Document nmw0NN62qbwVxLN5kKDE5d9aG

TQ 0 gc*'-0`>l As Listed * FROM *.) OiOC*'n J.M. Rainey INTERNAL LETTERHEAD ----- 1 p*- I INI M.| HO. JMR 75-5^5 Subject: OSHA Work Standards The Department of Labor has identified the next eleven proposed OSHA standards which will be published in the Federal Register within the next week, they are: p-tertiary butyl toluene cumene ethyl benzene alpha-methyl styrene styrene vinyl toluene cyclohexane camphor mesityl oxide 5-methyl, 3-heptanone ozone PLAINTIFF'S EXHIBIT I have requested copies of the standards from our Washington office just as soon as they become available. I, suggest a thorough review on the following standards: 1) Cyclohexane - Bay City 2) Ozone - Bishop I do not believe any of the other nine are of interest to us with the pos sible exception of mesityl oxide which is present in low concentrations in the Diacecone Alcohol unit at Bishop. If this assumption is not accurate, please let me know. At the same time, OSHA is revising existing health standards for: lead - reduces permissable exposure limit (PEL) by 502 to 100 micrograms/m^ of air and initiates an Action Level .it 502 of PEL. toluene - reduces PEL to 100 ppm and Imposes Action Level at 502 of PEL. abestos - allows workers to be exposed to 0.5 fibers/cc of air. This Is a drastic change in lh.it the old standard IM'.I. was 5 Clhcrs per cc of air. (A fiber is defined as a particle of abestos longer than five micrometers). Excursions are limited to five fibers in ny 15-minute period as compared to 10 in the old stan dard. A word of explanation. We are still under the Asbestos standard issued on i in. 1972. The new standard is proposed and will almost assuredly have a .c.iew period before it Is imposed on industry. However, I think it would be in order for all plants and terminals to review the old abestos standard and ensure that they are in compliance. Coot1d 010690 Page 2 JMR 75-545 - IO/3/75 We recently had an incident at Celriver Terminal where abestos 6horts were being used to coat the Sparkler Filter in the HCHO unit. The 5-lb bags of .ibestos were not labeled in compliance with the regulation. This was noted hv vi nSHA inspector on another mission. On further checking, he found we had >.le any initial determinations on abestos fibers in the operating area nor ->!!itoicd levels. There were other shortcomings in the area of medical i'a.,1.1, i. .vn anj reporting. We will probably be issued a citation for our sins. Celriver is converting to compacted abestos sheets for coating filter which will minimize dusting and worker exposure. However, they will still have to comply with requirements of the asbestos standard. X would be very interested in information on where asbestos is being used and measures being taken to comply with the health standard. JMR:cc TO: W.H. Meyer Dave Damron J.N. Gann J.W. Dunn W.H. Tuke J.N. Sanborn cc: Dr. H. Kolodner Dr. E. Dlxonv''' W.D. Coble Dr. E.N. Wheeler Don Greeley B.L. Pritchard Paul Sturgis G. McCarroll Jim Wingard J. Petisi M. Sehnert T. Rogers C. Hood 010691