Federal Procurement Regulations <FPR) and are a part of the Federal Procurement Regulations System. <c> The effective date of FPR issu ances throughout AEC will be the date Indicated in the respective issuances un less otherwise provided In the AEC Pro curement Regulations. <d) The effective date of AECPR Is suances throughout AEC will be the date indicated In the respective issuances. (9-1.102-2 AECPR Temporary Regu lation*. nually thereafter, every employer shall until July 7, 1973. (a) The AECPR Temporary Regula provide, or make available, comprehen (8a. S. S. as Stet. 1193. 1991: 2* OJ.C. 8SS. tions are hereby established. sive medical examinations to each of his S37: a CFB 1910.4; Secretary ot Labor's (b) These regulations implement and employees engaged m occupations ex Ordsr Ho. 13-71. JS PJL ITM) supplement the Federal Procurement posed to airborne concentrations of as bestos fibers. Such annual examination shall Include, as a minimum, a chest 8igned at Washington, D.C., this 3d day of June 1972. Regulations Temporary Regulations. They alto contain policies and proce dures initiated by the AEC which are r^n:?rnogram (posterior-anterior 14 x O. C. GoxHTHxa. expected to be effective for a period of 17 inches), a history to elicit symptom Assistant Secretary ol labor. 6 months or lets. atology of respiratory disease, and pulmonary function tests to Include tm Doc.73-4374 FUsd 34-72;lit* ami (e) The effective date of the FPR Temporary Regulations Issuances forced vital capacity (FVCi and forced throughout AEC will be the date indi expiratory volume at 1 second <FEVi.). cated in the respective Issuances unless Title 41--PUBLIC CONTRACTS 41 Termination ot employment. The employer shall provide, or make avail otherwise provided In the AECPR Tem porary Regulations. AND PROPERTY MANAGEMENTable. within 30 calendar days before or after (he termination of employment of <d> The effective date of the AECPR Temporary Regulations issuances any employee encaeed in an occupation exposed to airborne concentrations of asbextos fibers a comprehensive medical Chapter 9--Atomic Energy Commission throughout AEC will be the date indi cated In the respective Issuances. (e> The AECPR Temporary Regula examination which shall include, as a minimum, a chest roentgenogram (pos terior-anterior 14 x 17 inches!, a history PART 9-1--GENERAL Subpart 9-1.1--Procurement tions are a part of the AEC Procurement Regulations and the Federal Procure ment Regulations 8ystem. All references to elicit symptomatology of respiratory Regulations to the AEC Procurement Regulations or disease, and pulmonary function tests to include forced vital capanty iFVC) Mucsujmcoos AmnsMtHK AECPR in If 9-1.103 through 9-1.109 of this subpart shall be deemed to Include and forced expiratory volume at 1 second The changes made In AECPR Subpart the AECPR temporary regulations. iFEV l. it Recent nominations. No medical examination Is required of any em ployee. If adequate records show that 9-1.1, Procurement Regulations, have been made in order to establish the AECPR Temporary Regulations, which are a part of the AEC Procurement Reg 3. Section 9-1.103 Authority, is revised to read as follows: 9-1.103 Authority. me employee has been examined In ac- ulations and the Federal Procurement The AEC Procurement Regulations arc tordance with this paragraph within the Regulations System. The AECPR Tem prescribed by the Oeneral Manager. As pail 1-yenr period. porary Regulations implement and sup sistant General Manager for Administra 'Ci Medical records--<h Mainte nance Employers of employees examined pur-mint to this paraemph shall cause tv l' maintained complete and accurst* plement the FPR Temporary Regula tions. They also contain policies and procedures Initiated by the AEC which are to be effective for a period of 6 tion. or the Director. Division ol Con tracts of the AEC, pursuant to the au thority of the Atomic Energy Act of 1954. and the Federal Property and Adminis T'.cjsit ot all such medical examina months or less. The AEC Procurement trative Services Act of 1949. rcoceAi usism, vou jy. no. no--widnisoat. juni y. tm USEI00003 5 RULES AND REGULATIONS 11321 :nf .-ecuirements of the American Na- where asbestos fibers are released to be subpsrsgraoh shall conform to (he re Standards Practices for Respire- monitored in such a way as to determine quirements of 20" x 14" vertical format ion Protection. ANSI Z88.2-1969. which whether every employee's exposure to signs specified tn t 1910.145(d><41. and is uirorporated by reference herein. asbestos fibers is below the limits pre- to this subdivision. The signs shall dis b See i 1910 S concerning the avail* scribed in paracraph <b> of tills sec* play the following legend in the lower abilitv of ANSI Z88 2-1969 and the main* tion. If the limits are exceeded, the em* panel, with letter sues and styles of a ten.-incr 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 i 1910.100. ic> No employee shall be assigned to tasks requiring the use of respirators if. based upon his most recent examination, an examining physician determines that the employee will be unable to function paragraph <c) of this section. (2) Personal monitoring--<1. Sam ples shall be collected from within the breathing tone of the employees, on membrane filters of 0.8 micrometer porossity mounted In an open-face filter holder. Samples shall be taken for the Ltgtnd UbMUK ............ Dust Kftxtrd. Kotatxon Sane 6ertf. Oo t h1c or Block. a.%" Bans Serif. Gothic or Block normally wearing a respirator, or that determination of the 8-hour time- Avoid Breath in* Dust... U *' Gothic the safety or health of the employee or other employees will be impaired by Msuse of a respirator. Such employee shall be rotated to another job or given the opportunity to transfer to a different po sition whose duties he is able to perform weighted average airborne concentra tions and of the celling concentrations of asbestos fibers. <10 Sampling frequency and patterns. After the initial determinations required by subparagraph (1) of this paragraph, Weu* AasJfaed Protective Equipment. Do Hot Remain In Area Unieu Tour Wort Re* quires It. Breathing Aebestae Dust May Be Rarardou* To U " Gothic. *4" Gothic. 1* point Gothic. with the same employer. In llie tame reo- samples shall be of such frequency and Tour 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. <3i Special clothing: The employer shall provide and require the use of. spe* clal clothing, such-as coveralls or similar whole body clothing, head coverings, gloves, and .<ot coverings for any em ployee expo: -d to airborne concentra tions of asoe -:os fibers, which exceed the ceiling level rescribed In paragraph (b> of this sectic . i4i Chan,: rooms: <ii At any fixed place of em: yment exposed to airborne concentrate i of asbestos fibers in ex cess of the r aosure limits prescribed in paragraph < of this section, the em ployer shaL irovide change rooms for employees w king regularly at the place. >ii' Cloth- lockers: The employer shall provide ro separate lockers or con tainers for e :h employee, so separated or Isolated a. to prevent contamination of the emplo .*e's street dollies fiom his pattern as to represent with reasonable accuracy the levels of exposure of em ployees. In no ease shall the sampling be done at intervals greater than I months for employees whose exposure to asbestos m:ty 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. 8amples shall be taken for the determination of the I- hour 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 Spacing between lines shall be at least equal to the height of the upper of any two lines. <2> Caution labels-- <11 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 wbestos fibers have been modified by e 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 ol the exposure limits prescribed in paragraph (b) of this section will be released. (11) Label specifications. The caution labels required by subdivision u) of this subparagraph shall be printed In letters of sufficient size and contrast as to be readily visible and legible. The label shall state: Caotiox work clothes pattern as to represent with reasonable Contains Asbestos ytiitn mi' Lauii, -ring: ia> Laundering of accuracy the levels of exposure of the Avoid Creating Oust asbestos coir -mtnated clothing shall be employees. In no case shall sampling be done so aa tc arevent the release of air at Intervals greater than 8 months for Brvathing Asbestos Oust May Cause Serious Bodily Harm borne asbestc.-. fibers In excess of the ex employees whose exposures to asbestos <hi Housekeeping-->1) Cleaning. All posure limits prescribed in paragraph <b> may reasonably be foreseen to exceed external surfaces In any place of employ of this section. <b> Any employer who gives asbestos- eon taminated clothing to another person for laundering shall inform such person the exposure limits prescribed in para graph <b> of this section. <4> Employee observation of monitor ing. Affected employees, or their rep ment shall be maintained free of accu mulations of asbestos fibers if. with their dispersion, there would be an excessive concentration. of the requirement In <) of this subdi vision to effectively prevent the release of airborne asbestos fibers in excess of the exposure limit* prescribed in para graph <b> of this section. >ci Contaminated clothing shall be transported In sealed Impermeable bags, or other closed, impermeable containers, and labeled in accordance with para graph if) of this section. resentatives. shall be siven 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. (1> 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 (2) Waste disposal. Asbestos waste, scrap, debris, bags, containers, equip ment, and asbestos-contaminated cloth ing. consigned for disposal, which may product In any reasonably foreseeable use, handling, storage, processing, dis posal. or transportation airborne concen trations of asbestos fibers m excess of the exposure limits prescribed m paragraph (b) of this section shall be collected and (e) Method of measurement. All de <b> of this section. Signs shall be posted disposed of in sealed impermeable bags, terminations of airborne concentrations at such a distance from such a location or other closed. Impermeable containers. of asbestos fibers shall be made by the so that aa employee may read the signs (It Recordkeeping--<1> Exposure rec membrane filter method at 400-450 X and take necessary protective steps be ords. Every employer shall maintain rec (magnification) (4 millimeter objective) with phase contrast illumination. <fi Monitoring--<l) Initial determi nations. Within 6 months of the publi fore entering tlie 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 lor a period of at least 3 yean and shall be made avail able upon request to the Assistant Secre cation of this section, every employer (li> Sign specifications. Use warning tary of Labor for Occupational Safety shall cause every place of employment signs required by subdivision U> of this and Health, the Director of the National MDIIAl KCISUI, VOL 37, NO. 110--WtONtSOAT, JUNt 7, 1*72 USEI000036 United States Steel Carpomtum peter M. Serokis Plant Manager Neville Island Plant USS Chemicals 1 >* lntirorjJfliMtisn CorrtipanSanca Date: September 21, 1972 frtm: Kenneth M. Morse, Director Environmental Health Sut|ct: Asbestos Survey Insulation Work Pursuant to your request, the asbestos exposures of mechanics doing insulation work were evaluated at the Neville Island Plant by our Environmental Health Engineer, Mr. Jack Masaitis# during the periods of August 29-30 and September 7-8, 197 This study was accomplished by collecting 36 samples in the employees' breathing sone while removing deteriorated insu lation, cutting, installing and finishing new insulation. The results of the samples are presented on the attached table, ; .ong with the Federal standards, and are the basis for the 1 lowing conclusions and recommendations. C nclusions 1. The mechanics' time-weighted average exposure to asbestos while doing insulation work were all well below the current Federal standard and also below the established standard that will become effective as of July 1, 1976. 2. .The highest short-term exposure was 3.5 fibers/ ml, and this occurred during a 15-minute period when old insulation was being removed. This exposure is below the allowable excur sion limit of 10 fibers/ml which cannot be exceeded. Recommendations atAlthough the mechanics' asbestos exposures were not axces- siver it i* being suggested tnat tne practice wetTiftg thS -'insurXticn before handling continued cO minimize the asbesTCs acpoJWW; ----------- ---------------------------------- Results of the Survey During the four-day period comprising this survey, normal tasks- involved with removing the old insulation and installing new insulation were performed. The highest exposures occurred from the dust generated when the old insulation was removed and from cutting and handling the new insulatior USEI000037 The effects of wetting insulation before handling is somewhat manifested by comparing the September 7 and 8 expo sures of Henry Jagielski. This employee did the bulk of removing the old insulation and fitting of the pre-formed insulation shells on these days. As indicated, his exposure was 1.1 fibers/ml on September 7 when the insulation was not wetted, as compared to 0.7 fibers/ml on September 8 when the practice of wetting the insulation was initiated. The mechanics showing the lowest time-weighted average exposures were, for the most part, involved in finish-type work. The results of this survey indicate that the mechanics doing insulation work are not subjected to excessive asbestos concentrations. In view of this, and the major manufacturers commencing to producing asbestos-free insulation in the up coming year, no health problems from asbestos are anticipated at the Neville Island Plant from insulation work. JBM/ir. id Attac unent X. M. Morse USEI000038 * lW C w H M o o o o u> cn r T3 e 1 c * < r * fM </ V} * r> s *8 i ce <N 1 a' VO r-i *W > Z Jrn 3 M 0 X0 * M? * Mb aj 4M. < M 0 X 1* 0 X I* ** 3 5! 8 3 M< 5 3 MJOj i I- I 0 X I1* ii *| 0| X M i GO M \ O' i M r* s O' i n r* CO * * o <N cn <N r4 o m T N IN O IN CN IN - o |* m \ a * i* CN \ QB 0 VO -4 4 o IN fN CN --* P> -w ~T= o Co o CO cr CO m 1 04* i 3 1 A m bros ?.n i rt\s J< r 0 u tr N XI- e 1 9h a- & wi 4)4 >i- e se1 MS v w JS <1 4) ft 0<C c- o S- no. < c n * W * 4) a U 01 Cu c ma 1 a: c vJVKCcnjp .. rofTSv f sVKHmva i. L ppm :rp p;*0 * >4 1 0 m> s * 1* u *O i* U n Oc' iJ 4) Vc e oc w 5u ue u H IN s A. in KV U ~4 ~l *1 -* h in [e n 41 X) H v' In-IN i I O' in t -* *e* -ri -** V c* Ua w4.i ^>. *n 3 TI `8 ft rn * ` " lnuiw < iwm Uifm tm* Svwnw Ti: K. M. Mors* * A lntarr|inintion Corrsipontfsnes .C 0c.- August 22, 1972 Fnm: P. M. Serokis V Witt* ASBESTOS EXPOSURE OSHA STANDARDS He request pour Department's-assistance in determining exposure to asbestos dust of Neville Island employees engaged in removing and/or installing asbestos insulation on piping and other equip* meat. Affected employees Include pipefitters and mechanics. The latter have primary responsibility for Insulation work. This initial survey is needed in order to establish a control program in accordance with instructions in your letter of June 26, 1972. PMS/jcp cc: J. V. Brady J. S. Denis ?. J. Plan G. P. Hillard USEI000040 0 b.\i >;hm.\n & \ssoc r.RussMA> frOK. lit dttk of j. $. d.nu TO: J. fl. Maaaieis 9/*//72 Will you please review Che areached Safa job Procedure and let me have your commence. J. S. Denis USEI000041 8\i & vs.sui; ... 2:oo-i United States Steel Carpomtian J. S. Denis Chief Engineer Neville Island Plant lntrorgni<atian Corrtfpondanca Oita: October 2, 1972 Frafi: Kenneth M. Morse, Director Environmental Health tuaiact Safe Job Procedure Asbestos Workers In response to your request to review the Safe Job Pro cedure for mechanics doing insulation work with products containing asbestos, the following comments are submitted for your consideration. In general, we agree with the operating procedures out lined but do not agree with the procedures for respiratory protection. We do not believe that it is prudent for foremen to determine when respiratory equipment is not necessary. Foremen are not qualified to make such a judgement since they have little or no training pertaining to toxicity or the chemistry and physics of airborne particulates. The need for respiratory equipment should be determined by a complete evaluation of an operation by a competent environmental health engineer. In this case, a survey was conducted and it was determined that respiratory equipment was not heeded since all of the asbestos exposures were well below the current and proposed standards. So far as operating procedures, it was recommended in the survey report that the practice of wetting the insulation before handling be continued to minimize the asbestos expo sures. This is also a work practice recommended in the Occupation Safety and Health Standard to prevent the emission of airborne fibers in excess of the exposure limits. The asbestos standard also requires annual comprehensive medical examinations on or before January 31, 1973 and at least annually thereafter for every employee engaged in occu pations where there is an exposure to airborne concentrations of asbestos fibers. In conjunction with this, a preplacement examination and a termination of employment examination shall be provided to each employee thirty days following the first exposure to asbestos fibers and within thirty days before or after the termination of employment, if no medical examination was conducted within the past one-year period. USEI000042 02/25/83 14:24 2U 021 4G33 BAUGHMA.N k ASSOC GROSSH.KS 2 005 -2- We appreciate the opportunity to comment upon the Safe Job Procedure and hope our comments will be beneficial. JBM/add X. M. Morse USEI000043 c a fKt n 03 3f9t C * o0 H* o fHt a o (9 Oc0 ?r 3* r* pIft* 3 m >* Zl 'Ll! ft O . . j i. . <.oo viXuaaM.A.' 2ooj VI li aa 3VI S(HfBt pom (fftt TC39 c Mr0t. C3 Ps<S. O3ft P0Pic-** nP(0<ft30 9 2j 0 o3 9 0s jr VI 3VI rr m* ncft mcm 0rt M 03 2 pm O3ft rPr* 330 fil S. HMM9*** O3 XOo3 3s0 * *m fc-r <ft mn h 930 cVftIir r(Vfrt) 09 a g a n 0 r3* >0* 3i M* re3V** 0Mrr* 30 f Xpm pXm 933 rol X r0* 03 XQf3f a 50 ** LJ N> fN 0> n e c(ftr 3r r0r p9**` NO0*- 3 030 n m* 0 3 3 <ft c l 30 mGm ftf) M pwy30i#tt O3ft o(ft f(3ftt p9* Or30O (r*frt MCiinL m(ft* < to Xr*r (ft *3 0<(ft M((fftt #n-* (0ft NO ** |s _s 1 M as ;1 "IT 1 M 8 i CV/5 ii I iH !H Ni V* NS Afct yft <0Cr9t n y9Ml o 3 0 Of%P*r(a0<0M3c*af+ftttt***oe(fytM30M0NP0MM30fftttf**** (ft p* UCp*(f31mt f(ftt PP yift (03ft OMl ypr -1 0 9 3a 0a M* > 3M MPf30e0t*C M3 Ia0ft 9(ai -pam ft m0 Oft o2 0 ryt y a c0 ft 9 p* 5 (ft < p** 9 aS uy o s 0 w y 't s"3 3 & 0 fctr cy^ Q. 8 (fftt ! t g 0 < (ft fftt f<t g 0 rt m ft o. O* ft 30(ft oti 0yC8 p3p0-** Pc3* I0ft V* (yrftt MOl MfpM** ft (ft 10 Myoe0& O* ft ^9 *03 *f3t 9< 0& 9 M(ft* 0 3 ft Ift c0 n (ft s ft 0 S Q>*3 3 PM O yM- *0f1t (ft P* 0 0 ft n 3 ft nO 6rr hft 3 p T (ft 9 ft ^ 91 ft* CA *39' 3m c 3(ft* ni Ml 0 Ml 0 M MO f30t 3 a f90t 9Oft N(9 *a3 m f0<CtL f0t p* ff0tt 0 ft n0 3 ft y ft a fG0t Mft* 0ca. f0ftt mfct* y rr yft f3Ma<* 30 *e-f 0ft 3 90 c3& y00 c a 3 M* ft 0 y 0 *e m y 0 ft a. c 0 M CL cr ft yM a a0 0ft a M* c sr^ ft 30 0 ft C 0* CL A 9 C (ft ft" IV M ift 9 ft (ft *-00 3 S,`Jb. 8 c1 < v m- -9 m (ft 9 (ft * 3 3 Sr 9 o ft * ti rr >3 fftt-*"* 3* ft* (ft &(ft ft a0 < &ft m0Mmrmrm 'ft yft MfM0t l PM M0 ft M* 30 f0t e- of- r0t a 0m y 0 3 Mft Cfaye0* y o3o 0y0f0t fftt aft yrt s. w 0 y0 pcm a y ft rt y ft 9 ft ft & 0 0 ft ft *33- Ml M* e0 ft * y CL * 0ft y a M3 ft *t 0 y(ft 3 0C < 9 * 3" (ft f 0 0 M (ft ft *--o< *3a-- u 3 m "^ 3 f3t* Oft (ft fm3t** Ci 0 fMt f3Ot Ml Me Mpml y M0ft M0My* 3 3f0t 00 Mft 0 fyt y rtw a y 0 N 0 30 e M0 Q. O c PM0*> 03 M n M 3o ft ft ft 0 -i -- 9rt 3>* ,!- 3 3 Oft -O 9 f3nt cVIr (ft VI cl n eo -(0f1t 0 1. 1 *v Oo Q ao 0 !! 1 ii ,i on > T1 m u. o es "0 w O n m U C m 3 *3 < M ro M* M ft 3 X ^ O M 0 ft M* ft *K C ft 3 ft ptf 0 9t y 0 0 0 pi ft pm mm pm M < ft ft M 0 ft 0 ym 3 y ft -- a 0 0ft 6 * M* * y 0 ft p* rt 0 0 ft p- ft y M W ft 0 pm 0 0 0e *t o P* c M M 00 0e 0 M0 *d ft f-* 3- M 0 3 I-* C 0 M* a a ft M o y 'o & -roz^r*. X. O 9e S r 0 ft ft 0 M* C 00 3 ft a y y M ft 0 y p* 3 00 e o M y ft e aO 9 * c rr 0 0 pm ft ft mm s tm ft m pym ft mm 0 pm 3 QQ c a. 0 M ft ft y y y ft 9 0 ft m CL 0M c0 CO ypm M* 3 ft 0 X 0e C0 pm ft ft 0 9* rm ft M pm y ft o a. 3 ft ft o 03 00 ft pp ft yy ft Ml M Mo ft 3 i 5 rt <y 0 ft M* o3 Ml 0 ft y0 ft rt N*> n0 y3 ft ft a 0 ft ft SB , i ft M * . *3 ; *T3 M* I ` 3 1 0 . NS M* |3 O *1 u ft i* rt n , f- l| 03 M 00 M J ft OO i , pm 1 3 ai < ; T n s* M 3 s ft 2 crv n r> r y U-l 0t 3 " j p* n 0 1 Am , i USEI000044 United States Steel Carpcmticm peter M. Serokis Plant Manager Neville Island Plant tJSS Chemicals Intarorganixatian Corraiponlanea DU: September 21, 1972 fttm: Kenneth M. Morse, Director Environmental Health Irtjtct Asbestos Survey Insulation Work Pursuant to your request, the asbestos exposures of mechanics doing insulation -work were evaluated at the Neville Island Plant by our Environmental Health Engineer, Mr. Jack Masaitis, during the periods of August 29-30 and September 7-8, 1972 This study was accomplished by collecting 36 samples in the employees' breathing zone while removing deteriorated insu lation, cutting, installing and finishing new insulation. The results of the samples are presented on the attached table, along with the Federal standards, and are the basis for the following conclusions and recommendations. Conclusions 1. The mechanics' time-weighted average exposure to asbestos while doing insulation work were all well below the current Federal standard and also below the established standard that will become effective as of July 1, 1976. 2. The highest short-term exposure was 3.5 fibers/ ml, and this occurred during a 15-minute period when old insulation was being removed. This exposure is below the allowable excur sion limit of 10 fibers/ml which cannot be exceeded. Recommendations Although the mechanics' asbestos exposures were not exces- sivr;- itTT being suggested that the practice of We~liflg thg "Insulation before handling ~tfdr~cTVtinU''d to miniMiZe the asbestos tfkpoiures. * " --------- -------------- ------- ------------------ Results of the Survey During the four-day period comprising this survey, normal tasks involved with removing the old insulation and installing new insulation wert performed. The highest exposures occurred from the dust generated when the old insulation was removed and from cutting and handling the new insulation USEI000045 T s+ UAv vJil.l.V- 1 iacj -2- The effects of wetting insulation before handling is somewhat manifested by comparing the September 7 and 8 expo sures of Henry Jagielski. This employee did the bulk of removing the old insulation and fitting of the pre-formed insulation shells on these days. As indicated, his exposure was 1.1 fibers/ml on September 7 when the insulation was not wetted, as compared to 0.7 fibers/ml on September 8 when the practice of wetting the insulation was initiated. The mechanics showing the lowest time-weighted average exposures were, for the most part, involved in finish-type work. The results of this survey indicate that the mechanics doing insulation work are not subjected to excessive asbestos concentrations. Zn view of this, and the major manufacturers commencing to producing asbestos-free insulation in the up coming year, no health problems from asbestos are anticipated at the Neville Island Plant from insulation work. JBM/mdd Attachment X. M. Morse USEI000046 - - .................... 3 t- nr* n ft V 1 U1 V3 K) m- ft 3 n 3 3 n o 3 3 ft ,-j? ft rr 3 ft re 3" x o 0 3 I rr I < 9 cr ft rt U1 \ 3 ro n s> 3 3 0 n *n ft a a. * a 1 JL \-j j 1 ill' 3 & &3 3 M 03 <3 rftr 1 * m9 iU Jw 4 9 B U 0 o H- 3> DC* am ?S 3- 3" n b3 fri fl ftp ftft F-i-i -c 3. *1 1fl 3 pft N i-v mct H w bi 1< 0 n 3 0 P Pf b 08* Or * Uf )U/ u a p 09 \ O o jo o to *i \Q 1 SL_ ** to NJ to t- .fe o o\ jf 00 \ UJ H| M Si U* d 0 1 o -- o 1 "I ro r- H * i M to u to ? a 9 Si e SO o o o w *hI LJ *1 00 * r* H s* 3** ? 28 8i "1 5 a 5 ? p S *) * f 9m *1 ? f H f 'S3 a y w a--<* o tX c- ap O o o o i W W cn WI *4 *4 K * t*. D.K. Schade SuktKt AIR CONTAMINATION CONTROL ASBESTOS Chemicals OMMM UMM SIMM Otr^VMlM Intarorganization Corraapondanca Date July 8, 1980 Fimu R.G. Buckingham The attached Air Contamination Report ahowa the abort term exposure of two maintenance workers to asbestos. The samples were taken on April 16, 1980, while the workers were removing insulation from the PA transfer line to the flaker. ( /ft? R.G. Buckingham RGB/dim Attachment USEI000048 USEI000049 \ /AT" roH TtM iH m A M or>trrpoi, REPORT - ASBESTOS TLV - 2- fiOb eUrs) m l. File ccs D. K, Schade J. J. Stanko Subjtct: ASBESTOS GASKET GRINDING SIMULATION uss Chemicals Ohio-- t> lMM flam KM CowrMM intsrorgsnizstion Corrupondanca 0<tt: December 16, 1980 From: J. P. Koch On April 2, 1980, a test was sec up in Che Maintenance Shop demonstrating Che removal of asbestos-containing gaskets (Garlock gaskets) from three flanges. These were to be removed by means of a pneumatic powered wire brush. This operation is not done frequently, but it was desired to deter mine the exposure to personnel that perform the job. Tie operation was monitored by J. P. Koch obtaining two area samples and a breathing zone sample of Che pipefitter doing the grinding, V. J. Vanshura (Check #194). These samples were Chen analyzed by J. J. Stanko of the Corporation's Environmental Health Staff. The test took eight minutes to grind off the three flanges which was the duration of the air sampling. J. J. Stanko then reported that he was unable to find any asbestos-form material on the samples, indicating Chat there was no exposure to asbestos during this operation. USEI000050 Mr. Peter Serokis Plant Manager USS Chemicals Division Neville Island Sample Analysis Data United 2T . Corporation Intarorganlzatlon Corrtapondtnca w* January 26, 1981 W. M. Bernhart Environmental Health Engineer Attached is a copy of the results of asbestos analyses conducted by Environmental Health on samples submitted by your plant on January 6, 1981. 10 771, Co At achment cc David Schade Robert Buckingham USEI000051 P*S O U*i *X cc II ie <I* *> Q 2* 5 CD 0 u 2 0X u. (4uA1i 5Z? zouo<03) 7" ,, % * -2 ?j*L fi ll* V) pi |3c 773 d o oo s r o u 4) . lf "itis i5 li oo cn oo <n oo n cl f* cn |5 g oo ~ a 3e $ CO H 5 K0 ' cr V*> 1a4 C/3 S a 2 s| o.2 >.i > -< ou 1 1 -*J S! a w wo u O(4 u wo B MO - eo I 4J u to to Bo I u am 53 o Vb to aJ QCM *C*44 <CS4 CH* = s s si I I USEI000052 Subjnet Air Samples - Asbestos Fiber Content Vmted States StEel Cbrparatian Inttrorganization Corraapondanea OtU: June 17, 1981 Fran: J. J. Sfcanko, Ph.D. Senior Environmental Health Engineer As requested by R. G. Buckingham on May 27, 1981, we have completed our examination of subject air samples for asbestos fibers. They consisted of two personal breathing zone samples obtained while preparing PA tubes for the PA plant filter cases and seven area samples. These samples were examined under the optical microscope using phase contrast at 450X magnification according to the technique prescribed in the OSHA Asbestos Standard. The asbestos fiber concentrations are reported in the attached table. They ranged fran a "lew" of 0.02 fibers/cubic centimeter (cc) of air in the composited breathing zone samples (sanples 20, 21, 25 and 26) to a "high" of 0.13 fibers/cubic centimeter on the area sanple obtained at the work bench on May 18. These exposures are not considered to be a health hazard and are well below the present OSHA permissible exposure level of 2.0 fibers/cubic centimeter, greater than five microns in length. Approved by: ii ?J. B. Mgsaitis Assistant Manager - Environmental Health JJS/jmr Attachment cc: R. G. Buckingham Stanko, Ph.DT tior Environmental Health Engineer USEI0Q0053 A IR CONTAMINATION REPORT ASBESTOS (TLV = 2 f ib e r s / c c ) (S| O CM nO o ooo W x 52; PS r* vn vO u com CoM cn o o ^4 'oso* m H ^4 '0M0. CmM H 00 00 00 00 U*> sn m O' O' O' Os ao CM 00 CM i S 2! og> S <0 a4J ^c4 <Q g01 0(e0 w0C1 4l <9 0) u c a e 0) 44 C *p4 as o0c) as OS 41 c CQ X X XX u JU 44 m >4 w ^4 O3eS <0 X H 40c> X ^4 JC0eO>40 JNo6*OsJ oa 00 d d C& s d X M * c4 0 <4 0 1 00 r-7^ 5S MO u 5 M O CM ^4 CM w* CM o CM to. USEI000054 TABLE NO. 1 ASBESTOS IN AIR SAfPLES -USS CHEMICALS NEVIUE ISLAND PLANT OSHA P erm issible Exposure Level (PEL): 2 fib e rs /c c o f a i r g re a te r than 5 m icrons in le n g th USEI000055 NEVILLE ISLAND PLANT None D etected 1--YTtT I ffE3 Wax. w1C .81 >10. is t \ C= 88 r=w OZ ou.i a2. -- a. c ;* a: -- Za Z Uxl o< Z Z <si* L Z $*w:f*P<t-- 00. Z4 iZ 8 # * If oQQ ss Z Z n cn sO so 2 2 V ft <Or w * pfaat.. C"l *r2- sa u* ft ft H s ft U u I C ft. *r< offfttt ofl 4t .<6a w* <O (O 2 o (4 ft 5 >4 o 4U CO ft ft O ao >. 1uMf-4t fu9t fufdtt & c C CO flu ft p4 c ^4 U C( 4J ft 2I ft in u <n C pH p4 2 ft cm il rH a -< o W z < . 3 Jft- Qe Uz4ffSJtt o OS ^ea4 co > m<-- Z O h< z X< Z mi a 2u W z 4o u oo < a X XX 8 < 5 o *w (qS> b wf3t 52 1Q4Mawffff0Mfs0H-Uttt4tt>44<fuff3Q9ffOVecHf3f1JtJtttttt1r*' CQM Mz pH * HCfaafOtt /CCMM** wMz CM ft* ^Cffga4Ott *CfMH"1MS %Z en * 1fd*4t* CfOt s .bfftt U 8 $ ooufwst c CO a. w c s to mi u> ft w o >a * o o o oM Cd CO 1D Ui QC T D K. Schade uss Chemicals OMM UMM tutm tun OvwrMM Intsrorganization Corrtapondane* Oat* October 14, 1981 FfMK R.G. Buckingham Subjaet- AIR CONTAMINATION CONTROL ASBESTOS The attached Air Contamination Report shows the long term exposure of employees collaring PA filter tubes and also area concentration levels for the maintenance area of the Tech Building and for the Annex Building. All of the exposure levels are veil below the OS HA permissible level of 2 fibers/cc greater than 5 microns in length. At the very low concentrations reported for these samples it is very difficult to determine if the fibers are actually asbestos. R.G- Buckingham Attachment: RGB/dim SAFETY /-- USEI000057 J cuasD ( 4x r w 41 2 3 NEVILLE ISLAND PLANT X o1--f1 2 < o* 1 oS V0 f*% I 4U1 O3 4W1 *T3 C4 3 41 ouo ^4 3 m4 uu h co a Hu>\ uOa 4o{1 u fi u Q 41 C0 Pm H a. a wX UXi .81: >31 Is P"> d I nnyfln O 1-4 dodo 44 r** r* wr**i po* * CM C4 O O xx XX 5 -C <a CO ON o H M CM Cl 8 1 4) J6 OOOO ini/iniAi 8 4 oooo 00 00 ao co oo ao fe 6 gi o Ui <o co 4) e8 4> a < z o o <9 *3 Cfl 4} pe4 4o* W CO CL 41 41 J3 U3 a. w I AV. b HR. CXP. O n o o 5? o *XA f Uaei _______ U S E I000058 FCOCRal s io s . ? fib e ra /j  a E3 wax. wa*c .Si >J 4 Is f 88 zw 8a;: *-- uaK.i a<^ o <3i m* & A o oN oN No o' d d d pa O O <n A rs. rs. ^ OURAltON Of SAMPLE HOURS NEVILLE ISLAND PLANT i 3 f3 4V X XX b is *H> W sWi S~ XX s .Cn s00 Mac U s m u >cx0 rP*S cx tn CNI Ias i--i < 9iA s o V rs ac&u 0w9 go s 8 fe w 5 2 49J 0e0 U J00t 000 uo p0H oo e a000 O ia O lA Oi lA o iA o^4 a O^4 00 O 00 o0H04 * * * ^0C4U CaO 0U 04 *2u O 0 U9l <9 U0 i>v 0 s 1 co a i H u A(9 i/) S aa0 u9 s u0 < s -PGc4O 0 5 ua a& 9 0w uo CU *** remarks; * Laborer d id not work w ith asbestos gaskets d u rin g sample. T0TAL I q .02 ?) 'federal s io s . fib e rs /c Te C. W. Henderson Subject AIR CONTAMINATION CONTROL REPORT ASBESTOS EXPOSURE OF LABORERS uss Chemicals amiiH * hm ttaui t Ofui Intarorganirstion Correspondence Oita: May 11, 1984 Fnm R. G. Buckingham The attached Air Contamination Control Report shows the exposure of laborers to asbestos. The samples were taken on February 21 while the laborers rebagged Insulation in the Asbestos Waste Bln. Ail of the samples were short term samples taken as the laborers were actually wor- ng with the insulation (not on breaks or at lunch). The time weighted ave: iges (TWA) of.the laborers were well below the emergency temporary standard (ETS of 0.5 fibers/cc over an 8 hour shift. Only one sample approached this iimi , and it may have been contaminated by brushing directly against the insi. ation as there was a large clump on the outside of the cassette. Again, not 11 the fibers counted were necessarily asbestos since not ail of the insu ition rebagged contained asbestos. R. G. Buckingham USEI000061 AIR CONTAMINATION CONTROL REPORT 5/11/84 vt < ? ao| o<?> eM S * mi U HS o o o' vO I'm o NO r*. O* o -< o' O 0 0 <0 CO oH 2 CO C0i>2 CO < cwho 0 cu 0 OS ^ o0 CO u vO O vO mi <n mi tn *y cn O v<OM cn co O 2 3 OV o' o' o M 6u y y <P y y y y y y CO CO 00 00 CO 00 00 CO 00 CO b]| *, **> HI ^4 *4 mi m4 ^4 ^4 mi mi < cm CM CM CM CM CM CM CM CM CM q| *. CM CM CM CM CM CM CM CM CM CM CM CM CM CM <n cn CO co 00 CO pm *4 mi mi y ON <* 0v y y CM CM CM CM mi mi mi w4 *4 mi SuM0 2 0 J u 01M. 2 0 n-3 h> 8 0 fi 5 u 3 w 8 1 3 UVb Ub0 2- 2 22 U V .Qo J3 2 A0 2 U0 ja00 M 2OS Xo W9 U0c38u *(0O3a4i 0b53a>. 0u0O3a6. *C03O C>ooO no>0as -C>03Os maw0u0si O*u0m0S4 4* % * * * . h H H H ij ml N-J ~9 CJ CJ o CM m <r m NO r-. 00 yv 1 CM CM CM CM CM CM CM CM CM Oo o ooO ooo as y 00 y 00 <T 00 y CO y 00 y oo y 00 y 00 y co CO < CO < CO < CO < CO < CO < CO < CO < CO < USEI000062 v> ( Industrial Hygiene Services Environmental Health.......................................... .. Recognition, Evaluation, Control Survey Report Asbestos Exposure Evaluation USS Chemicals-Neville Is1and Industrial Hygienist: Date: S. D. Stockton, CIH May 17, 1984 Distibution: G. R. Hanington E. D. Sutilla 'C. W. Henderson Summary: T. F. Fisher, M.D. W. D. Miller J. J. Schwerha, M.D. Approved by: F. M. Toca, Ph.D., CIH Manager-Industrial Hygiene U SEI000063 Table 1 Asbestos Exposures Common Example Operations USS Chemicals Neville Island Plant March, 1984 Occupation Mechanic Mechanic Total Duration (minutes) 142 142 Pipefitter Pipefitter 138 135 Mechanic** Mechanic. ------------- - Mechanic Mechanic Mechanic Mechanic Mechanic Mechanic 15 IS --- ------ " 15 15 11 11 103 103 Pipefitter Pipefitter- 152 150 Eight-Hour TimeWeighted Average Asbestos Exposure (fibers/cc)* 0.56 0.88 0.10 0.10 0.77 0.82 40.01 <0.01 <0.01 0 <0.01 . <0.01 0.11 0.05 Description of Operation Removing insulation fran steam heating pipes in office building. Removing insulation for steam pipe removal in plant. Cutting six (6) linear feet of Transite board with a portable power saw. Removing packing frcm patp and replacing it. Cutting gasket material,. nn Removing insulation from salt cooler near barge dock. Removing insulation from pipes near barge DOCK* Eight-hour time weighted average asbestos exposure in fibers per cubic centimeter of ear analyzed in accordance with the G6HA 29 CFR 1910.1001 Asbestos Standard. The eight-hour time-weighted awrage is calculated assuring the employee is ex posed to asbestos for the time shown during the eight-hour workshift. The OSHA permissible exposure limit (PEL) is currently 2 fibers/cc with proposed revision to 0.5 or 0.2 fibers/cc. Curing this operation, employee exposure to asbestos, when time-weighted over the entire workshift, is well below the current OSHA PEL. The 15 minute peak exposures however axe 24.79 and 26.38 fibers/cc, well aborc the 15 minute ceiling value limit of 10 fibers/cc. USEI000064 May 17, 1984 G. R. Hanington Plant Manager USS Chemicals Neville Island Summary and Recommendations On March 5 and 6, 1984 arrangements were made to measure employee exposure to asbestos during maintenance operations which are normally randomly scheduled. These operations were representa tive of normal jobs and, in all cases, were conducted in the usual manner. Employees used all the appropriate protective equipment required by the applicable Safe Job Procedure. The results of this evaluation indicate that removal of well wetted asbestos insulation and the handling of materials contain ing well bound asbestos (gaskets, etc.) does not result in employee eight-hour time-weighted average asbestos exposures above the current Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL) of 2 fibers per cubic centimeter of air (2 fibers/cc) nor the proposed OSHA PEL'S of either 0.5 fibers/cc or 0.2 fibers/cc. While the removal of insulation containing asbestos in an office area (not as well wetted) does not expose employees to eight-hour tine-weighted average asbestos doses above the current OSHA PEL, such an operation may exceed the proposed OSHA PEL's. The use of a power saw on Transite board does not result in employee eight-hour time-weighted average asbestos exposures above the OSHA PEL, but does result in employee peak exposures to asbestos of more than double the current OSHA ceiling value of 10 fibers/cc as measured over a 15 minute period. While removing asbestos insulation in office areas, greater care should be taken to thoroughly wet the insulation through the use of a more intense water spray, or by trial use of a 1:5 ethylene glycol and water solution. The area involved should be restricted to allow only the employees removing the asbestos to enter the area to prevent unnecessary exposures. Post removal clean-up should also be improved to prevent re-distribution of dust containing asbestos. Power tools should not be used on any Transite materials, and when ever possible, a substitute for Transite materials should be used. Detailed findings for each operation are contained within the report. USEI000065 ( % May 17, 1984 G. R. Hanington Plant Manager USS Chemicals Neville Island On March 5 and 6, 1984 common maintenance operations were scheduled at the Neville Island Plant for the specific purpose of measuring employee exposure to asbestos during such jobs. Mechanics and pipefitters performed jobs which required handling materials containing asbestos that are representative of normal operations. In all cases, the Neville Island Safe Job Procedure (SJP) for working with asbestos products was adhered to including the use of all the appropriate personal protective equipment. The results of this evaluation follow. Method and Criteria To determine employee exposure to asbestos, breathing zone air samples are collected using a calibrated MSA Monitaire pump and an appropriate filter. The filter is then inspected using 450 magnification on a phase contrast microscope. Asbestos fibers at least five microns (5 Aim) in length and three times longer than their diameter (3:1 aspect ratio) are counted and the occupational exposure to asbestos is calculated. The Occupational Safety and Health Administration (OSHA) has established that no employee shall be exposed to an eight-hour time-weighted average (8-hour TWA) asbestos dose of more them 2 fibers per cubic centimeter of air (2 fibers/cc). Further, in any 15 minute period, occupational exposure to asbestos must be limited to 10 fibers/cc (called the ceiling value). It is expected in the near future that OSHA will reduce the permissible exposure limit (PEL) for asbestos to an 8-hour TWA of either 0.5 fibers/cc or 0.2 fibers/cc with a corresponding ceiling value ten times the PEL (5 fibers/cc or 2 fibers/cc). All efforts to control employee exposure to asbestos should be with the recognition that OSHA will reduce these limits in the near future. Recently revised Corporate guidelines for the protection of employees against the hazards of asbestos dust exposure were distributed on April 27, 1984. These guidelines detail the requirements of the OSHA standard and offer methods for compliance. USEI000066 G. R. Hanington USS Chemicals Neville Island Asbestos Evaluation May 17, 1984 Page Two Conclusions and Recommendations The following conclusions and recommendations are based on the results of the air samples collected, data supplied by plant personnel and observations during the survey. The employee exposures to asbestos have been time-weighted averaged for comparison to the OSHA regulations. The survey results are presented in Table 1. Conclusions 1. No significant exposures to asbestos fibers were measured during the asbestos gasket cutting opera tion or during the unpacking and repacking of pumps. 2. The removal of asbestos insulation from process and steam lines in the operating areas (lines that are exposed to the open atmosphere), and the re moval of asbestos insulation from the old salt cooler (stored near the barge dock) results in eight-hour time-weighted asbestos exposures below the current OSHA permissible exposure limit, and below the pro posed OSHA permissible exposure limits. 1. Removal of asbestos insulation from steam lines in office areas, or in areas where such lines are not exposed to the open environment results in eighthour time-weighted average asbestos exposures below the current OSHA PEL, but this operation can result in employee asbestos exposures in excess of the pro posed OSHA PEL of 0.5 fibers/cc. 4. Evaluation of employee asbestos exposure while cutting Transits with a power saw (total cut of six (6) linear feet) indicates an eight-hour time-weighted average exposure of 0.77 - 0.82 fibers/cc (well below the current OSHA PEL). This operation does however re sult in employee asbestos exposure of more than double the OSHA permissible ceiling limit value of 10 fibers/cc for a 15 minute period. Recommendations 1. The Neville Island SJP for handling materials con taining asbestos, which requires the use of respira tory protection, protective clothing and gloves, and wetting the product prior to removal, provides the maximum practical employee protection available. Continued emphasis of the SJP for all operations in volving materials containing asbestos is essential to prevention of asbestos related disease. USEI000067 G. R. Hanington USS Chemicals Neville Island Asbestos Evaluation May 17, 1984 Page Three 2. When removing asbestos insulation from steam pipes in office areas, the insulation should be more thoroughly wetted. This may be accomplished by using a water fire extinguisher such as was used when re moving the insulation from lines near the barge dock. The insulation should be wetted to the maximum extent possible, even to the point of being "dripping wet". In addition, trial of a 1:5 solution of ethylene glycol and water may better control the releasing of asbestos fibers. To avoid asbestos exposure for employees not involved in the removal procedure, the area involved should be isolated as much as possible and posted as a restricted area. After the insulation has been removed and bagged, all shelves and ledges in the room should be wiped down with a soggy cloth, and the floor carefully wetmopped to control the redistribution of dust contain ing asbestos. Clean-up employees should follow the protective equipment requirements of the asbestos SJP. Care should be taken to avoid tracking dust containing asbestos into other office areas. 3. WVen changes in buildings require the removal of Transits materials, the whole sheet of material should be removed with as little cutting or breaking as possible. Every effort should be made to avoid the us a of any power tools without local exhaust ventila te an on any Transite materials. Whenever possible. Transits materials should be replaced by building materials which do not contain asbestos. USEI000068 1 T#; T. G. Wylie Oivision Superintendent Coal and Coke Operations \> MAILED Mjacfe Asbestos Survey |-r{ 2 0)9??m : ENVWONMENJU l health services CUUHON WK1 "III ^/ ' V United SST EASTERN STEEL OIVISION JNte May 20, 1977 pTM* P. K. Morrison Superintendent Environmental and Health Services On April 21, 1977, an aibeitos^syryey was conducted on Number 19 Battery. The purpose of the survey was to evaluate employee exposures to asbestos .fiber while using asbestos rope to pack slip joints. Criteria - OSHA limits an employee exposure to asbestos dust to two fibers longer than five micrometers per cubic centimeter of air based on an eight hour time weighted average exposure. Concisions - The results of the survey (Table 1) indicate time weighted averageexposures of 0.04_.and 0.03 .fibers/ccjof air,for .the two employee monitored. These exposures are well below the 2.0 fibers/cc permissible limit. It should be noted that the asbestos rope was wetted before packing the slipjoints. This practice should be continued. This monitoring fulfills the initial monitoring requirements of the OSHA standards for usage of asbestos rope for packing of slip joints. The use of asoestos rope for the packing of slip joints may be expanded. THC/e* s Attachment cc: L. G. Gainer R. E. Lewis R. L. Walls / USEI000069 C lalrton Works 4-21-77 Time weighted average exposure - (TWA) Is 0.04 flb e rs /c c o f a ir. CD *1 V CO - 09 3 09 -t nao/ oa-** s? r+ 1 n o 0 Q# O o-** -**il c3*vO O a (a0 (n9 t---o*- aa/ rus o 2.8 T> 3 r+ r* a* (0 -t vsir VI << la <0 -1 -*< oro v00i s? VI r+ O VI VO 5 VI a a O VI < <v s > no 09 (71 (O (71 --- fS7 o> VO go o p< 00 0m9 0--04 90 V) (/> oo mx-o o(/I e cc t\ a USEI000070 Table 'con Asbestos Survey C lairton Works I U3 ~o3 r'3urOr rr <0 CL < C-0Dt <0 ^03* G-*Ono V* 0^3 o * TcoW^J*.<ooo 9r* V<90 fn3 0-13 O ST *0* o0# (0 -**o yr </i *<cn0 roo *3 *_ O-* o</# Oc *<Q9 vo orf Oro <A gs? f\i*< go. cs3 vem<or/o+rr o(A roo> yr VO 03 Of ro << s(0 8 X 3VO 2T ro C <9 23 u O oUl ro oo ui VO cn ro -- G\ r(9o 30 mco o ST (O no a* OOOO 2S k S So (7k c>o -n m wm 0m3 C--O< 3co3 Ot/> r> m o x-o o CO 4-21-77 t I 4tV ttf) USEI000071 /- U'v<r~ Mr X. A. EUcaa General Superintendent Clairton Works Analysis off Pipe Insulation Samples January 19, 1979 W. C. Janes, Manager Environmental Health On October 11, 1978, two samples of pipe insulation materials were received from Clairton Works for identification of possible asbestos content. These were identified as Sample #1, taken from a steam valve on a direct steam line to the superstill; and Sample #2, taken from a steam valve on a line to the superstill reboiler. Oust generated from each-iafflple was examined tinder optical microscopy at 450x7~ using phase contrast`Illumination. Sample <1 contained a heavy concentration of flexible, fibrous bundles," and individual fibrils leas than one micron Jji .dionetex_wexc .c.2 aa.rly obsgryed- S_ych fibrous bundles are indicative of.jehrysotile asbestos, by far the most'common form of commercial asbestos. .Sample f also'contained a significant fibrous component. However, these were extremely long, singular fibers, unlike the fibrous bundles often found in asbestos materials. In addition, the wide fiber diameters, some exceeding 40 microns, were much larger than usually jeen in asbestos fibers. I__was pur opinion that the fibrous component of this .aample.jcas .jot asbestos. A preliminary indication of our findings was given to Kr. Terence Civic, General Supervisor-Safety and Environmental Health, who requested that the samples be forwarded to USS Research for positive identification of the fibers through electron micro scope techniques. Research has completed their analyses and has confirmed our observations. They have identified the fibers in Sample #1 as common commercial chrysotile asbestos. Sample 12 con tains individual fibers of calcium silicate, a non-asbestos fiber, possibly from the zeolite group. A copy of the Research report is attached. .Jf'Qmnt Att. USEI000072 Research t' V. A. Szirmae and R.J. La Basle Research-Physica MEMORANDUM Subject ANALYSIS OF PIPE INSULATION SAMPLES ) *t# January 12, 19 79 Ref. No. TWo aamplas of plpa Insulation from Clairton Works were received on October 24, 1978 for identification of the fibrous component (see attached note of October 19, 1978 from J.F. Quealy). The optical observations using a light microscope were correct as reported in Mr. Quealy's note, which we confirmed by scanning electron microscopy. Sample Preparation The fibers were removed from the bulk insulation with tweezers and mounted on a copper tape with conducting adhesive. The copper tape was then mounted on a carbon planehet mount to be examined in an ETEC scanning microscope. To prevent fibers from charging in the electron beam, the fibers were coated from 7 different angles with gold by vacuum vapor deposition. Results Sample #1 contained fibrous bundles made up of very fine flexible tube11 ko Individual fibers that appear silky, greasy and seem to have an adhering tendency to all material they come in contact with. Figures 1, 2 and 3 show the morphology of the fibrils at different magnifications. The x-ray spectra in Figure 4 gives the chemical composition of the fibrils as mostly Si and Mg with slight amounts of Fe and Ca. The copper and gold peaks represent the copper mounting tape and gold coating. The morphology and chemical compositions Indicate that the fibers in Sample fll are from the mineral group serpentine and is commonly known as chrvsotilo (Mg,(Si.O.1(Oil).) which is a commercially used asbestos. 3 25 h Figures S,6 and 7 show that the fibers in Sample 92 are individual, springy, ribbon-like fibers forming tangled arrays but were easier to separate for mounting than the chrysotlle fibrils from Sample 91. The composition of the fibers in Sample e2 is shown on the x-ray spectra in Figure 8 as containing only equal amounts of silicon and calcium and is not an asbestos type fiber. Summary and Conclusions Sample "'l oonrains l>-ni, tubul.ir <>i materia? kncun as chrvsot i It-, Me ! S i I (fll) . common conmcrrij 1 asbestos USEI000073 Sample 12 contains Individual ribbon-type fibers of cnlclum si lieu*, j non-asbestos fiber, possibly from cne zeolite group. Of the large number .>f i aUium-sllicatss, cwo other minerals of a fibrous nature exist: foslwigite, (.'i^Sl.jO^(OH) , and xonotllte, Ca^St,!)^ (OH)^. If nore data on the crystal structure and coaposlelon of this fiber are needed, ve will use high voltage transmission electron diffraction analysis to obtain the exact crystallographic data or the manufacturer should be willing to supply this information. AS/RJl./d cc: R. M. Fisher J. F. Qusaly File OL. USEI000074 Fig. 4 'JSEI000075 Fig. 6 50X rig. a USEI000076 J. F. Boal, Superintendent Central Maintenance Asbestos Exposures - Pips Insulators 4 United EASTERN STEEL DIVISION 0<: November 14, 1979 fna: N. R. Stromness, Superintendent Environmental & Health Services On October 31, 1979, a survey was conducted by the Environmental and Health Services Department to determine the asbestos exposures of pipe insulators. Criteria: Section 1910.1001 of the Occupational Safety and Health Act limits employee exposure to asbestos fibers greater than five (5) microns to two (2) flbers/cc for an 8-hour Tims Weighted Average (TWA). The celling limit for asbestos is ten (10) fibers/cc of air. Conclusions: 1. Ihe Time Weighted Average asbestos exposures of the pipe insulators Insulating the Benzene Plant napthalene line south of Ho. 3 Still House were below the permissible limits of 2 flbers/cc 8-hour TWA and 10 fibers/cc celling limit. TWA asbestos exposures of .09, .06, .08 were measured on insulators Prisbylla, Conlogue, and Behary respectively. Short-term exposures of the insulators monitored ranged from H.D. - .8 fibers/cc. 2. Area samples collected six feet and ten feet downwind of the work arsa (0.04 and 0.03 flbers/cc) were also well below the permissible exposure limit (Table II). 3. Considering only one out of three insulation sections handled contained asbestos, a worst case situation could exist; whereby, all of the materia] handled contained asbestos, asbestos exposures could then approach or exceed the tvo (2) fiber/cc permissible exposure limit. For instance, a short-term exposure of 0.80 flbers/cc to Prisbylla while Installing three sections of insulation (only one contained asbestos) nay have "been 2.4 flbers/cc had all three sections contained asbestos. USEI000077 SecommendstIona: 1* When feasible, Environmental and Health Services should be notified prior to the start of a major Job involving replace ment of eebestoa insulation. Should Environmental and Health Services determine no asbestos is present in the material, no precautions will be necessary. In all cases where Environmental and Health Services cannot be notified prior to work beginning and In all cases where Environmental and Health Services has determined that aabestoa-bearlng material 1* present, precautions should be taken as follows: (a) Approved respirators (Dustfoe) shall be worn during removal of asbestos or suspected aabestoa-bearlng material. (b) Approved respirators shall be worn when cutting asbestos insulation. (c) When practical, all asbestos insulation shall be wetted prior to removal, cutting or disposal. 2. No asbestos Insulation removed from plant structures shall be reused. All material of this nature should be wetted (when practical) and disposed. This Is a directive from the General Superintendent. 3. All personnel working with asbestos material shall be scheduled to receive an asbestos exam. Should an employee currently be receiving a medical examination, the employee must also be coded as receiving an asbestos examination. Discussion: On October 31, 1979, a survey was conducted by the Environmental and Health Services Department to determine the exposures of insulators to asbestos while working with asbestos which had been previously Installed in the plant. Samples were collected on Hilllpore AA 0.8 u Filters at a flow rats of 1.7/pm and analyzed under phase contrast microscopy. Three Insulators were aaapled for esbestoa exposure while removing and replacing pipe Insulation on a naphthalene line In the Benzene Plant. Two of the Insulators worked on a scaffold removing and replacing Insulation while the third provided insulation material from the ground to hla co-workers above. The monitoring results (Table l) indicated exposures to tbs Insulators working on the scaffold (Prlabylla and Conlogue) were 8-hour Tims Weighted Average Exposures well below the permissible exposure limit- of two (2) fibers/ cc (0.23 flbers/cc and 0.17 flbers/cc respectively). The 8-hour TUA exposure to Insulator Behary (0.06 flbers/cc was also well below the permissible exposure limit. All of Behary'a time was spent on the ground. USEI000078 A breakdown of the results Into aharc-cera samples ahowa the hlgheac exposure for lnaulator Prlabylla waa 0.80 flt>ers/cc during a thlrteen-alnute period during which cine three lengcha of lnauladon were reaoved. It ahould alao be noted that the accond hlgheat expoaure occurred to Prlabylla during the inecallatlon of three aectlone of lnaulacloa (0.47 fibere/cc). Both of the hlgheac shorc-cera veluea obtained were below the penalealble celling Halt of 10 flbera/cc. Short-ten aaapllng conducted on lnaulator Conlogue Indicated the hlgheac ahort-ten expoaure waa 0.47 flbera during which tlae he and Prlabylla were inatalllng three aectiona of lnauladon. lnaulator Behary, who provided aacerial to hia co-worfcars on the acaffold, had a aaxiaun expoaure (.23 fibera/cc) during a 59-alnuce period In which he waa below the acaffold where hie co-workera were Inatalllng lnauladon. It la alao algnlflcant to note that during a forty-nine nlnute sailing period, Behary loaded two boxee with vaate lnauladon and carted the boxea fro* the work alte. During thla aaapllng period, the expoaure waa found to be 0.21 flbara/ce of air. All short-tarn aaaplaa collected on the three loeulatore ware well below the celling Halt of 10 flbera/cc. Area aaaplaa collected alx feet and tan feet downwind of the work area ehoved levela well below the peralaelble expoaure llnlt of two (2) flbera/cc (0.04 flbera/cc and 0.03 flbera/ce reappctlvely). Aa praviouely noted, all expoeurea were well below the two (2) flbera/ce peralaelble expoaure Halt. However, It ahould be noted not all of the lnauladon reaoved or laatalled waa aebestoe-bearlog notarial. Conalderlng the expoeurea for Insulator Prlabylla, It can be seen froa Table I that during the hlgheat axpoaore period (0.80 fibera/ee) during which lnauladon waa being reaoved, only one of the three aectiona con tained aabeatoa. Therefore, If ell three aectlone had been aebeetoe, the exposure could lncreeee by a factor of 3, with the potential existing for an axpoaura la excess of the two (2) flbera/ce of elr ahould the work be performed over an 8-hour period (potential expoaure ef approxlaattly 2.4 flbera/cc). The eeae factor can be applied to a aaaple which showed en exposure of 0.47 flbera/ce to Prlabylla while installing three aectiona of Insulation. Again, only one of the three sections installed contained asbestos. A potential axpoaura of approxlaataly l.S flbera/cc axlata (ahould all sections contain asbestos) which again la approaching the peralaelble exposure Hale of two (2) flbers/cc. Co-worker 'Cohlogue alao hed an axpoaura of 0.47 flbers/ce of air for the aeae tine period, with en Identical potential expoaure existing. Insulator Behary*a expoaure while loading and reaovlng old Insulation fron the work area was .21 flbers/cc. Considering that only -ibout one-fourth of the aectiona disposed of vaa sabeatoa-bearlng notarial, i approxlaate potential exposure increased by e factor of 4 exists. In corporating thla factor into Che exposure obtained, en expoaure to one (1) flber/cc aey have existed had ell of the aaterlal been asbestoa-baariag. USEI000079 In s ta lle d fiv e f u l l lengths am one le n g th o f asbestos-bearing in s u la tio n U 3 Ou fl d u JS M a! 0 M fH *3 o o 0 O <s doo JuS 2 me o u r*4 m 3 m C0 ** m e M *J 0 m c 3? sm*4 3s ?T3 aaa U0 m +a4 21 s sa .a -t ^ $ 4 u 33 4 ae a5 e S3 o * a a JS v4k M um 0 m s ^*34 O u0 o i*4 0 2 * 3 mom S 5" ?i%4 m , gsHS -UH f 0 a i <* a o <*4*3 W 3 s?3<-t a H * u9a a iMa s< *mO a * u o*4 aa M <3 a 1 HM Is tn N H HN 0v O o $ AS . ASBESTOS EIPOSU1ES 12 C. Coalogua (s c a ffo ld ) k> M -O >-4 5 A0i ^o S9-4 **44 3c *U USEI000080 In s u la to r iI A5IXST0S LXVKLS (Flbere/ec of Air) 10-31-79 TAILS IX LDCATXOW A fe. akm grn--i 1ml iprtodattily 4 ft. aorth of the plgellm 2 fe. ikm pail Iml pproxlaately 10 ft. aorth of tho plgallaa 93 110 0.0* 0.03 Fexaleolhle Lladtsi AabMtoo 1) 2 flboro/ee pttttr then S adcroaa la length - 8-Hour TVA2 2) Celling Halt - 10 flhere/ee USEI000081 UNITED STATES STEEL CORPORATION U-AIKTUN WORKS ENVIRONMENTAL & HEALTH SERVICES DECEMBER II, 1979 MEMORANDUM SUBJECT: Mechanic and Apprentice Mechanic Exposures Garage and Locomotive Crane Repair Station Compensation Claim - Julius Onyika On October 9 and 10, 1979, a survey was conducted by the Environmental and Health Services Department to determine the exposures of the mechanics and apprentices to various airborne contaminants. Criteria: Section 1910.1000 and 1910.1001 of the Occupational Safety and Health Act limits employee exposures to various physical and chemical agents. The Permissible Limits for those substances present in the garage and repair stations are as follows: SUBSTANCE Total Particulates Chromates Iron Oxide Asbestos 8-Hour Limit (TWA) 3 15.00 mg/m 0.05 mg/m;: 10.00 mg/nr 2 fibers/cc Ceiling Limit 10 fibers/cc (greater than 5 microns) (greater than 5 microns) Conclusions: The personal sampling results indicated the exposures of mechanics and apprentices in the Garage and Locomotive Crane Repair Station to the substances listed were well below the Permissible Limits. Sampling conducted October 9 and 10 indicated Total Particulate exposures of 1.18 mg/m-*, 0.10 mg/m^, 0.14 mg/m^ and an Asbestos exposure of 1.35. fibers/cc. The samples collected for chromates analyses indicated 'no detectable levels of exposure. Recommendations: As indicated, exposures to Total Particulate, Chromates, Iron Oxide, and Asbestos were well below established safe limits; therefore, no precautions need be taken by the mechanic or mechanic helper against these contaminants. USEI000082 Discussion: The garage is primarily used for motor vehicle repair, ancf general upkeep of motorized equipment such as portable-welders. All typer of services are performed, from visu4l inspections co engine overhauls. The personnel were sampled for exposures to Total Particulates, Iron Oxide, Chromates, and Asbestos. The Particulates, Including Iron Oxide were evolved by mechanical attrition, although some Iron Oxide may have resulted from the small amount of burning and welding done in the shop. The Asbestos was generated from changing brake shoe pads. The exposure results indicated all the personnel were below the permissible limits for all substances sampled. The Total Particulates averaged less than 5X of the allowable level of IS mg/m^ (1.18 mg/m^, 0.18 mg/m^ and 0.25 mg/m^). No Chromates were detected since very little welding or burning was conducted in the shop. The majority of Iron Oxide found was present in the form of rust. Iron Oxide exposures to the mechanic and apprentice were well below the Per missible Exposure Limit of 10 mg/m^ (0.26 mg/m% 0.10 mg/m^, and 0.14 mg/sP). An asbestos sample was collected during a visual inspection of the brake pads of #15 fire service truck. The mechanic, wearing a Duscfoe 66 respirator, blew off the brakes and drum with an air hose. According to his foreman, it is not common practice to use an air hose. Thus, even though his exposure was well below the permissible ceiling limit, it could be assumed that his exposure would have been considerably less had proper procedures been followed. His exposure to Asbestos was 1.35 fibers/cc while the permissible ceiling limit is 10.00 fibers/cc. TMC/cay cc: W. C. King H. S. Miller T. F. Weir, M.D. General Supervisor Environmental Health & Safety USEI000083 > OCCUPATION Mechanic Apprentice Apprentice Mechanic MECHANIC AND APPRENTICE MECHANIC EXPOSURES CARACE AND LOCOMOTIVE CRANE REPAIR STATIONS 10-9 and 10 - 79 TABLE I Time (Min) Total Particulates Chromates Iron Oxide Asbestos (mg/a3) (ag/m3) (ag/a3) f/cc 421 1.18 0.0 0.26 - 420 0.18 0.0 0.10 - 422 0.25 7_ 0.0 0.14 - - 1.35 Substance: Total Particulate Chromates Iron Oxide Asbestos 8-Hour Limit (TWA) 15 mg/a^ 0.05 ag/a^ 10.00 ag/a^ 2 fibers/cc (greater than 5 microns) Ceiling Limit - 10 fibers/cc (greater than 5 microns) o. n * m im.o a USEI000084 D. M. Ferguson l. G. Gainer Asbestos Survey - Patchers Vmtcd Ccrrpomtxcm EASTERN STEEL DIVISION March 18, 1980 N. R. Stromness, Superintendent Environmental & Health Services On March 11, 1980, an asbestos survey was conducted on #8 Battery. The purpose of the survey was to evaluate employee exposures to asbestos fiber while using asbestos rope to pack sllpjolnts. Criteria: OSHA limits an employee exposure to asbestos dust to two fibers longer than five micrometers per cubic centimeter of air based on an eight hour time weighted average exposure. Conclusions: The results of the survey (Table 1) Indicate time weighted average exposure of 0.08, 0.05, and 0.03 fibers/cc of air for the three employees monitored. These exposures are within the permissible exposure limit of i fibers/cc as established by OSHA. Recommendations: 1. During the survey, It had been noted that compressed air was used to blow out sllpjolnts. This practice should be discontinued Immediately. 2. The Safe Job Procedure (P-31) January 29, 1980, should be followed PRB/cay Attachments USEI000085 f ASBESTOS SURVEY ClAIRTOH WORKS 3/11/80 TABLE I ' Activity fora tlon/mlnotes (Replacement of 4 standpipes on #8 Battery} Patcher - Pavlack Chipped out old asbestos around the standpipe, cleared out old asbestos with compressed air. After the stand pipe was removed, used compressed air to clear opening of debris. Also chiseled carbon from Inside of opening. Sprayed In repair cement. After new pipe was put In place, he packed the wet asbestos rope In sllpjolnt and sealed with mortar. 13B Asbestos Exposure Flbers/cc .16 Continued as above on other standpipes as they were removed. Alternated jobs with other Patcher. 45 .33 Time Weighted Average exposure (TWA) is .08 flbers/cc air Patcher - Day Chipped out old asbestos around the standpipe. After the standpipe was removed, used compressed air to clear opening of debris. Also chiseled carbon from Inside of opening before spraying In repair mortar. After new pipe was put In place, he packed wet asbestos rope In the sllpjolnt & sealed with mortar Continued as above on other standpipes as they were removed. Alternated jobs with other Patcher. 135 48 .11 .23 i Time Weighted Average exposure (TWA) Is .05 flbers/cc air USEI000086 3/n/oo ASBESTOS SURVEY (continued) Activity (Replacement of 4 standpipes on i #8 Battery) Ouratlor./mlnutes Asbestos Exposure Flbers/ec Patcher - Walker Worked on walkway above battery main. Chipped out asbestos around upper sllpjoint. After new pipe was put In place, packed sllpjolnt with wet asbestos rope and sealed with mortar. Continued as above with packing new slip* joints as the pipes were replaced. 129 55 .06 .14 Time Weighted Average exposure (TWA) Is .03 ftbers/cc air ! USEI000087 T: W. J. Kelly, Olvision Superintendent Maintenance & Utilities lukjMt: Asbestos Survey - Bricklayers # 14 Battery ) United States Steel Ccrrparaturn EASTERN STEEL DIVISION Date April 1, 1980 s. Fnau N. R. Stromness, Superintendent Environmental & Health Services On March 25, 1980, an asbestos survey was conducted on #14 Battery rebuild. The purpose of the survey was to evaluate employee exposure to asbestos fiber while using asbestos rope to pack around the air boxes being installed on the battery. Criteria; OSHA limits an employee exposure to asbestos dust to two fibers longer than five microns per cubic centimeter of air based on an eight hour Time Weighted Average exposure. Conclusions: The results of the survey (Table 1) indicate Jime Weighted. Average exposures of .15 fibers/cc of air for. both employees monitored. These exposures are within the permissible exposure limit of 2 fibers/cc as established by OSHA. Recownendations; The practice of wetting the asbestos rope before using should be continued. The rope should be wetted before cutting or be cut on a wet saw. PRB/cay Attachment cc; K. A. Elkan T. G. Wylie T. F. Weir USEI000088 ASBESTOS SURVEY Clalrton Works 3/25/80 ACTIVITY TAB DURATION/MINUTES Bricklayer - Berclk Wetted pre-cut pieces of asbestos rope and then packed the rope around the air boxes. Used a metal rod to pound the rope Into place. (This exposure Includes time spent at lunch) 112 80 141 TIME WEIGHTED AVERAGE EXPOSURE (TWA) s .15 flbers/cc of air. Bricklayer - Mil las Wetted pre-cut pieces of asbestos rope and then packed the rope around the air boxes. Used a metal rod to pound the rope Into place. (This exposure Includes time spent at lunch) 110 80 144 TIME WEIGHTED AVERAGE EXPOSURE (TWA) Is .15 flbers/cc of air. ASBESTOS EXPOSURE FIBERS/cc .07 .61 .11 .14 .47 .13 USEI000089 Tk Mr. K. A. Elkan General Superintendent Clairton Works Asbestos Sample Analyses / United. States Steel Corporation. tofarorgantzatfon Corratpondanca 0U: April 28, 1980 fWK W. C. Janes, Manager Environmental Health Attached are the results of asbestos analyses conducted by Environmental Health on samples submitted by your plant on April 18, 1980. JFQ:mt Att. cc: T. M. Civic USEI000090 USEI000091 W. J. Kelly J. F. Boal Asbestos Exposures - 14 Battery Rebuild United States Steel EASTERN STEEL DIVISION <*: Hay 7, 1980 fnm: N. R. Stromness, Superintendent Environmental & Health Services On April 16, 1980, a survey was conducted by the Environmental and Health Services Department to determine the asbestos exposures of bricklayers packing asbestos rope around air boxes on 14 Battery Rebuild. Criteria: Section 1910.1001 of the Occupational Safety and Health Act limits employee exposure to asbestos fibers greater than five (5) microns to two (2) fibers/cc for an 8-hour Time Weighted Average (TWA). The ceiling limit for asbestos is ten (10) fibers/cc of air. Conclusions: 1) Eight-hour Time Weighted Average exposures to the two bricklayers samoled while packing air boxes on the coke side of 14 Battery Rebuild showed full shift exposures which were well below the eight hour Permissible Exposure Limit of 2 fibers/cc of air. Exposures to the bricklayers were .19 fibers/cc and 0.22 fibers/cc respectively. TABLE I 2) Short-term exposures ranged from .02 fibers/cc to .94 fibers/cc for the two bricklayers. These exposures were well below the short-term ceiling limit of 10 fibers/cc of air. TABLE I Recorrmendations: 1) All asbestos rope should continue to be presoaked prior to use. 2) Measures to properly handle asbestos products should be followed. These should include: (a) designated storage locations, (b) imediate clean-up of work area, and (c) disposal of waste asbestos rooe in plastic bags. 3. The Safe Job Procedure for handling and using asbestos rope should be followed at all times. Employees working with asbestos should be provided respirators upon request. Current exposures do not dictate mandatory use of respiratory protection. USEI000092 -2- 4) Employees working with asbestos rope in the Rebuilds should be scheduled for medical examinations. All Rebuild employees should have been previously coded to receive a sT.Ica examination. In addition, all Rebuild employees using asbestos in their work should be coded as requiring a silica and an asbestos examination. Discussion On April 16, 1980, a survey was conducted to determine the exposure of bricklayers to asbestos while packing air boxes on 14 8attery Rebuild. Two bricklayers working as a team were sampled over the full work shift. The basic procedure for the packing Involved compacting four to five lengths of asbestos rope around the exterior of the air boxes with the aid of a metal bar. Exposure results showed eight-hour Time Weighted Average Exposures of 0.19 fibers/cc and 0.22 fibers/cc to the two bricklayers as compared to the 8-hour Permissible Exposure Limit. However, all personnel at the Battery Rebuilds who Install asbestos must be scheduled to receive an asbestos examination In addition to the silica examination which all Rebuild personnel should be currently scheduled for. Short term exposures which ranged from .02 fibers/cc to .94 fibers/cc were well below the Permissible Ceiling Limit of 10 fibers/cc. As has been required previously, asbestos rope should be soaked prior to use to prevent unnecessary dispersion of asbestos to the air. Proper handling methods Including designated storage locations, immediate clean up of work areas, and disposal of waste asbestos rope in plastic bags should be foil owled. The Safe Job Procedure which contains proper handling methods should be followed. Should an employee working with asbestos request a respirator, one should be provided. Current exposures do not dictate mandatory use of respiratory protection. JRD/cay USEI000093 AS8EST0S EXPOSURES Battery Rebuilds - Packing Air Boxes 4-16-80 TABLE I Activity 1. Packed top and bottom of Air Box 24 2. Packed top and bottom of Air Box 25 3. Packed top and bottom of Air Box 23 4. Packed top and bottom of Air Box 22, Lunch 5. Packed top of Air Box 21, bottom of Air Box 22 6. Packed bottom of Air Box 21 7. Packed top and bottom of Air Box 20 Duration (minutes) 50 85 55 no 45 25 35 Asbestos Exposures (fibers/cc) Bricklayer Bricklayer AB 0.02 0.72 0.18 0.02 0.11 0.13 0.24 0.02 0.53 0.11 0.49 0.78 0.18 0.94 Eight Hour Time Weighted Average for Bricklayer A - 0.19 fibers/cc " .......................... "" " B - 0.22 fibers/cc Permissible Exposure Limits: 1) 8-Hour TWA - 2 fibers/cc 2) Ceiling Limit - 10 fibers/cc USEI000094 Tt: K. A. Elkan L. G. Gainer W. J. Kelly T. F. Weir, M.O. /CL-**-'-' ,'L. <v. Oi. ' "United. States Steel Corporation EASTERN STEEL DIVISION <uu: November 10, 1980 Fnm: tt. R. Stromness, Superintendent Environmental & Health Servlroc sutjwt Asbestos Levels. - Batteries T-3 and Battery 15 Monitoring was conducted October 22 and 23, 1980 on Battery Unit 1-3 and Battery 15 to determine ambient concentrations of airborne asbestos. Established OSHA standards limit exposure to asbestos fibers in excess of 5 microns to 2 fibers/cc of air for an 8-Kour Time Weighted Average (TWA), and 10 fibers/cc as a maximum ceiling limit. Corporate and OSHA guidelines of 0.1 fiber/cc have been established as the baseline for medical examinations and monitoring requirements. Conclusions: 1) Every sample collected for asbestos fibers on both 1-3 Batteries and 15 Battery was well below the 2.0 fibers/cc 8-Hour TWA exposure limit, the 10.0 fibers/cc ceiling limit, and the 0.1 fibers/cc medical examination and monitoring guideline. Levels ranged from 0.00 fibers/cc to 0.06 fibers/cc. Tables I and II 2) .All TWA's for 1-3 Batteries and 15 Battery were also below the 2.0 fibers/cc 8-Hour TWA exposure limit, and the 0.10 fibers/cc medical examination and monitoring guideline. TWA's for the various locations surveyed ranged from 0.002 fibers/cc - 0.027 fibers/cc. Tables I and II 3) There were no significant differences in the asbestos levels detected on the Top, Bench, and Alley levels of 1-3 Batteries. TWA levels were 0.011 fibers/cc, 0.009 fibers/cc, and 0.014 fibers/cc for the Bench, Alley, and Topside levels respectively. Table II 4) There were no significant differences in the asbestos levels detected on the Top, Bench, and Alley Levels of 15 Battery. TWA levels were 0.01?. fibers/cc.0.011 fibers/cc,and 0.012 fibers/cc for the Bench, Alley, and Topside levels respectively. Table I 5) No significant differences were detected between the newly rebuilt 15 Battery and the older 1-3 Battery Unit. Respective TWA's were 0.011 fibers/cc for 15 Battery and 0.012 fibers/cc for the 1-3 Batteries. Recommendation: 1) Since all levels of asbestos were well below all exposure limits and guidelines, medical examinations and monitoring are not required for asbestos exposure for personnel working on the Batteries. USEI000095 -2- Discussion: The survey conducted on the newly rebuilt 15 Battery showed asbestos levels of 0.012 flbers/cc as calculated for a TWA for the entire battery. A further breakdown of the results was made for the Bench, Alley, and Top levels. Results from the 15 Battery Bench Level monitoring showed a TWA on the Push side of 0.002 fibers/cc with levels ranging from 0.00 flbers/cc to 0.020 fibers/cc throughout the day. Coke Side showed a TWA of 0.012 fibers/cc for the shift with levels within the time period ranging from 0.00 fibers/cc to 0.03 fibers/cc. The north and south transfer areas showed TWA's of 0.009 fibers/cc and 0.024 fibers/cc respectively, with individual exposure levels ranging from 0.00 fibers/cc to 0.06 fibers/cc. A TWA for the entire Bench Level of 15 Battery was shown to be 0.012 fibers/cc. Table I Samples collected in the Alley or basement level of 15 Battery showed a TWA for the entire lower level of 0.011 fibers/cc. A TWA for the Push Side Alley showed a level of 0.010 fibers/cc with individual exposure levels ranging from 0.00 fibers/cc to 0.04 fibers/cc. The Coke Side Alley showed a TWA of 0.014 fibers/cc, calculated from samples which ranged from 0.00 fibers/cc to 0.05 fibers/cc. The Basement Level Transfer Areas showed a TWA of 0.010 fibers/cc and a range of 0.00 fibers/cc to 0.03 fibers/cc. Table I Monitoring conducted on 15 Battery Topside showed a TWA of 0.012 fibers/cc for the entire area. Samples collected on the Push Side showed a TWA of 0.013 fibers/cc and a range for the samples collected of 0.00 fibers/cc to 0.04 fibers/cc. Coke Side monitoring showed a TWA of 0.015 fibers'/cc with a range of 0.00 fibers/cc to 0.06 fibers/cc. The Topside Transfer Areas ranged from 0.00 fibers/cc to 0.04 fibers/cc with a TWA of 0.009 fibers/cc. Table I Asbestos monitoring was also conducted October 23 on 1-3 Batteries which is an older Battery Unit. Results from the monitoring indicated a TWA for the entire 1-3 Battery Unit of 0.011 asbestos fibers/cc of air. A further breakdown into Top, Bench, and Basement Levels is also provided. Sampling conducted on the bench level indicated a TWA for the Coke Side of 0.009 fibers/cc and a range of 0.00 fibers/cc to 0.04 fibers/cc. Coke Side results ranged from 0.00 fibers/cc to 0.05 fibers/cc withaTWA of 0.018 fibers/cc, while Bench Level Transfer Areas showed a TWA level of 0.008 fibers/cc with a range of 0.00 fibers/cc to 0.02 fibers/cc. A compliation of the Bench level data indicates a TWA for the entire 1-3 Battery Bench Level of 0.011 fibers/cc. Table II Alley or basement level monitoring on 1-3 Battery showed a TWA for the Push Side of 0.008 fibers/cc arc! an individual range of 0.00 fibers/cc to 0.C4 fibers/cc. Coke Side levels ranged from 0.00 fibers/cc to 0.02 fibers/cc with a TWA of 0.010 fibers/cc. A TWA for the entire Alley Level showed an asbestos level of 0.009 fibers/cc. Table II. USEI000096 -3Topside Exposure measurements showed a Push Side TWA of 0.005 flbers/cc with a range of 0.00 flbers/cc to 0.03 flbers/cc, while coke side levels were shown to range from 0.00 flbers/cc to 0.05 flbers/cc. A TWA for the entire Top Level of 1-3 Battery was shown to be 0.014 fibers/cc. Table II JRD/cay Attachments cc: VW. C. Janes USEI000097 PUSHER MACHINE Sample Time (min.) Flbers/cc 68 0.00 93 0.00 83 0.01 70 0.00 99 0.02 TWA 0.002 ASBESTOS MONITORING IS Battery 10-22-80 TABLE I BENCH LEVEL DOOR MACHINE SOUTH TRANSFER Sample Time (min.) Flbers/cc Sample Time (min.) Ffbers/cc 77 0.00 96 0.02 82 0.03 69 0.01 82 0.00 77 0.00 96 0.03 80 0.01 71 0.00 82 0.00 TWA 0.012 TWA 0.009 NORTH TRANSFER Sample Time (min.) Flbers/cc 69 0.06 97 0.00 85 0.00 65 0.03 91 0.04 TWA 0.024 TWA 15 Battery Bench Level * 0.012 Flbers/cc TWA 15 Battery * 0.012 Flbers/cc Permissible Limits: 8 Hour TWA - 2.0 Ffbers/cc Ceiling Limit - 10.0 Fibers/cc USEI000098 ASOESTOS MOMI TORIMG o> O COI rrs CNi CD CNJ oI USE1 0 0 0 0 9 9 TWA 15 Battery Top Level = 0.012 Fibers/cc TWA 15 Battery = 0.012 Flbers/cc 3-- o *-- T oj W cc <-> ASBESTOS MONITORING 0 .0 0 9.01 0.001 10*0 00*0 oc o uj ae U. UJ in xz eS ae t- oz g 2 u. U_Ji Ui < 5i- z in w CoM> .0 in f*** f* Oi < THA 0 .0 2 95 95 oe o Ui X U. UJ VO _ X o u *S. iOnf UJ SI u. i- s in UJ --* 5 1-- in --* 76 s n CM o O o o ooooo 8 CM' 62 62 >UJ o u io g <z Ui UCOJ UI _ aw z H- vo x U. o UJ z U|J*c*-* >w Of 4+->f o 001 *+>coo!J# u> 5 hi mw <0 CM CD CM1 in o 2 m 2ea Ij o c C UXJ u u in aUeI CD UoJ x U. *- H- m oUi <> oX UJ |*c u> o CO oooo d o o o' o' 0.05 72 0.04 76 86 10*0 66 CM O o oo 78 97 -CM in m o d c CO c d in oCM o >ui -^J < oz UJ UJ QX *- -- <n x o VO X o. uu g Ui CD U ^i 51- x in s** o Oo oo o o o o' r a* iO r- VO ov 0 .0 0 62 o o1 0 .0 2 0 .0 2 000 UJ _I <z UJ UJ MM Hx- mx c xm m XUi CD U UJ X a. S?` ' C vCOM *r cr> r*-. m in o% 5- m --* CO oo o < CM o d TWA TWA t 2 inN o> */> (a H01- u I u uu u 4/) t- u 5 0 JS o o N H m Of > Of < s* -Oof < CO Of 01 om u CO < in u u -0O1 o o o n in s? o o H -Oof o o o mM j= W cn 3D Cu 3 TWA 15 Battery * 0.012 Flfcers/cc uu uu <u/ <u/* Of c i . OC c\i C " <r-S US- TI-- -- /> <> U 3- g <1j t *- Push Side Alley 3 Battery Sample Time (min.) Flbers/cc 106 57 198 TWA 0.00 0.04 0.01 0.010 ASBESTOS MONITORING 1-3 Batteries 10-23-80 TABLE II BASEMENT LEVEL Push Side Alley 1 Battery Coke Side Alley 3 8atter> Saple Time (min.) Flbers/cc Sample Time (min.) Fibers/cc 117 0.00 160 0.02 229 0.003 49 0.02 99 0.02 85 0.00 TWA 0.006 TWA 0.013 Coke Side Alley 1 Battery Sample Time (min.) Fibers/cc 180 0.00 81 0.01 170 0.01 TWA 0.006 TWA Push Side Alley 1 -3 * 0.008 Fibers/cc TWA Coke Side Alley 1 -3 * 0.010 Fibers/cc TWA 1-3 Alley Level - 0.009 Fibers/cc TWA 1-3 Battery * 0.011 Flbers/cc Permissible Limits: 3-Hour TWA - 2.0 Fibers/cc Ceiling Limit - 10.0 Fibers/cc USEI000101 ASBESTOS MONITORING TWA 1-3 Battery = 0.011 Fibers/cc *%/s> <UU 0L1 * C h<u*0 00 <o i CM <S1 HZ COM S 5 o go V) CM co 4c0o 0V0) sC7> uu V) as 0> 4m(c/-) m u CM h- ui 5? x c 5kz m CM o CM MO 9t to V) o o < t/t <D ou </) t/1 4- 0J C o L. o <04JJ co 1 u CO CM *-4 o UJ CO czJ o * CD t. UJ > O CO O1 a.; UJ -J a ey Si U) z UJ lA OJ 4/ fC- U*- 4= OJ O ** uo /> 00 w o co oi O r-- aJ. UJ c 5{= V> W 8CO ro co oooo o d o VO co in vn Cf> CM fN. CO r** co O o o o m o o o CM o o in o *3* oin o CM o m d oj C vn xu:- oj i- U U U00J 4- L. <9 01 CO J\9ZA coi a. cm a. X r- co o o O 'o o d o o CO m *r CO o\ CO VO CM f*** c>* oo m a: o o o o o o o o O o o o do -j i ! 1^ VO n VO vo fc-o. CM u u Vu* OJ Xi CO o o d N <u on co I QJ 4- (/) CuO u uo IA u 0) QJ *o GO O do II d H o c 0J 00 01 CO CO I 01 CO 01 o u u u j0QJ OH o o d M 0c 01 CQ CN O r--1 QJ o "O o CO o H-f JZ W D CL CO D \A </> L U OJ 01 c CM < I 3 --1 u e 3 *o *-- "7 OJ 00 0) 2 m !I Push Side 1 Battery Sample Time (min.) Fibers/cc 105 77 93 | 82 79 TWA 0.00 0.00 0.00 0.03 0.00 0.006 ASBESTOS MONITORING 1-3 Batteries 10-23-80 TABLE II (Cont.) TOP LEVEL Push Side 3 Battery 1 Sample Time (min.) Fibers/cc Coke Side 1 Battery Sample Time (min.) Fibers/cc 39 0.00 62 ,0.00 53 0.00 48 0.02 68 0.00 74 0.00 95 0.01 107 0.007 74 0.05 92 0.03 84 0.01 76 0.05 TWA 0.027 TWA 0.004 - Coke Side 3 Battery Sample Time (min.) Fibers/cc 40 0.00 60 0.03 55 0.03 115 0.007 77 0.03 73 0.02 TWA 0.019 TWA Push Side 1-3 Batteries 0.005 Fibers/cc TWA 1-3 Batteries Coke Side 0.023 Fibers/cc TWA Top Level 1-3 Batteries * 0.014 Fibers/cc TWA 1-3 Battery 0.011 Fibers/cc Permissible Limits: 8-Hour TWA - 2.0 Fibers/cc Ceiling Limit - 10.0 Fibers/cc USEI000103 /' t Mr. J. A. Diardorf General Supervisor > Safety and Environmental Health Clairton Works Analyeie of Insulation Material June 5, 1981 J. F. Quealy Senior Environmental Health Engineer On May 29, 1981, an unidentified sample of insulation material was received from Pat Bossier of Clairton Works for determination of possible asbestos content. Pat indicated that the material tested positive for iron using the SXC asbestos screening method. Oust generated from the sample was examined under polarizing light microscopy at 450x end was found to contain a significant fibrous component. However, these were extremely long, pitted, ribbon like, singular fibers, unlike the fibrous bundles generally found in asbestos materials. In addition, the wide fiber diameters, ranging from 10 to 50 microns. Were much larger than those usually observed in asbestos fibers. In summary, it is our opinion that the fibrous component of this sample is not asbestos, but probably some form of paper or wood fiber. J. F. Quealy jmr USEI000104 T Mr. J. A. Dierdorf General Supervisor Safety and Environmental Health Clairton Works tubj*et Analyses of Insulation Materials Vmtsd Iniarorganization Corratpondtnce Date August 27, 1981 Frwn: J. F. Quealy Senior Environmental Health Engineer As requested. Environmental Health has analyzed three bulk samples of insulation materials submitted by Jim Santory for determination of possible asbestos content. Two of the samples were Transite board from the Benzene Lab and Transite pipe from the Electric Shop. The third sample was identified as crucible tray insulation from the Benzene Lab. Transite is a trade name product of the Johns-Manville Corporation. It is a composite asbestos/cement material extensively used in rigid insulating board or pipe applications. Johns-Manville has informed us that it contains approximately 35% chrysotile asbestos, by weight. We confirmed the presence of chrysotile under polarizing light microscopy, using the dispersion staining technique Microscopic examination of the crucible tray insulation showed it to be composed exclusively of homogeneous fibrous material These were long, singular fibers, unlike the fibrous bundles generally found in asbestos. In addition, the uniform fiber diameter of approximately three microns was somewhat larger than those usually observed in asbestos. Under polarized light, these fibers were found to be an isotropic substance, i.e., having only one index of refraction such as fiberglas or mineral wool. This test eliminates any possibility of the material being asbestos. JFQ/jmr USEI0001 Mr. C. 1. Kellly Diraccor of Safety Rational Tuba Divieion BUXLDXHG ui 959 Kamaeh M. Norse, Dirac cor Induacrial Ryglene Toxic Limitt Ac par your request, nay X suggest you concider including cha following information with your transmission r of tha enclosed tables of "Threshold Limit Values for 1958." The enclosed list of "Threshold Limits" are known under a variety of names, such as "maximum allowable con* centrations," "toxic limits," etc. They are not exact delinea tions between hasard and non-hazard conditions, since they are derived from a variety of sources. S*ne are based upon studies with human subjects, others upon opinions derived by interpo lating from animal experimental data, while still others are based merely upon unsupported opinions from industrial medical and hygiene authorities, however, the fact remains that these limits are often incorporated into state codes or used by state inspectors as exact numbers above whleh a condition is dangerous. Therefore, in actual practice, it is important to maintain air concentrations of these gases, vapors, dusts or sdsts within such levels where possible or protect workers by approved respiratory devices. These data are tha maximum degree of air contamination to which one should be exposed upon a continuous f-hour daily and 40-hour weekly basis. Thr data, therefore, are degrees of air contamination which will prevent the development of chronic poisoning arising from continuous day to day exposures. Xt is our opinion that short-term exposures also should be maintained within such limits where practicable, because of the absence of good data on safe concentrations for preventing acute (sudden) poisoning. This approach is considered to be tha best course of action because the human body does not respond in a direct arithmetic relationship with the amount of contaminant in the air. In other words, it would not be prudent to expose an individual for one hour to eight times the values shown in the enclosed table without respiratory protection, furthermore, state inspectors would no doubt consider such exposures as" hazardous to health. mf USEI000106 4 Threshold Limit Values for 1958 Adopted at the 20th Annual Meeting of the American Conference of Governmental Industrial Hygienists Atlantic City, April 19-22, 195S Reprinted frtm ikt A. it. A. ArcUeet / leduttriel Hcelth ' Aufuu tost. v*l it, pp. m-m Cepfripht l9St, hr America Medicel Auocietion USEI000107 k Threshold Limit Values for 1958 Adopted at the 20th Annual Meeting of the American Conference of Governmental Industrial Hygienists Atlantic City, April 19-22, 19id Threshold limits should be used as fuides in the control of health hazards and should not be regarded as line lines between safe and dangerous concentra tions. They represent conditions under which it is believed that nearly all workers may be repeatedly exposed, day after day, without adverse effect. The values listed refer to time-weighted average concentrations for a normal work day. The amount by which these figures may be exceeded for short periods without injury to health depends upon a number of factors, such as the nature of the contami nant, whether very high concentrations even for short periods produce acute poisoning, whether the effects are cumulative, the frequency with which high concentrations occur, and the duration of such periods. All must be taken into consideration in arriving at a decision as to whether a hazardous situation exists. Special consideration should be given to the application of these values in the evaluation of the health hazards which may be associated with exposure to com binations of two or more substances. Threshold limits are based on the best available information from industrial experience, from experimental studies, and, when possible, from a combination of the two. These values are based on various criteria of toxic effects or on marked discomfort: thus, they should not be used as a common denominator of toxicity, nor should they be considered as the sole criterion in proving or dis proving diagnosis of suspected occupational disease. These limits are intended for use in the field of industrial hygiene and should be employed by persons trained in this field. They are not intended for use. or for modification for use. in the evaluation or control of community air pollu tion or air-pollution nuisances. These values are reviewed annually by the Committee on Threshold Limit* for changes, revisions, or additions as further information becomes available. The Committee welcomes-the suggestion of substances to be added to the list and also comments, references, or reports of experience with these materials. Submitted for publication May S, 1958. RECOMMENDED VALUES ` Cases tad Vapors ISTAXd PPM* Acetaldehyde .......... ...... 200 Acetic acid .......... .... 10 Acetic anhydride ... 5 Acetone ................. .... 1.000 Acrolein ................. 0.5 Acrylonitrile .......... Ally! alcohol ......... S Ally! ehlohdt ......... 5 Approx. Me. oer Cu.M t 560 25 20 2.400 U 45 12 15 SultTAXCt PPM* Ally! propyl disulfide Ammonia ................... Amyl acetate ............ .. Amyl alcohol (isoamyi alcohol) .. .. Aniline ...................... Arsine ........................ Benzene (beuol) ___ 2 200 100 *00$ 25 17t Approx Mg per Cu. M t 12 *0 1.030 560 19 02 so 4 USEI000108 a TmHRESHOLD LIMIT VALUES FOR Mt SrasTAxct PPM Benzyl chloride ........... 1 Bromine ........................ 1 Butadiene (lj-butadiene) .......... . 1,000 Butanone (methyl ethyl ketone) . 250 Butyl icttiit (butyl acetate) ... . 200 Butyl alcohol (butanol) ............... . 100 Butylsmine ................... 5 Butyl ctlloaohf (2*butoxyethanol) ... SO Carbon dioxide............. . 5,000 Carbon disulfide .........., 20 Carbon monoxide .......... 100 Carbon tetrachloride -- 25 CcJioiolve (2-ethoxyethanol) --. 200 Gellosoive acetate (2-ethoxyethyl acetate) 100 . Chlorine ........................ 1 Chlorine trifluoride ....... 0.1 Chlorobenzene (monochlorobenzene) .. 7S Chloroform (triehloromethane) ... 100 l-Chloro-l-nitropropane . 20 Chloropicrin ................... 1 Chloroprenc (2-chloro-12-butadicne) 25 Crool (alt isomers) ... 5 Cvclohexane ................... 400 Cydohcxanol ................... 100 Cyclohexanone ............... 100 Cyclohexene ................... 400 Cyclopropane................... 400 Dealbonne .................... 0.05 Diacetone alcohol (4-hydroxy-4-methyl- 2-pentanone) ............... SO Diborane ........................ 0.1 o-Dichlorobonene .......... so Dichlorodifluoromethane 1.000 1,1-Dichloroethane .......... 100 12-Dichloroethane (ethylene dichloride) .. 100 12-Dichlorocthylcne ___ 200 Dichloroethyl ether ..... is Dichloremonofluoro- methane ...................... 1,000 1,1-Dichloro-l-mtTo- ethane .......................... 10 Dichlorotetrafluoroethane 1,000 Dicthylamine ................... 25 Difluorodibroroomethane 100 Diiaobutyl ketone .......... so urs CaU.t s 7 2200 740 9S0 200 . IS 240 9,000 60 110 160 740 540 3 04 350 490 100 7 90 22 1,400 410 400 1J50 690 OJ 240 0.1 300 4.950 400 400 790 90 4200 60 7,000 75 S60 290 i JSSTAKCS PPM Dimcthylanilme (N-dimethylaniline) . S Diacthyliulfate .......... 1 Diexane (dicthylcne dioxide) ................... . 100 Ethyl acetate .............. . 400 Ethyl acrylate.............. 25 Ethyl alcohol (ethanol) 1.000 Ethylaminc ................... 25 Ethylbentene .................. 200 Ethyl bromide ............ .. 200 Ethyl chloride .......... , . 1,000 Ethyl ether .................... 400 Ethyl formate ............... 100 Ethyl aelicatc ............... . 100 Ethylene ehlorohydrin .. 5 Ethylenediamine ............ 10 Ethylene dibromide (12-dibromoethane) .. 2S Ethylene mint.............. 5 Ethylene oxide ............ 50 Fluorine ........................ 0.1 FIuorotriehloromethane . 1,000 Formaldehyde ................ 5 Furfural ........................ 5 Gasoline ........................ 500 Heptane (a-beptane) ... SOO Hexane (hexane) ... 500 Hcxanone (methyl butyl ketone) ...................... 100 Hexone 'methyl isobutyl ketone) ...................... 100 Hydrazine. ..................... 1 Hydrofcn bromide......... 5 Hydrogen chloride......... 5 Hydrogen cyanide ......... 10 Hydrogen fluoride ......... 3 Hydrogen peroxide, 90`S 1 Hydrogen telenide ......... 0.05 Hydrogen sulfide ......... 20 Iodine ........................... 0.1 Isophorone ..................... 25 Isopropylamine .............. 5 Mesityl oxide ................ 25 Methyl acetate .......... 200 Methyl acetylene .......... 1.000 Methyl acrylate ............ 10 Methyl alcohol (methanol) ................ 200 Methyl bromide ............ 20 Methyl ctllosolve (2-methoxyethanol) .. 25 Methyl ctllosolve acetate (ethylene glycol mono methyl ether acetate) .. 25" Methyl chloride ............ 100 Approx. Me per CuM 25 5 360 1.400 100 1,900 45 870 890 2.600 1200 300 850 16 30 190 9 90 02 5,600 6 20 2.000 2.000 1,800 410 410 1.3 17 7 11 2 1.4 0.2 30 1 140 12 100 610 1.650 35 260 to to 120 210 179 I USEI000109 A. M. A. ARCHIVES OF INDUSTRIAL HEALTH St/tXrAXCK PPM* Methyl*! (dmtethoxymethane) ............... . 1000 Approx. Mr. oer CuM.t 3,100 SUIITANCE PPM' Phosphine ....................... Phophonu trichloride .. 0.05 0.5 Approx. Mr oer Cu.M t 0.07 3 Methyl chloroform Propyl reetate ............... 200 840 (1,1,1-trichiorotthane) 500 2.700 Propyl alcohol Methylcydoheaane ........ 500 000 (isopropyl alcohol) .. 400 W0 Methylcydohexanol ........ 100 470 Propyl ether Methylcydohexaaone ... 100 460 (isopropyl ether) ... 500 2,100 Methyl formate .............. 250 Propylene dichloride Methyl itobutyl carbinol (14-dichloropropane) 75 350 (methyl amyl alcohol) 25 10C Propylene inline ........ 25 60 Methylene chloride Pyridine ........................ 10 30 (dichloromethane) ___ 500 1450 Quinone ......................... 0.1 0, I .Naphtha (coal tar) .... Naphtha (petroleum) ... Nickel carbonyl .............. Nitric add....................... f-Nitroanilinc ................. Nitrobenzene ................... 200 500 0.001 10 1' l 800 ZsOOO o.a 25 6 -5 Stibine .......................... Stoddard solvent ........ Stymie monomer (phenylethylcne) ___ Sulfur dioxide ............. Sulfur hexafluoride ___ 0.1 500 100 5 1,000 0 900 420 13 6.000 Kitroethane ..................... 100 310 Sulfur monochloride___ 1 6 Nitrogen dioxide ............ 5 9 Sulfur pentafluoride ___ 0.025 03 Nitroglycerin........... 0.5 5 A-Teruarybotyltoluene .. 10 60 Nitremethane ................. 100 250 1,144-Tctrachloroethane 5 35 2-Nitropropane ............... 50 180 Tetrchydrofuran ........... 200 590 N itrotoluene ................... 5 30 Tetranitromethane .......... 1 8 Octane ............................ 500 2450 Toluene (toluol) .......... 200 750 Oxone .............................. 0.1 Pentane............................ 1,000 Pethanone (methyl propyl ketone) 200 Perchlomhylene (tetraehloroethylenc) . 200 Phenol ............................ 5 Phcnylhydraaine .............. 5 Phosgene (carbonyl chloride) .. 1 04 2.950 700 1450 19 22 4 o-Toluidine ..................... 5 22 Trichlotoethylcne ........... 200 1.050 Triduoronicootimmo- methane ...................... 1,000 6,100 Turpentine ...................... 100 560 Vinyl chloride 500 1400 200 870 * Pant sf vaaar r su per suUiars ram au Sr rslaim. t ApfnxaiN auUifraaia per cube attar at air. Toxic Dustt, Fumes, and Miata Mf per SuastAiect Cu. M4 Aldrin (144,4.10,10-htxachloro- 1,4,4aJ4,8a>hexahydro> 1,4,5,8- dimethanonaphthalfnc) .................... 045 Ammate (ammanitsn tulfamate) .... 15 Antimony ...................................... . 0.5 ANTU (alpha-naphthyl-thiourea) ... 0.3 Arsenic ........................................... 0.5 Barium (soluble compounds) ............ 0.5 'Cadmhxn oxide ftxnc ....................... 0.1 Calcium inmate ................................ 0.1 Chlorrfane (14.44A7A8- octaehloro-3a,444a-tctnhydro- 44m)cthanoindane) ...................... 2 Chlorinated eamphoic, 60%................. 05 Chlorinated diphenyl oxide................ 0.5 Chiorodiphenyl (42% chlorine) ......... 1 Qilorodrphenyl (54% chlorine) ......... 0.5 Mf. per SuasTAHCt Cu M t Crag herbicide (sodium 2-[2,4- dichlorophoioxy} ethanol hydrogen sulfite) ............................................. 15 Cyanide (as CN) ................................ 5 2,4-D(4-dichloropbenoxyicetic acid) 10 DDT (24-bis[p-ch)orophenyl]-l,l,l- trichloroethant) ................................ 1 Dieldrin (144.4,10,10-hcxachIoro- 6.7-epoxy-1.4,4a4,6,74,8a-octahydro- 1,44.8-dimethmo-naphthalene) ........ 045 Dinitrebpuene ...................................... 1 Dinitrotoluere ....................................... 1.5 Dinitro-o-ertsol ................................... 04 EPN (O-ethyl O-p-nitrophcnyl thionobensenephosphonate) ............. 0.5 Ferbsm (ferric dimethyl j Qiromic add and chromataa (as CrOa) 0.1 dithiocarlamate) .............................. 15 180 Vol. It. A*g.. Nit USEI000110 THRESHOLD UMIT VALVES FOR KSt 0 Substance PPM Me. oer Cu.M.1 Ferrovanadiutn dust ............................. 1 Fluoride ................................................ IS Hydroquinonc ..................................... 2 Iron oxide fume ................................ 15 Lead ..................................................... 02 Lead arsenate ..................................... 0.15 Lindane (hexachkrocydahcxane, gamma isomer) ................................ 02 Macncsium oxide fume....................... 15 Malathian (O,O-dimethyl dithiophos- phate of diethyl mereaptotuceinaie) 15 Manganese .......................................... 6 Mercury .............................................. 0.1 Mercury (organic compounds) ........... 0.01 Methoxychlor (22^K-P-methoxy* phenyl-1,1,1-lrichloroethane) ......... 15 Molybdentxn (soluble compounds) ....................... 5 (insoluble eompoutids) ................... 15 Nicotine ............................................. 0.5 Parsthion (O,O-diethyl O-p- nitrophenyl thiophosphate) ............ 0.1 Pcmachloronaphthalenr ..................... 0.5 PenucMorophenol .............................. 0.5 Phosphorus (yellow) ..... .................. 0.1 Phosphorus penuchloride .................. 1 Phosphorus pentasulfide..................... 1 Picric arid ........................................ 0.1 Pyrethrum ......................................... 2 Rotenone............................................. 5 Selenium compounds (as Se)............. 0.1 Soditan fluoroacetate (1080) ............. 0.1 Sodium hydroxide .............................. 2 SuasTAircr PPM * Me per Cu. m. : Strychnine ............................................. 0.15 Sulfuric acid ........................................ 1 TEDP (tetraethyl dithionopyrophosphate) ................... 02 TEPP (tetraethyl pyrophosphate) .. 0.05 Tellurium ............................................... 01 Tctryl (2.4,6-trinitropiienyl- molhyinitramine) .............................. 1.5 Thiram (tetramethyl thiuram disulfide) ........................................... 5 Thallium (soluble compounds) ........ 0.1 Titanium dioxide.................................. 15 Trichloronaphthalcne ........................... 5 Trinitrotoluene ...................................... 1.5 Uranium (soluble compounds) ..................... 0.05 (insoluble compounds) ..................... 025 Vanadium (ViOsdust) ....................................... 0.5 (V0 fume) .................................... 0.1 Warfarin (3*| acetonylbenzyl)-4- hydroxycoumarin) ............................ 0.5 Zinc oxide fumes.................................. 15 Zirconium compounds (as Zr) .......... 5 Badieaniatty: Far aanuiaaibk eancemranani at radio, iaatapet in air. aaa "Maxima Permiiaiblt Araagnu of Kafanwan m tSa Hunun lady and Maximum Permit, aikia Canaannauan m Air and Water." Handbook s:. V. 5. Department af Cananarca. Xettenal Bureau of Standards, dull, 1053. la addition, are "Permiitiblf Data fra External ianrcti at lanmne JUdiauon." Hand, beak St, V. S. Disannul! af Caatirra, National Bureau ad leandarda. Sea. Id. Its*. Kaniiaa ad tSo me paMitatimi aneiaeiad adore it in paaeraaa. 1 Mliberam# ad dual, fwmt, er auit par cubic atatar af air. Mineral Oust* Substance MPPCFf Aluminum oxide ................................. SO ^'Asbestos ................................................ 5 Dust (nuisance, no free silics) .... 50 Mica (below 5% free silkx)......... 20 Portland cement ................................. 50 Talc ....................................................... 20 SUBSTANCE MPPCF { Silica hifh (above 5O0t free SiOe) ... 5 medium (5 to 50* fret SiOi) .. 20 low (below 5* free SiOe) ___ 50 Silicon carbide ................................ 50 Soapstone (below 5* free SiOt) .. I Millians ad partklaa par cubic fa af air. 20 Substance (x) Acetylene tetrsbromide .............. (x) Allyl flyeidyl ether (AGE) .............. (x) Beryllium ............... (x) Boron trifluoride .. (x) n-Butyl flyddyl ether (BGE) .. TENTATIVE VALUES PPM I 1 10 1 50 Approx. Mr per Cu. M.f 14 45 2y/m* 3 270 SuaSTAMCX PPM 11 (x) Butyl mercaptan .. Chlorine dioxide .. (x) Chkroacttaldehyde (x) Qlorobromomethane (QBrCHi) .... (x) Diplyddyl ether (dge) .......... 10 0.1 1 400 10 Approx. Me. per Cu. M.S 35 0.3 3 2.100, 55 IS USEI000111 A. it. A. ARCHIVES OF INDUSTRIAL HEALTH Sumtamcx ppm n (x) Dimethyl forraamide 1,1-Dimethyl hydraaine ........ (x) Dipropyknefiy. cofanethylcthcr .. (x) Ethyl mercapan .. (x) Furfuryl alcohol .. (x) Glyddol ............... tec-Hexyl acetate (x) Itopropyl glyddyl ether (IGE) ... (x) Lithium hydride .. (x) Methyl mercaptan (x) e Methyl ttyrene .. (x) Monomethyl aniline (x) Paradichloro- benzene ............ (x) Perchloromethyl mercapun ........ (x) Phenyl flyodvl ether (PGE) ............ 20 as too 250 50 50 100 50 50 100 2 75 ai so Approx. MX P> Co. M.f 60 1 too 640 200 150 590 240 2Sy/ 100 480 9 4S0 0.8 310 SraiTAxa PPM [ Phoephorie Kid ... Propyl nitrate .. US (x) Propyim oxide .. 100 (x) Tertiary butyl alcohol ............. 100 (x) Tolylene-2,4diitocyanate .... 0.1 1^3-Trichloropropane.. 50 (x) Triethyl amine -- Triorthocmyl pbo^ltttc ....... 25 (x) Vinyl toluene .. .. 100 (x) Yttrium and inorfxnic compounds (x) Xyhdine ............... 5 (x) Ttrion decomposition product* ........... * (x) Ptntaborane (BMt) * 300 0.7 303 100 I Pm f n*r r | r*t tollin' tens to ur by toum. I MmMii millierin. art cubic mttrr to ur. (a)Tk*M Tthm tpeurto m tto Mftutm Um <r Until mn tiu ir farttouaunc. it a wtoOMB Its.. Uu it nptoni wactatfuina to ttow warnl. t* which worker. m expand nr t* ton u am 0 u patobtf. WmiAN L. Ball \V. Claxx Coora H. E. Stoxixoxx Kutm H. jACoatoN Hrxvtv B. Elxih* W. H. Rcixmaxt Allak L. Colimax, Chairman % n V- c_, m USEI000112 f BeidWe ii.tr- to Mr* * ** Mor* iMleh Services Diractor of Industrial Hygiene Rood 1703, William Farm Place Pittsburgh oatc February 25, 1966 from Mr. E. L. Wilson auajtcT Amoclta On ona of our jobs, we hava a subcontractor using a produce eallad "Amoclta" manufactured by the Roberta Company of England. Thla material haa an aabaatoa baae and la aprayed on the atructural aurfaca under a high praaaure pump and cpray arrangement. Xt la alao my underatanding that thla material la mined In Afrlea. X eeek any advica that you can give me aa to the hatardr of thla produce, and precautionary meeaurec to be uaed. Xt la rumored that thla material baa a ailiea or aabaatoa baae and con tinued exposure without a respirator la hazardous. Tour.help would be appreelatad. Genl. Supervisor of Safety* Construction ELV:mm PS: This material being bandied by the Armstrong Cork Company on a franchise. USEI000113 ,Kr. I. X*. Wilton ' Central Supervisor of Safety March I, IMS Kenneth ICjMtH, Director Induetridx Tffglma* Amoclte Thia la to aefaxowledge your an of February 25 relative to the eubject compound. Aabeatoa haa long been reeognised aa a Material whieh, if inhaled over a long enough period of tine and in aignifleantly heavy concentrationa in air, ean and haa produced aerioua pulmonary diaability. The aubject haa received renewed attention on the part of induatrial phyaiclane and lnduatrial hygieniata and an international conference waa held laat year in Vow Tork. The evaluation of the work conditiona under which the aubcontraetor la handling thia product ean beat be ascertained by obaerving the work conditiona and the eource of the aabeatoa. iowr .r, aa a general precaution in any apraying operation, je believe that the uae of a reapiratory device ahould .be a- minimum requirement. Therefore, until we have an opportunity to evaluate thia potential problem with more information and/or by obaerving the operation, we would auggeat that the aprayera involved be provided with reaplratora approvet by the DS8M for pneumoconioala*produeing duat. i\y*-. USEI000114 MOUNT SINAI SCHOOL OF MEDICINE of Tbt Ciy Unietrsity ofNtv> York PirTN AVINUI AMD 1MTM (TIIIT MIV TO*It. N.T. !* tkftrtmrmt if OmmmrityMtitcim July *3, 1970 Sr. Merle Bandy Medical Director, Industrial Medicine United States Steel Corporation 625 Willlas Penn Avenue Pittsburgh, Pennsylvania 16230 Sear Merle: I've been curious about the Increased lung cancer aortallty aaong your coke oven workaan, as deaoastrated by Lloyd. The question of.benzpyrene has, In our opinion, been Inadequately established, especially In vie* of our failure to find, at least so far, an increased lung cancer rate aaoag our roofing workers exposed to rather high concentrations of benzpyrene In the air about their work. I have a possible alternate explanation which could be looked at. in general, coking ovens are associated with a good deal of insulation. Insulation asbestos. Very often, too, the sen on the job either do their ovn repairs or are In the vicinity of repair ork if done by other trades. Scaetlaes the clean-up Is less than Meticulous with aueh asbestos allowed to rtmaln as waste. A hypothesis equally tenable, than, nighty that the Increased lung cancer is due to asbestos lnhalatlon^F Of course, all of this depends upon the actual Insulation conditions, of which 1 know very little. What are the facts? VIth wars regards. Sincerely yours. jk nuuA Irving JjSallkoff, M.D. Professor caaAjJm 'fcUv-- USEI0001I5 i*vrf .^* .*'t * /S*M r August 7. 1970 Irving J. Selikoff, M.D., Professor Department of Community Medicine Mount Sinai School of Medicine of Th City University of New York Fifth Avenue and 100th Street New York, New York 10029 Dear Irving: Thanks very much for your calling our attention to a potential explanation of our coke oven problem. My first inclination was to suggest that-there was no appreciable asbestos used. However, I find there is a fairly amount of asbestos rope that is used as piping around pipe as they emerge from the furnace and that there are asbestos gaskets that are used on some of the lids attached to these pipes. This obviously gives us another avenue to pursue, and I will keep you informed of our efforts to identify the agent responsible. I am bringing your letter to the attention of our Medical Com mittee and will ask that they likewise check in their companies. I appreciate very much your having brought this to our attention. With kind personal regards. Sines rely. MB/rp USEI000116 i.- \ H. J. . D!Atrro&-- r.<viftctt*.?SKTAi C3*rr*.?i *fP OPAJV $1"l .'1 I'ITTSMURSri. HINI.5YIVANSA IJJ.'O October 11, 1371 Professor Bernard B. Berber Chairman, Environmental fcaslity M*r.aoesct Cceumittee, 5P.X/, ftSCS Miroitor, Water Pesourcui*. research Certor University t-f Kcac!inserts iVnriorst. Massachuscitf C1002 Doer Ftiaie: I havg .xeac' the j*:*:jra';ed s.t. ter.ent. c* the Cor .to ..ter. on Environmental Reality jij-r-.paeed by H nrole Ke:r.cr, anci bov: only the ;r.ir.or ci.iri.eal chances ^ho./i) on pzra 1. inccruiy, Attachment boo: Mr. 3. H. Bong S Dr. Merle Bundy-' Mr. K. M. Morse USEI000117 WATER UESOukwCS kuseakch CENTER Office ef the Diroetor Graduate Research Center September 29, 1971 f RECEIVED UMiir. suns sms. r.tirr.iwrct. TO: memeers of the environmental quality management Harold Homer has prepared a draft of c statement on the use of a:bcs!os containing material for the Commit lee on Environmental Quality Manage ment. You will recoil (refer to minutes of meetings of January 27, 1970 and July \A, 1971) that the Committee decided to recommend a policy statement for ASCE adoption. Please examine the attached draft in that light and let me hove your comment: by November 1, 1971. At that time, Harold and I will rr.ehe such revisions as appear to be appropriate and the statement will be sub mitted Jo ASCE with the recommendation that it be published in the SED Journal BBB:edr Bernard B. Berger Chairman, Environmental Quality Management Committee, SED, ASCE Director, Water Resources Research Ccnfci P.S, Attached is a Corps of Engineers -- EPA publication on the "Refuse Ac! Permit Program", USEI000118 Engineering Evaluation of the use of Sprayed Asbestos-Containing K*.tr-i_-j_ By The Committee on Environmental Quality Management of the Sanitary Engineering Division ......... Draft by 11. Romer 9/14/71 The consumption of asbestos in the United States has assumed large proportions and its use in increasing at a rapid rate. The 15GC con sumption in the U.S. was equal to 25% of the total world production. Annual world production in 1930 was 500,000 tons; in 1967, four million tons of asbestos were produced. _______ ........................................ During the past 10 years, asbestos-containing material has been used extensively in sprayed form at an increasing rate, to protect steel structures from fire. In 1970, approximately three million . pounds of asbestos were used to fireproof structures. It is particularly with reference to this use of sprayed asbestos that this report is addressed. In the United States, almost 901 of the asbestos usee is cf the chrysotile fibre type that easily fragments into fibrils, 200 to 4 CO angstrom units in diameter anc often 2,CC0 angstrom units or smaller in length (200 angstrom units equals approximately a millionth of an inch). Thus, 10-9 grams of chysctile asbestos (one billionth oi a gram) could represent a million fibrils. Asbestos fibrils can only * be identified by use of the electron microscope in association with other sophisticated instrumentation. There are approximately one million fibrils lying side-by-side in a linear inch of chrysotile asbestos. / 70% of the asbestos in this country is used in the con struction industry. .- ire-- 7 From the published medical reports and epidemiological studies it would be fair to state that the individual, invisible asbestos (continu^c?' USEI000119 -2- fibril represents a built-in "time bomb" set eons age when the fibrous silicate crystals cooled and began to grow within the fractures of the serpentine rock. The mechanism can be activated when these fibrils are inhaled or ingested - albeit it may take 20-25 years to wreak its havoc in the form of excessive cancer incidence rates including the in variably fatal pleural and peritoneal mesotheliomas. Several statistical and medical references are noted: 1. The following material is abstracted from a 1269 tl.S. Public Health Service report, "Preliminary Air Pollution Survey of Asbestos - A Literature Review". r' - - a large fraction of the people, in the U.S. have been exposed to asbestos, including the following: a) approximately 100,000 workers using asbestos in their occupations. b) approximately 3,5000,000 construction workers expose:' indirectly to asbestos as they work with asbestos products or near those who handle asbestos products. c) approximately 50,000,000 Americans who possibly have "asbestos bodies" in their lungs. 2. In November, 1970, in a court case against the City ci` New York, Dr. Irving Selikoff was called upon to provide expert medical testimony. Dr. Sftlikoff is a renowned researcher and pioneer in the field of asbestos diseases; he is also Director of Environmental Science Laboratories at the Mt. Sinai School of Medicine in New York City. The following quotes are abstracted from his testimony: "In New York, in 3,000 consecutive autopsies at Elmhurst Hospital in Queens, the V.A. Hospital in the Bronx, and Mt. Sinai Hospital in Manhattan, examination of --- lung tissues has shown that asbestos bodies exist in 45?. of all (continued) USEI000120 3 cases. Smaller particles of asbestos, seen only by electron microscopy, were found to be commonly present in almost all eases examined. It now'appears that virtually ail New Yoikerr.1 lungs contain asbestos." "Among asbestos workers, for example, the incidence of ds-ath from lung cancer among smokers is about 20 tines as high as for non-smokers. If a person is both an asbestos worker and a cigaretv.e smoker, his chance of dying from lung cancer is 92 times the chence__ of a nan who neither smokes cigarettes nor wor^ with asbestos.'1 "Recently, I conducted an investigation with respect to asbestos- related conditions among the members of Local 12 (New York City) and Local 32 (Newark) of the International Association of Heat & i'rcst. Insulators ar.d Asbestos Workers, one of the building trade unions." "As of April 30, 1970, >03 of the original 632 union members in c/ our study were dead, 72^1ung cancer. Currently deaths among members of Local 12 in New York include one in 5 of lung cancer, one in M' of mesothelioma, one in 10 of asbestosis, and one in 10 of gastro intestinal cancer." "Asbestos-related cancers occur not only in occupationally exposed workmen, but may occur among people living or working in an area where asbestos fibers arc disseminated. Mesothelioma, for example, which is invariably fatal, has occurred among people living in the contaminated households of asbestos workers as well as among people living within a half-mile of major asbestos sources, such as asbestos factories, mines and mills. Investigations by Wagner ir. South Africa, Newhouse in London, Leiben in Pennsylvania, Bohlig in Germany, ar.d others, reveal a substantial health hazard to such persons. In London, an examination of records in one hospital revealed that of 76 recorded meoothelima ucEI00012l (continued) cases, 31 had worked in an asbestos factory, 9 of the remaining *> had lived in the household of an asbestos worker, and 11 simply lived within a half-mile of an asbestos plant. My group at Mt. Sinai has investigated the homes of asbestos workers and has found the air there contaminated by asbestos particles carried home on the clothing of the workers. We have also seen cases of mesothelioma among relatives of asbestos workers and people who lived near an asbestos-using facility". "In Manhattan ambient levels far removed from construction sites arc nnv? 20-60x10 ' grams per cubic meter of air, up to 6 times more than in, say, Staten Island, or Ridgewood, N.J. Indeed, ambient air levels about construction sites are even several tisnes higher than these`background levels. At these levels the average person might inhale 10 to 15 million asbestos fibrils in one 2' hour day." "In Hew York City, the construction industry is a major source, of airborne asbestos particles. Three-quarters of all asbestos used, is used in the construction industry". At the request of the Commissioner of Air Resources, the Health Research Council of the N.V.C. Department of Health studied the hazards of the sprayed asbestos problem in November, 1969 one reported: "Experience in industry clearly indicates that inhalation of asbestos may cause serious disease, and that some asbestos related diseas^ may be found after exposure to relatively low levels of asbestos. This committee,therefore, recommends that steps be taken immediately to eliminate contamination of the community by asbestos." (continued) USEI000122 5 The April 1, 1971 issue of the New York Times reported that Federal EPA began publishing a list of air pollutants, which in the opinion of Administrator William D. Ruckelshaus "may cause, or contribute to, an increase in mortality or an increase in sciious irreversible, or incapacitating reversible illness." Mr. Ruckelshaus "named three such pollutants - asbestos, beryllium and mercury." It is because of the relative indestructibility of the asbestos fibril, and its inherent potential for harm, as well as the unsatis factory experience of many cities in their efforts to control asbestos spraying operations, that the Cities of New York, Phila delphia and Chicago in 1970 and 1971, urged the banning of ths spraying of any substance containing asbestos in or upon a building or other structure during its construction, alteration or repair. H O7. C Because of the recognition of the intense health.of asbestos A exposure, and the amount of construction using sprayed asbestos in densely populated areas, a number of cities set op interim regulations prescribing containment and clean-up methodologies. Efforts at controlling the emission of asbestos from spray operations were not successful. On numerous occasions, emissions were such that heavy asbestos "snowfalls" were observed and accumulations of asbestos as deep as 3 inches at curbs and at other vertical rises occurred within a radius of several blocks of the spraying site. Since there are 25 to 40 skyscraper asbestos insulationspray operations in progress at any one time in New York City, for example, it would take virtually the entire field staff of The Department of Resources to provide adequate surveillance for this one function. (continued) USEI000123 fe Even if this were feasible/ the ability of the industry to prevent the emission of asbestos into the outside air under actual, dfy-to day conditions of construction is strongly questioned. Court actions, resulting from the issuing of many summonses, bad but limited deterrent value; adjournments were endless and the fines, when finally imposed, were only a minor overhead to the con tractors. The interim enclosure and clean-up regulations were intended to provide a workable methodology which could be implemented immediately by the construction industry. To provide for a method ology which would assure, positive containment of this carcinogenic: material, would have resulted in the complete cessation of construe.: on on all high rise buildings. However, experience clearly indicated that, with the present en closure methodology, even with conscientious follow-through by the contractor, asbestos dust, in lesser or greater quantities, was found in almost any part of the building under construction, l'n industry, where asbestos products are manufactured, "clean-room" procedures often are employed, including an exhaust system and filter baghousc. placed directly above or below such processes as cutting operations to preclude the likelihood of asbestos duct reaching the face of the worker or entering the workroom or outside air. This positive type of control is required when handling asbestos, if confidence in the methodology and protection of the public and worker are to be assured. Visible emissions, prohibited by coaeSjare difficult to observe, especially when spraying occurs on the upper floors of skyscrapers, (continued) USEI000124 7 unless there is a veritable snowstorm of asbestos into the outside eir. Perhaps more important than the visible emissions, however, are the fine asbestos particles which are not visible to the nuked eye, but which axe more hazardous because they can penetrate the lungs' smallest alveoli. Again, note that a billionth of a gram of chrysotile asbestos may contain a million fibrils of asbestos. Sampling for such particulates is not only extremely difficult at upper stories, but also time-consuming and expensive. By tne time laboratory results v.*culd become available, the spraying pro cedure of the specific area sampled would be long completed. Demolition: Even if a me.thodology were developed which could protect the ambient air from sprayed-asbestos particulates, a problem, for which no solutions are currently known, would dictate the banning of sprayed asbestos. The problem of demolition dust is being re ferred to. It is difficult to visualize the demolition of a mag nificent 30, <0 or 50 story structure. Nevertheless, based upon the construction and demolition history of buildings in cities such as New York, it should be anticipated that a significant per centage of these "old fashioned" structures will be demolished 30, 40 or 50 years hence. The present state of the art is such that there is reasonable assurance that our cities will be coated with asbestos when these buildings are demolished.* Whereas, it is hoped that ways and means to cope wit)i demolition dust problenf will be developed, there is no certainty of success, particularly because of the inherent diffi culties and high costs. (continued) USEI000125 -8Hazard to Workers; Last, and certainly not least, is the extreme hazard to worJ-ers employed in spraying asbestos. The tremendously high incidence of lung cancer, the 1002 fatal mesotheliomas and other carcinogenic cause4 of death experienced by asbestos-insulation workers cry out against the use of sprayed-asbestes. With the knowledge that it was, at best, a most difficult task adequately to supervise all construction sites using sprayed asbestos insulation; with the problem of multiple adjournments and meaningless fines in court; and with the preponderance of medical evidence as to the pathogenicity of asbestos, a campaign v.*as under taken to encourage manufacturers to eliminate asbestos and develop suitable substitute fireproof materials. As a result, there aro now several satisfactory substitute materials on the market at v. competitive price. Because of the known hazards of sprayed asbestos and with the availability of adequate substitute materials, the cities of Haw York, Philadelphia and Chicago have banned the spraying of asbestoscontaining materials. The ASCE has great concern not only with sprayed asbestos but also with all sprayed insulating materials^--because of potential, though unknown, hazards to health,. provisions which regulate such applications should be promulgated. The same problems of emissions into the open air experienced with sprayed asbestos-containing insulation are being and, doultlessly, will continue to be experienced with non-aJsbestos sprays, as long as the present methodology of temporary enclosure is practiced. (continued) USEI000126 The uses of tarpaulins for enclosure is not satisfactory on a continuing basis. Several alternatives arc proposed; 1. Fireproofing of peripheral columns, spandrels, -etc., by non-spray means, such as boxed beam with lathe and plaster, drywall en casement, concrete encasement, etc. Spraying of peripheral steel is a major source of visible emissions into outer air. 2. Design structure so that skin and windows can be installed be fore any spraying is done. 3. In any insulation spraying operation, install exhaust system and baghouse to ameliorate the astonishingly bad conditions under which sprayworkers now operate and to reduce emission.'; outside the building. Many architects, engineers and builders agree that there are virtually insurmountable problems associated with insulation spraying. There arc many available alternatives to spraying, howevei, each is more costly than spraying. Reported costs for the various alternatives differ widely. Some average figures indicate that for high rise structures the cost of spray insulation is 3/4 of 1% 1% of the total cost. V?hat does " total cost" mean? Some mean "bricks and mortar"; others include bricks and mortar, foundation, land costs, architectural fees, financing charges, profit, etc. Costs for drywall encasement vary from 2-3% of"total cost"; boxed beam with lathe and plaster from 2-3t of "total cost", concrete encasement as high as 5%. (continued) USEI000127 10 If one of the less costly, approved alternatives were sale::toe1, the increase in cost would be in the area of 3 3/4i. Ko one vvj.'.s to spend inore than he is required, however, this additional cost does not appear prohibitive and, above, all, will protect both public and worker. Product manufacturers are developing competitive non-asbestos insulating materials and methodologies. Among these are application of insulation at the steel fabrication mill; insulation in rolls and strips which can be applied to the steel with adhesives; appli cation by trowelling; intumescent mastics; insualtion Manbotewrapped around steel members cn the site, etc. "With all the current emphasis on the systems approach, it if. curious that a practical factory assembled enclosure has not yet been developed for the fire protection of steel beams. In addition to obtaining the usual advantages of factory production, tin- rrobu--. of air pollution would be avoided. The prefabricated units could consist of two sides and a bottom that enclose the beam and arc attached to the floor slab by stud welds or powder-actuated fester.ovs, or the units could be hung from studs welded tc: the. bottom flr-ngc while the sides are braced by studs welded to the web." (Ira Kcsj-.v-r, Modern Steel Construction, 1971). A Final Item of Importance: State and federal labor departments have set up the working atmosphere dust standard of not more than 5 fibers per c.c., 5 microns or larger. What does this mean in view of recent experience? A recent study by the NYC Department of Air Resources produced air analyses yielding no fibers 5 microns or larger; all particulates (asbestos fibrils) were submicron, fa?-,,!:-) (continued' USEI000128 11 The concentration of the submicron fibrils was approximately 200 per c.c. This is 40 times greater than the industrial standard for fibers. By definition, the air met industrial quality standards since there were no fibers 5 microns or larger. Normally, industrial air analyses do not include examination for submicron particulates. A sample of air having a zero count of fibers, 5 microns or larger, would be considered excellent. Obviously, the standard must be re-examined, especially since the submicron parti culates are highly respirable and present a greater hazard to health. CONCLUSION: It is obvious that each of us and our families have, n major stake in this natter. With the cooperation of each individual concerned, with the cooperation of industry and govcrnm.vnt, rational and meaningful solutions can be attained v'ithcrt undue hardship to any quarter and with better health to all. ft (continued) USEI000129 SUMMARY OF SECOND ADMINISTRATIVE MEDICAL MEETING. CENTRAL OPERATIONS - STEEL Pittsburgh. Pa. December 3 and 4, 1957 On December 3 and 4, 1957. there was held in Pittsburgh the second of a series of semiannual meetings of the doctors responsible for administration of the medical departments of Central Operations-*Steel. Appendix I lists the par ticipants. Appendix II is the program. Fif st, Dr. O'Connor outlined the format of the two days' sessions, emphasizing that the entire first day was to be devoted to furnishing the doctors a broad orientation to the Corporation as a whole. Next, Mr. John A Stephens offered a brief word of greeting. He stated the intentions of the company to develop a oneness within the Corporation, to im prove the integration of the various segments and functions, to improve communi cations, and to keep our management people, including the doctors, abreast of developments in the Corporation. He stressed the importance of the doctor in com pany relations, and again emphasized that it was the responsibility of each of us to make our contribution to the general objectives of the Corporation. Then Mr. E. C. Myers described the "Search for a Better Way, " the Task Force studies, and the conclusions and recommendations tha| had reached by the Task Force on Personnel Practices. 1 ^ *'*''* Two and one-half years ago Mr. Hood instituted the "Search for a Better Way" to improve human relations within the company. A Creed of Human Relations was suggested and adopted to help management to do a better job in this area. Twenty-five thousand questionnaires were distributed to USS management, and the replies were sent directly from each individual to Western Reserve for compilation and analysis. A significant minority expressed certain dissatisfactions. To pursue this further, the Operations Policy Committee appointed four Task Forces, each to study one of the four major subjects of Compensation, Working Conditions, Com munications, and Personnel Practices. Such study included visits ol the Task Forces to all Divisions and Subsidiaries, as well as Central Operations. The Task Force on Personnel Practices was composed of George Nations, Jim Collins, and Ed Myers, with George Thursby as chairman and representative on the Coordinating Committee. Ait of their study has come a series of pamphlets proposing a coordinated plan for management personnel practices within the Corpo ration. The plan-begins with a forecasting of management manpower needs for three-year periods, taking into consideration needs for management replacements due to turnover and ocher causes. Sources for meeting such needs are promotions of present employees, colleges, employment agencies, and the like, but with specific emphasis placed on promotions from within the company. USEI000130 methods uasLto distill requests down to appropriate levels. He presented a chart of capacity and production from the inception of the company in 1901, and a chart that showed toad steel capacity, that of our competitors and that of U. S. Steel for the same perisd, indicating that our percentage of the total production of steel is considerably&ss now than in 1901. -3 pointed out that a major consideration in determining long-range expenditures was the number of years needed to recover the original investment. Other considerations were the effect on U. S. Steel's participation pattern, the likelihood of satisfying a local market deficiency, and the effect on future potential for expansion. Hen Dr. W. H. Turner presented a brief review of corporate giving and some ofits attendant problems. He first distinguished between those contri butions that are given directly by the Corporation (usually having some direct relation or benefit to the Corporation) and those that are given by the U. S. Steel Foundation Usually benefitting people'in general). He indicated that each of these representedapproximately 6 million dollars a year, or a total of 12 million. He described those contributions of the Foundation that had a bearing on medical and health matters. He-pointed out some of the many problems involved; e. g., how judge the significance of requests, how meet requests that totalled many times the amount available for giving, etc. He indicated that while the government allows corporate giving up to 5% of profits before taxes, U. S. Steel ran about lfi, whereas a number of ether large corporations ran about 2%, showing that U. S. Steel was not overlooking stockholder interest in its philanthropies. The meeting was adjourned at 5 P. M, and dinner was held at the Duquesne Club. At 9 A. M. Wednesday, December 4, the meeting reconvened. Mr. K. M. Morse presented "Environmental Health in the Steel Indus try - H, " covering the newer knowledge of the effect of industrial dusts on employees' lungs. He stressed the fact that free silica was no longer the only dust to be concerned about, but that any dust in sufficient amounts over sufficient time could impair lung function. Especially a combination of irritant gases, heat, and dust is cause for concern. He cited a recent case in which a very reputable chest consultant in Pittsburgh, who has in the past examined many cases at Com pany request, considered that the pulmonary fibrosis and emphysema he found in a soaking-pit crane operator was caused by the combination of dust, heat, and sulfur-dioadde fumes to which he had long been exposed. He described the old and new concepts of the term "pneumoconiosis, " and indicated that while silica and asbestos were considered the sole causes in the past, now talc and diatomaceous earth had been added, and Shaver's Disease from the fusion of artificial abrasives, and more recently coal miners' pneumo coniosis. USEI000131 IWTC*0*AMIXATIN C0*M*ONOCWCC UNITED STATES STEEL CORPORATION All Participants DATS moM SOSJtCT September 1, 1960 R. B. O'Connor, M. D. Medical Director Transactions, Sixth Semiannual Administrative Medical Meetine Enclosed is a copy of the Transactions of the Sixth Semiannual Administrative Medical Meeting held in Pittsburgh on June Zl and ZZ, 1960. There was so much clinical detail involved which appeared to be of special interest that I took rather copious notes. From them I compiled this summary) which you may want to review and keep in your files for reference. fit Orj@yuLor~~& i>. km enclosure Ors. R. N. Armen 1*. H. Botkin R. J. Bennett D. C. Braun C. B. Bryce Merle Bundy E. W. Caughey H. H. Clapper J. B. Clement H. E. DeWalt J. C. Donchess Drs. Mr. A.M. Edwards C. V. Foster Louis Hamman J. C. Hayes W. J. Helzlsoue W. J. Lace B. J. Larsen R. M. Maher C. P. Markle H. E. Mathay K. M. Morse Drs. J. H. .Murry. J. F. Novak J. C. Painter W. J. Ralston W. K. Riland R. W. Saul D. J. Smith J. T. Taylor Mr. W. W. Turner Drs. J. R. Weddell C. R. Zeiss ec: E. B. Robinson, M. D. F. J. Schaeffer C. T. Spivey AUG 1 2 1963 USEI000132 1 .'I 1 TRANSACTIONS OF THE U. S. STEEL ::.;SflSEMIANNUAL ADMINISTRATIVE MEDICAL MEETING !- L33KIiliAm Pena Place Building, Pitt*burgh, Penn*yivuni*. Jus* 21 and 22, I960 U. S. 9tKffixth Semiannual Administrative Medical Meeting wai convened at 9 a.m., lca&L Those in attendance are listed in Appendix A. The program is listed in AjgmtfhB. The entteftint morning was devoted to pulmonary disease. I. The ftMpeaker was E. P. Robin, M. D., Associate Professor of Medicine at the3fot?*ity of Pittsburgh. As an aside at the beginning, he mentioned that he would bf-ging a talk to UMWA doctors on the same subject, namely, Pulmonary Egaam-Tests in the following week. A. At fhtfBtset, Dr. Robin said there were four things that should be recognized as a backdropahzs talk:'. 1. AlShings being equal, the best pulmcnary function test still is a casifel clinical history, a thorough physical examination, and proper an*areully taken x*rays of the lung. 2. Cement pulmonary function tests almost never give data that is etiolqpcally precise, i.e.. they tell the degree of involvement but not the asm of it. 3. Du Robin emphasised that he was unfamiliar with our specific problems aaslhoped to learn from us. 4. Aspresently understood, pulmonary function is complex, thus current teas* are eamplex; there is no single adequate test, but rather subdfeaded. isolated functions are tested with different presently available B. Four seasons were given for doing pulmonary function tests: 1. Tfepick up subtle gradations of abnormality. For example, in asbestosis the patient may have considerable symptoms but there may be no abauirnal physical findings except in a pulmonary function test. 2. These tests are the only way to get specific figures representing objective measurements. USEI000133 I In reply to'lht question a* to whether the Timed Vital Capacity will pick up arly emphysema, he eaid there it an early stage which is not ordinarily detectable but will be pichnlup by this simple test. He stated that pulmonary function tests cannot distinguish focal emphysema from diffuse obstructive emphysema. A glossary olferms, abbreviations, definitions and normal values, supplied by Or. Robin, is ia Appendix C. **ee** II The second speaker was K. M. Morse, Director of Industrial Hygiene, U. S. Steel, and the title of his talk was "Measurement of Dusts." Mr. Morse said there are four major items of concern to the industrial hygienist and the physician regarding dust and its effects on the lungs: A. Chemical composition. In the past, one was concerned almost wholly with silica and asbestos. If these were not present, then the dust was considered merely a nuisance. Although free silica content is still important and silica is the most hazardous of the common industrial dusts, we now know that any dust regardless of silica content, in great enough quantities, can overload the defenses of the lungs and cause trouble. B. Particle size. We are concerned only with those tinder 5 microns. It is felt that maximum retention of dust in the lung occurs with particle size between 1.5 or 2 microns. C. Concentration. Maximum Allowable Concentrations (MAC) have been set up by the Conference on Governmental Industrial Hygienists for all the substances commonly met in industry. Some of these have been well substantiated, but some of them are mere guesses. For example, the MAC of 5 million particles per cubic meter of air for silica has been well validated, whereas a commonly accepted MAC of 50 million p&rticles for "nuisance" dusts is not at all well validated. In U. S. Steel, we are aim ing below this latter amount and are recommending 20 million as a maximum in any dusty situation. D. Duration of Exposure. In speaking of pulmonary dust diseases, one is speaking of conditions that take twelve to fifteen years to develop. Mr. Morse then discussed various techniques of measurement of dust and the instruments used: A, Sedimentation. This is now obsolete for in-plant studies, but is still used in some studies of community air pollution. Settled dust can be used for chemical analyses; however, it is apt not to be truly representative of the dust in the air. 5 USEI000134 h Two psychiatrists tried unsuccessfully to get rid of the fear reaction. A Workmen's Compensation Claim was filed. He said he was so disabled that he didn't even have the stamina to drive a taxi cab, a job which he had tried. Kis wife was working to support him and their three children. He was awarded compensation. Subsequently he was killed in an auto accident and at autopsy his lungs were proven to be perfectly normal except for iron retention which produces no disablement. Dr. Sander said that the best distinction on x-ray between a benign siderosis and an actual pulmonary fibrosis was that in siderosis the root shadows were within normal limits. Also the nodulation was fine, small and evenly distributed. Of course, sometimes one can have both, as in welders who work in a foundry cleaning room, exposed to both iron oxide fumes and to silica dust. To show the difference, x-rays of a case of silicosis were used to demonstrate the larger general silicotic nodulation with dense root shadows and increased root markings, compared to the siderosis, uniform fine nodulation and normal hilar shadows. These are sometimes combined in a grinder, although now most grinding wheels are Silicon Carbide or Aluminum Oxide. Earlier studies from Saranac sug gested that Silicon Carbide might make a person more susceptible to tuberculosis; Sander has doubted this, and Dr. Cross has shown overgrowth of fibrous tissue in animals dusted with Silicon Carbide but no increase in incidence of tuberculosis. Sander has successfully contested claims of this kind in Workmen's Compensation. With the grinding wheels presently in use, he indicated that grinders can develop pure iron retention, i.e., siderosis. He then showed x-rays of a case of tin oxide retention, which presented a brighter, harder appearing nodulation. Discussing 35 claims for "damaged lungs" in burners in ship yards, said to be due to smoke, iron oxide and soot from coal, he reviewed the question of the possible occupational origin of emphysema. While he is not prepared to say that emphysema is any higher in occupational exposures than in the general population, he has found it very difficult to contest a case in men exposed to irritants who develop emphysema. However, if there is well-developed emphysema in a man who has been a heavy smoker all his life, who has a heavy cough and recurrent upper respiratory infections, such a ease should be vigorously contested. Sander and many others felt that heavy smoking is a major cause of emphysema. As men grow older and smoke longer, developing chronic bronchitis and emphysema, those that also have dust exposure at work he feels will probably succeed in a compensation claim. He next showed x-rays of a case of asbestosis caused by installing asbestos bats around piping. This affects the alveolar walls more than silicosis, and in this case the man died of cor pulmonale 20 years after the last exposure to asbestos. He contrasted this with simple silicosis which does not produce such disablement because the alveolar walls are not to blocked with the fibrosis. 21 USEI000135 United State* Steel Corporation TRANSACTIONS Of The SEVENTH SEMIANNUAL ADMINISTRATIVE MEDICAL MEETING November 16-17, 1960 525 William Penn Place Pittsburgh 30, Pennsylvania USEI000136 - 10 - A high power view of the silica nodule showed the concentric structure, with an -cellular, hyaline center, and a cellular periphery indicating progression. . An ash pattern superimposed showed that there was considerable variation with distribution of silica, some in the center of the nodule, some in the periphery; most, however, was in the periphery, not the center. Emphysema was also noted around the nodule. Another slide demonstrated that if the silica is associated with other dusts, the nodule is modified. Instead of being round it is stellate with processes projecting out. This is a microscopic, not macroscopic, change. It is seen when silica is combined with silicates or coal dust and the like. Of the common forms of free crystalline silica, i.e., quartz, erystobalite and tridomite, pathogenicity occurs increasingly in that order, with tridomite the worst. Diatomaceous earth is a silica, but it is amor phous, not crystalline. It produces a cellular reaction with alveolar wall thickening and no collagen formation. In this it is like the quartz-iron combination. It may produce considerable alveolar distortion, but without scar formation. However, if the diatomaceous earth is calcined, some crystalline silica is formed and this then can produce large plaques with serious collagen formation. Asbestos produces a diffuse pulmonary fibrosis with some scarring. The thickening of the alveolar walls is especially noted at the bases of the lungs. There is often an associated severe obliterative fibrous pleuritis. The slide also showed the presence of "asbestos bodies, " elongated, straight or curved, club shaped structures. The severe fibrinous pleurisy, scarred alveolar walls and emphysema mean that an asbestosis usually dies of cor ptilmonale. A slide of talc pneumoconiosis showed thickened alveolar walls, in this instance with desquamation into the alveolar spaces and secondary infection. A study, conducted under Iron and Steel Institute auspices by Dr. Gross, has demonstrated the mobility of dust deposits in the lungs. The first slide showed a young silicotic nodule, a reaction to quartz dust, with no collagen as yet. A superimposed ashed specimen showed the silica throughout the nodule but the air spaces free of it. If ANTU is then given to produce pulmonary edema and pleural effusion, at the level of an LD 50 dose, the section then shows outpouring of edema fluid. When the ash pattern is superimposed, it shows that the dust has been mobilized out of the nodule and is now dispersed through the edema fluid. Reabsorption would then produce further damage and scarring, the progression of silicosis. (This phenomenon also explains why expectoration of coal or iron dust can occur for many years after cessation of exposure.) USEI000137 PROCEEDINGS FIBROUS DUST SEMINAR November 22,1968 * INDUSTRIAL HYGIENE FOUNDATION OF AMERICA 5231 CIN7HI AVENUE PITr3"?G- . USEI00.0138 f) PROCEEDINGS FIBROUS DUST SEMINAR November 22. 1968 Mellon Institute of Carnegie-Mellon University Pittsburgh, Pennsylvania Medical Series: Bulletin No. 16-70 Industrial Hygiene Foundation of America. Inc. 5231 Centre Avenue Pittsburgh. Pennsylvania 15232 Copyright 1970 Industrial Hygiene Foundation of America, Inc. USEI000139 PREFACE This Fibrous Dust Seminar represents an important step towards fulfillment of the first goal in which direction industry should be moving according to Dr. Theodore Hatch. IHF Trustee Emeritus, in Industrial Hygiene Highlights - Vol, 1 -- i. e. , protection of employee health. These proceedings exemplify industry's attempts with IHF's help to advance scientific progress by use of epidemiological and biostatistical studies, in plant as well as in the experimental research laboratory. Studies on fibrous gl*ss, which appears to have no demonstrable pathogenic effects, provide an effective control over those investigations on asbestos bioeffects reported herein, all of which have been performed in or for IHF. It can be seen that studies designed to investigate patho genic effect become highly sophisticated in an attempt to prove the "null hypothesis. " These studies of fibrous dusts are still under way and further progress will be reported as it developes in an effort to keep our members and the interested scientific and professional communities advised. The use of fibrous dusts is so widespread today that all those responsible for employee health should find this bulletin interesting and useful. Robert T. P. deTreville, M. D. , Sc. D. President m. USEI000140 PreJKEfi TABLE OF CONTENTS ............................................................................................. Robert T. P. deTreville, M. D. President Industrial Hygiene Foundation Page iii Welcome ................................................................................ 1 Robert T. P. deTreville, M. D. and G. A. Webb, Ph. D. , Chairman 1HF Board of Trustees Associate Director, Mellon Institute Carnegie-Mellon University Opening Remarks........................................................................................................ <2 W. Clark Cooper, M. D. Professor in Residence Occupational Health School of Public Health University of California (Berkeley) IHF Statistical Studies of Health of Fibrous Glass Workers ........................................................................................... H. Michael D. Utidjian. M. D. Assistant Professor Department of Epidemiology Graduate School of Public Health University of Pittsburgh 3 Records Studies of Health of Fibrous Glass Workers ............................................... :. . ................................. 16 Lewis J. Cralley, Ph. D. Scientist Director. Associate Chief Occ. Health Program, Field Studies U. S. Public Health Service A Comparison of the Effects in Experimental Animals of Certain Fibrous Dusts: Fibrous Glass--Asbestos (Natural and Synthetic).................... ZZ Paul Gross. M. D. . Director IHF Research Laboratory Physiological Studies of Health of Fibrous Glass Workers............................................... ........................................... Z6 Benjamin J. Lambiotte. M. D. IHF Resident Fellow in Occupational Medicine Radiological Studies of Health of Fibrous Glass Workers ............................................................................................. 33 Jon L. Konzen, M. D. Medical Director Owens - Corning Fiberglas Corporation IV. USEI000141 TABLE OF CONTENTS Moderator'* Summarization (Morning Session)............................................................................................................ W. Clark Cooper, M. D. 39 Opening Remarks ................................................................................. .......................... 41 Lewis J. Cralley, Ph. D. Asbestos Exposure in the U. S. Textile Industry--1930 to Date................................................................................. Joseph L. Goodman, M, D, Medical Director for Research Raybestos-Manhattan, Inc. 42 Statistical Studies of U. S. Asbestos Products Workers ......................................................................................................... Philip E. Enterline, Ph. D. Professor of Biostatistics Graduate School of Public Health University of Pittsburgh 52 Studies on the Pathogenicity of Brake Drum Dust........................ Paul Gross. M. D. 50 Pathological Studies of Ferruginous Bodies: Methodology ................................................................................................. H. Michael D. Utidjian, M. D. 53 Pathological Studies of Ferruginous Bodies: Instrumentation............................................................................................ Martin N. Haller Fellow, Mellon Institute Carnegie-Mellon University 56 Pathological Studies of Ferruginous Bodies: Bodies: Basic Considerations................................................ John M. G. Davis Department of Pathology University of Cambridge Discussion....................................... Paul Gross, M. D. 10 Concluding Remarks Robert T. P. deTreville, M. D. II *p Industrial Hygiene Foundation 4400 Fifth Avenue Pittsburgh. IS, PaonaylTania BE7EL0PMEHTS I* 1947 SESSIONS OF STATE LEGZSUTUBSS PEE?ABED FOE F0DHLATI0H MEMBERS Theodore C- Waters Chairman, La|al Comittee Industrial.Hygiene Foundation CONTENTS In T3Wc State Amendment. ass 1 Ion Statute............................. 2 Imda Statute.......................... 4 South Dakota Statute. .......................................... 5 Taoneaaee Statute.................................................. 7 Texas Statute......................... 8 Montana Comission.................................................. ....10 Vemont Commission...................................................................11 TV* May, 1947 USEI000143 k TFS&mi 1. Effective date of let - March 12, 1947. 2. Schedule of eompemsable diseases: (Sac Item 6 below) Load poisoning Metal fuse ftTcr Silicosis Benzol poisoning Dermatitis Miner1s disease, including only cellulitis, bursitis, nystaycus, ankylostomiasis, tenosynovitis Anthrax /sbesteels Chronic sangenese poisoning 3. Compensation is payable for partial disability, total disability or death resulting from occupational disease in the same manner as compensation is payable under the lorkaen* s Compensation lew for injury by accident. 4. Medical Board (No provision) 5. Limitations (a) in employee must give written notice to the employer within thirty (30) days after the first distinct manifestation of the disease (b) Suit must be commenced within one year after the beginning of incapacity for work resulting from an occupational disease, and if death results from the occupational disease, suit must be commenced within one year thereafter. 6. Election of employer By the provisions of Senate Bill No. 1088 (Chapter 197, Laws of 1947) an employer may elect general coverage for any and all occu pational diseases. -7- USEI000144 1. Effective date of the Act - The bill wee signed by the Governor on April 19, 1947 and becomes effective ninoty days after the adjournment of the Legislature (date of adjournment now not certain). 2. Schedule of compensable diseases: Poisoning by; Aluminum trioxide Arsenic Benzol or its homologues and derivatives Beryllium Cadmium Carbon bisulphide Carbon dioxide Carbon monoxide Chlorine Cyanide Formaldehyde Balogesrted hydrocarbons Hydrochloric acid Hydrofluoric acid Hydrogen sulphide Lead Manganese Mercury Methanol (wood alcohol) Methyl chloride Hitrous fumes Nitric acid Petroleum or petroleum product! Phosphorus Selenium Sulphuric acid Sulphur dioxide Sulphur trioxide Tellurium Thallium Zinc Anthrax caused by handling of wool, hair, bristles, hides and skins Blisters caused by prolonged or repeated use of tools or mechanical appliances Synovitis, tenosynovitis, or bursitis due to sn occupation involving continual or repeated pressure on the parts affected Chrome ulceration Compressed air illness Dermatitis, that is, inflammation of the skin due to oil, cutting compounds or lubricants, dust, liquids, fumes, gases or vapors --8-- USEI000145 9- TELLS (Coat'd) Diseased condition caused by exposure to x-rays or radioactive substances Diseased condition of the eyes due to electric ere and welding, and cataract ia glass workers Epitheliomatous cancer or ulceration of the skin or of the corneal surface of the eye caused by tar, pitch, bitumen, mineral oil or paraffin or any compound, product, or resi due of any of these substances Glanders and other diseased conditions caused by handling eny equine animal, or the carcass of any such animal Infectious or contagious disease contracted in the course of employment in or in immediate connection with a hospital or sanatorium in which persons or animals suffering from such disease err cared for or treated Nystagmus incurred in underground work Aabestoais Silicosis S. Special provisions for silicosis and asbestosis (a) Compensation is payable for partiel disability, total disability and death (b) Limitation of monetary liability If incapacity or death occurs within the first twelve months after the effective date of the Act, compensation limited to 20$ of the number of weeks of compensation otherwise payable for such incapacity or death; this amount is increased in each succeeding twelve months period by sn additional 20$ of the nunber of weeks of compensation otherwise payable for such incapacity or death until the amount attained equals the amount payable for incapacity in the game manner bad such incapacity or death been due to an injury other than an occupational disease. 4. Kedieal Board Upon motion by either party the Workmen1 s Compensation Board shall appoint a medical committee of three doctors who ahall examine the claimant and report to the Board its opinion s'egarding all medical questions in the case. The opinion of the medical committee is advisory to the Board. 5. Limitations: An employee shall giva notice to the employer thirty (SO) days after the first distinct manifestation of the disease and file claim within six months after the first distinct manifestation of the disease, or in case of death within six months after date of death. The Workmen's Compensation Board may, in meritorious cases, waive strict compliance with the foregoing limitations as to notice, and the filing of the claim before the Board. USEI000146 X 7"?7vvaj KZCXSPtS PRO! SS ggJSTRUL HTOIEHB COBBS OR SXSOULZ2DR3 flLlED APRIL, 1949 ____________ /^A^. w ; _.,/* . ^ ~ C ' V-K % Illumination (Motion 15) '> 1. (toeing tasks requiring contrast and where the discrimination of fin* detail under nature of the work is Tory exacting conditions of and prolonged fair shall d-0 JL~ be proTided with a minimum of 100 foot-oandles of illumination* 2. Similar seeing tasks under conditions of moderate oontrast should be proTided with a minliman of 50 foot-oandles of illumination* 'I V3. Seeing tasks requiring moderate discrimination of detail orer intermittent periods of time under conditions of normal oontrast should be provided with a minimum of 30 foot-oandles of illumination* !'J 4* Casual seeing tasks not involving discrimination of fine details should be pro vided with a minimum of 10 foot-osndles of illumination* Ventilation and Temperature Requirements (Section 16) 1* Outside air should be provided to all workrooms at the rate of 15 cubic feet per minute per person, or 1-1fz air changes per hour, whichever is greater* 2* Workers should not be subjected to air velooities exceeding 200 feet per minute* 3* In work rooms where strenuous work is performed, the minimum air temperature should be 60 P* 4* In all other workrooms, unless prohibited by process requirements, minimum air pressure should be 65 P. f j Sanitation (Section 20) 1* Every plaoe of wmployment shall be provided with adequate toilet facilities (inter closets)* conveniently located and separate for each aex according to the following! 1 to 9 employees 10 to 24 " 25 to 49 " 60 to 74 75 to 100 " Over 100 1 facility 2 facilities 3 facilities 4 facilities 5 facilities 1 additional facility for each additional 30 employees * Where the installation of a weter-oarriage sewerage systsa may be impracticable, the authority may designate another type of toilet facility approved by the publlo health agency having jurisdiction* USEI000147 (Urinal# instead of water closets for sale employees say bo substituted in a ratio of not noro than one-third urinals in the above minimus facility schedule). 2* Every place of employment shall bo provided with adequate washing facilities in the ratio of one lavatory (or equivalent Hash plaoe) for eaoh 10 employees up to 100 persons and one lavatory (wash plaoe) for eaoh additional 15 persons* Eaoh lavatory (wash plaoe) shall be provided with soap and hot and oold running water* 3* A minimum of one shower bath with ample supply of hot and oold water from one fixture shall be provided for every 15 employees or fraotion thereof exposed to excessive heat* or to skin eontamlnation with poisonous* infectious, or irritating material* Service Facilities (Seotlon 21) 1* There 10 or more women are oaployed at any one time* at least one retiring room for their exolusive use shall be provided. 2. TShere less than 10 women are employed and a retiring room is not furnished, some equivalent spaoe shall be provided which can be properly screened and made suit able for the use of mnen employees* . 3* The minimum space provided for a retiring room for 10 women shall be 60 square feet* . .The minimum increased space for more shall be at least 2 square feet for each additional woman employed* 4* At least one couch or bed shall be provided in every place where more than 10 women are amployod* The number of such beds or couches required shall be as followst 10 to 100 women* one bed; 100 to 250 women* two beds; and one addi tional bed for each additional 250 women employed* Values Recommended by the Committee on Threshold Limits at Eleventh Annual Meeting of the Amerioan Conference of Governmental Industrial Hygienists* April 1950. OASES ASP VAPORS SUBSTANCE P.P.1L SUBSTANCE P.P.M.. Acetaldehyde Acetic Acid Acetic anhydride Aoatone Acrolein Acrylonitrile Aaoonia Amyl acetate Iso amyl alcohol Aniline Arsine 200 10 5 500 0.5 20 100 200 100 5 0.05 Benzene (benzol) Bromine 1* 3-Butadiene n-Butanol 2-Butanone n-Butyl acetate Butyl cello solve Carbon dioxide ' Carbon disulfide Carbon monoxide Carbon tetrachloride 35 1 1000 100 250 200 200 5000 20 100 50 USEI000148 r SUBSTANCE Callow lye Callosolv# acetate Chlorine Chlorobenzene 2-Chlorobutadiana Chloroform 1-Chloro-l-nitropropene Cyclohexane Cyclohexanol Cyclohexanone Cyolohexena Cyclopropane (propane) o-Di chlorobenzene Diohloro dif1 uoromethane 2l-Dichloroethane 12-Dichloto ethane (ethylene dichloride) 1*2-Dichloroethylena Edchloroethyl ether Diehl ore methane . Dichi o romonofluoromethane 1 /1-Di chlo ro-1-nitroethane l*2-Dichloropropana (propylene diohloride) Di chloro tetrefluoro ethane Dimethylaniline Dimethylsulfate Dioxane Ethyl acetate Ethyl alcohol Ethyl benzene Ethyl bromide Ethyl chloride Ethylene chlorohydrin Ethylene oxide Ethyl ether Ethyl formate Ethyl eilioate FI uo ro tri chi oromethane Formaldehyde Gasoline Heptane Hexane Hydrogen chloride Hydrogen cyanide Hydrogen fluoride Hy'trogen selenide Hydrogen sulfide Ic dine Isophrene *3 F.P.M. SUBSTANCE 200 100 1 75 25 100 20 400 100 100 400 400 50 1000 100 - 75 200 15 500 1000 10 75 1000 5 1 100 400 1000 200 200 1000 5 100 400 100 100 1000 5 500 500 500 5 10 3 0.05 20 1 25 Mesityl oxide Methanol Methyl acetate Methyl bromide Methyl butanone Methyl oellosolre Methyl cellosolve aoetate Methyl chloride Me thyl cyclohexane Methy1 oyol ohexano 1 Methyl cyclohexanone Methyl formate Methyl iso-butyl ketone Naphtha (ooal tar) Naphtha (petrol#via) Nickel carbonyl Nitrobenzene Hitroethane Nitrogen oxides (other than Nitroglycerin N2.O Nitromethane 2-Nitropropane Nitrotoluene Ootane Ozone Pentane Pentanone (methyl propaaone) Rio sgene Rio sphine Phosphorus trichloride Isopropyl aloohol Propyl aoetate Isopropyl ether Stibiae Stoddard solvent Styrene monomer Sulfur chloride Sulfur dioxide 1>12.2-Tetrachloroethane Te trachlo ro ethylene Ibluene Toluidine Trichloroethylene Turpentine Vinyl chloride Xylene P.P.M, 50 200 . 200 20 100 25 25 100 600 100 100 100 100 200 600 1 1 100 25 0.5 100 60 5 600 1 1000 200 1 0.05 0.5 400 200 500 0.1 500 200 1 10 5 100 200 5 100 100 500 200 USEI000149 r -4- ronODUaMiratBSAHDUMS . SUBSTANCE Antimony Arsanio Barium Cadalum (hlorodiphenyl Chromic add-and chromates. as' Cr03 i:; Cyanide as CH Dinitro toluene o-Dinitrocrosol Fluoride Iron oxide fume Lead Magnesium oxide fume Mg. per Cu.'M. SUBSTANCE 0.5 O.S 0.6 0.1 1 0.1 6 1.6 . 0.2 . 2.5 15 0,15 15 Manganese Mercury Pentaohlo ronaphthal sns Psntachlorophsnol Phosphorus (yellow) Phosphorus pentachlorlde Phosphorus pentasulfide Selenium, as Se Sulfur!o aoid Tellurian Tetryl Trichloronaphthal ene Trinitrotoluene Zinc oxide fuse Mg. per Cu. M. 6 0.1 0,5 0.5 0.1 1 1 0.1 1.0 0.1 1.5 5 1.5 15 MINERAL DUSTS SUBSTANCE M..P.P.C.T. Alundum Asbestos Carborundum Dust (nuisance, no free silica) Mica (below 6# free silica) Portland oeoemt 50 5 60 50 50 50 SUBSTANCE M.P.P.C.F. Ihlc Silica high (above SO# free Si02) median. (5 to SO#free Sioc,) low (below 5# free SiOg) Slate (below 6# free SiOg) Soapstone (below 5# free SiOg) Tbtal dust (below 5# free SiOg) 20 5 20 60 60 20 50 MATERIAL OH RADIATION RADIATIONS MATERIAL OH RADIATION Gaaaa (roentgens par week) 0.5 Radon (curias par cubic metar) 10~8 3horon (curies par oubio meter) 10"8 Roentgen ray (roentgens per week) 0.3 Safety Committee United States Steel Company Research and Development Laboratory U S E I000150 July 2, 1952 om<iA*<iArif>+ COmmtfOmOl *C t American Dkiimie 0 * .a, --........... &...... T R. D. Northcutt G. H. Moore W. B. Hunter, Jr. G. R. Robbins H. A. Rankin, Jr. K. C. Morford J. C. Magncas V. E. Harris V. 0. Mitchell C. T. Osborne OATC r*OM November 9, 1967 J. L. Beckner, _ f) suajecT Management Guide for Contractors' Safety Resoonaibilitles We attach harato ooa copy of the abova corporation booklet which ia to aerve aa a management guide concerning independent contractora that may be performing work in our planta. Pleaae contact your area lew department or thia office if you have any queetiona whatever concerning requirementa aet forth in thia booklet. Enclosure cc: Leon Beekman 8. A. Halliday '''Plant Safety Supervisors r-- --~ USEI000151 a UNITED STATES STEEL CORPORATION I v. * %-'^.r '*'* sc' : ` -i*' -r?. ` i A JSEI00G152 MANAGEMENT GUIDE FOR CONTRACTORS' SAFETY RESPONSIBILITIES UNDER CONSTRUCTION CONTRACT ctwnuL opeiuTiotts. mm. VWTSO STATOS STBSV eOftPOOATTOM SECTION I - RESPONSIBILITY FOR SAFETY OF PERSONS AND PROPERTY The fallowing is Artiela 16 of eh* Con*ernecion Contract. Zt 1* the baala upon which the contractor'a responsibility for aafeey la predicated. "The safety of all persona employed by contractor and his subcontrac tors on owner's premises, or any other person who enters upon owner's premises for reasons relating to this contract, shall be the sole responsibility of contractor. Contractor shall maintain at all times good order among his em ployees and shall not employ on the work any unfit person or anyone not skilled in the work assigned to him. Contractor shall confine his employee* and all ocher persons who come onto owner's premises at contractor's request or for reasons relating to this contract and his equipment to chat portion of owner's premises where the work under his contract la to be performed or to roads lead ing to and from such work sites and to any ocher area which owner may permit contractor to use. "Contractor shall eake all reasonable measures and pracautiona at all elmss to prevent injuries to or che death of any of his employees or any other person who enters upon owner's premises. Such measures and precautions shall include, but shall noe be limited eo, all safeguards and warnings neces sary to protact workmen and others against any conditions on owner's premises which could ba dangerous and to prevent accidents of any kind whenever work is being performed in proximity to any moving or operating machinery, equipment, or facilities, whether such machinery, equipment, or facilities are che property of or are being operated by, che contractor, his subcontractors, che owner, or ocher persons. "It is understood that if employees of owner shall perform any acta for che purpose of discharging che responsibility undertaken by che contractor in this Article 16, whether requested to perform such acts by che contractor or not, such employees of the owner, while performing such aces, shall be considered the agcncs and servants of che contractor subject eo che exclusive control of che contractor." SECTION U - GOVERN IMG PRINCIPLES The need to provide plane management with guldepoata to direct their dealings with contractors is twofold: 1. To assure maximum safety for our own employees, contractors' employees, and third persona. 2. To assure maximum safety wlthouc placing the Corporation In a position where unwarranted liability under coesaon law is assumed. USEI000154 E IK illllfllB lia Casual reflection on eheee point* vould seem to place Major emphasis on point 1 above. This is noe the case; these points are not of equal impor tance. Major consideration must be given to point 2. Detailed analysis of these goals will make it apparent that the placing of primary emphasis on point 2 is entirely in keeping with our management belief ehat "safety is our flrsc consideration". It Is In keeping because any ocher concept vould permit respon sibility along one "chain of command" but vould have aeeountablilty follow another. The Construction Contract makes it crystal clear that the contractor is responsible for the safety of all persons employed by him and his subcon tractors or any other parson entering our premises for reasons relating to the contract. The accountability for their safety is also his unless his respon sibility is qualified by some act or failure to act on the part of Corporation management. ^ The "acts of management" which can qualify or perhaps negate this seated responsibility of the contractor generally fell under three mein heeding#* These ere: 1. Assuming a measure of responelbtllcy for the safety of contractors. 2. Defining the position of the Construction Engineer ss responsible for completion of contract 3. Giving working directions to contractors' employees. Perhaps a clear distinction ean be made under "assuming a measure of responsibility for the safety of contractors" by shoving the contrast between an individual contractor Inspecting a plant site prior to bidding and the same contractor reporting for work as the successful bidder after the contract has been awarded. Ac site Inspection prior to bidding, the contractor Is a buslnaas invitee presumed unfamiliar with the hazards involved and plant management assumes a measure of responsibility for the safety of business invitee* end ocher persons lawfully on the premises when those business invitees and other persons enter the premises through the use of the special pass procedure. This assumption of responsibility includes, where appropriate, hard hats, eye pro tection, guides, etc., and is based on the lack of familiarity with steel operations of this type of person. However, as the successful bidder, plant management assumes no responsibility for the safety of the persons of contractors' employees, his subcontractors, and their employees coming on the premises pursuant to a Construction Contract since this class of person is by the terms of the contract skilled In the work being performed and assumed to be familiar with steel operations, further, by the specific terms of the contract, the con tractor himself has assumed full responsibility for their safety. Contractors' employees enter the premises through the use of the contractor's badge procedure and their comings and goings are not brought to the attention of plant manage ment on an Individual basis. -2- 1 USEI000155 m lc la Imperative Chat thla relationship ami the distinctions It makes he understood by plant management. It la even more Imperative that this relationship be carried to the point where the Corporation la fully protected or to a point beyond which we are willing to assume a calculated risk. Experience has shown thee the most severe Injuries arise out of moving machinery (cranes, conveyors, hot cars, etc.), electricity, and toxle Inflammable, and explosive gases. All such hazards should, of course, be pointed out to each contractor at the time of his visit to our premises In preparation for bid and each should be Informed that the responsibility for providing for such hazards and pointing them out to his subcontractors rests with him not with United States Steel Corporation. It should also be pointed out to the contractor who Is the successful bidder that his responsibility for adopting and enforcing safe procedures Includes the responsibility of any subcontractor he might employ. The responsibility for pointing out these types of hazards exlaea and rests with plant management even though the coneraceor has received a copy of "Contractors' Safety Responsibilities". In some Instances, a hazard of the types just mentioned la considered by a court to be so extreme that merely pointing out Its existence to the con tractor may not be held to be enough to relieve the Corporation of liability. For Instance, if .the Corporation retains control of the transformer room end continues lc In operation even chough the Corporetlon had notified the con tractor chat the panel boards would be energized throughout Che performance of Che work the contractor was hired to do, Injuries growing ouc of the work could be laid at the door of the Corporation. In Ohio, a contractor was hired to do a specific job of work on sn electric panel board; the contractor hired supposedly expert workmen to do the job The contractor had been advised of the hazard. One of those workmen got himself burned on a panel board he knew was energized and the owner of the premises was held liable to the employee for not providing a safe place In which to work. By extension, the same rule possibly could be applied to moving machinery, cranes, conveyors, trucks, and the like. !n ocher words, where there Is an active condition as distinct from a passive condition like a hole in the ground, calling the attention of the contractor to the hazard and the problem may not be enough to shift responsibility. It may not be enough-even if wc have scrupulously avoided having any of our our people assume responsi bility by actively directing the progress of the work. It may be that in some situations the only answer if we are to avoid liability Is to remove the hazard and do so before the accidene. That may sound unreasonable but there was one Instance where a painter was electrocuted by high voltage lines in the roof trusses. In the light of several "electrocution" decisions as well as a result of a little pre-trial persuasion by the judge, we knew we were faced with al most absolute liability so we settled with his widow for $22,800. The day after the man was killed, the high voltage feeder lines were moved outside the building a: a cost of $485 This may or may not be typical of an average -3- I USEI000156 i pre-accident choice but ie does typify the kind of pre-contract planning which could pay dividends Soma mlconcepclons have developed relative Co the position of Che Construction Engineer These muse be clarified. The Construction Engineer is responsible for coordinating the contract, interpreting require* ments, and serving as the point of contact for plane management with the contractor The Construction Engineer la not responsible for the work per* formed by the contractor except as he polices ehe specifications and eondleloaa of the contract Internally, the relationships between ocher members of plant management and the Construction Engineer should be akin to and controlled by the requirements for dealing with a Department Superintendent. Zn "Contractors' Safety Responsibilities.", reference Is made In several Instances to clearance with the Engineer Tills does not mean chat the Engineer has complete author* icy for independent and unilateral action, rather it vests in the Construction Engineer the responsibility to check and clear with Che departments at interest such as Safety, Fire, Operating, etc , before granting Che necessary authori* ration This responsibility to confer is not intended to qualify or to establish joint or divided responsibility between Che Construction Engineer and oeher de* parements in dealing with contractors. Sole responslbility is vested in the Construction Engineer ^ " 1--------------------- It is of concern thae we select our contractor with some considera tion to his regard for a proper safety program. Past experiences can form a reliable gulda in chls manner but certainly, as Corporation management, ve are remiss if we continually let contracts eo individuals whose demonstrated regard for a proper safety program is inadequate. Much trouble can be elimin ated at this point by simply advising the Purchasing Division not to extend an invitation to bid to these individuals. In extending Invitations to be bid, Che following must be considered: First, it Is of some importance how we select our contractor. Pe should be one who does have a general reputation for care and safeey and one who does not have previous adverse safety performance records either with United States Steel Corporation or other companies and who we know, or believe, will adopt safe practices without our having "to fight" him. It is fair to say that we would not contract work which our own employees could do only because it was cheaper * if the only reason it was cheaper was that the contractor was more lax in his safety precautions than we would be Not only would thae represent a callous adoption of a double standard of safety moral ity but it might cost more money in the end anyway by the time we settled all of the claims asserted against ua. So it is of concern that we select our contractor with some regard to his regard for a proper safety program. Second, we must do what we can to see that the contractor does the safety job chat is rightly his. In addition to ooincing out the hazards at the time of view, safety and engineering personnel should observe the performance by the contractor periodically end give him all necessary advkc and counsel relative to safe practices. In so doing, we are not taking over -4 ia n a " USEI000157 hit job, vo aro only helping hi* to do that job safely aa ho haa undertaken to do by contract. This la the function which va can perform in limiting the Corporation*a liability for injury or death during eonatruction work on our premises. Mot to do the safoty work for the contractor but to help to see that he does it himself. Finally, In planning for the anticipated work of a contractor, a proper inspection of the situs of the work la bound from time to time to show some hazards which can be easily removed, perhaps even more cheaply than the nuisance value of a lawsuit. If you would fix it before giving your own employees an assignment to work there, then do it for the contractor. Giving working directions eo contractors is the area where manage ment is most likely to unintentionally assume liability. One of the major areas of ability to claimants "to tag" us for negligence arises from fact situations in which the claimant was in some measure justified in contending chat even though the contractor had been warned about the existence of a condition, our own people could be drawn into the picture as having subse quently and specifically "okayed" ehe contractors' employees working under the dangerous circumstances which produced the accident. Zn ocher words, the effort to place the responsibility on the contractor by notifying him of the hazards was negatived by one of our supervisors, in cffece, taking the responsibility back again by giving some on-che-scenes off-the-cuff working instructions to an employee of the contractor which the court construed as practically an invitation to an accident. Zn an effort to avoid ehe recurrence of faces which would support a charge of negligence for this kind of situation in the future, the Construction Contract has included within it Article 16. Our practical success under it, however, will depend in large measure on our ability to avoid giving working directions to employees of contractors wherever possible. How, does this mean that our own safety people should no longer be concerned with whether or not the contractor has an adequate safety program? The answer is clearly and definitely "no". It Is now even more Imperative that the works personnel Intensify their efforts to secure safe performance of the work by che contractor. Our actions should be directed toward having a proper safety program adopted by the contractor - not merely handing him our own department safety rules and telling him to follow them. We should noe only urge the contractor to adopt our rules as his own as a minimum but also revise and supplement those rules when and where necessary in order to properly discharge hi* responsibility to prevent accidents. Any failure on the part of the contractor to comply with United States Steel requirements .is *ct forth In Part I Construction Safety Responsibility and any failure to enforce proncr safety procedures can be considered every bit as much of a breach of the Construction Contract as chough he were to sand the concrete or apply one coat of paint where two were called for in che so-cifleatlons. i i USEI000158 ft *A w H3 >v Th "fal lure ce act" on eha pore of management which eon cause eho ft Corporation eo assume liability falla Into two main eaeagorlaa. Thaaa ara: 1. Failure eo acquaint eho eoncraeeor with knovn hosarda. ft 2. Fallura eo Inalae upon eho contractor adopelng and enforcing, a safety program. ( Tha manual, "Contractor** Safaey Responsibilities", haa boon prepared to minimise the possibility of liability seeming from failure of managemene eo adequately Inform the contractor but le cannot do ehe complete job. Plane I managesMnt must supplement, aa necessary, this manual In order to avoid liabilley from ehls source. Failure of plane sumagernene eo periodically Inapece ehe work alee and deeermlne and Insist upon ehe coneractor enforcing the safety program he has adopted might be considered by a court eo Indicate aunagemenc acceptance of ehe contractor's work standards. Periodic Inspections are necessary, chare- 1 fore, so that we are not backed lneo corners by our failure eo ace. SECTION III - CONTRACTORS SAFETY RESPONSIBILITIES 1 This manual la prepared as a separate book In order eo provide one more assurance it will reach the contractor's superintendent and not be used only by the estimator as could be the case If It were printed in its entirety F as a part of the specifications. Therefore, a copy will be given to eoneraeeora lnspecelng the site prior to bidding and again to the successful bidder. The manual, "Contractors' Safety Responsibilities", has to do with problems for ehe prevention of Injury, not only eo our own employees but also to employees of contractors or subcontractors performing work on Corporation premises. Ze Is Intended as a guide, outlining minimum precaution* to be l taken by ehe contractor. Zt 1* based on actual experience in the steel Indus try and is given to ehe contractor with the understanding thae these practices are representative of minimum safety requirements only and In no way relieve the contractor of the responsibility for such additional requirements for the I safe performance of work as may be necessary for the protection of Corporation personnel, contractors' personnel, or third persons. Zf clarification of any pare of ehe manual is necessary, the contractor should consult with ehe I Construction Engineer. When an employee of a contractor or subcontractor Is injured or killed, suits arising eherefrom fall under common law or statutory liability t for which there is no limitation fixed as in workmen's compensation statutes. The Construction Contract has no indemnity clause. The coneractor [ Is subject to common law liability for his own negligence and since the Corporation had been unable co effectively avoid tha consequences of claimed S ( ^ a > T) iu r USEI000159 k m M m i negligence on our own pore, the tndimiejr in pace contracts woo eliminated and replaced with Arelelo 16 which provides: 1. The safety of all his employees or his subcontractor's employees la the contractor's sole responsibility. 2. The contractor Is required to take every reasonable precaution to prevent Injury or death. 3. Whan Corpora .on personnel advise or counsel the contractor relative to s safety practices, in doing so, they become one of the c itractor's agents and are not relieving the contractor c his primary obligation and responsibility for safe perform ice of work. The safe perform ice of work by the contractor falls under three principal headings: 1. Ceneral requ aments for the protection of Corporation personnel and property 2. Minimum requirements for the protection of contractors' employees and third pevions while working on Corporation property. 3. Suggested saia practices for adoption by contractors to Insure safety of coi.tractors' employees and third persons. With Article 16, It la now even more Imperative that works personnel Intensify their efforts to secure safe performance of work by the contractor. Our actions, however, should be directed toward having a proper safety program adopced by the contractor and periodic Inspections to assure that he is policing ehe program and practice which he adopeed. The "Contractors' Safety Responsi bilities" manual has been prepared to help bridge this gap. Our success under it will depend, in a large measure, upon our ability to avoid giving working directions to employees of contractors. For instance. If plant management personnel notice that contractors' employees are not wearing hard hats, do not call to them and dlrcet them to wear hard hats - report the instance to the Construction Engineer who will advise Che contractor chat he la noe com plying with his own safety requirements. Continued abuse could bring more drastic action with the "threat" of actual cancellation of the contract under the "breach of contract" provisions. Any substantial failure on the part of the contractor to adopt and enforce proper safety procedures can be considered a breach of contract. Of course, the right should be used judiciously and only should be exercised after due clearance and with the consent of Engineering, Operating, and Law. -7- USEI000160 ft SECTION IV - INVITATION TO 810 Xn order eo bo assured thee the contreecor io fully aware of hie oafocy responslbilities, a statement will appear In ehe specification going cue with cho Purchasing Division's "Invitation co bid". Including Contractors' Sofoey Responsibility lo pore of the specification which. In turn, becomes pare of contract. * For apecial hazard condlelona noe covered In chls auinual, these special regulations shall be Included In ehe specification In addition to thlj manual. It la the responsibility of the Engineering and Purchasing Divisions jointly and separately to see that this specification is pare of the "Invitation to bid". * SECTION V - INSPECTION OF THE SITE PRIOR TO BIDDING Because of ehe specification vhleh the contractor has received along with his "invleation eo bid", he will expect to receive a copy of the "Contree* tors* Safety Responsibilities" manual at ehe time he inspeees Che plane sice In preparation of his bid. Therefore, ie shall be ehe responsibility of the Works Chief Engineer, at locations where work is to be performed by contractors, to maintain a stock of the "Contractors' Safety Responsibilities" manual in sufficient quantity to provide each contractor Invited to bid on the job with a personal copy. These manuals are stocked in the Stores Department and have been assigned Form No. C-2Chi>7. They may be ordered by white requisition addressed eo Hr. R. A. Winner. At the cine the contractor reports td the plant site for inspection prior to bidding, Che Construction Engineer assigned to- the project will meet with him, give him his copy of the "Contractors' Safety Responsibilities" manual, discuss it with him, and answer such questions as the contractor may have rclativo to it. The responsibility for meeting with the contractor is vested in the Construction Engineer. However, the Construe* tlon Engineer may be assisted in this meeting by the General Supervisor of Safety or such other plant personnel as he deems advisable in accordance with practices established by the plant. Upon completion of the discussion, the contractor shall sign the following form, acknowledging receipt of the "Con tractors' Safety Responsibilities" manual. This form, signed by all prospective contractors, shall be kept on file by the Construction Engineer. FORM I certify that I have received a copy of Contractors' Safety Responsibilities end that these have been explained to me and l agreed to comply wish these requiremenca. *8 - ^ Titla Company USEI000161 Xe 1* necessary chae Fare l of ehe "Contractor*' Safety ResponalblUtas" manual vhlch ralaeaa co ehe protection of Corporaelon peraonnel and property be thoroughly discussed at ehla time. In addition, Fare tX aha11 be reviewed with the contractor under*tending that hi* bid 1* hla agreement to adopt and enforce as pare of hla safety program ehese requirement*.. Xe la Important that the contractor have full knowledge of Fares X and XX so chae he can determine what effect. If any, these requlremcnes will have on hla bid. If ehese requirements are noe explained prior to bidding, lc la possible that che contractor,. It awarded ehe conerace and then learning of these safety requirements, may avoid che conerace on ehe basis of his noe being aware of or having a chance eo consider ehese requiremenes In submitting his bid, or he may submlc a bill for extras eo cover che real or Imaginary coats properted to be suaealnad by him in meeting ehese requiremenes. SECTION VI - INSPECTION OF PLANT SITE BY SUCCESSFUL BIOOER PRIOR TO START OF VOftK Prior eo scare of work, che successful bidder will meee with Che Construction Engineer, che Cancral Supervisor of Safeey, and such other plane personnel as ehe Construction Engineer may deem advisable. The purpose of this meeting Is eo again review In complete detail ehe safety requirements of Pares X and XX and to determine'if che eontraceor desires local asslseanea under Part XXI. At this time, ehe contractor will be expeeced eo explain end define his safety program and che Construction Engineer will outline ehe means eo be employed by the plane for inspection of work and for determining adequacy of the contractor's safety program. SECTION VII INSPECTION OF WORN IN PROGRESS We must do what we can cd see thae ehe eonerector does che safety Job ehae Is rightly his. In addition to pointing out the hazards ae elms of Inspection of site, safety ami engineering personnel muse obaurve ehe perform* ancc by the contractor periodically and give him all necessary advice and counsel relative eo safe practices. By doing so, we are not caking over his I job; wc are only helping him to do that job safely as he has undertaken eo do it by ehe contract. This Is the function to be performed by Corporation personnel in limiting ehe Corporation's liability of Injury or death during construction work on our premises. We should not do the safety work for the contractor but should help him to see that he does it himself. Safety inapee* cions should be made by safety personnel and reports made eo the Construction Engineer who will cake up with the contractor maeecr* of unsafe practices or safety program violations. If ehese violations eontinue after they have been discussed with che contractor, work may be stopped under the breach of contract provision. Also, in the inspection of ehe sice, we are likely to uncover, from time to time, hasards which can be easily removed. These should be reported to the Construction Engineer for handling. -9 - USEI000162 m m n SECTION VIII - RESPONSIBILITIES OF THE CONSTRUCTION ENGINEER Ih CoMtnetiwi Engineer it rupmiiblt for eh coordination ( all work under a contrace. He la responsible for interpreting requirements of the "Contractors' Safety Responsibilities" Manual. However, le la noe Intended that eh* Conatrucelon Engineer should unilaterally Make deelalone and grant approval which would affece Operating or Safcey Departments wichowt adequate "before the face" clearance with these .department*. for inseance, lean 4.5 on page 2 of "Contractors' Safety Responsibilities'* has to do with the procedure for handling floanable liquids. *.t Is expected that before the Engineer approves any such procedure, he will have discussed le with and obtained the recoamendatlon of the plant fire department. Because of the importance of Item 1.5 on page 1 and 1.3 on page 7, Contractors' Safety Responsibilities, provision Is specifically Made for a prescribed "Certifi cation of Instructions'* which is to be signed by the contractor, the Engineer, an operating supervisor, and a representative of the Safety Cepareocnt. This "Certification of Instructions" should be In the form of Minutes of eh* Meet ings between plane representatives and the contractor and should cover all such nestings which relate to agreement on procedure and auch items as: no saoklng areas, electrical circuit d*'energising, entry on or above erane runways. Isolation of gas and/or fuel, air, or steam lines, painting or working on coke benches, and similar Items. Minutes shall be acknowledged by the contractor signing the following 7 certify that l have received a copy of the minutes of (date) Meeting and that those minutes correctly states those matters which were discussed and agreed upon at that time. _ Title Company SECTION IX - SAFETY DEPARTMENT RESPONSIBILITY The Safety Department shall conduct periodic inspections of the work sit*. They shall note and report unsafe practices or direct violations of the "Contractors' Safety Responsibilities" manual or the contractor's safety pro gram to the Construction Engineer. If such violations continue, the plant Safcey Department is vested with the responsibility eo have the Construction Engineer stop work until adequate consideration has been given eo these items by the contractor. This authority extends to breach of eoneract, if necessary. The plant safety department further shall provide counsel and guidance to the contractor as required by him and as'requested by the Construction Engineer. SECTION X - CONTRACTORS' SAFETY RESPONSIBILITIES MANUAL The manual "Contractors' Safety Responsibilities" is included in Its entirety in the pages immediately following. - 10 - USEI000163 SECT ION XI ACCEPTANCE OP EWIPtCXT AND FACILITIES The plant safety department should bo notified of any aov equipment received or being installed in order that safety Inspection nay bo node to detcralne If le it safe eo operate. Nov machinery should.not bo oporstsd or aov proeossos pue loco offset until posood oa by tho plane Safety Department, la collaboration with representative* of the Engineering, Maintenance, and Operating Department*. - 11 - USEI000164 CONTRACTORS* SAFETY RESPONSIBILITIES I UttfTEO STATES STEEL COEPOHATtO* NOVEMBER 1, IMS USEI000165 TABLE OF CONTEXTS Nil nitviii. ................. ............................ ................................................................ .. i NIT I KIIIU UKIKNtlTI FOR TNE PROTECTION Of CORPORATION PERSONNEL AID NINITT IY (KTNeTIU Sietiei i - General ............. .......................... .................. .................... 1-2 Suction Suction Suction Suction Suction 2 Traniertittin.................................................... 3 - Nrfl*l Conduct .......................................................... 4 - Housekeeping and PtraProtection ....................................... 2-3 5 - utilities ....................... 3-4 o - Overhead worn including Painting and Scaffolds ........... 4 Suction 7 - Cranes....... .............................................................. Suetlon $ - Explosives ........ ............................................................................ Suction ' 9 - Gas ............................................................................... 3 Suction to Sowars and Excavations ......................................... Suction || - woiding and Burning......... ......................................... 2 2 5 3 5 0 FAIT II MINIMUM REQUIREMENTS FOR THE PROTECTION Of CONTRACTORS* EMPLOYEES AN TMIR9 PERSONS WHILE WORRINS ON CORPORATION PROPERTY Section | - General ........................................................... Suction 2 - Transportation.......................................................... Suction 3 - Puraonal Conduct ....................................................... Suction 4 - uti l itits ................................................................... Suction 3 - Overhead work .......................................................... Suction 0 - Cranes ................................................................. Section 7 - Gas ............................................................................. Suction 8 - Sewers and Excavations ............................................ 7-0 8 8 9 9 9-10 PART III SUOOESTCO SAFE PRACTICES FOR ADOPTION Y CONTRACTORS TO INSURE SAFETY OF CONTRACTORS* EMPLOYEES AND TNIRO PERSONS .............................. ||-I2 FOREWORD Concrsceors performing vork on United State* Steel Corporation premises, elehcr purauane to a standard construction contract or w a purchase order with attached conditional aaauma complete responsibility for the aafe performance of auch work. The contractor aaeumee thae rcaponaihility under the following clause: fat wctt or au rtitM (mono ar mid mo ms jvscoNTSAtfOAi on pvacnaka's patnuts. oa ant otmA Ptasoe who cntcas upon auacmasca's PatwiStJ roa atASONS aclating to this contaact, skau ae Tat sou atSPONSintirr op stuta. stitca saiu Ar au Tins maintain gooo caoca among his emonrs ano Small not wot ON m won* Amt unpit MASON oa ANYONt not saiuto in Tat woaa Assrcno to am. sclUA Small conpinI mis (RAlOyks ano all OTata mason* who Ctt< ONTO PU*CnAS(A'S pamists AT SfLLtA'S ACQUCST OA POA A(AS0NS ACLATinC to this oontaact ano nis (oviprcnt to that poation op PuacMAsra*s pacriscs VaCAt Ta VOAK UNOCA TNIS CONTAACT IS TO |( P(APOAW(0. OA TO AOAOS IfAOIKG TO Ano PAOn SUCH VOAK SIT(S. ANO TO ANT OTMCA AA(A VMICM PgACMA$(A MAT PCAPIlT stuta to ust. SCllca small tak( all AtASONAiif ntASuatS ano paccauTions at all tires to patvtNT iNjuaits to oa tm( ocatm op ant op mis tRPLOTtcs oa ant oTKta pikson HM0 (NTCAS UPON PUACmASCA'S PAtniStS. SUCH RCASUACS ANO PAtCAUTlQNS SmALL INCLUOC. tUT Small NOT It LIRlTtO TO. All SAPtCUAAOS ANO VAANINGS NtCCSSAAT TO PAOTtCT WOAKRtN AMO OTatAS ASA INST ANT COOtTIONS ON PUACMASEA'S PAfmStS VNICH COULO It OANGtAOUS AMS TO PA(V(NT ACCIOCNTS OP ANT KINS WHtNCVtA VOAK IS King PtAPOantO in paoxiriTt to ant roving OA OMAAtihG racnincat, (ouiprCnT. OA PACILITICS, vatTata SUCH rACMINCAY, (OUIPRCNT. OA PACILlTltS AAE Tat PAOPtATr OP. oa AAt king OPtAATtO ST. TM( Stuta. MIS SUICONTAACTOAS. Tm( PUACMASta. oa OTata PtASONS. This responsibility for the safe performance of the work extends both to United States Steel Corporation employees and property and to the employees of contractor, hia subcontractora, and other peraona coming on the premiaea in connection with the work. Zn the proper discharge of this reepoaeiblliey, the eoneractor will meet with designated representatives of the Corporation to view the premises and become completely aware of exiatiag conditions and hazards if any. Prior to beginning vork, the eoncraceor will again meet and consult with designated representatives of tho Corporation to dlacuss the discharge of hia responsibilities under the contract. Pittsburgh, Pennsylvania Kovembsr 1, 1953 1 USEI000167 i i f ! I h H5 > D H tD > *0 USEI000158 V PART I * GENERAL REQUIREMENTS FOR THE PROTECTION OF CORPORATION PERSONNEL ANO PROPERTY BY CONTRACTORS Pare S of Contractor*' Safety Roeponslbllltlas outUna* th* precawcions to be taken by th* contractor for th* protection of Corporation personnel and Corporation property. It la baaed on aetual experience In th* Steel Industry and la given to the contractor at th* tin* he Inspects th* ale* prior to submitting his bid, with th* understanding that these practice* represent minimum safety requirements only and la no way relieve the contractor of the responsibility for such additional requirements for the safe performance of work as may be necessary for th* protection of Corporation personnel and Corporation property. If clarification la necessary, ' the contractor should consult with the Construction Engineer of the plant where work Is to be performed. 1.0 GENERAL 1.1 All safe practices on construction work outlined In the latest edition of the "Manual of Accident Prevention In Construction", as published by The Associated Ceneral Contractors of America, Xnc., shall be followed. A copy of this manual shall be on the Job sit* at all times and all contractors' personnel shall have a working knowledge of it. 1.2 Contractor shall recognize that work In the construction may be performed while the mill Is In operation and that he Is responsible to establish necessary safe practices to permit the performance of work under operating conditions without endangering Corporation personnel and property. 1.3 Vhere work of contractor must be integrated and coordinated with Corporation operations or with work of oeher contractor, such Integration and coordination shall be undertaken only as authorised by the Engineer. 1.4 The term "Engineer" as used shall be the plant Chief Engineer or his authorized representative assigned to the contract. 1.3 Before entering any Operating Department to perform work, the contractor shall obtain permission from the Engineer after consul* cation between the Engineer, Operating Supervisor, and Safety Department. A prescribed form of Certification of Instructions to contractors shall be signed by each and a copy obtained by contractor before starting work In each department. Intermittent I operations shall b* cleared with Engineer before work is resumed. 1*4' Contractors shall comply with all safety codes, laws, or ordinances applicable to any public authority, 1 * ft h 7 USEI000169 1.7 Conservation of all temporary building* and trailer*. Including vtrlng and haaelng facilities, shall b approved by Che Engineer. 1.8 The coneraceor ahall report til injuria* auatalnad while on ehe property oC ehe United Sente* Steel Corporation to the Engineer who will forward to the plane Safety Department. 2.0 TRANSPORTATION 2.1 Contractor*' vehicle* operating within the plant shall be kept la safe operating condition. Thia include* brake*, horn*, light*, ate. If back-up horn* and llghc* era not provided, a man shall walk behind any vahlcla backing up in araa* wher* Corporation par* onnel ara located eo warn personnel. Truck* Moving In Mill building* Must be preceded by a nan on the floor. 2.2 All truck* and vehicle* operated by the coneraceor In ehe plane hall adhere to plane regulation* and ahall ob**rv* all warning and traffic sign*. 2.2 Coneraceor*' employe** ahall not operate locoooclve*. car*, eraiaa, elevator*, other moving equipment, or tool* owned by the Corporation unla**' authorised by the Engineer. 2.0 PERSONAL CONDUCT 2.1 Coneraceor* and ehalr employee* shall observe all parking reetrlceion*. access restriction*, and regulaclona. 2.2 Contractors' employee* shall not use sanitary section* and wash house* of the plane except as approved by the Engineer. 4.0 HOUSEKEEPING ANO FIRE PROTECTION 4.1 The Job sle* shall be kept clean and orderly at all times. 4.2 Lumber, pipe, and ocher material* shall be piled where they will not interfere with operation* or create hazards. Pile* shall hay* at least six feet clearance baeween cloacae erack rail, roadways, building* and edge of pile. Location of pile* to be approved by the * Engineer. 4.2 All scrap and waste material shall be disposed of prompely a* directed by ehe Engineer. 4.4 Upon completion of contract, work site ahall be cleaned up to th* satisfaction of tha Engineer in accordance with plant standards. 4*2 Procedure in handling flammable liquids shall be approved by tha Engineer. -2- USEI000170 i Motor fueling locations iml procedure eheli be approved by eke Engineer end plane Fire Department. Centrectors' personnel shell become familiar with fiTe protection end gee eleni facilities, including "turning in" of alarms. A minimum of IS feet cleerence eround ell fire hydrants shell ke aelneeined with enerence co seme. 4.B.1 Contractors' eaployees shell noe use fire hydrencs for eny other purpose unless epproved ky the Engineer.' 4.10 Conerectors' eaployees shell obey ell fire control end nonsmoking signs. Conerectors shell use only the type seleaendors end loceelons epproved by che Engineer. 4.10.1 Conereceors* eaployees shell extinguish ell open fire heeclng unles when uneetended. 4.11 Disposel of points end solvents viehin the plsns shell be epproved by the Engineer. Contractors' eaployees shell noe neke eny conneeelon co opereelag eleeerleel, gas. stesa. sir. oxygen, ecld, voter, or process line unless euthorleed by e written procedure signed by che Engineer, Opereelng Supervisor, end conerector end then only when ehe Engineer has so cleered. Conerectors' eaployees shell not turn on or off eny of ehe ebove lines. All opereting velvet or svleches shell ke opereted by ehe responsible Opereelng Department unlees euthorlsed by e written procedure signed by ehe Engineer. Contrsceors' eaployees shell noe sec in notion eny alll machinery without ehe approval of ehe Engineer. All valves or svleches shell be locked out by both the coneraceor and ehe Opereelng Deparemene or Engineer. Contractors shell noe make inaccessible eny control valve or switch. Conerectors shell report eny unusual eondlelons chat nay be found immediately eo the Engineer and stop ell work until approval to continue is granted. 1 USEI000171 5.7 PRISMATIC ARC RYOIUVUC IQUIPMERT ARC URIS 5.7.1 Contractors' employee# shall not use piped ojcygan la piece of compressed air. 5.7.2 Contractors' employees shall not braak any hydraulic llna under pressure. 5.7.3 Contractors' employees shall not bum or void on existing hydraulic lines wiehout approval of the Engineer. S.t frames - euecTRfeu cwipmcrt arc uircs 5.8.1 Power-driven mill machinery requiring shutdown shall be made inoperative jointly by the Engineer and the contractor. 5.8.2 Contractors* employees shall not operate or tamper with any existing power-driven mill machinery. 8.0 OVERHEAD WORK tKCLUOIKfl PAINTING AND SCAFFOLDS 8.1 OVIRHIAO WORK 8.1.1 Contractors shall be responsible for barricading ground or floor when working above ground level to protect Corporation personnel. The protection shall be equal to that described In the A.C.C. Manual or In accordance with written plant procedures furnished to the contractor. Signs shall be placed warning of danger of falling objects. Vatehaen shall be placed if required by Engineer. 8.1.2 Contractors' employees shall not leave cools and equipment when working overhead so that they may fall. ,8.1.3 Contractors' employees shall not leave loose material over head. 8.1.4 Contractors' employees shell not take glass bottles on roofs or elevaeed areas. 8.2.1 Painting by spray gun shall be done on approval of the Engineer. Spray painting signs should be posted and consid eration be given to wind direction, location of roads, parking lots, etc. * 6.2.2 Contractors shall not paint over or smear safety signs. USEI000172 a n m 7.0 MAXES 7.1 Contractor*' employees shall not operate any of the Corporation'* laeerlc overhead traveling crane* except a* approved by the Engineer. 7.2 Contractor* shall not carry crane lift* over the head* of Corpora* tlon employee*. 7.3 Contractor* shall not us* defective chains or slings in asking lift*. .0 EXPLOSIVES g.l Handling of explosive* shall be in accordance with exlacing plant procedures furnished the coneraceor ae tine of bidding. 5.2 Contractors shall nee use explosive* vlehouc approval of the Engineer. 8.3 Contractors shall noe drive- explosive*driven studs into structural neabers until approved by the Engineer. 1.4 Use of powder-actuated tools shall eonfora to standards developed by the Engineer. .0 GAS 9.1 Contractors' employees shall noe work in doubtful areas until tests for combustible gases, carbon monoxide, and other hamful gases have been made. 9.2 Tests shall be taken before coneraceor* work in oxygen pies or oxygen-enriched atmospheres. 9.3 Purging of oxygen, acetylene, and gas lines shall be performed by ehe plane. 10.0 9.4 Contractors shall noe use lneemal combustion engines inside buildings where personnel are ac work unless adequate ventilation is provided. SEWERS AKO EXCAVATIONS 10.1 Concraeeors shall protect open manholes, catch basins, pits, and excavations with adequate barricades and red lights. 10.2 Contractors shall replace manhole covers promptly when work is suspended. -3- USEI000173 11.0 VELOtXS AMD BURNING 11.1 Contractor*' employee* shall noe burn bole* in or wel<l to * structural member* uni*** approved by the Engineer. 11.2 Contractor*' welders *hall not weld without protecting Corporation employeoa from the arc'* ray*. 11.3 Contractor*' employee* shall ground all weldment* *o that indi vidual* or equipment arc not exposed to ground circuit. 11.4 Work area* where burning or welding 1* done shall b* approved for fir* protection. Adequate fir* prevention equipment ahall be on hand. 11.3 Oxygen and gas cylinder* shall be returned promptly to storage area after use. 11.4 Oxygen and gas cylinder* shall be kept away from heat, open fires, and hot metal. 11.7 Oxygen and ga* cylinder* shall be stored separately and at lease 6`-0M from each ocher. 11.i Contractors' employee* shall noe use oxygen or ga* cylinder* sc ground level in horltontal position. Cylinder* shall be used in vertical position and secured to prevent falling. 11.9 Contraeeors' employ*** shall noe drop or roll oxygen or gas cylinder*. 11.10 Caps shall b* kept in position except when gauges are aceaehed. 11.11 Cylinder* shall not ba moved from one location to another with gauge* attached. 11.12 Cylinders shall ba transported only when secured in a vertical position. r \ ii i i p A [ R T II i I P A R T III PART II MINIMUM REQUIREMENTS FOR THE PROTECTION OF CONTRACTORS* EMPLOYEES ANO THIRO PERSONS WHILE WORKING ON CORPORATION PROPERTY . rare It of Contractor*' Safety Responsibilities act* forth mlnlsnsm requirements which Che contractor oust adopt and enforce for the protection of contractors' employees and third persona while working on Corporation properey. These minima are based on actual experience In the Steel Industry and sec forth only minimum safe practices for the proteeelon of contractors' personnel and third persons coming on the premises. They are not Intended In any way to be Inclusive or eo relieve the contractor of all or any pare of his responsibility for the safe performance of work. Zf clarification la necessary, the contractor should consult with the Construction Engineer of the plane whera work la to be performed. 1.0 GENERAL 1.1 Contractor shall recognize that work In che construction nay be performed while the mill Is In operation and that he Is responsible to establish necessary safe practices to permit the performance of work under operating conditions wiehout endangering contractors' personnel and property or third parties. 1.2 Contractor shall comply with all safety eodes, laws, or ordinances applicable to any publle authority. 1.3 Before entering any Operating Department to perform work, ehe con tractor shall obtain permission from the Engineer after consultation between the Engineer, Operating Supervisor, and Safety Department. A prescribed form of Certification of Instructions to contractors shall be signed by each and a copy obtained by contractor before starting work In each department. Intermittent operations shall be cleared with Engineer before work Is resumed. 1.4 Construction of all temporary buildings and trailers. Including wiring and heating facilities, shall be approved by the Engineer. 1.3 Hard hats shall be worn by contractors' employees, and eye protec tion shall be worn In designated aye protection areas. 2.0 TRANSPORTATION 2.1 Contractors' employees shall not enter any building, pit, or tunnel unless work requires them to do so end then only after permlaaton Is obtained as outlined In 1.3. Contractors' employees shall not visit other departments or other sections of the same department; USEI000176 when entering and leaving eh plant, thay ahail use only assigned entrances and exits; viehin ehe plane they ahail uaa anly established walkways, roads, and croaaovara tn gain* eo and iron job site. 2.2 Concraeeora' employees ahail not rtda upon Corporation locomotives, ears, trains. alavatora, or other moving equipment uniaaa authorised by tha Engineer. 3.0 PERSONAL CONDUCT 3.1 Concraeeora* eaployaea ahail kaap off mill tablaa. conveyors, sad equipment uniaaa their work requires and ehan only afeor drives are locked out. 4.0 UTILITIES 4.1 Concraeeora' employeea ahail not work on any hoe wire or line under preaaura unleaa authorised by the Engineer. 4.2 Concraeeora shall maintain minimum elaaraneaa baevaan men or equipment and high voltage to conform eo applicable states codes and standard plant practice. 4.3 Coneraetors shall consult with Enginaar before working on or around high .voltage, elaeeric vires, or power circuits. 4.4 Lock-out of eleeerleal equipment shall be ae the main disconneee switch controlling the eireule or machine. 4.3 Loeks on main dlaeonneeta shall be removed only by the person who plaeea the loek. 4.6 Coneraetors' employees shall not enter motor rooms or eubstaclons unless required and then only after clearance with the Engineer. 4.7 Coneraetors' employees shall not use eleeerleal vires, cables, or eolleetor rails as scaffold supports. 4.8 Contrsecors' employees shall not make any connection eo utilities or plug or conneee into any plane electric circuit until released by the Engineer. 4*9 Contractors' employee shall noe ride upon any poverdrlven mill machinery. 4.10 Contractors' employees shall consider all electric lines hot until cleared by the Engineer. 4.11 All cranes, mobile equipment, jackhammers,-concrete busters, etc., operating in areas where they may come in eoneaet with live wires shall be grounded. 8 USEI000177 5.0 OVERHEAD WORK 5.1 Contractor** employe** shall not go *n roof* without approval of Engineer. It 1* tho contractor* responsibility to check Che bearing eapaelcy of the roof In It* present condition to support his equipment and personnel and provide necessary safe conditions* 1.0 CRANES / l Contractors' employees shall not go onto any overhead crane runway of an operating facility for any purpose until authorised by the Engineer through written procedure. 6*2 Contractors' employees shall noe go onto any overhead crane runway operated by the contractor and noe released for mill operation unless aafeey precautions have been taken for their personal pro* section. 4.) When It la necessary to work on crane,'crane runway, or when contractors* employee* sight be endangered by the movements of eranes, ehe runway must bo protected by bumpers and red lights. If cranes muse continue to operate past the area, the contractor must place a watchman on each side of the area as well as a man in eh* cab of each operating crane. 6.4 Contractors* employees shall keep in the dear of all crane lifts. 6.5 Contractors* esiployee* shall noe pass or work under ehe boom of any crane or power shovel. 6.6 Contractors* employees shall noe stand near chains or slings being pulled from under a load nor near a load being raised. 6.7 Contractors* employees ahsll not ride crane loads. 7.0 GAS 7.1 Contractors' employes* shall noe work in doubtful areas unell tests for combustible gases, carbon monoxide, and other harmful gases have been made. 7.2 7uel, steam, and air lines shall be blanked off before working la furnaces. 6.0 SEWERS AHO EXCAVATIONS 8.1 Contractors shall cake precautions to prevent cave-ins. 8.2 Contractors shall cheek all manholes or underground pits for gas before entering. -9 r f f.3 Contractor! ihall know huirdi of |u and liquid Lovol ia savors, | taka necessary precautions, and Maintain gas chock*. 1.4 Contractor* ahall sake go* eooca hoforo working ia valve git, | tranche*, or ocher doubtful area*. 1.3 Contractor* shall not excavate in vicinity of elactrieal duct line*, severs, voter lines, gas lines, or railroad craeka until | approved by the Engineer. .{ All protruding nails, tie-rods, and vires shall be reaovod from a foundation* a* soon as fora* are stripped. 1,7 Rail* from crataa or foundation ferae ahall be bent over or removed, I r * i i * I SUGGESTED SAFE PRACTICES FOR ADOPTION 8Y CONTRACTORS TO INSURE SAFETY OF CONTRACTORS' EMPLOYEES AND THIRD PERSONS part III of Contractors' Safety Heaponalbllltlea contain! sugges tions which the contractor My wish to Incorporate In his safety program for the protection of his personnel and property and third persons coming on che premises In addition to those minima sec forth In Part IX. The plant Safety Department, when requested by the contractor, and acting under the provisions of ehe Construction Contract, will counsel the contractor In che eleaenca of an effective program for the safe performance of work. 1. Establish a schedule of safety meetings conducted by contractor's foreman for dlseusslng specific copies, sueh as safety rules, hatards of-specific jobs, safe practices, etc. 2. Establish a plan for contractor's foreman to contact each employee under his supervision at least once per week on safety. 3. Establish a procedure for the prompe Investigation of all Injuries by contractor's management. 4. Establish a schedule for periodic Inspection by contractor's management of "housekeeping" of job site. 3. Establish a plan for the periodic Inspection of tools and equipment by contractor's management. 6. Develop basic safety rules for job, Instrucc employees, and enforce compliance. 7. Incorporate applicable Items of ?art I Into Contractor's Safety Rules (Item 6 above). 8. Establish standards for wearing eye protection. 9. Establish standards for using safety belts. 10. Establish standards for use of portable ladders, giving consid eration to use of "safety feet", lashing ladders at top and bottom, or ladders not lashed being steadied by another employee. 11. Establish standards for scaffolding or staging to assure that It Is securely lashed and provides adequate clearance to moving equipment. - 11 - USEI000181 12. toeobllah eh prutlu clue raffoldi # thaa 7'0" w eko 8round will bo ftovldod with eo board and railing* and eoafoxa to Soccloa 18 of chc A.C.C. "Xanual of Aeeldoae Frovoaeloa la Coaatruetloa"* 15. EiMbllih r^ulnMoti for cbo vurln* of foot protoccioa. 12 USEI000182