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<. DOW CHEMICAL U.S.A. C:MdueS. TBX AS Division FREEPORT. TEXAS 77541 'fUC'H.rL^, tfzC/gi April 12, 1976 Joseph M. Griffin Legal Department 47 Building MIDLAND cc: R. L. Buell F. D. Hoerger D. J. Roberts ASBESTOS - WORK PRACTICE HISTORY - TEXAS DIVISION In response to your telephone call on March 11, I have reviewed the information in our files and am forwarding copies of seven items that reflect our understanding of the health hazards of exposure to asbestos and actions taken to minimize employee risk. Perhaps this will help you in your effort to determine Dow's liability risk from employee exposures to asbestos. If review of this information generates further questions I will be happy to try to answer them for you. I have omitted the Asbestos Handling Policy for the Texas Division Chlor-Alkali plants. I understand that the ChlorAlkali Tech Center is including this in their compilation of information for you. bbs Enclosures (7) R. L. Daniel Environmental Health Services S iV liS O lS AN OPERATING UNIT OF THE DOW CHEMICAL COMPA.VV 403728 ^closure - 1 ASBESTOS AND HEALTH Asbestos is an extremely useful mineral in our society--having more than 3, 000 different applications. Early in this century, a scarring disease of the lungs called "Asbestosis" was discovered. Control standards were established and, to my knowledge, no case of "classical" advanced asbestosis has occurred at : Company. This disease brought early death, usually in less than dC y after first exposure. Though there is no reason to believe we have ever cxc. d the time- weighted average recommended for control of asbestos-con' ining dusts, it has now become apparent that these people exposed to "'he lower levels will develop various other forms of "asbestos disease" after a lapse period of 20 to 30 years. These diseases consist of (1) thickening of the pleura or lining of the lungs, (2) cancer of the lung, (3) cancer of the gastrointestinal tract, and, (4) malignant mesotheliomas --a deadly cancer of the . lining of the lung or abdomen which is extremely rare except following asbestos exposure. Studies by our Medical Department indicate that, though we thought our employees were exposed only to safe levels, the changing opinion of what constitutes a safe level has left us with a significant number of individuals who are potential victims of asbestos disease. We should therefore (1) institute procedures to minimize future exposure, (2) institute medical surveillance of the individuals at risk, and, (3) institute a campaign among the previously exposed group to discontinue smoking, which habit vastly enhances the chances of developing cancer of the lung. Some Divisions have ongoing control programs of excellent quality and I have no doubt their people will gladly share their experience with anyone who has not yet established control. Continued public information on this topic could eventually result in another case of environmental hystcria--we hope if such occurs we can say everything that can be done has been done. Let us be sure that, in addition to controlling our plant environment, wc also insure that wc arc adding no asbestos dust to the community environment. Corporate Medical Department July 17, 1970 .CON:... 403729 9*1*1'iL S O iS Enclosure 2 TEXAS DIVISION FRECPOnT TEXAS 77D4I September 11, 1970 B. J. Kinsel B- 108 cc: 0. A. Easton ASBESTOS INSULATION - STATUS REPORT As of the date of this report, the Insulator Shop has discontinued the i installation of most asbestos-bearing pipe insulation. In cases where the service requirements are greater than 1500*F. , we are still installing Kaylo 20, a calcium silicate, asbestos reinforced material. This use is limited, mostly, to tube-turns on LIIP cracking furnaces. This work only comprises about 2% of the jobs we currently install. This is expected to continue until an adequate high temperature substitute is found. All of the Kaylo, a calcium silicate asbestos-filled insulation for temperatures to 1200oF., has been removed from the shelves in the shops and has been returned to locations as directed by Stores. The field stocks are being shipped to Stores as they are located. It is felt that approximately 807. of these field stocks have been removed to date. We are still in the process of locating and eliminating these small amounts of material. Engineering standards of E & CS and Texas Division are in the process of being revised. It is felt that finalization of these standards will take about eight weeks longer. Contractors are still being allowed to install Kaylo and Kaylo 20 on new construction although most of the new instal lations are in Carey-temp, a non-asbestos material. Technical Development is working in the area of finding substitutes for materials which contain asbestos such as transite, haveg, etc. It is felt at this time that existing safety rules regarding the use of respirators for "hazardous dusts" are adequate to require the use of respirators by all personnel when dismantling the existing insulation materials. Subsequent to additional talks with the Safety Department, we expect to formally communicate with all supervisors involved. 'The Functional Superintendents have already talked with the Zone Superin tendents regarding the use of respirators, when handling these products. V,Te had some minor difficulties with Purchasing's getting us into the Carey-temp business, but these were ironed out quickly. I feel that we are now "over the hump" as far as the change over occurs. There are a great many loose ends which still need to be gathered up. I will keep you informed as we change specifications, types of materials, handling procedures, etc. F. B. Crouch /wb 403730 L W lL b G lS Dji A Fl Enclosure 3 ASBESTOS USAGE - STATE OF MAINTENANCE DEPARTMENT AT PRESENT Briefly, we feel that the highest exposure rates are experienced by the Insulator Group which handles the material on a day-in and day-out basis, both maintenance and construction. The next highest group would be the Brickmasons who apply the loose asbestos fill used in the mag pot program. Next in the exposure-time-weighted factor would be the persons who occasionally fabricate asbestos-bearing materials such as transite, haveg, and the like. The last on the exposure list would be those persons who occasionally perform demolition of asbestos-bearing insulation within the plants such as removal to facilitate repairs, etc., and handling loose material torn oft existing lines prior to sending to the dump grounds. Presently, we have discontinued all purchasing of asbestos-bearing insulating pipe covering with exception of certain selected sizes of Kaylo 20, a high temperature pipe covering material, used for temperatures from 1200t' to 2200!. Only use we are aware of for this material is certain light hydrocarbon plant furnaces tube-turn bends. ST0 5 7 !< 8 We have made a concerted effort to eliminate the small stocks of asbestos pipe covering which are scattered throughout the division. I believe we have accomplished this goal to the tune of about 957. complete. We have also returned all asbestos pipe covering from our supplier (Gulf Supply) back to the manufacturer. Presently, we believe that only about 27. of the insulators'work within the division is made up of asbestos pipe covering. ($4,000 to $5,000 to eliminate all existing stocks.) Insulating materials we are using to replace asbestos are: 1. Fiberglass - both in "snap-on" and loose blankets, ambient to 350F. 2. Foamglass - 450 to 800F - also used where temperatures cycle excessively and for Dowtherm service. 15% more expensive than asbestos. 403731 Page 2. 3. Careytemp 1500 - ambient to 1500F - expanded pearlite fiberglass reinforced. Some problems associated with application but best available at present. Same cost as asbestos. Several other areas we are working on: 1. Have problems with loose fill insulation used when setting mag pots- This generates a terrific amount of dust when asbestos shorts are used. We have found that "Super 48" by "48 Insulations, Inc." mineral wool makes less dust than asbestos shorts and contains only about 10% asbestos. The texture is slightly damp or moist feeling, thus fi^ettting down on the dust problem. When our brickmasons are using this material, they have been wearing respirators. We have been assured by the manufacturers of "Super 48" that by October 16 they will be producing an asbestos-free insulation in bags marked as such. The composition of this material is a mineral wool made from copper slag. 2. Fabricating of asbestos-reinforced plastics such as transite, haveg, micarta, where dusts become a problem in operations such as sawing and grinding. We have no problem with insulators wearing respirators when this work is going on. Saws have been developed with vacuum systems to reduce amount of dust, but we still wear respirators as we still get quite a bit of residual dust. 3. Our foremen have been notified that respirators are to be worn by the employees when significant amounts of insulation are to be removed when demolition occurs. We have not yet made it a firm rule to wear respirators in any situation where dusts of asbestos occur, but I believe this will be only a short time before we do. Due to gathering evidence 403732 Page 3. of existing hazards. The last principal area I want to cover is that of new construction. We are currently in the process of changing the Texas Division standards which will require the elimination of Kaylo (asbestos-type pipe covering) from the list of approved material. The Sons truetion Department is continuing with all new construction in asbestos in which the material is on the job site, but any other new work will have the Carey temp 1500 or expanded pearlite installed in lieu of asbestos. This..change, took place about-.the -5th of..October. This is a brief summary of where we stand in the Maintenance program of elimination of asbestos exposure hazards. . B. Crouch /bs October 13, 1970-- 403733 O S V iiS O lS Enclosure - 4 ASBESTOS USE - STATUS OF IN TEXAS DIVISION We recently ran a survey of the use of asbestos in the Division with the object of answering 3 questions - 1) Where is asbestos used 2) What protective gear is being used and 3) What have people been told about asbestos. Where is asbestos used? In addition to the use of asbestos containing materials(\t&3t^V3V^fegFn=H5gri. throughout the Division, asbestos is used in our chlorine areas for cell diaphragms in cell manufacturing, and repair for facilities and in all chlorine plants for pulping cells. Asbestos is also used in the Mag Cell areas for insulationin pot settings and in numerous other ways for the sealing of leaks in the cells and vent systems. In addition to the use of new asbestos, we also have the problem of tearing out of insulation throughout the plant as well as the disposing of used asbestos in the chlorine and magnesium areas. C/7 --i ID c-~1 There is also in use materials of construction such as transite and haveg that are asbestos containing materials. cn What protective gear is being used? 403734 In most of the areas where asbestos is being used, either installed or disposed, we now have some form of protective gear in use. Our insulators have been wearing respirators for sometime. Cell Manu facturing folks have had a good protective program for about the last 1% to 2 years. Recently the Mag folks started using more pro- 2- - tective gear. I would say that the insulator and Cell Manufacturing and repair people have a good program with good supervisory control. With some of the other crafts who occassionaly remove and dispose asbestos materials, the use of protective gear is variable, probably relative to the degree of exposure. Contractors in the Division presently do not wear much in the way of protective gear. What have people been told? Asbestos information which our folks have received varies widely. Some have been.told little, if anything -- others that asbestos is hazardous to the lungs -- and others that it causes lung problems including cancer. Probably the best informed are those who have been under the periodic examination program where the doctors have apparently discussed asbestos candidly. Contractors probably have been told little about the hazards of asbestos. Now, I'll turn this over to Jack Crouch who will discuss the effort by the Maintenance folks.in substituting some different materials for asbestos containing materials. cr> --i CD cn cn no RCW/ks 10/14/70 S & LP 403735 Enclosure - 5 ASBESTOS RECOMMENDATIONS 1. Develop a Dust-Asbestos informational type program for division employees and contractors. (Similar to other hazardous material programs which have been developed.) 2. Develop and audit safe work procedures for minimizing the generation of asbestos dust. Procedure must include protective gear as a final precaution. 3. Continue to pursue the replacement of asbestos with reasonable economic substitutes. (Recognize that asbestos is probably irreplaceable in certain applications.) 4. Develop procedures for accounting for asbestos used and in monitoring asbestos exposures. 5. Continue periodic physical program on division employees who have reasonable exposure to asbestos. GS'l'l/.SO lS D. J. Kilian, M. D. F. B. Crouch R. C. Walker RCW/ks 10/15/70 S & LP 403736 uae rope to e e *l c ru c ib le c o v e r fc new ftnode s e a l. sa r nrr * S 56 : ac Iumji c sg 5S P ^ s. * ?* 3 r,3 3 9C '<rK 9 *" P* [* 13 fO* R5 3M I 3 *-* ft *9 sO Oi ** > : -v I 3o <y 2c h" i i* t- o 09 3 ' *1 O i '3 6 c a cn 3 CP* 3* ft ft3Mfaefcl O< a rr o n?Mi* n** 9>- 3 C& & 15? * V o 8. 3? 3 2- 3 43 C zz? oC O H3 8 < C. --J ft 9 Oa --4 9 e* SI Cb ii oo o 'o Iafts*** a: dI n13ftC3 c,; ' si 1f* S' o o h a < co 13 Or OO PM "533tQ 1o3 I3 3 Oa S o13c? 1P1 ' . OHa(k Ai ft _ 3" lr& ps : * - 0*3 9J g 15 3 " > 3" ft ? 9 *g -> 1 O r* 9 1 x' B3 3 ft n o a c 9 I-* r* O "SiC. _ ' 9 se 5 *f<t c-- > o 3 t- ' %9 *< "ft ox "cr 913O cr C 9" ga5 Ho o 3C 9 "ft .% cr i OilPlS -Cl s - o 3r> 3 3 H --3l 3 9 -- C3 33 ft 3 9 *0 C 3 ft 3 in c 9m &Z 9i 9 ?m.?. 3 n 9 93 vft *n rtv o9y 9 < ** ft 'i 5 f> c h fi ^ c n i c 403737 cg*i*i L901S 403738 Enclosure / 9S*lh/Lil01S HANDBOOK FOR HANDLING ASBESTOS MATERIAL THE DOW CHEMICAL COMPANY TEXAS DIVISION Maintenance Department Supporting Services July 1972 Rev.-- 403739 HANDBOOK FOR HAUDLIHG ASBESTOS MATERIALS Index 1. Purpose and Description 2. Safety 3. Use of Handbook 4. Safe Work Procedures Fabrication of Asbestos Materials Mixing Cement Containing Asbestos Handling and Storing Asbestos Materials Sawing and Cutting by Hand Insulation Removal 5. Insulator Safety Check List 6. Threshold Limit Value Page(s) 2 3,4 5 6 7 8 9 10 ll 12 I ST05741457 -1- 403740 purpose add deeceiptiq;: The purpose of this handbook 3 s to outline the cafe handling procedures of various asbestos materials used in the Texas Division. The intent is to minimize future exposure of employees to asbestos dust in any form through the proper use of safe work'procedures. Asbestos is widely used as structural wall board, insulation, and roofing material. Asbestos fibers are used as a mechanical reinforcing matrix in insulation, roofing paper, certain piping systems, etc. However, Dow Engineering Specifications were revised to ex clude asbestos-containing insulation prior to installa tion of Federal regulations controlling the use and handling of asbestos. Eventually, the use of asbestos will be eliminated as the ultimate solution to the problem. V/hen working with materials which contain asbestos fiber, care must be taken to eliminate as much loose dust as possible. V/etting, isolating the work area, or other suitable procedures to eliminate the dust hazard are absolutely necessary. The main problem areas will be in removal of old, deteriorated insula tion and the sawing of Transite. The OSHA standards which are effective July 7, 1972, define the precau tions required for asbestos handling and the allowable safe working limits. Should a hazard exist, and these procedures are not sufficient, contact the superintendent of the Plant A or B Functional groups. Exceptions or variations to the procedures which follow can be obtained only by the above responsible superin tendents. GSh'i/.GOiS -2 - 403741 SAFETY The intent of THE DOW CHEMICAL COMPANY is to comply with all Federal and State reflations and to minimize the exposure of their employees to hazardous dusts. In order to accomplish this, substitutes for asbestos-containing materials v:ill be used wherever possible. Respiratory protection, dust collectors, blowers, etc., will be mandatory where asbestos con taining materials must be handled. Materials described herein are furnished in blocks (or lags), shapes, curved segments, pre-formed pipe and fitting covers, flat and corrugated sheets and the asbestos as loose material. When handled, formed, cut, sawed, or mixed into mortars, a fine dust will be loosed in the air which may be breathed into the human respiratory system. (Respiratory protection shall be used, not just for asbestos, but other mineral dusts as well, eg. mineral wool, silica, etc.) The health of those who breathe asbestos dust may be seriously affected. Results can be similar but more serious than those caused by the more commonly icncwn materials such as silica and coal dust. This phenomena has been observed for many centuries. Current medical discoveries show that handling of asbestos by a confirm ed cigarette smoker is especially hazardous in the area of potentially serious lung disorders. It Is recommended that those persons handling asbestos not smoke cigarettes in any quantity. The two nose and mouth dust respirators which have been approved by the Safety Department are: (l) MSA Dustfoe 77, Dow Stock Ho. 15-26005, Cartridge No. 15-23774, and (2) Wilson Dust Respirator, Dow Stock No. 15-25460, Cartridge No. 15-25790. Disposal of asbestos will be in polyethylene bags, Dow Stock No. 15-05080 for large bag and 15-04170 through 15-04l85 for small bags. As required, special protective clothing such as coveralls, head covering and gloves will be provided. Such require ments will be determined by the Division Monitoring Program. 6S't 'USUIS. -3r 403742 Tv.'O lockers will be provided, so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes. Asbestos-contarr.inated clothing shall be placed in labeled, polyethylene bacs for shipment to the laundry. \ 4 403743 IS <1n q h / Q lb frL S < ? J -S use of handbook FOR HANDLING ASBESTOS MATERIALS The Safe- Work Procedures outlined in this handbook are minimum requirements for working v.'Ith asbestos contaxiixng materials. In some cases, job conditions may dictate more stringent requirements. These could include com pletely wetting down the area with water when removing old insulation, or completely isolating the work area with tarpaulins, etc. Because Dow's Engineering Specifications have been re vised to exclude use of asbestos-containing insulation, most of the Safe Work Procedures in this section of the Manual will seldom be referred to for new installations These procedures are to be used in conjunction with Plant Safety Rules, Maintenance Standard Safe Work Procedures for the Area, and Safety Standards. -5 - 403744 SAFE WORK PROCEDURE Subject: Shop Fabrication With Asbestos Materials Minimum Safety Equipment Requirements: 1. Side Shield Goggles must be worn. 2. Approved "Nose and Mouth" Dust Respirator must be worn at all times. (See Page 3; 3. There shall be a Dust Collecting System en -Pevjcr__ -gtp.rjpv.cTTt adequate to remove large amounts of dust generated. 4. An Insulator Safety Check List is to be filled out prior to the job and properly approved. Turn in to supervisor at completion of job. Special Precautions: 1. Do not breathe asbestos dust. 2. Do not operate equipment if provision cannot be made to eliminate dust in a safe manner. 3. Normal precautions must be taken for working with power equipment. (See specific Safe Work Procedure for Operating Power Driven Tools if in doubt). 4. When cleaning out the vacuum system of the machines, a respirator must be worn. Wet down dust prior to handling. Place the wet material in polyethylene bags, seal, label and notify Yard Department that asbestos waste is ready for proDer disposal at landfill. ` 3. Good housekeeping in the shop area is to be practiced. Asbestos dust must be vacuumed throughout the shop area if and when such conditions exist. 6. Keep all personnel not directly involved in the fabrication operation away from the area unless they observe minimum safety requirements and have been apprised of the hazards involved. ST0574462 .- 6- 403745 SAFE V.'O Subject: Mixing Material Which Contains Asbestos Minimum Safety Equipment Requirements: 1. Side Shield Goggles must he worn. 2. Approved "Rose arid Mou be worn at all times. Dust Respirator must 3. An Insulator Safety Chech List is to be filled out prior to the job and properly approved. Turn in to supervisor at completion of Job. Special Precautions: 1. Do not breathe asbestos dust. 2. When mixing whole sack."', do not open sacks and dump into open mixi'-.. \^ay. Moisten asbestos by adding water threu^,. a small hole in sack until danger of dust is eliminated. Then the material can be removed if necessary to complete mixing operation to desired consistency. 3. Slipping or falling is a hazard to be considered when working around wet asbestos mud. 4. Back strains from handling containers of mixed mud are also a hazard. A means of handling this mixture may need to be provided, depending on the circumstances. 5. Keep all personnel not directly involved in the mixing operation away from the area unless they observe minimum safety requirements and have been apprised of the hazards involved. 6. All contaminated bags, boxes, waste, etc., shall je wetted, placed in labeled polyethylene bags and sent to landfill. G9 *i *i .ZS0 1 S -7- 403746 SAFE WORK PROCEDURE Minimum Safety Equipment Requirement 1. Side Shield Goggles must be \:orn. 2. Approved "Nose and Moutl " " ' " irator must be worn at all times. 3. An Insulator Safety Check List is to be filled out prior to the job and properly approved. Turn in to supervisor at completion of job. Special Precautions: 1. Do not breathe asbestos dust. 2. Handle materials in such a manner as to minimize exposure to dust. Moisten material with water spray before removing from container if material will not be damaged. 3. Areas used to store asbestos containing materials should be marked "Asbestos Material". Cartons, boxes, etc., that have contained asbestos materials should be wetted, broken and placed in labeled polyethylene bags for disposal. 5. Good housekeeping of shop areas is to be practiced. Clean up all loose dust on floor, machines, shelves, etc., by vacuuming. Wet down, place in labeled polyethylene bags and dispose of dust while damp. Notify the Yard Department to dispose by landfill while material is still damp. 8- 403747 *19 *i `U S U IS SAFE WORK PROCEDURE Subject: Sawing 2nd Cutting by Hand ^ /- Minimum Safety Equipment Requirements: -- 1. Hard Hat must be v;orn. 2. Side Shield Goggles must be worn. 3. Approved "Hose and Mouth" Dust Respirator must be worn at all times. (See Page 3) 4. An Insulator Safety Check List is to be filled out prior to the job and properly approved. Turn in to supervisor at completion of job. 3. All other safety equipment which is required by job location must be used. (Read Area Safe Work Procedures.) Special Precautions: 1. Do not breathe asbestos dust. 2. We2r the "Nose ar.d Mouth" Dust Respirator when removing asbestos material from paclcage, installing, or cutting. S9VK501S 3. Keep all personnel not directly involved In the operation away from the area unless they observe minimum safety requirements and have been apprised of the hazards involved. 4. Special precautions shall be taken when using "Skil-Saw" for sawing asbestos materials. To eliminate dust hazards and protect all people in the area, an air operated saw shall be used and the material shall be flooded with water. 5. If vjat er will damage the material, a hand saw shall be used and sawdust collected with a portable . vacuum whenever possible. If site work prohibits use of a vacuum pick-up, cuts should be made directly over a collection box or polyethylene bag. 6. All contaminated bags, boxes, waste, etc. shall be wetted, placed in labeled polyethylene bags and sent to landfill. - 9- 403748 Subject: Insulation Removal Minimum Safety Equipment Requirements: 1. Hard Hat must be worn. 2. Side Shield Goggles mus,, be worn. 3. .Approved "Nose and J-joutJ " ~ be worn at all times. ~ irntor must 4. An Insulator Safety Check List is to be filled out prior to the job and properly approved. Turn in to supervisor at completion of job. 5. All other safety equipment which is required by job location must be used. (Read Area Safe Work Procedure.) Special Precautions: 1. Do not breathe asbestos dust. 2. Hazards from asbestos dust that falls, blows or may be scattered throughout the area must be elimina ted. 3. Keep all personnel not directly involved in the insulation removal operation away from the area unless they observe minimum safety requirements N and have been apprised of the hazards involved. 4. Use water to wet down the Insulation before and during removal. 3. Seal all material in labeled polyethylene bags as removed. The Yard Department is to be notified f disposal at landfill. 99*l`i i S 01S 10 403749 JOS D--1)C * i-L i' j. j. Oi^ * 'r* iJ t\J ^ I. AREA 1. Safe Work Permit Received 2. Area Safe Work Procedure Known YES NO UU 3. Nearest Phone 4. Nearest Eyebath and Safety Shower 5. Job Site in Safe Condition .LJ 6. Is Pipe or Equipment Safe to Work On? * 1___ 1 1--1 diD7. Are Corrosive Chemicals Involved? a. Can lines or equipment be drained? ljo 8. Is Adjacent Piping and Equipment Safe LZ! U 9. Red Tags Needed? " Burn Hazards Present? 11. Craftsmen Lined Up With Check List? aa U LDO Special Hazards Special Safety Precautions Checked and Approved By: Supt. Foreman Crcwleader Craftsman DATE: DATE ii. AS J3EST0S WORK YES 1. Handbook for Handling I----- : Asbestos Materials Use; T---- 2. Signs and/or Barricades 1 Up to Warn Others ? 13. Has Disposal of Debris ; Been Arranged ? 4. Is Water Needed to Control Dust ? J 5. Stencil on Job to Denotle---> Materials Used ? 6. Have all Involved J --J Personnel Been Informed hi. Special Safety Equipment Recui: Coveralls Chemical Goggles Face Shield Acid Hood Air Mask Dust Respirator GO --\ CD cn -o Rubber Gloves Rubber Boots Slicker Coat Slicker Pants c-nj -- Safety Belt Hearing Protection Other: Specify IV. Personnel on Job 'Name) Expose Tinie-H 1. 2. 3. 4. 5. 6. 403750 11 threshold limit v/.lue Ho employee eMail be exposed at any time to air borne concentration? of a sheeton fibers in excess of 10 fibers, longer than 3 micrometers, per cubic centimeter of air. The eight hour tire-weighted average shall not exceed five (5) fibers per cubic cer. Lime ter.* In order to assure compliance with these limits, the Environmental Health Group will make random samples. V.'hon special field testing Is desired, call Environmental Health at 238-2121. In order to keep asbestos dust concentration within the proper limits, any dusty conditions connected with the handling of asbestos materials must be kept to an absolute minimum. This must be done as out lined in the previous Safe Work Procedures by v:etting down the area, pre-soaking the material, or vacuuming the material as it is cut. Each individual job should be planned with this uppermost in mind. * Effective 1 July 197*3, this limit.edf^is reduced from five (3) to tvjo (2) fibers per cubic centimeter. - 12 - 403751 e w ts o is