Document nkw8Mx6krv14JNygOErQG3Nw

SC-10J3 (REV. 5-78) Shell Chemical Company Interoffice Memorandum August 14, 1983 %fn)l5 sU- Cun CMjj\util Qrv^ftfwbL FROM: TO: J. F. HALL R. R. ERICKSON - DPMC T. R. WILLIAMS /Qhuntl^ Qjjvact1. SUBJECT: THE CHLORINE INSTITUTE, INC. "ASBESTOS MEMBER SURVEY" (JUNE '83) LjGWiO Attached is the annual "Asbestos Member Survey" (June '83) conducted by The Chlorine Institute, Inc. Attachment cc: L. A. Wheeler W. A. Scott mm SATELLITE 13 &tLtfa>Or\ Return Document to File 3 Record Copy in File Information Copy Recc-rd cocy h-yfy^Satollite- Jih LAM 001797 DPMC-17490 DATE THE CHLORINE INSTITUTE, INC. 342 MADISON AVE., NEW YORK, N.Y. 10173 : August 8, 1983 212 682-4324 TO : SELECTED OFFICIAL CORRESPONDENTS FROM : Edmund J. Laubusch SUBJECT : ASBESTOS: MEMBER SURVEY (JUNE '83) In late June, and in anticipation of imminent OSHA asbestos rulemaking, we surveyed the membership to assess "concern levels" associated with asbestos exposure limits more stringent than the current 2 fiber/cc (TWA) limit. Results of our survey are summarized on the attached. Responses were received from 10 companies operating 27 diaphragm facilities (about 80*). Respondents have no concern as to their ability to achieve a 1 fiber/cc mandate; in fact, more than half of the facilities currently achieve this level even without the use of respira tors. At a 0.5 fiber/cc level, essentially all would have a "moderate" concern and about half of the facilities would have some dependency on respirators. Nearly all would have "consid erable" concern should a 0.1 fiber/cc limit be mandated but most could achieve compliance even at that low level with im proved engineering, work practice and administrative controls, provided respirator use also were permitted. Our survey did not address members' concerns with possible asbestos cost increases associated with added cost burdens in curred by asbestos suppliers, or with possible inability of asbestos producers to comply with a worst-case regulatory control scenario. Attachment cc: Selected H & T Committee members EPC Diaphragm Cell Subcommittee PAS Analytical Procedures Subcommittee LAM 001798 DPMC-17491 MEMBER SURVEY: ASBESTOS (June 1983) Respondent Company 10 companies: 27 far-ilitigs (optional) I NUMBER OF FACILITIES AT WHICH ASBESTOS DIAPHRAGMS ARE USED __________ II TOTAL NUMBER OF EMPLOYEES POTENTIALLY EXPOSED TO ASBESTOS 715 III WORK ACTIVITY HAVING HIGHEST EXPOSURE POTENTIAL Asbestos Weighing (eg. diaphragm depositing, asbestos weighing etc.) " (describe) A. TYPICAL EXPOSURE FREQUENCY Range: 1-7 times/wk B. TYPICAL EXPOSURE DURATION Range: 10-120 min. Typical: 30-60 min C. TYPICAL EXPOSURE CONCENTRATION (fibers/cc) Range Max. TWA Basis __________ _ Ceiling ___________ IV PRESENT OVERALL CAPABILITY OF COMPLIANCE WITH DESIGNATED LIMITS SANS DEPENDENCY ON RESPIRATORS (indicate approximate! time per centage) USING PRESCRIBED OSHA MEMBRANE FILTER METHOD X %% 1 fiber TWA/5 fiber ceiling 100(16) 95(11) 0.5 fiber TWA/5 fiber ceiling 100(B) >98(11) >95(22) 0.1 fiber TWA/0.5 fiber ceiling 100 (1) >75(11) <25(13) V PROJECTED OVERALL CAPABILITY OF COMPLIANCE WITH DESIGNATED LIMITS AND PROBABLE COMPLIANCE ROUTE(S): A = Use of Substitutes B = Improved Engineering Controls C = Work Practices and/or Admin istrative Controls D = Use of Respirators E = Unable to achieve practically 1 fiber TWA/5 fiber ceiling 0.5 fiber TWA/5 fiber ceiling X mo (?7) 100(271 Route(s) r r r nfi fi) : r.r n M fi) 0.1 fiber TWA/0.5 fiber ceiling 100(20):>95(26) B.C.D(24) VI COMPANY "CONCERN" LEVEL: A = None; B = Moderate; C = Considerable 1 fiber TWA/5 fiber ceiling A(26)R(7) C(0) VII 0.5 fiber TWA/5 fiber ceiling A(4)R(24) C(0) 0.1 fiber TWA/0.5 fiber ceiling A(0)B(4) C(24) COMMENTS (eg. re availability of substitutes, adequacy of analytical methodology etc.) - Several opined that suitable substitutes not currently. ___ avai_Lab_Le^-------------------------------------------------------------------------------------------------------------------------- Many fpp>1 Bnalytiral m^-Hind nndpppnHahlp bplnw --0.5 .f-ibers/cc. Note - Number in ( ) = respondent facilities LAM 001799 DPMC-17492